On being a modern PELE: a Pragmatic Environmentalist, Lukewarmer, Ecomodernist

Last weekend I had the opportunity to go to my 30^th high school reunion. The reason my reunion is being mentioned in my blog is that part of a 30^th reunion is the inevitable question: “so what are you doing with yourself”? After talking about my wife and kids (the important things in my life) I would simply say that I worked as an environmental chemist. For some that was all the details they needed: I had ended up in science (not a big surprise to the people who knew me then) and was happily employed with a young family and a happy life. Many wanted more details and over the course of the weekend my spiel got more polished:

I am an environmental chemist. I am employed in the field of contaminated sites where I work to clean up old industrial and commercial facilities so that they can be made safe for further uses. I design and execute investigation plans and then develop and implement remediation plans. I also do occupational health and safety testing to help ensure that people have safe and healthy places in which to work.

   

As a spiel it was relatively short but gave a flavour of what I am up to. What it also caused me to do was to ponder what I am in a more general sense. Outside of my identity to my friends and neighbours as a family man and coach (with three kids I have coached many teams of children’s sports) I also have my more “meta” identify. As regular readers of my blog know I am a “Pragmatic Environmentalist” and a “Lukewarmer”. As I have discovered through recent reading, I apparently fit into the mold of an “Ecomodernist”. As a fan of soccer, I was amused to realize that this makes me a modern day PELE:

Pragmatic Environmentalism:

In my mind I am first and foremost an environmentalist. I have worked in the environmental field for the better part of twenty years in activities ranging from ecosystem restoration to ecological and human health risk assessments. In doing this work I have come to understand that the vast majority of the population (including environmental activists) are for the most part “science-blind”. Most have little more than high-school science backgrounds with a very small number having any science at a university level. As for chemistry, most viewed the topic with suspicion in school and outright fear as adults. How else to explain a “food babe” who warns that: “There is just no acceptable level of any chemical to ingest, ever.” As such most Canadians are unaware of the marvels of science that keep their daily lives moving forward and are essentially unaware of the chemistry that helps them live the lives they love. This is how environmentalists can see no irony in complaining about the export of fossil fuels while wearing the fruits of those fossil fuel exports on their backs and feet. The do not understand how the petrochemical industry underpins their every daily activity from the cell phone in their hand, to the gortex jacket on their backs to the polypropylene socks that keep their feet dry, to the medicines they take to get better when sick. The environmentalists talk about moving towards a “fossil-fuel free future” oblivious to the fact that not only are we not close to such a future, but such a future is simply not possible given the state of our civilization. As I pointed out in a previous post (Starting a Dialogue - Can we really get to a "fossil fuel-free BC"?) at best we can approach a point where our home province (British Columbia) no longer relies on fossil fuels for electricity generation, but even then fossil fuels will still make up the lion’s share of our energy mix. Given the absence of alternatives for fossil fuels in the transportation and industrial sectors we need to look at how we handle fossil fuels for at least the next 50 years as we move towards alternatives.

 

Given the foregoing, a pragmatist asks a simple question: given we cannot do without a product, what can we do to make the transport of this product safer? In North America the majority of our raw petroleum supplies are located in the interior of the continent and thus cannot be shipped around by double-hulled tanker. Instead the choices are in order of environmental concern: tanker truck, rail or pipeline; that is it, period, there are no other options. Given the choices at hand, the obvious answer therefore is: invest in the safest, most environmentally benign of the transportation methodologies currently available. Thus as a pragmatic environmentalist I push towards improving our pipeline technologies and capacity. My acquaintances on the deep green end of the environmental spectrum, meanwhile, fight these pipelines tooth and nail, and in doing so they appear oblivious to the fact that the fuel has to move somehow. They talk of trying to “strangle” the oil sands not recognizing the economic folly of such an attempt . What is more, they do not even recognize the irony when at the same time they weep and wail about the dangers of transporting fuel by rail. They are the ones who have made oil-by-rail an economic reality, no one else but them.

