Other formats

    Adobe Portable Document Format file (facsimile images)   TEI XML file   ePub eBook file  

Connect

    mail icontwitter iconBlogspot iconrss icon

Salient. Newspaper of the Victoria University Students' Association. Vol 42 No. 14. July 2 1979

2,4,5-T... A Danger We Don't Need

page 7

2,4,5-T... A Danger We Don't Need

[unclear: 5] - T.........

Danger Chemical Our [unclear: Go- ment] Won't Ban.

[unclear: rowing] evidence that a wide range of [unclear: ical] phenomena, notably miscarriages [unclear: regnant] women, can be attributed to [unclear: se] of the herbicide, 2,4,5-T has [unclear: promp-] the U.S. Environmental Protection [unclear: Agen-] impose an emergency ban on all but uses of the chemical. Yet in New [unclear: Zea-] it continues to be available without any [unclear: ictions]. High time our government dements changed their "she'll be right"-[unclear: oach] to the problem of chemically-in-[unclear: ed] environmental hazards, says [unclear: Welling-] freelance journalist Tom' Appleton.

[unclear: hen] the American EPA banned 2,4,5-T [unclear: tle] while ago, no-one could have accused [unclear: agency] of acting with undue haste: it the benefit of almost three decades' [unclear: re-ch] into the occupational and public [unclear: hea-uiards] of this substance. The "clincher" ever, came when an EPA research team [unclear: overed] a significant correlation between [unclear: ing] of 2,4,5-T and miscarriages in the [unclear: a] basin area in the state of Oregon.

[unclear: opies] of the American report were also [unclear: n] to Wellington and studied by Health [unclear: artment] experts. On April 2 the [unclear: depart-t's] director of public health, Dr. Maxwell ins, told the media that the EPA-study [unclear: tained] "severe inadequacies" and that [unclear: ould], therefore, be premature to ban the [unclear: cide] in New Zealand on the basis of that" [unclear: rt].

[unclear: o] Proof"

To be sure, the EPA hasn't "proved" that 5-T induces miscarriages - the report me-speaks of a "statistically significant [unclear: coation]." And one might reproach the [unclear: agen-] or not spending a few hundred thousand dollars more and setting in train two study programmes. Perhaps two reports with very similar findings would have rendered something approaching proof. But, as EPA deputy administrator Barbara Blum said, the "emergency suspension" was warranted as seven million lion pounds of 2,4,5-T were about to be used during the spring spray season, potentially affecting several million people.

"There are considerable data on the health effects of 2,4,5,-T in animal tests which are predictive of the same human health effects we are seeing in Alsea," said Blum. (The herbicide is contaminated with 2,3,7,8-tet-rachlorodibenzo-para-dioxin, or TCDD-dioxin for short, which even at very low levels produces birth defects, miscarriages, and tumours in laboratory animals. See also box two on "The Chemistry of 2,4,5-T.)

THERE'S NO NEED FOR PANIC! I'VE EATEN BLACKBERRIES SPRAYED WITH PESTICIDES AND LOOK AT ME.... Rick Omor

"Taken together, all these facts sound an alarm. Prudence dictates EPA to stop use of the herbicide until we have a fuller understanding of this phenomenon and its implications for human health." Blum said.

"Prudence", mixed with a shot of public pressure, was also behind the Mount Herbert (near Christchurch) county council's decision to limit aerial spraying of TODD-contaminated herbicides to less populous areas.

"Prudence" also motivated the Sale city councillors in the Australian "garden state" of Victoria, who unanimously voted to ban 2,4,5,-T (and the chemically related herbicide 2,4,-D) when a cluster of baby deaths and birth deformities was attributed to the herbicide use in that city last October.

In fact, throughout 1978 a spate of birth deformity clusters all over Australia kept public attention focussed on the issue. But federal and state health authorities were quick to absolve the herbicides - without making their studies available to the public.

That's why the Sale city fathers' action was so unusual. "We are erring on the side of caution," one councillor was quoted as saying, "and that's the side we should be erring on."

