of .'< |> c-1- v over a lifoLirae.	That is exposure to
. j - i	yi-.ir ovt.-c 1 i fc{ i.	That i s exposure to .5 rem per year
r i i.f"i. lii.e shou 1 :! cause. a number of cancer cases equal to the
:,pnni ."rn-uins rate. 0->j r.;an e^t:i:.iates that thi.y figure translates into
j 00,000 or i/.ore addif Lonal cancer cases per year. The calculation by
Abrnh.-j indicated that the effect of ingestion of nitrites is equivalent
to alio;.;: this Amount ctf rndiati'on. Of course, both these calculations are
specv'-itive, Lut they indicate the possible magnitude of the effect.
Before-: concluding this section we should indicate briefly which of
Jie pu--iibly cuta^c-nic pesticides are important to our study. Barathion
(nnd erir.eiitiaJ.ly the range of oryanophosphates) is used heavily in all
Mrops under study. Carbaryl is used in significant amounts on oranges and
.onatoc^, and is u.so.d to a snail extent on lettuce. Phospharnidon is used
.rKj:inc;lv on oranges, tomatoes arid lettuce. DDT and endrin are currently
banned frov' normal use.
After this survey we are still unable to make any accurate estimate of
the tint ;rni. Lucie of the effect on health resulting from the ingestion of residues
ctf avCn.;ctiic pesticides. Most pesticides have not been tested adequately
to determine their mutagenicity. However, there is definite evidence that
some important and frequently used pesticides are mutagens. The tools are
available to determine if chemicals are mutagens, and the costs of the
approprj iLo tests are relatively low. Moreover, this type of toxicological
tenting advanced further in a quantitative way than in any related area.
Hence it should be possible, if a concerted effort is made, both to determine
vli Lch p'^t icSdcy are mutagens, and to estimate the magnitude of the effect.

: I  . i : ' ' r i" I   i ' :; -sr.* ;iu ii.'pnr t auE	i>f i .1 I ue.ii.s,
i t ti *3  r;- i r:on *  in iwf : i :-i art rate: v.'iil .add lo the- burden. It. is
v u ri-nt i " v. co:.:.'.-sr;. tL r.rould try to prevent clinically induced
inn tviLi sTi: ?'  -ro	-i ; .10/ of the spontaneous; rate. However, the calcula-
tion i -:.r , ' : : it:', i ,! ic.iLtii. th.il: thiu standard nay already be exceeded for
n i.tri t'e; '  m. A1 though the intake of pesticides from residues is con-
siderably Her t am the average nitrite intake, this calculation should
ir.nke us	of adding any burden of mutagenic chemicals to our diet. Dr.
7 9
Samuel Kp >' f:J.n	a leading authority in this field, indicated in an
interview, that he thinks the mutagenic effects of pesticides are a definite
ar ea of c.o.u'OTn for t.hosi? who are occupationally- exposed. He said that it
is problematical whothen: the dietary residues of pesticides are a significant
hazard in thi;; regard, aud hoped that the EPA would get geared up to perform
trio appropriate testr;.
As fa.? chip study is concerned we only conclude that since there is
reasonable evidence thr:t a hazard may exist in this regard, any burden of
pesticider- result in & froji a use that has not been well justified, should
be elimin:^ :. Spec i !: Jcally the use of pesticides for cosmetic purposes
do^s not balsr.ca the possible harmful effects, and should be discontinued.

While pesticides are designed with the intent of producing a positive
impact on the yield and the economic value of crops, their use may also
result in a negative impact on the stability of the agro-ecosystero,
especially in the long-run. As C. B. Huffaker has written:
The adverse effects of general pesticide usage on the environ-
ment as a whole have been widely and intensely proclaimed. So
have the advantages in pesticide use for producing the food man
needs and in alleviating human disease. I wish here to emphasize,
however, that in the midst of confronting the very real adverse
effects of past pesticide usage, especially on our birds, and on
our fish and lower forms of life in inland waters and estuaries,
general ecologists and the public have been almost unconcerned
about the adverse effects on beneficial insects. This is especially
regrettable because the adverse effects on the insect enemies of
these pests have led more than anything else to the perpetuation
and intensification of the chemical applications that cause these
Huffaker goes on to document several cases in which pesticide treatment for
one pest has resulted in the elevation, to pest status, of sometimes more
damaging and more intractable pests. In a current review of the status of
the chemical strategy of pest control, Luck, Garcia and van den Bosch have
documented a large number of cases in which phenomena of "secondary pest
resurgence" has occurred.

It is strangely ironic that in the attempt to suppress insect pest
populations to the extremely low level required by cosmetic quality standards
and insect parts standards, the agro-ecosystem way be altered so that the
resurgence of a more serious non-cosmetic pest is favored. One such case,
discussed in detail on page below, involves the citrus thrips and the
citrus red mite.
Another beneficial insect which may be adversely affected by the use of
pesticides is the honey b*ie. This animal is an integral part of the agro-
ecosystem, for its pollination activities are essential to the production of
many important crops.
Most of the information concerning effects on bee populations comes from
an interview with Ward Stecger. ^ St eager is an adviser to beekeepers
and growers dependent on bees from the University of California Agricultural
Extension. Stenger reports that over the past 12 years an average of
60,000 colonies of bees per- year have been killed as the result of the use
of pesticides. This is abcot one sixth of the pasteurized bee population.
Most of the bee colonies are rented to growers for pollination of their
crops. In the past two years, according to Stenger, the bee loss to
pesticides has been cut to aiout 36,000 colonies per year.
The main use of bees is for pollination of certain crops, alfalfa,
and almonds being especially- dependent on bee pollination. Although
beekeepers are supposed to receive 48 hours notice before a field in which
their bees are living is sprnsyed with pesticides, this regulation is of
little practical value. Ba=akeepers are unable to move their bees in this
amount of time. Moreover, tmls is generally no place to which the bees can
be movea wnere proper nutrition for them is available. Hence moving the

"bees would probably serve only to change the cause of death from direct
pesticide poisoning to starvation. A sugar serum is available, but this
is too expensive to be of practical use at the present time.
At the moment the most serious economic threat from pesticide
poisoning of bees is in the almond industry. Almonds require pollination*
and honey bees are the only possible agents available to perform the pollina-
tion function. However, the spraying of the almond fields goes on while
bees are in them, so there is destruction of bee colonies. According to
Stenger it is not possible to bring the bees into the field only after
spraying, because there is no place to pasteurize the bees in the meantime.
Moreover, the presence of the bees is required for continuous pollination.
The melon and the cantalope industries are also in jeopardy for
similar reasoqs. The bees which pollinate these crops are threatened by
pesticides sprayed on nearby cotton fields, not on these crops directly.
Another possible problem involves plums which require pollination by bees.
The bees are affected by pesticide drift from the spraying of nearby crops.
Stenger feels that if proper cooperation and communication between
bee keepers, growers, and agricultural commissioners were maintained,
about 75% of the problem could be eliminated. However, there would still
be some loss of bees due to the inherent unecological technology. In other
words the technology required for the production of certain crops requires
pollination by bees as well as spraying with certain pesticides. But the
pesticides kill a fair percentage of the bees necessary for pollination.
The crops in which bee pollination is of prime importance (alfalfa
seed, almonds, avocados, cherries, melons and plums) are not crops included
in this immediate study. However, this does not eliminate the possibility

that unnecessary use of pesticides due to cosmetic quality and insect parts
standards may take place in crops in which bees are present.
Another point to note is that beekeepers are indemnified by the U. S.
government for part of their losses to pesticides. This amounts to a sub-
sidy by taxpayers to those involved in the pesticide technology. In other
words part of the actual cost of using the pesticides is removed from those
who use them, and shifted to taxpayers. If users of pesticides had to pay
their entire cost it is possible that their use would not be found as
favorable compared to other methods of pest control technology.
In a broader sense the information on bees indicates the possible
effects on the environment of indiscriminate use of pesticides.

the impact of pesticide use on wildlife
An excellent review of the effects of pesticides on wildlife is
found in "Interactions Between Pesticides and Wildlife" by Oliver Cope.
The review includes the results of both field and laboratory studies on the
effects of pesticides on wildlife. The survey indicates many effects on
animals similar to those of people. It points out acute effects resulting
from exposure to high concentrations (generally death), as well as chronic
effects such as interference with reproduction, harm to learning mechanisms,
and the production of tumors. The topics discussed in the review go far
beyond the range of this study, and the interested reader is referred to
it for additional information.
What is worth brief mention in this study are the subtle effects of
pesticides which may be felt through the environment. For example pesticide
resistant strains have developed among some species. Among mosquito fish
resistant strains can withstand concentrations of endrin 1000 times that of
normal strains. Although this resistance is helpful to the exposed species.,
the Increased ability to store toxic substances can result in increased
deaths to animals higher in the food chain. Another obvious indirect effect
is the destruction of predator populations when the prey has died out as
a result of pesticide poisoning. More subtle effects on complicated food
vebs may take place if a stratum of food succession is lost. Behavioral
changes may make some organisms unusually vulnerable to predation or other
natural hazards. Another well known effect is the inhibition of photosyn-
thesis in marine phytoplankton by organochlorine pesticides. Because of
the fundamental importance of photosynthesis to marine ecosystems, potential

damage to fish is suspected as a result. The author concludes, "Just as
chronic toxicity may be more damaging to a population than is acute
toxicity, indirect effects on wild animals can often have more serious
consequences than sublethal influences."
A special threat from pesticides exists for birds at the top of the food
chain, herons and owls for example. Chlorinated hydrocarbons are highly
lipid solubles and concentrated to a high degree toward the top of the food
chain. For example, in a study of DDT concentration in the Carmans River
Estuary, Long Island, New York, the DDT (and breakdown products) concentra-
tion increased from .083 ppm in shrimp to 1.07 ppm in the black duck to
75.5 ppm in. the ring billed gull. The latter figure is more than a million
times the concentration in the water in the estuary.
Such accumulations of organochlorine pesticides is known to have killed
off populations of certain wildlife species. Broad correlations exist
between residue concentrations of organochlorine insecticides and mortality.
For example, fish of several species have been killed by DDT concentrations
of 1 to 26 ppm, commonly averaging 4 to 7 ppm. In the case of birds those
that have succumbed to DDT poisoning have had residues between 30 and 295
ppm, with the q average for several species being 112 ppm. 84
In addition to the acute effects of pesticide poisoning chronic effects
may take their toll on populations, and these effects may be more significant
in the long run. Laboratory studies have indicated that sublethal concen-
trations of DDT have reduced the reproductive success of pheasants and
mice.	Population studies have indicated that DDT has caused
reduced reproduction in field populations of trout, osprev. woodcock, eagles,
falcons and other species.	In some cases serious population declines

have resulted for certain species. A detailed discussion of acute and
chronic effects of pesticide poisonings on the populations of various
species of wildlife, is far beyond the scope of this study. We refer the
reader to the survey in reference 4 for further details.
Significantly, pesticides used in the amounts and manner that was
common, caused substantial damage to wildlife, and reduced the populations
of some species. We obviously are not able to establish dose-response
relationships for these effects, although it is likely that the greatest
threat results from the persistent pesticides which accumulate in the
One mightj of course, object that a decline in the population of pere-
grines is of no consequemce to people, and is no threat to our survival or
quality of life. In isolation such an argument may have merit, although
many people derive pleasure from observing or hunting these animals. What
is, of course, worrisome is the possibility that such wildlife population
declines could have additional effects on the ecosystem. For example, the
decline in some predator populations could increase the population of some
pests. Moreover, more serious effects on the ecosystem are at least possible.
Finally, the eixistence of these effects on wildlife may be indicative of the
general hazard resulting from loading an ecosystem with pesticides. They
indicate that pesticides should not be used with impunity unless there is
good justification for their use, and that the ecosystem should be monitored
for possible adverse effects.

Dr. J. Azevedo 	of the California Department of Fish and Came
has supplied some information concerning the magnitude of the effect of
pesticides on wildlife in California. He pointed out that it is neither
practical nor possible to take a systematic census of the species of wild-
life affected by pesticides. Hence the totality of the effects on wildlife
are not readily known. Rather, assessment of the effects must come from
some of the most obvious occurrences, e.g. mass killing of certain species.
Azevedo pointed out that quail and pheasants have been hurt because of
the general use of pesticides in citrus, and upland game populations have
been cut by the use of pesticides in many crops. He said that in the case
of citrus, when the pesticides were used properly the loss in bird popula-
tion has not been large. Rather the large losses have occurred when the
pesticides have been improperly used. For alfalfa and cotton, however, the
normal use of pesticides may result in the significant killing of wildlife
populations. This is because the pesticides get into the food eaten by
the wildlife.
One particular problem has resulted from the heavy use of azodrin.
Azodrin is an organophosphate pesticide which has been used to a great
degree in cotton and to a much lesser extent on other crops such as citrus
and ornamentals. It brushes off leaves and collects in pools of water.
As the water evaporates, the concentration of azodrin increases to as much
as 20 ppm. Animals drinking in pools of water with high azodrin concentra-
tions may be killed in large numbers. Azodrin has also killed birds
directly as a result of their being sprayed in the course of its application.

Because several significant incidents of wildlife kill resulted from
applications of azodrin (the incidents were noted in 1965, 1966, 1967), we
will elaborate on the situation with azodrin briefly. During these years
several incidents were reported in which dead or injured birds were found.
They were found in the vicinity of cotton fields which had been sprayed with
a2odrin, and examination of brain tissue indicated severely reduced
cholinesterase activity. This is an indication of exposure to a cholinesterase
inhibitor such as azodrin.
In 1967 19 instances of wildlife losses were verified with the losses
being attributed to azodrin exposure. Among the effected species were
pheasants, doves, quail, jackrabbits, horned larks, meadow larks, .blackbirds,
killdeer, and sparrows. The number of affected birds discovered varied from
1 to 29 per incident. The Fish and Game report emphasizes that these
numbers do not reflect the actual extent of wildlife losses, but only
indicate the number of carcasses (or sick birds) found near the ends of
treated fields.
The numerous losses of birds indicates that the use of azodrin as
practiced at that time constituted a serious hazard to wildlife. One of
the most interesting findings was not the number of dead birds, but the lack
of living birds in the areas neas treatment, indicating a possibly greater
effect than that demonstrated just by the number of dead birds.
Azodrin has a relatively low dermal toxicity, but is orally more toxic
than such highly toxic substances as parathion. This, fact has led to the
conjecture that the main way in which azodrin causes death among wildlife
is by accumulating on food or in the water supply.

One significant point made in the Fish and Game report is that azodrin
had been used on a scheduling program known as multiple treatment. Under
this concept frequent applications of the pesticide were made (as many
as 23 at 5 to 7 day intervals) without regard to the actual need for the
insecticide in terms of controlling insects. The hazards to wildlife
documented above indicate serious problems involved when such an indis-
criminate program of spraying is adopted.
'The use of azodrin in cotton fields has now been restricted to certain
time periods when the pheasant population in the field is low. As a result
the number of birds killed by azodrin has beei significantly reduced.
Another pesticide that has caused a problem for fowl is furidan, a
carbamate. Furidan is especially toxic to water fowl, and in one incident
knocked out a large percentage of the population of one species. The exact
percentage of the population decline is, of course, difficult to assess
because no census is taken. As a result of the incidents furidan is not
supposed to be used near drinking fowl.
A problem that may arise in assessing the possible hazard of a
pesticide on wildlife is that its chemical decay rates are likely to be
different in the field than in the laboratory. According to Azevedo,
azodrin decayed much more slowly in the field than in the laboratory. A
similar problem was pointed out in the section on occupational health hazards,
where it was noted that worker re-entry times were frequently based on decay
rates noted in the laboratory, while decay rates on the foliage were far

Since so little systematic monitoring of the impact of pesticide use
on wildlife has been conducted, it is possible that the situation in regard
to azodrin and furidan represent only the tip of an ice-berg. We must
assume that any pesticide use has a potential for impacting on wildlife and
the general stability of the ecosystem.

1.	Milby, T., et al. J. of American Medical Assn. 189(5): 351. 1964.
2.	Hamilton, A., and Hardy, H. Industrial Toxicology, third edition,
Publishing Sciences Croup, Acton, Mass. 1974. p. 357.
3.	Pesticide worker safety regulations, California State Department of
Agricultural Chemicals and Feed, April 10, 1974.
4.	California Community Studies on Pesticides, Contract Report #19, Jan. 1-
Dec. 15, 1969,
5.	Howitt, Richard, Ph.D. Thesis, University of California, Davis. 1975.
6.	Shea, K. Environment 16(9): 6. November, 1974.
7.	Barnes, J., and Dent, P., J. Path. Bac. 65: 597. 1953.
8.	Interview wit;h Dr. Gerald Rosen, Dept. of Toxicology, Duke University,
Sept. 1974.
9.	Milby, T. Testimony on Federal Environmental Control Act of 1971.
Hearings before Senate Subcommittee on Environment. Serial #92-80, p. 397.
10.	Jager, K., et al. Br. J. Ind. Med. 27: 273. 1970.
11.	Drenth, et al. Arch. Envir. Health 25: 395. December, 1972.
12.	Schmertzler, L. "Achilles tendon reflex force as a sensitive test for
organophosinate exposure." To be published.
13.	Rayner, et al. Res. Comm. Chem. Path, and Pharm. 4(3). Nov. 1972.
14.	Metcalf, D. and Holmes, J. Annals N. Y. Academy of Science 160: 357.
June 23, 1969.
15.	Gerson, K. and Shaw F. Lancet, p. 1370. June 24, 1961.
16.	Dllle, J., and Smith P. Aerospace Medicine 35: 475. May, 1964.
17.	Clark, G. Aerospace Med. 42: 735.
10. Medved, F. Residue Reviews 6: 42.

19.	Reiter, L., Talens, G. , Woolie, D. Troc. West. Pharra. Soc. 15: 123. 1972.
20.	Tocci, et.al. Ind. Med. Sur. 38(6): 188. 1969.
21.	Davies, J. In Rroc. of Natl. Conf. on.Protective Clothing and Safety
Equipment for Pesticide Workers. Atlanta, Ga. Hay,1972.
22.	Wasserman, M., and Wasserman, D. Jfo "Fate of insecticides in the
Environment". S. A. Tahori (Ed.) Butterworth, London, 1972. P. 521.
23.	Kaloyanova-Simeomova, F. Reported at meeting of subcommittee on
Pesticides of international Association of Occupational Health,
Amsterdam, 1971. Summary of Conference in Arch. Envir. Health 25.
December, 1972.
24.	Boguzs, M. Clin. Chim. ACTA. 19: 367. 1968.
25.	Nakazawa, T., and Nakazawa, T.	j, jap. Assn. Rural Med. 22(6): 756.
26.	Community Pesticide Study, California State Dept. of Public Health,
Contract lr Ph 86-6J-87, Jan. 15, 1970. Principal Investigator, Serat, W.
27.	Epstein, S. et al. Nature 214(50871): 526. April, 1967.
28.	Information obtained from Juarez Lincoln Center for Information on
Migratory Workers. Austin, Texas.
29.	Chase, H. et al. In U. S. Senate Labor and Public .Welfare Hearings
(91st Congress) Subcommittee on Migratory Labor, part 8-A, July 20, 1970.
30.	Boyd, E., and Chen, C. Arch. Envir. Health 17. August 1968.
31.	Stoenswand, G., et al. New York's Food and Life, Science 2(1). January-
March 1969.
32.	Duggan, R. and Lipscomb, G. Pest Monitoring Journal 2: 153. 1969.
33.	Corneliussen, P., Ibid., p. 140.
34.	Harrison, H. et, al. Science 170: 503. 1970.
35.	Woodwell, et al., Science 156: 821.
36.	Duggan, R. and Lipscomb, G. Pest. Monitoring Journal 2: 153. 1969.

mg Journal, 5(4;; jjj.
March, 1972.
38.	Corneliussen, P. Ibid., p. 313.
39.	Interview with James Kalstron, Division of Agricultural Chemicals and
Feed, California State Department of Agriculture, January 1975.
40.	Reported in DuBois, K., Advances in Pest Control Research 4:117- 1961.
41.	Interview with Dr. A. H. Conney, Hofman La Roche Corporation, Nutley,
New Jersey, October, 1974.
42.	Swartz, J., and Spear, R. In press. Mathematical Biosciences, To appear
August, 1975.
43.	Epstein, S. Case-Western Reserve University, Testimony at Hearings on
Aldrin-Dieldrin. P. 7.
44.	Innes, R. et al. J. Natl. Cancer Institute 42: 1101. 1969.
45.	Tarjan and Kemeny . Cosmet. Toxiol. 7: 215. 1969.
46.	Quoted in Epstein, S. op. cit. p. 39.
47.	Ad Hoc Committee on the Evaluation of Low Levels of Environmental
Chemical Carcinogens. Saffiutti, U. (National Cancer Institute), et al.
April 22, 1970.
48.	Quoted in Epstein, S., op. cit., p. 19.
49.	Ibid. p. 21.
50.	Ibid. p. 28.
51.	Preliminary Report on the Carcinogenesis Bioaasay of Chlordane and
Heptachlor, National Cancer Institute. January 22, 1975.
52.	Weirsma, . Peat; Monitoring Journal 6(20): 126. September, 1972.
53.	Weirsma, . Pest Monitoring Journal, 6(3):	December, 1972.
54.	Dahlsten, D., and Wenz, J. InEnfo, Spring, 1975. Available from
Northern California Committee for Environmental Information; P. 0. Box 761,
Berkeley, California 94701.

55.	International Agency for Research Against Cancer, "Evaluation of
Carcinogenic Risk of Chemicals to Man." Vol. 5, 1974. Leone, France.
56.	Interview with Tucker Helmes, Stanford Research Institute, October, 1974.
57.	Lederberg, J. In Foreward to The Mutagenicity of Pesticides. Epstein,
S., and Legator, M. M.I.T. Press, Cambridge, Mass. 1971.
58.	Epstein, S., and Legator, M. The Mutagenicity of Pesticides, M.I.T.
Press, Cambridge, Mass. 1971, p. 5.
59.	Ibid, p. 7.
60.	Legator, M. Annual Review of Medicine 23: 413. 1972.
61.	Hamilton, A. and Harby, H. Industrial Toxicology. Publishing Sciences
Group, Acton, Mass. 1974, p. 403.
62.	Lederberg, J. Op. cit. XIII.
63.	Cytologia 32: 31. 1967. (No author listed.)
64.	Science 109: 467. 1949. (No author listed.)
65.	Phyton 18: 23. 1962. (No author listed.)
66.	Nu, K., and Grant, W. Cytologia 30: 175. 1965.
67.	C & En. News, Aug. 10, 1970, p. 51.
68.	Shea, K. Environment 14(1): 22. 1972.
69.	Mutation Res. 16(4): 413. Dec. 1971.
70.	Interview with Dr. Dale Haddis. Center for Policy Alternatives. (M.I.T.),
December, 1974.
71.	Epstein, S. et al. Tox. Appl. Pharm. 23: 288. 1972.
72.	Dean, B. and Thorpe, E. Arch. Toxikol. 30: 51. 1972.
73.	Reported in Witt, J>- et -al. r .Cooper.ative..Extension Service. Corvallis,
Oregon 97331. July 18, 1967.

74.	Abrahamson, S. Science 187: 503. February 14, 1975
75.	Kilby, B. Mutation Res. 26: 240. 1974.
76.	Frohberg, H., and Schenking,	Arch. Toxicol. 32: 1. 1974.
77.	Interview with Dr. S. Abrahamson, Zoology Department, University of
Wisconsin, Madison. January, 1975.
78.	Cofman, J. et aJL. In Symposium on Fundamental Cancer Research, M. D.
Anderson Hospital, Houston, Texas. Williams and Wilkins, Bait.
79.	Interview with Dr. S. Epstein, Case Western Reserve University, January, 1975.
80.	Huffaker, C. B. "The Ecology of Pesticide Interference with Insect
Populations." In Agricultural ChemicalsHarmony or Discord, J. E.
Swift, ed. University of California, 1971.
81.	Interview with Ward Stenger, University of California Agricultural
Extension, Davis, Ca., October, 1974.
82.	Cope, D. Interactions Between Pesticides and Wildlife.
83.	Woodwell, C. et al. Science 156: 21. May; 1967.
84.	Wurster, C., et al. Science 148: 90. 1965.
85.	DeWitt, J. J. Agr. Food. Chem. 3: 672. 1955.
86.	Interview with Dr. J. Azevedo, California State Dept. of Fish and Game,
Nov., 1974.
87.	Azodrin Wildlife Investigations in California, prepared by the Calif.
Dept. of Fish and Game Pesticides Investigations Project. 1967.

CITRUS I. Supply and Demand
Citrus Acreage and Production
The citrus industry is an important part of California agriculture.
California oranges ranked as the state's number one crop between 1930 and
in terms of cash value.
1950 / Since 1950 it has fallen in relative importance, but was still the
number ten crop in the state in 1969	Navel and Valencia oranges
account for seventy percent of the California-Arizona citrus crop, while
lemons make up another 20 percent. We shall restrict most of our
discussion to the orange crop.
There are three major citrjis growing regions in the California-Arizoija
production zone. Region 1 runs along a vertical strip of the southern por-
tion of the San Joaquin Valley; it is centered around Porterville, being
bounded by Fresno in the North and Bakersfield in the South. Fifty-five
percent of the California-Arizona orange crop is produced in this region.
Navel oranges are the predominant variety with 74 percent of the total,
while Valencias make up the remaining 26 percent.
Region 2 consists of the coastal Southern California counties from
Ventura in the North to San Diego in the South and as far East as Riverside.
This region contains 33 percent of all California-Arizona acreage. Valencia
oranges are the predominant variety with 71 percent of the total, while
navels account for the remaining 29 percent.
Region 3 consists of the Arizona-California desert valleys, especially
around Indio, Ttuma and Phoenix. This district contains 12 percent of the
California-Arizona orange acreage* Valencias are the predominant variety
*ith 78 percent of the total. Arizona navels make up the remaining 22 percent.
There is a fourth citrus production region in Northern California hut
It produces an insignificant percentage of the total crop.

The Fresh Market
The California-Arizona citrus industry is geared toward the fresh market.
The navel and Valencia varieties tend to have a lower juice yield than
Florida oranges (a more cosmetically attractive exterior color) and
they tend to have a higher level of citric and ascorbic acid which
are associated with taste and nutrition. Since the California citrus
industry was more or less fully developed before the advent of frozen
orange juice concentrate it is geared, in other ways, toward the fresh
market. The quality standards which prevail in California are
designed to meet the criteria of the fresh market,' The major marketing
cooperative of California-Arizona oranges, Sunkist Growers, Inc., has spent
many years and millions of dollars to cultivate and maintain a market
image for fresh citrus.^ Consequently, the financial well-being of California-
Arizona orange growers is critically tied to the state of the fresh market.
For example, in 1965 California growers received an average of $2.61 a box
for navel oranges sold in the fresh market, but only 12c a box for navel
oranges sold for processing into juice or other by-products. The respective
prices for Valencias in the same year was $2.90 and 42c. These figures
are fairly typical. California-Arizona orange growers make little or nothing
on oranges sold to the processing market. They must sell a large percentage
of their crop to the fresh market. This is in contrast to the Florida
citrus industry where the prices received for citrus for processing are
comparable to those received for citrus for the fresh market.**
The Problem of Over-Production
The California-Arizona citrusindustry has suffered a chronic problem
of "over-production"; a substantial proportion of the orange crop, over 20
percent of the navel erep-andr-41Lp&rces&0 Ahe Valencia. crop,, must be sold

for juice or by-products, at little or no net return to the growers. There
are several possible factors that enter into the "over-production" problem.
The per-capita consumption of fresh oranges has declined badly in recent
years. Between 1945 and 1960 per-capita consumption declined from 37.9
pounds per year to 16.2 pounds per year.	Since 1960 the per-capita
consumption has remained about constant at about 16 pounds per year.
In this same period the consumption of frozen orange juice concentrate
has increased greatly. In terms of total consumption, the consumption of
fresh citrus declined from 72 million boxes in 1945 to 38 million boxes
in 1962, while in the same period the consumption of citrus juice and by-
products increased from 27 million boxes in 1945 to 98 million boxes in
1962. Since the per-capita consumption of all orange products has remained
about constant it is natural to assume the consumers have been substituting
frozen orange juice concentrate for fresh orange consumption, and that this
accounts for the decline in the per-capita consumption of fresh oranges.
However, according to the results of several econometric studies on con-
sumer demand for oranges, orange juice and frozen orange juice concentrate
8 9
are good substitutes for fresh oranges during only a few months of the year. *
Additionally, results of retail market tests reveal that since 1955 there
has been little substitution between the purchases of fresh oranges and
processed orange and citrus products as a result of changes in relative
price levels between the two productsThus, the decline in the
per-capita consumption of fresh citrus may relate to other factors in
addition to the rise of the frozen juice concentrate industry. The
per-capita consumption of total fresh fruit and the per-capita consumption of
total fruit ffcfish.ao^progessed.. has.also declined in the post J940,period

in the United States. This general change in food consumption patterns
is undoubtedly reflected in the decline in the consumptionjof fresh citrus.
In addition to slackening per-caplta demand for fresh citrus, the grower has
been receiving a decreasing proportion of the total return on citrus.
Marketing margins, the difference between the price paid by the consumer
Snd the amointreceived by the producer, have been increasing since 1950
for oranges. in particular retailer margins have increased dramatically
since 1950. This is probably due to the great increase in the market
power of the retail sector relative to the production sector as large
retail chains have become dominant in the last few decades. It should also
be noted that when supplies of oranges are low and the retail price is
high the proportionate return to growers is relatively high, whereas when
supplies of oranges are high and retail prices relatively low, the retailer
margin is relatively high.^This ;s a special case of the general observation
by Jamison that, "The grower demand curve is generally price inelastic in
the relevant output range while the demand facing the marketing firm is
generally elastic. Total revenue maximization therfore calls for opposite
control policies at these two levels--e.g. growers, as a group, gain from
decreased quantities sold and marketing firms, as a group, gain from
increased supplies'.1
Given this situation, of decreasing per-capita demand for fresh citrus
and a decreasing proportionate return to the grower, we might expect to see
a pattern of decreasing acreage and production of California-Arizona citrus
in the post 1950 era. However this is not the case. California orange
acreage did, in fact, decline from 235*000 acres in 19^5 to 132,000 acres
In 1961. However, this was due primarily to the urbanization of the Los
Angeles basin, starting in I960, California acreage started to Increase

rapiaiy to auuut	 ...	 . .
in oranges has remained fairly stable. Orange acreage continued to
decrease in the .Southern Cal i forni a growing region in the sixties, while
there was a precipitous increase in orange acreage in the Central California
growing region, and an increase of lesser magnitude in the Arizona-Califonia
Desert region. The increased acreage was disproportionately allocated to
the production of navel rather than Valencia oranges.^
This pattern of acreage increase ir the 1960's is explicable for
the following reasons. Growers who were forced out of production in the
Los Angeles area due to urbanization undoubtedly received very substantial
capital gains upon the sale of their land. It would seem logical, from the
viewpoint of an individual grower; to reinvest tin's capital in new orange
acreage in Central California where the weather was conducive to citrus
production, water was available and land was relatively cheap. For navel
oranges grown in Tulare county in 1971 the cost per acre for water was
$36 and the cost per acre for taxes was $64. For San Bernardino county
the respective figures were $64 and $125. For Valencia oranges grown
In Tulare county in 1971 the cost per acre for water was $36 and the
cost per acre for taxes was $55. The respective figures for Valencias
grown in Orange county was $80 and $ 150.16 It would

also be logical to invest in navel rather than Valencia oranges since
a higher percentage of navels make it to the fresh market, and therefore
the potential return is higher on navels. fn addition, under the federal
tax laws operative in the 1960's citrus growers were allowed to count
cash expenditures on orchard development as capital expenses. Thusj the
investor could deduct depreciation, cultural costs, interest, taxes and
management fees associated with establishing the citrus orchard from other
income. After the orchard was established the cost of planting the trees
was depreciable over their useful life. This incentive toward "tax shelter
farming" undoubtedly contributed to the expansion fn citrus acreage in
Central California. The Tax Reform Act of 1969 wiped-out the tax shelter
provisions for citrus and almond orchards and this may account, In part,
for the leveling off of citrus acreage since 1970.17,18 ,19
The 1950's and 1960's were also periods of increasing population and
increasing real income. Both these factors could be expected to contribute

an increase in the total consumption of fresh citrus. The larger the
population, especially in California where fresh citrus consumption is
relative]-/ high, the larger the total consumption of fresh citrus. Since
the demand for citrus has been shown to be income elastic, that is families
with higher incomes purchase more citrus per-capita, an increase in real
incomes for all families would be expected to result in an increase in
total consumption of citrus. If these were the expectations of the 1960s
they have not been fulfilled by the 1970s. The population growth-rate
is declining as is the level of real family income. It is not clear that
either of these trends are likely to be reversed before 1980.
The combined effect of these factors, some of which induced an expansion
of citrus acreage for reasons unrelated to consumer demand, is evident in
the data for the percentage of California-Arizona citrus that is actually
sold to the fresh market. For Valencia oranges, the percentage of the crop
sold to the fresh market averaged about 67 percent in the period 1950-1960.
Between I960 and 1973 the percentage of the Valencia crop sold to the fresh
market uncjer-went a steady decline, averaging 60 percent for the period
1960-1973. Navels follow a similar pattern. In the period 1950-1960,
88 percent of the navel crop, on the average, was sold to the fresh market.
For the period 1960-1973 this figure dropped to 78 percent. The season
average on-tree returns for California oranges, which had been increasing
between 1950 and i960 also declined between I960 and 1973- These various
, trends are illustrated in figures ), 2, and 3-
To summarize, in the post-1960 period orange production acreage in
California increased, shifted from Southern to Central California, and
shifted relatively toward the-production of navel oranges. During the
same period per-capita consumption of fresh oranges declined as did the
proportion of the orange crop sold to the fresh market, the relative


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hrst time since 19&0, the trend ;n citr'us production acreage seems to bear
fcome relationship to the trend in per-capita consumption. That is, they
jire both fairly stable. If other factors remain stable this means a
fcontinuation of the current situation of chronic over-production, with
fco percent of the navel and AO percent of the Valencia crop going to juice
jsricf byproducts. Accelerated population growth, the opening of new (foreign)
harkets, a shift in consumer preferences toward the consumption of fresh
fruit, could, imaginably, alleviate the situation. However, such intervening
factors might also spur a renewed period of acreage expansion, although
this possibility is somewhat dampened by the provisions of the 1963 Tax
Reform Act.
The situation in citrus production seems to fit the
general m.ode-1 of economic behavior described by the National
Commission on Food Marketing:
For a variety of reasons bearing acreage of some perenni.al
crops exhibits broad, cyclical movements. The basic cause
of such cyclical movements appears to be the tendency of
producers to formulate expectations of future price of
a commodity upon the current price or those prices of the
recent past. if expectations of earnings are high for a
singfe commodity relative to those for alternative uses of
resources in some given period of time, planting of the
former commodity tends to increase. As plantings come
into bearing in a subsequent period, production rises and
price fails, other things being equal. At that time the
cyclical movement tends to reverse. Because of the
perennial nature of the crop and the relatively high
proportion of fixed to variable costs involved in bearing
acreage, resource adjustments occur in a lagged and sluggish
manner. Price may remain comparatively low for several
years during the'eye 1icaI Iy high level of bearing acreage.
In time, the price and market mechanism would bring about
adjustments in resource use. In the meantime, owners of
resources are concerned with the short run and the hardship
which theimpersonaf forces of the market might fnvoke.
(Fruit and Vegetable Industry, National Commission on
Food Marketing, Technical Study No. 4, June, 1966, f>. 355.)

CITRUS II. Cooperatives and Marketing Orders
The anarchy that prevails In citrus production, the low rate of return
and fluctuating price structure, the inordinate degree of market power
of the input and retai} sectors; these factors have long been recognized
by citrus growers and agricultural economists concerned with California)
agriculture. Two basic institutional arrangements have been constructed In itri
attempt to stabilize intra-seasonal and inter-seasonal prices and increase
the general level of grower return. These institutions, each of which
make the grower exempt from certain provisions of anti-trust law, are the
marketing cooperative and the marketing order.
The dominant marketing cooperative for California-Arizona citrus Is
Sunkist Growers, Inc. which markets about 80 percent2^ California-Arizona
citrus and represents 8,500 citrus growers. Under the provisions of the
Capper-Volstead Act of 1922 Sunkist growers are allowed to join together
into one organization for the collective processing and marketing of their
fruit without being held in combination or conspiracy. However, in
Case-Swayne Company, fnc v. Sunkist Growers, Inc. the U.S. Suoprct*: Court
ruled, in 1967, that Sunkist no longer qualified for exemption under the
Capper-Volstead Act because 5 percent of its membership cons'ste^
corporate growers having their own packing houses and 15 percent were
private corporations and partnerships owning and operatic packing houses
for profit, whose relationship to growers was defined not >%V J cooperative
agreement but a cost-plus-fixed-fee marketing contract?' *,,m* Sunkist
has reorganized to comply with the Supreme Court ruling.'	recently
as 1974 Sunkist still listed Goodyear Tire 6 Rubber Comp*1^ K*l'5er
Aluminum and Chemical Company among Its groweremembers.	i,rjc*'ce
aHowing giant corporations like these to take advantage ,v* Capper-Vol stead
exemption, which was meant to give economic power to the *** fl>rncr, ha*
been criticized by some.29

Each member of Sunkist is also a member of a local association or
district exchange. The members, wh.et.fier they market through a cooperative
packing house or a private packing house licensed by Sunkist, elect
representatives at the level of the district exchange. The most important
mechanism of communication between Sunkist management and the grower-members
is the annual meeting of Sunkist. In addition, according to Sunkist representative
Curtis Anderson, "Many opportunities are provided each year for growers to
attend local and central organization board meetings, to hear how their
business is being conducted."
Sunkist has engaged in substantial promotional activities, spending $38.
million between 193** and i960 for radio, television, newspaper and magazine
!advertisements designed to build a quality image for fresh California citrus.
In order to maintain the quality "reputation of the Sunkist trade-mark'. Sunkist
Issues a set of quality standards in excess of statutory state quality
standards, which must be adhered to by all packing-houses that market through
Sunkist. It has been estimated that the Sunkist quality reputation
confers a price premium of five to ten percent on Sunkist products over the
prices of competitive products. However, there is some evidence that the
quality factor may be over-rated (see p	below).
Sunkist also plays a significant role in the administration of the marketing
order under which the California-Arizona orange industry operates. The mar-
keting order itself specifies that Five out of the eleven members on th6
Administrative Committees of the orange marketing orders shall be members
of Sunkist. 33
The other major citrus marketing cooperative In California-Arizona is Pure
Cold, Inc. which markets abput ten percent of the crop. The giant vertically
integrated agribusiness corporation, Tenneco, currently markets about five
percent of the California citrus crop. Tenneco is attempting to increase
Its share of the fresh produce market through aggressive marketing which

places special emphasis on trie cosmetic appearance or the produce and on
increased packaging designed to appeal to consumer reflexes. ^
Taken together, the top four firms in citrus marketing account for
about 90 percent of the market. A concentration ratio of this magnitude
would ordinarily be taken to represent a high degree of monopoly power.35
Under the Capper-Volstead Act, marketing cooperatives are allowed to possess
monopoly power as Jong as fts is not exerci'sed to produce anti"-compet i t i ve
effects. In any case, Tt is doubtful that citrus marketing cooperatives
really possess the kind of monopoly power that the concentration ratio
would appear to suggest. The marketing cooperatives face a retail sector
that is also highly concentrated and well coordinated. In addition, the
over-production problem we have already described puts the marketing cooperatives
St a great disadvantage when bargaining with retailers. The Capper-Volstead
Act, which allows the organization of marketing cooperatives does not.,
however, allow the organization of production cooperatives wtiTch might
function to rationally allocate the total production of citrus products.
Marketing Orders 907 and 908.
The Celtfornia-Arizona orange industry also functtorB under
federal marketing orders, the intent of which is to stabilize the price
level for oranges and to increase the net returns to growers. These
marketing orders are made possible by the Agricultural Marketing Agreement
Act of 1937* the federal law which exempts the activities of marketing
orders from certain anti-trust provisions. The present marketing orders
governing oranges, marketing order 907 for navel oranges and marketing
order 908 for Valencia oranges, came into being in the I950's. Each of
these marketing orders is administered by an Administrative Committee
composed of six growers, four handlers, who may also be growers, and
one non-industry member who has always been nominated by the other
menfcers to serve as the chairman of the Administrative Committee.

Under the provisions of the marketing orders three of the grower members
and two of the handler members of the Administrative 3?oard?must belong
to Sunkist Growers, Inc. The other marketing cooperatives, Pure Gold, Inc.
and Gold Banner Association get one grower and one handler member each,
and two grower members and one handler member are chosen to represent
independent growers and handlers. The Administrative Committees require
six concurring votes to take any action. Obviously, with five votes,
Sunkist has a good chance of dominating the policy of the navel and
Valencia Administrative Boards. Some non-Sunkist growers and handlers
have complained about Sunkist domination of the Administrative Boards.^
There is certainly a possibility of a conflict between Sunkist and non-
Sunkist interests in regard to marketing order policy since Sunkist
enjoys a special reputation for quality not shared by non-Sunkist
growers and handlers. Thus, Sunkist may wish to set a marketing policy
based on higher prices and lower market volumes than non-Sunkist people
would 1ike to see.
The orange Administrative Coiirenittees aro empowered to establish a
"best" policy for the marketing of CalifornJa-Arizona oranges. A "best"
policy, presumedly, is one which minimizes prices fluctuations and
maximizes returns to the grower. In order to achieve the goals of this
policy the Administrative Committees collect and analyse information ori
the available crop of oranges, including estimated quality and composition
of sizes, the estimated utilization of the crop, available supplies of
competitive oranges, the level and trend of consumer income, estimated
supplies of competitive citrus commodities, and any other pertinent infor-
mation. Based upon this information the Adminsitrative committees
produce a schedule of estimated weekly shipments designed to meet the
goals of their marketing policy.

The .recommended weekly volume of orange shipments, which may be revised
as the season progresses, is implemented by a system known as Pro-rate.
Under the pro-rate system the weekly quantity of oranges that may be
shipped to the fresh market is fixed for each of the three growing regions
in the California-Arizona market. Each packing house is allocated a
specific percentage of this quantity based upon its percentage of the
total production of the pro-rate region. The packing-house is thus con-
strained to allocate only a certain proportion of each grower's crop to the
fresh market. The mechanism, by which this allocation takes place is the
enforcement by packing-houses of the quality standards established by
marketing cooperatives. The administrative committees may also regulate
directly the size of oranges that are allowed to be sold on the fresh
fflarket. Specific exemptions from regular allotments are allowed in the
case of early maturing fruit, fruit with a short-tree-storage life, and for
freeze-damaged weeks of the season in which freeze damage takes place.
The orange marketing orders do not apply to fruit that is sold for
processing into juice and by-products or to fruit that is exported to
countries other than Canada. The marketing orders have no effect on the
development of new orange acreage or the entry of new growers. Thus, the
orange marketing orders are totally ineffective in regulating the total produc-
tion of California-Arizona oranges. As a result, while intraseasonal price
fluctuations have followed a fairly stable pattern, interseasonal prices do
not. In addition, it is doubtful that the operations of the orange marketing
orders can have any significant effect on the over-production problem. The power
of the marketing order is predicated on the assumption that there is no commodity
substitute available for California-Arizona fresh oranges. While this is true
to a great extent from the consumer's point of view, it does not mean that

highly concentrated retailers may not ch ose to feature other commodities
rather than oranges if they perceive that the weekly volume flow of oranges
j ^
is being unduly restricted. The resultant drop in wholesale price might
force the A'.dminist rati ve Boards to restrict the flow to even a greater
extent in an attempt to make up for the loss in projected revenues.
If this tendency exists, as the pattern of declining fresh market allocations
and declining grower returns indicate it might, then it might also be
dampened	by the promotional activities of Sunkist, which retailers
may exploit in their ovn promotional activities.
Under the Pro-rate system the grower receives the seasonal average
price for his fruit. What becomes critically important in determining the grower's
returns is the size distribution of the fruit, which is beyond his immediate
control, and quality of the fruit, which is, to some extent, affected by
pest control practices. Each grower, then, seeks to Increase the total
yield of the crop and seeks to maximize the proportion of his crop that
is allocated to the fresh market and to the top grade in the fresh market.^
The long-run consequence of these atomistic efforts may be to decrease
the industry wide average proportion of the crop that is allocated to the
fresh market, arid this has in fact been the case in recent years. The
result of this pattern is to increase, even more, the incentive of the
individual grower to maximize yield and quality, resulting in Increased
production costs, increased reliance on input factors^ and an increase
in the minimal size of the production unit. One grower we spoke to
testified that in the 1950's a ten acre orange grove could provide a
living income, but today ^0 acres is the minimum. Robert Howie, the
agricultural commissioner of Riverside County also indicated that
the smaller orange growers are being driven out of business by Increasing
Input costs.46,47

, summary, the Institutional arrangements which have been developed
,onse to the over-production problem, the marketing Cooperative
2 marketing order, are incapable of directly attacking the root
0f the over-production problem, the disproportionate market power
j input and retail sectors compared to the atomistic production
instead attempts are made to deal with the over-production
,:1 in a symptomatic way, resulting in additional dislocations
say not be beneficial to society. Such dislocations are not a
of insincerity or ineptitude on behalf of orange growers and
institutions, but result inspite of the test motivated and best
~ed efforts on their part.
..'ithin this system quality standards play an important role, and it
:a consideration of these standards that we now turn.

CIl-RUS III. Quality Standards
The Calilornia-Atizona citrus industry operates under two kinds of
quality standards for fresh fruit. In the first instance, the fruit must
meet the statutory quality standards which are established and enforced by
the state. The California standards required that oranges have a soluble
solids (sugar) to acid ratio of eight to one if 25 percent of the surface
of 90 percent of the fruit has attained an orange color, and a soluble
solids to acid ratio of ten to one if the average surface of 95 percent of
the fruit is orange. These state standards clearly relate to maturity and
are written so as to insure that green or sour fruit does not appear on the
fresh market.
The statutory standards are not, in reality, the effective quality
standards that orange growers must meet. Rather, quality standards of a much
more comprehensive and stringent nature are enforced by the orange marketing
cooperatives. For example, Sunkist maintains a set of quality standards
that specify criteria which oranges must meet in order to be sold under the
various Sunkist Jabels, e.g., "Sunkist," "Excel," "Red Ball" and SK." In
order for oranges to receive the top "Sunkist" label they must, in addition
to meeting the statutory quality standards, fulfill the following criteria:
Oranges packed for marketing under the trademark Sunkist shall be
mature; of one variety; of good eating quality and flavor, of good
juice content; well grown specimens of normal form, picked from the
tree; of good color for the variety; of good texture; practically
free from scale or other insect pests, fungus diseases, splits, or
defects of any kind that cause fruit to decay. The following classes
of fruit shall be excluded: rough; coarse; more than slightly puffed;
more than slightly scarred; more than slightly sunburned; misshapen

fruit; dirty fruit unattractive to the consumer; fruit showing
effects of frost or which cuts dry for any reason; immature fruit;
fruit insipid in flavor; fruit deficient in juice content; and
fruit green or very pale in color. Soft fruit or fruit showing
marked evidence of aging or shriveling shall be excluded. Fruit of
extra texture and color may properly carry more scars than fruit
possessing only the minimum of color and texture required under
these "Sunkist" specifications. Oranges packed for marketing
under the trade-mark Sunkist shall not vary more than 5 percent
below foregoing specifications except that decay within this
tolerance shall not exceed 1 percent.
These specifications for oranges receiving the "Excel11 label are
identical to those for the "Sunkist" label except that specific provisions
are made to allow for the inclusion of frost-damaged fruit. The "Excel"
label is used primarily in frost-damage years to allow for the marketing
of a proportion of oranges that would ordinarily, because of excessive
interior dryness, go into juice and by-products. The specifications for
oranges receiving the "Red Ball" label are identical to those receiving
"Sunkist" except that the word "good11 is replaced by "fair", the words
"more than slightly" are replaced by "badly" and the word "very" modifies
the remaining defects. The tolerance allowed for the "Red Ball" label is
10 percent instead of 5 percent, but not more than half this tolerance is
allowed for serious drying or freezing damage. Valencia oranges marketed
under the "Sunkist" and "Red Ball" labels must, in addition to meeting the
statutory maturity standards, have a Brix reading (which measures percent
sugar) of not less than 9.0.

