FYI
Beyond Pesticides
National Coalition Against the Misuse of Pesticides
701 E Street, SE, Washington DC 20460, 202-543-5450 (voice), 202-543-4791
(fax)
March 17, 1999
The Honorable Carol Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Re. Immediate action requested regarding public interest participation in a meeting on pesticides and schools taking place today and tomorrow (3/18/99).
Dear Administrator Browner:
I am writing you to express a deep sense of concern and hope for immediate corrective action in the lack of inclusion of public interest and environmental groups in an EPA-funded workshop, entitled National IPM in Schools Workshop, taking place today, March 17 and tomorrow, March 18 in Crystal City, VA. The invitation-only meeting to discuss integrated pest management in schools (IPM) is being organized by Indiana University on a grant that I understand comes through the Biopesticides, Pollution, and Prevention Division of the Office of Pesticide Programs.
As a taxpayer, I am outraged. As a parent, I am deeply worried. As an environmentalist, I am disgusted.
Let me be blunt. The level of arrogance and one-sidedness associated with a government-supported meeting on children and schools not including the very public interest groups that at the grassroots have successfully promoted programs and policies to protect our children from pesticide use in the schools is beyond imagination. It runs contrary to EPA's stated interest in transparency and inclusion. This is all made worse by the fact that one of the biggest promoters of pesticide-intensive integrated pest management, the trade association representing conventional chemical-intensive pest control operators, the National Pest Control Association (NPCA), has a seat at the table. So does a consultant that works with the industry. I can assure you that, after having participated in a debate at the annual meeting of NPCA on the definition of IPM, the differences in definition are deep and serious and have profound ramifications when it comes to pesticide use reduction and implementation of programs in schools, homes and communities across the country.
When we brought to the Program's attention that the public interest community was absent from the invitation list, we were extended an invitation to sit in as an observer and asked not to make any comments. While it seemed odd that EPA would not want to reach out to the very people that have been instrumental in effecting practical changes in school pest management, it became absurd when I arrived for the first day as an observer and found the pro-chemical lobby seated at the table.
This is a very serious matter that raises critical concern about the integrity, sense of fair play, and degree to which dialogue on a critical issue that affects the health of children is truncated. For example, when one participant asked whether pesticides could be safely used around children, the response was basically yes. There was no discussion on the critical questions that EPA is struggling with under the Food Quality Protection Act on calculating children's exposure, pesticide impact on developing organs, aggregate risk calculation of dietary and nondietary exposure, and common mechanism of effect. Is it not important for the policy and program leaders who hold the decisions on pesticide use and our children's health in their hands to have the benefit of a full and balanced discussion of these issues? When parents say that they want to embrace the precautionary principle and take the extra steps to adopt an integrated pest management program that utilizes cultural, biological and mechanical practices first, wouldn't these policy and program leaders be better informed by a balanced discussion?
The national IPM meeting continues tomorrow. As an administrator seeking to ensure a thorough, fair and honest discussion of issues critical to the health of our children, I urge you to introduce some balance into these proceedings and invite a member of the public interest community. Many people have worked for many years at the grassroots to bring the issue of children's exposure to pesticides in schools to the level of local, state and national attention that it now receives. I urge you to make sure that these people's voices are heard as the United States Environmental Protection Agency engages in and supports the crafting of national policy on one of the most critical public health issues for our children. As you know, Beyond Pesticides/National Coalition Against the Misuse of Pesticides has a petition in front of EPA calling for the agency to promulgate national standards to protect children from pesticides in schools. I look forward to your response to this petition and working with you.
Thank you for your immediate attention to this request.
Sincerely,
Jay Feldman
Executive Director
cc. Susan Wayland
Marsh Mulkey
Janet Anderson, Ph.D.
National Coalition Against the Misuse of Pesticides
701 E Street, SE #200
Washington, DC 20003
ph 202-543-5450
Fax 202-543-4791
http://www.ncamp.org
ncamp@ncamp.org
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