Merryl Hammond, Ph.D., B.Soc. Sc. (Nursing)
6 Sunny Acres, Baie d'Urfe, Quebec, H9X 3B6, Canada. Tel (514) 457-4347 Fax (514) 457-4840
mhammond@total.net
 
Members of the Standing Committee on Environment and Sustainable Development
c/o Mr. Stephen Knowles, Clerk
Room 642, 180 Wellington
House of Commons,
Ottawa, ON, KlA OA6
11 November 1999.
 
Dear Colleagues,
re: Urgent call for long-overdue changes re cosmetic use of pesticides
 
1. WHEREAS: Chemical pesticides are inherently toxic products created to kill various life -forms and deliberately released into the environment, and whereas ecological, non-toxic methods of pest management do exist;
 
2. WHEREAS: Every Canadian is affected by this problem: we are all exposed to pesticides in the air, soil, water and food;
 
3. WHEREAS: Babies, children, youth, pregnant women, elderly, asthmatic, chemically-sensitive and other susceptible Canadians are currently being exposed to a variety of pesticides in their homes, gardens, schools, workplaces, parks, sports fields, and neighbourhoods; 1
 
4. WHEREAS: Suburban lawns and golf courses are even more heavily treated with pesticides than agricultural areas; 2
 
5. WHEREAS: Both the National Cancer Institute in the US 3 and the Erie County Unit of the American Cancer Society 4 have published documents in which the role of pesticides in cancer causation is highlighted;
 
1 See Davis, K (1998) Pesticides and your child: an overview of exposures and risks, Campaign for Pesticide Reduction, Ottawa, for a scientifically referenced summary of the many pathways of exposure and the acute and chronic health effects of pesticides.
 
2 Koppell, G.O. (1994) Toxic fairways: risking groundwater contamination from pesticides on Long Island Golf Courses. New York State Department of Law, New York. In this report, the Attorney General states that farmers use an average of 1.5 lbs. of pesticides per acre per year, and 2.7 lbs. per treated acre per year. (Not all agricultural land is treated every year.) For golf courses, the equivalent figures are 7 lbs. and 18 lbs. respectively. Homeowners use between 3-10 lbs. per acre per year.
 
3 Subcommittee to Evaluate the National Cancer Program (1994) Cancer at a Crossroads: A Report to Congress for the Nation, National Cancer Advisory Board of the National Cancer Institute, Bethesda. See especially the table about environmental and genetic factors in carcinogenesis in Appendix B (pages B 12-B 15). This was the first time we saw such strong language about environmental and occupational contaminants as cancer-causing agents from an institution within the "cancer establishment". They call for more research and public education into these factors, and recommend changing "laws and regulatory policies and practices, including those related to the environment and food supply, that contribute to the cancer problem and frustrate cancer prevention and control efforts" (pg. 21). (Tel: [301] 496-5515 for copies of the report.)
 
4Pamphlet entitled "WARNING: The use of pesticides maybe hazardous to your health!", produced by the Erie County Unit of the American Cancer Society, 1993.
 
 
6. WHEREAS: Many studies published in prestigious, peer-reviewed, medical and epidemiological journals and reports point to strong associations between chemical pesticides and serious health consequences including:
 
o Endocrine disruption and fertility problems 5 6 7 8
 
o Birth defects 9 10
 
o Brain tumours and brain cancer 11 12 13 14 15
 
 
 
 
_______________________________
5 Colborn, T., von Saal, FS. & Soto, AM. Developmental effects of endocrine-disrupting chemicals in wildlife and humans. Environmental Health Perspectives, Vol. 101, 1993: 378-384.
 
6Carlsen, E. et al. Evidence for decreasing quality of semen during the past 50 years. British Medical Journal, Vol. 305, 1992: 609-613.
 
7 Sharpe, RM. Declining sperm counts in men: is there an endocrine cause? Journal of Endocrinology, Vol. 136, 1993: 357-360.
 
8Sharpe, RM. & Skakkebaek, NE. Are oestrogens involved in falling sperm counts and disorders of the male reproductive tract? The Lancet, Vol. 341, 1993: 1392-1395.
 
9 Czeizel, AE. et al. Environmental trichlorfon and clusters of congenital abnormalities. The Lancet, Vol. 341, Feb. 27, 1993: 539-542.
 
10 Garry, VF., Schreinemachers, D. et al. Pesticide appliers, biocides and birth defects in rural Minnesota. Environmental Health Perspectives, Vol. 104. No. 4, 1996: 394-399.
 
11 National Cancer Advisory Board (1994) Cancer at a Crossroads: A report to Congress for the Nation. National Cancer Institute, Bethesda, Maryland. (See "Environmental and Genetic factors in Carcinogenesis" page B-15.)
 
