The Regular “Regulation” of Agricultural Poisons At the US EPA

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Always start with the consciousness: For the corporate state system and its religious believers, the project of poison-based agriculture must go forward. Nothing may ever be allowed seriously to hinder this. This Poisoner campaign is at the core of all corporate profit, corporate/government power, and techno-cultism.

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Although under legal pressure EPA temporarily withdrew approval of Dow’s Enlist Duo herbicide formulation, we mustn’t expect this to be more than a temporary delay. Dow expects to ship the poison for the 2016 season. A more typical indicator of EPA’s relationship with Dow and Enlist was its active collusion with Dow in falsifying data in order to suppress Dow’s own trial results finding health dangers from Enlist. EPA “scientists” changed the agency’s rules for data analysis midstream in order to invalidate Dow’s own data showing that 2,4-D (one of the two main poisons contained in Enlist Duo, the other being glyphosate) causes kidney damage in rats. As the Environmental Working Group pointed out, EPA ”contradicted standard scientific practice” in order to set an alleged “no observed adverse effect level” (NOAEL) dose at a level which the company’s own tests showed to cause toxic effects in rats, including kidney lesions, thyroid damage, and reproductive organ changes. This puts the NOAEL concept in an even blacker light. The concept is already bogus in principle in the case of endocrine disruptors, including almost all pesticides. And now we see how, even where toxic effects are found at an inconveniently low dosage, EPA and other regulators will simply change the rules in the middle of the game. This puts in perspective the sanctimonious claims of regulators that in order to be considered in regulatory assessments, scientific work must adhere punctiliously to certain officially designated rules (which never have anything to do with scientific quality but do always favor big corporate labs). As we see, for the regulators such adherence is only for real scientists, never for the corporations or for themselves. For themselves and their corporate clients the only rule is Do What Thou Wilt.

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The EPA did this in order to give itself a pretext to approve the product. The regulator’s job is always to approve the product and claim it to be safe, no matter what. Therefore EPA destroyed the scientific evidence and then lied about it. This is nothing new, but is part of the standard EPA pattern of conduct going back to the 1970s.

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Here we have a case study in how the corporate science paradigm and the regulator template work together.

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I’ve described and applied the template many times, to regulators, pseudo-scientists (the post just linked), system NGOs, etc. Here’s a quick description again.

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1. The corporate prerogative and corporate tasks, profiteering and any other imperatives, are normative. The regulator must always seek to assist the corporations and boost their power.

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2. Given the framework of (1), the regulator may sometimes seek to ameliorate the worst abuses, perhaps even hinder or ban isolated, ad hoc products. Or, more commonly these days, the regulator only pretends to do this. Often, as in the case of EPA and EFSA with glyphosate, or the USDA with GMO approvals, it doesn’t even pretend. Either way, nothing the regulator does must hinder the overall corporate imperative or any significant corporate project. Therefore the pesticide and GMO genres, as well as particular blockbuster products like Roundup, must go forward no matter what.

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3. Whatever the regulator did or didn’t do, it now bestows its imprimatur of “safety” and any other necessary endorsement upon the product. It engages in taxpayer-funded PR and educational campaigns on behalf of the corporate product. Most of all, it tells the people, implicitly and where necessary explicitly, that they shouldn’t have any concerns, shouldn’t even think about the product, and most of all shouldn’t bother with educating themselves, let alone questioning the official imprimatur. As is typical of bureaucratic ideology, the regulator mindset is anti-democratic in the extreme. This is part of why regulators are so comfortable with fraudulent “secret science” and want to keep as much information from the public as possible. This is on ideological principle, as well as having more mundane corruption origins.

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So it goes: Pro-corporate ideological commitment; farcical and fraudulent “regulating”; propaganda and secrecy.

