The Public Policy/Cancer Scare of the Month
Havender, William R.
St. Patrick's Day crowds. The very next day, however, Times readers might have thought they were seeing the same picture--until a glance at the caption explained that here was Koch (sans the...
...In fact, I am at least $700 in the hole for all the long distance calls I made in investigating the EDB issue, and even received a call from an outraged representative of the peanut industry objecting to my remarks on "Nightline" about the hazards of aflatoxin in peanut butter...
...with this year's budget he reported a $500 million surplus...
...This level of risk, moreover, is inconsistent with extant data on workers exposed to EDB levels five to ten thousand times greater than typical consumers over long periods...
...Concerning phosphine, no long-term, high-dose animal cancer test has yet been performed...
...Other states soon followed Florida's lead, and the environmentalists and media did their part...
...Decide in haste, repent at leisure" goes an old saw that has proved uncannily apt in evaluating previous William R. Havender is an independent consultant on environmental carcinogens who lives in Berkeley, California...
...EDB, for example, presents an even smaller carcinogenic hazard than saccharin because saccharin, while a weaker carcinogen than EDB, is present in much larger amounts...
...In contrast EDB use was never "restricted" in grain and fruit fumigation...
...Finally, on February 3 of this year, EPA Administrator William D. Ruckelshaus made the scare official: He ordered an immediate ban on EDB's use in fumigating stored grain and milling machinery, set temporary tolerance levels of EDB for food already in the pipeline (e.g., 30 parts per billion in bread, 150 ppb in flour and cake mixes), and then in early March announced that the only remaining agricultural use of EDB--the fumigation of fruit to kill fruit flies--would be permanently banned starting this fall...
...Ruckelshaus's ban...
...when it came my turn he ignored my professional affiliations and academic credentials (which I had carefully communicated to his producer) and introduced me as "an industry consultant...
...Ruckelshaus's February 3 decision...
...Clearly, aflatoxin at 20 ppb poses a much greater carcinogenic risk than EDB does at 30 ppb, and were an analogous risk equation applied to aflatoxin, the number generated would not be three but some hundreds of excess cancer cases per 1000 exposed people--a figure that would swamp all other known causes of cancer, including smoking...
...Environmental advocates enjoyed ready access to the print and broadcast media, and used it to distort the hazards of EDB and advocate a ban...
...Phosphine, on the other hand, is highly flammable, not a comforting thought to anyone using it in the presence of grain dust, which is highly explosive...
...Ruckelshaus's decision to order a nationwide ban of EDB...
...if he were a mayor somewhere in Iowa, I imagine we would see him running about in suspenders, promoting the local 4-H fair...
...The sample of corn muffin mix found in California containing EDB at 5400 ppb was flashed across the nation, but not news of the extreme rarity of products with such levels...
...EDB has been found to be highly carcinogenic in ten long-term, highdose tests on rats and mice of both sexes, and involving exposure by either inhalation or stomach tube...
...If uncontrolled, their growth would be explosive...
...Methyl bromide and phosphine, in contrast, are much more volatile (i.e., gaseous) and thus dissipate before the bugs are killed...
...Ruckelshaus's 2Aflatoxin, a naturally occurring mold contaminant in many nut- and grain-based foods (such as peanut butter), is 1000 times more potent as a carcinogen than EDB...
...As for the third alternative, the major component of that mixture, carbon tetrachloride, is a proven carcinogen and is already under review at the EPA with a ban on its use possible in the near future...
...Both phosphine and methyl bromide are more poisonous than EDB: In fact, all uses of phosphine are classified as "restricted" by the EPA (i.e., only certified applicators may work with it) as are most uses of methyl bromide...
...This would have provided adequate public protection while causing minimal disruption in existing patterns of food production and distribution...
...We have just gone through another cancer scare, this time over the grain fumigant, ethylene dibromide, or EDB...
...Moreover, there is evidence that these alternatives substantially increase the toxic risk to workers who apply them...
...Grain storage is a necessity not only between harvests but also in case of drought (as in 1983...
...In other words, you would have to consume about 400 tons of food daily to receive the doses of EDB the rats got...
...In fact, no excess cancer has been seen among these workers, though over~ half should have died of cancer were the EPA's estimate valid...
...Ruckelshaus's announcement in February, cancer test results on methyl bromide were not yet available, but they were reported later that month...
...Ruckelshaus's temporary standards...
...Some "industry consultant...
...It should have been candid in revealing that EDB's replacements are potentially more hazardous to the public and workers, and that we lack crucial data on the carcinogenicity of certain of these chemicals...
...Treatment of milling machinery against insects is also necessary to prevent the eggs, which are as fine as flour and pass right through the milling process, from getting into products and germinating on supermarket and kitchen shelves...
...What is disputed is whether consumers face any significant risk from the incredibly tiny levels of EDB typically present in foods...
