Stephen L. Tvedten, TIPM, CEI
Director, President and Director, Professional Development Services, IPM, Inc., President, Get Set, Inc., Inventor, Faculty

George Campbell, Retired Industrialist,
Adventurer and Environmentalist

Merrill Clark, Organic Farmer/Livestock Producer

Gary Coller, D.O., Founder and Chairman, Integrated Therapies

Paula Davey, M.D., Environmental Medicine

Bryna Eill, Ed.D., A.A.S., FIT, Lecturer in Architecture and Environment

Samuel Epstein, M.D., Professor of Occupational and Environmental Medicine, Internationally Recognized Authority on the toxic and carcinogenic effects of environmental pollutants, Author, Lecturer, Legal Expert. Advisor to a wide range of public interest groups

Jay Feldman, Co-founder and Executive Director, National Coalition Against the Misuse of Pesticides

Zane R. Gard, M.D., Detoxification Expert, Environmental Consultant, Professor, Lecturer, Author

Claire Gilbert, Ph.D., Editor and publisher, "Blazing Tattles"

Glenn D.Gordon, TIPM, Chairman and Owner, Home Guard Pest Control, Inventor

Donnelly W. Hadden, J.D., Environmental Attorney, Author.

R. Michael Kelly, M.D., MPH, Medical Director, Occupational Health Services.

Robert L. Laing, Founder, President, CEO and Chairman of the Board, Clean-Flo Laboratories, Inc., Inventor, Faculty

Harvey A. Loomstein, Ph.D., LPC, LMSW-APC, Clinical Director, BioTech Institute

Peter Lurker, CIH, Ph.D., P.E., Environmental Health Consultant.

Robert McClintock, Assistant Superintendent, Northmont Schools

Kenual (Ken) Okech Ogwaro,Ph.D., Entomologist, PCO, Environmental Consultant, Pest Expert

Warren P. Porter, Ph.D (Phynological Ecology), Chair, Dept. of Zoology, University of Wisconsin, Madison

Doris Rapp, M.D., FAAA, FAAP, Environmental Medical Specialist, Pediatric Allergist, Author, Assistant Professor, Lecturer.

Ted Rescorla, Director, Buildings, Grounds and Construction, Grand Haven Schools.

Elihu D. Richter, M.D., MPH, MPII, Sr.,  Lecturer and Head, Unit of  OEM, Hebrew University, Jerusalem

Janette Sherman, M.D., Author, Legal Expert, Lecturer.

Robert K.Simon, Ph.D., DABB, Director, Toxicology International, Inc.

Will Snodgrass, Director of Chemical Injury Communications Network, Director of Missoulans for Clean Environment.

Milton Weiss, DDS, Retired Dentist, Environmentalist

November 13, 2001

Shelley Burkley U. S. House of Representatives

Dear Congresswoman Burkley:

Re: FIFRA "Registration" of Poisons

First of all, it was a real pleasure to talk with you in Nevada on the phone yesterday.

As you may be aware, June of 2001 was the 54th anniversary of pesticide "registration" in the U. S. In June of 1997, Peter Caulkins, deputy director of the Office of Pesticide Program's (OPP) Registration Division summarizing the past five decades said, "The whole registration process started out looking at efficacy," Strange as it may seem today, the entire original emphasis of FIFRA was based only on "efficacy"!!! Safety was not a real concern; only an afterthought. As Dr. John McCarthy, vice-president of global scientific and regulatory affairs for the American Crop Protection, points out, "FIFRA in 1947 really was a labeling law geared toward efficacy. The basic question was asked was: 'Did the product (poison) do what it said it was going to do?' In terms of safety, basically manufacturers only had to note if the product would kill you if it got on your skin or if you drank it." In the 1960s, the focus finally began to shift to human health concerns. By 1988, the pesticide "registration" process was substantially upgraded - it became more sophisticated and demanding - and human health and ecological concerns became the driving factors. The "registration" of corporate "tested" poisons and how to "safely" use them was the order of the day. But, the old pesticide poisons were obviously still around and were not retested. Today proof of efficacy no longer is even required information as part of the data package although the manufacturer still must supply efficacy data only if EPA requests (this is a good thing for the poison industry because poisons no longer even have "efficacy"). Each iteration of FIFRA attempted to bring a stronger focus on safety to man and the environment.

