We gratefully acknowledge the assistance of the following people who provided background information and their thoughtful and informed opinions regarding various aspects of this report: Monica Moore and Susan Kegley of the Pesticide Action Network; David Chatfield and Joan Clayburgh of Californians for Pesticide Reform; Norma Grier and Neva Hassanein of the Northwest Coalition for Alternatives to Pesticides; James Moore and Pamela Hadad Hurst of the New York Coalition for Alternatives to Pesticides; Kert Davies of the Environmental Working Group; and Polly Short of the World Wildlife Fund.

We also thank: James Liebman at the United States Environmental Protection Agency, Region 9 for technical advice on data analysis; Robert Haggerty of the New York State Department of Environmental Conservation for his openness and availability in meeting with us and answering our many questions; Beverly Martin of the California Department of Pesticide Regulation for providing pesticide product information for use in data analysis; and James Beech of the United States Environmental Protection Agency in Washington D.C. for clarifying pesticide product data.

Finally, we would like to acknowledge William Smith and Robert Warfield of the Cornell Pesticide Management Education Program for their exceptional generosity with their time and insight into the intricacies of the data.

The authors also gratefully acknowledge the financial support of the Pew Charitable Trusts, the Turner Foundation and the Winslow Foundation. The opinions expressed in this report are solely those of the authors and their organizations and do not necessarily reflect the views of any other person, organization, or funder acknowledged here.

Table of Contents:

Glossary of Key Terms
Executive Summary
Introduction
Background
New York State Pesticide Use and Sales Data
Sidebar: Inert Ingredients
Sidebar: Alternative Pest Control
Sidebar: Food Quality Protection Act of 1996
Table 1
Table 2
Table 3
Table 4
Table 5
Maps
Water Contamination
Recommendations
Conclusion
References
Appendix A: Methodology and Data Quality Issues
Appendix B: The Greater Rochester Area
Appendix C: Western New York
Appendix D: New York City
Appendix E: Long Island
Appendix F: Westchester
 

Active Ingredient: an agent that is specifically intended to kill, repel, or otherwise deter a target organism, and which is registered with the United States Environmental Protection Agency and the New York State Department of Environmental Conservation as such. Active ingredients are listed on pesticide product labels.

Certified Applicator: anyone who has received training and been tested in subjects related to pesticide application by the New York State Department of Environmental Conservation. Certification is necessary to perform any pesticide application for hire, and to purchase and apply restricted use pesticides (with the exception that non-certified personnel working under the supervision of certified applicators are also permitted to apply restricted use pesticides). All commercial applicators are certified. Private applicators (farmers) need only be certified if they apply restricted use pesticides.

Commercial Applicator: anyone who applies pesticides for hire, including: lawn and garden applicators; exterminators; custodial and groundskeeping staff in schools, office buildings, and other structures; and municipal employees who apply pesticides in such places as parks or on roadsides. In addition, some commercial applicators are hired to make agricultural applications on farms they do not own or rent themselves (most aerial applicators are commercial applicators, for example).

General Use Pesticide: a pesticide that is available to any person.

Inert Ingredient: any ingredient of a pesticide product in addition to the active ingredient. Inert ingredients are not disclosed on the product label and are often highly toxic. They are added to increase the potency of the active ingredient, or to act as a carrier (aiding in dispersion or adherence).

Pesticide Product: a mixture of pesticide active ingredients and inert ingredients. Some pesticide products consist entirely of active ingredients.

Private Applicator: a farmer who applies pesticides only on property he or she owns or rents for the purpose of producing an agricultural commodity.

Restricted Use Pesticide: a pesticide for which limitations have been established regarding where and how it can be used. Restricted use pesticides can only be obtained and applied by certified applicators.

Target Organism or Target Pest: an insect, weed, fungus, or other pest that a pesticide is specifically intended to kill or repel.

 Executive Summary 

New York State is awash in pesticides. The new pesticide use and sales data, released in July, 1998 by the New York State Department of Environmental Conservation (DEC), reveals that millions of pounds and millions of gallons of pesticides were applied by commercial pesticide applicators and sold to farmers for use on their crops in New York State in 1997. For the first time in the half century since pesticides have come into widespread use, it is possible to begin to understand the type, relative amount, and geographic variation of pesticide use in the State, as a prelude to reducing and eventually eliminating pesticide risks; risks that include cancer, nervous system damage, developmental and reproductive abnormalities, hormone disruption, and immune suppression.

Analysis of the data yields the following major findings:

• In 1997, 16.7 million pounds and 2.4 million gallons of pesticides were applied by commercial applicators or sold to farmers for use on their crops in the New York State.
• Downstate urban and suburban counties report more pesticide use than rural and other upstate counties. The data reveal a striking pattern that shows substantially more pesticide use in downstate urban and suburban areas than in rural and other upstate counties. New York (Manhattan), Kings (Brooklyn), Nassau, Suffolk, and Westchester counties dominate the overall county rankings. The use of such large amounts of toxic pesticides in the densely populated and geographically small downstate areas can pose significant public health risks. This kind of intimate exposure has the potential to affect people, particularly vulnerable populations such as infants, children, and the elderly, on a round-the-clock basis.
• Statewide, agricultural use is lower than non-agricultural use. Many people believe that pesticides are only a hazard in farming communities. But the data clearly show that this assumption is not true in New York State. Non-agricultural pesticide use is greater than agricultural use statewide, although in certain areas of the State, such as the western and Hudson River Valley farming areas, agricultural pesticide use is dominant. Because agricultural use entails certain unique risks, including residues on food and water contamination, reducing agricultural pesticide use must be a State priority. But it is clear from the patterns revealed by these data that non-agricultural exposures — in homes, offices, schools, parks, and roadsides — must command new attention.
• New York State relies heavily on toxic pesticides, even though non-toxic alternatives and least-toxic strategies are readily available for most pest problems. Over a third of the total pesticide products used statewide contain active ingredients classified as known, probable, likely, or possible carcinogens by the United States Environmental Protection Agency, and nearly 40% of the pesticides used belong to one of the two main neurotoxic insecticide families. Significant quantities of products containing endocrine disruptors and reproductive and developmental toxins were also used. One neurotoxic pesticide, chlorpyrifos, is both the most heavily used pesticide in the State and also one of the leading causes of pesticide poisonings in the nation. Other heavily used active ingredients are characterized by a wide array of health and environmental hazards.
• Water monitoring studies show pesticide contamination is a major problem in New York State, particularly for vulnerable areas, such as Long Island. Water contamination by pesticides parallels pesticide use patterns, and water monitoring studies across the State and particularly on Long Island show widespread contamination, sometimes rendering well water unfit to drink.

Recommendations to alleviate some of the hazards revealed by the data include:

• New York State should ban those pesticides whose toxicological properties make them high risk. These most hazardous pesticides include: known, probable, and likely carcinogens; highly acutely toxic pesticides, developmental and reproductive toxins, and those pesticides that can disrupt the hormone system. Government regulators routinely allow pesticides that are known to pose such serious health risks to be used. Banning the worst pesticides would be the first step in reversing this course and ameliorating risk.
• New York State agencies should use the pesticide reporting data to further the goal of public health and environmental protection. The data should be used to identify those pest problems that are subject to the greatest amounts of toxic pesticide use so that non-toxic alternatives can be implemented, and it should be compared to other data bases of known health problems, such as the New York State Department of Health’s cancer and birth defects registries. Pesticide use data can also be used to guide targeted water monitoring, identifying areas most at risk from water contamination hazards.
• Non-toxic pest management strategies should be actively promoted. New York State should actively promote research and education into non-toxic pest control strategies and organic farming, and DEC should ensure that certified pesticide applicators are trained in non-toxic strategies.
• New York’s decision makers need to expand and improve the public’s right-to-know. The public should have greater access to the pesticide reporting data and that data should be compiled in greater detail from both farmers and commercial applicators. DEC should publish the data in a single unit of measure (pounds) to facilitate understanding, and all data should be reported to DEC electronically in order to reduce errors and costs to the agency. In addition, the public should be warned of pesticide applications to neighboring properties to which they could be exposed.
• Government should lead by example. Phasing out pesticide use on municipal and state property through the passage of “Pesticide Sunset” laws, and establishing procurement preferences for organic food would eliminate some pesticide risks, enhance knowledge of alternatives, and support the market for organic food, including food produced by local New York State farmers.
• Enforce the Worker Protection Standard. Farmworkers and their families receive significant exposure to pesticides, yet DEC does not have a full-time staffperson dedicated to enforcing the regulations designed to protect them. New resources and staff must be committed to this essential program.
• Ban Aesthetic Uses of Pesticides. The use of toxic pesticides for purely ornamental purposes entails considerable risk with no public health benefit and should not be allowed.
• Tax Pesticide Sales to Fund Pesticide Programs. Pesticide programs are underfinanced and are generally paid for with taxpayer monies. In keeping with the concept of “polluter pays,” pesticide manufacturers should pay a tax on pesticide sales to finance pesticide programs. With the knowledge of pesticide hazards growing, it is time for those who profit from them to take responsibility for the costs such use foists upon society.

Pest management is not synonymous with pesticides. We have been on the dangerous path of pesticide reliance for a comparatively short time. The time has come for New York State’s legislature, governor, and regulatory agencies to use the knowledge gained from the pesticide reporting data to act in the public interest and move the State away from the use of toxic pesticides and toward non-toxic alternatives.

 Introduction

New York State is awash in pesticides. This is now clear because, on July 1, 1998, the New York State Department of Environmental Conservation (DEC) released the first year of pesticide use and sales data collected under the State’s 1996 Pesticide Reporting Law (Chapter 279 of the Laws of 1996)The impetus for enacting this new statute was the near total absence of information regarding actual pesticide use in the State — when, where, what, and how much. Lacking such fundamentals, decisions regarding pesticide regulation and risks were being made in a vacuum, and research into their impacts suffered. Crafting intelligent policy, however, requires a foundation of knowledge. The Pesticide Reporting Law has begun the process of constructing that foundation. All commercial pesticide applicators must now annually report detailed records of their pesticide applications for the previous calender year to DEC, all businesses that sold pesticides to farmers must report the details of those sales, and all businesses selling restricted use pesticides must report total sales of these pesticides.

For the first time in the State’s history we can generate a baseline description of the type, relative intensity, and geographic variation of pesticide use. This information will in turn lead us to understand the areas of greatest risk, describe patterns, and reveal opportunities for use reduction. In future years, we will also be able to document use trends.

Pesticide is an overarching term for an array of chemicals intended to kill or repel living things. It includes insecticides, herbicides (designed to kill weeds), fungicides, nematacides, rodenticides, anti-microbial agents, some microbes themselves (such as the insecticidal bacteria Bacillus thuringiensis), and a host of other biocidal or repellent chemicals. The new data reveal that an overwhelming 16.7 million pounds and 2.4 million gallons of pesticide products were applied by commercial pesticide applicators or sold to farmers for use on their crops in 1997 alone. Because these numbers do not account for pesticide use by individuals in their own homes and gardens, even these substantial figures are an underestimate. The most heavily used products were some of the more hazardous pesticides available on the market, including numerous known and probable carcinogens, and highly neurotoxic insecticides.

Now that New York State’s public officials know what is occurring with regard to pesticide application, there is no excuse not to act. This is the challenge posed by the data. Bolstered by the voluminous evidence that non-toxic pest control measures are safer, effective, longer-lasting, and often less expensive, we hope that the broad analysis contained here will spur citizens, local and state governments, regulators, and researchers of all stripes, to both examine and break New York’s collective chemical habit.

 Background

Synthetic pesticide use is a relatively recent phenomenon, vaulting onto the American scene after World War II and transforming pest management practices — even the definition of what constitutes a pest — in the brief space of five decades. Some of the original uses of these pesticides, such as DDT for typhus and malaria control, appeared at first to be unqualified advances. Others were clearly understood to be harmful from the start. Today’s dominant class of insecticides, for example, organophosphates, was developed as a weapon of war — nerve gas — in Germany in the early part of the century. But whatever their origin, pesticide use in the post-war era proliferated unchecked, becoming a routine that spread to every corner of the pest control universe — from agriculture to homes and lawns.

This spread occurred without foresight or appreciation of the panoply of hazards that it entailed. Only after pesticides were in wide use did we awake to the bitter knowledge that they are far from benign. Furthermore, our profligacy has generated pest resistance and resurgence, and fueled fundamental and continuing shifts in our food production system — away from small, diversified family farms, and toward huge crops of genetic clones (monocultures), exquisitely vulnerable to large-scale pest invasion — that actually increased some pest problems. The recklessness with which we embarked on this chemical course has exacerbated some previously manageable conditions and subjected people and wildlife to needless risks for often frivolous reasons.

The universe of hazards we now know to be associated with pesticides is large and growing. Although federal and state government, which share the responsibility for regulating pesticide use and availability, have occasionally banned or stringently limited the use of certain pesticides based on such hazards, the list of these pesticides represents a mere fraction of the total amount of products available. It is a list that expands by increments, as the epidemiological or ecological evidence reaches the critical point necessary to spur regulatory action. Yet its very existence exposes the dangerous illogic our system, which is biased in favor of pesticide availability until the mounting proof of harm is incontestable. The plainest indictment is this: each pesticide that has been banned — such as DDT, dieldrin, and chlordane — was once widely used and claimed to be safe.

New York State has had ample experience with the adverse consequences of pesticides. In fact, for some of these hazards, notably groundwater contamination, New York was one of the first places they were identified. The State has been hindered in addressing them, however, by the sketchy and disjointed condition of knowledge about pesticide use. With the release of the pesticide use and sales data, that is beginning to change.

 New York State Pesticide Sales Use and Data

New York’s new pesticide reporting data shed crucial light on pesticide use in the State. For the first time, we have a unified data base, based on actual application and sales reports, that shows how much and which pesticides are being used, and where. Also for the first time, this report correlates information on the health and environmental hazards posed by pesticide use with actual pesticide use data for the State ( see the Methodology and Quality of the Data Appendix for a detailed description of how this correlation was made). The data represent an unprecedented opportunity to examine the nature and dimension of our use of these toxic chemicals, and as such, they also represent an unprecedented opportunity for making informed changes to reduce and eliminate risks.

I. MILLIONS OF POUNDS AND MILLIONS OF GALLONS OF PESTICIDES WERE USED IN NEW YORK STATE IN 1997
Table 1 shows the total reported amount of pesticide products used and sold in New York State in 1997— 16.7 million pounds and 2.4 million gallons of products — as well as how these totals divide up between the commercial and agricultural sectors. These totals are a combination of the commercial applicator use data and the data on sales to farmers, which is used as the best available surrogate for pesticide applications by farmers. Because these figures are a snapshot — the first one we have of pesticide use in the State — it is not possible to know how they relate to past use. Future years of data will tell us whether these amounts are increasing, decreasing, or holding steady. Nor can we put this in a wider context of pesticide use by other states. Only California publishes full pesticide use data and they are difficult to discuss relative to New York’s, chiefly because California’s physical size and agricultural scale are so vast — California uses 25% of the nation’s pesticides, and 90% of those are used in agriculture.1

Lacking a history or comparison state for context, therefore, New York State’s first year of pesticide reporting data stands on its own as a baseline and starting point for discussion.

II. DOWNSTATE URBAN AND SUBURBAN COUNTIES REPORT MORE PESTICIDE USE THAN RURAL AND UPSTATE COUNTIES
Until now, it was not possible to make informed statements about where the greatest pesticide use was occurring in the State. With the availability of this data, however, a striking pattern is revealed: substantially more pesticide use occurred in downstate urban and suburban areas than in rural and other upstate counties in 1997 (see Tables 2 and 3, and Maps 1 and 2). New York (Manhattan), Kings (Brooklyn), Nassau, Suffolk, and Westchester counties dominate the overall county rankings. The use of such large amounts of toxic pesticides in the densely settled and geographically small downstate areas can pose significant public health risks, particularly for highly volatile pesticides, which can linger in indoor air and in the already polluted outdoor air. This kind of intimate exposure has the potential to affect people, particularly vulnerable populations such as infants, children, and the elderly, on a round-the-clock basis.

New York and Kings counties top the rankings for gallons and pounds of pesticides used respectively. And within those two counties a single product dominates — the insecticide Dursban Pro(R) (containing the active ingredient chlorpyrifos described in Section IV), which is used for a host of pest problems, including termites, roaches, fleas, flies, moths, spiders, silverfish, and stinging insects. In New York County, 438,797 gallons and 832,424 pounds of Dursban Pro(R) were used, which represents 78% of the total gallons of all pesticide products used in that County, and 82% of the total pounds. In Kings County, applicators did not report using much Dursban Pro(R) in liquid form but did report applying a remarkable 2,245,902 pounds of Dursban Pro(R) in solid form. This figure represents 87% of the total pounds of pesticide products used in that County. The number of gallons of Dursban Pro(R) used in New York County was greater than the number of gallons of all pesticide products applied by commercial applicators in any other single county. The number of pounds of Dursban Pro(R) used in Kings County was nearly twice the total amount of pounds of all pesticides applied by commercial applicators in Nassau County, which ranked second overall in pounds of pesticide product applied by commercial applicators. Not all high ranking counties showed such a marked dominance of a single product. Nassau and Suffolk counties, for example, had a wider range of heavily used products, many of them lawn care products combined with fertilizers.

