It's becoming clear why the Joint Fact Finding report on Kauai agricultural pesticide use is such a muddle. Consider the belief system that drove it, as articulated by facilitator Peter Adler to the state Board of Ag this week: “Everyone is entitled to their own facts.”
Ah. No wonder we see high school science projects given the same weight as those conducted by professionals. But if facts are equal to beliefs, what is the value of a fact-finding process?
Too bad we weren't warned about the limitations of such a process before the state/county signed on to this $175,000 project:
Yet joint fact-finding is not appropriate for every conflict scenario. Where there are drastic power differentials, extreme mistrust or hatred of the other side, or volatile social/political concerns, joint fact-finding may be impossible. The process must involve a relatively even playing field so that one side cannot dominate the fact-finding efforts.
So then why did Adler stack the group with those who favored Bill 2491?
Meanwhile, experts shared numerous concerns with Adler and the JFF, but their comments were never incorporated into the group's final report.
Consider this critique by F. DeWolfe Miller, MPH, PhD, Professor of Epidemiology, John A. Burns School of Medicine, University of Hawaii. First he takes apart the health monitoring proposals:
These recommendations were clearly made without professional epidemiological consultation and are typical of many other communities in the US and elsewhere in the world who have tried to link various health outcomes to some geographic marker as a proxy for some kind of potential environmental hazard. There is an abundance of literature on this subject. An example of a local study is by Kirkham (1987).
Linking health outcomes (cancer/BD) to zip codes is not recommended for two reasons. One is statistical. There will not be enough events per zip code to reach “statistical significance”, especially in Kauai. In spite of this, there seems to be an irrational obsession with using zip codes for various useless data mining endeavors.
Even if statistical significance could be achieved, zip codes are not exposures. They are zip codes. Exposure to environmental hazards – in this case pesticides - has to be demonstrated and linked directly and quantitatively to an individual or individuals.
Linking cancer, birth defects or other health outcomes geographically is called by epidemiologists “ecologic study designs”. Inferring the results from ecologic studies, i.e. from groups (zip codes for example) to individuals is termed an “ecological fallacy” and is by definition, flawed. Investigation of birth defects is in the arena of research that should be separately funded though peer reviewed funding sources such as NIH.
The Hawaii State Department of Health should not be bound by this recommendation.
Miller also dismantles the proposal to test workers for pesticides:
The Rationale for this recommendation is confusing: “Pesticides migrating off of their target site has been documented”. This is not a rationale for medical monitoring of agricultural workers. In addition, applicators and field workers are not necessarily the most at risk of exposure. This would depend on many factors.
It would be more cost effective to monitor and test all those who handle and apply pesticides for knowledge, skill, practice and mandated documentation. When a worker tests positive for exposure it is too late.
|Unprotected farmer applying paraquat to eggplant in India.
Miller also dismisses the recommendations to initiate surface water, air, soil and dust monitoring/sampling:
[T]he objectives are not sufficiently clear nor the finding of the report such to justify the costs of testing potentially thousands of environmental specimens from water, soil, and air. Such programs are a costly waste of resources.
What is important is compliance with application methods, rules, and regulations.
The Department of Health has an excellent Hazard Evaluation Program and Director of Health. They routinely update their knowledge on published research for any new health risk factors for exposures to a wide variety of environmental agents including pesticides. Due to budget cuts there is not an environmental health epidemiologist in the Department of Health. A crucial state function is to have in house expertise to assess and evaluate health impacts from environmental sources, including pesticides. Adding this capacity to Hazard Evaluation and Emergency Response office will strengthen the ability of the state to address public health concerns from potential pesticide exposures.
Miller then states what has been obvious to so many — except Adler and the JFF group:
[S]ome of the recommendations made are not entirely consistent or follow logically with the findings, given the lack of any documented negative health impacts. Moreover, the recommendations given are not without impact in terms of cost, resources, expertise, and interpretation. On the face of it, it would seem that the recommendations made were for yet unforeseen or yet to be established events.
Yet none of Miller's thoughtful assessments found their way into the final report. Why?
Then there was this, from Dr. Barry M. Brennan, UH Emeritus Extension Specialist for Pesticide Safety and Agrosecurity:
My major concern is the composition of the SG [study group] and the failure to include articulate and knowledgeable experts like Drs. Lyle Wong and Po-Yung Lai as consultants or volunteers. Pesticide investigations can be highly complex and both Wong and Lai have the requisite experience, knowledge, and understanding to address questions and concerns of the SG. Without their input and guidance the SG may be unaware of how pesticides are managed, where and why environmental and human health impacts are most likely to occur, and what changes might be needed to improve Hawaii’s pesticide laws and regulations, inspection process, educational programs, licensing and registration policies and programs.
I am concerned about the appearance of bias. First, because of the lack of input from individuals like Drs. Wong and Lai, and second because of the appended comments from Milton Clark regarding the origin of MITC [stinkweed at Waimea Canyon Middle School]. (At the very least, Dr. Li should have been asked to respond to Clark’s comments.)
Secondly, while you involved a long list of people in your acknowledgements (myself included) how and why were these individuals picked to participate in the SG discussions? Why weren’t authorities like Drs. Lyle Wong, Po-Yung Lai, and Mike Kawate included as resources? Both Drs. Wong and Lai have working knowledge of the environmental fate of pesticides, the registration process and state and federal pesticide laws and regulations. Both have served as Pesticide Branch Chief, Head of the Plant Industry Division and as UH faculty or administration. Did your Project Team have a strong science background related to pesticide use and how did you define “strong science”? Having a professional degree in one area of science or medicine does not make you a professional in an unrelated field.
Indeed. Why did Adler engage biased consultants, like Surfrider's Carl Berg, rather than ag and pesticide experts?
It is unrealistic to compare pesticide use by the corn seed companies in Hawaii with pesticide use in major corn growing mainland states. Hawaii grows foundation seed; mainland states grow sweet, field, feed, and seed corn. The weather systems, ecology, insect and weed pests, soils, and economics are also different. Foundation seed is a specialty crop and therefore considered a high cash crop like flowers, fruits and vegetables. Foundation seed production is far less tolerant of pest damage than mainland corn production.
Relative to California, Hawaii’s Pesticide Branch is greatly understaffed. Several states have attempted to duplicate California’s pesticide regulatory framework with little success despite investing considerable financial resources.
Determining the “chronicity” of pesticides used in Hawaii is the responsibility of EPA as defined in the oft amended Federal Insecticide, Fungicide, and Rodenticide Act and the Federal Food, Drug, and Cosmetic Act.
Adler and JFF members owe both the Kauai community and the Hawaii taxpayers who funded this project an explanation as to why these and other relevant, legitimate critiques were completely ignored.
In closing, I'll return to the essay that started this post:
Ultimately, though, the greatest benefit joint fact-finding can achieve is an improved relationship between the conflicting parties. When a group gathers together to achieve a common goal, members become more familiar. Trust is improved. The other side becomes more human, their concerns more readily validated. The act of deciding to work with individuals formerly considered "the enemy" is really an act of good faith, one that fosters mutual respect and understanding.
Considering that the three members who didn't support Bill 2491 were driven to resign, and then derided as "petulant" seed industry shills, I'd say Adler scored an epic fail.