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