panaceachronicles

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


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RJR Interoffice Memo – 1997

 

It took me 20+ years after this memoto get the hard data – how’s this for “proactively applying sound science”? Does it look like the industry pesticide committee ever did anything but perhaps meet and decide they had enough regulators, scientists and politicians in their pocket that they didn’t have to worry about it “getting out of control”. 

Community Tobacco Control Partners Test Results 12/18

 


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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Violation Report ID 19C00160“) should be re-tested on a national scale and if they are in violation they should be withdrawn and the manufacturers subjected at least to fines.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

 


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Sweet Cheap Poison At The Bodega

We’ve just finished testing off-the-shelf tobacco products from local mini-marts in Portland, Oregon and among the 20+ hidden, unregulated xenobiotic contaminants that we were able to identify (see below) we found extremely high concentrations of Carbendazim. This contamination occurred in a little cigar brand that is #1 in Latino communities and high in popularity in African-American, Native American and other marginalized & low-income communities where tobacco product choices are restricted to the cheapest, and now we know the most contaminated brands.

Carbendazim has been banned in the EU since 2014. It attacks and destroys the reproductive and immune systems of young people, particularly young Latinos, African-Americans, and Native Americans whose genetic materials are known to be more vulnerable to Carbendazim than youth of European ancestry.  As you can see in the data, Carbendazim is only one many previously hidden, unregulated contaminants we found, each with it’s own health impact. But for the moment let’s focus just on the Carbendazim 0.843 mg/kg that’s being inhaled 20-40-60 times a day by @ 850,000 young people in the US right now today.

Carbendazim contamination disproportionately impacts marginalized young people who fall victim to tobacco products and who, because of poverty and carefully targeted marketing, have few choices available to them other than the cheapest and most contaminated brands. Please notice the relationship between price and contamination in the data below. 

(from): Summary of Science Behind 2014 EU Ban on Carbendazim “Independent literature shows that the pesticide Carbendazim is a very dangerous toxin, capable of causing malformations in the foetus at very low doses and it’s still uncertain if a safe level exists at all. Carbendazim is also capable of disrupting chromosome unfolding, can cause infertility of men and cancer.”   

Community Tobacco Control Partners Test Results 12/18

As you can see, Carbendazim shows up in our first-ever data on pesticide contaminants of tobacco products (right hand column third row). This brand, Swisher Sweets, is #1 in popularity among young smokers, who are also right in the middle of their reproductive years. It is heavily marketed to youth, and is designed with sweet flavors and heavy social media advertising to be part of a cool lifestyle.

Here is a detailed study of how the most toxic brands, with Swisher Sweets the “most toxic”, are marketed in low-income, Latino, Black, and Native American communiities.

This means that these young people, in the middle of their reproductive years, are at the highest possible risk for suffering the known consequences of Carbendazim exposure. (And all the other pesticides you see there, each of which deserves it’s own discussion.) This is made more serious by the route of exposure, because inhalation exposure is far more toxic than eating or skin exposure, and the frequency, because smokers (and fetus and child) are exposed to the pesticides with every puff.

The bottom line is that 0.843 mg/kg is an extraordinary level of Carbendazim to find in any consumer product, but especially in an off-the-shelf tobacco product being marketed heavily to kids, considering that it has been totally banned in much of the world since 2014, is strictly regulated in the US, and is totally illegal on tobacco. Imagine the response of health authorities if this were found on school lunches, slurpees at the 7/11, beer at the mini-mart or granola at Whole Foods?

The problem isn’t just that the Carbendazim is present. For there to be that much Carbendazim residue, it had to have been sprayed on the tobacco deliberately, heavily and recently. There is full knowledge of the EU ban, and the reasons for it. All tobacco manufacturers have notified by their own scientific authority CORESTA. The manufacturers know, or have every reason to know, that they are committing serious race-based crimes against humanity. I can only assume that they have been at this for so long that they actually don’t realize what they are doing to so many people.

Here are just a few of the peer-reviewed research data links that throw light on this hidden relationship

1. Regul Toxicol Pharmacol. 2014 Aug;69(3):476-86. Reproductive and possible hormonal effects of carbendazim.

“The literature review indicates that CBZ induces reproductive and developmental toxicity through alteration of many key events which are important to spermatogenesis. It seems that this fungicide may influence the hypothalamus-pituitary-gonad axis in addition to being a testicular toxicant.”

“2,5-Hexanedione (2,5-HD), a taxol-like promoter of microtubule assembly, and carbendazim (CBZ), a colchicine-like inhibitor of microtubule assembly, are two environmental testicular toxicants that target and disrupt microtubule function in Sertoli cells.”

3. Toxicol Ind Health. 2014 Apr;30(3):259-67. Carbendazim-induced testicular damage and oxidative stress in albino rats: ameliorative effect of licorice aqueous extract

“Administration of carbendazim induced significant decrease in testis weight, diameter, and germinal epithelial height of the seminiferous tubules. Histological results revealed degeneration of seminiferous tubules, loss of spermatogenic cells, and apoptosis. Moreover, carbendazim caused elevation of testicular malondialdehyde (MDA), marker of lipid peroxidation, and reduced the activity of the antioxidant enzymes, superoxide dismutase (SOD) and catalase (CAT).”

4. Toxicol Pathol. 2007 Aug;35(5):719-27. “Dose-dependent effects of sertoli cell toxicants 2,5-hexanedione, carbendazim, and mono-(2-ethylhexyl) phthalate in adult rat testicles.

“Sertoli cells are the primary cellular target for a number of pharmaceutical and environmental testicular toxicants, including 2,5-hexanedione, carbendazim, and mono-(2-ethylhexyl) phthalate. Exposure to these individual compounds can result in impaired Sertoli cell function and subsequent germ cell loss. The loss of testicular function is marked by histopathological changes in seminiferous tubule diameter, seminiferous epithelial sloughing, vacuolization, spermatid head retention, germ cell apoptosis, and altered microtubule assembly.”

5.  Environmental Chemistry Letters 14(3) · June 2016 “Toxicity, monitoring and biodegradation of the fungicide carbendazim” 

“We found that carbendazim causes embryotoxicity, apoptosis, teratogenicity, infertility, hepatocellular dysfunction, endocrine-disrupting effects, disruption of haematological functions, mitotic spindle abnormalities, mutagenic and aneugenic effect.”

