Natural Resources Defense Council, Inc. 25 KEARNY STREET SAN FRANCISCO, CALIFORNIA 94108 415 421-6561 BOARD OF TRUSTEES Adrian W. DeWind Chairman Stephen P. Duggan Chairman Emeritus James Marshall Vice Chairman Michael McIntosh Vice Chairman Dr. George M. Woodwell Vice Chairman Dr. Dean E. Abrahamson Richard 1. Beattie Boris I. Bittker Robert O. Blake William T. Coleman, Jr. Robert W. Gilmore Dr. Joshua Lederberg Dr. Gifford B. Pinchot Robert Redford John R. Robinson Laurance Rockefeller Leonard R. Sargent Joan C. Schwartz John Sheehan David Sive Thomas B. Stoel Thomas A. Troyer Beatrice Abbott Duggan John H. Adams Executive Director COMMENTS of the NATURAL RESOURCES DEFENSE COUNCIL on the ENVIRONMENTAL PROTECTION AGENCY'S SUMMARY OF THE IBT REVIEW PROGRAM 11 July 1983 Lawrie Mott, M.S. Simon Frankel 100% Recycled Paper New York Office 122 EAST 42ND STREET NEW YORK, N. Y. 10168 212 949-0049 Washington Office 1725 STREET, N.W. SUITE 600 WASHINGTON, D.C. 20006 202 223-8210 New England Office: 17 ERIE DRIVE NATICK, MA. 01760 • 617 655-2656 Public Lands Institute: 1720 RACE STREFT DENVER, CO. 80206 303 377-9740 I. INTRODUCTION On 11 July 1983, the Environmental Protection Agency's Office of Pesticide Programs issued its "Summary of the IBT Review Program" (Hereinafter cited as "Summary"). This report was intended to summarize the findings of the joint program conducted by the Environmental Protection Agency (EPA) and the Health Protection Branch of Health and Welfare Canada to reexamine the validity of health effects studies on pesticides tested by Industrial Bio-Test Laboratories, Inc. (IBT). During 1976, a series of audits by the Food and Drug Administration (FDA) and EPA revealed that many of the tests conducted by IBT on numerous pesticides and some drugs used in the United States were supported by data which was inaccurate, fabricated, fraudulent, or even non-existent. EPA's IBT Review Program was designed to assess the gaps created in the data base of chemicals registered with IBT studies because of the invalidity of these tests. The Program was also intended to resolve the problems created by the IBT situation and to prevent its recurrence. However, the reality of this Program falls far short of these goals. The Agency has been aware of the IBT problem for six years; yet the safety of the majority of IBT-tested pesticides still remains in question. In particular, there are serious problems with EPA's July 11th Summary, resulting in false conclusions that public health and the environment are adequtely protected from the hazards of IBT-tested pesticides. The opening pages of the July 1983 report argue that any possible safety problems created by false IBT data are minimal, 28-401 O - 84 13 |