birds then produced 23% more "hatchable" eggs than the control birds did. Two weeks later 100% of the "DDT"" chicks were alive, compared with only 94.8% of the "controls", and after six weeks the survival of the DDT birds was still 4% higher than the controls. Rudd & Genelly (1956) discussed orchards sprayed with 40 to 60 lbs per acre per year in which "apparently there has been no noticeable decline in the reproductive success of the species concerned" (of birds).

Bitman et al 1969. “DDT induces a decrease in eggshell calcium",......

It has been claimed by some that "experimental evidence" has linked DDT with thin eggshell formation, and the EDF included three articles as their "proof": Bitman, et al, 1969. "DDT includes a decrease in eggshell calcium", Nature 224: 44-46; Porter & Wiemeyer, 1969. "Dieldrin and DDT, Effects on Sparrow Hawk Eggshells and Reproduction", Science 165: 199–200; and Heath, et al, 1969. “Marked DDE impairment of Mallard Reproduction in Controlled Studies", Nature 224: 47-48. The felonius nature of each of these is mentioned below, to indicate the experimental “errors" that predominate.

(1) Bitman's experiment was designed to produce thin eggshells regardless of whether DDT was introduced into the diet of the quail. He fed the birds on "a diet of low calcium content (0.56%) to provide a calcium stress during egglaying." (The DDT concentration in the diet was 4,000 times the normal level in human diets in U.S.) The work by Tucker & Haegele bears on this research (Bull. Environ. Contam. & Tech. 5(3): 191-194), for quail were fed on diets of 3% calcium (control), 1.73% calcium, and 1% calcium. The eggshells formed by the low calcium birds were 9.3% thinner than the control birds formed. (Mallard ducks fed 1% calcium diets showed 12.9% thinning.) Bitman's quail on 0.56% calcium diet, plus 100 p.p.m. DDT, only formed eggshells 4% thinner than the controls! In other words, Tucker caused much more thinning by just reducing the calcium in the diet to 1.0% than Bitman caused by reducing the calcium to 0.56% and adding 100 p.p.m. to the diet. Rather than blame DDT for the shell thinning, Bitman should have blamed it on the calcium deficient diet that he deliberately fed the birds.

(2) Porter & Wiemeyer fed hawks a mixture of DDT and dieldrin even though he realized in advance that the dieldrin alone should cause thin eggshells and should strongly inhibit reproduction. The British Wilson Report placed the blame for the peregrine decline there on dieldrin seed-coating, and Lockie reported that "The proportion of Golden Eagle eyries in west Scotland successfully rearing young increased from 31% in 1963-65 in 1966-68", while the level of dieldrin in the eggs fell from 0.86 to 0.34 p.p.m. He concluded that "contamination by dieldrin was the cause of the decline", which “became appreciable only after dieldrin had taken the place of DDT as the principle organochlorine sheep dip." Porter & Wiemeyer thus attempted to incriminate DDT, knowing in advance that dieldrin alone could cause egg failure and therefore feeding the birds dieldrin mixed with the DDT.

(3) Heath and associates fed their mallard ducks diets of "DDE" and DDT. The "DDE" caused reproductive difficulties, but the 2.5 p.p.m. DDT diet increased productivity by 140% and the 10 p.p.m. DDT diet actually increased productivity by 181%. Completely ignoring those great increases caused by DDT added to the diets, Heath stated: "DDT in concentrations of 2.5 and 10 p.p.pm. did not have measurable effects on reproduction." That blatantly untruthful statement has been repeated by anti-DDT forces all across the country, adding to the other untruthful and misleading propaganda that has characterized the fight to ban DDT! Yet another article has sometimes been cited as evidence of reproductive inhibition caused by DDT in the diet. It is by Dr. David Peakall, in Science 168: 592-94 (1970), and describes his work with Ringdoves. Peakall states: "Pairs were kept in cages, on a 16-hour light and 8-hour dark schedule at 25°C". "At the start of the experiment the female of each pair was removed from the cage and maintained in isolation from the male on an 8-hour light and 16-hour dark schedule for three weeks." Why did the researcher expose his birds to this remarkable treatment, when it is well-known that even one light-bulb out in the hen-house causes the hens to lay thin-shelled eggs? The predictable result was an inhibition of reproduction, however the inhibition was not as severe as might have been expected. Poultry treated in that manner would have ceased to lay eggs and would probably have moulted, but the effect on the ringdoves was to increase the time needed to produce the first egg (from 16.5 days to 21.5 days) and to reduce the total weight of the eggshells. This article is often used as a reference to the "method of egg-shell thinning" hypothesized by anti-DDT

writers, based on carbonic anhydrase inhibition. Peakall states that Carbonic anhydrase controls the hydration of carbon dioxide and is involved in the secretion of the calcareous eggshell, and that “Eggshell thinning by DDT may result largely from inhibition of carbonic anhydrase." This is the basis upon which DDT has been so widely blamed for the "thin eggshell disasters" by all anti-DDT forces. It should be pointed out now that actual research has shown DDT increases carbonic anhydrase production, rather than inhibiting it. Obviously the anti-DDT hypothesis must therefore be revised!