  

Being a pragmatic environmentalist also means walking the walk. I would put my carbon footprint up against any of the people who call me a “sell-out” or a “shill”. My wife and I made a conscious choice, almost a decade ago, to live what is now called a “low carbon lifestyle”. At the time it wasn’t chic (and didn’t even have a label) but simply seemed socially responsible. We took the time, to find, and spent a bit more money, to get, a house close enough to my work (and our local grade school) so that I could get rid of my car and we could commute by foot. My wife, meanwhile, arranged to move schools so her commute to work is less than 3 km. This has allowed us to live a suburban lifestyle but only to own a single vehicle. We pay a bit more to shop locally and our kids do their sporting activities in local clubs so that even on the weekend we almost never get more than 10 km from our home (we do travel to the aquarium etc..).  We have not travelled by air in over 15 years and have limited our vacations to our home province. I can’t guarantee that this state of affairs will last forever, but for the last decade we have lived the “act locally” credo.  I am not saying all this to get any acclaim, but rather because being a pragmatic environmentalist means making personal choices and making what little differences we can, however small they may be. In a personal sense it means working to reduce our personal emissions. In a provincial sense it means British Columbia imposing its own carbon tax even though it had the potential to cost us in competitiveness (which in the end it did not) and only made a minor dent on national CO₂ emissions. In a national sense it means fighting for a national program to reduce Canadian emissions even when Canadian emissions only represent a fraction of world emissions. The old adage goes that the trip of a thousand miles starts with a single step and so we must all take that first step individually.

Lukewarmer and Ecomodernist:

As I wrote in my last post, I am also a Lukewarmer. But as I also wrote, I am of the variety that believes that action is necessary to reduce our dependence on fossil fuels with a goal of stabilizing global CO₂ concentrations.  My last post pretty much sums up my position on the topic so I won’t say more on that topic except to point out that we share our planet with countless other species and any attempt to stabilize global CO₂ concentrations must acknowledge the importance of protecting our shared ecological heritage. This brings me to my final label: an ecomodernist. I would direct anyone interested in the topic to An Ecomodernist Manifesto and leave it at that for the moment as this post is already getting long. My next post will go further into the idea of ecomodernism and compare and contrast it with the concept of “degrowth” of which I only recently became acquainted.

On a Broader Definition of a “Lukewarmer”

I have been offline for a bit of a holiday and as such am catching up on some very interesting posts that appeared in my absence. One of the most interesting was from Dr. Tasmin Edwards titled: The lukewarmers don’t deny climate change. But they say the outlook’s fine on the Guardian’s web site.  Dr. Edwards has been a very welcome contributor to the climate change debate since the initiation of her blog (All Models are Wrong, now hosted by PLOS blogs). Dr. Edwards’ contributions have been universally civil, scientifically-sound and devoid of the partisanship that is often associated with the subject matter. While I have sometimes disagreed with individual points within her commentary, I have yet to be disappointed by any of her posts. This most recent post fits precisely into that mold. In it Dr. Edwards does a solid job of summarizing the views of one component of the Lukewarmer community but in doing so she conflates what I view as two divergent streams of Lukewarmers. You are probably asking yourself? Are there really two types of Lukewarmers? My response to that question is twofold:

1) absolutely, and

2) at least.

Just as a spectrum of views exist in other fields so one exists within the Lukewarmer community. There are Lukewarmers who believe that climate change will be mild and can be addressed through mitigative methods and others who believe that low climate sensitivity simply provides more time than the alarmists claim, to wean ourselves off fossil fuels. In the remainder of this post I will expand on this topic.

It was interesting, upon reading Dr. Edwards’ article, to do a few searches for the term “Lukewarmer”. To no surprise, most of the definitions were from people outside the community. The folks at Skeptical Science state that Lukewarmers ignore inconvenient evidence while Bart Verheggen apparently thinks they are total doorknobs. This is consistent with what I observed in an earlier post (Does the climate change debate need a reset? - on name calling in the climate change debate). As I describe, one way to damage the reputation of someone with a differing viewpoint is to label them using your terms. By relabeling “Lukewarmers” as some form of “denier” the “alarmists” attempt to reframe the debate to their advantage. As I presented in my original Lukewarmer post (My Lukewarmer post, or how to lose friends on both sides in the AGW debate) and further detailed in my post on the scientific consensus (About that climate "consensus" we keep reading about) being a Lukewarmer does not make you a denialist. Frankly, being a Lukewarmer doesn’t even require that you stand outside of the scientific consensus in the field of climate change. Rather, Lukewarmers fit neatly into the scientific consensus; they just exist on the lower end of the sensitivity debate. You see all it takes to be a Lukewarmer is a view that climate sensitivity is at the milder end of the range suggested by the IPCC. As Dr. Edwards points out, Lukewarmers are more apt to trust the instrumental record rather than simply relying on the outputs from the global climate models. In this regard Dr. Edwards asks the question:

Do lukewarmers believe ECS is low because they trust the instrumental studies more, or do they trust those studies because they give answers they want to believe?

I have argued previously that the former is clearly the case (although I don’t discount the possibility of the latter in a number of very limited cases). As I have argued in the past, I think it comes down to the types of individuals who make up the core of Lukewarmer community. I go into detail  on this type in my posts “Type I and Type II Error Avoidance and its Possible Role in the Climate Change Debate” and “Does the Climate Change Debate Come Down to Trust Me versus Show Me? - Further thoughts on Error Avoidance”. Both emphasize that most Lukewarmers tend to come from the “show me” intellectual worldview (engineers and non-academic scientists) and most recognize that climate models, while the best tools we have to date, are still not able to make skillful predictions about future conditions. Ever week new information is uncovered to improve the science underlying the models but we are not there yet and until the models can show a better skill at predicting conditions, the instrumental record (and the underlying theoretical geochemistry) wins the day in my books.

Going back to the concept of a spectrum of Lukewarmers, this is where I disagree most with Dr. Edwards. In her post, Dr. Edwards presents a picture of “Lukewarmers” as being (as the title suggests):

“not convinced there’s a substantial risk that future warming could be large or its impacts severe, or that strong mitigation policies are desirable.”

The problem is that Dr. Edwards is portraying only one extreme Lukewarmer position as the sole position of the entire intellectual community. It would be like suggesting that all Christians believe in papal infallibility while ignoring the difference between Catholics and non-Catholics or that all Muslims share identical beliefs while ignoring the differences between the Sunni and Shiite practitioners of the faith. In this it is possible that her view is coloured by her geographic location and her position outside the community. As discussed in her post, Dr. Edwards identifies a number of prominent British Lukewarmers, most of whom indeed hold the positions that jibe pretty well with her description. Prominent writers, like Dr. Matt Ridley and to a lesser extent Nic Lewis, appear to hold a view that climate change could potentially be a relatively benign thing. I hesitate to say more as I do not wish to get bogged down in that discussion. I would merely point out that on this side of the pond there exist a different type of “Lukewarmer” of which I am one and I believe Dr. Thomas Fuller the author of “The Lukewarmer’s Way” blog is another (having mostly completed this post I now see that Dr. Fuller just added a new post: “The Myth of Mitigation Skepticism” which confirms my earlier suspicion).

Lukewarmers, like myself, recognize that too much climate forcing has the potential for consequences that cannot be mitigated without economic, environmental and social hardship. As for climate sensitivity and its importance in the debate, I bring you back to a post I wrote in January where I explained my view on the importance of climate sensitivity: (Why I think Climate Sensitivity is Essential for Developing Effective Climate Change Policy). While Dr. Edwards considers it from an academic position, a Lukewarmer, like myself, would look at it from a pragmatic perspective. If climate sensitivity is lower, it gives us more time to make the necessary changes to address the problem before it gets too late. We don’t need to take the manic actions suggested by the purveyors of the 350 ppm terror scenario. Instead we can wean ourselves off fossil fuels in a step-wise and reasoned manner hand-in-hand with reducing human misery and improving global quality of life. Thus, I view the Lukewarmer’s way (apologies to Dr. Fuller for misappropriating his blog title) as one of moving towards the elimination of fossil fuels as our society’s primary energy source in a pragmatic and humanist manner. In this position, I believe I am joined by Dr. Fuller who warns in his post: “Answering Tamsin Edwards’ Important Question” about overspending, spending inappropriately and concentrate[ing] on appropriate policy options.

