October 5th, 2011
EPA-HQ-OPP-2008-0850
Submitted via www.regulations.gov
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, 2011 Memorandum of
Understanding on Environmental Justice and Executive Order 12898, and the recent
announcement of Plan EJ 2014. We hope that these announcements represent meaningful
steps 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 communities by 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 all residential 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
house dust 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 the continued use of 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), 11261134, (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 nonagricultural 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 MexicanAmerican 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
(http://www.cdpr.ca.gov/docs/whs/pisp.htm)
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, <http://www.fwpp.org>;
(2006); Fenske et al, Organophosphorus Pesticide Air Monitoring Project Final Report,
<http://www.doh.wa.gov/ehp/Pest/driftresults.htm> (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, http://www.fwpp.org;
(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 < http://www.epa.gov/oppsrrd1/REDs/factsheets/chlorpyrifos_fs.htm>
xvi
National Agricultural Statistics Service, Agricultural Chemical Use Database
<http://www.pestmanagement.info/nass/act_dsp_usage_multiple.cfm>
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
fhsinj@aol.com
Robina Suwol
Executive Director
California Safe Schools
Los Angeles, California
(818) 785 5515
www.calisafe.org
Margaret Reeves, PH.D.
Senior Scientist
Pesticide Action Network North America
49 Powell St., Suite 500
San Fransisco, CA 94102
(415) 981-1771
mreeves@aol.com
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
acode@pesticide.org
Lewis Papenfuse
Executive Director
Farmworker Legal Services of NY, Inc.
1187 Culver Road
Rochester, NY 14609-5448
(585) 269 9639
lpapenfuse@wnylc.com
Jeannie Economos
Pesticide Safety and Environmental Health Project Coordinator
Farmworker Association of Florida
1264 Apopka Boulevard
Apopka, Florida 32703
(407) 886 5151
farmworkerassoc@aol.com
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
catanc@aol.com
Virginia Ruiz
Senior Attorney
Farmworker Justice
1126 16th Street NW, Suite 270
Washington, DC 20036
(202) 293 5420
vruiz@farmworkerjustice.org
Margarita Romo
Executive Director
Farmworker Self Help
37240 Calle De Milagros
Dade City, Florida 33523
(352) 567 1432
room@fshflorida.org
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
jphilo@sugarlaw.org
Virginia Nesmith
Executive Director
National Farm Worker Ministry
438 North Skinker Boulevard
St. Louis, Missouri 63130
(314) 726 6470
vnesmith@nfwm.org
Denise Diaz
Director
Central Florida Jobs with Justice
231 Colonial Drive, Suite 150
Orlando, Florida 32801
(407) 849 1799
centralfljwj@gmail.com
Anne Katten
Pesticide and Work Safety Project Director
California Rural Legal Assistance Foundation
2210 K Street, Suite 201
Sacramento, California 95810
(916) 446 7904
akatten@crlaf.org
Mitzi Shpak
Executive Director
Action Now
2062 Lewis Avenue
Altadena, California 91001
msmshpak@gmail.com
Sarah Aird and Tracey Brieger
Co-Directors
Californians for Pesticide Reform
49 Powell St., Suite 530
San Francisco, California 94102
(415) 981 3939
tracey@pesticidereform.org
Melinda Wiggins
Executive Director
Student Action with Farmworkers
1317 W. Pettigrew Street
Durham, North Carolina 27705
(919) 660 2652
Nadeen.Bir@Duke.edu
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
Alice.Freund@mssm.edu
Marty Mesh
Executive Director
Florida Organic Growers
PO 12311
Gainesville, Florida 32604
(352) 377 6345
fog@foginfo.org
Karen Otto, Program Administrator
Dr. Rathin Vora, Medical Director
Finger Lakes Occupational Health Services
University of Rochester
2180 S. Clinton Avenue, Suite D
Rochester, New York 14618
(585) 244-4771 Ext. 212
Karen_Otto@URMC.Rochester.edu
Rev. Stephen Copley
Chairman
Arkansas Committee on Occupational Safety and Health
P.O. Box 2441
Little Rock, Arkansas 72203
(501) 626 9220
Scopley438@aol.com
Arthur N. Read
Executive Director
Friends of Farmworkers, Inc.
