Force Of Nature -- The Wisdom of Holland -- 2009 11 00 -- Parts 1-3 -- Precautionary Principle -- CCS -- MODIFIED -- pdf -- 300 dpi.pdf

8/9/2019 Force Of Nature -- The Wisdom of Holland -- 2009 11 00 -- Parts 1-3 -- Precautionary Principle -- CCS -- MODIFIED -

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Pest Control Products

A Brief Outline

of Real Science

and Actual Fact

( Adapted excerpts )

November 2009

John J. HollandCOMMUNICATIONS DIRECTOR

espite the opposite claims

of many antipesticide or-

ganizations, no regulatory

body in the world classifies

2,4D as a human carcino-

gen. >>


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HEALTH CANADAREEVALUATIONS

By the end of 2009 orearly 2010, Health Canada plans to have

reevaluated all pest control products registered in Canada

prior to 1995. At least80% of this work was completed byJuly

2009, with the most common landscape and garden pest con-

trol products such as 2,4D already reevaluated. Health

Canada has a mandate to approve only those pest control

products that show no significant increased health risk, in-cluding cancer.

2,4DREEVALUATIONS

2,4D is the active ingredient in the majority of lawn weed con-

trol products, and also has the distinction of being one of the

main targets of antipesticide activity and attacks by many or-ganizations and activists at least, those who are unable to

appreciate or understand the vast amount of research to which

this product has been subjected.

Despite the opposite claims of many

antipesticide organizations, no regulatory body in the world classifies

2,4D as a human carcinogen.


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2,4DHISTORY

2,4D was first registered in Canada in 1946.

Since that time, there have been numerous reevaluations, by

the P.M.R.A. ( Pest Management Regulatory Agency of

Health Canada ), the U.S. E.P.A. [ Environmental Protection

Agency ], the World Health Organization ( W.H.O. ), and the

European Commission.

In fact, despite the opposite claims of many antipesticide or-

ganizations ( including the Canadian Cancer Society ), NO REGU-

LATORY BODY IN THE WORLD CLASSIFIES 2,4D AS A HUMAN CARCINO-

GEN.

The P.M.R.A. has stated that ...

No other international body considers

2,4D to be a human carcinogen. Based

on all available and relevant data,

Health Canada agrees with this posi-

tion.

REFERENCE : QUESTIONS AND ANSWERS. FINAL DECISION ON THE REEVALUATION OF 2,4D, P.M.R.A.,

JANUARY 14, 2009, AVAILABLE ONLINE.


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The U.S. Environmental Protection Agency [ E.P.A. ] has

stated that ...

The Agency has determined that the

existing data do not support a conclu-

sion that links human cancer to 2,4D

exposure.

REFERENCE : DECISION NOT TO INITIATE SPECIAL REVIEW, AUGUST 08, 2007, AVAILABLE ONLINE.

According to many internationally respected experts on 2,4D,

including Dr. Len Ritter ( Executive Director, Canadian Net-work of Toxicology Centres ) and the respected American

toxicologist Dr. Frank N. Dost, 2,4D is probably the most stud-

ied and best understood of any chemical not just pesticide

in existence.

2,4D is probably the most studied

and best understood of any chemi-

cal not just pesticide in ex-

istence.


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PESTMANAGEMENTREGULATORYAGENCY

OFHEALTH CANADA(P.M.R.A.).

This government agency employs over350qualified scientists,

including ...

Biologists,

Chemists, Toxicologists,

Epidemiologists,

Plant Pathologists,

Weed Scientists, and

Entomologists

They are all dedicated to the evaluation of pest control prod-

ucts. One must wonder why the Canadian Cancer Society

never references the findings of the P.M.R.A. in its campaign

against the use of pest control products, and instead prefers to

claim that pest control products are KNOWN to cause cancer.

The Ontario College of Family Physicians Re-

view has been internationally discredited.


