October 6, 2011 Pesticide Re-evaluation Division Office of Pesticide Programs Environmental Protection Agency 1200 Pennsylvania Ave.

, NW Washington, DC 20460-0001 Re: To: Support for ending all remaining uses of the neurotoxic pesticide chlorpyrifos to protect childrens health -- Docket #: EPA-HQ-OPP-2008-0850 Administrator Lisa Jackson, Administrator Steven Bradbury, Director Office of Pesticide Programs Tom Myers, Pesticide Re-evaluation Division

In 2000 the Environmental Protection Agency banned the pesticide chlorpyrifos, commercially called Dursban, in roach killers, flea bombs and other household pesticides. Chlorpyrifos is a widely-used pesticide and known neurotoxicant. The agencys decision to bar it in household use was based on its determination that Dursban was among a handful of highpriority pesticides posing the greatest risks to human health. It was among the first pesticides EPA evaluated and found unsafe for children under the ground-breaking childrens health standards established by the 1996 federal Food Quality Protection Act. Despite EPAs action, too many children are being exposed to significant amounts of this chemical. The chemical is also found on domestic and imported produce (Lu 2011). Every year, American farmers use nearly 10 million pounds of chlorpyrifos. The U.S. Department of Agriculture pesticide monitoring program has measured chlorpyrifos on popular fresh produce in recent years including peaches (13 to 18 percent in 2006, 2007, 2008), bell peppers (17 and 18 percent in 2003-2004), plums (17 percent in 2006), cranberries (22.5 percent in 2006), nectarines (10 to 15 percent in 2007 and 2008). Recent research studies suggest that childrens risks from chlorpyrifos are even higher than previously believed. Numerous studies find that American children exposed to chlorpyrifos and related organophosphate pesticides during pregnancy suffer from measurable and lasting deficits in learning and memory. Three studies published in the last year alone of more than 800 children in New York and California, authored by researchers at Columbia University, Mt. Sinai School of Medicine and University of California, Berkeley, add to a body of science demonstrating that children exposed to chlorpyrifos have lower intelligence scores, loss of memory and diminished reasoning skills (Rauh 2011, Engel 2011, Bouchard 2011).

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Biomonitoring data from the federal Centers for Disease Control and Prevention, collected between 2000 and 2002 period showed that two in five American children were exposed to organophosphate pesticides exceeding the EPA reference dose or safety level (Payne-Sturges 2009). The CDC found that children with the highest measurements of organophosphates in their bodies were more likely to be diagnosed with attention deficit-hyperactivity disorder (Bouchard 2010). But at a time when evidence is mounting that the chemical is damaging American children, EPA is back-pedaling on its assessment of risks to childrens health. In its 2011 Chlorpyrifos Preliminary Human Health Risk Assessment for Registration Review, EPA has reduced its estimate of the chemicals risk to children by 7- to 10-fold, citing spurious justifications not supported by science. If these faulty estimates stand, chlorpyrifos could remain a pervasive food contaminant, and childrens health would continue to be damaged long into the future. The Congress wrote the 1996 Food Quality Protection Act to require that EPA take special precautions for children because their rapidly developing brains, nervous and reproductive systems and immature detoxification systems made them more susceptible than adults to permanent damage from pesticides and other poisons. EPA is required to add a factor of 10 to all risk calculations unless it can prove, based on reliable data, that lesser protections will be safe for infants and children (FQPA at FFDCA 408(b)(2)(C)). While the 10-fold safety factor was meant to establish the standard practice for most pesticide risk assessments, EPA has rarely employed it. In the new chlorpyrifos risk assessment, EPA uses rat studies as justification for deciding that the 10-fold safety factor is not justified. However it is not clear that the same toxicological mechanism is the one that affect childrens intelligence. It is quite possible that children are more sensitive that rats to neurological damage induced by chlorpyrifos. In his comments to EPA on this topic, Duke University professor Thomas Slotkin points out that humans appear to be more sensitive to neurotoxicity than laboratory animals (Slotkin 2011 citing Rauh 2006). In a 2006 study by Virginia Rauh of Columbia University the effects of chlorpyrifos toxicity are seen in the children exposed to concentration of 6.2 parts per trillion or greater, much lower than the doses that caused blood or brain cholinesterase depression in laboratory studies. To protect childrens health, Environmental Working Group fully supports ending all remaining uses of chlorpyrifos. We fully support the excellent technical comments by the Natural Resources Defense Council detailing the many flaws in EPAs new health assessment. We also support the petition submitted by the NRDC and its partners advocating an end to all use of this hazardous chemical. It is of vital importance that the agency retain the 10-fold safety factor for children in its new health assessment, as required under the Food Quality Protection Act. The law allows a weaker factor only in cases where reliable evidence supports it. This is not such a case, as the NRDC persuasively argues. Given the stakes childrens intelligence, memory and reasoning this is not the time to weaken the safety margin the agency has allowed in the cases of toxic substances that pose danger to the developing brain.

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We ask not only that you make these critical improvements to the 2011 chlorpyrifos health assessment quickly, but also that you also take expeditious action to end all remaining uses of this neurotoxic chemical. Nothing less will adequately protect the health of our children. Sincerely,

Jane Houlihan Senior Vice President for Research

Sonya Lunder Senior Analyst

References: Bouchard MF, Bellinger DC, Wright RO, Weisskopf MG. 2010. Attention-deficit/hyperactivity disorder and urinary metabolites of organophosphate pesticides. Pediatrics. Jun;125(6):e1270-7. Bouchard M, Chevrier J, Harley K, Kogut K, Vedar M, Calderon N, et al. 2011. Prenatal Exposure to Organophosphate Pesticides and IQ in 7-Year Old Children. Environ Health Perspect 119(8):1189-95. Engel SM, Wetmur J, Chen J, Zhu C, Barr DB, Canfield RL, et al. 2011. Prenatal Exposure to Organophosphates, Paraoxonase 1, and Cognitive Development in Childhood. Environ Health Perspect 119(8):1182-8. Lu C, Barr DB, Pearson MA, Waller LA. 2008. Dietary intake and its contribution to longitudinal organophosphorus pesticide exposure in urban/suburban children. Environmental Health Perspectives 116(4):537-42. Lu, C, FJ Schenck, MA Pearson and JW Wong. 2010. Assessing childrens dietary exposuredirect measurement of pesticide residues in 24-hour duplicate food samples. Environ Health Perspect. 118(11):1625-30. Payne-Sturges D, Cohen J, Castorina R, Axelrad DA, Woodruff TJ. 2009. Evaluating cumulative organophosphorus pesticide body burden of children: a national case study. Environ Sci Technol 43(20):7924-30. Rauh V, Arunajadai S, Horton M, Perera F, Hoepner L, Barr DB, et al. 2011. 7-Year

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Neurodevelopmental Scores and Prenatal Exposure to Chlorpyrifos, a Common Agricultural Pesticide. Environ Health Perspect 119(8):1196-201. Rauh VA, Garfinkel R, et al. 2006. Impact of prenatal chlorpyrifos exposure on neurodevelopment in the first 3 years of life among inner-city children, Pediatrics 118:18451859. Slotkin T. 2011. Comments regarding EPA chlorpyrifos risk assessment. Docket: EPA-HQ-OPP2008-05, July 15, 2011. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOPP-2008-0850-0043

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