Issue No. 124, June1996
Issue No. 124, June1996
Open Forum:
In an attempt to promote free and open discussion of issues, The
Agrichemical and Environmental News encourages letters and articles
with differing views. To include an article, contact:
Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491.
E-mail:
cdaniels@tricity.wsu.edu
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Home Page
Note: The AENews is now accessible from the World Wide Web
via
the Washington State Pesticide Page. The address for the page is:
http://www.wsu.edu:8080/~ramsay
Enter this address carefully, paying close attention to punctuation and spacing (no spaces between parts of the address). Some readers may experience difficulties accessing the site. These are believed to be related to the Internet and to on-line services, not the web site. If you are having a problem accessing the web page, please inform Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491. E-mail: cdaniels@tricity.wsu.edu
It was reported incorrectly in the May issue of AENews that Washington State University has mailed Pre-License and Recertification brochures to licensed applicators. Brochures are not yet available. WSU offers pesticide application training from November through March. Information may be obtained from one of the following:
Ciba will no longer carry Funginex in its product line, as of mid-year 1997. The company is currently in the process of notifying the EPA. According to a company announcement, Ciba anticipates being able to sell remaining stocks of Funginex for 12 months after notification, or until approximately June 1997.
Grain supplies are at their second lowest levels in 20 years. In terms of the number of days supply at the current consumption rate, the world grain supply has decreased from 100 days to fewer than 50 days of available grain in the last 10 years. This is the lowest per-capita level ever. Although corn production for 1996/1997 is expected to be high, corn supplies will be at the second lowest levels since 1975.
The proposed 1997 EPA budget is $6.55 billion. This is $19 million more than last year but $500 million less than EPA requested. The budget was approved by a subcommittee with budgetary responsibilities for independent agencies such as EPA. It appears that this year's EPA budget will have no policy riders, as did the more contentious 1996 budget.
The export value of U.S. agricultural products is expected to hit a record $60 billion, up nearly 10% from last year's record-setting level of $54 billion. The U.S. is increasing exports at a faster rate than that of the nearest competitor, the European Union. Japan is the leading buyer of U.S. agricultural products, buying $11 billion in 1996. The U.S. is expected to import $30.5 billion of agricultural products. This will result in a $29.5 billion surplus in agricultural trade, also a new record.
In 1997, growers are expected to plant between two million and four million acres of genetically modified crops. The primary crops will be corn, soybeans and potatoes.
The Washington Attorney General's Office is quietly investigating price fixing of pesticides in Washington. Paralegals and attorneys from the office have been working the phone for months trying to collect information on how prices are set for pesticides. They are targeting efforts on some of the more widely used pesticides on the more widely grown crops. Their efforts are being coordinated with AG's offices in other states. One of the questions being asked is, "Do you know of any growers who have complained that the price of pesticides is too high?"
WSU and the Washington State Commission on Pesticide Registration will host a Pest Control Tour on July 16, 17 and 18. The tour will provide an overview of crop protection and production practices for about two dozen crops and sites of pesticide use, with the intent of identifying solutions to unmet crop protection needs. The target audience is pesticide registrants; so far, 20 organizations have reserved one or more seats on the tour. The tour will cover sites in the Yakima Valley, Horse Heaven Hills, the Columbia Basin and the Walla Walla Valley. Tour sponsors include Washington Friends of Farms and Forest, Washington State Potato Commission, Washington Asparagus Commission, Washington Association of Wine Grape Growers, Mint Industry Research Council, Washington Alfalfa Seed Commission, PNW Vegetable Growers Association, PNW Canola/Rapeseed Association, U.S. Hop Industry Plant Protection Committee, and the U.S. Dry Pea and Lentil Council.
The WSU FEQL and Pesticide Education Programs are co-sponsoring a pesticide education workshop in the Tri-Cities on October 17. The conference will focus on the current pesticide issues in Washington. Target topics are genetically engineered crop plants, cholinesterase testing for pesticides and endocrine disruptors. For more information on the workshop, contact Carol Ramsay (509-335-9222) or Alan Schreiber (509-372-7324).
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The Washington State Commission on Pesticide Registration at its sixth meeting May 22 in Yakima approved support for five additional projects. These five projects bring the number of projects supported by the commission to 37. Additionally, three previously approved projects were halted due to a manufacturer or EPA concern, one project was not funded by the commission and one project is on hold until next year.
Thus far, the WSCPR has committed $365,651 to the 37 projects. Applicants have committed $297,062 in support and in-kind services. Significant additional in-kind support is being provided by applicants, but the value of this contribution has not been determined. Including commission support and matching contribution, combined project funding approaches $700,000. Washington State University and the IR-4 Project provided significant additional support.
The enabling legislation establishing the commission instructs the commission to spend at least 25% of funding on projects not included in the top 20 commodities produced in Washington. Twenty-six of the 37 projects involve commodities outside of the top 20, and these 26 projects represent 70% of project funding.
Following is an approximate breakdown of commission funding by institutional recipient: WSU - $231,523; Oregon State University - $53,247; University of Idaho - $32,271, Pacific County Conservation District - $26,000, University of California at Davis - $21,650, USDA - $8,960 and private researcher - $2,500. OSU and UI funding was for a combination of analytical work and field trials, with the majority of support for laboratory analysis. UCD funding was for laboratory analysis. Pacific County Conservation District, USDA and private research funding was for field trials.
The 37 projects included a surprisingly wide array of crops or sites, reflecting the great diversity of crop protection needs in the Northwest. A total of 27 crops or sites are included in the 37 projects (some projects involve multiple projects). Crops or sites receiving commission support are dry peas/lentils/chickpeas (3 projects), timothy, onion (2 projects), raspberry (2 projects), mint, asparagus, green pea (2 projects), currants, lettuce, strawberry, bluegrass seed, clover seed, apple, pear, rhubarb (2 projects), umbelliferae seed, canola, hops (5 projects), oysters, spinach seed, radish seed, vegetable seed (3 projects), flower bulb, carrots and aquatic weeds.
The project objectives propose to address some of the state's greatest crop protection, human health and environmental issues. The oyster project seeks less risky control alternatives to aerial application of carbaryl for control of burrowing shrimp in Willapa Bay and Grays Harbor. The bluegrass seed project is attempting to develop weed control techniques in lieu of field burning. The aquatic weed project is examining improved spartina control tactics in Willapa Bay. The strawberry project and one raspberry project are developing an organic insecticide for root weevil control. Four projects, involving dry pea/lentil/chickpea, timothy, vegetable seed and currants, are directly related to continuing emergency exemption requests.
