APPENDIX ii-AI: Blood Brain Barrier CCHE.

This information is copied from:




OCTOBER 30, 2001



Pesticides have a long history of detrimental, unintended consequences to human health, wildlife

and the environment. Pesticide use often kills natural predators and makes us more dependent on

pesticides. Pesticides are marketed widely before chronic health effects are properly assessed. It

often takes decades before regulators recognize health and environmental damage. Testing and

regulation of pesticides are woefully inadequate and slow. There is ample documentation in the

scientific literature that shows that pesticides can be harmful even at low levels, especially for

sensitive populations such as children. Surveillance, monitoring and research on low-level

exposures are needed. Significant data are being excluded in the current approaches to controlling

mosquito borne diseases and control for nuisance reasons. Pesticide risk assessments are based on

only a tiny part of the picture, and exclude consideration of critical data-gaps. The threat of

mosquito-borne disease is often exaggerated. The public is often misled about the safety of



A serious and thoughtful Integrated Pest Management program (IPM) should be implemented for

mosquito control. A true IPM program emphasizes that least-toxic alternatives be used at every

opportunity. IPM makes special emphasis on a prevention component that includes an expanded

public education campaign promoting awareness and community participation. This is especially

important because many people breed mosquitoes unknowingly on their own properties. IPM also

includes enhancement and preservation of natural predators such as dragonflies and fish. Instead

of toxic pesticides, greater reliance on use of larvicides such as BTI (Bacillus Thurengiensis

Israelensis) in temporary bodies of standing water is advisable. BTI and other larvicides are not

recommended for ponds and lakes where there are predators such as fish and dragonflies. The

spraying of pesticides should be done only in very limited and specific situations as a last resort,

when stationary sentinel animals are found infected with arthropod-borne diseases. In these cases

only a very limited amount of spraying should occur in the immediate area around the outbreak.

In those instances, only least toxic pesticides that have the least impact on humans, wildlife and

the environment should be used. The public should be told of the potential risks of pesticides, and

notified when spraying is to occur.


Nearly 100 pesticides have already been banned or severely restricted by the Environmental

Protection Agency (EPA) because of serious health and environmental damage. (1) Many

dangerous pesticides are still on the market. The pesticide chosen for local aerial spraying for

mosquito control of West Nile Virus (WNV) is on a list of highly toxic pesticides currently being

re-evaluated by the EPA. This process will take a long time. Considering that the Centers for

Disease Control and Prevention (CDC) estimated that only one-in-a-million mosquitoes carries

WNV, and that all mosquito borne-illnesses are extremely rare in this country-it would be wise to

severely restrict the use of toxic pesticides.

This past summer, North Florida experienced an onslaught of heavy rains and a migration of

birds infected with West Nile Virus (WNV). Then came a Medical Alert from the State of Florida

Health Department and news from the Department of Agriculture and Mosquito Control that they

would be spraying pesticides by plane and by truck. It was difficult not to see the irony --that

pesticides would be sprayed over hundreds of square miles -- in the name of public health.

Citizens aware of chronic health problems caused by pesticides tried to understand why most

residents are content with the spraying. The answers now seem obvious. The

chemical/pharmaceutical industry spends billions of dollars on advertising promoting the notion

that its products are "safe," and the public is rarely exposed to the concept that pesticides can

cause a wide array of environmental and health problems.

Scientific data indicate clear links between many pesticides and chronic illness, immune

dysfunction, (1a) (2) developmental, learning and behavioral disabilities, and birth defects and

brain damage. (3) (4) Uninformed of these negatives, and exposed to exaggeration about the

threat of WNV, (5) (6) the public actually asks to be sprayed.

Most people believe that pesticides have been properly tested for human health impacts. Actually,

nothing could be further from the truth. Pesticides are not tested and regulated like drugs, and it is

the chemical/pharmaceutical pesticide manufacturers that test pesticides and conduct their risk

assessments - not the Environmental Protection Agency. (6b)

For the more than 600 older pesticides currently on the market, only very limited information was

required prior to their registration. Testing requirements were inadequate and focused mainly on

acute effects such as how much of the pesticide it takes to kill a rat. Most importantly, almost no

testing was done for chronic health effects such as neurological damage. Despite critical datagaps,

pesticide companies went forward and conducted risk assessments based on inadequate

information -- and the pesticides were widely distributed.