I have written several tens of thousands of words on my blog on the topic of renewable energy and have tried to concentrate on the topic of “regionally-appropriate renewable energy” (On “soft climate denial”, regionally-appropriate renewables and marginalizing potential allies in the climate change debate). Like Dr. Fuller I agree that there are some low-hanging fruit that should be addressed ASAP such as those described at Fast Mitigation. The biggest early culprit I see is what he calls "black soot" and I call “black carbon”.  I wrote a detailed post on black carbon (Black Carbon, a Climate Change Topic We Should all be able to Agree on) earlier this year where I wrote:

Looking at black carbon we have a major potential forcing agent for climate change; a serious risk to the cryosphere; and a human health risk of the first order. By targeting black carbon I feel we can get out of our mutual trenches and start working together in a way that will improve the condition of the planet. In doing so we can identify those people actually interested in having a perceptible effect on improving the planet and smoke out the rent seekers and hangers on who seek only to extend the debate for their own purposes

I also see a need to move towards wind, geothermal and hydro in my home province of British Columbia, while moving towards a much greater reliance on nuclear and solar energy from a global perspective. I also believe that getting our kin in lesser developed countries out of energy poverty is a morally necessary goal and by doing so we can help protect a highly stressed ecosphere.

To go back to the spectrum of views. As I am only connected to the European Lukewarmers via the internet I cannot explain why the highest profile members of the community tend to be on the mitigative side of the spectrum. As a Western Canadian, I can only say that those of us on the energy-action side make up a larger percentage of the population in my neck of the woods. I would venture a guess (and only a guess) that the prevalence of Lukewarmers, like myself, in North America is a function of the more alarmist rhetoric and toxic politics we encounter here. Interestingly enough Dr. Edwards ends her post with the question:

If you agree with mainstream scientists, what would you be willing to do to reduce the predicted risks of substantial warming? And if you’re a lukewarmer, confident the Earth is not very sensitive, what would be at risk if you were wrong?

My answer to her first question is simple: we ARE working to reduce the risks. We are just doing so in a manner that doesn’t ignore our shared humanity or cause greater harm to our shared ecological heritage. We do not accept an approach that sentences billions to live in energy poverty, using scarce natural resources to build the open fires they currently rely on to cook their food and keep their children warm. We also do not believe that taking an action simply because you can do so quickly is the right approach. We have had too many monstrous failures (like our policies towards biofuels) that have actually increased our global carbon footprint and it is time to do this right. While I do not require the solutions to be perfect, I do ask that they be both well-considered and good. As for her second question, I would turn it around: if you are so confident that sensitivity is high, what are you doing to reduce your personal carbon footprint? Because as I wrote in a previous post: simply buying carbon offsets is not enough. Every time I am lectured by a high-flying celebrity I become more certain that I do not want them dictating how I should live my life.

More on Gypsy Moth Spraying: Bioaerosols and Medical Symptomatology

I had really hoped that after my first and then second posts on gypsy moth spraying that I could get off the topic and move on to more interesting discussions, but the topic is like the bad guy in a horror movie: you think you have dealt it a death blow only to have it re-emerge for another fight. Like my last post, this one is going to be a bit shambolic as I will attempt to cover several topics that have been raised since the last blog posting. 

On being a paid “shill”

As my regular readers know, I have previously discussed the “shill gambit” in my post “On “Bullies”, “shills” and using labels to shut down legitimate debate”. In that post I was talking about other scientists being called shills, but I wasn’t fooling myself. I knew full well that as I continued to blog about evidence-based decision making, it was only time before I was labelled a “shill”. Now admittedly, I have been called it a couple times on the topic of pipelines, but if pipelines get people excited then spraying for gypsy moths turns it up to an eleven. In the last week I have been called any number of names from “shill” to “unethical” with a few people pointing out that my work as a government scientist, and the owner of a money-making blog, puts me in position of a conflict of interest. I’m afraid to say that both my employer and my wife would be a bit surprised by that line of reasoning. My employer because they didn’t realize that I had left my job to go work for the government and my wife because she knows nothing about the slew of slush money apparently coming my way from unknown “corporate interests”. To put this all to rest, let’s start with the obvious. I do not work for the government. I work in the private sector. I do not get paid to blog, and since my blog site has no ads I derive no income from my blog. I blog on my own time, and never on the company dime, as I enjoy my real job far too much to put myself in any conflict of interest on that front. It goes without saying that since I blog on my own time, the opinions expressed here are entirely my own. For those of you wondering, some friends at work read my blog but my wife does not.

