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## COMMENTS FROM THE NATURAL RESOURCES DEFENSE COUNCIL On the Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticides with No Food Uses (EPA

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NRDC Supports this Policy to Protect Farm Children, the Children of Agriculture Workers, and Youth Agriculture Workers from Harmful Pesticides
On December 9, 2009 EPA announced in the Federal Register that it would accept public comments on its newly released Policy Paper Policy Paper on Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticid es with No Food Uses . The comment period was extended to April 12, 2010 (FR Notice Feb 5, 2010). More information can be found on the EPA website at: http://www.ep a.gov/pesticides/health/worker

- rsk

- assmnt.html

This forward

- thinking policy addresses the risks to agriculture workers and their children who have been shown to experience significantly higher pesticide ex posures than the average child. The policy extends the now

- established methods of conducting an aggregate and cumulative risk assessment from the general population to agriculture workers and their children. Specifically, the policy will require that when EPA assesses risks from pesticide exposure to agri culture workers and their children, EPA will now quantitatively include a calculation of the risks from aggregate exposures to the same pesticide used in multiple settings, the risks from cumulative exposures to multiple pesticides that share a common toxi c mechanism, and the ―unique risks posed to infants and children due to their potentially increased sensitivity to pesticides.‖ (Policy at 2)

. These factors (aggregate and cumulative exposure, and sensitive subpopulations) are already required by the Food Quality Protection Act (FQPA) of 1996 to be included in EPA‘s pesticide risk assessments.NRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 2 NRDC has been advocating that EPA include agriculture workers and their children as populations requiring specific consideration when assessing pesticide risks, because of their excessive exposure and the special vulnerability of children. In fact, o n Octo ber 22, 1998 NRDC and over fifty farmworker, environmental, conservation, public health, and labor organizations formally served a petition to EPA to identify farm children as a ―major identifiable subgroup‖ specially protected under the FQPA. 1 The FQPA re quires that EPA ensure to a ― ̳reasonable certainty‖ that ―no harm will result‘‖ to any children as result of their aggregate exposure to pesticide. 21 U.S.C. §346a(b)(2)(C)(ii)(I). The NRDC petition stated that FQPA provisions include farm children, who are particularly at risk from pesticide exposure. EPA denied that petition.
In 1998, NRDC published Trouble on the Farm: Growing Up With Pesticides in Agricultural Communities 2 and in 2004, NRDC published Hidden Danger: Environmental Health Threats in t he Latino Community
, 3 which discuss pesticide

- associated risks to farmworkers and their children. These reports reference scientific data showing that children living on and near farms may have substantially increased exposure to pesticides over other grou ps of children. These children represent a significant proportion of the population, and any tolerance that does not protect them cannot be found to provide ―a reasonable certainty of no harm‖ under the law.
We are pleased that this policy acknowledges t he scientific evidence and the legal requirement that agriculture workers and their families deserve and require better protection from exposure to dangerous pesticides

.

EPA Has Legal Authority to Protect Farm Children, the Children of Agriculture Workers, and Youth Agriculture Workers from Harmful Pesticides
EPA regulates pesticides under two statutes, the Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. § 346a and the Federal Fungic ide, Insecticide, and Rodenticide Act (FIFRA), 7 U.S.C. § 136 et seq. The Food Quality Protection Act of 1996 (―FQPA‖) significantly amended both the FFDCA and FIFRA by mandating that health

- based and child

- protective standards drive decisions about accept able levels of pesticide residues in food and the environment . Under that statute EPA has the legal authority to identify farm children as a ―major identifiable subgroup‖ specially protected under the Food Quality Protection Act

. The FQPA requires that EP A ensure to a ― ̳reasonable certainty‖ that ―no harm will result‘‖ to any children as result of their aggregate and cumulative exposure to pesticides. Specifically, the FQPA amended EPA‘s authority by requiring EPA: to ensure that there is a ―reasonable c ertainty that no harm will result‖ from dietary and certain other exposures to pesticide chemical residues, see 21 U.S.C. §§ 346a(b)(2)(A)(i)

- (ii); to account for the particular susceptibilities of and provide

1 Natural Resources Defense Council et al., Petition for a Directive that the Agency Designate Farm Children as a Major Identifiable Subgroup and Population at Special Risk to Be Pro tected Under the Food Quality Protection Act (1998)

2 Trouble on the Farm: Growing up with pesticides in agricultural communities. G. Solomon. Report of the Natural Resources Defense Council. 1998. Available at http://www.nrdc.org/health/kids/farm/farminx. asp

3 Hidden Danger: Environmental health threats in the latino community. A. Quintero and M. Quirindongo. A report of the Natural Resources Defense Council. 2004. Available at http://www.nrdc.org/health/effects/latino/english/contents.aspNRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 3 special safeguards for infants and children, s ee 21 U.S.C. §§ 346a(b)(2)(C); and to take into account available information concerning aggregate exposure levels and variability of sensitivities of ―major identifiable subgroups,‖ see 21 U.S.C. § 346a(b)(2)(D)(v i ). This command includes farm chil dren and the children of farmworkers, who are particularly at risk from pesticide exposure.

Specific Policy
We strongly support this policy, which will extend the aggregate and cumulative risk assessment methods that EPA has already established for food

- use pesticides to non

- food uses and occupationally

- related exposure scenarios. EPA describes the policy as follows:
Specifically, this will include use of an additional safety/uncertainty factor to protect children, and will also consider aggregate e xposures to pesticides from multiple sources and cumulative effects which may occur from exposure to multiple pesticides with a common mechanism of toxicity. Moreover, risks will be explicitly reported for individuals who had not been explicitly considered , specifically, workers age 12

- 17 and young children taken into agricultural fields while their parents work

. (Policy at 4)
What EPA is proposing to do in its policy is bold, but it is not new. The methods have been established by the EPA pesticide office (OPP) through a rigorous years

- long public vetting process that included multiple reviews by its Scientific Advisory Panel, multiple opportunities for public comment, and internal agency review. Fu rther, EPA‘s failure thus far to account for occupationally

- related exposures and specific exposure scenarios experienced routinely by young farm workers and the children of farm workers has left these populations at risk.

