First, Mr. Hoogheem, sorry for addressing you as Mr. Hoog;
e-mail addresses, like book covers, sometimes do not tell the
whole story. I was not trying to be disrespectful.
In your 11/16 response you say that you attack the EWG report
because it overstates the size and severity of the risk posed by
herbicide residues in drinking water. Please help us understand
what you mean. Are you saying that the risk estimates in the EWG
are empirically wrong? In the body of your message, you note the
availability of more recent exposure data, which shows that
residue levels may be going down. So, is your criticism largely
on the exposure side, or the risk extrapolation side?
The EWG "finding" that risks are excessive is based on their
judgement, or assertion that risks exceeding one-in-one million
are excessive as population risks. I suspect that your conclusion
that the EWG "overstates the severity of risk" relates to their
reliance on this standard. Am I correct?
Now a question for you which I and others would sincerely
welcome a response to. The EWG has gone out on a bit of a limb in
the environmental community by accepting population cancer risks
below one-in-one million as not sufficiently worrisome to warrant
any regulatory actions. Most environmental groups, as you know,
steadfastly refuse to let go of the Delaney Clause zero-risk
standard. But EWG has. My question to you is the flip-side --
what level of risk would Monsanto consider too high to justify?
At what level of risk would you start to take actions voluntarily
to reduce exposure and risks to one of your chemicals? We can
infer from your actions and inactions on alachlor a little bit
about what those levels might be; but seriously, as a corporation,
do you have a bottom line?
In further response to your points about "Tap Water Blues"
exposure and risk estimates, and the Springfield estimates in
particularly, I called my friends at EWG and found out --
1. Every other analysis of these herbicides in surface water by
EPA, the water industry, and even David Baker have concluded that
contaminant levels are similar or higher than those reported by
EWG. Based on these analyses and in contrast to extensive USGS
data which is of the highest quality, EWG exposure estimates are
actually conservative.
2. The recent EPA triazine Special Review announcement reports
average risks in the range of 10-5 (one-in-one hundred thousand)
for people exposed to these pesticides in their drinking water.
These average results are in the same range as those reported in
TWB by EWG.
3. A recent American Water Works Association study reported
results that indicated far more people exposed to higher levels of
pesticides than reported in Tap Water Blues. This analysis
estimated that a total of 19 million people drink pesticide
contaminated water, and that over 10 million are exposed to
pesticides above EPA standards. EWG's standards in sorting data
in STORET were conservative, in that they did not want, under any
circumstance, to bias their results upward, because they knew they
would be under such intense scrutiny from industry. The database
available to the American Water Works Association is even more
extensive than what EWG had access to.
4. David Baker's published work indicates that EWG underestimated
the number of individuals exposed and the concentrations of
herbicides present in their water. In most cases where
comparisons of city level data can be made, EWG reports lower
concentrations of herbicides present than Baker reports.
5. Has the problem gotten appreciably better recently? I doubt
it. Reduced application rates have not helped much in terms of
what farmers have actually been applying. The USDA Objective
Yield survey of practices on the farm shows little change in acres
treated or application rates. Tap Water Blues analyzed
application rates of atrazine and found that 85% of farmers were
already applying atrazine at levels below the new rate reductions
before they went into effect. The problem with atrazine is
intrinsic with the pesticide -- it is just too soluble. If
farmers use it at low enough rates to eliminate risk to water it
will not work well enough anymore to hold market-share. In some
places atrazine use has fallen in watersheds dramatically, but
unfortunately in most cases it was replaced by cyanazine, which is
a much more potent carcinogen.
6. The Springfield question. Don't believe the headlines; and of
course, no one should loose their job over this report, or this
debate. (There is a certain irony in this coming from me). Here
is how EWG was "wrong". After two years of high contaminant
levels, Springfield finally started using Powdered Activated
Carbon in June of 1994 after tests of finished tap water revealed
atrazine concentrations as high as 14 ppb -- more than enough to
put them in violation of the MCL on a year round weighted basis.
Concentrations were reduced somewhat, but were still at
unexpectedly high levels for the time of the year when the next
sample was collected -- 0.82 ppb in September 1994, 4 months after
the last major application in the watershed. EWG did not include
the last sample in their average of exposure because it was not
available when they did the analysis. If they had, the exposure
estimate (based on an average of two years of data) would have
been reduced by less than 10 percent -- certainly not enough to
change any conclusions. Following some bad media work by the EWG
analyst, the headline comes out "Group Says Water Data Was Wrong".
FYI -- EWG's published results for contaminant concentrations in
Springfield water were in line with Baker's. The two analyses
report results within 10% of each other.
EWG took on a huge analytical task with a modest budget and
staff. They are as dedicated and professional as any group I
know, and take great pride in their analytical abilities. People
may not like their conclusions and their "in your face" approach
to public policy, but they rarely will loose an argument over math
and computer glitches. You folks in industry are not all, or
always exactly models of civility when it comes to the full
contact sport known as debate on pesticide policy in the U.S. of
A., I might add.
In any event, one of the positive results of TWB is that a
whole bunch of communities/towns/cities across the midwest are
going to do WEEKLY sampling next spring and summer of residue
levels in drinking water, in cooperation with a diversity of
grass-roots citizen groups. The database will grow rapidly.
Better information will move the policy debate to the next level,
although I doubt it will settle anything. The debate has not
changed in the 15 years I have been involved in it; its about who
gets to decide what risks others are asked to accept, often
unknowingly, and exactly who has a right to take chances with
other people's health. I sincerely hope Monsanto and the ag chem
industry, and the EPA are right in their contemporary, relaxed
view of the toxicological significance of pesticide exposure
patterns across the American population, for if they are not,
there will be hell to pay. I personally think the scientific
evidence, coupled with our risk-benefit pesticide law, supports
the need to take prudent steps to reduce exposures. Such steps
would have about as much dent on the American food supply -- its
cost, quality, and availability -- as a balanced budget amendment
will have on the deficit.
Hope we can continue this discussion. Looking forward to
your response to above questions.