CropLife America and its member companies support improved worker protection standards, promote product stewardship and advocate for rigorous scientific studies of pesticide exposures to ensure the safety of their employees, pesticide applicators and farm workers.
Modern advances in pesticide application technology coupled with implementation of the WPS have added significant safeguards to protect agricultural workers. According to government regulators, these actions have greatly reduced risks associated with pesticide applications. CLA supports the WPS as a systematic and uniform approach to protect the safety of those who produce our nation's food and fiber.
The WPS is based on sound scientific principles that allow food production to flourish while providing the best protection possible for farm workers, pesticide handlers and applicators. However, the WPS program should be improved and made more effective by better enforcement of the existing WPS rule, rather than significant additional regulation. CLA also supports science-based efforts that protect public health.
There are inherent limitations in the statistical associations between pesticide exposure and disease being claimed based on results from the Agricultural Health Study (AHS). Unless and until data are available to demonstrate causation, conclusions based on weak associations should not be used to support regulatory decisions or to infer that these products cause harm to farm workers.
- The application of pesticide products is highly regulated in accordance with the label requirements and the WPS, providing significant protection applicators and farm workers.
- CLA agrees with the EPA that data from the AHS should be made available to environmental health and safety professionals to assist in efforts to improve worker protection. Data gathered from the study should also be used to document the benefits of improved work practices since implementation of the WPS in 1992.
- While AHS researchers agreed in 2002 to investigate possible weaknesses in the self-reporting study design, they should be more explicit about the limitations of exposure/illness associations based on the current methodology and data.
- The AHS study results should not be interpreted as providing valid or conclusive causal links between pesticide exposure and specific health effects. The AHS researchers should discuss their observations in terms of actual exposure data and animal test data. Recent peer reviewed studies, such as the Farm Family Exposure Study and the Ontario Farm Study, clearly show pesticide exposure within accepted levels for applicators and no increased exposure to farm families not directly involved in mixing, loading or application of pesticides.
- CLA supports the EPA's Reduced Risk program that accelerates the registration approval process for products with enhanced safety profiles and minimal health impacts. This program helps focus product development efforts on compounds that feature favorable safety profiles for pesticide applicators and farm workers.