From a Correspondence with the Environmental Protection Agency regarding “Our Systematic Exposure to Tens of Thousands of Environmental Chemicals" by Jean-Marie Kauth

“…Mr. Borges-Silva, thank you so much for your personal response.

“One of the biggest mistakes the EPA has made is relying on single-substance animal tests, often performed by the pesticide companies, to assess toxicity.  Rats and mice are not perfect human models and do not have the longer latency period of humans.  These single-substance tests also do not factor in synergistic effects with other chemicals to which we are all exposed (CDC); this is the most likely reason that the best epidemiological studies show very different results compared to animal studies.  And all this explains why the President’s Cancer Panel (PCP) Report of 2010 and the American Academy of Pediatrics (AAP) in 2013 assign much of the blame for rising cancer rates in children to virtually unregulated pesticide exposures.

“Organophosphates, the class to which chlorpyrifos belongs, have long been implicated in epidemiological studies of childhood leukemia (Zahm and Ward 1998; Meinert et al. 2000; Infante-Rivard and Weichenthal 2007); now in addition to teasing out this particular class of chemicals, studies are starting to use direct measures, like metabolite levels in urine and biomarkers of toxicity, to assign blame to particular substances (Soldin et al. 2009; Amaroli et al. 2013).  

“One recent study points out that the finding that insecticides like organophosphates, organochlorines, and pyrethroids are particularly linked to brain cancer is ‘interesting’ because these class of insecticides ‘readily cross the blood-brain barrier and target the nervous system, whereas pesticides aimed at plants and fungi inherently rely on different mechanisms of action’ (Nielson et al. 2010).  

“New research argues that chlorpyrifos may be responsible for increased levels of cancer, not because it damages DNA directly, but because it depresses immune and neurochemical activity (Perry and Soreq 2004; Amaroli et al. 2013) or causes oxidative stress, endocrine disruption, and cholinesterase inhibition (Rull et al. 2009).

“Our eight-year-old daughter Katherine died in 2002 of leukemia we have every reason to believe was caused by her unwitting exposure to chlorpyrifos, so we have followed the evidence carefully for years.  We thought she was protected when chlorpyrifos was banned for residential use in 2001, but there was a loophole for mosquito spraying, which we did not realize had occurred from her infancy onwards.  We know your hands are tied by the weakness of TSCA.  The Safe Chemicals Act, sponsored by Frank Lautenberg, would be a step in the right direction; but in the meantime, you at the EPA are all that protects our children, and you have largely failed to do so, not just by our accounting, but according to the PCP and AAP.  Having an Environmental Protection Agency gives people the illusion that they are protected from environmental exposures, when nothing could be further from the truth.  Registration implies to most people that the chemicals in question have been thoroughly researched and have negligible human health risks.  That is simply not the case.

“Could you please pass this on as a request for re-registration of chlorpyrifos and other organophosphate chemicals in light of more recent and epidemiological evidence?”

Thank you–

Jean-Marie Kauth, PhD

Craig W. Colling, PhD

References

American Academy of Pediatrics (AAP).  2012.  Policy statement: Pesticide exposure in children.  Pediatrics 130(6):e1757-e1763.

Amaroli A, Aluigi MG, Falugi C, Chessa MG.  2013.  Effects of the neurotoxic thionophosphate pesticide chlorpyrifos on differentiating alternative models.   Chemosphere 90:2115-2122.

Centers for Disease Control and Prevention (CDC). Fourth National Report on Human Exposure to Environmental Chemicals. Atlanta (GA). 2005.

Infante-Rivard C, Weichenthal S.  2007.  Pesticides and childhood cancer: An update of Zahm and Ward’s 1998 review.  J Toxicol Environ Health, Part B 10:81-99.

Meinert R, Schüz J, Kaletsch U, Kaatsch P, Michaelis J.  2000.  Leukemia and Non-Hodgkin’s Lymphoma in childhood and exposure to pesticides: Results of a register-based case-control study in Germany.  Epidemiology 151(7):639-646.

Nielson SS, McKean-Cowdin R, Farin FM, Holly EA, Preston-Martin S, Mueller BA.  2010.  Childhood brain tumors, residential insecticide exposure, and pesticide metabolism genes.  Environ Health Perspect 118(1):144-149.

Perry C, Soreq H.  2004.  Organophosphate risk of leukemogenesis.  Leukemia Research 28: 905-906.

President’s Cancer Panel (PCP).  2010.  Reducing Environmental Cancer Risk: What We Can Do Now.  U.S. Department of Health and Human Services.

Rull RP, Gunier R, Von Behren J, Hertz A, Crouse V, Buffler PA, Reynolds P.  2009.  Residential proximity to agricultural pesticide applications and childhood acute lymphoblastic leukemia.  Environmental Research 109:891-899.

Soldin OP, Nsouly-Maktabi H, Genkinger JM, Loffredo CA, Ortega-Garcia JA, Colantino D, Barr DB, Luban NL, Shad AT, Nelson D.  2009.  Pediatric acute lymphoblastic leukemia and exposure to pesticides.  Ther Drug Monit 31(4):495-501.

Zahm SH, Ward S.  1998.  Pesticides and childhood cancer.  Environ Health Perspect Suppl 106:893.

This is a serious and important correspondence between Jean-Marie Kauth and the Environmental Protection Agency. Please read the complete exchange at http://poisoningourchildren.wordpress.com/2014/02/10/corresponding-with-the-epa/