Why Pesticide Reduction Why Now

Spring 1997

A Policy Paper of the Maine Organic Farmers and Gardeners Association

February 1997

MOFGA has proposed “An Act to Reduce Reliance on Pesticides” in this legislative session. The bill, which is co-sponsored by State Senator Marge Kilkelly, Senate District 16 (Co-chair of the Committee on Agriculture, Forestry and Conservation), and State Senator John Nutting, Senate District 20 (Co-chair of the Natural Resources Committee), would effect a fundamentally positive shift in Maine away from costly chemical dependance. The bill declares State policy “to reduce the volume of pesticides sold [in Maine] without any corre­sponding increase in toxicity.” It states a goal of accom­plishing a 33% reduction in pesticides sales by the year 2002. It applies to pesticide use in agriculture, forestry, ornamental, arborist and turf services, rights-of-way vegetation management, public and private structural pest control (including school buildings) and aquatic pest control. It establishes a broad based Commission to imple­ment this goal according to a step-by-step timetable, through both regulatory and nonregulatory approaches. It directs the Commission to study a possible repeal of the sales tax exemption for agri­cultural pesticides in order to fund research and support for pesticides alternatives, and it charges the Commission to consider an array of tough regulatory actions in any sector that has not accom­plished the reduction goal by 2002.

This is a bill, in short, whose time has come. It can become law with your support. If every reader of The MOF&G takes some time to talk with friends and neighbors about this bill and to contact representatives in Augusta – perhaps sharing this insert with them – pesticide reduction can become a reality in Maine.

Introduction

“The chemical war is never won, and all life is caught in its violent crossfire.” – Rachel Carson, Silent Spring, 1962

The time has come for Maine to get off the pesticide treadmill. Pesticides (including insecticides, herbicides and fungicides) are simply too costly, too risky, and in the long run not effective. Effective alternatives that are safe for our bodies and our environment have been proven, not just in the lab but in the field, not just “away” but here in Maine. The time has come to devote energy and resources to making these methods available to all in Maine – farmers, foresters, state agencies, industry, municipalities and home­owners.

There are strong economic advantages to getting off the pesticide treadmill, in addition to the immediate payback of reduced out-of-pocket costs. Consumers want safer foods and a healthy environment in which to live and raise their children. Putting Maine on the map as a state with a concerted plan to reduce pesticide dependence can be a critical marketing tool – for its products, for its life style. All pesticides used in Maine are manufactured outside the state and represent a significant drain of hard-earned capital.

Right now there is no middle ground in the marketing of agricultural products between certified organic (which is growing rapidly) and conventional, pesticide-laden farming. Pesticide reduction presents an additional opportunity to add markets for Maine agriculture. A “Made Sustainably in Maine” label – indicating production in accordance with a state-approved pesticide reduction program – could go a long way to giving Maine products the value-added attraction that they critically need as they compete in national and (increasingly health conscious) international markets.

The proposed legislation would not establish a “Made Sustainably in Maine” label or the criteria necessary to implement it. It would, however, be the essential first step in that process – declaring the objective of the state to reduce pesticide dependence in Maine and establishing a stakeholder, consensus-building approach to developing a plan for accom­plishing that goal. Pesticide reduction is a win/win situation for the State, the consumer, and the farmer, and the time to do it is NOW.

Pesticide Use: How Dependent Are We?

“As [pesticide] reliance increases, costs of production are likely to rise faster than commodity prices in these regions, thus decreasing farm profits. The long-term economic sustainability of the agricultural industry as a whole and the rural economies in those regions that depend on agriculture may then be in jeopardy.” – Michele C. Marra, Adjunct Associate Professor, Department of Resource Economics and Policy, University of Maine, in The Ecology, Economics, and Management of Potato Cropping Systems: A Report of the First Four Years of the Maine Potato Ecosystem Project