The non-statutory standards contain a large number of
specifications which relate exclusively to the external appearance
of the fruit and havo no bearing on the taSte or nutritional
quality of the fruit. This Is especially true of the specifications
vhich differentiate the "Sunki st" grade from the "Red Ball1' grade.
These specifications can be classified as "cosmetic" if, in
addition, they bear little or no relationship to the yield of
fruit or to tree vigor- (For a case in point, see the discussion
of the citrus thrips, below.) It Is also apparent that oranges
can be allocated to juice and by-products strictly on the basis
of external appearance.
Obviously, the non-statutory standards do not serve as a
"standardization" mechanism, assuring to all parties a minimum
level of quality, especially in regard to taste and maturity.
This is done by the statutory standards, which are, in fact,
subsumed as part of the non-satutory standards. It might be
thought that the non-statutory standards have been established
in response to a consumer preference for high cosmetic quality.
This theme has been stressed by many commentators, Including
many of those who are highly critical of the current pattern of
pesticide use related to cosmetic qua I Ity standards. For example,
David Pimentel, writing in the March, I973 Journal of the New
York ntomoIogoca( Society, observes, "Oranges also are fn the
same category as apples, because of the currently high 'cosmetic
standards' now expected by the consumer.ir (emphasis added)
However, since the consumer Is rarely presented with an explicit
choice between oranges of differing cosmetic quality, it Is
difficult to know, from direct evidence, what the consumer
preference really Is. P.S. George an^l G.A. King, agricultural

lonornis+s with the Giannini Foundation, have indirectly derived
i, "e 1 as t i c i ty of quality" for oranges. This elasticity is
lightly negative (-.035) which could mean a number of things;
Jt it at least leaves open the possibility that the current level
t quality of oranges is higher than consumer preference would
arrant, that is, the level of quality could be lowered without
fall in the price of oranges."*1
Whatever the current state of consumer preference for
iosme+ic quality in oranges, it is no doubt a product of decades
if promotional activities by Sunkfst rather than an endogenous
iroperty of the human psyche. The Florida "russet grapefruit"
ihlch is severely cosmetically damaged by mites and whlteflies,
receives a premium price because of its high interior quality.
In this case, the cosmetic damage has become a trade-mark,
Bs tt were, of the high quality of the fruit. The green color
Of the re-greened Valencia orange Is now being advertised as
a "guarantee" that the fruit is ripe, which, in -fact, it is.52
Thus, consumer attitude does not  seem to be an insurmountable
barrier to the alteration of cosmetic quality standards once
other obstacles to change have been overcome.
Non-statutory standards may exist for another reason,
quite apart from consumer preference, and that ?s as a mechanism
for allocating oranges to the fresh market, in accordance to the
policy goals of the orange Administrative Boards. !t is in
the packing-house that the enforcement of non-statutory quality
standards takes place and it Is as a result of this enforcement
that a certain number of oranges are offered for sale on the
fresh market and the remainder diverted to Juice and by-products.

This Is all of great importance to the grower, for he receives a
significantly lower price for oranges that are- classified as "Red Ball'f
rather than "Sunkist" and an even lower price for oranges that go to
juice and by-products. For the years 1950-51, 1965-66 and 1967-68, Rausser
reports the following composite relative prices that were received for the
different grades of navel and Valencia oranges.
Navels	Relative Price	Valencias	Relative Price
Sunkist	1.0Q	Sunkist	1.00
Excel	.82	Excel	.83
Red Ball	.74	Red Ball	.71
The on-tree return per 75 lb. box for oranges that went to the processed
and fresh markets was reported by Burke^ to be:
Fresh	Processed	Fresh	Processed
Navel	Valencia
Data from pack-out sheets
that we have
received for 1973
and 1974
this general situation.. These pack-out sheets, which report to the grower
the distribution of his crop into different grades and the prices received,
indicate that the grower receives between $.50 and $1.50 less per packed
(50 lb.) box for oranges that are graded "Red Ball" or "Choice" rather than

"Sunkist" (or "Pure Gold")* Pack-out sheets for navel oranges indicate
that growers received from nothing to $10.00 a ton for navel oranges that
went to juice and by-products. This latter figure is equivalent to $.25
per box. For Valencia oranges the price received per box was in the $.60
to $.80 range. Obviously, there is a great financial incentive for growers
to meet the quality standards that adhere to the top grade for fresh oranges.
An important aspect of the quality standards that are specified by
Sunkist is their non-quantitative nature. For example, it is difficult to
know exactly what "more than slightly scarred" means. Additionally, the
cause of many of the defect^ is not specified. Scarring may result from a
number of factors, including wind, mechanical abrasion by branches, and
various insect pests. The wide range of exterior defects specified In the
quality standards are not detected by any quantitative technique. Rather,
the oranges are screened visually by packing-house workers as they are
carried down a conveyor belt. It would seem that the non-quantitative
nature of the exterior quality standards and the inspection procedure would
allow for the adjustment of the enforcement level of the quality standards
without any change in the specification of the quality standards themselves.
It has been suggested, for example, that this could be accomplished by
simply increasing the speed of the conveyor belt that carries the oranges
past the quality inspectors, or by increasing or decreasing the number of
inspectors on duty. Spokesmen for Sunkist categorically denied that any
"adjustment of the quality standards" takes placed In the strict technical
Bense of this phrase they are correct. However, there is evidence to
Higgest that adjustment of the level of enforcement of quality standards
loes, in fact, take place. First of all, the decreasing proportion of
Ganges that are sold to the fresh market indicates that either the actual

quality of oranges has been deteriorating or that the level of quality
standards enforcement has become more stringent. The first possibility
is explicable only if we assume that insect related damage is the pre-
dominating factor in determining the level of quality and, furthermore,
that orange growers have been progressively inept at dealing with insect
pests in the .last decade. Though there is some truth to the latter of these
assumptions, there is hardly enough to explain the regular decline in the
proportion of fruit sold to the fresh market. If this hypothetical quality
decline is not due to insect damage it must be due to various cultural and
mechanical factors, and, again, there is no reason to expect a regular
increase in damage due to these factors. It is much more credible to
assume that as orange acreage and production has expanded in an inordinate
fashion, the enforcement level for quality standards has had to be annually
adjusted to fulfill the marketing policy established by the orange
Administrative Boards. This phenomena should not be all that surprising.
In the June, 1972 issue of Citrograph, "The Magazine of the Citrus
Industry,"	agricultural economists Leon Garoian and Kirby
Moulton wrote, "Certainly at the grower level we've seen the results of
low or nonexisting barriers [ to entry]. New growers can raise the required
57. (emphasis added)
quality of citrus and can join marketing associations. / Still, this issue
seems to be a sore point with the marketing cooperatives. As to whether
the level of enforcement of quality standards is adjusted during the
season, as changes in the weekly volume flow of oranges to the fresh market
might suggest, the orange growers we spoke to unanimously and emphatically
agreed that this does occur-.

In order to resolve the question, of intra-seasonal adjustment of the
enforcement level of quality standards it would be necessary to have data
on the proportion of the orange crop that is allocated to various grades
as the season progresses. Unfortunately, such data was not forthcoming
from the citrus industry. Vie were referred to the USDA and the California
Department of Agriculture. After a careful search of USDA publications
and consultation with USDA economists and crop statisticians at the
California Department of Agriculture, we have concluded that the necessary
data is not kept by these agencies.
Spokesmen for the citrus industry emphatically denied, to us, that
there is a cosmetic component involved in the quality standards as far as
insect related damage is concerned. Two grounds were cited in support
of this position. Richard Breuner, the President of the Industry Committee
on Citrus Additives and Pesticides, a citrus industry advisory and lobbying
organization, told us that insect related external damage is symptomatic
of lower interior quality. However, he was unable to cite any scientific
evidence to this effect and we have been unable to find any evidence which
would confirm Breuner's assertion. Measurements of the interior quality of
severely thrips scarred navel oranges, which we performed, failed to confirm
Breuner's assertion. (See discussion of the citrus thrips below.)
Don Avis, manager of pest control for Sunkist, also contended that any
cosmetic effects obtained from pest control are strictly the side benefits
of sound pest management practices necessary for the maintenance of fruit
yield and tree vigor and, furthermore, that fruit exposed to proper pest
control automatically meets the Sunkist quality standards with
regard to insect-related damage. On these grounds Avis denied
that the Sunkist quality standards contain any

tserationally effective cosmetic components. However, there are several
itrounds for doubting Che validity of this argument. (See discussion of
itrus thrips below.)
To understand the impact of the citrus quality standards on pesticide
ise> we dust now examine the nature of citrus insect pests and pest
tontrol in California.

Citrus is among the top ten food crops in terms of pesticide
application. 97 percent of all citrus acreage is treated on a
regular basis and citrus accounts for 2 percent of all
agricultural Insecticide use.62.in 1973 over twelve million
pounds of various pesticides were sprayed on California oranges,
according to the California State Department of Agriculture
Pesticide Use Report. The chemicals used included such toxic
substances as De 1 nav-d i oxath i on , Malathlon and Par ath i on . ^3-The
disproportionatly large amount of pesticide use in citrus is
reflected in the extremely high pest cofitrol costs for this
crop. For example, the pest/ccfntroI cost' (excluding control
costs for weeds and nematodes) was estimated a+ $160.00 an
acre for the 1973-74 growing season for navel oranges In
Central California^* The significance of this cost can be
appreciated by comparing ft to the net return for navel oranges
which ranges between $500.00 and $1,000.00 per acre,^'
There are Important variations in the number, type and
severity of citrus insect pests according to the growing region.
Southern California,
relative !y
fsf\nfiospitab Ie to a number of important citrus pests, most
notably the citrus thrips. In addition, the parasites of
certain citrus pests thrive In Southern California but not In
other growing regions. This is especially true of	AphytIs
melfnus DeBach, an effective parasite on the California red scale.
In the Central California	growing region the
citrus thrips, the citrus red mite., and the California red scale
are major pests. Other citrus pests are also morfl severe In

these regions. than i r. Southern C 
The integrated pest management approach attempts to take
the entire agro-ecosystem into account. The population levels
of insect pests are caretully monitored to determine whether
Sn economically significant infestation exists, and if so, when
and how it can be most effectively controlled. Use is made
pf cultural techniques, the introduction or predator and parasite
Insects, and the selection and use of chemicals materials on
foe basis of their long-term, as well as short-term, effects of
(the target pest and the entire agro-ecosystem.
In tab \ e s/^nr^oghams of citrus pest control for Central
Salifornta based upon the conventional chemical approach a-nd
toe integrated pest management approach are compared. According
o University of California citrusentomologist, C.E.Kennett,
tftrus red mite falls in the pest hierarchy because integrated
^est management consultants attach less Impotance to it than
!hemical control specialists. "Citrus thrips retains a high
osltion not so much because of its actual damage potential
nt more so because the arbitrary classification, by the
-Itrus industry of thrips feeding scars on the fruit as serious
amage, does not allow the supervised control specialist to
elegate it to a position of lesser Importance," Kennett comments J-
Richard D. Strong, Commodity Specialist, California Farm
Nreau Jederation, conducted a five year study of the comparative
ost of conventional and integrated control on Valencia oranges
i Tulare county. He reported that Integrated control programs
>st $45 per acre as compared to $101 per acre for conventional

Under Conventional Control
I . Citrus th r]ps
2.	Citrus red mite
3.	Red scale; Yellow scale
4.	Various Lepidoptera, e.g. Cutworms, Leafroilers
5.	Cottony-cushion scale
6.	Ci tr i co I a sea I e
7.	Brown soft scale
8.	Leafhoppers
9.	Orange dog, aphids, katydids
Under Integrated Management
1.	Ci+ricola scale	The rank of red scale in integrated
management is unknown at this time
2.	Citrus thrips	as the effectiveness of its natural
enemies, Aphyt i s me Ii nus and Comper i eII a
3.	Various Lepidoptera b i fasci ata are still under evaluation.*
4.	Ci trus red mite
5.	Ye I Iow sea Ie
6.	Cottony-cushion scale
7.	Brown soft scate
8.	Leafhoppers
9.	Orange dog, aphids, whiteflies
* The experience of the last few seasons indicates that red scale should be
ranked number one or two under both conventional and integrated pest

Pest Species Timing of Treatment	Pesti ci des
Convent IonaI Integrated Conventi onaI
Natural Enemies
Citrus thrips May-post petal Post petal guthion,
C i trus red
m 1 te
Red scale
ow scale
n soft
c row
Ci tr i co
Ka tyd i d
Fruit "iree
J e s f r o
e r
f a f
Sp r1ng
Spr i ng
Spr!n g
Summe r
Fa I I
Suit,me r
fa I
Wi nter
Spri ng
Summe r
Summe r
Fa i i
W i n te r
Sp rIng
Di methoate
Oe inav
PhosphamI don
1ntegrated Convent IonaI
Ryan i a*		
parath f on(0C) +
Ke i thane	NR ol
Om i te
Ch i orobenzl I ate
parath i on
ma i ath i on
parath i on +
ma I ath i on
NR oil
same as red
sea f e
carbary1 + NR olJ
NR oi I
parathI on(TC) 	
maiathion	none
(most disruptive
chem teal for citrus)
and cu tworms
parathI on
NR of I
parathI on
guth i on
parath1 on
D i b rom
carbary I + 	
NR ol i
pa rath I on (OC)
NR 415 oil
parath!on (OC) 	
8ac i I Iu s thu r inqlensis
parathI on (OC)
i neffecti ve
effective some
partially effective
ef feetJ ve
ef fectIve
I neffeet!ve
J neffeet Ive
1neff ect]ve

^*>4 1 Iota	raj- s d lima 	

$uni|i3c Cost per Arrc (Tnlacc County)
Tradii ioilnl TVst ami Disease Control
Major Pcsl Problem
Colt per Acre
C.ilniH Strips

Red and yellow srale
IJcla! fallorganopliosphate
Citrus red mile
Summerorg.-Miopliospbate or

lmlaiiiral< for llirips
Cilritola scale


ClllW Of IKS
Knllmilicidc for miles
Oranpc do;;

Hroi'ii soft srnlc:
Fall wliitcwnsltfungicide
I ,rafl toppers

Brown rot ami Scplnria spol


Integrated Pest and Disrose Control
Majnr Prst Problem
Sal ul ion
Cost per Acre"
Citrus limps
lltplirr threshold of economic damage

Cilrirol.1 w;iin
Single prcMoom organo|iliosp(iatc
i 18
Lrnlrol Irr
On llirips and mitesa number

of preiiacecus inscsrls plus diseases

Cut worms

Yi'Ilow mfd red scales
ParaiilcComperefta bifasdata
D rii ii snft ra!c;
PorasitrAphycux luteniui
Citric ml mites

Ot'anJ;f, tlop.

Oplinnnl, depriidinp on monitored


Thrips Matter season)
Petal to pnsthluotnbotanicals

(two applications at $9.00)
S 9
Brovn rot surf Srptorin spot
Fall whitewashfnnpicide
% 18

I 45
Pert aiul diwjw eon as pftrcentaiit* of total input costs	11.2%
DiflVicure between traditional and integrated programs	(56 per acre
Saviitc* as a reduction of ucl loss	38.3%
" 1 irM nvcrnirc'* fi>r ,r> vi>n.r |irril mnro olil prwlurprl .TOO tn DOO licM tone* PC Hero
Part'ii r.t S(v,' with yvnr !t>ii(r |'MV (Iiiirlirr with (mumjiuiI [iivi k]
NOTK: K*vi orangci500 lu "TOO baxc* wiUkltu lh.au 10071 pxekaul (jcit lane)

One of the worst chemical insecticides to use on oranges,
'from an integrated pest management viewpoint, Is m.alathion.
Malathion has extremely broad-spectrum toxicity and it's use
Its almost certain to result in the extermination of important
beneficial insects and subsequent secondary pest resurgence.
IHalathion is frequently used in combination with parathion for
the chemical control of red scale. While parathion alone
Is relatively selective in its action, malathion has the
advantage of a short re-entry time of 24 hours and a short
pre-harvest waiting period. A full page advertisement in the
larch, 1975 issue of C t trograph by American Cyanamid recommends
Cythion (Cyanamid's trade-name for malathion) for use on red
scale. The advertisement mentions the short re-entry and pre-harvest
periods required with malathion but fails to point-out the
hazards associated with the broad-spectrum nature of malathion.^*
In 1973 236,188 lbs. of malathion were sprayed on oranges
in California according to the California Pesticide Use Report.^'
If the use of malathion and malathion + parathion by California
orange growers is any measure of the continuance of the conventional
chemical control approach, then we must conclude that this
approach Is still alive and flourishing in California.

.i i cabti, i ntegrd itu
pest management, at least at its present state of development,
appears to confj ict with the goat of farm worker safety.
Parathion has been responsible for a large number of acute
poisoning incidents in farm workers and, as we have indicated,
it is probabiy responsible for a large amount of chronic illness
among farm workers. Malathion, on the other hand, with a
much shorter re-entry time, poses relatively little hazard
to worker health. This simply high-lights the need for
adequate estab/ishment and enforcement of worker health and
safety regulations, even under the roost idea circumstances
of pest management practice. It also underlines the
advantage of eliminating the need for pest control altogether
when it is required by unreasonably strict cosmetic quality
standards. Of course, when compared to the situatEons in
which chemical control calls for parathiontmaIathion, Integrated
pest management is superior on all counts. Furthermore,
If the use of some parathion reduces the need for pesticide
use in the long run, then the farm worker will also be the
beneficiary of integrated pest management.
Richard Norgaard, agricultural economist at the University of
California, Berkeley, has collected some useful data for comparing
growers who use integrated pest management and those who use
conventional chemical control 7^'Thirty-nine orange growers in the
San Joaquin Valley were interviewed. Seventeen were clients of
Independent pest management consultants, while twenty-two were
not. An additional eighteen growers in the coastal region

Df Southern California were interviewed. All of these growers
fere clients of independent pest management cons u'l tants.
Differences in the general characteristics of Central California
adopters and nonadopters seem apparent from the survey. On the
average adopters have a smaller percentage of acreage in crops
other than oranges; they have a lower quality of land as measured
by the Storie Soi I Index; they watered more often with less
later per application; they have fewer trees per acre and younger
proves. On the average adopters tend to be more educated, have
less contact with their farm advisor, and to read more technical
journals. They tend to have less total alsets and less total
ilebts and a higher asset to debt ratio then nonadopters. These
characteristics vary from grower to grower and this average
composite picture cannot be applied to any Individual grower.
Additionally, the differences between the average adopter and
nonadopter are not striking in all of these categories and it
cannot be concluded that a cause and effect relationship necessarily
exists between these characteristics and the decision to adopt
or not adopt Integrated pest management advise. Nevertheless,
this data is suggestive of what some of the actual factors might
When the nonadopters were asked to rank, in order of their
Preference, their sources of pest control information, 15 out
of 22 listed chemical company salesmen as their most preferred
source of information. Significantly, noneof the nonadopters
listed independent pest management consultants, even as a second,
third or fourth preference. Independent pest management consultants
tend toward integrated pest management, while chemical company
jUaesmen tend toward conventional chemical control, partly

iecause they receive a commission on the amount of their company's
Jnemicals which the grower purchases. This tendancy may be
>o'derated in some cases because the saleman may value his
long-term [relationship with his grower-customers above short
term commission income. I ri contrast, the Independent pest
Management consultant is paid a flat.-per acre fee by the grower
[for his professional advise and receives no commission from
ky chemical company. It is generally recognized that the
^dependent pest management consultants have been Intimately
(connected with the development and dispersion of Intergrated
pest management information in California.
Thus, in the case of oranges, we should be able to obtain
^ f a J r" y reliable estimate of the relative importance of the
-wo approaches to pest management5n California by looking
bt the relative proportion of growers who are and are not clients
j&f independent pest management consultants. In 1971, when this
Purvey was conducted, the total California orange acreage under
Independent pest management was 17,840 acres. The total California
Grange acreage in that year was about 230,000 acres. Thus, about
percent of California orange acreage was under independent pest
panagement while the reraaining ^rowers relied most heavily on the
advise of chemical company salesmen. That is, probably about
percent of the orange acreage was under integrated pest management
Kfh 1 l e the remainder was under conventional chemical Control.
The orange growers were also asked to rank reasons for utilizing
the type of advise they used. The adopters attributed about equal
height to: respect for and friendliness with the adviser; a lower
tost of pest control; and a lower risk of pest damage. The nonadopters
lighted personal respect and friendliness much higher than other

iactors and also listed "free advise ot the chemical company
Salesman"as the second most Important tactor. Th^se responses
*ouId seem to indicate that the nonadopter is being "sold"
Jiore on the personality of the salesman than on the effectiveness
of the pest control procedure. This conclusion is supporte.d
by the fact that most nonadopters, as well as adopters,
agreed that integrated pest management is cheaper and more
effective than conventional chemical control.
It Is difficult to know to what extent the attitudes of
adopters and nonadopters is the cause of their decision to
adopt or not adopt independent pest-management consultants
or the effect have having done so. In any case, grower attitude,
though probably very Important, may not be the only barrier to
the greater use of independent pest management consultants.
Another barrier is the economic difficulty of starting an
independent small business enterprise, especialiy when your
competitors in the market are large chemical corporations.

Additionally, a pool of highly trained applied inject ecologists
Capable of providing competent integrated pest management advise
^as not been developed. The divisions of biological control
at the Univeristy of California are capable of providing the
lece ssary expert; se to train such people, if the financial
^sources are available, but it seems unlikely that a coherent
Program f this type will develop while high barriers to
&ntry exist for independent pest management consultants.
''syne Wiliey has studied the problem of the dispersion of
Pest management information and has proposed policy measures
k increase the efficiency of grower adoption to integrated
3flst management.^* Another possible approach is the formation
Of cooperative pest management districts, such as the Fillmore
Citrus Protection District.
The data from the Norgaard survey yields the following
'nformation on the actual economic effects of independent
Pest management. The average net return per acre for San Jaoquin
Ya|ley adopters was $480.00 while for the nonadopters it was
1460.00. Obviously, the adopters of independent pest management

-  - nui i/tcji ouvl-i jciy effected financially. The adopters also
experienced a significantly lower average por acre pest control
cost than toe nonadopters, even when the pest management
consultant's fee.is added in. The average per acre expenditure
on Insecticides reported in the survey was $18.93 for the adopters
and $42.49 for the nonadopters over the years 1970 and I97i.
When Norgaard, Willey and Hall applied regression analysis to
the information from the survey results, the following estimates
were obtained for the profit accruing to the grower as a result
of adopting independent pest management. For 1970 the 90 percent
confidence interval for the average profit realized by adopters,
attributable to independent pest management, was -$14.44. to $153.03
per acre. For 1971 the interval was -$8.56 to $159.07 per acre.^'
The location <3f these confidence intervals indicates that adopters
could expect to have benefited from independent pest management.
The analysis also suggests that there is a likelihood that one-third
of the nonadopters in the sample would also have benefited from
using independent pest management if they were to become adopters.
The relatively favorable environment for natural pest control
of coastal Southern California was also confirmed by this survey.
When growers were asked to estimate the percent pest damage loss
If no pesticides were used, the San Joaquin adopters gave an
average estimate of 40 percent while the Southern California
adopters gave an average estimate of only 7 percent. The actual
level of pest damage loss reported by the two groups was 22
Percent and 2.5 percent respectively.

We should nor r cu i to men m uu a nuiomt instance in
citrus growers have taken advantage of the favorable environment
of coastal Southern California and integrated pest'management.
The Fillmore Citrus Protection District, in Ventura county, is
a citrus grower1s cooperative pest control association which
is responsible for the maintenance of insectories, for the- release
of citrus pest predator and parasite insects into the groves of
its member growers, and for the general citrus pest management
on the 8,000 acres of citrus orchards over which ft has jurisdiction.
The organization has been heavily involved with integrated pest
management and biological control since 1922. Red scale and black
scale are under relatively effective biological control in the
Fillmore District and the amount of chemical treatment used
for the control of other insect pests is relatively low. In
1973, a fairly typical year of the 8>000 acres in the Fillmore
District, 660 acres were treated for black' scale, 75 acres
were treated for red scale, 200 acres were treated for aphids,
800 acres were treated for citrus thrlps, and 2 100 acres were
treated with a medium oil spray designed to prevent the fall
and winter build-up of red spider mites, 77.
Currently, any pest control strategy, conventional chemical
or integrated management, must take cosmetic factors into account.
When we asked nine citrus growers to list insect pests which they
considered partially or wholly cosmetic eight listed citrus thrips
four listed citrus red mite, five listed red scale and one
listed worms. When asked to estimate the proportion of their
pest control cost that Is attributabIe to cosmetic pests, the
average estimate was 71 percent, with a range from 40 percent
to 100 percent. When asked If they were able to take full advantage

of integrated pest nwnagement under the existing quality standards,
eight of the nine said they were not?'For these growers, then,
there is a definite relationship between quality standards
which they consider cosmetic and their mode of insect pest
management, including the degree to which they must use chemical
pes t i c i de s .
Let us examine in detai I what is, perhaps, the most
archtypical case of a cosmetic pest in citrus--the citrus thrips.

If any major agricultural insect pest has gained a reputation
for causing essentially cosmetic damage, It is the citrus thrips,
Scirothrips citrus (Moulton). Yet, even in this case controversy
rages as to the nature of citrus thrips damage. In an evaluation
of whether, or to what extent, the citrus thrips should be
considered a cosmetic pest, a complexity of factors must be
taken into account, Including the nature of the damage caused
by the insect pest, the age and location of the citrus grove,
current and past environmental conditions, current and past
cultural and pest management procedures, prevai ling and projected
economic conditions and quality standard^. Many of these factors
have been discussed above and it is within this context that
we will examine the nature of citrus thrips damage.
The citrus thrips was first identified as an insect pest in
California in 1908 after a severe outbreak of thrips-reIated
damage to the Tulare county citrus crop. A 1918 report of
icitrus thrips by the United States Department of Agriculture^*
Provides us with information on the nature and extent of thrips damage
before the era of effective control. The report notes that severe
infestations of citrus thrips can cause stunted growth on nursery
stock and young groves. Severe Infestations can also result in
fruit drop and the splitting of fruit, as well as substantial
deformation of fruit. Certainly this type of damage must be
classified as noncosmetic. However, according to the 1918 USDA
report, such damage was relatively rare even when thrips were
'eft,totally uncontrolled. Fruit drop occurred only "in

xception a IIy severe infestations;" thrips were responsible for
on iy a small proportion of the usual fruit splitting,11 and
ubstantial malformation due to thrips occurred in from one
o six percent of the orange crop. This is not to dismiss the
act that certain groves at certain times suffered severe d-amage
fue to thrips. But, as the 1918 USDA report observed,
The most important damage resulting from the feeding of
thrips upon trees that have passed the period of rapid
growth is the lowering of the market value of the fruit
by unsightly scabbing and scarring. Although the eating
quality of the orange is not affected thereby, its commercial
grading is lowered considerably and the selling price
correspondingIy reduced.
Specifically, it appears that the typ i ca 1/ mature citrus grove
ts primarily susceptible only to the characteristic "stem-end
ring scarring of fruit which occurs without significant loss
of fruit yield or tree vigor. The extent to which such damage
constitutes an economic loss to the grower' depends not only
on the severity and Incidence of scarring, but on the level
and enforcement of quality standards. In the case of citrus
thrips scarring other than that which causes splitting or
substantial deformation of the fruit, applicable quality standards
Seem to fall into the cosmetic category.
In the severe thrips year of 1909 more than 80 percent of the
oranges In Tulare county were so damaged by citrus thrips as to
lower the grade of the fruit. In 1910 this figure fell to 63
percent even though no treatment procedure was available at the
time. In the fairly typical season of 1911 It was estimated that
the economic loss to San Joaquin Valley citrus growers due to
citrus thrips damage was In excess of $180,000. This would certatal^
be an incentive to control 61+rus thrips damage to below the

level of noncoimet i c damage.
A 1938 report by the University of California Agricultural
experiment S t a t i on^;ori cu r s with the 1918 USDA report regarding
the nature of thrips damage. As to tree damage it comments,
'Citrus nursery stock and young groves are often stunted and
lid I formed by thrips attack." On fruit damage the report states,
"The fruit Injury is rarely severe enough to cause dropping
or malformation, although some splitting is attributed to
excessive thrips attacks. Though the eating quality remains
unaffected by the surface scarring, the market grade Is definitely
lowered and the selling price reduced." According to the 1938
report thrips damage in the Central California growing region was
reduced to 3.8 percent of the fruit by a control procedure
involving a series of three sulfur treatments. With no treatments
46.6 percent of the fruit was affected by citrus thrips. What
proportion of this damage resulted in grade lowering and what
proportion resulted in more severe damage is not stated in the
Contemporary opinion on the nature of citrus thrips damage
Is mixed. Certainly, citrus thrips is still considered a major
insect pest in California. According to estimates by Ronald
M. Hawthorne, survey entomologist far the California Department
of Agriculture, citrus thrips accounted for $4,340,763 in crop
damage in 1970, the latest year for wh i ch f i gure.s_ are available.
This figure Is based upon estimates submitted by county Agricultural
o I
Commissioners and Is probab-ly not very fefl ablfeHowever, 11~ way
serve, at least, to ind^cate.the.order pf magnitude of the problem.

3	-	, , 	 ,,,000,/U WclS
s p e n1 1n 197 0 in attempts 1o control the citrus t h r i ps , bringing
the total direct economic loss attributed to citrus thrips to
about 7.3 million d oI I a rs.
In the Desert and Central California growing regions the
citrus thrips is considered a leading insect pest. In a 1.973
article on "Citrus Pest Management Studies in Tulare County,"
University of California citrus entomologists, D.L. Flaherty',.
J.B. Pehrson, and C.E. Kennett write, "Thrips are rated high as
Pests in Tulare county. The fruit must meet marketing standards:
too much scarred fruit results in heavy culling and reduced grade,
both influencing grower profits." The"l9/74-75 Treatment Guide
for California Citrus Crops," publsihed by the University of
California, recommends treatment for citrus thrips "to prevent
fruit scarring" implying that thrips damage is primarily cosmetic.
In a 1971 newspaper account Don Avis, manager of pest control
for Sunkist Growers, Inc. "acknowledges that the thrips damage
to citrus is mostly cosmetic in nature." "According to Everett
J. Dietrick, an independent pest management consultant with
extensive experience in citrus, "Examples of cosmetic pest
problems are the citrus thrips, which starts the pesticide
[treatments to deal with]
treadmill in citrus and creates the need for additionaI/up sets
U the natural biological controls of other citrus potential
Pests.	we mentioned above, citrus growers we have talked to
Consider citrus thrips a cosmetic pest. It was listed as
a major pest more times than any other insect and it was
designated either wholly or partially cosmetic by all of those
Kho I isted it. It was mentioned specifically by several growers
#s constituting a large part of cosmetic pest control costs and

as a barrier to more effective uti lization of integrated pest
On the other hand, Avis, in a recent communication with
us modified his position on the cosmetic nature of citrus thrips
damage, contending that it was not treated as a cosmetic pest
as such, but that cosmetic resuits were acheived as a side
benefit of generally sound pest management practices. 'This
Position was reiterated by William K. Quarles, Vice Preseident
for Government Affairs for Sunkist, who stated, "The current level
of pest control activity is necessary to maintain tree vigor,
as well as crop productivity at a level of economic necessity
for the grower. Most pest control activity has a side benefit
of improving the cosmetic appearance of the fruit, but there is
Jittle use of chemicals for purely cosmetic, purposes."
Dr. Glenn Carman, Professor of Entomology at the University
of California, Riverside, and a member of the Board of Directors
Pf the Industry Committee on Citrus Additives and Pesticides,
stated to us that cosmetic considerations play no role in
citrus thrips control. Carman did acknowledge that citrus thrips
pre generally treated on a prophylatic basis. That is, the orchard
is automatically sprayed at a given time of the season whether
jBny evidence of an economically s i gn i f i cant ci trus thrips infestation
i	+ 88.
Nlsts or not.
The actual operationally effective quality standards for
tftrus, those established and enforced by marketing cooperatives
loch as Sunkist and Pure Gold, do not contain expI Icit crIterJ a

with regard to citrus thrips scarring. For the "Sunkist" grade,
for example, only the vague specification of ."more than slightly
scarred" seems to be relevant to citrus thrips damage. It is
difficult to kn-ow, without additional information, how important
a role citrus thrips damage plays in grading decisions. A
current study by Louis Riehl, Professor of Entorhology at the
University of California, Riverside, gives some indication of the
relative importance of thrips scarring in the down-grading of
oranges . -'Ri eh I tabulated data for exterior damage and the
percentage of the crop packed out as "Sunkist", "Choice" ("Red Ball")
and juice grade, for crop samples from three different locations
using various p.3st management procedures. For our present
purposes the following aspect of this study is relevant: Jn
one location there was an extremely severe infestation of citrus
thrips resulting in relatively high levels of thrips scarring
in all three crop samples from that location. The percentage of
thrips damage for the three samples was 40 percent, 32 percent and
16 percent, while the percentage of the crop channeled to juice
*as 38 percent, 28 percent and 25 percent', respectively. In the
Case of the location from which all three samples had relatively
low levels of thrips damage, the percentage of the samples
channeled to juice was about 20 percent, in each case and was
independent of the level of thrips damage in each sample. The
fRiehl data suggests several interesting conclusions. First of all
Under	- prevailing pest control practices for citrus
thrips, which results in generally low levels of citrus thrips
damage, th.e major factor i.n the down-grading of citrus may be
Various types of cosmetic damage not related to insect feeding,
Such as mechanical scarring, or rind disorders. As is pointed

out in the 197 4 progress report of the integrated Pest
Management Project, "It appears that cullage due to non-eirthropod
damage may equal or surpass damage caused by arthropods. This
indicates that chemical treatments to control insects and/or
mites to eliminate damage and subsequent cullage may be wasted to
a large extent because often other factors, such as wind damage
and abrasions, may be the major cause of cullage."
However, this is not to say that there is no incentive
for growers to control for citrus thrips a+ the current level.
As the Riehl data also Indicates a relatively high incidence of
citrus thrips damage does result in substantially increased
allocation to juice and perhaps down-grading from "sunkist"
to "choi ce". Add i t i on a 1 Iy, the grower has no way of knowing,
in advance, how important thrips damage will be in the grading
process, since the enforcement level for citrus thrips damage
may vary from year to year depending on the total supply of
citrus and the relative degree of other kinds of damage. Since
citrus thrips damage, unlike scarring due to mechanical or
metabolic factors, is controI IabIe by the relatively simple
technique of chemical treatment, the grower may perceive it in
his interest to militantly treat for even the last vestige of
thrips damage. In fact, as Carman testified, prophylactic
treatment for citrus thrips is standard. Citrus entomologists
Flaherty, Pehrson and Kennett note that, "In many cases treatments
for thrips are overdone, with unwise choices of chemicals. In
their zeal to protect their fruit, growers frequently resort
to multiple treatments, some of- which inolude comtxLnati ons of
Insecticides. Often treatments are applied beyond the stage

of fruit development susceptible to thrips damage. Such treatment
programs trigger biological upsets and promote resistance. Costly
citrus red mite, brown soft scale, cottony cushion scale, or
yellow scale treatments are the likely aftermath of thrips
programs of multiple applications or combinations of insecticides."
More research is needed to determine exactly the role
citrus thrips damage plays in the grading of fruit. If a
realistic economic threshold level for thrips can be developed
it must sti I I be effectively communicated to growers by
credible sources of pest control information. The difficulty
With this approach is that the packing-h6use can instantly
change the effective economic threshold for thrips damage simply
by changing the level at which it enforces this aspect of the
quality standards. Furthermore, such a change is not readily
detectable without constant, after the fact monitoring of
quality standards enforcement procedures. As long as growers
are competing with each other to meet cosmetic quality standards
they are running a risk to assume an economic threshold level
'or citrus thrips greater than zero.
Since the authoritative opinion that citrus thrips damage has
fio effect on the eating quality of the fruit was challenged by
Richard Breuner, President of the Industry Committee on Citrus
Additives and Pesticides, we decided to explore this area
further. Two boxes of navel oranges were obtained from a
local grocery store. One ,box carried the Sunkist label and the
*ruit was marked "Sunkist" indicating top grade, while the other
tax was from the Valley Cove ranch and was marked "Organic".

...	.... ^y ^ i>uiu i ur	per pound. (However,
later in the season the price of the Valley Cove oranges came
down to 19 
S u n k i s t ^
Va I ley Cove5
Mechanical Damage
Other F\ i n d Disorders
Red Scale 1-3
Red Scale 4-10
Red Scale 11+

1 3


Li ght Thr i ps



Heavy Thrips



Clean Fruit

1 6


AC 1 D2

Va1 ley Cove

Samp 1 e

Aci d(meq)
Ac i d(meq)
% Sugar

1 .54
1 .22

1 .66
1 .52

1 .62
1 .42

1 .96
1 . 44

1 .36
1 .74


Va1 ley Cove

Samp 1 e
Orange Without Skind Whole Orange Without





1.	To determine cosmetic damage oranges were examined one to one.
2.	Soluble solids to acid was determined by the standard method as
described in the Bulletin of the California State Department of
Agriculture, except that refractWeindex measurements were substituted
for Brix hydrometer readings in the sugar determination.
3.	Moisture content was determined by weighing each orange in the
sample, placing it in a descicating oven at 180 degrees Farenheit
for 72 hours and weighing again.
4.	"Sunkist" oranges from Earlibest packing-house, Exeter, California,
purchased from the COOP super market, Berkeley, California, 12/17/74
at 29
minimum s + atutory standard.
This one measurement- does not prove that the quality of
Valley Cove oranges is generally higher than that of Sunkist
oranges. But it is at least one case in which the presence of
extensive thrips activity in an untreated grove did not adversely
affect the interior quality of the fruit. This is not surprising
to us since nobody, to our knowledge, has ever pointed to a
mechanism that would link insect teeding on the exterior layer
of the rind to interior variables. On the other hand, it is
clear that such factors as root-stock' variety, cultural practices
and climate will play a role in determining the final interior
quality of the fruit. It may be tempting for the grower to
place the blame for a fai lure in one of these areas on insect
feeding, but that doesn't make it so. Under the quality
criteria of the major citrus marketing cooperatives, a crop
of oranges with 50 percent thrips damage would not be likely to
be marketed under the top grade; in fact, it is likely that
a large proportion of such a crop would be allocated to juice.
It would be desirable to repeat the measurement of interior
quality on additional samples of thrips scarred oranges and
ciean oranges, but we have been unable to find additional samples
of thrips scarred oranges on the market, as top grade or even
choice grade oranges. The Valley Cove oranges, which were of superior
Interior quality, reached the market only because they were
marketed by the grower himself. For these oranges to have
reached the market by way of a major marketing cooperative they
would undoubtedly had to have been sprayed for thrips.

It is interesting to nolo that the Sunkist sample, whi le
practical ly free of thrips damage, contained a higher percentage
o'f oranges affected by red scale than would ordinarily be acceptable
under the "Sunkist" grade. 13 percent of the sample contained
eleven or more red scale whi le the specifications for the "Sunkist"
grade state that the fruit must be "practically free from scale."
These oranges were early season fruit from the Tulare county
growing area. Red scale has been particularly abundant in this
area despite intense and prolonged efforts at chemical control.
It has been particularly severe in recent years, partly because
of the occurence of relatively mild winters?^" The early season
supply of oranges comes predominantly from this region! 'thus, it
would seem reasonable to expect that the prevailing cosmetic
appearance of the oranges would determine the level at which
quality standards are enforced. That is, if a high percentage of ear
season oranges have substantia I red scale damage, the citrus
industry has a choice of either marketing such oranges as top
grade, or not marketing top grade oranges at all, thereby failing
to exploit the full economic demand for oranges. The former
alternative is followed in the case of severe freeze years, when
frost damaged oranges are marketed under the "Excel" label rather
than the "Sunkist" label. But this does not appear to be the
case with cosmetic damage such as red scale. Of course, a relaxation
in the enforcement level for red~scale might be accompanied by
a simultaneous tightening of some other, easier to control
quality variable, such as thrips damage. In mid-season, when the
industry is plagued by the chronic over-production problem, the
quality standards in regard to red scale might be more stringently
enforced, or they might be enforced differently between growing

regions. As we have indicated above, this is denied by spokesmen
for Sunkist, but is claimed to be the case by most growers we
have spoken to.
Sunkist states in regard to its quality standards that,
"These rules and regulations are necessary, not only to preserve
the legal rights of Sunkist Growers, Inc. in the Sunkist, Excel,
SK and Red Ball trademarks, but to assure a continuing reputation
of high quality which now attaches to them. This is the only
way in which these famous trademarks can be used to derive the
maximum benefits and returns for those marketing their fruit
through Sunkist Growers, Inc. In adhering to these rules the
strength and value of the trademarks will not only be maintained but
will continue to increase." Unfortunate Iythe current system
of quality standard enforcement, which attempts to maximize the
joint profits of growers, has negative consequences which propagate
throughout the society, and eventually have consequences for the
growers, themselves, as well as other groups. We can enumerate
some of these social costs in the case of citrus thrips.
As we have already indicated the necessity to control citrus
thrips results in a control cost of several million dollars
annually to California citrus growers. Additionally, the widespread
use of DOT for citrus thrips and later broad-spectrum organo-phosphvit*5
Insecticides, has resulted in the elevation, to serious pest
status, of a number of heretofore innocuous insects and mites.
The most notable example of this phenomena is the citrus red
mite, Panonychus cltri, which has become one of the leading citrus
pests In California, In large part"as a side-effect of citrus thrlc*

trea1rnorri"?k'9j''ifb le 5. indicates the recent increase of the citrus
red mile cis a pest species in California citrus. This increase
has paralleled the world-wide increase in the importance of
red spider mite problems as the use of synthetic organic
insecticides has increased. This problem is high-lighted by
a recent issue (March, 1975) of C i troqraph. This leading citrus
industry journal contains a full page advertisement, by American
Cyanamid, for its insecticide, Cygon. The advertisement is
head-lined, "FOR THRIPS CONTROL... USE CYGON" and goes on to say,
"When it comes to thrips on citrus, CYGON 267 Systemic Insecticide is
outstanding. It's been doing a superior job on both bearing and non-
bearing trees for many years and is now widely used for thrips
and aphids.". The generic name for Cygon is dimethoate. Dimethoate
is an organophosphate insecticide which, according to an evaluation
by von Rumker, is highly toxic to beneficial insects, including
bees. *1 n the same issue of C i troqrap h there is a full page
advertisment for Dupont's Lannate. As: a giant size cartoon
thrips falls dead to the bottom of the page, the advertisement
tells the reader, "This year, protect your trees--and harvest
more scar-free fruit. See your pest control advisor and spray
LANNATE this season." The generic name for Lannate is Methomyl.
Methomyl is a highly toxic organo-phosphate which also adversely
effects beneficial insects. No mention is made in either of the
advertisements of the possible adverse effects of using these
insecticides, such as the resurgence of citrus red mite and other
serious pests. We do not know to what extent these advertisments
effects grower pesticide use decisions, but they surely are a
reflection of what American Cyanamfd and Dupont salesmen are
telling their client growers- Guthion, Phosphamidon and malathion

* s
17 51 *9 <0 (I . it J 14 (} *1 17 U 19 r3
5 a B 3 w 8
. i a
1 I I
B   a  - H  B '
.1 3 S .B..J ..ja w q g pu*
 * *-
	B g ~
*i > n  ii t u . m m

arc also highly destructive to Amblyseius h i b i s c i , the preddceous
mite that, in the past, has/kept the citrus red mite under
effective biological control.
The citrus red mite is one of the most expensive citrus
pests to treat for. The estimated cost for citrus red mite
control in 1970 was $4,088,517. The estimated loss of crop
value, much of it attributable to cosmetic damage, was $ 4, 554,799 1 *
Citrus red mites are widely sprayed with chemical acaracides but
the populations are rapidly becoming resistant to many of these chemi
One of the leading acaracides now in use is Kelthane, manufactured
by Rohm and Haas. Kennett and Flaherty have pointed out that
the citrus red mite has developed a moderate degree of resistance
to Kelthane and as a consequence Kelthane is usually ineffective
against the mite in the spring when populations are increasing
at a rapid rate. On the other hand, the predator of the citrus
red mite, A. h i b i sc i has not developed resistance against
Ke I thane J^Rohm and Haas ran a two page, full color advertisement
for Kelthane in the March, 1975 issue of C i troqr aph which
features photographs of cosmetically perfect citrus fruit, but
doesn't inform the reader of Kelthane's limitations as an
effective acaracide.
As pesticide costs increase, the
financial burden made necessary by quality standards for
citrus thrips and the consequent resurgence of other pests,
looms as a growing social cost to citrus growers as a whole,
even as individuals they continue to strive to maximize their
returns through the control of cosmetic Insect pests.

and more effective enforcement of existing worker-safety
regulations would a meliorate this impact, a far simpler
approach would be to reduce or eliminate the use of insecticides
for cosmetic purposes. Their use against the citrus thrips
appears to be a case in point.
We have dealt with the citrus thrips and its potential as
a cosmetic pest in some detail. It should not be forgotten,
however, that many of the growers we spoke to also listed
the citrus red mite and red scale as at least partially cosmetic
pests. This is to say, there is some level of these pests
reached, a density which
which requires treatment, not because they/yet/constitut a
threat to the yield of fruit or to tree vigor, but because
the grower must meet cosmetic standards in regard to these pests.
While at higher population levels,
red scale and citrus red mite may be very serious noncosmetic
pests, the treatment for these pests at cosmetic levels may result
in the same types of negative impacts that we have discussed
in regard to citrus thrips. Moreover, it Is likely that
the same kind of effects that we have described for citrus thrips
occurs in other crops that are marketed as fresh produce under
strict cosmetic quality standards, such as other kinds of tree
f_r_y 11.

The current level of control for thrips damage almost
cerldinly consiitulos a threat io the welfare of farm workers.
It is difficult to determine the exact amount of pesticides
that are applied for the cosmetic control of citrus thrips,
since the California Pesticide Use Report does not report
pesticide use by pest category. The University of California
recommendations list parathion, DeInav-dioxathion, guthion,
p hosph am i don , and dimethoate for the treatment of citrus thrips!0*1-
These are all organo-phosphates with,high mammalian toxicities.
The $3 million spent annually for citrus thrips control
indicates that there is a substantial use of insecticides
against this pest. According to the California Pesticide
Use Report 23,319 lbs of DeInav-dioxathion, 35,580 lbs of guthfon,
16,581 lbs of phosphamidon, 109,629 lbs of dimethoate, and
194,061 lbs of parathion were sprayed on oranges In California
in I973l05-UndoubtedIy, a I arge amount of this material was
used for the treatment of citrus thrips. An attempt to explore
this question was made	in the survey conducted by Norgaard.
Unfortunately, the data on this question was sparse. The data
that does exist points to the use of organophosphates for thrips
control. Our own communication with growers and pest management
consultants also indicates that organophosphates are often used .
in this manner, especially as the more selective botanicals,
such as Ryania and Sabadilla have become increasingly difficult
to obta i n .
As we have indicated below (see section of the impact of
pesticide use) a substantial number of farm workers suffer from
chronic and acute health effects due to exposure to organo-phosphate
insecticides. While better standards for pes+lclde registration

There are ^overdI imaginabIo alternatives to the current
situolion w i I h ccnr. i dorat i on 1o the citrus thrips jproblem.
li may be possible 1o meet current quality standards regarding
citrus thrips damage with substantial reduction in the amount
of pest con1roI materials actually applied. As we have
indicated, the evidence suggests that an integrated control
program, as opposed to an intensive chemical control program,
results in a generally reduced application of insecticides as
well as a reduced over-all pest control cost. However, in regard
citrus thrips, the implementation of an effective integrated
control program is problematical. Integrated control consultants
would like to lower the-status of citrus thrips in the pest
heirarchy, or, whit amounts to the same, to increase the economic
threshold level for citrus thrips to some value greater than
zero. It this could be accomplished the outlook for the entire
integrated pest management of oranges would be improved. As ft
is, there are two barriers to this policy. First of all, both
the grower and the consultant may be uncertain as to . the
actual relationship between c?trus thrips damage and economic
return. Additionally, the actual effective quality standards
for citrus thrips, even if known with certainty, may be
unreasonably high frati an integrated pest management viewpoint.