The Attitude of NZ Health Department

It's difficult to fault such prudence - and equally difficult to see why Australian and New Zealand health departments don't share it. Both countries are, by the nature of their economy, large, consumers of herbicides: about 250 to 300 tonnes of 2,4,5-T are used "in Australia each year and in New Zealand more than 500 tonnes.

In the United States 5000 tonnes a year were used before the EPA ban. The herbicide had been severely restricted since 1970.

The controversy over the hazards of 2,4,5-T use has been going since the first reports of birth malformations came out of Vietnam in the early 1960s where the chemical was used for defoliation and crop destruction purposes.

A decade ago there was even some suggestion that 2,4,5-T manufactured by Ivon Watkins-Dow Limited of New Plymouth might be being shipped to Vietnam. Although the US government denied it the New Zealand government of the day, it will be remembered, was all for it.

As it happened, a substantial shipment of an undisclosed type of herbicide (or herbicides) was sent to - the Phillippines. Antiwar activist Owen Wilkes, expressing doubts about the ultimate destination of the shipment was advised that the company could not "dictate to buyers the destination of herbicides we produce."

Then, in 1972, the chemical was in the public eye again. The Agricultural Chemicals Board had investigated charges that deformities of two babies born in the Te Awamutu area had been caused by the mothers being page 8 exposed to liquid 2,4,5-T during pregnancy. The special sub-committee set up for this purpose could neither confirm nor deny this claim. Instead, the subcommittee made several significant recommendations. By this time the impurity contained in the herbicide - TCDD, or tetra-dioxin - had been shown to have marked foetus-damaging properties in laboratory animals. So it was recommended that the level of tetra-dioxin in 2,4,5-T should be lowered to the tenth of one part in a million parts of 2,4, 5-T (0.1 ppm). Also, all 2,4,5-T lables were to carry a "conspicuous warning" that "women of child-bearing age should avoid exposure to 2,4,5-T". (Note the difference between "of child-bearing age" and "pregnant.")

Decision Reversed

The board okayed this recommendation but reversed its decision again in 1977 - ironically, only months after one of the most catastrophic TCDD-accidents in history, at. Seveso, Northern Italy.

If that reversal cast grave doubts on the wisdom of the statutory body which okays the use of 2,4,5-T (and other agricultural chemicals, as the name implies) — it also raised doubts whether the board was indeed anything but an industry rubber-stamp. (After all, one of the men responsible for setting up the board was Daniel Watkins himself, the chairman of directors of Ivon Watkins-Dow, the sole New Zealand manufacturer and distributor of 2,4,5-T,)

The board's main objection to a 2,4,5-T ban seems to be that it's a handy chemical to have around. Apart from that, it happily echoes the curiously non-profit-minded IWD-claim that alternatives to the herbicide would cost the consumer more dearly.

But no impact study of cost escalations and consequences to agriculture in case of an actual ban, gives support to that contention, as the board's registrar, Brian Watts, confirms.

The Agricultural Chemicals Board does not even keep statistics on the amount of herbicide used, says Watts. In an age of global concern over environmental pollutants the board continues to measure the risks vs. benefits of 2,4,5-T use in dollars and cents.

Recommendations "Too Tough"

When the 1972 investigatory sub-committee recommended a ban on all aerial spraying of 2,4,5-T within one mile of a homestead or urban area, the board couldn't accept that. For during the preceding year, (1971) about one fifth of the total of 254. 000 gallons (1.5 million litres) of 2,4,5-T sold in New Zealand had been sprayed from the air, and this had meant an increase in carrying capacity of 50,000 sheep and a saving in labour charges to forestry of $1.5 million. (Again, the question of possible alternative sprays wasn't even raised.)

That leaves the reduction of the tetra-dioxin level. However, the subcommittee cautioned at the time, "present methods of analysis used by a Government laboratory are not equal to the task of monitoring to 0.10 ppm, TCDD and considerable work on this method will be necessary in this regard."

This was in 1972.

