Children's  Health
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Multiple Risk

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     United States
     Environmental Protection
Office of Pesticide Programs (7506P)
Washington, DC 20460
   October 2010

The mission of the U.S. Environmental Protection Agency's (EPA's) Office of
Pesticide Programs (OPP) is to protect human health and the environment
from potential risks associated with pesticide use. When used properly,
pesticides can help control disease-causing organisms and foster a safe and
abundant food supply. It is OPP's goal to ensure that pesticides marketed in
the United States are sold, distributed, and used in a way that is protective of
people's health, particularly that of vulnerable populations like children.  This
requires that the Office use the best available science when reaching
regulatory decisions, find ways to communicate those decisions effectively,
develop educational and training opportunities to help pesticide users make
informed choices, and ensure proper implementation of pesticide statutes.

Protecting children's health is a priority for this Administration.  EPA and other
agencies place priority on addressing environmental health risks that
disproportionately affect children. There are a number of unique challenges
to ensuring that pesticide regulatory decisions are protective of children. In its
1993 publication, "Pesticides in the Diets of Infants and Children," the
National Research Council stated that children are not "little adults."
Important differences include:

•  Children's metabolic rates are more rapid
•  Children process toxicants differently
•  Children pass through critical developmental stages
•  Children consume more food in proportion to body size (as well as
   different types of food)
•  Children's exposure patterns differ from adults'

Many of the recommendations outlined in "Pesticides in the Diets of Infants
and Children" were incorporated in the Food Quality Protection Act of 1996
(FQPA), which ensures greater protection of children from pesticide risks.
Consistent with these  mandates, OPP has established policies, procedures,
and requirements to expand the protection of children.

This document is designed to educate readers about the foundation for
children's health protection that has been established in our national pesticide
program, which encompasses the work of OPP and its regulatory partners,
including states, tribes, and other federal agencies.  This foundation consists
of comprehensive, interconnected activities that address critical needs related
to children's health. In addition to current activities, the document outlines
how the program is working to expand the protection of children in the future.
    By building on
  past successes,
    responding to
 changes in science
  and statutes, and
  focusing on areas
    that still need
  improvement, we
    protect future
  generations while
providing access to
safe and useful pest

              Steve Owens,
       Assistant Administrator,
  EPA's Office of Chemical Safety
       and Pollution Prevention
                                                                                      Page 3


Mission Statement
       Administrator Lisa P. Jackson stressed the importance of children when she
       stated that "protecting children's environmental health is central to our work at
       EPA." In keeping with OPP's broader mission and the Administrator's
       statement, OPP has developed the following mission statement for children's
       health protection:

            Protecting children's environmental health in all communities
               will be a routine part of OPP's programmatic activities.

       OPP uses a comprehensive, tiered, and linked approach to accomplish this
       mission.  Our actions are built on the foundation of relevant statutory
       authorities, which provide a framework for efforts to protect children. These
       authorities are implemented based on an informed appreciation of the
       multiple risk exposure scenarios that potentially impact children.
       Understanding these scenarios allows meaningful, risk-based priority setting
       and activity planning.  The Office's children's health protection activities are
       grouped in core programmatic components that encompass activities to
       address the key risks in the various exposure scenarios  and allow the
       program to focus on areas that  provide the most impact.  These concepts are
       discussed in detail in subsequent sections.
                                    Risk Exposure Scenarios
                                     Statutory Authority
                 EPA will use a variety of approaches to protect children from
               environmental health hazards.  Those approaches will include
               regulation, implementation of community-based programs,
               research and outreach."
                                                  EPA Administrator Lisa P. Jackson

Statutory Authority

Focus of Activities - Fully utilizing relevant statutes to
protect children, including the development of
appropriate regulatory actions and the use of data call-in
authority to require studies where needed to address data

The primary statutes regulating pesticide use in the United States are the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug, and
Cosmetic Act (FFDCA).  FIFRA gives EPA the authority to regulate the registration
(licensing) and use of pesticides, and FFDCA governs the establishment of tolerances
(also known as maximum residue limits) on food and animal feed.  In order for a pesticide
to be registered under FIFRA, it must be demonstrated that the pesticide's use will not
result in "unreasonable adverse effects" on human health or the environment. FIFRA
provides EPA with authority to make pesticide regulatory decisions necessary to ensure
the safe use of pesticides and to require any data the Agency determines are needed to
reach those decisions. FIFRA also requires the periodic review of existing registrations,
during which EPA can use the same data call-in authority associated with the registration