And the issue isn’t just Carbendazim as you can see looking back in the data. Most of the individual contaminants are concerning by themselves, but they are additive and synergistic in effect and their impact on human health in that regard is absolutely unknown. What is known now, and IMO it ought to be enough, is that young smokers are inhaling a toxic cocktail of chemicals each designed to operate in different ways at the nano-level to disrupt basic life processes.  The dosage of the most advanced pesticides doesn’t matter – they don’t need a “critical mass” to work. A couple of molecules, well below the level of detection, is enough for them to do what they were designed to do to the reproductive systems and genetic materials of bugs, and human teens are simply unfortunate collateral damage in the tobacco industry’s search for increased profits through chemistry.


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Incidental Genocide

The Tobacco companies aren’t deliberately mass murderers. They do maim and kill genocidal levels of people every single year, but that’s just as a byproduct of their business decisions. They don’t actually intend to have their customers sicken and die- it’s just so damned profitable to use stuff like DDT instead of labor to grow tobacco.

They do know that it’s the DDT and other xenobiotic chemicals they use in the fields, invisible to everyone, that are actually killing most of the people dying of “smoking-related disease.” They’ve spent huge amounts of money to keep that particular little piece of information top secret even though it’s been in plain view for fifty years. That has been quite a trick, but they have managed to pull it off pretty well so far. However, bad news is coming for the so-called “Tobacco” industry. All it’s going to take is one well-informed class-action lawsuit based solidly on injury by preventable pesticide contamination and this whole nasty conspiracy will finally come crashing down.

The thing is, these murderous companies don’t actually want to kill off their customers, although because they know that they do, they spend lots of money creating large numbers of what they call “replacement smokers” every year. They spend vast sums advertising heavily to kids worldwide, making cheap fruity sweet tobacco products readily available and now packaging straight nicotine in glycerin for vaping just to give kids a taste of the real thing. And those cute little replacement smokers just keep lining up.

Oh, and those small farmers in remote areas that work like slaves for the Tobacco companies and apply all those chemicals that should be labeled “severe hazard – inhalation”, but aren’t? There aren’t any labels on the 55 gallon drums of pesticide that the tobacco company agent drives up and hands to the farmers and says – “spray this tonight”. They aren’t complaining because if they do they won’t get their tobacco allotment next time and their families will starve, plain and simple. Yes everybody is always sick, and they have lost a few babies to disease, but they have to eat. So it’s really just business all up and down the line. Except that a lot of people seem to be dying at every step.

Even fifty years after global governments first banned DDT, and with every health agency in the world classifying it as an extreme hazard, the Tobacco companies are still forcing illiterate farmers in remote Tobacco-growing regions to drench the Tobacco crops with it. Why do this?  Because if you use enough DDT all you need is one peasant with a tank on his back walking through the field killing all the bugs and worms with chemicals rather than twenty men, women and children working that same field, taking care of the tobacco using the old ways, and earning at least something of a wage, and not being drenched with DDT drift day and night.

Oh sure, the global tobacco industry could pay people to work the tobacco fields by hand and maybe even pay them a decent wage. Then  tobacco products would be more expensive, which of course is exactly what American health authorities think is the only way to get people to cut down, quit or never start. You would think that everyone would get behind organic tobacco because it would be much more expensive, but that would mean more profits for the tobacco industry and not more taxes for the bureaucrats so of course that isn’t an appealing tobacco control strategy.

“We believe that making tobacco products more expensive reduces smoking, and it is a primary strategy for control and prevention. But, we don’t want to make tobacco more expensive by requiring that it be organic or at least meet reasonable pesticide residue standards, we want to leave outrageously dangerous pesticide contaminated tobacco alone and just make it more expensive using taxation. Our job isn’t to protect people – it’s to preach at them and take away their money so they can’t do bad things with it.”

Tobacco has always been an extremely profitable crop, but a very tough crop to farm. The problem is that bugs love tobacco more than just about any other plant. Tobacco is so high in both sugars and very rich protein that every kind of bug, animal and worm in nature loves to eat those incredibly valuable tobacco leaves. So, for centuries growing tobacco meant prodigious hand labor in the tobacco fields day and night (by guess who), along with great wealth (owned by guess who) that built the American society. But that tobacco wealth wasn’t an industry until agricultural chemicals came along, and then tobacco was one of the earliest and strongest adopters of pesticides.

With the chemical revolution came highly effective Organochlorine pesticides that sprang directly from WWII Nazi poison gas experiments, and virtually overnight the tobacco companies switched from human labor in America to ever-diversifying chemical “crop protection agents” in the Third World that let them grow tobacco at a fraction of the cost of human labor, increasing their already insane profits even more. The difference in profit between growing tobacco using hand labor and using chemicals is what has made the tobacco industry rich beyond imagination since 1950, and they’ve used that wealth to make sure that no government gets in the way of their use of those extremely profitable chemicals.

As a result, chemical contaminants that are totally banned on any other consumable product are not regulated at all on tobacco, and the tobacco industry is continually coming up with new exotic chemicals to use on their fields of GM tobacco and all those chemicals are winding up in the lungs of poor smokers and vapers.

The anti-tobacco crusaders have been raising taxes for years, showing studies that prove when tobacco products get more expensive, people smoke less. We’ve got a winner folks – increase prices.  That finances a huge bureaucracy that can then run around and invent a lot of ways to justify its existence by “educating” people. They can all have comfy salaries and a “sense of mission”, spending all that easy-come tax money on themselves so that they can “educate” and “persuade” people. They can’t actually”protect” people of course, because the tobacco industry has tied these well-meaning but also self-satisfied and very comfortable health bureaucrats up in very subtle legislative knots to where they actually say that they can’t regulate pesticides in tobacco products and then in the next breath play CYA by saying, with complete sincerity, “We believe that tobacco is so bad that there is no need to focus on pesticide residues.”

Of course, if you DID focus on the pesticide residues, then you would HAVE to do something about tobacco products – like regulate them for example. 

Community Tobacco Control Partners Test Results 12/18

The pesticide residues that contaminate tobacco products are simply the incidental result of crop management decisions the industry makes every day. Since these giant international companies grow most of their tobacco in remote parts of the world, out of sight of any regulators who can’t be easily managed with a few dollars they are free to use the most effective crop chemicals available on their Tobacco crops, which means using chemicals that are so toxic to living things (xenobiotics) that they are banned in every place where regulations matter. There is plenty of DDT and other banned pesticides available anywhere in the world outside of the tightly regulated countries, where almost all of the tobacco is grown for US consumption.

