Ruckelshaus, Sweeney and DDT – rescued from the archives, for the record

January 14, 2020

Years ago Jim Easter tracked down the actual decision document from EPA’s Administrative Law Judge Edmund Sweeney, in which detailed his findings from the months of hearings at EPA on whether to pull registration as a pesticide from DDT.

Masthead and first few sentences of Jim Easter's late, lamented blog Some Are Boojums, and his 2007 post on EPA Administrative Law Judge Edmund Sweeney's decision on DDT labels after several months and 9,000 pages of hearings.
Masthead and first few sentences of Jim Easter’s late, lamented blog Some Are Boojums, and his 2007 post on EPA Administrative Law Judge Edmund Sweeney’s decision on DDT labels after several months and 9,000 pages of hearings.



It was great sleuthing, taking him through several EPA regional libraries, for a document that just falls into the cracks of most history of environmental law, DDT and regulation.

Jim posted the document at his blog, Some Are Boojums, and linked to his .pdf of the document. A great historical record.

Then his blog went out of commission, then it came back. And now, it’s gone again.

Meanwhile, I’d linked to the post, and have over the years sent a few hundred people to the old blog to find the .pdf and read Jim’s write-up of EPA’s hearings, findings and effects.

Some time in the late-Bush/early-Obama years EPA posted a copy of Judge Sweeney’s decision. That disappeared with the Trump administration, and I’ve not found it anywhere.

So to defend myself, make linking easier, and to aid any stray researchers who are having difficulty finding Judge Sweeney’s real decision, perhaps to debunk the pro-DDT lobbyists’ shouting that Sweeney said DDT is perfectly safe and should be used to bath every newborn, I’ve recaptured Jim Easter’s post from Some Are Boojums, and put it all here.

Warning: I’ve not rejiggered any links. I suspect many of them have gone sour. I may come back to fix a few, but you should know that at one time they all worked well.

Comments were quite lively, but I haven’t quite figured out how to post them; that may come later, or it may not.

Judge Sweeney’s decision? Full text here: Sweeney decision.

After all that ado, here’s Jim Easter’s post:
______________________________________________________________

Ruckelshaus, Sweeney and DDT

On June 2nd, 1972, William D. Ruckelshaus, Administrator of the Environmental Protection Agency, issued an order effectively ending the agricultural use of DDT in the US.

Thirty-five years later, that order is still the subject of fierce controversy.

One claim often made by proponents of renewed DDT use is that Ruckelshaus’ decision was capricious and unsupported by the evidence — specifically, that he acted in willful disregard of his own hearing examiner’s findings. For example, in a post co-authored[1] with the late J. Gordon Edwards, Steven Milloy states that Ruckelshaus “ignored the decision of his own administrative law judge.”[2]

Milloy’s distortion of the history and science surrounding DDT is shameless, and deserves to be the subject of a separate post. But let’s stick with the Ruckelshaus order for now.

Did Ruckelshaus ignore the conclusions of his hearing examiner? You’d think, since this claim is made so relentlessly by DDT advocates, that we could find the relevant document somewhere on the Web. But it’s not that easy. Ruckelshaus’ order itself is readily available (see below for a more readable copy), but the hearing examiner’s findings … not so much. The document is sometimes cited as “Sweeney, E.M., 1972. ‘EPA Hearing Examiner’s Recommendations and Findings Concerning DDT Hearings,’ April 25, 1972. 40 CFR 164.32.” — which helps a bit, but only a bit, since “40 CFR 164.32″ is just the Federal Regulation governing administrative hearings at EPA. Anyone who offers that to you as an actual cite for the opinion is blowing smoke. A better cite is the one given in the order, viz.: “Stevens Industries, Inc. et al., I.F&R. Docket Nos. 63 et al. (Consolidated DDT Hearings)”. But even that will not get you anything online. EPA does give its Decisions and Orders online, but only back to 1989. A good deal of fruitless searching convinced me that the Sweeney opinion would not be mine with the click of a mouse; it was old-school or nothing. After several weeks, a dozen or so phone calls and the help of some very nice university librarians, I was able to get my hooks on all 173 glorious manually typewritten pages of Edmund M. Sweeney’s “Recommended Findings, Conclusions and Orders.”

