You mention that EWG used STORET data. I was one of the first industry people
who requested and was granted access to this data base in the late 70's. I
believe anyone can get such access. The first thing I learned was that this data
base is full of questionable data. There is no QA/QC review at all. Second, I
found numerous entries that were duplicates. As you might guess, I was looking
for data on alachlor and found that about half the data in the database had
somehow been entered twice under different codes. I therefor question the use of
STORET data without some sort of check for validity.
Next, I have been contacted by several of the cities cited by the EWG report as
having "unsafe" water. I was contacted because when these cities contacted EWG
for the source of their data, they had in these cases said the data came from
Monsanto. When I researched back this data, I found that watershed studies we
had done in 1985 were used. These same cities indicated to me that they had been
monitoring these compounds, as required under the Safe Drinking Water Act, for a
number of years, using at least quarterly samples. Their results indicated MUCH
LOWER LEVELS, if any than were cited by EWG. It thus became obvious to me that
EWG had not used the most recent data collected by these cities. Thus, EWG
assumed, incorrectly in these cities' cases, that what existed 9 years ago,
exists today. This is nonsense! Rates of all these five products have been
reduced greatly, market shares have decreased, awareness of runoff problems and
how to correct them have increased at the farm level. Again, EWG has overstated
the current risks.
In Springfield, Illinois, the EWG admitted, after they had publicly announced
that the water was "unsafe" that they were wrong. Indeed, they found that they
had not used the most recent data available. I give them credit for admitting
this mistake but it calls into question the validity of the claims they made in
other cities. Mistakes will be made, and I have made my share, but when you
decide to go out and inform people that their water is unsafe, you had better
have your facts straight and not overstate the case.
EWG, like a number of other anti-pesticide groups have had a history of
overstating the case, in this case risk, and I think TAP WATER BLUES is yet
another case. Yes, this is my opinion, but I believe it is others as well.
Finally, the report does show that there is a problem. We in industry can agrue
forever whether 1 part per whatever is safe or not. The fact is people do not
want residues of ANYTHING in their water. No one intentionally in agriculture
that I know of wants any of the five subject herbicides to get into drinking
water. The reason these five are found most often, I believe, is because they
are the five most widely used preemergent products. This fact helps explain why
they are found, that is the farm practice. The issue is not what product is
used, but rather how, where, and when.
I have been promoting buffer zones/strips along water ways that both reduce
erosion and the velocity of water runoff. There is at least some data showing
that using these practices reduces chemical runoff- not all, but some. I am also
promoting the global positioning system that can help over time assure that
right amount of chemical is applied only where it is needed. Many are also
working on better application equipment to assure that what is needed is applied
correctly.
There are other examples; the point is rather than say the problem is the
chemical, I say it is the practice of where, when and how the chemical is
applied. The vast majority of the agricultural land in this country can have
chemicals applied and they will NOT end up in either surface or groundwater.
TAP WATER BLUES overstates the risks and has needlessly scared people, and in
one case may cause a water treatment operator his job because incorrect data was
used. This is uncalled for and could have been avoided if EWG had done a better
job, something that must be required when failure to do so scares people about
the safety of the very water they drink.
Sorry Chuck but I don't think EWG was careful at all!
Rather than just calling for a ban on these products, let's look at how they got
into water and change to practices that reduce that likelihood. Will newer
products be better- yes. But if we spray these newer products right next to a
river of stream, they too will end up in drinking water. Let's promote practices
that minimize runoff. That should be part of any sustainable agriculture of the
future. And for those that say simply stop using synthetic chemicals and go
organic- is a little bit of runoff of an organic OK- I think not!
I hope others will join this discussion and rather than attack me for who I work
for, work with me to address the real problems with runoff and the safety of
drinking water. I really want your thoughts and suggestions.
p.s.- and I will try and keep my flame baiting in check!
