By the mid 1980s (as I’ve written here and here in this series), in response to the findings that Alar (and its breakdown product UDMH) were probable human carcinogens and that EPA had begun the process to ban it, several supermarket chains, including Krogers, Safeway, Giant, A&P and Grand Union, and a number of food manufacturers, including Gerber, Heinz, Beech-Nut, Martinelli, Welsh and Seneca Falls, had pledged to stop stocking or processing Alar-treated apples.
It’s not clear whether they just didn’t honor their pledge or doing so proved harder than it sounds, but a 1988 market basket survey conducted by an independent laboratory in Oakland, CA revealed that 30 percent of the apples for sale in Safeway contained Alar.
Now it’s 1989, and in January, EPA received preliminary results from mouse studies that Uniroyal began in 1987. Having proposed it would ban Alar in 1985 and then deciding it wouldn’t, EPA reversed its position a third time and announced on February 1, 1989 that it had decided to “speed up the process” to remove Alar from the nation's food supply.
In a press statement, Acting Administrator John A. Moore said Uniroyal's studies of Alar and UDMH showed that UDMH clearly caused cancer in mice and Alar probably did. "There is an inescapable and direct correlation between exposure to UDMH and the development of life-threatening tumors in mice," Mr. Moore said. Because Alar contains UDMH as a contaminant, and because Alar breaks down into UDMH when heated, or when metabolized in the human stomach, EPA had decided to propose banning Alar/UDMH.
Moore also said that, based on the Uniroyal studies, EPA had calculated the hazard of cancer among people exposed to UDMH in Alar for a lifetime; he said the hazard was 45 per million, which is 45 times as high as the one-in-a-million hazard EPA considers "negligible."
Though in fits and starts, EPA seemed to be moving in the right direction. So it was altogether confounding when Moore declared in the same February 1st speech that EPA was extending Uniroyal’s license for Alar on apples for another 18 months, until June 1990. The agency appeared weak and incapable of removing a hazardous farm chemical from the food supply.
And that’s when NRDC released its lengthy report, “Intolerable Risk: Pesticides in Our Children’s Food.” The evening before, 60 Minutes aired its “A is for Apples” segment. Approximately 40 million people viewed the program. As mentioned in previous posts, NRDC’s study was about much more than Alar. Its three main findings were:
-- The cancer hazards to children from pesticides were much higher than government officials said they were because children have quite a different diet from adults (and are very likely more sensitive to carcinogens than adults are).
-- Many pesticides are known to affect the central nervous system and children are more likely to suffer these effects than adults are.
-- The government's process for getting hazardous pesticides out of the food supply is too cumbersome and slow to protect public health.
By stressing Alar in the first few minutes of its 60 Minutes program, CBS News skewed coverage of the NRDC report to a point where people today think that it was the singular focus of both. Important findings, that some 3 million U.S. children regularly eat combinations of brain-damaging pesticides at exposure levels greater than allowable EPA standards, disappeared from view in the flurry over Alar.
Alar/UDMH however did top NRDC’s list of farm chemicals posing cancer risk to children so it was not inappropriate for 60 Minutes to make it the focus of their story. And it was certainly a nearly perfect example of a failed regulatory system. NRDC's report said that, among 22 million U.S. pre-school children, 4,700 to 6,000 would eventually get cancer from exposure to Alar/UDMH. This translates into about 250 cancers per million children.
An angry public reacted swiftly and decisively, essentially boycotting apples. Schools removed them from the menus, and unnerved parents rushed their supermarkets demanding pesticide-free and organic varieties.
The government sought to calm the public but completely mishandled it. Clearly stung by NRDC’s findings, EPA acting chief John A. Moore launched a counter-attack, charging that:
-- NRDC's report was "gravely misleading" because it "relied on data that had been rejected in scientific peer review, along with food consumption data of unproven validity."
-- EPA's calculations "allow us to ensure that no particular group--such as infants and children--receives exposure that is likely to cause unreasonable risks."
-- EPA's assessment of the Alar hazard was "severely at odds" with NRDC's assessment. He said NRDC's hazard estimates are "up to 100 times higher than EPA's estimates."
