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Issues and Impacts 2009

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INTRODUCTION

Like a resounding prophesy Rachel Carson‘s work continues to remain relevant.

In this year‘s "Issues and Impacts - 2009" report, there are reviews and updates of pesticide-related developments from a Rachel Carson legacy perspective.

Four statements have been selected from the fifteen-page Congressional Testimony given by Rachel Carson in 1963. They appear in Issue # 1. Themes related to these four points are found throughout the remaining "Issues and Impacts."

These "Issues" are of special interest for Rachel Carson Council, and we hope for our supporters, as well as for students, teachers, health care providers, parents, and gardeners.

Note: if time is restricted, reading only the "Impacts" at the end of most of these "Issues" will provide an overview to identify topics for future reading.

"Issues and Impacts - 2009", as a whole or in part can be reproduced and shared with others.

ISSUES AND IMPACTS

1) Excerpts from Rachel Carson's 1963 Congressional Testimony

Four statements taken from Rachel Carson‘s testimony before the United States Congress on June 4, 1963 comprise the cornerstones of this "Issues and Impacts - 2009".

Rachel Carson‘s testimony began with a focus on how we human beings are sustained by the earth. She stated: "The world of air and water and soil supports not only the hundreds of thousands of species of animals and plants, it supports man himself." In his "Introduction" to the 1996 edition of Silent Spring, Al Gore wrote "Rachel Carson brought us back to a fundamental idea lost to an amazing degree in modern civilization: the interconnection of human beings and the natural environment. "

This is explored below in "Ecosystem Services Lost and Found: Birds, Bats, Fish, and People" (Issue #5). The impacts of immediate, as well as delayed, chronic adverse effects accompanying pesticide usage are frequently overlooked when the risks of these chemicals are assessed. Rachel Carson recommended: "...[W]e shall have to begin to count the many hidden costs of what we are doing [with pesticides], and weigh them against [their] gains or advantages." The costs of a childhood illness, such as cancer, asthma, or developmental problems, that are paid by patients, their families and friends are incalculable. The costs of the increasingly diagnosed debilitating neurological conditions, such as Parkinson‘s disease, in both suffering and expense, call for urgent preventive action. Medical professionals need to include the hazards of pesticides when advising patients on avoidable health-threats. Estimates of the costs in wildlife lost to outright killing by pesticides appear below under "Ecosystem Services..." (See Issues # 3, 4, & 5.)

Incident reports of pesticide toxicity from a variety of sources were important to Rachel Carson as indicated by the following observation: "Many case histories [of problems following pesticide exposures] have come to me in letters... [and] in current medical literature." At RCC we have been compiling and alerting others to pesticide incident data from various sources for over four decades. A recent example of RCC‘s action on incidents concerns tetrachlorvinphos and the EPA (see Issue # 13).

Rachel stressed to lawmakers her firm belief in "...the right of the citizen to be secure in his own home against the intrusion of poisons1 applied by other persons." Conflicts continue to rage over the issue of toxics trespassing into citizens‘ homes and gardens. The unwelcome presence of highly persistent herbicides such as picloram, clopyralid, or aminopyralid in compost used by homeowners for growing vegetables for their families is a recent example of toxic trespass that has infuriated gardeners here and abroad. (See Issue # 9.)

2) Déjà vu: Trust in Pesticides' "Safety" Reminiscent of Rachel Carson's 1962 Comments

In her address to the National Women‘s Press Club following Silent Spring's publication, Rachel Carson described a news article from The Globe Times of Bethlehem, PA. At Farm Bureau offices in two Pennsylvania counties "No one who was interviewed had read Silent Spring but all disapproved of it heartily." (From: "Rachel Carson Speaks" audio tape of the 1962 talk - available from RCC.)

At a recent meeting with directors of a local, residential community, at a resident‘s request, RCC spokespersons described alternative (non-chemical) pest management for lawns. Our suggestions to the directors for low risk, non-chemical weed management were met with resistance and were countered by strong support for a chemical herbicide product, previously proposed by a professional lawn care contractor. Some of what transpired that evening recalled Rachel Carson‘s words.

These directors described the recommended herbicide product as being "safe, " as being "approved by the EPA, " and as containing weed killer in amounts too low to do any harm. One individual also asserted that herbicides are not pesticides. Finally, and here the resemblance to Rachel‘s Globe Times reference becomes quite apparent - not one of those who championed the chemical herbicide product as "safe" knew its trade name or the identity of its active ingredients.

There‘s more. The herbicide that directors considered a "safe" product was identified several days later as containing three active ingredients: 2,4-D, triclopyr, and clopyralid. When RCC performed a routine check on the product‘s registration status with USEPA and the Maryland Department of Agriculture, it turned out to be unregistered in both jurisdictions. In Maryland it is illegal to apply a pesticide that is not registered in the state.

An inquiry into the origins of the directors‘ questionable information about lawn chemicals revealed a prior presentation to the group by a speaker representing the local Master Gardeners (a volunteer program).

Impact (Déjà vu: Trust in Pesticides' "Safety" Reminiscent of Rachel Carson's 1962 Comments):

We hope the knowledge about pesticides provided by RCC to these directors will help with future lawn care and other pest management decisions.

As we informed them: The concept that pesticide products registered with USEPA can be considered "safe" is contrary to that Agency‘s own regulations. 2 Yes, the term "pesticides" includes "herbicides. " Pesticide products are registered under a risk benefit standard by the EPA. Unlike drugs, they are not "approved as safe and effective. " Adverse reactions in people, pets, and desirable plants have been reported for herbicide products applied to lawns. Further, clopyralid a constituent of the formulation in question has been found to persist in compost made from treated grass clippings and to adversely affect broad leaf plants such as tomatoes around which such compost has been applied. Note: The Washington State Department of Agriculture prohibited clopyralid for most lawn and turf use in 2002 to help avoid contamination of yard debris compost. (See Issue # 9.)

3) Children and Pesticides 2009

Today it is clear that links between exposure to pesticides and children's health problems exist. In fact, they are far more frequent and far more serious than previously imagined.

Children are more vulnerable than adults to hazards from chemical pesticides. Children‘s brains and other organs under development are more sensitive to biologically active material such as pesticides. Babies in their mothers‘ wombs are especially vulnerable to chemical pesticides.