NRDC Specific Recommendations
These comments support the following recommendations as detailed in the comments of the Pesticide Action Network North America (PANNA), California Rural Legal Assistance Foundation, and Farm Worker Pesticide Project (FWPP). Specifically, we recommend the following:
Alternatives assessments should be conducted routinely

. EPA should a dd an alternatives analysis as a first step to all risk assessments that includes full consideration of reduced

- risk chemical and

non

- chemical alternatives. Any assessment of relative risks and benefits must take into full consideration the less

- toxic alternatives available for pest control to be meaningful and realistic.
Inclusion of an added safety factor should be the norm for pregnant women, young children and adolescents. We strongly support the inclusion of an additional safety/uncertainty factor to reduce and eliminate pesticide exposures in pregnant women and children of agricultural workers who can and do work in the fields or accompany their parents to work in the fie lds rather than stay at home unsupervised.
Neurotoxicity tests must be appropriate for evaluating effects on the young. Both currently registered pesticides, especially those with neurotoxic properties at any dose, and chemicals newly proposed for use as pesticides, should undergo obligatory evaluation forNRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 4 neurodevelopmental toxicity. 4 Neurotoxicity testing must include evaluation of prenatal, infant, and juvenile exposures, addressing the failure of current neurotoxicity testing to consider the critical windows for neurodevelopmental exposure because they are conducted with adult labor atory animals. New toxicity

- testing methods are being developed that will probably be quicker, less expensive, and more directly relevant to human exposures, as described in the NRC report Toxicity Testing in the 21st Century: A Vision and a Strategy (2007 ). 5 However, the NRC committee recognized that the realization of this promise is at least a decade away. 6
EPA must call for independent peer

- reviewed studies . EPA should routinely include independent toxicology studies) in pesticide risk assessments. S tudies conducted independently at academic or government institutions (in contrast to registrant

- conducted or funded studies) are published in the peer

- reviewed literature and available for public scrutiny.
Registrants should be required to develop pesti cide

- specific biomonitoring and diagnostic tests

. We urge US EPA to require that pesticide registrants, as a requirement for registration, develop and provide to the public a sensitive and specific diagnostic test and/or a biomonitoring tool for detection of each pesticide or its effects in human beings. EPA cannot effectively enforce its regulations or measure the efficacy of its mitigation measures if it cannot detect the material under consideration.
Children ages 12 to 17 must not be evaluated as adult s . Puberty is recognized as a critical or sensitive window of susceptibility to chemicals 7 particularly with respect to reproductive and endocrine disrupting effects. For example, exposure of rodents to high doses of some phthalates has been shown to dela y onset of puberty while pubertal dosing of two rat species with the phthalate DEHP has been shown to delay onset of puberty and caused testicular damage 8 and exposure to various chemicals can delay or accelerate onset of puberty in females. 9
Aggregate ex posure assessments should include assessments of inhalation and dermal exposures, including exposures in homes, daycare centers, or family vehicles from pesticide drift or from residues tracked in on workers‘ clothes. The targets of these exposures should include prenatal and infant exposure via consumption of breast milk.

4 Grandjean P and PJ Landrigan 2006. Developmental neuroto xicity of industrial chemicals. www.thelancet.com Vol 368 December 16, 2006. pp. 2167

- 2178.

5 Toxicity Testing in the 21st Century: A Vision and a Strategy . Committee on Toxicity Testing and Assessment of Environmental Agents, National Research Council, 216 pages, 2007.

6 Science and Decisions: Advancing Risk Assessment . Committee on Improving Ris k Analysis Approaches Used by the U.S. EPA, National Research Council, 478 pages, 2008.

7 Woodruff, TJ, et al. 2008. Proceedings of the Summit on Environmental Challenges to Reproductive Health and Fertility: executive summary. Fertility and Sterility_ Vol. 89, Supplement 1, February, pp. e1

- e20.

8 Noriega NC, Howdeshell KL, Furr J, Lambright CR, Wilson VS, Gray LE Jr. Pubertal administration of DEHP delays puberty, suppresses testosterone production, and inhibits reproductive tract development in male S prague

- Dawley and Long

- Evans rats. Toxicol Sci. 2009 Sep;111(1):163

- 78. Epub 2009 Jun 15. PubMed PMID: 19528224.

9 Woodruff, TJ, et al. 2008. Proceedings of the Summit on Environmental Challenges to Reproductive Health and Fertility: executive summary. Fer tility and Sterility_ Vol. 89, Supplement 1, February, pp. e1

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### 5 Cumulative risk assessments should incorporate modern approaches

. The National Academy of Sciences (NAS) National Research Council (NRC) published three very important new reports, which cover new science in risk assessment 10 , the feasibility and desirability of assessing the cumulative risks of multiple chemical exposur es 11 , and rapid and effective testing methods to assess inherent hazard 12 . The NRC report on Science and Decisions (2008) emphasized that there is a need for cumulative risk assessments as defined by EPA (EPA 2003), ―that include combined risks posed by agg regate exposure to multiple agents or stressors; aggregate exposure includes all routes, pathways, and sources of exposure to a given agent or stressor. Chemical, biologic, radiologic, physical, and psychologic stressors are considered in this definition.‖ 13 The NRC report points out that, ―although cumulative risk assessment has been used in various contexts, there has been little consideration of nonchemical stressors, vulnerability, and background risk factors‖ and recommends EPA seriously consider adopt ing the recommendations of the NRC report on phthalates (NRC, 2008) that, ―addresses issues related to the framework within which dose

- response assessment can be conducted in the context of simultaneous exposures to multiple stressors.‖ 14 The NRC report on Science and Decisions (2008) also emphasized that ―variability in human susceptibility has not received sufficient or consistent attention in many EPA health risk assessments... greater attention to susceptibility in practice is needed, particularly for spe cific population groups that may have greater susceptibility because of their age, ethnicity, or socioeconomic status.‖ 15 EPA should implement the recommendations of these NRC reports
More detail is needed on analysis of endocrine effects . EPA must make explicit how the agency will move forward on its analysis of endocrine disrupting effects and specifically address how it will take into consideration non

- linear dose responses and adverse health effects occurring at extremely low doses (e. g. parts per trillion) for which there is a growing body of scientific evidence. For example, pesticides, at extremely low levels, can interfere with the proper functioning of hormone systems including estrogen, androgens, thyroid, and the pituitary/hypoth alamic axis. When exposures, even at very low levels, coincide with critical windows of development, they may be more potent than higher dose exposures, or the low dose exposure may otherwise exert a non

- traditional dose

- response curve. The consequences of exposure to an endocrine disruptor may also be delayed with additive or synergistic effects from myriad chemical exposures. Data primarily from laboratory animal and cell culture studies have shown over 50 pesticides to have known or suspected endocrine d isrupting properties on the female reproductive system. 16
, 17

10 Science and Decisions: Advancing Risk Assessment . Committee on Improving Risk Analysis Approaches Used by the U.S. EPA, National Research Council, 478 pages, 2008.

