panaceachronicles

Thoughts On Coca, Cannabis, Opium & Tobacco – Gifts Of The Great Spirit


Leave a comment

They Can’t Claim They Didn’t Know

As of 2011 Federal law (cited below) specifically forbids tobacco manufacturers from using pesticide contaminated tobacco that exceeds US pesticide residue standards for domestic tobacco whether that tobacco is domestic or imported. Every tobacco company, US and international, is in gross, reckless and conspiratorial violation of this law.

The law has been on the books since 2011 but apparently nobody at FDA is testing, reporting, or investigating anything. I looked hard and saw zero evidence of concern but who knows, maybe I missed something.

Since I couldn’t find any evidence that FDA was doing its job, or get any response from them when I asked, I just paid for the lab tests that FDA should be doing and am publishing data below showing that every brand we tested violates 907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act. These products we tested and reported to FDA in January 2019 (Potential Tobacco Violation Report ID 19C00160“) should be re-tested on a national scale and if they are in violation they should be withdrawn and the manufacturers subjected at least to fines. I am of course holding my breath.

Here’s the core language of the Federal statute which along with the accompanying language gives any health authority at any level powers to act immediately in protection of public health and safety.  

907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act: 
(B) ADDITIONAL SPECIAL RULE. “Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.”

Here is violation of the law. 

Community Tobacco Control Partners Test Results 12/18

The law means no DDT (zero tolerance under US law), no Carbendazim (zero tolerance under US law), and none of about 13 others just in the little sample of tobacco products we sampled in December 2018. The tobacco material in at least one of the products – Swisher Sweets – violates this law multiple times with contaminants that are a clear and present danger to public health.

The Feds know what the industry is doing, because they wrote this law forbidding it. But they have never published one single test or as far as I can ell conducted one inspection, which means that since 2011 they haven’t prevented one single child from inhaling DDT from a Swisher Sweet their older friends bought at the bodega.

By imposing reasonable pesticide regulations based on existing, effective Cannabis pesticide limits in Oregon and other states, millions of smokers could be protected from exposure to pesticide residues in tobacco products (shown below) that are strongly associated with or in some cases proven to cause breast cancer, testicular cancer, obesity, diabetes, prostate cancer, liver cancer, childhood leukemia (ALL)atrophied testicles, compromised immunity and ruined HIV/AIDS treatments. And there’s more, but I hope this awful list of preventable slaughter is enough to demand that 907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act: 
(B) ADDITIONAL SPECIAL RULE. be enforced. Here is the full data

Tobacco Product Pesticide ResidueTest Sample #1: 12/15/2018Community Tobacco Control Partnersbilldrake4470@gmail.com Comments
Analyte Results/Units
Exceed MRL   √
Not Registered √√
Banned/Zero Tolerance √√√
RED = FUNGICIDE
American Spirit (Cigarette)
Azoxystrobin 0.936 mg/kg Exceeds 0.2 limit
Imidacloprid 0.105 mg/kg Exceeds 0.4 limit
Propamocarb √√ 0.252 mg/kg Not Registered
Fluopyram √√ Trace Not Registered
Spinosad Trace Under 0.2 limit
Marlboro Red 100 (Cigarette)
Azoxystrobin 0.897 mg/kg Exceeds 0.2 limit
Bifenthrin 0.0870 mg/kg Under 0.2 limit
Chlorantraniliprole 0.614 mg/kg Exceeds 0.2 limit
Dimethomorph  √√ 0.0220 mg/kg Not Registered
Metalaxyl 0.0780 mg/kg Under 0.2 limit
Propamocarb √√ 0.129 mg/kg Not Registered
Fluopicolide √√ Trace Not Registered
Imidacloprid Trace Under 0.2 limit
Penconazole √√ Trace Not Registered
Trifloxystrobin Trace Under 0.2 limit
Camel Classic (Cigarette)
Azoxystrobin 0.875 mg/kg Exceeds 0.2 limit
Chlorantraniliprole √ 0.377 mg/kg Exceeds 0.2 limit
Dimethomorph √√ 0.0210 mg/kg Not Registered
Imidacloprid 0.106 mg/kg 0.4
Metalaxyl 0.0810 mg/kg 0.2
MGK-264 0.0600 mg/kg 0.2
Propamocarb √√ 0.167 mg/kg Not Registered
Bifenthrin Trace 0.2
Penconazole √√√ Trace Not Registered
Piperonyl Butoxide Trace 2
Swisher Sweet (Little Cigar)
Acetamiprid 0.146 mg/kg 0.2
Azoxystrobin 0.198 mg/kg 0.2
Carbendazim √√√ 0.843 mg/kg BANNED
Cypermethrin 0.443 mg/kg 1
DDT, p,p-  √√√ 0.816 mg/kg BANNED
Dimethomorph √√ 0.0380 mg/kg Not Registered
Fenamidone √√ 0.0370 mg/kg Not Registered
Imidacloprid 0.169 mg/kg 0.2
Indoxacarb √√ 0.0790 mg/kg Not Registered
Mandipropamid √√ 0.0770 mg/kg Not Registered
Pendimethalin √√ 0.0910 mg/kg Not Registered
Propamocarb √√ 0.0910 mg/kg Not Registered
Pyraclostrobin √√ 0.0210 mg/kg Not Registered
Chlorantraniliprole Trace 0.2
Ethofenprox Trace 0.4
MGK Trace 0.2
Permethrin Trace 0.2
Thiacloprid Trace 0.2
Camel (Snus)
Azoxystrobin 0.142 mg/kg 0.2
Fluopyram √√ 0.0380 mg/kg Not Registered
Bifenthrin Trace 0.2
Mandipropamide Trace Not Registered
Pendimethalin Trace Not Registered

 


Leave a comment

Tobacco Product Risk Reduction

This is a comment that I’ve just submitted to the FDA asking them to enforce their own regulations and conduct appropriate testing, which has not been done to date, to determine whether all current IQOS applications are in compliance with regard to pesticide residues as required by this rule, and then to determine the impact of any discovered pesticide residues on the manufacturer’s many and deceptive “Modified Risk” claims.

