Read the interview.
Milton “Tito” Rafael Barreto Hernandez, 22, suffered fatal traumatic injuries on Tuesday, October 28, while working for Scott Materials in Scott, Louisiana. KLFY provides some initial information on the worker’s death:
- His employer, Scott Materials, is a “concrete crushing company.”
- A supervisor and another employee were with Hernandez when the accident occurred.
- They were working to remove debris from a conveyor belt on a piece of heavy machinery. The equipment was turned back on and Hernandez was pulled into the machine.
OSHA’s on-line inspection data suggests Scott Materials has not been subject to an OSHA inspection.
Each year, more than 100 workers in Louisiana are fatally injured on-the-job. The Bureau of Labor Statistics reports 114 work-related fatal injuries in Louisiana during 2013 (preliminary data, most recent available.) Nationwide, at least 4,405 workers suffered fatal traumatic injuries in 2013.
The AFL-CIO’s annual Death on the Job report notes:
- Federal OSHA has 16 inspectors in Louisiana to cover more than 103,000 workplaces.
- The average penalty for a serious OSHA violation in Louisiana is $1,765.
Federal OSHA has until the end of April 2015 to issue any citations and penalties related to the incident that stole Tito Hernandez’s life. It’s likely they’ll determine that Hernandez’s death was preventable. It was no “accident.”
Study engages residents in collecting air samples around fracking sites, finds high levels of dangerous chemicals
A recent study of air quality around unconventional oil and gas extraction sites — more commonly referred to as fracking — found high levels of benzene, hydrogen sulfide and formaldehyde, all of which pose risks to human health. But what makes this study particularly interesting is that the air samples were collected by the very people who live near the extraction sites, and the collection times were specifically triggered by the onset of health symptoms.
Published yesterday in the journal Environmental Health, the study involved residents living near 11 unconventional extraction sites in five states: Wyoming, Arkansas, Pennsylvania, Colorado and Ohio. The residents involved in the study were trained to take a “grab air” sample using an inexpensive bucket outfitted with a battery-operated vacuum pump that sucks in air over two to three minutes. (The study authors noted that the bucket device has been subjected to numerous validation tests by public agencies and independent labs.) In addition to the grab air samples, residents were also given a device to measure formaldehyde levels. (That device is called the UMEx100 Passive Sampler and almost looks like an USB flash drive with a clip on it — here’s a picture.) In all, residents put out 41 formaldehyde badges near production facilities and compressor stations.
Residents ended up collecting 35 grab air samples in areas of particular community concern and “under conditions that would lead them to register a complaint with relevant authorities such as a county public health department or state oil and gas commission,” the study stated. Twenty-nine of the samples were taken in direct response to health symptoms, with the most common symptoms being headaches, dizziness, irritated, burning or running nose, nausea, and sore or irritated throat. Air samples were then tested for 74 volatile organic compounds, and formaldehyde samples were analyzed using a method recommended by the U.S. Environmental Protection Agency.
Ultimately, the study found that 16 of the 35 grab air samples and 14 of the 41 formaldehyde tests surpassed minimal risk levels set by EPA and the U.S. Agency for Toxic Substances and Disease Registry, with the three chemicals most commonly found to exceed such levels and which are linked to human disease being benzene, hydrogen sulfide and formaldehyde. Benzene, in particular, was detected at sample locations in Pennsylvania and Wyoming in concentrations that exceeded recommended safe levels “by as many as several orders of magnitude,” wrote the authors, who noted that benzene is a known human carcinogen.
In fact, some air samples had benzene levels that ranged from 35 to 770,000 times higher than background levels (defined as levels that researchers would expect to find naturally), according to a news release about the study. To put that in perspective, the study found benzene levels that were up to 33 times the concentration exposure a person gets when pumping gas. Here’s another comparison from the study’s authors: The benzene exposure a person would experience at one study site in Wyoming would be equal to the exposure of a person living in Los Angeles for two years or Beijing for nearly nine months.