Beyond the overall dominance of the downstate counties, it is harder to generalize about pesticide use patterns, partly because reporting gallons and pounds separately does not allow for a unified ranking.2 Map 2, which displays pesticide use and sales in pounds, shows heavy pesticide use and sales in relatively rural central New York, but also in counties with substantial urban and suburban areas, such as Monroe and Erie counties. Map 1, which displays pesticide use and sales by gallons, shows only one county with significant rural acreage, Orange County, in one of the heaviest use categories. It may be that upstate cities and suburbs have the same high rate of pesticide use as downstate urban and suburban areas. But because upstate cities and suburbs coexist with considerable open and agricultural land in the same county (as opposed to downstate counties that are generally all urban/suburban) it is difficult to determine their rates of pesticide use. Analysis of pesticide use by zip code, a smaller geographic area than county, would begin to answer these and other questions.

The general patterns highlighted here logically lead to the question of precisely what these pesticides are being used for and how often they are being applied (for example, are these large treatments every few years, or monthly chronic exposures?). We can speculate in a general way, but the Pesticide Reporting Law does not allow the public access to the detailed data that would tell us precisely which pest problems are drawing this toxic fire. Government agencies, however, do have access to this information and are positioned to respond productively to these revelations, by identifying and implementing non-toxic alternatives. For example, numerous interior pests, such as roaches, can be controlled by simple structural measures, such as caulking cracks and crevices, eliminating leaks in roofs and pipes, and sealing around cabinets, or by least toxic chemicals such as boric acid or silica gels injected into walls and baseboards. Such measures provide long-term solutions while improving the livability and pest resistance of the structure overall.

A final note: an unfortunate entry into the county list, and one which ranks disturbingly high in many of the rankings, is “Unknown.” According to the Cornell Pesticide Management and Education Program, “Unknown” is a compilation of all the applications and sales that could not be attributed to a specific geographic area due to insufficiencies or errors in the reporting forms,as well as some out of state applications; it represents a significant shortcoming in the current reporting system.

III. AGRICULTURAL USE IS LOWER THAN NON-AGRICULTURAL USE STATEWIDE
Many people imagine pesticide use to be solely an agricultural phenomenon that does not affect them if they do not live in farming areas. The data clearly show that this assumption is not true in New York State. Commercial pesticide applications (which are generally non-agricultural) dominate over sales for agricultural application statewide; the former account for 82% of the total pounds and 80% of the total gallons reported (see Table 1). This pattern is not consistent for all regions of the State (see Maps 3 and 4). In the farming and orchard areas of western New York and the Hudson River Valley, as well as in the northeast corner of the State, sales to farmers account for the majority or, in some cases, virtually all reported pesticides. But overall, non-agricultural use is higher. Only Wayne County among the top ten counties in either total gallons or pounds has clearly greater sales to farmers than commercial applications. Monroe County has substantial sales to farmers, but commercial application appears to predominate.

While the scale of the difference between non-agricultural and agricultural pesticide use is dramatic, there are several factors that may exaggerate this difference to some degree:

• Only sellers of restricted use pesticides are required to report sales to farmers (though these sellers must report sales of all pesticides — both general and restricted use). This means that pesticides sold to farmers by dealers who only sell general use pesticides are missing from the data base, as are pesticides purchased out of state. The limitations of the data base mean that there is no way to even estimate how large a universe is being excluded by these anomalies in the reporting law.
• Some commercial applicators make agricultural applications and the commercial applicator category therefore contains some agricultural applications. However, without further information on the reason for such pesticide applications, we cannot say how much this represents. Data to make such a determination are available to DEC (though collecting and deciphering this information would take some effort), but the Pesticide Reporting Law does not allow the public access to them.
• Because farmer reporting is indirect, by sales, it has a greater potential to inaccurately reflect true use. If a farmer used last year’s chemical stock during the reporting year, this amount would not show up as a purchase in the reporting year, potentially leading to an underestimate of application amount. The inverse is also true though; stockpiling during the reporting year could lead to an overestimate.

These qualifiers notwithstanding, the dimension of the difference between commercial application and farmer sales amounts, combined with the absence of homeowner use from these data, indicate that non-agricultural applications account for a greater proportion of New York State’s overall pesticide use than do agricultural applications. The fact that urban and suburban counties rank highest in overall amount of pesticides used and sold, versus the more rural counties that dominate only in the agricultural sales rankings, bolsters this conclusion.

It is essential to note, however, that agricultural pesticide use, even though lower statewide than non-agricultural use, poses certain unique risks. Because they can remain on treated crops as food residues (a particular threat to infants and children),3 the impacts of agricultural pesticides are felt far beyond the immediate area in which they are used. In addition, some of the most heavily used pesticides in New York State agriculture — atrazine, metolachlor, alachlor, and cyanazine — are also the most significant water contaminants in New York State and across the country (see Water Contamination). While total amounts of agricultural pesticides are lower than non-agricultural amounts, therefore, certain risk pathways may be more accentuated for agricultural use based on the hazards of the dominant agricultural pesticides. Reducing agricultural pesticide use must therefore be a state priority, but it is clear from the patterns revealed by these data that non-agricultural exposures — in homes, offices, schools, parks, and roadsides. — must command new attention.

IV. THE PESTICIDES USED AND SOLD IN NEW YORK STATE ARE HIGHLY TOXIC
Because they are intended to kill living things, it is not surprising to learn that pesticides can harm people as well. The release of the pesticide use and sales data marks the first time that we can correlate the known health risks associated with pesticides with actual figures for pesticide use. And these figures demonstrate that, although non-toxic alternative pest control strategies and least toxic pesticides are readily available, New York State’s pesticide use is dominated by highly toxic pesticides.

The hazards associated with pesticide use are many, including:

Nervous system toxicity: Neurotoxicity is the feature of pesticides responsible for acute poisoning and it can also result in lingering neurological problems -- from persistent headaches and dizziness, to confusion and seizures. Many pesticides can be neurotoxic, but the two major classes of insecticides, organophosphates and carbamates, actually work by interfering with an enzyme — cholinesterase — that is essential to normal nervous system function in insects and humans alike (and all other animals as well). Fetuses, infants, and children, whose nervous systems have not fully matured, are particularly vulnerable to the overt damage that this disruption causes. And like the slow, dawning awareness of lead toxicity, we are just beginning to understand that even at low, chronic doses, neurotoxic pesticides cause subtle, potentially permanent neurological and intellectual harm, particularly to children.4 In the words of one researcher: “Pesticides are chemicals deliberately designed to sabotage biological mechanisms and insecticides are powerful neurotoxicants. Some have achieved global distribution in human tissues. Instances of poisoning erupt repeatedly. It would be quite extraordinary to find them devoid of a significant role in the etiology of developmental disabilities.”5 On the other end of the age spectrum, Parkinson’s disease, one of the most common neurological illnesses, has also been repeatedly linked to pesticide use.6

Carcinogenicity: Cancer is a group of illnesses characterized by the uncontrolled growth and spread of abnormal cells. One of every four deaths in the United States is caused by cancer.7 A substantial portion of pesticides are classified by the United States Environmental Protection Agency (EPA) as known, probable, likely or possible carcinogens,8 with particularly sobering indications in the epidemiological literature linking pesticide use to childhood cancers, Non-Hodgkin’s lymphoma, multiple myeloma, leukemias, breast and prostate cancers, and others.9 The incidence of many of the cancers linked to pesticide use has risen dramatically in the past few decades. Regarding the risks to children, a recent review by researchers at the National Cancer Institute stated: “Many of the cancers associated with pesticides among children, such as leukemia, brain cancer, non-Hodgkin’s lymphoma, soft-tissue sarcoma, and Hodgkin’s disease, are the same cancers that are repeatedly associated with pesticide exposure among adults, suggesting that a role among children is highly plausible. Furthermore...the magnitude of the risks is often greater than among adults, indicating greater susceptibility ...[therefore] it is prudent to reduce or where possible, to eliminate pesticide exposure to children.”10

Birth defects: Pesticides, like many other chemicals, carry the possibility of inducing birth defects from prenatal exposure. Limb reductions either alone or in conjunction with other abnormalities11 have been linked to agricultural work and pesticide exposure, as have general malformations12 and the increasing problem of male genital abnormalities (undescended testes and a defect of the urethral opening known as hypospadias).13 One notable study found that: areas of greater pesticide use also had significantly higher frequency overall of birth defects; abnormalities were most frequent in infants conceived during the season of highest pesticide use (spring); and infants born to farmers who applied pesticides had higher birth defect rates and a skewed proportion of males to females, than did infants born to non-applicators.14

Reproductive abnormalities: Over the years, pesticides have been implicated in infertility (the now-banned soil fumigant dibromochloropropane, DBCP, being the most well documented)15 and other reproductive problems, such as miscarriage, stillbirth, and premature birth.16 A vigorous debate, far from settled, about possible global decreases in sperm counts has fueled concern over this issue and the role toxic chemicals, including pesticides, may play in it.

Hormone mimicry and disruption: The delicate hormonal balance in our bodies governs virtually all aspects of our maturation and daily functioning. The recently recognized ability of many pesticides to interfere with the normal hormone system,17 known by the broad term “endocrine disruption,” is the subject of a major federal program established under the Food Quality Protection Act of 1996 (see Food Quality Protection Act sidebar page 20). Although the vast majority of chemicals have yet to be tested for this effect, epidemiological evidence points to numerous pesticides as potential culprits.

Immunotoxicity: The immune system governs our bodies’ response to illness. Though a relatively new line of inquiry, there is evidence that pesticides interfere with proper functioning of the immune system,18 leaving affected populations subject to a wide range of other maladies.

Table 4 shows the total amounts of pesticides used and sold in the State which contain active ingredients that are known and suspected carcinogens, reproductive and developmental toxins (disrupting normal fetal maturation), neurotoxins, and endocrine disruptors, as the current state of our knowledge has identified them. It was not possible to analyze the pesticide use data base for immunotoxicity because comprehensive lists were not available for this health effect.

Products containing known and suspected carcinogens constituted 38% of the total pounds and 33% of the total gallons reported statewide. Sixty-one percent of the gallons and 40% of the pounds of pesticides purchased by farmers contained probable, likely, or possible carcinogens (no sales of products containing known carcinogens were reported). Of the products applied by commercial applicators, 26% of the gallons and 37% of the pounds of pesticides contained known, probable, likely, or possible carcinogens. Ten per cent of the pounds of pesticides applied by commercial applicators contained known carcinogens. For the most part, these known carcinogens were found in wood preservatives that are applied during a manufacturing process and then widely dispersed when the resulting “pressure treated” wood is used for building homes, playgrounds, decks, and a host of other structures where people come into contact with the wood itself and its sawdust.

Neurotoxic organophosphate and carbamate insecticides constituted 39% of both the total pounds and the total gallons reported statewide. Endocrine disruptors were present in 14% of the pounds and 26% of the gallons of pesticides reported statewide.

These substantial percentages underscore New York State’s reliance on toxic pesticides. Examining the most heavily used active ingredients further illuminates the nature of the hazards entailed by such reliance. Table 5 shows the top 15 pesticide active ingredients in descending order of prevalence for the various reporting categories. Prevalence was determined by the total amount of pesticide products containing a given active ingredient used or sold in New York State (see Methodology and Quality of the Data Appendix for a fuller description of the ranking process).

Chlorpyrifos
The organophosphate insecticide chlorpyrifos dominates both the commercial applicator use and overall use and sales categories and thus deserves particular emphasis here. A notable 4,603,888 pounds and 744,769 gallons of chlorpyrifos-containing products were applied by commercial applicators and sold to farmers. Chlorpyrifos’ neurotoxic properties have resulted in its being “one of the leading causes of acute insecticide poisoning incidents in the United States.”19 It also causes long-term poisoning symptoms, such as persistent headaches, fatigue, weakness, dizziness, irritability, depression, confusion, and short-term memory impairment, and it may cause peripheral nerve degeneration,20 and suppression of the immune system.21

Despite its toxicity, chlorpyrifos has replaced some banned pesticides, most notably chlordane which had previously been the dominant product for termite control before it was removed from the market. In addition to being a termiticide, chlorpyrifos is a also heavily marketed for a wide range of common insect problems, including roaches, fleas, flies, bees, and wasps. As a result, sales of Dursban(R), the chief (but not the only) pesticide product containing chlorpyrifos as its active ingredient are reported to have increased 26-fold since 1975.22 Commercial application of the single product Dursban Pro(R), manufactured by Dow Agrosciences LLC, was reported to be a staggering 3,478,754 pounds, and 661,107 gallons statewide, demonstrating the market dominance of this pesticide in New York State.

In response to the steady flood of chlorpyrifos poisoning incidents nationwide (the bulk of which were traced to commercial as opposed to homeowner application — possibly because commercial applicators use more concentrated products),23 and evidence that chlorpyrifos clings to toys, carpets, upholstered furniture, and drapes in the home,24 EPA banned certain uses in June, 1997.25 These uses include residential “total release foggers,” broadcast products for the home, direct application pet products, and paint additives. While a small step forward, many of the documented poisoning incidents would not have been prevented by these restrictions. Rather than tweaking its allowable uses, sound public health policy dictates that we pursue alternative, non-toxic solutions to the pest problems for which chlorpyrifos is applied.

The data show that chlorpyrifos, one of the leading causes of pesticide poisoning in the nation, is also the leading pesticide used in New York State. This striking parallel should serve as a loud wake-up call to regulators and the public.

Other Active Ingredients
In addition to chlorpyrifos, the list of most heavily used active ingredients includes a rogue’s gallery of other noteworthy pesticides. For example:

Arsenic Acid Anhydride and Chromic Acid are used in combination with copper (II) oxide as wood preservatives. These compounds are classified by EPA as known human carcinogens. Both are also acutely and chronically poisonous, and damaging to the liver. Chromic acid is also highly corrosive.26

Methyl Bromide is not only a highly toxic fumigant (only available in restricted use products), but also a severe ozone depleter, scheduled for phase-out under the federal Clean Air Act on January 1, 2001. It can cause both acute poisoning (including pulmonary edema and bleeding, convulsions, dizziness, nausea and vomiting), significant long-term damage to the nervous system,27 and fatalities. Data on its carcinogenicity are inconclusive, but there is some evidence for this effect.28 Its combination of volatility and marked toxicity make its application a high-risk proposition under any circumstances, but particularly near residential areas and schools. Yet the data show that this toxic pesticide is being applied in highly populated areas in New York State, including Manhattan.

Metolachlor is classified by the EPA as a possible human carcinogen and is a widespread water contaminant (see Water Contamination). It also shows evidence of being a developmental toxin.29

Atrazine and Cyanazine belong to a class of herbicides called the triazines that are known to disrupt normal endocrine function,30 and are repeatedly linked in the epidemiological literature to various cancers (both are classified as possible human carcinogens by the EPA), including breast31 and ovarian cancer.32 Both, along with metolachlor, have been linked with developmental problems as well.33 As a result of the hazards it poses, the manufacturers of cyanazine, chiefly DuPont, agreed to voluntarily phase out production of cyanazine. Ciba-Geigy (now Novartis), the manufacturer of atrazine, is not following suit and this widely used herbicide and frequent water contaminant will continue to be available. Underscoring the risk this availability poses, a recent study in the Hudson River Basin by the United States Geological Survey (USGS) found that: “(a)trazine was the most commonly detected pesticide in surface water and groundwater and was found in nearly every sample in which any other pesticide was detected.”34

Mancozeb, Maneb, Captan and Chlorothalonil are all fungicides classified by the EPA as probable human carcinogens.

Azinphos-methyl and Methyl Parathion are among of the most highly toxic members of the organophosphate insecticide family. Most products containing these pesticides are restricted use. Because azinphos-methyl does not have any residential uses, the main route of exposure for the general public is through food. A recent review by EPA’s Health Effects Division (HED) of azinphos-methyl toxicity concluded that “...(A)ccording to the exposure and risk assessments described here, currently registered uses of azinphos methyl result in dietary risk estimates for acute exposures through food alone that exceed HED’s level of concern.”35 Put more simply, this means that EPA believes the risk of poisoning from exposure to residues of azinphos-methyl on food is real and immediate. Regarding farmworker and applicator exposure for azinphos-methyl, HED states that: “(r)isk remains unacceptable despite additional protective clothing for all scenarios.”36 Residue risks posed by these pesticides has led Gerber Products Company to prohibit its apple suppliers from using methyl parathion and to significantly limit the use of azinphos-methyl.37

Zinc Phosphide is an extremely toxic rodenticide. “Very small amounts...can cause severe and even fatal poisoning.”38 In addition, zinc phosphide breaks down into highly toxic phosphine gas, which is “at least as toxic systemically as hydrogen cyanide,”39 and which has been associated with chromosomal damage.40

2,4-D and Mecoprop are herbicides in the phenoxy family. Phenoxy herbicides have been strongly linked to a number of different cancers, most notably Non-Hodgkin’s lymphoma,41 the incidence of which has risen dramatically in recent decades. 2,4-D has also been shown to damage sperm quality42 and may be an endocrine disruptor.43

Pyrethrins and Piperonyl Butoxide are often combined in insecticide products. Pyrethrins are naturally occurring compounds that act by paralyzing the nervous system of insects. In humans, they can cause both allergic skin reactions and asthma attacks that can be severe, particularly for people with previous respiratory problems.44 Once such a severe reaction has occurred: “Inhalation exposure should be carefully avoided in the future.”45 Because pyrethrins tend to dissipate quickly in the atmosphere, piperonyl butoxide is added as a synergist to prolong their efficacy. Piperonyl butoxide is classified by the EPA as a possible human carcinogen; the carcinogenicity classification of pyrethrins has been deferred by the EPA.

