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Pesticides in California’s Air What You Don’t Know Could Hurt You  W O R K I N G G R O U P T M E N V I R O N M E N T A L  

What You Dont Know Could Hurt You

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Pesticidesin

California’sAir

WhatYou

Don’tKnow

CouldHurtYou

W O R K I N G G R O U PT M

E N V I R O N M E N T A L

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Acknowledgments

This report is the joint product of Bill Walker, Richard Wiles, Todd Hettenbach and Chris Campbell of EWGand Kert Davies, formerly of EWG and now of Ozone Action. It is released in partnership with Californians forPesticide Reform, a statewide coalition of more than 100 public interest groups, including EWG, working to protectpublic health and the environment from pesticide proliferation.

Thanks to EWG’s Molly Evans who designed and produced the publication. For their insight, suggestions andassistance, thanks also to David Chatfield, Ken Cook, Patty Clary, Joan Clayburgh, Jonathan Kaplan, Anne Katten,Ralph Lightstone, Pete Price, Zev Ross and Wil Sumner. Special thanks to Jeanne Merrill of Pesticide Watch and theCommunity Coalition Against Pesticide Drift, and all the groups who assisted with the Community MonitoringProject: Action Now, Californians for Alternatives to Toxics,Community & Children’s Advocates Against PesticidePoisoning, Committee to Save Pescadero, the community of Davenport, Environmental Center of San Luis Obispo,Environmental Defense Center, Farm Without Harm, Regional Environmental Alliance for Progress and Volunteersfor a Healthy Valley.

What You Don’t Know Could Hurt You is dedicated to Alexandra Walker Barish (b. 8/2/98) and Oona MaeDavies (b. 7/16/98).

This report was made possible by grants from the Richard and Rhoda Goldman Fund, the W. Alton Jones Foun-dation, the Arkay Foundation, Patagonia Inc, and The Gap Foundation. The opinions expressed in this report arethose of the authors and do not necessarily reflect the views of the supporters listed above. Environmental Work-ing Group is responsible for any errors of fact or interpretation contained in this report.

© January 1999 by Environmental Working Group/The Tides Center. All rights reserved. Manufactured in theUnited States of America. Printed on recycled, chlorine-free paper.

Environmental Working Group

Environmental Working Group is a nonprofit environmental research organization with offices in Washington,D.C. and San Francisco. EWG is a project of the Tides Center, a California Public Benefit Corporation based in San

Francisco that provides administrative and program support services to nonprofit programs and projects.

Kenneth A. Cook, PresidentRichard Wiles, Vice President for ResearchEdward Hopkins, Vice President for ProgramsBill Walker, California Director

To order a copy

Copies of this report may be ordered from the Washington office for $20 each (plus 6% sales tax, or $.60 for Washington, D.C. residents) and $3 for postage and handling. Payment must accompany all orders. Please makechecks payable to:

Environmental Working Group1718 Connecticut Avenue, N.W. Suite 600

Washington, D.C. 20009(202) 667-6982 (phone)(202) 232-2592 (fax)[email protected] (e-mail)

www.ewg.org

www.ewg.org

This report and other EWG publications are available online at www.ewg.org.

EWG CaliforniaP.O. Box 29201, The PresidioSan Francisco, CA 94129(415) 561-6698 (phone)(415) 561-6696 (fax)[email protected] (e-mail)

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FOREWORD ......................................................................................... i

EXECUTIVE SUMMARY ............................................................................ 1

CHAPTER 1. T HE COMMUNITY PESTICIDE M ONITORING PROJECT ................... 7

CHAPTER 2. P ESTICIDES ARE POLLUTION , T OO ........................................ 15

CHAPTER 3. A LL IN A D AY’S SPRAY ...................................................... 23

CHAPTER 4. W HAT YOU D ON ’T KNOW C OULD H URT YOU ..................... 27

CHAPTER 5. M ETHODOLOGY ............................................................... 11

APPENDIX . DPR M EETS THE SCIENTISTS ................................................. 35

REFERENCES ...................................................................................... 43

Contents

What You Don’t Know Could Hurt You

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iENVIRONMENTAL W ORKING G ROUP

Foreword

What You Don’t Know Could Hurt You

“Given the way the law is set up, you might as well designate allpesticides as toxic air contaminants. They all kill something and they are all toxic, or they wouldn’t be put in the air.”

— James Wells, DirectorCalifornia Department of Pesticide Regulation

(Lifsher 1997)

The California Department of Pesticide Regulation (DPR) is indenial.

In the state that uses one-fourth of all pesticides applied inthe United States, and where theamount of pesticide use percapita is double the nationalrate, DPR insists that the increas-ing volume of agricultural poi-sons used in California is irrel-evant to questions of publichealth. DPR has done little fieldmonitoring of real-world pesti-cide applications to assess Cali-fornians’ actual exposure to air-borne agricultural chemicals.Still, the agency claims that arising tide of toxic pesticides isnot of concern, because DPR’sregulations limit public exposureto supposedly safe levels.

DPR further shows its disre-gard for public health by itsrecord of repeatedly failing toofficially list pesticides as toxicair contaminants, a designation

which under state law triggers

significantly increased mitigationand enforcement efforts. It’s hardto say what’s worse: DPR’s recal-citrance or the willingness of the

Wilson Administration to let themget away with it for the last eight

years.

DPR maintains its mask of de-nial even though air monitoring

by public interest groups, localcommunities and the agency itself has repeatedly found exposureand drift problems. DPR main-tains its denial even when con-fronted with geographical datashowing the proximity of schoolsor residential neighborhoods toareas of heavy pesticide use.

In August 1998, Californiansfor Pesticide Reform, a statewidecoalition of more than 100 publicinterest organizations includingEnvironmental Working Group,released a computer analysis esti-mating that 2.8 million Califor-nians live within half a mile of heavy use of the most dangerouspesticides. (CPR 1998) Previously,

The state claims that arising tide of toxicpesticides is not of concern, becauseregulations “limit”exposure tosupposedly safe levels.

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ii W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

EWG had shown that more than14 million pounds of toxic pesti-cides were sprayed within 1.5miles of California schools in1995 (EWG 1998), and that

73,000 California children attendschool within 1.5 miles of heavy methyl bromide use. (EWG1998b) DPR Director Wells dis-missed the findings out of hand,declaring: “That’s like saying thatmillions of Californians must beat risk because they live withinhalf a mile of freeways wherecars emit exhaust.” (DPR 1998)

The undisputed fact is thatmany Californians who live closeto freeways are at increased riskbecause of exposure to auto ex-haust. The link between auto ex-haust (which contains smog-forming chemicals also found inpesticides) and asthma, emphy-sema and lung cancer is welldocumented. Or DPR could lookto the example of the California

Air Resources Board, who re-cently decided that smog-spew-ing sport-utility vehicles must beregulated as strictly as other au-tos. (No exception, in other

words, just because a crackdownon a growing source of air pollu-tion might be politically unpopu-lar.) If the head of the state’spesticide agency really believesthat increased exposure to auto-

mobile exhaust is not a healthrisk, it’s not surprising he thinksit’s safe to spray highly toxic and

volatile chemicals close to schoolsand homes.

DPR’s position rests on the ar-gument that statistical analyses are

irrelevant because they measureproximity to potential exposure,not actual exposure. Now, for thefirst time, this report documentsthat many Californians are indeedroutinely exposed to toxic pesti-cides in the air they breathe. Intwo years of testing up and downthe state, EWG’s Community Pesti-cide Drift Monitoring Projectfound toxic pesticides in the air in

a significant majority of samples. What’s more, we found that Cali-fornians have no practical way of knowing what pesticides they arebeing exposed to on a day-to-day basis. In the state that prides itself on having the nation’s most com-prehensive laws to protect thepublic’s right to know about pesti-cide use, that is simply unaccept-able.

It’s time for DPR to stop deny-ing the obvious problem of run-away pesticide use. It’s time forthe State of California and thenew Davis Administration to ac-knowledge that pesticides are airpollution — posing as serious ahealth threat as auto exhaust andindustrial smokestacks — andtake the steps urgently needed to

protect the public.

Kenneth A. Cook, President Environmental Working Group

Californians have nopractical way of knowing whatpesticides they areexposed to on a day-

to-day basis.

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1ENVIRONMENTAL W ORKING G ROUP

Count

Numberof

Locations Dates

TotalNumber of Air Sam les

PercentPositive Pesticides Detected

Contra Costa 1 8-9/96 2 0% noneMonterey 5 8/96*, 8-9/97 & 5-7/98 35 66% cyfluthrin, permethrin, carbaryl,

methomyl, methyl bromideSan Mateo 1 5-6/97 3 33% iprodioneSanta Barbara 1 8/96 1 100% cyfluthrinSanta Cruz 2 11/96, 8/97, 10/97 & 5-7/98 17 59% permethrin, chlorpyrifos, methyl bromideSonoma 6 5-8/98 26 62% sulfur, carbaryl, phosmetVentura 3 6/96*, 3-5/97 & 8/97 9 66% chlorpyrifos, mycobutanil, methyl bromideSan Luis Obispo 1 10/97 1 100% methyl bromide

Executive Summary

What You Don’t Know Could Hurt You

Independent air monitoring ineight California counties by Envi-ronmental Working Group foundthat toxic pesticides routinely driftfrom farm fields into surrounding

neighborhoods and schoolyards.Of 94 air samples collected forEWG’s Community MonitoringProject from June 1996 to Sep-tember 1998, 60 samples, or 64percent, detected pesticidesknown to cause cancer, braindamage, birth defects, acute poi-soning or other illnesses. Airmonitoring was conducted at 22different locations; at 19 sites,

drifting pesticides were detectedin the air. (Table 1.)

These findings — derivedfrom almost twice as many airmonitoring tests as state pesti-cide regulators have conductedthis decade — corroborate the

overwhelming statistical evi-dence that pesticide air pollu-tion in agricultural regions of California is a real phenom-enon, and a real problem. AnEWG analysis of the latestavailable state data estimatesthat more than 100 millionpounds of pesticide pollutiondrifts or evaporates each yearfrom farm fields and vineyards

into the air Californiansbreathe.

Table 1. Many toxic pesticides drift into California communities.

*Included one 24-hour continuous methyl bromide sample.

Source: Environmental Working Group

Sixty-four percent of EWG air samplesfound drifting toxicpesticides.

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2 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

According to 1995 data fromthe California Department of Pes-ticide Regulation (DPR), there

were 303 reports of individualsexposed to pesticide drift in 1995

— almost one case of exposurein the state per day. (DPR 1997)(Table 2.) This figure should beconsidered conservative in lightof reports from agricultural com-munities that some local officialsare reluctant to report drift inci-dents and tend to dismiss resi-dents’ complaints.

In almost all documented

cases of pesticide drift, DPR maintains that the levels of po-tential exposure did not pose adanger to public health. Indeed,levels of airborne pesticides de-tected by EWG monitoring werein most cases relatively small.But exposure to low levels of airborne pesticides should not bemisconstrued as safe. Health-based safety standards for most

pesticides in air have not beenestablished. Those that do existare not set to protect childrenand other sensitive populationsbut are based on supposedly safelevels of exposure for the aver-age adult. Furthermore, they ac-count only for exposure to indi-

vidual pesticides, not to combina-tions of chemicals often driftingoff of treated fields. For commu-

nities near heavy pesticide use,the issue is not whether theamount of poison in the air is"safe," according to the DPR, butthe right not to be poisoned atall.