On Bioaerosols and Inhalation Risk

A number of people have directed me to a Facebook page: StopGypsyMothSpraying. At the site is a prominent link to an undated New Zealand TV article on Btk spraying (ref) which I believe refers to spraying conducted in New Zealand in May 1999. The story features a very likable epidemiologist Dr Simon Hales from the University of Otago in Wellington, New Zealand. Dr. Hales brings up some very important points about spraying programmes. Specifically he points out that at the time of the spraying, in May 1999, very little was known about the science of bioaerosol dispersion of this particular compound. For those of you not familiar with the term a bioaerosol is simply a suspension of airborne particles that contain living organisms. The Foray 48B spray is a bioaerosol made up of Btk (a biological organism) in a liquid suspension. Most of the “inert” compounds discussed in my previous posts relate to the liquid suspension. To explain, you can’t simply spray raw bacteria into the air. The sprayed material consists of an active agent (the Btk) in a liquid. If designed correctly, the suspension will not clump and when sprayed correctly will produce uniform droplet sizes which will disperse in a manner that effectively covers the area being sprayed. The chemistry of these suspensions is very tricky and most of the suspensions are the result of years of study (and are thus patented and not shared with competitors). As I discuss in my previous post, the components are known to regulators but are not shared openly to protect all the work invested in producing the recipes. You need the right particle size to get effective coverage and to ensure that the compound hits and stays on the target. For the keeners out there I include a reference that details particle sizes and how they relate to the effectiveness of sprays (ref). 

In the clip from the television programme, Dr. Hales points out that not a lot was known about this topic at the time. That being said, a lot of research has been carried out and many of Dr. Hales’ concerns have been addressed. An example of this is a report titled: “Bioaerosol Health Effects and Exposure Assessment: Progress and Prospects” (2003). It indicated that in some cases, under the wrong wind/humidity conditions, droplet sizes can vary from designated parameters and respirable particles can result in both allergic and non-allergic responses in sensitive populations. The Annals of Occupational Hygiene did a major issue on the topic in 2014. I have attached a copy of the feature editorial which discusses the state of the art in the field (Advancing the Science of Bioaerosols’ Exposure Assessment 2014 ref). The literature indicates that for endpoints like cancer there exists no identified mechanism to elicit the response and thus the likelihood of cancer as a result of the spraying is extremely low (below the de minimis risk level). Moreover, the research indicates, when sprayed under the correct environmental conditions, only a very, very small percentage of the spray actually reaches respirable size. Specifically, Foray 48B spray droplet size is calibrated for ~120 μm. This is far larger than the maximum respirable size of <10μm. In the testing, approximately 0.17% of the volume of spray was determined to be <14 μm in size in bench tests (ref). So while it is clear that the possibility exists that respirable particles will be produced by the spraying, the recent literature dismisses the likelihood that it serves as a significant health risk for the typical community. The language used was pretty certain:

• Some people may experience minor eye, nose, throat and respiratory irritation. The HRAs [health risk assessments] raised the possibility of asthma aggravation of asthma [sic], which was considered biologically plausible, although epidemiological research and surveillance from the WSTM [white spotted tussock moth] operation did not support this.
•  Some people would find the odour of F48B unpleasant. Some people may experience nausea, headache or other symptoms if exposed to unpleasant smells.
• Available evidence does not support any effects during pregnancy on either mother or fetus, or effects on prematurity, miscarriage rates, birth weights, congenital abnormalities.

