Dursban In Your Water ? "Under the Radar of Regulators"

 

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WARNING:

If you have a chlorpyrifos well water contamination, don't drink your water ... don't use your water.

DO NOT USE the super-chlorination process which Dow recommends if your water source has been  contaminated with chlorpyrifos. Despite what Dow may tell you, using their procedure creates a far more serious health threat to you and your family by converting chlorpyrifos to an even more toxic compound. And this procedure is not approved by the EPA as Dow has claimed.
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Drinking-Water Well Contaminations

What You Should Know:

Individuals who have experienced Well/Drinking Water Contaminations should know that Dow has intentionally deceived you. The decontamination procedure they recommend and use for chlorpyrifos contaminations is a complete deception. Here is what Dow has known about this procedure since at least the early 1980's:

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The decontamination procedure converts chlorpyrifos into chlorpyrifos oxon, a chemical compound 3,000 times more toxic than chlorpyrifos.

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Dow intentionally hid the chlorpyrifos oxon content of the water samples. It has not been reported even though Dow knew it was present in all water samples, samples Dow said were safe to drink.

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Dow knew the chlorpyrifos oxon was stable for months in the cool and dark conditions of a well environment. This meant people would be consuming and bathing in it for months.

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Dow knew that while the chlorpyrifos compound has some safety aspects such as it can be detected by both smell and taste, chlorpyrifos oxon has no odor and no taste. Dow counts on this lack of ability to detect chlorpyrifos oxon to quickly remove themselves from events which could possibly heighten and bring the attention of the media which also could raise adverse awareness to Dow and their products.

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Dow also knew that many wells would re-contaminate from the original source of chlorpyrifos after an event such as heavy rain. No procedures were in place to retest wells for this re-contamination.

Details

If Dow personnel break the law hiding reports of health complaints do you think they'd bother reporting well contaminations? By hiding all water incidents Dow has also kept their entire well decontamination process from scrutinization. You will see that the well procedure is in itself a superb example of the irresponsible and criminal deceptions the people at Dow use. This Dow business practice has now been termed "Poisoning For Profits".

Some individuals have indicated that Dow has reported less than 2% of all chlorpyrifos water contaminations in the U.S. These are contaminations that Dow has dealt with or had knowledge of occurring.  This means that tens of thousands of people have been involved in well contaminations but their well contamination has gone unreported. That insight was brought forth during the process of reconciling what Dow reported in chlorpyrifos well-water contaminations as compared to their known occurrence. This under-reporting would be in line and of the same type compliance problem Dow had with failing to report the chlorpyrifos health complaints that turned into lawsuits discussed in previous sections. It is now also understood that the only incidents Dow's field reps have been instructed to formally report are those that they personally determine could possibly become lawsuits. That of course is not what the law requires - ALL health complaints and well contaminations involving pesticides are required by federal law to be reported. The EPA's discovery of Dow not reporting them should have been a major hint to the EPA that Dow has been hiding something even more sinister.

We have been able to determined at least one procedure which Dow did openly put in place concerning drinking water samples and the analysis of those water samples that would destroy evidence of the incident. Dow provides water sample analysis for anyone at no charge but Dow requires that no water samples are allowed to be sent to the Dow lab until the well has undergone at least 24 hours of their chlorination procedure.  In other words, they refuse to test any samples of the initial contamination.  Those are Dow's specific instructions in a well decontamination presentation that Dow created immediately after being caught and fined $732,000 for the discovery of the first 249 unreported health complaints previously discussed. Was this a new procedure put in place by Dow to hide water contaminations? This requirement by Dow would of course result in the destruction of the analysis of the real level of the contamination unless additional samples were taken and sent elsewhere for analysis. The results of testing "treated" water, which had already undergone decontamination procedures would unquestionably show much lower levels of chlorpyrifos than when the water was originally contaminated. The treated sample could even be expected to result in non-detectable levels for chlorpyrifos. Was Dow's goal in using this procedural requirement to eliminate the reporting of the contamination to the EPA or was it to destroy the evidence of the existence of the contamination, or both?

What would even motivate Dow to provide lab analysis of water samples at no charge?  It may seem this was a responsible product stewardship step and out of the kindness of their hearts they provided this service. However, taking on the lab analysis responsibilities would be a critical key-element in a scheme to hide the true number of water contaminations from the EPA and has had many additional benefits for Dow:

  1. In almost all instances, by Dow providing water analysis, the state health agency nor the state's water quality department would be notified of or involved in the water contamination. Normally these agencies would get involved in the water sample testing but they are notoriously slow in actually providing the results. Dow's analysis was offered immediately and results were provided within a few days. Well owners therefore almost never sent samples to their state agencies for analysis. They instead chose to trust Dow.

  2. Because of Dow's requirement to start decontamination without taking any samples, true contamination levels would never be known unless a third party analyzed additional samples.

  3. Dow had full control of the sample results. They could just tell the well owner to re-chlorinate the well if there was still chlorpyrifos in the samples.  Would they even report the initial results showing chlorpyrifos? We doubt they ever did except when a government agency may have been involved in the water contamination which was rare.

  4. Keeping the water contamination low-key and handled internally also meant a low risk of discovery by regulators or even by the media of the water contamination or in Dow terms it would keep these incidents "under the radar of regulators".