FFDCA governs the establishment of tolerances, requiring that these levels are sufficient to
ensure a "reasonable certainty of no harm" from pesticide use. FFDCA contains specific
requirements  related to children as a result of the Food Quality Protection Act (FQPA)
amendments of 1996.  Specifically, when establishing  or modifying a tolerance, EPA must
consider available information about the consumption patterns of infants and children, the
special susceptibility of infants and children to pesticide residues, cumulative  effects of
exposure (not just to the  pesticide being considered for the tolerance but to other
pesticides with a common mechanism of toxicity), and aggregate exposure from all
possible routes of exposure. FQPA also requires that  EPA apply an additional tenfold
safety factor when establishing tolerances for foods consumed by children, unless reliable
data indicate that a lesser factor would be protective.
                                                                           Page 5

          Multiple Risk Exposure Scenarios

          Focus of Activities - Taking steps to ensure that OPP's
          activities are protective for all exposure scenarios, using
          sound science and the best available data.
          In modern society, pesticides have widespread uses and, therefore, have the potential to
          impact children in a variety of settings (see below).  Effectively protecting children
          requires assessing each of these exposure scenarios independently as well as in the
          aggregate, identifying scenarios resulting in unacceptable risk, and mitigating those risks.
                    Possible Exposure Scenarios Affecting Children
                         Home - Children may be exposed to pesticides
                         used in the home to control pests or through the
                         food they eat. Risk assessments and pesticide
                         registration actions take account of these potential
                         School - Children may be exposed to pesticides
                         at school.
                         Play - Children may be exposed to pesticides
                         where they play.

                         Work - Some children are employed in agriculture
                         and others may be present in fields or exposed to
                         pesticides brought home on the clothes of parents.

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At Home
A child's diet is a potential source of pesticide exposure, but it may not be the only
potential source within the home. Children may also be exposed to pesticides through
lawn and garden products, insect repellents, antimicrobial products, or other pest control
practices within the residence. To address these exposures, OPP has:

      •  Concentrated on reducing pesticide dietary risk from foods most consumed by
      •  Given priority to registration applications for pesticides that pose less risk to
         human health and the environment than existing conventional pesticide
      •  Improved risk assessments to better characterize potential exposure to children
         and account for children's behavior (e.g., crawling and placing objects in their

OPP has also partnered with the Department of Housing and Urban Development and
others on a National Integrated Pest Management (IPM) in Housing Strategy to help bring
IPM to families living in  public housing.
 Integrated Pest Management programs rely on a combination of common-
 sense pest control practices and not just use of pesticides. IPM strategies
 make use of information regarding the biology of pests in combination with
 available pest control technologies to manage  pests economically and with the
 least possible hazard to people, property, and  the environment.  IPM
 programs take advantage of all appropriate non-pesticide pest management
 strategies, with the judicious and careful use of pesticides when necessary.
                                                                            Page 7

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In School

Children may be affected by pesticide use in and around schools and day care centers.
OPP has emphasized this potential exposure through initiatives such as IPM in Schools,
which seeks to obtain a significant reduction in both pest complaints and pesticide use in
schools.  OPP, partnering with the National Head Start Association and the Department of
Health and Human Services' Child Care Bureau, launched a national awareness
campaign on the safe use of pesticides directed at child care center staff and parents.

OPP also manages two grants programs that have historically funded School IPM grants:

(1) OPP's Pesticide Environmental Stewardship Program (PESP), a voluntary
   membership and grants program (with over 200 members and $500,000 a year in
   grants) that works with the nation's pesticide-user community to reduce human health
   and environmental risks associated with pesticide use. PESP Regional grants have,
   over the past decade, funded over 25 IPM in School projects across the country; and

(2) Pesticide Registration Improvement Act grants, which in the past three years has
   provided $500,000 for two projects to foster IPM implementation in all of the nation's

In addition, OPP has partnered with a team of IPM experts from across federal, state, and
local governments, as well as non-governmental organizations and the academic
community, to promote IPM in schools.
                                                                               Page 9

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 At Play

Children also face the potential for exposure to pesticides outside of the home and classroom.

