(Beyond Pesticides, April 17, 2008) In what it calls the most important article it has ever published, Golf Digest in its May 2008 issue (pp 196-232) publishes an article, How Green is Golf?, which asks the hard questions about the environmental impact of golf in a series of in-depth interviews, including a builder, golf course superintendent, regulator and environmentalist. The article spans a range of opinions on water usage, pesticide contamination, and management practices, with general agreement that golfer expectations and management practices must move and are moving in an environmental direction, citing important ways in which attitudes and understanding must change. Despite the documented problems with pesticides, the head of EPA’s pesticide program, in what is described as a “rebuttal” to criticism of pesticides and the pesticide registration process that are highlighted, responds without addressing key specifics identified in the article and preferring to extol the virtues of the EPA’s pesticide program.

The article says in its introduction, “As water becomes scarcer, as organic management practices increase, as environmentalism and environmental legislation start to bite more than they have, as the economy struggles, and as we come to appreciate the aesthetics of golf courses in all their many natural, beautiful hues, the way the game looks will change. And the way it plays will change too, with firmer and faster turf demanding a return to shotmaking, creativity, the bump-and-run. It’s starring to happen already: The hot courses are not dutiful apostles of Augusta; they are unique, wild and woolly-looking layouts like Bandon Dunes, Sand Hills, Chambers Bay. Americans increasingly love to visit the rugged natural links of the British isles, where the game began.”

In the piece, Jay Feldman, executive director of Beyond Pesticides, points out the hazards of pesticides to human health and the environment and the high degree of inadequate health and safety data, indicting EPA’s cumulative risk assessment process, which specifically permits the continued use of the potent nerve poison chlorpyrifos (trade name Dursban) on golf courses (after banning its residential uses in 2000) with the assumption that young children do not play golf. Mr. Feldman urges golfers to play a more active role in developing guidelines and approaches that support golf course superintendents’ strategies to avoid toxic chemical use. He criticized the Golf Course Superintendents Association of America (GCSAA) for walking lock step with the chemical industry which does not represent the interests of the golfers, superintendents or the environment. GCSAA, given an opportunity to respond in the article says, “These [chemical companies] provide funds that help enable us to deliver programs and services to our members and the golf industry. Many of these programs are focused on environmental management. It behooves us to work cooperatively with those manufacturers so that we can gather and distribute reliable and accurate information to our members.”

EPA’s “rebuttal” by Debra Edwards, Ph.D., director of the Office of Pesticide Programs, does not dispute most of the specifics outlined in the Feldman interview. Instead, she uses her space on the Golf Digest website to offer a boilerplate characterization of the pesticide registration program. “[E]PA bases its decisions to register pesticides for use in the United States on scientific data showing that the pesticides meet applicable safety standards to protect human health and the environment when used as directed on product labeling,” Dr. Edwards says. She refers to “rigorous risk assessment” and “uncertainty factors” without addressing the deficiency of false assumptions, such as children not playing golf, and lack of attention to synergistic effects and mixtures. Without admitting that the agency is years behind a statutory schedule to fully test pesticides for endocrine disruption, she says “[W]e have now developed and will begin requiring new studies to help us understand whether endocrine disruption is the mechanism causing the effects,” but does not say when and how long it will take. In her rebuttal, Dr. Edwards prefers to focus on the number of completed reevaluations of existing pesticide food tolerances (9,721 over the past 12 years) rather than the quality or documented deficiencies in those reviews. Dr. Edwards cites the agency’s support of integrated pest management (with undefined toxic pesticide use) and reduced risk pesticides, without ever questioning the real need for toxic chemicals or advancing defined organic management systems not reliant on toxic pesticides.