On Hospitalization and Asthmatics:

In keeping with the sensationalization of the topic, nothing beats the headline from The Province Newspaper on Tuesday: “Two hospitalized as spraying continues in Surrey and Delta against the gypsy moths”. Reading that headline, I thought it might be time to set up the barricades to protect us from the hoards of people rushing to escape Cloverdale for the kinder, gentler world of Langley. Upon reading the article I discovered that The Province was being a bit liberal with the use of the term “hospitalized”. The story describes two individuals who went to the Surrey Memorial Hospital Emergency Room after encountering the spray. Based on my reading of the story, neither “patient” was admitted but rather as a representative of the Health Service noted: “they were fine and they were released”. Now my understanding is that the definition of “hospitalize” includes the requirement for “treatment”. The simple act of walking into an ER and asking to see a doctor really doesn’t count as being “hospitalized” in my books...unless you are trying to drive readers to your online article....

Regarding asthmatics, here we have a group that clearly represents an “at-risk” population that was specifically described the earlier risk assessments. That being said this population has not been ignored in the research and the risk to them has been studied. Specifically, during the 1999 spraying in Victoria, a matched-pair cohort study was carried out to establish the risk to this population (The effects of aerial spraying with Bacillus thuringiensis Kurstaki on children with asthma). The result was reassuring. There were no differences in asthma symptom scores between subjects exposed to the spray and control subjects located outside of the spray zone.  Moreover a larger study conducted at the same time (Human Health Surveillance during the aerial spraying for control of North American Gypsy Moth on Vancouver Island, British Columbia) had a similar conclusion: 

Results to date show no apparent relationship between aggravation of asthma in children and aerial spraying of Foray 48B. As well, no short-term health effects were detected in the general adult population nor in hospital emergency room visits.

So when people claim that no studies have been done on this topic, the correct response is “balderdash”. Surrey and Delta are not the first places this spray has been used. It has been in use for almost two decades in a large number of jurisdictions and each and every one did a risk assessment prior to the spraying and all have found the spray to be safe. Of note, I keep reading a comment that Foray 48B was “banned in New Zealand” but I have yet to find any support for this statement and attribute it to an unsubstantiated urban myth.

The Big Conspiracy

The strangest set of comments have dealt with some unspecified conspiracy between government agencies around the world to ignore the few enlightened individuals on this topic. As I mentioned previously, I have been informed that I am either a witting member of the conspiracy or simply an unwitting dupe. I’m not sure which version I prefer, but do not believe either case. As I mentioned in an earlier post: “Public Sector Compensation - You Get What You Pay for” most of the civil servants in the technical end are underpaid with respect to their private sector peers and many work in the public sector out of a sense of public duty. I cannot believe that every one of these people has been bought out by the dark forces. I think it more likely that if such a conspiracy existed we’d have read about it on WikiLeaks or through some other journalistic enterprise. As for the peer-reviewed literature, it is categorical in that researchers have been unable to demonstrate links to any effects beyond minor discomfort associated with ingesting the spray. The particles, when applied according to specifications, are not respirable and thus would not cause effects in non-sensitized populations. Given the number of exposures necessary to sensitize the population, only the most highly susceptible would appear to even have a chance of having issues. For the vast majority of the population symptoms are limited to minor headaches, a minor odor and a bad taste in the mouth. It is possible that the suspension solution may have food additives that may result in minor reactions but given the minute quantities ingested these symptoms would be expected to disappear shortly after exposure ceased. That being said all studies repeat the same warning: most negative reactions in affected communities will be linked to adverse effects promoted by expectation, otherwise known as “the nocebo effect”.

More on Gypsy Moth spraying: Toxicity redux

Much as I expected, my post on "the nocebo effect" and spraying for gypsy moths” drew a whirlwind of criticism on Twitter and in my email inbox. The major concern had to do with the fact that in my post I dealt with Btk in general and did not concentrate on the specific formulation used for spraying in Surrey and Delta: Foray 48B. Now Foray 48B is a proprietary formulation of Btk produced by Valent BioSciences and is sold in Canada by Valent’s Canadian Agent: Valent Canada Inc.  Valent’s Canadian page for Foray 48B is here while a more detailed set of documents is available at Valent’s US website. The intent of this post is to address my previous deficiency and in doing so build on my previous series of posts on risk assessment and toxicology since, as many of you know, the intent of this blog is to enhance evidence-driven decision-making in British Columbia and understanding the science is the best way to do that. 