Pesticide air pollution affectsmillions of Californians: residents

of communities near applicationsites, children and teachers atnearby schools, and farm work-

ers and farm families who may breathe pesticide-laden air at work and home. Yet pesticideair pollution is poorly controlleddue to a gaping loophole instate air pollution regulations.Unlike all other air pollutants,pesticides are not regulated by the California Air Resources

ReportedDrift

County Incidents

San Jose 61Monterey 55Kern 39Fresno 27Imperial 25Tulare 22Ventura 18Santa Barbara 10San Diego 7Kings 6

Merced 4Stanislaus 4Yolo 4Sacramento 3Solano 3Yuba 3Butte 2Humboldt 2Madera 2Orange 2Sonoma 2Tehama 1

Colusa 1

TOTAL 303

Table 2. Exposure incidents frompesticide drift reported in 1995.

Source: California Dept. of Pesticide Regulation, 1995 Pesticide Use Reporting database.

For communitiesnear heavy pesticideuse, the issue is notwhether the amountof poison in the air is

"safe," according tothe DPR, but theright not to bepoisoned at all.

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3ENVIRONMENTAL W ORKING G ROUP

Board (ARB), but instead areunder the purview of the De-partment of Pesticide Regulation

— an agency whose statedpolicy is that it is not necessary

to reduce or eliminate use of toxic pesticides, as long as thepublic’s exposure is “limited.”Responding to a 1997 analysis of state data by Californians forPesticide Reform (CPR), a state-

wide coalition including EWG,that found a dramatic increase inpesticide use, a DPR spokes-

woman said: “Increased sprayingdoes not equate to increased

risk if you control the exposure,and we control the exposure.”(Arax 1997)

In fact there is no evidencethat DPR adequately controlsexposure. The agency rarely even attempts to measure expo-sure through air testing. It allowspesticides to be applied in closeproximity to homes and schools,

and even closer proximity tofarm workers in adjacent fields.It virtually refuses to add pesti-cides to the list of chemicalsregulated as air pollution. It is acentral premise of this reportthat under the conditions thathave prevailed during the Wil-son Administration — the hugeand rapidly increasing volume of pesticides used in California;

growth patterns that are turningonce-isolated agricultural com-munities into densely populatedsuburbs; and DPR’s failure tomonitor the air for pesticide driftor regulate pesticides as air pol-lution — it is virtually impossibleto adequately control exposure.

DPR’s head-in-the-sand attitude,symptomatic of the agency’slongstanding accommodation of agricultural interests at the expenseof public health, has allowed pesti-

cide air pollution to effectively es-cape monitoring and needed con-trols. Pesticides enjoy this regula-tory holiday even though an EWGanalysis found that pesticide use isa larger source of one of the majorforms of toxic air pollution in Cali-fornia (reactive organic gases suchas benzene and other solvents)than petroleum refining and allother stationary industrial sources

of these smog-forming gases.Under a 1983 California law (AB

1807), chemicals designated astoxic air contaminants (TACs) by the state are subject to increasedmonitoring and mitigation efforts toprotect public health. DPR, whichhas authority over whether or notpesticides are designated as TACs,has shown a cavalier disrespect for

the entire listing process. Staterecords show that while the ARBhas placed 20 other air pollutantson the TAC list since 1983, DPR has taken similar action on just onepesticide — and then only afterthat pesticide had already beenbanned by the U.S. EnvironmentalProtection Agency. Worse, therecord also shows that while ARBrequires extensive monitoring for

TACs across the state, pesticide airpollution is virtually unmonitoredby DPR.

Each year, the ARB analyzesmore than 16,000 air samples forover 50 TACs, performing a total of more than 60,000 individual chemi-

DPR has listed onlyone pesticide as aToxic Air Contaminant— after it was bannedby the U.S. EPA.

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4 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

cal analyses annually. (ARB 1996)DPR routinely analyzes the air fornone. Since 1991, excluding a few special monitoring projects, DPR has monitored the air for pesti-

cides just 50 times in 14 locations.1

Out of more than 600 pesticidesregistered for use in California — approximately 150 of which havebeen identified by federal or stateagencies as TAC candidates — DPR has tested the air for fewerthan 30.

In many counties with heavy pesticide use, no air samples have

ever been taken or analyzed forpesticides by the DPR. From 1991to 1995, more than 4.2 millionseparate applications of pesticides

were reported in California, mak-ing DPR’s sampling record ap-proximately one test for every 84,000 applications in the state.Even in counties with heavy pesti-cide use, DPR’s record is not muchbetter. In the top three counties

for number of pesticide applica-tions each year — Fresno, Tulareand Monterey — DPR sampled theair for pesticides just 21 times from1991 through the present, an aver-age of one test for approximately every 69,000 pesticide applica-tions.

All of which leaves Californiansto fend for themselves. In this

light, perhaps the most disturbingfinding of the Community Monitor-ing Project is the lack of a publicright to know when and what pes-ticides will be applied to a givenfield, even when that field is lo-cated directly adjacent to homes,schools and businesses. In Califor-nia — home of the nation’s most

comprehensive program for pesti-cide data collection and reporting

— timely information about pesti-cide use in local communities isscarce and difficult to obtain due

to an indifferent or openly hostilebureaucracy and a political tradi-tion of accommodation of theagrichemical industry. These bar-riers inhibit citizens’ rights toknow about local pesticide useand the accompanying right toavoid exposure.

The bottom line: Even thoughpesticides are a significant source

of toxic air pollution, Californiansliving near sprayed fields have noguaranteed or uniform access tofind out what pesticides are beingapplied adjacent to their homes orthe schools where they send theirchildren. If you have time, persis-tence and know where to look, itis possible to learn which agricul-tural poisons were sprayed near

your home, school or business

three years ago — but a dauntingtask to find out what will besprayed tomorrow or next week.

Recommendations

Pesticide air pollution is, in atleast one respect, no differentthan industrial air pollution. It is aroutine and inevitable conse-quence of pesticide use, not

merely the accidental result of “agricultural chemicals” beingblown off-site. Agriculture is infact the largest industry in Califor-nia, and as a significant contribu-tor of toxic air emissions, shouldbe regulated as such. On DPR’s

watch, however, pesticide air pol-lution has largely escaped moni-

DPR monitors forpesticides in air onetime for every84,000 applications.

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5ENVIRONMENTAL W ORKING G ROUP

toring and regulation, placingmany Californians at risk of expo-sure to toxic chemicals known tohave serious health effects.

In the face of DPR’s persistentfailure to effectively address in-creasing pesticide use, wide-spread evidence of pesticide driftand growing community concernover exposure of the public topesticide air pollution, EWG andCPR urge the State of Californiato:

• Transfer authority for the

regulation of pesticides inair from DPR to the Califor-nia Air Resources Board.The ARB is a recognized

world leader in publichealth protections from airpollution. Without question,

ARB has greater expertise inair pollution monitoring, riskassessment and standard-setting than the Department

of Pesticide Regulation. Theagency responsible for regu-lating pesticides in airshould be committed to rec-ognizing, assessing and re-ducing risk, not to ignoringevidence of problems. Cali-fornians living in counties

with heavy pesticide air pol-lution should not be deniedthe protections that ARB’s

regulations extend to otherresidents of the state.

• Direct the ARB to conductroutine monitoring of pesti-cide applications to deter-mine the need for increasedbuffer zones and other mea-sures needed to protect the

public from pesticide activeingredients and reactive or-ganic gases from pesticideformulations drifting off-siteafter applications.

• Mandate 72-hour written no-tice to all homes, schools andbusinesses within 1,000 feetof a field before the applica-tion of any pesticide knownor suspected to cause cancer,brain or nerve damage, orreproductive disorders.

• Guarantee that agricultural

workers will be given thesame degree of protectionfrom potential pesiticide ex-posure as people who livenear application sites.

• Require growers, in their an-nual applications for use of restricted pesticides, to listless-toxic alternatives to thechemicals they plan to use.

• Provide all Californians witheasy, localized access to in-formation about recent andpending pesticide applica-tions in their communities.

• Order DPR to adopt a policy of reducing and eliminatingthe use of the most danger-ous pesticides, with an ag-

gressive plan and an acceler-ated timetable for implemen-tation. To facilitate this goal,the state must immediately and significantly increasefunding for research intonon-toxic alternatives tochemical pesticides.

Pesticide regulatorsmust reduce exposure,not ignore problems.

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6 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

Note

1 DPR contracts with ARB for almost all of its air monitoring. When this report refers to“DPR tests,” we mean routine tests for pesticides in air performed by ARB staff at DPR’srequest. Results of all general monitoring studies performed up to 1995 were publishedboth by DPR and in professional journals. In addition, DPR’s Environmental Monitoring

Branch conducts occasional special studies in response to accidents, citizen complainsand other urgent situations. Such a monitoring program is now underway in Lompoc,following years of residents’ complaints about spraying and after state health studiesfound elevated rates of cancer in the community. Over the last two decades, DPR (andits predecessor agency) has conducted about two dozen of these special studies — anaverage of about one per year. Results from these studies have never been publishedin a comprehensive or standardized format, therefore we did not include them in ouranalysis.

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7ENVIRONMENTALWORKING GROUP

The Community Pesticide

Monitoring Project

Chapter 1

EWG air monitoring for driftof multiple pesticides in South-ern, Central and Northern Cali-fornia shows that even as DPR fails to monitor, pesticides aredrifting off-site after applicationsinto residential neighborhoods,schoolyards and other publicspaces. The California Food and

Agricultural Code (Sec. 12972)states: “The use of any pesticideby any person shall be in such amanner as to prevent substantialdrift to nontarget areas.” How-ever, the definition of “substan-tial” is ambiguous, is subject to

varying interpretation by county agricultural commissioners, andhas not been tested in court.

EWG began its Community Monitoring Project in 1996 todocument pesticide drift in theso-called agricultural/urban in-terface — suburban communities

where residential development isoccurring in close proximity tolarge-scale farming. Althoughthis phenomenon is foundthroughout California and is onthe rise in the booming Central

Valley, it is currently most pro-nounced in the coastal strip, asthe outer suburbs of the Los An-geles Basin and the San Fran-cisco Bay Area have expandedinto areas where the intensity of

pesticide use is the highest in thestate, and among the highest inthe nation.

The Monitoring Project fo-cused on three coastal areas

where citizens have organized tofight illegal pesticide drift:

Ventura County in Southern Cali-fornia, Monterey and Santa Cruzcounties on the Central Coast andSonoma County in Northern Cali-fornia. In 1995, Santa CruzCounty growers used 75.1pounds of pesticides per har-

vested acre, most in the state. Ventura ranked fourth, with 51.8pounds per acre; Sonoma fifth

with 48.7 pounds per acre; andMonterey seventh at 39.6 poundsper acre. (In Fresno County, pe-rennially the top-producing agri-cultural county in the UnitedStates, 1995 use per acre was39.3 pounds.) (CPR 1997) Be-tween 1991 and 1995, as thepopulation of these four coastalcounties increased by an esti-mated 3.9 percent, total reportedpesticide use increased by 52percent. (DOF 1998)

Between June 1996 and Sep-tember 1998, EWG coordinatedair monitoring at 15 individuallocations across 7 counties to as-sess multiple pesticide drift.

Relative to population,the rate of pesticideuse in coastalCalifornia is amongthe highest in thenation.

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8 WHAT YOU DON’T KNOW COULD HURT YOU: PESTICIDES IN CALIFORNIA’S AIR

Monitoring was conducted inContra Costa, Monterey, SantaBarbara, Santa Cruz, Sonoma, SanMateo and Ventura counties. Sixdifferent locations in Sonoma

County, four in Monterey, andone in each in the other counties were monitored. Samples weretaken near the edge of treatedfields, usually in residentialneighborhoods, typically in frontor back yards. During the sameperiod, EWG monitored specifi-cally for methyl bromide, an es-pecially toxic and volatile fumi-gant gas, at seven other locations

in Ventura, San Luis Obispo,Monterey and Santa Cruz coun-ties, including two elementary schools.

