CLC and Several Members Join 100 Organizations in Asking EPA to Immediately Ban the Pesticide Clorpyrifos which Damages Children’s Neurological Systems
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.
For the workers, the EPA is considering requiring more protective clothing and gear, but those measures can cause heat stress in many regions where workers toil in hot temperatures. And the agency is proposing to afford farmworkers less protection than industrial workers where personal protective equipment is the last resort, employed only if the exposures cannot be prevented.
When the Trump EPA derailed the proposed tolerance revocation, states like Hawaii, California, Oregon, and New York stepped in. In California, 99% of chlorpyrifos uses are now banned. While states can end use of chlorpyrifos, they cannot prevent residues of chlorpyrifos on their food. Only the EPA can do that. All Americans need the EPA to do its job and ensure our food is safe for children.
We, therefore, urge the EPA to immediately:
1. Revoke the 2019 final order2 that denied the 2007 petition to ban food uses of chlorpyrifos;
2. Grant the 2007 petition;
3. Finalize the 2015 proposed order revoking all chlorpyrifos food tolerances;
4. Initiate the cancellation process for all uses of chlorpyrifos.
The proposed interim decision on chlorpyrifos fails to protect the health of workers and children from a pesticide that is widely recognized as unsafe. Only banning the pesticide can truly protect children, workers, and the environment.
Signed,
| ActionAid USA |
| American Bird Conservancy |
| American Public Health Association |
| Association of Farmworker Opportunity Programs |
| Beyond Pesticides |
| Center for an Ecology-Based Economy |
| Center for Biological Diversity |
| Center for Energy & Environmental Education |
| Center for Food Safety |
| Child Labor Coalition |
| Citizens Campaign for the Environment |
| Clean Water Action |
| Clean Water Fund |
| Community Action Works |
| Conservation Law Foundation |
| CREA: Center for Reflection, Education and Action |
| CRLA Foundation |
| Defend Our Health Earth Action, Inc. |
| Earth Ethics, Inc. |
| Earthjustice |
| East Yard Communities for Environmental Justice |
| Endangered Species Coalition |
| Environment Maine |
| Environmental Advocates NY |
| Experimental Farm Network |
| Farmworker and Landscaper Advocacy Project |
| Farmworker Association of Florida Farmworker Justice |
| Fayetteville PACT |
| Fertile Acres |
| First Focus on Children |
| Food & Water Watch |
| Food Empowerment Project |
| Four Harbors Audubon Society |
| FreshWater Accountability Project |
| Friends of the Earth |
| Genesee Valley Audubon Society |
| Georgia STAND-UP |
| Global Labor Justice – International Labor Rights Forum |
| Green America |
| Green Inside and Out |
| Human Rights Watch |
| Huntington Breast Cancer Action Coalition |
| International Corporate Accountability Roundtable (ICAR) |
| International Initiative to End Child Labor |
| Justice for Migrant Women |
| Labor Council for Latin American Advancement |
| LEAD for Pollinators., Inc. |
| League of Conservation Voters |
| League of United Latin American Citizens (LULAC) |
| Learning Disabilities Association of Georgia |
| Learning Disabilities Association of America |
| Learning Disabilities Association of Arkansas |
| Learning Disabilities Association of Connecticut |
| Learning Disabilities Association of Illinois |
| Learning Disabilities Association of Maine |
| Learning Disabilities Association of New Jersey |
| Learning Disabilities Association of Pennsylvania |
| Learning Disabilities Association of Minnesota |
| Learning Disabilities Association of South Carolina |
| Learning Disabilities Association of Texas |
| Learning disabilities association of Utah |
| Learning Disabilities Association of Tennessee |
| Learning Disabilities Association of Wisconsin |
| Maine Audubon |
| Maine Conservation Voters |
| Maine Organic Farmers and Gardeners Association |
| Maine Unitarian Universalist State Advocacy Network |
| Maryland Pesticide Education Network |
| Media Voices for Children |
| Mighty Earth |
| Migrant Clinicians Network |
| MOM’s Organic Market |
| National Consumers League |
| National Nurses United |
| Natural Resources Defense Council |
| NC Farmworkers’ Project |
| New Mexico Center on Law and Poverty |
| Northeast Organic Farming Association — New York (NOFA-NY) |
| Northwest Center for Alternatives to Pesticides |
| Northwest Workers’ Justice Project |
| NYC Audubon |
| Operation Splash |
| Oregon Physicians for Social Responsibility |
| Pesticide Action Network |
| Physicians for Social Responsibility |
| Physicians for Social Responsibility Maine Chapter |
| Pineros y Campesinos Unidos del Noroeste (PCUN) |
| Public Citizen |
| Rachel Carson Council |
| RESTORE: The North Woods |
| Santa Cruz Climate Action Network |
| Sierra Club |
| Student Action with Farmworkers |
| The Oakland Institute |
| The Xerces Society for Invertebrate Conservation |
| Toxic Free North Carolina |
| Union of Concerned Scientists |
| UFW Foundation |
| Virginia Association for Biological Farming |
End notes:
1 See: “Brain anomalies in children exposed prenatally to a common organophosphate pesticide,” Rauh et. al., Proceedings of the National Academy of Sciences of the United States of America, reviewed for review February 27, 2012. Viewable: https://www.pnas.org/content/pnas/109/20/7871.full.pdf (last visited 1/29/21) “Prenatal exposure to organophosphate pesticides and functional neuroimaging in adolescents living in proximity to pesticide application,” Sagiv et. al., Proceedings of the National Academy of Sciences of the United States of America, received for review March 6, 2019. Viewable: https://www.pnas.org/content/116/37/18347 (last visited 1/29/21)
