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	<title>Comments on: Details on the Dirty Dozen</title>
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	<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/</link>
	<description>Stronger plants, stronger science, and stronger communication.</description>
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		<title>By: Anastasia Bodnar</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-33034</link>
		<dc:creator>Anastasia Bodnar</dc:creator>
		<pubDate>Sat, 05 Feb 2011 02:04:55 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-33034</guid>
		<description>I just saw something about this on Twitter a few days ago but now I can&#039;t find the article. There&#039;s many reports about fake organic, though, I just googled &quot;fake organic&quot; and found a few articles, such as &lt;a href=&quot;http://www.pri.org/science/environment/fake-organic-foods-proliferate-from-china2055.html&quot; target=&quot;_blank&quot; rel=&quot;nofollow&quot;&gt;Fake organic foods proliferate from China&lt;/a&gt;. The recent article I can&#039;t find (I&#039;ll post it here if I find it) talked about how there aren&#039;t enough inspectors so any single farm overseas might never be inspected to see if they are really using organic practices or not.</description>
		<content:encoded><![CDATA[<p>I just saw something about this on Twitter a few days ago but now I can&#8217;t find the article. There&#8217;s many reports about fake organic, though, I just googled &#8220;fake organic&#8221; and found a few articles, such as <a href="http://www.pri.org/science/environment/fake-organic-foods-proliferate-from-china2055.html" target="_blank" rel="nofollow">Fake organic foods proliferate from China</a>. The recent article I can&#8217;t find (I&#8217;ll post it here if I find it) talked about how there aren&#8217;t enough inspectors so any single farm overseas might never be inspected to see if they are really using organic practices or not.</p>
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		<title>By: Rich Kozlovich, Exterminator</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-33017</link>
		<dc:creator>Rich Kozlovich, Exterminator</dc:creator>
		<pubDate>Fri, 04 Feb 2011 22:17:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-33017</guid>
		<description>The Environmental Working Group is nothing more than a scare factory that only exists if it can generate scares long into the future.  The fact that pesticide residues are detectable is meaningless without determining the dose, and pesticide residues on food is so low that it means nothing to our health, other than the fact they these residues are the end result of wonderfully high production and low cost for life saving products....food!

As Dr. Bruce Ames notes; you will receive more carcinogens in one cup of coffee than the entire pesticide residue on all the food you will eat in one year.  We almost have the ability to detect residues of virtually everything in a glass of water now....that doesn’t mean that it matters to our health or has any impact on our lives.  

Regarding the comment about the determination of safe levels of pesticides being political...he is right...but only in the converse.  From the very beginning there was a hundred fold safety factor tied up in the use of pesticides.  First they added a tenfold safety factor regarding intra-species testing, the another ten X safety factor for inter-species bringing it up to a hundred fold safety factor and then the Food Quality Protection Act added another ten X, making it a thousand fold safety factor....and all of this is based on risk assumptions, in other words it was a political move and had nothing to do with science, and industry had nothing to do with that.  It was the people at EPA who are indistinguishable from the irrational misanthropic anti-pesticide EWG people.

Everything we are told should bear some resemblance to what we see going on in reality.  In reality those countries that have been the biggest pesticide users are the best fed people on the planet and live longer, healthier lives than ever in human history.</description>
		<content:encoded><![CDATA[<p>The Environmental Working Group is nothing more than a scare factory that only exists if it can generate scares long into the future.  The fact that pesticide residues are detectable is meaningless without determining the dose, and pesticide residues on food is so low that it means nothing to our health, other than the fact they these residues are the end result of wonderfully high production and low cost for life saving products&#8230;.food!</p>
<p>As Dr. Bruce Ames notes; you will receive more carcinogens in one cup of coffee than the entire pesticide residue on all the food you will eat in one year.  We almost have the ability to detect residues of virtually everything in a glass of water now&#8230;.that doesn’t mean that it matters to our health or has any impact on our lives.  </p>
<p>Regarding the comment about the determination of safe levels of pesticides being political&#8230;he is right&#8230;but only in the converse.  From the very beginning there was a hundred fold safety factor tied up in the use of pesticides.  First they added a tenfold safety factor regarding intra-species testing, the another ten X safety factor for inter-species bringing it up to a hundred fold safety factor and then the Food Quality Protection Act added another ten X, making it a thousand fold safety factor&#8230;.and all of this is based on risk assumptions, in other words it was a political move and had nothing to do with science, and industry had nothing to do with that.  It was the people at EPA who are indistinguishable from the irrational misanthropic anti-pesticide EWG people.</p>
<p>Everything we are told should bear some resemblance to what we see going on in reality.  In reality those countries that have been the biggest pesticide users are the best fed people on the planet and live longer, healthier lives than ever in human history.</p>
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		<title>By: Clem Weidenbenner</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-32943</link>
		<dc:creator>Clem Weidenbenner</dc:creator>
		<pubDate>Fri, 04 Feb 2011 14:38:12 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-32943</guid>
		<description>Anastasia:


