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Full text of "Migrant and seasonal farmworker powerlessness. Hearings, Ninety-first Congress, first and second sessions .."

AMHERST COLLEGE 



( Of 3, 




310212 3 



11 4604 9 



SEASONAL FARMWORKER 
ruWERLESSNESS 



HEARINGS 

BEFORE THE 

SUBCOMMIHEE ON MIGRATORY LABOR 

OP THE 

COMMITTEE ON 

LABOR AND PUBLIC WELFARE 

UNITED STATES SENATE 

NINETY-FIRST CONGRESS 

FIRST AND SEX30ND SESSIONS 
ON 

PESTICIDES AND THE FARMWORKER 

AUGUST 1, 1969 



PART 6-A 



Printed for the use of the Committee on Labor and Public Welfare 





MIGRANT AND SEASONAL FARMWORKER 
POWERLESSNESS 



HEARINGS 

■BEFORE ,THE 

SUBCOMMIHEE ON MIGRATORY LABOR 

OF THE 

COMMITTEE ON 

LABOR AND PUBLIC WELFARE 

UNITED STATES SENATE 

NINETY-FIRST CONGRESS 

FIRST AND SECOND SESSIONS 
ON 

PESTICIDES AND THE FARMWORKER 

AUGUST 1, 1969 



PART 6-A 



Printed for the use of the Ck)mmittee on Labor and Public Welfare 




U.S. GOVERNMENT PRINTING OFFICE 
36-513 O WASfflNGTON : 1970 



COMMITTEE ON LABOR AND PUBLIC WELFARE 
RALPH YARBOROUQH, Texas, Chairman 
JENNINGS RANDOLPH, West Virginia JACOB K. JAVITS, New York 

HARRISON A. WILLIAMS, Jr., New Jersey WINSTON L. PROUTY, Vermont 
CLAIBORNE PELL, Rhode Island PETER H. DOMINICK, Colorado 

EDWARD M. KENNEDY, Massachusetts GEORGE MURPHY, California 

GAYLORD NELSON, Wisconsin RICHARD S. SCHWEIKER, Pennsylvania 

WALTER F. MONDALE, Minnesota WILLIAM B. SAXBE, Ohio 

THOMAS F. EAGLETON, Missouri RALPH TYLER SMITH, Illinois 

ALAN CRANSTON, California 
HAROLD E. HUGHES, Iowa 

Robert O. Harris, Staff Director 

John S. Forsythb, Oeneral Counsel 

Roy H. Millenson, Minority Staff Director 

Eugene Mittelman, Minority Counsel 



Subcommittee on Migratory Labor 

WALTER F. MONDALE, Minnesota, Chairman 
HARRISON A. WILLIAMS, Jr., New Jersey WILLIAM B. SAXBE, Ohio 
EDWARD M. KENNEDY, Massachusetts GEORGE MURPHY, California 

ALAN CRANSTON, California RICHARD S. SCHWEIKER, Pennsylvania 

HAROLD E. HUGHES, Iowa RALPH TYLER SMBTH, lUlaois 

BORBN Chertkov, Counscl 

A. Sidney Johnson, Professional Staff Member 

EcoENE Mittelman, Minority Counsel 

(H) 



Format of Hearings on Migrant and Seasonal Farmworker 

poaverlessness 

The Subcommittee on Migratory Labor conducted public hearings 
in Washington, D.C., during the 91st Congress on "Migrant and Sea- 
sonal Farmworker Powerlessness." These hearings are contained in the 
following parts : 

Subject matter Hearing dates 

Parti: Who Are the Migrants? June 9 and 10, 1969 

Part 2 : The Migrant Subculture July 28, 1969 

Part3-A: Efforts to Organize July 15, 1969 

Part 3-B : Efforts to Organize July 16 and 17, 1969 

Part 4-A : Farmworker Legal Problems Aug. 7, 1969 

Part4-B: Farmworker Legal Problems Aug. 8, 1969 

Part 5-A : Border Commuter Labor Problem May 21, 1969 

Part 5-B : Border Commuter Labor Problem May 22, 1969 

Part 6-A : Pesticides and the Farmworker Aug. 1, 1969 

Part 6-B : Pesticides and the Farmworker Sept. 29, 1969 

Part 6-C : Pesticides and the Farmworker Sept. 30, 1969 

Part 7 : Manpower and Economic Problems Apr. 14 and 15, 1970 

Part 8 : Who Is Responsible? July 20, 21, and 24, 1970 



(m) 



CONTENTS 



CHRONOLOGICAL LIST OF WITNESSES 
Friday, August 1, 1969 

Cohen, Jerry, general counsel. United Farm Workers Organizing Com- Pa&e 
mittee, Delano, Calif 3008 

Johnson, C. C, Chief, Consumer Protection and Environmental Health, 
Department of Health, Education, and Welfare; accompanied by Dr. 
Samuel Simmons, Director, Division of Community Studies, Office of 
Product Safety, Food and Drug Administration, Atlanta, Ga.; Dr. 
William Durham, Director, Primate Research Branch, Division of 
Pesticides, Food and Drug Administration, Perrine, Fla. ; and Reo 
Duggan, Deputy Associate Commissioner for Compliance, Food and 
Drug Administration 3100 

STATEMENTS 

Cohen, Jerry, general counsel, United Farm Workers Organizing Com- 
mittee, Delano, Calif 3008 

Prepared statement 3009 

Creuziger, Charles M., president. Vegetable Growers Association of 
America, Sturtevant, Wis., before a committee of the Wisconsin State 
Legislature, prepared statement 3250 

Gordon, Jerome B., president, Delphic Systems Research Corp., prepared 
statement 3196 

Johnson, C. C, Chief, Consumer Protection and Environmental Health, 
Department of Health, Education, and Welfare; accompanied by Dr. 
Samuel Simmons, Director, Division of Community Studies, Office of 
Product Safety, Food and Drug Administration, Atlanta, Ga. ; Dr. 
William Durham, Director, Primate Research Branch, Division of 
Pesticides, Food and Drug Administration, Perrine, Fla.; and Reo 
Duggan, Deputy Associate Commissioner for Compliance, Food and 

Drug Administration 3100 

Prepared statement 3192 

National Agricultural Chemicals Association, prepared statement 3222 

ADDITIONAL INFORMATION 

Articles, publications, etc.: 

"Agriculture and the Child Labor Requirements Under the Fair 
Labor Standards Act As Amended in 1966," by the U.S. Depart- 
ment of Labor, Child Labor Bulletin No. 102 (Revised) 3152 

Allegation by Grape Boycott Activists branded "Untrue and Irre- 
sponsible" by California Department of Agriculture 3031 

"CPR Report/Renewed Debate Over DDT: Should the Government 
Restrict Its Use?", from the National Journal, September 29, 
1969 3359 

"California Grapes 'Safe' Says Official," from the Seattle Times, 

July 20, 1969 3099 

"Characteristics of Pesticide Poisoning in South Texas," reprinted 

from Texas Medicine, September 1968, volume 64 3307 

"Compromise on Banning DDT Agreed to by Senate Group," by 
Jerry Gillam, from the Los Angeles Times, July 2, 1969 3091 

"DDT Peril Seen in Mother's Milk," from the Washington Post, 

May 27, 1969 3095 

(V) 



VI 

Articles, publications, etc. — Continued 

"DDT Termed Peril to the Sex Organs," from the New York Times, Paw 
January 15, 1969 3095 

Excerpts from testimony of selected witnesses concerning occupational 
diseases attributed to pesticides and other agricultural chemicals in 
Kern County, Calif 3049 

"Exposure of Workers to Pesticides," by Homer R. Wolfe, B.S.; 
William F. Durham, Ph. D.; and John F. Armstrong, B.S., 
Wenatchee, Wash., from the Archives of Environmental Health, 
April 1967, volume 14, copyright 1967, American Medical Asso- 
ciation 3105 

"Fire Prevention Code," recommended by the American Insurance 
Association, Engineering and Safety Department, New York, N.Y., 
Chicago, 111., and San Francisco, Calif 3165 

"Grape Growers Get Okay To Use the Sodium Arsenate," from the 

Fresno Bee, January 12, 1969 3097 

"How Poisonous Are Pesticides?", by L. M. Vasvary and Fred C. 

Swift, Rutgers, the State University 3325 

Interpretation of Toxicity 3320 

"Mayda^^," by Ralph Nader and Jerome Gordon, from biweekly 

magazine Hard Times, issue of November 8-15, 1968 3207 

"Michigan Act to Ban DDT Sales," from the San Francisco Chronicle, 

April 17, 1969 3093 

"Needed: Pesticide Control Review," from the Los Angeles Times, 

April 17, 1969 3085 

New Pesticide Safety Posters Can Be Read by Illiterates 3226 

"New U.S. Ban on the Use of Pesticides," from the San Francisco 

Chronicle, April 17, 1969 3093 

"Occupational Disease in California Attributed to Pesticides and 
Other Agricultural Chemicals," published by the State of California, 
Department of Public Health, Bureau of Occupational Health, 1966. 3162 

"Occupational Disease of Farm Workers," by Irma West, M.D., 

Berkeley, Calif 3292 

"Parathion Residues as a Cause of Poisoning in Crop Workers," Griffith 
E. Quinby, M.D., M.P.H., Wenatchee, Wash., and Allen B. Lemmon, 
A.B., Sacramento, Calif., from the Journal of the American Medical 
Association, February 15, 1958, volume 166 3117 

"Parathion Residue Poisoning Among Orchard Workers," from the 
Journal of the American Medical Association, August 3, 1964, 
volume 189, pages 351-356 3124 

"Pesticide-Induced Illness — Public Health Aspects of Diagnosis and 

Treatment," by Irma West, M.D., Berkeley, Calif 3302 

"Pesticide Laws and Legal Implications of Pesticide Use," excerpt from 
Pesticides Program Training Guide, U.S. Department of Health, 
Education, and Welfare 3144 

"Pesticide Review 1968," from the U.S. Department of Agriculture-. 3342 

"Pesticides," by John Neumeyer, Donald Giggons, and Harry Trask 

in Chemical Week Report 3329 

Programs Provided by Department of HEW and Consumer Protection 

and Environmental Health Services, summary 3102 

Proposed Agreement Between UFWOC, Thomas Griffin, Atwood 

Aviation Co 3041 

"Public Health Problems Are Created by Pesticides," by Dr. Irma 

West, M.D 3073 

"Relationship Between Pesticide: and Nerve Gases," prepared with 

the assistance of the Library of Congress 3317 

"Report on Pesticides and Related Activities — 1968 Abstracts," U.S. 

Department of Agriculture and Cooperators, February 1969 3253 

"Rhine Shows No Trace of Fish-Killing Poison," from the Los Angeles 

Times, June 26, 1969 3095 

"Scientists Ask Ban on Dangerous Chemical Warning," by Charles 

Golden 3086 

"State Will Ban Home Usage of DDT and DDD," by Jerry Gillam, 

from the Los Angeles Times, Juno 13, 1969 3092 

"Suits Asks Ban on DDT in California, Crop Confiscation," by 

George Getze, from the Los Angeles Times, April 15, 1969 3084 



vn 

Articles, publications, etc. — Continued 

"Sweden's Ban on DDT," from the San Francisco Chronicle, April I'as* 

14, 1969 3094 

"The California Pesticide Regulatory Program," by A. B. Lemmon.. 3227 

The California pesticide regulatory program 3237 

"The Farm Workers' Power Plea," from the San Francisco Chronicle, 

April 17, 1969 3094 

"The Health of the Migrant Worker," by J. Robert Lindsay, M.D., 
and Helen L. Johnston, Washington, D.C., reprinted by HfiW from 
the Journal of Occupational Medicine, volume 8, No. 1, January 

1966 3270 

"The Hidalgo County Incident," by Oliver Bryk 3306 

"The Insecticide Crisis," by Robert van der Bosch, Department of 
Entomology and Parasitology, University of California, Berkeley, 

Calif 3239 

"The Use of Agricultural Chemicals," by Irma West, M.D., Berkeley, 

Calif 3298 

"The War That Never Ends," from the Office of Information, U.S. 

Department of Agriculture, September 1966 3173 

UFWOC Pesticide Presentation by United Farm Workers Organizing 

Committee, AFL-CIO 3275 

"Warning Concerning Out-of-Date Sources of Pesticide Information," 

by J. Lincoln Pearson, University of Rhode Island 3328 

"Wetters Are Big Factor In Spray Mixes," from the Fresno Bee, 

January 12, 1969 3096 

"Wisconsin Hearing on Bid To Ban DDT Could Affect Future of All 
Such Products," by Richard D. James, from the Wall Street 

Journal, March 4, 1969 3088 

Work Injuries in California Agriculture, 1966 3267 

Charts: 

Pesticides Sales Will Top $3 Billion by 1975 3201 

Communications to: 

Bozick, Mike, chairman. Desert Grape Growers League, Richard 
Bagdasarian Ranch, Mecca, Calif., from Cesar E. Chavez, January 

14, 1969 3043 

Chertkov, Boren, Counsel, Subcommittee on Migratory Labor, U.S. 
Senate, Washington, D.C., from: 

Farkas, Eugene M., Special Reports Division, Office of Informa- 
tion, U.S. Department of Agriculture, Washington, D.C., July 

2, 1969 3252 

Gibbs, L. C, Coordinator, Agricultural Chemicals Program, 
Federal Extension Service, U.S. Department of Agriculture, 

Washington, D.C., July 9, 1969 3275 

Public Health Service, Health Services and Mental Health 
Administration, Department of Health, Education, and Wel- 
fare, July 25, 1969 3266 

Cohen, Jerome, Esq., Delano, Calif., from Stephen E. Wall, Wall & 

Byrum, Bakersfield, Calif., January 8, 1969 3042 

Fielder, Jerry W., director, California Department of Agriculture, 
Sacramento, Calif., from: Hon. Walter F. Mondale, a U.S. Senator 
from the State of Minnesota, chairman. Subcommittee on Migratory 

Labor, U.S. Senate, Washington, D.C., September 4, 1969 3235 

Mondale, Hon. Walter F., a U.S. Senator from the State of Minne- 
sota, chairman. Subcommittee on Migratory Labor, Washington, 
D.C., from: 

Bryk, Oliver, Bethesda, Md., August 1, 1969 3311 

Creuziger, Charles M., president, Vegetable Growers Association 

of America, Washington, D.C., August 4, 1969 3250 

Fielder, Jerry W., director, California Department of Agriculture, 
Sacramento, Calif.: 

June 31, 1969 3031 

July 30, 1969 3226 

September 17, 1969 3235 



vin 

Communications to — Continued 

Mondale, Hon. Walter F., a U.S. Senator from the State of Minnesota, 
chairman, Subcommittee on Migratory Labor, Washington, D.C., 
from — Continued 

Johnson, Charles C, Jr., Assistant Surgeon General Adminis- 
trator, Department of Health, Education, and Welfare, Public 
Health Service, Consumer Protection and Environmental 
Health Service, Washington, D.C.: ?««« 

July 30, 1969 3131 

August 29, 1969 3195 

Swankin, David A., Director, U.S. Department of Labor, Bureau 

of Standards, Washington, D.C., July 8, 1969, with enclosures. . 3144 
Wall, Stephen, Esq., Bakersfield, Calif., from Jerome Cohen, Delano, 
Calif.: 

January 7, 1969 (with enclosure) 3040 

January 9, 1969 3043 

Memorandum to: 

Chertkov, Boren, staff, Senate Subcommittee on Migratory Labor, 
from Acting Coordinator for Migrant and Rural Health, Division of 
Health Care Services, Community Health Service, HEW, March 13, 

1969 3274 

Coordinator for Rural and Migrant Health, from Paul Agnano, Public 

Health Service, Department of HEW, April 3. 1969 . 3266 

Preliminary injunction issued by the Superior court of the State of California 
in and for the County of Kern to Atwood Aviation, Inc., Garriott Crop 
Dusting Co., Inc., Arvinair Crop Dusters, and all other members of Kern 

County Agricultural Chemical Association 3078 

Selected tables: 

List of commodities seized because of pesticide contamination : Fiscal 

year 1969 3142 

Pesticide accidents investigated, 1963-66 3 168 

Reports of occupational disease among agricultural workers attributed 

to pesticides and other agricultural chemicals, Kern County, 1967 __ 3045 

Synthetic chemical pesticides and effects on man 3102 

Table D — State pesticide laws 3146 

Temporary restraining order and preliminary injunction issued by the 
Superior Court of the State of California to Atwood Aviation, Inc., 
Arvinair Cropdusters, and all other members of the Kern County Agri- 
cultural Chemical Association 3039 



MIGRANT AND SEASONAL 
FARMWORKER POWERLESSNESS 

(Pesticides and the Farmworker) 



FRIDAY, AUGUST 1, 1969 

U.S. Senate, 
Subcommittee ox Migratory Labor 
OF the Committee ox Labor axd Public Welfare, 

Washington^ B.C. 

The subcommittee met at 9:30 a.m., pursuant to notice, in room 
4232, New Senate Office Building, Senator Walter F. Mondale 
(chairman of the subcommittee) presiding. 

Present : Senators Mondale (presiding), Cranston, and Bellmon. 

Committee staff members present : Boren Chertkov, majority coun- 
sel; and A. Sidney Johnson, professional staff member to the sub- 
committee. 

Senator IMondale. The subcommittee will come to order. 

This morning we begin the sixth in a series of hearings on migrant 
and seasonal farmworker problems. The underlying theme of our 
hearings is powerlessness. 

In past hearings we have endeavored to obtain a broad introduc- 
tion to the problem areas by hearing farm workers themselves tell of 
their own lives, their own problems. Last month, we heard testimony 
from both community and union organizers on the obstacles to their 
self-help efforts to improve their own situation. Last week we ex- 
plored what really happens to the men, women, and children that 
are confronted with the severe economic and social stress of migra- 
tory farmwork related to us in our earlier hearings. We have also 
heard testimony on the border-commuter labor problem and the se- 
vere economic depression created by the surplus of desperately poor 
people forced to accept substandard living and working conditions 
along our borders with ^lexico. 

Today we are devoting our attention to a discussion of the effects 
of pesticides on farmworkers. Senator Gaylord Nelson of Wisconsin 
has brought the public's attention to the dangerous use of pesticides, 
and the effects that pesticides have on our Nation's environment and 
population. We will try to determine : 

What the scope of the entire problem area may be? 

What are the short- and long-range effects, if any, of the use of 
pesticides on farmworkers who apply them, or work in the fields soon 
after they have been applied ? 

(3007) 



3008 

"V^Tiether, in view of increasing production, and the proliferation 
of various new pesticides, adequate funds are being devoted to re- 
search on occupational hazards to farmworkers? 

"What Government programs exist for protection of the farm- 
worker from pesticides and whether they are adequately funded and 
enforced ? 

Questions such as these must be explored to gain a full under- 
standing of the special problems which pesticides may have for 
migrant and seasonal farmworkers. 

This morning we are privileged to have several expert witnesses to 
discuss these pfoblems. 

Our investigation continues on Thursday, August 7, with a study of 
the legal problems of farmworkers. 

I understand it has been agreed that the witness list as printed will 
be somewhat changed and our first witness will be Mr. Jerry Cohen, 
general counsel of the United Farm Workers of Delano, Calif. 

Mr. Cohen. 

STATEMENT OF JERRY COHEN, GENERAL COUNSEL, UNITED FARM 
» WORKERS ORGANIZING COMMITTEE, DELANO, CALIF. 

!Mr. CoHEx. Thank you, Senator Mondale. 

Cesar Chavez asked me to thank you for holding these hearings 
because, as we understand, these are the first hearings in the history 
of the country that concern pesticides and the farmworker of our 
Nation. 

I would like to summarize the main area of Farm Workers' con- 
cern. The reason the Farm Workers are testifying here today is be- 
cause we believe that the table-grape industry in California is irre- 
sponsible in its use of economic poisons, uses the wrong kinds of 
poisons at the wrong time and in the wrong amounts, and in disre- 
gard of the health of both the consumer and the workers. 

For example, we have recently discovered from those records 
which are available to the Farm Workers that the chemical that was 
used on cranberries, amino triazole, was sprayed on a thousand acres 
of table grapes in Kern County. 

We also discovered, despite a denial of table-grape growers, DDT 
residue is found on the grapes. 

Finally, the use of parathion, akin to nerve gas, in the State of 
California, is of grave concern to the union because it has caused and 
still is causing serious injuries to many farmworkers. 

I submitted a prepared statement to the subcommittee. I don't 
wish to read the statement but I do wish to review some of the im- 
portant aspects of this problem. I would like to briefly go into the 
history of the problem as it has developed from our point of view. 

Senator Moxdale. Mr. Cohen, we will put your prepared state- 
ment in its entirety in the record as though read, and you may pro- 
ceed. 

(The prepared statement of Mr. Cohen follows :) 



3009 



PREPARED STATEMENT OF JERRY COHEN, GENERAL COUNSEL, 
UNITED FARM WORKERS ORGANIZING COMMITTEE, 
DELANO, CALIF. 



On July 3rd, 1969, negotiations between the 
United Farm Workers Organizing Committee and 12 table grape 
growers came to an end when the 12 growers called for a recess. 
The use of economic poisons by the grape industry was the issue 
over which the negotiations foundered. 

Article 25 of the Employer's Contract Proposals reads 

in part as follows: 

"The Union agrees that it will not harass 
any employer regarding the use of pesticides so long 
as the employer agrees to abide by the regulations 
heretofore referred to. The Union agrees that it 
will not embark upon any program regarding pesticides 
that can in any way be detrimental or harmful to the 
industry in which the employer belongs." 

The United Farm Workers Organizing Committee has 

submitted a proposal which reads in part as follows: 

"The Company and the Union recognize the 
need to supply the consumers with healthy grapes picked 
and handled under the most clean, sanitary and healthful 
conditions possible. Furthermore, the Company and the 
Union recognize the need to conserve our natural resources 
and protect all forms of life from the serious dangers 
and damages caused by the improvident use of economic 
poisons. In the hope of taking progressive steps to 
protect the health of farm workers and consumers through- 
out the world and conserving for all mankind the benefits 
of our natural resources and surroundings the Company and 
the Union agree as follows: 

(1) The Health and Safety Committee shall be 
formed consisting of equal numbers of workers' represen- 
tatives selected by the bargaining unit and Company rep- 
resentatives. Members of the Health and Safety Committee 
shall have free access to all records concerning the use 
of economic poisons. 

The Health and Safety Committee shall participate 
in the formulation of rules and practices relating to the 
health and safety of the workers including but not limited 
to the use of garments, materials, tools, and equipment as 
they may affect the health and safety of the workers and 
sanitation conditions. 

(2) The Company shall not use DDT, Aldrin, Dieldrin 
and Endrin. The Company shall not apply other chlorinated 
hydrocarbons which are dangerous to farm workers , consum- 
ers and the environni©»*-:^ 

(3) The Company shall not use any organic 
phosphate pesticides such as but not limited to Parathion 
without first receiving approval from the Health and Safety 
Committee. The Company shall notify the Health and Safety 
Committee as soon as possible but at least 72 hours before 
the application of the organic phosphate material. Said 
notice shall contain the information set forth in part 4 
below: The Health and Safety Committee shall determine 



3010 



the length of time during which farm workers 
will not be permitted to enter the sprayed field 
following the application of the organic phosphate 
pesticide. Any Company using organic phosphates 
shall pay for the expense for all farm workers of 
one baseline cholinesterane test and other addition- 
al such tests if recommended by a doctor. The results 
of all said tests shall be immediately given by the 
Company to the Health and Safety Committee, and, if 
requested to any other authorized union representative. 

(4) The Company shall keep the following 
records and make them available to each member of 
the Health and Safety Committee and to any other 
authorized union representative. 

a.) A plan showing the size and location 
of fields and a list of the crops or plants being 
grown . 

b.) Pesticides and economic poisons used 
including brand names plus active ingredients, regis- 
tration number on the label, and manufacturer's batch 
or lot number. 

1. Dates and time applied or to be applied. 

2. Location of crops or plants treated or 
to be treated. 

3. Amount of each application. 

4. Formula. 

5. Method of application. 

6. Person who applied the pesticide, 
c.) Date of harvest. 

The Union also included in its proposal, requirements relating 
to sanitation and tools and protective equipment. It is the 
United Farm Workers Organizing Committee's position that the 
subject of economic poisons is a necessary and proper subject 
of collective bargaining in the field of agriculture. 

The 12 growers with whom the United Farm Workers Organizing 
Committee was dealing would not agree not to use DDT on table grapes 
even though DDT has now been banned in Michigan, Arizona and Sweden 
and hopefully will be banned in California by 1971. Furthermore, 
the 12 growers with whom the United Farm Workers Organizing Committee 
was negotiating desired that the Union agree not to discuss the 
use of economic poisons publicly. The United Farm Workers 
Organizing Committee will not be blackmailed by 12 growers, they 
will not exchange a contract for their right to discuss impor- 
tant issues both to the workers and to the consumers. The Union 
will not be muzzled on this issue. 



3011 



•3- 



The United Farm Workers Organizing Committee 
subsequent to the end o£ negotiations has begun to examine 
the conditions of the table grapes which are currently being 
sold throughout the United States. 

As Page 27 of the Kern County Agricultural Commissioner's 
Report shows, 1,046 acres of grapes in Kern County alone were 
sprayed with economic poison Amino Triazole. This is the same 
poison that was used on cranberries in the late 1950 's and caused 
the confiscation of the cranberries which were so treated. 
This poison is known to cause cancer in small mammals such as 
rats. This chemical has a tendency to cause malignant tumors of 
the thyroid glands in mammalian system. However, it is impos- 
sible to tell from the records that are currently available to 
the public which particular grapes were sprayed with this poison. 
Therefore to eat a Kern County grape is to play Russian roulette 
with one's health. Furthermore, the United Farm Workers Organ- 
izing Committee has taken tests of grapes which are now being 
sent to market. Thus far, we have sampled grapes from the fields 

of different growers and in each instance DDT residues has 

been found on these grapes. This is, despite the fact that 
the state director of agriculture in the state of V.'ashington said 
that grapes are remarkably free of chemical residues. It also 
flies in the face of a statement issued by the California department 
of agriculture claiming that grapes were safe . Many recent 
studies have shown that DDT which is stored in the body fat of 
humans, cause carcinogenic tumors in mice. The most recent of 
these studies is from the journal of the National Cancer Institute 
appearing on page 1101 and entitled, "Bioassay of Pesticides and 
Industrial Chemicals for Tumorigenicity in Mice: a Preliminary 
Note." It is the position of the United Farm Workers Organizing 
that grapes which cannot be peeled in a manner that bananas and 
oranges can should contain no DDT when they go to market. 

It is very clear that as long as public officials make 
statements that grapes contaminated with DDT are safe to eat, 
they are not serving the interests of the consuming public. 



3012 



It is clear to the Union that to ban DDT we must take the route 
of collective bargaining. 

Perhaps the most painful proof of the inadequacy of current 
governmental regulations is the one year battle which the farm 
workers have waged to see public records relating to the use of 
economic poisons in Kern County, California. 

During the summer of 1968 many farm workers came to 

visit the legal office of the United Farm Workers Organizing 

Committee and complained of symptoms varying from eye irritations 

and rashes to dizziness, nausea, vomitting, double vision, after 

having been in contact with sprays and dusts as the workers call 

it. In order to find out what materials are being used at what 

locations and what exact time, I visited the Kern County Agricul- 

Morley 
tural Commissioner, C. Seldon/on the morning of August 22nd, 1968, 

I was told by commissioner Morley to return to his office on the 
following day. I was interested in seeing two types of records, 
permits to use injurious materials and the reports of commerical 
spray applicators on how the materials were used, that is under 
what wind, and weather conditions, in what quantity and formula, 
at what locations, and during what time. I left the commissioner's 
office at approximately 11:30 in the morning. At 1:34 in the 
afternoon a temporary restraining order was issued by the Kern 
County Superior Court preventing me from viewing the records 
of the commercial spray applicators. Subsequent to this, the 
United Farm Workers Organizing Committee did everything within 
their power to work this problem out privately without creating 
a public scandal over the mis-use of economic ipoisons in the grape 
vineyards. We did this believing. that the fastest way of pro- 
tecting the workers and the consumers was not by creating public 
hostility but rather by working the problem out through private 
agreement between the farm workers , the grape growers and the 
pesticide companys . We informed the growers that even if they 
did not want to enter into collective bargaining negotiations 
with us that at least they sit down and talk to us about the use 
of pesticides. 



3013 



•s- 



Rather than take the matter to a trial in the Kern 
County Superior Court which would have necessitated a factual 
disclosure of the mis-use of economic poisons and thus lessen 
the possibility of private agreement, the United Farm Workers 
Organizing Committee chose to appeal the temporary restraining 
order by challenging only the legal basis under the California 
statutes of the decision to withold the records from the public. 
Therefore, the United Farm Workers Organizing Committee commenced 
an extraordinary original proceeding in the court of appeal for 
the 5th district seeking to prohibit the superior court from en- 
forcing a temporary restraining order on strictly legal grounds. 
The court of appeals stated in its decision of November 8, 1967, 
that exceptional circumstances justifying the resolution of the 
legal issue before the factual issue was heard at the trial court 
level were not in evidence and they therefore denied the farm work- 
er's writ of mandate. Subsequent to that the United Farm Workers 
Organizing Committee on December 16, 1968, intervened in the 
case of Atwood Aviation vs. Seldon C. Morley, the agricultural 
commisBdoner of Kern County. We commenced the discovery process 
in this case to examine the public need for seeing the records 
concerning the use of economic poisons in Kern County. 

However, the farm workers made a further effort to 
reach a private agreement with the pesticide companys and the 
growers to quickly solve this problem. Therefore, on January 7, 
1968, as general counsel for the farm workers I wrote to Stephen 
Wall, who represented the pesticide companys and I proposed an 
agreement bwtween the pesticide companys, the agricultural 
commissioner, the table grape growers and the United Farm Workers 
Organizing Committee. In that agreement, the farm workers pro- 
posed to obtain the following information to adequately insure 
that workers were protected when they worked in the fields. 

1. The following information currently on record with 
the Commissioner of Agriculture should be turned over to the 
United Farm Workers Organizing Committee: 

a) A description and location of all properties 
treated with injurious materials. 



3014 



-6- 



b) Date of the treatment 

c) Material and dosage used 

d) Number of units treated 

e) Type of crop involved 

f) The identity of the equipment used 

g) If applied by airplane, the name of pilot or 
pilots who applied the treatment. 

h) The temperature and wind conditions during the 
time of the treatment 

i) The name of the grower or grower representative 
for whom the treatment was applied 

2. All growers who used their own eqipment to apply 
dangerous pesticides must deliver the following information to 
UFWOC: 

a) Description of properties and location of 
property treated 

b) Date of treatment 

c) Material and dosage used 

d) Identity of equipment used 

e) Brief description of qualifications of person 
applying dangerous materials 

f) Statement of tolerance level for workers and 
consumers for each kind of injurious material 

g) Disclosure of amount of geybral used in vine- 
yards and number of applications of geybral 

3. All growers shall inform the United Farm Workers 
Organizing Committee three (3) days in advance of application 
of poisonous materials. 

4. Growers shall post written warnings in fields in 
which injurious materials have been applied. Such warnings 
shall be in Spanish and in English and shall state in letters 
six (6) inches high the name of the material which has been 
applied and the date on which the field will become safe to 
work in. 

The response which Mr. Wall wrote to us is contained in 
a letter which I am filing before this committee, Mr. Wall re- 



3015 



sponded in part as follows; 

"I understood you to say also that you might now be 
satisfied with receiving from the subject reports 
that are now filed only those portions of data con- 
tained therein which could reasonably relate to the 
announced aim of your clinic in Delano primarily 
that of improving general health of agricultural 
workers in the area as well as the standards of 
safety applicable to their working conditions. 
I understand you to say also that your only other 
interest in seeing these specific reports on file 
now, was for your use in formulating some per- 
tinent contract language for future use in nego- 
tiating labor contracts hopefully. You definite- 
ly stated that you were not interested in seeing 
the subject reports for using any part of the 
contained data in connection with your boycott 
efforts or as a basis of filing any lawsuit or 
lawsuits, but here is what you come back with. 
You want the name of the grower, the name of the 
airplane pilot, the name of the material and 
dosage used, the legal description of the prop- 
treated, the exact date of the treatment, and 
so on. These you intend to use in connection 
with your Delano clinic or in negotiation of 
future contracts? Your actual purpose is 
clearly evident, and there is not even a coin- 
cidental resemblance to the one you expressed, 
but the ends justifys the means in your league- - 
right?" Very truly yours, Stephen E. Wall 

I responded to Mr. Wall by assuring him that the 

information which we asked for was absolutely necessary to 

protect and reasonably and adequately develop safeguards concerning 

the use of economic poisons in the vineyards. However, Mr. 

Wall did not response to my subsequent letter of January 9th. 

Therefore, on January 14th Cesar Chavez wrote a letter to the 

table grape industry which is being submitted with this statement. 

The letter reads in part as follows: 

"There is one critical issue of such overriding 
importance that it demands immediate attention even 
if other Tabor relations problems have to wait. I 
mean the harmful effects of spraying grapes with 
pesticides or economic poisons as they are called. 
We have recently become more aware of this problem 
through an increasing number of cases coming into 
our clinic. We will not tolerate the systematic 
poisoning of our people... we will be damned and we 
should be if we will permit human beings to sustain 
permanent damage to their health from economic 
poisons. We are willing to meet with your rep- 
resentatives on the sole issue of pesticides even 
if you are not prepared to begin full scale collec- 
tive bargaining at present. These talks would go 
on even as we pursue our final aim of fair agreement." 

The growers did not respond to this letter in any 

way and so the farm workers had no alternative but to take 

the matter of the use of economic poisons to a public trial 



36-513 O - 70 - pt. 6A - 2 



3016 



which took place on January 29th and 31st and was finished 
on February Sth, 6th and 27th. At that hearing the farm workers 
introduced a vast amount of evidence which was overwhelming 
regarding the peril to farm workers health of pesticide poisoning. 
An official report of occupational disease compiled by the state 
department of public health for Kern County for the year 1967 
alone contained over 95 pesticide related injuries. 

Enclosed are excerpts of testimony from various witnesses. 
Thomas Milby who is the chief of the Bureau of Occupational 
Health in the State Health Department testified in part as follows: 
Q Now, you mentioned organic phosphate compounds. 
Could you give us examples of those in economic poisonings? 

A There is a long series of them. Parathion, 
TEPP, Diazion, Azodrin, and others. 
Q And others? 
A Many others . 

Q These different pesticides, you say, actually 
destroy the Cholinesterase? 

A They inhibit. They unite chemically with the 
Cholinesterase and inhibit its action in the destruction of 
this material Acetylcholine; and therefore, a nerve which is 
under the effect of the organic phosphate compound. This 
compound, which allows the impulse to go across, is not 
destroyed; and, therefore, you have a short circuit and a 
continuous nerve action. 

Q Can you explain the effect on the human body 
by that short • circuit? 

A Yes. This setup -- this particular physiological 
setup is in only certain parts of the body; that is, there 
are a number of several kinds of -- several nervous systems 
involved, and I won't go into a technical description of these. 
But the upshot is this -- that in the certain systems such 
as certain glands, such as the sweat glands, the salivary 
glands, and certain other glands are involved here, as well 
as certain of the voluntary muscle systems; therefore, in 
an individual who's under the influence of the organic 



3017 

-9- 

phosphates, who has -- will have such things as muscle 
twitching, muscle paralysis, slavation. They will have 
difficulty breathing because of secretions which are built 
up because of this action. They will have pupillary con- 
striction, which we call myosis. And you will have excessive 
sweating. You will have nausea and vomiting. You will have 
headache because of the central nervous system effect of 
this thing, and you will have several other symtoms . 

Q Can that be lethal? 

A Yes. 

Q Has it been lethal? 

A It has been lethal. 

Q Do you know if it has been lethal to farm workers? 

A It has been 

Q Do you know, for instance, which kind of pest- 
icides have caused fatalities to farm workers? 

A Yes. I know from personal experience that 
Phosdrin, TEPP, which we spoke of before, Parathion, for 
three examples. All have been. 

Q Dr. Milby, you talked about -- excuse me if 
I mistate this -- pupillary constriction, and headache. 
In your experience, do people who have been poisoned by 
Parathion, for example --do they lose their sense of judg- 
ment? 

A Well, they could, yes, but primarily because 
they are ill -- because they are exceedingly ill. And the 
usual picture of Parathion poisoning is headache, nausea, 
vomiting, and the other things I spoke of -- heavy sweating 
and difficulty in breathing. And, of course, under those 
circumstances, one could lose their judgment, but the com- 
pound itself would not primarily affect judgment. 

Q I understand, but can it, because of the 
illness involved, cause a dizziness? 

A Yes. 

Q Do you have any idea as to the long-term 
effects of acute poisoning by Parathion, assuming the 



3018 

-10- 

person lives? 

A It is very difficult problem. There is not 
much known about it, but in my clinical judgment, in my 
experience, individuals who are poisoned by the organic 
phosphates, primarily Parathion, take a long time to re- 
cover. It may take months. And during this recovery 
phase, they have loss of appetite. They have lassitude, 
and they have symptoms which are difficult to evaluate. 
But they certainly have symptoms for many months, but in 
terms of years -- no, I think not. 

Q Have there been any pesticides which you 
feels may cause permanent nerve damage? 

A Yes. There have been several pesticides 
which have shown to have produced permanent nerve injury. 
These have not been used in California or elsewhere in 
this country to my knowledge, because the evidence that 
they produce permanent injury appeared during their early 
phasi- of production, and they were withdrawn. But to 
my knowledge there are no compounds used here which pro- 
duce permanent nerve damage. 

Q Doctor, have you done any work in regards to 
Malathion? 

A Yes. 

Q Is that a fairly nontoxic organic phosphate? 

A Malathion is a compound which is handled very 
well by the warm-blooded animal; therefore, it is not 
very toxic to warm-blooded animals. It is quite toxic to 
insects . 

Q In terms of this pesticide, Malathion, what 
would be the kind of dosage of concentrated Malathion to 
kill a human being? 

A It would be several ounces. 

Q How about Parathion? 

A The toxic dose to an adult human being of 
Parathion would be more on the order of half a teaspoon. 

Q And what about TEPP? 



3019 



-11- 



MR MR. JORDAN: Objection, if you will. Do I 
gather we are talking about taking it orally? 

THE WITNESS: Yes, sir. 

MR. JORDAN: Thank you. 

THE WITNESS: The compounds are also toxic by skin 
absorption, but I was referring to oral dosage. 

Q (By Mr. Averbuck) And TEPP -- how much orally 
would that take? 

A In a rough approximation, several drops. 

Q Several drops could kill? 

A Several drops would be a lethal dose --of 
lethal TEPP. 

Q Now, the point has been brought out that this 
is the oral toxicity for lethal dosage. Is it possible for 
the human body to take these pesticides in any other avenues? 

A Yes. The other two avenues -- routes of entry -- 
are through the skin -- through the intact skin, and also 
through the respiratory system -- through inhalation of dusts 
or mists. They are somewhat less toxic. Some of them are 
somewhat less toxic if applied to the skin. Some are more 
toxic by skin than by mouth. Respiratory toxicity is not 

we 11 -under stood. 

* ****** 

Mr. Thomas C. Griffin, the owner of a pesticide 
company, under cross-examination from David Averbuck 
testified as follows concerning an injury which occurred to 
him personally. 

Q (By Mr. Averbuck) Would you please explain 
the incident of when you got ill because of TEPP? 

A I was flagging some TEPP over a very long period 
of time, and I did not take what were rtcirmally considered 
the proper precautions. At this time I was in charge of 
pest control just prior to going into business for myself 
a long, long time ago, but briefly, that is what happened. 

Q And how did you know you became ill from TEPP? 



3020 



•12- 



A I had the common symptoms that one would 
suspect I have. I had pinpoint pupils. Vision was 
blurry, headache, sweating of the palms, and so on. 

Q Did you have nausea? 

A Yes. 

Q And flid you have trouble breathing? 

A A little congestion. 

Q In other words, you were good and sick. 

Q Now, finally two points. I think this will 
sum it up. You talked about washing the grapes. 

A That is correct. 

Q Now, that was a little bit surprising because, 
am I correct in gleaning from your testimony, that you are 
saying that you wouldn't want this information out because 
you want to keep it hidden from the public? 

A Not from the public at all. Certainly not from 

the public. What I am trying to say is this: That over the 

course of time, because of the way it was done, there was 

that 
a general feeling by buyers that grapes/have been washed were 

not good grapes to buy because their appearance had been 

somewhat destroyed, and certainly in the past this was so. 

So, during the course of histiivy of washing grapes, the term 

"washing", making an application, at this time became very 

very detrimental to the growers, and he was not interested in 

having anyone know this was done. 

Q Even the buyer? 

A Even the buyer. I am saying, however, that 
this kind of wi.rk can be done today and is often done today, 
and with the appearance of the grape being perfectly natural , 
because of the techniques that are used. 
A * * * * * * 

Seldon Morley, the Kern County Agricultural 
Commissioner, the official who is supposed to be responsible 
for taking all steps necessary to protect farm worker and 
consumer health testified as follows: 



3021 

-13- 

Q Mr. Morley, have you notified the Department 
of Public Health of Kern County that they should keep in 
contact with you if they did hear of any injuries in Kern 
County due to economic poisons? 

A Not so far, no, sir. 

Q Had you contacted the State Department of 
Public Health? 

A No, sir. 

Q Have you contacted any doctors? Have you con- 
taced anybody? 

A No, sar. 

* ***** 

In discussing the danger to health of many 
of the poisons used in table grapes, Edward Lester, Pres- 
ident of the Central California Medical Laboratories, a labor- 
atory in Fresno which conducts cholinesterase tests, testi- 
fied as follows: 

THE WITNESS: The Cholinesterase tests is a specific 
measure of nervous damage. It is run in two parts, as I 
said before. Plasma and red blood cells. It is essential 
that we determine a specific level in every individual before 
exposure, so that we have some basis of comparison during the 
coming season, or in the years to come. Now, this is called 
an individual worker's base line. Everything else will be 
compared tc this base line. 

Now, at the tine of exposure, if this is a person's 
base line of red blood cells and plasma, and exposure is 
at this period, the plasma is the first one to go down. It 
is also the first one to return to normal after that worker 
is no longer exposed to organic phosphates. The RBC follows 
in this manner. It trails behind the plasma, and this is the 
one that we are most concerned with in that RBC is the one 
that reflects more precisely the status of the central nervous 
system. Once the RBC goes down, it will delay a long time 
before coming up. 

Now, from an economic standpoint, this means that 
if we can detect early changes in the plasma, it is very 



3022 



-14- 



easy for us to recommend that such a worker be removed 
immediately from further exposure, and long before the 
RBC starts to drop and becomes dangerous. 

This means that we are not dealing yet with 
clinical symptoms, acute symptomology , but rather we are 
dealing with the first preliminary indication of poisoning, 
and that further exposure will precipitate the clinical 
symptoms that have been described here today. 

Now, if the worker can be removed by running 
these tests at an early enough stage, we are speaking 
then of removal from the job on one day, two days, three 
days, or a week. But once the RBC goes down, we may be 
speaking of a poisoning situation which may not return to 
normal for perhaps a month or longer. So, it is essential 
that we identify poisoning long before clinical symptoms 
appear. 

Now, the curve I have drawn here are nice slopes. 
Actually it doesn't work quite that way. Every individual 
has different reserves to accommodate loss of Cholesterase , 
as was explained to you by Dr. Milby. Now, we find that 
when we give an individual with exposure at this point, 
we find that nothing happens for a considerable length of 
time. These are reserves that every individual has. 
Further exposures -- they reach various plateaus, various 
plateaus. In other words, it's not an even drop in Cholin- 
esterase. What I am saying is that at this point, unless 
this worker were identified, even a small minor exposure 
will precipitate a fantastic drop in Cholinesterase . I 
personally have seen this drop from a normal level to this 
point in less than 30 minutes. At this point, clinical 
symptoms appear. The victim is prostrate, and we are talking 
about an emergency situation often requiring heroric measures. 

* A * A * A A 

Mr. Allen B. Lemmon, Assistant Director, State 
Department of Agriculture, who has responsibility for 
promulgating regulations as to when crews can enter the 



3023 

-15- 

fields after they have been sprayed with economic 
poisons, testified in part as follows: 

Q Currently, what is the time span that 
might elapse before a farm worker can go in the field 
after Parathion has been applied? 

A It depends upon the quantity that has 
been applied as to what can be a safe length of time 
that must elapse. 

Q Isn't fourteen days the recognized time? 

A There are some cases where labels specify, 
because of particular dosage, that it must be longer than 
that. 

Q And what is the longest that you know of? 

A I recall some of twenty-one, and I am not 
sure whether there are any twenty-eight now or not. They 
have varied at various times according to the best infor- ' 
mation the health people can give us. 

Q Now, do you remember in the 19S1 incident, 
how long after application did the workers go into the 
fields? 

A My recollection from that article was 33 days. 

Q Thank you. I have no further questions. 
******* 

Robert Van Den Bosch, a professor of entomology 
from the University of California testified in part as 
follows : 

Q And water pollution? Is this not an area 
that concerns you as one who is interested in the integrated 
control of environment? 

A Well, of course. This is one of the reasons 
why I am interested in integrated control, because it will 
bring about a rational and scientific and minimized use of 
these highly pollutant agricultural chemicals that we are 
dealing with. 

Q You don't recommend, of course, that at 
present time we -- I will withdraw that. Are you a competitor 



3024 



■16- 



of the plaintiff in this action? 

A No. 

Q Do you have any type of private practice 
or private employment? 

A No. 

Q You don't consider then that your school 
necessarily would conflict with the pest control operators? 

A I think it will conflict with the pest control 
operators, and I think it will conflict with the chemical 
industry, because fundamentally, pest control as it is now 
practiced in the State of California and in the United States 
of America, is essentially not an ecological matter. It is a 
it is largely a matter of merchandising, and this is a fun- 
damental problem in the whole matter of the pesticide prob- 
lem that we are confronted with today. In essence, we are 
using the wrong kind of materials in the wrong places at the 
wrong times in excessive amounts, and engendering problems 
which increases the use of these materials, adds to the 
pollution problem, adds to the cost of agricultural pest 
control, adds to the -- you might say -- the concern of 
the general public, and in this essence I belong to a 
school of entomological research and pest control phil- 
osophy that is at odds with these people. But "this is 
not an overt attack on either the pest control advocates 
or the agricultural chemical industry. It simply happens 
to be that this is one philosophy based against another. 
And the answer to the situation is -- which will prevail. 
Believe me, having been in this situation for twenty years, 
it's a long, tough fight and it's a long, tough fight ahead. 
****** 

Despite the overwhelming evidence of the harm 
caused by economic poisons Judge George Brown ruled that 
the records were not be seen. He ruled in part, "The im- 
portance of the agricultural chemical industry to this valley 
and this state is enormous, not only in terms of the employ- 
ment and income which it generates but in terms of the astro- 



3025 



•17- 



nomical increase in productivity and improvement in quality °f food 
and fibre that has accompanied widespread use of agricultural 
chemicals . " 

Clearly in weighing the interests of the workers against 
the interests of the industry, Judge Brown recognized that at 
least in Kern County the interests in making profit outweighs 
the interest in the health of farm workers and consumers. 

Subsequent to that time, the United Farm Workers Organizing 
Committee has taken legal steps to try and ban the use of DDT. 
David Averbuck, my associate, has filed suits in state and federal 
court to attempt to ban the use of DDT. Subsequent to that time 
the Farm Bureau has come out discussing the harmful effects of 
DDT and the state senate has currently proposed a ban on DDT in 
the home. Finally, they have proposed that all DDT be banned 
in California by. 1971. 

The United Farm Workers Organizing Committee's position- 
is as follows: 

If DDT is harmful to consumers in 1971 it is just as surely 
harmful to them now. 

Therefore, the United Farm Workers Organizing Committee 
is currently embarking upon a testing program. So far, we have 
tested the grapes of Karahadian, Mel-Pak, Bagdasarian Ranch, 
Glass, Heggblade-Marguleas and Delano grapes from a Bank of America 
field. All of these grapes were found to contain DDT. We have 
tested grapes in Sacramento, in Seattle and Buffalo, and the grapes 
from the chain stores in these cities were found to contain DDT. 

It is not surprising to the farm workers that the table 
grape industry should continue selling contaminated grapes. The 
table grape industry has shown its irresponsibility in various 
ways throughout the 4 year struggle to unionize that industry. 
They have persistently refused to obey the sanitation laws of 
the state of California. They have persistently recruited workers 
illegally from Mexico to break the strikes of American residents. 
They have extensively used illegal wetback labor. They have fired 
people for union activity. They have mislabeled grape in order 
to deceive the public into thinking nonunion grapes were union grapes. 



3026 



■18- 



Now they are using DDT and other chlorinated hydrocarbons, and, 
as we have just discovered from the Kern County Agricultural 
Cominissioner' s report, Amino Triazole even though they know that 
this creates unknown dangers to the American consuming public. 

Had the table grape industry discussed the problem of 
economic poisons with the farm workers and had we worked out an 
agreement similar to the one which we proposed in our recent 
negotiations the problem could be well on its way to being solved. 
However, the growers have prevented this. Therefore we must now 
take our case to the public and to the United States Senate in 
hopes that some relief will be forth coming. 



3027 

Mr. Cohen. Last year in the Coachella Valley various farmwork- 
ers came to see Cezar Chavez and described various times they have 
been in the fields and have been sprayed by the spraying apparatus. 
Subsequent to that in Kern County in the southern San Joaquin 
Valley, farmworkers came to us and described further injuries. 

Last August 19 I went to see the Kern County agriculture com- 
missioner, Mr. Morley, and I asked Mr. Morley to see the records of 
the commercial pest control operators. There are two types of rec- 
ords, and there are two types of problems that I think this commit- 
tee should be aware of. First of all, in the State of California, only 
commercial applicators have to account for what chemicals they use 
in what amounts at what times, and how soon the crews can go in 
the field. The grower does his own spraying. He does not have to ac- 
count to anybody as to how he uses those chemicals. That is one 
problem I think this committee should address itself to. 

Senator Mondale. Does the grower need a permit to apply pesti- 
cides, or is it just the commercial applicator? 

Mr. Cohen. In California, both grower and commercial applicator 
need a permit to use the material. However, it is only the commercial 
applicator who must account to how he uses this material. 

Furthermore, even though the commercial applicators have to 
account to the commissioner as to how they use the chemical, when 
we sought to see the public records on what chemicals were used, we 
were denied access to these records. I saw the agriculture commis- 
sioner on August 22. He told me to come back the next day to look 
at the record. Two hours after I left his office there was a temporary 
restraining order issued which was used for restraining seeing pub- 
lic records on the ground it was trade secret, that formula of the 
chemicals was a trade secret. 

It is known that it would take but a drop of parathion to kill you 
and we think that the public interest in seeing that farmworkers and 
consumers know what is being sprayed outweights the economic in- 
terest of the pesticide companies. 

So we attempted to negotiate with both pesticide companies and 
table-grape industry concerning their use of economic poisons. I ap- 
proached the attorney for the pesticide companies and asked them to 
disclose information, and they refused to disclose it. 

On January 14, Cesar Chavez wrote a letter to the grape industry 
and asked them to sit down and talk the matter over with the farm- 
workers because they won't tolerate the systematic poisoning of 
farmworkers any longer. They refused to respond to that. 

(The Chavez letter and other documents and references, appear at 
the close of Mr. Cohen's testimony, starting at p. 3039.) 

Mr. Cohen. In January we took the injunction to trial and dur- 
ing the course of the trial we had testimony as to the extent of inju- 
ries that had been reported to the State. Some 95 injuries in 1967 in 
Kern County alone reported to the State department of public 
health. I think this has to be understood in the context of the degree 
of knowledge that the farmworkers had about this problem. 

Senator IVIgndale. Those injuries are in Kern County, and 95 
workers reported to the State department of public health that they 
had problems relating to pesticides ? 

Mr. Cohen. That is right. 



3028 

Senator Mondale, I want to point out that in Tulare County we 
had our organizers interviewing farmworkers for 2 months for prep- 
aration for this hearing, and m preparation for taking the case to 
the public. Of the 600 workers interviewed, about 540 had symptoms 
relating to pesticides. They had eye injuries and nausea. In terms of 
95 injuries, I think that is part of the type of injuries that we are 
reviewing. We presented evidence of those 95 major injuries. 

We also asked one of the State officials in the State of California, 
Mr. Lemmon, who was responsible for promulgating regulations as 
to how soon a crew could go into a field after parathion is used, 
what their criteria are. In that particular instance, Mr. Lemmon told 
us that if a pound were used on ten acres, a group could enter the 
field 14 to 21 days after the application of parathion. This was de- 
spite the fact that we had access to an article written by ]Mr. Lem- 
mon concerning workers in the grape vineyards who entered the 
field 33 days later and 12 out of 16 went to the hospital. 

(The article referred to appears elsewhere in the printed record of 
this hearing.) 

Mr. Cohen. We think currently the state of regulation in California 
is inadequate because the time period obviously isn't long enough. 

Mr. ^lorley, who was Kern County agriculture commissioner, was 
asked if he had contacted anybody from the department of public 
health relating to the issue of farmworker injuries, and he said no, 
he hadn't. Then he was asked if he contacted anybody from the 
medical profession. 

Mr. Averbuck asked, "Have you contacted the State department of 
health?" He answered "No." He asked, "Have you contacted any doc- 
tors ? "No, sir." 

This man, Mr. Morley, had responsibility for farmworker health 
in the county of Kern. He has not contacted anybody in the State 
department of public health, any doctors, to investigate the extent to 
which farmworkers are injured. 

This is to say nothing about the effect of the DDT and parathion, 
and cranberry poisoning on consumers. We are talking about farm- 
workers now. Furthermore, at that hearing the director of the State 
department of public health. Dr. Milby, testified as to a death which 
occurred because of parathion poisoning. 

Senator Mondale. Was this a farmworker death ? 

Mr. Cohen. This was a farmworker, yes, sir. That death had oc- 
curred even though the man had entered the field long after the pre- 
scribed time by the regulation. What they had done in that case was 
apply parathion to a certain amount of acreage. Then they applied 
the same amount of parathion to the same acreage and even though 
both applications of parathion were in and of themselves in accord- 
ance with the regulation, together they caused the parathion to 
break down into paraoxon which is even more deadly. So it resulted 
in death. 

Mr. Morley's response to the question was, "We live and learn." 

It seems to me that is not an acceptable response to the farmwork- 
ers. 

As to the status of the case, even though we presented all of this 
information, the judge decided that we didn't have a right to see the 
records and the reason we didn't have a right to see the records was 



3029 

because he said, and I have it in my statement, he said that the pes- 
ticide industry was responsible for an astronomical increase in the 
quality of food and fiber and had brought much income into Kern 
County. 

Because of the testimony of one of the witnesses of the pesticide 
company, he thought what we were doing would jeopardize the pes- 
ticide companies. 

I want to explain how that works. Mr. Griffin testified on behalf 
of his company. He stated that being a commercial pesticide appli- 
cator, he had to account to the State for the way in which he used 
these chemicals and if the farmworkers or anybody else saw how he 
used the chemicals, that would only make a big grower apply his 
own poisons to his own grapes, and when the private grower uses a 
chemical, he doesn't have to account to anybody as to how he used it. 

Mr. Griffin went on to say that the grape growers are doing things 
they don't want their buyers to know. They are washing grapes, he 
didn't go into details of what they meant, and he doesn't want the 
public to know what is going on. 

I think Mr. Griffin was telling the truth when he said that. What 
the judge did was balance that against our interest in seeing that in- 
formation. I think one of the problems we are faced with now is the 
problem that the farmworkers in California do not have access to 
any information as to what is being used in specific fields. And I 
want to give some recent examples as to what kind of thing can 
happen. 

Last Friday some workers were sitting in the field and they were 
eating. They were taking a break in the late morning. A ground-rig 
spray came down the vineyard two rows away from them. They got 
up and shouted at the man operating the ground rig. He saw them 
and he heard them but sprayed them anyway. Six of the people 
began to vomit and they were dizzy for 2 days. 

We can't go to the agricultural commissioner and see the informa- 
tion very quickly. What we have had to do is get some soil samples 
and grapes and test them. 

Senator Mondale. When did this happen ? 

Mr. Cohen. This happend Friday, the 25th. 

Senator Mondale. You say the pesticides were sprayed right on 
the workers? 

Mr. Cohen. They were sprayed on the workers sitting there hav- 
ing a little break and they were eating. It was about 9:15 in the 
morning. They had gotten in the field at 6. They have a break at 
9 :15 in the morning, and then they have lunch. 

Senator Mondale. They became nauseous? 

Mr. Cohen. They became nauseous and three of them vomited. 
That kind of thing happens a lot. That is an arrogant disregard for 
the farmworkers in the field. 

Senator ISIondale. Is it unusual for a worker to actually be 
sprayed ? I can see the problem of workers going into a field to work 
just after it has been sprayed, say within a day or two, or three, or 
however long it takes for danger to disappear, if it does. But, it is 
something else if there are actually instances in which the worker is 
sprayed by pesticides ? Does this occur often ? 



3030 

Mr. Cohen. It occurs quite frequently, Senator. It doesn't occur in 
flagrant manner, as it occurred to these workers. It usually occurs 
because, since the growers don't have to account how they use the 
pesticide, they don't have to account to the agriculture commis- 
sioner as to the wind directions. So what they may do is spray in 
the field and not take into account the wind and drift. Some w^ind 
and drifts may reach workers 10 rows down. That happens quite 
often. The kind of example I gave you that occurred last Friday, 
that doesn't happen very often. It was the kind of thing that caused 
us to begin to investigate the records and it doesn't happen as often 
as the accidental injury to farmworkers. 

But there is another aspect to it, and that is that our pickets get 
deliberately sprayed. On Saturday the 12th we were picketing "Lost 
Hills" near Delano and a man affiliated with the Farm Bureau 
turned on a tank of ammonia gas and he sprayed and gassed the 
picket line. I asked the officers of Kern County to help me turn that 
off and they refused, so I got to a city policeman and he and I had 
to go and turn off the ammonia gas and make this man who works 
with the Farm Bureau turn off the ammonia. 

Saturday the 26th we were picketing the S. A. Camp farms. There 
were about 16 pickets on the line at that time. One of the former 
foremen of S. A. Camp brought a ground rig down the row and 
sprayed lindane on the pickets. Those kinds of things do happen. 
Those kind of injuries take place. 

That is one of the reason I say we are dealing with a type of ice- 
berg is because the kinds of injuries that we are talking about are 
very subtle and you know, for instance, farmworkers consider rashes 
as a way of life. Five hundred and forty people who reported inci- 
dents of illness to us in Kern County in the last 2 months consider 
when they go in the field they are going to get a rash. 

Senator Moxdale. How does the rash manifest itself? 

ISIr. CoHEX. On the skin it has open sores, sometimes there are 
bumps on the hands, there are bumps on the le^s, and faces become 
swollen. That usually follows the nausea and dizziness that occurs. 

Senator Moxdale. Are these rashes rather common in the field ? 

Mr. CoHEX. They are very common in the field and they are ac- 
cepted by the farmworker in the field. The other thing which is 
frightening, is that farmworkers do not know the word parathion, 
even though it is being bought by the Government as nerve gas, it 
was developed in World War II as a nerve gas and even though it 
is used in diluted form as chemical poison, it still has those effects 
on nervous systems of farmworkers if they enter the field too soon. 

About 70 percent of the workers we have talked to don't even 
know what parathion is. They know what DDT is and they know 
there is DDT on grapes, but they don't know what parathion is. In 
terms of danger to farmworkers, the organic phosphates such as para- 
thion are much more deadly and it should be restricted. They should 
be carefully restricted. 

In relationship to this, I should like to mention our recent experi- 
ence with 12 table grape growers who we were negotiating with. 
Those 12 growers broke up those negotiations over the issue of pesti- 
cides. They wanted us, the United Farm Workers, to sign an agree- 
ment whereby we would agree not to embark on any program re- 



3031 

garding pesticides that can in any way be detrimental or harmful to 
the industry to which the employee belongs. That was an ultimatum 
which they issued to us. 

In other words, in return for a contract on table grapes, they 
wanted us to shut our mouths about pesticides. The union's position 
was that it has a duty not only to workers but also to consumers who 
have been our friends in the national boycott and when we find 
DDT on the grapes, we are going to tell consumers about it. We 
have tested grapes of 13 growers so far and we have found DDT, 
DDE, or Aldrin on all 13. We wanted those growers to sign an 
agreement to very carefully regulate the use of organic phosphates 
poisoning. We wanted them to form health and safety committees. 
We wanted them to give farmworkers access to information which 
we currently can not get from the State Department of Agriculture. 

They won't agree to that. We wanted them to ban DDT. We know 
DDT has been banned in Michigan, it has been banned in Arizona. 
The senate of California last week was deliberating whether to ban 
it by 1971. We think any union contract that covers the grape 
should include a ban on DDT. 

Senator Mondale. We asked the California Department of Agri- 
culture to testify here, if they would, on this issue. We received a tel- 
egram that says it is not possible to have someone come to Washing- 
ton to testify. We will put this telegram in the record, along with a 
recent press release that office issued. 

(The material referred to follows:) 

Sacramento, Calif., June 31, 1969. 
Hon. Walter Mondale, 
Senate Subcommittee on Migratory Labor, 
Old Senate Office Building, 
Washington, D.C.: 

Not possible to have someone in Washington at 8/1/69 hearing. Califs pesti- 
cide regulatory program exceedingly effective in protecting persons, animals, 
and crops. Know of no one in Calif poisoned from use of DDT. We have re- 
ceived no reports of injury to farm laborers from use of DDT. Detailed state- 
ment for hearing record airmailed 8/30/69. 

Jerry Fielder, 
Director, California Department of Agriculture. 



Allegations by Grape Boycott Activists Branded "Untrue and Irresponsible" 
BY California Department of Agriculture, Jerry W. Fielder, Director 

State Director of Agriculture Jerry W. Fielder today branded as "completely 
untrue and irresponsible" the allegations being made by grape boycott activists 
that California table grapes are unsafe to eat because they contain residues of 
poisonous chemicals. 

These claims are made in the form of leaflets and mimeographed sheets 
I)assed out to customers at retail markets in many parts of the country. 
Fielder said. 

"We maintain tight controls and constant checks on spray residues on Cali- 
fornia produce," Fielder said. "And we have found that table grapes, like all 
other fresh fruits and vegetables, are remarkably free of chemical residues 
and perfectly safe to eat. 

"Last year we officially tested many samples of table grapes on sale in var- 
ious parts of the state and found no harmful residues on any of them. So far 
this year we have tested representative samples of table grapes grown in the 
Coachella Valley and found them similarly pure. 

"Department chemists conduct such tests for pesticide residue throughout 
the year to assure consumers of safe and wholesome foods. Each year we ana- 

36-513 O — 70 — pt. 6A 3 



3032 

lyze about 7,500 samples of fruits and vegetables in our chemistray laborato- 
ries to make sure they are free from illegal residues. California regulations 
specify the same stringent low tolerances for residues as those of the Federal 
Food and Drug Administration." 

Fielder added that besides being safe to eat, grapes are a healthful food, 
rich in food energy, high in Vitamin A and containing calcium and carbo- 
hydrates. 

"Consumers continue to buy, eat and enjoy California table grapes," Fielder 
said. "We don't believe many of them are being misled by the false statements 
in these leaflets. 

"But as one of several agencies responsible for the enforcement of laws reg- 
ulating the quality and purity of agricultural commodities, we want to go on 
record against these malicious attempts to destroy public confidence in Califor- 
nia table grapes." 

According to Fielder, the State Department of Public Health has reported 
that it has no knowledge of consumers of table grapes in California being 
harmed by pesticide residues. 

Senator Moxdale. They say that the California pesticides pro- 
gram is protecting persons, animals, and crops, and they know of no 
one in California poisoned in the use of DDT and have received no 
reports of injury to farmlabor from use of DDT. 

It is signed by Jerry Fielder, Director of California Department 
of Agriculture. 

Will you comment on that quoted portion ? 

Mr. Cohen. Yes, I would like to comment on that. I think that is 
an extraordinary statement from Mr. Fielder. The State right now 
is conducting a survey on farmworker injuries. We know they have 
interviewed people in Tulare County. Tulare County is adjacent to 
Kern County. We know at least 85 or 95 percent of the workers we 
have talked to have had adverse symptoms. Many know of deaths, 
many know of people who have gone to Mexicali and haven't re- 
turned after they have been subjected to parathion poisoning. I think 
Mr. Fielder is also aware of that. 

Mr. Fielder is also aware, I think, of 15 mothers who held a press 
conference in San Francisco last week and they have had their breast 
milk tested. In that milk they found they have four times more 
DDT than would be allowed if it were cow's milk. So they are nurs- 
ing their babies with milk that would be unacceptable for sale if it 
were cow's milk. 

To me that is poisoning because of DDT. Those mothers were 
going after the grape industry along with the union because they 
know we can't reform all of agriculture just because agriculture 
out of the goodness of its heart knows it is misusing pesticides. We 
have been negotiating with the grape industry and we know the sub- 
ject of economic poisons is necessary and proper subject in any 
collective bargaining and the mothers agree with this. They had a 
public press conference and Mr. Fielder knew of that. 

Senator Moxdale. Do you know of any people who became ill 
with rashes as a result of either spraying directly on employees, or 
drifting caused by wind or from entering a field too soon after 
spraying ? What would be too soon ? Do you have some notions about 
how soon employees ought to enter the field ? 

Mr. CoHEx. Yes. For example, parathion, according to Mr. Lem- 
mon, when we had him testifv at the hearing 

Senator Mondale. Who is Mr. Lemmon with ? 



3033 

Mr. Cohen. Mr. Lemmon is a member of the State Department of 
Agriculture. He has some responsibility for promulgating the regu- 
lation which controls when a crew enters the field which has been 
sprayed with parathion. Mr. Lemmon and Mr. Milby both admitted 
that parathion acted as nerve gas. Their position was that the State 
of California was adequately protecting farmworkers from the dan- 
gers of the nerve gas. 

Mr. Lemmon testified that if you had a pound of parathion and 
sprayed it on 10 acres in very diluted form — one drop of parathion 
on your eye or skin would kill you — so it has to be very diluted to 
use it in the field. That crew can enter the field 14 to 21 days later. 
But the problem that we have with that regulation is that we intro- 
duced an article that was written by Mr. Lemmon and that article 
concerned poisoning in a Delano vineyard. In that case, 12 out of 
16 workers ended up in hospitals and they entered the field days 
after the application of parathion. 

Senator Mondale. Is parathion being used ? 

Mr. Cohen. Parathion is being used. 

Senator Mondale. This was a case according to this doctor, where 
33 days after spraying, farmworkers entered the field and they got 
poisoned ? 

Mr. Cohen. Yes, and I think that points out that even the State 
officials don't know under all situations how parathion breaks down. 
There may be weather conditions that causes parathion to break 
down to paraoxon. That killed the worker Dr. Milby talked about in 
the hearings. In terms of protecting the workers, to get back to Mr. 
Fielder's telegram, he states he doesn't know of any adverse effects 
or poisoning of DDT in that telegram, yet last Friday in the 
Fresno Bee an article appeared, and I would like to give it to the 
committee, in which the University of California recommends that 
DDT not be used next year on the crops, and it is interesting to note 
that the only two crops it should be used on are cotton and grapes. I 
don't know how they can differentiate on putting it on cotton and 
grapes. You can't peel a grape. Mae West said, "Peel me a grape." 
But you know you don't peel any grape, you just eat the grape. 

So it seems to me that Mr. Fielder is indicating in the article that 
he may welcome University of California recommendations. So Mr. 
Fielder knows there are grave dangers because of DDT. What he 
does not, however, is that the union has a national boycott against 
grapes. So, what they want to do is say somehow DDT is safe to use 
on grapes, whereas it is not safe to use on other crops. That is incon- 
sistent. I hope that the Senator from California could ask Mr. 
Fielder that question. 

Senator Mondale. We were hoping they would accept our invita- 
tion to testify here. I think it weakens their case. 

Mr. Cohen. I am very sorry they didn't. 

The other thing I would like Mr. Fielder to account for is how 
1,046 acres of grapes last year were sprayed with amino triazole. 
That was the chemical used on cranberries. That chemical was said to 
have caused cancer in rats and maladjustments of thyroid glands. 

By the way, their recent studies on DDT came out m the June 
issue of Journal of National Cancer Institutes, which says that 



3034 

DDT causes carcinogenic tumors in mice. It has unknown effects on 
human beings. 

This is a newspaper from Mexico. It has very interesting; articles 
in it. This is probably the only protection North Americans get 
from DDT. It says cannibals in certain primitive islands in the Pa- 
cific — scientists from England discovered, have a propensity to 
eat English missionaries and English soldiers but they don't indulge 
in North Americans. The scientists did a study on it. They think the 
reason is that cannibals are naturally selecting out those people who 
don't have as much DDT in their bodies. So we have become unfit 
for human consumption. 

That may be the only thing that Mr. Fielder has done for Califor- 
nia, to protect cannibals in the West Pacific. I think that we have a 
serious problem. 

Senator Cranston. What was the second question you would like 
to have answered? 

Mr. Cohen. See, we are having a very major problem obtaining 
public records concerning the use of economic poisons. We filed a 
case in Riverside County and we can't get records as to how the 
growers are using the poisons. We can't get records in Kern 
County, Many of the countries don't even keep the record. But the 
records that are kept that we have seen have to do with the kind of 
chemical used on total number of crops. In other words, Mr. Morley 
of Kean County publishes a summary at the end of the year and 
now we have just received a 1968 summary which I have put before 
the committee in a little packet of materials — (printed at the conclu- 
sion of Mr. Cohen's remarks). 

In that summary it says grapes and then the kind of chemicals, 
amino triazole. That is the chemical that was used on cranberries, 
1,046 acres. We would like to know why they are using it, when 
using it, and which growers are using it. We would like to know 
which growers are continuing to use DDT. We have had to go and 
obtain grapes which, as you understand, is against every principle 
we stand for, and test them. We found on every grape we have 
tested DDT, or DDE, or aldrin, all chlorinated hydrocarbons that 
last a very long time and accumulate in the body. It would be a lot 
easier if we could have access to the records. 

I would like Mr. Fielder to make that a little easier for us. We 
have been fighting it in the court now for a year. The attorney gen- 
eral of the State of California has intervened on our side of the 
case. It is going to take time. In the meantime farmers don't know 
what is being sprayed on them. 

Senator AIoxdale. So the farmworkers who have to work in the 
fields and who have reason to believe, based upon expert judgment, 
that these pesticides present a risk to their health, today have no 
way of knowing when they go into a field whether the field is safe, 
or not? 

Mr. Cohen. That is correct. I would like to add one thing: It is 
kind of complicated but I think it is important that we understand 
this. The organic phosphates affect the chemical structure of the 
human body. If a man is exposed to too much organic phosphate 
poisoning such as parathion, he can become convulsive, go into coma, 
and die. In order to take preventive steps for the farmworkers until 



3035 

the chemical companies, (Shell and other chemical companies, 
should be developing that can kill bugs without killing humans), but 
\mtil they do, it seems to me that we have to take as careful a look 
at the situation and that as many preventive steps as we can. One of 
the steps we could take is to give all of the farmworkers a cholines- 
terase test. The way phosphates work, it inhibits the cholinesterates in 
the human body and cholinesterates allow the body to function, and 
when that drops, he is in trouble. 

In order to get what is called baseline test on farmworkers, we 
need to know what his normal cholinesterate level is. If we get a 
false baseline, we don't know when that man can be in trouble. A cer- 
tain amount of exposure, and Mr. Lester testified to all of this in the 
hearing we had last January, a certain amount of exposure may 
cause a man's level to reach a certain plateau and he may go along 
with that plateau for a while and then he may get another exposure 
and he may drop to another plateau. But there comes a point when 
he falls off the cliff. But to know what point is the danger point for 
any particular man, we need to have baseline tests, and to establish 
valid baseline tests, we need to see the records. 

Senator Mondale. Are you saying that a worker may be nearing 
this danger point by the intake of these poisons ? 

Mr. Cohen. Right. 

Senator Mondale. But the worker may appear to be perfectly 
healthy? 

Mr. Cohen. That is correct. 

Senator JNIondale, But at some point, with one small additional 
application or dosage, he may arrive at the critical point where his 
life would be in jeopardy? 

Mr. Cohen. That is correct. Senator. There are many articles 
written by Dr. Irma West from the State department of public 
health, and in her articles she says that over 3,000 children a year in 
the State of California receive some kind of injury from pesticides, 
either in agriculture or at home. 

Senator IMondale. Many times the workers will have their chil- 
dren with them? 

Mr. Cohen. Yes, they will. As a matter of fact, I talked to a lady 
2 days ago who had a little baby with her right near the edge of a 
vineyard in the car and a plane came over and sprayed something 
on the adjacent vineyard and it drifted over the car and there was a 
white mist on top of the car. They were lucky they had the car win- 
dows rolled up. I talked to a little girl who began to vomit. She ate 
grapes out in a field next to her field and they had obviously put 
phosphates on them a day or two before. 

We have over 400 kinds of poisons in over 60,000 brand names, 
and it is completely uncontrollable. That is the kind of problem 
farmworkers and consumers are faced with today. 

Senator Mondale. You talked about workers in the field, and you 
have mentioned briefly that children might be along where their 
families are working. What about the workers who apply pesticides, 
either on the ground or by air? Is there evidence that these people, 
whose occupation requires them to be exposed to these dangers, ade- 
quately protect themselves or do they risk their own health by this? 

Mr. Cohen. Senator Mondale, last summer — we don't know what 



3036 

the results are this summer, yet because they are not all in — last 
summer 12 pilots, crop dusters, plowed themselves into San Joaquin 
Valley and killed themselves. 

Senator IMondale. Twelve pilots who were spraying pesticides flew 
into the ground? 

Mr. Cohen. That is right. They think the reason for that is their 
vision was affected because of the effects of phosphate poisoning, it 
gives you double vision and affects your depth perception. We have 
talked with people who have been on ground rigs for years and a 
Mr. Cramden comes to mind. That man has taken 10 or 12 years off 
his life. His lungs are in terrible shape. Doctors say he has been 
breathing sprays all his life and he has never been given adequate 
respirator protection. There is no standard in any field but there 
will be standards under the union contract. That was the major fight 
we had with the grape growers. They wanted us to drop the issue 
and we wanted them to take steps to protect the workers and chil- 
dren but also the people who necessarily handle the stuff during the 
course of the day. 

Senatore Mondale. Do you have any precautions to protect work- 
ers or applicators in the contracts which you have bargained collec- 
tively? 

Mr. Cohen. Yes, we do. Senator. We have a health and safety 
clause. We have certain minimum standards that the growers have 
to live up to. The growers have to provide the workers with safety 
equipment and tools. I don't think those contracts are good enough 
yet because we are just learning about this problem. 

Senator Mondale. Do you think it has been helpful ? 

Mr. Cohen. I think it has been very helpful. I think it has been 
helpful because if you put in a union shop, if you put a poison in a 
Ignited Auto Workers plant and it came down the belt, they just 
shut down the line until they get the poison out of there. Wlien you 
get a union the workers get a sense of security and when something 
dangerous is happening, they leave the field and go to the foreman 
and they try to correct it. Without a union contract, a worker who 
complains about pesticides is going to get fired because it is the big- 
gest issue in the valley right now. 

Senator Mondale. Senatore Cranston ? 

Senator Cranston. I hope the subcommittee follows up on the 
questions of Mr. Fielder. Thank you very much for your help. 

(See the correspondence between Mr. Fielder and the subcommit- 
tee at the close of hearings on August 1, 1969.) 

Senator Mondale. Senator Bellmon. 

Senator Bellmon. Thank you, Mr. Chairman. 

I have a couple of questions I would like to ask, Mr. Cohen. First, 
you mentioned that you or your organization has conducted tests to 
determine DDT residues on grapes. Is this right? 

Mr. Cohen. That is correct. 

Senator Bellmon. Did you conduct these tests with your own lab- 
oratories, or how do you do it? 

Mr. Cohen. No, there is a laboratory in Los Angeles that we send 
them to, and a laboratory in Buffalo, Sacramento, Seattle, and Chi- 
cago. 



3037 

Senator Bellmon. Does one laboratory support the finding of the 
others? 

Mr. Cohen. Yes, they use gas chromatography which is supposed 
to be a pretty foolproof method. 

Senator Bellmon. Do you remember what the levels of DDT con- 
tamination were? 

Mr. Cohen. We just got a report today from Washington, D.C, 
that talks about 18 parts per million for aldrin. That was on Bianco 
grape. Some of the grape has two and three parts per million. It is 
under seven parts per million, but the problem is they are using 
DDT and DDE and aldrin, they are using all kinds of pesticides, so 
if each one is under tolerance, together they may end up over toler- 
ance. 

And it seems to me tolerance for DDT now should be zero, that 
the numbers game we are playing is irrelevant. I think the Federal 
Government says tolerance for DDT is seven parts per million. We 
know DDT is stored in fatty tissue so you may eat something three 
or four times a day, but if it is going to stay in your tissue for 10 
years, it seems to me there should be no residue on any food, espe- 
cially grapes. 

Senator Bellmon. You mentioned you have found evidence of 
aldrin in your tests. Does California permit use of aldrin on grapes? 

Mr. Cohen. Yes, it does. It permits the use of DDE on grapes. 
They have an agreement to use sodium arsenic on grapes last year, 
too. Sodium arsenic caused an epidemic in German vineyards 6 years 
ago. 

Senator Bellmon. What insects are the insecticides supposed to 
control ? 

Mr. Cohen. I am not an entomologist, but they control things like 
mealy bugs and red leaf hoppers. 

Senator Bellmon. Do you have an alternate way of controlling 
these? 

Mr. Cohen. At the hearing we had Professor Van Den Bosch, 
who is an entomologist from Berkeley; Professor Van Den Bosch 
went into detail on this. What is going on in California vineyards 
right now is that many salesmen are going to growers during times 
of the year when they really don't need the use of pesticides. They 
may have a beneficial bug out in the field and the salesman may 
come along and say you need to spray something on your grapes, so 
they kill it and then kill the beneficial bug, and then the grower has 
to rely upon pesticide to kill the harmful bug that comes up. A care- 
ful, controlled, integrated experiment using bugs and all kinds of 
methods has to be workable. What is happening now, we are having 
unilateral wholesale use of pesticides. It is being dumped all over 
the valley. A hundred million pounds of it every year in California. 
There must be a better way of doing it. I don't know what they are 
developing. If we put a man on the moon, it seems to me we could 
kill a bug without poisoning man. 

The research they do goes to the bugs and how cheap it can be, 
but how do you protect a farmworker in the field and how do you 
protect the consumer ? It seems to me they keep raising tolerance but 
what has to be done with DDT is they have to lower that tolerance 
to zero. 



3038 

Senator Bellmox. We have a Federal Food and Drug Adminis- 
tration. "Where do they fit in the picture? "Wliy do they allow these 
abuses to continue? 

Mr. CoHEX. I know someone has submitted a statement today that 
talks about the fact that the reported incidence of injuries they have 
are not at all reflective of how many people are being injured every 
year because most States don't require reporting of injuries. I think 
Food and Drug Administration could do a lot more to solve the 
problem. The farmworkers don't have much faith in the FDA, and 
when they were labeling illegal with other growers, it took them 4 
months just to slap their hands to stop them from doing that, even 
though it was violation of the Pure Food and Drug Act. 

Senator Bellmox. You mention that the Food and Drug Admin- 
istration allows seven parts per million of DDT as the human tolerance 
level. 

Mr. Cohex. I think that is correct. 

Senator Bellmox. Do you object to that? 

Mr. CoHEX. I think DDT should be banned. 

Senator Bellmox'. On what basis? 

Mr. CoHEX. I think it should be banned because if you read the 
article in the June issue of the Journal of American Cancer Insti- 
tute, you find that DDT is causing tumors in mice. So it has un- 
known effect on human beings. If it is contaminating mother's milk 
to the extent that if it was cow's milk it could not be sold on the mar- 
ket, I think it should be banned. It appears on page 1011 of the 
Journal of the National Cancer Institute. I think it is a study of tu- 
moragenicity in mice — a preliminary note and I suggest that every- 
body read it. 

Senatore Bellmox'. Is it accepted as authentic research ? 

Mr. CoHEX. Yes, but I think ]Mr. Hayes may be the only excep- 
tion to that. I think scientists do accept the fact that it causes 
unknown dangers to humans. 

Senator Bellmox. I wonder why the FDA hasn't come to that 
conclusion. 

Mr. CoHEx. That is a good question. 

Senator Bellmox. Have you ever tried to find out ? 

Mr. CoHEx. We tried to find the FDA with one of our problems, 
and didn't get any result. So we are going to rely on ourselves, and 
ban it during bargaining negotiations. 

Senator Bellmox. On what basis? 

Mr. CoHEx. I am saying that there are many scientists that have 
said it is injurious to human beings. 

Senator Bellmox. You are saying the FDA is wrong in their con- 
clusion ? 

Mr. CoHEx. Yes. 

Mr. Bellmox. Where are you getting your information other than 
in the one article that you cited? 

Mr. CoHEx. I think if you look at testimony that Mr. Yanacone 
developed in his hearing in Suffolk County, New York, you will find 
that scientists say that DDT causes grave danger to human beings. If 
you want us to tell horror stories, we will tell them. In Madison, Wis., 
Dr. Grace, who is a chemical pharmacologist, and in Tuckahoe, N.Y., 



3039 

states that DDT could be seriously affecting man's sex organ 
changes. I don't want my sex organs changed any way by DDT. 

"They affect the sex organs of rats. DDT seen as peril to mother's 
milk." 

Scientists are making statements like this every day about DDT. I 
think there is enough doubt that they had better take it off the mar- 
ket. 

"The Federal Government recently has banned DDT for 30 days 
pending a study." That was in an article that appeared on June 16 
by Gladwin Hill. If the Federal Government has banned use of 
DDT for 30 days, I think they have a valid reason to do it. 

Senator Bellmox. Why does one Federal agency allow tolerance of 
seven parts per million when the other is banning ? 

Mr. Cohen. I don't know. 

Senator Bellmox. Do you feel that perhaps the growers might be 
a little confused as to whether or not it is justifiable if the Federal 
agencies can't decide? 

Mr. CoHEX. The growers may be confused but I don't propose to 
take any chances with my health, and I hope the consumers of this 
Nation don't propose to take any chances with their health. 

If I were confused, I don't think I would take the chance. I don't 
think I would let the consumers play Russian roulette with their 
lives. 

Senator Bellmox. The memory I have of DDT was that during 
World War II troops were sprayed with DDT to get rid of some of 
the pests we were putting up with. I am sure we have learned a 
great deal about it since that time. 

That is all the questions I have, Mr. Chairman. 

Senator JNIoxdale. Thank you very much, Mr. Cohen, for your tes- 
timony. We appreciate your assistance. We will insert in the record, 
at this point, the documents you have presented as well as other rel- 
evant materials. 

(The material referred to follows :) 

In The Superior Court Of The State Of California 
In And For The 
County Of Kern 



No. 103595 

ATWOOD AVIATION, INC., A CORPORATION, GARRIOTT CROP DUSTING, CO., INC., A 
CORPORATION, ARVINAIR CROP DUSTERS, ON BEHALF OF THEMSELVES AND ALL 
OTHER MEMBERS OF KERN COUNTY AGRICULTURAL CHEMICAL ASSOCIATION, AN UN- 
INCORPORATED ASSOCIATION, PLAINTIFFS, VS. SELDON C. MORLEY, IN HIS CAPACITY 
AS AGRICULTURE COMMISSIONER OF THE COUNTY OF KERN, STATE OF CALIFORNIA, 

DEFENDANT 

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF TEMPORARY 
RESTRAINING ORDER AND PRELIMINARY INJUNCTION 



It appears from the verified complaint that plaintiffs who are not involved 
in the real dispute which is between the growers and the union organizers will 
likely suffer considerable harassment and expense unless defendant is immedi- 
ately enjoined from disclosing these records prepared and furnished by plain- 



3040 

tiffs. Mr. Morley the Agriculture Commissioner, according to the verified 
complaint admits that he does not know whether or not the disclosure could be 
made but that he may make the disclosure if insisted upon as it likely will be, 
and if that happens all of the damage will be done. 

Surely it can harm no one to prevent this at least for the few days involved 
under the temporary restraining order so that there will be time to make a 
proper determination. 

Certainly if there is an actual suit for damages alleging an injury the spe- 
cific information in a given case can be required under normal discovery pro- 
ceedings ; therefore, there can be no hardship to anyone who has a legitimate 
claim and files suit thereupon. 

Obviously these people who are putting the pressure on Mr. Morley seek to 
use the information for their own purposes totally unrelated to the reason for 
and the intent behind the Agricultural Code Section 11733 quoted in the com- 
plaint which requires plaintiffs to prepare these reports and send them to Mr. 
Morley. 

The other code sections referred to in the complaint and which according to 
Mr. Morley are being relied upon by the persons seeking the disclosure are as 
follows : 

JCP 1888 
Public. — Public writings are : 

1. The written acts or records of the acts of the sovereign authority, of 
official bodies and tribunals, and of public officers, legislative, judicial, and ex- 
ecutive, whether of this state, of the United States, of a sister state, or of a 
foreign country ; 

2. Public records, kept in this state, of private writings." 

CCP 1892 

"Public Right to Inspect and Copy. — Every citizen has a right to inspect and 
take a copy of any public writing of this state, except as otherwise expressly 
provided by statute." 

Oovernment Code Section 1227 

"Inspection of Public Records and Other Matters. The public records and 
other matters in the office of any officer, except as otherwise provided, are at 
all times during office hours open to inspection of any citizen of the State." 

The subject Pest Control Operator Reports obviously are not public writings 
within the purview of Sections 1888 or 1892. Obviously also they are not "pub- 
lic records" within the purview of Government Code Section 1227, the only 
possibility being that they could be construed to be "other matters in the office 
of any officer". 

Frankly, in the very limited time available due to the urgency of the situa- 
tion here we have not been able to accomplish much research on the point and 
we have not found direct authority on the point but we doubt that the Court 
will ultimately rule that these people have the right to these records of pri- 
vate busine.ss transactions for use in the manner so obviously intended. In any 
event we urge the Court to grant plaintiffs the immediate prorection of the 
temporary restraining order and such surely can do no harm to anyone. 
Respectfully submitted, 

Wall & Byrum. 
By Stephen Wall. 

January 7, 1969. 
Stephen Wall, Esq. 
Bakersfield, Calif. 

Dear Mr. Wall : Enclosed you will find a proposed agreement between the 
United Farm Workers Organizing Committee, your clients, and table grape 
growers. 

As you know, we are involved in a case in which I am personally petitioning 
the court to inspect the records. However, as General Counsel for the United 



3041 

Farm Workers Organizing Committee, I am representing not only my personal 
interests but also the interests of the Union. Therefore, I think it appropriate 
that the agreement should involve the United Farm Workers Organizing Com- 
mittee and not me personally. As I told you in your office, the United Farm 
Workers Organizing Committee is anxious to fulfill its responsibilities to all 
farmworkers whether or not they are members of our Union. 

The most pressing problem which faces us as of now is the ever-increasing 
danger to farmworker health and safety which arises from the use of danger- 
ous pesticides in the vineyards. The enclosed proposal is an initial step in in- 
suring adequate protection to farmworkers. 

As you can see from Parts 2, 3, and 4 of the proposal, we are attempting to 
obtain information not only from spray applicators who are required to main- 
tain records with the Agricultural Commissioner, but also from growers who 
are not required to submit any information to the Agricultural Commissioner. 
The reasons for this are as follows : 

As Mr. Griffin stated to us, he has developed a certain expertise in the appli- 
cation of dangerous materials. This case will force him to disclose to the 
United Farm Workers Organizing Committee certain information concerning 
the use of pesticides. It is ironic that growers who do not possess the exper- 
tise which Mr. Griffin possesses do not have to disclose information to the Agri- 
cultural Commissioner. We are fully aware that one possible result of this 
case will be the ever-increasing use by growers of their own equipment which 
would inevitably lessen business for more responsible applicators. Therefore, 
we are anxious to put covered spray applicators as well as non-covered grow- 
ers under the terms of this agreement. Section 4 which requires growers to 
post written warnings in the fields where injurious materials have been ap- 
plied is a minimum safety requirement which I am sure you will fully support 
in light of your expressed concern for the health and safety of agricultural 
workers. 

We request a meeting in your offices with your clients and representatives of 
the table grape growers of Kern County on either Thursday, January 9, or 
sometime in the afternoon of Friday, January 10. We would also appreciate an 
acceptance or rejection by Monday, January 13. We will assume that no re- 
sponse constitutes a rejection. 
Yours truly, 

Jekome Cohen. 



Proposed Agreement Between UFWOC, Thomas Griffin, Atwood 
Aviation Co., 

C. Seldon MoRLirr, And Table Grape Growers In Kern County 

The United Farm Workers Organizing Committee has recently become aware 
of the extensive health hazards which accompany the use of pesticides in the 
vineyards. The United Farm Workers Organizing Committee, as a responsible 
union proposes to take the following steps to more adequately insure the 
health and safety of grape pickers whether or not they are members of our 
Union. 

The United Farm Workers Organizing Committee will gather information to 
enable the farmworkers' clinic to more adequately care for workers who are 
victims of pesticide poisonings. 

The United Farm Workers Organizing Committee will gather information in 
order to write contractual protections covering the use of dangerous pesticides. 

Finally, the United Farm Workers Organizing Committee hopes to establish 
communications with each grower of table grapes in Kern County in order to 
develop procedures to insure the safety of the grape workers. The United 
Farm Workers Organizing Committee believes that this issue of farmworker 



3042 

health and safety supersedes other issues of conflict between the growers and 
workers and should be resolved even before such other issues are resolved. 

A public hearing concerning UFWOC's right to see public records covering 
the application of economic poisons is scheduled for January 29, 1969. If the 
following conditions are met, this hearing will become unnecessary : 

1. The following information currently on record with the Commissioner of 
Agriculture should be turned over to the United Farm Workers Organizing 
Committee : 

(a) A description and location of all properties treated with injurious mate- 
rials. 

(b) Date of the treatment. 

(c) Material and dosage used. 

(d) Number of units treated. 

(e) Type of crop involved. 

(f ) The identity of the equipment used. 

(g) If applied by airplane, the name of pilot or pilots who applied the treat- 
ment. 

(h) The temperature and wind conditions during the time of the treatment, 
(i) The name of the grower or grower representative for whom the treat- 
ment was applied. 

2. All growers who used their own equipment to apply dangerous pesticides 
must deliver the following information to UFWOC : 

(a) Description of properties and location of property treated. 

(b) Date of treatment. 

(c) Material and dosage used. 

(d) Identity of equipment used. 

(e) Brief description of qualifications of person applying dangerous mate- 
rials. 

(f) Statement of tolerance level for workers and consumers for each kind of 
injurious material. 

(g) Disclosure of amount of geybral used in vineyards and number of appli- 
cations of geybral. 

3. All growers shall inform the United Farm Workers Organizing Committee 
three (3) days in advance of application of poisonous materials. 

4. Growers shall post written warnings in fields in which injurious materials 
have been applied. Such warnings shall be in Spanish and in English and shall 
state in letters six (6) inches high the name of the material which has been 
applied and the date on which the field will become safe to work in. 



Wali- & Byrum, 
Bakersfield, Calif. January 8, 1969. 
Jerome Cohen, Esq. 
Delano, Calif. 

Dear Mr. Cohen : This is in answer to your January 7, 1969 letter to me en- 
closing a copy of what you propose for agreement between the United Farm 
Workers Organizing Committee, my clients, and others. It is obvious either 
that we completely failed to communicate or else you are trying to be funny. 

I understood you to say you would advise me as to which portions of the 
data contained in the subject filed reports you might accept as suflScient in 
order to .settle the existing litigation with regard to those reports already filed. 
It was my thought that if you would demon.strate at least some degree of rea- 
sonableness and good faith by not now insisting upon receiving the privileged 
information such as specific descriptions of properties and names of persons 
and companys, which incidentally could be useful to you only in contemplated 
activity such as filing nuisance lawsuits for propaganda purposes related to 
your so-called table grape boycott, then perhaps this present litigation might 
be settled and all concerned could consider the over-all situation free of the in- 
creasing bitterness now being generated here. 



3043 

I understood you to say also that you might now be satisfied with receiving 
from the subject reports that are now filed only those portions of the data 
contained therein which could reasonably relate to the announced aim of your 
Clinic in Delano, being primarily that of improving the general health of 
agrrcultural workers in the area as well as the standards of safety applicable 
to their working conditions. 

I understood you to say also that your only other interest in seeing these 
specific reports on file now was for your use in formulating some pertinent 
contract language for future use in negotiating labor contracts, hopefully. You 
definitely stated that you were not interested in seeing the subject reports for 
using any part of the contained data in connection with your boycott effort or 
as the basis of filing any lawsuit or lawsuits. 

But here is what you came back with : You want the name of the grower, 
the name of the airplane pilot, the name of the material and the dosage used, 
the legal description of the property treated, the exact date of the treatment, 
and so on. 

These you intend to use in connection with your Delano Clinic or in negotia- 
tion of future contracts? 

Your actual purpose is clearly evident and there is not even a coincidental 
resemblance to the ones you expressed. But the end justifies the means in your 
league — right? 

Very truly yours, 

Stephen E. Wall. 



January 9, 1969. 
Stephen E. Wall, Esq. 
Bakersfield, Calif. 

Dear Mr. Wall : Thank you for your letter of January 8, 1969. I was pleased 
by your prompt response to my proposal of January 7, but was very sorry that 
you rejected that proposal even without meeting with us. Let me assure you 
that the United Farm Workers Organizing Committee is attempting to act rea- 
sonably and develop adequate safeguards concerning the use of economic poi- 
sons in the vineyard.s. We are available to meet to discuss this subject at your 
convenience. AVe hope that such a meeting will take place soon, for the delay 
in working out safeguards only hurts the workers and consumers. 
Yours truly, 

Jerome Cohen. 



January 14, 1969. 
Mike Bozick, 

Chairman, Desert Grape Growers League, 
Richard Bagdasarian Ranch, 
Mecca, Calif. 

Dear Sirs : We are writing to request a meeting at a mutually agreeable time 
and place to begin negotiation of a collective bargaining agreement between 
the California table grape growers and the United Farm Workers Organizing 
Committee, AFL-CIO. 

For nearly three and a half years now, since September 1965, we have car- 
ried on a struggle at great cost to both sides and it is time we made renewed 
efforts to resolve it. 

Our international boycott has reached a critical stage in its development. In 
various communities we have made contact with labor, church, civil rights, 
and other groups friendly to our cause. The machinery has been set up and 
the boycott is taking on a certain momentum of its own. We must now decide 
whether to intensify our efforts and reach out into new communities. Before 
making that decision we would like to learn your intentions. 



3044 

There is one critical issue of such overriding importance that it demands im- 
mediate attention, even if other labor relations problems have to wait. I mean 
the harmful effects of spraying grapes with pesticides, or economic poisons, as 
they are called. We have recently become more aware of this problem through 
an increasing number of cases coming into our clinic. 

We will not tolerate the systematic poisoning of our people. Even if we can- 
not get together on other problems, we will be dammed — and we should be — if 
we will permit human beings to sustain permanent damage to their health 
from economic poisons. 

We are willing to meet with your representatives on the sole issue of pesti- 
cides, even if you are not prepared to begin full-scale collective bargaining at 
present. These talks could go even as we pursue our final aim of a fair agree- 
ment. 

We await your reply on both these proposals by January 20. 

If you should answer in the negative on both counts, or if you should choose 
to ignore our request, we will have no choice but to escalate the boycott. We 
are appealing to the conscience of the American people to support the farm 
workers' demand for a better chance in life, and to express that support 
through decisions in the marketplace. The appropriate method for a non- 
violent union such as ours is a direct appeal to the conscience of the American 
people. Our right to make that appeal, and their right not to buy California 
table grapes, are things you cannot take away from us. They are both consti- 
tutional rights ; they are also matters of conscience. The boycott is a revelation 
of the moral force behind our movement. 

Surely it must seem to you at times that you are only running away from 
the inevitable. The foundations of our resistance campaign are built on quick- 
sand. All the time and effort and money you spend trying to break our strike 
could be used instead to eradicate misery and hunger, the byproducts of this 
malignant fog of poverty which has settled over our vineyards. 

Should you negotiate an agreement with us, you will find us at best willing 
and serious-minded allies in all that makes for the prosperity of the table 
grapes industry. At worst you will be spared the cost of fighting the organiza- 
tion of farm workers. You see, gentlemen, your business is to grow grapes for 
profit ; our mission is to organize workers. 

Over thirty years ago oflBcials of the nation's largest industrial giants went 
about saying that if they were forced to capitulate to the unions, it would not 
be long until the unions would strangle them and the whole economy to death. 
Today those giant corporations are still in business and making bigger profits 
than ever. Wages won through union sacrifice and union effort have supplied 
the consumer buying power for the most prosperous economic system in world 
history, and incidentally, for buying your grapes. So you, no less than Ameri- 
can industry generally, have good reason to applaud the gains of those other 
unions. Yet when your own workers want the same benefits, you turn your 
backs on them. 

There is talk at both federal and state levels of farm labor legislation. If we 
can't agree on wages, hours and working conditions — or at the very minimum 
even talk about the most important issue of all, which is the protection of 
human life from the dangers of economic poisons — then how can we ever agree 
on legislation? What alternative do you have? You won't be able to break our 
union or .stop our boycott. So if you won't negotiate with us, the only route 
open to you will be repressive legislation, which the American people will not 
accept. 

Viva la Causa ! 

Cesar E. Chavez, Director. 



3045 



REPORTS OF OCCUPATIONAL DISEASE AMONG AGRICULTURAL WORKERS ATTRIBUTED TO PESTICIDES AND 
OTHER AGRICULTURAL CHEMICALS, KERN COUNTY, 1967 



Type of Industry Occupation, age/sex Date of Nature and extent of Injuries 



Period of 
disability 



Crop dusting. 
Farm 



Crop dusting. 
Crop dusting. 
Crop dusting. 
Crop dusting. 
Crop dusting. 

Farm 



Swamper 23/M 


. 8-14-67 


Laborer, 27/M 


. 7-11-67 


Loader, 27/M 


. 9- 2-67 


Crop duster, 20/M.. 


. 7-26-67 


Swamper, 18/M 


. 10-10-67 


Swamper, 49/M 


. 8-12-67 


Crop duster, 18/M.. 


. 6-12-66 


Laborer, 23/M 


. 1-18-67 



Farm. 



Farm. 
Farm. 



Fertilizer company. 
Farm 



Laborer, 49/M. 




6- 5-67 


Laborer, 31/M. 




8-2S-67 


Laborer, 17/M. 




6-19-67 


Tractor driver. 


33/M. 


6-29-67 


Tractor driver. 


64/M. 


5-16-67 



Handling insecticide spray. Became very 
ill. Insecticide poisoning. 

Developed a sore throat while breathing 
insecticides in cantalopes. Chemical 
conjunctivitis and chemical trachea 
bronchitis. 

Reoccurrence of insecticide poisoning. 
Organic phosphate poisoning suspect- 
ed. Hospitalized 3 days. 

Exposure to organic phosphate. Exten- 
sive signs and symptoms of phosphate 
intoxication. 

Mixing liquid poison. It spilled on me. 
Organic phosphate poisoning, subacute, 
now recovering. Hospitalized 2 days. 

General systemic poisoning secondary to 
exposure to inorganic phosphate crop- 
dusting chemicals. 

Accidental exposure to phosphate spray. 
Developed muscular spasms, and 
passed out. Had abdominal cramps, 
sweating and blurred vision. Hospital- 
ized 2 days. 

Filling tank on wheel tractor with DD 
fumigant. Spray got in my eye, I drop- 
ped the tank and sprayed feet and 
legs. Hydrocarbon burns 1st degree 
left eye, medial aspect right foot, ankle ; 
lateral aspect left foot, ankle. 

Changing the hose while fertilizing. The 
hose blew a hole and I got the fertilizer 
in both eyes. Could not sleep last night 
because of pain. Conjunctivitis bilateral 
eyes chemical irritation. 

Working on ranch in Buttonwillow. 
Spray got on legs. Infected legs and 
feet. 

Spraying weed killer. Handle blew off 
covering patient all over with spray. 
Fine, superficial rash on both arm and 
upper body as well as a few areas on 
the face. 

Exposed to Bidrin chemical. Nausea, 
vomiting, cramps (abdominal), dizzi- 
ness. Organic phosphate poisoning. 
I had 



1 week. 
Not stated. 

5 days. 
2-3 weeks. 

2 weeks. 

7 to 10 days. 
2 to 3 weeks. 

2 days. 

None. 

2 weeks. 
None. 



1 week. 
1 week. 



Farm Sulfur duster driver, 

55/M. 

Farm Laborer, 36/M 

Crop dusting Laborer, 19/M 



Farm Ranch foreman. 58/M. 

Farm Unknown, 31/M 

Crop dusting Pilot, 48/M 



Driving tractor through field which 
been dusted with sulphur— noticed 
rash breaking out on both hands, now 
worse. Weepmg eczema back of both 
hands and wrists— marked swelling of 
hands. 

6-28-67 Had been driving duster using Not stated. 
Ortho-7-Dibrom-Kelthene 44. Emphy- 
sema and bronchitis aggravated by 
sprays. 

9-17-67 Picking grapes and the insecticide gave 1 week, 
him a rash; imflammation flexor sur- 
face both forearms and creases with 
some secondary infection. 

8- 8-67 Mixing chemicals for the crop dusting 1 week, 
plane and splashed it on my feet and 
legs (phosdrin insecticide). Poisoning 
with insecticide; nausea, vomiting, 
muscle twitching calves of legs, profuse 
sweating. Hospitalized. 

3- 8-67 Injecting D.O. soil fumigant into ground. None, 
got some on right foot, irritated and 
infected now. Fumigant got into boot, 
blistered toe, now cellulitis entire toe. 

5-13-67 Driving down road chain broke on pump, 1 week, 
pump spinned around and busted hose, 
some ammonia sprayed into right eye. 
Purulent conjunctivitis, right eye. 

8-26-67 Hose blew off and I got sprayed. Con- Not stated, 
tinued working but sick to stomach, 
nausea continues, dizzy and spots 
before my eyes. Now I have trouble 
getting my breath. Chemical poisoning 
(Azadrin). Mild shock, hypotension. 
Dyspnea, cyanosis. Hospitalization 
recommended; patient refused. 



3046 

REPORTS OF OCCUPATIONAL DISEASE AMONG AGRICULTURAL WORKERS ATTRIBUTED TO PESTICIDES AND 
OTHER AGRICULTURAL CHEMICALS, KERN COUNTY, 1967-Confinued 





Type of industry 


Occupation, age/sex 


Date of 


Farm. 




.. Unknown, 17/M 


7- 8-67 


Farm. 




.. Laborer, 42/M 


9-28-67 


Farm. 


- 


.. Laborer, 21/M 


5-16-«7 


Farm. 




.. Laborer, 49/M 


7-30-67 


Farm. 




.. Ranch hand, 23/M... 


5-29-67 


Farm. 




.. Laborer, 45/M 


. 3-24-67 



Period of 
disability 



Farm. 



Farm. 



Fertilizer and insecticide 
company (services). 

Fertilizer and insecticide 
company (farms). 



Truck driver, 22/M_.. 8-28-67 
Truck driver, 38/M.. 2-17-67 



Laborer, 29/M. 
Laborer, 23/M. 



7- 8-67 
10-25-67 



Spray and pest control Sprayer, 37/M 2-17-67 



Farm 

Crop dusting. 

Crop dusting. 

Crop dusting. 

Crop dusting. 

Crop dusting. 
Crop dusting. 

Farm 



Laborer, 32/M... 
Groundrig, 22/M. 

Swamper, 42/M.. 

Swamper, 18/M. 



5- 5-67 
6-25-67 

7-28-67 

8- 2-67 



Farm 

Crop dusting. 



Flagman, 19/M 


.. 7-27-67 


Unknown, age 

unknown/M. 

Flagman, 18/M 


10- 7-67 
5-20-67 


Laborer, 38/F 


.. Over a 
period 
of time. 


Laborer, 42/M 


.. 5-15-67 


Swamper, 42/M8... 


.. 8-27-67 



Spraying weed oil and the wind blew it 3 days. 

on his face and feet burning them. 

Contact dermatitis of face and feet. 
Loading grapes. Has rash on right side 3 days. 

of face. Exposure to Sulfurdiox, 

rhinitis, pharyngitis, rash on right 

side of face. 
Spraying weeds, nozzle broke and he 1 week. 

got sprayed with weed oil, itches. 

Chemical dermatitis. 
Working in vineyard, irritation of eyes None. 

from Insecticides. Contact dermatitis. 
Working with sulfur, dusting in field. Not stated. 

Also welding without protective 

glasses. Conjunctivitis, both eyes, 

irritative. 
While flagging a plane crop dusting, was 2 weeks. 

sprayed with chemical. Became 

nauseated and vomited within a few 

minutes. Appears nervous and appre- 
hensive. Complains of dizziness, weak- 
ness, nausea, chest pain and blurred 

vision. Has erythematous rash over 

neck, chest and arms. Hospitalized for 

unknown length of time. 
Was mixing Metnel parathion and became Not stated. 

sick. Was nauseated and felt weak 

and dizzy. Possible symptom exposure 

to parathion. 
Filling tank with D.D. solution, hose None. 

slipped and D.D. solution got in eyes 

and on back and chest. Chemical irri- 
tant conjunctivitis, bilateral, mild. 
While spraying insecticides on cotton, 3 to 5 days. 

sprayed self on arms and chest. 