The problem with pesticide contamination of Tobacco products is that the Tobacco companies have arranged legislation in the US so that all that health departments can do is “encourage” people to stop smoking and ‘discourage’ them from starting, but they can’t actually touch the tobacco products themselves because they are protected by a core assumption that has cost the Tobacco companies billions to put in place. That core assumption is that Tobacco itself is so bad that nothing else matters. All I have to say is – who benefits from that assumption? Only the Tobacco industry.


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Do You Want To Make Little Cigars Illegal In Your Community?

I’ll skip the long, long back story and get right to the point. If you’ve been looking for a way that individuals and small groups of people acting on their own initiative can control dangerous tobacco products at the local level, this is it. Here’s wishing you a successful 2019.

I recently had a number of off-the-shelf tobacco brands tested for pesticide residues. This was the first time this has been done in the US, in spite of the massive amounts of tax and private money spent every year on so-called “tobacco control and prevention”.

In this post I’m including hard evidence showing the concentration of illegal, totally banned DDT I found on the most popular brand of sweet & fruity little cigars, Swisher Sweets – the top choice among low-income, Black and Hispanic teens. They are also arguably the most toxic piece of shit in the whole pile of toxic shit that this rat pack of corporate criminals sells to kids. Don’t get me wrong – I found extreme pesticide contamination on many of the brands I tested – it’s just that the little cigars stood way out at the top of the contamination chart.

Don’t just take my word for the toxicity of little cigars – the University of North Carolina conducted an extensive study in 2016 comparing the toxicity of little cigar smoke, including swisher Sweets, compared with cigarette smoke. This study was also the first of its kind, just like my pesticide residue study. The North Carolina researchers found detailed hard evidence that little cigars are extremely toxic and are particularly dangerous to young, Black, and Latino smokers compared with cigarettes. (This study, combined with the hard evidence I’m sharing in this post, will blow your mind if you care about mass poisoning of innocent children.)

The one area that this North Carolina study missed was the key role that pesticide residues play in tobacco product toxicity. Like every other scientific and medical study before them, these researchers totally failed to account for pesticide contamination in the tobacco products they tested, and so they were understandably puzzled by the extreme levels of toxicity they found.

However, once you factor in pesticide contamination, the whole picture emerges clearly. The North Carolina data makes sense. It’s the differences in the pesticide burdens of different types of tobacco products that account for the differences in toxicity among types of tobacco products. That’s why it’s so important for local communities to understand the nature of this hidden threat to their children.

I found actionable levels of many different pesticide residues in all the tobacco products I just tested, including several cigarette brands popular with kids. But the overall pesticide contamination of Tobacco products, which regulators manage to ignore, isn’t the key point here. The key point for tobacco product control at the local level is that these little cigar/DDT results are not only grim news for smokers but flat out violate the law.

It is illegal to sell any product contaminated with this level of DDT anywhere in the US. and much of the world. Only soil or water-residual DDT is allowed in any food, beverage, cosmetic or other consumer product, and there is no way that the level I found could occur as a residual from soil or water – it was sprayed on the tobacco used to make this product, and it was sprayed recently. (See commentary below the data.)

The DDT concentration shown below is 700+ times the highest level found anywhere in the entire US food chain from lingering soil or water contamination, and I will guarantee that a sampling of 100 such products will yield similarly shocking results. 

So here’s my suggestion. Take this data on your phone to your health department. Show them the DDT levels. Tell them that the same little cigar products are being sold at the mini-mart. (They are.) 

And then ask them what the law says they have to do. Tell them that the investigator behind this data will send them the full, certified lab report naming the specific brands we tested and the full results. I almost guarantee that they will try to wiggle out of it – “we don’t regulate tobacco products”, or “we don’t regulate pesticides in tobacco products” or, their favorite excuse – “well, tobacco is so bad anyway that we don’t care about a few pesticides”.

But here’s the beauty of the hard evidence I’m offering. It doesn’t matter if your local health officials think they can regulate tobacco products specifically or not. It doesn’t matter if they think have the authority to regulate tobacco products or not. Unless they are somehow forbidden to investigate and take action in cases of toxic substance contamination in consumer products being sold to children in your county, they do have the authority to act. You may have to make them act by going to the School Board, the District Attorney, and your local media, but they do have the authority to act locally and independently on high-level DDT contamination of anything in your community – period.

These contaminated tobacco products are illegal not because they are tobacco products; they are illegal because they are consumer products contaminated with hazardous concentrations of extremely hazardous, totally banned pesticide chemicals that will be emitted when they are used as intended by the manufacturer.

If you enjoy a sweet irony, I can guarantee that when all the testing is done, most of the premium cigars that the 1% love will turn out to be the most highly contaminated of all. Although some premium cigar tobacco growers still use traditional methods, and grow tobacco without industrial chemicals, I’m quite certain that most premium cigars will prove to be far more contaminated than the cheap little cigars the busboys out behind that five-star restaurant have to smoke. 

                   Pesticide Residue Test Sample #1                                  Multnomah County, Oregon                       Received 12/13/2018

billdrake4470@gmail.com

Oregon Cannabis Pesticide Residue Action Levels (PPM)
Analyte Results/Units na = not a listed or regulated pesticide
Exceeds ORS Action Levels √
Unregistered Tobacco EPA/Oregon √√
Banned/Zero Tolerance √√√

Swisher Sweets

Acetamiprid 0.146 mg/kg 0.2
Azoxystrobin 0.198 mg/kg 0.2
Carbendazim √√√ 0.843 mg/kg Carcinogen: WHO
Cypermethrin 0.443 mg/kg 1.0
DDT, p,p-  √√√ 0.816 mg/kg** 0.0 – banned
Dimethomorph √√ 0.0380 mg/kg na
Fenamidone √√ 0.0370 mg/kg na
Imidacloprid 0.169 mg/kg 0.2
Indoxacarb √√ 0.0790 mg/kg na
Mandipropamid √√ 0.0770 mg/kg na
Pendimethalin √√ 0.0910 mg/kg na
Propamocarb √√ 0.0910 mg/kg na
Pyraclostrobin √√ 0.0210 mg/kg na
Chlorantraniliprole Trace 0.2
Ethofenprox Trace 0.4
MGK Trace 0.2
Permethrin Trace 0.2
Thiacloprid Trace 0.2

** Relevant to risk assessment for these “Little Cigars”; the highest levels of DDT p, p- in all foods tested by FDA in their comprehensive “Total Diet Reports” for 2017, were for catfish filets and for frozen potato fries. The 2.17 ng/g potatoes and 2.3 ng/g levels expressed in the FDA “Total Diet Study” are the equivalents of 0.00217 mg/kg for potatoes and 0.0023 mg/kg for catfish. compared with 0.816 mg/kg in the single little cigar sample tested. Based on my knowledge of tobacco industry practices, additional testing will show serious levels of OCP and other classes of pesticide contamination particularly on tobacco products in the “discount” and low-price market segments and, as we will see, in the premium cigar market segment as well.

