The Story of the Alar Ban: Politics and Unforeseen Consequences

Daminozide; Termination of Special Review of Food Uses, Federal Register Vol. 54, No. 216 Tuesday, November 14, 1989 p. 47482.

Daminozide Special Review Technical Support Document — Preliminary Determination to Cancel the Food Uses of Daminozide, May 1989, Office of Pesticide Programs, Office of Pesticides and Toxic Substances, United States Environmental Protection Agency D-10806 p. III-3.

Ibid.

Daminozide; Termination of Special Review of Food Uses, Federal Register Vol. 54, No. 216 Tuesday, November 14, 1989 p. 47482.

“Thoughts on the Apple Harvest Problem” Lord William J. , Dept. of Plant and Soil Sciences Fruit Notes May-June 1969 pp. 8–9.

Druckrey (1967) and Roe . (1967) cited in Zeise . “Alar in Fruit: Limited Regulatory Action in the Face of Uncertain Risks” cited in The Analysis, Communication and Perception of Risk, Garrick B. J. and Geckler W.C. , eds. Plenum Press, NY 1991.

Toth B. , “1,1-Dimethylhydrazine (unsymmetrical) Carcinogenesis in Mice: Light Microscopic and Ultrastructural Studies on Neoplastic Blood Vessels,” Journal of the National Cancer Institute, 50; 181–187, 1973 and Toth B. , “The Large Bowel Carcinogenic Effects of Hydrazine and Related Compounds Occurring in Nature and the Environment,” Cancer Supplement, Volume 40, 2427, 1977.

Mott Lawrie D. , “Chronology for Daminozide,” Natural Resources Defense Council, Inc. San Francisco, CA (no date).

Ibid.

Hathaway J. S. “Alar: The EPA's Mismanagement of an Agricultural Chemical” in Pimentel and Lehman , ed., The Pesticide Question Environment, Economics and Ethics Chapman and Hall 1993 p. 338.

Mott Lawrie D. , “Chronology for Daminozide,” Natural Resources Defense Council, Inc. San Francisco, CA.

Ibid.

Mott Lawrie D. , “Chronology for Daminozide,” Natural Resources Defense Council, Inc. San Francisco, CA (undated but probably 1990).

Ibid.

Memo from Stephen Wood, President of New England Fruit Growers' Council on the Environment, Poverty Lane, West Lebanon New Hampshire, to Members of the Risk Assessment/Risk Management Work Group, Keystone National Policy Dialogue on Food Safety Oct. 26, 1990. According to this memo, the NPR report claimed that only red apples were treated with Alar which prompted New Hampshire apple farmer Stephen Wood to call Daniel Zwerdling at NPR to correct him. Zwerdling was not receptive to the correction and the next week, ran a follow-up story on Alar, reiterating that Alar was not used on Granny Smith or other green apples and that, If everybody, all of us, continue eating Alar-contaminated foods for the rest of our lifetime, then eventually one out of every 1,000 people will get cancer just from eating Alar. “When Wood called Zwerdling, asking where the risk estimates came from, he was told,” Look, I don't have time to argue about my methods. I know Alar's central to your life, but it just isn't to mine. If you want to criticize my report, put it in a letter. They read them.”

Hathaway J. S. “Alar The EPA's Mismanagement of an Agricultural Chemical” in Pimentel and Lehman , eds., The Pesticide Question: Environment, Economics and Ethics Chapman and Hall 1993 p. 338.

Daminozide Special Review Technical Support Document — Preliminary Determination to Cancel the Food Uses of Daminozide, May 1989, Office of Pesticide Programs, Office of Pesticides and Toxic Substances, United States Environmental Protection Agency D-10806 p. I-8.

“Government Regulation of Pesticides in Food: The Need for Administrative and Regulatory Reform,” Report by the Subcommittee on Toxic Substances, Environmental Oversight, Research and Development to the Committee on Environment and Public Works, United States Senate, Oct. 1989 pp. 33–34 cited in Hathaway J. S. “Alar: The EPA's Mismanagement of an Agricultural Chemical” in Pimentel and Lehman , eds., The Pesticide Question Environment, Economics and Ethics Chapman and Hall 1993 p. 338.

Daminozide Special Review Technical Support Document (see reference #74) p. II-37.

Ibid.

“B-Nine SP on Ornamentals — Greenhouse Mixer/Loader/Applicator Exposure Study” Uniroyal Study voluntarily submitted to EPA, completed May 6, 1991 MRID# 418760–01,02.

Ames Ron , Uniroyal, telephone interview, January 17, 1994.

Hathaway J. S. “Alar The EPA's Mismanagement of an Agricultural Chemical” in Pimentel and Lehman , ed., The Pesticide Question: Environment, Economics and Ethics Chapman and Hall 1993 p. 339.

Daminozide Special Review Technical Support Document (see reference #72) p. ii.

Memo from Stephen Wood, President of New England Fruit Growers' Council on the Environment, Poverty Lane, West Lebanon New Hampshire, to Members of the Risk Assessment/Risk Management Work Group, Keystone National Policy Dialogue on Food Safety Oct. 26, 1990.