12 Gold, E., Gordis, L. et al. Risk factors for brain tumours in children. American Journal of Epidemiology, Vol. 109, 1979: 309-319.
 
13 Wilkins, JR. & Sinks, T. Parental occupation and intracranial neoplasms of childhood: results of a case-control interview study. American Journal of Epidemiology, Vol. 132, 1990: 272-292.
 
14 Davis, JR., Brownson, RC. et al. Family pesticide use and childhood brain cancer. Archives of Environmental Contamination and Toxicology, Vol. 24, 1993: 87-92.
 
15 Kristensen, P., Andersen, A. et al. Cancer in offspring of parents engaged in agricultural activities in Norway: incidence and risk factors in the farm environment. International Journal of Cancer, Vol. 65, 1996: 39-50.
 
 
o Breast cancer 16 17 18
 
o Prostate cancer 19 20
 
o Cancer clusters in communities 21 22 23
 
o Gastric (stomach) cancer 24
 
o Learning disabilities 25
 
________________________________
16 National Cancer Advisory Board (1994) Cancer at a Crossroads: A report to Congress for the Nation. National Cancer Institute, Bethesda, Maryland. (See "Environmental and Genetic factors in Carcinogenesis" page B-12.)
 
17 International Joint Commission, 1994. Seventh Biennial Report on Great Lakes Water Quality. Ottawa and Washington.
 
18 Davis, DL. et al. Medical hypothesis: xenoestrogens as preventable causes of breast cancer. Environmental Health Perspectives, Vol. 101, Oct. 1993: 372-377.
 
19 Morrison, H, et al. Farming and prostate cancer mortality. American Journal of Epidemiology, Vol. 137, No. 3, 1993: 270-280.
 
20 Kross, BC., Burmeister, LF. et al. Proportionate mortality study of golf course superintendents. American Journal of Industrial Medicine, Vol. 29, 1996: 501-506.
 
21 Newman, P. Cancer clusters among children: the implications of McFarland. Journal of Pesticide Reform, Vol. 9, No. 3, 1989: 10-14.
 
22 The politics of cancer: why the medical establishment blames victims instead of carcinogens, Utne Reader, Nov/Dec 1993: 81-92.
 
23 Wilkins, JR., McLaughlin, JA. et al. Parental occupation and intracranial neoplasms of childhood: anecdotal evidence from a unique occupational cancer cluster. American Journal of Industrial Medicine, Vol. 19, 1991: 643-65 3.
 
24 National Cancer Advisory Board (1994) Cancer at a Crossroads: A report to Congress for the Nation. National Cancer Institute, Bethesda, Maryland. (See "Environmental and Genetic factors in Carcinogenesis" page B-14.)
 
25 O'Brien, M. Are pesticides taking away the ability of our children to learn? Journal of Pesticide Reform, Vol. 10, No. 4, Winter 1990/91: 4-8.
 
 
o Non-Hodgkin's lymphoma 26 27 28 29 30 31
 
o Canine rnalignant lymphoma 32
 
o Acute effects (fatigue, nausea, diarrhea, etc.) 33
 
 
______________________________
26 Hoar, SK. et al. Agricultural herbicide use and risk of lymphoma and soft tissue sarcoma. Journal of the American Medical Association, Vol. 256, No. 9, 1986: 1141-1147.
 
27 Wigle, DT. et al. Mortality study of Canadian male farm operators: Non-Hodgkin's Lymphoma mortality and agricultural practices in Saskatchewan. Journal of the National Cancer Institute, Vol. 82, No. 7, 1990: 575-582.
 
28 Hoar Zahm, S. et al. A case-control study of Non-Hodgkin's Lymphoma and the herbicide 2,4-D in Eastern Nebraska. Epidemiology, Vol. 1, No. 5, 1990: 349-356.
 
29 Hoar Zahm, S. & Blair, A. Pesticides and Non-Hodgkin's Lymphoma. Cancer Research (Suppl.), Vol. 52, 1992: 5485s-5488s.
 
30 National Cancer Advisory Board (1994) Cancer at a Crossroads: A report to Congress for the Nation. National Cancer Institute, Bethesda, Maryland. (See "Environmental and Genetic factors in Carcinogenesis" page B-15.)
 
31 US Institute of Medicine (1994) Veterans and Agent Orange: health effects of herbicides used in Vietnam. National Academy Press, Washington DC.
 
32 Hayes, HM. et al. Case-control study of canine malignant lymphoma: positive association with dog owners' use of 2,4-D herbicides. Journal of the National Cancer Institute, Vol. 83, No. 17, 1991: 1226-123 1.
 
33 Scarborough, ME. et al. Acute health effects of community exposure to cotton defoliants. Archives of Environmental Health, Vol. 44, No. 6, 1989: 355-360.
 
