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J.Entomol.Soc.Brit.Columbia109,December2012 3 FORUM ^Cosmetic' Pesticides: Safe to Use by Professionals and Homeowners JOHN HOLLAND' J. The Special Committee on Cosmetic CCS is a fiind-raising advocacy association, Pesticides was instituted by the British not a scientific organization. Columbia government to investigate whether Atenet ofepidemiology is that correlations or not pesticides can be used safely for the cannotprove causation.As well, epidemiology protection ofornamental plants and turf. After cannot prove biological plausibility. hosting numerous presentations in order to Toxicological confirmation is required in gain a fundamental understanding ofthe issue, order to illustrate plausibility, and none exists the Committee recently concluded that there to substantiate the suggestion that 'cosmetic' existed no scientific grounds to prohibit the pesticides cause cancer. Furthermore, no products (Bennett, 2012). Representatives of 'cosmetic' pesticide registered in Canada Health Canada's Pest Management Regulatory today has been determined to be carcinogenic Agency (PMRA), the agency responsible for by any regulatory agency in the world. The ensuring the safety of pesticides, appeared CCS, which has done much good work in the twice and also provided written responses to past, would seem to have lost its way on this two submitted lists of questions. Dr. Keith issue, perhaps preferring to follow opinion Solomon, one of Canada's most ratherthan science. internationally respected toxicologists and In response to a written question submitted acclaimed expert on pesticides, answered by the Committee on April 30, 2012, the PMRA committee questions by conference call. stated that "(w)hen determining the Many presenters were opposed to the use acceptability of a pesticide, PMRA scientists ofpesticides. Unfortunately, none ofthem had critically examine the totality ofthe scientific a background in toxicology or the necessary database for pesticide active ingredients and expertise in pesticide science. The Canadian end-use products, including the Cancer Society, one ofthe organizations most epidemiological studies in the OCFP (Ontario vocal in opposing pesticides, presented on College of Family Physicians)." This could November 8, 2011, with Kathryn Seely (CCS certainly help explain the difference between Public Issues Manager) stating that the the conflicting stances of the PMRA and the Society had "weighed the growing body of CCS: the PMRA considers all the evidence, evidence that's suggestive." But therein lays including toxicology, not just a few selected the problem: the CCS seems to regard as epidemiological studies. trustworthy only selected and weak In 2007, a report by the World Cancer epidemiological studies that fit preconceived Research Fund International and theAmerican notions concerning the 'dangers' ofpesticides. Institute for Cancer Research outlined the The Society has managed to collect 200 or so results ofa five-year review by nine teams of selected epidemiological studies with weak international cancer experts. One ofthe main correlations; but compare these to the findings is as follows: "There was no 23,000,000 pages of proprietary scientific epidemiological evidence that current studies alone which the PMRA uses to assess exposures to pesticides cause cancer in pesticide safety (as explained by the PMRA's humans" (WCRFI and the AICR, 2007). The Jason Flint - Director, Policy and Regulatory same report maintains that it is necessary to Affairs Division - in the January 17, 2012 enroll 10,000 to 100,000 or more subjects in a presentation to the committee). Also not study, in order "to have sufficient statistical understood by many Canadians is that the power to identify factors that may increase cancer by as little as 20 to 30 per cent." The 'CommunicationsDirector,IntegratedEnvironmentalPlantManagementAssociationofWesternCanada 4 J.Entomol.Soc.Brit.Columbia109,December2012 studies promoted by the CCS and other anti- to be carcinogenic to humans as pesticide organizations generally have well. So they are well understood considerably less than 2,000 subjects enrolled. predictors of potential human Because epidemiological correlations are toxicity, and those are the models based on statistics, many subjects are required that are well worked out and used for to provide some assurance that links are not toxicity testing. merely chance occurrences. Some medical associations have joined The ongoing American Health Study with the CCS to oppose pesticides. (AHS) was initiated