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


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Ancestral DDT Exposure & Trans-generational Obesity

The data and research studies we’ll look at in this post offer evidence that many, many millions of people today who are suffering from obesity may have a problem that, for those with a specific kind of family history of smoking, is totally independent of their diet or other behavior. In other words they aren’t eating or doing anything that can completely explain their obesity, but they are suffering, getting sick and dying of it. They may not be able or choose to eat the best diet, and they may not be able to live in the healthiest environment, but do those factors explain what’s causing their obesity enough that we can say “case closed”?

The newest research (shown and linked-to below) says the case is far from closed. It is linked to hidden endocrine disrupting pesticides including heavy DDT in the tobacco products smoked by women in the 1955-1980 time period. And by the way, knowing that pesticide damage may have been done to your mother or grandmother by constant DDT exposure, and that you were exposed before and maybe after birth, may lead your doctors today toward thinking about new ways of helping you.

So this post and these ideas aren’t just about raining awareness of the terrible things that smoking did to mothers and grandmothers of today’s generations, it’s about how knowing what what was done can help us do what we need to do to repair the damage if that’s possible.

To begin with, we have a study that shows us, although that was not the researcher’s objective, that people suffering from obesity today had mothers or grandmothers who were exposed. Not exposed by smoking – nobody knew that or even admits it today. But because as we’ll see shortly cigarettes were loaded with DDT in the period 1955-1980, people struggling with obesity today may well be the victims of DDT in the cigarettes their mother or grandmother smoked in 1970. DDT is now classified along with a number other supertoxic pesticides as an Obesogena chemical compound that causes obesity with the right exposure. It was a hidden but heavy contaminant of the tobacco product supply in those days, along with other supertoxic organochlorines including Endrin, Aldrin, Dieldren, Heptachlor, and Chordane.

This means that that people born to mothers who smoked 1955-1980, or to mothers whose own mother smoked 1955-1980, are at higher risk of transgenerational obesity just from that factor, exposure to DDT in the womb, even without any further exposure. In utero DDT exposure at just the wrong point in the unfolding tissues of the fetus, causes specific DNA damage that extends well beyond obesity in the later life of the unborn child  to include multiple kidney, prostate, testicular and ovarian diseases and several specific cancers including breast cancer and childhood leukemia.

Here is a data table from a confidential internal RJ Reynolds Tobacco Company that shows the levels of DDT contamination of their three most popular brands. Virtually any woman smoking an RJ Reynolds brand in those years, and earlier, was inhaling DDT at these levels. If she was pregnant, her child was exposed at precisely the right point to initiate the obesogenic process because even if she didn’t smoke every day of her pregnancy DDT lingers and accumulates in organs and fatty tissues. Her babies would have been exposed, and the transgenerational process initiated.

RJR Confidential June 21, 1972

Project 2358 – Cigarette Development; Notebook Pages: 250701-250719

In The Cigarette

DDT – Range PPM (20 samples)

DDT – Avg PPM (20 Samples)

4841 – Regular Unfiltered

4.14 – 7.96

6.06 +/- 0.99

4842 – Filter King

3.38 – 6.65

4.95 +/- 0.90

4843 – Filter King

4.86 – 6.82

5.89 +/- 0.61

In The Cigarette Smoke

4841 – Regular Unfiltered

0.35 – 0.57

0.42 +/- 0.06

4842 – Filter King

0.16 – 0.35

0.025 +/- 0.05

4843 – Filter King

0.24 – 0.46

0.35 +/- 0.05

I hope that this information can empower people suffering from obesity or any of the other diseases now associated with transgenerational effects of DDT exposure to seek alternative treatments and therapies that may help in ways not being addressed by Western Allopathic medicine as represented by the US FDA, which actively rejects responsibility for regulating pesticide contamination of tobacco products. FDA simply refuses to so so, and there can only be one reason for that. Only one.

Ancestral dichlorodiphenyltrichloroethane (DDT) exposure promotes epigenetic transgenerational inheritance of obesity

BMC Medicine 2013 11:228

Background

Ancestral environmental exposures to a variety of environmental factors and toxicants have been shown to promote the epigenetic transgenerational inheritance of adult onset disease. The present work examined the potential transgenerational actions of the insecticide dichlorodiphenyltrichloroethane (DDT) on obesity and associated disease.

Conclusions

Observations indicate ancestral exposure to DDT can promote obesity and associated disease transgenerationally. The etiology of disease such as obesity may be in part due to environmentally induced epigenetic transgenerational inheritance.

