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Mr. Wyant, Director Michigan Department of Agriculture,
Praxis brought two formal complaints to you about pesticide risk, misrepresentation of "pesticide safety" and also our pesticide alternative biological control products shortly after you became director many years ago.  To date we believe only some minor progress has been made at best, with an unnatural amount of effort and an unacceptable amount of difficulty; taking years rather than the days or months that it should have taken.  Truth and fact are the elements that are lacking, this is not a philosophical difference it is in reality the difference between fact and fiction.  We sincerely believe pesticide enforcement is sadly lacking and that the intent and possibly the letter of the law is not being followed.   The fact is things are going from bad to worse.
Samuel DeFazio, Praxis 2723 116th Ave. Allegan, MI 49010  616-673-2793
DISRUPTING LIFE'S MESSAGES                                                                  PRAXIS COMMENTS:

[In this series, we have been reviewing studies published during                    
the past two years in ENVIRONMENTAL HEALTH PERSPECTIVES,          It is not the job of MDA employees to sell or peer-reviewed journal published by the U.S. National Institutes                           to encourage pesticide use recommendations
of Health. Our purpose has been to discover whether mainstream                       or promote pest management strategies,
scientists believe that industrial chemicals, released into the                                  some employees remain unaware of that fact.
environment, can interfere with the hormones of wildlife and                                The disparagement of biological control by
humans, leading to widespread harm. It is abundantly clear that                            MDA is not acceptable.
they do. To keep abreast of the torrent of new studies of hormone
disruption appearing in dozens of journals, check in regularly at

Now the question becomes, "What does all this information about
hormone disruption mean?" One person eminently qualified to
comment on that question is Dr. J.P. Myers, a zoologist and
co-author (with Theo Colborn and Dianne Dumanoski) of OUR STOLEN
FUTURE, the book that pushed "hormone disruption" to the top of
the international environment-and-health agenda. The following
essay first appeared in the February, 2002, issue of OUR PLANET,
the journal of environmental sustainability published by the
United Nations Environment Program. See http://www.ourplanet.com.
We added the footnotes.]

Disrupting Life's Messages

by John Peterson Myers*

A revolution in scientific understanding of the impacts of
contamination on health is under way. As it unfolds, it is likely
dramatically to alter our understanding of the consequences of
pollutants for human well-being, and to require fundamental
changes in how chemicals are regulated. The revolution arises
from scientific discoveries which establish that many chemicals
both from the natural world and synthesized in laboratories
interfere with the natural chemical messaging systems that direct
the biological development of plants and animals, including

Virtually all biological development is under the control of                                404 error message in a biological transfer.
various chemical messaging systems that convey instructions from
the genes to their targets, thereby directing development.
Hormones, neurotransmitters and growth factors, among others, are
key elements of these message systems. Their successful
transmission of genetic instructions is vital to normal healthy
development, as they control almost if not every aspect of the
process from what sex a baby will become to how many fingers it
will have, to whether its brain is capable of intelligent
reasoning or whether its immune system will be able to resist

Science has now established that a wide array of chemicals can                 Among the group is many pesticides.
disrupt these genetically based messages without damaging the
genes themselves. Much attention has focused on disruption of
hormonal signaling, which has become known as endocrine

The roots of research in this arena go back to the 1930s, but it
has burgeoned in the last ten years because of very significant
investments of funds by European, Japanese and North American
governments. New results are published virtually every week.
These new findings are rich in detail, fascinating in what they
reveal about biological mechanisms, and sometimes breathtaking in
their implications.

For example, a study published in July 2001 by the United States
Centers for Disease Control reported a strong relationship
between DDT contamination in mothers and the likelihood of                         DDT/DDD and  its degradation congeners have a pre-term birth of their infants.[1] Using biological samples                              1/2 life of  thirty years.
stored since the 1960s, the authors report that their findings
indicate that the United States experienced an epidemic of
pre-term birth during the hey-day of DDT use, and that this
persistent pollutant may have caused up to 15 per cent of infant
mortality in America during that period.

Several important broad trends in the pattern of research
findings can be identified from the thousands of studies on
endocrine disruption published since the early 1990s.

First, the research confirms that contamination by hormonally
active compounds is globally ubiquitous. No one is unexposed,
even in the womb. The same is true for most, if not all living
organisms, especially those higher in ecological food chains and
thus consuming foods in which the contaminants have become
concentrated by bioaccumulation. Contamination is partly so                    This means that there are no populations untainted 
widespread because of the global redistribution of pollutants                     to act as controls in a "good science" review.
transported through air and water. The inadvertent but pervasive
inclusion of hormonally active compounds in consumer products
such as many cosmetics and plastics also contributes.

Empirical confirmation

Second, effects of exposure can be observed at levels                          The "Poison is in the dose" mantra of MDA's 3PM and
dramatically lower than those thought relevant to health a decade          MSU Toxicologists does not have a basis in fact. It is
ago. Scientists are measuring the endocrine-disruption impacts of          instead bad information from professional pesticide contaminants like arsenic, dioxin and bisphenol A (a basic                     apologists. We are talking low parts ... 1 p/per billion.
component of polycarbonate plastic) in the low parts-per-billion.
This was unmeasurable two decades ago (scientific instruments
simply were not that accurate) and highly controversial until
recent review and empirical confirmation.