The idea of officially "registering" poisons as pesticides actually began over 90 years ago when the federal government passed the Insecticide Act in 1910. However, the Act did little more than set the stage for the 1947 Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), that still remains prominent today. Originally under FIFRA, all pesticides had to be "registered" by the Secretary of Agriculture - under the auspices of USDA - before being eligible for sale or distribution in interstate or foreign commerce. In 1954 and again in 1958, Congress took its next significant steps by updating the Federal Food, Drug and Cosmetic Act (FFDCA) to establish a maximum permissible level for pesticide residues (poison contamination) found in processed food, raw food and animal feed. The "Delaney Clause" of the FFDCA attempted to protect us from cancer with its "zero-tolerance" language. The clause's sponsor, Rep. James Delaney of New York, called for a prohibition on any pesticide additives "found to induce cancer when ingested by man or animal."

Another key event in the history of pesticide "registration" was the passing of jurisdiction from USDA to EPA, an agency created by President Richard Nixon in 1970, EPA's OPP officially assumed oversight of pesticide "registration" through the revision of FIFRA IN 1972.

Spurred by the environmental movements of the 1960s, OPP stressed strict environmental standards in the regulation process. New yardsticks for "registration" included risk-benefit assessments to determine only a particular active poison ingredient’s potential impact on soil and water.

In 1995-1997, a flurry of new crop (no longer human health concerns) protection regulation reform came down from Captiol Hill - including a Congress-mandated elimination of the Delaney Clause. Dan Barolo, OPP director, has been charged with implementing 1996 rules contained in the Food Quality Protection Act (FQPA), the Federal Agricultural Improvement and Reform (FAIR) Act, and the Safe Drinking Water Act Amendment. Among other things, FQPA now establishes a "reasonable certainty of no harm" standard for "registered" poisons to replace the Delaney Clause that prohibited all poisons found to induce cancer when ingested by man or animal. What may be "reasonable" to the poison "industry" however is not reasonable to me!

Volatile pesticide poisons, while "registered," can and do contaminate our water, food and ambient air. The American College of Allergists has said that 50% of all illnesses are either caused by or aggravated by polluted indoor air. It really is time to improve our indoor air quality and our "registration" process!

"IPM" As Defined by the Poison "Industry"

To become a state or certified "IPM" expert all a poison sprayer (professional pest control operator) is required to do is sit in a meeting or two for a few hours and the poison sprayer is transformed miraculously into an "IPM" expert! Every competitive "IPM" program we have ever read states, "their first line of defense" is a chemical (poison) barrier. The June 1997 Consumers Report had an "IPM" article entitled, "Safe Ways to Banish Bugs," and noted "In short" (1) Harmful ("registered") pesticide (poisons) are still widely used in homes (and schools), and (2) you'll need to ask hard questions to get safe treatment.

Consumers Report sent out a 1996 IPM questionnaire to six state and regional pest control associations. For virtually every category of pest their top three treatments included at least one organophosphate insecticide, yet 5 of the 6 associations said "IPM"-style treatment was on the rise in their regions.

One Florida concern advertised itself as "environmentally friendly, environmentally safe," but the Company President immediately described a course of treatment that included indoor and outdoor applications of both a "registered" organophosphate and a "registered" carbamate pesticide poisons.

Occasionally a pest control company's ad will mention "EPA registered" pesticides implying they are some how safer. Consumers Report noted then any pesticide - including some that are exceedingly toxic - must be "registered" by the EPA before they can legally be applied to homes.

The article noted an EPA survey found that only one in four customers had received written identification of the "registered" pesticide poison used in their homes. The article also gave no real IPM alternative controls its readers could undertake themselves that would actually eliminate pests without using and/or misusing "registered" volatile, synthetic pesticide poisons.

A 1993 report published by the National Academy of Science entitled, "Pesticides in the Diets of Infants and Children concluded that current government pesticide standards do not protect the health of children. The reason for this include the facts that babies' bodies are much more vulnerable to "registered" pesticides because (1) their brains, immune and detoxification systems are immature and in a state of development, (2) pound for pound babies eat 2 to 4 times more vegetables and fruits than adults and so are exposed to a higher proportion of possible contaminants, and (3) the health effects of chronic low level exposure to "registered" pesticide residues are still unknown. A subsequent report released by the Environmental Working Group, "Pesticides in Children's Food" concluded that the largest contribution to a person's lifetime risk of cancer from "registered" pesticide residues occurs during childhood. (Whether from food, water, air and/or surface "registered residues" or poison contaminations.)

It may interest you to know the usual "registered" organophosphate poison used to control insects and/or termites is still Dursban even though it has been "voluntarily withdrawn." Some of this "registered" poison will continue to volatilize into your home for many years, even after a labeled termite treatment. The "registered" Dursban TC label does not allow any amount of this poison to be applied in a barn "where" the animals will be used for food purposes, but the "regulators" in many states demanded the professional must "legally" treat your home with over 300 times what is considered to be a safe application to an acre of ground outside.

