Comments to the EPA on Chlorpyrifos
(i.e. dursban)

...study showed that using chlorpyrifos, even in a manner consistent with the label, can lead to exposures well above the level considered safe for infants and children by the EPA.

[ More About Chlorpyrifos ]

[ Pesticide Poisoning and Kids ] * [ Symptoms of Pesticide Poisoning ]
[ MEMORIAL TO VICTIM of PESTICIDE POISONING ]

Subject:   Chlorpyrifos Comments to EPA from SCRAM------
Date:       Sun, 27 Feb 2000 16:15:47 -0500
From:        Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To:     Lyndon Hawkins <hawkins@empm.cdpr.ca.gov>
          State of California, Department of Pesticide Regulation
          Integrated Pest Management

Dear Lyndon, I thought you might like to read the following Chlorpyrifos Comments to EPA from SCRAM. There were originally sent Sun, 02 Jan 2000 19:41:56 -0500 - To: ccox@pesticide.org. -From: Cheryl Ann Gross <honey2@mindspring.com - Re: Docket Control Number OPP-34203.

Sarasota/Manatee Citizens Rally Against Malathion (SCRAM) has the following comments regarding the EPA Preliminary Risk Assessment of chlorpyrifos:

1.     We concur with many of the HED conclusions regarding the potential risks of chlorpyrifos exposure, as noted in their memorandum dated October 18, 1999. However, HED also makes suggestions to reduce exposure risks from indoor, termiticide and broadcast turf applications. These include:

· Revising labels to include appropriate intervals between treatments
· Reducing exposure by eliminating concentrates which require mixing
· Requiring more training of PCO's and more supervision during application
· Requiring PCO's to clean up spills and misapplications.

While these suggestions would somewhat ameliorate exposure risks, they do not go nearly far enough in protecting human health, in particular that of children, infants and fetuses.

Chlorpyrifos is readily available for multiple uses and is heavily employed both indoors and outdoors by a wide variety of applicators. The majority, including homeowners, do not have licenses. Therefore, PCO requirements will not affect or protect them. There is no way to enforce application interval adherence by anyone, including PCO's and LCO's. At the present time PCO's, LCO's and their employees do not abide by recommendations for PPE, wind speed restrictions or product effectiveness against the target insect. Often, applications are done routinely, even in the absence of any pest problem. Applications are based on contractual monthly agreements and property owner misperceptions that such frequent applications are necessary.

In the case of homeowner applications, they frequently fail to read labels and often exceed recommended applications or apply the chemical inappropriately, such as to clothing and water. They also ignore drift factors, the presence of children and pets and the need for protective clothing, feeling that if a product is available for purchase and has been reviewed by the EPA, it must be safe. They often confuse EPA registration with EPA endorsement and approval. The fact that this product can be purchased off the shelf at drugstores, grocery stores and numerous other retail outlets without so much as an MS/DS or verbal warning also lends an unwarranted appearance of safety.

2.     The products are stored inappropriately in retail outlets, often next to food or other items, which may be contaminated by the pesticide. Chlorpyrifos is volatile and the product off-gases, exposing shoppers and employees to toxic fumes, which can build up within a confined space.

3.     Broadcast turf treatment - Chlorpyrifos use on lawns creates a multiple exposure setting for children. We share HED's conclusion that residential post-application risk characterization exceeds the level of concern for both liquid and granular formulations. Applicators often tell the public that chlorpyrifos liquid is safe once dry and that there is little or no exposure risk from granules. This false and illegal assurance of safety leads to a failure of customers to restrain children and pets from coming in contact with treated lawns. Both children and pets are closer to the ground than adults and play on the ground; the skin of children is more permeable and they frequently wear less clothing than adults; their immune, detoxification and nervous systems are underdeveloped, making them less able to detoxify and excrete pesticides and making them more susceptible to the effects of pesticides; they have more rapid metabolism, inhaling more frequently (the air intake of an infant at rest is twice that of an adult per pound of body weight) and metabolizing substances more rapidly; children have frequent hand to mouth and eye contact, enhancing absorption through mucous membranes and ingestion.

Additionally, drift and foot traffic ensure that a portion of any chemicals applied outdoors will end up indoors. Therefore, even if precautions are taken to keep children and pets off a treated lawn, they will suffer continual exposures.

4.     If the interior is also treated, the exposure is obviously increased. Chemicals applied or tracked indoors are not exposed to sunlight, rain, wind, temperature extremes or biological agents which break them down. They and their contaminants may remain in their original state for a significant period of time, often years. Children and pets will again be those suffering maximum exposure, as they play on floors and rugs and play with and chew on toys. The same factors listed above for outdoor exposure which make children more susceptible to the health effects apply.

A Rutgers University study published in Environmental Health Perspectives, an NIH Journal, January 1998 investigated the level of chlorpyrifos that adhered to surfaces and objects in a room after it had been treated with the pesticide and ventilated according to the manufacturer's instructions. This study showed that using chlorpyrifos, even in a manner consistent with the label, can lead to exposures well above the level considered safe for infants and children by the EPA.

5.     Additionally and in particular in southern states such as Florida, there will be exposures to chlorpyrifos and numerous other pesticides in multiple settings - mosquito control, schools, public buildings, parks, athletic fields, restaurants, theaters, etc. When all this is added to food and water exposures to chlorpyrifos and other chemicals, the risk cup will have been seriously exceeded. Therefore, this EPA Risk Assessment cannot be considered complete, based on the statement in the HED October 1998 memorandum: "Cumulative risk assessment considering risk from other pesticide or chemical compounds having a common mechanism of toxicity is not addressed in this document".

6.     We agree with HED's conclusions that there is an age-related sensitivity to chlorpyrifos exposure for the young. We are very concerned about recent studies indicating chlorpyrifos affects the developing brain of neonates during cell division and the 1999 EPA study relating to chlorpyrifos and its metabolites affecting neuronal differentiation. These and numerous other studies relating to children's sensitivity to chlorpyrifos and other OP's refute DAS's claim that the FQPA additional risk factor for children should not apply. Cholinesterase inhibition in rats provides absolutely no accurate indication of human young susceptibility to chlorpyrifos exposure and the potential resultant long-term effects on intellectual, emotional, physical and motor skills development. The learning disabilities which may be inflicted upon a child by chlorpyrifos exposure cannot be measured in a laboratory rat.

SCRAM can see only one method by which the devastating and well-documented impacts of chlorpyrifos on the young and other sensitive populations can be avoided. That is through the elimination of all non-agricultural uses and the eventual phase-out of agricultural uses, with their replacement by safer alternatives. This product should under no circumstances be available for purchase in any form for indoor, termiticiding, lawn or ornamental uses by the general public, PCO's or LCO's. Safer, effective alternatives are already available for all of these uses and should be implemented without delay.

SCRAM will be sending supporting documentation of its statements by mail.

Sincerely,

Cheryl A. Gross, MS
President

Nina Powers, Horticulturist
Board of Directors

Well Lyndon, The simple question remains: "Do you want to protect people - or do you want to protect your "registered" POISONS?" There are many more economical, safer and far more effective unregistered alternatives. When will it be "legal" (in your opinion) to use these safe and effective alternatives rather than your "registered" POISONS to actually control pest problems in California?

Respectfully, Stephen L. Tvedten

 

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