The routes of children‘s exposure to pesticides can be oral, dermal (through the skin), and by inhalation. The ways that children can encounter pesticides include: through the air that drifts from treated sites adjacent to their homes, schools or day care facilities; through exposure to treated pets that they stroke or hug; through contact with surface areas where pesticides have been applied. Finally, pesticide residues can be found in the food and/or water consumed by children.

Mothers carrying fetuses in their wombs can be exposed to pesticides at work, on golf courses, and in recreational facilities, in addition to the other ways itemized above. Physicians advising pregnant patients have cautioned them to avoid or minimize their exposure to pesticides. (Peters, Paul, Section 2.23.6 in: Drugs During Pregnancy and Lactation, Treatment Options and Risk Assessment, Schaefer, Christof., et al., ed., 2nd Edition, pp 576-581, 2007)

Adverse effects in children due to immediate toxicity from pesticides can take the form of itching, dizziness, coughing, headache, burning eyes, muscle aches, and intestinal upset (Alarcon, W.A., et al., "Acute illness associated with pesticide exposure at schools, " JAMA, 294,4, July 27, 2005).

Chronic conditions associated with pesticide exposure in children include asthma, cancer and developmental disorders such as autism, as described below.

Asthma

Exposure of children to pesticides in the first year of life has been linked to the development of childhood asthma. This condition is the most common chronic disease among young children in the U.S. (Salam, M.T., et al., "Early-life environmental risk factors for asthma: findings from the children‘s health study, " EHP, V112, #6, pp 760-765, May 2004).

Cancer

In 2007, a researcher concluded that children may develop cancer if they had been exposed to chemical pesticides before birth. (Rudant, Jeremie, et al., "Household exposure to pesticides and risk of childhood hematopoietic malignancies: The ESCALE Study (SFCE), " EHP, V115, #12, pp 1787-1793, December 2007).

In 2009, researchers at Georgetown University Hospital found that the most common of all childhood cancers, acute lymphoblastic leukemia (ALL) is associated with increasing levels of organophosphate transformation products in the urine of affected children and their mothers. (Soldin, O.P., et al., "Pediatric acute lymphoblastic leukemia and exposure to pesticides, " The Drug Monit., V31, #4, pp 495-501, August 2009)

Autism

Rates of autism spectrum disorders are increasing. Neurotoxic insecticidal chemicals have been associated with these conditions. A case control study in California compared the rate of autism spectrum disorders with proximity of the mothers‘ residence, while pregnant, to agricultural areas where pesticide applications occurred regularly. An association was found between exposure to the organochlorine insecticides dicofol and endosulfan, and higher rates of autism. (Roberts, E.M, et al., EHP, V115, pp 1482-1489, 2007).

A report on a study of Mexican farmworker families in California found that metabolites of organophosphates in the urine of children were associated with a greater likelihood of developmental disorders (including autism spectrum disorders) at age 2. (Eskenazi, B. et al., "Organophosphate Pesticide Exposure and Neurodevelopment in Young Mexican-American Children, " EHP V115, No. 5, May 2007).

A preliminary report from a study on prenatal exposure to sprays containing pyrethrin or pyrethroid type chemicals in pet shampoos and certain sprays for controlling flies, ants and cockroaches - found that they were associated with an increased risk of autism spectrum disorders. (Hertz-Picciotta, I., Int‘l Mtg for Autism Res, 2008)

Impact (Children and Pesticides 2009):

The question is no longer whether or not there are links between exposure to pesticides and hazards to children, but what can be done to remedy the situation. Action is needed to protect pregnant women and children from exposures to these toxic chemicals. RCC recommends that health care professionals, parents, legislators, and responsible citizens' organizations unite to reverse the increasing rate of serious acute and chronic diseases by seeking greater protection of this vulnerable and precious population from exposure to chemical pesticides.

4) Parkinson's Disease and Pesticides 2009

Approximately 1 million residents of the United States suffer from Parkinson‘s disease (PD). The disorder usually strikes those over 60 and the rate triples in those over 85. (Washam, Cynthia, "Double exposure heightens Parkinson‘s disease risk, " EHP, 117, #7, July 2009, p. 295)

Epidemiological studies have linked a number of insecticides, fungicides and herbicides with PD. Two chemicals prominently implicated in the development of the disease are the herbicide paraquat and the fungicide maneb. (Ritz, B., "Dopamine transporter genetic variants and pesticides in Parkinson‘s disease, " EHP, 117, #6, June 2009, p. 964)

A test population living in an agricultural area, was found with two levels of genetic predisposition to PD (high and low). In addition, two pesticide exposure levels (high and low) were designated depending on the proximity of a given subject‘s residence to agricultural fields where combinations of paraquat and maneb were applied. The application data was taken from agricultural records. The researchers stated that "risk of Parkinson‘s disease (PD) seems to depend on whether subjects are exposed to pesticides. " The level of risk was found to increase if the subject had a high genetic predisposition to PD and was living close to the pesticides‘ application site. (Ritz, B., "Dopamine transporter genetic variants and pesticides in Parkinson‘s disease," EHP, 117, #6, June 2009, p. 964).

Impact (Parkinson's Disease and Pesticides in 2009):

People not involved in manufacturing, working with or personally using paraquat and maneb were found, nevertheless at increased risk of Parkinson's disease (PD) merely by living near a field regularly sprayed with a mixture of these pesticides. The 2009 study establishing this link should be of interest to everyone especially health care professionals. Other research has linked PD to general pesticide exposure. Health departments everywhere should make an urgent effort to warn against avoidable exposure to pesticides in general and paraquat and maneb in particular due to their association with Parkinson's disease.

5) Ecosystem Services Lost and Found: Birds, Bats, Fish, and People

Functioning ecosystems operating successfully provide vital services in four main areas: supporting (nutrient recycling, soil formation), provisioning (food, fresh water, wood, fiber), regulating (climate regulation, flood control, water purification, pest management) and, cultural (aesthetic, spiritual, educational). Ecosystems have also been recognized as having monetary value for investors. These essential ecosystem services3 depend on thriving wildlife populations. (Millennium Ecosystem Assessment, 2005).

Below are 3 different types of human/ecosystem services interactions.