This difficulty could be resolved through the establishment of
an explicit quality standard for citrus thrips damage, a standard
that lakes the requirements of integrated pest management into
Even under the current quality standards, integrated pest
management consultants have been able to successfully tolerate
a finite level of citrus thrips damage. It has also been shown
that citrus thrips can be managed through the use of cultural
techniques and relatively non-disruptive insecticides. It
is known that the presence of cover crops and the use of over-
head sprinkler systems for irrigation greatly reduces the
severity of citrus thrips infestations, even to levels below a
reasonable economic threshold. An experiment conducted in
Tulare county between 1970 and 1972 demonstrated that citrus
thrips can be effectively controlled through the use of such
botanical insecticides as Ryania and Sabidilla rather than much
more hazardous organo-phosphatesJ^^This, and other work, is
continuing as part of the integrated pest management program
at the University of CaIifornia.'7lHopefuIIy, a comprehensive
and effective strategy for the integrated control of citrus
thrips will eventually result from this research. However,
we should not loose sight of the fact that the current quality
standards with regard to citrus thrips damage constitutes a
barrier to the full development of an integrated pest management
program for oranges as well as an integrated control program
for citrus thrips itself.
Another alternative would be to simply not treat for thrips
In mature groves except against Infestations of such severity that

s vigor or y.i e I d is threatened. in the Fillmore Protection
-trict only about ten percent of the acreage is treated for
i n R
'rus thrips on the average. *1 f the level of enforcement of
ill ty standards were relaxed even moderately it might be
sib I e to eliminate the need for treatment against citrus
ips in this coastal growing area. In Tulare county, where
rus thrips are much more severe, it appears that the Valley

not believe that consumer attitutdes are the primary obstacle
altering existing quality standards. Consumer education
Daigns can be successfully waged if somebody is willing
carry them out. The Consumer Cooperative in Berkeley, California,
ajor retail food outlet in the city that is consumer owned
operated, recently featured cosmetically lower quality
iges, at I9
how much of the aggregate crop goes to juice and by-products.
The current system of allocation of' oranges was designed with
b single-minded intent of providing the growers with a modicum
'monopoly power to countervail the monopoly power that already
:isted in the input and retail sectors. The system was not
'signed to provide a means of economic expression on behalf of
pe stability of the agro-ecosystem, or on behalf of the health
L welfare of agricultural laborers. It is not astounding,
Sien, that the current system results in negative Impacts in
liese areas that go uncprrected and unheeded.
It does seem appropriate, therefore, that political agencies
'liose mandate if is to protect the quality of the environment,
Deluding the working environment of farm laborers, should
fifervene politically on behalf of those Interests in order to
Meliorate those negative impacts that exist as a result of
'"sufficient supervision by the economic and technical systems
^rrently operating in agriculture.
It also seems, to us, that it is time for a thorough-going
eevaluation of the entire system of agricultural production,
istribution and consumption. If the orange industry is any
ftdica+ion, the current system consists of a conglomeration of
ntagonistic and contradictory economic, technical, political
nd social relationships snd forces which, in no way, Is capable
f guaranteeing the maximization of social welfare.

1.	Gordon Rausser, "A Dynamic Econometric Mode] of the California-
Arizona Orange Industry," Doctoral Dissertation, University of.
California, Davis, 1971, P- 1-
2.	Walter Reuther, ed., THE CITRUS INDUSTRY, University of California,
1967, p. 80.
3.	Robert C. Rock and Robert G. Piatt, CALIFORNIA ORANGES, ACREAGE AND
University of CaJifornia, 1973, p- 1.
4.	Reuther, op. ci t., p. 69.
5.	Rausser, op. ci t., p. 139 -
6.	Reuther, op. cit., p. 69.
7.	Reuther, op. cit. , pp. 65~67-
8.	Anthony A. Prato, "An Econometric Study of Consumer Demands for
Fresh Oranges and Frozen Concentrated Orange Juice," Doctoral
Dissertation, University of California, Berkeley, 1969, p. 91.
9.	M. R. Godwin, "Agricultural Economics Report 6*t-2," Gainesville,
Florida, 19&3-
lO- Hoy Carman, "Demand for Oranges," CITROGRAPH, June, 1972, p. IV.
Printing Office, Washington, D. C., p. 90.
12.	James Youde, "Marketing Margins," C1TRCJRAPH, June, 1972, p. V.
13.	John A. Jamison, "Marketing Orders and Public Policy for the Fruit
14.	Reuther, og_. cit., p. 66.
15.	Rock, op. cit., p. 16.
16.	Rock, 0_. cit., Supplement.
17.	Hoy Carman and James Youde, "Alternative Tax Treatment of Orchard
Development Costs: Impacts on Producers, Middlemen, and Consumers,"
18.	Hoy Carman, "Tax Loss Agricultural Investments After Tax Reform,"
lg. Jeanne Dangerfield, "Sowing the Till" CONGRESSIONAL RECORD, May 16,
1973.	Vol. 119, No. 7^.

 Carman, "Demand for Oranges"
. P.S. George' and G.A.King, "Consumer Demand for Food Commodities
in the United States With Projections for 1980," Giannini
Foundation Monograph Number 26, March, 1971,
. CITRUS FRUITS, Statistical Reporting Service, United States
Department of Agriculture, Washington, D.C., 1949-1974.
. Rock, p. 26 .
. Leon Garoian and Kirby Moulton, "Structure of the California-
Arizona Market," CITROGRAPH, June 1972, p. VIII.
Curtis Anderson, "Structure of Sunkist," CITROGRAPH, June, 1972,
p . X.
!>. U.S. Congress, House Committee on the Judiciary, Subcommittee
on Monopolies and Commercial Law, Hearings, "Food Price
Investigation," 93rd Congress, 1st Session, June, July. I973,
Serial No. 15, p. 7 I I-715.
li. Anderson.,
IS. Linda Kravitz, WHO'S MINDING THE CO-OP?, Agribusiness Accountability
Project, March, 1974, Washington, D.C., p. 47.
I.	Anderson.
II.	Rausser, p. 139.
Garo i an .
12. Federal Marketing Orders No. 907 and No. 908.
'l. Garoian.
!5. F.M. Sherer, INDUSTRIAL PRICING, Rand McNally Publishing Co.,
Chicago, 1970, p. 3.
!6. Krav i tz , p . 38 .
'7. Garoian.
>8. Robert Rock, "Marketing Orders," CITROGRAPH, June, 1972, p. VII.
A^so see Rausser for a complete discussion of orange marketing
*9. Federal Marketing Orders Mo. 907 and No. 908.# FEDERAL REGISTER,
December 30, 1961.
'0. Interview with Stan Gillette, manager of Euclid Pure Gold
pack.i ng-h.o.use,
Fruit and	Vega + ahiA ^ nHjie-)-py ( National Commission on Food
Mar If t i nn Tftrh ni ral" Stu d v No. 4 . June. 1966. D.33I

. Federal Marketing Orders No. 907 and fio. 903.
. Rock, "Marketing Orders".
. For an analogous situation in cling peaches see Jamison,
p . 2 98.
. Floyd D. Shimomura, "A New Look At The California Marketing
Act of 1937,"
. Interview with Tom Karins, grower, Exetor, California
.	Interview with Robert Howie, August 6, 197^.
. S h i momu ra, p. 19 1.
. California Food and Agricultural Code, Sections 46951-46961.
. "Rules and Regulations Governing Fruit Packed For Marketing
By Sunkist Growers, Inc. Under its Trademarks Sunkist, Excel,
SK, and Red Ball and Under Association Non-Advertised Brands,"
Sunkist Growers, Inc., November I, 1967.
. David Pimentel, "Extent of Pesticide Use. Food Supply, and
Pollution," NEW YORK ENTOMOLOGICAL SOCIETY, March, 1973, .p. 21.
. George, p. 74.
. Everett J. Dietrick, Rineon-Vitova Insectaries, Inc., persona!
communication, August 19, 1974.
. Rausser, p. I 47.
. In Reuther, p. 69.
. Irving L. Eaks, "Rind Disorders of Oranges Lemons In California," in
SYrtPOSIUM, University of California, Rivcrr.idc. March, 1969, p. 1343-
. Interview with Sunkist, Pure Gold, and ICCAP representatives, September 2^,
. Ga roi an, p. I X.
. Of nine orange growers i nterv iewoil ''	"'no stated that the
enforcement of quality standard:'* A	d i ntraseasona I I y .
. V. Cerinka, a crop statistician wlffl '	1 ^ ' i f orn i a Dep artmen t
of Agiri culture conducted a caro'"1	us for 's
kTntf of dafa' and wa unable to M	,ho state Department
of Agriculture. 3[*7S

|f>0 . I ritervi ew 'with Richard Brpuner, August 6,. 19 7b.
,51. Interview with Don Avis, August 11, 197^*
52 ; P i mornte i , p . 15.
63.	PESTICIDE USE REPORT BY COMMODITY, 1973, State of California
Department of Food and Agriculture Agricultural Chemicals
and Feed, Sacramento, 1974, pp. 170-175.
64.	Communication from Don Avis, October 14, 1974.
. According to data provided by Norgaard, see ~]h n. below.
56.	Reuther, p. 81.
1974, p.87.
58.	C.E. Kennett, citrus entomologist. University of California,
Berkeley, personal communication.
59.	C.B. Huffaker, "The Ecology of Pesticide Interference with Insect
University of California," 1971, p. 99.
?0. C.E. Kennett, personal communication.
?|. Reported in Ray Smith, "What Is Being Done by the Universities,"
?2. CITROGRAPH, March, 1975, p. 175.
?3. PESTICIDE USE REPORT, 1973, p. 172.
74.	As part of an on-going study on pest rjianagement technology,
Professor Norgaard has surveyed growers on their attitudes
toward integrated and conventional pest management as well
as collected objective data on growers who have and have not
adopted independent pest management consultants. He has made
the data on orange growers available to us and we report
some of our observations based on this data.
75.	Wayne Wi I ley, "The Diffusion of Pest Management Information Technology,"
Doctorol Dissertation, University of California, Berkeley, 197*.
76.	Darwin Hall, Wayne Wi I ley* and Richard Norgaard, "Productivity
and Profit of Pest Control Techno 1ogyi in California Citrus,"
PROTECTION DISTRICT, December 31, 1973.
78.	A survey of nine California citrus growers, six located in the
Central California growing region and three in the Desert region.

'9. J. R. Hor-'-wri . "The Citrus Thrips," United States Department
of Ac r i c lTi YTTre Bulletin No. 616, February 14, 1918, Washing ton, D.C.
!0. Slanley F. Bailey, "Thrips of Economic Importance in Ca I i f oi >' > a , "
Circular 346, University of California Agricultural Experim^.t
Station, Berkeley, December, 1938, pp. 39-44.
31.	Ronald Hawthorne, "Estimated Damage and Crop Loss Caused By
Insect/Mite Pests, 1970," California Department of Agriculture,
Sacramento, November 6, 1972, Mr. Hawthorne informed us th.i'
his department is currently revamping its survey procedures
in order to obtain more accurate and reliable data and that
data on crop damage and cost of pest control costs will soon
be avai lable for post-1970 years.
32.	D.L. Flaherty, J.E.Pehrson and C.E. Kennett, "Citrus Pest
Management Studies in Tulare County," CALIFORNIA AGRI CULTURE! -
November, 1973, p. 4 .
33.	G.E. Carman, et. al., "1974-1975 Treatment Guide For Califor"*3
Citrus Crops," University of California Agricultural Experinc?"*t
Station, Riverside, 1974, p. 31.
84. Dick Lyneis, "If Yoti Rule Out Pesticide Use, You May Have To
Eat Worms," THE PRESS, Riverside, June 3, 1971.
55.	E.J. Dietrick, personal communication, August 19, 1974.
56.	Interview with Don Av i s f August 11, 1974.
57.	William K. Quarles, personal communication, December 19,
58.	Interview with Glenn Carman, September 2k, 1974.
Volume 2, September 1971, p. 350.
30. IPM PROGRESS REPORT, Volume 2, September, 1974, p. 88.
91.	F1ahe rty , p . 4 .
92.	"Official Method For. Determining Soluble Solids To Acid RaJ 
For Oranges and Grapefruit," Bulletin, California Departmer-
of Agriculture, 1949. We substituted refractive index for
Brix Hydrometer reading as a measure of sugar content.
93.	C.E. Kennett, personal communication.
94.	Rock, p. 2.
95.	"Rules and Regulations Governing Fruit Packed For Marketing
Sunkist Growers, Inc."

96.	C.E. Kennett ana u.L. Flaherty, "Spider Mites," Sa Joaquin
Valley Agricultural Research and Extension Center, Parlier,
September, 1974.
97.	R. F. Luck, R. van den Bosch, and R. Garcia, "Chemical Insect
Control, A Troubled Pest Management Strategy," submitted
98.	R.M. von Rumker, PESTICIDE MANUAL, RvR Consultants, Shawnee Mission,
Kansas, August, 1372, p. 2^k.
99 .
II00. Kennett, p. 20.
101.	Hawthorne.
102.	George P. Georghiou, "Resistance of Insects and Mites to
Insecticides and Acaracides and the Future of Pesticide
p. 118
103.	Kennett, pp. 20,26.
i'0 4. "Treatment Guide for California Citrus Crops," p. 31. -
:'05. PESTICIDE USE REPORT, 1973, p. 170-175.
106. Flaherty, p. 5.
08. Lorbeer.
09.	W. Leland Brown, personal communication, August , 1974.
10.	Observed at the Berkeley CO-OP, December 17, 1974.
11 . Observed on Bay Area television and Safeway Stores, December, 1974.
12. Quarles..
13 . Interview with Sunkist representatives, September 2^, 197^

California far exceeds all other states in the production
of tomatoes. In 1972 about 80 percent of the nation's
supply of processing tomatoes were produced in California.
Along with Florida, California -is the leading producer of
fresh tomatoes, each state supplying about 25 to 30 percent
of the national need. The production of fresh and processing
tomatoes are each very specialized activities; they are
essenitally different crops. For this reason, and because
the processing tomato is an outstanding example of how
cosmetic quality standards for processed produce operate,
we will restrict our attention to the processing tomato.
The harvested acreage for the processing tomato in California
has fluctuated significantIy from year +o year. For example
the harvested acreage declined from 231,000 acres in 1968
to 141,000 acres in 1970, but since 1970 acreage has been
steadily increasing at about 15,000 to 30,000 acres per
year. The overall trend in harvested acreage for the state
has been increasing in the post World War I I period. On
the other hand,for the United States, as a. whole there has
been a declining trend from the peak harvest year of 1946
of some 570,000 acres, to the 1973 harvest of 300,000 acres.
The yield per acre in California processing tomatoes has
doubled in this same period to its present level of about
24 tons per acre.1 There has been a sharp decline in the
number of processing tomato growers In California, from
about 4000 growers in 1964 to just over 600 in 1973.

Processing tomatoes are not grown throughout the state but are
concentrated in certain geographical sections. Eighteen of
California's 56 counties produce processing tomatoes, with the
mid-Central Valley counties of Yolo, Fresno, San Joaquin,
Sutter, Solano, San Benito and Sacramento being the major
producers. Yolo County leads the state with a 1972 production
of one mi I I ion tons, about one-sixth of the national total
producti on."

The canning and preserving of fresh produce is a highly
concentrated industry. I'n 1962 four firms, Campbell Soup,
M.J. Meinz, Del Monte, and Libby, McNeil & Libby, controlled
79.9 percent.of the market; together with an additional
four firms, Stokely-Van Camp, Gerber Products, Green Giant,
and DiGeorgio Fruit, they controlled 96.2 percent of the
market.'^ The Federal Trades Commission estimated that these
firms were able to gain $143,600.00 in profits in 1972	0
due to monopoly overcharge to consumers.
Del Monte Corporation is the world's largest canner of
fruits and vegetables, accounting for 16 percent of all
canned fruits and vegetables sold in the United States.
Del Monte enjoys a high degree of horizontal and verticle
integration. In terms of horizontal integration Del Monte
has a product line of more than 250	different items.
Geographically, Del Monte has sixty-six subsidiaries operating
in the United States and a score of foreign countries. Del
Monte's borad of directors includes representatives from
government (Shirley Temple BIack--President's Council on
Environmental Quality), research and education (Edwin W.
Carter  Stanf ord Research Institute, Gw i n R. Fo I I i s--S tan f ord
Research Institute, Chester 0. McCorkle, Jr. --Vice President,
University of California) and related food industries (Edwin
Carter--Sunray Co-op, Richard G. LandisGrocery Manufacturers
of America, Edwin L. Palmer-~PotIach Forests). Del monte's
verticle integration is acheived, In large part, through contractual
agreements with the growers of raw agricultural produce. Del
Monte has about 10,000 growers under contract.

fi a f i y i , i, ... _> i i in u i i a 111 r' u c u 11 i i i onds in The p roc e s _> * .. ^
tomato industry are attributable to the introduction of
processing tomato mechanization technoIogy. in recent years.
Thi<> technology was developed in California, in part as a
response to the elimination of cheap imported labor under
the defunct Bracero program, and it was implemented earliest
and most completely in California. It is for this reason
that the production of processing tomatoes has become more
concentrated in California in recent years. Additionally,
because of the large capital investment required for the
purchase of a tomato harvesting machine,/ana the specialized
technology required in the growing o4 machine-harvestabIe
tomatoes, processing tomato production has become an
increasingly specialized activity, wi+h fewer and fewer
growers with larger and larger farms. The labor force
required for the production of processing tomatoes has been
According to
greatly reduced. / Schmitz and Seckler 19,477,227 man-hours
of agricultural labor per year were displaced by the introduction
of the mechanical tomato harvester. They comment that,

"The process of adjustment is particularly painful for dsiplaced
tomato workers because the'y are highly immobile, mainly
because of limited occupational versatility. If a fraction
of the great economies generated by such technological
innovations as the harvester could be allocated out of
general taxes and applied to destroying the Tvicious
cycles of poverty' that afflict society, i rnmobi Iities--and
thus the social costs accompanying such innovations as the
tomato harvester--wouId be substantially reduced." Unfortunate]y,
no provision has been made for such compensation to
agricultural workers displaced by the tomato harvester.
The introduction of the tomato'harvester also changed
the nature of the work-force and the working conditions.
The work-force has changed from one characterized by
ma.le, Mexican, migratory labor to one characterized by
female, American, settled labor. The work now resembles
factory, assembly line type of labor rather than traditional
agr-l cultural field-work. Of particular Interest to us
is the fact that the harvesting mach.ine literally tears up
the entire tomato field and produces a great amount of
dust to which the workers are dtrectly exposed. It is
probable that this greatly increases the pesticide exposure
because a large perdentage of pesticide is probably released
from the foilage and primary exposure route becomes respiratory
rather than skin contact. The respiratory route is, of
course, a much more potent route of exposure to pesticides.
While no systematic studies have been conducted on this
subject, some evidence that we have cited above, clearly
suggests that chronic pesticide poisoning is widespread

uiany wi those workers are v/oifion
there is even more cause for concern because of the possibie
effects of chronic pesticide exposure on unborne children.
In i960, the latest year in which complete comparative
data is available, the California processing tomato crop
was allocated to the following uses:*
Canned Tomatoes	212,000 tons
Tomato Juice.......	211,000 tons
Chili Sauce		 25,000 tons
Tomato Puree	142,000 t.ons
Tomato Products	50,000 tons
Tomato Catsup	367,000 tons
Tomato Paste	801,000 tons
Tomato Sauce	414,000 tons
According to tyeI Zobel, State Agricultural Extension Advisor
in Yolo County, processing tomatoes are not distinquI shed
by use'until after they have been acquired by the processor,
thus all processing tomatoes must meet the most stringent
quality standards, even though, according to Zobel, ft "is
impossible for the consumer to detect insect parts or Insect
damage in the ground tomato products, such as tomato paste,
sauce, puree, and catsup. ^As we have indicated above, the
presence of insects of field origin In these products presents
no hea I th hazard.
Tomatos is one of the few crops in which there is
a state quality standard which refers explicitly to the
product meant for processing. Until 1968 the state quality
standards for processing tomatoes allowed up -to 10 percent
worm damage. However, the provision was ammended In 1968
to restrict worm damage to-2 percent.12

Processor contracts generally do not allow more than
one percent worm damage, and as we have indicated above
many contracts allow the buyer to reject shipments which
contain in excess of 5 percent worm damage, and, in some
cases, the buyer may demand literal iy zero worm damage.
The effect, in all these cases, is for the grower to feel
that he must have a zero tolerance level for insect damage
or insect parts. As one grower explained,
Standards for insect parts and damage can he graded.
It is the idea of establishing standards that are
designed to eliminate ALL insects that cause fear
+0 develop in the mind of the farmer.
We were under scheduled treatments and most of them
are bought out of fear of very low tolerances
established by processors through contracts.
Further reductions- in pesticide usage could be
obtained if there weren't the fear of the zero
tolerance for insect parts.
I know we never would have to spray tomatoes if
the rumor weren't to have zero tolerances on worms.
Russet mite is sprayed for only in unusual situations,
usually after treating for worms.
In addition to contractual obligations H. J. Heinz Company
sent the. foI Iowing letter to one tomato grower:
The 1971 tomato crop is in the process of being planted
and, although we h-ave had cool weather, the crop is
approximately three-fourths emerged. The early acreage
is progressing at a rather slow rate but appears to
have a satisfactory stand.
I am again making it my responsibility to remind you
that a continued emphasis on quality of raw product
with special attention to insect contamination, is
mandatory if California tomato products are to maintain
their high quality reputation and market acceptance.
The H.J. Heinz Company intend to protect their operations
duri.ng the coming harvest season by giving very close
scrutiny to any or all your loads where "State Inspection"
has indicated a measurable amount of worm contamination.
If contamination is confirmed by our own Inspection, such
loads may have to be returned to you. Presentation of
two consecutive loads containing I $ or more of worm
contamination may result In condemnation of the remainder

 ~< , ihu w e will have a full schedule for t h o
month of August and the early part of September; there;'ore,
I recommend th at a fwice-weekly inspection of all of the
tomato fields be curried out and a v i gorous' i nsect
prevention program be in effect at ali times. We_ do
not want i nsect c o n t a minatod tomatoes (emphasis in the
Obviously, growers who receive letters of this kind are
likely to be very apprehensive about having worms of
"a measurable amount". A "vigorous insect prevention
program...in effect at alt times" can only refer to
prophylactic spraying for worms whether they are present
or not.
The major insect pes+s In processing tomatoes.are
such t-ep j dop terous larvae as the green fruit worm, looper,
armyworn, pinworm, and tomato hornworm. Russet mite, flea
beetle, dark Iing;ground beetle and aphids are also commonly
found attacking tomatoes. Integrated pest management and
conventional chemical control depend on similar chemical
materials, with the exception that such broad-spectrum
chemicals as Lannate are avoided under integrated pest
management. However, under integrated pest management
there are generally fewer applications of the chemicals,
lower dosages of the chemicals used, and an avoidance of
combination applications.
In a recent study Charles Summers has compared the
effectiveness of conventional chemical control and integrated
pest management for processing tomatoes. Twenty-four fields
were divided into two groups, twelve conventional control
and twelve integrated management fields. Reports of every

chemical application and the reason for it were requested.
Frequently an insecticide was applied because the grower
"felt like it". At the time of u fungicide application
often an insecticide was added for good measure. Summers
reported that approximately 30 percent of the insecticides
were applied as fungicide/insecticide combinations.
The research team did their own grading which was
repeated by state inspectors. None of the loads were
rejected. There was no statistical difference between the
integrated pest management and the conventional chemical
control fields, in yield or damage. /At one point in the
study, when the integrated fields had received one treatment
and the conventional fields three, a group of cannery
representatives and growers were asked to compare two fields
In the Lodi area; they could detect no dIfferences between "
the conventional chemical control field and the integrated
pest management field.
Overall the integrated pest management fields received
58 percent less insecticides than the conventional chemical
control fields. The integrated fields received between zero
and three applications while the conventional fields received
between two and four applications. The pest management cost
per acre was significantly lower in the Integrated fields
than the conventional fields.
Obviously* the current qua Iity -standards- for processing
tomatoes can be met with a significant reduction In pesticide
use. However, as. we. liave. Indicated above (see page ),

test in the design of toxicity and Carcinogenicity tests. This approach
may be particularly important for compounds with potentially wide environ-
mental distribution."
Because of the enhancing effect of P.B., exposure to carcinogens should
be considered more dangerous to persons working with P.B. than to the general
population. A more detailed discussion of toxicity experiments with P.B.
and its potential hazards will be included in the section on. effects on the
general population.

Moreover, people are exposed to carcinogens all the time apart from work,
so a workplace exposure could combine with other exposures to produce
cancers. Hence cancer should be considered a possible hazard of corrtinued
work with pesticides although at the present level of information there
is no way to quantify the dose-response relationship.
In connection with the possible carcinogenicity of pesticides, the
use of piperonyl butoxide should be mentioned. Piperonyl butoxide (P.B.)
is a pesticide synergist used to enhance the effectiveness of pyrethrum
insecticides. Unfortunately P.B. can also have a synergistic effect with
certain carcinogenic substances. P.B. apparently functions by interfering
with the microsomal fraction enzymes which have the function of detoxifying
foreign substances. Certain of these enzymes metabolize carcinogens. If
this metabolism is interfered with exposure to the actual carcinogen, an
epoxide intermediate in the metabolism, could be prolonged and the carcino-
genic effect increased.
Some experiments on the carcinogenic enhancing effect of P.B. were
reported by Epstein et al.	In several experiments mice were fed
combinations of freons and P.B. control mice, and mice fed P.B. alone had
no tumors, but tumor incidence was much higher in mice that received both
a freon and P.B. It should be noted that in other tests freon by itself
was found to be a weak carcinogen, although it produced no tumors by itself
in this experiment. The reason that P.B. was tested with freon compounds
is that freon is often a propellant in sprays containing P.B. so that people
are exposed to both at the same time.
The authors conclusion is worthy of note. "This report of synergistic
toxicity and carcinogenicity between two widely used and unrelated compounds
suggests the need to consider interactions with-unrelated agents, not under

A final, but not unimportant, consideration in the study of the chronic
effects of pesticides on agricultural workers is the possible enhancement of
toxicity because of the generally poor health status of agricultural workers.
It is well known that agricultural workers as a group are among the poorest
people in the U.S., and suffer from the effects of poor housing, lack of
proper diet, unavailability of medical care, and lack of access to social
services. A 1971 study indicated that the average yearly income of persons
in California whose primary work was agricultural labor was $2,000.
This figure is far below themedia" for the U.S., and is also below the
poverty lp.vel. The same ".tudy indicated that the life expectancy for an
agricultural worker in California was 41 years. TKis is nearly 30 years
below the mean figure for the U.S. life expectancy is a reasonable measure
of the health status of a population, and the very low life expectancy for
farmworkers reflects many factors which contribute to poor health. Cet-
tainly it is indicative that farmworkers are likely to be less resistant
to the toxic effects of chemicals than the population at large.
Although evidence concerning the specific health problems is difficult
to come by, the results of a nutritional study of pre-school Chicano
migrant farm children in Colorado are very useful in this context.
Three hv^dred children were examined in the study in 1969. Biochemical
testing showed low vitamin A in over half the children, low alkaline
phosphatase level in 120 children, and low levels of serum protein in 28
children. Thus there was evidence of malnutrition in over hald the
children, and protein deficiency in about 10%. Findings of physical
examinations included high incidences of upper respiratory infection, low

i u b are one or me
obstacles to grower acceptance of integrated pest management.
Furthermore, relaxation of quality standards for processing
tomatoes would allow for an additional reduction in pesticide
use. According to Zobel, two-thirds of the current pesticide
use in processing tomatoes is for the tomato fruit worm,
which is essentially a cosmetic pest and does not threaten
tomato yields. The pesticide that is usually used is parathion.
In 1973,89,928 pounds of parathion was sprayed on 113,610 acres
of tomatoes in California, according to the California State
Department of Agriculture Pesticide Use Report. In addition
163,439 pounds of Methomyl (Lanna^e) and 256,488 pounds of
Carbaryl CSevin)" were used.3""* These latter two pesticides
are also often used in the treatment of worms on tomatoes.
there seems.to be no compelling reason why the cosmetic
quality standards in processing tomatoes should be as stringent
as they currently are, especially in the majority of cases
where the tolerance for insect parts or damage approaches
a zero tolerance. A more appropriate standard would certainly
be non-zero and perhaps somewhere between the current state
standard of 2 percent for processing tomatoes and 10 percent
for fresh tomatoes. it seems reasonable that quality standards
could be less stringent for those tomatoes that are allocated
to such products as paste, puree and catsup if some advanced
allocation method could be designed. For a relaxation of
quality standards for processing tomatoes the federal FDA
regulations for insect parts debris would have to be clarified
so that these regulations could not be used, by the processors
as a justification for demanding stringent cosmetic quality

standards for raw produce at the input end of processing.
The future of cosmetic quality standards for processing tomatoes
depends partly on the relative strength of tomato growers
and tomato processors. One of the effects of the mechanization
of tomato harvesting has been to reduce the number of growers
to the point where, in the first time in the industry there
appears to be a possibility that a strong grower bargaining
organization can be formed. Whether this actually takes
place and whether the growers place a priority on modifying
the quality standards remains to be seen.

1.	Gordon A. King, Edward. V. Jesse and Ben C. French, Economi c
T rends i_n t h e Processing Tocn a to Industry, University of California
Extension Service, August 23, 19 7 3
2.	CaI i f orn i a Tomato Grower, October, 1972, Febraury, 1973.
3.	King, op. c i t.
4* The Structure of Food Manufacturing, The National Commission
on Food Marketing, Technical Study Number 8, U.S. Government
Printing Office, Washington, D.C., 1966.
5.	Paul D. Scanlon, "FTC and Phase II: The McGovern Papers,"
Antitrust Law and Economi cs Rev i ew, Spring, 1972, pp. 33-36.
6.	A.V. Krebs, "Del Monte Corporation," Agribusiness Accountability
Project, Washington, D.C., December, 1973.
7.	William H. Fried1 and, Amy Barton and Robert Thomas, "De-stalking
the Wily Tomato," University of California, Santa Cruz, In
progress, p. 18.
8.	Andrew Schmitz and David Seckler, '!Mechanized Agriculture
and Social Welfare," American Journal of Agricultural Economics,
November., 1970, p. 576.
9.	Friedland, oj)_. clt., p. 50.
t0." King, o]3. ci t. , p. 124.
11.	Interview with Mel ZobeI, March, 1975
12.	Cal. Food and Agric, Code 40844-40845 (West, 1968)
13.	Charles Summers, personal communication.
14.	Interview with ZobeI.
15.	State of California Department of Food and Agriculture,
Pesti c i de Use Report By CommodIty, 1973, pp. 262-266.
16.	W.R. Bowen, et. al., "Pest and Disease Control Program
for Tomatoes,"Division of Agricultural Sciences, University
of CaIi forn i a, 1973


Draft of Final Report
Environmental Protection Agency Contract 68-01-2602
Prepared By
Robertvan den Boich
m* u% &m

2 95 4
The purpose of this report is to investigate the relationship
between cosmetic food quality standards and pesticide use, and
to detect any elements of the current system of laws, regulations
and practices which result in, or contribute to, negative
social Impacts, especially to the public health and environmental
quality. The relationship between quality standards and pesticide
use Is not simple and direct. It fs conditioned by all the
political, economic, lega:, technical and ecological factors
th?+, together, constitute the environment In which modern
agricultural production operates. In this report we have
attempted to describe these relevant factors and 1o evaluate
their Impact on the Issue under consideration.
The origin, history and current nature of the relevant
quality stancards Is examined and the meanino of a "cosmetic"
quality standard Is defined.
Pesticide use Is examined In terms of regulatory
procedures, agricultural practice, and Impacts on public health,
environmental quality and the stability of the agro-ecosystem.
Against this background specific crops are studied in
order to determine which are the relevant and sensitive factors
relating quality standards and pesticide use.

The two categories of quality standards that are relevant
to this study are those which pertain to the marketing of fresh
produce and those which pertain to freshproduce which Is sold as
on Input to processing firms. In either case formal, statutory
standards exist; however, for many crops the operationally
effective standards are those that are required by contractual
agreement between producers and buyers, or by the Joint agreement
of producers through marketing cooperatives and marketing orders.
In most cases this latter type of quality standard Ii much more
stringent than the statutory standard.
The establishment and enforcement of quality standards for
' <"7 :	p-y
fresh produce^l^ essentially a state function. The federal
Qjovernmen* does maintain a system of federal grades as a service
to buyers and sellers. According to the National Commission
on Food Marketing, "One of the principle functions uf Federal
grades for fresh fruits and vegetables Is to provide a bails
for describing products and, thereby, facilitate trade between
shipping point and terminal market firms."1 The National
Commission goes on to document the fact that {'federal grades do,
In fact, play a substantial role In commerce between the sellers
and buyers of fresh fruits and vegetables.* Nevertheless, jR de ra I
grades are not the same thing as mandatory quality standards.
The Federal Food, Drug, and Cosmetics Act specifically forbids
federal quality standards, providing that "no standard of
quality shall be established for fresh or dried fruits, (or;)-
fresh or dried vegetables."

California State Quality Standards
The California legislation regulating the quality of fresh fruits
and vegetables began to develop early in this century. Because of
progress in transportation, eastern markets were beginning to be accessible
to fresh California produce. Thousands of small growers and shippers
scrambled to serve these markets. It was in the interests of each grower
to reach the market first each season to reap the premium prices available
for early produce; invariably the competition resulted in many shipments
of insufficiently ripe produce. Further, the hope of each grower to sell
all his crop led to the swamping of the markets in peak season with produce
of marginal quality. Deceptive packaging, marking, and grading were used
to hide defective produce. Eastern wholesalers, retailers, and consumers
became cautious about California produce and prices began to fluctuate. To
protect consumers by eliminating the deceptive practices and thus to promote
the reputation and the business of the state's agricultural industry, both
Inside and outside the state, the California legislature established minimum
maturity, size, packing, and labeling standards for some of the major
California fruits and vegetables."*
The quality standardization laws have grown progressively more com-
prehensive and complex. They now apply to the same or shipment of all
fresh fruits and vegetables, packed or in bitlk.^ The standards are
established by the state legislature through the normal legislative
process. The standards have been amended and new standards have been

added often in the years since standards were first established.
Bills proposing amendmetits or add it ions to then; appear nearly
every legislative session. Limited temporary standards may
also be promulgated by the director of the Department of
Food and Agriculture.'' The director has the discretionary
power to change existing standards fora maximum of 120 days.
except those standards which rebate to the maturity or the
keeping quality of any commodity. His authority to set
emergency standards is conditional upon a finding by him
that the enforcement of the existing standard would: (1) be
difficult or impossible because of conflicting laws or orders
promulgated by the U. S. government; or (2) be difficult or
Impossible because of labor, material, or equipment scarcities;
or (3) result In serious waste of otherwise useful produce;
or (4) prevent utilization of new technological developments to
the disadvantage of producers.
The director also has the responsibility of supervising
the enforcement of the standards,*0 including the authority to
promulgate reasonable regulations to that end. The role of
the director anc of the Department is limited (although not by
law) to the training of Inspectors and general coordination;
the actual inspections are made by county Inspectors who work
under the supervision of the county agricultural commissioners.***
The inspections are performed at the production, wholesale,
and retail levels. The inspectors have the authority to enter,

Inspect, and take samples from any place or conveyance within
the county where the produce may be stored, produced, packed,
delivered, loaded, shipped, or sold. Major retailers to whom
we have talked state that the county Inspectors come nearly
every morning. Enforcement seems fairly uniform; retailers
report that one county's inspectors are tougher than another's
but the toughest inspector seems always to be the one which
deals with the retailer with whom one speaks.
Produce which !oes not meet the quality standards is subject
to legal abatement as a public nuisance if the deficiencies cannot
be corrected. Selling produce which does not meet any one of the
quality standards is a misdemeanor and the seller is also
civilly liable in an amount equal to the current market value
that the produce would have had if it had conformed to the
quality standa-ds.
The state legislature of California has enacted quality
standards which, apply, across the board, to all fruits and
vegetables. These criteria are rather broad and vague, providing
that arty fresh fruits or vegetables cannot be sold unless
90 percent, by weight, of the product.Is free of worms, mold,
decay, or any insect Injury which has penetrated the edible
portion, as determined by inspection of representative samples.***
Crops to which additional, speci f i-c qua 11 ty standards apply
are apples, apricots, artichokes, asparagus, avocados, berries,
broccoli, brussel sprouts, cantaloupes, carrots, cauliflower,
celery, cherries, citrus fruit, corn, dates, grapes and raisins,
lettuce, melons, nectarines, onions, peaches, pears, peas,

persimmons, plums and fresh prunes, pomegranets , potatoes,
quinces, sweet potatoes, tomatoes and walnuts.
Quality criteria for a few crops wilt serve to Illustrate the
nature of the state quality standards:
Oranges: The quality standards for California oranges forbids
the sale of oranges with "serious" damage from decay, drying,
freezing, or unhealed splits, bruises or punctures. "Serious"
damage, with the exception of damage caused by freezing, Is
defined cs damage to more than 10 percent of the oranges by
count fn any one container or bulk lot. Not more than 5 percent
of the damage can he due to any one cause. The tolerances are
more generous with regard to damage caused by freezing; up to
15 percent by ccunt of the oranges can be freeze damaged without
being considered unacceptable. The standards also ban the accelerated
cojoring of oranges nnt!! a level of maturity is reached, as
measured by the ratio of soluble solids 'essentially sugar) to
acid in the juice. The California quality standards tor oranges
do not explicitly refer to insect damage or Insect debris, or,
in general, to superficial damage to the rind that does not
penetrate into the Inferior of the fruit.
TomatoesThe quality standards for tomatoes provide that
not more than 10 percent by weight of the tomatoes fn any one
container or bulk lot may have pinworm damage to Individual
tomatoes which has penetrated beyond the tissue making up the
core of the tomatoe or insect damage which has penetrated or
damaged the flesh. The quality standards also prohibit "serious
damage" to more than 10 percent by weight of the tomatoes In
any one container or bulk lot due to freezing, blossom end rot.

mosaic, alkali spot, sunscald, bruises, catfaces, growth cracks
or other causes. Serious damage to any one tomatoe is damage
which causes a waste of 10 percent, by weight, of the Individual
Lettuce: The quality standards for head lettuce specify
that insect injury which affects leaves within the head (without
any definition as to what constitutes insect injury) makes a
head of lettuce unacceptable. Also prohibited are heads with
slime, decay, or rot which affects leaves within the head, heads
with seed stems developed to the point that they are apparent
upon external examination, and heads damaged by broken midribs,
bursting, tip burn, or freezing. Head lettuce Is also unacceptable
if it is- "leafy without head formation". Not more than 15
percent, by count, of the heads of lettuce in any one container
or bulk lot can have the prohibited detects. A further limitation
is that not more than 5 percent of the heads may be affected^
w i th decay or sIi me.
While it is difficult to evaluate quality standards except
on a crop-by-crop basis, It is safe to say that the California
state quality standards for fresh fruits and vegetables are, by
and large, directed at maintaining a minimum level of produce
quality and are concerned primarily with maturity and substantial
damage. One reason the standards have been set low Is that, as
statutes requiring legislative action for adoption or amendment,
they cannot be readily altered In resppnse' to emergency situations,
such as a sudden change In the weather, that might suddenly result
In a substantial reduction In the quality of a specific crop,
though the crop might still be basically wholesome.

Growers apparently have no great difficulty in meeting the
current standards as evidenced by the fact that for the fiscal
year 1972-73, 99.6 percent of the produce inspected In Fresno
County was passed. (Fresno County Is the largest agricultural
producer of any county in the United States, measured by the
gross value of sales. The value of its crops in 1972 were In
excess of $550,000 ,000.22
There has been some pressure to increaset+he level of the
state quality standards. For example, the Western Growers Association
which is a major shipping organization for California row crops,
has consistently lobbied for increased quality standards. According
to a Western Growers Association spokesman, the effect of Increased
quality standards Is to Improve the quality rep'itation of
California produce and to Improve the competitive position of
fresh produce relative to processed produce.
There may also be cuses in which statutory quality standards
are established for the purpose of eliminating a certain group
of producers from the market. We know of at least one case In
which this use of quality standards has been attempted. An
asparagus growers association tried to have a quality standard
passed that would ha,ve eliminated the growers that spec! 11 ze
In small diameter asparagus. This latter group comprises
26 percent of the growers having 13 percent of the market.
This attempt at using quality standards to secure economic power
was unsuccessful In California, thoughSuch a quality standard
was passed in the state of Washington.2^
The slow but steady Increase in the number and the stringency
of state quality standards may also contribute to a higher
barrier to entry for small producers, especially "organic"

producers, than would otherwise exist.
In recent years attempts have been made to transfer the
authority for establishing state quality standards from the
California state legislature to the State Director of Agriculture.
Such a change is contained in legislation proposed by the
Agricultural Council of California, a trade association of
agricultural marketing cooperatives. The legislation would
also combine Shipping Point Inspection, the voluntary Inspection
of produce to certify that It meets federal grades, arid
Standardization, the mandatory inspection of produce to ensure
that it meets state quality standards. The proponents of the
legislation argue that the current system Is too slow and
unresponsive to meet the needs of frbe volatile agricultural
market. Opponents of the legislation, which Included various
grower associotions and most of the state*s County Agricultural
Commissioners, argued that tho State Director of Agriculture
would be too susceptible to pressure from specific Interest- groups
that might not have the welfare of the entire agriculture Industry
at heart. The Agricultural Commissioners also argue that
Shipping Point Inspection and Standardization serve different,
and sometimes conflicting, functions, and, therefore, It would be
improper to combine these two activities. To date, this
legislation has not passed the state I eg IsIature .25*26
Lastly, It should be noted that state quality standards
are promulgated and enforced primarily In the Interest of the
producers and retailers, not the consuming public. Certainly, the consumer has an
Interest In a system of quality standards that guarantees a
minimum degree of maturity and who Iesomeness In fresh produce

available on the market. However, there may be situations In
which the estab I ishment of quality standards In the interest
of the producers works to the detriment of the consumers.
An Christina Rose, of the California Department of Consumer
Affairs testified in 1973,
In spite of the original purpose of commodity standards,
there are those who question whether their real benefit
accrues to the consumer in every instance.
They ask, for example, if consumers might not gladly
purchase fruit and vegetables for cooking purposes which
did not meet the stringent standards to which they have
become accustomed, but which could be purchased at a
reduced price consistent wl H) greater suppjy.
The price of a-food product is, in some measure, Influenced
by l"he quality and maturity standards applied to basic
agricultural commodities. To increase the price, one
may raise the standard acceptable cn a given commodity
and thus reduce the legal supply available on the market.
A substantial lowering of the standard wi II Increase the
supply aid may reduce the price, but will poss!b!y provide
to ths consumer .^ha t^-.'ou! d previously have been considered
an inferior product.
Consumer advocate, Roy Alper, has pointed out that even under the
current system, in which new state quality standards must be
approved by the legislature, there is relatively little Input
from the consur.er. T..is Is even more so for emergency quality
standards which are established Independently by the State
Director jf Agriculture.
In the final analysis, however, state quality standards
do not, in most cases, constitute the prime barrier to change
in regard to the production and distribution of fresh fruits
and vegetables. in most crops, other, more stringent quality
standards are operational, and It Is to these that we now turn.

Ma rKe11ng Urders
Under the provisions of federal and state marketing orders
producers may agree to establish and enforce quality standards
in addition to those specif.ied by state law. In 1968 there
were 49 marketing orders in effect under the federal provision
and 34 under the state of California. Of the 91 federal
and state marketing orders tabulated by the National Commission
on Food Marketing 76 percent contained provisions for grade,
siz, maturity, or other quality control. The general goal of
marketing orders is to increase the net return to the grower
by increasing market organization, by increasing consumer demand,
by regulating the flow of the produce to the market place, and,
In some cases, by restricting the total supply of the product.
The quality standards that are specified by marketing orders
are tied to thir general goal and related to one or more of
these mechanisms.
Marketing Cooperatives
Under the provisions of the Capper-VoI stead Act the producers
of a commodity may join together in a cooperaMve for the
i j
purpose of jointly marleting their product. Market Ing cooperatives
may establish and enforce their own quality standards. For
example, Ljnkist Growers, inc., the major marketing cooperative
for fresh California oranges maintains a set of quality standards
that Is far more comprehensive, specific and stNngent than the
regular state quality standards.-
Private Marketing Organizations
Likewise private marketing organizations may maintain their
own set of quality standards. For example Kenneth Dunham
of the giant produce marketing firm HeggbIade-MarguIeas-Tenneco

testified in 1973 that, "we have consistently strived with
the growers to upgrade the quality of their produce in order
to compete in the marketplace, domestic and international.
We are relentlessly hammering at the growers to put up the
finest package of fruit and vegetable possible. If you ask
why we have done this over the years are are continuing to
do so, it is done for the growers' saI vation--not to become
fat with profit, but to enable them to compete In the marketplace
wlTh their products, whether it is fruit, nuts or vegetables,
with a reasonable return to invest."
Reta i I Standards
The most comprehensive use of quality standards In fresh
produce occurs in the buying transactions of large supermarket
chains and fn the marketing of produce to these chains by
large marketing organizations. Buyers for retail supermarkets
have reported to us that cosmetic criteria are routinely used
In selecting produce. The buyers state that the standards they
use are not written down or codified In any way, but that they
are acquired from a buyer's experience as to what consumers will
or will not buy.
Crates or boxes or produce In which Insects are found
are often rejected summarI Iy. Buyers ma IntaIn that the
presence of one Insect often indicates that more may be present
In the shipment. It makes no difference whether the Insect Is
one which attacks the commodity on which it is found or whether
It Is merely an innocuous Insect that does not feed on the
commodity. Evidence of Insect damage Is treated almost as
seriously as the presence of Insects. Buyers said that
produce must be practically free of Insect damage to be saleable.

. w, u cjiso cosmetic criteria that are important
to buyers. Retail stores often like to stock two sizes of the
commodities for which there is a federal grading system
(e.g. apples, oranges, tomatoes, etc.) Buyers prefer to buy
the largest produce within a given grade. They have commented
that consumers are often uninformed as to what size indicates;
often smaller produce within a grade has better taste qualities
but consumers seem to equate maturity and quality with size.
Color is important for the same reasons; consumers equate good
c^lor with maturity and quality, according to the buyers.
The cosmetic criteria applied are flexible and vary with
the season and with the availability of produce. Buyers are
constantly in touch by phone and by personal visits with wholesale
brokers and with large growers who sell directly to retailers.
They actively compare the produce which is available and buying
decisions are made by balancing price with cosmetic quality,
assuming that the produce is acceptable on other grounds.
Don Dressier of the V/estern Growers Association concurred
with this viewpoint. He asserted that the use of agricultural
chemicals wc.s vital in obtaining produce with the "right color"
and for "blemish control". He thought that the cosmetic appearance
of fresh produce was a major factor in competition against
canned and frozen produce which have the advantage of picturesque
labels and elaborate packaging. According to Dressier, "fresh
produce Is Its own label". Dressier also contended that even
a small proportion of non-cosmetic produce appearing In the
market-place could spoil the consumer market for the entire
Industry. He was especially upset about the marketing of
f'organ I c crap" .