In 1962, Rachel Carson’s Silent Spring laid bare the risks and fallacies inherent in our chemical warfare against pests. Carson’s findings were confirmed in the 1963 report of President Kennedy’s Scientific Advisory Panel, which called for the ultimate ban of all persistent toxic pesticides. Nevertheless, reliance on pesticides has grown significantly since the 1960s. Although in some sectors, smaller quantities of some pesticides are being used, this reduction is often accomplished by switching to more potent and persistent products that work at lower rates. And despite the banning of several highly toxic pesticides discussed in Silent Spring, and regulatory measures intended to screen new pesticides for safety, a recent analysis of the pesticides in use over the last 20 years and of their known acute and chronic toxicities for mammals concludes that the risks presented by pesticides are as significant today as they were in 1962. [1]

National Data: Pesticide Sales and Use

• According to preliminary EPA estimates, 1.25 billion pounds of pesticide active ingredients were sold in 1995 in the U.S., more than double the 540 million pounds sold in 1964. [2]

• 76 percent of the 1995 pesticide sales (by volume) were to the agricultural sector, 12 percent to other industries and government, and 12 percent to homeowners and gardeners. [3]

• Total expenditures on pesticides in 1995 were $10.42 billion, more than double the $4.83 billion spent in 1979. Adjusted for inflation, pesticide expenditures have grown about 3 percent annually. [4]

• Farmers in particular are spending more on pesticides. Between 1983 and 1993, agricultural expenditures on pesticides rose almost 35 percent. In 1991, the $5.7 billion that farmers spent on pesticides was 3.9 percent of total production costs, a share that rose to 4.2% two years later. [5]

• Pesticide expenditures of several hundred dollars per acre remain common on farms producing fruits and vegetables and ornamental crops. [6]

• Herbicides account for 65 percent of farmers’ pesticides expenditures. [7] The percentage of crop acres treated with herbicides has risen from about 50 percent in the 1960s to more than 96 percent in the 1990s. [8] The average number of active ingredients of herbicide applied per acre has risen from one active ingredient on about half the planted acres to more than 2.5 active ingredients on almost all acres. While total pounds of herbicides applied have decreased for some major row crops since 1982, this is due to the lower rates of application needed for many of the more potent herbicides gaining market share, not because of any reduction in reliance on herbicides as a weed management tool. [9]

• The average rate of insecticide application on major field crops has increased from 1.05 pounds active ingredient per acre in 1991 to 1.33 pounds in 1995, and the average number of treatments with a distinct active ingredient per acre has almost doubled, from 1.8 in 1991 to 3.5 in 1995. [10]

• Across all sectors (agriculture, industry, and home and garden), EPA data show insecticide use rising from 295 million pounds in 1986 to 334 million pounds in 1995 – a 13 percent increase in 10 years. [11]

Maine Data

There is no reason to believe that trends in pesticide reliance in Maine differ significantly from national trends. Statistical compilations of pesticides sales in Maine, however, exist only for the years 1991 (agriculture) and 1995 (agriculture and forestry). [12] The State Board of Pesticides Control (BPC) receives more than 600 reports of pesticide sales by retailers for each year, but has lacked the time and resources to compile and verify data for other years. The 1991 and 1995 totals, moreover, do not necessarily include potentially significant quantities of pesticides purchased from some out-of-state wholesalers. A pending bill requested by the BPC would considerably facilitate data compilation by requiring direct reporting by all wholesalers and computerizing the reporting process.

The data that are available indicate that reliance on pesticides in Maine certainly is not decreasing overall. In 1991, the BPC reports that 1,957,649 pounds of pesticide active ingredient were sold (counting only pesticides with over 1,000 pounds of active ingredient sold). In 1995, the figure had grown to 2,046,041 pounds. (The addition of forestry sales in 1995 should, according to BPC Planner Tammy Gould, account for only an approximate 62,000 additional pounds of glyphosate, bringing the 1995 figure for agriculture alone to approximately 1,984,000 pounds, still up from 1991.) Decreases in the use of some products (for example, hexazinone, down from 47,822 pounds in 1991 to 28,779 pounds in 1995), were more than offset by dramatic increases in three fungicides, chlorothalonil, mancozeb and maneb.