In 1958, believing that sparrow-type birds were eating large amounts of grain, the Chinese government declared war on small perching birds, calling them major scourges in a class with rats, mosquitoes and house flies. Over a 3-day period, 800,000 small birds were eliminated by agitated crowds in Beijing alone. "The [policy‘s] consequence of course was major outbreaks of insect pests. The misjudgment was acknowledged [by Chinese officials] ... and the killing of insect-eating birds was subsequently banned." (Baskin, Y., The Work of Nature: How the Diversity of Life Sustains Us, Island Press, 1998)

An editorial in The New York Times recently reported that the mosquitoes were unusually numerous in the Adirondacks during August 2009 and that the bat populations were in decline due to the dreaded fungus infection, white-nose syndrome, that seems to be killing many of these nocturnal creatures. (Randolph, E., "The Trouble With Chiroptera (Bats), " NYT, 8-4-09). Bats are well-known consumers of mosquitoes so it may be that their reduced numbers are contributing to increases of the pest insects. It is as important for us to make the connection between mosquito control and bat populations, as it was for the Chinese government officials to connect insect control with birds.

Although it may appear that disease outbreaks, such as white-nose syndrome are not directly under our control, possibly with better information we might discover a connection between human activities and such conditions. For example, frog populations exposed to pesticide mixtures can develop suppression of their immune systems, with the likely result of higher disease levels. Could a similar effect take place in bats? Possibly yes. Note that there is no requirement to assess pesticides risks to bats before such products are registered with the EPA.

From Maine comes an account of people protecting fish by avoiding applications of chemical pesticides on nearby lands. The Downeast Salmon Federation has taken over management of blueberry fields converting them to organic production in order to protect the habitat of valuable and vulnerable migratory fish from pesticide contamination and/or from the adverse effects of land development. The aquatic habitat adjacent to the blueberry fields being managed by the Federation has some of the best salmon pools in the United States. The Federation director has stated, "We know that pesticides and herbicides are not good for aquatic life... [and] small amounts of herbicides [present in the water]...may be contributing to the fishery‘s decline." (Mack, S. K., "Salmon federation manages lands too," Bangor Daily News, 8-15-09)

We have already discussed how loss of wildlife numbers can impact society in terms of the 1958 Chinese experience, regarding ecosystem services provided by birds. In the U.S., although we have laws intended to protect migratory birds from being deliberately taken, they can be killed from exposure to certain toxic chemicals that are applied for pest control. An estimate of the number of birds killed annually in the United States by pesticides is 72 million. A conservative estimate of the number of fish killed annually by pesticides in the U.S. is 14 million. The estimated cost of these annual losses and the losses of pollinators and other beneficial insects is over $2 billion (Pimentel, D., "Economic and Environmental Costs of the Application of Pesticides primarily in the United States," Environment, Development and Sustainability, 7, pp 229-252, 2005.) Salmon populations were a focus of Rachel Carson‘s concern due to their vulnerability to DDT and other insecticides of the day.

It turns out that they are still in danger. As explained by Dr. Chuck Benbrook in the 2008 Rachel Carson Memorial Lecture, "...In the real world of pesticide regulation, birds, fish and bees are expendable." (Pesticides News 82, Dec 2008)

Impact (Ecosystem Services Lost and Found: Birds, Bats, Fish, and People):

Ecosystem services such as regulating (insect control) and provisioning (fishing) as well as numerous others essential to sustaining our way of life, depend on healthy wildlife populations to function. These natural services can be harmed by applications of toxic pesticides. Keeping pesticides out of the environment is within our control. Growers using methods that avoid hazardous chemicals and that work with nature to control unwanted organisms help protect ecosystem services. The responsibility for stewardship is on everyone's shoulders since we all can choose between toxic chemicals and sustainable practices and we all need pure water, clean air, safe food, as well as the other benefits of natural systems that make our society possible. Further, we all need to support those whose work supports the work of nature. See examples of organic agriculture in other countries (Issue # 10).

6) Frogs and Pesticides

Frogs are regarded as ecologically important members of wetland communities, cherished residents of wild areas, control agents for pest insects (like mosquitoes), a potential source for new drugs, and nature‘s early warning system of substantial aquatic contamination. Frog species have been declining worldwide. A number are close to the point of extinction (Lipps, K., "Save the frogs - and perhaps ourselves," The Baltimore Sun, 9-1-09) Many frog species are known to be extremely vulnerable to pesticides polluting the places where they struggle to survive.

The EPA does not require pesticides to be tested on frogs and does not routinely assess the risks of pesticide contamination to frogs themselves, to their habitats or to their food sources.

Nevertheless, toxicity research on frogs and pesticides has been conducted by university scientists. These studies have found that: tadpoles are more sensitive to pesticide hazards than are the adults; pesticide mixtures produce unexpected toxicity; species can differ in their sensitivity to pesticides; pesticides can be transported by wind to contaminate pristine environments and reduce frog populations living there.

The following examples of research findings indicate frogs‘ vulnerabilities:

• Pesticides applied in agricultural fields in California‘s Central Valley have been found transported to the Sierra Nevada Mountains by wind action. Two highly toxic insecticides, endosulfan and chlorpyrifos were found to harm frogs living in the mountains due to concentrations achieved as a result of wind transport. (Buckley, L., "Insecticides potentially harmful to frogs miles from application site," Pesticide & Toxic Chemical News, 8-3-09)

• "Glyphosate formulations containing the POEA surfactant have the potential to cause substantial amphibian mortality at environmentally expected concentrations." (Relyea, R., "Roundup Toxicity to Larval Amphibians," Environmental Toxicology and Chemistry, in press, 2009)

• Hermaphrodite frogs have been found in urban, suburban and agricultural ponds but they have not been found in ponds from undeveloped, often forested, areas. The occurrence of the hermaphrodite condition in frogs was believed to be due to contaminants found in the water such as pesticides, flame retardants, and chemicals used to give fragrance to soap and cosmetics. (Barringer, F., The New York Times, April 8, 2008). It is noteworthy that hermaphrodite frogs were not found in undeveloped forested areas.

• The insecticide endosulfan at low levels found in the environment can be deadly for tadpoles.

• For example 6.4 ppb (parts per billion) a very low concentration caused 86% mortality in a population of leopard frog tadpoles. (Relyea, R., Oecologia, 2009) Note: Endosulfan is very highly toxic to birds, fish, bees, crustaceans, mollusks and to mammals as well as to amphibians. (Briggs, S. and Rachel Carson Council, Inc., Basic Guide to Pesticides, 1992)

• A single application of a mixture of 5 insecticides (malathion, carbaryl, chlorpyrifos, diazinon and endosulfan) each of which was present at a non-toxic level resulted in 99% lethality in leopard frog tadpoles. (Relyea, R., "A cocktail of contaminants: how mixtures of pesticides at low concentrations affect aquatic communities," Oecologia, 159, pp. 1213-9, 2009).

