6 Dwight Welch, “New Whistleblower Law—Same Old Office of Special Counsel,” Inside the Fishbowl, April 1990, 5. (Inside the Fishbowl was a newsletter of the EPA employees union, National Federation of Federal Employees, Local 2050.) When I called Welch recently, he said he left all the EPA experience behind him and he did not want to remember any of it. “I have 14 boxes of documents, but don’t ask me to search them. I will not do it. I live a different life now,” he said. “Please don’t call me back.” He hung up. This reaction from a warm human being I remember so vividly shocked me. But I also understand it.
7 Memo of November 24, 1987, from Welch to Edwin Tinsworth.
8 Dwight A. Welch, “Management Retribution for Employee’s Diligent Efforts to Protect the Public from Flammable Pesticide Aerosols” (grievance filed with Marita Llaverias, Management Relations Office, U.S. Department of Labor, October 7, 1988).
9 See Welch’s article in the April 1990 issue of the EPA newsletter Inside the Fishbowl. See also Cate Jenkins, “Consultant Abuses at EPA and Cover-Up” (memorandum to Congressman John Dingell, Senator Max Baucus, Senator David Pryor, and Congressman Gerry Sikorski, October 7, 1989).
10 Jenkins’s letter of April 30, 1989, was addressed to Congressman John D. Dingell, chairman of the Committee on Energy and Commerce; Senator Max Baucus, chairman of the Subcommittee on Hazardous Wastes and Toxic Substances, Committee on Environment and Public Works; Senator David Pryor, chairman of the Federal Services, Post Office, and Civil Service Committee; and Congressman Gerry Sikorski, chairman of the Human Resources Subcommittee, Post Office, and Civil Service Committee.
11 Jenkins memo to Reps. John Dingell and Gerry Sikorski and Sens. John Glenn and David Pryor, February 21, 1989.
12 The corruption of consultants and dioxin issues, 1978–90, were part of the suit Jenkins filed against the EPA. The U.S. Department of Labor adjudicated those issues in favor of Jenkins. See http://www.combat-monsanto.org/docs/doc%20scan/Dioxine/Jenkins%20v.%20EPA/?monsanto%20letters%20to%20EPA%20about%20dioxin,%20Jenkins%20case.PDF. See also http://www.combat-monsanto.org/docs/doc%20scan/Dioxine/Jenkins%20v.%20EPA/Jenkins%20vs%20EPA%20case.PDF.
13 Marsha Coleman-Adebayo, NO FEAR: A Whistleblower’s Triumph over Corruption and Retaliation at the EPA (Chicago: Lawrence Hill Books, 2011), 163.
14 Coleman-Adebayo, NO FEAR, 336–72.
Chapter 9: When Will the Well Run Dry?
1 Richard Back of Union Carbide met Frank Sanders of EPA’s pesticide program to break the news: aldicarb had been discovered in amounts ranging from 1 part per billion to 0.04 parts per million. See Frank Sanders’s briefing paper on August 27, 1979.
2 Steven Jellinek letter to David Axelrod, health commissioner of New York, September 4, 1979.
3 We don’t know whether certain fishes may be hypersensitive to malathion—a condition in which the behavior and health of the fish would change without any significant loss, reduction, or depression of the vital nerve enzyme cholinesterase, ChE, the clinical measurement of which confirms the poisoning of the animal. See David L. Coppage et al., “River Pollution by Anticholinesterase Agents,” Water Research 10 (1) (1976): 19–24.
4 See the Biscardi memo of October 17, 1979, to Adrian Gross, who was then the chief of the toxicology branch. See also “Aldicaarb Information Paper,” prepared by the following scientists of the Registration Division: Herbert Harrison, Charles Mitchell, and Frank Sanders, August 26, 1979; Douglas Campt, “Contamination of Ground (Drinking) Water from Aldicarb Crop Use” (memorandum to John Todhunter, April 28, 1982). Campt was director of the Registration Division, OPP, and Todhunter was the Reagan political appointee serving as the assistant administrator for pesticides and toxic substances at the EPA.