OPP has taken regulatory action to address these risks, such as eliminating uses of chromated
copper arsenate (CCA) on play-structures, decks, and picnic tables.

The Agency is also investigating ways to reduce off-site exposure of bystanders to pesticides
through spray drift or volatilization, as discussed elsewhere in this document, and will continue to
assess risks where exposure to children may be an issue.

The Office is committed to continuing to take regulatory action as appropriate to ensure the
protection of children. Pesticide risk  assessments include consideration of the possible exposure
to children at play by considering practices such as placing toys or their hands in their mouths and
crawling or rolling on lawns.
                                                                                   Page 11

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In  the Workplace
 The Government Accountability Office, in its 1998 report Child Labor in Agriculture, estimated that
 approximately 120,000 children between the ages of 15 and 17 work in agriculture but
 acknowledged it is very difficult to develop an accurate figure.  Children who work with and
 around pesticides may not be the only children exposed. Parents who work with pesticides, or
 who work in or near fields where pesticides have been or are being applied, may bring their
 children to the fields with them. There may also be second-hand exposure to children of
 agricultural workers through spray drift or residue on the clothing of parents.

 OPP has reached out with Public Service Announcements (PSAs) on Spanish-language radio
 stations to educate parents about the hazards of bringing pesticide residues home and is working
 with migrant and worker advocates, states, and farm groups on ways to encourage parents to
 send their children to  school and not bring them to the fields where the parents work.

 EPA is seeking to further protect children by proposing to strengthen its assessment of pesticide
 health risks, including a more thorough assessment of risks to workers (including farmworkers
 and farm children) and risks posed by pesticides that are not used on food.
                                                                                  Page 13

    Core  Programmatic  Components

    While OPP has always been committed to protecting children, the Office recognizes that
    more can be done. By taking advantage of new data and scientific advancements and
    learning from our experiences, OPP is building on past successes to strengthen our efforts to
    protect children's health.  We continue to address existing data gaps and make regulatory
    decisions that are protective of children.

    Realizing OPP's mission to protect children's health involves work in six broad areas:

           1 Establishing a sound scientific foundation;

          2. Making effective risk assessment and risk management decisions;

          3. Developing a strong regulatory framework;

          4. Designing relevant education and training for staff, OPP partners, stakeholders,
             and the general public;

          5. Enforcing pesticide laws in a timely and targeted manner; and

          6. Forming new, or maintaining existing, partnerships to improve our ability to protect
            children's health.

    This section describes the focus of OPP's activities in these key areas and how new efforts
    are building on a strong foundation to expand the protection of children. This description
    outlines current protections resulting from completed or continuing work and future activities
    that will address remaining needs or deficiencies. The  details of how these activities are
    implemented are contained in annual work plans  and commitments.
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      Representative Pesticide Activities and Future Enh
              Sound Science
                                                          Identify/address data gaps —
                                                          >   Identify nature and extent of exposure to children
                                                              taken into fields and obtain better data on number
                                                              of children working in agriculture

                                               Seek to increase the amount/nature of data on children working in
                                               agriculture as part of worker safety regulation amendments
                                          Analyze incident data for trends in children's exposure
                                                                                            Current Pn
                        Work with the Tribal Science
                        Council on children's health issues
                                                                • Provide funds to support
                                                                  Department of Labor's pesticide
                                                                  worker safety survey fund
                                                                • Consult on development of
                                                                  National Institute of Occupational
                                                                  Safety and Health SENSOR
                                                                  Drogram (pesticide incident data)
           Continue to use grant programs toj
           attract new investments in research
           related to children's health
            Coordinate closely with state
            and tribal regulatory partners to
            identify children's health issues of
• Work with EPA's Office of Children's
  Health Protection on GAO recommendations
  and task force on children's health
• Participate in national disinfection workgroup
• Work with other federal agencies to promote
  use of IPM and IPM education and
  training initiatives
                                                                                Expedited response to child-
                                                                                related exposure incidents:
                                                                                Provide medical personnel
                                                                                with pesticide information
                                                                                Request results if testing is
                                                                                conducted, and collect
                                                                                statements from authorities
                                          Enhance enforcement
                                          coordination with states/
                                          regions to identify children's
                                          health issues and possible
                                          violations of pesticide laws

