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J. Gordon Edwards, professor emeritus of entomology at San Jose State University in California, has taught biology and entomology there for 44 years. He is a long-time member of the Sierra Club and the Audubon Society and is a lifetime fellow of the California Academy of Sciences. He is the author of several ornithological articles published by the Audubon Society and other environmental groups
During th 1950s and 1960s, the world's major source of DDT was the Montrose Chemical Company in Torrance, California. If that production were to be shut down, the environmentalists realized, there would be a worldwide shortage of DDT and the malaria eradication effort would fall. Soon, the Environmental Defense Fund (EDF), a private environmentalist think tank, and its cohorts in the Environmental Protection Agency (EPA), engaged in a massive, expensive court fight against DDT in 1972. The "trial" of DDT lasted nearly seven months, and the transcripts of the testimony filled more than 9,000 pages.
The official decision by the EPA hearing examiner, judge Edmund Sweeney, was: "DDT is not a carcinoggenic, mutagenic, or teratogenic hazard to man [and] does not have a deleterous effect on freshwater fish, esturarine organisms, wild birds or other wildlife".
William Ruckelshaus, the attorney who was then EPA administrator, never attended a single day of the hearings and admitted that he did not even read the transcripts. He ignored the judge's decision and single-handedly banned DDT, effectively Jan. 1, 1972. Millions of human beings in Third World nations have died every year, as a direct result of Ruckelshaus's action. Others have suffered avoidable malnutrition, starvation, and debilitating diseases.
Later, the Environmental Protection Agency produced its notorius Toxic Substances Control Act, The Act drew criticism from around the world. It is "an absurd piece of gobbledegook", British science attaché Alan Smith told an EPA meeting in May 1976. As reported in the June 10, 1976 issue of Science, Smith urged that the EPA "not presume to legislate for the Universe and the whole human race.... There is a limit to the number of times even the greatest country in the world can afford to appear ridiculous in international affairs". Smith was applauded by more than 600 specialists who were attending the May 1976 meeting.
William Ruckelshaus was replaced as head of the EPA in 1973 by the tax attorney Russel Train, who was equally unqualified to rule on scientific issues. After pledging not to take precipituous action against pesticides without giving Congress advanced notification, Train surprised even his staff by calling a Christmas Eve press conference to announce his intention of banning chlordane.
A suit by environmental groups urged that dieldrin also be banned. On March 28, 1972, the EPA Advisory Committee unanimously recommended that it not be banned. The recommendation echoed the conclusions of the following authorities:
- The U.S. Food and Drug Administration committee (1965)
- The National Academy of Sciences, National Research Council committee (1965)
- The Gunther Committee (1967)
- The USDA Agricultural Research Science committee (1969)
- The Wilson Committee of the British Department of Education and Science (1969)
- The Mrak Commission of the Department of Health, Education and Wellfare (1969)
- The World Health Organization Food and Agricultural Committee (1970)
None of these scientific authorities influenced Russell Train, who personally disagreed with them and took it upon himself to ban dieldrin.
The EPA redefines "cancer"
To carry out his political goals, Train next redefined the medical term, "cancer", lumping together benign tumors and malignant cancers so that even temporary and harmless swellings could thereafter be referred to as "cancer". Invoking the sloppily worded Delaney Cluase of the Food and Drug Act, Train could then easily ban any chemical that fit his new definition of "cancer". The actual wording of the Delaney Clause is as follows:
- no additive shall be deemed safe if it is found to induce cancer when ingested by man or animal, or if it is found, after tests that are appropriate for the evaluation of the safety of food additives, to induce cancer in man or animal."
The shortcomings of the clause are obvious. What is a food "additive"? How can it be "found to induce cancer when ingested"? What tests are "appropriate for the evaluation of the safety of food additives"?, and who decides? A perfect example of a carcinogenic chemical that would have to be banned under the clause is table salt.
Bizarre Testing Standards
The greatest difficulties with the EPA bans however, have been the absence of any rulings on what tests are "appropriate" for food additives and the position that insecticides that are used only to protect people from pests are "food additives!" A report by concerned government scientists urged that "no bizarre tests" should be the basis for banning an additive. In the case of government tests on saccharin, obviously was bizarre to force feed rodents as much saccharin every day of their lives as a human would ingest in 500 cans of diet cola.
Injecting concentrated chemicals into the blood and pumping pure chemicals into the stomachs of neonatal mice are certainly bizarre and inappropriate, too. Routinely, animals in all tests were fed the "maximum tolerated dosages" of chemicals (that is, any higher dosage would be acutely toxic and would quickly kill them). Dosages that high would give misleading results because they would overwhelm the normal protective response of the body.
Another key point is that DDT and chlordane are not food additives, nor were most of the other chemicals that were banned on the basis of the Delaney Clause. These are just a few of the reasons that scientists have so bitterly opposed the missaplication of the Delaney Clause. Although it has been under attack by scientists for decades, it is still in place, and the faulty definition of "cancer" is still relied upon by the attorneys who run the EPA.
The Phony Pesticide "Hot Line"
On May 15, 1975, an EPA radio broadcast claimed that "hundreds of thousands of Americans farmr workers are injured every year by pesticides". And that "hundreds of them die annually". That fabrication came from a 1970 statement by a spokesman for farm worker organizer Cesar Chavez. After strong objections from scientists and health officials, the EPA apologized saying; "We used those statements in good faith, thinking they wre accurate, and they turned out not to be accurate... they cannot possibly be substantiated".
Nevertheless, Train's EPA used that very claim as the excuse to inaugurate a "hot line" that anyone could call, toll-free, to anonymously report the misuse of pesticides. The New York Times, via the Freedom of Information Act, discovered that the toll-free number was not an EPA number, but was in Chavez's National Farmworkers' Information Clearing House. The Times also learned that it was financed by the U.S. Labor Department via Antioch College, in Ohio. After violent congressional criticism, the "hot-line" was finally shut down.
Train left the EPA in 1977, and joined the board of directors of Union Carbide Corporation (the same that was responsible for the Bhopal tragedy in India). Later he became president of the World Wildlife Fund, which is now the Worldwide Fund for Nature (WWF), where his salary far exceeds $100,000 annually and his gift for untruthful propaganda has free rein.
Why is all of this important? Simply because it reveals the nature of the leadership and the methods of operation of the powerful EPA. Can responsible public health, agriculture, or industry long survive under an EPA whose capricious zeal so greatly surpasses its expertise?
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