The new federal pesticide regulations require pesticides to be more thoroughly tested prior to

marketing. The older ones will be required to undergo re-registration and new testing, but of

these 600 plus older pesticides, only six have completed this new process. Despite these

problems, the public is often given false assurances of safety (7)

Once on the market, it often takes decades for unintended consequence incidents to be identified

and evaluated, and for scientific data to be made public. For decades the EPA and Congress have

received reports that neurotoxins such as pesticides can cause brain and central nervous system

damage. (8) Children are of special concern because organophosphates (OPs), the most widely

used class of pesticides, have been shown to damage the developing brain. (9) EPA says concerns

raised by this information are "supported by other literature." (10) Despite this knowledge, it was

1999 before the EPA began requiring scientific studies relating to pesticide effects on the brain.

The concern over this class of OP pesticides has been mounting and as early as 1998 the EPA's

Office of Pesticide Programs warned industry leaders "to start thinking about alternative

registrations" to OPs. Soon afterwards Novartis announced it would "terminate production of

OPs." (11) Other companies like those that manufacture the OP pesticides Dursban and Diazinon,

quietly agreed to severely restrict or phase out these products so they will not have to produce

newly required brain studies. (12) (13) But not all companies did this.

The EPA's regulatory machinery moves very slowly and the chemical/pharmaceutical industry

that produces pesticides, is very powerful. Despite mounting evidence of their harmful effects, it

took the EPA decades to finally achieve restriction of Dursban and Diazinon under the Food

Quality Protection Act. The Act seeks to prevent damage to children's health from pesticide

exposure. Dursban and Diazinon are from the same class of pesticides as Dibrom --the pesticide

sprayed by plane in North Florida for mosquito control.

Dibrom, also known as Naled, it is also under EPA scrutiny. There is no way for the public to

know when its re-assessment will be completed. EPA just disclosed the delay of its interim report

and says that only the study protocol for the required brain study has been submitted so far. (14)

According the federal agency watchdog, the U.S. General Accounting Office (GAO), the public

may have to wait a long time because action on pesticide products is often delayed for decades.


There is much that the scientific community does not know about the long term health effects of

the synthetic chemicals that are being found in the public's blood --a body-burden that we all

share, (16) (17) but there is ample, scientifically valid data that shows that pesticides can be

damaging to human health and the environment. This makes it especially troubling to repeatedly

hear the word "safe" when they are described. Federal law prohibits manufacturers and

distributors from directly or even indirectly suggesting that pesticides are "safe."(18) (19) Claims

may not differ from those found on the product label. Nowhere on the Dibrom label does it say it

is safe, even if used according to its instructions. (19a)

Florida health and mosquito control officials could benefit from the experience of New York

where health officials have been dealing with WNV for three years. There officials initially

sprayed OP pesticides after the outbreak, but by the end of the mosquito season there came a

surprise twist: The New York Department of Health declared that more people got sick from

pesticide exposure from mosquito control than from the WNV. (20)

By the end of the second year the WNV rhetoric had cooled down all along the eastern seaboard.

Dennis McBride, director of the North Carolina Health Department dared to call WNV "a mild

disease". (21) The Maine Environmental Policy Institute came out with a report entitled

"OVERKILL" that criticized the use of pesticides for combating WNV, followed by appended

versions of this same document from both Connecticut and Massachusetts. (22) It was time for

some balance and perspective. Some people had begun to notice that in 1999, the first and worst

year of New York's WNV epidemic, that only 7 people died from WNV while 2,474 people died

from the flu. (23)

New York officials dramatically changed course by stopping the use of OP pesticides. They also

decided to greatly expand the use of bacterial larvicides like BTI (Bacillus Thurengiensis

Israelensis) that has a much higher safety threshold for humans and wildlife. The N.Y.

Department of Health also greatly increased public education on how individuals can take

personal responsibility for control and avoidance of mosquitoes by use of repellents, proper

clothing and by eliminating breeding sites around properties. As a last resort, officials will only

spray Pyrethroid pesticides in a limited area immediately around WNV outbreaks. (24)

By spraying we may not see as many mosquitoes, but there is a price to pay both in terms of

human health and the loss of countless other creatures. Florida does not have an effective

pesticide illness or pesticide death-monitoring program for humans or other non-target species.

