Ruckelshaus, Sweeney and DDT

On June 2nd, 1972, William D. Ruckelshaus, Administrator of the Environmental Protection Agency, issued an order effectively ending the agricultural use of DDT in the US.

Thirty-five years later, that order is still the subject of fierce controversy.

One claim often made by proponents of renewed DDT use is that Ruckelshaus’ decision was capricious and unsupported by the evidence — specifically, that he acted in willful disregard of his own hearing examiner’s findings. For example, in a post co-authored[1] with the late J. Gordon Edwards, Steven Milloy states that Ruckelshaus “ignored the decision of his own administrative law judge.”[2]

Milloy’s distortion of the history and science surrounding DDT is shameless, and deserves to be the subject of a separate post. But let’s stick with the Ruckelshaus order for now.

Did Ruckelshaus ignore the conclusions of his hearing examiner? You’d think, since this claim is made so relentlessly by DDT advocates, that we could find the relevant document somewhere on the Web. But it’s not that easy. Ruckelshaus’ order itself is readily available (see below for a more readable copy), but the hearing examiner’s findings … not so much. The document is sometimes cited as “Sweeney, E.M., 1972. ‘EPA Hearing Examiner’s Recommendations and Findings Concerning DDT Hearings,’ April 25, 1972. 40 CFR 164.32.” — which helps a bit, but only a bit, since “40 CFR 164.32″ is just the Federal Regulation governing administrative hearings at EPA. Anyone who offers that to you as an actual cite for the opinion is blowing smoke. A better cite is the one given in the order, viz.: “Stevens Industries, Inc. et al., I.F&R. Docket Nos. 63 et al. (Consolidated DDT Hearings)”. But even that will not get you anything online. EPA does give its Decisions and Orders online, but only back to 1989. A good deal of fruitless searching convinced me that the Sweeney opinion would not be mine with the click of a mouse; it was old-school or nothing. After several weeks, a dozen or so phone calls and the help of some very nice university librarians, I was able to get my hooks on all 173 glorious manually typewritten pages of Edmund M. Sweeney’s “Recommended Findings, Conclusions and Orders.”

Here it is. (56 Mb pdf!) EPA’s librarians indicated that they would not post it online, because of the wretched quality. I’m not so picky. While we’re at it, here is a (slightly) more readable copy of Ruckelshaus’ order.
(UPDATE: See [4] below.)

The following are some of the more notable things we can observe if we look at both documents:

Did Sweeney’s findings generally support the Petitioners (DDT registrants)?

Yes. Sweeney found no evidence to indicate that DDT causes mutations or birth defects in humans, considered the evidence for DDT’s carcinogenicity in humans to be inconclusive, and, though he found that DDT is harmful to wildlife, he deemed that harm to be outweighed by DDT’s value as a pesticide. Sweeney’s findings of fact are summarized in pages 91-92, and his conclusions of law in pages 93-94. Milloy quotes (#17) part of those conclusions:

The EPA hearing examiner, Judge Edmund Sweeney, concluded that “DDT is not a carcinogenic hazard to man… DDT is not a mutagenic or teratogenic hazard to man… The use of DDT under the regulations involved here do not have a deleterious effect on freshwater fish, estuarine organisms, wild birds or other wildlife.”

That partial quote is misleading. Sweeney also found (p. 92) that

20. DDT can have a deleterious effect on freshwater fish and estuarine organisms when directly applied to the water.

21. DDT is used as a rodenticide.

22. DDT can have an adverse effect on beneficial animals.

23. DDT is concentrated in organisms and can be transferred through food chains.

It is not true that Sweeney found no harm caused by DDT. Rather, he found that, using a “preponderance of the evidence” test, DDT users and USDA had shown that DDT’s usefulness to agriculture outweighed the demonstrated harm.

Did Ruckelshaus ignore Sweeney’s opinion?

No, but he disagreed with substantial portions of it. Ruckelshaus quotes extensively from Sweeney’s opinion, including the findings of fact and conclusions of law noted above. He repeats arguments made by the petitioners, and describes how he differs. Choosing one example:

Group Petitioners and USDA argue that the laboratory feeding studies, conducted with exaggerated doses of DDE and under stress conditions, provide no basis for extrapolating to nature.
They suggest that the study results are contradictory and place particular emphasis on documents which were not part of the original record and the inconsistencies in Dr. Heath’s testimony as brought out during cross-examination. Group Petitioners also contend that the observed phenomenon of eggshell thinning and DDE residue data are tied by a statistical thread too slender to connect the two in any meaningful way.

Viewing the evidence as a total picture, a preponderance supports the conclusion that DDE does cause eggshell thinning. Whether or not the laboratory data above would sustain this conclusion is beside the point. For here there is laboratory data and observational data, and in addition, a scientific hypothesis, which might explain the phenomenon.

This is exactly the kind of language that sent J. Gordon Edwards ballistic (detailed discussion reserved for another post). Then as now, DDT advocates felt that the existence of studies with negative results created enough doubt that a ban could not be justified. Ruckelshaus felt just the opposite — that the bulk of the evidence supported a ban — and explained why. For eggshell thinning, 35 years of research have shown that Ruckelshaus was right. A follow-up report issued in 1975 cited 179 studies related to eggshell thinning alone (pp. 69-81). Today, a quick check of PubMed for “ddt eggshell” turns up 50 papers since 1969, and it is clear from the abstracts that the association of thinning and DDT is well established. Bald eagle populations have rebounded since the DDT ban, so successfully that they are now delisted as threatened, a result accepted matter-of-factly by wildlife biologists as a benefit of the DDT ban.