I know for certain that as we test other tobacco products, especially the cheap ones, we’ll find stuff that makes DDT look like a hint of mint. However, this data is right now, and approximately 800,000 children between 11-15 are smoking this particular brand of little cigar every day and inhaling every one of the pesticides listed.

But even if the only contaminant were the 0.816 mg/kg (or 816 mcg/kg) DDT ….

Average adult intakes of DDT were estimated to be 62 µg/person/day (1000 micrograms = 1 milligram) in 1965 and 240 µg/person/day in 1970, before the DDT ban was instituted. The FDA Total Diet Studies show that the daily intakes have fallen since the ban, with daily intakes (for a 16-year-old, 70 kg male) averaging 6.51, 2.38, 1.49, and 0.97 µg/person/day for 1978–1979, 1979–1980, 1984–1986, and 1986–1991, respectively.https://ntp.niehs.nih.gov/ntp/htdocs/chem_background/exsumpdf/ddt_508.pdf

“Based on all of the evidence available, the Department of Health and Human Services has determined that DDT is reasonably anticipated to be a human carcinogen. Similarly, the International Agency for Research on Cancer (IARC) has determined that DDT is possibly carcinogenic to humans. EPA has determined that DDT, DDE, and DDD are probable human carcinogens.”

https://www.atsdr.cdc.gov/phs/phs.asp?id=79&tid=20

Here is a first-class study of the toxicity of cigarette smoke compared to little cigar smoke. It’s clear from this data and analysis that little cigars, including Swisher Sweets which were one of the brands tested, are far more toxic than cigarettes. Interestingly, the researchers were puzzled about where those huge differences in toxicity came from. ‘

It was at least partly from the hidden and unaccounted-for pesticides, which were overlooked in this study as they have been overlooked in virtually every American scientific and medical study of “tobacco” smoke. Little cigars are far more contaminated with far more toxic “crop protection agents” than cigarettes because of differences in how the tobacco is raised, and in how much highly contaminated tobacco manufacturing waste is used in making the product.


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A Community-Level Tobacco Control Strategy

We laugh at the silly idea of Cannabis as a “killer weed” now, but millions believed it and happily allowed the government to send generations of people to prison because they believed it. It seems absurd that anyone would be fooled by that ham-handed government propaganda, but millions were and many still are.

Keeping mind that what has happened in the past could happen again, and could be happening right now, let me ask you to consider this:

What if there is a much more subtle and sophisticated generations-long campaign of disinformation about Tobacco just like there was about Cannabis? What if it’s run by a powerful industry with endless money and not by a bunch of clueless bureaucrats thinking up stupid slogans.  What if the Tobacco industry has known for a long time that it has a severe, possibly fatal problem that it has managed to keep completely out of public view by spending vast sums of money on a combination of public persuasion and widespread, carefully targeted (but increasingly visible) official, scientific and medical corruption?

What if some or even most of the damage being caused in the modern world by commercial Tobacco products is not being caused by the Tobacco in those products but by previously unidentified hazardous toxic substances IN the tobacco products, and what if that means that these products can be controlled at the local level using existing local and state ordinances and laws?

I know that’s it’s a heresy, but fair-minded people will consider the actual evidence and not rest on an unquestioned assumption: maybe it’s not the tobacco in the tobacco products that’s killing most of the people.

The very foundation of the anti-tobacco, anti-smoking faith is that “Tobacco Is Bad Shit”. That’s the firm, unquestioning belief, and every tobacco prevention and control effort in the world is pinned to that article of faith. Tobacco causes illness and death. End of discussion. No questions. Full stop. We already know that Tobacco is bad shit, and we don’t want to hear any more about it. So let’s just move on and figure out how we can keep people from smoking and now vaping the goddamned stuff!

OK, but what if everybody is wrong? Really – what if everyone thinks things are one way, when they are actually another? Is that possible? What if people are all looking in one direction while the answer lies in another? Has there ever been that kind of mass delusion in history? Of course there has been – that’s a central theme in the history of science. People believe something fundamental for generations. It’s obviously wrong, but nobody can see it.  The first one who points this out is attacked. Others speak up and say wait a minute, we should check this out and see if it’s true. They do, and it is. And then everybody says “Whocoulddaknowed?”

The oldest example of “everybody knows” is the flat earth delusion that ruled western minds for centuries. Maps showed the edges of the earth. Then one day – Oops! It’s round. Whocoulddaknowed? Then next the all-powerful church decided to burn heretics who pointed out simple, hard evidence that the world rotated rather than the heavens turning.everyone knew that the earth was the center of the universe and that everything in God’s heavens rotated around God’s earth. Then one day – Oops! Whocoulddaknowed? It took the church centuries to apologize to Galileo.  Then everyone laughed at the idea of invisible bugs causing disease because everyone knows it’s the vapors. Oops! again. Really, Whocoulddaknowed? Little invisible bugs. Well I’ll be damned.

Most of us scoff at that kind of profound ignorance as if we were invulnerable to the same folly. But I’m telling anyone who will listen – it’s not the tobacco that is sickening and killing millions.

I realize that tying those profound historical delusions to a delusion about Tobacco, even if it could be demonstrated, may seem trivial in comparison, but if anything the effect of the delusion about Tobacco has had greater impact than any of those mass delusions just cited. That’s because of our profound collective delusions about tobacco, carefully cultivated by the tobacco industry to shield itself from accountability, have allowed millions of completely preventable deaths in the past and the dying will continue long into the future because of our willful collective ignorance.

The last words attributed to Jesus were “Father forgive them. They know not what they do.” I have always believed that Jesus was using those last words not to comment for all eternity on those who were killing him, but on the one thing most responsible for the suffering and death of mankind.

So, I’ll ask again, what if most of the damage being caused by Tobacco products is actually being caused by pesticide residues that contaminate the Tobacco products? The tobacco products, the manufactured crap, not tobacco itself.