in 1994 and is the largest Unfortunately, physicians generally have continuous epidemiological study ever neither the scientific nor toxicological undertaken on the possible effects of expertise that must be gained over years of pesticides. It has 89,000 Iowa and North postgraduate studies and experience, and the Carolina farmers, spouses, and commercial position of a medical association's board of applicators enrolled, in order to examine possible causes ofdiseases - including cancer. directors does not necessarily represent that of In a review of the findings of the AHS, the the majority ofits members. The 'viable' organic alternatives, suggested PMRA's Dr. Scott Weichenthal stated at a by those opposed to conventional products, 2009 Heath Canada meeting in Winnipeg that are much more expensive, very labour- "current occupational exposure levels are not intensive, and do not workvery well - ifat all. expected to result in increased risks ofadverse As Health Canada states, "(i)n most cases, health effects." If occupational exposures to efficacy data requirements for non- pesticides were not creating adverse health conventional products will be less than for effects, why would homeowners and others conventional pest control products and the with extremely limited exposure to pesticides establishment of a lowest effective rate (such develop them? as is required for conventional products) will proAhsibiatnioothne,r tohfeitsCCstSatedsayresasotnhsatforthea not be needed. The PMRA recognizes that some non-conventional products may not be International Agency for Research on Cancer as efficacious as conventional (lARC) finds that pesticides can be products" (Health Canada, undated). carcinogenic. What is not mentioned, A ban of 'cosmetic' pesticides in B.C. however, is that none of the recognized would result in a duplication of Ontario's carcinogenic pesticides are registered for use experience: parks so full of weeds that they in Canada. And, according to a recent report cannot be used, lawns destroyed by grubs, and by the IARC, "(v)ery few currently available ornamentals lost to insects and disease. The pesticides are established experimental next time you hear of a study about the carcinogens, and none is an established human 'danger' of pesticides, you should ask the carcinogen. Studies in humans have failed to following two questions: (1) is the study provide convincing evidence of an increased epidemiological and, ifso, how many subjects risk, even in heavily exposed groups" lARC, ( were enrolled?; and (2) does toxicology 2007). In the words of Dr. Connie Moase PMRA confirm the biological plausibility of the (Director, Health Evaluation suggested correlation? Directorate) in her appearance before the Removing useful products that can be used Committee onJanuary 17, 2012: safely - merely because weak epidemiological For any known human studies are proffered as evidence (without carcinogen, whatever the chemical toxicological findings to substantiate might be - I'm not speaking directly correlations) - is not part of a scientific to pesticides - the animal models process. Fortunately, the Special Committee that have been used have shown to on Cosmetic Pesticides made a decision based be positive for anything that's known on science, not opinion. REFERENCES Bennett, Bill. 2012 (May 17). Report ofthe Special Committee on Cosmetic Pesticides. Ministry ofEnvironment, GovernmentofBritishColumbia,Canada. 118 pp. J.Entomol.Soc.Brit.Columbia109,December2012 5 Health Canada. Undated. Guidelines forthe registration ofnon conventional pest control products, http://www.hc- sc.gc.ca/cps-spc/pubs/pest/j3ol-guide/dir2012-01/index-eng.php (lARC) International Agency for Research on Cancer. 2007. Attributable causes ofcancer in France in the year 2000. WorldHealthOrganization, Switzerland. (WCRFI) World Cancer Research Fund International and the (AICR) American Institute for Cancer Research. 2007. Food, nutrition, physical activity and the prevention ofcancer: a global perspective. American Institute forCancerResearch,Washington,DC. Disclaimer The BC Cancer Agency was also asked to write a Forum article on the topic of cosmetic pesticides. We hope to run their contribution to this discussion in an upcoming ESBC publication. JESBC Forum articles express the opinion of the author(s) and do not necessarily reflect the views of the Entomological Society of British Columbia. Forum pieces are presented to stimulate discussion on matters related to entomological research and practice, andwe invitepotential authors to contactus with ideas for future Forum articles.