11 Phthalates and Cumulative Risk Assessment: The Task Ahead . Committee on the Health Risks of Phthalates, National Research Council, 208 pages, 2008.

12 Toxicity Testing in the 21st Century: A Vision and a Strategy . Committee on Toxicity Testing and Assessment of Environmental Agents, National Research Council, 216 pages, 2007.

13 Science and Decisions: Advancing Risk Assessment . Committee on Improving Risk Analysis Approaches Used by the U.S. EPA, National Research Council, 478 pages, 2008.

14 Phthalates and Cumulative Ri sk Assessment: The Task Ahead . Committee on the Health Risks of Phthalates, National Research Council, 208 pages, 2008.

15 Science and Decisions: Advancing Risk Assessment . Committee on Improving Risk Analysis Approaches Used by the U.S. EPA, National Research Council, 478 pages, 2008.

16 Bretveld RW, et al. 2006. Pesticide exposure: the hormonal function of the female reproductive system disrupted? Reproductive Biology and Endocrinology, 4:30.NRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 6 Specific Comments on the Policy and Scientific Support for NRDC Recommendations

O ccupational exposures in general
The Policy requires EPA to consider risk posed to infants, children, and fetuses (pre

- birth exposures) from aggregate exposures to individual pesticides from all sources, including occupational exposures, as well as cumulative exposures to multiple pestici des. (Policy at 7) This includes occupationally

- related exposures through the parent as well as exposures from pesticides carried into the home, sc hool, or playground environment. (Policy at 7) We strongly support efforts to describe and calculate the impa ct of these real

- world exposures to the aggregate and cumulative pesticide burden that youth workers and the children of farmworkers experience.
Approximately one million children of farm workers live in the United States. More than 320,000 children und er the age of six live on farms in the United States. 18 Farm children, especially the children of farmworkers, come in contact with pesticides through residues from their parents‘ skin and clothing, soil and dust tracked into their homes, contaminated soil and other surfaces in areas where they play, food eaten directly from the fields, drift from agricultural pesticide applications, contaminated well water, and breast milk from exposed parents

. 19 These exposure routes can be very significant, even dominant, for these children.
A study by Lu et al (2000), reported on pesticide exposures in the children of agriculture families compared with non

- agriculture families. 20 Families were from Washington State, and included 109 children aged 9 months to 6 years old. Families included 49 applicator, 13 farm worker, and 14 non

- agriculture families. Pesticides were measured in household dust, on the children‘s hands, and in the children‘s urine. The authors report that the average pesticide metabolites in urine was five times higher in the agriculture children than in the non

- agriculture children (0.05 vs 0.01 ug/ml; P=0.09). Household dust was seven times more contaminated with pesticides in agricultural family homes than non

- agriculture family homes (1.92 v 0.27 ug/g; P<0.001). Pesticide applicator families had the highest house dust pesticide levels, followed by farmworker families. And, approximately 67% of the children from these families had detectable levels of pesticide metabolites in their urine, compared with 53% of the non

- agriculture children. The authors conclude that children who live with parents that work with agriculture pesticides or who live near pesticide

- trea ted farms are far more likely to be exposed to higher levels of pesticides in their home environment, compared with children from non

- agriculture families. 21 This

17 Diamant

i

- Kandarakis E et al. 2009 Endocrine

- Disrupting Chemicals: An Endocrine Society Scientific Statement. Endocrine Reviews 30(4):293

- 342

18 Trouble on the Farm: Growing up with pesticides in agricultural communities. G. Solomon. Report of the Natural Resources Defense Council. 1998. Available at http://www.nrdc.org/health/kids/farm/farminx.asp

19 Bradman A, Harnly ME, Draper W, Seidel S, Teran S, Wakeham D, Neutra R 1997. Pesticide exposure to children from California‘s Central Valley: results of a pilot study. J. Expo. Anal. Environ. Epidemiol. 7, 217

- 234

20 Lu C, Fenske RA, Simcox NJ, Kalman D. 2000. Pesticide exposure of children in an agricultural community: evidence of household proximity to farmland and take home exposure pathways. Environ res; 84: 290

21 Lu C, Fenske RA, Simcox NJ, Kalman D. 2000. Pesticide exposure of children in an agricultural community: evidence of household proximity to farmland and take home exposure pathways. Environ res; 84: 290NRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 7 substantial agriculture

- related exposure is in addit ion to the pesticides that they also enco unter in their food, drinking water, and any residential uses of pesticides (which is substantial since over half, 53%, the non

- agriculture children had urinary pesticide residues) .
A 2006 study of organophosphate pesticide metabolites in farmworker ch ildren‘s urine found that these children had much higher levels of organophosphate pesticide metabolites than the national average, as reported in the NHANES 1999

- 2000 study data. 22 Urine samples were collected from 60 children 1

- 6 yrs old whose parents wer e farmworkers in North Carolina. Many of the metabolite levels were approximately 2

- fold higher in these NC farmworker children, compared with the NHANES national average data. This study further confirms previous studies showing that farm worker children are exposed to more pesticides than other children.

Take

- home exposure from farmworker and applicator parents contributes significantly to pesticide residues in the homes, and eventually in the bodies of agriculture family children. 23 A 2002 study of 218 Washington State farmworker households reported on detectable pesticide residues in house dust, and dust from the vehicle used by farmworker parents to commute to and from work. The researchers found a significant correlation between the amount of pestici de reside in the parent‘s urine and their child‘s urine, providing evidence that the parent‘s occupational exposure was contaminating the children (r 2 = 0.18, p < 0.0001)

. This work shows that parent‘s occupational exposure to harmful pesticides is resulti ng in residential contamination and adding significantly to the levels of pesticide exposure in their children.
A study by Grandjean et al (2006) reported that Ecuadorian children whose mothers had worked in flower green houses with intensive pesticide use during pregnancy showed a significant elevation in lasting neurotoxic effects

. 24 This study evaluated 72 children, 37 of these children were from women who had been expos ed to pesticides during pregnancy. A group of tests were done on these children including psychomotor tests, tests of reflexes, intelligence tests, blood pressures and growth. It was found that children that had pesticide exposure in utero showed statistic ally significantly impaired visual

- spatial performance. These findings are in agreement with a 1998 study of children in Mexico whose developmental exposure to pesticides was associated with significant deficits in eye

- hand coordination, short

- term memory, and ability to accurately draw stick figures. 25

In a 2010 follow up of the Ecuador floriculture study by the same authors similar impacts of prenatal pesticide exposures were reported