A total of 55 air samples werecollected for analysis of multiplepesticides, and 39 other samples

were taken for analysis of methylbromide. Of the 55 multiple pes-ticide samples, 29 samples, or 53

percent, tested positive for drift-ing pesticides. (Table 3.) Of the39 methyl bromide samples, 31samples, or 80 percent, detectedmethyl bromide. Measurable drift

was detected at 13 of the 15 mul-tiple pesticide sampling locations,and at all but one of the methylbromide sampling locations. (Seep. 10 for details of methyl bro-mide monitoring results.)

Multiple Pesticide MonitoringResults: Monterey-Santa Cruz

EWG monitored pesticide ap-plications in five locations inMonterey and Santa Cruz coun-ties. Of 18 samples taken, 10

detected drifting pesticides. Mostfrequently detected waspermethrin, found at five loca-tions in Monterey County andone in Santa Cruz County. The

highest detection of permethrin was 4.3 parts per billion (ppb) inMonterey County; the averagelevel of the six detections was1.4 ppb. Other pesticides de-tected in the two counties in-cluded chlorpyrifos, carbaryl,methomyl and cyfluthrin. Thehighest level of any pesticidedetected was cyfluthrin, at 4.5ppb in Monterey County.

The Department of PesticideRegulation has only tested fortwo pesticides in Monterey County since 1991:oxydemeton-methyl andpermethrin. Neither of thesepesticides are on the TAC list.

Sonoma County

Six locations in SonomaCounty were monitored withPUF tubes — filter-lined glasstubes attached to air pumps.(See Methodology.) Of 26samples taken, 15 detected drift-ing pesticides. Most frequently detected was sulfur, found atnine locations. Sulfur was de-tected at levels of up to 10.5 ppb

with an average of 2.8 ppb.

Other pesticides detected inSonoma sampling were carbaryl(5 detections) and phosmet (1detection). The average of thecarbaryl detections was 0.25ppb, with the highest detection0.65 ppb. Phosmet was detectedat 0.19 ppb.

Drifting pesticideswere detected in 19 of 22 communitiestested.

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9ENVIRONMENTALWORKING GROUP

Seven paper-tray samples werealso taken near Sonoma vineyards,and four tested positive for sulfur.Paper sampling trays were placedoutdoors to passively collect pesti-cide fallout from nearby fields and

vineyards. This test is useful forcollecting data on potential expo-sure from pesticides that mightaccumulate on playground equip-ment, picnic tables and other out-door surfaces. Use of sulfur inCalifornia vineyards was higherthan normal in 1998, because of heavy rains triggered by El Nino.

DPR has never tested for any pesticides in the air in SonomaCounty.

San Mateo County

One location in San MateoCounty was monitored. Of threesamples taken in May and June,1997, one detected drifting pesti-cides. Iprodione, a fungicide,

was found at 1 ppb near a crop of flowers.

DPR has never tested for any pesticides in the air in San MateoCounty.

Ventura County

Monitoring was conducted atone location in Ventura County.Of five air samples taken, two de-tected pesticides. Chlorpyrifos wasdetected at a level of 0.22 ppband myclobutanil was detected at0.16 ppb.

DPR has only tested for twopesticides since 1991, chloro-thalonil and siamazine, in the airin Ventura County. Neither of thepesticides are on the TAC list. In

Ventura County, ARB tested for 61different TACs more than 12,000times between 1991 and 1995.

Santa Barbara County

The one sample that was takenin Santa Barbara County in August1996 contained cyfluthrin, an in-secticide, at 2.5 ppb..

DPR has never tested for any pesticide in the air in Santa Bar-bara County. ARB, on the otherhand, tested the air in Santa Bar-bara County for 61 different TACSnearly 13,000 times between 1991and 1995.

CountyNumber of Locations Dates

TotalNumber of Air Samples

Number of PesticidesDetected

PercentPositive Maximum Individual Residue Detected

Contra Costa 1 8-9/96 2 0 0%Monterey 4 8/96 & 5-7/98 13 8 62% cyfluthrin near lettuce field - 4.3 ppbSan Mateo 1 5-6/97 3 1 33% iprodione near flower farm - 1 ppbSanta Barbara 1 8/96 1 1 100% cyfluthrin - 2.5 ppbSanta Cruz 1 5-7/98 5 3 60% permethrin near brussels sprouts field - 0.1 ppbSonoma 6 5-8/98 26 16 62% sulfur near grape vineyard - 10.5 ppbVentura 1 3-5/97 5 2 40% chlorpyrifos near strawberry field - 0.2 ppb

Table 3. EWG discovered nine different pesticides in the air in agriculture communities.

Source: Environmental Working Group

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10 WHAT YOU DON’T KNOW COULD HURT YOU: PESTICIDES IN CALIFORNIA’S AIR

County Town DatesNumber of

SamplesPercentPositive Testing Method

Mean Detection(ppb)

MaximumDetection (ppb)

Maximum 24Hour Average

(ppb)

Monterey Castroville 8-9/97 9 66% Carbon FiltersMonterey Castroville 8/96 continuous NA FTIR 204 665 102*Monterey Castroville 8-9/97 12 66% SUMMA Canisters 202 490 370San Luis Obispo Oceano 10/97 1 100% SUMMA Canisters 230 230 NASanta Cruz Watsonville 8/97 2 0% SUMMA Canisters - - -Santa Cruz Watsonville 10/97 4 100% SUMMA Canisters 1,350 3,700 2,115Santa Cruz Watsonville 11/96 4 100% SUMMA Canisters 162 190 170Santa Cruz Watsonville 11/96 2 100% Carbon Filters 6 6 6Ventura Camarillo 8/97 3 100% SUMMA Canisters 64 68 68

Ventura Ventura 6/96 continuous NA FTIR 294 1,900 147*

EWG’s Air Monitoring for Methyl Bromide Drift

Table 4. Over sixty percent of the locations tested positive for methyl bromide.

From June 1996 to August 1997, EWG conducted orfacilitated air sampling for methyl bromide drift inVentura, San Luis Obispo, Monterey and Santa Cruzcounties. (Previously published detailed reports fromthese sampling projects are available on-line atwww.ewg.org.)

Methyl bromide is a fumigant classified by the U.S.EPA as a Category I acute toxin — a designationreserved for the most toxic substances — and isknown to cause birth defects and nerve damage. It isalso a potent destroyer of the Earth’s protectiveozone layer. California is the world’s largest user of methyl bromide, with 17.6 million pounds applied in1995, mostly to Central Coast strawberry fields.Because the fumigant is injected into the soil as avolatile gas, methyl bromide routinely drifts off treated fields into adjacent neighborhoods andschool grounds.

Methyl bromide was first targeted for phaseout bythe California Birth Defects Prevention Act of 1984,but pesticide interests have successfully lobbied inSacramento and Washington for repeated extensions

of the deadline. Currently, under the Clean AirAct and an international treaty, the MontrealProtocol on Ozone Depleting Substances, methylbromide will be banned in the United States in2005.

Of 37 samples taken by EWG or local residents atseven locations — three suburban subdivisions,two elementary schools and two mobile homeparks, all near strawberry fields — 28 detectedmethyl bromide in the air. In five of the locations,peak levels of methyl bromide detected exceededDPR’s safety guidelines of 210 parts per billion.(Table 4.) (DPR insists that the only validmeasurements are 24-hour averages — scantreassurance to someone exposed to a toxic nervegas for 6 or 12 hours.) In October 1997, atSalsipuedes Elementary School in Watsonville,the 24-hour average detection was 2,115 ppb —more than 10 times the guideline.

After widespread news coverage of EWG’sfindings and a series of permit challenges by localresidents, DPR was forced to expand the

*12-hour average.Source: Environmental Working Group

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11ENVIRONMENTALWORKING GROUP

minimum no-spray buffer zone between methylbromide applications and adjacent homes or schoolsfrom 30 feet to 100 feet or more, depending onlocation. However, EWG monitoring has detectedmethyl bromide up to 1,300 feet from the

application site, and a former state Air ResourcesBoard expert has said that buffer zones should be atleast half a mile throughout the state. (Sears 1997) In1998, a bill to ban the use of methyl bromide within1,000 feet of homes or schools was blocked in theCalifornia Assembly by farm-district legislators.

In October 1998, with no public notice other thanan advisory to county agriculture commissioners,DPR said residential buffer zones for certainapplications of methyl bromide to tracts of 10 acresor less could be reduced to 50 feet. DPR said it wasalso increasing the buffer zones for some methods of

applying methyl bromide, but failed to note that themajority of applications in the counties of heaviestuse are to tracts of 10 acres or less. At the same time,DPR set the minimum buffer zone between methylbromide applications and workers in adjacent fieldsback to just 30 feet, arguing that because workers

were exposed for 12 hours at a time whereasneighboring residents might be exposed round-the-clock, workers did not need as much protectionfrom exposure.

DPR cited “new science” derived from “extensive”air monitoring as justification for the reduction. Butas of the end of 1998, results had been made publicfor only two of the monitoring tests, both from SanLuis Obispo County. One test found methylbromide drifting beyond the 100-foot buffer zone,but in concentrations below the state guidelines.The other test found levels exceeding stateguidelines drifting into a senior citizen’s mobilehome park, prompting county officials to extend thebuffer zone for similar applications to 450 feet.(The trailer park was also where, in October 1997,air monitoring by EWG found 230 ppb of methyl

bromide more than 350 feet from the field.)Questioned about DPR’s basis for shrinking thebuffer zones, county ag commissionersacknowledged that the agency had not providedthem with its test results either. (Alvarez 1998)

Contra Costa County

Two samples were taken inContra Costa County between

August and September, 1996;however, neither of the samplestested positive for pesticides.

DPR has only tested for onepesticide in Contra Costa’s ambi-ent air: a single test for metamsodium in March 1994. The ARB,on the other hand, tested inContra Costa for 61 toxic aircontaminants over 15,400 timesbetween 1991 and 1995.

About the pesticides

Each of the three majorclasses of insecticides in use

were detected during the Moni-

toring Project. Organophosphates were detected in Ventura, SantaCruz and Sonoma; carbamates

were detected in both Monterey and Sonoma; and pyrethroids

were detected in Monterey, SantaCruz and Santa Barbara. In addi-tion, three fungicides were de-tected: myclobutanil in VenturaCounty, iprodione in San MateoCounty and sulfur in SonomaCounty.

Organophosphates

Organophosphates (OPs) are aclass of neurotoxic insect poisonsfor which the observable symp-toms of exposure include nausea,

vomiting, blurred vision, convul-sions and irregular heartbeat. Ex-posure to OPs can produce long-

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12 WHAT YOU DON’T KNOW COULD HURT YOU: PESTICIDES IN CALIFORNIA’S AIR

term damage to the nervous sys-tem, even in the absence of ob-servable signs of toxicity. Animalstudies, as well as evidence fromhuman poisonings, show that

fetuses, infants and children areoften more susceptible to OPtoxicity than adults. Because or-ganophosphates are widely usedon many different food crops,they are the first group of chemi-cals to be regulated under theFood Quality Protection Act, alandmark 1996 federal law thatstrengthened the protections forchildren from pesticides.

• Chlorpyrifos, an organo-phosphate detected in oursampling, is the most

widely used insecticide inthe U.S. and in California,

where use exceeded 3.5million pounds in 1995. In1996, the ARB monitoredfor chlorpyrifos drift fromorange groves in Tulare

County, and detected thepesticide in 74 percent of the air samples taken nearthe groves. ARB alsosampled the air in urbanareas well away from thegroves, and found the pesti-cide in 24 percent of samples.

