cBe:wflrc The Zestof the Lemon '(-rime, 0range , 'IQui'fyot, grnyffruit- by ShirleyA. Briggs RACHEL CARSONCOUNCIL, INC. -n-,fn^ ) LJzwazt the Z ett ol thtl tm - on -- i orqnpf rrri wi-th special Citrus may not be unusually fruits contaminated by pesticides, reputati-on but their nutritious as especially foods means that they are sought for children and older people who are more vulnerable As a source to poisons. of popular flavoring, they pervade our food supply, making their toxic residue content important for the public to understand. Imported foods,. a-n important source of our citrus present supply, even more pesticide lnazards than domestic produce. We offer short survey of some aspects of this pesticide use and regulation as an illustrative example of the general situatlon. Feseha Woldu of the Rachel Carson staff the work of untangling the EPA printout of registered for citrus fruits. did much of pesticides S h i n X - e . qA . B n i g g ' s Second Copyright @ Edi.tion fOOO by Rachel Carson Council, Inc Covett: pontnaLt bu,st ct( Rache,L Canton by IJna Ha.nbunq, NaLLctna(Pontnai-t Gatlenql . Photctctnaph by ShLnIe q A. Bn Lgg.t Rachel Carson Council, Inc 8 9 4 0 J o n e s 1 1 1 .1l R o a d Chevv Chirse, llD 20815 f or orange, J.ime, kumquat, -- reference to dicofol and ethylene dibromide It did not matter, said the man from Rohm and Haas, pestici-de dicofol that their was being sprayed generously crops, because we on Southwestern U.S. cotton and citrus do not eat cotton, and 90 percent of the chemical stayed in the outer peel of citrus fruit, "which is not used for The July 8, 1985 meeting of the Environmental food." Protection Agency's Sci-entific Advisory Panel on pesticides EPA specialists, was attended by the usual mlxture of the industry Panel itself, conand people from the pesticide Aside from a reporter cerned with the topi-cs of the day. from a trade journal, I could see no one else representing -- a common situation. At the time for the general public pub11c comment, therefore, that citrus I rose to insist peel is indeed used for food. lt{armalade and candied peel food aslde, recipes for lemon, 1ime, or orange ffavored amount of the "zest specify that the cook add a certain is needed, and may fruit of the lemon" or whichever other the outer, explain more clearly that this means grating is flavoring Commercjal citrus colored part of the peel. flavored outer peel in the made from this intensely ol1y, is an oi1 soluble form of citrus Since dieofol oi1s, product, ce]1s in the oi1-fi1led it does indeed concentrate is How much of thls may be released as fruit of the pee1. to mingle with the juice and thus remain squeezed for juice, juice? This may be thought concentrate in fresh or frozen desirable, enhancing the flavor. I tried After to find out whether prothe hearing, may either remove some of cessing of peels for citrus oil remain. or concentrate them, but questions the contaminants Citrus From the U.S. Department of Agriculture and Tropical a in Winter Haven, Florida, I received Fruits Laboratory copy of the Food and Drug Admi-nistration's "Good ManufacPractices il{anua1" and the forms used by i-nspectors turing quoting the plants, processing and a letter of citrus Servlce offlcial, Florida Fruit and Vegetable Inspection aI1 Dr. M. Dougherty, assuring that the state monitors products in the state, and they have not found manufactured The inspections level. any residues above the FDA tolerance gas-liquid include chromatograph analysi.s for pesticides In the general known to be used on crops in the state. rules for plant inspection the emphasis is on sanitation common to al1 food processing, with much washing of fruit, withj-n peels. oils though this would not necessarily affect Inspection in bins is mainly concerned with of raw fruit and decayed removing damaged fruit, washing bins 1f iuice with anythlng fruit has adhered to them, and a preoccupation sentence A disconcerting that coufd attract fruit f1ies. seasons when says, "Frequent spraying is necessary during may be What pesticides t l r e D t t c t . t o p h L . L af 1 y i s n u m e r o u s . " I from the used? How much exposure to pesticides results ttreatments' various and how during storage and shipping, is the frui-t often or adequately checked between E{rower state and consumer, may depend on horv manl' jurisdictions, done are involved. and federal, Testine is of necessity on a sampling basis. More distqrbing corunents came from the person at USDA's to whom I first cltrus laboratory spoke on the telephone. processed in I[hi]-e they could send information on citrus Florida, trees this was