Permethrin, Cyfluthrin, and Tefluthrin are pyrethroid insecticides (synthetic versions of pyrethrins that do not degrade as quickly). All pyrethroids are neurotoxic. Permethrin is also classified by the EPA as a possible human carcinogen and appears to disrupt the endocrine system.46

Pendimethalin, Trifluralin and Benfluralin are related, dinitroaniline herbicides. Pendimethalin and trifluralin are classified as possible human carcinogens by the EPA (benfluralin has not yet been classified for carcinogenicity). Dinitroanilines are also suspected mutagens, developmental toxins, and may damage the liver and kidneys.47

Carbaryl and Trichlorfon are members of the neurotoxic carbamate and organophosphate insecticide families respectively. As such, both pose both acute and chronic poisoning risks to anyone in contact with them or their residues.

Diazinon, also a neurotoxic organophosphate, was banned in 1990 by EPA for use on golf courses and sod farms because of bird kills. But it is still available for other uses, including lawn applications where children as well as birds are exposed. Food residue concerns have led Gerber Products Company to ban its use on apple crops by its contract growers.48

These brief summaries are but a sampling of the hazards of some of the top pesticide active ingredients used in the state. There is also a tremendous amount we cannot describe here because government regulators do not require certain essential kinds of testing. For example, active ingredients are often applied in combination with each other and while there is some information about the immediate threat from acute poisoning for certain combinations, there is essentially no information available about their chronic effects (such as potential carcinogenicity, hormone mimicry, developmental or reproductive toxicity). This means that real world exposures to chemical combinations are not understood.

 Sidebar: Inert Ingredients  

Inert ingredients are the dirty little secret of the pesticide industry. They can increase the potency of pesticide active ingredients, or make a product easier to use, and they can constitute as much as 99% or more of a pesticide product. But they are not identified on product labels and are by no means the innocuous agents their name suggests. Many inerts are highly toxic in their own right. Of the more than 2500 chemicals used as inert ingredients, 209 are classified as hazardous air and water pollutants regulated under the federal Clean Air and Clean Water Acts, 14 are classified as “extremely hazardous” under the federal Superfund program, 21 are classified as known or suspected carcinogens by various international, federal, and state agencies, 127 are regulated as occupational hazards by the Occupational Safety and Health Administration (OSHA), and 84 are reported to the federal Toxic Chemical Release Inventory. More telling is the fact that 394 of the so-called inert ingredients are or have been registered as active ingredients in other pesticide products, including 11 that are considered restricted pesticides.*

Even with such demonstrable toxicity, pesticide manufacturers are not required to identify most inert ingredients on pesticide labels and inert ingredients are not reported under New York’s Pesticide Reporting Law. Individuals can file a Freedom of Information Act request with EPA to obtain the information for a given product, but this is a significant hurdle to leap for the average consumer. We are allowed to know everything that is in the package of cookies or frozen pizza we purchase, but full knowledge of what is in the toxic pesticide products to which we are exposed is unconscionably out of our reach.

 Alternative Pest Control

Although many uses of pesticides are frivolous — maintaining weed-free yards for example — others are directed at real pest management issues. Using toxic chemicals to control these pests, however, is a band-aid at best. It addresses the symptoms, but does nothing to get at the conditions which foster infestations so that they can be averted in the future. At worst, pesticide use is not a band-aid but an irritant, exacerbating pest problems by generating resistance, eliminating natural predators, or causing secondary pests (those which had not been a problem prior to pesticide use) to flourish. These new pest problems frequently impel yet more pesticide use in a escalating cycle known as the “pesticide treadmill.”

But the tools to shift from pesticide use to saner, more sustainable pest management methods are readily available, and new information, products and discoveries appear continually. Although the subject of alternative controls is vast, most techniques fall into one of four general categories:

Physical controls. Simple maintenance, such as caulking cracks and crevices; plugging holes with plaster or steel wool; and eliminating water leaks in roofs or pipes can significantly decrease many pest problems inside buildings, such as roaches, ants, and rodents, at the same time as they improve overall structural integrity and livability. Exclusion measures, such as storing food in sealed glass or plastic containers, and making sure all trash cans are sealed and emptied at night rather than in the morning, are also effective. Outdoor physical controls involve common sense strategies like directing water away from structures (via guttering, proper placement of stairs), moving woodpiles away from buildings, and removing rotting carpentry or old stumps.

Biological controls. Natural enemies of pests (such as parasitic wasps, nematodes, and ladybugs), microbial agents (such as Bacillus thuringiensis and certain fungi), plant extracts, and insect hormones (pheromones) that disrupt normal mating and development are all strategies that capitalize on natural checks and balances to control problem pests. Biological controls are a burgeoning field of research, with news of new discoveries and potential products appearing all the time. Some of these may have toxicity implications for non-target organisms and require careful scrutiny before adoption.

Cultural controls. Farming strategies such as crop rotation and cover crops to break up weed and insect cycles, mulching, and building up soil structure and natural biotic communities (e.g. earthworms) are among the many different cultivation techniques that keep harmful pests in check.

Least toxic controls. Certain low risk pesticides or other agents can aid in getting infestations under control. Examples include boric acid and silica gels for household pests, and solutions of vinegar, soap, or garlic, for outdoor insects and fungi. EPA maintains a list of pesticides that are of such low risk they are exempt from regulation and EPA also has a fast-track registration process for reduced risk pesticides in order to increase the number of lower risk products available so that higher risk ones can be reduced or eliminated.

Numerous resources are available to find out more about specific alternative approaches to common household pest problems and crop pests alike. Several recent reports give farming case histories of shifts away from pesticides and resources for alternative pest control in agriculture (1) and organizations like the Pesticide Action Network of North America, the Henry A. Wallace Institute for Alternative Agriculture, and some academic institutions have further resources and breaking research to offer. Information on non-agricultural alternatives is available from a host of comprehensive reference books (2) and public interest groups, including the New York Coalition for Alternatives to Pesticides, the Bio-Integral Resource Center, the Northwest Coalition for Alternatives to Pesticides, and the Green Thumb Project (3). Numerous alternative product lines also exist.

(1) Consumers Union of U.S. 1998. Worst First: High-Risk Insecticides in Children’s Foods and Safer Alternatives. Consumers Union. Washington D.C. see also Curtis, J. 1998. Fields of Change: A New Crop of American Farmers Finds Alternatives to Pesticides. Natural Resources Defense Council. Washington D.C. see also Benbrook, C. et al. 1996. Pest Management at the Crossroads. Consumers Union. Washington D.C.
(2) For example, Olkowski, W. et al. 1991. Common-Sense Pest Control. The Taunton Press. Newtown, CT. (3) For information on how to reach these organizations, please contact Environmental Advocates or NYPIRG.

 Food Quality Protection Act of 1996

In 1996, Congress unanimously passed the Food Quality Protection Act (FQPA), which reformed the laws governing pesticides in a myriad of ways. Among its key provisions are the following:

1. The allowable residues (known as “tolerances”) of pesticides in food, whether raw or processed, must meet a new safety standard: a reasonable certainty of no harm from aggregate exposure to the pesticide from all sources. In addition, safety must now be assessed by looking at all pesticides with the same toxic effect, an approach that reflects more realistic exposure patterns. Previously, there was no articulated safety standard. Pesticides were registered by balancing risks and benefits, and meeting the tepid criterion that the pesticide would “not generally cause unreasonable adverse effects on the environment.”

2. When setting tolerances, EPA must now specifically assess the impact on infants and children, taking into account their unique eating habits, particular vulnerability to toxic chemicals, and cumulative exposure to all pesticides that have the same toxic effect. EPA must then make a finding that aggregate exposure to the pesticide will not result in harm to infants or children. Children, because of their immature nervous and immune systems, smaller body size, and higher metabolic rates, are more susceptible to the toxic effects of chemicals and require greater protections than do adults, but our regulatory system had previously failed to account for this.

3. All chemicals, pesticides included, must be assessed for whether they have the capacity to act as hormones, or to interfere with normal hormone actions. Such effects are known as endocrine disruption.

Proceeding with a strategy of reassessing the worst pesticides first, EPA has begun with the category of insecticides known as organophosphates, to be followed by the carbamate insecticides. Both of these insecticide classes interfere with an enzyme necessary for the proper functioning of the nervous system in insects — cholinesterase. Unfortunately, this is also an essential nervous system enzyme in humans and all other animals. What these poisons do to insects, therefore, they can do to us as well. Organophosphates and carbamates are also among the most widely used pesticides, both in New York State and across the country. Their reevaluation is thus imperative.

In August, EPA released recommendations related to assessing organophosphate risks to infants and children. These will potentially reduce the margin of safety used to set child-protective standards for certain pesticides. More recently, EPA released draft risk assessments on 16 of the 40 organophosphates under review (the other 24 assessments are still being developed). Interested parties, from public health and environmental groups, to industry, are currently reviewing these initial risk assessments. Once all of the risk assessments have been released and comments regarding them have been submitted to EPA, a time of reckoning begins — EPA’s final decisions regarding tolerance reassessment based on these risk assessments will determine whether the reassessment process ultimately achieves the kind of protection embodied in and required by FQPA, or whether the clear moral and legal imperative to keep children safe will be subverted. In the meantime substantial delays in the federal review process, though they serve the interests of the agribusiness lobby, do not serve the public.

 Table 1

Total Amount of Pesticide Products Applied by Commercial Applicators and Sold to Farmers in New York State - 1997

Gallons

User Category	New York State Total
Commercial Applicators	1,894,223
Sales to Farmers	470,743
Total	2,364,966

Pounds

User Category	New York State Total
Commercial Applicators		13,771,940
Sales to Farmers	2,938,225
Total	16,710,165

Source: 1997 NYSDEC Pesticide Sales and Application Database

 Table 2

Counties and Amount of Pesticide Products Applied by
Commercial Applicators and Sold to Farmers in New York State - 1997
County	Sales to Farmers		Commercial Applicator Use		Total
	Gallons	Pounds	Gallons	Pounds	Gallons	Pounds
ALBANY	357	2,776	17,331	218,033	17,688	220,809
ALLEGANY	2,789	9,626	1,325	9,317	4,114	18,943
BRONX	135	10	16,957	636,779	17,092	636,789
BROOME	924	5,715	6,165	167,118	7,089	172,833
CATTARAUGUS	3,833	5,604	5,631	33,295	9,464	38,899
CAYUGA	16,710	62,338	703	279,264	17,413	341,602
CHAUTAUQUA	6,178	55,261	10,940	88,857	17,118	144,118
CHEMUNG	247	748	1,158	67,354	1,405	68,102
CHENANGO	1,124	13,003	15,061	13,475	16,185	26,478
CLINTON	11,962	76,246	889	8,978	12,851	85,224
COLUMBIA	7,350	40,034	9,618	18,733	16,968	58,767
CORTLAND	1,124	12,525	2,629	962,682	3,753	975,207
DELAWARE	810	674	8,226	16,710	9,036	17,384
DUTCHESS	89	17,598	6,834	145,406	6,923	163,004
ERIE	3,976	47,151	76,489	521,019	80,465	568,170
ESSEX	731	15,610	555	16,202	1,286	31,812
FRANKLIN	8,166	10,384	2,545	25,318	10,711	35,702
FULTON	392	10	959	16,268	1,351	16,278
GENESEE	37,381	158,691	9,453	21,566	46,834	180,257
GREENE	200	957	1,844	479,585	2,044	480,542
HAMILTON	0	0	345	10,408	345	10,408
HERKIMER	1,848	1,306	27,068	16,816	28,916	18,122
JEFFERSON	1,795	16,026	4,097	99,741	5,892	115,767
KINGS	148	0	57,521	2,587,055	57,669	2,587,055
LEWIS	1,764	1,266	2,208	42,060	3,972	43,326
LIVINGSTON	28,448	144,039	7,711	26,002	36,159	170,041
MADISON	2,929	4,261	8,986	55,561	11,915	59,822
MONROE	25,982	151,360	27,744	581,724	53,726	733,084
MONTGOMERY	2,213	868	2,656	17,862	4,869	18,730
NASSAU	1,228	9,886	404,144	1,293,278	405,372	1,303,164
NEW YORK	1,871	0	561,516	1,016,991	563,387	1,016,991
NIAGARA	23,810	218,448	10,358	110,581	34,168	329,029
ONEIDA	4,339	37,288	5,449	153,770	9,788	191,058
ONONDAGA	13,054	55,850	16,388	452,534	29,442	508,384
ONTARIO	17,706	90,559	9,834	144,241	27,540	234,800
ORANGE	51,927	49,672	10,627	129,747	62,554	179,419
ORLEANS	26,222	197,185	2,727	7,029	28,949	204,214
OSWEGO	15,673	24,410	6,478	104,437	22,151	128,847
OTSEGO	180	3,212	4,837	3,821	5,017	7,033
PUTNAM	0	3,004	2,535	63,729	2,535	66,733
QUEENS	1,605	0	27,615	95,099	29,220	95,099
RENSSELAER	2,909	11,426	5,380	54,199	8,289	65,625
RICHMOND	10	0	2,655	64,232	2,665	64,232
ROCKLAND	389	434	19,382	200,072	19,771	200,506
SARATOGA	2,434	20,278	9,484	202,379	11,918	222,657
SCHENECTADY	122	530	4,126	65,517	4,248	66,047
SCHOHARIE	584	897	3,448	6,479	4,032	7,376
SCHUYLER	228	1,835	1,014	3,151	1,242	4,986
SENECA	3,892	18,302	6,987	12,918	10,879	31,220
ST. LAWRENCE	1,520	400	3,039	56,064	4,559	56,464
STEUBEN	32,849	136,476	3,231	32,546	36,080	169,022
SUFFOLK	730	16,869	162,120	1,003,467	162,850	1,020,336
SULLIVAN	5	0	3,213	2,165	3,218	2,165
TIOGA	1,552	5,369	1,558	25,834	3,110	31,203
TOMPKINS	943	10,840	2,709	52,596	3,652	63,436
ULSTER	280	4,292	5,953	44,749	6,233	49,041
WARREN	8	0	12,844	37,682	12,852	37,682
WASHINGTON	4,396	46,200	14,025	13,021	18,421	59,221
WAYNE	45,281	704,187	3,042	58,058	48,323	762,245
WESTCHESTER	98	13,601	95,936	667,367	96,034	680,968
WYOMING	30,084	210,710	11,835	13,992	41,919	224,702
YATES	11,962	137,179	1,177	5,717	13,139	142,896
UNKNOWN	3,680	54,828	124,846	391,274	128,526	446,102