By April 1973, Ivon Watkins-Dow was legally required, and apparently able to meet the requirement, to make the "cleaner" version of 2,4,5-T:

Since 1973/74 the "government laboratory" (of the Department of Scientific and Industrial Research) has been able to monitor these low levels of TCDD-dioxin with accuracy, according to Ian McDonald, the DSIR's dominion analyst of chemicals. The DSIR, says McDonald, can measure levels down to 0.01 ppm with confidence. This compares with a dilution of one sugar cube in 100,00-litres of water he said. The department is now "working on and very close to developing the processes required to measure traces a million or more times smaller."

"The Most Poisonous Synthetic Substance Known"

Small as these quantities may seem, in the world of chemistry they are a part of reality. TCDD-dioxin is roughly 67,000 times more poisonous than cyanide, and 500 times more so than strychnine. This means that one 67, 000th of a gram of TCDD has the same effect as one gram of cyanide.

In fact, TCDD is regarded as the most poisonous synthetic substance known.

Experiments carried out by Professor James R. Allen and associates of the University of Wisconsin in the United States in 1976 showed that TCDD caused significant levels of liver cancer in rats at doses of five parts per billion to five parts per trillion. (This is a figure so small it is preceded by 12 zeroes to the right of the decimal point: 0.000000000005)

2,4,5-T

2,4,5-T

The TCDD-level of 2,4,5-T produced in New Zealand is said to be as far down as 0.01 ppm - that is, eight zeroes to the right of the decimal point. This means that the dioxin level accepted as "safe" in New Zealand remains still several thousand times higher than the smallest dose found to cause cancer in rats.

And, taking into account a World Health Organisation ruling that any dose accepted as safe for humans should be at least 2000 times lower than the lowest dose found to cause cancer in animals, it is hard to see how the present New Zealand level of 0.01 ppm TCDD in 2,4,5-T can, in fact, be regarded as safe.

1 Seveso is everywhere

Birds began to drop off the roofs, dead. Cats died in the streets. Yellow-rimmed holes appeared in the leaves of the plants. When the children came home from play with red skin-rashes, people gradually realised than something was not quite right.

It happened on July 10, 1976. The ICMESA chemical company, situated outside Seveso (Northern Italy), had closed down for the weekend. There was a "runaway reaction" in a vessel producing trichlorophenol (TCP), a substance used in the manufacture of cosmetics. It is also the chemical precursor of 2,4,5-trichlorophenoxy acetic acid - that is, the herbicide 2,4,5-T.

When the pressure had reached the critical limit, it blew the safety valve, releasing a hot purple cloud into the atmosphere. Contained in that cloud were 300 kilograms of trichlorophenol and two kilograms of TCDD (2,3,7,8-tctracholrodibenzo-para-dioxin), a virulent poison.

This fact alone should have been sufficient reason for the ICMESA management to alert the authorities and urge instant, large scale evacuation of the town's inhabitants. Instead, mum was the word. Only when the signs of the catastrophe had become manifest - in all, some 500 people had to be hospitalised, 3000 animals died and 75,000 had to be destroyed - did the company admit that TCDD-dioxin had indeed escaped into the atmosphere. Not until almost three weeks after the explosion was evacuation finally begun. It was this delay which gave most cause for concern, in view of the known toxicity of TCDD.

However, ICMESA's behaviour in the face of trouble was merely a further instance of the almost aggressively defensive stance often characteristic of the industry as a whole. ICMESA, a subsidiary of the Swiss chemical group of companies, Givaudan S.A. (which in turn is a subsidiary of the giant Hoffman-La-Roche pharmaceutical concern in Basle), was chosen as manufacturing site for the highly dangerous production of trichlorophenol because Italian legislation on dangerous chemicals had remained unchanged since '34.

Another reason was that Givaudan itself had suffered adverse publicity in 1972 following the death of more than 30 babies in France. Unwittingly, the mothers had applied a baby-powder (manufactured by Givaudan) which contained a lethal dose of an anti-bacterial agent, hexochlorophene. But instead of adopting a safer manufacturing process for trichlorophenol - from which hexachlorophenc is made - the firm shifted this part of its operation to Italy.......