Not all produce people feel this way. According to Bill
Ramsey, supervisor for Mann Packing Company, which ships
25 percent of the nation's broccoli, it is the retail buyers,
no1 the consuming public, who demand the maintenance of
high cosmetic quality standards. According to Ramsey, a
reduction in the cosmetic quality standards would result
In a saving to both the grower, who would use less pesticides,
and the consumer. "Consumers buy the relative best so if
quality goes down, they would buy the relative best," said
D	36

McClure or the Bo+sford-Ke+chum advertising agency has designed
campaigns to educate consumers to the non-cosmetic aspects of
fresh produce. "One winter (artichoke growers) had a heavy frost
which turned the outside leaves of the chokes brown. They put
on a campaign which explained that frost-kissed artichokes really
have improved flavor. They turned frost damage into a maney-maker."
According to McClure, "Some of the new peach varieties have
been developed with an eye toward blush, that beautiful color
that I ^ associated with peaches. But- there is a problem with
them. They don't taste so good. I think people are ready for
a change. This growing emphasis on consumerism Is beginning
to counter 40 years of effort and promotion of the perfect produce."37
Nowhere In the vast system of quality standirds for fresh
produce is there a definition of a "cosmetic" quality standard.
However, commentators within and outside of the fresh produce
system have acknowTedged the existence of such a thing for
many years. At this point, based upo ; our review of quality
standards for fresh pr.oduce. It seems clear that a cosmetic
quality standard can be defined In the following manner: A
cosmetic quality standard Is a quality standard that refers to
superficial damage to the exterior appearance of the commodity,
damage wfiich does not significantly effect the taste, nutrition
or storage capacity of the produce. Of course, this report Is
concerned, more specifically, with cosmetic damage that Is
actually caused by, or Is attributed to. Insect pe&ts.

As it stands, of course, this definition !s exceedingly
vague. To have any meaning, it must be applied to specific
commodities in specific situations. However, from our review
of quality standards for fresh producewe can, at least, make
the following comments regarding the relative degree to which
quality standards incorporate a cosmetic component. The
regular statutory state quality standards refer, by and large,
to minimal maturity and non-cosmetic quality criteria. However,
vhere are some specifIcations which could be Interpreted as
cosmeti j, such as the "heading" requirement for heaJ lettuce.
The quality standards that are established and enforced by
marketing cooperatives and marketing orders often contain
substantial cosmetic components. The quality standards maintained
by Sunkist Growers, Inc., for example, contain numerous criteria
relaied strictly to the external, superficial appearance of the
fruit, final )y, at the retail level, cosmetic factors seem
to play the decisive role in decisions of the large supermarket
chains to buy or not to buy fresh produce. It Is assertod that
this reflects a "cosmetic consciousness" on behalf of the consumer.

The states play little p-rt In setting quality-
standards for processed foods. The first attempts
to regulate processed foods vrere made "by the states, but
the emergence of a national economy and the dominant
proportion of processed food shipped through interstate
commerce made national regulation necessary. State power
to regula/te products in interstate commerce was limited.
Conflicting regulations made It difficult for producers
to serve multi-state markets. FDCA now Is the dominant
force in regulating processed foods.
California's health codes illustrate the merger of
st=te and federal regulations. CalifDim44 does have one
state statute which controls the quality of food which can
be processed, but the standards are totally noncosmetic.
But .beyond this statute California has adopted the federal
standards. Section 265IO of the California Health and Safety
Code reads:
Definitions and standards of identity, quality, and
fill of container, and any amendments to such definitions
and standards, adopted pursuant to the federal act which
are in effect on the effective date of this division, or
which are adopted on or after that date, are the definitions
and standards of Identity, quality, and fill of container
in this state. The department' maycj by regulation,
establish definitions .and standards of identity, quality,
and fill of container for any food whether or not
such definitions and standards are in accordance with
the federal regualtions, when in its judgment such
action will promote honesty and fair dealing in the
interest of consumers....

Section 262 09 of the California Health and Safety
Code reads:
All good manufacturing practices regulations for any
food...and. any amendments to such regulations adopted
pursuant to the federal act which are In effect on the
effective date of this division, or which are adopted
on or after such date, are the good manufacturing
practices regulations of this state. If the department
fir.ds thst it is necessary for the protection of
consumers, it may adopt interpretive regulations as
necessary to define "current good manufacturing practice"
as used in this division.
California has not m^de significant use of the
provisions of section 26510 aad section 26209 authorizing
the California State Department of Health to adopt regulations
Independent of FDCA that are relevant to cosmetio standards.

The primary federal statute which regulates, inter alia, the quality
of processed food is the Federal Food, Drug, and Cosmetic Act (FDCA).
The primary purpose of the Act is to protect consumers from the dangers
of unwholesome food. In general, FDCA provides for the promulgation of
three types of food standards which an interstate processor must meet.
The three types of standards are identity, quality, and fill of container.
The Act prohibits interstate commerce foods which are "adulterated" or
"misbrindedand the receipt or delivery of such defective foods.
Almost all the civil and criminal violations with respect to food under
FDCA involved adulterated or mifbranded food, both of which are given
broad definitions. The Food and Drug Administration, (FDA), under the
Department of Health, Education, and Welfare, is responsible for ad-
ministering the major part of FDCA.
Section 402 of FDCA gives the Secretary of HEW the authority,
delegable to FDA, to "promulgate regulations fixing and establishing for
any food, ... a reasonable definition and .standard.of identity, a
reasonable standard of quality, and/or reasonable standard of fill of
container" excepting most fresh fruits and vegetables. FDA has Issued a
large number of regulations under the authority of section 402 covering
nearly all processed food. Most of these regulations are concerned with
mandatory standards of identity and fill of container to insure that
consumers receive what they reasonably expect they are buying.

FDA has also issued standards of quality for the major
processed foods, but very little of the standards* contents
are concerned with -f quality th=)t could be termed cosmetic.
The s;enera^ exception is the reouireroent that most processed
fruits cannot contain more than a stated percentage of
fruit (usually between 15 and 20 percent) blemished with
"scab, hail injury, scar tissue or other abnormality or
discoloration." But none of the quality standards, cosmetic
or noncosmetic, are mandatory; the processor may market
his product without penalty if only it is labeled as being
below the FDS standards. The objective is disclosure to
the consumer as to what he is buying, giving him the opportunity
to make decisions on quality without setting governmental
quality standards which are mandatory. Hende, the PDA has
chosen not to use the authority delegated by section U-02
to set minimum quality and cosmetic standards.
Rather, the FDS regulates the quality of processed
foods by promulgating regulations and tolerances which, in
part, define adulteration as the failure to meet certain
quality and cosmetic standards. Because FDCA prohibits the
introduction or delivery for introduction into interstate
commerce,or the receipt in Interstate commerqe.of adulterated
food,	it then.becomes a crime to use interstate
commerce to sell processed fonds which do not meet these
quality and cosmetic standards.
Certainly the definition of adulterated food comprehends
more than quality and cosmetic st^nd^rds. A food is also

adulterated> for example, If it bears or contains any
poisonous or deleterious and unsafe substance.	But
section ^02(a)(3) states that a food is adulterated if
"it consists in T-rhole or in part of any filthy, putrid, or
decomposed substance, or if it is otherwise unfit for fo.od."
The FDA and the courts have applied this section in such
a manner as to define and enforce	.standards
concerning insect debris which posei no threat to human
health whatsoever.
If section *f02(a)(3) were strictly construed and enforced,
it would ban all pnocessed food from Interstate commerce.
Even with the best of technology 611 defects in food cannot
be dLlmin^.ted. Technologists using only a microscope ean find
at least minute quantities of decomposed or moldy substances
in almost all processed food. These minute amounts make
the food "in part filthy and hence adulterated, even
though they pose no possible danajer to human health.
Further, the courts have uniformly held/4-02(a)(3) is
to be interpreted In the disjunctive,""*" that the phrase
"otherwise unfit for food" does not limit the phrase which
bans food in whole or in part which is filthy, putrid, or
decomposed. Thus food containing minute amounts of "filth"
could be found to be In violation of *K)2(aX3) even though
it is not unfit for food, and indeed, even it It is of
excellent quality. This Interpretation reads the word

"otherwise" out of the statute. But the courts have
accepted this interpretation, rationalizing that Congress
may have wanted to set a standard xvell above what was required
for the health of eonsumers. A high standard .r~-> would force
the industry to inspect strictly, thus reducing the probability
that dangerous food mi^ht reach the public even very
Thus the dilemma arises that, despite the clearly

undesirable result, the Act seems to ban from interstate
commerce essentially all processed foods. Section of
the Act allows FDA the discretion not to -prosecute minor
violations, but this only begs the question as to when
to prosecute because there is no guidance as to what
constitutes "minor" adulteration if all food Is to some
degree adulterated.
To reasonably limit the application of the Act,
FDA has established what are called defect action levels;
these are amounts of defects or filth which are allowed in
some catagories of food because such amounts are often
unavoidable. They are established at levels that present no
health hazard to humans. They do not represent an average
level of dtfects in processed foods, but are higher than
actual empirical averages of defects in food. Many of
*Lhe defect levels are tolerances as to the amount of Insect
debris allowed in fliod, and as insect debris poses no threat
to human health, these defect levels are minimum quality
standards which are purely cosmetic. If a product, assuming
the processor employs good manufacturing practices, Is
within the tolerances set by the defect levels, the FDA will
not take legal action against it.
Although defects in food which are within the defect
action levels are not hazardous to	humans,
health is not a criteria used In established the defect
levels. They are based instead upon the processing industry#s

technological ability to remove, through whatever means,
food defects. The levels are subject to change as technology
or new inf or/sat ion develops. The FDA states that the defect
levels hgve be?n and will continue to be reduced and that the
food industry has a continuing Responsibility to minimize
even innocuous defects In food.
The courts have accepted the defect levels as	-having
the force of law. FDCA does not provide authority for FDA
to set admininstrative tolerances for filth, and one court,
although basing its decision on an FDA defect level,
questioned the scope of the validity of the defect levels*
But a large majority of courts accept the defect levels as
dispositive. The courts recognize that they do not have
the expertise to know what standard of food quality is
necessary for the public health nor what performance can be
expected frcTi the processing industry. As a minimum, recent
decisions show that courts accept the defect levels but
irrply that they are not bound by them.
The FDA has not adopted defect levels for all processed
foods. When a processed food is prosecuted as adulterated
that does not have an action defect level, the courts interpret
the words "filth, purtid, or decomposed substance" in their
ordinary rather than any scientific meaning.60/ The courts
have emphasized that the sensibilities and esthetic feelings
of consumers are protected by the Act. Without defect
levels to guide t;hem, courts often look to expert witnesses

to inform them as to what levels of defects are "usual" or "unavoidable."
If the contamination is "unavoidable," courts are likely to label the defect
as de minimis, below the concern of the law, and find no adulteration.
This approach implicitly adopts the same criteria the FDA uses to establish
its defect levels.
But being beyond the narrow objection of de minimis, Insect fragments
in other than infinitesimal amount are "filth"^ even without a danger to
health. This would b?: particularly trae for any visible insect fragments.
Nearly all the FDA defect levels are set at amounts of filth indiscernible
to the human eye, and to our knowledge, there exist no cases that hold
that visible insect debris in processed food is not adulterated regardless
of whether It is in a category to which a defect level has been assigned.
Hence by recognizing consumer sensibilities and by adopting a meaning of
filth vhlcU uueu not include any element of potential human harm, courts
have interpreted FDCA as including cosmetic quality standards with respect
to insect debris.
There are circumstances under which food which is within the defect
action levels vrould still be in violation of FDCA. Section 402(a)(4)
states that a product is adulterated "if it has been prepared, packed, or
held under insanitary conditions, whereby it may have become contaminated
with filth, or whereby it may have been rendered injurious to health."^
To constitute a violation under 402(a)(4), the court in Berger v. United
j>tates held that it is sufficient that the manufacturing conditions "would
vith reasonable possibility result in contamination."^ A "mere possi-
bility" of contamination is not enough, but it is certainly not necessary

that the food actually be contaminated. The focus of section 402(a)(4)
is on the conditions of manufacturers; the objective is to prevent
adulterated food by condemning the conditions under which it could be
In 1969 the FDA promulgated regulations applicable to the entire
food industry, called good manufacturing practice (GMP) regulations.
FDA's objective was to provide detailed standards as to vh&t is and what is
not a violation of section 402(r)(4). The regulations specify proper
practices relating to plant construction and design, the surrounding
grounds, the equipment and utensils, sanitary facilities and their control,
maintenance, animal and vermin control, raw material handling, packaging,
and personnel work procedures. The FDA intended that the GMP regulations
have the force of law and that a violation of one of them would be a viola-
tion of section 402(a)(4). Immediately after they were issued, industry
lawyers scrambled to argue that the FDA had no authority to endow the
regulations with legislative status. They maintained that the regulations
could at most be guidelines for the Industry which were not binding ou
. 69
the courts.

...w i un nds made it clear that violations of the GMP
regulations wi I I bring prosecution and the FDA has a high
percentage of convictions under section 402(a)(4) J But
the courts response to the GMP regulations has not been clear.
Courts have acknowledged the existence of the GMP regulations,
but have grumbled that they are generally inadequate because
they are too vague.71 Generally courts have not mentioned the
regulations in their opinions, but have continued to apply
Merger "reasonable possibility" test.
A major deficiency in the FDA approach to insect contamination
of processed food is the failure to distinquish the origin
of the insect. While Insects whose origin is the processing
plant may be associated with unhygienic conditions in the
plant, insects which originate in the field as qgr1cuItura I
pests (or, for that matter, as beneficial insects) pose
no danger to human health directly or indirectly. Nevertheless,
the notion that any insect part contamination Is associated
with a risk to human health persists, possibly because of
the fact that FDA regulates this area. For example, we were
told by an entomologist with the California Department of
Agriculture Feed and Chemical Division, the state agency that
supervises pesticide use, that fruit which contained even
eating damage from Lepidopterous insects posed a threat to
human health because the digestive enzymnes left behind might
be toxic. Because of such statements, we have conducted a
rovlew of the literature on the health hazards of insects.
'oalth Hazards of Insects In Food
Apparently from man's antiquity insects and other small
''vertebrates have been consumed either Intentionally as a

food source, or unintentionally, hidden from view, in the
fruits, seeds and other foods gathered as nutrients. In the
early Greek writings of Aristotle the use of Cicada as food
were described along with notes on which stages of the life
cycle were the choicest. The range of insects consumed as
food is extensive and includes insects from all major orders
including such loathsome forms, by Western standards, as the
head lice. The major criteria in the use of insects and
related \ nvertebrates as a food source appears prl-marily
related to their abundance and the ease of capture and/or
the large size of such individual Insects as aquatic beetles
and bugs; thus even rather small insects +hat occur in great
numbers in time and place such as the ephedrid flies of brine
lakes were harvested in great numbers by North American Indian
tribes as were collections of field I ocus t?^'^"\3oden he I mer
has extensively reviewed the use of insects as food by peoples
of the world and points out that in some human populations
insects constitute a substantial source of nourishment. The
natives of tropical Africa have used termites extensively as
food and these dried or fried insects can be found in the markets
for sale. The desert locust is another Insect prized as a food
In Africa and can be found for sale in Moroccan markets also.
Both of these species because of behavioral traits, swarming
In the case of the locust and colonies In the case of the termites^
can be captured in large numbers and therefore contribute
significantly although transiently to the food supply of
these people.76 it must be assumed that since insects have been
usod for food so widely that they are of nutritive value;
howover, only a relatively few studies have been conducted In

i nis regard. Tjhon analyzed fried termites and found a value
of over 500 calories, The protein and fat content were both
high, surpassing other animal foods and approaching that of
ground nuts. Lapp and Rohmen calculated that the desert
focust sold in Moroccan markets had a protein content averaging
about 46 percent. Bodenheimer points out that insects
were particularly important in human populations where large
animal protein was scarce end that these insects formed a
valuable addition of protein and fat as well as certain minerals,
vI tarn i ns and satts.
The long history of human ingestion of Insects suggests
that this food source is non-toxic to humans. Mills and Pepper
conducted a small series of experiments on 4 human volunteers
by feeding them cooked oatmeal containing adults, larvae and
cast skins, eggs and excretement of f"he flour beetle..
T r i b o! 1 u itr contusum. these workers noted no obvious III effects
and concluded that accidental swallowing of the beetles cooked
fn oatmeal caused no injury to humans/^
Certain insects do serve as intermediate hosts of
various parasites which, when consumed with the Insects may
continue to develop in humans. For example, the spiny headed
worms, AcanthocephaI a, utilize as intermediate hosts various
beetles and other Insect species. On rare occasslons these
worms have been reported as parasites in humans. Certain
tapeworms of dogs and rodents which utilize flees and other
insects as Intermediate hosts have been reported In man,
particularly in children.	nana which is capable of undergo!ng
autoinfectI on In humans and is a normal parasite of rodents

may be transmitted on occasion to humans by the grain beetle
Tr i bo Ii um spp. which serves as an excel lent intermediate host
In the laboratory. Contact between rodents Infected wfth
tapeworms and grain or grain products infested with the
beetles would be the potential route of infection. Treatment
for these tapeworm infections are relatively safe and constitute
no serious threat to health. Adiitionat ly, cooking of the
insects, which often takes place in processing, would eliminate
the threat of transmiss i o".
Ren Taylor is a forensic toxTcologlst who has been studying
the use of insect fas food for several years. The only
evidence of toxicity that Taylor has found is In regard to
cockroaches. People chronically exposed to cockroaches
develop allergies. However, there is no evidence of any
allergies td insect parts In processed fc-ju, Taylor has
never heard of any toxin problem from 'nsects and thinks he
would have seen such information if It were available.
Taylor feels that the level of Insect parts could be raised
considerably without any problem for health. Similarly,
according to Alex McCormick, compliance officer for the
FDA, while bird and rodent debris const'tute a threat *3
human health, insect debris does not, with the possible
exception of cockroach debris.
Insect damage and insect debris on produce used as an
Input for processing, then, would appear to be purely a
cosmetic Issue and quality standards In reference to such

damage or debris would have to be classified as cosmetic
quality standards. The FDA has acknowledged the cosmetic
nature of its standards in regard to field insects. The FDA
has also recognized that "it is not now possible and never
has been possible to grow in open fields, harvest and process
crops that are totally free from natural defects." The FDA
has pointed out that if natural defects were not allowed
the consequence would be an increased use of chemical substances
In an attempt to control insects and other natural contaminants,
and ;hat these substances pose a Threat to the health of farm
workers, the environment and the consumer?-* Yet, by falling
to distinquish between insects of plant origin and field
origin and by lowering defect action levels as technology
permits, without regard to the actual health hazard, the
current FDA requlatlons already serve as a rationale for
processors to demand essentially Insect-free produce from
growers, whether or not the actual motive of the processor
is related to the FDA regulations. For example, according
to Stanley D. Ray, Agricultural Corrui.i ss I oner for the county
of Modesto, where food processing Is a major Industry,
"The contracting system between growers and processors does
have some affect on pest contamination and the related use
of pesticides. The requirements, however, are dictated by
strict Pure food and Drug and USDA regulations, and growers
and processors cannot afford to have their commodities condemned
because of Insect contamlnatI on."^Add 111 onaI Iy James Bell,
Executive Vice-President of the Canner's League of California,
in organization which represents many marketing cooperatives
ind small Independent canneries, told us that contamination

by field insects and insect damage was a major problem for
ceiriners because of "consumer standards and behavior and
FDA standards. "
There is no way in which the FDA regulations can be
directly translated into insect-re Iated quality standards
for the grower. Nor are/the fresh produce standards followed
In the case of produce that is used as an input for processing.
The most important quality standards are those that are
specified in contractual agreements between processors and
growers. The quality standards for insect debris and Insect
damage specified in such contracts is usually much more
stringent than s-fate quality standards for fresh produce.
A 1971 contract form from the Canners League of California
for tomatofts specifics that the buyer may reject the entire
shipment if more than  percent of the tomatoes contain
any worm or worm damage that penetrates the flesh of the
tomatoe. A Hunt-Wesson Foods, Inc. tomatoe contract specifies
that the buyer may reject the entire shipment If any worms or
worm damage or Insect infestation is present in the flesh,
core or stem cavl+y of any tomato . A Canners League contract
for peaches jays that the buyer may require peaches to be
free of worms, worm damage, parasite or Insect damage, San
Jose scale and may reject the entire shipment If there
Is more than one percent wormy or worm damaged peaches.
Stokely-Van Camp, Inc. contracts for frozen vegetables
specifically require that produce be delivered, "In the condition
ffbyer may require. In order to meet the tolerances permitted by

und requirements of the United States Food and Drug Administration
and in all respects conforming to any applicable Pure Food &
Drug requirements of the state or political subdivision
therof in which this contract is to be performed and the crop Is
to be processed". From this passage one might get the
Impression that FDA places specific^requirements on produce
at the point of delivery to the processor, which Is not the
case. It can only refer to the Exceedingly vague requIrement
that produce from the grower does not contain a level of
Insect contamination which would result In the processor
exceeding the FDA defect action level for Insect debris
or GMP. A 1974 Stokely-Van Camp, con tract for -frozen spinach
contains the additional, appended provisions that, "Any
lot of spinach Infested with insects including worms or
 or seriously damaged by any of the above defects
(which include? insect damage effecting an area of one
square Inch on leaf or stem) beyond the level normally
accepted in the frozen spinach industry, may be rejected
by Buyer "
These strlngen't contractual standards for insect debris
and Insect damage- may be justifiable, after the fact, on the
basis of FDA regulations, but there is no reason to believe
that these standards are primarily motivated, In the first
place, by the FDA regulations. The FDA regulations are
based upon "good industry practice" not vise versa. The
other major reason given by industry spokesmen for the tough
Insect quality standards Is consumer attitudes. It Is asserted
that consumers demand absolutely perfect cosmetic produce and
would not stand for processed produce which showed signs

of insect damage or contained Insects or Insect parts. There
Is undoubtedly a large measure of truth to this assertion.,
although systematic studies of consumer attitudes toward insect
contamination are non-existent. Additionally, It should
be noted that many of the Insects which are so strictly controlled
by the contractual standards would not be detectable In many
forms of processed food even If they were present at levels
far In excess of current contractual levels, except, of
course, by careful microscopic examination.
It should also be asked to what extent current attitudes
of consumers are Indigenous to human nature and to what extent
they are the result of promotional activities by the food
Industry itself. The United States Department of Agriculture
estimates thjt in fiscal year 1962 l>200 agricultural groups
In the United States spent a total of $86 million to promote
agricultural products. Among all California marketing orders
advectlsing and promotion costs averaged about 69 percent of
total expenditures in the decade 1960-70John A. Jamison
notes that, "Growers have generally been very optimistic about
advertising and promotion through-out the post-World War (I
history of marketing orders. Demand expansion programs have
seldom been met by the vocal opposition that has accompanied
quantity control programs. The very fact that the results
of these promotional efforts can seldom be measured seems to
encourage rather than discourage their use. ..the great faith
of producers In such programs seems to be based principally
on two premises: (I) that these efforts must be beneficial
because advertising Is so widely practiced and supported In

the genera! economy; (2) that it Is necessary to advertise
merely to defend your commodity against all the competing
commodities that are doing it." In addition to these
promotional activities there are the promotional activities
carried out by brand-narne processors. As Jamison intimates,
all these various promotional activities may not be effective,
some of them may be counter-productive to others, especially
In the case of product advertising v.s. brand-name advertising,
a^d, In genera', the overali effect of this promotional
atmoshpere may be to raise the over-all quality expectations
of the consumer for all produce.
Consumer attitudes toward insects in fooo may also
be related to more i>asic cultural values. In a review of
"entomophobI a", the Irrational fear cf insects, Helga and
William Oikowski comment,
A review ^f the literature on entomophobia and personal
discussions with a psychiatrist have confirmed our impression
that the basic syndrome is one of fear of contamination,
penetration, and/or filth. We find people who take a
'disinfectant' or sanitizing approach to gardening. In some
cases It seems to be the germ theory gone astray,...
Thir general attitude may be extended to life generally,
the natural world is feared, it is repulsive, dirty....
These attitudes are not at all helped by government
regulations that refer to insect parts as filth, lumping
them together with.rodent uropplngs, the Inference being
that any Insect part Is evil whether from beneflcal or
pest s pec i es . 0
There should be no question that consumer entomophobia, to the
extent that it Is based upon fear and ignorance as the Oikowski's
hold, can be countered by Informational and educational programs.
An intrinsic aspect of such programs should be not Just how
Insect-re I ated quality standards effect consumers directly,
but how they effect other segments of the society and social
Wn I far a	L_n			 '

There are other possible reasons for the maintenance of
extremely stringent contractual quality standards, as well as
fresh produce standards, besides consumer attitudes. The contracts
are written in such a way that the quality standards can be used
as a mechanism for regulating the flow of the supply of
raw produce to the processing plant. In periods of short
supply quality standards may be relaxed, or below quality
produce may be accepted with a penalty loss to the grower.
In periods of peak supply, below quality shipments may
simply be rejected.9'
The quality standards that are endemic to the processed food
industry have created a zero tolerance for Insect damage on
the part of the growers of produce destined as an Input to
food processors. According to Duncan Carter, Manager of
Entomological Research and Services for Del Monte, Inc.,
pesticides are beino used by everyone, Including Del Monte
growers, as insurance against insects and insect damage when
It Is uncertain whether there will be a problem or not.92
According to Dave Scott of Soil Serv, a major pest control
advisory company and a subsidiary of Union Carbide, in one
Instance a field was sprayed for lady beetles, a well known
beneficial insect, because they were present In the field
Just prior to harvest and the grower did not want to run
the risk of having Insects In his crop.9-*
Neither attempts at preventive "insurance" spraying
or the deliberate suppression of beneficial Insects are
practices consistent with a sound pest management program.
Vet, growers feel It necessary to Indulge In such practices

In order to meet contractual obligations that call for
quality standards which, such as in the case of tomatoes,
may be twenty-times as tough as the state quality standards
which have been deemed adequate to protect the Interests
of producers and consumers.
As we have indicated, quality standards of all kinds
are written by and primarily In the interest of producers,
processors, and retailers. The welfare of the consumer is
always given lip-service but, In fact, consumers h-ave had
little to say about the development of the current system
of quality standards. However, not even lip-service has
been given to the possible consequences of quality standards
for the welfare of agricultural workers, the stability of
the agro-ecosystem and the general env I ronmt-nt t or the
long-lerm economic and physical health of the public.
While the currant system of quality standards may bennflt
some groups, they may be of greater detriment to other
groups that have had no Influence in devising the current
system. The purpose of this study, then, Is to provide
additional information of this kind so that the true effect
of quality standards may be better evaluated by the public,
by the Industry and by government.
As Senator Philip Hart has observed, "You can make certain
book that consumers will elect to have unblemished fruit
unless and until they become aware that the price of
unblemished fruit is dead farm workers."

To reiterate;, it would seem reasonable to define a
"cosmetic" quality standard, as a quality standard or that
part of a quality standard which refers to damage to produce
which does not significantly effect its nutritional value,
its storagabi llty, Its taste, or Its general who 1esomeness.
The state quality standards for fresh produce do not seem
to be, by and large, primarily cosmetic quality standards.
Rather they set minimum levels for maturity of produce and
prevent mIsrepresentation in packaging and labeling. However,
the actual effective quality standards, which are established
and enforced by marketing organizations, with input from
retail sellers, often contain considerable and significant
cosmetic quality aspects.
In the case oi processed produce, the quality standards
that are established by processing firms and enforced through
contractual agreements with growers often contain cosmetic
quality aspects, especially In regard to Insect parts, which
are sometimes justified by referring to federal Food and
Drug regu I at i ons.
The additional provi.so shoulo be made, that damage due
-to insects or other arthropod pests can only be considered
cosmetic if the specific pest does not in some other way
significantly disrupt the production system for the crop.

Quality StandardsFootnotes
1.	Marshall R. Godwin, Organization and Competition in the Fruit and
Vegetable Industry, Technical Study No. 4, National Commission on Food
Marketing, U. S. Government Printing Office, Washington, D. C.,
June, 1966, p. 149.
2.	Ibid., p. 151, 152.
3.	21 U.S.C. 341
4.	Cal. Stats. 1917, Ch. 594, p. 909.
6.	These miaimum standards are to be distinguished from federal grades
and classifications into which produce nay be categorized Sec. 7 U.S.C. 499.
7.	Cal. Food and Agric. Code 42950 (West 1963)
Cal. Food and Agric. Code 42711
9. Cal. Food and Agric. Code 42704 (West 1968)
10.	Cal. Food and Agric. Code 42651 (West 1968)
11.	Cal. Food and Agric. Code 42791
J.2.	Cal. Food and Agric. Code 42821 (West 1968)
13.	Cal. Food and Agric. Code 43031-43041 (West 1968)
14.	Cal. Food and Agric. Code 42971 (West 1968)
15.	Cal. Food and Agric. Code 43001 (West 1968)
16.	Cal. Food and Agric. Code 43801 - 50891 (West 1961)
17.	Cal. Food and Agric. Code 43801-50891 (West 1968)
18.	Cal Food and Agric. Code 46951-46961 (West 1968)
19.	Cal Food and Agric. Code 50601-50602 (West 1968)
20.	Cal. Food and Agric. Code 48001-48008 (West 1968)
21.	Cal. Food and Agric. Code 42950 (West 1968)
22.	California Legislature, Assembly Select Committee on Agriculture, Food and
Nutrition, Marck K. Fong, Chairman, Interim Hearings, Quality Standards and
Standards Enforcement, December 4. 1973. p<"***	Ca	=-=

23.	Interview with Donald Dressier, Western Growers Association, August 6,
1974, Newport Beach, California.
24.	Interview with Michael Gagan, Legislative Assistant to California
Assemblywoman March Fong, August 2, 1974, Sacramento, California.
25.	California Legislature, Assembly Select Committee on Agriculture,
Food and Nutrition, March Fong, Chairman, Interim Hearing, The
Shipping Point Inspection System, December 3, 1973, Riverside, California.
26.	Fong, op; cit., Dec. 4, 1973.
27.	Ibid., p. 70.
28.	Ibid., p. 65.
29.	John A. Jamison, "Marketing Orders and Public Policy for the "Fruit sod
Vegetable Industries," Food Research Institute Studies in Agricultural
Economics, Trade and Development, Vol. X, No. 3, 1971, Food Research
Institute, Stanford University, p. 230.
30.	Godwin, o^. cit., p. 288-292.
31.	U. S. Congress, House Committee on the Judiciary, Subcommittee on
Monopolies and Commercial Law, Hearings, Food Price Investigation.
93rd Congress, 1st Session, June, July, 1973, Serial No. 15, p. 711-715.
32.	"Rules and Regulations Governing Fruit Packed For Marketing By Sunkist
Growers, Inc. Under Its Trademark Sunkist, Excel, SK, and Red Ball
and Under Association Non-advertised Brands," Sunkist Growers, Inc.
November 1, 1967.
33.	Fong, 0. cit., ecember A, 1973, p. 80.
34.	Interview with Tsuelo Koto, Assistant Produce Buyer, Co-op, Richmond,
California, March 14, 1975.

35.	Dressier, 0. cit.
36.	Interview with Bill Ramsey
37.	Evan Maxwell, "Perfect Produce: Cosmetic Defects Hold Key to Profits,"
Los AriRel.es Times, August 20, 1971.
38.	Cal. Food and Agric. Code p.41361 (West 1968)
39.	21 USC pp. 301-392.
40.	21 USC p. 341.
41.	?1 USC p. 331.
42.	21 USC p. 341.
43.	Sec. 21	CFR pp. 10-125.
44.	21 USC pp. 341, 342.
45.	21 USC p. 342 (a) (1).
46.	21 USC p. 342 (a) (3).
47.	Ibid.
48.	U.S. v. 1.500 Cases More or Less, etc.. 236 F2d 208 (7th Cir. 1956).
49.	See Circuit Judge French's dissention U.S. v. 449 Cases, Etc., 212 F2d 567
at 5/5 (2nd Cir. 1954).	'
50.	21 USC p. 336.
51.	See discussion of GMP regulations on page
52.	21 C.F.R. p. 128.10
53.	Interview with Alex McCormick, Compliance Offices, FDA, in San
Francisco, July 31, 1974.
54.	21 C.F.R. p. 128.10 (c).
55.	38 Fed. Reg. 854 (1973).
56.	U.S. v. 449 cases, etc., 212 F2d 567 (2nd Cir. 1954).

57.	U.S. v. 1500 Cases, More or Less, etc., 236 F2d 208 (7th Cir. 1956).
58.	Ibid., at 211.
59.	U.S. v. 484 Bags, More or Less, 423 (F2d 839 (5th Cir. 1970);
U.S. v. 1,200 Cans, Pasteurized Whole Eggs, Etc., 338 F. Supp. 131
(N.D. Ga. 1972).
60.	U. S. v. Roma Macaroni Factory, 75 F. Supp. 1663 (N.D. Cal. 1947).
61.	U. S. v. 1,500 Cases More or Less, Etc., 236 (F2d 208 (7th Cir. 1956);
U. S. v. 935 Cases of Tomato Puree, 65 F. Supp. 503 (N. D. Ohio, 1946).
62.	U. S. v. 1,500 Cases More or Less, Etc., 236 F2d 208, 212 (7th Cir. 1956).
63.	U. S. v. Capital City Foods, Inc., 345 F. Supp. 27 (N.D. 1972).
64.	U. S. v. Cassaro, Inc. 443 F2d 153 (1st Cir. 1971).
65.	21 U.S.C. p. 1:42 (a) (4).
66.	200 F2d 818, (8th Cir. 1952).
67-. Ibid, at 821.
68.	21 C.F.R. p. 128.
69.	Cody, Authoritative Effect of F.D.A. Regulations 24 F.A.C.L.J. 195
70.	Interview with Alex McCormick, see footnote #16.
71.	U. S. v. 1,200&ses, Pasteurized Whole Eggs, Etc., 339 F. Supp. 131,
141 (N.D. Ga. 1972).
72.	See U. S. v. H. B. Gregory Co., 502 F2J (7th Cir. 1974); U. S. v.
Cassaro. Inc.. 443 (F2d 153 (1st Cir. 1971).

"*3. Interview with Dr.	Singh, entomologist, Feed and Chemical Division,
California State Department of Agriculture, Sacramento,	1974.
74.	C. T. Brues, Insect Dietary, 1942 Cambridge, England, pp. 419-422.
75.	E. 0. Essig, "The Value of Insects to the California Indians,"
Science Monthly 38(2): 181-186. 1934.
76.	F. S. Bodenheimer, Insects As Human Food, Dr. W. Junk, Pub., 1951, The
Hague, p. 352.
77.	L. Tlhon, "A propos des Termites au point de uue alimentalve," Bull.
Agrlc. du Congo Beige 37: 865-868.
78.	C. Lapp and J. Rohmer, "Conrosition et valeun climentaive du ciiquctt
pelevin," Bull. Soc. Chim. Biol., Paris 19 , p. 413-416.
79.	H. B. Mills and J. H. Pepper, "The Effect on Man of the Ingestion of
the Confused Flour Beetle," .J. Econ. Ent. 32: 874-875.
80.	C. J. Weinmann, personal communication, Department of Entomological
Sciences, University of California, Berkeley.
81.	Interview with Ron Taylor, September 23, 1974, Los Angeles, California.
Also see Ron Taylor, Butterflies In My Stomach, Woodbridge Press, 1975.
82.	Interview with Alex McCorraick, July 31, 1974,	California.
83.	Anonymous, Current Levels for Natural or Unavoidable Defects in Sood
for Human Use that .present no Health Hazard, Fifth Revision, H.E.W.-
P.H.S.-F.D.A., Rockville, Maryland.
84.	Stanley D. Ray, personal communication, August 6, 1974.
85.	Interview with James Bell, August 16, 1974. Sacramento, California.
86.	See Appendix A for copies of coutracts.
87.	Godwin, o{>. cit., p. 359.
88.. Jamison, op. cit., p. 307.
89. Ibid.

90.	Helga and William Olkowski, "Entoraophobia in the Urban Ecosystem,
Some Observations and Suggestions," paper presented to American
Institute of Biological Sciences, Tempe, Arizona, June, 1974.
91.	See p. below.
92.	Interview with Duncan Carter, August 22, 1974,	California.
93.	Interview vith Dave Scott,	1974.	California.
94.	Statement of Agribusiness Accountability Project on Occupational
Safety and Health Act of 1970 before U. S. Department of Labor
Hearings, August 23, 1973.


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*p *rnrL :& : r
fjnt; rt. i'
'	. 1 ~^ 1 rr..ri-J rarranr in; w:>:U>iT E.'rrr
ut the	w ;r,iT	i p.jrjj r.-r.
f i;-.jr: e"> r-if CDr>irtfr, r*r cr	rerc;-
r.ie-	.c S"o. rn, c^"*' ci >uri(T -#?;<, cip'pr. c-
ino.it: ineui'-r; ar. irrs .c .jrrinr> at i-ia-ti*.raa. ir- or ef fi:n;
is' 1	r>o rv?r
I'jr., swj 't, tjr-fv	ar.y cmer marrjr or any xts
er piar- 'c-iini r- 5u*f^ rr oot Euyer jf.-ie to reeeive wrjroet
F-rS*	-=-	ih: -' ?;arr: ji a r-=r^' dei:e-v ere-
crc-.- k.r!--.i rr-' .r- -;-r tf-s pancu.ar wt-h r-.^- *rrm: ar.s c:n.
dirioni ne-fcr. ir. cr* cut >r wr.:K 5u*er rnij be uab*e. vhetrter ort
r- re* rrr r'r;c c." crr-crv.isc, tr>* unt *n*'r b !itiit*s fe
tne pursr.as? p-ir- cf >i.:n *rcc'i or plants. Sailer's exsiusive rtm'f
in 'i ciik shati be feeovry e no e*e*td *ueh pureHue price,
and, at 1 eineirior to a* l:ai!ity on rte oarf e* Buyef, Seiier mu^
ji notice t* ecrrified nai! to Euyer ef ar elaim tnar *ed er plants
are iirr:rie wt:rin t>:rr> days a*:er iry defect becomes apparent.
A. PERFORM A NCc EXCUSED; Eash Of* s^al' exemed from
perfsrmanc# unor f^-s crnrrasr wnile and t_ me e*'ft '' tha? ne
c Lir.aa.e t:	d. rcaior- o* any cauM b?vcnd nil riawrabie
co-.t'c-, ir.ciucrf nc* res*-ictec 10 fire, i sni, f;ooc, eirrnquake,
*5i;si;r. wir re?*iiion. irsurre^-rsn. acrrrp cf tnt e'ementt, ii^cr
C:spu:ej. trr? 3r nrt.fl ftilu-* ?* rrjnspcrrarion er celivscy faciliriei,
shcrrage sr ig-xr. .-a~ r. ate.-ials or sups.it!. inT-rrja'i-n of f>cwr.
a-.c ans a:- c: g.mtnt: c rr<'.Tr^ ian:';;itj, or that no
fa 's to perf^-r-	cf a;T,.n *a.n ;n a l^?r dtspyre, including
pjr nit wr'jfe; r; icckc i's. -jyer may	svich per cd *;:epr
si.c-1 pcrt-sn 3* "~e to;arrei as 2uye-. in it: ?_-cpr.er:r, car econsmi-
ci'v prccejj. ^.-y 'ci';s tna!' Buyer fiii to accerr unce;' tne re-rm
rx rn s caraj.-za^ A a1-?!! be ^uromaica"y released fsr sale i-d
oe'iven/ e'j-?wr>fr fy 3*er.
o*riss'y r  mer pa*ry ; ms'sr _-p3" r- enrarce arv c* rr terms of rihis
cor tract Or;hei by tr.e otr.er sn;i be oeemed a waiver unie*> the same
shaii be ir *--irir; Sr. ?rresfcr.:s:;.c z:	c: sj;r sruli r.ave any
a^r->cr:r . t:- a>ve, :Ka'.; -r ioc ri anv 3: the :errr. ^r C0.u,!>ons speci-
fied he-e:r. except b> a writing c-iy executed b, said representative c.-
ajer.t.	.
C. ARBITRATION; if any canrrcversv shal! arise Hereunder bet-ween
"h parnei Se-era, such conrro/ersy sr.i-.i be oetermined by rtirrat.;r..
sjvr -nay 'eaut^e specific pe.'fcrmance of Seiier's dutv ta deliver rtie
crcs upon pest ng oy ruer of security for Buyer's performance here-
unde* o:."r:ed jsirtiy by the otner twc. ir* arbitrators
yiiL ;n a:> u.u be :ar-. .ar wttrvlne crawing an: canning cf tomataes.
The determination of rne maionry of tre arbirratcrj shall be binding
ani rmj! tPin tr.s parnei hfreta.
sr.all be de-ntd rr.ad:r.r ta tnt **e.nr nertsu^y ta ccmpl> with Stare
and fesera .awt anc ii. critr. reg_ut;an cr :>cenve priar.: inert;:,
*"3 i-.v	a;rt!*r.nr sr z'3*r t-e aj!+*ir:r> a* ia*.
E.	T!Mt Or ESitriCE. Time is &i tHe eisenee cf th:s csntract.
F.	NCT.Iii; <.cc; a> here.r	e>>P:^ > srs-'iti any r.y-
:.ze cr .;er--o n-a r	?er;;-a ins isa be
ci: - . :-!:<	1-. r:. t: w-1 *; State j
r--i a--. *. ,*r-f; i'.: )>>t; vt	rz i-rtrii irhniij:
i:r-t .:
S. Fa.F. - -iC.".	ACT: ;*.,cr	:r.i: 4. cf t-e
j.. ; . r; --  :		 ; ;i	r:
- " v >z' zi~ . *tc. '-*-! ~Sr ; ~ 1-: 2	a>rLac-
-_a.-c - . *:	a-.;  . r-.; *-tt-arj i"; crterj a; tr^i L. S
It-..-- 	j-;-.- 'ar : ' *-**. t-: r-i* ^2;-
4. . .. ,e. . ...i	ff-'*<:**Si'*? w-:	;e:-e-
*> -. * * * '"'U't *C	**,"% 'riw .'*"1**'* f|e(
5*r :: ~ :	-
k ecrr .'s: ?Vw'3 '.a-*: asd RtGL'-Ar*.3 :< t.-
er: * v'c < ;  , *... v-"fa'er r* 
" .* J"  *~ ri " "ii r*;_I: rri
- i- . . - c- < s- j L-,; J-; C.! ; ^.;r :- . j-i II
'c3s, j:.iT,-:.s:,ar. -v r1 :   : r
.-vi.'-:-	jl .s : As*		
".SS'J* > tc* w*ttj	' r-

t ar.y purjios; wh;twsver other ttijn
,;ii or	jbi^s to Co:np-jny thffclty
,i -,(jirr;i'',jiior and .-*<: I.t.v
N? "119S
,M f rn.vl- this	
.'Jjy o f _
, California in t-
herri''of.'r rrfL-rr^o lo Ji "Comppny" and
__by and be;v*^n HUNT V.ES3Q.N FO005. INC. with offices located at 16^5 Wi Valencia Orivs, Fulleri;
od to as "Grower	(
lion swtt'J herein agr?e as follo.vs:
y sens to Company and Company hereby buys ftom Grawer_
is", which Grower snail wjsoubly pljnt and grow during the,
>w. Grower ayen tnat h shall deliver to the Company id "MaxiC"jm Tons" during the harvest period spect
_r ton* of tomatoes of the \
tons ol tomatoes of the varieties specified, hereinafter calf
.crop year on no less than.
.acres of the real proper
in the following "M.ixirrtum W-
Jul*", however. Grower snail not deliver more than the number ot ton* of such tcmaioey specified for the applicable week under th
fits of rarities 'ri Gfff.ver in rcess of euh: '.heKMaxirr'-'m \'L*v.iy T?^s" or the "Maximum .Tons" lexcspt puraJar: to"the option grartsfi Co
fraph E bsiowf. /	j \	/	i \\ /
Of CONTRACT TOMATOES:	\ \ \	f	 ' \-/
t trie mutual acvartase of. 'r. .parties hereto that harvjstrnif ani processing be so coordinated as to maintain an ewer/^aily flow of tomsrres for pice^
jany ano allow Company to orcvids for periods of ol jn: clear-up in oris' to maintain sanitary conditions in acc.voance vvitn ijood manufacturing
' harvest oencl .-s z.ierirce as ipecitied in "Maximbtn Weekly Delivery Schedule" and Grower snail rn deliver tomatoes and Company shall roc
take tomatoes p.-:or ta comnrencement or_a';or rie last.'-ee'n endirg due suecnied forde,jAo t and ir paraqraon c. In IdHtion. picktrgoays shali be weelc day:: non pidcinf davs shaii ce Saturdays, Sundays and/or holidays. Hti
me to time C^.-r>oany rrav au:nori:a picking c\nor picxirg days in .vhieh ua*it it shall acceot dalivery of tnou tomotoes ' Suitaol* for Canning" vin^
rd delivered as au:r.orized oy Company. Sucn "Ccmpany authorized narvesi on non-picking days sr.all not incfias* Grower's "M*tmuT. V/askly Tc>
mTons". /	\	\	1
ry v/tektsl Grower cois r.c Sil ver, or rotifies Co^sany that hr will r;; be ab!e to dsIWer, tfi delmreti :n su-n	at /b^ it Oro.ver ha> or >viii hav^ the capability of cal;wwi:ig ail or e portion ot scsh urd^livtnd tonrucoas i^ ^
'A, Company ray -elect to acj'j>: or ex tans-Grower's "Maximum ',v>. t*'.'e='ait"jii have delivrd tne Vaxirnum Tops" provi'Jiof hernia to Consanv, Growtr snail nt-: perrrit
te taken frorn sa.
jr'vil'.o be
icaiV Grcv/er sns
I'M TOES:	, .	.	.
~'caratiors for the .r>~-evs csid a^d- aysfl/:o be paid hereunder by Comsai\. Grcv/er sijII deliver to Cc^oany tomatoes. >i xceu of such Maa>
roun;t tt soecifi-:;:
tceipt by Grov.^r of -'jc^ "o:?-'zstion, tttlVo i; ur.Jiiivared tomaio^s t+ncifpt de!ive,i'd toCor-pary Jurinj tr* -3 +cur none* pe;sd' shjtf r .
Ml toma'.oJ* in iCssi oi	^u'3 Tor.f ' -d-l.. -red ay Grc.ver to Company	a: ir* wrr-s oric-3 ar'd ^aoi' :r am* wr-'s a-o co-~d :
On the faco and c:c'< ;?? A<: ':> de'ivarv i:J di'rMry or "Vav.mjn Tout" Grav.ir vsji.
aOaolt ' Suitabls 'ar C^nr.r j' - x an amount gredtar than tha amount specified m the "Vc*ity OaM.ar> SchMul* for Excess Tofnjwrf*" fat thjt
t additional tomaiaw v.a^l	to (jra.ver.	$
ijrm tha; it shjH say ft Air ton stated belov/ lor H tomatoes, which are "Suitable for Canning", as defined herein, delivered to  a:
 times and i-i :he ^-a."per ssj^ ifyhere.n,	:
/ /	Price Per Ton
VQP TIT'.F:	/ '
(wnn t-jt "* tor-awa* i!' : hereby are h>s aosolui^ oroo-Mt ^ led ras he has not h^etofor# contracted to fed nor wftf ;h*m toom*rs. nl that
i*n wcjr
1 w E < |w*:tKENOi\GCUrr.L\ TO^S	
WC t K. CNUliNg U4f i
K "

1 5
\ \ t


1 6
\ ^

I 7
\ \
1/ >1


I 8
\ -.|| il 12
V-	V

f jcrejqa:

lal prodjcing acrEjije Vjii mjasurd prior to hanj-st. If Grower's aciu^\oroducinij acre'ags is less than i^.e acreage scecjr ed to te planted iocj?. jr?
kf' Maximum Tons iir'. ixirr.um V.'eettty Tons' :o delivere-b h-:reuri<.ier shall be nducjd proportionally. In no : s^lH Ccmaany boc::;i:v.
Mies of tomatoes fram Grower :n exces; of either trie '-Wavmum Weekly T?)fis" or i!je "Maximum Tons" lexcept pursuant to the option granted Ca.-
iraph  Osiowl. /	> \	* /	t \V /
3F CONTRACT TOMATOES	\ \	/	^ " \ /
tne muiUJI	or :~,e odriiw hereto that hjrvtstini/-and processing be 50 coordinated as to maJotsin 3" evir^aily flow of tomatoes for cror^
any and allow Compjny to or cv.de lor periods of siin* clean up in orr!?' ;o maintain sanitary conditions in accsroance*.v!h (,'oad manofacturiig pra-
harvest oeno
~rtion of such undeliv-re 1 tons and Grj ner shall make oeliveriasor iucn undelivered, tons in accord Mice therewith. In ordar to acure Cie order!*/ harv..
herfjndei'l the Company wll iot adjust the scheduled "Maximum Wejkly Tons" hereunder to accommodate _ndslivfri tonnage of another grcv.
Bwtr is abFe to deliver such^-;yeekIy Tons" in accorda .ce vjiifi ^aid "Maximum Waskly Oelivery Schedul*".
as otherwise providecl>^refn, until Grc-\er shall have cfelivered tne "Maximum To(is" provided ror herein to Company, Grower wa!J not permit d
5e taken from saidJ^Was, except tomatoes'tor dslivfry to Company, ror shall Grower deliver or attempt to deliver 10 Company any tomatoes not g.-c\-
i	t	\	" '
Point:-	/ 	^	 f
iderscioo for th moneys paid and ay'wj/ro be pa>d hereunder by CumpaiTy,

