Let me emphasize that this kind of study is very treacherous in drawing any conclusion at all, because if you make a substantial difference in the amount produced or the quality produced, that which remains may sell at a higher price, and this again brings in a matter of value judgments. What we can say, I think, with respect to all herbicides and all pesticides in general, is that if we had to do without them and had available the hoes and the people to do the hoeing and the other things to produce our same crop, you would add a cost of production of more than $2 billion a year. Let me emphasize, however, that our primary concern is not the economic cost in the aggregate. Important as this may be, our primary concern, as Mr. Bayley has said, is that we shall control pests and we shall do it safely and without hazard to human health or the public welfare. Mr. BICKWIT. We have emphasized that we have some differences in evaluation of the evidence. I am trying to discern what evidence would convince you that this pesticide was in fact hazardous. The one thing that you have said about what would convince you is that you specify that should the teratogenic nature of 2,4,5-T be confirmed, registration for use on food crops will be canceled. My understanding, correct me if I am wrong, is that the four studies cited earlier; although all preliminary, demonstrate that 2.4.5-T is teratogenic. Dr. BYERLY. We do not accept that statement. Mr. BICKWIT. In what way do you not accept it? Dr. BYERLY. I think the statement that Dr. Bayley read is correct, that all of the evidence known to me is compatible with the hypothesis that these results were due to contaminant dioxin or the interaction of that dioxin and 2.4.5-T. Mr. BICKWIT. The evidence which I have read shows that 2,4,5-T when contaminated with dioxin in amounts similar to or less than those in currently produced 2,4,5-T does produce teratogenic effects. Now, I am on the basis of that evidence, unwilling to say it is because of the dioxin or the 2,4,5-T or the relationship between the two. Are you? Dr. BYFRIY. I believe that our previous dialogue indicated that these are preliminary results, so preliminary, sir, that I have not seen the published figures nor have I seen all of the figures to which you allude in the record. Mr. BICKWIT. I agree they are preliminary. What I am asking you is if they are confirmed, will you deregister 2.4.5-T for use on food products! Dr. BYERLY. This depends upon the dosage at which they are effective. Mr. BICKWIT. You will have to modify your statement then. Mr. BiCKWIT. Well, you have said that should the teratogenic nature of 243-T be confirmed, you would deregister the pesticide. Dr. BYERLY. I do not modify the statement, I said if 2.4.5-T. Mr. Bickwir. What does it matter whether pure 2.4.5-T is teratogente if there is no such product as pure 245-T on the market? I assumed that by your reference to "2,4,5-T," you meant pure 2,4,5-T as currently produced on the market. Dr. BAYLEY. I think you ought to recognize that he was answering your question precisely. Dr. BYERLY. I believe good manufacturing practice can restrict the amount of contaminant dioxin in the product. I believe it should be done; I believe it is now being done and that it will be done. Mr. BICKWIT. Then, I take it that your statement was not in reference to the teratogenic nature of 2,4,5-T when contaminated with any dioxin whatsoever? Dr. BAYLEY. No. Mr. BICKWIT. Have we ever produced 2,4,5-T without any dioxin whatsoever? Dr. BYERLY. This is not a statement that can be answered absolutely, but it can be answered within the limits of the method in Dr. Bayleys statement. It indicates there was one in which there was no detectable amount of dioxin. Mr. BICKWIT. Would you be willing to say that if the teratogenic nature of 2,4,5-T with the amount of dioxin that is contained in currently produced 2,4,5-T is found to be teratogenic that you would deregister it for food use? Dr. BYERLY. I would be willing to say, sir, if the 2,4,5-T with no detectable amount of dioxin, of tetrachlorodibenzo paradioxin, would prove to be teratogenic, I would recommend to the Department that actions to cancel uses on food crops be taken. Mr. BICKWIT. Yet, what is really relevant here is the effect of currently produced 2,4,5-T. Why then are you basing your decision on the effects of 2,4,5-T in a form that we do not know it commercially? Dr. BYERLY. I think you are misconstruing my reply. Again, pending the fact that neither you nor I have before us published figures which would sustain your statement that all four of these things do in fact show teratogenic effects, if we accept what you say may be true, but it has not been published nor publicly disclosed, then let me say further that so far as I know, the dosage at the current level of 150 milligrams per kilo is equivalent to the amount of the dioxin therein contained at one part per million which would be expected to give a teratogenic effect if there were no 2,4,5-T present, and 150 milligrams per kilo is astronomically higher than any amount to which any person would normally be exposed in the normal course of usage. Mr. BICKWIT. How long is the usage to which you refer? Dr. BYERLY. I