How did Ruckelshaus’ order differ from Sweeney’s recommendation?

One word: cotton. Sweeney ruled on six separate applications for DDT registration, affirming the cancellations for two, vacating the cancellations for three, and allowing a sixth to start the application process. Two of the cases where Sweeney restored the DDT registration were for public health uses: Wyco’s for treatment of mosquito larvae and Eli Lilly’s for use against body lice. Ruckelshaus permitted both applications, as well as public health use of DDT generally, but required a label restricting it to that use. As to DDT’s application worldwide against malaria (the topic of so much dispute nowadays), Ruckelshaus took pains to say that he was not restricting it:

It should be emphasized that these hearings have never involved the use of DDT by other nations in their health control programs. As we said in our DDT Statement of March, 1971, “this Agency will not presume to regulate the felt necessities of other countries.” (p. 26)

The remaining case in which Sweeney vacated the cancellation of DDT registration, permitting its use, was a biggie: USDA and Group Petitioners (31 users of DDT). These had argued collectively that DDT was “essential” for economical production of various crops and control of pests such as the spruce budworm. Of these applications, by far the most important was cotton production, accounting for at least half of all DDT consumption in the US[3]. Other crops were discussed, with sweet peppers in the Delmarva peninsula used as an example. In his order, Ruckelshaus carved out specific exceptions for several crops where DDT was considered the only acceptable alternative, and said that

… if these users or registrants can demonstrate that a produce shortage will result and their particular use of DDT, taken with other uses, does not create undue stress on the general or local environment, particularly the aquasphere, cancellation should be lifted.

The fact that a few loopholes were left open for a while does not change the fact that Ruckelshaus intended to eliminate use of DDT on crops in the US, and his order did have that effect. Even for the “essential” uses, alternatives were found and DDT was dropped. The largest impact of the order was on cotton production. And this is where it gets even more interesting. One of Sweeney’s conclusions of law (p. 94) was that

13. The use of DDT in the United States has declined rapidly since 1959.

The EPA’s 1975 report gives a table (p. 149) that I’ve represented graphically below.
DDT plot
Although exports, and overall production, continued to rise until 1963, US consumption of DDT peaked in 1959, before any significant restrictions were placed on its use, and declined steadily thereafter. A reasonable person might wonder why that would be. Guess what? The boll weevil and the bollworm were becoming resistant to DDT. Sweeney refers to this fact (p. 86) and observes that

While the evidence convinces me that the use of DDT on cotton is declining and should be reduced as soon as effective replacement means of controlling pests are developed, I do not feel that the evidence to date permits any conclusion to the effect that DDT should be banned for use on cotton at this time.

Ruckelshaus disagreed. With his order, use of DDT on cotton pests became history. The economic impact on cotton growers was significant but far from catastrophic: costs to cotton producers were estimated at $7.75 million nationally, and for consumers at 2.2 cents per capita per year (p. 193).

Even in the one arena where the DDT ban was argued to be unbearably burdensome, its use was already declining, the hearing examiner recommended that it be reduced further in favor of alternative methods, and in the event, the ban’s effects were easily absorbed. Well, then — did it have any impact that we should care about?

Glad you asked.

Returning to Steven Milloy’s DDT FAQ, cited above, we find a pearl. Robert Desowitz’ The Malaria Capers is quoted (#8):

“There is persuasive evidence that antimalarial operations did not produce mosquito resistance to DDT. That crime, and in a very real sense it was a crime, can be laid to the intemperate and inappropriate use of DDT by farmers, especially cotton growers. They used the insecticide at levels that would accelerate, if not actually induce, the selection of a resistant population of mosquitoes.”

That’s right. The 1972 DDT ban did nothing to restrict the chemical’s use against malaria, but had the effect of eliminating the single most intense source of selection pressure for insecticide resistance in mosquitos. As the rest of the world followed suit in restricting agricultural use of DDT, the spread of resistance was slowed dramatically or stopped.
By this single action, William Ruckelshaus — and, credit where it’s due, Rachel Carson — may well have saved millions of lives.

Steven Milloy is invited to add that to the DDT FAQ any time it’s convenient.

_____________________________________________________________

[1] A footnote explains that the post is “largely drawn from materials compiled by J. Gordon Edwards, professor of entomology at San Jose State University.” How much actual collaboration took place, if any, is not stated.

[2] Technically, it’s not a “decision”, but an opinion stating “recommended findings, conclusions and orders.” A fine point, to be sure, but it makes a difference.

[3] “It has been estimated that two-thirds of the DDT that is used in the United States is used in agriculture, and that 75% of the DDT that is used on agricultural crops is used on cotton.” (Sweeney, p. 83). According to the 1975 report, cotton’s share had increased to 80% by 1971-1972.