Contact chemical dermatitis. 
Was mixing a spray of zinc blue stone 5 to 7 days. 

and lime and burned both hands. 

Vesicular dermatitis, contact type, 

fingers and hands bilateral, moderate. 
While operating spray equipment some ot 1 week. 

the spray material blew back on him. 

Contact dermatitis with vesicular weep- 
ing areas around neck and forearms. 
Was fumigating potato ground, got some None. 

chemical on right shoe, penetrated 

leather and burned right foot. 
Just started feeling sick. General sys- 4 to 6 days. 

femic poisoning secondary to work ex- 
posure to inorganic phosphate crop- 
dusting chemicals. 
Generalized systemic poisoning secondary Not stated. 

to exposure to inorganic phosphate 

crop-dusting chemicals, incurred while 

at work. 
General systemic poisoning secondary to 7 to 10 days. 

exposure of inorganic phosphate crop- 
dusting chemicals incurred while at 

work. Weakness, nausea, vomiting, 

abdominal cramp-like pain. 
Generalized systemic poisoning second- 3 to 5 days. 

ary to exposure to inorganic phosphate 

crop-dusting chemicals, incurred while 

at work. Hospitalized 1 day. 
Parathion poisoning severe, incurred 1 month— 6 

while at work. Hospitalized 4 or 5 days. weeks. 
General systemic poisoning secondary to 7 to 10 days. 

exposure to inorganic phosphate crop- 
dusting chemical. Hospitalized for un- 
known length of time. 
I work with grapes and I developed a 4 days. 

reaction from the dust on the grapes. 

Fatigue, weakness. Has sinus drainage 

which causes productive coughing. Has 

grayish streaked phlegm. Throat red. 
Was working where they had sprayed 7 days. 

sulfur and developed a rash on his face, 

arms, and hands. Contact dermatitis. 
Inhalation Parathion, chemical poisoning. 5 to 6 weeks. 

Hospitalized 7 days. 



3047 



REPORTS OF OCCUPATIONAL DISEASE AMONG AGRICULTURAL WORKERS ATTRIBUTED TO PESTICIDES AND 
OTHER AGRICULTURAL CHEMICALS, KERN COUNTY, 1967— Continued 



Type of industry Occupation, age/sex Date of Nature and extent of Injuries 



Period of 
disability 



Potato contractor Mechanic, 33/M 2-15-67 



Farm.. Laborer, 25/M. 



5-11-67 



Farm Laborer, 37/M 9-7-67 I 



Crop dusting Flagman, 16/M- 

Farm Laborer, 67/M.. 



Farm Laborer, 66/M. 

Turkey ranch Laborer, 52/M. 

Farm Laborer, 57/M. 



8- 9-67 
9-29-67 



Gradual 
onset 



6-21-67 



3-14-67 



Crop dusting Crop duster, 33/M... Unknown 

Crop dusting... Crop duster, 47/M... Unknown 

Crop dusting Crop duster, 44/M... Unknown 

Farm Laborer, 40/ M 8-9-67 



Turkey ranch..- Laborer, 52/M 6-22-67 



Farm Foreman, 46/M. 

Farm Cowboy, 22/M.. 



Farm Laborer, 39/F.. 

Farm Laborer, 17/M. 

Farm Laborer, 28/F.. 

Farm Laborer, 39/M. 

Farm. Laborer, 31/M. 



Farm Laborer, 42/M. 



Farm Laborer, 59/M... 

Agricultural pest control... Rig driver, 23/M. 



5- 1-67 
11- 5-67 



Gradual 
onset 
7- 4-67 



6-23-67 
7-15-67 
7-6-67 

6-20-67 I 

5-19-67 
5-19-67 I 



Planting potatoes In Wasco. Got piece of Not stated, 
fertilizer in left eye. Eye markedly red. 
Swelling and edema present from the 
irritation to the conjunctiva. 

Spraying weeds ... got insecticide in None, 
eyes. Bilateral spray "burns" (ery- 
thema) of face and ears plus bilateral 
conjunctivitis. 

was fertilizing the ground, I opened the 1 day. 
valve, fertilizer sprayed me. Chemical 
burns from fertilizer spray. 

Possible organic phosphate poisoning. 7 to 10 days. 
Heat exhaustion. 

Working in vineyard, gradual onset of None, 
rash on left arm, possibly due to insec- 
ticides used in vineyard. Contact 
dermatitis. 

After working in vineyard noted gradual None, 
appearance of a rash on both arms, 
believed due to insecticides. Contact 
dermatitis. 

Patient was spraying ground with oil. None. 
Wind caused to spray on hands. Hands 
show signs of burns or infection. Acute 
contact dermatitis of the hands. 

Packing carrots and insecticide from 2 months, 
carrots caused burning rash. Bilateral 
contact dermatitis of hands and fore- 
arms. 

Was exposed to phosphate poisoning. Not stated. 
Ortho phosphate poisoning. Was Hos- 
pitalized. 

Exposed to phosphate sulfate. Phosphate Not stated, 
poisoning. Hospitalized 3 days. 

Leak in lid of Phosdrin tank. Phosphate Not stated, 
poisoning. Hospitalized for unknown 
length of time. 

After spraying insecticides noted gradual 1 week, 
appearance of rash on body. Contact 
dermatitis from waist down with itch- 
ing and scratching. 

Developed a crusting, itching rash over his 1 to 2 days, 
hands and face, several days after using 
an insecticide. Contact dermatitis of 
hands and face. 

I was working in poison and now I have None, 
diarrhea and sweating. (Malathion 
type drug). Nausea. 

Was working with cattle, organic phos- None, 
phate. Swollen and has a rash. Possible 
organic phosphate poisoning rash and 
swelling of both wrists, ankles, thighs 
and face. 

Working in vines noticed face irritating. 2 to 3 days. 
Allergic rash on face due to sulfur. 

While spraying with Tedion Thiodan 25- None. 
25, breathed fumes and later developed 
aching and soreness in shoulders and 
chest wall. Possible chemical toxicity. 

Allergic conjunctivitis of right eye due to None, 
grape spray. 

Patient got sulfur in his eyes. Allergic None, 
conjunctivitis. 

Filling NH3 tank on tractor, valve leaked 1 week, 
permitting ammonia to escape striking 
chest and abdomen and lips. First 
degree burns from ammonia, chest, 
abdomen, slight burn to lips, 
was dusting cotton and I got some sulfur None, 
into both my eyes. I was on the cultiva- 
tor behind the sulfur duster. Mild bi- 
lateral eye irritation, probable chemical 
due to sulfur. 

A hose broke on a spray rig and I got some None, 
weed oil in my eyes. My eyes are burn- 
ing now. Chemical conjunctivitis each 
eye. 

was turning the rig in the field and aqua None, 
ammonia flew in both eyes. Chemical 
conjunctivitis in both eyes, worst in left. 



3&-513 O — ^70 — ^pt. 6A- 



3048 



REPORTS OF OCCUPATIONAL DISEASE AMONG AGRICULTURAL WORKERS ATTRIBUTED TO PESTICIDES AND 
OTHER AGRICULTURAL CHEMICALS, KERN COUNTY, 1967-Contlnued 



Type of industry Occupation, age/sex Date of Nature and extent of injuries 



Period of 
disability 



Farm Laborer, 22/F 9-1-67 Picking grapes, sulfur and dust caused 1 week. 

both eyes to swell. Bilateral allergic 
conjunctivitis with conjunctival edema 
and eczema-like reaction to eyelids. 

Farm Serviceman, 47/M... 5-23-67 Ran some Nemigon into right boot ac- None. 

cidentally. Has burn all up and down 
right leg from top of foot about H 
way to knee. 
12- 8-66 Was down in vat where they dip potatoes, 



Fa rm La borer, 61/M . 



Farm Laborer, 46/M 4- 5-67 



Crop dusting Laborer, 19/M 8-28-67 



Farm Ranch foreman, 5-11-67 

54/M. 
Farm Laborer, 58/M 5-23-67 



Farm Laborer, 21/M 7-14-«7 

Crop dusting Flagman, 17/m 10- 1-66 

Farm Unknown/M 5-26-67 

Farm Laborer, 38/M 6-15-67 

Farm Laborer. 17/M 6-26-67 

Farm Foreman, 45/M 4-67 

Farm Laborer, 25/M 7-22-67 

Farm Laborer, 30/M 8-5-67 

Farm Laborer, 63/M Unknown 

Farm Laborer, 19/M 8-31-67 

Farm Laborer, 28/M 8-10-67 

Farm Laborer, 47/M 10-17-67 

Crop dusting Swamper, 18/M 8-10-67 

Farm Laborer, 19/M 2-20-67 

Farm Laborer, 22/M 8-28-67 

Farm Laborer, 37/M 5-15-67 

Farm Laborer. 27/M 10-12-67 



None. 

cleaning it. Felt burning in lungs and 

got sicK to stomach. Says he was 

Breathing chemical fumes (bichloride 

of mercury). Suspected chemical 

poisoning. 
Was spraying weed killer, walking None. 

through the weeds, came in contact 

with Tower legs causing burning and 

rash. Contact dermatitis on legs. 
Loading chemicals on airplane, inhaled 3 days. 

fumes, still has headache and nausea. 

Exposure to organic phosphate. 
Insecticide poisoning, both hands. Not stated. 

Erythematous, palms. 
Working with fertilizing equipment, valve 1 week. 

came loose allowing ammonia to strike 

the right eye. Irritation right eye due to 

ammonia. 
Spraying cotton, some struck face and None. 

arms with subsequent blisters, scab- 
bing and itching. Infected dermatitis 

left cheek, right elbow. 
Loading organic phosphates for crop 1 week. 

duster, innaled some dust. Phosdrin. 
Mixing weed spray and got some powder None. 

in eye. Chemical irritation, no burn. 
Working in vineyard, sulfur got in both 3 days. 

eyes. Bilateral conjunctivitis, burning 

of eyelids. 
Working in field, got weed oil in both 1 week. 

eyes Bilateral conjunctivitis. 
Nausea, vomiting for 1 month. Blurred 4 days. 

vision, difficult respiration. Organic 

phosphate poisoning (Thimite). 
Sprayed in eyes with weed oil. Burned 1 week. 

both eyes. 
Spraying weeds and ammonia sprayed 1 week. 

into eyes and face. Chemical burns 

forehead and eyes. 
Exposure to agricultural chemicals in- 1 to 3 weeks. 

eluding sulfur sprays. Severe erythe- 
matous, oozing, crusted, edematous 

involvement of the exposed areas of 

the face, arms and neck. 
I was tieing small orange trees on a stake None. 

and my hands broke out from the spray 

on them. Allergic dermatitis both hands. 
Spraying some weeds, got weed poison 1 day. 

in right eye. Chalazion, right eye. 

Caused by the irritant and rubbing. 
While working in cotton with insecticides, None. 

developed rash all over body. Contact 

allergic dermatitis — chemical. 
Working with spray insecticides and be- 2 to 3 days. 

came ill after coming In from field. 

Shortness of breath. Nausea— also 

drank water contaminated with in- 
secticide. 
Eruption occurred on face after spraying None. 

weeds with a chemical. Contact der- 
matitis. 
I was spraying weeds and I got weed oil None. 

sprayed into both my eyes and onto my 

neck and arms. Mild chemical irritation 
of the eyes. 
I was fertilizing some fields and I got None. 

some aqua ammonia in my eye. Con- 
junctiva inflamed; mucoid discharge. 
Chemical conjunctivitis. 
Spraying weeds and got rash on both 1 week, 
hands. Contact demratitis both hands. 



3049 

REPORTS OF OCCUPATIONAL DISEASE AMONG AGRICULTURAL WORKERS ATTRIBUTED TO PESTICIDES AND 
OTHER AGRICULTURAL CHEMICALS, KERN COUNTY, 1967-Continued 

Type of industry Occupation, age/sex Date of Nature and extent of injuries Period of 

disability 

Farm Laborer, 33/M. 6-26-67 Ammonia in both eyes while working. None. 

Chemical conjunctivities. 

Farm _ Laborer, 17/M 5-6-67 Was working around weed killer, started None. 

to break out face, neck, arms and 
hand. Multiple crusted infected areas 
with surrounding tissues red and 
inflamed. 

Farm Laborer, 56/M 3-9-67 I used ammonia and fertilizer in irrigating, 3 days. 

skin on my right hand started to dry 
and crack. Celljulitis right major hand 
marked edema. 

Crop dusting Swamper, 53/M 8-24-67 Loading plane with sacks Sevin and 3 days. 

sulfur. Opened the sacks, transferred 
chemical to bucket to take to plane. 
Wearing mask and goggles. Sudden 
weakness, dizzy and could not get my 
breath. Chemical toxemia due to 
insecticide. 

Farm Laborer, 52/M 6-27-67 Was working with chemicals on the ranch 3 days. 

and got sick. Nausia, vomiting, 
diarrhea. 

Farm Laborer, 54/M 7-12-67 Sulfuring grapes, has rash on arms and 3 days. 

body. Typical erythematous popular 
rash over trunk and arms. 

Farm Laborer, 58/M 9-5-67 Working in the fields, came in contact 3 days. 

with sulfur dust on weeds, has rash on 
both hands. Eczematoid reaction dor- 
sum of hands, wrists, back of neck; 
allergic-type reaction. 

Source: State of California, Division of Labor Statistics and Research. "Doctor's First Repo rtof Work Injury." Compiled 
by State of California, Department of Public Health, 1968. 

ExcEBPTS From Testimony of Thomas H. Milby, M.D., Chief of the Bureau 
OF Occupational Health, California State Health Department 

The following are excerpts of Thomas Milby, chief of the bureau of occupa- 
tional health in the California State Health Department. 

Page 3 

Thomas H. Milby, M.D., called as a witness on behalf of the intervener, and 
being first duly sworn, testified as follows : 

DIBEOT examination BY MB. AVEBBUCK 

Q. State your full name, please. 

A. Thomas H. Milby. 

Q. What is your current occupation? 

A. I am Chief of the Bureau of Occupational Health in the State Health 
Department — the California State Health Department, and I am a physician. 

Q. How long have you been in the position of Chief of the Bureau of Occu- 
pational Health? 

A. About three years. 

Q. And before that — between 1962 and 1966 — what was your occupation? 

A. I was a medical oflBcer in the same bureau. 

Q. Were you not the head of Epi . . . 

A. Head of the Epidemiology Section. 

Page 4 

Q. And what is that section concerned with? 

A. It's concerned with the special studies of skin diseases. 

Q. And between 1959 and 1962? 

A. I was a medical officer with the US Public Health Service, Division of 
Occupational Health. 

Q. Where did you receive your pregraduate training? 

A. Purdue University. 

Q. And following that, did you then obtain an M.D.? 

A. An M.D. degree at the University of Cincinnati. 

Q. And following that, did you have any internship- 



3050 

A. I interned at Ohio State University Hospital in Columbus. 

Q. Did you receive an M.S. Degree? 

A. Yes, I have an M.S. degree from the University of Cincinnati in In- 
dustrial Hygiene. 

Q. And finally, did you receive another degree? 

A. Yes, a Ma.ster of Public Health degree from the University of California. 

Q. Are you involved with any professional organizations? 

A. Yes. I am the Secretary of the Western Industrial Medical Association. I 
am an editor of the Journal of Occupational Medicine — case report editor. 

Q. And are you a member of the American Public Health Association? 

Page 5 

A. I'm a member of the American Public Health Association, and I am 
Board certified in occupational medicine by the American Board of Preventive 
Medicine. 

Q. Would you please explain what it is when you're Board certified, to the 
court? 

A. Yes. The American Board of Preventive Medicine is similar to the Ameri- 
can Board of Surgery, the American Board of Internal Medicine, whereby one, 
to gain access to tlie Board, must fulfill certain residency requirements, certain 
training requirements, and pass certain examinations. 

Q. Dr. Milby, do you have any connection with the University of California 
School of Medicine? 

A. Yes, I'm a research as.sociate at the medical center at the University of 
California in San Francisco. 

Q. Have you done any — made any publications concerning economic poisons 
and pesticides? 

A. Yes, I published a number of papers in the area of toxicology of these 
agents, and have been a contributor to a book on the subject. 

Q. Have you done any research in the area — field research? 

A. Yes. Over the period of the last four years, I have conducted a number 
of studies of economic poisons. 

Page 26 

A witness on behalf of the intervener, resumed the stand, having been pre- 
viously duly sworn and testified as follows : 

Q. You understand you are still under oath, Dr. Milby- 

A. Yes. 

Q. Has your department found that there have been special problems in ag- 
riculture due to the use of pesticides- 

A. Yes, sir. 

Q. Would you describe some of these problems? 

Page 27 

A. Well, there have been many problems. Possibly the most serious one that 
has occurred within the span of my memory with the Health Department is the 
last five or six years has been the episode of peach-picker poisoning in Stanis- 
laus County, which I incurred several years ago, in which case there were 
.some one hundred individuals, peach pickers, who were made clinically ill, and 
some undetermined number — probably far exceeding the one-hundred — who had 
aborbed enough of the toxin to have a detrimental effect on certain of their en- 
zyme .system .si)ecifically Cholinesterase. There have been other such episodes in 
the last eight or ten year.s. This is one that was studied in some great detail, 
and which has contributed somewhat to our knowledge of the problem. 

Q. What is Cholinesterase? 

A. Cholinestera.se is an enzyme which is found in a number of tissues in the 
l)ody, but its primary importance is that it is active in mediating nerve impul- 
ses; that is, as the nerve impul.ses — and I think you could think of it in terms 
of an electrical impul.se — as a nerve impulse comes down the nerve, it needs to 
cross certain junctions, which are, in fact, spaces. Cholinesterase is an enzyme 
which is involved in this nerve cro.ssing. 

Q. Would it help you if you u.sed the blackboard to describe the way it 
works ? 

A. I could do so if you like. 

Mr. Averbuck. Your honor, with your permission? 

The Court. Surely. 



3051 

The Witness. This is a schematic of the nerve. The nerve impulse comes 
down this way, and it must cross a junction called the neuron here. When the 
nerve impulse comes to this spot, it must cross this space. To do so, a com- 
pound call Acetylcholine is produced here. 

Page 28 

Acetylcholine allows the impulse to cross to the other side. Almost instanta- 
neously the Acetycholine is destroyed by an enzyme called Acetylcholi- 
nesterase. The term ASE. This compound destroys the Acetylcholine, and 
therefore breaks the contact. And in a normal situation, this is what occurs. 

Q. (By Mr. Averbuck) What would be Cholinesterase in your description 
that you gave? 

A. Well, in the first place, the Acetylcholine is produced. It is destroyed by 
Acetylcholinesterase. Any phosphate compounds destroy or inhibit the Acetyl- 
cholinesterase ; therefore allowing the Acetylcholine to remain there, and, 
therefore, you have a short circuit. 

Q. Now, you mentioned organic phosphate compounds. Could you give us ex- 
amples of those in economic poisonings? 

A. There is a long series of them. Parathion, TEPP, Diazion, Azodrin, and 
others. 

Q. And others? 

A. Many others. 

Q. These different pesticides, you say, actually destroy the Cholinesterase? 

A. They inhibit. They unite chemically with the Cholinesterase and inhibit its 
action in the destruction of this material Acetylcholine ; and therefore, a nerve 
which is imder the effect of the organic phosphate compound. This compound, 
which allows the impulse to go across, is not destroyed ; and, therefore, you 
have a .short circuit and a continuous nerve action. 

Page 29 

Q. Can you explain the effect on the human body by that short circuit- 

A. Yes. This setup — this particular physiological setup is in only certain 
parts of the body ; that is, there are a number of several kinds of — several 
nervous systems involved, and I won't go into a technical description of these. 
But the upshot is this — that in the certain systems such as certain glands, 
such as the sweat glands, the salivary glands, and certain other glands are in- 
volved here, as well as certain of the voluntary muscle systems ; therefore, in 
an individual who's under the influence of the organic phosphates, who has — 
will have such things as muscle twitching, muscle paralysis, .salavation. They 
will have diflSculty breathing because of secretions which are build up because 
of this action. They will have pupillary construction, which we call myosis. 
And you will have excessive sweating. You will have nausea and vomiting. 
You will have headache because of the central nervous system effect of this 
thing, and you will have several other symptoms. 

Q. Can that be lethal? 

A. Yes. 

Q. Has it been lethal? 

A. It has been lethal. 

Q. Do you know if it has been lethal to farm workers? 

A. It has been. 

Page 30 

Q. Do you know, for instance, which kind of pesticides have caussed fatali- 
ties to farm workers? 

A. Yes. I know from personal experience that Phosdrin, TEPP, which we 
spoke of before, Parathion, for three examples. All have been. 

Q. Dr. Milby, you talked about — excuse me if I mistate this — pupillary con- 
striction, and headache. In your experience, do people who have been poisoned 
by Parathion, for example — do they lose their sense of judgment ? 

A. Well, they could, yes, but primarily because they are ill — because they 
are exceedingly ill. And the usual picture of Parathion poisoning is headache, 
nausea, vomiting, and the other things I spoke of — heavy sweating and diffi- 
culty in breathing. And, of course, under those circumstances, one could lose 
their judgment, but the compound itself would not primarily affect judgment. 

Q. I understand, but can it, because of the illness involved, cause a dizzi- 
ness? 

A. Yes. 



3052 

Q. Do you have any idea as to the long-term effects of acute poisoning by 
Parathion, assuming the person lives? 

Page SI 

A. It is very difficult problem. There is not much known about it, but in my 
clinical judgment, in my experience, individuals who are poisoned by the or- 
ganic phosphates, primarily Parathion, take a long time to recover. It may 
take months. And during this recovery phase, they have loss of appetite. They 
have lassitude, and they have symptoms which are difficult to evaluate. But 
they certainly have symptoms for many months, but in terms of years — no, I 
think not. 

Q. Have there been any pesticides which you feel may cause permanent 
nerve damage? 

A. Yes. There have been several pesticides which have shown to have pro- 
duced permanent nerve injury. These have not been used in California or else- 
where in this country, to my knowledge, because the evidence that they pro- 
duce permanent injury appeared during their early phase of production, and 
they were withdrawn. But to my knowledge there are no compounds used here 
which produce permanent nerve damage. 

Q. Doctor, have you done any work in regards to Malathion? 

A. Yes. 

Q. Is that a fairly nontoxic organic phosphate? 

A. Malathion is a compound which is handled very well by the warm- 
blooded animals ; therefore, it is not very toxic to warm-blooded animals. It is 
quite toxic to insects. 

Q. In terms of this pesticide, Malathion, what would be the kind of dosage 
of concentrated Malathion to kill a human being? 

A. It would be several ounces. 

Page 32 

Q. How about Parathion? 

A. The toxic dose to an adult human being of Parathion would be more on 
the order of half a teaspoon. 

Q. And what about TEPP? 

Mr. Jordan. Objection, if you will. Do I gather we are talking about taking 
it orally ? 

The Witness. Yes, sir. 

Mr. Jordan. Thank you. 

The Witness. The compounds are also toxic by skin absorption, but I was re- 
ferring to oral dosage. 

Q. (By Mr. Averbuck) And TEPP — how much orally would that take? 

A. In a rough approximation, several drops. 

Q. Several drops could kill? 

A. Several drops would be a lethal dose — of lethal TEPP. 

Q. Now, the point has been brought out that this is the oral toxicity for le- 
thal dosages. Is it possible for the human body to take these pesticides in any 
other avenues? 

A. Yes. The other two avenues — routes of entry — are through the skin — 
through the intact skin, and also through the respiratory system — through in- 
halation of du.sts or mists. They are somewhat less toxic. Some of them are 
somewhat le.ss toxic if applied to the skin. Some are more toxic by skin than by 
mouth. Respiratory toxicity is not well-understood. 

Page 36 

Q. But is it not true that Cholinesterase has a certain norma ; level in the 
body? 

A. Yes. Certainly Cholinesterase does, and malnutrition in certain other 
states will reduce Cholinesterase level in plasma. 

Q. You mentioned — we have talked about residues and about the different 
ways poisons can get to people. Let's extend that to that incident which you 
referred to — the peach harvest in Stanislaxis County. Were you there- Did you 
approach the subject, or what happened? 

A. Yes. Through the country health officers health in Stanislaus County we 
became aware that there was a .serious problem among peach pickers insofar 
as they were becoming ill with some condition which wa.sn't described. We 
went to the area, and through doing blood tests — Cholinesterase — and through 
observing the operations, we determined that the peach pickers were becoming 



3053 

ill because of the residues on the peach trees. We reviewed in great detail the 
application of pesticides on these trees, because we had determined through 
methods, which I had discussed, and Cholinesterase testing, and through clini- 
cal operation, that the peach pickers had Parathion poisoning, and this was no 
longer in our minds a question. 

Page 37 

The question was why did they have Parathion poisoning, because in gen- 
eral, residues have not been shown to be toxic. We reviewed the problem very 
carefully, and found that as a matter of fact, in certain orchards in that area 
where they had applied Parathion in very heavy doses, although perfectly 
within legal limits — where they had applied Parathion in great amounts in 
these orchards — the Parathion or a Parathion related substance had remained 
and were producing, even as long as two and three and four weeks after the 
last application, was producing illness in the peach pickers. 

Q. Dr. Milby, let me see if I understand what you said. The actual residue 
on the leaves were not in violation of the law. Is that correct? 

A. The residue on the fruit was not in violation. There is no tolerance for 
residue on leaves, but the residue on the fruit was well within legal limits. 

Q. And yet farm workers were still getting ill up to four weeks, did you 
say? 

Mr. Jordan. I will object to leading his witness, your honor. 

The Court. Objection overruled. He is merely restating the question. 

Q. (By Mr. Averbuck) Did you say that even with this residue level, farm 
workers were injured over four weeks after the application? 

Page 38 

A. In some instances, yes. 

Q. Dr. Milby, how did you discover the fact that so many applications had 
been put on the different crops? 

A. In the case of peaches, the canners who buy the peaches, as a condition 
of purchase, require that they be provided with a schedule of the spray appli- 
cations that went on those fruit trees over the year. We simply asked the can- 
ners for these records, which they provided to us. And we were able thereby 
to tell what sorts of pesticides and how much went on the trees. 

Q. And the canners voluntarily gave them to you? 

A. Voluntarily. 

Q. Do you know of any other source you might have had if the canners 
would have refused? 

A. Well, the Agriculture Commissioner in Kern County — or rather in Stanis- 
laus County — would have made the information available to us. 

Q. And how would he have made that information available to you? 

A. Well, it was my understanding that he had it, because as part of his re- 
quirement, he received this information. He worked very closely with us and 
would have given us this information, except it was more convenient for us to 
get it elsewhere, because it was in the form we needed. 

Q. Doctor, that incidence you gave us in peaches, that was with Parathion? 

Page 39 

A. That was with Parathion. 

Q. Do you know if Parathion is currently being sprayed? 

A. Yes, Parathion is a very popular pesticide. It is being sprayed, yes. 

Q. What about TEPP- 

A. TEPP is being used, as well. 

Q. Finally, Doctor — excuse me — so I can get this straight, when you say 
that Parathion and TEPP are being sprayed now, do you mean right at this 
time of the year? 

A. Well, first of all, let me say I am not an expert on when spray is applied 
to what products. I do know, however, in my experience with, for example, 
peaches, that Parathion is applied at almost all times of the year. It is applied 
before the leaves come out to destroy certain insects. It is applied about the 
time that the bugs come out to do other things. It is applied two or three 
times during the period when the leaves are out and the fruit is growing. I 
suppose there are other times of the year when it isn't but it is put on for 
many months, time and time again. And I am really not conversant enough 
with the use of this material and other crops to comment. 



3054 

Q. Doctor, two more questions, please. Have there been other injuries from 
pesticides and economic poisons in Kern County to farm workers to your 
knowledge ? 

A. Based on the reports that we have received that we discussed yesterday 

Page ^0 

Mr. Jordan. I will object to the question as calling for a conclusion. The an- 
swer so far indicates he does not know of his personal knowledge. 

The Court. Objection overruled. He is basing it on the exhibit. Go ahead. 

The Witness. Based on my knowledge of the reports which we have received, 
the answer is yes. 

Q. (By Mr. Averbuck) The exhibit that we had a tough time getting in yes- 
terday, and I apologize for that, that was finally — did get in — that was for the 
year 1967. Is here one for 1968? 

A. We have nothing for 1968 which is ready for preparation. It takes a 
while to analyze these things. 

Q. And, therefore, there may have been injuries in Kern County for 1968? 

A. There may have been, but I have no personal knowledge of that. 

Q. The fact that there were, according to that list, ninety-five different- 
over ninety-five different injuries in Kern County in 1967, does that mean it 
was a unique year, or were previous years similar? 

A. We have no report — I have no similar reports on previous years. 

Page 45 

A. Yes, sir, you may conclude that. Only organic phosphate pesticides and 
certain war gas materials, to my knowledge. 

Q. How do you know that the short circuit has occurred? 

A. We measure the amount of Cholinesterase in the blood, which is an indi- 
rect indicator. 

Q. What is the outward symptom that leads you to believe there is a short 
circuit? 

A. It is a simple complex, sir. It is not any single symptom. 

Q. Does it involve convulsing, for example? 

A. It may. 

Q. Is convulsing always a result of pesticide poisoning? 

A. Asbolutely not. There are many things that cause convulsions. 

Q. Does this short circuit — has this got anything to do with the synapses? 

A. Yes, 

Page 59 

A. When he asked about pupillary constriction, there aren't very many 
things that cause that. And, as a matter of fact, the organic phosphate pesti- 
cides, to my knowledge, have their basis in the war gas materials. They don't 
happen to be gases, of course, but they have these so-called war gas, as I 
think of it, as a compound which inhibits Cholinesterase, which is an organic 
phosphate ; so war gases and organic phosphate pesticides have a very close 
similarity. 

Q. Doctor, the question was raised as to, possibly the validity of these First 
Doctor's Reports. 

A. Yes. 

Q. In your experience — or the trustworthiness of these Doctor's Reports — in 
your experience. Dr. Milby, have you found that doctors report all of the in- 
cidences that have been caused by pesticides, or that we only know some of 
them ? 

A. We have not done any studies on the reporting of physicians on pesti- 
cides. We have done studies on the completeness and validity of over-all re- 
porting. 

Q. And what has been your result? 

A. We have found — number one — it's very diflBcult to answer that question 
about do they report everything they .see. I don't known. We have found, how- 
ever, that tho.se cases which are reported are, in general, valid. 

Page 60 

Q. Finally, Doctor, in regards to Kern County — you mentioned there was a 
study that was done down here. 

A. It — we have done a study in Kern County. Yes, sir. 



3055 

Q. And do you know what that study concerned? 

A. It was a — it had many facets to it, but, primarily, it was involved in col- 
lecting tissues to analyze for pesticides. There were primarily autopsy tissues ; 
and, secondarily, there was a study which was done here to compare certain 
kinds of mortality — from certain causes in the pesticide days, that is now ver- 
sus the days before pesticides, and to see whether there was any difference in 
the causes of death. 

Q. Was there any difference? 

A. No. 

Q. Did the study also go into the question concerning different growers in 
these areas? 



Excerpts FIiom Testimony of Thomas C. Griffin, Coowner of a Pesticide 

Company 

The Following are excerpts of Thomas Clyde Griffin, coowner of a pesticide 
company. 

the pages indicated below are taken from transcript 

Thomas Clyde Griffin, called as a witness on behalf of the plaintiff, and 
being first day duly sworn, testified as follows : 

direct examination by MR. WALL 

Page 99 
Q. Would you state your name, please? 
A. Thomas Clyde Griffin. 

Page 100 

Q. And what is your occupation? 

A. I am engaged in the field of agricultural pest control. 

Q. Are you a member of the organization known as the Kern Agricultural 
Chemical Association, which the members of whom are the plaintiffs in this 
proceeding? 

A. One of the companies, which I am a co-owner, is a member of the Kern 
Ag Chemical Association. 

Q. And you are also an officer of that company- 

A. Yes. I am the president of that corporation. 

Q. And what is the name of that corporation- 

A. Southern Valley Chemical Company, Inc. 

Q. Mr. Griffin, you made the declaration supporting application for prelimi- 
nary injunction under oath, which has been filed in these proceedings that 
have been referred to. Is that correct? 

A. That is correct. 

Q. Are you that gentleman? 

A. Yes, sir. 

Q. Your honor, could I 

The Court. It has been admitted in evidence, Mr. Wall. It is not necessary 
to cover all the details. 

Mr. Wall. All right, fine. I just want to refer him, your honor, without — I 
will not go in and repeat what is in there. I just want to 

cross-examination by MR. AVERBUCK 

Page 108 

Q. Mr. Griffin, so we can get that last question as clear as possible, I show 
you now a copy of your deposition. 

Mr. Wall. Page, counsel. 

Mr. Averbuck. Page 32. Line 9, I believe is when it starts. Could you please 
read that to the court? 

The Witness. Do you wish me to start where you have outline it? 

Q. (By Mr. Averbuck) Well, I believe that is where the question begins. 

A. All right. 

Q. Mr. Wall had objected so I believe I rephrased the question. 

A. "Q I will rephrase the question. Do you feel you would have given this 
information to Mr. Morley had he requested it without giving you a guarantee 
of it being confidential ? 



3056 

"Mr. Wall. You mean all of the information contained is these reports? 

"Mr. Averbuck, Exactly. 

"The Witness. I am going to be perfectly honest with you and say this, that 
as a licensed operator in this county, having filed in this county, if I am given 
a report that has this information on it and this is the report that I am to file, 
then I will file it, regardless of whether — that is the way I see it, Steve. 

Page 115 

Q. Thank you. Did you ask them why they had limited to that period? 

A. No, and I would like to point out — when I point out I would like to state 
this — and certainly, this is no reflection on the fine Kern County Department 
that we have down here where we have people to help us within this matter, 
but many times there are decisions that can only be made by those of us in 
the field. You ask if I ask them — should I make this — can I make this applica- 
tion or should I make it, and I suggest to you that this department itself has 
asked me at times to take part in their seminars to inform them on pest con- 
trol. 

Q. Thank you. Don't you feel somebody should watch over the people who 
apply economic poisons? 

Mr. Wall. I object, your honor. 

The Court. That will be sustained. 

The Witness. Yes, I agree. 

The Court. The objection was sustained. 

The Witness. Sorry. 

Q. (By Mr. Averbuck) Does your company use Parathion? 

A. My company uses Parathion. 

Q. Does your company use Malathion- 

A. My company uses Malathion. 

Q. When do you use Malathion? 

Page 116 

A. We generally use Malathion when I feel it is safer to use Malathion than 
It is Parathion. 

Q. And could you give us examples of when it would be safer to use Mala- 
thion than Parathion? 

A. Certainly, I would be more than — 

Mr. Jordan. I will object to the relevancy of the question. 

Mr. Averbuck. I think the answer will explain the relevancy. 

The Court. I will overrule the objection. 

A. I would use Malathion when I have a house on the property that is being 
treated, or when I might have adjoining livestock that are close and there 
could be a drift on that livestock. This is a discrimination I make for the 
safety of people around me or animals. 

Q. So, in other words, you will not use Parathion if you feel it would hurt 
human beings? 

A. Certainly, that is so. 

Q. So you feel it can hurt human beings? 

A. There is no question about it. 

Q. What about TEPP? Do you use that? 

A. Yes, I use Tetraethyl pyrophosphate. 

Q. Do you use it now? 

The Court. Didn't we all stipulate in the beginning that these things were — 

Mr. Averbuck. There is a special point on this that was brought out in the 
deposition. 

Page 117 

The Court. I recall we stipulated that these could hurt people. 

Mr. Averbuck. Well, this is a very crucial point, your honor. 

Q. (By Mr. Averbuck) Do you use TEPP? 

A. Yes, I do. Yes, I have. I do not use it now. 

Q. Would you please explain to the court why you do not use it now- 

A. I do not use it now because in a ground rig operation, and I am a 
ground rig operation — not an aircraft operation — the people that would be 
applying this thing, this material, have to be in close proximity, of ten work- 
ing through the drift of insecticides, and as far as I am concerned, the drift 
of this insecticide In proximity to the workers, is too dangerous for my com- 
pany to tolerate. 



3057 

Q. Would it be fair for me to say that you feel, and I believe you stated 
this in your deposition — correct me if I am wrong; that you feel TEPP is so 
dangerous that even though you have confidence in your workers using it cor- 
rectly, you still don't want them to use it? 

A. This is correct in my ground rig spray operation. I do not intend to tes- 
tify other than to my own operation and the type of operation it is, but as far 
as I am concerned, in my own operation there is a policy by me that this ma- 
terial will not be used. 

Q. Have you ever personally been sick from TEPP? 

Page 118 

A. Yes, I have. 

Q. Would you please tell the court about that one? 

Mr. Jordan. Object, your honor. 

Mr. Wall. Object, your honor. 

The Court. What is the basis for the objection? 

Mr. Wall. Irrelevant, your honor. 

Mr. Jordan. It has no relevancy to any of the issues in this case, and I 
would be glad to hear an offer of proof. 

The Court. Well, I would like to hear some arguments on the question of re- 
levancy. Why isn't it relevant? 

Mr. Jordan. What issue in the case, your honor, does this testimony as to 
what happened to him from insecticides, give to it? 

The Court. Well, we are dealing here with a question, gentlemen, of whether 
or not we are going to issue the preliminary injunction against the use of 
some — not against the use, but to permit the inspection of records, and I think 
you have to balance the interests here when you get into this area, and one of 
the questions is : Is this dangerous to people, and under what circumstances is 
it dangerous to people ? 

And he said that this particular product, as far as he is concerned, if he ap- 
plied it on the ground and it drifted against these workers, it would be dan- 
gerous to them. 

Now, why isn't that relevant to the question of determining whether or not 
— it may be a little remote, actually, but I think it has some relevancy. It may 
go the weight of the thing, counsel, but I think it is relevant. 

Page 119 

Mr. Averbuck. Might I also add, your honor, that we also feel it is relevant, 
because one of the points that we wanted to be stipulated to earlier, our point 
was — even if handled properly, some of these things are so dangerous, they 
should not be used. 

The Court. The objection is overruled ; you may answer the question. 

The Witness. Would you rephrase the question? 

Q. (By Mr. Averbuck) Would you please explain the incident of when you 
got ill because of TEPP? 

A. I was flagging some TDPP over a very long period of time, and I did not 
take what were normally considered the proper precautions. At this tipae 
was in charge of pest control just prior to going into business for myself a 
long long time ago, but briefly, that is what happened. 

Q. And how did you know you became ill from TEPP? 

A. I had the common symptoms that one would suspect I have. I had pin- 
point pupils. Vision was blurry, headache, sweating of the palms, and so on. 

Q. Did you have nausea? 

A. Yes. 

Q. And did you have trouble breathing? 

A. A little congestion. 

Q. In other words, you were good and sick. 

A. For a very, very short period of time. 

Page 120 

Q. But you were sick. 

A. Yes, I was. 

Q. Do you know the cumulative effect of economic poisons on the environ- 
ment of Kern County? 

A. Do I know? 

Q. Yes. 

A. No, I don't know what they are. 



3058 

Q. Mr. Griffin, isn't it a fact that you told Mr. Cohen that you recognized 
that there was something wrong with pesticides, and that you hoped someday 
you would be able to have viruses that will do the work? 

A. I stated this — that with the regulation of pesticides as they are today ; 
with the tremendous amount of time that it takes to get these products regis- 
tered — that it was going to require a total picture of viruses, bacteria, and all 
the rest to properly control pests. 

I do not believe that these pests totally can be controlled by insecticides or 
viruses. I think that it takes an integrated program to do this sort of thing, 
and I would like to mention that in this discussion, that this question that you 
have just brought up — this question came up before Mr. "Wall and I — when we 
were endeavoring to try to find out just what part of this information you 
would be satisfied with. And I think Mr. Wall heard exactly what I was dis- 
cussing at that time. 

Page 123 

Q. Are you familiar with the department — University of California Davis' 
Agricultural Department stating in their bulletin each year that they do not 
think organo-phosphates should be mixed ? 

A. If you are asking if I combine two organo-phosphates — is that the ques- 
tion? 

Q. Yes. 

A. No. 

Q. Do you combine them with other chemicals? 

A. As I recall, I believe some of these applications of combinations have 
been made, but like I .say, you are asking me to make a determination over a 
volume of work which I am not prepared to say at this time. 

Q. Now, finally, to points. I think this will sum it up. You talked about 
washing the grapes. 

A. That is correct. 

Q. Now, that was a little bit suprising becau.se, am I correct in gleaning 
from your testimony, that you are saying that you wouldn't want this infor- 
mation out because you want to keep it hidden from the public? 

Page 124 

A. Not from the public at all. Certainly not from the public. What I am 
trying to say is this : That over the course of time, because of the way it was 
done, there was a general feeling by buyers that grapes that have been washed 
were not good grapes to buy because their appearance had been somewhat de- 
stroyed, and certainly in the past this was so. So, during the course of history 
of washing grapes, the term "washing," making an application, at this time be- 
came very detrimental to the grower, and he was not interested in having any- 
one know this was done. 

Q. Even the buyer? 

A. Even the buyer. I am saying, however, that this kind of work can be 
done today and is often done today, and with the appearance of the grape 
being perfectly natural, because of the techniques that are used. 

Q. Are you saying then, that to show this information would permit the 
buyer to find out something you would rather he not find out? 

A. I am saying this, that to permit the buyer to see this information and 
have this buyer boycott the purcha.se of those grapes without taking a look at 
them — and buyers certainly look at their grapes — they should make a determi- 
nation on the visual inspection of tho.se grapes rather than some report that I 
have file down in the Agriculture Commissioner's office. 

Q. Have you been appointed by any buyer to make that decision for them? 

A. No, but I have been appointed by growers to make that application for 
them. 

Q. No further questions, your honor. 



Excerpts From Testimony of C. Seldon Morley, Agricultural Commissioner, 

Kern County, Calif. 

The following are excerpts of C. Seldon Morley, agricultural commissioner of 
Kern County. 

Page 13 

C. Seldon Morley, called as a witness on behalf of the plaintiff, and being 
first duly sworn testified as follows : 



3059 

EXAMINATION BY MB. WALL 

Q. Mr. Morley, would you state your fully name, please? 
A. C. Seldon Morley. 
Q. What is your occupation, Mr. Morley? 
A. Agricultural Commissioner of the County of Kern. 
Q. And how long have you been so occupied ? 
A. Since 1955. 

Q. In such capacity, Mr. Morley, has it been your duty to prescribe rules for 
the filing with you of pest control operators' ports? 

Page H 

A. May I hear that again? 

Q. You are aware of the type of reports that we are concerned with in this 
proceeding? 

A. Yes, sir. 

Q. The pest control operator reports? 

A. Yes, sir. 

Q. And the question was, or intended to be — are you the man that ordered 
those filed with you? 

A. Yes, sir. 

Q. I see. And, you have taken the position with regard to this proceeding, 
Mr. Morley, that those reports were filed with you at your request in confi- 
dence, and with the understanding that you would maintain them in confi- 
dence. Is that correct? 

A. That is correct. 

Q. And you know of your own knowledge, do you not, Mr. Morley, that these 
records do contain trade secrets and other items of information which are per- 
sonal and private business information of various persons? 

A. Regarding the trade secrets — that is more for chemical companies or 
things like that. Regarding the others, I understand that they have been con- 
sidered as confidential in their crops, and et cetera, and I have maintained 
them as confidential on that basis. 

Page 15 

Q. And from time to time over the years, you have met with members and 
representatives of the Kern Agricultural Chemical Association — members of 
whom I am representing in this proceeding. Is that correct? 

A. Yes, sir. 

Q. And this matter of the containing of confidential, private information, 
and the holding them in confidence by you, has been discussed numerous times 
at those meetings. Is that correct? 

A. It has. 

Q. And you have always maintained that confidence to the extent that you 
have even, on occasion, refused to let representatives of governmental agencies 
see them except going to the principals and getting their consent. Is that cor- 
rect? 

A. That is correct. 

Q. But that doesn't apply to the Health Department, I believe. 

A. I have co-operated with the Health Department regarding the application 
of pesticides. 

Q. All right. Now, and when there has been any claim of any personal in- 
jury or any crop damage made to you, you do then make those available in 
such cases without any problem involved. Isn't that correct? 

A. May I explain that a little bit? 

Q. Yes. 

Page 16 

A. When there is a report of a crop damage, with the permission of the 
owner or the applicator, then we take that one report pertaining to that one 
job and let them see that one report. 

Q. All right. Now, does the same hold true with regard to a claimed per- 
sonal injury? 

A. That is correct. Under those conditions. 

Q. Yes, Now, is it your understanding, Mr. Morley, that in this attitude 
which you have maintained with regard to these reports, that you have been 
carrying out the policy of the California Department of Agriculture? 

A. Yes, sir. 



3060 

Q. And — may I see the — your honor, may I please see the file? I need to 
refer to that exhibit. 

The Court. Yes. It's right there. 

Q. (By Mr. Wall) Mr. Morley, I show you here — this is in evidence as Ex- 
hibit A. It is the declaration of Mr. Thomas C. GriflSn. 

Mr. Averbuck. May I take a look at that, your honor? 

The Court. Don't you have a copy? 

Mr. Averbuck. Well, I wanted to see what he was showing to him. 

Mr. Wall. Policy Letter 1-3. 

The Court. This declaration was served on all counsel, I presume. 

Mr. Wall. Yes. your honor. 

Page 17 

Q. (By Mr. Wall) This is attached, Mr. Morley — it is designated Exhibit D, 
Page 1, 2, and 3 — to the declaration of and supporting the preliminary injunc- 
tion by Thomas C. GriflSn. I ask you to look at that, and look at each page, if 
you will. 

A. Yes, sir. I have read this. 

Q. All right, Mr. Morley, that states that it is Policy Letter 1-3, and it 
shows that it is from the State Deparment of Agriculture and it is dated 
April 7, 1964, and it is signed by Charles Paul, then director, purportedly, and 
I ask you — does that set forth the policy under which you have been operating 
with regard to the confidentiality of these reports? 

A. That is correct. 

Q. And, insofar as you know, is the policy of the State Department of Agri- 
culture still the same? 

A. So far as I know. 

Q. And I suppose that you advised them in some manner when this injunc- 
tion matter came up, and had some discussion with your superiors in Sacra- 
mento on it? 

A. I contacted them verbally, and told them the action I had taken, for 
their information. 

Q. And I suppose they approved it. 

A. There was no objection. 

Q. I see, and then, if you will look at — on the second page, I believe it is — 
looking at the second page of this policy letter that we are referring to, and I 
ask you to note in particular Subsection 6 and Subsection 9. If you will look 
at 6 first, and it is your position, as I understand it, that these subject reports 
that this lawsuit is about are covered by that section? 

Paffe 18 

A. In part, yes, sir, 

Q. That is, part of that section covers these reports? 

A. Right. 

Q. And also Subsection 9, as I take it. 

A. Yes, sir. 

Q. Excuse me, I referred to that as Exhibit A, and it should be for the rec- 
ord, Exhibit No. 1. Sorry. That is all. 

The Court. This is your client. Correct? 

Mr. Jordan. Yes, your honor. 

The Court. I think we had better proceed with cross-examination and then 
we will have direct on your part. 

Mr. Jordan. Thank you. 

Mr. Averbuck. Your honor, may I ask a question? There are some other 
areas that were not touched by Mr. Wall. Am I free to go into them? 

The Court. You can call him under Section 776 of the Evidence Code as an 
adverse witness. Perhaps, in view of that, may Mr. Jordan — we could — maybe 
it would be better procedurely if you did ask him — or would you prefer not 
to? 

Page 19 

Mr. Jordan. If it pleases the court, in the absence of any objection of coun- 
sel, I would like to move it forward as fast as we can with both of these par- 
ties presenting their evidence. I reserved the right to put something on later. 

The Court. All right, you will proceed, Mr. Averbuck, please. 



3oei 

Page 27 

A. Paragraph No. 5. Quote — 

The Court. This question was compound. First he wants to know — is the 
paragraph that you are referring to on crop acreages in the law that you said 
you did not know. Is this what you are referring to? 

The Witness. Yes, sir. 

The Court. Now, the second part is — read it if it is. 

The Witness. "List of persons reporting and reports made by farmers, stock- 
men, processors, dealers, handlers, and others, to the California Crop Report- 
ing Service, as well as the tabulated copies of such reports and copies of re- 
ports made to the Federal Crop Reporting Board at Washington, D.C." And 
then in parentheses it has, "Federal regulations require confidentiality." 

Q. Mr. Morley, as I look at No. 5, it's talking about reports that are made 
to the California Crop Reporting Service, and reports made to the Federal 
Crop Reporting Board of Washington, D.C. Are the pest control applicators' re- 
ports made either to the California Crop Reporting Service, or the Federal 
Crop Reporting Board at Washington D.C. ? 

A. Not that I know of. 

Q. Thank you. Mr. Morley, Mr. Jordan this morning has stated that — and 
you have stated in your pleadings — that you have weighed the public policy in 
whether or not to show these records publicly. Is that true? 

Page 28 

A. That is true. 

Q. Mr. Morley, what did you weigh in the public policy? As you weighed the 
public policy in this matter, what factors did you take into consideration? 

A. I took into consideration this paragraph here. This policy letter. The re- 
quirements that we have regarding crop acreage. We assist in taking crop 
acreages. We have, in the oflSce, the acres for individuals. That is not to be di- 
vulged although we may have them. That is included in those reports ; there- 
fore, the crop acreage in these reports would be divulged if they were released 
to the public, and that is considered one of the reasons why they are held eon- 
fldentially. 

Q. Can you give me other reasons — the other factors which you took into 
consideration when you felt that it was in the public interest not to let these 
records be made public ? 

A. I tried to consider everything that I could think of. I can't remember 
just all of them at the present time, but I tried to consider all factors, and — 

Q. Would you like me to ask you some of them, or do you want to keep 
talking? 

A. You may ask the questions. 

The Court. If you want to finish the answer, you may. 

The Witness. Would she quote my last part of that last three or four lines? 

Page 29 

Q. Would you please read that back? Excuse me, Mr. Morley, I didn't mean 
to cut you off. 

(The answer was read by the reporter.) 

A. I tried to consider all factors regarding crop acreage, the regard of the 
dosage of materials used, because that could be changed by the grower and 
still remain within the legal tolerance of the requirements of that material as 
it was registered. It is that grower's personal confidential right to do those for 
his own information, for his own crops, without divulging that information to 
anyone else. And I have maintained that confidentiality, and I took things like 
that into consideration. 

Q. May I ask you if you took some other things into consideration? 

A. Undoubtedly I did. 

Q. Mr. Morley, did you take under consideration the health of farm work- 
ers? 

A. I did because it is part of our work to. Under the Administrative Code, 
there is a section in there that relates to protection of persons. 

Q. When you took the health of farm workers under consideration, did you 
contact the Department of Public Health in Kern County to ascertain their 
analysis of any health problems caused by pesticides in economic poisons? 

A. Occasionally I do. 

Q. When did you first contact the department? 



3062 

Page so 

Mr. Wall. Your honor, may we please have counsel required to permit the 
witness to comple his answer? 

The Court. Yes. 

Mr. Averbuck. I'm sorry, your honor, I apologize. 

The Court. I am sure it's not intentional, but if you would permit him to 
complete his answer. He sometimes takes a little time to think about these. 

Mr. Averbuck. I understand, your honor. 

The Witness. Thank you. 

The Court. There is no hurry. Take your time and answer completely. 

Q. (By Mr. Averbuck) Mr. Morley, have you contacted the Department of 
Public Health for Kern County to determine if there have been any problems 
with economic poisons in Kern County? 

A. Occasionally I have. 

Q. When was the first time you contacted them, Mr. Morley? 

A. I do not remember. 

Q. Mr. Morley, in your deposition, did you not state that you contacted them 
for the first time about the dangers of pesticides in Kern County one month 
age? 

Mr. Wall. If the court please, may we have Mr. Averbuck show him rather 
then just ask him the summaries of the deposition? 

Page 31 

The Court. The objection is overruled, Mr. Wall, Under the Evidence Code 
you no longer have to show a witness a written statement or a deposition be- 
fore you can read from it or impeach him with it. 

Mr. Wall. I believe he does have to read from it, your honor, does he not? 

The Court. He can ask him under the New Evidence Code provisions. It 
used to be the rule. I will get the section here. 

Mr. Wall. Your honor, I will withdraw the objection. 

The Court. It's under 785 of the Evidence Code. 

Mr. Jordan. I think he is merely offering to refresh memory at this point, 
and I think it's okay to ask him if he said that in his deposition. Can you an- 
swer the question, Mr. Morley ? 

The Witness. Y'es, .'«ir. I was referring at that time as the first time to con- 
tact the Health Department regarding the inquiry I had for workers in the 
field. This was after some of your representatives came to the office for those 
— for that information of individual reports. I have contacted the Health De- 
partment that on occasion prior to this — a year or two ago — if I may u.se an 
example ; but when I said about a month ago was when I was asked for these 
reports, and they said that they had heard someone had been injured by pesti- 
cides, I referred them to the Health Department, either county or state. Then 
I contacted them and asked them if they had anything. Now, that was the rea- 
son I answered at that time quote approximately one month ago, close quote. 

Page 32 

Q. Mr. Morley, have you notified the Department of Pul)lic Health of Kern 
County that they .should keep in contact with you if they did hear of any inju- 
ries in Kern County due to economic poisons? 

A. Not so far, no, sir. 

Q. Had you contacted the State Department of Public Health ? 

A. No, sir. 

Q. Have you contacted any doctors? Have you contacted anybody? 

A. No, sir. 

Q. Mr. Morley, do you know the toxicity of the different pesticides used to 
human man? 

A. I have in the office some charts .showing that. 

Q. Mr. Morley, I show you this piece of paper here. Is that the chart you 
are talking about? 

A. Yes, sir. This is one of them. 

Q. May we mark that for identification, your honor? 

The Court. Show it to the other counsel, if you will, please. 

The Witness. May I explain the .source of that chart? 

Mr. Averbuck. Certainly. I will get to that, Mr. Morley. I will ask you about 
that. 

Mr. Wall. There is no objection. That can go right into evidence. 



3063 

Page Ifl 

Q. (By Mr. Averbuck) Mr. Morley, on the day that Mr. Cohen came to see 
you in your office, back in August, did you specifically refuse to show him the 
applicator reports? 

A. I told Mr. Cohen that they were kept in confidence and that I could not 
show him those reports- 

Q. Did he come during office hours ? 

A. He did. 

Q. Now, these records which you are referring to, I want to get some infor- 
mation in terms of these records so we know what we are talking about in 
this case in the record. Mr. Morley, is this a copy of your record? 

Mr. Jordan. May we see it? 

Mr. Wall. May we see it, please? 

Mr. Averbuck. Yes. 

The Court. I think the proper way to proceed here is if any document is 
going to be used to question a witness, or to be presented here, that we ought 
to mark it for identification and permit counsel to see it before it is used. 
That will apply all the way around. Everybody on every side. 

The Clerk. Intervenor No. 4 for Identification. 

Q. (By Mr. Averbuck) Mr. Morley, would you take a look at that, please? 

The Court. Counsel, have you seen that? 

Mr. Wall. If the court please, there is a copy of that in evidence. 

Page 43 

A. Under crop, and acreage. 

Q. Excuse me. I don't think — I think I'm getting you mixed up a little bit. 
I'm concerned about trade secrets. 

Mr. Jordan. May I ask for clarification, your honor? You are not asking him 
what information on there he considers as confidential. 

Mr. Averbuck. That's right. 

Mr. Jordan. Y"ou are asking him what he considers to be of the nature of 
trade secrets? 

Mr. Averbuck. That is right. 

The Witness. May I refer that to the chemical companies for their trade se- 
crets regarding their formulas and et cetera. 

Q. (By Mr. Averbuck) Do you feel that the formulas are trade secrets? 

A. So far as they are concerned, I believe they are. 

Q. Why do you believe they are, Mr. Morley? 

A. From the different formulations that each one of them makes. 

Q. Mr. Morley, are you aware that every one of these formulas are on the 
labels of the pesticides? 

A. That is correct. 

Q. And those labels are probably in every store in this state that sells pesti- 
cides. 

A. But it does not give all of the ingredients in some cases, and I would like 
to refer that again to the chemical companies or the manufacturers to answer 
your question. I am not qualified to answer why they consider some of those 
trade secrets. 



Excerpts From Testimony of Edward P. Lester, Director and President, 
Central California Medical Laboratories, Fresno & Bakersfield, Calif. 

The following are excerpts of Edward P. Lester, director and president of 
central California medical laboratories, with offices in Fresno and Bakersfield, 
both. 

PAGES INDICATED BELOW ARE TAKEN FROM REPORTER'S TRANSCRIPTS 

Page 82 

Edward P. Lester, called as a witness on behalf of the intervener, and being 
first duly sworn, testified as follows : 

Q. Would you state your full name, please? 

A. My name is Edward P. Lester. 

Q. And what is your current occupation ? 

A. I am the Director and President of Central California Medical Laborato- 
ries, with offices in Fresno and Bakersfield, both. 

36-513 O— 70 — pt. 6 A 5 



3064 

Q. Where did you receive your undergraduate training? 

A. I am a graduate from U.C.L.A., and I did my graduate work at the 
U.S.C. School of Medicine. 

Q. Dr. Lester, have you ever been licensed by the State of California for 
anything? 

A. I am Mr. Lester. 

Q. Excuse me. 

A. And I am a licensed clincical bioanalyst and laboratory director since 
1954. 

Q. And were you licensed prior to that? 

Page 83 

A. Yes. I was a licensed clinical technologist. 1950 through 1954. 

Q. Now, is it true that in this state only an M.D. or a bioanalyst like your- 
self can legally be a director of a licensed clinical laboratory? 

A. That is correct. 

Q. And you do have a license in a clinical laboratory ? 

A. Yes. 

Q. Do you have any professional aflSliations? 

A. At present, I'm a member of the California Association of Bioanalysts. 
I'm a former National Vice President of the American Association of Bioana- 
lysts, and several other professional associations, including the American Asso- 
ciation of Clinical Chenii-sts, and other organizations dealing with my field. 

Q. Are you familiar with Cholinestera.se testing? 

A. Yes, I am. 

Q. When did you first become familiar with it? 

A. As we understand it, we were one of the first clinical laboratories in the 
State of California to set this test up on a regular basis in early 1954, here in 
Bakersfield. 

Q. So it has been over — almost fifteen years now? 

A. Exactly. 

Q. And have you run many Cholinesterase tests? 

A. It would be hard to estimate in fiteen years' time, but it would be in ex- 
cess of fifty thousand separate tests. 

Page 8// 

Q. And for what purpose do you run these tests? 

A. These tests are run only, in my experience, in case of exposure to organic 
phosphates. 

Q. And by that, you are referring to such economic poisons as Parathion 
and TEPP? 

A. Yes. We count several hundred, actually, different formulations. 

Q. Have you ever done any work for the State Department of Public 
Health? 

A. Yes. The State Department of Public Health lends considerable encour- 
agement and technical assistance to clinical laboratories in the field ; particu- 
larly the Bureau of Occupational Health. In addition, we have engaged in sev- 
eral research projects, and we have kept the state posted on the results of 
these research projects as it related to organic phosphates. 

Q. Have you ever had any publications? 

A. Yes. In this particular field alone. I presented a pai)er to the International 
Congress on Clinical Chemistry in Europe, and the paper was published in its 
entirety at the proceedings of that congress, published by Butterworth, 1961. 

Q. Mr. Lester, are you presently administering Cholinesterase tests? 

A. We are presently administering Cholinesterase tests on a routine basis 
for, I would suggest, most of the commercial operators in the San Joaquin 
Valley. 

Page 85 

Q. Would that include people from this country? 

A. Yes. 

Q. Are you familar with any injuries due to organic phosphate? 

A- Many. 

Q. How can you be certain that the Cholinesterase tests shows — might show 
an injury to biorganic phosphates? 

A. I can say quite positively that the Cholinesterase test is a specific indica- 
tor of not only acute exposure to organic phosphates, but to subclinical forms 



3065 

of poisoning. The test is highly specific in this regard, and the test is run in 
two parts. It is actually two different tests. We run a test both on the plasma 
of the serum, which is the — that type of test which is first affected by the 
presence of organic phosphates, as well as the red blood cells. 

Now, if the plasma is considered nonspecific, merely exposure or not expo- 
sure, then the RBC is conceded to be a direct measure — excuse me, I beg your 
pardon — the red blood cell test is conceded to be a specific measure of central 
nervous system damage. 

Q. Mr. Lester, have you seen any injuries because of organic phosphates? 

A. Yes, many. 

Page 81 

Q. Doctor — excuse me — Mr. Lester, have you been approached by the United 
Farm Workers Organizing Committee to set up a testing program? 

A. Yes, I have. 

Q. And in that regard, would you be working hand in hand with the United 
Farm Workers Organizing Committee in setting up that program? 

A. If this is of their mind, yes. 

Q. Mr. Lester, could you please explain how the Cholinesterase test spots — 
how you use the Cholinesterase test in determining the degree of toxicity that 
a person has acquired? 

A. With your permission, may I use the blackboard? 

The Court. Certainly. 

The Witness. The Cholinesterase test is a specific measure of nervous dam- 
age. It is run in two parts, as I said before. Plasma and red blood cells. It is 
essential that we determine a specific level in every individual before exposure, 
so that we have some basis of comparison during the coming season, or in the 
years to come. Now, this is called an individual worker's base line. Everything 
else will be compared to this ba.se line. 

Now, at the time of exposure, if this is a person's base line of red blood 
cells and plasma, and exposure is at this period, the plasma is the first one to 
go down. It is also the first one to return to normal after that worker is no 
longer exposed to organic phosphates. The RBC follows in this manner. It 
trails behind the plasma, and this is the one that we are most concerned with 
in that RBC is the one that reflects more precisely the statiis of the central 
nervous system. Once the RBC goes down, it will delay a long time before 
coming up. 

Page 88 

Now, from an economic standpoint, this means that if we can detect early 
changes in the plasma, it is very easy for us to recommend that such a worker 
be removed immediately from further exposure, and long before the RBC 
starts to drop and becomes dangerous. 

This means that we are not dealing yet with clinical symptoms, acute symp- 
tomology, but rather we are dealing with the first preliminary indication of 
poisoning, and that further exposure will precipitate the clinical symptoms 
that have been described here today. 

Now, if the worker can be removed by running these tests at an early 
enough state, we are speaking then of removal from the job on one day, two 
days, three days, or a week. But once the RBC goes down, we may be speak- 
ing of a poisoning situation which may not return to normal for perhaps a 
month or longer. So, it is essential that we identify poisoning long before clini- 
cal symptoms appear. 

Now, the curve I have drawn here are nice slopes. Actually it doesn't work 
quite that way. Every individual has different reserves to accommodate loss of 
Cholinesterase, as was explained to you by Dr. Milby. Now, we find that when 
we give an individual with exposure at this point, we find that nothing hap- 
pens for a considerable length of time. These are reserves that every in- 
dividual has. Further exposures — they reach various plateaus, various pla- 
teaus. In other words, it's not an even drop in Cholinesterase. What I am 
saying is that at this point, unless this worker were identified, even a .small 
minor exposure will precipitate a fantastic drop in Cholinesterase. I personally 
have seen this drop from a normal level to this point in less than thirty min- 
utes. At this point, clinical symptoms appear. The victim is prostrate, and we 
are talking about an emergency situation often requiring heroic measures. 



3066 

ExcEKPTS From Testimony of Robert Van Den Bosch, Ph. D., Professor of 

PyNTOMOLOGY. TNIVERSITY OF CALIFORNIA. BERKLEY. CALIF. 

The following are excerpts of Robert Van Den Bosch, professor of entomol- 
ogy at the University of California at Berkeley. 

PAGES INDICATED BELOW ARE TAKEN FROM ACTUAL REPORTER'S TRANSCRIPTS 

Robert Van Den Bosch, PH.D., called as a witness on behalf of the inter- 
venor, and being first duly sworn, testified as follows : 

DIRECT EXAMINATION BY MR. AVERBUCK 

Page 116 

Q. State your full name, please. 

A. Robert van den Bosch. 

Q. Mr. van den Bosch, where do you now reside? 

A. Kensington, California. 

Q. And were you subpoenaed to come down here today? 

A. Yes, I was. 

Q. Dr. van den Bosch, what is your current occupation? 

A. I am a Professor of Entomology at the University of California at Berke- 
ley. 

Q. When did you receive your Masters of Arts? 

A. In 1943. 

Q. And where? 

Page 117 

A. From Berkeley. 

Q. Did you ever receive a doctorate? 

A. Yes, in 195S at Berkeley. 

Q. What was that doctorate for? 

A. In the field of entomology. Specifically, my training and background was 
in Economic Entomology. 

Q. Did you do any work at the University of Hawaii? 

A. Yes, I was there for two years in the Experiment Station. 

Q. And did you do any work for the University of California at Riverside? 

A. I was tliere for twelve years in the Experiment Station. 

Q. Did that include considerable foreign travel? 

A. Yes. 

Q. Would you describe some of the traveling you did and tlie work you did? 

A. One of my areas of activity is biological control which is, in tliis context, 
is the introduction of exotic beneficial insects — predaceous and parasitic in.sects 
to be used against agricultural pests. Since a great number of our agricultural 
pests are of exotic origin, one of the techniques of the pest control is to seek 
their native home, and to obtain therefrom the parasites and predators that 
affect them there ; trans-sliip them to California, in this case, screen them 
through a (luarantine laboratory, and produce them in an insectory and release 
them in the field against tlie infestion of these pests in the hopes that they 
will establish their old relationships, and effect suppression, in general, of the 
pests. So this entails a considerable amount of foreign work. 

Page 118 

Q. In other words, you've left the country and have gone to many other 
countries? 

A. Yes, I have spent about five and a half years overseas in the last twenty 
years. 

Q. Do you have any relationship — or have you had any relationship with the 
Entomological Society of America? 

A. Yes, I have been a member, I sui)po.se now, almost — for almost twenty 
years. 

Q. Did you ever hold any formal position with themV 

A. I was a chairman of one of the subsections. A sub.section of biological 
control. 

Q. Have you received any fellowships because of your work ? 

A. I received the Guggenheim Fellow.ship to study the parasitism of aphids. 
I have received .several grants, both from industrial and from the National in- 
stitutes of Health, and from the National Science Foundation for Research. 



3067 

Q. In 1963, did you transfer to the Division of Biological Control? 

A. I transferred from Riverside to Albany, which the Division of Biological 
Control — is one of the tliree divisions of the Department of Entomology and 
Parasitology at Berkeley. Yes 

Page 119 

Q. Have you had any speaking engagements? 

A. Oh, yes, of various sorts. I have spoken before many agricultural groups ; 
before various .scientific groups; universities; international congresses of sev- 
eral kinds, relating to my field. 

Q. And you were invited to those? 

A. On a number of occasions, yes. 

Q. Have you published any articles concerning insecticides in the pest con- 
trol? 

A. Oh, yes. I suppose — my list of publications is, oh, I guess, approximately 
eighty — but perhaps half of those are concerned with pest control in one sense 
or another, and many of them have involved the use of chemicals. 

Q. And when were you appointed a Professor of Entomology at Berkeley? 

A. I believe in 1967. 

Q. And you have been in that capacity now for almost two years? 

A. Yes. 

Q. Have you had any form of public service? 

A. No in the elective sense, or of a formal nature, that I can recall. I have 
given talks and I give to the United Fund, and things like that. 

Page 120 

Q. Now, Dr. Van Den Bosch, you mentioned that you work with integrated 
control — in the field of integrated control. Could you please explain that to the 
court? 

A. Well, I am a school that has developed very strongly here in California, 
beginning with the organic insecticides revolution, you might say. At first we 
were very small and forlorn, but our program is burgeoning. Our basic philoso- 
phy is that pest control is essentially an ecological problem, and we have at- 
tempted to develop programs based on the management of pest problems in an 
ecological way, rather than through the use of any particular unilateral tech- 
nique. 

Q. Would you please explain in the name of ecological? 

A. Well, ecology is the science of the relation of animals, you might say, in 
a succinct way — animals to their physical environment. Insect pests are ani- 
mals and they have a rather complex environment in which they live. Their 
population is regulated, of course, by the physical and biotic mortality factors 
in the environment. And what we do in growing crops, attempting to control 
insects, cultivating, irrigating, harvesting, and all of the manifold things that 
we do in our crop production program, are factors which are ecological — or 
they play a role in the ecology of these pests and the creatures that feed upon 
them. 

Q. Would it be fair to use the layman's term "environmental" — ^just over-all 
environment ? 

Page 121 

A. Environment connotes something — the word I am seeking — encompasses, 
you might say. The environment is the thing in which we live. The entity in 
which we live. Ecology is a much more dynamic concept. In other words, we 
are creatures that live in an environment, but we liave our own ecologies. 
Things impinge on us and we impinge on things, and they influence our health, 
vigor, activity, longevity, welfare, and so forth. 

Q. Are you referring to, for example, chains of life? 

A. Well, yes. The food chain concept is very well known in the field of ecol- 
ogy. In essence, we belong to a food chain in that we are the top consumer on 
the pyramid that begins at a very basic level. 

Q. Now, you were explaining again on integrated control, and you're going 
into the philogophy of your department in regards to this. 

A. Pest control is the management or regulation of insect population, and 
we early recognized that to attempt to regulate populations in the true sense 
of that word. The use of unilateral techniques, whether they be chemical, cul- 
tural, biological, physical, would not in themselves bring about, you might say. 



3068 

permanent alleviation or permanent suppression of these populations. And it 
became very clear immediately after the advent of DDT and its successors — ■ 
the other chlorinated hydrocarbons and organic phosphorous materials — there 
was a very disruittive impact of these broadly toxic materials on the general 
eco-system. 

Page ISJ, 

Q. Dr. Van Den Bosch, are you at all familiar ^^^th what is commonly 
known as DDT? 

A. Oh, yes.This is, of course, a very well known material. 

Q. And, to your knowledge, is it still used in Kern County? 

A. Oh, yes. 

Q. Does this — what happens to DDT after it is sprayed? Does it break 
down, as was described earlier, like I'arathion? 

A. No. DDT is a long-residue material. It has a very long "half-life," as 
they call it. I believe something on the order of ten years. It accumulates and 
it moves through the eco-system, and of course, it moves from Kern County, 
probably, to the middle of the Pacific Ocean or to the Antarctica ; but it is, in 
essence, a very mobile material and a very long lasting material. 

Q. There was a testimony this morning by Dr. Milby, that it is possible we 
could be poisoning ourselves with DDT. Do you take issue with that? 

Page 135 

A. No. Obviously we are ingesting it and it is accumulating iu our bodies. 
The moot question is — how bad is this? If this is a poison and it's getting into 
our bodies, in that sense we are poi.soniug ourselves. The great heated debate 
of our era is whether this is actually hurting us or not, and I am not qualified 
to say. All I can .say is that this is a poison and at maximum dosage it can 
kill us, and it is accumulating in our bodies ; but I am not in the position to 
•say what the chronic effect of this material is on the Homo sapiens. 

Q. Dr. van den Bosch, you stated earlier that we were at the top of an eco- 
logical chain. Is that right? 

A. Yes. 

Q. Would that mean that, for instance, DDT could be transferred to us 
through the food we eat? 

A. Well, it is, and it was at one time much more so, but the checks and 
blocks that have been develoi)ed to preclude this occurring have reduced this 
problem very strikingly. I can remember when we first started working with 
DDT. We used it on alfalfa at a pound an acre, and then fed it to our cow 
and this meant it was getting into the milk in very large quantities. We were 
ignorant in those days as we are of things that come along today, and all of 
that stopped ; l)ut right now the actual accumulation of DDT in our tissues is 
not as dramatic, and I think there has been a drop in the levels in the last two 
years, because of regulations on use of this material, and diminished use. 

Page 186 

Q. Do you know how it is used, for instance, on a crop like grapes? 

A. I am not very — I prefer no to— or I can't answer the grape situation. I 
know liow it is used on cotton, which is a sort of a standard field crop situa- 
tion, and I suppo.se it's in general the same pattern. 

Q. Finally, Doctor, are you familiar with Dipterex? 

A. Dipterex. D-i-p-t-e-r-e-x. 

(l What is that? 

A. Well, I believe it is also a phosphate material rather ephemeral in its 
topical residuality. you might say, but — I believe because it's ab.sorbed into the 
plant very (luickly after it's applied. In es.sence, that's what it is. It's a very 
ephemeral, I believe, organo-phosphorous material. 

Q. Do you know of any particular problem that has been faced with this 
pesticide? 

A. Well, for one thing, its effectiveness is breaking down as a control of 
Lygus liere in California. It is one of the materials that we recommend for 
u.se on cotton because it has been rather effective, and it is in the form — in its 
original form — a rather .safe material. However, it does metabolize or break 
down into a product called DDVP, which is about ten times as toxic — a very 
lughly toxic material. Now, this is generally not a problem, but on occa.sion. 
and — I can remember one case in our own experiments where we were work- 



3009 

ing with this material Dipterex, in highly alkaline water on the west side of 
the San Joaquin Valley — that the Dipterex or Dylox converted to DDVP in 
the spray tank, and where we were using it as a selective material on an ex- 
periment, it then turned into a disaster in that it wiped out literally all in- 
sects, good and had, in the experiment ; so there is this possibility that, under 
sometimes rather uncontrollable situations, the original Dipterex may convert 
actually in the spray tank into DDVP before the material is absorbed into the 
plant. 

Page 137 

Q. Finally. Doctor, one last question. Are you familiar with any of your 
staff ever becoming ill from Paration? 

A. Well, at Riverside about twenty years ago, before they understood this 
material, and a number of other things, one of the laboratory technicians died 
from a Parathion poisoning. AVe have not observed symptoms of illness 
amongst our own people ; however, this summer in one of our — in our experi- 
ment here at Rosedale where we were using Parathion at very short intervals^ 
four-day intervals ; four treatments in sequence, and we were aware of this 
problem developing — we had our research assistants routinely checked for 
Cholinesterase levels and quite to our surprise, several of them — I think either 
four or five out of the six — suffered reduced Cholinesterase levels which, of 
course, caused us to immediately withdraw them from sampling. 

They weren't sick, and it was simply the initial indication that the level had 
gone down and we had better get those boys out of there. This disturbed me 
and surprised me that this kind of an exposure was enough to cause a general 
depression as it did amongst about eighty per cent of our assistants. 

Page 138 

Mr. Averbuck. Thank you. I have no further questions. 
The Court. Mr. Jordan, you may cross-examine. 

CROSS-EXAMINATION BY MR. JORDAN 

Q. Is the control of agricultural pests a necessary thing? 

A. Yes, it is. 

Q. Is It essential to the enterprise of agriculture? 

A. I would certainly think so. 

Q. Is there a difference — two schools of thought — about the best way this can 
be accomplished? 

A. I should think so. There may be more than two schools. 

Q. At least — and I only know what I have heard you say, so feel free to 
correct me. 

A. Yes. 

Q. Do you feel the most effective way is through the ecological approach to 
control of the environment? 

A. Well, let me explain this. We don't put on a hundred pounds of ecology 
to the acre to control insects as opposed to four pounds of Toxaphene or some- 
thing of this sort. 

Page Ul 

Q. All right. Did I understand correctly that in the tests — I will withdraw- 
that — that is a part of your school of thought that the eradication or repres- 
sion, I think you said, of the insect pest population, should be done by using 
both the ecological approach and the chemical iiesticides? 

A. Well, I don't think I quite said that. The chemical pest approach is part 
of the ecological approach. We are employing ecological principles and tech- 
niques in managing pest populations. We use insecticides and we prefer to use 
them wherever we can as augmentative temporary suppressants of popula- 
tions that are out of hand, for one reason or another. But the important con- 
cept is that we look at the area we are dealing with, whether it's the cotton 
industry of California or the grape industry, or the walnut industry, or al- 
falfa, as an eco-system ; a complicated, dynamic, very mosaic of species and 
factors, amongst which is the human being ; of water, air, wind, good insects, 
bad insects, .so forth and so on. 

We recognize that if we do anything unilaterally in that environment, we 
are liable to trigger a very disruptive chain of events; and indeed, I can tes- 
tify with absolute confidence, that the unilateral uses of insecticides has engen- 



3070 

dered this kind of development, as you jwinted out the unilateral use of the 
rabbit in Australia engendered a problem there. So, when I talk about the 
ecological approach, I include the use of insecticides, chemicals, microbial, if 
you will, in that over-all philosophical approach. 

Page 142 

Q. Then in the county of Kern, am I not correct, they do use the ecological 
approach to the pest problem in agriculture? 

A. Not widely, no. 

Q. How do you control the pink boUworm ? 

A. Well, in the sense — in that sense, yes, because they have a system of ex- 
clusion, a quarantine system, but the pink boUworm doesn't occur here in 
Kern County. 

Q. Well, translate this system of exclusion. What do they do, actually. 

A. It was a matter of in.spection and quarantine. 

Q. Didn't they introduce anything into the county? 

A. They have the detection traps. They have used the sterile male technique, 
which was not considered even by the experts, or the people involved, as a 
highly critical factor. 

Q. In your ex[)erience — your testing, your reading of the learned publications — 
what is your personal opinion, do you feel is the most effective method of con- 
trolling pink boUworm? 

A. Probably an integrated control program involving — 

Q. Everything. 

A. Yeah. 

Q. Okay. 

A. In the south — in the cotton belt, particularly in Texas, they have relied 
heavily on cultural controls which, in that area have been quite effective. In 
the Imperial Valley, they relied heavily on chemical control this year, and 
ended up with a secondary pest disaster in the form of the cotton Leaf Perfo- 
rator : so what works in one area doesn't work in the other. The cultural pro- 
gram has not worked, but they are working on an integrated control approach 
in the Imperial A'alley at this time. 

Q. And more studies should be made, and continued observations of the at- 
tempts that are made, in reports — 

A. Oh, of course. Tliis is an on-going process. 

Q. Very good, Do you recommend that there be no use of chemical pesticides 
in the State of California? 

A. Of course not. 

Q. Do you recommend in your professional opinion, that it is in the public 
interest to eradicate completely the use of DDT? Completely? 

A. I have taken a stand on DDT in this respect ; I personally no longer rec- 
ommend the use of DDT on cotton in California. This is a personal conviction. 

Page IJfJ 

Q. Air pollution is a similar type of problem, is it not? 

A. In a sense. All of these things come under the — 

Q. Well, air pollution, that we are now learning, has long-range harmful ef- 
fects on humans. Is this not correct? 

A. Yes, and DDT is part of the air pollution problem. It gets into the air. 

Q. And you are also of the opinion, are you not, that air pollution has an 
adverse effect upon the animal population? 

A. According to reports it does on us so 

Q. It does on us? 

A. Yeah. 

Q. Do you have an opinion 

A. It has 

Mr. Averbuck. I fail to .see the relevancy. We are not talking about the air 
killing i)eople, we are talking about pesticides killing people. 

The Court. Objection overruled. 

The Witne.ss. It has been demonstrated that it affects plants. It has quite a 
toxic effect. 

Q. And water pollution? Is this not an area that concerns you as one who is 
interested in the integrated control of environment? 

A. Well, of cour.se. This is one of the reasons why I am interested in inte- 
grated control, because it will bring about a rational and scientific and mini- 



3071 

mized use of these highly pollutant agricultural chemicals that we are dealing 
with. 

Q. You don't recommend, of course, that at present time we — I will with- 
draw that. Are you a competitor of the plaintiff in this action? 

A. No. 

Q. Do you have any type of private practice or private employment? 

A. No. 

Q. You don't consider then that your school necessarily would conflict with 
the pest control operators? 

A. I think it will conflict with the pest control operators, and I think it will 
conflict with the chemical industry, because fundamentally, pest control as it 
is now pacticed in the State of California and in the United States of Amer- 
ica, is essentially not an ecological matter. It is a — it is largely a matter of 
merchandising, and this is a fundamental problem in the whole matter of the 
pesticide problem that we are confronted with today. In essence, we are using 
the wrong kind of materials in the wrong places at the wrong times in exces- 
sive amounts, and engendering problems which increases the use of these mate- 
rials, adds to the pollution problems, adds to the cost of agricultural pest con- 
trol, adds to the — you might say — the concern of the general public, and in 
this essence I belong to a school of entomological research and pest control 
philosophy that is at odds with these people. But this is not an overt attack 
on either the pest control advocators or the agricultural chemical industry. It 
simply happens to be that this is one philosophy based against another. And 
the answer to the situation is — which will prevail. Believe me, having been in 
this situation for twenty years, it's a long, tough fight and it's a long, tough 
fight ahead. 

Q. What exact is your function in the university ? 

A. Well, I teach. I guide the activities of a number of graduate students. In 
other words, I direct their Ph.D. work. 

Q. Do you teach entomology ? 

A. Yeah. 

Q. Do you — you're not at Riverside — you're at Berkeley? 

A. I'm at Berkeley. 

Q. You were at Riverside? 

A. Yes. 

Q. Now, you were at an Experimental Station at Riverside? 

A. Yes. 



Excerpts From Testimony of Joe Sellers, General Manager, Atwood Dusters, 

Bakersfield, Calif. 

The following are excerpts of Joe Sellers, general manager for the Atwood 
Dusters, Bakersfield area. 

PAGES INDICATED BELOW ARE TAKEN FROM REJPORTEK's TRANSCRIPTS 

Page 43 

Q. (By Mr. Wall) Would you state your name, please? 

A. My name is Joe Sellers. 

Q. Where do you live, Mr. Sellers? 

A. 1515 Crestmont, Bakersfield. 

Q. What is your occupation? 
. A. I'm general manager for the Atwood Crop Dusters, Bakersfield area. 

Q. And is Atwood Crop Dusters one of the plaintiffs in this proceeding? 

A. Yes, sir. 

Q. And how long have you been in that capacity with Atwood Crop Dusters? 

A. About twenty -five years. 

Q. Would you describe briefiy what has been your experience in this busi- 
ness in Kern County during the past twenty-five years? 

A. Well, I fiew in Kern County from '39 'til '50, and since that time I have 
served as the general manager for the company. 

Page 44 

Q. Mr. Sellers, I ask you to look at Plaintiff's Exhibit 7 and I ask you — is 
that the form that is used by your company in filing the reports with Mr. 
Morley of the type which are the subject of this proceeding? 

A. It is. 



3072 

Q. I'll ask you some questions, Mr. Sellers, about the different items thereon, 
if you will refer to it. 

First off, does the report contain the date of application? 

A. Yes, it does. Date or data did you say? 

Q. The date. 

A. That top line there is the date the invoice is made out. These are copies 
of the customer's invoices. The date of the actual application is in the column, 
"Date Flown." 

A. It shows the date and the actual time of day, the pounds carried there ot 
each load. 

Q. You have been in the courtroom here during all of this proceeding. Is 
that correct? 

A. Yes, sir. 

Q. You have heard the testimony of the proceeding witnesses with regard to 
the trade secret aspect of various items of information given in these reports. 
Is that correct? 

A. Yes, sir. 

Page 75 

The Court. Mr. Sellers, I believe you were on the stand under cross exami- 
nation by Mr. Averbuck. 

Q. (By Mr. Averbuck) Mr. Sellers, are you a member of the Kern County 
Agricultural Chemical Association? 

A. I'm ex officio and on the executive committee. 

Q. Pardon me? 

A. I am an ex officio and on the executive committee. 

Q. How many members do you have in that? 

A. It varies between forty and fifty. 

Q. And how many applicators — how many people are there in Kern County 
that could be members? 

A. How many are there in Kern County that could be? 

Q. Yes. 

A. It is limited to applicators and chemical distributors and dealers. 

Q. Is there anyone, to your knowledge, doing business as applicators or chem- 
ical distributors who is not included in your organization? 

Page 76 

A. Yes. Mr. Tom Griffin. He is in the ground applicating business. 

Q. I see, but basically all the air applicators are? 

A. Air applicators, dealers and distributors, and representatives of major 
manufacturing people. 

Q. What is purpose of this association? 

A. To exchange information with each other in the matters coming up in the 
application.s — recommendations and application of these materials. 

Q. Do you discuss with each other the things you have learned? 

A. Yes, sometimes. 

Q. For example, do you di.scuss with each other the things you have learned 
about wind movements in Kern County? 

A. No, sir. 

Q. Do you discuss with these people such things as the amount of pesticides 
you use and the dosage? 

A. No, sir. 

Q. You mentioned that you thought it was highly important information 
that you have concerning such things as the weather and dosage and where you 
applied it, did you not? 

A. Yes, sir. 

Q. And, in fact, didn't you state that this information was crucial to make 
certain you could do your job without causing crop damage? 

Page 77 

A. I did with relation to temperatures and materials that are being used. 

Q. And yet you do — and in fact, al.so, it relates to whether or not there are 
houses in the area and wliether tliere are people around. 

A. That would be of major importance. 

Q. Whether there are workers in the fields. Would that be a relevant factor 
al.so? 

A. Yes, sir. 



3073 

Q. And yet you say you do not share this information with your competi- 
tors? 

A. That is right. 

Q. Are you telling us today that you would rather see your competitors do it 
without tlie expertise you have, and make mistakes, just to make a buck? 

A. Yes, sir. We would have less competitors that way. 

Q. No further questions. 

Public Heialth Problems Abe Created by Pesticides 
(By Dr. Irma West, M.D.) 

Pesticides have made a generous contribution to public health by augmenting 
the production of food and fiber and by helping in the control of vector-borne 
diseases. Concurrently, the use of pesticides has resulted in human health and 
environmental contamination problems. The information in this paper is based 
on experience in California, where the leading industry is agriculture, where 
at least 20 percent of the nation's i^esticides are used, and where over 40 per- 
cent of the nation's vegetable crops are grown. 

It is also the state where a substantial number of signatures were collected 
for an initiative, which if it had been successful in reaching the 1964 ballot, 
would have asked voters to consider banning the use of most pesticides in Cal- 
ifornia's agriculture. 

Public health pesticide problems are noted for their technical complexity, 
scientific controversy, and public apprehension and confusion. Such problems 
are somewhat analogous to those arising from the use of certain drugs whose 
unwanted side effects are occasionally the object of widespread concern. The 
difference is that with pesticides, the whole population and its environment is 
involved. Furthermore, the public has been sensitized to the problems of envi- 
ronmental contamination by air pollution and radioactive fallout. 

There is no adequate state surveillance program for detection and study of 
effects of pesticides on human health except for the acute effects experienced 
by employed persons working with pesticides. Unlike air pollution and radioac- 
tive fallout there is also no comprehensive environmental monitoring program 
except for pesticide residues on raw agricultural food products. Therefore only 
examples of some of these problems occuring in California can be selected for 
presentation. 

MORBIDITY 

For California, morbidity from pesticides can be only roughly estimated for 
young children ; described more precisely for workers ; and remains largely un- 
known for the remainder of the population. 

A study of hospital emergency care of children, made by the State of Cali- 
fornia Department of Public Health, indicated that 3,000 California children 
received emergency medical or hospital treatment because of ingestion of pesti- 
cides during 1960. This number was about 10 percent of the total receiving 
emergency care for ingestion of noxious substances. 

Reports describing occupation disease are available through reports of work 
injury required of all physicians in California.* The number of doctors' re- 
ports involving pesticides and other agricultural chemicals have doubled since 
1954, and have ranged from 800 to 1,100 reports annually since 1958. The high- 
est numbers were reported in 1959 and 1963. Most of the reports come from 
agriculture, which has the highest occupational disease rate of any industry in 
California. About one-half of these 800 to 1,100 reports are classified as skin 
disease and about one-third as systemic poisoning. The phosphate ester pesti- 
cides, parathion, phosdrin, and timet, account for most of the poisoning cases. 



•Each physlcan who attends an Injured employee and each employer of such a 
worker is required by Section 6407 of the California Labor Code to file a report with 
the State Department of Industrial Relations when disability lasts beyond the day of 
Injury or requires medical service other than ordinary flrst-ald treatment. By definition, 
work Injury Includes occupational disease. Under an interapency agreement with the 
State Department of Industrial Relations, the California State Department of Public 
Health through its Bureau of Occupational Health, reviews and analyzes these doctor's 
reports (doctors first report of work Injury) which concern occupational disease. Reports 
are received only for the 80% of employed persons in California covered by the Cali- 
fornia Workmen's Compensation Law. Among the 20% excluded are federal employees, 
maritime workers, railroad workers in interstate commerce and self-employed. 



3074 

For the past ten years about one occupational death from pesticides has 
been reported for each 100 reports of occupational poisoning from these chemi- 
cals. For phosphate ester i>esticides the rate has been one death per 2()0 re- 
ported poisoning cases. Data on occupational disease from pesticides and other 
agricultural chemicals are probably imderstated, because reports of occupa- 
tional disease are not received from self-employed agricultural workers, a 
group which comprises about one-third of all agricultural workers. 

In considering the impact of pesticides on the health of workers whose occu- 
pation requires their use, two assumptions were made which later proved to be 
false. The first of these assumptions was that farmers, spray oi>erators and 
their employees were generally prepared by knowledge, training, and equip- 
ment to handle the difficult and responsible task of safe application of hazard- 
ous iiesticides. Unfortunately, it was soon found that employers were often 
either uniformed themselves or reluctant to provide adequate occupatitmal 
safety information becau.se they did not want to alarm workers about hazard. 
Moreover, pesticide salesmen often were reluctant to provide adequate safety 
information about their products. In short, economic incentives did not act in 
the direction of encouraging occupational safety in the application of pesticides. 
It was often less expensive to risk occupational disease than to prevent it. 

The second assumption which proved to be false presumed that all physi- 
cians were prepared to deal with the ca.sualties. Both the realities of pesticide 
application and the casualties resulting therefrom were upon us before pre- 
vention and treatment information was develoi)ed and disseminated. 

Concepts in industrial hygiene and industrial medicine commonly used for 
man.v years in other industries have not been employed nor adapted to the ag- 
ricultural setting. Such commonplace needs as clean drinking water, wash 
water, and .sanitary facilities are rarely available in the fields, and are notably 
deficient in many of the living quarters of farm laborers. Yet, water and soap 
are vital to the prevention of the most serious occupational diseases occurring 
on the farm. 

Since workers who regiilarly formulate and apply agricultural chemicals are 
among the first to be exposed to newly introduced pesticides, their health 
should be the subject of intense and continuous observation. Such observation 
would not only be essential to the well being of the worker but would al.so 
constitute an invaluable mechanism for discovering toxic manifestations whicli 
might have been mis.sed during the course of the animal studies carried out in 
conjunction with the initial evaluation of the pesticide chemical in question. 
Unfortunately there is little if any of this kind of research under way in Cali- 
fornia. 

MORTALITY 

Although the mortality data for 1964 is not completely processed there may 
have been only one pesticide death in 1964. The average of five pesticide fatali- 
ties annually in California during the years 1960-1963 represents a considera- 
l)le improvement over the previous four years, during which time an average 
of fifteen deaths were reported anniially. This improvement can be partially 
accounted for by the reduction in deaths among children from sodium arsenite 
weed-killer which was removed from the home market in 1961 by tlie Depart- 
ment of Agriculture and by a widespread educational program by the Depart- 
ment of Public Health. 

While only about 13 percent of pesticides are sold for use outside of agricul- 
ture, al>out one-half of all deaths from pesticides come from pesticidal 
materials sold for nonagricultural use. These deaths usually occur in young- 
sters following accidental ingestion of pesticides left around the home. 

Tliere has been no improvement in the number of deaths among workers ex- 
po.sed to pesticides. They have averaged about two annually over the past ten 
years. However, the amounts of pesticides applied is believed to have al»out 
doubled if the national figures apply to California. 

The most frequent causes of these pesticide deaths were phosphate ester pes- 
ticides and methyl Itromide. Information coming from the investigation of oc- 
cupational deaths indicate that deaths from pesticides can be mis,'<ed easily if a 
history of exposure is overlooked and appropriate chemicals tests omitted. Con- 
versely, deaths attributed at first to pesticides have occasionally proved on 
more tliorough investigation, to be due to other cau.ses. 

In just one of the 67 counties in Florida, there were eight accidental and 
five suicidal deaths from phosphate ester pesticides in 1963 alone. In that 



3075 

county the county medical examiner had undertalien a special study because it 
had become apparent to him that deaths from pesticides could be and were 
frequently missed. Eight out of the thirteen deaths would have been missed 
had not this special investigation been made. In previous years, two homicides 
involving parathion were detected in the same county because of these special 
investigations. Unless there is a high degree of suspicion and if a cholinester- 
ase test is not performed the true cause of death may not be detected. In Flor- 
ida and in most other states anyone can purchase for a few dollars enough 
parathion to kill several thousand people. 

For many years in California the highly toxic phosphate esters can be ap- 
plied only after a permit is obtained from the county Agricultural Commis- 
sioner. This procedure may account at least partially for the fact that Califor- 
nia apparently reports a much lower proportion of pesticide fatalities than do 
the other states. 

Another measure which has contributed to occupational safety in California 
is the medical supervision requirements covering agricultural workers applying 
the more toxic group of phosphate ester pesticides (parathion. phosdrin. thi- 
met, d-syston, and bidrin). These requirements were included in the Agricul- 
tural Safety Orders in 1961. No worker who has been supervised according to 
these requirements has died or been seriously affected from occupational phos- 
phate ester poisoning. These orders include : advance planning with the doctor 
for prompt and adequate treatment in case of a poisoning emergency ; initial 
and periodic cholinesterase tests for each exposed worker ; and medical observa- 
tions of workers and medical interpretation of cholinesterase tests with appro- 
priate recommendations to employer. 

Here are several examples of deaths from pesticides occurring in California. 

Case 1 

The most recent occupational death from pesticides occurred in 1964 in a 
28-year-old worker who had no record of occupational exposure to pesticides 
until his employment as a sprayer by a licensed agricultiiral pest control oper- 
ator. He began his employment by applying parathion, tepp, and phosdrin 
under the direction of a more experienced sprayer. He attended one safety 
meeting at the company headquarters. His first job alone was assigned after 
three weeks of employment and was at a ranch in the adjoining county where 
he was to apply a mixture of phosdrin, parathion, tde (a mixture of chlori- 
nated hydrocarbons) to lettuce. There is no record of his being placed under 
medical supervision as required by the California Division of Industrial Safe- 
ty's Agricultural Safety Orders. No baseline cholinesterase tests were per- 
formed, nor were the required arrangements made in advance with a physi- 
cian to take care of any poisoning emergency which might arise. 

He began to spray 40 acres of lettuce at the ranch about 9 :30 P.M. He was 
working alone and was last seen alive at midnight by an irrigator who said he 
had then sprayed half of the field. He was expected to complete his job about 
2 A.M. It was a cool, -cloudy, evening and he had no illumination except the 
headlamps of his vehicle. The ground spraying apparatus included a closed 
system for mixing the concentrates. However, the phosdrin was not mixed in 
the enclosed system as was the paration and tde. The phosdrin, a 50 percent 
concentrate, was poured manually from a five-gallon can into a tank on the 
truck and the sprayer had spilled the material on himself in the process. 

The sprayer finished the job, secured his equipment on the truck and drove 
1/4 mile to the main road where he stopped the truck and began to vomit. He 
apparently tumbled out of the truck, landing face down in the ditch at an esti- 
mated time of 2:30 A.M. At 8:00 A.M. he was found by the owner of the 
ranch who described him as possibly still alive frothing at the mouth. He was 
pronounced dead on arrival at the hospital. Red cell, pla.sma, and brain cho- 
linesterase were all close to zero postmortem, confirming the diagnosis of phos- 
phate ester poisoning. 

The area and the equipment pertinent to the incident were investigated. A 
wet spot smelling like the phosdrin formulation was found on the ground 
where the nurse rig, part of the spraying and mixing equipment, had been lo- 
cated. (Phosdrin itself is not odoriferous but this particular formulation was.) 
Three respirators were found in the rig and the torn mate to the glove was 
found where the nurse rig had been. The respirators were of the proper type. 
There was no change of clothes on the rig. There was vomitus in the truck 
cab. It was not clear if any protective device, except possibly the gloves, had 



3076 

been worn. The sprayer was reported to have had adequate water to decon- 
taminate himself in case of a spill but there was no evidence that he had 
made an attempt to do so. Erratic tractor tracks were found in the field. 

This death was entirely preventable. Phosdrin is absorbed through the skin 
and takes an estimated 12 drops of 50 percent concentrate remaining on the 
skin to be fatal to an adult. Pouring such materials is a hazardous operation 
in full daylight and with the most adequate protective clothing. Without help 
and in the dark, decontamination, a .spill on the clothing and skin, such as oc- 
curred here, means certain death. However this worker could have survived if 
there had been someone working with him to help with decontamination and 
obtain prompt and adequate medical care. This death is the second in two 
years in California in which a spray applicator spilled a concentrated phos- 
phate ester pesticide while he was working alone and was later found dead. 
The need for more closed systems for measuring concentrates is abundantly 
apparent, as is the need to heed the basic safety rule "never work alone with 
a hazardous chemical". 

In the circumstances surrounding pesticide poisoning among workers, the op- 
eration of vehicles on the highway by poisoning victims is becoming more a 
problem. In this case the victim and his truck rig were entering a well-traveled 
highway. 

Case 2 

A young sprayer was found dead in the field in the tractor which had been 
pulling his .spray-rig. He had been working alone pouring and mixing para- 
thion concentrate into the spray-rig tank. In the process of mixing the concen- 
trate, the worker contaminated his gloves hands on his trousers as he pulled 
the rig to apply the spray. Parathion was absorbed through the skin of his 
hands and thighs. He began to vomit, an early symptom of parathion ix)ison- 
ing. He could not remove his respirator and he aspirated the vomitus and 
choked. The diagnosis of poisoning was confirmed by postmortem cholinester- 
ase tests. 

Case 3 

A young man came to work as a swamper for a agricultural aircraft oper- 
ator. On the first day, he was put to work steam-cleaning and washing a crop- 
dusting aircraft. It was reported that he was not informed of any hazard nor 
was he given any protective clothing or equipment. His clothing was observed 
to have been thoroughly wet while he was working. In the early afternoon, he 
complained of not feeling well. His employer gave him two atropine pills and 
the .swamper returned to work. Not long afterwards, he was found uncon- 
scious. He was admitted to the hospital and died several hours later. Appar- 
ently, the aircraft he was cleaning had been used to make several applications 
of demeton. The diagnosis of phosphate ester pesticide poisoning was confirmed 
by iiostmortem cholinesterase tests. 

Contamination of the environment occasionally has produced acute human 
pesticide poisoning. A l)ale of blue jeans became contaminated from a leaky 
drum of pho.sdrin concentrate during transit by truck. Because phosdrin is a 
liighly toxic phosphate ester pesticide and can bo absorbed through the skin, 
six boys who wore unwa.shed jeans from this bale eight montlis later were poi- 
soned, two .seriously. This contaminated bale had also been stored in tlie A-enti- 
lation intake area for a large department store for .several months, iiotentially 
exposing the occupants of the entire building although no cases of illness were 
reported. 

In California, during August and September of 1963, an outbreak of illness 
which .sent 94 i)each harvesters to physican was traced to parathion residues 
on the foliage of the orchards in which the affected individuals worked. The 
cause of the outbreak was shown to be related to the amount of parathion 
application and not to an unusually early entry into the orchards l)y the har- 
vesting crews. (By law, there is a waiting i»eriod between pesticide application 
and crop harvesting so that the chemical will have deteriorated to the point 
where residues on the food are within safe limits.) Information obtained re- 
vealed that, although parathion could easily l)e recovered from all elements of 
the orchard environment, it was not i)resent in amounts sufficient to account 
for the observed illness. This incf)nsistency suggested the presence in the spray 
residue of a compound evolved from parathion alteration which was consider- 
ably more toxic than parathion, but identifiable by routine analytical proce- 



3077 

dures only as parathion. Paraoxon was considered a likely suspect and was 
postulated as a prime cause of the outbreak. 

Recently an episode of food poisoning involved about 28 persons, including 
tlie baker, who had eaten donuts made at a local bakery. Eight of the victims 
were hospitalized. An alert physician suspected an anticholinesterase agent. 
Cholinesterase levels of these patients were sufficiently reduced to confirm the 
diagnosis. Donuts and ingredients were analyzed for phosphate ester pesticides 
and found to contain diazinon. A concentrate had been spilled on a corner of 
the sack of donut mix. Pest control operations at the bakery were reported as 
being the most likely source of the diazinon. A full report of the incident is 
not yet available- 

These examples are of immediate, obvious and substantial effects of acute 
and substantial exposure. Present methods of obtaining human health data are 
not usually sufficiently sensitive to pick up whatever delayed or less obvious 
effects may exist. 

Inherent in any discussion relative to toxicology, there must be a clear un- 
derstanding of the concepts of exposure and effect. We have found it most use- 
ful to think of exposui-e as either acute or long-term and to consider effect as 
either immediate or delayed. Thus, when considering the impact of synthetic 
organic pesticides on human health, it becomes apparent that most is known 
about acute exposures which produce delayed effects ; and least is known about 
long-term exposures which produce harmful effects, either immediate or de- 
layed. 

A perplexing situation which seems to qualify as an immediate effect of 
chronic or repeated home environmental exposure has been attracting more at- 
tention. 

Since 1957, 4 and possibly 5, Californians are known to have died from 
aplastic anemia or related blood dyscrasias in which exposure to the chlori- 
nated hydrocarbon pesticide, lindane (hexachlorocyclohexane, gamma isomer), 
has been implicated either directly or circumstantially. In another in.stance the 
patient recovered. None of the deaths is attributed to lindane in mortality sta- 
tistics. The American Medical Association's Council on Dnigs maintains a reg- 
istry on blood dyscrasias and lists 18 reports of major blood dyscrasias in 
which lindane exposure was implicated (Best, 1963). Additional ca.ses have 
been reported and the problem has been discussed in medical literature from 
many countries (Sanchez-Medal et al. 1963) (Editorial, British Medical Jour- 
nal, 1958) (Danopoulos et al. 1953) (Mastromatteo, 1964) (Council on Phar- 
macy and Chemistry 1952 and 1953) (Scott et al. 1959) (Huguley, 1961) (Jed- 
llcka et al. 1958) (Friberg, 1953) (Marchand et al, 1956) (Albahary et al, 
1957 ) . 

A stable or per.sistent chemical such as lindane vaporized into living quar- 
ters whether by a continuously operating dispenser or at intervals by a pest 
control operator, can produce a continuous exposure. The pesticide can recircu- 
late in the dwelling assisted by air currents and heating and ventilating equip- 
ment. The potential for long-term, continuous and sub.stantial exposure by in- 
halation does exi.st and it can, be of a magnitude greater than workers 
handling lindane in industry may experience. 

The two best sources of decades of abimdant human toxicological experience 
with chemicals are found in the fields of pharmacology and industrial medi- 
cine. In both areas of human experience, lists of chemicals have been compiled 
which have been reported to adversely and sometimes permanently damage the 
developing blood cells in the bone marrow (Wintrobe, 1961) (Best, 1963). Ap- 
parently only a small proportion of persons exposed are seriously affected, and 
the degree of exposure is not necessarily related to the extent of damage to 
the bone marrow (Osgood, 1953). In pharmacology it is the antibiotic, chor- 
amphenicol, which has been the best known offender (Schmick et al, 1964) 
(Sharp, 1963). In industry, it has been the solvent, benzol (Vigliani, 1964) 
(Wintrobe, 1961). 

This phenomenon is not predictable by animal experimentation. There are no 
laboratory tests which can prove or disprove a cause and effect relationship In 
the individual case. Only when large numbers of people are involved, such as 
there were with choramplieniacol, have epidemiological studies have been use- 
ful in providing statistical evidence of the association between chemical expo- 
sure and bone marrow damage. 

It is not surprising that as human experience with pe.sticides accumulates 
the problem of bone marrow damage arises here as it has with therapeutic 
drugs and industrial chemicals. In drug^ manufacture and in industry, stringent 
controls have been placed upon chemicals were epidemiological or even circum- 



3078 

stantial evidence indicates that blood dyscrasia hazard may exist. However, 
only recently, after many years of use and many warnings from authoritive 
sources (Council on Pharmacy, 1952 and V,)~hi) (California State Board of 
Health, 1952) have lindane vaporizers for home use become illegal in Califor- 
nia. Even though a cau.se and effect relationship between lindane exposure 
and blood dyscrasis has not been proved, considerable circumstantial evidence 
has been accumulating for many independent sources and it would .seem pru- 
dent to restrict all exiwsures of this chemical until research efforts can be 
mounted to settle the (juestion of its relationship to bone marrow damage. 

In regard to contamintion of the environment in trace amounts, encouraging 
reports are coming in both nationwide and within California in regard to pes- 
ticide residues on ff)ods. A recent report from the State Department of Agri- 
culture concerning random sampling at the market of fresh produce in South- 
ern California states that 45 percent of these foods tested showed no 
pesticides, 52 percent showed a trace (1 PPM or less) and only 9 percent 
rangetl between 1 and 3 PPM. None was above legal tolerances. The pesticide 
most often detected was DUT, with malathion, DDE and lindane in that order, 
l)ut much less freiiuently found than DDT. 

There is no regular monitoring for pesticide in soil, water, air, in wildlife, 
in and around the home, and in nonedible commodities. But they have been 
found in varying amounts in many places on a number of occasions- There is 
considerable interest in establishing standards or limits for pe.sticide residues 
in water, in fish and in game. 

