The colored parts of the image above, prepared by Columbia University scientists, indicate where a child’s brain is physically altered after exposure to this pesticide.
Action #1 – CA isn’t waiting for the EPA to ban chlorpyrifos.
SB 458 (Durazo) will ban the use of Dow’s highly profitable pesticide chlorpyrifos (klaw-pir’-uh-fos) in California, its biggest market, because the EPA will no longer do its job. In 2016, the agency’s own scientists and the Dept. of Pesticide Regulation determined that there was no safe level on food crops and prepared to completely ban its use. After the election, however, the new and now-disgraced EPA director Scott Pruitt reversed course. Therefore, Californians are still being exposed to a neurotoxin that can cause serious, irreversable harm to adults, children, as well as fetuses, through residue on food which cannot be washed or peeled off, water pollution, or drift from 1/2 mile away. Everyone is at risk. The bill is co-sponsored by CPR allies/members: the United Farm Workers, the American Academy of Pediatrics-California and Earthjustice.
Earthjustice is currently presenting its case against the EPA reversal in court, but the agency can draw this out for years. Meanwhile, activists who are pushing for state and local bans to speed up the process of protecting their communities. Hawaii has already banned this toxin. We can too.
Minimal script: I’m calling from [zip code] and I want Senator [___] to vote ‘YES” on SB 458 – the “Protect Children from Brain-Damaging Chlorpyrifos Act of 2019.”
More script if you want it: Now that big corporations control the EPA, it’s up to the states, especially an environmental leader like California, to lead the way in banning this nerve gas pesticide and protect all our families, especially those of the hard-working farm workers that produce our food.
Action #2 – Support H.R. 230 – Ban Toxic Pesticides Act of 2019
“This was a chemical developed to attack the nervous system,” notes Virginia Rauh, a Columbia professor who has conducted groundbreaking research on chlorpyrifos. “It should not be a surprise that it’s not good for people.” “We are all Flint,” she says. “We will look back on it as something shameful.”
Minimal script: I’m calling from [zip code] and I want Rep. [___] to cosponsor and vote “YES” on H.R. 230 – “Ban Toxic Pesticides Act of 2019“.
Rep-check here. (Thank Carbajal, and ask Brownley to sign on!)
Contact (Have your friends and relatives in GOP states call theirs too!)
Rep. Julia Brownley: email, (CA-26): DC (202) 225-5811, Oxnard (805) 379-1779, T.O. (805) 379-1779
or Rep. Salud Carbajal: email. (CA-24): DC (202) 225-3601, SB (805) 730-1710 SLO (805) 546-8348
Who’s my representative/senator?: https://whoismyrepresentative.com
Chlorpyrifos, which Dow sells under the trade names Lorsban and Dursban, is a neurotoxin scientifically proven to harm human health, water, and wildlife. It’s actually a nerve gas, which targets neurotransmission – following the same chemical pathway through the body as its relative, sarin gas, be it that of a warm-blooded creature or an insect. Both substances cause damage by overstimulating the nervous system. They belong to a class of chemicals called organophosphates – some such as diazinon and chlorpyrifos, have already been banned by the EPA for household use, and others like Parathion have been completely banned.
Chlorpyrifos can be eaten, drunk, inhaled, or absorbed through the skin. Exposure is harmful to adults, being linked to Parkinsons’s disease and lung cancer, but the damage it causes to children has profound costs to our society. It lowers children’s IQs; increases the likelihood of children being born with autism, ADHD, or other neurobehavioral disorders; decreases children’s lung function; and exacerbate asthma and other respiratory-related problems. One 2012 study found that it was in the umbilical cord blood of 87 percent of newborn babies tested and a 2014 study found that children born to mothers who lived less than one mile from fields treated with organophosphate pesticides during pregnancy were about 60 percent more likely to have autism than children whose mothers who lived further away.
Chlorpyrifos was first registered as an insecticide in 1965 and is the “most used conventional insecticide” in the U.S.. It was used in homes and gardens until 2002 and is still allowed in commercial agriculture, with roughly 10 million pounds used on crops each year. Nearly 50 different crops are routinely treated with it, with soybeans, corn, alfalfa, oranges and almonds topping the list in terms of pounds of chlorpyrifos applied. It is also applied to over 30 percent of their apple, asparagus, walnut, onion, grape, broccoli, cherry and cauliflower crops.
