Dear friends,
This is important news and information - please take a look.
Thanks -
Ericka Dana, Catnip Farm
Midwest Anti-Drift Coalition
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From: PANUPS <[log in to unmask]>
Date: Fri, 18 Jan 2002
Subject: PANUPS: Drift Action Alert Sample Letter
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P A N U P S
Pesticide Action Network Updates Service
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For the "Strengthen Controls on Pesticide Drift" Action Alert sample
letter and detailed talking points, please visit the following link:
http://www.panna.org/panna/billboard/billboard_020118.dv.html
Strengthen Controls on Pesticide Spray Drift
January 18, 2001
The U.S. Environmental Protection Agency (EPA) is currently considering
comments on their Pesticide Registration (PR) Notice 2001-X, Spray and Dust
Drift Label Statements for Pesticide Products, which seeks to regulate
pesticides in order to control pesticide spray drift, largely by changing
the labeling of pesticide products. The agency is accepting comments until
Friday, March 29, 2002.
PAN North America urges you to send a letter to EPA expressing your concerns
about EPA's proposed drift-control strategies. In particular, we wish to
challenge some basic assumptions the EPA makes about drift and how to
control it, with the aim of eventually achieving significant reductions in
the amount of pesticides applied. Reduction in use of the most highly toxic
pesticides is the highest priority.
Below are EPAšs contact details, a sample letter and PANNAšs detailed
comments on the strategy. For a more general background on drift, see the
most recent PANUPs Action Alert on drift.
Action:
Submit your comments to EPA on PR Notice 2001-X on or before Friday March
29, 2002. The EPA PR Notice can be found at
http://www.epa.gov/opppmsd1/PR_Notices/prdraft-spraydrift801.htm.
Send emails to [log in to unmask], with OPP- 00730A in the subject line, or
send a letter referencing Docket No. OPP- 00730A to:
Public Information and Records Integrity Branch (PIRIB)
Information Resources and Services Division (7502C)
Office of Pesticide Programs (OPP)
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460 U.S.A.
Sample Letter
[Below is a brief sample letter that covers some of the main concerns with
drift. You may want to emphasize and elaborate upon certain points based on
your own experience/knowledge or by using PANNA's detailed comments below.]
To: U.S. Environmental Protection Agency (EPA), Office of Pesticide Programs
From: <<Your name, affiliation, and address here>>
Re: U.S. EPA PR Notice 2001-X, Spray and Dust Drift Label Statements for
Pesticide Products, Docket control number OPP- 00730A.
Thank you for the opportunity to comment on EPA's spray and dust drift label
statements for pesticide products. <<I/We>> appreciate EPA's acknowledgement
that pesticide drift is a significant problem and hope that <<my/our>>
comments and recommendations are incorporated in the final labeling
requirements.
<<If you have had a personal experience with pesticide drift, you might want
to include your story here.>>
It is crucial that stronger measures be taken to protect humans and the
environment from pesticide drift. EPAšs current proposed approach has many
shortcomings, including:
1. The definition of drift is too narrow. EPA's definition of drift does not
take into account all sources of drift. Excluding all drift that occurs
after a pesticide application ignores some of the most important sources of
drift, such as pesticide evaporation and pesticide-coated dust particles.
This leads to proposed control strategies that are grossly inadequate for
reducing off-site, airborne movement of pesticides.
2. Technical specifications have limited ability to control drift. Despite
improved engineering of nozzles and determination of optimum droplet size,
real world experience demonstrates that applicators are often not trained to
use the technology correctly and frequently spray in weather conditions that
promote drift. The fact that acute poisonings still occur with disturbing
regularity (sub-acute or chronic poisonings are even more common) suggests
that more of the same "technology enhancement" approach will not solve the
problem.
3. There are serious knowledge gaps regarding the effects of airborne
pesticides. Toxicological data on inhalation exposures are not available for
most pesticides. Also, air monitoring data show that people are frequently
exposed to multiple pesticides simultaneously in the air they breathe but
the toxicological effects of exposure to multiple chemicals are unknown.
In short, new strategies are needed to prevent pesticide drift. The most
effective approach is to ban the use of drift-prone pesticides--especially
the most highly toxic ones--and problematic spray technologies altogether.
Finally, pesticide drift has significant adverse effects on ecosystems
(including fish, wildlife and beneficial insects) as well as many different
communities, such as farmworkers, residents of rural communities, organic
farmers, and urban residents. Adversely affected communities must be
included meaningfully in the process of determining new drift control
strategies.
Thank you for your time and attention.
Sincerely,
<<Your name and, if appropriate, position and organization >>
[Back to top]
PANNAšs Specific Comments on PR Notice 2001-X
Our specific comments are detailed below.
1) Definition of drift inadequate: The U.S. EPA's definition of drift in
Section I.B is inadequate since it defines drift as occurring only at the
time of application or immediately thereafter. In fact, any off-site
movement of the active ingredient, including volatilization or movement on
wind-blown dust particles, should be included in the definition of drift,
since all of these off-site movements represent opportunities for exposures.
While controls at the time of application are necessary to reduce
application-related drift, such measures are not sufficient to control
post-application drift of pesticides. If U.S. EPA wishes to address the full
range of adverse effects caused by pesticide drift, post-application drift
must be regulated as well, thus, the definition of drift should be modified
to include post-application off-site pesticide movement of any type. See
above for our proposed definition.