did not make a limit. Mr. BICKWIT. In one's lifetime? Dr. BYERLY. In a lifetime. Mr. BICKWIT. You are willing to say this is more dioxin than one is likely to be exposed to in his entire lifetime? Dr. BYERLY. That is my opinion. Mr. BICKWIT. You will have to admit it is not based on much. Dr. BYERLY. You are forcing me into the realm of conjecture and I do not choose to go into that very far. We do not have the empirical evidence on which to state whether or not it is degradable. We have no evidence, sir, that it is not degradable. Mr. BICKWIT. Here we are again; we do not know whether it is or is not. Dr. BYERLY. We intend to find out. Dr. BAYLEY. Mr. Chairman, this dialogue is the same type of dialogue that we have with industry people who come in and want to know exactly what evidence we have to have in order to assure them that they have provided us with sufficient proof. These judgments are not so simple that you can conjecture ahead of time of seeing the data exactly what position you are going to take. It is characteristic of them: it is inherent to them. And I suggest this is characteristic not only when we are dealing with industry but when we are also concerned about the public health. Senator HART. Gentlemen, did you have anything you would like to add? Dr. BAYLEY. We do not, sir. We would be glad to enclose the additional statements for the record that we have discussed. Senator HART. Thank you very much. I had hoped we could continue through the lunch hour, but I am stuck with a Policy Committee lunch. (The statement follows:) STATEMENT BY NED D. BAYLEY, DIRECTOR OF SCIENCE AND EDUCATION, MR. CHAIRMAN: I am Ned Bayley, Director of Science and Education, Office of the Secretary, USDA. I have with me T. C. Byerly, Assistant Director of Science and Education. We are pleased to be here to comment on the current state of knowledge with respect to the herticide 2,4,5-T. We will be glad to respond to questions relevant to its usage as fully as information available to us enables us to do 80. The herbicide 2,4,5-T has been recognized a the most effective herbicide registered for use for control of certain weeds and brush species for more than 20 years. About four-fifths of the domestic use of 2,4,5-T is for nonfarm use, the largest such use being for control of brush on rights-of-way. It is also used extensively to control brush on forest lands and certain weeds in turf. 2,4,5-T has been used in the production of fruit crops, cereal grains, and sugarcane. It is the most effective herbicide for control of brush on several million acres of rangeland in the Southwestern United States. 2,4,5-1 is degraded in the environment within a few months after application so that residues do not persist from one season to the next. Residues on foods are unusual. Among 5300 food samples analyzed by FDA for 2,4,6-T during the past four years, 25 were reported to contain trace amounts; i.e., amounts less than the 01 ppm limit of accuracy of present analytical procedures for foods. Two samples showed residues of 0.19 ppm and 0.29 ppm, respectively. No finite tolerance has been established for 2,4,5-T in food. In the absence of such tolerances, any detectable amount of 2,4,5-T in food would make such food subject to seizure if found in the channels of interstate commerce. From the data cited above, it is apparent that contamination of food with 2,4,5-T is very infrequent and then only at very low levels. There is current concern over the continued use of 2.4.5-T arising from the report of a research study completed under contract by the National Cancer Institute by Bionetics Ine. This study was based on a commercial lot of 2,4,5-T so uired for the study in 1965. It was fed to pregnant mice and rats. Many of their developing young had birth defects After review of this information and after consn'tation with Federal agenconocrnod. Dr. Lee A DuBridge, the President's Science Advisor, pocood on October 29, 1969, a coordinated series of actions being taken by CIND A NON with respect to the use of 243 T agg fiem was the annonpoement that: "The Department of Agriculture *... carool registrations of 2.43 1 for use on food crops effective January 1, 1970, unless by that time the Food and Drug Administration has found a basis for establishing a safe legal tolerance in and on foods." USDA was informed in January that the lot of 2,4,5-T used in the Bionetics study contained significant amounts of a highly toxic contaminant, tetrachlorodibenzo paradioxin. The Department was further informed that lots of 2,4,5-T of current and recent manufacture were reported to contain less than 1 ppm of this contaminant in contrast to the 27 ppm reported for the lot used in the Bionetics study. Extensive studies are under way to determine whether 2,4,5-T is itself teratogenic. Preliminary reports are consistent with the hypothesis that the teratogenic results reported in the Bionetics study were due to the contaminant dioxins or to interactions of such contaminants with the 2,4,5-T rather than to 2,4,5-T per se. The Department announced on February 6 that it would undertake examination of 2,4,5-T and 17 related compounds registered for pesticidal use to determine whether or not they are contaminated with dioxins. Preliminary results on 2,4,5-T show that those lots examined of current manufacture and those now in channels of trade gave the following results: TABLE 1.