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Authors: E. G. Vallianatos

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10
   Cited in a memorandum of William Dickinson, Deputy Director, Special Pesticide Review Division, to Edwin Johnson, Director, Office of Pesticide Programs, EPA, February 22, 1982. See also EPA position document 2/3, dated December 12, 1980, stating that toxaphene ought to be banned for all uses except for cattle dip.

 
11
   Memo from David Severn and Joseph Reinart, February 16, 1982.

 
12
   Congressional Record, August 11, 1982, p. H5670. See also press release by the office of Congressman Yates: “Yates Reveals New Threat to Lake Michigan—Proposes Ban on Insecticide [Toxaphene] Found in Great Lakes Fish,” July 23, 1982; Irvin Molotsky, “E.P.A. Plans to Curb Use of Toxaphene, a Pesticide,” New York Times, October 17, 1982.

 
13
   See Cook memo to his colleagues on September 21, 1983.

 
14
   See Rosmarie von Rumker’s July 1974 study, “Farmer’s Pesticide Use Decisions and Attitudes on Alternate Crop Protection Methods.”

Chapter 11: The Hubris of the Reagan Administration

 
  
1
   See “Results of National Urban Pesticide Applicator Survey by EPA,” 1984.

 
  
2
   See EPA report, “National Household Pesticide Usage Study, 1976–1977.”

 
  
3
   Note from James Touhey to Edwin Johnson, September 7, 1983. Touhey was then the director of the Benefits and Use Division, OPP, EPA, and Johnson was the deputy assistant administrator or director, OPP, EPA.

 
  
4
   Adrian Gross long ago showed that malathion and its oxygen analogue, malaoxon, cause cancer in both rats and mice. He also demonstrated that people eat five times more malathion per day than the maximum permissible level, and he warned that as many as four people per thousand are in the upper limit of possibly getting cancer from malathion. Adrian Gross, “Carcinogenicity of Malathion” (memorandum to Kevin Keeney through James Touhey, April 24, 1984, Office of Pesticides and Toxic Substances, U.S. EPA).

 
  
5
   Joel A. Mintz,
Enforcement at the EPA: High Stakes and Hard Choices
, revised edition (Austin: University of Texas Press, 2012), 42.

 
  
6
   William Sanjour, “In Name Only,”
Sierra
, September/October 1992, 99.

 
  
7
   “Anne Gorsuch Buford, 62, Dies; Reagan EPA Director,”
Washington
Post
, July 22, 2004.

 
  
8
   
Sarasota Herald-Tribune
, May 19, 1983.

 
  
9
   Richardson discussion with the author, September 22, 1983.

 
10
   Martin Crutsinger, “Reagan Orders Full Probe of EPA,” Associated Press, February 17, 1983.

 
11
   See the August 1984 report “Investigation of the Environmental Protection Agency.”

 
12
   EPA, “National Nursery Pesticide Usage Survey” (1984).

 
13
   EPA, “Health Assessment of Pesticide Applicators in an Enclosed Environment” (1984).

 
14
   EPA, “A National Survey of Pesticide Usage of Golf Courses in the U.S.” (1984).

 
15
   Ibid.

 
16
   EPA, Office of Pesticide Programs, “R.E.D. Facts: Thiram,” September 2004.

 
17
   National Corn Growers Association, “World of Corn,” 2013.

 
18
   See “Minutes for the First Meeting of the Interagency Task Force on Seed Treatment” (September 11, 1986, OPP, EPA); Edwin Tinsworth, “Note to Douglas Camp” ([1986], OPP, EPA); Eugene Wilson, Product Manager, Fungicide-Herbicide Branch, Registration Division, “Chronology of Recent Meetings Regarding Detreated Seed Corn” (memorandum to Frank Sanders, Chief, Fungicide-Herbicide Branch, Registration Division, OPP, EPA, January 27, 1987). Wilson wrote: “Illegal residues of heptachlor in milk reported by FDA [U.S. Food and Drug Administration] in 1986 were a result of feeding [the fungicide] captan and heptachlor detreated seed corn to dairy cows.”

