FACA Mombers; MelanieA. Many. Ph.D.. Chair CalIEPA, Offlce of Environmental Wealth HazardAssessment 1515 Clay St. 16IhFloot Oakland CA 94812 (51 0) 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. RichardJ. 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 

### StatesEnvironmental Protection Agency Ariel Rios Building 1200Pemsylvania Avenue, N.W. Washington,

### DC 20460



### RE: Kccommendations Regarding ProtectingFarmworker Children From Exposure to Pesticides

Dear Administrator Johnson:


### The Children's Health Protection Advtsory (CHPAC) recently conducted a review ofpesticide-related health risks to the children of farmworkers. We began by reviewtagprcvlous CHPAC letters to the 

### EPA (includingFACA 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 informationwe concluded that fannworker chtldren are not adequatelyprotected and that a number ofrisk-reduction actions can be taken now. We also found areas where scientificevidence is laclung and recommend that EPA support addttionalresearchin targeted areas of inquiry. 

### In conducting our review, we also 

### came 

### to the conclusion that children 

### are best protected through primary prevention measures. 

### Weurge 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 recommendationsfall 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~thening the WPS
The Worker Protection Standard (WPS) sets forth grower responsibilities for pesticide safety requirementsto 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 trainingbe 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 safetyhandout addressing: 1) the short- and long- term health effects ofpesticides used at that particular workplace, 

### 2) safetyprecautions (e.g., restricted entry intervals) and 3) first aid information. This brochure should be provided by pesticide manufacturers, and be linyisticatly-. culturally-, and educationally-appropriatefor farmworkers. The use ofpictograms and other low-literacy health information techniques should be investigated.


### 3. Access 

### to Ch6ning Facilities 

### atthe Work Site: Because most fanslack 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 reminghome 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 ofprotecting 

### their children.
4. and Auwlying: Under current policy, farmworkers must be at least 

### 16to mix, load and apply toxicity category 

### I and 

### I1pesticides. However, some categories

### UI or 

### IV pesticides have been associated with long-term health effects, including cancer
or adversereproductiveeffects. In 2000, the National. Institute of Occupational 

### Safety and Health recommendedthat the Secretary of Labor designate all pestictde handling activities 

### as "hwardous" m order to prevent farmworkerJAN-20-1996 06' 06 

### -- -.. November tS, 2005 Page 3 children under age 16from engaging in such activtties. We recommend that the 

### EPA adopt this 

### NIOSH recommenclation. Because growth and developmentof many organ systems continues into late .tedolesi;ence,we hope that 

### EPA, with its fellow agencies, also will develop ways to enhanceprotection 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 shouldbe 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 applyingcertain pesticides needs to be improved'. However, states currentlyimpose few penalties for violations of these provisions. Consequently, employers have little economic incentiveto obey the law. For example, in California (often considered to have a strong statepesticide program), state data indicate that for the period 1997-2000,worker safe@laws
were violated 

### in 41% ofreportedpoisoning cases involving agriculturalworkers. Fines were issued for less than 20% ofthese violations, andthe vast majority were for less than $400. Workers also rarely report violations because they fear employerretaliation. The CHPACurges EPA to improve enforcement ofthe WPS 

### and related safety laws. This should include a requirement that states issue meaningful fines for violations found, that complaints 

### of worker poisoning or employerretaliation be prioritized 

### and ptomptly and thoroughly investigated, and that EPA issue 

### an annual report summarizingenforcement activities (e.g., number and type of violationsfound, penalty imposed, if any, etc.).


### B. Reduciw Exposures 

### from PesticideDrift Children living 

### in agricultural areas 

### arepotentiallyexposed 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 fieldwork, living condihons, cumulative exposures, and the proximity of agriculture fields lo housing, schools and day care settings. 

### By takingpreventive actions to protect farmworker ch~ldren, all children may be protected 

### as well.
Further work 

### is heeded to understand the effects of secondaryas well as drift. To date EPA's models have focusedprimarily on modeling dispersionpatternsfrom 

### primary drift (e.g., dispersion atthe 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, shouldbe informed about spray drift that can potentially affect them. Requ~ring applicatorsto notify nearby people (~.e., all areas where children live, work, and play) of spraying will allow them to take risk reduchon actions (e.g., shuttingwindows, 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 ofpesticide spraying as well as investigating ways to reduce the burden of notification on growers. 

### 2. Explore the effectiveness ofno-sprav buffer zones: Preliminary evidence suggests that buffer zones around 

### homes,schools, 

### andparks may be childprotective. 

### Mwy school distnicts have already adopted no-spray policies on district propen?es. Buffer zones around schoolshavcthe potential to protect large numbers of children; their effectiveness should be evaluated.