For hydrogen sulfide samples that exceeded recommend levels, study results ranged from 90 to 60,000 times higher than background levels — concentrations that can cause eye and respiratory tract irritation, fatigue, loss of appetite, headache, irritability, poor memory and dizziness. In analyzing the formaldehyde samples that exceeded recommended safe levels, the study found that they were 30 to 240 times higher than background levels. In some cases, the formaldehyde concentrations were more than twice the concentrations found in rooms in which medical students dissect cadavers.
The study authors did note that while the samples taken during the study may reflect a “worst-case concentration,” engaging residents who are directly affected by unconventional oil and gas extraction can benefit long-term research on the topic.
“Community-based monitoring near unconventional oil and gas operations has found dangerous elevations in concentration of hazardous air pollutants under a range of circumstances,” said study author David Carpenter, director of the Institute for Health and the Environment at the University of Albany. “In this study, we have shown that community-based research can improve air quality data while adhering to established methods. Our findings can be used to inform and calibrate state monitoring and research programs.”
To read the full study, visit Environmental Health.
Kim Krisberg is a freelance public health writer living in Austin, Texas, and has been writing about public health for more than a decade.
OSHA proposed serious and repeat violations yesterday to Wayne Farms for a variety of safety hazards, including those that led to musculoskeletal injuries among the company’s poultry processing workers. By my calculation, it was the first time in more than a decade that the Labor Department used its “general duty clause” to cite a poultry company for ergonomic hazards.
OSHA conducted the inspection in response to a complaint filed six months ago by the Southern Poverty Law Center on behalf of a group of workers. The complaint described the harsh working conditions in the Jack, Alabama plant, and also provided specifics on management’s retaliation against workers who are injured or complain about hazards. The workers involved in filing the complaint should feel vindicated because OSHA’s citations validate their assertions.
OSHA’s investigation involved staff from its Mobile, Alabama and Atlanta, Georgia offices, as well as the agency’s top-notch ergonomist and occupational medicine physicians. They note that workers in the plant are required to perform:
“prolonged repetitive, forceful tasks, often in awkward postures for extended periods of time.”
Those tasks include cutting wings, cutting shoulders, sawing wins, pulling skin, and pulling tenders.
The OSHA team also identified gross deficiencies in the company’s lockout/tagout procedures. Such safeguards can help to ensure that workers were not caught-in or struck-by equipment when it is being cleaned or repaired. That’s bad enough, but Wayne Farms was cited by OSHA in 2011 for this same violation at one of the company’s other poultry processing plants. For the repeat infraction, OSHA has proposed a $38,500 penalty.
Besides validating the workers’ complaints, OSHA’s citations corroborate what researchers and worker advocates have been saying for decades: Injury rates based on employer self-reporting are works of fiction. OSHA assembled evidence against Wayne Farms on the ways in which the company gamed the system for recording injuries. OSHA’s Mobile, Alabama area director said,
“By failing to report injuries, failing to refer employees to physicians and discouraging employees from seeking medical treatment, Wayne Farms effectively concealed the extent to which these poultry plant workers were suffering work-related injuries and illnesses. And as a result, it reported an artificially lower injury and illness rate.”
I have no doubt that other poultry and meatpacking companies use the same dishonest practices to intentionally deceive the Labor Department and the public about working conditions in their plants. If you haven’t already, you should dismiss any assertions made by the National Chicken Council and other industry groups that poultry slaughtering plants are safe and worker injury rates low. That goes for the safety award given to Wayne Farms in 2011 for its “outstanding safety performance.” The company touts its behavior-based safety program called “WorkSAFE” which
“focuses on helping employees identify unsafe behaviors and remain conscious of their environment and potentially dangerous situations.”
What a bunch of baloney. Workers at Wayne Farms know what causes their injuries. It’s not their “unsafe behaviors.” It’s all about the incessant repetitive motions, fast work pace and deficient equipment in their jobs. These are all things that the company controls, not the workers. The “unsafe behaviors” are the company’s not the workers’.