Source: 1997 NYSDEC Pesticide Sales and Application Database

 Table 3 

Counties Ranked by Amount of Pesticide Products Applied by
Commercial Applicators and Sold to Farmers in New York State - 1997
Rank	Sales to Farmers		Commercial Applicator Use		Total
	Gallons	Pounds	Gallons	Pounds	Gallons	Pounds
1	ORANGE	WAYNE	NEW YORK	KINGS	NEW YORK	KINGS
2	WAYNE	NIAGARA	NASSAU	NASSAU	NASSAU	NASSAU
3	GENESEE	WYOMING	SUFFOLK	NEW YORK	SUFFOLK	SUFFOLK
4	STEUBEN	ORLEANS	UNKNOWN	SUFFOLK	UNKNOWN	NEW YORK
5	WYOMING	GENESEE	WESTCHESTER	CORTLAND	WESTCHESTER	CORTLAND
6	LIVINGSTON	MONROE	ERIE	WESTCHESTER	ERIE	WAYNE
7	ORLEANS	LIVINGSTON	KINGS	BRONX	ORANGE	MONROE
8	MONROE	YATES	MONROE	MONROE	KINGS	WESTCHESTER
9	NIAGARA	STEUBEN	QUEENS	ERIE	MONROE	BRONX
10	ONTARIO	ONTARIO	HERKIMER	GREENE	WAYNE	ERIE
11	CAYUGA	CLINTON	ROCKLAND	ONONDAGA	GENESEE	ONONDAGA
12	OSWEGO	CAYUGA	ALBANY	UNKNOWN	WYOMING	GREENE
13	ONONDAGA	ONONDAGA	BRONX	CAYUGA	LIVINGSTON	UNKNOWN
14	CLINTON	CHAUTAUQUA	ONONDAGA	ALBANY	STEUBEN	CAYUGA
15	YATES	UNKNOWN	CHENANGO	SARATOGA	NIAGARA	NIAGARA
16	FRANKLIN	ORANGE	WASHINGTON	ROCKLAND	ONONDAGA	ONTARIO
17	COLUMBIA	ERIE	WARREN	BROOME	QUEENS	WYOMING
18	CHAUTAUQUA	WASHINGTON	WYOMING	ONEIDA	ORLEANS	SARATOGA
19	WASHINGTON	COLUMBIA	CHAUTAUQUA	DUTCHESS	HERKIMER	ALBANY
20	ONEIDA	ONEIDA	ORANGE	ONTARIO	ONTARIO	ORLEANS
21	ERIE	OSWEGO	NIAGARA	ORANGE	OSWEGO	ROCKLAND
22	SENECA	SARATOGA	ONTARIO	NIAGARA	ROCKLAND	ONEIDA
23	CATTARAUGUS	SENECA	COLUMBIA	OSWEGO	WASHINGTON	GENESEE
24	UNKNOWN	DUTCHESS	SARATOGA	JEFFERSON	ALBANY	ORANGE
25	MADISON	SUFFOLK	GENESEE	QUEENS	CAYUGA	BROOME
26	RENSSELAER	JEFFERSON	MADISON	CHAUTAUQUA	CHAUTAUQUA	LIVINGSTON
27	ALLEGANY	ESSEX	DELAWARE	CHEMUNG	BRONX	STEUBEN
28	SARATOGA	WESTCHESTER	LIVINGSTON	SCHENECTADY	COLUMBIA	DUTCHESS
29	MONTGOMERY	CHENANGO	SENECA	RICHMOND	CHENANGO	CHAUTAUQUA
30	NEW YORK	CORTLAND	DUTCHESS	PUTNAM	YATES	YATES
31	HERKIMER	RENSSELAER	OSWEGO	WAYNE	WARREN	OSWEGO
32	JEFFERSON	TOMPKINS	BROOME	ST. LAWRENCE	CLINTON	JEFFERSON
33	LEWIS	FRANKLIN	ULSTER	MADISON	SARATOGA	QUEENS
34	QUEENS	NASSAU	CATTARAUGUS	RENSSELAER	MADISON	CLINTON
35	TIOGA	ALLEGANY	ONEIDA	TOMPKINS	SENECA	CHEMUNG
36	ST. LAWRENCE	BROOME	RENSSELAER	ULSTER	FRANKLIN	PUTNAM
37	NASSAU	CATTARAUGUS	OTSEGO	LEWIS	ONEIDA	SCHENECTADY
38	CHENANGO	TIOGA	SCHENECTADY	WARREN	CATTARAUGUS	RENSSELAER
39	CORTLAND	ULSTER	JEFFERSON	CATTARAUGUS	DELAWARE	RICHMOND
40	TOMPKINS	MADISON	SCHOHARIE	STEUBEN	RENSSELAER	TOMPKINS
41	BROOME	OTSEGO	STEUBEN	LIVINGSTON	BROOME	MADISON
42	DELAWARE	PUTNAM	SULLIVAN	TIOGA	DUTCHESS	WASHINGTON
43	ESSEX	ALBANY	WAYNE	FRANKLIN	ULSTER	COLUMBIA
44	SUFFOLK	SCHUYLER	ST. LAWRENCE	GENESEE	JEFFERSON	ST. LAWRENCE
45	SCHOHARIE	HERKIMER	ORLEANS	COLUMBIA	OTSEGO	ULSTER
46	FULTON	LEWIS	TOMPKINS	MONTGOMERY	MONTGOMERY	LEWIS
47	ROCKLAND	GREENE	MONTGOMERY	HERKIMER	ST. LAWRENCE	CATTARAUGUS
48	ALBANY	SCHOHARIE	RICHMOND	DELAWARE	SCHENECTADY	WARREN
49	ULSTER	MONTGOMERY	CORTLAND	FULTON	ALLEGANY	FRANKLIN
50	CHEMUNG	CHEMUNG	FRANKLIN	ESSEX	SCHOHARIE	ESSEX
51	SCHUYLER	DELAWARE	PUTNAM	WYOMING	LEWIS	SENECA
52	GREENE	SCHENECTADY	LEWIS	CHENANGO	CORTLAND	TIOGA
53	OTSEGO	ROCKLAND	GREENE	WASHINGTON	TOMPKINS	CHENANGO
54	KINGS	ST. LAWRENCE	TIOGA	SENECA	SULLIVAN	ALLEGANY
55	BRONX	FULTON	ALLEGANY	HAMILTON	TIOGA	MONTGOMERY
56	SCHENECTADY	BRONX	YATES	ALLEGANY	RICHMOND	HERKIMER
57	WESTCHESTER	RICHMOND	CHEMUNG	CLINTON	PUTNAM	DELAWARE
58	DUTCHESS	KINGS	SCHUYLER	ORLEANS	GREENE	FULTON
59	RICHMOND	SULLIVAN	FULTON	SCHOHARIE	CHEMUNG	HAMILTON
60	WARREN	NEW YORK	CLINTON	YATES	FULTON	SCHOHARIE
61	SULLIVAN	HAMILTON	CAYUGA	OTSEGO	ESSEX	OTSEGO
62	HAMILTON	WARREN	ESSEX	SCHUYLER	SCHUYLER	SCHUYLER
63	PUTNAM	QUEENS	HAMILTON	SULLIVAN	HAMILTON	SULLIVAN

Source: 1997 NYSDEC Pesticide Sales and Application Database

 Table 4

Total Amount of Pesticide Products Applied by Commercial Applicators and
Sold to Farmers in New York State Containing Active Ingredients with Listed Health Hazards - 1997
Health Hazard	Sales to Farmers		Commercial Applicator Use		Total
	Gallons	Pounds	Gallons	Pounds	Gallons	Pounds
Known Carcinogens(1)	0	0	7,826	1,438,515	7,826	1,438,515
Probable and Likely Carcinogens(1)	95,547	897,525	50,439	287,819	145,986	1,185,344
Possible Carcinogens(1)	189,728	288,007	425,906	3,425,523	615,634	3,713,530.16
Reproductive/Developmental Toxins(2)	4,815	182,140	14,686	1,516,814	19,501	1,698,954
Neurotoxins(3)	50,344	550,044	875,231	5,900,881	925,575	6,450,925
Endocrine Disruptors(4)	163,449	764,878	460,443	1,505,089	623,893	2,269,968

Source: 1997 NYSDEC Pesticide Sales and Application Database
(1)Office of Pesticide Programs. 1998. Office of Pesticide Programs List of Chemicals Evaluated for Carcinogenic Potential. United States Environmental Protection Agency. Washington D.C. Memorandum dated June 11, 1998.
(2)Office of Environmental Health Hazard Assessment. 1998. List of Chemicals Known to the State to Cause Cancer or Reproductive Toxicity. California Environmental Protection Agency. Sacramento.
(3)Neurotoxin amounts were calculated by totalling up all organophosphate and carbamate insecticides.
(4)Colborn, T. 1998. Endocrine disruption from environmental toxicants. in: Environmental and Occupational Medicine, Third Edition. ed. Rom W.N. Philadelphia: Lippincott-Raven Publishers. pp. 807-816.
 

 Table 5

Most Heavily Used Active Ingredients in New York State,
Ranked by Prevalence - 1997
Rank	Sales to Farmers
	Gallons	Pounds
1	Atrazine	Tefluthrin
2	Metolachlor	Mancozeb
3	Pendimethalin	Captan
4	Maneb	Sulfur
5	Petroleum distillate, oils, solvents, etc.	Chlorpyrifos
6	Glyphosate	Metiram
7	Alachlor	Alachlor
8	Chlorothalonil	Zinc phosphide
9	Dicamba	Methyl bromide
10	EPTC	Atrazine
11	Methyl parathion	Basic cupric sulfate
12	2,4-D	Copper chloride hydroxide
13	Chlorpyrifos	Maneb
14	Maleic hydrazide	Cyanazine
15	Paraquat dichloride	Azinphos-Methyl
Rank	Commercial Applicator Use
	Gallons	Pounds
1	Chlorpyrifos	Chlorpyrifos
2	Petroleum distillate, oils, solvents, etc.	Pendimethalin
3	Permethrin	Chromic acid
4	Cyfluthrin	Copper(II) oxide
5	Atrazine	Arsenic acid anhydride
6	Carbaryl	Benfluralin
7	Pendimethalin	Trifluralin
8	Metolachlor	Imidacloprid
9	Diazinon	Diazinon
10	2,4-D	2,4-D
11	Sodium hypochlorite	Mecoprop
12	Glyphosate	Dicamba
13	Bromadiolone	Piperonyl butoxide
14	Dicamba	Pyrethrins
15	Dimethylamine 2-(2-methyl-4-chlorophenoxy)propionate	Trichlorfon
Rank	Total
	Gallons	Pounds
1	Chlorpyrifos	Chlorpyrifos
2	Petroleum distillate, oils, solvents, etc.	Pendimethalin
3	Atrazine	Arsenic acid anhydride
4	Permethrin	Chromic acid
5	Cyfluthrin	Copper(II) oxide
6	Pendimethalin	Benfluralin
7	Metolachlor	Imidacloprid
8	Carbaryl	Trifluralin
9	Glyphosate	Diazinon
10	2,4-D	2,4-D
11	Maneb	Mecoprop
12	Diazinon	Dicamba
13	Sodium hypochlorite	Piperonyl butoxide
14	Alachlor	Pyrethrins
15	Dicamba	Mancozeb

Source: 1997 NYSDEC Pesticide Sales and Application Database

 Maps 

Map 1
Map 2
Map 3
Map 4

 Water Contamination

In addition to requiring pesticide use and sales reporting, the Pesticide Reporting Law also established the Water Quality Monitoring for Pesticides Program at DEC. The purpose of this program is to gather information on water contamination in order to make informed regulatory decisions about pesticide use and availability. When viewed together with the pesticide use and sales reporting data, these water monitoring data greatly enhance the picture of pesticide impacts in the State.

DEC has approached this new statutory charge by entering into partnerships with the USGS and the Suffolk County Department of Health Services to conduct ground water, surface water, and well monitoring in various parts of the State. The partnership also includes the New York Water Resources Institute, which is exploring modeling as a tool for estimating water quality impacts. The results reported this July 1998,49 along with the pesticide use and sales data, confirm that pesticide contamination of water is a significant issue in New York State.

I. United States Geological Survey Reports
Examining 64 streams and rivers draining a variety of land use types — agricultural, forest, urban and suburban — the USGS found 25 of the 47 pesticides for which it sampled in 1997,50 and discovered that contamination patterns parallel pesticide use patterns. The most frequently detected pesticides were the herbicides atrazine (found in 97% of the samples), metolachlor (found in 89%), a toxic atrazine breakdown product deethylatrazine (in 88% of the samples), simazine (72%) alachlor (50%) and cyanazine (41%). All but simazine are among the top active ingredients sold to farmers in New York State (see Table 5). All but deethylatrazine (which has not yet been evaluated for cancer risk) is classified as a probable, likely or possible human carcinogen. The highest concentrations of atrazine, metolachlor, and deethylatrazine were found in corn producing areas in western New York.

Carbaryl, diazinon, and chlorpyrifos, all of which are among the most heavily used insecticides by commercial applicators in New York, show up in 20%, 14%, and 11% of the samples respectively. Carbaryl and diazinon were found most often in urban and suburban areas in southeastern New York, including Long Island. Carbaryl was also frequently found in urban and suburban areas in western New York, and in orchard and vineyard areas. Diazinon and the highly hazardous organophosphate insecticide azinphos-methyl, were found at levels exceeding the State’s criteria for protection of aquatic life. Details on where chlorpyrifos was detected were not available.

The USGS states that the levels of pesticides found in this study were generally low. There are two reasons why this statement offers little reassurance. The first is that the water samples for this study were taken during low-flow conditions and thus do not represent maximum annual contamination levels. Another, sobering USGS study indicates just how high such concentrations can get. A 1996 USGS report on the Canajoharie Creek in the Hudson River Basin, which was not included in DEC’s annual report, found atrazine, metolachlor, cyanazine and deethylatrazine in every water sample taken. 51 Furthermore, it found that “(s)amples collected in June 1996 contained the highest observed concentrations of atrazine, metolachlor, simazine, pendimethalin, alachlor, and carbaryl to date.” Most disturbing, the median concentration of atrazine was above the drinking water standard, known as the maximum contaminant level (MCL). Of this list, all but simazine are among the most heavily sold to farmers for applications on their crops.

The second reason for concern relates to the drinking water standards themselves. The report states that “...no concentrations exceed federal health advisory or maximum contaminant levels.”52 But chemical specific drinking water standards — MCLs — do not exist for most of the pesticides detected in this study. MCLs exist only for atrazine, simazine, and alachlor. All of the other pesticides detected have not been assigned MCLs, though some have been assigned a federal health advisory level (HAL), a figure that deals only with non-cancer effects and thus does not represent a full assessment of the pesticides’ hazards. Many pesticides have neither an MCL nor an HAL assigned to them.

Furthermore, the MCL is not the level at which the contaminant poses no known adverse effect. The standard which ostensibly represents no known adverse health is called the maximum contaminant level goal (MCLG). For some chemicals, the MCLG is zero. Of the pesticides detected in this study, alachlor has an MCLG of zero, meaning that any detection transgresses a safety level. In short: only three of the pesticides highlighted in this study have been assigned specific drinking water standards that deal with both cancer and non-cancer effects, and one of those pesticides is considered potentially unsafe at any level of detection. Statements that safety standards were not exceeded by the levels of contamination found in this report are therefore misleading.

II. Suffolk County Department of Health Services
Data from Suffolk County, which tested groundwater for pesticides in both Nassau and Suffolk Counties, reached conclusions even more discomfiting than those from the USGS studies.53 Two hundred and thirty-four wells, (26% of the total tested) showed the presence of at least one pesticide or metabolite. Ten percent of the wells showed pesticide concentrations that exceeded drinking water standards, and, according to the report: “(t)he vast majority of the exceedences were from wells located in agricultural areas of Suffolk County. Eleven wells in the agricultural areas exceeded MCLs for more than one pesticide or metabolite compound.” In addition: “Four public (community) supply wells exceeded pesticide MCLs,”54 and are retrofitted with carbon filters at an unspecified cost to the municipality and its taxpayers.

In general, the most glaring contamination was not linked to homeowner use or residential pesticide applications, but to agriculture, past and current. The report states: “The interim results of the study demonstrate the vulnerability of Long Island’s groundwater to impact from pesticides and their metabolites, particularly to agricultural chemicals applied to the land surface.”55

The report hastens to note that half of the wells sampled for this study were chosen because of their high potential for contamination and so these results may not be representative of overall contamination rates. It also notes that many of the pesticides detected are now banned and their presence represents residual contamination. Pesticides can indeed contaminate groundwater for decades or even longer after they have been banned. Residual contamination from older pesticides is both a real problem and a caution against allowing fresh contamination. But the data also show that fresh contamination is occurring. Metolachlor, for example, one of the pesticides detected in this study, is in heavy current use. Furthermore, many high use pesticides were not even part of the testing protocol. Chlorpyrifos, the dominant insecticide in the State, cyanazine, a well known water contaminant, pendimethalin, trifluralin, and azinphos methyl are all among the most heavily used pesticides in the State, all were detected in the USGS studies above, and yet all are missing from the testing list in Suffolk County.

Even with this last limitation, the Suffolk County and USGS studies are striking confirmation that pesticide contamination is a serious problem requiring an aggressive regulatory response. EPA has also recognized the need to respond to this hazard and is requiring all states to submit State Management Plans (SMPs) for reducing contamination risks from five of the most common water-contaminating pesticides — the herbicides alachlor, atrazine, cyanazine, metolachlor, and simazine.56 EPA must approve of the actions each state proposes to take to reduce contamination, or the targeted pesticides (four of which are among the most heavily used in New York State) can no longer be used or sold in the state. An early draft of New York’s SMP was not approved by EPA, but DEC is waiting to resubmit a plan when final federal regulations are released. The SMP is an ideal opportunity for the State to take action on these known hazards.

 Recommendations  

For decades, regulators have focused on registering a massive number of chemical pesticides, certifying tens of thousands of people to apply these poisons in our homes, schools, public places and on our food, and doing very little to promote non-toxic alternatives to pesticides. But the Pesticide Reporting Law has now clearly revealed substantial use of highly toxic pesticides in New York State. State officials must now act to reduce and eventually eliminate the health and ecological risks associated with the use of these pesticides. The time to get off this chemical treadmill has arrived.

The following policy recommendations, if adopted, would signal a major shift away from the heavy use of pesticides and toward public health and environmental protection.

I. BAN THE WORST PESTICIDES
New York State should ban use of the most hazardous pesticides based on clear toxicological criteria. Currently, for a pesticide product to be used in New York State it must be registered both by the EPA and by DEC. The registration process involves a review of the toxicological and environmental effects data for each pesticide. Either DEC or EPA can reject or revoke a pesticide's registration based on this review.

DEC is under no obligation to rubber stamp every product that meets with federal approval. There are several instances where New York State has led the nation in banning or restricting certain high hazard pesticides (aldicarb and chlordane, for example). It is time for New York State to be out in front again and to set a date certain after which the registration for any pesticide that meets one of the following toxicological criteria will be revoked:

• Carcinogenicity (known, probable, or likely carcinogens, as classified by EPA)
• High acute toxicity (as defined by EPA Toxicity category)
• Endocrine disruption activity
• Developmental or reproductive toxicity

Creating such a list will take time. It will require that the agencies delve into the current scientific literature and review information on thousands of different pesticide products. Much of this information already exists in DEC and DOH product registration files. The framework and authority for making the remaining toxicological judgments also exists and DEC and DOH, through their own research and programs, can augment any incomplete information.

For example, the process would begin with EPA's carcinogenicity classifications. Acute toxicity can then be determined from the "Toxicity Category" assigned to each product by EPA (Toxicity Categories I and II are the most acutely toxic). A major testing program to determine which chemicals (including pesticides) are endocrine disruptors, has just been launched by EPA and will yield data in the next few years. Developmental and reproductive toxins can be determined from certain existing lists (such as the California Proposition 65 lists used for this report) and by research into the epidemiological and toxicological literature.

Examples of pesticides which would be eliminated by this approach are: known carcinogens such as arsenic acid anhydride and chromic acid; probable carcinogens such alachlor, captan, chlorothalonil, maneb and mancozeb; highly acutely toxic pesticides such as methyl bromide, azinphos-methyl, methyl parathion, and terbufos; endocrine disruptors such as endosulfan and atrazine; and developmental and reproductive toxins warfarin and vinclozolin.