                                          Implement soil fumigant
                                          .decision w/benefits to children
                                                                   Improve coordination, response,
                                                                   timing in support of enforcement
                                                                   case development
                                                             Promote actions to protect children
                                                             and raise the visibility of programmatic
                                                             and regulatory (including enforcement)
                                                             actions to protect children's health.
Timely and Targeted Enforcement

ancements  to  Expand Protection of Children
   Expand current protections for dietary risk to infants
   and children to non-dietary risks

   Re-evaluate risk assessment
   practices to better consider child workers' risks
   Implement decision on soil fumigants, which focuses on
   Drotection of bystanders, including children
                               Risk Assessment and
                         Risk Management
   • Improve Risk Assessment Process^
    Require neurotoxicity studies, develop
    new methods to better consider
    children's risk
   • Implement Pesticide Specific Actions:
    Tolerance reassessment and action
    on specific pesticides (methyl
    parathion, carbofuran, azinphos-
    methyl, CCA, rodenticides)
              Assist in revision of national health and
              safety standards for child care centers
             • Make consideration of children's health
              issues a routine part of rule/regulation
    Conduct outreach to Hispanic
    and urban audiences:
    > PSAs on take-home exposure
    Provide grants to address children's
    health issues
    Conduct public education campaigns
    (safe storage, use of pesticides in
    child care centers)
    Conduct Nationwide IPM training
    program (Healthy Homes)
Develop curricula
parents about risks
                    Finalize amendments to
                    current regulations:

                    Worker safety regulations —
                    >   inform about hazards
                    >   protect from exposure
                        and mitigate if it occurs

                    Certification and training
                    regulations —
                    >   set age limits for using
                        restricted use pesticides
                    >   improve competency of
                        applicators through training

                    Consider impacts on children
                    while developing rules on
                    product performance — 25(b)j
                    (minimum risk) products
for parents to educate
from take-home
   Enhance websites on product performance and consumer labeling
   to help users make better decisions to protect children
    Revised educational materials for health care

    >   Recognition and Management of Pesticide
                                                      Relevant Education and Training

        ound Science
 Focus of Activities - Promoting use of sound science and
 continued investment in new scientific approaches to
 improve our understanding of the potential risks to
 children from pesticide use and develop a blueprint for
 future advancements.

 Because science is always advancing, OPP periodically updates and changes the way it
 approaches pesticide risk assessments. Under FIFRA and FFDCA, the national pesticide
 program is one of the most data-rich programs at EPA, providing significant information
 upon which to make pesticide decisions. Our goal is a more comprehensive and consistent
 evaluation of potential risks of pesticides, including all potential routes of exposure.  For
 example, OPP is moving to apply risk assessment techniques for food-use pesticides,
 developed in implementing FQPA, to any pesticide risk assessment as long as application of
 the risk assessment technique is consistent with good scientific practice and is not otherwise
 prohibited by law. This will include reporting potential risks for individuals who had not been
 explicitly considered, specifically workers 12 - 17 years of age and children taken into
 agricultural fields while their parents work.  OPP will continue improving data requirements
 to allow for the collection of more relevant data on children's exposure.

 Current Protections:

 •  Revised data requirements for conventional,  biological, and antimicrobial pesticides to
    increase available information on human health and environmental effects;
 •  Began explicitly reporting risks for child workers and children taken into agricultural
 •  Supported the Department of Labor's National Agricultural Workers Survey that provides
    national information on health and demographics of agricultural workers;
 •  Provided funding and consultation to the National Institute of Occupational Safety and
    Health to increase the number of states in the Sentinel Event Notification System for
    Occupational Risk (SENSOR) Program and to expand occupational illness and injury
    surveillance capacity within  state health departments in areas of the country with sizable
    agricultural worker populations;
 •  Improved methods to ensure that pesticides intended to control vector-borne diseases
    (West Nile virus, Lyme disease, etc.) are efficacious;
 •  Received peer review from the FIFRA Scientific Advisory Panel, an independent
    scientific panel, to determine how to address potential  risk from pesticide volatilization;
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•  Conducted a "Bed Bug Summit" that brought together experts to discuss possible areas
   for research and to recommend approaches to address bed bug infestation. As a follow-
   up activity, OPP distributed information on best practices for controlling bed bugs; and
•  Supported the Centers for Disease Control and Prevention (CDC) National Health and
   Nutrition Examination Survey, which provides up-to-date food consumption data for