On children and golf course exposure, Dr. Edwards appears to dodge the agency’s failure to fully address young children’s exposure to chlorpyrifos on golf courses, by ignoring the original 2000 decision that dismissed all children’s exposure and the more recent 2006 analysis that ignores children six and under. Dr. Edwards writes, “[W]e estimated the potential exposure and risks received not only by adults but also by both children aged 7-12 and teenagers in the chlorpyrifos risk assessment. The assessment of the use of chlorpyrifos on golf courses shows that this use met our rigorous safety standard.” However, first, as noted in EPA’s “Provisions of the June 2000 Memorandum of Agreement,” the agency exempted golf courses from the chlorpyrifos phase out with its decision: “Outdoor areas in which children will not be exposed [to chlorpyrifos], including only: golf course turf. . . “ Then, in its Memorandum entitled Finalization of Interim Reregistration Eligibility Decision (IREDs) and Interim Tolerance Reassessment and Risk Management Decision (TREDs) for the Organophosphate Pesticides over six years later on July 31, 2006 (authored by Dr. Edwards), EPA narrowed its definition of children, deciding it was not necessary to evaluate children six and under. (p.41) Junior golf can certainly begin at age 5, or before, exposing young children to a hazard that EPA assumes does not need to be evaluated. Children are especially vulnerable to chlorpyrifos and chemical exposure and suffer their greatest risk of adverse effect during this period of life.

Some say that the debate with EPA is becoming increasingly irrelevant as the market moves ahead to address key issues of environmental health. This has happened in the food and agriculture sector where organic food has grown to a $20 billion industry. The majority of non-golfers (66%), according to a 2007 Golf Digest survey, understands that pesticides used on golf courses can be a health hazard. The number of golfers who understand this (40%) has doubled since Golf Digest conducted a similar survey in 1994. A majority, or 64%, of golfers is willing to “play golf under less manicured conditions to minimize the use of pesticides on the course.” An even greater majority, 85%, is willing to “sacrifice some level of golf course landscape “perfection” to save water/prevent groundwater pollution.” The growing number of concerned golfers and the communities surrounding golf courses are having increasing influence over golf course practices. Jeff Carlson, golf course superintendent at the Vineyard Golf Club on Martha’s Vineyard, MA, interviewed in the article, manages an organic course with a focus on cultural practices and describes a number of approaches that he uses to manage insects, weeds and fungus, as well as the importance of support from the club. Mr. Carlson says that it is important that he is “. . .working with our members and explaining this idea of great playability versus visual perfection. We take the focus away from having every piece of fairway and rough perfectly green. The members have to be on board, or the superintendent wouldn’t last too long.” With a background in using chemical-intensive practices, Mr. Carlson says, “I am just so surprised that so much of our golf course is unaffected by not using pesticides. To see a course without any at all is something I’m really proud of.”

(Beyond Pesticides, April 16, 2008) The California Department of Food and Agriculture (CDFA) is warning that if pheromone spraying in the San Francisco Bay area is postponed this summer, more conventional insecticides could be used in the future to manage a larger-scale light brown apple moth (LBAM) infestation. The related legal brief was released Monday in response to a lawsuit that demands an environmental review before the pheromone, CheckMate, is sprayed this summer. A number of cities and counties have taken a stand against the spray, including Santa Cruz county’s lawsuit, the hearing for which is coming up on April 24.

CDFA is resisting the counties’ attempts to delay their LBAM action plan. “The risk of greater conventional pesticide is out there,” said CDFA spokesman Steve Lyle. According to the brief, the pesticide to be used would be bacillus thuringiensus (Bt), which is commonly used in other areas of the country to fight insects like the gypsy moth. One concern of local researchers is the area’s populations of endangered and threatened moths and butterflies, which would be further threatened by a non-selective insecticide.

Santa Cruz Councilman Tony Madrigal dismissed the brief as employing scare tactics. “They’re proposing a choice to the people between bad and worse,” he said.

