FACA Mombers; 

Melanie A. Many. Ph.D.. Chair 

CalIEPA,Offlce of Environmental Wealth 

Hazard Assessment 

1515 Clay St. 16IhFloot 

Oakland CA 94812 

(510)622-3154 

Henry Anderson. M.Q. 

John Balbus. M.D., MPH 

Sophie Balk, M.D. 

MS.BBatriz Barara-Roppe 

Ms. Claire Earnetl 

Mr. Angelo Bellorno 

Patricia Buttefleld, R.N.. Ph.0. 

David Carpenter, M.O. 

Ms. Shelly Davis, Esq. 

Mark Dickie. Ph.D. 

Maureen Edwards. M.D. MPH 

Natalie Freeman. M.D., Ph.D. 

Howard F~mkh.M.D., Ph.D. 

Gary Glwburg, Ph.0. 

Daniel A. Goldstein. M.D. 

Mr. Richard J. Ha&mm 

Wwdle Kessel, M.D. 

Mr. Robert Leidich 

Janet Mo$towy 

LouIYles Sotode Lautido, Ph.D..MPH 

William Sanders. Ph.D. 

Ms. Susan West M'armagas 

Charles Yarborough, hl.D., MPH 

November 15,2005 

Stephen L. Johnson, Administrator 

United States Environmental Protection Agency 

Ariel Rios Building 

1200 Pemsylvania Avenue, N.W. 

Washington, DC 20460 

RE: Kccommendations Regarding Protecting Farmworker 

Children From Exposure to Pesticides 

Dear Administrator Johnson: 

The Children's Health Protection Advtsory (CHPAC) recently 

conducted a review of pesticide-related health risks to the children of 

farmworkers. We began by reviewtag prcvlous CHPAC letters to the 

EPA (including FACA to EPA correspondence from 1.999)and then 

focused on research and policies addressing: 1) exposures levels in 

pregnant women and children, 2) pesticide residues in homes and 

cars, 3) pesticide drift, 4) the Worker Protection Standard (WPS),and 

5) gaps in research (see Attachment 1). From this information we 

concluded that fannworker chtldren are not adequately protected and 

that a number of risk-reduction actions can be taken now. We also 

found areas where scientific evidence is laclung and recommend that 

EPA support addttional research in targeted areas of inquiry. In 

conducting our review, we also came to the conclusion that children 

are best protected through primary prevention measures. We urge the 

EPA to support agricultural practices that use fewer pesticides, less 

toxic pesticides, and alternatives to pesticides. We also encourage the 

EPA 'to involve all stakeholders (e.g., pesticide manufacturers, 

growers, and workm) in the development of strategies aimed at 

reducing risks to fannworker children and pregnant women. 

The CHPAC's recommendations fall into two categories, short-term 

and long-term. Short-term recommendations focus on strengthening 

the WPS, and reducing exposures from pesticide drift. 

Our long-term recommendation focuszs on reducingdatagaps 

through research. 
JRN-20-1996 06:06 .....-.-7-"-."A "-.".,"A* 

No.vember 15,2005 

Page 2 

A. Stren~theningthe WPS 

The Worker Protection Standard (WPS) sets forth grower responsibilities for pesticide 

safety requirements to protect farmworkers and then children from exposure. In 

reviewing WPS policies and implementation issues, thc CI-IPAC concluded that much 

more can be done to reduce risks to farmworker children. Our recommendations can be 

implemented today, and include: 

1. Training to Modifv Worker Behaviors: The WPS requires that workers receive 

training every five years. The CHPAC believes this is inadequate and 

recommends that training be provided annually to both field workers and 

pesticide handlers. Training should be expanded to include information about take 

home exposure pathways, risks to family members from take home exposures, 

pesticide toxicity, and health risks to infants, children, and pregnant women. 

Workers also need to be educated about practical risk reduction actions (e.g., 

changing clothes andshowering before going home) and how these actions can 

help protect their family. 