 
7. WHEREAS: The following respected health-related organizations formally supported CAP's call for a-moratorium on the cosmetic use of pesticides; 34
 
  o Allergy Asthma Information Association
o Canadian Dental Association
o Canadian Liver Foundation
o Canadian Nurses Association
o Canadian Physiotherapy Association
o Canadian Soc. for Environmental Medicine
o Health Action Network Society
o International Institute of Concern for Public Health
o Learning Disabilities Association of Canada
o Pesticide Exposure Group of Sufferers
 
 

 

8. WHEREAS: There is increasing evidence that pesticides and other synthetic chemicals pose serious threats to the environment; 35

 
9. WHEREAS: The chemical pesticide industry is part of an even larger, multi-billion dollar global pharmaceutical industry with massive vested interests in the continued use of pesticide products, and virtually unlimited funds to silence potential critics and to influence public opinion and government officials; 36
 
 
 
 
 
 
_______________________________
34 Letters from all these organizations were presented to then federal Minister of Health, Diane Marleau, when CAP met with her on 24 May 1994.
 
35 See Commercial Chemicals Evaluation Branch (1994) Towards a Toxic Substances Management Policy for Canada: a discussion document for consultation purposes, September 1994. Environment Canada, Ottawa. Also see the reports of the International Joint Commission, and recent media reports re xeno-estrogenic effects of many chemicals, including diminished penis size and other reproductive malfunctions, and many reports by the World Wildlife Fund.
 
36 In 1992/3, eight of the top twelve agrochemical companies in the world (Ciba-Geigy, ICI Du Pont, Bayer, Monsanto, DowElanco, Sandoz, etc.) also produced pharmaceuticals, and seven produced animal health products. Average annual sales of these top 12 companies in that year were US$ 1,630 million. The average annual sales of the top 12 pharmaceutical companies, on the other hand, was US$ 5,582 million. (Watkins, S. 1993. Agrow's Top 25 companies. London: PJB Publications, pg. 2). Given the financial power of the pharmaceutical companies, and their very close association with pesticide producers, we should not be surprised that medical and veterinary associations (whose conferences are sponsored by pharmaceutical companies, and whose journals are full of advertising from these companies) have been very hesitant to speak out publicly about the dangers of pesticides... Referring back to point 7 above, note that groups like the Canadian Medical Association, College of Family Physicians of Canada, Canadian Pharmaceutical Association, Canadian Veterinary Medicine Association, and Canadian Cancer Society chose not to support CAP's call for a moratorium in 1994. (For more about the "cancer establishment's" silence on this issue, please see the book, The Politics of Cancer by Samuel Epstein.)
 
 
10. WHEREAS: The bulk of the so-called "safety tests used to test these products are fundamentally inadequate: toxicological studies are done by pesticide manufacturers (not objective researchers), and they measure the acute (not chronic) effects of single (not multiple) chemicals on healthy (not sick, chemically sensitive or immuno-suppressed etc.) adult (not fetal or young) animal (not human) subjects exposed over short (not long)
periods of time; 37
 
11. WHEREAS: The limited tests done on agricultural workers are totally inadequate; 38
 
12. WHEREAS: Homeowners and the chemical lawn care industry are using products that have never been adequately tested or monitored in residential areas for their chronic, synergistic, and other effects on human and animal health; 39
 
 
 
 
 
 
 
 
________________________________
37 Please see any of the "Decision Documents" about registration of new pesticides published by the Interdepartmental Executive Committee on Pest Management of Agriculture Canada and more recently by the Pest Management Regulatory Agency (PMRA).
 
38 See, for example, Interdepartmental Executive Committee on Pest Management, Decision Document E94-03, Imazethapyr. Plant Industry Directorate, Agriculture and Agri-Food Canada, March 30, 1994. In this document, we are informed that the new pesticide Imazethapyr (Pursuit) has been registered in Canada. However, no occupational exposure tests were submitted for this specific pesticide. Rather, a "surrogate study" for a different pesticide, Assert, was submitted by the manufacturer instead. The two pesticides are apparently "chemically similar", but - wait for it - are "metabolised differently" in the human body! This glaring error notwithstanding, the original study (for the wrong pesticide!) consisted of a sample size of only 13 farmers who were occupationally exposed to Assert for only 4-7 hours each! And that "Surrogate study" of Assert was accepted by government officials as "proof" that the new (untested) pesticide, Pursuit, was "safe"...
 