In addition, the state has gone on the offensive against injury reports from the first round of pheromone spraying, which occurred last fall. The Office of Environmental Health Hazard Assessment, Department of Pesticide Regulation, and California Department of Public Health released a report last week that argues a lack of evidence showing reported illnesses were caused by the spraying. After analyzing a total of 463 reports of human symptoms after the spraying, most of which included respiratory symptoms, the report concluded, “It is not possible to determine whether or not there is a link between any of the reported symptoms and the aerial spraying.” Among several shortcomings found in the data, the report argued, “the reported symptoms are nonspecific and, and are quite common among the general population . . . Given the range of causes for these symptoms and the large number of individuals expected to experience such symptoms at any given time, the symptoms in the 463 reports cannot be clearly attributed to any specific cause.”

To improve future reporting, the three agencies are designing a streamlined program to collect illness reports, including providing training to physicians on how to identify pesticide-related symptoms. The report includes full recommendations to help prevent any “unexpected health events” in conjunction with future LBAM spraying.

State Senator Carole Migden released a statement following the report. She said, “OEHHA says that it was unable to confirm a link between spraying and adverse health effects because most health complaints did not contain enough information to determine the cause of symptoms. Clearly, people should refrain from assuming that this means that no link exists. What residents must understand is that the spraying plan for the Bay Area will be much longer in duration than last fall’s and that no long-term studies have been done on the health affects [sic] of the spray that will be used – a spray that encapsulates the pesticide in tiny plastic spheres that people will inhale. How can that possibly be good for us?”

Sources: The Mercury News, eFluxMedia, San Francisco Bay Guardian

(Beyond Pesticides, April 15, 2008) Thanks to the organizing efforts of the local Environmental Action Task Force, the town of Greenwich, CT has banned the use of pesticides on all of its athletic fields. The first application of the year, which was set for April 14, 2008, was cancelled after the Board of Selectmen passed a resolution mandating the ban.

“It’s very exciting,” Selectman Lin Lavery told Greenwich Time newspaper. “It shows the town’s commitment to being a leader on environmental issues.”

According to the newspaper, the Environmental Action Task Force proposed the resolution in response to a state law banning the use of pesticides on all elementary and middle school grounds, that goes into effect next year. But the task force took the mandate a step further, banning pesticides on all town athletic fields and instituting it a year early.

It seemed logical to move forward with a ban as quickly as possible once it was determined that these pesticides were toxic and potentially harmful to children, Lavery told Greenwich Time.

Pesticides, such as Barricade- containing the active ingredient prodiamine, which is used on town fields, is a possible human carcinogen and suspected endocrine disruptor. Michael Franco, M.D., a local pulmonologist who is chairman of the task force’s pesticides sub-committee is concerned about the pesticide’s carcinogenicity, developmental toxicity, links to behavioral problems and persistence in the soil.

A spokesperson for the Greenwich Parks Department called the move a “noble” thing to do, but believes an organic approach will be more labor intensive. However experience shows, organic management of playing fields can be cheaper, does not require “rest” time, as once believed, and are safer for the athletes.

For more information on organic athletic fields, see “Pesticides and Playing Fields,” published in the Summer 2006 issue of Pesticides and You, and Beyond Pesticides’ Lawns and Landscapes project page.

(Beyond Pesticides, April 14, 2008) After almost a year and a half of debate on genetically engineered (GE) crops, the Maine Legislature passed a bill last week to protect farmers from genetic trespass. According to Protect Maine Farmers, the bill prevents lawsuits for patent infringement against farmers who unintentionally end up with GE material in their crops; ensures lawsuits that do occur will be held in the state of Maine; and, directs the Department of Agriculture, Food and Rural Resources to develop and implement specific practices, or Best Management Practices, for growing GE crops. One component of the bill that was supported by many Maine farmers but failed would have required all businesses selling GE seeds in Maine to report their annual sales data to the Maine Commissioner of Agriculture.

“Maine’s farmers now have some substantial assurance that if they save seed that has been contaminated by [GE] varieties, they are not at risk for a lawsuit,” states Logan Perkins, the lead organizer for Protect Maine Farmers. “Hopefully, the development of these Best Management Practices will give farmers the information they need to make good decisions about how to protect themselves, their livelihoods and their neighbors when using [GE] crops.” North Dakota, South Dakota and Indiana have already passed similar legislation.

