Policy Formulation for Unethical Research Protocols

August 6th, 2003

Letter to various medical societies

To Whom it May Concern,

If industry prevails in its bid to get the EPA to consider results of human trials on the effects of pesticide ingestion, their studies will require the assistance of licensed physicians to monitor test subjects for adverse reactions. I am writing you to urge passage of standards of behavior for licensed physicians which would prohibit any participation by a physician in such activities reminiscent of science under Nazi Germany.

My rationale for such a ban is that these studies do not benefit medical science. These are purely market research. To protect the public health would require studies of how poisons can be applied environmentally WITHOUT trespassing into the bodies of bystanders. In recent years, studies showed over 90% of children and more than 80% of adults had signs of such trespass by pesticide products. I am all too familiar with this scenario as I was permanently disabled with chronic illness and brain damage from pesticide poisoning several years ago at the age of 45.

The fact that most adverse consequences of pesticide contacts occur via inhalation and dermal absorption, makes the ingestion studies a ludicrous design. Since no one will allow pesticides to be fed to children or the elderly and infirmed, such studies can still not be used to fix permitted residue standards on foods for sensitive populations. In other words, such studies will harm people for absolutely no reason but to permit pesticide companies to continue to muddy the waters of debate about the harm these chemicals wreak.

Pesticide studies already promulgate irrelevant and inaccurate conclusions based upon data that does not even assess the full product with its complement of synergists and solvents (also omitted from the label as “inert” ingredients.). Research findings are published only for active ingredients.

Further, there is no way to assure participants that they will not be harmed by the studies. People have different tolerance levels for toxicants. I personally have a deficiency in paroxonase enzyme ensuring a more severe effect from organophosphate pesticide exposures than another adult with normal levels of that enzyme. I have had recurrent episodes of acetylcholinesterase suppression. Will they test patients for adequate levels of AchE before risking their levels falling to a degree guaranteed to cause brain injury, cardiac arrest etc? Will storage of these lipophilic chemicals harm subjects in later years? Or their yet to be borne children?

Any practicing physician participating in such events would be violating the Hippocratic oath and doing a great disservice to science as well as mankind.

Thank you for your attention.


Barbara Rubin
P.O. Box 224
Locust Valley, N.Y. 11560

Categories: Letters

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