Third, the findings indicate that virtually all chemical
messaging systems are vulnerable, in principle, to message
disruption. Work in this area focused for decades on interference
with estrogen. As the focus has expanded to other hormones, one
or more disrupting contaminants have been discovered for every
system studied carefully, including the thyroid system (crucial
for brain development), the retinoid system (involved in very
basic control of development), and the glucocorticoids (important
for metabolism and tumour suppression, among other things). In
the summer of 2001, new results reinforced this trend
dramatically, with a report that the ecological symbiosis between
leguminaceous plants like beans and the bacteria responsible for
nitrogen fixation is vulnerable to disruption by contaminants.[2]
This symbiosis, mediated by chemical communication between the
plant and the bacteria, is a vital component of the global
nitrogen cycle.

Fourth, the health effects of concern have expanded dramatically                    Immune compromised children is
beyond those of the traditional focus for toxicology. Laboratory                      not every parents dream, why is MDA
studies unequivocally demonstrate effects on disease resistance,                      resisting attempt to advance alternatives,
cognitive function and fertility resulting from low-level exposures.                     to pesticides, overtly and covertly.

These findings should be of deep concern to people, organizations                  This problem is also of deep concern to Praxis.
and agencies focused on human economic development and equity. It
is clear, for example, that background levels of contamination
can make children less resistant to infectious agents. Further
research in this area may force a radical reassessment of the
toll of contamination, as this implies that many deaths and
diseases would have been avoided had contaminants not reduced

Similarly, the research suggests that widespread exposure to                            Ridilin use is on the rise, Why?
neurologically active contaminants as might occur, for example,                        
in agricultural areas in with intensive pesticide use may lead to
community-wide erosion of cognitive abilities.
In a world in which
information is a key economic currency, this contamination burden
could consign those affected to the economic margins forever.

These emerging trends are forcing toxicologists toward several
conceptual shifts that will lead to fundamental changes in the
ways that chemicals are managed. The most important of these
involves a change in the way that toxicologists think about what                         Apparently not MDA's toxicologist
is relevant to human health.

Traditional toxicology focuses on damage, such as cell death,
mutations, cancer or genotoxicity. Message disruption can cause
these, but the effects may also be of a very different, but
equally important, nature. Most challenging to traditional
toxicology, message disruption does not work by overwhelming the
body's (or the cell's) defenses. It works by hijacking the
developmental process, adding to or subtracting from the body's
own control mechanisms at remarkably low levels of exposure. By
subtly (or blatantly) altering the path of development, message
disruption leads the victim to a different future. The difference                       
may be small, as in the loss of a few IQ points, or it may be                            Pesticide Registry
large, as in a completely dysfunctional immune system.                                    MCS Michigan resident are unfairly burdened
                                                                                                                     by MDA 3PM registration nightmare.  Its bad
Toxicology has focused traditionally on the impact of high levels                      please fix it, apparently the mission is to make it
of exposure on small numbers of people. This new approach                           as difficult as possible to identify chemically
requires considering widespread, low-level exposures experienced                  handicapped people living in Michigan.
by many people -- exposure levels that many had come to write-off
as "background" and, by implication, irrelevant.

Taken together, these new scientific findings add to growing
pressure to change the basic rules of chemical regulation. Once
again, we have been blind-sided. Our ability to synthesize
chemicals got far ahead of our scientific understanding of their

Traditional risk assessment allowed them to be commercialized and
distributed, causing pervasive contamination. Risk assessment's
partner in developing protective standards, epidemiology, by
definition works only after an epidemic. Even then, its tools are
remarkably insensitive in studies of the effects of endocrine
disruption, and strongly biased toward negative results even when
there are real effects.

The answer, still imperfect, lies in implementing precautionary
measures that impose far more stringent requirements on old and
new products alike. As the Swedish Chemicals Policy Committee has
recognized, certain attributes should be knock-out criteria.[3]                         Re: Pesticide Alternatives
Persistent bioaccumulative compounds, for example should be                       Mr. Waynt please work with us to end
eliminated from use even without demonstrating toxicological                          this situation that puts our families at risk,
risk. Endocrine disrupting materials should be removed from                          is bad for the State of Michigan and our great
consumer products and their environmental release should be                         nation. Please allow for more than one option.
phased out. More generally, the demonstration of potentially
harmful biological impacts in laboratory studies should reverse                         Hang up, Redial.
the burden of proof in developing regulations from one in which
harm must be demonstrated before a product is withdrawn, to an
approach where safety is ensured beyond reasonable doubt before
widespread deployment is allowed. These steps will help ensure
that the benefits we all enjoy from modern chemistry do not come
back to haunt us.


* John Peterson Myers, co-author of OUR STOLEN FUTURE (hard
cover: Dutton, 1996; ISBN 0525939822; paperback: Plume, 1997;
ISBN 0452274141), is Senior Advisor to the United Nations
Foundation and Senior Fellow, Commonweal.

[1] M.P. Longnecker, M.A. Klebanoff, H. Zhou, J.W. Brock,
"Association between maternal serum concentration of the DDT
metabolite DDE and preterm and small-for-gestational-age babies
at birth, " THE LANCET Vol. 358 (2001), pgs. 110-114.

[2] J.E. Fox, M. Starcevic, K.Y. Kow, M.E. Burow and J.A.
McLachlan, "Nitrogen fixation: Endocrine disrupters and flavonoid
signalling," NATURE Vol. 413 (2001), pgs. 128-129.

[3] Swedish chemicals policy recommendations were reported in
Lotta Fredholm, "Chemical Testing: Sweden to Get Tough on
Lingering Compounds," SCIENCE Vol. 290, No. 5497 (Dec. 1, 2000),
pgs. 1663-1666.