• Tyrone Hayes and others have reported that exposures of tadpoles to mixtures of pesticides were associated with immune system suppression (from: Relyea, R., "A cocktail of contaminants: how mixtures of pesticides at low concentrations affect aquatic communities," Oecologia, 159, pp. 1213-9, 2009).

Impact (Frogs and Pesticides):

Frog losses and abnormal populations continue to be documented throughout the world. Generally, uncontaminated habitats have fewer problems for frogs. However, sites in pristine locations receiving pesticide contamination through atmospheric transport, can be hazardous to them.

Certain pesticide mixtures have been found to be highly toxic to tadpoles, even though the individual chemicals are present at levels that do not harm them. Such mixtures have produced immune suppression in some cases and fatalities in others.

Suppression of the immune system can result in higher levels of disease in a population. A deadly fungus is spreading to frogs around the world (Lipps, K, "Save the frogs - and perhaps ourselves" The Baltimore Sun, 9/1/09.) The hazardous nature of this infection could be enhanced by the immune suppression produced by pesticide mixtures. A variety of pesticide mixtures have been found in U.S. surface water. (Gilliom, R.J., et al., The Quality of Our Nation's Waters: Pesticides in the Nation's Streams and Ground Water, 1992-2001, revised, Circular 1291, U.S. Department of the Interior, U.S. Geological Survey, 2006)

In other words, frogs and other amphibians are under threat from chemical hazards, as long as these toxic materials continue to be released into the air, water or soil. For the sake of our frog populations and other wildlife exposed to pesticides, we need to minimize general pesticide use and ban those pesticides, such as endosulfan, found highly toxic to them.

Rachel Carson designated half of her own land in Maryland to be kept wild for the birds and frogs. She would no doubt be distressed by the continuing pesticide threats to frogs and other amphibians.

7) Endosulfan / Carbofuran / Glyphosate

Endosulfan Discontinuation Announced

In July 2009, the announcement came from Bayer CropScience that the company would stop U.S. sales of all products containing endosulfan by the end of 2010. They had stopped manufacturing the pesticide in 2007, but have been selling it in countries that still allow its sale, including the U.S. Endosulfan is already banned in over 20 countries and in the European Union. Endosulfan-containing products are still registered for agricultural applications in the U.S. (pers. comm. NPIC, August 2009). We urge an international ban.

Carbofuran - Settled At Last?

As we stated earlier ("Issues & Initiatives - 2006") the EPA proposed to cancel all carbofuran uses in 2006. Efforts by the manufacturer prevented that action. In a May 11, 2009 announcement, the EPA declared that it would revoke all food tolerances for carbofuran. When this rule becomes final, the EPA plans to proceed with the cancellation of registration for all domestic uses of the pesticide. Elsewhere, the deaths of lions due to use of carbofuran in bait has resulted in carbofuran‘s cancellation in Kenya.

Glyphosate - Severe restriction proposed in Argentina.

Based on research from Andres Carrasco medical professor at the Universidad de Buenos Aires, Argentina, "...draft legislation in the states of Buenos Aires and Jujuy would severely restrict glyphosate sales." Carrasco‘s studies have suggested "...that the herbicide poses an immediate threat to the environment, farm workers, and consumers." The research findings include "severe embryo malformations" in laboratory rabbits and rats and "birth defects in [residents of] rural areas of Argentina where use of the herbicide rose dramatically over the past decade..." (Lewis, S., "Proposed glyphosate ban gains traction in Argentina," PTCN, 8-3-09)

8) Scientists, Citizens, and Media Literacy

Problems with the quantity and quality of scientific information available to the public have been identified. Reports of interference with scientists' research continue to appear.

8-a) Pew Survey

A recent (2009) survey by the Pew Research Center for the People & the Press, in cooperation with the American Association for the Advancement of Science (AAAS) reported a low level of positive interaction between scientists, the popular media (newspapers, TV, magazines, radio), and the public.4

In a news account of the Pew Survey, a representative of the AAAS is quoted as commenting that scientists must find new ways to communicate with the public and that a more interactive process is very important.

Of the scientists polled, 85% said that the public‘s ignorance of science is a major problem. ("Public Praises Science; Scientists Fault Public, Media: Scientific Achievements Less Prominent Than a Decade Ago," Pew Survey Report - on-line, July 9, 2009)

8-b) Scientists/Citizen Communication

The need for communicating scientific information to members of the public (in non-technical language they can understand) is important. This is what Rachel Carson did in Silent Spring and what RCC tries to do in all of our publications and educational programs.

RCC has found that bringing together scientists and citizens can foster positive interactions provided certain conditions exist. At RCC‘s Wildlife, Pesticides and People Conference in 1998, the scientists were strongly urged to present their information in plain English. The result was an array of engaging speakers who made an effort to be understood by the audience of housewives, students, activists, and other scientists. Both presenters and audience members communicated enthusiastically and showed a surprising degree of mutual admiration and respect (even if they expressed different opinions), during the two-day event.

8-c) Media Literacy

The internet can be a wonderful source of scientific data including peer reviewed publications. However, misleading information may also present a problem for the citizen using search engines or sites that fail to edit or fact-check the "science" articles (or even op-ed pieces) that they accept for publication. "[Search engines] can be powerful research tools - or they can drive you straight to the sites that are most aggressive and adept at playing the search engine optimization game." (Maestretti, D., "Information Overload: In the Google Age, media literacy is crucial - and in short supply" UTNE Reader, July-Aug ‘09) From the coordinator of a college information literacy program comes the following observation: [Many] people ... don‘t have the tools to critically... understand the structures of media production and whose interests are being promoted..." (Maestretti, D., "Information Overload: In the Google Age, media literacy is crucial - and in short supply" UTNE Reader, July-Aug ‘09)

For those going to the internet for information, being a critical reader can be essential, especially when dealing with data bases and certain sites.

As part of RCC‘s service to the public, we provide critical analysis of articles from time to time. As an example, there is "...RCC‘s Commentary on ‗Rusted Roots. "5 This is an analysis of an article from the September 8, 2008 issue of the online magazine, www.slate.com under the "Green Room" section. When we consulted the scientific publication on which "Rusted Roots" purported to be based, it became evident that the Slate article failed to accurately reflect the reference cited. In other words, many of the conclusions in "Rusted Roots" were misleading. We conferred with experts and prepared a response that reflects our scientific background and standards. This is only one article on one site, but it can serve as an example of how to investigate and analyze such pieces. We continue to be concerned that the public may have no way of judging the accuracy of a "scientific-type" article found on the internet or any other non-peer reviewed source, without detailed fact checking and reference consulting.