2. Hazard Communication: EPA is considering adding hazard communication 

information to the WPS. We endorse this concept and suggest that workers be 

provided with a simplified safety handout addressing: 1) the short- and long- term 

health effects of pesticides used at that particular workplace, 2) safety precautions 

(e.g., restricted entry intervals) and 3) first aid information. This brochure should 

be provided by pesticide manufacturers, and be linyisticatly-. culturally-, and 

educationally-appropriate for farmworkers. The use of pictograms and other 

low-literacy health information techniques should be investigated. 

3. Access to Ch6ning Facilities at the Work Site: Because most fans lack places 

for workers to wash or change their clothes, pesticide residue remains on workers' 

hair, olocbes and shoes when they return home. Children can be exposed to 

pesticide residue when they hug their parents at the end of a work day. Providing 

workers with a place to wash and change clothes before reming home will help 

protect their children from pesticide Exposure. Employers should be required to 

provide farm workers with an area to store clean clothes, change clothes and 

shoes, and wash, so that pesticides will not be carried from work to home. These 

washing areas provide a logical place for permanently displaying safety 

information that shows workers that prstecting themselves is part of protecting 

their children. 

4. 

and Auwlying: Under current policy, farmworkers must be at least 16 to mix, load 

and apply toxicity category I and I1 pesticides. However, some categories UI or 

IV pesticides have been associated with long-term health effects, including cancer 

or adverse reproductive effects. In 2000, the National. Institute of Occupational 

Safety and Health recommended that the Secretary of Labor designate all 

pestictde handling activities as "hwardous" m order to prevent farmworker 
JAN-20-1996 06' 06 -- -.. November tS, 2005 

Page 3 

children under age 16 from engaging in such activtties. We recommend that the 

EPA adopt this NIOSH recommenclation. Because growth and development of 

many organ systems continues into late .tedolesi;ence, we hope that EPA, with its 

fellow agencies, also will develop ways to enhance protection for the 16-20 year 

old age group. 

5. Ensure Young: Farmworkers: Resnirator~ Protection: Under OSHA's standard 

workers who use respirators must be medically cleared and have the respirator 

properly fitted to their face. For youth (ages 16 and older) who need to use a 

respirator, EPA regulations should be expanded to address respirator fit testing for 

famworkers. This change would provide farmworkers with the same level of 

protection that all other workers receive under OSHA. 

6. Stren9hm WPS Enforcement. Compliance with the WPS and the prohibition 

against children mixing, loading and applying certain pesticides needs to be 

improved'. However, states currently impose few penalties for violations of these 

provisions. Consequently, employers have little economic incentive to obey the 

law. For example, in California (often considered to have a strong state pesticide 

program), state data indicate that for the period 1997-2000, worker safe@ laws 

were violated in 41% of reported poisoning cases involving agricultural workers. 

Fines were issued for less than 20% of these violations, and the vast majority 

were for less than $400. Workers also rarely report violations because they fear 

employer retaliation. The CHPAC urges EPA to improve enforcement of the 

WPS and related safety laws. This should include a requirement that states issue 

meaningful fines for violations found, that complaints of worker poisoning or 

employer retaliation be prioritized and ptomptly and thoroughly investigated, and 

that EPA issue an annual report summarizing enforcement activities (e.g., number 

and type of violations found, penalty imposed, if any, etc.). 

B. Reduciw Exposures from Pesticide Drift 

Children living in agricultural areas are potentially exposed to drift at home and at 

school. Child protective policies need to consider the evolving science addressing 

pesticide drift as well as the realities of field work, living condihons, cumulative 

exposures, and the proximity of agriculture fields lo housing, schools and day care 

settings. By taking preventive actions to protect farmworker ch~ldren, all children may 

be protected as well. 

Further work is heeded to understand the effects of secondary as well as drift. 