Certainly no-one at managerial level of the ICMESA - Givaudan-Roche troika could claim ignorance of the dangers involved in TCP-manufacture, More than 20 cases of TCP-accidents, from 1949 onwards have been documented by the International Labour Organisation's International Occupational Safety and Health information Centre in Geneva.

For example, in November 1953 at the West German Badische Anilin und Soda Fabrik (BASF) in Ludwigshafen a smaller-scale Seveso-type accident occured at a TCP-producing plant. On this occasion previously unknown and highly toxic chlorinated hydrocarbons - of which TCDD -dioxin is but one - were chemically identified for the first time.

Fifty-five workers were exposed to the dioxin, and all developed chloracne, a highly disfiguring rash of boils and pimples. Twen-ty-one developed symptoms of systemic poisoning which included damage to the liver, kidney and spleen. The heart, respiratory tract, eyes and nervous system were also affected. BASF medical superintendent Dr A. M. Thiess described the case of "G", one severely affected fitter, thus:

"The nostrils were fissured and looked as if burnt out. The hairy part of the head showed a smudgy discolouration and was infilt-rated with leathery patches. Hairloss was increased. Countless pimples continually became inflamed, forming fingertip-sized abscesses. G. could not sweat and had a feeling of boiling inside his skin."

Ten years later, "G." was hospitalised with edema of the lower leg and bleeding in the lung, and died of these late consequences of TCDD-poisoning.

The plant was closed down. Every few months rabbits would be sent in as "sensors." These tests were continued until 19 68 but the rabbits never survived. That year the factory was dismantled under the most elaborate safety precautions. Parts of the building were packed into airtight containers and buried in disused salt mines. Metallic parts were melted down in industrial blast furnaces. (The task of dismantling and "burning" Seveso and much of its outlying top soil to a depth of at least 10 centimetres remains as yet untackled.)

Other accidents had occured in the United States, the U.K., the USSR, Holland, France, Italy, Czechoslavakia, Austria and elsewhere in West Germany.

The Hamburg firm Boehringer Ingelheim experienced two accidents, then developed its own, safer manufacturing process. It wasn't widely adopted because it was also less profitable. But even New Zealand's 2,4,5-T manufacturer Ivon Watkins-Dow, employing the safer Boehringer process-judging from a fact-sheet put out by IWD; the firm actually refuses to deny or confirm this - has not been without accidents.

In 1975 an explosion, caused by mounting pressure in a chemicals mixing vessel used in the manufacture of a herbicide, released a "big ball of orange flame and dark smoke that went up with a whoosh in a mushroom." (Staff reporter, Taranaki Herald.) However, that explosion had nothing to do with 2,4,5-T production, I was told in a recent personal communication with IWD, "as, in fact, the process was concerned with the manufacture of another pesticide."

This may be so. But shouldn't the public have a right to know, which?

2 TCDD - The on/off poison

Whether a chemical substance is toxic or not depends largely on the type of poison, its molecular structure, the amount of intake per time unit, as well as on the part of the body it first comes into contact with and on the part if affects.

The human body constantly fends off all sorts of alien substances which attempt to gain entry into it. These reaction-patterns are, however, phylogenetically determined, that is to say their main thrust is directed against substances occuring in nature.

This situation has undergone drastic changes since the beginning of industrialisation. An immense number of new chemical substances have entered the environment. Each year hundreds of new chemicals are added to the list. Along with this number of allergenes, (allergy-causing factors), also increases.

Initially, the body will always attempt to rid itself of alien matters through the liver, the body's sewage treatment plant, by breaking down harmful chemical substances to harmless ones. And the skin's glands too, can try a first localised counter-attack. If this doesn't succeed, and if even the liver cannot cope with the poisonous combinations, then, as a rule, these are the organs first to go.

Liver and skin, along with the kidneys whose job is to detoxify the blood, are, therefore, the organs most easily damaged by poisons.

This could be seen, for example, in the children of Seveso who, playing outdoors at the time of the explosion, were exposed to the greatest dosages of the poisonous TCDD-fallout. First they developed a seriously disfiguring kind of acne; later, many of the children also showed signs of liver disorders.

Progress in the field of biochemistry has now made it possible to investigate toxicological processes within the body (or plant) cell itself.