Here is direct evidence that smokers of at least brands of RJR cigarettes were exposed to DDT with each puff they took before, during and after pregnancy. I have a copy of the original report found in the Tobacco settlement files. Here are the important data.

RJR Confidential June 21, 1972

Project 2358 – Cigarette Development

Notebook Pages: 250701-250719

In Cigarette

DDT – Range PPM (20 samples)

DDT – Avg PPM (20 Samples)

4841 – Regular Unfiltered

4.14 – 7.96

6.06 +/- 0.99

4842 – Filter King

3.38 – 6.65

4.95 +/- 0.90

4843 – Filter King

4.86 – 6.82

5.89 +/- 0.61

In Cigarette Smoke

4841 – Regular Unfiltered

0.35 – 0.57

0.42 +/- 0.06

4842 – Filter King

0.16 – 0.35

0.025 +/- 0.05

4843 – Filter King

0.24 – 0.46

0.35 +/- 0.05

This level of contamination was universal in 1972, and included many other organochlorines that RJR didn’t test for – at least not in this report. But tobacco products in those days were heavily contaminated with the whole range of OC pesticides including Endrin, Aldrin, Dieldrin, Chlordane, and many others whose impact on human health have never been studied.

This also means that people who themselves smoke or use DDT contaminated tobacco products today are reinforcing the transgenerational effects of DDT exposure by their mother or grandmother. It’s also important to say that the tobacco products with the highest levels of DDT today are those being smoked by poor, marginalized Hispanic, African American and Native American youth.

Obesity is one of the known effects of current DDT exposure, so as long as this synergistic pathway goes unrecognized in our understanding of obesity the opportunities for successful healing will be unnecessarily limited. A good first step would be to remove all tobacco products contaminated by high levels of DDT from the market.

This study of transgenerational effects of exposure to DDT ought to provoke questions about what the tobacco manufacturers knew in 1972, or earlier, or afterwards about organochlorine pesticides in their products.


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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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Prostate Cancer & Tobacco Pesticides: The Hidden Connection

There doesn’t seem to be any question about the connection between pesticide exposure of agricultural workers and prostate cancer. We know that this kind of exposure leads to prostate cancer, and we know which pesticides are the causal agents.

Through new research that we have just completed, we can also now identify specific pesticides that are known to cause prostate cancer that contaminate specific tobacco products. This means that a whole new connection between smoking and prostate cancer starts to emerge. 

We can see that specific pesticide contaminants of tobacco products are the same pesticides that have been shown to cause prostate cancer in exposed farm workers. (I discuss farm worker exposure vs smoker exposure below.)

Check out this data from lab tests we’ve just finished running on off-the-shelf tobacco products. Notice the totally illegal and banned worldwide DDT. Notice all the Azole fungicides like Penconazole. Check that amazing concentration of Cypermethrin. But really, with 0.816 mg/kg of DDT in every puff, all day every day, what other direct linkages to prostate cancer would you need? How about that 0.843 mg/kg of Carbenzadim, banned in the EU since 2014.

We are sadly confident that the entire tobacco product supply in the US will prove to be similarly heavily contaminated. We plan to test as many brands as possible as soon as funding becomes available. But here’s what we’ve found so far.

Community Tobacco Control Partners Test Results 12/18

Farm workers are exposed heavily to known prostate carcinogens regularly during certain parts of the year, whereas smokers of the brands shown above are inhaling known prostate carcinogens 50-100 times a day and more, year-round. So we are looking at two kinds of exposure – heavy during the season for farm workers, and low-level 7/365 for smokers. Intermittent mid-level exposure vs chronic low-level exposure. Also the farm workers are being exposed to one chemical at a time where the smoker is getting a toxic cocktail. Then of course there are farm workers who smoke the cheap tobacco brands like little cigars because that’s all they can afford. Double or triple whammy there. 

One thing that needs special attention with this new connection is the clear evidence that a smoker with prostate cancer risks that cancer turning very aggressive if it feeds on DDT and other endocrine-disrupting pesticides, which we can now show are just what that aggressive cancer is getting with every puff. Doctors see this happen in relapsing patients and know that it’s connected with their smoking but can’t explain why it’s happening. 

Here’s the message: If you stop feeding that thing in your prostate the chemicals that turn it aggressive maybe it will calm down and maybe you and the docs can get it under control.

So, here are a few key references. There are plenty more – it just depends on how much convincing anyone needs.