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THE ONTARIO COLLEGE OF FAMILY PHYSICIANS[OCFP ]2004PESTICIDE LITERATURE REVIEW

This STUDY has been widely used by antipesticide groups as

part of their claim of a GROWING BODY OF EVIDENCE , and has

then been accepted by many municipalities as proof of the car-

cinogenicity of pest control products.

However, the [ OCFP ] Review has been internationally discred-ited, due to the fact it consists of cherrypicked epidemiological

studies, with virtually no reference to important and relevant

toxicological research.

Copied below, as one example, are excerpts from an analysis of

The Ontario College of Family Physicians [ OCFP ] Review in

the U.K. Governments Report to the Royal Commission on En-

vironmental Pollution ( by Dr. Michael Burr, 2005, availableonline ) :

The treatment of [ OCFP ] review

papers is unclear and appears inconsis-

tent.

The [ OCFP ] review takes a rather

superficial approach in bringing to-


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gether the findings of the individual

studies.

Few of the cited studies [ by OCFP ]

adequately address the issue of con-

founding by coexposures. Much of the

evidence supporting an association be-

tween pesticide exposure and cancer is

derived from occupational exposures,

e.g. in agriculture, where animal vi-ruses, diesel fumes, fertilisers ( sic )

and other factors may play a role.

THE [ OCFP ] REVIEW SEEMS TO OVERINTERPRET THE

FINDINGS, GIVEN THE LIMITATIONS OF THE RELEVANT STUD-

IES; STRONG CONCLUSIONS ARE DRAWN FROM EVIDENCE OFRATHER WEAK QUALITY.


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PRECAUTIONARYPRINCIPLE

This principle is used as the ultimate tool and guiding light by

those opposed to the use of pest control products. There are

numerous definitions of this principle ( which is also seen as

antiscience by many scientists ), but the generally accepted

one is that of the Rio Declaration, from a United Nations Con-

ference on Environment and Development held in Rio de Ja-

neiro in 1992.

This document states that ...

Where there are threats of serious or

irreversible damage, lack of full scien-

tific certainty shall not be used as a

reason for postponing costeffective

measures to prevent environmental

degradation.

Landscape and garden use of pestcontrol products does not qualify for

consideration under the precaution-

ary principle.


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Dr.Keith Solomon

is Professor at theCentre

for Toxicology and Department of Envi-

ronmental Biology, University of Guelph, and

Director, Canadian Network of Toxicology

Centres.

As Dr. Keith Solomon explains :

Landscape and garden use of pest

control products does not qualify for

consideration under the precautionary

principle. They are not serious,

they are selective to pests, have low

toxicity to nontarget organisms, andare well understood. The effects of

these pest control products are not ir-

reversible. There is rapid recovery

through reinvasion and weed seeds and

most need to be used at least once per

year.

QUESTIONS AND ANSWERS ABOUT LANDSCAPE AND GARDEN PEST CONTROL PRODUCTS, DR. KEITH

SOLOMON, MARCH 27, 2007.


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The Rio Declaration, however, did not embody a vague enoughdefinition for antipesticide and unscientific organizations such

as the Canadian Cancer Society, which instead choose to use

the definition contained in the Wingspread Statement :

When an activity raises threats of harm to human health or the

environment, precautionary measures should be taken even if

some cause and effect relationships are not fully established

scientifically.

Note that SERIOUS AND IRREVERSIBLE has been deleted from

the original.

This STATEMENT of the principle was formulated by a small

group of environmentalists meeting in the U.S. in 1998, and it

is not difficult to see why it would be chosen over the Rio Dec-

laration as the weapon of choice.

In a2006 published report by the prestigious British House of

Commons Select Committee on Science and Technology, it

was stated that ...

[ ... ] the term precautionary prin-

ciple should not be used, and ( we )

recommend that it cease to be included

in policy guidance.


