California Dept. of Food and Agriculture, Pesticide
Monitoring Program

*including residues of pesticides not authorized for use in

the commodity tested.

Footnotes

1. The experiments on toxicology of UDMH were in some cases unreliable. The test animals were compared with controls run 7 years earlier. The drinking water containing the UDMH was changed only once in 2 or 3 days. UDMH decomposes in water to formaldehyde dimethylhydrazone. In an experiment with hamsters, the animals were "suffering from degenerative diseases". In another study (Haun et. al.) the test

2.

substance was not analyzed and it had a boiling point 30° 40° C higher than that of UDMH.

No effect was detected in mice fed 10 and 20 ppm of UDMH. This dose is 22,000 times higher than the dose calculated by NRDC for children.

The effects at higher levels (40 and 80 ppm) were "merely
a consequence of severe liver toxicity" (Chaisson, C.F.)
which interfered with catabolism of estrogenic steroids,
thus causing tumors. Dr. Chaisson notes that "pre-puberty"
animals would be expected to be less vulnerable, since
the causative factor the hormones I would be more scarce.

-

"Since daminozide and UDMH do not cause genetic
damage, an argument that exposure to low levels of
these chemicals early in life would cause tumors
later in life has no credibility. (If the liver is
not damaged and no cellular genetic damage has occurred,
no effect is expected at any point in life.)

The tumors noted in these experiments are very

rare in humans, but they have been found in females
who have been treated for a long time with

therapeutic levels of estrogens (very high levels
of hormones) for other health problems. This
again demonstrates that high levels of circulating

hormones can cause the effects noted in the experimental
animals."

Her conclusion is that "at low levels of human dietary
exposure UDMH and daminozide (Alar) do not pose a carcinogenit.
risk.".

I agree with her conclusion. UDMH is a good example of

a threshold, below which there is no effect.

References

Mayo Clinic Institute Letter pp 4-5, June 1989 Mayo Clinic
Institute Minnesota.

Dvorak, John C The Forbidden Fruit Scam from Chile, San Francisco Examiner p. A25, March 17, 1989.

Rosen J. D. The Death of Daminozide, Department of Food Science Rutgers University, New Brunswick, NJ 08903, pp. 1989.

Chaisson, C.F. Overview of the evaluation of carcinogenic risk of Alar and UDMH, Technical Assessment Systems Inc., Washington, DC 20007.

California Department of Food and Agriculture, Results of Residue Monitoring Program, 1988 and 1989, Discussion of Risk Management, Environmental Protection and Worker Safety, 1220 N. Street, Sacramento, CA 95814.

Scheuplein, Robert, Paper presented at AAAS Meeting New Orleans, LA February 19, 1990, Food and Drug Administration Center for Food Safety.

Brookes, Warren Commentary in Cortlandt Forum pp 17-18, August 1990.

Ames, Bruce N, What are the major carcinogens in the etiology
of human cancer? In Important Advances in Oncology 1989
J. B. Lippincott Co., Philadelphia, 1989

Jukes, Thomas H., Chasing a receding zero, J. AM, College
Toxicology 2, 147-160 (1983).

Ottoboni, Alice The Dose Makes the Poison: A plain language
guide to toxicology (book) 1984 Vincente Books, Berkeley, CA
222 pp.

THE ALAR SCARE, 1989

by Thomas H. Jukes

University of California, Berkeley

Using questionable science and credulous news media,

the Natural Resources Defense Council (NRDC) frightened mothers into pouring apple juice down the drain and grocers into pulling fruit from their shelves.

On February 26, 1989, "60 Minutes" correspondent Ed Bradley warned on nationwide TV that "the most potent cancer causing agent in our food supply is a substance sprayed on apples to keep them on the trees longer and make them look better. That's the conclusion of a number of scientific experts...." This statement was untrue.

The TV screen showed an apple with a skull and

crossbones on it. Alar was found non-carcinogenic in either mice or rats when fed at doses as high as 10,000 ppm (1% of the diet).

Alar (daminozide) is a plant growth regulant that is sprayed on apple trees to prevent early drop and to aid ripening of apples, especially red ones. It is classified as a pesticide by governmental regulations, not because it kills pests (which it does not). It is used on other crops to a lesser extent than on apples.

Chemically speaking, Alar is a compound of succinic acid joined to unsymmetrical dimethyl hydrazine (UDMH), which has the chemical formula H2N-N(CH3)2. Succinic acid

HOOC-CH2-CH2-COOH, is a normal food substance that is formed in the body from glucose. UDMH is set free from Alar by cooking apple products in processing. Alar is not carcinogenic in animal tests, but toxic levels of UDMH have produced tumors in mice. Earlier tests of UDMH in mice were rejected by EPA's scientific advisory panel as being seriously flawed. Further experimental work on this effect of UDMH is in progress, and was regarded as incomplete by the EPA, although it was stated on February 1, 1989 by EPA that some of the mice fed 80 ppm of UDMH in the current experiments were dying early and developed cancer. EPA also stated simultaneously that "it may be argued that the deaths are the result of excessive toxicity, which may compromise the outcome of the study."

Hydrazines, derived from ordinary mushrooms, have been found to induce cancer in mice and hamsters. Regulatory decisions require sound scientific evidence, and this is not complete for UDMH.

Pesticide residues in foods are widely alleged to be carcinogenic, even though no case of cancer, and, for that matter, no major illness in a consumer attributable to pesticide residues in foods produced by approved methods has ever been recorded. There have been occasional occurrences of allergic illnesses caused by the use of sulfite as a fungicide on grapes and lettuce.

Anti-pesticidism has given rise to expansion of the organic food industry and to the professional involvement of