less relevant Their citrus now. in had been so widely damaged by disease and freezlng years that much of the recent and products fresh frult now come from other with no countries, BraziT, largely telling what pesticides and methods they use in countries with minimal pesticide regulation. If you check the fine print juice, you may find the on labels of frozen cltrus Florida Brazil-. source as Florida, and Brazil, or just of fruit Can lnspection and products at time of importing deal with the problem? Florida says they sample products each lot of all made in the state, but Federal sampling is done on a more random basis. And without knowing which pesLicides can be only lo look for, testing a stab in the dark. o utL thn-ee airn.t Our inquiry has three purposes: to alert consumers pee1s, to provide to possibl,e hazards 1n the use of cltrus some insight into the procedures and assumptions of EPA as it resporrds to its pesL icide registrarion and testing obligations, and to illustrate L h c s c w i t h t w c - ri m p o r L a n t recent investigations of dlcofol and ethylene dibromide. Dlcofol is a close chemical relative of DDT; both for the lethal degrade to DDE, the chemical responsible for the neareggshelJ--thinning Lhat has been responsible of such birds as the ba'ld eag1e, peregrine d.LcodoX,e x t j n c t i o n falcon, and brown pelican in much of North America before the ban on DDT in \972. DDT also degrades to dicofof. A 1972 study cited in Calvin f our. volume "llletabolism Menzie's of Pesticides" is as sood or better indicated that dicofol a precursor The environmental of DDE as is DDT. impact of DDT, on birds was a principal and many other creatures, for many decades, and its reason for its ban. It persists for the fatty of anima1s means that it affinity tissues accumulates in the bodies of animals and results in much in food chains. It is thus a lons-term bioaccumulation hazard to us and our fellow crea"tures, especiallv those us at the top of food chains. like Its immediate toxicity effect, comes from its nerve-poisoning but it was also shown to cause cancer in mammals. After the ban, bjologist.s r i ' c - . r cp l r : a s e d t o f i n d t h a t DDT levels in animals iLnd in soil ancl w:rter were decreasing or steadilv. By 1983, howcver, stuciies shorved continuing 1n the southincreasing Levels in birds, bats, and fish come from illegal Could this western Unj-ted States. use Mexico) or from airborne dust? of DDT (stil1 ava11ab1e in dicofol A more 1ike1y source rvas discovered: in common use and cotton crops, contained consldin the area, for citrus erable amounts of DDT, from about 9 to 15 percent. Whv DDT not applied? conta'ining had the 7972 ban on products officiils in 1957. Agriculture Dicofol was reglstered may surel-y knew by lb72 have known then of the DDT; EPA experts was present, according to William the DDT contamination A. jn achieving the DDT ban. instrumentaI Butler, the lalyer IVhen the dicofol case came up 1983, he wrote to EPA to point out that the 7972 ruling should still apply, and ruling a1-1 they needed to do was lnvoke the earlier and The fact that they had not the market. take dj-cofo1 off ingredients' listed DDT or its kin among the 'active on by others the 1abel may account for its being overlooked for action. responsible al-1 this but EPA rvas sti11 time, lt as a new case. EPA chose, horvever, to treat learned the excuse given for Dr. Butler subsequently Because the presence to be marketed. havj-ng allowed dicofol it somehow did not ki-n was 'unintentionaf of DDT and its pests, and so by defiagainst target Though active count. In a t i ' av g' f, a i l u r e n i+inn to liSt On the 1abel was sOmehow 4LUf llrLrurr lega11y or at least in fact, construed to make them inactive of reality and the clear intent Biological unaccountable. t l-ro I orv inara ! a^lrq ! Y q * t I I rz 4 J i qnnrerl In October, 1984, EPA proposed to cancel registration nf rlinofnl whinh uas identi fied as a health and environbut also for mental hazard not only for its DDT content, DDE, DDD, and tetrachloro-DDT it contains, the related all causing serious adverse effects on human and emvironmental they could health. Rohm and Haas objected, claiming that reduce the content of DDTr (the collective name for all four unwanted contaminants) to 0.1 percent by July 1987. This would suffice, they claimed, to reduce damage to an endurable 1evel, since it was about the same as the background leve1 in the areas. Wh11e EPA did not agree that risk/ problems, they made the required this would solve all to benefit balance and decided that the economic benefits growers exceed