Other commission projects include hosting a crop protection tour for registrants and development of a tracking system for pesticide availability in Washington state.
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The following article was taken from an open letter to Warbex users by John Daly, Assistant Directory of the WSDA Pesticide Management Division.
Following discussions with other state and federal regulatory agencies and considering potential future effects, the Washington State Department of Agriculture (WSDA) has decided to take immediate action to register famphur (Warbex) as a pesticide in Washington State.
During the last two years, a number of bald eagle and red tail hawk deaths1 in Whatcom County have been attributed to the misuse of Warbex, an animal drug used to control grubs on cattle. The misuse involves the application of Warbex liquid to various grains that were spread on the ground as bait, apparently to kill starlings. The subsequent secondary poisonings and deaths of eagles and other predatory birds were due to their consumption of the Warbex-contaminated starlings. One Whatcom County farmer is being charged with the "laying out of a poison" under state Fish and Wildlife law. The case was scheduled to go to court in early June.
Warbex is currently regulated by the federal Food and Drug Administration (FDA) as a general use animal drug. Until a few years ago, the product was under the dual jurisdiction of the Environmental Protection Agency (as a pesticide) and FDA (as an animal drug). In the Whatcom County eagle poisonings, FDA has been unable to pursue prosecution for the misuse of Warbex, because it was not misused as an animal drug. Misuse as a pesticide must be proven under federal or state pesticide law. Federal regulations currently prohibit the EPA from registering the product as a pesticide.
Federal law does not preempt or prohibit the state from registering the product as a pesticide. Application of Warbex to control cattle grubs is considered a pesticidal use under the Washington State Pesticide Control Act (RCW 15.58). Registration of Warbex as a pesticide will require all firms selling the product to become licensed pesticide dealers. All distribution and uses of the product, once it is registered, will be subject to regulation under the Washington State Pesticide Control Act (RCW 15.58), the Washington State Pesticide Application Act (RCW 17.21), and the General Pesticide Rules (WAC 16-228). Applications inconsistent with the Warbex label, once the product is registered, could result in fines of as much as $7,500 per violation.
If misuse of the product continues or if additional wildlife mortality occurs, WSDA will further restrict distribution and use by declaring Warbex a state Restricted Use Pesticide (RUP). If it is necessary to designate Warbex as a state RUP, all farmers must possess a WSDA private applicator license to purchase or use the product. In addition, dealers must keep records on the sales of restricted use pesticides and users must maintain application records on their use.
WSDA recognizes that Warbex is a legitimate treatment for parasites on cattle and that most individuals use Warbex responsibly. However, the consequences of misuse (including death of protected species) call for additional protective measures. WSDA understands the inconvenience and the additional regulatory burden placed on legitimate users, but cannot ignore its mandate to protect state resources from the effects of pesticide misuse.
WSDA, in conjunction with the agriculture community and fish and wildlife interests, is asking for everyone's cooperation in using chemicals responsibly to prevent unintended adverse environmental consequences. WSDA and others are working to find effective, legal alternatives to managing starling pest populations that will not lead to further environmental harm.
Those interested in finding alternatives to Warbex may contact the WSDA office in Olympia; Dave Grusenmeyer, Whatcom County Extension (360)-676-6736; or Debbie Becker, Washington Dairy Federation at (360)-754-4025 to join in upcoming discussions.
For further information, contact Ted Maxwell, WSDA Program Manager, Pesticide Registration at (360)-902-2030 or Cliff Weed, WSDA Program Manager, Compliance at (360)-902-2040.
1 Sixteen bald eagle and six redtail hawk deaths due to Warbex secondary poisoning were documented in 1995. Three bald eagle deaths were in 1996. As the U.S. Fish and Wildlife Agency has demonstrated through studies, only 10-20% of carcasses are recovered; the numbers of birds killed could be much higher.
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Value of Production of Top U.S. Crops -- 1993-1995 | ||
(x 1000 dollars) | ||
Average | Rank | |
| Corn | 20,723,178 | 1 |
| Soybeans | 13,423,386 | 2 |
| Wheat | 8,453,412 | 3 |
| Alfalfa | 6,804,224 | 4 |
| Cotton | 5,956,082 | 5 |
| Tobacco | 2,694,064 | 6 |
| Potatoes | 2,677,239 | 7 |
| Grapes | 1,903,745 | 8 |
| Tomatoes | 1,670,535 | 9 |
| Apples | 1,546,608 | 10 |
| Oranges | 1,531,574 | 11 |
| Rice | 1,365,919 | 12 |
| Sorghum | 1,322,264 | 13 |
| Sugarbeets | 1,129,079 | 14 |
| Lettuce | 1,123,648 | 15 |
| Peanuts | 1,092,796 | 16 |
| Almonds | 906,331 | 17 |
| Sugarcane | 893,556 | 18 |
| Barley | 874,660 | 19 |
| Strawberries | 753,742 | 20 |
Source: USDA National Agricultural Statistics Service (1993-1995 averages)
I happened to catch the Natural Resources Defense Council's press conference on May 28 on C-Span. The NRDC used a preliminary EPA report on pesticide usage to suggest that there has been a dramatic increase in risk to the public and the environment due to an increase in pesticide usage.I was quite disturbed by the information that the NRDC was releasing. There were two particular points I feel are misleading. First, Robert F. Kennedy, Jr., senior attorney for NRDC, stated that the Delaney Clause had protected the U.S. food supply from cancer-causing additives and that Congress would increase the public's risk of contracting cancer by revoking it. This is untrue. Historically, EPA has not enforced the Delaney Clause, so it has not provided any protection, nor would it if it were enforced. The second misleading and more important issue put forward by NRDC was that increased pesticide usage is synonymous with increased risk. While this is not necessarily true, I did not know how to respond. Fortunately, someone did. Following is an article by Leonard Giannessi from the National Center for Food and Agricultural Policy.