"Registered" synthetic organophosphate and carbamate poisons are made to kill; they do not protect - they attack our central nervous systems and other vital body centers. Poisoning symptoms are often mistaken for flu and other illnesses and can vary greatly with each person from a slight reaction to death.

When Rachael Carson published her SILENT SPRING in 1962, she was concerned with about 700,000 pounds of annual pesticide POISON use - we now are using/misusing 4.5 BILLION POUNDS!  With no decrease in pest problems.

The National Academy of Sciences estimates 1 out of 7 of us nationally are already significantly impaired by "registered" pesticide poisons and other toxic chemicals. The National Cancer Institute studies show children get leukemia 6 - 7 times more often when "registered" pesticide poisons are used in and around their homes. Drinking water in at least 38 states is already contaminated with "registered" pesticide poisons. Thirty years ago one out of every seven Americans got cancer; since then we have spent $25 billion on cancer research (continually ignoring the poisons) and now one out of ever two of us gets cancer!

There are approximately 10 million insect species on earth; we have named only about 1 million of them. Only about 1 thousand of them are pest species; over half of those pest species are already immune to "registered" pesticide poisons. Dr., Richard Leakey of Kenya now estimates that the world is "accidentally" losing between 50,000 and 100,000 plant, insect and animal species a year. Even though the U. S. has "purposely" waged a continual, ever increasing, chemical war on pest species for over a half of a century, and now applies over 4.5 billion pounds of "registered" pesticide poisons a year, we have never "controlled," endangered, much less eliminated, even one pest species. We have, however, contaminated the entire earth with our use/misuse of banned, restricted, voluntarily-withdrawn and still EPA "registered" pesticide poisons!

IPM Concerns Expressed by Others

Charles M. Benbrook is a specialist on pesticide policy and author of the book, Pest Management at the Crossroads. In his speech to the USDA Integrated Pest Management Seminar Series, Feb. 28, 1997, in Washington, DC he noted, "In pest management, the time has come to gradually and consciously shift from today's often excessive reliance on ("registered") pesticides to more prevention-based approaches. The knowledge and tools needed to incrementally lessen reliance on broad-spectrum, high-risk pesticides through IPM implementation exists in nearly all crops and regions. We ought to use them more fully and to do so we must exercise discipline in our choices...Yet ironically, across the country there has been slippage in the ability of USDA and universities to carry out IPM research and deliver information key to those trying to implement IPM in the field. Most states have had to reduce the number of applied pest management specialists because of budget cuts. Once world-class IPM research programs have been all but dismantled in key agricultural states including California and Florida.

The Clinton administration proposed significant increases in IPM funding, through what has been called the 'National IPM Initiative.' But congress never approved any real increases in IPM research and education, even those proposed and paid for in the President Clinton's budget submissions.

President Bush George W. has proposed no IPM funding of which I am aware.

Meanwhile, genetic pest resistance to "registered" poisons is a growing worldwide problem. Resistant pests pose as great a threat to today's cotton farmer as the boll weevil did before the introduction of modern insecticide poisons (that are now "banned") in the late 1940s. After just two years of field use, resistance already had already been reported to the latest miracle "registered" pesticide - the reduced-risk and often highly "effective" systemic insecticide Admire.

The number of resistance weeds in the U. S. is up from about a dozen in the early 1980s to over 300 today. Experts acknowledge the problem is growing and predict that if herbicide-tolerant plant varieties are a commercial success, the weed problem will, obviously, worsen. One weed species is resistant to more than 25 herbicides in four different chemical families. The first cases of resistance to the world's most widely used herbicide, Roundup, have now been reported and more are expected. Genetically-engineered canola is an ever-expanding weed pest in Canada.

Hundreds of once secondary pests have now become well-established primary pests. New strains of potato late blight disease and other fungal pathogens are threatening the nation's potato, wheat and tomato crops. Fungicide use is up more than 40% since 1991, according to EPA data.

The surest way to reduce the ever-increasing crop losses due to resistant insect pests, and all the other economic, environmental and public health costs stemming from today's high level of reliance on EPA’s "registered" pesticide poisons is to invest in the tools and information needed to help growers adopt biointensive or alternative IPM." Without any funding, I have developed, researched, discovered and/or field tested over 2300 safe and far more effective (unregistered) alternatives to "registered" pesticide poisons.