Dr. E. L. R. Stokstad, Professor of Nutritional Sciences at University of California, found that in Japanese quail given 50 p.p.m. of DDT or DDE in the diet, the enzyme activity in the oviduct actually increased. (U.C. Dateline, No. 21, Dec. 1970). Dr. Yeshayau Pocker and coworkers at University of Washington have also found that "DDT, DDE, and Dieldrin are not true inhibitors of carbonic anhydrase activity" (Chemical & Agr. News, Jan. 18, 1971). A study published in Canadian Journal of Zoology (1971) also "found no relationship between the levels of DDE in the eggs and the thickness of the egg shells". This work was done on terns in Alberta, by Dr. Bruce Switzer and colleagues at the University of Alberta. Perhaps also bearing on this subject is the recent work by B. M. Mulhern and colleagues indicating that Bald Eagles from Maine had thicker shells than those from Florida, even though they contained higher levels of DDE, DDD, DDT, and dieldrin than the Florida eagle eggs.

STATEMENT OF RICHARD T. O'CONNELL, SECRETARY, NATIONAL COUNCIL OF FARMER COOPERATIVES

We appreciate the opportunity to present our views on S. 745. The National Council of Farmer Cooperatives is a federation of one hundred regional farmer cooperatives serving approximately 6,500 local cooperatives and exchanges, and 33 state cooperative councils. Farmer cooperatives engage in the marketing and purchasing of farm products for and on the behalf of farmers.

Our interest in pesticides is twofold: members of the National Council formulate and mix pesticides for distribution to owners of their cooperative organizations, the farmer. Farmers, in turn, utilize pesticides for the production of uniform, high quality food and fiber.

We believe S. 745 can serve as a vehicle for placing pesticides in their proper perspective. Pesticides are an important tool in the production of food and fiber, but we must recognize a degree of toxicity in pesticides and the need for their careful use. Therefore, regulations to provide protections are needed, but the regulations should not be so prohibitive as to limit the use of pesticides unduly. S. 745 will remove much of the criticism of pesticides because scientific knowledge will replace emotion in deciding pesticide issues. This change can occur because of the improved training for applicators, additional research on pesticides and closer monitoring of pesticide use.

We have several questions which we do not believe have been answered in the hearings to date.

There is no indication as to what extent state regulations will improve or impair the use of pesticides in the production of food and fiber. We realize a complete and definitive list of regulations cannot be promulgated if the states are going to be permitted to establish their own regulations. However, we believe an explanation is possible on the general thrust of these regulations, as to what restrictions may be placed on pesticide use, the licensing criteria for applicators and what pesticides will be in the classifications of use by "permit only," "restricted use" and "general use."

Also, we have not heard of any estimates on the cost of the licenses to the applicators. From the farmer's standpoint, the price of the license, if prohibitive, would force him to use commercial applicators only. We do not believe the legislation should be drawn so that farmers cannot readily apply pesticides on their own land. Because of the uncertainties on costs and the problems we believe will occur during the transition period under this legislation. we recommend an exemption under the licensing provisions of this Act for farmers applying pesticides on their own land, whether owned or leased, for a period of no less than five years following enactment.

We also see problems in dual enforcement on inspection of pesticidal manufacturing plants. Under this proposed Act (Section 9) the inspectors from the

enforcement agency will have a right to enter into, for the purposes of inspection, the premises of the manufacturer, distributor, carrier, or dealer, or anyone else who sells or offers for sale certain pesticides. We wish to call to the attention of the Committee that under Section 20 (a) (5) and (a) (6) of Public Law 91-596, the Occupational Safety and Health Act, the Secretary of Health, Education and Welfare is empowered to seek information and develop inspection regulations covering plants where potentially toxic substances are being manufactured or used. We believe this would include pesticides and the dual inspection could cause confusion over who has the final jurisdiction over the inspections of these toxic materials.

We are further concerned about the type of training required of the applicators prior to licensing. If these licensing requirements go into effect immediately, or during the four year adjustment period, and the potential licensees are required to have specialized training, the capacity of the land grant institutions could be taxed heavily if hundreds of thousands of farmers need a license soon after this Act becomes effective. This is another reason for the licensing exemption for farmers.

