(Beyond Pesticides, July 23, 2012) The U.S. Environmental Protection Agency’s (EPA) announcement last week of new agricultural risk mitigation measures for the neurotoxic insecticide chlorpyrifos continues to ignore farmworker health and that of their families, as well as the viability of organic farming systems in providing not only safer food, but safer working environments for farmworkers. The new measures, while a step in the right direction to protect vulnerable populations, do not go far enough to address the unreasonable risks associated with the chemical’s widespread continued use. The national pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), requires protection against “unreasonable adverse effects to man or the environment.”
In its latest decision, EPA seeks to reduce exposure to “acceptable” risk levels. In this case, the agency is seeking to reduce exposure of bystanders to spray applications. The measures include reductions in aerial application rates of the insecticide and the establishment of mandatory buffers around sensitive sites where bystanders including children are known to suffer exposure. The new mitigation practices include reducing the maximum amount of chlorpyrifos that can be applied per acre using spray applications from 6 pounds/acre to 2 pounds/acre. The new measures also include no-spray buffer zones near sensitive sites, from 10 feet up to a maximum of 100 feet. The definition of “sensitive sites” includes places children live and play, whether they are present at the time of application or not. The new use restrictions will appear on all chlorpyrifos agricultural product labels starting in late 2012. EPA’s action is a partial response to a legal petition and subsequent lawsuit filed by the Natural Resources Defense Council (NRDC) and the Pesticide Action Network of North America (PANNA) which requested that EPA revoke all remaining allowed uses for chlorpyrifos.
EPA negotiated settlement in 2000 with the principal registrant, Dow AgroSciences, allowed the continuation of all agricultural uses except tomatoes (allowable residues on apples and grapes were adjusted), as well as golf course and public health mosquito control uses. EPA argued at the time that in banning residential applications of chlorpyrifos it was adequately mitigating risks through the removal of high exposure uses to children, but its decision ignored special risks to farmworkers and especially their children. EPA argues that the Worker Protection Standards are enough for farmworkers, however, these standards are not fully protective of farmworkers during the application of toxic pesticides, and residual exposures off application site. For more information on pesticide drift, read Beyond Pesticides’ report Getting the Drift on Chemical Trespass: Pesticide drift hits homes, schools and other sensitive sites throughout communities.
Chlorpyrifos is a neurotoxic insecticide that was banned from residential applications after EPA determined that cumulative exposure resulted in serious adverse health outcomes, especially for children. Short term effects of exposure to chlorpyrifos include chest tightness, blurred vision, headaches, coughing and wheezing, weakness, nausea and vomiting, coma, seizures, and even death. Prenatal and early childhood exposure has been linked to low birth weights, developmental delays, ADHD and other health effects.
Beyond Pesticides has cited EPA’s action regarding the organophosphate chlorpyrifos as a classic failure of the risk assessment process under the Food Quality Protection Act (FQPA) —a failure that is repeated over and over again in agency chemical regulation decisions. The purpose of FQPA is to protect infants and children from pesticides, taking into account the potential for pre- and post-natal toxicity via any route of exposure, including exposures through structural and landscape uses, diet, and water. Advocates have pointed to chlorpyrifos as the poster child for why risk assessment does not work to protect the public, workers and the environment, given that safer practices, including organic practices and products are increasingly available in the marketplace.
By focusing on risk reduction strategies to come up with “acceptable,” but unnecessary, rates of illness across the population, EPA continues to underestimate the impact of the chemical’s continued widespread use in agriculture. Chlorpyrifos is a frequent water contaminant and a long range contaminant, exposing communities and contaminating pristine areas far from where it was applied. Residues in food and water continue to put public health at risk. Volatilization drift””the evaporation of the pesticide after application””is also part of the problem for chlorpyrifos, but the new restrictions do not take into account volatilization drift. EPA noted its intention to address volatilization drift when the chlorpyrifos risk assessment is finalized in 2014.
The only way to know that you are not supporting chemical intensive agriculture is to buy organically produced food. Beyond Pesticides advocates for the national conversion to organic systems planning, which moves chemicals off the market quickly and replaces them with green management practices. The effects that chemicals such as chlorpyrifos have on the natural environment, in addition to untold damage it has caused families across the U.S., is testimony to the need to adopt alternatives assessments that force chemicals off the market that can be replaced by safer or green practices. Despite agency efforts to use failed risk assessment decision making to claim that the food supply is safe and the environment protected, an informed public is driving the growth of organic production in the marketplace, choosing health, environmental protection, and precaution over risk assessment. It is a process that can be supported through purchasing decisions every day in the grocery store and advocacy that effects a conversion of land and building management in parks, schools, health care facilities, indoor and outdoor spaces, especially lawns and gardens, to nontoxic and least-toxic methods. Visit our Organic Program page to learn more and find out what you can do to support organic production.
Also see: Pesticide Action Network North America All unattributed positions and opinions in this piece are those of Beyond Pesticides.