Future Activities:

Strategic Approach — Enhance data and scientific tools to improve decisions and target
actions to protect children.

Specific Actions
•  Identify and Address Data Gaps — Determine if there are areas where additional data
   are needed to better inform our decisions (for example, several changes are being made
   to the risk assessment process that are discussed in the next section);
•  Analyze Available Data on Pesticide Incidents — Ascertain if certain pesticides, or
   pesticide use patterns, are more likely to result in risks to children;
•  Develop Integrated Testing Strategies — Building on
   previous work, integrate concepts such as
   computational toxicology to allow for more timely and
   effective risk assessments, which will facilitate quicker
   regulatory decisions; and
•  Reduce Non-Target Exposure From Pesticide Spray
   Drift — Work with the U.S. Department of Agriculture
   (USDA) and stakeholders to finalize a protocol to
   identify and verify technologies to reduce spray drift in
   the environment, which will reduce health risks to
   children from off-target deposition of pesticides.
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Risk Assessment/Risk Management
    Focus of Activities - Ensuring that risk assessment and
    risk management processes consider the uniqueness of
    children  and inform decisions that are protective of

    Pesticide risk assessments cover all endpoints of concern. OPP updates risk assessment
    methods as science evolves or new information becomes available, and has worked to
    improve protection of children's health. There has been an increased emphasis on toxic
    effects unique to children.  OPP requires advanced toxicity testing to assess possible effects
    on the fetus and developing young, including developmental neurotoxicity and reproductive
    studies. OPP has required specific studies to evaluate comparative sensitivity of adult and
    young experimental animals, and has focused on child-specific diets, residential exposures
    (playing on lawns and hand-to-mouth behavior),  and aggregate risks (risk of exposure to
    several pesticides that act  in the same manner).  Post FQPA (1996), OPP added an extra
    tenfold uncertainty factor when establishing tolerances where there is a lack of reliable data
    on children's health effects and exposures. OPP is also improving occupational risk
    assessments, which have not routinely considered some child-specific exposure scenarios.

    Current Protections:

      Risk Assessment

    •  Completed reassessment of all (over 9,700) tolerances (maximum residue levels in
       food), giving special consideration to consumption patterns and special susceptibility of
       infants and children;
    •  Required additional studies (developmental neurotoxicity, immunotoxicity, and special
       comparative toxicity studies such as comparative cholinesterase, thyroid, and
       immunotoxicity studies) to better understand how pesticides may affect children;
    •  Implemented pesticide screening in the endocrine disrupter screening program to better
       understand and address possible pesticide effects on the human endocrine system;  and
    •  Used new tests/risk assessment methods to target factors unique to infants and children.

      Risk Management

    •  Took significant action  on individual pesticides, or groups of pesticides, where risks to
       children had been identified, including:
       > Canceled major children's food uses of methyl parathion and all tolerances for
         carbofuran, resulting in a significant reduction of acute dietary risk to children;
       > Eliminated virtually all residential uses of organophosphate pesticides;
       > Negotiated elimination of virtually all residential uses of chromated copper arsenate
         (CCA), including play structures, decks, picnic tables, fencing, and patios;
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•  Established new restrictions for phosphine fumigants, prohibiting use around residential
   areas, increasing buffer zones for treatment around non-residential buildings that could be
   occupied by people or animals, and creating more protective product labeling;
•  Gave registration priority to reduced risk pesticides designed to replace or reduce reliance
   on more toxic pesticides (e.g., organophosphates and carbamates);
•  Established new safety measures for 10 rodent-control products to require that they be
   enclosed in bait stations, making the pesticides inaccessible to children;
•  Required label changes to indoor fogger products to reduce the potential for misuse; and
•  Mandated child-resistant packaging when certain toxicity triggers are met.