The chemical has a half-life of several months and can remain on sprayed foods for up to several weeks. It can typically last from 33-56 days for soil incorporated applications, 7-15 days for surface applications, 25 days in water and 4-10 days in the air. Nonorganic produce is a major source of exposure along with non-grass fed meats, as their feed consists primarily conventionally farmed grains such as corn. It can be carried long distances when sprayed and effects have been noted on people living within a mile of target crops.and has even been found in indoor air. The insecticide is also a commonly found water contaminant that reaches rivers, lakes and streams, where it concentrates in the fatty tissue of fish. According to the National Water Quality Assessment Program, chlorpyrifos contaminated surface water has been reported in urban and agricultural streams at levels potentially harmful to aquatic life. Studies by the Arctic Monitoring and Assessment Program show that it can also travel long distances to remote areas far from its source, such as surface water, ice, & fog from the Bering & Chukchi Seas, Alaskan snow and fish from Alaskan parks and Arctic & subarctic Canadian lakes.
Government-funded studies also show chlorpyrifos poses serious risks to 97 percent of endangered animals in the U.S.. It is particulary toxic to bees, birds, crustaceans and fish. Aquatic insects and animals appear to absorb chlorpyrifos directly from water. Acute exposure to chlorpyrifos can be toxic to bees and some application rules prohibit application to fruit tree flowers with 4-6 days of blossoming. However, more recent studies have detemined that sub-lethal repeated exposure to the chemical causes profound behavioral changes that ultimately deplete populations.
What the EPA knew BEFORE the Trump Administration took over
The EPA found that:
- All food exposures exceed safe levels, with children ages 1–2 exposed to levels of chlorpyrifos that are 140 times what EPA deems safe.
- There is no safe level of chlorpyrifos in drinking water.
- Pesticide drift reaches unsafe levels at 300 feet from the field’s edge.
- Chlorpyrifos is found at unsafe levels in the air at schools, homes, and communities in agricultural areas.
- All workers who mix and apply chlorpyrifos are exposed to unsafe levels of the pesticide, even with maximum personal protective equipment and engineering controls.
- Field workers are allowed to re-enter fields within 1–5 days after pesticide spraying, but unsafe exposures continue on average 18 days after applications.
What does it do to people? (The expanded list)
- Chlorpyrifos is acutely toxic and associated with neurodevelopmental harms in children. Levels far lower than what EPA was previously using to establish safety standards — harms babies permanently.
- Organophosphate poisoning may mimic acute complications in pregnancy, such as eclampsia and seizures.
- Prenatal exposures to chlorpyrifos are associated with lower birth weight, reduced IQ, lower intellectual development, loss of working memory, attention disorders, structural changes in the developing brain, and delayed motor development. There does not appear to be a safe level of exposure for pregnant women.
- At high doses, nerve agents, chlorpyrifos and other organophosphates impact humans similarly, including headache, nausea, dizziness and confusion. At very high doses, organophosphates can cause vomiting, abdominal pain and diarrhea. And at ever higher doses, such as from spills or accidents, they can lead to death.
- It can cause irreversible eye damage as well as include marked miosis, ocular pain, conjunctival congestion, diminished vision, ciliary spasm, and brow ache.
- Acute poisoning suppresses the enzyme that regulates nerve impulses in the body and can cause convulsions, respiratory paralysis, and, in extreme cases, death.
- Exposure to chlorpyrifos is linked to Parkinsons’s disease and lung cancer,
- A link exists between prenatal exposure and tremor in childhood. This finding is relevant because the pesticide acts on an enzyme involved in motor signaling.
- Chlorpyrifos is one of the pesticides most often linked to pesticide poisonings.
- Autism: Researchers in the CHARGE study found that every 100 pounds of the chlorpyrifos applied within 1.5 kilometers of pregnant mothers’ homes increased the chance of their child developing autism spectrum disorder by 14 percent.
- Research shows that living within 1 mile of chlorpyrifos-treated fields increases a woman’s risk of having an autistic child by 300 percent.
A brief and assuredly incomplete history.
1965: Dow Chemical Company introduces chlorpyrifos.
1993: Following the release of a report by the National Academy of Sciences, “Pesticides in the Diets of Infants and Children”, Congress strengthened protections for children from pesticides. The NAS report criticized EPA for treating children like “little adults” by failing to address the unique susceptibility of children to pesticide exposures based on the foods they eat, their play, and sensitive stages of development.
1994: Dow entered into an agreement with New York State prohibiting advertising touting the safety of its pesticide products. The company agreed to stop making claims that its products were “safe.” However, an investigation by Spitzer’s office found that almost immediately after the company entered into the agreement it once again began to make misleading safety claims in its print, video and internet advertising.