5 Maurie Semel, “History of the Colorado Potato Beetle in New York: Control and Development of Resistance to Insecticides on Long Island” (Long Island Horticultural Research Laboratory, Riverhead, New York, February 1980), pp. 1–19.
6 Letter from F. Eugene Hester, acting director of the Fish and Wildlife Service of the Department of the Interior, to Clayton Bushong, chief EPA ecologist, on January 22, 1982.
7 EPA, Office of Policy Analysis, “Agriculture and the Environment: Briefing for EPA Deputy Administrator” (June 22, 1988); Office of Pesticide Programs, Biological and Economic Analysis Division, “An Overview of Pesticide Usage, Groundwater Concerns, and Costs of Alternative Regulatory Options” (May 1989); Office of Pesticide Programs, “Pesticides and Ground-Water Strategy: A Survey of Potential Impacts” (February 1991).
8 EPA, Office of Pesticide Programs, “Combined Special Review of the Triazine Herbicides Atrazine, Simazine, Cyanazine: Briefing for the Assistant Administrator” (August 11, 1993).
9 Tyrone Hayes: www.atrazinelovers.com. Hayes lists his own articles and dozens of other similar articles documenting the devastating effects of atrazine.
10 Lindsey Konkel, “Atrazine in Water Tied to Menstrual Irregularities, Low Hormones,” Environmental Health News, November 28, 2011.
11 Paul Taylor, “Weed Killer Linked to Gender-Bending in Animals,” Globe and Mail, December 1, 2011.
12 Jeff Donn, Martha Mendoza, and Justin Pritchard, “What’s in Our Drinking Water? For 41 million, Traces of Drugs,” Dayton Daily News, March 10, 2008.
13 “Premature Births Peak Seasonally When Pesticides and Nitrates in Surface Water Are Highest,” Science Daily, May 7, 2007.
14 Kathleen Blanchard, “Research Strongly Links Pesticides to Birth Defects,” EmaxHealth, October 22, 2011; P. Monica Lind et al., “New Research links Pesticides to cardiovascular Disease,” ENEWSPE, October 14, 2011; EPA, Office of Policy Analysis, “Agriculture and the Environment: Briefing for EPA Deputy Administrator” (June 22, 1988).
15 According to a 2012 EPA report, fertilizer ends up in surface or groundwater because of bad farming practices and overuse: “excess fertilizer use and poor application methods can cause fertilizer movement into ground and surface waters.” EPA, Office of Water, “Managing Agricultural Fertilizer Application to Prevent Contamination of Drinking Water,” Source Water Protection Practices Bulletin, August 2010. See also George Hallberg, “Agricultural Chemicals and Groundwater Quality in Iowa” (Cooperative Extension Service, Iowa State University, December 1984).
16 Padma Datta,” “Review of Hydrology, Water Quality and Land Management in the Big Spring Basin, Clayton County, Iowa” (Memorandum to David J. Severn and Carolyn K. Offutt, March 31, 1984).
