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Alisha Morris
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1 FMC Corporation 1735 Market Street Philadelphia, PA phone fax February 13, 2009 Mr. Michael Gavshon, Producer CBS News, 60 Minutes Building 10, Chiswick Park 566 Chiswick High Road London W4 5XS Dear Mr. Gavshon, Thank you for offering FMC the opportunity to participate in your forthcoming segment on the Maasai people in Kenya. After careful consideration, we have decided not to do an on-camera interview for your story. However, we have attached to this letter a written statement about Furadan and allegations about its misuse in Kenya, and detailed responses to the questions you posed as well as other information about Furadan. We trust that you will make every effort to include some part of our written response in your story. Please contact us if you have any additional questions or need any more information. Sincerely, Milton Steele Vice President and General Manager FMC Agricultural Products Group

2 FMC Statement to CBS News 60 Minutes FMC is a 120-year-old global company dedicated to delivering innovative products that improve the lives of people around the world. We take tremendous pride, not only in our products, but in our stewardship responsibilities. Therefore, we have been very concerned about allegations that pesticides are being misused to control predator populations in remote areas of Kenya. We were particularly alarmed when one of our products, Furadan insecticide/nematicide, was alleged to be potentially connected to the death of lions in the Maasai Mara Reserve in Kenya. FMC strongly condemns any misuse of Furadan and supports the Kenyan government s position that the deliberate use of a pesticide to poison wildlife is illegal and punishable under law. We have worked with the Kenyan government, our distributor, and other pesticide manufacturers on stewardship initiatives to promote proper product use and to alleviate human-wildlife conflict issues in Kenya. FMC is a member of Crop Life International, a federation of the plant science industry, formed in 1991 to help train growers in the proper use and storage of chemicals, create poison information and treatment centers, improve product labeling and educate school children on the hazards of pesticides. FMC works diligently to address any incidences of misuse of its products. When allegations surfaced last year that carbofuran may have been used to poison wildlife in the Maasai Mara, FMC, out of an abundance of caution, immediately suspended the export of Furadan to Kenya. We also immediately offered technical assistance to Kenya s Pest Control Products Board (PCPB) in conducting their investigation. The PCPB is the government agency in charge of regulating pesticide products and, in that regard, is the Kenyan equivalent of the U.S. Environmental Protection Agency. Subsequent to the PCPB s investigation, we dispatched a senior regulatory toxicology manager to conduct an investigation of our own into the allegation and product stewardship.

3 The PCPB s investigation concluded that there was no connection between Furadan and the deaths of the animals in the Maasai Mara Reserve. Nevertheless, FMC has not introduced any additional Furadan product into the sales channel since last May and has no intention to do so until after we consult with stakeholders on the means by which it could be effectively re-introduced. Furadan remains a useful product, important to the sustainability of agriculture in Kenya. FMC believes the proper use of Furadan does not create risk to human health, wildlife, or the environment, and we will continue to promote its responsible use.

4 ADDITIONAL INFORMATION ABOUT FURADAN AND ALLEGATIONS ABOUT ITS MISUSE About Furadan Since its inception in 1967, Furadan has become one of the most widely used pest control insecticides in the world. It is most commonly used in protection of crops such as rice and corn, though it is labeled for safe use on many crops. Because of its versatility and effectiveness, Furadan is used in more than 80 countries by both large commercial farms and small plot growers. How Furadan is used The primary use of Furadan in Kenya is for the control of nematodes microscopic worms in the soil that can severely damage or totally destroy a crop. There are only two products, Furadan and an organophosphate product, available to small farmers in Kenya for the control of nematodes. How Furadan is sold In Kenya, FMC sells Furadan through a single distributor. The product is a granular formulation that can be used on corn, potatoes, vegetables, bananas and horticulture crops. It is distributed through Agrovet shops, the preferred retail outlet to smaller farms. Furadan granules have a uniquely distinctive purple color, so that the farmer can clearly see whether the product is being applied in the proper location for plant protection purposes.

