Advocating for Policy Change to Require Clinical Diagnostic Tools and Biomonitoring of Exposures to Pesticides
August 24, 2011
This essay is in response to: How does our nation's reliance on pesticides affect the health of those who plant and harvest our food?
In 2010, the American Public Health
Association (APHA) passed a policy resolution urging the US Environmental
Protection Agency (EPA) to require pesticide manufacturers to develop methods
for detecting human exposure to their chemicals. The resolution highlights a growing
effort among clinicians, researchers, and advocates to better protect farmworkers
and other populations overexposed to pesticides. The policy statement, “Requiring
Clinical Diagnostic Tools and
Biomonitoring of Exposures to Pesticides,”
is excerpted below.
The effort of preparing and obtaining
APHA endorsement for a policy resolution is an effective way to articulate an issue
that can be used in broader advocacy efforts. APHA members draft a statement for
review and endorsement either as an individual or as a section. It is then submitted
to the APHA Joint Policy Committee (JPC) and undergoes rigorous peer-review.
The authors and others are given an opportunity to respond to reviewer comments
and revise. Once accepted by the JPC, together with their section, the authors
seek endorsement from other sections and caucuses to garner support and educate
APHA members about the resolution. At the annual APHA meeting, all resolutions
are discussed at an open hearing of the Governing Council (comprised of the elected
members of all APHA sections and state-affiliates) and ultimately either passed
APHA and its state affiliates
represent over 50,000 health professionals and others who work to promote
health and prevent injury and disease. Public policy statements adopted through
this process provide the basis of the Association's stance on public health
issues. A policy statement endorsed by the largest public health organization
in the nation is a powerful tool in continuing efforts to promote an issue. We
are members of APHA’s Occupational Health and Safety Section and drafted Requiring
Clinical Diagnostic Tools and
Biomonitoring of Exposures to Pesticides. We continue to use this and other policy statements in efforts to
advocate for better protection of workers. The topic of biomonitoring will be
addressed by EPA during a day-long meeting in Washington, DC
on October 11, 2011. For more information on this meeting click here.
The following is an excerpt
of “Requiring Clinical Diagnostic Tools
and Biomonitoring of Exposures to Pesticides, APHA Policy 20108”. The full resolution is available here.
The EPA is responsible for the welfare of workers
exposed to pesticides in the agricultural workplace, farmworker families, and
the health of the public with respect to pesticides in food and the
environment.14–16 The EPA’s authority to oversee farmworker
protection from pesticide exposure can be found in its regulatory authority
under the Federal Insecticide Fungicide and Rodenticide Act of 1972 (FIFRA).14
FIFRA mandates that EPA, and not the Occupational Safety and Health
Administration (OSHA), promulgate the regulatory standards to protect workers
and their families from pesticide exposure.14,17 Consequently, EPA
and its designated state regulatory agencies oversee the worker protection
standard (WPS), the primary regulatory standard that mandates workplace
protection for hired agricultural laborers. The WPS involves pesticide safety training, notification of
pesticide applications, use of personal protective equipment, restricted entry intervals
after pesticide application, decontamination supplies, and emergency medical
assistance.16 It is notably weaker than similar regulatory
standards for occupations other than agriculture, and the WPS is poorly
which in multiple standards requires that employers conduct medical monitoring
of workers exposed to harmful substances,20 EPA has no requirements
for monitoring of workers exposed to pesticides. An essential component of the
information that EPA uses to make decisions about the removal or restriction of
use of a pesticide once on the market is information from surveillance systems.21
Several toxic pesticides have lost registration in the United States largely because of
the information available to EPA through surveillance of pesticide poisonings.
Examples include ethyl parathion and mevinphos.22 However, the
ability of clinicians to report exposures through pesticide illness
surveillance systems depends on their ability to diagnose pesticide poisonings.
With the introduction to the marketplace of new pest-specific chemicals,
diagnosis of human overexposure becomes even more difficult, because no human
data on the health effects of these chemicals exist.23 Cholinesterase
activity, a marker of overexposure to organophosphate and carbamate pesticides,
offers the only easily available confirmatory test for pesticide poisoning, and
this marker is nonspecific. Washington and California require
cholinesterase biomonitoring for pesticide applicators. These biomonitoring
programs have been of substantial value in reducing overexposure by removing
workers from ongoing exposure24,25 and identifying flaws in the
system of worker protection.25
APHA recommends that EPA require pesticide registrants, as a
requirement for registration, to develop and provide to the public—
- A sensitive and specific
diagnostic test or biomonitoring tool to detect either chemical-specific levels
in humans, the human health effects caused by their exposures, or both
- A sensitive diagnostic test or biomonitoring tool to detect their chemical or
its effects in human beings, the cost of which will be covered by the
14. The Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) of 1972; 7 USC §§136 et seq. (1972). Accessed
June 12, 2010.
15. Food Quality Protection Act of 1996 (FPQA). Pub L No.
104-170). Accessed June
16. The Worker Protection Standard. 40 CFR §170. Accessed June 12, 2010.
17. Organized Migrants
in Community Action, Inc. v Brennan. 520 F.2d 1161 (1975).
18. Arcury TA, Quandt SA, Austin CK, et al. Implementation of EPA’s Worker Protection
Standard training for agricultural laborers: an evaluation using North Carolina
data. Public Health Rep.
General Accounting Office. Pesticides: improvements needed to ensure the safety of farmworkers and their children. GAO/RCED-00-40. Washington,
DC: US General Accounting Office;
2000. Accessed March
M. Analysis of medical screening and surveillance in 21 Occupational Safety
and Health Administration standards: support for a generic medical surveillance
standard. Am J Ind Med. 1994;26(3):283–295.
21. Mevinphos. Proposed Amendment and Revocation of Tolerances. Federal
Register. August 2,
Accessed June 14, 2010.
22. Skeers V, Morrissey B. Acute organophosphate pesticide
poisoning in Washington
orchards. J Env Health.
23. Martin, P. Immigration Reform: Implications for
Agriculture. Agricultural and
Resource Economics Update. Davis, Calif: University of California, Giannini
24. Ames RG,
Brown SK, Mengle DC, et al. Cholinesterase activity depression among
California agricultural pesticide applicators. Am J Ind Med. 1989;15(2):143–150.
25. Hofmann JN,
Keifer MC, De Roos AJ, et al. Occupational determinants of serum
cholinesterase inhibition among organophosphate-exposed agricultural pesticide
handlers in Washington State.
Editor's note: if
you'd like to take action on pesticide policy, click here.