PANNA: Action Alert: Tell U.S. EPA Testing Pesticides on People is Off Limits


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Action Alert: Tell U.S. EPA Testing Pesticides on People is Off Limits
July
25, 2003

U.S. EPA is now in the initial stages of considering new regulations for testing pesticides on human subjects. Pesticide manufacturers have moved through the courts to make their case for a process that is unsafe and unjustified. It is important to make a strong case now and put a stop to pesticide testing on humans. Write U.S. EPA before the comment period closes on August 5, 2003 and tell them dosing people with toxic pesticides is unethical and must not be condoned.

In 1998 the Environmental Working Group reported on alarming tests performed in England and Scotland and paid for by U.S. pesticide companies in which people were paid to eat and drink pesticides, then monitored for health effects. The intentional feeding of toxic substances to people contradicts the ethical foundation of medical testing, because the subject will never benefit from the test and risks harm, and the payment offered, especially in cases of extreme poverty, can be considered undue duress.

In response to growing controversy over human testing, U.S. EPA issued a directive against such tests in 2001. But CropLife America, a trade group for chemical companies, filed suit and a federal appeals court in June 2003 ordered U.S. EPA to accept data from human tests.

Pesticide companies have increasingly strong incentives to use human tests to determine the acute toxicity of their products. In 1996 the Food Quality Protection Act (FQPA) strengthened U.S. EPA risk assessment by adding a third, ten-fold uncertainty factor for acceptable exposure levels for children and pregnant woman. So-called "safe" exposure levels for adults are based on laboratory studies, usually conducted on rats, mice or other animals to which a ten-fold uncertainty margin has been added to account for the differences between species, and a second ten-fold margin to account for differences within a species (e.g., some people are much more sensitive to chemicals than others).

The FQPA also required U.S. EPA to consider the cumulative risks of pesticides that have a common mechanism of toxicity when setting standards for an individual pesticide. This leads to much lower acceptable exposure levels for some individual pesticides, such as organophosphates, since they are in widespread use and share the same toxicity mechanism. U.S. EPA has said that risk assessments may show that some organophosphates exceed the cumulative risk level, or in U.S. EPA-speak that, "the risk-cup is full."

For pesticide manufacturers, data from tests on human subjects offer the possibility of circumventing the more stringent standards of the FQPA. At stake are continued uses of organophosphate insecticides, and possibly the carbamate class of pesticides. In recent years chemical companies have asked U.S. EPA to allow data from a number of human studies. Eric Olson with the Natural Resources Defense Council warned after the court's decision, "There will be enormous political pressure on the EPA" [to allow human testing].

In contrast to the U.S. EPA proposal for regulation regarding testing toxic pesticides on people, the European Union (EU) is taking a far different, safer and more ethical road. The EU is moving forward with a chemicals policy that incorporates the Precautionary Principle, which emphasizes reduction of harm, places the burden of proof upon the polluter (and not the regulator) and requires an assessment of available alternatives. All of this is a far cry from intentionally feeding toxic pesticides to people to see how much they can take.

Testing of pesticides - on animals or humans - is a byproduct of an agricultural and pest-control system overly reliant on chemical inputs. Alternative agricultural systems have proven effective and can be less expensive than conventional production - particularly if the costs of chemical testing and enforcement of regulation is factored in.

Write or Email the U.S. EPA before August 5, 2003 with your own version of the sample comment below.

Reference U.S. EPA Docket Number OPP-2003-0132 - Human Testing; Advance Notice of Proposed Rulemaking.

Comment on the Web at
http://cascade.epa.gov/RightSite/dk_public_collection_detail.htm?ObjectType=dk_docket_collection&cid=OPP-2003-0132&ShowList=items&Action=view

Comment by Email: opp-docket@epa.gov,
U.S. EPA Docket Number OPP-2003-0132

By mail:
Environmental Protection Agency
EPA Docket Center (EPA/DC)
Human Testing; Advance Notice of Proposed Rulemaking Program Docket
1200 Pennsylvania Avenue, NW
Washington, DC 20460
RE: EPA Docket Number: OPP-2003-0132

SAMPLE LETTER
Dear Agency Officials,
I am writing in response to your request for public comment on the issue of accepting studies that rely on exposing people to pesticides to determine health effects. Testing pesticides on people is unethical and unnecessary, and I urge you to develop a policy that disallows consideration of these studies.

Please stick to tough and appropriate standards for exposure levels for children and pregnant moms, and use the agency's resources to promote known alternatives to reduce the need for toxic pesticides.

EPA's approach to regulating pesticides should be based on the precautionary principle, an approach that will protect public health much more effectively. Encouraging intentional dosing of people with toxic pesticides by accepting these studies would be irresponsible, and I urge you not to support such a move.
Sincerely,

- signature -

Sources: The 1998 Science Advisory Board/Scientific Advisory Panel (SAB/SAP), http://www.epa.gov/science1/pdf/ec0017.pdf; U.S. Court Lifts Ban on Human Testing of Pesticides, Planet Ark, June 5, 2003, http://www.planetark.org/dailynewsstory.cfm/newsid/21051/story.htm; The English Patients: Human Experiments and Pesticide Policy, a report by the Environmental Working Group, http://www.ewg.org/reports/english/englishpr.html; EPA Opens the Door to Testing Bug Killers on People, Village Voice, July 9-25, 2003, http://www.villagevoice.com/issues/0328/tracy.php.

Contact: William Jordan, Mail Code (7506C) Environmental Protection Agency
EPA Docket Center (EPA/DC), EPA Docket Number: OPP-2003-0132, Human Testing; Advance Notice of Proposed Rulemaking Program Docket , 1200 Pennsylvania Avenue, NW, Washington, DC 20460, Phone: U.S. EPA (703) 305-1049.

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