RECOMMENDATIONS OF THE GOVEHINOR'S COMMITTEE OX PESTICIDE REVIEW 

In 1963 the Governor directed a committee representing the University and 
nine state agencies, all with responsibilities regarding pesticides, to study the 
state's current programs, identify shortcomings, and recommend programs 
needed to meet the state's obligations toward its citizens. After a year's study 
a report was made public June, 1964. It is reconnnended reading for persons 
interested in a comprehensive and broad consensus of California's pesticide 
problems. Many recommendations were made. The most urgent concerned ex- 
panded research, programs for human .surveillance and environmental monitor- 
ing, plus .strengthening of pesticide registration with participation of public 
health and other state agencies in addition to agriculture. The committee em- 
phasized that responsibilities for pesticides cut across many state agencies and 
that a permanent pesticide review committee should be established to coordi- 
nate these responsibilities. (The references to this report have l)een deleted but 
one may write to I'FWOC. P.O. Box 130. Delano, Calif, for these names.) 

[Editor's Note: Other articles by Dr. Irma West appear el.sewhere in this 
volume]. 

In THE Superior Court of the State of California in and for the 
County of Kern 



No. 103595 

ATWOOD aviation, inc., a corporation, GARRIOTT crop dusting, CO., INC., A 
CORPORATION, ARVINAIR CROP DUSTERS, ON BEHALF OF THEMSELVES AND ALL 
OTHER MEMBERS OF KERN COUNTY AGRICULTUR.\L CHEMICAL ASSOCIATION, AN UN- 
INfORPORATED ASSOCIATION, PL.MNTIFFS VS. SELDO.X C. MORLEY, IN HIS CAPACITY 
AS AGRICULTURE COMMISSIONER OF THE COUNTY OF KERN, STATE OF CALIFORNIA, 
DEFENDANT, JF:R0ME COHEN, INTERVENGR 



ORDER ON ORDER TO SHOW CAUSE AND DECISION GRANTING 
PRELIMINARY INJUNCTION 

The named plaintiffs hereinabove listed will he referred to as plaintiffs, the 
named defendant will l)e defendant and .Terome Cohen, the intervenor, as inter- 
venor. 

PLEADINGS AND BACKGROUND 

On August 22, 1968 this court, per the Honorable ,T. Kelly Steele, .Judge, 
upon application of the plaintiffs and after the filing of the complaint herein. 



3079 

issued a temporary restraining order in the following language : "It is further 
ordered that pending the hearing and determination of said order to show 
cause the defendant and eacli of his agents, employees and representatives are 
hereby restrained and enjoined from disclosing to anyone any of the informa- 
tion shown or contained in any Pest Control Operator Report prepared by and 
furnished to defendant by plaintiffs, or any of them, excepting witli the ex- 
pressed consent of the person so preparing and furnishing." 

In an entirely separate original proceeding commenced in the Court of Ap- 
peal, Fifth District, (5 Civ. 1043) intervenor sought a peremptory writ of 
mandate to require the defendant commissioner to exhibit the records herein 
involved. The Court of Appeal's concluding paragraph in its order dated No- 
vember 8, 1968, stated : "Exceptional circumstances justifying an original de 
termination of the questions involved by the appellate court not having been 
shown, the writ of mandate is denied, without prejudice, however, to the right 
of petitioner to seek a solution of the questions involved and the enforcement 
of the right, if any, of petitioner in the superior court." 

Thereafter, and on December 16. 1968. intervenor filed a complaint in inter- 
vention in these proceedings wherein intervenor on behalf of himself, his fam- 
ily and his clients, the United Farm Workers Organizing Committee 
(UFWOC), AFL-CIO, and the members thereof, sought to examine the pest 
control operators records on file with the defendant agriculture commissioner 
of Kern County. 

The hearings before this court on January 29, 30, 31 and February 5, 6, and 
27 were hearings on the order to show cause issued on August 22, 1968 upon 
application of the plaintiffs as to why the defendant and "his agents, employ- 
ees and representatives should not be enjoined and restrained during the pen- 
dency of this action from disclosing to anyone any of the information shown 
or contained in any pest control operator reports prepared by and furnished to 
defendant by plaintiffs or any of them except with the express consent of the 
person so preparing and furnishing." 

" Neither the complaint nor the complaint in intervention were at issue at the 
time of the hearings herein. These were not hearings upon the complaint in in- 
tervention nor on the complaint. The hearings were for the purpose of deter- 
mining whether or not a preliminary injunction should issue pending the trial 
of the principal action on the issues made by the complaint and answers there- 
to and the complaint in intervention and the answer thereto. 

MEMORANDUM 

Plaintiffs, as commercial applicators of pesticides are required to be licensed 
and to apply to the defendant commissioner for permits to apply injurious and 
restricted pesticides (Agricultural Code Sec. 11732; Title 3 Administrative 
Code — Agriculture ; Def 's. Ex. B ) . 

Section 11733 of the Agricultural Code requires each registrant to maintain 
a record of each pesticide application in the following language : 

"Sec. 11733. Records. The registrant shall keep and maintain a record of 
each property treated that shows all of the following information : 

(a) Date of treatment. 

(b) Material and dosage used. 

(c) Nimiber of units treated. 

(d) Any other information which the commissioner may require. The regis- 
trant shall report the information to the commissioner or the director when 
and as required." 

The defendant commissioner requires a report entitled "Agricultural Pest 
Control Operators Report — Kern County" (Def. intervenor's Ex. 4 and Pltf's. 
Ex. 1) to be submitted by the tenth of each month for the preceding month's 
operations. As indicated in the exhibit this report contains information relative 
to the operator's name, type of pest control, property owner or lessee, location 
of property, date of treatment, material used and strength, brand of material, 
percentage of active ingredients, dose and total amount used, crop treated, 
acres or units treated, pest treated, velocity and direction of air movement and 
name of pilot or ground rig operator. As a matter of practice, the defendant 
commissioner has accepted the information required in forms other than on 
the form supplied by him. The reports are kept on file with the commissioner 
as part of his office records and hereinafter will be referred to as pecticide re- 
ports. 

36-513 O — 70— pt. 6A 6 



3080 

Enforcement of the agricultural pesticide control law contained in Division G 
of the Agricultural Code is vested in the State Director of Agriculture and 
local county agriculture commissioners. (Agricultural Code Sec. 11501, 11502 
and 11503). 

In August, 1968 intervenor was denied inspection of these reports by defend- 
ant commissioner. According to the defendant, intervenor did not state why he 
wanted the records, indicating he had the right to inspect them and would do 
.so one way or another. Intervenor testified that he felt that as a member of 
the public he had the right to inspect these reports irrespective of the reason. 
The testimony established that the defendant offered to allow and did actually 
allow inspection of the applicators applications for permits to apply material 
and the permits them.selves, and the annual report of the Kern County pest 
control operators for 1967 (Def's. Ex. C). The evidence also e.stablished that 
the defendant will make the information contained on the pesticide reports 
available upon request to the State Department of Agriculture, the Director of 
the State Department of Public Health and to the Division of Industrial 
Safety of the State Department of Indu.strial Relation.s. In the event of 
claimed pesticide injury to an individual, necessary information from such re- 
l)orts for the care and treatment of such individuals so claiming injury will be 
made available to the treating doctor or the county health department. 

Intervenor claims the right to inspect the pesticide reports under the Cali- 
fornia Public Records Act (Chap. 3.5, Section 6250-6260 of the Government 
Code). 

The sections immediately pertinent here are : 

"6250. Legislative findings and declarations. In enacting this chapter, the 
Legislature, mindful of the right of individuals to privacy, finds and declares 
that access to information concerning the conduct of the people's business is a 
fundamental and necessary right of every citizen of this state." 

"6253. Public records open to inspection ; time; 

Regulations governing procedure. Public records are open to inspection at 
times during the oflSce hours of the state or local agency and every citizen has 
a right to inspect any public record, except as hereafter provided. Every 
agency may adopt regulations stating the procedures to be followed when mak- 
ing its records available in accordance with this section." 

"6254. Exemption of particular records. 

Nothing in this chapter shall be construed to require disclosure of records 
that are : 

(d) Trade secrets; 

(e) Geological and geophysical data, plant production data and similar in- 
formation relating to utility systems development, or market or crop reports, 
which are obtained in confidence from any person ; 

(f) Records of complaints to or investigations condiicted by, or records of 
intelligence information or security procedures of, the office of the Attorney 
General and the Department of Ju.stice, and any state or local agency, or any 
such investigatory or security files compiled by any other state or local agency 
for correctional, law enforcement or licensing purposes ; 

(k) Records the disclosure of which is exempted or prohibited pursuant to 
provisions of federal or .state law, including, but not limited to, provisions of 
the Evidence Code relating to privilege." 

"6255. Justification for withholding of records. The agency shall justify 
withholding any record by demonstrating that the record in question is exempt 
under express provisions of this chapter or that on the facts of the particular 
case the public intere.st served by not making the record public clearly out- 
weighs the public interest .served by disclosure of the record." 

Also pertinent to this cause is Evidence Code Sec. 1040. 

"1040. Privilege for official information. 

(a) As used in this .section, "official information" means information ac- 
quired in confidence by a public employee in the course of his duty and not 
open, or officially disclosed, to the public prior to the time the claim or privi- 
lege is made. 

(b) A public entity has a privilege to refuse to disclose official information, 
and to prevent another from disclosing such information, if the privilege is 
claimed by a person authorized by the public entity to do so and : 

(1) Disclosure is forbidden by an act of Congress of the United States or a 
statute of this state ; or 



3081 

(2) Disclosure of the information is against the public interest because 
there is a necessity for preserving the confidentiality of the information that 
outweighs the necessity for disclosure in the interest of justice ; but no privi- 
lege may be claimed under this paragraph if any person authorized to do so 
has consented that the information be disclosed in the proceeding. In determin- 
ing whether disclosure of the information is against the public interest, the in- 
terest of the public entity as a party in the outcome of the proceeding may not 
be considered." 

The legislative committee comment to this section, states, in part : 

"Official information is absolutely privileged if its disclosure is forbidden by 
either a federal or state statute. Other official information is subject to a con- 
ditional privilege : The judge must determine in each instance the consequences 
to the public of disclosure and the consequences to the litigant of nondisclo- 
sure and then decide which outweighs the other. He should, of course, be 
aware that the public has an interest in seeing that justice is done in the par- 
ticular cause as well as an interest in the secrecy of the information." 

Also of importance is Evidence Code Section 1060. 

"1060. Privilege to protect trade secret. If he or his agent or employee 
claims the privilege the owner of a trade secret has a privilege to refuse to 
disclose the secret, and to prevent another from disclosing it, if the allowance 
of the privilege will not tend to conceal fraud or otherwise work injustice." 

Part of the legislative comment reads as follows : 

"Therefore, the privilege exists under this section only if its application will 
not tend to conceal fraud or otherwise work injustice. The limits of the privi- 
lege are necessarily uncertain and will have to be worked out through judicial 
decisions." 

The court is of the opinion that under these sections there is no absolute 
privilege of nondisclosure in this case and that the court is required on the 
facts of the case to weigh the public interest served by not making the records 
public against the public interest served by disclosure of the records. Upon 
weighing of these interests under the totality of facts and circumstances here 
involved, the court has concluded that the records should not be made avail- 
able to intervenor. 

Intervenor alleges in Paragraph XVIII of his complaint : 

"Intervener (sic) JEROME COHEN must inspect said records in order to 
ascertain if the Agricultural (sic) Commissioner's office is doing a satisfactory 
job in protecting his clients and himself and his family ; and in order to prop- 
erly carry out his obligations to his clients in taking preventive steps against 
physical injury due to the u.se of economic poisons." 

The intervenor testified at the hearing that he wanted the information be- 
cause none of the governmental agencies involved can be trusted to perform 
their duty of enforcement of the various regulations and laws pertaining to 
registration, handling and use of pesticides, and that he personally wanted 
more knowledge regarding the use and application of iiesticides and their ef- 
fect in order that appropriate provisions regarding workers protection can be 
made an item of bargaining with growers and included in future contracts, 
that he would contemplate a research program on the effect of agricultural 
chemicals on humans, and would contemplate organizing policing crews from 
the union to prevent workers going into sprayed fields until the expiration of 
the waiting period after application and that he would contemplate injunctive 
proceedings to stop the spraying or use of particular kinds of injurious chemi- 
cals and that the union desires and needs this information in order to estab- 
lish a health and benefit program including a cholinesterase testing program 
for organic phosphates for the benefit of field workers. 

Of course, if, in the process of bargaining with employers — owners — growers, 
intervenor is able to obtain contractual provisions governing the use and appli- 
cation of pesticides for the protection of workers in addition to those required 
by law and regulations, that is a matter of private contract. It is difficult to 
understand, however, how the information in these records would assist in 
such bargaining and further, even assuming that such information could be 
helpful, it does not appear to the court to be a proper function of this court to 
require the opening of the.se records for this purpose. In this connection, it is 
interesting to note that the plaintiffs herein contend that the intervenor's ef- 
fort to organize agricultural workers and the grape strike and boycott having 
been unsuccessful, the intervenor's motive and purpose are not in fact as here- 
inabove stated, but are to use the information acquired to keep alive contro- 



3082 

versy with the growers, to assist in selling unionization to workers and to in- 
voke public sympathy and support and to force unionization not only through 
publicity but by using the information to commence and prosecute groiuuUess 
law suits for alleged pesticide injuries against growers and owners. 

The plaintiffs and the defendant both resist the inspection. One or both take 
the position and the court finds that the information contained in the reports 
has, in fact, been given and received in confidence xuider a long standing and 
statewide policy of county commissioners and the Department of Agricidture. 
Policy Letter No. 1-3 from the State Department of Agriculture to all agricul- 
ture commissioners expres.ses this policy in writing (Pltf's. Ex. 1 — Ex. D at- 
tached thereto). Sections A-5, 6 and of that policy read as follows : 

"A. The following records are considered confidential in accordance with 
provisions of law or because disclosure of their contents would not be in the 
public interest : 

"(5) Lists of persons reporting, and reports made by farmers, stockmen, proc- 
e.ssors, dealers, handlers, and others, to the California Crop Rei>orting Serv- 
ice, as well as tabulated copies of such reports and copies of reports made to 
the Federal Crop Reporting Board at Washington, D.C. (Federal regulations 
require confidentiality.) 

(6) Records, correspondence and lists of names which woidd reveal the con- 
fidential affairs of individual persons or firms, such as the volume of business 
done, the composition or secret formulas of products manufactured, prices paid 
or charged, financial condition, or like items. 

(9) Information obtained under a pledge of confidence." (In this connection 
see also Evidence Code Sec. 1040 heretofore quoted, and Richards v. Superior 
Court, 258 Cah Apf). 2(1 635 ; Citi/ and County of San Francisco 'v. Superior 
Court, 38 Cal. 2d 156, 161-16Jf.) 

In effect, both the Department of Agriculture and the defendant have made 
the determination as a policy matter that the public intere.st is best served by 
maintaining the records in confidence. Such a policy is fully justified including 
the fact that requiring the di.sclosure of this information would seriously ham- 
per the essential cooperation exi.sting between all .segments of the pesticide in- 
dustry and the farmers on the one hand with the commissioner on the other. 

The position is further asserted that these reports are immune from inspec- 
tion under Government Code Section 6254 (d) — Trade Secret, (e) market or 
crop reports, which are obtained in confidence from any person, and (f) inves- 
tigatory files for correction, law enforcement or licensing purposes. 

The court is of the opinion that subdivision (f) of Government Code Sec. 
H254 is inapplicable and that subdivision (e) is of qiiestionable applicability. 
However, the court is of the opinion that the reported information does con- 
tain vital trade .secrets as te.stified to in detail by representatives of the appli- 
cators and manufacturers of pesticides, and that the disclosure of this infor- 
mation would be very damaging to a major industry and the public in Kern 
County, and the nondisclosure thereof will not work any substantial injustice. 
In this connection it is to be noted that an owner — grower applicator — as dis- 
tinguished from a commercial applicator — is not subject to licensing nor to the 
reporting requirements of the law. The inevitable effect of requiring the di.sclo- 
sure of this trade secret information would be a shift from well regulated, li- 
censed, experienced and (jualified commercial applicators to inexperienced, 
unlicensed and le.ss qualified owner — grower applicators, thus exposing workers 
and the public to greater danger of injury as well as resulting in the elimina- 
tion of a large .segment of an important commercial applicator industry in this 
county. The intervenor has, in effect, conceded that such a shift would take 
place. (Pltf's. Ex. 0). 

There is no di.spute that many commonly used pesticides — particularly the 
organic phosphates and chlorinated hy(lrocari>on.s — are highly toxic and can 
constitute a hazard to human health and welfare, including death, if not j)roi>- 
erly regulated and used, and there is no dispute that continuing research re- 
garding the labeling, registering, testing, us<> and application of these pesti- 
cides should be conducted and rules and regulations for protection of workers 
and the public slumld be a matter of continuing study and revision. The evi- 
dence estal)li.shed that .such research has been and continues to be coTiducted 
by appropriate agencies at an accelerated rate. While the ecological approach 
to the control of agricultural pests is an important one and should be pursued 
with vigor, it is equally obvious that this approach has not reached the point 
at this time where it can replace the use of agricultural chemicals. The impor- 



3083 

tance of the agricultural chemical industry to this valley and this state is 
enormoiis, not only in terms of the employment and income which it generates, 
but in terms of the astronomical increase in productivity and improvement in 
quality of food and fiber that has accompanied widespread use of agricultural 
chemicals. 

The court is of the opinion that research and the enactment and enforce- 
ment of regulations pertaining to pesticides is a proper function of appropriate 
governmental agencies and if the current regulations are not adequate then 
the proper place to go is to the legislature or to the governmental department 
involved for appropriate changes. It is significant that intervenor has not re- 
quested to appear, nor has he actually appeared at hearings for changes in 
regulations including hearings on proposed changes recently held by the De- 
partment of Agriculture. 

For example, if there is a danger to agriculture workers from exposure to 
residue and by reason thereof a testing program — such as the cholinesterase 
test for handlers of organic phosphates — is indicated, then the regulations 
should require such tests as they do in the case of handlers. The same obser- 
vation can be made with respect to owner — applicators being brought under 
the provisions of the regulations, or with respect to waiting periods, residue 
tests, etc. This would assure protection of all agriculture workers whether 
they belong to the union or not. In this connection the court is not unmindful 
of the very few agriculture workers who are members of UFWOC. AFL-CIO, 
as compared to the total number who may have some exposure to injury. 

There are now very extensive and comprehensive regulations dealing with 
pesticides including those relating to residue waiting periods, registration and 
labeling of products, personal safety, first aid treatment, storage, etc. (see 
Pltf's. Ex. 11 entitled Pesticide Information and Safety Manual : Def's. Ex. F 
entitled Injurious Materials Safety Requirements based on the Safety Orders 
of the Division of Industrial Safety from the Department of State Industrial 
Relations ; and Pltf's. Ex. 3 entitled Agriculture and Administrative Code Reg- 
ulations). 

These regulations were enacted or promulgated after being coordinated with 
all interested departments of government, organizations and individiials (see 
testimony of J. Blair Bailey). The evidence indicates that all of this research 
data and information on agricultural chemicals is available to intervenor or 
other interested organizations. The evidence also shows that intervenor, nor 
those intervenor represents, have not requested such information from these 
authoritative sources. 

The provisions of some of these regulations and others are of particular in- 
terest including the following : 

Pltf's. Ex. 11, California Administrative Code, Title 3, Chapter 4, Section 
2462: 

"2462. Time and Conditions for Use. No injurious material or restricted ma- 
terial shall be used in pest control or other agricultural operations in any area 
of this State in violation of any of the following conditions : 

(a) No injurious material or restricted material shall be applied under any 
circumstances or in any location where damage, illness or injury appears 
likely to result, through direct application, drift or residue, to persons, animals 
(including honeybees) or crops other then the pest or vegetation which the 
material is intended to destroy ; 

(b) Application of injurious materials and restricted materials shall be sub- 
stantially confined to the property to be treated, and no injurious materials or 
restricted materials shall be discharged onto any property without the consent 
of the owner or person in possession thereof : 

(e) After any i>est control material containing parathion, methyl parathion, 
or O-ethyl 0-paranitrophenyl thionobenzenephosphonate (EPN) is applied at a 
rate greater than one pound of actual parathion, methyl parathion, or O-ethyl 
O-paranitrophenyl thionobenzenephosphonate (EPN) singly or in combination, 
per acre, the treated property shall be kept posted by the person who author- 
ized the application for two weeks in such manner as to provide adequate 
warning to persons who enter the property by the point or points of normal 
entry. The warning notice that is posted shall be of such size that it is reada- 
ble at a distance of 25 feet and be substantially as follows: WARNING DO 
NOT ENTER This proi)erty treated with (Parathion) (Methyl Parathion) 
(EPN) on . . . (date) and all persons are warned to stay out for two weeks; 



3084 

(f) Before any employee engages in handling or applying injurious mate- 
rials or restricted materials or is required to work in areas where residues of 
such materials remain in injurious amounts, he shall be informed by his em- 
ployer of the precautions recommended by the manufacturer and by all appro- 
priate industrial safety orders ; and shall be provided with adequate protective 
devices as specified in such recommendations." 

Also, California Safety Orders issued by the Department of Industrial Rela- 
tions, Division of Industrial Safety, Safety Orders 3298 and 3298.2 (Def's. Ex. 
F) which read as follows : 

"3298. Application. The Orders in this article shall apply to employment and 
places of employment involved in the growing and harvesting of farm crops 
and agricultural services." 

"3298.2. Conwiunications. Employers employing persons who do not speak the 
English language shall provide adequate means of communication so that in- 
.structions can be given effectively." 

General Indu.strial Safety Orders 4146 and 4206 require : 

"Employers shall instruct employees who may exposed to injurious mate- 
rials of the hazards they may encounter and the methods of protecting them- 
selves against injury by such substances." 

Other safety orders and provisions as indicated by Ex. F require many 
safety practices. 

Agricultural Code Section 11761 provides : 

"11761. Verified report; duty to file; time. Any person that .suffers any loss 
or damage as a result of the use or application by others of any pesticide, or 
of any substance, method, or device for pesticidal purposes ; or for the purpose 
of preventing, destroying, repelling, metigating, or correcting any disorder of 
plants; or for the purpose of inhibiting, regulating, stimulating, or otherwise 
altering plant growth by direct application to plants shall, within 60 days 
from the time that the occurrence of such loss or damage, or some are of the 
loss or damage, is alleged to have occurred, a verified report of loss." 

According to the defendant, not a single case of claimed pesticide injury to 
an agriculture worker from pesticide residues has evern been reported to his 
office. It is further indicated that if such an instance had been reported, ap- 
propriate action would have been taken. No member of UFWOC, the inter- 
venor, nor the UFWOC medical clinic has ever requested any information re- 
quired for treatment or care for an alleged pesticide injury to an individual. 

Of the 94 first reports of occupational injury to agriculture workers 
attributable to pesticides and other chemicals (Int's. Ex. 3) during 1967, only 
19 are farm laborers and not a single one is attributable to organic phosphates 
at which a cholinesterase testing program would be aimed. Also, with respect 
to the claimed desire to establish a cholinesterase testing program involving 
organic phosphates, the court notes that while the demand for the subjects rec- 
ords was made in Augu.st. 1968, no incpiiry of a testing laboratory to set up 
such a program was made until November. 1968, and there have been no fur- 
ther efforts to set up such a program as of the date of the hearing. 



It is ordered that the defendant, C. Seldon Morley, in his capacity as Agri- 
culture Commissioner of the County of Kern, State of California, and his 
agents and employees and repre.sentative be, and they liereby are enjoined and 
re.strained during the pendency of this action from disclosing to the intervenor, 
to the United Farm Workers Organizing Committee, AFL-CIO, or any repre- 
sentatives thereof, or to the persons or organizations represented by the inter- 
venor herein, any of the information shown or contained in any pest oi>erators' 
reports or documents received in lieu of such formal report furnished to the 
said defendant bv the plaintiffs or any of them. 

Dated, March 27, 1969. 

George A. Brown, 
Judge of the Superior Court. 

[From the Los Angeles Times, Apr. 15, 1969] 

Suits Ask Ban on DDT in California, Crop Confiscation 

(By George Getze) 

Two suits to ban the use of DDT in California were filed Monday in the 
U.S. District Court here and the Superior Court in Sacramento. 



3085 

David Averbuck, assistant general counsel for the United Farm Workers Or- 
ganizing Committee, announced the filings at a press conference at AFL-CIO 
headquarters. 

He said the suits also ask confiscation of all crops in California that have 
been sprayed with DDT, which, according to Averbuck, has been shown to 
have long lasting detrimental effects on the health of animals and which is af- 
fecting the human environment itself. 

Plaintiff in the suits is Vicente Ponce, 34, a Coachella grape picker repre- 
sented by Averbuck. The attorney said Ponce and other grape pickers have been 
sprayed with DDT from airplanes and ground rigs while working in the fields. 

REFUSE TO DISCUSS PROBLEM 

"The growers and sprayers have refused even to discuss the problem of the 
use of DDT and other economic poisons," Averbuck said. 

"They haven't answered out letters, even though the UFWOC has agreed to 
divorce the subject utterly from its fight for union recognition and collective 
bargaining," he said. 

He said that when the suits come up in court the UFWOC will present biol- 
ogists and other scientists as expert witnesses as well as farmworkers who 
have been injured or made sick by the pesticide. 

"Growers are using DDT in reckless disregard of its effects on human life 
and the environment," Averbuck said. He said that 70,000 pounds of the pesti- 
cide are used each year in Riverside County alone. 

"We don't think the growers are using DDT to kill farmworkers, but on the 
other hand, we don't think they're using it innocently, either," he said. 

"They're using it to make a buck." 

Averbuck said that other poisons that break down after a few weeks are 
available. DDT, on the other hand, lasts for years and perhaps forever, and is 
being found in fish and birds in all parts of the world, even in places like Ant- 
arctica far from any fields where it is sprayed. 

"Wliat the long-term effects on life and the earth may be, nobody knows 
yet," Averbuck said. "Some medical scientists believe that DDT increases the 
incidence rate of cancer and other diseases." 

The attorney agreed that some scientists doubt that DDT is harmful to man. 

"But the farm workers don't want to be the guinea pigs in the process of 
finding out which scientists are right." he said. 

According to Averbuck, "wise growers" have already stopped using DDT, 
and similar suits to Ponce's have been filed in Michigan and New York. In Ar- 
izona, where influential cattlemen protested the presence of DDT in the ani- 
mals they sold for beef, the state legislature has ordered a year's moratorium 
in the use of DDT. 

Two weeks ago Sen. Gaylord Nelson (D.-Wis. ) called for a nationwide ban 
on the use of the pesticide. 

Averbuck said that although the suits ask that all DDT stores in the 
state be seized and quarantined, and that all crops that have been sprayed be 
confiscated, it would not mean financial disaster for the state's agriculture. 

"If it is done at the beginning of a growing season, before the crops have 
been repeatedly sprayed, a shift can be made to other poisons, ones that are 
not so long lasting," he said. 

[From the Los Angeles Times, Apr. 17, 1969] 
Needed : Pesticide Control Review 

Issue : There is worldwide concern over the use of DDT in crop control. 
Shouldn't California review its rules and regulations? 

Legal actions to ban the use of DDT in California have been filed in U.S. 
District Court here and in Superior Court in Sacramento. 

Confiscation of all crops sprayed with the controversial chemical pesticide 
also is sought in the twin suits brought by the United Farm Workers Organiz- 
ing Committee. 

The court actions are a by-product of a so far unsuccessful union effort to 
inspect county records of chemical insecticides used in Kern and Riverside 
Counties. 



3086 

The union charges that farmworkers have been poisoned and inspection of 
the records is necessary for their proper medical treatment. 

Kern County Superior Judge George Brown has ruled, however, that the 
chemical mixtures and application methods are trade secrets and not open pub- 
lic records. 

This is the stance long held by the chemical firms and pesticide applicators. 
And Kern County farmers accuse the union of raising the issue to promote its 
organizing campaign. 

Without entering into the union-grower dispute, we believe the controversy 
outlines an area of great concern : a worldwide uneasiness over the use of pes- 
ticides. 

Sweden has banned DDT for two years to discover if prohibition will reduce 
the amount finding its way into plants and animals. Arizona lias instituted a 
one-year moratorium and a U.S. senator has called for a nationwide ban. 

There is a large segment of the scientific community which contends insolu- 
ble DDT and certain other pesticides constitute a danger to man's very exist- 
ence. 

By the same token, other scientists and agronomists argue that pesticides 
are vital to food production. 

California, the No. 1 agricultural state, is a leading user of pesticides. This 
is valid reason, we believe, for a complete and unemotional review of the prob- 
lem. It is up to the Legislature and state health authorities to take the lead. 

If the new rules and regulations are required, they should be considered and 
applied. While the health of the farm workers is of immediate concern, so is 
that of every child, woman and man. 



Scientists Ask Ban on Dangerous Chemical, Warning . . . 

ALL LIFE on EARTH IS THREATENED 

(By Charles Golden) 

A poisonous chemical covers the earth. It invades the tissues of every ani- 
mal and human being, attacking the central nervous system, the intricate proc- 
ess (if the ))ody's chemistry, and even the sexual identify of the human race. 

It falls with every drop of rain and every flake of snow, contamiTiates every 
lake and every river. 

It threatens fi.sh, birds, and other wildlife with extinction. 

It is impossible to eradicate, and its toxic influence lingers for decades. 

And more of it is being [ivunped each day into the air we breathe and the 
water we drink. 

Science fiction? Some bloodcurdling tale from Edgar Allan PoeV 

Unfortunately, no. This horror story is true, a prominent U.S. biologist 
warns. It is the disastrous story of the pesticide DDT, of how we have pol- 
luted our entire environment with it over the past 25 year.s — and bow we are 
heedlessly continuing to spread this pollution. 

"Everyone dismissed as over-emotional all the little old ladies who said that 
DDT was killing birds." .said Dr. Charles F. Wurster Jr., 38, who is professor 
of biology at the State I'niversity of New York. 

"But the little old ladies were right. 

"Actually, the real situation is worse than the emotional people first 
thought. It's a real horror story. 

"The most dangerous myth about DDT is that it can l)e used safely if peo 
pie only follow the directions on the label. 

"But it is impossible to use DDT safety. It is luicontrollalile. The only an- 
swer is to outlaw it." 

Dr. Wurster has set (mt to do exactly that. He is chairman of the Scientists 
Advisory Committee of tlie Environmental Defense Fund, a Long Island-based 
organization which has filed .suits in thi-ee states to prevent tlie u.se of DDT. 

In January, Dr. Wurster joined other biologists from across the country at a 
hearing called by the Wisconsin State Department of Natural Resources to de- 
bate a statewide ban on the use of DDT. 

He testified at the hearing in Madison, Wis., that pollution by DDT has 
reached the level of "great worldwide damage." 



3087 

Continued agricultural use of the potent pesticide, he warned, could cause 
"one of the worst environmental disasters ever perpetrated by man upon the 
life of this planet." 

The Wisconsin debate, between conservation-minded scientists on one side 
and large chemical conerns on the other, has become the national battleground 
in the war against DDT pollution. 

And the stakes are exceptionally high. 

Since DDT came into widespread use immediately after World War II, sci- 
entists say, it has killed billions of birds and fish. 

Some wildlife species are facing the immediate threat of extinction as a re- 
sult of DDT poisoning. 

Especially hard hit have been various types of eagles (including the Ameri- 
can bald eagle), ducks, falcons, hawks, trout and salmon. 

Bird populations are being sharply reduced because DDT causes birds to lay 
eggs with abnormally thin sheels. The eggs dry out and the shells break before 
the young can be hatched. 

The chemical causes the breakdown of certain sex hormones in birds. This 
breakdown, in turn. Interferes with calcium metabolism and results in the thin 
eggshells. 

University of Wisconsin ecologist Joseph J. Hickey called DDT a "chemical 
of extinction." 

After the fish and the birds, larger animals— even humans — could be seriously 
affected. 

"You can't separate the danger to human beings from that to wildlife," Dr. 
Wurster emphasized. "Is man safe when wildlife is being poisoned? Isn't it 
likely that something is happening to man as well?" 

Human beings, the scientist noted, have the same type of sex hormones as 
birds. Although there is no proof, he considers it likely that DDT may have 
similar detrimental effects on human sex hormones. 

Long-range damage to human hormone production could, theoretically, result 
in subtle, but devastating changes. 

These could conceivably include, over many years, a feminizing eiTect on 
men, or a tendency to masculinize women. 

Other effects miglit include abnormalities in sexual characteristics, such as 
full-breasted men or bearded women. 

But such grotesque sexual changes are only one possible result of the overall 
metabolic interference bau.sed by DDT. 

Metabolism is controlled by many highly specialized enzymes produced by 
the liver. These enzymes regulate the whole spectrum of body functions. 

Therefore, Dr. Wurster noted, all the intricate w.orkings of the body chemis- 
try could be thrown out of kilter by DDT's poison. 

"No one has the right to say that DDT is safe for humans," Dr. Wurster 
stressed. "The tests that supposedly 'prove' that DDT is safe in man are 10 
years behind the times." 

In the late 1940s, DDT became a popular ingredient in many large-selling in- 
sect sprays which were sold in stores throughout the country. It was found in 
almost every American household. 

But after its dangers to wildlife were widely publicized several years ago, 
most manufacturers quietly remove it from their insecticides. However, it has 
continued to be used in large quantities by farmers fighting crop pests. 

Dr. Wurster charges that DDT manufacturers — which include only about 10 
U.S. firm.s — falsely claim that DDT is the only means of controlling such haz- 
ards as the malaria mosquito, the Dutch elm beetle and other pests. 

The biologist insists that there are, in fact, plenty of safe non-persistent pes- 
ticides readily available, and that DDT manufacturers should be forced to 
switch to the production of these chemicals or get out of the business alto- 
gether. 

One of tlie reasons conservationists favor a total ban on DDT is because it 
is "persistent." In other words, it stays around to contaminate the environ- 
ment for decades. 

It is a neuro-toxin which kills insects by attacking the central nervous sys- 
tem and paralyzing vital organs. 

But it is also toxic to all forms of life, not just the insects it is supposed to 
kill. Dr. Wurster explained. 

It is highly mobile and has spread like a deadly stain over the entire earth. 
Even penguins in the Antarctic have traces of DDT In their bodies. 



3088 

Finally, it dissolves in fats — which means it is stored in living creatures. 

"As far as we can tell, everyone on earth has some of the poison in his tis- 
sues," said Dr. Wurster. 

Scientists in Germany reported finding extensive DDT contamination in milk 
samples and urged that "extensive application of DDT and similar products be 
dispensed with." 

The U.S. Food and Drug Administration recently condemend a (piantity of 
butter in Arizona found to be contaminated with DDT, but allowed the butter 
to be sold to a soap manufacturer. 

And a special investigating committee of the Pennsylvania State Senate has 
reported that DDT and other "persistent pesticides" pose "suflScient hazards" 
to justify outlawing them in the .state's forests and fields. 

In the face of all this damning evidence, scientists say it is absurd to allow 
DDT to remain on the commercial market. 

"The use of DDT is not consistent with modern scientific knowledge," Dr. 
Wurster said. 

"Adequate alternative methods using safe, short-lived chemicals, are avail- 
able for controlling insects." 

Lake Michigan, which covers 22,000 square miles, already has been declared 
"irreparably contaminated" with DDT. 

"We've created a mess," Dr. Wurster said. "Even if we stopi>ed using DDT 
today, it would take many years for the damage we have already done to be 
repaired." 

The Wisconsin hearings will resume sometime this spring, and scientists all 
over the world will be watching them intently. 

The danger of DDT has become a matter of life and death. But it is still 
not too late to find a happy ending to this horror story which affects every liv- 
ing thing. 

[From the Wall Street Journal, Mar. 4, 1969] 

Wisconsin Hearing on Bid To Ban DDT Could Affect Future of All Such 

Products 

(By Richard D. James) 

Madison, Wis. — The agricultural chemical industry is under attack — again. 

Ever since 1962, it has led a somewhat harried existence. That was the year 
the late Rachel Carson's best .seller, "Silent Spring," appeared, alleging wide- 
spread, indiscriminate use of pesticides produced by the industry. Xow. as 
before, the i.ssue is pesticides, this time specifically l,l,l-trichloro-2,2-bis 
(p-chlorophenyl) ethane — better known as DDT. 

The battle is being waged on .several fronts. Last summer, Illinois, Wiscon- 
sin, Michigan and Indiana signed an agreement calling for .stricter controls on 
all pesticides, DDT included, that are polluting Lake Michigan. The Illinois 
legislature is con.sidering a bill banning the use of DDT. In Penn.sylvania. a 
state senate conmiittee recommended a ban on its iise in fields and forests. 
And Sen. Xel.son (D., Wi.s. ) .says he plans again to .seek legislation outlawing 
the insecticide nationally. "I think it's been clear for a long time to those sci- 
entists who are knowledgeable that DDT is having a devastating environmen- 
tal effect," he says. 

A hearing in WISCONSIN 

The sharpest fight of the campaign, however, is .shaping up here, and its out- 
come could have an important l)earing on the future of DDT and pesticides 
generally. Focal point of the confrontation is a hearing being conducted by the 
Wi.sconsin Department of Natural Resources on a petition to ban the use of 
the chemical in the state. The agency has jurisdiction over keeping the state's 
water resources free of pollution, and under state law it can, upon petition by 
interested parties, restrict or ban the use of any substance it finds to )>e foul- 
ing the water. 

In November, the department was petitioned by a group of Wi.sconsin con- 
•servationists called the Citizens Natural Resources Association. They were 
joined by the Wi.sconsin division of the Izaak Walton League. The two groups 
allege DDT is getting into the water from a variety of sources and is harming 
wildlife. 



3089 

Hearings began in December and continued for 13 days, with about a dozen 
scientists appearing in support of a ban. Then the proceedings were recessed 
to allow the chemical companies time to prepare a defense. They are expected 
to begin presenting their case in a few weeks. 

The case is of more than passing interest. Since "Silent Spring" appeared, 
research has turned up new evidence suggesting DDT may harm wildlife, and 
possibly humans too, in previously unsuspected ways. The hearings mark the 
first time many of the findings have been used as ammunition against pesticide 
makers. If Wisconsin finds the evidence sufficiently persuasive to ban or se- 
verely limit the use of DDT, conservationists and other DDT opponents are 
expected to carry their fight against the industry into other states. 

Moreover, if the campaign against DDT proves successful, the industry ex- 
pects attacks against similar insecticides. Finally, the loser here seems certain 
to appeal to the courts, raising the prospect of a precedent-setting legal deci- 
sion. 

COULD AFFECT LARGER MARKET 

The industry attempts to play down its financial interest in the case. It says 
the DDT used in Wisconsin in 1967 amounted to sales of only $17,000. Even 
nationally, DDT volume isn't huge. In 1967, the largest period for which fig- 
ures are available, sales totaled $13.7 million. However, the larger market that 
the industry believes would be threatend if the DDT issue goes against it to- 
tals about $200 million annually — more than 25% of manufacturers' total pes- 
ticide sales. 

To bolster their attack, the Wisconsin conservationists enlisted the help of 
the Environmental Defense Fund, a small Long Island, N.Y., -based group com- 
prised mainly of scientists that has waged a steady battle against DDT and 
similar insecticides, chiefly in the courts, ever since it was formed in October 
1967. 

It has met only limited success in the courts, but its lawsuits against state 
and local agencies haven't been totally ineffectual. Among other things, the 
pressure the suits have generated as credited with prompting more than 50 
cities in Michigan to stop using DDT against the Dutch elm disease. 

The industry is fighting back through a DDT ta.sk force, organized several 
years ago luider the aegis of the National Agricultural Chemical Association to 
contain the brush fires ignited by DDT's opponents. Most of its members are 
the companies that make DDT : Diamond Shamrock Corp.. Allied Chemical 
Corp., Olin Mathieson Chemical Corp., Lebanon Chemical Corp., a privately 
held company ; and Montrose Chemical Corp. of California, the largest maker. 
Montrose is owned jointly by Chris-Craft Industries Inc. and Stauffer Chemi- 
cal Co. A sixth member, Geigy Chemical Corp., Ardsley, N.Y., doesn't make 
DDT. 

CAUGHT OFF BALANCE 

Thus, the industry is well organized to defend itself, but the Wisconsin at- 
tack .seemingly caught it off balance. The task force didn't retain an attorney 
to represent it at the hearings until less than a week before they opened, and 
it apparently had almost no idea of what it would face in Madison. "Frankly, 
nobody knew what kind of hearing this was," .says Louis A. McLean, the attor- 
ney finally picked by the task force. "We thought it would be something like a 
legislative hearing, where people get up and make statements of position." Mr. 
McLean is a long-time industry spokesman, who until he retired in July 1967 
was secretary and general counsel for Velsicol Chemical Co., pesticide maker 
and Northwest Industries Inc. subsidiary. 

In the past, pesticide manufacturers sometimes have tried to dismiss their 
critics as food faddists and neurotics. For example, in 1967 Mr. McLean 
wrote: ". . . the antipesticide people in almost every instance hold numerous 
beliefs in nutritional quackery and medical quackery, and they oppose public 
health programs." 

The characterization rankles many of the scientists involved here, leading 
some to suggest that the industry this time has underestimated its opposition. 
Indeed, the Environmental Defense Fund and its attorney, Victor J. Yanna- 
cone Jr., have spearheaded the case against DDT with expert testimony from 
reputable scientists brought in from all over the country. 

Included are fishery and wildlife biologists, botanists, an organic chemist, a 
pharmacologist and entomologist. Through its scientists advisory committee, 



3090 

headed by Charles F. Wurster Jr., a biology professor at the State University 
of New York at Stony Brook, the EDF has built up since its inception a pool 
of about 100 scientists to furnish opinions or testimony. Not all EDF witnesses 
are members. 

The EDF contends a complete ban on DDT is needed because even small 
amounts of the pesticide applied in the most rigidly controlled manner will 
still pollute the water and atmosphere. Mr. Wurster testified DDT is easily 
picked up from the soil and carried throughout the world on wind-born dust 
and water particles. Other witnesses testified DDT has been found in nearly 
every part of the world, including dust collected over the Indian and Atlantic 
oceans. It even has been detected in the penguins of Antarctica, they assert. 

The widespread contamination is harming wildlife, not necessarily by killing 
it outright, but by producing subtle metabolic changes, unsuspected luitil re- 
cently, that are gradually eliminating various species, the scientists say. Ken- 
neth Macek, a biologist for the U.S Department of Interior's fish-pesticide lab- 
oratory at Columbia, Mo., reported his research sliows that feeding low, 
.sublethal doses of DDT to brook. trout causes a higher mortality among their 
offsping and makes the trout more susceptible to environmental stresses. 

DROP IN BIRD POPULATION 

University of Wisconsin wildlife ecologist Joseph Hickey testified that since 
1950 there has been a plunge in populations of birds of prey such as the eagle, 
osprey and peregrine falcon. At first, scientists didn't know why, he explained. 
Then in 1967 research showed the birds were laying thinner-shelled eggs that 
were breaking and failing to hatch. Because the change in eggshell thickness 
occurred after 1947, the start of widespread DDT use, the scientists theorized 
that DDT somehow was upsetting the birds' calcium metabolism, which is in- 
volved in eggshell formation. 

Messrs. Hickey, Wurster and others believe the theory now is well docu- 
mented. During the hearings they explained how researchers quite by accident 
found that DDT. even in small amounts, activates certain liver enzymes in 
rats, rabbits and some birds. Enzymes generally control the body's chemical 
functions ; those involved in this instance affect estrogen, a female sex hor- 
mone that plays a role in calcium metabolism. In this subtle way, they argue, 
DDT exacts its toll. 

Additional support came from Lucille Sticel at the Interior Department's Pa- 
tuxent wildlife research center in Maryland. She told how she fed small 
amounts of DDT and DDD, a breakdown product of DDT, to mallard ducks. 
The results were thinner eggshells and increased breakage, she said. 

Although the industry hasn't yet presented its side of the story, talks with 
Mr. McLean and others give some indication as to' what lines it will follow. 
Mr. McLean questions the accuracy of the research studies and the qualifica- 
tions of the scientists who conducted them. 

He contends, for instance, that Mr. Wurster is an organic chemist, "but he 
was talking about things entirely unrelated to the field of chemistry. If a man 
wants his opinions respected, he should be qualified in the specialty in which 
he's speaking, and a scientist who's speaking outside his area of expertise is 
really no l)etter (lualified to foist an opinion than any per.son on the street." 

Mr. McLean indicates the industry will call toxicologists and medical experts 
in its defen.se. "I think it's particularly interesting that although the EDF is 
ba.sically talking about matters of liealth, it didn't bring one medical witness 
to the .stand. And frankly I didn't expect them to, becau.se I don't know of any 
medical toxicologist who's informed about pesticides who shares their fears." 

The EDF argues that there are substitutes for DDT that are as effective l>ut 
much safer becau.se they are shorter-lived and therefore their harmful effects 
don't persist in the atmosphere. 

Tlie industry disagrees. It contends other pesticides aren't as effective, and 
iiecau.se they are shorter-lived, they mu.st be applied more often, increa.sing the 
chances for improi)er and harmful u.se. Beisdes, industry spokesmen say, DDT 
is safe. It must l>e approved by tlie Federal Government, they as.sert, and the 
Governmental agencies involved — the departments of Agriculture and Interior 
and the Food and Drug Administration — wouldn't approve any agent liarmful 
to humans or wildlife. 

The industry backs up its contentions on safety by citing a study of Mon- 
trose Chemical employes at a DDT plant. The study reports the employes are 



3091 

exposed to much higher levels of DDT than is the general public, yet they 
don't show any signs of harmful effects. 

POSSIBLE EFFECTS ON HUMANS 

So far, the issue of DDT's effects on humans hasn't been raised directly in 
the hearings. It was touched on briefly, though, by two witnesses. Richard 
Welch, a pharmacologist with Burroughs AVellcome & Co., a drug manufac- 
turer, said the sex hormones affected in rats by the DDT-activated enzymes 
are the same ones found in man. He also explained that the amount of DDT 
needed to produce the effect "is within a range of DDT found in human fat 

. . thus, if one can extrapolate data from animals to man, then one would say 
that the change in these enzymes probably do occur in man." 

And Robert Risebrough, a biologist with the University of California's Ma- 
rine Resources Institute, touched on the subject briefly in his testimony. "Our 
general point is that (the Food and Drug Administration) hasn't taken any 
consideration of the enzyme inducing capacity of these substances (DDT and 
similar pesticides). This is a decision which the FDA will have to make some- 
time in the near future. Will it permit an increase in the activity of these 
enyzmes in our liver? No responsible person could now get up here and say 
that this constant nibbling away at our steroids (the sex hormones) is without 
any physiological effect. It would be irresponsible." 

Finally, the industry can be expected to hit hard on DDT's public health 
uses and benefits. "Too many people forget we need DDT for control of mos- 
quitoes that carry encephalitis, and the world needs it to control malaria, 
says Mr. McLean. 

Adds Samuel Rotrosen, chairman of the DDT task force and general man- 
ager of Montrose Chemical, "I don't say these people (EDF witnesses) aren't 
true scientists, but their interest appears to be 'let's worry about birds more 
than people.' I think we'll have qualified scientists who will put the picture in 
perspective." 

There's no way, of course, to ell yet how the Wisconsin Natural Resources 
Board will rule. But it may have given some indication of its attitude on the 
DDT question last year in one of its technical bulletins. "The use of any per- 
sistent pesticide (which includes DDT) remains a calculated risk. Science has 
already shown chlorinated hydrocarbon pesticides (the family to which DDT 
belongs) to interfere with fish reproduction, behavior, and hereditary factors. 
Further, these residues may be harming a variety of animal life in many sub- 
tle ways, which will only become apparent through intensive research. To con- 
tinue to use DDT ... in the face of the present level of contamination would 
seem to be an invitation to disaster." 



[From the Los Angeles Times, July 2, 1969] 

Compromise on Banning DDT Agreed to by Senate Group 

(By Jerry Gillam) 

Sacramento. — A compromise bill to outlaw all use of DDT in California 
effective Dec. 31, 1971, was agreed on Tuesday by the Senate Agriculture Com- 
mittee, acting in closed-door executive session. 

The chairman. Sen. Fred. W. Marler (R-Redding), scheduled a public hear- 
ing Thursday to vote on the amended legislation. 

Sen. John A. Nejedly (R-AValnut Creek), author of the measure, agreed to 
the proposed changes, according to Marler. 

Nejedley's original bill would have banned all use of DDT in the state start- 
ing next Jan. 1, but he couldn't muster the five necessary aye votes on the 
nine-member committee to approve this version. 

The amended bill also would give the director of agriculture authority to ex- 
tent the Dec. 31. 1971, cutoff date for one year — if no resonable alternate for 
DDT is developed and ready for use by that time for specific crops. 

Marler noted this would give the pesticide industry a maximum of three 
years to come up with a suitable substitute for DDT. 

DDT, the major pesticide used in the United States, is dangerous to fish and 
wildlife and even humans, according to some scientists, because it doesn't dis- 
sipate easily after use. 



3092 

"All indications are that the amended bill does have the necessary votes to 
get out of committee," Marler said, although he added he wasn't "particularly 
happy" with the compromise version either. 

'•The lead time for a new pesticide can be 5-8 years." he told The Times. 
"And as far as I can tell, there is nothing on the horizon that will replace 
DDT in all of its present uses." 

The Department of Agriculture has recommended a ban on the use ofDDT 
in the home and garden effective Jan. 1. 

This prohibition also would apply to agricultural use of the pesticide in dust 
form, but this accounts for only about 20% of the total farm useage. 

Liquid spray use of DDT would still be permitted under the department's 
proposed regulation. 

Opponents have until July 11 to file their objections, but indications are 
strong that it will be adopted. 

Meanwhile, the department has warned housewives not to try to dispose of 
DDT by flushing it down the sink or toilet into the sewage system or by plac- 
ing it in any body of water. 

[From the Los Angeles Times, June 13, 1969] 

State Will Ban Home Usage of DDT and DDD 

(By Jerry Gillam) 

Sacramento. — The use of DDT and DDD in the home and garden will be 
banned effective Jan. 1, it was announced Thursday by the Department of Ag- 
riculture. 

Also prohibited will be the agricultural use of both in dust form, which ac- 
counts for about 20%. of the farming use of the two pesticides. 

Although the department gave objectors until July 11 to file arguments, it 
left little doubt that its ban would then be made final. 

A department spokesman said the exact number of brand-name housegarden 
bug killers containing DDT, DDD or combinations or compounds is not known, 
"but it's considerable — quite a few do." 

Noting recent public and scientific concern about the effects of DDT and 
DDD, department Director Jerry W. P"ielder said : 

"We know of no reliable evidence that the.se pesticides are directly harmful 
to man, but they do represent a hazard to man's natural environment, includ- 
ing fish and wildlife. 

PROPOSED ACTION EXPLAINED 

"As part of our continuing program to regulate pesticides in the public inter- 
est, therefore, we believe this proposed action is necessary." 

Application of DDT and DDD as farming pesticides by liquid spray would 
be exempt, if a permit is obtained from a country agricultural commissioner. 

Liquid spray accounts for the bulk of farming use of the two pesticides. 

Fielder said the six-month time lag before the effective date will allow for 
orderly disposition of pre.sent stocks of the two pesticides. 

He said many firms and individuals could suffer a severe economic loss if 
the time lag wa.sn't permitted. 

A group of 62 marine scientists last week urged complete prohibition of the 
u.se of DDT in California in an open letter to Gov. Reagan. 

DDT, the major pesticide used in the United States, has been banned in Ari- 
zona, Michigan and Sweden. 

Scientists say DDT is dangerous because it does not dissipate easily after 
use. 

There is a pending bill in the Legislature by Sen. John A. Nejedly (R-Wal- 
)uit Creek) to ban all u.se of DDT in California. 

"What is being done today has nothing to do with Sen. Nejedly's bill," the 
spokesman said. "This has been under consideration for several months." 

SAYS BAN doesn't GO FAR ENOUGH 

Informed of P'ielder's announcement, Nejedly .said the ban didn't go far 
enough in his opinion, and he will continue to push his legislation. 
It is scheduled to be heard June 19 by the Senate Agriculture Committee. 



3093 

The department ban would cancel state registration of manufacturers of the 
two household-type bug killers. This would stop those products from being sold 
in California. 

Violators could be prosecuted in court by the department. 

DDT and DDD are chlorinated hydrocarbons that have been on the depart- 
ment's "injurious materials" list since 1963, meaning they could be used in 
large amounts in farming only by permit. 

The department prevously reported the use of DDT as an agricultural pesti- 
cide has been reduced substantially over the last five years. 

Fielder said the use of DDT and DDD for home and garden purposes isn't 
regulated by permit because this would be "impractical and hard to enforce." 

He also said the ban should not hurt the housewife who wants to kill bugs. 

"There are now available for home and garden use other registered economic 
poisons that will adequately do the same job at reasonable cost," Fielder said. 

The director added the ban of the use of DDT and DDD is dust form on the 
farm would "eliminate a threat to the environment" because of its easy drifting 
ability. 

"This dust is made up of minute particles," he said, "that tend to drift into 
non-target areas and contaminate them." 

Fielder also noted that the University of California has agreed to conduct a 
study to advise which further applications of DDT and DDD should be cur- 
tailed. 

[From the San Francisco Chronicle, Apr. 17, 1969] 
Michigan Acts to Ban DDT Sales 

Michigan, torn by dissention over pesticide control measures, took steps yes- 
terday to outlaw the sale of DDT for farm and other uses and became the 
first- state to ban the increasingly controversial chemical. 

The State Agriculture Commission voted to cancel all registrations for the 
sale of DDT. Hearings would be required, if demanded by contesting interests. 

Michigan, a leading State in which tourism and recreation is an industry 
second only to auto manufacturing, has been shaken by discoveries pointing to 
pesticides as a menace to commercial and sport fishing. 

Last week. Governor William G. Milliken summoned the Governor William 
G. Milliken summoned the Governors of Illinois, Indiana, Wisconsin and Min- 
nesota to an emergency meeting Sunday in Chicago to discuss the problem. 
Milliken may ask neighboring states to follow Michigan's lead in banning DDT 
to increasing perils to fish in Lake Michigan where chemicals used on crops 
are eventually carried by runoff into streams and rivers. 

Increasing concentrations of DDT have turned up in the fat of salmon, white- 
fish, trout and perch and there has been talk of need to close down the State's 
commercial fisheries. 

The State is caught up in a new fishing craze for a variety of salmon called 
the Coho which was introduced into Lake Michigan a few years ago. It has at- 
tracted sportsmen from out of State and created a fever of excitement. 



[From the San Francisco Chronicle, Apr. 17. 1969] 
New U.S. Ban On the Use Of Pesticides 

The Agriculture Department, reflecting a tough new approach to the use of 
pesticides yesterday canceled authority for the use of mixtures containing 
DDT on cabbages and lettuce which are near maturtiy. 

Oflicials said they acted to prevent buildup of dangerous residues. A ban on 
the use of another pesticide, Toxaphene, on near-mature cabbages and lettuce 
was ammounced last month. 

Spokesmen said the ruling on DDT, following the pattern set in the Toxa- 
phene order, will permit the use of the chemical in accordance with label direc- 
tions during early growing stages. 

In the cabbage-lettuce case, oflicials determined that even though the label 
directions would provide consumer protection, a chemical ban was needed be- 
cau.se some producers were failing to follow the directions. 



3094 

[From the San Francisco Chronicle, Apr. 14, 1969] 
Sweden's Ban on DDT 

STOCKHOLM 

Sweden — the first country in the world to ban use of DDT — is accepting the 
role of guinea pig. 

The ban is to last for two years and the first aim is to discover if a na- 
tional prohibition will reduce the amount of DDT finding its way into phints 
and animals. 

The deci-'Jion came after an international conference in Stockholm to discuss 
the dangers of using the chemical. 

It is recognized that since the chemical is so easily spread, a one-nation ban 
is bound to liave a limited effect. Consequently, there is a move afoot to extend 
the measure to the rest of Scandinavia, and demands have already been heard 
in Norway for a total ban on DDT there. 

The Swedish ban is comprehensive covering DDT and all its derivatives in 
every field. Agricultural and domestic uses are specifically mentioned in the 
regulations, so DDT will disappear from all sprays and insecticides used in 
Sweden. 

Although the Swedes promulgated their ban in connection with an interna- 
tional conference to make an impact abroad their information had been gath- 
ered carefully for years. 

Fish, birds and many plants were found to contain rising amounts of DDT, 
and its presence in human beings was distinctly on the increase. "What dis- 
turbed the Swedish authorities most was the fact that no scientist was al>le to 
.say for certain that DDT is harmless in the ca.se of the higher forms of life. 

On the other liand. evidence was presented at the Stockholm conference that 
DDT in remarkably small (luantities could affect human metabolism. Russian 
investigations .showed that certain people habitually working with DDT were 
found to suffer from changes in the liver which slowed down the elimination 
of waste products from the body. 

Some Stockholm scientists who investigated the presence of DDT in wildlife 
along the Swedish coast foinid that it is present in rapidly increasing quanti- 
ties as one moves up the scale of predatory creatures. 

Thus, gulls contain more DDT than the fish upon which they feed, while cer- 
tain types of sea eagles, which prey Upon both, exhibit the highest concentra- 
tion of all. They were foinid to have 25 per cent by weight of DDT in their 
fat tissues. 

It is often argued that DDT affects only lower forms of life, particularly 
the insects it was originally designed to kill. But it has also been shown to 
have poisonous effects of shellfish, and to cau.se thickening of tlie sliells of 
birds' eggs. If the shells become too think the chicks are luiable to hatch. 

At present, there is hardly a part of the globe free of DDT. Eskimos in 
Greenland and seals in the Antarctic have it and .both are far from the near- 
est source. Perhaps the Swedish ban will at least eliminate an annual contri- 
bution of 700 tons. l)ut that is a small amount compared with the 11,000 tons 
u.sed annually by the United States. 

The strongest opposition is exi)ected to come from countries involved in mil- 
iaria control. DDT and its allied components are the chief chemicals used to 
eliminate mosquitoes. 



[From the San Francisco Chronicle, Apr. 17, 1909] 

The Farm Workers' Power Plea 

washington 

Farm labor leaders called yesterday for a law to assist farm workers in 
forming strong unions. 

Spokesmen for the AFL-CIO United Farm Workers Organization Committee 
ojjpo.sed farm lalior union coverage under the National Labor Relations Act un- 
less farm workers are permitted .secondary boycotts and the right to strike. 

The only way to end strikes, boycotts and child labor abuses is through 
strong unionization and signed contracts, Delores Huerta, union vice president. 



3095 

told a Senate labor subcommittee considering collective bargaining for farm 
workers. 

Chairman Harrison A. Williams Jr. (Dem-N.J.) invited the union officials to 
submit draft legislation after hearing their report of what he described as a 
"breakdown of existing law." 

Mr. Huerta and two union attorneys said California has state laws regard- 
ing sanitation and child labor but "all the laws are violated." She said the 
same is true with Federal immigration and anti-discrimination laws. 

Reading from a statement of Cesar E. Chavez — union director unable to ap- 
pear because of illness — Mrs. Huerta said : 

"If farm unionism is to make progress — we need sufficient economic power 
under law to be able to wrench signed agreements from unwilling growers. . . . 
Coverage under the present NLRA would not give us the needed economic 
power — and it would take away what little we have." 



[From the Washington Post, May 27, 1969] 
DDT Peril Seen In Mother's Milk 

Mother's milk is laced with about four times more DDT pesticide than is 
permitted in milk sold to the public, conservationist leader David Brower said 
yesterday. 

"Some wit even suggested that if it were packaged in some other container, 
we wouldn't allow it across state lines," the former executive director of the 
Sierra Club said. 

Brower, testifying before the House Merchant Marine and Fisheries Commit- 
tee, said the average person carries more DDT in his body than is permitted 
in the meat he eats. 

The California conservationist testified in support of legislation to create a 
council on environmental quality. 



[From the New York Times, Jan. 15, 1969] 
DDT Termed Peril to the Sex Organs 

Madison, Wis., Jan. 14 (UPI) — A scientist warned today that the pesticide 
DDT could be seriously affecting man through sex organ changes and by re- 
ducing the effectiveness of drugs. 

Dr. Richard M. Welch, a biochemical pharmacologist at Burrough-Wellcome 
Research Laboratories, Tuckahoe, N.Y., made the statements during testimony 
at a state hearing on a petition to ban DDT in Wisconsin. 

Dr. Welch outlined experiments he had conducted with rats to determine the 
effects of DDT. He said those experiments showed alterations in the sexual 
mechanisms of both male and female rats and also that DDT interfered with 
effects of some commonly used drugs. 

"If one can extrapolate data from animals to man then one can say this 
change in animals probably does occur in man," he said. 

Among the effects of the chemical on rats, he said, were induction of en- 
zymes, body catalysts ; increases in the weight of the female uterus and depo- 
sition of dextrose in the uterus, and stimulation of production on the female 
sex hormome estrogen. 

He said DDT also interfered with drugs used for treatment of disease by 
causing the body to break down the drugs faster than it would normally. 



[From the Los Angeles Times, June 26, 1969] 
Rhine Shows No Trace of Fish-Killing Poison 

one sack of insecticide may have caused deaths in west GERMANY, 

EXPERT SAYS 

Dusseldorf. — The West German section of the Rhine River showed no more 
traces Wednesday of a poison that killed millions of fish, officials reported. A 

36-513 O — 70 — pt. 6A 7 



3096 

Health Ministry water expert said one sack of insecticide may have caused all 
the touble. 

The insecticide reportedly is relatively harmless to humans. 

A spokesman for the North Rhine-Westphalia State Agricultrual Ministry 
said the poison began disappearing from the water late Tuesday. He added 
that fish put into the river showed no effects of poisoning. Earlier, trout had 
died within seven minutes after being put into the water. 

The water expert told a news conference in Bonn : "As far as can be estab- 
lished, the poisoning was caused by about 100 kilograms (220 pounds) of 
Endo Solvan which is al)out a sackful." 

Dutch authorities earlier said they had traced the poison to the German-pro- 
duced in.sjecticide whicli is marketed xnider the trade name of Thiodan. Amster- 
dam has shut off all water from the Rliine, which usually supplies about half 
the city's water needs. 

expert's opinion 

The water expert, who is aiding investigation of the poison, said the insecti- 
cide could have been thrown, dropped or washed accidentally into the already 
heavily polluted river in the wine-growing region around Bingen, where the 
dead fish first were found last week. 

Some West Germany experts theorize that the chemical may have gained 
added lethal qualities by reacting with other industrial chemicals and wastes 
in the river. 

An oflScial of the Rhineland-Palatinate Agriculture Ministry said Tuesday 
the chemical probably was dumped into the river from a ship or barge some- 
where along a picturesque 12-mile stretch of the river between Bingen and St. 
Goarshausen in the heart of the Rhine wine country. 

The North Rhine- Westphalia spokesman said drinking water taken from the 
Rhine for 3.5 million persons in the state had not been endangered by the 
chemical. 

The poison pollution raised an outcry in the West German press. 

Calling the Rhine "Europe's biggest sewer," the Stuttgarter Zeitung com- 
mented that "what has happened to the Rhine today could spread all over by 
tomorrow." 

The Frankfurter Rundschau demanded more federal money to stop pollution. 

There was evidence that the poison was becoming diluted as it flowed down- 
stream. 

Wild ducks were reported to have died in the Koblenz area after drinking 
river water but other ducks were showing no ill effects at Dusseldorf, 60 miles 
downstream to the north. 

In the Netherlands, the Dutch Institute for Purification of Refuse Water 
.said the drifting poison was being blocked near Dordrecht by the currents of 
the incoming sea tide. He hoped the ebbtide would carry it out into the North 
Sea. 

.Tan A''an Veen, manager of the Amsterdam water works, said he has an 
emergency water supply of two to three months, enough to ride out the period 
of poisonous pollution. 

West German Federal Health Minister Kaete Strobel expressed concern that 
drinking water supplies could be affected by the poison. 



[From the Frosno Bee, .Tan. 12. 1960] 
'Wetters Are Big Factor In Spray ^Iixks' 

Bakersfield. — Considerable research has been done on wetting agents in re- 
cent years l)y industry and i)nblic researchers. Tlie differences they have found 
have l)een striking. But the variability in performance of individual wetting 
agents witli different crop chemicals has been even more striking. 

For this rea.'^on, ranchers will see more frequent reference to the use of spe- 
cific wetting agents with specific crop chemicals. In many cases the chemical 
will come formulated with a given wetting agent. 

SELF protection 

Should a grower follow the label suggestion? 

In most ca.ses he should ; one advantage is that if injury to a crop should 
occur then the user has legal recourse against one manufacturer instead of 



3097 

two, reminds Harold Kempen, Kern Country farm adviser. Secondly, he can be 
more assured of a satisfactory result — the object he is seeking. 

However, many different brands of wetting agents are available and often 
they are of lower cost to the user. If adequately tested, certainly these can be 
used, Kempen said. 

Results with wetting agents vary not only with the chemical used but with 
environmental conditions and the proportion used. Obviously the wetting agent 
has completely different physical characteristics at 120 degrees Fahrenheit 
than at 40 or 50 degrees. Likewise it has been shown that these "wetters" (as 
they are called in Australia) may react with an herbicide if used at high con- 
centrations in the water diluent. Thus, adding the wetter to water before or 
after the herbicide, or to a wettable powder slurry, may change the result ob- 
tained. 

While mentioning concentration, one must remember that the percentage of 
active ingredient varies with the brand used. Usually the active ingredient is 
considered to be mainly alkylarylpolyoxyethylene glycols. All labels include 
other compounds to stabilize and enhance the wettability. 

Thus, wetting agents are different and the results obtained with crop chemi- 
cals might be related to the wetting agent used. 



[From the Fresno Bee, Jan. 12, 1969] 
Gr.\pe Growers Get Okay To Use The Sodium Arsenite 

The U.S. Food and Drug Administration has again cleared sodium arsenite 
for use by grape growers to control black measles on Thompson Seedless grape- 
vines. 

Curtis Lynn, Fresno County farm adviser, believes growers will be allowed 
to use the chemical permanently after 1969 because the FDA granted the ex- 
tension as a result of tests being conducted by Dr. William B. Hewitt at the 
University of California at Davis. Hewitt's tests showed no residue of the ar- 
senite is carried into the fruit. 

In the meantime growers must obtain permits from the county agricultural 
commissioner's office both for purchase and use of the chemical. 

Lynn suggests growers noticing 5 or 6 percent of their vines showing the 
symptoms of measles on the fruit last season start their corrective spray pro- 
gram either before pruning or at least four weeks after pruning. 

Fred Jensen, Tulare County farm adviser, warns that "bud damage from 
sodium arsenite is always a possibility. Thompsons are more apt to be injured 
than spur pruned vines. 

"When spraying Thompsons, direct the spray up and down the trunk, then 
keep the spray on the ground between vines. Avoid hitting the canes as much 
as possible. Complete treatment before bud push." 

The UC pest and disease control program for grapes recommends the use of 
three quarts of sodium arsenite per 100 gallons of water. 



Abticle XXV (Proposed) 

The Union agrees that it will submit forthwith a program which will bring 
about an end to our present labor dispute which includes the picketing of our 
properties and the boycott of our product. Upon an acceptable proposal of the 
Union submission to bring about such a cessation of the dispute, any failure of 
an agreed to program by the Union, shall immediately and forthwith result in 
a cancellation of the entire Agreement between the Union and the Employer. 

The Employer agrees that it will abide by any local, state or Federal regula- 
tions regarding pesticides. 

The Union agrees that it will not harass any Employer regarding the use 
of pesticides as long as the Employer agrees to abide by the regulations here- 
tofore referred to. The Union agrees that it will not embark upon any pro- 
gram regarding pesticides that can in any way be detrimental or harmful to 
the Industry in which the Employer belongs. 



3098 

[UFWO Contract Language] 

Consumer and Worker Protection Clause 

preamble 

The Company and the Union recognize the need to supply consumers with 
healthy grai>es picked and handled under the most clean, sanitary and healtli- 
ful conditions possible. Furthermore, the Company and the Union recognize the 
need to conserve our natural resources and to protect all forms of life from 
the serious dangers and damages caused by the improvident use of economic 
poison. In the hope of taking progressive steps to protect the health of farm 
workers and consumers throughout the world and conserving for all of man- 
kind the benefits of our natural resources and surroundings, the Company and 
the Union agree as follows : 

(1) The Health and Safety Committee shall be formed consisting of equal 
numbers of workers' representatives selected by the bargaining unit and Com- 
pany representatives. Members of the Health and Safety Committee shall have 
free access to all records concerning the use of economic poisons. 

The Health and Safety Committee shall participate in the formxUation of 
rules and practices relating to the health and safety of the workers including 
but not limited to the use of garments, materials, tools, and equipment as they 
may affect the health and safety of the workers and sanitation conditions. 

(2) The Company shall not use DDT, Aldrin, Dieldrin and p]ndrin. The 
Company shall not apply other chlorinated hydrocarbons which are dangerous 
to farm workers, consumers and the environment. 

(3) The Company shall not use any organic phosphate pesticides such as but 
not limited to Parathion without flr.st receiving approval from the Health and 
Safety Committee. The Company shall notify the Health and Safety Committee 
as soon as possiitle but at least 72 hours before the application of the organic 
phosphate material. Said notice shall contain the information set forth in part 
4 below : The Health and Safety Committee shall determine the length of time 
(luring which farm workers Avill not be permitted to enter the sprayed field 
following the ai)plication of the organic phosphate pesticide. Any Company 
using organic phosi)hates shall pay for the exi^en.se for all farm workers of 
one ba.seline cholinesterane test and other additional such tests if recom- 
mended by a doctor. The results of all said tests shall be immediately given by 
the Company to the Health and Safety Committee, and, if requested to any 
other authorized union representative. 

(4) The Company shall keep the following records and make them available 
to each member of the Health and Safety Committee and to any other author- 
ized union representative. 

(a) A plan showing the size and location of fields and a list of the crops or 
plants being grown. 

(])) Pesticides and economic poisons used including brand names plus active 
ingredients, registration number on the label, and manufacturer's batch or lot 
number. 

(1) Dates and time applied or to be applied. 

(2) Location of crops or plants treated or to be treated. 

(3) Amount of each application. 

(4) Formula. 

(5) Method of application. 

(6) Person who applied the pesticide, 
(c) Date of harvest. 

SANITATION 

(A) There shall be adequate toilet facilities, separate for men and women, 
in the field, readily accessible to workers, that will be maintained in a clean 
and sanitary manner. These may lie portable facilities and shall be maintained 
at the ratio of one for every 3~> workers. 

(B) Each place where there is work l)eing performed shall be provided with 
suitai>!e, cool, portable drinking water convenient to workers. Individual paper 
drinking cui)s shall I»e provided. 

(C) No worker under this agreement will be required to work when in good 
faith he believes that to do so woidd immediately endanger his health or 
safety. 



3099 

(D) Workers will have (2) relief periods of (15) fifteen minutes which, in- 
sofar as practical, shall be in the middle of each work period. 

TOOLS AND PEOTECTrV'E EQUIPMENT 

(a) Tools and equipment and protective garments necessary to perform the 
work and or to safeguard the health of or to prevent injury to a worker's per- 
son shall be provided, maintained and paid for by the Company. 



GROUND RIG CROP DUSTING; KERN COUNTY, 1968 



Spray 
Crop Pest Material or dust Acres 

Cotton Loopers.._ .- Dibrom_'_ 

Mite, lygus.. Dylox, Kelthane 

Weeds Eptam 

Mite ._ Kelthane , 

Loopers, mite... Kelthane, Malathion... 

Mite Kelthane, Phosphamidon._ 

Weeds MSMA 

Defoliant.- Magnesium chlorate 

Worms, bugs Parathion, Thiodan .' 

Worms, lygus Phosphate _._ 

Weeds... Promytrene 

do Sodium TCA... _-_-.. 

Mite -. Tedion 

_/..do Thimet 

Worms.. Thuricide 

Weeds... Tretlan 

Nutritional Zinc 



Total pesticide spray. 



Grapes Fungicide. Botran, Delnav 

Weeds Amino Triazole, Simazlne 

Fungicide Botran dust 

Rot, nutritional Captan, Leaf Life 

Hopper, mite Captan, Ethion, Thiodan, zinc Sulphur 

Loopers, mite Captan, sulphur, Tedion, Thiodan 

Mite, hoppers. _ Captan, Gibrel, Kelthane, Thiodan Sulphur. 

do Captan, Gibrel, Kelthane, Thiodan 

Mite, growth Captan, Gibrel, Nutraphes, sulphur Zinc 

do Captan, Gibrel, Tedion, Thiodan 

Mite, hopper, rot Kelthane, Captan, Thiodan, Sulphur 

Weeds Cy trol _ 

do Cytrol, Karmex , 

do Cytrol, Simazine 

Mildew Cosan ..." 

Hoppers, mite, nutritional.. Delnav, Delmo Z, sulphur 

do .- Delnav, Gibrel, sulphur 

do Delnav, Gibrel, sulphur, Tedion Thiodan 

do Delnav, Gibre!, sulphur, Thiodan 

Thrip, mite Delnav, Thiodan ' 

Hoppers, mite, nutritional.. Delnav, Nutraphos, sulphur 

do Delnav, Sulphur-. 

do Delnav, Delmo Z, sulphur, ThHodan.. 

Growth - Delmo Z, Gibrel, Urea 

Mite, hoppers.- Delmo Z, Gibrel, sulphur 

Mite nutritional Delmo Z, sulphur, urea 

Mite Diazinon, Trithion 



s 


1,194 


D 


564 


S 


144 


S 


21,943 


S 


230 


S 


3,044 


S 


48 


S 


1,191 


S 


300 


S 


78 


S 


236 


S 


30 


S 


751 


s 


257 


s 


20 


s 


399 


s 


710 




.. 54,229 






s 


15 


s 


1,046 


D 


27 


s 


18 


s 


578 


s 


52 


s 


111 


s 


274 


s 


21 


s 


75 


s 


100 


s 


75 


s 


229 


s 


703 


s 


399 


s 


130 


s 


598 


s 


140 


s 


253 


s 


25 


s 


20 


s 


252 




379 


s 


20 


s 


27 


s 


29 


s 


899 



[From the Seattle Times, July 20, 1969] 
CALIFORNIA Grapes 'Safe,' Says Official 

State Agriculture Director Don Moos has issued a statement that California 
grapes are safe to eat, United Press International reported. 

Moos said the statement was prompted by inquiries received concerning in- 
formation contained in grape boycott literature being distributed near groceries. 

The boycott is in connection with a labor dispute between California table 
grape growers and vineyard workers. 

"We have no reason to have any particular issue with the California labor 
dispute," Moos said. "We're in the business of assuring people as to what is 
wholesome." 



3100 

"The oflBcial tests show that table grapes are remarkably free of chemical 
residues and are perfectly safe to eat," Moos said. 

Senator Mondale. Our next presentation is a panel consisting of 
Mr. C. C Johnson, Chief, Consumer Protection and Environmental 
Health, HEW. accompanied by Dr. Simmons and Dr. Durham. 

Those three witnesses will please come to the witness table. You can 
proceed with your statement in wliatever order you wisli. You may 
introduce the panel, Mr. Johnson. 

STATEMENT OF C. C. JOHNSON. CHIEF, CONSUMER PROTECTION 
AND ENVIRONMENTAL HEALTH, DEPARTMENT OF HEALTH, 
EDUCATION, AND WELFARE; ACCOMPANIED BY DR. SAMUEL 
SIMMONS, DIRECTOR, DIVISION OF COMMUNITY STUDIES, OFFICE 
OF PRODUCT SAFETY, FOOD AND DRUG ADMINISTRATION, 
ATLANTA, GA.; DR. WILLIAM DURHAM, DIRECTOR, PRIMATE 
RESEARCH BRANCH, DIVISION OF PESTICIDES, FOOD AND DRUG 
ADMINISTRATION, PERRINE, FLA. : AND REO DUGGAN, DEPUTY 
ASSOCIATE COMMISSIONER FOR COMPLIANCE, FOOD AND DRUG 
ADMINISTRATION 

Mr. JoHXsox. Thank you, Mr. Chairman. I would like to intro- 
duce my colleagues. 

On my left is Dr. Samuel W. Simmons, Director of our communi- 
ty-studies efforts on pesticides. Immediately on my right is Mr. Reo 
Duggan. He is Deputy Associate Commissioner for Compliance in 
the Federal Food and Drug Administration. On my far right is Dr. 
William F. Durham, and he is Director of our Primate Research 
Laboratory. 

I am the administi-ator of the Consumer Protection and Environ- 
mental Health, Department of Health, Education and Welfare. 

Senator Moxdai.e. Proceed as you wish. 

Mr. JoHxsox. I would like to read my statement, Mr. Chairman. 

At the present time the pesticides programs of the Consumer Pro- 
tection and Environmental Health Service are directed primarily at 
protection of tlie public and of those workers directly involved in 
the manufacture, handling, or application of pesticides through 
spraying or dusting operations. 

The possible liarmful effects to migrant agricultural workers, who 
commonly work at such jobs as thinning, weeding, or picking, have 
not been the subject of specific investigation. I believe, liowever, that 
certain of our findings have at least limited relevance to the situa- 
tion of such workers. And there is no doubt that controls instituted 
primarily to protect pesticide applicators and minimize residues on 
food crops serve, at the same time, to hold down exposures for all 
agricultural workers. 

I am sorry to say that we have ^t this time no scientific data 
which would show, without question, that the margin of safety thus 
provided is adequate in the case of migrant workers. 

Senator INIoxdalk. Pardon me for interrupting there, Mr. John- 
son. Is the scope of your effort directed primarily at protection of 
the consumer, or at the protection of the workers in the field, or just 
the applicators? 



3101 

Mr. Johnson. The scope of our effort, Mr. Chairman, is protec- 
tion of the public health of all people regardless of whether they are 
workers or consumers or laborers in the manufacturing plants. We 
have a total concern for the health and well-being of the American 
public. 

Senator Mondale. At this point you are not satisfied that you 
have the data that proves that there is a margin of safety protecting 
the farm worker? 

Mr. Johnson. I think that the nature of the discussion that en- 
sues as I read the paper will put this into a perspective that we can 
perhaps better understand. 

Senator Mondale. Very well. 

INIr. Johnson. Regulation of the use of pesticides is carried out by 
several agencies. The responsibility for registration of pesticides and 
pest-control materials has been placed in the U.S. Department of 
Agriculture. These products may not be legally shipped in interstate 
commerce without prior registration as required by the Federal In- 
secticide, Fimgicide, and Rodenticide Act. 

When the proposed use of a pesticide will result in residues on a 
feed or food crop, the registration by USDA is not granted until a 
tolerance has been established by the Food and Drug Administra- 
tion. Before registration, the petitioner must present FDA with ex- 
perimental evidence on toxicity to establish what tolerances, if any, 
will be safe and to show that the tolerances can be met under the 
practical conditions of pesticide usage and to specify the conditions 
of use on the labeling for the pesticide. 

The Department of the Interior has programs designed to protect 
fish and wildlife from pesticidal contamination. The Department of 
Transportation regulates shipment of pesticides by interstate car- 
riers. And the Department of Defense has several programs involv- 
ing the use and/or control of pesticides. 

The various States and local governments also have requirements 
aimed at safeguarding the safety of citizens from the hazards of 
[)esticides. 

A memorandum of agreement between the Departments of Agri- 
culture, Interior, and Health, Education, and Welfare was entered 
into in 1964 to coordinate the programs of these departments in pes- 
ticide use and control, pursuant to a report of the President's Sci- 
ence Advisory Committee pointing to the need for closer coordina- 
tion and recommending that responsibility for the health aspects of 
pesticide use be vested in the Department of Health, Education, and 
Welfare. 

The many different synthetic chemical pesticides can be grouped 
into three classes : the chlorinated hydrocarbons, organic phosphates, 
and the carbamates. We have prepared a chart showing representa- 
tive pesticides in each of the three classes and their effects on man, 
including symptoms of poisoning. 

]Mr. Chairman, I would like to submit this chart for the record. 

Senator INIondale. Without objection, it is so ordered. 

(The chart referred to follows:) 



3102 

SYNTHETIC CHEMICAL PESTICIDES AND EFFECTS ON MAN 



Representative members of Signs and symptoms of poisoning 

Pesticide class class in man 



1 Chlorinated hydrocarbons DDT, Aldrin, Chiordane, Dieldrin En- Dizziness, diarrhea, headache, nausea, tremor, 

drin, Heptachlor, Kelthane, Lindane, convulsions and respiratory failure. (The basic 
Toxaphene mode of action for each of these pesticides Is 

not known. It is entirely possible that chlori- 
nated hydrocarbon Insecticides of significantly 
different chemical structure have different 
modes of action; it is certain that there are 
qualitative as well as quantitative differences 
in their pharmoco logical action.) 

2 Organic phosphorus . Parathion, Malthion, Phosdrin Diazi- Headache, giddiness, blurred vision, nausea, 

non, Chlorthion, Dimethorate, Guth- cramps, diarrhea, sweating, tearing, salivation, 
ion, Methylparathion, Phorate vomiting cyanosis, papielledema, uncontrol- 

lable muscle twitches, convulsions, coma, loss 
of reflexes, and loss of sphincter control. (The 
last four signs are seen only in advan:e cases.) 

3. Carbamates _ Carbaryl.... . Constriction of the pupils, salivation, muscular 

incoordination, violent epigastric pain, profuse 
sweating, lassitude and vomiting. These mani- 
festations usually disappear within a few hou rs. 

Source: (Information abstracted from "Clinical Handbook on Economic Poisons," Public Health Service, 1933). 

]Mr. Joiixsox. I believe it would be useful, first of all, to review 
the responsibilities and activities of CPEHS in this area, then to re- 
late these, insofar as possible, to the subject of your inquiry. There 
are a number of other agencies in the Department of HEW whose 
profrrams also relate to the health and welfare of migratory farm 
workers, and we will submit for the record summaries of these pro- 
grams if you wish. 

Senator ]\roxnALE. If you will, please. 

(The documents referred to, subsequently supplied, follow :) 

Summary of Programs Provided by Department of HEW and Consumer 
Protection and Environmental Health Services 

IIE.\LTn services and MENTAL IIELVLTII ADMINISTRATION, COMMUNITY HEAUTH 
SERVICE — MIGRANT HEALTH ACTIVITY 

The Migrant Health Act was devised to help communities and States solve 
migrant health i)rol)lems, including provision of service as people move. Seven 
years of successful operation of the Migrant Health Program have resulted in 
115 grant-assisted projects to provide health services for migrant workers and 
families in one or more local areas of 36 States and Puerto Rico. These proj- 
ects are not demonstrations or pilot activities. Instead, they provide actual 
medical, dental, hospital and related health services. 

In addition to greatly needed remedial care, migrant health projects provide 
immunizations, family planning services, nutrition counseling, prenatal care, 
well child care, and other preventive services. Moreover, project staff members 
work with growers and other community groups to improve housing and envi- 
ronmental conditions, and to develop better understanding and acceptance of 
migrants. Finally, they work with migrants, themselves, to develop understand- 
ing and application of good personal health, homemaking and safety practices 
to prevent as much illness and disability as possible. 

During the past year, migrant workers and family dependents made nearly 
300,000 visits to jdiysicians and 30.000 visits to dentists under project auspices. 
Sixty projects in 2~) States have signed agreements with 162 short-term general 
hospitals to provide care for migrant patients. These projects also intensified 
early case-finding, strengthened medical .services outside the liospital, and 
arranged for .systematic advance planning for the discharge of hospitalized 
patients. 

Statistical outputs in terms of services rendered are reported annually by 
each grant-assisted migrant health project. The following summarizes .selected 
outputs for the past three fiscal years on which data has been compiled. 



3103 



Visits 



Medical care 

Dental care 

Field nursing 

Hospital days. 

Migrant patients: 

Medical 

Dental 

Hospital 



Fiscal year 
1966 


Fiscal year 
1967 


Fiscal yea r 
1968 


165, 000 


176, 000 
23, 000 
144, 000 


190, 000 


18, 000 


25, 000 


100, 000 


150, 000 










20, 000 








94, 000 


100, 000 
17, 000 


110,000 


14, 000 


19, 000 
3,400 









Sanitation inspections 75,000 88,000 100,000 



Per Capita expenditures for personal liealth care for tlie Nation as a whole 
average more than $200 annually. Nationally, the amount per migrant totaled 
only $12 last year, $7.20 from grant funds and $4.80 from other sources. 

For the first time in migrants' long history of neglect, the Migrant Health 
Grant provides a mechanism to bring this needy group higher on the priority 
list of States and communities. The program has demonstrated that the special 
incentive of project grants stimulates community planning and acceptance of 
responsibility. Many of the communities where migrants live and work tempo- 
rarily are themselves below the national average in income. Outside financial 
help continues to be greatly needed. 

CONSUMER PROTECTION AND ENVIRONMENTAL HEALTH SERVICE. ENVIRONMENTAL 
CONTROL ADMINISTRATION MIGRANT HEALTH ACTIVITY 

The Environmental Control Administration of the Consumer Protection and 
Environmental Health Service allocates no resources specifically for migratory 
farm workers as a population group. However, the Bureau of Occupational 
Safety and Health and the Bureau of Community Environmental Management 
do tackle problems which affect migratory farm workers as well as other 
Americans. The Bureau of Occupational Safety and Health is concerned with 
exposures to extremes of temperature, both high and low, skin irritations pro- 
duced by prolonged exposure to the sun's rays, noise exposure from the opera- 
tion of agricultural machinery, and dust and pollen exposure which may cause 
sensitization causing chronic bronchitis or asthma. The Bureau of Community 
Environmental Management attempts to improve health and well-being by pro- 
viding communities with information to modify human behavior and manage 
changes in the residential environment that affect health. These activities con- 
ducted by the Environmental Control Administration do not specifically target 
the migratory farm worker but do have an effect on his well being. 



CONSUMER PROTECTION AND ENVIRONMENTAL HEALTH SERVICE, FOOD AND DRUG 
ADMINISTRATION MIGRANT HEALTH ACTIVITY 

The Division of Pesticide Registration, Office of Product Safety, Food and 
Drug Administration, has the responsibility of advising the Pesticide Regula- 
tion Division of the U.S. Department of Agriculture regarding pesticide regis- 
tration in respect to safety and possible human health hazards. 

In carrying out this responsibility, the Division of Pesticide Registration 
evaluates the toxicological data and labeling on proposed new pesticide prod- 
ucts or the labeling in connection with the re-registration of old products and 
determines if the products can be safely u.sed as labeled. The Division then 
recommends whether or not the products should be registered. 

In an effort to safeguard the health and safety of the migrant farmworker, 
the Division of Pesticide Registration recently notified the Pesticide Regulation 
Division. U.S. Department of Agriculture, that the caution statements on the 
labels of parathion (and other highly toxic chemicals) should be expanded to 



3104 

include a requirement tliat treated fields should be posted with signs specify- 
ing the date after which treated fields may be entered. 



CONSUMER PROTECTION AND ENVIRONMENTAL HEIALTH SERVICE, FOOD AND DRUG 
ADMINISTRATION — MIGRANT HEALTH ACTIVITY 

Essentially all of the research being carried out by the Division of Pesti- 
cides, FDA, provides peripheral information on the potential hazard of pesti- 
cides to migrant workers, insofar as these workers eat food, breathe air, and 
drink water from the common supply shared by the general population of the 
United States. This research involves among the various projects laboratory 
study of experimental animals exposed to known quantities of pesticides, meas- 
urement of exposure of workers to pesticides under actual work conditions, 
clinical evaluation of workers in pesticide manufacturing and formulating 
plants, study of accidental poisoning cases, and projects involving dosing 
human volunteers with pesticides. The accomplishments^ of this research pro- 
gram, together with those of the Division of Community Studies, are summa- 
rized in more than 300 scientific publications. 

However, in addition to these generally applicable studies, the Division of 
Pesticides has also done some work — primarily at the Wenatchee, Washington 
Re.search Laboratory — bearing specifically and directly on the hazard of pesti- 
cides to agricultural workers. We have not, of course, distinguished whether 
the workers under study were migrant or resident in the area. 

Methods for determining exposure of workers have been developed at the 
Wenatchee Station and are being applied in various work situations. Both di- 
rect and indirect methods are being used. The direct methods involve the use 
of some mechanism to trap the toxic material as it comes in contact with the 
workman during his exposure period. Our method uses alpha-cellulose absorb- 
ent pads for skin exposure and impingers or respirator pads for respiratory 
exposure. The indirect methods involve the measurement of some effect of the 
toxicant upon the exposed individual. 

Values for dermal and respiratory exposure and for total exposure in terms 
of fraction of toxic dose have been determined using the direct method for 31 
different work activities involving ten different pesticides. The results are sum- 
marized in Publication No. 212, attached. 

Since migrant agricultural workers generally work at jobs not directly asso- 
ciated with pesticide application, such as thinning, weeding, or picking, their 
exposure levels tend to be in the lower range of those tested. For example, 
workers picking malathion-treated beans sustained less exposure than applica- 
tors who applied the pesticide to the crop. 

In studies involving measurement of blood cholinesterase activity and excre- 
tion level of a metabolite (p-nitrophenol), parathion exposure level of agricul- 
tural crop workers waj? determined. Their exposure was intermediate between 
that of pesticide applicators and residents near orchards. 

Residues on crops have, in a few instances, caused poisoning in agricultural 
workers from occupational exposure. Quinby and Lemmon (1958) reported 11 
episodes of poi.soning from contact with parathion residues involving more 
than 70 persons. This residue poisoning was mild and consisted predominantly 
of gastrointestinal symptoms. The crops involved were i)ears, apples, grapes, 
citrus fruits, and hops. Milby et al. (1964) reported additional outbreaks of 
residue poisoning in peach orchards in California. The sporadic nature of this 
disease is not understood. However, certain weather conditions, including tem- 
perature and rainfall, may play a part in its etiology. 

The results of the research summarized liere indicate that the exposure of 
agricultural crop workers to pesticides is relatively low in comparison with 
formulating plant workers, spray pilots and ground pesticide applicators, and 
otlier personnel having direct exposure to pesticide chemicals. There is no indi- 
cation from the research summarized above or to our knowledge from that re- 
ported by others which indicates that pesticides used according to recommen- 
dations con.stitute a significant health hazard to migrant agricultural crop 
workers. However, continued surveillance and research are needed to assure 
that subtle effects have not been heretofore undetected or have required longer 
time intervals following exposure to develop. Also, continued research is neces- 
sary to obtain for new compounds the kind of data presently available for pes- 
ticides now in use. 



3105 



Reprinted from the Archives of Environmental Health 

April 1967, Volume 14 

Copyright 1967, American Medical Association 



Exposure of Workers to Pesticides 

Homer R. Wolfe, BS; William F. Durham, PhD; 
and John F. Armstrong, BS, Wenatchee, Wash 



In order to evaluate the hazard to the 
health of workers using pesticides, it is im- 
portant to know the amount of exposure 
which workers undergo while carrying out 
various jobs related to the preparation and 
use of these compounds. Both direct and in- 
direct methods are available for measuring 
exposure. The direct methods are those 
which utilize some mechanism to entrap the 
toxic material as it comes in contact with 
the workman or to remove the retained toxi- 
cant at the end of the exposure period. The 
amoimt of toxicant trapped or removed is 
then a direct measure of the particular expo- 
sure being studied. The indirect methods in- 
volve the detection of the pesticide or its me- 
tabolite(s) in body tissue or excreta or the 
measurement of some pharmacologic effect 
of the toxicant on the exposed individual. 

The indirect methods have been quite ex- 
tensively employed in studying exposure of 
workers to pesticides. Thus, the exposure of 
workers to DDT has been estimated on the 
basis of their body fat content of DDT and 
DDEi'2 or of urinary excretion level of the 
metabolite DDA.^* Exposure of subjects 
whose occupations involved use of dieldrin 
has been determined from excretion levels of 
dieldrin-derived material in urine.^ A num- 
ber of surveys of exposure of workers to or- 
ganic phosphorous insecticides using blood 



Submitted for publication Oct 26, 1966; accepted 
Nov 11. 

From the Western Pesticides Research Laborato- 
ry, Office of Pesticides, Ck)mmunicable Disease Cen- 
ter, Public Health Service, US Department of 
Health, Education, and Welfare, Wenatchee, Wash. 

Reprint requests to Western Pesticides Research 
Laboratory, Public Health Service, PO Box 73, 
Wenatchee, Wash 98801 (Dr. Durham). 



cholinesterase activity level as the criterion 
have been reported.^-^^ Exposure to para- 
thion has been estimated from urinary ex- 
cretion of the hydrolytic product p-nitro- 
phenol.'^i* 

The indirect methods for measuring expo- 
sure to pesticides have been less used. The 
first study of this type was apparently car- 
ried out by Batchelor and Walker^^ who 
determined the exposure of orchard spray- 
men to parathion. These investigators used 
a-cellulose pads on the exposed skin area 
and in the respirator to entrap the pesticide 
and, thus, serve as an indicator of contami- 
nation. Later work has followed this general 
procedure although some refinements have 
been introduced. The methodology has been 
reviewed in detail by Durham and Wolfe." 
The published studies of exposiu-e of work- 
ers to pesticides which have been carried out 
using direct methods are summarized in Ta- 
ble 1. 

The present paper reports the results of 
pesticide exposure studies using direct meth- 
ods for a number of agricultural and public 
health vector control work situations. The 
effect of a number of factors on the level of 
exposure has been determined. Factors stud- 
ied include wind, type of activity, method 
and rate of application, duration of expo- 
sure, route of exposure, and attitude of 
workmen. The hazard to workers of various 
activities involving different pesticides is 
evaluated. 

Materials and Methods 

Samples to permit measurement of exposure 
were collected in the field while the workmen 



Arch Environ Health — Vol 14, April 1967 



3106 



were carrj'ing out their usual duties. There 
were 31 different work activities studied, in- 
volving ten different pesticides. Although the 
results for ten of these work activities have 
been partially reported in previous publications 
from this laboratory, they are included here 
along with additioneil recent data to give the 
best available exposure values for these situa- 
tions. 

Estimation of the amounts of pesticide expo- 
sure that workers would potentially incur fol- 
lowed the techniques and procedures described 
in detail by Durham and Wolfe.i" Potential 
dermal contamination was measured primarily 
by attaching absorbent a-cellulose pads for 
spray exposure, or layered gauze pads for dust 
exposure, to various parts of the body or cloth- 
ing of workers and allowing them to become 
contaminated during a timed interval of work. 
Contamination of the hands was measured ci- 
ther by rinsing in a suitable solvent in a poly- 
ethylene bag or by swabbing with solvent-im- 
pregnated gauze swabs. 

Respiratory exposure was estimated from the 
contamination of filter pads held in specied sin- 
gle or double-unit respirators or from air con- 
centration values determined by use of imping- 
er-type air samplers or both. 

The dermal and respiratory exposure pads 
were extracted with a suitable solvent in a 
Soxhlet apparatus. 

Chemical analysis for the various compounds 
was done using the following methods: azin- 
phosmethyl, Meagher et al;i*; Chlorthion, a 
modification (Chemagro Corporation, unpub- 
lished data) of the Averell-Norris procedure;!" 
DDT. a modification by Mattson et al-o of the 
methorl of Schechter et al-i; demeton and 
TEPP, a total phosphorus method--; dieldrin, 
O'Donnell et al23; DNOC (sodium salt of dini- 
tro-o-cresol), Wolfe et aP*; endrin, the paper 
chromatography procedure described by Mitch- 
ell--' malathion, electron-capture gas chroma- 
tography-"; and parathion, Averell-Norris.i^ 

A total of 3,555 analyses of dermal pads and 
333 analyses of respirator pads were carried 
out in the present study. 

Dermal exposure values were calculated on 
the assumption that the exposed person wore a 
short-sleeved, open-necked shirt, no gloves or 
hat, and that his clothing gave complete protec- 
tion of the areas covered. This amount of cloth- 
ing was elected since it represented just about 
the smallest amount of protection which was 
observed in the field. However, some spraymen 
wore additional protective clothing such as a 
hat or cap, long-sleeved shirt, or even a jacket 
or coveralls. It was considered advisable to cad- 



culate potential exposure based on the lesser 
amount of protective clothing so that safety rec- 
ommendations derived from these calculations 
would (end to be on the conservative side. The 
surface areas of the usually unclothed body 
parts (face, back of neck, "V" of chest, fore- 
arms, and hands) were determined using Ber- 
kow's-'^ values for surface area. The total cal- 
culated dermal exposure was the sum of the ex- 
Ijosures of the usually unclothed body parts. 

The respiratory exposure was assumed to be 
equivalent to the contamination of the respira- 
tor pad or pads. Alternatively, air concentra- 
tion values taken as near the breathing zone as 
possible were multiplied by an assumed value 
for lung ventilation rate of 1,740 liters/hr^s 
during the light work involved in spraying to 
obtain respiratory exposure. 

Calculation of the total exposure in terms of 
the percentage of the toxic dose was made by 
the procedure described by Durhsun and 
Wolfe.i^ The calculations were based on com- 
l^arison between the dermal and respiratory ex- 
posure values determined here and values by 
Gaines (unpublished data) for doses toxic to 
the rat.20 

Results and Comment 

The values of dermal and respiratory ex- 
posure and for total exposure in terms of 
fraction of toxic dose per hour of work as de- 
termined in the present study are shown in 
Table 2. 

Factors Affecting Level of Exposure. — 
There were wide ranges in exposure level for 
a given work activity with a specific pesti- 
cide depending on the environmental condi- 
tions, technique of the operator, and, per- 
haps, other factors. These variations ranged 
up to about 200-fold for dermal exposure as- 
sociated with applying parathion to fruit 
trees with an air blast dilute spray machine 
and up to almost 300-fold for respiratory ex- 
posure associated with spraying parathion 
on fruit trees using a concentrate spray ma- 
chine. 

Wind. — The most important environmen- 
tal condition studied with regard to effect on 
exposure was wind. Wind was thought to be 
an important factor in determining the 552 
mg/hr exposure to parathion for an opera- 
tor spraying parathion in a fruit orchard 
with an air blast machine. This level was the 
highest potential dermal exposure deter- 
mined in the present study. This exposure 



Arch Environ Health — Vol 14, April 1967 



3107 



Table 1. — Summary of Published Studies on Potential 
Exposure of Workers to Pesticides Using Direct Methods 



Exposure 



Compound 

Azinphosmethyl 
Azinphosmethyl 

Azinphosmethyl 

Azinphosmethyl 
Azinphosmethyl 
Azinphosmethyl 
Azinphosmethyl 
Azinphosmethyl 
Benzene 

hexachloride 
Benzene 

hexachloride 



Carbaryl 
Carbaryl 
Chlorthion 

DDT 
DDT 
DDT 
DDT 
DDT 
Dieldrin 

Dieldrin 
Dieldrin 



DNOC 
DNOC 
DNOC 
DNOC 

DNOC 

DNOSBP 

Endrin 

Endrin 

Endrin 

Endrin 
Endrin 
Endrin 

Malathion 
IVIalathion 
Malathion 
Malathion 

Malathion 



Activity 

Checl^ing cotton for insect damage 
Air blast spraying fruit orchards 

during night 
Air blast spraying fruit orchards 

during day 
Air blast spraying fruit orchards 
Air blast spraying fruit orchards 
Air blast spraying fruit orchards 
Filling spray tank 
Working in formulating plant 
Spraying forests 

Hand spraying for mosquitoes 



Air blast spraying fruit orchards 
Air blast spraying fruit orchards 
Operating aerosol machine for 

mosquitoes 
Indoor house spraying 
Indoor house spraying 
Outdoor house spraying 
Outdoor house spraying 
Spraying forests 
Hand-spraying of dwellings for 

disease vector control 
Spraying pear orchards 
Operating power air blast machine 

spraying fruit orchards 
Power hand gun spraying fruit 

orchards from portable machine 
Spray-thinning apples 
Spray-thinning apples 
Spray-thinning apples 
Chemical thinning apple blossoms 

by power hand gun spraying 
Chemical thinning apple blossoms 

by powerairblast spray machine 
Herbicide spraying corn and pea 

fields with boom ground sprayers 
Spraying orchard cover crops for 

mouse control 
High pressure power hand gun 

spraying orchard cover crops for 

mouse control 
Operating power air blast or boom 

sprayers treating orchard cover 

crops for mouse control 
Dusting potatoes 
Spraying row crops 
Piloting airplane during air 

application 
Operating aerosol machine 
Air blast spraying fruit orchards 
Air blast spraying fruit orchards 
Persons outdoors during air appli- 
cation to populated area. 
Persons indoors during air appli- 
cation to populated area 



Dermal 
(mg/hr) 



Respiratory Total 

(mg/hr) (% Toxic Dose/hr) Reference 



5.4 


el* 




(0.04)t 


51 


541 


0.47 


6.5 


(3.5)t 


34 


755 


0.54 


8.4 


(4.9)t 


34 


12.5 


0.26 




(0.1) 


30 


9.9 


0.1 


0.15 




46 


27.2 


0.04 


0.18 




This paper 


52.9 


1.27 


0.72 


(0.46)1 


30 


10.1 


0.56 




(0.1) 


30 


(70.3) 


(3.06) 




(0.29) 


52 


(10.2) 


(4.29) 




(0.15) 


Wassermanni 

M. etal, 

unpublished 

data 


25.3 


0.29 


0.03 




33 


24.9 


0.48 


0.02 




46 


(3) 


(0.3) 




(0.003) 


53 


543 






O0.31) 


54 


1.755 


7.1 




(1.02) 


48 


84 






O0.05) 


54 


243 


0.11 




(0.14) 


48 


(212) 


(4.92) 




(0.15) 


52 


(18.6) 






O0.33) 


55 


14.2 


0.25 (0.03)11 


0.24 




56 


15.5 


0.03 


0.25 




This paper 


15.1 


0.03 


0.25 




This paper 


63.2 


0.4 




(0.25) 


47 


57.5 


2.75 


0.20 




34 


24.4 


0.03 




(0.1) 


24 


55.1 


0.13 


0.13 




This paper 


22.5 


<0.05 


0.05 




This paper 


88.7 


0.12 




(0.57) 


24 


2.6 


0.01 


0.21 




56 


3 


0.01 


0.25 




This paper 



2.5 


0.01 


0.21 




Th 


is paper 


18.7 


0.41 


1.5 






56 


0.15 


el 




(o:oi) 




33 


1.18 


0.08 


0.29 


(0.1 6){ 




33 


(6.6) 


(0.3) 




(0.003) 




53 


2.5 


0.08 


0.002 


(O.OOl)t 




33 


30 


0.11 


0.01 




Th 


is paper 


(0.89) 


(0.055) 




(<0.001) 




57 


(0.25) 


(0.012) 




(<0.001) 




57 



Arch Environ Health — Vol 14, April 1967 



3108 



Table 1. — Summary of Published Studies on Potential 
Exposure of Workers to Pesticides Using Direct Methods (Continued) 









Exposure 






Dermal 


Respiratory 


Total 




Compound 


Activity 


(mg/hr) 


(mg/hr) 


(% Toxic Dose/hr) 


Reference 


Methyl Para- 


Checking cotton for insect damage 


0.7 


el 


(0.02) 


51 


thion 












Parathion 


Air blast spraying fruit orchards 


77.7 


0.16 


(5.4) 


16 


Parathion 


Air blast spraying fruit orchards 


2.4 


0.03 


0.43 (0.18); 


33 


Parathion 


Air blast spraying fruit orchards 


19 


0.02 


1.33 


45 


Parathion 


Concentrate air blast spraying fruit 
orchards 


28 


0.06 


1.95 


45 


Parathion 


High pressure power hand gun 
spraying fruit orchards 


55.8 


0.19 


(3.9) 


16 


Parathion 


Hand knapsack mist spraying 
tomato bushes 


9.1 


0.29 


(0.82) 


58 



* el indicates "below the experimental limits of the chemical method." 

t All values shown in parentheses were not included in the original paper but were calculated by the present 
authors. 

; Calculations based on the original authors' published dermal and respiratory exposure data indicated that the 
correct total exposure as a percentage of the toxic dose per hour should be the values shown in parentheses rather 
than the figures originally published. 

S These original values were calculated on the basis of maximum exposure. The recalculated values shown in 
parentheses are based on mean exposure. 

Study of the original data on which the published respiratory value (0.25 mg/hr) was based indicated that this 
figure was derived in error and should have been 0.03 mg/hr. 



indicated that the sprayman was receiving 
37% of the toxic dose per hour of work. 
However, the operator was wearing very 
effective protective clothing and probably 
actually absorbed only a small fraction of 
the estimated potential exposure. 

Type of Activity. — There appeared for 
each given pesticide to be a significant varia- 
tion in hazard depending upon the type of 
activity in which the worker was engaged. In 
the case of DDT, as shown in Tables 1 and 
2, indoor house spraying was about 4 times 
as hazardous as flagging for airplane dusting 
of fruit orchards, approximately 7 times as 
hazardous as outdoor house spraying, and 
over 30 times as hazardous as operating an 
air blast spray machine in a fruit orchard. 

