February 13th, 2010
The New Hampshire legislative committee on the Environment and Agriculture held a hearing on 2/11/10 to discuss Bill #1456 presented by Representative Suzanne Smith. This bill proposed the creation of a committee to study the use of pesticides in the schools and other places where children congregate. Here is the text of my written testimony regarding the need for every state to recognize that they can work as partners with the pest control industry without exposing children and school staff to poisons.
by Barbara Rubin
Part I: General Remarks
Thank you for permitting me to offer this information in support of HB 1456. We urgently need to improve the indoor air quality (IAQ) of schools through reducing and/or potentially eradicating the use of pesticides with known toxicity effects upon people and other non-targeted life forms.
As a disabled educator poisoned by pesticides used in my own NYC school facility in 1999 and, as a part-time journalist who has published a few articles and commentaries on the subject matter, I hope my informal remarks and lay studies will be of use to this committee. Please forgive any errors committed in the conveyance of this testimony as I am mildly aphasic and have acquired learning disabilities. These disabilities have been attributed to brain injury suffered in a NYC school setting as a result of exposures to the very chemicals we are here to discuss. My exposures occurred while I was a supervisor of a school for developmentally disabled children between 2 and five years of age. My aim today is to discuss the scope of inquiry for a committee dedicated to developing a needs assessment for policy setting in pest control practices. I hope to accomplish this through a review of well known issues in the science of pest control and my own, personal experience of the terrible results of ignoring science in the service of retaining old technologies and business practices.
Pest control services are a vital industry to the health of the population. We know that it is impossible to eradicate insect populations, and other invasive organisms. While these will always be with us, controls are important in preventing intolerable concentrations of these unwanted items from turning into infestations and uncontrolled colonizations of molds or bacteria. Advances in chemistry taught us how quickly we can kill such organisms but gave us little preparation for the collateral damage such chemicals can cause. Fortunately, we now have the knowledge and technology which allows us to avoid sacrificing the safety of building occupants against the desirable goals of pest management A study regarding pesticide use in the schools is not a dismissal of the value of pest control services but rather an investigation into the forms it should take in these environments occupied by the most vulnerable of exposed populations – children and a largely female staff.
Pesticides are toxic by definition and it remains against the law for vendors to claim they are ‘safe’, even when used as directed. This alone makes examination of their use in schools a worthwhile endeavor. We know pesticides include ingredients which are irritants as well as well as contributing to asthma – the largest cause of missed school days for children and the fourth largest cause of lost work productivity among adults. While the waste products and remains of dead pests such as roaches also contribute to respiratory problems, those can be resolved with a vacuum cleaner unlike the residues left by pesticides.
Sometimes the cure is worse than the ailment.
Pesticides are a class of chemicals which include not just products that kill insects but also target other life forms – hence the suffix, ‘cide’. This extends the range of our concerns here to include herbicides (targeting weeds); mildicides/fungicides (targeting molds/ fungi) and products which kill disease promoting micro-organisms like bacteria. Many products called ‘repellents’ are actually pesticides despite the alteration in labeling. Today, DDT is applied as a repellent to the interior of house walls in some countries. The overuse and abuse of biocides such as triclosan has led to the development of antibiotic resistant bacteria which has become a concern to school programs in recent years. Our increased understanding of mycotic diseases stemming from exposures to certain forms of molds and fungi associated with moisture damaged buildings has led to increased use of fungicides and mildicides in the schools. These pesticidal agents are present in products used in cleaning to those used in painting and other construction/renovation materials. Since all of these products are regulated by the same EPA department, I suggest they should be considered by this committee as falling within their scope of inquiry. It would not only serve the NH communities but set precedents for other states to broaden their range of concerns. For a full listing of the various kinds of pesticides, I refer you to this website by the EPA.