Now as I noted above, I did a series of posts explaining the basics of risk assessment and toxicology in February. Unfortunately, due to the nature of my blogging platform (read free and simple since I am a chemist and not a web designer) it is not terribly easy to figure out what I have written in the past so I will summarize here. The intent of that series of posts was to help me out in situations like this. You see talking about Foray 48B would be very hard if my audience didn’t understand the language of the field. The posts started with “How Big and Small Numbers Influence Science Communication Part 2: Understanding de minimis risk” which explained how the science of risk assessment establishes whether a compound is “toxic” and explained the importance of understanding dose/response relationships. It explained the concept of a de minimis risk. That is a risk that is negligible and too small to be of societal concern (ref). The series continued with “How Big and Small Numbers Influence Science Communication Part 3: Understanding "Acceptable" Risk” which, as the title suggests, explained how to determine whether a risk is “acceptable”. I don’t have the space to recap that post here so feel free to read that post then come back...I will wait here for you...okay I see you are back so let’s continue. I then went on to explain how a risk assessment is actually carried out in “Big and Small Numbers in Science Communication Part 4: the Risk Assessment Process. I finished off the series by pointing out the danger of relying on anecdotes in a post titled: Risk Assessment Epilogue: Have a bad case of Anecdotes? Better call an Epidemiologist.  Now anyone who has read all those previous posts can probably figured out what I am going to write next but that would be less fun for me so I will continue here.

The most common comment was by far the easiest to answer: I was informed “that the compound had an MSDS then it must, by definition, be dangerous”. This is simply incorrect. A Material Safety Data Sheet (MSDS) is a basic requirement of the Workplace Hazardous Materials Information System (WHMIS). Now I agree that WHMIS does indeed have the word “hazardous” right in its title but that doesn’t mean that it only regulates “hazardous” materials. Rather the system provides a consistent method to supply employers and workers with information about chemicals and compounds used in their workplace. WHMIS was developed to provide a uniform system to communicate the risks associated with “controlled products”. So there you have another set of scare quotes. You see the unspoken secret about WHMIS is that it covers pretty much every compound that is used in an industrial setting. The reason for this is that due to the nature of industrial processes almost any chemical can have dangerous properties. MSDSs are available for some of the most terrifying compounds out there from distilled water, to Coca-Cola, to table salt? So you are probably wondering: how can distilled water be considered a hazard? Well let’s look at the MSDS. Distilled water is incompatible with: “Strong reducing agents, acid chlorides, phosphorus trichloride, phosphorus pentachloride, phosphorus oxychloride”. Moreover, as any first year chemist who loves seeing cool reactions will tell you, when you mix distilled water with sodium metal the reaction can be very entertaining. So to ensure the safety of employees, MSDSs exist for virtually every compound used in an industrial/commercial setting.

The next common comment was: look at the MSDS and all those restrictions on its use. Now while there are standards for use in preparing an MSDS, we live in a litigious society and some companies can be extremely cautious when they write an MSDS. Consider this MSDS for distilled water: it includes a pretty detailed description of the necessary skin protection when encountering distilled water. It is so entertaining I will present it unedited: 

Handle with gloves. Gloves must be inspected prior to use. Use proper glove removal technique (without touching glove's outer surface) to avoid skin contact with this product. Dispose of contaminated gloves after use in accordance with applicable laws and good laboratory practices. Wash and dry hands.

Full contact:

Material: Nitrile rubber

Minimum layer thickness: 0.11 mm

Now that is some scary stuff! Think about it for a moment, they are warning you not to touch distilled water unless you are wearing gloves. Forget those hospital-issued latex gloves, they aren’t enough to protect you from this dangerous substance, you need to use nitrile gloves. Remember not just any nitrile gloves are enough either, the only safe gloves need a minimum thickness of 0.11 mm. The part I find hardest to figure out is what substance you are expected to use to “wash hands” after exposure to that nasty distilled water! Now not only is that water dangerous to touch, it also has a reported LD50 under the toxicological Information. Specifically rats die when administered an oral dose of >90 ml/Kg. Even more frightening is the fact that distilled water has been “investigated as a mutagen”. According to the Sigma-Aldrich MSDS for distilled water: “To the best of our knowledge, the chemical, physical, and toxicological properties have not been thoroughly investigated” According to the David Gray & Co MSDS: distilled water can be a “very slight eye irritant” and “excessive inhalation may cause drowning”. Based on these MSDSs I would be considered derelict as a father if I put my beautiful daughter in the tub for fear of the potential mutagenic exposure. Can’t let her outside while it is raining as water is an inhalation risk and I will also have to weigh her regularly to ensure I don’t administer too heavy a dose of water through that sippy cup!

