Dow's Motives in Hiding Complaints

      Has Dow been hiding problems just to extend the sales life of chlorpyrifos

      Are there even more sinister problems with chlorpyrifos that Dow has been concealing?

      Is it easier and cheaper to intentionally not comply with federal reporting requirements because those reports could raise the attention of regulators and shorten a product's sales life?

      Has Dow seen the fines of approximately one million dollars from the EPA and two million dollars by NY's Attorney General as merely "the cost of doing business" to keep a problem product on the market while generating corporate profits?
   Note: Want to bet that Dow has not and probably never will end up paying the above fines?

      Has it been an intentional business decision on Dow's part to not comply with reporting requirements?

To understand Dow motives its first important to realize just how dependent Dow's agricultural products sales division has been on the sales of just this one insecticide - chlorpyrifos. It has been used to create a majority of Dow's Agricultural Department's highest volume products by creating a variety of formulations with it for different uses. These products have generated the bulk of the revenue for the entire Dow agricultural subsidiary - previously known as DowElanco and now known as Dow AgroSciences. Dow managers have been desperate to sell more chlorpyrifos and any concerns of health issues were being ignored to accomplish their goal.

There are actually two major issues here to cover in terms of Dow motives. One - Dow hiding complaints in general to delay regulatory reaction to the complaints and two - Dow's act of hiding their knowledge of the chlorpyrifos oxon formation in the water from following Dow's decontamination procedures for chlorpyrifos contaminated water.

In regard to the second of the two major issues, hiding chlorpyrifos oxon formation, Dow has and continues to receive complaints from chlorpyrifos use which involve water contaminations each year. These contaminations involve both drinking water wells and surface water such as ponds, streams, and lakes. Well/drinking water contaminations have been critically important to Dow to remedy as quickly as possible due to the extremely sensitive nature of these type contaminations. Not solving these contaminations quickly would of course result in additional parties becoming involved in the contaminations such as health departments and the media. This additional attention would result in additional attention on chlorpyrifos in general and that would have caused regulatory actions earlier to restrict chlorpyrifos product uses. Dow's goal in well water contaminations has been to "sweep them under the rug" as soon as possible even if the well was not truly decontaminated. Dow was even willing to poison families from the hidden problem of chlorpyrifos oxon formation in using their decontamination procedure to hide contamination events. 

A major contamination event recently took place in Veria, Greece on September 2, 2007 when chlorpyrifos was found in the city's drinking water system at a level 2,260 times the permissible level. City water is usually chlorinated for water quality reasons. This would mean chlorpyrifos oxon formation would occur immediately.

How significant is chlorpyrifos to Dow? Because of the recent regulatory demise of chlorpyrifos,  Dow AgroSciences has been said to be on "the block" for sale even by Dow Chemical's ex-CEO Michael Parker. Either Dow Chemical doesn't believe there's any more life in Dow AgroSciences' product pipeline or they have enough issues to deal with themselves and do not want to deal with the ones Dow AgroSciences has caused. Dow bought Union Carbide and Dow is dealing with all the issues that came with that buyout such as the chemical explosion in Bhopal to name just one of so many. Dow announced that it is trying to sell Dow AgroSciences but it seems no one wants to buy. Maybe there are just too many skeletons in Dow AgroSciences' closet.

Dow knows where its bread is buttered. Dow protects its profitable products. Here's is an example. The Dursban LO product used in homes for pest control accounted for over 80% of all complaints that Dow AgroSciences received annually while it was on the market but barely showed as a sales item amongst all of Dow's other products. This product was utilized in crack and crevice treatments and also for flea treatments. Flea treatments usually involve a complete broadcast spray of the insecticide solution over all carpeted areas of a home. This is a treatment which involves using a significant amount of insecticide, far more than almost all other indoor treatments. The Dursban LO label had been amended in 1994 to included a warning for occupants to stay out of the home until the spray had dried, usually three hours. You may think that a prudent measure but what Dow knew at the time was that it really made no difference. Chlorpyrifos, the insecticide in Dursban products, is a semi-volatile chemical. At room temperatures it volatizes off the surface where it is applied and will contaminate any objects in the enclosed application space. So while the carpets may be dry, the chlorpyrifos was still volatizing and contaminating the air breathed by the occupants and contaminating surfaces where it was not even applied. Dow used some common sense and eliminated an already problematic product that was sure to cause huge problems if its use continued. In 1997 Dow agreed, after some pressure, to withdraw Dursban LO from the pest control market. It was becoming a huge blip on the regulator's radar.

By hiding complaints involving chlorpyrifos, Dow kept chlorpyrifos from being the center of attention at the EPA, state regulatory agencies, and other interested parties or as Dow laughingly puts it, they have kept chlorpyrifos "under the regulatory radar". It has been concluded that if all the complaints and adverse incidents had been accurately reported chlorpyrifos would have had its usages severely restricted years ago or been banned. Dow handled complaints like water contaminations internally to alleviate third party involvement, reduce possible attention the problems would create, and to help hide the actual level of complaints that chlorpyrifos was creating. Chlorpyrifos already had a higher complaint incident rate then much more commonly found household products such as bleach. Reported incidents should have brought regulatory attention and caused regulatory restrictions but Dow has been able to keep a problem product on the market by falsifying state and federally required reporting requirements. Dow has used deceptive, unethical and even criminal methods to hide the problems chlorpyrifos has caused such as with water contaminations. 

Are there positive changes coming at Dow? Management at Dow seems to be only getting more desperate. This can only mean Dow will take more and more risky moves to sell their products. New Dow AgroSciences' products don't seem to be doing well. According to Dow AgroSciences customers, upon Dow's realization of possible diminishing sales of chlorpyrifos in the early 1990's, Dow hurried a product to market which would replace some of the structural termite control uses of chlorpyrifos. That product is called Sentricon*. Dow AgroSciences brought Sentricon to the pest control industry in 1994 stating that Sentricon was not yet fully developed and would be improved while it was being used. Clearly, this statement indicates some hurrying in the developmental process. According to users of Sentricon, they believe it was a hurried new product introduction to help Dow fill losses in revenue from EPA use restrictions of chlorpyrifos.

From the time of introduction of Sentricon, people were skeptical of Dow's aggressive claims of Sentricon's structural protection capabilities. Industry experts have added that Dow has made claims regarding Sentricon's termite control abilities that even Dow hasn't and now won't stand behind. One of those was Dow's advertising statement concerning an efficacy claim for Sentricon of "Total Colony Elimination".  Dow changed that aggressive statement to merely "Colony Elimination", dropping the word "Total" in 1997 after industry researchers and regulators objected to the statement based on their research and experience.  It seems that Sentricon more often suppresses the colony and doesn't always obliterate the entire colony as the word "Total" would imply. Dow's aggressive statement was said to have given false impressions about the capabilities of Sentricon.

Here is a website that  was created shortly after the introduction of Sentricon which shows the skepticism and ridicules Dow's claims of termite control.

Dow AgroSciences has since seen Sentricon sales decline significantly and customers discontinuing usage. Dow's largest Sentricon customer and the largest pest control company in the world - Terminix - made the decision to no longer offer Sentricon through their company owned branches in early 2005. It seems there are major issues with Dow's Sentricon product too.

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