Tag Archive for: Pesticides

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CLC and Several Members Join 100 Organizations in Asking EPA to Immediately Ban the Pesticide Clorpyrifos which Damages Children’s Neurological Systems

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March 5, 2021

OPP Docket # EPA-HQ-OPP-2008-0850-0750 Environmental Protection Agency Docket Center (EPA/DC) 1200 Pennsylvania Ave. NW Washington, DC 20460-0001

Subject: Letter Urging Expeditious Action to Ban Chlorpyrifos

The undersigned 101 farmworker, public health, environmental, labor, and faith organizations urge the EPA to immediately revoke all food tolerances for chlorpyrifos and initiate the cancellation process to end all uses of this neurotoxic pesticide.

Chlorpyrifos, which belongs to a nerve-agent class of pesticides called organophosphates (OPs), is used on an extensive variety of crops and is acutely toxic and associated with neurodevelopmental harms in children. Yet, in its proposed interim registration review decision, the EPA is proposing to allow 11 food uses of chlorpyrifos to continue at the urging of industry.

Peer-reviewed studies and EPA’s own Scientific Advisory Panel have demonstrated that chlorpyrifos damages children’s brains; prenatal exposure to very low levels of chlorpyrifos — levels far lower than what EPA used to set regulatory limits — harms babies permanently. Studies show that exposure to chlorpyrifos, and other OP pesticides during pregnancy, is associated with lower birth weight, attention deficit disorders, autism spectrum disorder, reduced IQ, and loss of working memory.1 It is also unsafe for workers even with the most protective equipment.

In 2014, EPA released a risk assessment finding unsafe drinking water contamination from chlorpyrifos and it proposed to ban chlorpyrifos from food in 2015. In 2016, EPA released a revised human health risk assessment, which confirmed that exposures to chlorpyrifos are unsafe whether in food, pesticide drift, or drinking water; toddlers were being exposed to levels 140 times what is considered safe in food and all drinking water exposures were found to be unsafe. But in 2020, EPA released a new risk assessment, which abandoned attempts to protect children from the low-level exposures that damage their brains.

Under the law, EPA must find reasonable certainty of no harm to children from pesticides. It cannot make this finding for any use of chlorpyrifos on food. The only outcome that protects our children and complies with the law is to revoke all food tolerances and end all food uses as soon as possible. The 2015 proposed tolerance revocation would have prohibited chlorpyrifos on food six months after the rule became final. EPA should adhere to that timetable. 2

Ending use of chlorpyrifos on food will protect the farmworkers who grow that food. However, chlorpyrifos is also used in other ways that expose workers to extremely dangerous amounts of the pesticide. For example, chlorpyrifos is used in greenhouses on ornamental plants. The greenhouse workers face unconscionable risks. And under EPA’s 2020 risk assessment and proposed decision, the agency finds that the workers who mix and apply chlorpyrifos will face unsafe exposures from more than 100 tasks; workers who re-enter fields sprayed with chlorpyrifos will be at risk as well.

The EPA is proposing to allow these risks to continue because of the economic benefits of using chlorpyrifos compared to other currently available chemical pesticide alternatives. In making this proposal, EPA is ignoring non-chemical methods of pest control as well as the economic costs and hardships caused by pesticide poisonings, learning disabilities, reduced IQ in children, and environmental harm from chlorpyrifos use; this pesticide also contaminates surface water and harms threatened and endangered species, including birds, Pacific salmon, Southern Resident Killer Whales, and other mammals.

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Why Won’t New York’s Governor Cuomo Ban the Nasty Pesticide Chlorpyrifos which Harms Children?

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Something really curious is happening in New York State. In June, the New York Assembly passed a bill to ban the nasty pesticide chlorpyrifos that damages the development of children. That’s not the weird part. What’s surprising is that Governor Andrew Cuomo has not signed the bill, despite the fact that the NY Attorney General Letitia James joined five other attorneys general in suing the Trump administration’s federal Environmental Protection Agency because it overturned an Obama administration ban on the pesticide.

“Chlorpyrifos is extremely dangerous, especially to the health of our children,” said Attorney General Letitia James. “Yet, the Trump Administration continues to ignore both the science and law, by allowing this toxic pesticide to contaminate food at unsafe levels. If the Trump EPA won’t do its job and protect the health and safety of New Yorkers, my office will take them to court and force them to fulfill their responsibilities.”

“The governor shouldn’t be striving to protect some of the people some of the time, but should protect all of the people all of the time.” — Reid Maki

The other states that joined the suit are Washington, Maryland, Vermont, Massachusetts, and California—the latter is the country’s largest agricultural producer (measured by cash receipts) and has decided to remove chlorpyrifos from the market in 2020.

Studies have also linked chlorpyrifos to autism, cancer, Parkinson’s disease, reduced IQ, loss of working memory, attention deficit disorders and delayed motor development.
Nationally, home use was banned in 2001 because of its impact on children’s developing brains. In 2018, Hawaii became the first state to enact a complete ban on its use, which includes farms.

Chlorpyrifos is also thought to damage male reproductive organs to the point that it can make men sterile.
After food safety authorities determined that there was no safe exposure level to chlorpyrifos—that any trace of the pesticide was too dangerous, the European Union is expected to ban entry of food products contaminated with the pesticide next year.

In August, The National Consumers League (NCL) and the Child Labor Coalition, which NCL co-chairs, joined over 80 groups—including many from New York—on a letter, urging Governor Cuomo to sign the chlorpyrifos ban. We were naïve enough to think he would.

With an avalanche of data suggesting it is too dangerous to use and his own attorney general suing over its use, why has Cuomo seemingly decided not to ban the pesticide? We can only guess. In July, the governor signed landmark legislation to protect farmworkers from labor abuses, ensure equitable housing and working conditions, and grant them collective bargaining, overtime pay, unemployment compensation and other benefits.

Farmworkers are some of the most exploited workers in America and we applaud the governor for doing the right thing, but he seems to be taking the position that having done something farm owners didn’t like, he shouldn’t sign the chlorpyrifos ban because they won’t like that either. The farmers see the pesticide as an effective tool to help them grow crops.
The problem is that chlorpyrifos doesn’t just harm consumers—those who eat farm produce. It harms the very people that produce crops: the farmers and the farmworkers and the children of both.

Should giving farmworker labor rights mean that it’s okay to endanger their fertility and cause their children to suffer developmental delays or autism? And from the farmers’ perspective, shouldn’t their children be protected from those afflictions. The governor shouldn’t be striving to protect some of the people some of the time, but should protect all of the people all of the time.

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What has happened to nurturing and protecting children?

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The Child Labor Coalition is a non-partisan group that is concerned with the health and welfare of children in the U.S. and abroad. We were extremely critical of the Obama administration’s decision to withdraw proposed safety protections for children who work in agriculture—-known as “hazardous occupations orders.”

We try to call it as we see it and ignore politics. We love any politician who puts children first. But today, we are stunned by the numerous attacks on children by the Trump administration and left wondering what horror is next? 

Earlier this month, Customs and Border Patrol announced that it would stop education classes, legal aid, and even recreational activities for children at the border detention facilities housing immigrant children. Detained children have already been traumatized by their arduous journey to the U.S., their subsequent detention, and, in many cases, forced family separation. What Grinch would deny them schooling and playtime?

Reid Maki, Director of Child Labor Advocacy, National Consumers League and Coordinator of the Child Labor Coalition.

Institutionalization and family separation constitute traumatic experiences that threaten the physical and mental health of children. The N.Y. Times reported on February 27th that the federal government had received more than 4,500 complaints of sexual abuse of children in immigration facilities over four years, including an increase since the Trump administration began separating families. Shouldn’t we focus our energies on reuniting families and easing the psychological damage that has already been done—not penalizing children even further?

The decision to withhold education and recreation was just the latest salvo in what increasingly seems like a war against children by the Trump administration. We recently learned that the Environmental Protection Agency (EPA) had decided to defund children’s health research centers around the U.S. For decades, the centers have brought together researchers and children’s health experts to reduce environmental health risks that children face.

The research centers helped expose the danger of the pesticide chlorpyrifos which damages the development of children’s brains and poses grave health risks to child farmworkers, adult farmworkers, and farmers. EPA had decided to ban the toxic pesticide under the Obama administration, but then reversed the ban under the Trump presidency.

The Trump administration also attempted to reverse an Obama administration ban on children applying pesticides as part of their job on farms. Does our agricultural economy need children to apply pesticides? No. Fortunately, after several months of pursuing the idea, the Trump administration seems to have given up—only to move on to the latest perverse idea.

Recently, the EPA and the Office of Management and Budget officials announced plans to change regulations concerning “agricultural exclusion zones” (AEZs). Under current rules, if a plane or aerator sprays pesticides on a field it must be at least 100 feet from workers in the fields; other applicators must be at least 25 feet from workers. Although not spelled out, everyone is assuming the changes will weaken or eliminate the AEZs–because the Trump administration never acts to increase protections for vulnerable populations.

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127 Groups Ask EPA Not to Reverse Ban on Pesticide Application by Children

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Dear Administrator Pruitt:

The undersigned organizations write to oppose any changes by the Environmental Protection Agency (“EPA”) to the requirements in the Agricultural Worker Protection Standard (“WPS”) and Certification of Pesticide Applicators rule (CPA).

