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: What is an Alternative to "Registered" Pesticide POISONS?

I am writing you because I need your help. In 1993 the EPA, FDA and USDA all agreed to find to alternatives to pesticide poisons. I have personally researched, field tested and/or developed 2300 safe and far more effective alternatives to pesticide poisons. I have consistently gotten better pest control using these unregistered alternatives than I did when I used any/all of EPA’s "registered" pesticide poisons! All of my proven alternatives are either food grade and/or GRAS materials.

The Random House College Dictionary defines an alternative as: 1., a choice limited to one of two or more possibilities; 2., one of these choices; 3., a necessary or remaining choice; 4., affording a choice between two things; 5., (of two choices) mutually exclusive so that if one is chosen the other must be rejected; 6. (of a proposition) asserting two or more choices, at least one of which is true.

I have verbally, in writing and on the web, repeatedly asked for "someone" in the EPA to define the word "alternative", especially for what EPA considers constitutes a pesticide alternative. I have never received any answer, but I know of several people who have been or are being investigated for using safer alternatives the EPA has decided to call "unregistered pesticides"!

Pesticides are, by their very definition, poisons; my alternatives are not considered to be toxic or poisonous, nor does anyone consider them to cause any unreasonable effects on the environment or to cause any health risks. The majority of the public clearly wants pest-free and pesticide-free food, water, parks, homes and schools. To have pesticide-free pest control will require the use of safe and effective alternatives to control the pest problems. However, every time people attempt to use any effective alternatives, EPA officials attempt to fine or stop them for using "unregistered pesticides".

The history of the ‘registration" of pesticide poisons by the Environmental "Protection" Agency has been rather abysmal. Since their "registration," EPA has basically had the following classes of "registered" poisons banned and/or "voluntarily withdrawn": cyclodiene chlorinated hydrocarbons, organophosphates and carbamates; only the pyrethroids basically remain and EPA has now declared them and their synergists to be carcinogens.

Dr. Sam Epstein and Jay Feldman reported in the Los Angeles Times, 11/16/89 that California found, "under its own Birth Defects Prevention Act, that EPA has reached the wrong conclusion in 58 of 99 pesticides (poisons) reviewed - could this much incompetence be accidental?

"When we register a product (pesticide), we’re not saying that it is safe," said Edward Tinsworth, director of the registration division of the EPA’s office of pesticide programs at a 1988 forum held by the National Coalition Against the Misuse of Pesticides. "We’re saying that there is no unreasonable risk, which means there may be a risk." There are no comparable risks with any of my food grade and/or GRAS alternatives..

EPA has clearly said that if you say you are removing germs when you clean or wash with soap and water, you must register the soap and water as a pesticide. It is common knowledge that we wash and clean to remove bacteria and the debris that promotes their growth. For EPA to say soap and water becomes an "unregistered pesticide", when we simply say what it does, is regulatory insanity.

My Grandmother used her old dishwater to safely and effectively remove insect pests from her garden, so one of the alternatives I recommend is simply 1 tablespoon of dish soap, 1 teaspoon of vegetable oil in 1 quart of water; this "dishwater" mix safely controls most insects; if any survive, you can add a few drops of peppermint oil and they too die. This simple alternative still does not create resistant pests, is still safe, inexpensive and effective, even on resistant pests. Yet, per the EPA, this age-old mix can not be "legally" used to control pests, nor is it on EPA’s exempted list.

EPA has also said if you use any of its unregistered "inerts" to control pest problems all by themselves, you are guilty of using an unregistered pesticide! If you add an unregistered surfactant to a pesticide mix to enhance its killing power, this is legal, but if you use it all by itself, this is "illegal"! Yet no "regulator" can logically explain to me why this these unregistered materials need to be "registered", if you do not include some "registered" poison with them!.

My Mother taught me the basis of my Intelligent Pest Management™; she said, "Steve, if you close the door, you will not let in the flies." I still choose to use common sense and unregistered alternatives rather than EPA’s "registered" poisons.

Historically most state "regulators" have only been concerned that the maximum labeled rate of a pesticide poison was used and/or if you left any survivors. The pest control company was and still is basically forced by the state "regulators" to be sure "they used "enough registered" poison "to get them all" and thus the "regulators" have made and continue to make the use/misuse of "registered" pesticides (poisons) the one and only "legal" option to "control" pest problems. These same "regulators" require that farmers, pest control applicators and governmental agencies can only use unregistered poisons to "legally" control pest problems.

