Pesticide Action Network Updates Service (PANUPS)
The neurotoxin endosulfan is rated by EPA as a Category I pesticide with Extremely High Acute Toxicity. Health effects of accidental exposure include central nervous system disorders such as dizziness, convulsions and loss of consciousness. Endosulfan exposure has been linked to dozens of deaths in the U.S. and around the world, and there is strong evidence that it is an endocrine disrupting chemical.
Classified as an organochlorine (the same family of pesticides as DDT and dieldrin), endosulfan and its breakdown products are persistent in the environment, with an estimated half-life of nine months to six years. It is known to bioaccumulate in humans and other animals, collecting particularly in the liver, kidneys and fatty tissue.
According to EPA, endosulfan is currently registered to control insects and mites on 60 U.S. crops, including many fruits and vegetables as well as alfalfa, barley and Christmas trees. Three crops account for more than 50% of endosulfan use in the United States: pecans, honeydew melons and strawberries.
According to EPA's risk assessment, U.S. farmworkers face significant health risks from endosulfan exposure. Twelve of the 21 worker exposure scenarios examined found exposure levels "of concern" to the agency. The actual risk to workers is likely to be even higher than EPA estimates. The agency's analysis underestimates worker exposure by considering potential exposure routes (skin and breathing) separately, rather than calculating the more accurate cumulative exposure.
An analysis of endosulfan's impact as an endocrine disruptor is entirely omitted from the risk assessment. While the agency recognizes that "available scientific literature suggests that endosulfan may act as a potential endocrine disruptor," it postpones consideration of this risk until the agency's new Endocrine Disruptor Screening Program is in place. EPA documents state that the Screening Program is scheduled to be in place "in 2001," but there are no indications that the program will be implemented before the end of the year.
Also postponed is the cumulative risk assessment required under the U.S. Food Quality Protection Act (FQPA). FQPA requires that EPA consider the cumulative effects of chemicals that have "similar mechanisms of toxicity." The agency does not include this cumulative assessment because it has "not yet initiated a review to determine if there are any other chemical substances that have a mechanism of toxicity common with that of endosulfan."
Despite these weaknesses and omissions, EPA's risk assessment provides ample evidence that the re-registration of endosulfan represents an unacceptable risk to public health. In addition to the significant occupational exposure risks, endosulfan and its breakdown products are found in water samples in 38 states and in both imported and domestic foods. Dozens of poisoning incidents document the risks of endosulfan exposure both in the U.S. and abroad.
Endosulfan is banned in many countries, including Colombia, Germany, Denmark, Sweden, Belize, Netherlands, Singapore and the Indian state Kerala. There are strong restrictions in many other countries, including Canada, Finland and Kuwait.
ACTION: Submit your comments to EPA on their risk assessment and re-registration decision for endosulfan on or before Tuesday, November 13, 2001. EPA's endosulfan re-registration and risk assessment documents are available on line at http://www.epa.gov/pesticides/reregistration/endosulfan/.
Send emails to firstname.lastname@example.org, with OPP-34242 in the subject line, or send a letter referencing Docket No. OPP-34242 to:
Ms. Christine Todd Whitman, Administrator
1) EPA underestimates occupational exposure by considering dermal and inhalation routes of exposure separately, rather than cumulatively. Despite this underestimation, occupational exposures are unacceptably high.
2) Given the significant evidence available that endosulfan has endocrine disrupting affects, EPA's risk assessment will not be adequate until these affects are considered.
3) FQPA requires that EPA consider the cumulative effects of chemicals with similar mechanisms of toxicity. By neglecting this cumulative assessment, EPA is not fulfilling its obligations under the law.
4) Many countries have banned endosulfan out of concern for its health and environmental effects, and have found and implemented safer alternatives.
5) Given the clear and substantial evidence of risk to public health, EPA should not re-register endosulfan for use in the United States.
Sources: EPA risk assessment and re-registration documents for endosulfan, available at http://www.epa.gov/pesticides/reregistration/endosulfan/; PAN-UK News Release "Endosulfan concerns are global: New ban in Colombia," November 4, 2001; PAN's Pesticide Database, http://www.pesticideinfo.org.