The Bangor Daily News states that “In the 10 years that GE crops have been grown in Maine, there have been non GE-related lawsuits [in the state].” But, there have been more than 90 GE-based lawsuits filed against 147 farmers in 25 states, according to the Center for Food Safety.

The passage of the bill comes just weeks after the town of Montville passed an ordinance that makes it “unlawful for a person, partnership, firm, or organization of any kind to produce genetically modified organisms in the Town of Montville for a period of ten years.” For those residents that are currently growing GE crops, they have two years to phase them out. This is the first of such ordinances to be passed outside of California. In 2005, town officials in Kennebunk and Kennebunkport prevented voters from on a similar ban, stating that the ordinance conflicts with Maine’s right-to-farm law. Brooklin and Liberty passed non-binding ordinances establishing their towns as “GE Free Zones.”

More and more GE crops are being grown around the world. The International Service for the Acquisition of Agri-biotech Applications reports that biotech crops grew by 30 million acres, or 12 percent, in 2007 for a total of 282.4 million acres worldwide. Also astounding is the fact that 2 million more farmers planted biotech crops last year to total 12 million farmers globally. Notably, 9 out of 10, or 11 million of these farmers, are resource-poor farmers. In fact, the number of developing countries (12) planting biotech crops surpassed the number of industrialized countries (11), and the growth rate in the developing world was three times that of industrialized nations (21 percent compared to 6 percent.)

An organic dairy farmer thinks that legislation needs to go a step farther, “It’s good to know that I will not be sued for saving my seeds, but I would like to see a way to make the companies take responsibility for the losses this technology can cause when it contaminates my crops.”

There are many problems with GE crops as they are known to lead to insect resistance, create superweeds, contaminate other plants from the same species through pollen drift, harm human health, wildlife and other non-target organisms, contaminate soil, contain hidden allergens, negate religious and moral considerations, lead to antibiotic resistance, and unreasonable business contracts with farmers.

For more information on GM crops, visit Beyond Pesticides program page and Daily News archive.

(Beyond Pesticides, April 11, 2008) The United States House of Representatives’ Committee on Oversight and Government Reform released a report last month on the Food and Drug Administration (FDA) failures that lead to the E.coli outbreak in spinach, which peaked in September 2006. When E.coli was discovered in package spinach, critics of organic agriculture and parts of the media were quick to target organic spinach as the source (starting something of a debunking “war”). NBC’s Today Show erroneously blamed organic agriculture (to which Beyond Pesticides responded here). However, the Congressional report lists a variety of failures on the part of FDA to ensure safe handling and packaging of spinach, citing a limited number of inspections and failure to enforce adequate sanitation and processing practices.

The major faults found by the committee range from frequency and thorughness of inspections, to lack of enforcement, including:

• Packaged fresh spinach facilities were inspected only once every 2.4 years, less than half of FDA’s stated goals.
• FDA observed objectionable conditions during 47% of the packaged fresh spinach inspections [60% of which pertained to facility sanitation].
• Despite observing objectionable conditions in packaged fresh spinach facilities, FDA took no meaningful enforcement action.
• FDA overlooked repeated violations.
• FDA found repeated problems at multiple facilities operated by the firm implicated in the 2006 E.coli outbreak but took no enforcement actions.
• In eight cases, packaged fresh spinach facilities denied FDA inspectors access to records or other relevant material.
• The scope of FDA inspections appears too narrow to capture the sources of an E.coli outbreak.

In 2006, it was widely reported that the E.coli stemmed from organic spinach, which was fertilized with manure, as opposed to synthetic chemical fertilizers. The committee (and, by now, others) has pointed out “that the outbreak probably did not originate in the facilities that are inspected by FDA. Instead, the problem began outside the plants and most likely was due to contamination of the water outside of the plant by cattle feces, pig feces, or river water. FDA does not routinely inspect the fields except in outbreak investigations.”