Recently, I had a Friend tell me EPA is going to fine him an outrageous amount of money because other people said his product could be used to control pest problems. My Friend clearly has made no pesticidal claims about his own product. Supposedly, it is only when a complaint is filed does EPA check to see if "someone" is selling an "unregistered" pesticide. To me this is an extremely prejudicial and selective "enforcement" of EPA’s "pesticide policy". I cite the following examples of obvious prejudicial and/or selective enforcement:

In the September 1988 issue of Pest Control Technology, (page 18) Stoy A. Hedges, B.C.E., R.S. from Terminex International noted in part: "Although not registered with EPA as a disinfectant, household bleach, such as Dow’s Clorox®, does in fact state ‘disinfectant’ on the label, although specific directions for such use are obviously not provided on the product label. It is common knowledge that hospitals, clinical laboratories and others use household bleach as a disinfectant for blood-borne pathogens." Mr. Hedges notes the Centers for Disease Control have several bulletins that make such recommendations. Yet EPA has not chosen to fine Dow for selling an unregistered pesticide all over the USA, even though its own label clearly states it is a disinfectant.

From Our Toxic Times, May 2001: Heinz Company spokesperson Michael Mullen references numerous studies to show that a straight 5% solution of vinegar—such as you buy in the supermarket—kills 99% of bacteria, 82% of mold and 80% of germs (viruses). He noted that Heinz can’t claim on its packaging that vinegar is a disinfectant since the Company has not registered it as a pesticide with the Environmental Protection Agency (EPA). Yet EPA has not chosen to fine Heinz for selling an unregistered pesticide all over the USA even though its own Spokesman has clearly made pesticidal claims.

Currently 4.5 billion pounds of EPA’s "registered" pesticide poisons are used annually in the United States. Because of all this "registered" use/misuse, our environment and public health continue to be threatened. Studies link EPA’s "registered" pesticide use to elevated rates of cancer in children, farmers and pets. Groundwater and drinking water are contaminated with EPA’s "registered" pesticide residues. Wildlife studies link EPA’s "registered" pesticides with disruption of animal endocrine systems, permanently damaging their reproductive capability and overall health. Government risk assessments use flawed data and false assumptions and exposure and consumption, with limited attention to vulnerable population groups such as children and the ill and the aged. We now have a human cancer epidemic, with cancer striking one in three in the U. S., a dramatic worldwide decline in male sperm counts over the last 50 years, and an increase in childhood asthma. Meanwhile, the system that "regulates and registers" pesticide poisons does not adequately review the full range of possible adverse effects, the interaction of all the product ingredients, and the cumulative and synergistic effects of exposure to multiple pesticide products. These conclusions were reached by a National Academy of Sciences 1993 report, Pesticides in the Diets of Infants and Children. We, obviously, need a "system" that allows the use of safe and effective alternatives!

There are approximately 10 million insects in the world. We have only named about one million and we recognize only about 1000 insects as pest species. Over half of these pest species are already resistant to EPA’s "registered" pesticide poisons. We have never "controlled", much less eliminated, any pest species, but we have eliminated, endangered or reduced many beneficial species using billions of pounds of EPA’s "registered" poisons! We have also contaminated the entire world in the process and currently have more insect loss to our crops now than before we ever used/misused any of EPA’s "registered" poisons. We, obviously, need safe and far more effective alternatives that actually control even resistant pest species.

Please help me and the public by requiring that the EPA, FDA and USDA clearly define the word "alternative". Based on EPA’s current definition of what constitutes an unregistered "pesticide" and their ongoing inability to define the word "alternative" there never will be any "legal" alternatives to EPA’s "registered" poisons! I have a dream that everyone in America and the World stops using dangerous pesticide poisons and the regulatory people not only allow them to do so, but actually promote the use of safe alternatives. Come dream and work with me.

May I humbly suggest, that as a start, the EPA, USDA and FDA consider that if any alternatives are food grade products or Generally Recognized As Safe (GRAS), that it is illogical to register these safe alternatives as "poisons" and/or to consider their alternative use as "unregistered pesticides" that require "regulatory" action.

Sincerely,