Background Paper for Candidate National Enforcement Priority: Pesticides Use at Day Care Facilities January 2010 Why is pesticide use at day care facilities a concern? Pesticides that are not used or applied properly can result in harm to both human health and the environment. Many day care facilities engage in the use of pesticides both inside and outside of their facilities. Indoors, pesticides are typically employed to control insects and rodents but are seeing increasing use as antimicrobials in disinfection practices implemented as part of flu prevention programs. Outdoor use includes insect control and lawn care activities such as weed, insect, and animal control. Both general use pesticides that can be applied by anyone and restricted use pesticides that may only be applied by certified applicators are in use at these facilities. A joint study between the U.S. Department of Housing and Urban Development, the U.S. Consumer Product Safety Commission and the U.S. Environmental Protection Agency characterized the environments of young children (<6 years) by measuring lead, allergens, and pesticides in a randomly selected nationally representative sample of licensed institutional child care centers. Field technicians spent about four months in 2001 wiping samples from indoor surfaces, such as floors, desks and tables, and scraping up soil from outdoor play areas from all the centers. Center directors were also quizzed about cleaning practices and pesticide use. At least one pesticide was found in every daycare center studied. Pesticides were used up to 107 times annually. A large variety of pesticides were used, with centers employing up to 10 different kinds. The most commonly found pesticides were chlorpyrifos, diazinon, and permethrin. Chlorpyrifos and diazinon are organophosphates, which kill insects by disrupting their brains and nervous systems and can harm the brains and nervous systems of animals and humans. Permethrin attacks the nervous system and is possibly a carcinogen. Since the study was first conducted, chlorpyrifos and diazinon were banned by the EPA for use in daycare centers, homes and nearly all indoor locales. Rationale: Environmental Risks/Significant Environmental Benefit With bodies that are still developing, children and infants are some of the groups most vulnerable to pesticides. Pesticides pose greater risks to children than adults for a variety of reasons. Children's bodies are much smaller than adults and pesticides have a greater potential of affecting them at sensitive stages of their physical and mental development. In addition, children spend more time outside crawling on the ground and putting things in their mouth, which makes them more susceptible to pesticides that drift to the ground. There are many well-documented health impacts to fetuses and children who are exposed to pesticides. Studies have shown that exposure to certain pesticides can lead to malformed genitalia, lower birth weights, and other developmental defects in fetuses, while young children can suffer from lower IQs, a potentially greater risk of autism, and acute effects such as vomiting, seizure, and even death. 1 ------- Non-compliance Data EPA has not conducted sufficient inspections in this sector to identify a pattern of noncompliance. However, anecdotal evidence such as reported pesticides exposure incidents and calls/referrals to state and local health departments suggest that a pattern of noncompliance may exist since pesticides exposures should not be occurring if label directions were properly followed. Federal Government Role EPA is well suited to take this action as it is national in scope and addresses the Administrator's priority of protection of a vulnerable population. Detecting violations across the nation in a uniform approach envisioned by this initiative will send a strong enforcement message to day care facility owners and operators and commercial pesticides applicators thereby leveraging resources for this comprehensive enforcement and compliance assistance national initiative. Another federal role is capacity building for the states to enable them to develop outreach materials, target for, and inspect these facilities. In addition, a clear Federal role is justified by the number of day care facilities that are owned by companies operating facilities in many different regions across the nation. 2 ------- |