October 5th, 2011
EPA-HQ-OPP-2008-0850
Submitted via
Mr. Richard P. Keigwin, Jr., Director
Pesticide Re-Evaluation Division
Office of Pesticide Programs
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460-0001
We, the undersigned, conclude that continued use of chlorpyrifos presents very serious environmental health risks to farmworkers, their families, surrounding communities, and the consuming public.Children, infants, and pregnant women are particularly vulnerable to harm. Agricultural producers already have access to less hazardous pest control methods.We strongly urge that chlorpyrifos not be reregistered for continued use.
We are heartened by The Obama Administration’s August 4, 2011Memorandum of Understanding on Environmental Justice and Executive Order 12898, and the recent announcement of Plan EJ 2014. We hope that these announcementsrepresent meaningfulsteps toward finally achieving a sustainable future; where environmental health, safety, and security are treated as fundamental human rights for all, regardless of race, ethnicity and income.
We are concerned, however, that as this Administration cultivates an understanding of and strategy to pursue Environmental Justice, the concerns and voices of one of the communities most disproportionately affected by environmental injustices are conspicuously missing from the national dialogue. We fear that EPA will buckle under political pressure to maintain the status quo; even where change is most needed, such as in pesticide registration reviews. To truly achieve Environmental Justice, this Administration must reject self-interested deceptions perpetuated by the pesticide industry.It must act decisively to protect farm worker communitiesby banning chlorpyrifos.
Due to pesticide exposure, farmworkers suffer from more chemical related injury and illness than any other workforce in the nation.[i] The danger from exposure to pesticides is not limited to the work sites. Families of farmworkers are put at risk through contact exposure to residues left on clothes and skin. Pesticide drift exposes nearby communities, including homes and schools. Pesticide exposure also harms consumers, who ingest residues of pesticides in their food. Farmworker families suffer multiple exposure sources to these chemicals; resulting in a higher body burden of toxins.
Chlorpyrifos is amongst the most dangerous pesticides still used in agriculture. This chemical is so toxic that the EPA banned it for nearly allresidential uses in 2000; citing risks associated with the toxin including “nausea, dizziness, confusion, and at very high exposures, respiratory paralysis and death.”[ii] However, it is still permitted and widely used for agricultural purposes.[iii] Chlorpyrifos is now known to be even more dangerous than was previously believed at the time of the EPA action. Recent studies have revealed links to lung cancer,[iv] birth defects,[v] neurological impairment,[vi] developmental delay,[vii] and acute poisoning.[viii]
Despite these widely known dangers, recognized as too great to allow chlorpyrifos into our homes for residential purposes, farmworkers remain exposed to this hazardous chemical. Many farmworkers are exposed when handling and applying chlorpyrifos products. Many more are exposed through direct skin contact with residue left on crops and in the soil. Farmworkers are also subjected to exposure through inhalation when there is pesticide drift from application areas toward nearby fields and other areas where workers are present, including in their homes.
