February 3rd, 2003
Dear Mr. Helliker,
I recently received Steve Tvedten’s email of an abstract for the study of farmers engaging in sheep dipping using organophosphate pesticides. Apparently those farmers who succumbed to the toxic effects of the chemicals used were among a group of persons deficient in an enzyme, paroxonase, essential to the detoxification process for a group of poisons within the class of organophosphate toxicants. It brought me to formulate this statement given your role in the enforcement of regulations regarding the use of registered pesticides in the state of California. This applies equally to those occupying your role in other locales throughout these United States.
My name is Barbara Rubin and I worked in a series of school environments throughout my working career as a special educator and school administrator. I began experiencing episodes of acute illness following the monthly visits of exterminators to the facilities in which I worked early in this career. After a decade of worsening reactions including one episode in which I fainted and fell down a flight of stairs, the connection became apparent after years of searching for medical advice. By the time this phenomena was apparent to even our physicians here in the U.S., all extremely lacking in toxicological training, I had already become sensitized to many chemicals common to the environment causing significant lifestyle adaptations.
I continued to work with accommodations permitting me to avoid contact with the monthly visits from exterminators required by mandate of the Board of Health overseeing day care and school facilities in the state of N.Y. For some unknown reason, they always sprayed chlorpyrifos (Dursban) whether or not pests had been sighted and without regard for the presence of children and staff on the premises. In deference to me, facilities hiring me began to reschedule such visits to Friday afternoons, warning me to leave the premises should the applicators arrive prior to the close of business for that day. I was considered an exceptional individual who could not be so exposed.
Unfortunately, there were times when people forgot to warn me with disastrous results. Then there was a period of three years when I worked in an office lacking in ventilation. There, returning to work even two days following applications, could not protect me from declining health and increasing chemical sensitivities. Finally, reassignment was made to a better ventilated building and a new policy implementing the use of gel baits rather than airborne toxicants. I experienced a resurgence of well being within the limits of my disability brought on by chemical injury.
Despite earning a very good salary during those years prior to 1999, I had little to show for my hard work given the costs of fruitless medical consultations for my supposedly “rare” health problems. I finally learned, via independent research and a few physicians educated in environmental/occupational medicine, that pesticides effect a surprisingly large number of humans in predictable ways – just as they do pests. I had my blood tested by a prominent researcher, Dr. Clement Furlong, at the University of Washington (Seattle), which revealed that I was among 15% of the adult population deficient in the enzyme, paroxonase or PON 1. Even more surprising was the published fact that infants and toddlers below the ages of 18-24 months are all lacking in PON 1 as it develops at a later age.
This enzyme appears to be essential to the detoxification of both clorpyrifos and diazanon, used in high concentrations throughout commercial, educational, day care and residential facilities all around the country, indoors and out. Apparently the connection between PON 1 deficiency and acute/chronic adverse affects had been the subject of open study for two decades and published in peer reviewed journals. Yet the regulatory agencies of the U.S. did not appear to take into account the actual and potential damage to millions of children and adults around this country from organophosphate products, even those used in municipal mosquito control programs via aerial spraying. Physicians remained ignorant of the connections and still have not heard of PON 1 even during the recent controversies surrounding the agonizingly slow process of cancellation for clorpyrifos and diazanon – withdrawals which permit continued usage of existing stocks despite the known dangers millions of susceptible persons.
This story does not have a happy ending, Mr. Helliker, New York State does not require landlords to notify persons in advance of the use of toxic chemicals. My employers apparently failed to take the necessary steps to ensure “special” treatment for me during the fall of 1999. Spraying of neurotoxic pesticides and herbicides resumed in this new working environment without notice to me every two weeks for over six months. I developed significant brain damage and further sensitization which ended my career at the age of 45 and now requires me to live in chronic ill health, poverty and isolation. I even demonstrate chronic AchE suppression, another common phenomenon rarely tested by mainstream physicians as a result of organophosphate “misuse” in a residential setting the following year (confirmed by toxicological analysis)..
The damage done to me was entirely predictable and preventable using existing knowledge and research from almost the beginning of my long journey into permanent disability, pain and isolation. Neither the pest control industry, the regulatory agencies or the AMA appears to have recognized or cared about the millions of affected individuals labelled “asthmatic”, “chemically sensitive”, “brain damaged” or a myriad of other descriptors for sequelae to such toxicological nightmares inflicted upon the general population. The knowledge that our sufferings were preventable while such data was apparently suppressed in favor of useless measures of LD50 research for registration of these terrible chemicals is the most bitter pill to swallow. I would not mind suffering in the interests of scientific ignorance and ongoing study. However, my life has been sacrificed in the interests of “special interests” with the blessings of the United States legal codes.
Mr. Helliker, I suggest to you that your role in society cannot be fulfilled via the codes you enforce. Morally, those in your position must go beyond the law to study, independently, the research material on the chemicals you regulate in order to truly fulfil your mission to protect the public. Many neurotoxic agents remain on the market despite industry “research” and EPA “registration” with no eye to the widespread effects of their usage and misusage based upon true science (see work of Dr. Haley, Dr. Abou-Donia and others). The government cannot regulate the laws of biochemistry. They can only ignore them for profit or bow to them in deference to human health and dignity.