To date EPA's models have focused primarily on modeling dispersion patternsfrom 

primary drift (e.g., dispersion at the time of application); such models do not account for 

expasures to secondary drift(e,g., revolitalization andlor windblown dust) and thus 

underestimate exposure. 
Page 4 

1. Require prior notification of nesticide spravinq: All families, farmworker and 

non-farmworker alike, should be informed about spray drift that can potentially 

affect them. Requ~ring applicators to notify nearby people (~.e., all areas where 

children live, work, and play) of spraying will allow them to take risk reduchon 

actions (e.g., shutting windows, bringing children inside) if they so choose. Thcse 

types of common sense strateges can foster trust between growers and local 

residents as well as reducing risks to local children. The EPA should require 

notification of pesticide spraying as well as investigating ways to reduce the 

burden of notification on growers. 

2. Explore the effectiveness of no-sprav buffer zones: Preliminary evidence 

suggests that buffer zones around homes,schools, and parks may be childprotective. Mwy school distnicts have already adopted no-spray policies on 

district propen?es. Buffer zones around schools havc the potential to protect large 

numbers of children; their effectiveness should be evaluated. 

3. Develop and field-test comvrehensive drift models: It is critical to have pesticide 

drift models that focus on human health as well as ecologic risks. We recommend 

that EPA consider the development of new and/or expanded mod& that account 

for exposures from both primary and secondary pesticide drift. Models should be 

tested by comparing predicted drift to actual field measurements of drift. 

4. Develop svecific drift-control swate~ies: EPA should use current information to 

develop compound andlor classification-specific drift control strategies. Such 

strategies need to consider common types of application (e.g., aerial, air blast), 

spray release height, and meteorological conditions. h addition, the EPA should 

also require pesticide labels to include clear instructions on application in 

different types of wind and temperature conditions. Such information, based on 

modeling, should take into consideration the drift potential of that formulation. 

C. Reducine Data Gaos Thrauah Research 

While mindful of special considerations regarding human subjects protection related to 

intentional dosing and the applicability of the National Children's Study, the CHPAC 

makes the following research recommendations to obtain critical knowledge for informed 

decision making: 

1. Conduct research addressing the environmental transformation products of ~esticides: 

We do not understand the relationship between exposure to environmental 

transformation products of pesticides and measured human urinary metabolites. In 

addition, population-based metabolite data are lacking on children under age six, a 

potentially vulnerable age group. Research is undeiway that quantifies how much of 

a metabolite is athibutable to the parent compound as opposed to direct exposure to 

the environmental bl.ansformation product. This is a generalissue, but is particularly 

urgent in regards to organophosphates and their urinary metabolites. We want to 
JAN-20-1996 06:07 


November 15,2005 

Page 5 

encourage the continuation of this research with a wider range of chemicals especially 

other pesticides where the metabolites may be harmful. 

2. Examme the ahvsical-chemical aroaerties of pesticides that influence drift: Existing 

information can be used to take child protective actions now;however, additional 

research is needed to understand the health implications of pesticide drift. EPA 

should support additional technical research addressing the physical-chemical 

properties and other determinants of mobilization of pesticides and inerts. EPA also 

needs to support field research so that best practices to test pesticide drift in actual 

settings can be undwstood. 

3. Conduct rnethodolo~cal research addressing practical a~nroaches to data collection: 

Develop applied research methods to help us understand exposure, including stable 

and reliable biomltrkers in readily accessible biornedia such as saliva. These methods 

should be applicable to adults and children and should reduce the burden of data 

collecti~n,a limiting factor to understanding exposures. 

4. Examine aestlcide metabolism in arenatal and aost-parturn women in observational 

m:Research should focus on physiological vanations in pregnant, post-partum 

and nursing women and children. Compared with pregnant women, tecent studies 

have suggested an increase in post-parturn urinary metabohte levels. Additional 

observational research IS needed to determine whether this post-partum increase is 

reproducible and, if so, to understand the mechanism and implications of this 

phenomenon on children's exposure. 