-AMOUNTS OF TCDD FOUND IN COMMERCIAL 2,4,5-T BY TWO METHODS 2 TCDD Refers to the 2,3,7,8-tetrachloro-dibenzo-p-dioxin (TCDD). 3 N.D. Levels of TCDD are below the limits of detection or below 0.05 p.p.m. * Sample supplied by Dow as a reference check and reported to contain about 0.5 p.p.m. TCDD. These data are preliminary and are obtained from first drafts of methods developed by chemists in the Crops Research Division (USDA) and in the Pesticide Chemistry and Toxicology Division (FDA). The dioxin values refer only to the 2,3,7,8-tetrachloro-dibenzo-p-dioxins (TCDD) and do not indicate levels of other halogenated dioxins (containing 5, 6, 7, or 8 chlorines) in the 2,4,5-T samples. In view of all the information now available, we have not found that registered use of 2,4,5-T without a finite tolerance on food crops constitutes a hazard requiring cancellation or suspension of such registered uses. There has been and is concern over the ecological effects of 2,4,5-T used as a defoliant in Viet Nam. Dr. Fred Tschirley, Assistant Chief of our Crops Protection Research Branch, has reported the results of his examination of areas treated in Viet Nam. He has reported no evidence of irreversible ecological damage. Allegations that defoliation will lead to extensive laterization of Vietnamese soils, that Mangrove areas will not recover, that fish production in wetland areas will be reduced were not verified. Dr. Tschirley also headed a team of scientists who investigated allegations of injury to humans and animals due to herbicide treatment for control of Chapparal by the Forest Service on the Tonto National Forest near Globe, Arizona. They found that apparent damage consisted of damage to susceptible plants near the treated area from drift of the herbicides used. The alleged injuries to a duck and a goat were found to be groundless. Human illnesses were those expected in a normal population with the possible exception of one man with skin irritation on his eyelids. Clinical chemistry on specimens obtained during the investigation is in process. Senator HART. I think in fairness to all we should recess to resume at 2:15. (Whereupon, at 12:45 p.m., the subcommittee was recessed, to reconvene at 2:15 p.m., this same day.) 45-362-706 AFTERNOON SESSION Senate Hua. Tie ommittee will be in order. Lesuming this afternoon, our first witness is Dr. Arthur H. Tessing. In. Westing is chairman of the biology Department of Wodnim College in Putney. Vt. STATEMENT OF DR. ARTHUR H. WESTING. CHAIRMAN. BIOLOGY DEPARTMENT, WINDHAM COLLEGE, PUTNEY, VT. Dr. Wasting. Senator Hart, I consider it a privilege to be able to testify before your committee. Actually, I am very pleasantly sur prised that you and your staff show such tolerance toward me espite a fairly questionable record with respect to your state. First of all, host of the year I lived in Michigan. I devoted to spraying your forests with 2.45-T. and perhaps even worse, when I left Michigan I took with me one of your most desirable natives as my wife. Senator HART. I don't know whether that makes an even trade or not. Dr. WESTING. All the time I was listening to this morning's testimony and realizing how muddled the situation was with respect to the medical and public health aspects and the legal and administrative aspects. I kept thinking that those aspects were crystal-clear in relation to the aspects that I am going to try to talk about, and that is the impact of 2.4.5-T on the environment. It is such a difficult field to cope with because ecology is still really in its infancy, particularly when it comes to the study of the fuli impact of a toxie introduction to the environment. To judge from the popular press, our nation is on the brink of environmental disaster. Ecology has achieved some sort of a mystical significance to many people, and a whole new vocabulary has emerged overnight utilizing that wonderful avant-garde prefix "eco.” Over and over again we are being reminded of our collision course with "ecocatastrophe" leading to "ecodeath." We are told that we have to really use drastic "ecotactics:" a Senator like you should be using aggressive "ecopolitics." The whole world is being challenged to accept a protocol on "ecocide." And I suspect that psychiatrists are very soon going to be diagnosing "econeuroses." Actually, the unhappy truth of the matter is that there may well be good cause for concern over the future of man's environment. It is ling assaulted from all quarters with a gusto that is hard to grasp. Man has habitually ignored the impact that he has had on the environment, the environment that all of us depend upon for our weil-being and survival. Western man has always considered himself master of his surroundings. Until the present, with far smaller numbers and very ineffectual technology, this self-delusion made very little difference. But today we are introducing a great diversity of chemicals into our environment in vast, continuing, and exponentially increasing quantities. Among these chemicals, pesticides are worthy of particu |