-r.f"I'11~i1 ~~ 

FARMWORKER 

JUSTICE 

December 15, 2006 

rfhe Honorable Stephen L. Johnson 

Administrator 

U.S . Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue N.W. 

Washington, D.C. 20460 

Dear Administrator Johnson, 

r, 

. _ 

~ . ._, . ~. .-F- l ~-~~ 

(`A`~~8 EG t;i=TAF1'1AI` 

Each year . thousands of farmworkers and their children are injured by exposure to pesticides . 

'hhey also face elevated risks of cancer, birth defects, infertility, and neurological disorders, 

including Parkinson's disease. Recent studies show that even low levels of exposure can lead to 

deficits in attention, memory and intellectual functioning. The Worker Protection Standard 

(WPS), issued in 1992, has not stemmed this tide of suffering. Improving the protections, training 

and information available to workers will lead to both a reduction in human illness and injury to 

wildlife and the environment. Consequently, the undersigned farmworker, Latino, labor, environmental, faith-based, health and other groups, urge you to propose issue and implement 

major regulatory reforms in the WPS without delay. 

For workers laboring in pesticide-treated fields, orchards, greenhouses, nurseries, mushroom 

houses and forests (known as post-application workers), improvements are needed in training, 

hazard information, re-entry and other protections. The current WPS scheme hinges largely on I 'd' I I I I )rovi Ing post-application workers with a cursory pesticide sat'ety training, once every five years. One short training session, years apart without reinforcement, cannot ensure that workers 

appreciate the health risks facing them or their families or know how to prevent injury or secure 

assistance in case of exposure. Studies show that misconceptions abound among farmworkers . 

Many workers believe that they can recognize pesticide hazards by the smell, that invisible 

residucs pose no threat, and that the adverse effects of pesticide exposure last no more than a day 

or two. Most also lack information about their rights or how to enforce them. 

Under the Occupational Safety and Health Administration's (OSHA) Hazard Communication 

Standard, by contrast, workers in non-agricultural settings are entitled to far more extensive 

training and chemical inforrnation, than farmworkers receive under the WPS. The OSHA 

standard, for example, requires that workers receive training and have access to written 

information on the short- and long- term health effects associated with all toxic chemicals used at 

thcir worksites, before they begin work in that area . Although the EPA proposed adding a Hazard 

Communication provision to the WPS in 1992, no such protection has ever been included. This 

C)11n1sSlon must be rectified. 

1010 Vermont Ave., NW, Suite 915 " Washington, DC 20005 

(202) 783-2628 9 (202) 783-2561 fax 9 email: fjCnclr.org " www.farmworkerjustice .org 
To secure the information they need, farmworkers must receive an annual, comprehensive 

training, conducted in an interactive manner, before they are exposed to pesticides . The training 

should focus on protecting workers and their children/families and include concrete information 

on workers' rights and how to enforce them. In addition, farmworkers should be given written 

information, in a pictorial and low-literacy format, concerning the short- and long- term health 

effects associated with each pesticide used at their worksites. This would enable them to 

recognize and seek medical assistance when they experience symptoms which may be related to 

pesticide exposure . 

Restricted entry intervals (REIs) are a second critical component of protection for postapplication workers. They are intended to provide a physical barrier, reducing worker exposure to 

pesticides when and where the risk is greatest . But workers are not effectively warned to keep out 

of recently treated areas. In addition, vague and overbroad REI exceptions undermine the value of 

this protection . Nor is the use of Personal Protective Equipment (PPE) a practical alternative for 

these workers. PPE impedes worker efficiency, which cuts the pay of piece-rate workers and the 

equipment is often too hot or uncomfortable to be worn. As a consequence, early entry into areas 

under an REI should be prohibited except in true emergency situations (e .g ., an unexpected 

freeze). 

Pesticide exposure from drift of sprays which are applied in nearby fields is one of the leading 

causes of poisoning of post-application workers. These incidents pose serious risks since they 

occur when pesticides are highly toxic and the affected workers are wholly unprotected . 

