This page is one that documents the extent to which EPA blows smoke – to put it mildly – about how much it “really believes that scientific integrity underpins all of its work to protect public health and the environment”… when it comes to pesticides. Be prepared to be disgusted.

Malathion is an organophosphate (OP) pesticide, one of a class that also includes chlorpyrifos, parathion, dichlorvos, among others, all of which inhibit acetylcholinesterase (AChE), an enzyme vital for normal neuromuscular function in humans as well as insects. Acetylcholine is a compound produced in neural tissue, including the brain, and is an agent that transmits signals between adjoining nerve cells. Once a signal is transmitted it is necessary for acetylcholine to be destroyed by AChE  to prevent undesirable repeated “firing” of the signal. Other OPs are chemical warfare “nerve gases” or “nerve agents” such as Sarin, Tabun and VX, all of which function as potent AChE inhibitors.

Regarding organophosphates as a class, in 2006 11 EPA unions signed on to a letter to Administrator Johnson expressing concern that EPA may violate the Food Quality Protection Act by not applying its own Principles of Scientific Integrity to information on organophosphate pesticides. In particular the unions pointed out the need to address the information on developmental neurotoxicity, as required by the FQPA, and they noted EPA’s apparent lack of interest or rigor in dealing with OP exposures via food stuffs. The unions expressed concern that EPA was too accommodating to agricultural interests and too lax about using the tools and addressing the mandates of the FQPA.)

Dr. Brian Dementi  During his tenure at EPA Dr. Dementi was a Ph.D. toxicologist and Diplomate of the American Board of Toxicology, recognized within EPA and among state environmental authorities as the national expert on malathion toxicology. His testimony on malathion toxicology and risks associated with mass spraying of populated areas was sought by the State of California. He was brought by that state’s legislature to advise it about use of malathion use in eradication of the medfly  in that state.

His advice was sought by Congress as it addressed the Gulf War Syndrome illnesses of many veterans of that conflict who may have been exposed to Sarin or other nerve agents. Dr. Dementi was tasked by EPA with the scientific work to develop a national policy on AChE inhibitors. The controversy that developed following Dr. Dementi’s completion of that work is covered in excerpts from Inside the Fishbowl that are linked to this page,here.Malathion Dementi

NTEU Chapter 280 represented Dr. Brian A. Dementi for many years in his disagreements with Office of Pesticide Programs over risks associated with malathion. During that time the union and Dr. Dementi were able to win some concessions from management, particularly over making his views on those risks available to Congress, various state authorities and the public.

kDr. Dementi’s dedication to scientific integrity bought him into conflict with EPA policy decisions that he felt were based on what might generously be termed faulty science. Here is his detailed critique of EPA’s final risk assessment for malathion. There is a great deal of documentation – far beyond what can reasonably be posted on this website – that deals with these conflicts. These two links document the grievance – the first filed over violations of EPA’s “policy” on scientific integrity as characterized in the Agency’s high-sounding Principles of Scientific Integrity. PSI1.p1  PSI1.p2 Here is management’s response to these grievances – and to all others subsequently filed – that cited violations of  scientific integrity. Step III grievance  The union demanded a high-level hearing, by Assistant Administrators, of the facts presented. The union filed a post hearing brief, which includes details of how EPA’s responses to Dr. Dementi’s adherence to scientific integrity affected his career.
PSI Grievance Post hearing brief

Dr. Dementi’s Dissenting Opinion letter details  his analysis of the shortcomings of EPA’s cancer risk assessment. Union scientists endorsed the Opinion. Management replied.

What follows are several pages constituting comments by Dr. Herbert Needleman (whose recent passing resulted in this headline in Environmental Health News on July 21, 2017, “Refections on the death of a hero, Dr. Herbert Needleman.”), which also strongly endorse Dr. Dementi’s dissent on the cancer classification EPA gave malathion.These comments dealt with a report of a Pathology Working Group that downgraded tumors in a cancer bioassay of malathion that resulted in changing EPA’s cancer assessment from “Likely” to be carcinogenic, to “Suggestive Evidence” of carcinogenicity. Dr. Dementi challenged this change, and Dr. Needleman’s comments strongly supported Dr. Dementi’s view. The change had significant implications, because a “Likely” finding would trigger a full cancer-based risk assessment and result in more stringent regulation of malathion exposures, while the “Suggestive” finding did not require such an assessment/regulatory response from EPA. Needleman p.1  Needleman p.2   Needleman p.3 Needleman p.4