In addition to this probability, Natural Selection Foods LLC was found to have multiple violations, “including indications that the facility failed to take effective measures to prevent extraneous materials from entering the food; failed to clean and maintain processing equipment; failed to ensure that condensation did not contaminate the product; and failed to review and verify plant records pertaining to sanitation.” In spite of these, “FDA never initiated any enforcement action against Natural Selection Foods,” which would go in, in 2006, to be identified as the source of the E.coli outbreak.

Natural Selection was quick to state that, “We continually search for new ways to improve food safety and note all observations provided by FDA inspectors during their audits.” However, FDA’s advisory committee, the Science Board, concluded, “We can state unequivocally that the system cannot be fixed within available resources.” Watchdogging government oversight will likely remain relevant in the foreseeable future. To track Beyond Pesticides’ alerts on current issues, visit our program page, or learn more defending about organic integrity here.

Sources: Washington Post, Los Angeles Times

(Beyond Pesticides, April 10, 2008) Common frogs that live in suburban areas are more likely than their rural counterparts to develop reproductive abnormalities, according to David Skelly, PhD, professor of ecology at the Yale School of Forestry and Environmental Studies. This phenomenon becomes a serious concern as the frog’s mating season begins, leaving researchers to wonder: will frogs be clear on their role in the annual ritual?

Research by Dr. Skelly, soon to be published, focuses on the common green frog, Rana clamitans, within the Connecticut River Valley. A total of 233 frogs were collected from various ponds and landscapes with the river valley and among them 13 percent have abnormalities occurring in their reproductive organs. In urban areas, 18 percent of the collected frogs are intersex, and in suburban areas 21 percent. Frogs collected from agricultural areas have the lowest rate of reproductive problems with just 7 percent classified as intersex. According to Dr. Skelly, the more suburban the land cover, the more likely the abnormalities.

“This is the first evidence that I think anyone has provided that agriculture is doing anything but pushing those rates higher,” remarked Dr. Skelly of the intersex phenomena.

In an attempt to explain the higher prevalence of intersex frogs in urban and suburban areas, the study notes that many suburban areas use septic systems that may be leaching chemicals or pharmaceuticals into streams or ponds. These areas also have higher rates of using herbicides and insecticides for lawn care and garden treatments.

Intersex frogs, also called hermaphroditic frogs, refer to frogs, mostly males observed to be producing eggs in their testes. There are many studies documenting this phenomenon, which is also blamed for the decline in many frog populations. Work by Tyrone Hayes, PhD, University of California, Berkeley, has linked the agricultural herbicide atrazine to reproductive disorders in frogs. A U.S. Geological Survey (USGS), also suggests a strong link between the abnormalities and agriculture. However, this study is the first to document the relationship with a non-agricultural setting.

Atrazine, which is classified as an endocrine disruptor, interrupts the workings of natural hormones. However, many household products, such as antibacterials and antimicrobials like triclosan and its cousin triclocarban, which are found in detergents, bar soaps, and other personal care products, have been shown to produce the same effects when released into streams and ponds. A recent study found that these antibacterials enhance endocrine disruption and have also been found to have the highest user rates among the wealthy. These antibacterials and other estrogenic chemicals are detected at high concentrations in the effluent discharged in the areas where the abnormalities are found. Lawn care chemicals like 2,4-D, permethrin, and glyphosate (Round-up) also cause damaging endocrine effects, even though the U.S. EPA does not currently evaluate or consider the endocrine disrupting properties of pesticides during registration or re-registration. These chemicals run off from treated lawn surfaces to contaminate nearby streams.

“Looking upstream and downstream from wastewater-treatment plants, we see there’s obviously been an impact by some of the chemicals discharged,” said Vicki S. Blazer, PhD, fish biologist at USGS.

Recent news reports have brought attention to antibacterials and pharmaceuticals in drinking water. While these chemicals pose serious health concerns to human populations, the harm posed to wildlife species being documented at alarming rates.

