GAO

United States General Accounting Office

Report to Congressional Requesters

March 2000 PESTICIDES

Improvements Needed

to Ensure the Safety of

Farmworkers and

Their Children

GAO/RCED-00-40

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Contents

Letter 3

Appendixes Appendix I: Scope and Methodology 28

Appendix II: Comments From the Environmental Protection Agency 30

Appendix III: GAO Contact and Staff Acknowledgments 34

Figures Figure 1: Children as Young as 6 Picking Onions, April 1998 18

Abbreviations

CDC Centers for Disease Control and Prevention

EPA Environmental Protection Agency

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

NIOSH National Institute for Occupational Safety and Health
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United States General Accounting Office

Washington, D.C. 20548

Resources, Community, and

Economic Development Division

B-284152 Letr

March 14, 2000

The Honorable Henry A. Waxman

Ranking Minority Member

Committee on Government Reform

House of Representatives

The Honorable Tom Lantos

The Honorable Bernard Sanders

House of Representatives

Pesticides are designed to kill or control living organisms such as

unwanted species of plants, insects, and animals. Because pesticides are

designed to be toxic, they have the potential to cause adverse effects on

humans. Children are at greater risk from pesticide exposure than most

adults because, pound for pound of body weight, children breathe more

and eat more. They also have more hand-to-mouth contact than adults. The

Environmental Protection Agency (EPA) is responsible for ensuring that

when properly used, pesticides do not pose an unreasonable risk to human

health or the environment. In this regard, EPA has developed aWorker

Protection Standard that is intended to reduce the risks to agricultural

workers from pesticide exposure and the possible adverse health effects of

pesticides because these workers are among the primary populations

exposed to pesticides.

Concerned about the possible adverse effects of pesticides, you asked us to

report on issues related to the safety of children who may be exposed to

pesticides in agricultural settings. As agreed with your offices, we have

addressed a series of questions pertaining to this overall topic and have

consolidated these questions into three overall issues: (1) What federal

requirements govern the safe use of pesticides, particularly as they relate to

protecting children in agricultural settings? (2) What information is

available on the acute and chronic effects of agricultural pesticide

exposure, particularly on children? (3) What has EPA done to ensure that

its Worker Protection Standard considers the needs of children and is being

adequately implemented and enforced?
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Results in Brief Two laws principally govern the safe use of pesticides: (1) the Federal

Insecticide, Fungicide, and Rodenticide Act, which, among other things,

requires that pesticides be approved byEPA for specified uses, and (2) the

Federal Food, Drug, and Cosmetic Act, which regulates the residues of

pesticides on or in foods. In 1996, the Food Quality Protection Act amended

these two laws and required EPA to, among other things, reevaluate the

amount of pesticide residues allowed on or in food, taking into account

consumers’ aggregate exposure from other sources, including residential

exposures. Unless another safety factor is determined to be appropriate,

EPA is generally required to apply an additional margin of safety in setting

limits on pesticide residues to ensure the safety of food for infants and

children. This law also directed EPA to consider available information

concerning “major identifiable subgroups of consumers” in reevaluating

the amount of pesticide residues that can remain on or in foods. In October

1998, the Natural Resources Defense Council and others petitioned EPA to

identify children living on and near farms as a major identifiable subgroup

for the purposes of the Food Quality Protection Act. In its initial response

to the Council, EPA said it was funding several studies aimed at assessing

the effects of farm children’s exposure to pesticides. As of November 1999,

EPA was still considering the Council’s petition.

Comprehensive information on the occurrence of acute and chronic health

effects due to pesticide exposure does not exist—whether for

farmworkers, farm children, or the population in general. The data sources

that are available to track acute (short-term) pesticide illnesses are

incomplete and have limitations that result in the underestimation of both

the frequency and the severity of such illnesses. In 1993, we reported that

without a means of monitoring pesticide illnesses, there was no way to

determine whether risk assessment or management practices were

effective in preventing hazardous exposure incidents. Our current work

shows that this problem remains largely unaddressed. Information on the

chronic (long-term) effects of agricultural pesticide exposure generally,

and for farm children in particular, is also limited. According to the

National Center for Environmental Health of the Centers for Disease

Control and Prevention, the studies that have been conducted to date have

been limited, inconsistent, and inconclusive. A number of federally

sponsored studies are under way related to the chronic effects of pesticide

exposure, but because of the complexity of the issues involved, it will be

many years, and perhaps decades, before conclusive results from these

studies are known.
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Recognizing the potential for pesticides to cause a variety of illnesses, EPA

has implemented the Worker Protection Standard, which is intended to

reduce farmworkers’ exposure to pesticides. According to EPA, one of the

most important protections afforded by the Standard is the time intervals

between when pesticides are applied and when workers may enter treated

areas (called entry intervals). However, EPA officials told us that these

entry intervals were designed for adults and children at least 12 years old

who do farm work, but were not designed for children younger than 12

years of age. Furthermore, EPA has little assurance that the protections

called for in the Standard are actually being provided to farmworkers

generally or to children who work in agriculture. We found that EPA

regions have been inconsistent in whether they set goals for the number of

worker protection inspections states should conduct, in defining what

constitutes a worker protection inspection, and in the extent to which they

oversee and monitor the states’ implementation and enforcement of the

Standard.

We are making a number of recommendations pertaining to (1) improving

the data on acute pesticide illnesses, (2) taking steps to protect children

younger than 12 years old who work in agriculture or are otherwise present

in pesticide-treated fields, (3) completing the documentation on the

adequacy of the Standard’s entry intervals for children 12 years of age or

older who work in agriculture, and (4) strengthening EPA’s oversight of the

states’ implementation and enforcement of the Standard.

Background Although pesticides play a significant role in increasing food production by

reducing the number of crop-destroying pests, exposure to pesticides can

be harmful to humans. The ill effects may follow from short- or long-term

exposure through skin contact, inhalation, or ingestion. Acute symptoms

range from relatively mild headaches to fatigue, nausea, skin rashes, eye

irritation, burns, paralysis, and even death. Chronic illnesses and those

with delayed onsets, such as cancer, which may only appear years after

exposure to pesticides, can also occur. Some chronic illnesses linked to

pesticide exposure may be subtle—such as neurological disorders or

reduced cognitive skills.