Various phases of an operation deter- 
mined different rates of exposure. For exam- 
ple, in airplane application of 1% TEPP 
dust to a fruit orchard, the loader received 
about 3 times as much exposure as the pilot 
and about 41/2 times as much as the flag- 
man. A similar finding has been reported by 
Jegier^" who noted for orchard air blast 
spraying considerably higher rates of der- 
mal and respiratory exposure to azinphos- 
methyl during loading than during the spray 
cycle as a whole. 

Activities which did not involve direct 



contact with insecticides were generally as- 
sociated with relatively low levels of expo- 
sure. For example, entomologists observing 
mosquito control operations with Chlorthion 
or malathion incurred 0.002% of the toxic 
dose per hour. Workers picking pole beans 
one and two days after application of mala- 
thion dust sustained 0.001% and less than 
0.001% of the toxic dose, respectively. The 
exposure levels (as the percentage of toxic 
dose) for these two activities were the lowest 
of all work activities studied. 

Loaders and flaggers for air applications 
received relatively high levels of exposure, 
particularly by the dermal route. For exam- 
ple, a flagman in aerial application of DDT 
to a fruit orchard had a dermal exposure 
rate of 517 mg/hr. It is possible that in this 
instance the worker, knowing that DDT was 
a relatively nontoxic compound, made little 
effort to keep out of the drift. Airplane load- 
ers — particularly those working with dusts 
— often became heavily contaminated as 
shown by the maximum (135 mg/hr) value 
for TEPP exposure, which corresponded to 
about 83% of the toxic dose. 

Method and Rate of Application. — ^The 
amount of potential exposure depended also 
upon the method of application. There was 
more exposure while operating equipment 



Arch Environ Health— Vol 14, April 1967 



3109 



Table 2.— Potential Dermal and Respiratory Exposure of Workers to Selected Pesticides as 

No. of 
Samples Analyzed 



Compound 


Formulation 


Rate of 

Application 

(Lbs Active 

Ingredient/Acre) 


Azinphosmethyl 


0.05% spray 


3 


Chlorthion* 


5% aerosol 




Chlorthion* 


5% aerosol 




DDT 


0.09% spray 


8 


DDT 


35% dust 


17.5 


Demeton 


0.03% spray 


2 


Demeton 


0.03% spray 


2 


Dieldrin* 
Dieldrin* 


0.02%-0.03% 

spray 
0.03% spray 


2-2.5 
2.5 


DNOC* 
DNOC* 
Endrin* 


0.02%-0.04% 

spray 
0.02%0.04% 

spray 
0.05% spray 


1.1-2.1 

1.1-2.1 

1.2 


Endrin* 


0.05% spray 


1.2 


Malathion 
Malathion 
Malathion 


0.04%-0.08% 

spray 
0.03%-0.08% 

spray 
4% dust 


3-4 
3-4 

1.4 


Malathion 


4% dust 


1.4 


Malathion 


4% dust 


1.4 


Malathion* 
Malathion* 


2.5-5% 
aerosol 

2.5-5% 
aerosol 




Parathion 


0.05% spray 


2-3 


Parathion 


0.05% spray 


2-3 



Parathion 
Parathion 



0.05% spray 



0.05% spray 



2% dust 
9% spray 



Activity 

Operating power air blast machine 

spraying fruit orchards 
Operating aerosol machine for 

mosquito control 
Entomologist field observers 

checking for mosquito control 

near aerosol machine operation 
Operating powerair blast machine 

spraying fruit orchards 
Flagging for airplane dusting of 

fruit orchards 
High pressure power hand gun 

spraying fruit trees in nursery 
Driving tractor pulling high pres- 
sure power hand gun sprayer in 

nursery 
Operating powerair blast machine 

spraying fruit orchards 
Power hand gun spraying fruit 

orchards from portable machine 
Chemical thinning apple blossoms 

by power hand gun spraying 
Chemical thinning apple blossoms 

by powerair blast spray machine 
High pressure power hand gun 

spraying orchard cover crops 

for mouse control 
Operating powerair blast or boom 

sprayers treating orchard cover 

crops for mouse control 
Operating powerair blast machine 

spraying fruit orchards 
High pressure power hand gun 

spraying fruit orchards 
Operating power duster applying 

pesticide to pole beans 
Picking pole beans one day after 

dust application 
Picking pole beans two days after 

dust application 
Operating aerosol machine for 

mosquito control 
Entomologist field observers 

checking for mosquito control 

near aerosol machine operation 
Operating powerair blast machine 

spraying citrus groves 
Driving tractor pulling portable 

tower hand gun power sprayer 

during application in citrus 

groves 
High pressure power hand gun 

spraying from tower position of 

portable spray machine— citrus 

groves 
High pressure power hand gun 

spraying from ground position 

near portable tower sprayer- 
citrus groves 
Piloting airplane dusting fruit 

orchards 
Flagging for airplane application 

to fruit orchards 



Dermal Respirator 
215 8 

112 10 

170 20 



258 


15 


21 


1 


48 


6 


.31 


3 


42 


2 


42 


2 


25 


6 


177 


22 


194 


10 



44 


7 


94 


13 


14 


4 


194 


6 


42 


1 


166 


14 


238 


30 



18 
75 



(Table continued on pp 628-629.) 



Arch Environ Health— Vol 14, April 1967 



3110 



Determined by a Direct Method 



Exposure 




Dermal 


Respiratory 


Total 


Value 


(mg/hr) 


(mg/hr) 


(% toxic dose/hr) 


Range 


1.1146 


0.02-0.08 


0.01-0.95 


Mean 


27 


0.04 


0.18 


Range 


1.9-12 


0.08-0.5 


0.01-0.02 


Mean 


6.8 


0.28 


0.01 


Range 


0.81. 6 


0.05-0.08 


0.001-0.003 


Mean 


1.1 


0.07 


0.002 


Range 


3.2392 


0.02-0.27 


0.0020.23 


Mean 


54 


0.1 


0.03 


Range 


395-517 






Mean 


420 


0.2 


0.24 


Range 


1.6 5.8 


0.01-0.03 


0.17-0.62 


Mean 


3.1 


0.01 


0.33 


Range 


1-2.5 


0.01-0.03 


0.11-0.29 


Mean 


1.9 


0.01 


0.21 


Range 


6.3-31.1 


0.02-0.04 


0.1-0.5 


Mean 


15.5 


0.03 


0.25 


Range 


3.4-29.5 


0.02-0.04 


0.06-0.48 


Mean 


15.1 


0.03 


0.25 


Range 


7-90.2 


<0.02-0.42 


0.020.22 


Mean 


55.1 


0.13 


0.13 


Range 


2.9-131 


<0.04-0.08 


0.01-0.31 


Mean 


22.5 


0.05 


0.05 


Range 


1.5-7.1 


0.001-0.03 


0.12-0.59 


Mean 


3 


0.01 


0.25 


Range 


1.3-6.1 


<0.0010.02 


0.1-0.49 


Mean 


2.5 


0.01 


0.21 


Range 


3.9-59 


0.02-0.24 


0.002-0.02 


Mean 


30 


0.11 


0.01 


Range 


8.4-194 


0.01-0.25 


0.003-0.06 


Mean 


67 


0.09 


0.02 


Range 


17-32 


0.22-1.23 




Mean 


23 


0.73 


0.01 


Range 


<0.5-28 




<0.001-0.01 


Mean 


3.9 


<0.02 


0.001 


Range 


<1. 5-4.3 






Mean 


2.1 


<0.02 


<0.001 


Range 


3.7-53 


0.02-0.10 


0.001-0.02 


Mean 


29 


0.09 


0.01 


Range 


2.3-6.4 


0.04-0.09 


0.001-0.003 


Mean 


4.1 


0.06 


0.002 


Range 


1.3-38 


0.010.07 


0.09-2.60 


Mean 


18 


0.03 


1.17 


Range 


5.5-25 


0.01-0.06 


0.38-1.77 


Mean 


12 


0.03 


0.84 


Range 


1.0-28 


0.004-0.05 


0.07-1.94 


Mean 


11 


0.03 


0.77 


Range 


20-113 


0.02-0.19 


1.35-7.8 


Mean 


47 


0.09 


3.3 


Range 


8.3-19 


0.01-0.04 


0.57-1.35 


Mean 


13 


0.02 


0.87 


Range 


9.5-306 


0.003-0.08 


0.65-20.8 


Mean 


84 


0.02 


5.72 



which directed spray upward into the air 
where it was more subject to drift than when 
operating equipment that directed the spray 
downward. For example, taking into consid- 
eration the difference in dilution of the 
sprays being used, potential exposure while 
operating an air blast machine spraying 
fruit orchards with parathion was about 12 
times as great as during application of the 
same compound on row crops with a boom- 
type sprayer that directed the spray down- 
ward and, thus, resulted in less drift. The 
effects of some other methods of application 
on exposure, particularly by the respiratory 
route, are discussed below under route of ex- 
posure. 

Another variable which might be expected 
to influence exposure of applicators was rate 
of application. This value is shown in table 2 
for each of the exposure situations studied. 
Very little data on the influence of changes 
in rate of application on exposure were ob- 
tained, however, because all operators tend- 
ed to use approximately the same dosage in 
a given circumstance. The maximum varia- 
tion in application rate which was observed 
in these studies was for DNOC which varied 
from 1.1 to 2.1 lbs of active ingredient per 
acre. The application rates which were gen- 
erally used were those recommended by the 
Washington State University and the US 
Department of Agriculture. 

Duration of Exposure. — In addition io the 
level of contamination incurred per hoiir of 
work, the hazard of pesticide exposure .for a 
worker was also related to the amouit of 
time he worked at these particular duties. 
Thus, it has been pointed out that, on the 
average, poisoning can be expected to appear 
most quickly, most frequently, most diverse- 
ly, and most severely in those persons most 
extensively exposed.^i Many work situations 
involving pesticide exposure did not last a 
full 8 hr/day and those that did usually 
were not continuous for many days. Par- 
ticularly in the application of pesticides to 
agricultural crops, the work not only was 
usually seasonal but also was broken up into 
separate spraying or dusting periods of a few 
days each, as the pest infestation warranted. 
For example, air blast spraying of a fruit or- 
chard with parathion was usually carried 
out only three or four times during a grow- 



Arch Environ Health— Vol 14, April 1967 



3111 



Table 2. — Potential Dermal and Respiratory Exposure of Workers to Selected Pesticides as 







Rate of 






No 


.of 








Application 




Samp 


es 


Analyzed 






(Lbs Active 






















Compound 


Formulation 


Ingredient/Acre) 


Activity 


Derma 




Respirator 


Parathion 


1% dust 


0.30.4 


Operating tractor-mounted boom 
ground duster in row crops 


198 






33 


Parathion 


0.09% spray 


0.5 


Operating tractor-mounted boom 
ground sprayer in row crops 


48 






7 


TEPP 


l%dust 


0.5 


Piloting airplane dusting fruit 
orchards 


30 






5 


TEPP 


l%dust 


0.5 


Flagging for airplane application 
to fruit orchards 


24 






5 


TEPP 


l%dust 


0.5 


Loading for airplane application 
to fruit orchards 


34 






6 



* Partially reported in previous publication. 



ing season. Each spray period for an indi- 
vidual orchardist or sprayman lasted for one 
to six days of eight to ten hours each, de- 
pending on the size of the orchard to be 
covered. These spray operations were often 
hampered by wind, thereby extending the 
period required to complete the application. 
However, in the case of such an extended 
spray period, the number of hours per day 
was lower. In fact, there were waiting peri- 
ods of several days when adverse weather 
did not permit any spraying at all. These 
delays spread the sprayman's exposure over 
a relatively long period. The increase in the 
period over which a given amount of expo- 
sure was spread tended to decrease the toxic 
effect and to prevent the occurrence of ill- 
ness. This has been shown to be true in var- 
ious animals studied, including man. The 
time factor in relation to dosage is particu- 
larly important in the case of the organic 
phosphorus pesticides. For example, rats 
can withstand over a 24-hour period a dos- 
age approximately equivalent to the acute 
LD50 level (office of Pesticides, Communi- 
cable Disease Center, unpublished data). 

Route of Exposure. — The potential der- 
mal exposiu-e to each compound in every 
work situation studied was much greater 
than the potential respiratory exposure. The 
respiratory exposure for the various work 
situations studied ranged from 0.02% to 
5.8% (mean, 0.75%) of the total (dermal 
plus respiratory) exposure. The fact that the 
skin receives a higher dose than the lungs 
has been noted in other work situations 
studied by direct methods at this labora- 
toryi^i'''32 and by other investigators.^''-^^'''' 



In general, it is true that chemicals given 
at equivalent doses are absorbed more rapid- 
ly and more completely from the respiratory 
tract that through the skin and that studies 
with volunteers revealed a lack of toxic ef- 
fect from large dermal doses of parathion.^^ 
However, parathion applied to the skin of 
laboratory animals has shown high tox- 
icity-^'36 and a number of authors^'"** have 
attributed instances of parathion poisoning 
in people to dermal contact. 

In the various situations studied the aver- 
age potential respiratory exposure tended to 
be higher in agricultural dusting operations 
than during agricultural spraying opera- 
tions. For example, in the ground applica- 
tion of parathion to row crops, the average 
respiratory exposures were 0.16 mg/hr with 
dust and less than 0.01 mg/hr with spray. 
The respiratory exposure in these instances 
represented 1.6% and less than 0.2% of 
the total exposure with dust and spray, 
respectively. A relatively high respiratory 
exposure (0.73 mg/hr; 3.2% of the total ex- 
posiire) was also noted in the ground appli- 
cation of malathion dust to pole beans. The 
potential dermal exposure was found to be 
about the same for a given pesticide applica- 
ion regardless of whether the material was 
applied as a spray or as a dust formulation. 
Thus, ground application of parathion to 
row crops gave skin contamination levels of 
4.7 and 8.8 mg/hr with spray and dust for- 
mulations, respectively. 

Disproportionately high respiratory expo- 
sure values in relation to dermal exposure 
levels were also found in two spray opera- 
tions — use of Chlorthion aerosol for mosqui- 



Arch Environ Health — Vol 14. April 1967 



36-513 O - 70 - pt. 6A - 



3112 



Determined by a Direct Method (Continued) 



Exposure 



Dermal Respiratory Total 

Value (mg/hr) (mg/hr) (% toxic dose/hr) 



Range 


1.4-17 


0.03-0.41 


0.12-1.43 


Mean 


8.8 


0.16 


0.71 


Range 


2.2-11.3 




0.15-0.72 


Mean 


4.7 


<0.01 


0.33 


Range 


10-53 


0.02-0.47 


6.2934.5 


Mean 


24 


0.17 


15.4 


Range 


1621 


0.030.12 


9.67-12.9 


Mean 


16 


0.07 


10.2 


Range 


43136 


0.03-0.43 


25.7-83.4 


Mean 


73 


0.15 


44.2 



toes (respiratory exposure, 0.28 mg/hr or 
3.9% of the total exposure) and, to a small- 
er degree, low-volume concentrate spraying 
of parathion in fruit orchards (respiratory 
exposure, 0.06 mg/hr or 0.2% of the total 
exposure). These latter values were about 
three times as great as the respiratory ex- 
posure for similar parathion applications 
using conventional high-volume spray. These 
disproportionately high respiratory exposures 
were probably due to the fact that the spraj' 
in these two instances was made up of par- 
ticles of significantly smaller size than was 
usually the case with sprays. The small par- 
ticles tended to remain suspended in the air 
longer and, thus, presented a greater oppor- 
tunity to be inhaled. Also, the path of the 
smaller droplets was more easily changed by 
the influx of air into the nose, thus diverting 
these particles from their normal extracor- 
poral path into the respiratory tract. The 
question of exposure levels involved in con- 
centrate spraying has been dealt with more 
thoroughly elsewhere.'*^ 

The data on relative respiratory exposure 
("expressed as percentage of total [ie, dermal 
plus respiratory exposure] for workers 
applying different types of pesticide formu- 
lations is summarized in Table 3 for all the 
exposure situations measured in the present 
study. These results indicate that relative 
respiratory exposure is higher for aerosol 
(2.87% of total exposure) and dust (0.94% 
of total exposure) formulations than for di- 
lute spray formulations (0.23% of total ex- 
posure). 

Attitude of Operator. — Although it is a 



rather difficult concept to document with 
specific exposure data, observations made in 
the present study suggest that, for a given 
operation, considerably lower exposure was 
sustained by a careful operator than by a 
careless one. Among the factors noted were 
differences in avoiding contact with both 
concentrated and dilute formulations during 
loading and mixing, washing before eating 
or smoking, and wearing protective clothing 
and respirator when needed. In addition, the 
careless operators sometimes sprayed on 
windy days or under other adverse condi- 
tions while the careful spraymen waited for 
better conditions. 

Comparison of Present Results With Pre- 
vious Studies of Exposure. — In table 1 are 
listed results of previously published studies 
using direct methods to determine dermal 
and respiratory exposure of workers to pes- 
ticides, lu a number of instances, the origi- 
nal workers did not calculate total exposure 
on the basis of fraction of toxic dose per 
hour. However, these values have been cal- 
culated by the present authors and inserted 
where indicated. Also included in the Table 
are some exposure values from the present 
paper (excerpted from Table 2) for compar- 
ison with previously published resu'ts. Pa- 
pers in which authors have merely deter- 
mined air concentrations of pesticides in 
work areas and made no calculations of ac- 
tual respiratory intake have not been in- 
cluded in the tabulation. The results from 
the present study were generally in good 
agreement with those published previously, 
in those instances in which direct compari- 
sons were possible. , 

Values for exposure to azinphosmethyl 
while spraying fruit orchards have been re- 
ported from Australia,^^ Canada,3o Israel,^'' 
and the United States, as reported in 
this paper. The dermal exposure levels for 
this compound determined by Simpson (9.9 
mg/hr), by Jegier (12.6 mg/hr), and that 
reported in the present paper (27.2 mg/hr) 
were similar. Known differences in proce- 
dure apparently account for some, if not all, 
of the variation which does occur among 
these results. Thus, although both Jegier 
and Simpson generally followed the proce- 
dures initially described by Batchelor and 
Walker, ^8 there were some differences in 
technique. Jegier used a-cellulose strips only 



Arch Environ Health— Vol 14, April 1967 



3113 



Table 3. — Relative Respiratory Exposure (Ex- 
pressed as The Percentage of Total 
[Dermal + Respiratory] Exposure) for Workers 
Applying Different Types of Pesticide 
Formulations 







Respiratory Exposure 


Type of 


No. of 






Formulation 


Activities 


Value % of Total 


Dilute Spray 


19 


Range 0.02-0.5 
Mean 0.23 


Aerosol 


4 


Range 0.3-5.8 
Mean 2.87 


Dust 


7 


Range 0.05-3.2 
Mean 0.94 



on the forehead and wrists of the subject in- 
stead of on the four body areas (shoulders, 
back of neck, "V" of chest, and forearms) 
sampled in the present study. Also, both Je- 
gier and Simpson calculated hand exposure 
on the basis of the wrist pad contamination 
while the whole hand was rinsed in the 
present study to determine exposure. In our 
experience pads placed on the wrists gave 
lower results for hand contamination than 
did washing the entire hand area, particu- 
larly in regard to exposure during mixing 
and loading. The much higher dermal ex- 
posure results (541 and 755 mg/hr for noc- 
turnal and daytime spraying, respectively) 
obtained by Wassermaim et aP* caimot be 
explained at this time. The difference be- 
tween nocturnal and daytime exposure levels 
was due to the greater amount of protective 
clothing worn when spraying in the cooler 
temperatures at night. The respiratory lev- 
els for the present study (0.04 mg/hr) were 
considerably lower than those obtained by 
Wassermann et al (0.54 mg/hr) and some- 
what lower than those reported by Simpson 
(0.10 mg/hr) and by Jegier (0.26 mg/hr). 
It is particularly interesting to note that Je- 
gier obtained good correlation for respira- 
tory exposure determined from pads (0.26 
mg/hr) and from air samples (0.30 mg/hr). 
The dermal exposure level for operators 
thiiming apple blossoms with DNOC, as de- 
termined much earlier at this laboratory 
(63.2 mg/hr) by Batchelor et al,*^ was 
somewhat higher than that found in the 
more recent studies (24.4 mg/hr, 22.5 
mg/hr). The markedly higher respiratory 
level found earlier (1956 value, 0.40 mg/hr; 
present values, 0.13 for hand-gim and less 
than 0.05 for air blast equipment) was ap- 
parently due to the use at that time of un- 



covered respirator pads which permitted im- 
pingement of spray and apparently resulted 
in counting as respiratory exposure particles 
which would not be inhaled through the 
presently used funnel-covered respirator 
pads. These differences were discussed in 
detail by Wolfe et al.-* The dermal expo- 
sure level for DNOC (57.5 mg/hr) deter- 
mined in Israel by Wassermann et aF* 
agrees well with the values determined here 
(22.5 and 55.1 mg/hr); however, the respir- 
atory level determined by Wassermann and 
his colleagues (2.75 mg/hr) is very much 
higher than the present values (0.13 and less 
than 0.05 mg/hr) or even than that ob- 
tained earlier with uncovered respirators 
(0.40 mg/hr). In fact, the respiratory expo- 
sure level of 2.75 mg/hr is higher than that 
for any compound studied by other labora- 
tories in outdoor spraying activity and ap- 
proaches the level for DDT exposure during 
indoor house spraying (7.1 mg/hr). *^ 

Dermal malathion exposvire as deter- 
mined in the present study (30.3 mg/hr) 
was higher than that (2.5 mg/hr) published 
by Jegier,^3 probably due at least partly to 
the differences in technique mentioned 
above. Respiratory results (present paper, 
0.11 mg/hr; Jegier, 0.08 mg/hr) were com- 
parable. 

Also, for parathion spraying, the present 
dermal exposure level (19.4 mg/hr) was 
higher than that reported by Jegier (2.4 
mg/hr) while the respiratory values were 
similar (present paper, 0.02 mg/hr; Jegier, 
0.03 mg/hr). 

Evaluation of Hazard to Workers. — From 
tables 1 and 2, it can be seen that in studies 
at this laboratory three compounds — endrin, 
parathion, and TEPP — have been involved 
in operations in which the mean value for 
the percentage of toxic dose potentially ab- 
sorbed per hour exceeded 1%. All three of 
these compounds are known to have caused 
occupational poisoning. There is only one 
other compound (demeton) listed in the ta- 
bles which is known to have caused occupa- 
tional poisoning in the sort of work activi- 
ties under study here. Therefore, it appears 
that, in general, the results of these exposure 
tests correlate well with use experience. 

The highest mean value for fraction of 
toxic dose received per hour of work 
(44.2%) was for workers who loaded air- 



Arch Environ Health — Vol 14, April 1967 



3114 



planes with 1% TEPP dust. Although there 
have been numerous illnesses among work- 
ers in this occupation, the number who be- 
come ill has been quite low considering that 
the workers potentially would, on the aver- 
age, be subjected to almost one half the tox- 
ic dose per hour of work. Three factors may 
account for the low morbidity rate. First, ob- 
servations have indicated that the number of 
hours per day or per week the worker is ac- 
tually loading airplanes is quite low. Sec- 
ondly, in such a situation where it is obvious 
that high contamination of the worker may 
occur, much more attention is generally giv- 
en to the use of adequate protective clothing 
and respiratory devices than in less hazard- 
ous jobs. Thirdly, probably only a small per- 
centage of the dry dust impinging on ex- 
posed skin areas is actually absorbed. 

Although much attention has been, and 
rightly should be, given to prevention of ex- 
posure to compounds that are more acutely 
toxic, the importance of also minimizing ex- 
posure to other less toxic compounds should 
not be overlooked. For example, malathion, 
while not a compound of high systemic tox- 
icity, has been shown to be a skin sensitizing 
agent and a potential cause of dermatitis in 
exposed individuals.^^ -phe fraction of toxic 
dose received during application of some of 
the less toxic chlorinated hydrocarbon pesti- 
cides may be compartively low; however, 
these compounds are stored in body fat fol- 
lowing absorption. Although no adverse 
health effects have yet been shown in work- 
ers with continued, high-level exposure to 
DDT'' or pesticides generally ,•'*'' the contin- 
ued contact with absorbed chlorinated hy- 
drocarbon compounds resulting from fat 
storage and the possible additive pharmaco- 
logic effect of various related pesticides in 
this chemical class are factors that should be 
considered. Also, certain dusts, even tho.se 
inert ones which do not contain pesticides or 
other added chemicals, may cause discom- 
fort and even precipitate illness in some peo- 
ple. 

The exposure studies reported in the 
present paper and similar studies which 
have been published previously from this 
and other laboratories fas summarized in 
table 1) indicate that, in general, agricul- 
tural and public health vector control work- 
ers asing pesticides in various activities are 



exposed to relatively small fractions of the 
toxic dose each day. Surveys of illness, and 
of various physiologic manifestations of pes- 
ticide exposure, such as symptomatology, 
blood cholinesterase activity, fat storage of 
DDT and other chlorinated hydrocarbon 
pesticides and their metabolities, and uri- 
nary excretion of DDA, p-nitrophenol, and 
other pesticide biotransformation products 
confirm this impression of a generally low- 
level of exposure of workmen to pesticides. 
Both direct and indirect studies have shown 
that the exposure levels of workers, while 
higher than those for the general popula- 
tion, are generally relatively low in compari- 
son to the toxic level. In many instances in 
which poisoning of a pesticide worker does 
occur, it is possible to show an obvious disre- 
gard for one or more safety recommenda- 
tions to account for the illness. 

Thus, the results of the present study are 
consistent with the idea that pesticides can 
be used safely provided recommended pre- 
cautions are followed. In fact, a number of 
pesticides are so nontoxic that occupational 
poisoning associated with their use has not 
been reported and the exposure levels (as 
the percentage of toxic dose per hour) are so 
low that it is doubtful that it will occur. 
However, a few of the more toxic com- 
pounds (such as endrin, parathion, and 
TEPP) have caused occupational poisoning 
in the past. Their relatively high exposure 
values indicate that even minor lapses in ad- 
herence to safety precautions might be 
sufficient to allow poisoning to occur. 

Summary 

Values for dermal and respiratory expo- 
sure and for total exposure in ternis of frac- 
tion of toxic dose were determined for 31 
different work activities involving ten dif- 
ferent pesticides. 

There were wide ranges in exposure level 
for a given work activity with a specific pes- 
ticide, depending on the environmental con- 
ditions, particularly wind and technique of 
the operator; but other factors could not be 
excluded. Also, for a given pesticide there 
was a significant variation in hazard de- 
pending upon the type of work activity in- 
volved. Various phases of an operation often 
produced different levels of exposure. Gen- 



Arch Environ Health— Vol 14, April 1967 



3115 



erally, the loading operation was the most 
hazardous part of the spraying or dusting 
cycle. Exposure also depended upon the 
method of application. Not only was the 
hazard related to the length of time worked, 
but the use of dusts or fine aerosols rather 
than sprays greatly increased respiratory 
exposure. 

As reported in previous exposure studies, 
the potential dermal exposure to each com- 
poimd in every work situation studied was 
much greater than the potential respiratory 
exposure. However, the practical importance 
of this potential difference must be viewed 
in light of the fact that chemicals given at 
equivalent doses are absorbed more rapidly 
and more completely from the respiratory 
tract than through the skin. 

The results from the present study were 
generally in good agreement with those pub- 
lished previously in those instances in which 
direct comparisons were possible. 

The present results indicate that, in gen- 
eral, workers using pesticides in agriculture 
and public health vector control are exposed 
to relatively small fractions of the toxic dose 
each day. These findings are consistent with 
the idea that pesticides can be used safely 
provided recommended precautions are fol- 
lowed. However, the relatively high expo- 
sure values associated with a few of the more 
toxic pesticides ("such as endrin, parathion, 
and TEPP) indicate that even minor lapses 
in adherence to safety precautions might be 
sufficient to allow poisoning to occur. 

Some of the data reported in this paper was col- 
lected by Gordon S. Batchelor and Kenneth C. 
Walker. The a-cellulose was supplied by Rayonier, 
Inc.. New York. 

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GROWTH OF PROCESSED FOODS 



In 1908 there were three cans of food used per family, while in 1963, 680 cans and jars 
were consumed per family. Ahnost 30 billion cans of food are consumed annusdly in this 
country. This is only one segment of the food industry. The frozen-food packers also 
have a spectacular story of product development and acceptance. In the last 25 years, 
their production ha.s increased from 648 million pounds to more than 8.5 billion pounds. 
— Mounce, D. M.: Standards of Safety for Foods in Relation to Public Health, Amer J 
Public Health 56:952 (June) 1966. 



Printed and Published in the United States of America 
Arch Environ Health— Vol 14, April 1967 



3117 



Reprinted from The Journal of the American Medtcal Association 

Ff^h. 15. 1958, Vol. 166 

Copyright 1958. by American Merlicol A^snrwtion 



Purnrshed by 

Communicable Disease Center 

Tectinical Development Laboratoriei 

P Box 769. Ssvinnah. Gs. 



PARATHION RESIDUES AS A CAUSE OF POISONING IN CROP WORKERS 



Griffith E. Quinby, M.D., M.P.H., Wenatchee, Wash. 

and 

Allen B. Lemmon, A.B., Sacramento, Calif. 



From the early days of agricultural use of 
parathion (0,0-diethyl-O-p-nitrophenyl thiophos- 
phate), it has been recognized that a potential haz- 
ard to the workmen exists "from the point of open- 
ing the bag to the ultimate possibility of a contact 
with material residual at thinning or suckering 
time." ' Leach,' Haller,' and doubtlessly others rec- 
ognized the hazard to all workers— even those whose 
only exposure was in areas after application. Never- 
theless little attention was given to the hazard 
of contact with residual parathion. One difficulty 
pointed out by Kay and co-workers ' was the 
lack of suitable analytical methods for separating 
parathion residues from the plant products. More- 
over, all the deaths and the majority of the serious 
illnesses from parathion were associated with known 
direct exposures while mixing or applying the ma- 
terial or from relatively concentrated material left 
in a container. Such poisonings occurred sporadi- 
cally among many people so exposed. 

One instance of poisoning in harvesters to be 
described in this paper was known to have occurred 
as early as 1949. Though widely discussed, it has 
never been previously published. Other unpub- 
lished reports of similar poisoning have come from 
several states in this country and from provinces of 
Canada. When large groups of workers were in- 
volved, the pattern of illness sometimes suggested 
food poisoning or water-borne gastroenteritis. When 
small groups were involved, heat stroke was some- 
times suspected. When illness was recognized as 
poisoning, it was sometimes mistakenly attributed 



From the Communicable Disease Center. Pii'ilic Health Service, U. S. 
Department of Health. Education, and Welfare, Atlanta, Ga. {Dr. 
Quinby); and the Bureau of Chemistry, Department of Agriculture of 
California (Mr. Lemmon). 



The applicafion of parathion as a pesli- 
cidal spray in fields and orchards leaves a 
residue that declines rapidly on most crops 
for the first few days and more gradually 
during a period of weeks. Persons not actu- 
ally engaged in spraying but working among 
trees and vines thereafter run a risk of 
poisoning that depends on a number of 
focfors. Eleven episodes of poisoning from 
contact with parathion residues, involving 
more than 70 persons, have been analyzed. 
The crops involved were pears, apples, 
grapes, citrus fruits, and hops. The workers 
were engaged in picking, thinning, cultivat- 
ing, and irrigating. Absorption apparently 
was by the dermal rather than the respira 
tory route. It was favored alike by the re 
moval of protective clothing and by the per 
sistent wearing of contaminated clothing 
Certain weather conditions may have 
creased the likelihood of contamination. One 
episode involving 1 6 cases occurred 33 days 
after the spraying. Regulations intended to 
minimize the hazards of using parathion 
need to be reviewed with respect to the 
poisonings that have occurred from the per- 
sistence of toxic residues. 



to the inhalation of parathion vapor so that atten- 
tion was diverted from the major source of exposure 
^ dermal). The earlier outbreaks were seldom 
checked by blood cholinesterase determinations. 



3118 



A 1951 outbreak which was confirmed by chol- 
inesterase determination was summarized before a 
scientific meeting in 1952 by Conley.' On May 25, 
1951. 300 acres of vineyard near Delano, Calif., 
were sprayed at the rate of 1.9 lb. of parathion per 
acre. On June 27, 33 days after application, 24 men 
were stripping and thinning the vines. None had 
had previous exposure to cholinesterase inhibitors. 
After about seven hours of work, some became ill 
and ultimately 16 of the 24 developed symptoms and 
were hospitalized. The chief s\'mptoms were head- 
ache, nausea, vomiting, diarrhea, miosis, weakness, 
and mild shock. Symptoms were relieved by doses 
of atropine 1/100 grain (0.6 mg. ) administered at 
short intervals. .Most were discharged from the hos- 
pital within 24 hours, one was hospitalized for three 
days. Blood samples taken on July 6 still showed 
"low" cholinesterase activities. On June 29, the 
leaves showed a residue of 8 ppm of parathion. 

Lieben and associates ' described an outbreak of 
illness occurring in 1952 in 20 of 52 teen-age tobacco 
pickers in Connecticut. Although parathion poison- 



Being aware of the logical possibility of excessive 
exposure from contact with residues, Braid and Dus- 
tan ■ carried out an excellent study of parathion resi- 
dues on immature peaches. They found that residues 
persist far longer on the fruit ( half-life of 7 to 10 
days) than on the leaves (approximately 2 days) 
of the same peach tree. The authors mentioned 
"ill-effects supposedly due to residual parathion 
during thinning operations." However, further in- 
vestigation ' revealed that the case histories of the 
two persons in question were so confounded with 
recent heavy spray exposures in both cases and 
with contradictory autopsy findings in one case that 
their interpretation is difficult. Bobb " reported resi- 
dues in two successive \ears on peach trees indi- 
cating a half-life of about two weeks on bark, but 
only 2% of the residue persisted on the leaves after 
one week. 

Report of Cases 

The following instances of parathion poisoning 
associated with direct exposure to residues are ar- 
ranged in chronological order and designated by 



T.4BLE \.—Data on Parathitm Poisoning in Crop Workers Exposed to Residues 



Lomtlon Yr. Crop .\otlvlly 

Marjsvlllr, Calif 1SI9 Pears PIrklni; 

HlKhlaod. Calif IMl Cllnis CuUlvatinir 

Delano. Calif* lft:>l Grape«t StrlppiD»f aud thInniDK 

Orovllle. Wanh ia>2 Apple.i Thlnnlnit 

So. OkanaKao Valley. 

B. (•."' 1»V> .Apple* ThlnniriK 

Riverside. Calif 19i> OranBes PIcklne 

Riverside, Calif Ift'iS Oranites Plcltlni; 

Entlat, WaFh 1953 .\pples Thiiuillik: diirlDK »pruylnK 

Manson. Wa^ti 1J.'>4 Applet* IrrlKatinK 

Wenatchee. Wai»h IXA Apples ThlDOlOK 

Yakima. Wash 19:13 Hops Picking 

• Best data avalluhle reflecllHK weight of actual parathion per oi' 
t One patient had had previous exposure and one had not. 

ing was suspected, the authors presented .some evi- 
dence that poisoning was not involved. No similar 
illness occurred in other camps. Blood cholinester- 
ase activities were normal in five of the exposed 
boys including three who were ill. There was no 
essential difference in the paranitrophenol excretion 
of the normal and the sick boys on the day after 
illness. Most important; the sick boys returned to 
work and showed no further illness although their 
level of paranitrophenol excretion ( presumably re- 
flecting rate of parathion absorption ) approximately 
doubled during the next 10 days. In a related study, 
Schaefer and Vance " have reported measurements 
of parathion residues on tobacco at different inter- 
vals after application. They mentioned that no 
proved illness due to skin absorption of parathion 
has come to the attention of the Connecticut State 
Department of Health among many thousands of 
workers, many of them children, while handling to- 
bacco leaves containing spray residues. 




Previous 






Exposure 


EITect on 


Response 


While 


C'holln, 


to 


Spraying 


esterase 


Atropine 



the name of the town near which they occurred 
(table 1). Direct study by one of us was possible 
in some cases. Other cases were brought to our at- 
tention long after they occurred. Thus the thorough- 
ness with which it has been possible to study the 
cases has varied. However, all of these cases give 
some additional proof to the conclusion already 
suggested by the literature, namely, that dermal 
contact with parathion residues can cause poison- 
ing under practical conditions of work. Such poison- 
ing apparently occurs more frequently than has 
been recognized before. 

In Mary.sville, Calif., on July 8, 1949, at 8 a. m. three 
crew.s of 30 men eacli began picking pears. Two of the 
crews picked in areas sprayed on June 27 (12 days earlier) 
with 2.5 lb. of parathion per acre. The other crew picked in 
a block sprayed on an earlier date. Residue analysis, done 
two days before the picking started, from the trees sprayed 
on June 27 showed only 0.00156 grains of parathion per 
pound of fruit ( 0.22 ppni ) . Picking had therefore been 
undertaken with rea.sonal>le assurance that residues were not 
high on the fruit. 



3119 



The day was hot and humid with little air motion. Onset 
of symptoms ranged from 12:30 p. m. to 8 p. m. Most of the 
men became ill between 2:30 and 4 p. m. By mid-aftemoon 
a dozen pickers in the first two crews became ill and quit 
work. Some lay down and others left for their homes. Almost 
all those who were ill and who remained at the ranch began 
to vomit and were then hospitalized. By evening at least 
20 to 25 men had been to the hospital. Two were so sick 
that they had to be brought by ambulance. All but four 
vomited and retched continually. Temperatures were sub- 
normal, pulses fast, and the men perspired excessively. The 
four who did not vomit had vertigo. Pallor and weakness 
were also common symptoms. Two or three complained of 
twitching of the arm and leg muscles. 

The response of the patients to atropinization was striking. 
Within 20 to 25 minutes all improved and 10 men wanted 
to go home. Nine of the seriously affected were detained in 
the hospital for overnight observation. A tew had repeated 
doses of atropine. All but two were released the next morn- 
ing. The diagnosis was acute parathion poisoning by inhala- 
tion. 

None of the pickers had had prior exposure to organic 
phosphates. None of the third crew picking in the orchard 
sprayed earher had similar symptoms. All pickers had dif- 
ferent lunches and different sources of water. Some ate pears; 
others did not. 

Table 2.-Blood Cholinesterase Actwities' in Orange Pickers, 
Riverside, Calif., 1952 

Case -No. RBC Plasma 

1 0.11 0.18 

•) 0.12 0.22 

3 0.20 0.22 

4 0.21 0.20 

5 0.21 0.38 

6 0.38 0.21 

7 0.39 0.29 

8 0.52 0.25 

9 0.51 0.38 

10 0.57 0.58 

• Modified Metcalf incthml in terms oi micromoles per live micro- 
liters per 30 minutes. Xonnul raii^^es: rhc, 0.8-1.4; plasma, 0.3-0.5. 

On July 11a sample of 100 leaves was taken for residue 
analysis from tile plot sampled earlier. It showed 6.5 ppm 
or 0.0313 meg. per square centimeter of leaf surface. Four 
days later a sample of leaves showed 2.9 ppm or 0.0146 
meg. per square centimeter of leaf surface, indicating the 
considerably greater amount and persistence of residues on 
leaves as compared with fruit. 

In Highland, Calif., a 22-year-old tractor driver disked a 
citrus orchard on the morning of May 30, 1951. The foliage 
of the low, closely set trees was dusty. Parathion had been 
applied eight days earlier and the orchard was still posted 
with warning signs. The driver brushed against the trees as 
he drove along. It was so hot and still that he removed his 
shirt. Although this man had had unrecorded previous ex- 
posure to sprayed foliage, at no time was he exposed to tlie 
process of spraying. At about 2 p. m., which was somewhat 
after lunch, the driver became violently ill. He called a 
nearby pest control operator who supplied the patient with 
atropine tablets and had the patient taken to the local hos- 
pital. Signs and symptoms included vomiting, abdominal 
cramps, sensation of feeUng "numb all over," and pinpoint 
pupils which still reacted to light and accommodation. His 
skin color was ashen, and mild cyanosis was present. Urine 
and blood studies, as well as physical examination revealed 
no other positive findings except 3-|- mucus in the urine with 
two to four white blood cells per high power field and a 
trace of albumin. Upon admission, 1/50 grain (1.2 ing. ) of 
atropine ( 1/200 grain [0.3 mg.] intravenously and the re- 
mainder intramuscularly) gave the patient an immediate 
sense of relief. The atropine furnished by the pest control 



operator was lost or misplaced on the way to the hospital. 
The pupils dilated but some vomiting continued as long as 
two and one-half hours after admission. The patient slept 
soundly throughout the night, but when he awoke it was 
noted that his pupils were contracted again and other s>'mp- 
toms returned. Another dose of atropine ( 1/100 grain [0.6 
mg.] subcutaneously) relieved him again and he required 
no further treatment. 

In OroNille, Wash., a 48-year-oId orchardist sprayed his 
apple trees with parathion from June 13 to 20, 1952, at a 
rate of 2.25 lb. per acre. He started thinning in trees sprayed 
two days earher. Seven days after starting to thin, he noted 
visual disturbances, was dizzy, and returned home where he 
became nauseated and vomited. He was seen to have pin- 
point pupils. He had heaviness of his legs and excessive 
sweating. His physician gave him atropine which afforded 
fairly iimnediate relief. Three weeks after this experience, 
the patient had a normal plasma cholinesterase activity but 
his erythrocyte value was 0.38 -i pH per hour by the Michel 
method.'* 

In retrospect this patient had noted that four hours before 
the recognized onset of liis illness, both he and his daughter 
had had a warning sign of txvitching of the eyelids. The 12- 
year-old daughter had helped her father thin his recently 
sprayed orchard. Her only sign of illness was uncontrollable 
twitching of the eyelids four hours before the onset of her 
father's illness; the significance of the twitching was not 
reaUzed at the time. 

In South Okanagan Valley, British Columbia,'" on Aug. 4, 
1952, four workers became ill after thinning in an apple 
orchard sprayed two days earlier with paratliion. Their symp- 
toms suggested food poisoning but were relieved by atropine. 
Red blood cell cholinesterase activities three or four days 
later ranged from 26"r to 55'^" of Michel's normal values; 
plasma activity was not determined. Cholinesterase deter- 
minations in six employees of the Department of Finance, 
whose only possible exposure was incurred while assessing 
the orchards, showed no such depletion. Six orchardists who 
had sprayed parathion for three years but without recent 
exposure had essentially normal cholinesterase activities. 

In Riverside, CaUf., on Aug. 8 and II, 1952, a 6-acre 
orange grove was sprayed at a rate of 12 lb. of parathion 
per acre. From 16 to 19 days after these apphcations, on 
Aug. 27, a crew of 30 men picked oranges from the dusty 
trees from about 6 a. m. to 2 p. m. No picker had had pre- 
vious exposure to an organic phosphorus insecticide nor had 
he picked on other sprayed areas. Seven men became ill a 
little after lunch; three others became ill later the same day; 
and another became ill the next day, making a total of 11. 
Symptoms were weakness, vomiting, and profuse perspira- 
tion. One man was almost unconscious; two were reported 
as hardly able to see. Ten of the men were hospitalized and 
treated with atropine. Their blood choUnesterase activities, 
apparently tested on the day of onset, were reduced (table 2). 

Again in Riverside, Calif., on July 6, 1953, seven orange 
pickers became ill while picking oranges and others had 
their onsets after returning home from work. The grove had 
been sprayed with parathion 17 days earlier. Three workers 
were so ill they were hospitalized overnight. Brief hospital 
records revealed symptoms of nausea, sweats, and abdominal 
cramps. Miosis was recorded for only one of the patients. 
This sign and other symptoms were relieved in all three 
cases by a single dose of 1/50 grain (1.2 mg. ) of atropine. 
No cholinesterase determinations were done. 

The etiology of this group of cases might be hard to accept 
as parathion residues 17 days old were it not for the more 
completely documented episode described above, apparently 
due to residues 16 to 19 days old. Moreover, within the same 
month as the second outbreak at Riverside, a third outbreak 
was associated with 34-day-old residues, and another at 
nearby Bryn Mawr with 33-day-old residues, although the 
latter two outbreaks have not been described in detail for 
lack of clinical records. 



3120 



In Entiat. Wash., in early June of 1953, a woman thinned 
apples for two days in an area being sprayed with O.CW^t 
parathion (as water-wettable powder) at a rate of about 
2.25 lb. per acre. AlthouRh she felt the spray hit her often, 
her greatest exposure was to residues, for some of the trees 
she thinned were still wet. During the morning of her second 

Table 3.— Blood Cholinesterase Determinations by Michel 
Method in Case of Parathion Poisoning (Entiat, Wash.) 
APH Hr. 

Days Slnc« First KnowD Exposure RBC PlaRma 

» 0.82 O.Sl 

7 0.S8 0.16 

> 0.!5 O.U 

U 0.38 0.40 

M O.Vi OSO 

day of exposure, she became dizzy and unsteady. At lunch 
time she was not as huncr>' as usual. By 4 p. m. she was weak 
and vomiting. This condition continued throughout the night 
and next morning when she sought medical advice, at which 
time miosis was noted. Her blood cholinesterase activities 
were as shown in table 3. 

The failure of the plasma cholinesterase activity to show 
any recover)' for nine days and the recurrence of mild symp- 
toms of poisoning led the attending physician to suspect she 
had continued her exposure unintentionally or against medi- 
cal advice. 

In Manson, Wash., in 1954, a woman thought on each of 
two occasions that she was poisoned by malathion after 
spraying her Howers with two heaping tablcspoonfuls of 25% 
water-wettable powder in two to three gallons of water in a 
hand sprayer. Her exposures to malathion were on June 28 
and July 7, 1954. Each application was followed shortly by 
headache, nausea, and dizziness. She was under the mis- 
impression that her husband and son had sprayed the family 
orchard with malathion. .Subsequent investigation revealed 
that the orchard and her garden (all in the orchard) had 
been sprayed with parathion at the rate of about 2.5 lb. per 
acre. Although her memory of details was in question, calen- 
dar records showed that she irrigated the orchard for the 
five days following the .second cover spray of parathion on 
June 23. The weeds in the orchard were wet with the spray 
and later white with residues when she walked through the 
orchard five or six times daily changing sprinklers. She wore 
the same dusty "pedal pushers" throughout and her legs 
were bare half-way below the knees. The second illness was 
preceded by additional exposure to residues. 

In Wenatchee, Wash., during the first week in June, 1954, 
five persons related by blood or marriage began thinning 
apples from 1 to 10 hours per day for six days a week. On 
June 24, four of the five showed moderate symptoms of or- 
ganic phosphorus poisoning while the fifth exhibited only 
muscle twitchings of the eyelids. The exposure, symptoms, 
and cholinesterase activities of the five exposed persons are 
shown in table 4. 

For four days before the onset of the symptoms, all five 
people had been thinning in trees sprayed from 32 to 108 
hours previously. On the day of onset, they had thinned in 
an area sprayed three days earlier. Although no analyses of 
residues on leaves and friiit were performed, the degree of 
exposure was evidenced by the fact that visible amounts of 
white powder were noted on clothing and arms. 

The spray used was 0.1 S'J parathion applied at the rate 
of about 2.25 lb. of actual parathion per acre. The exact 
dates of scattered light rains while the thinning was in 
progress are uncertain. However, all infonnants recalle<l that 
there was some "sprinkle" heavy enough to cause them to 
stop work one day. Another day they continued to thin in 
a light rain. On one occasion one of the thinners, an older 
boy, continued to thin after he removed his shirt because 
of the heat. He was one of the two ill enough to require 
medical treatment. 



One of the patients was hospitalized over night and im- 
proved on a dosage of 1/100 grain (0.6 mg.) of atropine 
every two to three hours during the night. She was dis- 
charged the following morning but relapsetl and had to be 
given atropine again later in the day. The other treated pa- 
tient was given considerable relief by a single dose of 1/100 
grain of atropine. 

In Yakima, Wash., on Aug. 31, 1955, two pilots from a 
commercial airplane dusting service applie<l a total of about 
7 tons of 4 and 5^c parathion dust on four different hop 
farms, totaling 280 acres, at the rate of 50 lb. per acre ( 2 to 
2.5 lb. actual parathion). This high concentration was used 
just before har\'est in a desperate effort to check mite damage 
to the valuable crop. The application was repeated about 48 
hours later on Sept. 2 with 4% parathion dust. (After these 
heavy applications, both pilots became severely affected. ) 
At least six hop pickers were mildly poisoned by handling 
the crop which the pilots had recently dusted. Some rumors 
were current that there were many (up to 60) other mild 
untreated illnesses among other pickers. Under the circinn- 
stances, the investigator of this outbreak (G. E. Q. ) felt that 
partial credence must be given to these rumors. 

Five of the six investigated illnesses were associated with 
treatment of a single field. Picking had started Aug. 24, but 
no illness occurred among pickers until Sept. 1, the day after 
the first dusting with 5^( parathion. On that day a crew of 
seven pickers renewed the harvest of hop vines. The pro- 
cedure involved the cutting of the vines first at the grouiicl 
level and then from the supporting wires about 15 ft. om r 
head. The vines dropped onto the bed of the picking vehii I. 
where they were caught by the pickers who then placed tli< 
ends of each vine into clamps on a carriage belt which i.u 
ric-d the vines into a shredder. Vines frequently fell on tin 
pickers, and their blue denim clothing became white wilh 
dust. The air around the pickers was cloudy with the dust 

A 19-year-old daughter of the manager of a hop farm was 
one of a crew of seven hop pickers which included her sister 
and five others, most of whom were Mexican itinerant farm 

Table 4.— Parathion Poisoning in Family Group Engaged in 
Thinning Fruit at Wenatchee, Wash., 1954 



' .^ge, Synipto?iis Day of 1 

Yr. Sox Exposure Onset Date RBC 

28 F ThlnnlDB 10 Hiccups, nausea, vom- 0/25 0.26 

hr. day (or Itlng. sweatlnK. weak- 6/28 0.29 





ness. shortness of 


fl/2S 


0.40 


0..tli 




breath, headache. 


7/14 


0.43 


0,hH 


sprayed 
from 2-4 


twltchlni! eyelids and 


8/18 


0.66 


o.m 


days earlier 


facial muscles, 
tachycardia, miosis 








Same as 


.Nausea, vomiting. 


6/26 


030 


0.24 


above 


sweating, heart con. 


7/13 


0.46 


0.6I> 




sciousness. weakness. 


8/18 


0.48 


VO 




twitching eyelids 









39 M Thinning 4 
hr.. Irrigat- 
ing 4 hr. 

46 M Thlnnlngt 



Ulddlness. almost 6/26 0.29 0.24 

tainted, sweats, nau- 7/13 0.44 0.64 

sea. weakness, 8/18 0.M 0.80 
twitching eyelids 

Twitching eyelids 



ausea, headache, 6/26 0.26 016 

witching eyelids 7/13 0.41 0.62 

8/18 0.48 0.60 



laborers. Picking was begun in the field behind the home of 
the girls' parents. The convenient location was doubtlessly 
somewhat responsible for the decision to pick in that field 
rather than one dusted some days previously. About 4 p. ni. 
on Sept. 1, the girl had to stop work and came into her 
mother's house sweaty, nauseated, and vomiting. Her mother 
described the ashen pallor as "green." The retching which 



3121 



followed the vomitinR lasted about four hours. There were 
sweats and chills. Retrospective questioning revealed that 
uncontrollable twitching of the eyelids was the first symptom 
or sign. After the girl had vomited continually for some time, 
the mother suspected the cause of the illness and called a 
physician. He prescribed atropine. One tablet was taken and 
vomited. However, the second tablet taken four hours later 
was retained. The patient recovered and felt well enough to 
go back to work again on Sept. 5 in the same field. She was 
made ill again by her ree.xposure, and vomiting was the only 
recalled sign. 

The 21 -year-old sister of this patient worked two days 
longer than her sister before becoming ill on Sept. 3. Pre- 
sumably all work was in the same field, which was dusted for 
the second time Sept. 2. As with her sister, the first sign was 
twitching of the eyelids. This was followed by nausea, vom- 
iting, and chills. She and her sister had both complained of 
the odor and taste of parathion while working in the dust. 
She was given atropine orally at home but was unable to 
retain the tablets. Vomiting was so severe that she was hos- . 
pitalized for three days. Atropine, 1/150 grain (0.4 mg. ) 
in 1,000 cc. of 5'7< dextrose given intravenously, stopped the 
vomiting. The dose of atropine was repeated intramuscularly 
in six hours. She was also given one dose each of pheno- 
barbital and meperidine ( Demerol ) as a sedative. On the day 
she was discharged from the hospital, she fainted and fell 
while in a store but required only bed rest to recover. 

A 17-year-old Mexican itinerant laborer was the third 
person of the crew of seven who showed signs of poi.soning. 
On Sept. 3, he complained of dizziness, followed by per- 
spiration, nausea, vomiting, and pain in the chest. He was 
noted to have pinpoint pupils. He collapsed while on the 
picking machine and was taken to a hospital. He was reUeved 
by atropine, 1/150 grain (0.4 mg. ) given subcutaneou.sly. 
The eholinesterase activity of his whole blood was reduced 
as measured by the bromothymol blue .screening test (VVolfsie 
and Winter) ' ' and the blood showed hemoconcentration. 

The fourth sick crew member, a 30-to-40-year-old Mexi- 
can woman, was seen vomiting on Sept. 1. No other history 
was obtained, probably because of the inability of the 
woman to speak English and because the significance of the 
illness was not realized at that time. 

The fifth sick crew member, a young Mexican male, was 
noted to have been ill on Sept. 3 "just like the four others'* 
but was not seen by a physician nor any English-speaking 
person who made any careful observations of the patient. 
He recovered spontaneously and shortly afterward left the 
state. 

While working with another crew on the same farm where 
the five pickers had become ill, a young Mexican hop picker 
fainted while on a picking machine. The date of onset of his 
symptoms could not be ascertained except that they occurred 
between Sept. 4 and 8. He was taken to one of the physicians 
who had seen several cases of parathion poisoning during the 
year. There were no signs noted in fragmentary office rec- 
ords. Since a bromothymol blue screening test on Sept. 8, 
1955, showed "normal activity" and the patient had recov- 
ered from his syncope, he was returned to the hop farm. 

The second of the four hop farms dusted by the two pilots 
previously mentioned produced one case of poisoning on 
Sept. 4, 1955. The foreman on this farm stated that no other 
pickers were ill. The superintendent of the four hop farms 
and the physicians concerned with the care of the employees 
knew of no illnesses occurring in connection with the other 
two farms. 

A young Mexican hop picker was brought into a physi- 
cian's office in a small town away from the medical center 
where the group of poisoning eases had been recognized. 
On Sept. 4, after considerable vomiting, he had collapsed 
while on a hop-picking machine. When first seen he was 
pale, nauseated, and vomiting. He collapsed in the doctor's 
office after complaining of cramps and abdominal pain. That 
same morning he had felt perfectly well. He was hospitalized 



and treated as a suspected food poisoning case even though 
there was no diarrhea. When his abdominal cramps became 
somewhat localized in the right lower quadrant and the 
white blood cell count was found to be elevated, he was 
seen by a surgical consultant and followed for possible ap- 
pendicitis. However, this consultant had attended one of the 
sisters who had been poisoned on the other farm. When he 
noted that the pupils were smaller than normal and only 
poorly reactive, even late in convalescence, he considered 
this to be another case of parathion poisoning. Earlier ob- 
servations on the size of the pupils had not been made. The 
patient recovered from marked weakness during four days in 
the hospital. 

Comment 

Mild poisonings have been caused in workers 
thinning, picking, cultivating, or irrigating crops of 
apples, pears, grapes, oranges, and hops treated 
with 1 lb. or more of parathion per acre. Several of 
the known instances of poisoning involved e.xposure 
to foliage or fruit sprayed not more than two days 
earlier. However, contact with pear trees, citrus 
trees, and grape vines caused poisoning as much as 
12, 17, and 33 days, respectively, after application 
of parathion. In general, the episodes of poisoning 
involving old residues are not so well documented 
as those involving residues not more than two days 
old. 

On the other hand, the episode occurring at De- 
lano, Cahf., in 1951, 33 days after the vineyard had 
been sprayed was thoroughly investigated, and the 
cause of illness was confirmed by low cholinsterase 
values and relief of symptoms by atropine. More- 
over, the causal relationship was further supported 
by the finding of a residue of 8 ppm of parathion on 
the leaves. That there might be considerable varia- 
tion from crop to crop as to the dangerous period 
after spraying is to be expected from the fact that 
there has been a similar difference between crops 
demonstrated in regards to the persistence of par- 
athion residues.'^ Though no half- life is reported 
for grape foliage, the above-reported residue of 8 
ppm 35 days after application is far greater than 
would be expected on most crops, and yet citrus 
fruit has been reported to retain parathion for a 
half-lifeof60to80days.'=' 

The physician who attended the men poisoned at 
Marysville, CaKf., in 1949, and other physicians 
have attributed the poisoning to parathion vapor 
and laid heavy emphasis on the respiratory route of 
exposure. The preoccupation with vapor is evident 
in several attempts to measure the respiratory ex- 
posure of workers." Considerable note was also 
made of the high temperatures to which poisoned 
workers have been exposed. 

Although it is true that the vapor pressure of 
technical parathion doubles with a rise of tempera- 
ture from 68 to 79 F, the vapor pressure even at 
103 F is only 1/x Hg, which is capable of producing 
at most a concentration of only 15 meg. per liter of 
air. It would seem most unlikely that workmen 
would be subjected to such saturated air for pro- 
longed periods if at all. On the other hand, all thin- 



3122 



ners and han-esters have extensive contact between 
the fruit and their hands and less extensive contact 
between their arms and other parts of their body 
and the foliage. 

In an attempt to measure such exposure Batche- 
lor " persuaded apple thinners to wear cotton 
gloves, respirators, and absorbent pads during their 
thinning operations. In general the recovery from 
gloves was several times as much as from the arms 
as calculated from the absorbent pads, and the re- 
cover)' from the respirators was below the sensitivity 
of the method. Batchelor and Walker " and Culver 
and co-workers '" have also shown that the skin is 
the principal route of absorption even during actual 
spraying or aerosol operations. Therefore, it seems 
reasonable to presume that dermal contact is more 
important than inhalation in explaining the ex- 
posures resulting in the poisonings described above. 
Apparently no one has succeeded in reasonably 
estimating the importance of the oral exposure re- 
sulting from eating, drinking, or smoking without 
washing the hands or from eating fruit while har- 
vesting. 

The role of temperature in the etiology of these 
outbreaks is apparently still undetermined. One 
might speculate that sweating in response to high 
temperatures produced a layer of moisture on the 
skin which made parathion adhere more easily and 
perhaps facilitated absorption of the compound. 
Certainly it was recognized that high temperatures 
and humid working conditions did cause some 
workers to remove their shirts and otherwise dis- 
regard protective clothing, thus increasing the area 
of skin exposed. However, occurrence of most of 
these outbreaks during hot weather may merely be 
a reflection of the fact that most crop operations 
from which the poisoning episodes ensued are 
normally carried out during the relatively warm 
summer months. 

In several of the earlier episodes the occurrence 
of light rains just prior to the outbreaks of poisoning 
caused some workers to believe that moisture on the 
recently sprayed foliage increased the amount of 
the residue that was transferred from the leaves 
onto the skin. The absence of such meteorological 
conditions before some other outbreaks certainly 
implies that, if it is a factor at all, rain or moisture 
on the crop is not essential to poisoning. 

One other exposure factor was contaminated 
clothing. Most of the laborers who do thinning and 
similar agricultural tasks wear their work clothing . 
for about a week or longer without laundering. The 
white dust and odor of parathion were noted on 
the clothing of many of those who became ill. Pro- 
longed wearing of contaminated clothes increases 
the likelihood of poisoning. 

One striking feature of the group of outbreaks 
described in this paper is the physical nature of the 
crops implicated thus far. All had foliage at least 
chest high. This may imply that workers are poi- 



soned in this way only when dusted or bathed in 
the dilute residues practically from head to foot. 
After seven years of using this insecticide, the lack 
of poisonings from residues deposited on much 
lower row crops appears significant. 

The clinical picture in this type of poisoning pro- 
duced only by residues on the foliage of plants 
was somewhat different from that in most cases 
produced by exposure during spraying or dusting. 
The chief diflFerence was one of relative mildness so 
that the onset tended to be more gradual and the 
entire course more benign. No doubt the relative 
mildness of this type of organic phosphate poisoning 
has caused many physicians to attribute such ill- 
nesses to causes other than the insecticides to which 
the crop workers were exposed. Because of the 
paucity of published reports of poisoning by resi- 
dues, physicians have heretofore tended to insist 
on a history of direct exposure to sprays, concen- 
trates, or dusts before giving serious consideration 
to a diagnosis of parathion poisoning. 

The epidemiologic picture of poisoning produced 
by residues differs strikingly from the picture of 
poisoning produced by exposure to concentrates, 
sprays, or dusts. In connection with residue poison- 
ing, it has frequently happened that a large pro- 
portion of the persons exposed became sick. In 
poisoning after direct exposure to formulations, 
it is unusual to have more than one or two cases 
among any group of workers. 

It is obvious that regulations and' recommenda- 
tions which have been promulgated to prevent oc- 
currence of such episodes are not only justified in 
purpose but probably need review, modification, 
and improved enforcement if such incidents are to 
be prevented. 

Summary 

Mild poisoning has followed exposure to residues 
of parathion on several kinds of crops (pears, 
grapes, hops, citrus fruits, and apples ) among agri- 
cultural workers engaged in picking, thinning, cul- 
tivating, and irrigating. The lack of a direct exposure 
history incidental to the application of parathion is 
not necessarily grounds for ruling out intoxication 
by this compound. The route of absorption of par- 
athion most likely to produce poisoning of this type 
appears to be dermal rather than respiratory. The 
relatively mild poisoning— frequently in groups— 
from exposure to parathion residues differs from 
the usually more severe cases— generally sporadic- 
resulting from direct application procedures. 

Addendum 

Since this article was submitted for publication 
one more incident has occurred which appears to 
be due to parathion residues. In VVenatchee, Wash., 
four cases of mild poisoning occurred on June 18, 
1957, in the same group of five people exposed in 
1954 (table 4) and two others. For about two 



3123 



weeks they had been thinning apple trees with resi- 
dues estimated to be two to five days olds. The most 
severely ill patient (case 1) in the 1954 outbreak 
had a similar but less severe symptom picture as in 
her prior experience. Her eyelids and those of 
three co-workers had twitched uncontrollably for 
two days prior to occurrence of faintness, nausea, 
vomiting, and difficulty in breathing. Her nephew's 
observation of pinpoint pupils in this patient is 
open to question, since this sign was never ob- 
served during her two-day hospitalization. How- 
ever, her blood cholinesterase activity about 48 
hours after onset was still at a level at which 
symptoms of poisoning might be expected to occur 
(0.26 A pH per hour for red blood cell count and 
0.23 A pH per hour for plasma). One other woman, 
who had not been thinning in the 1954 outbreak, 
had her onset about 18 hours later with a similar 
clinical picture. Both women were partiallv relieved 
of symptoms by single doses of atropine several 
hours after onset, but each had a recurrence of 
vomiting and other symptoms the following day. 
A third woman co-worker had twitching of the 
eyelids and "cold sweats" at nights for a period of 
several days as well as dizziness, weakness, and 
"weak stomach." A fourth co-worker had only 
twitching of the eyelids for about the same two-day 
period, as did his co-workers. In addition to the 
recognized dermal and respiratory exposures inci- 
dent to thinning the trees, one of the patients ( case 
1 ) used her teeth about twice a day to loosen the 
adhesive tape with which she protected her fingers 
from excessive friction. 
P. O. Box 73 (Dr. Quinby). 

References 

1. Kay, K., and others: Parathion Exposure and Cholines- 
terase Response of Quebec Apple Growers, A. M. A. Arch. 
Indust. Hyg. 6:252-262 ( Sept. ) 19.52. 

2. Leach, P. H.: Organic Phosphorus Poisoning in General 
Practice: Parathion, TEPP, HEPT, EPN, and others, Cali- 
fornia Med. 78s491-49.5 (June) 1953. 

3. Haller, H. L.: Hazards in Connection with Pesticide 
Use, Agr. Chem. I1j49-50, 128 (April) 1956. 



4. Experts Agree Pesticide Residues Needed, but Are They 
Harmful? Chem. Eng. News 3Oj1509-1511 (April) 1952. 

5. Lieben. J.; Waldman, R. K.; and Krause, L. ; Urinary 
Excretion of Paranitrophenol Following Exposure to Para- 
thion: Progress Report, A. M. A. Arch. Indust. Hyg. 7:93-98 
(Feb.) 1953. 

6. Schaefer, R. A., and Vance, G. M.; Exposure of Con- 
necticut Tobacco Workers to Parathion, A. M. A. Arch. In- 
dust. Hyg. 7:193-196 (March) 1953. 

7. Braid, P. E., and Dustan, G. G.: Parathion Residues 
on Immature Peaches and the Hazard in Spraying and 
Thinning Operations, J. Econ. Entomol. 48:44-46 ( Feb. ) 
1955. 

8. Braid, P. E.: Department of National Health and Wel- 
fare, Occupational Health Division, Ottawa, Canada, per- 
sonal communication to the authors. 

9. Bobb, M. L.: Parathion Residues on Peach Bark and 
Foliage, ]. Econ. Entomol. 47:190-191 (Feb.) 1954. 

9A. Michel, H. O.: Electrometric Method for Determina- 
tion of Red Blood Cell and Plasma Cholinesterase Activity, 
]. Lab. & Clin. Med. 34:1564-1568 (Nov.) 1949. 

10. Black, D. M.: Unpublished data on file in the Depart- 
ment of National Health and Welfare of Canada, personal 
commimication to the authors. 

11. Wolfsie, J. H., and Winter, G. D.: Bromothymol Blue 
Screening Test: Value for Determination of Blood Cholines- 
terase Activity, A. M. A. Arch. Indust. Hyg. »:396-401 
(May) 1954. 

12. Gunther, F. A., and Blinn, R. C: (a) Analysis of 
Insecticides and Acaricides: Treatise on Sampling, Isolation, 
and Determination Including Residue Methods, New York, 
Interscience Publishers, Inc., 1955, pp. 139-140. (fo) Per- 
sisting Insecticide Residues in Plant Materials, Ann. Rev. 
Entomol. 1:167-180, 1956. 

13. Griffiths, J. T.; Steams, C. R., Jr.; and Thompson, 
W. L.: Parathion Hazards Encountered Spraying Citrus in 
Florida, J. Econ. Entomol. 44:160-163 (April) 1951. Brown, 
H. v., and Bush, A. F. : Parathion Inhibition of Cholines- 
terase, Arch. Indust. Hyg. 1:633-636 (June) 1950. Steams, 
G. R., and Griffiths, J. T.; Parathion Contamination Hazards 
to Spray Labor, Florida Entomol. 35:143-146 (Dec.) 1952. 

14. Batchelor, G. S.: L'npublished data. 

15. Batchelor, G. S., and Walker, K. C: Health Hazards 
Involved in Use of Parathion in Fruit Orchards of North 
Central Washington, A. M. A. Arch. Indust. Hyg. 10:522- 
529 ( Dec. ) 1954. 

16. Culver, D.; Caplan, P.; and Batchelor, G. S.: Studies 
of Human Exposure During Aerosol Application of Mala- 
thion and Chlorthion, A. M. A. Arch. Indust. Health 13:37- 
50 (Jan.) 1956. 



3124 



Reyrinted From the Joumttt of the American Medtcnl AssociatU 

Aut:usi 3. 1964, Vol. Hi9, pp. 3S1-356 

Coityriuhl 1964, hv American Midical AiSoeiatior\ 



Parathion Residue Poisoning 
Among Orchard Workers 

Thomas H. Milby, MD, Fred Ottoboni. ChE. MPH, and 
Howard W. Mitchell, MD, MPH, Berkeley, Calif 



Following an outbreak of illness among 
peach harvesters, 186 peach orchard work- 
ers were studied in relation to pesticide 
application practices and fruit harvesting 
procedures representative of the orchards 
in which they worked. It was necessary 
first to establish a diagnosis of organic 
phosphate poisoning and then to associate 
observed illness with the intensity of para- 
thion application. Information obtained 
revealed that, although parathion could 
easily be recovered from all elements of 
the orchard environment, it was not pres- 
ent in amounts sufficient to account for the 
observed illness. This inconsistency sug- 
gested the presence in the spray residue 
of a compound evolved from parathion 
alteration which was considerably more 
toxic than parathion, but identifiable by 
routine analytical procedures only as para- 
thion. Paraoxon was considered a likely 
suspect and was postulated as a prime 
cause of the outbreak. 



HEALTH HAZARDS associated with the manu- 
facture, formulation, distribution, and appli- 
cation of the organic phosphate pesticide, para- 
thion, have been frequently described and will not 
be reviewed here. It has not been so clearly recog- 
nized, however, that for many days or weeks after 
application of parathion spray formulations to 
argicultural field crops, resulting residues may con- 
stitute an important health hazard to argricultural 
workers. 

In 1958, Quinby and Lemmon ' summarized II 
episodes of poisoning from contact with parathion 
residues involving a total of more than 70 workers 
who were involved in harvesting, thinning, culti- 
vating, and irrigating such crops as apples, grapes. 

From Ihe Burtau of Occupitioinl Hcilth, Califomlt State D«p«rt- 
mcnl of Public Health. 



citrus, and hops. Although six of the outbreaks oc- 
curred within two days of pesticide application, in 
the remainder of the episodes, the residues had 
been from 8 to 33 days old. In general, the illnesses 
were characterized by a gradual onset and a rela- 
tively benign clinical course. Percutaneous absorp- 
tion was thought to be the primary route of entry 
of the toxicant. 

Although we are aware of no other published re- 
ports describing poisoning liy organic phosphate 
residues, cases have occurred on a sporadic basis in 
California over the past several years and, in 1959, 
more than 275 cases of parathion residue poisoning 
were reported among workers harvesting citrus 
crops throughout the state." 

In early August, 1963, the California Department 
of Public Health was notified of an outbreak of 
parathion poisoning among orchard vNorkers who 
were harvesting peaches in the northern part of 
California's San Joaquin Valley. 

Description of Area and Workers 

The epidemic was centered around the town of 
Hughson in Stanislaus County. Several hundred 
peach orchards with a total of about 24,0()0 acres 
under cultivation are located in this major peach- 
growing area. For the annual harvest, during 
August and September, these orchards employ 7,- 
500 to 8,500 agricultural workers, most of whom 
are migrants. The orchards in this area grow a num- 
ber of varieties of peaches and because each variety 
of peach becomes ready for picking at a slightly 
different lime, the harvest season extends over a six 
to eight week period. As a result of this prolonged 
harvest period, a grower in the area is able to em- 
ploy a small crew, usually 15 to 25 workers, for the 
entire season. The pickers move from one variety to 
another and often from one grower to another as 
the fruit becomes ready for harvest. 

The harvesting of peaches has not been mecha- 
nized. Each piece of fruit must be picked from the 
tree by workers using ladders and chest-slung bas- 



3125 



kets or canves bags. In this process there is manual 
contact with all of the fniit and a great deal of con- 
tact between the upper half of the body and tree 
foliage. The picker's breathing zone is often closely 
surrounded by branches thick with leaves, affording- 
maximum opportunity for inhalation of pesticide 
residues rendered airboine by the picking process. 
The San Joaquin Valley s-immer heat, the con- 
stant use of ladders, and the pace induced by piece- 
work combine to make the job hot and uncomfor- 
table. As a result, clothing is light and often sweat 
impregnated. Shirts are open at the collar, and 
often shirt sleeves are short or rolled above the el- 
bow. 

General Study Plan 

The general study plan consisted of relating the 
worker's health to his occupational envuonment. 
During the course of the field work, three groups 
consisting of 186 peach orchard workers exposed 
to parathion residues were identified and studied. 
The first group was made up entirely of cases of 
poisoning reported by local physicans. These cases 
were selected to provide information on the clinical 
manifestations of the toxicant involved and also 
served to identify orchards with unsafe residue 
levels. A second group was comprised of workers 
employed in a sample of these unsafe orchards. 
Some of these workers had been poisoned and 
sought medical attention and some had not. This 
group was selected to provide information on the 
prevalence of clinical illness in these orchards as 
well as an estinsate of the prexalence of subclinical 
illness as reflected by depression of blood cho- 
linesterase levels. This group also provided subjects 
for environmental studies from which maximum 
daily assimilation of residue could be estimated. A 
third group was selected at random iii order to 
estimate the prevalence of cholinesterase depression 
in the universe of orchard workers employed in the 
Hughson peach-growing area. 

To study the relationship between pesticide appli- 
cation and the occurrence of reported clinical ill- 
ness, pesticide spraying schedules were collected 
from all growers in whose orchards illness had been 
reported. These schedules were then compared to a 
second group of schedules selected from orchards 
in which no illness had been reported. The second 
group of schedules v/as obtained from two large 
canneries and represented all of the fruit purchased 
in the epidemic area by these two firms. These 
schedules were readily av.nilahle because a copy 
of the grower's pesticide application schedule is re- 
quired by all fruit processors in California as a 
condition of purchase. Except for several schedules 
which were excluded for technical reasons such as 
incompleteness or illegibility, all were used for com- 
parison purposes. 

Finally, leaf and fiiiit si)ecLTici!S were collected 
from both orchard groups, those With associated ill- 



ness and those with no associated illness. These 
specimens were analyzed for residues in an attempt 
to relate residue levels to presence of i'lness. 

For the purpose of this paper, cholinesterase de- 
pression is defined as depletion ol cither red blood 
cell (true) cholinesterase or plasma (pseudo) 
choluiesterase, or both to a level belov.' the range 
of normal variation reported by \^'olfsie and Win- 
ter 'as: 

RBC: 0.53-1.21 pH units per hour. 
Plasma: 0.44—1.38 pH units per hour. 

All cholinesterase values were determined by the 
electrometric method of Michel ' as modified by 
Hamblin and Marchard.' All parathion analyses 
were canied out using the method of Averill and 
Norris.' However, because this method does not 
differentiate between parathion and its S-phenyl 
isomer, its S-ethyl isomer, or its oxygen analog 
(paraoxon), any value reported as parathion may 
reflect the presence of these other fonns. 

Results 

Group i.— The first group was made up of 94 
orchard v%'orkers who became clinically ill during 
the period betueen Aug 4 and Sept 1.5 and who 
sought medical care from local physicla.is because 
of the severity of their complaints. The figure shows 
these 94 cases as they appear when converted to a 
weekly attack rate based on the total picker work 
force.' The spread of cases with time generally co- 
incides with tlie period of peak peach harvest, 
which extended from July 28 to Sept 15, 1963. 

At the time of illness, cholinesterase levels were 
detemiined on bloovd collected from 68 of these 
cases and found to be depressed in 66 of them. The 
26 cases in which no cholinesterase levels were de- 
termined were consideied by the attending phy- 
sicians to be so tyi)ical of organic phosphate poison- 
ing that no laboratory verification of the clinical 
diagnosis v/as necessary. The most consistent com- 
plaints described by these clinically ill workers 
were nausea, vomiting, occipital headache, pro- 
found wcalcness, and extreme malaise. Other mani- 
festations of parasympathetic stimulation including 
miosis, blurred \'ision, dizziness, excessive sweating, 
salivation, dianhea, and abdominal cramping were 
reported, but not consistently so. It is noteworthy 
that several clear-cut cases failed to demonstrate 
miosis at any time during the course of illness. Al- 
though a number of patients were hospitalized for 
24 to 48 hours, symptomatic treatment with large, 
parenteral doses of atropine (1.2 to 2.4 mg) re- 
peated as necessary appeared to give satisfactory 
relief in every case. 

One death during the epidemic was attributed to 
parathion poisoning by a local pathologist. Al- 
though it was determined that the deceased had 
worked for no more tlian 1% days in an orchard 
from which one other case of clinical illness had 
been reported, his activities and erqiosure during 



3126 



several of the days immediately prior to his hos- 
pitali7ation covild not be traced. The clinical course 
of this fatal ilhiess is obscure, but it was reported 
that upon hospitalization seven days after known 
work exposure, both red blood cell and plasma 
cHolinesterase levels were depressed. Sixteen days 
after exposure, following nine days of hospitaliza- 
tion, the patient died. Cholinesterasc levels at the 
time of death were reported to be in the low- 
normal range. Postmortem examination led to a 
final diagnosis of "bilateral terminal bacterial pneu- 
monia" and "organic phosphate poisoning." 

Croup 2.— The second group consisted of 68 vol- 
unteers from a total work force of about 100 work- 
ers who were employed in six orchards from which 
clinically recognizable cases of organic phosphate 
poisoning were being reported. Among these 68 
volunteers were 62 pickers, 2 fruit graders, 2 or- 
chard owners, 1 labor contractor, and 1 cook. All 68 
were interviewed, and a blood specimen for cholin- 
esterasc determinatio.n was obtained from each of 
them. In addition, 14 volunteers from these six 
orchards were examined for skin parathion con- 
tamination. In the course of this procedure, various 
skin surfaces of measured area were scrubbed with 
alcohol-moistened cotton swabs which were then 
sent to the laborafor>' for analysis. To further evalu- 
ate skin exposure, a shirt was acquired from one 
worker who stated that it had not been laundered 
for eight days. The condition of the shirt bore out 
his claim. To estimate respiratory exposure to air- 
borne residues, breathing zone dust samples were 
collected on lapel-mounted filter paper air samplers 
and analyzed for parathion. Tlic results of the 
analysis of these ennronmental samples will be de- 
scribed later in this paper. 

From Table 1, it can be seen that 8i% of the 68 
volunteers in this group showed evidence of signifi- 
cant organic phosphate absorption reflected by de- 
pression of blood cholinesterase levels. Moreover, 
from this table it is clear that once an individual 
becomes sufficiently ill to seek medical care, his 
cholinesterase levels are veiy likely to be depressed. 
However, it is equally as clear that cholinesterase 
depression, in itself, is not always accompanied by 
symptomatic illness, even of a mild degree. 

It is of interest to note that of the six volunteers 
who were not employed as pickers, none had sought 
medical care, and five were as)'mptomatic with 
normal cholinesterase 'evels. Only one, the labor 
contractor, was placed in a category indicating both 
complaints and cholinesterasc depression. 

Croup 3.— In order to arrive at some estimate of 
the prevalence of cholinesterase depression among 
peach pickers in the epidemic area, 45 workers re- 
siding in seven groups of living units were studied. 
The living units consisted of trailer parks, labor 
camps, and motels and were selected only on the 
basis of proximity to the liarvest area. The workers 
were interviewed and blood samples were obtained 



E 



7/28 ^4 8/11 8/18 8/25 9/1 
WEEK BEGINNING 



9/8 9/1 5 



Clinical allacic rate per 1000 pkkeri by weak. 

from each of them. Only individuals who were 
actively engaged in peach picking were included in 
the study group. None reported working in or- 
chards with which clinical illness had been as- 
sociated, nor had any of them sought medical at- 
tention during the peach harvesting period. Sixteen, 
however, complained of minor signs and symptoms, 
including nausea, vomiting, headache, dizziness, 
weakness, insomnia, and anorexia, which several 
thought referable to their work. As shown in Table 
2, 35? of these 45 orchard workers had absorbed a 
significant amount of organic phosphate pesticide 
as reflected by depression of blood cholinesterase 
levels. Table 2 also relates cholinesterase levels to 
presence and extent of clinical illness. In this group, 
as in the second group, it is clear that a worker may 
be asymptomatic e\'en though his blood cholinester- 
ase is significantly depleted. 

The status of the cholinesterase levels of the 
entire population of several thousand pickers can- 
not be realistically ex-trapolated from these 45 cases. 
However, the prevalence of cholinesterase depres- 
sion in this small sample suggests that the problem 
of significant parathion residue absorption extended 
bejoiid the few score cases reported by physicians 
or discovered by study of a highly selected group 
of pickers working in orchards from which illness 
had been reported. 

Pesticide Spraying Schedules.— In all orchards 
studied, parathion was applied in the fonn of 25% 
wettable powder in water suspension. Essentially all 
spraying wai done by tractor-drawn spray blowers. 
Schedules varied from one to seven applications 
over the growing seasons at rates of one to two 
pounds of parathion per acre at each application. 
Tlie frequency and rate of pesticide application de- 
pended largely upon the degree to which the or- 
chard owner felt his crop was threatened by insect 
predators. 

Pesticide spraying schedules from 16 illness-pro- 
ducing orchards were compared to pesticide spray- ' 
ing schedules from 43 no-illness orchards. This com- 



3127 



Table 1.— Cholinesterase Levels by Extent of Illness 
Among 68 Workers From Six Illness-Producing Orchards 



Extent of Illness 


No. of 
Workers 
Sampled 


% With 

Depressed 

Ct>ollnesterase 


Clinical poisoning by 
physician dragnosis 


21 




95 


Complaints but no 

medical care sought 


14 




86 




33 




76 


Total Chcs 


68 




84 



parison indicated that the only cholinesterase in- 
hibiting compound used in every illness-producing 
orchard uas parathion. However, it was apparent 
that application of parathion, in itself, was not the 
determining factor in the causation of illness be- 
cause 40 of the 43 orchards without associated ill- 
ness also applied it. Organic phosphate pesticides 
other than paiathion were used only irregularly, 
and therefore, their effect in the causation of the 
epidemic could not be assessed. 

The important differences between the orchards 
with associated clinical illness and those with no 
associated illness appeared to be related to total 
liarathion application and to the time interval be- 
tween the last application and the start of harvest. 
The 40 parathion-using orchards with no associated 
clinical illness applied a mean parathion dosage of 
4.38 pounds per acre for the season and waited a 
mean intcr\al of 45 days between the last applica- 
tion of parathion and the start of harvest. Com- 
parable means from the 16 orchards with associated 
clinical illness were 7.14 pounds and 23 days. Thus, 
the orchards w ithout illness applied less total para- 
thion per acre and waited longer between the last 
application and harvest. While this infonnation is of 
interest, it is not really useful as time and dosage 
have an uncertain effect on residue Ie\els at harvest 
aiid both vary in this particular comparison. 

The interval between the final parathion applica- 
tion and the first day of harvest ( the spraying-pick- 
ing interval) was eliminated as a variable by match- 
ing the group of illness-producing orchards and 
a group of no-illness orchards with comparable 
mean intervals. This was accomplished by eliminat- 
ing all of the orchards in the no-illness group with a 
spraying-picking interval of more than 40 days. The 
final matched groups consisted of 16 illness-pro- 
ducing orchards with a mean interval of 22.9 (stan- 
dard deviation 7.7 ) days and 26 no-illness orchards 
with a mean inter\al of 22.4 (standard deviation 
6-1) days. 

Table 2.— Cholinesterase Levels by Extent of Illness 

Among 45 Peach Pickers From Miscellaneous 

Camps. Motels, and Trailer Parks 

No. of % With 

Workers Depressed 

Eitent of lllne<> Sampled Cholinesterata 

Clinical poisoning by . « 

physician dugnosis 

Complaints but no 

medical care sought 16 iS 

Asymptomatic 29 ♦! 

Total Casai «S 3» 



Table 3 compares the mean parathion dosages for 
these two matched groups of orchards Note that 
the total dose for the season after Jan 1 was signifi- 
cantly higher in the orchards from which clinical 
illness had been reported. The dosage applied after 
July 1, 1963, however, does not show a significant 
difference between the two groups of orchards. It 
was not possible to make a similar compari:.on 
(holding dosage constant) to determine the effect 
of the spraying-picking interval on illness because 
matching groups could not be constructed from 
the data available. 

Parathion Residues and Total Worker Dose.-Fo- 
liage specimens were collected from 11 orchards, 
six with associated illness and five with no associ- 
ated illness. Leaves from the former group of or- 
chards were obtained within three days of the onset 
of clinical illness among employees and leaves 
from the latter group of orchards were collected at 
random during the harvest period. Residues were 
removed by surface stripping with benzene and 
analyzed for parathion. The mean parathion con- 
tent of the foliage from the six illness-producing 

Table 3.— Comparison of Matched Groups of 
Orchards by Parathion Dosage 









Signifi- 








cance of 




Mean Dose, 




Difference 


Time Interval and 


Pounds/ 


Standard 


by -t" 


Orchard Group 


Acre 


Deviation 


Test 


After July 1. 1963 








Orchards wtth illness 


. 2.24 


1.10 


Not sig- 


Orchards without illness 


1.78 


0.81 


nificent 


After Jan 1. 1963 








Orchards with illness 


7.14 


2.60 


0.01 


Orchards without illness 


499 


1.95 





orchards was 4.4 parts per million by weight 
(PPM) with a range of 1.0 to 7.2 PPM. The mean 
parathion content of the foliage from the five no- 
illness orchards was 1.9 PPM with a range of 0.9 
to 3.6 PPM. \Miile these figures suggest that illness 
is more likely to be associated with higher para- 
thion residues levels, the considerable overlap be- 
tween the two orchard groups rendered impractical 
any attempt to use residue levels as an indicator of 
worker risk. 

Fruit samples were collected from five of the 
above orchards, three of which had produced clini- 
cal illness and two of which had not. Results of the 
analysis of these samples for parathion content 
ranged from 0.02 PPM to 0.5 PPM parathion by 
weight No le\els were found which exceeded the 
permissible tolerance for peaches of 1.0 PPM. 
(US Department of Health, Education, and Wel- 
fare, Food and Drug Administration, Federal In- 
secticide, Fungicide and Rodenticide Act [1947] 
and Miller Pesticide Residue Amendment [1954] to 
the Federal Food Drug and Cosmetic Act of 1938. ) 

Variations in weather are known to exert a com- 
plex effect on parathion degradation rates and 
resulting residue levels. However, in this study 



36-513 O - 70 - pt. 6A - 9 



3128 



Table 4.— Parathion Contamination of Pickers From 
Orchards That Produced Clinical Illness 

Paralhlon. ug par 

par square Inch of 

•kin Burface 

No. of Ob-, * , 

Datcrlption of Sample tarvatlons Range Mean 

Palm of hand. lOrters 3 204 7 3.4 

Palm of hand, pickers 5 05 7 2.8 

Forearm, pickers 3 4 4.7 2.0 

Upper arm. pickers 2 0.2-1.4 0.8 

Back of neck, pickers 3 0-1.4 0.5 

One shirt, worn eight days: total parathion— 960;ig 

ue.itlier was not a \aiiable because all of the or- 
chards in the small peach-growing area were neces- 
sarily subjected to essentially identical weather 
conditions. 

Table 4 lists residues found on the shirt of 1 and 
on the skin of 14 pickers working in orchards that 
produced nia.\imum rates of clinical illness. These 
data confirm the presence of parathion on the arms 
and tnink as well as on the palms of hands and 
suggest that contact with lca\Ci and tree surfaces 
contribute to total exposure. Because of limitations 
of the alcohol swab sampling technique, the values 
for skin contamination are probably about 10% 
low." Breathing zone air samples from these same 
orchards were collected on filter paper and ana- 
lyzed for parathion. Tlie highest value obtained by 
this method was 35 /ig of parathion per cubic meter 
of air. According to Durham and Wolfe ' these 
.alues may be 10% to 15% low due to evaporation 
of parathion into the airstream passing through the 
filter. Airborne parathion vapor e.xposure was not 
measured but estimated as zero, based on istudies 
by others.' 

Table 5 details an estimate of the maximum 
fruit, skin, and air exposure to parathion which 
could be encountered by a picker. These are maxi- 
mum values based on measurements obtained from 
the two orchards which had produced the highest 
rates of clinical illness. 

Although the total daily dose of paratliion ab- 
sorbed through the skin cannot be precisely deter- 
mined, work by Durham and Wolfe ' suggests that 
parathion is slowly and inefficiently absorbed and 
that residues found on the skin constitute many 
times the quantity which will be absorbed in eight 
hours. Likewise, the quantity found on a shirt is 
more than would be absorbed in a single day. 
Thus, the maximum quantity of parathion absorbed 
tluough the skin of the in lividuals studied was 
probably less than 3,000;ig per day and the maxi- 
mum total dose by all routes was less than about 
4,000/ig per day. 

Comment 

From the very beginning of the epidemic, local 
physicians had implicated parathion as the caus- 
ative agent. Their reasoning was based on ob- 
servation of the clinical syndrome and on some 
knowledge of the spraying practices prevalent in 



Tatjie 5.— Daily Maximum Exposure Which Could be 

Encountered by a Picker by Sources 

of Agent and Routes of Entry 

Route of Entry and Source of Exposure Parathion, 

ft 
Ingestion 

4 peachers per day with residue level of 

0.5 PPM by weight 500 

Inhalation 

Airborne dust, based on highest breathing zona 

value of 35 ^g/cu m and breathing rate of 

10 cu m/day 350 

Airborne vapor, estimated negligible 

Dermal" 

Palms of two hands about 63 square inches 

total and 7ug per square inch maximum 440 

Backs of hands, forearms, and face about 

351 square inches total and 4.7Mg per square 

inch maximum , 1660 

Back of neck and "V of neck about 40 square 

Inches and 1.4(ig per square inch maximum... 56 

Upper arms and remainder of trunk 

based on shirt 960 

Lower limbs assumed negligible because contact 

with foliage minimal 

Total dermal exposure <3000 

Total exposure all routes <4000 

'Surface areas determined using Berkow's method as'quoted by 
Durham et al.« 

surrounding orchards. Our evaluation of spraying 
schedules indicated that parathion was the only 
organic phosphate applied in every illness-produc- 
ing orchard and supported their contention. The 
slight variance of the clinical picture of poisoning 
described here from the classical syndrome of in- 
tense parasympathetic stimulation seen in cases of 
poisoning among workers exposed to sprays or con- 
centrates is almost certainly related to the insidious 
manner in which the poison was assimilated. Thus, 
the slow rate of absorption produced a gradual but 
progressive depiction of blood cholinesterasc ele- 
ments until, at a critical level, mild to moderately 
severe clinical illness became apparent. 

Careful environmental sampling revealed that 
although parathion could be recovered and identi- 
fied without much difficulty, the maximum daily 
dose with \<hich a worker could come into contact 
was not in excess of 4 mg. Because this quantity of 
parathion, even if completely absorbed, constitutes 
only about one-half of the daily dose reported to 
be capable of producing progressive cholinesterase 
depletion,'" the presence in the orchard environ- 
ment of one or more compounds, derived from 
parathion, but considerably more toxic is hypothe- 
sized. The presence of such a compound could be 
the result of contamination of the original spray 
material (unl'kely) or the product of parathion 
aging, weathering, plant alteration, or other form 
of degradation. The most likely suspect is the 
o.xygen analog of parathion, paraoxon, a cholines- 
terase inhibiting compound with cutaneous toxicity 
ten times that of parathion." (Routine analytical 
capacity for the determination of paraoxon was' not 
available at the time of the study. One leaf residue 
sample analyzed for parao.xon indicated the pres- 
ence of 3.0 PPM paraoxon and 2.8 PPM paratliion.) 
Also to be considered are the S-phenyl and S-ethyl 



3129 



isomers of paratliion. Both of these isomers and the 
analog are potent, direct, in vitro inhibitors of 
cholinesferase. (Extrapolation from parathion tox- 
icity suggests that absorption of as little as 2 mg 
per day of paraoxon would be sufficient to produce 
progressive cholinesferase depletion.) Cook and 
Pugh " reported the presence of these three com- 
pounds plus an unidentified "light product" in a 
sample of parathion irradiated with ultraviolet light 
under laboratory conditions. Although they did not 
identify this "light product," they reasoned that its 
cholinesferase inhibiting properties were at least as 
potent as paraoxon. 

Available information "'" has indicated that 
parathion disappears in a rapid and continuous 
manner and has suggested that multiple spra>ings 
applied over a six-month period should not result 
in residue accumulation. This concept would fend 
to implicate the final spray application closest to 
hars'esf in the causation of residue poisoning. How- 
ever, our data cannot support this concept for the 
following reasons: (1) In no orchard studied, re- 
References 



gardless of illness experience, did the final para- 
thion application exceed the recommended rate of 
2.5 pounds per acre followed by a 14-day interval 
between spraying and harvest." (2) Analysis ot 
data previously presented here can detect no sig- 
nificant difference between matched orchard groups 
when compared by amount of parathion applied 
during the five weeks preceding the outbreak de- 
scribed. Such differences appear only when earlier 
applications are included in the analyses. These 
findings suggest that the observed illnesses were 
the result of residue accumulation related to total 
amount of parathion applied during the entire 
growing season. It should be noted that the rela- 
tive contribution to the total leaf residue levels of 
the winter, spring, or early summer parathion ap- 
plications is not known. Likewise, while the last 
spraying was not the deciding factor in the causa- 
tion of illness, it certainly contributed by adding to 
the already present foliage residues. 
2151 Berkeley Way, Berkeley, Calii (Dr. Milby). 



1. Quinby, G.E., and Lemmon, A.B.: Parathion Residues 
as Cause of Poisoning in Crop Workers, JAMA 1GG:740, 
1958. 

2. Doctor's First Rciwrt of Work Injury, State of Cali- 
fornia, Division of Labor Statistics and Research, 1959. 

3. Wolfsie, J.H., and Winter, CD.: Statistical Analysis 
of Normal Human Red Blood Cell and Plasma Choline- 
sterase Activity Values, Arch Eniiron Health (Chicago) 
6:43, 1952. 

4. Michel, H.O.: Electrometric Method for Determination 
of Red Blood Cell and Plasma Cholinesferase Activity, ] 
LahCtin .\fc(i 34.1564, 1949. 

5. Hamblin, D.O., and Marchard, H.F.: Cholincsterase 
Tests and Their Applicability in Field, New York: Ameri- 
can Cyanamid Co, 1951. 

6. Avercll, PR., and Norris, M.V.: Estimation of Small 
Amounts of 0,0-Diclhvl 0,0-Nitrophenyl Thiophosphate, 
Analyt Chem 20;753, 1948. 

7. Weekly Farm Labor Report, No. 922-930, State of 
California, Department of Employment, 1963. 

8. Durham, W.F., and Wolfe, H.R.: Measurement of 
Exposure of Workers to Pesticides, Bull WHO 26:75, 1962. 

0. Parathion Vapor Concentrations in Atmosphere of 



California Groves During and After Application, New York: 
American Cyanamid Company, 1951. 

10. Hayes, W.J., Jr.: Clinical Handbook on Economic 
Poisons, Emergency Information for Treating Poisoning, 
US Dcpt of Health, Education and Welf:ire, 1963. 

11. Metcalf, R.L.: Organic Insecticides. Their Chemistry 
and Mode of Action, New York: Interscience Publiiliers, 
Inc, 1955. 

12. Cook. J.W., and PuRh, N.D.: Quantitative Study of 
Cholinesferase Inhibiting Decomposition Products of Para- 
thion Formed by Ultraviolet Light, J Assoc Agric Cliim 
40:277, 1957. 

13. Culver, D., et al: Study of Exposure to Parathion 
in Greenhouse, Arch Environ Health (Chicago) 18:235, 
1958. 

14. Fahcy, J.E.. H.innlton, D.W.; and Rings, R.W.: 
Longevity of Parathion and Related Insecticides in Spray 
Residues, / Econ Entimiol 4.>:7U<). 1952. 

15. Brunson, M.ll.; Koblitsky, L ; and Chisholm, R.D.: 
Effectiveness and Persistence of Insecticides Applied During 
Summer MonOis to Control Oriental Fruit Moth on Peach, 
; Econ Entomol 55:728. 1962. 

16. Manual of Manufacturing Information for Thiophos 
Parathion, New York: Anierican Cyanamid Company, 1958. 



3130 

ATr. Jonxsox. Under the Pesticide Chemicals Amendment to the 
Federal Food, Dni«r, and Cosmetic Act, pesticides which are not 
fjenerally reco<rnized as safe by qualified experts may not be present 
in or on raw a<rricnltural commodities for food use unless a safe tol- 
erance, which may even be zero, lias been established by FDA, 

The primary responsibility for obtaininjr proof of safety of resi- 
due tolerances is ])laced on tlie industry or firm promoting; the use of 
pesticide chemicals. The FDA is responsible for the scientific judp;- 
ment concernin<r the safety of the tolerance. As of July 1, 1968, 
there were 3,115 tolerances or exemptions established on 175 pesti- 
cide chemicals. Xew pesticide chemicals, formulations, and other 
methods of insect control are constantly bein^ developed. New toler- 
ances are required, and existinfr tolerances must be reviewed in terms 
of current agricultural practice and need, in keeping; with the policy 
that tolerances should not be higher than necessary for safe and 
effective use. 

For example, FDA has recently published an order to reduce 
DDT tolerances. This action was initiated by a findin<j that jrood ag- 
ricultural practices would permit lower tolerances. In fact, analysis 
of a lar<re number of samples over the past several years showed 
that the level of DDT found on most fruits and vefretables is far 
below the 7-p.p.m, tolerance for that pesticide. Some other tolerances 
have also been reduced. The intent is to establish tolerances no 
hijrher than needed in current jjood agricultural practices. 

Senator Moxdale. That sentence perplexes me a little bit. Is the 
purpose of your effort to protect first of all the health of the Ameri- 
can people, or to do so insofar as consistent with good agricultural 
practice ? 

Mr. Jonxsox. It is two-fold, Mr. Chairman. 

First of all, all of our tolerances are, in our judgment, safe for 
purposes of human consumption. This is a first criteria. Then, not- 
withstanding this, we still keep them as low as practical and feasible 
in accordance with good agricultural practice. 

Senator Moxdale. So it is not your policy to say: "Well, this pes- 
ticide is carried to the consumer. It is dangerous, but if we are 
going to kill tlie bug that that pesticide is directed at, the farmers 
may nevertheless continue to use it." 

Mr. Jonxsox. Absolutely not. Actually, with regard to the basis 
whereby we set tolerances, we know what has been accepted through- 
out the world by the Food and Agriculture Organization of the IJN 
as to what is the normal total body uptake of pesticides of various 
types. That is our takeoff' jmint. It is the best judgment that we 
have. 

We keep everything in terms of total diet studies within the con- 
fines of these recommendations. 

The Food and Drug Administration carries out other activities of 
control and investigation with respect to pesticides. There are sur- 
veillance activities to determine compliance with tolerances and 
.sanctioned uses, which includes inspectional investigations in the 
growing fields and the analysis of preharvest and postharvest sam- 
ples. There are information and educational activities to keep the 
grower and cooperating State officials knowledgeable of our findings, 
both good and bad. This assists the grower in avoiding shipments of 



3131 

foods with illegal residues. There are control activities to remove 
hazardous foods from consumption channels through State and Fed- 
eral legal actions. Furthermore, there are total-diet investigations, 
which are used as an index to the dietary intake of pesticide resi- 
dues, and community epidemiological and ecological studies. 

FDA has a primate research laboratory at Perrine, Fla. Here the 
long- and short-term toxicology and biochemistry of pesticides and 
related chemicals are studied in primates, and the results of these 
studies are used in assessing hazards to man from environmental ex- 
posure to these chemicals. 

Investigations bearing specifically and directly on the hazards of 
pesticides to agricultural workers and others associated with the 
handling and application of pesticidies are conducted by the We- 
natchee. Wash., research laboratory of FDA's Division of Pesticides 
and the Division of Community Studies located in Atlanta, Ga. 

]\Ir. Chairman, there are currently 15 community studies in prog- 
ress under State health departments and universities. I have a sum- 
mary of these to submit for the record, if you so desire. 

Senator Mondale. If you would, please. 

(The information referred to follow :) 

Department of Health, Education, and Welfare, 

Public Health Service, 
Consumer Protection and Environmental Health Service, 

Washington, D.C., July 30, 1969. 
Hon. Walter F. Mondale, 
Chairman, Subcommittee on Migrator}/ Labor, 
Catnmittec on Labor and Public Welfare, 
U.S. Senate, 
Washington, D.C. 

Dear Senator Mondale : This is in reply to your letter of June 24, 1969, and 
the telephone comnmnication from Mrs. Marsha Carlin of your ofHce [Editor's 
note : Miss Carlin was employed by the Legislative Reference Service, Library of 
Congress.] to Dr. S. W. Simmons of the Division of Community Studies, Office of 
Product Safety, Food and Drug Administration. 

These communications request a report about research projects underway 
which concern pesticides and their effects on farmworkers. 

A list of research projects being conducted by the Division of Community 
Studies is enclosed, which includes the start-up date and a brief description of 
each project subject matter. There are a total of 15 projects, all operating 
under contract, 9 with State Deparments of Health and 6 with universities. 
Some of the universities holding contracts have subcontracts with State De- 
partments of Health and some of the State Departments of Health holding 
contracts, subcontract certain specialty work to university medical schools. 

A completion date for these projects has not been set as there is no before- 
hand way of knowing what, if any, is the long term effect of continuous low 
level exposure of pesticides on the health of people. The only way that this 
can be determined is to study people intensively over a long period of time. At 
present, some 1,500 people are under study, including both occupationally ex- 
posed and control groups. The duration of these studies will be determined by 
a careful evaluation of the data as the work progresses. All project contracts 
are reviewed and negotiated annually to insure that the work has continued 
significance and that meaningful results are being obtained. 

Enclosed with this letter are reprints reporting information obtained from 
community studies projects. Three reprints are grouped under "Morbidity and 
Mortality from Pesticides," and four under "Effects of Pesticides on Farmers 
and Migrant Workers." A number of other research publications containing in- 
formation on the effect of pesticides on man and the detection and determina- 
tion of pesticide residues are also enclosed. 

All of the Community Studies, with the exception of the New Jersey Study, 
include a considerable number of study subjects who are associated with agri- 



3132 

culture. In the southwest, west, and to some extent in Florida, Latin American 
workers are included in some of the study groups and migrant workers are in- 
volved in studies of acute cases of poisoning by pesticides. Since it is the in- 
tent of these studies to ob.serve each subject for a number of years, the 
mobility of migrant farmworkers presents extreme difficulty for long term ob- 
.servation. The selection of study .subjects is based on an expectation that the 
person will reside in a given area for a long period. 

If you have any questions regarding this information or if we may be of 
further assistance, please do not hesitate to call. 
Sincerely yours, 

Charles C. Johnsox, Jr., 
Assistant Surgeon General Administrator. 

[Enclosures] 



CoNtMUxiTY Studies Projects Under State Health Departments 
AND Universities 

1. The Arizona Community Study is comparing pesticide exposure level.«i. 
blood pesticide concentrations, and clinical characteristics (physical and biolog- 
ical) in tive urban families and in live rural families in Pima and Mari- 
copa Counties. The latter resides in an area intensely sprayed in the summer 
months. A close surveillance is also maintained on aerial spray pilots and 
loaders with reference to total DDT blood levels as well as cholinesterase lev- 
els. The surveillance of this group of workers is being conducted since it ap- 
pears that pilots and particularly loaders sustain the highest exposure to cholin- 
e.sterase-inhibiting compounds and also represent the highest DDT exposure. 
The study is done under contract by the University of Arizona, Tucson, Ari- 
zona, and was started in May. 106.". 

2. In California, a study of blood dyscrasias in a sample of the population 
regularly exposed to lindane is in progress. Al.so this project is studying tlie 
cau.sal relationship between seasonal neonatal jaundice in the Imperial Valley 
and the use of cotton defoliants. This study is supported by contract with the 
California Department of Public Health, Berkeley, California, and was started 
in May 1965. 

3. In "Weld County. Colorado, location of the Colorado Community Study, a 
multiple regression study is being made to determine the source of families' 
pesticide exposure. Potential sources are evaluated which include house dust, 
soil. food, water, and drift from treated fields. The.se family units are luider 
continuous medical and biochemical surveillance. Another study involves occu- 
pationally exposed persons, including pilots and groinul crews of aerial spray 
companies and personnel employed in the manufacture and processing of i)esti- 
cides. This work is carried out inider a subcontract with the ITniversity of Col- 
orado Medical Center. Denver. Colorado. This project is supported by contract 
with Colorado Department of Health, Greelev, Colorado, and was started April 
1965. 

4. The Florida Study is continuing a state-wide program designed to main- 
tain liaison with all licen.sed pesticide workers — even after they have left the 
industry. This is l»eing done in an effort to determine the health status of 
the.se people over a period of years. The Dade County area of Florida — due to 
tlie extensive use of large am<mnts of organic phosphorus in.secticide.s — has a 
munber of imisonings from these compounds. The P"'lorida proj(K't sttidies bio- 
chemical and j)hysiological changes in ixiisoning cases and also considers im- 
Itroved patient management and therajty. A contract with the P^lorida Board of 
Health sui)ports this work, started in .Tiuiuary VMtit. 

5. The Hawaii Community Study supported by contract with the University 
of Hawaii. Honolulu, is conducting an island-wide survey of tlie jiossible rela- 
tionship lietween maximal daily hoiisehold pesticide use and certain chronic 
respiratory di.seases. In addition, a study is presently being conducted on the 
relationship of pesticides to cardiovascular disease, asthma, bronchitis, and 
sinusitis. This is carried out in cooperaton with the Hawaiian NIII Cardiovas- 
cular Study and the Hawaii Department of Health. University of Hawaii con- 
tract was started in May 1965. 

6. A contract with the Idaho Department of Health supports the Idaho 
project which is centered in an area where pe.sticides are applied in large 



3133 

amounts over a comparatively short growing season. Research at this project 
includes close surveillance of exposed persons — especially people who reside in 
close proximity to heavily treated areas. This contract project was started in 
May 1967. 

7. The Iowa Community Study is seeking a possible causal relationship be- 
tween pesticide exi)osure and prolonged recovery time of pesticide-exposed sur- 
gical patients who have received the muscle relaxant, succinylcholine. Other 
studies underway deal with man's exposure to pesticides through his food 
chain. This involves investigating the study of the metabolism and storage of 
pesticides by animals used for food by man. These studies are carried out 
under contract by the Institute of Agricultural Medicine, University of Iowa, 
College of Medicine and a subcontract with the Veterinary Diagnostic Labora- 
tory, Iowa State University. The contract started in December 1965. 