The 1996 Food Quality Protect Act (FQPA)—passed unanimously in Congress—requires EPA to protect children from unsafe exposures to pesticides, no matter the financial costs. The EPA must find a product safe BEFORE it can be used.
1996: The annual number of chlorpyrifos poisonings, which can cause twitching, tremors, slurred speech, and even paralysis and death, reported to Poison Control Centers in the U.S. reached 7,000. It was also becoming clear that children were particularly sensitive to the pesticide, which was available in many household products used to kill cockroaches, termites, fleas, and other bugs.
1997-8: (Historical perspective) We’ve had a corrupt EPA before. “Toxic Deception” and “Unreasonable Risk, the Politics of Pesticides” (Center for Public Integrity) were written by investigative reporters who described chemical companies successfully working to keep known health threats profitably on the market with the help of the EPA and well-financed congresspeople. They described the employment pipeline between the Environmental Protection Agency (EPA) and the companies they were supposed to be overseeing. They described an industry essentially responsible for testing the toxic effects of their own chemicals, and then reporting the results, even if they didn’t match the work of independent scientists. They described chemical companies’ obfuscation of facts, bullying with lawsuits both threatened and real, propaganda, and borderline fraud. The result is that their products continued to contaminate our air, water, and food while they promoted pro-environmental television commercials.
2000: Voluntary Agreement to Eliminate, Phase Out and Modify Certain Uses
Chlorpyrifos was banned for use in homes, schools, day care facilities, parks, hospitals, nursing homes and malls. It had been the active ingredient in pet flea and tick collars. However, agricultural use remained, and it can still be used on golf courses and road medians, treated wood fences and utility poles. It could also still be used in residential child-safe ant and roach bait products. (It was in Raid!), but started phasing out termiticide uses.
The agency banned its use on tomatoes, and limited its use on other crops, including apples, grapes and citrus.
2002: Label Changes to Ensure Environmental and Worker Safety
- Use of buffer zones to protect water quality, fish and wildlife;
- Reductions in application rates per season on a variety of crops including citrus and corn; and
- Increase in amount of personal protective equipment to mitigate risk to agricultural workers.
Californians for Pesticide Reform and Beyond Pesticides asked the EPA to ban chlorpyrifos, altogether, including its use in agriculture. Dow threatened to sue the agency if it tried for a full ban, so a compromise was made to phase out most household uses.
2003: Attorney General Spitzer announced that Dow AgroSciences, LLC, a subsidiary of the Dow Chemical Company, would pay a $2 million penalty for illegally advertising safety claims about its pesticide products in New York between 1995 and 2003. “Excellent studies conducted by independent scientists have clearly shown that chlorpyrifos, the active ingredient in Dursban, is toxic to the human brain and nervous system and is especially dangerous to the developing brain of infants. I applaud the actions of Attorney General Spitzer to stop these misleading and potentially dangerous safety claims.” – Dr. Philip Landrigan, chair of the Department of Community and Preventative Medicine at Mount Sinai Medial Center.
In the US, the number of incidents of chlorpyrifos exposure reported to the US National Pesticide Information Center shrank sharply from over 200 in the year 2000 to less than 50 in 2003, following the residential ban.
2006: EPA’s Reregistration Eligibility Decision for Chlorpyrifos – “Used on a variety of food and feed crops, golf courses, as a non-structural wood treatment, and as an adult mosquitocide, chlorpyrifos residues in food and drinking water do not pose risk concerns.“
2007: the Pesticide Action Network North America (PAN) and the Natural Resources Defense Council (NRDC) petitioned the EPA to outright ban chlorpyrifos for multiple reasons, especially on its impact on the development of children. Then because 8 years of waiting and a court decision. (See 2015)
2011: Preliminary Human Health Risk Assessment
EPA completed a comprehensive preliminary human health risk assessment for all chlorpyrifos uses as part of the registration review process. This assessment included the results of extensive new research and the findings of a number of new studies that had become available since the agency’s last human health risk assessment for chlorpyrifos, completed in June 2000. Report, including toxicity of food and water for children and infants, here.
2012: Spray Drift Mitigation and Changes to Application Rates
In 2012, EPA significantly lowered the aerial pesticide application rates and created “no-spray” buffer zones for ground, airblast and aerial application methods around public spaces, including recreational areas, schools, homes and other sensitive areas to be protective of children and other bystanders. Read the report here.
In 2012: David Bellinger, Ph.D., professor of neurology at Harvard Medical School, published a study funded by the National Institutes of Health where he calculated the impact of toxic exposures on children’s IQ – based on a population of 25.5 million children, aged birth to 5, those born to mothers exposed to organophosphates, mercury or lead during pregnancy suffered a combined loss of 16.9 million IQ points. Researchers calculated a collective loss of 41 million IQ points in the U.S. from the same exposures. One 2012 study found that chlorpyrifos was in the umbilical cord blood of 87 percent of newborn babies tested.