...Alan Schreiber
The Natural Resources Defense Council (NRDC) on May 28 released a press announcement stating that pesticide use increased dramatically during the last two years. Contrary to a preliminary Environmental Protection Agency report released publicly by the NRDC on that day, U.S. pesticide use did not increase by more than 100 million pounds annually between 1993 and 1995. The preliminary EPA report is seriously flawed, and the EPA should carefully consider revising its pesticide usage estimates before releasing the report in final form. Also, the NRDC should utilize more due diligence in verifying its information before releasing it publicly. Finally, industry representatives need to do more to ensure that the public is accurately informed about the quantities of pesticides used in agriculture each year. In total, this incident exhibits the need for comprehensive, accurate, publicly available information on pesticide use in U.S. agriculture.
Discrepancies in Data
More than one half of the supposed increase
(1993-95) in pesticide use is due to increased EPA estimates for sulfur (+15
million lbs) and petroleum oil (+30 million lbs). In reality, the 1995 EPA
estimates merely reflect a long-overdue increase in estimated usage for these
two compounds. Earlier EPA estimates (in particular, the 1993 estimates)
were gross underestimates of their usage. If EPA were to revise its 1993
estimates for these two products to reflect actual reported data for that
year, there would be no increase of 45 million pounds for 1993-95.
For example, EPA estimated for 1993 that U.S. farmers used 45 million to 50 million pounds of sulfur and 20 million to 25 million pounds of petroleum oil. And yet, the California EPA Pesticide Use Report indicated that 1993 actual usage of sulfur in California totaled 73 million pounds. Thus, EPA's national sulfur estimate for 1993 was 26 million pounds less than the reported usage in California alone. The National Agricultural Statistics Service (NASS) reported that the usage of petroleum oil by fruit growers in 1993 totaled 56 million pounds, which is 30 million pounds more than EPA's national estimate for 1993. Thus, one option that EPA has in releasing a final report for 1995 is to revise the 1993 estimates. This would lessen significantly the impact of the supposed increase from 1993 to 1995.
EPA identifies methyl bromide as one of the pesticides that increased significantly in use by U.S. farmers from 1993 to 1995; it is reported as increasing from 30 million to 35 million pounds in 1993 to between 56 million and 61 million pounds in 1995. This is a surprising trend, because the U.S. has agreed, as part of an ozone-protection program, to freeze production and consumption of methyl bromide at 1991 levels. If the U.S. is in compliance, the large increase in agricultural usage of methyl bromide must have come from some reduced use by industry or government. This is highly unlikely, because agricultural crop production has been identified consistently as the largest use of methyl bromide. Once again, the more likely cause of this discrepancy is a significant EPA underestimation of methyl bromide use in 1993.
Pesticide Data Problems
Environmental Protection Agency
The real problem is that estimating
pesticide usage for many compounds is very inexact. EPA has no independent,
statistically valid set of data. The public may believe that these are official
EPA estimates based on complete knowledge, but the truth is that EPA has
only limited pesticide use data. The sole statement of documentation for
EPA's usage estimates is "EPA estimates based on a variety of sources". Perhaps
a Science Advisory Board should scrutinize the procedures used by EPA. What
are the statistical procedures used by EPA staff in making these estimates?
One of EPA's primary sources of data is proprietary multiclient pesticide use market surveys conducted by private contractors mainly for sale to agrochemical companies. The contractors sell a set of annual reports to EPA, but these are proprietary. EPA can't make any of the estimates public. Thus, it is difficult for outsiders to judge the accuracy and completeness of the surveys on which EPA bases its estimates. One of the drawbacks of these market survey reports is, while they do a good job of reporting use on high-acreage field crops such as corn and soybeans, it is unclear what level of accuracy can be assigned to data on low-acreage crops, including many fruit and vegetable crops, the primary users of sulfur and petroleum oil. To fill the need for more accurate data for fruit and vegetable crops, several additional private marketing reports are used by the agrochemical industry. Unfortunately, EPA does not subscribe to all the available private market reports.
EPA's limited usage of available reports is apparent also in its preparation of 1995 estimates prior to the release of a major 1995 survey of U.S. fruit growers conducted by USDA's National Agricultural Statistics Service (NASS). Congress provided USDA with $4 million to conduct a survey of pesticide use by U.S. fruit growers in 1995. The report is scheduled for release on July 17, 1996. Wouldn't it be prudent for EPA to wait until the USDA report is available before finalizing estimates for 1995?
As a way to avoid misinterpretation of data, EPA needs to consider providing more information about the pesticides that are ranked in its list of highest volume of usage. The current lack of information can lead to serious misinterpretations by others. For example, NRDC's press release extols the "real environmental stewardship of organic growers" while, at the same time, raising serious risk concerns about sulfur and petroleum oil, two pesticides used widely by organic growers and ranked by EPA among its top five. Perhaps EPA should provide two lists and keep the synthetic chemicals separate from the non-synthetic chemicals. Many groups, such as NRDC, labor under the mistaken belief that organic growers don't use pesticides. The truth is that not only do organic growers use pesticides, but they use them at extremely high rates in comparison to the rates generally used for more sophisticated and better-designed synthetic chemicals.
EPA needs to revise this report carefully. The pesticide usage report is the most frequently distributed report from the Office of Pesticide Programs. It is the only long-term source of year-to-year variations in pesticide use. The report is taken seriously and used widely by many analysts. EPA should take it as seriously. There are obvious political and policy implications of a data trend suggesting a dramatic increase in pesticide use. If there has not been a real increase in pesticide use, public policy decisions and Congressional deliberations are being misled.
Natural Resources Defense Council
The Natural Resources Defense
Council acted prematurely by publicly announcing data clearly marked
"preliminary" before checking it with other sources. The preliminary report
received no internal EPA or external review. It was not approved by management
prior to its release to the NRDC.
NRDC suggests that the purported increase in pesticide use runs counter to the claim of the pesticide industry that it has adopted stewardship programs to reduce pesticide use. However, EPA, the chemical industry and commodity groups have agreed to work toward policies that reduce risk, not volume, of pesticide use. As such, one of the dramatic changes that NRDC highlights was directly the result of EPA's "safer" pesticide policy. The meteoric increase in the use of acetochlor (it was at zero in 1993, and increased to between 22 million and 27 million pounds in 1995) is a direct result of the registration of acetochlor under the "safer" EPA policy. Increased use of acetochlor led to a dramatic decline in the use of alachlor (also noted by NRDC).