8. The Louisiana Study is concerned with agricultural workers and family 
units in southeastern Louisiana and pest control operators in New Orleans. At 
all community studies, emphasis is placed on the study of population segments 
receiving heavy exposure to pesticides and on long-term surveillance. Also, 
each study is involved in the development of ecological data on the movement 
of pesticides in the environment of their respective area. Clinical and biochem- 
ical studies of exposed persons are conducted under contract with the Louisi- 
ana State University Medical Center and a subcontract with the Louisiana 
State Department of Health. This contract started in June 1967. 

9. In Michigan, a study is conducted through contract with the Michigan De- 
partment of Public Health and a subcontract with Michigan State University. 
Five occupationally exposed groups of workers are under medical and biochem- 
ical surveillance. These include fruit growers, truck farmers, commercial appli- 
cators, dairy farmers, and urban dwellers. These groups are believed to repre- 
sent a spectrum of the pesticide exposure. This contract started in February 
1965. 

10. The Mississippi Study is supported by contract with the Mississippi 
State University, analytical work is conducted at the laboratories at Starkville 
and epidemiological and clinical studies are carried out in the Greenville area 
in conjunction with pesticide research at MSU's Delta Experiment Station. In- 
tensive medical study of selected occupationally exposed persons is provided by 
subcontract with the University of Mississippi Medical Center, Jackson, Missis- 
sippi. In addition to the studies of occupationally exposed workers, the Missis- 
siijpi Study maintains a close surveillance on pilots of spray planes, since 25 
percent of all U.S. fatal spray plane crashes in 1964-1966 occurred within the 
area of the Mississipi Delta. This contract started in June 1967. 

All community study projects investigate crashes of planes engaged in the 
application of pesticides. This is carried out under an agreement with the Bu- 
reau of Aviation Safety and the Federal Aviation Administration of the De- 
partment of Transportation. 

11. The New Jersey Community Study is located in the highly industrialized 
area of Trenton. There, intensive surveillance is maintained of persons in- 
volved in the manufacture and formulation of pesticides. This effort is 
supported by contract with the New Jersey Department of Health, started in 
March 1965. 

12. The South Carolina Study closely follows the employees of pesticide for- 
mulating and manufacturing plants in the Charleston area in addition to the 
study of farm families and persons involved in the application of pesticides. 
The work is conducted by the Medical College of South Carolina, Charleston. 
iHider contract. Analytical chemistry is provided under subcontract by the 
South Carolina Department of Health. This contract was started in June 1967. 

13. The Texas Study, conducted imder contract with the Texas Department 
of Health, is situated in the agricultural area in the southern tip of the State 
where warm temperatures and modern irrigation practices permit an unusually 
long growing season. Massive amounts of insectivides, herbicides, and defol- 
iants are applied by aerial sprayers and ground applicators. Numerous persons 
are occupationally exposed, and acute illness frequently occurs as a result of 
accidental exposure. These illnesses are investigated by personnel from the 
Study Team ; exposed persons are kept under biochemical, medical, and physio- 
logical surveillance and hospitalized when necessary. This contract was 
started in April 1965. 

14. The Utah Study, located at Salt Lake City, provides for regular medical 
and biochemical surveillance of occupationally exposed workers who apply pes- 



3134 

ticides to the extensive marshy hike beds characteristic of the Great Salt Lake 
Basin area. It is also proposed tliat water, tish, and muck in watershed areas 
be analyzed. This is accomplished by contract with the Utah Department of 
Health, Salt Lake City, Utah, started in June liRiT. 

15. The Washington State Community Study is in the center of the fruit- 
growing region. The study involves the effect of spraying operations on or- 
chardists and people living adjacent to fruit orchards. Also, the Washington 
project is re-examining approximately 1,000 people who had prolonged occupa- 
tional exposure to lead arsenate and were originally studied by Dr. I'aul Neal 
of the National In.stitutes of Health in 1!)3S. The study is carried out under 
contract by the Washington Department of Health. The contract was started 
in March 1965. 



(A list of publications of the i>esticides program of the National Communicable 
Disease Center accompanied by Charles C. Johnson's commuinication is available 
through the Public Health Service of the Department of Health, Education, and 
Welfare.) 

Mr. JoHXSox. These studies consist of epidemiological and ecolog- 
ical investigations in areas of heavy pesticide usage throughout the 
United States. Within each study area a pesticide-usage profile is de- 
veloped. Concurrently, levels of pesticides and their metabolites in 
man and the environment are determined. These data should eventu- 
ally provide information on the movement of pesticides in the envi- 
ronment and their routes of entry into man. 

Basically, each study consists of compiling the medical history of 
about 100 volunteers selected because their occupations or their envi- 
ronment subject them to greater exposure to pesticides than the pop- 
ulation at large. A group of individuals with minimal pesticide ex- 
posure are selected to serve as controls for comparison purposes. 

These investigations include the direct measure of exposure of 
workers by methods such as attaching absorbent patches on the skin 
of spraymen during actual s]:)ray operations. Measurement of this 
sort and/or respiratory inhalation have been carried out for a num- 
ber of i)esticides and for workers doing various agricultural jobs as- 
sociated with spraying or dusting operations. 

Senator Moxdale. AVould those studies extend as well to the work- 
ers in the field? 

Mr. Joiixsox. They extend to workers in the field, Mr. Chairman, 
I might add. 

Senator Moxdale. You say jobs associated with spraying or 
dusting, but it would go beyond that? 

Mr. Joiixsox. It does. These studies include the actual applicator, 
and also workers in the field that may be subject to any fallout as a 
result of such application. I think that is correct, isn't it, Dr. Sim- 
mons ? 

Dr. SiMMOxs : That is correct. 

Mr. Joiixsox. The Division of Community Studies also assists State 
officials in conducting State pesticide projects. These i)rojects are de- 
signed to determine pesticide-related health problems within the 
States and to improve the State and local conij)etency in handling 
these problems. Each project consists of a multifaceted program, in- 
cluding training in the safe use of pesticides, surveys to develop pesti- 
cide usage profiles, pesticides safety review, environmental monitor- 
ing, disposal of pesticide wastes, monitoring of people, morbidity and 
mortality reporting, and comprehensixc planning and activating of 
programs on the public-health asj)ects of pesticides. 



3135 

The present results of our community studies indicate that, in 
general, workers using pesticides in agriculture and public-health 
vector control are exposed to relatively small fractions of the toxic 
dose each day. Since migrant agricultural workers generally work at 
jobs not directly associated with pesticide application, their exposure 
levels would tend to be lower. 

For example, workers picking malathion, an organophosphate of 
pesticide-treated beans, have significantly less exposure than the pes- 
ticide sprayers treating these beans. However, it must also be borne 
in mind that spraymen may be expected to wear protective clothing 
and to observe other recommended safeguards not observed by work- 
ers in the fields. 

Residues on crops have, in a few instances, caused poisoning in 
agricultural workers from occupation exposure. Eleven episodes of 
poisoning from contact with parathion residues involving more than 
70 persons were reported as early as 1958. 

The crops involved in these episodes of poisoning by residues have 
included pears, apples, grapes, citrus fruits, and hops. The poisoned 
workers were engaged in picking, thinning, cultivating, or irrigating. 

Outbreaks involved exposure to foliage or fruit sprayed not more 
than 2 days earlier. But in some cases the age of residue was as much 
as 33 days. Absorption of toxicant was favored by failure to wear 
protective clothing or by the persistent wearing of contaminated 
clothing. 

I might add at this point, ]Mr. Chairman, that this brings out the 
opportunity to bring out that when you talk about pesticides and its 
relation to the worker, it is pretty hard to separate this from total 
environment in which the worker lives. In a situation where you 
work a certain period of time through intermediate exposure and 
you can take off your clothes and take a shower and wear clean 
clothes the next day, that is different from a situation where you put 
the same clothes back on the next day, and there is not sufficient san- 
itary facilities in the living environment from these workers to prac- 
tice the kind of body cleanliness they should. 

Senator JMoxdale. That can be very important, can it not, if you 
get a chemical in your hair and you don't take a shower? That can 
continue to poison your system, can't it ? 

]\Ir. JoHxsox. It can be very important, and my emphasis is that 
we need to consider the total environment in which the worker lives 
and exists and not just the working environment in which he exists 
in the field. There has to be good water and sewage and housing in 
order to make any of the kinds of practices that we think are neces- 
sary for his health and well-being to be really effective. 

Coming back to the remarks on worker exposures, outbreaks of 
residue poisoning in peach-orchard workers in California were re- 
ported in 1964. 

In line with its responsibilities in reviewing registrations and la- 
bels, FDA recommended to I^SDA in August 1968 that considera- 
tion be given to requiring the posting of signs warning against 
entering fields treated with highly toxic pesticides and specifying a • 
date after which treated fields may be safely entered. The State of 
California has such a requirement for certain pesticides. 

It is well to bear in mind that exposure to pesticides is only one 
of many factors affecting the health of farm workers, as well as all 



3136 

citizens of this country. Today the farm worker may be exposed to 
an ever-increasin<r variety of body insiUts from his environment, in- 
chidin<r a«j:ricukural chemicals, inadequate diets, a hick of sanitation, 
poor sewage disposal, and low-quality housing. The collective and 
cumulative etiects of these exposures are only partly known. "While 
the health of an individual might tolerate slightly polluted water, 
air, or food, he probably cannot adapt to their collective attack 
with adverse effects. If at the same time he is subject to noise, crow^d- 
ing, and other environmental stresses, his health and well-being can 
be damaged or destroyed. Eli'orts to identify the ell'ects of a single 
stress or a single route of exposure cannot hope to define the impact 
of the total environment on the individual. 

"We have not as yet evaluated the medical significance of this dis- 
covery. However, it is certainly a most interesting development. 

Pesticides have made significant contributions toward elevating 
our standard of living during the '2()th century. They have con- 
trolled malaria, typhus, dysentery, plague, and other diseases trans- 
mitted by insects. They have also brought vast economic and social 
benefits through better health and increased quantity and quality of 
foodstuffs. 

In less than 20 years the production of synthetic chemical pesti- 
cides in the United States has increased from a level of a few mil- 
lion pounds a year to nearly 1 billion pounds annually. Almost ()0,00() 
pesticide formulations are now registered in the United States, and 
each of these contains one or more of the approximately 800 differ- 
ent pesticide compounds. 

The increased production and use of pesticides as well as many 
other industrial chemicals has without doubt presented increased 
hazards to the health of many persons — maufacturers' employees, 
applicators, migrant and other farm workers, and the consumer. It 
is difficult to estimate the incidence of illness due to pesticide poison- 
ing, as reports of these poisonings are not required in most States. 

The mortality rate in the total population due to poisoning by 
pesticides is estimated at one fatality per 1 million in population per 
year. This figure includes intentional iningestions of pesticides in su- 
icides. 

There is need for more data and better statistics. The reporting 
systems need strenghening on a nationwide base. All cases of pesti- 
cide poisoning should be investigated. To actually bring this about 
would require that physicians report all cases in\ol\ing significant 
exposure to pesticides and that adequate time and personnel be 
available to conduct epidemiological investigations. 

jNIr. Chairman, there are a number of other problems which we 
face in carrying out our mission. For exami)le, the 15 community 
studies are not fully staffed because of the difficulty in obtaining 
(lualified people. AVe would like to fully staff' the present comnumity 
studies and to provide staffs to other States that would like to par- 
ticipate. 

Mr. Chairman, i)ublic policy for the use of pest-control chemicals 
involves many considerations. The interrrelated Federal, State, and 
local efforts are indicative of the complexity of most environmental 
l)roblems. We at HP:AV are keenly aware of the work being done in 
the field of pesticides by other departments, and every effort is made 
to avoid duplication of effort. 



3137 

In fiscal year 1969, FDA spent $14,618,000 on activities associated 
with pesticides. Tliese funds liave been concentrated in studies where 
current knowledge indicates the most exposure to pesticides. 

With the creation of the Consumer Protection and Environmental 
Health Services on July 1, 1968, the Department of Health, Educa- 
tion, and Welfare focused in a single agency the responsibility for 
identifying health hazards in man's environment, developing, and 
pronuilgating criteria and standards for the control of such hazards, 
and carrying out appropriate corrective programs. Thus, the mission 
of the Consumer Protection and Environmental Health Service is to 
assure effective protection for all against controllable hazards to 
health in the environment and in the products and services which 
enter our lives. 

On April 21, 1969, Secretary Finch appointed a Commission on 
Pesticides and Their Kelationship to Environmental Health. Dr. 
Emil Mrak, retiring chancellor of the University of California at 
Davis, an internationally renowed authority in the field of food 
chemistry, is Chairman of this commission of experts from the fields 
of environmental health, agronomy, entomology, and from industry. 
Their mission is to evaluate all aspects of pesticide usage and report 
their recommendations for research and policy guidelines by October 
1969. 

We are concerned with all aspects of pesticide usage— the benefits 
and the risks — as they affect the health of all our people. 

This concludes my statement, ]Mr. Chairman. If you or other mem- 
^oers of your subcommittee have questions, I will be happy to try to 
answer them. 

Senator ^NIoxdale. Are there any farm w^orkers on the Commis- 
sion just appointed by Secretary Finch? 

Mr. JoHxsox. There are representatives that I think are associ- 
ated with the conditions to which the farm workers are exposed. 

I might say that Dr. ]Milby, whose name was mentioned ealier, is 
on the Commission. He also is Director of our community studies 
projects in the State of California, and he is an occupational in- 
dustrial hygienist by profession. He has some of the best data that 
we are collecting in terms of exposure of agriculture and occupa- 
tional exposure in this area. 

I think we do have adequate representation in this respect. 

Senator Moxdale. Thank you, INIr. Johnson. 

Senator Bellmon? 

Senator Bellmox'. Thank you, Mr. Chairman. 

]Mr. Johnson, you mention the fact that the 15 community studies 
are not fully statfed. I am a little curious to know if this problem of 
inadequate staffing or inadequate support is a problem throughout 
your agency. 

iNIr. Jonxsox\ Certainly, Senator Bellmon. I think in this time of 
budget stress, in this time of awakening concern for the problems of 
the environment, it would be wrong to assume that any of the agen- 
cies that are involved in trying to enhance the quality of the envi- 
ronment liave a staft' that will be required to do all that is required. 
The problem is great. We are only beginning to recognize through- 
out the country this problem. 

This conimittee, along with other distinguished committees in the 
Congress, is now giving the attention I think long-deserved of the 



3138 

problems that beset us in the environment. There is a great deal to 
be done. All of the lack of support is not necessarily budgetary, but 
certainly these are considerations that have to be taken into account. 

By and large, there is a training question. It takes highly trained 
and\vell-skilled experts in some of these areas to come up with the 
kind of decisions and oi)inions that we need in order to carry for- 
ward the program that has to be carried out. 

Senator Bellmox. I am very familiar with the problems and 
weaknesses in the laboratories that exist in the State departments of 
agriculture, at least in the one State I know best. These tests that 
have to be made on foodstuifs and on the different commodities that 
move in interstate trade are very difficult to conduct sometimes. And 
they do, as you say, require skilled technicians. 

Do you feel that the laboratories that you rely upon are well 
staffed and that their findings can be relied upon? 

Mr. JoHXsox. For the work that we put out, sir, we have every 
confidence that the quality of efforts and the competence of the sci- 
entist are good. We would like to be able to carry out more analyses 
to give a broader coverage to our area of responsibility. 

These are decisions beyond my immediate office. 

Senator Bellmox. Do you feel that, for instance, the figure you 
have given here of T-p.p.m, DDT, do you feel there has been enough 
research to establish that that is a safe level ? And do you feel when 
a test is made and a report is issued showing the level of DDT on 
grapes that we can rely on the adequacy of that report ? 

Mr. JoHxsox. I will answer the last one first, and I would like to* 
discuss the first part of your question a little bit. 

I have every confidence that when we issue a report based on the 
analysis conducted in our laboratories that that report will sustain 
the confidence of the scientific community. This is not our problem. 

Perhaps we should have a system that gives us an opportunity to 
do more analyses of certain types of good crops. We have been dis- 
cussing just grapes, and there are many food crops that are exposed 
to different types of pesticide. 

Within the limitation of our resources we try to give as balanced 
coverage concerning the seriousness of the problem as we can. Let 
me discuss for a moment the basis against which we make that judg- 
ment. 

I remarked a little earlier as to the UN Food and Agricultural 
Organization and the WHO recommendations for total body input 
of different types of pesticides. We participated in this work. Our 
experts i)articipate in these international bodies that help determine 
on the basis of the best evidence that they can gather what should be 
the permissible levels of intake. 

Let's take DDT for an instance. The FAO recommends that the 
average person should not take in more than 0.01 milligrams of 
DDT per kilogram of body weight per day. Now, if you translate 
that into terms that you and I understand, that says that the aver- 
age man who eats a normal daily American diet, probably 19 or 20 
years old, one of the heavier eaters — I have a son who can certainly 
qualify for that — weiglis about 150 or 160 pounds, should not take in 
more than seven-tenths of a milligram of DDT a day. 

Now, starting with that figure, we are able to construct on a 
model the kinds of diets that people eat and the amount of DDT 



3139 

that they would be taking in on the basis of that. And different 
kinds of good eaten in different quantities, subjected to different tol- 
erance levels, help to make up that ultimate decision that we are 
staying within the recommendations of the Foreign Agricultural Or- 
ganization and WHO recommendations. 

Actually, our studies indicate that on the whole the average 
American has taken in about one-tenth on a total basis, total body- 
burden basis, of DDT that is recommended as the outside level 
against which we begin to have some doubt. 

Senator Bellmon. Do you have studies showing what the people 
who work in the fields with these products are taking, how close are 
they to their maximum? 

JNIr. Johnson. These particular studies would include workers in 
the fields. What you have to add to that is the exposure they get 
from their occupational exposure. 

Senator Bellmon. That is what I am referring to. 

Mr. Johnson. This is a different situation. There are the 15 corn- 
munity studies which give us indications as to what is happening in 
these areas. 

Senator Bellmon. How close are the agricultural workers to their 
maximum level of tolerance? 

Mr. Johnson. This is done on a little different basis. Actually, 
when we look at the occupational exposure, we are doing more in- 
depth studies as to what actually happens to the human body to 
varying levels of exposure that affect him in a deleterious way in 
terms of his health. You cannot at this particular point say that 
what we are doing in the food-basket study for people who are not 
always working in the fields is what happens to them in an occupa- 
tional setting. 

On the other hand, we have a major program in my particular 
service that is concerned with occupationnal illnesses and diseases. 
And the study results that we get and will get out of the 15 com- 
munity studies will help us to make judgments in this respect. 

Perhaps, Dr. Simmons, you would like to speak a little more 
pointedly to Senator Bellmon's question. 

Dr. Simmons. In the 15 community studies, there are farm work- 
ers involved or associated agricultural workers involved in every one 
of them. And these people are given thorough physical and neuro- 
logical examinations once a year. Then they are followed regularly 
throughout the year by conducting a battery of biochemical tests to 
determine if there is any aberration in organ function. 

Now we also make blood tests to determine the levels of pesticides. 
x\.nd where we can, we get tissues to analyze that also. So w^e have 
information on the storage level of pesticides in these workers as op- 
posed to the people who are not exposed through occupation. And, 
of course, it is high. 

Not only that, but we have conducted feeding experiments with 
people over a period of 2 or o years, where the level of DDT in this 
instance built up to several hundred parts per million, which is 
much higher than you get in agricultural w^orkers, of course. 

Now, at that time we had no adverse clinical illness, no clinical 
illness in the human volunteers, but we did not conduct an in-depth 
biochemical study that we are conducting on our community studies 
today, which includes farmers. And we have set these things up to 



3140 

determine Avhiit effect long-term, low-level exposure on people pesti- 
cides have on their health. And we can determine that only by fol- 
lowing them over a period of year, constantly testing them with doz- 
ens and dozens of different biochemical tests. And at the present 
time we have found some differences in certain biochemical tests 
with people heavily exposed and people not exposed, but they need 
confirming. Also, we do not know whether they will ever be of sig- 
nificance as far as clinical illness is concerned. 

But, to answer your question shortly, yes, we do know the levels 
of pesticide storage in people working in different agricultural pur- 
suits. And a lot of other people are working on that too. 

Senator Bellmox. Is this level approaching what you have found 
to be an intolerable conditon, or is there still a margin of safety? 
Can you tell us if we are approaching a time when there is a grave 
danger to those who work with these pesticides? 

Dr. Simmons. The maximum level found in farm people has 
never caused illness that we know of. I am excluding acute poison- 
ing, but I am talking about during their normal occupation, not 
spillage or drinking or anything like that. 

In fact, we have had people who did not show clinical illness with 
600 or 700 p.p.m., which the agricultural worker doesn't even ap- 
proach. Howe\-er, the purpose of these studies is to not find out what 
the high level will do but what a low level will do over a generation, 
because that is what is the concern of the President's Advisory Com- 
mittee and several other committess. That is, what is the effect on 
the health of the people of low-level, long-term exposure. 

We understand the level for acute poisoning. But the question is, 
will 7 p.p.m. have any effect over 20 years? That is the thing we 
don't know, and that is what our community studies are trying to 
find out. 

Senator Bellmox. Thank you. I have a couple of other questions 
I would like to ask Mr. Johnson. 

How many Federal agencies are involved in this problem of 
trying to assure us that the safety of the food we eat and the condi- 
tions under which we work is adequate? 

Mr. JoHxsox. Let's say that almost every department in the broad 
scope of its mission is and should be in some degree concerned with 
the quality of our environment. That, I think, is the scope of your 
question. 

In terms of food particularly, certainly tlic I)e})artment of Agri- 
culture, the Department of HEAV, the Department of Transporta- 
tion, and in some respects the Defense Department are all more or 
less directly involved, as well as the Federal Trade Commission. 

Senator Bellmox. Is there anywhere in our Federal structure one 
central authority or one place where all of these different agencies 
are brought together to concentrate on this one problem? 

Mr. Johnson. Certainly in terms of the health as])ect, within my 
own mind at least, there is no question that the Department of 
HEW is a centi'al authority for the health impact of the environ- 
ment on men. 

Senator ]^ellmox'. Do you have the authority you need to really 
cope with this problem? 

Mr. Johnson. We are certainly continually apprising ourselves of 
what our legal tools are and what our legal needs should be. The 



3141 

Federal Food, Drug, and Cosmetic Act certainly has a very broad- 
based legal document that gives us a great deal of authority. This 
has been amended from time to time, and I dare say that in the fu- 
ture we will perhaps ask for other amendments to it. 

Senator Bellmox. One other question. Perhaps someone on the 
panel can answer that. . 

It was stated here earlier that we ought to develop pesticides that 
give us an opportunity for controlling the insects we are after but 
which are not dangerous or which are not harmful to people. Chemi- 
cally is this possible? 

Mr. JoHXSON. Senator Bellmon, I often say that m this day and 
age, where we are shipping people to the moon and bringing them 
back and living to tell us what their experience is all about, that 
nothing is impossible. In the scientific community I think that part 
of the background of the scientist is that he is an eternal optimist. 
That if there is a problem to be solved, we should be able to bring 
the scientific resources to bear to solve that problem. 

It is just a matter within what period of time we are talking 
about, it is also a matter of how many dollars we want to address to 
that particular problem. If you go all out to do something and bring 
all of the minds that are capable of contributing to this, you have a 
monstrous undertaking in terms of both resources and dollars. 

Yes, I would say that ultimately it will be possible, certainly, to 
have less harmful pesticides than now exist in our environmental 
area. 

Senator Bellmox. Thank you very much, INIr. Johnson. 

Senator ]\Ioxdale. Thank you. Senator Bellmon. 

As I understand the Federal authority to act in this field, it is 
based upon the jurisdiction of the Government to prohibit shipment 
of dangerous pesticides in interstate commerce. Ajid if it is deter- 
mined that a certain pesticide is dangerous, we can prohibit ship- 
ment. That, in effect, prevents its use on a commercial basis. Is that 
correct ? 

]Mr. JoHxsox. That is partially correct, Senator Mondale. The 
other side of this is that once the pesticide is used, then the Food 
and Drug Administration authority is to prohibit the shipment of 
foodstuffs. 

Senator ISIoxdale. So it affects the shipment of pesticides, but if it 
is pesticide-contaminated food, for example, and this is determined 
by FDA, FDA can prohibit its shipment in interstate commerce ? 

Mr. JoHxsox. That is correct. 

Senator jMoxdale. Has that been done ? 

]\Ir. JoHxsox. Most certainly, sir. 

Senator INIoxdale. Can you give us a few examples ? 

INIr. JoHxsox. I would be glad to submit that for the record. 

Senator jNIoxdale. I don't care to go into the details, but just give 
some examples of food that has been denied the right of interstate 
shipment because of contamination. 

Mr. DuGdAX. We have a number of shipments of fresh food and 
vegetables that have been seized. Recently we have seized honeydew 
melons, alfalfa, celery, and wheat. 

Senator JMoxdale. Perhaps you could submit a recent representative 
list for the record. 

JNIr. DuGGAX. We will do that. 

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3142 



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3143 

Senator Mondale. In those cases, the Federal Government deter- 
mined that the sale and consumption of those goods would be inju- 
rious to the health of consumers, is that correct ? 

Mr. DuGGAN. Yes, sir. 

]\Ir. Johnson. I think that is partially correct. Again, Mr. 
Chairman, ours is a legal regulatory agency, and in those instances 
they were seized because they exceeded legal tolerance limits for 
those particular residues on those particular food crops. 

Senator Mondale. Which in turn had been established to protect 
the consumer from a health risk due to contamination. 

Mr. Johnson. That is correct. 

Senator ISIondai^. What comparable authority do you have, if 
any, to protect against the use of dangerous pesticides in the field or 
the dangerous application of dangerous pesticides, even though ac- 
cording to your standards the final product — fruit or vegetable — 
is shippable in interstate commerce? 

jNIr. Johnson. That basic legal responsibility is with the U.S. De- 
partment of Agriculture, Mr. Chairman. Our participation is to 
provide the health consultation in establishing whether or not there 
is an overriding dangerous health implication in the use of a pesti- 
cide, and, if so, then to make sure that the labeling that goes with 
the use of the pesticide properly describes the method and conditions 
under which it can be used. 

Senator ]\Iondale. So that your effort is essentially consumer-pro- 
tection related and not worker related. That is, there is generally no 
on-going surveillance of the methods of application in fields by your 
Department to determine whether the health of the workers is being 
risked, and no study of that is going on in a systematic, thorough 
basis. 

Mr. Johnson. At this time we do not have what would be called 
the legal responsibility, but we are very much concerned and we do 
exercise through our research and demonstration capabilities this 
concern. And we do have some knowledge of how this is done and 
where possible in our educational programs with the states. 

Senator Mondale. But at this point where the risk exists to the 
consumer, in your judgment, you have a tool which you use in pre- 
venting shipment ? 

INlr. Johnson. That is correct. 

Senator ]\Iondale. But where there is a risk to workers, all you 
have is studies and educational. eiforts? 

]\Ir. Johnson. In the Department of Health, Education, and Wel- 
fare, that is correct. I believe there is greater authority in the U.S. 
Department of Agriculture. 

It has been pointed out to me, Mr. Chairman, that some 37 States 
have use-application legislation. 

Senator JMondale. But basically at this point, restrictions, if they 
do exist to protect the farm worker, basically are a State re- 
sponsibility and not a Federal level responsibility ? 

^Ir. Johnson. It is certainly not found in HEW. 

Senator Bellmon. Mr. Chairman, I might say that some of those 
State laws are drawn to establish liability in case there is an opera- 



36-513 O— 70— pt. 6A- 



3144 

tor that causes damage to another person's crop. They are not at all 
concerned with workers. 

Senator Moxdale. In other words, some of those State laws may 
not have worker-protection elements involved at all. AVe might ask 
the stall' to analyze that point. 

(Communications regarding this matter follow :) 



t'.S. Department of Labor, 
Bureau of Labor Standards, 

Washington, July 8, 1969. 
Hon. Waltf:r F. Mondale. 
Chainiia)!. Subc'iinniittcc on Migratory Labor, 
Committee on Labor and Public Welfare. 
U.S. Senate, 
Wasliington, I).C. 

Dear Mr. Chairman : In reply to your reciuest of .Tune 20, we are pleased to 
furnish the following information regarding State and Federal regulations 
dealing with pesticides. 

As indicated in the enclosed Department of Health, Education, and Welfare 
publication, generally there are two types of State pesticide laws — registration 
laws and use and application laws. The registration laws have been adopted 
by 47 of the States with only Indiana, Delaware, and Alaska without such 
provisions. Thirty -nine States have use and application laws. 

California, in its occupational disease studies (see enclosed) points out that 
farm laborers accounted for more than half (704) of the 1,347 reports of occu- 
pational disease attributed to pesticides and other agricultural chemicals in 
1966. 

A recent Bureau of Labor Standards' study of State fire and labor codes 
shows only eight States with other than miniscule coverage of storage facili- 
ties for hazardous chemicals such as pesticides. Of these, only two States, 
Maryland and Delaware, have adopted the minimal requirements of the Ameri- 
can Insurance Association's "Fire Prevention Code." (see enclosed). The other 
State recjuirements are more permissive. 

Federal regulation of pesticides has been entirely on the basis of labeling, 
transportation, and certification with the exception of aerial application which 
is regulated by the Federal Aviation Agency, (see 14 CFR 137). 

The I'esticides Regulation Division of the Agricultural Research Service, 
U.S. Department of Agriculture is charged with the responsibility of adminis- 
tering the "Federal In.secticide, Fungicide and Rodenticide Act" which covers 
labeling and certification, (see 7 CFR 361; 363). 

The Hazarduous Materials Regulations Board in the Department of Trans- 
portation regulates interstate transportation of pesticides, (see 49 CFR 
171-179). Water transportation is regulated by the U.S. Coast Guard, (see 46 
CFR 146). Air transportation is regulated by the Federal Aviation Agency 
(see 14 CFR 103). 

If we may be of any further assistance, please do not hestitate to call on us. 
Sincerely, 

David A. Swankin, Director. 
[Enclosures] 



Excerpt From Pesticide Laws and Leoai. I.mpmcations of Pesticide Use — 
U.S. Department of Health, Education, and Welfare, Public Health 
Service — Pesticides Program Training Guide 



state pesticide legislation 

Generally, there are two tyi)es of state i)esticide laws, First, there are reg- 
istration laws, specifying certain controls over the distribution and sale of pes- 



3145 

ticides in intrastate commerce. In addition, some states have set up pesticide 
tolerances for agricultural commodities sold within the particular jurisdiction. 
Secondly, there are a group of laws which are generally considered peculiar to 
the states: those which regulate within the state the use and application of 
the substance themselves. The first set of laws have been generally modeled 
after the Federal Insecticide, Fungicide and Rodenticide Act by way of the 
Council of State Governments' so-called "Uniform State Pesticide Act." The 
registration laws, dealing with pesticide marketing within state boundaries, 
have been adopted in more or less similar form by 47 of the 50 states. Only 
Indiana, Delaware and Alaska are without state labeling regulations. 

In actuality, the state registration laws are relative uniform when compared 
to the use and application laws. There is a great divergence of coverage, un- 
fortunately most inadequate, among the states' use and application legislation. 
Other than the Federal Aviation Agency (FAA) regulations, no applicable Fed- 
eral counterpart to these laws exists since they regulate activities which are 
by their nature normally intrastate. Some states have taken significant steps 
to insure generally ample licensing provisions, specific regulations as to the use 
of pesticides, inspection of equipment, etc., by way of Custom Applicators Acts, 
Pest Control Operators Laws and Aerial Application Regulations. Other states, 
however, either have no laws dealing with pesticide use or have what might be 
considered only partial coverage of the problem. While the lack of uniformity 
is evident, such divergence can be explained in part by the varying needs and 
desires of the people in different areas. However, certainly the greaatest short- 
coming in the field of pesticide laws today is the incomplete coverage within 
the states over the use and application of these potentially harmful substances, 
which have been known to cause injury in a variety of ways. Undoubtedly, 
this can be overcome by some centralized effort which could be exerted against 
each individual state problem. However, more practically, a uniform or guide- 
line act, presented to the states as a basis from which they may fill gaps exist- 
ing in current state codes or adopt as a whole or in part with or without vari- 
ations to suit particular circumstances, seems to be the most desirable 
approach to this difliculty. It is noteworthy that uniformity was stressed by 
the House Committee on Agriculture before the passage of the Federal Insecti- 
cide, Fungicide and Rodenticide Act in 1947 so as to minimize conflicts be- 
tween state laws. 

While there is much that could be said in support of uniform state pesticide 
use and applications acts ; there are, of course, very definite problems of en- 
forcement that vary from state to state. Pragmatically, it is difficult from a 
practical point of view to enforce licensing, inspections, examinations and 
technical rules over the use of pesticides. Some states already have adequate 
means by which surveillance is maintained over custom applicators, pest con- 
trol operators and the like. Other states have poorly enforced powers in exist- 
ence. Still others, however, have no system through which control over these 
persons is maintained. A licensing system would, in reality, reduce by some 
factor the apparent threat to public health from pesticide contamination. The 
problem is, however, whether this apparent threat would be alleviated by a 
scheme of more strict control over those who use, handle and apply pesticides. 
States which now have controls over that class of persons have met with suc- 
cesses are varied as the laws themselves. However, one point is clear, a pro- 
gram of enforcement is only as effective and vigorous as the agencies who ad- 
minister it. Having well-written laws is one thing while adequate enforcement 
is quite another. 

The great number of state statutes, both registration and use and applica- 
tion, are listed below. The list is a compilation of the major pieces of pesticide 
legislation now in force in the United States. 



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3152 

WHPC Publication 1229/ Wash., D.C. 20210 
January 1968 




UNITED STATES DEPARTMENT OF LABOR 

WAGE AND HOUR AND PUBLIC CONTRACTS DIVISIONS 



Child Labor Bulletin No. 102 (Revised) 



3153 



CHILD LABOR REQUIREMENTS IN AGRI- 
CULTURE UNDER THE FAIR LABOR 
STANDARDS ACT WHICH APPLY IN ALL 
STATES 



1. Are there child-labor requirements of the 
Fair Labor Standards Act that apply to agriculture? 

Yes. The requirements for agriculture are 
more limited than in other industries. They 
apply, however, whether the farm is small or 
large and do not depend on the number of 
man-days of agricultural labor used, as in the 
case of the minimum-wage requirements. 

They apply generally to farmers whose 
crops or products go either directly or indi- 
rectly into interstate or foreign commerce, 
as in the case of a farmer who sends his pro- 
duct outside the State or delivers his product 
to a canner, processor, or dealer who he 
knows or has reason to believe will send it 
outside the State, either in its original form 
or as an ingredient of another product. For 
example, tomato growers who send their toma- 
toes to a cannery within the same State are 
covered if the canned tomato product made 
from their tomatoes goes out of the State. 

2. What employment is permitted under these 
child-labor requirements? 

• Farmers may employ minors 16 years of age 
and over at anytime in any agricultural 
occupation. 

• No minor under 16 may be employed at any- 
time in an agricultural occupation declared 
hazardous by the Secretary of Labor, ex- 
cept on the home farm by his own parents. 

• Children under 16 may not be employed in 
agriculture during school hours, except by 
parents on the home farm. 

3. What is meant by "during school hours?" 

During school hours means the hours when 
the school for the school district where the 
child is living while employed is in session. 
(This means that, if school is open in the 
place where a crew leader takes his workers, 
the children may not work during the hours 
the school is open.) 



3154 



Children should be enrolled in the local 
school in the fall as soon as it opens even 
though the family is going to another area 
later or back home. 

"School hours for the school district where 
such employee is living while he is so em- 
ployed" do not apply in the spring to a child 
from another school district if the school he 
last attended has closed for the school year; 
however, local school attendance laws may 
require that these children attend school even 
if the school they last attended in another 
district is closed. 

4. How can a fanner or a crew leader be sure 
that the school the child last attended is closed? 

A written statement signed by the school 
official of the school the child last attended 
would constitute satisfactory evidence. This 
statement should contain the name of the 
child, the name and address of the school, 
the date the school closed for the current 
year, and the date the statement was signed. 
Employment before May 15 should be avoided. 
Crew leaders should remind parents to bring 
this school statement with them. 

5. How old must a child be to work on a 
farm outside school hours? 

A child may be employed at any age before 
and after school hours on any school day, or 
at any time during a school holiday or vaca- 
tion period, except in occupations declared 
hazardous by the Secretary of Labor. A 16- 
year minimum age applies in such occupa- 
tions at all times; i.e., during school hours, 
before and after school, and during vacations. 

6. What are the agricultural hazardous occu- 
pations? 

Occupations in Agriculture particularly hazardous 
for the employment of children below the age of 
16 are: 

(1) Handling or applying anhydrous ammonis^. 
organic arsenic herbicides, organic phosphate 
pesticides, halogenated hydrocarbon pesticides. 
or heavy-metal fungicides, including cleaning or 
decontamination equipment used in application o r 
mixing of such chemicals. 

(2) Handling or using a blasting agent. For the 
purpose of this subparagraph, the term "blasting 



3155 



agent" shall include explosives such as, but not 
limited to, dynamite, black powder, sensitized 
ammonium nitrate, blasting caps, and primer cord. 

(3) Serving as flagman for aircraft. 

(4) Working as - 

(i) Driver of a truck or automobile on a pub- 
lic road or highway. 

(ii) Driver of a bus. 

(5) Operating, driving, or riding on a tractor 
(track or wheel) over 20 belt horsepower, or at- 
taching or detaching an implement or power-take- 
off unit to or from such tractor while the motor is 
running. 

(6) Operating or riding on a self-unloading bunk 
feeder wagon, a self-unloading bunk feeder trai- 
ler, a self-unloading forage box wagon, a self- 
unloading forage box trailer, a self-unloading auger 
wagon, or a self-unloading auger trailer. 

(7) Operating or riding on a dump wagon, hoist 
wagon, fork lift, rotary lift, rotary tiller (except 
walking type), or power-driven earthmovingequip- 
ment or power-driven trenching equipment. 

(8) Operating or unclogging a power-driven 
combine, field baler, hay conditioner, corn picker, 
forage harvester, or vegetable harvester. 

(9),0perating, feeding, or unclogging any of the 
following machines when power-driven: Sta- 
tionary baler, thresher, huller, feed grinder, chop- 
per, silo filler, or crop dryer. 

(10) Feeding materials into or unclogging a 
roughage blower or auger conveyor. 

(11) Operating a power-driven post-hole digger 
or power-driven post driver. 

(12) Operating, adjusting, or cleaning a power- 
driven saw. 

(13) Felling, bucking, skidding, loading, or un- 
loading timber with a butt diameter of more than 
6 inches. 

(14) Working from a ladder or scaffold at a 
height over 20 feet. 

(15) Working inside a gas-tight type fruit en- 
closure, gas-tight type grain enclosure or gas- 
tight type forage enclosure, or inside a silo when 
a top unloading device is in operating position. 



3156 



.(16) Working in a yard, pen, or stall occupied 
by a dairy bull, boar, or stud horse. 

E^cceptions: 

(A) These standards do not apply to the em- 
ployment of a minor under 16 by his parent or 
by a person standing in the place of his parent 
on a farm owned or operated by such parent or 
person. 

(B) Student-learners under 16 enrolled in a 
bona fide cooperative vocational education train- 
ing program in agriculture are exempt from the 
provisions of this Interim Order provided the fol- 
lowing requirements are met: 

(1) Such student-learner is employed under a 
written agreement which provides: 

(i) that the work of the student-learner in 
the occupations declared particularly hazardous 
shall be incidental to his training; 

(ii) that such work shall be intermittent and 
for short periods of time, and under the direct 
and close supervision of a qualified and ex- 
perienced person; 

(iii) that safety instructions shall be given 
by the school and correlated by the employer 
with on-the-job training and; 

(iv) that a schedule of organized and pro- 
gressive work processes to be performed on the 
job shall have been prepared. 

(C) Any educational or training program for 
which an exclusion has been obtained from the 
Secretary of Labor. 

7. What are some of the jobs still permitted on 
farms under the agricultural hazardous order? 

Examples of some of the permitted jobs are: 
Handling many chemical pesticides and fertili- 
zers; 

Driving a truck or automobile on the farm proper 
and helpers on motor vehicles; 
Loading and unloading trucks; 

Operating garden-type tractors; 

Picking vegetables and berries, and placing them 

on conveyors or in containers; 

Clearing brush and harvesting trees up to 6 inches 
in butt diameter; 



3157 

Working from ladders at heights less than 20 feet, 
such as picking of most fruits; 

Hand planting and cultivation; 

Raising and caring for poultry; 

Milking cows; 

Processing and storing milk and dairy products; 

Detasseling com; 

Cleaning barns, equipment storage buildings, 
chicken coops, etc.; 

Mowing lawns; 

Riding, driving or exercising horses; 

Picking cotton; 

Handling of irrigation pipes; 

Harvesting curing and storing tobacco; 

Riding on transplanters. 

8. How can a farmer or crew leader be sure a 
minor is at least 16 years of age? 

The Act provides that a farmer or crew leader 
may protect himself from unintentional violation 
of the child-labor requirements by having on file 
an age or employment certificate showing the 
minor to be the legal age for the occupation in 
which he is employed. He is not required, how- 
ever, to obtain this certificate. Families should 
bring with them some evidence of date of birth 
for their children— either a birth certificate or 
baptismal certificate. 

9. Where can such a certificate be obtained? 

Age and employment certificates issued under 
State child-labor laws may be obtained in every 
State except four. These State age and employ- 
ment certificates are issued usually by local school 
officials, or a representative of the State labor, 
welfare, or education department. 

In the four States without such systems, the 
Wage and Hour and Public Contracts Divisions, 
U.S. Department of Labor, issue Federal certifi- 
cates of age. These may be obtained in the Divi- 
sions' offices located in Boise, Idaho; Jackson, 
Mississippi; Columbia, South Carolina; and in 



3158 



Dallas, Texas (also in Field Offices located in 
Texas) . 

10- Do these child-labor requirements apply to all 

Vf-s. These rhild-lahor nrnvisions nf the Art. 
apply to the agricultural employment of all rhil- 
r\rpn-- mimnnt.'; a.s well as local resident children . 
The only exemption provided is that a parent may 
employ his own child on his farm without regard 
tor these requirements . 

11. Is a farmer in violation of the Fair Labor 
Standards Act if the underage children working on 
his farm were not hired by him personally? 

Both the farmer and the crew leader may be 
held responsible for every underage child work- 
ing on a farm. This includes children hired 
either individually or as a part of a family 
group by labor contractors, processors, or others. 

12. What records must be kept by farmers and 
crew leaders for minors working on farms? 

Every employer (other than a parent or guard- 
ian standing in place of a parent employing his 
own child or a child in his custody on his farm) 
who employs in agriculture any minor under 18 
years of age oil days when school is in session or 
on any day if the minor is employed in an agri- 
cultural occupation found to be hazardous by the 
Secretary of Labor shall maintain and preserve 
records containing the following data with re- 
spect to each aSid every such minor so employed : 

( 1 ) Name in full. 

(2) Place where minor lives while employed. 
If the minor's permanent address is elsewhere, 
give both addresses. 

(3) Date of birth. 

It is not necessary that records be maintained 
in any particular order or form. They must be 
kept in a safe and accessible place and be open 
at anytime to inspection and transcription by 
authorized representatives of the Secretary of 
Labor. These records must be preserved for at 
least 3 years. 

If a mjnor is subject to the minimum wage 
requirements of the Act, additional records show-* 
ing his pay and hours of work are requited. 



I 



3159 



13. Are minors subject to a minimum wage? 

The 1966 Amendments to the Fair Labor 
Standards Act extended minimum-wage protec- 
tion to certain farm employees, including minors, 
whose employer in any calendar quarter of the 
preceding calendar year used more than 500 man- 
days of agricultural labor. Such employees, unless 
otherwise exempt, must be paid at least $1.00 an 
hour beginning February 1, 1967; $1.15 an hour 
beginning February 1, 1968; and $1.30 an hour 
beginning February 1, 1969. There is an exemp- 
tion for migrant hand harvest laborers 16 years 
of age or under employed on the same farm as 
their parents, if (a) they are paid piece rates in 
an operation generally recognized as piecework 
in the region, and (b) the piece rate is the same 
as paid workers over age 16. Employment of such 
minors is subject to the prohibitions against em- 
ployment in hazardous occupations or during 
school hours. The overtime provisions of the law 
do not apply to farmworkers. Further information 
may be obtained from the Divisions' nearest 
offices. 

The above requirements do not apply to children 
employed by their own parents on the home farm. 

14. What are the penalties for violation of the 
child-labor requirements of the Fair Labor Stand- 
ards Act? 

The Secretary of Labor may ask a Federal dis- 
trict court to restrain future violations of the 
child-labor requirements of the Act by injunction. 
The Act provides, in case of willful violation, a 
fine up to $10,000. For a second offense, com- 
mitted after conviction for a similar offense, a fine 
of not more than $10,000 or imprisonment of not 
more than 6 months, or both, may be imposed. 

15. What other Federal laws affect the employ- 
ment of children in agriculture? 

The Sugar Act of 1948 contains certain provi- 
sions with which producers engaged in the pro- 
duction and harvesting of sugar beets or sugar- 
cane must comply to obtain maximum benefit 
payments. These provisions include a minimum 
age of 14 years for employment and a maximum 
8-hour day for childien between 14 and 16 years 
of age. Members of the immediate family of the 
legal owner of at least 40 percent of the crop at 
the time the work is performed are exempted 
from these provisions. The 16-year minimum age 
set by the Fair Labor Standards Act would, how- 
ever, apply to children who work on sugar beets 
or sugarcane during school hours unless they are 
the farmer's own children. 



36-513 O - 70 - pt. 6A 



3160 



ADDITIONAL INFORMATION 

Inquiries about the Age Discrimination in Em- 
ployment Act of 1967 will be answered by mail, 
telephone, or personal interview at any office of 
the Wage and Hour and Public Contracts Divisions 
of the U.S. Department of Labor. Offices are 
listed in the telephone directory under the U.S. 
Department of Labor in the U.S. Government list- 
ing. These offices also supply publications free 
of charge. 

Offices listed in Italics are staffed by investi- 
gation personnel whose duties frequently require 
them to be away from the office. Telephone mes- 
sages and requests for information may be left at 
these offices when regular personnel are not on 
duty. Personal appointments may be arranged by 
either telephone or mail. 

Alabama: Andalusia, Anniston, Birmingham, Dothan, 

Florence, Gadsden, Huntsville, Mobile, Montgomery, 

Opelika, Selma, Tuscaloosa 
Alaska: Anchorage 
Arizona: Phoenix, Tucson 
Arkansas: El Dorado, Fayetteville, Fori Smith, Hope, 

Jonesboro, Little Rock, Pine Bluff 
California: Bakersfield, Fresno, Hollywood, Long Beach, 

Los Angeles, Modesto, Monterey, Oakland, Redding, 

Riverside, Sacramento, San Diego, San Francisco, 

San Jose, San Mateo, Santa Ana, Santa Rosa, 

Stockton, West Covina, Whittier 
Colorado: Denver, Pueblo 
Connecticut: Bridgeport, Hartford, New Haven, New 

London 
Delaware: Wilmington 
District of Columbia, College Park 
Florida: Clearwater, Cocoa, Fort Lauderdale, Fort Myers, 

Jacksonville, Lakeland, Leesburg, Miami, North 

Miami, Orlando, Pensacola, St. Pe/ersfcurg, Tampa, 

West Palm Beach 
Georgia: Albany, Athens, Atlanta, Augusta, Columbus. 

Gainesville, Hapeville, Macon, Rome, Savannah, 

Thomasville, Valdosta 
Hawaii: Honolulu 
Idaho: Boise 

Illinois: Chicago, Springfield 
Indiana: Evansville, Indianapolis, South Bend 
Iowa: Burlington, Cedar Rapids, Davenport, Des Moines, 

Fori Dodge, Mason City, Sioux City, Waterloo 
Kansas: Pittsburg, Salina, Topeka, Wichita 
Kentucky: Ashland, Lexington, Louisville, fAiddles- 

boTO, Pikeville 
Louisiana: Alexandria, Baton Rouge, Hammond, 
Houma, Lafayette, Lake Charles, Monroe, New 
Orleans, Shreveport 
Maine: Portland 

Maryland: Baltimore, College Park, Hagerstown. Salis- 
bury 



I 



3161 



Massachusetts: Boston, Louie//, Springfield, Worcester 
Michigan: Detroit, Grand Rapids, Lansing 

Minnesota: Minneapolis 

Mississippi: Biloxi, Columbus, Clarksdale. Green- 
wood, Hattiesburg, Jackson, Tupelo 

Missouri: Cape Girardeau, Columbia, Joplin, Kansas City, 
St. Joseph, St. Louis, Springfield 

Montana: Great Falls 

Nebraska: Grand Island, Lincoln, Omaha 

Nevada: Reno 

New Hampshire: Manchester, Laconia 

New Jersey: Camden, Newark, Paterson, Trenton 

New Mexico: Albuquerque, Las Cruces, Roswell 

New York: Albany, Bronx, Brooklyn, Buffalo, Hempstead, 
New York, Rochester, Syracuse 

North Carolina: Asheville, Charlotte, Durham, Fayette- 
ville, Goldsboro, Greensboro, Hickory, High Point, 
Raleigh, Wilmington, Winston-Salem 

North Dakota: Bismarck, 

Ohio: Cincinnati, Cleveland. Columbus 

Oklahoma: Ardmore, Enid, Lawton, Muskogee, Okla- 
homa City, Tulsa 

Oregon: Eugene, Medford, Portland, Selma 

Pennsylvania: Allentown, Altoona, Chester, DuBois, 
Erie, Greensburg, Harrisburg, Indiana, Johnstown, 
Lancaster, Lewistown, McKeesport, New Castle, 
Philadelphia, Pittsburgh, Reading. Scranton, 
Vniontown, Washington, Wilkes-Barre 

Rhode Island: Providence 

South Carolina: Charleston, Columbia, Florence, Green- 
ville, Spartanburg 

South Dakota: Aberdeen, Rapid City, Sioux Falls 

Tennessee: Bristol, Chattanooga, Columbia, Jackson, 
Johnson City, Knoxville, Memphis, Nashville 

Texas: Abilene, Amarillo, Austin, Beaumont, Corpus 
Christi, Dallas, El Paso. Fort Worth, Galveston, 
Harlingen, Houston, Laredo, Longuiew, Lubbock, 
Lufkin, Midland, Odessa, Paris, San Antonio, 
Texarkana, Tyler, Victoria, Waco, Wichita Falls 

Utah: Ogden, Salt Lake City 

Vermont: Burlington, Montpelier 

Virginia: Alexandria, Norfolk, Richmond, Roanoke, 
Waynesboro 

Washington: Seattle, Spokane, Tacoma 

West Virginia: Bluefield, Charleston, Clarksburg, Hunt- 
ington, Logan 

Wisconsin: Madison, Milwaukee, Oshkosh 

Wyoming: Casper, Cheyenne 

Puerto Rico: Arecibo, Caguas, Hato Rey, Mayaguez, 
Ponce, Santurce 

Canal Zone, Virgin Islands: Santurce, Puerto Rico 

American Samoa, Eniwetok Atoll, Guam, Johnston Island, 
Kwajalein Atoll, Wake Island: Honolulu, Hawaii 



3162 



...// 



I Occs^paiioiial Disease hi Calsfehiia 
J Aiii ibutcd to restgcadcs m^^ 
Ouier Agricullural Cteiicals 




3163 



SUMMARY 



The 1,347 reports of occupational disease attributed to pesticides and other agri- 
cultural chemicals received in 1966 compares with 1,340 in 1965 and 1,328 in 
1964. 

Occupational diseases are not included from among self-employed farmers and 
unpaid family labor, 28 percent of the agricultural work force, and from self- 
employed one-man operations in structural and agricultural pest control work. 
Data in this review, therefore, undoubtedly understate the incidence of occupa- 
tional disease attributed to pesticides and other agricultural chemicals. 

The rate of occupational disease from agricultural chemicals in agricultural ser- 
vices (6.6 reports per 1,000 workers) was nearly twice that for workers in all 
agriculture (3.5 reports per 1, 000 agricultural workers). 

Since 1951, there have been 32 occupational fatalities implicating agricultural 
chemicals. In this same period, 82 children and 22 other adults died in Cali- 
fornia from accidents attributed to pesticides and other agricultural chemicals, 
a total of 136 accidental deaths. 

Organic phosphate pesticides were implicated in 19 percent of the 1,347 reports 
in this series; followed by herbicides, 11 percent; fertilizers, 10 percent; halo- 
genated hydrocarbon pesticides, 7 percent; and phenolic compounds, 7 percent. 

There were 233 reports of systemic poisonings in 1966. The organic phosphate 
pesticides were blamed in 173 of these. 

Forty percent of workers with occupational disease attributed to agricultural 
chemicals were expected to lose some time from work. Ten percent of such 
workers were hospitalized. 

Farm laborers accounted for more than half (704) of the 1,347 reports of occu- 
pational disease attributed to agricultural chemicals; nonfarm laborers, 15 per- 
cent; and operatives, including truck and tractor drivers, 14 percent. 

Eighty percent of pest control chemicals moved beyond local areas are moved 
by truck. Chemicals are usually transported in concentrated form, creating 
potential health hazards in transportation and storage of pesticides in the event 
of mishap. 



3164 



BACKGROUND 



Occupational disease caused by agricultural chemicals continues to be one of the 
most important occupational health problems in the State. Diseases caused by 
these chemicals include a liigh proportion of serious acute illness. In 1966, 42 
percent of tlic IS,S7 reporlis of all occupational poisonings were altrilnited to aj^'ri- 
cultural chemicals, althougli only 5 percent of the 27,626 reports of all occupa- 
tional diseases received were attributed to these chemicals. Furtlier, tiiese 
cases arc concentrated in the agriculture industry which has the highest rate of 
occuiiational disease in California: 11 .9 reports per 1,000 agricultural workers 
in 1966, or more than two and a half times that for all industrial divisions (4.5 
per 1,000 workers for all industry). 

The acute effects of pesticides and other agricultural chemicals on workers in 
California, as recognized and reported by physicians, have been summarized by 
the Bureau of Occupational Health of the California Department of Public Health 
since 1950. While limited to the segment of the population covered by the Cali- 
fornia Workmen's Compensation law, these data are the only regularly available 
information in the United States on acute conditions caused by agricultural chem- 
icals. As such, they have been of continuing interest to persons concerned with 
the effects of agricultural chemicals on the health of people. Although the use 
of pesticides and other agricultural chemicals is widespread in home and garden, 
the effects of this contact on the health of the general population are not com- 
pletely known. 

Comments in earlier reports of the Bureau of Occupational Health pointed to 
needed improvements for the protection of workers using agricultural chemicals. 
These comments still apply, as demonstrated by a review of the 1966 doctors' 
reports. Among the needed protective measures are: provision of washing fa- 
cilities for farm workers in the fields; adequate supervision of agricultural chem- 
ical users; improvement in the engineering of crop-dusting aircraft and related 
equipment; and standardization of labeling on pesticide containers. As recently 
as the summer of 1967, an outbreak of pesticide poisoning in the San Joaquin 
Valley was reported to have sickened about 25 peach pickers. Yet similar out- 
breaks among fruit pickers had occurred there in 1959 and 1963. 



3165 



FIRE PREVENTION 
CODE 



A code prescribing regulations governing 

conditions hazardous to life 

and property from fire, 

also. 

A suggested ordinance adopting the Fire 

Prevention Code and establishing a 

Bureau of Fire Prevention. 



Edition of 1965 

Superseding the Edition of 1960 with 

Amendments of 1961. 



Recommended by the 

AMERICAN INSURANCE ASSOCIATION 

successor to the 

National Board of Fire Underwriters 



Engineering and Safety Department 

85 John Street, New York, N. Y. 10038 

222 West Adams Street, Chicago, III 60606 

465 California Street, San Francisco, Calif. 94104 



3166 
Hazardous CiiKMicALS Siic. 20.2 



ARTICLE 20 
HAZARDOUS CHEMICALS 

Section 20.1. Scope. 

This article shall apply to materials not otherwise covered in 
this code which are highly flammable, or which may react to cause 
fires or explosions, or which by their presence create or augment a 
fire or explosion hazard, or which because of their toxicity, flam- 
mability, or liability to explosion render fire fighting abnormally 
dangerous or difficult ; also to materials and formulations which arc 
chemically unstable and which may spontaneously form explosive com- 
pounds, or undergo spontaneous or exothermic reactions of explo- 
sive violence or with sufficient evolution of heat to be a fire hazard. 
Hazardous chemicals shall include such materials as corrosive 
liquids, flammable solids, highly toxic materials, oxidizing ma- 
terials, poisonous gases, radioactive materials, and unstable chem- 
icals, as defined in section 20.2. 

Section 20.2. Definitions. 

a. Corrosive liquid shall mean and include those acids, alka- 
line caustic liquids, and other corrosive liquids which when in 
contact with living tissue, will cause severe damage of such tissue 
by chemical action; or in case of leakage will materially damage 
or destroy other containers of other hazardous commodities by 
chemical action and cause the release of their contents; or are 
liable to cause fire when in contact with organic matter or with 
certain chemicals. 

b. Flammable solid shall mean and include a solid substance, 
other than one classified as an explosive, which is liable to cause 
fires through friction, through absorption of moisture, through 
spontaneous chemical changes, or as a result of retained heat from 
manufacturing or processing. Examples arc : white phosphorous, 
nitrocellulose, metallic sodium and potassium, and zirconium 
powder, 

c. Highly toxic material shall mean a material so toxic to man 
as to afford an unusual hazard to life and health during fire fighting 
operations. Examples are: parathion, TEPP (tetraethyl phos- 
phate), HETP (hexaethyl tetraphosphate), and similar insecticides 
and pesticides. 



3167 
Hazardous Chemicai^ ' Sf.c. 20.13 



Section 20.11. Highly Toxic Materials. 

a. Highly toxic materials shall be separated from other chem- 
•rals and combustible and flammable substances by storage in 
;i room or compartment separated from other areas by walls and 
loor and ceiling assemblies having a fire resistance rating of not 
less than one hour. The storage room shall be provided with ade- 
(jtiatc drainage facilities and natural or mechanical ventilation to 
the outside atmosphere. 

b. Legible warning signs and placards stating the nature and 
location of the highly toxic materials shall be posted at all en- 
trances to areas where such materials are stored or used. 

Section 20.12. Poisonous Gases. 

a. Storage of poisonous gases shall be in rooms of at least 
one-hour fire-resistant construction and having natural or me- 
cbanical ventilation adequate to remove leaking gas. Such ven- 
tilation shall not discharge to a point where the gases may endan- 
^i;oi- any person. 

b. Legible warning signs stating the nature of hazard shall 
w: placed at all entrances to locations where poisonous gases are 
stored or used. 

Section 20.13. Corrosive Liquids. 

Satisfactory provisions shall be made for containing and neu- 
tralizing or safely flushing away leakage of corrosive liquids which 
may occur during storage or handling. 



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The protection of man, his food and fiber supplies, and his forests from the ravages 
of pests of all kinds is essential to the continued grovrth and strength of America and 
the progress and well-being of its people. 

Even with modern pest control methods, harmful insects, diseases, nematodes, and weeds 
still cause serious damage to crops and livestock, with the estimated loss amounting 
to nearly one-fourth of our total yearly production. The cost of controlling these 
pests comes to over $3.1 billion a year. 

Some 10,000 species of insects in the United States are classed as public enemies, of 
which several hundred are particularly destructive and require some measure of control. 
Other pests capable of causing serious economic loss include 500 weed species, 1,500 
plant diseases, and 1,500 species of nematodes (microscopic worms). 

Of the 457 million acres of farmland in the United Stctes, 15 percent (69 million 
acres) produces crops needing some degree of protection from insect pests. Some fonn 
of weed control is used on all cropland and also on a high percentage of the more than 
one billion acres of forage and grazing land. Host grain and all cotton seed requires 
chemical treatment for prevention of plant diseases. 

CHEMICALS — A MAJOR WEAPON AGAINST PESTS 

Pesticides are generally the most effective and, in many instances, the only weapons 
available to fight pests that damage or destroy crops, livestock, and forests or 
endanger human health and oru natural resources. 

The development since 1945 of modern pesticides, together with other technical 
advances, has made possible a spectacular advance in American agricultural efficiency. 
During the past two decades, farm output per acre has increased by at least a third, 
keeping pace with the needs of an exploding population at home and growing markets 
abroad. 

At the same time, these chemicals have played a major role in protecting man's health 
and well-being. They not only are used to produce and protect the abundance and 
nutritional quality of our food, but serve us directly in suppressing the pests that 
transmit malaria, yellow fever, typhoid, and many other diseases, and in controlling 
poisonous plants. 



OFFICE OF INFORMATION 



U. S. DEPARTMENT OF AGRICULTURE 



SEPTEMBER 1966 - Rev. 



3174 



USDA Policy on Pesticides 

The U. S. Department of Agriculture has maior responsibilities for protecting man, 
animals, plants, farm and forest products, and communities and households against 
pests. In carrying out these responsibilities, the Department seeks to: 

(1) Protect the health and well-being of people who use pesticides 
and consumers who use food and other products protected by pest 
control chemicals, and 

(2) Protect fish, wildlife, soil, air, and water from pesticide 
pollution. 

The Agriculture Department uses in its own pest control programs and encourages 
others to use those means of effective pest control which provide the least potential 
hazard to man and wildlife and least danger of air and water pollution. 

The Department strongly supports the use of biological, cultural, mechanical, and 
ecological pest control methods or non-persistent and low toxicity pesticides whenever 
such means will do the job effectively and safely. When residual or long-lasting 
pesticides are necessary, the Department urges they be used in the smallest effective 
amounts applied precisely to the infested area, and no more often than needed for 
effective control or elimination of the target pest. 

The Department implements this policy through its own research and control programs. 
USDA scientists recently developed a new low-volume spraying technique for applying 
undiluted malathion, an effective but non-persistent chemical of low toxicity to 
warm-blooded animals. The technique has been used successfully against grasshoppers, 
cereal leaf beetle, boll weevil, and spruce budworm. In boll weevel spraying, this 
low- volume method has reduced the amount of insecticide used per acre from three 
gallons of liquid to 16 ounces of undiluted malathion. One planeload can do the work 
which previously required 23 planeloads. Before any pesticide can be registered with 
directions for low volume application, adequate data must be available to show that 
the use would be safe, effective, and would not result in illegal residues on food. 

The Federal-State program to control the imported fire ant, begun in 1957 in the 
Southeastern State initially used 2 lbs, of heptachlor per acre for control. 
Continued USDA research cut use to 1-1/4 lbs. per acre, and then to two applications 
of only 1/"* lb. spaced 3 to 6 months apart. Finally, heptachlor was entirely replaced 
with the much less toxic rairex bait which is considerably less hazardous than 
heptachlor. 

The average number of fungicide applications needed to control potato late blight in 
the northcentral and northeastern states has been reduced from ten to five per year. 
USDA scientists made this possible through development of more accurate disease 
forecasting and related proper timing of fungicide applications. 

As a result of research work, the U. S. Department of Agriculture has switched from 
the use of pesticides to insect sterilization in the battle to keep the Mexican fruit 
fly under control along the border with Mexico. Male flies treated with either 
chemosterilants or gamma radiation are released to mate with females, thereby 
preventing reproduction and keeping the fly population in check. 



3175 



Pesticides and the Farmer 

The use of chemicals to fight pests dates back at least to the ancient Greeks who 
employed brimstone (sulfur) as an insecticide. Common salt probably was used in 
ancient times as the first chemical weed killer. 

In the U.S., settlers in the Great Plains in 1869 prevented their own starvation 
by use of Paris green, a crude arsenical, to save their potato crops from the Colorado 
potato beetle. Settlers also treated their grain seeds with copper sulfate to protect 
grain from plant disease. 

In recent years, pesticides have become a common tool of progressive farmers. Last 
year, nearly $1 billion worth of pesticides were used to produce and protect 
agricultural and forest products. 

Herbicides were used for weed control on more than 70 million acres of agricultural 
land in 1962 at a cost of more than $272 million. Principal application: 
approximately 25 million acres of corn, 6 million acres of cotton, 3 million acres of 
soybeans, 20 million acres of small grains, and 7 million acres of pasture and range- 
land. Herbicide usage is increasing markedly each year. 

It is estimated that insecticides are used by farmers to protect 32-1/2 million acres 
of grains (including corn, feed sorghum, and rice), 12 million acres of cotton, 2-1/2 
million acres of fruit and nuts, 2 million acres of vegetables (including potatoes), 
and about 20 million acres of other crops. These treated crops occupy about 15 per- 
cent of the total crop acreage. 

Of the 758 million acres of forest land, less than three-tenths of one percent is 
subjected to any pesticide treatment in any one year. 

Ninety-seven percent of our native grasslands have never had a pesticide applied to 
them. About 7 5 percent of the total land area of the U. S. has never had any 
pesticide applied to it. 

Pesticides and the Consumer 

The effectiveness of modern pesticides in controlling agricultural pests helps keep 
food cost down and quality high. It is estimated that if pesticides were to be 
completely withdrawn from farm use, crop and livestock production in the United States 
would drop by 25 to 30 percent. 

This sharp cut in production could boost the price of farm products by 50 to 75 
percent, and increase food's share of the family budget from less than one-fifth at 
present to as much as one-third. The quality of this reduced supply of vegetables, 
fruit, meat, and other food items would be visibly poorer than at present. 

Without pesticides, potato production would be virtually wiped out in the East by 
disease, and peaches and citrus fruit probably would be destroyed by insects and 
disappear almost completely from food markets. 



36-513 O - 70 - pt. 6A 



3176 



During the Second World War, production of sweet corn in the United States was 
greatly reduced due to the depredations of the European corn borer and the corn ear- 
worm. In 191*6, blight destroyed over 50 percent of the tomato crop in ten states. 
These .popular table foods were restored to full production through protection with 
modern pesticide. 

Some of the American consumer's favorite vegetables might be priced out of the food 
markets if weeding on farms was still done by costly hand labor instead of with 
chemical weed killers. 

Pesticides in the Home and Garden 

Approximately 15 percent of all pesticides sold are purchased for home and garden use, 
and last year totaled over 50 million pounds of insecticide preparations. By con- 
trolling destructive or disease-carrying pests, these chemicals help make possible 
our modern way of life. 

The aerosol principle, now a commonplace method of applying insecticides in the home 
as well as dispensing everything from deodorants to whipped cream, was invented 
during World War II by U. S. Department of Agriculture scientists. About 80 million 
aerosol "bug bombs" were sold in 1965 for use against such common home pests as flies, 
mosquitoes, roaches, and ants, and for protection of flowers and ornamentals. 

Wildlife Conservation and Pest Control 

Protecting man, his food, and his fiber against pests is conservation in the broadest 
sense of the word. Protecting wildlife is a vital part of the Department's dedication 
to conservation. 

The nation's farmers, ranchers, and foresters play a key role in maintaining an 
abundant wildlife population because it is their agricultural and forest lands that 
provide the habitat for most of the nation's wildlife. 

USDA takes this fact into account in conducting research and helping landowners and 
operators plan the water conservation measures now in use on two million American 
farms. 

The Soil Conservation Service of the U. S. Department of Agriculture reports that in 
195U there were 7.9 million acres devoted to preserving wildlife habitat within the 
nation's 2,989 Soil Conservation Districts. In 1965, our farm and ranch lands 
contained over 1.4 million man-made ponds, 3,891 multi-purpose dams, 30,525 miles of 
hedgerow, 11.8 million acres of seeded rangeland, 11.8 million acres planted in 
trees, and numerous other conditions favoring the expansion of our wildlife and fish 
populations. 



3177 



Pesticides are used in ways directly beneficial to wildlife. For example, herbicides 
are employed to eliminate poisonous plants and brush from rangeland and aquatic weeds 
from ponds, lakes, and streams. Treated rangeland is replanted with forage suitable 
for grazing by antelope, deer, elk, and other wildlife species as well as cattle. 
Elimination of aquatic weeds permits growth of food plants needed by fish and other 
aquatic life. 

Increases of up to 65 percent in the deer populations have been reported in areas of 
Texas from which the screwworm fly, a highly destructive animal parasite, had been 
recently eradicated by the USDA, with non-chemical means, in cooperation with southern 
states and livestock producers in those states. 

National forests, administered by the Forest Service of the Department of Agriculture, 
shelter many species of fish, birds, and mammals. Through careful planning and 
supervision, pesticides can and are being used to protect timber and range values in 
these forests without adversely affecting wildlife populations or their habitat. 

About one-third of the big game animals taken by hunters in the U. S. comes from the 
national forests. In recent years, the population of deer, bear, antelope, elk, 
moose, and other big game in these forests has been at one of the highest levels 
recorded in the past two decades, according to Forest Service estimates. 

In the application of pesticides to forest lands, the Forest Service carefully 
delineates the infested areas to be treated, marks off buffer zones bordering lakes 
and streams, and monitors the effects of certain pesticides on wildlife and fish in 
and near treated areas. Federal and State fish, wildlife, and public health agencies 
are consulted during the planning of chemical pest control projects by the Forest 
Service and are often directly involved in the monitoring of these projects. 

The control of diseases, insects, weeds, and other pests harmful to man, livestock, 
farm crops, and forests contributes directly to preserving an abundant and healthy 

wildlife population. 

PROTECTING PRODUCERS AND CONSUMERS 

The U. S. Department of Agriculture carries out many programs and works with other 
agencies to help safeguard men, animals, and their environment from the ravages of 
pests and from potential hazards associated with pesticide use. Federal laws and 
regulations administered by USDA govern the movement and sale of pesticides in inter- 
state commerce. Pest quarantine barriers are maintained to keep foreign pests from 
entering the country. Monitoring programs keep watch on pesticide residue levels, if 
any, in meat and poultry products, and measure the effect on agricultural pesticides 
generally. Continuing research is conducted in an effort to find better and safer 
pest control methods. Public education and information programs promote the safe use 
of pesticides. 

Registration 

Every commercial pesticide formulation must be registered with the U. S. Department of 
Agriculture before it can be sold in interstate commerce. Before registration is 
granted, a pesticide must meet rigid tests, proving its claimed effectiveness against 
a particular pest or pests and demonstrating its safety to humans, crops, livestock, 
and wildlife when used as directed. 



3178 



A pesticide manufacturer often must undertake as much as 3 to 5 years of exacting 
scientific research to obtain proof acceptable to the U. S. Department of Agriculture 
of the safety and effectiveness of a single new pest control chemical. In addition, 
the Department itself conducts intensive research on pesticides to assure the develop- 
ment of effective and safe use practices. 

In the two decades since the development of DDT, 2,4-D, and other pest control 
chemicals, over 60,000 pesticide formulations based on more than 800 individual 
active chemical ingredients have been registered with the U. S. Department of 
Agriculture's Agricultural Research Service. 

When application is made for registration of a pesticide with directions for use on 
food or feed crops, the U. S. Department of Agriculture withholds registration and 
notifies the applicant that he must petition The Federal Food and Drug Administration 
for a tolerance to cover any residues resulting from such use. Thip legally enforce- 
able level is set well below the point at which residue might be hajrmful to consumers, 

A three-way agreement was concluded in 1964 providing for coordination among the 
Departments of Agriculture, Health, Education, and Welfare, and Interior on the 
clearance of pesticide registration applications and the establishment of residue 
tolerance levels. 

Forty-eight states have laws which in some degree regulate the sale and use of 
pesticides within the state. A number of states also set residue tolerance limits 
for foodstuffs grown and marketed within the state's boundaries. 

Labeling 

Federal regulations regarding pesticide labels are designed to protect both the user 
of pesticides and persons who may also be exposed. The law requires that key warning 
and caution statements be displayed on the front panel of pesticide labels. The 
nature and scope of any safety claim on the label must conform to the proven facts. 

All pesticide labels must bear registration numbers indicating the product has been 
accepted by the U. S. Department of Agriculture as adequate to permit both safe and 
effective use when label directions are followed. 

During 1965, the U. S. Department of Agriculture had U. S. Marshals seize 71 shipments 
of separate pesticidal products on charges that the products were shipped interstate 
in violation of the Federal Insecticide, Fungicide, and Rodenticide Act. Alleged 
violations included lack of Federal registration, adulteration, misbranding, and other 
illegal practices. 

Watching for Residue 

USDA meat and poultry inspectors conduct a continuing pesticide residue surveillance 
program to insure that meat from animals and birds slaughtered under Federal in- 
spection is free from harmful pesticide residues. The Food and Drug Administration 
monitors the entire range of food products for the same purpose. In total diet 
studies done periodically on marketed foods eaten by a 16-to-19 year-old boy, the 
biggest eater in America, FDA tests have found that residue is either not present at 
all, or is found in amounts so small as to constitute no human health danger. 



3179 



All pest control pro^ranis in which the Department participates and which involve the 

use of pesticides are monitored -- often by outside conservation af;encies--for any 

adverse effects on wildlife, fish, and beneficial insects. The data obtained is used 

in the Dlanning of future programs for maximum safety and effectiveness. 

As part of a national program to monitor the total environment for pesticide residues, 
USDA scientists and technicians are engaged in checking the soil and water at 55 
locations throughout the Nation to determine the extent and nature of residues trace- 
able to agricultural chemicals. These locations cover both agricultural areas of high 
pesticide use and such non-farming areas as forests, plains, arid rangeland, and hard- 
wood regions. 

Federal Pest Control Programs Reviewed, Monitored 

The Federal Committee on Pest Control, established in 1961 at the request of the 
Secretary of Agriculture, reviews all pest control activities in which the Federal 
Government participates. The committee, consisting of representatives of Agriculture, 
Interior, Defense, and Health, Education, and Welfare Departments, examines each 
proposal for soundness of planning and any possible hazards to the public generally 
and to wildlife. Similar review committees have been established in many states and 
provide an added safeguard against possible hazards in pest control programs where 
there is no Federal participation. 

Federal pest control programs involve less than 3 percent of all the pesticides used 
in this country each year. When warranted, the use of pesticides in these programs 
is carefully monitored before, during, and after the program. 

A U. S. Department of Agriculture Pesticides Committee also reviews and directs the 
Department's efforts to develop safe and effective control programs. The Committee 
cooperates with other Federal and State agencies and private organizations to 
coordinate research and to provide effective regulatory programs. 

Quarantine Barriers 

Federally established quarantines against agricultural pests have two objectives: To 
keep potentially dangerous insects and diseases from entering the country, and to 
prevent the spread of established pests from one State or region to another inside 
the country. 

Most of our most destructive agricultural pests are of foreign origin. The majority 
of these were introduced prior to 1912 before the Federal Plant Quarantine Act was 
passed. 

Plant quarantine inspectors of the U. S. Department of Agriculture intercept 
potentially dangerous pests at ports of entry on an average of once every 15 minutes. 
During 1965, inspectors prevented 32,572 insects, diseases, and other plant pests and 
4t6,247 lots of prohibited plant material from entering the United States. They ex- 
amined ships, planes, trains, cars, and — in cooperation with customs inspectors — 
over 36.6 million pieces of passenger baggage. 

USDA animal quarantine inspectors, checking animals shipped to the United States, 
turned back more than 19,600 during 1965 because of disease and other livestock pests. 



3180 



When a major pest accidentally manages to get through the quarantine harriers, the cost 
can be high to farmers and the public. A Federal-State program costing OlO million 
including the expense of extensive aerial spraying was needed to eradicate the 
Mediterranean fruit fly after it slipped into Florida in 1956 and became established 
there. It would have cost the Florida fruit industry $20 million a year to live with 
this pest. 

Similarly the discovery of witchweed, a parasitic native of Africa, in North Carolina 
in 1956, led to a Federal-State control program which cost $25 million through 1964. 
This pest is a potentially serious threat to the country's $5 billion corn, sorghum, 
and sugarcane crops. Multiple herbicide treatments have succeeded in confining witch- 
weed to 35 contiguous counties in North and South Carolina where the damage it does 
is minimal. 

PEST CONTROL WITHOUT PESTICIDES 



From necessity, pesticides will continue to be the major pest control weapons in the 
foreseeable future. However, their use has created special problems such as: 

— some 70 species of insects in the United States have developed 
resistance to chemicals used against them. 

-- the misuse of some chemicals may result in harm to beneficial 
insects, birds, and other wildlife as well as fish. 

Non-chemical pest control methods — including biological, cultural, and mechanical 
— are both very old and very new. These methods sometimes are sufficient, but more 
often their most effective use is in combination with chemical control. Research 
into non-chemical and specific chemical pest control techniques by the U. S. Depart- 
ment of Agriculture has received increasing emphasis and funds in recent years. 
More than two-thirds of the research on insects is now devoted to developing new 
biological controls for major pests and basic information about insects. The search 
for new ways of controlling weeds, diseases, and nematodes also is being greatly 
intensified by USDA. 

Predators and Parasites 

The biological approach to the control of insect pests was one of the early pest 
control weapons developed by U. S. Department of Agriculture scientists. In 1888, the 
Department sent an entomologist to Australia to seek natural enemies of the cottony- 
cushion scale which then threatened the citrus industry in California. He returned 
with the vedalia beetle, which devoured the scale and saved an industry. 

U. S. Department of Agriculture scientific explorers have repeatedly traveled around 
the globe in search of insect parasites, predators, and diseases that might help 
control agricultural pests in this country. In all, some 650 species have been im- 
ported and at least 100 of these have become successfully established here. 

A parasitic wasp brought here from Japan by U. S. Department of Agriculture scientists 
now helps reduce infestations of Japanese beetle in the Eastern States. Other 
beneficial insects introduced into the U. S. are providing some control of such major 
insect pests as gypsy moth and European corn borers, Larch casebearer, and balsam 
woolly aphid. 



3181 



A beetle imported from Australia in 1941+ has brought Klamath weed under effective 
control on 400,000 acres of western rangeland. The beetle feeds on the weed but does 
not eat grass or other valuable plants. Rangeland that was almost worthless for 
grazing because of this weed has been made useful again. 

Sterilization, Attractants 

The screwworm fly, a parasite of livestock, wildlife, and humans, has been eradicated 
from all but a small area of the Far West through a unique program conducted by the 
Department of Agriculture's Research Service and cooperating states. In this program, 
millions of male screwworm flies were sterilized by radiation. Released in infested 
areas, the mating of these sterile males with native females halted the reproductive 
process, wiping out this costly pest. 

A number of chemical sex attractants of major insect pests have been identified and 
isolated. The use of these is being exploited in the hope that they will prove use- 
ful in control work. 



Diseases Against Insect Pests 

USDA scientists are also developing a kind of pest control observed, in nature: The 
killing of insects by their own diseases. The ideal microbial insecticide is one 
that is highly infectious for at least one pest insect but preferably for a large 
number of kinds. It is easily and inexpensively produced. It is capable of being 
stored for a long period. And it poses no hazard to man, animals, or beneficial 
insects. 

Certain carefully tested microbial insecticides are now being used under scientific 
guidance against some forest and farm pests in the United States and other countries. 
In addition, two kinds of microbial insecticides are being produced commercially in 
this country having been registered with USDA for specific uses. One preparation 
contains milky disease spores for killing Japanese beetle grubs, and the other is 
a bacterium for use on a limited number of crops to control certain kinds of cater- 
pillars. 

Trapping, Burning, Flailing 

Three hundred and seventy light traps using ultraviolet or black light lamps caught 
from 50 to 80 percent of the adult tobacco hornworm moths in a USDA experiment covering 
a 113-square mile area of North Carolina. When unmated female moths were added to 
light traps, the catch of male moths greatly increased. 

Flame cultivation, or the selective burning off of weeds using a mechanized multiple 
flame thrower, is gaining wider use in cotton and other crops as a result of the 
recent development of a new hooded flame nozzle and other refinements by USDA 
agricultural engineers. 

Another new mechanical pest control technique developed by the Department involves 
a machine which vacuums up fallen immature cotton bolls or squares and destroys any 
boll weevils on them by flailing. 



3182 



Pest-Resistant Plants 

It usually takes several years to develop a crop variety resistant to a single pest, 
and much longer to incorporate multiple resistances to a complex of insects, diseases, 
and nematodes, which must be controlled on a single crop. 

Twenty-four varieties of wheat resistant to the hessian fly are grown on 8-1/2 million 
acres in 26 States, with the net benefit to farmers estimated at $16,000,000 to 
$18,000,000 per year from use of these varieties. 

The wide use in recent years of four USDA-developed varieties of alfalfa resistant 
to bacterial wilt disease has prevented an annual loss of $100 million in farm income 
that would have resulted from planting wilt susceptible varieties on the same 
acreage . 

Certain varieties of potatoes have been found resistant to at least l"* species of 
insects, including leafhoppers, Colorado potato beetle, and the tuber flea beetle. 

Pesticides Information Center 

The Pesticides Information Center was established in 1965 as part of the USDA's 
National Agricultural Library. Scientific and technical information on pests and 
their control is made available by the Center to scientists, administrators, and 
others working in the pest control field. A Pesticides Documentation Bulletin 
listing pertinent literature is published bi-weekly by the Center. 

USE PESTICIDES EPrECTIVELY AND SAFELY 

The U. S. Department of Agriculture carries on a continuing program to inform the 
public — farmers, homeowners, gardeners, and others -- concerning the safe, effective 
use of pesticides. The Department distributes popular publications on the subject, 
furnishes radio and television stations with safety announcements, produces motion 
picture and exhibits for groups showing, and uses numerous other means of dissemin- 
ating information to the public on pest control and pesticide safety. 

Complementing and reinforcing the national pest control information program are the 
joint Federal-State cooperative educational programs conuucted by the individual 
States working with USDA's Federal Extension Service. These programs are tailored 
to bring detailed information to specific audiences such as farmers, pesticide 
applicators and dealers, gardeners, and others who have specific pest control problems. 
In addition to mass media outlets. Extension makes frequent use of workshops and group 
demonstrations to encourage the safe use of pesticides. 

The States receive all new information on Federal pesticide registrations and 
regulations, and on the latest research-based suggestions concerning the best means 
for controlling pests. This information is available to everyone through local county 
agents or State land-grant universities. 



3183 



Among the materials issued by the U.S. Department of Agriculture on safe, effective 
use of pesticides are: Publications — "Your Home and Safe Use of Pesticides," 
"Farmers' Checklist for Pesticide Safety," "Safe Use of Pesticides," "Aerial 
Application of Agricultural Chemicals," and others. Motion pictures — "Pests or 
Plenty?" and "Safe Use of Pesticides." Slide set — "Safe Use of Pesticides." 

Safety Rules for Pesticide Use 

*" Read the container label ... follow the directions. 

** Mix pesticide solutions in a well-ventilated area, preferably outside. 

** Avoid inhaling pesticide sprays or dust. 

j't* Never smoke while handling pesticides. 

"* When using a pesticide outdoors, apply when there is little or no wind ... to 
minimize drifting of the spray or dust. 

"* Don't use pesticides near wells, cisterns, and other water supply sources. 

** Avoid chemical contamination of streams, lakes, or ponds in order to 
protect fish and wildlife. 

*•' When protecting food crops against pests, observe proper times and rates of 
application. 

** Keep weed control chemicals away from flowers, ornamental shrubs, and other 
valuable plants. 

** Wash with soap and water and change clothing immediately if you spill a pesticide 
on skin or clothing. 

*" If a pesticide is swallowed accidentally, call a physician at once. If 
splashed in eyes, flush with water immediately. 

** Store pesticides in closed, well-labeled containers, where children and 
pets cannot reach them. Do not place near food, feed, or seed. 

** Wrap empty pesticide containers, or those with unwanted pesticides, in heavy 
layers of newspaper and put them in the trash can, if trash collection service 
is available. If there is no such service, carry containers or surplus pesticides 
to sanitary land-fill type dump or bury at least 18 inches deep in a level, 
isolated place where water supplies will not be contaminated. 



3184 




l/4e P^^^^laikd ^d 




FOLLO>V THE LABEL 

U.S. DEPARTMENT OF AGRICULTURE 



3185 

Mr. Johnson. I think there is a wide variance between the kinds 
of legislation that exists in any of the States that they have it. Some 
of it is good. Some of it should be updated. 

Senator Mondale. But the basic point is that insofar as consumer 
protection is concerned, we have authority to prevent shipment of 
contaminated food. But insofar as those most exposed to the danger 
of pesticides, the farm workers, there is no Federal protection. 

jNIr. Johnson. There is not, except that which is provided under 
the Federal Pesticide, Fungicide, and Genocide Act. 

Senator jNIondale. Basically it is a State responsibility, and you 
would have to look at those statutes. And I would ask the staff to 
prepare a study on that, particularly Senator Bellmon's point that 
many of those statutes are not drawn with the protection of the 
worker in mind. He has another kind of point in mind. 

I would like to ask Dr. Simmons a few questions, if I might, since 
I understand he has been making the studies to which you have ref- 
erence. 

Dr. Simmons, you say there are 15 studies which are directed, at 
least in part, at the farm worker. When were these studies begun? 
How sophisticated are they, in your judgment, in reflecting a com- 
prehensive and responsible picture of the exposure to pesticide prob- 
lems of the farm worker of America today? Can you respond to 
that? 

Dr. Simmons. These studies were started in 1965, the first one, but 
they have been added to since then. And it took a considerable pe- 
riod to get people and get them going, so most of them have been in 
full-scale operation 2 or 3 years. Some of them were just started a 
little over a year ago. 

Senator INIondale. Were these studies exclusively directed to pesti- 
cide risks to which the farm workers are exposed ? 

Dr. Simmons. We are studying the long-term effect of exposure 
of pesticides to people, and I would say that probably over 50 per- 
cent of the some — 1,500 people in these studies are farm people in 
one way or another — actual farmers or sprayers, pilots, or something 
of that sort. 

Senator Mondale. Do they tend to be the applicators or the farm 
workers ? 

Dr. Simmons. We have all kinds. We selected the farm workers. 
We selected applicators. We selected, in a few instances, formulators 
and manufacturers. 

Senator JNIondale. Are some of the results of these studies such 
that you can tell us what the disclosures established thus far about 
the dangers to the migrant and farm workers in the use of pesticides 
in the fields? 

Dr. Simmons. As Mv. Johnson pointed out before, the dangers to 
migrant workers are not any greater than to other farmers. And, of 
course, the information you get from one farmer will apply to the 
other. We have not encountered any frank illness or known danger 
to health among farmers using pesticides other than acute illnesses 
caused by accident. But we do not know what will occur after 10 
years or so. But pesticides used as directed according to the label 
which has been approved has not caused illness among farmers. 



3186 

Senator ^Ioxdale. You are not limitino; your study on that condi- 
tion, are you, that the farmer pursued the specific instruction of the 
labclin<r ^ 

Dr. iSiMMoxs. Xo. 

Mr. Joiixsox. Could I amplify that last point a moment, INIr. 
Chairman? When we talk about a "frank illness," we are talking 
about somethinrr that has a cause-etl'ect relationship that puts you in 
a hospital bed and under the care of a doctor because of that. AVhat 
we don't know and what we hope to get some indication of out of 
these conununity studies is, do these low-level exposures contribute 
to liver aihnents or kidney ailments or heart disease or respiratory 
ailments? Fntil we get this kind of an insight into this type of envi- 
ronment to which the worker is exposed, it is very diflficult to say 
that they do or they don't. 

AVe know the people get ill and they get ill from a lot of things. 
For instance, a parallel might be the relationship between smoking 
and health. No one can say for certain, but the highest statistical evi- 
dence of relationship between certain types of manifestations and 
smoking causes us to conclude that this is bad for your health. 

Senator Mondale. Are you saying, then, that the pesticide studies 
are highly tentative in terms of the risk to which a farm worker 
may be exposing himself over the long term? 

Mr. .Tonxsox. That is correct. 

Senator Moxdale. So it should not be taken to be final or defini- 
tive in this field. 

Mr. Joiixsox. It can't at this time. We do not have enough data. 
The studies have not been underway for enough time. We have con- 
siderable time in terms of laboratory and animal experimentation. 
In the final analysis you have to be able to translate in this 

Senator ^Moxdale. You ha\e more research on animals than peo- 
ple? 

Mr. Joiix'sox. It is a lot easier to sacrifice an animal and find out 
what happened to his liver or kidney than it is a human being. 

Senator Moxdale. In this case human, right out there in the field. 

]Mr. Joiixsox'. That is correct. And that is the reason we have 
now designed the kind of studies that will give us the kind of infor- 
mation that will further interpret what we learn in the laboratory. 

Senator ^Toxdale. Dr. Simmons, do you in your office receive re- 
ports from around the country that may be submitted by State or 
local governments, or others, of injuries and deaths related to pesti- 
cides ? 

Dr. SiMMoxs. Not each individual one, but we do receive and 
have published on the mortality and morbidity in this country. 

Senator Moxdale. Does that relate to pesticides? 

Dr. SiMMoxs. Relating to pesticides. 

Senator Moxdale. What do your reports show in terms of morbid- 
ity and mortalities last year relating to pesticides? 

Dr. SiMMoxs. I don't think that we have it for last year, but it 
runs api)roximately about 150 to 200 deaths per year. 

Senator ^Moxdale. From pesticides? 

Dr. SiMMoxs. From pesticides. 

Senator Moxdale. Is that principally farm workers? 

Dr. SiMMoxs. No, not necessarily. I can't give you a breakdown. 



3187 

Senator JNIoxdale. Could you give us a breakdown ? 
Dr. SiMMOXs. I don't know. 

(Thereafter the following information was subsequently supplied 
1 )y Mr. J ohnson : ) 

A Breakdown of the Occupations of People Who Died From 

Pesticides 

Data are not available which would enable us to furnish a complete break- 
down relating occupations to deaths due to pesticide poisoning. 

Senator INIgndale. Do you feel that the 150 deaths reported in 
that last year which you made reference fully reflects the number of 
deaths arising from exposure to pesticides ? 

Dr. Simmons. I don't think so. But it is more accurate than the 
estimated morbidity. 

Senator INIondale. You said that you had 150 to 200 per year or 
something like that. By what magnitude do you think this underesti- 
mates the number of deaths and injuries derived from pesticides ? 

Dr. Simmons. I don't know because there are accidental deaths 
that are diagnosed as something else. And I don't know how many. 

Senator Mondale. In other words, a person may die of pesticide 
exposure. 

Dr. Simmons. Let me give you an example. In Dade County, 
Florida, there were three deaths reported to the Poison Control Cen- 
ter. They happened to have a very good medical examiner, and 
they had recorded 29 deaths. 

Senator Mondale. I read or heard of a specialist in this field who 
says he thinks those estimates are about 400 percent under the actual 
deaths and injuries attributable to pesticides. Would you reject that 
out of hand? 

Dr. Simmons. No, I would not. As I say, we found three at the 
Control Center in Dade Country, and there were 29 at the medical 
examiner's office. I don't think that is a typical one. But certainly if 
you had them thoroughly investigated, you would find them consid- 
erably higher. 

Senator JNIondale. So that we don't know, but it won't be unusual 
if we had an in-depth national survey to find 800 or more deaths per 
year from pesticides? 

Dr. Simmons. Yes. I wouldn't think it would be that much, but I 
wouldn't be surprised. 

Mv. Johnson. I think the answ^er, ]\Ir. Chairman, is that we just 
don't know. 

Senator ]Mondale. Now we are trying to find out whether farm 
workers are exposed to serious risk. We have a national statistician 
who just testified that it is entirely possible that there are 800 or 
more deaths per year. Based upon spot check he finds that to be a 
reasonable i:)ossibility. 

We recognize this isn't a hard scientific fact. We also recognize 
that hundreds of people are dying yearly from pesticides, and we 
want to see a sense of urgency that shows some concern about the 
value of human life. I know that you agree with me on that. 

Mr. Johnson. I certainly do. 

Senator jNIondale. We are trying to get something here we can 
deal with. 



3188 

Dr. Simmons, you talked about the number of deaths, ma^be 150 
to 200, that are actually reported, and the possibility there might be 
four times that. What about injury figures? Do you have figures re- 
flecting that? 

Dr. Simmons. This is not a reportable thing in the States. We 
have studied this for years, and picked up information on it. And a 
lot of other people have, too, and there have been all kinds of esti- 
mates given, anywhere from 100 to 500 for each. We have been us- 
ing — and this is indefensible, but it is all we can do — we have been 
using 100:1. So you can multiply your deaths by 100 and get the 
number of poisonings, but this gain is just a judgment. 

Senator Mondale. So if you had 800 deaths, you could multiply 
that times 100? 

Dr. Simmons. That is right. 

Senator ]\Iondale. To get 80,000 poisonings per year from pesti- 
cides? 

Dr. Simmons. The figure we are using is around 150 to 200 multi- 
plied by 100, because it stays fairly level, that is, the mortality rate. 

Senator ^NIondale. How many years have you been monitoring 
these figures? 

Dr. Simmons. I have forgotten when we first published on it. I 
believe it was — Dr. Durham, do you remember the date we first 
published on the mortality and morbidity? 

Dr. Durham. I think it was 1961, Dr. Simmons. 

Senator Mondale. What has been the trend in deaths and inju- 
ries? 

Dr. Simmons. About the same. 

Senator Mondale. It has held constant. 

Dr. Simmons. About the same. Of course, we don't work this up 
every year. It is a big problem. You have to circularize the States 
and work it up. 

Senator Mondale. You send a questionnaire to the States and ask 
for the figures. How many of the States respond ? 

Dr. Simmons. We get something from all of them. 

Senator Mondale. How many responses do you think are things 
you could use in your statistics? 

Dr. Simmons. Most of them, all of them. We have communitiy 
studies in 15, and they know what is happening in those States. We 
have peoi)le assigned or contractual agreements with 15 others. So 
we have pretty good coverage and have people working in the State 
health departments that can get that data for us. 

But the trouble of it is, they do not always have the correct figure, 
because a lot of this isn't reported. 

Mr. Johnson. I would like to be sure that we keep this in the 
right perspective. 

First, I want the record to be abundantly clear that if anybody is 
concerned about the migrant workers anymore than I am, they are 
well out ahead of the j^ack. I want to be sure that not only the mi- 
grant workei-s and farm workers are adequately protected from in- 
sults that couie from environments. When we analyze the problem, 
we want to be sure we don't use one set of statistics which are some- 
what obscure in terms of a specific objective that we are shooting too 
far and draw a wrong conclusion. 



3189 

These 150 to 200 deaths inchide suicides. They include accidents. 

Senator INIoxdale. What percentage are suicides ? 

Mr. JoHXSOX. I am not sure. 

Senator Moxdale. What do you guess ? 

"Sir. JoHxsox. I would not hazard a guess, but I will be glad to 
look these up and see if we can give you a breakdown on it. The 
mortality figures should not be too difficult to answer, is that correct. 
Dr. Simmons? But they do include suicides, they do include even 
this as a homicidal weapon. 

(The following information was subsequently supplied by Mr. 
Johnson:) 

What Percentage of the Deaths From Pesticides Are Suicides? 

There is no way to determine on a nationwide basis, ttie number of suicides 
from tlie use of pesticides. In most States, tliere is simply no single category 
of suicidal, accidental, or homocidal deaths which represent poisoning by pes- 
ticides. In the case of both suicides and homocides, these are frequently re- 
pDrted as accidental deaths unless there is definite proof to the contrary. The 
available data on this question is from Dade County, Florida where informa- 
tion of mortality records for the years 1956 through 1967 showed a total of 
121 deaths attributed to pesticides, 69 of which were placed in the category of 
suicide. This is about 57.4% of pesticide deaths attributable to suicides in this 
study. 

]\Ir. Jonxsox"^. This occurred again down in Florida just last year, 
where one man poisoned his whole family with parathion. 

It also includes accidental deaths and these airplane pilots that 
you hear about dying. 

Senator Moxdale. It is not just the farm workers, but if the pi- 
lots are flying in the field, because they have been poisoned because 
of what they are flying, might it not be a reasonable inference that 
it is not healthful to the workers on the ground either? 

Mr. JoHxsox. We all agree there is some hazard to the workers. 
What we do not agree on is the degree of risk and what can be done 
about it and whether or not the pesticides are being used outside of 
their recommended limitation. 

Senator ]\Ioxdale. That is right, doctor. I am not being critical of 
you, because this is our problem. It is not yours. Until we agree, we 
are letting the farmworker take the risk and continue to die and 
suffer injury, that is what bothers me. 

INIr. JoHy;so's. I am not sure that is a valid conclusion. 

Senator Moxdale. You tell me why it isn't. 

Mr. JoHxsox. I think what we are talking about is that within 
the limitation of the knowledge we have — and it is our job to assess 
this in terms of the environment — we believe that if the users of in- 
secticides use these within the limitations of their prescribed usage, 
which are set out by the labels, that our Food and Drug Adminis- 
tration examines on the basis of the scientific evidence that they 
have, that the risk in terms of the need are within the bounds of 
safety. And we are continuing to study it because scientific knowl- 
edge is never firm. It is always changing. As we get more knowl- 
edge, then we do things differently. But you can't just stop every- 
thing. 

I might give as an example that we know 50,000 people a year are 
killed by automobiles. 



3190 

Senator ]Moxdale. That is right, and we passed the Auto Safety 
Act to do soniethin<i: about it. We now know there is an act that 
gives you authority to protect the consumers — and I am glad you 
have it — from the distribution of foods that have dangerous contam- 
inants. But you have no simihir authority to protect the farm work- 
ers who are most exposed. 

Mr. Joiixsox. I am not saying we shonl(bi't have the authority. I 
want to be sure we get the problem in the right perspective. 

Senator Mondale. I lespect what you are doing. I respect your 
work. But the thrust of your testimony is to try to play down the 
risk. 

Mr. Joiixsox. Absolutely not. I think, Senator INIondale, that 
within the Department, when I came on board July 1 of last year, 
one of the first tilings that I said we were going to give high prior- 
ity to was the problem of the pervasive use of pesticides in this 
country. And we have proceeded to do that. 

I just want to be sure we do it within the realm of scientific 
knowledge and reason and not one of emotion. I think that there is 
a lot of evidence that points to exactly what you are saying. But 
when we begin to zero in on the specifics, let's be sure that we are 
doing it on the basis of the best knowledge that we can project. 

I am supporting what you are trying to do, but I want to be sure 
we do it in the right perspective with the best knowledge and that 
we don't do it on the basis of emotional appeal. 

Senator Moxdale. ]Mr. Johnson, would you agree with Dr. Sim- 
mons, who estimated it is not an unreasonable suggestion that 800 
people are dying annually from pesticides, and that a multiple of 
lOO-to-200 times that are being injured from pesticides? Would you 
disagree with that figure? 

Mr. Joiixsox. I am saying there is no basis for agreement or dis- 
agreement. I don't know the statistics. T'ntil I could see the basis 
against which that assum])tion was made, I have no basis for agree- 
ing or disagreeing. I don't think very many people do, and I think 
anybody who thinks they know that, when there is absolutely no sys- 
tem for collecting the data — but that doesn't mean I am not in sym- 
pathy with having a need to have that kind of data, that I am not 
in sympathy with the need to i)rotect the workers. 

Senator ^Ioxdale. ]Mr. Johnson, if you say there are no such sta- 
tistics that assist you in recommending measures to protect the 
farmworkers, when will you have the figures that will be sufficiently 
persuasive to you to justify legislative recommendations? Will it be 
next month, the end of the year, or when will we have the figures? 

]Mr. Joiixsox. Certainly it will not be next month. The statistics 
we can give you in the immediate future are those we knoAv we 
can get and place i-eliance on. Basically the^se are mortality data. 
Until we have a system that requires the reporting of morbidity data 
in terms of toxic i)oisonings, either acute or long-term effects, we 
will have to make some estimates. This system really has not been 
set up. 

We will continue to utilize the knowledge, the information and 
data that we get fi-om the States and give the best estimate that we 
can. To project these beyond the data that you get, I think, is court- 
ing with unreality and is a very difficult and hazardous thing to do. 



3191 

Senator INIoxdale. Are you testifying that the present data base 
will not disclose that which will be. sufficient to justify any action to 
protect the farmworker? 

Mr. JoHxsox. I have not said that in anything that I have said. 

Senator Moxdale. Would you tell us when you will have data 
that you think will be adequate? 

Mr. JoHxsox. I think we have data that tells us we have a prob- 
lem out there. I would not have even become interested in pesticides 
if I didn't think the current research and knowledge and informa- 
tion gave us that evidence. 

What I am saying is that I don't think that data is specific 
enough to tell us exactly what we have to do. It tells us we have to 
do something, that's all. 

Senator Moxdale. Could you tell us what steps you are taking to 
get the specific data? 

Mr. JoHxsox. The Secretary of HEW has established the HEW 
Commission on Pesticides in the Environment, as discussed in our 
statement. I believe we are going to get from it some guidance and 
expertise, in a consolidated fashion that will give us a better basis 
against which to make the decisions that you are talking about. I 
certainly think that our 15 community studies are producing data 
and information that will have to be taken into consideration. I 
would hope that we are not talking about something of a long-term 
nature. I think we have to keep things w'ithin the realm of scientific 
recognition and there will be a time, I hope in the very near future 
(and this could be 1 or 2 years) when we are going to do something 
on the basis of the information we have. We will do it promptly, 
and then we are going to modify this on further evidence as it 
evolves through our study and demonstration processes. 

Once again I want to say that we are an actuary agency. We are 
going to do something to protect the health of the people in this 
country. Pesticides are one of the things threatening in some degree 
and there may be other alternatives and we hope we can find this, 
but we can not look at this in a vacuum, we have to look at it in the 
total effects of what does it do to our health in all aspects, and that 
is what I hope we are able to do. 

Senator INIoxdale. Do you have data indicating the tolerance lev- 
els for aldrin? 

Mr. JoHxsox. For which product? 

This will vary depending on the products you have in mind. 

Senator Moxdale. For aldrin on grapes ? 

Mr. JoHxsox. For grapes we have 7 parts per million tolerance 
for grapes with aldrin. 

One tenth per part per million in aldrin. 

Senator INIoxdale. I have a survey here prepared by C. W. Eng- 
land, dated August 1, 1969, submitted to us by the Farm Workers, 
that Thompson seedless grapes being sold in Washington Safeway 
Stores had 18 parts per million of aldrin. 

]Mr. JoHxsox, Certainly, ^Nlr. Chairman, if that were so, and those 
samples were submitted to the FDA so we would be sure that the 
analytical technique was scientifically accurate, we would ban those 
grapes from the market. 

36-513 o — 70 — pt. 6A 13 



3192 

Senator Moxdale. We will give you a copy of this and I would 
ask you to immediately determine whether that is true. 

]\lr. JoHxsox. "We would be jjlad to. 

Senator ^Iondale. Thank you very much. I would like to express 
my ai)preciation to all of the members of the panel. 

Mr. Johnson. Thank you. 

Senator Mondai.e. We will print your prepared statement in its 
entirety at this point in the record. 

(The prepared statement of Mr. Jolinson follows :) 

Prepared Statement of Charles C. .Johnson, Jr., Administrator, Consumer 
Protection and Environmental Health Service, Public Health Service, 
U.S. Department of Health, Education, and Welfare 

Mr. Chairman, at the pre.sent time the pesticides programs of the Consumer 
Protection and Environmental Health Service are directed primarily at protec- 
tion of the public and of those workers directly involved in the manufacture, 
handling, or application of i>esticides through spraying or dusting operations. 
The possible harmful effects to migrant agricultural workers, who commonly 
work at such jobs as thinning, weeding, or picking, have not been the .subject 
of specific investigation. I believe, however, that certain of our findings have 
at least limited relevance to the situation of such workers ; and there is no 
doubt that controls instituted primarily to protect pesticide applicators and 
minimize residues on food crops serve, at the same time, to hold down expo- 
sures for all agricultural worl^ers. I am sorry to say that we have, at this 
time, no scientific data which would show, without question, that the margin 
of safety thus provided is adequate in the ca.se of migrant workers. 

Regulation of the use of pesticides is carried out by several agencies. The 
re.siM)nsibility for registration of pesticides and pest control materials has been 
placed in the U.S. Department of Agriculture. These products may not be le- 
gally shipped in interstate commerce without prior registration as required by 
the Federal Insecticide. Fungicide, and Rodenticide Act. When the proposed 
use of a pesticide will result in residues on a feed or food crop, the registra- 
tion by USDA is not granted until a tolerance has been established by the 
Food and Drug Administration. Before registration, the petitioner must pre- 
sent FDA with experimental evidence on toxicity to establish what tolerances, 
if any, will be safe and to show that the tolerances can be met under the 
practical conditions of i)esticide usage and to .specify the conditions of use on 
the labeling for tlie i)esticide. 

Tlie Department of the Interior has programs designed to protect fish and 
wildlife from pesticidal ccmtamination ; the Department of Transportation reg- 
ulates shipment of i)esticides by interstate carriers ; and the Department of 
Defense has .several programs involving the use and/or control of pesticides. 

The various States and local governments also have requirements aimed at 
safeguarding the safety of citizens from the hazards of pesticides. 

A Memorandum of Agreement between the Departments of Agriculture, Inte- 
rior, and Health, Education, and Welfare was entered into in 19(54 to coordi- 
nate tlie i)rograms of the.se Departments in pesticide u.se and control, pursuant 
to a report of the President's Science Advisory Committee pointing t(t the need 
for closer coordination and recommending that responsibility for the health as- 
pects of pesticide u.se be vested in the Department of Health, Education, and 
Welfare. 