II uitiver to Comoany tofnatoes, in e^ctss of such "Maximt
II tomatoes in excess ol * Ma*oy Grower oi said "itaimum Tons". If, after Grower+wi completad delivery or "P/ix:rntim Tens" Grower sr.j!l s ^
liUola "Suitable for Canni.i-j" ir/an a/nount greater than the amount specified in the "Weekly Delivery Schedule lor Excess Tomi-,o" lor that .v-
.... .	>	. J _ .	
^cjuiiiofi^i hUnitfUJej aiiaii Tevcr
rtes tha
'.a; itsfiaH
times^nd i
pay the pric-
in the manner spera'ie^herein
I evci / gi
/ /
ice/?r ten s;at
A , #re
! .. ....
at id below far ill tomatoes, which are "Suitable for Canning as defi ed herein, delivered to it at the Oeliv^
Price Per Ton
^sents irai the iom.ito s -d "hereby are his absolute property and that he has riot heretofore contracted to sell nor sold ttiem to other*, and that
jn, security interest or ov.Kf encumbrance on the crop covered by this contract except ai taii.-mv*-	^
incur any other cbiigotioni thereon without prior written consent of Company,	.	.
1 the dot* and year l,,t written aoove.
f"shjll olfvr lor delivery 10 t,un.Lji)y, Jt Udivvrv Paint" pfOjtij>tly jfter hjrvrtlir"). vnie-riy^tierl tnmjtJrt "Suiubte 'orCunning** as
rnolufits' con'L'jny n> :y rL.}_:i-. jnd hjrvt'sitxl puruant t-j ifiu icrini Jicrcol. E Jch such vJelivi;i> of umijtotta iiuil be friaS tr iuv<-i. v<>.
I, fiiuU jflil tilh"-*' lurC'jn njitur	^	a	
Mi'iy Oi.i'l iuv Gruwer lu' jii i -^Jiort (11 uii jrxt'iHu! IcjiJ which jrc "SuiUOle lor Cj)hi!j". A rtrsirn*!ntjtv* sair.plwof c*n IojJ wialiein<|i-CT.-j ^
ifin/ *11 |f.1f	^	l-""1* I'-tl'/f jo.hi v'l.*l> be	l*l It.. -	ul Wwll wllllil^.
i u'.hcfwcx- '^irLilii.-U ti'.-fu-ni. i-J '.u;rjt. .lull tic tui vili'rd auil it >'- C.niniinj il:
IS tc> liu't 1" " 11	>"iii in.-.'.u'i'I ihitHiij" II." i .1 .| ".l piMliui* o .1 uiiv. vctiun:
v mold IM 11111I1J iljili,H(.;. !(.!. ..ijnri 'i	>y C.jsiii.wiiv 			 t-'m-i'v-Mnj Ii'.-IN.*!-., >f I* V.iv- itn.it..
l'XCir%* u' -*J 	>v'"i! t -j	"u u-.vi! it.' -.11.n1 ij |>,i 11it.-. . > 
r v*:lluw cul'i' I'1**	otl.vr unui-i li  ti.nn 1 i>jI %it.. 11 iu ivhi.

i) It I.	Of tfO'l"'l.
b tiv .ivi n - -I >r of i:w; " -..'i !>!-. I  rrv-i ih.; Ar)ir<)i: f.n'i.i >i	m l.i:i .it timi; of delivery (at K"II roHf-.fl .K vtMOfiert in tit-* "CALIPO!,',:i^.,
I 14 fc/ l.'l H:;(. r f "	l>y Hi  r.-jiil.wi i	t, f Ajr ..iiUu'-, f;'<>.> nl F'oit 4' ."in r 	.:i u;o 'J .: J '-i-i-r. fnuiJ urd Drug Ailmm.-.tratirjn ,wj/or Ova rot mall rr[ixlscaitf'jm ta
. r>>  <.	I l.l r>" l"'J M-.-llh	_	_	'
j ,y lu..' lot Imn.i' 0>'1' 1 lu' <;'linrfv ( j CotiOhii/ in )y TV' r I;c' ^r f jr.H turni-rj ti.ir.V. t'j G'Ow-r js U'"'Jlit.ill*? 'or C-r'^'n'J if' ( 1) it C3nt.iiiiri. m ni	i'>r. . |o-in,in. (i' .mv	!	vi' r i/
to *i1' 'jm .1. -I .:	<.. J |	4 f I l -r I.r.-s..!.. ,.,) my <" .111 of trv?. ..'-..iiti-vi'. rn.'ntiori-J i* rh.-. Riir..-;raDh 1 j- suth 1" i: j
C.;:hmh>. co.ii;- '.'.i '.'i.:rrl(.> o'	-x; S: j'"i FotjiI .jiv! Oi'ic i> ii'	ir*.	J
ct'viiV.i ;. r!i: nvt*-1'"!	cnn-r j,-y	r"v-in, Co-*:' >'; rr\y/ crcvo' .my loart of tormraes wl~.ieh confirm to the.trarxlard; 'or tornatc** (.
Dy	I-! A"f>cji"urji Cortj ;>( :ln S;..:c '.! CjiiHr.-vv
*jmu "y not h: rc:-j-rtd :c jt'.:r-*yji e or to pdy lof thj! p.-d in'.jir: ol jji accepted loud which, upoo inspection, is found lo consist of tomstc^ 
LjitJUto lor C.Jnmiu)' jsO-.'l.'i 'J in ri'S (i.irosronh 1
,'0'.ver	(h it CoiT'p.mv )v cnorq-.' .ill coms. 'r^miii ai>d oiher p'j^MSes in connection -ith dit-vcr'/. inrpwtiOfi an'J fJtu'fl ol Jf / re';>K'.f-d lO-Trt to '
r of  fr:JV n1? ';ivon My Co'^pjnY tfitlisr vi'rt>.iily Of in vntirvj to Grower. Grower's A^iint, or the Tructi Driver t!eltvtfyi:oi.- oflt-r"!! 'Tr eetiv^ry t-j Comojr-.y contains ony chrnical re'.KJuo snecilied in subsection (g). Company, v/hethef or not it
r My clijri to r^f'jvr io	j^y fjr'ner deliyerits h.:r*un6sr by yivinj Growjr written notice of such election.	
Jmpjny inay orier G'j-.v.'r jjv.re c*:?Mining to Grow-r's tomato growrng ar^d harvesting operations, huf any Such advic* shall b* COnsirisred cratui;^ *
inly onrf shell in no v/ay ip'pos? any lisoiiity on Company in ta event Grower should follow such advice to his detrirrent. Company shall incur no j,
for any loi* whic!i rrjy rciuit from any directions qiven in goott faith by Company.	"
Ffower slull oermii agents of Comoany to enter said lands duriny the tsrm hereof fof the purpose of observing the growing, harvtsting and hjolingof
!7r Labor St^
33. as amended, and the rK^uUtions and orders of the United States Daparrr.ent of Labor issued under Section 14 thereof and Grower as;*s that he v
jany with yji itten certification of such compliance either ten (10) days af te- linal delivery, prior to finaf payment hereunder, or at ny other tim du r"i
[ornpjny inoli no; be oblnoted tci furnish bins or bulk trailers, hereinafter referrtd to collectively as "Containers" 'or delivery of tomatoes hereunder ,
r furnished by Company, tney sna:i be furnished free o( any rental charge, but grower shall pay Company a service charge for container tnsintenjnc- ^"r !
lompany an amount ^quwaient to forty Cent; <4C) per ion of lomaiodj (culls included). Should containtrsba furnished. Company shall hav4 ih* ,
m proportion ot Grower's deliveries nereuixjir to be made in LuU trai'^rs. V.'hen such bulk t.-ailers era used. Grower agrees to aSKtrr.e respoisibiliC/ fc^ '
kf iuch bulk trailers while i:i Gro^vir's custody and Gt jvjer accents liaoiiiiy for any and all loss ir damagj to or destruction of such bulk trail-^sduriiigci^
barvestinfj ooerations.. Cornoany iumufied contairvers shall used exclusively for delivery of_ tomatoes hereunder, shalt be handled with r*asor>lii*
:^ion ol Grower's harvest, snail be immediately returned u Company ot tr.s 'Delivery Point" or such other pfacs as m-jtailly ogre id ift good ana cj.^
c'^vet shall pay for alt com jinors lost. J2nag2d. dest:  pesticides ^
iplication and c'^sr ril-^'ant information which will aid Company to determine whether such tcmatoes are "Suitable for Canning."
contract intsr.sad and -jnderstocd by the parties to be itffec'.ive v/hn signed ard title to the sro-.ving tomato crop jswell as t" etc-ratoes shall
imm".-!!!:^; / unon its so-.vina =1 tn seed and, or ''le transolanjino o' tomato plants by urower. However, until delivery ar-d accectance bvComoa-T,.
fcma5S or cettnoraticn to urdehvered tomatoes shall be borne by Grower. Company shall have the option to cancel muconcract cr to reeuca jie
Icilied here!.- by .mailing written notice to such effect to Grower on cr before March I of the year of planting.
5e!:ve'v or a 'oad cf tomatoes vail tot ba completed until it hus been inspected ard passed bv irsoeetors designated bv iheCaUfom"# "tare Deo art-
r anr! insoec*-d and accepted r>y Co.Toany insoectors using any insoecting devices adopted by Company ard no*, unaccsotibleio the Ca^'crnia Sta'.-j. ,
^gricL-lture. Grc.ver agrees twat ,v".e Company's inspection nay be marie bv i*n State Department of Agriculture or other f'rd parresuncer contract w;.
krovde s:ich msp-ction sen/i^es .v^ic!! wi!i fjrth.v grnde any load or B;rr:o.i of a lo3d to determire the prgyn-ce of defKti. darrtstfe or artdlnortal Gu>;
solids, consistency cr pe,-jb,!:tv- " Company furnishes :rin5por:a:.pn to "joint of inoection, s^ch tra^cportation shall 's right to i.-ipect. .vetch or rej-rct su'en tomatoes ac point of inspection as ntrain prodded.
^AVMeNT QP f-.'Q!>l = YS:
"ji.' Cj-r.Ti.ny -
PZyrr.-'.i: for ail ;orra:c?s di'i.ered hJr^jr.jBr shall be madi ty ;^4 wcond Wednisday following the Saturday of theof delivery. Tlo fjilur ^
>ay Gro.var any amount s.-.ai; -e r^jrded as a br-jen of t.^is cor:rcc. l written demand s.ijil nave bfan actually recei-.rt vy Comoar./. and Cc np-,
ti to corrp'y .vit.~ such di/ra'id fo.* & psricd of r//enty-foyr (2-1) ho-jrs thereafter. No such demand shall fc* irade until after the flay for payment sr-s^.
13) Grower 
fn thj evert of a croo failure or te"nin3:ion of this cor>:ract for env causa. Grower shall make caih payment to Compi"y. on demard. c' atl mc:>^
) bjt not Mmited to	o .:ri for se-;ds. plants or oi.^er mj'.inaii a.-.J supplies furnished by Compiryl. and siiatl return iU !ieldcon;airefj
K*Pd'i/ may >:jve
I CI '.Vil'"i^'JM 
Gro.. -i r.luthon.'j'i Is-H"-/ :o v.nnho'd frjn: yoce-ji f .-: C:a v*r frof. the wkof tomitoes 'Suitao'ns for Ca	q": Comoj-y an arnou^
^3') o! -ch prczitc.t. i-c.n = -cunts law ofije;> ;p'=ciii'ic: mi gjra^rapri 3. suuparagrapn lei snj> ue paid :~ Grower vutriin trttrty (32; cays Jaiic
k Co.:0.i.^Ar.H OH PAiL'^^E TQ r'EPFORM
RfTj.f 3i wf'j-sf 	v-i" j.-.ti or ca.is.t.i^i tjrtai.isd herein or failure to i/Srfo'f ai hre ~ prc-.ir.-d, 63*.'H:
|j miy at J"./ -:er	--s;',:i:j en :h; tiC2 ' j.'vo;. t ij;i o' '~'-c crc.i .tnd take :h4 t-Kiisary	f:~-e zm-xr3.:.
wui:oj ..." J **t\ tn-'oof. A	e>Oi.'n ._ >j .r.c^rr.j J.j.l uv lir jCMuni cf C'J.'.'.r jud be pjy.U*4 0Jt of *" J mo-",r.* pjy:u: t f?r s;.i -
g;r^^ J, a-0 Cr
[tn	:he rr.pi to .-rm-nj:# !"'$co-troet and -~'j~ S'.-c.~ .-j'.-an ail of Cof*":>.i**v s'.'Ul'git'O^ihar+urKt^ shait Tvrttraw
ijiv/ at ir>J I'""-' aftd' :	'Ci j:;-.-	j'i-.~'j* rn^nt of C>" =j-- r-ju3.^'	t:r t-^	:.> Gr j .;! of jiiy oc-vn.ir: a-ijrtlsvan ccntaics-a 'v-e-r In --*; ot--!
ijny. itr.r ,u'i: 'j '.tie ttr- j- vn :j'i-'*:2'i, i::i- :a j -^vi	i.-ji! ".;v*r tj Cr:. .
(cl ^>j!I e tne ri.j*:: to v	or OCw< *" Jiv x*
*jf 'j Cj '	- "=-> !> '>*/ iJi'iiiil<	-and j:'..'.- -j.i tv.-> ntjr'"l b-, Co'ujov to can.-eOoo
|'f, I .'.I .  Of f '*.*. *ir" -* - ' - j. !r ;r"r :i Jf'Su.t ..O'l.ni^.  Out, C-t	jl.
t! a' Co'l O' Cf J *>/ !>'-!> ' vjl i": irv }' i.'v*5!-ji' "v	vi if ;.ny v.'! 3 O' rf.vli t 'J'.V Cfd?r l-'rr'jIjUO"*. r-tjir^t 3: e*: j^rwrj
n,t .'>ut."ori:v it. - :rj . Iv*.)-' * .:T .' i ' > )1:  S i?i j"y ; 3 ;	. u";l i^ ihi.^;, ,t.. j:!,* J j-,;t r V v.i"i:j"', 	cr " JT J* "> <
''.'J.-'T'i .C'* '.il. C 1 ^ 1 i -  * I * J. ', >'* '.I - V I  * "	 .'. * ,  ,.' j . f .i ti;i t ^ i'?t t,. . I	.  c*.*.' Tu. i J
: " 1 :? i- T -** " .. o^f' JJ. "j* WV" 'j: .r.	p- C'. *:,;-'*,', in }t J v  U CJ'-i-l. V! ?** :C A-. 1* " 1" sv: .
o' - C.",;i:'- ' -I ""  J (V I. i'.-". i.r :i ill"-	j't^CO'i-'.'i't "I tin; V. '.*;	J'!. V	" 
t, - S . ^.-f f.. , - : C. '.i .' i ii. '	;  u-.'.i -n	rj Ji.-.t- 	'

MTAiricar..	im	45
"..l.'iuy ,h,.li"r i.t :.n! r.lV.r >:'] to furnish I):ns or bu!!< trailers. htr-;ir.!< re'!rd to rolliCti'Hy 31 "Container!**. for y C;mur f, -~i-i shi'I oe fi,?ni>.hd tree of any reou! rhjrgs, bu; ;ro ,v?r sha'l ojy Company 3 service cha.*?* for container r^nr-fure" an^jl.
in-jji'v an amount * Snouid cWHiafJl)* IgfCitijd, CcmsifV *: Hw in* rlv,i
"i jn of C'ower 5 *!...<.r-.-i-^u.K! -;r to be ir.aJj in t,ul 1 -j.'-Ti V.>en such lJ"; tniters ir? us.-'j, Gro.ver a. fai'idunr'jG
v.-st.na operations. Cu"''J4'v/ -'jrinlvo container* n-i uv3n ill Grov-ir s hirwst, i"iii b-f 'm'r.eoutaly ret'jru-it t; C;mjjr., jt ;he 'Oenvery Point" or such o'h** s'a-r* as	v;'esd it czad 2fC d-?.,"??
, />r shall pay for ! coi.raiv, y>: in, Jama^d. dMirssoc or u~ K_c-n'eJ for r.th raw of S20 p-r osn and'rw the acfjal a^ourt if bu wiiasr.jQ far J
. 1 cha.-;.-j >!uM bu pjyasl" pr.or iir^t j'ccountms o-'t.ve-ji tl-w o.-rcis Ary s^cn DJvrre.ot shall not pji; title :o any caa:a::;ef. r'~al pi'/nwt b/ Co> i
> , not b-." ;naJ-: until ail containers are rtuinwJ or pare lor as jrOviC-ci H-sriin.	.-I
;'y: jr	thj.it Company's r-rcveic he ihnll pr;p3r* and subnit to Corr.oiry on Company's form all pertiwit infofrnarlon rj'atiog to perticiffsi ut f- j:;
ification and c:ticr rj';vart in'or~a'-ion wHich will aid Ccnpony to d:arrmrte '.vhetr.er such tomatoes ars " Suitable for Ca.'sr'irj."	aj
ir'-n. risk of i oss:	i
To r.oi'.nct >s i-^tnnae'j an 'J vrritrtrccJ by the parties to fc? fiflecuve whan s;q"ed and litis to ths grovjirq :orr:aTo crcp 51 welt a> :>.e ts-rstoes shall a j
(Yirnecfij^iy upon the so-.viy of tne so) arc!.'or the :r2o<3:an(mq of la-mto ptants by Grower. Ho^.vevar, until Sela*ery anj acu'Mrjfice b/ Com^a.iy, ^
hajf or fletoriora;ioo to unc!^llvrd ;o~ijios ih311 be bom? by Gro-.ver. Carrip^ny sh^ll nave the oOtion to cancel tinilcontract Ci* to ted'-J# the	.
filled h;reic by .-nailing wnttjri notice to such effect 10 Groiver on cr before March 1 of the year of planting.
>|;v;'v oi a lo.;d cf tornjioes snail no: be complstid until it has b;?r insp^ctad ar*d aatud by insaectorsdesignated by thClifo^'3 Star? Deoarm-,,
i find inspeciid o^d oc^cjjiod by Company inripactors uiing any insoecting Cjvices adoo'.ed by Company arvi not unaccsatsbie 10 the Cj!;f?fnia Stale Q~"
,r icuiture. Grower aqrees that the Company s inspection may b e marty by the State Oeoartment of Agriculture or Other third oart-ej uncer contract w-tj-,'
2 Cjnn.'.nv -
' fay.-nvnt for all tomatoes cfe'ivr?d hereunder shall be made by the second Wednesday following the Saturday of th* week of detiwerv. No failure fc^j
ky Grower any ariuurl shall bs rsgarded as a braacn of this contract until -.vcrten demand shall have been actually received oy Company, and Cor.Bar. '
[ to comply with such demand for a period of twenty-four (24) hours thereafter. No such demand siwll b made unt'l after the day for paymani scrci
J JtS22-
'' tn th? event of a croo failure or te'mination of this contract for any cause. Grower shall make cash pa yment to Cpmpiny, on demand, c* art mfveys
! t .1 not limited to moneys owingJor seeds, plants or other materials and supplies furnished by Company), and shall return alt fiald containers
m3y hav# furniihed.	1
i-> VJ'tl'noldinn 
Crovti hereby outfioriz?i.Co^oany :o withhold from proceeds duo Grower from the sal* of tomatoes "Suitable for Canrt^g" to Compaq an arijun*
[ 2 ''> o; a'!, such procoedy'S jch amounts lets offsets specified in paragraph 9, subparagraph (c) shall be paid to Growar witrnc thirty {301 cays fotiov^:
: Company's cari-.mri
vuiiy. 01 upc.-.sf ^ Lrtij.n c: o; i:'i! <:u.'v:ur.tj or conditions contained herein or faiiura to perform as here:;* prc.idpcS^he Coxpair/:
.nay at anv^ffrrte enter :nt imcs u-ncr.bcJ on :h: ha nareo', i-ki ,Josi>a>S'0h or the cop and tak* the necessary measure* fc- the rwtectia.-.. g.-cv, ^
iul'.ng jnd cJ-tivery thsreof. A!l rea^onablL- expenssi so incurred shall be for the account of Grower and be payabieout of tie moneys pjynbfs for said ^ "
; rjvclevifai-3/or	,	.	r
j&; f'-jv th?	:"rm;nir? ihis contract and uaon such lerrnination. all of Company's obligations hereunder jhl! cea. Termirratrc'* .may h
jiy/ Gry.-ir cf any covenant or condition contained herein. t'lie ewenvof tarrt^1
IkViy purvjant lo thff terms of this oaranraon, title to all undei!v-;r*o vjmataas ihai! revert to Gro-.ver.	.	"
jt) shall have the rnjht to set oil against j,:y mooeys payaale to Gro-.ver anv sums o-./ed by Gro-.ver to Company whether or nor the* due or piyalj'.^o^ 
hiQtii'Jaiid. " wit is t.'ou^iH ay Compjny ajoinit Grower because of brch of or raiiure to pirtornt tiiis contract !>v Gro-.ver, or to collect any >orr
u Company, gro-.v-r sorees to pay reasonable fr.penses snd attorneys' fes 'r.curr-^i by Ccnvjaoy in connection Jtre\vitrt.
|r?Y 1 i-Jtt-xjn of iire, i-art'-'juite, liood, explosion, acci'Jcnt. wind. v. jtcr, diff v-mce wi'm or inability to vcu.e workmen, 'ockout. Ias*s of materia:, lar.u
k' of Gad. or of fny pub'ic enemy, volunury or n-wolunt i'y conip'c^ncc witn any valid or invalid la^y. crder, reculation. f-fjjfst or recorTp-irua:'-^.
k-,l ao-.-ncy or authorny, l.iw* 0! transuortaiion fdiii;i-.'S or u:iy coujj H-'yord me iminiOo'tf and direct control of Contsany, i\*iethr or not ot th-j
t-iOi'-cra yi-.'cif.ijd, Co^ii.hv/ ihan :,a ti .-idv.-'I. in . ior O't't. 1:1	.".'ly	t ciuin ?nvC:'!eiJ, sjCf> tvav ie
Iff*, to tho er.Mht of sc:h causa. Htunrq priocj r,f jo.-:-;; incfcinty 01 t^-: part 0. Co.mpiT/. on account of a-.y of tl causes, to o-oc-.'js. or ra.-isp-a': -1'
ir .'ei!-.-ry Comp.iny ,*>iy	.'J ihijui! usliv.-'v cr *jch uortlui: -ji '.^ch taruu- :s as Ccri.tar .-. ;n it* jtiit^meftt.cjn OCjnom CJ!!-, c:0CiKv
[ (!'." ".S ii!.'il)li! for C.imr:'j' jnd not JtC.-p.'t.rl !;v rrr>..T.y ov r ,^n of jny ; t!'i; u'uv^i-)i-. ui this fvi'	To'i to lis 0-.!iv-.-rs0 t-.-vur.f.ic- ,:i JI li-.- re-:. .. :c ,i.*ar or': ji.atc'v il-Xi-.-.'ft riifujar-.t (a the ti*"rw h.'reof >UtlSC:tJ^e j:--a *
|5 'son.iLilv to^ibis a'tsr thtf removal of -uch cjjie. Grj.-.rf shall not he l;.it;!e fcr fa.lure :c. delivei- to.iiatocsdestroyed by froit. vvrrd. v-ater. vt-o^ ^
I* uciirs.	
it-,-  vnit of ) asii'.. im-.-nt or tr.ins'.r of Grov.-i-r's rigV.s hrejri'-'-'C |. -'-.id-nii hut far	tn j-.v-jttmMKSf rrtip prec(i?3rd sattirip/	'
w -)'..iifi,iiy I.r ivolu'st.iry. o' 11/	.1 oi '.i.v. .;rri.-.,it nr.-v uu-. t. r r.jiitnl oI CuJilu 'it /. Co.vp.mv Jwr t~u r,-,:. jt. ja	Jtc l}t.%
i j'r-' v.irt; .p,;::iii:Ticnt or Ir."- '-*!, ii.-i:i arry | jo- .iiicr -.niilrrJ) F*o:i;e tliiuoi ;.m :uve lt.-'ii rt^'*mJ Cviu'Va'>> * ry'-rw*'.	"
'.'1 i-i.in--f r t-'iil .mm 1. "ji i^nifrjrsuMS.
[I. it i .11.:i -.'. 1.1.1 1. i:--- ...Juil tti th.: r 'if't  ci->..ry t>i I'o'i'iJ'y \..h Slat-: ad! or P-. dcrjl l.i.v-4inJ jHy flrccr,	-.r l-.cer%* (!t*:Svij
t 4 I-. ;IU>-1'III| J.;r..-i:i-;iV. ! U'-.! :f u.lit-.r tllC .lUt' Orily J* I.I-.V,
r( t ,rjliiori'i i C...iijjjiiy to ;v./ Kir Giowirr s .iccwuni j. 4 ' s or cii.ir.jcs Vj/jci'i- by G.'J.'.et wui-r j:.-/i*r s ii-r'i.vm.i.'t!, of O' ...i:im*i." i'.-,> liy Ci,n:iiv p 'rmilttr j tlrc^.ver to l-\-.t" ?'>" ;i.;-	?"
; _i .il t". i;.r.tn.--l .1. .1 (.v.nvi-r .jt Ci> im.iiiy ri s'it t.i  | nr.- jn .'. n.rx" i.' 111.'  1"!  i.r .in*,* d'^.-r	-r rn--.;<;it,'	Ti.ii 
 ./: - -! 111 -11 li.,'..'. cm | ii 1..' 1. . . il im it t 'i - 1 v'.:'  1 :	1 nr jiii .i 1 >im' c.-h. >| l;j. ...' . .uitii'-t :> .11 . *t t*, !** * .it t *
1 ! .my '-rt:< 1:1.1'"*. II  *.iM>? bi: 1.1 .vi iliO'.l .Im I -.i.jii" ! tn  p : ..-s nn ..to
I m;
  .-1 ,'.f II It'll 11' II" " I1'  I I'd i> IJfK-iuli.-if 'or t'-i.!.i, '.Il fi II .'-II' ('	'j't III'	fy iriT.!	tN* 1 11, { y-r .f St.: .r . *\
..  : .	m Mu"t	f-oodI'a:. FiJC ii? -itn.i. AtrrM'i.m	i_ Fi. 1.1 ,inti '^.|'i. .i'.uij: o.-.	: t. !. :>	- **'
.i.ti.i 1 -J-.iii 1.1.- i.-iiI'h'' i uuon ihi. it-^iii;i'v- !>. .'i. '., 'h.-i- If.-ii v	rr.11 -r*. Miuti-

rc^oiiu j
			, Calif., 					 19....^^
				 	 of 	;	, County of 			California, has ld, ari*j
			Has bought for the season 19	 to 19		 both inclusive, upon th^
Is and cono'.tions expressed below and on the back hereof, all pejchss of fhe quality and variety hfrretn.frer specified, now growing Qr
h Seller agrees to grow, upon (he following described Ijnds owned leaded by Seller in 						County, California, to-Wij,,
fione and orchard number) 								. .
I "-J
pjid peachei to be delivered at 							, fhe point of delivery
lrnnt Tolerances: (a) When weight of the peaches is determined immediately after containers are filled at a location utilizing wet process
|*r may deduct 		% of weight of peaches and containers for weight of water on surface of peaches and in containers.

Mr'i full address 		
I. WARRANTY OF EXCLUSIVE SALS AND ENCUMBRANCES; Seif.jr represents that he has nof sold or contracted to sell said peachy
e else, and that said peaehrt are and wilt be kept free of crop mortgages, liens, or other encumbrances except as fellows:
2. HAULING: Hauling fo pcinr cf deliver/ shall be by		
		.. . , 			(enter Buyer or 5*11^(
iby Seller, his hauling allowance shall be 							Dollars (5	) per gresi }
peaches, which shall include leading and hauling of all errpry containers and pallets. As used herein "gross ton" shall be construed to rrs^
b weight of the peaches and the csnfairiers, but excluding the wsighr cf the pallets and fhe tare weifhr of the truck. If by Buyer, picj^
fell be loaded by Seller at rcadnde adjoining Seller's property and transaortatior to pairi of delivery shall not operrt-r as an acceptance cf ^
ches or as a waiver of Fuyer's ng.nt to inspect, weigf, a-ccepr or reject any peaches at point of delivery.	*
3. CONTAINERS AND PALLETS: Buyer may f rnish ccnrjmri for delivery of peaches hereunder bur shall not be liable to do so -ey^
it exercise of reasonable effort aeei care. The Seller shall -ay a rental charge of				per net ton of peaches or on* lie)
I bo* or			 P*' k"1 Mch t,rr<* ccnramer is vied m delivering peaches hereunder. Containers and palters if fumry.
fell be used exclusively 'or csiivery ?! pejenes htreuneir jr.d shai! be handled carefully. At close of tuion Seller shall promptly rettr*^
Irit of delivery all containers and p!iets on hand and pay the rejicra^  replacement cost to Buyer of att containers not so returned.
y withhold an amount equal o such cost frcm any moneys payable fa Seller by Buyer. Payment of such costs dots nor pass tit:* to the
ritrs or palled-	^
4, PESTICIDE CONTROL: Seller warrants that no produce sold hereunder has beon. or will be, treated with any "economic po

def'**d in 'he Federal Insecticide, Fun{i;id< and Roaenticide Act, other than (1) those shown in the Pesticide Schedule furnished ^
Buyer applicable for the year in which the crop told hereunder is to be harvested and in accordance with the use data shewn therein;
2>  otherwiie agreed *n *''"< *"fh Buy". Buyer ijy amend tne Poticide Schedule and Siller agrees that upon receiving written *,
i'ce thereof he will comply w>ih the tame. At lejst 48 hours prior to delivery of the crop. Seller shall furnish Eupr jn accurate w i
italement of the pciticide treatment of fhe crop sold hereunder. INoutd Seller breach any of these provisions (which it concluiively *
turned if residues esceed tolerances tel farrh in the Schedule1 in addition to ether remedies Buyer may refuse to accept delivery e+ any
tion or all of ,h* crop. In such event Buyer shall have no obligation to pjy for said crop and StflUr may dispose of it free ef this eonrrj^*
tf Seller >s indebted to Buyer lor materials, services or money furnuhed in connection with such crop, such indebtedness end any
prefer shall, however, continue to ei.					

I "ARE OP CROP: $?Hr shaii r. It, cultivate, fert-iltie and imgate
cultorra e right, at its
to direct the time and r*eihid of harvvting.
SPECIFICATIONS: Seiier snali deliver at point of denvery,
fly after harvesting, all peacr.s covered hereby cf good shape.
>. and suitable for cjnrnnj as herein defined, at rh* star? of
ty 8uyer may require, free from worms, worm jge,
V rof, brown rof, blaik flesh, green core, overripe poaches, wind-
|jlit pits, mildew, scab, sunburn, red streaks in the flesh, bru.ses,
 or insect damage, hail damage, San Jose scale, shothole
or other imperfections. Ail peaches shall also be of a color and
p suitable for canning into Choice grade as such grade is gen-
understood in the canning trade.
No. 1 Peaches shall be 2Va inches or more in diameter.
Spicing or Pickling Peacher. shall be leis than 2Yb inches in
EXCESS TONNAGE; Buyer shall have the option to take ail the
peaches at the price set forth in the face hereof, such election
pxercised in wr' ing as in each separate variety prior to the date
 I delivery. If Buyer does not elect to fake the excels cf rhe
tied tonnage, he si tall notify Seller in writing as above specified,
ich tonnage is hereby released from this contract.
REJECTIONS: Buyer may reject any peaches delivered or tendered
livery hereunder net complying with the terms and conditions
f and may charge the same and all costs, freight and expenses
r incurred in connection with receipt and return thereof back to
his J^ent or truckman; provided, however, that the rejection
t delivery or partial delivery or any grading down or restating of
fclivery or partial delivery, at point of delivery specified herein by
jhall not relieve Seller of his obligations r-j deliver rhe balance
i peaches purchased hereunder, and to this extent this contract is
ibL. Buyer may also reject any delivery cr partial delivery con-
g in excess of 10% culls or in excess of 2% Rot andor Brown
if in excess of I 9b wormy or worm damaged peaches. Culis shall
T cf sr.y peaches "Ot rrnfnrmmg tn graHp *ii* and quality
cations set forth in paragraph 6 hereof.
CXADI.NG: Unless Buyer exercises the option provided in para-
7, if does not want delivered hereunder any peaches other than
implying with ihe grade and cuality for which a price has been
led on the face hereof. Seller therefore should keep all such
peaches out of deliveries. If any such peaches are found in the
iierj 0# any delivery mingling with the grade or quality for whicn
: has beifn so specified, Buyer may retain rhe same and pay
only 5 1.00 per ton.
1r may grade, at its option, any delivery or partial delivery or
wi thereof. In the latter e--nt, the grade of fne portion shall
*sh :he grade of the delivery.
 PAYMENT: Payment for each week's deliveries shall be made
iday of the following week. Failure of Buyer to so pay .shall nor
fute a breach of contract until Seller makes written demand
Suyer for payment and Buyer rai's to pa> for a period of "rry-
t24) hours. Demand shall be dserred mace hereunder wnn
receives wntlen demand by r->stered letter, through the United
i mad, addressed to Buyer a: me address on tre face cr tms
ct. tf SeCf rnakes such demand prior to final 'delivery,, suver
p*y interest at six per eerr 6;a) per annum, begirmng 'Si'ty
rltyi after final delivery, cr. al< sums remaining unpaid cn jjd
Seller authorizes Buyer ra pay for his account any f*es or
s payable by Seller ur.der any Governmental order, regu!ar,cn v
PASSAGE Of TITLE AND DELIVERY; Th* crops sold heresy
be identified and tirle lhere*: i"jll cjss hereunder to Buyr i.'
as to existing crops upon execution hereof and (2) a] to nonexisrinj
crops as sson as the n in S"5>Ir- until acrual delive-y n Buy'.r.
it is understood that harvesting will be *o arranged that peaches cov-
ered by fh.s contract will nor be " add to any of rhe terms or condiri-ns
specified herein except by a writing duly executed by said repre-
sentative or agent.
C.	ARBITRATION: If any controversy shall arise hereunder between
the parties hereto, such controversy shall be determined by arbitration.
All arbitrations shall be by three arbitrators, one of whom shall
appointed by the Seller, one by the Buyer, and the third shall be ap-
pointed joinrly by the other two. The arbitrators shall in all cases b--~
familiar wirh the growing and canning of peaches. The determination
of rhe majority of the arbitrators shall be binding and final upon the
parties herero.
shall be deemed modified to the extent necessary to comply with
valid Sratc and Federal laws and any valid order, regulation or license
pursuant thereto and any valid marketing agreement or order under
the authority of lavr.
E.	TIME OF ESSENCE: Tim* is of the essence of this contract.
F.	NOTICES: Except as herein otherwise expressly provided, any
rorice or demand hereunder may be given personally, and shall also
be deemed n have been given or made when deposited in the United
States mail nd registere-, addressed to th* party to whom directed
at his last known address.
G.	FAIR LABOR STANDARDS ACT: SIIr guarantee* (hat alt ot
the produce subject to this contract was or will be produced in c=m
!' irxe with all applicable requirement* of 5eetior*s 6, 7. and 12 cf
he Fair Labor Standards Act, as amended, and all regulations ancj
;rders cf rr U S. C*partmenr cf Labor osued under Section 1 <
hereof, and that upon completion cf Seller's perf;rmanc* hereunder
Seller will promptly deliver ra Buyer a written cerrricar; :e rhe effect
rnjt such requirements have been complied with.
t*e hjt r; art.cte sold hereunder r. ~.r wni b iciulterared or m<^>
i*J"SeC w.rrim rhe meaning of any law and g2vernmtnr.il regulation
jrj .n oar? the Federal Feed. Drug ad Chimeric Act June 2S*
1933. as a.s.-ded. ard that no such article wiil be produces  shtppM
m viturnn at Srcfitn 404 or JGItdi cf sj'd Act.
June 29. 197)

fThu form i>	J '" th*	* of Buyer and Seller *like)
			...., onf,		1^
.... of 			, County of	r?it.:... shall be at roadside adjoining Sailer's property, or at			......					
Importation to point of delivery shall not operate as an acceptance of any vegetables or as a waiver of Buyer's right to inspect, weigh, accept'
1 joy vegetables at point of delivery.
J. CONTAINERS; 	fc5C&4jLe*'mJ.	 	(Enter Buyer or Seller) shall furnish containers and pallets for delivery of vegetable,
kr. If required to be furnished by olivet, the following provisions of this paragraph shall apply. Buyer shall not be liable to furnish such cor)r
Clltrs beyond the exercise of reasonable effort and Care. Containers and pallets shall be used exclusively for delivery of vegetables hereung^'
J) be handled carefully. Seller shall prorrptly return to point of delivery all containers, pallets and other equipment of fj^yer on hand ar"i p.
kinabe replacement cost to Buyer of all containers, pallets and equipment tost, damaged or destroyed. Buyer may withhold an amount equal
Pf'om any moneys payable to Seller by Buyer. Payment of such costs does not pass title to the container!, pallets or equipment.	~
4. PAYMENT: Payments for deliveries shall be made as follow*: ...EA-A/rL

lire of Buyer to so pay shall not constitute a breach of contract until Seller makes written demand upon Buyer for payment and Buyer fail*~V"
period of one week. Demand shall be deemed made hereunder when Buyer receives written demand by registered letter, through the Unites J
I, addressed to Buyer at the address on the face of this contract.
t$. SPECIFICATIONS: Seller shall deliver, at .point of delivery, promptly after harvesting, all vegetables suitable for freezing as herein
rod by this contract, m the condition Buyer may require, in order to meet the tolerances permitted by and requirements of the United Stat^*
prug Administration, and in all respects conforming to any applicable Pure Food & Drug requirements of the State or political subdivision
hich this contract is to be performed and the crop is to be processed.	^
4. REJECTIONS: Buyer may reject any vegetables delivered or rendered for delivery hereunder not complying with this contract and may
ajme and all costs, freight and expenses incurred m connection with the receipt and return thereof back to Seller, giving nonce in writing
l reiection to Seller, or his agent, provided, however, that the rejection of any delivery or partial delivery or any grading down or regrading ?
<'V or partial delivery at point of delivery spec.fied herein by Buyer, shall not relieve the Seller from his obligation to deliver the balance
jrables purchased hereunder, and to this extent this contract is severable.	**
7. GRADING BY BUYER: Irrespective of any provisions of this contract relating to the poml ol delivery or passage of title. Buyer1 shall h*.
k to grade tne vegetables delivered hereunder at its plant and th right of rciectien is reserved to the Buyer until after such grading. Nothing , *
Lrjpn should be construed to prevent the application of bona fide third party grading'. Seder shall use every effort to keep delivery free fror^
g jnii parts thereof subject tc reaction Buyer does not want same, as they cause an undue economic burden on Buyer, but if included n tK^
" Buve' may	x"1* 'or such use as Su rer ma r rrnkr	^v- -. - ^	r . .	n

- _ 	v 			jou Harvesting. tne ,
It J. ir/er.?0 f rhi; p.i i.ifl'.iph Buyer shjll, alter notice in writing to Seller, tie relieved of any obli i1
,:cpr any unj^ljljlcs hereunder. id Se'ior sh.ili be liable for gll	caused Buyer on jfuunt of ;uch breach.
11.	CARE OF CROP: Seller s^al! r.!l cultivate fertilize, weed, irnf;jte ipra> or dujt fcr in-cct or disease control. all m tl.o manner Custorr,
jdjptcd fo tlu1 proper core onj ir-.w"*. of the Ctsl CUilitv of vegetables r ^ir, J by thi, _c.h seed for the planting of r-p hereunder, Seller shal
m and use the lame and none other w r-.cut the written consent ol Buyer Buyer wjrrariti to the extent of the purchase price that seeds fur-r] I
js described on the container, tag. r aL.el, within recc.gnned tolerances, and gives n.j >,tkcr cr further warranty, express or implied (includirv,
ed warranty of merchantability or ;r -!:ress for a particular purpose), and rr.ak.es no representations as to description, quality, variety, prodmi
or any other matter, of any sc^d f-ri-.-ri
k, interruption of power, and any act cf governmental cr military authorities, or (b) that he fails to perform by reason of action t*ken in a jj
^te, including but not restricted to tcckcuts Buyer may during such period accept such portion of the crop as Buyer, in its judgment, can eco,1;!
 proce.s. Any crop that Buyer fails ro accept under the terms of this paragraph 13 sh.MI be automatically released for sale and delivery eli^jl
ller. ,
14.	WAIVER OF TERMi OF CONTRACT OR BREACH THEREOF: No failure or omission by either party to in'ist upon or enforce any 0|
%% of this contract breached by t>s otner shall be deemed a waiver unless such waiver shall be in writing. No representative or agent of Buy^r |
any authority to waive, change or add ro any of the terms or conditio.'.s specified herein except by a writing duly executed by said represent!
15.	ARBITRATION: If any conrrcversy involving a quei ion of fact shall arise hereunder betv jen the parties hereto, such controversy sh^
mtned by arbitration. All arbitrations shall be by three arbitrators, one of whom shall be appointed by the Seller, one by the Buyer, and th*. ;
be appointed jointly by the ether two The arbitrators shall in .ill cases be familiar with the growing and freezing of vegetables. No of|!
Joye*. agent or representative cf the ^fjtral Government ?r any department thercf or of any St .te. County, City or Municipal Government Qf:'!
ch or department thereof shall be el.g .le to act as an arbitrator under this agreement. The determination of the majority of the arbitrator^ h
oding and ftnal upon the parties hereto
M. I EGISLATION OR MARKETING AGREEMENT: This contract shall he deemed modified to the extent necessary fo comply with Stater an^
U'ws and any order, regulation or license pursuant (hereto, and any marketing agreement or order under the authority of law. Seller authority
pay for his account any fees or charges payable by Selltr under any governmental order, regulation, or license.	V
17.	FAIR LABOR STANDARDS ACT: Seller guarantees that all of the produce iubjecf to this contract was or will be produced in compliancy ;i
pplicable requirements of Sections 6. 7, jnd 12 of the Fair Labor StanrtarrU Arr, 3 amended, and all regulations .<;'
; meaning of any law and governmental regulations, and m pamcuUr the Federal Feed, Drug and Cosmetic Act of June 25, 1933, as arr>^|!
|haf no such article will be prcduced cr snipped in v.olancn ot Section <04 or 30 I'd) of ziid Act.	?

20. PESTICIDE CONTROL: Seller v. jrrar.ts that no produce sold hereunder has butn,  ' will be, treated with any "economic poison" ^ i,
 fined in rhe Federal Insecticide, Fung.'.:de ana Rodcnticide Act as amended or any federal act or regulation which may supersede it relating
Y regulation of pesticides, other than < I j those shown in the Pesticide Schedule furnished by Buyer applicable for the year in which rhe cro2
Id hereunder is to be harvested and m accordance with the use data shewn thereon; or .2) as otherwise agreed in writing with Buyer.
iy amend the Pesticide Schedule and Seder agrees that upon receiving written notice thereof he will comply with the same. At fe.Mt 48 h  Ur*^
If* ro delivery cf rhe crop, Sel .* shall furnish B.'ver in accurate written statement of rh pesticide treatment of the crop told hereunder. ShocijJS'
||er breach any of these provisions 'v.h.ch -. ccnc'.ujiveiy presumed if re>ioi-js exceed tclerances set forth in the Schedule) in addition to oth,^
h".edies. Buyer may refuse to accept dei.^ery of any psrtion or all of the crop In such evtnf Buyer shal' have no cbl^ation to pay fcr said cr^J-
^ Seller May dupose of it free of fh: c-nrract. If Sellor is indebted to Buyer for materials, services or money furnished in connection with Svj^S?
such indebtedness and any secur ty th^relor shjii, however, continue fo exist.	1
; Address
5423 t. 14th ST., OAKLAND, CALIFORNIA 94*21
Payment ti; t-tf m.wlc f^'

SJIor's AJi'^s

fcju	for
! r.z.2 adopts \-7 tli" CalifcrrJLa Frco-rrs A.*?ocI&tioa vith Jtcrlniona to
wcruury 2?, 2SS!> for the* Co?r*c3lt\ncp oT L'uycr ad teller (illk*.
1	rJP. t?TZ'r Jt'*7	cone 1st of	p), oplnach of ccod typical
{": -is color, Tree froa d?cn?p	a!r.or dz~p~'* (2), wcx-us as J Injects, mjor
i1r" rf l^.vvfu cr ctrzo (3), v^c In, roo^.T * root stabs (/,), pint otcnr: 15) rvsc'iive
ol- v; nn-i i;t<-3 lrscih. (6), eccd -talks (7), cro^n  '
^ i^haJLl cosoiot of spinach which does not coet tbe reqaircfcrato of tbo forrnoln-r

j Jet eC spinach infcstcjl vith inrKCta incluiinc yores or uphlds or srrlcuoly
r - --r:\ ty ir7 of tbo above listo! defects tcyoxil ttin level normlly accepted in
tha frosea cplxur.h industry, cay tc>:V c^ar.a thit spinich is not c:rcrc3l7r3y wilted.
{;?) ""l.'sor JrjEso" Brans ncj aotior^Mo dolccl, ir.Jary, or discoloration on a
c\r~Io l-:oT or et^a which in r<\~7r.ato c-cccdo curl wtvs. cqunl to * inch fcy
I ir-c! lit not nor** thm 1 cjoir*? isch, or vliich, mterially aX-Tccta the- fr^ez-
Ir,*: r;.nllt/ of the* spltach.
(3) p- r-aa^CB" cc3U3 ic^cry, diccoloratlco or dscac on a eincle leaf or ot-a.
vr.ich in	cacmds tc arra of appro-'rr.tloy I errau*e irch wvl s^ricur.-
1 y aiTccta tho appearance czU frccalnj quility of tho cpiaacb.
U) "lout ail Hoot Stufctr is thai porUta of t&> cpisach thai 1* fcolov th* cro.m of
t',~ plant.
15) *. inl. .Itrsa" ero ctcaa that iuvo a plsk, rcO, or parpliah cast not typical or
c: : u;l green color,
(C) or - ,-lvo str~3 oni ctca IcD^ht" iactn?3 th-*t not cw 15 per ect J?7 vr-ifcht of
t!ij clrnrl spinach chill ccnr.ict of tlfftw.
(7; " 0 Jtal'.cs0 exo ctcsa graJinj froa tho crater of the spinach plaat vith erod
V:i la or ocfy'-o.
{:) "i-ro-zw" is that portion cT tha spinich plnnt "hero tho leaves ero attftebrd to
Hi? root.
(?) Vr.-o ^oisstcrc" arona all "vicalila or surface aoltur  wch coietaro to b>
froT, growers* tosru^c.
(2C) :z^^r^T, scans nty Injury or defect vhich satorially affect tho apprxutxeo or
freezing quality of the opinach.
. .i:3 rii.CZ.rU7S. Ao goon ea practical a.flr delivery, Ite7*>r ohall 8-lrct nt
l*~rt two rwrcacstativo ICC oiinco carplcs tr.I^n froa tho flxat tmch or tnUrr of
?a at raaloa tLrcuchout tli? lo-J, p.r.l in tho event th? first rs^I#; .Vth
3 r. -".iv to hi rcprraaatativc of thr loii, dj;/licntt> cr.Trpla will hf drawn snl the>
r.v-r-:.o of all oa=?leo taken ohall bo ir;od to datorSiloo cradc._		..
71>7	aro part of tha coat mat tciabor j
. ,r~-. 1	! ,1'i	'* ' ' % -	.? r	*Z	\
mtmmmmmtmm			 i.	immmmmt i i	' ' 	
S*1  ,	- - vr
	,		- Califoraia	. j	| /

It Is Important and useful to examine pesticide jse and
regulation in California for several reasons. Mere
pesticides are used for agricultural purposes In California
than in any other state In the nation. In 1973 183,657,000
pounds of pesticides were sprayed on 26,618,000 acres of
California farm I and. ''Par11 y because of this high use,
California was one of the first states to devefop a system
of pesticide use regulation and it currently has tho most
well developed regulatory system (n the co-untry. In fact,
the California system has been looked at as a model for the
development of a federal system of pesticide use regulation.
For this reason, It is Important to critically examine the
California system. Additionally, for the purposes of this
report, California is the leading state In the production
of ''specialty" crops, crops in which cosmetic quality
standards may play an Important role and in which a substantial
amount of pesticide use may/ci*?tr I butab I e to cosmetic pests.
California Is the leading producer of almonds, apricots,
artichokes, broccoli, grapes, lemons (second in oranges),
lettuce, nectarfnes, peaches, pears, strawberries end tomatoes,
all crops in which cosmetic quality plays an Important role.^*
All fruits and vegetable crops account for 21 percent of
agricultural Insecticide use. Many of these crops account
for a greatly disproportionate usage of pesticides than
would be expected on the basis of their acreage. For example.

apples, which account for 0.07 percent of t6tal crop acreage,
account for 6 percent of all agricultural insecticide use.
Citrus, which accounts for 0.08 percent of total crop acreage,
accounts for 2 percent of all agricultural Insecticide use.4*
Thus, whi le the use of pesticides that may be attributed to
the need to meet cosmetic quality standards cannot be said
to be the bulk of agricultural use, It may be significant
enough to have important consequences for public health
and the stability of the ecosystem, especially as an
accumulative process. Furthe;more, the average figures
tend to obscure the fact that pesticide use attributable to
cosmetic quality standards may be used, at relatively high
concentrations, in localized growing regions. In this
case the consequences for the local environment may be
Vi A H A I r< in ) 4 t a << ^
o y	i vjn i T i ^uh i 
Pesticide use decisions related to cosmetic quality standards
are partially dependent on the pest management technology
which Is available and, just as Important, is acceptable to
the user. Current pest management technology can be
characte-ized by two basic, and sometimes conflicting,
approaches. These characterizations are general, and are not
meant to describe the specific pest management approaches of
Individual pest management advisors, but they are Indicative
of the over-all situation. The approach we shall call
"conventional chemical control" has grown with the production
and use of agricultural chemicals and has become an Important
approach to pest management, especially In the lest two decades.