...Tom Vacar of San Francisco's KGO-TV and the Wall Street Journal gave solid coverage to the cancer and workplace hazards of 3Sad to relate, I am not now, nor have I ever been, in the pay of either a food or chemical firm...
...The scare goes back to 1975 when EDB was first discovered to be a potent carcinogen in rats and mice, leading the Environmental Defense Fund to petition the Environmental Protection Agency to take action...
...More extensive sampling, however, involving thousands of foods tested across the country, has shown this estimate to be too large by at least a factor of ten...
...Only three other effective substances are currently registered for use on grain, namely: methyl bromide, phosphine, and a 4:1 mixture of carbon tetrachloride and carbon disulfide...
...By chewing through the coat protecting the seed, they bring spores directly into contact with the nutritive part of the grain...
...Taken together, these considerations show that the 3 per 1000 risk estimate should be reduced by at least 100-fold--one factor of ten because EDB's estimated potency in humans is incompatible with the data we have on workers, and another factor of ten because, as the EPA now quietly concedes, consumer intake is at least ten times less than the ten micrograms per person per day previously believed...
...Politics in Regulatory Washington," The American Spectator, June 1983...
...But it did none of these, and so we've gone through yet another episode in which poor science has motivated a hasty and misguided regulatory decision...
...No editorials questioned the 3 per 1000 excess-cases-ofcancer figure, despite the fact that PD4, a publicly available document, states in non-technical English that this estimate was based on only 22 biscuit samples...
...Horror stories of painful deaths from EDB in industrial accidents were publicized, but not how seldom these occurred, nor how much more often they occur with EDB's replacements...
...But at least it is flame retardant (as is EDB...
...These substitutes can only be effective, according to the EPA and other sources, if the whole mill is closed off and fumigated, a process that not only is less efficient, but also substantially increases the risk of worker exposure...
...Undoubtedly, you're reading it here for the first time...
...The very next day, however, Times readers might have thought they were seeing the same picture--until a glance at the caption explained that here was Koch (sans the fisherman sweater) marching in the Purim parade, commemorating the saving of the Jews from annihilation by Haman in the Persian-Medean Empire...
...The few products found to contain inordinate levels of EDB were clearly anomalous, the result of accidents or negligence rather than int r a c t a b l e technical difficulties...
...and people would only have spit at him...
...Still, the political graves are full of competent men who never achieved popularity...
...Although Efron absolves the media of ultimate responsibility in concocting the cancer scare syndrome--she gives that honor to the American science establishment--the national media did play a major role in heightening the EDB scare and in forcing Mr...
...According to EPA estimates given in its "Position Document No...
...In addition, a skin painting test has been conducted on mice with positive results...
...3. Do we have safe alternatives to EDB...
...Perhaps the best explanation lies in the early pages of his first chapter...
...Ruckelshaus have made a better decision...
...The verdict: Methyl bromide is a strong carcinogen, fully as potent as EDB...
...Unlike Nelson Rockefeller, who would consider himself above such exuberance, 3 Ed Koch is an unabashed cheerleader...
...4" (hereafter PD4), the average person ingests about ten micrograms of EDB a day (by comparison, the average person ingests 140,000 micrograms of pepper a day...
...THE AMERICAN SPECTATOR JUNE 1984 31...
...Koch is that rare man who has both...
...Yes...
...Moreover, they are ideal carriers of bacterial and mold contamination (including the mold that produces aflatoxin...
...It is allowed in foods at levels up to 20 ppb...
...What the bugs don't eat themselves can therefore be rendered unfit for consumption by humans...
...When Edward I. Koch was sworn in on January 1, 1978, New York City was $1 billion in the red...
...Ruckelshaus was not operating in a calm and rational world...
...Ruckelshaus to set sensible limits on EDB levels permissible in consumer products...
...Charlayne Hunter-Gault of "The MacNeil-Lehrer Report" was a model of impartiality...
...Clearly, as Koch now says frequently, he must be doing something right...
...Beame could have camped out at the Brooklyn Bridge 'Compare Koch against the old legend about Bobby Kennedy who, while campaigning in an Italian neighborhood, allegedly horrified aides by asking for a knife and fork when he was given a slice of pizza to bite into...
...On "Nightline" Ted Koppel introduced EDB critic Samuel Epstein as " P r o f e s s o r o f Environmental Medicine at the University of Illinois...
...Because of its mixture of gaseousness and toxicity, only EDB is conducive to "spot" (i.e., local) fumigation of milling machinery wherein a few gallons are injected through special ports directly into the machinery, with toxic concentrations reaching the insects before the gas dissipates...
...When "debates" were staged, there was the media's anti-industry bias to contend with...
...The minor component, carbon disulfide, is currently being tested by the National Toxicology Program, with results not expected before two years...
...Even if such a test were to begin today, it would take three years before we could state with confidence that phosphine is not a carcinogen...
