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Patricia A. McDaniel,¹ Gina Solomon,^2,3 and Ruth E. Malone⁴

¹Center for Tobacco Control Research and Education, University of California, San Francisco, California, USA; ²Natural Resources Defense Council, San Francisco, California, USA; ³Division of Occupational and Environmental Medicine, Department of Medicine, University of California, San Francisco, California, USA; ⁴Department of Social and Behavioral Sciences and School of Nursing, University of California, San Francisco, California, USA

Abstract
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. Key words: ethylene bisdithiocarbamates, Environmental Protection Agency, methoprene, pesticide regulation, phosphine, tobacco industry, World Health Organization. Environ Health Perspect 113: 1659-1665 (2005) . doi:10.1289/ehp.7452 available via http://dx.doi.org/ [Online 8 August 2005]

Address correspondence to P. A. McDaniel, Center for Tobacco Control Research and Education, University of California-San Francisco, 530 Parnassus Avenue, Suite 366, San Francisco, CA 94143-1390, USA. Telephone: (415) 514-9342. Fax: (415) 514-9345. E-mail: patricia.mcdaniel@ucsf.edu

We thank E.A. Smith and B. Skinner for critically reviewing drafts of the manuscript.

This research was supported by grants CA90789 and CA095989 from the National Cancer Institute and by American Legacy fellowship funding.

The authors declare they have no competing financial interests. G.S. is employed by an environmental nonprofit organization with an interest in ensuring that regulations of toxic chemicals are as health protective as feasible.

Received 27 July 2004 ; accepted 8 August 2005.

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