&lt;blockquote&gt;If you buy produce from other countries, those regulations regarding worker exposure might be less strict or not exist. Still, buying organic might not make a difference anyway, as some recent studies have found foods labeled “organic” to have non-approved pesticide residues on them anyway (in short, farms are cheating).
&lt;/blockquote&gt;

  Could you point to one or two of these studies please?</description>
		<content:encoded><![CDATA[<p>Anastasia:</p>
<blockquote><p>If you buy produce from other countries, those regulations regarding worker exposure might be less strict or not exist. Still, buying organic might not make a difference anyway, as some recent studies have found foods labeled “organic” to have non-approved pesticide residues on them anyway (in short, farms are cheating).
</p></blockquote>
<p>  Could you point to one or two of these studies please?</p>
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		<title>By: Anastasia</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-32804</link>
		<dc:creator>Anastasia</dc:creator>
		<pubDate>Thu, 03 Feb 2011 22:56:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-32804</guid>
		<description>This comment was posted on Facebook, and I think the commenter brings up some good points relevant to this post, so here it is, along with my reponse.

----

Interesting article. I use to know some of the folks at EWG (when I working at cdph) and think that, in general, they do a pretty good job of taking complex scientific data and translating it for laypeople. This, I&#039;m sure you know, is not always easy to do. I have a few thoughts on what she wrote. I don&#039;t think it&#039;s a negative post, but there are some things I&#039;d like to say. First, one of the reasons I try to buy organic is that I feel like I&#039;m doing a better job of supporting ag workers, who often get sprayed along with the crops being dusted by the pesticide planes flying overhead. 

Second, when she talks about safe levels, she sort of implies that established safe levels are based purely on scientific data, which is not true. levels are ultimately decided by a combination of data and politics. Industry is heavily involved in the process. Also, as recently as 8 years ago (the last time I was really steeped in this stuff), the science that determines safe limits was based on what a safe allowable load would be for an average sized full grown man, which means that the level may not be safe for children, women, the immuno-compromised etc. This could have changed, I&#039;m willing to listen to someone who has more recent knowledge. Also, levels change as data accumulate - lead and mercury are perfect example. As is DDT. I think her suppositions on why certain data points are worthless are based on a premise that the &quot;safe&quot; levels out there are just that - safe. 

Finally, it&#039;s hard to look at pesticides and judge them as discrete chemicals. I think you do have to look at accumulation and interactions and right now, the way rules are written, companies don&#039;t have to look at that or prove that kind of safety when they present their data. 

I don&#039;t think EWG is saying that complex risk assessment models are a bad thing. And I certainly think people need to eat more fruits and vegetables even if they can&#039;t afford organic.

----

I agree that the conditions of workers is one important consideration when choosing what products to buy. However, I don&#039;t think that always means organic is better.

In the US at least, there are very strict regulations about pesticide use and where workers are allowed to be during and soon after pesticides are applies. EPA and OSHA both have regulations regarding worker exposure for both persons applying pesticides and those who work where pesticides may be used. Of course, not everyone follows the rules, but for the most part the regulations work. 

If you buy produce from other countries, those regulations regarding worker exposure might be less strict or not exist. Still, buying organic might not make a difference anyway, as some recent studies have found foods labeled &quot;organic&quot; to have non-approved pesticide residues on them anyway (in short, farms are cheating).

If we&#039;re really concerned about worker welfare we also have to consider non-pesticide related issues. For example, organic methods of weed control include hand weeding, which if you&#039;ve ever weeded you know is horrible backbreaking labor. Organic methods of insect control can include picking insects off plants manually (particularly in countries where labor is cheap, also, children are well suited for this task, unfortunately), and either pesticides or the genetically engineered trait Bt can control without that labor.