Data being collected are primarily limited to acute exposures of migrant farm workers, and

evident pesticide suicides. No attention is given to low-level exposure effects. If no one is

looking for negative effects, how can we make wise decisions in the future? Florida does not

have anyone like New York state wildlife pathologist Dr. Ward Stone. When he tested dead birds

that were turned into his lab, he found that far more of them had died from pesticide poisoning

than from WNV. (25)

And humans may become more at risk for WNV when exposed to pesticides. Many studies have

shown that pesticides compromise the immune system. (26) (27) Given that we need an intact

immune system to combat all illnesses including WNV, the logic to use pesticides seems

somehow perverse. New York Health Department data show that most of the people who died of

WNV had pre-existing weak immune systems because they had diseases such as AIDS and

cancer. (28) Random blood samplings in New York showed that most healthy persons who tested

positive for WNV antibodies were surprised because they either had mild symptoms or no

symptoms at all. (29)

Research shows that WNV does not become life threatening until it crosses the brain's protective

shield. The spraying of pesticides may actually increase the probability that WNV develops into a

life-threatening disease because pesticides and other toxic chemicals can breech the blood-brain

barrier and may leave us more susceptible to viruses. (30) (31)

Humans sometimes forget that we are a part of the ecology and dependent on it in countless

ways. Scientists claim that if we leave nature alone, it will take care of 95% of the mosquitoes for

us. (32) Each time we spray toxic chemicals the balance of nature gets disrupted and many nontarget

organisms are sickened and killed, including one of our best allies - the

dragonfly. But when we kill dragonflies with pesticides their populations are slow to recover. A

dragonfly takes from 1 to 3 years to pupate. It only takes from 3 days to 3 weeks for mosquitoes

to reach the adult state. Even the dragonfly nymphs eat mosquito larvae and here in dragonfly

country, one hundred dragonflies can eat 1.5 million mosquitoes a month!

(1) United States Environmental Protection Agency (USEPA). EPA List of Pesticides Banned

and Severely Restricted in the U.S. found at the following EPA web sites:

Newly Restricted:

Voluntarily withdrawn:

(1a) Immune parameters in biological monitoring of pesticide exposure: current knowledge and

perspectives; Colosio C., Corsini El, Barcellini W., Maroni M.; International Centre for Pesticide

Safety, Milan, Italy. Toxicol Lett 1999 - Sep 5:108 (2-3):285-95

(2) Environmental Immunotoxicology. Environmental Medicine, S.M. Brooks, M. Gochfeld, J.

Herzstein, R.J. Jackson, and M.B. Schenker, Editors; Mosby-Year Book, Inc., St. Louis,

Missouri, pages 139-155, 76 references, 1995

(3) In Harm's Way: Toxic Threats to Child Development; Ted Schettler MD, MPH, Jill Stein

MD, Fay Reich PsyD, Maria Valenti, David Wallinga MD; A report by Greater Boston

Physicians for Social Responsibility, May 2000

(4) The Washington Post. Chemicals and the Developing Brain, Judy Mann, Jun 14, 2000


(5) Public statement by Lisa A. Conti, DVM, MPH, state public health veterinarian, Florida

Department of Health at the Jefferson County Courthouse public meeting

on July 16, 2001. When asked what percentage of persons die from West Nile Virus infection,

Dr. Conti said "an average of 15%."

(6) Public statement made by Dr. Steven Wiersma, M.D., Florida Department of Health

epidemiologist on local public radio program Family Forum Live on August 22, 2001. Dr.

Wiersma stated that the percentage of persons who die from West Nile Virus infection ranges

from 12-15%.

(6a) Life's Delicate Balance: Causes and Prevention of Breast Cancer. Dr. Janette D. Sherman,

MD. Page 204, paragraph 5; Taylor and Francis Publishers, 1999

(7) U.S. General Accounting Office. Non-Agricultural Pesticides, Risks and Regulation; April


(8) Neurotoxins: At Home and in the Workplace; Report to the Committee on Science and

Technology, U.S. House of Representatives, June 1986.

(9) Mehl, Anna et al. The effect of trichlorfon and other organophosphates on prenatal brain

development in the guinea pig. Neurochemical Research, 19(5). 569-574, 1994.

(10) U..S. Environmental Protection Agency, Office of Pesticide Programs, Health Effects

Division (7509C); Report entitled "Human Health Risk Assessment - Dichlorvos (DDVP); page.

3, paragraph 1, line 6.

(11) Alabama Pesticide Information State Headquarters, Extension Pest Management Newsletter.