 
19
   EPA, “Environmental News,” September 10, 1976; testimony of Jack Griffith, Office of Pesticide Programs, to the Subcommittee on Health and Scientific Research, Committee on Human Resources, U.S. Senate, June 8, 1977.

 
20
   EPA, “Pesticide and Toxic Substance Residues in Humans from the Second Health and Nutrition Examination Survey, 1976–1980,” October 1983.

 
21
   John A. Todhunter received a Ph.D. from Berkeley in 1976. According to the American Presidency Project, he was a fellow at the Roche Institute of Molecular Biology, Hoffmann La Roche, Inc. When appointed to EPA on November 13, 1981, to the EPA, he was an assistant professor of biology at the Catholic University of America. He was fired on March 25, 1983.

 
22
   Edwin L. Johnson, “PCB’s in Human Blood Serum,” note to Don Clay, June 20, 1984. Johnson and Clay were senior officials at EPA.

 
23
   See Nicole Ostrow, “Exposures to Pesticide in Utero Linked to Brain Abnormalities,”
San Francisco Chronicle
, April 30, 2012.

 
24
   John E. Davies, “Communities Studies and Pesticides” (progress report to EPA, December 20, 1971).

 
25
   Mark R. Powell,
Science at EPA
(Washington, DC: Resources for the Future, 1999), 297.

 
26
   See Philip Shabecoff, “U.S. Officials Faulted for Talks over Pesticide Ban,”
New York Times,
January 30, 1984, http://www.nytimes.com/1984/01/31/us/us-officials-faulted-for-talks-over-pesticide-ban.html. See also “Possible Destruction of EPA Dagat Under Inquiry,”
New York Times,
March 9, 1983, http://www.nytimes.com/1983/03/09/us/possible-destruction-of-epa-data-under-inquiry.html.

 
27
   See Martin Crutsinger, “Three More EPA Officials Asked to Resign,” Associated Press, March 25, 1983, http://news.google.com/newspapersnid=1665&dat=19830325&id=5HEjAAAAIBAJ&sjid=NiQEAAAAIBAJ&pg=6636,3685204. See also http://www.nytimes.com/1983/03/25/us/acting-epa-chief-is-said-to-be-ready-to-quit-post-today.html. See also http://www.highbeam.com/doc/1G1-4811096.html.

 
28
   See “Ex-E.P.A. Official Says Pressure Didn’t Delay Action on Pesticide,”
New York Times
, September 27, 1983
.
See also “Possible Destruction of E.P.A. Data Under Inquiry,”
New York Times
, March 9, 1983, http://www.nytimes.com/1983/03/09/us/possible-destruction-of-epa-data-under-inquiry.html. See also Lloyd Tataran,
Formaldehyde on Trial: The Politics of Health in a Chemical Society
(Lorimer, 1983), p. 129. See also “The EPA Wasteland,”
New York Times,
February 26, 1983, http://www.nytimes.com/1983/02/26/opinion/the-epa-wasteland.html.

Chapter 12: From Reagan to Bush

 
  
1
   For a link to a brief history of rice production in the Missouri Bootheel, see http://agebb.missouri.edu/rice/ricehist.htm.

 
  
2
   The major source of PCB pollution, General Electric, while fighting every step of the way, was ultimately forced to engage in a massive cleanup of the Hudson.

 
  
3
   Ambush is not a benign compound: Permethrin’s links to cancer seemed to be “many-fold more ‘significant’ than indicated either in the superficial and flawed Hazard Evaluation Division’s reviews or for a number of pesticide products which have in the past been suspended or canceled by the EPA,” Adrian Gross wrote. EPA scientists who reviewed permethrin relied on “misleading” information they received from the owners of the insecticide, Gross said. Since the 1980s, we have learned that permethrin, a chemical belonging to the synthetic pyrethroids, combines the ecocidal effects of DDT with the crippling and dehumanizing power of a central nervous system toxin. January 19, 1981, letter from Adrian Gross to Patricia Critchlow of the Registration Division of the Office of Pesticide Programs of EPA.

