As of 2011 Federal law (cited below) specifically forbids tobacco manufacturers from using pesticide contaminated tobaccothat 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Violation Report ID 19C00160“) should be re-tested on a national scale and if they are in violation they should be withdrawn and the manufacturers subjected at least to fines.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 says and means “any tolerance” which 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 tell conducted one inspection of pesticide residue contaminants in cigarettes or any other tobacco product, which means that since 2011 they haven’t prevented one single pregnant teen from inhaling DDT from a Swisher Sweet their older friends bought at the bodega.
There are quite literally thousands of pregnant teens inhaling DDT today in the Us. The reason this is critically important is that DDT is a severe hazard to human fetal development. 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
Hello! This blog post is now part of my newly published ebook “Smoke No Evil“, which is published on Amazon but its available free for the asking to visitors like you – see below.
I here’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.
Just click here to request your free review copy of “Smoke No Evil”. After you read it, I hope that you’ll add your voice to those demanding investigation and accountability for the Tobacco Cartel. My hope is also that the knowledge in this book can be life-changing for smokers who are trapped in addiction to commercial Tobacco Cartel products, and life-affirming for those who already understand and smoke or vape only organic tobacco whenever possible.
Whether you smoke, vape, or chew tobacco this book destroys the myth that tobacco is going to harm you. Using data and hard evidence, this book proves that it’s not tobacco killing millions of smokers every year, and it never has been. You’ll see how the “science” used to prove that Tobacco is a killer is pure fraud and deception on the part of the Tobacco Cartel, and pure hypocrisy on the part of regulators and anti-tobacco propagandists.
My hope is that the knowledge here can be life-changing for smokers who are trapped in addiction to commercial Tobacco Cartel products, particularly people who are members of oppressed minority communities where the damage from pesticides in cheap tobacco products is magnified by genetic vulnerability.
My hope is that the knowledge here can be life-changing for smokers who are trapped in addiction to commercial Tobacco Cartel products.
Hello! This blog post is now part of my newly published ebook “Smoke No Evil“, which is published on Amazon but its available free for the asking to visitors like you – see below.
I here’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.
Just click here to request your free review copy of “Smoke No Evil”. After you read it, I hope that you’ll add your voice to those demanding investigation and accountability for the Tobacco Cartel. My hope is also that the knowledge in this book can be life-changing for smokers who are trapped in addiction to commercial Tobacco Cartel products, and life-affirming for those who already understand and smoke or vape only organic tobacco whenever possible.
Whether you smoke, vape, or chew tobacco this book destroys the myth that tobacco is going to harm you. Using data and hard evidence, this book proves that it’s not tobacco killing millions of smokers every year, and it never has been. You’ll see how the “science” used to prove that Tobacco is a killer is pure fraud and deception on the part of the Tobacco Cartel, and pure hypocrisy on the part of regulators and anti-tobacco propagandists.
My hope is that the knowledge here can be life-changing for smokers who are trapped in addiction to commercial Tobacco Cartel products, particularly people who are members of oppressed minority communities where the damage from pesticides in cheap tobacco products is magnified by genetic vulnerability.
Toxicologists have just designated a new class of chemicals, aptly naming them Obesogens. With chronic exposure, or with exposure before birth at a critical development point, these chemicals initiate body processes that lead directly to childhood, teen and adult obesity and the range of related diseases.
Tobacco products are full of Obesogens, far more of them in far greater concentrations than in any other environmental or consumer product source. Yes Obesogenic chemicals are everywhere, and yes they are in every diet, but their presence as heavy contaminants of tobacco products is a unique kind of hidden health threat whose proportions are unseen.
The data above displays some of the pesticides we just identified in our tests of tobacco brands popular with kids. Our tests were the first ever of off-the-shelf tobacco brands for pesticide Obesogens. We’re especially concerned about the concentrations of some of the azole fungicides we found, in addition to the DDT.
Kids who smoke these tobacco products are being exposed to a pesticide cocktail with each inhalation, 50-100 times a day. This is a level that is unmatched by any other type of exposure to Obesogens or to any class of pesticides. None of the studies of obesogenic chemicals look at what happens to young people who are dosing themselves with a cocktail of these endocrine-disrupting chemicals every waking hour, but it’s pretty easy to see what researchers will find when they do the science.