Vol.2, No.4, 19 June 98 "EPA Officials Tells (sic) Industry to Look for OP Alternatives" and

"Novartis to Terminate Production of OPs"

(12) ENVIRONMENTAL PROTECTION AGENCY (EPA) Federal Register: December 6, 2000

Chlorpyrifos (Dursban, Lorsban); Cancellation Order (Volume 65, Number 235)] [Notices]

Page76233-76240 from the Federal Register online GPO Access []

[DOCID:fr06de00-63] [OPP-34203F; FRL-6758-2]

(13) ENVIRONMENTAL PROTECTION AGENCY (EPA) Federal Register: May 30, 2001

Diazinon; Receipt of Requests for Amendments and Cancellations (Volume 66, Number 104);

[Notices] [Page 29310-29313] From the Federal Register Online via GPO Access

[] [DOCID:fr30my01-50] [OPP-34225E; FRL-6785-2]

(14) Dennis Utterback, EPA Chemical review Manager; Special Review and Reregistration

Division; Office of Pesticide Programs in a personal e-mail. Contact: Dennis Utterback: (703)

305-0076 or FAX: (703) 308 8041 or

Utterback/DC/USEPA/US@EPA and

(15) U.S. General Accounting Office. 1986. Pesticides: EPA's formidable task to assess and

regulate their risks. Washington, D.C. (April.)

(16) Centers for Disease Control National Report on Human Exposure to Environmental

Chemicals; 3.21.01

pgs, 1,2,3, 6

(17) Science News, September 24, 1983"Pesticides: The Human Body Burden", pg. 199

(18) Federal Insecticide, Fungicide and Rodenticide Act, 7 USC '136j, federal

pesticide regulations at 40 C.F.R. 162.10(a)(5)(ix)

(19) U.S. General Accounting Office, Non-Agricultural Pesticides, Chap. 3, "The General Public

Receives Limited and Misleading Information on Pesticide Hazards, pg.35, GAO/RCED-86-97

(20) Albany Times Union, "Feeling the Sting of West Nile Spraying", Friday, June 15, 2001; also

available via world wide web at:


(21) North Carolina Department of Health and Human Services Press Release; Oct 20, 2000

(22) OVERKILL: Using pesticides to control West Nile Virus mosquitoes in Maine

may do more harm than good Prepared by the Maine Environmental Policy Institute

May 2001. This report was also adapted and re-written to fit the states of Connecticut and


(23) New York City Department of Health Office of Public Affairs Press Release, Friday, Dec/

29, 2000 (212) 788-5290 entitled, "FLU SEASON PICKING UP IN NEW YORK CITY; NEW


(24) State of New York Department of Health: " Health Officials Unveil 2001 West Nile Virus

Response Plan: Education, Prevention Remain Key Components of Fight Against Mosquitoborne


(25) THE RECORD - TROY, NY., dated June 3, 2001 and entitled: "TOXINS KILLING

BIRDS" by Michael Gormley -- Associated Press.

(26) The Immunotoxicity of Selected Environmental Chemicals, Pesticides and Heavy Metals.

Exon JH. Prog Clin Biol Res 1984; 161:355-68

(27) The Effects of Pesticides on Human Health, S.R. Baker and C.F. Wilkinson, Editors;

Princeton, Princeton Scientific Publishing Co., Inc., pages 262-295, 107 references, 1990

(28) New York City Department of Health information newsletter on West Nile Virus; page 2,

May 2000

(29) The Lancet. Epidemic West Nile encephalitis, New York, 1999: results of a household-based

seroepidemiological survey Farzad Mostashari, Michel L Bunning, Paul T Kitsutani, Daniel A

Singer, Denis Nash, Michael J Cooper, Naomi Katz, Karen A Liljebjelke, Brad J Biggerstaff,

Annie D Fine, Marcelle C Layton, Sandra M Mullin, Alison J Johnson, Denise A Martin, Edward

B. Hayes, Grant L Campbell Volume 358 Issue 9278 Page 261

(30) Ben-Nathan, D. et al. (1996). West Nile virus neuroinvasion and encephalitis induced by

macrophage depletion in mice. Arch. Virol. 141: 459-469.Ben-Nathan, D. et al. (2000). CNS

penetration by noninvasive virus following inhalational anesthetics. Ann.

N.Y. Acad. Sci. 917: 944-950.

(31) Gupta, A. et al. (1999). Effects of pyrethroid-based liquid mosquito repellent inhalation on

the blood-brain barrier function and oxidative damage in selected organs of developing rats. J

Appl. Toxicol. 19: 67-72.

(32) Mosquito Control Alternatives for the New Millennium, Charlie D. Morris, Ph.D., Florida

Medical Entomology Laboratory, IFAS-University of Florida, Vero Beach, April 1991, page 6.