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In today’s example:

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1. EPA has always been activist toward the corporate task of maximizing poison use. It has always been willing to do whatever’s necessary toward this goal. In the late 1970s a massive scandal in lab testing broke involving IBT Laboratories, a favorite industry contractor. FDA investigators called it “the most massive scientific fraud ever committed in the United States, and perhaps the world”. Years later several executives would be convicted on criminal charges. (This is one of the purposes of corporate outsourcing to smaller contractors. But it’s the oligopolists who dictate the practices, and require the crimes.) Nazi experimenters would’ve been ashamed to work at this place, and the denizens of “Animal House” would’ve fled in horror.

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* New animals routinely substituted – often en masse – for test animals that died, without noting deaths or substitutions in lab reports
* Entire test data and lab reports for one test product copied into reports for other products
* “Magic pencil” studies substituted false data for tests never done or results implicating test products’ adverse or fatal effects
* Signatures of lab techs who had refused to sign false reports were forged by managers on the false reports
* Rats listed as dead and autopsied in one section of a report reappeared alive and breeding in another section of the same report (“Now IBT did some strange and unusual things,” Dr. Adrian Gross, who first revealed the IBT scandal, remarked, “but bringing back the dead wasn’t one of them.”)
* Substitution of unexposed control animals for test animals that died
* Substitution of dogs for rats when all the rats in one test died, then reporting them to be rats
* Wholesale concealment and falsification of cancers, testicular atrophy, death and other effects in test animals
* A laboratory that IBT scientists called “The Swamp”, with a faulty water system that drenched the entire room, cages, rodents and all, in a continuous spray of water, drowning the test animals in droves. “Dead rats and mice, technicians later told federal investigators, decomposed so rapidly in the Swamp that their bodies oozed through wire cage bottoms and lay in purple puddles on the dropping trays.”
* Massive, frequent die-offs of test animals due to staff failing to feed and water them over holidays, rodents dying from unhygienic conditions, rats dying from rat poison fed them by mistake, rodents escaping, rats and mice being shifted from one cage to another, contaminating and eating each other; frequent “search and destroy” hunts for escaped rodents, with scientists and lab techs dashing about squirting chloroform to “slow down” the escapees, often killing the test animals as well
* After Gross’s first visit to IBT in 1976 and before he could return with auditors, the company equipped its offices with paper shredders and “strip filed” huge volumes of raw data, studies and client lists, including all of its studies on 2,4-D, six other herbicides (never identified), artificial sweeteners, cyclamates and plastics components

Almost all of the products tested by IBT, including 2,4-D, glyphosate, atrazine and many of the 66 products banned on California red-legged frog habitat, are still on the market today.

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EPA worked aggressively to cover up the fraud and consulted with the corporations about how EPA would run interference with Congress and the media. As top official Fred Arnold put it to an industry convention, EPA had their backs: “The concept was to try and proceed in an orderly fashion and fill data gaps and not interfere with the ability to market pesticides.” He was referring to how EPA was going to lobby Congress to change the law to allow “conditional registration” of all the poisons which EPA had approved based on the IBT testing. (And testing at other labs; 47 of 82 audits found similar conditions at other labs contracted by the poison manufacturers.) The law required the cancellation of such fraudulent approvals. But in tandem with the poison corporations, EPA convinced Congress to allow it to extend “conditional” grace periods until industry could submit new tests.

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In other words, the proven systematic, premeditated fraudsters were going to be allowed to organize another systematic fraud. That’s always what the Fox Guarding the Henhouse means. Anyone, especially government regulators, who says that proven liars and organized criminals should be allowed to police themselves is really willfully collaborating in those massive crimes.

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Sure enough, the industry never submitted legitimate tests, and EPA never asked again for them. The shared goal of EPA and the corporations, maximizing the production, sales, and use of poisons, continued without flagging. The scandal was just a political speed bump. Just as the current embarrassment over Dow’s poison is intended to be a minor hiccup. Meanwhile, to this day EPA refuses to divulge which poisons were approved based on the fraudulent “studies” at INT and elsewhere. As per our usual rational method for dealing with those who maliciously invoke secrecy, we must assume that ALL EPA pesticide registrations during the years in question were allowed on the basis of those fraudulent studies.

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EPA’s services to Dow regarding Enlist are similar to the services it has performed for Monsanto on behalf of glyphosate (I’ll begin the discussion in this post) and PCBs (a subject for future posts).