• Phosmet is an organophos-

phate pesticide and a pos-sible carcinogen. Phosmetis mostly used on fruit treesand vines and in some dogcollars. More than 267,000pounds were used in Cali-fornia in 1995.

Carbamates

Carbamates are another classof neurotoxic insecticides.Though they are more acutely

toxic than organophophates,they can be flushed from thehuman body more quickly, mak-ing them less lethal. Knownhealth effects of carbamate ex-posure include headache, dizzi-ness and nausea at low levelexposure and numbness, tin-gling burning sensations, sei-zures, coma and death at highexposures.

• Carbaryl is a widely usedcarbamate pesticide that isused on agricultural crops,forest land, and home gar-dens. Carbaryl is classifiedas a possible human car-cinogen and suspected re-productive toxicant by theEPA and is a suspectedendocrine toxicant. About

1.5 million pounds wereused in California in 1995.Carbaryl drift has neverbeen monitored by DPR or

ARB.

Pyrethroids

Pyrethroids are synthetic for-mulations of chemicals originally derived from natural insecticides

found in flowers that have thecapability to kill insects by dis-rupting their nervous systems.

While studies of their health ef-fects are incomplete, the sus-pected effects include toxicity of the endocrine system.

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13ENVIRONMENTALWORKING GROUP

• Permethrin is a pyrethroidinsecticide that is classifiedas a possible carcinogen by the EPA and is a suspectedendocrine toxicant. Ap-

proximately 420,000pounds were used on a variety of fruit, vegetable,flower, and nut crops inCalifornia in 1995.Permethrin drift has beenmonitored by the state inMonterey and Butte coun-ties, but as of late 1998 theresults had not been madepublic.

• Cyfluthrin is a pyrethroidinsecticide that is used onnumerous types of fruits,

vegetables, and nuts. Al-most 44,000 pounds wereused in California in 1995.Cyfluthrin drift has neverbeen monitored by DPR or

ARB.

FungicidesFungicides are pesticides that

are applied to structures and tocrops before and after harvest toprevent or halt the growth of molds and fungi. Many fungi-cides have been found to be po-tent carcinogens and some, likehexachlorobenze and pentachlo-rophenol, are being phased out

because of their toxic effects andpersistence in the environment.

• Sulfur is one of the mostheavily used fungicides in

California, with nearly 70million pounds applied in1995 alone. As a naturally occurring mineral, it is ap-proved for use in certified

organic farming, and usedsparingly is a less-toxic al-ternative to pyrethroids. Un-fortunately, because of its

widespread use and the vol-ume of material used — typically, hundreds of pounds per acre — sulfur isthe chemical most com-monly implicated infarmworker pesticide health

complaints, primarily respi-ratory or eye irritation. Sul-fur drift has never beenmonitored by the ARB orDPR.

• Iprodione is a fungicide thatis used on both pre-harvestand post-harvest fruits, veg-etables, and flowers. Morethan 588,000 pounds of

iprodione were used inCalifornia in 1995. It is clas-sified as a known carcino-gen by the State of Califor-nia.

• Myclobutanil is a fungicideused on grapes and othercrops. More than 100,000pounds of myclobutanil

were applied in California

in 1995. The chemical hasbeen shown to be associ-ated with birth defects andtesticular atrophy in labora-tory animals.

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14 WHAT YOU DON’T KNOW COULD HURT YOU: PESTICIDES IN CALIFORNIA’S AIR

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15ENVIRONMENTAL W ORKING G ROUP

Pesticides Are Pollution, Too

Chapter 2

When pesticides are appliedto crops, some portion of thepoison (for which theagrichemical industry’s euphe-mism is “active ingredient”) in-evitably becomes airborne.

Whether the pesticide is appliedas a gas, liquid, spray or dust,blowing wind or drifting fog dis-perses the vapors, droplets orparticles, and because of California’s highly localized mi-croclimates, the amount of drift

varies greatly for a given day ina given location. In 1995, theUnited States Geological Survey released a report that docu-mented drift of every major classof pesticides and the subsequentdeposition of these chemicals inrain and fog. (Majewski 1995)Most of the air and fog samplescollected in California testedpositive for a number of pesti-cides, including highly toxic or-ganophosphates like chlorpyrifosand methyl parathion.

In addition, for hours andeven days after application, pes-ticide formulations evaporatefrom the soil and vegetation,emitting more chemicals into theair and possibly leading to con-tinued exposure for farmworkersand nearby residents. Theseevaporating chemicals can in-

clude the active ingredients,chemical products of the break-down of those ingredients andchemical additives — so-called“inert ingredients” — in the pesti-cide formula. Collectively, theseevaporating chemicals are knowneither as volatile organic chemi-cals (VOCs), or as they are offi-cially classified in California, re-active organic gases (ROGs). Amore accurate term for this com-bination of drifting pesticides andpost-application emissions of ac-tive ingredients and ROGs wouldbe pesticide air pollution.

The fact that airborne pesti-cides and pesticide ROGs are airpollution may seem self-evident,but apparently not to the State of California, and in particular, notto the Department of PesticideRegulation. Under a 1983 statelaw, AB 1807, if a chemical emit-ted into the air is officially deter-mined to be a toxic air contami-nant (TAC), it is subject to in-creased monitoring, mitigationand enforcement efforts designedto protect public health. All airpollution from factories, automo-biles and all other non-agricul-tural sources is regulated underhealth-based standards by the

ARB, which has set some of thetoughest and most protective air

Pesticides are the onlyform of airbornecontaminants notregulated by state airpollution experts.

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16 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

pollution regulations in the na-tion, and by late 1998, hadplaced 20 contaminants on theTAC list — most recently, particu-late matter in diesel exhaust.

Pesticides in the air, however,are overseen by DPR. Comparedto ARB, DPR has responded le-thargically to the law’s mandateto protect public health: In itshistory as an agency, DPR hasmoved to list only one pesticideas a TAC, and only after the pes-ticide was banned by the U.S.Environmental Protection

Agency. (At an October 1998meeting of the state’s ScientificReview Panel on Toxic Air Con-taminants, DPR said it would sub-mit TAC evaluations to the Panelfor an additional 11 chemicals,including methyl bromide, by theend of 1999.)

But even when DPR does getaround to placing a pesticide on

the TAC list, it may not meanmuch. Under AB 1807, U.S. EPAlisting of a substance as a hazard-ous air pollutant (HAP) under theClean Air Act Amendments of 1990 triggers an automatic listingas a TAC in California. But DPR maintains that the federal listingmandates no additional monitor-ing or regulatory action (DPR 1997b). From 1991 through 1995,

there were more than 45,000 ap-plications in California of pesti-cides listed as HAPs by the U.S.EPA. DPR tested the air in Cali-fornia for these pesticides just 7times from 1991 through 1997.

ARB, on the other hand, moni-tored for HAPs across Californiaover 178,000 times between 1991

and 1995. During that sameperiod, ARB analyzed morethan 80,000 air samples forTACs. (Table 5.)

DPR has undertaken nocomprehensive, long-term orstatewide air monitoring pro-gram to quantify the extent orrisks of pesticide air pollution.Out of more than 600 pesticideactive ingredients currently reg-istered for use in California — approximately 150 of whichhave been identified by federalor state agencies as candidates

for the TAC list — the state hastested the air for fewer than 30. And even this testing can notbe characterized as routinemonitoring. Instead it is typi-cally designed to monitor thedrift from one application, orfor one pesticide over a few days. Most of the studies havebeen conducted in the Central

Valley, where the agricultural

industry’s influence is domi-nant, largely ignoring the grow-ing public health concerns overheavy pesticide use in coastalcounties — the so-called subur-ban-ag interface. Judging fromthe department’s 1997 methylbromide monitoring inCastroville, where extraordinary precautions were taken to re-duce the possibility of drift, it is

also questionable whetherDPR’s special tests adequately reproduce real-world applica-tions.

Even in the counties of heaviest pesticide use, DPR monitors only a minute fractionof applications. In the top three

DPR has no statewideair monitoringprogram to quantifythe extent or risks of pesticide air pollution.

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17ENVIRONMENTAL W ORKING G ROUP

YearNumber of Applications

(1991-1995)Pounds

(1991-1995)

DPR Testingfor HazardousAir Pollutants(1991-

Present)

ARB Testingfor HazardousAir Pollutants(1991-1995)

1991 76,348 24,366,363 0 35,7221992 82,674 24,530,058 1 34,7821993 88,934 21,033,858 3 39,0801994 100,010 23,590,287 0 34,5081995 109,948 28,504,673 3 34,398

Table 5. From 1991 through 1995, DPR tested the air once for every65,000 applications of pesticides listed as Hazardous Air Pollutants*.

*Toxics (including pesticides) designated by the U.S. EPA as Hazardous Air Pollutants are automatically listed as Toxic Air Contaminants (TACs) under California law.

Source: Kollman 1996, DPR 1996, DPR 1997, Kelley 1996, Baker 1996, Baker 1998 & ARB 1996.

counties for number of pesti-cide applications each year — Fresno, Tulare, and Monterey

— DPR sampled the air for pes-ticides just 22 times from 1991through the present, an average

of one test for approximately every 66,000 applications. Be-tween 5 million and 25 millionpounds of pesticide active in-gredients are applied in thesethree counties each year; duringthe peak of the spraying sea-son, as many as 1,250 separateapplications per day are re-corded in Fresno County.(Table 6.)

Furthermore, in 11 counties with over 10,000 pesticide ap-plications each year, DPR hasnot tested the air for pesticidessince 1991. (Table 7.) Between1991 and 1995, there weremore than 1.1 million applica-tions of hundreds of different

pesticides in these counties; DPR monitored not one. It is not un-usual for more than 100 differentpesticides to be applied on thesame day in just one of these 11counties during peak spray sea-

son, contaminating the air with amix of poisons that poses an un-known risk to residents. By con-trast, in these same 11 counties,

ARB monitored the air nearly 40,000 times for toxic air contami-nants from 1991 to 1995.

Estimates of pesticide drift

An active ingredient is the part

of a pesticide product that killsthe target pest. It is the poison inthe can of Raid, as opposed to allthe other so-called inert ingredi-ents in the formulated product. If

you know the physical character-istics of the pesticide, the methodof application, the crop density and height, and weather factors

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18 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

County

Number of Applications(1991-1995)

Pounds of Active

Ingredient(1991-1995)

Number of TestsCommissionedby DPR (1991-

Present)

PesticideApplicationsper DPR Test

Fresno 601,060 124,163,515 13 46,235Monterey 429,601 28,441,882 3 143,200Tulare 415,573 48,367,349 6 69,262Kern 262,307 65,821,723 10 26,231San Joaquin 175,706 45,721,984 1 175,706Santa Barbara 169,115 11,574,481 0 NAMerced 159,532 26,137,842 1 159,532San Diego 147,513 4,027,692 0 NARiverside 147,100 14,787,067 0 NAImperial 146,486 26,355,312 7 20,927

State Total 4,204,798 619,627,380 50 84,096

Table 6. Even in the counties with the heaviest pesticide use, DPR monitorsthe air less than once for every 84,000 pesticide applications.

Source: DPR 1997, Baker 1996, Baker 1998 & Kollman 1996.

including temperature, humidity and wind, you can estimate, on acase-by-case basis, how much of a given pesticide active ingredi-ent might drift from the applica-

tion site. Applying that formula tothe entire state is difficult, but anumber of recent studies providea basis for an estimate.