 
  
4
   Section 18 also opens another route for the expedited delivery of toxins: the so-called crisis exemption. With this rule, farmers (again represented by the governors of their states) are allowed to use untested and unregistered toxins, including poisons like DDT that EPA banned in 1972; some of these chemicals are suspected to be carcinogenic, or have been taken off the market by the EPA.

 
  
5
   Douglas D. Campt, “Five Year Review of 40 CFR Part 166” (action memorandum to John A. Todhunter, March 4, 1983).

 
  
6
   EPA, Office of Pesticide Programs, Registration Division, “Audit of Emergency Exemption and Special Local Needs Programs” (March 1983); “A Review of the Emergency Exemption Program” (March 1987).

 
  
7
   Dodd letter to Clay, June 29, 1983.

 
  
8
   See U.S. EPA, “Regional Environmental Management Reports,” 1983.

 
  
9
   U.S. Fish and Wildlife Service, Office of Migratory Bird Management, Pesticides and Birds, March 2000.

 
10
   Rebecca Clarren, “Pesticide Drift,”
Orion Magazine
, July/August 2008.

 
11
   Lynne Peeples, “Pesticide Drift, Sick Rural Residents Force Face-Off with Big Agriculture,”
Huffington Post
, July 23, 2012.

 
12
   Brad Balukjian, “Pesticides found in frogs far from crops,”
Los Angeles Times
, July 29, 2013.

 
13
   Anne C. Mulkern, “Pesticide Industry Ramps Up Lobbying in Bid to Pare EPA Rules,”
New York Times
, February 24, 2011.

 
14
   PEER press release, “NJ DEP Employees Say Whitman Administration Soft on Polluters,” December 22, 2000.

 
15
   Schaeffer resignation letter, February 27, 2002.

 
16
   Although federal and Supreme Court judges leaned on the EPA to enforce the law—especially the 1970 Clean Air Act—Bush’s EPA remained firmly in the grip of the energy industry. Judges ordered the EPA to require factories under renovation to upgrade pollution control technologies and (in the case of coal-fired power plants) to reduce their emissions of mercury, a brain poison. The Supreme Court even ordered EPA to start regulating greenhouse gases from cars. See Schaeffer’s article, “Clearing the Air,” in the July/August 2002 issue of the
Washington Monthly
.

 
17
   See note from Lyons Gray, EPA Chief Financial Officer, to his senior colleagues, June 8, 2006. Bush pulled similar tricks at the U.S. Forest Service, weakening or eliminating the government’s protection of forests and easing restrictions on the timber industry.

 
18
   Brian Litmans and Jeff Miller, “Silent Spring Revisited” (Center for Biological Diversity, San Francisco, 2004), 58–60.

 
19
   Joe Eaton and Ron Sullivan, “Silent Spring for Bay Area Raptors?”
San Francisco Chronicle
, May 11, 2012.

Chapter 13: The Obama Administration: Yes, We Can?

 
  
1
   Dina Cappiello, “EPA Tells Nation’s Dirty Power Plants to Clean Up,” Associated Press, December 21, 2011.

 
  
2
   See letter, “Dear President-Elect Obama and Members of the Transition Team,” signed by 102 organizations, dated January 9, 2009.

 
  
3
   Bill Moyers and Company, “Crony Capitalism,” January 20, 2012, PBS.

 
  
4
   
Friends of the Earth Newsmagazine
, Fall 2009, p. 2.

 
  
5
   See CBS News, “Critics Slam Obama for ‘Protecting’ Monsanto,” March 28, 2013, http://www.cbsnews.com/8301-250_162-57576835/critics-slam-obama-for-protecting-monsanto/.

 
  
6
   “Wikileaks Cables,”
Democracy Now!
December 23, 2010.

 
  
7
   In the Supreme Court of the United States,
Monsanto Company et al., Petitioners, v. Geertson Seed Farms et al
. On Writ of Certiorari to the U.S. Court of Appeals for the Ninth Circuit, Brief for the Federal Respondents Supporting Petitioners, Elena Kagan, Solicitor Genera, March 2010. See also “Elena Kagan: Toward a Pro-GM Supreme Court?”
The Atlantic
, May 12, 2010.

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