[4] UPDATE: EPA has now posted its DDT archives, complete with the Sweeney opinion, here. You can now download a better-quality copy of the opinion at a fraction of the size, so do that. If my copy is adding no value, I’ll probably take it down eventually. I see that the EPA page was last updated September 25th, roughly a month after this post. I’d like to think that my prodding was a factor, but there’s no way to know.

_____________________________________________________________

(Hat tips are due Ed Darrell, for the best historical coverage, Bug Girl, for the best scientific coverage, and Tim Lambert, for the best overall coverage of this issue.)

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34 Responses to “Ruckelshaus, Sweeney and DDT”

  1. bug_girl Says:

    Given that Edwards has been dead for quite a while, I’m guessing the collaboration was minimal.

    Thanks for this post! I’ve been too swamped lately to do much on the issue.

  2. Ed Darrell Says:

    The title for “best historical coverage” has to rest where the greatest contribution is, and right now you’ve got it with this post and the posting of the Sweeney decision.

    Great work, Jim. Thanks.

  3. Deltoid Says:

    Jim Easter on Sweeney, Ruckelhaus and DDT

    It’s often claimed by DDT advocates that the 1972 ban on the agricultural use of DDT was made in spite of a report that cleared DDT from harm. Jim Easter has found and posted a copy of the report. It…

  4. John Says:

    Hi Jim: As always an excellent post. The level of research that you put into your posts is always impressive. I bet Milloy corrects his FAQ immediately and posts a nice credit to you. Of course I also believe in the easter bunny.

    Say, that’s an idea – have you and Eli Rabbit ever thought of teaming up on a project. Who could resist an article by the “Easter-Bunny” team!!!

    Best,
    John

  5. alkali Says:

    Save your bandwidth and put the PDF up on scribd.com (just a suggestion, I have no relationship with that site).

  6. site admin Says:

    Thanks, Bug Girl, Ed and John, for the kind comments.
    And thanks, alkali, for the suggestion. If I do many more of these, space and bandwidth may become an issue.

  7. BruinKid Says:

    FYI, about J. Gordon Edwards

    Seems he couldn’t find any reputable journal to publish his anti-Rachel Carson screed “The Lies of Rachel Carson”, and so finally got it published in… 21st Century Science and Technology, which is a Lyndon LaRouche publication. That’s right, he affiliated himself with those psycho LaRouchies, who still claim global warming is a myth.

  8. Gus diZerega » More on DDT and Rachel Carson Says:

    [...] I doubt that Fred Smith and others associated with Science in the Interest of Corporate Profits will bring anyone’s attention to some new research on that front. Jim Easter at Someareboojums provides an interesting post concluding: “The 1972 DDT ban did nothing to restrict the chemical’s use against malaria, but had the effect of eliminating the single most intense source of selection pressure for insecticide resistance in mosquitos. As the rest of the world followed suit in restricting agricultural use of DDT, the spread of resistance was slowed dramatically or stopped. [...]

  9. Marjorie Mazel Hecht Says:

    The 1972 ban on DDT use in the United States in effect banned it in Africa and other tropical countries for malaria control, because U.S. AID and NGO agencies would not fund projects that made use of a pesticide banned in the United States. The U.S. AID only recently, at least verbally, gave up its ban on the use of DDT for malaria control. Some NGO groups are still agitating against DDT for indoor spraying and lobbying to change the World Health Organization’s decision in September 2006 to permit the use of DDT for indoor spraying.

  10. stewart Says:

    I was going to suggest to the last poster that she may want to review her facts. However, linking back through her name explains that fact, history, or other data associated with reality would simply be an unwanted distraction. So, she may not get the golden horseshoe, but still managed to fit 4 lies or distortions into 3 sentences. Good try for a start.

  11. Peter Barry Says:

    I know that DDT is a useful substance and it helped farmers in many ways. I know that farmers could have been a bit more careful with the usage of it. They over used the product way to much.

  12. Michael Says:

    DDT is useful? Oh, yeah, right. It does kill very well. Also is proven to cause nervous system damage particularly in children.

    Matter of fact, the supposed “polio epidemic” here in the US corresponds perfectly with the use of DDT:

    http://www.vaclib.org/intro/present/pol_all.jpg

    Funny too, how supposed “polio outbreaks” are still happening wherever in the world that DDT and its derivatives are put back into use!

  13. site admin Says:

    Well, let’s not get carried away here.
    I am aware of only one study showing nervous system damage from DDT. It examined workers in Central America who participated in mosquito eradication programs, and were exposed to very high doses of the chemical. There may be other such studies; please cite them and I will be happy to read them. DDT is associated with low birth weight and early weaning of infants where it is used, so there is an impact on children. On the whole, though, DDT’s acute toxicity to humans is low — that is one reason why it became so popular. The reason DDT was banned for agricultural use in the US had more to do with its proven adverse effects on wildlife and its persistence in the environment than its effects on human health. DDT is considered a probable human carcinogen because of its chemical similarity to other known carcinogens, and the fact that it causes cancer in some animals.