Regarding what the EPA bases tolerances on - from the EPA website: &quot;In August 1996, the Federal Food, Drug, and Cosmetic Act was amended to include the Food Quality Protection Act or FQPA. This Act required EPA to reassess by August 2006 all of the pesticide tolerances that were in place in early August 1996 to ensure that they met current safety standards and were supported by up-to-date scientific data.&quot; They also reevaluate whenever there is an objection filed or if a study comes out indicating a tolerance is set too high. 
http://www.epa.gov/pesticides/regulating/tolerances.htm The important thing to remember here is that the tolerance levels are actually set an order of magnitue or more higher than the actually dangerous level, to account for the difference between safe levels for healthy adults vs children, elders, etc.

Finally, as I said in the post, I think EWG is generally a force for good. But I don&#039;t know how they can justify putting out materials that scare people out of eating fruits and vegetables. EWG counts trace amounts of a pesticide known to be fairly benign as equal to a large amount of a pesticide known to be dangerous. That&#039;s just irresponsible. Regardless of how valid or not valid their methods are, EWG isn&#039;t being responsible in how they present their findings. Their little disclaimer that people should still eat produce is not enough. Take a look at this acticity for children from the California Academy of Sciences, for example http://www.calacademy.org/teachers/resources/lessons/pesticide-watch-card/. It instructs teachers to show children how dangerous their favorite fruits and vegetables are, based on the EWG information. How many of those impressionable kids avoid produce after that demonstration, possibly for life? What if their parents can&#039;t afford organic produce? It is possible to advocate for reduced pesticides without scaremongering - EWG needs to learn how to do that.</description>
		<content:encoded><![CDATA[<p>This comment was posted on Facebook, and I think the commenter brings up some good points relevant to this post, so here it is, along with my reponse.</p>
<p>&#8212;-</p>
<p>Interesting article. I use to know some of the folks at EWG (when I working at cdph) and think that, in general, they do a pretty good job of taking complex scientific data and translating it for laypeople. This, I&#8217;m sure you know, is not always easy to do. I have a few thoughts on what she wrote. I don&#8217;t think it&#8217;s a negative post, but there are some things I&#8217;d like to say. First, one of the reasons I try to buy organic is that I feel like I&#8217;m doing a better job of supporting ag workers, who often get sprayed along with the crops being dusted by the pesticide planes flying overhead. </p>
<p>Second, when she talks about safe levels, she sort of implies that established safe levels are based purely on scientific data, which is not true. levels are ultimately decided by a combination of data and politics. Industry is heavily involved in the process. Also, as recently as 8 years ago (the last time I was really steeped in this stuff), the science that determines safe limits was based on what a safe allowable load would be for an average sized full grown man, which means that the level may not be safe for children, women, the immuno-compromised etc. This could have changed, I&#8217;m willing to listen to someone who has more recent knowledge. Also, levels change as data accumulate &#8211; lead and mercury are perfect example. As is DDT. I think her suppositions on why certain data points are worthless are based on a premise that the &#8220;safe&#8221; levels out there are just that &#8211; safe. </p>
<p>Finally, it&#8217;s hard to look at pesticides and judge them as discrete chemicals. I think you do have to look at accumulation and interactions and right now, the way rules are written, companies don&#8217;t have to look at that or prove that kind of safety when they present their data. </p>
<p>I don&#8217;t think EWG is saying that complex risk assessment models are a bad thing. And I certainly think people need to eat more fruits and vegetables even if they can&#8217;t afford organic.</p>
<p>&#8212;-</p>
<p>I agree that the conditions of workers is one important consideration when choosing what products to buy. However, I don&#8217;t think that always means organic is better.</p>
<p>In the US at least, there are very strict regulations about pesticide use and where workers are allowed to be during and soon after pesticides are applies. EPA and OSHA both have regulations regarding worker exposure for both persons applying pesticides and those who work where pesticides may be used. Of course, not everyone follows the rules, but for the most part the regulations work. </p>
<p>If you buy produce from other countries, those regulations regarding worker exposure might be less strict or not exist. Still, buying organic might not make a difference anyway, as some recent studies have found foods labeled &#8220;organic&#8221; to have non-approved pesticide residues on them anyway (in short, farms are cheating).</p>
<p>If we&#8217;re really concerned about worker welfare we also have to consider non-pesticide related issues. For example, organic methods of weed control include hand weeding, which if you&#8217;ve ever weeded you know is horrible backbreaking labor. Organic methods of insect control can include picking insects off plants manually (particularly in countries where labor is cheap, also, children are well suited for this task, unfortunately), and either pesticides or the genetically engineered trait Bt can control without that labor.</p>
<p>Regarding what the EPA bases tolerances on &#8211; from the EPA website: &#8220;In August 1996, the Federal Food, Drug, and Cosmetic Act was amended to include the Food Quality Protection Act or FQPA. This Act required EPA to reassess by August 2006 all of the pesticide tolerances that were in place in early August 1996 to ensure that they met current safety standards and were supported by up-to-date scientific data.&#8221; They also reevaluate whenever there is an objection filed or if a study comes out indicating a tolerance is set too high.<br />
<a href="http://www.epa.gov/pesticides/regulating/tolerances.htm" rel="nofollow">http://www.epa.gov/pesticides/regulating/tolerances.htm</a> The important thing to remember here is that the tolerance levels are actually set an order of magnitue or more higher than the actually dangerous level, to account for the difference between safe levels for healthy adults vs children, elders, etc.</p>
<p>Finally, as I said in the post, I think EWG is generally a force for good. But I don&#8217;t know how they can justify putting out materials that scare people out of eating fruits and vegetables. EWG counts trace amounts of a pesticide known to be fairly benign as equal to a large amount of a pesticide known to be dangerous. That&#8217;s just irresponsible. Regardless of how valid or not valid their methods are, EWG isn&#8217;t being responsible in how they present their findings. Their little disclaimer that people should still eat produce is not enough. Take a look at this acticity for children from the California Academy of Sciences, for example <a href="http://www.calacademy.org/teachers/resources/lessons/pesticide-watch-card/" rel="nofollow">http://www.calacademy.org/teachers/resources/lessons/pesticide-watch-card/</a>. It instructs teachers to show children how dangerous their favorite fruits and vegetables are, based on the EWG information. How many of those impressionable kids avoid produce after that demonstration, possibly for life? What if their parents can&#8217;t afford organic produce? It is possible to advocate for reduced pesticides without scaremongering &#8211; EWG needs to learn how to do that.</p>
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		<title>By: Rich Kozlovich, Exterminator</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-6633</link>
		<dc:creator>Rich Kozlovich, Exterminator</dc:creator>
		<pubDate>Tue, 17 Aug 2010 11:00:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-6633</guid>
		<description>I have been reading your original post and the comments.  Although there is a great deal that can be said about the Environmental Working Group that shows who and what they actually are, I don&#039;t intend to do that here now....perhaps in another post.  However, what I really wish to address is the idea that any exposure at any level is dangerous if it has been shown to be dangerous at higher levels.  