Future Activities:

Strategic Approach — Take aggressive  action to improve risk assessment/risk
management activities to better protect  children.

Specific Actions

Risk Assessment
• Expand Assessment Methods  — Expand scientifically based protections for infants and
  children by applying additional  safety factors for non-food use pesticides where data are
• Enhance Scientific Basis for Decisions — Improve consideration of children in the risk
  assessment process by seeking data on the transfer of pesticide residues to children and
  youth in pesticide-treated fields, the number and age distribution of youth under the age of
  18 working in agriculture, the extent to which non-working children are taken into pesticide-
  treated fields, and  the likelihood/extent of exposure from work in agricultural settings in
  addition to other sources of exposure;  and
• Increase Use of Incident Data — Increase scrutiny of incident data to identify areas of
  concern and take more targeted actions.

Risk Management
• Target High Risk Uses — Implement 2009 soil fumigants decision, focusing on  protecting
  children and others living, going to school, and working near fields treated with soil
  fumigants (e.g., buffer zones between  treated fields and schools);
• Address Risks of Concern — Take timely action on pesticides where data indicate an
  unacceptable risk to children; and
• Improve the Quality of Pesticide Labels — Work with states and manufacturers to ensure
  pesticide labels effectively convey use directions so pesticide users avoid unnecessary risk.
                                                                               Page 21

Regulatory Framework
     Focus of Activities - Establishing rules, regulations, and policies
     that promote the protection of children from pesticide risks.

     Effective implementation of regulatory decisions relies on a strong regulatory framework,
     including clear, focused, and effective rules, regulations, and policies.  Development and
     communication of these documents are crucial in educating pesticide registrants and users
     and changing behavior in a manner that promotes the safe use of pesticides. Many of the
     actions outlined in the risk assessment and risk management section were implemented by
     developing rules and regulations. In addition to those actions, OPP is engaged in additional
     areas that will positively affect protection of children's health.

     Current Protections:

     •  Assisting in the revision of national health and safety standards for child care centers,
        resulting in the development of more than a dozen new standards to address emerging
        environmental health issues; and
     •  Giving appropriate consideration to children's health issues when promulgating pesticide
        rules and regulations, including close coordination with EPA's Office of Children's Health
        Protection and non-governmental organizations in planning rule changes.
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                                             Future Activities:

                                             Strategic Approach — Address needs
                                             for improved regulatory framework to
                                             support children's health protection.

                                             Specific Actions
                                             •  Significantly Upgrade Rules on
                                             Worker Protection/Certification and
                                             Training — Propose amendments to
                                             Agricultural Worker Regulations (40
                                             CFR, Part 170) and  Certification and
                                             Training (40 CFR, Part 171) to increase
                                             the amount and nature of available
                                             pesticide safety information and improve
                                             the competency of those applying
                                             pesticides in environments where
                                             children may be exposed.
                                             •  Consider Impacts on Children in 25
(b) Product Performance Rules — OPP is focusing on 25(b) (or minimum risk) products,
such as insect repellents, to ensure that they are efficacious in protecting children from
                                                                       Page 23

Relevant Education/Training
        Focus of Activities - Implementing communication and training
        initiatives that effectively inform people, resulting in
        improvements to children's health through proper use of
        pesticides or techniques such as Integrated Pest Management

        OPP has made a significant investment in improving communication and training efforts
        related to children's health. Using the Internet, targeted media spots, and public service
        posters, OPP promotes a broad array of messages concerning the safe use of pesticides
        to diverse audiences.  EPA is also working with states, tribes, other federal agencies, and
        external organizations to improve available training opportunities in areas such as the
        use of IPM.

