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Chlorpyrifos has been widely used in homes and on farms. In the home, it is used to control cockroaches, fleas, and termites; it is also used in some pet flea and tick collars. On the farm, it is used to control ticks on cattle and as a spray to control crop pests.
In a letter dated May 24 and released Thursday by Public Employees for Environmental Responsibility (PEER), the leaders of three unions -- the American Federation of Government Employees, the National Treasury Employees Union, and the Engineers and Scientists of California -- ask EPA Administrator Stephen Johnson to either adopt maximum exposure protections for these agents or take them off the market. The unions represent 9,000 scientists, risk managers and other specialists.
The union leaders write that they are "troubled by the agency's failure to consider exposure to neurotoxic pesticides by infants and children who enter fields treated with these pesticides while accompanying parents employed to perform post-application tasks.
"The children of farmworkers, living near treated fields, are also repeatedly exposed through pesticide drift onto outdoor play areas and through exposure to pesticide residues on their parents' hair, skin and clothing."
"Additionally," the union leaders write, "we are concerned that unborn fetuses may also be exposed to these neurotoxicants when pregnant women are employed to handle (mix, load, apply) these pesticides or are employed to enter treated areas to perform hand labor tasks following pesticide applications."
In their letter, the union leaders cite information from the EPA Inspector General's office that "it would be premature to conclude that there is a complete and reliable database on developmental neurotoxicity of pesticides."
Therefore, they say, "EPA's risk assessments cannot state with confidence the degree to which any exposure of a fetus, infant or child to a pesticide will or will not adversely affect their neurological development."
In the absence of "a robust body of data" the union leaders remind Johnson that the Food Quality Protection Act requires the EPA to use "an additional 10-fold safety factor in its risk assessments when setting pesticide tolerances."
The Food Quality Protection Act of 1996 amended the Federal Insecticide, Fungicide, and Rodenticide Act to require a new program of review of pesticide registrations on a 15 year cycle to ensure that over time they continue to meet statutory standards for registration. The public had an opportunity to comment on the pending pesticide re-registrations. The public comment period closed last October.
The EPA says the agency "made significant effort in the reregistration and tolerance reassessment programs to ensure that data requirements were identified and satisfied with appropriate data," adding that "pesticide databases now meet or exceed the standard established in 1984." Still the agency acknowleges that it "will identify data gaps for many pesticides in the registration review program."
Some commenters on the Advance Notice of Proposed Rulemaking issued in 2000 that the EPA identifies as "primarily from pesticide manufacturers or other persons with commercial interest in the sale or use of pesticides," want to "limit public participation in various ways," the EPA states in its Federal Register Notice about the pesticide registration review.
"Other commenters acknowledged the value of public participation but cautioned that it could slow down decision-making," the EPA said.
In their letter, the union leaders warn EPA Administrator Johnson about political pressure from industry to allow high tolerances of these pesticides.
"Our colleagues in the Pesticide Program feel besieged by political pressure exerted by Agency officials perceived to be too closely aligned with the pesticide industry and former EPA officials now representing the pesticide and agricultural community," the union leaders write.
"Equally alarming," they write, "is the belief among managers in the Pesticide and Toxics Programs that regulatory decisions should only be made after reaching full consensus with the regulated pesticide and chemicals industry."
"In the rush to meet the August 2006 statutory deadline, many steps in the risk assessment and risk management process are being abbreviated or eliminated in violation of the principles of scientific integrity and objectivity by which we as public servants are bound," the union leaders warn in their letter to Johnson.
The union leaders are asking the EPA to issue an interim decision requiring maximum protections for pesticide handlers and longer re-entry intervals for post-application employees.
© 2006
Environment News Service and reprinted by special permission
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