Such a move would represent a fundamental change in the way government regulates the use of pesticides. Pesticide exposure is different from other environmental health challenges. Most air and water pollution is the by-product of combustion and manufacturing, and exposure to it has little to do with the purpose of the manufacturing process. Likewise, with the exception of "midnight dumpers," few people purposefully set out to create a toxic waste site. But pesticides are created to cause harm and are not applied by mistake. They are widely used and do predictable damage. Government regulators routinely approve the use of pesticides that are known to cause cancer and other serious health effects. Banning the worst pesticides would be the first step in reversing this course and ameliorating risk.

II. USE THE PESTICIDE REPORTING DATA TO IDENTIFY THE GREATEST HAZARDS TO NEW YORKERS
This report is just an initial foray into understanding the hazards revealed by the pesticide use and sales data. The public is limited as to what it can do with this data because we do not have access to site-specific information and information on target pests. But DEC and DOH do have such access, as do researchers that have been approved by the Health Research Science Board (also established under the Pesticide Reporting Law under the auspices of DOH). Government and independent researchers should seize the opportunity to use the data to identify hazards and opportunities for hazard reduction. For example:

• Knowing which pests receive the greatest treatments with highly toxic pesticides can guide government initiatives to shift to less toxic methods. Cornell Cooperative Extension Service should capitalize on this knowledge to promote known alternatives and develop new ones for high priority pest problems.
• DOH maintains cancer and birth defects registries for the State. The new pesticide use and sales data can be compared with these, and any other sources of information that might help identify disease patterns to determine what, if any, links exist between illness and pesticide use (this was the methodology employed in a birth defects study cited earlier).57
• Use and sales of those pesticides that pose the greatest water contamination hazards can be compared to areas of known vulnerability (such as wellheads and aquifer recharge areas) and existing water monitoring data to make decisions about product restrictions and bans, and to do targeted water monitoring.

There are numerous ways to use the newfound knowledge represented by the pesticide reporting data and it should be a State priority to do so.

III. ACTIVELY PROMOTE ALTERNATIVE PEST MANAGEMENT STRATEGIES
In order to promote safer, and non-chemical means of pest control, New York State should establish the following new programs:

• Pesticide Research and Education Initiative. DEC focuses the bulk of its attention on pesticide registration and applicator certification with little effort to proactively reduce pesticide use. One way to shift this emphasis would be to establish a Pesticide Research and Education Initiative to award grants to local governments, cooperative extension offices and non-profit organizations that aim to educate pesticide users, citizens, businesses, institutions, and government agencies about non-toxic alternatives to pesticide use. The pesticide use and sales data can guide DEC in identifying the most pressing pesticide hazards in need of alternatives.
• Office of Organic Agriculture. Consumers want to buy organic products - commodities that were grown or raised without the use of chemical pesticides. The demand for organic products has increased dramatically in the past few years (20% annually since 1990),58 even though they are frequently expensive. New York State is missing an important economic opportunity if it ignores the market demand for organic products. Organic farmers are the future of agriculture (also its bedrock from pre-chemical days). They provide essential products without the damaging effects of chemical pesticides and fertilizers, yet they are virtually ignored in New York State policymaking. The New York State Department of Agriculture and Markets should establish an Office of Organic Agriculture to support and expand organic farming opportunities in New York State.

In addition, DEC should also revise its certified pesticide applicator programs to incorporate information about non-toxic pest control. Pest control does not have to involve pesticides, but unless the people doing the work are familiar with other modes of operation, we will remain stuck in old and dangerous habits. California DPR is in the process of revising its licensing requirements for prospective agricultural pest control advisers to enhance their knowledge of reduced-risk pest control methods.59 New York State should follow suit.

IV. EXPAND AND IMPROVE THE PUBLIC’S RIGHT TO KNOW
Improve the Pesticide Reporting Law and Data Base

Though groundbreaking, the pesticide reporting data could be more accurate, more useful to a wider range of people, and less demanding of government resources, with the following changes:

• All data, not just summaries, should be available to the public. Without the details of where and why pesticides are being used, people cannot get a precise idea of their exposure. The information submitted to the state and kept on-site by applicators is relatively detailed; the information provided to the public is less so. The public has access to the name and amount of each pesticide product used in a given zip code or county. This does not tell us the purpose for the pesticide use (which could be used to facilitate the development of alternatives) or precisely when and where such use occurred (which could be used to assess actual exposure scenarios).
• Pesticide applicators and sellers should be required to file their reports with DEC electronically. This would increase accuracy and cause significantly less of a financial and staff time drain on DEC and Cornell Cooperative Extension resources. We live in an electronic world with a wide array of electronic reporting options to suit each reporting entity. California’s pesticide use and sales reporting system is entirely electronic; New York State’s should be as well.
• Farmers should report direct use of all pesticide products, as commercial applicators are required to do, and they should be required to keep the same detailed information on all pesticide use that commercial applicators do (right now, farmers keep sketchier information on restricted use products only). Although sales to farmers is a workable surrogate for actual use by farmers, it is far from ideal. Actual use reporting would give agricultural and integrated pest management researchers real, site-specific data to work with. This would require a statutory change.
• Farmers and commercial applicators should report all the data points now kept on-site to DEC, not just a select few. Under current statutory requirements, commercial applicators report product, quantity, date and location of application. But they also keep the following information, crucial to understanding why pesticides are being used, on-site: dosage rates, methods of application, and target organism. DEC and DOH have access to this on-site information, but it requires a site visit to obtain it. This information is essential for formulating policy responses to pesticide use and should be mandatory for all commercial applicators and farmers to submit. This would also require a statutory change.
• Aggregate statewide sales of all pesticides should be reported. Without overall sales data, there is no way to estimate the volume of homeowner use in order to generate a full picture of pesticide use and exposure in the State. If total sales data were available, commercial applicator data and farmer sales data could be compared to it to yield an estimate of homeowner use.
• Inert ingredients should be reported.
• DEC should express all the data in pounds. The most glaring problem with the data as presented is the fact that there are two units of measurement: gallons and pounds. This makes overall totals and rankings difficult. DEC does not need to report the data this way. California’s DPR gathers all the necessary information to convert gallons to pounds itself before it releases its data. As a result, the California data is simpler and easier to assess.

Adopt a Neighbor Notification Policy

Legislation passed by the State Assembly in 1998, but abandoned by the State Senate, would require companies that apply pesticides to notify neighbors 48 hours in advance and schools to inform parents of pesticide use. This prior notification is supported by every major environmental organization in the State but opposed by pesticide applicators, who are concerned about the additional paperwork that would be required and the public’s growing awareness of the risks their products present. Yet everyone deserves the chance to protect themselves and their families against toxic exposure. Using toxic chemicals should carry with it the minimal responsibility to inform.

V. HAVE GOVERNMENT LEAD BY EXAMPLE
Phase Out Government Use of Pesticides

In 1996, the City and County of San Francisco adopted an ordinance phasing out the use of most pesticides on municipal property. This pioneering initiative should be replicated in every community in the State and by New York State government itself. Dubbed the “Pesticide Sunset,” it has already been adopted by Albany County — the first local government in New York State to do so — this past June, 1998. Similar efforts are pending in a number of other municipalities and there is a legislative proposal to accomplish this at the state level in the State Assembly (though it was not acted on by the State Senate in 1998). Government phase-out of pesticides is an admirable way to both lead by example and develop a host of practical alternative pest control solutions to share with the private sector.

Eliminate The Use of Herbicides by the Department of Transportation:

New York State maintains thousands of miles of state roads, a number of which are sprayed with herbicides to control weed growth on median strips and highway shoulders. Not only does the use of herbicides to control roadside vegetation pose potential ecological and health risks, but it also results in large swaths of brown vegetation in the summertime that are not aesthetically pleasing.

In recent years, the New York State Department of Transportation (DOT) has reduced the use of roadside herbicides, primarily through an increase in the use of mowing equipment to control weeds. Numerous other technological and cultural strategies (such as planting low, dense vegetation) exist to allow DOT to phase out the use of all herbicides. DOT has begun to take steps in this direction by launching a Rochester-area demonstration project, in response to concerns raised by local citizens, to maintain certain roadside areas without the use of herbicides and by drafting a “Request for Proposals” for strategies and equipment that would maintain vegetation height under guide rails without the use of herbicides. With more effort, and the necessary resources, DOT could be a model for local highway departments to phase out the use of all herbicides on all roadways.

Establish a Procurement Preference for Organic Products

In the 1980s, New York decided to support the emerging recycling industry by establishing a preference for the purchase of recycled products. Everything from recycled paper to recycled oil filters was promoted by articulating a preference for these products and allowing a somewhat higher price to be paid for them. New York State, local governments and school districts should establish a similar price preference for organic products. Providing organic food in school and State University cafeterias, at state hospitals, and throughout the prison system and all state-run cafeterias, would not only be healthy and nutritious, but would also significantly stimulate the demand for organic produce.

VI. ENFORCE THE WORKER PROTECTION STANDARD FOR FARMWORKERS
Though often neglected in the pesticide debate, farmworkers and their children are routinely exposed to high levels of pesticides. The federal Worker Protection Standard (WPS), administered and enforced by DEC, is designed to protect agricultural workers from the dangers of pesticides by ensuring that basic health and safety measures are followed (such as pesticide training, use of personal protective equipment, on-site water for routine washing and emergency decontamination, and re-entry interval enforcement). DEC does not have a full time staffperson assigned to implement this regulation and the responsibility falls to overburdened regional staff. Effective WPS enforcement, however, requires a resource commitment. Farmworker and environmental groups advocated in the 1998 State budget process that $300,000 be appropriated to DEC to implement this program, but the State Legislature did not approve the request.

VII. DO NOT ALLOW AESTHETIC USES OF PESTICIDES
The use of toxic pesticides for purely aesthetic purposes — on lawns and ornamental plants, shrubs, and trees to enhance their appearance — entails considerable risk with no countervailing public health benefit, and the pesticide use data plainly show that this is a real threat in New York State. Aesthetic use on home lawns and gardens puts some of the most vulnerable people at risk: the infants and children who reside in the vicinity. The EPA has stated that: “[E]ven a properly applied pesticide with a complete [health effects] data base by current standards may pose risks to sensitive individuals, or may pose risks in the lawn care use pattern which have yet to be recognized or understood by the current state of scientific risk assessment.”60 There is no compelling reason to allow such use to continue.

VIII. FUND PESTICIDE PROGRAMS THROUGH A TAX ON PESTICIDE SALES
Pesticide regulation, enforcement, research, and data collection are underfinanced and, with the exception of some minimal certified applicator and product registration fees, the cost of maintaining these programs comes out of taxpayers’ pockets. In keeping with the concept of “polluter pays,” pesticide manufacturers should pay a tax on their pesticide sales to adequately finance all pesticide programs. California has such a system (known as the mill tax) and New York State considered establishing one in the 1980s. With the knowledge of pesticide hazards growing, it is time for those who profit from them to take responsibility for the costs such use foists upon society.

is awash in pesticides. The new pesticide use and sales data, released in July, 1998 by the New York State Department of Environmental Conservation (DEC), reveals that millions of pounds and millions of gallons of pesticides were applied by

 Conclusion 

The first year of pesticide reporting data is an eye-opener. No longer mere speculation, this concrete evidence confirms that New York State relies heavily on hazardous chemicals for its pest problems. But pest management is not synonymous with pesticides. We have been on this dangerous path a comparatively short time. There is another, better way, and the time has come for New York State’s political leaders to act in the public interest and force a shift in a new direction: away from the use of toxic pesticides and toward non-toxic alternatives.

