A 10-POINT REBUTTAL OF THE LIES PEDDLED AGAINST THE BANANA INDUSTRY
1. The study methodology is not clearly described in the report.
In particular the randomization method, sampling of environmental samples and methods of pesticide residue analysis, need to be clearly described in order for us to appreciate the results better.
Statistical randomization must balance other factors that have not been explicitly accounted for in a study design. Where those random numbers fall short of the acceptable standards of randomness, any subsequent analysis will suffer from systemic bias. This is one of the many lapses of the health assessment and environmental study of Sitio Camocaan and it is to nobody’s benefit to cover it up with an air of infallibility.
We have direct information that the respondents volunteered because they were made to understand that there was a free medical clinic in Camocaan. In addition, not all of the respondents had blood analysis. Clearly, this situation is not random in nature and the test population is not a representative sample (Video Clip 1 in CD).
Given the manner by which the respondents were engaged in the study, we would not be surprised if the researchers concluded 100% of the community was exposed to pesticides through aerial spraying and 100% were sick.
2. The identities of the sick people in Camocaan have not been endorsed to the local health authorities despite repeated requests.
The global developmental delay of 2 children is likewise a matter of extreme concern to us. In fact, one child has mild wasting. We wonder why the good doctors have not referred these cases to the health workers in Davao so that their concern and recommendation for further investigation could have been immediately done years ago.
We find it extremely difficult to comprehend the actions or inaction of the researchers for the last three years, despite repeated efforts to get the information, as expressed by the LGU at the DOH Davao public hearing (May 12, 2009) and at the People’s Inquiry in Camocaan (June 3, 2009), as expressed by the people of Camocaan in a letter written to Dr.. Allan Dionisio (dated July 5, 2009) (Annex 1). At the People’s Inquiry, Dr. Allan Dionisio promised to endorse to Dr. Patricio Hernane, municipal health officer, the results of the examinations, with emphasis on those who were sick, so that these persons could get medical attention (Video Clip 2 in CD). However, to date, these names have not been endorsed despite the repeated visits of Dr. Dionisio to Davao for his various speaking engagements. It appears media mileage has overshadowed the Hippocratic oath of this doctor.
It is therefore not surprising that the people of Camocaan are now restless over this development, showing indignation over the way their dignity has been trampled upon. They see themselves as mere numbers or statistics for the consumption of media and advocates with their own agendas.
3. We maintain, aerial spraying in areas without communities does not offer a health risk.
The researchers agree with this statement but do not believe it is true for the Philippine setting. We marvel at the gall of the researchers to make such a claim.
Are they better authorities on the state of the Philippine export banana industry than the PBGEA?
4. The nature of environmental samples is questionable.
The researchers have emphasized that “due to the presence of pesticides in the environment, acute signs and symptoms as well as abnormalities in biologic markers among the residents in the area has occurred.”
We have serious doubts about the veracity of the environmental samples and the levels detected for the following reasons:
a. The water samples were presented in the report as drinking water samples (Table 27, p.21) and are once again reiterated in your letter (Item No. 5). However, in the same instance, the researchers also acknowledge that the sample taken from the irrigation system is now described as water from a canal.. We have information, from the site, that the water for this particular sample was taken from the river close to the fishponds (Video Clip 3 in CD). This is not a drinking water source for the community. The sampling was done by the baranggay health worker after instructions were given by Engr. Rivera, who chose to stay at the main community area, leaving the BHW to do the sampling by herself (Video Clip 4 in CD). There is no canal in that area although Engr Rivera emphatically stated, during the People’s Inquiry, that the irrigation sample was taken from a canal. In your letter to us, you mention that the canal is indicated in the map. Our efforts at searching for this canal, at the site, has been futile and neither can we find it in the attached map of the report. This therefore proves to us that the researchers did not have full control over the quality, nature and integrity of the samples.
b. We have information also that a soil sample was not undisturbed soil but rather swept soil which is not the manner by which an environmental risk assessment is made (Video Clip 5 in CD). It is therefore not surprising that soil samples collected in such a manner, would contain detectable residues. We wonder how many square meters of top soil were scraped, by sweeping, thereby concentrating any low level or even non-detectable residues that would be present in undisturbed soil. This is not reflective of the soil conditions that would be considered as contaminated soil to be used for risk assessment. Thus, levels detected in soil remain highly questionable in nature.