Currently, the WPS largely ignores drift, omitting both buffer zone requirements and provisions 

for access to spray and label information, when the drift results from applications performed by 

an individual who does not employ the affected workers (or provide services to the workers' 

employers) . 

Farmworkers often return home from work with pesticide residues on their skin, clothes and 

shoes. These residues contaminate the workers' homes and vehicles, and enter the bodies of their 

children . Numerous studies have shown that farmworker children are far more exposed to 

pesticides than children whose parents do not work in agriculture. These "take home" exposures 

could be reduced by requiring employers to provide their workers with an area at the worksite to 

wash themselves, change and store clothes. 

Changes are also needed to protect farmworkers who mix, load or apply pesticides under the 

supervision of certified applicators (i .e., the workers known as pesticide handlers). Such reforms 

must include: medical monitoring, fit-testing of respirators, use of closed mixing and loading 

systems, appropriate-language pesticide labels and the provision of showering and changing 

areas. Medical monitoring of pesticide handlers is a crucial early detection method to prevent 

overexposure to the two types of insecticides responsible for the most reported acute poisonings : 

Toxicity Category 1 and 2 organophosphates (OPs) and n-methyl carbamates (CBs). Exposure to 

these products causes both immediate and long-term damage to the brain and nervous system. 

Medical monitoring programs have been adopted in California (1974), Washington State (2003) 

and Ohio (2005) . Reports from the first two years of implementation in Washington State have 

shown that the program has prevented injury to a significant number of handlers in a costeffective manner. It is time to require such a program nationally . 
While OSHA requires workers wearing respirators to be "fit tested" and medically evaluated 

before using such equipment, the WPS does not. Without these protections, respirators often do 

not fit properly and workers with contraindicated medical conditions are allowed to wear 

respirators, resulting in injury . Under the WPS, workers using respirators should be fit-tested and 

medically evaluated. 

Handlers need access to label information in order to prevent injury to themselves, others and the 

environment. Pesticide companies can produce these labels in multiple languages and should be 

required to do so. In addition, handlers, like field workers, can cause "take home" exposure to 

their families, unless they have an opportunity to shower and change clothes before leaving work. 

Pesticide handlers mixing and loading Toxicity Category 1 liquids and wettable powders are 

injured due to spills, splashes and blowing powder. To protect these workers, the WPS should 

require closed mixing and loading systems for all Toxicity Category 1 and 2 pesticides . 

Both handlers and post-application workers are afraid to file complaints, when their WPS rights 

are violated, for fear of employer retaliation . The WPS must include clear procedural safeguards 

that afford workers the opportunity to file complaints with a grant of confidentiality that only the 

worker can waive . In addition, workers should be permitted to be parties in administrative 

hearings, requested by employers, to contest alleged violations . Finally, stiff financial penalties 

and license revocations should be utilized to achieve compliance with these crucial requirements . 

Our specific recommendations are set forth in Attachment 1 . By adopting these reforms, the EPA 

will greatly reduce the risk of immediate and long-term illness to farmworkers and their families 

and improve protections for wildlife and the environment. 

Sincerely, 

Shelley Davis 

Deputy Director 

Farmworker Justice 

0 

Mary Bauer 

Director, Immigrant Justice Project 

Ann R. Cox 

Executive Director 

American Association of 

Occupational Health Nurses, Inc. 