 References

1 Liebman, J. 1997. Rising Toxic Tide: Pesticide Use in California, 1991-1995. Californians for Pesticide Reform. San Francisco.
2 It is possible to convert gallons to pounds and thereby have a single unit of measure, but DEC did not do so (see Methodology and Quality of the Data).
3 National Research Council. 1993. Pesticides in the Diets of Infants and Children. National Academy Press. Washington D.C.
4 Guillette, E.A. et al. 1998. An Anthropological Approach to the Evaluation of Preschool Children Exposed to Pesticides in Mexico. Environmental Health Perspectives. 106(6):347-353. see also Wiles, R. et al. 1998. Overexposed: Organophosphate Insecticides in Children’s Food. Environmental Working Group. Washington D.C. see also Weiss, B. 1997. Pesticides as a Source of Developmental Disabilities. Mental Retardation and Developmental Disabilities Research Reviews. 3:246-256. see also Stokes, L. et al. 1995. Neurotoxicity Among Pesticide Applicators Exposed to Organophosphates. Occupational and Environmental Medicine. 52: 648-653.
5 see Weiss, B. note 4 above.
6 For a review of the medical literature on Parkinson’s disease and pesticides, see Environmental Advocates’ and NYPIRG’s Focus on Pesticides #1: Pesticide and Parkinson’s Disease. December 1997. 7 American Cancer Society. 1996. Cancer Facts and Figures. Brochure.
8 Office of Pesticide Programs. 1998. Office of Pesticide Programs List of Chemicals Evaluated for Carcinogenic Potential. United States Environmental Protection Agency. Washington D.C. Memorandum dated June 11, 1998.
9 Daniels, J.L. et al. 1997. Pesticides and Childhood Cancers. Environmental Health Perspectives. 105(10):1068-1077. see also Kettles, M. et al. 1997. Triazine Herbicide Exposure and Breast Cancer Incidence: An Ecologic Study of Kentucky Counties. Environmental Health Perspectives. 105(11):1222-1227. see also Pogoda, J.M. and S. Preston-Martin. 1997. Household Pesticides and Risk of Pediatric Brain Tumor. Environmental Health Perspectives. 105(11):1214-1220. see also Khuder, S.A. and A. Mutgi. 1997. Meta-Analyses of Multiple Myeloma and Farming. American Journal of Industrial Medicine. 32:510-516. see also Keller-Byrne, J.E. et al. 1997. A Meta-Analysis of Non-Hodgkin’s Lymphoma Among Farmers in the Central United States. American Journal of Industrial Medicine. 31:442-444. see also Clavel, J. et al. 1996. Farming, Pesticide Use and Hairy-cell Leukemia. Scandinavian Journal of Work and Environmental Health. 22:285-293. see also Garry, V.F. et al. 1996. Pesticide Appliers with Mixed Pesticide Exposure: G-banded Analysis and Possible Relationship to Non-Hodgkin’s Lymphoma. Cancer Epidemiology, Biomarkers and Prevention. 5:11-16. see also Zahm, S.H. et al. 1993. The Role of Agricultural Pesticide Use in the Development of Non-Hodgkin’s Lymphoma in Women. Archives of Environmental Health. 48(5):353-358. see also Fleming, L.E. and W.Timmeny. 1993. Aplastic Anemia and Pesticides: An Etiologic Association? Journal of Occupational Medicine. 35(11):1106-1116. see also Morrison, H. et al. 1993. Farming and Prostate Cancer Mortality. American Journal of Epidemiology. 137(3):270-280. see also Garry V.F. et al. 1992. Chromosome Rearrangements in Fumigant Appliers: Possible Relationship to Non-Hodgkin’s Lymphoma Risk. Cancer Epidemiology, Biomarkers, and Prevention. 1:287-291. see also Crosignani, D. et al. 1989. Triazine herbicides and ovarian epithelial neoplasms. Scandinavian Journal of Work and Environmental Health. 15:47-53.
10 Zahm, S. H. and M.H. Ward. 1998. Pesticides and Childhood Cancer. Environmental Health Perspectives. 106(Supplement 3):893-908.
11 Lin, S. et al. 1994. Potential parental exposure to pesticides and limb reduction defects. Scandinavian Journal of Work and Environmental Health. 20:166-179. see also Schwartz, D.A. and J.P. LoGerfo. 1988. Congenital Limb Reduction Defects in the Agricultural Setting. American Journal of Public Health. 78(6):654-658.
12 Blakley, P.M. et al. 1989. Effects of Preconceptional and Gestational Exposure to Tordon 202C on Fetal Growth and Development in CD-1 Mice. Teratology. 39:547-553.
13 Garcia-Rodriguez, J. et al. 1996. Exposure to Pesticides and Cryptorchidism: Geographical Evidence of a Possible Association. Environmental Health Perspectives. 104(10):1090-1095. see also Toppari, J. et al. 1996. Male Reproductive Health and Xenoestrogens. Environmental Health Perspectives. 104(Supplement 4):741-803.
14 Garry, V.F. et al. 1996. Pesticide Appliers, Biocides, and Birth Defects in Rural Minnesota. Environmental Health Perspectives. 104(4):394-399.
15 Smith, E.M. et al. 1997. Occupational Exposures and Risk of Female Infertility. Journal of Occupational and Environmental Medicine. 39(2):138-147. see also Sarkar, S.N. et al. 1995. Subacute Toxicity of Urea Herbicide, Isoproturon, in Male Rats. Indian Journal of Experimental Biology. 33:851-856. see also de Cock, J. et al. 1994. Time to Pregnancy and Occupational Exposure to Pesticides in Fruit Growers in the Netherlands. Occupational and Environmental Medicine. 51:693-699. see also Strohmer, H. et al. 1993. Agricultural Work and Male Infertility. American Journal of Industrial Medicine. 24:587-592. see also Lerda, D. and R. Rizzi. 1991. Study of Reproductive Function in Persons Occupationally Exposed to 2,4-dichlorophenoxyacetic acid (2,4-D). Mutation Research. 262:47-50. see also Wyrobeck, A.J. et al. 1981. Sperm Shape Abnormalities in Carbaryl-Exposed Employees. Environmental Health Perspectives. 40:255-265.
16 Savitz, D.A. et al. 1997. Male Pesticide Exposure and Pregnancy Outcome. American Journal of Epidemiology. 146(12):1025-1036. see also Pastore, L. et al. 1997. Risk of Stillbirth from Occupational and Residential Exposures. Occupational and Environmental Medicine. 54:511-518. see also Goulet, L. and G. Theriault. 1991. Stillbirth and Chemical Exposure of Pregnant Workers. Scandinavian Journal of Work and Environmental Health. 17:25-31.
17 For a landmark discussion and literature of the subject, see Colburn, T. et al. 1996. Our Stolen Future. Dutton. New York, New York.
18 Blakley, B.R. 1997. Effect of Roundup and Tordon 202C Herbicides on Antibody Production in Mice. Veterinary and Human Toxicology. 39(4):204-206. see also Repetto, R. and S.S. Baliga. 1996. Pesticides and the Immune System: The Public Health Risks. World Resources Institute. Washington D.C. see also Thrasher, J.D. et al. 1993. Immunologic Abnormalities in Humans Exposed to Chlorpyrifos: Preliminary Observations. Archives of Environmental Health. 48(2):89-93. see also Desi, I. et al. 1985. Immunological Investigation of the Effects of a Pesticide: Cypermethrin. Archives of Toxicology. Supplement 8: 305-309.
19 Blondell, J. and V.A. Dobozy. 1997. Review of Chlorpyrifos Poisoning Data. United States Environmental Protection Agency Memorandum. January 14, 1997. Washington D.C.
20 Ibid.
21 Thrasher, J.D. et al. 1993. Immunologic Abnormalities in Humans Exposed to Chlorpyrifos: Preliminary Observations. Archives of Environmental Health.48(2):89-93.
22 see Blondell and Dobozy, note 19 above.
23 Ibid.
24 Gurunathan, S. et al. 1998. Accumulation of Chlorpyrifos on Residential Surfaces and Toys Accessible to Children. Environmental Health Perspectives. 106(1):9-16.
25 United States Environmental Protection Agency. 1997. Agreement Reached Between EPA and Chlorpyrifos Registrants. Press Advisory dated June 6, 1997.
26 New Jersey Department of Health and Senior Services. 1996. Hazardous Substance Fact Sheet: Chromic Acid. New Jersey Department of Health and Senior Services. Trenton, New Jersey. see also D.P. Morgan. 1989. Recognition and Management of Pesticide Poisonings. United States Environmental Protection Agency. EPA-540/9-88-001.
27 Morgan, D.P. note 26 above.
28 Extoxnet. 1996. Pesticide Information Profile: Methyl Bromide. Series maintained and archived at Oregon State University.
29 Munger, R. et al. 1997. Intrauterine Growth Retardation in Iowa Communities with Herbicide-contaminated Drinking Water Supplies. Environmental Health Perspectives. 105(3):308-314. see also United State Environmental Protection Agency. 1995. R.ED. Facts: Metolachlor. EPA-738-F-95-007.
30 Cooper, R.L. et al. 1996. Effect of Atrazine on Ovarian Function in the Rat. Reproductive Toxicology. 10(4):257-264. see also Kniewald, J. et al. 1987. Indirect Influence of s-Triazines on Rat Gonadotropic Mechanism at Early Postnatal Period. Journal of Steroidal Biochemistry. 27(4-6):1095-1100.
31 see Kettles, M. et al. 1997. note 9 above.
32 see Crosignani, D. et al. 1989. Note 9 above.
33 see Munger, R. et al. note 29 above.
34 Wall, G.R. et al. 1998. Water Quality in the Hudson River Basin: New York and Adjacent States, 1992-1995. United States Geological Survey Circular 1165.
35 Environmental Protection Agency. 1998. Human Health Assessment for the Azinphos methyl Reregistration Eligibility Decision Document (RED) Case No. 0235. Memorandum dated May 7, 1998.
36 Ibid.
37 Maine Apple Pest Program: University of Maine Cooperative Extension Apple IPM Program. Volume 6, No. 8. July 10, 1998.
38 see Morgan, note 26 above.
39 Ibid.
40 Garry, V.F. et al. 1989. Human Genotoxicity: Pesticide Applicators and Phosphine. Science. 246:251-255.
41 Garry, V.F. et al. 1994. Survey of Health and Use Characterization of Pesticide Appliers in Minnesota. Archives of Environmental Health. 49(5):337-343. see also Institute of Medicine; National Academy of Sciences. 1993. Veterans and Agent Orange: Health Effects of Herbicides Used in Vietnam. National Research Council. Washington D.C. see also Zahm, S. H. and A. Blair. 1992. Pesticides and Non-Hodgkin’s Lymphoma. Cancer Research (Supplement): 52:5485S-5488S. see also Scherr, P.A. et al. 1992. Non-Hodgkin’s Lymphoma and Occupational Exposure. Cancer Research (Supplement). 52:5503S-5509S.
42 see Lerda, D. and R. Rizzi note 14 above.
43 Colborn, T. 1998. Endocrine disruption from environmental toxicants. in: Environmental and Occupational Medicine, Third Edition. ed. Rom W.N. Philadelphia: Lippincott-Raven Publishers. pp. 807-816.
44 see Morgan, D.P. note 26 above
45 Ibid.
46 Cox, C. 1998. Insecticide Factsheet: Permethrin. Journal of Pesticide Reform. 18(2):14-20.
47 Briggs, S. A. 1992. Basic Guide to Pesticides: Their Characteristics and Hazards. Rachel Carson Council. Hemisphere Publishing Corporation. Washington D.C.
48 see Maine Apple Pest Program note 37 above.
49 New York State Department of Environmental Conservation. 1998. Annual Report on New York State 1997 Pesticide Sales and Applications. New York State Department of Conservation. Albany, New York.
50 Phillips, P.J. et al. 1998. Pesticide Concentrations in Surface Waters of New York State in Relation to Land Use — 1997. United State Geological Survey. WRIR 98-4104.
51 United States Geological Survey. 1999. Pesticide Concentrations in the Canajoharie Creek, New York 1994-1996. United States Geological Survey Fact Sheet FS 131-97.
52 see Phillips et al. note 50 above.
53 Suffolk County Department of Health Services. 1998. Water Quality Monitoring Program to Detect Pesticide Contamination in Groundwaters of Nassau and Suffolk Counties, NY.
54 Ibid.
55 Ibid.
56 Environmental Protection Agency. 1996. Pesticides and Ground Water State Management Plan Regulation; Proposed Rule. Federal Register 61(124):333259-33301.
57 see Garry et al. note 14 above.
58 Anderson, C. 1997. USDA Unveils Organic Food Rules. Associated Press wire story, December 15, 1997.
59 California Department of Pesticide Regulation. 1998. New Standards Proposed for Pest Control Advisors. Press release dated September 18, 1998. California Department of Pesticide Regulation. Sacramento.
60 Environmental Protection Agency. 1993. Lawn Care Pesticide White Paper.

 Appendix A: Methodology and Data Quality Issues 

The following methodology was used to prepare the tables and maps in this report, and to analyze the overall patterns of pesticide use and sales in New York State.

Data Collection
We first obtained several databases needed to calculate pesticide use and sales amounts in New York State, active pesticide ingredients, and health effects of these chemicals. These are:

a) The data collected by DEC as a result of the 1996 Pesticide Reporting Law, and released by DEC in the July 1998 CD-ROM, titled “Annual Report on New York State 1997 Pesticide Sales and Applications; Data Summaries 1-8.” These were presented in two key tables:

• Use Data: Commercial Applicator Pesticide Use for New York State Summarized by County.
• Sales Data: Commercial Permittee Annual Sales Report for Restricted Use Pesticides and General Use Agricultural Pesticides in New York State; and Commercial Permittee Annual Sales Report for Restricted Use Pesticides and General Use Agricultural Pesticides in New York State in New York State Summarized by County.

b) The related annual report prepared by DEC and released on July 1, 1998, as well as descriptions of this data and a report prepared by the Pesticide Sales and Use Reporting Database Group at Cornell University and posted to the World Wide Web at: http://pmep.cce.cornell.edu/regulation/psur/annualreport1997/index.html.

c) A series of inter-related tables from EPA’s Pesticide Product Information System (PPIS), which were used to link pesticide products in DEC’s “Pesticide Sales and Applications” databases with active ingredients used in those products. The PPIS data were downloaded from EPA’s website at http://www.epa.gov/opppmsd1/PPISdata/index.html. We compared this information with other databases that provided active ingredient information, such as the interactive website maintained by the California Department of Pesticide Regulation (DPR) http://www.cdpr.ca.gov/docs/database/database.htm.

d) Health effects information from a variety of official lists and other sources (see below), which were used to characterize active pesticide ingredients identified in the pesticide products reported in DEC’s Pesticide Sales and Applications databases.

Data Analysis Issues
Our next step was to analyze the data provided in DEC’s Pesticide Sales and Applications databases.

a) Reporting categories, commercial applications and agricultural sales of pesticides: Understanding the data first requires an understanding of the different reporting categories included in the data base and how they relate to one another. The data submitted to DEC are a partial portrait of pesticide use in the state, encompassing two broad categories of pesticide applicators. The first category, commercial applicators, is required to report each application made during the previous calender year. The term commercial applicator refers to anyone who applies pesticides for hire, including: lawn and garden applicators; exterminators, custodial and groundskeeping staff in schools, office buildings, and other structures; and municipal employees who apply pesticides. In addition, some commercial applicators are hired to make agricultural applications to farmland they do not own or rent themselves (most aerial applicators are commercial applicators, for example).

The second major category of applicator, farmers applying pesticides on their own land, is covered indirectly through sales reporting. All businesses that sell restricted use pesticides are required to report sales of all pesticides (both general and restricted use) to farmers intending to use them on their crops. Farmers must tell the sellers the address of the farm where the purchased products will be applied.

For this report, data on pesticides used by commercial applicators were combined with data reported by businesses that sold pesticides to farmers, in order to develop estimates of the total amount of pesticides used and sold for use throughout the state. Sales reporting to farmers is not duplicative of commercial applicator reporting. The two categories of applicators are separate and therefore combining them should not result in double-counting. Although sales to farmers is not a precise measure of the amount of pesticides used in agriculture in a given year (unlike the actual use reporting to which commercial applicators are subject), it is the best surrogate for agricultural use currently available.

A third category of reporting exists — sales of all restricted use products — but these are aggregate sales data for the State, not tied to any application locations and partially duplicative of the data on sales to farmers. Therefore, we did not use this data anywhere in this report.

b) Gallons and pounds: DEC’s databases show the amounts of pesticide products used and sold in units of volume (gallons), weight (pounds), or both, as this information was reported to DEC on the forms submitted by pesticide applicators and sellers. In contrast, California DPR converts its pesticide data from various units of measurement into weight units (pounds) before releasing pesticide use and sales figures.

Converting all data to a single unit of measurement would enable researchers to determine the overall ranking of pesticide use in New York State. To do so, however, requires specific gravity data for pesticide products to calculate the weight of each pesticide that was reported in gallons. Although California DPR shared their specific gravity conversion methodology with us, we were unable to obtain the specific gravities for all pesticide products in New York’s database that were reported in gallons. This limitation made it necessary to report total amounts used and sold separately, both by gallons and by pounds.

c) Pesticide products vs. active ingredients: The term “pesticide” can be used interchangeably to refer to either a pesticide product or a pesticide’s active ingredients. Active ingredients are the chemicals that give the product its purported pesticidal properties for which it is registered by the EPA and DEC. Products contain one or more active ingredients, but they can also contain so-called “inert” ingredients which give the product volume or bulk, or contribute to its application, dispersion, or adherence. Roundupâ and Dursbanâ are examples of product names; glyphosate and chlorpyrifos are their respective active ingredients.

New York State’s Pesticide Reporting Law requires that DEC report only the product name when releasing the data (although nothing precludes DEC from also reporting active ingredients). This presents a fundamental problem: most toxicological and environmental effects information, as well as EPA product registration decisions regarding pesticides, are based on active ingredients (1). To analyze the data in terms of this hazard information, therefore, the product information provided by DEC had to be translated into active ingredients. To do this, we used EPA’s Pesticide Product Information System (PPIS) data base to determine which active ingredients are associated with the pesticide products identified in DEC’s data. Each pesticide product has a unique chemical formulation, enabling us to precisely link DEC’s product information with the active ingredient data provided in EPA’s PPIS data. The only exceptions to obtaining active ingredient information from the PPIS databases were six pesticide products for which there were no corresponding active ingredients in the PPIS data base. These products accounted for 246 gallons and 5604 pounds of pesticides reported used by commercial applicators and sold to farmers across New York State in 1997.

The method for linking pesticide products to active ingredients used for this report was as follows: The EPA Product Number reported in DEC’s databases for each pesticide product was linked to the corresponding EPA Product Registration Number in the PPIS product formulation table. This table provided a identifying number (a “PC Code”) for each active ingredient in each product, as well as the percent of each active ingredient in each product. The PPIS formulation table was then linked via the PC Code to the PPIS table that included chemical names, in order to determine the name of each active ingredient.

The PPIS databases only described the amount of active ingredients for each pesticide product according to the percent by weight of active ingredient. Since DEC’s data was reported in weight and volume, and we were unable to combine the amounts reported in both measurements, this report could not show the overall amounts of specific active ingredients used and/or sold across New York State. Instead, in order to rank the most heavily used active ingredients and discuss the amounts of cancer-causing or otherwise toxic active ingredients, the report lists the amount (in pounds and gallons) of pesticide products containing the particular active ingredients applicable to each section of the report. In addition, one active ingredient, 2,4-D is actually a family of related chemicals. Because the chemicals in this family are considered together for toxicological purposes by EPA, they were aggregated in this report for the purpose of ranking active ingredients.

d) Health effects data: To determine the amount of pesticides used and sold in New York that are associated with specific health hazards, we compared the active ingredient information from EPA’s PPIS data with health effects data from various sources.

We first linked DEC’s Pesticide Sales and Applications data with the PPIS tables as described above. The PPIS formulation table also provides the Chemical Abstract Service (CAS) number for each active ingredient, which is necessary for linking each ingredient with health information.

We then combined several databases of health effects information for pesticides and their active ingredients into one table, and linked this through the PPIS formulation table to DEC’s pesticide products database. To generate the health effects data base, we used: EPA’s carcinogenicity classifications (2); California’s Proposition 65 lists of developmental and reproductive toxins (3); and the latest list of endocrine disrupting pesticides from the seminal researcher on the subject, Dr.Theo Colborn (4). For the neurotoxins category, we chose to use only the organophosphate and carbamate insecticides. These actually function by virtue of their neurotoxicity and are considered so hazardous by EPA that they are first and second in line respectively for reevaluation under the new federal Food Quality Protection Act. Since many other pesticides are also neurotoxic, our figures underestimate the amount of neurotoxic pesticides used and sold in New York State.

It is important to remember that not all chemicals have been examined for these health effects. Many pesticides are not on the carcinogenicity and endocrine disruptor lists, for example, because they have not yet been evaluated for these effects, not because they have been evaluated and exonerated, though that is true for some — EPA, for example, has a carcinogenicity class “E” for chemicals for which there is evidence of non-carcinogenicity (glyphosate and chlorpyrifos are examples of class “E” pesticides).

Data Quality
Finally, we need to address several data quality issues, which DEC discusses in its report (5). The information released by DEC is based on the first year of pesticide use and sales reporting data, and any new program of this type will have some data collection and maintenance problems. This report uses the data to describe broad patterns and concerns regarding pesticide use in New York State. Once the data limitations are overcome, DEC’s annual pesticide use and sales data will provide even more accurate and comprehensive information about pesticide applications across the State.There are three types of limitations to the data provided by DEC: omission of data, duplication of information, and inaccuracies.

Omission of data
The chief source of omission stems from the reporting compliance rate. As of June 19, 1998 the compliance rate was 85% for commercial applicators and 93% for sellers of pesticides. These rates are relatively high for the first year of a new program, and DEC deserves credit for this achievement. It should also be noted that DEC is continuing to pursue those who have yet to report in order to reach full compliance. The fact remains, however, that the 15% of applicators and 7% of sellers who haven’t reported represent a significant hole in our picture of pesticide use. Furthermore, DEC received approximately 450 pieces of returned mail after their first mailing to applicators that had not reported. For various reasons, DEC did not have current addresses for these applicators. These individuals were not included in the calculation of compliance percentages, and could lower the compliance rate by nearly three percent had they been included.

DEC also states that records received after May 1, 1998, may not have been entered into the data base before it was released in July, 1998 (5).

Finally, retailers who did not understand their reporting responsibilities may not have submitted appropriate data. Retailers that sell restricted use pesticides are required to report certain details of all pesticides, both restricted and general use, sold to farmers for use on their agricultural crops. But not all were diligent about this. Instances of non-compliance were reported to DEC by NYPIRG, and DEC has initiated a follow-up investigation.

Duplication of information
Duplicate records were introduced into the database when, during an enforcement action, DEC required an unspecified number of commercial applicators to submit records that the applicators claimed to have already submitted. Because of time constraints, DEC decided to include both sets of records in the July, 1998 release of the data and eliminate the duplicates later, rather than leave out the applications altogether. This mistake is acknowledged in DEC’s report, although it offers no estimate as to the percentage of duplicate records.

Inaccuracies
Finally, simple accuracy of the data has been compromised, chiefly because 90% of the forms received were handwritten, thus making data entry difficult. As a consequence, some pesticide products are listed as having “0” amounts in both the gallons and pounds columns, which DEC explains by stating that, “(p)roducts with a quantity of zero reflect that applications or intended applications of the product were made, but that quantity was indecipherable on the report form (5).” There are numerous products reported fitting this description. DEC is making efforts to obtain the correct information. While the scale of this last inaccuracy is difficult to determine, the fact that it occurred should not be used to discount the current numbers, but instead to highlight that any corrections to these errors will lead to an increased number of total pesticides used and sold, and to argue for electronic reporting, which is less error-prone, in the future.