If the NRDC had consulted earlier EPA reports, it could have noted, with some satisfaction, a very large reduction in pesticide use. By comparing draft EPA 1995 estimates with 1987 estimates, the following major reductions in national pesticide use can be discerned:
Change 1987-1995 | |
Atrazine | 17 million lbs/year |
2,4-D | 25 million lbs/year |
Alachlor | 66 million lbs/year |
Butylate | 45 million lbs/year |
Trifluralin | 6 million lbs/year |
Of course, some of these reductions were partially offset by increased use of replacements. An increased use of five million pounds of metolachlor from 1987-95 contributed to the sharp decline in the use of butylate (butylate is used at a much greater per acre rate than metolachlor). The reduction in atrazine use from 1987-95 is the result of a significantly reduced average per acre use rate (the same number of acres are being treated with atrazine in 1995, but at a significantly lower rate per acre than in 1987). The underlying causes of these and other changes in pesticide use were not discussed by the NRDC.
Summary
Further analysis brings to light serious
doubts about the accuracy of the pesticide use data released by the EPA.
The data are preliminary and were released improperly from the EPA without
adequate review. The NRDC should have readily acknowledged the weakness of
the data and sought other sources of data to determine the validity of the
EPA estimates. Finally, private industry should understand the importance
of ensuring that the government and the public are well informed. This incident
should serve as a lesson to all parties involved. Accurate, comprehensive,
publicly available pesticide use data are needed in order to make informed
and fair public policy decisions.
Leonard P. Gianessi is a senior research associate at the
National Center for Food and Agricultural Policy
1616 P Street, N.W.,
1st Floor
Washington, D.C. 20036
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1. Must be multiple rinsed, so that no residues remain.
2. Must be clean and dry inside and out, with no apparent odor.
3. Hard plastic lids and slip on lids must be removed.
4. Glue-on labels may remain.
5. The majority of the foil seal must be removed from the spout.
A small amount of foil remaining on the container rim is acceptable.
6. Half pint, pint, quart, one and two-and-a-half-gallon containers
will
be accepted whole.
7. Five-gallon containers will be accepted whole if the lids and bails
are removed.
8. Special arrangements must be made for 30-gallon and 55-gallon
containers, by calling (509) 457-3850 prior to the collection.
Containers not meeting above specifications will not be accepted.
| Date | Site | Sponsor/contact | Phone | |
| 6/20 8-noon | Wilbur-Ellis | Wilbur-Ellis/Wolfkill Al (Wilbur-Ellis) Rick Florine (W. Kill) | 509-932-4988 509-932-4769 | 509-678-5750 |
| 6/28 8-noon | Othello Airport | Othello Air Applicators Steve George | 509-457-3850 | |
| 6/7 8-noon | Wilbur-Ellis Quincy | Columbia Basin Veg./Seed Assoc. Ron Turner | 509-787-3556 | |
| " | " | Simplot Soil Builders John Cullen | 509-837-6261 | |
| " | " | Monsanto Ted Nullinger | 509-966-2363 | |
For more information about plastic pesticide container collection, contact:
Steve George
WPCA Recycling Coordinator
31 High Valley View St.
Yakima, WA 98901
(509) 457-3850
or the WAPP web site at
http://www.wsu.edu:8080/~ramsay/wpca.html
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This is an opinion essay; the views presented herein are those of the author.
Toxicologists have long accepted the concept that biological effects are proportionate to the dose to which an organism is exposed. Thus was born the paradigm, "The dose makes the poison." It has served our understanding of physiology well since the late 1500s, when Paracelsus first recognized that a chemical poisonous in large amounts could be therapeutic in lesser amounts. Until recently, all biological responses to foreign substances, with the exception of cancer, were believed to follow this paradigm. Cancer was always considered separately by the EPA, which proclaimed no threshold for response. To declare no threshold is to accept the idea that one molecule of a foreign substance that causes a mutation could lead to cancer. But even this view is changing, at least among biochemical toxicologists, who now realize that cellular toxicity caused by feeding rats high doses leads to tumors that do not appear at lower doses. Thus, EPA has proposed revamping its carcinogenicity assessment and classification system to consider how fast and into what substance a compound is broken down, its distribution in the body, and its mechanism of action. The fate of a chemical in the body depends on initial dose.
Just as the EPA appeared to be shifting to a more rational risk assessment of chemicals, along came the book, Our Stolen Future - Are We Threatening Our Fertility, Intelligence, and Survival? - A Scientific Detective Story. This book hypothesizes that the concept of "dose makes the poison" is actually irrelevant; the real problem is not cancer, but disruption of the endocrine system. The endocrine system, through the use of hormones or "chemical messengers", controls everything from reproductive and neurological development to everyday metabolism. Change the endocrine system, and other physiological functions are changed.
Our Stolen Future has been depicted as "picking up where Silent Spring left off." It would be a mistake, however, to dismiss this book as just another diatribe from scientists associated with environmental advocacy organizations. I hope that risk assessors and managers (i.e., scientists in regulatory agencies) will not only read the book but also examine the scientific articles that the book references. When someone is trying to change the paradigm for how we view our chemical technology we had better be certain about what is being proposed and the nature of the evidence supporting the new rules.
The harsh criticism Our Stolen Future directs at persistent chlorine-containing chemicals is nothing new. DDT, PCBs, and dioxin are familiar rallying cries against the evils of chemical technology. But, Our Stolen Future has taken the argument to a new playing field. Biochemical studies have shown that these chemicals, or at least their metabolites, can mimic the hormones estrogen and testosterone, which are responsible for more than just sexual development. Furthermore, the effects of exposure to these chemicals and, thus, the real hazard is not to adults, but to the developing fetus and perhaps to newborns. Prenatal exposure is purported to result in reproductive maladies, including decreases in fertility and intellectual development, that do not appear until later in life. Our Stolen Future argues that the adverse reproductive effects and strange malformations reported in aquatic wildlife are sentinels warning of what is happening in humans.
Perhaps we've heard this before. But the authors emphasize throughout the book how endocrine system effects are different from cancer, because the endocrine system works similarly among different organisms and even "low" doses of certain contaminants produce effects. More alarmingly, the authors state that hormone systems "do not conform to the assumption that underlies classical toxicology - that a biological response always increases with dose." They cite a study in which low doses caused effects not seen at higher doses and, thus, concluded that "testing with very high doses will miss some effects that would show up if the animals were given lower doses. Extrapolation from high-dose tests to lower doses may in some cases seriously underestimate risks rather than exaggerate them." In short, Our Stolen Future challenges prevailing notions about toxicity. Or does it?