Here it is. (56 Mb pdf!) EPA’s librarians indicated that they would not post it online, because of the wretched quality. I’m not so picky. While we’re at it, here is a (slightly) more readable copy of Ruckelshaus’ order.
(UPDATE: See [4] below.)

The following are some of the more notable things we can observe if we look at both documents:

Did Sweeney’s findings generally support the Petitioners (DDT registrants)?

Yes. Sweeney found no evidence to indicate that DDT causes mutations or birth defects in humans, considered the evidence for DDT’s carcinogenicity in humans to be inconclusive, and, though he found that DDT is harmful to wildlife, he deemed that harm to be outweighed by DDT’s value as a pesticide. Sweeney’s findings of fact are summarized in pages 91-92, and his conclusions of law in pages 93-94. Milloy quotes (#17) part of those conclusions:

The EPA hearing examiner, Judge Edmund Sweeney, concluded that “DDT is not a carcinogenic hazard to man… DDT is not a mutagenic or teratogenic hazard to man… The use of DDT under the regulations involved here do not have a deleterious effect on freshwater fish, estuarine organisms, wild birds or other wildlife.”

That partial quote is misleading. Sweeney also found (p. 92) that

20. DDT can have a deleterious effect on freshwater fish and estuarine organisms when directly applied to the water.

21. DDT is used as a rodenticide.

22. DDT can have an adverse effect on beneficial animals.

23. DDT is concentrated in organisms and can be transferred through food chains.

It is not true that Sweeney found no harm caused by DDT. Rather, he found that, using a “preponderance of the evidence” test, DDT users and USDA had shown that DDT’s usefulness to agriculture outweighed the demonstrated harm.

Did Ruckelshaus ignore Sweeney’s opinion?

No, but he disagreed with substantial portions of it. Ruckelshaus quotes extensively from Sweeney’s opinion, including the findings of fact and conclusions of law noted above. He repeats arguments made by the petitioners, and describes how he differs. Choosing one example:

Group Petitioners and USDA argue that the laboratory feeding studies, conducted with exaggerated doses of DDE and under stress conditions, provide no basis for extrapolating to nature.
They suggest that the study results are contradictory and place particular emphasis on documents which were not part of the original record and the inconsistencies in Dr. Heath’s testimony as brought out during cross-examination. Group Petitioners also contend that the observed phenomenon of eggshell thinning and DDE residue data are tied by a statistical thread too slender to connect the two in any meaningful way.

Viewing the evidence as a total picture, a preponderance supports the conclusion that DDE does cause eggshell thinning. Whether or not the laboratory data above would sustain this conclusion is beside the point. For here there is laboratory data and observational data, and in addition, a scientific hypothesis, which might explain the phenomenon.

This is exactly the kind of language that sent J. Gordon Edwards ballistic (detailed discussion reserved for another post). Then as now, DDT advocates felt that the existence of studies with negative results created enough doubt that a ban could not be justified. Ruckelshaus felt just the opposite — that the bulk of the evidence supported a ban — and explained why. For eggshell thinning, 35 years of research have shown that Ruckelshaus was right. A follow-up report issued in 1975 cited 179 studies related to eggshell thinning alone (pp. 69-81). Today, a quick check of PubMed for “ddt eggshell” turns up 50 papers since 1969, and it is clear from the abstracts that the association of thinning and DDT is well established. Bald eagle populations have rebounded since the DDT ban, so successfully that they are now delisted as threatened, a result accepted matter-of-factly by wildlife biologists as a benefit of the DDT ban.

How did Ruckelshaus’ order differ from Sweeney’s recommendation?

