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


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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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