the risk to environment and consumers at the 0.1 percent 1eve1. Their formulas for equating possible are farm profits with overall environmental degradation complicated Risks are mostly and inevitabty arbitrary. Dicofol borne by others than those who gain the benefits. but is used to ki11 mites, not only on cotton and citrus, (including on turf lawns), seed crops, stone and pome fruits' figs, vegetabl es, smal I -truits, t r e e n u L s , r , n i n t, g r e e n h o u s e crops, and agricultural house plants, and in commerclal of the buildings. account fot 67 percent Cotton and citrus U.S. use, however, estimated by EPA aL 2 to 2.5 million pounds when the ban was proposed, In Apri1, 1985, EpA ruled that of dicofol be reduced, to 2.5 percent levelsofDDTr by June 29, were to r.986, and 3 the fi.rst to 0.1 by December 1988. Rohm and Haas failed products deadline, and their were taken off the market ti11 in they were able to comply, but other firms had no halt production. By August 1987, Rohm and Haas were back, and they and other producers were able to show EPA by March 31, 1988, that they could meet the December 31 date for 0.1. The 2.5 products may be sold until December 31, and used March 31, 1989, after until which all must be down to 0.1. Part of thi,s arrangement to affow the manufacturers dicofol if brought to specifications to continue marketing from Rohm and Haas of $350,000 to help was a contribution now an the peregrine fafcon, fund a program assisting to increase its population' endangered species in CAlifornia, poisoned Just how the money could compensate for a contj-nua1Iy was not made cl-ear, since the idea must be to environment 'background The normal original ranpie. to their birds return poison even at the DDT is zero, and a cumulative l-evel'of at the top would continue to concentrate levef O.f percent ours and the falcon's. of food chains, by Laurie l{ott expertlv EPA's action was criticized Resources Defense Fund' Campbell of the Natural and Faith that the declsion "is shocking" and that EPA and stating of Endangered Species in the Department of the the Office pressure, and Interior "have backed down, due to registrant use of a hj.ghly DDTr novr propose to al1nw the continued It also is shocking that the contaminated pesticide. of findine their in modifying agencies are so 'flexible' The March' 1986 jeopardv jeopardy to endartgered speeies. f unding of a f ails to expli:.in lrorv the registrant's opinion program in one part of California falcon egg manipulation j-n Texas, New trtlexico' protect of falcons the populations will months before were and elsewhere which OES had found iust falcon the peregrine Furthermore, threatened by dicofol. not producing is currently California population in central -- indeed EPA It ls obvious eggs able to hatcli in nature. experts have admitted -- that the five year period proposed pro.iect will not be long for the peregri-ne egg manipulation persistent and bioaccumulating enough to overcome the highly how can the Fina1ly, reproduction. DDTr to a11orv natural on the rate of recovery agencies fal1 to address the effect the brorvn including endangr:red species, other of several and wood storks, pelicans, bald e:rg1es, Everglade-s kites, peregrine -fa1c.ons Inentioned jn the tr'larch, 1986 Arctic op in ion?" recommended "We urge EPA and OES thev In conclusion, to back dorvn on the decisions tentative their to reevaluate p r e v i o u s l y p r o l t ( ) s e d b : r n . A n i m n r c dj a t e b a n o n D D T r r : o n t a m i n research i s n e e t - l e <. 1 F u r t h e l ' n l ( ) r e , a f a s t . - t r a c k itt-,d dicolol djtrr.rlol iLsc:lf -- rvhich is inio the imp:rcts of ef fort lc1at ed to DDT i tst-'I f :rnd probu.bly has structurallv closely The dicofol effect.s -- must immedi:rLe1r'begin. simjlar (-()ntintting tlse of a pesticide procr:edings, by allowinfl causing .jeoparclv to endangerecl spec j es if the regi strant 4 manipulatj-on after-the-fact agrees to pay for limited of Jay Hair of the eggs, sets an unacceptabl-e precedent." protests made similar Federation National \fildlife to Lee Hodef of Interior' Thomas of EPA and Secretary 1986 proposed rule followed the April These protests oermissive ruling i-n by EPA, but dici not deter the f inal on the DDTr component, concentration N{iy. Irtstead of this give a ful1 j-s, EPA might better review to serj,ous as this it causes cancer in s h o w s , c h a r t o u r A s dicofol itself. is high by oral ingesimmediate toxicity its test animals, by whi-ch i-t tion, and up to very high for dermal toxicity, skin and into the bloodgoes directly through the intact