The public comment period will be open until June 5th, 2017. It is imperative that you, as a member of the public, voice your concern. You can do so here at Regulations.gov, either using your name and contact information, or as Anonymous. Docket ID: EPA-HQ-OPP-2007-1005-0100
The backstory: For the past 10 years the NRDC and Panna has been fighting via the legal system to get the worst of the worst pesticides removed. Chlorpyrifos is one of those. The NRDC and Panna won a very rare victory, banning chlorpyrifos use. However, just as it was about to be implemented, Scott Pruitt, the new director of the EPA blocked it and instead removed ALL tolerances for chlorpyrifos. Read my Open Letter to Trump about chlorpyrifos and autism.
Chlorpyrifos is an organophosphate and also found in flea and tick products. Find my comments below.
To revoke pesticide tolerances for organophosphates, including chlorpyrifos, is reckless and directly in contradiction to the mission of the EPA. “The mission of EPA is to protect human health and the environment.” including “all Americans are protected from significant risks to human health and the environment where they live, learn and work;”. The studies that Mr. Pruitt is basing this incredibly perilous decision on were provided by the registrant/manufacturer of chlorpyrifos, Dow. It is a clear conflict of interest. The Dow studies, including human studies, were deemed to be unethical and not based on good science. However the primary study advocating for this ban was a CHARGE study which followed over 900 people over the course of years. This study showed a direct link, with even minute amounts of exposure, to neurotoxicity causing increased autism and developmental delay in infants when mothers were exposed during pregnancy. Backing conflict-of-interest studies which already were deemed unethical vs a genuine above-reproach study when making this unilaterally reckless decision is appalling.
Chlorpyrifos is used on crops and subsequently has been found in dangerously high levels in our food supply; up to 140 times higher than acceptable levels. To boil it down, that’s 14,000% higher for children in the 1 to 2 year age range. Even with a small margin for calculation error, there is no way this pesticide currently is at any “safe” or acceptable tolerance.
In addition, it has been restricted already for home use due to the danger it poses particularly to children. However it still creeps into our homes in the form of traditional flea and tick products such as spot-on, drops, collars, powders, sprays and others. Exposure to infants via domesticated companion animals is grave. Hand to mouth activity of toddlers is legendary to any parent. This use on pets is a direct route to exposure for infants and toddlers as well as susceptible adults.
The NRDC and Panna went through an extensive ten year process to protect our children and communities from an incredibly dangerous organophosphate pesticide, chlorpyrifos. Mr Pruitt in a short brief and a handshake with Dow and CropLife, wink wink, believes that ten years of court and documents is not sound science.
It is reckless and a clear breach of public trust as well a dereliction of duty. Human health and that of our children and most vulnerable populations is not the right of a political agenda, but that of the office Mr Pruitt promised to carry out faithfully. Couching this decision in lack of sound science is nothing more than obfuscating his own agenda.
Perhaps some people do not realize that it is incredibly difficult to ban a pesticide in the United States. For one, there is a small addendum in a farm bill that allows manufacturers and registrants like Dow, to cash in on their lost profits. It was originally written into this bill and sold as being for the benefit of farmers, however to date no farmers have ever used it. Why? Because pesticide manufacturers have other pesticide products to market in the stead of banned substances. Due to this, and the fact that the EPA must weigh loss of profit over human health, in this case banning chlorpyrifos is the right thing to do. Dow will not lose profit, only be slightly inconvenienced. However an autistic child will struggle for a lifetime.
In weighing loss of profit, you must also consider other economic influences in your decision. The economic impact on your other stakeholders – the American People.
The medical costs associated with developmental delay and autism will be saved on a large-scale. How much might be saved? A study from 2014 published and peer reviewed in JAMA Pediatrics suggests the cost of care for one autistic child over a lifetime is as high as $2.4 million. This figure includes direct medical, educational and residential costs but it also considers costs that are indirectly influenced, such as lost wages of parents (not lost wages of the child as an adult). They found for autistic individuals with no developmental delay the costs were in excess of $1.4 million over the cost of other children. Boiling it down, the cost of an autistic child with a developmental delay averages between $85,000 to $107,000 per year depending upon age. With such a steep increase in autism in the US, surely these economics must be weighed with equal weight as the loss of profit of one company. Autism services cost U.S. citizens $236-262 billion annually. (Buescher et al., 2014)
Also, you must consider the additional cost to Medicare and Social Security, for all the children who will not need to receive governmental assistance from autism or developmental difficulties as a direct result of chlorpyrifos exposure of their mothers while pregnant.
Dow will survive, but many children and families will suffer if you do not honor this prudent and necessary ban of chlorpyrifos.