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 Post subject: THE WISDOM OF HOLLAND ▬ November 2009
PostPosted: December 16th, 2009, 10:30 am 
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THE WISDOM OF HOLLAND ▬ November 2009


( PDF documents concerning this topic, with photos, are available at
force.of.de.nature@gmail.com )


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PEST CONTROL PRODUCTS

A BRIEF OUTLINE
OF REAL SCIENCE
AND ACTUAL FACT

( Adapted excerpts )

November 2009

John J. Holland
Communications Director
Integrated Environmental
Plant Management Association
of Western Canada


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HEALTH CANADA RE–EVALUATIONS

By the end of 2009 or early 2010, Health Canada plans to have re–evaluated all pest control products registered in Canada prior to 1995. At least 80% of this work was completed by July 2009, with the most common landscape and garden pest control products such as 2,4–D already re–evaluated. Health Canada has a mandate to approve only those pest control products that show no significant increased health risk, including cancer.


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2,4–D RE–EVALUATIONS

2,4–D is the active ingredient in the majority of lawn weed control products, and also has the distinction of being one of the main targets of anti–pesticide activity and attacks by many organizations and activists ─ at least, those who are unable to appreciate or understand the vast amount of research to which this product has been subjected.


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2,4–D HISTORY

2,4–D was first registered in Canada in 1946.

Since that time, there have been numerous re–evaluations, by the P.M.R.A. ( Pest Management Regulatory Agency of Health Canada ), the U.S. E.P.A. [ Environmental Protection Agency ], the World Health Organization ( W.H.O. ), and the European Commission.

In fact, despite the opposite claims of many anti–pesticide organizations ( including the Canadian Cancer Society ), NO REGULATORY BODY IN THE WORLD CLASSIFIES 2,4–D AS A HUMAN CARCINOGEN.

The P.M.R.A. has stated that ...

“ No other international body considers 2,4–D to be a human carcinogen. Based on all available and relevant data, Health Canada agrees with this position. ”

Reference : Questions And Answers. Final Decision on the Re–Evaluation of 2,4–D, P.M.R.A., January 14, 2009, Available Online.

The U.S. Environmental Protection Agency [ E.P.A. ] has stated that ...

“ The Agency has determined that the existing data do not support a conclusion that links human cancer to 2,4–D exposure. ”

Reference : Decision Not To Initiate Special Review, August 08, 2007, Available Online.

According to many internationally respected experts on 2,4–D, including Dr. Len Ritter ( Executive Director, Canadian Network of Toxicology Centres ) and the respected American toxicologist Dr. Frank N. Dost, 2,4–D is probably the most studied and best understood of any chemical ― not just pesticide ― in existence.


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PEST MANAGEMENT REGULATORY AGENCY
OF HEALTH CANADA (P.M.R.A.).

This government agency employs over 350 qualified scientists, including ...

• Biologists,
• Chemists,
• Toxicologists,
• Epidemiologists,
• Plant Pathologists,
• Weed Scientists, and
• Entomologists

They are all dedicated to the evaluation of pest control products. One must wonder why the Canadian Cancer Society never references the findings of the P.M.R.A. in its campaign against the use of pest control products, and instead prefers to claim that pest control products are “ KNOWN ” to cause cancer.


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THE ONTARIO COLLEGE OF FAMILY PHYSICIANS
[ OCFP ] 2004 PESTICIDE LITERATURE REVIEW

This “STUDY ” has been widely used by anti–pesticide groups as part of their claim of a “ GROWING BODY OF EVIDENCE ”, and has then been accepted by many municipalities as proof of the carcinogenicity of pest control products.

However, the [ OCFP ] Review has been internationally discredited, due to the fact it consists of cherry–picked epidemiological studies, with virtually no reference to important and relevant toxicological research.

Copied below, as one example, are excerpts from an analysis of The Ontario College of Family Physicians [ OCFP ] Review in the U.K. Government’s Report to the Royal Commission on Environmental Pollution ( by Dr. Michael Burr, 2005, available online ) :

• The treatment of [ OCFP ] review papers is unclear and appears inconsistent.

• The [ OCFP ] review takes a rather superficial approach in bringing together the findings of the individual studies.

• Few of the cited studies [ by OCFP ] adequately address the issue of confounding by co–exposures. Much of the evidence supporting an association between pesticide exposure and cancer is derived from occupational exposures, e.g. in agriculture, where animal viruses, diesel fumes, fertilisers ( sic ) and other factors may play a role.

• The [ OCFP ] review seems to over–interpret the findings, given the limitations of the relevant studies; strong conclusions are drawn from evidence of rather weak quality. 