have yet to be made. tests itream. Many important an earlier repeated round rvith dicofol Our experience (EDB). At both the EPA and the FDA with ethylene dibromide fumigant in 1984, I also of this thq.Lene h e a r j . n g s o n c a n c e l l a t i o n LbictrwLdze n c o u n t e r e d t h e c l a i m t h a t i t w a s n o t a p r o b l e m i n c i t r u s I\tlyinsistence peels because they "are not used for food. " impression made 1i-ttle that peels are a food item apparently are concerned. One on EPA as far as other investigations a personal enough to raise reacted of the FDA offj-cials of lemon peel in his martini, question: a twist he liked No one synergism be? and what mlght the EDB and alcohol could say. than that of dicofol. is more complicated The EDB story in the United States in 1948, it as a pesticide Registered for nemaLodes in soi1, on fresh was a rvidely-used fumigant, In 1975' the and on stored grain. fruits and vegetables. that EDB causes cancer. determined National Cancer Institute 1977, when the long review EPA did not take action until evidence of carcinoprocess was started. tr(ore conclusive Document ln genicity was found, and EPA issued a Position by 1983' This in 1980 asking phase-out for grain and fruit procedure was going on as more and more evidence lei,surely Fi-na11y and consumers accumulated. c:tf bazard to applicators its own, and banned EDB as a soil Flori,da did inspectionsof Other states because lt was found in groundwater. fumlgant in Septemfirm action suit and EPA took the first followed then Florida fumigant. EDB as a soil ber 1983 in cancelling spurring stores, in grain products in retail found residues A11 uses were and EPA. by other states investigation and fresh fruit stopped or phased out for grain eventually though there were delays to accommodate the and vegetables, produce to the affected export that demands of countries and who asked for time to devise other means United states pests' EPA forbidden and other fruit flies of controlling ott EDB use on mangoes for a couple of vears' was tapering in 1984 ' grain products In phasing out EDB-contaminated h u m an exg a p s i n c o n s i d e r i n g u n e x a m i n e d l e f t r u l i n g EPA's said they would temporarily posure. When tr{r. Ruckelshaus 150-ppb on interon raw grains, 9OO parts per billion tltor and 3O ppb in cooking, further requiring mediate products 5 products, ready-to-eat f wondered what exposures might come to people on hand while the grain was being converted from one stage to another, and the EDR was supposed to be evaporating. How about the cook leaning over a stove turning pancakes while At the 1e.ve1 went down from 150 to 3O ppb? the gathering where these new rules were announced, they had no answer to the question. 6omQaLtelna.ilvaa When it was definite that EDB would be removed from such as methyl use, and other similarly hazardous fumigants, (EDC) would come under bromide and ethylene dichloride grain and fresh scrutiny soon, other ways of protecting fruit Heat and vegetables were rediscovered or proposed. or cold at fevels undamaging to the produce had been used before EDB took over; their feasibility has been shown again. Though some countries sti11 wanted the guarantee against fruit i,nfestation fly the EDB was supposed to give, those who have to handle the shipments realized the dangers to themselves, and began to refuse to touch fumigated shipments, speeding EPA's final- decisions. t I In another example of superior the botany alternatives, department of the Smithsonian fnstitution that had used a close relative specimens, of EDB to fumigate herbarium their found that results at recognized haza-rd to their staff, were just as good from deep-freezing the specimens. For grains, attention has gone to ancient methods. In has Mediterranean for thousands of years grain countries been puL into dry, air-tighL containers, usually carved out of stone and tightll' .sea1ed. f nsects put in with the grain work toward the top for the soon exhausted oxygen and When this is finally die in the top ferv inches of grain. use scooped out, the rest is uninfested. Current versions metal air-tiplht contaj-ners with oxygen removed and replaced gases like nitrogen. with non-toxic Research into biological o f B a . c i L . L u , st h u n i n a t e n , s i d controls has shown that a strain is effective against some pests of stored grain. tNl'La,t ? ?.5e in ci,uuA? Dicofol and EDB are only two of a long list of pesticides registered Many have known for use on citrus crops. serious most have effects health; on human and envlronmental needed for complete many data €iaps in the information Whjle only a few are apt to be used on a given cvaluation. 