Here’s the thing. We know for sure that pesticide chemicals do exactly what they’re designed to do. They interrupt nerve transmissions, they destroy DNA, they poison internal organs, they mutate little bug babies – the scientists are endlessly creative. So in the end, it really doesn’t matter whether tobacco is bad or not – we know that pesticides are “bad” for sure. They are “xenobiotics” – substances “hostile to life”. But so many people are so tied up arguing the evils of Tobacco so passionately and hatefully that they don’t see themselves as precise  parallels with the Middle Ages “angels on the head of a pin” debate that consumed generations of “wise men”, while the Tobacco companies are snickering all the way to the bank.

There are laws in place in every community to deal with pesticides as toxic substances, although those laws have been rigged by the pesticide manufacturers to cover what they thought was every contingency.

That’s the beauty of understanding that there are xenobiotic substances ON the tobacco products. It doesn’t matter what you think about tobacco itself, or even what laws and ordinances and regulations say about “tobacco” itself. Hate it or love it – doesn’t matter. These are products, and they are toxic, and they violate all kinds of laws on that basis. If you love Tobacco, you should care. If you hate Tobacco, you should care. Pesticide-free tobacco products would be a major improvement in the life of a community regardless.

So there really doesn’t have to be any argument at all about whether or not tobacco is bad and should be controlled – some of the pesticides on the tobacco products being sold in your community are flat illegal and there are available legal remedies that the law says MUST be applied. Take that to the bank – and to your health department. and don’t let them stonewall you about “lack of authority” – they have it. They have never used it before, and they probably haven’t ever thought about it, but if a toxic substance suddenly falls from the sky into the WalMart parking lot you can bet they won’t be sitting around wondering who is going to handle it. If somebody lets loose a can of DDT in a school you can bet that the local authorities aren’t going to call the state police and then wait. Communities can act when they are in immediate peril, and high concentrations of banned pesticide residues in tobacco products being smoked by children in the community meets that definition in spades.

Pesticides fall into a class of chemicals defined as “toxic substances” in a wide range of environmental and consumer protection regulations and statutes. In every state, there are statutes that empower local, county-level health officials to act when toxic substances threaten local public health. Yes there are pre-emption laws that forbid local communities from imposing greater restrictions on pesticides than state laws do, but in this case we’re talking about local communities using existing state laws on toxic substances in consumer products that, if detected at the any level, can trigger local action by public health authorities without waiting for permission from the state. This strategy may need tweaking in many communities, but because state and federal lawmakers have been incredibly (and perhaps in some cases deliberately) sloppy in writing tobacco product regulations I believe that tobacco product pesticide contamination opens a big wide door for local control.

In Oregon where I live, the credible allegation of the presence of banned “toxic substances” on any property located in the community is supposed to trigger mandatory regulatory responses if the allegation is properly made and supported by evidence. “Property” includes tobacco products sitting on the shelf down at the mini-mart. I’m currently working on educating our local public health administrator on her authority to act in this area.

In most jurisdictions I’ve looked at in California, Colorado, and other Cannabis-legal states, a broad range of “Property” is subject to “toxic substance” regulatory oversight by County public health authorities. 

I can hear the screams from the faithful now – but, but Tobacco is so bad that it doesn’t matter if there’s poison on the leaves! I would only ask the faithful – can you point to one scientific research study that compares the smoke or vapor of 100% pure, organic Tobacco with any Tobacco product on the market? There are none. Zero. And, that’s not one of those famous “distinctions without a difference”. Please think about that – if actual, real Tobacco smoke or vapor has never been tested, and if every report of toxic substances in “tobacco” smoke has been based on rigged “reference cigarettes” supplied by the industry itself, where does that leave the idea that, without any question, Tobacco is horrible, awful, dangerous stuff? It may be true, but there are no studies that prove it one way or another.

Since 1970 virtually every “scientific” study of tobacco products has used industry-supplied “reference cigarettes” that don’t give results relevant to either what is really on the commercial market or to organic or even simply leaf tobacco. At least 25% of those “reference cigarettes” are “reconstituted tobacco”, a synthetic product made from a highly variable mix of tobacco stems, stalks and factory-floor waste called “tobacco dust”. There is no way that the results of smoke stream or vapor stream analysis using “reference cigarettes” has anything to do with tobacco in pure form. I know that anti-tobacco advocates would fear that the results of such testing might clear Tobacco’s name and give people who like to smoke and vape a license to do so. But so what?

I would say to them, if it turns out that it isn’t the Tobacco but the pesticides, since the pesticides are a very controllable harm while people smoking and vaping are not controllable, then forget about your dislike of Tobacco and deal with the problem. Or , I would also ask them, do you secretly agree with that renegade government bureaucrat in the 1920’s who arranged to have bootleg whiskey poisoned with methanol in order to scare people into not drinking? Do you think, I would ask, that this was actually a pretty good idea and those drinkers deserved what they got? Or maybe you aren’t that cold-hearted and simply think that alcohol is so bad anyway, and those drinkers were poisoning themselves anyway, so what’s the big deal?

I would ask them these questions because any person who felt so strongly about alcohol that they would ignore the deliberate poisoning of drinkers by the government wouldn’t be worried about a few pesticides in Tobacco products. By the same reasoning, Tobacco is so bad anyway – who cares about pesticides? 

Think that an example from the 1920’s, a hundred years ago, is a bit irrelevant to today’s enlightened government? Well, remember Paraquat on Marijuana? The DEA came right out and said that regardless of what it did to Marijuana smokers, they were engaged in illegal activity and so it didn’t matter. Besides, from the government’s point of view, a few dead hippies weren’t worth getting worked up over. The idea that was sold to the public is clearly that Marijuana is so bad anyway who cares if the government poisons it – after all, they’re just trying to keep precious little American children from being lured into a life of degradation and crime. 

Workers apply fungicide “Ditio carbamato” to cigar tobacco in Nicaragua every 4 days

So what I’m saying is that the only fair and reasonable way to determine the truth, the relative degree of actual risk, would be to compare (1) commercial tobacco products with (2) organic tobacco smoke and vapor. Otherwise all that science on smoking, and all those horrible components of “tobacco” smoke and vapor, aren’t actually testing “tobacco” smoke or vapor at all. They are testing “Tobacco product” vapor and smoke, and most Tobacco products in America have no relationship to real Tobacco leaf. Again, a distinction with a big difference.