We support, as we said earlier in our statement, the principles contained in S. 745, but we believe the reception of this legislation and its later effectiveness will be improved if some changes are made, including the following:

1. The Environmental Protection Agency produce for this Committee a set of "model regulations" which the states can follow in enforcing the Act. 2. Estimates be obtained on the costs of obtaining an applicator's license. 3. An exemption be granted for farmers applying pesticides on their own land for a pediod of at least five years.

In addition, Mr. Chairman and members of the Committee, we have specific amendments to offer to the language of the bill. These are attached. We urge the Committee to give them serious consideration.

We appreciate the opportunity to present our views on this legislation.

PROPOSED AMENDMENTS TO 8. 745

1. Section 2(b) Page 3, line 4, after the word "contrivance" add the words "containing or using pesticides..."

3. Section 2(x) Page 10, line 23, preceding the word "hazard" add the worst "shall" and add "cause death or serious physical harm..."

3. Section 2(x) Page 10, line 23, preceding the word "hazard" add the word "serious".

4. Section 2(x) Page 10, line 24, strike the word "injury" following the word "prevent" and add the words "death or serious physical harm...'

5. Section 2(y) Page 11, line 4, strike the word "against" after the word “injury" and add the words "the cause of death and serious physical harm..."

6. Section 2(y) Page 11, line 6, place a period after the word "values", and strike thereafter a comma and the words "taking into account the public interest".

7. Section 3 (a) (1) Page 12, line 1, strike the word "adverse" and add the words "a serious".

8. Section 3(3), Page 12, line 23, strike the word "injurious" after the word "quantities" and add the words "which cause death or serious physical harm..." 9. Section 10(a), Page 40, line 17, add a paragraph (c) "Any producer applying pesticides on land owned or leased by such producer shall be exempt from the applicator licensing provisions of this Act."

STATEMENT OF CARL F. SCHWENSEN, EXECUTIVE ASSISTANT,
NATIONAL ASSOCIATION OF WHEAT GROWERS

The National Association of Wheat Growers is a commodity organization representing producers in Montana, South Dakota, Kansas, Wyoming. Oklahoma, Texas, Nebraska, Colorado, Idaho, Washington and Oregon. The major portion of the nation's wheat production is grown in these eleven Great Plains and Pacific Northwestern States.

Wheat growers recognize fully the importance of controlling factors which threaten human health, wildlife and the environment; this recognition extends to the use of agricultural chemicals and cultural practices necessary to efficient, modern production.

Pesticides have enabled the wheat farmer to produce an abundance of high quality wheat for domestic and export markets, and the farmer-not the consumer or the exporter-has absorbed the cost of pesticide materials and applications. It is for these reasons that an approach must be found to discipline pesticide use which is practical and economical for the farmer and does not destroy the progress which agriculture has made in the efficient production of food. Moreover, regulation must balance the risk associated with the use of a particular compound against the benefits produced by its application.

The National Association of Wheat Growers cannot support in its present form, the proposed Federal Environmental Pesticide Control Act of 1971 (S 745). We favor instead the continuation and improvement of the Federal Insecticide, Fungicide and Rodenticide Act.

Provisions in S 745 which restrict pesticide use through permits and licensing are of primary concern to our organization.

The NAWG feels strongly that pesticide regulation should be accomplished through product registration and labeling requirements. Farmers have demonstrated their ability to apply pesticides both efficiently and effectively. While there are possibly instances where more caution could have been used by applicators, we are aware of neither substantial nor conclusive evidence indicating farmers should be required to become licensed applicators or to secure permits to control pests threatening their crops and livelihood.

The practical knowledge of pesticide use lies in agriculture; legislation regulating this use should not be structured in a manner that will discourage or prohibit good farming practices. Fear among farmers that substitutes for pesticides removed from the market will be more costly and less effective appears justified. In this event, the farmer will not only have to pay more per unit to control his particular pest problem, but he will need more units to achieve desired results. The grain farmer has no means of passing these increased costs on to the

consumer.

The consumer, however, will not be insulated from the effects of these increased costs. Pesticides enable farmers to produce a quality product. When the economics of production force the farmer to reduce the number of acres of applications, or even abandon some uses altogether, crop quality will be affected. The consumer will then have to pay more for the same quality of product that he is currently using.

Another area of concern which we wish to identify with regard to S. 745 is the discontinuation of an expert advisory committee selected by the National Academy of Sciences to make recommendations concerning the cancellation of pesticide registrations. The reliance, instead, on public hearings to develop a record on which to base registration and labeling judgments indicates that public interest will have the same impact as scientific fact, maybe more. We do not feel that public hearings will enable scientific judgments—moreover, the public, in participating, might not be acting in its own interests.