The best estimates of drift of pesticide active ingredients havebeen done by the U.S. Environ-mental Protection Agency (EPA)and Environment Canada, thatnation’s federal environmental

agency. A 1995 EPA computermodeling project found that forjust 11 of the most commonly used pesticides, nationwide over35 million pounds of active ingre-dients drift or volitalize off-siteeach year. A more recent Cana-dian study estimated total North

American drift of active ingredi-

ents from 10 commonly usedpesticides at nearly 28 millionpounds a year. (Scholtz 1997)

The EPA study determined

that an average of 20 to 45 per-cent of the active ingredients of a given pesticide could driftfrom the field, depending on the

volatility of the compound andother factors. (Benjey 1995) Thestudy’s author now believes av-erage drift rates are probably lower, on the order of 5 to 20percent of the pesticide applied.(Benjey 1998)

According to DPR studies, anumber of pesticides used inCalifornia, including some of themost toxic, have much higherdrift potential of 80 to 100 per-cent. Finally, in estimating thepotential for drift and post-appli-cation emissions in California,keep in mind the fact that one-

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19ENVIRONMENTAL W ORKING G ROUP

Table 7. DPR does no monitoring at all in many counties wherepesticide exposure potential is high.

Source: DPR 1997, Baker 1996, Baker 1998 & Kollman 1996.

County

Number of Applications(1991-1995)

Pounds of ActiveIngredient(1991-1995)

Number of TestsCommissionedby DPR (1991-

Present)

San Diego 147,513 4,027,692 0Riverside 147,100 14,787,067 0Stanislaus 145,669 19,321,048 0Madera 128,176 37,507,347 0San Luis Obispo 105,739 6,103,858 0Sonoma 72,958 12,596,473 0Santa Cruz 67,140 5,583,000 0Yolo 64,290 12,011,217 0Sutter 57,273 11,000,634 0Napa 52,777 11,661,550 0

fourth of all pesticides used inthe U.S. are applied in Califor-nia, and that the rate of pesticideuse per capita in California — eight pounds per person per

year — is more double the na-tional rate. (CPR 1998)

Even applying the lowest driftpotential rate of 5 percent, thetotals are substantial: Of the 212million pounds of pesticide ac-tive ingredients applied in Cali-fornia in 1995, at least 11 millionpounds drifted from the field.

Applying a drift potential rate of

20 percent, the estimate rises to44 million pounds.

Reactive Organic Gases

But offsite drift of toxic pesti-cide active ingredients is only the tip of the iceberg. It does notinclude reactive organic gases

that evaporate in huge quanti-ties after the pesticide is ap-plied. Reactive organic gasesare volatile organic chemicalsthat readily evaporate into air

from other substances. When you smell gasoline, you aresmelling airborne ROGs. Thechemical classification ROGsincludes hundreds of chemicalcompounds, including solventslike benzene, toluene, naphthaand zylene. Some pesticides,such as chlorpyrifos and methylbromide, are so volatile they areconsidered ROGs on their own.

Often these ROG solvents areadded to pesticide formulationsto dissolve the active ingredientand keep it in solution for evendistribution on the crop. Some-times solvents are added to helpthe pesticide penetrate the in-sect or plant targeted. In suchcases these added chemicals are

Between 11 millionand 44 million poundsof pesticides drift off California farm fieldseach year, along with

millions of pounds of toxic chemical gasesthat evaporate into theair after the pesticidesare applied.

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20 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

Table 8. Pesticide Reactive Organic Gases (ROG) Emissions in California, 1995.

Source: Environmental Working Group. Compiled from California Air Resources Board data.

Agricultural

Total PesticideReactive

Methyl Bromide Non-Methyl Bromide Structural Organic Gases (ROG)

Rank County (pounds) (pounds) (pounds) Emissions (pounds)1 Kern 1,672,200 14,289,400 26,400 15,988,000 2 Fresno 372,800 12,742,200 162,000 13,277,000 3 Imperial 273,800 8,064,800 13,200 8,351,800 4 Kings 58,400 6,637,600 27,000 6,723,000 5 Monterey 4,154,200 2,319,400 32,200 6,505,800 6 Tulare 752,800 5,550,000 61,400 6,364,200 7 San Joaquin 1,108,400 2,695,600 56,600 3,860,600 8 Merced 785,800 2,053,000 271,400 3,110,200 9 Santa Barbara 794,200 1,993,200 53,000 2,840,400 10 Ventura 1,334,600 1,377,800 58,200 2,770,600 11 Riverside 667,800 1,627,200 306,200 2,601,200 12 Stanislaus 783,200 1,678,400 56,600 2,518,200 13 Yolo 24,000 2,321,200 15,200 2,360,400 14 Madera 33,400 1,704,000 19,400 1,756,800 15 Santa Cruz 1,170,400 400,800 8,800 1,580,000 16 Sutter 329,000 1,203,200 4,600 1,536,800 17 Los Angeles 54,000 366,400 960,000 1,380,400 18 Colusa 17,200 1,360,000 2,200 1,379,400 19 Orange 513,000 474,000 300,600 1,287,600 20 Butte 216,800 1,055,800 11,200 1,283,800 21 San Diego 472,000 374,800 294,000 1,140,800 22 Sonoma 471,200 525,600 25,600 1,022,400 23 Glenn 26,200 922,800 3,000 952,000 24 San Luis Obispo 225,200 669,400 12,800 907,400 25 Sacramento 25,800 741,400 99,800 867,000 26 Solano 78,400 720,600 25,400 824,400 27 Yuba 170,400 484,600 200 655,200 28 Napa 318,600 327,800 6,000 652,400 29 Santa Clara 78,200 300,800 161,000 540,000 30 San Benito 192,000 170,400 4,200 366,600 31 San Bernardino 38,000 219,200 100,400 357,600 32 Mendocino 49,000 276,800 2,200 328,000

33 Tehama 84,000 214,400 1,600 300,000 34 Contra Costa 3,400 226,200 70,200 299,800 35 Shasta 240,600 45,000 6,200 291,800 36 Alameda 80,200 127,800 62,400 270,400 37 Del Norte 40,800 219,800 200 260,800 38 Siskiyou 70,200 167,600 400 238,200 39 Placer 21,400 148,000 62,800 232,200 40 San Mateo 24,400 133,800 35,600 193,800 41 Lake - 140,600 37,600 178,200 42 Lassen 112,000 9,000 200 121,200 43 Modoc - 71,200 - 71,200 44 Calaveras - 66,000 3,200 69,200 45 Amador 31,400 19,600 1,200 52,200 46 Humboldt 19,400 26,400 5,800 51,600 47 Marin - 13,000 20,400 33,400 48 Mono - 30,600 - 30,600 49 El Dorado - 15,800 12,600 28,400

50 San Francisco - 5,400 22,800 28,200 51 Nevada - 15,000 5,600 20,600 52 Tuolumne - 12,200 4,400 16,600 53 Mariposa - 7,000 1,800 8,800 54 Plumas - 2,200 4,800 7,000 55 Sierra - 2,600 - 2,600 56 Inyo - 600 1,400 2,000 57 Trinity - 200 - 200 58 Alpine - - - -

Statewide Total 17,988,800 77,368,200 3,542,000 98,899,000

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21ENVIRONMENTAL W ORKING G ROUP

called “inert ingredients,” butthey are hardly biologically in-ert: Many ROGs are potent poi-sons that can cause cancer, birthdefects, nervous system disrup-

tion, kidney disease and heartdamage, as well as the flu-likesymptoms associated with acutepoisoning.

Because they contribute tothe formation of smog, emis-sions of ROGs are regulatedunder the U.S. Clean Air Act. Tocomply with the law, DPR hasestablished a ROG emissions

potential factor (EF) for every pesticide registered for use inCalifornia. This rating gives thepercentage of the chemical thateither is or potentially will be-come airborne ROGs after thepesticide is applied. The EF

varies greatly according to theexact formulation of the pesti-cide, even for products with thesame active ingredient. For ex-

ample, according to DPR,chlorpyrifos used for termitetreatment has an emissions po-tential of around 25 percent

while some formulations usedon crops have EFs of near 100percent. For many fumigantgases, such as methyl bromide,Telone and Vapam, DPR esti-mates the emissions potential at97 or 100 percent. Of 246 cur-

rently registered pesticide prod-ucts evaluated by DPR, almostone in 4 had emissions potentialof at least 50 percent. (DPR 1998b)

Using methodology estab-lished by ARB and DPR’s 1995pesticide use figures, EWG esti-

mated that some 98.9 millionpounds of ROGs are emitted as asresult of pesticide applications inCalifornia each year. (Table 8.)This figure was calculated as the

product of the number of poundsapplied of each pesticide andDPR’s estimate of that pesticide’semissions potential. Since somepesticides are themselves ROGs,there is some overlap betweenthis figure and the estimate of 11million to 44 million pounds of drift. However, it is a safe andconservative estimate to say thatapproximately 100 million pounds

of pesticide active ingredients andROGs drift or volitalize into theair each year as a result of pesti-cide use in California. This esti-mate is nearly four times the totalstatewide ROG emissions frompetroleum refining (25.5 millionpounds annually) and more thandouble the emissions from allother stationary industrial sourcesbesides petroleum refining (46

million pounds).

Many agricultural regions of California are out of compliance

with federal Clean Air Act stan-dards — that is, levels of smogexceed the U.S. EPA’s health stan-dards. According to ARB esti-mates, agricultural chemicals aresignificant contributors to some of these regions’ “non-attainment”

status. (Baker 1998) (ARB’s ROGestimates for these non-attainmentregions do not separate pesticidesand fertilizers.)

In the San Joaquin Valley (Fresno, Kern, Kings, Madera,Merced, San Joaquin andStanislaus counties), pesticides

Pesticides emit fourtimes as much of onekind of air pollutionthan all the oil and gasrefineries in

California.

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22 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

and fertilizers emit an estimated34 million pounds of ROGs a

year, more than 13 percent of theregion’s total. In Ventura County,estimated pesticide and fertilizer

ROGs are about 2.1 millionpounds a year, or 5.6 percent of the total. In the Southeast Desertarea (Riverside-San Bernardino),about 1.2 million pounds of ROGs were emitted from pesti-cides and fertilizers, or 3.4 per-cent of the total. In each of those areas, the main ROG culpritis methyl bromide, which has apotential emissions rate of as

much as 100 percent, dependingon the brand used.

The other agricultural area where ROG emissions exceedstandards of the Clean Air Act isthe Sacramento region, wherepesticide and fertilizer ROGs total2.7 million pounds annually, 3percent of the total. In the Sacra-mento area, the biggest source of

pesticide ROGs is chlorpyrifos, aneurotoxic organophosphate in-secticide.

Regulations to control ROGemissions must be part of eachstate’s implementation plan (SIP)of the Clean Air Act. In 1994, be-cause California had failed to

complete its SIP, the EPA pro-posed a plan that, according toDPR, would have required upto a 45 percent reduction inpesticidal ROGs and banned the

use of some pesticides high inROGs. DPR said the federalplan “would have had severeeconomic impacts,” and pro-posed “more reasonable alter-natives,” accepted by EPA in1996. The state plan now callsfor a 20 percent reduction by 2005. (DPR 1998b)

However, the plan’s baseline

was developed not by air test-ing or computer modeling of emissions, but by surveyinggrowers who estimated theemissions rate of pesticides they used. Further, the plan allowsfor reductions to be achievednot primarily through reducingpesticide use, but by changingthe chemical formulation of thepesticide or using a DPR-devel-

oped protocol for recalculatingthe emissions factors that theagency says will “virtually al-

ways” yield a lower EF. Thismay or may not result in a realreduction in ROGs, but is con-sistent with DPR’s insistencethat the increasing volume of pesticide use is not a problem.

In the San JoaquinValley and otherareas, pesticides are asignificant source of smog-forming

chemicals.