17 See “Absorption of Pesticides in the Course of Occupational Exposure” (March 1977), and “Cooperative Agreement Progress Report” (October 9, 1980), EPA report written in August 1980 by Kenneth W. Kirby and Leon Burmeister, University of Iowa School of Medicine, and John Kliewer and Gill Fuller, Medical University of South Carolina. See also Kenneth W. Kirby and Leon Burmeister, “Cancer Types Among Iowa Farmers” (August 4, 1980). This report says that “greater production of corn and soybeans may be associated with stomach cancer, while soybean production may be associated with multiple myeloma rates.” See also Sheila H. Zahm, Division of Cancer Etiology, National Cancer Institute: there are “high cancer mortality rates among farmers in the midwest,” The Use and Regulation of Lawn Care Chemicals, Hearing, Subcommittee on Toxic Substances, Environmental Oversight, Research and Development, Senate Committee on Environment and Public Works, March 28, 1990 (Washington, DC: Government Printing Office, 1990); D. M. Schreinemachers, “Birth Malformations and Other Adverse Perinatal Outcomes in Four U.S. Wheat-Producing States,” Environmental Health Perspectives 111 (9) (2003): 1259–64; M. Sanborn et al., Systematic Review of Pesticides: Human Health Effects (Ontario College of Family Physicians, 2004); U.S. National Cancer Institute, Cancer Trends Progress Report, 2007; Molly Jacobs and Dick Clapp, “Agriculture and Cancer: A Need for Action” (Lowell Center for Sustainable Production, University of Massachusetts, and Boston University School of Public Health, October 2008); S.-J. Lee et al., “Acute Pesticide Illnesses Associated with Off-Target Pesticide Drif
t from Agricultural Applications—11 States, 1998–2006,” Environmental Health Perspectives 119 (8), (2011): 1162–69; M. Antoniou et al., “Roundup and Birth Defects: Is the Public Being Kept in the Dark?” Earth Open Source, June 2011; D. Brandli and S. Reinacher, “Herbicides Found in Human Urine,” Ithaka Journal 1/2012 (2012): 270–72.
Chapter 10: Fallout
1 Wiggins’s speech was published in the spring of 1983 in the Bulletin of the Entomological Society of America.
2 George M. Woodwell, “The Challenge of Endangered Species,” in Extinction Is Forever: Threatened and Endangered Species of Plants in the Americas and Their Significance in Ecosystems Today and in the Future, edited by Ghillian T. Prance and Thomas S. Elias (New York: New York Botanical Garden, 1977), 5–10.
3 David Pimentel, “Pesticides: Environmental and Social Costs,” in Pest Control: Cultural and Environmental Aspects, edited by David Pimentel and John H. Perkins (Boulder, CO: Westview Press, 1980), 99–137; “Environmental and Economic Costs of the Application of Pesticides Primarily in the United States,” Environment, Development and Sustainability 7 (2005): 229–52; E. F. Knipling, “One Hundred Years of Entomology—Past and Future,” Journal of Economic Entomology 47 (3), (June 1954): 545.
4 David Pimentel and Lois Levitan, “Pesticides: Amounts Applied and Amounts Reaching Pests,” BioScience 36 (2), (February 1986): 86–91; Pimentel, “Amounts of Pesticides Reaching Target Pests: Environmental Impacts and Ethics,” Journal of Agricultural and Environmental Ethics 8 (1995): 17–29.
5 David Pimentel and Michael Burgess, “Small Amounts of Pesticides Reaching Target Insects,” Environment, Development and Sustainability 14 (2011): 1–2.
6 Meeting with David Pimentel, November 3, 1981, Crystal Square #4, Crystal City, Arlington, VA, OPP, EPA.
7 EPA position paper 2/3 on toxaphene, December 12, 1980.
8 Dave Severn, “Toxaphene” (note to Edwin Johnson, February 16, 1982, OPP, EPA); William Dickinson, “Toxaphene” (memorandum to Edwin Johnson, February 22, 1982, OPP, EPA).
9 In 1955, the U.S. Department of Agriculture’s toxaphene scientists approved 7 parts per million of toxaphene in crops. The government’s decision on how much toxaphene people could “tolerate” in their food did not reflect some kind of scientific evaluation of toxaphene’s toxicity; my guess is that they simply borrowed the number from the legal tolerance number of DDT.
10 Cited in a memorandum of William Dickinson, Deputy Director, Special Pesticide Review Division, to Edwin Johnson, Director, Office of Pesticide Programs, EPA, February 22, 1982. See also EPA position document 2/3, dated December 12, 1980, stating that toxaphene ought to be banned for all uses except for cattle dip.