. 26 In this study the authors selected 84 eligible

22 Arcury TA, Grzywacz JG, Davis SW, Barr D, Quandt S . 2006. Organophosphorus pesticide urinary metabolite levels of children in farmworker households in Eastern North Carolina. American Journal of Industrial Medicine. Sep; 49(9): 751

- 60

23 Curl C, Fenske R, Kissel J, Shirai J, Moate T, Griffith W, Coronado G, Thompson B. 2002. Evaluation of take

- home organophosphorous pesticide exposure among agricultural workers and their children. Environmental Health Perspectives. v 100 n 12 p a787

- 792

24 Grandjean P, Harari R, Barr D, Debes F. Pesticide exposure and stunt ing as independent predictors of neurobehavioral deficits in Ecuadorian school children. Pediatrics. 2006; 117; e546

- e556

25 Guillette EA, Meza MM, Aquilar MG, Soto AD, Garcia IE. An anthropological approach to the evaluation of preschool children exposed to pesticides in Mexico. Environ Health Perspect. 1998;106:347

– 353

26 Harari R, Julvez J, Murata K, Barr D, Bellinger DC, Debes F, Grandjean P. 2010 Neurobehavioral deficits and increased blood pressure in school

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### 8 participants, childre n who were exposed and not exposed prenatally to pesticides. The authors found prenatal pesticide (organophosphates) exposure was associated with deficits in motor speed (Finger Tapping Test), motor coordination (Santa Ana Form Board) visu al

- spatial perfor mance (Stanford

- Binet Copying Test) and visual memory (Stanford

- Binet Copying Recall Test). These associations corresponded to a statistically significant developmental delay of 1.5

- 2 years. The authors conclude that, ―These findings support the notion tha t prenatal exposure to pesticides

- at levels not producing adverse health outcomes in the mother

- can cause lasting adverse effects on brain development. Pesticide exposure therefore may contribute to a  ̳silent pandemic‘ of developmental neurotoxicity.‖ 27
A study by Bradman et al (2005) reported on organophosphate pesticide exposures (measured as urinary metabolites) in 600 women during and after pregnancy living in agriculture communities. 28 The intent of the study was to evaluate if after delivery, more organophosphate may be mobilized from the body, possibly being available in breast milk. The study took urine samples at three times during the pregnancy. The first sample was taken at 13 we eks of gestation, the second sample was at 26 weeks of gestation and the last collection was done approximately nine days after delivery. The median metabolite levels of organophosphate metabolite (DAP ) at the first and second prenatal sampling points and at the postpartum collection were 102.8 nmol/L, 106.8 nmol/L, and 227.2 nmol/L, respectively. There was a doubling of concentrations of pesticides post partum. The authors noted that, ―both prenatal and postpartum metabolite levels were higher in these Sa linas Valley women than in a sample of women of childbearing age in the general U.S. population (National Health and Nutrition Examination Survey 29 ), although the deviation from U.S. reference levels was most pronounced after delivery.‖ 30 These data have im portant implications for breast milk contamination and infant exposure via that route.
The children of farmworkers are at greater risk than the general population for pesticide

- related cancer from in utero and early life pesticide exposures through their parents. In a meta

- analysis of 31 studies examining the link between parental occupational pesticide exposures and incidence of childhood leukemia, the authors found that risk of childhood leukemia was associated with prenatal maternal occupational pestic ide exposure. 31 The authors found a statistically significant doubling in the risk childhood leukemia if the child was exposed prenatally to pesticides through maternal occupational pesticide exposure (OR = 2.09; 95% CI, 1.51

- 2.88). The link was even strong er if the mother‘s exposure was high (OR = 2.45; 95% CI, 1.68

- 3.58), higher confounder control scores (OR = 2.38; 95% CI, 1.56

- 3.62), and farm

- related exposures (OR = 2.44; 95% CI, 1.53

- 3.89) as opposed to mixed or unknown pesticide exposure place. Childho od leukemia risk

27 Harari R, Julvez J, Murata K, Barr D, Bellinger DC, Debes F, Grandjean P. 2010 Neurobehavioral deficits and increased blood pressure in school

- age children prenatally exposed to pesticides. Environmental Health Perspectives. February 25

28 Bradman A, Eskan azi B, Barr D, Bravo R, Castorina R, Chevrier J, Kogut K, Harnly M, McKoe T.2005. Organophosphate urinary metabolite levels during pregnancy and after delivery in women living in an agricultural community. Environmental Health Perspectives. Dec; 113 (12): 1802

- 7

29 CDC. 2004. 2001

– 2002 National Health and Nutrition Examination Survey (NHANES). Atlanta, GA:Centers for Disease Control and Prevention, National Center for Health Statistics. Available: http://www.cdc.gov/nchs/nhanes/nhanes_questionnaires.htm

30 Bradman A, Eskanazi B, Barr D, Bravo R, Castorina R, Chevrier J, Kogut K, Harnly M, McKoe T.2005. Organophosphate urinary metabolite levels during pregnancy and after delivery in women living in an agricultural community. Environmental Health Perspectives. Dec; 113 (12): 1802

- 7

31 Wigle DT, Turner MC, Krewski D. 2009 A systematic review and meta

- analysis of childhood leukemia and parental occupational pesticide exposure. Environmental Health Perspectives. Oct. 117 (10): 1505

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### 9 also was found to be significantly associated with prenatal maternal occupational exposure to insecticides (OR = 2.72; 95% CI, 1.47

- 5.04) and herbicides (OR = 3.62; 95% CI, 1.28

- 10.3). These studies and findings show the damaging and perma nent risks that may be associated with early life exposures to pesticides through the mother‘s occupational exposure while pregnant. The risks to the fetus may be much more severe than the risks to the pregnant mother, even from the same exposure scenario.
A companion meta

- analysis of childhood leukemia and home

- pesticide use was published in 2010 by the same authors. 32 In that report, they find that fetal exposures to pesticides used in the home was associated with a 54% increase in risk of childhood leukemia (OR = 1.54; 95% CI, 1.13

– 2.11). The risk was even more strongly associated with pre

- birth insecticide exposure ( OR = 2.05; 95% CI, 1.80

– 2.32), and herbicides (OR = 1.61; 95% CI, 1.20

– 2.16).
The 2004 National Institutes of Health (NIH) Agriculture Health Study, a robust prospective epidemiology study of pesticide applicators in the Midwest, reported increased child hood cancer risk associated with occupational exposure of the parents to pesticides (N=50 incident childhood cancer cases from a total of over 17,000 children of Iowa pesticide applicators). 33 In this study, the risk of all childhood cancers in farm childre n whose parent applied pesticides increased by 36% compared to other similar children (SIR=1.36; 95% CI=1.03