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23ENVIRONMENTAL W ORKING G ROUP

All in a Day’s Spray

Chapter 3

Even in counties with heavy pesticide use and high potentialfor human exposure, DPR virtu-ally never monitors the air forpesticides. To estimate the po-tential for human exposure topesticides and toxic ROGs frompesticide formulations, EWG cal-culated pesticide applicationsper day for each county, usingthe most recent data availablefrom the California pesticide usereporting (PUR) system. PUR data were also combined withproduct-specific emissions fac-tors (EFs) from DPR, to produceestimates of pesticide ROG airpollution by county. Theseanalyses show that on many days during peak pesticide ap-plication months, Californians incounties where pesticide use isheavy are exposed to tens of thousands of pounds of toxicROGs from pesticide use daily,as well as an array of pesticideactive ingredients that pose seri-ous health concerns.

Potential for human exposureto pesticides and toxic com-pounds in pesticide formulationscan be estimated by spray events, or “spray-days” percounty. A spray-day representsone field treated one time withone or more pesticides. Spray-

days are an imperfect but usefulindicator of the potential for hu-man exposure to pesticides andthe toxic compounds in pesticideformulations. Other measure-ments, such as pounds appliedper day, reflect only the applica-tion rates of the pesticide activeingredients applied; spray-daysshow the frequency and geo-graphic range of applications andthe potential for public exposureto all the air toxins in the pesti-cide formulation. EWG’s esti-mates of spray-days are conserva-tive measures of potential expo-sure, since spraying one field

with three chemicals at the sametime counts as only one spray-day.

Why is the number of applica-tions important? If measured inpounds, one spray-day consistingof one application of 10,000pounds of methyl bromide inMonterey County would look thesame as 10 applications of 1,000pounds each in adjacent SantaCruz County. Clearly, with 10sites the potential for some levelof drift is greater. Countingpounds instead of applicationsmasks this wider potential forexposure; neither does it accountfor potential exposure to thetoxic inert ingredients in pesti-

On a given day,Californians in a singlecounty may beexposed to hundredsof applications of dozens of differenttoxic pesticides.

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24 W HAT YOU D ON ’T KNOW COULD H URT YOU : P ESTICIDES IN CALIFORNIA ’S AIR

cides which are not reported inthe PUR system.

Up to 1,200 Sprays a Day

In counties of heaviest pesti-cide use, hundreds of separateapplications of 100 or more differ-ent chemicals can take place on asingle day during periods of heavy spraying. (Table 9.) In1995, Fresno, Monterey, andTulare counties averaged morethan 390 applications per day forat least one month, and FresnoCounty averaged more than 680

sprays per day for the month of May. For each month from Marchto August, Fresno County had anaverage of more than 400 applica-tions per day. Nine other countiesaveraged more than 100 spraysper day during those months. Toput it another way, calculated asannual spray-days, Fresno re-corded more than 143,000 oppor-tunities for potential drift or expo-

sure in 1995; Monterey had almost95,000 and Tulare more than90,000. (Figure 1.)

The most sprays on any singleday between 1991 and 1995 wererecorded in Fresno County onMay 17, 1995, when there were1,278 separate applications of pes-ticides. In 12 counties, the peakspray-day had at least 250 sepa-

rate applications, and in 26 coun-ties the peak day had over 100applications.

The highest number of differentpesticides applied on any givenday between 1991 and 1995 wasalso in Fresno County, with 159different chemicals applied on

June 30, 1995. In 12 counties,there was at least one day on

which more than 100 pesticides were applied. In 14 counties, forthe six months between March

and August, more than 50 pesti-cides were applied every day.

In most coastal counties, thesummer growing months are thetime of greatest pesticide use.

In Monterey and Santa Cruzcounties, an average of over 419pesticide applications per day take place from May through

September. On Aug. 5, 1995,there were 603 separate applica-tions in Monterey County, using133 different pesticides totaling62,637 pounds. On June 30,1995, there were 102 applica-tions in Santa Cruz County, us-ing 90 different pesticides total-ing 5,586 pounds. In 1995,Monterey had almost 95,000spray-days; Santa Cruz had

about 13,000.

In Santa Barbara County, anaverage of 120 pesticide appli-cations per day take place fromMay through September, and onMay 31, 1995, there were 205separate applications using 111different pesticides totaling16,741. pounds. More than36,000 spray-days were re-

corded in Santa Barbara County in 1995.

In Sonoma County, the sum-mer months see an average of over 60 applications a day. OnMay 17, 1995, there were 263separate applications in Sonomausing 53 different pesticides to-

In many counties,pesticides are sprayedhundreds of times aday in peak growingseason.

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25ENVIRONMENTAL W ORKING G ROUP

County

Day with the MostPesticide Applications(1991-1995) Number of Applications

Pounds of Pesticide

ActiveIngredient Number of Pesticides

Fresno May 17, 1995 1,278 440,410 125Tulare May 10, 1995 852 124,315 133Monterey August 5, 1995 603 62,637 133Kern June 17, 1995 536 130,123 113San Joaquin May 17, 1995 402 177,222 108Merced March 7, 1995 314 55,878 105Imperial February 25, 1995 297 101,761 62Madera May 8, 1995 295 155,105 64Stanislaus March 17, 1995 295 39,900 92Sonoma May 17, 1995 263 95,582 53

Napa May 17, 1995 239 82,053 33Riverside March 20, 1995 217 28,485 81Kings August 5, 1995 208 43,514 83Santa Barbara May 31, 1995 205 16,741 111Glenn May 19, 1995 202 84,829 45Sutter June 8, 1995 201 72,618 47Yolo February 15, 1995 194 24,475 62Colusa May 19, 1995 191 90,510 26Solano February 15, 1995 176 12,410 45Butte June 8, 1995 175 73,607 56Ventura March 15, 1995 163 7,057 90San Diego July 15, 1995 148 6,507 96San Luis Obispo June 20, 1995 136 19,274 84Sacramento March 30, 1995 127 16,548 51Santa Cruz June 30, 1995 102 5,586 90Mendocino May 18, 1995 101 37,756 31Lake April 4, 1995 70 1,797 28San Benito May 23, 1995 68 2,874 65Santa Clara June 20, 1995 62 2,409 51Tehama March 17, 1995 61 12,575 24

Table 9. Pesticides can be applied up to 1.200 different times in onecounty in a given day.

Source: California Dept. of Pesticide Regulation, 1991-95 Pesticide Use Reporting database.

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26 W HAT YOU D ON ’T KNOW COULD H URT YOU : P ESTICIDES IN CALIFORNIA ’S AIR

Figure 1. Annual number of spray-days* in California.

*A spray-day equals one field treated once on a given day with at least one pesticide. A field treated with multiple pesticides in one spraying session counts as a single spray-day.

Source: Environmental Working Group. Compiled from California Department of Pesticide Regulation, Pesticide Use Reports, 1995.

Number of spray-daysin 1995

0 - 2,5002,500 - 10,00010,000 - 25,00025,000 - 75,00075,000 - 145,000

taling 95,582 pounds. In 1995,Sonoma County recorded morethan 18,000 spray-days.

Pesticide use in VenturaCounty remains fairly steady throughout the entire year exceptfor January, when there were an

average of 68 sprays each day from 1991 to 1995. The peak day in that period was March 15,

1995, with 163 separate applica-tions using 90 different pesti-cides totaling 7,057 pounds. To-tal spray-days in 1995 totaledmore than 25,000.

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27ENVIRONMENTAL W ORKING G ROUP

What You Don’t KnowCould Hurt You

Chapter 4

Based on the response toEWG’s call for local communi-ties to participate in the Com-munity Pesticide Air MonitoringProject, public concern about

pesticide drift is widespread inCalifornia. Citizen volunteersattempted to sample air quality in five additional counties (Im-perial, San Diego, Orange,Solano and Yolo). In some casesthey were unable to find suit-able sites, given the limitationsof the equipment. (See Method-ology.) But in most cases, thechief obstacle was the inability to learn the time and place of pesticide applications withenough notice to set up andactivate the equipment.

In some communities citizenssecured agreements with farm-ers or local authorities to notify them when pesticides were be-ing applied, but this usually wasachieved only after residentsorganized, filed complaints andheld public protests to voicetheir concerns. Although statelaw requires annual reporting of every commercial application of pesticides, there is no law re-quiring prior notification toneighboring residents, schoolsor businesses before the use of

even the most toxic and volatilepesticides.

To get information on whatpesticides are being used on a

field behind your house or near your child’s school, the firstsource of information is thefarmer. However, growers are notobligated to provide this informa-tion and, understandably, are of-ten reluctant to provide it to citi-zens who may use it to organizeopposition to spraying.

The County AgricultureCommissioner

This means most citizens mustgo to the County AgricultureCommissioner, the keeper of pes-ticide reporting records for eachcounty. The willingness of Com-missioners to assist citizens con-cerned about pesticide drift variesfrom county to county. Some

view their jobs primarily as advo-cates for agriculture, denying thatpesticides pose any risk, whileothers take seriously their re-sponsibility to protect publichealth.

An activist in Davis describedthe Yolo County AgricultureCommissioner as “absolutely

State law does notrequire notice toneighboring residents,schools, or businessesbefore the use of even

the most toxic andvolatile pesticides.

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28 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

wonderful,” providing a detailedmap of crops grown in the pro-posed sampling area, but theCommissioner’s office in neighbor-ing Solano County was “unwilling

to push (farmers) for informationor relay it to me.” (McCarthy 1997)

In 1997, when hundreds of par-ents at Amesti Elementary Schoolin Santa Cruz County kept theirchildren home from school be-cause of a pending methyl bro-mide application, the County AgCommissioner dismissed their fearsas irrational, even before DPR con-

ducted any monitoring to assessdrift. But after an EWG air sam-pling project in nearby San LuisObispo County detected methylbromide drifting into a mobilehome park for senior citizens, the

Agriculture Commissioner took theinformation seriously, formally re-questing that DPR monitor a seriesof methyl bromide applications inthe county. DPR monitored two

application in the county in thesummer of 1998, and after againfinding excess levels at the trailerpark, county officials ordered a450-foot buffer zone around me-thyl bromide applications usingcertain methods. (Sneed 1998)

These varying county-to-county attitudes mean access to local in-formation about pesticide applica-

tions depends largely on where you live, rather than being uni-formly and equitably provided toall Californians.

There are several records pesti-cide users must file with the Agri-cultural Commissioner:

• Before the planting andspraying season, farmersmust file a Restricted Mate-rials Permit, indicating

what restricted use pesti-

cides the farmer plans touse that year. Restricteduse pesticides are thosethat are so dangerous thatU.S. law allows their useonly by trained and li-censed applicators. TheRestricted Materials Permittypically is a laundry list of all pesticides the farmermight use that year, be-

cause all anticipated usesmust be approved by the Ag Commissioner beforethe application season. Thepermit, filed months beforethe crops are even planted,provides no information on

where, when or in what volume pesticides will besprayed.

• When the farmer wants touse a pesticide listed onthe permit, he or she mustfile a Notice of Intent withthe Ag Commissioner

within 72 hours prior tothe application. This No-tice includes a map of thefield where the application

will take place, the acreageto be treated, the product

and the amount to beused. But as a practicalsource of information toconcerned citizens, it is of little use. The applicationmay take place at any time

within the 72-hour window and may be postponed or

Some local pesticideofficials take citizenconcerns seriously;others defend thestatus quo.

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29ENVIRONMENTAL W ORKING G ROUP

canceled without notice, socitizens can’t be sure whenthey will face exposure.

Also, hundreds of applica-tions may be pending in a

county each day during thepeak season, so unless acitizen has persuaded afriendly commissioner orclerk to provide a tip, find-ing out if a Notice of Intenthas been filed for a par-ticular field requires re-

viewing a mountain of forms each day.