...What has not been so well publicized is that the equation relating animal and human risks used to derive this figure was only recently cooked up by the EPA's own Carcinogen Assessment Group, and has yet to be subjected to outside peer review...
...3 A "debate" on WOR, a New York City radio station, turned out to be a lengthy interview with representatives of the EPA and the National Resources Defense Council, with only a single question to me on the hazards of EDB...
...I f you know how to use a heckler," writes the Mayor, "he can be very good for you...
...After my brief reply the NRDC representative responded by insinuating that I must be in the pay of the Grocery Manufacturers Association, since I sounded just like them, whereupon the moderator closed the debate...
...Moreover, their activity leads to the release of moisture stored within the kernel, raising the atmospheric humidity in grain bins and thereby furthering m01d growth...
...With the discovery last year that EDB was contaminating ground water in Florida (from use as a soil fumigant), the issue became hotter, causing Florida agricultural commissioner Doyle Conner to suspend the sale of all food products containing EDB...
...The six-week media life of this flap saw plenty of drama and sensation, but little if any effort to ask the tough questions...
...In its public statements, the agency should have pointed out the weaknesses of its risk estimation procedures and hence of its risk estimate...
...This amount is more than 250,000 times smaller, on a bodyweight basis, than the cancercausing doses given to test animals...
...None uncovered the fact that this risk figure was refuted by published studies on workers...
...1. What degree o f hazard did EDB pose to the public...
...There were some notable exceptions...
...Relatively simple measures such as monitoring EDB levels, aerating grain, and blending high-EDB grain with Iow-EDB grain would have sufficed to eliminate these few instances of excessive contamination...
...He was operating in the apocalyptic world described by Edith Efron in these pages last March and in her brilliant new book, The Apocalyptics...
...2 Finally, PIM reveals that THE AMERICAN SPECTATOR JUNE 1984 29 the EPA increased its estimate of the typical daily intake of EDB by some 400-fold between 1980 and 1983...
...Specifically, some 99 percent of all food products currently on supermarket shelves already complied with Mr...
...Methyl bromide is particularly insidious: Under normal working concentrations it is odorless and thus can cause lasting central nervous system damage before it is detected...
...I participated in four such debates, and with one exception the moderator always lowered his guard...
...Ruckelshaus's decision was made to release this information...
...Indeed, his temporary levels are quite sensible, and could well have been made permanent...
...EDB has a further advantage...
...Koch is the people's mayor, because he is smart enough not to tell them things are getting better when all their five senses tell them things are getting worse...
...The wackos have yet to figure this out...
...A striking outcome of the extensive food sampling done in the wake of Florida's ban has been the revelation that products with high levels of EDB are very rare, even in the absence of any conscious effort by industry to reduce these levels (no tolerance levels for EDB in food had ever been set prior to Mr...
...Yes...
...levels in the diet could lead to an increase in lifetime cancer risk of 3 per 1000 people...
...EDB replacements, and also attempted to put EDB risks into perspective...
...30 THE AMERICAN SPECTATOR JUNE 1984 emergency ban on EDB has yet been given a clean bill of health in the same sort of rigorous animal tests that revealed EDB's potency as a carcinogen...
...It should have promptly informed the public that the amount of EDB being found in the nation's diet was at least ten times smaller than previously believed, rather than waiting until after Mr...
...And if the occasion warrants, he steals his critics' thunder by admitting he was wrong...
...Are any of these carcinogenic...
...At the time of Mr...
...Still, it is with the EPA that ultimate responsibility must lie...
...Control of these insects by one method or another is thus essential...
...In short, none of the available alternatives which we are now obliged to use as a result of Mr...
...regulatory decisions.' Four questions might be raised to determine whether it is similarly apt in describing Mr...
...None has yet publicized the fact that the EPA has now lowered this figure by more than tenfold...
...Rather than ban all grain-related uses of EDB, then, it would have been enough for Mr...
...Also, the assumptions underlying this estimate would lead to grossly unrealistic predictions of risk for other dietary carcinogenic hazards, such as aflatoxin...
...No one disputes that EDB is reliably carcinogenic under these conditions, nor that, as pesticides go, it is among the more potently carcinogenic...
...When he senses he has an implacable enemy, he baits him, hoping at least that way to gain some mileage from it...
...Another source of confusion has been the EPA's estimate in PD4 that lifetime exposure to EDB at typical ~See my article "Science vs...
...4. Could Mr...
...The sole basis for this re-evaluation is an analysis of biscuits made from 22 flour samples that were supposedly "geographically representative of cities throughout the continental U.S...
...Yet symbols without substance are doomed to backfire...
...Grain beetles are voracious and multiply incredibly fast (hatchling to sexually mature adult in four weeks...
...2. Do we need the service performed by EBB...
...But of course we know that Mr...
Vol. 17 • June 1984 • No. 6