Will the EPA Ban a Pesticide That’s Been Lowering Children’s IQs for Years?

Elizabeth Grossman

The pesticide chlorpyrifos is known to cause headaches, nausea and dizziness, and even to stifle neurological development in children. (Wisconsin Department of Natural Resources / Flickr)

In a remark­ably rare move, the U.S. Envi­ron­men­tal Pro­tec­tion Agency (EPA) is propos­ing to with­draw its approval for all agri­cul­tur­al uses of a wide­ly used pes­ti­cide, chlorpyrifos.

First approved in 1965, chlor­pyri­fos belongs to a class of pes­ti­cides known as organophos­phates — a type of chem­i­cal devel­oped as a nerve agent pri­or to World War II — that kills insects by affect­ing their ner­vous sys­tems. It’s used on dozens of crops, includ­ing cit­rus, grapes, almonds, corn, apples, broc­coli, onions, straw­ber­ries, wal­nuts, soy­beans and alfal­fa. Although use has decreased since the 1990s, about 6 mil­lion pounds of chlor­pyri­fos were used across the U.S. in 2012, about a quar­ter of that in Cal­i­for­nia alone. Chlor­pyri­fos is one of the pes­ti­cides most fre­quent­ly cit­ed in pes­ti­cide poi­son­ings of agri­cul­tur­al workers.

The EPA’s pro­pos­al was timed to respond to a court-ordered dead­line prompt­ed by a 2007 peti­tion from the Nat­ur­al Resources Defense Coun­cil (NRDC) and Pes­ti­cide Action Net­work North Amer­i­ca ask­ing the EPA to ban chlor­pyri­fos. The EPA announced its inten­tion to issue such a pro­posed rule in June but want­ed to do so by April 2016. The 9th Cir­cuit court reject­ed this time­line and ordered the EPA to act by Octo­ber 31, 2015. The EPA says it intends to issue a final rule on chlor­pyri­fos by Decem­ber 2016. Earth­jus­tice, which filed the advo­ca­cy groups’ peti­tions with the EPA, is ask­ing the 9th Cir­cuit court to make this dead­line legal­ly binding.

We’ve been push­ing for this for many years,” Farm­work­er Jus­tice occu­pa­tion­al and envi­ron­men­tal health direc­tor Vir­ginia Ruiz told In These Times. This, she said, is def­i­nite­ly a big deal.”

Chlor­pyri­fos man­u­fac­tur­er Dow Agro­Sciences down­played the EPA action, say­ing in a state­ment that it dis­agrees” with the EPA’s pro­pos­al and that the EPA pro­pos­al is just that: a pro­pos­al, not a final reg­u­la­to­ry action. It has no cur­rent impact on exist­ing uses of the product.”

The pes­ti­cide man­u­fac­tur­ers’ trade asso­ci­a­tion CropLife Amer­i­ca said in a state­ment post­ed to its web­site that it is dis­ap­point­ed” in the EPA’s pro­pos­al, call­ing it a dras­tic and unnec­es­sary step that is caused by waste­ful, agen­da-dri­ven lit­i­ga­tion.” Chlor­pyri­fos, says CropLife Amer­i­ca, is an invalu­able tool for grow­ers on a diverse array of crops.”

High­ly tox­ic to the ner­vous system

But chlor­pyri­fos is well rec­og­nized as high­ly tox­ic to the ner­vous sys­tem. It can have seri­ous, imme­di­ate adverse effects — among them headache, nau­sea, dizzi­ness, vision and mus­cle prob­lems. Farm­work­ers have been over­ex­posed even with all the pro­tec­tive cloth­ing that could pos­si­bly required,” says Earth­jus­tice man­ag­ing attor­ney Pat­ti Goldman.

Chlor­pyri­fos is also well doc­u­ment­ed to have long-last­ing neg­a­tive impacts on the neu­ro­log­i­cal health and devel­op­ment of chil­dren whose moth­ers were exposed to chlor­pyri­fos while preg­nant, includ­ing at lev­els below those that prompt imme­di­ate effects and below expo­sure lev­els EPA con­sid­ers acceptable.

Chil­dren exposed pre­na­tal­ly, in Cal­i­for­nia agri­cul­tur­al com­mu­ni­ties and in New York City where chlor­pyri­fos was used in indoor pest con­trol, have been found to have low­ered IQ, impaired cog­ni­tive abil­i­ty and behav­ior prob­lems. Researchers at the Uni­ver­si­ty of Cal­i­for­nia-Berke­ley and Colum­bia Uni­ver­si­ty have both found that the high­er the chlor­pyri­fos expo­sure, the greater the children’s IQ reduc­tion. But they also found there to be no lev­el of chlor­pyri­fos expo­sure that did not low­er IQ to some extent.

What makes this evi­dence par­tic­u­lar­ly strik­ing is that in chil­dren exposed pre­na­tal­ly, researchers at Colum­bia Uni­ver­si­ty have also seen phys­i­cal alter­ations in parts of the brain that con­trol work­ing mem­o­ry, lan­guage, behav­ior and emo­tion. In a paper pub­lished this Sep­tem­ber, Vir­ginia Rauh, deputy direc­tor of children’s envi­ron­men­tal health at Colum­bia University’s Mail­man School of Pub­lic Health and col­leagues found pre­na­tal chlor­pyri­fos expo­sure to be asso­ci­at­ed with child­hood arm tremors, a sign of the pesticide’s ner­vous sys­tem effects.