42 South 15th St., Suite 605
Philadelphia, Pennsylvania 19102-2205
(212) 733 0878
aread@friendsfw.org
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
DeanHub@gmail.com
PollyHalf43@gmail.com
Justin Feldman MPH, MSW
Worker Health and Safety Advocate
Public Citizen
215 Pennsylvania Avenue, SE
Washington, DC 20003
(202) 454 5151
JFeldman@citizen.org
Arlene Blum, PHD
Executive Director
Green Science Policy Institute
PO Box 5455
Berkeley, CA 94705
Arlene@arleneblum.com
Elizabeth Crowe
Director
Kentucky Environmental Foundation
PO Box 467
Berea, Kentucky 40403
(869) 986 08068
Elizabeth@kyenvironmentalfoundation.org
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
Linda.Cocchiarella@stonybrook.edu
Barbara Rahke
Director
Philadelphia Area Project on Occupational Health and Safety
3001 Walnut Street, 5th Floor
Philadelphia, Pennsylvania 19104
(215) 386 7000
Philaposh@aol.com
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
Beth.Rosenberg@tufts.edu
Erin Switalkski
Executive Director
Women’s Voices for the Earth
114 W. Pine Street, PO Box 8743
Missoula, Montana 59807
(406) 543 3747
Jamies@womensvoices.org
Rick Hind
Legislative Director
Greenpeace
702 H Street, NW #300
Washington, DC 20001
(202) 319 2445
Rick.Hing@greenpeace.org
Michael C. Fitts
Executive Director
Connecticut Coalition on Occupational Safety and Health
683 North Mountain Road
Newington, Connecticut 06111
(860) 953 2674
Mike.ctcosh@snet.net
Pamela K. Miller
Executive Director
Alaska Community Action on Toxics
505 West Northern Lights Boulevard, Suite 205
Anchorage, Alaska 99503
(907) 222 7714
pamela@akaction.org
Judith Robinson
Associate Director
Environmental Health Fund
41 Oakview Terrace
Jamaica Plain, Boston Massachusetts 02130
(802) 251 0203
jrobinson@igc.org
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
(202) 895 0420 ext. 109
Reid Maki
Director of Social Responsibility and Fair Labor Standards, Child Labor Coalition
National Consumers League
1701 K Street, NW, Suite 1200
Washington, DC 20006
(202) 207 2820
reidm@nclnet.org
Kathleen A. Curtis, LPN
Executive Director
Clean and Healthy New York
62 Grand Street
Albany, NY 12207
518-708-3922
Clean.Kathy@gmail.com
Jim Harkness
President
Institute for Agriculture and Trade Policy
2105 1st Avenue, South
Minneapolis, Minnesota 55404
(612) 870 0453
Lin Kaatz Chary, PhD, MPH
Director
Indiana Toxics Action
7726 Locust Avenue
Gary, Indiana 46403
(219) 938 0209
lchary@sbcglobal.net
Peter Dooley MS, CIH, CSP
Director
LaborSafe Health and Safety Consulting
6301 Zeeb Road
Dexter, Michigan 48130
laborsafe@aol.com
Joann Lo
Executive Director
Food Chain Workers Alliance
634 S. Spring Street, #614
Los Angeles, California 90014
(213) 489 9054
joann@foodchainworkers.org
Judy Gearhart
Executive Director
International Labor Rights Forum
1634 I Street NW, Suite 1001
Washington, DC 20006
(202) 347 4100 x106
judy@irlf.org
Sue Phelan
Director
GreenCAPE
P.O. Box 631
West Barnstable, Massachusetts 02668
(508) 362 5927
suephelan@comcast.net
Barbara Gottlieb
Director, Environment and Health
Physicians for Social Responsibility
1875 Connecticut Ave. NW, Suite 1012
Washington, DC 20009
(202) 587 5225
bgottlieb@psr.org
Cecil Corbin-Mark
Deputy Director
WE ACT for Environmental Justice
1854 Amsterdam Avenue
New York, New York 10031
(212) 961 1000 x.303
Cecil@weact.org
Juan Parras
Director
Texas Environmental Justice Advocacy Services
6733 Harrisburg
Houston, Texas 77011
(281) 513 7799
Parras.Juan@gmail.com
Kerstin Lindgren
Executive Director
Domestic Fair Trade Association
PO Box 300190
Boston, Massachusetts 02130
(617) 680 9862
kerstin@thedfta.org
Robynn Shrader
CEO
National Cooperative Grocers Association
14 South Linn Street
Iowa City, Iowa 52240
(319) 466 9029
Monique Harden & Nathalie Walker
Co-Directors, Attorneys
Advocates for Environmental Human Rights
650 Poydras Street, Suite 2523
New Orleans, Louisiana 70130
(504) 799 3060
mharden@ehumanrights.org
nwalker@ehumanrights.org
Rosalinda Guillen
Executive Director
Community to Community Development
203 W. Holly, Suite 317
Bellingham, Washington 98233
(360) 738 0893
rosalindag@qwestoffice.net
Ernesto Velez Bustos
Director
Centro Campesino, Inc
216 N. Oak Avenue
Owatonna, Minnesota 55060
(507) 446 9599
info@centrocampesino.net