IPM As Defined by FIFRA

Sec. 20. [136r] Research and Monitoring

(a) Research.--The Administrator shall undertake research including research grant or contract with other Federal agencies, universities, or others as may be necessary to carry out the purposes of this Act, and the Administrator shall conduct research into integrated pest management in coordination with the Secretary of Agriculture. The Administrator shall also take care to ensure that such research does not duplicate research being undertaken by any other Federal agency.

Sec. 28(c) Integrated Pest Management.--The Administrator, in cooperation with the Secretary of Agriculture, shall develop approaches to the control of pests based on integrated pest management that respond to the needs of producers, with a special emphasis on minor pests.

(d) Public Health Pests.--The Administrator, in coordination with the Secretary of Agriculture and the Secretary of Health and Human Services, shall identify pests of significant public health importance and, in coordination with the Public Health Service, develop and implement programs to improve and facilitate the safe and necessary use of chemical, biological, and other methods to combat and control such pests of public health importance.

IPM As Defined by Florida

This is the way Florida has interpreted FIFRA and their IPM definitions are found in the Florida Statutes, Chapter 482 Pest Control

http://www.leg.state.fl.us/citizen/ducuments/statutes/1997/ch0482/E021_.HTM

Section 482.021

(14) "Integrated pest management" means the selection, integration, and implementation of multiple pest control techniques based on predictable economic, ecological, and sociological consequences, making maximum use of naturally occurring pest controls, such as weather, disease agents, and parasitoids, using various biological, physical, chemical, and habitat modification methods of control, and using artificial controls ("registered" pesticides) only as required to keep particular pests from surpassing intolerable population levels determined from an accurate assessment of the pest damage potential and the ecological, sociological, and economic cost of other control measures.

(20) "Pest control" includes:

(a) The use of any method or device or the application of any substance to prevent, destroy, repel, mitigate, curb, control, or eradicate any pest in, on, or under a structure, lawn, or ornamental;

(c) The use of any pesticide, economic poison, or mechanical device for preventing, controlling, eradicating, identifying, inspecting for, mitigating, diminishing, or curtailing insects, vermin, rodents, pest birds, bats, or other pests in, on, or under a structure, lawn, or ornamental;

In 1993, EPA, USDA and FDA agreed to find alternatives to pesticides; at the time of this writing of this letter, no one in EPA or any other regulatory agency has been able to even define the word "alternative," much less to find or allow the use of any "alternatives" to "registered" poisons! EPA, however, has moved to destroy any alternative it finds by calling it an "unregistered pesticide".

True IPM As Defined by the Institute of Pest Management, Get Set, Inc. and Stephen L. Tvedten

Definition of True IPM: True Integrated Pest Management (IPM), or Intelligent Pest Management ®, is the coordinated use of pest and environmental information with all available pest management methods to prevent unacceptable levels of pest damage by the most economical means creating the least possible hazard to people and the environment. The goal true IPM or Intelligent Pest Management® is to manage pests and the environment so as to balance costs, benefits, human health and environmental quality. True IPM systems utilize a high quantity and quality of technical information on the pest and its interaction with the environment (site). Because true IPM programs apply a holistic approach to pest management decision-making, they take advantage of all low risk management options, emphasizing natural biological methods, and the appropriate use of various food-grade and/or GRAS alternatives. True IPM's strategies incorporate environmental considerations by emphasizing pest management measures that minimize intrusion on natural bio-diversity ecosystems with "registered" poisons. Thus, true IPM is:

A system utilizing food-grade or GRAS methods and alternatives,

A decision-making process,

A risk reduction system,

Information intensive,

Biologically based,

Safety conscious,

Cost effective,

Site specific, and

Uses non-volatile pesticides as a last resort.

Common Sense, Not "Registered" Synthetic Pesticides

I have consistently proven that a true IPM program does not require the use of any volatile, synthetic pesticide poisons. NONE! It uses something a lot safer - Common sense and food-grade and/or GRAS alternatives. We study every kind of pest problem and then we develop an environmentally sound way of dealing with each one, critter by critter, alternative by safe-and-far-more-effective (unregistered) alternative.

Controlling pests with poison is the last thing we do.

It is against the federal law to say that the use of any "registered" pesticide poison is "safe". No honest and/or objective person would consider EPA’s "registered" poisons as being safe. The original intent of the "registration" of pesticide poisons was to make sure they were effective. No honest and/or objective person would consider EPA’s "registered" poisons as being "effective". There are, however, many safe and far more effective, unregistered alternatives. When will it be legal to use them?

Please have someone in EPA define the word "alternative" and/or explain why the EPA now wants to "register" any/all safe alternatives, e.g., mayonnaise, as a pediculicide poison or soap and water as a pesticide poisons?

Respectfully,

Stephen L. Tvedten