TOXICS
INFORMATION PROJECT (TIP)
(Lighting the way to Less Toxic Living)
LIBERTY GOODWIN, DIRECTOR
P.O. Box 40572, Providence, RI 02940
Tel. 401-351-9193, E-Mail: TIP@toxicsinfo.org
WEBSITE: www.toxicsinfo.org
SOME COMMENTS FROM 2005 TESTIMONY SCHOOL LAWN PESTICIDE
TESTIMONY BEFORE
RI STATE SENATE
ENVIRONMENT & AGRICULTURE COMMITTEE,
SAFETY
ISSUES: Surveys show most people assume
that if a product is allowed to be sold, it is safe. Unfortunately, that’s not true.
In fact, the EPA has made it clear that no pesticide can legitimately be
described as safe, and penalties have been assessed on companies making such
false claims. Dow Chemical, was fined
$2 million dollars for persisting in such dishonest corporate behavior even
after being reprimanded by NY State Attorney General Spitzer. Secondly, the reason EPA does not permit
such claims is that no research can truly support the claim that any registered
pesticide will do no harm, because:
1. Toxicity
is the reason that the product needs to be registered.
2. Testing is
limited to single chemicals, yet exposure is always to combinations.
3. It has
been shown that interaction between chemicals may product different or greater
reactions and health effects that one lone ingredient.
4. Many
problems caused by pesticides are chronic conditions that do not become
apparent for years after the first exposure.
5. Many
problems are associated with low level exposure over time, yet testing is
usually done with acute doses and short time frames.
6. Most
testing is done by the companies themselves, who stand to make billions of
dollars by selling the product when approved.
Clouds of questions about such studies have arisen, including claims of
pressure on researchers to suppress or alter findings. It certainly seems a “conflict of interest”
and “fox guarding the henhouse” situation.
EFFICACY OF REGULATION: The federal government’s record of protecting the public from
toxic pesticides is a dismal pattern of failure. Over and over again, products are thrown onto the market, only to
be withdrawn, many years later, when evidence of their deadly effects cannot be
ignored. This happened, most famously,
with DDT, originally advertised as so safe you could bathe in it. Sometimes, as older pesticides are phased out because of toxicity,
their replacements are ultimately found to be just as toxic. This was so with chlorpyrifos [Dursban], an
organophosphate that became popular as chlordane was phased out. Once widely used as a pesticide in household
and professional applications, chlorpyrifos
was found to accumulate heavily on surfaces long after it was applied, and
complaints of health effects included headaches, dizziness, muscle twitching,
vomiting, blurred vision, and other problems.
The product was withdrawn for residential uses by 2000, but is still on
some store shelves, and remaining supplies are still being used. In short, the real
“testing” of these products is on the American public.
Protection
at the state level has its own problems.
Especially in these times of reduced state budgets, it is difficult to
find the money to allow RI DEM to effectively monitor or police pesticide use,
much less engage in or fund the extended studies that might produce significant
health data. Moreover, to be valid,
such research would need to take many years.
Even if state lawmakers pass strong protective legislation, follow-up is
challenging. One difficulty with provisions requiring use of Integrated Pest
Management (IPM) for example, is the wide range of choice permitted by that
concept – and differing interpretations of what it means. Too often, the lawn care company or even the
individual pest control operator makes that choice – and may decide that the
accustomed pesticide application practices are the “least toxic” because that
is the easiest thing to do.
OTHER CONSIDERATIONS: It is common to make decisions based on a
“risk-benefit ratio” model. Because
absolute “proof” of causation in many cases is difficult to produce, the
chemical companies claim we should not remove their products from consumer use. I urge you to think carefully about what, in
this case, “benefit” and “risk” really entail.