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PRECAUTIONARY PRINCIPLE

This principle is used as the ultimate tool and guiding light by those opposed to the use of pest control products. There are numerous definitions of this principle ( which is also seen as anti–science by many scientists ), but the generally accepted one is that of the Rio Declaration, from a United Nations Conference on Environment and Development held in Rio de Janeiro in 1992.

This document states that ...

“ Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost–effective measures to prevent environmental degradation. ”

Dr. Keith Solomon is Professor at the Centre for Toxicology and Department of Environmental Biology, University of Guelph, and Director, Canadian Network of Toxicology Centres.

As Dr. Keith Solomon explains :

“ Landscape and garden use of pest control products does not qualify for consideration under the precautionary principle. They are not serious,
they are selective to pests, have low toxicity to non–target organisms, and are well understood. The effects of these pest control products are not irreversible. There is rapid recovery through reinvasion and weed seeds and most need to be used at least once per year. ”

Reference : Questions And Answers About Landscape and Garden Pest Control Products, Dr. Keith Solomon, March 27, 2007.

The Rio Declaration, however, did not embody a vague enough definition for anti–pesticide and unscientific organizations such as the Canadian Cancer Society, which instead choose to use the definition contained in the Wingspread Statement :

“ When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. ”

Note that “ SERIOUS AND IRREVERSIBLE ” has been deleted from the original.

This “ STATEMENT ” of the principle was formulated by a small group of environmentalists meeting in the U.S. in 1998, and it is not difficult to see why it would be chosen over the Rio Declaration as the weapon of choice.

In a 2006 published report by the prestigious British House of Commons Select Committee on Science and Technology, it was stated that ...

“ [ ... ] the term ‘ precautionary principle ’ should not be used, and ( we ) recommend that it cease to be included in policy guidance. ”  

Also stated, by the British House of Commons Select Committee on Science and Technology, was the following :

“ In our view, the terms " precautionary principle " and " precautionary approach " in isolation from any such clarification have been the subject of such confusion and different interpretations as to be devalued and of little practical help, particularly in public debate. Indeed, without such clarification and explanation, to elevate the precautionary approach or principle to a scientific methodology, which can be proved or disproved to have been applied in any particular case, is both unrealistic and impractical. It also provides ammunition for those seeking to promote an overly cautious approach to innovation or exposure to any risk at all. ”

Reference : Science and Technology – Seventh Report, House of Commons Science and Technology Committee Publication, 2006.


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INCONVENIENT FACTS

● Despite claims to the contrary, there are NO viable, efficacious, or economical products to replace present pest control products.

● There are only two “ ALTERNATIVE ” products approved for lawn care by Health Canada : Sarritor and corn gluten.

Sarritor is 5–10 times more expensive ― and certainly no safer ― than 2,4–D, and works only on top growth, necessitating even more applications.

Corn gluten can only used as a pre–emergent ― which means it is not effective for pre–existing weeds ― and provides only poor results.

● Despite claims to the contrary, children and pregnant women are taken into account when pest control products are registered in Canada :

“ [E]xtra safety factors were applied to the no effect level identified in animal toxicity studies to protect population groups, such as children and pregnant women, that may be more susceptible to the potential effects of pest control products. This resulted in reference doses that were 300– to 1000–fold lower for these groups for these sensitive groups, which are more protective than the minimum 100–fold safety factor. Thus, products will not be considered acceptable for continued registration unless the estimated human exposure is at least 300 times to 1000 times less than the level at which there were no observed effects in the studies examined. These levels ensure the most sensitive population groups ― children and pregnant women ― are protected. ”

Reference : Health Canada’s P.M.R.A., Re–Evaluation Decision RVD2008–11, May 16, 2008, Available Online.

● Many “ ORGANICS ” are considerably more toxic than conventional counterparts.

For example, consider copper, which is used by organic farmers, and is, indeed, labelled as “ ORGANIC ”. Yet, copper is non–degradable, corrosive, more toxic than its conventional counterparts, and can cause kidney and liver damage.

● Claims by anti–pesticide organizations that business increases for applicator companies after a ban are completely false.

The Statistics Canada figures used as “ PROOF ” are gleaned from a catch–all category that includes all landscape related companies, such as landscape installation and grass–cutting operations. If switching to products deemed “ ORGANIC ” increases income, why would applicators be opposed ? 


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BOTTOM LINE

THE CANADIAN CANCER SOCIETY IS NOT A SCIENTIFIC BODY : IT IS A FUND–RAISING ORGANIZATION, CONSISTING OF VOLUNTEERS AND ADMINISTRATORS. MUCH THE SAME CAN BE SAID FOR OTHER NON–SCIENTIFIC ORGANIZATIONS, SUCH AS TOXIC FREE CANADA AND THE CANADIAN ASSOCIATION OF PHYSICIANS FOR THE ENVIRONMENT (CAPE).