11 Memo from David Severn and Joseph Reinart, February 16, 1982.
12 Congressional Record, August 11, 1982, p. H5670. See also press release by the office of Congressman Yates: “Yates Reveals New Threat to Lake Michigan—Proposes Ban on Insecticide [Toxaphene] Found in Great Lakes Fish,” July 23, 1982; Irvin Molotsky, “E.P.A. Plans to Curb Use of Toxaphene, a Pesticide,” New York Times, October 17, 1982.
13 See Cook memo to his colleagues on September 21, 1983.
14 See Rosmarie von Rumker’s July 1974 study, “Farmer’s Pesticide Use Decisions and Attitudes on Alternate Crop Protection Methods.”
Chapter 11: The Hubris of the Reagan Administration
1 See “Results of National Urban Pesticide Applicator Survey by EPA,” 1984.
2 See EPA report, “National Household Pesticide Usage Study, 1976–1977.”
3 Note from James Touhey to Edwin Johnson, September 7, 1983. Touhey was then the director of the Benefits and Use Division, OPP, EPA, and Johnson was the deputy assistant administrator or director, OPP, EPA.
4 Adrian Gross long ago showed that malathion and its oxygen analogue, malaoxon, cause cancer in both rats and mice. He also demonstrated that people eat five times more malathion per day than the maximum permissible level, and he warned that as many as four people per thousand are in the upper limit of possibly getting cancer from malathion. Adrian Gross, “Carcinogenicity of Malathion” (memorandum to Kevin Keeney through James Touhey, April 24, 1984, Office of Pesticides and Toxic Substances, U.S. EPA).
5 Joel A. Mintz, Enforcement at the EPA: High Stakes and Hard Choices, revised edition (Austin: University of Texas Press, 2012), 42.
6 William Sanjour, “In Name Only,” Sierra, September/October 1992, 99.
7 “Anne Gorsuch Buford, 62, Dies; Reagan EPA Director,” Washington Post, July 22, 2004.
8 Sarasota Herald-Tribune, May 19, 1983.
9 Richardson discussion with the author, September 22, 1983.
10 Martin Crutsinger, “Reagan Orders Full Probe of EPA,” Associated Press, February 17, 1983.
11 See the August 1984 report “Investigation of the Environmental Protection Agency.”
12 EPA, “National Nursery Pesticide Usage Survey” (1984).
13 EPA, “Health Assessment of Pesticide Applicators in an Enclosed Environment” (1984).
14 EPA, “A National Survey of Pesticide Usage of Golf Courses in the U.S.” (1984).
15 Ibid.
16 EPA, Office of Pesticide Programs, “R.E.D. Facts: Thiram,” September 2004.
17 National Corn Growers Association, “World of Corn,” 2013.
18 See “Minutes for the First Meeting of the Interagency Task Force on Seed Treatment” (September 11, 1986, OPP, EPA); Edwin Tinsworth, “Note to Douglas Camp” ([1986], OPP, EPA); Eugene Wilson, Product Manager, Fungicide-Herbicide Branch, Registration Division, “Chronology of Recent Meetings Regarding Detreated Seed Corn” (memorandum to Frank Sanders, Chief, Fungicide-Herbicide Branch, Registration Division, OPP, EPA, January 27, 1987). Wilson wrote: “Illegal residues of heptachlor in milk reported by FDA [U.S. Food and Drug Administration] in 1986 were a result of feeding [the fungicide] captan and heptachlor detreated seed corn to dairy cows.”
19 EPA, “Environmental News,” September 10, 1976; testimony of Jack Griffith, Office of Pesticide Programs, to the Subcommittee on Health and Scientific Research, Committee on Human Resources, U.S. Senate, June 8, 1977.
20 EPA, “Pesticide and Toxic Substance Residues in Humans from the Second Health and Nutrition Examination Survey, 1976–1980,” October 1983.
21 John A. Todhunter received a Ph.D. from Berkeley in 1976. According to the American Presidency Project, he was a fellow at the Roche Institute of Molecular Biology, Hoffmann La Roche, Inc. When appointed to EPA on November 13, 1981, to the EPA, he was an assistant professor of biology at the Catholic University of America. He was fired on March 25, 1983.