The main attention has been focused on researching enzymatic systems or the development of anti-bodies. The findings from these toxicological studies have made possible a better quantitive assessment of the risk nosed by toxic substances in the environment And it has been shown that the same enzyme systems which are supposed to protect the body, can in fact, participate in the transformation of alien substances into highly toxic metabolites, that is, internally produced poisons, which are of particular relevance in assessing foetus-damaging, cancer-causing and gene-damaging tendencies of environmental pollutants.

One group of chemical compounds subjected to considerable critical flak in recent years are the so-called chlorinated hydro-carbons. In particular, vinylchloride (VC), used for more than four decades to make a popular type of plastic - polyvinylch loride, or PVC - was found, as late as '74, to cause cancer. This finding alarmed scientists and the general public alike and woke them up to the limitations of toxicological checking methods devised to that date.

One West German toxicologist. Professor Dietrich Henschler of Wuerzberg University, expressed concern that similar toxic effects might be detected in other members of this family of chemical compounds. Henschler had discovered a connection between the molecular structure of these compounds and their toxic effects. In some substances he said, the toxicity increased with the number of chlorine atoms in the molecule

The molecule structure can also give hints as to a chemical's cell-damaging and cancer-causing propensities. Chlorinated ethylenes with a symmetrical molecular structure, for example, cause no damage to cells. If, on the other hand, the structure is asymmetrical, as for example in the case of VC, then the substance causes cancer.

But such correlations between molecular structure and toxic effectiveness are not very well understood and continue to baffle scientists. Indeed, the order of number of atoms wither a molecule is by no means a reliable indication of a chemical's toxicity.

In particular the dioxins, including TCDD, show an unusual type of behaviour. The same molecule can be either a super-poison or, comparitively, much more harmless. TCDD is, truly, an on/off poison. And indeed, most researchers of the effects of TCDD wind up with curiously on/off findings. Most, like Professor James Allen of the University of Wisconsin, add that "the elucidation of the molecular mechanism of TCDD toxicity is required for a better understanding of these results."

page 9

[unclear: Data] Ignored

Ignoring such data seems to be the most [unclear: disturbing] aspect of a dangerous government industry mind-fix on the hazards of [unclear: 45-T] - as exemplified in the Big Pacifier [unclear: or] the Big Baby Public, the health departments 1977 report, "2,4,5-T and Human [unclear: irth] Defects."

After investigating some 20 cases of [unclear: se-ous] birth defects which had occured in [unclear: sp-ived] neighbourhoods in the Northland, [unclear: Ta-maki] and Waikato areas, the department [unclear: ar-ved] at the conclusion that "there is no [unclear: evi-ence] to implicate 2,4,5-T."

At the time the report's many [unclear: inadequa-ies] quickly established it in the eyes of the [unclear: ublic] as a whitewash-attempt.

The report's main faults included:
  • [unclear: the] exclusive and rather superficial [unclear: investi-ation] of a small set of data - the mothers [unclear: oncerned].
  • [unclear: wo] Whangarei mothers who had given birth [unclear: o] deformed babies were omitted altogether. [unclear: j] least one mother was questioned only over [unclear: ie] telephone. Local hospital data was not [unclear: sed], files not searched for further case [unclear: ma-rial].
  • [unclear: the] extreme speed with which the report [unclear: as] produced - ostensibly to dispel public [unclear: ars] over 2,4,5-T, roused by a "Dateline londay" programme a few months earlier.
  • [unclear: the] omission of a known 2,4,5-T critic, [unclear: rofessor] R. B. Elliot, an Auckland [unclear: Uni-risty] child health expert. Professor [unclear: El-ot] was invited to the committee, which [unclear: len] chose to proceed without him.

The health department's Dr Collins who [unclear: ow] has found "severe inadequacies" in the PA report, confided to the New Zealand [unclear: erild] in July 1977 that the department's [unclear: port] was the result of a "political [unclear: decion]".