c. Given the nature of the samples taken, water and soil without known spraying history, it is incumbent upon the researchers to confirm results made by gas chromatography. This was not done and therefore, the presence of any residue is not conclusive, most especially since the detector used in this analysis (electron capture detector) is not a selective detector.
d.. The detection of ETU in blood, soil and water is likewise highly questionable to us. Earlier on, we emphasized that the methods of analysis needed to be clearly explained. We refer to an earlier study conducted by Panganiban et al, 2004 which showed ETU levels in soil taken from an organic farm, which is doubtful. The study was not able to explain the presence of ETU thus we question the scientific value of the ETU results of this study as the analysis was conducted in the same laboratory as the former study. (Annex 2).
e. The presence of ETU in soil, several hundred meters away from the plantation and several days after spraying, is inconsistent behavior of the chemical ETU under Philippine conditions. ETU was not detected in soil 2 days after spraying in cucumber; the same rapid degradation was observed in soil after spraying cabbage in studies conducted at the National Crop Protection, UPLB (Calumpang et al, 1990; Calumpang et al 1988; Annex 3) and in other countries (Yip et al 1971 cited in Calumpang et al 1990). Pesticide residues in the environment degrade due to the effect of the environment; microbial degradation of ethylenethiourea is highly temperature dependent and is reduced to half the original value in less than one week (Rhodes 1977; Jacobsen et al 2006 cited in JMPR, Annex 4).
The persistence of ETU for as long as 5-10 weeks, as claimed by the researchers, is not reflective of conditions in the tropics.
Supporting data from a study conducted in a banana plantation in Australia:
In a study conducted by the North Coast Public Health Unit, Australia, ambient air was monitored for pesticides at four sites in Coffs Harbour, a coastal town surrounded by banana plantations in Australia. Air was sampled continuously for 5 consecutive months during the peak agricultural spraying period. The only pesticide applied by air in the district (propiconazole) was not detected. If international health guidelines are used as a yardstick, these levels of exposure appear unlikely to present an appreciable health risk. (Beard et al 1995, Annex 5).
The researchers claim that “… pesticide residues were seen in air and soil samples, as analyzed by the UP-Los Banos”. This claim is not true. UP Los Banos only analyzed water and soil samples, for which chlorothalonil residues were not detected in water, while chlorothalonil residues in soil were extremely low (0.01 – 0.05 ug/g).
Action for possible remediation cannot be based on just one air sample with ETU levels exceeding the US EPA program remediation goals, considering the nature of the analysis, which is very much in question. The results in the report, given the doubtful nature of the samples, reflect the over-eagerness on the part of the researchers to blame pesticides, leading to statements that have been used to practically wreck havoc on the banana industry.
5. Volunteer bias in the study prevents pesticide management decisions from being made.
Volunteer bias is always avoided in studies of this nature (Keifer et al 1996; Annex 6). The study report mentions that some of the respondents are workers of the nearby Lapanday banana plantation. It is no wonder therefore that ETU levels detected in blood were high in some respondents resulting in a higher arithmetic mean for Camocaan subjects than Baliwaga subjects (12.77 vs. 5.34 ppb), while geometric means are much lower (0.67 vs. 0.37 ppb) (Table 22, p. 18). This indicates that some subjects in Camocaan and Baliwaga may have been directly exposed to an EBDC fungicide or ETU, that is not related to aerial spraying drift.
At the very best, the analysis of the data should have differentiated the occupational exposure from exposure related to drift. Had this been done, the information generated from the study would have helped draw sound pesticide management decisions from the plantation management team as well as from LGUs and other concerned government agencies. As it is, the researchers clearly showed their strong inclination in banning aerial spraying, which is now clearly being publicly advocated by Dr. Allan Dionisio and Dr. Annabelle Yumang, DOH Davao in their current forum shopping spree in Davao. Given that Dr. Yumang carries with her the authority of her office, are these pronouncements the official stand of DOH?