1ruit, we cannot know the ones used. To suggest the posof pesticides we provide the following sibil ities, list computer I ist registc.red for citrus on EPA's current fruits stages of grolth, sLorage, and shipment against atall all Converting thelr recognized pests. list to an alphabetical sequence of common nilmes pror,'ed m()re compf icated than Different expected. chemical names were given for many of one infTredienL, more. than rvas useful esters and salts h e r e , a n d s o m e . n a m e s r v c , . r en o t o n E P A ' s o f f i c i a l list of names that may be usc'd on fabels. EPA does not guarantee list that this is up-to-date as far as regulatoly action goes, either. EDB had not been removed, nor had toxaphene, * 6 *in 1988 in 1982. Others are in the same kind of offcancelled again, on-again process as dicofol. Two character j-st j-c s indicate whether a pestici-de. rnay juice. A pesticide i.^ ann, be found in the peel or the pulp and can be fixed in the oily outer citrus that is oil-soluble o,!,,^.0 peel, while a water-soluble material may come up through i product Some versatile the plant and into pulp and juice. Our list does not show degrees of solubilj-ty may do both. possible but just indicates which may vary considerably, in the fruit. destination made of living organisms, speciallzed Pesticides bacto act on for examDle, must remain intact teria or fungi, t2rset nests so cannot be solubfe in thelr carrier subsfor a pesticide not directly It is also possible tance. be dissol-ved in another or water to first in oil soluble in oi1 or water, so that solvent which is in turn soluble could be found in parts of the fruit the pesticide not anticipated list. Afl rve can claim is that some of on this grown under the rnay be found in cj-trus fruit the foflowing Some sources offer today. usual commercial conditions or otherwise fruit, whether ca11ed 'organic' untreated such contaminants. sai-d to be free of all HAZARDSTO HUN{ANAND ENVIRONI\'IENTALHEALTH OF DICOFOL AND ETHYLENE DIBROMIDE DICOFOL immediate (sca1e of very high, human/mammalian toxicity: high, medium, and 1ou) oral: medium to high; dermal: inhalatlon ? medium to very high; long-ter-n: carcinogen; data lacking on nerve damage, birth other chronic exposure studies defects,. mutations, to birds immedjate toxicity adverse effects: environmentbl changes; medium; long-term: eg6rshe11 thinning,behavior cumulative. fish: lower reproduction and viability. J ) ETHYLENE DIBROT{IDE :hi1 immediate: oral:high;'dermal human/mammalian toxicity: inhalat ion :high. mutagen; reduced sperm count, egg long-term: carcinogen; teratogen; fertillty;suspect damage to liver,kidneys, eyes, heart., pancreas, spleen, 1ung, Depression o skin, sensitizing nervous system; potentlal central allergic synergism wlth disulfiram,a drug and pesti-cide. toxic adverse effects: environmental high, damages reproduction; ' aquatic organisms' :medium volatile highly Both may persist -rater: dicofol to bir' immediate toxicity fish: medium to high; othe for many months;ED!: 14 years un to 4 vea.r's jn soj.l-. in sterile common or chemical name P E S T I C I D E S R E G I S T B P . E D FOP, CITRUS FRLIITS cornmon or chemical name solubiiity o 11 rvat er acephate a ldi carb aldoxycarb al lethrin amobam az inphosmethyl Eac,LLLu's tpheanLcu.t Baci,LLul tlunengLenti's v . hut stalz'L benorny 1 biphenyl ( diphenyl ) borax boric acid bromacil buty), amine cacodylic acid calcium thiosulfate capt afol captan carbaryl carbo furan chlorobenzilate chl or ine chlorop icr in chlorpyrifos copper (meta11ic) copper ammonium carbon at e copper carbonate copper hydroxide copper oleate copper oxychloride coppor oxychloride sul-f ate copper salt of I aLty and res i n acids copper sulfate copper sulfate monohydrat e cottonseed oi1 cryolite cubd resins cupric oxide cuprous oxi de cvcl ohexane cyhexut i n x x x x x x x x x x x x x x x x X x x common or chemical name solubi 1ity oi1 wa.ter cytogen 2,4-D 2,4-DB da1 apon dazomet di az inon dicamba dichloben i 1 dichlone dichloropropane dichloropropene x dicofol dimethoat e dinocap x dlnoseb x dioxath i on x diphacinone disodium methanearsenate (DSMA) di su1foton diuron endosuf fan endr in EPTC EPN essential X oils ethanol x eth i on x ethoprop X ethylene ethylene dibromide eth5rlene dichloride ethylene glyco1 et rldi azol fenamiphos fenbutatin oxide fenoxycarb fensul fot h ion ferbam fluazi-fop but;71 x fol pet formet anat e hvdroc'h 1or i de fosetvl al uminum 1 1 1 1 ' c ' e rlo HinluteLh thctmp.towii imazal i I kerosenc' x X x x x x x x x