It was felt, he said, that if a high-power [unclear: ommittee] had been especially created for [unclear: ne] job it would have been "tantamount to [unclear: agisting] 2,4,5-T was a major hazard and [unclear: e] had to put all our big guns in to get it [unclear: ff] the hook." One can only speculate why [unclear: e] department created to promote and pro-[unclear: ect] "health" should want to get a dange-[unclear: ous] chemical "off the hook."

More to the point, however, is the [unclear: ques-on] why the department found the EPA [unclear: port] - which has all the appearance of serious and self-critical scientific [unclear: investi-ation] - to be inconclusive on the [unclear: ques-on] of a link between 2,4,5-T and human [unclear: irth] problems, and yet found its own [unclear: fli-uy] investigation conclusive proof of no [unclear: ch] link. (As, indeed, it should be clear [unclear: hat] absence of evidence does not mean [unclear: vidence] of absence of such a link.)

Certainly the EPA study provides a moel of the investigation the health department should have carried out, complete with [unclear: lghly] detailed questionnaires. Had similar [unclear: ndings] been made in New Zealand - would [unclear: he] department have imposed at least a [unclear: tem-orary] ban?

Meanwhile, further evidence of 2,4,5-T [unclear: azards] is mounting up:
  • a statistical investigation into possible links [unclear: etween] herbicide spray application and birth [unclear: eformities] in Northland has been originated [unclear: y] an Auckland University inter-disciplinary [unclear: search] team and is due for publication soon However, as malformed foetuses would probably be aborted spontaneously (miscarriages) some time before completion of the full birth cycle, the link with actual birth deformities may be more tenuous than the miscarriage link found by the EPA.
  • a number of studies during the past few years have confirmed that burning of shrub or brush sprayed with 2,4,5-T can produce additional TCDD-dioxin in the environment. (See "Science" (1977) pages 1008 to 1009).
  • in a personal communication from Hamoi, Professor Ton That Tung, a world authority on the effects of 2,4,5-T, advised me that "primary liver cancer (hepatoma) had been seen in 25 per cent of all cirrhoses of the liver autopsied in Paris in 1974 - even though primary liver cancer used to be extroadinarily rare among members of the white race."

Professor Tung, who had been retained by the Italian government in an advisory capacity after the 1977 Seveso debacle, and had consultations with many European liver specialists, believes the increase in primary liver cancers might be linked to TCDD-dioxin.

WHAT'S TRS PRESCRISED QUANTITY; NONE.

The herbicide 2,4,5-T is widely used in European agriculture.

  • a recent and about-to-be-published study of "The Genotoxic Effects of 2,4,5-T" (as opposed to the contaminant, TCDD) by Wiliam F. Grant of the genetics laboratory at Montreal's McGill University states that "the safety of 2,4,5-T is still in question." Grant sees risks in the use of the herbicide, "even with restrictions on the quantity of TCDD present in commercial samples of 2,4,5-T.". Grant goes on to say that "individuals involved in manufacturing 2,4,5-T or in spray operations for weed control or in forestry operations where exposure is high, stand a much greater risk of mutagenicity (cell, including chromosome cell, changes) and cancer. Precautions should be exercised in such occupations to the greatest extent."
  • Christchurch researchers looked into possible genetic damages in 57 local sprayers using a large variety of pesticides. While some chromosome changes were observed, the overall result remained somewhat inconclusive. However, the study team's fin-dings on handling and storage of pesticides gives some cause for alarm:

In some cases "the chemicals were easily accessible to children, and in one instance full canisters were stored under a hedge. Stocks of chemicals which showed obvious deterioration of the container, the contents, and an illegible label were frequently encountered. Some chemicals would be at least 10 years old. One orchadist required hospital attention for acute poisoning after sweeping his storeroom. Apparently he had inhaled dust containing organophosphates. Over half the sprayers studied used no protection when making up or mixing chemical sprays, and some even used their bare hands to measure the amount of spray concentrate required. Only 12 sprayers had adequate protection while both mixing and spraying. Washing of hands after spraying was limited, as was washing of protective clothing after use." (New Zealand Medical Journal, September 13, 1978)

In the final analysis scientific evidence, no matter how voluminous or convincing will count for little without the EPA's political muscle. The success or failure of the American ban - now being challenged in the courtroom by Dow Chemical, the principle American manufacturer of the herbicide - will provide the litmus test for New Zealand's legislators as well.