For me, some of the most powerful language in the OSHA citations is the long list of feasible options the agency offers Wayne Farms to fix the ergonomic hazards. For workers in the chicken deboning area, OSHA explains that the company could:
- increase the recovery of affected body parts through task rotation during the work shift (rotation to tasks without continuous use of a knife, scissors or forceful grip);
- increase recovery time through implementation of mini-breaks, increase cycle time for each task, establish a rotation on a daily basis between departments to increase recovery time (such as rotation between debone and marination);
- provide knives with handles designed for repetitive tasks;
- provide hand tools with textured handles to reduce employee grip force, larger quillons (guard) before the blade to prevent hand from sliding down knife-allowing reduced grip force;
- install mechanical skin removal equipment or provide textured gloves to reduce hand force required in pull skin;
- provide air-assist powered scissors or wing cut;
- position the knife sharpener to minimize non-neutral wrist posture; and
- evaluate employees at each station to determine appropriate work platform height for each employee.
Surely, a firm with more than $1.9 billion in annual sales can afford buying some better hand tools and giving workers rest breaks.
Michelle LaPointe, senior staff attorney with SPLC remarked about the OSHA citations:
“The actions taken by the Occupational Safety and Health Administration go far beyond a company being fined for violations at a single poultry plant,” said Michelle Lapointe, SPLC senior staff attorney. …This is an industry where workers are forced to work at dangerously fast speeds that cause disabling injuries and often thrown away when they can no longer work.”
In a statement to Dave Jamieson of the Huffington Post, Wayne Farms said it is contesting the citations.
OSHA has taken an important step with these citations. It was Labor Secretary Elizabeth Dole in the late 1980’s that put citations for ergonomic hazards on the radar screen. Use of the general duty clause was embraced at the time, but largely abandoned over the last decade. Our government has failed to hold poultry companies accountable for the workplace hazards that cripple the hands, wrists, shoulders and backs of workers. I hope these citations are not an anomaly, but a sign of much more attention to the deplorable working conditions in poultry and meatpacking plants.
Raising the federal minimum wage isn’t only good for workers — it’s good for the federal budget as well, according to a new issue brief from the Economic Policy Institute.
Released earlier this month, the policy brief details just how many low-wage workers have to depend on public assistance programs to make ends meet and how increasing the minimum wage could save billions in federal spending — and those billions could be redirected toward creating stronger, more resilient anti-poverty programs. The brief reports that about half of all workers earning less than $10.10 per hour, the new minimum wage proposed in the federal Fair Minimum Wage Act of 2013, receive public assistance either directly or through a family member via programs such as Medicaid, the Earned Income Tax Credit, the Supplemental Nutrition Assistance Program (also know as SNAP and formerly known as food stamps), the Low Income Home Energy Assistance Program, the Supplemental Nutrition Program for Women, Infants and Children (WIC), the Section 8 Housing Choice Voucher program and the Temporary Assistance for Needy Families program. All of that adds up to more than $45 billion in government assistance each year.
“Essentially, low-wage employers are being subsidized by the taxpayer,” said brief author David Cooper in a news release. “Prices are going up, but paychecks are not, and taxpayers are making up the difference. We’ve long known that raising the minimum wage would help millions of workers and give the economy a boost — now we know it’s a winning idea for taxpayers, too.”