    The polio epidemic in the US was not in any sense “supposed” — it was very real. Polio is a viral disease transmitted from person to person. It has nothing to do with DDT. The graphic to which you linked seems to be mistaken in several areas. For example, the label “Worldwide: No Previous Paralytic Polio Epidemics” and the accompanying arrow pointing to the year 1870 is in error. Polio was known to antiquity, and reported in Europe and the US during the 1700s and early 1800s. The plot is labeled “Acute Poliomyelitis (“Infantile Paralysis”) Cases in the United States 1870 – 1998.” It shows a resurgence of polio to over 50,000 cases starting in 1983. This never happened, in the US or worldwide. There are many errors in the DDT timeline as well.

    Polio was, and is, a terrible disease. It has, thankfully, been eliminated in the US and much of the world through childhood immunization — perhaps the most beneficial public health measure in the history of medicine.

  14. Tom Stark Says:

    I compliment site admin for setting Michael straight on his inane ejaculations, for polio is indeed viral and is not linked in any way whatsoever with DDT; DDT is not toxic to humans, as Paul Muller went out of his way to demonstrate, and did a fairly convincing job.

    And yet the author of this article makes a number of small factual blunders, which, however small, do accumulate, so that by the end of the article one is left wondering at the author’s exact intent: is it scientific or activistic? The preponderating number of errors made in this article take the form of a rather sloppy and offhand style — to wit:

    “Bald eagle populations have rebounded since the DDT ban … a result accepted matter-of-factly by wildlife biologists as a benefit of the DDT ban.”

    Ideally, you’d want to cite your references to such a matter-of-fact claim, but in any case I, for one, can promise you that this wildlife biologist, as well as most wildlife biologists I’ve ever worked with, including my old man, certainly do not accept that, neither matter-of-factly nor otherwise. On the contrary, did you know there have been numerous studies, by, for instance, the United States Fish and Wildlife Service, the Game and Fish, the United States Forest Service, and even the National Audubon Society, among others, that have concluded the opposite of your matter-of-fact claim?

    I remember one study in particular, conducted in the mid 1960’s, wherein wildlife biologists actually fed bald eagles raw DDT for over three months, and that study found no adverse health effects, on either the eagles or their eggs.

    Another study, conducted by the Wisconsin Forest Service, found that from 1962 through 1972, there was an increase in bald eagle productivity.

    The old man was part of a large and exhaustive study, lasting from 1960 through 1977, which examined every single dead bald eagle found within that time frame, and do you know what they discovered? No deleterious effects associated with DDT in any of the bald eagle corpses.

    Although the Audobon Society has always been very sympathetic to Rachel Carson’s claims, they nonetheless reported that “no extinctions or significant loss to bird populations came about through the use of DDT…. Of 40 birds Carson said might by now be extinct or nearly so, 19 have stable populations, 14 have increasing populations, and seven declined.”

    But that’s only the beginning: of declining bird populations, we’ve found within them everything from organochlorine pesticides to pyretheum to rotenone, to much else. But little or no DDT.

    The fact of the matter is that bald eagle populations were declining as early as the 1920’s — there were once huge sums of money offered for dead bald eagles — and New England was devoid of bald eagles before DDT was ever invented: i.e. by 1940. The bald eagle’s comeback was primarily the result of outlawing the killing of these animals, and private conservation measures as well. In fact, to this day, a great many eagle nests are located on private land.

    Please understand, it is not my intention here to defend the use of DDT, but rather to point out that this issue runs deeper by far than most people, even scientists, often realize. It is much more complex than either you or Lambert are evidently aware. A great many of us have studied DDT for a great many years, and I promise you, friend, all activism aside, we have firsthand experience with it, and no matter what you think, DDT has incalculable benefits, which to this day no other chemical alternatives can match, cost being only one of several. So let me just say with all due respect that, irrespective what your political ideology tells you to think of DDT, DDT has incontrovertibly saved millions upon millions upon millions of human lives, and it has killed comparably few birds.

    I’d like to point out lastly that when Rachel Carson writes the following: There once was a town in the heart of America where all life seemed to live in harmony with its surroundings. The town lay in the midst of a checkerboard of prosperous farms, with fields of grain and hillsides of orchard where, in spring, white clouds of bloom drifted above the fields. In autumn, oak and maple and birch set up a blaze of color that flamed and flickered across a backdrop of pines. Then foxes barked in the hills and deer silently crossed the fields, half hidden in the mists of the fall morning… The town is almost devoid of robins and starlings; chickadees have not been present for two years, and this year the cardinals are gone too… ‘Will they ever come back?’ the children ask, and I do not have the answer.

    When she writes nonsense like that, apart from its being embarrassingly overwritten, sir, you can be certain that you’re not dealing with science, but pure, unadulterated activism. And that, as you may or many not know, is poison to real science.

  15. site admin Says:

    Tom –
    Your comment is much appreciated.
    Actually, I researched the subject of DDT and bird reproduction at some length before writing the passage you cited.
    You quote the passage “Bald eagle populations have rebounded since the DDT ban … a result accepted matter-of-factly by wildlife biologists as a benefit of the DDT ban.” and say

    Ideally, you’d want to cite your references to such a matter-of-fact claim …

    The word “rebounded” is a link to an article in Science. Here’s the abstract:

    Ban of DDT and subsequent recovery of Reproduction in bald eagles
    JW Grier

    Reproduction of bald eagles in northwestern Ontario declined from 1.26 young per breeding area in 1966 to a low of 0.46 in 1974 and then increased to 1.12 in 1981. Residues of DDE in addled eggs showed a significant inverse relation, confirming the effects of this toxicant on bald eagle reproduction at the population level and the effectiveness of the ban on DDT. The recovery from DDE contamination in bald eagles appears to be occurring much more rapidly than predicted.