Atlanta, GA 

Southern Poverty Law Center Caroline C:ox 

Montgomery, AL Research director 

Carol Brooke 

Staff Attorney 

North Carolina Justice Center 

Raleigh, NC 

Will Callaway 

Legislative Director 

Physicians for Social Responsibility 

Jessie Coclcs 

Kennett Area Democrats Chair/Zone 

Leader and Spirit Body Resources 

Founder/Facilitator 

Kennett Square, PA 

8 

Center for Environmental Health 

Oakland, CA 

D. Michael Dale 

Executive Director 

Northwest Workers' Justice Project 

Portland, OR 

Jaime Duggan 

Outreach Worker 

Farmworker Health Program, Watauga 

Medical Center 

Boone, NC 
Kathleen Fagan, MD 

Occupational Doctor 

AOEC Clinic 

Lorain, OH 

.lay Feldman 

Executive Director 

Beyond Pesticides 

Washington, DC 

Nora Ferm 

Director, Fairness in Flowers Campaign and 

Rights for Working Women Campaign 

International Labor Rights Fund 

Washington, DC - 

Joan D. Flocks 

Director, Social Policy Division 

Center for Governmental Responsibility 

Levin College of Law 

University of Florida 

Gainesville, FL 

Tim Freilich 

Legal Director 

Virginia Justice Center for Farm and 

Immigrant Workers 

Charlottesville, VA 

Michael Fry 

American Bird Conservancy 

Washington, DC 

Humber-to Fuentes 

Chair 

Farmworker Advocate 

Nampa, ID 

Melody Goldberg 

Attorney at Law 

Director, Migrant Farmworker Law Center 

Indiana Legal Services 

Indianapolis, IN 

Patti Goldman 

Managing Attorney 

Earthjustice 

Seattle, WA 

Billy W. Green 

North Carolina Public Records Law 

Spring Hope, NC 

N orma Gri er 

Executive Director 

Northwest Coalition for Alternatives to 

Pesticides (NCAP) 

Eugene, OR 

Tee L. Guidotti, MD, MPH, Professor 

Chair, Dept. of Environmental and 

Occupational Health 

Director, Division of Occupational Medicine 

and Toxicology 

(Dept. of Medicine) 

The George Washington University Medical 

Center 

Washington, DC 

Eric M. Gutierrez 

Legislative Staff Attorney 

MALDEF 

Washington, DC 

Teresa M. Hendricks 

Director and Senior Litigator 

Michigan Migrant Legal Assistance Project, 

Inc . 

Grand Rapids, Michigan 

Caroline Kennedy 

Defenders of Wildlife 

Washington, DC 

Legal Services of New Jersey 

Edison and Bridgeton, NJ 

Stephen M. Levin, MD 

Medical Director 

Mount Sinai - IJ Selikoff 

Center for Occupational and Environmental 

Medicine 

New York, NY 

Amy K. Liebman, MPA 

Migrant Clinicians Network 

Quantico, MD 
Allison Lipscomb, MPH 

Program Director Farmworker Health 

Program, Watauga Medical Center 

Boone, NC 

.1ena Matzen J. D. 

Chair 

Advisory Board of the 

North Carolina Farmworker Health Program 

Raleigh, NC 

Maricela Morales 

Mayor Pro Tern 

City of Port Hueneme 

Port Hueneme, CA 

Lupe Martinez 

Executive Director 

i.JMOS 

Milwaukee, WI 

Tirso Moreno 

General Coordinator 

Farmworker Association of Florida 

Apopka, FL 

Karen Mountain, RN, MSN, MBA 

Chief Executive Officer 

Migrant Clinicians Network 

Austin, TX 

Neil D. Michaud 

Director of Peace and Justice Office 

Environmental Justice Commission, Peace 

and Justice Office, Diocese of Venice in 

Florida 

Venice, FL 

Virginia Nesmith 

Executive Director 

National Farm Worker Ministry 

St . Louis, MO 

Erik Nicholson 

United Farm Workers of America 

'Cakoma. WA 

Teresa Niedda 

Administrator 

Farmworker Health and Safety Institute 

Bridgeton, NJ 

Laurence E. Norton, II 

Executive Director 

Community Justice Project 

Harrisburg, PA 

Gene Ortega 

President 

Rural Housing, Inc . 

Albuquerque, NM 

Fawn Pattison 

Executive Director 

Pesticide Education Project 

Raleigh, NC 

Deepa Premnath 

Pesticide Program Outreach and 

Education Worker 

Farmworker Legal Services of NY, Inc. 