EPA has reported that of the 1.2 billion pounds of pesticides used in the

United States annually, 76 percent, or about 950 million pounds, is used in

the agriculture industry. According to EPA, farmworkers are among the

primary populations exposed to these pesticides. Children may be exposed

to pesticides by doing farm work, by eating fruits and vegetables directly
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from the fields, by being caught in the drift from field applications of

pesticides, or by direct contact with treated plants and soil. Children are

more vulnerable than adults are to the effects of pesticides. For example,

some pesticides pose a greater risk to infants and children because they

breathe more and eat more than adults per unit of body weight, and their

bodies and internal organs are still developing, which makes them much

more susceptible to the effects of pesticides.

The Department of Labor estimates that there are about 2.5 million hired

farmworkers and that about 1.8 million of them work on crops. The number

of children who work in agriculture is not reliably known. In 1998, we

reported that recent estimates from the Department of Labor’s National

Agricultural Workers Survey (the Survey) indicated that about 129,000 14-

to 17-year-olds were being hired to work on crops in the United States,

although this number may be an underestimate.1 The Department did not

survey workers under 14 years of age, but the Survey does contain limited

information on children of farmworkers from interviews conducted with

their parents. For example, the Survey indicated that, in 1996 and 1997, 7

percent of farmworkers with children 5 years of age or younger took their

children with them, at least sometimes, when they worked in the fields. In

this connection, on the basis of thousands of inspections of agricultural

establishments, the Department of Labor’s Wage and Hour Division

reported in 1999 that “farmworker children [are] forced to suffer long hours

in the fields with both parents working and [virtually] no day care

alternatives.”

1

We reported that information collected by the Bureau of the Census indicated that the

number of 15- to 17-year-old agricultural workers may be as high as 290,000. This number

included workers who work on crops, with livestock, or in services related to agriculture,

such as mechanical repairs. These young workers may be hired, self-employed, or unpaid

family workers. We also reported that the Fair Labor Standards Act and state laws provide

less protection for children working in agriculture than for children working in other

industries. For example, children as young as 16 may work in agriculture in any capacity,

including in some occupations declared hazardous by the Secretary of Labor, while in

nonagricultural industries, children generally may not perform such tasks until age 18. The

report also stated that the Congress may wish to reevaluate whether the Fair Labor

Standards Act adequately protects children who are hired to work as migrant and seasonal

farmworkers. See Child Labor in Agriculture: Changes Needed to Better Protect Health and

Educational Opportunities (GAO/HEHS-98-193, Aug. 21, 1998).
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Federal Requirements

Related to Pesticide

Protections for Farm

Children

The primary federal requirements pertaining to the registration, sale, and

use of pesticides are in the Federal Insecticide, Fungicide, and Rodenticide

Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act, both as

amended by the Food Quality Protection Act.

Under FIFRA, pesticides must generally be registered with EPA in order to

be sold or distributed. EPA will register a pesticide if it determines, among

other things, that the pesticide will not generally cause unreasonable

adverse effects on human health or the environment when used in

accordance with commonly recognized practices. EPA’s principal means of

ensuring that pesticides are used properly is enforcement of the agencyapproved label directions, restrictions, and precautions. Also under FIFRA,

EPA established the Worker Protection Standard. States generally carry out

the implementation and enforcement of pesticide requirements, including

the Standard, under cooperative agreements with EPA.

According to EPA, the Worker Protection Standard is EPA’s primary means

to reduce farmworkers’ risks of exposure to pesticides. EPA established

the Standard in 1974, but in 1980, the agency reviewed the Standard and

found it inadequate to protect agricultural workers from exposure to

pesticides. In 1992, EPA made major revisions to the Standard that the

agency began enforcing in January 1995. The revised Standard contains

general protections applicable to farmworkers and others, including

prohibiting the spraying of pesticides while anyone is in a field or allowing

the exposure of people to pesticide spray drift. The Standard also contains

provisions that specifically apply to farmworkers, including restricting

entry into treated areas for specified periods and requiring employers to

provide workers with, among other things, (1) information about when and

where pesticides were applied, (2) basic pesticide safety training, and (3)

supplies (soap, water, and towels) for workers to use to decontaminate

themselves.

According to EPA, the Standard applies to any person who is compensated

for activities related to producing agricultural plants, including children

who are below the legal age to work in agriculture (generally 12 years of

age or older). However, enforcement of the Standard specifically for these

young children is problematic because proving that children are working

for compensation is difficult when such activity is illegal. For example, EPA

told us that it is unlikely that records of any illegal employment are being

kept and that neither the farmer nor the worker is likely to be forthcoming

about such an arrangement.
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The Standard makes employers responsible for providing farmworkers

with basic pesticide safety training. EPA regional officials told us that

children who work in agriculture receive the same worker protection

training as adults. While FIFRA requires those who register pesticides to

pay fees to offset EPA’s registration costs, none of these fees may be used

for pesticide safety training. However, EPA was recently authorized to

provide grants for farmworker training (about $200,000 a year). In addition,

according to EPA, several EPA regional offices have provided funds to

either supplement or develop programs to enhance farmworker training.

EPA also provides about $2 million per year to the Department of

Agriculture for training pesticide applicators, but none of this funding is

used to train farmworkers. During our work, we asked EPA and others

about whether there are additional sources of funding or models of funding

being provided for the purpose of pesticide safety training. We identified

one such model. Specifically, an official of the Iowa State University

Extension Service told us that Iowa assesses fees from pesticide dealers

that are used to train and certify pesticide applicators.

Under the Federal Food, Drug, and Cosmetic Act, the amount of pesticides

that may remain on or in foods is limited to a level (referred to as a

tolerance) that EPA has determined to be safe. Under the Food Quality

Protection Act, EPA sets tolerances by considering the anticipated dietary

exposures to the pesticide and other exposures for which there is reliable

information. EPA must consider risks to infants and children and must

generally include in tolerances an additional ten-fold safety margin to

protect infants and children unless another safety factor is determined to

be appropriate. EPA is also required to consider available information on

the aggregate exposure levels of major identifiable subgroups of

consumers to the pesticide and other related substances, including

exposure from dietary and other sources. 2 EPA will not register a pesticide

under FIFRA for use on foods unless it has also issued all necessary

tolerances for that pesticide.