The many different synthetic chemical pesticides can be grouped into three 
cla.s.ses : the chlorinated hydrocarbons, organic pho.sphates, and the carbamates. 
We have prepared a chart showing representative pesticides in each of the 
three classes and their effects on man, including symptoms of poisoning. Mr. 
Chairman, I would like to submit tliis chart for the record. 

I believe it would l)e useful, first of all, to review the responsibilities and ac- 
tivities of CPEHS in this area, tlien to relate these, insofar as jtossible. to the 
subject of your incpiiry. (There are a number of other agencies in the Depart- 
ment of HI]W who.se programs also relate to the health and welfare of migra- 
tory farm workers, and we will submit for the record, summaries of these pro- 
grams if you wish. ) 

Under the Pesticide Chemicals Amendment to the Federal Food, Drug, and 
Cosmetic Act, pesticides which are not generally recognized as safe by quail- 



3193 

fied experts may not be present in or on raw agricultural commodities for food 
use unless a safe tolerance (which may even be zero) has been established by 
FDA. 

The primary responsibility for obtaining proof of safety of residue toler- 
ances is placed on the industry or firm promoting the use of pesticide chemi- 
cals. The FDA is responsible for the scientific judgment concerning the safety 
of the tolerance. As of July 1, 1968, there were 3,115 tolerances or exemptions 
established on 175 pesticide cliemicals. New pesticide chemicals, formulations, 
and other methods of insect control are constantly being developed. New toler- 
ances are required and existing tolerances must be reviewed in terms of cur- 
rent agricultural practice and need, in keeping with the policy that tolerances 
should not be higher than necessary for safe and efi:ective use. 

For example, FDA has recently published an order to reduce DDT toler- 
ances. This action was initiated by a finding that good agricultural practices 
would permit lower tolerances ; in fact, analysis of a large number of samples 
over the past several years showed that the level of DDT found on most fruits 
and vegetables is far below the 7 ppm tolerance for that pesticide. Some other 
tolerances have also been reduced. The intent is to establish tolerances no 
higher tlian needed in current good agricultural practices. 

The Food and Drug Administration carries out other activities of control 
and investigation with respect to pesticides. There are surveillance activities to 
determine compliance with tolerances and sanctioned uses which includes 
inspectional investigations in the growing fields and the analysis of pre- and 
post-harvest samples. There are information and educational activities to keep 
the grower and cooperating State officials knowledgeable of our findings, both 
good and bad. This assists tlie grower in avoiding shipments of foods with ille- 
gal residues. There are control activities to remove hazardous foods from con- 
sumption channels through State and Federal legal actions. Furtliermore, there 
are total diet investigations, which are used as an index to the dietary intake 
of pesticide residues, and community epidemiological and ecological studies. 

FDA has a primate research laboratory at Perrine, Florida. Here, the long 
and short term toxicology and biochemistry of pesticides and related chemicals 
are studied in primates and the results of these studies used in assessing haz- 
ards to man from environmental exposure to these chemicals. 

Investigations bearing specifically and directly on the hazards of pesticides 
to agricultural workers and others associated with the handling and applica- 
tion of pesticides are conducted by tlie Wenatchee, Washington Research Labo- 
ratory of FDA's Division of Pesticides and the Division of Community Studies 
located in Atlanta, Georgia. 

Mr. Cliairman, there are currently 15 Community Studies in progress under 
contract with State health departments and universities, and I have a sum- 
mary of these for tlie record if you so desire. 

These studies consist of epidemiological and ecological investigations in 
areas of heavy i)esticide usage throughout the United States. Within each 
study area a pesticide usage profile is developed. Concurrently, levels of pesti- 
cides and their metabolites in man and the environment are determined. These 
data should eventually provide information on the movement of pesticides in 
the environment and their routes of entry into man. Basically, each study con- 
sists of compiling the medical history of about 100 volunteers selected because 
their occupations or their environment subject them to greater exposure to pes- 
ticides than the population at large. A group of individuals with minimal pes- 
ticide exposure are selected to serve for comparison purposes. 

These investigations include the direct measure of exposure of workers by 
methods such as attaching absorbent patches on the skin of spraymen during 
actual spray operations. Measurements of this sort and/or respiratory inhala- 
tion have been carried out for a number of pesticides and for workers doing 
various agricultural jobs as.sociated with .spraying or dusting operations. 

The Division of Community Studies also assists State officials in conducting 
State pesticide projects. These projects are designed to determine pesticides- 
related health problems within the States and to improve the State and local 
competency in handling these problems. Each project consists of a multifacted 
program including training in the safe u.se of pesticides, surveys to develop 
pesticide usage profiles, pesticides safety review, environmental monitoring, dis- 
po.sal of pesticide wastes, monitoring of people, morbidity and mortality report- 
ing, and comprehensive planning and activating of programs on the public 
health aspects of pesticides. 



3194 

The present results of our community studies indicate that, in general, work- 
ers using pesticides in agriculture and puhlic health vector control are ex- 
posed to relatively small fractions of the toxic dose each day. Since migrant 
agricultural workers generally work at jobs not directly associated with i)esti- 
cide application, their exposure levels would tend to be lower. For example, 
workers picking malathion — an organophosphate pesticide — treated beans have 
significantly less exposure than the pesticide sprayers treating these beans. 
However, it must also be borne in mind that spraymen may be expected to 
wear protective clothing and to observe other recommended safeguards not ob- 
served by workers in the fields. 

Residues on crops have, in a few instances, caused poisoning in agricultural 
workers from occupational exposure. Eleven episodes of poi.soning from contact 
with parathion residues involving more than 70 persons were reported as early 
as 19r)S. 

The crops involved in these episodes of poisoning by residues have included 
pears, apples, grapes, citrus fruits, and hojKs. The poisoned workers were en- 
gaged in picking, thinning, cultivating, or irrigating. 

Outbreaks involved exposure to foliage or fruit sprayed not more than two 
days earlier, but in some cases, the age of re.sidue was as much as 33 days. 
Absorption of toxicant was favored by failure to wear protective clothing or 
by the persi.stent wearing of contaminated clothing. Outbreaks of residue poi- 
soning in peach orchard workers in California were reported in 1964. 

In line with its responsibilities in reviewing registrations and labels, FDA 
recommended to I'SDA in August. IIKJS that consideration be given to requir- 
ing the ijo.sting of signs warning against entering fields treated with highly 
toxic pesticides and specifying a date which treated fields may be safely en- 
tered. The State of California has such a requirement for certain pesticides. 

It is well to bear in mind that exposure to pesticides is only one of many 
factors affecting the health of farm workers, as well as all citizens of this 
country. Today the farm worker may be expo.sed to an ever-increasing variety 
of body insults from his environment including agricultural chemicals, inade- 
quate diets, a lack of sanitation, poor sewage disposal, and low quality hous- 
ing. The collective and cumulative effects of these exposures are only partly 
known. While the health of an individual might tolerate slightly polluted 
water, air or food, he probably cannot adapt to their collective attack without 
adverse effects. If at the same time he is subject to noise, crowding and other 
environmental stresses, his health and well-being can be damaged or destroyed. 
Efforts to identify the effects of a single stress or a single route of exposure 
cannot hoi^e to define the impact of the total environment on the individual. 

This complex interrelationship of all environmental impacts is well illus- 
trated by findings recently revealed by an FDA research team conducting a 
community study in Dade County, Forida. They have discovered that 125 pa- 
tients taking phenobarbital or diphenylhydantoin (two drugs widely used to 
control convulsions) had strikingly lower levels of DDT residues in their blood 
than the average of the general population, and that such residues were non- 
existent in the fat of four patients. 

AVe have not, as yet, evaluated the medical significance of this discovery ; 
however, it is certainly ;i most iiit(>resting development. 

Pesticides have made significant contributions toward elevating our standard 
of living during the 20th century. They have controlled malaria, typhus, dysen- 
tery, plague, and other dis(>ases transmitted by insects. They have also brought 
vast economic and social l)enefits through better health and increased quantity 
and quality of foodstuffs. 

In less than 20 years, the production of synthetic chemical pesticides in the 
United States has increa.sed from a level of a few million i)ounds a year to 
nearly 1 billion pounds annually. Almost 60,000 pesticide formulations are now 
registered in the T'nited States, and each of these contains one or more of the 
approximately SOO different pesticide compounds. 

The increased production and use of pesticides as well as many other in- 
dustrial chemicals has witliout doultt presented increased hazards to the health 
of many persons . . . manufacturers' employees, applicators, migrant and other 
farm workers, and the consumer. It is difficull to estimate the incidence of ill- 
ness due to pesticide iJoisoning as reports of these poisonings are not required 
in most States. The mortality rate in th<' totiil population due to poi.soning by 
pesticides is estimated at 1 fatality per 1,000,000 population per year. This 
figure includes intentional ingestions of pesticides in suicides. [Staff note: See 



3195 

letter correcting this sentence appearing at tlie end of the statement.] There is 
need for more data and better statistics. The reporting systems need strength- 
ening on a nationwide base. All cases of pesticide poisoning should be investi- 
gated. To actually bring this about would require that physicians report all 
cases involving significant exposure to pesticides and that adequate time and 
personnel be available to conduct epidemiological investigations. 

Mr. Chairman, there are a number of other problems which we face in 
carrying out our mission. For example, the 15 Community Studies are not 
fully staffed because of the diflSculty in obtaining qualified people. We would 
like to fully staff' the present community studies and to provide staffs to other 
States that would like to participate. 

Mr. Chairman, Public policy for the use of pest control chemicals involves 
many considerations. The interrelated Federal, State and local efforts are in- 
dicative of the complexity of most environmental problems. We, at HEW, are 
keenly aware of the work being done in the field of pesticides by other depart- 
ments and every effort is made to avoid duplication of effort. 

In fiscal year 1969, FDA spent $14,618,000 on activities associated with pesti- 
cides. These funds have been concentrated in studies where current knowledge 
indicates the most exposure to pesticides. 

With the creation of the Consumer Protection and Environmental Health 
Services on July 1, 1968, the Department of Health, Education, and Welfare 
focused in a single agency the responsibility for identifying health hazards in 
man's environment, developing and promulgating criteria and standards for the 
control of such hazards, and carrying out appropriate corrective programs. 
Thus the mission of the Consumer Protection and Environmental Health Serv- 
ice is to assure effective protection for all against controllable hazards to 
health in the environment and in the products and services which enter our 
lives. 

On April 21, 1969, Secretary Finch appointed a Commission on Pesticides 
and Their Relationship to Environmental Health. Dr. Emil Mrak, retiring 
Chancellor of the University of California at Davis, an internationally re- 
nowned authority in the field of food chemistry, is Chairman of this Commis- 
sion of experts from the fields of environmental health, agronomy, entomology, 
and from industry. Their mission is to evaluate all aspects of pesticide usage 
and report their recommendations for research and policy guidelines by Octo- 
ber, 1969. 

We are concerned with all aspects of pesticide usage — the benefits and the 
risks — as they affect the health of all our people. 

This concludes my statement Mr. Chairman. If you or other members of 
your Subcommittee have questions, I will be happy to try to answer them. 



Depaetment of Health, Education and Welfare, 

August 29, 1969. 
Hon. AValter Mondale 

Chairman, Subcommittee on Migratory Labor, 
Committee on Labor and Public Welfare, 
U.S. Senate, 
Washington, B.C. 

Dear Senator Mondale : On August 1, 1969, I testified before the Senate 
Subcommittee on Migratory Labor. On page 8 of my written statement pre- 
sented at that hearing I stated : "The mortality rate in the total population 
due to poisoning bj' pesticides is estimated at 1 fatality per 1,000,000 popula- 
tion per year. This figure includes intentional ingestions of pesticides in sui- 
cides."' 

I have learned from the Director, Division of Community Studies that this 
above statement is not correct in that recognized cases of suicide and homicide 
are excluded from the above estimate. Therefore, I ask your permission to 
change "includes" in the above statement in the record to "excludes". 
Sincerely yours, 

Charles C. Johnson, Jr., 
Assistant Surgeon General, Administrator. 

Senator JSIoxdale. Our final witness is Mr. Jerome Gordon, Presi- 
dent, Delphic Systems and Research Corp. 
Mr. Gordon. Thank you, Mr. Chairman. 



3196 

Senator Mondale. You may proceed as you wish. You have a pre- 
pared statement. 

Mr. (tordox. I liave submitted my prepared statement to you for 
the record, Mr. Chairman. 

(The prepared statement of ]Mr. Gordon follows :) 

Statement Of Jerome B. Gordon, President, Delphic Systems 
Reseaucii Corp. 

introduction THE DANGER AND THE THREAT OF PESTICIDE POISONING 

I should like to start off the discussion today, by asking what the following 
three women, one, a young mother of two children and the wife of a farmer in 
Lubbock. Texas, another a mother of four children in suburban Westchester 
County, New York, and lastly, a farm worker in Coachella, California have in 
common with each other and the subject matter of today's hearing : Pesticide 
Safety and Farm Workers? The answer is amazingly simple, yet vitally dis- 
turbing. 

All of them have been seriously poisoned by highly toxic pesticides developed 
from nerve gas research to the extent that they have either been seriously dis- 
abled or actually paralyzed ! 

To make matters worse, all of them are victims of a carelessly regulated ag- 
ricultural chemical industry and all three have been on the receiving end of 
some of the most blatant forms of arrogant bureaucracy in this country. Yet 
their plight, as hapless, as totally inconceivable to the minds of most Ameri- 
cans, can be niultipled several hundred thou.sand-fold in the unwritten, luispo- 
ken anguish of the nation's farm workers. It is brought home by the following 
facts that — over tifty million pounds of a pesticide, originally developed in WW 
II as a German Nerve Gas, are being spread luichecked on America's farms 
and garden.s. The result is tliat iinc'tinitcd thousands of the nation's migrant 
farm workers, farmers and suburban homeowners have been fatally overcome 
or seriously di.sabled. 

To compound the felony, U.S. manufacturers export almost 60 million lbs. of 
the deadly materials to users overseas, the largest consumers being Canada 
and Mexico. Within domestic agri-business the big users are the connnercial 
fruit-crop growers in California and the cotton producers in Mississippi and 
Texa.s. Together, they account for almost one-half of the acreage treated by 
pesticides annually in the U.S. 

The very fact that this situation actually exists in this country, and that all 
three groups ; the farm worker, the farmer and the suburbanite are powerless 
in changing it is why this hearing is being held today. 

Even more foreboding is the prospect that the occupational and general 
health danger from the.se "nerve agent" pesticides could ironically increase in 
the future, with the proI)able banning of persistent insecticides such as DDT 
and DDD by many states and the federal government. This bizarre situation is 
the product of an unwieldy and unresponsive federal and state pesticide regula- 
tory program that has permitted the increased production and use of these 
deadly nerve agents, but has not subsidized the development of more selective 
and less toxic sub.stitute pesticides by the U.S. agricultural chemical industry, 
even in the wake of the pesticide crisis raised by the publication of Rachel 
Car-son's book, the "Silent Spring" in the early nineteen sixties. 

THE POISONING POWER OF ORGANIC PHOSPHORS 

The pesticides in question derived from German nerve gas research, are 
called organic phosphors and appear under such trade names as Parathion, 
Methyl Parathion, TEPP, and in less lethal dosages, as Malathion. They are 
first cou.sin.s, chemically, to the nerve agents GB and VX involved in the cur- 
rent chemical and biological warfare controversy. 

The odorless, colorless licpiid or powder form of the pesticide is so i)owerful 
that a minute amount — -less than .00424 ftf an f)unce, swallowed by a human is 
fatal in less than five minutes! Even under ideal condition, continued cinnula- 
tive expr)sure can result in disabling partial jiaralysis and mental debility. 

Both the organic pliosi)hor coniiiouiids and the war gas nerve agents GB and 
VX u.se the same "kill mechanism." They prevent the manufacture of enzymes 
which carry body "messages" controlling respiration. 



3197 

In other words, victims simply suffocate. Early symptoms include pinpointing 
of eye pupils, tightness in the chest, convulsions, paralysis and finally respira- 
tory failure. Even more insidious is that less than lethal dosages of the pesti- 
cides have symptoms resembling the onslaught of an attack of flu ! 

THE VICTIMS 

To illustrate the monstrous power of the pesticides, let us discuss the case 
of one of the three women mentioned earlier, Mrs. John Ford of Lubbock, 
Texas. 

One glowing afternoon in September of last year, a Piper Pawnee crop-dust- 
ing plane buzzed monotonously over the fields adjacent to the cotton growing 
area surrounding Lubbock, Texas. The plane, operated by a pesticide applicat- 
ing service based at nearby Shallwater Airport was spreading the pesticide 
Parathion as protection against a blight of "green bugs" infesting the neigh- 
boring farm. Mr. Ford and his two young children were in town on some er- 
rands, Mrs. Ford a young mother of 28 was preparing the evening meal. Noth- 
ing unusual you might say. Just a typical country scene. 

However, there was one difference. Mrs. Ford was being slowly paralyzed 
from the waist down through insidious little enzymes called cholinesterase re- 
leased by the pesticide Parathion and attacking the vital function of her cen- 
tral nervous system. 

The morning after the crop-dusting incident, Mrs. Ford felt that she was 
coming down with a touch of the flu — the first symptoms of Parathion poison- 
ing. This wasn't unusual either, since a fiu epidemic had broken out in Lub- 
bock the week before. 

Mrs. Ford isn't one to be overly concerned about ailments concerning 
herself — she is when it comes to her children. But, at her husband's urging she 
went to see her family physician to get a flu shot. Her physician examined 
her and diagnosed the ailment as the "flu" and gave her the prescribed dosage. 
E)verything seemed to be improved for a while, except that by the end of the 
first week following the incident, Mrs. Ford began to feel a numbing in her 
lower body and gradually began to lose control over her legs. It was during 
this period that she consulted a second physician who correctly diagnosed the 
case as Parathion poisoning; however, it was too late to apply the antidote. 
Atropine. Mrs. Ford was lucky to be alive, but the control over her lower 
limbs will be a long time in returning to normal use. She is a victim of the 
carelessness and callousness of both government, industry and the medical pro- 
fession. 

What was interesting about Mrs. Ford's case was the perniciousness of the 
pesticide, Parathion. Mrs. Ford was inside the house, while the spray plane 
was delivering its deadly product. Further, the pesticide had penetrated so 
deeply into everything on the Ford homestead ; that a chemical analysis of the 
peach trees on the property showed traces of Parathion particles in the pits ! 

What did the applicator anfl the manufacturer of the chemical, W. R. Grace 
and Company have to say? Nothing. It is their contention that Mrs. Ford is 
psycho-somatic and is imagining her chronic condition. Nor, would they reveal, 
what the contents were of the pesticide — the manufacturer is protected under 
U.S. law from ever revealing the chemical formulations of his product. 

Because of an epidemic of "green bugs" again this past spring, Mrs. Ford 
was forced to move several hundred miles away to New Mexico during the 
spraying period, because Parathion was again being applied to her neighbor's 
property ! 

Actually, Mrs. Ford was probably not the victim of Parathion, but rather a 
"frankenstein-like" compound called Paraoxon. This compound, evolved from 
the excessive and frequent use of Parathion, has been found to be 2 to 3 times 
as toxic as Parathion itself ! In that regard, Mrs. Ford has a lot in common 
with the 1S6 peach orchard farm workers who were poisoned by the compound 
in a 1962 massive outbreak of pesticide residue poisoning in California. 

Writing on the subject of "Parathion Residue Poisoning Among Orchard 
Workers" in the August 1964 edition of the Journal of American Medical Asso- 
ciation, public health researchers; Milby, Ottobani, and Mitchell noted the fol- 
lowing from their investigations of the pesticide disaster. First, that the out- 
break occurred even though the Parathion application met the State of 
California standard of 2.5 pounds per acre followed hy a H day interval be- 
ttcccn spraying and harvest. Second, that the illnesses ivere the result of resi- 



3198 

due accumulated related to total amount of Parathion applied during the en- 
tire growing period. All this goes to show is that even if you follow the intent 
of the present pesticide control laws you still can get hurt I 

But I'arathion and the other organic phosphors can be fatal. Let's look at 
the sickening roll call. 

Just this past June, the Dominican Republic reported 8 accidental deaths 
from I'arathion poisoning of river water. The same statistic last year was 
over 30 fatalities. 

In an eighteen month period over 1966 and 1967, six California farm work- 
ers died from pesticide poisoning. They had mistaken the pesticides for wine 
or water because they were in unmarked bleach containers, a violation of the 
California Farm Safety Regulations. 

In 1965, twenty-eight persons in San Diego, Calif., were poisoned by the pes- 
ticide diazinon which accidentally contaminated doughnut mix in a local bak- 
ery. 

In 1967, in nearby Tijuana, Mexico, 17 persons were fatally poisoned and 
300 were reported ill when Parathion was carelessly spilled on a truck which 
was later used to transport confectionery sugar. 

In California, fruits and vegetables, not cheesecake on the silver screen or 
the esoteric production of integrated circuits for complex electronic gear, is 
the leading industry. I'roduction of table grapes is a billion dollar industry. 
Over one hundred million pounds of pesticides — 20% of the nation's total — are 
used in California's agri-business. Not so surprising, the agricultural industry 
has the highest occupational di.sease rate — over 50% higher than the industry 
in second place and almost three times as high as the average rate for all in- 
dustries in the state. 

Pesticide poi.'^oning is high among the mo.st serious causes of fatal and non- 
fatal occupational diseases. The number of doctors' reports involving pesticides 
and other agricultural chemicals have doubled since 1951 and in California 
have ranged from 800 to 1,100 reports annually. Over the ten-year period from 
1955 to 1965, about one occupational death from pesticides has been reported 
for each 100 reports of occupational poisoning from these chemicals. The vil- 
lains in these cases are the familiar family of phosphate ester pesticides — Para- 
thion, Phosdrin and Thimet, Demeton and Tetraethyl Pyrophosphate (TEPP). 
The wonders of chemical technology have made the unit costs of these pesti- 
cides so cheap that, for example, $5 worth of Parathion is sufficient to cause 
the death of several thou.sands people if dispensed without proper controls. 

While farm workers in California are exposed to considerable risk of pesti- 
cide i)oisoning, the most formidable record of occupational disease and injury 
is in the agricultural aircraft industry. Pesticides are applied by air to half of 
the acreage treated in California. 

The complement of 1,000 agricultural pilots apply about 10 to 15% of the 
nation's pesticides, at a considerable price. One pilot is killed in an air acci- 
dent for each million acres treated. In addition to having the highesst fatal in- 
jury rate of any occupation in California, over half the disal)ling work inju- 
ries are due to pesticide poisoning. For most other industries the occupational 
disea.se injury rate is 5% or less of total work injuries. However, considering 
the amount of pesticides and other agricultural chemicals used by this group, 
the co.st in occupational di.'sease is considerably less than among farm workers 
and ground applicators who apply the other half of the.se chemicals. 

The frequent victims of pesticide poisoning are children. In the period from 
1951 to 1965, roughly 60% of the accidental deaths attributable to poisoning 
from jtesticides in California were among children. The nH)st frequent causes 
for this toll are the improper safeguards — in the private home or farm — for 
the storage of pesticides and the contamination of clothing l)y adults in the 
hou.sehold or on the job who apply the chemicals. Two incidents drawn from 
the annals of the California Department of Public Health files are representa- 
tive : 

An 18-month old child of an agricultural aircraft pilot was found at home in 
a state of acute respiratory distress, semi-conscious and with "pin-point" pu- 
j)ils of the eye.s. She was rushed to a local hospital and treated by a physician 
for severe organic i)hosphate poi.soning. Fortunately, she recovered. On the 
morning of her illness, her father had come home after ap[)lying a highly toxic 
phosphate ester pesticide. He cleaned his boots with paper towels, threw them 
in a nearby wastebasket and put his boots in the bathroom. The child con- 
tracted the poisoning from either the boots or the paper towels. 



3199 

In the second instance, a group of families, witti children, were picking ber- 
ries on a farm. They were followed by a spray rig carrying a five gallon tank 
of TEPP concentrate. A four-year old girl sampled the can, which her older 
brother had opened. She died in twenty minutes. 

Because of readily available supplies of pesticides for both commercial and 
private use, suicide and accidental deaths from pesticide poisoning is an increas- 
ing problem. While only 13% of pesticides are used in the home for pest con- 
trol, 50% of all accidental deaths and suicides, traced to pesticide poisoning, 
are from non-agricultural uses of pesticides. For example, in just one of Flori- 
da's 67 counties there were eight accidental and five suicidal deaths from phos- 
phate pesticide poisoning in 1963 alone. 

HOW IGNOEANT ARE WE OF THE DANGER 

While the data on fatalities and non-lethal poisonings are illustrative, they 
nevertheless are the tip of the unseen iceberg. The real fact of the matter is 
that we are simply not counting many of non-lethal and fatal pesticide poison- 
ings. 

In an article entitled "Some Health Related Needs in Pesticide Investiga- 
tions" appearing in the March 1969 edition of Industrial Medicine, Dr. S. W. 
Simmons, Chief of the F.D.A. Pesticide Research program, made some reveal- 
ing guesstimates of the size of the pesticide poisoning peril, nationally. 

Dr. Simmons believes that there are possibly as many as 100,000 cases of 
non-lethal pesticide poisoning a year, with perhaps upwards of 150 to 200 fa- 
talities, as well. Remember that the non-lethal poisonings would include such 
cases as Mrs. Ford's in Texas and the orchard pickers in California. Dr. Sim- 
mons goes on to .say, that part of the reason for the amazing state of igno- 
rance about public and occupational health hazards from pesticides, is that 
pesticide poisoning is not a reportable disease event in most states ! A further 
problem is that while most communities have Poison Information Centers, 
most family and industrial physicians are not adequately equipped either by 
dint of training or practice to adequately diagnose and treat pesticide poison- 
ings, 

In fact, the present status of information on occupational poisoning gener- 
ally is pretty thin. Witness this unpublished statement prepared by Victoria 
Trasko of the Occupational Health Program, National Center for Urban and 
Industrial Health, U.S. Public Health Service, for last year's testimony on the 
Occupational Safety and Health Act of 1968. 

"Occupational poisonings were identified for 6,901 cases in 15 different 
States. This is definitely an understatement of the real occurrence of poison- 
ings in these states. A few of the states provided data both on total number of 
cases of occupational (poisonings) for some years, and frequency distributions 
for other years. Some states tabulated their data by causative agent and it 
could not always be determined whether the agent was associated with syste- 
matic poisoning or other physiological conditions. 

"There is also no doubt that poisonings occurred in the other 9 States (out 
of a total of 23 reporting data for the entire United States), but these could 
not be identified because only gross totals for occupational or industrial poi- 
sonings were reported." 

An interesting statistic from Miss Trasko's study on occupational poisonings 
data is that of the 800 cases of agricultural chemical poisoning reported, almost 
all iccrc chiefly from California. 

This leads to a most important revelation, that only California counts farm 
work injuries and incidencies of occupational disease in the entire United 
States. Neither the federal government or any of the remaining 49 states do! 

INDUSTRY AND THE PUBLIC INTEREST — IS THERE ANY? 

A point that must be raised at this juncture is the position of the agricul- 
tural chemical industry in all of this. Do they really care about the effects of 
the products they sell? Have they really done anything since the "Silent 
Spring" crisis of the mid-sixties? 

First, let's look at the scope of the industry's operations and growth. 

The growth and use of pesticides in this country has been enormous. More 
than 650 varieties have been invented over the last quarter-century. These new 
chemical compounds, as well as several others, have been forumlated into 



3200 

60,000 trade names. About 59% of the pesticides used are insecticides, 15% 
fungicides, another 15% defoliants and herbicides, 10% fumigants and 1% ro- 
denticides. In contrast to many areas of the world, only 1% of all pesticides 
produced in the United States are used for control of diseases, such as malaria. 
By far the greatest use of pesticides in this country is in commercial agricul- 
ture. 

The following extract from a major industry publication, Chemical Week, 
gives you some idea of the rapidity with which the industry has expanded. 

"Chemical pesticides production has been growing at a 16%/year clip re- 
cently, and projections or market growth and price patterns indicate that pes- 
ticides will pull ahead of fertilizers in total sales by '75. 

Manufacturing value of pesticides production topped $1 billion in '68; sales 
at consumer prices can only be estimated, but they probably were close to $1.7 
billion last year, including exports of about $200 million. Fertilizer sales 
(on the same basis) now are about $2.7 billion, but pesticides should close that 
$l-billion gap by the mid-"70's. 

By '70 pesticides sales at consumer prices should reach $2 billion, and by '75 
they are expected to top $3 billion — or slightly more than projected fertilizer 
sales at that time. Pesticides sales at manufacturers' price levels should exceed 
$2 billion in '75 (see chart on next page). 

Farmers' outlays for pesticides have grown at a 15%/year rate since 'GO, 
jumping from $87 million to more than $1 billion in '68. At the same time, 
farm value of crop production has grown only 2% and the number of har- 
vested acres has decreased from 3J,0,000 to 294,000. In '50 farmers spent 
25^ /acre for pesticides (0.5% of the value of farm production) ; last year they 
spent $3.65/acre (4.6% of production value). By '75 the figure will be closer to 
$8-9/acre (see table)." 

In their zeal to become a $3 billion industry by the mid-seventies, they have 
proliferated an uninformed agricultural service superstructure — signified by 
the appearance of pesticide "detail men" in major commercial growing areas 
in this country. The net result has been the proliferation of sales of less than 
effective, but highly toxic pesticide formulations to applicators and users. 

In the case of the highly toxic organic phosphor pesticide Parathion, this 
has resulted in an increase in production volume of 188 percent over the seven 
year period from 1960 to 1967. Industry consultants expect this rate of in- 
crease to be maintained into the seventies (see below). 

WHAT'S AHEAD FOR TODAY'S MAJOR PRODUCTS 

Relative production rates (1968= 100) 



Herbicides: 

Trifluralin 

Atrazine 

Amiben ,. 

2,4-D 

Insecticides: 

DDT . 

Malathion 

Systemics ' 

Parathion •...•... 

> Includes demeton, dimethoate, disulfoton, methyl-demeton, phorate, phosphamidon. 
Source: Arthur D. Little, Inc. 

A kind of curiosity is why should such major producers of a highly toxic 
pesticide like Parathion .such as Shell, Monsanto, Cyanamid, Stauffer and 
American Potash want to continue manufacturing the stuff in newer version.s, 
if the risks of acceptance are so high? 

If the enclosed chart from Chemical Week is any criterion, the economic mo- 
tivation to produce less toxic pesticide agents should be of vital concern in the 
research and development decisions of most firms in the industry. With the 
fielding of a potentially less toxic product, the risks of acceptance at the toxic- 
ity testing stage could be reduced by half providing about a 9% reduction in 
overall costs of development ($500,000 for the typical product) ! That savings, 



I960 


1964 


1968 


1975 





10 


100 


260 


15 


40 


100 


140 








100 


260 


45 


70 


100 


140 


120 


90 


100 


0-50 


30 


50 


100 


200 





25 


100 


500 


30 


50 


100 


125 



3201 
Pesticides sales will top $3 billion by '75 



3200 



3000 



2800 



2600 



2400 



2200 



2000 



1800 



1600 



(in million doll«r«) 




1400 



1200 



1000 



■62 '63 '64 '65 '66 '67 '68 '69 '70 

'Includes export sales. 



Sales to farmers have tripled since '60 



•55 



•60 



•64 



•68 



Farmers^ pesticide purchases 

(nnillions) 



$184 



$292 



Harvested acreage (million acr») 335 319 

Purchases/acre $0.55 $0.91 

Purchases vs. farm production 1-0% 1.5% 

value 

Sources: U.S. Dept. of Agriculture; Arthur D. Little, Inc. 



$500 $1,065 

292 294 

$1.70 $3.65 

2.3% 4.6% 



April 12, 1969 CHEMICAL WEEK 39 



Average cost 
per compound 


Chance of 

reaching next 

step 


Cumulative 
odds 


Total R&D 
cost 


$400 


1:100 
1:10 

1:4 

1:2 

1:1.5 

1:1.5 

1:2 


1:100 

1:1,000 

1:4,000 

1:8,000 

1:12,000 

1:18,000 

1:36,000 


$400, 000 


100.000 


1,000,000 


400,000 
200,000 
200,000 


1,600,000 
400, 000 
300,000 


200, 000 
. '1,000,000 


300, 000 
2, 000, 000 


2, 100, 400 






6,000,000 




1:10 


1:360.000 .. 





3202 

through reduction in risk, could resiilt in an upward spiral of development of 
increasingly less toxic pesticide products I A highly desirable goal. 

The U.S. Department of Agriculture and the companies must be thinking of 
something else. 

PESTICIDES RESEARCH: BIG OUTLAYS, HEAVY ODDS 

Step 



Synthesis and initial screening 

Toxicity testing 

Field evaluation 

Product development - 

Process development and pilot plant 

Test marketing 

Commercialization. 

Total 

Sales over $5 million/year 

I This assumes no marketing organization has been established. Otherwise, the commercialization step would be re- 
duced to $200,000. Source: Arthur D. Little. Figures are for 1964, latest year for which they are available. 

GOVERNMENT AND THE PUBLIC INTEREST — IS IT WORKING? 

The next logical series of questions deal with the problem of how the major 
federal and state pesticide regulatory programs are operating and, what if any 
is provided in the way of protection for farm workers and others? 

In the legislative lexicon, pesticides are called "economic poisons." a euphe- 
mism devised by Congress and the Agriculture Department to distinguish be- 
tween the purportedly beneficial nature of the potentially lethal stuff and 
"hazardous materials" generally. In fact, the "economic poi.sons" are specifi- 
cally exempted from coverage tnider the Federal Hazardous Materials Act. 

With well over 60.000 trade names of pesticides in existence, the job of in- 
dustry surveillance and compliance with existing pesticide manufacturing and 
applications standards is virtually impossible. The response of the Johnson ad- 
ministration after the submission of the Scientific Advisory Council report on 
pesticides in 1965 was effectively to hol)ble the federal regulatory program. 

Surveillance and regulatory functions were split between the Public Health 
Service and the Agricultural Research Service. The PHS Office of Pesticide 
Research has responsibility for conducting basic researcli on human and envi- 
ronmental health hazards of pesticide use and is also responsible for inspect- 
ing establishments involved witli the formulation of pesticide chemicals. If 
that were not enough, the PHS is supposed to monitor areas of concentrated 
pesticide use in major commercial agricultural centers in this country. How- 
ever, the fine Byzantine hand of the agricultural interests has made sure that 
the PHS cannot issue cease and desist orders. Violations are to be turned over 
to the Agricultural Research Service for disposition and prosecutirm. But the 
ARS hasn't filed a major violation prosecution with the Justice Department in 
the 22 year history of the Federal Insecticide, Fungicide and Rodenticide Act 
of 1947. 

On September 10. the U.S. General Accoimting Office issued a report on regu- 
latory enforcement of the Federal In.secticide. Fungicide, and Rodenticide Act. 
The substance of the GAO review was tliat there was little effective com- 
pliance action and no request for prosecution by the Justice Department in 13 
year.s. "This was true," the GAO found, "even in instances where repeated 
major violations of the law were cited by the Agriculttiral Research Service 
(of the Department of Agriculture) and when shii)pers did not take satisfac- 
tory action to correct violations or ignored ARS notifications that prosecution 
was being contemi)lated." ARS conceded the truth of the GAO's charges. 

As usual, the GAO report was hardly noticed. Little action has been taken 
since Rachel Carson's Silent SnrifKj raised inn)ortant public health issues in 
1964 and the chemical-agri-business bloc squelched them l)efore fundamental, 
enduring reforms were developed. 

That law contains some neat provisions to dissuage investigators from dig- 
ging into the pesticide chemicals indu.stry. Information on the production of 



3203 

.synthetic organic compound pesticides is compiled by ttie U.S. Tariff Commis- 
sion, not Agricultural Research or Public Health. Further, information on the 
exact ingredients of specific formulations are not permitted to be disclosed by 
law to protect "trade secrets." 

WHAT ABOUT THE STATE PROGRAMS? 

California is better than most states in the regulation and use of pesticides ; 
but the form of regulation leads to abuses by special interest groups that have 
severely weakened the national pesticide regulatory program and have blocked 
efforts to seek increased protection of farm workers. 

The four-part regulatory structure consists of : a) registration or licensing of 
pesticide products; b) licensing of agricultural pest control operators; c) the 
registration and use, by permit, of injurious materials such as the highly toxic 
phosphate ester pesticide family; d) sampling of crops for pesticide residue 
inspection. As in the federal program and some other state programs, the re- 
sponsibilities for regulation of pesticides is in the hands of the Department of 
Agriculture and, in the case of California, the County Agricultural Commis- 
sioner. 

GOVERNMENT IGNORES MOST PESTICIDE VIOLATIONS 

With the exception of registration, testing and evaluation of specific pesti- 
cide products, the California program is effectively run by County Agri- 
cultural Commissioner. For example, an agricultural pest control operator must 
register with the Commissioner in each county in which he does business and 
supply a monthly report of his operations in the county. The Commissioner 
also issues licenses for agricultural aircraft operators and administers special 
examinations for agricultural aircraft pilots. Most important, the Commis- 
sioner issues permits for the use by farm operators of chemicals registered by 
the California Department of Agriculture as injurious materials. These include 
the toxic phosphate ester family of pesticides and 14 other pesticides. 

The State Department of Agriculture, to ensure quality control over applica- 
tion of pesticides, inspects and analyzes samples of fruits, produce and meats 
in wholesale marketing distribution facilities to check on pesticide residues on 
food offered for sale in the State. The U.S. Food and Drug Administration 
does the same thing in interstate traffic. Tolerances for pesticide residues used 
in California are the same as those developed by the Federal Food and Drug 
Administration. 

These tolerance levels are set for the particular crop and practically none 
are developed for the foliage on which the crop is grown. The outbreak of pes- 
ticide poisoning among the 186 peach harvesters in California in 1962 was 
traced to excessive application of Parathion on the foliage, but not the crop. 
■ The effectiveness of this program of regulation by state and federal agricul- 
tural authorities has come under serious attack recently in a salient area — reg- 
istration, evaluation and testing of pesticide products. Under the Federal In- 
secticide, Fungicide and Rodenticide Act, the U.S. Agricultural Research 
Service can take action to remove products from the market, cancel the regis- 
tration of products and prosecute those who ship products that violate the 
law. 

The GAO report last September detailed that Research Service's concept of 
"law and order" is for the benefit of pesticide industry. The report went on to 
show that of 2,751 samples of products tested and reviewed during fiscal 1966, 
750 were found to be in violation of the law. Of these, 70% or 520 were in 
"major" violation of the law. In 1967, of 4,958 samples taken 23% or 1,147 
were found in violation. 

Part of the reason for the situation is the old complaint of fiscal starvation 
and bureaucratic passivity toward vested interests. The pesticides regulation 
division has a staff of about 150 of which 26 are field supervisors and 5 are 
supervisory inspectors. In fiscal 1968 the total budget of the agency was $3.6 
million. By way of contrast, the California State Assembly appropriated and 
spent $20 million last year for agricultural research support for its state uni- 
versity and college system. 

Obviously, federal and state agricultural agencies are oriented toward max- 
imizing the productivity-increasing features of agricultural chemicals, gener- 
ally, and pesticides, specifically. The fact that no research in the U.S. is 
currently conducted into the occupational health hazards of agricultural and 



3204 

industrial chemicals is indicative of the general lack of concern in the regula- 
tory organization for worker interests. 

A portent of the future direction of public policy in this area is the fact 
that the budget of the Bureau of Occupational Health of the California State 
Department of Public Health was cut by one-third as imrt of Governor Rea- 
gan's attempt to bring "etficiency"' into government operations. 

If a severe budget cut were not enough, the Bureau of Occupational Health 
was also in jeopardy of being legislated out of existence. The chief legislative 
analyst of the California State Assembly, Alan Post, uncovered the fact that 
the Bureau's existence was subject to legislative approval. Recently legislation 
has been introduced into the Assembly to rectify the anomaly before the Bu- 
reau's existence becomes an object of lobby pressure. This may seem like just 
another administrative oversight, but the Bureau is practically the only source 
of information on occupational disease and health hazards among farm work- 
ers for the United States. (California is the only state in the country where 
injuries among farm workers are counted and where farm workers are also 
covered by Workmen's Compensation.) 

California is one of the few states to have developed safety standards for 
agricultural operations. The standards are administered by the Division of In- 
dustrial Safety of the State Department of Industrial Relations. Safety orders 
for injurious materials (as defined in Section 2461 of Title 3 of the California 
Administrative Code) cover four areas: first, the provision of medical services 
by an employer engaged in commercial operation who uses toxic pesticides ; 
second, decontamination of equipment ; third, precautions for aircraft crop 
dusting and spraying; and fourth, standards for equipment used in both 
ground and air application of pesticides and other injurious agricultural chem- 
icals. By far the most important of these for protection of the farm worker is 
the standards of medical supervision over application of pesticides. Even this 
is weakened, since control over recommendations and reports filed witli the Di- 
vision of Industrial Safety covering the determination of restricted activities 
for employees exposed to injurious materials, is under the employer. 

The question of safety brings us back to the paradoxical imbalance between 
spending on Pesticide Research and Development and Pesticide Safety. The 
U.S. Department of Agriculture spends over .$180 million annually on research 
activities in contrast to the totally inadequate annual pesticide program of the 
Food and Drug Administration of approximately $5 million. 

It is astounding to compare the U.S. Department of Agriculture spending of 
over $180 million on pesticide-related research, while allocating less than $U)0 
thousand annually for pesticide safety and not even including farm ivorkers in 
anil of the pror/ranis. It is almost beyond comprehension that within the highly 
subsidized American agricultural business that there is outright refusal on the 
part of embattled grape industry to "bargain" on control of pesticides in the 
fields with the grape worker.s. 

It is interesting to note that last year, Sen. Ralph Yarborough, Chairman of 
the Senate Committee on Public Welfare and Labor specifically asked about in- 
secticide safety programs on the nation's farms in a colloquy with representa- 
tives of the American Farm Bureau. The resiwnse was loaded with remarks by 
each state farm bureau chief about "roll-bars on tractors," but nothing was 
mentioned about pesticide safety. If Mrs. Ford's case is any illustration of the 
Farm Bureau's concern for its own constituents, then something is very much 
awry. 

FARM WORKERS A.\I) THEIR POWERLESSNFSS VIS-A-VIS PESTICIDES 

The pesticide problem would appear to be the literal apotheosis of the mi- 
grant farm workers dilemma. These people are prey to the most unspeakable 
of occupational health hazards — death through nerve gas asphyxiation, and yet 
they are unprotected by safety legislation in all states save California. They 
have no recourse to Workmen's Compensation medical and income benefits in 
almost two thirds of our country. They can't even inspect public records in 
states where they exist like California to a.scertain whether existing pesticide 
rules have been violated. Emi)loyers won't even recognize their right to safe 
and healthful workplaces — a right purportedly guaranteed by every state in- 
dustrial accident commis.sion in this coiuitry to every workingman and woniaJi, 
as a "i)argaining" point. Then what we have is a class of workers who rival 
the "helots" of ancient Si)arta who were .slaughtered at the whim and discre- 
tion of the warring Spartan landowners. 



3205 

SOLUTIONS TO THE PROBLEM 

What we have seen so far is a trail of misfortune, Iain with broken prom- 
ises and dominated by an indifferent, callous bureaucracy, both governmental 
and private. Be that as it may, the remaining issue is one of what can we do 
to mitigate the pesticide hazards to farm workers and others in the short run, 
and what long range solutions should wo seriously consider tackling, not only 
the pesticide safety issue, but the whole problem of improving occupational 
safety and health condition for farm workers, generally. 

In the short run, I would like to suggest the following remedies. 

First, the establishment of a phased ban of the use of organic phosphor pes- 
ticides to be in total effect within 5 to 7 years, at the latest. 

Second, the content of periodic cholinesterase tests by uniformed members 
of the U.S. Public Health Service on the nation's farm worker population. 

Third, the development of an intensive instructional and remedial program 
of diagnosis of pesticide poisoning for physicians in both rural and suburban 
areas. 

Fourth, the adoption, through Amendment of the existing Federal Harmful 
Materials Act and the Federal Insecticide, Fungicide and Rodenticide Act of 
stricter pesticide residue tolerances than those presently in use to prevent the 
creation of "frankenstein-like" derivative compounds resulting in possible pesti- 
cide residue poisoning. 

Fifth, adoption of stricter, yet lucid standards for proper labelling of pesti- 
cide products to show both oral toxicity and residue toxicity levels in English 
and in Spanish. 

Sixth, the creation of a special instructional program administered by the 
U.S. Department of Agriculture Extension Service in the proper use, storage 
and labelling of pesticides, as well as, use of simple Pesticide public health 
precautions for the benefit of both Spanish-speaking and English-speaking mi- 
grant farm workers. 

In the long run, I would consider the following as being most important to 
rectify the present imbalance in the overall pesticide safety picture. 

First, federal subsidization of the development of new families of selective 
less toxic pesticides as substitutes for the broad spectrum organic phosphors. 

Second, a minimum of a ten fold increase in the funding of Department of 
Health, Education and Welfare Pesticide Research and Surveillance Programs 
from its present level of less than $5 million annually. 

Third, enactment of a special workmen's comi>ensation program for the na- 
tion's farm workers to provide adequate medical and income benefits to fill-in 
presently non-existent protection against the hazards of work in the nation's 
fields and vineyards. 

Fourth, the development of a nationwide system of farm worker injury and 
occupational disease reporting, with procurement of data from the states on a 
contract basis, with federal reimbursement for development and operating ex- 
penditures. 

Sixth, revision of the existing federal pesticide regulatory legislation to shift 
the present responsibilities split between the U.S. Agricultural Research Serv- 
ice and the Food and Drug Administration into a proposed executive level en- 
vironmental health protection agency. 

Seventh, the earmarking of Department of Defense Chemical and Biological 
Warfare defensive systems research and development and procurement funds 
to serve the dual purposes of protecting the nation against the very slim likeli- 
hood of chemical warfare attack and the nation's farm workers, farmers and 
suburbanites against the very strong possibility of pesticide poisoning of our- 
selves and our environment. 

The technology is available for monitoring and pinpointing excessive and 
dangerous concentrations of pesticides in our environment and in agriculture. 
A number of firms, in instrumentation research and development, such as EX- 
OTECH, Inc. of Rockville, Md. have actually developed portable systems for 
just such a possible use from research work currently supported by the De- 
fense Department. This would be a iwsitive example of the much-wanted, but 
little in evidence, military -civilian technology transfer process. 

Finally, part of the pesticide safety problem comes from our failure to rec- 
ognize that a problem really exists. Dr. Irma West, a leading champion of pes- 
ticide control among environmental health specialists, writing in California 
Medicine has summarized the issues involved clearly : 



3206 

"Man has manipulated his environment on so large a scale that he has inad- 
vertently invented and produced a multitude of the most complicated new 
problems ever to confront the health professions. Unfortunately, we have been 
slow to realize that plans for health and safety should be built into techno- 
logic advances in the planning stages. By the time technical tools are in opera- 
tion and their use results in undesirable and iniexpected effects upon people 
and their environment, the best opportunity to minimize these effects eflSciently 
and humanely is largely lost." 

News Release — Delphic System & Research Corp. 

"Fifty Million Pounds of a pesticide originally developed in AVW II as a 
German Nerve Gas are being spread imchecked on America's Farms and Gar- 
dens. The result is that uncounted thousands of the nation's migrant farm 
workers, farmers and suburban homeowners have been fatally overcome or se- 
riously disabled." This is one of .several allegations made in a statement by 
worker safety advocate Jerome B. Gordon in testimony released today at a 
Hearing in Washington held by the U.S. Senate Sub-committee on Migratory 
Labor, headed by Sen. "Walter Mondale of Minn. 

The pesticides in question derived from German nerve gas research, are 
called organic phosphors and apijear under such trade names as Parathion, 
Methyl Parathion, TEPP, and in less lethal dosages, as Malathion. They are 
flirst cousins, chemically, to the nerve agents GB and VX involved in the cur- 
rent chemical and biological warfare controversy. 

The odorless, colorless liquid or powder form of the pesticide is so powerful 
that a minute amount — less than .00424 of an ounce, swallowed by a human is 
fatal in less than five minutes I Even under ideal conditions, continued cumula- 
tive exixj.sure can result in disabling partial paralysis and mental debility. 

Both the organic phosphor compounds and the war gas nerve agents GB and 
VX u.se the same "kill mechanism." They prevent the manufacture of enzymes 
which carry body "messages" controlling respiration. In other words, victims 
simply suffocate. Early symptoms include pinix)inting of eye pupils, tightness 
in the chest, convulsions, paralysis and finally respiratory failure. Even more 
insidious is that less than lethal dosages of the pesticides have symptoms re- 
sembling of the onslaught of an attack of flu ! 

Mr. Gordon further contends that the occupational and general health dan- 
ger from in.secticides such as Methyl Parathion, Parathion and Malathion could 
ironically increase in the future, with the probable banning of persistent insec- 
ticides such as DDT and DDD by many states and the federal government. To 
quote Mr. Gordon ; "This bizarre situation is the product of an unwieldy and 
unresponsive federal and state pesticide regulatory program that has permitted 
the increased production and u.se of the.se deadly nerve agents, but has not 
subsidized the development of more selective and less toxic substitute i>esti- 
cides by the U.S. agricultural chemical industry even in the wake of the pesti- 
cide crisis raised i)y the publication of Rachel Carson's book, the "Silent 
Spring" in the early nineteen sixties." 

"The situation is not helped any by the facts uncovered by pesticide re- 
searchers of the existence of more toxic "frankenstein-like" compounds evolved 
from excessive and frequent application of organic phosphor pesticides. One of 
these derivative compounds, Paraxon has 2 to 3 times the toxicity of Para- 
thion." 

Citing specific instances of pesticide poisoning and government research find- 
ings, Mr. Gordon goes on to state that "we are not counting over one hundred 
thou.sand ca.ses of pesticide poisoning and several hundred fatalities annually. 
This anomolous situation is the i>roduct of : a ) the fact that physicians fre- 
quently mis-diagnose deadly Parathion poisoning as "flu"; b) persons directly 
affected by expo.sure to potentially fatal organic phosphor pesticide poisoning 
are least well informed about the potential hazards; c) pesticide poisoning is 
not a recordable occupational dlsea.se event in mo.st states." 

Major victims of this state of affairs, according to Mr. Gordon are the na- 
tion's migrant farm workers. "These people are prey to the most unspeakable 
of occupational health hazard.s — death through nerve gas a.sphyxiation, and yet 
they are improtected by safety legislation in all states save California. They 
have no recourse to workmen's compensation medical and income benefits in 
almost two thirds of our country and they can't even inspect public records in 
states where they exist like California to ascertain whether existing pesticide 



3207 

rules have been violated." It is astounding to think that the U.S. Department 
of Agriculture spends over $132 million on pesticide-related research, while al- 
locating less than $160 thousand annually for pesticide safety and not even in- 
clude farm workers in any of the programs. It is almost beyond comprehension 
that within the highly subsidized American agricultural business that there is 
outright refusal on the part of embattled grape industry to "bargain" on con- 
trol of pesticides in the fields with the grape workers. 

"Part of the problem, Mr. Gordon suggests, is the non-think attitude of the 
Agricultural Chemical Industry. In their zeal to become a $3 billion industry by 
the mid-seventies, they have proliferated an uninformed agricultural service 
superstructure — signified by the appearance of pesticide "detail men" in major 
commercial growing areas in this country. The net result has been the prolifer- 
ation of sales of less than effective but highly toxic pesticide formulations to 
applicators and users. This can be seen in the fact that average consumption 
of pesticides per farm acreage has trebled in volume over the period from the 
mid fifties to the late sixties. In the case of the highly toxic organic phosphor 
pesticide Parathion, this has resulted in an increase in production volume of 
188 per cent over the seven year period from 1960 to 1967. Industry consul- 
tants expect this rate of increase to be maintained into the seventies." 

Among the possible remedies recommended by Mr. Gordon in his testimony 
are the following : 

1. A phased ban of the use of organic phosphor pesticides. 

2. Federal subsidization of the development of new families of selective less 
toxic pesticides as substitutes for the broad spectrum organic phosphors. 

3. A minimum of a ten fold increase in the funding of Department of 
Health, Education and Welfare Pesticide Research and Surveillance Programs 
from its present level of less than $2 million annually. 

4. Enactment of a special workmen's compensation program for the nation's 
farm workers to provide adequate medical and income benefits to fill-in present 
non-existent protection against the hazards of work in the nation's fields and 
vineyards. 

5. Revision of the existing federal iiesticide regulatory legislation to shift 
the present responsibilities split between the U.S. Agricultural Research Serv- 
ice and the Food and Drug Administration into a proposed executive level en- 
vironmental health protection agency. 

6. The earmarking of Department of Defense C.B.W. defensive systems re- 
search and development and procurement funds to serve the dual purposes of 
protecting the nation against the very slim likelihood of chemical warfare at- 
tack and the nation's farm workers, farmers and suburbanites against the very 
strong possibility of pesticide poisoning of ourselves and our environment. 

Mr. Gordon is President and founder of the New York-based policy re- 
search consulting firm, Delphic Systems and Research Corporation. Mr. Gordon 
has authored a number of articles on worker safety and health and collabo- 
rated in the preparation of one of the strongest versions of the Coal Mine and 
Safety and Health Act of 1969, co-sponsored by Rep. Ken Hechler of W. 
Virginia and Sen. Harrison Williams of New Jersey. 

Mr. Gordon is a resident of Ossining, New York and a native of Lynn, Mass. 



[From a biweekly magazine, HARD TIMES, issue of November 8-15, 1968] 

Mayday 
By Ralph Nader and Jerome Gordon 

PESTICIDES : SLOW OR SUDDEN DEATH FOR CALIFORNIA FARM WORKEaSS 

Three months ago a group of Cuban refugees escaped to the U.S. on a Sovi- 
et-built Antonov crop-dusting aircraft. When the plane touched down in Flor- 
ida, it was immediately quarantined by Federal Immigration and Florida 
State Health officials and returned to Cuba the following day. The passengers 
in the aircraft emerged retching and vomiting and were rushed to nearby clin- 
ics ; they had been made ill by the noxious pesticide parathion that was all 
over the aircraft. 

In 1965 twenty eight persons in San Diego, Calif, were poisoned by the pes- 
ticide diazinon which accidentally contaminated doughnut mix in a local bakery. 

36-513 O — 70 — pt. 6A 14 



3208 

In 1967, in nearby Tijuana, Mexico, 17 persons were fatally poisoned and 
300 were reported ill wlieii parathion was carelessly spilled on a truck which 
was hiter used to transport confectionery sugar. 

But the worst disiister from i)esticide contamination of food occurred in Co- 
lombia last year : 77 people were fatally poisoned, 146 were hospitalized and 
upwards of 600 were reported ill from flour contaminated by the traces of par- 
athion spilled on the floor bed of a truck used to transport the flour. 

On September 10, the U.S. General AccountiuK Office issued a rei>ort on regu- 
latory enforcement of the Federal Insecticide, Fungicide, and Rodenticide Act. 
The substance of the GAO review was that there was little eifective compli- 
ance action and no request for prosecution by the .Justice Department in 13 
years. "This was true," the GAO found, "even in instances where repeated 
major violations of tlie law were cited by the Agricultural Research Service 
[of the Deimrtment of Agricultui'e] and when shippers did not take satisfac- 
tory action to correct violations or ignored ARS notifications that prosecution 
was being contemplated." ARS conceded tlie truth of the GAO's charges. 

As usual, tlie GAO report was liardly noticed. Little action has been taken 
since Rachel Carson's Silent Spring raised important public health issues in 
1964 and tlie chemical-agri-business bloc squelched tliem before fundamental, 
enduring reforms were developed. 

While regulations exist in this country for registration, dosage limitations 
and residue tolerances, violations or misapplications can have tragic conse- 
quences reaching far into the lives of an affected people. Farm workers in Cal- 
ifornia know this to be true : 

In August and September of 1963 an outbreak of pesticide poisoning among 
94 peacli liarvesters was traced to the residues on the foliage of the orcliard in 
which they were working. The cau.se of poisoning was the amount of par- 
athion applied and not tlie premature entry into the orchard l)y the harvesting 
crews, according to tlie California Department of Public Health. (California 
law stipulates a waiting period between the application of a pesticide and crop 
harvest, so that the cliemical will have deteriorated to the point where resi- 
dues on the fruit are within "safe" limits.) The final cause was determined to 
be the presence in the spray residues of a compound evolved from parathion 
alteration which was considerably more toxic than parathion ; but it was iden- 
tified by routine analysis simply as parathion. The mishap resulted in one 
death and lengthy ho.spitalixation for many others. 

It is difficult to work through bureaucracies for compliance of existing 
safety standards — and next to impossible to campaign politically for additional 
safeguards. A case in point is the recent experience of Cesar Chavez and his 
United Farm Workers. Over the past IS months in California there have been 
six deaths among farm workers due to accidental ingestion of pesticides mis- 
taken for water or wine. Some of the i)esticides were improperly stored in 
empty plastic bleach containers. The bottles were either mislabeled — or the 
workers, many of whom cannot readily read or write English, misunderstood 
the labels. This is in spite of the fact that California State Safety Orders ex- 
plicitly reipiire farm operators to properly inform farm workers of hazards, 
even for workers wlio do not understand English. 

This summer, as part of their organizing operations, the United Farm 
Workers Organizing Committee sent legal aides into the fields to get affidavits 
from the grape-pickers about specific instances of pesticide poisoning. The 
affidavits — as well as information in the application and use registers kept by 
the State County Agricultural Commissioner's oflSce — would have revealed the 
extent of po.ssil)le violations of State pesticide standards. 

The information is presumably open to the public, and the Farm Workers 
requested access to the records through the Kern County Agricultural Commis- 
sioner. They were summarily informed they could not obtain access to such in- 
formation ; two hours after their appearance at the Commissioner's office an 
injunctir)n was issued by the Kern County Court barring them from looking at 
the records. 

A hearing is under way to determine the legality of that move on the part 
of the State agency. 

Chavez's troubles are not limited to the effects of toxic pesticides on his 
workers, l)ut also involve tln' pollution of the local water supply beyond the 
tolerance of even the most morihund suburl)anites. Last summer, the State De- 
partment of Public Heiilth condemned the use of the local water supply in De- 
lano for the consumption of infants below the age of six months. The ground 



3209 

water supply — the major source of supply for the water system in the Delano 
area — is loaded with nitrate residues from the applications of fertilizer to the 
crops in the fields surrounding the Delano area. Nitrates are normally tolera- 
ble in the digestive systems of children and adults beyond the age of one 
year ; but to infants below one year of age — and particularly to infants during 
the first six months of life — the residues are highly toxic. 

AMERICAN BABY FOOD POISONS EUEOPEAN INFANTH 

Prof. Barry Commonor, of the Washington University in St. Louis, recently 
reported on the increasing incidents of nitrate poisoning uncovered by Euro- 
pean public health officials among infants traced to the consumption of unre- 
frigerated American-processed baby food. 

Chavez's people now are forced to purchase bottled water for their children. 
On an average income of $1,232 per year for farm workers, buying bottled wa- 
ter — for which local public officials provide no funds — can be an intolerable ne- 
cessity. 

Large scale grass roots efforts aimed at controlling the spread and use of 
pesticides have met with something less than success in California. In 1964, a 
petition banning the use of most pesticides in California's agriculture failed by 
only a few thousand signatures to reach the ballot. The Brown administration 
— in the wake of the 1962 peach harvester debacle — tried to avoid the problem 
t»y appointing a commission to investigate and report on recommendations for 
regulating the use of pesticides. The Reagan administration has done nothing 
to expand significant control over the registration and use of pesticides in Cal- 
ifornia ; and Reagan may even dismantle existing machinery for doing the job. 

In California, fruits and vegetables, not cheesecake on the silver screen or 
the esoteric production of integrated circuits for complex electronic gear, is 
the leading industry. Production of table grapes is a billion dollar industry. 
Over one hundred million pounds of pesticides — twenty percent of the nation's 
total — are used in California's agri-business. Not so surprising, the agricultural 
industry has the highest occupational disease rate — over fifty percent higher 
than the industry in second place and almost three times as high as the aver- 
age rate for all industries in the state. 

Pesticide poisoning is high among the most serious causes of fatal and non- 
fatal occupational diseases. The number of doctors' reports involving pesticides 
and other agricultural chemicals have doubled since 1951 and in California 
have ranged from 800 to 1,100 reports annually. Over the ten-year period from 
1955 to 1965 about one occupational death from pesticides has been reported 
for each 100 reports of occupational poisoning from these chemicals. The vil- 
lains in these cases are the familiar family of phosphate ester pesticides — para- 
thion, phosdrin and thimet, demeton and tetraethyl pyrophosphate (TEPP). 
The wonders of chemical technology have made the unit costs of these pesti- 
cides so cheap that, for example, $5 worth of parathion is suflScient to cause 
the death of seven thousand people if dispensed without proper controls. 

The growth and use of ijesticides in this country has been enormous. More 
than 650 varieties have been invented over the last quarter-century. These new 
chemical compounds, as well as several others, have been formulated into 
60,000 trade names. About 59 percent of the pesticides used are insecticides, 15 
percent fungicides, another 15 percent defoliants and herbicides, ten percent 
fumigants and one percent rodenticides. In contrast to many areas of the 
world, only one percent of all pesticides produced in the United States are 
used for control of diseases, such as malaria. By far the greatest use of pesti- 
cides in this country is in commercial agriculture. 

While farm workers in California are exposed to considerable risk of pesti- 
cide poisoning, the most formidable record of occupational disease and injury 
is in the agricultural aircraft industry. Pesticides are applied by air to half of 
the acreage treated in California. 

The complement of 1,000 agricultural pilots apply about 10 to 15 i)ercent of 
the nation's pesticides, at a considerable price. One pilot is killed in an air ac- 
cident for each million acres treated. In addition to having the highest fatal 
injury rate of any occupation in California, over half the disabling work inju- 
ries are due to pesticide poisoning. For most other industries the occupational 
disease injury rate is five percent or less of total work injuries. However, con- 
sidering the amount of i>esticides and other agricultural chemicals used by this 
group, the cost in occupational disea.se is considerably less than among farm 
workers and ground applicators who apply the other half of these chemicals. 



3210 

The frequent victims of pesticide poisoning are children. In the period from 
1951 to 1965, roughly 60 percent of the accidental deaths attributable to poi- 
soning from pesticides in California were among children. The most frecpient 
causes for this toll are the improper safeguard.s— in the private home or farm 
— for the storage of pesticides and the contamination of clothing by adults in 
the household or on the job who apply the chemicals. Two incidents drawn 
from the annals of the California Department of Public Health files are repre- 
sentative : 

An 18-month-old child of an agricultural aircraft pilot was found at home in 
a state of acute respiratory distress, semi-conscious and with "pinpoint" pupils 
of the eyes. She was rushed to a local liospital and treated by a physician for 
severe organic phosphate poisoning. Fortunately, she recovered. On the morn- 
ing of her illness, her father had come liome after applying a highly toxic 
phosphate ester pesticide. He cleaned his boots with paper towels, threw them 
in a nearby wastebasket and put his boots in the bathroom. The child con- 
tracted the poisoning from either the boots or the paper towels. 

A 4-YEAR-OLD DIES IN 20 MINUTES 

In the second instance, a group of families, with children, were picking ber- 
ries on a farm. They were followed by a spray rig carrying a five gallon tank 
of TEPr concentrate. A four-year-old girl .'sampled the can. which her older 
brother had opened. She died in twenty minutes. 

Because of readily available supplies of pesticides for both commercial and 
private use, suicide and accidental deaths from pesticide poisoning is an in- 
creasing problem. While only 13 i^rcent of pesticides are used in the home for 
pest control, 50 percent of all accidental deaths and suicides, traced to pesti- 
cide poisoning, are from non-agricultural uses of pesticides. For example, in 
just one of Florida's 67 counties there were eight accidental and five suicidal 
deaths from phosphate pesticide poisoning in 1963 alone. 

California is better than most states in the regulation and use of pesticides : 
but the form of regulation leads to abuses by special interest groups that have 
severely weakened the national i)esticide regulatory program and have blocked 
efforts to seek increased protection of farm workers. 

The four-part regulatory structure consists of : a) registration or licensing of 
pesticide products; b) licensing of agricultural pest control operators; c) the 
registration and use, by permit, of injurious materials such as the highly toxic 
phosphate ester pesticide family; d) sampling of crops for pesticide residue 
inspection. As in the federal program and some other state programs, the re- 
sponsibility for regulation of pesticides is in the hands of the Department of 
Agriculture and, in the case of California, the County Agricultural Commis- 
sioner. 

GOVERNMENT IGNORES MOST PESTICIDE VIOLATIONS 

With the exception of registration, testing and evaluation of specific pesti- 
cide products, the California program is effectively run by the County Agricul- 
tural Commissioner. For example, an agricultural pest control operator must 
register with the Commissioner in each county in which he does business and 
supply a monthly report of his operations in the county. The Commissioner 
also issues licenses for agricultural aircraft operators and administers special 
examinations for agricultural aircraft pilots. Most important, the Commis- 
sioner issues permits for the use by farm operators of chemicals registered by 
the California Department of Agricultural as injurious materials. These in- 
clude the toxic phosphate ester family of pesticides and 14 other pesticides. 

The State Department of Agriculture, to ensure quality control over applica- 
tion of pesticides, inspects and analyzes samples of fruits, produce and meats 
in wholesale marketing distribution facilities to check on pesticide residues on 
food offered for sale in the State. The U.S. Food and Drug Administration 
does the same thing in interstate traflBc. Tolerances for pesticide residues used 
in California are the same as those developed by the Federal Food and Drug 
Administration. 

These tolerance levels are set for the particular crop and practically none 
are developed for the foliage on which the crop is grown. The outbreak of pes- 
ticide poisoning among the 95 peach harvesters in California in 1963 was 
traced to excessive application of parathion on the foliage, but not the crop. 

The effectiveness of this program of regulation by state and federal agricul- 
tural authorities has come under serious attack recently in a salient area — reg- 



3211 

istration, evaluation and testing of pesticide products. Under the Federal In- 
secticide, Fungicide and Rodenticide Act, the U.S. Agricultural Research 
Service can take action to remove products from the market, cancel the regis- 
tration of products and prosecute those who ship products that violate the 
law. 

The GAO report last September detailed that Research Service's concept of 
•'law and order" is for the benefit of pesticide indiistry. The report went on to 
show that of 2,751 samples of products tested and reviewed during fiscal 1966, 
750 were found to l)e in violation of the law. Of these, 70 percent or 520 were 
in "major" violation of the law. In 1967, of 4,958 samples taken 23 percent or 
1,147 were found in violation. 

Part of the reason for the situation is the old complaint of fiscal starvation 
and bureaucratic passivity toward vested interests. The pesticides regulation 
division has a staff of about 150 of which 26 are field supervisors and 5 are 
supervisory inspectors In fiscal 1968 the total budget of the agency was $3.6 
million. By way of contrast, the California State Assembly appropriated and 
spent $20 million last year for agricultural research support for its state uni- 
versity and college system. 

Obviously, federal and state agricultural agencies are oriented towards max- 
imizing the productivity-increasing features of agricultural chemicals, gener- 
ally, and pesticides, specifically. The fact that no research in the U.S. is 
currently conducted into the occupational health hazards of agricultural and 
industrial chemicals is indicative of the general lack of concern in the regula- 
tory organization for worker interests. 

A portent of the future direction of public policy in this area is the fact 
that the budget of the Bureau of Occupational Health of the California State 
Department of Public Health was cut by one-third as part of Governor Rea- 
gan's attempt to bring "efficiency" into government operations. 

If a severe budget cut were not enough, the Bureau of Occupational Health 
was also in jeopardy of being legislated out of existence. The chief legislative 
jinalyst of the California State Assembly, Alan Post, uncovered the fact that 
the Bureau's existence was subject to legislative approval. Recently legislation 
has been introduced into the Assembly to rectify the anomaly before the Bu- 
reau's existence becomes an object of lobby pressure. This may seem like just 
another administrative oversight, but the Bureau is practically the only source 
of information on occupational disease and health hazards among farm work- 
ers for the United States. (California is the only state in the country where 
injuries among farm workers are counted and where farm workers are also 
covered by AVorkmen's Compensation. ) 

California is one of the few states to have developed safety standards for 
agricultural operations. The standards are administered by the Division of In- 
dustrial Safety of the State Dei^artment of Industrial Relations. Safety orders 
for injurious materials (as defined in Section 2461 of Title 3 of the California 
Administrative Code) cover four areas: first, the provision of medical services 
by an employer engaged in commercial operation who uses toxic pesticides; 
second, decontamination of equipment : third, precautions for aircraft crop dust- 
ing and spraying; and fourth, standards for equipment used in both ground 
and air application of pesticides and other injurious agricultural chemicals. By 
far the most important of these for protection of the farm worker is the 
standard of medical suix^rvision over application of pesticides. Even this is 
weakened, since control over recommendations and reports filed with the Divi- 
sion of Industrial Safety covering the determination of restricted activities 
for employees exposed to injurious materials, is under the employer. 

Part of the pesticide problem comes from our failure to recognize that a 
problem really exists. Dr. Irma West, a leading champion of pesticide control 
among environmental health specialists, writing in California Medicine has 
summarized the issues involved clearly : 

"Man has manipulated his environment on so large a scale that he has inad- 
vertently invented and produced a multitude of the most complicated new 
problems ever to confront the health professions. Unfortunately, we have been 
slow to realize that plans for health and safety should be built into techno- 
logic advances in the planning, stages. By the time technical tools are in oper- 
ation and their use results in undesirable and unexpected effects upon people 
and their environment, the best opportunity to minimize these effects eflBciently 
and humanely is largely lost." 



3212 

DEATH STALKS THE GARDEN 

Thousands of home-gardeners have suffered peculiar "flu" symptoms after 
spraying tlieir flowers and shrubs with a common form of i)esticide. They 
rarely learn that they have been mildly "poisoned" by an organo phosphor 
compound. In more lethal strengths, the same chemical agent is used in "nerve 
gas." and can wipe out huge populations of men or animals in a few miniites. 
But despite the obvious hazards, very little is being done to control the wide- 
spread foreign and domestic sale of highly toxic pesticides ; beyond that, the 
Army is continuing its secret tests of nerve gas as a weapon of mass annihila- 
tion. 

Army experimenters had an unexpected windfall of data from the accidental 
exposure of several thousand sheep to air-sprayed nerve gas near Dugway, 
Utah. The chemical that killed these sheep also goes into the organo phosphors 
pesticides — such as the widely distributed garden product called Parathion. 
Until the end of World War II. Parathion itself was the favorite candidate 
for the standard nerve gas in the Army Chemical Corps' arsenal. Then the 
Army "liberated" the secret German nerve gas. "GB." and it won out over 
Parathion, for two reasons: it was easier to disseminate, and it would not so 
readily arouse public fears as would the use of a common pesticide like Para- 
thion. "GB" was saved for people and Parathion relegated to weeds. 

Both agents have the same toxicity : .2 milligrams per kilogram of body 
weight. Both use the same "kill mechanism" : they prevent the manufacture of 
enzymes which carry body "messages" controlling respiration. In other words, 
victims simply sufi'ocate. Early symptoms (the whole process can take less 
than five minutes) include pinpointing of eye pupils, tightness in the chest, 
convulsions, paralysis, and finally respiratory failure. If the dose is less than 
lethal, the symptoms resemble the onslaught of an attack of the flu. 

Current hearings in Wisconsin into the environmental hazards of the chlori- 
nated family of insecticides — the most notable of which is DDT — focus concern 
about the chemical "synergy" of simultaneous and continued exposure to dif- 
ferent pesticides : there is some evidence that since both the organic phosphor 
pesticides and the chlorinated insecticides accumulate in the fatty body tissues, 
under certain conditions (such as malnutrition stress), genetic damage could 
occur. 

In 1966 alone, over 55 million lbs. of organic phosphor pesticides were manu- 
factured for use in US agri-business. The passage of the Federal Insecticide, 
Fungicide and Rodenticide Act and the public disclosures of pesticide abuses 
had indicated that some reduction or stablization in manufacture and use 
would occur. But there has been a growth of 188 percent in the production of 
organic phosphor pesticides over the period from 1960 to 1966, as compared to 
an increase of 25 percent in the production of all classes of pesticides over the 
same period. Effective substitutes exist, such as the pesticide Malathion with 
1/2,000 of the toxicity of the organic phosphors, and the price differential be- 
tween the two is nominal. 

In 1966 alone, US manufacturers exported 59 million lbs. of organo phosphor 
pesticides to users overseas, the large.st consumers being Canada and Mexico. 
Within domestic agri-business the big users are the commercial fruit-crop 
growers in California (the villains of the current United Farm Workers Orga- 
nizing Committee confrontation with the California pesticide regulatory pro- 
gram), and the cotton producers in Mississippi and Texas. Together, they ac- 
count for almost one-half of the acreage treated by pesticides annually in the 
U.S. 

Federal and state governments subsidize the organo phosphor business 
through secret military chemical and biological warfare research, agricultural 
pesticide research and bio-chemical re.><earch. In fiscal 1967, a total of $70 mil- 
lion in unclassified pesticides research was funded by the Department of Agri- 
culture and the Public Health Service. An ecpial amount is estimated to be 
spent on pesticide chemical research by private industry and state universities. 
Only $5 million is currently allocated for the support of research into the oc- 
cupational and environmental health hazards of pesticides by the PHS. 

In the legislative lexicon, pesticides are called "economic poisons," a euphe- 
mism devised by Congress and the Agriculture Department to distinguish be- 
tween the purportedly beneficial nature of the potentially lethal stuff and 
"hazardous materials" generally. In fact, the "economic poi.sons" are specifi- 
cally exempted from coverage under the Federal Hazardous Materials Act. 



3213 

With AA-ell over 60,000 trade names of pesticides in existence, the job of in- 
dustry surveillance and compliance with existing pesticide manufacturing and 
applications standards is virtually impossible. The response of the Johnson ad- 
ministration after the submission of the Scientific Advisory Council report on 
pesticides in 1965 was effectively to hobble the federal regulatory program. 

Surveillance and regulatory functions were split between the Public Health 
Service and the Agricultural Research Service. The PHS Office of Pesticide 
Research has i-esiwnsibility for conducting basic research on human and envi- 
ronmental health hazards of pesticide use and is also responsible for inspect- 
ing establishments involved with the formulation of pesticide chemicals. If 
that were not enough, the PHS is supposed to monitor areas of concentrated 
pesticide use in major commercial agricultural centers in this country. How- 
ever, the fine Byzantine hand of the agricultural interests has made sure that 
the PHS cannot issue cease and desist orders. Violations are to be turned over 
to the Agricultural Research Service for disposition and prosecution. But the 
ARS hasn't filed a major violation in-osecution with the Justice Department in 
the 13 year history of the Federal "rat and bugs chemicals" act. 

That law contains some neat provisions to dissuade investigators from dig- 
ging into the pesticide chemicals industry. Information on the production of 
synthetic organic compound pesticides is compiled by the US Tariff Commis- 
sion, not Agricultural Research or Public Health. Further, information on the 
exact ingredients of specific formulations are not permitted to be disclosed by 
law, to protect "trade secrets." 

Senator Moxdale. Proceed as you wish. You might tell us a little 
bit about your background and expertise in this field, 

Mr. GoRDox. I am currently conducting a major evaluation study 
for the U.S. Bureau of Labor Standards in connection with the 
occupational safety work injury program. This study takes into 
account such things as topics you have heard from Dr. Simmons this 
morning, the potential under enumeration of work injuries and occu- 
pational disease. 

Last year I testified before the major committee on the same topic 
of the potential under enumeration of industrial injuries and occu- 
})ational diesease in this country. I collaborated with Senator Wil- 
liams of New Jersey and Representative Heckler of West Virginia 
in the preparation of their version of the Coal INIine Safety & Health 
Act of 1969. I would like to make one quip, if I may. 

For a moment I thought my name was not Jerome Gordon, but 
really John Yossarion of Catch-22 fame. I say that not so much 
with tongue-in-cheek but with some reservation about what has 
really transpired here this morning. 

I think that is distrubing to realize that we are using a pesticide 
derived from German World War II nerve gas. We are using about 
55 million pounds of this in the ITnited States, about half of which 
is in concentrated forms in both Texas and California, and to lesser 
extent in INIississippi and Louisiana, and we export this lethal mate- 
rial overseas in the guise of assistance for underdeveloped nations. 
Just yesterday, talking to a friend of mine from the Defense 
Department, he pointed out an article in Aviation Weekly which 
stated that the American Air frame industry is involved in the con- 
struction of agricultural aircraft and was trying to fill up its 
demand for this kind of aircraft by exporting them overseas with 
the potential burgeoning market for pesticide application out of the 
United States. 

I think it is kind of interesting to note that less than 3 weeks ago 
eight people died in the Dominican Republic from Parathion poison- 



3214 

ing of river water, and that 30 people died there last year from the 
effects of Parathion poisoning. 

I think what is disturbing is that we continue to use these nerve 
agents after having liad a cumulative experience of their unfortu- 
nate application during AVorkl War II ni Xazi death camps and 
having seen most recently in this country a rather large controversy 
raised about tlie Chemical and Biological AVarfare research. 

I would like to read an extract which comes from an unclassified 
Army teclmical manual, Chapter 2, of Training Manual 8-285, 
dealing with treatment of chemical agent casualties, dated January 
1968. This is available to the press and it is unclassified. 

Xerve agents are among the most deadly chemical agents. They include 'G' 
agents and 'V agents. Examples of G agents are Tabun GA. Ar.sene GB, and 
Somen GD. The standard is VX. Several related but somewhat less toxic com- 
pounds here proved to be most useful in medicine and agriculture. Tliey in- 
clude BFV, TEI'P, OMPA. Parathion. Malathion, and Carbamates. 

It is further interesting to note that the Army has a word of pre- 
caution for its own troops. 

Widespread use has occasioned many accidental poisonings, some fatal. The 
symptoms and treatment of iwisoning by these compounds are similar to those 
of ix)isoning by nerve agents. 

So we are dealing with exactly the same animal. 

Senator ]\Ioxi)ale. Have there been American farm workers, to 
your knowledge, who died from this nerve gas type pesticide ? 

]Mr. GoRDox. There have been farm workers who had died, from 
records, some of which has been compiled by a lady who couldn't be 
here today, Dr. Irma West at the California Bureau of Occupational 
Health. 

Senator ^NIoxdale. I understand this is a hideous type of death 
that occurs. It affects the nervous system, normal nervous system 
restraints disappear, and the person dies with convulsions. Is that 
correct ? 

Mr. GoRDOX. Senator, I would like to read to you an extract from 
a deposition that was forwarded to me by an attorney in Texas, 
whose client, ]Mrs. John Ford in Lubbock, the wife of farmer, a con- 
stituency I think the American Farm Bureau should be mightily 
concerned about, was poisoned in a rather strange way. I would like 
to relate part of that background information from the statement 
that I prepared for the committee today, because it is rather dis- 
turbing. 

Mrs. Ford was sitting in her house in Lubbock, Tex., in August of 
last year, while her husband and two kids were outside doing some 
marketing in the nearby center of Lubbock, Tex. The property next 
door was being sprayed with the nerve agent Parathion. Mrs. Ford 
^vas not in the direct path of the aircraft or drift pattern of pesti- 
cide application. 

]Mrs. Ford on the morning after the spraying in the field adjacent 
to her, began to feel the early symptoms, rather insidious symptoms 
of Parathion poisoning. She thought she had the flu I What was 
most unfortunate in INIrs. Ford's case was that her own personal 
family physician diagnosed her malady as flu and gave her the 
appropriate shot. . 



3215 

Within 1 week Mrs. Ford's lower limbs began to lose effective con- 
trol and she became temporarily paralyzed. 

Now what is tragic about this is that gomg to a second phy^ician 
in the area, unfortunately a week after the incident, her case was 
careful Iv diao-nosed as Parathion poisoning and the available ante- 
?Me! which rs atropine, was administered. I will discuss atropine 
liter because it is a rather insidious antedote. 

Ithink what was interesting about Mrs. Ford s case was the per- 
nicioi^ness of the pesticide. Mrs. Ford was mside the house while 

e plane was delivering the chemical on the property adjacent o 
ersBiT after chemical examination of the peach trees on her prop- 
erty; ley found that residue from the pesticide had penetrated o 
deeply that in fact it was found in the pits of the peaches on the 

*Tow the manufacturer of the chemical W. R. p^^^^through its 
subsidiary Estes Chemical, they and the Texas Agricultural Com- 
mission have contended that Mrs. Ford can't possibly be Paralyzed 
when in fact she has media proof of her paralysis and some of this 
has been forwarded to the committee. , , ^i ^ i. 

What is absurd about this, and why I related it back to the outset 
of the testimony is that because of another epidemic of the pest, 
green bugs, in the area, on cotton, Mrs. Ford was forced to move 
several lumdred miles away to Albuquerque, N. Mex., to avoid this 
past S]5ring what occurred last August. , . , . ^i • 

What poisoned Mrs. Ford was not Parathion itself but this com- 
pound we heard about from Jerry Cohen this morning, Paraoxon it 
is interesting to note that Paraoxon can be developed within the 
existing stated tolerances for application of Parathion to the helds. 
And it is a very minute amount, less than 21/2 pounds per acre. 

In the deposition which I have here you get some leel for the 
dancrer of Parathion poisoning and its product, Paraoxon, because 
the field was spraved in the course of the year six or seven times, 
again within the allowable residue tolerances set up by the iexas 
State Agricultural Commission. 

Now even with the existing standards, Mr. Ford has a set ot com- 
panions, the 186 peach pickers who were poisoned by the same com- 
pound Paraoxon in 1962 in California. . „ x ^u 

Let me read an extract of an article that is, ironically, from the 
research of Dr. Milby, current head of the California Bureau ot 
Occupational Health. 

First, that the outbreak occurred even though Parathion applica- 
tion met the State of California standards of 2.5 pounds per acre 
followed by 14-day interval between spraying and harvesting. 

Two, that the illnesses were the result of residue accumulated to 
the total amount of Parathion during the entire growing cycle. ^ 

All of this goes to show you can get seriously hurt by following 
the letter of the law, the present pesticide control law, both nation- 
wide and in individual States. 

Senator Mondale. We have heard testimony that if they ]ust fol- 
lowed instructions on pesticide containers, the risk to health would 
be avoided. Do you have a comment on that ? 

Mr. Gordon. I would like to interject one comment. 



3216 

Another individual who I thought should have been here today 
was Dr. Van Den Bosch, a noted entomologist from the University 
of California at Berkeley. It is not only Dr. Van Den Bosch's con- 
tention but it is the contention of a number of experts in the field 
that in fact tlie existing labeling requirements which FDA and C. C. 
Johnson's administration have charge of, are totally inadequate 
from two regards. First, there is no lucid statement about the possi- 
ble harm or toxicity of using the stuff. Second, there is absent, and 
this is most important and most damaging in the case of the opera- 
tions of the American chemical industry, information on the relative 
effectiveness of the pesticide products. 

Most importantly, very few people I think in the field farmers, 
farm workers, and even suburbanites, don't realize what available 
antedotes there are. Most shamefully, the method of treatment and 
antedote are not formally placed or fixed lucidly on the label. 

Senator Moxdale. I talked to Dr. Van Den Bosch, and he said, as 
I recall, that most doctors are not trained to identify or work with 
pesticide poisoning. They don't know how to diagnose it, and they 
don't know how to treat it if they can diagnose it. 

Mr. GoRDox. I think that, as I stated both in my news release and 
testimony, is a serious component of the overall fault with our data 
on occupational health, particularly in areas like pesticidal poison- 

Senator ^NIoxdale. You heard the testimony from Dr. Simmons 
this morning about the data that they have and possible margins of 
under reporting. I thought it was fairly candid testimony, that he 
believes it would he fair to estimate that there are maybe SOO deaths 
other than 150 to 200 that were reported, and in the magnitude of a 
hundred times or more that many injuries. 

What does your expertise tell you about those figures ? 
Mr. GoRDOx. I think Dr. Simmons' estimates are well within the 
range of not only possibility but probability. I would like to go fur- 
ther and corroborate that information with a professional colloquy 
from a colleague of Dr. Simmons at HEAV, Miss Victoria Trasko, 
who is in the National Center for Urban and Industrial Health, of 
the U.S. Public Health Service. 

In an unpublished statement last year prepared for the Occupational 
sonings statistics are indeed for only 6,901 cases from only 23 States 
in this country- that accumulated the information and at best most of 
that information was relatively incomplete.'' 

The mere fact, as Dr. Simmons pointed out briefly before, that 
medical examiners or records compiled by medical examiners and 
records compiled by individual vital statistics agents, are so at vari- 
ance, is indicative of this. She says this is definitely an understat- 
ment of the real occurrences of poisonings in these States. 

And specifically in the case of agricultural chemical poisoning she 
has the following remark. 

"Of the 800 cases of agricultural chemical poisoning reported, 
almost all were from California." 

These lead to another point which the Nation really doesn't know 
about. 



1 



3217 

Senator Moxdale. You heard one of the witnesses say that you can 
discount these figures because an undetermined percentage are 
related to suicide and murder. 
Mr. Gordon. That was said, yes. 

Senator Moxdale. Do you have any information upon which you 
could express your opinion as to whether it can be simply dismissed 
as another form of homicide in America. 

Mr. GoRDOX. I would only say that I would think the problems of 
having a personal family "physician record on a death certificate 
whether it was homicide or suicide, for example, in a case of a 
family, would be quite conceivable, knowing the kind of oath the 
physician might have. 

Senator INIoxdai.e. jNIy point is that if a farm worker, and that is 
what we are hearing testimony on today, is being exposed to loss of 
life or injury by being exposed directly to pesticides in the field, 
that is one thing. But if all of these things can be dismissed just as 
another manifestation of crime statistics, that is something else. 

My feeling was that FDA was trying to leave us with the other 
impression, that there was no source of alarm because of the patho- 
logical manifestation of American psyche, or some such nonsense. 
Would you respond to that? 

]\Ir. GoRDox. I think that question was perhaps in part directed at 
me. I think the problem with FDA and its research programs is in 
fact the research programs that Dr. Simmons and Dr. Johnson were 
talking about this morning are kind of lopsided. For example, in the 
15 cooperative studies that Dr. Simmons and Dr. Johnson talked 
about this morning that are currently being conducted in the United 
States, and rather interestingly they all began in 1965, only one of 
them is in California. 

California is currently consuming 20 to 30 percent of the total 
volume of pesticides applied in this country, and in terms of the 
materiality of the issue at hand, it would seem to me that of the 15 
studies, — if in fact that is all of the funds available for conducting 
that kind of research, that a significantly greater relative proportion 
should be allocated to some of the major areas of concentrations of 
use of pesticides. 

I think that the FDA is a victim of the typical mind-set that is 
normally associated with "hard" scientists oi that kind of bent. I 
think this is injurious also to their own causes and to the health and 
welfare of the Nation, and more particularly in this case to the farm 
workers. 

Senator jMoxdale. Are you familiar with what protections are 
available now nationally to a farm worker if he suspects his health 
or life is in jeopardy from exposure to pesticides? 

Mr. Gordox. It is rather humorous. The Department of Agricul- 
ture spends over $180 million a year on pesticide research and in a 
documented report which I believe has been forwarded to your com- 
mittee they spend less than $160,000 a year for pesticide safety. Most 
of those funds for pesticide safety go into the development of these 
advertising gimmicks on the part of agriculture and chemical man- 
ufacturers. 

As you see, the sign says "Stop l^efore using any pesticide, read the 
precautions." If there really are no lucid precautions on the bottles or 



3218 

containers, this is really a sham. It is further interesting to note that 
the only Spanish lanfruajje proofnim that the U.S. Department of 
Agriculture has in operation is not in California, is not in Texas, but 
rather is in Puerto Rico. 

Senator ^Toxdale. Say that again. 

Mv. Gordon. The only pesticide safety operation of this variety 
that the U.S. Department of Agriculture runs in the Spanish lan- 
guage directed at certain Spanish language employees on farms is 
in Puerto Rico, and not in the area of major pesticide use in this 
country : California, Texas, Louisiana, and jNIississippi. 

Senator Moxdale. Do you know if the Department of Agriculture 
make surveys or seeks to determine the amount or risk to the farm 
worker from exposure to pesticides? 

Mr. GoHDOX. The Department of Agriculture at the present time 
has no safety authority to conduct any surveys in the fields for agri- 
cultural workers and, ironically, for the farmers. I think if I can 
proceed with a bit more summation of the statement, this will 
become clearer. 

A significant facet that was perhaps glossed over is the motivation, 
frankly, of a rather large ungainly industry in the United States, 
the U.S. agricultural chemical industry. It is kind of interesting to 
hear statements from pesticide manufacturers to the effect that they 
have done such humane things as add 10 years to the useful life 
span of underdeveloped nations like India. That is really a specious 
argument. 

In the case of the United Statees with over 60,000 trade name 
products, less than 1 percent of these pesticides are actually used for 
things like control of diseases like Malaria. Here is an extract that I 
read into my testimony from a major industry publication. Chemical 
"Week, and I think I would like you, Mr. Chairman, to pay particu- 
lar attention to what industry says about itself and its future and 
its market. 

"Chemical pesticides production", according to the statement in 
Chemical Week, "has been growing at a 16 percent yearly clip and 
projection of market growth and price patterns indicate that the 
pesticides will pull ahead of fertilizers in total value by 1975." 

The value of pesticides is about $1 billion now and if we add 
markup on sales it is more in the order of $1.7 billion to $2 billion. 
By 1975 the industry expects to be somewhere in the order of $3 bil- 
lion." 

"What is insidious about this was the remark made by Dr. Van 
Den l^osch concerning over-application, the over-selling of pesticides 
by the agricultural chemical companies. This is what the consultants 
in Chemical "Week said: 

Farmers' outlays for pesticides have grown at 15 percent rate per year* since 
lf>oO, jumping from absolute level of .$87 million to more than .$1 billion in 
19(>S. At the same time farm value of crop production has grown only 2 per- 
c-ent and the number of hanested acres lias decreased from 340,000 to less 
than 204,000. In '.">0 farmers sf^ent less than 2'> percent i>er acre for i>esti<?ldeis, 
or 5 ijercent of the value of fann pr(Kluction. Last year in 19C8 they sijent 
over $.3.60 per acre, or rougldy ~> i>ercent of production value. By 197.5 that 
figure will Ije .$8 to $0 i>er acre. 

So I think, as I indicated in my testimony, we are compounding a 
felony on a national level. 



3219 

Now the question is since the public health specialists and indus- 
try know about the toxicity or organic phosphors that we were talk- 
ing about this morning such as Parathion and Malathion, is there a 
trend in production either upwards or downwards in this regard, 
and what are the implications of that in conjunction with probable 
banning of DDT ? I would like to quote some statistics. 

By 1975 the production of DDT according to the consultants from 
Arthur D. Little who prepared this report for Chemical Week, 
DDT will be about 50 percent of the 1968 level of production. In 
contrast Malathion another organic phosphor will be about 200 per- 
cent of 1968 level. Parathion, the most deadly organic phosphor will 
be 125 percent of its current level. So industry in the wake of the 
late Eachel Carson's book Silent Spring, has really not considered 
entering into the active development of more selective, less toxic pes- 
ticides. 

The curiosity to me, is why major manufacturers of Parathion 
continue to manufacture this stuff. Using the consultants data from 
Chemical Week, it is rather interesting to postulate something that 
could happen for the benefit of the farmworkers, farmers, and sub- 
urbanites in this country. 

With the fielding of potentially less toxic products, the risks of 
acceptance at toxicity testing stage, the stage that the FDA and C. 
C. Johnson's agency are most responsible for, if they were reduced 
by half, this would bring about a nine percent reduction in overall 
costs for research and development for the typical pesticide product 
or an average of savings $500,000 per product. 

That savings through reduction of and risk could result in an 
upward spiral of development of increasingly selective, less toxic 
pesticides which I think is a desirable goal, a goal which unlike 
other basic industries in the United States would not have to be sub- 
sidized. 

Another point that was glossed over this morning, and addressed 
in questions asked by Senator Bellmon and by you, Mr. Chairman, 
was why does this anomalous condition of regulatory deficiencies 
exist between U.S. Department of Agriculture and FDA? 

I would like to read from a report that was prepared by U.S. 
General Accounting Office in the course of a review of the entire 
pesticide regulatory program and released last September and prob- 
ably smothered in the back pages of the New York Times. 

On September 10 the U.S. General Accounting Office issued a 
report on regulatory enforcement of the Federal Insecticide, Fungi- 
cide, and Rodenticides Act. The substance of the review was there 
was little effective compliance action and no review by the Justice 
Department in over 13 years. 

This was true, the GAO found, even in instances where repeated 
major violations of the law were cited by the Agricultural Research 
Service and when shippers did not satisfactorily act to correct viola- 
tions or ignored Agricultural Research Service notifications that 
prosecutions were being contemplated. 

The extent of that violation is in the data accumulated on the 
samples that the GAO reviewed that did not meet specifications laid 
down by the Federal Insecticide, Fungicide, and Rodenticide Act. 
Under the act, U.S. Agriculture Research Service can take action to 



3220 

remove products from the market, cancel registration, and classify 
those who ship products wlio violate the law. 

GAO found that in over 2,751 samples of products tested and 
reviewed during fiscal year 1956, over 750 were found to be in sub- 
stantial vioLation of the law. Of these 70 percent or 5"20 with major 
violation of the law. A 1967 total of about 5,000 samples were taken 
and 23 percent were found to be in violation. I don't consider this to 
be effective compliance of the regulation. 

Senator jNIoxdale. What this committee is interested in is the 
extent to whicli American farmworkers' health is jeopardized. That 
is the question that concerns this committee as a part of the overall 
review of tlie life of tlie farmworker of this country. What I think 
is becoming increasingly apparent is that whatever national thrust 
there is for protection of one kind or another, there is little or no 
thrust directed toward the protection of the person whose life and 
health is most in danger, mainly the worker most exposed to pesti- 
cides by either applying them, or being exposed to them by drifting 
or being permitted or forced into the field too early, or working in 
the fields where the pesticides used were too dangerous or have been 
inaccurately applied. And, we find the data the Federal Government 
has is wholly inadequate. 

Indeed, the Director of the H.E.W. program said it was so inade- 
quate that he couldn't base any judgment as to what action should 
be taken. We have only 15 pilot studies, even though the Director of 
statistics says there were 800 deaths a year and 80,000 injuries a 
year attributable to pesticides. I can't understand, and I don't think 
it can be explained by saying that there are more being killed on 
American highways, t think we have a right with this kind of a 
problem to see some concern expressed about health and lives of 
people who are working in the fields. 

I don't see any sense of interest or commitment. Apparently it is 
basically a State's responsibility, and we are going to have an analy- 
sis of that, but according to Senator Bellmon, most of the State laws 
to which reference was made have no worker protection element in 
them at all. They have other objectives. 

So here we see, as we have seen in every area that we have stud- 
ied, whether it is farm bargaining power, whether it is housing, 
whether it is consumer protection, working conditions, the matter of 
life itself, there is little or no concern. 

The individual Avorker, to my knowledge, has nothing he can do to 
protect himself. He is not an expert in these fields. He doesn't know. 
There are for all practical purposes no unions, except the attempt in 
California to include pesticide protection in collective bargaining 
agreements. The Federal Government in effect has no res]:>onsibility, 
it only has some preliminary pilot studies. Most of the States have 
shown no concern, and I am afraid that this is a very serious indict- 
ment about our concern for the value of life. 

Mr. GoRDOx. A serious concern. Senator. I would like to make two 
comments before I get into that subject directly. 

Looking back at my own statement, it is kind of interesting to 
note that in California, which is again the only State that compiles 
any information at all on occupational injury and occupational dis- 
ease for agriculture, the agriculture industry has the highest occupa- 



3221 

tional disease rate, almost three times as high as that incurred by all 
industries in California. We were talking about applicators before, 
agricultural aircraft pilots, people who are directly in contact with 
this stuft'. It is interesting to note that the complement of 1,000 agri- 
cultural pilots in California apply 10 to 15 percent of the nation's 
pesticides and one pilot is killed in an air accident for each 1 million 
acres treated. 

Senator Mondale. I think we heard testimony from Mr. Cohen 
that 12 pilots in one season flew into the ground in California. Is 
that correct? 

Mr. GoRDOx. That is correct. There is even a more fatal absurdity, 
and I would like to read it to you. It describes the mentality of 
some of these applicators in the field and it is a good example of 
what you might call the lack of self concern about the occupational 
health conditions of the job. It relates to the symptoms of Parathion 
in a person, not only for the applicator, but also his son. 

I would like to read from the deposition : 

Is there any danger from your knowledge of this Parathion, any danger 
from it coming in contact with human l>eings and animals? 

The answer is "yes". 

Gould you explain that to us ? 

Answer : 

Of course I have been working around the Parathion several years. It has 
never bothered me and I have had it all my life all over me and I go wash it 
off as soon as possible. Of course we have fliers sprayed occasionally intention- 
ally and naturally they are going to get sprayed some. I never know any that 
is hurt. It gives some of them a headache. 

Last year some of the compianies started putting less water in the Parathion 
and had some pilots getting sick. Of course, it is sickness of the lungs. They 
use atropine to counteract that. They get a new drug. I don't know what the 
name of the new drug is. My boy got sick with it last year working on the 
airplane with it and he vomited and the doctor gave him atropine and he 
came home. They sent him back again to another doctor. They put him to bed 
and gave him Pam. In 15 minutes he was all right. But he was just about 
dead. 

That is the kind of mentality of the unfortunate people who are 
involved in the application of the stuff. 

Senator INIondale. They tell me that one of the intricacies of the 
use of antedotes of pesticides is that it takes a different kind of 
dosage for children and a lot of doctors are unaware of this. They 
will give the wrong dosage, which can be almost as dangerous as the 
pesticide. 

INIr. GoRDox. That is right. 

I would like to read from the Army Training Manual about the 
effect of using the antedote. I don't want to read too much of it but 
I would like to read the effects of it. 

If administration of atropine in doses of about 2 milligrams is repeated 
within an hour, the .'jymptoms become more moderate in degree and some will 
have drowsiness, slowness of memory, feeling that body movements are slow, 
blurring of near vision. 

Wliich was a significant factor in the death of these 15 agricultural 
pilots last year. 

Further administration of atropine will result in severe and incompacitating 
symptoms, including very dry mouth, thirst, hoarseness, dialated pupils, blurring 
of near vision, very rapid heart beats up to /60 beats per minute, urinal reten- 
tion, constipation, restlessness, disorientation, hallucinations. 



3222 

So liere we have a product -which almost has some effects as LSD, 
and yet it is used as an antedotes for pesticides. 

The Army says, ''Abnormal behavior may require restraint." 

Senator Mondale. I regret that our time is sucli that we can't go 
any longer, but we may be submitting some questions to you for the 
record, if you can respond, and that will be true of some of the 
other witnesses, also. 

I will ask the staff today to ask the Food and Drug Administra- 
tion whether these readings on the Thompson seedless graps are 
accurate. 

Also, I am going to order included in the record, at this point, a 
statement submitted by the National Agricultural Chemical Associa- 
tion. Although they were asked to testify, they were unable to 
attend the hearings because of schedule conflicts. Similarly, the Cali- 
fornia Department of Agriculture was unable to accept our invita- 
tion to testify, and I shall order printed their statement. I am also 
going to order included in the record a statement on the Insecticide 
crisis by Dr. Robert Van Den Bosch. Other pertinent communica- 
tions, letters, and documents shall also be included at this point in 
the record. 

Thank you very much, the hearing is now adjourned. 

Whereu]x>n, at 12 :15 p.m., the committee recessed, to be recon- 
vened at tlie call of the Chair. 

(The material referred to follows:) 

Pbepabed Statement of the National Agricultural Chemicals Association 

This statement is submitted on behalf of the National Agricultural Chemi- 
cals Association ^ in response to an invitation from the Subcommittee. In coop- 
eration with the United States Department of Agriculture, the Food and Drug 
Administration and the Public Health Service of the Department of Health, 
Education, and Welfare, and counterpart agencies in each of the states, this 
Association has participated in the development of laws and regulations deal- 
ing with pesticides for the past thirty years. It is the purpose of this state- 
ment to outline the industry, its products, and the existing regulatory controls 
over pesticides, with brief references to current pesticide-related research pro- 
grams. 

The principal regulation of pesticides rests with the United States Depart- 
ment of Agriculture under the Federal Insecticide, Fungicide, and Rodenticide 
Act, 7 U.S.C. §135. This, statute requires all pesticides shipped in interstate 
commerce to be registered with the Department of Agriculture and to display 
the registration number on the label. The burden is on the applicant for regis- 
tration to establish the .safety and efficacy of the product and the suitability of 
its labeling before registration is granted. Under a formal interagency agree- 
ment published in the Federal Register on May 1, 1964, 29 F.R. 5808-09, each 
product that is submitted for registration is reviewed carefully not only by the 
Pesticides Regulation Division of the Department of Agriculture but also by 
the Fish and Wildlife Service of the Dei>artment of the Interior, the Office of 
Pesticides of the Public Health Service and the Food and Drug Administra- 
tion. Each agency reviews the label from its own expertise before registration 
is approved by the Department of Agriculture. 

If the product is not for a food-i)roducing use, it may be shipped in inter- 
state commerce following its review, evaluation and registration. If the pesti- 
cide is to be u.sed in agriculture for the production of food, the Department of 
Agriculture issues a certificate of usefulness certifying that the product is use- 
ful for the control of the insects claimed on the label. The applicant must then 
submit a petition to the Food and Drug Administration requesting that a 
tolerance for a residue of the pesticide be established on each crop on which 



1 NACA is a non-profit trade association representing the manufacturers and distributors 
of approximately ninety percent of the pesticide chemicals used in atrricultnre in the 
United States. Its principal office is located at 1155 Fifteenth Street, N. W., Washington, 
D. C. 



3223 

the pesticide is directed for use. The permissible tolerances are stated in terms 
of parts per million. The approved levels represent a safety factor of approxi- 
mately 100 between the no-effect level of the pesticide in laboratory animals 
and tile maximum permissible residue. The applicant must develop experimen- 
tal data with the use of the product under several of the varying climatic con- 
ditions in the United States to establish the time and minimum rate of appli- 
cation needed to achieve insect control and to determine the maximum residue 
likely to remain when the product is so used. If this residue is less than the 
established safety level, the tolerance is set at the lower level of the two values. 
Once the tolerance is established, and the tolerance may not permit any residue 
to remain if a safe level cannot be determined, the Department of Agriculture 
will register the product when the label instructions and warnings and cautions 
meet the statutory criteria. 

Pesticides are also registered annually in each of forty-eight states, where 
the label statements are subject to constant review. Most state laws are simi- 
lar to the Federal Act. Development of a new pesticide from the laboratory to 
the user requires from five to eight years and an average expenditure of some 
$4,000,000. 

A pesticide, when used, is usually a combination of many ingredients, though 
generally we refer only to the active ingredients. Inert ingredients will include 
solvents, carriers, diluents, spreaders, stickers, detergents, and other materials, 
used to control the percent of active ingredient, including water. The active in- 
gredients are produced principally by basic chemical manufacturers and the 
petroleum companies. Inert ingredients are supplied by a variety of producers. 
Pesticides include not only insect control materials but also defoliants, desic- 
cants, plant growth regulators, rodenticides, disinfectants, fungicides, herbi- 
cides, nematocides, and others. 

Chemicals are essential farm tools. They are not optional control techniques. 
Fertilizers replace soil nutrients which are used by crops for growth and yield. 
Pesticides protect the crop, increase yields, prevent or destroy weeds, and pre- 
serve the harvest in storage until use. Pesticides are used extensively in 
improving the public health and eliminating disease vectors. The World Health 
Organization is a major user of pesticides. Wildlife management requires the 
application of many pesticides to protect food supplies, control disease, elimi- 
nate undesirable wildlife such as trash fish, and to control many predators of 
desirable wildlife, sucli as the sea lamprey which threatened to destroy the 
trout and whitefish populations in the Great Lakes. 

Safe u.se of pesticides is a concern of all persons. Industry's deep interest is 
obvious. The focal ix)int of safe use is, of course, the label. A pesticide will 
not be registered under Federal liaw unless the label provides instructions for 
use and cautions, adequate if complied with, to prevent injury to man and de- 
sirable animals. Persuading people to read and follow labels is a continuing 
program of every one connected with the production and use of pesticides. 

Educational programs must be and are conducted at the local level with the 
support of county, state and Federal governments and the agribusiness indus- 
tries. Short courses on safe pesticide use are conducted by most land grant col- 
leges. Information on safe use is disseminated through the schools, the extension 
service, farm organizations, Federal and state agencies, county commissioners, 
county agents, Four-H Clubs, farm newspapers, magazines, radio, television and 
other forms of available communication. 

NAC sponsored with the National Safety Council the ongoing stop sign pro- 
gram. A facsimile of the stop sign is attached to this statement. Stop signs are 
used on many pesticide containers, in advertising and other literature distrib- 
uted to growers. 

This industry has led the way to improve labeling of a number of pesticides. 
Ten years ago, parathion dust formulations containing two percent or less of 
parathion were not required to bear the word POISON or a skull and cross- 
bones. Industry, after careful review, concluded that these products should be 
labeled with the word POISON and the skull and crossbones and made this 
recommendation to the United States Department of Agriculture. A copy of the 
Association bulletin, dated December 18, 1959, relating to this subject is at- 
tached to this statement. As a result of this recommendation, the regulations 
of the Department of Agriculture were appropriately modified, and since then 
all parathion products regardless of the amount of toxicant bear a poison 
label. 