This is par­tic­u­lar­ly com­pelling evi­dence,” says Colum­bia Uni­ver­si­ty Mail­man School of Pub­lic Health pro­fes­sor emer­i­tus of envi­ron­men­tal sci­ence Robin Why­att, whose research has linked pre­na­tal chlor­pyri­fos to low­er birth weights as well as neu­ro­log­i­cal impacts. This is a chem­i­cal that has been stud­ied exten­sive­ly with a phe­nom­e­nal amount of con­sis­ten­cy in exper­i­men­tal and epi­demi­o­log­i­cal data,” says Whyatt.

EPA cites risks from drink­ing water

In announc­ing the pro­posed ban on Octo­ber 30, the EPA explained that while there do not appear to be risks from expo­sure to chlor­pyri­fos in food,” when those expo­sures are com­bined with esti­mat­ed expo­sure from drink­ing water in cer­tain water­sheds, EPA can­not con­clude that the risk from aggre­gate expo­sure meets the Fed­er­al Food, Drug and Cos­met­ic Act (FFD­CA) safe­ty stan­dard.” Water­sheds of most con­cern are small­er ones that are heav­i­ly farmed, explains the EPA.

In oth­er words, accord­ing to the EPA, while residues left on food alone may not present a health con­cern, when com­bined with chlor­pyri­fos present in drink­ing water as result of drift and runoff, expo­sure becomes a con­cern. The fact that they found high lev­els in drink­ing water, that’s what’s dri­ving the EPA to say this [agri­cul­tur­al use of chlor­pyri­fos] isn’t doable any more,” explains NRDC senior sci­en­tist Jen­nifer Sass.

Adding to the con­cern about chlor­pyri­fos in drink­ing water is the fact that, when treat­ed by chlo­ri­na­tion as much drink­ing water is, chlor­pyri­fos turns into anoth­er form of the chem­i­cal that is per­sis­tent and par­tic­u­lar­ly tox­ic. Data ana­lyzed for the EPA’s chlor­pyri­fos risk assess­ment released in Decem­ber 2014 has led the agency to deter­mine that many uses of chlor­pyri­fos will result in drink­ing water lev­els that put infants and chil­dren at risk.

Con­cern about chlo­rypri­fos has been build­ing for some time. In 2000, the EPA banned indoor house­hold use of chlor­pyri­fos (with the excep­tion of ant and roach bat in child-resis­tant pack­ag­ing). While the chem­i­cal breaks down when exposed to sun­light, it can last a long time indoors and thus pose long-term expo­sure haz­ards. Chlor­pyri­fos can last for years and years indoors,” explains Why­att. We’re still detect­ing it a decade after the ban” in the homes where chlor­pyri­fos mon­i­tor­ing has been done, she says.

Short­ly after the EPA banned indoor use, it also reduced the amount of chlo­rypri­fos that could be legal­ly applied to apples and grapes—due to con­cerns about children’s expo­sure — and barred its use on toma­toes. Still, in 2010, the Cal­i­for­nia Depart­ment of Pub­lic Health found chlor­pyri­fos to be among the top ten pes­ti­cides applied with­in one-quar­ter mile of Cal­i­for­nia pub­lic schools in the 15 coun­ties studied.

Then in 2012, to address con­cerns about pes­ti­cide drift raised in peti­tions filed with the EPA by Earth­jus­tice on behalf of NRDC, Pes­ti­cide Action Net­work North Amer­i­ca and oth­er envi­ron­men­tal orga­ni­za­tions, the EPA imposed buffer zones around pub­lic spaces, includ­ing parks and homes, while low­er­ing allow­able chlor­pyri­fos appli­ca­tion lev­els. Yet accord­ing to its cur­rent analy­sis, the EPA said in its Octo­ber 30 announce­ment that it can­not con­clude that the risk from aggre­gate expo­sure meets the Fed­er­al Food, Drug, and Cos­met­ic Act (FFD­CA) safe­ty standard.”

How­ev­er, the EPA is still ana­lyz­ing drink­ing water data, both to make sure any final deci­sion pro­tects infants and chil­dren” and to deter­mine risks for the entire coun­try in addi­tion to those water­sheds already analyzed.

The EPA pro­pos­al — which would leave in place use on golf cours­es, turf and oth­er non-agri­cul­tur­al appli­ca­tions — will be open for pub­lic com­ment for 60 days. Dow Agro­Sciences says it is con­fi­dent” that issues relat­ing to the con­tin­ued use of chlor­pyri­fos can be read­i­ly resolved with a more refined analy­sis of data.”

Among indus­try groups’ hopes, says Gold­man, is that EPA may lim­it a chlor­pyri­fos ban to cer­tain water­sheds. But EPA is also cur­rent­ly review­ing sev­en addi­tion­al organophos­phate pes­ti­cides that, like chlor­pyri­fos, can cause both short- and long-term adverse neu­ro­log­i­cal effects to work­ers and the gen­er­al pub­lic, includ­ing infants and chil­dren. This is huge because it means EPA is stand­ing behind its sci­ence on neu­rode­vel­op­men­tal effects,” says Goldman.

And when it comes to chlor­pyri­fos’ tox­i­c­i­ty says Why­att, Com­pared to many chem­i­cals, this is one about which there appears to be no doubt in anybody’s mind.”

Eliz­a­beth Gross­man is the author of Chas­ing Mol­e­cules: Poi­so­nous Prod­ucts, Human Health, and the Promise of Green Chem­istry, High Tech Trash: Dig­i­tal Devices, Hid­den Tox­i­cs, and Human Health, and oth­er books. Her work has appeared in a vari­ety of pub­li­ca­tions includ­ing Sci­en­tif­ic Amer­i­can, Yale e360, Envi­ron­men­tal Health Per­spec­tives, Moth­er Jones, Ensia, Time, Civ­il Eats, The Guardian, The Wash­ing­ton Post, Salon and The Nation.
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