Rev Environ Health. 2016 Sep 1;31(3):311-27

Exposure to pesticides and prostate cancer: systematic review of the literature.

Results: The review included 49 studies published between 1993 and 2015. All studies were in English and analyzed exposure to pesticides and/or agricultural activities. Most studies (32 articles) found a positive association between prostate cancer and pesticides or agricultural occupations, with estimates ranging from 1.01 to 14.10.

So, what if tobacco products were loaded with pesticides but nobody knew about that contamination, so even though they knew there was a link between smoking and prostate cancer they didn’t know why? Would that show up in smoking & prostate cancer studies? Well, it seems that it might.

Eur Urol Focus. 2015 Aug;1(1):28-38.

Smoking and Prostate Cancer: A Systematic Review

CONCLUSIONS:

Data from the peer-reviewed literature suggested an association of smoking and aggressive PCa. Although the pathophysiology underlying this association remains unclear, smokers presented higher PCa mortality and worse outcome after treatment. Smoking-cessation counseling should be implemented for patients with PCa, although its effect on PCa progression should be investigated.

OK, but how do we know that the pesticides in tobacco products have anything to do with prostate cancer? Well, first, pesticides used in tobacco are heavily used throughout agriculture. Second, we know that at least two of the contaminants of the little cigar we tested are potent human carcinogens and one acts specifically on human testicles. Now your testicles aren’t your prostate, but that’s getting close enough to merit a second glance if you’re a smoker, don’t you think?

https://pubchem.ncbi.nlm.nih.gov/compound/Carbendazim#section=GHS-Classification

“Carbendazim is a broad-spectrum benzimidazole antifungal with potential antimitotic and antineoplastic activities. Although the exact mechanism of action is unclear, carbendazim appears to binds to an unspecified site on tubulin and suppresses microtubule assembly dynamic. This results in cell cycle arrest at the G2/M phase and an induction of apoptosis.”

Oh, and that other carcinogen – the one that directly impacts your prostate?

Chemico-Biological Interactions

Volume 230, 25 March 2015, Pages 40-49

p,p′-Dichlorodiphenyltrichloroethane (p,p′-DDT) and p,p′-dichlorodiphenyldichloroethylene (p,p′-DDE) repress prostate specific antigen levels in human prostate cancer cell lines

“Thus, we conclude that men who have been exposed to either DDT or DDE may produce a false-negative PSA test when screening for prostate cancer, resulting in an inaccurate clinical diagnosis. More importantly, prolonged exposure to these anti-androgens may mimic androgen ablation therapy in individuals with prostate cancer, thus exacerbating the condition by inadvertently forcing adaptation to this stress early in the disease.”

These are farmers, not smokers, but their prostate didn’t like the DDT exposure and neither will the prostate of anyone who inhales pesticide-contaminated tobacco product smoke (or vapor).

Prostate. 2011 Feb 1;71(2):168-83.

Prostate cancer risk and exposure to pesticides in British Columbia farmers.

“The significant association between prostate cancer risk and exposure to DDT (OR = 1.68; 95% CI: 1.04-2.70 for high exposure), simazine (OR = 1.89; 95% CI: 1.08-3.33 for high exposure), and lindane (OR = 2.02; 95% CI: 1.15-3.55 for high exposure) is in keeping with those previously reported in the literature.

If you keep smoking things just get worse; if you quit after 10 years the risk disappears. But if you are going to keep smoking at least pay attention to the pesticides that you’re inhaling and choose the least contaminated brand possible.

European Urology, December 2015, Volume 68, Issue 6, Pages 949–956

Association of Cigarette Smoking and Smoking Cessation with Biochemical Recurrence of Prostate Cancer in Patients Treated with Radical Prostatectomy

We investigated the effect of smoking on the risk of prostate cancer recurrence in patients with treated with surgery. We found that former smokers and current smokers were at higher risk of cancer recurrence compared to patients who never smoked; the detrimental effect of smoking was mitigated after 10 yr or more of smoking cessation.

I’m not writing this post as a science paper – I’m writing it to point out a connection that is as obvious as it is hidden, and hoping that the message will reach people who can benefit. The message to smokers is that if you are going to smoke, pay close attention to the contaminants in your brand and stop feeding your cancer with banned pesticides. I know this is heresy but – if you’re going to keep smoking than at least smoke American Spirit organic tobacco. Fair disclosure – I invented American Spirit but lost the company to the tobacco industry not long after we started and I have absolutely no connection of any kind to the company. I don’t benefit in any way from anyone choosing American Spirit. Well, actually, the benefit I get is the only one I want, which is knowing that I may have made a contribution to the health and happiness of another person.