        Current Protections:

        •  Promoting IPM strategies  and supporting implementation of IPM in  the nation's
           school systems;
        •  Coordinating nationwide IPM training for affordable housing providers (Healthy
           Homes Initiative);
        •  Conducting public education campaigns  on (1) safe storage of pesticides (Lock It Up),
           (2) use of pesticides in child care centers (Play it Safe), and (3) the importance of
           adhering to pesticide labels directions (Read the Label First);
        •  Awarding 29 grants ($1.65 million) to address children's health issues through
           programs such as Pesticide Environmental Stewardship and Pesticide Registration
           Improvement Act partnerships;
        •  Targeting outreach to urban audiences, including Hispanic families, to raise
           awareness of potential pesticide risks, such as Spanish-language PSAs designed to
           educate parents who work in or near agricultural fields on the hazards of exposure to
           pesticide residues they may bring home; and
        •  Designing/launching websites with information on protecting children, sharing
           information on pesticides with children, and designing publications for parents/
           children on proper pesticide use.
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Futam Activities;

Strategic Approach — Take full advantage of opportunities to improve children's
health through education and training initiatives.

Specific Actions
•  Inform Health Care Providers — Publish a new edition of Recognition and Manage-
   ment of Pesticide Poisonings, a valuable resource for health care professionals
   whose patients include agricultural workers, in both English and Spanish;
•  Educate Parents — Support development of a curriculum to educate parents who
   work in agriculture about the risks to children from take-home exposure;
•  Enhance Web Pages — Strengthen Internet presence so information on issues such
   as bed bug or cockroach infestation or product performance/consumer labeling is
   more accessible; and
•  Utilize Social Media — Use social media to reach targeted  audiences with messages
   on pest control and the safe use of pesticides.
                                                                              Page 25

Timely and Targeted  Enforcement
       Focus of Activities - Coordinate with appropriate governmental
       authorities to ensure necessary action is taken, in a timely manner,
       to enforce pesticide laws where children's health and safety may be
       negatively affected.

       OPP's regulatory process is designed to ensure the safe use of pesticides when they are
       applied according to label directions. Any use not according to the label  is a violation of
       federal law and may endanger children, adults, or the environment. OPP works closely with
       EPA's Office of Enforcement and Compliance Assurance (OECA), EPA regional offices, and
       states/tribes to investigate misuse of pesticides that results in adverse effects to children,
       and assist in development and implementation of timely enforcement actions. OECA and
       OPP's parent organization (EPA's Office of Chemical Safety and Pollution Prevention)
       signed a Memorandum of Understanding that "establishes a framework for productive and
       efficient collaboration and cooperation" on enforcement issues.

       Current Protections:

       •  Expedited responses to pesticide exposure incidents where children's health was a
          concern (such as the deaths of two children in Utah in 2010 following improper
          applications of fumigant pesticides near the home) and learned from experiences with
          previous enforcement cases; and
       •  Improved coordination between EPA Headquarters and Regions to facilitate technical
          assistance and the exchange of information to support enforcement actions.
       Future Activities:

       Strategic Approach — Improve coordination with relevant entities to ensure timely and
       effective enforcement actions to address children's health issues.

       Specific Actions
       •  Strengthen Coordination on Enforcement Actions — Enhance coordination, quality of
          responses, and timing when supporting EPA, state, and tribal enforcement case
          development activities; and
       •  Raise  Visibility of Enforcement Actions— Work closely with OECA, EPA Regions,
          states, and tribes to identify cases with children's health impacts, raise visibility of
          enforcement actions related to children's health, and provide expertise to ensure the
          successful conclusion of enforcement cases.
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Strong Partnerships
Focus of Activities - Strengthening existing partnerships and
developing new relationships that will help  OPP provide greater
protection for children from pesticide risks.
While OPP is working diligently to protect children from risks associated with pesticide use, we are
only one of a number of partners whose work is crucial to success. To maximize protection efforts,
OPP has fostered working relationships with other parts of EPA, state and tribal authorities, other
federal agencies, and external stakeholders.  Partnerships already mentioned include -

•   Receiving consumption data for children from the CDC and data on agricultural workers from the
    Department of Labor and National Institute of Occupational Safety and Health;
•   Developing nationwide IPM training in coordination with HUD, requiring consideration of IPM use
    in public housing, and scoping out national IPM priorities with USDA's IPM Centers;
•   Working with PESP partners on issues related to children's health protection; and
•   Coordinating with child care providers to develop national health and safety standards.
 OPP is committed to continuing these collaborative efforts and developing new partnerships to take
 advantage of potential synergies  and enhance our children's health protection activities.