One more heretical question, if you’re with me so far. What if those toxic substances are in Tobacco products for one reason only – because it is more profitable for Tobacco product manufacturers to use these chemicals in Tobacco production than to produce Tobacco without them? Almost as an aside, premium cigars are among the most severely contaminated Tobacco products in the world, because the growers spare no expense in applying pesticides, fungicides and every other kind of chemical to keep bugs and worms 

from eating holes in those incredibly valuable cigar wrapper leaves. And why do they do that? Simple, again. It’s the money. A Tobacco leaf with bug holes can be used for making premium cigars, so once a bug takes a bite that leaf turns from gold into plain old shit. 

Tobacco products aren’t contaminated with pesticide residues because the growers and manufacturers want to poison their customers; they’re contaminated because everybody makes more money by using these chemicals and they aren’t being forced to clean up their products, so millions of people are dying just like the bugs and worms in the Tobacco fields. It’s really that simple.

 

The Tobacco industry has produced organic Tobacco products, with no pesticide residue contamination. It knows how. It simply chooses not to. That cost/benefit decision alone impoverishes and drives the loss of millions of lives every year with immeasurable suffering and grief.

Pretty damned grim, right? Well, maybe not.  

All it took to bring down Al Capone was one little charge of income tax evasion, and he wasn’t nearly the magnitude of monster these Tobacco companies are. Al thought he was riding pretty high too. Fancy suits. Expensive wine. Hookers. Blow. The best of everything. But he overlooked that one little crime, and that was enough. 

Who in your County public health structure has the regulatory authority to order inspection of commercial products that are credibly suspected of being contaminated with the residues of banned pesticides? 

Insist that they forget you are talking about Tobacco products.

Ask them what their action would be if you were coming to them with evidence that imported scented candles, or air fresheners, or incense being sold in your community were contaminated with these same pesticides at these same levels?

Geiss, O., Kotzias, D. – Determination of Ammonium, Urea and Pesticide Residues in Cigarette Tobacco. Fresenius Environmental Bulletin (FEB), No. 12 (2003), 1562– 1565

What would they do if they knew that children in the community were going to be inhaling vapors of Endosulfan, 4,4-DDE and Heptachlor over 100 times a day in homes where adults burned these candles?

How about if the issue was air fresheners contaminated with those same nerve toxins? Or maybe incense from China or India full of Chlordane?

What would they do if Tobacco products at the local mini-mart had the same contaminants as the cigarettes on the list you see here.

Oh, and about this cigarette pesticide data being from 2003? See my recent blog post with the Tobacco industry’s own data that shows these same pesticides – and about 100 more – still present on Tobacco worldwide in 2018. Show that data to your county public health department too.

If these two little bits of “income tax evasion” evidence aren’t enough to give your County public health officer “reasonable cause” to order inspection of commercial Tobacco products being sold in your County, let me know.

I’m doing some Tobacco product testing right now (12/18) in three of Oregon’s premier testing labs, and I plan to make the results available as part of a community-level Tobacco product control program.

Local communities have deferred too long to State and federal bureaucrats to protect them from Tobacco products. Simple residue testing of commercial tobacco products being sold in your community will give you ample evidence to insist that your local public health officials use their existing authority to enforce toxic substances regulations against contaminated Tobacco products for sale in your community.

If your community doesn’t have existing qualified pesticide residue testing labs, and most don’t, get in touch and ask for no-cost assistance from the Oregon Community Tobacco Control Partnership. 


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Stone Killers

If you want a new way to control the damage that Tobacco products do to your community, then this may interest you.

This post offers credible tobacco industry data showing all of the pesticides that contaminate Tobacco products worldwide. It is published by CORESTA, the tobacco industry’s captive science & research institute. This information alone can empower local initiatives by offering credible evidence that banned toxic substances may be contaminating locally-sold Tobacco products.

If your local health department has regulations that allow it to investigate whether a product being sold in your community is contaminated with banned pesticide residues, then this list will give them probable cause to sample locally-sold Tobacco products and test for the presence of banned pesticide chemicals.

It is important for you to keep in mind, when making such a request, that (1) it doesn’t matter that the products are Tobacco – they are just like pesticide contaminated candles, air fresheners or incense – and (2) these contaminants are present because of negligence by the manufacturer and lack of regulatory oversight by any superior authority, so the local authorities have to act in the interest of public health and safety.

So this is it – the official (but highly confidential) June, 2018 tobacco industry guide to the pesticide chemicals used on tobacco worldwide. It’s an industry list cautioning manufacturers to ‘watch out’ for these chemicals that remain on Tobacco from the fields, which means that it’s a list of what the industry knows is potentially present in any Tobacco product anywhere.

Many of these pesticides are damaging to human health at very low levels of chronic exposure – just like a smoker gets 100-200 times a day, 365 days a year puffing away and inhaling the pesticide residues invisibly contaminating the tobacco in their cigarette. (Except that it isn’t really tobacco, but that’s another post.)

But the really severe public health threat created by pesticides on Tobacco lies in the industry’s attempt to pivot toward vaporizing. Imagine that instead of being at least partially destroyed by combustion and smoking, all those pesticides are now being gently vaporized and delivered full-strength to your lungs as IQOS Tobacco vapor.

While the tobacco industry publishes pesticide standards for its members, it makes clear that nobody actually has to follow this industry guidance. The tobacco companies are safe from accountability because there is no testing of commercial cigarettes in the United States for the presence of any of these chemicals, and what little testing the FDA, EPA and USDA do perform almost seems deliberately designed to shield the tobacco industry from investigation. It’s not as if the FDA doesn’t have the authority to demand that Tobacco companies at least keep the contamination down a little. 

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.

Please keep that language in mind as you browse the list below. Chronic low-dose exposure to any one of the pesticides on this list, just by itself, is enough to cause serious damage to human adults, children and babies. The US government, along with the health authorities of every state, seem collectively uninterested in knowing what dozens of these violent chemicals, all being either burned or heated, smoked or vaporized and then inhaled actively or passively are doing to smokers or vapers, their families and everybody else downwind every day of their lives.

One last thing – notice that there are a lot of banned pesticides on the list. That’s because the Tobacco industry recognizes that large stores of these chemicals still exist and farmers still use them for one simple reason – they  kill bugs. It might also be that these chemicals are still being made in black factories in India and China.

Whether using banned pesticides or not, most small farmers in the Third World can’t even read the labels, if there are any, so all they care about is killing bugs and fungus. Every pound of tobacco that bugs eat and fungus destroys is one less pound the farmer has to sell to feed his family, which doesn’t mean that the kids just go without a snack for a day or two.