One word: cotton. Sweeney ruled on six separate applications for DDT registration, affirming the cancellations for two, vacating the cancellations for three, and allowing a sixth to start the application process. Two of the cases where Sweeney restored the DDT registration were for public health uses: Wyco’s for treatment of mosquito larvae and Eli Lilly’s for use against body lice. Ruckelshaus permitted both applications, as well as public health use of DDT generally, but required a label restricting it to that use. As to DDT’s application worldwide against malaria (the topic of so much dispute nowadays), Ruckelshaus took pains to say that he was not restricting it:

It should be emphasized that these hearings have never involved the use of DDT by other nations in their health control programs. As we said in our DDT Statement of March, 1971, “this Agency will not presume to regulate the felt necessities of other countries.” (p. 26)

The remaining case in which Sweeney vacated the cancellation of DDT registration, permitting its use, was a biggie: USDA and Group Petitioners (31 users of DDT). These had argued collectively that DDT was “essential” for economical production of various crops and control of pests such as the spruce budworm. Of these applications, by far the most important was cotton production, accounting for at least half of all DDT consumption in the US[3]. Other crops were discussed, with sweet peppers in the Delmarva peninsula used as an example. In his order, Ruckelshaus carved out specific exceptions for several crops where DDT was considered the only acceptable alternative, and said that

… if these users or registrants can demonstrate that a produce shortage will result and their particular use of DDT, taken with other uses, does not create undue stress on the general or local environment, particularly the aquasphere, cancellation should be lifted.

The fact that a few loopholes were left open for a while does not change the fact that Ruckelshaus intended to eliminate use of DDT on crops in the US, and his order did have that effect. Even for the “essential” uses, alternatives were found and DDT was dropped. The largest impact of the order was on cotton production. And this is where it gets even more interesting. One of Sweeney’s conclusions of law (p. 94) was that

13. The use of DDT in the United States has declined rapidly since 1959.

The EPA’s 1975 report gives a table (p. 149) that I’ve represented graphically below.
DDT plot
Although exports, and overall production, continued to rise until 1963, US consumption of DDT peaked in 1959, before any significant restrictions were placed on its use, and declined steadily thereafter. A reasonable person might wonder why that would be. Guess what? The boll weevil and the bollworm were becoming resistant to DDT. Sweeney refers to this fact (p. 86) and observes that

While the evidence convinces me that the use of DDT on cotton is declining and should be reduced as soon as effective replacement means of controlling pests are developed, I do not feel that the evidence to date permits any conclusion to the effect that DDT should be banned for use on cotton at this time.

Ruckelshaus disagreed. With his order, use of DDT on cotton pests became history. The economic impact on cotton growers was significant but far from catastrophic: costs to cotton producers were estimated at $7.75 million nationally, and for consumers at 2.2 cents per capita per year (p. 193).

Even in the one arena where the DDT ban was argued to be unbearably burdensome, its use was already declining, the hearing examiner recommended that it be reduced further in favor of alternative methods, and in the event, the ban’s effects were easily absorbed. Well, then — did it have any impact that we should care about?

Glad you asked.

Returning to Steven Milloy’s DDT FAQ, cited above, we find a pearl. Robert Desowitz’ The Malaria Capers is quoted (#8):

“There is persuasive evidence that antimalarial operations did not produce mosquito resistance to DDT. That crime, and in a very real sense it was a crime, can be laid to the intemperate and inappropriate use of DDT by farmers, especially cotton growers. They used the insecticide at levels that would accelerate, if not actually induce, the selection of a resistant population of mosquitoes.”

That’s right. The 1972 DDT ban did nothing to restrict the chemical’s use against malaria, but had the effect of eliminating the single most intense source of selection pressure for insecticide resistance in mosquitos. As the rest of the world followed suit in restricting agricultural use of DDT, the spread of resistance was slowed dramatically or stopped.
By this single action, William Ruckelshaus — and, credit where it’s due, Rachel Carson — may well have saved millions of lives.

Steven Milloy is invited to add that to the DDT FAQ any time it’s convenient.

_____________________________________________________________

[1] A footnote explains that the post is “largely drawn from materials compiled by J. Gordon Edwards, professor of entomology at San Jose State University.” How much actual collaboration took place, if any, is not stated.

[2] Technically, it’s not a “decision”, but an opinion stating “recommended findings, conclusions and orders.” A fine point, to be sure, but it makes a difference.