2) The most effective way to reduce pesticide drift is to ban the use of
drift-prone pesticides and problematic spray technologies altogether,
particularly for the pesticides known to be most harmful to human and
ecosystem health. Aerial spraying is particularly problematic, with
poisoning incident data showing many worker poisonings due to aerial
spraying. The fact that terrorists have been investigating the use of this
technology is another reason to prohibit aerial applications altogether and
dismantle the infrastructure that makes rapid dispersal of highly toxic
substances possible. U.S. EPA must move quickly to phase out these
technologies and replace them with less hazardous, more ecologically
sophisticated alternative systems and methods.
3) As an interim measure, the proposed label statement is a good start
towards controlling drift: We support U.S. EPA's proposed label language in
Section II.B., which reads:
"Do not allow spray to drift from the application site and contact people,
structures people occupy at any time and the associated property, parks and
recreation areas, nontarget crops, aquatic and wetland areas, woodlands,
pastures, rangelands, or animals."
The statement should be modified slightly to specifically include public
roads, streets and sidewalks.
4) A secondary approach to reducing pesticide drift is to reduce application
rates to lower the absolute amounts of pesticides released into the
environment. Combined with biologically based integrated pest management,
this approach would save farmers money by reducing the amount of pesticides
they use and result in significant progress towards reducing drift. Again,
for maximum protection of public health and the environment, the most-toxic
pesticides should be targeted first for significant reduction in application
rates until they are phased out.
5) Omission of fumigants: We are deeply concerned that fumigants are being
omitted from this attempt to regulate drift. These pesticides are highly
mobile gases and the most drift-prone of any group of pesticides. All of the
fumigants are known to have serious adverse health effects and are used in
very large amounts, with application rates of 100-400 pounds per acre. The
most effective strategy for controlling fumigant drift would be to eliminate
use of these dangerous pesticides altogether. In the absence of a complete
ban, substantial reductions in the amounts applied in a given time period in
a particular area should be implemented as soon as possible.
6) Buffer zones essential: If drift-prone pesticides and technologies are to
continue to be used, buffer zones (no-spray zones) should be required by the
label for all pesticides applied by spray or blower technologies, including
aerial and ground-rig airblast applications, as well as spray or dust
applications using blowers or fans. Buffer zones must be contained within
the property on which the pesticide is applied and clearly defined so they
do not include adjacent private properties (unless permission of the
property owner has been explicitly granted in writing), public lands or
public thoroughfares. Buffer zones also need to be large enough to protect
workers in adjacent fields, neighboring organic farms, and residents
(including labor camps) within a specified radius of the spray area. All
buffer zones should be delineated for the highest wind speed allowed by the
label in order to protect surrounding areas under worst case scenarios.
7) Problematic language: There are several areas in which U.S. EPA's
language is problematic or unclear. In particular, we object to the idea
that some de minimus level of drift is expected and acceptable. Our point of
view is that any amount of chemical that drifts away from the application
site and makes its way into other fields, our homes, schools, or workplaces
is unacceptable. We are not recommending that U.S. EPA set "safe" levels of
drift for each pesticide---this approach is impossible because of the
unknowns associated with exposure to multiple pesticides. A better approach
would be to ban or severely restrict spray applications of pesticides and
use of volatile pesticide chemicals. For as long as drift-prone applications
continue, it is essential that neighboring communities not be required to
accept any level of chemical trespass onto their homes, property,
businesses, schools and workplaces, just so others can profit.
The term "unreasonable adverse effects" has similar problems. We would like
clarification from U.S. EPA as to which adverse effects are considered
"reasonable."
8) Posting and notification requirements: Pesticide label instructions must
require 24-hour advance written notification of all residents and property
owners within 1/4 mile of any application that has the potential to drift
off-site at any time during or after the application. Information should
include anticipated date and time of spraying, name and phone number of
applicator, name and phone number of the property owner, name of the
pesticide product, a list of active ingredients and other ingredients, and a
copy of the Material Safety Data Sheet (MSDS) for the pesticide product(s)
being sprayed. The label must also require the sprayed area to be posted for
72 hours after the application.
9) Flexibility for Applicators Should be Limited: The pesticide
manufacturing and applicator industries appear to be requesting ultimate
flexibility for applicators to test and develop new methods. We agree that
development of new technologies will be important in controlling
application-related drift; however, we are concerned to note that these
stakeholders would like to use the new technologies to spray in weather
conditions (wind speed, as an example) that currently exceed recommended
standards, or use application rates that are higher than existing label
rates. In our view, they do not deserve this flexibility, since the
discretion they presently have has led to a substantial number of acute
poisoning incidents and numerous more sub-acute or chronic problems. In
particular, we think that applicators should never be permitted to apply
more pesticide than the label application rate or at higher wind speeds than
8 mph. Experiments focused on reducing application rates (resulting in a
reduction in the total amount of pesticide actually applied) should be
strongly encouraged.
Thank you for the opportunity to offer comments. Please make this an
effective process of public input by recognizing and including our concerns
in the strategies for controlling drift in the future.
------------------------------------------------------------------------
Email us at: [log in to unmask] Phone us at: (415) 981-1771. Also see Contact
and visit information.
Site design and implementation by Skip Spitzer. Also see Acknowledgements
and Awards.
This page is www.panna.org/panna/billboard/billboard_020118.dv.html on
January 18, 2002 at 04:24 PM (PST)
Š2001 by Pesticide Action Network North America (PANNA).
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