An Unethical Report on Pesticide Studies

By Michael Fumento
December 7, 1998


It's the Tuskeegee syphilis experiment all over again! No, worse yet, it's Dr. Josef Mengele (a.k.a. the Nazis' "Angel of Death") risen from the grave!

Or so you might think from a report released recently from the Environmental Working Group (EWG) at a joint press conference with the Natural Resources Defense Council, a report that has led to two days of EPA hearings to be held this week outside of Washington, D.C.

The report concerned testing pesticides in extremely low doses on human volunteers. The environmentalists are demanding an immediate moratorium on such tests, insisting that the EPA stop accepting them, and demanding that chemical companies stick to tests using Mickey Mouse and Rizzo the Rat.

If you don't understand the science very well, you might think their concern was humanitarian. But if you do, you understand it has nothing to do with humanitarianism and everything to do with simply placing more restrictions on pesticides usage.

Environmentalists know that animal testing is highly inexact and that's just the way they like it. The inexactness provides a regulatory rationale for building in all sorts of conservative "safety factors" in extrapolating from animals to humans. These conservative factors then hamstring farmers in attempting to apply their pesticides.

Because rodent physiology is so different from that of humans, regulations require that after first finding out how much pesticide it takes to cause symptoms in animals, a dose slightly below that must be divided by ten to allow for the possibility that humans are more sensitive to the chemical than the test animals. Then it's divided by ten again to allow for the most sensitive of humans you know, like Phil Donahue or Alan Alda. So already, the regulations allow humans to receive less than one one-hundredth what caused problems in the rodents.

Of course, the more you divide, the less pesticide farmers can use to protect their crops. Since pesticides are generally quite expensive, the farmer needs no incentive to use just as little as possible. But he also needs to use enough to do the job.

The environmentalists don't want that though, which is why like an amoeba in heat, they found an excuse to cry: "Let's divide again!" The excuse was that children in some cases are more susceptible to chemicals than adults and sometimes eat more of a given fruit or vegetables. Congress bought this reasoning, and two years ago authorized the EPA to in cases it deems proper employ yet another 10-fold "safety factor" to protect children.

That now allows dividing by a factor of 1,000. It is so onerous that when applied it will probably force farmers to replace many useful pesticides with inferior ones that are more costly and less effective.

Yet children are already covered under the second 10-fold factor as "more sensitive" humans--even though actually they're LESS susceptible to some pesticides. They also receive some coverage under the first 10-fold factor, because often animal testing is done on infant or fetal rodents.

The environmentalists know this, as does the EPA. So do the pesticide companies, which is what makes greater use of human testing more attractive. It could prove how greatly exaggerated is the need for that first division by ten, the one that allows for possible greater sensitivity of humans to chemicals than rodents. Scientifically, it makes perfect sense.

Therefore, the environmentalists attack such testing on humanitarian grounds. The EWG labeled it "ethically indefensible."

Really? When questioned at the press conference, the EWG admitted there was no evidence of unethical treatment. The testing was unquestionably legal under British and U.S. laws. A spokesman for the British government told a reporter the tests "seemed to be along the right lines ethically." Finally, a medical ethics committee always reviews test protocols, which themselves are reviewed every few years at international committees.

To listen to the EWG, England and Scotland were chosen because its citizens are readily exploitable like those poor Indians who sell their kidneys. Last I checked, the United Kingdom did not qualify as an impoverished Third World country though I haven't checked lately.

Further, there's no evidence that anyone who took part in these experiments suffered any symptoms not caused by anxiety. They include muscle weakness, lightheadedness, and headaches. Other than a sudden acne outbreak, these are the same symptoms you'd expect in a teenager going on a first date. The EPA's own evaluation of a study involving an insecticide called dichlorvos reported that some subjects reported such minor ailments as headaches and drowsiness but "did not attribute these symptoms to dichlorvos administration." In other words, it was nerves.

This only makes sense, because of the tiny doses involved. They weren't supposed to induce the least outward symptom, but rather to see at what point it affected a certain enzyme in the blood.

It's not ethical concerns that bother the environmentalists; it's the mere existence of man-made pesticides.

It hardly matters that in a nation where less than a tenth of the population eats as many fruits and vegetables as is recommended, they're working to make fresh produce even less desirable by forcing us to eat expensive, ugly-looking "organic" produce. Doesn't that seem a bit, well, unethical?

Yet such nonsense can have considerable power to intimidate. The very day the environmentalists held their press conference, the EPA proclaimed itself "deeply concerned that some pesticide manufacturers seem to be engaging in health-effects studies on human subjects as a way to avoid more protective results from animal tests."

Like Louis in "Casablanca," they were "Shocked, shocked!"

But why weren't they "deeply concerned" the day BEFORE the press conference? Why are tests on rats and mice somehow more protective for humans than human testing." And why didn't the EPA note that in the early 1990s the EPA conducted its own human pesticide trial with the insecticide malathion?

Why? Because quite simply the widespread suspicion that the EPA takes its marching orders from environmental groups is essentially correct.

Michael Fumento is a senior fellow at the Hudson Institute in Washington, D.C. who writes frequently on health and science issues.

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