06/11/01

Appeal to MO Department of Health to Reject Dead Geese

Dr. Maureen E. Dempsey
Director
Missouri Department of Health
920 Wildwood Drive
PO BOX 570
Jefferson City, MO 65102

VIA FAX: (573) 751-6041

Dear Dr. Dempsey:

I am writing to alert you that the Department of Conservation (MDC) has embarked upon a scheme that involves putting the health of Missouri's most vulnerable at needless risk -- a situation that requires your immediate intervention.

Recognizing that their plans to live-capture and slaughter Canada geese throughout Missouri would not be looked upon favorably by the public (and the public has already expressed its outrage), they have turned to a false-charity public relations gimmick that involves distributing the dead geese to Missouri's needy, homeless and elderly via Missouri food banks. I am writing on behalf of those who look to you to protect the health of all citizens of the state -- especially the needy and disenfranchised -- from potential harm, especially when the source is unscrupulous state agencies attempting to advance dubious agendas.

Using the poor as pawns to appease the conscience of the public and garner acceptance of a cruel, unnecessary and biologically questionable program is a clear case of socio-economic discrimination. The needy should not be forced or allowed to consume unregulated, potentially unsafe "food." Geese are grazers and regularly ingest turf grass chemicals, including herbicides and pesticides. They also frequent industrial sites exposing themselves to halocarbons and heavy metals. Studies have shown that lead is a fairly common contaminant in the flesh of these birds. While the Department of Conservation claims to have carried out a "contaminant study" to assess safety for consumption, it is scientifically lacking.

Dr. Gary Pearson evaluated the report of contaminants by the Missouri Department of Conservation (MDC). He concluded that this report "contains insufficient information to permit an independent and objective evaluation of the reliability of the results of the contaminant analyses reported." The procedures for evaluating chlorinated hydrocarbon residues analyzing (removing the skin) "may have resulted in a substantial under-detection of chlorinated hydrocarbons in the geese." Pearson stated, "The failure to analyze fat from these geese for chlorinated hydrocarbon residues raises serious questions about the validity and objectivity of the study."

Dr. Pearson also questioned the casual dismissal by the MDC of the findings of high levels of lead in the tissue of one of the geese. One goose was, in the words of an MDC staff member "really hot" (high lead level). One sample of breast muscle was found to have 10,700 ppb (wet weight) lead (the World Health Organization limit is 300 ppb), but a second sample from the same goose found < 20 ppb lead. The MDC report dismissed the extremely high levels of lead as a result of lead shot, now illegal in the US for geese (it is still legal in Canada). However, Pearson said: " ...[E]ven a 3 % occurrence of lead shot in Canada geese in Missouri, where the report indicates that lead shot has been banned for waterfowl hunting since 1987, may be significant."

There is little doubt that the Department of Conservation has a vested interest in seeing to it that the dead birds can be distributed to food banks -- it is critical to the propaganda component of their program. On these grounds alone, their studies lack legitimacy. Whatever testing is done to establish safety, they must be done by an independent party and overseen by your department. Wildlife mangers lack the training, knowledge and expertise to determine what is safe for the public to consume and they should not be allowed to do so.

Finally, I raise the concern of "acceptable levels" of various contaminants in goose flesh. Whatever standards exist, they were not designed to predict margins of safety for those whose overall health deviates substantially from "average," or for people who do not have, or have not had, regular access to health care: that is, the very groups targeted to receive the flesh.

All citizens of Missouri, regardless of age, race or economic status, deserve protection from exploitation, especially when it comes to their health. They look to your department for that protection. We are certain that when you review the situation, you will find that the Missouri Department of Conservation has overstepped its bounds by putting their goose-killing program above the health of the State's most vulnerable. We expect that you will use your department's influence to derail a plan that is destructive on so many levels.

Sincerely,

Gregg B. Feigelson, Ph.D.
(845) 732-4704

cc:
P. Kirkpatrick, Executive Director, Central Missouri Food Bank
America's Second Harvest
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