I cannot in one essay discuss and provide counterpoint to all the hypotheses in Our Stolen Future. I will, however, challenge the idea that we should throw out the paradigm of "dose makes the poison." One study cited in Our Stolen Future illustrates why changing the paradigm is not warranted by the evidence. In the June 1995 issue of the journal Nature, W. R. Kelce and co-workers from the EPA reported that DDE, the stored form of DDT, could cause developmental problems by interfering with the normal functions of the male hormone testosterone. If a male fetus or newborn infant were exposed to DDE during a critical stage in development, then sexual development could be impaired, somewhat similarly to what would happen if the male fetus were exposed at the wrong time to overly high levels of the female hormone estrogen. Yet, Kelce's own studies clearly showed a level of DDE at which there was no effect. In other words, a threshold concentration of DDE was required before a response was observed.
When critically analyzing the results of chemical exposure tests, one must differentiate between observations from test tube or cell culture (`in vitro' or "out of the body") experiments and whole animal feeding (`in vivo') studies. Using in vitro biochemical tests, Kelce observed anti-testosterone effects at low levels of DDE, but even these tests indicated the existence of a threshold for effect. To see any effect in vivo, Kelce pumped massive doses of DDE, i.e.,100 milligrams (mg) per kilogram (kg) of body weight, directly into the stomachs of neonatal rats daily for 32 days. To put this dose in perspective, the Food and Drug Administration estimates daily exposure of total DDT residues in the diets of infants to be 0.00008 mg per kg body weight. Thus, in 32 days an infant may be exposed to 0.00256 mg, which is 1,250,000 times less than what Kelce's rats were fed. When subjected to similar critical analysis, other articles cited in the book also show that dose clearly matters and that there are thresholds for effect.
I credit the authors of Our Stolen Future with pointing out that we have been too focused on cancer, and that the endocrine system may be the most vulnerable target on which to focus. However, the overwhelming discussion in Our Stolen Future focuses on compounds that have been banned for the last 20 years. Ironically, the EPA banned these compounds because the results of extremely high dose testing were interpreted as indicative of the potential for causing cancer at the much lower levels characteristically present in the environment.
Our Stolen Future will provide grounds for new studies for years to come. I am certain that simple laboratory tests for endocrine disruption effects will become widely available, just as tests for mutagenicity did over the last two decades. However, I believe a strong case can be made that the rules of the game have not changed. To announce the demise of "dose makes the poison" would be premature.
Allan Felsot is an evironmental toxicologist at the Food and Evironmental Quality Laboratory.
A bibliography of articles related to this subject is available upon
request.
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The 1995 Washington State Legislature created the Washington State Commission on Pesticide Registration (WSCPR) to assist pesticide users in obtaining and maintaining pesticide registrations for minor uses in Washington state. As instructed by the Legislature, Washington State University (WSU) has made funds available specifically for studies and activities related to pesticide registration as approved by the WSCPR.
Intent: The purpose of the WSCPR is to fund studies and activities resulting in pesticide registrations for minor uses in Washington. A minor use is a pesticide use pattern so limited in volume that the cost of obtaining or maintaining the registration is greater than the expected return to the registrant. Only proposals for projects expected to result in obtaining or maintaining a pesticide registration will be considered.
General Information: Projects requiring two years of funding may be submitted, but second year funding will depend on availability of funds and satisfactory progress toward meeting project objectives. WSU researchers who submit proposals must obtain prior budget approval from Tom Kelley of the CAHE Business Office. One proposal may be submitted per project.
Generally, the WSCPR provides no funds for equipment purchases. If purchase of equipment is necessary and WSCPR funds are to be requested for that use, the equipment and estimated cost of purchase should be clearly identified and explained in the proposal budget. The WSCPR reserves the right to retain ownership of equipment once the project funding period is completed.
Proposals must originate from the affected pesticide user community: The request may be from an individual, company or organization on behalf of a particular user community. Requests will not be accepted from pesticide manufacturers, dealers or distributors. Funded projects may be carried out by qualified university or USDA specialists, private researchers or laboratories. Individuals and organizations in other states may submit proposals or collaborate with Washington researchers. Additionally, because pesticide residue data from Idaho and Oregon can suffice for Washington in the registration process, researchers in those states may submit proposals. Applicants are encouraged to suggest field and/or laboratory researchers or other individuals to carry out project activities; however, the WSCPR reserves the right to select the individual or organization to complete WSCPR-funded projects. Project requests should be limited to five pages, not including budgets and attachments, and should state who will conduct the work, their qualifications and the time frame for project completion. Names, addresses and phone numbers of individuals involved in submitting and conducting the work should be included. Projects involving generation of pesticide residue data in support of a registration must provide for use of Good Laboratory Practices (GLP). Anyone preparing a proposal requiring GLP research must contact the WSCPR prior to proposal submission. If appropriate, manufacturer assurance of permit registration resulting from the successful completion of projects should be included as part of the proposal. Name, address and phone number of appropriate contact at the manufacturer should also be included. Researchers or grant recipients are responsible for obtaining any necessary state or federal permits.
Users of pesticides on sites or crops not in the top 20 agricultural commodities produced in Washington are especially encouraged to submit proposals; the current top 20 commodities are apples, milk, cattle and calves, wheat, potatoes, farm forest products, hay, nursery and greenhouse, pears, hops, sweet cherries, eggs, chickens and broilers, onions, grapes, asparagus, sweet corn, field corn, mint oil and Christmas trees. Proposals dealing with pesticide use on a wide variety of sites may be submitted, including but not limited to the following areas: agriculture, forestry, aquaculture, structural pest control, rights-of-way, noxious weeds, nursery, landscape, ornamentals, rangeland and mosquito control districts.
Assistance: Those needing help in proposal preparation may contact a commission member or Catherine Daniels, Food and Environmental Quality Lab, WSU Tri-Cities, 100 Sprout Road, Richland WA 99352-1643. Contact numbers are: 509-372-7492 (phone); 509-372-7460 (fax); or E-mail cdaniels@beta.tricity.wsu.edu. Examples of funded proposals are available on-line (http://picol.cahe.wsu.edu) or from the WSCPR upon request.