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Also stated, by the British House of Commons Select Commit-tee on Science and Technology, was the following :

In our view, the terms " precautionary

principle " and " precautionary approach " in

isolation from any such clarification have

been the subject of such confusion and dif- ferent interpretations as to be devalued

and of little practical help, particularly in

public debate. Indeed, without such clari-

fication and explanation, to elevate the

precautionary approach or principle to a

scientific methodology, which can be proved or disproved to have been applied

in any particular case, is both unrealistic

and impractical. It also provides ammuni-

tion for those seeking to promote an

overly cautious approach to innovation or

exposure to any risk at all.

SCIENCE AND TECHNOLOGY SEVENTH REPORT, HOUSE OF COMMONS SCIENCE AND TECHNOLOGY

COMMITTEE PUBLICATION, 2006.


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INCONVENIENTFACTS

Despite claims to the contrary, there are NO viable, effica-

cious, or economical products to replace present pest control

products.

There are only two ALTERNATIVE products approved for

lawn care byHealth Canada : Sarritor and corn gluten.

Sarritor is 510 times more expensive and certainly no

safer than 2,4D, and works only on top growth, necessitat-

ing even more applications.

Corn gluten can only used as a preemergent which means

it is not effective for preexisting weeds and provides only

poor results.

Despite claims to the contrary, children and pregnant

women are taken into account when pest control products are

registered in Canada :

[E]xtra safety factors were applied to the no effect

level identified in animal toxicity studies to protect

population groups, such as children and pregnantwomen, that may be more susceptible to the poten-

tial effects of pest control products. This resulted

in reference doses that were 300 to 1000fold lower

for these groups for these sensitive groups, which


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are more protective than the minimum 100foldsafety factor. Thus, products will not be considered

acceptable for continued registration unless the es-

timated human exposure is at least 300 times to 1000

times less than the level at which there were no ob-

served effects in the studies examined. These levels

ensure the most sensitive population groups chil-

dren and pregnant women are protected.

( HEALTH CANADAS P.M.R.A., REEVALUATION DECISION RVD200811, MAY 16, 2008, AVAILABLE ONLINE )

Many ORGANICS are considerably more toxic than conven-

tional counterparts.

For example, considercopper, which is used by organic farm-

ers, and is, indeed, labelled as ORGANIC . Yet, copper is

nondegradable, corrosive, more toxic than its conventionalcounterparts, and can cause kidney and liver damage.

Claims by antipesticide organizations that business in-

creases for applicator companies after a ban are completely

false.

The Statistics Canada figures used as PROOF are gleaned

from a catchall category that includes all landscape related

companies, such as landscape installation and grasscutting

operations. If switching to products deemed ORGANIC in-

creases income, why would applicators be opposed ?


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BOTTOM LINE

THE CANADIAN CANCER SOCIETY IS NOT A SCIENTIFIC BODY : IT IS A

FUNDRAISING ORGANIZATION, CONSISTING OF VOLUNTEERS AND ADMIN-

ISTRATORS. MUCH THE SAME CAN BE SAID FOR OTHER NONSCIENTIFIC

ORGANIZATIONS, SUCH AS TOXIC FRE E CANADA AND THE CANADIAN AS-

SOCIATION OF PHYSICIANS FOR THE ENVIRONMENT (CAPE).

The antipesticide organizations have no one in their employ with recognized pesticide training or appropriate scientific ex-

pertise.

Compare this with the over 350 qualified scientists at Pest

Management Regulatory Agency of Health Canada, and the

thousands at the U.S. Environmental Protection Agency.

What is the rationale that causes municipalities to choose to

listen to those emotionally and irrationally opposed to the use

of pest control products, rather than the actual experts ?

Why is it that uninformed opinion and unsubstantiated claims

take precedence over science for so many Councils and Coun-

cillors ?

According to Dr. Keith Solomon, the University of Guelph Pro-

fessor of Toxicology, and an awardwinning and internationally

respected expert on pest control products, a lot of this has to

do with BYLAW ENVY .


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There has, in addition, been an almost universal lack of due

diligence: if a number of municipalities pass a pesticide ban,

then this alone is taken as acceptable PROOF of the need for

further bans and one municipality simply copies the bylaws of

others.

