30
Jul
EPA Recognizes Pesticide Drift Poisoning, Responds with Assessments, but Limited Action
(Beyond Pesticides, July 30, 2024) The U.S. Environmental Protection Agency (EPA) announced on July 15 what it described as a new process for evaluating the risks of spray drift—the migration of pesticides from their target area to off-site zones. According to a statement by EPA Chemical Safety and Pollution Prevention Assistant Administrator Michal Freedhoff, PhD in an Oregon Public Broadcasting story, the agency took the step so that “people don’t have to wait years for the protections they deserve and need.” However, EPA states, “The Agency is not making any changes to its chemical-specific methodology outlined in [its] 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” EPA has said, “Spray drift is governed by a variety of factors which govern how much of the pesticide application deposits on surfaces where contact with residues can eventually lead to indirect exposures (e.g., children playing on lawns that are next to treated fields and where residues have deposited).” The new policy will add spray drift evaluation to occasions when the agency receives an application for a new pesticide and when a registered pesticide is intended for a new use or applied to a new crop. The change will also be integrated into the implementation of the Federal Insecticide, Fungicide, and Rodenticide Act and EPA’s obligation to fold pesticide harms into its regulations under the Endangered Species Act.
Pesticides are applied as sprays from aircraft, spraying machines traversing fields, and by hand by people using backpacks. Details like nozzle size also affect the droplet size, which in turn affects how far it will travel. High pressure applications with small droplet size, such as those used on fruit tree canopies, tend to produce the highest number of illnesses from spray drift, followed by aerial applications. Pesticides are sprayed on crop fields, forests, park and school grounds, golf courses and roadway margins as well as private properties. The reason that spray drift is a problem is that it makes people, animals, and plants sick, especially noticeable in acute exposures at the time of spraying.
The economics of spray drift are such that one would think the pesticide industry—or at least farmers—would be desperately seeking for a solution to the problem. And in fact, it is clear that the pesticide industry is deeply concerned about spray drift, and its messaging is almost entirely devoted to advising farmers on how to reduce it. CropLife International, for example—the industry’s primary mouthpiece—admits that “in the long run, the consequences of repeated spray drift can mean that growers lose access to key weed control tools” through regulation and that spray drift can mean the intended recipient field is missed, neighbors’ crops may be damaged, and there may “even [be] a health hazard for humans and animals.” The solution, CropLife says, is “operator knowledge.” This is yet another case of placing the burden on the worker lowest on the totem pole when the entire premise of agricultural pesticides is a macro-scale problem.
Pesticides cannot be precisely applied only to existing target plants. Air is a fluid, which means that anything in the air can potentially go anywhere. According to a 2011 French study, up to 86.6 percent of sprayed fungicides can miss the target crop entirely. Even with soil-applied glyphosate, the study found that less than half the amount applied stayed on the plants, and much of it accumulated in the bodies of test snails. EPA’s July announcement took pains to point out that the rule change won’t require more data or fees from the “regulated community” because these ““could disincentivize registrants from introducing new tools for growers and could lead to unclear labels and confusion at the user level.”
Dicamba is perhaps the most notorious culprit in spray drift damage to humans and plants. Beyond Pesticides has covered dicamba’s multiple harms repeatedly (for example here and here). Dicamba’s drift-prone behavior is becoming even more severe because of climate change. The worst form for pesticide application is as a gas, or fumigant, and dicamba exhibits an increasing tendency to vaporize as temperature increases. Advice for spraying pesticides already includes strong emphasis on monitoring specific wind conditions such as speed and direction, avoiding atmospheric inversions, and applying when non-applicators are not present. A stricture should be added against applying dicamba when the air temperature is above 85 degrees Fahrenheit, the point where dicamba turns from a liquid to a gas, known as volatilization. As we are currently undergoing the hottest year in Earth’s recorded history, there may be very few days when dicamba could be applied without entering its gas phase. And as the Arctic melts, as Beyond Pesticides has covered, the Arctic serves as a reservoir for both banned and current-use pesticides which will be decanting from permafrost and ice into the world oceans and terrestrial regions. To compensate for climate’s exacerbation of agricultural degradation, see Regenerative Organic Agriculture and Climate Change: A Down-to-Earth Solution to Global Warming.