The benefit? Sometimes a
beautiful green field of grass. This is
not even assured – the efficacy of repeated pesticide applications is
questionable. There are problems with
developed resistance, the need to apply more product to get results. Also, broad spectrum pesticides kill off
natural lawn care helpers, such as ladybugs and worms. Even a High School student in this year’s RI
Science Fair demonstrated this principle – by a project showing how insecticide
killed beneficial fungi that could have been working to keep the lawn
healthy. Ask yourself, also – haven’t
you ever seen a gorgeous grassy field that did not have the “benefit” of
pesticides? Of course you have.
Moreover, the question must be
asked – how important is it that the field be “perfect”? Kids play in many places on fields without
chemicals or even much care. They still
have fun, the game goes on. The
chemical mavens suggest, in desperation it would seem, that the young people
might trip on the deadly crabgrass and fall down! The truth is, kids do fall down sometimes no matter how even the
grassy surface, skin their knees, come home covered with dirt or even mud from
an imperfect spot on the field. You
give them a bandaid for the knee, throw the kid in the shower and their clothes
in the washer.
On the other hand, what are the risks of allowing
children to roll around on fields doused with poison? A team of medical researchers with the Ontario College of
Family Physicians, a Canadian professional society for family doctors, released
a report last year that analyzed 250 previously published epidemiological
studies from around the world on possible adverse effects of pesticides on
human health. The report found
"consistent positive associations" between popular pesticides used in
lawn care and cancers, reproductive problems, neurotoxic effects and other
serious illnesses. This is just one of
many studies linking pesticide exposure to health effects, especially in
children. Children face unique hazards from
pesticide exposure. They take in more pesticides relative to their body weight
than adults in the food they eat and air they breathe. Their developing organ systems often make
them more sensitive to toxic exposure.
The U.S. EPA, National Academy of Sciences, and American Public Health
Association, among others, have voiced concerns about the danger that
pesticides pose to children. The body of evidence in scientific literature
shows that pesticide exposure can adversely affect a child's neurological,
respiratory, immune, and endocrine system, even at low levels. Some pesticides, such as pyrethrins and
pyrethroids, organophosphates and carbamates, are also known to cause or
exacerbate asthma symptoms.
The organization Beyond Pesticides has begun
compilation of a list of pesticide incidents at schools (40 when I last looked)
that involved damage to the health of both students and school staffers. See their website at: http://www.beyondpesticides.org/schools/publications/school_pirs.htm
for details. I have personally heard
the stories of numbers of people who have suffered from pesticide exposure at
school and elsewhere. About a year ago,
a group of children on a soccer field in Georgia were sickened by lawn
pesticide spraying, and two were taken to the hospital in anaphylactic
shock. I just learned from a contact
there that now two children in that soccer league have Non-Hodgins lymphoma, an
uncommon cancer in youngsters that has been linked to pesticides. How in the
world can the perils of a few weeds be compared to the risk of seeing a child
gasping for breath with an asthmatic attack, suffering neurological damage,
perhaps autism or ADHD, childhood leukemia or other cancer? (Understand clearly that this bill does NOT
have any prohibition vs. pesticide use for the purpose of protecting human
health, such as pest control vs. mosquitoes, ticks or wasps.)
A WIN-WIN SOLUTION
I suggest to you that this is that rare opportunity
to achieve a win-win resolution for everyone concerned. Rhode Island, and its lawn care
professionals, can, through this legislation and the switch to organic lawn
maintenance, become a model for others.
No work will be lost – it will just be less toxic work! Pest control applicators are actually a
high-risk group themselves for cancer and other health problems. This change could save the life and health
of some of the very people opposing the legislation! Parents and children around the state can rest easy knowing that
they can happily play in any park or athletic field without exposure to
poisons. Moreover, the cost is likely,
especially over a few years, to be comparable to or even less than toxic
methods. One school district reduced
its pesticide use by 90 per cent and its budget dropped 40 per cent in the
process! We don’t need to wait for a
certainty of harm that is unlikely to be found. We don’t need to continue allowing those who profit from
pesticide sales to use us and our children as guinea pigs. Which of today’s “safer” formulations will
be pulled off the market in 10, 20 or 30 years after ruining the health of
hundreds of youngsters? The
Precautionary Principle is anathema to the chemical industry – because it says
that avoiding harm to people is more important than providing profit to
them. It says if we don’t have all the
facts, we should err on the side of protecting precious human life.