 


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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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Tobacco Product Risk Reduction

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

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

To: US FDA December 4, 2018 via Comment Portal

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

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

FDA Comment Submission

I am concerned that

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

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

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

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

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

Discussion

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

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

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

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

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

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

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

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

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


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

Banned Pesticides In Tobacco Products – Background

The tobacco industry is extremely careful not to allow (more on that later) studies of pesticide residues on its cigarette products in any country but particularly in the US. The industry is exquisitely aware that if the extent of this chemical contamination were known, particularly the presence of multiple banned organochlorine pesticides in their products, then especially at the state and county levels public health officials and regulators would have no choice but to call an end to industry’s game.

And then there would also be a brand new basis for some hefty civil lawsuits as well as domestic and international criminal charges for everything from negligence to genocide.

About time too, don’t you think?

So here’s an outline of the issue and why I think it represents a new broad area for regulatory control of the harm being done by Tobacco products. I would love to hear from organizations with a Tobacco product control agenda who would like help in crafting a local strategy of pesticide residue identification – we have fully certified high-level labs here in Oregon with experience in Tobacco testing that are ready to help.

European regulators in several countries, notably Germany, and acting through the EU Commission as a whole, are already way ahead of the US in identifying and regulating the public health threat caused by pesticide residues in Tobacco products. But, because of the tight control that the Tobacco industry has over the US media, Americans who are casually consuming “the news” will NEVER hear about these controls on pesticide contamination. And because of the control that the Tobacco industry has over the US scientific and medical communities, you will NEVER find that anyone in the entire anti-tobacco movement has ever spent a few hundred bucks and tested some off-the-shelf Tobacco products for pesticide residues. Go ahead – Google away. It’s just not there. 

Does that strike anyone other than me as a bit odd?

That tight grip on public knowledge, by the way, comes from clandestine financial controls,  domination of advertising, hidden ownership of important media, and co-opted journalists at every level of every important media player.  To the Tobacco industry, this is all a game-planned process.

That may sound like a cold-blooded way to refer to the slaughter of untold millions of people across generations of smokers and their families, but you can be certain that as far as the tobacco industry is concerned it’s a game, and when it comes to money they are definitely cold-blooded, and they’re playing for keeps.

The Smoking Gun

As you read this please keep in mind that all it took to bring down Al Capone was one small tax evasion charge that the feds could make stick. 

So. There has only been one small study of pesticides in actual commercial cigarettes since the 1970’s, but if that study is at all representative of the state of the 2018 commercial cigarette market (parenthetical comment – it is, as you’ll see documented later) then regulators worldwide ought to be pulling cigarettes from shelves and running them through pesticide testing. Don’t you think?

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

I can hear the Tobacco science flacks now. “Well,  that data is from 2003. That was 15 years ago. And besides those pesticides aren’t permitted on tobacco anymore.”

Oh, really?

So, you would think that if nasty old Endosulfan, Heptachlor and 4,4-DDE, and a whole lot more organochlorine and organophosphate pesticides weren’t being used on tobacco anymore then the tobacco industry scientific organization CORESTA wouldn’t be publishing “good practice” guidelines updated June 2018 that lists acceptable limits on them – right?

https://www.coresta.org/agrochemical-guidance-residue-levels-grls-29205.html

Well, just because the tobacco industry chooses to publish good practice limits on those banned pesticides, that doesn’t mean they are still being used – right? When you read the document it is absolutely clear – these pesticide residues are being detected in Tobacco and Tobacco products worldwide and the industry is worried enough to publish “good practice” and “stewardship” guidelines, including guidelines for dozens of pesticides that are banned because chronic exposure in any amount is hazardous – like through a few hundred puffs of Tobacco product smoke or vapor a day.

Also if you open that CORESTA link above, please notice their innocent little qualifying remark:

“The GRLs are applicable to cured tobacco leaf while focusing on processed tobacco leaf which is predominantly used for the production of traditional cigarette tobaccos and the GAPs associated with the cultivation of these tobacco types.”

In other words we are just going to ignore the issue of pesticide residues on Tobacco stems and trash, which we know are present in higher concentrations than on the leaf, because we don’t want to raise that particular issue.

How We Know Brazilian Tobacco Is Widely Contaminated

With that hidden public health issue in mind, let’s look at pesticide use on tobacco in Brazil – as good a place to start as any. We could look at dozens of other countries, but Brazil is the biggest exporter of tobacco to the US. 