Add to this mix the nonscientific approach of the Canadian

Cancer Society ( which, because of other good work

done by them, manages to still be viewed as highly respected

and reputable ) and other antipesticide organizations.

Many unsubstantiated claims are presented to Councils, using

a combination of misinterpreted, poorly conducted studies and

fraudulent information.

Thus is laid the groundwork for what appears superficially to

be suitable grounds for a ban. However, FACTS cannot be

validated by majority votes, and science is not determinedthrough groundless emotion or uninformed public opinion

polls.

For additional detailed scientific information from respected

nonindustry scientists and sources, contact :

John J. Holland

Communications DirectorIntegrated Environmental

Plant Management Association

of Western Canada

[email protected]


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John J. Holland is Communications Director for Integrated

Environmental Plant Management Association of Western Canada(I.E.P.M.A.).

He is one of the most eloquent and intelligent writers on the subject of

public policy and pest control products.

Here is a list of Mr. Hollands career highlights and accomplishments :

Honours BA in History and Geology.

Postgraduate work in History.

After university, coowned a large bookstore in Ontario.

Moved to British Columbia from Ontario in 1978.

Worked for a structural pest control company in British Columbia for

three years, the last two of which Mr. Holland was a supervisor.

Owned a large tree and lawn care company in the Okanagan from 1983

until 2004, when he retired.

One of the founders of the ESA (Environmental Standards Association forerunner to the Integrated Environmental Plant Management

Association of Western Canada) in 1984.

President of the Environmental Standards Association, 1985 1994.

VicePresident of the Integrated Environmental Plant Management Association, 1998 2007.

Director of the Integrated Environmental Plant Management Association, 2007 present.

According to Mr. Holland :

ALTHOUGH I HAVE NEVER USED MY DEGREE IN THE PROFESSION FOR WHICH I

STUDIED, I FOUND THAT THE TRAINING I RECEIVED IN THE METHODS OF RESEARCH

WAS INVALUABLE IN ENABLING ME TO DISCERN THE FACTS OF THE REAL SCIENCE

BEHIND THE USE OF PEST CONTROL PRODUCTS. NOT BEING A SCIENTIST, I HAVE

ALWAYS BEEN GUIDED BY THE WORK OF THOSE WHO AR E THE ACTUAL EXPERTS.


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Force of Nature was launched for continuous transmission on the Internet on January 1st, 2009. It

is a series of enewsletters destined for the GREEN SPACE INDUSTRY, the Environmental TerrorMovement, government officials, municipalities, and the media, nationwide across Canada, and

parts of the United States and overseas. FORCE OF NATURE is produced in two parts. First. The

MEDIA REPORT itself that reports on the current events affecting the future of the GREEN

SPACE INDUSTRY. Second. INDEPENDENT PERSPECTIVE, which is a running commentary,

sometimes technical in nature. Force of Nature is the WHOLE TRUTH from an INDEPENDENT

PERSPECTIVE ! Force of Nature is TOTALLY INDEPENDENT of any trade association or

business operating within the Green Space Industry.

FORCE OF NATURE is the brainchild of William H. Gathercole and his entourage. Norah G is actually an acronym for the stable of anonymous

producers and writers that contribute to this enewsletter and have now replaced Mr. Gathercole. They consist of people from the following industries

: Distribution, Fertilizer, Golf, Lawn Care, Manufacturing, Municipal, Nursery, Orchard. Many of these people are leaders in their own industries.

The opinions expressed in Force of Nature, even though from an INDEPENDENT PERSPECTIVE, may not reflect those of everyone in the GREEN

SPACE INDUSTRY, or Mr. Gathercoles many associates. Be warned ! Mr. Gathercole and Norah G may sometimes be very irreverent and fearless

with these enewsletters. DONT THANK US. ITS A PUBLIC SERVICE. AND WE ARE GLAD TO DO IT.