Farmworkers unintentionally expose their families with residues left on their clothes and bodies. This type of exposure can be chronic and on-going, as chlorpyrifos can linger in housedust for many years.[ix] The extent to which farmworkers and their families continue to be exposed to this toxic chemical is well documented. Sampling tests found chlorpyrifos contamination of the air, soil, house dust, and even in blood and urine samples of farmworker communities.[x]
Exposure to this toxic chemical is particularly harmful to children, who have a reduced ability to detoxify the poison.[xi] The damage caused by chlorpyrifos begins in the womb, and can have profound effects on a child’s development. Studies in New York City that contributed to the decision to ban chlorpyrifos from homes linked prenatal exposure to low birth weight, significant physical and mental developmental delays, and attention deficit disorder.[xii] Similar studies found that pregnant farmworkers experienced the same, and in many cases higher, amounts of chlorpyrifos exposure as the women surveyed in New York.[xiii] Many farmworker communities face these same high exposure rates today, ten years after chlorpyrifos was taken off the shelves for use in our homes.[xiv]
Despite these hazards, approximately 10 million pounds of chlorpyrifos are applied in US fields every year.[xv] It is applied on a wide variety of popular fruits and vegetables; including corn, broccoli, peanuts, tomatoes, onions, lemons, oranges, pears, grapes, cherries, blueberries, and apples. It is also used in the ornamental plant industry.[xvi] This widespread use, combined with studies showing that the health hazards of chlorpyrifos can affect people whose only exposure is through their food, mean that the dangers posed by this toxin extend from the field to the plate.[xvii]
Over a decade has passed since the EPA took action to protect families from the potentially lethal health effects of chlorpyrifos in our homes. Since that time, new data has revealed that the full extent of the danger is far greater than first realized. Yet the men, women, and children who cultivate, pick, and distribute our food are regularly exposed to the same, and even higher, levels of this toxin that led to it being banned from our homes. Chlorpyrifos can still be found in the air and soil in farmworker communities. It still contaminates the skin, lungs, and blood of farmworkers and their children across the country. Although thecontinued useof chlorpyrifos poses a threat to everyone, this is undoubtedly an instance of environmental injustice. Farmworker communities are a vulnerable population, shouldered with an unequal burden of toxic exposure. They deserve the same protection deemed necessary for all other families ten years ago. Continued use of chlorpyrifos in agriculture calls into question the violation of the civil and human rights of the largely ethnic minority farmworker community. We urge you to apply the principles announced in the Environmental Justice Memorandum of Understanding. Ban all remaining uses of chlorpyrifos,and finally put an end to this unequal burden hoist upon those who keep us fed.
[i] Calvert et al., Acute Pesticide Poisoning Among Agricultural Workers in the United States, 1998-2005, American Journal of Industrial Medicine 51:8830898 (2008); Martin Donohoe, MD and Eric Hansen, MD Health Issues of Migrant and Seasonal Farmworkers, Journal of Health Care for the Poor and Underserved, Vol. 14, No.2, p. 157, (2003)
[ii] EPA Chlorpyrifos Revised Risk Assessment and Agreement with Registrants; Office of Prevention, Pesticides and Toxic Substances: Washington, DC (2000)
[iii]EPA, 738-F-01-006, February (2002)
[iv] Lee WJ, et al. Cancer Incidence among Pesticide Applicators exposed to Chlorpyrifos in the Agricultural Health Study, Journal of the National Cancer Institute, 96:1781-1789, 2004