Match: Proposals do not require matching support, but applicants are encouraged to provide matching funding, in-kind services or materials for laboratory studies and investigations. Matching contributions should be clearly described, and the value of match should be provided. When in-kind contributions are included as all or part of a match, include an estimated value of the service, product or assistance. If the WSCPR provides project support, the requesting user group must provide the match to the WSCPR or provide documentation that the match was used in support of the project.
Description of Problem: Each proposal should briefly describe the affected industry and detail the pest problem using any of the following appropriate criteria: 1. crop farmgate value - state the estimated per acre value of the site or crop, 2. per acre/unit impact - include potential monetary losses if appropriate, 3. acres impacted, 4. aggregate impact to the industry - include aggregate value of the site or crop in the state, 5. effect of the pest problem on the industry, 6. effect of the pest problem on consumers, society, environment, non-target species or human health, 7. description of why alternative control measures are not effective, or any additional information on the specific need.
Evaluation and Selection Criteria: All proposals received will be acknowledged and reviewed for compliance with WSCPR guidelines. Proposals not adhering to guidelines will be returned to applicants; additional guidance will be extended for returned proposals. Accepted proposals will be reviewed by WSCPR. Proposals will be judged by the following criteria: 1. Relevance to stated WSCPR areas of emphasis, 2. Overall merit and quality of proposal, 3. Feasibility of completing project objectives within stated time frames, 4. Appropriateness of requested budget, 5. Adherence to WSCPR guidelines
Areas of Emphasis: (unranked in order of significance)
Deadlines: Two formal requests for proposals are issued annually; however, proposals are accepted at any time. Submit one hard copy original of each proposal with an electronic copy identifying the word processing program used to Catherine Daniels, Food and Environmental Quality Lab, WSU Tri-Cities, 100 Sprout Road, Richland WA 99352-1643. Contact numbers are: 509- 372-7492 (phone); 509-372-7460 (fax); or E-mail cdaniels@beta.tricity.wsu.edu. Proposals will be reviewed by the WSCPR at the next regularly scheduled meeting. Applicants should be available to make a brief presentation and respond to questions from commissioners at that meeting. A final report should be submitted to the WSCPR within one month of project completion.
The next meeting for the Washington State Commission on Pesticide Registration is scheduled for 10 a.m. July 24 at WSU-IAREC, Prosser. A subsequent meeting is to be held in Ellensburg in September.
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The lower Yakima Valley of south central Washington state is a highly diversified irrigated agricultural region where dryland wheat is grown in close proximity to irrigated minor crops. The extensive use of herbicides in the dryland farming of Horse Heaven Hills as well as in the lower Yakima Valley has contributed greatly to increasing agricultural production in the region. However, the widespread use of herbicides has resulted in occasional herbicide symptoms on nontarget crops. Thus, complaints of herbicide drift from target crops to nontarget crops have over the years been a concern in the Yakima Valley.
Injury to nontarget crops may occur from point sources such as direct drift of sprays during application or from secondary drift as a result of vapor movement. In the former case, drift of a well defined mass of aerosols occurs during the actual spray operation. Depending on whether spraying is by tractor or aircraft, deposition of most aerosols occurs within 500 meters of the spray. In the case of secondary drift, movement of pesticide vapor occurs after the deposition of spray aerosols and thus can occur over a longer period of time and perhaps over greater distances than point source drift. An atmospheric inversion could enhance the long-distance movement of pesticide residues, whether from direct or secondary drift, away from the targeted field. Vapor drift has caused contamination of nontarget crops with pesticides unregistered for these crops.
The concept of using sensitive plant species as sentinel plants to detect airborne phytotoxic chemicals and exposure of nontarget plants is not new. A large number of cultivated or ornamental plants may qualify as sentinel species and can be particularly useful for biomonitoring, especially when analytical methods for contaminants are unavailable. For example, sulfonylurea (SU) herbicide residues are difficult to detect at levels of low parts per billion and parts per trillion on plants through available analytical methods. In response to complaints of herbicide drift, WSU scientists at the Food and Environmental Quality Lab in Richland and the Irrigated Agricultural Research and Extension Center (IAREC) in Prosser designed a sentinel biomonitoring network to detect incidents of atmospheric deposition of herbicides, whether it be from drift as conventionally defined or from nonpoint source atmospheric deposition. The network is formed by cooperators living within the Badger Canyon, Horse Heaven Hills and Finley areas who agree to keep WSU sentinel plants on their properties from April to September. The sentinel plants consist of two sets of peas, beans and corn seedlings held within a screened cage at each location. The plant sets are picked up and replaced with new sets on a weekly basis. Sets are returned to IAREC in Prosser, where they are observed for symptoms that may indicate exposure to various herbicide residues.
During 1993, sentinel plants were placed at 25 locations around Benton County. During 1994 and 1995, the sentinel biomonitoring network was expanded to 50 locations in Benton and Franklin counties. Symptoms characteristic of exposure to drift-size aerosols of chlorsulfuron (Glean), 2,4-D, glyphosate (Roundup), and paraquat (Gramoxone) (as determined by controlled tests at IAREC) were recorded, and the number of locations harboring plants with similar symptoms were plotted relative to time of plant collection.
The Washington State Department of Agriculture (WSDA) issued a pesticide application record call-in that coincided with the area where sentinel plants were located. This allowed testing of the hypothesis that the widespread observations of herbicide symptoms (eg. chlorotic spots on early leafing vegetation) in south central Washington result largely from deposition of regionally transported herbicide residues rather than from specific point sources. The results of sentinel biomonitoring in south central Washington during three years (1993-1995) are summarized in Fig.1.
Few sentinel plants exhibited symptoms of 2,4-D exposure during 1993 or 1995. However 2,4-D exposure was very significant during 1994. Most incidents of 2,4-D exposure occurred during a time when comparatively little herbicide was used. Exposures to glyphosate and paraquat were generally infrequent and occurred later in the growing season.
During 1993-1995, chlorotic spots characteristic of SU exposure were observed on sentinel plants from the first week in April until the second week in May.
The maximum percentage of sites with plants exhibiting symptoms (about 50%) always occurred during the first two weeks of April. After May, no symptoms characteristic of SU exposure were observed. Overall incidence of sites with chlorotic spots was 50% less during 1995 than during 1993 or 1994. In contrast to 1993 and 1994, no symptoms characteristic of SU exposure were observed after the second week of May 1995, while the symptoms disappeared during the third week of May 1993 and 1994.