In 1996, 6,696 pesticide products were registered in Maine, almost double the 3,423 registered in 1981. The BPC has no authority to compile and has no information on total costs of pesticides sold.

Pesticide Effectiveness: Do They Deliver What They Promise?

“[Reliance on chemical pesticides] has not led to long term sustainable solutions. In fact, it has often led to further pest prob­lems, putting farmers in a vicious cycle of pests and pesticides, and increasing the burden on the environment.” Integrated Pest Management: Strategy and Policy Options for Promoting Effective Implementation, World Bank, March 1996 (draft)

As every farmer knows, with chemical pesticides one battles not only pests, but, increasingly, pesticide resistance. Before World War II, only seven species of insects and mites were known to be resistant to insecticides. Now, more than 400 species are resistant to some pesticides. The development of resistance to one pesticide usually requires resorting to more expensive, toxic or ecologically hazardous pesticides.13 The development of such bioengineered plants as Monsanto’s NewLeaf potato, which genetically incorporates large concentrations of Bt toxins throughout the plant, has been widely acknowledged to increase the risk of resistance to the natural pesticide Bt, as it hastens the loss of the Bt-susceptible gene pool in the pest populations.14

Another problem is secondary pest outbreaks. These occur when pesticides applied to treat a specific pest kill the natural enemies of insects that previously were not problems. With the natural enemies gone, new pests are created. In 1978, 24 out of the top 25 agricultural pests in California were believed to be secondary pests. [15]

These problems suggest that the pesticide “treadmill” is just that – not a long-term solution but an expensive, unproductive running-in-place to keep up with nature’s ever effective inventiveness. As discussed in the next section, the risks of that race are no longer acceptable.

Pesticide Risks: How Real Are They?

In 1972, Congress ordered the EPA to review the health effects of all registered pesticides, one by one. Because public health was at stake, Congress mandated that the review be completed in five years. As of 1994 – 22 years later – EPA has re-evaluated fewer than half of the pesticides presently found as residues in the foods we eat. [16] Review methodologies used to date, moreover, neglect the critically emerging issue of the effects of these chemicals on our endocrine systems, and do not take into effect the cumulative and synergistic effects of a “chemical cocktail” of multiple exposures to different pesticides and other toxic chemicals. As noted in a 1993 study of the National Research Council of the National Academy of Sciences, pesticide tolerances – the legal limits for pesticide residues in food – are “not based primarily on health considerations,” but rather on anticipated actual residues in the field, given current pesticide use. [17] They provide, in effect, only an illusion of safety. Congress formally recognized and sought to correct these deficiencies in the Food Quality Protection Act of 1996 – but established a ten-year time frame for developing methods to evaluate these issues and re-examine pesticide tolerances in light of them.

Pesticide impact on wildlife was well documented in Silent Spring. Rachel Carson’s fears regarding their impact on human beings continue to be confirmed by scientific study. Nearly one-third of pesticides now in use are suspected of causing cancer in laboratory animals. Another third are thought capable of disrupting the human nervous system. Many other pesticides are suspected of disrupting the endocrine system that regulates growth and reproduction. [18] Following is a brief summary of some of the recent research that tells us that the time to move toward pesticide reduction is NOW.