[v] Curl et al, Evaluation of Take-home Organophosphorous Pesticide Exposure among Agricultural Workers and Their Children, Environ Health Perspect (EHP) 110(12), A787-792, (2002); Fenske et al, Children’s Exposures to Chlorpyrifos and Parathion in an Agricultural Community in Central Washington State, EHP 110(5), 549-553, (2002); Koch et al, Temporal Association of Children’s Pesticide Exposure and Agricultural Spraying: Report of a Longitudinal Biological Monitoring Study” EHP 110(8), 829-833, (2002); Simcox et al, Pesticides in Household Dust and Soil: Exposure Pathways for Children of Agricultural Families, EHP 103(12), 1126-1134, (1995); Fenske et al, Strategies for Assessing Children’s Organophosphorus Pesticide Exposures in Agricultural Communities, Journal of Exposure Analysis and Environmental Epidemiology, 10, 662-671 (2000)
[vi] Kamel F, et al. Neurologic Symptoms in Licensed Private Pesticide Applicators in the Agricultural Health Study. Environ Health Perspect, 113:877-882. (2005); Rohlman D, et al. Neurobehavioral performance in preschool children from agricultural and non-agricultural communities in Oregon and North Carolina. Neurotoxicology, 26:589-598 (2005); Slotkin, TA. Developmental Neurotoxicity of Organophosphates: A Case Study of Chlorpyrifos, Chapter 21, Toxicology of Organophosphates and Carbamate Compounds (2006)
[vii] Young et al, Association Between In Utero Organophosphate Pesticide Exposure and Abnormal Reflexes in Neonates, Neurotoxicology 26:199-209 (2005); Eskenazi et al, Organophosphate Pesticide Exposure and Neurodevelopment in Young Mexican-American Children, EHP; 115:792-798 (2007)
[viii]Calvert et al., Acute Pesticide Poisoning Among Agricultural Workers in the United States, 1998-2005, American Journal of Industrial Medicine 51:8830898 (2008); California Department of Pesticide Regulation Pesticide Illness Reporting System (
[ix] Stout et al, American Healthy Homes Survey: A National Study of Residential Pesticides Measured from Floor Wipes. Enviro Sci and Technology, accepted March 5, 2009; M. Nishioka et al., Measuring transport of Lawn-applied Herbicide Acids from Turf to Home: Correlation of Dislodgeable 2,4-D Turf Residues with Carpet Residues and Carpet Surface Residues,Env. SCI Technol. 30 (1996)
Thompson et al, Pesticide Take-Home Pathway among Children of Agricultural Workers: Study Design, Methods and Baseline Findings, J Occup Environ Med, 45:42-53, (2003); Curl et al, Evaluation of Take-home Organophosphorous Pesticide Exposure among Agricultural Workers and Their Children, Environ Health Perspect (EHP) 110(12), A787-792, (2002); Simcox et al, Pesticides in Household Dust and Soil: Exposure Pathways for Children of Agricultural Families, EHP 103(12), 1126-1134, (1995 Dansereau et al, Poisons on the Wind: Community Air Monitoring for Chlorpyrifos in the Yakima Valley, < (2006); Fenske et al, Organophosphorus Pesticide Air Monitoring Project Final Report, < (2009):
[xi]Furlong, CE, et al.. Status of Farmworker Mothers and Children as a Predictor of Organophosphate Sensitivity. Pharmacogenetics and Genomics, Vol 16 No 3: 183-190 (2006); Huen K, et al. Developmental Changes in Enzyme Activity in Young Children and Effects of Polymorphisms. Environ Health Perspect, 117:1632-1638. (2009)
[xii] Perera FP, et al.. Effects of Transplacental Exposure to Environmental Pollutants on Birth Outcomes in a Multiethnic Population, EHP, 111:201-205 (2003); Berkowitz et al.. In Utero Pesticide exposure, Maternal Paraoxonase Activity, and Head Circumference, EHP, 112:388-391 (2004); Rauh VA, et al.. Impact of Prenatal Chlorpyrifos Exposure on Neurodevelopment in the First 3 Years of Life Among Inner-City Children. Pediatrics, 118:e1845-e1859 (2006)
[xiii] Dansereau et al, Poisons on the Wind: Community Air Monitoring for Chlorpyrifos in the Yakima Valley, (2006); Fenske et al, Organophosphorus Pesticide Air Monitoring Project Final Report, (2009):
[xiv] Richard Knox, Mothers Pesticide Exposure Linked to Kids’ IQs, All Things Considered, National Public Radio, April 21,2011
[xv]EPA, Chlorpyrifos Facts <
[xvi] National Agricultural Statistics Service, Agricultural Chemical Use Database
<
[xvii] Chensheng LC, et al. Dietary Intake and Its Contribution to Longitudinal Organophosphorus Pesticide Exposure in Urban/Suburban Children. Environ Health Perspect 116: 537-542. (2008)
Respectfully,
Brian Brotman
Director
Farmworker Health and Safety Institute
P.O. Box 510, 4 South Delsea Drive
Glassboro, NJ 08028
(856) 881 2507
Robina Suwol
Executive Director
California Safe Schools
Los Angeles, California
(818) 785 5515
Margaret Reeves, PH.D.
