MIGRANT CLINICIANS NETWORK

“A FORCE FOR JUSTICE IN HEALTHCARE FOR THE MOBILE POOR” 

PO BOX 164285 + AUSTIN, TEXAS 78716 + (512) 327-2017 + (512) 327-0719 FAX + (800) 825-8205 TOLL FREE

December 15, 2009 

Debra Edwards, PhD 

Director 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

1200 Constitution Avenue N.W. 

Washington, DC 20460 

Re: Requiring that Pesticide Labels be Available in Spanish 

Dear Dr. Edwards: 

Currently pesticide labels are only required to be in English. This policy has a disproportionate 

impact on foreign-born pesticide applicators who primarily speak Spanish, with little or no 

ability to speak or read English. As a consequence, they cannot read the pesticide labels and do 

not understand the pesticide use directions, the personal protective equipment (PPE) required or 

the instructions to avoid contamination of water bodies. The current provision, which directs 

Spanish-speaking handlers to get the label translated themselves, is grossly inadequate. Without 

the benefit of foreign language labels and comprehensive training in a language and manner they 

understand, these pesticide applicators are ill-equipped to protect themselves, others, or the 

environment. 

For farmworkers, this is an environmental justice concern and it underscores an obvious gap in 

worker protection to which the EPA should respond immediately. At recent Pesticide Program 

Dialogue Committee meetings, several representatives have mentioned this environmental justice 

concern, but have not been offered an Agency-initiated response or solution. We are writing to 

formally request an Agency solution that requires pesticide manufacturers selling products in the 

United States to offer Spanish-language labels. 

 

There are an estimated 2.5 million hired farmworkers in the United States, hundreds of thousands 

of whom mix, load, or apply pesticides. According to the National Agricultural Worker Survey 

(NAWS), 81% of farmworkers reported Spanish as their native language and 53% of the 

farmworkers said they can not speak, read, or write English. In a study of 195 pesticide handlers 

who were participating in the Washington State cholinesterase monitoring program from 2006-

2008, only 29% reported being able to read in English but nearly all of the participants were able 

to read in Spanish to at least some degree, though most (56%) reported having a primary school 

education or less (Hofmann et al. 2009). 

Manufacturers of pesticides routinely translate their labels into Spanish and many other 

languages in order to sell them worldwide. Restricted use pesticides (RUPs) sold in Puerto Rico 

come with Spanish-language labels. As such it would not be difficult for pesticide manufacturers 
to label all agricultural use products with an EPA-approved label that has been translated into 

Spanish (or a number of other languages). 

The EPA has previously resisted requests that it require foreign-language labels on the grounds 

that it would cost the agency too much time and effort to review and approve each translation. 

Ensuring that labels carry appropriate translations could be accomplished, however, without 

requiring an EPA review of each translation. Once the English-language label has been 

approved, the agency could require that any company which uses a label in a different language 

must first attest that its translation is true and accurate compared to the EPA-approved English 

language version. The agency would then only have to review a sample of the translated labels. 

This system should be acceptable in this instance, because the manufacturers would have no 

incentive to use anything other than an accurate translation of the approved label. Of course, any 

translation found to be misleading or inaccurate would be viewed as misbranding and result in a 

violation of the Federal Insecticide, Fungicide and Rodenticide Act. 

In sum, there is a great need for Spanish-language labels, many pesticide manufacturers already 

produce such labels for the world market, and the agency could approve these labels with 

relatively little effort. As such, we request that the EPA permit pesticide manufacturers to begin 

selling products in the United States with Spanish-language labels as soon as possible. We would 

be glad to meet with you at your earliest convenience to discuss this further. Please contact Amy 

Liebman at 410-860-9850/ aliebman@migrantclinican.org or Virginia Ruiz at (202) 293-5420/ 

vruiz@farmworkerjustice.org. 

Sincerely, 

Amy K. Liebman, MPA 

Director of Environmental and Occupational Health 

Migrant Clinicians Network 

 

Virginia Ruiz 

Senior Attorney 

Farmworker Justice 

Dona Hippert 

President 

Oregon Toxics Alliance 

Margaret Reeves, PhD 

Senior Scientist 

Pesticide Action Network North America 

Anne Katten, MPH 

Pesticide and Work Safety Project Director 

California Rural Legal Assistance Foundation 
Carol Dansereau 

Farm Worker Pesticide Project 

Jeannie Economos 

Pesticide Safety and 

Environmental Health Project Coordinator 

Farmworker Association of Florida 

cc: Lisa Jackson, Administrator, US Environmental Protection Agency 

Stephen Owens, Assistant Administrator, Office of Prevention, Pesticides & Toxic Substances, 

US Environmental Protection Agency 

Sources: 

U.S. Department of Labor, Office of the Assistant Secretary for Policy, Office of Programmatic Policy. (March 

2005). Findings from the National Agricultural Workers Survey (NAWS) 2001 - 2002. A Demographic and 

Employment Profile of United States Farm Workers. Research Report No. 9. accessed on 11/14/2009 at 

http://www.doleta.gov/agworker/report9/toc.cfm 

Hofmann J, Checkoway H, Borges O, Servin F, Fenske R, Keifer M. (2009). Development of a computer-based 

survey instrument for organophosphate and N-methyl-carbamate exposure assessment among agricultural pesticide 

handlers. Paper submitted.