This; approach is centered around the pragmatic use of agricultural
chemicals for the suppression of specific insect pest populations,
/his often includes the use of chemicals In a preventive
or prophylactic manner and the use of pesticides which have
a broad-spectrum of activity, including toxicity to beneficial
insects and other non-target species, Including humans.
The efficacy of conventional chemical control has been seriously
questioned in recent years by some entomologists. For
example, C.B. Huffaker and Ray F. Smith, of the Department of
Entomology of the University of California at Berkeley, have
written that,
There was (in conventional chemical control) a general
disregard of the fact that even the simplest agricultural
system presents a maze of delicately balanced ecological
Intricacies. Elaborate calender treatment schedules
were developed on a prophylactic basis. Both approaches
not only Ignore the complexity of agroecosystems, but
both of them ignored the two giants of nature's own
system of pest control, i.e., over-the-eons-evoIved
plant resistance and control by natural enemies.
Since the single objective of the unilateral broad-spectrum
chemical approach was total and lasting destruction of the
pests, serious disturbances soon arose. Target species
counterattacked, developing resistance to one material
after another. Adverse effects on natural enemies and
stimulating effects on some pests have released the
target species to rapid resurgence and caused minor or
innocuous ones to become serious pests. Increasing dosages,
and more kinds of, and more frequent, chemical applications
have led to pesticide addiction from which It is difficult
to withdraw. Problems of residues and adverse environmental
effects at places even far removed from treated areas have
led to public clamor against all pesticides.
We do not believe that our Insect problems would simply
disappear if we would stop using Insecticides but we do not
believe the consequences would be quite as Intense,
ubiquitous or prolonged as some would have us believe.
Yet, this public clamor, indeed, threatens to deny the
research needed to assure availability of proper chemicals
to save our crops when needed and, as well, to perpetuate
an enlightened, lasting control program.

The uni lateral chemical approach has not even had the
prolonged success in the control of the Initial insect
targets that was first suggested. Insect problems have
not lessened; they are even greater than before. We
are using more chemicals and against more species of
Insects than ever before. Some agricultural enterprises
are threatened with disaster from mounting pest control
costs, yet poor pest control. 5.
The alternative that Huffaker and Smith, and others, have
proposed is "integrated pest management", Integrated pest
management strategies attempt to take Into account ?ll
the relevant factors that Impinge upon the agroecosystem.
For example, Pimentel lists: pesticides, non-target species,
pathogens, insects, weeds, pollinators, human health, biocontrol
agents, rotations, soil preparations, fertilizer, diversity,
water, plant density, sanitation and plant genetics as relevant
factors. According to Pimentel, "the total costs, benefits,
and risks of the factors in the system can be evaluated and
used as a basis for making sound decisions about pest control
measures." Pimentel concludes that. In general, pesticide
use In the United States could be significantly reduced If,
1.	BloenvIronmentaI pest controls which were replace with
pesticides were again put into full practice wherever possible.
2.	Some or all of the 60 million acres currently diverted
at * cost of $3 to $4 bill ion annual ly were planted to
help balance the Increased crop loss resulting from a
reduction in pesticide use.
3.	A"treat-when-necessary" program based on monitoring
pest populations were Initiated and aircraft spray drift
were reduced..
4.. The public were educated to be concerned for the
safety of their fruits, vegetables, and other produce and
attach less importance to "cosmetic appearance." 6.


While a specific pest may be suppressed by a number of
alternative means, including chemical control, biological
control or cultural control, Integrated pest management is
an over-a I I strategy for maintaining the health and productivity
of the agro-ecosystem. Integrated pest management Includes
the option not to control for an Insect pest when It Is
determined that the costs out-weigh the benefits. As Luck,
van den Bosch and Garcia have recently commented,
This (integrated pest management) represents a change
!n the philosophy of pest control: it utilizes and
builds upon the natural mortality that affects any
pest popu I at I 0j>. , It tolerates uneconomic densities of
pests and It augments natural control with a variety of
techniques that are tailored to be minimally disruptive.
...Thus, there are various techniques and materials that
can be utilized in pest management systems In which
knowledge of the species and their ecosystems permit the
Integration of natural and artificial mortality factors
In mutually augmentative programs. These can lead to
maximum pest control efficiency with minTmum ecological
tmpact.... Under this concept chemical control reverts
from Its present role of a single strategy to that of
a mere tactic. Confusion of the latter with the former
Is a basic reason for much of our current pest control
dI lemma. 7 .
The philosophy of Integrated pest management, when
carried to Its logical conclusion. Implies that. In addition
to the Immediate welfare of the grower, the welfare of other
groups I r. society should be considered In pest management
decisions. However, It Is unlikely that this will be the
case when the pest control advisor Is employed directly by,
and In the Interests of the grower. As was stated at the
1973 IBP Integrated Pest Management Conference on Economic
Injury Evaluations,
There Is often a conflict between farmers and the rest of
society. Farmers on one hand make decisions which directly
affect production costs or yields and thus Influence profits

whereas society may consider a pesticide free environment
to be more important than pest control in an individual
field, farm or area. Therefore, we must consider who
benefits from Pest Management Programs; both farmers
and society should benefit from these programs If they
are to be truly successful.
The cost of using pesticides may be greater than the
benefits which we usually associate with' Increased
yield or better quality because of externalities.
For example, In many of our cost/benefit calculations
we exclude damage to the environment, the hazards In
using pesticides etc., and base our calculations of
benefits only on Increased yield or quality.
Whiln the integrated pest management approach, even when applied
for the direct benefit of a cI Ient grower, takes more of the
total social welfare Into account than the conventional
chemical control approach, there is st.i I I plenty of room
for conflicting goals. To speak to the point, an economic
threshold level of an insect pest population which Is determined
cr the basic of meeting a cosmetic quality standard for the bcncfl
of tne grower may be socially InapproprI ate if. In addition, the
welfare of the farm worker or the long-term stability of the
agro ecosystem is taken into account. Just how such factors
are to be taken into account Is a political and economic problem.
The Integrated pest management approach lends itself to a
consideration of s:ich political and economic factors
while the conventional chemical control approach does not.
The particular approach to pest management that growers
adopt depends on the availability and the effectiveness of
various pest management Information sources. Von Rumker
has studied this problem in relation to corn and soybean
growers In Iowa and Illinois. It Is clear from the von- Rumker

study that the conventional chemical control approach
dominates in Iowa and Illinois corn and soybean farming.
According to von Rumker,
Close to 6 million acres of corn In Illinois were treated
with soil Insecticides in recent years, primarily against
corn rootworms. Entomologists estimate that only about
40 % (2.5 million acres) of this acreage needed treatment.
Concerning control of soil Insects other than corn rootworms,
It Is estimated that of 4.5 - 5.0 million acres per year
treated with chlorinated hydrocarbon Insecticides In
both states in recent years, at least 2.5 million acres
did not need the treatment. However, diagnostic and
predictive methods available to growers are not adequate,
and It is often difficult for them to know whether or
not to use ??n Insecticide. Thus, from an overall standpoint,
a substantial portion of the corn soil insecticide uses
appear unnecessary or wasteful, while most growers
consider their individual decisions to use a preventive
treatment a necessary protection against possible yield
losses. 9.
On sources of pest management information von Rumker comments,
Farmers in the midwest receive Information on pesticides
primarily from pesticide sellers, labels, and other
farmers. University extension specialists, area extension
agents and county agents (farm advisors) are regarded as
very useful sources of Information on pesticide by farmers.
They are very effective communicators, considering their
small numbers In relation to the large number of farmers
they serve. However, these public servants jre outnumbered
by pesticide Industry representatives and pesticide sellers
by wTde margins, and their messages reach only a small
percentage of growers dIrectIy....Many of the farmers
Interviewed expressed Interest In receiving more specific,
Individualized crop protection advice. Some of this
Information is available from public sou-ces, some of It
would have to be adapted to local conditions. However,
there are currently no efferMve, unbiased channels through
which growers could receive such Information regularly
and in a timely fashion from the public agency originators
of the information. '0.
While there is no categorical relationship between the
source of pest management Information and the approach toward
pest management which Is adopted, It Is only to be expected
that chemical company representatives who engage In pest
management advising will tend to promote the conventional


chemical control approach. As Harrison C. Dunnfng comments
in his classic study of the control of pesticides in
California's Imperial Valley,
It is not generally a matter of these field men "loading"
their customers with unnecessary appIicat5ons--the salesman
depends on repeat business and the grower is alert to
being gouged, so this Is unlikely to happen often. Nor
is the problem primarily one of unethical field men who
know there Is some non-chemical solution to a problem
but refuse to disclose it. Rather, the central problem
is that the chemical company field man thoroughly
knows but one techno I egicaI approach to pest problems.
That is the chemical one. Chemicals are his product,
and it is to the resources of the chemical company that
he turns If he has a special problem. Even absent the
pressure put on growers by advertising and that put on
field men through financial rewards tied to their sales
record, it Is entirely natural that ch3mlcal company
field men will view pest problems from the vantage
point of a single technology. II.
The available information Indicates that the situation
in California with regard to pest management information Ts
similar to Illinois and Iowa. However, there are some notable
differences. In California integrated pest management information
Is available not just from some public sources but It Is also
available from some private independent pest management consultants.
Most of th^se private consultants, who have no ties to chenlcal
companies and sell their professional advice rather than
chemicals, are members of the Association of Applied Insect
Ecologlsts, a professional society which explicitly endorses
integrated pest management. The AAIE defines Integrated Pest
Management as "the modern concept of careful monitoring of
crops for insect populations, recognition of economic damage
thresholds and avoidance of pesticide applications on simply
a preventative schedule. IPM Includes environmental and
cultural management, biological control as well as the
careful use of pesticides." AAlE's professional and

I 2
general membership numbers about fifty. 'This can be compared
to the force of pest control advisors employed directly by
private agricultural chemical companies In California.
To determine this Chris Merritt has polled the 133 California
agricultural chemical firms listed in the directory of the
Western Agricultural Chemical Association. Ninety-five of
the firms responded to the poll; 89 percent of the firms
employed agricultural pest control advisors; the total
number Qf the advisors employed by the firms was 1648.
This was a slight underestimation because one of the largest
agricultural chemical companies, Kerr-McGee, did not specify
the number of advisors It employs. If the average 17.35
advisors per firm is projected to all 133 firms the number
of advisors would be about 2300. Obviously, In the private
sector the number of pest control advisors that would lend
to adopt the conventional chemical control approach far
out-numbers those who endorse integrated pest management.
In fact +he fop ^r i cu I tura I chemical f I rms? eftp^oy In
than ten times the membership of AAIE.
excess of 550 advisors, more/The bulk of California's
pest control advlsors'are In the direct employ of private
agricultural chemical companies ar.4 they far out-number
the combined advisors, private and public, that are available
In California to provide Integrated pest management advice.'^'
This Is consistent with Dunning's estimate for imperial
County which was that, "Chemical company field men In the
Imperial Valley now outnumber other Individual sources of
pest control advice, such as consulting entomologists or
Ca11fornI a AgrIcuItitraI Extension Service farm advisers, by

a ratio of at least five to one." ' ^ *
Gutierrez and l.oew luivo polled 1700 California cotton
growers on their preferredi;ource of pest management Information.
Of the 415 growers that responded, 66 percent list chemical
company representatives as the preferred source, 13 percent
listed independent pest management consultants, and 17 percent
listed themselves. Fifty-seven percent af the growers reported
using a prophylactic mitgeide, a strong indication of a
conventional chemical control approach. Gutierrez and Loew
could detect no correlation between the grower's decision to
use integrated pest management and grower experience or slze.'^.
The 13 percent figure for the use of independent pest management
consultants is probably atypical ly high because Integrated
pest management has made more head-way into cotton than any
other crop in California.
Based on an Intensive survey of pest control practices-
In cotton, alfalfa hay, process tomatoes, and grapes In
California, Wayne Wi I ley determined that, in 1972 8.7 percent
of these crops, by acreage, were under Integrated pest
management. For sugar beets, nuts, deciduous fruits, vegetables,
melons, and alfalfa seed, 6.7 percent of the crops were under
Integrated pest management. The to^al revenue of the Independent
pest management consulting industry in 1972 was $3 million.
This compares to a total pest control Industry revenue of
$600 mil I Ion. I6*
Data from a survey of the California citrus Industry by
Norgaard Indicates 1hat about 8 percent of California orange
growers were under integrated post management In 1972.'^*

In evaluating the factors which determine growers'
decision to adopt, or not to adopt, integrated pest management,
Wi I ley observes that,
Several consultants Indicated that they would not seek to
expand the acreage served until they become certain that
existing ci ien+s are satisfied. The implication is that
the growers must develop enough confidence tn the consultant
so that an occasional less than satisfactory per f oririance
will be overlooked. Such poor performance vi I I Inevitably
happen to even the best consultant due to the complexity
of the agroecosystem that he attempts to control. The
crux of the problem vis-a-vls the grower's confidence Is
hat when poor performance occurs, the tendency is to
place the blame on the consultant's low pesticide use
at certain times when pest pupulations are present.
However, the fact often Is that a heavier use of pesticides
vjou^d not have provided economically viable control.
Subject to massive pesticide advertisement via the
media and salesmanship centered around an exploitation
of the grower's ever present fear o< losses, the tendency
among growers to single out the consultant's low pesticide
use persists. Instances In which pesticide salesmen
have approached growers immediately after a consultant has
indicated that a pesticide treatment should not be
undertaken have occurred. The salesman's strategy in
those cases was to "fear talk" the grower into a lack
of confidence tn the consultants Judgement. S'ich fear
is easy to exploit when a pest present and can be
visually Identified for the grower by the salesman. Thus,
the uncertainty to the consultant which accompanies his
attempt to gain the confidence of a sufficient number of
clients Is a key factor In the availability of Information
services. 18.
It should be added that the existence of stringent cosmetic
quality standards can only magnify the "fear factor" Whether
It ortglnates In the promotional activities of the pesticide
salesman or the mind of the grower.

regulation or plsticidc usi: in cali torn i a
California has a well developed system of pesticide use
regulation. Pesticide dea-lers, pest control operators, and
post advisors are licensed by the State Department of
Agriculture. Pesticide use permits must be obtained by
operators from County Agricultural Commissioners and pesticide
use reports must be filed with the County Commissioners.
The County Commissioners are also responsible for enforcing
pesticide use regulations, including the farm worker safety
regulations promulgated by the Environmental Protection Agency. 7
In 1972 Harrison C. Dunning studied the control of pesticides
in Imperial County. The most intense use or pesticides In
California takes place In Imperial County and It has
traditionally lead the state In the development of pesticide
use regulation. Many of the programs first Implemented In
Imperial County have later been adopted state-wide and are
also being seriously considered by national pesticide policy
makers. For this reason, we summarize some of Dunning's
findings here.
Dunning, as well as others. Is a little disturbed about
the political origin of County Agricultural Commissioners,
noting that they are "hired and fired by the county board of
supervisors, which in rural counties generally Is dominated
by local growers." The Commlssloers see themselves as
politically neutral. In response to a recently proposed
bill which would have required the election of County Agricultural
Commissioners "to assure agricultural workers are glvon as

much attention as tho growers," the California Agricultural
Commissioners Association stated that the commissioners
"are the least poiiticaIIy-orien ted group of any, and If we
had to start playing politics our office simple would not
function as well."
While the commissioners we spoke to appeared to be
sincere and conscientious in regard to their basic regulatory
duties, this is not to say that we did not detect a bias
In their perspective to-ard pesticide use and other mutters.
For example, some of the commissioners are growers themselves;
It is only natural that they would tend to Identify more
with the interest of the grower than the farm worker, whose
health and safety they are charged with protecting.
Robert M. Howie, Agricultural Commissioner for Riverside
County, stated thdi,
In my opinion, we, as a society, are on the brink of
over-kill in our Imposing of restrictions on pesticides.
Agricultural production must be increased to meet human
needs and chemical pesticides are necessary to this
Increased production. Without pesticides, public health
would be In jeopardy; the sociological aspects of a food
shortage are self-evident; and, at least In this county,
there has been no noticeable deter IoratI on of environmental
quality because of the heavy and sustained use of pesticides.
Quite the contrary is true. Without the use of r.'cessary
pesticides ws would have health and sociological problems;
sociological problems involving hungry people and Increased
unemployment; r>nd we wouldn't enjoy our present environment
because the depredations of pests would soon discourage
the cultivation of orchards and crops without which
Riverside County would revert to desert.
Agriculture commissioners are, of course, entitled to their
opinions, but it must be recognized that statements such as
this are not based upon scientific analysis of the situation
but reflect a political orientation toward the use and regulation

of pesti cIdes.
Dunning found several deficiencies In the enforcement
of pesticide regulations in Imperial County. He found the
job permit system to be both cumbersome and Inadequate;
Dunning writes.
With the manpower available, this is inevitable, for
the quantity of applications forbids meaningful Individual
review within the time available. Furthermore, there is
insufficient information upon which to base a decision.
Permit applications presently show only the pesticide(s),
location of the area to be treated, grower's name and
address, total acres to be treated, commodity, pest(s),
type of material (dust, spray, or other) and method of
application. This enable one to determine some basics
on label compliance, but little else- If pesticide use
were limited to "need" for example, and if the permit
system were to be looked to for enforcement of that
concept, the;: the regulatory officials engaged in review
of permit applications would have to have far more
information in order to make Intelligent decisions.
In fact, given the complexity of pest control, It
would probably be necessary for an official to visit
the field to be treated under the permit for which
for which application is made. Ultimately the most
serious contemporary nee*4 in pesticide use Is sound
Judgement exercised by decision makers with ecological
awareness, and this need will not be met simply by
Insistence upon filling out and review of forms'^
Indeed, Agricultural Commissioners complained to us that they
reeded for man-power for field inspection, and that they
^id not have adequate resources to enforce 4 he new EPA
orker safety regulatIons
Dunning also noted that when pest control operaters
'iolate regulations, sanctions are weak. A criminal sanction
*'fsts, but It is rarely used, and even when it is sought by
'"mml ss I oners district attorneys throughout California have
*^n reluctant to comply. Dunning noted the use, In Imperial
'"nty of mass appeals by the Agricultural Commissioner:

For example, pest control operaters have befcn asked to
avoid spraying fields with workers in them; to take
precautions against the drift of sulphur, an Irritant
to the eyes, onto residential properties; and to avoid
applications which do not conform to the product's
registrati on, unless special authorization Is obtained.
All the acts cautioned against are unlawful, and the warnings
suggest that the Agricultural Commissioner's office
has had reason to believe they were taking place with
some froquency. A general warning may be helpful In
curbing such violations, but the use of this technique
also seems to reflect the present lack of any "middle 25
level" sanction for violations by pest control operators.
Agricultural Commissioners we talked to seemed to rely on
voluntary compliance motivated, In part, by fear of the
criminal sanctions, that exist for vlolaiing the regulation.
Yet, according to Dunning, these sanctions are generally
not used.^
Imperial County pioneered the licensing of pest control
advisers. Pest control advisers are required to register,
Since "the Dunning study, the examination requirement -for
pest control advisers has become a state-wide requirement.
Barry W{ Ik, who has a masters degree in entomology end has
worked as a staff research associate in entomology for five
years, took and passed the state examination In 1975.
Wilk felt that anybody who carefully studied the study
guides provided by the state could pass the examination
and that passage of the examination would not qualify the
individual to be a competent post control advisor. Wilk
spoke to another person taking the exam who stated that
he had taken a course at Modesto Junior College In which
he had been drilled in many questions which were Identical
or similar to those which appeared on the examination.
AdditIonaJiy, Wilk's former employer, a large cotton grower
who had previously worked for a major agricultural chemical
company in Los Angeles, offered Wilk a large stack of past
exam questions when Wilk Informed hfm that he Intended to
take the examination. Wilk said that his Impression was
that these questions were available to the employees of
agricultural chemical' companies who were preparing to take
the examination?^ Ironically, we -.vere refused copies of
past examinations on the grounds that the validity of the
examination depended on this security measure.
Wilk proposed that a more valid certification procedure
would require a series of courses In pest management, similar
to certain pest management courses taught at the University
of California, supervised field experience, and an examination
which required the Individual to explain how he would deal
with specific pest management situation*	sclantlMr

justification for the proposed course of action. In any
case, there is no evidence that the current licensing procedure
for pest control advisers has improved the quality of pest
management information available in California. Dunning
proposes that this goal could be approached by the simple
measure of making it illegal for any licensed pest control
adviser to be an employee of, or have financial interest In
any agricultural chemical company, or any company which has
a financial Interest in any pest control technology.^
Dunning found basic failures at the state level In
taking the initiative on pesticide policy. In 1971 the
State's Director of Agriculture determined that Integrated
control would be officially supported as the best method
for dealing with agricultural pest problems, but there has
been little done to implement this decision, according to
Dunn I ng .31
According to Dunning the Department of Agriculture has
also failed to follow-through on state legislation, enacted
in 1969> which required the development of "on orderly
program for the continuous evaluation of all economic poisons
(pesticides) actually registered" tn order to "endeavor to
eliminate from use In the state any economic poison which endangers
the agrlcultrual or nonagrIcuIturaI environment. Is not beneficial
for the pusposes for which It Is sold, or Is misrepresented."
The Department of Agriculture has stated that It simple did not
have the resources to carry out such an ambitious program.
However, the department has been criticized by th$ state's
Legislative Analyst for wasting Its resources:

One reason "the registration workload ts not handled on a
timely basis is because the registration staff spends a
large portion of its time correcting errors in the
applications for registration or requesting copies of
the proposed label. This time-consuming and expensive
practice of correcting errors should be curtailed. It
Is the responsibility of the registrant prior to
submitting the application to assure that it Is correct.
The department now permits itself to be used as a service
arm of the industry which it Is to regulate. Much of the
time which should be spent implementing new statutory
policies is diverted to performing a service for the
most inefficient registrants of economic poisons.'2
Dunning reviews three situations in which the? county
permit system was used to Influence pesticide use practices.
In the first case rather strict regulations were placed on
the timing of pesticide use in order to protect honey bees
in Imperial County. This program has apparently been
successful. It should be noted, however, that there has
historically been a well organized and vocal group of bee
Keepers In the Imperial Valley and similar use regulations
have not been Instituted In other California counties.
In I960, when unacceptably high DDT residues were
found In Imperial Valley alfalfa hay, use permit authority
was used to restrict the use of DDT wifhln one quarter
mile of alafal.'a hay. In this case the Interests of alfalfa
hay growers were at stake, alfalfa Is a leading crop In the
Imperial Valley. Thus, in both these cases the use permit
system was used to protect the Interests of Influential
groups from direct damage to to pesticide use. Furthermore,
the changes that were effectuated were tn the type of
pesticides used and the timing of treatment, not In the

basic approach to pest management.
The third case that Dunning cites involves a conflict between
Integrated pestmanagemont for the cotton pink bollworm and
a state promoted chemical control program. In this case
the chemical control program won out, with dlsast rous
consequences for Imperial Valley growers. There were
several reasons for this but it seems clear that there Is
nothing Intrinsic to the current pesticide regulatory system
that necessarily encourages integrated pest management or
prevents unsound and unnecessary chemical treatment, especially
if there is nothing blatantly illegal about It. This
seems to be especially true If there Is no strong, well
organized interest group which Is able to lobby directly at
the county level for a specific pesticide use policy.
Against the pressures on growers to use chemical control to
meet cosmetic quality standards, a phenomenon which Dunning*
observed In Imperial County, there Is no effective advocate
for the health of the farm worker, the public and the environment
In the current pesticide use regulatory system. The current
system 16, at Its best, only capable of detecting and
regulating abuses of pesticide use, within the context of
chemical control; It does not challenge or Influence the
basic approach to pest management*
It Is for this reason that Dunning proposes economic
Incentives aimed at Influencing pest management practices.
He proposes such things as a tax on the use of broad-spectrum
pesticides, more effective licensing examinations for pest
control advisors, and the establishment of pest management
districts. Wayne Willey has also proposed f

subsidy to advisers wlio provide integrated pest management iti-
formation. However, as Dunning recognizes, proposals such
as -these are, have, and will continue to meet strong political
opposition from chemical companies and pest control operators
and advisors who are dependent upon the chemical control
Another possible approach is to look to other outside
incentives which, by representing the interests of other
groups in society, may produce Incentives for the grower
and the pest control advisor to learn to depend less on
ch smlc-il control and to put a lower priority on such factors
as cosmetic quality standards* An obvious example Is trte
recent system of farm worker health and safety regulations
promulgated by the Environmental Protecll^n Agency. Not
only does tNs system serve the vitally Important function
oi pioieclihg the health of the farm worker, and consequently
the health of the public and the environment, buteffecttve
protection of the farm worker from the hazards of pesticides
could have the effect of encouraging more sound pest
management practices. For th f s reason, we turn to an
examination of an important part of this system, pesticide
re-entry Interval for farm workers.

We will now consider the value of re-entry intervals as a method of
protecting field workers from pesticide poisoning. In 1970 the State
Pesticide Advisory Committee appointed Dr. Thomas Milby and Dr. Dwight
Culver as a sub-committee on worker safety. They arrived at the concept
of worker re-entry intervals as the method to protect field workers ex-
posed to pesticide residues. An interval was set up tor a number of
pesticides on several crops. Workers were not to re-enter the field until
the specific interval had elapsed after the application of the pesticide.
The crops chosen were crops in which poisoning incidents had been reported.
These crops generally involve a large degree of contact with the foliage
in harvesting. The crops are citrus, apples, peaches-nectarines, and grapes.
Dr. Ephraim Kahn, Pesticide Coordinator for the California State
Health Department lists 7 factors Important in determining the re-entry
intervals. They are as follows:
1.	Toxicity of the compound.
2.	Rate of application.
3.	Rate of degradation of the compound on the foliage of the given crop.
4.	Effect of formulation and concentration on the rate of degradation.
5.	Amount of exposure Involved in harvesting the crop.
6.	Relative magnitude and rate of absorbtion In exposed workers by
different routes for each residue.
7.	Chemical alteration of the residue by soil content, temperature, etc.
According to Kahn only the first two of these factors were documented
with any degree of reliability. For the rest the committee had to rely on
paltry epidemiological evidence, and extrapolation from the scattered data

in a few studies. In discussions with investigators close to the re-entry
problem, the opinions expressed by Dr. Kahn were confirmed. Specifically
the opinion was generally held that a large degree of guesswork was in-
volved in the setting of the re-entry intervals, and that there is every
likelihood that some are significantly in error. In support of these re-
entry times Kahn notes that there have been no major incidents reported
of poisoning since their adoption in 1971.
Among the significant criticism of the existing re-entry times is
one jjade by Thomas \,effingwell, an agricultural chemist with a project
studying re-entry times. According to Leffingwell the re-entry times
were set using degradation information for the chemicals based either on
degradation in the laboratory or on the edibie portion. The relevant
number, however, is the degradation time on the foliage, and this frequently
can be quite different from either of the other figures. In other words we
must conclude that a lot of important information necessary to the setting
of re-entry times was not available when they were established.
Since 1971 several projects have been undertaken to study the estab-
lished re-entry times. We report on the results as far as they are avail-
able and relevant to our project.
One study was performed under the direction of Dr. Robert Spear and Dr.
Thomas Milby. Thid study, which is scill in prugress, involved the in-
vestigation of cholinestera^e depression in workers harvesting Valencia
oranges in a field that had been sprayed with parathion. The amount of
pesticide applied was varied from field to field in such a way as to make
the best determination of the parathion decay. An Important aim of the
study was to determine how much of the toxicity could be attributed to the
parathion. It was not an Immediate aim of the study to determine the safety
of fields at particular times compared to the re-eatry Intervals.

However, for our purposes, some important information can be ascertained
concerning the efficacy of the re-entry intervals. In the one field studied
which was a legal field, that is where the workers entered after the re-entry
interval had elapsed, all the workers showed significant cholinesterase de-
pression. Four pounds per acre of parathion were applied to this field, and
the workers entered after 24 days, with the re-entry time being 21 days. All
the people working in this field showed cholinesterase depression of at
least 20% after 8 to 12 hours of work. Most of the subjects were college
students whose work rate was considerably slower than that of the farm
laborers, and the cholinesterase depression is closely correlated with work
rate. Two subjects who were also farm laborers showed cholinesterase
depressions of 25% to 32% after about 8 to 12 hours of work. The experiment
was terminated when the high level of cholinesterase depression was noted.
None of fhp subjects complained of symptoms of choliaesteirase poisoning
at this point.
Another result which came out of the study was that the offending sub-
stance is pavaoxon, a decay product of parathion. Also the decay rate for
the paraoxon is smaller than that for the parathion.
A third point dealt-with by Spear is the validity of the re-entry
concept. This concept is based on the belief that the toxicity of a field
is a monotonically	decreasing function in time. Since the dangerous
substance is, at least in this case, a decay product of the original pesti-
cide, it is in principle possible to find a field safe one day, and find that
the toxicity has increased to a higher, unsafe level by the next day. It was
shown that in all groves studied the toxicity decreased monotonically after
the fifth day. Hence, for all practical purposes, the re-entry concept was
valid for these groves, although the possibility of a problem arising

because of the reasons mentioned above should be noted. Another conclusion
of the study is that the establishment of re-entry times on a scientific
basis should begin with the determination of the important parameters of
the decay process.
For our purposes what is most important is the ability of the existing
re-entry interval to provide agricultural workers with safe working con-
ditions. It was clear from this experiment that a field in which the re-
entry regulations were followed was definitely unsafe. Farmworkers, who
normally work at least 5 days a week, had ? 30% cholinesterase depression
in less than a full work day. People working with the project guessed that
a safe re-entry interval would be in the 30-45 day range (compared to the
existing 21 day interval) although It was emphasized that these figures
are merely guesses.
Apparently the most important reason for the re-entry time being too
sh >rt is that it was based on degradation rates of the pesticide on the
edible portion of the fruit. As mentioned, above the relevant figure is
for the foliage. This figure will be different from the figure on the
fruit on the figure in the laboratory. In this case the degradation on
the fruit is slower than on the edible portion.
What the above means is that it is likely that re-entry Intervals
are too short in many cases. It is, of course, reasonable that they may
be too long in about the same number of cases, and may be substantially
correct in a large number of cases. Also there may be other factors at
work to prevent poisoning incidents. For example for some crops In certain
areas, spraying and harvesting schedules are such that no one Is likely to
be in the field within the period of the re-entry interval after spraying.

Moreover, there are variations with place in all the parameters relevant to
setting re-entry intervals. Because of differences in such factors as soil
content, temperature, rainfall the actual safe re-entry period may vary
significantly from area to area.
Even after noting the above mitigating factors, the results of this
experiment clearly indicate that the current re-entry time for parathion
(4 pounds per acre) is too short to protect workers from organophosphate
poisoning. Moreover, and more significantly, they indicate that an
assumption used in establishing re-entry intervals (that degradation time
on foliage is similar to that found or. the fruit, or in the laboratory)
is false, and that even strict adherence to the present re-entry Intervals
may permit organophosphate poisoning of workers in many instances.
Some additional work on re-entry intervals is being done, or has been
done recently, and It is valuable to consider some of It briefly.
A study under the direction of Dr. Wendell Kilgore at U. C. Davis
was conducted to study the validity of the re-entry tine for guthion for
workers Involved in thinning peaches. The study was conducted near
Marysville, California during the summer of 1974. A final report of the
8tudy was not rvailabli at the time of this writing, but the general results
were made available to us by one of the participants in the study, Dr.
Betty Cxson.
In this study the cholinesterase levels of workers thinning peaches
was monitored. The workers entered the field 14 days after spraying with
guthion. Fourteen days is the legal re-entry Interval. Thirty-two sub-
jects participated in the study. Their cholinesterase levels were measured
three times before entering the field, and dally during the time they were

in the field. No significant cholinesterase depression was noted. As a
result it was concluded that 14 days is a safe re-entry interval for thinning
peaches that had been sprayed with guthion. It should be noted, however,
that thinning involves less contact with the foliage than harvesting, and
hence is less likely to produce illness. The results of this experiment
should not be interpreted to imply that 14 days is a safe interval for re-
entering to harvest peaches after spraying with guthion.
The group which performed the above experiment is planning several
additional experiments or check or determine re-entry intervals for
several crops. The results of these, however, were not available at
writing time.
As a result of r. poisoning incident In 1970 among citrus workers in
a field that had been sprayed with guthion and ethion, a thirty day re-
entry time was placed on these chemicals. The manufacturers Involved
(C'ueuiagiu lot jjuchion, and FMC-Niagra for ethion) performed some re-entry;
studies in an attempt to establish shorter re?ntry times. The studies
were severely criticized by the California State Health Community Pesticides
Program. We include a brief discussion of these tests and the criticism
for pedagogical value. They Indicate how science can be distorted (and the
health of people threatened) when such distortion suits the interests of
the people performing the experiment. It is indeed fortunate that people
at the State Department cf Health performed such an excellent service in
pointing out the defects of the study and in preventing the implementation
of lowering the re-entry times as recommended in the studies. Hopefully
this action will present a repetition of such blatant self-serving "pseudo-
science," especially in cases where it may badly damage someone's health.

The authors of the Niagara study concluded that people working in
trees sprayed with ethion emulsifiable concentrate are subjected to no
toxic exposures and that those working with wettable powder probably are
not either. The commentary by the Community Study on pesticides notes
the following problems with the study.
J. The study design could not possibly allow it to find the proper
re-entry interval.
2.	Only one cholinesterase test was performed after exposure. This was
made four days af^er picking commenced. The fact that only one after
exposure test was made makes it virtually Impossible to construct a mean-
ingful time series.
3.	The Niagara analyst assumed that the first measurement In the
series was the normal or baseline cholinesterase value. This assumption
is unfounded since the first samples were drawn on a Friday afternoon,
after the subjects had worked in orange groves all week. Hence It was to
be expected that chis initial measurement already showed cholinesterase
depression from the normal as a result of having worked for a week. Under
these circumstances the closest to a baseline level reading Is the highest
of the pre-exposure readings. Exposure to oxganophosphates nay depress
cholinesterase levels, but nothing is known that elevates exposure of the
"true" normal.
4.	A careful examination of the data using the highest pre-exposure
measurement as the baseline measurement reveals significant cholinesterase
depression in most cases. When this is not so, the trend is In the direc-
tion of depression, and more subjects are needed to properly answer the
question that was posed. There is absolutely no way to conclude that

re-entry at this interval is safe. In the case of re-entry to navel orange
groves sprayed with ethion, 7 pounds per acre, the average depression is
23.2%, quite significant indeed.
The State Health report continues, "In short when submitted to
universally accepted statistical techniques, Niagara's own data disagree
with its; own contentions .... The company's request to return to the
status quo ante (I.e. may be applied up to the day of the harvest) must
be obviously rejected. Ethion is highly toxic to orange pickers seven
dayj after application.
The analysis of the Chemagro study on guthion produced much the same
result. In both cases, the study was faulty in design, and the analysts
came up with a conclusion not at all warranted by the experiment, but
suitable to the purposes for which the experiment was undertaken in the first
place, to lowi_r the re-entry interval. ^
As we mentioned above, variation in soil, temperature and rainfall,
make it extremely difficult to assign one-re-entry time to .ill areas of
the state. We just point out the existence of studies dealing with the
relationships between dislodgeable residues on the foliage and toxicity.
It is possible that such studies will eventually make it practical to
calculate when re-entry is safe by measuring the problem o variation of
toxicity with local conditions. ^^However, the point when this can be done
is still quite a ways in the future, and the current practice of assigning
uniform re-entry intervals will have to be relied upon for some time to
Synergistic Effects
Another possible inadequacy of the current re-entry Intervals is their
lack of proper provision for dealing with possible synergistic effects of

organophosphate pesticides. Pesticides are frequently used in combination.
According to the California State regulation, "Whenever a mixture of two
or more organophosphate pesticides is applied, the safety interval shall
be prolonged by adding to the largest applicable safety interval either:
1.50% of the shortest applicable safety interval, or 2.4 days, whichever
is largest.
While this regulation would suffice for most cases, the possibility
does exist of pronounced synergistic effects, effects which could cause the
combined toxiicities of the pesticides to be greater than could be ade-
quately dealt with by the above provision. Little work has been performed
in looking for synergistic effects of two or more organophosphate com-
pounds. However, one significant investigation was reported by Frawley,
et al. In this study synergistic effects between malathion and EPM
(O-Ethyl-O-P-Nitropher.yl Benzene Thiophosphonate) were examined. Some of
t-hp rpstilt* #r? nuite significant. For example, in rat studies *EPN had an
LD50 of 1400 rag/kg, and malathion an LD50 of 65 mg/kg. (The LD50 is the
dose that produces death in 50% of the animals under test by a particular
mode of administration). However, a combination of the two, 167 mg/kg.
IPN and 6.6 mg/kg. malathion also produced death in half the rats. Thus,
the chemicals were roughly 5 times more toxic when used together than when
applied separately. In the same study the effect of the chemical on
cholinesterase depression was considered. In these experiments the rats
were fed the appropriate compound in the daily diet at the concentration
listed with the following results: EPN at 5 ppm had no effect, EPN at
25 ppm produced about 15% depression on the average. Malathion at 100 ppm
and 500 ppm had no effect. When used in combination of 5 ppm EPN and
100 ppm malathion produced only a small depression, and 25 ppm EPN and

500 ppni malathion produced 80% depression from the baseline chollnesterase
value. So when used together the compounds caused a substantial cholin-
estcrase depression, whereas when used by themselves only a 15% depression
The cholinesterase experiment was performed on dogs with similar
results. In fact, the acute toxicity on dogs was potentiated 25-fold by
giving the pesticides in combination. In the feeding experiments, even
the tolerance level of each agrnt for fruits and vegetables (3 ppm of EPN
and 8 ppm malathion) resulted in potentiating the toxicity determined by
chollnesterase depression. All in all the above experiment points out
forcefully the possibility that exposure to a combination of pesticides
may be far more hazardous thai* would be expected by summing the toxicities
of each when administered separately.
One additional publication is important in this regard. DuBois'
group tested several sets of organophosphate compounds for the potentiating
effects on acute toxicity. In most cases the combined toxicities were
additive or less than additive, but in the following cases a potentiating
effect was found: malathion + EPN (as in the Frawley study), dipterex +
malathion, dipterex + guthion. The ratio of observed to expected toxicities
for these compounds varied from 1.5 to 2.2. In studies with the same com-
pounds at subacute doses, no potentiation was found. It was also reported
that the synergistic effects in combination.where EPN or dipterex vere
present resulted from the inhibition by those compounds of the enzymes
which detoxify other organophosphate compounds.
The author concludes that it is unclear whether the potentiation of
organophosphate compounds is a serious problem in connection with the

consumption of food. He adds, however, "It is clear, however, that acute
exposure to certain combinations of organic phosphates on the same or
successive days during the manufacture or use of these materials should
be avoided." It is further noted that the low mammalian toxicity of some
organophosphates is dependent on their rapid detoxification, and anything
which interferes with this process (an organophosphate pesticide or another
possible contaminant or drug) could seriously increase this toxicity.
The results reported above indicate the possible serious effects of
exposure to some combination of organophosphate insecticides. Hence it is
perfectly possible that the combined u~e of some of the chemicals can and
does cause illness in exposed workers, even though the re-entry regulations
are strictly obeyed. For example, EPN is approved for use on all the
crops for which re-entry standards were established. A reasonable recommen-
dation is that combinations, which according to the above information, ml&ht
have synergistic toxicity, not be approved for use until the re-entry
interval is established for the combination. Moreover, testing should be
universally undertaken to determine if any other possible combination of
organophosphate insecticide might have similar potential toxicity. In
view of the understanding of the mechanism involved this should not be too
difficult, and could result in the prevention of serious illness.
Another obvious limitation of the current re-entry Intervals is that
they offer no protection at all for the crops not covered. As mentioned
above these intervals were established for crops where poisoning incidents
had been reported. These were crops where harvesting generally involved
a large degree of contact with the foliage. Some information exists,

nowever, that indicates the presence of or^anophosphate induced illness
in crops other than those covered (grapes, peaches and nectarines, citrus,
apples). Some of this evidence is summarized below:
1.	During an extensive study of the effect of mechanization on the
tomato industry, conversations were held with a number of persons employed
working on the tomato harvester. The workers complained of frequently
suffering from one or more of the following symptoms: nausea, dizziness,
blurred vision, difficulty in breathing. These symptoms are all symptoms
associated with organophosphate pesticide poisoning. The interviewer was
unaware of this association during the period of the study.
2.	Dr. Ephraim Kahn, of the California State Department of Public
Health, reports that workers harvesting strawberries indicated that they
suffered from symptoms of organophosphate poisoning. The State Public
Health Department has been unable to follow up on this information so far
3.	Soitk* rvf the results of a study by Richart" Howxtt
on estimates of pesticide related illness
are relevant here. Figures were compiled both on the incidence of organo-
phosphate related poisoning, and on man hours lost per 1000 hours. Some
useful information is revealed by a comparison of the two counties examined
in the study - Stanislaus and Monterey. Stanislaus has mostly crops in
which incidents have lsen reported such as peache? and grapes, vhil< the
main crops in Monterey County are lettuce and related crops such as broccoli,
cauliflower, and celery. Howitt's study revealed that the man hours lost
per 1000 hours to pesticide related illness was about 30% higher in Monterey
County than in Stanislaus County. This figure alone indicates that pesti*-
cide related illness in other crops is quite real and significant.

in a particular crop. That is they indicate the relative degree of danger
to working in each crop. They are presented in Table 2.
Table 2
Crop	Unnortnalized Hours Lost Per Thousand Man Hours Wqrked
Grapes	1.7
Lettuce	5.7
Peaches	8.9
Stawberries	1.0
Tomatoes	3.1
Almonds	0.5
Broccoli	2.7
Cauliflower	12.4
Celery	1.61
According to these figures cauliflower is the most dangerous crop in
which to work,*followed by peaches and lettuce. Illness rates for some
crops for which no re-entry times have been established, e.g.* lettuce,
cauliflower, tomatoes, are comparable to the rates in crops generally
considered most dangerous.
Farmworkers outside of California are "protected" by Environmental
Protection Agency Regulations, published in the Federal Register, March 11,
1974. These regulations were severely criticized in a statement by Dr.
Ephraim Kahn, Pesticide Coordinator, California State Department of Public
Health. The most important criticisms are summarized briefly below.
^Though '..he cauliflower figure may be a statistical artifact due to the
small amount of acreage for this crop, this is not true for lettuce and

1. Harvest entry times defined in the regulation do not apply to
workers wearing what is described as "protective clothing." The description
of protective clothing, however, includes shirts with sleeves, full length
trousers, shoes, socks, hats with brins, and gloves. Farmworkers engaged
in tasks involving substantial contact with treated plant surfaces almost
always wear such clothing. If this clothing afforded any meaningful
protection there would have been no poisoning incidents, and there would
not have been significant cholinesterase depression in the re-entry experi-
ments reported above. In fact the available scientific evidence shows
that such common clothing may be worse than worthless. Research by Howard
Maibach, University of California at San Francisco, showed that if parathion
reached the skin, "protective clothing" increased the proportion pene-
trating into the body. Moreover, as much paraoxon penetrates the body as is
screened out by the citrus picking shirt.
In summary the whole set of re-entry times in the EPA regulation does
not apply if what is described as "protective" clothing is worn. However,
the protective clothing is ineffective in preventing orgaaophosphate
poisoning. Hence the set of E.P.A. regulations is worthless in protecting
farm laborers from organophosphate pesticide related illness. It is
reasonable to conclude, therefore, that agricultural workers outside of
California are subject to what could be a very significant overexposure to
organophosphate pesticides, and possible serictus Illness. No studies of the
general incidence of pesticide related illness outside of California have
been performed. We can only speculate that the incidence of such illness
may be high in some areas because of the gross inadequacy of protective

In addition to the first criticism of the regulations, discussed
above, several additional telling criticisms are made by E. Kahn.
2.	The proposed standards ignore the possibility of any synergistic
effects between combinations of pesticides. (See the section on synergisms.)
3.	No data are presented to justify the standards, nor is there any
indication that such data actually exists.
4.	The pesticides included in the regulation apparently were not
selected on the basis of chemical class, toxicity, persistence, or any
other relevant factor. For example, endrin is included, Endrin is an
organochloride insecticide which is not known to be implicated in any
residue poisonings. Some compounds known to be quite toxic are excluded.
These include TEPP, Phosdrin, Thiiuet, Delnav, Torak, Monitor and Phosphamidon.
5.	The proposal makes no mention of the type of data vhlch should be
generated for the protection of agricultural workers, j'hese data are
different from those rpqiHred	(go to next page)

for the protection of the grower and the consumer. Such studies
aro now required "by E.P.A. regulations.
All in all E.P.A. regulations offer essentially no
protection to agricultural workers. This raises the serious
possibility that workers not under the protection of the
California regulations (i,e, workers not working in California)
suffer from a good deal of pesticide related illness, No study
has been conducted to determine the incidence of eucli illness,
Another possible reason that re-entry times have not been
as successful as might be expected in preventing pesticide related
illness is that the regulations may not be strictly obeyed or
enforced, The regulations are valuable only in so far as they
are followed.
The extent to which re-entry regulations are obeyed or enforced
is not easy to determine. In the course of our study Tire have
interviewed several sources who have direct knowledge concerning this
matter and we report the most important results below*
The onus for the enforcement of these regulations is on
each County Agricultural Commissioner, In his doctoral thesis,
Howitt reports the following information on enforcement activities
by all Agricultural Commission ers in the state of California:
Fiscal Year district	Attorney Court Citations	License
Hearings	Issued	Suspensions
1969-70	2	3	56
1970-71	6	3	70
1971-72	2	70
1972-73	-	E3	117
It is difficult to reconcile this extremely low level of
Enforcement activity with the continuing high incidence of
foeticide poisoning among form-workers.