2014: Revised Human Health Risk Assessment
In 2014, as part of the registration review process, EPA completed a revised human health risk assessment for all chlorpyrifos uses. The assessment updated the June 2011 preliminary human health risk assessment based on new information received, including public comments. EPA factored in exposures from multiple sources including from the exposures from food and water, from inhaling the pesticide and through the skin. EPA considered all populations including infants, children, and women of child-bearing age. EPA incorporated information from a 2012 assessment of spray drift exposure and as well as new restrictions put into place to limit spray drift. Read the report here.
In 2014: the first and most comprehensive look at the environmental causes of autism and developmental delay, known as the CHARGE study, found that the nearby application of agricultural pesticides greatly increases the risk of autism. A number of studies tracked mothers and children, including one in New York City from before and after the chlorpyrifos residential-use ban.
Aug. 2015: After the EPA stalled for 8 years, including “partial reports, missed deadlines, and vague promises of future action,” the U.S. Court of Appeals for the Ninth Circuit ordered the EPA on August 10, 2015, to issue a full and final response to the NRDC’s 2007 petition by October 31. At that deadline, the EPA promised to ban the chemical.
In 2015: A coalition of 47 scientists and doctors with expertise in children’s brain development, including the director of the National Institute of Environmental Health Sciences, issued the TENDR statement, a warning that toxic chemicals in the environment, including organophosphate pesticides, were increasing children’s risks of developing behavioral, cognitive, and social disorders and contributing to the rise in cases of autism and ADHD.
From a presentation by Virginia Rauh of the Columbia University Center for Children’s Environmental Health, based on a study of 317 children in New York City. Children were asked to perform a free-hand motor test called an Archimedes Spiral. Children in the group with high chlorpyrifos exposure had higher rates of clinically meaningful tremor.
August 2016: the court said EPA had to take final action on the NRDC’s 2007 petition by March 31, 2017.
Nov. 3rd, 2016: Revised Human Health Risk Assessment
After receiving public comments on the 2014 risk assessment and feedback from the FIFRA Scientific Advisory Panel, EPA revised its human health risk assessment for chlorpyrifos in its report issued 11/3/16 here. Their “Chlorpyrifos Revised Human Health Risk Assessment,” stated that based on the evidence, that the pesticide can cause intelligence deficits and attention, memory, and motor problems in children. According to the report, 1- and 2-year-old children risk exposures from food alone that are 14,000 percent above the level the agency now thinks is safe. The EPA released a revised human health risk assessment for chlorpyrifos that confirmed that there are no safe uses for the pesticide.
November 8th, 2016: There was regime change in Washington and Scott Pruitt becomes head of the EPA.
November 17th, 2016: Revoking the tolerance allowance for chlorpyrifos required a 60-day comment period before it could be finalized. Trump was inaugurated three days after the comment period ended on January 17, 2017. The final deadline to incorporate the 49,535 comments, was March 31, 2017, giving the new administration almost two months to derail the long-awaited regulation. (The comments had a higher percentage of responses from growers concerned about losing access to chlropyrifos than those concerned about its safety. A number of growers stated that it was the only chemical that worked anymore, which implies increasing insect resistance and is actually really concerning. One grower noted that, while he still wanted it for commercial use, the household and garden ban caused a notable increase in the local butterfly population.)
January 17, 2017: Dow Chemical submitted a request to the agency to reject the petition to ban chlorpyrifos, calling the scientific link between the childhood health issues and the pesticide unclear, agency records show.
March 1, 2017: Chlorpyrifos was a major focus at a meeting with members of the American Farm Bureau Federation from Washington State at the EPA headquarters, during which, Pruitt “stressed that this is a new day, a new future, for a common-sense approach to environmental protection” and that the administration “is looking forward to working closely with the agricultural community. (Meeting notes here.)
March 7-29, 2017: Wendy Cleland-Hamnett, the acting head of the E.P.A.’s office of chemical safety, sent an email to the top political staff with options for how to handle the decade-old petition from an environmental group requesting the ban. Emails that followed (detailed in this article by the NYTimes) show how the EPA closely coordinated their decision to revoke the ban with the White House as well as the Department of Agriculture, which had questioned the justification for the ban.