Overall, we are impressed with the desire of the Environmental Protection Agency to effectively deal with environmental problems relating to pesticides and pesticide use. We feel, however, that the EPA can successfully achieve its goals under the existing act (FIFRA). We cannot understand the need to adopt the current act; it is our belief that improvements needed in pesticide regulation can be accomplished by amending FIFRA.

Finally, we wish to commend Chairman Talmadge and the Senate Committee on Agriculture for the in-depth hearings they have conducted into the subject of pesticide legislation. We appreciate this opportunity to present our views to the Committee.

Hon. HERMAN E. TALMADGE,

WASHINGTON, D.C., April 6, 1971.

Chairman, Committee on Agriculture and Forestry,
U.S. Senate, Washington, D.C.

DEAR SENATOR TALMADGE: The International Apple Institute submits the following for your consideration in furthering the wise development of S. 745, "Federal Environmental Pesticide Control Act of 1971," and respectfully asks that this letter be made a part of the hearing record.

The International Apple Institute is a national trade association dedicated to the welfare and promotion of the nation's apple producers, marketers, and other segments of the apple industry in the numerous areas of responsibility typical of almost all national commodity trade associations.

Directly and indirectly, through its approximately 15,000 grower and 1,400 "handler" members, it represents the entire apple industry of the United States. The apple industry is a prime user of pesticides and is vitally dependent upon the use of agricultural chemicals to produce and market an annual crop of approximately 150 million bushels. These chemicals are used to control insects, diseases, and rodents in th orchard and in storage warehouses in order to provide safe, wholesome, and high-quality apples and apple products for consumption. A well-integrated, experienced, smoothly functioning agricultural team of sophisticated, technically trained, and conscientious growers and handlers, backed by pesticide manufacturers, USDA, and land grant college researchers and instructors. Extension Service specialists, State and Federal Department of Agriculture research and regulatory personnel, state and federal legislators, has been doing this well for a great many years.

The Federal Insecticide, Fungicide and Rodenticide Act and other laws and regulations administered by various agencies of the Federal Government; state laws and regulations, carefully and expertly researched, developed, updated, taught, and enforced have been an integral part of the whole operation. Schools and training sessions, a continuing, trusted, and practical communications dialogue by radio, television, and newspaper press, by bulletins and service letters. by meetings and orchard and packing-operation visits involving all members of the production and marketing industry have made the implementation of this possible.

Safety of the consuming public, safety of pesticide applicators and other agricultural workers, and safety of the environment, as well as the efficient production of essential food supplies, have been prime, ongoing goals of all concerned. In the apple industry, as in all industries, agricultural and non-agricultural, there have been inadvertent errors and misjudgments. There have been some, a comparative few, violators of this code of conduct through willful misuse of pesticide materials. Many previously used materials have been completely eliminated for safety reasons. Research and development are constantly producing safer and better materials. Biological and other non-pesticide alternatives are being employed wherever possible.

The apple industry is but one essential segment of agriculture. A similar and equally good record of conduct and achievement has been demonstrated by all of agriculture.

The proposed legislation being considered by your Committee is not dealing with mismanagement, violations, and eminently dangerous practices in our food production system. On the contrary, it is seeking to improve still further on a system of ethical practice, conduct codes, safety standards, laws and regulations, and the practical application thereof which, on the whole, has served the public interest well and is worthy of great commendation.

The International Apple Institute cannot speak as a body of scientists, technologists, and legal experts, but it does represent the users of pesticides, commercial fruit growers, and does speak with a considerable degree of expertise regarding scientific training in, and knowledge of, the importance of proper application of proper pesticides in the apple industry.

The IAI urges that new legislation in the area of pesticide management and control recognize and build on the very considerable experience, practice, and expertise in its management to date.

The IAI seriously questions the need and practical value of the third category of pesticide regulatory classification, "Use by Permit Only." The other two specified classification. "General Use" and "Restricted," are sufficient if properly identified, administered, and enforced. The "Use by Permit Only" classification is really just a further requirement of the "Restricted" classification, if properly defined, applied, regulated, and enforced, provides the essential safeguards to human and environmental safety.

Further, the "Use by Permit Only" classification as detailed to apply to each and every application of pesticides coming under such classification, sets up a whole gamut of regulatory procedure for administration and enforcement which mandates nearly impossible achievement in terms of manpower, training, and funding, and sets the stage for assigning responsibility to persons far less qualified to make judgments than knowledgeable, commercial farmers who depend on the pesticides and whose investments in production depend on prior knowledge of the eligibility and availability of essential materials and the flexibility to use approved materials where and as needed, and who, in the final analysis, are legally, morally, and financially responsible for their use or misuse.