Pesticides and Children

• As a result of a request by Congress in 1988, the National Research Council of the National Academy of Sciences undertook a study to determine if the current system of regulating pesticides adequately protects children and infants. The answer, delivered in its 1993 landmark report Pesticides in the Diets of Infants and Children, was a resounding, “No!” The report noted that children and infants, unlike adults, have “special windows of vulnerability – brief periods early in development when exposure to a toxicant can permanently alter the structure or function of an organ system.” Children can be ten times more sensitive than adults to pesticides, and the makeup of children’s diets is significantly different from that of adults. Yet current testing methods to determine the safety of pesticides and to set food tolerances “do not, for the most part, ade­quate­ly address the toxicity and metabolism of pesticides in neonates and adolescent animals or the effects of exposure during early developmental stages …”19

• A study of U.S. government data on pesticide residues in foods, considered in light of average consumption patterns by children, determined that, “[b]y the average child’s first birthday, the combined cancer risk from just 8 pesticides on 20 foods exceeds the EPA’s lifetime level of acceptable risk of one-in-one-million additional cancers throughout the U.S. population.” No adjustments in this study were made for potential higher sensitivity of children; nor was consumption of milk, formula or water considered in calculating total pesticide exposure. [20]

• Children are also exposed to pesticides in their homes, yards and farms, and in schools and parks. Children are especially at risk from lawn-care pesticides because of their playing habits and the fact that their cells divide more rapidly than cells in adults. [21]

• Sixty-seven percent of all pesticide exposures reported to Poison Control Centers in the U.S. involved children. [22]

• A 1995 study of children’s exposure to pesticides in household dust found that farm families in Washington state had “significantly higher” concentrations of four organophosphate insecticides in household dust than non-farm families. [23]

• A 1995 study of childhood cancers and home pesticide use found a positive association between some childhood cancers and chemical lawn treatments and use of pest strips (since banned). [24]

• Children in homes where pesticides are regularly used are 3.8 times more likely to develop leukemia; regular use of lawn pesticides was associated with a 6.5 times greater risk of leukemia. [25]

Male Infertility and Cancers

• Prostate cancer has risen 126% in the United States since 1973, even after taking into account the aging of the population. [26]

• Testicular cancer has risen 34% over the 12-year period ended in 1991. [27]

• Worldwide, average sperm counts in humans have declined approximately 50% over the last 50 years, from 113 million per milliliter of semen to 66 million per milliliter. [28]

• Each of these dramatic developments has been linked through animal studies with chemicals in our environment that inadvertently mimic or alter the activity of human hormones (“endocrine disruptors”). Of the 45 environmental contaminants or agents that have been reported to cause changes in the reproductive and hormone systems, eight are herbicides, eight fungicides, and 17 insecticides. [29]

• Eight of the 25 pesticides most extensively used in U.S. agriculture, seven of the top 10 pesticides used in commercial and industrial situations, and eight of the 25 pesticides most commonly used in American households, are endocrine disruptors. [30]

• A total of 606,353 lbs active ingredient of pesticides linked to male fertility problems were sold and used in Maine in 1995. [31] Many other products used in Maine may not have been tested for this risk, because EPA was not, until the Food Quality Protection Act of 1996, required to analyze it.

Pesticides and Breast Cancer

• Over 180,000 U.S. women are diagnosed with breast cancer every year. A woman’s lifetime risk of breast cancer is 1 in 8.32 Approximately 46,000 women a year die of breast cancer, which typically robs 20 years of life from those who die. [33]

• Sixteen currently used pesticides have been linked with breast cancer in laboratory tests. [34] A total of 102,991 lbs. active ingredient of four of these – atrazine, cyanazine, endosulfan, and methoxychlor – were used in Maine in 1995. [35]

• Recent reports of a decrease in mortality from breast and certain other cancers are not to be confused with the rate of incidence or occurrence of the disease. [36] While as many or more people continue to contract the disease, early detection and advances in treatment technology mean that fewer people may die of it. As long as we fail to address the underlying causes, the human and economic costs of cancer will continue to mount.