[3] “It has been estimated that two-thirds of the DDT that is used in the United States is used in agriculture, and that 75% of the DDT that is used on agricultural crops is used on cotton.” (Sweeney, p. 83). According to the 1975 report, cotton’s share had increased to 80% by 1971-1972.

[4] UPDATE: EPA has now posted its DDT archives, complete with the Sweeney opinion, here. You can now download a better-quality copy of the opinion at a fraction of the size, so do that. If my copy is adding no value, I’ll probably take it down eventually. I see that the EPA page was last updated September 25th, roughly a month after this post. I’d like to think that my prodding was a factor, but there’s no way to know.

_____________________________________________________________

(Hat tips are due Ed Darrell, for the best historical coverage, Bug Girl, for the best scientific coverage, and Tim Lambert, for the best overall coverage of this issue.)

 

This entry was posted on Sunday, August 26th, 2007 at 6:25 pm and is filed under General. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.


Americans want EPA’s environmental protections; Verge film tells why

October 19, 2017

Verge caption:  A woman holds a jar of undrinkable water from her well in Ohio in 1973. She filed a damage suit against the Hanna Coal Company, which owned the land around her house. Photo by Erik Calonius / US National Archives. From EPA's Documerica project.

Verge caption: A woman holds a jar of undrinkable water from her well in Ohio in 1973. She filed a damage suit against the Hanna Coal Company, which owned the land around her house. Photo by Erik Calonius / US National Archives. From EPA’s Documerica project.

Short film from The Verge:

It’s good to be reminded of the burning Cuyahoga River, from time to time. As a great example of EPA’s successes, the the Cuyahoga has not caught fire for many years.


Oh, look: EPA ordered DDT to be used to fight malaria in 1972!

October 29, 2014

U.S. Environmental Protection Agency did not start a “worldwide ban” on using DDT to fight malaria. EPA instead lifted a court imposed ban on use of the pesticide to fight disease.

At least a couple of times a week I run into someone who claims that environmentalists are evil people, led by Rachel Carson (who, they say, may be as evil as Stalin, Hitler and Mao put together), and that their hysteria-and-n0t-fact-based “worldwide ban” on DDT use led to tens of millions of people dying from malaria.

Each point of the rant is false.

air pollution control activities in the Four Corners area of the U.S., in the 1970s -- soon after the agency completed its hearings and rule making on the pesticide DDT.  EPA photo.

EPA Administrator William Rucklshaus during an airplane tour of air pollution control activities in the Four Corners area of the U.S., in the 1970s — soon after the agency completed its hearings and rule making on the pesticide DDT. EPA photo.

But lack of truth to claims doesn’t stop them from being made.

Serious students of history know better, of course.  Federal agencies, like EPA, cannot issue orders on science-based topics, without enough hard science behind the order to justify it.  That’s the rule given by courts, inscribed in law for all agencies in the Administrative Procedure Act (5 USC Chapter 5), and required of EPA specifically in the various laws delegating authority to EPA for clean air, clean water, toxics clean up, pesticides, etc.   Were an agency to issue a rule based on whim, the courts overturn it on the basis that it is “arbitrary and capricious.”  EPA’s 1972 ban on DDT use on certain crops was challenged in court, in fact — and the courts said the science behind the ban is sufficient.  None of that science has been found faulty, or the DDT manufacturers and users would have been back in court to get the EPA order overturned.

Reading the actual documents, you may discover something else, too:  Not only did the EPA order apply only to certain crop uses, not only was the order restricted to the jurisdiction of the EPA (which is to say, the U.S., and not Africa, Asia, nor any area outside U.S. jurisdiction), but the order in fact specifically overturned a previously-imposed court ruling that stopped DDT use to fight malaria.

That’s right: Bill Ruckelshaus ordered that use of DDT fight malaria is okay, in the U.S., or anywhere else in the world.

Quite the opposite of the claimed “worldwide ban on DDT to fight malaria,” it was, and is, an order to allow DDT to be used in any disease vector tussle.

How did the ranters miss that?