5 Responsible use One of FMC s core principles is to responsibly steward our agrochemical products so that growers will benefit from their use in agriculture without causing harm to humans, the environment, or wildlife. We condemn the use of our products by anyone as a means to kill any predatory wildlife. FMC regularly communicates with its distributors and farmers about the latest information about our pesticide products, their intended uses, and the consequences of misuse. Furadan, like all pesticide products, is highly regulated. Sale or distribution of a pesticide product without a label, or use of the product not according to its label instructions, is illegal. Our labels are available in a variety of languages and include pictograms as a means to effectively communicate proper use and safety practices to farmers. FMC also requires its distributors to conduct training seminars to promote safe use and storage of our products. FMC performs studies so that we understand the characteristics of our products and that information forms the basis for the product label use directions which must be approved by the government before a product can be sold, distributed or used. As part of our ongoing, global stewardship initiatives, FMC has joined forces with CropLife International, a federation of the plant science industry committed to sustainable agricultural practices. FMC was one of the first to participate in the CropLife International Safe Use initiative, launched in Kenya in This initiative was intended to train growers on the proper use and storage of chemicals, create poison information and treatment centers, improve product labeling, and educate school children on the hazards of pesticides.

6 2008 Maasai Mara Incident In early 2008, FMC was made aware of a potential lion poisoning in the Maasai Mara Reserve in Kenya. In response, we decided, out of an abundance of caution, to suspend the export of Furadan to Kenya. In addition, we offered our cooperation in developing and interpreting evidence of any carbofuran involvement to the government agency conducting the official investigation. In concert, we opened our own investigation. Kenya s PCPB Investigation The investigation of the Maasai Mara incident was conducted by the Pest Control Products Board (PCPB), the Kenyan government agency that regulates pesticide products. The PCPB worked with the Kenya Plant Health Inspectorate Service (KEPHIS) during the course of their investigation. KEPHIS analyzed soil and plant samples supplied by PCPB using high pressure liquid chromatography, or HPLC, which is the preferred scientific method for the analysis and quantification of chemicals such as carbofuran. By contrast, the Mara Conservancy samples were analyzed with an out-dated qualitative method known as thin layer chromatography (TLC) which has been scientifically surpassed by HPLC. The PCPB-KEPHIS investigation determined that there was no connection found between the dead animals and the suspected chemical [carbofuran.]. (See full PCPB report attached.)

7 FMC s Investigation As noted above, FMC conducted its own investigation. We wanted to make every effort to determine the root cause of the death of these animals and better understand the allegations of misuse. FMC sent a senior regulatory toxicology manager into the region to work with our local distributor, the local industry association, as well as government and NGO officials to determine if our product was involved. We interviewed officials from the Mara Conservancy, PCPB, the government lab that conducted the TLC analyses on the Mara samples, KEPHIS (which conducted the HPLC analysis of PCPB s samples), Kenyan Wildlife Service and Serena Lodge manager and staff. Among our findings were: No detectable residues of carbofuran (LOD=0.35ppm) were found in soil or plant samples. There was no report of seeing any colored granules in any animal involved in the incident, nor did anyone report finding any containers of Furadan in the area. No Furadan products were used at the lodge or by the staff on their small garden. The lodge and staff quarters are area almost entirely encircled by an electric fence making it virtually impossible for a hippo to enter the lodge grounds to feed. The small garden outside the lodge perimeter enclosed with the barbed wire fence showed no signs of hippos in the area (no footprints). There is no agriculture in the Maasai Mara Reserve, so there is no reason to use Furadan or any other agricultural products within the Reserve. Our scientists calculated the labeled use of carbofuran for crops in the garden, if used, would have left a maximum 1.6 mg/kg (parts per million) of residue in the plants, and a normal size hippo would have to eat 1,500 kg of grass/plants to consume a toxic dose, 40 times what a hippo normally eats. Our scientists also calculated that, if a hippo did theoretically consume 1,500 kg of grass, then a single lion would have to consume 19,680 kg of hippo meat or about 10 entire hippos to reach a toxic dose.

8 Based on these findings and scientific data, we reached the same conclusion as the PCPB that there was no connection between carbofuran and the deaths of the animals. Other incidents The PCPB also investigated other suspected misuses of carbofuran. In 2004 and 2005 there were reported poisonings of lions in the Likipia area. A subsequent PCPB investigation found that strychnine, not carbofuran, was the cause. In 2006 in Tsavo West, there were more suspected illegal baitings. Again, a PCPB investigation found the presence of a carbamate and an organochlorine in the stomach contents of the dead lions. No carbofuran was detected. Where Furadan is Made and Sales in Kenya The Furadan granular product shipped to Kenya was formulated at the FMC plant in Illinois. FMC does not disclose sales and volumes figures for competitive reasons, but we would characterize our Furadan sales as modest in Kenya.

Consumer Concerns About Pesticides in Food

Cornell University Program on Breast Cancer and Environmental Risk Factors in New York State (BCERF) March 1999 Consumer Concerns About Pesticides in Food This fact sheet covers the following key topics