8-d) Interference with Science

In 2008, government scientists identified the Bush Administration‘s suppression of scientific reports that contradicted the administration‘s political positions. RCC addressed this in our "Issues and Integrity 2008" and in our letter to President Obama (reprinted on our web site6). We have not heard of similar complaints about the Obama administration.

In February 2009, a group of research scientists announced that their work on genetically engineered crops was being hampered and suppressed by biotechnology companies. The methods used included denial of access to genetically engineered seeds and attempts to keep the scientists from publishing their findings on research performed on such crops.7

Today‘s problems require research at the highest level of scientific integrity, if we are ever to achieve a sustainable society. Attempts to influence scientific research need to be challenged by regulators, organizations and the public. All of us can suffer when the reluctance of scientists to speak out may be related to the perceived or real possibility of losing jobs, if they make their findings public.

Impact (Scientists, Citizens and Media Literacy):

Rachel Carson's "powerful ability to communicate complex scientific knowledge in an appealing, compelling and eloquent fashion...may be one of her most important legacies." (Lubchenko, J., "Rachel Carson‘s Scientific and Ocean Legacies" in Rachel Carson: Legacy and Challenge, eds. L.H. Sideris & K.D. Moore, 2008)

The failure of many scientists to communicate with the media on a regular basis is seen as a problem by the AAAS and others. RCC has been concerned that many popular media sources are not supplying the public with scientific information of sufficient quality as well as quantity.

Some educators and librarians are concerned that the public needs to be more media literate, and more alert to the different ways of "spinning" information, especially on the Internet, to convey a desired message. Without media literacy knowledge, the public may have difficulty in distinguishing between opinions on scientific topics that are not supported by data as opposed to peer-reviewed scientific findings, based on data.

RCC‘s response to these concerns in our publications is to provide not only scientific information but also to give the sources. Thus readers don‘t have to take our reports and conclusions on faith, but can check out the references for themselves. Further, we describe the information in terms that can be understood by the general public and we endeavor to answer any questions that may arise.

We have made it part of RCC‘s mission to show that using the scientific method involves critical analysis of media reports.

For example, we critiqued an online article, "Rusted Roots" (see footnote # 5). We analyzed a non-peer-reviewed article, from Science and found that it gave an erroneous impression of safety for the insecticide imidacloprid. This is described in our 35 Insecticides Used on or Around Dogs and Cats.

We are concerned that forces - either from the government or from private industry - can interfere with scientists‘ work, or with the publication of their findings. We have already commented on this matter in our letter to President Obama, and intend to make our position known to the U.S. EPA in the future.

Rachel Carson spoke out on issues, knowing she would be attacked by powerful interests. Likewise agricultural scientists who made public the efforts (by biotechnology industry forces) to thwart their research are aware that they may suffer professionally for their comments. We applaud them for their brave statements.

We encourage our legislators and scientific organizations to investigate these recurring problems and to help resolve them.

9) "Killer Compost"

Serious losses for U.S. growers and gardeners have been associated with the use of three persistent herbicides intended to kill broadleaf weeds on turf and pastures: picloram (Nichols, W. 7-11-07), clopyralid (Washington State University, 12-2-02), and aminopyralid (Pleasant, B., 7-24-09). The results have been lethal for sensitive plants when material contaminated with any one of these herbicides is used on or in soil. Since all three are systemic chemicals, they can be taken up from the soil by plant roots. Tomatoes, beans and peas are especially sensitive to the action of these three herbicides. Ornamentals can be adversely affected as well.

Toxic residues of these three chemicals can be found in hay, grass clippings, straw, or in manure from animals that have grazed on treated turf or been given hay that had been exposed to any of these persistent herbicides.

Finally, and this is most devastating, compost made from material previously mentioned, (hay, grass clippings and manure that had been contaminated with any one of these three herbicides: picloram, clopyralid or aminopyralid) can be hazardous to broadleaf plants due to the persistence of these chemicals in the active form.

We are advising gardeners to avoid adding material contaminated with picloram, clopyralid or aminopyralid to vegetable or flower gardens. A serious difficulty, however, is the inability to easily identify material as being contaminated with any of these three persistent herbicides. Laboratory tests may fail to detect the herbicides, or may be prohibitively expensive.

Homeowners can endeavor to keep their plants free of contamination with these chemicals by avoiding their use on lawns and by creating their own compost from herbicide-free components. For further details please consult RCC‘s "A Gardener Alert - Avoid Killer Compost. " (Online at http://www.rachelcarsoncouncil.org/uploads/articles/AGardenerAlerttoKillerCompost11-5-08.pdf)

For further information on this topic, see:

http://www.puyallup.wsu.edu/soilmgmt/Pubs/CloBioassay.pdf

http://www.waterpennyfarm.com

http://www.grabngrowsoil.com/clopyralidinformation.htm

http://www.rachelcarsoncouncil.org/uploads/articles/AGardenerAlerttoKillerCompost11-5-08.pdf

http://www.motherearthnews.com/Grow-It/Milestone-Herbicide-Contamination-Creates-Dangerous-Toxic-Compost.aspx

Impact ("Killer Compost"):

Warnings on product labels alone have proven to be ineffective in preventing serious problems related to applications of the persistent, systemic herbicides (picloram, clopyralid, or aminopyralid) to pastures and grass. (EPA-registered products containing each of these three chemicals include information about their persistence and potential adverse effects). If contaminated with any of the above three herbicides - plant material, manure from animals feeding on this plant material, and compost made from these sources, as well as the soil on which they are grown - are all potential sources of problems to sensitive plants. Further, we know that incidents of plant poisoning involving each of these herbicides continue to be reported by U.S. growers.

Possibly, the cancelling of pasture and turf registrations for all three herbicides would not immediately end the problem, but it could be an effective step, especially if accompanied by public education on the hazards of plant material, manure and compost contaminated with these persistent herbicides. RCC will urge the EPA to take such actions in our upcoming letter to the agency.

Our objective here is to alert all growers who are attempting to use natural means (hay, straw or compost) for weed control or soil enrichment. We are especially concerned with reaching new gardeners who may be easily discouraged by problems brought on by the "Killer Compost" effect.