    The phrase “delisted as threatened” is another link, also to a study published in Science, in which a graph of bald eagle population is shown, with this caption:

    Upswing. Banning DDT has helped the national population of breeding bald eagles to grow. The data come from state surveys, which are not all done every year.

    (There is nothing unusual about the coverage of DDT in Science, by the way. You can search PubMed for “ddt bald eagle” and turn up 14 abstracts telling substantially the same story. I cited Science because I have full-text access to that journal, and could confirm that I was quoting the articles accurately.)

    It is very possible that, as you suggest, I have missed some of the complexity of this issue. Just to balance the books, however, let me point out that you missed the two cites to the literature provided, leapt to an unwarranted conclusion about my motivation, and seem to have overlooked a large and convincing body of evidence in the scientific literature regarding DDT and bird reproduction.

  16. Tom Stark Says:

    Hello Site Admin,

    Thank you for your excellent reply. I apologize for my cunctation. It’s not exactly easy to get to your computer when you’ve just gotten married and your knob is being polished pretty near 24/7.

    Actually, to respond to your closing comments, I didn’t miss your two cites, as you say, but simply couldn’t access them, and still can’t. But that’s academic. I already know that those cites don’t demonstrate that this collective you call “wildlife biologists” matter-of-factly accept that banning DDT is responsible for the rebounding bald eagle populations; for, among other things, and as I pointed out, many, like me, who belong to this wildlife biologist contingent don’t accept that conclusion, matter-of-factly or otherwise, and that fact alone, no matter how many abstracts PubMed pulls up, proves that your matter-of-fact assertion is not accurate.

    It’s worth reiterating also what I presume you already know: DDT wasn’t even around when bald eagle populations began to diminish.

    Also, anent my unwarranted conclusion regarding your motivation, I do apologize. And yet, if I may speak candidly, I see nothing so far to convince me that it is unwarranted. Please, I mean no disrespect.

    Concerning your final clause: friend, you bring us right back to where we started. And so I guess that’s that.

    Best of all possible regards,

    TS

  17. site admin Says:

    Hey, fair enough.
    All the literature I surveyed showed a strong consensus that DDT really does harm birds. The most recent of the articles I read started thusly:

    Just 40 years ago, the bald eagle seemed headed for extinction in the conterminous United States. Nesting females were accidentally crushing their eggs, which were weakened by the ubiquitous insecticide DDT. Populations spiraled downward. By 1963, only 417 pairs were still raising young in the lower 48 states.

    But the national icon began to bounce back after Congress banned DDT in 1972 and passed the Endangered Species Act (ESA) in 1973. Last year, there were nearly 10,000 successful breeding pairs.

    You say

    It’s worth reiterating also what I presume you already know: DDT wasn’t even around when bald eagle populations began to diminish.

    Wait a second. Go back and read Grier’s abstract supra. DDT sure was around during the bald eagle’s decline in the 1960s, and there is a strong negative correlation observed between DDT/DDE concentrations and eagle reproductive success. There is a ton of published research showing that DDT and its metabolites are harmful to birds. And to the contrary, we have … what? It’s just not even a close call.

    From all this, I assumed that wildlife biologists generally accepted that there exists a scientific consensus on DDT and birds. With you as a counterexample, I’ll have to concede that the acceptance is not universal. But I hadn’t communicated with you when I wrote this post. All I can do is read the literature. So — tell you what: point me to your articles, or any peer-reviewed studies concluding that DDT is harmless to birds, and I’ll be delighted to read them.

    Oh, and congratulations.

  18. BDAABAT Says:

    First, thank you for the investigative work! Interesting that the EPA found the document and managed to post it after your investigation. :)

    RE: finding info by looking in Medline/PubMed… just a reminder that Medline only goes back to the mid 1960s. Also, that many of the publications where this type of research was performed (feeding studies of DDT in bird populations, tissue studies of DDT in wild bird populations, etc) are not index-able from Medline. So, just because it’s not easily found from searching currently available on-line databases doesn’t mean the data doesn’t exist. It’s just harder to get to (like the info you dug up!).

    RE: Hearing findings…your summary of Judge Sweeney’s findings isn’t exactly complete…the nuances you provide don’t seem to square with what was actually written.

    You wrote:
    “It is not true that Sweeney found no harm caused by DDT. Rather, he found that, using a “preponderance of the evidence” test, DDT users and USDA had shown that DDT’s usefulness to agriculture outweighed the demonstrated harm.” Sounds like he’s equivocating and isn’t really solid on the case FOR DDT.

    What was actually written: page 3 of the decision, Sweeney wrote:
    “To be considered in the determination of the particular fate of the registrants in question, there has to be a preponderant showing that the present use causes an unreasonable adverse effect.