This is now and has always been scientifically false, in spite of the Delaney Clause of FIFRA.  At some point the molecular load of any chemical will be so small that the cells won’t respond to it.  Furthermore, the amount of pesticides that are naturally occurring is far higher than anything we are exposed to in the food we eat.  The base premise of the EWG is based on the false premise that a detectable presence is a toxic presence. With the advancement of modern detection techniques it is unlikely that we aren’t going to be able to find everything in everything at some point.</description>
		<content:encoded><![CDATA[<p>I have been reading your original post and the comments.  Although there is a great deal that can be said about the Environmental Working Group that shows who and what they actually are, I don&#8217;t intend to do that here now&#8230;.perhaps in another post.  However, what I really wish to address is the idea that any exposure at any level is dangerous if it has been shown to be dangerous at higher levels.  </p>
<p>This is now and has always been scientifically false, in spite of the Delaney Clause of FIFRA.  At some point the molecular load of any chemical will be so small that the cells won’t respond to it.  Furthermore, the amount of pesticides that are naturally occurring is far higher than anything we are exposed to in the food we eat.  The base premise of the EWG is based on the false premise that a detectable presence is a toxic presence. With the advancement of modern detection techniques it is unlikely that we aren’t going to be able to find everything in everything at some point.</p>
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		<title>By: Eric Baumholder</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-6177</link>
		<dc:creator>Eric Baumholder</dc:creator>
		<pubDate>Thu, 05 Aug 2010 17:43:25 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-6177</guid>
		<description>The Environmental Working Group is part of the Tides Foundation&#039;s constellation of activist franchises, sometimes referred to as the &#039;Green Mafia&#039;. In lieu of describing the Foundation&#039;s byzantine accounting practices (with a nifty real estate scam on the side), I&#039;ll just point out that this latest &#039;report&#039; by the EWG is most likely bought and paid for with tax-deductible &#039;donations&#039; by the organic industry.</description>
		<content:encoded><![CDATA[<p>The Environmental Working Group is part of the Tides Foundation&#8217;s constellation of activist franchises, sometimes referred to as the &#8216;Green Mafia&#8217;. In lieu of describing the Foundation&#8217;s byzantine accounting practices (with a nifty real estate scam on the side), I&#8217;ll just point out that this latest &#8216;report&#8217; by the EWG is most likely bought and paid for with tax-deductible &#8216;donations&#8217; by the organic industry.</p>
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		<title>By: Anastasia Bodnar</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-6113</link>
		<dc:creator>Anastasia Bodnar</dc:creator>
		<pubDate>Mon, 02 Aug 2010 21:57:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-6113</guid>
		<description>Toxins are really complicated. One thing I wish more people would keep in mind is that there are some things we do in life that have &lt;b&gt;way&lt;/b&gt; more effect on our overall health, cancer risk, etc than trace exposure to household cleaning products, pesticides, etc. I don&#039;t mean to say that there shouldn&#039;t be rigid testing and all that good stuff but let&#039;s put things in perspective!</description>
		<content:encoded><![CDATA[<p>Toxins are really complicated. One thing I wish more people would keep in mind is that there are some things we do in life that have <b>way</b> more effect on our overall health, cancer risk, etc than trace exposure to household cleaning products, pesticides, etc. I don&#8217;t mean to say that there shouldn&#8217;t be rigid testing and all that good stuff but let&#8217;s put things in perspective!</p>
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		<title>By: c_rader</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-6112</link>
		<dc:creator>c_rader</dc:creator>
		<pubDate>Mon, 02 Aug 2010 21:38:34 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-6112</guid>
		<description>Guys, there are so many overly simple generalizations about toxins.