Mott Lawrie D. , “Chronology for Daminozide,” Natural Resources Defense Council, Inc. San Francisco, CA.

Op. Cit. p. 5.

Lehman Hugh “New Directions for Pesticide Use” in Pimentel and Lehman , ed., The Pesticide Question: Environment, Economics and Ethics Chapman and Hall 1993 p. 4.

Memo from Stephen Wood, President of New England Fruit Growers' Council on the Environment, Poverty Lane, West Lebanon New Hampshire, to Members of the Risk Assessment/Risk Management Work Group, Keystone National Policy Dialogue on Food Safety Oct. 26, 1990.

51 Fed. Register 12889.

Mott Lawrie D. , “Chronology for Daminozide,” Natural Resources Defense Council, Inc. San Francisco, CA.

Ibid. p. 11.

There are numerous examples of individual states initiating public health and environmental legislation that the federal government eventually enacts. The Right-to-Know laws of a few states became part of federal OSHA's Hazard Communication Standard. The banning of many agricultural chemicals, including Ethylene Dibromide and DDT, and industrial chemicals like Carbon Tetrachloride and Polychlorinated Biphenyls (PCBs), as well as some consumer products, like Urea Formaldehyde Foam Insulation, began with bans at the state level. See Toxic Chemical Management in Masssachusetts: An Analysis of Further Chemical Restriction Policies Rossi, Mark and Geiser, Ken, The Toxics Use Reduction Institute, University of Massachusetts Lowell, pp. 83–95, for an analysis of the case studies of six banned substances.

Sewall Bradford and Whyatt Robin Intolerable Risk: Pesticides in Our Children's Food, Natural Resources Defense Council, Feb. 27, 1989.

Ibid. p. 29.

Ibid. p. 2.

Ibid.

Ibid. p. 2–3.

Memo from Stephen Wood, President of New England Fruit Growers' Council on the Environment, Poverty Lane, West Lebanon New Hampshire, to Members of the Risk Assessment/Risk Management Work Group, Keystone National Policy Dialogue on Food Safety Oct. 26, 1990.

Egan Timothy “Apple Growers Bruised and Bitter After Alar Scare” New York Times, Tuesday July 9, 1991.

Ibid.

Letter in Science Vol 244, 19 May 1989 from Edward Groth III, Consumers Union of the US, Inc.

Sugarman Carole , “Apple Processors Urge the EPA to Ban Alar,” Washington Post, May 12, 1989, quoted in Hathaway Janet “Alar: The EPA's Mismanagement of an Agricultural Chemical” in Pimentel and Lehman , eds., The Pesticide Question Environment, Economics and Ethics, Chapman and Hall, New York and London, 1993 p. 343.

Hathaway Janet , telephone interview, March 28, 1995.

Wood Stephen , telephone interview, March 29, 1995.

Daminozide Special Review Technical Support Document (see ref. #74) p. II-43.

Hathaway J. S. “Alar: The EPA's Mismanagement of an Agricultural Chemical” in Pimentel and Lehman , eds., The Pesticide Question Environment, Economics and Ethics Chapman and Hall, New York and London, 1993 p. 338 citing Daminozide Special Review PositionDocument 2/3/4, Draft, September 12, 1985 EPA p. II-52.

Daminozide Special Review Technical Support Document — Preliminary Determination to Cancel the Food Uses of Daminozide, May 1989, Office of Pesticide Programs, Office of Pesticides and Toxic Substances, United States Environmental Protection Agency D-10806.

“Uniroyal pesticide to be reviewed by EPA: Regulatory Action Prompted by its Toxicity” Chemical Marketing Reporter, July 23, 1984 226; 3.

Anderson Bob “La. plant makes chemical that has apple industry in uproar” The Baton Rouge Morning Advocate, March 15, 1989, p. 3-A.

James A. Wylie quoted in “Uniroyal pulls apple pesticide from market, citing controversy,” Chemical Marketing Reporter, June 5, 1989.

This, and all subsequent information in this paragraph, is from George Porter, at the Massachusetts State Department of Food and Agriculture. The statistics are from the New England Agricultural Statistics Service, USDA, Concord, NH 1992.

New England Agricultural Statistics, 1992 USDA publication, p. 34.

Unidentified picker on Rick Smith's orchard, Ashfield MA Oct. 13, 1993.

Clark Dana , grower, Ashfield, MA, interview, Oct. 13, 1993.

Chick Fred , grower, Worthington, MA, interview, Oct. 14, 1993.

Syncook Joe , telephone interview, Nov. 16, 1993.

Britton Sharon “The post-Alar era dawns chilly for apple growers” Boston Globe Oct. 25, 1989 p. 34, quoting Jack Manning, sales agent for J. P. Sullivan and Co., of Ayer, MA, an apple commission house.

Warren Nick , unpublished paper Unanticipated Consequences of Banning A Chemical: The Case of Alar, Work Environment Dept., UMass Lowell Dec. 17, 1992 p. 14.

Ibid.

Ibid.