If the minimum wage went up to $10.10, which the federal legislation would do over the span of three years, more than 1.7 million Americans would no longer have to rely on public assistance to meet their basic needs. In fact, the policy brief reported that going up to $10.10 an hour would lower government expenditures by $7.6 billion each year — and that’s a conservative estimate. Overall, safety net programs would save 24 cents for every additional dollar in wages paid to workers who benefit from the minimum wage increase. Right now, accounting for inflation, the current federal minimum wage of $7.25 is about 25 percent less than the minimum wage in 1968. Cooper, an economic analyst, writes:
This failure to adequately raise the wage floor has contributed strongly to the stagnation of wage growth at the bottom of the wage distribution. This wage stagnation has, in turn, been the single greatest impediment to making rapid progress in poverty reduction in recent decades. Indeed, all of the decline in poverty reduction in recent decades can be accounted for by safety net and income-support programs. In fact, managers at some of the largest and most profitable corporations in the United States today actively encourage their employees to seek public assistance to supplement meager paychecks. All of this has led many to conclude that American employers are too often dodging their responsibilities as partners in the social contract — the understanding that Americans who work hard should be paid enough to make ends meet. Instead, too many low-wage employers are leaving both taxpayers and, more importantly, low-wage workers themselves to pick up the slack.
The policy brief examines two methods for estimating how a minimum wage change would affect enrollment in public assistance programs. The first is known as a quasi-experimental design or natural experiment and compares a labor market that did increase the minimum wage to a similar labor market that did not. In this case, Cooper cites a study that examined the effects of a minimum wage increase on SNAP enrollment and spending. That study found that a 10 percent increase in the minimum wage reduced SNAP enrollment by between 2.4 and 3.2 percent and reduced SNAP expenditures by 1.9 percent.
The second research method is known as the simulation method, in which researchers estimate how benefit expenditures would change as hourly wages change, with all else remaining the same. Using this method, Cooper compared the receiving of public assistance among low-wage workers to higher-wage workers and estimated how a raise in the federal minimum wage to $10.10 would affect the use of public assistance programs. He found that increasing the minimum wage would provide about $32 billion in additional wages to more than 27 million workers, which “would unquestionably improve living standards for millions of working families.” He also found that a $1 hourly wage increase would be expected to reduce the average annual benefit dollars received from all safety net programs by $126 per affected worker. In total, a minimum wage raise could save the nation $7.6 billion in safety net spending.
Cooper noted in his conclusion that the safety net programs explored in the brief are critical for struggling families and “if anything, these programs are in need of expansion.” However, he also wrote that it’s time to call on employers to do a better job.
“As American businesses achieve record profit levels, we have to question whether it is appropriate to rely more and more heavily on safety net programs as the sole policy tool to raise working individuals’ incomes or whether we should expect more from the businesses that employ them,” Cooper writes.
To download a full copy of the policy brief, “Raising the Federal Minimum Wage to $10.10 Would Save Safety Net Programs Billions and Help Ensure Businesses are Doing Their Fair Share,” visit the Economic Policy Institute.
Kim Krisberg is a freelance public health writer living in Austin, Texas, and has been writing about public health for more than a decade.
A new Data Note about Kaiser Family Foundation survey findings highlights how this country’s lack of nationwide paid sick leave places a disproportionate burden on women with children – and is particularly hard on low-income mothers. In Balancing on Shaky Ground: Women, Work and Family Health, Usha Ranji and Alina Salganicoff begin by noting that 70% of mothers with children under 18 are in the labor force. Then they report the results of survey questions on who takes charge of children’s healthcare and whether they have paid leave time to fulfill these responsibilities.
The 2013 Kaiser Women’s Health Survey (I wrote about some of its other findings here) and the 2013 Kaiser Men’s Health Survey asked respondents with children under 18 questions about who usually takes children for doctors’ appointments and cares for sick children. Eight-one percent of mothers reported that they’re usually the ones taking children for doctor’s appointments, and 39% said they’re usually the ones to take care of sick children (another 33% said it’s a joint responsibility). Among fathers, 16% responded that they usually take children for doctor’s appointments. And just three percent of fathers reported that they are usually the ones to take care of a sick child. Another 42% said it’s a joint responsibility.
“Caring for children’s health has tangible economic consequences, especially for women,” Ranji and Salganicoff write. Of the 39% of working mothers who must miss work to care for sick children, 60% of them report that they don’t get paid for the time they have to take off. And this percentage is significantly higher than the 45% of respondents who reported in the 2004 survey that caring for a sick child means missing out on pay.