In this
case, the alternative is a happy one.
With good care and the correct species of plants, we can do it just fine
without the risk. Moreover, there are
many resources available to help those who need or want to get off the
drugs. Our organization already has
some good information on our website, and is compiling a Less Toxic Landscaping
Resource Guide for Rhode Islanders to lead them to information, services and
supplies. We stand ready to try to
track down the answers to any questions or problems that may arise in making
the change to healthier lawn care, for schools, towns or individual homeowners.
Respectfully Submitted,
Liberty Goodwin, Director
Toxics Information Project (TIP)
TOXICS
INFORMATION PROJECT (TIP)
(Lighting the way to Less Toxic Living)
Liberty Goodwin, Director
P.O. Box 40572, Providence, RI 02940
Tel. 401-351-9193, E-Mail: TIP@toxicsinfo.org
Website: www.toxicsinfo.org
CLARIFICATION OF “LAWN PESTICIDES” COVERED UNDER PROPOSED RI SENATE BILL S302 --- RESTRICTIONS ON THE GROUNDS OF SCHOOLS & DAY CARE CENTERS.
It has been suggested to us that the term “lawn pesticides” in this bill is too vague, and could result in the exclusion of some benign, non-toxic pest control options. Therefore, we offer the following suggestions on defining what we are proposing to ban, and what would be allowed under the legislation.
ALLOWED PESTICIDES
(All
products should have all “inerts” non-toxic and disclosed.)
(1) Insecticidal
Soaps
Exception:
Insecticidal soap products containing pyrethrin, a restricted material.
(2) Herbicidal
soaps or fatty acids: Herbicides,
animal-derived .
Exception: Synthetically
processed.
(3) Bt (Bacillus
thuringiensis)
Exception: Bt
products developed using genetic engineering, or with prohibited inerts.
(4) Nematodes
& other biological control organisms:
Arthropod parasitoids, arthropod (insect, spider, and mite) predators
& parasites.
(5) Dormant oils - Vegetable based oils
are allowed.
Exception: Petroleum
based oils are prohibited.
(6) Pheromone
traps
(7) Acetic
Acid/Vinegar
Exception: If prepared by synthetic processes, or
containing prohibited wetting agents.
(8) Diatomaceous
Earth
(9) Biological,
living control agents.
(10) Botanical Insecticides. (But not pyrethrin)
(11) Corn gluten.
(12) “Certified Poison Free”, with Scientific
Certification Systems (SCS) logo on the label.
(13) Products without an EPA Pesticide Registration
number.
(14) Products without “warning”, “caution” or “danger” on
the label.
(15) Products with “Minimal Risk Product EPA exempted
under FIFRA Section 25 (b)* on the label.
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PROHIBITED PESTICIDES
(Adapted from California's Healthy Schools Act of 2003, AB 1006)
(1) Those with the highest acute toxicity as defined by
EPA Toxicity Categories I and II;
(2) Containing N-methyl-carbamate, neurotoxic organophosophorus compounds, or
pyrethoids;
(3) Containing active ingredients rated by EPA as known, probable or possible
human carcinogens.
(4) Containing active ingredients that cause birth defects,
reproductive harm, or developmental
harm as identified by EPA.
(Mutagens, teratogens, reproductive toxins, developmental neurotoxins,
endocrine disrupters or immune system toxins.)
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ALTERNATIVE POSSIBILITIES
Allow use
of only those products permitted under Organic Farming regulations.
or
Include in
the bill at this time only the four prohibitions listed above.
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