In October 1998, the Natural Resources Defense Council and other groups

petitioned EPA to consider farm children as an identifiable subgroup for

the purpose of setting tolerances because they contended that children

living on or near farms may have substantially greater exposure to

pesticides than other groups of children. The Council also argued that

2

The Food Quality Protection Act did not specifically define major identifiable subgroups of

consumers.
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these children represent a significant proportion of the population and

should be protected. Several agricultural groups subsequently submitted

comments to EPA arguing that the Council had not presented any scientific

data showing farm children to be suffering from greater health problems

than other populations. The agricultural groups’ position is that even if

there were problems with farm children being exposed to pesticides from

occupational uses, such problems should be addressed under FIFRA. The

groups contend that FIFRA was specifically designed to deal with

occupational concerns, while the Congress excluded occupational sources

from the tolerance-setting done under the Food Quality Protection Act. In

December 1998, EPA stated that it was evaluating the issues raised in the

Council’s petition. EPA is funding several studies aimed at assessing farm

children’s exposure to pesticides and the effects of this exposure on

children’s growth and development. However, as of November 1999, EPA

had not completed its response to the Council.

As part of its implementation of the Food Quality Protection Act, EPA is

revising the way it assesses residential pesticide exposures to better

account for farm children’s exposures. Among other things, in setting

tolerances, EPA will consider pesticides that are tracked into homes and

pesticide exposures children receive through spray drift in agricultural

areas. As of November 1999, EPA had not completed its revision of

methods to assess residential pesticide exposures.

Finally, Executive Order 13045—Protection of Children From

Environmental Health Risks and Safety Risks—required each federal

agency to identify and assess environmental health risks that may

disproportionately affect children. In response to the Order, EPA

established the Children’s Health Protection Advisory Committee to advise

and make recommendations to EPA on issues related to children’s

environmental health. In 1998, the Committee identified five existing EPA

regulations that it believed should be reevaluated to better protect

children, including the Worker Protection Standard. The Committee stated

that the current Standard had not considered children’s exposure to

agricultural pesticides, but EPA has not yet responded to the Committee.
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Information on the

Extent of Acute and

Chronic Illnesses From

Agricultural Pesticide

Exposure Is Limited

The degree to which farmworkers generally, and their children specifically,

suffer adverse effects from pesticide exposure compared with the general

population is not conclusively known. The data sources that EPA uses to

track acute pesticide illnesses have limitations that may result in the

significant underestimation of both the frequency and the severity of

pesticide illnesses. The National Institute for Occupational Safety and

Health (NIOSH) and the National Center for Environmental Health

identified a number of steps that could be taken to improve data collection

and reporting of acute pesticide illnesses.3 Information on the chronic

effects of agricultural pesticide exposure generally, and for farm children in

particular, is also limited. For example, researchers at the National Cancer

Institute have reported that farmworkers and their children are frequently

exposed to potentially carcinogenic pesticides, but little is known about

the occurrence of cancer among farmworkers. The studies that have been

conducted to date have been limited, inconsistent, and inconclusive.

Nevertheless, the Center for Children’s Environmental Health Research at

the University of California at Berkeley, recently reported that despite the

lack of information on this topic, concerns still exist about the chronic

effects of children’s exposure to agricultural pesticides.4 A number of

federally sponsored studies are under way on the chronic effects of

pesticide exposure, but it will be many years, perhaps decades, before

conclusive results from these studies are known.

Information on Acute

Pesticide Illnesses Is Not

Comprehensive

In 1993, we reported that while some sources of information about acute

pesticide illnesses existed, they were generally limited in coverage,

comprehensiveness, and quality of information.5 As a result, there was no

capability to determine the precise national incidence or prevalence of

pesticide illnesses that occur in the agricultural sector. We concluded that

without a valid means of monitoring pesticide illnesses, there was no way

to identify problems that may occur with the different uses of pesticides or

3

NIOSH is a federal agency that conducts research on occupational disease and injury, and

the National Center for Environmental Health is a federal agency that conducts research

and monitors and evaluates environment-related health problems.

4

The Center for Children’s Environmental Health Research at the University of California at

Berkeley has been designated by EPA as a research center for studying the relationship

between pesticides and children’s health, including growth and development.

5

Pesticides on Farms: Limited Capability Exists to Monitor Occupational Illnesses and

Injuries (GAO/PEMD-94-6, Dec. 15, 1993).
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to determine whether risk assessment and management practices were

effective in preventing hazardous exposure incidents. Six years later, we

have found that this problem remains largely unaddressed.

During our current work, officials from EPA told us that no comprehensive

national data exist on the extent to which farmworkers (and farm children)

are experiencing acute pesticide incidents or illnesses.EPA officials

referred us to the National Institutes of Health—specifically, the National

Cancer Institute and the National Institute of Environmental Health

Sciences—and the Centers for Disease Control and Prevention (CDC)—

specifically, the National Center for Environmental Health and NIOSH.

Officials from these agencies that collect data on pesticide illnesses

confirmed that a lack of comprehensive national data exists not only for

farmworkers and farm children, but for the general population as well.

In the absence of comprehensive nationwide information, EPA uses four

databases to provide some indication of the extent of acute pesticide

incidents and illnesses. These databases are (1) the American Association

of Poison Control Centers’ Toxic Exposure Surveillance System, (2) the

data reported to EPA under FIFRA, (3) the National Pesticide

Telecommunications Network, and (4) the California Pesticide Illness

Surveillance Program. However, each of these databases has limitations:

• The American Association of Poison Control Centers maintains

information on poison exposures. However, its database does not

isolate pesticide exposures that occurred from agricultural work (or

from any other occupation). In addition, some poison control centers do

not report to the national database, and reports that poison control

centers receive by telephone may lack medical confirmation.

• Under section 6(a)(2) of FIFRA, registrants are required to submit

information they obtain about unreasonable adverse effects of their

pesticide products. The 6(a)(2) database was designed to gather

information on the effects of pesticides rather than on the extent of

pesticide incidents. Therefore, according to EPA, the database contains

detailed reports on serious and rare incidents, but little information on

less serious incidents.

• The National Pesticide Telecommunications Network (a cooperative

effort between EPA and Oregon State University) is a toll-free telephone

service that provides the general public and health professionals with

information on pesticide health and safety and pesticide incidents.