3 [unclear: hat] the EPA has found

The Environmental Protection Agency [unclear: pa]) of the U.S. government banned most [unclear: es] of the herbicide 2,4,5-T. This [unclear: deci-n] is not final and is, at the time of [unclear: wri-ig], being contested in court by the [unclear: manu-turers], led by the Dow Chemical Co. of [unclear: dland], Michigan.

[unclear: hy] the EPA did it

In a thorough statistical analysis of [unclear: spon-icous] abortions (miscarriages) occuring in [unclear: e] Alsea basin area in the state of Oregon, A researchers found a consistent and dra[unclear: tic] peak of miscarriages in the month of [unclear: ne] The peaks occured in each the past si c years (the time-frame of the [unclear: dy)] and markedly so in the past three [unclear: ars] when 2,4,5-T spraying was also hea[unclear: st]. In addition, the EPA found a "statically significant" (that is, not accident correlation between the spraying season [unclear: aring] March' and April) and the subsequent [unclear: h] miscarriage peak!

In the "control" area, of similar rural type and also in Oregon where, however, no 2,4,5-T was sprayed, no mid-year peak was observed. Instead the researchers found a curious and unexplained M-shaped pattern of regular ups and downs in the miscarriage frequency within any given year. This pattern was also found to exist in urban areas in Oregon and Florida But, significantly, in the study area a sort of W-pattern existed with a marked mid-year peak - an exact reversal of the pattern observed in the control areas

The possibility of a phase-shift in time was investigated and discounted - the June peak was found to be unique to the study area. EPA deputy administrator Barbara Blum called the correlation between the regular June miscarriage peak and the preceding spray period "remarkable" and added: "While it is not proof of a cause and effect relationahip, it is highly suggestive, particularly in light of animal test-data and gives great cause for concern."

4 Dow chemical - A company fights back

Already the Dow Chemical Company of Midland, Michigan - the principle manufacturer of 2,4,5-T has filed a lawsuit to over-turn the EPA's decision. Dow's president, David Rooke, reiterated the long-standing Dow-claim that the herbicide is a "safe product". "It's time to take a stand," said Rooke, "I'm sick and tired of the chemical indistry being picked out as the evil of mankind."

Dow has gained a reputation as the most militant of chemical companies. It virulently defended its manufacture during the Vietnam War of Napalm-B for liquid incendiary bombs, and the defoliant "Agent Orange" - a highly poisonous herbicide-cocktail consisting of a 50:50 mixture of 2,4,5-T and the chemically closely related herbicide 2,4-D.

The company, said Rooke, "believes in fighting. We hung in on napalm when it didn't mean anything to us business-wise. The government asked us to make it and we did. We believed in the principle."

Principles before profits, is Dow's motto. Already the company has spent more defending 2,4,5-T than it has recieved in profits from it, according to Rooke. And indeed, the "profit motive" alone cannot be held responsible for Dow's defence of either napalm or 2,4,5-T. At the time of the Vietnam War, the U.S. government (air force) contracts for the manufacture of Napalm-B amounted to US$6 million of the company's then US$1 billion annual turnover. Today, according to Rooke, manufacture of 2,4,5-T accounts for US$12 million of the company's annual US$6 billion worth of sales.

Strange behaviour for a capitalist ogre? According to Rooke, there is another side to the question as well: "This is only one battle in a much larger war that can affect every product industry makes. If you can wipe a product with this much proven safety off the market, then what is safe?........... There is a moral question: government abuse."

It sounds like the Free Enterprise theme song. The old liberal notion of the freedom of the invidual corporation to set up any kind of business, anytime, anywhere, clashes uncomfortably with the EPA's job to protect the freedom of the individual American citizen to choose clean air and a cancer-free environment to live in.