A pilot study is being undertaken by the EPA to study the techniques and
efficacy of enforcement procedures. Tulare County is to be a model county
for this project. As this report is being vritten, the project is just
beginning, and no results are yet available.
Mr. Robert Howie, the Agricultural Commissioner of Riverside County,
was interviewed and commented on this subject. He noted that the use
and enforcement of pesticide regulations began in southern California before
the state introduced re-entry regulations. On the question of enforcement
of the re-entry regulations, he said that there is essentially n(> enforce-
ment in Riserside County because there is no money available for the en-
[At the recent session of the California Legislature a bill to appropriate
additional funds for enforcement of worker safety regulations was passed,
but was vetoed by Governor Reagan. The bill would have appropriated aa
additional $600,000 to County Agricultural Commissioners for enforcement
of worker safety regulations. At present approximately $900,000 is
appropriated for this purpose in revenue from the pesticides' Bill tax.
One reason for proposing this bill is that it was felt by Assemblywoman
Fong, the sponsor, that all the money for enforcement of these regulations
should not come from the industry being regulated. The mill tax money
comes from a tax on the sale of pesticides.
It seems unlikely that the passage of this bill would have brought
about a great improvement in enforcement. Since under current conditions
enforcement is very inadequate, and in some cases non-existent* it is
unlikely that a 67% Increase in funds would make a big difference. It is
reasonable to expect that some version of this bill will pass and be
signed by Governor Brown at the next session of the legislature.]

He added that he assumes that voluntary compliance by growers is high. Mr.
James Stockton, Agricultural Commissioner of Kern County, stated in
an interview that his office does do some enforcement of re-entry
regulations, and that the percentage of non-compliance is small. He also
said that the existing re-entry regulations apparently seem reasonable
most growers, and that he has had few complaints about them.52
Also of interest in this regard are the comments by members and
representatives of the United Farmworkers of America. The comments pre-
sented here were m._de in the course of interviews with union representatives
at several sites in California.
According to Kress Fraley of the UFWA research staff in Keene,
California, state enforcement of worker safety regulations is non-existant.
According to Fraley the only protection available to farmworkers is through
health and safety provisions in union contracts. These contracts provide
for the creation of union health and safety committees which would be
informed when each organophosphate pesticide is sprayed, and would con-
sult on the setting of a time for re-entering the field. In addition some
contracts provided for the banning of parathlon.
Essentially the same opinion was expressed by union representatives
in other parts of the state (Keene is about 30 miles east of Bakersfield,
California). Nancy Kleiber of the UFWa Office in Salinas, California
(Salinas is in Monterey Co.unty, and ttemain crops are lettuce and related
crops) said that there is essentially no state protection of workers from
pesticide related hazards. The crops in the Salinas area generally are
not covered by re-entry regulations, but Kleiber reported some gross vio-
lations such as the spraying of people In the field."**

Dr. Daniel Murphy, of the UFWA clinic in Delano, California,
reported that there is essentially no enforcement of worker protection
regulations. According to Murphy the only protection against pesticide
poisoning available to farmworkers is through UFWA contracts.
A deposition filed with the UFWA by an illegal alien is of interest
here. The person complained of stinging in his eyes and sharp pain in
the ears and the back while working in grape fields. The condition was
diagnosed by a doctor at the UFWA clinic as being pesticide related. The
worker said that the grape leaves contained a sticky substance, and that
when he complained to the foreman, the foreman acted as though the illness
was a joke.
The deposition Indicates first of all the lack of protection for
field workers under existing conditions. Another point of note is the
special vulnerability of illegal aliens who fear even to complain about
their condition, because such complaints could lead to deportation. ^
In conclusion, different sources have differing opinions on the
effectiveness of enforcement procedures and the consequences, and the
actual degree of enforcement may vary from area to area. It does, how-
ever, seem reasonable to conclude that lack of effective enforcement of
pesticide regulations contributes to the high degree of pesticide related
illness in agriculture.
A more effective system might take advantage of the Information
available from the people most concerned with enforcement of re-entry times
agricultural workers. Such a system might utilize worker representatives
to observe and report violations to County Agricultural Cooaaisaloners or
to other agencies such as the state OSIIA. Alternatively, a farmworkers

union might incorporate this function as a part of its regular activities,
as the UFWA has done in some cases.
A final method of assessing the degree and importance of pesticide
related illness among agricultural workers is from interviews with
representatives of agricultural unions and workers at farmworker clinics.
The following information comes largely from interviews with, representatives
of the UHJA and workers in their clinics, but results of a conversation
with a Teamster official at Salinas arc included.
According to Dr. Daniel Murphy of the United Farmworkers Clinic in
Delano, California, it is common for farmworker patients to come to the
clinic with symptoms of organophosphate poisoning. The clinic does not
have the facilities to check on the pesticides used in the field where the
patients were working, or to find out precisely the cause of the symptoms*
Murphy strongly believes, however, that many of the symptoms are
related to pesticides. He said that besides the general discomfort
associated with the symptoms, there are occasionally more serious incidents
in which workers are hospitalized for up to two weeks. Another common
complaint, according to Murphy is of skin rashes due to contact with sulfur.
The pesticide problem was discussed in a brief interview with L. T.
Kennedy, and officials of the Western Conference of Teansters Office in
Salinas, California. According to Kennedy workers in the area who are
covered by Teamster contracts have essentially no problems with pesticides.
He said that the Teamsters had received only about 5 complaints in the
past year of pesticide related illnesses. Kennedy throught that the current

system of state and Federal regulations was sufficient both in provisions
and enforcement to protect workers from any pesticide related illness. He
said that business agents from the union are in the field daily to check for
complaints. In the only provisions in the Teamster contracts regarding
pesticides, the grower agrees to obey state and Federal regulations.^
Representatives of the UFWA gave a very different picture of the pesticide
problem for farmworkers. The UFWA operates a farmworker clinic, in Salinas
for its members. Farmworkers who are not UFWA members, including Teamster
membeis, can and do use the clinic on a i'ee for service basis. Sister
Barbara Jenkins, Clinic Director, reports that it is frequent for patients
to visit the clinic complaining of pesticide poisoning. About 5 people
per week visit the clinic with such complaints. The symptoms are both
symptoms related to organophosphate pesticides, as well as dermatitis and
skin rash, frequently related to sulfur. The UFWA representatives said
that many farmworkers take mild symptoms of organophosphate poisoning for
granted as a normal part of farrawork, and do not bother to seek medical
attention for such illnesses.
In addition to the normal cases of p<-sticide poisoning, from time to
time more serious incldpnts are reported. Typically in Such incidents,
a farmworker will be sprayed while working in the field. Such incidents
may result in illnesses of several weeks duration.
Workers at the farmworker clinic also report that many of the patients
who report pesticide related Illnesses work under Teamster contracts. The
reason that Teamster officials are unaware of pesticide problems Is that
thoy do not look for them, and do not provide any medical facilities for
workers under their contracts.

In conclusion, there is a wealth of evidence that use of pesticides,
under present conditions, causes serious, acute health problems for farm-
workers. This conclusion comes both from studies of the incidence of
pesticide related illness, and consultations with farmworkers and their
representatives. The actual extent of the problem is not known, but we
have pointed out that the severity of pesticide related illnesses to
farmworkers (measured in days lost per man hour worked) is greater by a
factor of 2 than that attributed to all occupational causes in any other
type of work in California. Both the deficiency of existing regulations,
and their lack of enforcement contribute to the situation.

Federal Pesticide L^ws
Federnl or stflte pesticide laws have never regulated
or prohibited the use of pesticides for cosmetic purposes.
Until the passn.
interstate. Pesticide usa^e was totally unregulated
except for the overkill alternative of registration
cancellation, a drastic step that the Administrator was
reluctant to take except infrequently and only to the most
detrimental of the pesticides like DDT.
In 1972 PEPCA was passed. It extended federal
authority to the distribution, sale, shipment, and use
of all pesticides, Intrastate and interstate. PEPCA
retained registration and labeling requirements and
continued to make unlawful the distribution and sale of
adulterated and misbranded pesticides. But most important
it extended federal control to the use of pesticides by:
1) classfying pesticides into two catagories, general use
and restricted use, and allowing pesticides classified for
restricted use to be applied onl.v by or under the super-
vision of trained applicatorsf^and 2) making it unlawful
to use any pesticide in a manner inconsistent with Its
labeling.66Hence by controlling the labeling, deciding
which pesticide usages are to be restricted and by setting
standards of competence for the applicators who apply the
restricted pesticides, the kPA through the authority of
PEPCA can regulate to some extent how pestioides are
used In the fields.
To d<3te, the EPA has not# in the regulations promul-
gated by EPA to implement FEPCA, used its authority to regulate
the cosmetic use of pesticides. But there may be a number

of ways th->t the EPA cmld use FEPCA as a vehicle for
controlling the use of pesticides for cosmetic purposes.
Registration, as in FIFRA, could tie one coarse way
of controlling usage by simply prohibiting any use of
a pesticide. The Administrator has wide discretion in
deciding whether to allow registration of a pesticide.
FEPCA states that the Administrator shall registrer a
pesticide if:
(A)	its composition is such as to warrant the proposed
claims for it;
(B)	its labeling and other material required to be
submitted compl" with the requirements of this Act;
(C)	it will perform its intended function without
unreasonable adverse effects on the environment; and
(D)	when used in accordance with widespread and
commonly recognized practice it will not generally
cause unreasonable adverse effects on the environment.
The phrase "unreasonable adverse effects on the environment"
is the key criterion for registration. This unreasonable
adverse effect test seems to allow the Administrator
considerable latitude and the definition of the phrase in
FEPC^^ioes not limit this discretion significantly. Section
2(bb) of FEPCA defines the phrase "unreasonable adverse
effects on the environment" ass
any unreasonable risk to man or the environment,
taking into account the economic, social, and
environmental costs and benefits of the use of any
This benefit-risk concept underlying the unreasonable
adverse effects test will necessarily result in a complex
balancing calculus. But it seems that a pesticide usage

for purely cosmetic purposes would have fewer benefits
to offset any economic, social, or environmental costs
and the calculus would be easier. For such pesticide
accruing from pesticide use solely for cosmetic purposes
even if the toxicities of the pesticide were not enough
to raise the presumption against registration.
The classification of pesticides Into general or
restricted use catagorles is another method for controlling
pesticide usage for cosmetic purposes. FEPCA provides
that t
As a part of the registration of a pesticide, the
Administrator shall classify it as being for general
use or for restricted use, provided that if.,.some
of the uses for which the pesticide is registered
should be for general use and that others for which
it is registered should be for restricted use, he
shall classify it for both general use and restricted
Pesticides classified as restricted can be applied only
by or under the supervision of a certified applicator..
If the usage threatens environmental damage as distinguished
from threats to human health, a restricted use pesticide
can be subjected to use restrictions determined by the
The statutory criteria for determing whether a pesticide
usage Is to be classified as general or restricted, as with
the criteria for registration, allow the Administrator
much discretion and are based upon the unreasonable adverse
effects test. Section 3(d)(1) of FEPCA statest
(?) If the Administrator determines that the pesticide,
when applied in accordance '.*ith its directions for use,
warnings and cautions and for the uses for which it
is registered, or for one or more of such uses, or
in accordance with-a widespread and conuponly
recognized practice, will not generally oause

unreasonable adverse effects on the environment,
he villi classify the pesticide, or the particular
use or uses of the pesticide to which the determination
applies, for general use.
(C) If the Administrator determines that the pesticide,
when applied in accordance with its directions for
use, warnings and cautions and for the uses for which
it is registered, or for one or more of such uses,
or in accordance with a widespread and commonly
recognized practice, rray generally cause, without
additional regulatory restrictions, unreasonable
adverse effects on the environment, including injury
to the applicator, he shall classify the pesticide,
or the particular use or uses to which the determination
applies for restricted use....
Hence the Administrator by applying the unreasonable adverse
effects tept could determine that a pesticide should be
classified for general use for those uses which are
noncosmetlc and should be classified as for restricted
use for cosmetic uses. This seems Justified because such
distinctions between uses are consistent with the balancing
nature of the test.
Uses of a pesticide f-at do return benefits of higher
agricultural productivity but necessarily occur with some
environmental costs or health threats would be more
reasonable than wo >ld uses of the same pesticide with the
same costs but whose sole benefit was more cosmetically
pleasing produce. Once classified for restricted use,
the Administrator could subject the cosmetic uses of a
pesticide.to restrictions such that the environmental
costs and threats to human health are minimized to a level
such that they are outweighed by the small benefits that
accrue from uses for cosmetic purposes.

As In the reo;u.i at ioiB proposed by EPA to govern
registration, cosmetic considerations are not Included.
in the proposed regulations for use classification. But
the proposed use classification regulations do differ from
the proposed registration regulations in that if certain
toxicity criteria are met, a specific use of a pesticide
product must be classified for general use. It is uncertain
that the toxicity criteria are sufficiently strict to
Justify the general use of a pesticide for cosmetic reasons.
There is good reason to use the restricted use
classification as the method for controlling the cosmetic
usage of pesticides. Such a classification can subject
their to the limitation of application only by or under the
supervision of e trained applicator. It will often be
true that it will take trained personnel to determine
whether an application of pesticide for cosmetic purposes
will have the desired effect without detrimental side
effects substantial enough to make the cosmetic usage
unjustified. However, as we have Indicated above
the effectiveness of this kind of strategy wou I'd depend
on greatly Improving the system of pest control
advisor certification and licensing.

Postici&a Use and RogulationsFootnotes
1.	Pesticide Use Report, 1973. Agricultural Chemicals and Feed, California
Department of Food and Agriculture, Sacramento, California, p, 289.
2.	Harrison C. Dunning, "Pests, Poisons, and the Living Law: the Control
of Pesticides in California's Imperial Valley," Ecology Law Quarterly.
Fall, 1972. p. 636n.
3* California Agriculture 1970, A Report on California's Principle Crop
and Livestock Commodities. California Department of Agriculture, 1971*
David Pimental, "Extent of Pesticide Use, Food Supply and Pollution,n
New York Entomological Society, March, 1973 P* 15
5* C. B. Huffaker and Ray F. Smithy "The IBP Program on the Strategies and
Tactics of Pest Management,M Proceedings. Annual Tall Timbers Conference
on Ecological Anjraal Control by Habitat Management. Pbb. 24-2^, 1972. p. 220#
6.	Pimentel, o. cit., pp. 27. 29.
7.	Robert F. Luck, R. van den Bos?h and R. Garcia, "Chemical Inseot Control*
A Troubled Pest Management Strategy," submitted to Science. 1975*
8.	"The Principles, Strategies and Tactics of Pest Population Regulation
and Control in Major Crop Ecosystems," Proceedings. IBP Integrated Pfrst
Management Conference on Economic Injury Evaluation, April 5 6, 1973*
Dallas, Texas, p. IB.
9.	Rosemarie Yon Rumker, Farmer's Pesticide Use Decisions and Attitudes on
Alternate Crop Protection Methods. U. S. Environmental Pro taction Agency,
Washington, D. C., 197^* p. 3*
10* Ibid., pp. 5* &
11, Dunning, oj>. cit.. p* 6B5.
12* AAIE brochure, AAIE, 100 North Winchester Blvd., Suite 260, Santa Clara,
California 95050,

13.	Chris Iterritt, Department of Entomology, University of California,
BarKeloy, personal communication.
1^.	Dunning, og. cit*. p. 653
15*	A. Gutierrez and W* Loew, "Pest Control Decision Making In California
Cotton," in progress*
16,	Wayne R* Willey, "The Diffus of Pest Management Information Technology,H
doctoral thesis, University of California, Berkeley, 197**. pp. 10, 11*
17.	See p. below.
18*	Willey, o. cit., p. 105*
19*	Inwjrview with	Dean, Chondcala and Feed Division, California
State Department of Agriculture, July 15, 197^*
20*	Dunning, og* cit,, pp. 639 bkQ*
21.	Interview with Robert Howie, August 6, 197^
22,	Dunning, 0. cit,, p. 64-8.
23*	See p. below*
2h	Dunning, ob cit*. p. t>51*
25*	Dunning, 	P b52.
26*	Interviews with Robert Howie, August 6, 1974; Claude FLnnol. August 8, 197^.
27.	Dunning, oj>. cit*, p. 655*
28*	Interview with Barry Wilk, March, 1975.
30.	Dunning, 0. rit*. p* 686*
31*	Dunning, oj>. cit*. p. 675
32*	Dunning, o* cit*, pp. 677. 678, 678n
33*	Dunning, o, cit*, pp. 66U-675*
3^.	Dunning, . cit*. pp. 687-69 
35.	Willey, oj>. cit.* p. 135.
36,	Dunning, og, cit*. p, 686,

37.	Kahn, E. (Cal. State Dept. of Health), Statement for presentation to
U.S. Dept. of Labor Hearings on Proposed Standards for Exposure to
Organophosphate Pesticides. Aug. 2, 1973.
38.	Interview with Thomas Leffingwell, Agricultural Chemist with School
of Public Health, University of California, Berkeley, August, 1974.
39.	Spear, R., et^ al. Environment Science and Technology 9(4): 308.
April, 1975.
49. Interview with Dr. Betty Olson, Dept. of Social Ecology, University of
California, Irvine, August, 1974.
41.	California State Department of Health, Community Pesticide Study,
Report, 1970.
42.	Gunther , F.ejt al., Archives of Environmental Contamination and
Toxicology 9(4): 243. 1973.
Westlake, W. et al. Op. cit. 1(1): 60.
44.	Frawley, J. et al. J. Pharm. Exp. Ther. 120: 96. 1957.
45.	DuBois, K. Archlues Indust. Health 18: 488. 1958.
46.	Field notes to "Destalking the wild tomato," Friedland, W., and Barton,
A., Dept. of Applied Behavioral Sciences, University of Calif., Davis.
47.	Interview with Dr. E. Kahn, California State Dept. of Health, July, 1974
48.	Howitt, Richard, Ph.D. thesis, University of California, Davis, 1975.
49.	Kahn, E California State Dept. of Health, Statement by the Committee
of Pesticide Safety, April 19, 1974.
50.	Howitt, o. cit. 1 p.
51.	Interview with Robert Howie, Agricultural Commissioner, Riverside
County, August 6, 1974.
52.	Interview with James Stockton, Agricultural Commissioner, Kern County,
Sept. 1974.

53.	Interview with Kress Fraley, United Farmworkers of America, Keene,
California, July, 1974.
54.	Interview with Nancy Kleiber, United Farmworkers of America, Salinas,
California, Sept., 1974.
55.	Interview with Dr. Daniel Murphey, United Farmworkers of America Clinic,
Delano, California, September, 1974.
56.	Deposition filed with United Farmworkers of America, Keene, California,
August, 1974.
57.	Interview with L. T. Kennedy, Western Conference of Teamsters, September,
58.	Interview with Sister Barbara Jenkins, United Farmworkers Clinic,
Salinas, California, September, 1974.
59.	7 USC pp. 136 et sea
60.	7 USC pp. 135 et seq as ammended, 7 USC pp 136 et seq.
61.	7 USC p. 1556
62.	Ibid.
63.	7 USC pp. 135a, 135f
64.	7 USC p. 136 et seq
65.	7 USC p. 136a (d)
66.	7 USC p. 136.
67.	7 USC p. 136a
68.	7 USC p. 136
69.	39 Fed. Reg. 36973 (1974)
70.	7 USC p. 136a
71.	Ibid.
72.	39 Fed. Reg. 36973 <1974).

In order to determine the impact on society of pesticide
use due to cosmetic quality standards It is necessary to
evaluate the impact of pesticide use generally on the
stability of the environment and public health. The
benefits of cosmetic quality standards can then be compared
to the costs attributed to the pesticide use required to
maintain t hose standards.

In this section we deal with health effects on persons occupationally
exposed to pesticides. During the past two decades or so the greatest
publicity and interest in the area of worker health hazards has centered
around thp use of organophosphate insecticides. These pesticides have been
replacing the more persistent orp.anochlorine pesticides because of their
relatively rapid decay, and because the organochloriae pesticides have become
relatively ineffective for many of the systems to which they have been
In this section we will mainly deal with health effects on agricultural
laborers. This is because there are far move of such people exposed to
pesticide hazards than people in any other category, and because they bear
the brunt of the hazard. Where appropriate, however, we shall consider the
effects on other groups that are occupationally exposed.
During the period since the Introduction of the organophosphate pesti-
cides, dramatic incidents of poisoning were noted almost every summer among
field workers. For example, in August, 1963, an outbreak of parathion
poisoning was noted among orchard workers harvesting peaches in the San
Joaquin Valley.1 Ninety-four workers became ill at that time with the
symptoms that are attributable to organophosphate poisoning. The workers
in the orchards where poisoning occurred had re-entered the fields an
average of 23 days after spraying with parathion. In fields where no
poisoning was reported the average re-entry interval was 45 days.

The acute effect of organophosphate pesticides on mammalian systems
results from depression of the cholinesterase level . . . Cholinesterase
is an enzyme found in many parts of the body, including the blood.. Its
function is to degrade acetylcholine, a transmitter substance which is neces~
sary for transmission between 1. preganglionic and postganglionic fibers
of the autonomic nervous system; 2. post-ganglionic parasympathetic nerves,
smooth muscle, and cardiac muscle; 3. motor nerves; 4. certain components
of the central nervous system. Cholinesterase degrades acetylcholine within
the refractory period of the nerve, thus allowing for continuous transmission
of the nervous impulses. Certain organophosphates are non-competitive
inhibitors of acetylcholinesterase. Consequently, exposure to organo-
phosphates can cause the accumulation of acetylcholine at transmission
sites, and caused sustained stimulation, increased function, and finally
decreased function with further accumulation.
Organophosphate insecticides can be absorbed by means of the lungs*
skin or g.i. tract. The symptoms of organophosphate poisoning are symptoms
characteristic of parasympathetic stimulation: nausea, vomiting, headache,
weakness, cramps, difficulty in breathing. More severe symptoms include
involuntary defecation and urination, excessive bronchial secretion, and
pulmonary edema. In addition central nervous system manifestations include
anxiety, headache, tremors, and electroencephalogram abnormalities.
As mentioned above, cholinesterase appears in the blood, in both the
plasma and the red blood cells. Measurements of both these quantities can
be made. It is now accepted that the most relevant value for detemrmlnlng
effects on the autonomic nervous system is the red blood cell value.
Generally the symptoms listed above are associated with depression of 30%

ortnore in red blood coll cholinesterase, although the relationship between
depression and symptoms varies with individuals, and with the speed of the
depression. In referring to cholinesterase depression below, the figures
given will always be for red blood cell cholinesterase, unless specified
As a result of the reports of the poisoning incidents described above,
re-entry times were established in California for certain crops in June,
1971. The re-entry regulations specify the amount of tine which must elapse
after spraying with a given pesticide, before workers are allowed to re-enter
the fielrt. The crops to which re-entry times apply are citrus, peaches and
nectarines, grapes, and apples. In addition some Federal regulations exist
which will be discussed below.
Our first task will be to assess the magnitude of acute organophosphate
poisoning among agricultural workers. (For simplicity we will use the t?.nn
organophosphate poisoning to refer to any poisoning induced by choiinesterase
inhibiting pesticides. This category include.-? those pesticides generally
referred to as organophosphate as well as those referred to as carbamates.
Carbamates probably are competitive inhibitors of cholinesterase rather than
non-competitive inhibitors as are orgaaophosphates)We will then try to
determine why the illnesses exist in spite of the existing regulations. The
possibilities include that some of the regulations are Inadequate, that the
regulations are not enforced, and that the poisoning occurs on crops
not covered by the regulations. Once we have looked at acute poisoning, we
will consider the effects of chronic exposure.

One study which gives some indication of the actual extent of the
problem was performed by the California State Department of Public Health
in 1969.^ The results indicated that the extent of pesticide related
illnesses among farm laborers far exceeded the figure indicated by the normal
reporting mechanisms. The study involved a household survey of agricultural
workers in Tulare County in 1969. From the househo3.d survey an estimate was
made of the incidence of pesticide related disease among agricultural workers,
and ihis vas compared to the reported incidence of such disease. Tulare
County was chosen for the study because it is diverse both in the type of
crops grown, and in t". e composition of the agricultural workforce. Tech-
nical details of the study are found in reference 4.
It was found that the actual rate at which farmworkers sought treatment
lor pesticide related illness was 249.1 per 1000 persons per year. Each
farmworker who sought treatment was counted only once in the figure, so the
actual number of times treatment was sought was probably much higher. On
the other hand, the workers' compensation figures, which are the best
available figures concerning the existence of pesticide related illness
showed 2 workers per 1000 per year treated. In other words fever than 1% of
the pesticide illnesses serious enough to require treatment were reported,
or the incidence of such disease was over 100 times that reported. As an
additional note it should be pointed out that not only did the workers*
compensation system result in creating a grossly distorted impression of
the magnitude of the problem, but also in unfairly depriving the overwhelming
majority of eligible people of their due compensation, i.e., payment for
physician's service and time lost from work.

A further aim of the study was to determine the total incidence of
symptoms, without regard to whether or not the victim received attention
by a physician. It was determined that seven of eight farmworkers reported
one or more symptoms that might be plausibly related to exposure to agricul-
tural chemicals on the job, and that all told there was a rate of 2980
symptoms per 1000 persons per year, or about 3 per person.
Some comments are offered in the study on why only a very small per-
centage of fieldvorkers with pesticide related illness make uae of the
workers' compensation mechanism. One reason Is that many of the workers
simply do not know about their rights under the system. A second Is that
to go to a doctor would require some time traveling. Since agricultural
workers are paid either hourly or by piece rates this would involve a loss
of income for the period away from work. Third, many agricultural workers
did not have sympathetic medical personnel available whom they thought they
could trust.
It is noted in this report that many of the symptoms of poisoning re-
sulted from chemicals generally considered non-hazardous, for example
fertilizer containing phosphorous, potassium and ammonia, sulfur, and weed
oil. Although these substances are unregulated they produce a substantial
toll In human discomfort. The main effects of exposure to such compounds
are dermatitis, skin and eye irritation.
Of those people who actually filed a workers' compensation claim, about
40% reported symptoms associated with organophosphate poisoning. There is
no other indication in the report of information which would Indicate the
percent Qf pesticide related illnesses associated with organophosphate

A control group was studied to determine whether the illnesses reported
were job related,	or rather related to some background
factor associated with living in Tulare County. The control group consisted
of about 100 non-farm workers. The members of this group received the same
interview as the farm workers. About 35% reported experiencing one or more
of the symptoms reported by 87.7% of the farmworkers. Moreover, the control
population visited physicians at a rate of 20 per thousand per year compared
to 250 to 1000 per year for farm laborers. These figures Indicate, beyond
any doubt, that there is something peculiar to the agricultural working
environment which causes such symptoms as nausea, skin and eye irritation,
chronic headaches, sleeplessness, etc. As the report states, "If anyone has
a credible hypothesis iis to what this something might be other than pesti-
cides, it has yet to be advanced."
The report also noted the casual manner with which many pesticide
related illnesses are treated. Many farmworkers seemed to take the pain
and discomfort associated with these illnesses for granted. Farmworkers also
noted many cases in which they or friends had been sprayed while working
in the fields. In mosL cases no advance warning was provided. In some
cases the field foreman had lied, saying, "It's only water." or "It's
vitamins, its good for you."
In summary, the study shows that there is a tremendous degree of under-
reporting of pesticide related illness among farmworkers. During the year
over 30% of the farmworkers had seen a doctor for pesticide related Ill-
ness, but official figures put the number at about 1% of that figure.
Moreover, more than 80% of the farmworkers' complained of one or more
symptoms of pesticide related illness. About 40% of the symptoms reported
were the kind associated with organophosphates.

We can conclude, then, at least at the time this report was written
(1969) that pesticide related illness (a substantial portion of which
resulted from organophosphntcs) was a very serious problem among agri-
cultural workers, affecting the vast majority of such workers.
Since the study cited above was made before the institution of worker
re-entry intervals in 1971, some information from the post 1971 period is
required to indicate to what extent a similar situation does or does not
now prevail.
A recent study was conducted by Richard Howitt at the University of
California, Davis department of Agricultural Economics.^ Thf purpose of
the study was to assess the economic costs of pesticide usage. In the
cours : of the study a good deal of information pertinent to our project was
The study involved intensive questioning of agricultural workers in
two California counties, Monterey and Stanislaus. These counties were
chosen co provide a diversity in crops. Among the information garnered in
the study is the number of days lost due to pesticide related illness per
thousand man hours. This figure is compared to that supplied from workers'
compensation figures.
Also involved in the study was a compilation of the incidence of symp-
toms associated with pesticide related llness. The symptoms under study

were the sane as those looked for in the 1969 California State Department
of Health Study mentioned above. As a result of the Howitt study it is possible
to make an estimate of the extent to which the symptoms are present among
agricultural workers.
The results of the study indicate that the illnesses included in the
workers' compensation reporting are about half the number of actual illnesses.
Howitt finds that the number of hours lost per 1000 man hours due to pesti-
cide related illness is 5.25 (thif. includes three levels of confidence in
associating the illness with pesticides: definite, probable, possible). It
is instructive to compare this figure with that reported for other occupa-
tions in California. The construction industry has the highest reported
figure of 4.9 hours lost per 100G man hours due to both illness and injury.
The figure for manufacturing is 2.49 hours per 1000 man hours. Hence,
according to this report the risk of pesticide related illness among farmwor-
kers :nay be greater than the combined risk of illness and injury from all
causes in any other industry in California, and this risk is almost twice
as great as that in manufacturing.
Thus, while the degre-2 of illness reported in this study is signifi-
cantly lower than that reported in the 1969 Tulare County study, the study
still indicates that there is a very high risk of illness from occupational
exposure to organophosphate pesticides. One can hypothesize that the dif-
ference between the 1969 Tulare results and the present results is due in
some measure to improvements from the institution of re-entry times. For
the purpose of our report, however, it is important to keep in mind that
farm work remains an extremely hazardous occupation, probably more so than any other
in the state, and under the current agricultural procedures a large degree
of illness among farm laborers is to be expected.
~Illnesses in a fourth category in which relatedness to pesticides could not

A further note of interest from the Howitt study concerns the percent
of farmworkers who were familiar with workers' compensation. Seventy-eight
percent of the workers interviewed had either not heard of, or had a
serious misconception concerning workers' compensation. Eight percent had
heard of workers' compensation, but did not knov what precisely was in-
volved. Only 14% had a precise idea of what the system was, and how to use
Additionally a follow up study to the 1969 study is being conducted
by the California State Department of Health. The purpose of the study
is to gain information concerning the prevalence of symptoms of pesticide
poisoning. Al~o the prevalence of cholinesterase depression is being
investigated. Results of this study were not available at publication

The situation described above for field workers could become signifi-
cantly worse if new chemicals like phosvel are introduced to wide-scale use,
as the manufacturers are now hoping. Because of the extraordinary poisoning
incidents which resulted form the use of phosvel, it is worth treating the
pesticide specially.
Phosvel is classified as an organophosphate pesticide, but in addition
to producing cholinesterase depression it shares with a few other compounds
the property of producing delayed nerve damage.^ This damage sometimes
does not appear until two weeks after exposure to the pesticide. The
damage is done by producing lesions in the mylein sheath, a layer of protein
and fatty material that covers the nerve fibers.
There is a history of serious poisoning incidents by phosvel and related
compounds in both humans and animals. In the 1930's TOCP, a related com-
pound, notorious for its ability to produce delayed nerve poisoning, was
linked to an outbreak of poisoning in the U.S. In this instance an alcoholic
beverage was adulterated with TOCP. Victims first suffered from symptoms
of cholinesterase depression, then 8 to 14 days later paralysis of limbs
occurred. In some cases the severity was so great that the victims remained
permanently paralyzed. In 1959 an incident of TOCP poisoning occurred in
Morocco where 2000 people were poisoned \-y cooking oil containing the
pesticide. Again some of the victims remained permanently paralyzed. One
importance of the incidents is that they demonstrate that delayed neurotoxic
effects can occur in humans. The effect has been demonstrated in some
species of animals, but appears to be absent in others. Some people have
discounted the danger of phosvel because of the species specificity of the

effect, but such reasoning is invalid because delayed neurotoxicity is
definitely an effect present in human beings.
A famous incident of pliosvel poisoning was an epidemic of paralysis
that struck several hundred water buffalo in Egypt in 1972. Twelve
hundred of the animals died. The poisoning coincided with widespread use
of phosvel in cotton fields, and it is generally accepted that the poisoning
was due to phosvel.
The neurotoxic effects of phosvel are obviously much more serious
than effects of cholinesterase depression. The symptoms associated with
cholinesterase depression mpy be very unpleasant, but will generally dis-
appear within a week.
In the case of a single instance of such poisoning it is unlikely
that there is any permanent damage done, although there may be serious
effects of chronic exposure. The effect of a cir.gle phosvel poiaoning,
however, may be permanent nerve damage and paralysis. What is important to
determine is the level of exposure to phosvel at which effects are likely
to occur.
Iia laboratory experiments in which delayed neurotoxicity was produced
in animals, the neurotoxic effect was produced at doses which had previously
produced some symptoms of cholinesterase depression. The symptoms had
disappeared by the time the neurotoxic effect appeared. In other words,
doses of pesticide- that produce symptoms of cholinesterase poisoning are
quite capable of causing neurotoxicity. Since symptoms of cholinesterase
depression are common among farm workers under current conditions it is
quite possible that the introduction of phosvel could lead to cases of nerve
poisoning among farm workers.

Dr. Gerald Rosen, of the Duke University Department of Toxicology,
reported in a phone conversation that he does not think that there is
sufficient information available to allow phosvel to be used safely on
crops at this time. Rosen is currently engaged in studying the toxicity
of phosvel, specifically delayed neurotoxicity in chickens. He said that
it is silly to assume that phosvel is safe, and that he definitely would
not want to be a guinea pig on whom phosvel is tried. One problem in
approving the use of phosvel is that no weathering experiments have been
done with it. In other words Mie degradation characteristics phosvel in
the field are unknown. Finally Rosen, pointed out that no one knows what
effect phosvel will have on people, and it should not be used until the
effects are known.
Velsicol, the manufacturer of phosvel, has applied to the EPA to
allow its use on lettuce, tomatoes, and non-bearing citrus. The residues
requpsfed are 10 ppn for lettuce ami 5 ppm for touatoes. EPA has not yet
taken action on this request. There is, it should be pointed out, no
evidence to indicate that working in fields in which the crop meets the
residue standard will not involve a serious threat to the health of farm-
workers. Phosvel should not be approved for use until and unless serious
tests on its safety are passed.

In addition to the immediate symptoms of pesticide poisoning, there is
some evidence that long term chronic exposure can produce more serious
effects among exposed persons. Generally, little research has been done
concerning the effects of chronic exposures to pesticides, of either the
organophosphate or the organochlorine type. However, a survey of the
literature from both the U. S. and abroad has produced some information
concerning chronic effects. What follows below is a selective, critical
summary of some of the most useful literature dealing with chronic effects.
The possible health hazards described in this section apply to a broad group
of people working with pesticides, including mixers, applicators, agricul-
tural laborers, and people involved in the manufacture of pesticides.
Among the most studied effects are chrcnic effects on the nervous
system. Sevaral types of such effects have been suspected, and some have
been at least partially documented. A statement from Dr. Thomas Milby on
the subject is reproduced below.
Our research leads us to suspect, furthermore, that there is
probably an even more common form of "adverse effect"one which is
even slower to develop and even subtler in its manifestations.
The individual may not feel nauseated, dizzy, etc.; he may not
lose any time from work at all. But he may have a little more
difficulty getting to sleep at night. His appetite may be a little
less hearty than it was. And there may be a gradual impairment of
his hand-eye coordination and other neuromuscular functions, so that
he is able to pick 10% fewer oranges or peaches, say, than formerly.

The effected individual may not notice the difference at all; or, if
he notices, will most likely shrug and ascribe it to "getting
older." Impairment of neuromuscular functions is not measurable
through the cholinesterase test referred to a moment ago, but we in
California are working on new methods for directly measuring these
kinds of pesticide "poisoning."
Despite the recognition of the importance of these effects by re-
searchers at the otate Department of Health in California, no program to
monitor their general prevalence or importance has yet been undertaken.
For hints of the types of effects likely to be involved we must turn else-
where. One of the most careful studies was performed by Jager, et al. ^
"Workers engaged in the manufacture and formulation of pesticides were
Nearly half the workers exposed to organophosphate pesticides had
abnormal EMG readings, although workers exposed only to organochlorine
pesticides had normal EMG readings. An electromyogram (EMG) is the recording
of electrical activity from a portion of the muscle. Electromyography has
greatly ai^ed in the classification of raotorneuron diseases.
One condition detected by EMG tests, known as myasthenia gravis, is
characterized by muscle weariness and fatigueabiiity. The EMG patterns of
myasthenic patients have the same rhythm as those of healthy people, but are
characterized by irregular amplitudes, depression of the first potential
after voluntary activity, and lower amplitude of potentials. The pesticide
workers with abnormal EMGs had EMGs characteristic of myasthenic patients.

The researchers found no correlation between abnormal EMG readings,
and whole blood cholinestcrase activity. One important result, however,
was that signs of progressive impairment of EMG appeared during a work week.
Specifically EMG amplitude in workers who already exhibited impairment of
function declined from the beginning to the end of a work week. The ampli-
tude recovered over the weekend. This pattern is typical of other
occupationally related chronic diseases. For example, in the case of lung
diseases, the forced expiratory volume decreases yearly in exposed persons,
anc decreases froa; the start to the finish of a work week building up again
over the weekend.
There are several important points to note from this study. First,
workers chronically exposed to organophosphate pesticides stand a good
chance of developing inpainnent of the neuromuscular function, and such
impairment is probably widespread. Second, this impairment is not detectable
by the normal method of detecting effects of organophosphate poisoning, i.e.,
testing cholinesterase depression. What is not known is how severe the
effects of neuromuscular impairment are. They probably vary from producing
mild muscular weakness (which may cut down work rate by about 10%), to
producing serious muscular weakness, interfering with hand-eye coordination,
and causing serious difficulty in performing normal work.
Several additional studies confirmed the fact that chronic exposure to
organophosphate pesticides cause neuromuscular impairment. We survey these
A study by Drenth et al.	also indicated that workers exposed
to pesticides had a high incidence of abnormal EMG readings. Forty percent
of the exposed workers had abnormal readings with the signs including low EMG

amplitude, and decrease in EMG voltage after maximal voluntary activity.
These are the same myasthenic signs reported by Jager's group. No differ-
ence was found in cholinesterase levels between exposed and non-exposed
workers. The workers studied were exposed to several pesticides, and no
attempt was made to correlate effects with the type of pesticide exposure.
A recent study of California farmworkers continuously exposed to post
spraying levels of organophosphate insecticides revealed a depressed
strength in the Achilles tendon reflex.	The farmworkers involved
in the study worked in irrigation, hoeing, and harvesting crops, but not
in spraying them. The force of the Achilles tendon reflex was measured
objectively with a machine designed for that purpose. Depression of the
reflex was found to be significantly greater in exposed persons than in
control populations. In addition the reflex force decreased with age in
the exposed population, but not in the control population. This indicates
Lhat the reflex force diminishes as the number of years exposure increases.
This study confirms earlier work by Rayner jet al..^ which showed a
significant depression of this reflex in a population of exposed orchard
growers as compared to a control population. According to the author of the
California study, Leslie Schmetzler, the significance of the diminished
reflex capacity for daily activity is unknown. It does, however, indicate
nerve d .:age.
Behavioral effects due to nervous system impairment caused by exposure
to organophosphate pesticides were documented in a study by Metcalf and
Holmes.The study involved a group, of men engaged in the manufacture
of several organophosphate pesticides. Many of the subjects have been
continuously employed in the same capacity since 1950. Included in the
study were psychological tests, electroencephalograms, and visual and

auditory invoked responses. The exposed workers were compared to people
working in similar job categories, but who were not exposed to organo-
phosphate insecticides.
Results of the psychological tests showed that compared to the control
group, the exposed workers had disturbed memories, difficulty in maintaining
alertness, and a general slowing down of movement. Neurological examina-
tions indicated that the workers in the exposed group had so called "soft"
neurological signs such as coordination deficits.
In addition EEG (electroe: cephalogram) readings on exposed workers re-
vealed abnormalities. Although there was no increase in hard EEG abnor-
malities, there was a high incidence of low to medium range slow activity in
the theta range. Because many subjects reported lethargy, drowsiness,
sleep problems, and narcoleptic symptoms, an EEC r.tudy of all night sleep
was made. Nine of the twelve subjects studied had narcoleptic sleep
patterns. Thee findings suggest that excessive drowsiness caused by
pesticide exposure is a symptom of an underlying disturbed physiology.
Several studies indicate possible psychological effects of heavy
exposure to organophosphate insecticides. Gerson and Shaw	reported
cases of persons working with pesticides who first suffered from the
effects of acute organophosphate poisoning, and later exhibited psychiatric
symptoms. The syraptors included symptoms of schizophrenia, depression,
loss of memory, and difficulty in concentrating. Dille and Smith^"^
reported on the cases of two pilots (employed spraying pesticides) who
first suffered from symptoms of acute poisoning, and later showed symptoms of
severe depression and anxiety. In the case of the second flyer an abnormal
EEG persisted for six months after the disease appeared. Both sets of

authors attribute the psychiatric symptoms to the effects of exposure to
organophosphate pesticides.
The two studies cited above are criticized in an article by Clark^
In his article Clark notes that the authors of the above studies offer no
proof that the psychiatric effects are causally related to pesticide ex-
posure. He notes the lack of any careful epidemiological studies which
would establish a causal relationship between exposure to organophosphate
pesticides and psychiatric effer.ts, and terms the human data "a maze of
unexplained inconsistencies." While it is true that many of the human
studies were unsysteratic, and that careful epidemiological studies are
certainly needed, thn case reports of psychiatric effects should serve as a
warning of possible, serious mental health hazards, related to heavy
organophosphate pesticide exposure.
In addition to the human studies wenLioneu above, a host. u expei iiuenLt>
have been performed on animals to look for possible chronic effects of
pesticide exposure on the nervous system. These experiments have largely
been concerned with the effects of organophosphates in inhibiting learning
or conditioned reflexes. The effects of pesticide exposure include
quicker extinction of the reflexes, and greater difficulty in learning. A
good review of much of the work in this field wc.s written by Medv 1
and this review is highly recommended to the interested reader. Much of
the work covered in the review was done outside the U.S., and some is not
readily available in libraries in this country. In the U. S, some work
in this area has been performed by a group at U.C. Davis.^
It is difficult to use animal experiments to make statements about
the amount of exposure to a hazard which will be dangerous to human health.

Moreover, a detailed analysis of the animal expex'iments in this area is far
beyond the scope of this report. In many of the experiments the effects
on conditioned reflexes did not appear until doses of pesticide sufficient
to produce large cholinesterase depressions (40% or more) were applied. In
a few cases, however, the effects on conditioned reflexes appeared at doses
of pesticide which produced relatively small cholinesterase drops (10% to
20%. These depressions are typical of the effects which farmworkers
probably experience under current working conditions. Hence, these animal
experiments raise the possibility that chronic exposure to organophosphate
pesticides at current levels can cause interference with reflexes or learning
A few studies in which enzyme levels and certain biochemical parameters
of persons working with pesticides were monitored, are valuable in indicating
other possible chronic effects. The studies indicate the effect of chronic
exposure to pesticide?, in producing liver- and kidney damage.
A group headed by Tocci compared the blood concentrations of some
substances in workers spraying organophosphate pesticides with those of a
control group. Among the differences noted were significantly higher levels
of serum creatine phosphate, and of serum glutamic oxalic transaminase (SGOT)
in the exposed persons. In a similar study of persons chronically exposed
to organochlorine pesticides, Davies^ found that serum levels of SGOT
were significantly higher in exposed persons than in controls. In another
study by Davies,	it was found that persons with heavy occupational
exposure to pesticides had low tubular reabsorption of phosphorus (T.R.P.).
The difference between the exposed and control groups was highly significant.
Moreover the T.R.P. became of more abnormal in the exposed persons as thieir
length of exposure increased. In addition exposed persons had high incidences
of amino acid uria (high levels of amino acids in the urine).

In an article by Wnssorman and Wasserman,	the authors note some
effects of chronic exposure to organochlorine insecticides. Persons
occupational]y exposed, and over 45 years of age had a significantly
elevated level of cholesterol. The authors attributed the change to an
impairment of homeostasis, a price paid by the human body in adapting to
the pesticide stress. Also noted in the article is an impaired immune res-
ponse in laboratory animals who received 200 ppm DDT in their drinking water.
Their conclusion is worth reproducing here:
"Organochlorine insecticides C>CI) interference with a number of meta-
bolic pa_hways. The healthy adult may adapt to the present dc-gree of OCI
pollution. It is questionable how older, and probably other groups of
people with impaired health acapt themselves to this aspect of the environ-
ment. "
Kaloyanova-Simeonova	reviews the results of a study on agri-
cultural workers in Bulgaria. The workers wert exposed mainly to organo-
phosphate pesticides, although organochlorine pesticides wer_ included among
those used. Haematological, urine, and liver function tests were made.
Among the significant findings were the high levels of protein in the urine
in about 10% of those exposed, low leucocyte counts in about 15%, and high
serum cholesterol readings in about 20% of those exposed. Surprisingly
the levels of SGOT and alkaline phosphatase were normal.
Studies on several groups of pesticide workers were carried out by
Bogusz. ^ . In one study tests were performed on two groups of workers.
One group was employed in producing organochlorine insecticides, and the
second in spraying organophosphorus insecticides. In the first group the
activity of alkaline phosphatase was noted to be higher than in the control
group. Among the workers handling organophosphorus pesticides, cholinesterase

levels were found to be depressed,.and the alkaline phosphase level was
significantly higher.
Although the results vary from study to study, there are some con-
sistent findings which indicate organ damage. The high levels of SGOT
and alkaline phosphatase are both markers of liver damage. Leakage of SGOT
into the blood indicates liver cell death or damage. Levels slightly above
normal indicate cirrhosis or obstructive jaundice. Higher levels of SGOT
could also indicate myocardial infarction;, but the accompanying pain makes
it unlikely that a victim could continue to work. Above normal levels of
alkaline phosphatase are indicative of the liver malady known as obstructive
jaundice. Liver damage is likely not to be manifested in changes in enzyme
levels until it is serious. It can be a major stress on the system and can
severely aggravate other conditions, and in the case of cirrhosis can be a
cause of death.
Kidney damage is signaled by high blood levels of SCP and high levels
of amino acids in the urine. The SCP levels will not be elevated until
there is 50% or more tissue loss in the.kidneys. Hence, people with high
SCP levels are likely to be suffering serious kidney damage. The excess
levels of amino acid in the urine are indicative of a wide range of kidney
disorders including chronic glomerulnephritis, nephrosclerosis, and
diabetic nepropathy. Because of the crucial role of the kidneys in main-
taining homeostasis, amino acid urea can be a sign of severe physiological
There are several important conclusions which can be made from these
studies. First, they indicate chronic exposure to pesticides, of both the
organochlorine and orgnnophosphate varieties, and result in serious damage

to or|;,iu systems in the body, damage severe enough to interfere with the
health of the affected persons. Second, there has been some controversy
regarding the goals of the program of regulations regarding organophosphate
pesticides. Some people have proposed that cholinesterase depression in
agricultural workers of up to 25% be tolerated, because poisoning symptoms
do not appear until cholinesterase levels are further depressed. On the
other hand the California State Department of Health has maintained that a
0 level of cholinesterase should be the goal of the program. These results
indicate ^hat chronic exposure to levels of pesticides which d^, not produce
symptoms can cause serious injury to health. Hence, the 0 cholinesterase
depression should be at least i minimal goal of such a control program.
l"here is, of course, no evidence that exposure to levels of pesticides
which do not affect cholinesterase levels does not produce other effects.
Finally, some comments are in order concerning the existing and non-
existing studies in this area. The lack of decent epidemiological studies
which would give some correlation between exposure and ill health is scanda-
lous. iluch of the work that was performed was done outside the U.S., despite
the fact th U.S. has a huge agricultural labor force of potentially
exposed persons. In the work that does exist, little attempt was made to
determine the extent of the exposure. About the best that was done was to
separate persons primarily exposed to organophosphate pesticides from those
exposed to organochlorine pesticides. Finally, the researchers have been
remiss in finding out the actual effects on health of exposure. Studies of
amino acid levels are a quick way to determine the presence of kidney
damage, but they in no way indicate the real toll of such damage in terms
of dysfunctions of the body, shortening of life, or human discomfort and

misery. Another problem with these studies is that the persons most seriously
affected by pesticide exposure are the most likely to have left their jobs
for health related reasons. These persons would not be included in the
study. In the absence of any evidence to the contrary, chronic exposure to
pesticides, at what are apparently thelevels to which workers are not
exposed, should be considered a serious health hazard, and immediate steps
should be taken to sharply reduce such exposure.
Some of the most serious effects from chronic pesticide exposure were
reported among Japanese women who applied organophosphate pesticides, and
performed farm labor in the affected fields. According to a study by
Sakazawa and Hakazawa	some of the women had symptoms which included
loss of 10 to 20 pounds bodyweight, anemia, and menstrual irregularity.
Temporary sterility was also induced in some of the women, a condition
which was reversed several years after parathion was eliminated from the
group of pesticides in use.
The authors also note that toxemia of pregnancy occurred frequently
during the busy farming season, something which did not occur in urban areas.
The disease was often accompanied by bleeding and premature births. The
absence of a seasonal effect in urban areas as well as the fact that the
incidence of toxemia was lower during a year of heavy rain (the rain washed
the pesticides off the areas of contact) implicate the pesticides as the
No indication is given of the dose received by the victims, nor is
there any indication of whether those affected suffered from acute
organophosphate poisoning. The authors do say that these diseases have
not been prevalent in recent years due to the elimination of parathion
and the more careful use of the other pesticides.