Hiding the water contaminations was only the beginning of Dow's fraud. Dow's well decontamination procedure is a scam in two ways:

  1. It results in merely decontaminating the water in the well casing area. The chlorination procedure would do nothing to stop a recontamination of the well from the chlorpyrifos source if that source came from outside the well casing area. In many known situations the wells increased in chlorpyrifos levels after a subsequent rainfall event or by some other cause after the decontamination procedure was supposedly complete. And Dow had no procedures in place for subsequent follow-up water quality testing after they determined and stated that the water was safe to drink. The actual reason for the well contaminations have not been well understood or even investigated. In many cases the water line running from the well to the structure is believed to have been a "conduit" for chlorpyrifos to enter the well during structural treatments. Dow provided no instructions to decontaminate this possible source of contamination in their procedures to stop a recontamination of the well-water.  Clearly, the decontamination procedure and offer to analyze water samples was a "quick fix" solely for Dow's benefit in accomplishing their larger objective.

  2. But most importantly, it has also now been learned that the Dow decontamination procedure caused the conversion of chlorpyrifos to chlorpyrifos oxon, a chemical estimated to be 3,000 times more toxic than chlorpyrifos. Dow discovered and knew this conversion was taking place in the wells since at least the mid 1980s but hid this information. In contrast to chlorpyrifos, the chlorpyrifos oxon has no taste and also no odor so the victims would never know they were drinking and bathing in it. See the Chlorpyrifos Oxon page for more details.

The Illinois State Health Agency has petitioned the EPA to stop Dow from using the chlorination procedure entirely after they learned of the chlorpyrifos oxon conversion problem. The EPA still has not taken any action on their request. The EPA's lack of action is most likely due to the EPA's misconception that the problem was less significant because Dow misled them by only reporting a small number of the actual chlorpyrifos water contaminations.  The EPA needs to act. Even if they were incorrect in their understanding of the number of wells contaminated, the toxicity of chlorpyrifos oxon is a serious threat to entire families drinking and bathing in the polluted water. Those that drank and used water containing chlorpyrifos oxon certainly would deserve to be informed of what has occurred. The continued use of the Dow chlorination procedure is only benefiting Dow Chemical and amounts to allowing Dow to intentionally poison those who drink and use the water. Dow has a history of this type disregard for the laws, human safety, and contempt of the EPA.  The EPA can't expect any better compliance from the likes of Dow if it doesn't enforce the laws we rely on it to uphold.

If you have had a water contamination you might also want to know that although Dow may have presented their decontamination procedures to you as "EPA Approved" it has been learned that the EPA has not approved of Dow's procedures nor had they any idea what Dow was doing to decontaminate your water.  Dow has misrepresented their decontamination procedure as EPA approved.

There are several critical steps the EPA needs to make besides stopping the use of the chlorination procedure. They need to:

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Inform all those who have had well contaminations of the fact that they have consumed chlorpyrifos oxon and/or chlorpyrifos.

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Require that ALL water contaminations be reported to the EPA and also to the appropriate state water quality agency.

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Make it a serious criminal offense for failing to comply with reporting. Upper Management should be held responsible for any failure to comply as the financial scandals have caused in accounting responsibilities for corporations.

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Determine why Dow has not informed regulatory agencies and well owners of the presence of chlorpyrifos oxon in water.

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Do a full investigation into Dow's chlorpyrifos complaint handling.

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Determine if this was a concerted effort to deceive the victims of the well contaminations and also regulatory agencies, and prosecute those responsible.

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Investigate to determine the true number of chlorpyrifos well contaminations and health complaints that have occurred.

The most important action is of course to inform those who trusted Dow to do the right thing but instead became victims of Dow - the babies, infants, kids, parents and older adults who trusted that Dow was being honest with their water decontamination and water analysis. We have had reports of chlorpyrifos well contaminations at places like daycare centers and churches, but predominantly at homes where the occupants would have bathed, consumed, and cooked in or with the chlorpyrifos and/or chlorpyrifos oxon polluted water. How about mixing some chlorpyrifos oxon water with your baby formula? Who you are does not matter to Dow. We believe it is even more important for the EPA to determine who was responsible for making these decisions to conduct business in this irresponsible and criminal manner, and to pursue those individuals.

Should you wish to share your experience, have a question, or want to be notified of new information, please go here.


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Links Of Interest

USDA - "chlorine in chlorinated tap water will rapidly transform chlorpyrifos to chlorpyrifos oxon"

Wu J, Laird DA. Department of Agronomy, Iowa State University, Ames, Iowa 50011 "transformation of chlorpyrifos to chlorpyrifos oxon is believed to be a prerequisite for this insecticide to display acute toxicity to organisms. We discovered that active chlorine dispersed in water causes the rapid abiotic transformation of chlorpyrifos to chlorpyrifos oxon"

EPA Addendum to the Drinking Water Memorandum to HED "... the State of Illinois and Region 5 of the U.S. EPA have expressed concern over the substantial formation of chlorpyrifos oxon in wells treated for chlorpyrifos contamination. Because the oxon may also exert substantial toxicity, wells treated for chlorpyrifos contamination should also be monitored for the oxon as well as chlorpyrifos. In addition, a level of concern (LOC) for the oxon in drinking water should be developed"

Dow Chemical: Risks for Investors http://proxyinformation.com/pdf/DowReport.pdf

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