So of course hundreds of thousands of small tobacco farmers worldwide are going to use triple-witching stuff like Endrin, Heptachlor, Aldrin, and Dieldrin whenever they can get it or whenever they are told to use it. Because while manufacturing of these incredibly toxic chemicals is banned almost everywhere, ‘black’ factories in China and India are churning out the oldies but goodies by the ton and selling them in countries where 50% of all pesticides are used on just one crop – tobacco.

But of course regulatory authorities in the ‘advanced’ countries like the US don’t test for these banned pesticides in anything anymore, much less in tobacco products like cigarettes, because “nobody uses them anymore and all the old stores have been used up or destroyed long ago”.


Table 1.   Crop Protection Agent (CPA) Guidance Residue Levels (GRL)

This is not a list of recommended CPAs (Crop Protection Agents) for tobacco. That is a matter for official and/or industry bodies in each country.

  • GRLs have not yet been set for all CPAs registered for tobacco. Setting GRLs is an ongoing process based on a list of priorities decided by frequency of use and importance to leaf production.
  • The presence of a compound does not imply endorsement by CORESTA
  • The entries in the list do not replace MRLs (Maximum Residue Levels) set by the authorities. Compliance with MRLs is a legal requirement for countries that have set them for
No. CPA GRL

(ppm)

Residue definition Notes
1 2,4,5-T 0.05 2,4,5-T
2 2,4-D 0.2 2,4-D
3 Acephate 0.1 Acephate
4 Acetamiprid 3 Acetamiprid
5 Acibenzolar-S-methyl 5 Acibenzolar-S-methyl
6 Alachlor 0.1 Alachlor
 

7

 

Aldicarb (S)

 

0.5

sum of Aldicarb, Aldicarb sulfoxide and Aldicarb sulfone, expressed as Aldicarb
8 Aldrin + Dieldrin 0.02 Aldrin + Dieldrin
9 Azinphos-ethyl 0.1 Azinphos-ethyl
10 Azinphos-methyl 0.3 Azinphos-methyl
11 Benalaxyl 2 Benalaxyl
12 Benfluralin 0.06 Benfluralin
 

13

 

Benomyl (a)

sum of Benomyl, Carbendazim, and Thiophanate-methyl expressed as Carbendazim  

see Carbendazim

14 Bifenthrin 3 Bifenthrin
15 Bromophos 0.04 Bromophos
16 Butralin 5 Butralin
17 Camphechlor (S) (Toxaphene) 0.3 Camphechlor (mixture of chlorinated camphenes)
18 Captan 0.7 Captan
19 Carbaryl 0.5 Carbaryl
 

20

 

Carbendazim (a)

 

2

sum of Benomyl, Carbendazim, and Thiophanate-methyl expressed as Carbendazim
 

21

 

Carbofuran (S)

 

0.5

sum of Carbofuran and 3- Hydroxycarbofuran expressed as Carbofuran
22 Chinomethionat 0.1 Chinomethionat
23 Chlorantraniliprole 10 Chlorantraniliprole
24 Chlordane (S) 0.1 sum of cis-Chlordane and trans- Chlordane
25 Chlorfenvinphos (S) 0.04 sum of (E)-Chlorfenvinphos and (Z)-Chlorfenvinphos

 

No. CPA GRL

(ppm)

Residue definition Notes
26 Chlorothalonil 1 Chlorothalonil
27 Chlorpyrifos 0.5 Chlorpyrifos
28 Chlorpyrifos-methyl 0.2 Chlorpyrifos-methyl
29 Chlorthal-dimethyl 0.5 Chlorthal-dimethyl
30 Clomazone 0.2 Clomazone
31 Cyfluthrin (S) 2 Cyfluthrin (sum of all isomers)
32 Cyhalothrin (S) 0.5 Cyhalothrin (sum of all isomers)
33 Cymoxanil 0.1 Cymoxanil
34 Cypermethrin (S) 1 Cypermethrin (sum of all isomers)
 

35

 

DDT (S)

 

0.2

sum of o,p’- and p,p’-DDT, o,p’-

and p,p’-DDD (TDE), o,p’- and p,p’-DDE expressed as DDT

 

36

 

Deltamethrin (b)

 

1

sum of Deltamethrin and Tralomethrin expressed as Deltamethrin
 

 

37

 

 

Demeton-S-methyl (S)

 

 

0.1

sum of Demeton-S-methyl, Oxydemeton-methyl (Demeton-S- methyl sulfoxide) and Demeton-S- methyl sulfone expressed as Demeton-S-methyl
38 Diazinon 0.1 Diazinon
39 Dicamba 0.2 Dicamba
 

40

 

Dichlorvos (c)

 

0.1

sum of Dichlorvos, Naled and Trichlorfon expressed as Dichlorvos
41 Dicloran 0.1 Dicloran
42 Diflubenzuron 0.1 Diflubenzuron
 

43

 

Dimethoate (d)

 

0.5

sum of Dimethoate and Omethoate expressed as Dimethoate
44 Dimethomorph (S) 2 sum of (E)-Dimethomorph and (Z)-Dimethomorph
 

45

 

Disulfoton (S)

 

0.1

sum of Disulfoton, Disulfoton sulfoxide, and Disulfoton sulfone expressed as Disulfoton
 

 

 

 

 

 

 

 

46

 

 

 

 

 

 

 

 

Dithiocarbamates (as CS2) (e)

 

 

 

 

 

 

 

 

5

 

 

 

 

 

 

 

 

Dithiocarbamates expressed as CS2

In countries where fungal diseases such as blue mould are a persistent problem in the field throughout the growing season, the use of dithio- carbamates (DTC) fungicides may be an essential part of the season-long disease management strategy and in keeping with GAP as a means of ensuring crop quality and economic viability for the producer. Under high disease pressure residues of dithio- carbamates (DTC) fungicides slightly in excess of the specified GRL may be observed.   In countries where there is not a field fungal disease problem the use of fungicides is not necessary, and there should be no residues detected. Consistent with GAP, dithiocarbamates (DTC) fungicides must be used only according to label instructions to combat fungal diseases in the seedbed and in the field.

