The Tobacco Industry and Pesticide Regulations
The Tobacco Industry and Pesticide Regulations
Tobacco is a heavily pesticide-dependent crop. Because pesticides involve human safety and health issues, they are regulated nationally and internationally; however, little is known about how tobacco companies respond to regulatory pressures regarding pesticides. In this study we analyzed internal tobacco industry documents to describe industry activities aimed at influencing pesticide regulations. We used a case study approach based on examination of approximately 2,000 internal company documents and 3,885 pages of U.S. Environmental Protection Agency documents obtained through Freedom of Information Act requests. The cases involved methoprene, the ethylene bisdithiocarbamates, and phosphine. We show how the tobacco industry successfully altered the outcome in two cases by hiring ex-agency scientists to write reports favorable to industry positions regarding pesticide regulations for national (U.S. Environmental Protection Agency) and international (World Health Organization) regulatory bodies. We also show how the industry worked to forestall tobacco pesticide regulation by attempting to self-regulate in Europe, and how Philip Morris encouraged a pesticide manufacturer to apply for higher tolerance levels in Malaysia and Europe while keeping tobacco industry interest a secret from government regulators. This study suggests that the tobacco industry is able to exert considerable influence over the pesticide regulatory process and that increased scrutiny of this process and protection of the public interest in pesticide regulation may be warranted.
Tobacco is a pesticide-intensive crop. With nearly 27 million pounds of pesticides (including insecticides, herbicides, fungicides, and suckercides) applied to the U.S.-grown crop from 1994 to 1998, it ranks sixth in terms of the amount of pesticides applied per acre [U.S. Government Accounting Office (GAO) 2003]. The tobacco industry regards pesticides as essential to tobacco production, stating that "the crop could not be produced economically without them" (Davis 1989; Philip Morris 1990b). According to industry documents, government-imposed limitations on pesticide use "may present a serious impediment" to the international tobacco trade (Hill 1989). Internal tobacco industry documents provide a window into the tobacco industry's activities regarding pesticide regulations. These case studies drawn from industry documents describe the tobacco industry's responses to pesticide regulatory action. The documents also provide insight into the relationships between the tobacco industry and pesticide regulatory agencies and tensions between business and public health interests.
Litigation against the tobacco industry has resulted in the release of nearly 7 million previously secret tobacco industry documents (Bero 2003; Malone and Balbach 2000). Scanned PDF versions of original handwritten, typed, or printed documents have been archived at the University of California, San Francisco, library in electronic repositories, searchable using basic keywords (http://legacy.library.ucsf.edu). Between July 2003 and February 2004, we searched the archives using a "snowball" sampling strategy, beginning with broad search terms ("pesticide" and "crop protection agent") and using retrieved documents to identify more specific search terms (such as names of specific pesticides, people, and regulatory agencies). Table 1 provides examples of keyword searches and the number of documents yielded. This process produced nearly 300,000 documents relating to many different pesticides. The first author reviewed these documents' index entries and excluded duplicates and documents unrelated to pesticide regulatory issues. The final sample size was approximately 2,000 documents, spanning 1974-2001.
We also filed Freedom of Information Act (FOIA) requests with the U.S. Environmental Protection Agency (EPA) on pesticide issues raised by information in the industry documents, resulting in 3,885 pages of government documents. Finally, we reviewed public health agency reports based on industry documents (Zeltner et al. 2000). We analyzed the industry, government, and public health agency documents by assembling chronologically constructed case studies, a method common to sociology, political science, and anthropology (e.g., analyses of a corporation's organizational structure, a social movement, or a tribe) (Hill 1993; Yin 1994) ( Table 2 ). The pesticides chosen for inclusion [methoprene, the ethylene bisdithiocarbamates (EBDCs), and phosphine] were those for which sufficient information related to regulatory activities was available in the archives to construct a case study.
Tobacco is a heavily pesticide-dependent crop. Because pesticides involve human safety and health issues, they are regulated nationally and internationally; however, little is known about how tobacco companies respond to regulatory pressures regarding pesticides. In this study we analyzed internal tobacco industry documents to describe industry activities aimed at influencing pesticide regulations. We used a case study approach based on examination of approximately 2,000 internal company documents and 3,885 pages of U.S. Environmental Protection Agency documents obtained through Freedom of Information Act requests. The cases involved methoprene, the ethylene bisdithiocarbamates, and phosphine. We show how the tobacco industry successfully altered the outcome in two cases by hiring ex-agency scientists to write reports favorable to industry positions regarding pesticide regulations for national (U.S. Environmental Protection Agency) and international (World Health Organization) regulatory bodies. We also show how the industry worked to forestall tobacco pesticide regulation by attempting to self-regulate in Europe, and how Philip Morris encouraged a pesticide manufacturer to apply for higher tolerance levels in Malaysia and Europe while keeping tobacco industry interest a secret from government regulators. This study suggests that the tobacco industry is able to exert considerable influence over the pesticide regulatory process and that increased scrutiny of this process and protection of the public interest in pesticide regulation may be warranted.
Tobacco is a pesticide-intensive crop. With nearly 27 million pounds of pesticides (including insecticides, herbicides, fungicides, and suckercides) applied to the U.S.-grown crop from 1994 to 1998, it ranks sixth in terms of the amount of pesticides applied per acre [U.S. Government Accounting Office (GAO) 2003]. The tobacco industry regards pesticides as essential to tobacco production, stating that "the crop could not be produced economically without them" (Davis 1989; Philip Morris 1990b). According to industry documents, government-imposed limitations on pesticide use "may present a serious impediment" to the international tobacco trade (Hill 1989). Internal tobacco industry documents provide a window into the tobacco industry's activities regarding pesticide regulations. These case studies drawn from industry documents describe the tobacco industry's responses to pesticide regulatory action. The documents also provide insight into the relationships between the tobacco industry and pesticide regulatory agencies and tensions between business and public health interests.
Litigation against the tobacco industry has resulted in the release of nearly 7 million previously secret tobacco industry documents (Bero 2003; Malone and Balbach 2000). Scanned PDF versions of original handwritten, typed, or printed documents have been archived at the University of California, San Francisco, library in electronic repositories, searchable using basic keywords (http://legacy.library.ucsf.edu). Between July 2003 and February 2004, we searched the archives using a "snowball" sampling strategy, beginning with broad search terms ("pesticide" and "crop protection agent") and using retrieved documents to identify more specific search terms (such as names of specific pesticides, people, and regulatory agencies). Table 1 provides examples of keyword searches and the number of documents yielded. This process produced nearly 300,000 documents relating to many different pesticides. The first author reviewed these documents' index entries and excluded duplicates and documents unrelated to pesticide regulatory issues. The final sample size was approximately 2,000 documents, spanning 1974-2001.
We also filed Freedom of Information Act (FOIA) requests with the U.S. Environmental Protection Agency (EPA) on pesticide issues raised by information in the industry documents, resulting in 3,885 pages of government documents. Finally, we reviewed public health agency reports based on industry documents (Zeltner et al. 2000). We analyzed the industry, government, and public health agency documents by assembling chronologically constructed case studies, a method common to sociology, political science, and anthropology (e.g., analyses of a corporation's organizational structure, a social movement, or a tribe) (Hill 1993; Yin 1994) ( Table 2 ). The pesticides chosen for inclusion [methoprene, the ethylene bisdithiocarbamates (EBDCs), and phosphine] were those for which sufficient information related to regulatory activities was available in the archives to construct a case study.
