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Welcome to PSR's Environmental Health Policy Institute, where we ask questions -- then we ask the experts to answer them. Join us as physicians, health professionals, and environmental health experts share their ideas, inspiration, and analysis about toxic chemicals and environmental health policy.


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Advocating for Policy Change to Require Clinical Diagnostic Tools and Biomonitoring of Exposures to Pesticides

Posted on August 24, 2011

By Amy K. Liebman, MPA and Matthew C. Keifer, MD MPH

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 or rejected.  

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 enforced.18,19

Unlike OSHA, 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 registrant.

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 12, 2010.

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. 1999;114(5):459–468.

19. US 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 31, 2010.

20. Silverstein 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, 1995;60(148).  Accessed June 14, 2010.

22. Skeers V, Morrissey B. Acute organophosphate pesticide poisoning in Washington orchards. J Env Health. 1995;58(2):18–23.

23. Martin, P. Immigration Reform: Implications for Agriculture. Agricultural and Resource Economics Update. Davis, Calif: University of California, Giannini Foundation; 2006.

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.


Alyssa Owens said ..

It is important to have unbiased opinion when testing industrial product. It is absurd to leave testing up to the manufacturers who stand to profit... Big business does not care that pesticides are harmful to our health and to the health of the environment. It is time for the manufacturers to have the burden of proof. The Precautionary Principle is imperative because most synthetic pesticides are toxic and in very small amounts and all of us are exposed to them unless we live in a bubble.

September 21, 2011
Walter Jones said ..

The Occupational Health and Safety Section of APHA, known for its 95 years of worker health and safety advocacy, believes that burden of developing standardized human exposure detection methods should be undertaken by pesticide manufacturers and not the public. For many of these international producers, this request is consistent with the European REACH requirements to provide hazard identification, risk assessment and risk abatement measures for their products.

August 25, 2011

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