It was once said that if the EPA could ban DDT (which has probably saved half a billion human lives), it could ban anything. As Dr. J. Gordon Edwards explained at the 1999 annual meeting of DDP, Congress has recently given the EPA the power to do just that.

The Food Quality Protection Act (FQPA) of 1996 states that the EPA may ban any chemical, unless they believe "there is a reasonable certainty of no harm from the total amount of that chemical in the aggregate of food, water or residential use."

The EPA will be in charge of defining the terms, including "is," "no," "harm," "certainty," and "reasonable." Aiding them in the definitions will be nonscientists from "environmental" organizations, who will sit on the Tolerance Review Assessment Committee (TRAC), which is to reassess, between 1996 and 2006, tolerances for each of the thousands of chemicals in food and liquids available to human beings and other life forms. One way to implement the FQPA, according to a remark by the Director of EPA's pesticide programs, would be to revoke all insecticide tolerances and start over. (This may not be a joke.)

By August, 1999, the EPA must complete analyses of 3,000 pesticides, including organophosphate and carbamate insecticides. These categories include about three-fourths of the pesticides needed to protect American crops, upon which our balance of trade is dependent. (All of these are probably more toxic than DDT.)

A clue to the EPA's standard of "reasonableness" is that the agency has defined frost to be an agricultural pest. This enables it to declare a strain of Pseudomonas syringae, which prevents frost from damaging plants, to be a pesticide (C.E.I. Update, April, 1999).

If bacteria are pesticides, then so are plants genetically engineered to produce compounds that kill pests. The EPA is seeking to ban, as a pesticide, every individual plant that has Bacillus thuringiensis incorporated into its genotype.

And what about plants not genetically engineered by human beings? Dr. Bruce Ames of the University of California at Berkeley points out that edible plants may contain natural pesticides constituting as much as 5 to 10% of the plant's dry weight. He states that "we are ingesting in our diet at least 10,000 times more, by weight, of natural pesticides than of man-made pesticide residues" (Science 236:271-280, 1987). Of those that have been adequately tested, more than half were found to be carcinogenic. (Yet, a diet containing at least five servings of fruits or vegetables daily protects against cancer.)

Could the EPA shut down American agriculture? They shut down U.S. Steel in Gary, Indiana, by imposing "abatement" costs that would have come to about $1 trillion as a condition of continued operation, stated Dr. Edwards.

[Around 1994, some Congressmen were interested in seeking a reasonable certainty of no harm from government agencies, and in repealing the Delaney Clause. The legislative process can have results the opposite of those originally intended.]

In Dr. Edwards's audiences, many think that a part per billion is more than a part per million. One ppm is like adding one penny to a pile of pennies worth $10,000; a ppb is adding one penny to a pile worth $10 million dollars. Or: a ppm is one jigger of vermouth in an 8,000 gallon railroad car full of gin. One ppb would be that same jigger in the total contents of 1,000 of those tank cars.

The EPA has the power to destroy an entire crop if the concentration of a pesticide exceeds the "tolerance" level in ppm, or perhaps even ppb, established by EPA employees. There are no bases for citizens to challenge the "no harm" limits.

Even though the government has the power to force babies to be vaccinated, there is no pretense that vaccines have a reasonable certainty of no harm.

Last month, rotavirus was on the list of "recommended" vaccines for infants, to protect against a common, self-limited diarrheal illness, which causes about 500,000 doctor visits per year, 50,000 hospitalizations, and 20 deaths. The treatment is rehydration, orally as with Pedialyte, or by intravenous solutions if necessary. The oral vaccine was said to prevent 50 to 70% of rotavirus illnesses, and 70 to 90% of severe cases. The main concern of many pediatricians was how to get the HMO to pay for it (cost, about $240 for three doses). There has also been an effort to have the vaccine mandated by states; the Texas legislature recently rejected such a mandate.

Information from the CDC web site, dated 3/23/99 reads: "A vaccine, like any medicine, is capable of causing serious problems, such as severe allergic reactions. The risk of a vaccine causing serious harm, or death, is extremely small. In studies that have been done so far rotavirus has been associated only with mild problems."

On July 15, the CDC recommended postponing the vaccine while studies are being analyzed. Between September 1, 1998, and July 15, 1999, the CDC received reports of 23 cases of intussuception in vaccine recipients. This condition, in which part of the bowel telescopes into another part, can result in a surgical emergency. Parents whose babies have already received the vaccine are now being advised to watch for severe vomiting, severe colic, bloody or black stools, and abdominal bloating. CDC spokeswoman Barbara Reynolds told The New York Times on July 16, "No one should now be giving rotavirus vaccine to anyone."

The intussuception problem was said to have come to light only on post-marketing surveillance. In prelicensure trials, the rate was said to be not significantly higher than with placebo. However, Andrew Schlafly, General Counsel for the Association of American Physicians and Surgeons, pointed out that there were 5 cases in the 10,054 infants in the trial, 3 of them within one week of the vaccine. CDC figures show a normal incidence of intussuception of about 51 per 100,000 infant-years, or about 1 per 100,000 infants in any given week. Thus, the rate of intussuception in the trial was 30 times the normal background rate: surely a cause for concern. (One case occurred in 4,633 placebo recipients.) According to the CDC web site, more recent data from Minnesota shows almost 300 intussuceptions per 100,000 infants in the first week post vaccine, 300 times the expected rate.

To obtain the most complete information about a vaccine, recipients or their parents should ask to see the package insert.

There is a mechanism for claiming compensation for vaccine injury through the National Vaccine Injury Compensation Program (NVICP). Rules are very complicated. Of note is that hepatitis B, HIB, and varicella vaccines were added to the program on August 6, 1997. Anyone immunized before that date must file a claim before August 7, 1999.