Senior Scientist
Pesticide Action Network North America
49 Powell St., Suite 500
San Fransisco, CA 94102
(415) 981-1771
Aimee Code, M.S.
Environmental Health Associate
Northwest Center for Alternatives to Pesticides
P.O. Box 1393, Eugene Oregon 97440-1393
(541) 344-5044 ex.27
Lewis Papenfuse
Executive Director
Farmworker Legal Services of NY, Inc.
1187 Culver Road
Rochester, NY 14609-5448
(585) 269 9639
Jeannie Economos
Pesticide Safety and Environmental Health Project Coordinator
Farmworker Association of Florida
1264 Apopka Boulevard
Apopka, Florida 32703
(407) 886 5151
Nelson Carrasquillo
Executive Director
El Comité de Apoya a Los Trabajadores Agrícolas (The Farmworker Support Committee)
4 South Delsea Drive
Glassboro, New Jersey 08028
(856) 881 2507
Virginia Ruiz
Senior Attorney
Farmworker Justice
1126 16th Street NW, Suite 270
Washington, DC 20036
(202) 293 5420
Margarita Romo
Executive Director
Farmworker Self Help
37240 Calle De Milagros
Dade City, Florida 33523
(352) 567 1432
John C. Philo
Legal Director
Maurice and Jane Sugar Law Center for Economic and Social Justice
4605 Cass Ave.
Detroit, Michigan 48201
(313) 993 4505
Virginia Nesmith
Executive Director
National Farm Worker Ministry
438 North Skinker Boulevard
St. Louis, Missouri 63130
(314) 726 6470
Denise Diaz
Director
Central Florida Jobs with Justice
231 Colonial Drive, Suite 150
Orlando, Florida 32801
(407) 849 1799
Anne Katten
Pesticide and Work Safety Project Director
California Rural Legal Assistance Foundation
2210 K Street, Suite 201
Sacramento, California 95810
(916) 446 7904
Mitzi Shpak
Executive Director
Action Now
2062 Lewis Avenue
Altadena, California 91001
Sarah Aird and Tracey Brieger
Co-Directors
Californians for Pesticide Reform
49 Powell St., Suite 530
San Francisco, California 94102
(415) 981 3939
Melinda Wiggins
Executive Director
Student Action with Farmworkers
1317 W. Pettigrew Street
Durham, North Carolina 27705
(919) 660 2652
Alice Freund
Industrial Hygienist
Mt. Sinai Irving J. Selikoff Center for Occupational and Environmental Medicine
345 East 102nd St.
New York, New York, 10029
(212) 241 9054
Marty Mesh
Executive Director
Florida Organic Growers
PO 12311
Gainesville, Florida 32604
(352) 377 6345
Karen Otto, Program Administrator
Dr. Rathin Vora, Medical Director
Finger Lakes Occupational Health Services
University of Rochester
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Rochester, New York 14618
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Rev. Stephen Copley
Chairman
Arkansas Committee on Occupational Safety and Health
P.O. Box 2441
Little Rock, Arkansas 72203
(501) 626 9220
Arthur N. Read
Executive Director
Friends of Farmworkers, Inc.