x x x x x l-ime sulfur I indane mal ath 1on maleic hydrazide maneb met a1dehyde metalaxyl meth idathion methi-ocarb methomyl methoxychlor methyl bromlde methyl parathion methyl chloride metol ach lor MGK 264 mevinphos mexacarbate monocrotophos monosodium methane(IUSI\IA) arsonate nabam naphtha (heavY, aromat ic ) napht hal ene acid acetic n o nrnn r r s y ^ x x x X X x X x X Y x x solubility rvater oi1 q m i rl o v y E , r , 4 q v nicot ine nitral in norflurazon oxadiazon oxamyl oxydemeton methY) oxyf luorfen oxyth ioquinox paraquat dichloride ^^--+hi^d r ,r r r u var rr x x x x x x X x x x x x x x x x x x x x x x x x X X x x X x common or name chemical s o l u b i 1i t Y water oi1 permethrin petroleum oils phenylphenol phosmet Phqtophtttonn c.Anc;pdlrcnn pine oil piperonyl butoxide polybutene propanoic acid putrescent whole egg solids pyrethrin resmethrin rotenone RqaruLa6pecLo6a Sabad&Ia slmazine sodium cacodylate sodium carbonate sodium cyanlde sodium hypochlorj-te sodium-ophenylphenat e soybean oi1 su1 fur terbacil t et raf idon th i abendazo 1e thi ram toxaphene t r i chlorfon t ri chloroethane ami-ne t riethanol trifluralin xy 1ene zlnc sulfate zineb x x x x x x x x x x x x x x x x x x x x x x x x x x is found ln action SOME SOURCES: the record of regulatory Special Review Decision a succession of EPA publications: stages, at critical Documents, facl sheets and press releases and hearings of the Science Advisory Panel for pesticides, and EDB' them, on dicofol to support bac\eround materials as did various much of the story, The press follolved in NelV l{exico journals, Examples: "DDT:Recent contamlnation and Alexander Krynitsky lnd Arizona?" by Donald R. Clark,Jr., in €nvinc.tnment for June 1983; "DDT in the 1980s: You l'lay in Tho Be Using it in Your Yard" by Richard E. Bonney, Jr' The ReLiving E L n d r l u a n t e t L . L ' 4 ,A u t u m n 1 9 8 5 ; a n d " D i c o f o l : 1984' NCAP Newl, Fall o f D D T " b v l t '.l O ' B r i e n , incarnation I 8 MORE HIDDEN HAZARDS: THE FLORIDA LEAD ARSENATE Barely had we published of this the first edition booklet than new word came of an even more astonishing exanple showing EPA's regulatory health of public dlsregard and concerns. A report reached the National Coalition Against the Misuse of Pesticides (NCAMP) that in Florida the grapefruit rrere sprayed with lead arsenate, not a proctuct to be found on the list we vere given. The practice had gone on for many years, however. The purpose was not todefend against pests or to improve the crop, but simply to permit greater profits bynakinA the fr:uit taste sweet sooner and so be marketable a couble of months earlier than normal. NCAMP's summary of the situation in 1988 follows on page 11. After this 1ead, prominent stories followed in the national press, and all at once action folloved: the sole producer of lead arsenate in the country withdrew it frorn registration, rather than supply EpA vith the required asked for j-n Irgqltt and safety data rhey had, b-1ired1y, 1986. But EPA, by failj_ng to take emergency action that could have removed the remainlng supply-from the market, let the producer sel1 all of it for-bontinulng use on the grapefrui-t as long as it lasted. The estj-rnated amount of 80,000 to 100,000 pounds was thought to be about a Ewo-year supply. Was this total correct? How much more may havl been in the hands of users or distributors alreadyi Since EPA just continued the lengthy review process begun in 197g, it is stil1 1ega1 for growers to use lead arsenaie on their grapefruit until a final decision document on the whole class of inorganic arsenic products is issued. At the time of the 1988 revelation, EpA sti11 labored under the o1d FIFRA provision requiring them to pay for the remaining stock, and for its disposal. After December 1988, hovever, this was not so, and EPA's budget would not have suffered frorn i-nvoking the suspension piocedure, which takes a product off the market at once. The long concellation process now lacks this economic justification. paymenrs to those left holding the bag are made through a Federal Judgment Fund. EPA is thus now freer to rnake objective rulings. Old habits may die s1owly. Had the rernaining stock of lead arsenate been removed by January, 1989, ie could have been spared two remaining seasons oi its use. Nor has this use been confined to early fa11, we later found. Whenever available crop was shorr oi the market demand, the "quick sweetening" procedure vas used. Even if you avoided September abd October grapefruj_t, you were not protected. The history of EPA dealings with inorganic arsenicals shows a remarkably hesitant approach to poisons whose health implications are clear to most laymen. Hazards of arsenic have been known from ancient times, and modern studv has 10 Pesticidesand You News from the National Coalition Acainst the Misuse of Pesticides(NCAMP) EPA AIIousllse of StacksAfter Cancellation C.t taminates Grapefruit, EPA Stands By I,.aa ets"""t" while the nation has tuhed its at' tention to d,u ssmval of lead trom dnntrng water, paint, and g"*rini, u| Florida citrus growe. "* ".