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Global Water & Biology, Conservation Research Institute ®
Children of any age may work on their parents’ farm or on small farms. Children of all ages walk through farmland to school or other destinations. Very young children may accompany their parents to the fields when other childcare options fail. 15 Taken together with children’s unique exposure patterns from activity close to the ground, hand-to-mouth behavior, and the fact that, per pound of body weight, children eat, drink and breathe more than adults,16 farm children may be the most pesticide-exposed group of people in the nation.An increasing body of scientific evidence, including biomonitoring data and residential exposure studies, indicates that farm children face particularly significant exposures and health risks from pesticides. As many as a dozen different pesticide residues have been found in household dust in farm homes, including agricultural insecticides and herbicides not registered for use in the home. 17The study tested for four organophosphate insecticides: azinphos-methyl, phosmet, chlorpyrifos, and ethyl parathion. All four were found in dust inside 62 percent of farm homes in a Washington State study, compared with 9 percent of non-farm homes. 18 More than half of the 48 farm homes in the Washington study had residues of one or more of these four organophosphates in the soil where children played next to the house. Less than 20 percent of non-agricultural homes had any of these pesticides in soil. Concentrations of pesticides are significantly higher in farm homes as well. In California, two pesticides, diazinon and chlorpyrifos, were found on the hands of three out of five farmworker children sampled, at levels predicted by a screening risk assessment to result in exposures over the reference dose.19 None of the children in non-farmworker homes had detectable pesticide residues on their hands. On Midwestern and North Carolina farms, a total of 17 different pesticides, including agricultural herbicides such as atrazine, alachlor, 2,4-D, and dicamba, have been found on the hands of non-working children ranging from ages three to fifteen.20 In Washington State, two-thirds of farm children under age six had a metabolite of two agricultural organophosphate pesticides in their urine (azinphos-methyl and phosmet), compared with less than half of the non-farm children living in the same area. The average concentration of the residue was four times higher among the farm children.21 Thus farm children are likely to be exposed to insecticides and herbicides not licensed for household use through numerous non-food same farm as their parents. Children of any age can work on their parent's farm without legal restrictions, even doing hazardous work. (Hazardous jobs include operating heavy equipment like powerful tractors or grain combines; loading or unloading timber; working on a 20 foot high ladder; and mixing, loading or applying certain pesticides.) Twenty eight percent of farm worker children have parents who mix, load or apply pesticides. Mines, supra, note 1 at 21.
sources, at levels higher than other children. In some cases, these exposures appear to result in elevated exposures above current reference doses, and are leading to quantifiable pesticide residues in these children’s bodies. Acting in large measure out of concern for the effects of pesticide exposure on children, Congress unanimously passed the FQPA, which President Clinton signed into law on August 3, 1996. The FQPA amended the nation’s pesticide and food safety laws and mandates that protection of infants and children drive decisions about acceptable levels of pesticide residues in our food supply. The FQPA explicitly directs EPA to take into account children’s unique exposure patterns and greater potential susceptibility to toxic effects when setting allowable residue levels, or tolerances, for pesticides used on food; to add together a child’s exposures to pesticides acting on the body in a common way; and to account for all sources of pesticide exposure, including residential, water, school and air exposure.22 The Act further provides that, in making tolerance decisions, EPA shall consider (among other relevant factors) “available information concerning the dietary consumption patterns of consumers (and major identifiable subgroups of consumers);” “available information concerning the aggregate exposure levels of consumers (and major identifiable subgroups of consumers) to the pesticide chemical residue and to other related substances, including dietary exposure under the tolerance and all other tolerances in effect for the pesticide chemical residue, and exposure from other non-occupational sources” and “available information concerning the variability of the sensitivities of major identifiable subgroups of consumers. . .” 23
The undersigned individuals and organizations request in this Petition that the U.S. Environmental Protection Agency (EPA) issue a directive stating that the agency will recognize farm children as a “major identifiable subgroup” under the FQPA §408 (b)(2)( D)(iv, vi & vii), treating them as a ‘population at special risk’ whose exposures and health status serve as an indicator of potential problems for other population groups and whose health, if protected, would assure a greater level of confidence in protection for the rest of the population. This Petition further requests that, in order to fully protect farm children and all children in making tolerance decisions, EPA:1) fulfill its non–discretionary duty to use the additional tenfold children’s safety factor in establishing, renewing, modifying or revoking tolerances where EPA lacks complete data on farm children’s exposure to a specific pesticide and other substances with a common mechanism of toxicity, as required by the FQPA; 242) in issuing any tolerance, make a specific determination as to the exposures for farm children from all pathways, and assure that these children are fully protected under the
15 Pineros y Campesinos Unidos del Noroeste (PCUN), Testimonies from the Field, Woodburn, OR 1997.16 NRC, Pesticides in the Diets of Infants and Children, Washington DC: National Academy Press, 1993.17 Camann DE, Harding HJ, Clothier JM, Kuchibhatla RV, Bond AE. Dermal and In-Home Exposure of the Farm Family to Agricultural Pesticides. Measurement of Toxic and Related Air Pollutants 1995; VIP-50:548-554. (showed an average of 17 different pesticides on children’s hands); Geno P, Camann D, Harding H, Villalobos K, Lewis R. Handwipe Sampling and Analysis Procedure for the Measurement of Dermal Contact with Pesticides. Arch Environ Contam Toxicol 1996; 30:132-138.18 Simcox et al., supra, note 7.19 Bradman A, Harnly M, Draper W, Seidel S, et al. Pesticide Exposures to Children from California's Central Valley: Results of a Pilot Study. J Expos Anal Environ Epi 1997; 7:217-234.20 Camann DE, Akland GG, Buckley JD, Bond AE, Mage DT. Carpet Dust and Pesticide Exposure of Farm Children, Intl Soc Exp Anal Ann Mtg, Research Triangle Park, NC, November 5, 1997, 1997.21 Loewenherz C, Fenske RA, Simcox NJ, Bellamy G, Kalman D. Biological Monitoring of Organophosphorus Pesticide Exposure Among Children of Agricultural Workers in Central Washington State. Environ Hlth Persp 1997; 105:1344-1353.22 The Food Quality Protection Act (FQPA) provides that in setting allowable levels of pesticide residue on food,the EPA Administrator “shall ensure that there is a reasonable certainty that no harm will result to infants and children from aggregate exposure to the pesticide chemical residue,” (21 U.S.C. §346a(b)(2)(C), (or commonly referred to as §408 (b)(2)(C)(i)(I–III) of FQPA), “including all anticipated dietary exposures and all other exposures for which there is reliable information” (21 U.S.C. §346a(b)(2)(A)(ii). The Agency is charged with basing its tolerance decisions on available information about: food consumption patterns unique to infants and children; special susceptibilities of infants and children to pesticides, including but not limited to neurological effects; effects of in utero exposure; and the cumulative effects on infants and children of pesticides with a “common mechanism of toxicity.” 21 U.S.C. §346a(b)(2)(C)(i)(I–III). 23 21 U.S.C. §346a(b)(2)(D)(iv, vi & vii).24 21 U.S.C. §346a(b)(2)(C). |
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