22 Edwin L. Johnson, “PCB’s in Human Blood Serum,” note to Don Clay, June 20, 1984. Johnson and Clay were senior officials at EPA.
23 See Nicole Ostrow, “Exposures to Pesticide in Utero Linked to Brain Abnormalities,” San Francisco Chronicle, April 30, 2012.
24 John E. Davies, “Communities Studies and Pesticides” (progress report to EPA, December 20, 1971).
25 Mark R. Powell, Science at EPA (Washington, DC: Resources for the Future, 1999), 297.
26 See Philip Shabecoff, “U.S. Officials Faulted for Talks over Pesticide Ban,” New York Times, January 30, 1984, http://www.nytimes.com/1984/01/31/us/us-officials-faulted-for-talks-over-pesticide-ban.html. See also “Possible Destruction of EPA Dagat Under Inquiry,” New York Times, March 9, 1983, http://www.nytimes.com/1983/03/09/us/possible-destruction-of-epa-data-under-inquiry.html.
27 See Martin Crutsinger, “Three More EPA Officials Asked to Resign,” Associated Press, March 25, 1983, http://news.google.com/newspapersnid=1665&dat=19830325&id=5HEjAAAAIBAJ&sjid=NiQEAAAAIBAJ&pg=6636,3685204. See also http://www.nytimes.com/1983/03/25/us/acting-epa-chief-is-said-to-be-ready-to-quit-post-today.html. See also http://www.highbeam.com/doc/1G1-4811096.html.
28 See “Ex-E.P.A. Official Says Pressure Didn’t Delay Action on Pesticide,” New York Times, September 27, 1983. See also “Possible Destruction of E.P.A. Data
Under Inquiry,” New York Times, March 9, 1983, http://www.nytimes.com/1983/03/09/us/possible-destruction-of-epa-data-under-inquiry.html. See also Lloyd Tataran, Formaldehyde on Trial: The Politics of Health in a Chemical Society (Lorimer, 1983), p. 129. See also “The EPA Wasteland,” New York Times, February 26, 1983, http://www.nytimes.com/1983/02/26/opinion/the-epa-wasteland.html.
Chapter 12: From Reagan to Bush
1 For a link to a brief history of rice production in the Missouri Bootheel, see http://agebb.missouri.edu/rice/ricehist.htm.
2 The major source of PCB pollution, General Electric, while fighting every step of the way, was ultimately forced to engage in a massive cleanup of the Hudson.
3 Ambush is not a benign compound: Permethrin’s links to cancer seemed to be “many-fold more ‘significant’ than indicated either in the superficial and flawed Hazard Evaluation Division’s reviews or for a number of pesticide products which have in the past been suspended or canceled by the EPA,” Adrian Gross wrote. EPA scientists who reviewed permethrin relied on “misleading” information they received from the owners of the insecticide, Gross said. Since the 1980s, we have learned that permethrin, a chemical belonging to the synthetic pyrethroids, combines the ecocidal effects of DDT with the crippling and dehumanizing power of a central nervous system toxin. January 19, 1981, letter from Adrian Gross to Patricia Critchlow of the Registration Division of the Office of Pesticide Programs of EPA.
4 Section 18 also opens another route for the expedited delivery of toxins: the so-called crisis exemption. With this rule, farmers (again represented by the governors of their states) are allowed to use untested and unregistered toxins, including poisons like DDT that EPA banned in 1972; some of these chemicals are suspected to be carcinogenic, or have been taken off the market by the EPA.
5 Douglas D. Campt, “Five Year Review of 40 CFR Part 166” (action memorandum to John A. Todhunter, March 4, 1983).
6 EPA, Office of Pesticide Programs, Registration Division, “Audit of Emergency Exemption and Special Local Needs Programs” (March 1983); “A Review of the Emergency Exemption Program” (March 1987).
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