Rochester, NY 

Nancy R. Powers 

Consultant, Farmworker Solidarity Project 

Florida Catholic Conference 

Tallahassee . FL 

Ramon Ramirez 

Pineros y Campesinos Unidos de Noreste 

Woodburn, OR 

Anna L. Rizzi 

Michigan Migrant Legal Assistance Project, 

Inc. 

Grand Rapids, MI 

Margaret Reeves 

Senior Scientist 

Pesticide Action Network, North America 

San Franciso, CA 

Michael Rowland, MD, MPH 

Medical Director 

Maine Migrant Health Program 

Augusta, ME 

Jennifer Sass 

Senior Scientist 

Natural Resources Defense Council 

Washington, DC 
Damien W. Sanchez 

Michigan Migrant Legal Assistance Project, 

Inc . 

Grand Rapids, MI 

Daniel Schlanger 

Staff Attorney 

Legal Aid Society of Cleveland 

Cleveland, OH 

Erika Schreder 

Staff Scientist 

Washington Toxics Coalition 

Seattle, WA 

Rev. Patrick Seyler 

Mission Developer 

United in Faith Episcopal-Lutheran Mission 

Kennett Square, PA 

Nargess Shadbeh 

Farmworker Director 

Oregon Law Center 

Portland, OR 

Christopher Siple 

Founder/Director and Reconciliation Project 

Nashville, 'I'N 

Marcos Vargas, PhD. 

Executive Director 

Central Coast Alliance United for a 

Sustainable Economy 

(CAUSE) 

Ventura, CA 

Melinda Wiggins 

Executive Director 

Student Action with Farmworkers 

Durham, NC 

Serafina Youngdahl Lombardi 

Union Representitive 

Union de Trabajadores de Kaolin 

Kennett Square, PA 

Barbara Vodapivc 

Administrative Assistant 

Farmworker Justice 

Washington, DC 
SPECIFIC RECOMMENDATIONS FOR IMPROVEMENTS IN THE WORKER 

PROTECTION STANDARD 

ATTACHMENT 1 

1. RECOMMENDATIONS FOR POST-APPLICATION WORKERS 

The WPS must be expanded to include the following requirements : 

" All post-application workers must receive pesticide safety training on an annual basis 

before they are exposed to pesticides . 

" In addition to current topics, the required pesticide safety training must cover: (i) 

information about the immediate, intermediate and long-term health risks to workers and 

their families from exposure to the specific pesticides used at the worksite; (ii) expanded 

information on how workers can reduce workplace, "take home" or drift exposures to 

themselves and their families ; (iii) an explanation of the pesticide information sheets and 

how to use them, including an explanation that: 1) workers may be suffering from a 

pesticide-related illness when they are experiencing symptoms associated with the 

pesticides to which they have been exposed; 2) that the information sheets will help a 

health professional diagnose a pesticide-related condition; (3) that workers should retain 

these sheets and give them to a health care provider, in case of suspected poisoning; (4) 

workers' rights, including how to file a confidential complaint and the protection against 

retaliation; (5) contact information for the state agency which accepts complaints; and (b) 

contact information for a nearby legal services agency or farmworker group. 

" Employed workers must be paid for the time they spend attending a pesticide safety 

training session. 

" The WPS must prohibit an employer from refusing to hire a worker who does not have 

proof of having been trained . 

+ To be certified as a pesticide safety trainer for post-application workers or pesticide 

handlers, an individual must complete an EPA- or state- approved train-the-trainer course 

covering methods of conducting an informal adult participatory education session for low 

literacy learners, with limited English proficiency . 

" Workers must receive a simple pesticide information sheet, in a pictorial and low literacy 

format and in a language the worker understands, which states the name of each pesticide 

used on a crop; its REI; the short-and long- term health effects of exposure to that 

product; and when the pesticide is used (by month or part of the cultivation cycle) . 

