Dear Mr. Pruitt, I hope you can help me out here. I’ve been having trouble explaining your recent decision in favor of the pesticide chlorpyrifos while dismissing years of work by EPA scientists to my environmental toxicology students. This is a chemical that interferes with the normal processes of the brain causing both acute toxicity – like death – and more chronic effects, particularly on developing brains and which like many other pesticides of its type, doesn’t distinguish between an insect and infant.

Granted, we consumers are exposed to small concentrations – a few parts per billion in our brussels sprout. Or our peaches. Or berries. But here’s the thing. It all adds up, apparently to more than EPA scientists calculate is “safe”. And, risk from exposure is particularly high for our nation’s farm workers and their families. Here’s what your own agency concluded just several months ago (emphasis added):

“Based on current labeled uses, the revised analysis indicates that expected residues of chlorpyrifos on food crops exceed the safety standard under the Federal Food, Drug, and Cosmetic Act (FFDCA). In addition, the majority of estimated drinking water exposure from currently registered uses, including water exposure from non-food uses, continues to exceed safe levels, even taking into account more refined drinking water exposure. This assessment also shows risks to workers who mix, load and apply chlorpyrifos pesticide products.”

This is pretty damning.

On the other hand, I understand. Growing food is difficult. I tell this to my students all the time. Meanwhile, the American public demands perfect fruits and vegetables. I am not against pesticides. While I would prefer not to eat them in my salad, I understand that there are times, for lack of alternatives growers reach for a chemical cure. But there are also a growing number of alternatives for pests controlled by chemicals like chlorpyrifos, like mating disruption (which is as it sounds; no mating, no eggs, and no wormy larvae in our fruits.) While it may not be a panacea for some growers it can reduce the need for subsequent applications. Which also suggests that there is room for regulation: what about reducing application rates? Or residue allowances? Why not strive towards limiting exposure to workers as well as consumers? One would think that even the pesticide industry would want to work towards limiting exposures.
But, rather than pulling back on the chemical you’ve decided to “review the science.” Mr. Pruitt, the science has been reviewed and the conclusion is that as used now, the chemical poses unacceptable risks for human health. The EPA’s mission is to protect human health and the environment (it says so right here.) How do I explain this to public health students who are eager to improve the health of their fellow citizens? How do I explain that their government can decide to stymie efforts to protect public health just because they don’t like the science?