6. Symptoms described after exposure to pesticides should be verified.
a. We have difficulty accepting that “recall bias does not apply to the issue of symptoms temporally related to serial spraying experienced by the subjects.” Anybody can claim to have been poisoned after exposure to aerial spraying. Anyone can claim anything for reasons only known to that person. A thorough medical examination should have been made to document and support such experiences. This is the reason why we have always stood for a science-based assessment of the situation..
We strongly react to the use of personal recall in the study. As an industry we have been burned from our previous experiences with Dr. Romeo quijano, who has long made misrepresentations about deaths and illnesses in Camocaan. He has even resorted to bringing some of them to New Zealand, claiming illnesses due to pesticides.
b. In addition, these symptoms experienced should have also been presented with a time reference. The use of GPS systems and flow-controls in aerial spraying has been in use for about 10 years already. At present, buffer zones are in place in Camocaan and elsewhere, while ground spraying operations are in place in areas close to the communities. There are trees and residential structures that obstruct wind movement and collect some residues in the air. Thus, the questionnaire should have been able to differentiate whether the symptoms experienced were current realities or previous experiences, reflecting previous episodes when current technologies were not yet in place.
c. The questionnaire portion on Symptoms of Exposure (p.43) has the following questions:
i. If you were exposed to pesticides, did you feel sick? Yes No
ii. If yes, how often were you sick? 100% 76-99% 51-75% 25-51% <25%
iii. What were your symptoms?
The results are presented as:
Table 19. Frequency with which Camocaan subjects experienced symptoms after exposure to aerially sprayed pesticides.
Table 20. Frequency of symptoms experienced after exposure to aerially sprayed pesticides among Camocaan subjects.
The questions shown above do not refer to aerial spraying exposure. However, the results are presented as such. Again, we clearly see the bias of the researchers in relating the results to aerial spraying even if these are not substantiated.
We wonder if this is the scientifically acceptable way to present the results of the questions.. We earnestly look forward to getting the peer review made by UP Manila experts to give us guidance on the appropriate scientific approach.
7. Confounding factors were not considered in the conclusion of the study.
a. The study shows the consumption of cassava is high in Camocaan (p.9) and is therefore a confounding factor. Cassava is a human goitrogen, ETU is not a human goitrogen. Cassava contains substances that act on the thyroid gland just like ETU, with one critical exception - human exposure to cassava is proven to be high enough to cause serious alterations to thyroid function whereas ETU exposure is almost certainly too low to cause any effects at all. There are many publications on cassava’s effect on the human thyroid, none of which are cited in the DOH study, in fact the action of cassava on the thyroid is not even mentioned.
However, there is one major difference, one is proven to cause effects in humans (cassava) while one is known to cause effects only in rodents (ETU). Based on toxicology data in rodents and epidemiology data in humans The International Agency for Research on Cancer (IARC) concluded that ETU is not classifiable as to its carcinogenicity to humans (IARC, 2001).
b. There are other causes of chloracne, other than chlorinated pesticides, such as dioxin, which is easily generated by human activities such as burning backyard garbage and reusing cooking oil. There appears to be an inclination by the researchers to attribute goiter and chloracne cases to exposure to pesticides fromaerial spraying without going through the rigors of eliminating the possibility that these factors could have caused these illnesses.
c. Your letter states that “the neurodevelopmental delays in the children studied may be related to pesticide exposure but further studies are needed to confirm this.”
It has been shown in a study conducted very recently (2004) that there is a significant interaction between material hardship and environmental tobacco smoke. Children with both ETS exposure and material hardship exhibited the greatest cognitive deficit or low mental status. Prenatal exposure to environmental tobacco smoke (ETS) in the home has a negative impact on 2-year cognitive development, and this effect is exacerbated under conditions of material hardship (Rauh et al 2005; Annex 7).
These conditions are evident in the Camocaan families.