Pesticide manufacturers should be required to prepare such a sheet for each product it 

sells that bears the WPS reference on its label. 

" Employers should compile these sheets so that a worker receives a single booklet with all 

pesticide information sheets applicable to the crop in which s/he is working. 

" When workers are given the pesticide information sheet, they should also be advised that 

pesticide application information is posted at the usual points of entry to the field . (This 

pesticide list will cover all pesticides applied or covered by REIs within the last 30 days.) 

" All fields which are or have been under an REI during the preceding 30 days, must have a 

sign at the usual points of entry which states the following specific information: name of 

pesticide applied; application date and times; REI, contact information for employer; onfarm manager; or pesticide applicator and date and time that REI expires. 
" in addition, attached to each sign should be a written list of the pesticides used on that 

field -- or for which an REI was in effect -- during the past 30 days. The list should be 

written in English and Spanish or other language spoken by a majority of the workers 

employed by that employer, and also include dates each pesticide was applied, REI, and 

the date and time the REI expires . 

" In fields covered by REIs of more than 72 hours, a warning sign should also be posted at 

the usual points of entry to the field and every 100 feet around the field's perimeter. The 

posted warning sign should bear the skull and cross bones, not the current sign (i .e ., a 

man with an upraised hand). 

" In case of suspected pesticide exposure to a worker, a worker's family member or 

bystander, growers must provide pesticide application information and a copy of the 

label(s) and MSDS or information sheets to the affected person, his/her representative or 

a health care professional, upon request, within two business days . In the event of a 

medical emergency, the information must be provided within one hour. 

" An EPA-approved pesticide safety poster must be posted at the typical points of entry to 

a treated field or at the site of the decontamination water. 

" Early reentry exceptions for "limited contact," "no contact" or irrigation workers, should 

be repealed. Exceptions should only be granted in the event of a true emergency or when 

a need is specifically justified through notice and comment rulemaking . 

" Moving or checking irrigation equipment should be included within the definition of 

hand-labor activities. 

" When an emergency exception is invoked, workers must receive written notification that 

they : (i) have been designated as early entry workers; (ii) are being put into a field prior 

to the REI's expiration, and (iii) must wear specified PPE, which is identified on the 

product label or WPS. 

" No worker should be permitted inside enclosed areas such as greenhouses or mushroom 

houses while spraying is occurring. Moreover, the adequacy of the 24 hour passive 

ventilation REI and other greenhouse ventilation criteria should be re-evaluated by EPA 

or NIOSH. 

" All farms must have an area where workers can change into work clothes and store clean 

clothing . Handwashing water, soap and towels must also be available at these sites . 

" Information should be posted, in changing areas, in an appropriate language(s) and 

literacy level, explaining why and how to protect household members from exposure to 

pesticide residues. 

II . RECOMMENDATIONS FOR PESTICIDE HANDLERS : 

" lZequire medical monitoring of pesticide handlers, who mix, load or apply Toxicity 

Category 1 or 2 OPs or CBs for 30 or more hours in a 30 day period, which includes 

taking baseline and periodic plasma and red blood cell cholinesterase tests. Employers 

must pay the cost of the medical monitoring, but doctors must inform workers and 

employers of results and results must be reported directly by the laboratory to the state 

agency overseeing the program. 

" When workers experience a 20% or more cholinesterase depression, the state agency 

must investigate and report on possible cause(s) . 

" When workers experience a 30% depression of RBC or a 40% depression of plasma 

cholinesterase, they must be removed from work until their cholinesterase rebounds to 

90% of normal . During this period, they must receive their average rate of pay for the last 

full pay period in which they worked. (Removal protection wages must be available for at 

least three months.) 
" Laboratory tests should be performed by a single laboratory for both the baseline and 

follow-up tests . The EPA or state lead agency should approve the labs, preferably 

designating a single lab for each state . (The list of approved labs should be updated 

periodically and posted on the EPA and state lead agency websites.) 

