DECLARATION OF GRACE ZIEM

I, Grace Ziem, M.D., Dr. P.H., declare:

1. My name is Grace Ziem. I submit this declaration in support of the petition of the Northwest Coalition for Alternatives to Pesticides to require full disclosure of pesticide ingredients on pesticide product labels. I am a physician with a private practice in occupational and environmental medicine, specializing in chemically-induced illness. I have been in practice for 30 years and currently manage over 300 patients with chemical sensitivity. I am currently a co-investigator in a research study of chemically-exposed patients with the Johns Hopkins School of Hygiene and Public Health, and a Clinical Assistant Professor in the Department of Epidemiology and Preventive Medicine at the University of Maryland School of Medicine. I teach occupational medicine to medical students. A copy of my résumé is attached to this declaration as Attachment A.

2. I specialize in the care of patients who have become chronically ill through exposure to toxic substances. Pesticides are the single most common chemical type that induces this type of chronic illness, with chlorpyrifos heading the list.

3. I could provide better, more efficient health care if all product ingredients were disclosed on pesticide labels.

4. When ingredient information is not available, diagnosis is more complicated. If a patient has been exposed to a pesticide product and the product label does not reveal all ingredients in the product, I must contact manufacturers to acquire information for treatment purposes. This is not always possible given time constraints of urgent patient care. Complete disclosure of ingredients, including inert ingredients, is necessary in order to diagnose why a patient has certain chemical antibodies, why a poison has penetrated through skin, or what kind of skin protection is needed.

5. Calling manufacturers to acquire ingredient information is time consuming and difficult. I must call the manufacturer, try to reach the right person in the technical office, and respond to any claim of trade secrecy. I am often forced to fax some kind of written guarantee that I will not disclose the information.

6. Even when a manufacturer verbally discloses to me the ingredients in a product, verbal information is not as reliable as written information. Manufacturers tend to check written information more carefully. When I get information verbally, therefore, it not only takes time away from patient care, but I also do not have as much confidence in the information.

7. Patient care suffers due to the time it takes to acquire information from manufacturers. I may need to spend 15-20 minutes or more getting verbal information on a pesticide, even if I reach the correct technical expert right away. For most doctors, 15-20 minutes is the entire length of a visit. Regardless of the length of the visit, however, time that can and should be spent with the patient is spent obtaining basic information on ingredients from the manufacturer.

8. Patients have an even harder time getting information from manufacturers. Manufacturers are very reluctant to give information on the ingredients in their products directly to people who have been exposed to those products.

9. In emergency situations the lack of information needed to do proper testing can lead to serious consequences. Labels that fail to disclose complete ingredient information prevent doctors from performing the necessary diagnostic tests and make accurate interpretation of test results more difficult.

10. Most physicians do not know how to go about getting information on product ingredients. They do not know that they have a right to this information, and therefore fail even to initiate the fact finding process. Some doctors assume that there are no other ingredients than those disclosed on the label. The patient ultimately suffers when doctors do not have the information necessary to diagnose illnesses.

11. Inerts can compound injuries caused by active ingredients. Synergistic interactions may cause a chemical to enter the skin more readily, make a substance more irritating, or cause more respiratory irritation in people who have asthma or other reactive airway diseases.

12. Symptoms and bodily effects of the chronic illnesses caused by exposure to chemicals are often serious and can have compounding effects on one's bodily functions. Some of the effects include: permanent damage to the brain and the rest of the nervous system; disruption of male and female hormone levels; damage to the immune system, which may become excessively activated (initiating new allergies or autoimmunity); and impaired immune functions that increase the likelihood that the body will develop infections.

13. Chemically-induced illness is occurring with increasing frequency. Studies show that the United States population has an increased sensitivity to chemicals due to increased nationwide exposure to pesticides. Numerous studies indicates that 15 or more percent of the United States population has an increased sensitivity to chemicals. Patients with increased sensitivities to chemicals will suffer more severe effects from pesticides than from other chemicals.

14. One illness resulting from increased pesticide exposure is time-dependant sensitization. The process of repeated exposure followed by intervals on no exposure need only occur a few times for people to develop sensitization. I have seen patients develop severe lifelong illness with just a few days (or less) exposure to a pesticide. The time-dependant sensitization mechanism causes permanent alteration in brain function. Complete ingredient disclosure on pesticide labels would help physicians simplify the treatment of this growing problem.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 20th day of January, 1998.

Grace Ziem, M.D., Dr. P.H.