42 South 15th St., Suite 605
Philadelphia, Pennsylvania 19102-2205
(212) 733 0878
Dean Hubbard and Polly Halfkenny
Co-Chairs
Labor and Employment Committee of the National Lawyers Guild
55 Harrison St., #400
Oakland, CA 94607
(203) 216 2262
(347) 453 5208
Justin Feldman MPH, MSW
Worker Health and Safety Advocate
Public Citizen
215 Pennsylvania Avenue, SE
Washington, DC 20003
(202) 454 5151
Arlene Blum, PHD
Executive Director
Green Science Policy Institute
PO Box 5455
Berkeley, CA 94705
Elizabeth Crowe
Director
Kentucky Environmental Foundation
PO Box 467
Berea, Kentucky 40403
(869) 986 08068
Linda A. Cocchiarella, MD, MSc, CAc
Medical Director
The Long Island Occupational and Environmental Health Center
1741-B North Ocean Avenue
Medford, New York, 11763
(631) 289 1405
Barbara Rahke
Director
Philadelphia Area Project on Occupational Health and Safety
3001 Walnut Street, 5th Floor
Philadelphia, Pennsylvania 19104
(215) 386 7000
Beth Rosenberg, ScD, MPH
Assistant Professor
Department of Public Health and Community Medicine
Tufts University School of Medicine
136 Harrison Avenue
Boston, Massachussets 02111
(617) 636 6651
Erin Switalkski
Executive Director
Women’s Voices for the Earth
114 W. Pine Street, PO Box 8743
Missoula, Montana 59807
(406) 543 3747
Rick Hind
Legislative Director
Greenpeace
702 H Street, NW #300
Washington, DC 20001
(202) 319 2445
Michael C. Fitts
Executive Director
Connecticut Coalition on Occupational Safety and Health
683 North Mountain Road
Newington, Connecticut 06111
(860) 953 2674
Pamela K. Miller
Executive Director
Alaska Community Action on Toxics
505 West Northern Lights Boulevard, Suite 205
Anchorage, Alaska 99503
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Judith Robinson
Associate Director
Environmental Health Fund
41 Oakview Terrace
Jamaica Plain, Boston Massachusetts 02130
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Rachel Lincoln Sarnoff
Executive Director/CEO
Healthy Child, Healthy World
12300 Wilshire Boulevard #320
Los Angeles, California 90025
(310) 820 2030 x.112
Lynn Thorp
National Campaigns Coordinator
Clean Water Action
1010 Vermont Ave NW
4th Floor
Washington, DC 20005
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Reid Maki
Director of Social Responsibility and Fair Labor Standards, Child Labor Coalition
National Consumers League
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Kathleen A. Curtis, LPN
Executive Director
Clean and Healthy New York
62 Grand Street
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518-708-3922
Jim Harkness
President
Institute for Agriculture and Trade Policy
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Minneapolis, Minnesota 55404
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Lin Kaatz Chary, PhD, MPH
Director
Indiana Toxics Action
7726 Locust Avenue
Gary, Indiana 46403
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Peter Dooley MS, CIH, CSP
Director
LaborSafe Health and Safety Consulting
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Dexter, Michigan 48130
Joann Lo
Executive Director
Food Chain Workers Alliance
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Los Angeles, California 90014
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Judy Gearhart
Executive Director
International Labor Rights Forum
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Washington, DC 20006
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Sue Phelan
Director
GreenCAPE
P.O. Box 631
West Barnstable, Massachusetts 02668
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Barbara Gottlieb
Director, Environment and Health
Physicians for Social Responsibility
1875 Connecticut Ave. NW, Suite 1012
Washington, DC 20009
(202) 587 5225
Cecil Corbin-Mark
Deputy Director
WE ACT for Environmental Justice
1854 Amsterdam Avenue
New York, New York 10031
(212) 961 1000 x.303
Juan Parras
Director
Texas Environmental Justice Advocacy Services
6733 Harrisburg
Houston, Texas 77011
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Kerstin Lindgren
Executive Director
Domestic Fair Trade Association
PO Box 300190
Boston, Massachusetts 02130
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Robynn Shrader
CEO
National Cooperative Grocers Association
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Iowa City, Iowa 52240
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Monique Harden & Nathalie Walker
Co-Directors, Attorneys
Advocates for Environmental Human Rights
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New Orleans, Louisiana 70130
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Rosalinda Guillen
Executive Director
Community to Community Development
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Bellingham, Washington 98233
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Ernesto Velez Bustos
Director
Centro Campesino, Inc
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Owatonna, Minnesota 55060
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