.png "Protect farmworkers from highly toxic fumigants!")
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[After submitting this Action, members of the public will also have the option to copy/paste comments directly to the California Department of Pesticide Regulation website. Unfortunately, a "click and submit" form is currently not available for CDPR comments; we apologize for the inconvenience.]
Given that three-quarters of all fruits and nuts and one-third of all vegetables consumed by U.S. food eaters are grown in California, we all have standing in voicing concerns about how our food is grown. So, as the California Department of Pesticide Regulation (CDPR) considers a draft regulation that allows highly elevated exposure to an extremely toxic pesticide, there is an opportunity for the public to be heard. CDPR is proposing to allow continued community exposure to the cancer-causing pesticide 1,3-dichloropropene (1,3-D, also known as Telone) at levels that are fourteen times higher than the State's official cancer risk level, perpetuating environmental racism and endangering vulnerable communities.
CDPR's draft regulation applies separate and unequal standards for different groups, allowing children and adult residents near agricultural fields to be exposed to significantly higher cancer risks than workers in neighboring fields—the "occupational bystanders." This discrepancy is unjustifiable and fails to uphold the principles of equity and environmental justice.
For decades, 1,3-D has harmed communities, particularly Latino and Indigenous populations, who are disproportionately exposed to the pesticide. The State's own toxicologists at the Office of Environmental Health Hazard Assessment (OEHHA) have set a cancer risk exposure level of air concentrated with 1,3-D at 0.04 parts per billion (ppb) per day. Yet, CDPR has adopted one regulation and is proposing another for the same pesticide: one adopts the 1,3-D manufacturer Dow Chemical's preferred exposure standard of 0.56 ppb per day for residents and children, while the other uses the OEHHA standard for occupational bystanders. Even for occupational bystanders, by disregarding off-the-clock exposure, DPR proposes implementing only 100-foot buffer zones, entirely inadequate for protection against a fumigant that can drift for miles at harmful levels.
It is outrageous that the Environmental Protection Agency (EPA) and CDPR would allow farmworkers—whose labor was judged “essential” during the pandemic—to be routinely exposed to highly toxic pesticides, which could be replaced by organic practices.
1,3-D is a pre-plant soil fumigant registered for use on soils to control nematodes. It is allowed on all crops and is often used with chloropicrin, another highly toxic fumigant, to increase its herbicidal and fungicidal properties. 1,3-D causes cancer. In addition, the National Institutes of Health's PubChem states, “Occupational exposure is likely to be through inhalation and via the skin. Irritation of the eyes and the upper respiratory mucosa appears promptly after exposure. Dermal exposure caused severe skin irritations. Inhalation may result in serious signs and symptoms of poisoning with lower exposures resulting in depression of the central nervous system and irritation of the respiratory system. Some poisoning incidents have occurred in which persons were hospitalized with signs and symptoms of irritation of the mucous membrane, chest discomfort, headache, nausea, vomiting, dizziness and, occasionally, loss of consciousness and decreased libido.” Chloropicrin is extremely irritating to lungs, eyes, and skin. Inhalation may lead to pulmonary edema, possibly resulting in death.
These and other soil fumigants not only pose severe health threats to farmworkers and bystanders but also threaten soil and water ecosystems. In contrast, organic production seeks to build healthy soils that resist plant pathogens, making fumigation unnecessary. Thus, these fumigants pose unreasonable adverse effects on humans and the environment and should be banned.
>>Tell EPA and Congress to cancel the registration of all toxic soil fumigants and encourage organic alternatives.
As a reminder, after submitting this Action, members of the public will also have the option to copy/paste comments directly to the California Department of Pesticide Regulation website!
The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress with an opportunity to submit comments at the state level to the California Department of Pesticide Regulation.
Thank you for your active participation! The Action is a multi-step process, so please click submit below to proceed to step two, where you will be able to personalize comments before final submission. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing.