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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.