- 1.79). Risk of all lymphomas combined was doubled (SIR=2.18; 95% CI =1.13

- 4.19) as was the increased risk of Hodgkin‘s lymphoma (SIR=2.56; 95% CI = 1.06

- 6.14). Interestingly, an increased cancer risk was found in the children of fathers who did not use chemically resistant gloves, compared with children whose fathers used gloves when applying pesticides, (OR=1.98; CI=1.05

- 3.76). This study demonstrate s that the children of pesticide applicators may be at greater risk than the general population for some kinds of cancers.
These cancer studies reporting elevated risks to children from prenatal and postnatal exposure to pesticides through the pregnant mother or even through the father are plausible, and even predictable, given that the EPA has identified about 165 pesticide active ingredients as either known, probable, or possible human carcinogens. 34 35 Some of these include pesticides that are among the most commonly used in the US, including alachlor, metam sodium, chlorothalonil, acetochlor, malathion, metolachlor, pendimethalin, and trifluralin. 36
These data together provide strong support for EPA to take into account the risks posed to fetuses, infan ts, and young children from parental or direct occupational exposure to pesticides.

32 Turner MC, Wigle DT, Krewski D. Residential pesticides and childhood leukemia: a systematic review and meta

- analysis. Environ Health Perspect. 2010 Jan;118(1):33

- 41. PubMed PMID: 20056585; PubMed Central PMCID: PMC2831964.

33 Flower KB, Hoppin JA, Lynch CF, Blair A, Knott C, Shore DL, Sandler D. 2004 Cancer risk and parental pesticide application in children of agricultural health study participants. Environmental Health Perspectives. April; 112(5) 631

- 5

34 Goldman LR. Chemicals and children‘s environment: what we don‘t know about risks

. Environ Health Perspect. 1998; 106 (suppl 3):875

– 880.

35 U.S. EPA. Chemicals Evaluated for Carcinogenic Potential. Washington, DC: Health Effects Division, Office of Pesticide Programs, Office of Prevention, Pesticides, and Toxic Substances, U.S. Environmental Protection Agency; 2007.

36 U.S. EPA (Environmental Protection Agency). Pesticides Industry Sales and Usage 20 00 and 2001 Market Estimates. 2004. [[accessed 7 April 2009]]. Available: http://www.epa.gov/oppbead1/pestsalesNRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 10 We are pleased that EPA is now addressing these vulnerable young workers and children of workers, who are as deserving of protection as any American.

Workers (age 12

- 17 y ears) need to be considered as sensitive populations
We are pleased that EPA has determined that youth agriculture workers are in dire need of protection from routine exposures to high levels of hazardous pesticides. However, they should not be assessed as adults. Compared to adulthood, p uberty can be a very sensitive developmental stage to chemical insult because of the rapid developmental changes taking place , and toxic exposures during this life stage can cause irre parable harm. For example, studies have reported that d ioxin causes abnormal breast development in pre

- pubertal girls, the plastics

- component Bisphenol A (BPA) has shown to cause precocious puberty in girls, the pesticide endosulfan has been reported to af

fect pubertal boys by slowing down the timing of reproductive maturation, and the fungicides vinclozolin and iprodione have been shown in pubertal male rats to impair normal puberty hormone levels. 37 T reating y outh workers l ike adult workers f ails to consider the scientific body of evidence to the contrary.
A report of the American Federation of Teachers points out that statistics on child and youth agriculture labor are hard to come by because no studies have been done to consistently collect these data. 38 However, the Government Accountability Office (GAO) estimated in 1998 that 300,000 youths aged 15

- 17 worked in agriculture, 39 and the National Agriculture Statistics Service (NASS) released a report estimating over 431,000 youths aged 12

- 17 we re hired in agriculture in 1998. Children account for ab out 20% of farm fatalities. According to the GAO more than 100,000 under

- aged teens and children are injured on farms each year. While the acute and long

- term health impacts from working with pesticid es are hard to document, we know that these children are exposed to cancer

- causing and other harmful pesticides during the course of their work.
In a report issued in June, 2000, Human Rights Watch documented the following narratives from the child worker s that labor in our fields, orchards, and packing operations: 12

37 Cowin PA, Gold E, Aleksova J, O'Bryan MK, Foster PM, Scott HS, Risbridger GP. Vinclozolin exposure in utero induces postpubertal prostatitis and reduces sperm production via a reversible hormone

- regulated mechanism. Endocrinology. 2010 Feb;151(2):783

- 92. Epub 2010 Jan 7. PubMed PMID: 20056826; PubMed Central PMCID: PMC2817613.
Bl ystone CR, Lambright CS, Cardon MC, Furr J, Rider CV, Hartig PC, Wilson VS, Gray LE Jr. Cumulative and antagonistic effects of a mixture of the antiandrogens vinclozolin and iprodione in the pubertal male rat. Toxicol Sci. 2009 Sep;111(1):179

- 88. Epub 2009 Jun 29. PubMed PMID: 19564212. Roy JR, Chakraborty S, Chakraborty TR. Estrogen

- like endocrine disruptingchemicals affecting puberty in humans

-- a review. Med Sci Monit. 2009 Jun;15(6):RA137

- 45. Review. PubMed PMID: 19478717. Schoeters G, Den Hond E, Dhooge W, van Larebeke N, Leijs M. Endocrinedisruptors and abnormalities of pubertal development. Basic Clin Pharmacol Toxicol. 2008 Feb;102(2):168

- 75. Review. PubMed PMID: 18226071.

38 In Our Own Backyard: The hidden problem of child farmworkers in America. Repo rt of the American Federation of Teachers

. Available at: http://208.106.244.178/pdfs/Part%201D

Children%20in%20the%20Fields.pdf

39 GAO. Child Labor in Agriculture: Changes needed to better protect health and educational Opportunities. 1998. http://www.gao.gov/archive/1998/he98193.pdfNRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 11 Damaris A., now nineteen, started working in the broccoli and lettuce fields when she was thirteen years old and continued until she was nearly eighteen. During the five months of peak season, she usually worked fourteen hours a day, with two fifteen

- minute breaks and a half

- hour for lunch. She often worked eighty

- five or ninety hours a week. For months on end she suffered daily nosebleeds; several times her blood pressure plummeted and she nearly passed out. She was exposed to pesticide drift and fell ill, yet was required to keep working. I just endured it, she said, of her time in the fields. It was very difficult.
Mark H. was twelve the summer he first worked in the cotton fields of central Arizona, getting up at 3:00 a.m. and finishing work at 2:00 p.m. His parents, aunts, and uncles had all worked in the fields for years. My dad started when he was ten years old, and he didn’t finish til he was twenty