• After application, farmersmust report their actualpesticide use monthly.These reports are compiledby the Ag Commissionerand sent to DPR for inclu-sion in the state’s PesticideUse Reporting database,published annually. How-ever, there is a delay of two or more years in avail-

ability of this data; the1996 PUR is not expectedto be released before theend of 1998.

This year the PUR was for thefirst time made available on CD-ROM, which in theory will im-prove citizens’ access. Unfortu-nately, the database is complexand unwieldy, requiring comput-

ers and technical expertise — well beyond the resources of average citizens — to decipherlocal data and make use of it. Inthe process of compiling thedata, the exact location of pesti-cide applications becomes ob-scured, and in the final database,

use locations can be determinedonly within a 1-square-mile sec-tion. No individual fields can beidentified, so the field behind

your child’s school is indistin-

guishable from those a mileaway.

Challenging the Permit

Although state law allows citi-zens to challenge the conditionsof a Restricted Use Permit, thedeck is stacked against them.First the challenge goes to the

Agricultural Commissioner, who

can fairly be said to have a vested interest in upholding hisprevious decision to allow theuse of restricted pesticides. Citi-zens may then appeal to the Di-rector of DPR. Under normal cir-cumstances, appeals of permitchallenges are handled by theDPR in Sacramento without pub-lic input other than a review of the written record. But in the

summer of 1997, in response toheated community opposition tomethyl bromide applications in

Ventura, Monterey and SantaCruz counties, DPR was forced tohold public meetings to hear theappeals, which drew large andemotional crowds from bothsides of the issue.

At the meetings, DPR officials

stated they had come only totake comments and refused toanswer most questions. They dis-couraged and restricted the pre-sentation of factual evidence by opponents of the applications.They also failed, despite a spe-cific request from Spanish-speak-

The state’s pesticidereporting system isdifficult for averagecitizens to use, andDPR doesn’t make it

any easier.

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30 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

ing residents in Santa CruzCounty, to provide full transla-tion of the proceedings. (EWG1997)

Although DPR Director Wellsruled in all three cases that theapplications could go forward,he did impose additional restric-tions on the amount of methylbromide to be used, the appli-cation schedule, and the bufferzone between the fields andneighboring homes and schools.

DPR then announced that futurelast-minute challenges would beto no avail: Unless challengesare filed well in advance of theNotice of Intent, the pesticide

application will go forward. Thisforces citizens to file all potentialchallenges at the beginning of the season, long before thegrower actually prepares to usea particular restricted pesticide.Once you find out a pesticide

will be sprayed, it’s too late tostop it.

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31ENVIRONMENTAL W ORKING G ROUP

Methodology

Chapter 5

The air sampling methodsused in the Community Monitor-ing Project were the same proto-cols employed by DPR and ARBin their monitoring efforts. Moni-toring experts within DPR and

ARB and from California aca-demic institutions were con-sulted during the developmentof EWG’s monitoring protocols.

Equipment

Most of the air samples formultiple pesticides were takenusing SKC programmable pumpsfitted with polyurethane fiber(PUF) tubes. This setup, com-monly used in occupational ex-posure studies of workplace pol-lutants, involves drawing airthrough the tube, which is lined

with an absorbent filter. Thepumps were programmed todraw one liter of air per minutefor eight continuous hours.

Pesticides or other pollutantsin the air were collected by thefilters, which were then analyzedby an independent laboratory inOakland. Pesticides were ex-tracted from the filters using pro-tocols of the National Institute of Occupational Safety and Healthand the California Department of Food and Agriculture. By mea-suring the amount of pesticide

collected in the filter against theamount of air drawn through thetube, the lab calculated the aver-age concentration of that pesti-cide in the air during the moni-toring period.

Sites

Volunteer samplers were in-structed to watch the testing loca-tions and take samples on days

when pesticides were being usednearby. Sampling stations wereplaced on private property nearthe application sites. If possible,the testing location was to belocated downwind from the pes-ticide application, with the pumptube mounted on a tripod four tofive feet above ground. The ap-proximate distance to the field,

weather conditions, the cropplanted, and the time, durationand method of application wererecorded.

Limitations

Though PUF tubes are state-of-the-art methodology, only 30 orso pesticides have ever been suc-cessfully sampled with PUFtubes. PUF tubes have been veri-fied as reliable for use on thepesticides by “spike tests” — de-liberately spiking the filters witha known quantity of the chemi-

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32 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

cal, then testing to confirm it.Many pesticides or fungicidescannot be detected by PUF tubes.Therefore, it is possible that ourair samples contained more pesti-

cides than the results indicate.Lack of exact information

about the specific pesticides usedduring a sampling period madelaboratory analysis more difficult.Knowing the crop being sprayedprovided some clues to lab tech-nicians who are familiar withpesticide use practices across thestate. EWG’s lab employed spe-

cialists trained in pesticide identi-fication, using techniques of ana-lytical chemistry more advancedthan the capabilities of most aca-demic labs.

Methyl Bromide MonitoringMethodology

Methyl bromide tests cited inthis report were conducted with

three different technologies: car-bon filters, silicon-lined canistersand an infrared electronic moni-tor.

During the initial stages of our work on methyl bromide in Cali-fornia we utilized carbon filtertechnology — at the time the in-dustry standard. DPR and ARB

were using this method, which

involves drawing air through aglass tube lined with activatedcharcoal and analyzing the filtersin a lab, and comparing the re-sults to regulations for methylbromide use near houses andother occupied structures. DuringEWG’s tests, we discovered thatcarbon filters were no longer

considered state-of-the-art. Dueto interference by atmosphericmoisture and degradation of thesample by heat and light on the

way from the field to the lab,

carbon filters routinely fail todetect 30 to 50 percent of themethyl bromide known to be inthe air. Internal DPR memos in-dicate that the agency’s scientists

were aware of this limitation, yetthe Department continued to usethis outmoded technology.

Air monitoring experts recom-mended that instead of carbon

filters we use SUMMA brandcanisters, which the ARB hadrecently adopted. The stainless-steel canisters are fitted a

vacuum pump that draws airinto a silicon-lined chamber. Af-ter collecting the sample, thecanister and the silicon lining areanalyzed in the laboratory for amuch more accurate reading of methyl bromide in air. In side-

by-side sampling, EWG foundthat SUMMA canisters consis-tently detected higher levels of methyl bromide than carbonsamples. In the summer of 1998,DPR finally began conducting itsown tests to compare carbonfilters and SUMMA canisters, andreportedly used canisters tomonitor for methyl bromide inSan Luis Obispo County. (Land

1998)

The FTIR infrared monitor,made available to EWG for ourfirst two monitoring projects in

Ventura and Monterey counties,uses a laser beam to identify chemical vapors in the air. Eachchemical has a unique light-in-

DPR was slow toadapt modern airsampling technology.

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33ENVIRONMENTAL W ORKING G ROUP

terference “fingerprint” that canbe detected by the laser. Unlikecharcoal filters or SUMMA canis-ters, FTIR monitoring allows in-stantaneous real-time readings of

methyl bromide in the air, atintervals as frequent as oneminute. In 1996, U.S. EPA ap-

proved the FTIR methodology formonitoring of atmospheric gases inambient air. Unfortunately, theFTIR technology is expensive andthe instrument requires trained

technicians to operate it, making itimpractical for use by the public.

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35ENVIRONMENTAL W ORKING G ROUP

DPR Meets the Scientists

Appendix

The state’s Scientific Review Panel on Toxic Air Contaminants(SRP) is a panel of nine academics and physicians, including toxicolo-gists, epidemiologists and other public health experts, appointed toadvise DPR and the Air Resources Board on the implementation of AB1807, the Toxic Air Contaminants Law. The SRP has been sharply criti-cal of DPR’s approach to science, saying the agency relies too muchon information supplied by the pesticide industry, uses outdatedmethodology, takes far too long to take action against dangerouschemicals and seems less than adequately concerned with protectingpublic health. Most significantly, SRP members have stated that DPR’sentire regulatory scheme, which says that increased volume of pesti-cide use doesn’t matter if exposure is controlled, is fundamentally un-sound.

For example, here are excerpts from a March 19, 1997 meeting at which the SRP reviewed DPR’s draft evaluation of the cotton defoliantDEF as a toxic air contaminant. The excerpts are followed by a letterfrom California public interest groups to the SRP, offering a detailedtechnical critique of DPR’s failure to adequate regulate pesticide airpollution.

Dr. John R. Froines, director, UCLA Center for Occupa-tional and Environmental Health: “I have serious problems

with this entire document. There is a fundamental problem wehave to talk about. Everything in this document, every assess-ment of risk, is tied to an estimation of exposure. In the [AB]1807 process we’re supposed to evaluate toxicology separately

— risk assessment is separate from risk management. If yourexposure estimate is wrong, or the circumstances change, yourassessment of risk can change radically. Toxicology must beevaluated on its own. This is a very peculiar way of doingthings. I know of no other purportedly scientific agency thatdoes things this way. All the way through, what we have is thedismissal of potential adverse effects. It’s as if you want to dis-miss everything. It’s inappropriate. It’s unconscionable. Thereare some really fundamental, not trivial, problems with this ap-proach.”

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Dr. Stanton A. Glantz, professor of medicine, UC San Fran-cisco: “The compound [DEF] is or isn’t toxic. Answer that ques-tion first. Then the second question is how much of it peopleare exposed to. You keep saying it isn’t toxic, based on your

assumption of exposure.”DPR Deputy Director Jean-Marie Peltier: “Our regulations arepromulgated on the basis of exposure.”

Glantz: “If that’s what [DPR’s regulation] says, that’s at odds with the law.”

Froines: “This is what bothers me. You say [the proposed stan-dard] meets your regulations. Or you say it conforms to a [safelevel] from a previous study. But this process is not about meet-

ing the minimum requirements. It’s about protecting publichealth.”

Dr. James Pitts, professor of chemistry, UC-Irvine, then-chair of SRP: “I just counted [DPR’s] citations in this document.Of less than 100 references, 40 are from industry reports thataren’t peer-reviewed — that come from people who have aninterest in the numbers. You are not going to find good sciencein confidential industry reports. You don’t mix paid data withscience without stipulating the conflict of interest. . . . Let’s stopplaying these numbers games and tell the public what expo-

sures they really ought to be worried about. It’s frightening tothink you can take a six-month-old baby into a home that’sbeen fumigated with methyl bromide and the State of Californiaoffers you no protection. You have to take into account what

will really protect public health. If you look at the risk of methylbromide based on the exposure to the entire population, it may be low. But you also need to consider, what’s the impact on asix-year-old whose home is next to a field sprayed with methylbromide?”

(SRP 1997)

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Letter to Scientific Review Panel From Public Interest Groups

October 12, 1998

Scientific Review Panel on Toxic Air Contaminants

c/o California Air Resources Board2020 L StreetP.O. Box 2815Sacramento, CA 95812

Dear Members of the Scientific Review Panel:

On October 14 you will be discussing the agenda for an upcomingeducational workshop for new Scientific Review Panel members en-titled “Pesticides in Air.” We strongly support the idea that the Depart-ment of Pesticide Regulation should conduct this workshop, and re-

quest that the Scientific Review Panel include in its agenda the follow-ing additional items.

1. Statutory Authority

It is important to include a section in the workshop on DPR’s re-sponsibilities under the Toxic Air Contaminant (TAC) law.

In public comments responding to a recently released CALPIRGand Californians for Pesticide Reform (CPR) report, DPR acknowl-edged its failure to implement the TAC law but justified its actions

with comments like “We have other laws,” “We have simply chosen afaster way to do things,” and “If the toxic air contaminant law disap-peared tomorrow, it would not affect our ability to place controls onpesticides.”

