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BY FAX: 916-324-5872

August 17, 2001

Barry Cortez, Branch Chief
California Department of Pesticide Regulation
1001 I Street
Sacramento, CA 95814-2828

Dear Mr. Cortez:

I read your letter dated July 30, 2001 yesterday.  It was waiting for me when I returned to California.

In your letter you said that the DPR will proceed with the registration of AuxiGro WP (L-glutamic acid)."

Question 1: What is "AuxiGro WP (L-glutamic acid)?"

In your letter you said that "a public report was written summarizing DPR's review and decision to allow registration. The enclosure provides a copy of that report."  I did not find an enclosure with your July 30, 2001 letter.

Question 2: Will you send me a copy of the missing enclosure?

In your letter you state that "DPR' staff have determined that the small amounts of L-glutamic acid being applied would not have an adverse effect on people consuming treated grapes.

Question 3: What is the amount of processed free glutamic acid residue that will be left in and on grapes from application of AuxiGro?

Question 4: What amount of processed free glutamic acid causes adverse reactions in highly MSG-sensitive people?

Material in hand sent to me recently by the EPA states that AuxiGro contains carcinogens.

Question 5: Why is the CDPR licensing a product that contains carcinogens?

Material in hand states that AuxiGro contains hydrolyzed casein (milk) protein. We know, therefore, that in treating crops with AuxiGro, a form of milk protein is being deposited on and in those crops.  We know that no one would ever dream that unprocessed produce would have been treated with a product that contained milk in any form; and the rights of vegetarians and certain religious groups -- and anyone else, for that matter -- to choose what they will eat will be violated. We also know that it is common knowledge that minute amounts of certain allergens, including milk, will trigger adverse reactions, including anaphylaxis, in people who are acutely sensitive to those allergens.  (Laoprasert, N, Wallen, ND, Jones, RT, Hefle, SL, Taylor, SL, Yunginger, JW. Anaphylaxis in a milk-allergic child following ingestion of lemon sorbet containing trace quantities of milk. Journal of Food Protection 61(11):1522-4,1998.)

Question 6: Why is the CDPR licensing a product that will not only be offensive to particular groups of people, but one that contains a hidden potentially lethal allergen?

Material in hand states that there is processed free glutamic acid in AuxiGro over and above the 29.2% active ingredient listed on the label.  Therefore, AuxiGro is misbranded.

Question 7: Why is the CDPR licensing a product that is misbranded?

I am aware that on June 21, 2001, the EPA published the Final Rule: L-Glutamic Acid and Gamma Aminobutyric Acid; Exemptions from the Requirement of a Tolerance.  According to the June 21, 2001 publication of that Final Rule in the Federal Register, that Final Rule establishes exemptions from the requirement of a tolerance for residues of what the EPA refers to as "L-glutamic acid" and also gamma aminobutyric acid on all food commodities when applied/used in accordance with good agricultural practices.

I am also aware that MSG-sensitive people have reacted to processed free glutamic acid in potatoes sprayed with agricultural products that contained processed free glutamic acid.  I believe that your office has received letters from some of those people.  I know that my husband, Jack Samuels, was one of them.  Since potatoes are tubers, and it is the tubers that grow under ground that are eaten (and not the stems or leaves of the potato plants), we know that when potatoes are treated with agricultural products that contain processed free glutamic acid, there is residue remaining in the potato. The EPA Final Rule promulgated on June 21, 2001, did not exempt the processed free glutamic acid (they call it "L-glutamic acid") from the requirement of a tolerance for residues of "L-glutamic acid" in all food commodities.

Since the June 21, 2001 Final Rule did not address the issue of an exemption from the requirement of a tolerance for residues of "L-glutamic acid" in all food commodities, the EPA has not taken a final tolerance action that would allow the CDPR to license AuxiGro.

In licensing AuxiGro for use in California, the CDPR is acting inappropriately.

Question 8: Why is the CDPR licensing a product that will cause there to be residue of processed free glutamic acid in crops when the EPA has not issued an exemption from the requirement of a tolerance for those residues in crops?

I think it is time that you answered my questions about AuxiGro and the processed free glutamic acid contained in it.  Some of these questions have been asked previously, and have been ignored.

I look forward to both your reply and to confirmation that the licensing of AuxiGro for use as a fungicide to be used on grapes has been denied or rescinded.


The Truth in Labeling Campaign
Adrienne Samuels, Ph.D.
1547 Santa Sabina Court
Solana Beach, CA 92075

858-481-9396 (fax)

850 DeWitt Place, Suite 20B, Chicago, IL  60611
adandjack@aol.com 858/481-9333 http://www.truthinlabeling.org

This page was last updated on June 5, 2004.