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

 

COMMENTS BY LIBERTY GOODWIN, TIP DIRECTOR,

ON PROPOSED RI PESTICIDE REGULATIONS, JUNE 2006

 

  1. Definitions:  We will need to get the list of  “Restrictive Use” and  “State Limited Use” pesticides from RI DEM in order to comment more fully on the proposed regulations.

 

  1. Rule 6 Record-Keeping.  We have serious concerns about the non-disclosure of inerts, which may be the same chemicals as active ingredients in another product. Although this is primarily a result of Federal inaction and weakness, it is our hope that something could be done at the state level to address the problem

 

Possible Actions:          As in Canada, require revealing toxic inerts on label?

Join the ongoing lawsuit by the AGs of NY, MA, CT & Alaska  pressing for a disclosure requirement by the EPA?

Require a stronger warning on labels in RI?

 

  1. Rule 11  Certification Procedure - J:  Certification should be revoked for lying to consumer by commercial applicators about safety-related info - not just because of a false statement on their initial application to be certified.

 

  1. Rule 12  Standards of Competency.  Some familiarity  with IPM and natural alternatives should be a requirement.  We should not assume that toxic pesticides are automatically going to be applied .  Those who do not know of alternatives will certainly not use them, and are likely to employ chemicals more often than necessary.

 

  1. Rule 16  Renewal/Maintenance of License.  P. 27, 28 29, 30, 31.

 

A.              Require, not just allow IPM or natural/organic turf management courses or workshops as part of continuing education. 

B.              Make NOFA and/or SCLT workshops eligible for CE Credit?

C.              Raise fee slightly to cover cost of offering URI course on IPM for credit? (Funding for this has been lacking in recent years.)

 

  1. Rule 19 General Rules.  P. 35, 36, 37

 

A.              Restricted Use or State Limited Use pesticides should not be used at schools at all.

B.              More time needs to be allowed between any pesticide application and children’s presence - especially in shaded areas. Labels underestimate the time needed for product deterioration and sun is needed to facilitate product breakdown.

C.              Treated areas should be clearly marked and protected from foot traffic.  Just because there are no planned activities doesn’t mean kids may not come by to play ball individually.

 

 

  1. Rule 23 Turf Management Signage & Notification, F & G, P. 42-43.

 

A.              Notification MUST be before application or the person requesting it can not protect themselves from exposure.

B.              Signs should be up longer than 48 hrs.  Change from 72 hrs. to 48 is bad.

C.              Lettering should be larger than 1/4 inch. (At least 1 inch, as in another reg)

D.              What’s with the little tiny lawn flags?  They don’t seem to meet specs.

E.               Homeowners applying pesticides should be subject to rules about signs.

 

GOOD CHANGES/PROVISIONS:  Requirement for physical presence of supervisor, storage and transport regulations., the variety of continuing education options.  Thank you for including these!