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April 12, 2009

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-HQ-OPP-2009-0889-0002)

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 Pesticides 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.epa.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 exposures 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 agriculture 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 toxic 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. 
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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, on October 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 requires 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 

Communities2and in 2004, NRDC published Hidden Danger: Environmental Health Threats in 

the 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 groups 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 the 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 Fungicide, 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 acceptable 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 EPA 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 certainty 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 Protected 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.asp
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special safeguards for infants and children, see 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)(vi). This command 

includes farm children 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 exposures 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. Further, 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 add 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 fields 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 for 
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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 

laboratory 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. Studies 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 pesticide-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 adults. Puberty is recognized as a critical or 

sensitive window of susceptibility to chemicals 7particularly with respect to reproductive and 

endocrine disrupting effects. For example, exposure of rodents to high doses of some phthalates 

has been shown to delay 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 damage8and 

exposure to various chemicals can delay or accelerate onset of puberty in females.9

Aggregate exposure 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 neurotoxicity 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 Risk 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 Sprague-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. Fertility and Sterility_ Vol. 89, Supplement 1, February, pp. e1-

e20.
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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 assessment10, the feasibility and desirability of assessing the 

cumulative risks of multiple chemical exposures11, and rapid and effective testing methods to 

assess inherent hazard12. 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 aggregate 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 adopting 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 specific 

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/hypothalamic 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 disrupting 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 Risk 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.
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Specific Comments on the Policy and Scientific Support for NRDC Recommendations

Occupational 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 pesticides. (Policy at 7) This 

includes occupationally-related exposures through the parent as well as exposures from pesticides

carried into the home, school, or playground environment. (Policy at 7) We strongly support 

efforts to describe and calculate the impact 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 under 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-treated 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 Diamanti-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: 290
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substantial agriculture-related exposure is in addition to the pesticides that they also encounter 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 children‘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 were 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 pesticide reside 

in the parent‘s urine and their child‘s urine, providing evidence that the parent‘s occupational 

exposure was contaminating the children (r2= 0.18, p < 0.0001). This work shows that parent‘s 

occupational exposure to harmful pesticides is resulting 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 exposed 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 

statistically 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 stunting 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-age children prenatally exposed to pesticides. 

Environmental Health Perspectives. February 25
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participants, children 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) visual-spatial performance 

(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 that 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 weeks 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 Salinas Valley women than in a sample of women of childbearing age in the general U.S. 

population (National Health and Nutrition Examination Survey29), although the deviation from 

U.S. reference levels was most pronounced after delivery.‖ 30 These data have important 

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 pesticide 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 

stronger 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. Childhood 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, 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

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): 1505-13
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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 permanent 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 childhood 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 children 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 

demonstrates 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, infants, 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 2000 and 2001 

Market Estimates. 2004. [[accessed 7 April 2009]]. Available: http://www.epa.gov/oppbead1/pestsales
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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 years) 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, puberty 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 irreparable harm. For example, studies have reported 

that dioxin 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 affect 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 Treating youth workers like adult workers fails 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 were hired in 

agriculture in 1998. Children account for about 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 pesticides 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 workers 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.

Blystone 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. Report of the American 

Federation of Teachers. Available at: http://208.106.244.178/pdfs/Part%201DChildren%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.pdf
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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 father, 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 broccoliharvesting knife. That knife was so 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 Mexican 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 school, according to the Human 

Rights Watch report. 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

Under 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 policy 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-mouth activity and soil ingestion. (Policy at 7) We strongly 

support this policy, which reflects the scientific evidence that children are more vulnerable to 
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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 farmworkers 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 or 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 during 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 gave 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. According 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 poisonings 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 endpoints. 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 their 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 and 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.cfm
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differences from adults. In 1993, the National Research Council issued a report called, Pesticide 

in the Diets of Infants and Children that reported on 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 susceptibility, 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 may 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 is 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 perinatal 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 infants 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, 

there 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 cohort 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 

susceptibility 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): 388-91
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ability to support their 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 reported 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 is associated with poor health outcomes (p=0.03). The authors 

noted that their results are consistent 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. 

(2004) found that exposure to herbicides and pesticides in the first year of life was associated 

with higher odds of asthma in children. 55

In another study of the CHAMACOS cohort, children born to mothers with elevated pesticide 

exposure during pregnancy (measured 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 years 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 agerelevant toxicity endpoints and uncertainty/ safety and incidental oral exposures such as hand-tomouth 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 the federal Register 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 Perspectives. 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-HQ-OPP-2009-0825

58 U.S. EPA PR Notice 2009-X, Pesticide Drift Labeling, Docket control number EPA-HQ-OPP-2009-

0628. Information available at: http://www.epa.gov/pesticides/factsheets/spraydrift.htm
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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 through 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 allowable 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 has 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 insecticides 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 to 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-HQ-OPP-2006-0618). October 2, 2006

60 Kegley, SE, Katten A, Moses, 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 calculations 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-HQ-OPP-2006-0618). October 2, 2006

63 US EPA on Accomplishments under the Food Quality Protection Act 

http://www.epa.gov/pesticides/regulating/laws/fqpa/fqpa_accomplishments.htm
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mitigation measures required by EPA following the FQPA-required review. 64 In addition, 

eighteen of the original universe of 49 OPs have either been phased-out or cancelled, so that from 

1994 to 2004 there has been a total reduction of 57% of OPs on the market, including a reduction 

of OPs on the top 10 kids foods, from 28 million pounds of active ingredient (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: Scientific 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 cancelled, 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, and 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 dangerous pesticides are 

still in widespread agriculture use, contaminating our environment and posing exposure risks to 

agriculture workers and their families. For example, although chlorpyrifos is no longer legal for 

home use, approximately 10 million pounds 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 worker 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-quarters of the US 

population.

66

Conclusion

More 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 farmworkers 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 112:186–200.
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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 Environment

Natural Resources Defense Council (NRDC)

1200 New York Ave, NW. Suite 400

Washington, DC 20005

Email: jsass@nrdc.org; Tel: 202-289-2362