The Data Note doesn’t speculate on why we’re seeing this increase in the percentage of working mothers who don’t get paid for the time they spend out of work caring for sick children. My guess is that the recent economic downturn and uneven recovery have left more women working in jobs that don’t offer paid sick leave. There’s a clear pattern to what kinds of jobs those are.
The third set of statistics in the Data Note adds to existing evidence that women who have lower incomes and work part-time are less likely to get paid sick leave from their employers. Seventy-one percent of working mothers with incomes at or above 200% of the federal poverty level report that their employers offer them paid sick leave, compared to just 36% of working mothers with incomes below 200% FPL. Seventy percent of full-time workers, compared to 25% of part-time workers, report having this benefit.
A recent analysis of the 2013 National Health Interview Survey by the Institute for Women’s Policy Research found that only 21% of workers in Food Preparation and Serving Related occupations and 28% of workers in Personal Care and Service reported having paid sick leave. To limit the spread of disease, it’s important for food workers and childcare providers to be able to stay home when they have the flu or another transmissible illness. When missing work means losing pay, however, many workers can’t afford to stay home and recover from their own illness, or care for a child who’s home sick from school. This is one of the reasons the American Public Health Association has adopted a policy statement calling for the US to improve access to paid sick and family leave.
The good news is that voters and legislatures across the US are acknowledging that if we want to encourage both work and good parenting, we need to make it possible for workers to stay home to recover from an illness or care for a sick child. Several cities have passed laws requiring employers to let workers earn paid sick time, and last month California became the second state to mandate paid sick days. (Connecticut was the first, although its law only applies to businesses with 50 or more employees.) Next week, Massachusetts voters will determine the fate of a ballot measure requiring paid sick days statewide.
I’m hopeful that in future Kaiser Family Foundation surveys we’ll see fewer working mothers reporting that they don’t get paid for time spent caring for sick children, and a disappearing gap in paid-sick-leave access between lower- and higher-income women. That would be good news for working women, and for public health.
Despite substantial public opposition and the “grave concerns” of about 50 members of Congress and significant unanswered questions about human and environmental health impacts, the Environmental Protection Agency (EPA) has approved a new herbicide called Enlist Duo for use on genetically engineered corn and soybeans in Illinois, Indiana, Iowa, Ohio, South Dakota and Wisconsin. EPA, which says it has approved Enlist Duo “to manage the problem of resistant weeds” is now considering approving Enlist Duo for use in ten more states: Arkansas, Kansas, Louisiana, Minnesota, Missouri, Mississippi, Nebraska Oklahoma, Tennessee and North Dakota.
Immediately following the EPA announcement, the Natural Resources Defense Council (NRDC) filed suit in the US Court of Appeals for the DC Circuit to block the registration of the new weed killer. A week later, on October 22nd, a coalition of farmers and environmental organizations – the National Family Farm Coalition, Center for Food Safety, Environmental Working Group, Earthjustice, Pesticide Action Network North America, Beyond Pesticides and the Center for Biological Diversity – filed suit in the Ninth Circuit Court of Appeals in San Francisco on behalf of their membership in the six Midwestern states where the herbicide would be used. They are also seeking to block the EPA’s approval of Enlist Duo. Both lawsuits contend that the EPA failed to adequately assess the herbicide’s impacts on human health and wildlife, including imperiled monarch butterflies.
Manufactured by Dow AgroSciences, Enlist Duo combines glyphosate – the active ingredient in Roundup, the most commonly used herbicide in the US – with what’s called a choline salt of 2,4-D – the country’s third most widely used herbicide. Enlist Duo would be used on corn and soybean seeds genetically engineered to withstand this herbicide combo. The US Department of Agriculture (USDA) approved these seeds last month. The aim of Enlist Duo is to tackle weeds that have become resistant to glyphosate that is now used on about 94 percent of the corn and about 89 percent of the soybeans planted in the US. The new seeds have been engineered to resist 2,4-D as well as glyphosate. A DowAgro Sciences press release calls the EPA’s approval of Enlist Duo, “a true victory for farmers” now grappling with glyphosate-resistant weeds across tens of millions of acres of American farmland.