Many pesticides which are or have been in common use are known to be
carcinogens. Others have not been appropriately tested in this regard.
In assessing the risk of cancer due to occupational exposure, we again
run up against an almost total lack of epidemiological evidence concerning
persons chronically exposed to pesticides. We think the most valuable
study in this regard is one in progress under the direction of Samuel
Pharr.26	We present the results as they are so far available.
This study involves examination of sputum samples from persons exposed
to J. ^sticides and controls throughout the country. Use of the various
State Community Pesticide Projects was made to gether the samples. Sputum
kits were issued to projects in 16 states. Satisfactory specimens were
received fron 1781 subjects, 1362 of whom were designated as having been
occupationally exposed to pesticides, and 419 of whom were controls. The
samples were analyzed for the existence of inflammation, irritation, allergy
and metaplasia. Metaplastic cells are cells that have been transformed
from their original character, and their presence is a marker of exposure
to carcinogens. This will be discussed more fully below. The proportions
of exposed persons, controls, and members of other occupational groups
(who were examined in 3 previous study), exhibiting each symptom were
tabulated and compared.
In the crse of inflammation, irritation, allergy, and obstruction,
no significant difference was found between the exposed persons and the
controls. However, metaplasia appeared in cells of 43% of the exposed
persons, compared to 27% of the controls. Moreover, when the figures were
broken down state by state, or into age groups, the percent metaplasias for

the exposed persons was significantly higher within each group. In a
further tabulation the results were broken down according to occupation with
the results shown below.
% Metaplasia
Occupational Group
# control
// exposed
Agricul. aircraft work

Mosquito Abatement

Agricul. service
Pest Conf-ol

In general, the results are approximately the same for each occupational
group. Metaplasia appears in between 38% and 47% of the people in each
group of exposed persons. The control group for formulators broke the
pattern, but this group h
We should also note the results of this type of study on other
occupational groups. The groups studied include office workers, riggers,
fire fighters, asbestos workers, electricians, machinists, metal workers,
welders, and persons exposed to urban traffic fumes. The mean percent
metaplasia for the entire group was 23%, compared to 27% for the controls.
The only group which exceeded the mean significantly was that of persons
exposed to urban traffic fumes, with 37% metaplasia, as compared to 43%
metaplasia in pesticide workers.
The presence of metaplastic cells is a marker of exposure to carcino-
genic substances. Metaplastic cells are cells which are in some way
transformed from the cell line of origin. The process of becoming meta-
plastic is a protective response to irritation. In the case of the lung
where the columnar epithial cells become metaplastic, the cells lose their
cilia, become keratinized, and stratified, and their nuclei.
Metaplasia is a reversible process, and the cells are likely to return
to normal if the source of irritation is removed. However, it is also the
first step in a process that can terminate in cancer if the exposure con-
tinues. The appearance of the cancer may be as much as ten or twenty
years off.
What is important to note is that people working with pesticides are
exposed to carcinogenic substances. Exactly which chemicals are carcino-
genic cannot be determined from this study, although the high levels of
metaplasia found in diverse groups indicates that probably several pesti-
cides have a carcinogenic property. If exposure is stopped during the
metaplastic stage, then the process may be reversed. However, continued
exposure is likely to bring about cancer In .some of the exposed persons.

height attainment, skin infections, dental cavities, enlarged liver,
hypertrophied tongue papillae, and conjunctival folliculitis. Finally
it was noted that the infant mortality rate was 63 per 1000 live births.
The infant mortality rate is another good indicator of the general health
status of a population. The figure of 63 compared to a figure of 23.4
in low income areas in Denver. While this study includes only one small
group of agricultural workers, it is likely that the living conditions and
health status of those included in the study are not too different
from the general population of migratory agricultural laborers.
Given this information on the health and nutrition status of agri-
cultural workers, we now check the literature on the effects of protein
deficient diets on pesticide toxicity. Boyd and Chen	fed lindane to
rats who had been fed a protein deficient diet since birth. These rats
were twice as susceptible to the effects of lindane as rats fed a normal
diet. For example, Lhe oral LD5U for those rats fed was 95 mg/kg, while for
the rats given a regular diet it was 185 mg/kg. The authors noted that
there was impaired growth ir: the livers of the rats on the low protein
diets. This led them to suggest that the enhanced toxic effect of lindane
might result from a diminished detoxification capacity in the protein
deficient rats.
In another experiment, rats on several different diets were fciven 150
ppm dieldrin in their food.	The rats were fed diets containing either
10%, 25%, or 50%' casein, which is 90% protein. The casein replaced car-
bohydrate. Mortality was noted at various intervals. The results are
shown below.

Cumulative mortality for males in percent
Percent Casein in Diet
The authors conclude that for male rats low protein diets definitely
contributed to increased toxicity, and that this result could generalize
to people. The combined evidence from the health status studies of
agricultural workers, and the laboratory experiments on protein deficient
animals constitute strong evidence that agricultural workers in the U.S.
are more susceptible to deleterious health effects of pesticides than are
generally healthy people.
To sum up this section, we have noted evidence for several possible
chronic effects of pesticide exposure. These include damage to the nervous
system with such accompanying effects as muscular weakness, and difficulty
in sleeping, damage to the kidneys and liver, and possible cancers. These
effects can occur even when no acute symptoms (such as those accompanying
cholinesterase poisoning are present), and may occur even when cholinesterase
depression is not detectable. Essentially no work has been done which
would indicate a dose-response relation for any of these effects. At this
time wr>. can only conclude that at present levels of exposure, long-term
exposure to pesticides is likely to produce one or more of these effects
among a large number of persons occupationally exposed. Any sizeable
reduction in pesticide use, therefore, would probably make a goodly con-
tribution to the health of persons employed in agriculture.

The general public is exposed to pesticides sprayed on crops in the
form of residues in food. These residues are generally of the order of
magnitude of 1 ppm, and frequently lower. They are too small to cause any
acute effects, the amount ingested in residues being far less than the
exposure received by persons occupationally exposed. Although there are no
acute effects from such exposures, the possibility exists that certain
chroaic effects can be caused by continued ingestion of pesticide residues.
We shall examine the evidence for and against the existence of such effects,
and then determine th-i implications for the use of pesticides for cosmetic
The pesticide residues in the food people eat, get there in two ways,
first, some pesticide that was actually sprayed on the crop remains on the
edible portion of the crop, and is ingested with the food. Second, in the
case of persistant pesticides (organochlorines), the chemical sprayed on
any crop is distributed through the ecosystem. Moreover, the concentrations
of such pesticides are magnified as they move up the food chain. Hence
the residues in the highest concentration are in foods at the top of the
food chain, rather thaa in foods which have been directly sprayed. Accord-
ing to a study of pesticides in the American diet more than half of the
chlorinated hydrocarbons contributed to that diet come from dairy products,
32 33
meat, fish and poultry. * Obviously cattle and fish are not sprayed
directly with pesticides. Moreover, the spraying of animal feed products
has been severely restricted or banned altogether. Hence the chlorinated
pesticides which accumulate in meat and dairy products must have been

originally used on some unrelated crop, and only later made their way
through the ecosystem, eventually into the bodies of cattle, fowl, and
It is useful to digress briefly to consider some of the evidence
concerning the movement of organochlorine pesticides through the ecosystem.
A model for the movement and distribution of DDT and its degradation products
is discussed in an article by Harrison et al.	They note that DDT is
transported through the ecosystem by air and water, as well as through
living biomass, and has become ubiquitous. Degradation products o DDT
such as DDE are stored and exchanged by the same process as DDT itself.
Because DDT is highly fat soluble its concentration is magnified in higher
trophic levels by factors of up to 10.	One conclusion found from the
use of the model is that levels of DDT are likely to remain high in the
environment for years after their use is terminated. Hence DDT concentra-
tion in animal fat may not reach its maximum level for perhaps a hundred
years after its use is halted.
An article by Woodwell et al. traces the movement of DDT through an
ecosystem. The authors first note that DDT has become an integral part of
biological, geographical, and chemical cycles. DDT residues, they point
out, have been found in animals in the Antarctic, hundreds of miles from
places vhere DDT has been applied.
In their study DDT concentrations were measured in a marsh on the
south shore of Long Island. The concentration in water was only .00005 ppm,
and in plankton it was .040 ppm. At the other end of the food chain we
find the herring gull with a concentration of 5.43 ppm, and the ring billet
gull with 75.5. Thus, the magnification from top to bottom was by 20,000

in this case. The point of mentioning this article was to indicate both
the spread of DDT through the ecosystem and the magnification of its concen-
tration through the food chain. Similar results have been found for other
chlorninated hydrocarbon pesticides.
These results indicate that organochlorine insecticides used on any
crops, are likely to persist in the ecosystem, and could present a health
hazard to persons consuming food other than the crops on which the pesticide
was used.
Before a pesticide is registered, certain chronic feeding tests on
anlctals are required. In these tests tne animals are given low levels of
pesticides in their daily diet. The animals are followed for their lifetimes,
and in some cases for several generations. The experimenters look for such
factors as reduced life expectancy, tumors, lack of ability to reproduce,
deformed offspring,weight loss, liver malfunction, and the blood concentra-
tions of certain substances.
The lowest level at which any abnormalities are found is noted, and
tolerance levels for residues are generally set lower than these levels
by a factor of 10 or so. Sometimes the experimenters start out to test a
particular tolerance level for safety, because this is the level of pesticide
left on the crop when the chemical is used as recommended. Still pesticides
are not registered at levels at which toxicity is noted.
Since insecticides must pass the type of test noted above, one might
reasonably question if there remains a valid reason to suspect possible
deleterious effects on health. There remain, however, certain grounds for
suspecting possible effects on health from ingesting low levels of pesti-
cides. The grounds for suspicion are as follows:

1.	The experiments were performed improperly. We do not have any
evidence that this occurs. However, we pointed out in the section on
occupational effects how two pesticide manufacturers performed self-serving
experiments that severely distorted the hazard associated with the organo-
phosphates tested. The possibility certainly exists that this could happen
in tests paid for by the manufacturer.
2.	Some effects could not be detected in these experiments.
Specifically it is quite possible that carci.iogenic or mutagenic effects
could exist without being detected in the registration experiments. Briefly,
the reason for this is that at a given dose, the effect may be present in
only a small percent of the observed population. For example, if the dose
administered were large enough to produce an effect in 1/1000 of the exposed
population, then in an experimental population of 10, there is less than a
1% chance of detecting the effect. Ten animal? is typical of the number
used in these experiments.
The above argument depends on the shape of the dose-response curve for
these effects. Although there Is debate over this shape, there is some
evidence that the approximation considered above is reasonable. These
matters will be discussed in detail below. We mention them here to point
out the possibility that the standard registration tests are not adequate
to prove that use of the pesticide in the prescribed manner is harmless.
3.	Potentiation Effects. As we pointed out in the section on occu-
pational effects, exposure to more than one chemical simultaneously may
have an effect significantly greater than that expected from adding the two
individual effects. For example the exposure to either substance A or
substance B at 5 ppm may be harmless, but exposure to both at that level
could be dangerous. We will also consider this phenomena in detail below.

Before considering in detail the possible hazardous effects of'pesticide
residues, we should obtain an idea of their magnitude in food. In general
we will compare the actual levels to the tolerance levels, using the tolerance
levels as the baseline. In subsequent sections we will try to determine
possible effects from ingesting such residues at or below the tolerance
levels. There are several possible tolerance levels for a pesticide,
including levels set by the Stafn of California, by the U.S. Envirc-.naental
Protection Agency, and the World Health Organization of the United Nations.
The standards generally do not differ significantly. At least within the
accuracy with which we can predict effects of the differences between
standards are not great. We will point out which tolerance levels are
being used when ve refer to them.
In a study performed by Di'ggan and Cornelliussen,	estimates were
made of the amounts of pesticioes in the American diet. A market basket of
food was selected. This basket was chosen to approximate the American diet.
Eighty two food items were considered. According to the authors there
figures were based on the food intake for a 16 to 19 year old male. Th
diet constructed represents an intake nearly twice that of the average
Americans, since persons of this age are heavy eaters. A total of 30
market baskets were obtained from cities throughout the U. S. of differing
The calculated intakes were compared to the F.A.O. acceptable levels.
The figures given are for food purchased in 1968. For only one pesticide
was the intake equivalent to the acceptable level. In the case of aldrin
and dieldrin (these two pesticides were considered together) the calculated
intake per day was 6x10 ^ mg/kg, whereas the acceptable intake is 10~* Big/kg.

Hence Americans were receiving almost as much aldrin/dieldrin in their diets
as was considered acceptable.
For most pesticides the intake was considerably lower than the vfilue
considered acceptable. For example, for DDT the calculated acceptable
intake was .0007 mg/kg per day with the acceptable daily level at .01 mg/kg.
In other words the safety factor was about 10. For malathion the
calculated intake was 4 x 10 ^ mg/kg per day, and the acceptable level .02.
Here the safety factor was 500.
It was also reported in the study that a general survey of food shipments
indicated {hat. 3% had residues exceeding the tolerances. (The reader should
note the difference bes_ween acceptable daily intake which is a limit on the
total amount ingested ker day, and residue level which is a limit on the
residues on foodstuffs in parts per million. The latter are presumably set
so that people will not ingest a total amount of pesticide per day greater
Liian the acceptable daily intake). It was also noted that foods of animal
origin supplied about half the organochloride pesticides. This implies
that abcut half the pesticides came from indirect sources.
A follow up study to the one reported above was reported in 1972.
The results were similar to those reported above with some new results of
note. Dieldrin/aldrin still represent the only pesticide entity present in
the diet at levels approximating acceptable levels. One change of note is
the large increase in the residues of organophosphate compounds. The average
total intake of these compounds was .012 mg per day, 75Z of which was
malathion. The acceptable level for malathion is about 2 mg per day, so a
safety factor of about 200 was maintained. About 10% of the malathion
intake was attributed to fruit consumption. The malathion intake was about
twice that reported in the previous study. Thus the

i<< ' ' :i '	rlvitc iiir.."?;. u.,Ule.rj (..-iu.= f'd about a doubling of
: -int.-i'--: ir. Coo'l in t!-rt-i; years.
I :i 1if>sur>  !	jde.-; J-kuvi torin^ Journal the results of
r.-'-I'm- f1 ' :  u  varn.ouM foods are reported. Some of the results are
jnli r-	. it our study. DDT (and its breakdown products) was found
i.osr f veqiu'-' I .j rj th the range varying from .001 to .474 ppm. In fruits
orga'io>.:i3orin: compounds were found frequently including DDT,
diclclrin/aldr in, f.nd TD. Sone parathion residues were also found. Among
the pesticide.-; which have been demonstrated to be mutagenic were lindane
and zlneb. Both of these appeared in root vegetables.
An inti-r-'io-.v with James Kalstrom of the California State Department
of Agriculture produced so-re information about residues in California
crop.;. Produce is regularly monitored for pesticides, with over 10,000
?.	bfMp;-; tr ken during the pre/ious year.
According; to Kalstrora the residues vary frora year to year and
crop to crop. In 1S73 about 4'S of the samples had residues over the
tolerance levels for one or more pesticides. He did not have a breakdown
indicating tlikind of pt-..sticide and nature of the crop in which limits were
noi-t oftv.n exc
."'.on	;;	,i' I . . Accorciln;', t o Kalstrom there
have	. ot.ii.-i	II-.ni.s Sa vuich residue I oleranccs were grossly
f>;t" *,'-.	by I he above information is that pesticide
residue i'.v.u; Ln 5 . ':* . : ^.nierally be low the tolerance levels, and daily
intake 3-..  13 are I ; >  the* estxshoe, intake limits. Generally the intake
is smal.Jer  han tli. Level cons leu-rod acceptable by a factor of 10 of 100.
Only aldr:;.n and cLieuirin are iu^.^sted at levels comparable to the maximum
acceptable levels, ilejldue limits are exceeded in a small percentage of
the food Ja. pled, .-u.ci a largy number of samples have residues far below the
levels ci.u;idcred ac rep table. Crgauochlorine pesticides enter the diet
about equrtl'y as the result of direct spraying of the food ingested, and
from bacl:;.;ri unci levvi.r; of r.ho pesticide in the environment. Residues of
organopiiGs-phate post ic. idus are well below the acceptable levels, but are
increasing rapidly.
With this information in mind we turn to examine the possible harmful
effects of continued ingestion of pesticides; at levels between 1% and 10%
of the tolerance levels.
Studies by Frawley^indicated the potentiation effect of two organo-
pViosphate insecticides used together.
These studies were also mentioned in the section of occupational effects.
Animal feeding studies were performed using both dogs and rats. In one
experiment in which fH'K and malathion were fed to dogs it was found that
250 ppm ni - Intliion or 50 pptn EPN fed separately in the daily diet caused no
effects. However, when the two were fed together at these levels 93%

11.1*; I) i t i-;i ;.> b.too;!	cholin c s t erase was found. This is u very
I -;i it	toxic el 'Vet vh 5 ch would cause sowj illness, it not death xr.
hit' ''UlS.
In a r;jia I ,'ar cxp'iT Lincnt 8 ppm raalathion and 3 ppm EPS had no effect
vhcri admin t"tcred separately, but when administered together caused up to a
2'i %inhibition of red bld cell cholinesterase over a period of 8 weeks.
What is significant about this experiment is that 8 ppm and 3 ppm are the
respective tolerances for raalathion and EPN. In other words, these
pesticides, which seemed quite harmless when injected separately at the
tolerance level, were quite toxic when taken together.
Because of this result an experiment was performed in which pesticides
were fed to human volunteers (healthy males) at these levels. EPN at 3 ppm
together with rnalathion at 8 ppm produced no effect, but when fed at twice
Lhese levels, chol.inesterase. depression was noted.
The author concluded rhat this result indicated there is no serious
danger from residue poisoning because no effect was found at the tolerance
levels. However, when a serious effect is found at twice the permitted
level, this should be cause for concern. There is biological variability
in susceptibility to any toxic effect. Moreover, the subjects for the
experiments wore described as healthy males. For persons not in the best
of health the situation could be far more serious.
The article also described the probable mechanism of the synergistic
clfect. The general mechanism for this type of effect is the interference
by one compound with the enzyne system that metabolizes the second compound.
Ti*..-	is Lliat the effective exposure to the second compound is far

; !.er t;:"  n the expo:-.Li re which would occur if only this compound were
i:ci:uinistc r ed.
The	i tude of.' iin's effect:, as well as the fact that it occurs at
Jfvtils comparable to Lho tolerance levels should cause concern. In the
iva] worit. people ingest residues from many different types of pesticides,
and are exposed as well to a multitude of additional toxic substances.
Hence the possibility is raised that the exposure to one pesticide could
turn a harmless dose of another chemical into a very toxic dose. We should
remember also from the occupational section that low level doses of organo-
paosphates produced chronic effects not associated with cholinesterase
depression. Thus the synergistic effects may be more serious than implied
by the experiments in which cholinesterase depression was measured.
It may be objected that our concern about synergistic effects is unduly
alarmist, or that on the other hand that it raises experimental questions
for which it is impractical to perform experiments to answer. We think that
neither of these objections is valid, tecause of the huge potentiation of
effect when the two pesticides were used together, and because of the great
number of types of residues that are injested, it is quite valid to be
concerned about possible synergistic effects.
The second objection is that because of the huge number of combinations
of pesticides it would be impossible or impractical to test all possible
combinations. At one time there was a requirement that each new organo-
phusp'hate pesticide be tested in combination with organophosphate pesticides
already registered. This requirement has been abandoned, at least in part
Wcnuse of the; inpracticality of testing so many combinations of Chemicals.
Hovwer, such an approach is a pragmatic one, and does not make use of the

in! or;r..-ili'.ui available. i'. : ; '..o r.eciuin j <;ia of p^ton! i ;.tion i:; kr.own, it i
not necessary to tcs-t all possi blc cu'.Jvi i:;; of	icicle:;.' Kaiher
pesticides should ho t ostod for their ;;bil i i.y to hinder the enr.yrocs res-
ponsible for detoxifying pes tic ides. liy constructing a theory to explain
the mechanispj Of detoxification and inhibition it would be p-o.ssi.ble to make
reasonable predictions about 'synergistic effects without testing all the
possible combinations of pesticides. In addition human subject tests are
possible to determine if ingest ion of pesticides, or other exposures has
interfered with competence to detoxify substances. Since many people have
already been heavily exposed to pesticides, these tc=sts could be performed
without exposing additional persons to large amounts of pesticides. We are
not advocating the intentional exposure of human subjects not already heavily
In the Eieantime, until it can be shown that the type of synergistic
effect described above is not a threat to human health, every effort should
be made to keep pesticide residues to a liiinimum. Specifically the use of
pesticides for purposes not related to increasing food production (e.g., for
cosmetic purposes) should be avoided. In this regard we should briefly
taenticn the pesticide synergist, piperonyl butoxide. It was rioted in. the
section on occupational effects the P.B. functions by inhibiting the micro-
somal fraction enzymes which detoxify chemicals. Residues of P.B. have been
reported in certain food products. In an interview, Dr. A. H. Conney, who
has been the principal investigator in studies involving P.B. said that
no one knows if P. B. could be a long terra threat to human health^ lie noted
that only i t!ia case of antipyrene had the effect of P.B. on metabolism

V-. i! !' <:C. j :t K	shown not. to inhibit I he raetuliolis'.'i of.
y.  W>;n 3 c-d in low (Join- to human, volunteers.	Conney pointed
oui. rh:t! the c-f fee. r of P.Ii. on .lung metabolism has not" been seriously con-
sidered , and said tint there, is a possibility of a long-term effect.
should i f?if r.hctt othur substances to which people are regularly
exposed, have been shown to stimulate microsomal enzyme systems in animals.
The net: effect of: exposures to many different types of chemicals, some of
which have opposite effects is unknown. Both animal and human, exposures should
be undertaken to assess the effect of such exposures. It is important to
note that because the metabolizing enzyme system may both activate a chemical
to its active form, as well as metabolize that chemical, the net effect of
changing microsmal enzyme activity cannot easily be predicted.	The only
reasonable conclusion to make at this point, is that use of pesticides which
may alter the metabolism of toxic substances should be avoided as far as
possible until such time as they can be proved harmless.
carciinQc.e;:ic effect
It has been estimated by various sources, that between 60% and 8Q& of
human cancers are caused by exposures to chemicals.	The chemicals may
act as primary carcinogens, (transforming normal cells to metaplastic or
neoplastic cells), promoters (causing cellular hyperplasia, changing a
transformed cell to an autonomous tumor cell, or an inhibitor of the immune
system which attacks cancer cells. They may have the effect of initiating
new tumors or shortening the period before a tumor becomes a hazard or both.
The pesticides DDT and aldrin/dieldrin have both been found unequivocally
be.carcinogenic. Because of their chemical similarity to these pesticides,
.til the organochlorine pesticides are suspected as possible carcinogens.

U-cly ' '	I on "i! 'J;   <  : i ;tf undertook pro;J,r;j m to test some or
tfi.rr;c' i.fri i: ,	r h-:- j.-t el Lv.Lnary results ind:! eating that some are
definitely c.-i r (..'! ii'-'fcnrj. At th ! s po int the only 0:10. of these chemicals of
f.i.-.-it int
! t is I ! j  s _ L o r a i s;.< i :i ti.:	; tia.L : in; c	'..Mit.1 . <  L t t n.-. c
jn at	an add it ;vo r:)an;i-:i' (i :< soc:	, e. ; .. .*::\l>e&tciS	i.gart.Lte
snoko, t :> taroino:'/':; ; h've be- : shown i.<< ', i n[y; such thai. the* i.r
eflect tojy- t-her is iai; greater i.h:in Uvit. lor r.-ithn< ; f;-..;;ratcly). li-jnce .it
is rcasonali.1 c to assur,;c that any exposure. to a carc.inrj*c*.o will add to Lhe
general burden of carcinogens, ar. 5 eontr j ii-.itto tin*. production of cancers.
Any attempts to consider the effects of a oiL^l.e carcinogen, in isolation
seem to be fruitless, and may provide a fal^c sense of security.
It is far beyond the scope of this report to discuss all the scientific
issues involved in assessing the risk resulting from c:;po.surE to carcinogen.
Th'ire are, however, sou: signif icant points to be made.
First, we must point out the inadequacy of exist'iTij; tests'in detecting
the carcinogenicity of pesticides. In the typical feeding experiments used
for registration of pesticides, 10 to 100 animals are; used. If no excess
tumors are found with 100 animals vc are cert-iin to the 99% confidence
level that the actual tumor risk is under	If 1000 animals were used
with no excess tumors found, we could be sure that the actual tumor rate is
below .46%. Both risks, however, are quite high, and should be considered
unacceptable. Hence the registration tests on pesticides should be con-
sidered totally inadequate to detect possible carcinogenic effects.
A related point deals with the size of the dose used. Generally in
carcinogenesis bioassay experiments, the dose^ used are far higher than the
levels to which people are likely to be exposed. But as we pointed out,
using doses more comparable to those to which humans are exposed would
require using larger animal populations than are possible with the funds
currently available for testing. At the moment the only feasible method of
doing bioassay tests for carcinogens is to use relatively high doses, and

3 j(>
. ;.< v. -a.- I.: r.c 1 L I::' i:,  , about the; efforts of lower doses. Invitro
 r 'j avai !-.I).!'. to Lo'ij ; i' a substance .is capable of producing
-  t .My,. ^ch syssu'n:-; c-..a be urn.-, / quickly and inexpensively. They will
: yl\U:	qu-'intit.ii: i vc. information concerning the carcinogenicity of a
'.i.-itarxft, t."'.- merely iivlieate that it chemical is likely to be a carcinogen.
So-tie objections have been mada to use of chemicals at high doses for
c.. i^ino^ci'' ing because it is asserted that any chemical at high doses
a carcir:o^;'.n. This assertion is totally false. In a recent study of 140
<-licals in nice, it was found that fewer than 10% had carcinogenic properties
at my level.
Further v.e. should point out that in some cases the doses at which
tu:^origenic responses ware produced, were not high compared to levels of
 ;:j vii? -exposure. For example in the study reported in reference 14, significant
tnr.-igtinic responses were found when DDT was fed at 3 ppm. In some areas
of (he: U.S. TV! residues in meat have been found at about 10% of this level.
As for the- issue of the effects or possible effects of low level ex-
r.o:,tires to carcinogens, we present the results of inquiries into the matter
;<> noted scientists. First we note that the principle of 0 tolerance for
carcinogens as food additives (embodied in the Delany clause) remains in
off.-ot. The reasons for retaining the clause were summarized in 1960 by
It.L.W. Secretary Arthur Fleming.
"The (Delany) clause is grounded on the scientific fact of life that
na one, at this tiuie, can tell us how to establish for man a safe tolerance
aw a cancer producing agent. Until cancer research makes a breakthrough
this point, there is sunply no scientific basis ori which judgment or
*; v:retion could be exercised in tolerating a stoall amount of a known
> -;fCcoloring or food additive."

(>'v.lou  } / cUvsiic;' I L-iiKJv,. ,'u:; tii'it. cuf.or	diet a.*; i r.i:i iues	t.L-
r	do r.;>f c!i t t or in thoi r of fool' from t.hos-" that en'.;: i r-o-' a ' : 11 ive -;.
f in-'	i ly lo
I.; i o i do r G:'.' dues.
Excerpts ;':rom the report of the Ad Hoc Coivnittee on the Kvaluation of
Lov/ Levels of Environmental Chemical Carcinogv-ns arc valuable. in this regard.
The commit tt-? includes nine outstanding scientists, recognised for their
work in carcinogenesis. Among their recommendations was "No level of
exposure to a chemical carcinogen should be considered toxicologically
insignificant for man. For carcinogenic agents a safe level for man canfiot
be established by application for our present knowledge."
The report also argues against the concept that because carcinogens can
bo detected at lower levels, the zero tolerance principle j. Would be altered.
It is pointed out that aflotoxin, for example, has been shorn to produce
tumors at the lowest level at. which it can be analytically detected.
The zero tolerance principle was also supported by an expert committee
of the World Health Organisation.
"It is agreed that no assuredly safe level for carcinogens in huan food
can be determined from experimental findings at this time."^
The above statment was quoted in the testimony by Epstein.	Another
point made in that testimony which we have mentioned several times in this
study, is the simplistic nature of toxicological studies. These are
generally based on the testing of one chemical in isolation, a situation
which never occurs in the real world. Thus the possibility of an interaction
between two carcinogens, or between a carcinogen and a non-carcinogen, an
interaction which cay greatly enhance the effect of the carcinogen, is not
Considered. Hence the lack of knowledge provides all the more reason to

On i? v1."! J  i i	n-;;  : v.nt so:. i  brought up in this con J" ex L is that
c.fin eh.-.ni J.s (l> , DDT) hi iCMt'lgcnir., but not cure Lrie^enic. That
is, the cJ.a:  -:..h iIkil s; t.o cher.iir.sls t.iuse only benign tumors. However, a
wealth of evidence has repeatedly shown that tin's concept is totally in-
valid It h;.< been found that a conversion f roiR a benigh to a malignant
tumor is a]'-.,-ys possible. Frequently the benign tumor is a stage in the
evolution to malignancy. In fact no adequately tested chenical has ever
produced only benign tutors. Thus the distinction between a tumorigenic
and carcinogenic substance is totally invalid, and any substance shown to
have caused tutors should be considered carcinogenic.
Having gone through these arguments it is clear that use of persistent
pesticides which are'carcinogens should be considered a health risk to the
general population. The use of any such pesticides for cosmetic purposes
certainly should be disallowed.
At the present tine the only pesticide in wide use that is known to
fall into this category is chlordane. In a recent series of tests by the
Bioassay prograju of the N.C.I, chlordane was found to be carcinogenic.^
A preliminary report of the results was made available to us.
Chlordane has been recommended by the U.C. Extension Service for use on
citrus and grapes. The E.P.A. has recommended that it be used on the
following crops: apples, broccoli, grapefruit, oranges, grapes, peaches,
tomatoes, lettuce. Chlordane has been shown to be persistent, and to build
up in the environment in Lhe same manner as DDT and aldrin/dieldrin.	For
exurjple in saaples of onion soils, residues of chlordane were sliovn to

eyco'.'ii llio.ie of ; i} d r j n / d i c 3 d r i. r.. J ^Ad d i t i o n a 1 studios have indicated the
prcsr-nc'- of aldr i:i/d :< Idrin rc idues in the environment.
'Jn vit'.w of this pvidonee, and the previous discussion on carcinogenicity,
it is rceojimended that chlorclam: not be used, and certainly not used Cor
cos:nin ic purposes.
We should also note that DDT and aldrin/dieldrin are currently banned
or su&pended. There have, however, been attempts made to reintroduce the
use of these pesticides. Again, in view of the above evidence, we definitely
recoaiatnd against this reintroduction.
In considering the possible reintroduction of DDT, we should consider
the publicity generated around the use of DDT in 1974 in forest land in
Washington and Oregon. The publicity generated from the case in which DDT
was supposedly used to control the tussock moth was false and misleading,
pnd intentionally generated to convince the public that certain circumstances
exist in which DDT must be used. If any such cases exist this is certainly
not one of them.
A general critique of this particular spraying program is presented
in reference 54, in the first place when the damage due to the tussock moth
vas discovered the inoth population was already in the declining phase of a
three year cycle, and the population probably would have collapsed by itself.
Hence the results of the spraying program .in no way provided any evidence
that DDT is effective against the tussock moth. No such evidence existed
before. Furthermore, other insecticides which had been more completely
tested were available. Finally the area in which the outbreak occurred
contained trees of poor quality, as is generally the case in forest area
inft-^ted with tussock moths. Thus the massive spraying program probably

co: t ware thon the va *si the t;-uk which couid be salvaged even ii tiie UDT
were cffcc.-'ivo.
We have discussed i:his incidc.n.-e just to indicate the strong pressures
being applied to re tin p. DDT (and other organoelil urine insecticides) to use.
If the tussock moth ca;;y is an illustration of the most pressing situations
requiring the. use of DDT, there is clt-arly no value in lifting the baa. In
view of the evidence presented of the possible public health hazards resulting
from its use, the ban definitely should be retained.
Although chlordane is the only pesticide relevant to our study, definitely
shown to be carcinogenic, we feel that in general the testing of pesticides for
carcinogenicity has been inadequate.. Hence we do not think it correct
to dismiss out of hand the possibility that other relevant pesticides may
contribute to the production of cancers. This seems especially true in view
of the results of the study of pesticide workers reported in the section
chronic occupational effects. Several groups of pesticide workers from
different parts of the country, with different types of jobs, were all shown
to have been exposed to carcinogens. It seems unlikely that all the workers
in question were heavily exposed to the relatively small number of pesti-
cides known to be carcinogens. Thus it seems reasonable to be at least
suspicious that other pesticides may be carciuogenically potent.
A look at some of the entires in "Evaluation of the Carcinogenic Risk
of Chemicals to Kan,"volume 5 (published by the International Agency for
Research Against Cancerf confirms our belief that much of the testing to
date has been inadequate. This book contains information on chemicals
which have been assayed for carcinogenicity. The information includes an
evaluation of the testing which has been done. Sundries of the entires for

some of the chlorinated hydroearbsur; arc.- presented be'tov.:
7/Lnd,ine: carcinogenic in wicc. Produced Hver celJ tumors nfier oral
adminis trat ion. Tests ii; rati; wur
.i if)
i f. t-h.j f v/ilh many similar evaluations of hazards this particular
scot* o;i i;t be i :i-."one ] usive. we have presented evidence that from sound
publ ic h-.-alth jjv.'iet ice, even cm fill amounts of carcinogens should be kept
of ths.? diet, although it is not. possible to present a quantitative estimate
of the effect- Further we have shown that many pesticides have not been
subjected to proper teats to a;;say for carcinogenicity, and have given
reason t:o suspect thac some of these may have carcinogenic properties.
Prude.no. e, then, dictates that exposure to these chemicals be minimized as
much as possible, and in cases where there is no good justification for
their use, their use should be terminated altogether.
To put this section in perspective, we have indicated a possible hazard
arising from the ingestion of small quantities of pesticide residues. The
hazard is not of such a magnitude that it will bring an end to civilization;
nor is it conparablc iu size to tho diseases brought on persons with occupa-
tional exposure to pesticides. However, a possible increase in cancer cases
(affecting possibly one person in a hundred, one in a thousand, or one in
ten thousand) is certainly tragic for those affected. It is definitely our
recommendation that pesticides which could produce an effect on health of
this order, and hava no sound justification in terms of increased food
production, should not be used.

:	..\iu s
AmU !i.:r hazard possibly resulting from exposure to pesticide residues
i:~, i!;iosit;. HuL.it.i.onc arc any inherited change in the genetic material,
i.'iif. chin..- isay be a simple chemical change at one gene (point mutation) or
r.'-y invoJv.: the rearrangement or gain or Loss of a chromesome (chromesome
;;brrrraLion). Ji": the mutation occurs in a somatic cell the most likely thing
r-o happen is cither that it has no effect or that it leads to cell death.
Another possibility is that it produces a cancerous or precancerous change.
If the change takes place in the cell of a developing egg (or during early
fetal development) it could produce a teratogenic effect. If the change
occurs in a sex cell than it could lead to a change in every cell in the
(of tru" child), and could affect individuals in generations to come,
l-h;tagftnes*3 generally refers to the last process* However, since the three
processes (carcinogenesis, mutagenesis, and teratogenesis) are closely re-
lated we will make mention of all of them in this section, while concentrating
on mutagenesis.
According to Dr. Joshua Lederberg genetic impairments already account
for a large portion of our existing burden of disease and premature death.
He gives an estimate that 25% of our health, burden is of genetic origin. The
effects of a nutation vary in magnitude from trivial to very serious. A
mutation may be so deleterious to the organism that it prevents birth, death
being caused at an early stage of embryonic development, or at a later stage
(miscarriage). Roughly one fourth of spontaneous abortions show chromesomal
aber rot ions. There are hundreds of known genetic diseases, which although
ntc individually rare, together have a serious impact on health.

The : .it.r. L ion n.-:y 'Ia.'it i- . ;;er,crat	If it is serious enough to
produce ck'^i.h, it will lie quv. l.ly linin-iLed. If it: causes a slight effect
j f n ay pei s ii;t from yenei aticu to generation. A lethal recesnive mutation
iray be iierbored for several generations before it appears, and r.tay continue,
in Che population, dyin?, out only slowly. Since experiments with fruit
flies indicate that in lid mutations occur with much greater frequency than
severe ones, the major statistical impact of a mutational increase oil the
population would seem to be an increase in the burden of rather uiild diseases.
In an article on the health effects of nutations Legator^ points
out that approximately 33% of all spontaneous abortions in the first trimester
are chrotneso.iully abnormal. This translates into 5% of all conceptions in
the U. S. or 200,000 per year, lie points out that at Johns Hopkins one
patient in .14 has a genetic disorder, and speculates that 15% to 20% have
diseases in genetics that plays a role.
The above sketch provides a background of the possible seriousness of
the problem caused by increasing the mutation rate. The normal mutagenic
events which are responsible for evolution and some genetic disease are
about 10% attributable to background radiation.^The source of the remaining
mutational events is not known. The total background radiation to which a
resident of the United States is exposed is estimated to be 125 million per
year.	Lederberg indicates that a 10% increase in the spontaneous
mutation rate is currently considered a reasonable standard for the maximum
'tolerable Mutagenic effect of an environmental chemical.	He indicates
that he hopes that a standard will soon be adopted under which the maximum
increase in the mutation rate from all environmental chemicals is IX of
spontaneous mutation rate.

With this background 'we w i 'i i briefly o./'iu.iine the ava i'  :o 1 Li-e.r#t>irc*
concerning the mutagenicity of pesticides. As va> t*io cau'.* v i rh "Lher ): :: .-ruous
effects tin-; literature is skimpy and the testing q>. i te iunae  re. Hove v . r ,
the procedures required to test the pesti ^ {des in viJe uwo ad^c-uately for
mutagenicity are relatively sitr>ple and inexpensive. The co.-;t of suffici-- :it\y
testing a chemical for mutagenicity is r:;vt!i -compared to the costs of inobt:
chronic toxicity testing. Moreover, the quantitative science of estiinatin;.'.
the response from the close and predicting the effects on hiuyaus froai tests
in non human systems, is far more advanced in the area of mutagenesis than
in any other area of toxicology. (We will look at some of the quantitive
techniques used in mutagenesis below). Hence it is possible, that within
a fairly short period of tine a reasonable, estimate could be iriade of the
effects produced by a given exposure to at least :-ome mutagenic, pesticides.
Among the pesticides relevant to our study which have been shown to be
63	6 A
mutagenic at least in one experiment are carbaryl, lindane,	para-
thion,^"* endrin,*^ phospharaidon,^ and DDT.^^ All except DDT were
found to be mutagenic in plant test systems. DDT was tested using the mammalian
dominant-lethal technique which will be described below. A few agricultural
chemicals have been tested sufficiently to indicate that t.hey are strong
68	69
mutagens. Most prominent among these are captan,	and dichlorvos
(also known as vapona). According to Dale Kaddis^ of the Center for
Policy Alternatives (M.I.T.) captan is positive enough in domiaant-lethal
tests that quantitation of its effect could be attempted. Neither captan
nor dichlorvos figures importantly in this study, however.
As far as other pesticides which may figure in our study, any chemical
:;hovn to be carcinogenic, should of course be suspected as a mutagen. Uaddis
also pointed out that a lot of organophosphate. pesticides give indications

i:: i;i'; t	i:y in > ; ; - j r, - 1 .  	. 	
M:t' pos-.i,.'. ...utageu t. c.- c-1. er : ;.l. c.' : "i s, ant! I rici i c.'it e	.-..iequat c
c estlnfc -is ;>os.-;ible. 1 ultoulc ' < ^; r i d f: 	A f aw oo.^nntfi i. :;jv.- tests
available. a'o in oni.'r.
The a,Khars of rt-reace 27r,aiK;,' , tlat sufficient testing requires
that a cher.ij.cal be assayed in three. n..vv. ." n systens (dominant: lethal, host
Sied laced, in vivo cytogenetic), aud a.7.^ -;n microbial systems. One of the
r.i>st popular and successful tests i?. tin- rt-.-rdnant-lethal. In this test the
chemical is given to tne male of the	vho is mated with a progression
of f ensalfia. Piegnancy is interrupt:cd she::: ]y before term. The number of
fetuses that died early in pre^Tar-cy if; <:	. This number gives an
Indication o. the cayacity of the cbcraic .1 ti induce gross chromesoma1 ab-
normalities. j.his test will, however,	u-ost point mutations. These
mutations maj be more important, in terms oi their effect, on the human popula-
tion because they are probably responsible for most genetic diseases. The
effect o~ gross chromosomal abnormalities on human populations is probably
to produce abortions.
Bacterial assay systems have the advantage of being relatively simple
and inexpensive, and o being able to detect point mutations. One problem
vith their use is that many substances arc activated to be mutagenic in the
hast s body, and these will not show up as Mutagens on standard bacterial
systems. The host mediated assay is used to try to correct this problem.
In this assay, a mammal, during treatment vith a potential mutagen, is
injected with an indicator microorganism in which mutagenic frequency can
be measured. After a given time the micro-organisms ace withdrawn and the
induction of nutations is determined.

We str ; :;s ."lyjin tlw:t the authors of reference 27 recoisatuvJ that: chwiicala
bo t e; ted by several methods. They recommend that a chenicnl be considered
fc only if it is found inactive on all tests. They further recoraend that
cl .::.iea.ls which have the greatest chance of affecting people should be
nddiLionally tested to take into account- possible interactions. The tests
should be designed so that a doubling of the control mutation rate could be
detected at the 5% level of confidence.
Some examples from the literature indicate that one test may easily
miss the mut.'^onic effect of a substance. For example, a series of doninant-
Icthal testa performed by Epstein et al.^	failed to show any mutagenic
effect for urc-thnne (a well known and potent carcinogen), captan, or thalidomide
(v.'c.ll known at; a teratogen, and similar in structure to captan)* A number
of tests were performed with dichlorvos, before it was determined to be
7 2
weakly mutagenic in a test.
It is also interesting to note that in this regard both Stauffer chcimical
and Chevron chemical (the tvo manufacturers of captan) carried what they said
were extensive tests with captan before marketing the substance.	Stauffer
said that the tests indicated no teratogenic or mutagenic effects. Chevron
stated that theit tests on the toxicology of captan had proven without, a
doubt that captan produces no genetic effects.
These statements, together with later studies which proved these com-
pounds to be teratogens, point out the inadequacy of the standard toxicological
tests used in registering a pesticide. At the beginning of 'this general
Portion wo pointed out that pesticides are generally tested in feeding experi-
wouts at levels ten times or more greater than the residue levels found in the

did . '-% then rlf.-i or tea 1 ly po:;-.*d the. question oT v':y, wi	res tin >t
procedure and the added margin of safety, it shoul:! ho nc-c^::r.;u-y fo won ;
about possible effects of those residues. We posed some possible explain-
tioni; for the tests failing to detect soir.e deleterious effects. This
example. indicates that in reality, in at least this case, such an effect
was missed during the standard registration testing.
Some attempts have been made to quantify mutagenic effects for certain
chemicals. While none of the substances of interest to our study are in
this category, it is instructive to sketch such a calculation both for the
methodology and for the magnitude of the results.
A calculation on nitrite was performed by Abrahamson.This
general technique in such calculations is to compare the mutagenic effect
of a chemical with radiation. A given awojnt of chemical is determined to
have the mutagenic efficacy of a given amount of ionizing radiation measured
in rem.
The highest eucaryote for which nitrite mutagenesis data are available
is drosophila. In a one day experiment males given an average dose of 767
rag/kg with a resulting sex linked nutation rate o .13%. Since the x-ray
doubling dose for mature sperm is 15.6 mg/kg this amount of nitrite is equival-
ent to 49 rem. Abrahamson makes some corrections for sensitivity, for the
fact that the experimenters used acute doses, and for the fact the sensitivity
of the sperm is in less than 1-0% of the cycle. He estimates that the average
human nitrite consumption of .17 mg/kg per day is equivalent to 8 rem per
generation. Using a doubling dose of 40 rem per generation, then this level
corresponds to 20% of the spontaneous mutation rate. Ke concludes, "this
calculation, though highly uncertain and likely to be on the hi,h side, calls

iitu-nLion to the por .  r- i Lity t:. .; h: <  '  :it ini e>[ nitrite already
r>:cols th<- recGr.:-f!t"(3-'\-J .1 ini t. "
The ni'!;.;nitiiGe vi t ho mut-... L U' oft t c.f pesticides is at this point
only speculative, iiowevtrr, tl; :>-.e ol th'.- .-.*f feet indicated by this calcula-
l ion shouli! at least r;^ce us co ;  rned qI tic: possibility of a hazard. We
note that this calculation was ba.ied on tU;>. assumption of a linear dose-
response relation for nvutagenes i s. Afta.in this is an assumption that deserves
nore consideration-
7 5
Kilby	has presented ifcr results on an experiment that indicates
that the dose-responso relation is not linear to low doses. The experiments
involved using neurospora for tm- assay. H^posures were made at differing
concentrations of DEB, but the exposure varied inversely with the concentration
-<> the total exposure i;ns the	ia a~\ ' c.:ses. The results indicate a
cooperative effect at lower dose::,. Thar is, at lower doses the mutation
rate increases more than in proportion to the dose as the dose increases.
The author hypothesizes that besides being simply a mutagen, DEB
in:erferes with some process that limits its capacity as a mutagen. At very
low doses, according to this theory, there is insufficeint DEB to interfere
with theprotective mechanism. Hence fractionation of the dose (such that the
lower dose created by fractionation is lower than the dose needed to inter-
fere with the protective raechanisni) should and does iresult in a smaller
yield of mutations per dose. The author points out in conclusion that the
dose rate raust be considered in the evaluation of environmental chemicals.
FroUberg and Schenking^ Report some results which they say indicate
that ttyes dose-response curve is not linear and that smaller effects should
be expected, at lower doses. Usius the dominant-lethal assay TEM was given

i n ;; s	- -p. iniu'LJon. A o> -.1 .Or.	vb;i. i;t,
(h'!iv:i of ,0'j Ft;;/k i.;-j onieity v. .round. Yhc tose-.'i"...y,'iw err v- v.-1 |ir, :'