March 29 2017: Denial of Petition to Revoke Tolerances
Forced to act by March 31st, Scott Pruitt, President Trump-appointed head of the EPA, issued an order on March 29th denying the petition to revoke all tolerances (uses) for chlorpyrifos on food. In rejecting the pesticide ban, Mr. Pruitt took what is known as a “final agency action” on the question of the safety and use of the pesticide, suggesting that the matter would not likely be revisited until 2022, the next time the E.P.A. is formally required to re-evaluate the safety of the pesticide. 2022!
Nothing to see here. Move along…
The $1 million donation Dow Chemical gave to Trump’s inauguration was just the icing on a great big money cake…
From ucsusa.org: “Dow spent more than $13.6 million on lobbying in 2016 and had spent over $5.2 million in the first quarter of 2017, advocating with the EPA, the White House, and both chambers of Congress for a variety of policies, including chlorpyrifos’ regulatory status. In June, it was revealed that Administrator Pruitt met with the CEO of Dow Chemical, Andrew Liveris, before making his decision to allow continued use of chlorpyrifos across the US, (Later reports state that they met in passing and denied speaking of the chemical. However, with millions of dollars in lobbying and their Jan. 17 report already submitted, it hardly matters.)…
…After the decision was announced, lawyers representing Dow sent a letter to the EPA, Department of Interior, and Department of Commerce asking Pruitt, Secretary Ryan Zinke and Secretary Wilbur Ross, respectively, “to set aside” the results of government studies showing that the insecticide is harmful to children’s health.”
On April 13, 2017: A legal team representing Dow Chemical and two other organophosphate manufacturers sent letters to the three agencies responsible for joint enforcement of the Endangered Species Act — the U.S. Fish and Wildlife Service, the National Marine Fisheries Service and the Department of Commerce — asking them to “set aside” these incriminating findings, as the companies believe they are flawed. (USA Today):
“Over the past four years, federal scientists have compiled … more than 10,000 pages indicating the three pesticides under review — chlorpyrifos, diazinon and malathion — pose a risk to nearly every endangered species they studied. Regulators at the three federal agencies … are close to issuing findings expected to result in new limits on how and where the highly toxic pesticides can be used …
The EPA’s recent biological evaluation of chlorpyrifos found the pesticide is ‘likely to adversely affect’ 1,778 of the 1,835 animals and plants accessed as part of its study, including critically endangered or threatened species of frogs, fish, birds and mammals … In a statement, the Dow subsidiary that sells chlorpyrifos said its lawyers asked for the EPA’s biological assessment to be withdrawn because its ‘scientific basis was not reliable.'”
2017 – UK response to science: ChemTrust Report, 2017: No Brainer – The impact of chemicals on children’s brain development: a cause for concern a need for action.
In June 27, 2017: Nation’s Pediatricians, EWG Urge EPA to Ban Pesticide that Harms Kids’ Brains
June 14, 2018: Hawaii Bans Chlorpyrifos Pesticides By 2023, First State To Do So
July 30, 2018: The California Department of Pesticide Regulation released its comprehensive risk assessment of chlorpyrifos. Per that document, a scientific panel has recommended chlorpyrifos be listed as a toxic air contaminant (TAC). Now, the state’s department has 10 working days to officially begin the process to list chlorpyrifos as a TAC.
On August 9, 2018, the 9th Circuit Court of Appeals ordered the U.S. Environmental Protection Agency (EPA) to finalize its proposed ban on chlorpyrifos based on undisputed findings that the pesticide is unsafe for public health, and particularly harmful to children and farmworkers. The EPA asked the court to re-hear the case.
February 6, 2019: Health and labor organizations will have to argue again in court that chlorpyrifos, a brain-damaging pesticide, must be banned from all food uses, the 9th Circuit Court of Appeals ruled today. The decision comes four months after Andrew Wheeler’s Environmental Protection Agency asked the court to rehear the case either by the 3-judge panel that originally banned chlorpyrifos in 2018, or by a panel of 11 judges.
March 26, 2019: EarthJustice will argue their case once more before the Ninth Circuit Court of Appeals. Meanwhile, we are supporting the work of community activists who are pushing for local bans as they educate their communities about how toxic all organophosphates are to farmworkers, families, and particularly children.
- Unreasonable Risk, the Politics of Pesticides (Center for Public Integrity)
- Dow Chemical wants Farmet to keep using a pesticide linked to autism and ADHD. (intercept)
- What you need to know about chlorpyrifos (earthjustice)
- EPA refuses to ban pesticide linked to poisonings and damage to children’s brains. (earthjustice)
- Trump’s legacy: Damaged brains (NYTimes)
- Fields of Poison 2002 California Farmworkers and Pesticides (Pesticide Action Network)