Turf soil contaminated with any of these persistent, systemic herbicides (picloram, clopyralid, aminopyralid) presents problems for transitioning the site from grass to a vegetable or a butterfly garden.

Bitter experiences of growers here and in the U.K. show that even minute quantities of these herbicides can be deadly to some of our favorite garden crops: tomatoes and beans.

Estimates claim that the herbicidal activity of soil contaminated by these herbicides may persist for up to three years. (Davis, J., "Herbicide Carryover in Hay, Manure, Compost, and Grass Clippings, " http://www.ces.ncsu.edu/fletcher/programs/ncorganic/2009extension-article-herbicide-in-hay-manure-etc.pdf)

This is a problem in need of strong, remedial action.

10) Organic Farming Abroad - 2009

10-a) Indian Farmers

In 2009, many Indian farmers in the Punjab region are reported to be facing problems that compromise the health of the land and of themselves, as people depending on it. These conditions can be traced to the Green Revolution of the 1960s that introduced the agricultural techniques of high yield seeds, requiring the use of synthetic fertilizers, chemical pesticides, and greater quantities of irrigation water. These developments as well as price supports by the Indian government for export crops contributed to the growing of cotton, wheat and rice in the Punjab. Individuals with large farms prospered for the next three decades, due to the success of Green Revolution-related crops. Now with groundwater in the Punjab becoming scarce due to continued irrigation, with depletion of soil nutrients due to high levels of pesticides and monocropping, with greater quantities of fertilizers and pesticides needed to maintain yields, and with illnesses among farmers and their family members, possibly due to pesticide exposure, this prosperity is declining and appears to be unsustainable. Organic farming‘s appeal has increased in the Punjab and elsewhere in India. This more natural system of farming seems to offer solutions to many of the problems brought about by the earlier chemically-intensive system. To farmers in India, organic means more than simply not spraying synthetic fertilizers and pesticides, instead they grow a mixture of crops in the same field that replenish the soil. Those favoring the organic system seek a new sustainable, naturally-green revolution that can make a good living for families, protect and enhance the environment and produce healthy, affordable food. (Zwerdling, D., NPR Broadcast from India, 2009)

Organic farming is gaining favor with international organizations as well.

10-b) The "United Nations Environmental Programme" (UNEP) and Organic Farming in 2009

In February 2009, in response to three serious problems: recent declines in agricultural production, faltering food distribution networks, and the worldwide environmental deterioration, UNEP generated a report - "The Environmental Food Crisis." It provides evidence that small scale organic agriculture can deliver acceptable yields without the environmental and social damage that have resulted from the industrial model of agriculture. (Deen, T., "U.N. Seeks a Green Revolution in Food," IPS, 3-15-09)

"Organic agriculture is a sustainable and environmentally friendly production system that offers African and other developing countries a wide range of economic, environmental, social and cultural benefits." (from: Executive Summary of "The Environmental Food Crisis") The UNEP Executive Director, Achim Steiner commented, "...we need a revolution that can boost yields by working with rather than against nature." (Deen, T., "U.N. Seeks a Green Revolution in Food," IPS, 3-15-09)

Impact (Organic Gardening Abroad - 2009):

Rachel Carson stated, "...it will take time to revolutionize our methods of insect and weed control to the point where dangerous chemicals are minimized." (in, "A New Chapter to Silent Spring," 1963.)

The Green Revolution came from the 1960s and data suggests it needs to be re-examined. Following the lead of Achim Steiner, RCC calls for a new naturally-green revolution as a sustainable, healthy and honest alternative way of the future.

11) Solitary / Native Bees

There are 4,000 bee species native to the U.S. Most wild bees (more than 85% of the 20,000 bee species worldwide) are solitary bees and they do not show the social behavior or the aggression of the domestic honey bees. In other words, they are more gentle than honey bees and less likely to sting. For solitary bees, "each female independently mates, makes her own nest of about 10 brood cells, stocks the cells with food for the young, lays an egg in each cell and dies before the next generation emerges." (Batra, S., "Solitary Bees," Scientific American, v. 250, #2, 1984, pp 120-127) Within this general context some fascinating behaviors have been described by Dr. Suzanne W.T. Batra in her 1984 Scientific American article, "Solitary Bees." (Copies are available from the RCC library, thanks to Dr. Batra).

According to Professor Bryan Danforth of Cornell U., "native bees [most of which are also solitary bees] are pollinators for apples, blueberries, cranberries, sunflowers, watermelons, squashes and pumpkins to name just a few." (7-25-09 "Commentary") He also states that "...biologists are now carefully examining the role that native bees perform in crop pollination... Conserving our diverse native bee fauna is good for the environment and may also preserve our ability to produce the fruits, berries, nuts and vegetables that keep our diet varied, interesting and healthy. " (7-25-09 "Commentary")

Solitary bees nest in the ground, in wood and in hollow reeds. Individual species may be active for only 1-2 months out of the year. They can be nurtured by providing undisturbed nesting areas, plants supplying nectar and pollen, as well as, most importantly, freedom from toxic chemicals especially the systemic neonicotinoid insecticides such as imidacloprid and clothianidin, that are extremely hazardous to bees.

Native bees are in decline worldwide. A movement to conserve and protect them is gaining support here in the U.S. Researchers in California believe that urban areas could serve as reserves of pollen and nectar sources for native bees especially in times of drought. More research is needed, especially on, "the ecology and behavior of native bees in urban environments... [and] how to encourage bees to visit gardens." (Fankie, G. et al, "Native bees are a richnatural resource in urban California gardens," California Agriculture, July-Sept, 2009) We at RCC would add that such a scenario could only succeed as long as no chemical insecticides are used in or around these garden areas. Floral scents used by bees to locate sources of nectar may be altered through chemical reactions with air contaminants such as ozone. The consequent disruption of airborne signals that has resulted is believed to have made locating beneficial plants more difficult for the bees. (Potera, C., Floral Scents Going Off the Air? EHP, V116, #8, Aug 2008). Bees need clean air, too!

Impact (Solitary/Native Bees):

Incidents of Colony Collapse Disorder (CCD) of honey bees have been widely reported, but the cause(s) are not yet identified. Therefore, it is all the more important to provide safe habitats for solitary/native bees. By protecting them, we will also be helping to protect our food supply and that of wild creatures, since we all depend on pollinating services.