While the Network categorizes pesticide incidents by the age, sex, and

occupation of the affected person, the Network’s data rely on self-
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reporting, and most of the information has not been verified or

substantiated by independent investigation, laboratory analysis, or any

other means. Moreover, many farmworkers, particularly migrant or

seasonal workers, may not have ready access to a telephone to report

pesticide incidents.

• The California Pesticide Illness Surveillance Program, often cited as the

most comprehensive state reporting system, obtains most of its case

reports through the Workers’ Compensation system. Therefore, illnesses

that occur in farm children who are not officially workers are unlikely to

be reported in this system. Also, according to EPA and farmworker

advocacy groups, farmworkers may be reluctant to report pesticide

exposures because of the potential for retaliatory actions such as loss of

job or pay cuts.

Notwithstanding the limitations of California’s program, EPA used this

information in 1999 to make a nationwide estimate that there were 10,000

to 20,000 incidents of physician-diagnosed pesticide illnesses and injuries

per year in farm work. However, EPA recognized that its estimate

represents serious underreporting. Moreover, according to officials from

the California Department of Pesticide Regulation, because California’s

crops and pesticide regulations are different from those of other states, it is

inappropriate to extrapolate California’s data to the rest of the nation. In

addition, there are other reasons why acute pesticide incidents are

underreported, including farmworkers’ hesitancy to seek medical care for

financial reasons or for fear of retaliation by employers and physicians’

misdiagnosis or failure to report incidents.

Given the limitations of the information on acute pesticide illnesses, we

asked officials from CDC what steps are needed to develop a model system

for monitoring and reporting acute pesticide illnesses.Two CDC

agencies—NIOSH and the National Center for Environmental Health—

provided responses.

NIOSH identified a number of steps that could be taken to improve data

collection and reporting of acute pesticide illnesses, including the

following:

• Establish reporting systems that are based on standardized data

elements for pesticide illnesses in all states. Currently, EPA and NIOSH

are funding such a program (referred to as the Sentinel Event

Notification System for Occupational Risk—or SENSOR—program).

The program provides funding and technical assistance to state health
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departments to support the pilot testing of standardized data collection

on pesticide illnesses and injuries. However, federal funding for this

program is limited to five states, and one other state is participating on

its own.

• Improve the training of health care professionals to help them recognize

acute pesticide illnesses and injuries. In 1998, EPA launched an initiative

to provide health care professionals with educational and training

opportunities on the health issues pertaining to pesticides. EPA is

developing a national plan to fully implement this initiative.

• Conduct a periodic survey of agricultural workers to identify individuals

with pesticide illnesses who have not sought health care and therefore

have not been reported in surveillance systems. Currently, the

Department of Labor’s National Agricultural Workers Survey collects

limited information on the health effects on the agricultural labor force

associated with pesticide exposure. NIOSH indicated that it would like

to expand the Survey to include more extensive questions about

pesticide exposures and their effects on farmworkers and their family

members.

• Improve the collection of data on pesticide use. While some data are

available nationally on the quantities of agricultural pesticides used

annually, only a few states require the reporting of pesticide use. NIOSH

stated that to make the needed calculations of risk and illness rates, it

would be useful to have data on pesticide use from all states.

NIOSH stated that implementing these steps would result in better

information on the number of illnesses; identify trends in diseases,

epidemics, and emerging problems; and provide a means to evaluate the

effectiveness of illness prevention and intervention efforts. However,

NIOSH estimated that implementing these improvements would cost more

than $20 million per year.

The National Center for Environmental Health added suggestions aimed at

collecting data on nonoccupational exposures to agricultural pesticides,

both for family members of farmers and farmworkers and for the general

public. The Center proposed establishing a national reporting system for

pesticide incidents that are nonoccupational to complement ongoing

occupational reporting. Such a system is currently being piloted in Texas,

involving active data collection and case investigations of all pesticide

exposures and illnesses in the state that are not associated with work.
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Chronic Effects of Pesticide

Exposure on Humans Have

Not Been Conclusively

Researched

Some studies have reported associations between pesticide exposure and a

range of chronic effects on humans, including fetal deaths and deformities,

cancers, and neurological and developmental effects. However, officials

from EPA, CDC (including the National Center for Environmental Health

and NIOSH), and the National Institutes of Health (including the National

Cancer Institute and the National Institute for Environmental Health

Sciences) told us that the chronic effects of agricultural pesticide exposure

on humans have not yet been conclusively researched. For example, the

National Institutes of Health stated that while pesticide exposure increases

the risk of certain tumors, there is scientific disagreement over the specific

agents in the pesticide formulation, the specific pesticides within large

chemical classes, and the specific doses and timing of exposure that might

be responsible. The National Center for Environmental Health told us that

“studies of the long-term health effects of pesticide exposures have been

inconsistent and inconclusive; therefore, it is not possible to state with any

degree of certainty what the long-term effects of pesticide exposure may

be.”

Even less is known about the combined effects of human exposure to

different pesticides. During the course of their work, farmworkers may be

exposed to several different types of pesticides. While pesticides may

combine their effects in controlling insects (known as a common

mechanism of toxicity), it is unknown whether pesticides combine their

effects in the same way to cause harm to humans. For example, NIOSH told

us that virtually nothing is known about the combined effects of different

pesticides on human health.

The chronic effects of pesticides on children have been researched even

less than these effects on adults. The National Institutes of Health told us

that while links have been identified between some pesticides and

leukemia, lymphoma, and brain cancer in children, the results are not

conclusive. The research on pesticide-related cancer in children has been

limited by the availability of information, such as uncertainty about the

levels and types of pesticides involved, and the small numbers of subjects

and studies. Similarly, researchers have linked in utero pesticide exposure

to defects in fetuses’ physical development and to fetal death, but these

studies have been limited by methodological constraints similar to those

occurring in cancer research.

However, the Center for Children’s Environmental Health Research at the

University of California at Berkeley (designated byEPA as one of two

university research centers for studying pesticides and children’s health)
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recently reported that notwithstanding the paucity of information about the

effects of pesticides on children, “there is substantial evidence in

developing rodents and limited evidence in adult humans . . . that low-level

chronic exposure to organophosphates may affect neurological

functioning, neurodevelopment, and growth.”

Federal researchers have several projects under way to begin determining

the nature and extent of chronic pesticide exposure on farm children.

However, this will be a long and complicated process. The federal research

projects under way include the following efforts:

• The Center for Children’s Environmental Health Research at the

University of Washington is studying the special vulnerabilities of

children to health risks from pesticides.