Here are the relevant clauses from the 1972 order, from a short order following a few pages of explanation and justification:

Administrator’s Order Regarding DDT

Order. Before the Environmental Protection Agency. In regard: Stevens Industries, Inc., et al. (Consolidated DDT Hearings). I.F.&R. Docket No. 83 et al.

In accordance with the foregoing opinion, findings and conclusions of law, use of DDT on cotton, beans (snap, lima and dry), peanuts, cabbage, cauliflower, brussel sprouts, tomatoes, fresh market corn, garlic, pimentos, in commercial greenhouses, for moth-proofing and control of bats and rodents are hereby canceled as of December 31, 1972.

Use of DDT for control of weevils on stored sweet potatoes, green peppers in the Del Marva Peninsula and cutworms on onions are canceled unless without 30 days users or registrants move to supplement the record in accordance with Part V of my opinion of today. In such event the order shall be stayed, pending the completion of the record, on terms and conditions set by the Hearing Examiner: Provided, That this stay may be dissolved if interested users or registrants do not present the required evidence in an expeditious fashion. At the conclusion of such proceedings, the issue of cancellation shall be resolved in accordance with my opinion today.

Cancellation for uses of DDT by public health officials in disease control programs and by USDA and the military for health quarantine and use in prescription drugs is lifted. [emphasis added]

In order to implement this decision no DDT shall be shipped in interstate commerce or within the District of Columbia or any American territory after December 31, 1972, unless its label bears in a prominent fashion in bold type and capital letters, in a manner satisfactory to the Pesticides Regulation Division, the following language:

  1. For use by and distribution to only U.S. Public Health Service Officials or for distribution by or on approval by the U.S. Public Health Service to other Health Service Officials for control of vector diseases;
  2. For use by and distribution to the USDA or Military for Health Quarantine Use;
  3. For use in the formulation for prescription drugs for controlling body lice;
  4. Or in drug; for use in controlling body lice – to be dispensed only by physicians. [emphasis added]

Use by or distribution to unauthorized users or use for a purpose not specified hereon or not in accordance with directions is disapproved by the Federal Government; This substance is harmful to the environment.

The Pesticides Regulation Division may require such other language as it considers appropriate.

This label may be adjusted to reflect the terms and conditions for shipment for use on green peppers in Del Marva, cutworms on onions, and weevils on sweet potatoes if a stay is in effect.

Dated: June 2, 1972

William D. Ruckelshaus

[FR Doc.72-10340 Filed 7-6-72; 8:50 am]
Federal Register, Vol. 37, No. 131 – Friday, July 7, 1972 pp. 13375-13376

Here is the entire order, in .pdf format. ddt-ruckelshaus order

More:


EPA approves CO2 permit for Texas steel maker; anyone notice?

June 19, 2014

Here’s the press release from EPA’s Region 6 office:

EPA Finalizes Greenhouse Gas Permit for Voestalpine Iron Production Plant
$740M facility in San Patricio Co., TX, will bring 1,400 construction jobs and150 permanent jobs

DALLAS – (June 16, 2014) The U.S. Environmental Protection Agency (EPA) has issued a final greenhouse gas (GHG) Prevention of Significant Deterioration (PSD) construction permit to Voestalpine for an iron production plant in San Patricio County, TX. The facility’s process for producing iron will use minimal natural gas and will be 40 percent more efficient than traditional methods. The permit is another in the series of permits drafted by the Texas Commission on Environmental Quality (TCEQ) and issued by EPA under a program to facilitate timely permitting for applicants in the State of Texas.

“Voestalpine shows energy efficiency is a common-sense strategy for success, not just in business but for the environment as well,” said Regional Administrator Ron Curry. “The joint EPA and TCEQ permitting program is helping Texas business grow while building greener plants.”

The plant will reduce iron ore pellets, which will be used as raw material input at steel mills. The direct reduced iron process will use only clean-burning natural gas instead of solid fossil fuels. The estimated project cost is $740 million and will bring 1,400 construction jobs to the area. Once complete, the facility will create around 150 permanent jobs.

In June 2010, EPA finalized national GHG regulations, which specify that beginning on January 2, 2011, projects that increase GHG emissions substantially will require an air permit.