-u,,y Dlyinq a lead and ar*nrc.on,.tng in no;ji up is tumint tt"t i-ti.tde srapefruit and trapefut ptoa*" ivhv?8*aurthrsrureriarauowsRoi. ida'qrcwer to begin roketing ""i' sap€fruir a fuil rwo montns eartier ihanwouldotherui*bepo5sible.Ui. protection ng"n.y Environmenrat dcumentsobtarnedbvNcer"lrsrro* wide u*of this matsial amongnorila t,gn or anv eriergencv ;;;;;;;J;; Agenq achon to Protrct aon,u-"ti whrle rhe prachceof addrnSlcad "ni t'"' u"*" una"l li*;:.'i; A;r;ti "s*ial Review" at EPA for ten yea;' and manufacturersbeganprtasingoi ftom ol&".n"t ti isee, t*"ent i"potts used ., . gro*lh mtly hogjend chictos """u'ii-^;'t'iiu,'tL stlmul'nt ln th€hetbicid€usotelcium-mteon turf' the tuntlcide us ot sdtum rF r"g"rly allowable mreongraF'ttll"-1T$tn'"'of grcm 'lnaer Ene's d*nic icid on cotlon rnd oltr r"*it iii"J *lip"riiit toiseed tnallttr*e*3'theAgencyis legaltoteraneis2btirehigher-(lbbi orcmed aboutthe levelsof dsic to aitl;;il; il; ,h;;il;i;i"*iit whichthepublicsexPosed i,ig*ii"ttid-ppul"iarmti-6-hiehet EPAhisokmroitepstowamthe ilil"r;il#-;;ir""erorrop-iJii public rhat Roridr gaFhuirs Nv iJl:i',iTtt;;;!U1t91ry;'Acthe hurdouschemicals and Lntain ildioie n|A in EPI airlSiiar" a"o iNte.di!@ntinuingrlengihvleview iilllii'i#i"*r;--"1t1t"a.,9U"** Grinotuici^pt"tta ati-*rugierrr70ppb)thanthJ;;i;;;;i;i-tii.i f,Jorerupilieottoda*mreanured il;^s:;il;t-""411-11a]l;; -thu yeat' the ProPosed drinling uP $trtime next tugher w;ter studard ot l0 PPI-.T31 '' -t rently found in gaPefruit luice at an a"erite teuelof 70-ipb'-7-tirm above the ^i* rcomended -":lf.,l"u"l tn water' ln 'ddltron'.graPefruil rinds' whichontain thehighestleedsof lead' !E fed to attle' g,ollll:::{* FiJiIiinai.","t'ur """,H:ffi,nffiU$"tlliff: u'^a**ra-*1-T{tl "i.J[Tl""i"ll""J;1'il:!tJJ":H;?""Jv'itipf -'Tff toa propoel Accordins rro undeirtre ;^:#;;; ;* LE sro*i'io sy'*i cau* braindarugc,newous. and symptons diff rfllt to digrdets, from the common coldl distinsish m level otlnr'itg wateiOilice^official' of lead rntestion-is^ete' InaM"arch'lgSSintemlEPAdcu- bvNclYl' mentobtained tt ;;;*s areespalatl'rn:1o"o the tlii *itttout tftu'u*of leadreMte sitive to this metal Arrnic cau*sL io* ii""J" ttru' *au"ty -*otiJ ii verenervoussy5temdiorders'ano - tbeo; 'u* tn$"e' "T" m t t "l l il 'i "otnu.' pg et "tpf l":i1i '"i "i f* o f k iadl n c y , t l u " ' a n o o ' J l a sasttointestrn ; v s t e m t o x i nl t r s a l e a k n o w n n u # i to '"o':t:'"li:ildg ililtt;;i lii .un.,o,,tt'"ptu'"tr" .'u..,nogun, deth f,iJ*g "'Ji' srlie' in thef"ii:" Chem.of Avon Park,Florrda'hass Dlied rts cuslomcrs*'rt' "nougn oiii" ^aterral to trcat 150{n to :tr'uro at'ei this vear. while EPA maintarnsp"ot totrJ x""'p*r"a t:-Tll'::i: P'"d*ing gt"p"ttit u"t"u* it would still bea pioi"it""*ilp-T-;^r?,31,"*""'"' f ron This excerPt June 1966 newstheir bv r e P r i n t e d i s letLer R:iT:;: itit:l t:l:" iil;,i:lti;: Bi;:o'^ ,,.",:^,1,'l,r,'.il;";ii::"1"',::Tf: ft"m;. -$^"fr.;h"ilT: ;"";il;'i;;ilr;i' nrcunl Asai nst Misuse of .lTiJl]i""'ii a":' i" orp",n'i uoi' :: l".iiall"universit{ Fro'i9j i,T: il$l;';;tr*1!:#::Jil'"iffi market,a ruminilF 9f :]'ii: ','$ :T"31"f: ff [il!iff:fj".T[ lffj ;iUiC;n*mffi i;;;';;;;i'ir,"iong"* throughthcncxt two*til.t-1"]il^;assistin the devclopmcntor an ailemd' rE u*s rn most deae oldesrDesticides, is ii* i,il. ph6; out. The Agency iS'.il: ;;;;; ff":':*:l ;11",1":i:Tlff r""au*'ir"'but loro^rv Grapefruit SafetYQuesfloneo ttnrta sffitr#ffiHfiHtr#*: i^B nPl,J.ti* in GtnrsHit onChemical Lsd Arsen& Flrm AtlouedtoUseUpStochof Potentilltl Hamrhus Bv Mkttd W.ifoC i-EYH ci@tcd .!d iirt ;;;Fb.td.;r.