• The Center for Children’s Environmental Health Research at the

University of California at Berkeley is studying pesticide exposures and

their effects on approximately 500 pregnant women and their children in

the Salinas Valley area of California.

• The National Cancer Institute, in collaboration with the National

Institute for Environmental Health Sciences and EPA, has recently

begun the Agricultural Health Study, a large study of pesticide

applicators, farmworkers, and their families in Iowa and North Carolina.

These efforts will yield results slowly over a number of years or even

decades. Recognizing the potential for pesticides to cause a variety of

illnesses, EPA has implemented the Worker Protection Standard intended

to help mitigate the possible health effects of pesticide exposure on

farmworkers.
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The Worker Protection

Standard May Not

Adequately Protect

Young Children, and

Questions Exist About

Whether the States Are

Adequately

Implementing the

Standard for

Farmworkers

Generally

One of the most important parts of the Worker Protection Standard—the

time intervals between pesticide applications and when workers may enter

treated areas (called entry intervals)—was designed to protect adults and

children who are 12 years of age or older, but was not designed for children

younger than 12 years of age. Nevertheless, there is evidence that young

children are either working in agriculture or are present in the fields for

other reasons and that they have greater vulnerability to the adverse effects

of pesticides than adults. Furthermore, although EPA has stated that

implementing the Standard is a high priority, EPA has little assurance that

the protections the Standard calls for are actually being provided to

farmworkers generally or to children working in agriculture. Under

cooperative agreements with EPA, the states monitor and enforce the

implementation of the Standard by inspecting agricultural establishments.

However, we found that EPA regions have been inconsistent (1) in whether

they set goals for the number of worker protection inspections that states

should conduct, (2) in defining what constitutes a worker protection

inspection, and (3) in the extent to which they oversee and monitor the

states’ implementation and enforcement of the Standard.

The Worker Protection

Standard May Not

Adequately Protect All

Children Exposed to

Agricultural Pesticides

Although young children are present in agricultural fields, either working

or accompanying their parents, and are especially vulnerable to the

potential adverse effects of pesticides, they may not be adequately

protected from pesticide exposure. While the Worker Protection Standard

applies to anyone compensated for activities related to producing

agricultural plants (regardless of age), according to EPA, the Standard’s

entry intervals were designed for adults and children at least 12 years old

who do farm work, but were not designed for children younger than 12. In

1998, the Children’s Health Protection Advisory Committee recommended

that EPA expeditiously reevaluate whether the Standard adequately

protects children’s health. EPA officials told us that the agency had

reviewed the process used to establish the entry intervals and, in

November 1999, had concluded that the entry intervals protect children 12

years of age or older. However, as of February 2000, EPA had not

completed documenting the analysis on which its conclusion is based.

Furthermore, EPA officials told us that the agency has not considered

whether the intervals protect children younger than 12 because their focus

has been on workers of legal age.
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Children below 12 years of age, whether working in agriculture or

accompanying their parents to the fields, have greater vulnerability to the

adverse effects of pesticides:

• Because young children’s internal organs and bodily processes are still

developing and maturing, their enzymatic, metabolic, and immune

systems may provide less natural protection than those of an adult. In

1997, EPA reported that children’s tissues absorb chemicals more

readily and are less effective at excreting some chemicals from the body.

Also, there are critical periods in human development when exposure to

toxins can permanently alter the way an individual’s biological system

operates. In 1993, the National Academy of Sciences reported that

children’s pesticide exposures are of special concern because “exposure

to neurotoxic compounds at levels believed to be safe for adults could

result in permanent loss of brain function if it occurred during the

prenatal and early childhood period of brain development.”

• In addition to breathing more and eating more than adults per unit of

body weight, children behave in ways that may make them more

susceptible to pesticide poisoning than adults. Because children have

greater hand-to-mouth contact compared with adults, oral transfer rates

of pesticides from objects, dust, or soil are greater for children.

Crawling, sitting, or lying on contaminated surfaces may also increase

the exposure rates of children to pesticides.

• Young children may not wear clothing that protects them from exposure

as well as adults’ clothing. In developing entry intervals, EPA has

assumed that workers would be wearing typical farm apparel (i.e., long

sleeves, long pants, and work boots). However, this may not always be

the attire young children wear when they are in the fields.

While the federal Fair Labor Standards Act generally prohibits children

below 12 years of age from working in agriculture, the Department of

Labor’s Wage and Hour Division has found children as young as 6 years old

working in agricultural fields during its inspections (see fig. 1). The

Association of Farmworker Opportunity Programs (a public interest group

that collects data on farmworkers for the National Cancer Institute) has

also reported children as young as 6 years old working in agriculture.

Officials from the Department of Labor’s Wage and Hour Division told us

that they have recently increased their attention to child labor violations in

agriculture. However, officials from the Division stated that it will never be

possible to uncover all cases of underage children working in agriculture.

In addition to underage children who work in agriculture, children

accompany their parents to the fields for other reasons, such as the lack of
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childcare. These children are not covered by the Fair Labor Standards Act

or most provisions of the Worker Protection Standard.

Figure 1: Children as Young as 6 Picking Onions, April 1998

Source: Department of Labor’s Wage and Hour Division.

EPA considers the entry intervals it sets to be one of the most important

protections in its Worker Protection Standard. When EPA issued the

revised Standard (which became effective in January 1995), the agency

adopted interim entry intervals until all pesticides could be individually

reevaluated. These interim entry intervals were designed to protect against

acute reactions to pesticides, but chronic health effects and potential

effects on children and fetuses were not considered. In reevaluating the

entry intervals, EPA has adopted a new methodology that is more detailed

and considers chronic health effects and in utero effects. As of August

1999, EPA had applied the new methodology to 189 pesticides (or groups of

related ingredients); EPA estimated that the new methodology may not be
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applied to the remaining 192 pesticides (or groups of related ingredients)

until 2006.