Thomas J. Hoogheem
Field Environmental Operations Director
The Agricultural Group, Monsanto Company
tjhoog@ccmail.monsanto.com
To SANET and T.J. Hoog:
Re: Tap Water Blues, Opinion, and Facts
I have read David Baker's comments on the EWG report in
several publications. The PR people did their job. David Baker
has done excellent work over many years in monitoring water
quality. He is not a toxicologist nor a politician, and hence his
opinions on the size and severity of cancer risk from herbicides,
and their acceptability to society are just that, his opinions,
just as mine are or anyone else's.
The issues Hoog and others have raised in criticizing "Tap
Water Blues" are important and deserve more discussion. As I said
in my earlier post, the major contribution the report makes is a
much more sophisticated and data-rich analysis of actual herbicide
residue exposure levels in finished drinking water through the
midwest. They had to develop a new methodology to sort through
and synthesize the EPA's huge STORET database (which includes much
of Baker's Heidelberg College data), producing community/city
specific estimates of herbicide levels in water during specific
periods of the year. They then used a method pioneered by Goolsby
of the USGS to calculate seasonally adjusted annual exposure
estimates, capturing peaks in the spring and early summer months,
but not over-estimating exposure in the fall and winter, when
levels in surface water tend to be much lower. I have yet to see
any criticism of their methodology, or estimates; some have
questioned why they singled out certain towns/cities. Apparently
they reported only on those communities/cities they had enough
data for to produce statistically reliable estimates.
Critics argue that the risk estimates are wrong, and that EWG
chose the wrong risk standard to use as a benchmark. The report's
risk estimates use EPA methods and data, nothing more and nothing
less. For each of the 5 herbicides, the applicable Q star (the
so- called cancer potency factor) was multiplied by estimated
exposure levels, by various populations cohorts. Those who
criticize this part of the report are really criticizing cancer
risk assessment methods in general, since EPA's methods are pretty
much in the conservative mainstream of the toxicological community
and other regulatory agencies. I agree with Hoog and Baker and
industry that risk assessment remains an imperfect science, and
that more research is warranted. I differ with them, I suspect on
how much weight should be placed on findings that risk exceeds a
certain level, and on the importance of re-assessing exposure and
risk levels faced by infants and children. Industry believes in
and vigorously defends risk assessment when it appears to
exonerate a chemical, but not when the same methods and new data
implicate a profitable product that poses risks over generally
accepted standards of "acceptable" risks.
Last, the EWG's use of one-in-one million risk as the
"standard" against which risk was measured. Here the EWG made a
value judgement, just as Hoog, Baker, and others in industry do in
arguing this is too stringent a standard. The one-in-one million
standard for cancer risk is embodied in dozens of regulations and
laws, at both the state and federal level. It is the level of
risk deemed acceptable under exemptions to the Delaney Clause. It
is the level of risk embodied in most proposed food safety reform
bills. It is the level EPA considers acceptable in food. In
assessing a pesticide's dietary cancer risk, EPA considers and
treats drinking water as a food, and counts any exposure from
residues in water as part of total dietary exposure and risk. For
these reasons EWG chose one-in-one million as the standard.
Others believe a less rigorous standard is justified; debate goes
on regarding acceptable risks, and will undoubtedly re-surface in
the 104th Congress.
I am trying to get a copy of Baker's critique of the report
so I can understand more fully where he is coming from. Many of
the quotes attributed to him about the number of cancer cases, and
percent of cases caused by herbicides are nonsense, and reflect
inappropriate and unscientific uses/interpretations of risk
assessment -- mistakes, by the way that the EWG was careful not to
make or assert. People in the ag community do not want to hear or
believe this, I know, and think that anything an environmental
group does must be wrong. Sometimes environmentalists/industry
types/aggies are right and basically stick to the facts, sometimes
they are not, and do not. People can and will argue with risk
assessment as a statistical tool, and over what the level of
acceptable risk is or ought to be, but let's not use these debates
to undermine or confuse otherwise solid contributions.
I will also try to find out if EWG has responded to Baker's
critique, and will try to keep people informed of the debate,
which may yet generate some light on an important subject/set of
policy issues that will not go away until farmers switch to less
chemical intensive weed control methods, new water filtration
techniques are developed, or it stops raining in the midwest.