First, note that Brazilian tobacco uses twice as much pesticide per hectare as the next biggest user, cotton, and three times as much as soybeans. That is significant – it means that Brazilian Tobacco plants are drenched with these chemicals.

That’s how we know beyond reasonable doubt that Brazilian Tobacco waste exports to the US are contaminated, and probably very heavily contaminated. That doesn’t worry the US Tobacco companies because nobody is watching what they do except for their own people, a few corrupt officials, and some piss-ant regulations that aren’t enforced and don’t matter.

Well, OK. So tobacco uses a lot of pesticides. That doesn’t necessarily mean they are using banned pesticides, or pesticides known to be dangerous if inhaled even in small doses on a chronic basis.

Actually, they are. If you click here and are a patient reader there’s all the evidence you’ll ever need that tobacco from Brazil is lethal – and not because it’s tobacco.

That link is a pretty detailed research piece that looks at the health impact of pesticides on tobacco farmers in Brazil, and in the process it talks in detail about the pesticides they are exposed to. Of course, these are the same pesticides whose residues wind up on Brazilian tobacco. Check it out.

So, it’s clear that a great many pesticides being used on tobacco in Brazil. This isn’t the only piece of evidence, by far. When you look at all the evidence, it is clear that banned organochlorine and organophosphate pesticides are being used intensively on Brazilian tobacco as recently as early 2018.

The reason that’s important is that all of the trash from the Brazilian tobacco industry – not the tobacco leaf, but the stems and waste from the factory floors – winds up being shipped to the US for manufacturing into American cigarettes. That tobacco trash and stems is if anything more heavily contaminated with pesticides than the tobacco leaf (because it includes systemic pesticides), which is kept in Brazil and Argentina for making cigarettes out of real leaf tobacco – the kind demanded by smokers in Latin America.

The contaminated tobacco trash is sent to the US, and look who’s bringing it in. (We’ll get to why in a minute.)

That’s a whole lot of tobacco trash, isn’t it? Well, those are only the records of two shipments of toxic waste brought to the US by Big Tobacco. There are plenty more. Now, let’s talk about why they are bringing in all those tobacco stems from Brazil and other waste dumps on the planet.

How Brazilian Nerve Poisons Get Into Those Marlboros, Camels etc.

It’s really pretty simple. The tobacco industry figured out years ago that American smokers didn’t really care what they were smoking, and since the tobacco companies could sell the actual leaf to Europeans and Latin Americans who cared, why not use all those stalks and stems and trash that they were just throwing away and figure out how to make cigarettes out of it?

Here’s a short video by Philip Morris showing in detail how they take tobacco waste and turn it into cigarettes. They treat this process as though it is a miraculous achievement. While you watch how this cigarette giant makes fake tobacco for American smokers, remember those pesticide residues on those millions of pounds of Brazilian tobacco waste they’re grinding up and bragging about.

There is major deception at @ 2:11-20. Can you can spot it now that you know about the pesticide residues in that trash they’re turning into cigarettes?

Click here for the video.

At this point you may be asking what contaminated Brazilian tobacco trash has to do with where we started – banned pesticides in commercial cigarettes in Europe, including two prominent American brands.

The relevance is that the banned pesticides in those 2003 EU cigarettes got into them exactly the same way that banned pesticides are getting into every US cigarette manufactured with Brazilian tobacco stems and trash in 2018.

The tobacco stems and trash that are being exported from Brazil ( and other countries, but Brazil is the biggest US supplier) to Europe and to America are used for the same thing – to make fake tobacco cigarettes chock full of invisible poisons on that waste Tobacco just like in the Philip Morris video above. Philip Morris, RJR and the others know for a fact that their manufacturing materials are contaminated with banned toxic substances, and they may even quietly test for some of these poisons, but they have never issued a recall for a single batch of Tobacco products which they would have a positive duty to do if banned pesticide residues were detected.

So What Can Be Done?

Quite a bit, actually. In a coming post I’ll link you to peer-reviewed journal research that demonstrates the level of public health threat presented by these hidden toxic substances, and I’ll share with you the results of a little public health effort here in Portland to test off-the-shelf Tobacco products being sold locally whose origins can be traced to imported Brazilian Tobacco waste. Stay tuned for what I expect to be some interesting results.

Meanwhile if you like what I’m trying to do here, please hit that little donate button below and drop a thank you on me. I would appreciate knowing that you care about the work I’m doing.

 

 

 

 

 


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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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