The anti–pesticide organizations have no one in their employ with recognized pesticide training or appropriate scientific expertise.

Compare this with the over 350 qualified scientists at Pest Management Regulatory Agency of Health Canada, and the thousands at the U.S. Environmental Protection Agency.

What is the rationale that causes municipalities to choose to listen to those emotionally and irrationally opposed to the use of pest control products, rather than the actual experts ?

Why is it that uninformed opinion and unsubstantiated claims take precedence over science for so many Councils and Councillors ?

According to Dr. Keith Solomon, the University of Guelph Professor of Toxicology, and an award–winning and internationally respected expert on pest control products, a lot of this has to do with “ BYLAW ENVY ”.  

There has, in addition, been an almost universal lack of due diligence: if a number of municipalities pass a pesticide ban, then this alone is taken as acceptable “ PROOF ” of the need for further bans and one municipality simply copies the bylaws of others.

Add to this mix the non–scientific approach of the Canadian Cancer Society ( which, because of other ― good ― work done by them, manages to still be viewed as highly respected and reputable ) and other anti–pesticide organizations.

Many unsubstantiated claims are presented to Councils, using a combination of misinterpreted, poorly conducted studies and fraudulent information.

Thus is laid the groundwork for what appears superficially to be suitable grounds for a ban. However, “ FACTS ” cannot be validated by majority votes, and science is not determined through groundless emotion or uninformed public opinion polls.


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For additional detailed scientific information from respected non–industry scientists and sources, contact :

John J. Holland
Communications Director
Integrated Environmental
Plant Management Association
of Western Canada
iepma@shaw.ca


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John J. Holland is Communications Director for Integrated Environmental Plant Management Association of Western Canada (I.E.P.M.A.).

He is one of the most eloquent and intelligent writers on the subject of public policy and pest control products.

Here is a list of Mr. Holland’s career highlights and accomplishments :

Honours BA in History and Geology.

Post–graduate work in History.

After university, co–owned a large bookstore in Ontario.

Moved to British Columbia from Ontario in 1978.

Worked for a structural pest control company in British Columbia for three years, the last two of which Mr. Holland was a supervisor.

Owned a large tree and lawn care company in the Okanagan from 1983 until 2004, when he retired.

One of the founders of the ESA (Environmental Standards Association – forerunner to the Integrated Environmental Plant Management Association of Western Canada) in 1984.

President of the Environmental Standards Association, 1985 – 1994.

Vice–President of the Integrated Environmental Plant Management Association, 1998 – 2007.

Director of the Integrated Environmental Plant Management Association, 2007 – present.

According to Mr. Holland : “ Although I have never used my degree in the profession for which I studied, I found that the training I received in the methods of research was invaluable in enabling me to discern the facts of the real science behind the use of pest control products. Not being a scientist, I have always been guided by the work of those who are the actual experts. ”




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William H. Gathercole and Norah G

National Organization Responding Against Huje that harm the Green Space Industry (NORAHG)

William H. Gathercole, Founder

For a free Force of Nature e-newsletter, contact force.of.de.nature@gmail.com


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FORCE OF NATURE was launched for continuous transmission on the Internet on January 1st, 2009. It is a series of e–newsletters destined for the Green Space Industry, the Environmental–Terror–Movement, Government Officials, and the Media, nation–wide across Canada, the United States and overseas.

Force Of Nature is the brainchild of William H. Gathercole and his entourage. Norah G is actually an acronym for the stable of anonymous producers and writers that contribute to this e–newsletter and have now replaced Mr. Gathercole. They consist of people from the following industries : Distribution, Fertilizer, Golf, Lawn Care, Manufacturing, Municipal, Nursery, and Orchard. Many of these people are leaders in their own industries. The opinions expressed in Force Of Nature, even though from an INDEPENDENT PERSPECTIVE, may not reflect those of everyone in the GREEN SPACE INDUSTRY, or Mr. Gathercole’s many associates. Be warned ! Force Of Nature may sometimes be very irreverent and fearless with these e–newsletters. Mr. Gathercole is now retired from Force Of Nature, although his name continues to appear as the founder.

William H. Gathercole is a principal FOUNDER of the Modern Professional Lawn Care Industry in BOTH Ontario and Quebec. He holds a degree in Horticulture from the UNIVERSITY OF GUELPH, and another pure and applied science degree from McGILL UNIVERSITY. He has worked in virtually all aspects of the GREEN SPACE INDUSTRY, including GOLF and PROFESSIONAL LAWN CARE, and has served in public affairs, workplace safety, and environmental compliance. Mr. Gathercole has supervised, consulted, programmed, and/or overseen the execution of HUNDREDS OF THOUSANDS of pest control applications in the urban landscape. He has trained, instructed, and consulted with THOUSANDS of turf managers and technicians. Mr. Gathercole has also been an agricultural agronomist. For many years, Mr. Gathercole was a contributing columnist for TURF & Recreation Magazine, Canada’s Turf and Grounds Maintenance Authority.