The record of why 2,4,5-T - many tines as poisonour to humans as for example, DDT which was banned in the U.S. in 1972 - has taken so long to deal with throws a telling light on what is supposedly helpful U.S. legislation - the Pesticides Control Act (PESCA) of 1972, with substantial amendments in 1975 and the Toxic Substances Control Act (TOSCA) of 1976.

The main thrust of these acts, as intended, has been to put the burden of proof of safety of a chemical onto the producers. But the chemical and agricultural industries, commanding considerable political muscle in Washington, ("lobbyism"), managed to obtain legislation setting up a labyrinthine obstacle course before a substance can, in fact, be barred from the market place.

The strength of the industry muscle can also be seen in the fact that TOSCA took six years of filibustering to overcome before it could become law. So, while TOSCA, on paper, is an exemplary poisons act, in reality it gives the EPA only relatively limited powers. The "emergency" ban on 2,4,5-T was the most drastic measure the EPA could take under the law. "EPA can't take things off the market without good cause," said the agency's pesticides chief, Ed Johnson, "We're not acting like a bunch of lunatics. We are trying to be objective about risks and benefits."

That's what concerned environmentalists in the U.S. and elsewhere, including New Zealand, would call a classic case of understatement.

Strong indications of the harmful effects of 2,4,5-T had been building up throughout the 1960s, particularly in Vietnam. From 1962 to 1971 some 71.4 million litres of highly impure 2,4,5-T were sprayed over Vietnam, mostly in combination with other herbicides. As a result, stillbirths increased dramatically: from 0.14 per cent in 1962 to 1.34 per cent in 1965 to 5.1 per cent in 1966 to 7.5 per cent in 1969. Liver cancers, which had numbered 159 between 1955 and 1961, were recorded in 791 cases between 1962 and 1968.

Public concern in the United States led to domestic restrictions on 2,4,5-T in 1970 and, a year later, to a stop of its use in the Vietnam War.

In 1975 the EPA instituted a new administrative mechanism, the "Rebuttable Presumption Against Registration" (RPAR), an ultimative order to the manufacturer to [unclear: prov] the safety of a product within a given period, or have it deregistered. Naturally, the manufacuter can challenge an RPAR several times at ever-higher levels. The rebuttable presumption process against 2,4,5-T was started in April of last year. (The March 1 "emergency" ban interrupted that process.)

Coincidentally, at the same time last year, the chairman of the New Zealand Dow-subsidiary. Daniel Watkins of Ivon Watkins-Dow Limited at New Plymouth, told "his" company's annual meeting, allegations that 2,4, 5-T was detrimental to human health were unfounded. "It is important to note," said Watkins, "that the allegations were not raised in scientific papers, nor did they originate from scientists with training and experience in toxicolocy, physiology, environmental chemistry and pediatric medicine."

Watkins was echoing what the EPA's Ed Johnson has called Dow's "posturing". The facts certainly present a different picture. In 1973, for example, 30 West German university professors - most of them all kinds of forestry experts, but with a few zoologists, environmental toxicologists, a limnologist, two geneticists, two medical pathologists, a plant physiologist and a cell biologist thrown in for good measure - signed a joint declaration calling on the West German government to ban 2,4,5-T.

However, Dow has good reasons to claim the safety of its product and, in particular, the safety of very small doses of TCDD and other dioxins. The EPA has been howling for Dow's blood since the company environment has been found to be contaminated" with low-level dioxin "fallout", and the Midland birth defects rate is three times higher than that of the rest of Michigan. (Which is none too reassuring news for the people of New Plymough, home of a TCDD-emitting ting Dow subsidiary.)

In addition, large numbers of U.S. Vietnam veterans have begun urging the government's Veterans Administration to recognise late-blooming service-related injuries allegedly stemming from handling "Agent Orange" during the war. As the U.S. Air Force had experimented with highly dioxin- contaminated 2,4,5-T in 1962 on a test-site at Fort Eglin, Florida, prior to the Vietnam defoliation programme, the veterans claim that "Dow knew" of the herbicides potential to damage human cells.

Dow could well be faced with an avalanche of million-dollar damages claims during the next few years if the EPA could prove that all the nasty things being said about TCDD were true. That's why the company fights the EPA tooth and nail.