EPA believes states are best equipped to run GHG air permitting programs. Texas is working to replace a federal implementation plan with its own state program, which will eliminate the need for businesses to seek air permits from EPA. This action will increase efficiency and allow for industry to continue to grow in Texas.

EPA has finalized 43 GHG permits in Texas, proposed an additional six permits, and currently has 21 additional GHG permit applications under review and permit development in Texas.

For all of the latest information on GHG permits in Texas please visit: http://yosemite.epa.gov/r6/Apermit.nsf/AirP

Connect with EPA Region 6:
On Facebook: https://www.facebook.com/eparegion6
On Twitter: https://twitter.com/EPAregion6
Activities in EPA Region 6: http://www.epa.gov/aboutepa/region6.htm

Headquarters of Voestalpine, head-turning building by Dietmar Feichtinger Architectes, located in Linz, Austria.  Architecture News Plus image

Headquarters of Voestalpine, head-turning building by Dietmar Feichtinger Architectes, located in Linz, Austria. Architecture News Plus image. Voestalpine plans to build a $740 million steel plant near Corpus Christi, Texas.

This is big news, really.  Texas constantly complains about regulations on greenhouse gases, and regularly and constantly sues EPA to stop regulation.  Texas and it’s wacky governor Rick Perry constantly complain that EPA regulation harms jobs, and that permits never really get issued.  So this announcement should be front page news in most Texas newspapers.

How was it covered?

That’s it for Texas media.  Where are the Dallas Morning News, the Fort Worth Star-Telegram, the Houston Chronicle, the San Antonio Express, the El Paso Times?  Big market TV and radio?

National coverage was limited to low-circulation newsletters.

Seems to me that these issues of actual action on climate change, are under-reported.

More:

Groundbreaking for Voestalpine facility near Corpus Christi, Texas

Caption from Voestalpine LLC: After about a year of preparation, Wolfgang Eder, CEO of voestalpine, broke ground today for the construction of a direct reduction plant in Texas (USA). This EUR 550 million investment is the largest foreign investment in the history of the Austrian Group. The voestalpine Texas LLC plant is being constructed at the La Quinta Trade Gateway Terminal in close proximity to the City of Corpus Christi. Starting in 2016, the plant will produce two million tons of HBI (Hot Briquetted Iron) and DRI (Direct Reduced Iron) annually and will supply Austrian locations, such as Linz and Donawitz, with “sponge iron” as a premium raw material. With the new facility, voestalpine can significantly reduce production costs in Europe. The highly automated plant will create 150 jobs.


Legacy of DDT abuse: Cleaning up old pesticide dumps

February 15, 2014

Contrary to science denialist claims, DDT is not harmless.  Users and abusers of DDT, abandoned stocks of DDT and other pesticides around the world, after the stuff had become essentially useless against insect or other pests originally targeted.

In the U.S., EPA moves in to clean up DDT dumps, under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), or Superfund.  In much of the world, various UN agencies find the old pesticides, and clean them up as funding allows.

The Food and Agricultural Organization (FAO) documents its cleanup efforts with photos of sessions training technicians to find and catalog dump sites, repackaging of old drums when necessary, extraction, packing and shipping to a disposal site.

Photos tell a story words on paper cannot.

Caption from FAO: TN (Tanzania) before: 40 tonnes of 50 year old DDT were found in Menzel Bourguiba Hospital, TN - : M. Davis

Caption from FAO: TN (Tanzania) before: 40 tonnes of 50 year old DDT were found in Menzel Bourguiba Hospital, TN – : M. Davis

Sometimes the toxic wastes did not stay neatly stacked.

FAO caption:  TN before: 40 tonnes of 50 year old DDT were found in Menzel Bourguiba Hospital, TN

FAO caption: TN before: 40 tonnes of 50 year old DDT were found in Menzel Bourguiba Hospital, TN View real size

DDT use against insect vectors of disease essentially halted in the mid-1960s.  The Rockefeller Foundation’s and UN’s ace mosquito fighter, Fred Soper, ran into mosquitoes in central Africa that were resistant and immune to DDT. Farmers and businesses had seized on DDT as the pesticide of choice against all crop pests, or pests in buildings.  By the time the UN’s malaria-fighting mosquito killers got there, the bugs had evolved to the point DDT didn’t work the malaria eradication campaign.