2,4-D is already widely used on a wide variety of edible crops, landscaping plants, and lawn, pasture and turf grasses. Its use in Enlist Duo on the genetically engineered corn and soy could significantly increase use of 2,4-D, say both the EPA and USDA. In 2011, about 5 percent of US corn was sprayed with 2,4-D, which was used on about 11 percent of soybeans planted. In the Midwest where it’s been used most intensively, 2,4-D has drifted away from fields where it has been applied, contaminating surface and groundwater. Weeds resistant to 2,4-D have already be found in the Midwest. Through Enlist Duo, the Department of Agriculture expects 2,4-D use could grow by as much as 300 to 700 percent by 2020.
Human health concerns and data gaps – no exposure monitoring required
In studies with laboratory rats, 2,4-D has been linked to adverse effects that include reproductive, hormonal and other health impacts. 2,4-D itself is considered a synthetic hormone works to kill plants by disrupting the way certain plant cells grow. A number of human epidemiological studies – of farmers in Kansas and Nebraska and of California farm workers, among others – have found links between 2,4-D use and increased risk for non-Hodgkin’s lymphoma. But EPA’s assessment of Enlist Duo’s toxicity, gives the herbicide a pretty clean bill of health.
In its approval documents, EPA explains that it looked only at environmental and health effects of Enlist Duo’s 2,4-D component as it is that ingredient’s use that the agency considered “new” for regulatory purposes. Because glyphosate is already widely used on corn and soy and that ingredient wasn’t changing, EPA didn’t reassess those environmental health effects and concentrated on looking at impacts of expanding 2,4-D use.
The EPA says that, “When used according to label directions, Enlist Duo is safe for everyone, including infants, the developing fetus, the elderly and more highly exposed groups such as agricultural workers” and “safe for the environment, including endangered species.” The details of EPA’s approval documents, however, raise some questions about that safety. Studies reviewed by EPA show that there is evidence of 2,4-D’s adverse effects to the kidney, liver, thyroid and reproductive system when high doses were given to laboratory rats. Such exposure also produced effects on the adrenal glands, various hormones, metabolism and neurological function. The EPA also reports that in rats, lower levels of exposure produced what might be described as subclinical effects on thyroid function. These lower exposures also produced adverse nervous system and kidney effects, gait abnormalities, birth defects and lower birth weights. Previous EPA assessment of 2,4-D have found links to cancer inconclusive.
Yet in addition to an association with non-Hodgkin’s lymphoma, in studies of farmers who worked with 2,4-D, the herbicide has also been linked to suppressed immune system function, thyroid problems, lower sperm count and increased risk for Parkinson’s disease , as noted in a June 2014 letter from nearly three dozen scientists and physicians to EPA Administrator Gina McCarthy asking EPA not to approve Enlist Duo.
While the types of crops on which Enlist Duo will be used involve less labor of the type that would expose agricultural workers and its chemical ingredients are less toxic than some other widely used pesticides, enforcement of use requirements will be critical to minimizing drift and human exposure, says Migrant Clinicians Network Director of Environmental Health, Amy Liebman. Further, she says, “It is our long-held contention that chemicals should not be put on the market without a way to monitor exposure, particularly for applicators.” Approval of Enlist Duo does not include any requirements for human exposure monitoring.
Despite the lab study results, the EPA did not find any exposure risks of concern for those mixing, applying or otherwise handling Enlist Duo. And because of what EPA describes as the “low acute inhalation toxicity” for 2,4-D choline salt, it did not perform “a quantitative occupational post-application inhalation exposure assessment.” EPA also found no concerns posed by skin contact.