Cumulative Effects

Although skyrocketing cancer rates probably provide a clue, no one has adequately tested the cumulative health impacts of our multiple exposures to dioxins, pesticides and other toxins in our environment. A study published in the journal Science last summer suggests that we can’t afford to continue to ignore this issue. Scientists at Tulane University tested four pesticides believed to be only weakly estrogenic (mimicking natural estrogens). When the chemicals were paired, however, their impact on hormone systems shot up by a factor of 160 to 1600. [37] Dr. Lynn Goldman, EPA Toxic Substances chief, responded that “[t]hese findings are astonishing. The policy implications are enormous about how we screen environmental chemicals for estrogen effects.” Under present policies, as Goldman conceded, “[w]e test the ingredients that go into the soup individually. [The combination effect] is a very, very new issue for us.” [38]

Pesticide Reduction: Is It A Realistic Goal?

“Biointensive [Integrated Pest Manage­ment] is a systems approach to pest management based on an understanding of pest ecology. It begins with steps to accurately diagnose the nature and source of pest problems, and then relies on a range of preventive tactics and biological controls to keep pest populations within acceptable limits. Reduced risk pesticides are used if other tactics have not been adequately effective, as a last resort and with care to minimize risks.” – Charles M. Benbrook, Pest Management at the Crossroads (1996)

The alternative to conventional reliance on chemical pesticides, an approach called Integrated Pest Management (IPM), is not new. It is an approach that has been recommended by experts as sounder and safer than conventional reliance on chemical pesticides for at least 20 years. In the ongoing battle for farmers’, homeowners’, and other pesticide users’ minds, however, the well-armed arsenal of pesticide industry advertising, education, and research funding has considerably slowed the transition to IPM. IPM is not one method, but exists along a continuum, with much of IPM currently practiced at the “Low” and “Medium” levels, maintaining still substantial reliance on chemical pesticides. Currently about 6 percent of crop acreage is estimated to be managed with High (biointensive) IPM, another 25 percent with Medium IPM, and the remainder with Low or no IPM. [39] Recent efforts to study the effectiveness of IPM and to promote its wider application in Maine and elsewhere, discussed in this section, demonstrate that, given the will, pesticide use definitely can be substantially reduced.

The Maine Potato Ecosystem Project

For over five years, a cooperative research effort by University of Maine environmental and agricultural scientists, the Maine Agricultural and Forest Experiment Station (MAFES), and the Maine Potato Board, has examined, in a complex and controlled field study, the effects and interactions of contrasting methods of potato crop management at the Aroos­took Research Farm in Presque Isle, Maine. The report of the first four years of the “Maine Potato Ecosystem Project” (MPEP) [40] demonstrates persuasively that significant pesticide reduction here in Maine, for Maine’s major cash crop, is not only feasible, but is also more profitable than the conventional methods currently recommended by the Cooperative Extension and employed by many Maine potato farmers.

The study divided a 15-acre tract of a potato farm into 96 plots. Each plot was managed with a particular combination of factors under study, including two varieties of potatoes (Atlantic, Superior), two approach­es to soil management (amended with organic matter, and unamended), and three methods of pest management, as follow:

Conventional (CONV) – Pest control was accomplished with synthetic pesticides using current recommendations from University of Maine Cooperative Extension specialists. Insecticide applications were based on published “economic threshold levels,” i.e., recommended responses to measured densities of insects in the field based on anticipated crop damage.

Reduced Input (RI) – Pest control was accomplished with synthetic pesticides applied at lower rates or decreased frequency compared with the CONV system. Insecticide applications were based on double the economic thresholds used in the CONV system (i.e., twice as many insects found before insecticide applications made). Herbicides generally were applied at half the rates used in the CONV system.

Biological (BIO) – Only biological agents and cultural practices were used to control pests.