    That showing has not been made. That preponderance is the burden of the Respondent. I arrived at that conclusion by the application to this case of the rule of evidentiary burdens in an adjudicatory proceeding. In this case, the issuance of the PR Notices constitutes a prima facie case for cancellation. The burden of proof was on the Petitioners to overcome that prima facie case by a preponderance of the evidence That has been done by proving that the label-language for essential uses of DDT is adequate to accomplish the statutory purpose of the the three “misbranding” sections (the first issue herein). Likewise, there has been proof that, on balance with the benefits, the present essential uses of DDT, under the registrations in question, do not create an unreasonable risk (The other issue herein).

    On the last page of his decision, Judge Sweeney notes that…
    “Although it was not in issue here, there was ample evidence to indicate that DDT is not the sole offender in the family of pesticides; and that necessary replacement would in many cases have more deleterious effects than the harms allegedly caused by DDT.

    In my opinion, the evidence in this proceeding supports the conclusion that there is a present need for the essential uses of DDT; that efforts are being made to provide a satisfactory replacement for DDT; and that a co-operative program of surveillance and review can result in continued lessening in the risks involved.”

    Shows that the folks bringing the case did not meet the burden of proof that they claimed (and they seemed to have gone into great detail about labeling of the product!) and that DDT was being painted with a very broad toxic brush, and that there were still appropriate reasons to use DDT… not the least of which was that the replacements were MORE toxic (which they surely were/are).

    Thanks!
    Bruce

  19. site admin Says:

    It is good to see that thoughtful people have given this post a careful reading.
    I stand by my statement that Sweeney acknowledged DDT’s harmfulness to wildlife, but did not find enough harm to justify banning its use in agriculture.
    That was the part of the opinion Ruckelshaus disagreed with.
    As time permits, I’ll assemble some of the background research and post it.

  20. BDAABAT Says:

    Well, Judge Sweeney did acknowledge that under certain circumstances that DDT could be toxic to some animals, but not most and not under most circumstances. That’s not really news though, is it?

    The reality is that Judge Sweeney was present, heard all of the testimony, considered all of the evidence, and came to the conclusion that the standard for de-listing had not been met, that there WAS still a need for DDT, and that there were no better agents available.

    Interesting… Ruckelshaus was not present for ANY of the hearings… it’s unclear how much testimony he actually read or how he made his decision to overturn his own hearing examiners opinion. It’s quite curious that he came to opposite conclusions without having the benefit of actually being present to hear the arguments and participate in the process. He just read up on it and made a decision. Not exactly the ideal approach, wouldn’t you agree?

    If that’s the standard he used, why have the hearing in the first place? Why not just collect data from all involved and then read up without the process of a hearing? Very, very curious.

    BTW: would suggest looking for info in a nifty text like Hayes Handbook of Pesticide Toxicology. It’s a treat to see references to early studies of DDT like that of Fennah. This guy was so concerned about the potential toxic effects of indiscriminate DDT use that he dosed himself and observed the findings! In one test, he exposed himself daily to 100 mg pure DDT by mouth and drank water dusted with DDT at a rate of 3240 mg/m*m (again, he did this EVERY DAY!) for 11.5 months. He did all kinds of things to himself with DDT, but never developed toxic effects.

    Bruce

  21. site admin Says:

    Bruce, you seem to be missing the point. DDT’s acute toxicity in humans is very low; that is why it became popular for uses such as delousing to control typhus. DDT is so good at these targeted applications that it should have been reserved for public health use — which was the intent and effect of the Ruckelshaus decision. The massive overuse of DDT on crops (about 1.35 billion pounds had been used in the US by 1974) led to widespread resistance among disease-carrying insects, a Very Bad Thing.

    Truth to tell, I am starting to lose patience with this relentless fussing about how Ruckelshaus supposedly blew off the hearings, ignored Sweeney’s arguments, etc., etc. It is clear from Ruckelshaus’ decision that he reviewed the evidence presented at the hearings in great detail, and gave careful consideration to the arguments from both sides. He didn’t agree with Sweeney; so what? It was his job as EPA Administrator to make a decision, and history shows that he made the right one.

  22. BDAABAT Says:

    I think I’ve got a pretty good idea of the point. :D

    The reality is that Ruckleshaus made the decision without hearing the evidence. That is not in question. He didn’t attend. He didn’t participate. He just read.

    That’s not “relentless fussing”… it is what it is.

    How much he read is not known. But, he took a position that overruled his own hearing judge who HAD been present, who HAD heard the arguments over a period of 7 months, and who HAD read the material. Seems a bit strange, doesn’t it?

    You may choose to lionize him for the decision or for his decision to resign rather than comply with Richard Nixon’s nutty orders to fire Cox. But the impact of the decision to delist DDT was huge. It had a dramatic impact on millions of lives around the world, and not in a positive way.

    Bruce

  23. site admin Says:

    If you really believe that DDT’s low acute human toxicity is a telling point in your favor, then you have missed the point by a country mile.

    I assume you did original research convincing you that Ruckelshaus was not present at the hearings. Good for you! But it still has no bearing on whether or not Ruckelshaus understood Sweeney’s opinion and responded to it fairly. He did.

    Now, you may not be aware of it, but there are folks who don’t do their own research, but pick up some talking point such as “Ruckelshaus was never present at the hearings” and tout it as fresh, and powerful, and convincing. It is relentless fussing over irrelevant baloney, and I have no time for it.

