Mr. Hoogheem from Monsanto responded to my last post
directly, but said I could post his response -- which appears
below.
I like his challenge to find something we can agree on and
work toward, and assuring the 1995 farm bill preserves the CRP and
ways to support farmers willing to put in grassed waterways and
filter strips is a good candidate. I wonder what the ag-chem industry
would be willing to do politically to lend its support to this
goal, and solid appropriations.
On the issue of acceptable risks, Hoogheem says he finds
one-in-one million excessively conservative, or over-protective.
In terms of regulatory consequence, he would resist EPA or a state
taking action against a Monsanto product posing such a level of
risk. What about one in ten thousand? If you had data, collected
by you or others showing some substantial population exposed at a
level of one in ten thousand, would the company start to take
steps to reduce exposure? Does Monsanto have a corporate policy
as part of your product stewardship program re acceptable risks?
More later.
>From TJHOOG@ccmail.monsanto.com Fri Nov 18 06:01:02 1994 To:
Charles Benbrook <cbenbrook@igc.apc.org> Subject: Re: Response to
Hoogheem re TWB Status: RO
Again, thanks for keeping this discussion going. Maybe we can even
find some actions that both sides can agree to..now that would be
a novel concept!
I have contacted Dr. Dave Baker at Heidelberg, who has now had a
chance to review the EWG report from front to back. He has
completed a 46 page critique that rakes a very different view than
yours on this report. I think Dave is in a position to comment on
this report since he generated about 1/3 of the data and is well
recognized for his expertise on pesticides in water. He had sent
out a his review to over 100 organizations including SCIENCE
magazine. I hope they publish it, as 46 pages is a little large
for SANET. I will be glad to send you a copy if you wish.
Now, to your response,
You ask what I believe is a "safe" level of a compound in water.
First, I wish there were no pesticides in water, and I having been
working towards that goal for sometime, as have others in industry
to reduce what does get to water. It is up to others to determine
success rate. Second, because conditions and practices have
resulted in compounds getting to water, we, as scientists must
have a level we can consider "safe". This has been done over the
years by determining an "acceptable risk", looking at the hazard
factor, or toxicity and calculating an allowable exposure. Again,
this does not mean I feel it is "OK" to let water become
contaminated to this allowable level, rather, when accidents and
practices do occur that contaminate water, what is the allowable
exposure.
For compounds that have caused tumors in laboratory animals and
are thus considered possible human carcinogens, that risk has been
set at 1 in a million. I personally think that the uncertainty of
extrapolating HUGE DOSE levels in rats and mice to humans is a
very large leap, but that is another debate!
Some have said even this level is not conservative enough because
we are exposed to many chemicals. My opinion is that the question
of synergism has been shown again only at very high dose levels
and even then rarely. It is overblown.
On the exposure end, we assume that a human drinks 2 liters of
water a day for 70 years. We then calculate a level in that
drinking water that will supposedly increase his/her cancer risk
by 1 in a million.
Put another way, there are solid data showing that the current
risk of getting cancer in the U.S. is around 1 in 4. I have heard
that it could be 1 in 3. Assuming 1 in 4 means that in a million
people, 250, 000 will die of cancer. If you assume you drink your
two liters a day for 70 years at the level that increases risk by
1 in a million, that increase would mean the overall rate would
increase to 250,001.
Yes, Chuck, I do believe, regulating compounds at a 1 in a million
level is excessive. No one has drank any of these compounds at
even this level of risk for 70 years.
In conclusion, I think the risks from pesticides in drinking
water, based on current levels, are over estimated and overblown.
What levels are present are decreasing due to newer chemistries
and BETTER FARM PRACTICES. Again, I wish there were no levels in
water and we should work toward that goal.
You are right on the issue of resistance to buffer strips. Many
farmers do not like being told how to farm and what they can or
can not do on their property. At the same time MANY have been
using the concept of filter strips for years. My personal view is
that to increase the use of this practice, we must find economic
incentives. For instance, I know many are calling for the
elimination of the conservation reserve program. HOWEVER, WHAT
BETTER LAND IS THERE TO HAVE IN SUCH A PROGRAM THAN THE HIGHLY
ERODIBLE LAND ALONG WATERWAYS! My point is that if there are to be
payments to farmers not to plant certain land in the future, make
it the areas along waterways.
You ask many more questions that I will try to answer, but I am
out of time and will write more later. If you wish to put this out
on the network, feel free to do so.
Thomas. J. Hoogheem tjhoog@ccmail.monsanto.com