The total hectares of SU herbicide sprayed and the timing of applications in Benton and Franklin counties varied each year and were influenced by prevailing weather conditions and status of the wheat crop. Sixty percent fewer hectares were sprayed in the region during 1995 than during 1994. During 1993-1995, applications of SU herbicides were at low points during the same week that sentinel plants were showing the highest incidences of chlorotic spots. For example, when sentinel plants were first placed in the field during 1994 and 1995, incidences of symptoms were prevalent on 50% and 25% of the sites, but only 685 and 380 hectares had been sprayed, respectively.
During 1994, nearly 4,000 hectares had been sprayed in Benton and Franklin counties prior to April 5. Chlorotic spots were seen at about 50% of sentinel plant sites the first two weeks of April, while significant acreage was still being sprayed. Symptoms declined during the last two weeks of April and the first two weeks of May, coincidentally with a decline in hectares sprayed. However, during the week prior to May 3, about 20% of sentinel plant sites were recorded with symptoms, yet almost no hectares were sprayed. The results from biomonitoring in 1993-1995 and pesticide application records showed very similar trends. The timing of chlorotic spotting on sentinel plants is independent of the total number of hectares sprayed with SU herbicides. The conclusion is that no correlation exists between use of SU herbicides and the number of sentinel plants showing symptoms. Thus, the widespread chlorotic spotting probably arises as a result of a regional transport and deposition of herbicide residues at very low concentrations.
Muhammad A. Bhatti is a research associate at the Food and Environmental Quality Laboratory.
This article is based upon Biomonitoring with Sentinel Plants to Assess Exposure of Nontarget Crops to Atmospheric Deposition of Herbicide Residues. Felsot, A.S., Bhatti, M.A., Mink, G.I. and G. Reisenauer. Environmental Toxicology and Chemistry, Vol. 15, No. 4, pp. 452-459. 1996. SETAC.
Copies may be obtained from either Dr. Allan S. Felsot or Dr. Muhammad
Bhatti at
Washington State University
Food and Environmental Quality
Lab
100 Sprout Road
Richland, WA 99352-1643
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Washington's Pesticide Incident Reporting and Tracking (PIRT) Review Panel recently released its annual report on pesticide incidents in Washington during 1994. The report describes the activities of the panel, analyzes 1994 complaint investigations and summarizes incidents from 1995. Three state agencies, including the Department of Health, Department of Agriculture and the Department of Labor and Industries, as well as the Washington Poison Center contributed data for the report.
In 1994, WSDA conducted 383 investigations, DOH conducted 589, L&I Consultation and Compliance Services conducted 14 and L&I Insurance Services Division Claims Administration Program received 241 pesticide-related worker compensation claims. Some of these reports were received by more than one agency. For example, L&I referred all of its pesticide-related claims to DOH for investigation. Total incidents investigated by DOH and WSDA were 972 (page 30 PIRT report).
1994 Pesticide Incident History by Agency | ||||||
| DOH (589 reports involving 691 individuals) | ||||||
| Relationship to exposure for 691 cases | ||||||
| definite 41 (6%) | probable 79 (11%) | possible 90 (13%) | ||||
| unlikely 102 (15%) | unknown 71 (10%) | unrelated 71 (10%) | asymptomatic 233 (34%) | |||
| 15 hospitalizations | ||||||
| pesticide-related exposures 7 | unrelated to pesticides 5 | ingestion exposures 3 | ||||
| 230 childhood cases | ||||||
| rodenticide exposures 173 | non-rodenticide exposures 57 | occupational exposures 3 | ||||
| WSDA | ||||||
| 383 total complaints | ||||||
| complaints related to pesticides 198 | ||||||
| 138 violations | ||||||
| pesticide violations 92 | violations not related to pesticides 46 | |||||
| Enforcement actions, excluding pending cases | ||||||
| fine/suspensions 8 | days per license suspension 25 | warning letters 32 | civil fines $4,450 | |||
| L&I consultation and compliance (inspections 14, violations 34) | ||||||
type of business: | ||||||
| orchards 6 | construction/landscape 3 | greenhouse/nursery 2 | other/farms 3 | |||
| L&I claims | ||||||
| pesticide-related claims 241: | ||||||
| agricultural 176 | non-agricultural 65 | |||||
| primary source of ag claims: | ||||||
| orchards 133 | ||||||
| Counties with largest number of complaints | ||||||
| Yakima 141 | King 133 | Pierce 75 | Spokane 63 | |||
| Grant 55 | Franklin 46 | Okanogan 43 | ||||
| In 1994, 546 complaints came from eastern Washington and 439 came from western Washington. One case came from out of state. | ||||||
| Activity for WSDA and DOH incidents | ||||||
| agricultural 382 (29%) | residential 331 (34%) | comm./ind. 205 (21%) | ||||
| other 47 (5%) | unknown 7 (1%) | |||||
| WSDA complaints by type of activity | ||||||
| Activity | 1992 | 1993 | 1994 | |||
| agriculture | 316 | 168 | 165 | |||
| comm./ind. | 81 | 141 | 133 | |||
| residential | 56 | 63 | 68 | |||
| other (license, records) | 105 | 28 | 17 | |||
| total | 558 | 400 | 383 | |||
| 1994 DOH source of reports for incidents | ||||||
| Washington Poison Center | 305 (51.8%) | |||||
| L&I | 199 (33.8%) | |||||
| WSDA | 34 (5.8%) | |||||
| individuals | 21 (3.6%) | |||||
| health care provider | 15 (2.5%) | |||||
| other | 15 (2.5%) | |||||
| total | 589 | |||||
| DOH -- Number of people involved per incident | ||||||
| # of people | incidents | individuals affected | ||||
| 1 | 533 | 533 | ||||
| 2 | 37 | 74 | ||||
| 3 | 12 | 36 | ||||
| 4 | 3 | 12 | ||||
| 5 | 1 | 5 | ||||
| 7 | 2 | 14 | ||||
| 17 | 1 | 17 | ||||
| total | 589 | 691 | ||||
| DOH -- Medical care received by case | ||||||
| ER visit 289 (43%) | physician visit 192 (28%) | no medical care 74 (11%) | other/ unknown 19 (3%) | |||
| totals | 691 individuals | |||||
| Pesticides most commonly associated with WSDA violations: | ||||||
| 2,4-D (10) | chlorpyrifos (9) | diazinon (8) | carbaryl (6) | |||
| In 1995, WSDA, DOH and L&I responded to approximately 893 complaints; more than 224 were responded to by more than one agency. | ||||||
For more information on the 1995 PIRT Panel report, contact Vicki Skeers, DOH, Pesticide Section, P.O. Box 47825, Olympia, WA 98504-7825.
