School Pesticides IPM Rule Up For Public Comment
People not able to attend the public hearings, or wishing to supplement their comments at the hearing, can submit written comment up until 4 p.m. July 17, 2002. Comments can be submitted by mail, e-mail or fax:
Fax: (207) 287 7548
BACKGROUND FOR TESTIMONY/COMMENT ON PROPOSED BOARD OF PESTICIDES CONTROL STANDARDS FOR PESTICIDE APPLICATIONS AND PUBLIC NOTIFICATION IN SCHOOLS
The following information, excerpted from MOFGA's testimony on pesticides legislation in 2001, and updated with new data from the BPC's March, 2002 Pesticides Sales Data Report, is provided to help citizens formulate their own comments on the proposed pesticides in schools rule.
It has been well recognized since a 1993 report by the National Academy of Sciences, and was recently acknowledged in the October, 2000 Report of the School Integrated Pest Management Survey of the Maine Department of Agriculture, that "children are more vulnerable to pesticide exposure than adults." In December, 2000, the Environmental Protection Agency released "America's Children and the Environment: A First View of Available Measures." (www.epa.gov/children/indicators/download.htm). The report notes that cancer is one of the two diseases identified as priorities by the Interagency Task Force on Environmental Health Risks and Safety to Children, organized by the EPA and DHHS. Cancer is the leading cause of death by disease of children under the age of 15. Cancer incidence for children under 20 has increased from 128 cases per million children in 1975 to 154 cases per million in 1995, a 20% increase.
Certain specific forms of cancer have risen dramatically. 1998 National Cancer Institute data show that the percentage of cancer increased in children 0-4 years old between 1973 and 1995:
While we in Maine often take pride in the relative healthfulness of our environment, Maine cancer statistics for children, who are the least likely to have "lifestyle" causes for their disease, do not bear out that perception. Judith Graber, epidemiologist for the registry, has reported that the 1995 and 96 data indicate an annual childhood cancer incidence rate for the age group of 0-14 years of 436 cases per million, above the national average of 432 cases per million.
Twelve of the 26 most widely used pesticides in the U.S. have been classified as possible or probable carcinogens by the EPA based on studies of laboratory animals, with an annual use that totals 380 million pounds. (atrazine (C=possible), metolachlor (C), metarn sodium (B2=probable), dichloropropene (B2), cyanazine (C), pendimethalin (C), trifluralin (C), acetochlor (B2), chlorothalonil (likely), mancozeb (B2), fluometuron (C), and parathion (C). While atrazine has recently been declassified as a carcinogen by the E.P.A., the pesticide was reported in April, 2002 to have caused male frogs to grow female sex organs at very low levels by a research team at the University of California Berkeley, and is likely to be reclassified by the EPA as a hormone disrupter.
The just released Maine Board of Pesticides Control Report of Pesticides Sales and Commercial Use for Calendar Year 2000 (March 29, 2002) reports the following pesticides with suspected associations with cancer or other chronic toxic effects among the top ten best sellers in retail sales reports in Maine: chlorothalonil (777,000 pounds sold in 2000); mancozeb (514,000 pounds); glyphosate (Roundup) (120,000 pounds); 2,4-D (48,000 pounds); atrazine (43,000 pounds). Among the top ten best sellers in wholesale sales reports in Maine [for a detailed explanation of the nature and relationships between these reports, see MOF&G article, "Pesticides Sales Estimates May be Tripled," at www.mofga.org ]: mancozeb (833,973 pounds); chlorothalonil (135,369 pounds); and glyphosate (123,903 pounds). [for more information on toxicity of these and other pesticides, consult www.scorecard.org, www.ncamp.org, www.pesticide.org, http://ace.orst.edu/info/extoxnet, or www.epa.gov/pesticides ].
While many government experts have traditionally been reluctant to definitively tie pesticide use to the increases in rates of childhood (or other) cancers, the December, 2000 EPA report on Children's health makes that positive connection:
Evidence from epidemiological studies suggests that environmental contaminants such as pesticides and certain chemicals, in addition to radiation, may contribute to an increased frequency of some childhood cancers. Some studies have found that children born to parents who work with or use such chemicals are more likely to have cancer in childhood. It may be that the chemicals cause mutations in parents' germ cells that may increase the risk of their children developing certain cancers, or perhaps the parental exposure is passed on to the child while in utero, affecting the child directly. Children's direct exposures to such chemicals may also contribute to cancer. (Report at 52)
In October, 2000, the Maine Department of Agriculture released a startling and excellently conceived and reported study: "What's 'Bugging' Our Schools? Pest Concerns and Pesticide Use in Maine Public Schools." State entomologist Kathy Murray, the Department's IPM specialist, surveyed all of Maine school districts on their pesticide use, accomplishing an impressive 88% response rate. The survey results reveal that most pesticide applications in Maine schools are made illegally, by school custodial staff who are not licensed and have no training in pesticide application, safety, or health concerns. Only 5% of schools provide written notice when pesticides are to be applied, and 82% of respondents have no integrated pest management plan in place. Still unanswered by the survey, however, are what types of pesticides the schools are using, in what quantities, and what risks they present our school children and staff, who spend 180 days a year in school environments.
The Agriculture Department and the University of Maine Cooperative Extension Service are proceeding apace, with the help of substantial EPA grants, to provide education services to schools on integrated pest management, in both indoor and outdoor pesticide applications. They have also prepared a model school pesticides IPM Manual, which should minimize the time required for individual school system to adopt and implement their own IPM programs. The Camden/Rockport Five Towns CSD has lead the way by adopting, last year, a school IPM program which provides written notification to parents every time a pesticide application will be made in their schools.