Source: New York Times

(Beyond Pesticides, April 9, 2008) You have an opportunity to ask your U.S. Representative to stand up for the protection of health and the environment by joining with his/her colleagues in the U.S. Congress on a letter to stop a pro-pesticide amendment in the Farm Bill, which is still under consideration in a House-Senate Agriculture conference committee. The provision, and other substitute language now floating around, stops the U.S. Department of Agriculture from curtailing hazardous pesticide use through its conservation programs, either by targeting specific contaminants that are poisoning water or hurting wildlife, or facilitating a transition to organic practices. (See March 27, 2008 Daily News) Attached below is the “Dear Colleague” letter that your Rep. received from Reps. Rush Holt (D-NJ) and Donald Payne (D-NJ) and the letter s/he is being asked to sign that will go to the Farm Bill conferees. To sign on, tell your Rep. (get contact info here) to email Rep. Holt’s aide Michele Mulder [email protected] or call her at (609) 750-9365.

“Dear Colleague” Letter to Your Member of Congress:

Don’t Turn Back the Clock on Safer, Less-Toxic, More-Environmentally Friendly Pesticides!

Dear Colleague:

I am writing to ask you to join me on a letter to the leadership of the House and Senate Agricultural Committees, urging them to support the Senate Agricultural Committees action in not including a provision passed in the House that would jeopardize the ability of conservation managers to choose the safest, least toxic, and most environmentally friendly pesticides in carrying out activities under integrated pest management and other Farm Bill programs. The provision, Section 11305 of the House-passed Farm Bill, was entitled No Discrimination Against Use of Registered Pesticide Products or Classes of Pesticide Products, and it read:

“In establishing priorities and evaluation criteria for the approval of plans, contracts, and agreements under title II, the Secretary of Agriculture shall not discriminate against the use of specific registered pesticide products or classes of pesticide products.”

The provision, inserted at the behest of pesticide manufacturers, was met with outrage by more than 50 environmental, conservation, heath and nutrition, organic, wildlife, organic and other public interest groups. Numerous existing Farm Bill programs, encourage as they should — the use of non-toxic or less-toxic methods of pest control. The foregoing language could be interpreted to find such facilitation of safer pest control methods discriminatory as against the use of conventional pesticides, and could thus prohibit efforts to use such safer methods. This language drives Farm Bill policy on the issue of pesticide usage and environmental conservation in precisely the opposite direction from where it should be going. In a letter to the Natural Resources Defense Council dated February 8, 2008, the Environmental Protection Agency (EPA) agreed with the concerns expressed by conservation groups and stated that the EPA would be concerned if language in the House passed version of the Farm Bill could be interpreted in any way to inhibit [pesticide risk reduction].

Attached is a letter to the leadership of the House and Senate Agriculture Committees, urging them to follow the lead of the Senate Agriculture Committee and remove Section 11305 from the final Farm Bill. Please join me in co-signing this important letter. If you have any further questions or would like to co-sign the letter, please contact Michelle Mulder of my staff at (609) 750-9365 or [email protected].
Sincerely,

RUSH HOLT                               DONALD PAYNE
Member of Congress             Member of Congress

———————————————

Letter to the Farm Bill Conferees

The Honorable Tom Harkin
Chairman
Senate Committee on Agriculture,
Nutrition and Forestry
328A Senate Russell Office Building
Washington, DC 20510

The Honorable Saxby Chambliss
Ranking Member
Senate Committee on Agriculture,
Nutrition and Forestry
328A Senate Russell Office Building
Washington, DC 20510

The Honorable Collin Peterson
Chairman
House Committee on Agriculture
1301 Longworth House Office Building
Washington, DC 20515

The Honorable Bob Goodlatte
Ranking Member
House Committee on Agriculture
1305 Longworth House Office Building
Washington, DC 20515

Dear Chairman Harkin, Chairman Peterson, Ranking Member Chambliss and Ranking Member Goodlatte:

We respectfully write to express our strong support for the Senate Committee on Agriculture, Nutrition & Forestry not including section 11305 of the House-passed Farm bill, entitled No Discrimination Against Use of Registered Pesticide Products or Classes of Pesticide Products, in the Senate bill. The provision read:

In establishing priorities and evaluation criteria for the approval of plans, contracts, and agreements under title II, the Secretary of Agriculture shall not discriminate against the use of specific registered pesticide products or classes of pesticide products.