Where do sprayed pesticides go? Mostly to areas adjacent to the target zone. This is often next-door farms but can include schools and many other buildings, including homes, especially those of farmworkers. Along roadways pesticides travel into whatever adjoins the road and easily make their way into ditches and streams. Pesticides can continue to volatilize for long periods after application.
There is no federal requirement for sprayers to notify neighbors of the date of spraying, although there are patchy state notice requirements, most of which are voluntary and require registration by people to receive notices ahead of time. Nor is there any requirement to notify farmworkers from neighboring farms, who suffer by far the most egregious exposure to these wasted pesticides. A 2017 report on human exposure to spray drift by the Northwest Center for Alternatives to Pesticides (NCAP) and Columbia Legal Services (CLS) noted a Washington State Department of Health study showing that 56 percent of the people sickened by pesticide drift were workers on another farm; the next largest group, 28 percent, were nearby residents—in sum, 84 percent of the victims were not present on the farm applying the pesticides.
There are many routes of exposure: direct skin contact and inhalation at the time of exposure, but also contact with soil and water, consumption of water, animals and plants also exposed to pesticide spray, and contact with clothing used by the applicator, to name a few. EPA’s July announcement does not mention inhalation at all, and, regarding children, refers only to “incidental oral exposure” to 1-to-2-year-olds who play on grass and put things in their mouths. The NCAP/CLS report considered acute symptoms rather than long-term effects in the spray victims of a 2014 event, all of whom reported neurologic problems including shaking, headache, and fainting, with large majorities also experiencing nausea, vomiting, coughing, rashes, and burning eyes. Some were hospitalized. Importantly, as much as 88 percent of spray drift illnesses are not reported by victims. In a Washington Department of Health study, workers in a focus group said they did not seek medical care for pesticide exposure because they needed their wages and feared being fired, did not know that workers’ compensation would cover their health care, and believed health care workers were on their employers’ side.
Despite regulators’ and industry groups’ efforts to develop adjustments to spray applications such as controlling nozzle size and timing of application, the incidence of illness from spray drift has not declined by much. The Washington Department of Health report cited by NCAP/CLS showed that the number of people who were sickened jumped from 43 in 2012 to 129 in just two years, by 2014. This occurred even though the actual number of pesticide drift events increased only from 15 to 22 in the same two years. In New Zealand, cotton growers reported the 2022-2023 growing season as one of the worst on record for spray drift damage. “EPA has made assumptions that are not true, and ignores reality, never incorporating any real science into exposure assessments,” said Beyond Pesticides executive director Jay Feldman.
The NCAP/CLS report cites a 2004 University of Washington School of Public Health study finding “spray drift occurring despite adherence to general precautionary pesticide application guidelines.” Both EPA and industry tout the inclusion of buffer zones, but these are often far too small to be effective. EPA’s effort to incorporate pesticide policy into the Endangered Species Act includes larger buffer distances for salmon—60 to 300 feet—in Washington, Oregon and California than many buffers designed to protect off-target plants and people. A 2012 state bill to establish a half-mile buffer between applications and nearby workers failed to pass the Washington legislature. “While EPA does not incorporate a lot of buffer zones into pesticide restrictions,” Feldman said, “even buffer zones are arbitrary and do not extend nearly far enough to truly be protective. If they were to be truly protective, it would be too burdensome to farming operations because they would have to take land out of production” to provide the buffer.
All the controls, mitigations, and advice doled out by EPA and the pesticide industry are likely not effective enough to seriously reduce the problem of spray drift. EPA’s new announcement will do little to reduce the harms of pesticides in the short term. EPA even claims its new and tepid policy is “furthering protections to bystanders wherever pesticide spray drift may occur, and thereby strengthening environmental justice protections associated with the use of pesticide products.” This is a specious claim at best, since it will still take years to incorporate spray drift into EPA’s regulatory structures and essentially nothing has been done to protect bystanders and residents near sprayed fields, forests and road verges. As Feldman put it, “The true effect of drift, if calculated, would be a good argument for the organic alternative. From an economic perspective, drift is an externality that is never calculated in the true cost of chemical-intensive farming. It is simply ignored or not realistically restricted.”