- two, Mark H. said. Like his fat her, Mark H. missed a lot of school and eventually dropped out. Now nineteen years old, he is struggling to catch up on his education.
Two years ago, when he was fifteen, Benjamin C. cut his finger badly with a broccoli

harvesting knife. That knife was s o sharp, he said, showing a three

- inch long scar running the length of his finger. Instead of taking Benjamin C. to a local hospital or clinic, the field supervisor sent him home to his parent’s house in Mexico; from there, his parents took him to a Mexica n hospital. This delayed by two or three hours his medical care, and also circumvented the employer’s responsibility under workers compensation law.
Only 55% of these young agriculture workers will finish high schoo l, according to the Human Rights Watch r eport . One

- third reported earning less than minimum wage, as little as $2

- 3 per hour. In addition to unsafe working conditions and economic exploitation, many of these vulnerable young workers suffer sexual exploitation at the hands of their bosses. 12

Un der the U.S. Fair Labor Standards Act (29 U.S.C. §201, et seq.) children as young as twelve can legally be employed in agriculture, with no limit on the number of hours they can work. The agricultural setting does not generally come under the Fair Labor Standards Act, and there are no regulations regarding children working on family farms. Children as young as four or five have chores related to farming activity. Unfortunately, farming activity, while not regulated, is a serious source of hazard. Over one hundred American children below the age of eighteen die working on farms each year. The only restrictions for agriculture are to preclude children from applying pesticides and herbicides. For all other occupations, the minimum age to be legally engaged in hazardous work is eighteen, but for agriculture it is fourteen. An estimated 85% of the seasonal and migrant farmworkers across the U.S. are racial minorities, mostly Latino.

These reports together provide strong support for the need for EPA‘s new polic y to take into account the risks posed to youth agriculture workers from occupational exposure to pesticides.

Children in Agricultural Fields
EPA‘s policy will specifically account for the risks to young children taken into agricultural fields, including identifying age

- relevant toxicity endpoints and uncertainty/ safety and incidental oral exposures such as hand

- to

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### 12 pesticide hazards because of unique exposure profiles, age

- related genetic activity
, and pharmacodynamic factors

. Citing data from the Department of Labor, the U.S. General Accounting Office reported in 2000 that 7% of farmworker s with children five years old or younger took their children with them, at least sometimes, when they worked in the fields. 40 Children age 12 or older legally may and do work on large farms, and children of any age may and do work on their parents‘ farms o r on small farms. There are an estimated 400,000 to 800,000 children working on farms in the United States. 41 In a survey of Colorado farmworkers, just under half (40 out of 88) began working before they were 18 years old, including several younger than ten years old. 42 Seventy

- eight percent of farmworkers are Hispanic, and sixty

- eight percent of farmworker children live below the poverty line , making this an environmental justice issue

. 43
Children in agriculture fields are sensitive to pesticide exposures d uring their most vulnerable life stages. Damage to the fetus from maternal occupational pesticide exposure can be severe and devastating. In one alarming group of case reports in 2007 regarding farmworker women in North Carolina and Florida, three women g ave birth to children with severe birth defects

. 44 All of these women had been exposed to a similar variety of agriculture chemicals in Florida. None of the women reported having any major illness other than morning sickness. The case reports only became known to the general public because the women filed legal cases against the company, and there was considerable media attention to their stories. 45 How many of these work

- related pesticide poisonings lead to birth defects that are unreported? Probably more than we‘d like to think occur. The Palm Post reported, ― The case of Ag

- Mart is not unusual: In Florida, where more pesticides are used per acre than in any other state, growers are rarely fined when they break the rules. Accor ding to state records reviewed by The Post, between 1993 and 2003 Florida inspectors found 4,609 violations of pesticide regulations, but only 7.6 percent resulted in fines. ‖ 46 Failure to consider the health impact of these occupationally

- related poisoning s on fetuses, infants, and young children is a serious omission. Failure to protect these populations is unforgiveable.
EPA is correct in identifying the need for child

- specific uncertainty/safety factors for unique exposure scenarios and toxicity endpoint s. It has long been documented that compared to adults, children are likely to be more susceptible to pesticide exposure due to their physiologic

40 U.S. General Accounting Office, Pesticides: Improvements Needed to Ensure the Safety of Farmworkers and Their Children , (RCED

- 00

- 40), March 14, 2000, at 6.

41 Human Rights Watch, Fingers to the Bone: United States Failure to Protect Child Farmworkers , June 2000, at 10, 16

- 22.

42 Cassillas Pesticide Action Project, Hidden Costs: Farm Workers Sacrifice thei r Health to Put Food on Our Tables , August, 2002, at 4.

43 See NRDC, Farm Children Petition , at 2

- 3, 8

- 9.

44 Calvert GM, Alarcon WA, Chelminski A, Crowley MS, Barrett R, Correa A, Higgins S, Leon HL, Correia J, Becker A, Allen RH, Evans E. 2007 Case report: Three farmworkers who gave birth to infants with birth defects closely grouped in time and place

— Florida a nd North Carolina, 2004

- 2005. Environmental Health Perspectives ; 115:787

- 791.

45 See stories by John Lantigua, Palm Beach Post. 2005. For example, see story posted at: http://www.organicconsumers.org/OFGU/birthdefects031405.cfm

46 See stories by John Lantigua, Palm Beach Post. 2005. For example, see story posted at: http://www.organicconsumers.org/OFGU/birthdefects031405.cfmNRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 13 differences from adults. In 1993, the National Research Council issued a report called, Pesticide in the Diets of Infants and Children that reported o n both quantitative and qualitative differences in toxicity of pesticides between children and adults. 47 Qualitative differences included the consequences of exposures during specific life stages, or windows of suscep tibility, when exposure can cause permanent harm to the structure or function of organs and systems. 48 Quantitative differences were identified as age

- related differences in absorption, metabolism, detoxification, and excretion of pesticides.

