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Coqui
Hawaiian Integration and Reeducation Program
P.O.
Box 1880, Pahoa, HI 96778
www.HawaiianCoqui.org
808-935-5563
August
28, 2002
Gary
Gill
Deputy
Director for Environmental Health
State
of Hawaii Department of Health
P.O.
Box 3378
Honolulu,
HI 96801
Dear
Mr. Gill:
Thank
you for your response to my letter of August 15, 2002
regarding the experimental use of caffeine to kill frogs
here in Hawaii. Your
letter has ignored many of the issues we have raised,
such as the use of human subjects as part of this
assessment of the effect of caffeine spraying, which
requires informed consent and an Institutional Review
Board to oversee the experiment.
You also ignored the many physiological risks
caffeine poses to the public, including those groups
known to be at high risk such as pregnant women,
toddlers, and anyone with circulatory disease or high
blood pressure.
You
chose to limit your response to our comment about the
mutagenic nature of caffeine, which you question since
it is not listed as a carcinogen by the National
Toxicology Program or the California EPA’s
Reproductive and Cancer Hazard Assessment Program.
You have asked for me to support my contention
that caffeine is a mutagen.
According
to the application made to the EPA by the Hawaii DOA and
DLNR for Section 18 exemption of caffeine, it states on
page 8 that, “One publication has also indicated that
caffeine induces chromosomal breakage in fruit fly,
higher plants, and a variety of microorganisms.”
The EPA’s Section 18 label for this
experimental use of caffeine states that, “Some
studies have indicated possible chromosomal damage at
high levels of application, therefore applications
should not be made to high-valued plants.”
From
a different source is a statement made by the Sandoz
Pharmaceuticals company about its product Cafergot,
which contains caffeine.
In the 1996 Physicians’ Desk Reference it
states, “Caffeine is known to cross the placenta and
has been shown to be teratogenic in animals.”
It
is interesting to note that in 1980, the FDA issued a
warning advising pregnant women to limit their exposure
to caffeine, since at high doses, caffeine seemed to
have a teratogenic effect in mammals.
The
MSDS-CCOHS (Material Safety Data Sheets from the
Canadian Center for Occupation Health and Safety), dated
January 9, 1997, states, “The Chronic Effects: There
is limited evidence that when overexposure occurs,
Caffeine is teratogenic and tumorigenic in laboratory
animals. There is also limited evidence that Caffeine is
mutagenic in laboratory cell cultures.
Until further testing has been done, it should
be treated as a possible teratogen, tumorigen, and
mutagen in humans.”
Again,
according to the National Institute of Environmental
Health Sciences, “At extremely high doses (much higher
than the average person can consume on a regular basis),
caffeine can be a mutagen (capable of making changes at
the cellular level), a potential teratogen (capable of
affecting the fetus) and a probable carcinogen as
well.” (http://www.niehs.nih.gov/external/faq/clean.htm).
A
recent review article on the teratogenicity of caffeine
is also instructive. “It should be noted that evaluation of the developmental
risks of caffeine based solely on epidemiological
studies is difficult because the findings are
inconsistent. Even more important, is the fact that
caffeine users are subject to multiple confounding
factors that make analyses difficult and prevent
investigators from reaching definitive conclusions. For
example, the caffeine content of foods and beverages can
vary considerably, which can interfere with obtaining
valid interpretations from many human studies.”
It goes on to state, “the overall conclusion is
that caffeine is a chemical, among a long list of drugs
and chemicals, that may have the potential to injure the
embryo if used in marked excess.” (MS Christian, RL
Brent. Teratogen Update: Evaluation of the reproductive
and developmental risks of caffeine.
Teratology, Vol 64 Issue 1 (2001) p.51-78.)
Perhaps
most sobering of all is the statement that,
“Overindulgence in xanthine beverages may lead to a
condition that might be considered one of long-term
poisoning. There are also rare persons who are so sensitive to
caffeine that even a single cup of coffee will cause a
response bordering on the toxic.” (Goodman and
Gilmans’s The Pharmacological Basis of Therapeutics. 8th
ed. NY, NY Pergamon Press, 1990.
You
cannot ignore the studies that show mutagenicity to
humans, even if some studies disagree.
There is not enough information at present. However, clearly, caffeine has not been proven safe.
The key question is whether the residents of
Hawaii are going to add to the bulk of caffeine research
by being forced to participate in the proposed caffeine
experiment.
Your
letter also mentions that caffeine is quickly
metabolized and eliminated from the body, implying that
mutagenicity is unlikely since the body does not
accumulate caffeine.
However, several studies on animals have shown
that a single high dose of caffeine was enough to
produce embryonic death and malformations.
(References available, if requested.)
This means that accumulation of caffeine is not
necessary to elicit a mutagenic response.
Further, the daily consumption of caffeine by the
average citizen today provides a constant exposure to
caffeine.
Keep
in mind, too, the synergistic and antagonistic effects
of caffeine in combination with other drugs.
For example, the combined action of caffeine and
histamine is greater than the sum of their individual
actions with respect to the secretion of pepsin and
stomach acid. (By
the way, caffeine is known to cause ulcers.)
Caffeine also may enhance the cardiac inotropic
effects of beta-adrenergic stimulating agents.
Caffeine has also been reported to increase the
metabolism of several drugs, including aspirin and
phenobarbital.
And caffeine has been shown to increase the
teratogenic effect of other drugs, such as acetazolamide,
mitomycin C, hydroxyurea, and 5-fluorouracil.