5. Conduct research to identifv effective and accentable uersonal protective equi~ment 

Encourage and support research to develop PPE that is comfortable for 

workers including teens &d pregnant women. It i~.~uite possible that disposable 

protective clothing for example could be developed (or exists) which is far mare 

comfortable than impervious materials while still providing adequate protection. 

Similarly, eye, hand, and respiratory protection may be significantly addressed using 

more comfortable technology. 

6. Surmort the collection of data at relevant times durinc, the gowing. season: Exposure 

data collection needs to be timed to coincide with specific instances of pesticide 

application. Such research requires access to field sites, which is limited due to the 

inherently adversarial social context in which exposure research takes place. Thus, 

EPA sho~ldbuild and expand paherships to help enhance access and facilitate 

information flow (e.g., with growers and or oommunity-based groups). 

7. Conduct research on the best wavs to f~rov~de tncentives for mowers to im~lement 

changes in amicultural vractices: We recognize that primary prevention actions are 

the most effective way to protect children. Such actions include long-term changes in 

agricultural practice to reduce farmworker children's exposure to pesticides. Applied 

research is needed to understand how best to encourage long-term changes in 

agricultural practices. 
JAN-20-1996 06:07 


Administrator Johnson 

November 15,2005 

Page 6 

D. Conclusion 

Our revied provided evidence of the need for further actions to protect farmworker 

children from ptsticide-related health risks. Our recommendations focus on: II 

strengthening the WPS,2) reducing exposures from pesticide drift, and 3) reducing data 

gaps through research. Along with these recommendations, we also urge the EPA to 

concurrently pursue prevention initiatives aimed at reducing pesticide use in both 

farmworker housing and agricultural settings. Together, this child-protective agenda 

provides a strong foundation for comprehensive, pragmatic, and science-based policy 

development. We propose these ideas for yam consideration and look forward to your 

response. 

Sincerely, 

-

&lanie A. Ma@, Ph.D., Chair / 

Children's Health Protection Advisory Committee 

Cc: Susan B. Hazen, Acting Assistant Administrator for Prevention, Pesticides, and 

Toxic Substances 

Dt. William Sanders, Acting Director, Office of Children's Health Protection 

Ms. Joanne Rodman, Associate Director, Office of Children's Health Protection 
Attachment 1 

Materials Reviewed by CUPAC Pesticides Task Group in Preparing This Letter 

(does not include speakers' PowerPoint presentations) 

I 

I 

A. Relevant Historical CHPACEPA Correspondence 

1, Letter from Routt Reigart regarding EPA's science policy issue paper on 

Residential Exposure Assessments, being -- proaared as part of the im~lementation - 

of the Food ~uality Protection, ~ct (February 18,1996). 

Response letter ftom EPA to Routt Reigart regarding the implementation 

of the Food Quality Protection Act (FQPA) (March 25, 1999). 

2. Letter from Routt Reigart to Carol Browner offering additional comments on the 

Residential Exposure Standard Operating Principles (January 21,2000). 

3. Letter from Rouct Reigart to Carol Browner requesting clarification on how the 

Environmental Protection Agency (EPA) assesses risks to farmworkor children, 

and presenting recommendations for EPA's consideration to hrther protect 

children who are working in agriculture (October 20,2000). 

Response &om EPA to Routt Reigart on the October 20,2000 letter to 

Carol Browner requesting clarification on how the Environmental 

Protection Agency (EPA) assesses risks to farmworker children, and 

presenting recommendations for EPA's consideration to further protect 

children who are working is agriculture (January 9,2001). 

4. Letter from Melanie Marty to Christine Todd Whitman recommending the 

Agency undertake certain steps to address some of the remaining concerns raised 

by the GAO in it's report, Pesticides: Improvements Needed to Ensure the Safety 

of Fanworkers and Their Children GAORCED-00-40 (March 2000) ("GAO 

Repon") (March 29,2003). 