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The following tolerances were granted by EPA since the last report (May 1996). These data do not mean that a label has been registered for this use. These pesticides must not be used until a label is registered with EPA or a state department of agriculture.
*Key
| A=adjuvant | D=desiccant | D/H=desiccant, herbicide | F=fungicide |
| FA=feed additive | FM=fumigant | G=growth regulator | H=herbicide |
| I-insecticide | N=nematicide | P=pheromone | V=vertebrate repellent |
| Chemical* | Petitioner | Tolerance (ppm) | Commodity (raw) |
| (H) fenoxaprop-ethyl | AgrEvo | 0.05 | cattle:fat, meat, mbyp goats: fat, meat, mbyp hogs: fat, meat, mbyp horses: fat, meat, mbyp sheep: fat, meat, mbyp |
| 0.02 | milk | ||
| 0.05 | wheat: grain, straw | ||
| (I) cyromazine | CIBA-Geigy | 1 | tomato |
| (H) tebuthiuron | RED tolerance assessment | 10 | grass: forage, hay |
| (I) tefluthrin | Zeneca | 0.06 | corn: grain, field, pop, forage and fodder, sweet, fresh (including sweet K and CWHR) |
| (A) xanthan gum-modified | Rhone-Poulenc | exempt | when used as a surfactant |
| (I) imidacloprid | Bayer | 0.6 | pome fruits crop group |
| (H) lactofen | IR-4 | 0.05 | beans, snap |
| 0.05 | soybeans | ||
| (H) clomazone | IR-4 | 0.05 | beans, snap |
| (I) avermectin B1 and its Delta-8,9-Isomer | IR-4 | 0.015a | cattle, fat |
| 0.02a | cattle: meat, mbyp | ||
| 0.02a | citrus whole fruit | ||
| 0.5b | hops, dried | ||
| 0.005a | milk | ||
| (I) allyl isothiocyanate as a component of food grade oil of mustard | Champon 100% Natural Products | exempt | all raw agricultural commodities |
| (FM) propylene oxide | Aberco | 150c | almonds, filberts, pecans, pistachios, walnuts |
a=Time limited tolerance expires April 30,
1996
b=Time limited tolerance
expires December 31, 1996
c=Time limited tolerance
expires May 20, 1998
Specific exemptions have been granted for the following uses:
A crisis exemption has been granted for the following use:
The source for this information, the Reregistration Notification Network, is a cooperative effort of USDA-NAPIAP, Interregional Project No. 4 (IR-4), U.S. Environmental Protection Agency (USEPA), and the American Crop Protection Association (ACPA).
For additional information on any reregistration notification, contact the individual(s) listed or contact:
Alan Schreiber
WSU Pesticide Coordinator
100 Sprout Road
Richland,
WA 99352-1643
Phone: 509-372-7378
Fax:
509-372-7460
aschreib@beta.tricity.wsu.edu
The USEPA has proposed revocation of tolerances established for residues
on commodities for 13 pesticides for which all registrations have been canceled.
Because of the time that has elapsed, the USEPA is proposing immediate revocation
of residue tolerances for the following nine pesticides: the herbicides sesone
(SES), fluchloralin (Basalin), and metobromuron (Patoran); the fungicides
basic zinc sulfate (BSZ), hexachlorophene (Nabac, Hexaphene), and manganous
dimethyldithiocarbamate (manam); the insecticides ethyl formate, and hydrogen
cyanide (hydrocyanic acid); and the plant growth regulator metachlorphenprop.
The remaining four pesticides have been registered as recently as 1993 and
used as recently as 1995. The USEPA is therefore proposing to delay revocation
of the tolerances for the herbicides dalapon (Dowpon) and diphenamid (Enide),
and the fungicides glyodin (Glyoxide, Glyodex) and DNOC (Elgetol) until 5/1/99.
The USEPA is not recommending the establishment of action levels in place
of these regulations. Written comments, mentioning OPP-300408, should be
sent to the Public Response Section of EPA by 7/29/96. For information,
contact: Mr. Owen F. Beeder, EPA, Registration Division, phone: 703-308-8351,
fax: 703-308-8369,
E-mail: beeder.owen@epamail.epa.gov
Send written comments to: Public Response Section (7506C), EPA, Office
of Pesticide Programs, 401 M Street, SW, Washington, DC 20460
E-mail:
opp-docket@epamail.epa.gov
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Label restrictions for Special Local Needs in Washington: The following
pesticide uses have been granted label registration by the Washington State
Department of Agriculture under the provision of Section 24(c) amended
FIFRA.
The Southern Region Pesticide Impact Assessment Program has developed an interesting and useful group of pesticide education fact sheets:
The Delaney Clause; A proper perspective on pesticide toxicity; Why use pesticides?; Federal pesticide laws and regulations; Pest resistance to pesticides; Pesticides and the Endangered Species Protection Program; Pesticide residues in food: the safety issue; and Pesticide usage in the United States: history, benefits, risks and trends.
Hard copies of these fact sheets may be obtained, free of charge, by
contacting:
Stephen J. Toth, Jr.
Department of Entomology, Box
7613
North Carolina State University
Raleigh, NC 27695-7613
phone:
(919)-515-8879, fax: (919)-515-7746
E-mail: Steve_Toth@ncsu.edu
Electronic copies of the fact sheets may be viewed, downloaded or pointed to on the World Wide Web at the following location:
http://ipm_www.ncsu.edu/safety/Southern_region/contents.html
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Contributors to the Agrichemical and Environmental News:
Alan Schreiber, Allan Felsot, Catherine Daniels, Mark Antone, Carol Weisskopf, Eric Bechtel
If you would like to include a piece in a future issue of the Agrichemical and Environmental News or subscribe to the newsletter, please contact Catherine Daniels.
Contributions, comments and subscription inquiries may be directed to:
Catherine Daniels, Food and Environmental Quality Laboratory, Washington State University, Tri-Cities campus, 2710 University Drive, Richland, WA 99352-1671. Phone: 509-372-7495. Fax: 509-372-7491.
E-mail:
cdaniels@tricity.wsu.edu
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