    The decision to restrict DDT’s agricultural uses had far-reaching and enduring effects. Everything I have learned about the subject tells me that those effects were overwhelmingly positive. The single most important benefit of the decision was that DDT retained some effectiveness against disease vectors — something that Ruckelshaus’ critics never seem to bring up.

  24. BDAABAT Says:

    The point about human toxicity isn’t really the issue. I included reference to human toxicity because the reality is so much different than the perception.

    So, let’s get to The issue: what was the process that was used to delist DDT??? And, what was the impact of that decision?

    The process: 7 months of hearings presided over by Sweeney. Much back and forth between the different groups that were testifying. NGOs, academics, industry all had their say. His decision was that the case had not been made the the benefit outweighed the risk.

    Next, his boss who wasn’t present for the meetings decided for whatever reason that he was going to overturn the hearing examiners decision. He, by definition, had LESS information available to him than his hearing examiner. He didn’t hear the arguments himself. He read the summary information. Yet, he decided that the evidence said something else. This is curious. It’s not being touted as something “fresh”. It’s old. It’s also contrary to what many people believe. And, it calls into question the process and decision making that Ruckleshaus used to decide to overturn the original decision.

    RE: Impact of delisting DDT. The effective ban in the US was used as a tool to force other countries to ban it’s use and force the WHO to ban it’s use. The alternatives were not as helpful in the fight against malaria, were and are much more toxic, and were much more expensive. The impact is that millions of people died. Not sure how you can spin that into an “overwhelmingly positive” impact. Estimates from researchers at NIH are that 20 million children have died as a result of restricting DDT use… Which is why after 30 years, WHO is now encouraging DDT use in areas that are prone to malaria. Why did it take 30 years to overturn it’s original decision? Those same NGOs who brought the case before the EPA in the US were fighting to prevent it’s use world wide.

    So, yes, banning DDT in the US did result in “far reaching and enduring effects”, just not in the way that you portray.

    Bruce

  25. site admin Says:

    The effective ban in the US was used as a tool to force other countries to ban it’s use and force the WHO to ban it’s use.

    When did the WHO ban use of DDT?

  26. BDAABAT Says:

    Sorry, should I have used the term, “phasing out” instead:
    http://www.malaria.org/DDTpage.html

    Countries using DDT had to ask for “exemptions” in order to use it to save their own people.

    Malaria prevention programs were pressured by outside governments and NGOs to not use DDT. DDT is one of the agents listed in the famous 12 “POP” that many groups are STILL trying to ban… which is why the change in the WHO stance is so remarkable.
    http://www.malaria.org/bateftddt.html

    Clipped from the above link at malaria.org:
    “Not long after DDT was removed from malaria control in South Africa in 1996, disease rates rocketed, particularly in northern KwaZulu Natal. A serious problem was that Anopheles funestus mosquitoes developed resistance to synthetic pyrethroids – the main alternative to DDT – making the switch an expensive and futile exercise. According to Rajendra Maharaj, head of vector control at the South African department of health, it is unlikely that A. funestus would ever have returned had DDT remained in use.”

    One need only compare malaria rates in South Africa, Swaziland and Mozambique to see the effect of banning DDT. Swaziland never halted DDT spraying and infection rates range between 2 and 4 per cent. A short distance over the border in South Africa, infection rates average about 40 per cent. In Mozambique, infection rates are over 80 per cent, owing in part to the collapse of the malaria control programme during that country’s war. The cash-strapped Mozambican government is now trying to control the disease by using pesticides that are four times as expensive as DDT.

    DDT is now back in use in KwaZulu Natal and according to Jotham Mthembu, head of the malaria control programme at Jozini in KZN, conditions have improved. Gerhard Verdoorn of the Endangered Wildlife Trust, the South African green group, has given his approval to the use of DDT and even trained sprayers. “DDT is used in tiny quantities and there is simply no prospect of any environmental damage arising from its use,” he says.

    Malaria kills more than 1m people and afflicts more than 300m every year throughout the world.

    Not only are people unable to work effectively when ill, causing enormous losses in productivity, but the disease also scares investors away because of the prospect of having one’s workforce – local and expatriate – ill and unable to work. Jeffrey Sachs of the Harvard Centre for International Development estimates that malaria destroys about 1 per cent of Africa’s wealth every year.”

    The result? Millions of people died needlessly.
    http://www.nature.com/cgi-taf/DynaPage.taf?file=/nm/journal/v6/n7/full/nm0700_729.html

    Clipped from http://www.malaria.org/bateftddt.html

    At the UNEP meetings this week, bureaucrats from the developed world are deciding the fate of many millions of people at risk from malaria in the developing world. Even if UNEP does not ban DDT for malaria use, it is certain to be “listed”, entailing onerous reporting requirements.

    Last year the World Health Organisation said 23 countries used DDT for malaria control. Yet only 14 have asked for exemptions. Mexico and Colombia have stockpiles but the rest may be concerned that they will lose donor aid if they ask for exemptions to spray DDT for malaria control. Merely placing DDT on the UNEP list will make it more expensive, reduce its use and expose more people to malaria.

    DDT is safe and cheap – and it saves lives.