There
is also a relationship between one’s level of health
and caffeine’s effects. Liver damage, for example, impairs caffeine metabolism and
clearance, as would kidney disease.
These confounding issues have been ignored in
this letter, but are nevertheless important to keep in
mind when considering the potential effects of the
caffeine experiment on the Hawaiian public.
Interestingly,
since caffeine is so widely used, and since many
billions of dollars are made annually selling coffee,
chocolate, tea, and caffeine-containing beverages, you
can understand why caffeine’s effects on health are
controversial. Nicotine, alcohol and caffeine are commonly used drugs in our
culture, with large industries invested in their
continued consumption.
All three have been claimed to create health
problems, as well as to provide health benefits. Like most things, there are advantages and disadvantages to
these drugs, and those invested in selling a product
point out the advantages of their product.
This explains why caffeine has been shown to be a
mutagen in many studies, yet continues to not be labeled
as such. With
billions of dollars invested in caffeine, it would take
unequivocal evidence, and mountains of it, to get an
adverse labeling of caffeine.
But this is politics, not science, or
preventative medicine.
Finally,
I was wondering if you realized that the State of Hawaii
has a huge conflict of interest regarding this proposed
use of caffeine as a pesticide.
The University of Hawaii, which is promoting this
use of caffeine, also owns the patent for the caffeine
gene, which was granted in 1999!
The developer of this patented gene, Dr. John
Stiles, was a Dean at the University, and left to start
Integrated Coffee Technologies, Inc., (ICTI), which has
the exclusive license for the use of this patent.
ICTI has been working on an uncaffeinated coffee
by blocking this gene.
However, Dr. Stiles has told me that the caffeine
gene could also be placed in bacteria to produce
genetically engineered caffeine in the laboratory.
He said the market value for caffeine is
currently too low to justify its production this way,
which could produce cheap GE caffeine.
However, if caffeine does become approved as a
pesticide, the market value of caffeine would increase.
This means that the University’s patent and its
license of that patent to ICTI would increase
tremendously in value if caffeine becomes approved as a
pesticide.
The
State of Hawaii has a clear conflict of interest in this
caffeine business and its promotion as a pesticide.
ICTI has stockholders, some of whom could be in
the government. Frankly,
I don’t know who the stockholders are.
But with the State and Federal governments biased
towards performing a caffeine experiment here in Hawaii,
it makes one wonder.
Is this all about frogs, or is it really all
about caffeine and money?
Remember,
the frogs are not a health threat.
The caffeine is.
Your
position is that we have insufficient data to state with
certainty whether caffeine can cause mutations and
cancer in people. However,
should we try the caffeine experiment and see?
I hope not!
And this ignores the host of other physiological
and psychological effects that caffeine is known to
cause. Caffeinism
is already a common problem for many.
Given the high doses of caffeine many people
currently consume each day, acute caffeine poisoning is
a real concern. And,
as I have mentioned in previous letters, there is no
antidote for caffeine poisoning.
If
you cared about prevention, we would agree that it is
prudent to take the side of safety.
Since caffeine could be a mutagen in humans, then
prudent avoidance of its use could prevent a
catastrophe.
Surely,
if the interest were there, an alternative to caffeine
that is safe could be found to help control the frog
numbers. The
way it seems now, however, the money is on caffeine.
The fact that the U of
H owns a patent for the caffeine gene casts
serious doubt on the integrity of this caffeine
proposal, and its true purpose.
And
keep in mind that we are only talking about frog
control, not frog eradication. Like the mongoose, they are here to stay, according to the
DOA and DLNR. Caffeine’s
ultimate effect on the frogs is still unknown, although
it is realized that the caffeine will kill much more
than frogs, and may pose a threat to the water supply,
as well as to aquatic life.
Caffeine
is currently found in water supplies in several
countries, including the mainland U.S., as a
contaminant. It
is said to display “very high mobility” if released
in the soil. This
means it will probably pollute our water supply.
I know that caffeine proponents will say they
expect that it will decompose quickly in water and pose
no threat at low concentrations.
But again, nobody really knows for sure.
That’s why this is an experiment with the
environment, as well as with the public.
What
I see, then, is a publicly funded caffeine experiment on
the people and environment of Hawaii designed to get
approval for caffeine as a pesticide thereby increasing
the value of caffeine and making the production of GE
caffeine a profitable enterprise.
It may have nothing really to do with frogs.
The fact that we are being told by the USDA
Wildlife Services that there is no alternative to
caffeine to kill the frogs reinforces this view,
particularly since the caffeine has been proposed by
this same agency, and this same agency will be receiving
millions of dollars per year for its administration.
In addition, the USDA is doing the EA on the use
of caffeine, making the conflict of interest even worse.
Do
your job, Mr. Gill!
Protect the people and environment of Hawaii.
Let the USDA Wildlife Services, DOA, and DLNR
come up with a PROVEN SAFE method for frog
control. The
public needs to be protected from risks, not placed at
risk. And
since caffeine could be lethal and mutagenic, the risks
of its use are too great, particularly when the
potential benefit of its use simply amounts to ongoing
frog control.
Sincerely,
Sydney
Ross Singer
Director,
CHIRP
Cc: Dr.
Lyle Wong -- DOA
Gilbert Coloma-Agaran – DLNR
Cooperative Extension Service, USDA, Univ. of
Hawaii
Mike Pitzler -- USDA
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