A major concern should be the fact that the most commonly used pesticides act by disrupting the ability of nerve cells to cease firing, over and over again until they become damaged or die. They don’t discriminate between the type of cells they disrupt and humans are a non-targeted organism affected by them. Central nervous system functioning is primary to learning. Developmental disabilities are now affecting one in six children according to Dr. Phillip Landrigan of Mt. Sinai Hospital, a leader in developing the field of environmental pediatrics. You may wish to consult with him since you will be reviewing the testimony of experts in the field at some point in this process. Further, exposure to toxic materials is also a candidate for investigation into high rates of illness, particularly autoimmune diseases. Disability among adults working in the schools may also be worth examining in a needs assessment of the type being recommended today.
Pesticides are quite persistent when used indoors without the aid of sunlight to degrade them, contrary to assumptions and recommendations for re-entry to treated rooms on material data and safety sheets. Exposure considerations must take into consideration the re-release of pesticide residues into the air each time a treated surface is exposed to heat (e.g. baseboard heating surfaces), light from direct sun or lamp exposure, or subjected to increased temperatures from seasonal changes. Recurrent applications, something which is very common in school settings, leads to issues of insect resistance calling for the use of more and mixed types of pesticides. The effects of combining chemicals upon bystanders has not been studied but we do know that effects are not just additive but synergistic. Also, the break-down byproducts or metabolites of some pesticides are more toxic than their original forms (as in the case of malathion).
Further, decades of use of chemicals such as chlordane and DDT, prior to their bans, means continued risks to children in older buildings where these chemicals and their metabolites remain. This means that the age of school buildings and their locations should also fall within the parameters of our concern. I have personally measured concentrations of these chemicals in both low and high amounts in residences. School locations are also subject to pesticide drift from nearby sources. Proximity to farms and gardening/nursery enterprises are obvious sources while communities near marshes and bodies of water will be open to drift for chemicals used for mosquito control. Commercial properties near schools may still be allowed to use chemicals currently banned for residential and school use so such chemicals can still become significant presences in our schools.
Drift from aerial applications of pesticides for forestry management and farming purposes travels extensively and communication with the Department of Agriculture in preparing a needs assessment for the testing of buildings is advisable. Aerial spraying is soon to be banned altogether in the European Union for this reason. Exposure by children in agricultural communities has been proven to be unavoidable, regardless of proximity to farmland as measured in metabolites of these chemicals in the urine of children. Therefore, applications in schools add to the overall body burden of children already affected by these chemicals in other settings.
The literature on the effects of pesticides contains a wealth of evidence for both immediate and delayed symptoms, long term damage to multiple organs biochemical processes apart from enzyme inhibition and adversely affecting learning abilities. Pesticides are also delivered in solvents such as xylene and trimethylbenzene, members of a large and hazardous class of regulated substances all on their own. These are known central nervous system depressants and carcinogens. The Ontario College of Family Physicians did an exhaustive review of the literature with specific conclusions about the risks of exposure to children by these chemicals.
This is the basic information I wished to present to this committee. My next submission is about my personal experiences which exemplifies how vital it is that we do not ignore this technical data. The results of doing so are with us daily.
Part II: My Personal Experiences in Pest Control in School Settings:
I first learned of my vulnerability to pesticides when I fainted following the departure of a pest control applicator in a school where I worked in the Bronx, NY in 1990. After learning about Dursban, the chemical in use, I began to work with accommodation plans permitting me to be absent when pesticides were applied each month. However, while a difference of a few days may make it appear as if one escapes hazards, the effects can only be assessed by looking at biochemical changes rather than overt symptoms. A poison is not just a substance that brings direct harm to us but also one that damages by adversely impacting catalysts in the body which are necessary to other functions. These may include hormones (e.g. thyroid, estrogen) or various enzymes (e.g. acetylcholinesterase). Reductions in important enzymes, interference in hormone regulation, inflammation and deferred symptoms of toxicity must be considered.
The information I gained at that time was used again when I lived in NYC in 1999 when West Nile Virus made its appearance in New York City and malathion was unwisely chosen to be applied by helicopter. Testimony by experts before a bi-partisan congressional committee headed by Congressman Gary Ackerman in March of 2000 found it to be most unwise with side effects far more damaging than its presumed benefits. The practice was halted. I have appended a copy of an article I wrote in 2002 for a magazine in which the effects of pesticides in school settings are discussed with respect to a particular child along with general considerations and quotes from interviews with several experts in the field.