Here’s some of what is already known.
“Obesogens disrupt the molecular mechanisms controlling the development and maintenance of adipose tissue. This disruption has the potential to produce larger and more numerous fat cells, which could in turn lead to obesity and related complications. Obesogens can also alter programing of metabolic set points, appetite, and satiety.” https://ehp.niehs.nih.gov/doi/full/10.1289/EHP2545
Consider the extreme concentration of DDT we found in the Swisher Sweets (in the data above). This brand is #1 in popularity among child and teen little cigar smokers in marginalized communities. Keeping the Swisher Sweet DDT concentration of 0.816 mg/kg in mind, check this out:
Obesogenic chemicals trigger complex responses by human endocrine and immune systems. Pesticides that persist in body tissues like DDT and Carbendazim are particularly powerful Obesogens that operate 24/7, so even when a child is sleeping these Obesogens are at work deep in their tissues.
Pesticide researchers are hard-pressed to study the effects of a single pesticide thoroughly, and when it comes to the multiplying effects of combined pesticides they pretty much throw up their hands – although they do it sounding very scientific and technical. But whatever brand a child or teen is smoking, when you look at the dozens of Obesogenic pesticides that are being inhaled puff after puff as a toxic cocktail we can be sure that the potential for inflammatory obesity is multiplied.
The cheaper the tobacco product the more Obesogens it has. Notice the progression from American Spirit Blue cigarettes to Swisher Sweet little cigars in the data table above. In a new variation on an old story, the very communities where the cheapest tobacco products are marketed are communities of children and adults who are most genetically vulnerable to inhaled pesticides and their Obesogenic effects. Hispanic, African-American and Native American children and teens seem to be particularly susceptible to Obesogenic chemicals. These communities also have the highest rates of both smoking and obesity. I think we have the connection in Obesogenic pesticides.
Unfortunately all the research on inhaled pesticide exposure so far is either on exposure through diet or through environmental causes – accidental releases, agricultural drift, etc. Nobody has ever studied the health impact of inhaling a pesticide cocktail 50-100 times a day, but when it comes to dosing yourself with Obesogens that sounds like a pretty dramatic way to do it.
Heindel J J, Newbold R, Schug T T.2015. Endocrine disruptors and obesity. Nat Rev Endocrinol 11(11):653–661, PMID: 26391979, https://doi.org/10.1038/nrendo. 2015.163
My concern is that those fruity, sweet, cheap and heavily marketed “Little Cigars” that are especially appealing to Hispanic and African-American children and teens who smoke are the most heavily contaminated with obesogenic pesticides of any tobacco product category we’ve tested so far. Obesogenic pesticides in these cheap tobacco products being marketed to dietarily and genetically vulnerable youth may account for some of the increased incidence of obesity among children and young people in these communities.
Of course, it isn’t just pesticides in cheap tobacco products making poor marginalized people obese – there are obesogenic chemicals in everything that people incarcerated in marginalized communities have available to eat and drink, and in virtually everything in their toxic environment. It’s just that tobacco products are the most concentrated source of the worst possible kinds of pesticides all blended together into a toxic cocktail that you inhale rather than drink, and that as one of its main side-effects makes smokers obese.
Eskenazi B, Chevrier J, Rosas L G, Anderson H A, Bornman M S, Bouwman H, et al. 2009. The Pine River statement: human health consequences of DDT use. Environ Health Perspect 117(9):1359–1367, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2737010/
The big difference between tobacco products as an Obesogenic chemical source and all other sources is that illegal obesogenic pesticides in cheap tobacco products are 100% preventable as a contributing factor to childhood obesity.
Kids are being subjected to these hidden, unregulated obesogenic chemicals for just one reason – they mean higher profits for the tobacco manufacturer. Tobacco companies take the cheapest possible tobacco trash swept up off the dirt floors of their factories in Third-World countries and ship it to the US by the freighter-load to make into those sweet, fruity little treats that teens love to smoke. (What happens to the actual tobacco leaf is another long story.)
More importantly, the obesogens in tobacco products are inhaled, not eaten. This is absolutely critical. All the research on the toxicity of pesticides shows much higher toxicity for the most hazardous chemicals when inhalation is the route of exposure, even though there is no research on what happens when pesticides are inhaled regularly every day, every waking hour.