Also, there were a few DDT accidents that soured many Africans on the stuff.  Around lakes where local populations caught the fish that comprised the key protein in their diet, farmers used DDT, and the runoff killed the fish.

Use of DDT ended rather abruptly in several nations.  Stocks of DDT that had been shipped were abandoned where they were stored.

For decades.

FAO caption:    Obsolete DDT in Luanda, Angola - July 2008 -  : K. Cassam

FAO caption: Obsolete DDT in Luanda, Angola – July 2008 – : K. Cassam

Prevention and disposal of obsolete chemicals remains as a thorny problem throughout much of the world.  Since 2001, under the Persistent Organic Pollutants Treaty, (POPs), the UN’s World Health Organization (WHO) has coordinated work by WHO and a variety of non-governmental organizations (NGOs), as well as governments, to make safe the abandoned pesticides, and detoxify or destroy them to prevent more damage.  FAOs efforts, with photos and explanation, is a history we should work to preserve.

DDT provided powerful insect killing tools for a relatively short period of time, from about 1945 to 1965.  In that short period, DDT proved to be a deadly killer of ecosystems to which it was introduced, taking out a variety of insects and other small animals, on up the food chain, with astonishing power.  One of DDT’s characteristics is a long half-life — it keeps on killing, for months or years. Once that was thought to be an advantage.

Now it’s a worldwide problem.


No, Congress did not “overreact” to DDT

October 30, 2013

Looking for something else, I restumbled on the Constitution Club, where they continue to club the Constitution, its better principles, and especially the great nation that the document creates.

And one of those grotesquely inaccurate posts blaming liberals for everything sprang up — bedbugs, this time.  If only those liberals had let the good DDT manufacturers poison the hell out of the entire planet, the blog falsely claims, there would be no concern for bedbugs surging in hotels worldwide today, and especially not in Charlotte, North Carolina, back during the Democratic National Convention.

A meeting of a chapter of Constitution clubs? Wikipedia image

A meeting of a chapter of Constitution clubs? Wikipedia image

Looking through the archives, I now recall I dealt with most of this issue on this blog before.

The post’s author made a response I hadn’t seen.  God help me these idiots do need a trip to the intellectual woodshed.  He said “Congress overreacted on DDT, I think. It likes to do that.”

In reality, Congress did nothing at all, other than pass the law regulating pesticides, if we stick to the real history. The U.S. Environmental Protection Agency (EPA) issued the rule on DDT, which still stands today.  Over react?  Two federal courts had to twist EPA’s arm to get any action at all, and after delaying for nearly two years, EPA’s rule didn’t ban DDT except for outdoor use on crops, which by that time meant cotton in a handful of states in the U.S. — DDT has never been banned in Africa nor Asia, Persistent Organic Pollutants Treaty notwithstanding.

Oh, hell. Put it on the record.

I wrote:

Did Congress ever “react” to DDT?

EPA was tasked by the 1950s’s FIFRA to check out safety of pesticides, and did.  FIFRA had recently been amended to give EPA (USDA, before) power to ban a pesticide outright. Two federal courts found DDT eminently worthy of such an outright ban, but refrained from ordering it themselves as they saw the law to require, on the promise of EPA to conduct a thorough scientific review.  At some length, and irritation to the Eisenhower appointees to the courts, EPA got around to an administrative law hearing — several months and 9,000 pages.  In a panic, the DDT manufacturers proposed a new label for DDT before the hearings got started, calling DDT dangerous to wildlife, and saying it should be used only indoors to control health-threats.  Alas, under the law, if DDT were allowed to stay for sale over the counter, anyone could buy it and abuse it.  The hearing record clearly provided proof that DDT killed wildlife, and entire ecosystems.  But, it was useful to fight diseases, used as the proposed label suggested . . .