12) Two Great Green Gardens

12-a) The Versailles Palace, France:

Alain Baraton is head gardener of the 2,000 acre Versailles Palace grounds, a historic site "with some trees so ancient they bore witness to the French revolution." By proposing changes to make Versailles a model of sustainability, Baraton has launched another type of revolution - that may "transform gardening across France." (Moore, M., "In the Gardens of Versailles, A Horticultural Revolution," The Washington Post, 7/9/08). In 2007, Baraton banned chemical insecticide applications, with a result that birds, finding insects available as a food source, "returned to Versailles in numbers not seen for decades." (Davies, L., "Versailles: the piece de resistance of modern gardening, "

http://www.guardian.co.uk/lifeandstyle/2008/jul/29 /gardens.france

Another example of a Baraton change - in place of rows of the same species of trees, he plants various species - to prevent major losses in case of disease affecting one type of tree. (Moore, M., "In the Gardens of Versailles, A Horticultural Revolution," The Washington Post, 7/9/08)

Baraton refers to his work as a common sense approach and rejects the organic label. In his words, "A garden is normal when it is organic. " With chemical use, it is "a polluted garden." He works to create a garden which is "good for nature, an intelligent garden." (Davies, L., "Versailles: the piece de resistance of modern gardening,"

http://www.guardian.co.uk/lifeandstyle/2008/jul/29/gardens.france

12-b) The White House, Washington, DC:

In the spring of 2009, a plot composed of "1,100 square feet on the South Lawn of the White House" grounds was transformed into an organic kitchen garden by First Lady Michelle Obama and friends, including a group of fifth graders.

"What Michelle and the kids and the crew did...was to drive a shovel right into the heart of that American icon: the lawn, [and thus they planted] the seeds of a revolution. " (Goodman, E., "Planting the seeds of a revolution," The Boston Globe, 3/27/09)

"Today, lawns cover 40 million acres, making them the largest agricultural sector in America. They consume over 70 billion gallons of water a week, or enough for 81 million acres of organic vegetables. They suck up $40 billion a year on seed, sod and chemicals..." (Goodman, E., "Planting the seeds of a revolution, " The Boston Globe, 3/27/09) This may be a fertile time for a "grass-roots anti-grass movement. " (Goodman, E., "Planting the seeds of a revolution," The Boston Globe, 3/27/09)

The hazards of chemical pesticides and other synthetic lawn amendments, especially to children, pets and wildlife have been described in RCC‘s publications, including: "Golf at a Crossroads," "Snoopy Only Lands on Toxic-Free Lawns," and others. (See: Issues # 3, 4, 5, & 6.)

Impact (Two Great Green Gardens):

"...The garden teaches [us] ... that as long as the sun still shines and people still can plan and plant, think and do, we can...find ways to provide for ourselves without diminishing the world."8

The First Lady‘s White House kitchen garden serves as an enormous source of inspiration for Americans. The fact that no chemicals are applied to the plants growing there is most fitting.

Every year, more research accumulates confirming that chemical pesticides are not "safe" for people, pets and wildlife.

From the "Killer Compost" experience, we have learned that three persistent chemical herbicides,9 intended to keep lawns free of broad-leaf weeds can poison beneficial food-producing plants. (See: Issue # 9.) Some of the most susceptible garden plants are tomatoes and beans. Therefore, we urge families to keep lawns organic, so the area can be converted to the growing of vegetables at any time. Creating a food-producing garden plot "... is one of the most powerful things an individual can do to reduce [his or her] carbon footprint." 10

A grand garden in the heart of France has become a source of inspiration for citizens of that country, who love beauty and sustainable growing practices. From his position as the head gardener of the iconic and lavish Versailles Palace gardens, the untraditional Alain Baraton urges others to follow his lead in adopting non-chemical methods of pest control. The banning of chemical insecticides in the Versailles garden was followed by the return of birds "in numbers not seen for decades," due to the increased availability of insects.

These two impressive examples of sustainable initiatives in gardening - one in the USA and the other in France - point us in the same direction as a recent United Nations report11 that supports sustainable agriculture as a solution to "The Environmental Food Crisis." RCC hopes that these policies indicate an increasing turn to methods of growing food, shrubs, and flowering plants - that work with, rather than against, nature.

13) Insecticide Incidents and RCC

Tetrachlorvinphos

In May 2009, RCC learned that the EPA was reviewing for the first time, over 40,000 incidents related to 7 pesticide products for flea and tick control on pets. Incidents, in this case are adverse reactions to these pesticide products, as reported by the public and sent to the EPA, but not necessarily reviewed by them. We believe that an action by RCC in September 2008 contributed significantly to the May 2009 announcement, as we explain below.

The backstory: In preparing comments to the EPA on its September 2008 review of the pesticide tetrachlorvinphos (a neurotoxic organophosphate, registered for use on dogs and cats for flea and tick control) RCC noted that the EPA‘s draft document included only one incident report - a fatality in a red-tailed hawk. RCC‘s own file for this chemical was found to contain over 2,000 incident reports pertaining to dogs, cats, other domestic animals, fish, bees, and people. These reports had all come from the EPA and had been obtained by RCC under a Freedom of Information Act (FOIA) request. The incident data for dogs, cats and people was included in RCC‘s 2005 publication, "35 Insecticides Used on or Around Dogs and Cats." Along with RCC‘s thoughtful comments on tetrachlorvinphos, the 2,000 incident reports were sent back to the EPA. After receiving them, EPA checked its files and found a total of not one but 4,000 incident reports for this chemical (the 2,000 from RCC plus 2,000 new ones). This may very well have served as a wake-up call for the EPA and explain its increased focus on pets, pesticides and incident reports resulting in the May 2009 announcement.

14) Systemic Pesticides

Systemics are chemical pesticides capable of being absorbed into the plants, from roots and elsewhere. For example, they can be applied to the soil, enter the roots, and travel to all parts of the plant. If they are insecticides, they may harm or kill insects feeding on the leaves or collecting nectar and/or pollen. Rachel Carson wrote about systemic insecticides in Silent Spring as follows: "...the world of systemic insecticides is...perhaps most closely akin to the cartoon world of Charles Addams. It is a world where the enchanted forest of the fairy tales has become the poisonous forest in which the insect that chews a leaf or sucks the sap of a plant is doomed...where a bee may carry poisonous nectar back to its hive and presently produce poisonous honey." (pp. 32-33)

In 2008, Dr. Chuck Benbrook, delivering the Rachel Carson Memorial Lecture stated the following about systemic pesticides: "In the last decade, the seed and pesticide industry has made a major commitment to systemic-based technology." [This technology's] "unique vulnerabilities have been out of sight and out of mind." (Benbrook, C., "Prevention, not profit, should drive pest management," Pesticides News 82, December 2008) The insecticides: imidacloprid and clothianidin as well as the herbicides: picloram, clopyralid, and aminopyralid are a few of the systemic pesticides described above. There are many more systemic pesticides; contact RCC for a list.