We urge the Conference Committee to follow the lead of the Senate Agriculture Committee with respect to this issue, and leave that provision or similar provisions out of the final bill. Numerous existing farm bill programs, including the Environmental Quality Incentives Program (EQIP), the Conservation Security Program (CSP), the Conservation Reserve Program (CRP), the Wildlife Habitat Incentives Program (WHIP), and the Integrated Pest Management (IPM) programs operating at the state level, encourage the use of non-toxic or less-toxic methods of pest control The foregoing language was included in the House bill at the urging of pesticide manufacturers and, if allowed to remain in the final bill, would jeopardize the ability of conservation program managers to use farm bill funding to implement the most environmentally friendly pesticide options available. That is, EQIP and other programs that intentionally facilitate the deployment of non-toxic pesticides could be seen as discriminatory as against the use of conventional pesticides, and such facilitation would be prohibited under this language This language drives farm bill policy on the issue of pesticide usage and environmental conservation in precisely the opposite direction from where it should be going.

Attached are a letter from the Natural Resources Defense Council and a letter signed by more than 50 environmental, conservation, health and nutrition, wildlife, organic and other public interest groups, urging the Conferees to remove the House-passed Section 11305 from the final 2007 Farm bill.

We respectfully request the deletion of the House-passed Section 11305 from the final 2007 Farm bill.
Sincerely,

Groups supporting removal of pesticide discrimination provision:

American Association on Intellectual and Developmental Disabilities
American Bird Conservancy
Berkshire Cooperative Association
Beyond Pesticides
Bio-Logical Pest Management, Inc.
Breast Cancer Action
Californians for Alternatives to Toxics
Californians for Pesticide Reform
California Rural Legal Assistance Foundation
Carandale Farm
Carolina Farm Stewardship Association
Center for Environmental Health
Center for Food Safety
Citizens Environmental Coalition
Clean Catch
Clean Water Action/Clean Water Fund
Coast Action Group
Colorado Organic Producers Association
Community Alliance with Family Farmers
Community & Children’s Advocates Against Pesticide Poisoning
The Cornucopia Institute
Defenders of Wildlife
Environment California
Environmental Defense
Environmental Working Group
Florida Organic Growers and Consumers
Food & Water Watch
Fresno Coalition Against the Misuse of Pesticides
Fresno Metro Ministry
Gardens of Goodness LLC
Georgia Organics
Greenpeace Toxics Campaign
Heal the Bay
Healthy Child Healthy World
Humane Society International
Humane Society of the United States
IPM Institute of North America, Inc.
Learning Disabilities Association of California
Marrone Organic Innovations, Inc.
Montana Organic Producers Cooperative
Monterey Coastkeeper
New England Small Farm Institute
New York Public Interest Research Group
Northeast Organic Farming Association of New York
Northeast Organic Farming Association of Vermont
Northern Plains Sustainable Agriculture Society
Northwest Coalition for Alternatives to Pesticides
Parents for a Safer Environment
Pesticide Action Network North America Regional Center
Pesticide Education Project
Pestec, IPM Provider
Physicians for Social Responsibility, Los Angeles
The Organic Center
Organic Consumers Association
Organic Farming Research Foundation
Sierra Club
Science and Environmental Health Network
Southern Sustainable Agriculture Working Group
Sustainable Agriculture Coalition
Steven and Michele Kirsch Foundation
Toxics Information Project
Tri-Valley CAREs
Twin Oaks Dairy LLC
Union of Concerned Scientists
Veritable Vegetable, Inc.
Virginia Association for Biological Farming

Contact: Michelle Mulder, Counsel, U.S. Representative Rush Holt, 50 Washington Road, West Windsor, New Jersey 08550, 609-750-9365 (tel.), 609-750-0618 (fax).