 Current Protections:

•   Using OPP's public participation process, developed as part of our effort to reregister pesticides, to
    collect better information from  the public on children's health risks;
•   Participating in a national disinfection workgroup, comprised of children's health professionals, to
    create a set of best-management practices for infection prevention in schools; and
•   Working with EPA's Office of Children's Health Protection to implement any recommendations
    from the Government Accountability Office on Agency efforts to address children's health issues,
    and helping re-establish the interagency task force on children's environmental health.

Future Activities:

Strategic Approach — Pursue partnerships that will enhance children's health protection.
Specific Actions
•   Improve Children's Health on Tribal Lands — Consult with the Tribal Science Council, which
    recently agreed to make children's health protection a priority issue;
•   Identify Issues of Concern — Coordinate with state/tribal regulatory partners to identify children's
    health issues of concern and include those issues in performance plans; and
•   Fund Research — Continue using grant funds to encourage research on children's health issues
    related to pesticide exposure.

 Overview of OPP Partnerships and Activities to Enhance Protection
                          of Children from Pesticide Risks
      Stakeholders/NGOs/General Public
             Scientific Community
Public Education, Migrant Support v.
Pesticide Environmental Stewardship Program
             :e Advisory Panel, lnde|
Work with PESP partners and administer grants to
address children's health issues

Focus on underserved and non-English speaking
populations through radio and print campaigns, such
as the dangers of take-home exposure

Develop applicator training/educational materials

Publish new edition of Recognition and Management
of Pesticide Poisonings
Implement Pest Management Strategic Plan for
School IPM

Coordinate with the medical community to improve
OPP's understanding of pesticide risks
              Governmental Partners

Consult SAP and others to ensure that OPP uses the
best available science and that risk assessments result in
decisions that are protective of human health and the
environment, particularly the health of children
Use cutting-edge science in areas such as:
   Approaches to tolerance reassessment -  including
   use of the FQPA 10x safety factor where appropriate
   Addition of comparative neurotoxicity studies to
   pesticide data requirements

   Revisions in general risk assessment process to
   provide greater consideration of potential impacts to
   children's health
                                                   •   Implementation of risk assessment methods to better
                                                      protect children in non-food regulatory actions
               Other EPA Offices
  States, Tribes, Federal Agencies (USDA, CDC,
                  HUD, HHS)
Support CDC survey to provide consumption data for
children and Department of Labor pesticide worker
safety survey to obtain pesticide incident data
Coordinate with states/tribes to identify children's
health issues

Implement soil fumigant decision with focus on
protecting children
Conduct nationwide IPM training through the Healthy
Homes Initiative (w/ HUD, CDC, USDA)

Work with Office of Head Start to help parents and day
care providers understand pesticide risks and how to
prevent risks to children
Compliance Assurance, General Counsel, Research
and Development, and Children's Health Protection
Expedite responses to child-related enforcement cases

Raise visibility of child-related enforcement actions

Implement endocrine disrupter screening

Enhance websites on product performance/consumer
labeling to help pesticide users make decisions that are
protective of children's health
Implement risk management decisions on fumigantj
rodent control products, methyl parathion, and CCA
                                                                                          Page 29

        M     he protection of children's health from the risk of pesticide use is a high
      -m      priority for OPP.  The Office is using available statutory authority and the
    recognition that children may be exposed to pesticides through multiple scenarios to
    focus activities in several core programmatic components. OPP is seeking to
    demonstrate the results of children's health protection activities by establishing children-
    specific measures in EPA's Strategic Plan and other performance accountability
    systems.  The actions detailed in this document collectively contribute to the mission of
    making children's health protection a routine part of OPP's programmatic activities.

    OPP continues to build on a strong record of protecting children by:

    •  relying on sound science,

    •  making regular improvements in the risk assessment and risk management
    •  establishing a strong regulatory framework,

    •  developing relevant communication and training initiatives,

    •  assisting in the timely and targeted implementation of pesticide statutes, and

    •  working  closely with current and future partners.

    For more general information on EPA's Office of Pesticide Programs, visit us on the Web
    at  For more specifics  on OPP's work to protect children
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