from Acting Medical Officer of Health, Hastings Prince Edward Counties, 2005
TRANSCRIBED FACSIMILE FROM ORGINAL LETTER
website posting December 27, 2005
A. C. Goddard-Hill
Acting Medical Officer of Health
Hastings-Prince Edward Counties
Ontario, Canada
March 14, 2005
Dr. Karen Dodds
Executive Director, PMRA
Health Canada
2720 Riverside Drive
Ottawa, Ontario
Dear Dr. Dodds:
Recently we at the Hastings-Prince Edward Board of Health received a presentation from Quinte Watershed Cleanup Inc. They have reminded us of the review by the Ontario College of Family Physicians of 300 human health studies on which OCFP has based its recommendation that cosmetic pesticide use be discontinued for reasons related to human health. The OCFP is supported in that recommendation by a number of other credible organizations.
The pesticide industry is now apparently lining up to refute the OCFP Report. Ontario Medical Officers of Health have recently received an invitation from Croplife Canada (formerly the Crop Science Institute, the trade association representing the manufacturers, developers and distributors of plant science innovations - pest control products and plant biotechnology - for use in agriculture, urban and public health settings) to hear an American consultant present a seminar for critical review of the OCFP report. Registration fees for MOH's are to be waived.
The controversy has been complicated by a recent announcement by Health Canada, which is the Canadian pesticide regulator through its arm, the Pest Management Regulatory Agency, PMRA. They have reviewed a specific herbicide, namely 2,4 D, sometimes known as Killex. It is apparently their opinion that this chemical is safe to use. There are 69 name brands of 2,4-D on the market, 23 of pure 2,4-D, and the remainder a mixture with mecoprop andlor dicamba.
However, the PMRA document entitled Re-evaluation of the Lawn and Turf Uses of 2,4-D, and the uses to which it has been put by the (American) Industry Task Force 11 on 2,4-D are troubling. In this document the PMRA concludes that 2,4-D used to treat lawns and turf "does not entail an unacceptable risk of harm to human health or the environment." But what do these words mean? Do they mean that 2,4-D "is not unsafe" (in another circumlocutory double negative used in the interpretation of Risk Assessments in another context.) Or do they mean that 2,4 D is "safe". If so, why not say so?
Furthermore, to whose definition of "acceptable risk'.' is the PMRA referring? Would that be the chemical industry's definition, or that of the children of Canada?
The message from the PMRA document seems to be that, according to the agrichemical industry, 2,4-D will (a) not harm you if you are a laboratory rat; (b) probably not harm you if you are an adult male, although the evidence about cancer risk is a little fuzzy; (c) perhaps not harm you or the embryo/fetus that you are carrying if you are a woman of child bearing age, as there are some uncomfortable issues surrounding reproductive and developmental neurotoxic effects; (d) have unknown effects if you are child, as we do not have the foggiest idea about the implications of 2,4-D for children's health and in particular childhood cancer as the studies have not been done and anyway it is not within our terms of reference or the scope of our study. Therefore we will just continue to the pedal the stuff and expose children to it until such time as epidemiology has the opportunity, and develops sufficient power, to tell that us if there is indeed a problem.
When it comes to that, who is the PMRA? As we have discovered, it is not so easy to find out. Who are the members and what are their affiliations? Does it comprise a balanced representation of independent academics or is the agricultural chemical industry disproportionately influential on the PMRA?
At least the composition of the 2,4-D Science Advisory Panel, which concurs with the "general thrust" (an unfortunate image) of the PMRA evaluation, is more transparent in its membership. We learn that it is composed of two federal civil servants (one Canadian, one American) and three academics, two of whom are employed by the University of Guelph.
Unfortunately for the PMRA their Science Advisory Panel has not proved to be entirely compliant, almost to the point of writing a dissenting opinion in the document. The Panel has insisted on reminding us that they have been unable to reach a conclusion on the classification of 2,4-D as a human carcinogen. In other words they concur with other regulators that 2,4-D is an IARC Group D unclassifiable compound.
The Panel goes on to insist that childhood cancer issues should receive greater attention. Amazingly, the PMRA maintains that a discussion of this issue is "beyond the scope of this document." Once again this invites the question, to the PMRA, as to whom do you serve, the chemical industry or the country's children?
Even the labelling advice given in the document is revealing for such a safe compound, if not entirely practical. "Keep out of the reach of children." "Avoid application when heavy rain is forecast." "The use of this chemical may result in contamination of groundwater." (Complicated advice is included as to how to avoid this eventuality, which presumably will largely be observed only in the breach.)
