The Oregon Department of Agriculture (ODA) has proposed new rules to strengthen protections for Oregonians from chlorpyrifos pesticides. Chlorpyrifos are an extremely harmful insecticide that causes neurological harm, risk of cancer, and damage to bees, butterflies, and birds. It’s important to show the ODA that you care about protecting human and environmental health from chlorpyrifos exposure. See the full 2020 Chlorpyrifos proposed rules here.
Other states including Hawaií, California, and New York have taken steps to ban or severely restrict chlorpyrifos. Oregon had a bill in the state legislature in 2020 that Oregon PSR submitted testimony in support of that would have taken steps towards limiting chlorpyrifos and protecting public health. Since the Republican walkout stalled many important bills, the ODA is moving forward with new proposed rules to reign in this dangerous pesticide. The proposed rules, OAR-603-057-0545, are good but need to be even stronger.
Take action and tell the Oregon Dept. of Agriculture to strengthen their proposed rules limiting chlorpyrifos so that we can protect human and environmental health in Oregon from this harmful pesticide.See below for talking points and instructions for taking action.
PUBLIC COMMENT DEADLINE: October 1st, 5:00 PM
HOW TO SUBMIT COMMENTS: Please email your comments (in any language) during the open comment period to: [email protected]
You can also mail your comments to:
Amy Bingham
Chlorpyrifos 2020 Rulemaking Comment
Directors Office
Oregon Department of Agriculture
635 Capitol St NE
Salem, OR 97301-2532
INFORMATION AND TALKING POINTS:
Rule Summary: Adopt OAR-603-057-0545, which places limitations on the insecticide chlorpyrifos.
- As of December 31st, 2023, it is prohibited to use, deliver, distribute, sell, offer or expose for sale pesticide products containing chlorpyrifos, except granular forms, seed treatments and pest emergencies.
- All products that contain chlorpyrifos are restricted-use and require a certified and licensed applicator to purchase and apply such products.
- Prohibits use of chlorpyrifos in an enclosed space production structure (i.e., greenhouse, hoop house)
- Prohibits and limits certain uses starting in 2020, and requires a minimum restricted re-entry interval of four days to protect workers from being required to go back into a sprayed area too soon.
- Increases respirator protection for applicators and requires records of chlorpyrifos applications.
- Provide increased no-spray buffers from sensitive areas and permanent waterways (includes homes, farm worker housing, schools, etc), which are considerably larger than those stated on the label.
CONCLUSION:
We support ODA to take this first step to protect Oregonians from a highly hazardous pesticide, with the following recommendations.
OUR RECOMMENDATIONS:
- Prohibit all uses by December 2023 (including granular forms, seed treatments, and pest emergencies)
- Restrict all aerial sprays on all crops, not just Christmas trees, and prohibit all aerial sprays by December 2023
- Prohibit uses of granular broadcast chlorpyrifos, which will continue to poison food and drinking water, harm farm workers, cause cancer, and impair children’s neurodevelopment.
- Immediately increase no-spray buffers for aerial and airblast sprays to 500 ft.
INDIVIDUAL/WORKER COMMENT TEMPLATE:
Please use your own words in your public comment.
Dear Oregon Dept. of Agriculture,
[Insert your own sentence or two here about who you are and why you care.]
As a community member from ______, I urge you to protect the health of our communities and wildlife by phasing out all uses of chlorpyrifos by 2023. ODA should not allow continued uses of granular chlorpyrifos, which will continue to poison our food and drinking water, harm farm workers, cause cancer, and impair children’s neurodevelopment. By phasing out on this toxic pesticide in Oregon as other states have done. Oregon shouldn’t put our communities or the safety of our food at risk.
I also support the adoption of the rules on Restricted Use Pesticides in 603-057-0205 expanding the definition of pesticide characteristics that qualify for restricted use.
Sincerely,
[Your name here]
[Your city, Oregon]
SAMPLE TALKING POINTS:
Human Health
- Using your personal story, explain why it is so important to you that Oregon phase out the use of chlorpyrifos pesticides by 2023 and provide the strongest possible protections for farm workers and children in the meantime.
- The ODA rules must prioritize protecting people from chemicals that can have lasting harmful impacts on their health and well being.
- Every day we go without stronger regulations on chlorpyrifos ban, children and farm workers are needlessly eating, drinking, and breathing this highly harmful pesticide. Chlorpyrifos is acutely toxic and associated with neurodevelopmental harms in children. Prenatal exposures to chlorpyrifos are associated with lower birth weight, reduced IQ, loss of working memory, attention disorders, and delayed motor development.
- Please adopt 300 ft. buffers to protect streams for all uses of chlorpyrifos because there is no safe level of chlorpyrifos in drinking water as determined by the EPA; According to the Oregon DEQ, chlorpyrifos is a pesticide of high concern, and ODA must do more to keep chlorpyrifos out of Oregon’s waterways.
- I support increasing the re-entry interval to 4 days for all crops and plants because field workers must not be allowed to re-enter fields within 4 days after pesticide spraying to protect them from unsafe exposures.
- I support that Chlorpyrifos rule will now include a broad definition of “sensitive sites” to help protect as many vulnerable people as possible. Farm workers and people living in agricultural communities, particularly children, are disproportionately affected by this toxic pesticide. In addition to food exposures, they are more likely to have contaminated drinking water, and they are, quite literally, getting hit from all sides by drift exposures at school, at work, and on residential property and homes.
- Oregon should phase out all uses of chlorpyrifos on food crops because residues are found in many common foods, and children are more at risk because they eat more fruits and vegetables, and drink more juice for their weight.
Environmental Health
- Phase out all granular uses because once chlorpyrifos is in the soil, it sticks very strongly to soil particles. Plant roots won’t usually pick it up, and it won’t easily get into groundwater. Chlorpyrifos may wash into rivers or streams if erosion moves the treated soil.
- Chlorpyrifos should be phased out for any above ground application because it is very toxic to fish and aquatic invertebrates. It may build up in the tissues of fish and other animals that eat smaller animals. This is known as bioaccumulation.
- Chlorpyrifos should be phased out for any above ground application including sprays, granular, and chemigation (in irrigation water) because chlorpyrifos is very toxic to bees and beneficial insects. It can poison beneficial insects for up to 24 hours after it is sprayed. Chlorpyrifos can be toxic to earthworms for up to 2 weeks after it is applied to soil.
- Chlorpyrifos is very toxic to many bird species such as grackles and pigeons, and it is moderately toxic to others such as mallard ducks. Mallard ducks fed chlorpyrifos laid fewer eggs and raised fewer ducklings. The eggshells were thinner than normal, and many of the young ducklings died. Of all birds, robins are most often found dead following accidents involving chlorpyrifos use.
Resources
The problem with chlorpyrifos (Beyond Toxics)
Listing of Restricted Use Pesticides – 603-057-0205 (PDF)
Oregon Dept. Agriculture – Notice of Proposed Rulemaking Filing (PDF)
Thank you to our partner, Beyond Toxics, for assembling these resources and materials.