Protecting
Children's Health
THE NATIONAL PESTICIDE PROGRAM
D
Introduction
Page 3
Mission
Statement
Page 4
Statutory
Authority
Page 5
Multiple Risk
Exposure
Scenarios
Page 6
Core
Programmatic
Components
Page 14
Strong
Partnerships
Page 28
Conclusion
Page 30
United States
Environmental Protection
Agency
Office of Pesticide Programs (7506P)
Washington, DC 20460
EPA-735-K-10-001
October 2010
www.epa.gov/pesticides
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Introduction
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.
til
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
control
technologies."
Steve Owens,
Assistant Administrator,
EPA's Office of Chemical Safety
and Pollution Prevention
Page 3
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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.
Core
Programmatic
Activities
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
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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
gaps.
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
process.
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.
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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
pathways.
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
children;
Given priority to registration applications for pesticides that pose less risk to
human health and the environment than existing conventional pesticide
alternatives;
Improved risk assessments to better characterize potential exposure to children
and account for children's behavior (e.g., crawling and placing objects in their
mouths).
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.
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Page 8
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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
schools.
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.
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Page 10
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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.
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Page 12
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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.
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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
1
EnhancedP
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)
6
Strong
Partnerships
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
concern
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.
5
Timely and Targeted Enforcement
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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
2
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
development
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
exposure
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
3
Regulatory
Framework
Enhance websites on product performance and consumer labeling
to help users make better decisions to protect children
Revised educational materials for health care
providers:
> Recognition and Management of Pesticide
Poisonings
4
Relevant Education and Training
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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
fields;
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
children.
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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2
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
children.
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
incomplete;
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.
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3
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:
I
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
insects.
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4
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
(IPM).
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.
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5
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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6
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.
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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|
Reviews
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
e
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
EPAR<
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
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Conclusion
T*.
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
processes,
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 http://www.epa.gov/pesticides. For more specifics on OPP's work to protect children
seewww.epa.gov/pesticides/health/children.htm.
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