In developing entry intervals under its new process, EPA determines the

amount of time that is required for pesticide residues to dissipate to the

level at which it is safe for agricultural tasks to be performed. As part of

this process, EPA considers, among other factors, how much exposure

workers receive in performing specific agricultural tasks, per unit of body

weight. Body weight is a significant factor in calculating entry intervals. All

other factors being equal, lower body weight would result in longer entry

intervals. For example, EPA generally uses a body weight of 154 pounds

when calculating the entry intervals, but if the pesticide has potential fetal

developmental effects, EPA uses a body weight of 132 pounds to account

for women in their childbearing years. However, EPA told us that the entry

intervals protect children who are 12 years of age or older despite their

smaller body size (the median weight for 12-year-olds is about 100 pounds)

because their bodies have less surface area and they perform less work,

resulting in less physical contact with pesticide-treated plants. Finally, EPA

officials told us that in setting entry intervals, the agency has not

considered whether the intervals protect children younger than 12 years of

age because its focus has been on workers of legal age.

Concerned about how well theWorker Protection Standard considers

children’s exposures to agricultural pesticides, in 1998 the Children’s

Health Protection Advisory Committee recommended that EPA

expeditiously reevaluate the Standard to determine whether it adequately

protects children’s health. The Committee made this recommendation

because it believed that the current Standard did not fully consider the

pesticide exposures that children receive through employment in farm

work and through other means. EPA agreed to this recommendation,

stating that in 1999, it would review its new process for establishing the

Standard’s entry intervals to affirm that the process adequately factors in

the special needs of children employed as farmworkers. In November 1999,

as discussed above, EPA officials told us that they had reviewed the

available data and concluded that the current process for establishing entry

intervals protects children who are 12 years of age and older working in

agricultural fields and that this review fulfilled EPA’s commitment to the

Advisory Committee. However, as of February 2000, EPA had not

completed documenting the analysis on which its conclusion was based

and therefore had not presented its analysis to the Committee. The

Chairman of the Children’s Health Protection Advisory Committee told us

that the Committee would like to assess how EPA came to the conclusion
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that children of legal age are protected under the current process.

Moreover, the Chairman stated that the Committee is still significantly

concerned about the lack of protection for children below the legal

working age.

EPA Has Little Assurance

That theWorker Protection

Standard Is Being

Adequately Implemented

and Enforced for

Farmworkers Generally

EPA’s response to the Children’s Health Protection Advisory Committee

also stated that EPA believes that the health of children who work in

agriculture can be protected by better implementation and enforcement of

the Worker Protection Standard. EPA stated that it planned to review the

implementation and enforcement of the Standard at the state level to

confirm that there is national consistency. As of November 1999, this effort

was still in the planning stages. However, we found that EPA’s regions have

been inconsistent (1) in whether they set goals for the number of worker

protection inspections states should conduct, (2) in defining what

constitutes a worker protection inspection, and (3) in the extent to which

they oversee and monitor the states’ implementation and enforcement of

the Standard.

The implementation and enforcement of pesticide requirements, including

the Worker Protection Standard, are primarily carried out by the states

under cooperative agreements with EPA. The agency has developed

guidance for the states to use in reporting their pesticide enforcement

activities to EPA under the cooperative agreements. Under these

agreements in fiscal year 1999, EPA provided the states with about $20

million (or about $400,000 per state, on average) to carry out pesticide

enforcement activities, of which $2 million was specifically allocated for

worker protection enforcement. EPA’s regional offices oversee the states’

activities under the agreements. The funds EPA provides cover

enforcement activities not only for worker protection but also for pesticide

uses in urban settings, among other activities. The ultimate use of these

funds among federal pesticide programs is determined by the states in

conjunction with EPA’s guidance.
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In fiscal year 1998, 5 states reported to EPA that they had conducted no

routine worker protection inspections, and 11 other states each reported

conducting fewer than 10 routine inspections under the cooperative

agreements with EPA.6 In addition to the inspections conducted under the

cooperative agreements, states can conduct additional worker protection

inspections using state resources. However, EPA regional officials told us

that they generally do not receive information on the number of inspections

conducted with state resources. Moreover, officials from several EPA

regions told us that worker protection enforcement is in its infancy in some

states and that the states had conducted few, if any, routine worker

protection inspections on their own.

We also found inconsistency amongEPA’s regions in whether they

negotiated goals for the number of routine worker protection inspections

that the states should conduct under the cooperative agreements.

Specifically, while three of EPA’s regions had established goals for the

number of routine worker protection inspections that states in their

regions should conduct, the remaining seven regions had not. Within the

three regions, the goals have established at least a minimum number of

routine worker protection inspections to be conducted under the

cooperative agreements. For example, beginning in fiscal year 1999, EPA’s

Atlanta region reached agreement that each of the eight states in the region

would conduct between 60 and 100 routine worker protection inspections

annually. These goals call for several of the states in the region to do many

more inspections than they have done in the past. In fiscal year 1998,

Alabama reported that it had conducted only five routine inspections under

its cooperative agreement, and Tennessee reported it had conducted four

such inspections. The remaining seven EPA regions had not negotiated

routine worker protection inspection goals, and according to officials from

several regions, it is up to the states to decide how to spend their federal

pesticide resources.

Besides the inconsistency in setting inspection goals, EPA was also

inconsistent in establishing minimum requirements for what constitutes a

worker protection inspection for reporting purposes under the cooperative

agreements. Officials from six regions told us that states have varying

interpretations of what constitutes a worker protection inspection for

6

EPA regional officials told us that one of the states that had reported doing no routine

worker protection inspections had actually conducted many such inspections but that these

inspections were reported under a different inspection category.
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reporting purposes. For example, as part of our analysis of the number of

worker protection inspections conducted under the cooperative

agreements during fiscal year 1998, we noted that Oklahoma had reported

conducting 174 such inspections, while New Mexico reported conducting 1

inspection. Officials in EPA’s Dallas region told us that the reason for this

variation is that some states report having conducted a worker protection

inspection if they asked a single question about worker protection during

an agricultural use inspection, while other states only report what they

consider to be comprehensive worker protection inspections. The Dallas

officials attributed this inconsistency to a lack of specificity about what

constitutes an inspection for reporting purposes under EPA headquarters’

guidance. Officials in four other EPA regions told us that they have

addressed this situation by developing regional guidance that for the

purposes of the cooperative agreements, calls for worker protection

inspections to cover all federal requirements contained in the Standard.

Although we obtained and analyzed data on the number of inspections

states reported for fiscal years 1996, 1997, and 1998, we are not including

this information in this report because of the concerns about the data’s

reliability for most regions.