&tdu dl d il b bcin3 drntci tt ihc cP$ .o' 'Y-' Asditrt h 'r'bL 8nF rre lod sidc 1t shovn us evidence of longterm dangers not suspected in ti_mes past. Lead toxicity is more recenily known, but with all of the publicity on danage from exposure to leaded paint and gasoline, and leaching frorn lead in plumbing or pottery glazes, few people can be unarrrare. .So we hive cbmbinei two serious and well-known poisons, both of which accumulate in the body, and surreptitiously introduced then into a highly recommended food. Lead arsenate became popular in the 19rh century, when efficacy in killing pests was the sole ai-m, and effects on people and othei non-target species were unnoticed. In time, orchard owners found that areas repeatedly sprayed with lead arsenate would no longer grow young frui-t trees, whose roots were too short to reachbelow the contaminated soi1. More recently, people who used calcium arsenate on lawns against soil found lnsects that they had soll so toxic and sterile that the desj-red turf was itself defeated. A S U M M A R YO F E P A R E V I E W O F I N O R G A N I C A R S E N I C 1978: 1981: 1984: 1986" 1987: 1988: 1990: story. market titute EPA issued the first revierr document, giving what they knew about these products, and what data was required from the producers to obtain re-registration. This covered wood and non-wood uses, on the grounds of causing cancer, birth defects, and rnutations. Soon the reviev was expanded to include the alsq very serious irnmediate poisoning ('acute, effecfs asopposed to rchronic! in toxicological terrninology) Second document issued, stating preli.minary intent to cancel the wood-preservative uses. Final cancellation of some vood uses was announced.. EPA finally asked the sole U.S. producer of lead arsenate to submit the required data. The withdrawal from registratlon by the producer fo1lowed, and the sale of remaining stocks to users. EPA stated intent to cancel non-wood uses, but put off action on lead arsenate, registered as a tgrowth (to protect regulator'on grapefruit those sti11 using it up?), calclum arsenic as a turf (on pesticide lawns frequented by children and pets?), and sodium arsenate as a fungicide on grapes (vineyard vorkers have long been clted as typical victims of occupational arsenic poisoning), and arsenic acid on cotton and okra being gro\{n for seed. EPA said the final cancellati.on would be issued in Apri1. Thlswas then postponed to summer, then late in the year, finally until early 1990. May 10, EPA insisted that the final cancellation would be in the Federal Register in a week or rwo. As we go to the prlnter, t.his remains a continued Readers can carry on the researcl.r: what is on the now? What has happened to the arsanilic acid subsand how toxic is 1t? And note -- NONE OF' THIS AFFECTS THE ORGANIC ARSENIC PESTICIDES. t2 A NEII SIDELIGHT ON CITRUS PEELS Insecticides based on constiLuents of citrus peels diPs' sPrays' are increasingly on the narket as anti-flea and shampoosfoi pets. Many plants develop their ovn c h e m i c a l d e f e n s e s - a g a i n s g i n s e c t p e s t s ' a n d s o m e - m a yb e Little data extracted to use in cornmercial pesticides' such elements lrom citrus has been on on the principal t o m a m m a l sg a v e that the low oral toxicity record,'.*""pL ( G R A S ) r ating frorn the s a f e " a s " g e n e r a f i y re-ognized the Veterlnarians have found Food ind Drug'Adminf"t..tiotr. less reassuring effects frorn use of these flea treatments' D-li-monene and lina1oo1 are the materials i-n question. Cats have been found to be extremely sensitive to some nonbased on crude citrus extracts EPA-registered insectlcides and some cats have died after routi-ne dippi-ng at the labe1 The products are i11ega1r,of course' but concentration. Even unti-l detected' mav come on the mark;t sporadically, d-limonene can cause products using purified fn6 t"gistered listlesslv) and recumbency (lying.around 6i a"pt""iion ;;;"; have caused Excessine ippl:-"ations lasting for several days. tenpw i t h l o w b g * V s h i v e r i n g t r e m o r s ' m u s c l e salivation, (see Hooser, S'S': D--limonene' and staggerinS. T oxLc,ologo . l il S ^ 4 "i iir^ui f" i " o, o i , a n d oil extracts, citius of North " t r r t E cl-1^nics Veterinary cl,-u,"eoZl, D;G;,-init ectect PeaLLctt(ea, o( t0 ,2, tniarcn iOOO) Refertnces in the Jarruary L990 Rzgi,stu'1 A,";;i.;; of occur n s r i r u t e N a r i o n a l C t u i e a L ' S u b ^ t a n c e , 5 " , c , 6 iiii-titiiia Safety and Health' cite Japanese studies showing lp.ii."?f in mice' firttr defects and damage to reproductive systens disturc h a n g e s , b e h a v i o r l a l a 1 s 5 and rabbits, ;;;;; 91eep netabolic damage (1ow temperature) and. spastic ;;;;;"; These studles often uied exposure by injection p.i"iy"l". j'nhalation routes ' than the usual oral , derrnal, or i"ttt.i but the effects echo those in the cats mentioned above' studies from the 1960s Nati-onal Cancer Institute tsuspect carcinogen' category, but place d-limonene in the hows a positive a c u r r e n t t e s t ' j u s t b e i n g p t t rt ct ia" rt tcei nd o, g es n " result for rats: unqualified MaY 1990
© Copyright 2024