The EPA was grasping. As we’ve seen, none of its arguments proved valid. On the first point, NRDC used food consumption data gathered by federal government itself in 1985, while EPA’s data was gathered in 1977. The more recent data showed that daily fruit consumption by pre-schoolers had increased 30 percent since 1977. Though the 1985 data was based on a smaller sample, it was still the best estimate of food consumption by Americans available in 1989 and more suitable for Alar risk assessments than the 1977 data.
As for Moore’s second charge, though EPA may have been concerned about the possibility that infants and children may be more sensitive than adults to the toxic effects of pesticide residues on food, the Agency was not taking any steps to ensure this subpopulation were adequately protected. In fact, the EPA’s risk calculations treated the entire population as adults, a practice NRDC’s report sharply criticized.
On the third point, you can do the math. NRDC estimated that 250 out of each million of children exposed to Alar/UDMH in the food they eat would get cancer. This is approximately 5 times the 45/1,000,000 estimate the Agency had just announced earlier in the month, not 100. Math errors aside, as risk assessments go, they were remarkably similar.
The government also sought to reassure the public that apples were safe and so in a press release it claimed that only 5 percent of U.S. apple crop was treated with Alar in 1988, and that routine monitoring often find no Alar or only traces well below the allowable limit. This wasn’t particularly reassuring given that NRDC’s report also took direct aim at the allowable limit government had set, arguing that it was too high.
But more importantly the Agency’s claim wasn’t even remotely true. On March 3, just a week after the 60 Minutes story broke, Consumers Union (publisher of Consumer Reports) issued a report indicating that 55 percent of the raw apples and three-quarters of the adult apple juice it tested contained Alar, even though apple processors and grocers claimed to have stopped accepting Alar treated apples and apple products.
Consumers Union criticized the FDA for using antiquated and insensitive laboratory techniques that could not measure Alar below 500 parts per billion (ppb), stating in Consumer Reports: "Looking for daminozide [Alar’s a trade name] in apple juice with PAM II [the test method used by FDA] is like trying to catch speeders with a radar gun that doesn't work for speeds under 100 mph." FDA would subsequently adopt the more sensitive test method recommended by Consumers Union.
Several state governments and news organizations, following Consumers Union lead, conducted surveys of their own. Their tests found Alar in 22 percent to 79 percent of red apples all across the country. As it turned out, Consumers Union’s estimate was pretty close to the average.
It was a low point for government credibility; officials were either misinformed or spreading misinformation. But as the campaign against NRDC continued, misinformation was replaced with disinformation when the apple industry hired the large PR firm of Hill & Knowlton to contain damage of the various reports.
In the first advertisement prepared by Hill & Knowlton, the industry argued that one would have to eat a box-car load of Alar-treated apples every day to be harmed.
This of course is the standard industry misrepresentation of the way risk assessments are conducted and completely dishonest. All government risk assessments are performed by extrapolating from high dose animal experiments to the lower exposures expected in the human population. This methodology has been proven valid by the most respected research institutions in the world.
Even John Rice of the International Apple Institute admitted in a public forum in June 1989 that the “box car” argument was dishonest. But he claimed the ads were justified because the industry was upset, particularly with the use of the skull and cross bones imagery in the 60 Minutes piece.
With all parties near the boiling point, on May 24, 1989, EPA issued a “preliminary determination” proposing cancellation of the food uses of Alar. While continuing to claim the chemical is safe, Uniroyal voluntarily removed in June 1989 Alar from U.S. markets for all food uses. (It continues to market it abroad and in the United States for use on flowers.) Uniroyal formally filed its “voluntary cancellation request” for food uses of Alar with EPA in October. The Agency published a cancellation order in November, revoking tolerances for Alar in or on tomatoes, milk, meat and eggs effective the following March and set lower interim tolerances for apples, peanuts, cherries, peaches, pears, nectarines and grapes. These lower tolerances were set to expire in May 1991.
I’ll report in the next post on the apple growers’ suit against NRDC and CBS’ 60 Minutes, what happened to the suit, and what happened to the truth.
1. Alar: Not Gone, Not Forgotten." Consumer Reports 52 (May 1989): 288–292.