We also found that EPA’s regions were inconsistent in the extent to which

they oversaw and monitored the states’ implementation and enforcement

of the Standard. During fiscal year 1998, three of EPA’s regional offices

limited their oversight of the states’ worker protection enforcement

programs to file reviews, meetings and discussions with state officials, and

mid- and end-of-year reports. No one from these regional offices

accompanied state officials on any worker protection inspections during

the year. For example, the FIFRA Enforcement Coordinator inEPA’s

Boston region told us that no regional representative had accompanied

state inspectors on any inspections and that the regional office was

unaware of what states check for when they conduct worker protection

inspections. When we inquired about inspection checklists for the states in

the region, regional officials said that the region did not have any and that

they were unsure whether the states in their region have inspection

checklists, although they told us that one state was developing a checklist.

In contrast, seven other EPA regions supplemented their file reviews by

accompanying state officials on at least some worker protection

inspections. Officials from one region told us that joint EPA-state

inspections are the best way to observe the adequacy and quality of a

state’s worker protection enforcement program. Many of the regions said

that resource constraints were the primary reason they conduct few, if any,

joint inspections.
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Finally, EPA’s regions had little or no information on the results of the

states’ worker protection inspections. We found that the regions did not

know how many and what types of actions the states had taken in response

to worker protection violations. Although the states report to EPA on the

number and types of actions (such as fines or warning letters) taken under

their pesticide enforcement programs, these statistics do not isolate the

number and types of actions that involved worker protection as opposed to

other pesticide requirements such as the proper labeling of pesticide

products. EPA’s Atlanta region, however, has developed a tracking system

that is intended to provide the region with statistics on actions states have

taken in response to worker protection violations.

Conclusions Exposure to pesticides can be harmful to humans, and farmworkers are

among the primary populations exposed to pesticides. Furthermore,

children are more vulnerable to the adverse effects of pesticides because

their bodies and internal organs are still developing. The ill effects of

pesticide exposure can range from acute symptoms, such as fatigue,

nausea, and skin rashes, to chronic effects, such as cancer, neurological

disorders, and paralysis. However, there is a paucity of information on the

extent of acute and chronic adverse health effects of pesticides on humans.

While EPA and others are sponsoring research on the adverse chronic

effects of pesticides, it will likely be years, or even decades, before the

precise extent and nature of these chronic effects of pesticide exposure on

humans are known. Nevertheless, there are shorter-term steps that can be

taken to quantify, analyze, and reduce the incidence of pesticide illnesses.

These steps would benefit not only farmworkers and their families but the

general population as well. Without a valid means of monitoring acute

pesticide illnesses, there is no way to determine whether risk assessment

and management practices are effective in preventing hazardous exposure

incidents. Farmworkers depend on the implementation ofEPA’s Worker

Protection Standard to safeguard them from the adverse effects of

pesticide exposure. However, an important part of the Standard—its entry

intervals—was not designed for children below 12 years of age, who are

more vulnerable to the adverse effects of pesticide exposure; and while

EPA has concluded that the Standard’s entry intervals adequately protect

children who are 12 years of age or older, it has not completed

documenting its analysis supporting this conclusion. Finally, EPA has little

assurance that the protections called for in the Standard are being

adequately implemented for adults or children.
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Page 24 GAO/RCED-00-40 Pesticide Safety for Farmworkers

Recommendations To better understand the overall risks that pesticides pose for farmworkers

and their families as well as for the general public, we recommend that EPA

work with the National Institute for Occupational Safety and Health and

the National Center for Environmental Health to implement their

suggestions for improving the quality of information on acute pesticide

illnesses in the nation, including establishing time frames, assigning

responsibilities, and identifying resource needs and sources to accomplish

this important objective.

We also recommend that the Administrator of EPA take the following

actions:

• Identify and expeditiously implement steps to mitigate the potential

adverse effects of pesticide exposure on children below the age of 12

who work in agriculture or are otherwise present in pesticide-treated

fields. Such steps might range from warning farmworker parents about

the adverse effects that agricultural pesticides may have on their young

children to having pesticide labels clearly state that children should not

enter pesticide-treated agricultural areas for specified periods.

• Complete the documentation supporting EPA’s conclusion that the

Worker Protection Standard’s entry intervals adequately protect

children 12 years of age and older, and provide the documentation to the

Children’s Health Protection Advisory Committee for its review.

• Improve EPA’s oversight of the states’ implementation and enforcement

of the Worker Protection Standardby, among other things, (1) clearly

defining what constitutes a worker protection inspection for the

purposes of the cooperative agreements, (2) establishing goals for the

minimum number of worker protection inspections that states should

conduct annually under their cooperative agreements, (3) examining

whether the resources states dedicate for this function under the

cooperative agreements are adequate to achieve the goals established,

(4) clarifying the roles and responsibilities of EPA’s regional offices to

ensure consistency in their oversight of the program, and (5) taking the

necessary steps to obtain and analyze data on the results of the states’

worker protection inspections, including the number and types of

actions taken in response to worker protection violations.

Agency Comments and

Our Evaluation

We provided EPA with a draft of this report for its review and comment.

EPA provided a written response, which is included as appendix II. In

addition, we met with EPA officials including the Director, Health Effects
B-284152

Page 25 GAO/RCED-00-40 Pesticide Safety for Farmworkers

Division, Office of Pesticide Programs. EPA generally agreed with our

findings and recommendations and noted that it appreciated our efforts to

understand national, regional, and state perspectives on the issues

discussed in the report. With regard to our specific recommendations, EPA

had the following comments:

• It strongly welcomes our recommendation to work with the National

Institute for Occupational Safety and Health and the National Center for

Environmental Health to expand and improve data collection and

reporting of pesticide-related illnesses.

• It agrees that it is important to fully assess whether farmworkers’

children are currently at risk and to address that risk. However, while

EPA’s comments identified a number of actions it is taking generally

related to this issue, it did not identify specific actions it plans to take

directly related to the adequacy of theWorker Protection Standard for

children under 12 years of age who work in agriculture or who are

otherwise present in pesticide-treated fields. We are concerned that this

lack of specificity will allow young children to remain at risk.

• It agrees with our recommendation to complete the documentation

supporting its conclusion that the Standard’s entry intervals adequately

protect children 12 years of age and older. EPA officials told us that they

anticipate providing the documentation to the Children’s Health

Protection Advisory Committee in 2000.

