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Violation Report ID 19C00160“) should be re-tested on a national scale and if they are in violation they should be withdrawn and the manufacturers subjected at least to fines.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