" Each state lead agency should report annually the number of workers with cholinesterase 

depressions of 20% or more and the likely causes. In addition, each state lead agency 

should report on the number of workers removed from work, due to cholinesterase 

depression, and the length of time they had to stay out of work before their cholinesterase 

level returned to 90% of normal. 

" EPA should adopt a requirement for fit-testing of respirators and the medical evaluation 

of handlers who must wear them. 

" Pesticide labels should clearly state when respiratory protection is required. 

" Growers and commercial applicator companies irnust provide showers and changing 

facilities for pesticide handlers to enable them to shower and change clothes at the end of 

their work day. Facilities must be supplied with soap and towels as well as 

uncontaminated lockers where workers can store their street clothes. 

" All Toxicity Category 1 and 2 wettable powders and other dry formulations must come in 

water soluble packets. Liquids must be packaged in containers that are compatible with 

closed mixing and loading systems or water soluble bags . Design and construction 

standards must also be established for these systems. 

" Handlers must receive training on an annual basis . 

" Training must cover: (i) how to properly fit PPE; (ii) how to check whether PPE is in 

good repair ; (iii) the purpose and procedures of the medical monitoring system; (iv) a 

handler's rights (including the right to be free from retaliation) ; (v) how to file a 

complaint and contact information for the state agency handling complaints and (vi) 

contact information for nearby low cost or free legal and health services . 

" Pesticide labels must be made available to handlers in English, Spanish or other 

languages spoken by the handler or it must be read or translated for the handler, upon 

request. 

111 . Expansion of Scope of WPS and Additional Procedural Protections 

" WPS should be expanded to cover dairy, livestock, landscape, and maintenance workers. 

" Workers must have a right to file complaints anonymously. A state agency cannot release 

the name of a complaining employee unless it obtains the complainant's agreement in 

writing. 

" A worker's representative should be authorized to file a complaint on the workers' 

behalf. 

" Complaints alleging worker injury should be investigated within 48 hours. 

" Workers should be permitted to participate as a party to an administrative proceeding 

requested by an employer to challenge an alleged WPS violation. 

" Adequate fines, license revocations and other enforcement measures should be used to 

deter misconduct. 

" EPA should approve an annual state plan for all state lead agencies, enforcing the WPS. 

The state agencies should also be required to report key data to EPA on an annual basis . 

" The state agency responsible for conducting workplace investigations should make 

summary data available to the public . Such data should include, but not be limited to : (i) 

number of investigations ; (ii) number and type of violations found; and (iii) number and 

amount of fines and other penalties issued . 
References 

Arcury TA, Quandt SA, Chronic agricultural chemical exposure among migrant and seasonal 

farmworkers . Soc Natur Resour 11 :829-843 (1998) . 

Arcuiy, TA, Pesticide Exposure Beliefs Among Latino Fannworkers in North Carolina's Christmas 

Tree Industry, Am. J . Ind . Med. 40 :153-160 (2001) . 

Arcuty TA, Quandt SA, Rao P, Doran AM, Snively BM, Barr DB, Hoppin JA, Davis SW, 

Organophosphate pesticide exposure in farmworker family members in western North Carolina 

and Virginia : Case comparisons . Hum Organ 64:40-51 (2005). 

Bradman, M.A . Harnly ME, Draper W, Seidel S, Teran S, Wakeham D, Neutra R., Pesticide 

exposures to children from California's Central Valley: Results of a pilot study. Journal of 

Exposure Analysis and Environmental Epidemiology, 7: 217-234 (1997). 

Coronado, GD, Thompson B, Strong L, Griffith WC, Islas 1. "Agricultural Task and 

Exposure to Organophosphate Pesticides Among Farmworkers," Environmental Health 

PC'rI1)eCtlvL'.4, vol. 112, no. 2, February 2004, pp. 142-147 . 

Curl, CL, Fenske RA, Kissel JC, Shirai JH, Moate TF, Griffith W, Coronado G, Thompson B . 