These comments imply that DPR believes it is not required toimplement the TAC law. Government agencies, however, are not per-mitted to pick and choose the laws they implement. The TAC law wasdesigned to address the specific hazards of pesticides in air and in-cludes important air monitoring and public, peer-review components.On what basis does DPR justify ignoring this law and failing to pro-

duce required documents?

2. Pesticide Air Monitoring

The workshop should include a discussion of pesticide air monitor-ing, a critical component of the TAC process. Because the law directsDPR to give priority to the evaluation and regulation of pesticidesbased on health risk and exposure, air monitoring data can be a de-termining factor both in the decision to list a pesticide as a TAC and

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in any ensuing mitigation. Thus, adequate monitoring of target pesti-cides is essential to protecting public health under the TAC program.In particular, the following subjects should be addressed:

• Scope . Considering the widespread use of pesticides, the scope

of current pesticide air monitoring under the TAC program failsto provide sufficient monitoring data. CALPIRG’s recent report,Poisoning the Air, found that TAC air monitoring had not beendone in 42 out of California’s 58 counties. While we supportDPR’s efforts to target monitoring in high use counties, monitor-ing in just one county per pesticide ignores regional variations,including differences in landscape, climate and population. Wedo not believe that monitoring in just one geographic locationcan accurately “document the level of airborne emissions,” asrequired by TAC law. In addition, only limited numbers of pesti-cides have been monitored under the TAC law. Only 26 air

monitoring reports have been completed in the 15 years of theprogram (air monitoring has been completed for 35 pesticidesbut the reports have not been completed for 9), far below the72-78 that DPR projected completing by 1998. Therefore, morethan 100 pesticides listed by the Department as “Candidate Toxic

Air Contaminants” have not been monitored.

• Correlating Air Monitoring with Use. Presumably, actual pesti-cide use in the monitored region would be a critical factor inassessing the potential for pesticides to drift in and around Cali-fornia communities. For most pesticides, however, DPR makes

no effort to correlate detection levels with actual pesticide use.Low or non-detect levels may simply be the result of little or nolocal use as opposed to low concentrations or mobility. As a re-sult, important regulatory decisions affecting the health of localcommunities are currently made based on ambiguous data.

• Notification of Agricultural Commissioners and the Potential for Altered Use Practices. Anecdotal evidence from air monitoring inLompoc suggests that growers with advance notice of air moni-toring may alter use practices in order to reduce pesticide detec-tions. While this evidence is strictly anecdotal, we believe ad-

vance notice of air monitoring statewide could result in alteredpractices and inaccurate monitoring results.

• Monitoring Technology. We are concerned that air monitoringtechnologies, particularly those used to monitor methyl bromide,may be outdated and inaccurate. According to studies by theEnvironmental Working Group (see Something’s in the Air , 1997)the monitoring equipment used by DPR in some studies em-ploys outdated charcoal-tube technology that routinely fails to

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39ENVIRONMENTAL W ORKING G ROUP

capture and retain significant amounts of methyl bromide in theambient air. The workshop on pesticides in air should include adiscussion of monitoring technologies and their strengths and

weaknesses.

• Publicizing Air Monitoring Results. Local communities should benotified of the results of air monitoring in their areas. Currently no effort is made to provide communities with air monitoringresults. Citizens who request information are sent documentsthat are typically long, complicated and difficult to interpret. Ef-forts should be made to summarize results and make them ac-cessible to the public.

3. Hazardous Air Pollutants

DPR’s “Pesticides in the Air” workshop should include the creation

of an action plan for DPR’s regulation of Hazardous Air Pollutants un-der the TAC law as well as its plans for producing health effects docu-ments for these pesticides.

In a letter to Assemblyman Fred Keeley, DPR argues that “there isno requirement to mitigate HAPTACs” under the TAC law. In other

words, DPR believes that the law only requires it to list Hazardous AirPollutants as Toxic Air Contaminants and that their responsibility un-der the TAC law ends there. As a result, some of the most dangerousair pollutants have been effectively isolated from the TAC process pre-cluding the production of health effects documents and avoiding pub-

lic accountability.

We do not believe this is what the authors had intended when they specifically required that DPR list HAPs as TACs. We believe thathealth effects documents are needed in order to assess a particularpesticide’s threat to human health and the environment.

4. Simultaneous Exposure to Multiple Pesticides

DPR should initiate a discussion with the Scientific Review Panelon the potential impact to public health of simultaneous exposure to

multiple pesticides. Current TAC evaluation is done on a chemical by chemical basis; however, real-world exposure to airborne pesticides ismore complex. For example, a recent study by Dr. Seiber [Dr. JamesN. Seiber, director of the Center for Environmental Science and Engi-neering, University of Nevada-Reno) found the three pesticides ethylparathion, diazinon and chlorpyrifos 25 to 50 miles from the likely sites of application. The level of each individual pesticide was below the state’s safety standard; however, cumulative exposure may be amore important consideration. The workshop should include a discus-

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40 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

sion of how DPR is protecting the public from multiple exposures topesticides with the same mechanism of toxicity (e.g. organophos-phates and carbamates).

5. Pesticide Prioritization

Although DPR has produced a list of “Candidate Toxic Air Con-taminants” ranked 1-134, this list apparently has not been used to pri-oritize the evaluation of potential TAC pesticides. According to a draftDPR memorandum, “Procedures to Address the Status of Toxic AirContaminant Candidates,” DPR has nearly completed the TAC processfor pesticides ranked 4 and 38 and has initiated the process for pesti-cides ranked 3, 14, 23, 28. Clearly DPR is not using its own priority list. And if it is not using its own priority list, how are the pesticidesbeing chosen? Why is DPR not using this list?

6. Structural Fumigation and Other Urban/Suburban Sources of Airborne Pesticides

Agricultural sources of airborne pesticides appear to be the solefocus of DPR’s limited TAC program. Although agriculture does ac-count for most of reported pesticide use statewide, non-agriculturaluses of pesticides, both through fumigations and landscape work by licensed applicators, as well as unreported use by homeowners, may be a significant source of exposure to airborne pesticides for the gen-eral public. DPR studies outside of the TAC program have shown, forexample, that structural fumigations with methyl bromide can result in

unsafe exposures 50 to 100 feet from fumigated homes. Pesticidesused outdoors may also accumulate indoors. The authors of The Ef- fects of Pesticides on Human Health (Princeton Scientific Press,1990),for example, cited three studies and concluded that “at any giventime, the air inside of the average dwelling in the U.S. contains sev-eral kinds of pesticides at levels that are typically 10-100 times higherthan those found in the immediately surrounding outdoor air.”

What are DPR’s responsibilities under the TAC program to monitorand regulate airborne pesticides in the urban environment? Does DPR have any responsibility under the TAC program to monitor and regu-

late pesticides found indoors? Should DPR be monitoring for Candi-date TACs inside buildings near fields as well as outside?

7. Strategies for Prevention

As the population of California expands, particularly in agriculturalcounties, airborne pesticides will become an increasingly controversialissue. Quoted in the Los Angeles Times , for example, DPR AssistantDirector Paul Gosselin explained that rural-urban clashes “are going

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41ENVIRONMENTAL W ORKING G ROUP

to come up more and more.” DPR should anticipate these clashes andtake proactive steps now to encourage alternatives to pesticide use. Inparticular, DPR should create incentives to phase out the use of pesti-cides identified as carcinogens, reproductive toxins and acute nervoussystem toxins.

We hope you agree that the issues above are crucial to the under-standing of pesticides in air, particularly as they relate to the Toxic AirContaminant Program, and we hope that you will include them in theagenda for the workshop.

Sincerely,

Zev RossCalifornia Public Interest Research Group

Bill WalkerEnvironmental Working Group

Jeanne MerrillPesticide Watch Education Fund

Susan Kegley Pesticide Action Network

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References

What You Don’t Know Could Hurt You

Alvarez, Fred, 1998. “Groups Protest New Guidelines on Fumigant.”Los Angeles Times (Ventura edition), Dec. 8, 1998.

ARB 1997. California Ambient Air Quality Data: 1980-1996. Califor-nia Air Resources Board. TSD-97-007-CD, December 1997.

Arax, Mark, 1997. “Pesticide Use Is on Rise in State, Study Finds.” Los Angeles Times, September 18, 1997.

Baker, Lyton T, et al, 1996. “Ambient Air Concentrations of Pesticidesin California.” Environmental Science & Technology. 30(4), pp. 1365-1368.

Baker, Lynton T, 1998. Personal Communication to EWG. November,1998.

Benjey, W.G., 1993. “Agricultural Pesticide Emissions Associated withCommon Crops in the United States.” 86th Annual Meeting of the Airand Waste Management Association, Denver, CO, June 14-18, 1993,No. 93-WP-96.01, published by the Air and Waste Management Asso-ciation, Pittsburgh, PA, 1994 (EPA Report No. 600/A-93/065)

CPR 1997. Rising Toxic Tide: Pesticide Use in California 1991-1995 .Californians for Pesticide Reform, 1997.

CPR 1998. Poisoning the Air: Airborne Pesticides in California . Califor-nians for Pesticide Reform, 1998.

DOF 1998. “County Population Estimates and Components of Change,1996-1997, with Historical Estimates, 1990-1996,” Demographic Re-search Unit, California Department of Finance, www.dof.ca.gov/html/Demograp/e-2text.html

DPR 1997. California Pesticide Use Reporting Database for 1995. Cali-fornia Department of Pesticide Regulation, 1997.

DPR 1998. “Statement on Pesticides In Air Report.” California Depart-ment of Pesticide Regulation Press Release, August 19, 1998.

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44 W HAT Y OU D ON ’T K NOW C OULD H URT Y OU : P ESTICIDES IN C ALIFORNIA ’S A IR

DPR 1998b. “Reducing Volatile Organic Compound Emissions form Agricultural and Commercial Structural Use of Pesticides.” CaliforniaDepartment of Pesticide Regulation. February 3, 1998.

EWG 1997. An EWG representative attended the DPR permit chal-

lenge hearings held in Watsonville and Ventura.EWG 1998. @Risk: Pesticide Use Near California Schools . Environmen-tal Working Group website, http://www.ewg.org/@risk, 1998.

EWG 1998b. Methyl Bromide Use Near California Schools 1995 . Envi-ronmental Working Group, 1998.

Kelley, Kevin and Nu-may R Reed, 1996. “Pesticides for Evaluation asCandidate Toxic Air Contaminants.” California Department of Pesti-cide Regulation Staff Report, October 1996.

Kollman, Wynette S. “Summary of Assembly Bill 1807/3219: Pesticide Air Monitoring Results Conducted by the California Air ResourcesBoard 1986-1995.” California Department of Pesticide Regulation,1996

Land, Geoff, 1998. Personal Communication to EWG. July 1998.

Lifsher, Marc, 1997. “Pesticide Control Agency Is Stalling, Critics Say.”The Wall Street Journal (California edition), March 5, 1997.

Majewski, Michael S. and Capel, Paul D., 1995. Pesticides in the Atmo- sphere: Distribution, Trends, and Governing Factors . United StatesGeological Survey, 1995.

McCarthy, Samantha, 1997. Personal Communication to EWG. Septem-ber 1997.

Scholtz, Trevor M., et. al., 1997. “Pesticide Emissions Modelling: De- velopment of a North American Pesticide Emissions Inventory.” FinalReport of the Canadian Global Emissions Interpretation Centre; pre-pared by Ortech Corporation, May 1997.

Sneed, David, 1998. “Pesticide Risk Prompts New County Regulation,”San Luis Obispo County Telegram-Tribune , November 14, 1998.

SRP 1997. Transcript of Meeting of Scientific Review Panel on Toxic Air Contaminants, March 19, 1997, at http://www.arb.ca.gov/srp/srp.htm.

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