The MPEP Report indicated that the BIO system was generally the most costly method to use and often resulted in lower yields than the RI and CONV systems, although it also resulted in lower densities of the Colorado potato beetle and accomplished similar levels of weed biomass control. Of most interest, however, was how the RI system compared with the CONV system. The results dramatically refute those who contend that farmers can’t afford to get off the pesticide treadmill, and that pesticide use cannot be reduced below current levels. The key findings were:

Weeds: “In 1993 and 1994 [the last two reported years], weed biomass did not differ between the RI system, which received half rates of herbicides, and the CONV system, which received full rates.” (p. 154) [41]

Insects: “For 1992 through 1994, the RI plots required fewer foliar insecticide applications to maintain beetle populations below threshold compared with the CONV plots.” (p.82) [42]

Crop yield: 1993: “[T]here were no significant effects of pest management system on U.S. #1 yields …. despite large differences in pest control practices and costs.” (p.23)

1994: “The CONV and RI systems were equal in yields…” (p. 23)

Profits: “Comparing the most recent three-year averages, the RI system showed highest returns over variable cost for each variety/soil manage­ment combination, with a profit advantage of between $40 and $130 per acre over the CONV system.” (p. 142) “The RI pest management system has consistently been the highest profit operation.” (p. 152)

While the authors of this study caution that their work is ongoing and subject to continuing refinement and development, the results of the first four years of their careful work make a very strong case for significant pesticide reduction in the cultivation of Maine’s major cash crop. Buying and applying fewer pesticides is not only a more healthful and environmentally sound alternative for the potato farmer; it also makes economic sense. Ed Plissey, University of Maine Cooperative Extension Potato Specialist, has commented that the Maine Potato Ecosystem Project “is probably the most significant [work] I’ve seen in my forty year career. It may put us back on the farm where I was when I was growing up – with four year rotations, animal manures, green manures.”43 It’s time to acknowledge the project’s accomplishments and to move forward to implement its findings through state support for a significant pesticide reduction program. A program in operation for many years for potato farmers in Wisconsin, discussed below, also suggests how Maine might move forward in this direction.

Wisconsin’s “Wisdom”

With financial support from growers, the state and the U.S. Department of Agriculture, the University of Wisconsin developed computer software that can be tailored to specific conditions on individual farms, helping potato farmers with disease management, insect management, irrigation scheduling and weed management. [44] The program has been particularly helpful in analyzing weather conditions to predict the appearance of early blight and late blight, advising farmers when to make a first fungicide application and how to increase the time between applications. WISDOM has helped reduce the quantity of pesticides applied on Wisconsin potato crops between 1980 and 1994 by about 40%, and is saving Wisconsin growers an estimated $110.00 per acre per year.45 Its value to farmers is indicated by the fact that the Wisconsin Potato and Vegetable Growers Association currently provides about $400,000 per year for university research from industry check-off funds.46 The University is currently expanding the WISDOM system to address potato root systems and soil fertility. Sample screens from the WISDOM program for a particular farm are attached.

The utility of the WISDOM program is clearly region-specific. Much work would be required to develop a similar program for use by Maine potato farmers (it took three years to develop WISDOM); but much of the necessary understanding of Maine climate, soil, and pest parameters has already been developed through MPEP. Development of a WISDOM for Maine is the perfect example of the practical applications of MPEP – work dependent upon the dedication of new resources for alternative pest management.

New York: Pesticide Reduction in Schools

Although 75% of pesticides in the United States are used in agriculture, a pesticide reduction policy should focus as well on other uses of pesticides, particularly those that involve widespread exposure of children. A survey conducted by the New York Attorney General in 1991 revealed that 87% of schools in New York State used pesticides; at least 50 different active pesticidal ingredients were being applied to the buildings and grounds of those schools; and the most commonly used products were chlorpyrifos, bendiocarb, 2,4-D and dicamba. The Attorney General found “serious deficiencies in the notification and warning practices of New York schools,” and recommended that “schools should adopt least-toxic pest management policies and practices in order to reduce or eliminate pesticide use, and should select the least toxic pesticides in situations where pesticide use is deemed to be essential.” He also recommended that schools “not use pesticides containing known or probable carcinogens for merely aesthetic purposes, such as lawn care.” [47]