William H. Gathercole holds a degree in Horticulture from the UNIVERSITY OF GUELPH, and another pure and applied science degree from

MCGILL UNIVERSITY. He has worked in virtually all aspects of the GREEN SPACE INDUSTRY, including public affairs, personal safety, and

environmental issues. Mr. Gathercole has been a consultant and instructor for decades. He has also been an agricultural agronomist. Mr. Gathercole

has followed the evolution of ENVIRONMENTAL TERRORISM for over a quartercentury. His involvement in environmental issues reached a fe-

vered pitch in the 1990s, when he orchestrated, with others, legal action against unethical and excessive municipal regulations restricting the use of

pest control products. ( i.e. the Town of Hudson. ) Although he can be accused of being ANTIENVIRONMENTMOVEMENT, he is, in fact, sim-

ply a strong advocate FOR the GREEN SPACE INDUSTRY, from an INDEPENDENT PERSPECTIVE. However, this position has not precluded

him from criticizing the Green Space Industry itself. Nonetheless, his vast knowledge of our long journey with environmental issues is UNDENI-

ABLE. ( Hopefully ! ) For many years, Mr. Gathercole was a contributing columnist for TURF & Recreation Magazine, Canadas Turf and Grounds

Maintenance Authority. Mr. Gathercole is now retired from Force of Nature, although his name continues to appear as the founder.

All document excerpts and pictures contained in FORCE OF NATURE were found somewhere on the Internet. We believe that they are in the public

domain, serving one of the following purposes : archive, education, promotion, publicity, or press release.

We believe that ENVIRONMENTAL TERRORISM can be BEATEN ! Information presented in FORCE OF NATURE has been developed for the

education and entertainment of the reader. The events, characters, companies, and organizations, depicted in this document are not always fictitious.

Any similarity to actual persons, living or dead, may not be coincidental. The mission of Force of Nature is as a National Organization Responding

Against Huje that harm the Green Space Industry with statements and activities seeking to prohibit FEDERALLY LEGAL, SCIENTIFICALLY

SAFE, and TOTALLY IRREPLACEABLE conventional pest control products. Culprits are identified on the basis of their statements, activities, af-

filiations, and whereabouts. Even though each culprit is a misguided adversary, each still deserves our respect. The terms culprit or terrorist are not

an accusation of any legal wrongdoing. Force of Nature is simply holding culprits accountable for conspiring to change public policies that TER-

RORIZE and THREATEN the Green Space Industry. Force of Nature believes that the prohibitionist policies of the Environmental Terror Movement

will lead to UNEMPLOYMENT, BANKRUPTCY, BUSINESS FAILURE, DESPAIR, and DESTITUTION. The actions of culprits in the move-

ment are viewed as a form of TERROR against the Green Space Industry.

The following titles are currently available. (Or, will be available in the near future.) Alberta Prohibition British Columbia Prohibition Ca-

nadian Association of Physicians for the Environment Canadian Environmental Law Association Consequences David Suzuki Foundation

DDT and Politicized Science EnviroMoney Environmental Terrorists Unmasked Death and the Environmental Movement Environ-

mental Terrorists Unmasked June Irwin, The Clown of Junk Science Kazimiera Jean Cottam LandsCAPE Trades Capitulate New

Brunswick Prohibition Nova Scotia Prohibition Ontario Prohibition Organic Fertilizers Pets and Lawn Care Chemicals Prince Ed-

ward Island Prohibition Quebec Prohibition Rachel Carson, The Queen of Junk Science Randy Hillier, The Next Premier of Ontario

Salmon Arm BC Prohibition The 9/11 Era of the Green Space Industry The Failure of Integrated Pest Management The Looming Golf In-

dustry Shipwreck The Industry Strikes Back The Misconceptions About Cancer The Wisdom of Drysdale The Wisdom of Holland

The Wisdom of Mains The Wisdom of the Solomons Wisconsin Fertilizer Prohibition ASK FOR A COPY OF ANY BACK ISSUE OF

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Force Of Nature -- The Wisdom of Holland -- 2009 11 00 -- Parts 1-3 -- Precautionary Principle -- CCS -- MODIFIED -- pdf -- 300 dpi.pdf