You can support a moveon petition to Congress demanding that FDA investigate by clicking on the cute little hummingbird choking on clouds of vaporized pesticides.

To: US FDA December 4, 2018 via Comment Portal

In reference to: 907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act:

(B) ADDITIONAL SPECIAL RULE.—Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.

FDA Comment Submission

I am concerned that

  1. The presence of pesticide residues in the Tobacco component of IQOS has not been discussed or referenced in any of Philip Morris’s FDA multiple IQOS applications.

  2. While the IQOS applications offer extensively documented comparisons between toxic substances in the IQOS vapor stream and toxic substances in the smoke stream of combusted Tobacco (reference Cigarettes only, not commercial cigarettes), after performing a keyword search through the submitted IQOS documentation I can find no mention of any comparison of pesticide residues in the IQOS vapor stream with those in a reference cigarette smoke stream in support of the IQOS claim of “modified risk”.

  3. The public record does not show that FDA has yet requested that Philip Morris demonstrate compliance with Special Rule 907(a)(1)(B) with regard to any of its IQOS applications.

  4. To grant any application related to IQOS without first establishing that IQOS can and will comply with Special Rule 907(a)(1)(B) would seriously jeopardize public health in that without demonstrated compliance and published results, the public will not have an opportunity to make a fair and complete comparison of the relative risks the pesticide residue contaminants of the IQOS product vs combustible Tobacco products.

  5. To grant any application related to IQOS that claims “harm reduction” without first comparing the relative harm of inhaling the intact pesticide burden in the IQOS vapor stream to the harm of inhaling the partially combusted, altered and degraded pesticides in a conventional Tobacco smoke stream, would not serve the public’s interest in having full and fair disclosure of all relevant risks associated with the use of IQOS.

Discussion

Because the Tobacco materials, along with any pesticide residues, in the Tobacco component of IQOS will be vaporized well below the point of pyrolytic degradation, and none of any pesticide residues contained in the Tobacco component will be destroyed by combustion, therefore it is reasonable to project that a greater proportion of the original pesticide residue burden on the Tobacco component of IQOS will survive and retain bioactivity in the vapor stream compared with the proportion of surviving and bioactive pesticide residues in a smoke stream that would be generated by combusting that same Tobacco component; and

Because in making its case for “modified risk” Philip Morris, by comparing the toxicant properties of an IQOS vapor stream with the toxicant properties of a Reference Cigarette smoke stream, either by oversight or by design fails to address the differences in potential for harm between (1) delivery of the full original pesticide residue burden in the IQOS vapor stream compared with (2) delivery of a reduced portion of the original pesticide residue burden, of which a portion has been destroyed by combustion, and some or all of the remainder of which has been dry-distilled into altered compounds and/or partially degraded by pyrolytic processes; and,

Because Special Rule 907(a)(1)(B) requires that manufacturers “shall not use” tobacco of any origin containing pesticide residues “at a greater level” than “any tolerance” specified under Federal law; and

Because in addition to pesticides registered for use on Tobacco with established tolerance levels, Federal law also specifies certain pesticides that are banned for use on Tobacco; in the context of US Special Rule 907(a)(1)(B) this requires that manufacturers shall not use any Tobacco containing those banned pesticides “at a greater level” than zero; and

Because current Tobacco industry documentation shows that certain pesticides not registered for use on Tobacco in the United States are present in the world Tobacco supply, and certain pesticides banned in the US are also present in the world Tobacco supply (https://www.coresta.org/agrochemical-guidance-residue-levels-grls-29205.html ); and

Because Philip Morris is a large importer of Tobacco stem and waste materials from Brazil, a Tobacco exporter with documented heavy use of pesticides on Tobacco crops; (https://www.zauba.com/Buyers-of-tobacco-stems) and

Because imported Brazilian Tobacco stems and waste that are likely to be contaminated with pesticides residues, some of which may violate the “greater level” condition of  Special Rule 907(a)(1)(B), are used in large quantities (millions of kilograms/year) by Philip Morris in its Tobacco product manufacturing in the US and are therefore, in the absence of any statement by the manufacturer to the contrary, likely used in its IQOS manufacturing processes; however, without testing for the presence and concentration of pesticide residues in the IQOS Tobacco component there can be no demonstration of IQOS compliance with Special Rule 907(a)(1)(B) regarding any such “imported tobacco”; and

Because Brazilian Tobacco pesticide use includes the documented use of pesticides for which US EPA and USDA have established that there are no safe levels, and that are either not registered or banned for use on Tobacco in the US ( https://www.hindawi.com/journals/omcl/2018/7017423/ ); therefore,

I am requesting that FDA suspend further consideration of the Philip Morris MRTP application, and any other Philip Morris application that can result in approval by the FDA for sale of IQOS in the US, until the issues I raise here are addressed under the FDA’s 907(a)(1)(B) authority and any other applicable enabling authorities.


Leave a comment

Tobacco Road – Brazilian Tobacco, Nerve Agents, and American Cigarettes

Hello! This blog post is now part of my newly published ebook “Smoke No Evil“.

There’s nothing wrong with smoking Tobacco.

It’s as safe as wine, beer, or cheeseburgers.

It’s the Tobacco Cartel’s products that sicken and kill.

“Smoking-related Death” has nothing to do with Tobacco.

Many people understand the truth, but don’t know the whole story.

Here it is.