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CDFA May Have Underestimated Toxic Danger of LBAM Pesticides By One Million Times or More

Evaluating the health effects of past and future pesticides applied on and around people to combat the Light Brown Apple Moth (LBAM), three state agencies concluded the potential danger was low because they incorrectly divided instead of multiplying. In their analysis, the agencies divided by the thousands of acres sprayed, when they should have multiplied by the same number of thousands. If only 1,000 acres were involved, the peoples' exposure was as much as one million times greater than reported by the state agencies.

For Immediate Release. Press Release: March 24, 2009 Santa Cruz, California

Contact: Professor Glen Chase Email: glenchase [at] aol.com

Topic: California Department Of Food And Agriculture (CDFA), Light Brown Apple Moth (LBAM).

 CDFA, DUE TO A SIMPLE MATH ERROR, MAY HAVE UNDERESTIMATED THE TOXIC DANGER OF LBAM PESTICIDES ON CALIFORNIA'S POPULATION BY ONE MILLION TIMES OR MORE.

Evaluating the health effects of past and future pesticides applied on and around people to combat the Light Brown Apple Moth (LBAM), three state agencies concluded the potential danger was low because they incorrectly divided instead of multiplying. In their analysis, the agencies divided by the thousands of acres sprayed, when they should have multiplied by the same number of thousands. If only 1,000 acres were involved, the peoples' exposure was as much as one million times greater than reported by the state agencies. [FOOTNOTE #1]

In larger pesticide application areas, which are typical, the error is even greater.

The Reports were prepared by the Department of Pesticide Regulation (DPR), the Office of Environmental Health Hazard Assessment (OEHHA) and the Department of Public Health (DPH). All three joint reports released November 3, 2008, April 10, 2008, and November 16, 2007 contain the same error. [FOOTNOTE #2]

The California Department of Food and Agriculture (CDFA), based on these incorrect reports and their enthusiasm to proceed, gave their assurance to the public that the pesticide applications directly on and around the people and their children were safe.

This extreme error in toxicity exposure could explain why hundreds of people and doctors filed written health complaints following CDFA's application of pesticides on people and their children in Santa Cruz and Monterey Counties in 2007.

The state agency tests acknowledge that the pesticide (including the synthetic pheromone) is toxic and exposure can cause skin, eye and respiratory problems. The state agencies reported: "However, as the product is diluted and applied over a large area, the degree of exposure as well as the potential for irritation should decrease significantly." The state agency conclusion is false. Because the same amount of pesticide is applied to each acre treated, dilution does not occur as area size increases. Pesticide exposure increases, not decreases as the state agencies concluded. [FOOTNOTE #2]

As the product is applied over a larger area, the degree of exposure to the toxicity of the pesticide chemicals as well as the potential for irritation should increase. That is because of the greater likelihood that people will spend more of their time in an infected area. If the spray area were small, it would be likely that only time walking by or driving by was spent in the spray zone. With a large spray area, it is more likely that ones home, work, school and/or shopping would be included in the spray area. At the extreme, if the spray area were large enough to encompass a family's total activities, they would be spending 24 hours per day within the domain of the toxic pesticide zone. Many people who reported illness lived and worked in the toxic pesticide zone. The average exposure to the toxic pesticide for the human population increases as application area increases under every circumstance, not decreases as the state agencies concluded.

The synthetic pheromone that the CDFA said was non-toxic and safe for people and their children ended up testing as a moderate level 3 toxin to the skin (11/3/08 Six-pack test). This indicates a strong likelihood that the synthetic pheromone also causes respiratory problems including wheezing and asthma, but the state agencies intentionally did no inhalation tests for the synthetic pheromone specifically, so no official results exist.

The 11/3/08 Six-pack tests of the pesticides applied on the people also showed lymphocyte proliferation. Lymphocyte proliferation is the immune system rapidly producing and spreading antibodies to attack infected and cancerous cells to attempt to reject foreign tissues.

Children, pregnant woman and their unborn children within the womb are more vulnerable to toxins because of their low body weights, developing organs and low tolerance to toxins. After the CDFA pesticide applications in Santa Cruz and Monterey Counties, children ended up in emergency rooms. One perfectly healthy 11-month-old boy went into respiratory arrest and though his life was saved in a hospital, he now lives with an asthmatic respiratory condition. No one can accurately predict what will happen in five, ten, twenty or thirty years from now to the hundreds of thousands of people and children who were sprayed with the pesticide, because the state agencies did not do any tests on the long term effects before spraying Santa Cruz and Monterey Counties.

Science from top botanists, entomologists, toxicologists, medical doctors, invasive pest biologists and rulings from two superior California courts have clearly indicated that: (1) the Light Brown Apple Moth (LBAM) is not an emergency or a threat to plants or crops in California, (2) LBAM has been in California for many decades, (3) LBAM has done no damage to any plant or crop and (4) LBAM is far too widespread and densely populated to eradicate. Unfortunately, none of this information is included in the CDFA's plans and analysis.

If the CDFA is able to maintain the unnecessary eradication program for LBAM, they can access approximately $500 million of taxpayer emergency funds over five years. This additional windfall to the CDFA equals the dollar amount the CDFA normally receives for their entire budget for two full years. Therefore, it is impossible to get any of the management at CDFA to consider eliminating this toxic and unnecessary eradication program.

 FOOTNOTES: #1 The state should have multiplied by 1,000, but instead they divided by 1,000. Because the agencies divided instead of multiplying, the total error in the toxic exposure to the population, in this case, reflects the state underestimated the toxicity of the pesticide impact on the people by as much as 1,000 X 1,000 = one million times.

#2 Error and false conclusion are identified below in all three joint reports by state agencies:

Page 15, paragraph 1, line 6 11/3/2008 A Review of Acute Toxicity Studies Results on the Light Brown Apple Moth Pheromone Active Ingredient and Four LBAM Pheromone Products (Six-pack test). Department of Pesticide Regulation (DPR), Office of Environmental Health Hazard Assessment (OEHHA), Department of Public Health (DPH). http://www.cdpr.ca.gov/docs/pressrls/lbam/lbam.htm

Page 4, paragraph 1, line 4 4/10/2008 Summary of Symptom Reports in Areas of Aerial Pheromone Application for Management of the Light Brown Apple Moth in Monterey and Santa Cruz Counties September, October, and November 2007. Office of Environmental Health Hazard Assessment (OEHHA), Department of Pesticide Regulation (DPR), California Department of Public Health (DPH) http://www.oehha.org/risk/pdf/LBAM041008.pdf

Page 5, paragraph 2, line 4 10/31/2007 Consensus Statement on Human Health Aspects of the Aerial Application of Microencapsulated Pheromones to Combat the Light Brown Apple Moth. Department of Pesticide Regulation (DPR), Office of Environmental Health Hazard Assessment (OEHHA). This report dated 10/31/07 was released 11/16/07. http://www.lbamspray.com/00_Health/2007/Consensus_Statement_on_Human_Health_Aspects.pdf


Background on Professor Chase:

Glen Chase is a Professor of Systems Management specializing in Environmental Economics and Statistics. Glen served as an Associate Professor teaching graduate level courses in Systems Management at USC for eight years. He has taught at multiple universities in the Central Coast area, including The Naval Post Graduate School, The Monterey Institute of International Studies and Cal State University, Monterey Bay. Glen is also a Management Consultant. Currently, Professor Chase develops management systems to assist organizations that cater to the improvement of life for children with disabilities.

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