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2. The main vehicle of EPA’s pretending to be looking out for the public and environmental good is its review processes for pesticides and other chemicals. These are always completely bogus. The Dow Enlist example is just an unusually egregious one.

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Of course sometimes the regulator will feel enough political pressure to go through the motions of doing something. An example is the recent expedient, mentioned above, of temporarily suspending Enlist registration. We also have the example from earlier in 2015 of sham limitations on glyphosate use. Ostensibly intended to slow the evolution of glyphosate-resistant superweeds, this is really meant to shift more of the political onus and legal risk onto farmers. Same for the whole “refuge” concept, allegedly for slowing the evolution of insect resistance to Bt toxins. EPA never required a meaningful acreage portion for the refuge (entomologists reached a consensus that 50% was the minimum necessary to have any hope of the policy having any effect; EPA never required more than 20%) and never rigorously enforced the policy. With the advent of multiple-toxin stacked products, EPA adopted corporate demands to lower the “required” acreage to 5%. The fact is that the “refuge” idea was never meant to be more than that – an idea, a propaganda theme, for media and pro-GM activist use. Bt refuge idea is one of the best examples of sham pro-corporate “regulation”.

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The EPA’s history with glyphosate cancer assessments gives another example of the regulator pretending to be looking out for the people. Since this has been above all a propaganda effort, especially during the GMO era, I’ll discuss it below.

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3. The final step of the whitewashing template is for the regulator to affirm that the product is safe and encourage the people to go back to sleep and let their government betters do any continued monitoring necessary. (None is ever done.) EPA has already proclaimed the alleged safety of Enlist, and is now waiting for Dow to give it enough of a pretext, even the most flimsy will suffice, to reaffirm this proclamation. For a prior case study, we can compare how EPA knew since at least the early 1980s that glyphosate causes cancer. The evidence was so conclusive that, in spite of EPA’s wishing to give Monsanto the green light and doing all it could to interpret Monsanto’s own test results in the best possible light, it felt compelled to give the poison Classification C – “Suggestive evidence of carcinogenic potential”.

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In terms of market share glyphosate wasn’t yet projected to become a major pesticide at this point, though Monsanto was already contemplating the idea of GMOs engineered to be tolerant of it. They worked on this idea (well, failed at it until they found some bacteria which had already done the main work for them) and by the early 1990s were preparing to bring Roundup Ready crops to market. It was time to whitewash glyphosate’s cancer record more thoroughly. EPA happily complied. With zero new evidence, not even a new round of phony tests, without further ado EPA in 1991 changed the classification to Group E, “Not likely to be carcinogenic to humans.” An even stronger, more politicized and fraudulent construction elsewhere in the regulation phrases this, “Evidence of non-carcinogenicity to humans.”

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This “evidence”, of course, is nothing but a political way of phrasing the real ideological position, that cancer cannot be allowed to stand in the way of the Poisoner imperative. Since, as EPA has known at least since the early 1980s, glyphosate does cause cancer in humans, EPA’s job becomes to deny this, cover it up, lie about it. Perform enough direct denial, and propagate the implicit mindset that giving farmers and consumers cancer is meaningless anyway compared to the great tasks of corporate rule and the Poisoner imperative, and in an ideological sense it does become “true” that “glyphosate does not pose a cancer risk to humans”, as EPA proclaimed again most recently in 2013. If cancer is irrelevant, it may as well not exist. This is the reality of the psychopathic mindset involved here. And this is the psychology and set of priorities which has cohered in the era of corporate rule as the corporate science paradigm. The decisions made about which lines of inquiry to pursue in the first place, the workings of day-to-day science practice, the mindset and party line of the scientific establishment, the STEM fraternity in general, the corporate media, and the cultist fanboys, all follow from the dictates of this dominant paradigm of prostituted pseudo-science. A regulator like the EPA plays a very important role in orchestrating this fraudulent science and disseminating the propaganda of it, a double nimbus of “Science” and “Good Government”. Both are Big Lies.

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