(1) The exception to this is something called “Toxicity Category,” which is measure of how potent a pesticide product is for causing short-term poisoning or injury. Each separate product has its own Toxicity Category listed on its label. Many active ingredients can be formulated into products with different toxicity categories depending on type of product, concentration of active ingredient, and other properties of the formulation.
(2) Office of Pesticide Programs. 1998. Office of Pesticide Programs List of Chemicals Evaluated for Carcinogenic Potential. United States Environmental Protection Agency. Washington D.C. Memorandum dated June 11, 1998.
(3) Office of Environmental Health Hazard Assessment. 1998. List of Chemicals Known to the State to Cause Cancer or Reproductive Toxicity. California Environmental Protection Agency. Sacramento.
(4) Colborn. T. 1998. Endocrine disruption from environmental toxicants. In: Environmental and Occupational Medicine, Third Edition. ed. Rom, W.N. Philadelphia: Lippincott-Raven Publishers. pp. 807-816.
(5) New York State Department of Environmental Conservation 1998. Annual Report on New York State 1997 Pesticide Sales and Applications. July 1, 1998. New York State Department of Environmental Conservation. Albany.

 Appendix B: Greater Rochester Area  

• Monroe and Wayne counties dominate the region and are ranked relatively high when compared to counties across the State. Statewide, Monroe County ranked seventh in total pounds of pesticides reported, and ninth in total gallons (see Table 3 in main report). Wayne County ranked sixth in total amount of pounds and tenth in total amount of gallons. But ranking counties in the Greater Rochester area of New York State is not entirely a clear cut exercise (see Table A and Maps A and B). Although Monroe and Wayne counties report significantly more pounds of pesticides than Ontario, Genesee, and Livingston counties, differences between counties regarding the amount of gallons used are not nearly as sharp.
• The Greater Rochester area reported a preponderance of pesticide products containing suspected carcinogens: 44% of the total pounds and 48% of the total gallons reported contained active ingredients classified as probable, likely, or possible carcinogens by the EPA. This is approximately 10% more than the statewide proportion of products containing suspected carcinogens. In addition, just over one quarter of the total amount of both gallons and pounds reported contained endocrine disruptors, and neurotoxic organophosphate and carbamate insecticides accounted for 19% of the total pounds and 13% of the total gallons reported (see Table B).
• Unlike the overall statewide pattern, where commercial application predominated over sales to farmers, the reverse was true in the Greater Rochester area (see Maps C and D). Sales to farmers constituted 60% of the total pounds and 73% of the total gallons reported regionwide. Only Monroe County reported more commercial application than sales to farmers (79% of the total pounds and 52% of the total gallons reported in Monroe County are from commercial applications). In contrast, Wayne County’s sales to farmers constituted 92% of the total pounds and 94% of the total gallons reported for the County. Like Wayne County, Genesee and Livingston counties reported more sales to farmers than commercial pesticide use, but it is not possible to say which category of use predominates in Ontario County because the pattern was not consistent between gallons and pounds.
• The top active ingredients reported in the region overall (see Table C) are dominated by agricultural pesticides that pose significant health and water contamination hazards. Mancozeb and captan are both classified as probable human carcinogens by the EPA. Atrazine, metolachlor, and alachlor are all classified as possible human carcinogens by the EPA. In addition, USGS water monitoring studies reveal that some of the highest pesticide detections in water in the state occurred in the Greater Rochester area (see Water Contamination in main report), in Livingston and Genesee counties.1 These detections are the unavoidable consequence of the use of certain pesticides that have been documented to cause water contamination during the course of normal agricultural use, a category that includes four of the top active ingredients reported in this region — atrazine, alachlor, metolachlor, and methyl parathion.2
• The major active ingredients used by commercial applicators all pose significant health risks as well. Pendimethalin is classified as a possible human carcinogen by the EPA, isofenphos is a neurotoxic organophosphate insecticide, labeled “highly toxic” by the leading reference on pesticide poisonings,3 and 2,4-D is a member of the phenoxy family of herbicides, which has been strongly linked to numerous cancers, as well as to fertility problems and hormonal disruption (see main body of report).
• In Monroe County, the pesticide products that were used in the greatest amounts (by pounds) by commercial applicators were primarily lawn care products that are combinations of pesticides and fertilizers, raising the possibility that applications may not be occurring in response to any documented pest problem, but as a routine part of lawn maintenance. By applying pesticides in this manner, as part of a fertilizer product that blankets an entire property, overuse is virtually assured and minimization techniques such as spot treatments do not occur.

Reducing pesticide use and risks in the Greater Rochester area will require a two-pronged approach that deals with both the heavy use of agricultural chemicals that pose significant health and water contamination risks, and the routine commercial application of toxic products. State and county regulatory agencies must take a closer look at the pesticide use and sales data, examining in particular the target pest (data to which the public does not have access) in order to implement non-toxic pest management policies.

1. Phillips, P.J. et al. 1998. Pesticide Concentrations in Surface Waters of New York State in Relation to Land Use — 1997. United States Geological Survey. WRIR 98-4104.
2. General Accounting Office. 1991. Pesticides: EPA Could Do More to Minimize Groundwater Contamination. Washington D.C. GAO/RCED-91-75.
3. Morgan, D.P. 1989. Recognition and Management of Pesticide Poisonings. United State Environmental Protection Agency. EPA-540/9-88-001.

Map A | Map B | Map C | Map D |

 Appendix C: Western New York

• Of the four westernmost counties in New York State, Erie County reported the greatest amounts of pesticides used and sold, with Niagara County second, Chautauqua County third, and Cattaraugus County least (see Table A, and Maps A and B). Erie County ranked fifth statewide in total gallons of pesticides reported, and tenth in total pounds of pesticides reported (see Table 3 in the main body of the report).
• Overall, commercial applicator use was greater than sales to farmers in western New York, mirroring the larger state pattern (see Maps C and D). Commercial application accounted for 73% of the gallons, and 70% of the pounds reported regionwide. In Erie County, the dominance of commercial application was even more accentuated — 95% of the total gallons and 92% of the total pounds reported were from commercial applications. Only Niagara County did not adhere to this overall pattern. Sales to farmers were approximately twice that of pesticides applied by commercial applicators in Niagara County.
• Nearly half of the total gallons of all pesticides used and sold in the region, and 35% of the total pounds contained probable, likely, or possible carcinogens (see Table B). Neurotoxic organophosphate and carbamate insecticides accounted for 23% of the total pounds and 13% of the total gallons reported regionwide.
• Even though sales to farmers were less than commercial use regionwide, there was a significant preponderance of extremely toxic products in the sales to farmers category that warrants immediate attention from regulatory agencies. Most notably, the fumigant methyl bromide topped the list of agricultural sales (by pounds), and ranked third overall (see Table C). Methyl bromide can cause both acute poisoning (including pulmonary edema and bleeding, convulsions, dizziness, nausea and vomiting), significant long-term damage to the nervous system,1 and fatalities. Its combination of volatility and marked toxicity make its application a high-risk proposition under any circumstances, but particularly near residential areas and schools. In Erie County, 54,933 pounds of methyl bromide were reported. There was, however, more methyl bromide used in Erie County than is accounted for by this figure because some methyl bromide product use reports did not contain legible figures in the amount columns and were thus excluded from county totals.2 In Niagara County, 25,708 pounds of methyl bromide were reported, but as in Erie County, some reports were illegible and were not included in this total. For both Erie and Niagara counties, therefore, the methyl bromide amounts reported are an underestimate. No methyl bromide was reported for Cattaraugus County, but 24,000 pounds were reported in Chautauqua County.

In addition to methyl bromide, the fumigant chloropicrin (which is often combined with methyl bromide in the same product) ranked sixth in pounds sold to farmers. Like methyl bromide, it poses severe poisoning risks (characterized by headache, nausea, vomiting, diarrhea, pulmonary edema, and corrosive gastroenteritis)3 as well as “dangerous explosion hazards,”4 (see Table C). Methyl parathion, which ranked sixth in gallons sold to farmers, and azinphos methyl, which ranked seventh in pounds sold to farmers, are among the most highly toxic members of the organophosphate insecticide family, posing both food residue risks and significant risks to farmworkers and others in the vicinity of their use (see main report for description).

• Other active ingredients used by commercial applicators and sold to farmers in western New York generally reflect those pesticides that are dominant statewide, such as atrazine, metolachlor, chlorpyrifos, trifuralin, 2,4-D, and cyfluthrin. The hazards of these — from neurotoxicity, to carcinogenicity, to reproductive problems — are highlighted in the main body of the report. The chief distinction between the pattern of most heavily used active ingredients in this region, versus the rest of the state, is that chlorpyrifos, the dominant pesticide statewide, is not the most heavily used pesticide in the western region.
• In Erie County (and to a lesser extent in the rest of the region), the pesticide products that were used in the greatest amounts by commercial applicators (by pounds) were primarily lawn care products that are combinations of pesticides and fertilizers, raising the possibility that applications may not be occurring in response to any documented pest problem, but as a routine part of lawn maintenance. By applying pesticides in this manner, as part of a fertilizer product that blankets an entire property, overuse is virtually assured and minimization techniques such as spot treatments do not occur.

Because the public does not have access to the site-specific details of pesticide use and sales, it is not possible to report here precisely where in the counties the most hazardous pesticides were used, or how frequently routine lawn maintenance with insecticides is occurring without an underlying pest problem. But DEC and both the county and State Departments of Health do have access to that data. It should be a government priority to learn where these unavoidable risky applications are occurring in order to warn residents and facilities that may be in the area, and to identify the pest problem being addressed so that safer alternative strategies for control can be implemented.
 

1. Morgan, D.P. 1989. Recognition and Management of Pesticide Poisonings. United States Environmental Protection Agency. EPA-540/9-88-001.
2. As described in Appendix A: Methodology and Quality of the Data, DEC reported some products with zeros for amounts in both the gallons and pounds columns. This was done when the amount recorded on the submitted report was illegible. Such products do not show up in amount totals, even though they were reported as used or sold. In Erie and Niagara counties, two methyl bromide products were reported as used by commercial applicators but recorded in the data base with zeros in both amount columns.
4.Ibid.

Map A | Map B | Map C | Map D |

 Appendix D: New York City  

• In New York City, comprised of New York (Manhattan), Bronx, Kings (Brooklyn), Queens, and Richmond (Staten Island) counties, pesticide applicators reported using 4,400,156 pounds and 666,264 gallons in 1997 — more than one quarter of all the pesticides reported for New York State (see Table A). Manhattan ranked number one in the State for the most pesticides reported in the gallons category, while Brooklyn topped the pounds category. Within New York City itself, Manhattan accounted for 84% of the total gallons of pesticides and Brooklyn accounted for 59% of the total pounds of pesticides reported for the five boroughs. All of the pesticide reports in New York City were commercial applications.1 
• Of the total pesticides reported used in the five boroughs a full 91% of the pounds (4,014,424 pounds) and 79% (529,175 gallons) of the gallons belong to one of the two main groups of neurotoxic insecticides — organophosphates and carbamates (see Table B). These insecticides function by interfering with an essential enzyme in insects — cholinesterase — that is also an essential enzyme in human beings. Whenever exposure to these insecticides occurs, therefore, subtle neurotoxicity and outright poisoning are potential hazards. And, as is true for the neurotoxicity associated with lead poisoning, these insecticides pose a particular danger to develop- ing fetuses and young children whose nervous systems are immature and vulnerable to permanent damage.2 
• A single product, the chlorpyrifos-based insecticide Dursban Pro®, accounted for 67% of the gallons and 79% of the pounds reported used in the region, although this use was not evenly distributed among the counties. Almost all (98%) of the Dursban Pro® reported for the five boroughs in gallons was used in Manhattan, and 65% of the Dursban Pro® reported by pounds in the five boroughs was used in Brooklyn.

Chlorpyrifos is an organophosphate insecticide and one of the leading causes of pesticide poisoning in the nation.3  In addition to the general hazards of organophosphate insecticides described above and in the main body of the report, a raft of recent research specifically related to chlorpyrifos points to its ability to selectively target other brain functions, inhibiting cell development and DNA synthesis, and lowering RNA levels.4  These effects can occur at levels of chlorpyrifos too low to cause the classic symptom of organophosphate poisoning — depressed bloodstream levels of the enzyme cholinesterase.5  Such subtle damage can lead to developmental learning deficits, particularly from chronic (low-level, repeated) exposure, as occurs with regular spraying or treatment of an apartment or office.6  Most at risk for these effects are fetuses, infants, and young children.

• There are many safer alternatives to the use of neurotoxic insecticides, including simple, routine building mainte- nance (e.g. fixing leaks, caulking cracks, crevices and holes) that both help to pest-proof buildings and improve their overall structural integrity and safety (see Alternative Pest Control sidebar, page 19), or use of least toxic products, such as boric acid bait. Nearly 6,400 pounds and 707 gallons of boric acid products (the bulk of which were nearly pure boric acid, not mixed with unknown “inert” ingredients) were reported used in the five boroughs in 1997. This demonstrates that there are applicators for hire who are aware of and apply less toxic products.
• In addition to chlorpyrifos, a host of other hazardous pesticides are used in the five boroughs (see Table C and description of pesticide active ingredients in main body of report). Of these, one in particular calls for immediate attention. Significant quantities of the extremely toxic fumigant methyl bromide were used in Manhattan and Brooklyn. In Manhattan, 11,851 pounds of the product Meth-O-Gas 100® were used, and in Brooklyn, a total of 2,503 pounds of Meth-O-Gas 100® and Meth-O-Gas Q® were used (both products are pure methyl bro- mide). Methyl bromide can cause both acute poisoning (including pulmonary edema and bleeding, convulsions, dizziness, nausea and vomiting), significant long-term damage to the nervous system,7  and fatalities. The combina- tion of high toxicity and high volatility makes using this pesticide in a densely populated area almost unavoidably hazardous. Discerning precisely where and why this fumigant is being used in these areas should be a top priority for City health officials so that safer alternatives can be immediately substituted.

A Different Look at Dursban Pro Because we lacked certain information, we were not able to express all of the pesticide data in a single unit (pounds) even though this is a more illuminating way to describe and compare pesticide use (see Appendix A). We did, however, have the information necessary to do so for the product Dursban Pro(r) When all of the gallons of Dursban Pro(r) are converted to pounds and added to pounds of Dursban Pro(r) reported, the data show that a total of 7.4 million pounds were used in the five boroughs, of which more than 4.5 million pounds (approximately 60%) was used in Manhattan alone.}

 

1 A small amount of pesticide sales to farmers was reported for the area (3769 gallons and 10 pounds) but these products, which bear such unagricultural names as “Landlord’s formula,” appear to have been reported erroneously and are disregarded for the purposes of this appendix though they are included in the totals in Table 2 of the main body of the report.  
2 Guillette, E.A. et al. 1998. An Anthropological Approach to the Evaluation of Preschool Children Exposed to Pesticides in Mexico. Environmental Health Perspectives. 106(6):347-353. see also Wiles, R. et al. 1998. Overexposed: Organophosphate Insecticides in Children’s Food. Environmental Working Group. Washington D.C. see also Weiss, B. 1997. Pesticides as a Source of Developmental Disabilities. Mental Retardation and Developmental Disabilities Research Reviews. 3:246-256.  
3 Blondell, J. and V.A. Dobozy. 1997. Review of Chlorpyrifos Poisoning Data. United States Environmental Protection Agency Memorandum. January 14, 1997. Washington D.C.  
4 Song, X. et al. 1998. Modeling the Developmental Neurotoxicity of Chlorpyrifos in Vitro: Macromolecule Synthesis in PC12 Cells. Toxicology and Applied Pharmacology. 151:182-191. see also Roy, T.S. et al. 1998. Chlorpyrifos Elicits Mitotic Abnormalities and Apoptosis in Neuroepithelium of Cultured Rat Embryos. Teratology. 58:62-68. see also. Dam, K. et al. 1998. Developmental neurotoxicity of chlorpyrifos: delayed targeting of DNA synthesis after repeated administration. Developmental Brain Research. 108:39-45. see also Johnson, D.E. et al. 1998. Early Biochemical Detection of Delayed Neurotoxicity Resulting form Developmental Exposure to Chlorpyrifos. Brain Research Bulletin. 45(2):143-147. see also Song, X. et al. 1997. Cellular Mechanisms for Developmental Toxicity of Chlorpyrifos: Targeting the Adenylyl Cyclase Signaling Cascade. Toxicology and Applied Pharmacology. 145:158-174.  
5 Campbell, C.G. et al. 1997. Chlorpyrifos Interferes with Cell Development in Rat Brain Regions. Brain Research Bulletin 43(2):179-189. see also. Whitney, K.D. et al. 1995. Developmental Neurotoxicity of Chlorpyrifos: Cellular Mechanisms. Toxicology and Applied Pharmacology. 134:53-62.  
6 Cohn, J. and R.C. Macphail. 1997. Chlorpyrifos Produces Selective Learning Deficits in Rats Working Under a Schedule of Repeated Acquisition and Performance. Journal of Pharmacology and Experimental Therapeutics. 283(1):312-20.  
7 Morgan, D.P. 1989. Recognition and Management of Pesticide Poisonings. United States Environmental Protection Agency. EPA-540/9-88-001.