Ibid. p. 7.

Clark Dana , interview, Oct. 13, 1993.

Egan Timothy , “Apple Growers Bruised and Bitter After Alar Scare” New York Times Tuesday July 9, 1991.

Clark Dana , interview, Oct. 13, 1993.

Syncook Joe , telephone interview, Nov. 16, 1993.

Syncook Joe , telephone interview, Nov. 16, 1993.

Warren Nick , in his unpublished paper Unanticipated Consequences of Banning A Chemical: The Case of Alar, Work Environment Dept., UMass Lowell Dec. 17, 1992, states,“One estimate (Greene and Autio, 1987) puts the labor of summer pruning at 30 hours/acre, with an accompanying 40 percent drop in dormant pruning time Since dormant season pruning used to take about 35 hours/acre, this translates into 21 hours of dormant pruning for a year-round total of around 51 hours/acre. Autio's more recent estimate (1992) is 23 hours/acre in the summer, with an additional 10–12 hours in the winter, resulting in a total figure of 30–32 hours/acre. If this more recent estimate proves to be correct, summer pruning may actually have reduced year-round pruning from the older winter figure of 35 hours/acre… But most growers seem to feel that the move to summer pruning does represent some increase in labor needs.” p. 13.

Autio 1992, phone conversation cited in Warren Nick unpublished paper Unanticipated Consequences of Banning A Chemical: The Case of Alar, Work Environment Dept., UMass Lowell, Dec. 17, 1992.

Ibid.

Britton Sharon , “The post-Alar era dawns chilly for apple growers” Boston Globe Oct. 25, 1989 p. 29.

Warren Nick , op. cit. p. 7.

Wood Stephen , telephone interview, Feb. 28, 1995.

Chick Fred , interview, Oct. 14, 1993.

Clark Dana , interview, Oct. 13, 1993.

Syncook Joe , telephone interview, Dec. 16, 1993.

Ibid.

Du Pont MSDS No. M0000057 p. 2.

Berberian IG , Journal of Occupational Medicine, Vol. 29 1987, p. 409.

Syncook Joe , telephone interview Dec 16, 1993.

Saunders 1987 “Outbreak of Omite-CR-Induced Dermatitis Among Orange Pickers in Tulare County, CA,” JOM, Vol. 29, No. 5 pp. 409–413.

Edwards Clive A. “The Impact of Pesticides on the Environment,” in Pimentel and Lehman , ed., The Pesticide Question Environment, Economics and Ethics Chapman and Hall 1993 p. 291.

All information about Daminozide is from Farm Chemicals Handbook 1985 Meister Publishing Co., Willoughby, Ohio 1985 p. C 10.

Information about oxamyl is from the Farm Chemicals Handbook 1985 Meister Publishing Co., Willoughby, Ohio 1985 p. C 175 and Du Pont Material Safety Data Sheet #M0000057 for “Vydate” L Insecticide/Nematicide 5/90.

Farm Chemicals Handbook 1993 Meister Publishing Co., Willoughby, Ohio 1993 p. C 282.

LD50 and LC50 stand for Lethal Dose and Lethal Concentration, respectively. They represent the dose at which 50 percent of the test animals die.

National Institute for Occupational Safety and Health Classification of Pesticides p. 360.

DuPont Material Safety Data Sheet #M0000057 for “Vydate” L Insecticide/Nematicide 5/90.

National Institute for Occupational Safety and Health Classification of Pesticides p. 349.

Ibid. p. 350.

Uniroyal Chemical MSDS No. A313002 for B-Nine (same formulation as Alar) Dec. 19, 1990.

Neither OSHA nor ACGIH (American Conference of Governmental Industrial Hygienists) has established an Exposure Limit for Vydate, although DuPont's is 0.5mg/m3 for an eight-hour Time-Weighted Average, according to DuPont MSDS #M0000057.

Wood Stephen , telephone interview, March 29, 1995.

Moore Richard , Uniroyal Agrochemical Division, telephone interview, March 30, 1995.

Ibid.

Prokopy Ron , telephone interview, March 31, 1995. He also explained that Stephen Wood is more “up on the literature” than most growers.

Farm Chemicals Handbook Meister Publishing Co., Willoughby, Ohio 1994.

Chick Fred , telephone interview, Oct. 14, 1993.

Smith Rick , telephone interview, Jan. 19, 1994.

Ibid.

Stott WT and Bullerman LB “Patulin: A Mycotoxin of Potential Concern in Foods” J. Milk Food Technology Vol. 38 No. 11 pp. 695–705 (Nov. 1975).

Ibid.

Ibid. p. 701.

Toxic Chemical Management in Massachusetts: An Analysis of Further Chemical Restriction Policies Rossi, Mark and Geiser, Ken, The Toxics Use Reduction Institute, University of Massachusetts Lowell, 1992.

Hathaway Janet , Natural Resources Defense Council, telephone interview, March 28, 1995.

Wood Stephen , telephone interview, New Hampshire Apple Grower, President of New England Fruit Growers' Council on the Environment, Jan. 29, 1995.