Phase out toxic fumigants

September 1, 2007

U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Dear EPA Scientists:

We join the United Farm Workers, the Pesticide Action Network, and other environmental groups in petitioning you to consider the following when deciding whether or not to allow re-registration of toxic and dangerous fumigant pesticides:

1. Initiate a permanent phase-out of key soil fumigant pesticides and insist that any chemical replacements pass very stringent tests for toxicity. All such chemicals are extremely dangerous to human health and the general environment. It is impossible to manage adequately all the risks associated with their use. Whole communities have been poisoned by such substances. Workers are routinely exposed and their health is often permanently damaged.
2. Cancel the registration of methyl bromide, ending a serious human health hazard for many thousands of farm workers and nearby communities and eliminating a major threat to the stratospheric ozone layer.
3. Work collaboratively with USDA to ensure that farmers receive assistance and support while transitioning to least-toxic pest management methods that do not require use of toxic fumigants.
4. During the process of phasing-out these toxic fumigants, please enact and implement regulations that protect workers and communities from all potentially harmful exposures. This needs to include buffer zones, community notification, funding for air monitoring near fumigated sites, and on-site monitoring in fumigated fields in order to protect workers.
5. In particular, fumigants such as methyl bromide, metam sodium, chloropicrin, dazomet and telone pose grave threats to the health and safety of farm workers. These are among the most toxic agricultural chemicals in use today and are responsible for causing birth defects, cancer, Parkinson’s disease and acute poisonings. Fumigant drift has resulted in mass poisonings in areas of high use, often causing the evacuation of hundreds of people from their homes and sending many to the hospital.
6. Fumigants are extremely volatile and therefore substantial contributors to ozone-producing volatile organic compounds (VOCs) that pollute the air. Methyl bromide especially erodes the stratospheric ozone layer that protects the earth from the sun’s ultraviolet rays.
7. All fumigants are difficult to apply without making mistakes, which can have devastating effects on individuals and whole communities.
8. As you evaluate these chemicals and consider re-registration under the Food Quality Protection Act of 1996, you must take this opportunity to enact landmark regulations to protect all of America’s farmworkers, rural communities and the environment.

We thank you and sincerely urge the U. S. Environmental Protection Agency to use its full authority to phase-out fumigants, establish protective mitigation measures during phase-out, and give incentives to farmers to transition away from all fumigants as a pest control strategy.

Sincerely,

Tracy Wolpert
Chief Executive Officer