Response from Stephen L. Johnson, Assistant Administrator, to 

Melanie Marty regarding the CHPAC's recommendations for 

strengthening the WPS program (May 22,2003). 

5. Advisory Committee Regulatory Re-evaluation Repon - Office of Children's 

Health Protection, Report of the Children's Health Protection Advisory 

Committee to the U.S. Environmental Protection Agency Regarding the Selection 

of Five Regulations for Re-Evaluation, Submitted by Dr. J. Routt Reigatt, Chair 

Children's Health Protection Advisory Committee, May 28, 1998. 
B. Articles and Re~orts 

a. "Agricultural and Residential Pesticides in Wipe Samples from Famworker 

Family Residences In North Carolina and Virginia," Sara A. Quandt, Thomas A. 

Arcury, Pamela Rao, Beverly M. Snively, David E. Camann, Alicia M. Dam, 

Alice Y,Yau, JamA. Hoppin, and David S. Jackson, Environmental Health 

Perspectives, Volume 112, Number 3, March 2004. 

b. "Agricultural Task and Exposure to Organophosphate Pesticides Among 

Farmworkers," Gloria D.Coronado, Beti Thompson, Larkin Strong, William C. 

Grifith, and Ilda Mas, Environmel7tal Health Perspectives, Volume 112, Number 

2, February 2004 

c. "Assessing Exposure to Organopbophorus Pesticides by Biomonitoring in 

Epidemiologic Studies df Birth Outcomes," Larry L. Needham, Environmental 

Health Perspectives, Volume 113, Number 4, April 2005. 

d. "13iologically Based Pesticide Does Egtirnates for Children in an Agricultural 

Community," Richard A. Fenske, John C. Kisscl, Chensheng Lu, David A. 

Kalman, Nancy J. Simcox, Emily W.Allen, and Matthew C. Keifer 

Environmental Health Perspectives, Volume 108, Number 6, June 2000. 

e. "Correlating Agricultural Use of Organophosphates with Outdoor Air 

Concentrations: A Particular Concern for Children," Martha Harnly, Robert 

McLaughlin, Asa Bradman, Meredith Anderson, and Robert Gunier. 

Environmental Health Persepctives, Volume 113, Number 9, September 2005. 

f. "Cumulative Organophosphate Pesticide Exposure and Risk Assessment Among 

Pregnant Women Living in an Agn~ultural Community: A Case Study from the 

CHAbfACOS Cohort," Rosemary Castorina, Asa Bradman, Thomas E. McKone, 

Dana B. Barr, Martha E. Harnly, and Brenda Eskenazi, Environmental Health 

Perspectives, Volume 111,Number 13, October 2003. 

g. "Evaluahon of Take-Home Organophosphorus Pestride Exposure among 

Agricultural Workers and Their Children," Cynthia L. Curl, Richard A. Fenske, 

John C. Kissel, Jefe H. Shirai, Thomas F. Moate, William Griffith, Gloria 

Coronado, and Beti Thompson, Environmental Health Perspectives, Volume 110, 

Number 112, December 2002. 

h. "Epigenetic Transgenerational Actions of Endocrine Disrupters and Male 

Fertility,"Matthew D.Anway, Andrea $, Cupp, Mehmet Uzurncu, and Michael K 

Skinner. Science 3 June 2005: 1466-1469. 
i. Imidacloprid; Order Denying Objections to Issuance of Tolerance, and Final 

Order Imidacloprid; Pesticide Tolerance; Part W ,Final Rules, Federal Register, 

Wednesday, May 26,2004. 

j. "Organophosphate Pesticide Exposure in Fannworker Family Members in 

Western Nortb Carolina and Virginia: Case Cornpansons," Thomas A. Arcury, 

Sara A, Quandt, Pamela Rao, Alicia M. Doran, Bevcrly M. Snively, Dana B. Barr, 

Jane A. Hoppin, and Stephen W. Davis, Human Organization, Voluine 64, No. 1, 

2005, 

k. "Pesticides and Childhood Cancers," Julie C. Daniels, Andrew F. Olsharl, and 

David A. Savitz, Environmental Health Perspectives, Volume 105, Number 10, 

October 1997. 