We now use pyrethroids in many locations where we used to use the organophosphates listed above since they were banned for the purpose. Pyrethroids are often advertised as synthetic pyrethrins or acting much like the anti-pest effects of the essence of chrysanthemum flowers. However, we also know these chemical effects, while still disabling to the nervous system, are amplified by the addition of synergists to the formulas. This increases the toxicity beyond the levels at which the active ingredient was approved for sale. Attached is a news article describing up to a ten-fold increase in toxicity, rendering these chemicals threats to aquatic life. The particular synergist cited is piperonyl butoxide and quite toxic in its own right.
I had never heard of pyrethroids until June of 1999 when I was enjoying my second year as supervisor for a school program for developmentally disabled preschoolers called the Douglaston Early Childhood Center. This program was run under the aegis of the New York League for Early Learning (a subsidiary of YAI/National Institute for Early Learning). Having learned first hand that environmentally induced illnesses in school programs can be avoided, I had instituted an indoor air quality program in our first year of operation (1998) which proved quite effective in maintaining a productive working and learning environment.
The spraying of pesticides in and around the property ceased and increased maintenance efforts along with the use of baits unlikely to become airborne were substituted. The school building itself was used for multiple purposes and the owners, in conjunction with their pest control company that more toxic pesticides should be applied in spray form during our week long break between spring and summer sessions. Upon our return, the staff and I all were conscious of residual fumes and remained in better ventilated areas of the school until they faded. Unknown to me, further applications were made to the building and I developed serious and chronic health effects. By September of 1999, I was unable to eat during school hours and lost weight; fought constant bronchial constriction requiring me to carry oxygen with me to work since inhalers were not effective for me. I found myself unable to concentrate for prolonged periods of time, to recall names of familiar people and had difficulty with word-finding in conversations and in my writing. Where it used to take me two hours to write a comprehensive clinical report, it now took days to achieve anything resembling a satisfactory effort. [additional description of symptoms/damage submitted here as well]
My career was over.
An EPA complaint was filed regarding lack of notice and the use of those chemicals in poorly ventilated areas and locations where food was prepared, both advised against in the MSDS sheets. The investigator informed me that the EPA did not pursue actions in the use of registered pesticides as it comprised a conflict of interest between the applicators and their agency which approves these chemicals for use. Instead, they encourage private individuals to file law suits in order to encourage the industry to refrain from using these chemicals in school buildings, residences etc. My law suit is still pending. The federal government has yet to pass the School Environment Protection Act or SEPA, providing national guidelines for the use of nontoxic methods and least toxic methods of pest control. Notification for use of such products to interested parties is also included in those provisions. Only a handful of states have such regulations at present and my own home state of NY didn’t pass their version until a year after I was disabled.
I ask this body to conduct their needs assessment and do whatever it takes to make my tragedy the last of its kind in the Northeastern United States. The material is not only plentiful in identifying the undesirability of using toxic pesticides in school settings but the alternatives are plentiful The pest control industry is slowly evolving into novel practices referred to as Integrated Pest Management or IPM. I thought my school program was following such IPM protocols but was denied my rights to participate in the process because local laws to that effect were lacking. Every person should have the right of choice with regard to exposure to toxic chemicals for themselves and their children, whether that involves being able to substitute other products for the undesirable ones or simply leave the vicinity. Had I known recurrent applications were going to be made, I would have quit my job before becoming so damaged.
We don’t have to choose between pest control and human safety. We can have it all if all parties are required to modernize their knowledge of the effects of these chemicals and make better decisions about selecting among them. It takes work but then that is what adults do to ensure our children grow up to become healthy and capable individuals. The sight of a few ants or roaches shouldn’t be a barrier to any of us losing our health, our futures and becoming burdens upon society instead of assets.
Barbara Rubin, M.A.
Former speech-language pathologist and educator