The history of this issue is that in the 1960's Agent Orange was produced for use as a defoliant. This was a mixture of 2,4,D and 2,4,5,T, and its use was shown to cause certain kinds of cancer and other disorders. This was probably attributable to a contaminant that was found in the mixture, namely dioxin. It is said by the industry that modern versions of 2,4,D do not contain dioxin, although apparently this carcinogen is still released as a by-product of herbicide production. An article in the New York Times recently appeared (February 28, 2005) in which we were reminded that twenty years ago another group, namely the American Vietnam Veterans, took the position that a herbicide (Agent Orange) had caused serious negative health effects when it was used twenty years before that in the jungles of Vietnam. The veterans sued the agricultural chemical industry and the US government. In the face of evidence, in that instance related more to dioxin contaminants, of negative health effects from Agent
Orange, the seven defendant companies in Agri-chem dug in their heels and denied the allegation. The outcome was that the courts found in favour of the Veterans and awarded them $180 million. Now twenty years later the OCFP has taken a similar position on pesticides and once again the chemical industry has dug in its heels.
Should we believe Health Canada's assessment? Perhaps not.
On the one hand, Health Canada, and the PMRA specifically, is a small unit which has a tiger by the tail. They are charged with the responsibility of regulating a behemoth of an industry made up of multiples of multinational companies with virtually unlimited resources. The PMRA does none of its own research, but simply reviews research done by the industry. (The PMRA assessment has been done in parallel with a review (2004) by the U.S. EPA.)
However, there may be a problem when these corporations do the research on which government regulators make decisions. It is known that corporations sometimes do not release research results which are unfavourable to their product. Corporations have developed the nasty habit of sometimes releasing only those studies which support the position that they are promoting, a practice revolting in its lack of scientific integrity. Someone, a Health Canada official 1 believe, coined this as "tobacco science", as the initial examples emerged from investigation of the tobacco industry.
The classic example was the British American Tobacco Company which for years concealed their own scientific research evidence which showed that cigarette smoking caused addiction. This research was only eventually revealed through the good conscience of a whistle blower on the inside of the corporation
Now we have recently learned about Phillip Morris (The whole truth and nothing but the truth? The research that Flhillip Morris did not want you to see. The Lancet, Feb 26,05) which has been revealed to have created a puppet arm's length company in the 1970's, INBIFO of Germany, which did research which could not be linked to Phillip Morris, but from which the latter could select the work that supported its position with respect to the safety of cigarette smoking. They had discovered at that early date that side stream smoke was more dangerous than mainstream smoke, but suppressed the information.
Then we move on to the very recent example of the Merck Corporation, makers of Vioxx. Vioxx was approved for use by the two federal drug regulators, the FDA and Health Canada. Health Canada now says that Merck concealed evidence that Vioxx was causing heart disease and stroke from which many patients died. The editor of the Canadian Medical Association Journal recently said that the two federal regulators "failed miserably" in their role. Health Canada responded that it did not have statutory power to access corporate drug research once the drug was approved for sale.
I refer to this case because 1 just want to raise the question as to whether the same regulatory problem which occurred with Vioxx could apply in the case of Killex.
In the case of 2,4,D the Canadian and American government regulators were advised by the "Industry Task Force on 2,4,D Research Data", which is based in North Carolina. This task force paid for, by coincidence, 300 research studies to comply with the Health Canada requirement for re evaluation of 2,4,D. Presumably this review was done in response to the OCFP report.
This Task Force is made up of the corporations which make and market 2,4,D: Dow Chemical (US), Nufarm (Australia), Agro-gor (US and Argentina), and PBI Gordon (US). -
The Industry Task Force quotes the "Family Farm Exposure Study", done by the University of Minnesota and funded by the "Family Farm Exposure Task Force", which consists of Monsanto, Dow Chemical, Bayer, Dupont Nemours, FMC and Syngenta Corporation, all of which are huge multinational agricultural chemical corporations. Taken together these constitute a consortium of nine chemical companies, even more than the seven that went eyeball to eyeball with the American Veterans.
Incredibly, although not surprisingly, the ITF II has put their own spin on the PMRA conclusions by distorting the conclusions of the SAP and as well the USEPA, WHO, and the EC in not reporting the inconvenient points made by the SAP despite the latter's agreement with the "general thrust" of the PMRA report; by not mentioning that 2,4-D as a carcinogen is in the Class D, "unclassifiable" category; and by highlighting the 2004 USEPA review which showed that "there was no additional evidence to implicate 2,4-D as a cause of cancer" without mentioning its continued "unclassifiable" status which indicates that a degree of uncertainty remains on this issue.
To conclude, I think that the evidence marshalled by the OCFP, of some 300 health studies, is significant. The OCFP recommendation is supported by a number of credible organizations. I do not believe that their position has been neutralized by the industry studies on which Health Canada's conclusions are based. I am troubled by Health Canada's position on this issue.
Pesticides are rather like antibiotics. They are very useful for certain purposes. However, using pesticides against the common dandelion is like using antibiotics for the common cold. It is unnecessary and may do harm. When it comes to such frivolous uses of agricultural chemicals this is the position that the PMRA should be promoting. By such means the children rather than the chemical companies of the country would receive the benefit of the doubt.
Yours truly,
BOARD OF HEALTH FOR THE HASTINGS AND PRINCE EDWARD COUNTIES HEALTH UNIT
A. C. Goddard-Hill , B. Sc, M.D
Acting Medical Officer of Health
AGH/ik
Cc Dr. Sheela Basrur, Chief Medical Officer of Health