Administrator William Ruckelshaus took the cue the DDT manufacturers offered.  He issued a rule banning DDT from outdoor use on agricultural crops except in emergencies with a permit from EPA.  But he specifically allowed U.S. manufacturers to keep making the stuff for export to fight malaria in distant nations, and to allow DDT makers to keep making money.

“Over-reacted” on DDT?  Not Congress, and not EPA.  The rule was challenged in court, twice.  The appellate courts ruled that the scientific evidence, the mountains of it, fully justified the rule, and let it stand.  (Under U.S. law, agencies may not act on whim; if they over-react, they’ve violated the law.)

How bedbugs react to DDT today. Articulate.com

How bedbugs react to DDT today. Articulate.com

No study conducted carefully and judiciously, and passed through the gauntlet of peer review, since that time, has questioned the science conclusions of that rule in any significant way — if any study questioned the science at all (there are famous urban legends, but most of them lead back to people who didn’t even bother to do research, let alone do it well and publish it).

But so-called conservatives have faith that if Congress will just repeal the law of gravity, pigs can fly.  In the real world, things don’t work that way.

How bedbugs view DDT in the 21st century.

How bedbugs view DDT in the 21st century.

I’ve captured most of the earlier exchanges below the fold; one can never trust so-called conservatives to conserve a record of their gross errors.  They’re there for the record, and for your use and edification.

Read the rest of this entry »


Querying the Rachel Carson Critics (who turned out the light?)

June 19, 2013

Another question of mine that will probably never see the light of day.  This group has no answer, so why would they allow the question?

I stumbled across a blog-looking page from the American Council on Science and Health, an industry apologist propaganda site, on World Malaria Day, which was April 25.  You may recognize the name of the group as one of the industry-funded sites that constantly attacks Rachel Carson, and often the World Health Organization, with the unscientific and false claims that environmentalists bannned DDT and thereby condemned millions of Africans to die from malaria — which, ASCH claims, could have easily been eradicated with more DDT poisoning of Africa.

On World Malaria Day, ASCH took note, flirted with the facts (that DDT doesn’t work as it once was thought to work), but then backed away from the facts — that the ban on DDT in the U.S. came years AFTER WHO suspended the malaria eradication campaign in Africa when it was discovered DDT couldn’t kill DDT-adapted mosquitoes, already subject to years of abuse of DDT by agriculture and other industries.  ASCH said:

DDT kills mosquitoes, although not as well as it did 60 years ago. But it also irritates them and repels them, so the small amount sprayed inside homes effectively reduces the transmission of the malarial microbe substantially. The banning of DDT, based upon political anti-chemical bureaucrats and “environmentalists” inspired by Carson’s “Silent Spring” who ran our EPA in 1972, helped to impede the malaria control program led by the UN’s WHO.

Impede?  Impossible for a 1972 ban to have been responsible for the earlier suspension of the WHO campaign, not to mention EPA’s ban ended at the U.S. borders.  So I asked:

Screen capture of query to ACSH on how EPA's ban "impeded" WHO's campaign against malaria, ended years earlier.

Screen capture of query to ACSH on how EPA’s ban “impeded” WHO’s campaign against malaria, ended years earlier.

Ed Darrell Reply

June 19, 2013 at 5:16 am

Your comment is awaiting moderation.

I would be very interested in just how the 1972 ban on DDT in the U.S. “impeded” the UN’s antimalaria campaign, which stopped using DDT heavily seven years earlier, and was suspended in 1969.

After the ban on U.S. use of DDT, all of U.S. manufacture was dedicated to export to Africa and Asia, which greatly increased DDT supplies available there.

How did this impede?

Want to wager a guess as to whether they’ll ever allow the comment to see the light of day at their site, let alone answer it?

More:

Wall of Shame – Sites that continue to spread the pro-DDT hoax as fact:

DDT is good for me advertisement

“DDT is good for me advertisement” from circa 1955.  Photo image from the Crossett Library Bennington College.  This ad today is thought to be emblematic of the propaganda overkill that led to environmental disasters in much of the U.S. and the world.  DDT cleanups through the Superfund continue to cost American taxpayers millions of dollars annually.


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