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Subject:
From:
James Fischer <[log in to unmask]>
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Date:
Mon, 4 Feb 2002 01:48:58 -0500
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Paul Cherubini said:

> According to the EPA
> http://www.epa.gov/pesticides/op/coumaphos/summary.htm

> "Dietary Risks are low:  Acute and chronic risks from food
> treated with coumaphos do not exceed the Agency's level of
> concern."

The quote above was taken so far out of context that it would
embarrass an Enron executive.  If you listen carefully, you can
even hear Richard Nixon not only turning over, but doing
summersaults in his grave in outrage.

The document explains why the EPA is so sanguine about
"dietary risks":

      "There are no registered uses of coumaphos on
       agricultural crops..."

No wonder the EPA is not worried - they have not approved
any uses on crops.  But isn't honey a crop?  One is forced
to conclude that whoever wrote the document did not consider
honey an "agricultural crop", or does not consider a Section 18
exemption a "registered use", or is unaware of recent forays
by coumaphos into beekeeping.

But read on (it is a short document)...

   "Drinking Water Risks are high:

   Acute and chronic risks from drinking water
   derived from surface water do not exceed the
   Agency's level of concern."

Translation: Reservoirs are not threatened.  But why
is the bold heading say that "drinking water risks are high"?
Read on...

   "Chronic risks from drinking water derived from
    ground water exceed the Agency's level of concern."

Translation:  Wells are threatened. Aquifers are
threatened.  Groundwater is threatened.  So
threatened that the EPA has no idea what to do
about it.  (Do recent prior concerns voiced on this list
about landfill disposal of coumaphos make sense now?)

The phrase "exceed the Agency's level of concern"
is a bureaucratic term describing the sort of reaction
expressed by the lead characters in 1950's Japanese
monster movies after a troop of boy scouts, hundreds of
policemen, four battalions of infantry, a brigade of tanks,
several jet fighter wings, and a pair of nuclear weapons
all fail to stop the monster.

But that's not all... there's more...

      "Occupational Risks are high:

      Three out of nine worker exposure scenarios exceed the
      Agency's level of concern at the maximum level of protection
      feasible. These scenarios are: applying liquids with a high
      pressure hand wand at the application rate for cattle and
      horses and use rate of 1000 gallons/day, applying dusts with
      a shaker can at the rate for cattle/horses and swine bedding,
      and loading/applying dusts with a mechanical duster at the rate
      for cattle/horses and swine bedding."

Translation: Current applications known to the EPA pose unacceptable
risks to workers, even when those workers had "the maximum level
of protection feasible".  Recall that the EPA has not even looked at
any beekeeping applications yet.  They are letting the states do the
best they can for beekeepers on budgets most often associated with
school car washes and bake sales.

      "Aggregate Risk is of concern:

      Acute aggregate risk (food and drinking water) does not exceed
      the Agency's level of concern."

Translation:  "Acute", meaning short-term effects.  The good news
is that there is little danger of anyone dropping dead shortly after
exposure to coumaphos.

      "Chronic aggregate risk (food and drinking water) may exceed the
      Agency's level of concern due to the contribution of estimated
      coumaphos concentrations in ground water based on modeling."

Translation:  "Chronic", meaning long-term impact.  The bad news is
that the long-term implications "may exceed the Agency's level of
concern".

Oh dear, there's that phrase again.

Darn, it is so easy to satirize when such good material is tossed
directly into our laps.  This stuff nearly writes itself.

I just wish the basic subject matter was not so serious.
We are almost certain to take some casualties from this stuff.

To quote Bogart, in "Casablanca":

    "...you'll regret it - maybe not today,
     maybe not tomorrow, but soon..."

        jim

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