Each toxic substance acts on the body in its own way. The relation of dose to toxic effect is different for different toxins. 

There are actually some toxic substances that are beneficial in small doses but harmful in larger doses, such as the heart drug I take every day.  

There are other toxins that are harmful when ingested occasionally but for which a tolerance can develop after a long time. 

Some toxins are metabolized and others accumulate.

I don&#039;t know how you counter propaganda about pesticides when the propaganda is determined to selectively distort the issue.</description>
		<content:encoded><![CDATA[<p>Guys, there are so many overly simple generalizations about toxins.</p>
<p>Each toxic substance acts on the body in its own way. The relation of dose to toxic effect is different for different toxins. </p>
<p>There are actually some toxic substances that are beneficial in small doses but harmful in larger doses, such as the heart drug I take every day.  </p>
<p>There are other toxins that are harmful when ingested occasionally but for which a tolerance can develop after a long time. </p>
<p>Some toxins are metabolized and others accumulate.</p>
<p>I don&#8217;t know how you counter propaganda about pesticides when the propaganda is determined to selectively distort the issue.</p>
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		<title>By: Clem Weidenbenner</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-6103</link>
		<dc:creator>Clem Weidenbenner</dc:creator>
		<pubDate>Mon, 02 Aug 2010 18:53:53 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-6103</guid>
		<description>We do pollinate by hand (with a tweezers to be precise).  It is more tedious than corn pollination, but we do have the advantage of working with a self-pollinated crop so that we only need to cross pollinate to develope new segregating populations.  Down stream you&#039;re self pollinating your F1s and subsequent generations to control pollen source... and we get to let Mother Nature do that for us.</description>
		<content:encoded><![CDATA[<p>We do pollinate by hand (with a tweezers to be precise).  It is more tedious than corn pollination, but we do have the advantage of working with a self-pollinated crop so that we only need to cross pollinate to develope new segregating populations.  Down stream you&#8217;re self pollinating your F1s and subsequent generations to control pollen source&#8230; and we get to let Mother Nature do that for us.</p>
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		<title>By: Steve Savage</title>
		<link>http://www.biofortified.org/2010/07/details-on-the-dirty-dozen/#comment-6098</link>
		<dc:creator>Steve Savage</dc:creator>
		<pubDate>Mon, 02 Aug 2010 15:06:11 +0000</pubDate>
		<guid isPermaLink="false">http://www.biofortified.org/?p=3596#comment-6098</guid>
		<description>Ewan,
thanks for the clarification.  You are exactly right, we are actually well designed to eat low levels of toxins because our intestinal lining cells only live for three days before being replaced. That means we can deal just fine with exposure to the natural toxins.  The pesticide residues are present at far lower levels so there is really no reason to worry about them at all</description>
		<content:encoded><![CDATA[<p>Ewan,<br />
thanks for the clarification.  You are exactly right, we are actually well designed to eat low levels of toxins because our intestinal lining cells only live for three days before being replaced. That means we can deal just fine with exposure to the natural toxins.  The pesticide residues are present at far lower levels so there is really no reason to worry about them at all</p>
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