In fact, both regulators and the pesticide industry rest their actions on a severe contradiction that generates a queasy sense of cognitive dissonance: Both take for granted the idea that pesticides can never go away, and therefore it is a great leap forward to incorporate probably ineffective steps into the constant parade of new pesticides coming down the pike because old pesticides become useless so rapidly through resistance among pests and their own inherent biological toxicity. It is strikingly illogical to keep doing the same thing repeatedly when it does not work except on very short timescales, and at the expense of the biosphere that is necessary to human survival. Baby steps in this case are simply deflection, denial and disregard for consequences.
Beyond Pesticides will suggest public comments through our Action of the Week at the end of this week. See Getting the Drift on Chemical Trespass.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.
Sources:
Implementing Chemical Specific Human Health Spray Drift Analysis for Pesticide Registration Action July 14, 2024
https://www.regulations.gov/document/EPA-HQ-OPP-2013-0676-0124
Human Exposure to Pesticide Drift: Washington State Report
Northwest Center for Alternatives to Pesticides and Columbia Legal Services
February 2017
https://columbialegal.org/wp-content/uploads/2018/11/PesticideReportFINALWeb.pdf
Washington State Department of Health, Learning from Listening: Results of Yakima Farmworker Focus Groups about Pesticides and Health Care (2004)
https://ntrl.ntis.gov/NTRL/dashboard/searchResults/titleDetail/PB2005100332.xhtml#
Court Strikes Down EPA’s Allowance of Weedkiller Dicamba after Scathing Inspector General Report
Beyond Pesticides, February 13, 2024
Court Strikes Down EPA’s Allowance of Weedkiller Dicamba after Scathing Inspector General Report
Call for EPA to Reject Harmful Weed Killer; Politicized Supreme Court Takes the Reins from Agencies
Beyond Pesticides, July 1, 2024
Call for EPA to Reject Harmful Weed Killer; Politicized Supreme Court Takes the Reins from Agencies
Tell EPA To Ban Drift-Prone Pesticides
https://www.beyondpesticides.org/action-of-the-week/tell-epa-to-ban-drift-prone-pesticides?contactdata=&nvep=&hmac=&emci=4035f12e-7f35-ef11-86d2-6045bdd9e096&emdi=ea000000-0000-0000-0000-000000000001&ceid=
“Legalized Poisoning of 5,500 People” Message Highlights Controversy Over Aerial Pesticide Spray in Oregon
Beyond Pesticides, September 5, 2023
“Legalized Poisoning of 5,500 People” Message Highlights Controversy Over Aerial Pesticide Spray in Oregon
Snails as indicators of pesticide drift, deposit, transfer and effects in the vineyard
Science of The Total Environment
Volume 409, Issue 20, 15 September 2011
Coline Druart, Maurice Millet, Renaud Scheifler, Olivier Delhomme, Caroline Raeppel, Annette de Vaufleury
https://www.sciencedirect.com/science/article/abs/pii/S0048969711007224?via%3Dihub
The Washington aerial spray drift study: assessment of off-target organophosphorus insecticide atmospheric movement by plant surface volatilization
Jaya Ramaprasad, Ming-Yi Tsai, Kai Elgethun, Vincent R. Hebert, Allan Felsot, Michael G. Yost, Richard A. Fenske
Atmospheric Environment
Volume 38, Issue 33, October 2004
https://www.sciencedirect.com/science/article/abs/pii/S1352231004005199
Dicamba: Past, present, and future
Bob Hartzler
Iowa State University
2017 Integrated Crop Management Conference
https://crops.extension.iastate.edu/blog/bob-hartzler/dicamba-past-present-and-future
Equipment and Application Techniques in relation to pesticide drift and residues
Wesley E. Yates and Norman B. Akesso
Report of the Fourth Agricultural Aviation Research Conference
University of California, Davis
1962
https://www.google.com/books/edition/Report_of_the_Fourth_Agricultural_Aviati/dnXDfa7bCgIC?hl=en&gbpv=1&dq=spray+drift+AND+livestock&pg=PA154&printsec=frontcover