    So, again, how does your research tell you that the ban had beneficial effects?

    Bruce

  27. site admin Says:

    Did you pause to reflect for a moment when it turned out that your statement

    The effective ban in the US was used as a tool to force other countries to ban it’s use and force the WHO to ban it’s use

    was not true?

    The ban on agricultural uses of DDT halted or slowed the spread of resistance to the chemical among insects that carry disease. Because malaria-carrying mosquitoes remained vulnerable to some extent (not completely, though; even today every single malaria vector in Africa has some resistance to DDT) strategies using indoor residual spraying had a chance to work. If blanket spraying of crops had continued, DDT would very likely be useless in fighting malaria today. Preventing that outcome has been very beneficial indeed.

  28. BDAABAT Says:

    Wrong. current use of DDT for malaria control isn’t solely related to direct application of DDT on water or spraying large areas. DDT use for malaria control is effective when used to spray homes and to spray on bed nets. Mosquitos don’t like to be around DDT even if they have become resistant to it.

    BTW: Check your logic.
    What on earth would you “save” DDT FOR if not to prevent wide spread disease and death?

    So, no, don’t try to imply that “preserving” use of DDT was some noble act or in some way beneficial. It wasn’t. Efforts to block use of DDT lead directly to millions of deaths.

    Bruce

  29. BDAABAT Says:

    BTW: Did you “reflect” at all about the millions of people who have died as a direct result of the efforts to ban DDT?

    Did you “reflect” on how DDT might get produced when the worlds major markets for the stuff have dried up due to bans in the developed world and continued pressure on other countries to not use it? How the inclusion of DDT to the Stockholm convention would mean the meager market that currently exists for DDT would completely evaporate?

    Bruce

  30. site admin Says:

    You have done a good job of reciting the “DDT ban killed millions” narrative.
    The only problem with that narrative is that every part of it is wrong.
    DDT has never been banned for public health use, in the US or elsewhere.
    The ban on agricultural use helped the fight against malaria by slowing the spread of resistance. If you doubt this, go back and read the link you provided. Malaria Foundation International is pleased that DDT is not banned, and that its continued use in disease prevention is protected by treaty. DDT was never banned for disease control, and the 2000 POP treaty reinforced that status.
    Note that the press release stresses that the treaty “restricts DDT use and production to disease vector control only (not agriculture)” and goes on to say

    For the first time, there is now an insecticide which is restricted to vector control only, meaning that the selection of resistant mosquitoes will be slower than before.

    My question about whether you had reflected on your statement was directed at whether you cared that it was wrong. The WHO, as you now know, never banned DDT. You were mistaken, but that’s not a problem. You didn’t care that you had been wrong, and that is a problem
    Now, I realize that this is an emotional issue for you. There has been an intense disinformation campaign aimed at spreading the “DDT ban killed millions” meme, and many people such as yourself have become deeply invested in defending it. To admit that the whole thing is a steaming crock is probably not possible for you now –but you might want to go back and do your research before digging yourself in any deeper.

  31. BDAABAT Says:

    Ban? Sorry, “restricted use”. Impact is = ban. DDT has been petitioned in US previously. Was denied.

    US and European NGOs fought against use of DDT throughout the world (and continue to do so). Pressuring other countries to NOT use it. How? By threatening sanctions of export crops and external aid funding.

    RE: thanking the rest of the world community for “severely restricting use to prevent resistance”. This was from an organization that was BEGGING to allow DDT use.

    Guess you happened to miss the links above called, “How Good Intentions Can Kill”.

    Bruce

  32. BDAABAT Says:

    So, what word would you use instead of “ban”?

    The impact is the same.

    And, what about the reported “environmental impact? Not so much:
    http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=1173321
    Bruce

  33. BDAABAT Says:

    BTW: you can talk all you want about the difference between DDT being banned or “restricted”, but that’s really just semantics. And, you know this, but you continue to play games.

    Robert Gwadz of NIAID called it a “ban” that killed an estimated 20 millions children. http://www3.niaid.nih.gov/labs/aboutlabs/lmvr/internationalStudiesMalariaEntomologySection/ Here’s the link to the National Geographic article that quotes Dr. Gwadz and the 20 million children who died as a result of the DDT ban. http://ngm.nationalgeographic.com/ngm/0707/feature1/text4.htmlSo, it’s not a “meme” when the chief of the National Institute of Allergy and Infectious Disease Laboratory of Malaria and Vector Research tells others that the ban of DDT has killed millions of children, is it? And you’re a bright person.. you already know this.

    Bruce

  34. site admin Says:

    [Y]ou can talk all you want about the difference between DDT being banned or “restricted”, but that’s really just semantics. And, you know this, but you continue to play games.

    There is a wonderful kind of symmetry operating here. Your point seems to be that whatever the WHO did about DDT (although you don’t know of anything in particular), it must have been a ban, and it must have cost millions of lives. Right?
    I suggest you rethink just who is “playing games.”

    I dropped this thread a month ago because there are just so many hours in a day, and the subtopic of DDT “ban” baloney deserves a post of its own. The same is true for Tom’s comments on DDT and bald eagles. So — thanks to both of you, and I’ll get both of those subjects up top before too long.

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