Impact (Systemic Pesticides):

Systemic pesticides by their very nature are readily absorbed into a plant and subsequently transported to all its parts. Because they are poisons, they can increase the toxicity of the plant for the period of time that they remain active. They can damage beneficial, non-target species that depend on the contaminated plants.

Individuals need to be aware of and avoid contamination of their gardens with systemic pesticides carried in or on plant and animal products. This is especially important, when a plot is designated as part of a community garden.

Growers need to determine if the seedlings they purchase have previously been exposed to systemic insecticides. Why? Systemic insecticides, since they are retained throughout the plant, could possibly have adverse effects on bees and butterflies that might collect nectar or pollen from the plant, once it is part of the garden. Imidacloprid and clothianidin, two popular, systemic insecticides are highly toxic to bees.

Three systemic herbicides, picloram, clopyralid and aminopyralid have been associated with the "Killer Compost" problem, reported in Issue # 9.

In the light of comments by Dr. Benbrook concerning systemic pesticides‘ vulnerabilities ("out of sight, out of mind"), we urge further research on the health and environmental effects of these widely used chemicals.

(Contact RCC for information on the systemic status of specific pesticides.)

15) New York City Study of Alternative Pest Control Methods

A study published in 2009,12 compared the effectiveness of a traditional pest control method, consisting of scheduled applications of pesticides by professionals, with an alternative method using integrated pest management (IPM). The study took place in conjunction with the New York City Public Housing Authority in some of its apartment buildings. This integrated pest management (IPM) program used for apartments showed significantly reduced pest populations and reduced pest-associated allergens compared to the traditional control method of regularly scheduled pesticide applications. The IPM program used in this study included actions by the program representatives giving the apartment residents‘ information focused on: "improving the sanitary and structural conditions to deny pests food, water, harborage [a safe refuge] and movement [into the home]." The IPM program also included "the judicious use of [least toxic] pesticides after an evaluation of need and the hazard to human occupants." The IPM-based education of apartment dwellers was "completed in a single visit..." (See footnote # 7.)

Impact (New York City study of Pest Control Methods):

With reduction of traditional pesticides in the apartments under the IPM program specified in this study, there would be fewer opportunities for exposure of children to toxic chemicals. "In New York City, greater than 1,000 accidental exposures to pesticides are reported to the regional poison control center annually, with the vast majority occurring to children in the home." (See footnote # 7.)

Following the study, the New York City Housing Authority (NYCHA) is reported to have implemented IPM changes at some locations. These included greater efforts at pest exclusion, distribution of cockroach baits, and education. NYCHA also is reported to have suspended the routine use of pyrethroid chemical insecticide sprays in all but basement areas that are not accessible to residents. (See footnote # 7.)

"Issues and Impacts" was prepared by Dr. Diana Post, assisted by Munro Meyersburg and the RCC Staff - September 2009

REVIEW QUIZ

1) What herbicide has recently been associated with birth defects in Argentina?

2) Under IPM (Integrated Pest Management), what are the four ways that apartment dwellers can help prevent pests from becoming established indoors?

3) What three systemic, persistent herbicides can produce "Killer Compost?"

4) Which classes of pesticides have been linked to autism?

5) True or False? If a pesticide is registered by the U.S. Environmental Protection Agency, then that pesticide is safe to use, provided that it is used as specified by the instructions on the product‘s label.

6) What is the most likely reason why birds returned to the gardens at Versailles Palace, once the spraying with insecticides had been discontinued?

REVIEW QUIZ - ANSWERS

1) Glyphosate

2) Deny pests food, water, harborage (a safe refuge), anbd movement (into the home).

3) Picloram, clopyralid, aminopyralid

4) Organochlorines, Organophosphates, Pyrethrins, Pyrethroids

5) False

6) Due to the increased number of insects

REFERENCE ABBREVIATIONS - EXPLAINED

The Balt. Sun The Baltimore Sun

The Drug Monit. Therapeutic Drug Monitor

EHP Environmental Health Perspectives

ET&C Environmental Toxicology and Chemistry

Int‘l Mtg for Autism Res International Meeting for Autism Research

IPS InterPress Service News Agency

JAMA Journal of the American Medical Association

NPIC National Pesticide Information Center

NPR National Public Radio

NYT The New York Times

PTCN Pesticide & Toxic Chemical News

UNEP United Nations Environmental Programme

1 The term "economic poisons" has been adopted by most state and federal laws as defining pesticides. (Ware, G.W., The Pesticide Book, 4th edition, 1994)

2 Companies have been fined millions of dollars for calling pesticides "safe."

3 RCC‘s publication, Wildlife at Work gives an overview and examples of ecosystem services. (ordering information is on RCC‘s Website: www.rachelcarsoncouncil.org) 4 "...only 3 percent of the scientists said they "often" spoke to reporters. " (Dean, Cornelia, "Views of scientists and public in conflict, survey finds, " The NYT, 7-9-09)

5 See at: http://www.rachelcarsoncouncil.org/uploads/articles/RCCsCommentaryonRustedRoots.pdf

6 http://www.rachelcarsoncouncil.org/uploads/articles/RCC%20Open%20Letter%20to%20Obama.pdf

7 Dr. Elson Shields of Cornell University, speaking for the researchers indicated that financing of professors‘ research has shifted from the public sector to the private sector making scientists dependant on financing or technical cooperation from the biotechnology companies. On behalf of the researchers, Dr. Shields stated, "People are afraid of being `black listed‘ and professionally cut off from essential material for their work." (Pollack, A., "Crop scientists say biotechnology seed companies are thwarting research," The NYT, 2-20-09)

8 Pollan, M., "Why Bother?" from: Food, Inc., Karl Weber, Editor, 2009.

9 Picloram, clopyralid, aminopyralid.

10 Pollan, M., "Why Bother?" from: Food, Inc., Karl Weber, Editor, 2009.

11 The UNEP Report, "The Environmental Food Crisis" reported in: Deen, T., "U.N. Seeks a Green Revolution in Food," IPS, 3-15-09