INIulti-lingual posters and symbols for the illiterate are widely distributed. 
Representative samples are being supplied to the Committee. These posters are 
3&-513 O — 70 — pt. 6A 15 



3224 

designed to prevent injury and illness to workers and to improve the safe han- 
dling and use of i)esticides. They are made available by the Chevron Chemical 
Company as ixirt of that Companys safety program. Chevron is headiiuartered 
in San Francisco. 

Product labels warn that people should not enter a field treated with a pes- 
ticide for a period of time which is related to the specific product used. At- 
tached to this statement is a sample of the label for Xiran, a proprietary par- 
athion formulation of the Monsanto Company. The label directs that persons 
should be kept out of the treated areas for forty-eight hours. Appropriate post- 
ers, therefore, should be used for a i>eriod of forty-eight hours after applica- 
tion to avoid the worker's exposure to a residue of the material. 

The label also directs that the product not be used within a certain period 
of time prior to harvest. These directions are standard for parathion products 
and are approved by the Department of Agriculture. For example, the label di- 
rects that parathion not be applied to apples, apricots, blueberries, cherries, 
grapes, peaches and other fruit within fourteen days of harvest. This helps as- 
sure that the residue at the time of harvest will not exceed the maxinunu per- 
missible limit. The maximum tolerance for parathion is one part per million in 
or on the raw agricultural commodity. 

If the residue at harvest should exceed this amount, the crop is subject to 
seizure and destruction by the Food and Drug Administration. Farm workers 
employed to pick crops are, therefore, not subject to exposure to parathion res- 
idues in excess of one part per million, only a portion of which is on the out- 
side of the crop since the tolerance is for the whole fruit item. Since para- 
thion is a relatively rapid breakdown product, it is extremely doubtful that 
any detectable parathion would remain on a crop fourteen days after applica- 
tion. The patterns of use of pesticides in agriculture and the extremely tight 
controls on residues have combined to protect workers in the field from expo- 
sure to quantities of pesticides which might be injurious. 

Research into all aspects of pesticide u.se and its relation to man and his 
ecology is conducted on a broad scale. Close to one hundred million dollars 
will be spent this year on pesticide-related research. The Public Health Service 
is conducting in depth community health studies in areas of heavy pesticide 
use. Representative segments of the population of workers exposed to pesti- 
cides are monitored. Research programs are underway in eleven states — New 
Jersey, Louisiana, Florida, Texas, Hawaii, Michigan, Iowa, Colorado, Washing- 
ton, California, and Arizona. Research laboratories at Wenatchee, Washington, 
and Perrine, Florida are devoted to i>esticides. Indu.stry monitors the health of 
plant employees on a regular basis. 

Nationwide monitoring of soils in several thousand sites is a program of the 
Department of Agriculture. The Department of the Interior operates laborato- 
ries at Gulf Breeze, Florida, Ann Arbor, Michigan, and Denver, Colorado. Pes- 
ticide levels at one hundred sixty sites along all coasts are monitored by 
monthly collection and analysis of clams and oysters. Six species of fish are 
collected and analyzed quarterly from many stations in the Great Lakes and 
mallard and black ducks and similar water fowl are monitored regularly for 
pesticide residues. 

The Department of Health, Education, and AVelfare is studying the atmos- 
pheric distribution of pesticides on the Ea.st Coast and the presence of these 
materials in the principal river drainage basins in the United States. The 
OflSce of Product Safety of the Food and Drug Administration conducts, six 
times yearly, a market basket survey in thirty different markets. A week's sup- 
ply of food for a nineteen year old boy (reputed to be our biggest eater) is 
purchased off the shelves and analyzed for all pesticides. These surveys have 
shown pesticide residues to be consistently below the tolerance level set by the 
Food and Drug Administration. 

Active water, soil and air monitoring programs are being conducted by sev- 
eral .states — Alaska, California. Delaware, Georgia, Iowa, Mas.sachusetts, Michi- 
gan, North Carolina, Texas, and Wi.sconsin. 

Combined, these .studies produce an impressive mountain of data. Better 
reader acceptance is gained by proclaiming the threatened extinction of birds 
such as the osprey (which is currently thriving in Maryland), but the dull 
routine facts, ba.sed upon painstaking research, reflect that the risk-benefit 
equation is in balance. The last Senate Committee to study this subject, the 
Subcommittee on Reorganization and International Organizations of the Com- 
mittee on Government Operations, under the Chairmanship of Senator Ribicoff, 



3225 

also came to this conclusion. (S. Rep. No. 1379, S9tli Cong., 2d Sess. (1966) at 
64-65. ) 

The additional one hundred million people predicted for our population by 
President Nixon, must be fed. True, protein requirements can be satisfied by 
processed fish scales and algae, but the American citizen today demands to 
live, not just exist. 

Tremendous resources are brought to bear daily on the pesticide issues. No 
new approaches are apparent. Continued and repeated effort at education 
stressing the need to treat i>esticides with resi>ect and care is the anticipated 
program of the future. Pesticides can ))e and are handled safely— they perform 
their funcion, an essential function— but users must assume some responsibility 
for avoiding misuse and the hazards which result. 

This Association and the industry it represents will continue their efforts to- 
ward eflicient and safe use of all pesticides. Continued education seems to be 
the most promising approach to even safer and more careful handling and use 
of pesticides. 

(Exhibits attached to this statement have been retained in the Subcommit- 
tee's files. They consist of actual posters, literature showing labelling of chemi- 
cals as they are sold, and other informative information about the industry. ) 

National Agricultural Chemicals Association, 

Washington, B.C., December 18, 1959. 

MEMBERS of THE INDUSTRY 

Re Labelling of organic phosphate insecticides 

In recent months there have been a number of accidental deaths resulting 
from misuse of parathion dust formulations where the actual amount of toxi- 
cant was 2% or less. In these incidents it has been established that lack of ad- 
herence to safe use practices was a major factor. 

Under Interpretation 18 of the regulations for the enforcement of the Fed- 
eral Insecticide, Fungicide, and Rodenticide Act, parathion dusts 2% and 
below are not required to be labelled with the skull and crossbones and the 
word poison. 

The basic producers of parathion have held two meetings to discuss the 
problem of misuse of parathion formulations. At a meeting held at the NAC 
oflSces on November 18 they recommended that labels of all parathion products 
should bear warning and caution statements the same as now required for 
parathion formulations containing more than 2% parathion, which includes 
the skull and crossbones. They feel that such labelling coupled with an in- 
creased educational campaign to inform users of the hazards of parathion 
would do much to reduce the likelihood of further deaths due to mis-use. 

The parathion producers further recommended that NAC should approach 
the Pesticides Regulation Branch requesting that Interpretation 18 be revised 
to require that labels of all Parathion products bear the skull and crossbones 
and other warning and caution statements now required to appear on formula- 
tions containing more than 2% parathion. 

These two recommendations have been reviewed by members of the NAC 
Lawyers Committee and that Committee has approved the parathion producers 
recommendations. 

Since the meetings on parathion, the question of whether similar action 
should be taken in regards to certain other organic phosphate pesticides has 
been raised by USDA and at least one of the states. NAC conducted a tele- 
phone survey of basic producers of TEPP, systox and disyston. The producers 
of these chemicals have stated that it would be desirable to require all formu- 
lations, regardless of percent of active ingredients, to bear a poison label, in- 
cluding the skull and crossbones. 

We have advised the Pesticides Regulation Branch of the above recommen- 
dations and have asked that they consider amending interpretation IS of the 
regulations for the enforcement of the Federal Insecticide, Fungicide, and Ro- 
denticide Act to require that a poison label, including the skull and crossbones, 
appear on all formulations containing Parathion, TEPP, systox and disyston. 
Mr. .T. C. Ward, Branch Chief, informs us that they are now considering the in- 
dustry recommendations and will contact us when these recommendations have 
been thoroughly reviewed. 



3226 

In view of the above described action and in light of anticipated changes in 
regulations, we urge members of the industry to voluntarily adopt the label- 
ling program for Parathion, TEPP, systox and disyston. We have been in- 
formed that in at least two states, Florida and Massachusetts, action will 
likely be taken to require such labelling at the state level if the regulations 
are not revised by USDA. 

We believe it will be of benefit to the industry to voluntarily adopt this la- 
belling program. The labelling program and an increased educational program 
to inform users of potential dangers from highly toxic organic phosphate pesti- 
cides when they are improperly used should reduce the chances of further 
deaths due to mis-use. 
Yours very truly. 

L. S. HiTCHNEB, 

Executive Secretary. 

Chevbon Chemical Co., 

San Francisco, Calif., 

New Pesticide Safety Posters Can Be Read by Illiterates 

Chevron Chemical Company has produced four new pesticide safety posters 
for distribution through members of the National Agricultural Chemicals Asso- 
ciation. 

Three of the high-visibility posters can be comprehended by workers who 
can't read. All four of them communicate warnings in either English or Span- 
ish. 

The brilliant yellow, black and white posters, 24" wide by 35" high, were 
prepared for mounting wherever agricultural workers congregate or pass-by, as 
a means of promoting increased understanding of fundamental safety, precau- 
tions for those who work around pesticides. 

L. F. Czufin, Manager of Advertising and Public Relations for Chevron 
Chemical Company asserted that the posters are the end product of intensive 
research by a team of industrial safety psychologists, language experts and 
graphic art experts who attempted to achieve the optimum in quick sight im- 
pressionability with a minimum of words. 

These posters, pompletely non-commercial, are available at cost to other com- 
panies. Individual company names are imprinted. California Chemical Com- 
pany has absorbed development costs as part of its commitment and concern 
with the proper usage of pesticides. Czufin said, "This is one of several steps 
we've taken over the years in our continuing effort to encourage proper pesti- 
cide precautions." 

Another step in this program was the company's production of the award- 
winning motion picture, "Prescription for Safety." This film is available to 
other pesticide manufacturers (with their name in the titles) for showing to 
their customers in the pure interest of safety. 



California Department of Agriculture, 

Sacramento, July 30, 1969. 
Hon. "Walter F. Mondale, 
Senate Subcommittee on Migratory Laoor, 
Washington, D.C. 

Dear Senator Mondale: In response to the telephone call by Mr. Boren Chert- 
kov, Counsel for the Senate Subcommittee on Migratory Labor, we are enclos- 
ing a .statement pertaining to the California pesticide regulatory program. 

It is not possible for us to have someone in Washington, D.C. to testify at 
the subcommittee hearing on Friday, August 1, and it will be appreciated if 
you will accept our statement for the record. 

If you have further questions, please let us know and we will do the best 
we can to .supply you with information. 

We feel strongly that our pesticide regulatory program is exceedingly effec- 
tive in protecting persons, animals, and crops. 
Sincerely, 

Jerry W. Fielder, 

Director. 



3227 



REPRINT FROM 

RESIDUE REVIEWS 

VOLUME 6 

EDITED BY 

FRANCIS A. GUNTHER • riverside 

SPRINGER- VERLAG / BERLIN • GDTTINGEN • HEIDELBERG / 1964 
printed IN GERMANY 

NOT IN CIRCl'I \TION 



THE CALIFORNIA PESTICIDE REGULATORY PROGRAM 

BY 

A. B. LEMMON 



3228 



The California Pesticide Regulatory Program 

By 
Allen B. Lemmon * 

Contents 

I. Introduction 27 

II. Legal requirements 28 

a) Registration or licensing of each pesticide product 28 

b) Licensing of agricultural pest control operators 29 

c) Injurious materials 29 

d) Pesticide residue inspection 29 

III. Protection of wildlife 30 

IV. Conclusion 31 

Summary 31 

Resume 31 

Zusammenfassung 32 

References 32 

I. Introduction 

The preceding report on the "Use of Pesticides" prepared by the 
President's Science Advisory Committee provides an excellent basis for 
evaluation of a state's pesticide regulatory program. The report emphasizes 
the great gains that have been made in the production of food, feed, and 
fiber through proper use of pesticides. California leads the nation by a 
wide margin in the production of fruits and vegetables. Its agriculture is 
the most diversified in the world, with no one crop dominating the State's 
farm economy. More than 140 crops are produced in commercial volume in 
California. When the various horticultural specialty crops are included, the 
total exceeds 200. 

In order to reach this great production, California farmers have made 
full use of pesticides and other modern farm methods. They have realized 
that there are hazards in use of pesticides and have strongly supported 
effective laws to assure that their produce is not only safe for their con- 
sumers, but will comply with the strictest standards that may apply 
anywhere in the world. 

Strict enforcement of laws is necessary if full protection is to be received. 
In addition to the staff of the California Department of Agriculture, there 
is the County Agricultural Commissioner, who in his respective county, 



* Chief, Division of Plant Industry, California Department of Agriculture, 
Sacramento, California. 



3229 

28 Allen B. Lemmon 

and under the supervision of the State Department of Agriculture, enforces 
the regulations pertaining to application and use of pesticides. The County 
Agricultural Commissioners, with their staffs numbering about 700, have 
an intimate knowledge of almost every farm in their counties and provide 
California with agricultural law enforcement that is unmatched. 

II. Legal requirements 

California has had a comprehensive pesticide regulatory program for 
many years. The program has four parts which can be described as: (a) con- 
trol over the composition and labeling of the individual pesticide products; 

(b) licensing of the business firms and aircraft pilots applying the materials; 

(c) restricting sale and use of particularly hazardous materials by requiring 
permits; and (d) testing of fruits and vegetables and other produce for 
pesticide residue. 

a) Registration or licensing of each pesticide product 

Each pesticide, and this term includes all insecticides, fungicides, dis- 
infectants, rodenticides, herbicides, and similar materials used around homes 
and in industry as well as on farms for control of pests, must be registered 
with the State Department of Agriculture before being offered for sale in 
California. When a pesticide is first offered for registration the manufacturer 
submits extensive information on tests that have been made to establish the 
effectiveness of the product against the pest which is to be controlled, in- 
formation with regard to both the acute and chronic toxicity, and infor- 
mation concerning any hazard involved in the use of the product. A hazard 
may include possible injury to people applying the material, to the crops 
being treated, to livestock, and to honeybees. In many cases special attention 
is given to need for protection of fish and wildlife. Consideration is also 
given to hazards that might arise if the material drifts onto adjacent areas 
or contaminates bodies of water. All of this information developed by the 
manufacturer for a single product may cost a million dollars or more, and 
the summaries submitted may consist of several thousand pages. The in- 
formation now required for registration of new chemicals is considerably 
more extensive than that required a few years ago. Where problems develop 
in older products, re-evaluation is made, and this includes consideration of 
a proper tolerance for any pesticidal residue that may remain on a crop that 
has been treated. If the product is not intended to be applied to a food crop, 
or if it is of a type that dissipates rapidly and leaves no residue, then a 
tolerance is not needed. 

At the present time manufacturers secure federal registration either 
before or about the same time that they request registration in California. 
This means that there is simultaneous evaluation of the information by the 
Pesticide Regulation Division of the U.S. Department of Agriculture, the 
U.S. Food and Drug Administration if there is need for a tolerance for 
pesticidal residue, and the staff of the California Department of Agriculture. 
There is exchange of information between these agencies. There is no pro- 
vision in California law for a registration under protest. If a pesticide 



3230 

A state views "Use of Pesticides" 29 

product appears unacceptable for registration in the State, it is refused 
registration. Registration may be refused, after hearing, on the basis that 
a product is of little or no value for the purpose for which it is intended, 
or is detrimental to vegetation, except weeds, to domestic animals, or to 
the public health and safety even when properly used. Registration may also 
be refused in case false or misleading statements are made or implied by 
the registrant. 

Products containing sodium fluoroacetate, commonly known as Com- 
pound 1080, and those containing thallium are restricted by law and may 
be licensed only for sale for use by specially trained people. These two types 
of materials are not permitted to be sold generally within the State, except 
for materials for ant control containing thallium not more than one percent. 

h) Licensing of agricultural pest control operators 

Each agricultural pest control operator is required to be licensed by the 
Department of Agriculture before engaging in the business of applying 
pesticides for hire in California. Also, eadi agricultural pest control operator 
must first register with the County agricultural Commissioner in each county 
in whidi business is to be done, and render a monthly report to him of all 
work done in the county. In the case of application by aircraft, each pilot 
must pass an examination to demonstrate his knowledge of the nature and 
effect of the materials being applied by aircraft. If either the agricultural 
pest control operator or an agricultural aircraft pilot does not comply with 
the law and regulations, he is subject to prosecution on a misdemeanor 
charge, or his license may be suspended or revoked. 

c) Injurious materials 

Certain pesticides have been declared to be injurious materials or in- 
jurious herbicides and can only be used under permit from the County 
Agricultural Commissioner. The Director of Agriculture, after investigation 
and hearing, designates those materials that, because of their high toxicity 
or special hazards, can only be used under permit. The law provides that it 
is illegal to sell any of these materials to a person required to have a permit 
unless he has such permit. At the present time herbicides containing 2,4-D 
and several related compounds are placed in this category. The injurious 
materials include such arsenic compounds as sodium arsenite solution, cal- 
cium arsenate, and lead arsenate, and a number of the highly toxic organic 
phosphorus compounds, including parathion and Phosdrin. Chloropicrin is 
also classed as an injurious material. In all, five hormone-type herbicides 
and fourteen other pesticides require special permit to buy and use. 

If all the directions on labels of pesticides and the rules and regulations 
governing their use are carefully followed, there should be no injury or 
damage, or excessive residue remaining at harvest. 

d) Pesticide residue inspection 

The California Department of Agriculture regularly inspects and ana- 
lyzes samples of fruits and vegetables, feeding stuffs, milk, hay, meat, and 
other produce in wholesale channels to be certain there is no excessive pesti- 



3231 

30 Allen B. Lemmon 

cide residue on the food offered for sale in the State. This is really a double 
check to be sure that the program guiding sale and use of pesticides has been 
completely successful. Samples are also drawn from retail markets as a 
further chedc. No residue at all is found on over half of the produce availa- 
ble to the housewife. Much less than one percent may be slightly over 
tolerance and the remainder well within the tolerances established. 

The Federal Food and Drug Administration draws samples from lots 
of produce that may move interstate. During the past year it made no 
seizures of California produce. 

The tolerances for pesticide residues established under the authority of 
the Agricultural Code and listed in the California Administrative Code are 
essentially the same as those established by the Federal Food and Drug 
Administration under federal law. They are based upon extensive toxi- 
cological information developed by the applicant for a tolerance through 
tests on animals, and are evaluated by competent people. The tolerances are 
expected to provide adequate safety factor so that there will be no hazard 
to consumers of the food even if it were accidentally contaminated with 
many times the tolerance. Whenever new information is developed that 
indicates need for review of a particular tolerance, such evaluation is made. 

III. Protection of wildlife 

The California Department of Agriculture has always recognized the 
need to protect beneficial wildlife. As early as 1915 special instructions were 
provided to those engaged in poisoning rodents and other pest animals 
calling attention to precautions necessary to prevent damage to other 
animals. 

When thallium first was proposed for use for rodent control, the De- 
partment of Agriculture recommended legislation which was enacted to 
restrict possession and use of this toxicant to governmental officials for use 
for pest control purposes. Similar restrictions were placed on sodium fluoro- 
acetate when It first became available for use. 

Wherever information has been submitted that a particular usage is 
detrimental to wildlife an evaluation is made and a way is found to allevi- 
ate the situation and protect the wildlife. For example, some years ago it 
was found that rotenone spray applied to dairy animals for cattle grub 
control was fatal to fish if permitted to drain into streams carrying fish. 
Arrangements were made to prevent such runoff until the rotenone had 
deteriorated and would no longer be toxic to fish. Labels of rotenone pro- 
ducts are required to warn against effect on fish. A typical label reads: 
"Caution: To protect fish and wildlife do not contaminate streams, lakes, 
or ponds with this material." 

There is an excellent working arrangement with the California Depart- 
ment of Fish and Game, which brings to the attention of the Department of 
Agriculture any pesticide wildlife problems. Such problems are Investigated 
together by these agencies, and solutions are developed. 

Even though considerable research is now being carried on to determine 
current pesticide levels and their trends in man and his environment, further 



3232 

A state views "Use of Pesticides" 31 

research is needed in this field. More information is needed concerning any 
toxic effects pesticides may have on wildlife, as reliable scientific informa- 
tion must be available to support regulatory actions. 

IV. Conclusion 

The program for regulation of the sale and use of pesticides in Cali- 
fornia provides even greater control over these materials than is exercised 
by the Federal Government as recommended in the report of the President's 
Science Advisory Committee. The California program restricts nineteen 
pesticides to use under specific regulations and requires a permit to purchase 
and use them. As need arises, additional materials can be placed under these 
restrictions. 

The pesticide residue testing of samples of fruits, vegetables, and other 
produce confirms that by controlling labeling and application of pesticides 
the food offered for sale in retail markets is free of pesticide residues that 
might be detrimental to health. 

Summary 

California farmers use large quantities of pesticides to protect their many 
growing crops. Strict enforcement of comprehensive laws is necessary to 
guide proper handling and use of pesticides. 

The California pesticide regulatory program includes licensing of each 
pesticide product, qualification of those engaged in the business of applying 
pesticides, restriction of the sale and use of particularly hazardous materials 
by requiring permits for use, and testing of fruits and vegetables and other 
produce for pesticide residue. 

The effectiveness of the program is confirmed by the fact that surveys of 
produce on the retail markets generally show all food to be free from 
excessive pesticide residue. 

Consideration is given to protection of wildlife by requiring cautions on 
labels of pesticide products and instructions to pest control operators con- 
cerning precautions to be taken in handling these materials. 

Resum6 * 

Les fermiers californiens utilisent de grandes quantit^s de pesticides pour 
prot^ger leurs nombreuses r^coltes sur pied. Une rigoureuse mise en vigueur 
de lois intelligibles est n^cessaire pour guider la manipulation correcte et 
I'usage des pesticides. 

Le programme de la r^glementation californienne sur les pesticides inclut 
une licence pour chaque produit pesticide, la qualification de ceux qui ont 
en charge leur application, des restrictions de vente et d'utilisation pour les 
produits particuli^rement dangereux, en requ^rant des permis d'utilisation 
ainsi que la pratique d'essais sur fruits, legumes et autres denr^es pour la 
recherche des r^sidus. 



* Traduit par S. Dormal van den Bruel. 



3233 

32 Allen B. Lemmon 

L'efficacite de ce programme est confirmee le fait que le controle des 
produits presentes a la vente au detail prouve g^neralement que toutes les 
denrees alimentaires sont exemptes de doses exag^r^es de r^sidus de pesti- 
cides. La protection du gibier est assuree par I'exigence d'avertissements 
devant figurer sur les etiquettes des produits pesticides et d'instructions aux 
operateurs quant aux precautions a prendre lors de leur manipulation. 

Zusammenf assung * 

Die kalifornischen Farmer wenden grofie Mengen von Schadlingsbe- 
kampfungsmitteln an, um ihre zahlreichen Pflanzenkulturen zu schiitzen. Die 
strenge Durchfiihrung umfassender gesetzlicher MafJnahmen ist notwendig, 
um eine richtige Handhabung und Anwendung von Schadlingsbekampfungs- 
mitteln durchzusetzen. 

Das „California Pesticide Regulatory Program" beinhaltet die Zu- 
lassung eines jeden Schadlingsbekampfungsmittels, die Frage der Eignung 
der in der Anwendung der Schadlingsbekampfungsmittel beruflich Tatigen, 
ferner einschrankende Mafinahmen fiir Handel und Anwendung besonders 
gefahrlicher StofFe, indem es Erlaubnisscheine fiir deren Anwendung fordert, 
weiterhin die Uberpriifung von Obst und Gemiise und anderen Produkten 
auf Schadlingsbekampfungsmittel-Riickstande. 

Die Wirksamkeit dieses Programms wird durch die Tatsache bestatigt, 
daf^ die Kontrollen der Produkte im Einzelhandel im allgemeinen zeigen, 
daf^ alle Lebensmittel frei von iibermafJigen Schadlingsbekampfungsmittel- 
Riickstanden sind. 

Beriicksichtigung findet auch der Schutz der frei lebenden Tiere, indem 
man Warnungen auf den Etiketten der Sdiadlingsbekampfungsmittelpackun- 
gen und Belehrungen der Schadlingsbekampfer iiber VorsichtsmafJnahmen 
bei der Anwendung dieser StoflFe fordert. 

References 

Agricultural Code, State of California. 

California Administrative Code, Title 3, Agriculture. 

President's Science Advisory Committee, Jerome B. Wiesner (Chairman): Report 

on "Use of Pesticides". The White House. May 15, 1963. Reproduced in Residue 

Reviews 6, 1 (1963). 



* Ubersetzt von O. R. Klimmer. 



3234 




SPRINGER-YERLAG 

Berlin Gottingen Heidelberg 



RESIDUE REVIEWS 

Residues of Pesticides and Other Foreign Chemicals 
in Foods and Feeds 

Riickstands-Benchte RuckstSnde von Pestlciden und anderen Fremdstoffen 

in Nahrungs- und Futtermitteln 



Edited by 

Francis A. Gunther 

Riverside, Calif., 
with the co-operation 
of numerous experts 



In the USA and Canada Residue 
Reviews are distributed by 
Academic Press Inc., Publishers, 
New Yorii 



Leaflet on request! 



Volume I: In English. With 22 figures 
IV, 162 pages 8vo. 1962. Cloth DM 22,— 

Volume II: With 10 figures. IV, 156 pages (130 pages 
in English, 26 pages in Frendi) 8vo. 1963. Cloth 
DM 22,— 

Volume III: In English. With 16 figures and 13 tables 
IV, 170 pages 8vo. 1963. Cloth DM 22,— 

Volume IV: With 33 figures. IV, 175 pages (164 pages 
in English) Svo. 1963. Cloth DM 24,— 

Volume V: Instrumentation for the Detection and 
Determination of Pesticides and Their Residues in 
Foods 

Symposium held in Los Angeles on March 31-April 5, 

1963. In English. With 75 figures VIII, 176 pages Svo. 

1964. Cloth DM 26,— 

Contents: Introduction to symposium; Special features 
in the analysis of pesticide residues: Residue analysis 
and food control. Gas chromatography using an 
electron absorption detector. Quantitative determi- 
nation of pesticide residues by electron absorption 
chromatography: Characteristics of the detector. Se- 
lective detection and identification of pesticide resi- 
dues. Applications of the microcoulometric titrating 
system as a detector in gas chromatography of pesti- 
cide residues. Comparison of flame ionization and 
electron capture detectors for the gas chromatographic 
evaluation of herbicide residues. Applications of po- 
larography for the detection and determination of 
pesticides and their residues. Polarography for the 
determination of organic feed medicaments. The po- 
tential of fluorescence for pesticide residue analysis. 
Infrared and ultraviolet spectrophotometry in residue 
evaluations. Automatic wet chemical analysis as applied 
to pesticide residues. Determination of pesticide resi- 
dues by neutron-activation analysis. 



3235 

U.S. Senate, 
Washington B.C., September 4, 1969. 
Mr. Jerry W. Fielder, 

Director, California Department of Agriculture, 
Sacramento, Calif. 

Dear Mr. Fielder: I am in receipt of your letter of July 30, 1969 and your 
statement pertaining to the California pesticide regulatory program which you 
enclosed. 

I think your statement is an important contribution to the hearing record, 
and I have accordingly ordered that it be made a part of the record of our 
hearings in Pesticides and the Farmworker on August 1, 1969. 

During our hearings, Jerome Cohen, a witness for the United Farm Workers 
Organizing Committee asked that you respond to two questions : 

1. What is the basis for your statement that DDT can be safely used on 
grapes when it has been recommended not to be used on any other crop except 
cotton ? 

2. Why don't you take positive steps to have private growers release their 
pesticide records, so that the public will know what is being put on their 
grai3es ? 

I would very much like to have your response to these questions so that it 
can also be printed in our hearing record. Your cooperation in this matter is 
deeply appreciated. 

Thank you very much for your interest in, and cooperation with, the work 
of the Subcommittee. 



With warm regards. 
Sincerely, 



Walter F. Mondale, 
Chairman, Subcommittee on Migratory Labor. 



California Department of Agriculture, 

Sacramento, September 17, 1969. 
Hon. Walter P. Mondale, 
Chairman, Subcommittee on Migratory Labor 
U.S. Senate, 
Washington, D.C. 

Dear Senator Mondale : Thank you for your letter of September 4, 1969. I am 
pleased that you are including our statement pertaining to the California pes- 
ticide regulatory program as part of the record of your hearings on pesticides 
and the farm worker. 

My response to your questions is as follows : 

1. What is the basis for our statement that DDT can be safely, used on 
grapes when it has been recommended not to be used on any other crop except 
cotton? 

DDT has been used through the years on a wide variety of crops to protect 
a broad spectrum of pests that attack such crops. Both the United States Food 
and Drug Administration and the California Department of Agriculture have 
established on many crops tolerances for DDT that are adequate to safeguard 
the, health of the people eating the fruits and vegetables. Because of the con- 
cern over the effect of DDT and other long-lived pesticides on the environ- 
ment, we propose to reduce the total usage and restrict use of DDT for the 
control of those pests on those crops where there is no other satisfactory alter- 
native material. In the case of grapes the grape bud bettle is occasionally a 
pest on certain varieties of grapes, and when it occurs it is very damaging. 
Usually only a small acreage is attacked at one time. It attacks grapes in the 
spring when buds are forming, and the use of DDT at this time does not leave 
any residue on grapes at the time they are harvested. We have not had a 
problem with this pest for several years. 

2. Why don't we take positive steps to have private growers release their 
pesticide records so that the public will know what is being put on their 
grapes ? 



3236 

In California each commercial pest control operator is required to file with 
the County Agricultural Commissioner, in accordance with the Commissioner's 
regulations, a monthly report covering the work done in that county during 
the previous month. These reix)rts include the n.imes and locations of the custo- 
mers, and customer lists are regarded as private business. Various counties do 
make summations of the pesticides used and distribute such information to 
those that are interested. A copy of the news release stating our Departmental 
policy is enclosed. We would like to emphasize that whenever there is a case 
of actual or suspected illness I'esulting from exposure to i)esticides, the Depart- 
mental will make available to the exposed person, his family, his physician, 
his attorney, and any other responsible interested party all of the information 
it has which could bear on the illness. 

3. Is it true that grapes in California have been sprayed with Amino Tria- 
zole? If so, how much of that chemical was used and how many acres of 
grapes were involved? 

Amino Triazole is not sprayed on grapes. It is occasionally used for control 
of weeds, but such use is carefully limited so that there will be no chemical 
either on the grapevines or on the grapes. Application for weed control is made 
at a time of year when there are no grapes on the vines. 

If there is any further information that we can send you, please inform us. 
Sincerely, 

Jerry W. Fielder, 

Director 



August 11, 1969. 
Jerry W. Fielder, 

Director, California Department of Agrieulture, 
Sacramento. 

California Director of Agriculture Jerry W. Fielder today made a policy 
statement regarding the release of information on agricultural pesticide appli- 
cations. 

In issuing the statement. Fielder said it reaffirmed the Department's position 
on release of pesticide information. He noted that severe controversy exists in- 
volving several lawsuits, and unwarranted charges by litigants, organizations, 
and other interested parties critical of restrictions on the release of such in- 
formation. 

The Director declined to comment directly on litigation at this time, saying 
he hoped these cases could be handled through the legal process itself. 

Director Fielder's statement of policy on pesticide information releases fol- 
lows : 

1. "In any case of actual or suspected illness resulting from exposure to pes- 
ticides, the Department will make available to the exposed person, his family, 
his physician, his attorney and any other responsible interested party, all the 
information it has which could bear on the illness. Further, it is expected that 
each County Agricultural Commissioner will make such information available 
from his files. 

2. "If proi)erty damage results from pesticide application, the Department 
will make available to the injured party, his attorney, and any other responsi- 
ble interested party, its information concerning the material used, and manner 
of application." 

3. "In ca.se of complaint about improper method of application which endan- 
gers persons or property, information will be made available as to the applica- 
tor and requirements for proper applications. This includes applications by 
either aircraft or ground equipment. 

4. "Permits issued by County Agricultural Commissioners for the applica- 
tion of pesticides are considered public records. 

5. "The type of information developed in investigations into illegal or improper 
practices is naturally confidential, as it is in any investigative process of 
law. Information concerning confidential business relationships and customer 
lists revealed in routine reports is also confidential in nature. 

"This type of information is contained in the pest control applicator's re- 
ports and at this time the status of such confidentiality is being decided by the 



3237 

courts. The Kern County Superior Court has ruled against the release of such in- 
formation." 

Fielder said the Department of Agriculture will continue to require its li- 
censed pest control operators to comply strictly with all laws and regulations 
governing the application of cliemicals. 

"There is no excuse," Fielder said, "for an applicator to apply materials 
while workers are in the field. The Department will not tolerate the placing of 
improper amounts or types of materials in any circumstances. The law care- 
fully controls the amounts and types of pesticides and herbicides that may be 
used. 

"There is nothing static about the Department's position. If needs change, so 
will the Department's position. Restriction on the granting of permits is under 
continued review. 

"If the courts decide that records now held confidential by the Department 
are a matter of public record, the Department will fully comply." 



The Califobnia Pesticide Regulatory Program 

There are many factors that contribute to the ability of California farmers 
to produce a large portion of the nation's food and fiber supply. Nature has 
been good to us in providing a wide variety of climate and a large fertile land 
area for production of a great variety of crops. Also, we have been protected 
from the introduction of new pests that occur in other parts of the United 
States and other parts of the world by our geographical location. The moun- 
tains on the north and the east, desert on the south, and the ocean on the 
west all serve as barriers to many pests and keep them from becoming estab- 
lished in California. Our plant quarantine inspection system has tried to pre- 
vent introduction of such pests through movement of man and his commodi- 
ties. In spite of these protection factors we do have pest problems that require 
use of pesticides. 

The great distance to markets, particularly to the eastern part of the United 
States, has made it necessary for California farmers to try to produce the 
highest quality fruits and vegetables. To do this they use the best available in- 
formation and the most satisfactory cultural practices. They try to take ad- 
vantage of natural factors such as parasites or predators to control those pests 
that have become established in California, but they still must use a wide va- 
riety of pesticide materials to produce good safe, high quality food. 

On grapes there are a variety of pests that become serious at various times, 
but all the grapes are never treated at the same time. In developing his pest 
control program the farmer tries to use pesticides that will be most effective 
during the dormant season if the life cycle of the pest indicates that this is 
the time to attack it. The growing cycle in some cases requires other treat- 
ments, while any treatment that is given at the time that there is fruit on the 
vines must be so regulated that there will not be pesticide residues in violation 
of federal and State tolerances at the time that the crop is harvested. For ex- 
ample, any DDT that is used on grapevines must be used prior to 40 days be- 
fore harvest to assure that there will be practically no residue on the grapes 
themselves at the time of harvest. Samples of grapes drawn from supplies in 
retail markets show them to be safely within legal pesticide tolerances. 

Through the years California farmers have supported legislation and regula- 
tions that provide the most thorough control over sale and use of pesticides of 
anywhere in the world. The regulatory program has several facets. First, each 
pesticide product must be registered by the California Department of Agricul- 



3238 

ture before being offered for sale in the State. The label is carefully scruti- 
nized to be certain that there are adequate directions for use and any 
necessary precautions. It is illegal to use a pesticide for a purpose not speci- 
fied on the label. All of the commercial pest control operators that apply pesti- 
cides for hire in asriculturt- are required to he licensed, and each pilot that 
applies the materials by the use of aircraft must pass a special examination 
covering his knowledge of the nature and effect of the materials being applied. 

Regulation is carried on at the county level in California, as there is a 
County Agricultural Commissioner who enforces i)esticide laws and other agri- 
cultural laws in each county. The County Agricultural Commissioner's regula- 
tions require each pest control operator monthly to file a statement showing all 
the work done in the county. These reports are reviewed to be certain that 
there is compliance with the requirements of laws. 

Certain materials through the years have proved to be troublesome either 
from the standpoint of presenting danger to those that are handling or apply- 
ing the materials, or because they may cause illegal residues through drift to 
neighboring crops. These materials have been classified under California law 
as injurious materials or injurious herbicides. There are 35 such materials so 
listed, and each can only be used under a permit from the County Agricultural 
Commissioner. This applies to individual farmers applying their own material 
as well as to the commercial pest control operators. 

Finally, there is an extensive sampling and analysis program covering Cali- 
fornia fruits and vegetables and other produce offered for sale to be certain 
that any residues that may remain are below the accepted federal and state 
legal tolerances. These tolerances or permissible limits are established on the 
basis of safety to people consuming the produce as well as not greater than 
the amount that may be likely to remain as the result of good agricultural 
pest control work. In other words, even though a larger amount might be safe, 
if a smaller amount is the limit that is needed to control the iiest, then the 
smaller amount is the limit that is permitted. 

There has been a good deal of speculation throughout the United States and 
the world with regard to the place of DDT insofar as injury to people, ani- 
mals, crops, and the total environment. Our experience has lieen that DDT is 
one of the least hazardous materials from the standpoint of handling by man. 
We have had broad experience through the years, and do not know of anyone 
in California having been poisoned from the use of DDT. There have been 
cases where children have swallowed products containing DDT in petroleum 
oil Itases or other solvents, wherein the amount of solvent would be fatal 
whether there was any DDT in it or not. DDT is not readily absorbed through 
the skin, so from the standpoint of those applying the material and those 
working in areas where it has been applied it is regarded as one of the safer 
materials. The amount that is applied to grapes is rather small as compared to 
the acreages of grapes that are grown. Many of the farm laborers that work 
in the Delano area or throughout the southern San Joaquin Valley are local 
people and not migratory labor as we understand the term. ]Many of the.se peo- 
ple have lived in the area for years and are familiar with many of the pesti- 
cides used. We liave not received reiiorts of injury to them from use of DDT. 
There have been studies made of DDT exposure of workers in chemical manu- 
facturing plants where they received exposure many many times that would be 
possible under agricultural operations, and these studies have indicated that 
currently man is exceedingly resistant to DDT poisoning. 

In order to provide further details we are attaching a reprint from "Residue 
Reviews", Volume 6, which describes the California pesticide regulatory program 
in greater detail. 



3239 



The Insecticide Crisis 

Robert van den Bosch 

Departnrent of Entomology & Parasitology 

University of California, Berkeley 

A crisis in chemical pest control is acknowledged by some and denied 
by others. But, proliferating pest problems, sharply rising pest control 
costs, increasing environmental pollution and burgeoning pesticide re- 
lated legal entanglements leave little doubt that there is a problem. 

In the following statement the several factors that have contributed 
to this crisis will be discussed, and policies and practices that might 
bring relief, offered. 

The Bases of the Problem 

The underlying cause of today's insecticide dilemma lies in the lack 
of ecological consideration given the synthesis, experimental development, 
registration and utilization of the new synthetic materials. 

The organic insecticide revolution began in the 1940''s with the dis- 
covery of the insecticidal property of DDT. Prior to that time the in- 
secticide spectrum consisted of a few heavy metal compounds, some botani- 
cally derived products, certain petroleum fractions, sulfur, and sundry 
other materials . 

These pesticides were not very effective, but neither were they 
particularly disruptive to the environment. Consequently, at the time of 
dot's advent most persons concerned with pest control were totally unaware 
of the disruptive potential of the synthetic materials. And so, the new 



36-513 O - 70 - pt. 6A - 16 



3240 



insecticides were released into the environment literally without mis- 
givings, and they effected such spectacular control of age old pests, that 
all but a few persons were oblivious to the ecological fire they had 
kindled. 

The problems associated with the synthetic Insecticides appeared 
simultaneously with the introduction of DDT. Some very perceptive persons 
foresaw their occurrence and called attention to them as they developed. 
But in the early flush of excitement over the new materials these warnings 
were largely ignored. Indeed, very little was done until the early 1960*3 
when Rachel Carson shocked the world with Silent Spring, and forced serious 
attention to be given the hazards posed by the materials. And even then, 
attention was as often focused on the symptoms as on the root causes of 
the problem. 

The basic flaw in the modern synthetic insecticides is their ecologi- 
cal crudeness. This largely stems from the fact that the materials have 
been synthesized by chemists at the behest of chemical company managerial 
and sales executives. These are people With little or no knowledge of 
ecological principles; they know how to s}rnthesize toxic chemicals and 
how to merchandise them, but they haVe no real appreciation of their eco- 
logical impact. Thus, toxicological and marketing considerations have 
been the fundamental criteria applied to the developmeht of the modern 
insecticides. As a result « the materials have had devastating ecological 
impact, and they have created staggering environmental problems. ■ 

For example, the entire biosphere has become contaminated with DDT. 
Pelagic fishes, Antarctic penguins and boreal frogs contain the material. 
The water of many lakes and even the Baltic Sea are so polluted with DDT 



I 



J 



3241 



that some fish cannot reproduce and others are unfit for human consump- 
tion. Our own bodies have accumulated the material and nursing mothers 
pass it on to their babies. DDT degrades so slowly that each year an in- 
creasing amount accumulates in the biosphere, despite breakdown. 

This is cause enough for concern, but it hardly reflects the full 
magnitude of the insecticide problem. In fact, there is reason to believe 
that the organochlorines have passed their zenith, since legal restrictions 
on their use and public pressures against them are forcing their replace- 
ment by more ephemeral materials. But in a number of ways the replacement 
materials pose greater problems than those created by the organo- 
chlorines . 

Many of the DDT substitutes are organophosphates which are extremely 
toxic to mammals and a broad spectrum of lower animals, including insects. 
A disturbing use pattern is beginning to characterize the organophosphates: 
they are being used redundantly and their use is actually aggravating pest 
problems. There are 3 basic reasons for this: (1) the materials are 
characteristically short lived, and must often be used repeatedly against 
given pest infestations, (2) their severe impact on insect natural enemies, 
and the resultant elimination of these forms from treated areas, frequent- 
ly permits rapid resurgence of the target pests and outbreaks of previous- 
ly inocuous species, (3) the wide scale and repetitious use of the materials 
has hastened genetic selection for pest resistance to the pesticides. 

These 3 factors and the essentially unilateral way in which the mate- 
rials are used have contributed to an expanding pesticide treadmill world- 
wide. This in turn is reflected in a proliferation of pest problems, in- 
creased hazards to humans and lower animals and finally a tremendous 



I 



3242 



increase In the cost of pest control. 

In essence, a situation has developed in chemical pest control that 
is bordering on the chaotic, and it has been largely brought about by the 
very materials that were developed to give efficient pest control. 

Shortcomings in the Development , Registration 
and Utilization of Insecticides 

It is quite apparent that the inherent ecological shortcomings of the 
modern synthetic insecticides have increasingly contributed to environ- 
mental disruption and to pollution. This in itself is serious, but the " 
problem goes far beyond the simple ecological crudeness of the materials, 
for ecology is also largely ignored in their experimental development, 
registration, and exploitation. «■ 

Spokesmen for the insecticide industry have frankly stated that, for 
economic reasons, the industry is not interested in ecologically selective 
materials. Literally all of the companies are seeking another DDT or 
Parathion; a product that will have wide potential use so that it can cap- 
ture the broadest possible market and thereby recoup development costs and 
insure a profit. To them, the ideal material is one which can be regis- 
tered and labeled for use against a very broad spectrum of pests on a 
variety of crops. But, it is precisely this type of toxicity spectrUm 
that dooms a material to be ecologically disruptive. 

Experimental screening of newly developed insecticides by chemical 
company entomologists and many federal and state researchers is simply 
concerned with the determination of the killing efficiencies of the mate- 
rials and the acquisition of residue data. Essentially nothing is 



3243 



determined of the ecological impact of the insecticides, because such data 
are not pertinent to federal registration and the ultimate labeling of the 
materials . 

In essence federal registration of a new insecticide involves 2 cri- 
teria; (1) the demonstration of reasonable killing efficacy against given 
pests on given crops and (2) evidence that the material can be used in such 
a way as to meet established residue standards and pose minimum hazard to 
warm blooded animals. 

These criteria are grossly inadequate. For one thing, performance 
data usually only indicate that a material will kill substantial percent- 
ages of given insects. They do not show that such kills may not be eco- 
nomically feasible, or that the very use of a material may engender prob- 
lems of greater severity than those against which it is directed. 

In effect, then, federal registration requires no testing of the im- 
pact of insecticides on the insect communities to which they are applied. 
Consequently, there is no statement on an insecticide label to indicate 
that because of ecological impact, the material can lead to pest resistance, 
pest resurgence or secondary pest outbreaks. The user in reading an in- 
secticide label has no way of knowing that the material he is about to ap- 
ply, in addition to killing the pest of concern may, in fact, aggravate 
that very problem and engender others. Each year countless insecticide 
users Suffer serious economic losses because of this, and there is no way 
for them to redress these losses through lawsuit, because the defendant 
chemical companies can (and do) maintain that an infestation occurring sub- 
sequent to the use of a pesticide may simply be an "act of God." In other 
words, the federally approved label exposes the insecticide user to eco- 



3244 



nomlc loss while simultaneously protecting the manufacturer and seller 
from accountability. This is all well and good insofar as the chemical 
companies are concerned, but It leaves the insecticide user open to irre- 
trievable economic loss. Quite clearly, the latter should know the eco- 
logical risks he takes in using a broad spectrum insecticide, and these 
risks should be stated on the label. 

Shortcomings in the System of Pesticide 
Recommendation and Use 

Thus far, the discussion has dealt only with the shortcomings in 
insecticide synthesis, experimental development and registration, and their 
effects on the Insecticide problem. Nevertheless, it is apparent that even 
before a material is brought into use, it may have characteristics that 
doom It to be a pollutant and a hazard to man and other life forms. This 
in itself is cause for concern, but the system under which insecticides are 
reconmiended and dispensed is even more disturbing. 

Under the prevailing system, pest control advisement and pesticide 
use are substantially matters of metchandising . The insecticide manufac- 
turers and the agro-service companies, through intensive advertising and 
the aggressive activities of their sales personnel, dominate pest control. 
The salesman is the key to the system, for he serves as diagnostician, 
therapist, and pill dispenser. And what is particularly <lintMtb<ng <f> fh)*f. 
he need not demonstrate technical competence to perform in this multiple 
capacity. 

In other words, the man who analyses pest problems, recommends the 
chemicals to be used and effects their sales is neither required by law 
to demonstrate (by examination) his professional qualifications (as do 



3245 



medical doctors, dentists, lawyers, veterinarians, barbers, beauticians, 
realtors, etc.) nor is he licensed. Yet this person often deals with 
extremely complex ecological problems and utilizes some of the most 
hazardous and ecologically disruptive chemicals devised by science. 

For example, today in California, where roughly 1/3 of the nation's 
insecticide use occurs, there is no official roster of pest control ad- 
visers and pesticide salesmen. A man can move into a county to make pest 
control recommendations and sell insecticides without the Agricultural 
Commissioner even knowing that he is there. Because of this, illicit 
recommendations can be made and unregistered products sold, without the 
perpetrators being identified or called to account. 

The chemical industry has made some effort to upgrade the quality 
of its field personnel but this is really only a gesture, because the 
men remain salesmen, and merchandising is their real charge. In fact, 
the very system forces aggressive salesmanship first, because of the 
great number of companies (at least 100 in California) competing for the 
market and second, because of the variety of incentives (e.g. conmiGsion^, 
bonuses, profit sharing) utilized by the companies to encourage their 
field men to make sales. 

A particularly disturbing practice is that utilized by some of the 
larger basic manufacturers who market their own materials. These com- 
panies encourage their salesmen to recommend the "captive" company in- 
secticides even in situations where they are not especially effective. 
A frequent tactic is to mix the "captive" material with a more effective 
or appropriate one and represent it as a sort of super nostrum. Any- 
thing to sell the company product'. Such practices will almost surely 
increase, for the basic manufacturers are absorbing more and more of the 



3246 



local agro-service companies and using them as outlets for the "captive" 
materials . 

Finally, even with the most conscientious salesman there is the 
long standing rationale which goes somewhat as follows: "I knew that 
field didn't require treatment, but if I hadn't sold the grower a spray 
job a rival salesman might have come along later in the day and talked 
him into treating. Why should I lose the sale?" 

All of this is perhaps shrewd merchandising or pure pragmatism, but 
it is also the antithesis of scientific pest control. 

Thoughts on Ways to Improve the Situation 

Chemical pesticides are indispensable to highly effective pest con- 
trol, and their importance will Increase as the booming human population 
creates a greater demand for food and fibre and protection from 
arthropod borne diseases and nuisance insects. But this goal will be in 
high jeopardy if we continue to use insecticides in an inefficient, disrup- 
tive and pollutlve manner. New policies of pesticide development and use 
must be devised and implemented if we are to avoid ecological disaster. 
The need for these innovations is urgent. Above all, it is absolutely 
necessary that there be a general realization that pest control is an eco- 
logical matter and that pesticides must be developed, registered and 
utilized in this context. 

Following are some thoughts on how this might be accomplished. 

1. There is a critical need for mora sophisticated (ecologically se- 
lective) pesticides which can be fitted into pest management systems. 
Selectivity must involve more than safety to man, domestic animals and 
wildlife. The selective materials must also have limited toxicity ranges 
within the Arthropoda (insects and insect like organisms) so as to pre- 



3247 



serve insect predators and parasites, pollinators (including honeybees), de- 
composers, aquatic insects (fish food), etc. 

Such materials will, for technological and economical reasons, be more 
costly than existing broad spectrum insecticides. But because of their 
very nature (ecological selectivity), they will be used less intensively, 
effect better control of target pests, cause essentially no secondary 
pest problems, and be less conducive to the development of resistance in 
the pest species. For these reasons they should be less costly to the user 
over the long run, and infinitely less hazardous to man and the general en- 
vironment . 

2. The developmental costs for the ecologically sophisticated mate- 
rials will unquestionably &e greater than those for the existing broad 
spectrum insecticides (approximately $4 million per material today). 
Furthermore, the market potential for a given selective insecticide will 
be considerably smaller than that for a new broad seectrum material. 

The chemical companies, as they have in the past, will surely balk at 
shouldering the full developmental costs of selective pesticides, and if 
certain adjustments are not made, will refuse to synthesize them. Because 
of this, the federal government may have to devise a system to underwrite 
the developmental costs of the ecologically sophisticated materials. It 
is envisaged that such support would largely be used for studies concerned 
with the analysis of the materials' health hazards and their impact on the 
environment . 

The funds need not be paid directly to the chemical companies, 
but instead used to support the critical developmental research by federal 
and experiment station researchers. 

3. Until such time as selective pesticides become generally available, 



3248 



broader ecological criteria must be applied to the registration of the 
wide spectrum insecticides. This applies to the registration of new mate- 
rials and the re-labeling of existing ones. It is only reasonable that 
the insecticide user have available to him (via the insecticide label) in- 
formation which describes the ecological shortcomings of the material he 
contemplates using. He should be warned that a material can do him harm 
as well as good. 

4. The professional qualifications of pest control advisers must be 
upgraded. In other words, a pest control technocracy is needed to imple- 
ment the increasingly complex integrated control programs which are al- 
ready being developed and which will certainly proliferate in the future. 

Basic professional qualifications for pest control advisers (including 
salesmen, so long as they act as advisers), should be established and de- 
termined by examination. These persons should be licensed and subject to 
a code of conduct just as are people in the other professions. 

The company affiliated salesman, with his built in conflict of interest 
and sales motivation, must be phased out of pest control advisement. 
Eventually, direct contact between the salesman and the lay user of in- 
secticides must be eliminated. Instead, just as in human medicine, the 
salesman should deal only with the pest control adviser (agro-technologist) . 
It is further envisaged that the user himself should be required to con- 
sult with a licensed agro-technologist (pest control adviser) on decisions 
involving use of insecticides. Many of today's insecticide abuses are 
committed by the user who applies the materials himself after obtaining 
thetn from a salesman or distributor. 

5. The integrated control concept must be fostered among pest control 
researchers, and research on pest management systems expanded as rapidly 



3249 



as possible. There is a critical need for information on pest economic 
thresholds, pest ecology and phenology and the nature of agro-ecosystems. 

Such studies will provide critical information which will permit 
better timing and placement of insecticidal treatments and lead to the 
development of alternative control measures. 

6. There is an urgent need to develop a training program for agro- 
technologists (pest control advisers). Ecologically oriented economic en- 
tomologists, versed in the principles of integrated control, are extreme- 
ly rare today and badly needed. The training of such persons will entail 
curriculum planning, staffing of faculties and the development of intern- 
ship programs. This implies a need for federal grants to support on-going 
costs of the programs and to provide fellowships for the students of agro- 
technology. The fellowships, in part, might well be in the form of re- 
search assistantships established from funds allocated to subsidize the de- 
velopment of ecolcgLcally selective pesticides. Other agencies such as 
N.I.H. and N.S.F. might also support the fellowship program and the 
development of curricula and facilities for the training of agro-technolo- 
gists . 



3250 

Vegetable Growers Association of Amesmca, 

Washington, B.C., August 4. 1969. 
Hon. Walter F. Mondale, 
Senate Office Building 
Washington, D.C. 

Dear Senator ^NIondale: In connection with your hearings as Chairman of the 
Subcommittee on Migratory Labor and your discussion of pesticides, will you 
kindly insert in the hearing record my testimony on pesticides presented be- 
fore an Assembly Committee meeting of the Wisconsin State Legislature. 
Thanking you, I am, 
Respectuflly yours, 

Charles ^l. Creuziger, 

President. 
Enclosure. 

Prepared Statement of Charles M. Creuziger, President, Vegetable 
Growers Association of Ame:rica, Sturte\'Ant, Wis. Before a Committep: of 
THE Wisconsin State Legislature 

Mr. Chairman, my name is Charles 'SI. Creuziger. I am a vegetable grower 
from Sturtevant, Wisconsin. In partnership with my sons, I own and operate a 
650 acre vegetable farm, growing cabbage, potatoes and onion sets. 

In addition to my vegetable growing activities here in AVisconsin, I am privi- 
leged to be President of the Vegetable Growers Association of xVnierica, a non- 
profit organization with membership today of approximately 20,000 members. 
The Vegetable Growers Association of America is the only national association 
of vegetable growers with membership in 30 states including Wisconsin. 

My past activities and as.sociation with farm interests and groups are as fol- 
lows : I served for five years as President of the Wiscon.^in I'otato Growers 
As.sociation : I served as President for two years of the Wisconsin Muck Farm- 
ers Association. I have also served five years as President of the Racine County 
Agricultural Society. 

My remarks this afternoon in opposition to Assembly Bill 163 are submitted 
for your consideration both as an individual Wisconsin farmer and as Presi- 
dent of the Vegetable Growers Association of America. 

Man's progi-ess from earliest times is marked by a multitide of developments 
for his benefit — yes, some even for his survival. Among such items are many 
types of machinery, medicines, and ix>sticides. Possibly none of these has been 
without risk to man. It's the benefit to risk ration that must determine 
whether the developments are to be accepted by man. 

DDT became well known in February, 1944 when the U.S. Army used it to 
halt an epidemic of typhus fever in Naples, Italy. DDT was dusted over inhab- 
itants to control body lice, which can carry the disease. 

By 1948, DDT had done so much for man to control in.sect vectors of dis- 
eases, such as those which spread malaria, typhus, and yellow fever that the 
Nobel prize in "Physiology or Medicine" was granted to Dr. Paul Mueller of 
Switzerland for discovering the insect-killing properties of this chemical. Addi- 
tionally at that time DDT was the number one residual control for several 
kinds of flies, most household insects, and some insects of field, vegetable and 
fruit crops. Yes, and those who had worked diligently during the period of 
World War II and thereafter to ease the world food shortage were happy to 
have DDT, the first modern insecticides. 

1. First, it is agreed that ani/thing with the potential hazard of a chemical 
pesticide, or even a human medicine, Khouhl he controlled. 

DDT has been jtrogressively controlled since its regulated u.se by the public 
began in the mid-1940's. As scientific studies have professed, additions to, and 
deletions of its u.ses have l)een granted. 

2. To ban anything which is a product of commerce, the concerned govern- 
mental regulatory agency or agencies must have sufl!icient proof of hazard, for 
example. The l)enefit to risk ratio is to be taken into consid(>ration, just as 
with human medicines, food additives, and automobiles, the latter of which 
kill many more people and wildlife than even the wildest emotionalist "sus- 
pects". Possibly everyone should put himself in the same position (momentar- 



3251 

ily) as an individual who has developed a product of commerce which has met 
all the regulatory requirements, but emotional outcries are made for the "gov- 
ernment to ban it without due process of investigation to determine the total 
good versus the total harm. Automolbiles and many human medicines could be 
banned today on similar emotional efforts only. 

Several federal agencies are charged with individual and cooperative respon- 
sibilities relative to chemical pesticides. Involved are such as the Department 
of Agriculture, Food and Drug Administration, Public Health Service Depart- 
ment of Interior, and Department of Defense. 

The Fish and Wildlife Service (of the Department of Interior) carries the 
major responsibility to advise on hazards to wildlife, the apparent major con- 
cern of those proposing the ban of DDT. If and when the Fish and Wildlife 
Service has ample evidence to support the governmental ban of DDT or any 
other pesticide, the Department of Agriculture could not afford to continue its 
label registration. In general, Wisconsin accepts by reference the regulations 
on pesticides as established by these federal agencies which act individually 
and collectively through governmental organization. 

Why, then, has not DDT been banned federally? Because there is not suffi- 
cient evidence to support the ban, even though the southerly areas of much 
higher DDT use than Wisconsin are also considered. 

3. Again, to control DDT or any other chemical pesticide is desirable — and 
it is progressively being done. At present there is no University of Wisconsin, 
College of Agricultural and Life Sciences recommendation for it in Dutch elm 
disease or mosquito conti'ol, two areas of major concern. Nor is there a recom- 
mendation for its u.se in the College's 1969 Insect Control special circular 113 
primarily on control of insects attacking crops and livestock. The pesticide la- 
beling section of the Wisconsin Department of Agriculture, under present law, 
has the authority to delete DDT label registrations which can be proven justi- 
fied, similar to the U.S. Department of Agriculture's authority at the federal 
level. Similarly, the Conservation Division of the Department of Natural Re- 
sources, under present htiv, has authority of issuing permits for DDT and five 
other chemical pesticide uses in forest and non-crop areas. The question arises 
as to whether we need legislation to ban DDT or to stress enforcement of ex- 
isting legislation and possibly strengthening any legislation which is deemed 
necessary to better control DDT. 

4. Banning DDT would impose distinct hardships on growers of carrots, let- 
tuce, celery and some fruits. In the case of carrots, DDT is considered a 
"must" for a profitable, marketable quality product. The aster leafhopper is 
the only known means of transmitting the yellows disease to carrots, lettuce 
and celery, and the purple disease to potatoes. DDT is the best and most eco- 
nomical control of this leafhopper by far. 

A recent federal deletion of toxaphene for control of cabbage worms has 
caused revival of a former DDT recommendation which was dropped in the 
1969 Special Circular 114 of the University of Wisconsin College of Agricul- 
tural and Life Sciences — dropped solely as a compromise. Thus the deleted 
parathion-DDT combination is now reinstated. This is an example of where 
there is a satisfactory substitute for DDT one day but not the next — if there 
had been a ban on DDT, no satisfactory recommendation would have been 
available for a very serious economic pest problem. A similar emergency is al- 
ready anticipated with lepidopterous larvae on potatoes — whereas the use of 
DDT would not be absolutely essential on potatoes at the present, it is ex- 
pected that with the use of the present DDT substitutes (systemics which fail 
to work on Lepidoptera) that within a year DDT will be necessary to prevent 
a rather disastrous attack on caterpillars on potatoes. Even if we do not use 
all of the materials in our arsenal, let us not cut our lines so thin with bans 
that we have no defense when a real emergency arises. 

For Pest Control Operators, who commercially control insect and other pests 
in and attacking buildings, DDT remains recognized as a very effective and 
safe material against several pests. Among others are powder post beetles, sil- 
verfish, ants, several "pantry pests", files, mosquitoes, bed bugs, fleas, and 
ticks. 

World and national traveling have presented real threats for people bringing 
home diseases which can be transmitted by our insects or ticks. Malaria, for 



32o2 

example, has been nearly eliminated from many sections of the world, due pri- 
marily to judicious use of DDT. It is such foreign use, primarily in human 
disease-control which accounts for the major production of DDT in the U.S.A. 

Encephalitis is a dread disease \vl)ich crops out in the U.S.A. periodically. 
When such occurs, the U.S. Public Health Service is usually called in for help 
— and their help includes advice to control the disease-transmitting mosquitoes 
— with DDT. One might conclude, without much emotion, that those who sup- 
port the outright ban on DDT could ethically be accused of indirect killing of 
humans who would succumb to the onslaught of encephalitis without the bene- 
fit of DDT to control the mosquito vectors. 

Lest we forget, DDT got the 1948 Nobel Prize in the "Physiology or Medi- 
cine" category (through the name of Dr. Paul Mueller of Switzerland) primar- 
ily for its miraculous control of an epidemic of typhus fever in Naples, Italy, 
in 1944 and subsequent victorious feat.s against the vectors of other diseases 
such as malaria and yellow fever. 

Let there be systematic, scientific investigation and regulatory action on pes- 
ticides. There are primarily the Federal Committee on Pest Control and expert 
committees of the National Academy of Sciences which screen research and 
survey reports to guide the U.S.A. in regulating pesticides. At State levels 
there are also regulatory agencies, expert committees, and educational and re- 
search agencies which may be guided by these national groups, adapting to 
State needs. Presently there is a "Committee on Persistent Pesticide Residues" 
consisting of fourteen scientists, appointed by the National Academy of Sci- 
ences : the Committee's forthcoming report should definitely guide both Federal 
and State Regulatory and educational agencies. It is doubtful if this expert 
Committee will recommend the "death" of Nobel Prize-Winning DDT or any 
other pesticide, unless there is much more critical information of hazard than 
has been published to date. 

Thank you. 

U.S. Department of Agriculture, 

Office of Information, 
Washington, D.C. July 2, 1969. 
Mr. Boren Chertkov, 
Subcommittee on Migratory Labor 
U.S. Senate, Washington, D.C. 

Dear Mr. Chertkov : In response to a request from Miss Marsha Carlin of 
your committee staff, we are enclosing for your information a copy of, "1968 
Abstracts: Report on Pesticides and Related Activities," issued by this Depart- 
ment in February of this year. Miss Carlin had asked for figures on the 
amount of money spent by this Department for pesticide safety education for 
the farmer, particularly the migratory laborer. You will find on page 44 of the 
"Abstracts" a table listing approximmately $4.7 million as the expenditure for 
"information, education, and coordination," during fiscal year 1968 and 1969 
and estimated for 1970. Of this amount, the Federal and State Extension Serv- 
ices had available (on a matching fund basis) $4.4 million in 1968 and 1969, 
and the Office of Information $58,000 and $76,000 respectively for pest control 
information and education, including pesticide safety (table 2, part A, page 
43). These are the agencies primarily responsible for pesticide safety education 
in this Department. 

No records are available on the specific audiences participating in our pesti- 
cide safety programs. Safety programs are basically designed for the pesticide 
user generally including the farmer and commercial applicator, farm supervi- 
sor and laborer. A few states such as Texas, Arizona, and California have on 
occasion conducted Spanish-language safety programs for farm workers, but 
this has not been on a continuing basis, as far as we know. 

Of the pesticide funds used by the Department's Office of Information, about 
one third to one half underwrites the cost of safety programs and materials 
.such as the continuing radio-television campaign to reduce pesticide accidents 
and safety cartoons for newspapers and magazines. This effort is aimed pri- 
marily at the housewife, gardener, and other small user of pesticides but also 
reaches the farmer and rancher. 

We will he pleased to provide you with any additional information or mate- 
rials you may need. 
Sincerely, 

Eugene M. Farkas, 
Special Reports Division. 



3253 




ABSTRACTS 



REPORT 
ON 

PESTICIDES 
AND RELATED 
ACTIVITIES 



1^^ 


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^^^^^1 


^^^^pcbnomk food and ^^H 


^Hk^^ ^n' 


M 


^For^^H 


^^^■Uf v>.«.>w.c...i£nf for fhe 


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^ 




^^^Bpod of tnan 


HbjI^ Momttatin 






1 


m/j 


1 







3254 



EXAMPLES OF PESTICIDE AND RELATED ACTIVITIES 



OF THE 



UNITED STATES DEPARTMENT OF AGRICULTURE 




l>Mf5ilii(Sai 




1/m P^ifc<;^a^ ^d 



FOLLOVS/ THE LABEL. 

U.S. DErAfllMEhT OF ACItlCULTUftE 



February 1969 



3255 



INTRODUCTION 



The pesticide and related activities of the Department of Agriculture 
continue to be directed toward the development and use of safer, more 
specific and more effective pest control measures. These activities 
involve Research . Education , Information , Regulation , Pest Control and 
Monitoring . 

Eleven USDA Services and Agencies are participating in a coordinated 
program. Within some Services a number of Divisions are engaged in 
several aspects of the program. The program is described under nine 
general targets. The nationwide effort is supplemented by programs in 
several foreign countries. 

The activities reported are representative of a total budget program for 
F.Y. 1968 of $132,123,000. The Department supports work done by public 
and private agencies through such mechanics as contracts and grants. 
Major grant funds are expended to State Agricultural Experiment Stations 
and Schools of Forestry through procedures authorized by the Hatch and 
Mclntire-Stennis Acts. 



36-513 O - 70 - pt. 6A - 17 



3256 



TARGETS OF USDA PROGRAM 



I. To gain knowledge of the taxonomy, biology, ecology, 
physiology, pathology, metabolism, and nutrition of 
pests and host plants and animals. 

II. To improve and develop means of controlling pests by 
nonpesticidal methods. 

III. To develop safer and more effective pesticide use patterns, 
formulations, and methods of application; and improved 
methods for detecting, measuring and eliminating or minimizing 
pesticide residues in plants, animals and their products, and 
In other parts of the environment. 

IV. To study the toxicity, pathology and metabolism of pesticides 
and investigate levels, effect, and fate of their residues in 
plants, animals and their products and in other parts of the 
environment. 

V. To study economic aspects of pest control; survey pesticide 
use; determine the supply and requirements for pesticides; 
end give assistance to control agencies and industry in 
emergencies, 

VI. To control pests and protect the environment during and 
after control operations. 

VII. To monitor the presence and distribution of pesticides in 

plants, animals, and their products, and in the environment. 

VIII. To' administer the regulatory statute--the Federal Insecticide, 
Fungicide and Rodenticide Act--to assure properly labeled 
pesticides, with guidelines for their safe and effective use, 
and to prevent the marketing of harmful, adulterated or mis- 
branded products. 

IX. To educate and inform the public about the importance of 

pesticides and pest control, and the need for safe and proper 
use of pesticides; maintain a Pesticides-Information Center; 
coordinate and review pesticide and pesticide-related activities 
of the U.S. Department of Agriculture and coordinate them v;ith 
other Federal, State, and private organizations. 



3257 



Table 1. PARTICIPATIKG USDA SERVICES AKD AGENCIES 









Activ 


ity 






Organizational Unit : 


R : 

e 
s 

e 
a 
r 
c 
h 


1 = 

u 

c 
a 
t 
i 



n 


I : 

n 

f 



r 
m 
a 
t 
i 
o 
n : 


R : 

e 

g 
u 
1 

a 
t 

i 



n 


C : 

o 
n 
t 

r 



1 


M : 
o 
n * 

i : 
t : 

O ; 

r . 
i ; 

n * 
8 ; 


Agricultural Research Service 














Agricultural Engineering Research 
Anitaal Disease and Parasite Research 


X : 
X : 












Animal Husbandry Research 


X : 












Animal Health 










X 




Crops Research 
Entornology Research 


X • 
X 












Human i;atrition Research 
Information 


X • 




X 








■ Market Quality Research 


X 












Pesticides Regulation 








X 






Plant Pest Control 










X 


X : 


Plant Quarantine 










X 




Soil and Water Conservation Research 


X 












Agricultural Stabilization and 














Conservation Servicj 


X 












Cooperative State Research Service 


X 












Forest Seri.-ice 














Forest Pest Control 










X 




Forest Protection Research 


: X 












Information and Education 




X 


X 








Timber Management Research 


: X 












Watershed, Recreation & Range Res. 


: X 












Federal Extension Service 




: X 










Economic Research Service 


: X 












Consumer and Marketing Service 














Livestock Slaughter Inspection 












: X : 


Processed Meat Inspection 












: X : 


Technical Services 












: X : 


National Agricultural Library 

Office of Information 

Office of the General Counsel 




: X 


: X 


: X 






Research Program Development 
and Evaluation Staff 


: X 













3258 



COORDINATION OF DEPARTMENTAL AND INTERDEPARTMENTAL 
ACTIVITIES RELATED TO PESTS AND THEIR CONTROL 



Current Activities ; The Department engages In extensive research, regulation, 
control, monitoring, education, and information programs related to pests 
and their control. Associated with these programs are numerous departmental, 
interdepartmental, USDA-State and international coordination, planning and 
communication activities. 

General interdepartmental coordination and planning is accomplished through 
participation in the Federal Committee on Pest Control (FCPC) and its several 
subcommittees and the Federal Weed Control Committee. These are supplemented 
by participation in Federal Council for Science and Technology Subcommittees 
on Environmental Quality and Water Resources. 

i 

Cooperation with States is affected through exchanges between Department 
research and extension leaders and their counterparts at agricultural experi- 
ment stations or cooperative extension services and between Department 
control and regulatory units and departments of State governments or the 
Council of State Governments. Department scientists and research leaders 
have represented the United States in several meetings with representatives 
of foreign governments. . 

The several approaches to coordination and planning involve task forces, 
committees, work groups and scientist to scientist relationships. Technical 
competence and leadership of this and other Federal departments. States, 
industry and foreign governnents are utilized. 

Selected Examples of Recent Activities and Progress ; 

I. The Department continues to participate in and contribute technical 
competence and services to the parent Interagency Federal Committee 
on Pest Control and its five subcommittees on research, monitoring, 
information, program review, and safety. Some highlights involving 
USDA participation are: 

a. Fiaal preparation for publication of a report outlining and 
summarizing Federally financed research on pest control. 

b. Final preparation for publication of a report on Federal pesticide 
monitoring activities. 

c. Review of Federal financed pest control programs for efficacy and 
safety and the development of suggested changes where needed. 

d. Identification and evaluation of Federal pest control information 
programs. 

1 
i 

e. The development of a review and evaluation mechanism for considering 

pesticide safety problems. This Department was instrumental in the 

establishment of a new FCPC Subcommittee on Safety and Pesticide 
Disposal. 



3259 



The Department of Agriculture is dedicated to assuring an adequate 
supply of wholesome food and fiber and to managing the environment for 
the long range good of man. 

To insure communication, review and planning relating to its programs 
in these areas, the Department continues to have an active Pesticide 
Committee. It is composed of representatives of the agencies within 
the Department that are concerned with research, education, information, 
regulation, control and monitoring programs. 

In addition the Department, in 1968, established a Food Safety Work 
Group. Pesticide residues in foods and feeds are a part of the concern 
of this group. 

An Environmental Quality Executive Committee-Work Group, with Department- 
wide representation, continues to consider the role of pesticides in the 
environment .as a part of its activities. 

The Department continued to stress public information as a means for 
gaining understanding of USDA pest control policy and to further the 
safe use of pesticides. Numerous press releases and articles in the 
Agricultural Research magazine were published on pest research and 
control activities. Many of them were concerned with new, nonchemical 
methods. The TV-radio service of the Department was used to present 
different informational features to millions of people. In addition, 
the Department Office of Information and agency staff prepared and 
released many other printed and filmed materials dealing with the need 
for pesticides and requirements for their safe use. 

Experts and officials representing the United States of America and three 
European nations -- Belgium, the Federal Republic of Germany, and The 
Netherlands -- met in Bonn, Germany, December 18-20, I'^S?, to consider 
some significant aspects of agricultural chemicals, including their 
regulation and their possible impact upon consumer safety and the quality 
of the environment. The meeting was held at the initiative of the 
U.S. Department of Agriculture. 

Residue data provided both by the United States and the European nations 
were compared and evaluated. It became evident that residues generally 
appear to be within safe limits for all chemicals and for all foods as 
set up by the tolerances of the nations involved. 

The delegates met again in, Washington on March 26 to 29, 1968, to further 
explore these and other areas relating to the use of agricultural 
chemicals. 

Representatives of the United States, The Federal Republic of Gerrr.any, 
and The Netherlands have agreed that the generally low levels of pesticide 
residue found in food products need not impede the substantial flow of 
trade between their Nations. 



3260 



A. (Cont'd) 

After a detailed review of procedures for setting and enforcing safe 
residue levels, the delegates found that the systems used in the three 
participating Nations are essentially the same. 

The delegates agreed to free and continuous exchange of data on research 
and regulatory activities underway in their respective Nations. 

5. In connection with the 1967 meeting with Belgium, The Federal Republic 
of Germany and The Netherlands, the U.S. Government delegation prepared 
a comprehensive discussion of the regulation of pesticides in the 

United States. This document was prepared cooperatively by the Department 
of Health, Education, and Welfare-Food and Drug Administration and the 
Department of Agriculture. 

An outline of the procedures to be followed in the regulation of pesticides 
is presented. In addition, the detailed residue analytical data on approx- 
imately 45,000 samples of raw agricultural commodities confirm the safety 
of our food supply. 

6. The Departinents of Agriculture and Health, Education, and Welfare repre- 
sent the United States on the Codex Committee on Pesticide Residues of 
the Codex Alimentarius Commission. The third annual meeting of the 
Committee v;as held in Arnhem, Holland, in October. Progress was achieved 
in the furtherance of international pesticide residue tolerances. 



3261 



The following table shows the use of pesticide coordination funds for fiscal 
years 1968 and 1969: 

1968 1969 

Actual Estimate 

USDA pesticide safety campaign 
conducted by the Department and 
other public agencies and for 
coordinating Department pesticide 
information with other Federal 
agencies $58,038 $75,600 

Review and evaluation of the 
Department's cooperative pesticide 
and related activities research 
program and continued preparation 
of USDA progress report 15,000 

Maintain up-to-date information 
on all registered U.S. pesticide 
uses, including nonfood uses; 
publish and distribute an index 
of registered uses of fungicides 
and nematicides in the U.S A2,767 50,000 

Publish infomation developed by 
the FCPC monitoring subcommittee 
documenting all Federal pesticide 
monitoring programs 3,000 

Produce release prints of two TV 
features on pesticide monitoring 1,750 

Reproduce additional copies of 
"The Regulation of Pesticides in 
the United States." 1,000 

Conduct U.S. -European meeting in 
Washington, D.C., on pesticide 
tolerance levels 5,359 

Unobligated or unallotted balance 101,035 

Total $225,000 




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3266 

diyartment of health, education, and welfare, 

Public Health Service, 
Health Services and Mental Health Administration, 

July 25, 1969. 
To : Boren Chertkov. 

From : Cherry Y. Tsutsumida, Division of Health Care Services. 
Subject : Requested information on effects of pesticides on migrant worlvers. 

As per telephone request today, I am sending you some information which 
might be relevant. 

Please keep in mind that this information reflects only those incidents which 
have been reported to us. To our knowledge, there is no single source which 
can give you the kind of information which could be most useful to you. 

The Farinholt booklet, though dated, probably gives the best definition of the 
problem. It serves as a good outline for any inquiry into the problem. 
The other information is State reported incidents. 

Finally, we have included some general information on the health of the mi- 
grant in general. If we can be of any further help, please feel free to call 
557-6331. 

WORK ACCIDENTS 

Reports of occupational disease attributed to pesticides and other agricul- 
tural chemicals in California : 1964—1,328 ; 1965—1,340 ; 1966—1,347. Data un- 
doubtedly understate incidence because they do not include self-employed 
farmers and unpaid family labor. 

Farm laborers accounted for more than half of the 1,347 reports of occupa- 
tional disease attributed to farm chemicals. 

Injury rate in agriculture in California is still twice as high as rate for all 
industries taken together. Agricultural injuries represent almost 8% of all 
lost-time injuries but agricultural workers represent less than 4% of all em- 
ployess. 68.3 disabling injuries per 1,000 workers in 1965 compared to 65.6 in 
1966. 

In 1964 contact with insecticides, sprays, defoliants, and fumigants disabled 
183 farm workers ; in 1966 disabilities resulting from such contacts rose to 254 
although fewer persons were at work. 

County Farm Bureaus are encouraging improved follow-up on medical care 
for injured workers. 

In Florida, each year since 1956, pesticides have been responsible for 9-10% 
of all deaths due to poisons by solids, liquids, gases and vapors. Pesticides 
have been responsible for 49% of deaths due to poisoning among children. In 
Puerto Rico, pesticides are leading cause of fatal poisoning. 

Nationwide, Negroes were involved in about 18% of accidental poison 
deaths. Among the accidental deaths due to pesticides in Dade County, 72% in- 
volved Negroes. Nationwide, men represented about 62% of accidental poison 
deaths. Among accidental pesticide cases in Dade County 67% were men. 

Three groups make up large majority of fatal and nonfatal poisoning by pes- 
ticides : young children, young to middle age adult males who are occupation- 
ally poisoned, and middle age to older adults who suicidally inge.st pesticides 
(south Florida data). 

There is a nationwide need for more reliable data on poison mortality and 
morbidity. . . . 

On June 13, 1968, 23 cotton workers near Santa Rosa, Texas, were poisoned 
with the chemical parathion. 

Sources : California State Department of Health, Bu. of Occ. Health : Pesticide Poison- 
ing In South Florida, Arch Environ Health— vol. 17. Nov. 1968. Morbidity and Mortality 
Weekly Report, CDC (report of Texas State Dept. of Health, San Benito, Texas). 



I 



Memorandum 

Department of Health, Education, and Welfare, 

Public Health Service, 

April 3, 1969. 
To : Coordinator for Rural and Migrant Health. 
From : Paul Agnano. 
Subject : Health hazards in use of agricultural pesticides. 

A review of available reference materials on the subject confirms the pre- 
vious opinion that the State of California has done more work in this area 



3267 

than other agricultural States. The references requested by Boren Chertkov 
and transmitted March 13, 1967 are particularly pertinent to the question of 
magnitude and seriousness of the problem throughout the country. 

To up date and supplement our office reference materials, I have asked the 
Migrant Health Project Sanitarians in California, Colorado and Michigan to 
send us reports of studies or similar information bearing on the subject. 

On the Federal level, I have contacted Dr. Savage, of the Pesticide Unit of 
the Communicable Disease Center, Atlanta, Georgia who offered to make avail- 
able some preliminary morbidity data being tabulated from State sources. He 
is also forwarding .some reports of classical cases pesticide poisoning in Flor- 
ida and lower Texas. Dr. Savage suggests, however, that interpretation of the 
data should be qualified because the present reporting system and method of 
collecting data have been implemented only recently for cases beginning in 
1968. 

The Pesticide Unit of CDC is coordinating its activities with the Poison Cen- 
tral Program which operates through some 20 poison control centers dispersed 
throughout the country. The Director of the Poison Control Program is Mr. 
Henry Verhultz, located in Silver Springs, his telephone number is 495-5347, 

Summary 

The 1,347 reports of occupational disease attributed to pesticides and other 
agricultural chemicals received in 1966 compares with 1,340 in 1965 and 1,328 
in 1964. 

Occupational diseases are not included from among self-employed farmers 
and unpaid family labor, 28 percent of the agricultural work force, and from 
self-employed one-man operations in structural and agricultural pest control 
work. Data in this review, therefore, undoubtedly understate the incidence of 
occupational disease attributed to pesticides and other agricultural chemicals. 

The rate of occupational disease from agricultural chemicals in agricultural 
services (6.6 reports per 1,000 workers) was nearly twice that for workers in 
all agriculture (3.5 reports per 1,000 agricultural workers). 

Since 1951, there have been 32 occupational fatalities implicating agricul- 
tural chemicals. In this same period, 82 children and 22 other adults died in 
California from accidents attributed to pesticides and other agricultural chemi- 
cals, a total of 136 accidental deaths. 

Organic phosphate pesticides were implicated in 19 percent of the 1,347 re- 
ports in this series ; followed by herbicides, 11 percent ; fertilizers, 10 percent ; 
halogenated hydrocarbon pesticides, 7 percent ; and phenolic compounds, 7 per- 
cent. 

There were 233 reports of systemic poisonings in 1966. The organic phos- 
phate pesticides were blamed in 173 of these. 

Forty percent of workers with occupational disease attributed to agricultural 
chemicals were expected to lose some time from work. Ten percent of such 
workers were hospitalized. 

Farm laborers accounted for more than half (704) of the 1,347 reports of oc- 
cupational disease attributed to agricultural chemicals ; nonfarm laborers, 15 
percent ; and operatives, including truck and tractor drivers, 14 percent. 

Eighty percent of pest control chemicals moved beyond local areas are 
moved by truck. Qhemicals are usually transported in concentrated form, cre- 
ating potential health hazards in transportation and storage of pesticides in 
the event of mishap. 

Source : California State Department of Health Bureau of Occupational Health. 



Work Injuries in California Agriculture, 1966 

trend of work injuries 

The number of on-the-job injuries to agricultural workers continued to de- 
cline in 1966. California farmers and firms providing agricultural services re- 
corded 15,325 lost-time employee injuries, down from 15,843 in 1965 and 16,022 
in 1964. 



3268 

Agriculture was one of the three major industry divisions that registered a 
lower work injurj' rate in 1966 than in the previous year, and the rate on 
farms dropped more than in either construction or government, the other 
major industries with declining rates. The agricultural job injury rate fell by 
4 i)ercent — from 6S.3 disabling injuries per 1,000 workers in 1965 to 65.6 in 
1966. 

Although the injury rate reduction in recent years indicates progress, it is 
still twice as high as the rate for all industries taken together. Looked at an- 
other way, agricultural injuries represented almost 8 percent of all lost-time 
job injuries recorded in California during 1966, although less than 4 percent of 
all employees worked on farms. 

There has been an upward trend of injuries involving mechanical harvesters 
and pickers, reflecting the increased mechanization of the harvest. When farm 
machines are used in large numbers, the specter of serious injury is always 
present. The table below compares the trend of mechanical harvesting equip- 
ment injuries with all lost-time agricultural injuries during the past 10 years. 

Lost-time agricultural work injuries 



Year 

1956 

1957 

1958 

1959 

1960 

1961 

1962 

1963 

1964 

1965 

1966 .— -.- 

Percent change, 1956-66 8.1 43.9 

' Includes harvesters, combines, diggers and pickers. 

Statistics are not available on the number of farm employees working on or 
in proximity to harvesting equipment. It seems very likely, however, that the 
number has risen much more than the 44 percent rise over the past decade in 
accidents involving harvesting equipment. As one indication of this, the num- 
ber of tomato harvesters u.sed at the season's peak in California increased to 
609 in 1966 from 272 in 1965, according to agricultural exi>erts. Sixty-six per- 
cent of the acreage in tomatoes was machine harvested in 1966, up from 25 
percent in the previous year. 

What are some of the factors that have acted to reduce the number of work 
injuries on farms in general, and to limit the rise in the number of injuries 
involving crop harvesting equipment? 

As agricultural engineers and manufacturers have develoi)ed new equipment, 
efforts have been made to engineer safety into the design of machinery now 
cr)niing into wide use. Although more farm emi>loyees are now exposed to the 
hazards inherent in working on heavy machinery, it is easier to supervise 
them tlian to supervise a large crew of field hands during the peak of the har- 
vest. Adequate supervision can prevent accidents. 

Althougli it is somewhat early to tell, it a|>i)ears that the introduction of me- 
chanical itickers lias resulted in a reduction in the number of agricultural acci- 
dents involving strain or overexertion. In the past when large numbers of 





Involving 




harvesting 


Total 


machinery > 


16,672 


221 


16, 165 


231 


15,841 


243 


17,883 


214 


17,121 


219 


16,724 


237 


16, 104 


253 


16,474 


226 


16, 022 


255 


15, 843 


285 


15,325 


318 



3269 

Braceros were brought in to work in the fields, each year hundreds of farm 
hands suffered strain or overexertion in lifting containers or in stooping for 
long periods of time. The major push toward mechanization of the harvest has 
occurred since 1964 when accidents involving strain or overexertion disabled 
3,458 farm hands. By 1966, the number of lost-time injuries involving strain or 
overexertion declined to 3,060, a drop of 11% percent. In vegetable farming, 
where the introduction of harvesting equipment has been rapid, the number of 
injuries caused by strain or overexertion fell 43 percent in the two years be- 
tween 1964 and 1966. 

Another factor that has tended to reduce farm injuries in recent years has 
been the safety programs instituted to create greater awareness by farmers of 
the need to encourage safety among their workers in the face of contraction in 
the available agricultural work force. Several County Farm Bureaus have em- 
barked on programs encouraging members to provide improved "follow-up" on 
the medical care received by injured workers. Even with minor injuries, farm- 
ers have been urged to immediately arrange for the injured worker to be 
taken to the employer's own physician for treatment, instead of leaving to the 
worker the responsibility for seeing a physician. It is believed in many cases 
this has prevented minor injuries from later developing into disabling injuries. 

Environmental hazards on the farm continued as an area of concern in 1966. 
Increased mechanization of agriculture has been accompanied by increased uti- 
lization of toxic substances to control crop damage by pests. In 1964, contact 
witli insecticides, sprays, defoliants, and fumigants di.sabled 183 farm workers. 
In 1966, disabilities resulting from contact with such economic poisons had 
risen to 254 although fewer persons were at work. 

WORK FATALITIES 

On-the-job accidents claimed the lives of 88 California agricultural workers 
during 1966. Seventy-two of those killed worked on farms, and 16 worked for 
agricultural service establishments. In 1965 there were 73 agricultural deaths 
in California. 

Vehicle Accidents 

Accidents involving trucks, automobiles, or farm labor buses killed 3^ icork- 
ers. Twenty-one deaths occurred in truck accidents, eleven involved automo- 
biles, and two resulted from accidents involving buses transporting farm work- 
ers. 

Two fatal accidents illustrative of vehicular mishaps involving farm workers 
are described below : 

A farm laborer was hoeing weeds around a cook house near where a 2i/4-ton 
truck was parked, while the driver picked up lunches for the field workers. 
The laborer stepped behind the truck to sharpen his hoe. A high wind was 
blowing, and the laborer apparently did not hear the truck driver return to 
the truck and start it. The worker was knocked down by the backing vehicle 
and run over. He died two we^ks later after suffering severe crushing injuries. 

A cantaloupe picker stepped between the trailers of a large truck to get a 
drink of water from a can on the rear of the front trailer. The driver of the 
truck moved the vehicle forward without warning, and the picker was crushed 
to death under the wheels of the rear trailer. The drinking water should not 
have been placed where the workers had to walk between vehicles and could 
not be seen by the driver. 

Farm Tractor Accidents 

Seventeen workers were killed while oi>erating farm tractors. Most of the fa- 
talities could probably have been prevented if seat belts and roll bars or ade- 
quate canopies had been installwl on the tractors. 



3270 



Reprinted by the 

U. S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 

Public Health Service 

from the Journal of Occupational Medicine 

Vol. 8, No. 1, January 1966 



The Health of the Migrant Worker 



J. ROBERT LINDSAY, M.D., and HELEN L. JOHNSTON, Washington, D. C. 



A MIGRANT WORKER IS a pcrson engaged in 
agricultural pursuits whose work necessi- 
tates his traveling for a portion of the year be- 
yond normal commuting distance from his home. 
Thus he must set up temporary residence in 
other places for at least brief periods. Fre- 
quently other members of his family travel with 
him for all or part of each crop season. They 
may travel within a single state or move into 
or across several different states. 

Included in the group for which the migi'ant 
health program of the Public Health Service has 
concern are both intra- and interstate domestic 
migratory farm workers and their families; ex- 
cluded are foreign nationals imported under 
contract for temporary work in agriculture, and 
permanent community residents such as farm 
owners, fann family members, and year-round 
farm employees. 

The program for the importation of foreign 
workers under Public Law 78 was formally 
brought to a close in December 1964. As a re- 
sult, during the 1965 crop season, foreign migra- 
tory workers were being replaced by domestic 
farm workers drawn chiefly from Texas and the 
states of the Southeast and the Southwest. 

Work Force 

Many domestic migrant workers are "hired" 
through an "employment agency" system oper- 
ated by the Department of Labor in which the 
growers register their needs. The Department 
of Labor then tries to match the requests with 
available manpower, as determined by negotia- 
tions at home-base areas from which migrants 
normally come. In addition, however, sizeable 
numbers of domestic migrant workers are so- 
called "free wheelers" who simply take a chance 
on finding work on the basis of knowing a par- 



Dr. Lindsay is cliief, nnd Miss 
Mi(trant Healtli Branrli, Divisir 
.Services, U. S. Public Health 
Health, Education & Welfare. 



.Tohnston is deputy chief, 
n of Community Health 
Service, Department of 



ticular employer or having worked in a particu- 
lar area in previous years. The migrant farm 
work force that registers with the Department 
of Labor has been estimated variously at from 
less than 50 to about 90^ of the total force in 
different parts of the country. Exact work force 
figures are difficult to obtain because of the diffi- 
culty in getting accurate counts of "free-wheel- 
ers" or "walk-ins." 

The number of persons actually moving in 
the stream of farm migration probably approxi- 
mates % million or more each year. They are 
drawn from a labor pool in home-base counties 
and states which probably numbers 2 or 3 mil- 
lion persons. 

Agricultural migrant laborers find employ- 
ment at the peak of the crop season in about 48 
of the 50 states. Nearly 1000 of our 3000 coun- 
ties use 100 or more at the peak of a normal 
crop season. Michigan, Texas, California, New 
York, and Florida are among the states which 
head the list of those dependent on an outside 
supply of labor. 

However, the peak number of workers in a 
state or community is somewhat deceiving when 
one tries to equate this with the problems to a 
community in providing needed health services 
for the workers. A large community that is 
amply supplied with health resources and that 
has prepared to handle a large number of mi- 
grants may indeed be able to accommodate 
an influx of 10,000 workers and families. Con- 
trasted to this, as small a number as 300 mi- 
grants may pose a tremendous burden to a 
small community if its health resources are 
inadequate even for its permanent residents, 
and if no planning has been done in anticipation 
of the migrant influx. 

Some domestic farm workers who leave home 
for part of the year to harvest crops are able to 
find nonagricultural jobs when farm work is not 
available. Even when earnings from other oc- 
cupations are included, however, the total earn- 



3271 



ings of domestic agricultural workers average 
approximately $1,000 per year per worker, ac- 
cording to estimates made by the U. S. Depart- 
ment of Agriculture. The pay rate is usually 
established at the "going rate" for harvesting or 
other crop work to be done in the particular 
local work area. It is usually set- by local em- 
ployers before the season starts. 

In some instances, migrants prefer to spe- 
cialize in certain crops, not so much because 
they disdain working in others, but simply be- 
cause they gain experience and consequent su- 
perior skill in picking beans or tomatoes, for 
example, and in view of the typical piece-rate 
basis of payment, earn more money working at 
this crop. 

Women and children who migrate do re- 
munerative farm work to some extent. Because 
of the family's needs in order to survive, there 
is a real temptation to allow children to work in 
the fields instead of seeking out schools for them 
when the family arrives at a work location. The 
average annual income per family, including the 
earnings of the women and children, has been 
estimated at under $3,000. 

As is recognized, a sizeable portion of the 
American public moves intermittently for work 
in other kinds of industry such as building and 
highway construction. However, most of these 
workers are covered by minimum wage laws, 
have unemployment compensation to tide them 
over periods when no work is available, and 
have fringe benefits, including in many cases 
some type of health insurance protection. Agri- 
cultural workers in general lack these benefits. 
Those who migrate annually also lose local resi- 
dence status and, therefore, fail to qualify for 
the local services available to others in their 
income group. 

We have no way to compare the migrant 
agricultural worker's educational level directly 
with that of factory workers. We do, however, 
have some information regarding the agricul- 
tural worker's general level of education. Usual- 
ly his children are taken from school to make 
their trek northward before the school term has 
ended in the home-base area; they return to the 
home-base in the fall after school starts. Thus, 
they typically fall behind their peers in educa- 
tional accomplishments. The average educa- 
tional achievement of migrant adults is about 
the fifth grade. 

Health Service Barriers 

Language difiBculties are common. The larg- 
est number of migrant workers are Spanish- 



speaking. Many are unable to speak English and 
therefore have great difficulty in communicating 
with health workers, especially when they are 
in northern work areas in which few people 
speak Spanish. In addition, approximately 20,- 
000 Navahos and members of other Indian tribes 
enter the migrant work force during part of each 
year. These people frequently are also unable 
to communicate in English so that difficulties 
arise in obtaining services of any kind. 

In addition to linguistic problems, other cul- 
tural barriers interfere with the provision and 
use of health services, not only among the Span- 
ish-speaking Texan and the Indian but also 
among the southern Negroes, Puerto Ricans, 
and low-income Anglo-Americans. All of these 
groups may differ in some respects in health 
understanding and practices from the middle- 
class "Anglo" culture represented by the com- 
munity in which they may find themselves for 
part of the crop season. This may lead to a 
failure on the part of the predominantly Anglo- 
American health workers and communities to 
understand the health concepts of the migrant 
worker. On the other hand the migrant may 
frequently misunderstand modem scientific 
medical concepts. As a result, much of the ef- 
fort to improve the health of migrants needs to 
be funneled along educational channels focused 
on the workers and on their temporary com- 
munities. 

To help overcome workers' language and edu- 
cational deficiencies in making work arrange- 
ments, the system of crews and crew-leaders is 
in fairly common use on the East Coast but less 
so in other parts of the country. Under this or- 
ganizational pattern, one crew member— usually 
one who is fluent in English and has more edu- 
cation than the average worker— makes work 
appointments with growers in northern work 
areas (often through the Department of Labor's 
federal-state recruitment system), agreeing to 
supply a given number of workers at a given 
time and for a given period. This crew-leader 
then recruits the workers, usually in his home 
territory, and often provides them transporta- 
tion to the job, withholding a certain amount 
from each worker's pay to reimburse him for 
transportation or other costs. In some cases the 
reimbursement for various services rendered by 
the crew-leader may amount to a few cents for 
each unit of the crop picked, such as a bushel 
of potatoes or hamper of beans. 

There is often a fairly rapid turnover in crew 
membership, especially among persons not re- 
lated to the leader. The original crew may start 



36-513 O - 70 - pt. 6A - 18 



3272 



out from Florida, work in North Carolina, per- 
haps drop off a few members and add a few in 
North Carolina, and go on to work in Delaware 
or New York, again with some change in the 
composition of the crew at each stop. 

In addition to the change in the composition 
of the crew during migration in a particular 
crop year, there is also a change in the composi- 
tion of the migratory force itself from year to 
year. As some people settle and find other types 
of work, new people join the migrant stream 
because of their inability to find work in their 
home-base areas or because their own small 
farm no longer is able to compete in the agri- 
cultural market. Lacking skills or knowledge of 
other work, they tend to seek employment in 
agriculture. 

This seasonal and annual turnover in popula- 
tion poses obvious problems in trying to measure 
accomplishments in a health program. It is like 
trying to measure the achievements of health 
services set up to serve the members of a 
parade. Parade members in one city block might 
be fully immunized at one point in time but a 
few minutes or hours later, an attempt to evalu- 
ate the immunization effort in the same block 
might reveal a very low level of immunization. 
When the workers are on location they are 
usually housed in buildings provided either by 
the grower on his farm, by a farmer cooperative 
which provides housing for workers that may 
serve as a reservoir for several farm employers, 
or by a company which contracts for a crop. In 
addition, in some cases a local housing authority 
may make housing available. The charges for 
the housing vary from no charge— typical in 
cases where the housing is provided by the 
grower for his own workers but no others— to 
fairly standard rental charges. Usually, public- 
housing authorities charge rent. 

Of concern to many citizens, and of special 
concern to the migrant health program, is the 
fact that in many areas the housing provided 
lacks an adequate supply of water suitable for 
drinking and other household purposes. It is 
also frequently lacking in proper sanitation 
facilities. Even if the facilities are adequate and 
approved for a given number of people, the 
number actually occupying the housing during 
the crop season may far exceed the number for 
which the housing has been certified. Over- 
crowding increases the health needs of workers 
and families who may already have greater 
needs for health maintenance and health care 
than local commimity residents. 



Most migrant families make their own pro- 
visions for buying, preparing, cooking, and stor- 
ing the food that the family consumes. Cooking 
and food storage equipment is often provided 
by the family— frequently on a makeshift basis. 
In some cases, where male workers are not ac- 
companied by their families, growers may pro- 
vide a facility where workers may purchase or 
cook their meals. Food is sometimes taken to 
the fields, particularly the luncheon meal, either 
by each worker or family, or by a vendor who 
sells sandwiches and soft drinks. In many cases, 
no provision is made for proper food storage in 
the fields. 

The domestic migrant is in most cases an 
American citizen or eligible for citizenship. Ac- 
cordingly, he is free to come and go as he 
pleases. Many health departments offer screen- 
ing for venereal disease and tuberculosis for 
local migrant workers as a protection against 
spread of these diseases to the local community, 
but there are no requirements for either health 
examination or certification of freedom from 
disease in order to work in agriculture. 

Experience indicates that migrants generally 
have no greater incidence of venereal disease 
and tuberculosis than other similar low-income 
nonmigratory residents. The migrant family 
does suffer, however, from diseases such as 
diarrhea, respiratory infections ( including pneu- 
monia), skin diseases, frequent pregnancies and 
complications of pregnancies, muscular aches 
and pains, and accidents and trauma. In past 
years, most communities have been able to 
provide little if any treatment for these con- 
ditions. 

Most migrants, in leaving their homes to har- 
vest crops, lose their residency status so far as 
their eligibility for county hospital and local 
welfare services is concerned. Even when a 
community is willing to provide them with 
health care, frequently additional assistance 
and supplementation of the existing health re- 
sources are needed in order to provide for a 
migrant influx that may in some cases double 
the population of the community during the 
height of the harvest season. 

Migrant Health Act 

The Migrant Health Act of 1962 was designed 
to help communities make adjustments in com- 
munity health services in order to meet the 
health needs of migrant farmworkers and their 
families. Thus a setting would be provided in 
which migrants could be encouraged to take in- 



3273 



creasing responsibility for meeting their own 
health needs. 

The 1962 Act enabled the Public Health Serv- 
ice to make grants to public or voluntary non- 
profit groups to pay part of the cost of family 
health service clinics in providing general med- 
ical care on an outpatient basis to workers and 
other migrant family members. It also enabled 
payment of part of the cost of other types of 
project services to improve migrants' health 
conditions or services and further authorized 
expanded effort by the Public Health Service to 
develop and supplement state and local project 
effort. 

Up to July 1965, 63 migrant health projects 
had received grant assistance. These projects 
provided services in one or more counties of 32 
states and Puerto Rico. Most of the projects 
provide family clinic, public health nursing, 
health education, and sanitation services. Some 
add dental, nutrition, social work, and other 
related health services. 

About 15% of the projects are under voluntary 
group sponsorship. Most are sponsored by state 
or local public health agencies. Regardless of 
sponsorship, each of the projects involves many 
community groups which have a contribution 
to make to the improvement of migrant health 
conditions and services. Such groups include 
local physicians, growers, agricultural extension 
groups, church organizations, welfare agencies, 
educational institutions, and many others. On 



the average, about 40% of total project costs are 
met from other than grant sources. These other 
contributions are often in kind rather than in 
cash. They may be in donated facilities, equip- 
ment, supplies, transportation, services which in 
some cases include medical and nursing care, 
or other items needed for project operation. 

The law enacted in 1962 was for a 3-year 
period. An act providing a 3-year extension 
was recently passed by Congress and was signed 
by the President on Aug. 5, 1965. The extension 
expands the scope of the grant-assisted services 
to include in-hospital care in short-term general 
hospitals. The experience of project-sponsored 
clinics indicates that such an expansion is need- 
ed and will be welcomed by many project direc- 
tors. Much frustration has arisen from the fact 
that project staff members could take patients 
only as far as the hospital door and at that point 
had to "pass the hat" in order to get the bills 
paid so that patients could be admitted. 

There are also geographic areas where need 
exists but no projects have yet been developed. 
This lack and the continuing need for grant 
assistance in some of the areas now receiving 
migrant health grants indicate that program ex- 
tension and expansion are necessary if the ill- 
nesses and injuries of migrants are to be treated 
adequately whenever and wherever they occur 
and prevented to the fullest extent possible. 

Division of Communiti/ Health Services 

U.S. Public Health Service 

Wa.':hington, D.C. 20201 



3274 

March 13, 1969. 
Memoraxdim 

To : Boren Chertkov, staff, Senate Subcommittee on Migratory Labor, 

From : Ac-tin^ Coordinator for Migrant and Rural Health, Division of Health 

Care Services, CHS 
Subject : Data on work injuries or fatalities in agriculture from the use of toxic 
substances (insecticides, herbicides, and fungicides) 

Attached are data from several recent sources on poisoning cases resulting 
from work in agriculture. We may be able to find additional data if more are 
needed. Also attached is the report of the National Consumers Committee for 
Research and Pklucation, Inc. on "The New Masketl Man in Agriculture." [Editor's 
note : I'rinted in iu\rt6-B.] 

As you know at the time the Migrant Health Act was passed in 1962, Con- 
gressional documents stated that grant funds should be used to support health 
services for migrants, not to make studies or to conduct demonstrations. Ac- 
cordingly, the Migrant Health Program of the Public Health Service has not 
used migrant health grant funds for studies of work hazards affecting migra- 
tory workers or other studies. 

Using State funds, the California migrant health project has investigated 
the problem, at least in a limited way. We will try to get anything we can 
from them. 

Helen L. Johnston. 

1. U.S. 1965 — Accidental deaths on farms, by age, sex and accident type 
p. 8Q— Accident Facts, 1967 edition. 

All ages and all accidents — 2,321 ; poisoning only — 43. 
Age groups over 14 — all accidents — 1.845 ; poisoning only — 34. 
(Poisonings include deaths from poisoning by gases and vapors and deaths 
from poisoning by solids and liquids. ) 

2. Bureau of Occupational Health, California Department of Public Health, 
February 15, 1965 {California's Health, vol. 22. no. 16. February 15, 1965). 

The Bureau "conducts research in occupational diseases, including studies 
on the effects of agricultural pesticides on crop dusters, produce pickers 
and pesticide control operators. The risk of serious occupational illness 
among these groups is high. . . ." 

3. Work Injuries in California Agriculture (reports for 1955 and 1966 pub- 
lished by Department of Industrial Relations, California). 

Parathion and other organic phosphate insecticides — 53 (1955) ; organic 

phosphate insecticides — 77 (1966). 
Other insecticides, sprays, fumigants — 134 (1955) ; 177 (1966) 

4. Work Injuries in California Agriculture, 1966, p. 5. 

"Environmental hazards on the farm continued as an area of concern in 
1966. Increased mechanization of agriculture has been accompanied by 
increased utilization of toxic substances to control crop damage by pests. 
In 1964, contact with insecticides, sprays, defoliant.s, and fumigants dis- 
abled 183 farm workers. In 1966, disabilities resulting from contact with 
.such economic poisons had ri.sen to 254 although fewer persons were at 
work." 

5. Thomas Saunders, Chief, Division of Industrial Safety, Department of In- 
dustrial Relations, California (Hearings on Migratory Labor, 1964) 

"We recently investigated and analyzed 143 disablements involving the use 
of organic phosphates in a variety of agricultural uses, mostly in the 
Central Valley. We attempted to draw a picture of the typical person in- 
jured. This is what we found. 

"He was of Mexican descent, about 29 years old ; he did not speak or 
write English. He was poorly paid, generally poorly housed and clothed. 
He knew nothing about the hazards to which he was exposed and re- 
ceived only the barest instructions and supervision on the u.se of these 
materials. 

"Just ye.sterday on my de.sk was ... a report to the insurance company, 
the doctor's first report of a work injury. It says that the nature and 
extent of the injury was chemical poisoning with severe nausea, vomit- 
ing and diarrhea ; working in the grapes. 



3275 

"It said for the name of the employee : 'See attached list,' and the at- 
tached list of this one incident lists the names of 53 men who received 
this poisoning from agricultural chemicals." 
Recommendations (paraphrased from Mr. Saunders' statement) : 

(1) If the children or minors are to be permitted to engage in agricultural 

work, then the tyi>e of work which they are permitted to do must be 
severely limited. 

(2) If non-English-speaking workers are employed, then the type of work 

they are permitted to do must be limited ; in every case, supervision 
must be provided ; and that supervisor must be able to converse from 
English and the language of the worker. 

(3) Definite responsibility for adequate and competent supervision of the 

workers must be re<iuired and enforced. 

(4) The employer must be financially responsible in case of injury to an em- 

ployee or damage to property or bodily injury suffered by other parties. 

(5) The employer must be required to carry workmen's compensation and the 

claim of the injured worker must be promptly and equitably processed. 

(6) Standards of .safety for the machines, equipment and processes involved 

in today's agriculture as in other industries. 
6. Statement of Donald McLachlan, Michigan Association of Cherry Produ- 
cers (Hearings on Migratory Labor 1964) : 

"Health hazards are few in the orchards because the use of poisonous in- 
secticides is halted several weeks in advance of harvest to avoid residue 
problems and their toxicity is dissipated before the harvest starts." 