Another common complaint was that the compound may not be appropriate for use because according to “A Health Professional Gives Facts about Foray 48B” posted at the No spray zone web site, the material is not even organic. Well while the “certified organic” label is reserved for foodstuffs and is certified by the various appropriate governmental bodies, the Organic Materials Review Institute (OMRI ™) certifies the raw materials and chemicals used in the production of “certified organic” foodstuffs. Unlike normal users of products, the OMRI™ gets to look at the actual chemical composition of a product being considered for certification. As indicated at their Website: Foray 48B has received  certification as for use in certified organic food production. So when “A Health Professional Gives Facts about Foray 48B” the first thing you may want to check is the background information. First and foremost what kind of health professional are you talking about (a toxicologist maybe?). In this case the “Health Professional” is actually an undefined “Mental Health Professional”. So what that means is that the person is apparently not trained in toxicology, epidemiology or other applicable field. Moreover, when this “mental health professional” informs you that “Foray 48B is not "certified organic" you may want to check with the OMRI™ anyways, because well, because. Given an unnamed “mental health professional” on one hand, and the body authorized to certify chemicals as organic by the United Sates Department of Agriculture on the other, you may want to trust the body authorized to certify compounds and formulations as organic.

The final point was that a large percentage of the Foray 48B is made up of mysterious “inert” ingredients. Well as noted OMRI™ got to look under the hood at that list and they still decided to certify the compound as organic.  As for better toxicological data, I have linked to a New Zealand assessment of Foray 48B that includes details of testing up to an including the feeding of Foray 48B to people. Yes they had test subjects take capsules of the stuff daily for five days, they were that confident that it would cause no harm. As described in the document on the use of Foray 48B: 

“Foray’s inert ingredients, which include various carriers, suspension agents, and stabilizers are classified by the Environmental Protection Agency (EPA) as inert ingredients of minimal toxicological concern to non-target organisms and the environment (EPA’s List 4B and 3)”

“All inert ingredients in Foray formulations are included in 40 CFR 180.1001. This list has been designed by the EPA as ‘exempt from the requirements of a residue tolerance on raw agricultural commodities” VBC verifies that none of its Btk formulations contain toxic inert ingredients, such as benzene, xylene, or formaldehyde”

So yes Foray 48B has proprietary compounds that are not on the MSDS, but that compound list is considered to pose an acceptable risk by the EPA , is certified as organic and appropriate for use on organic foodstuffs and is certified to be used up to and on the day of harvest. Yes read that again, you can apply the stuff to plants on harvest day and send them to your local organic market and they will still be considered both safe to eat and organic. 

Honestly at this point I am just banging a drum here folks. The data is pretty overwhelming. The compound has been certified as safe in Canada, the US, New Zealand and every other place where it has been sprayed. It is a certified organic mixture that provides a safe and effective method of controlling a financially devastating pest with a risk that is below the de minimis level. For those people out there complaining about symptoms like sore throat, and difficulty breathing I would direct you to the pollen outlook for the Vancouver because my family has been suffering from the same symptoms described in all the news stories and we are well outside the spray area. We are, however, sitting in the middle of the pollen season and the days suitable for spraying (dry days immediately after a rainfall) are exactly the same days that are most suited for spore dispersal by trees, flowers, grasses, molds and mushrooms. As someone who tracks pollen levels for my work, I can tell you that the best way to avoid waking up with a headache and dry throat is to take a Claritin before you go to bed and if that doesn’t work then sleep with your bedroom windows closed until the end of the pollen season because based on the toxicology that is the most likely culprit for your symptoms.