Children ma y have a genetic susceptibility to pesticide toxicity, compared with adults. Paraoxonase (PON1) is a protein (enzyme) that behaves very differently from one individual to the next and aids in recovering from pesticide toxicity. PON1 detoxifies many of the organophosphates through catalyzing the hydrolysis of its toxic oxon metabolite. In other words, PON 1 breaks down toxic by

- products of the metabolism of organophosphate pesticides , so that they do not build up in the body. A slow acting genotype of PON1 i s less efficient at detoxifying the oxon and is therefore associated with increased pesticide toxicity. 49 Published epidemiologic studies by Furlong and colleagues in 2003 and 2006 reported that the age

- related activity of PON1 may impair the ability for pe rinatal and juvenile animals and humans to recover from pesticide toxicity. 50 51 The difference in the activity of this enzyme from the most active metabolizing mothers to the slowest metabolizing infants was measured at 164

- fold. This suggests that some inf

ants may be as much as 164

- fold slower than some adults at getting rid of harmful pesticide metabolites, leaving much more time for bodily harm to occur. 52
In addition to the sensitivity of early life exposures (pre

- and peri

- natal) to organophosphates, t here are data reporting that infants born to mothers with genetically low activity of the PON1 detoxifying enzyme may be an especially vulnerable population. Berkowitz and colleagues from Mount Sinai School of Medicine determined pesticide exposure in a co hort of over 400 women in NYC by a prenatal questionnaire and measurement of maternal blood and urinary metabolites and fetal cord blood. The authors correlated this self

- reported exposure information with birth outcomes and found that maternal detectable chlorpyrifos exposure and low PON1 activity correlated with a significant, albeit small, reduction in newborns‘ head circumference. 53 The authors point to pre

- established evidence that small head size is predictive of impaired cognitive

47 Nat'l Research Council, Pesticides in the Diets of Infants and Children 2 (1993). The executive summary of the report is available at http://www.nap.edu/catalog.php?record_id=2126

48 Nat'l Research Council, Pesticides in the Diets of Infants and Children 2 (1993). The executive summary of the report is available at http://www.nap.edu/catalog.php?record_id=2126

49 Lee BW, London L, Paulausakis J, Myers J, Christiani DC. 2003. Association between human paraoxonase gene polymorphism and chronic symptoms in pesticide

- exposed worker. J Occup Environ Med. Feb 45 (2)

50 Furlong KP, Holland N, Richter R, Bradman A, Ho A, Eskenazi B. 2006. PON 1 status of farmworker mothers as a predictor of organophosphate sensitivity. Pharmogenet Genomics. Mar; 16 (3): 183

- 90

51 Costa L, Richter R, Li W, Cole T, Guizzeti M, Furlong C. 2003. Paraoxonase (PON 1) as a biomarker of susceptibi lity for organophosphate toxicity. Biomarkers. Juan

- Feb; 8(1): 1

- 12

52 Furlong KP, Holland N, Richter R, Bradman A, Ho A, Eskenazi B. 2006. PON 1 status of farmworker mothers as a predictor of organophosphate sensitivity. Pharmogenet Genomics. Mar; 16 (3): 183

- 90

53 Berkowitz GS, Wetmur JG, Birman

- Deych E, Obel J, Lapinski RH, Godbold JH, Holzman IR, Wolff MS. 2004. In Utero Pesticide Exposure, Maternal Paraoxonase Activity and Head Circumference. Environmental Health Perspectives. 112 (3): 388

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### 14 ability to support t heir suggestion that the infants of mothers with low PON1 enzyme activity may be an especially vulnerable population.
Pesticides may affect children‘s immune systems differently than adults ‘ , especially since it is a critical time in their development. In a study by Duramad et al (2006) , the investigators evaluated cellular biomarkers of allergic asthma in children of the CHAMACOS (Center for the Health Assessment of Mothers and Children of Salinas) cohort, a longitudinal birth cohort of pregnant women and their children that live in the predominantly agriculture region of Salinas Valley, California. 54 The authors report ed that early life exposure to an agriculture environment is associated with doctor

- diagnosed asthma and wheezing in young children. In particular, having a father that worked in agriculture i s associated with poor health outcomes (p=0.03). The authors note d that their results are co nsistent with other studies that have found associations between exposures to OP pesticides and self

- reported exacerbation or onset of respiratory disorders in adults (Hoppin et al. 2002; Zhang et al. 2002) and children (Salam et al. 2004). Salam et al

. (2 004) found that exposure to herbicides and pesticides in the first year of life was associated with higher odds of a s thma in children. 55

In another study of the CHAMACOS cohort , children born to mothers with elevated pesticide exposure during pregnancy (m easured by maternal urinary metabolites levels) had an associated decreased mental development and decreased psychomotor development. 56 Prenatal and postnatal pesticide exposure was associated with risk of pervasive developmental disorder by 2 y ea rs old (OR= 2.3 (p=0.05). This study suggests a lasting neurologic impairment of children related to in utero and early life pesticide exposures

.
These studies together provide strong evidence that supports EPA‘s policy to account for age

relevant toxicity endpo ints and uncertainty/ safety and incidental oral exposures such as hand

- to

mouth activity and soil ingestion in all Agency pesticide risk assessments.

Children and By

- Stander Exposure near Agriculture Fields
In November, 2009 EPA issued two notices in t he f ederal R egister pertaining to spray drift and volatilization. NRDC joined with other health and environmental groups to comment on both notices. One notice asked for public comment on a petition to protect children from pesticide drift. 57 While NRDC was not a party to the petition, we did submit comments supporting it. The other notice asked for public comment on pesticide drift labeling. 58 EPA has indicated that it

54 Duramad P, Harley K, Lipsett M, Bradman A, Eskenazi B, Holland N, Tager I. 2006 Early environmental exposures and intracellular Th1/Th2 cytokine profiles in 24

- month

- old children living in an agricultural area. Environmental Health Perspectives. December v 114(12) ,1916

- 1922

55 Duramad P, Harley K, Lipsett M, Bradman A, Eskenazi B, Holland N, Tager I. 2006 Early environmental exposures and intracellular Th1/Th2 cytokine profiles in 24

- month

- old children living in an agricultural area. Environmental Health Perspective s. December v 114(12),1916

- 1922

56 Eskanazi B, Marks A, Bradman A, Harley K, Barr D, Johnson C, Morga N, Jewell P. 2007. Organophosphate pesticide exposure and neurodevelopment in young Mexican

- American children. Environmental Health Perspectives. May; 115( 5): 792

- 8

57 Petition to Protect Children From Pesticide Drift: Notice of Availability EPA

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58 U.S. EPA PR Notice 2009

- X, Pesticide Drift Labeling, Docket control number EPA

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### 15 intends to assess risks to infants, children, fetuses and adult by

- standers from pesticide exposures due to volatilization and/or drift. (Policy at 8) We are very pleased that EPA intends to start addressing these real

- world significant exposure scenarios in this policy

. Farm children can be exposed to significant levels of pesticides throug h drift and volatilization resulting from field applications

. Pesticide Action Network North America (PANNA) has evaluated available near

- field air monitoring data from the California Air Resource Board ( CA ARB ) and compared measured air concentrations of post