U.S. Department of Agriculture, 

Federal Extension Service, 
Washington, D.C. July 9, 1969. 
Mr. BoREN Chertkov 
Subcommittee on Migratory Labor, 
U.S. Senate, Washington, D.C. 

Dear Mr. Chertkov : Reference is made to a telephone call I received from 
Miss Marsha Carlin re pesticide safety education programs with migratory 
labor. 

Our Extension pesticide education program has generally been directed to 
producers, applicators, pest control operators, home gardners, fieldmen, techni- 
cians, chemical salesmen, dealers and professionals. Others are also welcome, 
although I am not aware of any concerted educational effort directed specifi- 
cally to migratory labor. Any information passed along to this group would 
normally be through their foreman or crew leader. 

I feel that much of the information developed for use with other audiences 
could also be adapted for use with migratory labor. Examples are included 
among the publications enclosed.^ Note especially the one-sheet items from 
Puerto Rico. 

If you have any additional questions, please give us a call. 
Sincerely, 

L. C. GiBBS, 

Coordinator, Agricultural Chemicals Program. 



UFWOC Pesticide Presentation by United Farm Workers Obganizing 
Committee, AFL-CIO 

DDT and many other pesticides are poisoning workers in the grape fields of 
California and grape consumers around the country and yet the grape growers 
and federal government will not sensibly limit use of pesticides until the pub- 
lic demands it. This is the message which Marion Moses, a Kegistered Nurse 
from Delano, California, and representative of the United Farm Workers Orga- 
nizing Committee, is carrying to 75 cities in the United States and Canada. 
She is meeting with churches, students, labor unions, and other interested or- 
ganizations and individuals, explaining the facts about effects of pesticides. 

1 [Editor's note : Printed in volume 6-B.] 



3276 

Many farm workers in Delano liave been injured or killed by breathing or 
touchinf; small amounts of such toxic poisons as I'arathion, Tepp, and other 
commonly used i>esticides. In some cases, only one drop on the skin of a 
worker can kill him in a few agonizing minutes. Research also shows that 
when grapes are bought by the consumer, they still carry dangerous amounts 
of many highly poisonous sprays which are impossible to wash off and are 
eaten witii the grapes and stored indefinitely in our bodies. 

Miss Moses cites abundant evidence that pesticides are not working any- 
more to control in.sects ; with in.sect pests bec(miing resistant and helpful in- 
sects being destroyed, more and stronger pesticides are applied in a desperate 
but futile effort by the growers to stop the pests. Meanwhile, scientists are find- 
ing that i)esticides are dangerous to man and the natural world in general. Va- 
rieties of cancer and other ailments of man can be traced to pesticides, and se- 
rious imbalances in nature are now known to be influenced or caused by these 
chemical poisons. Fish and wildlife are being wiped out in unprecedented num- 
bers, and several species have dwindled near extinction. 

Cesar Chavez. Director of United Farm Workers Organizing Committee, has 
been trying to negotiate with the growers to limit the kinds and amounts of 
pesticides used on the grapes and to get safe working conditions for the labor- 
ers who handle the pesticides, l)Ut the growers have repeatedly refused to bar- 
gain at all and have denied the Farm Workers Union access to public records 
of pesticides used on the grapes. Miss Moses reports that at present no one is 
stopping the growers from spreading dangerous pesticides in the fields and on 
the consumers table. The Food and Drug Administration says in its own re- 
port that it can't handle the problems involved with control of pesticides, and 
the Department of Agriculture also reports that they do not do independent 
analyses of pesticides and instead entrust our lives to the opinion of pesticide 
safety given to the I'SDA by the manufacturers. Almost no research is being 
done on the methods of biological control of pests, nor is much research being 
done on the health hazards of the many pesticides now being used. Yet great 
amounts of money are available to create more toxic insect killers and investi- 
gate better ways to promote and sell the poisons created. 

Miss Moses will go into detail on these issues, and will call upon public sup- 
port for actions to limit pesticides and to provide protection for workers and 
consumers. The Farm Workers T^nion believes that if the public becomes better 
informed about the widespread hazards of pesticides, pressures can be placed 
on the growers and government to stop the poisoning of workers and consum- 
ers and encourage negotiation of the issues. 

1. PESTICIDE FALLOUT 

Pesticides are found everywhere in our environment. Traces have been found 
in penguins in the Arctic Circle. The oceans are now polluted with pesticides. 
Pe.sticides are in the air, the snow, the.v come down with the rain. Pesticides 
appear in water and air miles from where the.v were originally used. Every 
living organism that has been tested for pesticides has been found to have 
some in their system. There is hardly a square foot of real estate on the en- 
tire planet earth that is not somehow contaminated with pesti<'ides. 

Before Rachel Carson wrote her book Silent Spring, most people felt that 
pesticides were a "good thing". DDT was a household word and great ad- 
vances in agriculture and public health were credited to pe.sticides. Rachel 
Carson called pesticides elixers of death and gave documented cases of the 
alarming and serious dangers of the use of ix'sticides. Many things she pre- 
dicted have come to pass and man is finally beginning to .see the terrible toll 
that the use of these poisons has taken on man and his environment. See ex- 
hibit 1. 

•2. BALA>X'E OV NATITRE 

In order to understand the problems that are presented l)y the use of pesti- 
cides we must first see that man is at the top of a complex system in nature 
that includes plants, animals, bacteria, air, water, .soil and all living things. 
This system of nature is called the ecosystem and a study of it and its rela- 
tionships is called ecology. Looking at the pesticide problem as it related to the 
total environment is called the ecological approach. This is the only valid ap- 
prf)ach to tlie pesticide i»rol)lem because it takes into account not only the pest 
that is being killed but also effects on air, water, soil, fish, birds, man and 
other factors involved in the control of pests. 



3277 




The agricultural and the chemical (pesticide) industry say that the balance 
of nature is a meaningless concept — that technology and man's ability to "con- 
trol" nature have destroyed the balance of nature and any return to it is not 
only impossible but undesirable. We say that it is man's failure to take nature 
into consideration — his attempts to "beat nature into submission" that have 
created the serious crisis from the uncontrolled use of pesticides. Exhibit 2 
(not available). 

3. NATURE UNBALANCED 

The average person is now aware that we are in the midst of an environ- 
mental crisis. Pollution of air and water is no longer a problem that can be 
dealt with later, but the average person is probably not aware of the relation- 
ship of pesticides to the pollution problem. Agriculture is one of the greatest 
polluters in the nation. Pesticides are a heavy contributer to air pollution and 
in agricultural states the run off of pesticides and fertilizer contribute to over 
40% of the water pollution. In California where the heaviest use of pesticides 
anywhere in North America occurs the ground water is contaminated with pes- 
ticides and the neighboring Pacific Ocean is now polluted. Most of the pesti- 
cides are sprayed by crop dusters (from the air). It is a very cheap method 
which is why it is used. But it is very costly in terms of its effects on non- 
target crops, animals, pests and people. 

Pesticides have resulted in three kinds of effects on living organisms. Muta- 
tions, sterility and death. Many have caused mutagenic changes, chromosomal 
changes, birth defects similar to those of Thalidomide. In fact many of the 
weed killers used have a chemical structure similar to Thalidomide. Birds 
have become sterile and their egg laying capacity greatly reduced because of 
the build up of pesticides in their bodies. The American Bald Eagle is practi- 
cally extinct because of the u.se of UDT and similar types of poisons. Pesti- 
cides have resulted in the deaths of millions upon millions of fish. A recent ep- 
isode you may be familiar with was the massive fish kill in the Rhine River 
due to pesticides. And in the early 60's we had 5 million fish in the Mississippi 
killed because of pesticides. See exhibit 3. 



3278 



NATURE UM^ALAHCED 



AlR\fOllimON 



WATEOPOUOTIOM 




56im^nET(0N 



DEATH 



4. CHLORINATED HYDROCARBONS 

The best known member of a class of poisons called chlorinated hydrocar- 
bons is DDT. But there are other members of this family that are equally as 
dangerous as DDT and some of them even more so. The chlorinated hydrocar- 
bons are not found in nature — they are chemical poi-sons invented by man. 
They are nerve toxins, that is, they exert their poisonous effects on the brain, 
spinal cord and nerves. This means that they will affect all body functions, 
eating, sleeping, reproduction, etc. No one knows exactly how DDT and the 
chlorinated hydrocarbons kill, but we know that they do. 

Dieldrin is a compound that is 50 times as toxic as DDT. It is closely re- 
lated to Aldrin, another of the highly toxic chlorinated hydrocarbons. Aldrin 
and Dieldrin are banned in Ontario, Canada. They were until very recently 
used by the Armed Forces to spray airports, in spite of the evidence of serious 
effects on wildlife and contamination of air and water for miles around. En- 
drin is a compound so toxic that its stay on the market was relatively short. 
Shell Oil Company, who manufactures Endrin. in attempting to keep the com- 
pound on the market used among other arguments in its favor that "it was 
only killing fish". Heptachlor was recently found in 120,000 turkeys which 
were therefore confiscated by FDA. Heptachlor breaks down into a compound 
called Hetachlor Expoxide which is even more dangerous than Heptachlor. 
Thiodan was responsible for the massive fish kill in the Rhine River recently. 
Two barrels of it that fell overboard 12 years ago finally eroded and leaked 
out causing death of the fish and contamination of the water supply for all 
the communities along the river. 

DDT has been banned in Arizona, "Wisconsin, Canada, Sweden and Germany. 
It's use has been restricted in the United States. We mustn't get too comforta- 
ble because DDT has been banned and think that the pesticide problem is 
.solved. H0% of the DDT manufactured in North America isn't used in the 
U.S. or Canada anyway. Most of it is shipped overseas. Yet compounds of the 
same family which are even more toxic are still being used. It is important 
that any ban on DDT also include the other "hard" pesticides which are as 
dangerous as DDT and possibly even more dangerous. It is also important to 
understand that partial bans on DDT are not effective. As long as DDT is 
being used anywhere in the world it is going to be found every where in the 
world. If Canada bans DDT and we still use it in the U.S. the wind will 
carry DDT into Canada. 

In California DDT was banned except for cotton and grapes. See exhibit 4. 



3279 




CHLORifi^'^^^ rtyORftC/lRSftilS 






tlNDANC 
ALDRm 



6HC 

CH10RDAM£ 

HEPTACMLOR 

KatHKHE 



5. PERSISTENCE 

This is probably the biggest problem presented by DDT and the chlorinated 
hydrocarbons. That is, they are persistent, they do not break down and can be 
found in the soil in the original form they were put there as long as 14 years 
after application. DDT probably has a half life of 14 years. This means that 
in 14 years half of the DDT applied will still be active and poisonous — 14 
years later half of that amount will still be active and poisonous — 14 years 
later half of that amount and so on until it is gone. Considering that DDT 
has been applied to the earth in millions of tons since 1942 we can see the 
problem. Some scientists say that if we stopped using all the chlorinated hy- 
drocarbons immediately that it would take at least 40 years before reasonably 
safe levels were found. Some scientists also say that it may already be too 
late — that there is already too much DDT, Dieldrin, Endrin, etc. in the ecosys- 
tem. The results are seen only in future generations and we may have already 
seriously affected the reproductive cycle irreversibly. See exhibit 5. 

0. now MUCH IS DDT? (BIO- ACCUMULATION) 

The most serious problem with the use of DDT and the chlorinated hydro- 
carbons is that we store them in our bodies. Fat people are storing more than 
skinny people because DDT is stored in the fatty tissue. The average Ameri- 
can is storing 10 to 12 parts per million (ppm) of DDT in their bodies. No one 
knows what the long term effects are. No one knows how DDT is broken 
down, or excreted in the human body. No one knows if there is a point where 
storage of the poison stops. We do know that sudden weight loss can cause 
symtoms of poisoning since the DDT goes directly into the blood stream when 
the body loses fat. This can be a very serious problem in babies and children 
who tend to lose weight very rapidly during illness. We also know that breast 
milk contains 414 times as much DDT as milk sold to the public. There is 
mounting evidence that DDT and other pesticides cross the placental barrier, 
that is, that when a women is pregnant DDD in her blood stream passes into 
the baby's blood stream. See exhibit 6. 



3280 



7. PESTICIDE DEATHS 

There are some studies that have been done which should alarm us about 
the build up of DDT in our bodies and also the fact that it lasts so long and 
can't be broken down. There have been two studies done which indicate haz- 
ards to human health. One study was done by the National Cancer Institute. 
In this study 130 pesticides were studied to see if they were carcinogenic, that 
is, to see if they could cause cancer. DDT was proved to be a carcinogenic in 
this study. There was another study done by Dr. Deichmann of the University 
of Miami under a Public Health Service grant. The study was done in the state 
of Maryland and it showed that people who died of cancer. Leukemia, and 
heart disease had 2^2 times as much DDT in their body tissues as people 
who died of natural causes. A study done by Dr. Mizrahi at Salud clinic on 
children from 1 to 16 years of age showed that over 40% had blood tests re- 
sult.s indicating poisoning with pesticides. 42% of the chilren showed levels of 
pesticides higher than that considered safe for the adult population. A recent 
survey done by the Public Health Department in California showed that 80% 
of the workers surveyed had one or more symptoms of pesticide poisoning. See 
exhibt 7. 



K?i5\5%\iCi 



\ 




crops — enrers Loa-ter^ soiL, 
^'^ and 0.11 \,\j^n^ 4hin^s 

(156 

pGisor? s^.l/ femomed.. 

1170 

(iS'i- 

Of-e^gM-^i oj- ^he, 'po/'sOM 



3281 



eVtJHT O B)g>T HftY? 

HAM HttCU \% MT? 




S. ORGANOPHOSPHATES 

There is another group of chemical poisons that are used to spray crops in 
California. Theses are the organo-phosphates or nerve gases. These compounds 
were invented by the Germans during the second world war for reasons we all 
know well. When describing the difference between this group of poisons and 
the DDT type we can make a distinction between slow and sudden death. The 
chlorinated hydrocarbons being the slow death and the organophosphates being 
the sudden death compounds. The most commonly used of the nerve gas type 
of chemicals is Parathion. Six drops of parathion on the skin is fatal. Another 
commonly used poison is TEPP. One drop of TEPP is fatal. These are the di- 
rect, instant killers. Farm workers die every year from these compounds. A lit- 
tle four year old who was following behind her parents while they applied 
TEPP with a ground rig apparatus, stuck her finger into the jug of TEPP and 
died twenty minutes later. Every year pilots who fly the crop dusters that 
spray the organo-phosphates are killed from the effects on their vision — last 
year 11 crashed into the ground and were killed. Because of the effects on vision 
many farm workers have been seriously injured or killed while operating farm 
machinery or merely driving home in their cars after work. In order to under- 
stand how the nerve gases kill we must first understand cholinesterase. See ex- 
hibit 8. 



3282 






ORGAN PHOJPHftTtS 

f/lRATHIOH f£PP\ 
HETHyt PARRTIOH MAtATHIOII 

MBRftM £tMON 
SYSTOX MERVE GNS 






I 


) 


1 


> 


.^ 



3283 

9. ORGANO-PHOSPHATE POISONING (CH0LINESTEBA8E) 

Cholinesterase is a substance that we all have in our bodies. It is an enzyme 
and it is absolutely essential that we have enough of it in our bodies for our 
nervous system to work properly. It is necessary for the proper functioning of 
the brain, spinal cord and nerves. If we think of electricity running through 
a wire and think of the nerve impulse running through our nerve fibers in the 
same way — then think of cholinesterase as a circuit breaker, it stops the im- 
pulse, pulls out the plug so to speak. It is necessary that nerve impulses do 
not charge constantly or the nervous system becomes overworked and over- 
loaded resulting in convulsions, coma and death. The nerve gas chemicals are 
the only compounds known which reduce the amount of cholinesterase in our 
bodies. In other words, the nerve gases kill by destroying cholinesterase. And 
when cholinesterase is destroyed we begin showing symptoms of dizziness, gid- 
diness, blurring of vision, nausea, vomiting, diarrhea and if nothing is done 
this will lead to convulsions, coma and death. The tragedy is that we knov^ 
these symptoms so well in the valley. Because so many have died and nothing 
has been done. 

Two cases will be read from an article written by Dr. Irma West of the Bu- 
reau of Occupation Health of the State of California Department of Public 
Health. 

Case 1. A 16 year old and a 21 year old were hired to apply a pesticide dust 
consisting of phosphate ester (another name for organo-phosphate) mixed with 
sulphur. The estimated adult fatal dose for this pesticide is five drops orally 
(eaten or ingested) and six drops dermally (absorbed through the skin). The 
workers used knapsack dusters, .starting work at 7:30 AM. At noon, the 21 
year old worker became ill and remained at the side of the field in his car and 
vomited. After a while he felt better and drove home. Fortunately he did not 
have an auto accident. Workers with phosphate ester poisoning are poor risks 
with any moving machinery. The 16 year old worked until 4 :00 PM when he 
vomited and went home. At 8 :00 PM he complained of weakness and giddiness 
and was taken to a physician's office. The boy's clothing was reported to have 
been covered with sulphur. The physician called the Poison Information Center 
for information about sulfur which is relatively non-toxic. The boy was sent 
home with a prescription. At 9 :30 PM the boy became worse and was taken to 
the local hospital. This time, the label from the pesticide container was 
brought with the patient. The boy was again sent home although he was una- 
ble to walk. At 7 :30 AM the boy was found moribund in his bed, still in his 
contaminated work clothing. He died in the ambulance en route to the hospi- 
tal. Death due to Phosphate ester poisoning was confirmed by post mortem 
cholinesterase tests. 

The 21 year old worker, although asymtomatic, reported the next day for a 
cholinesterase test which confirmed he had been poisoned by a phosphate ester 
chemical. He had not worked with phosphate ester pesticides before. The 16 
year old had applied the same pesticide on one occasion two months before. 

Case 2. Because of engine trouble, an agricultural aircraft pilot attempted a 
forced landing in an unplanted field. The plane rolled into a fence and turned 
over. The hopper of the airplance contained a dust formulation of TEPP, an- 
other of the phosphate ester pesticides. The estimated adult fatal dose for 
TEPP concentrate is one drop orally or dermally. The pilot was not injured 
but was covered with dust. He walked a distance of 50 feet to a field worker, 
stated he felt fine, and asked for a drink of water. After drinking the water, 
he began to vomit and almost immediately became unconscious. By the time 
the ambulance arrived, the pilot was dead and the ambulance driver, the path- 
ologist, and the mortician became ill from handling the body. 

It is important to understand that it is possible to be poisoned by the nerve 
gas compounds and not have any symptoms. Small amounts of exposure will 
reduce the cholinesterase a small amount. Repeated small exposures can accu- 
mulate and build up to the iwint where poisoning and death occur. When the 
cholinesterase level drops, depending on how low it has dropped, it takes a 
long time for it to come back up to normal. It can take as long as 2 or 3 
months. During this time the worker is vulnerable to even tiny amounts of ex- 
posure which can again throw hiin into the danger zone. See exhibit 9. 



BhSELMl 



3284 
CHOLIHESTERRSE 

LEVEL 



3^ 



DANGER 



^RGKHO PHOSPHATE FWIPWITI jj 

10. now PESTICIDES entb:r the body 

Pesticides enter the body in three ways. We breath them in, we eat them in 
our foods and they are absorbed through the skin. Most of the serious poison- 
ings among workers have been from absorption tlirough the skin. Workers 
have been seriously poisoned (and died) merely from picking fruit that had 
been sprayed weeks before. From your own experience you will see that there 
is no protection. Look at the aerosol bug and/or weed sprays that you may 
have around your home. Most of them are conveniently and attractively pack- 
aged. Some will even go so far as to state that they are non-toxic to humans 
and pets. But then read the small print. You will see lengthy instructions 
warning you not to breath the fumes, not to get it on your skin, not to spray 
around food, not to u.se in a closed area, to have adequate ventilation, etc., etc. 
Also it is almost impossible for the average consumer to know what he is buy- 
ing because the common nam(> (if any) is often not given. Aslo it is not stated 
on the label what the jioison is and bow dangerous it is. The Sliell i)est strips 
are a good example of this. They are packaged in gold foil and the average 
person doesn't know that the yellow waxy strip is a nerve gas and that the 
only "safe" way to u.se it is when the ventilation and .space is such that it 
wouldn't concentrate enough to do it's job of killing. So that the only way you 
can use it is to put it inside a room where the vapor is constantly emitted — 
getting on and in your food, your children in potentially dangerous amounts. 
See exhibit 10. 

11. RESIDUES 

The food that we eat is contaminated with i)esticides. All the dangerous 
compounds that we have been discussing are being used in the vineyards of 
California. We will speak here of grapes becau.se this is the crop we know the 
most about. And because they are one of the heaviest sprayed crops in Califor- 
nia. By the time the grapes get to market there are still pesticides "left over", 
that is, there is a residue left on them. And it is not only one or two, but 
many different pesticides that remain on them. You will perhaps be told that 
it really doesn't matter that the amounts are .so small and that "a little bit 
won't hurt you". There is no such thing as being a little bit poisoned. It has 
become well known and is an accepted fact that the most minute and tiny 



3285 



HOW PESTICIDES EMTER THE BODY 




COMTACT 

_ WITH SKIM 




BREKfHM6 I EKnN& 




amount of pesticides can be concentrated in animal tissues many thousand fold 
and that there is no predictable safe level. 

We must understand how tolerances are set in order to understand the mag- 
nitude of the problem of the poisons on our food. A tolerance is the amount of 
a pesticide residue that is allowed to be on food when it is sold to you. In 
other words it is not a question of "are we going to allow poison on grapes" 
but a question of "how much poison are we going to allow on grapes". In 
order to determine a tolerance, the pesticide in question is fed to a laboratory 
animal until the animal develops symptoms or a symptom. A no-effect level 
(which is the point before the animal developed the symptom) is then deter- 
mined. The amount of pesticide at this no-effect level is then divided by 100 
and this amount is considered safe for human consumption. 

By using such a method Thalidomide would pass hands down. And in fact 
the herbicides (2,4,D and others) have been used in fantastic quantities be- 
cause they were considered "safe" by the above standards. 

The danger of this approach to tolerances of course is that it measures 
acute toxicity only. It does not take into consideration the long term effects, 
the effects on the human embryo, the effects on children, infants, the sick, in 
other words it has nothing to do with people. Also it is ba.sed on the assump- 
tion that this is the only food that the pesticide will be ingested on. We get a 
little bit on a lot of foods and eat multiple fruits and vegetables every day — 
so there is no such thing as a safe level of these poisons. Nor does this ap- 
proach take into consideration the multitude of poisons that we are exposed 
to. For example a bunch of grapes that were tested in Cleveland had 9 differ- 
ent poisons on them. And we know that some compounds that are not as 
harmful alone can be lethal in combination with other pesticides, which may 
also not be considered harmful. See exhibit 11. 

12. EL PATRONCITO Y DON SOTACO 

We see then that "a little bit won't hurt you" completely evades and avoids 
the real problem which is the uncontrolled and increasing use of more and 
more toxic chemicals in more and more toxic combinations. Even if we as- 



3286 



RESIDUE 









ENM|»r 

KELTHAME o^^ 




sumed for the sake of argument tluit a "little bit" of Parathion won't hurt 
you, what about a little bit of Sevin, and a little bit of Parathion, and a little 
bit of DDT, and a little bit of TEPP and a little bit of Dieldrin, etc. We know 
that these pesticides are harmful because we see evidence of it every day in 
the farm workers seen at our clinic in Delano. We see very severe skin dis- 
eases that do not respond to treatment— the dermatitis gets worse and worse 
until the skin cracks and a secondary infection sets in. Many times the work- 
ers are left with scarring before the condition clears up. We see many workers 
with visual disturbances, blurring of vision, double vision, just not being able 
to see right. We see very severe cases of asthma in childrin and adults, re- 
lated to the spraying season. We have workers become ill because they are 
sprayed while they are still in the fields. Workers are poisoned because they 
are sent in to pick crops while dangerous levels of pesticides are on the vines. 
When the crop is ripe, or the market is ready, the health of the worker is the 
last consideration. Workers are sent in to pick and if they become ill they can 
either quit or put up with it. Farm workers are the guinea pigs. See exhibit 
12. 



3287 




13. PESTICIDE RESEARCH 

These lovely ladies are deciding what the "safe" level of poisonous pesticides 
will be this year. The Food and Drug Administration is responsible for seeing 
that we have a safe food supply. The Department of Agriculture is responsible 
for the regulation of pesticides. The University of California (you may substi- 
tute your favorite land grant college) does a large amount of the agricultural 
research on pesticides and makes recommendations to the growers. 

How safe are your foods? How good a job does the FDA do of protecting 
youV The FDA can speak for itself. An article in the July 1969 San Francisco 
Chronicle stated the following : 

A confidential report by seven senior Food and Drug Administration of- 
ficials concluded that the Federal government does a completely inade- 
(luate job of i>rotecting Americans from dangerous drugs, tainted food and 
household products that can kill or harm them. 

The report . . . said that the FDA has neither the money, manpower, or 
legal authority to do the job effectively. 
The FDA has a very poor record of protecting the American consumer. They 
have shown themselves to be much more responsive to industry pressures than 
the public health. The recent whitewash done on Aldrin in grapes is just an- 
other example among many. 



36-51.3 O— 70— pt. 6A- 



-19 



3288 

How do pesticides get ou tlie market in tlie first place? What are the con- 
trols to see that the pesticide manufacturer is checked. An article that ap- 
peared in the Washington Post on May 5, 1969 stated : 

The top pesticide oflScial of the U.S. Agriculture Department has 
reported his agency registers pesticides mostly on the data supplied by 
chemical manufacturers. Harry W. Hays, director of the Pesticides Regis- 
tration Division said his department does not "analytically" check pesti- 
cides information partly because of the high cost of such a screening proc- 
ess. 
The Department of Agriculture is the least progressive department in our 
federal government. The committees in both the house and the senate are dom- 
inated by the "confederate generals". Agriculture has one of the strongest lob- 
bys in Washington. And the pesticide industry is an agriculture allied indus- 
try. So the situation in registering and controlling pesticides is put in the 
hands of the group that derives the profit from their u.se. This is open to ob- 
vious abuse and is a large part of the reason why the use of pesticides is out 
of control. The U.S. Department of Agriculture spends over $180 million on 
pesticide related research. USDA spends less than $160 thousand on pesticide 
safety. 

The fact that no research in the U.S. is currently conducted into the occupa- 
tional health hazards of agricultural chemicals is indicative of the lack of con- 
cern in regulatory agencies for workers interests. 

Almost all of the research that is being done is chemical research. And al- 
most all of the research is done by the pesticide industry and/or the 
government. Tax payers money is used by the Department of Agriculture to do 
the initial work on development of new pesticides and then when it looks mar- 
ketable it is turned over to the chemical company. Much of the research 
money is of course channeled into university projects. And the scientists who 
work on the projects know where the money is coming from. It is remarkable 
to note the pronouncements coming from governments witnesses at pesticide 
hearings on the safety of pesticides. In fact this is a large part of the problem 
— the evading of the issue by government agencies and their manipulation of 
scientists. It is very difficult for a scientist who wants to research alternatives 
to pesticides to find money for his projects. But if he wants to research a new 
and more lethal chemical poison he will have no difficulty in finding funds. 
And the research that is done is on how many bugs it kills and how dead it 
kills them. DDT's effect on human health was not tested until it had been on 
the market for 13 years. See exhibit 13. 

14. RESISTAJfCE 

The irony of the pesticide situation is that they are not working anymore. 
The bugs are developing resistance. When insects are sprayed with pesticides 
most of them are killed, but not all. The few that survive are resistant and 
they breed a generation that is also resistant to the amount they were sprayed 
with. In order to kill the new generation there are two possibilities : use more 
of the .same chemical, or use a more toxic one. Again not all the bugs will be 
killed and a few who survive will be resistant and breed a generation that is 
also resistant. In order to kill them you again have the two alternatives. This 
goes on and on until you have developed superbug. There are many species of 
in.sects that are now totally resistant to DDT and other pesticides. The World 
Health Organization is very concerned about this problem and in fact have de- 
voted much time and research to the problem. But there is another factor to 
l)e considered. Not only do the pesticides kill the pest but they kill the good 
bugs too. They kill the natural predator. Not only that fish and birds which 
al.so eat insects are being killed by pe.sticides. Lady bugs, and honey bees and 
innumeralde other beneficial in.sects are being killed by pesticides. So consider 
the situation — we have created superbug, we have killed off his natural preda- 
tor and other species in the environment which would keep him in check, and 
we give him thou.sands of acres of his favorite crop — and then we wonder why 
we have a pest control problem. Another aspect of this problem is tliat insects 
whicli were never considered pest before are now becoming pests and the irony 
is that the more pesticides we u.se the more we have to use. Tlie more pests we 
kill the more pests we liave. What we have done, of course, is to interfere with 
and disrupt the ecological balance of nature. We have tried to beat nature into 



3289 



PESTICIDE RESLKRCH 




submission. The more difficulty we get into by the use of poisons the more we 
attempt to deal with the problem by using more poisons. The cost is that we 
have seriously compromised ourselves and our environment. Sooner or later we 
are going to have to heed warning signs — nature is trying to tell us something. 
If we do not, we are going to pay the price and it won't be only in ourselves 
it will be in our children and in future generations. See exhibit 14. 

15. BIOLOGICAL CONTROL 

Do we have to have pesticides? What will happen if we don't use pesticides. 
How can we get along without them. How can we continue to produce enough 
food to feed the world without pesticides. It is becoming increasingly clear 
that the problem is not we have to have pesticides to eat, but that if we don't 
do something about pesticides we won't eat. An alternative must be found — 
and if we give the problem the priority and the money for research it deserves 
a solution will be found. In the interim until safe alternatives to pesticides are 
found (and the answers will no doubt be found in ecological solutions using 
biological controls among other methods) compounds that have been clearly 
demonstrated to be hazardous to man and/or the environment should be 
banned. An integrated approach using pesticides sensibly and sparingly along 
with other control methods should be used. Some of the millions of dollars 
being spent on poisons should be spend on the problem of how we are going to 



3290 




£ S f^ T^U C £ 



grow food without poison. The question is no longer how much will kill this or 
that l)ug or how much will make a man sick, hut what are the long term ef- 
fects on a population of animals (including us) in which very small amounts 
of pesticides are known to he active hiologically. 

Use of natural predators, sterile male techniques, simply changes in planting 
and harvesting have all i)een tried aiid found successful in varying situations. 
The serious depletion of our soils and use of hyhrid varieties have also accord- 
ing to some authorities added to our pest control prohlems. By making yield 
and (piantity the only criterion for success in farming, the quality of our food 
and our soil have seriously suffered leading to a situation where crops are 
more prey to infestations by pests. See exhibit lo. 

BIOLOGICAL CONM 




USE Of 6EN£RCJAL INSECTS 



3291 

10. TIP OF THE ICEBERG 

As we can see, \A-e know very little about the long term effects of pesticides 
— we know practically nothing about their effects on human health — yet we 
use them as if we knew everything about them. In the San Joaquin valley 
grape vineyards where we have a lot of experience and knowledge of the prob- 
lem, the evidence is clear that workers are being harmed. But there has been 
so much official apathy and refusal to consider the problem that the farm 
workers have had to take it upon themselves to force recognition of the prob- 
lem. The graiie growers have refused to bargain with the workers or even ne- 
gotiate the issue of pesticides. When U.F.W.O.C. attorney Jerry Cohen at- 
tempted to gain access to public records regarding the pesticides used on 
grapes he was denied the records by court injunction. The table grape growers 
have made is very clear that they have no concern for the perishability of the 
workers they are only concerned with protecting their industry. In the recent 
negotiations in which the union proposed a very strong worker protection 
clause involving banning of DDT, Aldrin, Endrin and Dieldrin and setting up 
a health and safety committee to safeguard the workers from hazards of pesti- 
cides the growers made the following proposal : They proposed that the union 
refuse to engage in any pesticide campaign that could in any way be harmful 
to the industry in which the employer belongs. 

So far we have managed to survive mistakes in which small groups of peo- 
ple and fish and wildlife have been damaged and killed. We cannot afford to 
make mistakes that involve the whole population. We must learn to recognize 
our mistakes and accept the fact that unforeseen, irrevocable and undesirable 
side effects have arisen on a large scale from uncontrolled and unintelligent 
use of pesticides. Assuming an unknown risk cannot be justified when the 
guinea pigs are men, women and children. We have no choice about it — all of 
us are being slowly poisoned — and farm workers quicker than the consumer. 
The burden of proof can no longer be put on the public to prove that a sub- 
stance is harmful. The manufacturer of pesticides must be able to prove that 
it is safe. See exhibit 16. 

TIP OF tHE ICtBtllG 



'UNR£PORrED> 
C/\5ES 

^UNDIAGNOSED CAStS 

'AGRIBUSINESS ?ROPirS 



INDUSTRY CONr(?0LL£D REStARCM 

Negligence GRt£^ 



3292 

[Reprinted from the Archives of Environmental Health, July 1964, Vol. 9, 
pp. 92-98. Copyright 1964, by American Medical Association] 

Occupational Disease of Farm Workers 

By Irma West. M.D., Berkeley, Calif. 

In California, the agricultural industry experiences the highest occupational 
disease rate — over 50% higher than the industry in second place, and almost 
three times as high as the average rate of all industries. 

A number of converging circumstances may explain this experience. First 
are the formidable hazards both new and old on the farm. Second, it is much 
more difficult to control hazards in orchards and fields than within the four 
walls of industrial plants. Third, agricultural workers, becausee of migrant 
status, seasonal work, language barriers, .substandard education, marginal 
health, and poor hygiene, are the least able of any group to protect themselves 
against occupational hazards so require more .safety supervision than other 
categories of workers. Fourth, the rapidly advancing technological changes in 
agriculture have left the industry behind in dealing with occupational hazards, 
particularly with agricultural chemicals. Concepts in industrial hygiene and 
industrial medicine commonly used for many years in other industries have 
not been employed or adapted to the agricultural .setting. Such commonplace 
needs as clean drinking water, wash water, and .sanitary facilities are rarely 
available in the fields and are notably deficient in many living quarters of 
farm laborers. Yet, both water and soap are vital to the prevention of the 
most prevalent and most serious occupational diseases occurring on the farm. 

In California, in 1962, about 230,000 farm workers were employed* ; 83 of 
them died from occupational causes (/). In seven instances, the death was at- 
tributed to an occupational disea.se, in the remainder, to a work injury. From 
1955 to 1962 inclusive, 29 deaths from occupational disease among farm work- 
ers were recorded. Eleven were attribvited to heat stroke, four to poi.soning 
from organic phosphate pesticides, and four to tetanus. The remainder were 
due to miscellaneous causes. 

In 1962. there were 2,696 reports of nonfatal occupational disease (2) among 
agricultural workers, most in farm laborers. Dermatitis, i>esticide poisoning, 
food poisoning, and heat stroke or exhaustion were reported most frequently. 
Judging from the number and seriousne.ss of fatal and nonfatal occupational 
disea.se, heat stroke and pesticide poisoning should be considered the most for- 
midable occupational diseases occurring in agriculture in California. Of the 
pesticides, it is the highly toxic group of phosphate esters, such as parathion, 
(0,0-diethyl 0-[p-nitrophenyl] phospliorothioate). Thimet (0,0-diethyl-S 
[methylthioethyll pho.sphorodithioate) , Phosdrin (alpha isomer of 2-carbo- 
methoxy-1-metliyl-vinyldimethyl phosphate), Demeton (0,0-diethyl 0-[2- 
(ethylthio) ethyl ]-phosphorothioate and 0,0-diethyl S-[2-(ethylthio)ethyl] pho.s- 
pborothioate in 2:1 ratio), and tetraethyl pyrophosphate (TEPP) which 
present the greatest hazard. Their toxic effects are due to cholinestera.se inhi- 
bition. 

EXAMPLES OK OCCUPATIONAL DISEASES OCCURRING IN CALIFORNIA 

Example 1. — A young sprayer was found dead in the field in the tractor 
which had been pulling his .spray-rig. He had been pouring and mixing para- 
thion concentrate into the spray-rig tank. Parathion is the most commonly 
u.swl of the highly toxic pho.sphate ester pesticides. The estimated fatal dose is 
about 9 drops orally and 32 drops dermally. In the process of mixing the con- 
centrate, the worker contaminated his gloves inside and out. He rested liis 
gloved hands on liis trou.sers as lie pulled the rig to apply the spray. Para- 
thion was altsorbed tlirough tl)e skin of his bands and thighs. He began to 
vomit, an early symptom of parathion poi.soning. He could not remove his res- 
pirator and he aspirated the vomitus. The diagnosis of poisoning was con- 
firmed Ity postmortem cholinesterase tests. 



Notes. — Read before the 2.3rd Annual American Medical Association Congress on Oc- 
cupational Health. Ran Francisco, Sept. 2.5-26. 196:^. 

Medical Officer, Bureau of Occupational Health. State of California Department of 
Public Health. 

♦ Self-emi)Ioyed farm workers who make up about one third of the total persons work- 
ing on farms are not included. Their occupational injuries and occupational diseases are 
not reported and, therefore, not Included here. 



3293 

Example 2.— About 50 agricultural laborers were picking grapes. In the af- 
ternoon, about the same time, all suffered a sudden acute attack of nausea, 
vomiting, acute abdominal cramps, diarrhea, and about half went into shock. 
They recovered rapidly and were well in a few days. The physician who first 
saw them thought that phosphate ester pesticide poisoning was the most likely 
cause of the outbreak. However, subsequent investigation revealed that no pes- 
ticide had been applied to grapes, but luncheon sandwiches had been left 
in the field in the hot sun for sometime before eating. Unfortunately, no food 
was available for examination nor were cholinesterase tests determined for the 
workers, so that the diagnosis will never be confirmed. However, the clinical 
course of events is more suggestive of staphylococcal food poisoning. All who 
ate the sandwiches experienced the same acute symptoms at the same short in- 
terval after eating. The kind of phosphate ester poisoning occurring among 
pickers is not so abrupt in onset, usually does not find the total crew sick in 
the same degree at the same time, and symptoms and signs of cholinesterase 
inhibition, in addition to those referable to the gastrointestinal tract, are in 
evidence — headache, giddiness, blurred vision, sweating, diflicult breathing, pin- 
point pupils, and muscle twitching, for example. 

Example 3. — A 22-year-old field laborer was harvesting seed. In the process, 
he lacerated his finger in the seed separating machine; ten days later he died 
of tetanus shortly after admission to a hospital where he was taken because of 
seizures. 

Example 4.— A 16-year-old and a 21-year-old farm laborer were hired to 
apply a pesticide dust consisting of a 1.5% phosphate ester and a 10% sulfur 
mixture to strawberries. The estimated adult fatal dose for this phosphate 
ester pesticide is five drops orally and six drops dermally. The workers used 
knapsack dusters, starting work at 7:30 am. At noon, the 21-year-old worker 
became ill and remained at the side of the field in his car and vomited. After 
a while, he felt better and drove home. Fortunately, he did not have an auto 
accident. Workers with phosphate ester poisoning are poor risks with any mov- 
ing machinery. The 16-year-old worked until 4 pm when he vomited and went 
home. At 8 pm, he complained of weakness and giddiness and was taken to a 
physician's oflice. The boy's clothing was reported to have been covered with 
sulfur. The physician called the Poison Information Center for information 
about sulfur which is relatively nontoxic. The boy was sent home with a pre- 
scription. At 9:30 PM, the boy became worse and was taken to the local hospi- 
tal. This time, the label from the pesticide container was brought with the pa- 
tient. The boy was again sent home although he was unable to walk. At 7:30 
AM the boy was found moribund in his bed, still in his contaminated work 
clothing. He died in the ambulance en route to the hospital. Death due to 
phosphate ester poisoning was confirmed by post-mortem cholinesterase tests. 

The 21-year-old worker, although asymptomatic, reported the next day for a 
cholinestera.se test which confirmed that he had been poisoned by a phosphate 
ester chemical. He had not worked with phosphate ester pesticides before. The 
16-year-old had applied the same pesticide on one occasion two months before. 

There were a number of errors committed in the series of events leading to 
this death : The permit to purchase and apply the pesticide had expired so 
that it was purchased and applied illegally. The highly toxic phosphate ester 
was applied by hand duster, a primitive and entirely unsafe method of appli- 
cation. The container label was not read until after the second illness. No 
medical supervision was provided. No advance arrangements were made with a 
physician for prompt adequate care in an emergency. The two workers were 
not instructed about hazards and precautions for using the pesticide. They 
were not provided with protective clothing. No medical attention was sought 
for the worker who quit at noon because of illness, and no medical examina- 
tion was considered for the younger employee who kept on working. The vic- 
tim was not told to bathe, wash his hair, and change into clean clothes after 
work. When the boy was taken to a physician, no one could provide informa- 
tion about the pesticide which the workers had applied. 

On first visit, the physician released the victim as only mildly ill without 
ruling out serious poisoning. He should have insisted on seeing a label from 
the pesticide container. On second visit, the physician was furnished the label 
but did not follow the medical treatment recommended on it. He may have 
been confused by entirely different doses of atropine prescribed. The label 
listed the large doses which should have been administered, but also listed the 



3294 

conventional dose of atropine by tablet for first aid (the practice of recom- 
mending tablets for first aid slionld be discontinued for reasons demonstrated 
here and in example C which follows). The physician did not call a consultant 
<ir the Poison Information Center for information about the pesticide mixture 
listed on the label. The boy was not kept under close medical observation for 
24 hours. He was not decontaminated, and no cholinesterase determination was 
made. 

The sui)plier of the pesticide did not check the number of permit given by 
the purchaser to assure that the permit was valid. The product was also mis- 
branded, it contained two to four times the phosphate ester pesticide specified 
on the label. 

This case is somethins of a classic in that .iust about every error possible oc- 
curred : and avoidance of any one of the more serious errors could have saved 
the boy. 

Example o. — A farm tractor driver was hospitalized with critical burns of 
Ixith eyes when ammonia under pressure escaped from a leaky valve on a fer- 
tilizer applicator. 

K.rntni)lc 6. — A youns man came to work as a swamper for an agricultural 
aircraft operator, and the first day, was put to work steam-cleaning and wash- 
ing a croi)-dusting aircraft. It was reported that he was not informed of any 
hazard nor was he given any protective clothing or eciuipinent. His clothing 
was observed to liave been thoroughly wet while he was working. In the early 
afternoon, he complainetl of not feeling well. His employer gave him two atro- 
pine tablets and the .swamper returned to work. Not long afterwards, he was 
found unconscious. He was admitted to tlie hospital and died several hours 
later. Apparently, the aircraft he was cleaning had been used to make .several 
applications of one of the highly toxic phosphate ester pesticides. The diagno- 
sis of phosphate ester pesticide poisoning was confirmed l)y postmortem cholin- 
e.sterase tests. 

Exam pi f 7. — Because of engine trouble, an agricultural aircraft pilot at- 
tempted a forced landing in an uni)laTited field. The plane rolled into a fence 
and turned over. The hopper of the airplane contained a dust formulation of 
TEI'P. another of the phosphate ester pesticides. The estimated adult fatal 
dose for TEPP concentrate is one drop orally or dermally. The pilot was not 
injured iiut was covered with dust. He walked a distance of 00 ft to a field 
worker, stated he felt fine, and asked for a drink of water. After driid<ing the 
water, he began to vomit and almost immediately became unconscious. By the 
time the ambulance arrived, the pilot was dead and the ambulance driver, the 
pathologist, and the mortician became ill from handling the body (3) 

Example H. — Althongh this example is not an occupational disease, it is in- 
cluded to illustrate that poisoning of children can result from the same mi.s- 
takes in handling farm chemicals that lead to occiipational disease. An IS- 
month-old child of an agricultural aircraft pilot was found at home in a state 
of jicute respiratory distress, semiconscious, and with pinpoint pupils. In the 
hospital, she was i>laced in a resuscitator and treated by a skilled physician 
for .'^evere organic phosphate poisoning from which she recoven'd. On the 
morning of the illness, her father had come home after applying a highly toxic 
phosphate ester pesticide. He was reported to have cleaned his boots with 
paper towels and then threw the towels in the wastebasket and placed his 
lioots in the bathroom. The child either contacted the boots or the paper in the 
wastebasket. 

In connection with these three examples of poisoning arising from the agri- 
cultural aircraft operations, it is of Interest to note that there is no group in- 
side or outside agriculture which has experienced a more formidable record of 
occupational iTijury and disease tlian the agricultural aircraft industry. This 
group has taken the brunt of the technological demands of agriculture in the 
application of pesticides. Pestic-ides are applied by air to about half the 
acreage treated ff)r pest control in California. Since this state uses over 20% 
of the nation's pesticides, its agricultural aircraft ])ilots apply about lO'/f to 
15% of the nation's pesticides, but at a price. One pilot is killed in an air acci- 
dent for each million acres treated (5.3 pilots killed and 54 million acres 
treated in California, 1950 to 1904, inclusive. The number of licen.sed agricul- 
tural pibits rose from just over ."iOO in 1I).50 to 700 in 1061). In addition to the 
higjiest fatal injury rate of any occupation on record in California, agricul- 
tural aircraft is unique in another respect — over half its disabling work inju- 



3295 

ries are due to pesticide poisoning. For most industries, occupational disease 
accounts for 57r or less of total work injuries. However, considering the 
amount of pesticides and other agricultural chemicals applied by this industry, 
the cost in occupational disease is considerably less than among farmers and 
ground applicators who apply the other half of these chemicals. 

Examijlc 9. — Two young milkers in a dairy became ill with brucellosis 
within two months of each other. Both workers complained of gradual onset of 
fatigue, fever, headache, and overwhelming fatigue. Lymphadenupathy was 
prominent in the younger victim who was not as ill as the second worker who 
was hospitalized for several weeks. 

Example 10. — Beginning in 1949, there have been at least six sizable epi- 
sodes reported where outbreaks of parathion poisoning occurred among farm 
workers picking fruit (oranges, peaches, pears, grapefruit, grapes, olives). In 
1959, about 275 orange pickers were poisoned in a series of outbreaks. The in- 
terval between application of pesticides and the harvest of edible crops is 
predicated on the time when the pesticide residue on the crop will be below 
legal tolerance (1 ppm for parathion) and thus considered .safe for market. It 
had been assumed that by this time, the parathion would have declined suffi- 
ciently to make the orchards safe for the workers. This assimiption was ob- 
viously incorrect under certain circumstances not understood until recently. In 
August of 1963, over 90 peach pickers became sufficiently ill with parathion 
poisoning over a period of several days to seek medical attention. Although 
most of tlie 90 cases were mild or moderate, about one third were hospitalized 
and there was one death. Of the approximately 5,000-6,000 pickers in the 
area. 70 were selected at random and tested during the outbreak. About half 
of the 70 workers showed significant reduction of cholinesterase levels but 
were either asymptomatic or had not sought medical aid for symptoms. Leaf 
and fruit samples and spray schedules were obtained, both in the dozen or- 
chards involvetl in the outbreak and in orchards not involved. It became ob- 
vious that the unusually heavy spraying with parathion during the spring and 
summer to combat tlie oriental fruit moth has resulted in a heavy deposit on 
the leaves in the orchards producing illness. Because the leaves had a greater 
surface area, they had collected more pesticide than the fruit. This study con- 
firmed the earlier contention of Quinby and Lemmon (^) and others that der- 
mal exposure from the leaves of the heavy foliage was the most likely source 
of the problem. However, the heavy spraying schedules were the clue to why 
there was excessive residue on the leaves, but the amount of residue did not 
account sufficiently for the occurrence of poisonings. Tlie presence of more 
toxic breakdown products of parathion, such as Paraoxon (diethyl ;>-nitro- 
phenyl phosphate), is strongly suspected. 

Example 11. — A young farm worker fainted in a bar after one glass of beer. 
Because of the peculiar bluish-red color of his face and neck, a physician was 
called who hospitalized the victim. He recovered in about four hours. Inquiries 
were made to determine the nature of the black powder which covered the 
workman's clothing. It was found to be a fertilizer, calcium cyanamide. AVhen it 
is inhaled or taken orally at the same time as alcohol, sudden systemic effects, 
manifest by headache, shivering, staggering, and dyspnea become evident. If 
enough alcohol is taken, seriouss pulmonary complications may develop, other- 
wise, the victim recovers in a few hours. The peculiar color of the skin is ap- 
parently due to cyanhemoglobin or cyanhematin. 

Example 12. — Twenty-five farm laborers planting cotton in the hot San Joa- 
quin Valley became suddenly ill with the nausea, headaches, giddiness, blurred 
vision, vweating, and other symptoms typical of phosphate ester poisoning. 
They had been unloading bags of Thimet-treated cotton seeds from trucks, 
loading the planters, and piling and burning tlie empty bags. No washing facil- 
ities 0" protective clothing were available to these workers. Protective clothing 
to prevent skin absorption of this highly toxic pesticide mut be air cooled to 
be feasible in 105 F weather. The estimated adult fatal dose of Thiniet is 
three drops orally and nine drops dermally. Here is a situation which calls for 
industrial hygeiene engineering controls to alter the work processes to make 
feasible a safer handling procedure. 

Example 13. — A 15-year-old farm laborer was tipping grape vines on a 105 F 
July day in the San Joaquin Valley. He complained of nau.sea, dizziness, head- 
ache, excessive sweating, and numbness of both arms. He developed severe 
muscle cramps and fell to the ground. He was taken to the emergency room of 



3296 

a nearby hospital where extreme pallor, and elevation of temperature, respira- 
tion, and pulse were noted. The patient responded well to ice packs, fluids, and 
bed rest. This worker had suffered a heat stroke. He had no water or salt pro- 
vided in the field. 

Many other examples of occupational disease on the farm could be presented 
to illustrate the variety of serious and growing problems facing the farmer, 
his employees, and their physicians. It is important to emphasize the new and 
growing occupational and rural health problems arising from the use of pesti- 
cides and other agricultural chemicals. Health hazards which have been a 
problem on the farm for hundreds of years are also present today — heat stroke 
and tetanus, for example. These problems require that physicians serving agri- 
cultural areas possess skills in toxicology and occupational medicine to serve 
their communities adequately. These demands are formidable enough without 
the addition of several hundred different farm chemicals calling for expert 
knowledge in industrial toxicology. However, four suggestions should be of 
considerable assistance in facing this task. First, every physician in an agricul- 
tural area should have on his desk the Clinical Handbook on Economic Poi- 
sons, Emergency Information for Treating Poisons (5). 

Second, each physician should be prepared to recognize and treat adequately 
poisoning from the phosphate ester anticholinesterase pesticides mentioned 
above. Poisoning from this group of chemicals is by far the most prevalent 
and most serious, accounting for over 70% of pesticide iioisonings among farm 
workers. The effectiveness of the antidotes and other treatment is such that 
medicine has much to offer in treatment. Victims who have absorbed several 
times the fatal dose can be saved with prompt and adequate medical manage- 
ment. 

Third, the physician must know how to identify a pesticide properly. Inade- 
quate identification of chemicals to which workers have been exposed is the 
most common difficulty noted in reviewing the physicians' reports of occupa- 
tional di.sease from chemicals in California. Several hundred commonly used 
pesticides liave markedly different effects which require different kinds of 
treatment. The important initial distinction is whether or not a pesticide is a 
phosphate ester anticholinesterase agent. If it is, treatment is specific and very 
effective and the cholinesterase test for red cells and plasma should be carried 
out. For almo-st all other kinds of farm chemicals, treatment of poisoning is 
largely symptomatic and there are few laboratory tests available to assist in 
diagnosis. The treatment for phosphate ester pesticide poisoning is of little or 
no value for poisoning from other kinds of chemicals and is contraindicated 
for some (example: atropine sulfate is contraindicated in pentachlorophenol 
poisoning). A common mistake is to assume that a farm chemical is a phos- 
phate ester when it is not. 

Identification of a chemical to which a worker has been exposed often re- 
quires considerable ingenuity on the part of the physician. Taking the worker's 
wftrd for it can be misleading. Checking with the employer and obtaining the 
label from the pesticide container, as well as finding out exactly how and 
when the exposure took place, is the basis for a valid diagnosis. The label on 
the original container will li.st the chemical ingredients in the formulation 
which can then be checked for toxicological data with the Poison Information 
Center, in a text .such as Clinical Toxicology of Commercial Products, Acute 
Poisoning, Home and Farm (6), or the handbook previou.sly recommended. 
Medical consultants in agricultural toxicology are rare but available through 
the larger companies manufacturing farm chemicals. It is important to con- 
sider all of the ingredients in a pesticide formulation. Sometimes, the .solvent 
in which tlie pesticide is mixed is also a toxicological consideration. When .the 
label is not available, sources of help include farm and health agencies such as 
the Agricultural Commissioner, state or local health or labor departments, and 
farm advi.sers. I'hysicians sliould learn what hazardous pesticides are used in 
the community and where and when exi)o.«ures to these chemicals may be oc- 
curring so that they are better prepared to deal with poisoning emergencies as 
well as offer advice about prevention. 

Fourth, physicians should recognize that the most important service they can 
perform is in the prevention of occupational di.sea.se from farm chemicals. 
There are several different methods. Physicians can provide good medical su- 
pervision for groups of farm workers. For example, in California agriculture, 
all workers regularly using the toxic group of phosphate ester pesticides must 



3297 

be medically supervised (7). The minimal legal requirement for medical super- 
vision consists of: (a) advance planning for prompt care of any emergency, 
(b) arranging for and interpreting the baseline and periodic cholinesterase 
tests so that excessive exposure is detected and corrected before illness occurs, 
and (c) deciding when workers must be removed from exposure to phosphate 
ester pesticides and when they may return to work after a poisoning episode 
or after a significant reduction in cholinesterase activity. 

Physicians can provide educational information for farmers who are their 
patients. Physicians can speak to various community groups on farm safety, 
and physicians can cooperate with the appropriate local agricultural, safety, 
and health agencies so that adequate health considerations are taken into ac- 
count in educational and regulatory affairs of agencies concerned with the use 
and control of pesticides. 

SUMMARY 

In California, agriculture experiences the highest occupational disease rate 
of any industry — three times as high as the average of all industries. A num- 
ber of converging circumstances may explain this. First, there are formidable 
hazards both new and old on the farm. Second, it is much more difficult to 
control hazards in orchards and fields than within an industrial plant. Third, 
agricultural workers need more safety supervision than other categories of 
workers. Because of migrant status, seasonal work, language barriers, sub- 
standard education, marginal health, and poor hygiene, they are the least able 
of any group to protect themselves against occupational hazards, particularly 
agricultural chemicals. Concepts in industrial hygiene and industrial medicine 
commonly used for many years in other industries have not been employed nor 
adapted to the agricultural setting. Such commonplace needs as clean drinking 
water, wash water, and sanitary facilities are rarely available in the fields, 
and are notably deficient in many of the living quarters of farm laborers. YeT, 
water and soap are vital to the prevention of the most serious occupational 
diseases occurring on the farm. 

In 1962, in California, there were about 2,700 reports of nonfatal occupa- 
tional disease coming from 230,000 farm employees. Dermatitis, pesticide poi- 
soning, food poisoning, and heat stroke were most frequently reported. From 
1955 to 1962, a total of 29 cases of fatal occupational disease were reported — 
11 attributed to heat stroke, 4 attributed to pesticide poisoning, and 4 from 
tetanus. The remainder were attributed to miscellaneous causes. Judging from 
the seriousness and number of reports, heat stroke and pesticide poisoning are 
the most formidable occupation diseases in California agriculture. 

Examples of various occupational diseases occurring on the farm are pre- 
sented to illustrate the serious and complex health problems entailed in the 
production of food and fiber. 

Physicians in farm areas can become the industrial physicians for agricul- 
ture and help prevent occupational disease and injury. Four specific sugges- 
tions are offered to the rural physician to assist him with pesticide poisoning 
problems: he should possess the Clinical Handbook on Economic Poisons (5) ; 
he should know how to identify the offending pesticide when confronted with a 
poisoning emergency : he should become skilled in the recognition and treat- 
ment of phosphate ester poisoning : and he should be prepared to provide good 
medical supervision for employees working with pesticides. 

REFEREXCES 

(1). California Department of industrial Relations: Work Injuries in Cali- 
fornia Agriculture, San Francisco : State of California, 1962. 

(2.) California Department of Public Health: Unpublished tabulation based 
on Doctor's First Report of Work Injury, Berkeley, State of California, 1962. 

(S.) Smith, Roy: Kimra, M. : and Ibsen, M. : Poisoning by Organic Phos- 
phate Insecticides, Calif Med 83 :240, 1955. 

i4-) Quinby, G. E., and Lemmon, A. B. : Parathion Residues as a Cause of 
Poisoning in Crop Workers. JAMA 166. 740. 19r)S. 

(5.) Hayes, W. C. : Clinical Handbook on Economic Poisons, Public Health 
Service Publication No. 476, Washington, D.C. : US Government Printing Office, 
1963. 



3298 

(6.) Gleason, M. H. : Gosselin, R. E. ; and Hodge, H. C. : Clinical Toxicology 
of Commercial Products : Acute Poisoning, Home and Farm, Baltimore : The 
Williams »& Wilkins Company, 15)63. 

(7.) California Medical Association, Committee on Occupational Health: 
New Law KtMHiiring Medical Supervision, Calif Med 96:364 (May) 1!>62. 



\ 



Thk Csk of Agricttltural Chemicals 
By Irma West. M.D. 

Anyone who applies, stores, transports, disposes of. formulates, mixes or 
manufactures agricultural chemicals has assumed a particularly important oh- 
ligation with respect to the safety of his operations. He must have special 
knowledge, adeipiate training, proper eciuipment. and sources of technical help 
and information to call upon when special prohlems or emergencies arise. 

There are .several fundamental "facts of life" which should he understood at 
the out.set hy per.sons responsible for safe u.se of agricultural chemicals. Fir.st, 
there are tremendous differences in the degree and kind of hazard they may 
present to peoi)le. A number of chemicals are of very little hazard, even when 
misused. H(»wever, it is practically never .safe to say any are harndess. Pesti- 
cides, for example, would not be of much use if they did not have some ad- 
verse effect on plant and animal life. There are a few agricultural chemicals 
which are amoTig the most dangerous materials ever u.sed by man. Examples 
are TEl'P (tetraethyl pyrophosphate), parathion, Phosdrin, Thimet (phorate). 
and Demeton ( Systox ) . Therefore, the prospective user nuist find out before 
he buys or uses any chemical just what the hazards are. and how to protect 
him.self, his employees and the public. Furthermore, in order to make an ac- 
curate estimate of the cost of using any chemical, the hazard must be known 
because a sizeable part of the expense can be in the time, equipment and serv- 
ices necessary to assure safety. 

Second, it sliould be understood what the term "hazard" means. It is not the 
.same as toxicity (poisoning ability), although toxicity is often a very imi)or- 
tant part of the oveniU hazard. The h;izard is the summation of all of the po- 
tentially harmfid effects which could occur during a particular use of a 
particular i>esticide. There are a number of factors in addition to acute and 
chronic toxicity which can contribute to the hazard. Among them are : 1 ) 
flannnability. 2) explosibility, 3) ability to cause chemical burns or irritation 
of the eyes (conjunctivitis), skin (dermatitis or rashes), and breaking passages 
(including chemical pneumonia), and less fretiuently 4) ability to cause al- 
lergic respon.ses such as hives, hay fever, and asthma. Any chemical can pres- 
ent one or more of these dangers from a very mild to a severe form. 

Factors greatly increasing the hazard are 1) the al)ility of a .substance to 
enter the body readily through the intact skin, and 2) the ability to easily 
emit vapor into the air (a litpiid with high vapor pressure or a gas). Any 
highly toxic chemical which is a gas or a licpiid with a relatively high vapor 
pressure and which can easily l»e absorbed through the skin is particularly 
hazardous to humans. Examples are-tetraethyl pyrophosphate (TEPP) and cy- 
anide gas. 

The third "fact of life" is that technical information about health and 
safety in the use of chemicals does not come from the same group of experts 
who advise on how to u.se chemicals effectively. The applicator, extension serv- 
ice man. varifnis fieldmen. and the entomologist are among those called upon to 
advise on the .selection of a pesticide to destroy a specific pest. The group tech- 
nically (lualified to advise on health and safety come from cTitirely different 
fields. They are industrial niedicine, human toxicology, industrial hygiene. 
public health and related health fields. For advice on safety with respect to 
wildlife, still another technical group must he called upon, such as the biol- 
gist, the ecologist, and the conservatif)n expert. It is important to seek advice 
from the group technically etiuipped to provide it. 

Experience has shown that more children under five years dies of accidental 
pesticide poisoning than any other group of i)eople, and that arsenic and phos- 
phate ester i«'sticides (such as itaratiiion and TEPP) are the most serious of- 
fenders. Ciiildren will find almost anything that is left accessible, and becau.se 
of their small size and increa.sed suceptibility, it takes a very small do.se to be 
lethal. 



3299 

Examples 

Case 1. A group of families with their children were picking berries on a 
berry farm. They were followed by a spray rig. On the spray rig was a five- 
gallon can of TEPP concentrate. A four-year-old-girl put her finger in the can 
which her older brother had opened. She died within twenty mintes. 

Case 2. A three-year-old boy was admitted to the hospital in a serious condi- 
tion. He had been nauseated and vomiting during the previous night. The 
child's shirt was found to be a stainetl with an oily substance. The child had 
been playing in a shed on a ranch near where a container of parathion, which 
had been left on a shelf seven years before, had spilled on the floor. The child 
recovered. 

The greatest numl)er of poisoning deaths from i)esticides are the result of 
suicide. At least some of these deaths could have been prevented if toxic pesti- 
cides had not been left within the reach of emotionally upset persons. Persons 
who have a history of attempted suicide or are emotionally upset are not good 
candidates for employment in any job where toxic chemicals are easily avail- 
able. 

Of growing concern are the increasing number of incidents where toxic pes- 
ticides are spilled during transportation or storage, and neighboring cargo such 
as food and clothing and bedding becomes contaminated (see Table). It cannot 
be emphasized too often that spills of concentrates of toxic chemicals wherever 
they occur are an emergency requiring immediate and expert attention. The 
chemical or common name of the chemical must be immediately available in 
order to know what the hazard is, how to decontaminate, and to inform the 
physician to whom anyone is taken who has been exijo.sed to the spill. Each 
operation where toxic pesticides are .stored, transported or used should make 
advajice plans for exactly how to handle spills of each chemical on the prem- 
ises. (See chapters on Safe Transportation and Storage of Pesticides in "Safe 
Use of Pesticides," listed in the references at the end of this paper. ) 

Another group at special risk where pesticides are manufactured, formulated, 
transported, stored, or applied are the workers, particularly farm workers. In 
California, over half of the cases of occupational disease from agricultural 
chemicals occurs in the farm worker. Fatal poisoning is fortunately not a fre- 
(luent occurrence but completely preventable deaths occur each year. Para- 
thion, Phosdrin, Demeton (Systox), TEPP, methyl bromide, ar.senic, paraquat 
and ammonia have been the agricultural chemicals involved in fatal cases 
among workers in California. Most of the serious nonfatal cases were attrib- 
uted to the phosphate esters, parathion. Pho.sdrin, Thimet. (For further infor- 
mation see Occupational Disease in California Attributed to Pesticides and 
Other Agricultural Chemicals. . . . 1965, listed with references at the end of 
this paper. ) 
Example : 

Case 3. Mr. X came to work for Mr. C., a California seed grower. Mr. X was 
handed a large shake of gray powder and told where to apply it. The shaker 
of 10% phorate (Thimet) was not labeled. The worker was not given any in- 
formation about the hazards involved in using this highly toxic pesticide. He 
was not provided with protective clothing, such as gloves, goggles, and imper- 
vious coveralls, to prevent skin contact. He was not provided with an ap- 
proved, clean respirator to prevent breathing the dust. He was not provided 
with washing facilities so he could shower and change to clean clothing before 
going home, thus avoiding bringing home contaminated clothing which could 
endanger him and his family, particularly young children. No one on this 
ranch knew the proper first aid to administer when Mr. X became ill. No pre- 
arrangements had l)een made with a local physician so that poisoning would 
receive prompt and adequate care. There was considerable delay in identifying 
the pesticide, since there was no label on the shaker and the original container 
could not be found. Since medical treatment for pesticide poisoning is quite 
different depending on the particular material, any dela.v in providing the phy- 
sician with the name of the pesticide can mean a serious delay in proper 
treatment. This case of iwisoning was entirely unnecessary. It could have been 
so easily prevented. No one comes etp^ipped with the knowledge he needs to 
use hazardous chemicals safely. He must first be taught exactly what to do 
and why. If the boss doesn't have the knowledge, training, or equipment, he 
cannot pass it on to others who work for him. 



3300 

8UMMABY — BASIC RULES FOR SAFETY 

A review of the serious to fatal agricultural chemical poisoning cases reveal 
that one or more of these basic safety rules were broken. 

1. Before opening any container of an agricultural chemical, workers should 
be informed if there are risks to themselves and others, and they should re- 
ceive instructions and equipment for safe handling. Read the Label Each Time 
Before Use. 

2. Whenever there is a choice, the less hazardous chemical should be used 
and no more than is necessary. 

POISONING EPISODES CAUSED BY CARGO CONTAMINATED BY A PESTICIDE SPILL IN STORAGE OR TRANSIT 

Commodity Where Persons 

Place Year Pesticide contaminated contaminated harmed 

England' 1956 Endrin Flour Railway cart 59 111. 

Singapore' 1959 Parathion Barley Boat from Europe. 9 dead, 26 ill. 

Fresno.s California 1961 Phosdrin Blue jeans Truck , 6 ill. 

Vancouver,* British Columbia, 1964 Parathion Bed sheets BoatfromSan 2 very ill, 

Canada. Francisco. repeatedly. 

San Diego,' California 1965 Diazinon Doughnut mix Bakery 28 ilL 

Report not released' 1967 Endrin Flour Boat Many dead and 

ill. 

Tijuana,' Mexico 1967 Parathion Sugar Truck 17 dead, 300 ill. 

Colombia," South America 1967 Parathion Flour Truck 77 dead, 146 

hospitalized, 
600 (7) ill. 

1 Davies, G. M., and Lewis, I.: "Outbreak of Food-Poisoning from Bread Made of Chemically Contaminated Flour." 
Brit Med J 2:3S3(Aug. 18)1956. 

2 Kanagaratnam, K., Boon, W. H., and Hoh, T. K.: "Parathion Poisoning from Contaminated Barley." Lancet 1:538 
(Mar. 5) 1960. 

3 Warren, M. C, et al: "Clothing-Borne Epidemic." JAMA 184:266, 1963. 

< Anderson, L. S.. etal; "Parathion Poisoning from Flannelette Sheets." Canad Med Assn. J 92:809 (Apr.) 1965. 
= West, I. : "Public Health Protilems are Created by Pesticides." California's Health, July 1965. 

< Report confidential and not yet released. Information for official agencies only. Occurred outside United States. 
'.•Widely publicized in newspapers. 

Prepared by: Bureau of Occupational Health, California State Department of Public Health, 2151 Berkeley Way, Berkeley, 
Calil. 94704. 

3. There should be on-the-job safety supervision. New employees and those 
not trained in handling chemicals need constant supervision. No one should 
work alone with a hazardous chemical. 

4. Pest control equipment should be of proper design, well maintained and 
regularly cleaned so as to minimize spills or other pesticide exposure to opera- 
tors or maintenance personnel. The mouth should never be used to siphon. 
Cross-connections or siphons which could contaminate wells and water supplies 
should be avoided. 

5. Washing facilities should be readily available and any spills or splashes 
of chemicals should be immediately washed from the skin and the clothing 
changed. Hands should be washed before smoking or eating. Lunches, drinking 
water, and tobacco should be kept away from farm chemicals. A shower fol- 
lowed by a change of clothing after each day's work is mandatory. Work 
clothes should be cleaned separately and not taken home for laundering. Con- 
taminated boots, tools or other items should not be taken home. They can be a 
hazard to the family. 

6. The employer should provide, maintain and clean whatever protective 
clothing or equipment (gloves, respirators, etc.) is needed for safe work with 
chemicals. Different pesticides may require different kinds of protective equip- 
ment. 

7. Special care is neces.sary in handling concentrated pesticides. It is at this 
point that the greatest hazards lie, particularly if the chemical is toxic and 
readily absorbed through the skin. In the transferring of concentrates from 
drums, either threaded taps or drum pumps should be used. Measuring and 
pouring from jars and cans is asking for trouble. 

8. Pesticides must be properly labeled and stored in original containers. All 
toxic chemicals should be stored separately under lock and key away from 
foodstuffs, medicines, clothing, toys and the like. They should never stored in 



3301 

containers which can be confused with food, beverages or medicines. No pesti- 
cide containers, empty or otherwise, should be left where children, pets, live- 
stock, or irresponsible persons have access. Empty container should be burned, 
or decontaminated and buried preferably at an authorized dump, right away. 

9. Toxic chemicals or any items contaminated by toxic chemicals must not 
be transported in passenger sections of vehicles, nor with foodstuffs or other 
commodities which could be a hazard if contaminated in a spill. 

10. Persons who have been accidentally overexposed to a toxic chemical or 
have symptoms of poisoning, should never operate an auto, truck, aircraft or 
any other vehicles. They should be taken promptly to the doctor. Plans for 
handling emergencies must be made in advance with the doctor. Medical super- 
vision should be provided for all work with hazardous materials. 

11. Workers should know basic first aid for chemical injuries as follows: a) 
give mouth-to-mouth artificial respiration if breathing has stopped, wash face 
and use handkerchief if face is contaminated; b) decontaminate skin by wash- 
ing, remove contaminated clothing, use gloves; c) if chemical splashes in the 
eyes wash for 15 minutes with clean water ; d ) if chemical swallowed and vic- 
tim fully conscious give water, induce vomiting by gagging only if victim is 
conscious and no solvents or corrosives are in the formulation; e) take victim 
to a physician or nearest emergency hospital as soon as possible and bring the 
container and label. 

REFERENCES ON AGRICULTURAL CHEMICAL SAFETY 

1. American Public Health Association : Safe Use of Pesticides 1740 Broad- 
way, New York, N.Y. 10019. 1967— ($3.00). 

2. Bureau of Occupational Health. California State Department of Public 
Health : Diagnosis and Treatment of Phosphate Ester Pesticide Poisoning — A 
Guide to Physicians, 1967. 2151 Berkeley "Way, Berkeley, California 94704. 

3. : Methyl Bromide Poisoning, 1964. 

4. : Occupational Disease in California Attributed to Pesticides and 

Other Agricultural Chemicals, 1965. 

5. National Agricultural Chemicals Association : Decontamination and Dis- 
posal of Empty Pesticide Containers. 1155 Fifteenth Street, N.W., Washington, 
D.C. 20005, 1965. 

6. : Waste Disposal. 1155 Fifteenth Street, N.W., Washington, D.C. 

20005, 1965. 

7. United States Department of Agriculture, Agricultural Research Service : 
Safe Disposal of Empty Pesticide Containers and Surplus Pesticides. U.S. Gov- 
ernment Printing Office, Washington, D.C, 1964. 

8. Yeomans, A. H., et al : Respiratory Devices for Protection Against Certain 
Pesticides. United States Department of Agriculture, Agricultural Research 
Service, Beltsville, Maryland 20705 — Revised February 1966. 

Pesticide Safety Book 

A 92-page, soft-cover handbook, "Safe Use of Pesticides," edited by Irma 
West, M.D., M.P.H., is available from the American Public Health Service, 
1740 Broadway, New York, NY 10019. Price is $3.00. 

Sections are included on safe use. transportation, storage, disposal, manufac- 
ture and packaging of pesticides ; first aid for pesticide injury or illness, medi- 
cal supervision of workers, diagnosis and treatment of poisoning ; and pesti- 
cides in water, air and soil. Fifteen specialists contributed to the manual, 
which is intended as a practical guide for the average, non-specialized person. 

Orangeicorms in Almonds 

Old nuts (sticktights) left in almond trees after harvest serve as overwinter- 
ing sites and also as the only source of food for the spring generation of the 
navel orangeworm. L. E. Caltagirone and coworkers at University of Califor- 
nia, Riverside, reporting on studies begun in 1963, said that larvae develop 
during the winter and early spring, then emerge as moths. Egg laying begins 
in late March or early April. Eggs are deposited only on the old nuts ; eggs 
have never been found on the new crop before the hulls begin to split and dry. 
Egg laying continues throughout the season, reaching peaks in May-June and 
August-September. 



3302 

At present, there is no ec-onomically feasible method of controlling navel 
orangeworms with insecticides, the researchers said. Complete removal of the 
old nuts would mean the destruction of the within-the-orchard source of infesta- 
tions, and economic feasibility of this must be weighed against the role of the 
sticktights as a food source for an increasing population of navel orangeworm 
in early spring. 

The navel orangeworm can live in a wide variety of fruits, Caltagirone 
pointed out. and to be effective, sound crop management must be extended to 
other fruits in the vicinity of almond orchards as well as to other almond or- 
chards in the area. 

AhiiuiiI lilKCfjrasfi Control 

Thirty pounds per acre of bensulide produced leaf discoloration and root 
length reduction of established annual bluegrass plants without injuring creep- 
ing bentgrass in tests conducted at Oregon State liuversity. 

Terbacil at 0.2 pounds per acre and bromacil at 0.4 pound per acre gave 
highly selective control of annual bluegrass in Merion and Newport Kentucky 
bluegrasses when applied preemergence. Posteniergcnce applications of these 
compounds gave moderate selective control of annual l»luegrass. 

Elm Leaf Beetle 

Although many insecticides will kill the adult and larvae of the elm leaf 
beetle, the ma.ior problem is thorough coverage of infested trees, according to 
John Durkin. New Mexico State University. Trees often have to be sprayed 
.several times, because there are at least three generations a year. High pres- 
sure, high volume sprayers are necessary. Durkin recommends that long-resid- 
ual chemicals such as DDT be used to treat tree trunks to kill larvae. 



Pesticide-Induced Illness — Public Health Aspects of Diagnosis 
AND Treatment 

(By Irma West, M.D., Berkeley, Calif.) 

Over the past 25 years there has been a remarkalde proliferation of new 
chemicals into our environment, among them the 57,000 different tradenamed 
pesticide formulations now for .sale in the United States. With them have come 
nian.v new problems to physicians needing up-to-the minute toxocologic infor- 
mation, and also sizal)le problems in pul)lic health. Technology must be har- 
nessed to bring to physicians, when they need it, help in the diagnosis and 
treatment of poisoning and other adverse effects from modern chemicals, for at 
present it is impossible for the practicing physician to keep up with what is 
known and unknown al>out the toxicology of all of these chemicals. 

Man has manipulated bis environment on so large a scale that he has inad- 
vertently invented and produced a multitude of the most conii)licated new prob- 
lems ever to confront the iiealth professions. I'nfortunately, we have been slow 
to realize that i)lans for health and safety should be built into technologic ad- 
vatices in the planning stages. By the time technical tools are in operation and 
their use results in undesirable and unexpected effects upon people and their 
enviroimient. the l)est opportunity to minimize these effects efficiently and hu- 
manely is largely lost. So it is with many of our new environmental health 
proltlems whether they are air pollution or other environmental contamination 
with modern chemicals, including pesticides. 

Pesticides are materials which mitigate or kill unwanted animal or plant 
life. About G50 have been invented in the last 25 years. These new chemicals, 
plus a few older ones, are formulated into over 57.000 trade name products 
registered for sale in the T'nited States. Never before have hundreds of new 
chemi<"ils jiossessing such varying degrees and kinds of potential for good and 
harm been introduced into the environment in so short a time. 

It is important that prf)lileins in envirf)nmental medicine be viewed in con- 
text. With the possible exception of drugs, pesticides have been the first great 
experiment in the mass use of chemical technology. Aljout one hundred million 
pounds of pesticides are now applied annually in California. Ten years ago 
about half that amount was applied and 20 years ago use of the new synthetic 
pe.sticidef: was just beginning. By far the greatest portion of i)esticides is used 



3303 

in agriculture. Only 1 per cent is applied for control of disease vectors. About 
59 per cent of the pesticides used are insecticides, 15 per cent fungicides, 15 
per cent defoliants and herbicides, 10 per cent fumigants and 1 per cent roden- 
ticides. 

Pesticides have brought great benefits — and, with them, disturbing adverse 
side effects which are summarizied in Table 1. 

A question which naturally arises is. do the benefits outweigh the adverse 
side effects? The answer depends, of course, on what values one assigns to the 
items listed. The food technologist, the agriculturist and the chemical manufac- 
turer Avill point to the sizable benefits as the more important — the food sur- 
pluses, the economic importance of the commodities where pesticides play a 
significant role in production or preservation. On the other hand, the biologist, 
the conversationist and the wildlife expert will look with alarm at the chain 
of events arising from the worldwide contamination of the environment with 
the persistent chlorinated hydrocarbon pesticides, including the insidious 
build-up of these chemicals in the food chains. Medicine and public health 
have interests in both sides of the picture. "Worldwide, pesticides have been 
one of the methods used in successfully combating malaria and other vector- 
borne disea.ses. Millions of lives have been saved. In California the threat of 
Western and St. Louis Equine viral encephalitis is held in check by the mos- 
quito abatement activities. On the other hand, deaths and serious illness from 
acute pesticide poisoning and other recognized adverse effects upon California 
citizens which occur regularly are a tragic and unnecessary waste of human 
health and life (See Tables 2 and 3). Further, the uncertainties about long- 
term effects upon i>eople arising from a contaminated environment and from 
the storage of chlorinated hydrocarbon in human fat, are reason for considera- 
ble uneasiness in the medical profession and among public health workers. 
There is, of course, no objective answer to the question of the relative value of 
the benefits versus the adverse side effects from pesticides. Information on 
which to make such a judgment is far from complete and may never be avail- 
able. However, as time goes on the relative importance of these benefits and 
side effects may become more obvious. 

A question of greater significance from the standpoint of public health and 
environmental medicine is, can we have the benefits of pesticides without the 
undesirable side effects? It is technically feasible and well within the realm of 
possibility to use pesticides in a manner which will reduce undesirable side ef- 
fects to almost zero. However, such a program would call for revolutionary 
changes in our standards for research and field testing, and in our control 
over developing technology. We can obtain as much protection against the ad- 
verse side effects as we are willing to insist upon and pay for. 

The prevention of untoward effects upon the health of the population arising 
out of our technology is emerging as a most important and difficult public 
health function. Our society has never really faced the issue of what would be 
necessary to prevent the undesirable side effects arising from the use of i^esti- 
cides and still enjoy their benefits. First, before a pesticide was put into gen- 
eral use it would be necessary to know, through research and field tests, what 
all of the potential undesirable effects, are. Second, these chemicals must 
really be controlled so that they will not be used in a manner producing ad- 
verse effects. Third, because methods for predicting adver.se effects cannot be 
expected to be perfect, they must be continually evaluated and a monitoring 
system for human health must be established with built-in power to stop and 
revise uses of pesticides when they become suspect of producing undesirable 
effects. 

This kind of system may seem insurmountably difficult, but that is because 
our administrative vision has never been l)ig enough for our environmental 
health problems. A good control program is technically feasible. It has been 
routine, for example, in the development of our space program. However, when 



NoTE-s : Presented before the Section on Environmental Health at the Annual Meeting 
of the California Medical Association. Los Angeles, 19 to 2.S March 1966. 

From the Bureau of Occupational Health. State of California Department of Public 
Health. Berkeley. 

Reprint requests to : Bureau of Occupational Health. 2151 Berkeley Wav, Berkeley 
94704. 



36-513 O— 70— pt. 6A 20 



3304 

TABLE 1.— BENEFITS AND UNDESIRABLE SIDE EFFECTS ARISING FROM THE USE OF PESTICIDES 

Benefits Undesirable side effects 

Enhance production of food and fiber. Human poisoning and other diseases from pesticides. 

Help preserve stored food and other commodities. Contamination of the environment with destruction of bene- 

Help control vector-borne disease. ficial plant and animal life such as bees and wildlife; con- 

Help control nuisance pests. centration of chlorinated hydrocarbons in food chains. 

Protect economically and aesthetically valuable resources Pesticide residues on food. 

(forests, parks, trees, lumber, flowers, gardens, etc.). Storage of chlorinated hydrocarbon pesticides in human 

and animal fat. 
Development of resistance to chemicals by pests. 



it comes to down-to-earth matters involving the general population, too little 
too late is more often the case. Air pollution is another example of a situation 
in which our administrative imagination and machinery has never been big 
enough to catch up and come to grips witli the problem. 

Using hindsight in analyzing the geiaesis of undesirable and often unex- 
pected side effects from pesticides, it is apparent that considerable research 
and control went into some aspects of i)esticide usage and very little into 
others. A great deal of research and attention was paid to establishing toler- 
ances for pesticides on crops in which t)esticides were applied. Applications of 
pesticides were carefully prescribed and the crops monitored. Crops with more 
than the legal tolerances were condemned. However, pesticide poisoning among 
workers applying these materials and contamination of the environment for 
example, received very little if any research attention or effective control. It is 
also apparent that the skills and technical knowledge employed in the de- 
velopment of pesticides were in fields related to the intended uses of pesti- 
cides. Technical skills related to the adverse side effects were often not in- 
cluded. 

It should be stated at this point that there are very distinguished scientists 
who are not optimistic about our ability to control unwanted side effects aris- 
ing from our technological tools. For example Dr. Rene Dubos (15 April 1965 
Journal of Occupational Medicine) is quoted as follows : 

"Present programs for controlling potential threats to health from new sub- 
stances and technologic innovations are doomed to failure because we lack the 
scientific knowledge to provide a sound basis for control. 

"Current testing techniques have been developed almost exclusively for the 
study of acute, direct toxic effects. 

"In contrast, most untoward effects of the technological environment are de- 
layed and indirect. . . . Yet little is being done in schools of medicine and pub- 
lic health or in research institutes of government laboratories to develop the 
kind of knowledge that is needed for evaluating the long-range effects on man 
of modern ways of life. 

"The dangers associated with ionizing radiation, or with cigarette smoking 
should have sensitized the public as well as .scientists to the importance of de- 
layed effects. But, surprisingly, this knowledge has not increased awareness of 
the fact that most other technological innovations also have delayed effects. 

"The slow evolution of chronic bronchitis from air pollutants, the late ocular 
lesions following u.se of chloroquine, the accumulation of the tetracyclines in 
the fetus, and of course all the carcinogenic effects, are but a few of the 
countless objectionable results of new substances or technologies which ap- 
peared at first essentially safe." 

The same scientist spoke to the same point in a statement appearing in 
Biosciencc, 14:11, January 1964: 

"There is no need to belabor the obvious truth that, while modern science 
has been highly productive of isolated fragments of knowledge, it has been far 
less successful in dealing with the complexity of natural phenomena, especially 
those involving life. In order to deal with problems of organized complexity, 
it is therefore essential to investigate situations in which several interrelated 
.sy.stems function in an integrated manner. Multifactorial investigations will 
naturally demand entirely new conceptual and experimental methods, very dif- 
ferent from tho.se involving only one variable, which have been the stock in 
trade of experimental science during the past 300 years and to which there is 
an increasing tendency to limit biological research." 



3305 

The time has come to state that the medical profession has been placed in a 
difficult position with respect to the recognition and treatment of untoward ef- 
fects upon human health from pesticides and other modern chemicals. Since 
the field is one of growing potential for liability, it is somewhat surprising 
that so little protest has been heard from physicians. The present mechanisms 
for bringing information and education to physicians are not geared to meet 
today's rapid introduction of hundreds of new chemicals of potentially danger- 
ous effect. It is entirely unrealistic to expect every physician in general prac- 
tice to keep up with what is known and unknown about the toxicologic proper- 
ties of modern chemicals. Since technology produced this urgent problem, it is 
only fair to expect it should be used to devise imaginative new procedures to 
bring to the physician, when he needs it, effective help and up-to-date informa- 
tion of poisoning and other conditions resulting from exposure to pesticides. 

TABLE 2.-ACCIDENTAL DEATHS ATTRIBUTED TO POISONING FROM PESTICIDES AND OTHER AGRICULTURAL 
CHEMICALS, CALIFORNIA 1951-19651 



















Number 


of deaths 
















Children 








Workers 






Others 










Orga 


nic 






Organic 




















Arse- 


Ph 


os- 






phos- 


Methyl 






Arse- 






Year 


Total 


Total 


nic 


phates 


other 


Total 


phates 


bromide 


other 


lotal 


nic 


other 


195H 


B5 total.. 


. 128 


76 


44 




13 


19 


29 


12 


7 


10 


23 





13 


19651 


5 


2 


1 




1 





1 





1 





2 





2 


1964 




2 


1 


1 










1 


1 

















1963 




6 


3 


1 




1 


1 


1 


1 








2 





2 


1962 




5 


4 


1 




2 


1 


1 


1 

















1961 




6 


3 


2 







1 


3 


2 





1 











1960 




4 


4 


4 































1959 




18 


10 


4 




2 


4 


5 


1 


2 


2 


3 


1 


2 


1958 




13 


6 


2 







4 


3 


1 


1 


1 


4 


3 


1 


19.57 




12 


8 


5 




1 


2 


2 


1 





1 


2 


1 


1 


1956 




18 


11 


9 




1 


1 


4 





2 


2 


3 


2 


1 


1955 




6 


3 


1 







2 


1 








1 


2 


2 





1954 




12 


9 


3 




4 


2 


2 


1 





1 


1 


1 


u 


19,53 




10 


4 


3 




1 





4 


3 





1 


2 





2 


19.52 




6 


5 


4 







1 


1 





1 





U 








1951_ 




5 


3 


3 






















2 





2 



I All 1965 data preliminary, a small number ot death certificates yet to be processed. 

Source: State of California, Department of Agriculture, Annual Reports, Bureau of Chemistry, 1951-1960; State of 
California, Department of Public Health, Death Records and Occupational Disease Attributed to Agricultural Chemicals, 
1951-1963 by Bureau of Occupational Health. 

Note: Suicides now outnumber accidental deaths from pesticides (13 in 1964, 19 in 1965). 

Also urgently needed is the development of many more clinical chemical labo- 
ratory tests to help the physician confirm a diagnosis. For many chemicals, 
such tests either do not exist or are not available locally. Circumstantial and 
clinical evidence alone are often quite inadequate to arrive at a sound diagno- 
sis. As a result there are probably more unsound diagnoses and missed diag- 
noses in chemical poisoning than in most other areas of medicine. 

One of the most immediate problems in public health is the lack of informa- 
tion about what effects pesticides and other modern chemicals are having in 
the population. Only a part of this information is available through death cer- 
tificates, the Doctor's First Report of Work Injury (See Tables 2 and 3) and 
an occasional research project. 

These problems of the practicing physician and public health suggest the 
po.ssibility of a joint solution. A state or national center to provide medical 



3306 

TABLE 3.-REP0RTS OF OCCUPATIONAL DISEASE ATTRIBUTED TO PESTICIDES AND OTHER AGRICULTURAL 
CHEMICALS FOR ALL CONDITIONS AND SYSTEMIC POISONING. CALIFORNIA 1953-1964 







Reports of occupational disease 












Systemic 


poisoning 












Attributed to 






Attributed to 








organic 


Attributed to 


other 








phosphates 


chlorinated 


agricultural 




Total 


Total (phosphateesters) 


hydrocarbons 


chemicals 


Total 


- , 9,894 


3,296 


2,412 




141 


743 


1964.. 


1,328 


230 


135 






71 


1963 


1,013 


345 


267 






64 


1962 


827 


219 


140 






58 


1961 


911 


268 


194 






60 


1960 


975 


368 


283 






78 


1959 


1,093 


499 


407 






82 


1958 


910 


328 


227 






87 


1957 


749 


252 


189 






51 


1956 


789 


?81 


197 






73 


1955 


531 


183 


126 






53 


1954 


391 


122 


101 






20 


1953.. 


377 


201 


146 






46 



'DDT only. 

Source: State of California, Department of Industrial Relations, "Doctor's First Report of Work Injury." 
Statistics compiled by Bureau of Occupational Health, Department of Public Health. 

and toxicolojjical consultation to pliysioians with diagnostic and treatment 
l)rol)leins cfjuld, at the same time, record, meclianize and analyze ca.se data for 
study and dissemination. Any nnmher of benefits to physicians, their patients 
and the pul)lic could arise from such a center. For example, unexpected effects 
upon health c(»uhl l)e picked up and documented much earlier and appropriate 
preventive measures taken : the physician would have help in obtaining and in- 
terpreting laltoratory tests: and liability problems would be minimized. This 
proposal is for an advanced .stage in the development of the I'oi.son Informa- 
tion Centers now in use. It is time we recognized the value of augmenting a 
valuable .service of this kind to meet the needs of the day. 



[From the Texas Health Bulletin, Austin. Tex., August 1968, Vol. XX, No. 8] 
The Hidalgo County Incidext 

Poisoning f)f 28 farm workers northwest of Santa Rosa in Hidalgo County 
was reported in June following aerial spraying of a cotton field. 

Twenty-tw(» farm workers (eight males and 14 females) were working in the 
field, while the 23rd was involved in irrigating near the cotton field. Ages 
ranged from 12 to i'u. 

The field was sprayed from the air in late afternoon of the day before the 
acute poisoning occurred. It was the fourth .spraying of the 145-acre field with 
ethyl and methyl parathion, an organophosphate insecticide. 

The night of the spraying was warm, with little wind movement. During the 
early morning hours afterward a dew fell and the plants were quite wet the 
following morning when the weeding crew went into the field around 7 a.m. 
Growth of the plants was good. They stood three to three and a half feet tall 
and obscured the ground between the rows. 

As a result of the dew and dense foliage, when the weeding crew entered 
the field the next morning the workers couldn't avoid getting wet as they 
made their wa.v through the dense growth chopping weeds. 

It was the habit of workers to skip l)reakfast but to take food with them 
and snack as they worked, usually starting about an hour after going into the 
fields. Some carried drinking water with them. There was reason to believe 
that on the morning of the incident sf)me members of the crew put weed stems 
in their mouths and several of the younger ones may have sucked the nectar 
from morning glory fiowers in the field. Most worked barehanded. 



3307 

A 15-year-old boy got sick around 11 a.m., reporting dizziness to the wife of 
a foreman. The boy's 14-year-old brother went home about 15 minutes later. 
The foreman's wife took lunch to two of her own sons and found one com- 
plaining of nausea. The farm owner was called. <iuickly recognized the symp- 
toms of dizziness, nausea, sweating and trembling and rushed the sick ones to 
the Poison Control Center at Valley Baptist Hospital in Harlingen. 

Others were taken to the hospital by private cars as they became ill, and 
two were taken by ambulance dispatched by the farm owner. The first two 
boys who became ill were in critical condition for awhile. 

Twenty-two of the 23 involved were taken to the hospital on the same day, 
June 13. Another reported the next day. Of the 22, 13 received emergency 
treatment and were hospitalized. Nine were I'eleased after treatment. Twelve 
of the 13 retained were released early the afternoon of June 14. One female 
thought to be pregnant was released the following day. All were seen by the 
physician who originally treated them. Dr. G. L. Gallaher, director of the Poi- 
son Control Center, following their dismissal. All were recovering satisfacto- 
rily. 

Wholehearted cooperation with Texas community studies was given by all 
parties involed in outlining details of the Incident, including the farm owner, 
Ben Bearden, the pilot, Elwood Schwarz, and Mrs. Amelia Salas, wife of the 
foreman. 

Oliver Bryk, 

[Reprinted from Texas Medicine, September, 1968, vol. 64, No. 9, pp. 56-58] 

PUBLICATION 281, PESTICIDES PROGRAM, NATIONAL COMMUNICABLE DISEASE 

CENTER 

Characteristics of Pesticide Poisoning in South Texas 

(By G. A. Reich, M.D., G. L. Gallaher, M.D.. and J. S. Wiseman, Ph.D.) 

Certain areas in the United States where urban communities lie in or near 
agricultural .sections have i-eported many cases of i)esticide poisoning.^ - One 
such area is the Lower Rio Grande Valley of Texas where large amounts of 
organophosphate pesticides are used.^ Gallaher has stated that about 275 
acute pesticide iX)isoning cases occurred in the Lower Rio Grande Valley from 
1960 through 1966, 25 percent of which took place during the first four years 
of that period. In 1964 there was a striking increase in the number of cases ; 
the total (70) was approximately equal to the number of cases observed during 
the i)revious four years combined. This rise coincides with the introduction of 
certain organophosphate insecticides used to control crop i)ests, especially insects 
attacking cotton. The number of cases of poisoning observed in 1965 and 1966 
was about the same, near 70 each year.^ 

Hospital records of 129 fully documented eases of pesticide poisoning which 
occurred in the area were reviewed in an effort to define their epidemiological 
and clinical characteristics. Poison Control Center data for the years 1964, 
1965, and 1966 for Cameron County were al.so reviewed so that i)esticide poison- 
ing could be compared with other types of poisoning. 

distribution 

June, July, and August are i>eak months for pesticide intoxication in the 
Lower Rio Grande Valley ; 93 percent of the cases occurred during this iieriod 
when pesticides, particularly the organophosphates, are most abundantly applied. 
Patients ranged from six months to 58 years of age in this group of 126 adult 
men, 1 adult woman, and 2 children less than 10 yeiars old. Nearly three-fourths 
of the cases involved men aged 10 to 29 years, with a preponderance in the 
16-to-19-y ear-old group. In this area it is common for teenage boys to work during 
the summer months as loaders, mixers, or row flagmen for aerial applicators. 
Their exposure probably x'esults either from ignorance of the hazards involved 



^ Davis, J. H. : Clinical, Epidemiological and Forensic Aspects of Pesticide Poisonings, 
Fifth Inter-American Conference on Toxicology and Occupational Medicine, Miami, Fla., 
(Auk.) 1966. 

2 Davies, J. E, et al. : Disturbances of Metabolism in Organophosphate Poisoning, Industr. 
Med. Surg. .361 : 58 (Jan.) 1967. 

3 Gallaher, (i. L. : Agricultural Poisons, Texas State J. Med. 61 : 336 (April) 1965. 

■* Gallaher, G. L. : "Low Volume" Ins Control and Parathion Poisoning, Texas Med. 
63: 39 (Oct.) 1967. 



3308 

or their disdainful attitude toward these hazards. This may be a reflection of 
the attitudes of their employers. However, a decline in the incidence of ix>isoning 
oases beginning in 19(>7 may indicate that workers are becoming better informe<l, 
and attitudes toward safety prei-autions are changing. The two oc*cui>ation'al 
groups most endangered by pesticides are those employed by spray pilots and 
those who work on farms. These two made up S7 ijercent of all cases. 

Of the lOS i)atients (83 i>ercent) who were hospitalized, the mean in-jKitient 
stay was 2.3 days with a range of 1 to 16 days ; however, tJS jxTcent si)ent 2 
days or less in the hospital. 

SYMPTOMS 

Table 1 ll.sts signs and symptoms recorded in the medical records, ranked 
in order of frequency. For the most imrt, they are what one would expe<'t in 
cholinergic crises with the exception of tachycardia (19 cases) and mydriasis 
(2 cases). However, the.se exceptions have been noted in cases in south Florida." 
The tachycardia may be associated with a stress reaction with varying blood 
pressure and i>erhaps circulating pressor amines. Amino acid di.^^turbances, amino- 
aciduria, and inipaire<l renal function have been note<l elsewhere.' ^ ^Mydriasis 
has been notetl in severe cases,- and it is sugge.sted that as the brain stem fails, 
the B<linger-Westphal nucleus becomes depressed leaving the cervical sympa- 
thetics dominant. In severe ca.ses presenting with mydriasis, it has l)een obsen^ed 
that atropine may initially convert mydriasis to miosis, probably through resto- 
ration of brain stem function, and then as the atropine is continued the mydria.sis 
recurs, but at this i>oint it represents adequate atropinizati(m rather than an 
agonal sign. This list indicates that many tissues, organs, and .systems are 
affected by pesticide poisoning. 

The route of exposure was dermal in greater than 98 percent of these cases ; 
123 of the 129 were poisoned by ethyl and/or methyl parathion, both of which 
have low LD^o's (3.6 mg./kg. and 14.0 mg./kg. respectively*).* 

TABLE 1.— SIGNS AND SYMPTOMS OF PESTICIDE POISONING IN SOUTH TEXAS 

Patients 



Signs and symptoms Number Percent 

1. Vomiting 95 74 

2. Nausea 77 60 

3. Miosis - 74 58 

4. Weakness.. 66 51 

5. Abdominal pain 39 30 

6. Dizziness -- 30 23 

7. Diaphoresis 21 16 

8-9. Increased salivation 20 15 

8-9. Headache.... 20 15 

10. Tachycardia (100 or greater) 19 14 

11. Hypertension (systolic 140 or greater and/or diastolic of 90 or greater)... 18 14 

12-13. Blurred vision 16 12 

12-13. Fasciculations 16 12 

14. Aberration of consciousness 14 11 

15. Rales— Ronchi... 11 

16. Shortness of breath 9 

17. Muscle cramps 8 

18. Hypotension (systolic less than 100) 7 

19. Diarrhea.... .. 6 

20-21. Elevated temperature (100° F. or greater) 5 

20-21. Chest pain 5 

22-23. Bradycardia (60 or less) 4 

22-23. Tachypnea (as stated) 4 

24-25-26. Convulsions 3 

24-25-26. Cough.... 3 

24-25-26. Conjunctivitis... 3 

27-28. Mydriasis (prior to atropine therapy) ^i...... 2 

27-28. Nystagmus - 2 

29. Hypopnea 1 

* Mann, .T. B.. Pt al. : Chronic Pesticide Expo.sure with Renal Tubular Dysfunction, Amino- 
acidemia, and Aminoaciduria, J. Clin. Invest. 45 : 1044 (June) 1966. 

• Hayes, W. J. : Clinical Handbool< on Economic Poisons, Washington, D.C., PHS Publi- 
cation No. 476, 196,3. 

•The total amounts of organophosphate pesticides used, alone or in combination with 
certain chlorinated hydrocarbons, is estimated to have been 1,0.30,000 gallons in 1963, 
480,000 gallons in 1966, and .580.000 gallons In 1967. The decrease in total gallons in 
1966-67 as compared to 1965 reflects the use of the ultra low volume method for aerial 
application of undiluted toxicant. 



3309 

DIAGNOSIS 

The most valuable laboratory aid in the diagnosis of acute organophosphate 
intoxication is the cholinesterase determination. This value can be particularly 
useful when it can be compared to values determined several days to a week 
or even longer prior to the onset of symptoms. The rate of decline in enzyme 
aeti^^ty is an important factor in assessing the patient's symptomaology. Fewer 
symptoms may be present in the patient with a low cholinesterase value if he 
has had frequent minimal pesticide exposures over a period of time with a 
gradual depression of enzyme activity. 

Cholinesterase was determined by either the Caraway or Michel method in 
115 of the 129 patients in this series, and recorded below normal in greater 
than 00 percent. Althought both methods are considered reliable, the Michel 
method is more specific in determining cholinesterase depression due to organo- 
phosphate poisoning as it measures red blood cell cholinesterase. Plasma, serum, 
and whole blood cholineserase can be depressed by liver disease and he pheno- 
thiazines, for example, in addition to pesticides. 

Table 2 summarizes tlie results of some other laboratory tests. The findings 
of albuminuria in 13 percent, ketonuria in 9 percent and leukocytosis in 24 
percent exceed what might be expected in a sampling of the general population, 
and suggest a definite relationship between these conditions and the occurrence 
of organophosphate poisoning. It appears that these toxicants have an effect on 
renal function, amino acid, fat, and carbohydrate metabolism, and hematological 
response, and that a number of physiologic and biochemical functions are altered. 

Treament : Atropine alone was used in the treatment of 80 cases, and atropine 
plus 2-PAM in 38 cases. No record of therapy was available on 10 cases. 

Poison Control Center data indicated that there is much poisoning which 
is not reported. When all cases of reported poisoning were examined, it waa 
found that 62 percent were due to pesticides. Poisoning had steadily increased 
each year. Pesticides were the number two cause of poisoning among children; 
salicylates ranked first. These data are presented in Fig. 1. 

TABLE 2.-ABN0RIVIAL RESULTS OF ROUTINE LABORATORY TESTS 

Patients 



Percent Number 



Urine: 

Albuminuria (trace to 2+) 16 13 

Glycosuria without intravenous administration of dextrose (trace to 4+) 6 5 

Pyuria.. 4 3 

Ketonuria (trace to 4+) 12 9 

WBC: 

Leukocytosis (10,000) 10,300-25,300 31 24 

Leukopenia (6,000) 3,900-5,700 - 4 3 

8UMMAKY 

Review of hospital and Poison Control Center records in one area of South 
Texas revealed the occurrence of 129 well-documented cases of acute pesticide 
intoxication between 1961 and 1967. The majority of these cases occurred during 
the summer months and principally involved teen-age boys occupationally ex- 
posed by the dermal route. The signs and symptoms are those usually seen in a 
cholinergic crisis although tachyeardia and mydriasis are not uncommon. Cho- 
linesterase determinations are valuable laboratory aids in substantiating the 
clinical impression. Most i^atients received prompt medical attention including 
atropine sulfate and/or 2-PAM and recovered. 

Although data for 1967 are incomplete, indications are that the number of 
cases of pesticide intoxication in this area will be significantly less than the 
number in each of the preceding three years, despite the fact that organophosphate 
insecticides were used in about the same quanties as in 1965 and 1966. To mid- 
November, only six acute pesticide poisoning cases had occurred in the Lower Rio 
Grande Valley in 1967. All involved male workmen exposed dermally while 
handling organophosphate insecticides (methyl parathlon, 5 cases; Bidrin, 1 
case), and all patients recovered. Additional tabular data concerning these cases 
are available on request. 



3310 



CD' 



rm nil 




Fig. J. Distribution of cases by agent and year. Poison Control 
Center, Harlingen. 



3311 

Dr. Reich, Dept. of HEW, National Communicable Disease Center, Atlanta, Ga. 

30333. 
Dr. Gallaher, Poison Control Center, Harlingen, Texas 78550. 
Dr. Wiseman, Texas State Department of Health, 1100 W. 49th St., Austin, Texas 

78785. 

Bethesda, Md., August 1, 1969. 
Hon. Walter F. Mondale, 
Chairman, Subcoiiuuittec on Migratory Labor, 
U.S. Senate, Washington, D.C. 

Dear Senator Mondale : As a follow-up to discussions with your counsel, Mr. 
Chertkov, and Mr. J. B. Gordon, I am forwarding a summary of defensive 
measures against chemical warfare that are standard operating practice for 
the military. No classified information has been used to prepare the notes that 
follow. I should like to emphasize that I am neither discussing risks to the 
population that may arise from the storage, transportation, or testing of chem- 
ical or biological weapons, nor the pros and cons o:^ their development or de- 
ployment in the United States or other countries. My comments are solely in- 
tended to illustrate what can be done to protect the health and life of 
individuals and to carry on the work of the organization when the presence of 
poisonous substances is known or suspected. I should also like to emphasize 
that I am not a chemical or biological scientist but a systems analyst who is 
concerned with the subject of your hearings. My purpose in forwarding this 
description is to let you compare the military preparations for working in a 
hazardous environment with the precautions taken to protect the health and 
life of those workers and their families who are exposed to toxic substances 
defined by the statute as economic poisons. I assume that the similarity be- 
tween nerve gases and such organic phosphorous insecticides which can enter 
the body through the skin as TEPP or Parathion is known ; see references 
Nachmansohn, Chemical and Molecular Basis of Nerve Activity and TM 8-285, 
Treatment of Chemical Agent Casualties. 

Chemical warfare defense is best viewed as a system. A simple but adequate 
definition of a system is, "human, material and information resources, orga- 
nized for a purpose." The human resources include the skills to utilize infor- 
mation, i.e., procedures. A basic principle of chemical defense is the training of 
the individual and the unit, including instruction, exercises, and testing for re- 
quired proficiency. Such training includes the effects of chemical agents, their 
employment, detection and identification ; precautionary measures, first aid and 
casualty treatment, decontamination, and control. Control is an important ele- 
ment of preparedness because compliance with established procedures is essen- 
tial for the minimization of risk. Control includes policing of contaminated 
areas. Emphasis is placed on the establishing of proper safeguards for friendly 
troops when offensive chemical operations are to be undertaken, and compli- 
ance is assured by a system of standard procedures for preventive action, 
standard items of information to be acted upon, and carefully designed meth- 
ods and effective means for making that information available as rapidly and 
accurately as possible. Elements of information include safe downwind dis- 
tance and safe time, based on meteorological observations and calculations, 
weapons and delivery system error, and agent characteristics. 

The various items of individual protection equipment, chemical detection de- 
vices, specialized first aid and other treatment, and skills to use them are 
maintained in a state of readiness, and are double-checked when a need to use 
them is anticipated. Training is commensurate with the scope of responsibility, 
i.e., everyone should know how-to protect himself and to aid himself; unit pro- 
tection and defense is taught to unit leaders, etc. A relatively small number of 
specialists perform functions that require fulltime activity and special train- 
ing. Training and proficiency emphasize the need to know what to do and how 
to sense and identify chemical agents without warning and what to do when a 
chemical attack warning is communicated. This reduces the risks to health, 
life and operational effectiveness that arise out of a failure to act as pre- 
scribed, i.e., to have been surprised or made a mistake. 

Planning for chemical defense emphasizes the need to be prepared for the 
worst that could occur in a given local situation. This does not mean that oi> 
erations will be carried out under this assumption but that it represents a 
baseline from which protective measures will be relaxed as the actual situa- 



3312 

tion, as measured, permits — not the other way around. Planning for chemical 
defense assumes that water and food supplies will be exposed to contaminants, 
and makes provisions for testing for c