To sign on to the letter below advocating for stronger restrictions on the cancer-causing fumigant pesticide chloropicrin, please send your ORGANIZATION NAME, CONTACT NAME & TITLE
to Sarah Aird at firstname.lastname@example.org BY WEDNESDAY, JULY 24, 2013
* * * * * * * * * * *
July XX, 2013
California Environmental Protection
1001 I Street, PO Box 2815
Sacramento, CA 95812-2815
California Department of Pesticide
I Street, PO Box 4015
e-mail and regular mail
Dear Secretary Rodriguez and Director Leahy:
Chloropicrin is a potent carcinogen and
respiratory system toxin responsible for numerous poisonings across the state.
To protect human health and safety in rural agricultural areas of California,
the organizations below urgently request that the Department of Pesticide
Regulation (DPR) implement more stringent rules and tighter controls on
chloropicrin, and develop a plan to phase out this chemical by 2020.
Widely used as a pesticide fumigant to kill
pests in the soil before planting a variety of crops across California,
chloropicrin is known to cause severe, immediate and chronic health effects.
According to the Office of Environmental Health Hazard Assessment’s and DPR’s
own scientists, chloropicrin is a potent carcinogen and we strongly dispute DPR
management’s subsequent conclusion that the evidence of cancer is uncertain or
equivocal and can be ignored. Chloropicrin is also severely irritating to the eyes and respiratory
system, and can cause chronic damage to the lungs. Symptoms of chloropicrin
exposure include: eye pain, breathing difficulties including asthma symptoms,
coughing, diarrhea, dizziness, headaches, nausea, sore throat, vomiting and weakness.
Since chloropicrin is highly volatile and
drift-prone, it often drifts away from where it’s applied, affecting
farmworkers, their families, and other rural community members, including
especially vulnerable populations such as children, the elderly, and those already
suffering medical conditions such as asthma. Chloropicrin drift has already
caused many poisoning incidents in California, with more than 700 people in the
past 10 years on record as having been affected; since many poisonings go
unreported, this number is likely the tip of the iceberg.
Chloropicrin is an outdated,
extremely-difficult-to-control agricultural tool and needs to be replaced with
safer, more reliable alternatives. We strongly urge Cal/EPA and DPR to phase
out chloropicrin and all chemical fumigants by 2020 and, in the meantime,
secure funding to implement a strong fumigant transition program.
While the phase-out of this fumigant is crucial
for the health and safety of Californians, tighter control measures are needed
immediately in order to mitigate the effects of chloropicrin.
Proposed buffer zones are not large enough to be
health protective because they will allow exposure to air levels of up to 73
ppb, a level 25 times higher than the exposure limit recommended by DPR and
OEHHA toxicologists and the Scientific Review Panel.
DPR has said they are considering whether
chloropicrin buffer zones should be designed to be protective 80% or 95% of the
time, possibly considerably less than DPR’s typical goal of 95% for other
pesticides. A protection program that is designed to fail up to one in five
times under regular, allowable use patterns—not counting inevitable human error
or adverse weather conditions—is fundamentally unacceptable. Buffer zones must
be large enough to protect the health of community members under all
circumstances, including under worst-case weather conditions, and a minimum
health protective buffer zone of ½ mile should be instituted for fumigations
taking place near schools. Adequacy of buffer zones should also be “groundtruthed”
with air monitoring. The current proposal establishes buffer zones of as little
as 60 feet for untarped and standard tarped fields and 25 feet with modern totally
impermeable film (TIF) tarps. These buffer zones are not big enough to protect
crews of fieldworkers or rural communities.
Ultimately, tarps have been demonstrated to be
an unreliable method of protecting workers and communities from volatile
fumigants, including chloropicrin, because they often leak around the edges or
are damaged by wind or animals. However, until chloropicrin is fully phased
out, tarps are a necessary part of a harm reduction strategy: all untarped
applications should be prohibited, and for every application, standard tarps
should be replaced with TIF tarps. The proposed 25 foot buffer zone around
fumigations using these modern TIF tarps is far too small because it was set
with the expectation that these tarps will never be blown apart, torn by animals
or leak around the edges—an unrealistic assumption given real-world conditions.
Instead, we propose a buffer zone of ½ mile for applications with TIF tarps.
In order to protect community members who live
near fields where chloropicrin is applied, a mandatory and comprehensive
neighbor notification program should be established, requiring posting near the
farm, and door-to-door notification for families living within ½ mile of the
application site, both two weeks and 24 hours before fumigation begins. Also,
to detect drift issues as early as possible, and to ensure the community’s
right to know, officials should insist on development of reliable, real-time
air monitoring methods and require air monitoring for wind direction and
detection of chloropicrin at the border of the buffer zone.
We strongly urge that DPR and Cal/EPA take swift
action to protect community members from chloropicrin and immediately develop a
comprehensive plan to phase out chloropicrin and transition to safe
replacements by 2020.
Aird & Tracey Brieger
for Pesticide Reform