Evaluation of take-home organophosphorus pesticide exposure among agricultural workers and 

their children. Environmental Health Perspectives, 110 :A787-A792 (2002) . 

Davis, S & Schleifer, R, Indifference to Safety (Farmworker Justice 1998) 

Fear NT, Roman E, Reeves G, Pannett B . Childhood cancer and paternal employment in 

agriculture : The role of pesticides. Brit J Cancer 77 :825-829 (1998). 

Fenske, RA, Kissel JC, Lu CS, Kalman DA, Simcox NJ, Allen EH, Keifer MC, Biologically 

Based Pesticide Dose Estimates for Children in an Agricultural Community, Environmental 

Health Perspectives (June 2000) 

Fenske, RA, Lu CS, Simcox NJ, Loewenherz C, Touchstone J, Moate TF, Allen EH, Kissel JC, 

Strategies for assessing children's organophosphorous pesticide exposures in agricultural 

communities. Journal of Exposure Analysis and Environmental Epidemiology. 10: 662-671 

(2002). 

Garry VF, Harkins ME, Erickson LL, Long-Simpson LK, Holland SE, Burroughs BL. 2002 . 

Birth defects, season of conception, and sex of children born to pesticide applicators living in the 

Red River Valley of Minnesota, USA. Environ Health Persp 110 :441-449 . 

Loewenherz C, Fenske RA, Simcox NJ, Bellamy G, Kalman D. 1997. Biological monitoring of 

organophosphorus pesticide exposure among children of agricultural workers in central 

Washington State. Environ Health Persp 105 :1344-1353 . 

Lu, CS, Fenske RA, Simcox NJ, Kalman D, Pesticide exposure of children in an agricultural 

community: Evidence of household proximity to farmland and take-home exposure pathways. 

Environmental Research, 84 : 290-302 (2000) 
McCauley, LA, Lasarev MR, Higgins G, Rothman N, Muniz J, Ebbert C, Phillips J, Work characteristics and pesticide exposures among migrant agricultural families : A community-based research approach . Environmental Health Perspectives, 109 :533-538 (2001) . 

Mills, PK and Kwong S, Cancer Incidence in the United Farmworkers of America 1987-1997, Am J . of Ind . Med. 40:59G-G03 (2001). 

Quandt SA, Arcury TA, Rao P, Snively BM, Camann DE, Doran AM, Yau AY, Hoppin JA, 

Jackson DS. 2004b. Agricultural and residential pesticides in wipe samples from farmworker 

family residences in North Carolina and Virginia . Environ Health Persp 112 :382-387 . 

Reeves, M, Guzman M, Katten A, Fields of Poison 2002 

Rothlein, Joan, Rohlman, Diane, Lasarev, Michael, Phillips, Jackie, Muniz,Juan, McCauley, 

Linda, "Organ ophosphate Pesticide Exposure and Neurobehavioral Performance in Agricultural and Nonagricultural Hispanic Workers," Environmental Health Prospectives vol . 114, No. 5, pp 

691-696 May 2006 

1J .S . General Accounting Office, Pesticides : Improvements Needed to Ensure the Safety of 

Fai-mworkers and Their Children GAO/RCED-00-40 March 2000 

Villarejo, D et al ., Suffering in Silence: A Report on the Health of California's Agricultural 

Workers (200) 

Washington Department of Health SUMMARY OF FOCUS GROUP DISCUSSION 2003 
gam aged 

~se contact 

:contents 

,~c c PG2~",, 

5~~ V ~ ~r 

1 21 ~ - PB87 4598 ,4 060 -S Ofl . 87°u E c 

0 n 9 2 6 2 WASHINGTON, Dc 2 0 

1010 Vermont Ave., NW, Suite 915 

Washington, DC 20005 

2, 

The Honorable Stephen L. Johnson 

Administrator 

U. S . Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue N.W. 

Washington, D. C. 20460