In response to the Attorney General’s recommendations, the New York Coalition for Alternatives to Pesticides developed a Partnerships for Healthy Schools program, which brings together school administrators, buildings and grounds personnel, teachers, parents and students to craft local solutions for reducing and eliminating pesticide use at schools, including offering workshops in Integrated Pest Management. The program has established 12 partnerships to date, with one school, Locust Valley Central School District, reporting no use of pesticides outdoors or indoors in four years, and another, Baldwin Union Free School District, reporting a 70% reduction in pesticide use. [48]

San Francisco: Municipal Pesticide Use Reduction

More than two tons of pesticides are sprayed annually by the San Francisco Recreation and Park Department, with 60 different active pesticide ingredients, half of which are believed to cause cancer, genetic damage or harm to the reproductive system. In October, 1996, the San Francisco Board of Supervisors voted unanimously for a sweeping ban of pesticide use in all city departments, including city buildings and grounds, parks and golf courses. The ordinance bans all pesticides known or believed to cause cancer and those known to cause reproductive harm by January 1, 1997. The city must cut in half use of all other pesticides by 1998 and eliminate all pesticides by 2000. [49]

In this paper we discuss only a few cases where IPM has been used to accomplish significant pesticide reduction. The University of Maine Cooperative Extension is also making significant progress with IPM in apple and corn cultivation. With the passage of “An Act to Reduce Reliance on Pesticides,” Maine will have taken a very important first step to a healthier environment for ourselves, our children and our wildlife, new marketing opportunities for our produce, and significant cost savings. Let it happen NOW.

– Sharon Tisher, J.D. [50]


l Benbrook, C.M., Pest Management at the Crossroads, Consumers Union (Yonkers, N.Y., 1996) at 81-84. This just published, comprehensive study of pesticide risks, costs, and alternatives is strongly recommended for those interested in further study of these issues. Copies can be purchased by calling (301) 617-7815.

2 Aspelin, A.L., Pesticides Industry Sales and Usage: 1994 and 1995 Market Estimates –Preliminary, U.S. Environmental Protection Agency (1996); Cline, M.L., et al., Pesticide reduction: a blueprint for action, Maine Audobon Society (1990).

3 Aspelin, supra nt. 2

4 Id.

5 Aspelin, A.L., Pesticides Industry Sales and Usage: 1992 and 1993 Market Estimates, U.S. Environmental Protection Agency (1994).

6 Benbrook, C.M., supra nt. 1, at 34.

7 Aspelin, 1994, supra nt. 5.

8 Anderson, M. (Editor), Agricultural Resources and Environmental Indicators, Agricultural Handbook Number 705, Economic Research Service, U.S. Department of Agriculture (1994).

Mayerfeld, et al., Pest Management in Iowa: Planning for the Future, Integrated Farm Management Report Number 17, Iowa State University Cooperative Extension (1996).

9 Benbrook, C.M., supra nt. 1, at 46.

10 U.S. Department of Agriculture, Cropping Practices Survey, National Agricultural Statistics Service/Economic Research Service, 1991 and 1995.

11 Aspelin, 1994 & 1996, supra nts 2, 5.

12 Information regarding Maine compilations from Tammy Gould, Pesticides Planner, Board of Pesticides Control.

13 Center for Science in the Public Interest, Funding Safer Farming: Taxing Pesticides and Fertilizers (1995), at 8.

14 Benbrook, supra nt. 1, at 167-168.

15 Curtis, J. et al., After “Silent Spring,” The Unsolved Problems of Pesticide Use in the United States, Natural Resources Defense Council (1993), p. 28.

16 Wargo, J., Our Children’s Toxic Legacy: How Science and Law Fail to Protect Us from Pesticides, Yale University Press (1996).

17 National Research Council, Pesticides in the Diets of Infants and Children (1993), p. 8.

18 Wargo, supra nt. 12.

19 National Research Council, supra nt. 17, at 3,4.

20 Environmental Working Group, Pesticides in Children’s Foods (1993) , p. 2.

21 Weiss, L., Keep Off the Grass, Part I: A Review of the Health Effects of Pesticides Most Commonly Used by the Lawn Care Industry, Public Citizen (April, 1989).

