From PSR.org, Physicians for Social Responsibility, Jennifer Sass, PhD and Mae Wu, JD, Aug 2011.
Note from Farmworkers Forum: This is part of an excellent series of essays on PSR.org, the website of Physicians for Social Responsibility. To read more of the series, visit: How does our nation’s reliance on pesticides affect the health of those who plant and harvest our food?
The US uses about 1.1 billion pounds of pesticides each year, representing more than one-fifth of the annual global use of 5.2 billion pounds. Pesticides are designed to harm or kill insects, plants, and other living things and are released over our land, water, and food crops, exposing wildlife and people to them. For these reasons, laws regulating pesticides are much stricter than those for industrial chemicals. Despite the safeguards, however, weaknesses, loopholes, and flaws undermine the legal requirements, their implementation, and their enforcement and oversight.
Pesticides must be registered by the US Environmental Protection Agency (EPA) before they can be sold. EPA can register only pesticides that will have no unreasonable adverse effects on the environment or human health. If, after a pesticide is registered, EPA determines that it no longer meets this standard, EPA has the authority to cancel the registration (but rarely does), thereby removing the pesticide from the market. A company seeking to register a pesticide (the “registrant”) must produce dozens of scientific studies for EPA to assess various aspects of the chemical, including toxicity, ecological effects, and environmental fate. EPA then determines whether the pesticide meets the safety standard. Unfortunately, despite all these data, harm still occurs. The required toxicity studies do not include many important endpoints such as immune system toxicity, endocrine system disruptions, learning deficits, or chronic illnesses. Yet, all of these endpoints have been linked to pesticide exposure.    Harm also occurs because pesticides are reviewed only every fifteen years, leaving long lag times between science and regulations.
Recent NRDC research revealed another problem with pesticide regulation: the majority of pesticide products are granted “conditional registrations” without all required information. EPA’s own analysis confirmed NRDC’s findings that 69%, or 11,000, of all 16,000 pesticide registrations are conditional. An NRDC report of this problem is currently in preparation. The failure of conditional registrations was highlighted this summer when the conditionally approved herbicide Imprelis® was linked to tree deaths around the country, prompting the manufacturer, DuPont, to recall the pesticide. 
Another problem is that once a pesticide is registered, later-developed scientific evidence of harm is often ignored by EPA for decades in favor of industry-sponsored studies showing no harm. For example, EPA recently removed endosulfan from the market due to its “unacceptable neurological and reproductive risks to farm workers and wildlife.”  However, the cancellation of its registration came only after decades of public comments, a legal petition, and a lawsuit by NRDC.
NRDC has pushed EPA to cancel dozens of pesticides. For example, exposure to chlorpyrifos during pre-birth and early life stages has been associated with poor birth outcomes and long-term neurobehavioral deficits. Although residential uses of chlorpyrifos were eliminated 10 years ago, approximately 10 million pounds are still used on farms, putting farm workers and their families at risk. Last year, NRDC, Pesticide Action Network, and Earthjustice sued EPA for failing to remove chlorpyrifos from the market. EPA is now reviewing the health effects of chlorpyrifos, but without committing to incorporate the new science.
Also problematic, EPA often ignores the particular concerns for farm children. Farm children, especially farm worker’s children, are exposed to pesticides through residues from their parents’ skin and clothing, soil and dust tracked into their homes, contaminated soil and other surfaces in areas where they play, food eaten directly from the fields, drift from agricultural pesticide applications, contaminated well water, and breast milk from exposed farm worker mothers. Over a decade ago, NRDC and more than fifty organizations petitioned EPA to specifically consider farm children impacts in its registration decisions. Although EPA denied that petition, it recently changed its mind and proposed to consider farm children in its risk assessments.
Pesticides regulations would benefit from many improvements. NRDC recommends that EPA do at least the following:
- Require an alternatives analysis with all risk assessments that includes consideration of reduced-risk chemical and non-chemical alternatives to conventional pesticides.
- Always add a safety factor for agricultural uses to protect pregnant women and farm workers’ children who either accompany their parents to work or themselves work in the fields.
- Routinely include new science in pesticide risk assessments where it would support more health protective regulations.
- Require registrants to develop pesticide-specific biomonitoring and diagnostic tests so that EPA can detect a pesticide and effectively enforce its regulations or measure the efficacy of its mitigation measures.
EPA can do more to protect farm workers and their families from harmful pesticide exposures. Doing less is inexcusable and unlawful.
Editor’s note: if you’d like to take action on pesticide policy, click here.
 Colborn T. Environ Health Perspect 2006
 Rudant et al. Environ Health Perspect 2007
 Kamel et al. Am J Epidemiol 2007
 Hoppin et al. Am J Respir Crit Care Med 2002
 Jennifer Sass’s blog. Three new government-funded studies link pre-natalpesticide exposure and later learning disabilities. April 21, 2011.
 Jennifer Sass’s blog. What’s all the ‘chlorpyri-fuss’ about? We filed a lawsuit to ban it! July 22, 2010.
 EPA Chlorpyrifos: Preliminary human health risk assessment for registration review. June 30, 3011. EPA-HQ-OPP-2008-0850.
 Bradman et al. J Expo Anal Environ Epidemiol 1997. See also Fenske et al. Env Health Perspect 2002
 Natural Resources Defense Council et al., Petition for a Directive that the Agency Designate Farm Children as a Major Identifiable Subgroup and Population at Special Risk to Be Protected Under the Food Quality Protection Act (1998)
 EPA Policy Paper on Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields, and Pesticides with No Food Uses. EPA-HQ-OPP-2009-0889-0002. More information can be found on the EPA website.