 

No. CPA GRL

(ppm)

Residue definition Notes
 

47

 

Endosulfans (S)

 

1

sum of alpha- and beta-isomers and Endosulfan-sulphate expressed as Endosulfan
48 Endrin 0.05 Endrin
49 Ethoprophos 0.1 Ethoprophos
50 Famoxadone 5 Famoxadone
 

51

 

Fenamiphos (S)

 

0.5

sum of Fenamiphos, Fenamiphos sulfoxide and Fenamiphos sulfone expressed as Fenamiphos
52 Fenitrothion 0.1 Fenitrothion
 

53

 

Fenthion (S)

 

0.1

sum of Fenthion, Fenthion sulfoxide and Fenthion sulfone expressed as Fenthion
54 Fenvalerate (S) 1 Fenvalerate (sum of all isomers including Esfenvalerate)
55 Fluazifop-butyl (S) 1 Fluazifop-butyl (sum of all isomers)
56 Flumetralin 5 Flumetralin
57 Fluopyram (g) 5 Fluopyram
58 Folpet 0.2 Folpet
59 HCH (a-, b-, d-) 0.05 HCH (a-, b-, d-)
60 HCH (g-) (Lindane) 0.05 HCH (g-) (Lindane)
 

61

 

Heptachlor (S)

 

0.02

sum of Heptachlor and two Heptachlor epoxides (cis- and trans-) expressed as Heptachlor
62 Hexachlorobenzene 0.02 Hexachlorobenzene
63 Imidacloprid 5 Imidacloprid
64 Indoxacarb (S) 15 Sum of S isomer + R isomer
 

65

 

Iprodione (S)

 

0.5

sum of Iprodione and N-3,5- dichlorophenyl-3-isopropyl-2,4- dioxoimidazolyzin-1-carboxamide expressed as Iprodione
66 Malathion 0.5 Malathion
 

 

 

 

 

67

 

 

 

 

 

Maleic hydrazide

 

 

 

 

 

80

 

 

 

 

Maleic hydrazide (free and bounded form)

In some instances, where GAP is implemented and label recom- mendations with regard to application rates and timing are strictly adhered to, residue levels may exceed the current GRL of 80 ppm as a result of extreme weather conditions and the current technology available for application. However, as with all CPAs, all efforts should be made to strictly follow label application rates, and use should be no more than necessary to achieve the desired effect.
68 Metalaxyl (S) 2 sum of all isomers including Metalaxyl-M / Mefenoxam
69 Methamidophos 1 Methamidophos
70 Methidathion 0.1 Methidathion
 

71

 

Methiocarb (S)

 

0.2

sum of Methiocarb, Methiocarb sulfoxide, and Methiocarb sulfone expressed as Methiocarb

 

No. CPA GRL

(ppm)

Residue definition Notes
 

72

 

Methomyl (f)

 

1

sum of Methomyl, Methomyl- oxime, and Thiodicarb expressed as Methomyl
73 Methoxychlor 0.05 Methoxychlor
74 Mevinphos (S) 0.04 Mevinphos (sum E and Z isomers)
75 Mirex 0.08 Mirex
76 Monocrotophos 0.3 Monocrotophos
 

77

 

Naled (c)

sum of Dichlorvos, Naled, and Trichlorfon expressed as Dichlorvos  

see Dichlorvos

78 Nitrofen 0.02 Nitrofen
79 Omethoate (d) sum of Dimethoate and Omethoate expressed as Dimethoate see Dimethoate
80 Oxadixyl 0.1 Oxadixyl
81 Oxamyl 0.5 Oxamyl
82 Parathion (-ethyl) 0.06 Parathion
83 Parathion-methyl 0.1 Parathion-methyl
84 Pebulate 0.5 Pebulate
85 Penconazole 1 Penconazole
86 Pendimethalin 5 Pendimethalin
87 Permethrin (S) 0.5 Permethrin (sum of all isomers)
88 Phorate 0.05 Phorate
89 Phosalone 0.1 Phosalone
90 Phosphamidon (S) 0.05 Phosphamidon (sum of E and Z isomers)
91 Phoxim 0.5 Phoxim
92 Piperonyl butoxide 3 Piperonyl butoxide
93 Pirimicarb 0.5 Pirimicarb
94 Pirimiphos-methyl 0.1 Pirimiphos-methyl
95 Profenofos 0.1 Profenofos
96 Propoxur 0.1 Propoxur
97 Pymetrozine 1 Pymetrozine
 

98

 

Pyrethrins (S)

 

0.5

sum of Pyrethrins 1, Pyrethrins 2,

Cinerins 1, Cinerins 2, Jasmolins 1

and Jasmolins 2

99 Tefluthrin 0.1 Tefluthrin
 

100

 

Terbufos (S)

 

0.05

sum of Terbufos, Terbufos sulfoxide and Terbufos sulfone expressed as Terbufos
101 Thiamethoxam 5 Thiamethoxam
 

102

 

Thiodicarb (f)

sum of Methomyl, Methomyl- oxime, and Thiodicarb expressed as Methomyl  

see Methomyl

103 Thionazin 0.04 Thionazin
 

104

 

Thiophanate-methyl (a)

sum of Benomyl, Carbendazim, and Thiophanate-methyl expressed as Carbendazim  

see Carbendazim

 

No. CPA GRL

(ppm)

Residue definition Notes
 

105

 

Tralomethrin (b)

sum of Deltamethrin and Tralomethrin expressed as Deltamethrin  

see Deltamethrin

 

106

 

Trichlorfon (c)

sum of Dichlorvos, Naled, and Trichlorfon expressed as Dichlorvos  

see Dichlorvos

107 Trifluralin 0.1 Trifluralin

 

 

  • Carbendazim is the degradation product of Benomyl and Thiophanate-methyl. In the case the same sample contains residues of both Carbendazim and/or Benomyl/Thiophanate-methyl, the sum of the residues should not exceed 2
  • Deltamethrin is the degradation product of Tralomethrin. In the case the same sample contains residues of both Deltamethrin and Tralomethrin, the sum of the two residues should not exceed 1
  • Dichlorvos is the degradation product   of  Naled  and     In the case the same sample contains residues of both Dichlorvos and/or Naled/Trichlorfon, the sum of the residues should not exceed 0.1 ppm.
  • Omethoate is the degradation product of Dimethoate. In the case the same sample contains residues of both Dimethoate and Omethoate, the sum of the two residues should not exceed 0.5
  • The Dithiocarbamates Group includes the EBDCs: Mancozeb, Maneb, Metiram, Nabam and Zineb – as well as Amobam, Ferbam, Policarbamate, Propineb, Thiram and
  • Methomyl is the degradation product of Thiodicarb. In the case the same sample contains residues of both Methomyl and Thiodicarb, the sum of the two residues should not exceed 1
  • Fluopyram added to GRL list June

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