Map A | Map B |

 Appendix E: Long Island 

• On Long Island (Nassau and Suffolk counties), 2.3 million pounds and 568,222 gallons of pesticides were reported used or sold to farmers in1997 alone — nearly one quarter of all the gallons of pesticides reported Statewide, and 14% of the pounds (see Table A). Nassau County ranked second and Suffolk County third overall in the State for amount of pesticides reported (for both gallons and pounds). ’
• Products containing active ingredients classified as probable, likely, or possible carcinogens by the EPA ac- counted for 42% of the pounds and 21% of the gallons reported on Long Island (see Table B). As noted in the main body of the report, the epidemiological literature is rife with studies linking pesticide use to childhood cancers, Non-Hodgkin’s lymphoma, multiple myeloma, leukemias, breast and prostate cancers, and others.1  The incidence of many of the cancers linked to pesticide use has risen dramatically in the past few decades. Increasing rates of breast cancer on Long Island, in particular, have spurred interest in the potential role of toxic chemicals in this illness.
• Neurotoxic organophosphate and carbamate insecticides accounted for 50% of the gallons and 35% of the pounds reported for Long Island (see Table B). These insecticides function by interfering with an essential enzyme in insects — cholinesterase — that is also an essential enzyme in human beings. Whenever exposure to these insecticides occurs, therefore, subtle neurotoxicity and outright poisoning are potential hazards. ’
• Health effects associated with the specific pesticides used in the greatest quantities on Long Island (see Table C) are outlined in the main body of the report. Among the most notable is chlorpyrifos, the most heavily used pesticide by gallons and the second most heavily used by pounds. Chlorpyrifos is an organophosphate insecticide and one of the leading causes of pesticide poisoning in the nation.2  Not only does it carry the general neurotox- icity risks common to all organophosphate insecticides (described above and in the main body of the report), but a raft of recent research specifically related to chlorpyrifos points to its ability to selectively target other brain functions, inhibiting cell development and DNA synthesis, and lowering RNA levels.3  These effects can occur at levels of chlorpyrifos too low to cause the classic symptom of organophosphate poisoning — depressed blood stream levels of the enzyme cholinesterase.4  Such subtle damage can lead to developmental learning deficits, particularly from chronic (low-level, repeated) exposure, as occurs with regular spraying or treatment of a home or office.5  Most at risk for these effects are fetuses, infants, and young children, because their immature nervous systems are vulnerable to permanent damage. ’
• The pesticide products that were used on Long Island in the greatest amounts by commercial applicators (by pounds) were primarily lawn care products that combine pesticides and fertilizers. This raises the possibility that applications may not be occurring in response to any actual pest problem, but as a routine part of lawn mainte- nance. By applying pesticides as part of a fertilizer product that blankets an entire property, overuse is virtually assured and minimization techniques such as spot treatments are unlikely to occur. ’
• Long Island, with its sandy soils and unconfined aquifer (no impermeable layer protects the groundwater from pollutants), was one of the first regions in the nation where water contamination by pesticides was identified. Aldicarb, a carbamate insecticide used on potatoes, was found in groundwater in Suffolk County in 1979, contradicting laboratory and field studies that had indicated such contamination could not occur.6  This kind of contamination is of particular concern on Long Island, where groundwater is the chief source of drinking water. The latest 1998 data from an extensive drinking water well testing initiative in Suffolk and Nassau counties by the Suffolk County Department of Health Services clearly show that this hazard is a continuing threat.7  Out of 1,395 wells sampled in Suffolk and Nassau counties, 27% had detectable pesticide levels, and nearly 10% exceeded drinking water standards.

These results represent a significant threat in themselves, but just as significant is the fact that the majority of the most heavily used pesticides on Long Island are not included in Suffolk County’s well water testing protocol.8  Of the top pesticides reported used on Long Island, only four — carbaryl, diazinon, dicamba and 2,4-D — were included in the testing protocol. This discrepancy may be due in part to the fact that this is the first year that pesticide use data have been available, and it was not previously possible to know which were the most heavily used pesticides in the region. Now that such data are available, however, the water testing protocol must be expanded to reflect current pesticide use patterns. At the very least, the most heavily used pesticides (as shown in Table C) must be included, as should any other high hazard pesticides that reporting data indicate are being used in the area. Until this is done, even those wells with no detectable pesticide levels under the current protocol cannot be considered contaminant-free. ’

• l Virtually all of the pesticides reported (99%) were used by commercial applicators, rather than sold to farmers. Because Long Island does retain some agriculture, it is not clear whether the relative lack of pesticides reported sold to farmers accurately represents the balance between agricultural and non-agricultural pesticide use in the region. It may be that low purchases by farmers during 1997, or greater reliance on commercial applica- tors for agricultural applications gave an inaccurately low picture of agricultural use in the region. There also ap- pear to have been some reporting difficulties with sales to farmers in Suffolk County. Of the 55 different prod- ucts reported sold to farmers in Suffolk County, 25 of them (nearly half) contained zeros in both the pounds and the gallons column, indicating that the report was illegible or contained some other problem that made it unrecordable (see Appendix A). Future years of data may sort out some of these questions, but these data do make clear that non-agricultural pesticide use is dominant on Long Island.

 1 Daniels, J.L. et al. 1997. Pesticides and Childhood Cancers. Environmental Health Perspectives. 105(10):1068-1077. see also Kettles, M. et al. 1997. Triazine Herbicide Exposure and Breast Cancer Incidence: An Ecologic Study of Kentucky Counties. Environmental Health Perspectives. 105(11):1222-1227. see also Pogoda, J.M. and S. Preston-Martin. 1997. Household Pesticides and Risk of Pediatric Brain Tumor. Environmental Health Perspectives. 105(11):1214-1220. see also Khuder, S.A. and A. Mutgi. 1997. Meta-Analyses of Multiple Myeloma and Farming. American Journal of Industrial Medicine. 32:510-516. see also Keller-Byrne, J.E. et al. 1997. A Meta-Analysis of Non-Hodgkin’s Lymphoma Among Farmers in the Central United States. American Journal of Industrial Medicine. 31:442-444. see also Clavel, J. et al. 1996. Farming, Pesticide Use and Hairy-cell Leukemia. Scandinavian Journal of Work and Environmental Health. 22:285-293. see also Garry, V.F. et al. 1996. Pesticide Appliers with Mixed Pesticide Exposure: G-banded Analysis and Possible Relationship to Non-Hodgkin’s Lymphoma. Cancer Epidemiology, Biomarkers and Prevention. 5:11-16. see also Zahm, S.H. et al. 1993. The Role of Agricultural Pesticide Use in the Development of Non-Hodgkin’s Lymphoma in Women. Archives of Environmental Health. 48(5):353-358. see also Fleming, L.E. and W.Timmeny. 1993. Aplastic Anemia and Pesticides: An Etiologic Association? Journal of Occupational Medicine. 35(11):1106-1116. see also Morrison, H. et al. 1993. Farming and Prostate Cancer Mortality. American Journal of Epidemiology. 137(3):270-280. see also Garry V.F. et al. 1992. Chromosome Rearrangements in Fumigant Appliers: Possible Relationship to Non-Hodgkin’s Lymphoma Risk. Cancer Epidemiology, Biomarkers, and Prevention. 1:287-291. see also Crosignani, D. et al. 1989. Triazine herbicides and ovarian epithelial neoplasms. Scandinavian Journal of Work and Environmental Health. 15:47-53.  
2Blondell, J. and V.A. Dobozy. 1997. Review of Chlorpyrifos Poisoning Data. United States Environmental Protection Agency Memorandum. January 14, 1997. Washington D.C.  
3 Song, X. et al. 1998. Modeling the Developmental Neurotoxicity of Chlorpyrifos in Vitro: Macromolecule Synthesis in PC12 Cells. Toxicology and Applied Pharmacology. 151:182-191. see also Roy, T.S. et al. 1998. Chlorpyrifos Elicits Mitotic Abnormalities and Apoptosis in Neuroepithelium of Cultured Rat Embryos. Teratology. 58:62-68. see also. Dam, K. et al. 1998. Developmental neurotoxicity of chlorpyrifos: delayed targeting of DNA synthesis after repeated administration. Developmental Brain Research. 108:39-45. see also Johnson, D.E. et al. 1998. Early Biochemical Detection of Delayed Neurotoxicity Resulting form Developmental Exposure to Chlorpyrifos. Brain Research Bulletin. 45(2):143-147. see also Song, X. et al. 1997. Cellular Mechanisms for Developmental Toxicity of Chlorpyrifos: Targeting the Adenylyl Cyclase Signaling Cascade. Toxicology and Applied Pharmacology. 145:158-174.  
4 Campbell, C.G. et al. 1997. Chlorpyrifos Interferes with Cell Development in Rat Brain Regions. Brain Research Bulletin 43(2):179-189. see also. Whitney, K.D. et al. 1995. Developmental Neurotoxicity of Chlorpyrifos: Cellular Mechanisms. Toxicology and Applied Pharmacology. 134:53-62.  
5 Cohn, J. and R.C. Macphail. 1997. Chlorpyrifos Produces Selective Learning Deficits in Rats Working Under a Schedule of Repeated Acquisition and Performance. Journal of Pharmacology and Experimental Therapeutics. 283(1):312-20.  
6 Zaki, M.H. et al. 1982. Pesticides in Groundwater: The Aldicarb Story in Suffolk County, NY. American Journal of Public Health. 72(12):1391-1395.  
7 Suffolk County Department of Health Services. 1998. Water Quality Monitoring Program to Detect Pesticide Contamination in Groundwaters of Nassau and Suffolk Counties, NY: Progress Report. August 1998.  
8 Suffolk County Department of Health Services. 1998. Water Quality Monitoring Program to Detect Pesticide Contamination in Groundwaters of Nassau and Suffolk Counties, NY.

Map A | Map B |

 Appendix F: Westchester

• Westchester County reported a total of 96,034 gallons and 680,000 pounds pesticides used and sold in 1997 (see Table A). This placed Westchester fourth among all counties in the state for gallons1 eighth for pounds. Commercial applicator use overwhelmed sales to farmers, accounting for more than 98% of the total amount reported. ’
• Of the total pesticides reported for Westchester County, half of the total gallons and nearly 60% of the pounds contained active ingredients classified by the EPA as probable, likely, or possible carcinogens (see Table B). This is nearly twice the percentage of carcinogens reported statewide.
• Fifty-seven percent of the total gallons and 13% of the total pounds contained active ingredients currently thought to be endocrine disruptors (see Table B). The percentage of pounds is roughly equivalent to the statewide percentage, but the percentage in gallons is more than twice the statewide percentage. ’
• The pesticide products that were used in the greatest amounts by commercial applicators (by pounds) were primarily lawn care products that are combinations of pesticides and fertilizers, raising the possibility that applications may not be occurring in response to any documented pest problem, but as a routine part of lawn maintenance. Of the top 50 products applied by pounds in Westchester County, 384,207 pounds were products that combined pesticides and fertilizers. This accounts for 56% of the total pounds reported applied in the county in 1997. By applying pesticides in this manner, as part of a fertilizer product that blankets an entire property, overuse is virtually assured and minimization techniques such as spot treatments do not occur.

  In recent years, the commercial applicator industry has frequently claimed to be using strategies, such as integrated pest management (a generic term), to reduce its use of pesticides. But the industry's reliance on fertilizer/pesticide combinations belies this statement. Because the public does not have access to the site-specific details of pesticide use and sales, it is not possible to report here how frequently routine lawn maintenance with insecticides is occurring without an underlying pest problem. But DEC and both the county and state Departments of Health do have access to that data. It should be a priority to learn where these risky applications are occurring in order to warn residents and facilities that may be in the area, and to identify the pest problem being addressed so that safer alternative strategies for control can be implemented.
   

• The health effects of many of the pesticides most heavily used in Westchester County (see Table C) are outlined in the main body of the report. Among the most notable is chlorpyrifos, an organophosphate insecticide and one of the leading causes of pesticide poisoning in the nation2. In addition to the general neurotoxic hazards of organophosphate insecticides described in the main body of the report, a raft of recent research specifically related to chlorpyrifos points to its ability to selectively target other brain functions, inhibiting cell development and DNA synthesis, and lowering RNA levels3. These effects can occur at levels of chlorpyrifos too low to cause the classic symptom of organophosphate poisoning C depressed bloodstream levels of the enzyme cholinesterase4. Such subtle damage can lead to developmental learning deficits, particularly from chronic (low-level, repeated) exposure, as occurs with regular spraying or treatment of an apartment or office5. Most at risk for these effects are fetuses, infants, and young children.
• In addition to chlorpyrifos, four other pesticides deserve special note. 2,4-D, dicamba, mecoprop, and MCPP are all among the top pesticides used in Westchester County and all are part of the related family of chemicals known as the chlorophenoxy herbicides. As described briefly in the main body of the report, this class of pesticides has been heavily implicated in certain cancers, most notably Non-Hodgkin's lymphoma, whose incidence has increased dramatically in the past few decades6. 2,4-D itself has also been linked to canine lymphoma in pet dogs whose owners treat their lawns7, childhood cancers8, sperm damage9, and possible endocrine disruption10.

The weight of evidence prompted the EPA to initiate a "special review" of 2,4-D, a process that has yet to officially conclude. Currently, 2,4-D is classified by the EPA as a Class "D" carcinogen, meaning that it is not yet classifiable regarding carcinogenicity. Dicamba is also a Class "D" carcinogen. Mecoprop and MCPP have not been classified for carcinogenicity by EPA at this time. This means that in spite of the considerable evidence for their carcinogenicity, these four compounds are not included in the percentage of products applied in Westchester County that contain carcinogens cited above, and those figures are in all likelihood an underestimate.

A further note of interest: although it is not possible to make any statements about causation, the rate of Non-Hodgkin's lymphoma incidence in Westchester County between 1976 and 1995 increased by 37% for males and by 40% for females11.
 

1. Westchester County appears fifth in the Table 3 in the main body of the report, however, because "Unknown," which is a compilation of all the applications and sales that could not be attributed to a specific geographic area, ranked fourth.
2. Blondell, J. and V.A. Dobozy. 1997. Review of Chlorpyrifos Poisoning Data. United States Environmental Protection Agency Memorandum. January 14, 1997. Washington D.C.
3. Song, X. et al. 1998. Modeling the Developmental Neurotoxicity of Chlorpyrifos in Vitro: Macromolecule Synthesis in PC12 Cells. Toxicology and Applied Pharmacology. 151:182-191. see also Roy, T.S. et al. 1998. Chlorpyrifos Elicits Mitotic Abnormalities and Apoptosis in Neuroepithelium of Cultured Rat Embryos. Teratology. 58:62-68. see also. Dam, K. et al. 1998. Developmental neurotoxicity of chlorpyrifos: delayed targeting of DNA synthesis after repeated administration. Developmental Brain Research. 108:39-45. see also Johnson, D.E. et al. 1998. Early Biochemical Detection of Delayed Neurotoxicity Resulting form Developmental Exposure to Chlorpyrifos. Brain Research Bulletin. 45(2):143-147. see also Song, X. et al. 1997. Cellular Mechanisms for Developmental Toxicity of Chlorpyrifos: Targeting the Adenylyl Cyclase Signaling Cascade. Toxicology and Applied Pharmacology. 145:158-174. 4. Campbell, C.G. et al. 1997. Chlorpyrifos Interferes with Cell Development in Rat Brain Regions. Brain Research Bulletin 43(2):179-189. see also. Whitney, K.D. et al. 1995. Developmental Neurotoxicity of Chlorpyrifos: Cellular Mechanisms. Toxicology and Applied Pharmacology. 134:53-62.
5. Cohn, J. and R.C. Macphail. 1997. Chlorpyrifos Produces Selective Learning Deficits in Rats Working Under a Schedule of Repeated Acquisition and Performance. Journal of Pharmacology and Experimental Therapeutics. 283(1):312-20.
6. Institute of Medicine; National Academy of Sciences. 1999. Veterans and Agent Orange: Update 1998. National Academy Press. Washington D.C. see also Fontana, A. et al. 1998. Incidence Rates of Lymphomas and Environmental Measurements of Phenoxy Herbicides: Ecological Analysis and Case-Control Study. Archives of Environmental Health. 53:384-387. see also Garry, V.F. et al. 1994. Survey of Health and Use Characterization of Pesticide Appliers in Minnesota. Archives of Environmental Health. 49(5):337-343. see also Zahm, S. H. and A. Blair. 1992. Pesticides and Non-Hodgkin=s Lymphoma. Cancer Research (Supplement): 52:5485S-5488S. see also Scherr, P.A. et al. 1992. Non-Hodgkin=s Lymphoma and Occupational Exposure. Cancer Research (Supplement). 52:5503S-5509S.
7. Hayes, H.M. et al. 1991. Case-control study of canine malignant lymphoma: Positive association with dog owner's use of 2,4-dichlorophenoxyacetic acid herbicides. Journal of the National Cancer Institute. 83:1226-1231.
8. Leiss, J. and D.A. Savitz. 1995. Home Pesticide Use and Childhood Cancer: A Case-Control Study. American Journal of Public Health. 85(2):249-252.
9. Lerda, D. and R. Rizzi. 1991. Study of Reproductive Function in Persons Occupationally Exposed to 2,4-dichlorophenoxyacetic acid (2,4-D). Mutation Research. 262:47-50.
10. Colborn, T. 1998. Endocrine disruption from environmental toxicants. in: Environmental and Occupational Medicine, Third Edition. ed. Rom W.N. Philadelphia: Lippincott-Raven Publishers. pp. 807-816.
11. New York State Department of Health, New York State Cancer Registry. 1998. Volume 3. Trends in Cancer Incidence and Mortality by County, 1976-1995. New York State Department of Health. Albany, NY