8. Cholinesterase depression can be caused by factors, other than pesticides.
a. We had expected the study to consider the effect of other factors that can cause false positives for acetyl cholinesterase depression. We are aware that the following factors cause false positive results for RBC cholinesterase: drugs and reticulocytosis (Keifer handout, University of Washington; Annex 8). However, the researchers continue to view pesticides used in the plantations as the only cause of the cholinesterase depression in Camocaan.
b. The present study did not do any baseline data gathering for the subjects. Even Engr. Rivera, declared at the Camocaan People’s Inquiry that the best way to conduct a study of this nature, was to gather data before the spraying, during the spraying and after the spraying. This was not done in the present study and a lot of aspects are left to be verified and studied further (Video Clip 6 in CD).
c. Results of 2009 physical examination of several workers of Lapanday, likewise show that even bud injectors, who are potentially occupationally exposed to cholinesterase-inhibiting compounds, have normal cholinesterase levels (Annex 9)
d. Likewise, we have attached results of annual physical exams of 35 persons (average age 44 years old) who used to be flagmen, and therefore can be considered as those with a long history of exposure to fungicides sprayed aerially, of Tagum Development Corp. These workers do not have cholinesterase depression, have normal haemoglobin levels and except for 1, are negative for thyroid mass. They have worked for about 20 years in the plantation. With the use of GPS systems, they are now assigned to other tasks.. (Annex 10).
9. We care about human and environmental health. Lives have not been sacrificed for profit.
So much improvement in the technologies for spray operations in banana production has been achieved. Recent developments in application technology, formulation chemistry and delivery systems have resulted in better application techniques. Thus, human exposure to drift under these conditions is extremely minimal. Standard operating procedures on good practice for aerial spraying and qualifications for pilots and ground support staff are attached. (Annex 11)
a. The banana industry goes through painstaking efforts at calibrating its aerial spraying equipment to ensure that there is maximum use of resources and minimal wastage of expensive fungicides as well as maximum protection of the environment, in compliance with government guidelines.
b. At present, the banana plantations only use airplanes with global positioning systems (GPS), a computer-driven, via satellite, guide for pilots on the course to follow while spraying. The planes have target flow controllers which are also computer-driven mechanisms that shut off automatically for areas which do not need to be sprayed and open automatically in areas to be sprayed. Delivery rates are also controlled by computerized flowmeters so that the required amount per unit area is accurately delivered. We do not spray when then the wind speed exceeds 2 m/second and the air temperature reaches 28 oC. We also only spray at a height of only 5-7 meters to ensure that the spray solution reaches the leaves right away. This situation makes the drift from aerial application absolutely minimal. We cannot afford to let it drift away while spraying.
c. Banana oil and stickers are also added to the fungicide spray solution to ensure maximum protection for the banana plants from the disease for several days. The fungicide stays on the leaves longer, as it is solubilized in the plant waxes or oils, resulting in the effective reduction of the vapor pressure of the fungicide which would mean less fungicides evaporating from the sprayed leaves. The number of droplets per unit area are monitored and have a standard number of counts. Only under these optimal conditions are fungicides sprayed. This is the desired situation because the banana plants need to be constantly protected. We cannot afford to let the fungicide drift away after spraying!
d. Sign boards are maintained to alert communities before any aerial spraying activity.
e. In addition, buffer zones of 50 – 100 m from communities and thoroughfares (highways, roads) are maintained. The bananas in these areas are sprayed using ground equipment and spray in the direction away from the road. This is to ensure that these areas are not covered by aerial spraying.
f. Environmental monitoring of water quality in terms of pesticide residues have long been conducted. (Annex 12) Likewise, pollution monitoring of water sources in Camocaan in terms of dissolved oxygen, pH, total suspended solids, chemical oxygen demand, etc have also been done since 2007 (Annex 13).
g.. In addition, our banana exports are monitored for pesticide residues to comply with maximum residue limits (MRLs). We are serious with our efforts in protecting the health and welfare of the consuming public (Annex 14).
DOH also made reference of “of the need for PBGEA to adhere to the global program of “REACH” (Registration, Evaluation, Authorization and Restriction of Chemical substances) which is a new European Community Regulation entered into force on June 1 2007 (Annex 15).
We are surprised at this pronouncement. PBGEA’s activities are not covered by the European Community. The Philippines has its own set of standards and operating systems and we work closely with FPA-DA, DOH and the DENR through the Multipartite Monitoring Team which meets regularly to address issues of common concern. All our environment and human health monitoring activities are in compliance with FPA guidelines and are monitored regularly in a transparent manner.