I. "Pesticide Contamination Inside Fm and Nonfarm Homes," Brian D. Cumin, 

Misty J. Hein, Wayne T. Sanderson, Marcia G. Nishioka,Stephen J. Reynolds, 

Elizabeth M. Ward, and Michael C. Alavanja, Journal of Occupational and 

Environmental Hygiene, 2:357-367, July 2005. 

m. "Pesticides in Household Dust and Soil: Exposure Pathways for Children of 

Agricultural Families," Nancy 5. Simcox, Richard A. Fenske, Sarah A. Wolz, IChwen Lee, and David A. Kalman, August 1995. 

n. "Pesticide Take-Home Pathway Among Children ofAgncultura1 Workers: Study 

Design, Methods and Baseline Findings," Beti Thompson, Gloria D. Corcnado, 

Julia E. Grossman, Klaus Puschel, Cam C. Solomon, nda Islas, Cynthia L, Curl, 

Jeffry H. Shirai, John C. Kissel, and Richard A. Fenske, Journal of Occupational 

Environmental Medicine, Volume 45, Number I, 42-53, January 2003. 

o. "Potential Exposwe and Health Risks of Infants.Following Indoor Residential 

Pesticide Applications," Richard A. Fenske, Kathleen G. Black, Kenneth P. 

Elkner, Chomg-Li Lee, Mark M.Methner, and Ralph Soto, Volume 80, Number 

6, AJPH June 1990. 

p. Report on the National Assessment of EP&S Pesticide Worker Safety Program, 

US. Environmental Protecciorl Agency, Ofice of Pesticide Programs, 

Washingtotl, DC,m.e~a.~ov/pesticides, undated. 

q. "eporting Pesticide Awmrnent Results to Farmworker Families: Development, 

Implementation, and Evaluation of Risk Communication Strategy," Sara A. 

Quandt, Alicia M.Doran, Pamela Rao, Jane A. Hoppin, Beverly M. Snively, and 

Thomas A. Arcq, Environmental Health Perspectives, Volume 112, Number 5, 

April 2004. 

r. "Secondhand Pesticides, Airborne Pesticide Drift in California," Susan Kegley, 

h e Katten, Marion Moses, Pesticide Action Network, California Rural Legal 
JAI.I-~~-~~~~-..~~:~!?LV~ ronnron 


November 15,2005 

Page 10 

Assistance Foundation, Pesticide Education Center and Californians for Pesticide 

Reform. Q 2003, Pesticide Action Network North America. 

s. "United States General Accounting Office Rcport to Congressional Requesters: 

Pesticides, improvements Needed to Ensure tho Safety of Farmworkers and Their 

Children," US GAO, March 2000. 

t. "Urinary and Handwipe Pesticide Levels Among Farmers and Nonfarmers in 

Iowa," Brian D. Curwin, Misty J Hein, Wayne T. Sanderson, Dana B Ban, Dlck 

Heederik, Stephen J. Reynolds, Elizabeth M. Ward, and Michael C. Alavanja, 

Journal of Exposure Analysis and Environmental Epidemiology, 2005, 1-9. 

u. "Work Characteristicsand Pesticide Exposurcs among Migrant Agricultural 

Families: A Community-Based.ResearchApproach," Linda A. McCauley, 

Michael R. Lasarev, Gregory Higgins, Joan Rothlein, Juan Muniz, Caren Ebbert, 

Jacki Phillips, Environmental Health Perspectives, Volume 109, Number 5, May 

2001. 

V. Workshop on Environmental Exposures Among Migrant Farnl Worker Children: 

Research Needs, Stone Mountain, Georgia, February 25-26,2003, Record of the 

Proceedings, convened by tfie US. BPA and Centers for Disease Canttol and 

Prevention. 

TOTRL P .I3