By KEVIN WALKER
Michigan Correspondent

WASHINGTON, D.C. — The U.S. Environmental Protection Agency (EPA) has written and published a paper that will be used as a guide to regulate pesticides more heavily.

The paper, called Revised Risk Assessment Methods for Workers, Children of Workers in Agricultural Fields and Pesticides with No Food Uses, seeks to protect children who either work in agricultural fields or who are in close proximity to their parents and other field workers. It’s targeted to migrant workers.

The notice of the proposed change was published in the Federal Register Dec. 9, 2009, and the public is invited to comment on the paper until Feb. 8. According to the notice, the paper “describes how the agency will assess pesticide risks not governed by the Federal Food, Drug and Cosmetic Act … Specifically, this will include using an additional safety/uncertainty factor to protect children” and ag workers.

Karen Reardon, spokeswoman for Responsible Industry for a Sound Environment, a pesticides manufacturers trade group, said that there has been a number of notices like this since October 2009. This is the case because the fiscal year for EPA begins in October, and because the agency now has its appointees in place, she said.
“This administration is more anti-chemical, generally, than the previous one,” Reardon said. “(EPA Administrator) Lisa Jackson’s agency is into transparency and significantly expanded enforcement.”

Last November the EPA issued at least two other notices regarding pesticides – in that instance, pesticide drift labeling. The idea behind those policy changes is to improve pesticide drift management, but which could impose more restrictions on their use. The comment period for those proposed changes has been extended to March 4.

According to a statement issued by the EPA on the subject, “these restrictions could include no-spray buffer zones, or requirements related to droplet or particle size, nozzle height or weather conditions at the time of application.” The goal is to “protect people, wildlife, water resources, schools or other sensitive sites from potential harm,” the statement reads.

Regarding the most recent proposed change, certain pesticides would be subject to some additional “safety/uncertainty factors.”
According to the paper referred to above, the EPA has for a number of years taken into consideration certain factors when evaluating how a toxic substance will be regulated.

For example, one safety/uncertainty factor is the difference between the short period of time a lab animal is exposed to a toxic substance and the long period of time a person might be exposed to the substance in the real world.

According to the paper, some of these factors have not been used to judge the safety of a substance for workers in fields or for children who work in fields, as well as children who do not work in fields but who might be exposed to the toxic substance – for example, the non-working children of migrant workers.

According to the paper, “EPA’s experience in evaluating children’s risks in safety decisions and tolerance risk assessments over the last 13 years has confirmed the need to systematically evaluate risks that the young (including infants, children and fetuses) face from pesticides …”

CropLife America (CLA), an association representing agricultural pesticides manufacturers, issued a statement Dec. 9 after the proposed policy changes were published: “CropLife America has consistently supported the use of sound scientific techniques in assessing the potential risks associated with crop protection products.

“While risks associated with all potential sources of exposure should be examined, the benefits of using these products should be carefully considered and analyzed as well … (C)rop protection products are extensively reviewed by the (EPA) to ensure the safety of humans and the environment. CLA is always willing to examine other possible recommendations to promote the safety of farm workers and children …”

There were only a few public comments posted as of last week, but one by Molly Hauck of the Environmental Task Force, Cedar Lane Unitarian Universalist Church, reads as follows: “I support your efforts for a more thorough assessment of risks to workers, including farm workers and farm children, but more needs to be done to restrict the availability of toxic pesticides on the market.”
Anyone interested in learning more about the proposed changes or in making a comment, may go online at www.regulations.gov and paste in the following docket number: EPA–HQ–OPP–2009–0889.

Also, comments may be mailed to: Office of Pesticide Programs (OPP). Address: Regulatory Public Docket (7502P), EPA, 1200 Pennsylvania Ave., NW, Washington, D.C. 20460-0001. Be sure to include the docket number.