Over 15 years ago, an EPA report stated that “pesticide poisoning in the United States remains under-recognized and under-treated…despite the ubiquity of pesticides in our homes, workplaces, and communities, and despite the considerable potential for pesticide-related illnesses and injury.” Farmworkers have one of the highest rates of chemical exposures among U.S. workers and they suffer acute pesticide poisoning every year through occupational exposures and pesticide drift. Studies have shown that agricultural workers suffer serious short- and long-term health effects from exposure to pesticides. The WPS and CPA rules provide vital protections from exposure to toxic pesticides for hired farmworkers, pesticide applicators, their families and the general public in communities across the United States. In revising these rules, the EPA recognized that the weight of evidence suggests that the new requirements, “will result in long-term health benefits to agricultural workers, pesticide handlers,” and “to certified and noncertified applicators, as well as to the public and the environment.”

After more than a decade of stakeholder input and analysis, the EPA revised the WPS and CPA rule to prevent injury and illness to the children, women and men who work around pesticides in agriculture, or who come into contact with pesticides in other settings. EPA found that the new safeguards are necessary to address the known dangers associated with pesticide use. The WPS applies to hired workers and pesticide handlers who labor in farms, fields, nurseries, greenhouses and forests. The CPA rule governs the training and certification requirements of workers who apply Restricted Use Pesticides (“RUPs”) in a variety of settings, including homes, schools, hospitals, as well as agricultural and industrial establishments. RUPs are some of the most toxic and dangerous pesticides on the market.

 

We are concerned that the EPA may weaken critical safeguards meant to protect agricultural workers, the public, and the environment. Among the many important provisions in the rules, the Agency has stated its intent to reconsider the minimum age protections that prohibit children from applying pesticides, the right of farmworkers to access pesticide application information through a designated representative, and protections for bystanders through “application exclusion zones,” which require that an applicator suspend pesticide application if “an unprotected/non-trained person” enters the area around the application equipment.

Undermining these important protections cannot be justified. We urge you to preserve the existing protections and to move forward with full implementation and enforcement.

Respectfully,

127 child, faith, agricultural, health, labor, human rights, consumer and environmental groups, including the Child Labor Coalition have signed the letter.

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A Toxic Decision — How Protecting Child Farmworkers May Be Pushed Aside by the EPA

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By Len Morris

America’s fields, orchards and farms are toxic places for children; and things could get much worse thanks to recent actions by the Trump administration Environmental Protection Agency led by Administrator Scott Pruitt, an ideologue willing to put business interests ahead of the health and welfare of migrant families and U.S. citizen children that the EPA. is responsible for protecting.

Len Morris

Over 2 million farm workers work in American agriculture, an estimated half a million of these are children. Their work puts them in daily direct contact with hazardous pesticides that can sicken them, lower their IQ, make them chronically ill or even lead to death. 

Two regulations to protect children from pesticide poisoning, illness and death, The Agriculture Worker Protection Standard of 2015 and The Certification of Pesticide Applicators Rule currently of 2017 make it illegal for children under 18 to handle these chemicals, especially those considered most toxic and lethal. These are the protections Pruitt has proposed revising/eliminating.

For children on farms, pesticide exposure is particularly hazardous. The American Academy of Pediatrics has said there is a clear link between childhood exposure to pesticides and pediatric cancers, decreased cognitive functions and behavioral problems. Young children are especially vulnerable as they metabolize poisons faster than adults. 

An estimated 1.1 billion pounds of pesticides are applied to crops each year in the U.S.  The Environmental Protection Agency has reported 20,000 cases of pesticide poisoning, a low estimate since reporting is spare and migrant families are often afraid to seek medical attention. 

Yesenia, age 12, harvesting onions in South Texas (Photo courtesy of Robin Romano)

It’s one thing to streamline regulations to promote economic growth but quite another when the work of an agency has become so corrupted that it turns its back on children’s health. Today’s EPA. under Pruitt’s stewardship has become a shameful enterprise, weakening the health of all Americans by lowering the quality of the air we breathe, the water we drink and the safety of our food supply while compromising the health and safety of those who harvest our food.

Today, more Americans than ever before are purchasing organic and locally grown food in an effort to minimize their children’s exposure to pesticides. Shouldn’t we have the same basic consideration for those children whose families do the work of bringing that food to our table?

The public comment period for the proposed revisions has not opened yet.

This piece was originally published January 17, 2018 on the Media Voices for Children website. Len Morris is the executive director of Media Voices for Children and a film director who has made several documentaries about child labor, including “Stolen Childhoods.”