• It believes that our recommendation on the implementation of the

Worker Protection Standard is consistent with what EPA has found in

looking into the implementation of the Standard. However, EPA did not

specifically address how it plans to implement the detailed steps laid out

in our recommendation.

EPA also provided technical comments that have been incorporated in the

report, as appropriate.

We conducted our review from June 1999 through February 2000 in

accordance with generally accepted government auditing standards. See

appendix I for our scope and methodology.

As arranged with your offices, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 30 days after the

date of this letter. At that time, we will send copies to other congressional

committees with jurisdiction over EPA pesticide programs and to the

Honorable Carol M. Browner, Administrator, EPA. We will also make copies

available to others on request.
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Page 26 GAO/RCED-00-40 Pesticide Safety for Farmworkers

If you have any questions about this report, please call me at (202) 512-

6111. Key contributors to this report are listed in appendix III.

Peter F. Guerrero

Director, Environmental

Protection Issues
Page 27 GAO/RCED-00-40 Pesticide Safety for Farmworkers
Page 28 GAO/RCED-00-40 Pesticide Safety for Farmworkers

Appendix I

Scope and Methodology AAppenednxidxeIis

To determine what federal requirements govern the safe use of pesticides,

particularly as they relate to protecting children in agricultural settings, we

reviewed the Federal Insecticide, Fungicide, and Rodenticide Act and

specifically the Environmental Protection Agency's (EPA) Worker

Protection Standard. Additionally, we examined the Federal Food, Drug,

and Cosmetic Act as amended by the Food Quality Protection Act. In doing

so, we reviewed the petition that the Natural Resources Defense Council

and other groups submitted to EPA requesting that farm children be

designated as a major identifiable subgroup for setting pesticide tolerances

for foods. We also reviewed comments from agricultural groups on the

petition. Finally, we reviewed EPA's procedures for assessing residential

pesticide exposures to determine howEPA is better accounting for farm

children's exposure.

To establish what information is available on both the acute and chronic

effects of agricultural pesticide exposure, particularly on children, we (1)

evaluated data sources that EPA uses to analyze acute illnesses related to

pesticides and (2) reviewed current research literature on the chronic

effects of pesticide exposure. We also obtained information from leading

researchers currently studying pesticide illnesses, including

representatives from EPA; the National Cancer Institute and the National

Institute for Environmental Health Sciences (both part of the National

Institutes of Health); the National Institute for Occupational Safety and

Health and the National Center for Environmental Health (both part of the

Centers for Disease Control and Prevention); and academic research

centers, including the University of Washington and the University of

California at Berkeley. We also interviewed officials from several offices at

EPA headquarters, most of which were within the Office of Prevention,

Pesticides, and Toxic Substances, Office of Pesticide Programs. Because

the National Institute for Occupational Safety and Health is the federal

agency responsible for conducting research on occupational disease and

injury, we obtained its analysis of the strengths and limitations of the

current pesticide reporting systems as a whole and with regard to

agricultural workers. We also obtained suggestions from the National

Center for Environmental Health on improving the reporting of pesticide

illnesses and injuries that are not associated with work.

To evaluate the adequacy of the Worker Protection Standard, particularly

as it pertains to children, we obtained documents on the issuance and

revisions of the Standard. Our documentary review included EPA's

response to public comments on the proposed Worker Protection

Standard; EPA's National Dialogue on the Worker Protection Standard,
Appendix I

Scope and Methodology

Page 29 GAO/RCED-00-40 Pesticide Safety for Farmworkers

March 1997; a Worker Protection Standard evaluation conducted byEPA's

Seattle regional office; a number of states' worker protection inspection

checklists; and other guidance material. We also interviewed the Chairman

and other representatives of the Children's Health Protection Advisory

Committee about its recommendation that EPA evaluate the Standard to

determine whether it effectively protects children's health. We met with

officials from EPA's Health Effects Division to obtain information on the

development and reassessment of the Standard. We reviewed documents

on how EPA currently formulates entry intervals to protect farmworkers.

Finally, to determine whether children were, in fact, being employed as

farmworkers or were present in the fields for other reasons, we analyzed

data provided by (1) the Department of Labor's National Agricultural

Workers Survey, (2) the Department of Labor's Wage and Hour Division,

and (3) a survey conducted by the Association of Farmworker Opportunity

Programs for the National Cancer Institute.

To assess the status of worker protection implementation, we interviewed

and obtained information from officials in EPA's Office of Enforcement and

Compliance Assurance on its guidance to EPA's regions about overseeing

the states' worker protection enforcement programs. (For the purposes of

this report, “states” include all 50 states, the District of Columbia, U.S.

territories, and Native American tribes.) We conducted interviews with the

officials responsible for the implementation and oversight of the worker

protection program in each of EPA's 10 regional offices. We also obtained

data on the number and comprehensiveness of worker protection

inspections conducted by the states.We reviewed the quality and

consistency of EPA regions' oversight of the states' implementation of the

Worker Protection Standard by determining the extent to which regional

officials had accompanied state personnel on worker protection

inspections and by determining whether EPA's regions had any information

on the results of state inspections. Finally, we accompanied representatives

from the Virginia Department of Agriculture and Consumer Services on two

worker protection field inspections.

We conducted our review from June 1999 through February 2000 in

accordance with generally accepted government auditing standards.
Page 30 GAO/RCED-00-40 Pesticide Safety for Farmworkers

Appendix II

Comments From the Environmental

Protection Agency ApendxiI
Appendix II

Comments From the Environmental

Protection Agency

Page 31 GAO/RCED-00-40 Pesticide Safety for Farmworkers
Appendix II

Comments From the Environmental

Protection Agency

Page 32 GAO/RCED-00-40 Pesticide Safety for Farmworkers
Appendix II

Comments From the Environmental

Protection Agency

Page 33 GAO/RCED-00-40 Pesticide Safety for Farmworkers
Page 34 GAO/RCED-00-40 Pesticide Safety for Farmworkers

Appendix III

GAO Contact and Staff Acknowledgments ApendxIi

GAO Contact Chuck Barchok, (202) 512-3548

Acknowledgments In addition to the individual above, Patricia J. Manthe, Richard A. Frankel,

Donald J. Sangirardi, Gopaul E. Noojibail, and Richard P. Johnson made

key contributions to this report.

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