The agency assumes that because there is no concern for health risks to those handling and applying the herbicide, there would also be no health risks for those inhaling Enlist Duo in the field after it is applied. Using the same logic, EPA says there is no risk from such inhalation to bystanders.
Despite these conclusions, labeling requirements for Enlist Duo tell a different story. These say that “only protected handlers may be in the area during application” and no one should enter treated fields for 48 hours after the herbicide has been applied without personal protective equipment. Specified protective gear includes chemical-resistant gloves and protective eyewear, such as goggles, safety glasses or a face-shield. A Dow AgroSciences’ Material Safety Data Sheet (MSDS) also says: “After using this product, remove clothing and launder separately” and to promptly wash any exposed skin and to remove all clothing and shower after work and to launder any protective clothing separately from other household laundry.
Lack of proper training in pesticide use worries Jeannie Economos, Pesticide Safety and Environmental Health Project Coordinator with the Farmworker Association of Florida. “Farm workers that are not properly trained are likely to risk very dangerous take-home exposures,” she says and unknowingly expose their families.
Drift and other exposures
A big concern for human health and environmental exposure to Enlist Duo is drift, explains Bill Freese, Science Policy Advisor with the Center for Food Safety, a Washington, DC-based non-profit. In its approval of Enlist Duo, the EPA explains that the herbicide has been formulated to reduce volatility and hence drift. EPA also explains that the amounts of 2,4-D that would be used via Enlist Duo present no risks of concern from drift. Yet to minimize potential drift , EPA specificies that Enlist Duo can only be applied when wind is 15 miles per hour or less and with 30 foot buffer zones.EPA’s use instructions also caution against applying the herbicide during temperature inversions as that could increase risk of drift. Dow AgroSciences’ MSDS further says to prevent runoff, application should be avoided when heavy rain is forecast. Freese points out that pesticide application during high winds is common and that historically, 2,4-D has been frequently implicated in herbicide drift.
While the new formulation is supposed to minimize drift, other changes in how 2,4-D can be used in Enlist Duo have the potential to increase exposure. NRDC notes that Enlist Duo can be used during more of the growing season than was allowed for 2,4-D and thus “could mean wider human exposure.” On its own, 2,4-D was approved for use only on very short plants and could be applied “over-the-top” only on corn plants up to 8 inches tall and as a “pre-plant” application on soybeans. In its Enlist Duo formulation, 2,4-D can be used “over-the-top” on corn pants up to 48 inches tall and “over-the-top” on the soybean plants. A question to be asked is what the exposure potential would be for corn detasseling crews – that in the Midwest are often made up of teen-agers as young as 13 – that work during hot summer months, if adjacent fields are in the process of being treated.
Left unanswered in EPA’s Enlist Duo toxicity assessment, is that of effects of cumulative exposure to Enlist Duo and other pesticide chemicals. The EPA explains that it did not do such an assessment because it does not think 2,4-D behaves biologically in the same way as other herbicides and pesticides. But without exposure monitoring for Enlist Duo, it will be almost impossible to know if farm workers have been exposed, whether to this chemical formulation alone or in combination with others. And as Economos points out, “farm workers do travel,” so could be exposed to a variety of pesticides in multiple locations.
Unless the NGOs’ lawsuits prevail, Enlist Duo is poised to be used across great swaths of the American landscape, with uncertain health effects and even less information about where and to what extent people are being exposed. The EPA is accepting comments on its approval of Enlist Duo in the ten additional states until November 14, 2014.
Elizabeth Grossman is the author of Chasing Molecules: Poisonous Products, Human Health, and the Promise of Green Chemistry, High Tech Trash: Digital Devices, Hidden Toxics, and Human Health, and other books. Her work has appeared in a variety of publications includingScientific American, Yale e360, Environmental Health Perspectives, Mother Jones, Ensia, The Washington Post, Salon and The Nation.