Testing Pesticides on Human Subjects

November 28th, 2001

Dear President Bush and Administrator Whitman;

I felt compelled to write concerning this admnistration’s reversal of policy on the use of test data from human subjects with regard to pesticide products. The implications of such a policy reversal are many and I will mention only a few of them:

1. Acceptance of such data is contradictory to the administration’s highly publicized position on morality with regard to human experimentation. When cells from unborn humans and animals are considered “off limits” for use in medical research, one wonders how the feeding of registered poisons to adult humans can be acceptable practice in our society. These living, breathing souls can have absolutely no idea of the risks they are undertaking in exchange for a few dollars.

2. Acceptance of such data is unscientific in the manner in which subjects are selected, tested and findings extrapolated to pesticide-exposed populations Inadvertent pesticide poisoning is frequently the result of inhalation and dermal contact with the poisons. Ingestion tends to be a smaller part of the equation. It is impossible to quantify the dose of the toxicants absorbed by the victim as rates of detoxification and excretion vary from person to person. Furthermore, humans are too diverse in the ways in which they tolerate toxicants, The pool of willing subjects to undergo such testing cannot possibly be representative of our society. I doubt the testers can accept more vulnerable parties as test subjects: h elderly; the infirm; pregnant women or children etc. Interestingly enough, the vulnerable populations make up the majority of exposed persons!

3. Acceptance of such data is harmful to test subjects beyond the capacity of testing companies to warn, monitor or compensate victims of this form of “employment”. I am one of an estimated 16 percent of the population who is deficient in an enzyme, paroxonase, which predisposed me to being damaged by Dursban and Diazanon. No one can know how much was “too much” for my system which became sensitized to those and other chemicals as a result of repeated exposures. WIll test subjects be screened for their status in detoxification enzymes and amounts of protective antioxident materials (such as retinoic acid) in their systems? Will the introduction of poisons deplete reserves of these vital materials in their bodies causing long-term adverse effects in endocrine, reproductive or digestive functions? Will subjects be screened for exposure to other chemicals and stressors which can lead to increased permeability of the blood – brain barrier and subsequent neurological damage? Will future offspring of volunteers be monitored for congenital defects? WIll test subjects ever be informed that all of the above-named risks are associated with the sale of their bodies for such testing?

4. Acceptance of such data is unnecessary, as legions of persons exist in our society who have been poisoned by so-called “legal” concentrations of applied pesticides products. However, these statistics are woefully inaccurate. Many cases go unreported because local governments and DEC’s refuse to investigate cases where registered pesticides have caused harm to avoid involvement in litigation. In my case, after being poisoned at my job site, a DEC employee told me to litigate the case privately but his office would do nothing in the matter because the products were registered!. In the state of New York, no permits are even issued to laboratories which can assess certain types of solvent and pesticide poisoning, making any diagnosis one of exclusion. Industry treats the registration of their products by the EPA as a license to ignore claims of harmful effects. Most cases are simply unrecognized because, as Dr. Enache of the EPA has pointed out in public statements, toxicology is insufficiently addressed in medical schools. If we train medical personnel to recognize pesticide toxicity and test for it, there will be plenty of human data to study as an adjunct to animal studies.

It is time for the standard LD50 testing format to be replaced by animal studies looking for adverse effects from sublethal levels of exposure to pesticides. How is the learning curve of exposed rats effected? What about digestive functions? Reproductive abilities? Differential effects upon immature rats and elderly rats as opposed to healthy adult males? Perhaps when these questions are answered, it will be completely unnecessary to even contemplate human testing – we will already have learned that substitutes are needed for these terrible products, contaminating our water table and crippling our society. It is ludicrous to experiment with poisons upon humans when it is already known that these chemicals are incompatible with biochemistry.

Please forbid such testing and recognize the need to study how to prevent human absorption of these products wherever they are in use. It makes far more sense to do that than to try to determine how much poison “most” people can take into their bodies without destroying them. As one whose life has been destroyed by pesticides, it is crucial that you hear a voice from “inside of the test tube”.


Barbara Rubin

Categories: EPA

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