39 Bystander and community exposure studies are not even mentioned in most Decision Documents. The very limited testing that is done is either for occupational exposures of chemical workers, or in agricultural areas where small samples of healthy, adult, male farmers are the subjects of investigation. (Needless to say, they are not still growing, or pregnant, or breastfeeding, etc.) And, please see footnote 40 above for a critique of the quality of the occupational exposure studies that have been accepted. Moreover, the so-called "research:" quoted by pesticide promoters and others with a vested interest in maintaining the status quo is methodologically unsound and therefore biased, and is either self-published or published in newsletters or so-called "journals" that are not peer-reviewed. (See for example, the methodologically unsound work of some of the staff and students from the Turfgrass Institute of Guelph University, such as Harris, SA. & Solomon, KR. "Human exposure to 2,4-D following controlled activities on recently sprayed turf" in Journal of Environmental Science and Health, B27 (1), 1992: 9-22 and Harris, SA. et al. "Exposure of homeowners and bystanders to 2,4--Dichlorophenoxyacetic acid (2,4-D)" in Journal of Environmental Science and Health, B27 (1), 1992:23-38.
 
 
13. WHEREAS: The government officials and staff responsible for pesticide registration are inappropriately trained and/or underqualified and therefore unable to do their work with any competence; 40
 
14. WHEREAS: Concerned residents have pressured many towns in Quebec to pass bylaws restricting or even banning the use of pesticides in the areas of their jurisdiction; 41
 
15. WHEREAS: Many other products (Thalidomide, DES, DDT, etc.) that have had tragic health consequences were initially government-approved but had to be banned or restricted after further studies were done;
 
16. WHEREAS: The federal government, through Minister of Health, is charged with "the promotion or preservation of the health... of the people of Canada" (clause 4[1] of the Department of National Health & Welfare Act);
 
* * *
 
 
__________________________
40 In 1993 and 1994, I interviewed numerous staff members in the Pesticides Division of the Health Protection Branch of Health Canada (before the creation of PMRA), asking to be referred to someone with training in nursing, medicine or community health who could answer my health-related questions about pesticide registration and monitoring. Not a single person with appropriate qualifications was on staff. Staffers had B. Sc. degrees in toxicology or chemistry, and senior officials had M.Scs or Ph.Ds in chemistry. But no-one had training in health sciences. Not surprisingly, then, no-one was able to answer my questions. Indeed, no-one was even asking health-related questions! (One staffer, in response to my questions about whether anyone in Canada was actually monitoring the quantities and types of pesticides currently being applied in residential areas, or monitoring the adverse reactions of residents to pesticides, or studying the synergistic effects of multiple chemicals said: "Ooh, you do ask difficult questions!')
 
41 In Quebec, for example, there are now over 20 towns with pesticide bylaws. See Hammond, M, (1995) Pesticide Bylaws: why we need them; how to get them. Consultancy for Alternative Education, Montreal.
 
 
THEREFORE: I call on the federal government to ensure that the pesticide registration system in Canada protects the health, safety and well-being of all Canadians by taking the following steps:
 
1 . Introduce an immediate moratorium on the cosmetic use of chemical pesticides in residential areas, until such time as their use has been scientifically proven to be safe, and the long-term consequences of their application in
residential areas are known;
 
2. Appoint people with demonstrated competence in the fields of pesticides and public health and pesticides and the
environment and with professional qualifications in medicine, nursing, public health, epidemiology, and clinical toxicology (as well as chemistry and animal toxicology) to staff the Pest Management Regulatory Agency and to draft
appropriate guidelines for safety tests to be submitted by manufacturers;
 
3. Use conventional epidemiological standards to evaluate the data submitted by pesticide manufacturers and only
register (or re-register) pesticides which have met these standards; 42
 
4. Insist that all data sets submitted by manufacturers include detailed results of occupational, bystander, and community exposure studies; 43
 
5. Require registrants to submit additional occupational, bystander, and community exposure data and environmental fate data 3-5 years after initial registration. This would ensure ongoing monitoring of the effects of pesticides, and the Agency would only renew registrations if these data showed that the product was not causing damage to human health or the environment;
 
6. Initiate a national health education campaign about the health effects of pesticide exposures and ecological
alternatives to pesticides;
 
7. Make all pesticide-related morbidity and mortality medically reportable conditions;
 
8. Ensure adequate diagnostic and treatment facilities for victims of pesticide exposure;
 
9. Make chemical manufacturers disclose all the contents (including so-called "inert ingredients" or formulants) of pesticide products on labels, and print clear health warnings on labels.
 
 
 
Yours sincerely,
 
Merryl Hammond, Ph.D., B.Soc.Sc. (Nursing)
Founder, Citizens for Alternatives to Pesticides
 
 
 
___________________________
42 The kind of "occupational exposure" data that is currently accepted by Health Canada and published by in Decision Documents from Agriculture Canada's Interdepartmental Executive Committee on Pest Management is completely inadequate; no competent epidemiologist would allow such blatantly flawed and incomplete data to pass through a regulatory system.
 
43 Bystander exposure is usually not a part of the data set. Community exposure is never mentioned.