22 Abrams, R., Pesticides in Schools: Reducing the Risks (1993), p. 5-6.

23 Simcox, N.J. et al., “Pesticides in household dust and soil: Exposure pathways for agricultural families,” Environ. Health Persp. 103(12):1126-1134 (1995).

24 Leiss, J.K. et al., “Home Pesticide Use and Childhood Cancer: A Case-Control Study,” American Journal of Public Health, Vol. 85, No. 2 (1995), pp. 249-252.

25 Lowengart, et al., “Childhood Leukemia and Parents’ Occupational and Home Exposures,” Journal of the National Cancer Institute. 79[1]: 39-46 (1987).

26 National Cancer Institute figures, quoted in Newsweek, March 18, 1996 at 48.

27 Lecture given by Dr. Beverly Paigen, Senior Scientist, The Jackson Laboratories, at the Common Ground Country Fair, Windsor, Maine, 1996.

28 Cox, C., “Masculinity at Risk,” Journal of Pesticide Reform, Vol. 16, No. 2 (1996) at 2; Raloff, J., “That Feminine Touch,” Science News, Vol 145 (January 22, 1994).

29 Raloff, supra nt. 28, at 58.

30 Cox, supra nt. 28, at 5.

31 These were, indecreasing order of sales in Maine: mancozeb, glyphosate, atrazine, chlorpyrifos, azinphos-methyl, endosulfan, carbaryl, 2,4-D, parathion, benomyl, copper oxychloride, methoxychlor, methomyl, malathion, permethrin, diazinon, ziram, and fenvalerate. Journal of Pesticide Reform, Vol. 16, No. 2 (1996) and Board of Pesticides Control compilation.

32 Cox, C., “Pesticides and Breast Cancer,” Journal of Pesticide Reform, Vol. 16, No. 1 (1996).

33 Davis, D. and Bradlow, H., “Can Environmental Estrogens Cause Breast Cancer?” Scientific American, Vol. 273, No. 4 (Oct. 1995).

34 Cox, supra nt. 32; Davis, supra nt. 33.

35 Board of Pesticides Control compilation.

36 Bangor Daily News, Nov. 14, 1996 at A1.

37 Kaiser, J., “New Yeast Study Finds Strength in Numbers,” Science, Vol. 272, p. 1418 (June 7, 1996).

38 Bangor Daily News, June 7, 1996.

39 Benbrook, supra, nt. 1, at 4.

40 A. Randall Alford et al., The Ecology, Economics, and Management of Potato Cropping Systems: A Report of the First Four Years of the Maine Potato Ecosystem Project, MAFES Bulletin 843, April, 1996 (hereinafter, “MPEP Report”).

41 Note that for the first two years (1991 and 1992), no herbicides were used in the RI plots.

42 As detailed in Table 4.1 on p. 82, in 1993 RI plots received on the average 1.25 applications of the insecticide esfenvalerate (AsanaXL.66EC, rate = 9.0-9.6 oz/A) where CONV plots received on average 2.75 applications; in 1994, the compar­ison was 2.00 applications for the RI plots; 3.00 applications for the CONV plots.

43 The MOF&G, March/April 1996, p. 22.

44 Johnson, N. , “Clean Water and Clear Profits,” Science Report, College of Agricultural and Life Sciences, University of Wisconsin-Madison, 1993.

45 Id. Data compiled and available from Dr. Walt Stevenson, Department of Plant Pathology, University of Wisconsin-Madison.

46 Benbrook, at 25.

47 Abrams, R., Attorney General of New York State, Pesticides in Schools: Reducing the Risks (1993).

48 NYCAP, Solutions, Vol. I, Number 1, Spring 1996, at 11, 13.

49 Global Pesticide Campaigner, Vol. 6, Number 4, at 19 (1996).

50 Adjunct Instructor, Environmental Law, University of Maine. Chair, Public Policy Committee, Maine Organic Farmers and Gardeners Association.

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