### 3. Develop and field-testcomvrehensivedrift 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 developmentof new and/or expanded mod& that account for exposures fromboth 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 informationto develop compound andlor classification-specific drift control strategies. Such strategies need to consider common types of application (e.g., aerial, airblast), sprayrelease 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 driftpotential of that formulation.
C. Reducine Data Gaos 

### Thrauah Research
While mindful of special considerations regardinghuman subjects protection related to intentional dosing and the applicability of the National Children's Study, the CHPAC 

### makes the following research recommendationsto obtain critical knowledge for informed decision making:
1. Conduct research addressingthe environmental transformation products of ~esticides: We do not understandthe relationship between exposure to environmental transformationproducts ofpesticides and measured human urinary metabolites. In addition, population-basedmetabolite data are lacking on childrenunder age six, 

### a potentially vulnerable age group. Research 

### isundeiway that quantifies how much of
a metabolite 

### is athibutable to the parent compound as opposed to direct exposure to the environmentalbl.ansformationproduct. This is 

### a generalissue, but is particularly urgent in regards to organophosphates and theirurinary metabolites. 

### We want toJAN-20-1996 06:07 November 15,2005 Page 5
encourage the continuation of this research with a wider range ofchemicals 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 sothat best practices to test pesticide drift in actual settings 

### can be undwstood.
3. Conductrnethodolo~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 accessiblebiornedia such as saliva.These methods should be applicableto 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 observationalresearch IS needed to determine whether this post-partum increase is reproducibleand, if so, to understand the mechanism and implications of this phenomenon on children's exposure.


### 5. Conductresearch to identifv effectiveand accentable uersonal protective equi~ment Encourage and support research to develop 

### PPE that is comfortable for workers includingteens &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, andrespiratoryprotection may be significantly addressed 

### using 

### more comfortabletechnology.


### 6. Surmort the collection of data at relevanttimes durinc,the gowing.season: Exposure data collectionneeds to be timed to coincide with specific instances of pesticide application. Suchresearch requires access 

### to field sites, which is limited due to the inherently adversarial social context in which exposureresearch takes place. Thus, 

### EPA sho~ld build and expandpaherships

### 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 amiculturalvractices: We recognize that 

### primary prevention actions are the most effectiveway 

### to protect children. Such actions include long-term changes in agriculturalpractice to reduce farmworker children's exposure to pesticides. Applied research is needed to understand how best to encourage long-term changes in agriculturalpractices.JAN-20-1996 06:07 Administrator Johnson November 15,2005 Page 6



### D. Conclusion
Ourrevied 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 initiativesaimed at reducing pesticide use in both farmworkerhousing 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 forwardto 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 ProtectionAttachment 1 Materials Reviewed 

### by 

### CUPAC PesticidesTask 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 sciencepolicy issuepaper on Residential ExposureAssessments, 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 ofthe Food Quality Protection Act (FQPA) (March 25, 1999).
2. Letter from Routt Reigart to Carol Browner offering additionalcomments on the Residential Exposure Standard OperatingPrinciples 

### (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 ProtectionAgency 

### (EPA) assessesrisks to farmworker children, and presentingrecommendations for 

### EPA's consideration to furtherprotect children who 

### are working isagriculture(January 9,2001).

4. 

### Letter from 

### Melanie Martyto Christine Todd 

### Whitman recommending 

### the Agency 

### undertake certain steps to address some of the remaining concernsraised by the GAO in it's report, Pesticides: ImprovementsNeeded 

### 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

### Martyregarding 

### the CHPAC's recommendations for strengthening

### the 

### WPSprogram (May 22,2003).

5. Advisory Committee Regulatory Re-evaluation Repon 

# - Office of Children's Health Protection, Report ofthe Children's Health Protection 

### Advisory Committee to the 

### U.S. Environmental Protection Agency Regarding the Selection ofFive Regulations for Re-Evaluation, 

### Submittedby 

### 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, 

### Jam A. 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, Environmel7talHealth 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 PesticideExposure and Risk Assessment Among Pregnant Women Living in 

### an Agn~ultural Community: A 

### Case Study

### from the CHAbfACOSCohort," Rosemary Castorina,Asa Bradman, Thomas 

### E. McKone, Dana 

### B. Barr, Martha E. Harnly, and Brenda Eskenazi, Environmental Health Perspectives, Volume 11 

### 1,Number 13, October 2003.



### g. "Evaluahon 

### ofTake-HomeOrganophosphorus 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 ofEndocrine 

### 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 PesticideExposure 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 StephenW. 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 ContaminationInside

### 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, SarahA. Wolz, 

### IChwen Lee, and David A. Kalman, August 1995.



### n. "Pesticide Take-Home Pathway Among Children ofAgncultura1Workers: 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.EnvironmentalProtecciorlAgency, 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," 

### SaraA. 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, PesticideAction 

### Network, California

### Rural LegalJAI.I-~~-~~~~-..~~:~!?LV~ ronnron November 15,2005 Page 10 Assistance Foundation, Pesticide Education Center and Californiansfor Pesticide Reform. Q 2003, Pesticide Action Network North America.

s. "United 

### States General Accounting 

### Office Rcport to CongressionalRequesters: 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 ExposureAnalysis and Environmental Epidemiology,2005, 1-9.



### u. "Work Characteristics

### and Pesticide 

### Exposurcs among Migrant Agricultural Families: 

### A Community-Based.ResearchApproach," Linda 

### A. McCauley, Michael R. 

### Lasarev, GregoryHiggins, 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, StoneMountain, Georgia, February 25-26,2003, 

### Record ofthe Proceedings, convenedby tfie 

### US.BPA and Centers 

### for Disease Canttol and Prevention.

TOTRL P .I3