Dow's Statements of Chlorpyrifos Safety
 Just Don't Hold Water

Here are two pieces of information, of which portions were directly provided by Dow, that show Dow's statements are either totally contradictory to the preponderance of real-life incidents that have occurred from chlorpyrifos uses or Dow's information is deceptively and fraudulently hiding the real problems that Dow fully understands but has not acknowledged because it would hurt their sales.

1. Dow Well Contamination Reports
    

2. Chlorpyrifos Incidents Review By Dow and the EPA

Chlorpyrifos Well Contamination Reporting by Dow

Below is a summary of what Dow has reported for chlorpyrifos well contaminations from 1992 to 1997 according to an EPA document. This report clearly shows a very significant under-reporting of well water contaminations by Dow as has been discussed previously. The data behind the reported incidents, even in the EPA's opinion, lacks detail in Dow's reporting of the incidents. Dow required those with water and well contaminations to complete a lengthy form which provided great detail to the incident. So why would the information that Dow passed along to the EPA show a complete lack of details? Would Dow be hiding the details intentionally so no one could reconcile what Dow reports versus the actually occurring chlorpyrifos contaminations?

Also notice that there is no mention in this 1998 EPA document of chlorpyrifos oxon or any discussion about its presence in wells. The document indicates that 3,5,6-trichloro-2-pyridinol (TCP) is the degradation product in wells but that is incorrect for wells treated with Dow's chlorination procedure where chlorpyrifos oxon is the degradation product of critical concern because of its extreme toxicity. Dow hid their knowledge of chlorpyrifos oxon from the EPA and from those with water contaminations. Dow knew of the presence of chlorpyrifos oxon since at least the mid-1980s.

What is known from this EPA report?

	The Dow reported data in the chart below fails to report all well contaminations during the years reported.
	Some states where wells were known to have been contaminated aren't even reported by Dow.
	There are known to be more well contaminations in specific states during these  specific years than Dow reported.
	It is now known that Dow has reported less than 2% of the well contaminations known to have occurred.
	Dow continues to falsify federally required FIFRA adverse incidents reporting.

Chlorpyrifos Incidents Review By Both Dow and the EPA

Below are comments regarding a review of chlorpyrifos incidents by Dow and then the  EPA's responses to Dow's comments follow.

Dow statement in a report reviewing chlorpyrifos incidents:

“There is no scientific evidence that chlorpyrifos causes neurobehavioral effects.”

EPA's response to Dow's statement:

"Such statements can only be made by totally disregarding the scientific literature. See Steenland et al. (1994) for evidence from human studies. In addition, the developmental neurotoxicity study in rats found that chlorpyrifos alters brain development of offspring following in utero or eary postnatal exposure (Hoberman 1998a,b) and another study reported that chlorpyrifos causes behavioral changes in both young and adult rats (Moser and Padilla 1998)."

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Dow statement in a report reviewing chlorpyrifos incidents:

“the child could accidentally ingest a 15% chlorpyrifos solution before displaying signs and symptoms consistent with exposure.”

EPA's response to Dow's statement:

The 1996 annual report of the American Association of Poison Control Centers (1997) includes the following fatality report:
A 22 month-old boy ingested an unknown amount of an insecticide (chlorpyrifos 0.5%, petroleum distillates 0.3%, and water) which had been placed in a cup. There was immediate choking, and after ED [Emergency Department] arrival, drooling, gastric distension, and respiratory distress developed.. . . The patient remained ventilator dependent, and died due to sepsis 10 weeks after admission. Initial plasma cholinesterase value was 0.4 U/mL (normal, 8-18 U/mL). [0.4 represents 95% depression below normal.] Two similar cases were reported by Zweiner and Ginsburg (1988) cited in the Blondell and Dobozy (1997) review where children swallowed household formulations (containing 0.5% chlorpyrifos) and experienced life-threatening effects and had very low cholinesterase values confirming poisoning by chlorpyrifos. These cases conflict with the statement by DowElanco regarding the safety of a 15% formulation, a 30 fold higher concentration."

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Dow statement in a report reviewing chlorpyrifos incidents:

“Acutely toxic concentrations of chlorpyrifos cannot be attained following proper chlorpyrifos applications.”

EPA's response to Dow's statement:

A physician contacted EPA regarding a poisoning that occurred to his son in October 1996 in Florida. The son, who was in his 30s, mowed the hospital ground for 40 hours per week. He was often hot and sweaty while mowing and frequently removed his shirt. On at least one occasion, the lawn had been treated with fertilizer containing chlorpyrifos in a granular or dust formulation. He reported getting considerable amounts of the material directly on his skin which he did not wash off for several hours. Though not in violation of label precautions because the label fails to list precautions about mowing after application, he did develop symptoms consistent with organophosphate poisoning. This incident strongly suggests that poisoning can occur in spite of following existing application precautions. Therefore, 24 products intended for applications to lawns should have warnings to prevent substantial dermal contact among people other than the applicator who may experience substantial contact.

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Dow statement in a report reviewing chlorpyrifos incidents:

“residential use does not result in chronic (long term) exposures”

EPA's response to Dow's statement:

There are numerous incidents where measurable levels of chlorpyrifos, well above ambient background, were found months after the treatment. For example, a church in Harper Kansas was treated for termites in July 1995 with 626 gallons of Equity (a product containing chlorpyrifos). One year later, in July 1996, chlorpyrifos was still detected in the air and it was confirmed that the product had been misapplied into the air ducts. People who worked at the church reported symptoms that were consistent with chronic neurobehavioral poisoning due to chlorpyrifos months after the treatment. Many other examples of spills and misapplications leading to measurable exposure months later could be cited. Even when chlorpyrifos is applied properly for the control of termites, low vapor concentrations can be measured as long as eight years following treatment based on studies conducted by Wright et al. (1988, 1994).

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The EPA concludes their review of the Dow statements above with, "statements in the DowElanco review are clearly inaccurate or misleading."

Background information: the Dow individuals providing Dow's  responses in these statements are the same individuals also involved in Dow's chlorpyrifos water decontamination procedure and analysis. They are the individuals who falsified records and hid well contaminations and adverse incidents. They are also individuals involved in the previous falsifying of FIFRA required adverse incident reporting in 1995 which resulted in the first fine of $732,000. And they still work for Dow AgroSciences where they have been promoted many times.

Additional Note: There are many studies which now document that chlorpyrifos is being found in the dust circulating throughout buildings years after a treatment had been conducted. Other studies also show that the applied chlorpyrifos slowly volatilizes (to become a gaseous airborne material) and causes the building to have low levels of chlorpyrifos in the air for years after a treatment. Dow has had knowledge of this information from their own studies long before many of these outside studies were conducted. They knew of the problems from at least the mid to late 1980s but they still continue to fraudulently present chlorpyrifos as a safe product. Their intentional misleading statements has led to improper use of chlorpyrifos and a lackadaisical safety concern during its use. The New York State Attorney General is the only government agency who has taken an appropriate action by suing Dow for continuing their practice of deceptively misrepresenting Dow products' safety. Dow was threatened with being sued by the NY Attorney General in 2004 after they continually broke an agreement initiated in 1994 to cease their practice of deceptively misrepresenting chlorpyrifos safety. Instead of going to court, Dow paid a record consumer fraud fine of $2 million dollars to settle the suit out of court. Dow probably considers this a petty amount for a product with sales of tens of billions of dollars. More importantly to Dow, their settlement also kept them out of a public court where the information that would have been presented would have hurt their sales even more and would have resulted in an avalanche of additional suits.

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