Mr. Gathercole has followed the evolution of ENVIRONMENTAL TERRORISM for over a quarter–century. His involvement in environmental issues reached a fevered pitch in the 1990s, when he orchestrated, with his colleagues, legal action against the prohibition of pest control products in the Town of Hudson, Quebec. For FIFTEEN YEARS, the strategies designed and implemented by Mr. Gathercole and his colleagues guaranteed the control of Enviro–Terror for the entire Modern Green Space Industry across Canada. Although he can be accused of being Anti–Environment–Movement, he is, in fact, simply a strong advocate FOR the Modern Green Space Industry. However, this position has not precluded him from criticizing the Green Space Industry itself. Nonetheless, his vast knowledge of our long journey with environmental issues is UNDENIABLE. ( Hopefully ! )

The mission of Force Of Nature is as a National Organization Responding Against Huje that harm the Green Space Industry (NORAHG) with statements and activities seeking to prohibit FEDERALLY LEGAL, SCIENTIFICALLY SAFE, and TOTALLY IRREPLACEABLE conventional pest control products. Enviro–Maniac–Culprits are identified on the basis of their statements, activities, affiliations, and whereabouts. Even though each Enviro–Maniac–Culprit is a mis–guided adversary, each still deserves our respect. The terms Maniac, Culprit, Terrorist, or Basterd are not accusations of any legal wrong–doing. Force Of Nature is simply holding Culprits accountable for conspiring to change public policies that TERRORIZE and THREATEN the Green Space Industry. Force Of Nature believes that the pretentious prohibitionist policies of the Environmental–Terror–Movement is leading to LOSS OF REVENUES, BUSINESS FAILURES, BANKRUPTCY, and UNEMPLOYMENT, inflicting DESPAIR and DESTITUTION for THOUSANDS of victims throughout the Green Space Industry. The actions of Maniac–Culprits–Terrorists–Basterds in the movement are viewed as a form of TERROR against the Green Space Industry. The information presented in Force Of Nature has been developed for the education and entertainment of the reader by providing a sequence of historical events with commentary. Additionally, Force Of Nature inspires people to believe that ENVIRONMENTAL TERRORISM can be STOPPED ! The events, characters, companies, and organizations, depicted in this document are not always fictitious. Any similarity to actual persons, living or dead, may not be coincidental. All document excerpts and pictures contained in Force Of Nature were found somewhere on the Internet. We believe that they are in the public domain, serving one of the following purposes : archive, education, promotion, publicity, or press release.

The following Force Of Nature documents are currently available ― ● Alberta Prohibition ● British Columbia Prohibition ● Canadian Association of Physicians for the Environment ● Canadian Cancer Society ● Canadian Environmental Law Association ● Consequences ● David Suzuki Foundation ● DDT and Politicized Science ● Death and the Environmental–Terror–Movement ● Enviro–Money ● Environmental Terrorists Unmasked ● Fertilizer-Terror Is Next ● June Irwin, The Clown of Junk Science ● Kazimiera Jean Cottam ● Landscape Trades Capitulate ● New Brunswick Prohibition ● Nova Scotia Prohibition ● Ontario Prohibition ● Organic Fertilizers ● Pesticide Free BC ● Pets and Lawn Care Chemicals ● Prince Edward Island Prohibition ● Quebec Prohibition ● Rachel Carson, The Queen of Junk Science ● Salmon Arm BC Prohibition ● The 9/11 Era of the Green Space Industry ● The Failure of Integrated Pest Management ● The Looming Golf Industry Shipwreck ● The Industry Strikes Back ● The Misconceptions About Cancer ● The National Annihilation of the Modern Green Space Industry ● The Wisdom of Bill Bell ● The Wisdom of Drysdale ● The Wisdom of Health Canada ● The Wisdom of Holland ● The Wisdom of Lowes ● The Wisdom of Mains ● The Wisdom of the Solomons ● Ask For a Copy of Any Back Issue of Force Of Nature Today. Read All About Enviro–Maniacs and Their Environmental–Terror–Organizations in Force Of Nature ! The Whole Truth From An Independent Perspective ! Force Of Nature is TOTALLY INDEPENDENT of any trade association or business operating within the Green Space Industry. DON’T THANK US. IT’S A PUBLIC SERVICE. AND WE ARE GLAD TO DO IT.

_________________
FORCE OF NATURE


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