10. At the People’s Inquiry in Camocaan, the researchers repeatedly and emphatically claimed that this present study is in no way connected to the reports made by Dr. Romeo Quijano.
We quote a portion of the introduction of the study report, which says otherwise:
This study was originally prompted by complaints from the residents of Sito Camocaan. Sitio Camocaan, Puroks 5A, 5B and 7 comprise Sitio Camocaan which is part of Baranggay Aplaya, Hagonoy, Davao del Sur. It is adjacent to the Lapanday banana plantation. In 1997, several individuals residing in Camocaan complained of skin diseases which were ulcerated and non-healing (Quijano and Quijano 2000). Some developed blisters and pruritic lesions. The residents attributed the conditions to the banana plantation pesticides to which they were allegedly exposed. Thus, the residents, through a local organization, sought the assistance of the Pesticide Action Network- Asia and the Pacific (PAN-AP) to look into the problem”.
We are extremely disappointed with this willful public disinformation and manipulation of the facts made by Dr. Allan R. Dionisio, UP Manila and Dr. Annabelle Yumang, DOH Davao at the Camocaan’s People’s Inquiry.
The people of Camocaan, Davao and the nation as a whole, deserve respect, nothing less.
Dr. Romeo Quijano of UP Manila has used his profession as a medical doctor to manipulate and fabricate lies regarding the health conditions in Camocaan. His two articles on Kamukhaan: Report on a Poisoned Village (Annex 16) and Kamukhaan Revisited (Annex 17) presented illnesses of people as caused by pesticides. He has blamed pesticide exposure for some congenital conditions or illnesses of persons who had these conditions before relocating to Camocaan, in search of a better life. We have documented the cases which FPA, in part, investigated and uncovered falsities. The deception has to stop now. (Annex 18).
We maintain that:
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Fungicide use and application in banana is approved by the Fertilizer and Pesticide Authority and the Department of Agriculture.
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The conditions presently in place in Camocaan is so different from those in 2006 when the study was conducted. In fact, there is a 2-hectare cemetery (100 x 200 m2) beside the community (which used to be planted to bananas) which puts a large portion of the community further away from the treated area. A buffer zone is in place beside the community and this is not sprayed aerially.
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Exposure of populations does not exclusively come from exposure to pesticide residues in the air. Other routes such as dietary and occupational are possibilities. For dietary exposure, there are standards to address these concerns, such as MRLs and ADI. This reflects the international community’s efforts at risk assessment. The acceptable daily intake (ADI) for man, expressed on a body weight basis, is the amount of a food additive that can be taken daily in the diet, even over a lifetime, without risk. Thus, the mere presence of pesticide residues does not necessarily mean a health concern.
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The identities of the “sick” people identified in the study, should be immediately endorsed to the municipal health officer, if indeed there is a genuine health concern. This has been made known to the researchers ever since we learned of this study..
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The banana industry is not against organic farming nor are we spraying insecticides and other chemicals hazardous to people’s health and the environment. We do not spray highly toxic chemicals and all that we are asking for is to be allowed to make use of a fungicide-control practice that have been proven safe to both humans and the environment. We have our 30-year track record of safety for all to see.
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It is our corporate social responsibility never to gamble with the lives and future of the hundreds of thousands of residents who are dependent on our continuing viability. We must, by all means, take precaution against all forms of harmful pests and in a manner, as we have been doing the past many years, that will ensure rich harvests but neither sacrifice the health of the people or contaminate the environment.
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It is our humble assessment that the report of the Health and Environmental Assessment of Sitio Camocaan, Hagonoy, Davao del Sur does not have the scientific basis that can withstand the rigor of scientific scrutiny. Obviously, it cannot serve as a basis for concluding that aerial spraying, in the banana plantations, has resulted in health concerns and therefore has to be banned.
We pray that those now under pressure to prove their institutional relevance for whatever purpose it will serve them will do it in the best interest of our country and people. We do share their noble cause of protecting our rich biodiversity and environmental integrity but it must be pursued not with Quixotic exuberance but with a dispassionate, scientific and developmental perspective.
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