Roots Of The Atrocity
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 every kind of sugar and high-quality protein that every bug, animal and worm in nature is irresistibly drawn to munch on those extremely tasty, extremely valuable tobacco leaves. So, for centuries growing tobacco meant prodigious hand labor in the tobacco fields day and night by black and brown people, with great wealth accruing of course to White people who used that wealth as the basis for early American economic development, and for hundreds of years Tobacco steadily built the foundation of American wealth along with cotton, sugar and alcohol of course.
But all that tobacco wealth, with all the power that it conveyed, wasn’t a real industry until agricultural chemicals came along, and then when they did tobacco was one of the earliest and strongest adopters of pesticides. That was because they saw immediately that $100 worth of chemicals could increase profits $500 an acre because of the extra tobacco not eaten by bugs, and $10,000+ for the manufactured products from that extra tobacco. So really, from the tobacco companies’ point of view, using those chemicals was and still is largely a business decision. If smokers die early well, that’s why they advertise so heavily to kids. The industry actually uses the term “Replacement Smokers”.
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.
Those little cigars that are being marketed so successfully to young Latino and Black kids are loaded with the residues of the chemicals used to control bugs on the tobacco because they are made with the waste from higher quality tobacco products made for sale in wealthier communities. Tobacco leaf, which is relatively less contaminated then the trashy parts of the plant, goes into the expensive cigarettes. Again, check the data at the top of the post and ask yourself – which gets sold at the suburban mini-mart and which gets sold at the bodega?
White smokers get to choose the cleaner, higher quality tobacco leaf if they’re informed enough to do so while Black and Latino smokers get little cigars made with the trash swept up off the tobacco factory floor and don’t have any choice except other equally contaminated cheap shit.
Here’s why the trashy parts are the most contaminated parts of the plant. The tobacco industry pays huge bucks to its scientists to design chemicals that will kill the bugs on the tobacco leaves and then trans-locate into the stems, stalks and roots of the plant so that they don’t affect the flavor of that precious tobacco leaf that’s going into the premium smokes. The contaminated trash parts of the tobacco plant – after the leaf is removed – is what goes into making all those cheap, fruity smokes that poor Black & Latino kids are being trained to love.
So that’s it. Poor young Black and Latino people who fall for the tobacco companies’ propaganda are being sickened, poisoned and made morbidly obese all simply because the tobacco companies can make more money using chemicals that happen to be Obesogenic, and carcinogenic, and teratogenic, and just plain xenobiotic on their crops that they don’t have to account for when they are selling their trash to kids in poor communities around the world.
It doesn’t really matter to the tobacco companies if their smokers get sick and obese and diabetic and have cancer and die young as long as they (1) keep smoking and (2) create at least a couple of replacement smokers before they die. It’s all just a numbers game to them.
But as for us? All it will take to answer this arrogance with finality is for one communities to act to investigate their local tobacco product supply. Then if they find it contaminated, and especially if some of that contamination is from banned substance like DDT, they can then pass local ordinances that impose reasonable pesticide residue standards on tobacco products being sold in their community.
If a child struggling with obesity has a smoking mother, both mother and child should be tested for Obesogenic pesticide poisoning which if found could lead to treatment. Anyone struggling with obesity who smokes, especially little cigars, should get their blood tested for Obesogenic pesticides. As long as the body is carrying a burden of Obesogenic chemicals, especially if they’re being constantly replenished by smoking or breathing second-hand smoke, no amount of dieting, pharmaceuticals or surgery will help.
I believe that those states where Cannabis is legal and where pesticide residue standards have already been put in place with lots of careful consideration will be the first where communities will insist on these reasonable standards. Our federal and state agencies and legislators have largely been compromised by tobacco industry stealth tactics over the past 50 years of carefully tended regulatory loopholes, exemptions and curious omissions. Local community officials have not been so compromised because the tobacco industry likes to work from the top down – they think of themselves as too wealthy and powerful to be accountable.
They just haven’t met the right Justice of The Peace or Magistrate yet who has a dear niece who can’t stop smoking Swisher Sweets and who is obese, diabetic, and has one child with leukemia and another with ADHD. Show the judge that list of Obesogenic and Xenobiotic pesticides in what his niece has been smoking and ask him if he’s OK with that.
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.
(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
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.
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”.
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.
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.
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.