- application drift to published EPA reference doses for several pesticides, including the OPs diazinon and chlorpyrifos. 59 The data show that pesticide concentrations in air near application sites commonly exceed reference concentrations (RfC; EPA all owable level) for volatile pesticides. For example, the peak concentration of diazinon in air near a legal application in the winter exceeded EPA‘s ―anytime‖ reference concentration (determined without using a tenfold FQPA factor) for a one

- year

- old child by a factor of 39 at a distance of 72 feet from the field boundary. Over a three

- day monitoring period, concentrations exceeded the acute reference concentration for 82% of all samples taken and 100% of samples collected downwind from the field. 60 PANNA ha s been working with rural communities to conduct air monitoring at people‘s homes, schools and workplaces. Data collected in Lindsay, CA showed that chlorpyrifos levels in Lindsay‘s air exceeded levels of concern derived from EPA studies by up to 11

- fold. In 2006, 28% of the 116 air samples were above the ―safe‖ exposure level for a one

- year

- old child based on EPA studies. 61
62

FQPA: A Good Start
In 1999 NRDC successfully sued EPA to review specific high

- risk toxic pesticides under FQPA in a worst

- first order of priority

. As a result, EPA has banned or severely restricted some of the most dangerous uses of the worst pesticides. 63 The first of the worst was the organophosphate pesticides (OPs), a class of neurotoxic insecticide s developed from World War II

- era nerve gas. Exposure can cause dizziness, confusion, vomiting, convulsions, numbness in the limbs, and even death.
According to a 2006 EPA review, total OP pesticide uses are estimated to have reduced from approximately 90 million pounds annually t o less than 60 million pounds annually because of

59 Pesticide Action Network North America. Coalition comments EPA‘s August 2006 Organophosphate cumulative assessment (docket ID number: EPA

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- 2006

- 0618). October 2, 2006

60 Kegley, SE, Katten A, M oses, M, Secondhand Pesticides: Airborne Pesticide Drift in California, Pesticide Action Network, California Rural Legal Assistance Foundation, Pesticide Education Center, and Californians for Pesticide Reform (San Francisco, 2003).

61 See PAN‘s calculatio ns for reference exposure levels for a 1

- year

- old child based on EPA‘s inhalation No Observed Acute Effect Level (NOAEL): Mills, K and S Kegley. 2006. Air Monitoring for Chlorpyrifos in Lindsay, California June

- July 2004 and July

- August 2005 . Pesticide Action Network, San Francisco, CA., p.24. http://www.panna.org/campaigns/DCLindsay04

- 05.dv.html

62 Pesticide Action Network North America. Coalition comments EPA‘s August 2006 Organophosphate cumulative assessment (docket ID number: EPA

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- 0618). October 2, 2006

63 US EPA on Accomplishments under the Food Quality Protection Act http://www.epa.gov/pestici des/regulating/laws/fqpa/fqpa_accomplishments.htmNRDC on risks to agriculture workers and children of workers Apr 2010 EPA

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### 16 mitigation measures required by EPA following the FQPA

- required review. 64 In addition,

e ighteen of the original universe of 49 OPs have either been phased

- out or cance lled, so that from 1994 to 2004 there h as been a total reduction of 57% of OPs on the market, including a reduction

o f OPs on the top 10 kids foods, from 28 million pounds of active ingredien t (M lbs/a.i.) to 12 M lbs a.i

. 65 This is a significant accomplishment, and EPA should take pride in its actions to effectively remove these dangerous pesticides from our environment and our food. Some specific accomplishments are below:
Chlorpyrifos : S cientific studies have reported that exposure to chlorpyrifos during pre

- birth and early life stages is associated with poor birth outcomes and long

- term neurobehavioral deficits. For these reasons, since 2001, residential uses of chlorpyrifos were all can celled, resulting in a reduction of over 6 million pounds annually from people‘s homes. This action has been associated with a 66% reduction in poisonings since 1995.

Diazinon : The phase

- out of over 11 million pounds annually of non

- agricultural uses of diazinon took 3⁄4 of diazinon off the market. This was correlated with a measurable reduction of diazinon in streams of between 20 and 40%, according to government geological survey data.
Acephate : Cancellation of acephate uses in and around homes, lawns, a nd gardens took almost 1 million pounds annually of this toxic chemical out of people‘s homes.
However, the accomplishments of EPA in cancelling many residential uses of dangerous pesticides have not been extended to agriculture uses. Many of the most da ngerous pesticides are still in widespread agriculture use, contaminating our environment and posing exposure risks to agriculture workers and their families. For example, a lthough chlorpyrifos is no longer legal for home use, approximately 10 million poun d s are still used annually on corn, in orchards, and on other vegetable row crops. It contaminates our food and soil and drifts into rural schoolyards and homes. Also known as LorsbanTM or DursbanTM, chlorpyrifos is responsible for a substantial number of w orker poisonings each year. Although government biomonitoring data indicate that the levels of chlorpyrifos in human urine has been reduced to half the amounts pre

- cancellation, its breakdown products still have been detected in the bodies of three

- quarte rs of the US population

. 66

Conclusion

M ore needs to be done to address the risks of these harmful agriculture chemicals to agriculture workers and their families. This policy will begin the process of providing real meaningful protections to young farmw orkers and the children of farmworkers by expanding pesticide risk assessments to include occupationally

- related exposures and specific exposure scenarios experienced routinely by young farm workers and the children of farm workers

. We strongly

64 Registration and Tolerance Reassessment. Powerpoint presentation by Debbie Edwards, Director, SRRD/OPP. Pesticide Program Dialogue Committee. November 8, 2006.

65 Registration and Tolerance Reassessment. Powerpoint presentation by Debbie Edwards, Director, SRRD/OPP. Pesticide Program Dialogue Committee. November 8, 2006.

66 Barr DB, Bravo R, Weerasekera G, Caltabiano LM, Whitehead RD Jr, OlssonAO, Caudill SP, Schober SE, Pirkle JL, Sampson EJ, Jackson RJ, Needham LL. 2004. Concentrations of dialkylphosphate metabolites of organophosphorus pesticides in the US population. Environ Health Perspect 112:186

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### 17 support this policy and recommend that EPA finalize it with the recommendations we‘ve made in these comments to strengthen its effectiveness.
Thank you for consideration of these comments,

Jennifer Sass, Ph.D. Senior Scientist, Health and En vironment Natural Resources Defense Council (NRDC) 1200 New York Ave, NW. Suite 400 Washington, DC 20005

Email: jsass@nrdc.org ; Tel: 202

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