1. 1
The undersigned organizations submit the following comments on the Joint Fact Finding Study
Group’s (JFFSG’s) draft report entitled Pesticide Use by Large Agribusinesses on Kaua‘i. These
comments were prepared by Center for Food Safety staff scientist Bill Freese.
Earthjustice GMO Free Kaua‘i Sustainable Coastlines Hawaiʻi
Sierra Club Hawaiʻi GMO Free Hawai‘i Island Babes Against Biotech
Hui Aloha ‘Āina Momona Aloha ‘Āina Project ‘Onipaʻa Na Hui Kalo
North Shore O.H.A.N.A ‘Ohana ‘O Kaua‘i SHAKA Movement
Maui United Beach Road Farms Moms on a Mission (MOM) Hui
Hawai‘i Alliance for Progressive Action Hawaiʻi Center for Food Safety
INTRODUCTION
The JFFSG has done an excellent job gathering often difficult-to-access data on the health status of
the Kaua‘i population. The JFFSG’s recommendations are also very well-considered and
comprehensive. Much of the analysis is also very good. However, in places the assessment leaves
out critical information or perspectives, or is unintentionally misleading. In some instances, these
deficits weaken the assessment such that it fails to make a strong case for the recommended
measures. The following comments and recommendations are meant in the spirit of constructive
criticism. Page number references are to the pdf page numbers (not document page numbers, which
are often missing) of the draft report; references to “Appendix” are pdf page numbers of Appendix
II. Center for Food Safety will submit separate, more detailed comments that also provide
documentation for many of the points raised here.
PESTICIDE USAGE
Excessive attention to chlorine and structural fumigants
The JFFSG’s charge is specifically to investigate the potential impacts of pesticides used by seed
companies and other large agribusinesses on human health and the environment on Kaua‘i (p. 13).
Neither chlorine for water treatment nor fumigants used for termite control in buildings are
agricultural pesticides. Discussion of these non-agricultural pesticides (e.g. Figure 3-1 and associated
text, pp. 23, 26, 31-32) is irrelevant to JFFSG’s charge and confusing to readers. We urge that these
sections be cut from the report or at least greatly abbreviated, especially Figure 3-1. This would
open more space for discussion of agricultural pesticides, as outlined below.
Kaua‘i seed corn vs. mainland field corn
The comparison between RUP use on Kaua‘i seed corn and mainland field corn is highly misleading
because no data are provided on acres treated, but rather only rate per treated acre (lbs./acre/year).
Both metrics are required to give an adequate picture of pesticide use. This is why standard
reporting on pesticide usage by USDA (e.g. USDA’s National Agricultural Statistics Service and
Economic Research Service) employs both metrics, as discussed more fully in separate comments
from Center for Food Safety (CFS). Two examples reveal why reporting rate alone is misleading.
Table 3-3 gives the impression that bifenthrin is the most intensively used RUP on Kaua‘i because it
is applied at 5.36 times the rate that it is used on mainland corn (the highest multiple for any Kaua‘i
RUP). This impression is entirely false, however, because bifenthrin usage is insignificant: only two
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acre-treatments1
of this RUP were made on Kaua‘i in all of 2014. (In contrast, bifenthrin was
applied to 4% of mainland corn in 2014.) At the other extreme, Table 3-3 suggests that lambda-
cyhalothrin use is only moderately greater (1.46 times, based on rate) on Kaua‘i than on mainland
corn. Once again, this is highly misleading, because fully 3,070 acre-treatments of this RUP were
made on Kaua‘i in 2014, more than for any other RUP, and over 1,500-fold acre-treatments than for
bifenthrin. (In contrast, only 2% of mainland corn was treated with this insecticide.) Center for
Food Safety is providing more detailed discussion of this important issue in separate comments
from our organization.
Data on frequency of pesticide use, including general use pesticides
JFFSG provides no information on usage of general use pesticides because the Hawai‘i Department
of Agriculture does not collect this information (p. 30). However, DuPont-Pioneer released valuable
frequency of use data on all of the pesticides it used on Kaua‘i from 2007 through 2012, and this
information should be included in the report (submitted with these comments as filename: DuPont-
Pioneer Pesticides Kaua‘i 2007-12).
Include section describing spray and vapor drift of various pesticides used on Kaua‘i
Some pesticides are more likely to drift and cause adverse effects than others. The main report lacks
any real discussion of this topic. As explained more fully in separate comments from CFS, JFFSG
should assess pesticides used on Kaua‘i for the drift threat they pose to human health by evaluating:
1) How frequently they have been cited in complaints of pesticide illness in California’s Pesticide
Illness Surveillance Program (see section entitled The California Model below, under Regulation and
Oversight); and 2) How heavily they are used on Kaua‘i, as measured by field area treated. By these
two metrics, chlorpyrifos poses by far the greatest threat to human health from drift of RUPs used
on Kaua‘i, as also suggested by Milton Clark’s assessment of chlorpyrifos drift (Appendix, pp.
106ff). In light of this evidence (see also separate CFS comments), JFFSG is urged to remove the
totally inaccurate statement with respect to chlorpyrifos that “risk of exposure was essentially non-
existent through this means of drift” (Appendix, p. 15).
HUMAN HEALTH
Currently used pesticides on Kaua‘i
Under this section of the report (p. 53), JFFSG should provide the fullest possible list of pesticides
used by the seed companies on Kaua‘i, not merely the RUPs, 2,4-D and glyphosate. The list of
general use pesticides at Appendix II, Attachment 4 is inadequate for two reasons: it does not list
active ingredients, and the title (suggesting formulations used only by DuPont-Pioneer in 2011-2012)
is inconsistent with the note appended at the end by HCIA stating that it represents GUPs used by
all four seed companies as of fall 2015. Instead, we recommend inclusion in the main report of the
pesticide list mentioned above and submitted with these comments: DuPont-Pioneer Pesticides
Kaua‘i 2007-12.
Acute high dose exposure can have long-term impacts
The JFFSG should include a brief section in the main report explaining that acute, high-dose
exposure to pesticides can in certain circumstances have long-term health impacts. This is
documented in the Appendix (pp. 12-13) under the section entitled “Acute, sub-chronic and chronic
pesticide effects,” where it is noted that some acute conditions (e.g. asthma attack) can lead to
1
That is, Good Neighbor Program data for 2014 show that bifenthrin was applied to a field area of just 2 acres.
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chronic conditions, and some chronic conditions may be the result of repeated acute exposure
episodes. CFS provides a discussion of this topic, with references, in Pesticides in Paradise, Section
6.4. This could perhaps follow the section of the main report entitled “Chronic low dose pesticide
exposure” (p. 54).
Pesticides and children
JFFSG should mention an additional reason for the special vulnerability of fetuses, infants and
children to harms from pesticide exposure (p. 54) – namely, their developing physiological systems
are more susceptible to disruption than the mature systems of adults. This applies particularly to the
unborn, and has the important implication that exposure to the same pesticide at the same low level
can have very different effects depending on the developmental stage at which exposure occurs.
JFFSG for some reason qualified all studies that find associations between pesticide exposure and
childhood disease as “emerging” or “relatively new” or “evolving” research (Table 5-1 on p. 55 and
associated text). This misleadingly suggests to the reader that all research on pesticide exposure in
children is preliminary, subject to change, and hence unreliable. This is certainly not the case with
neurodevelopmental and behavioral disorders. There is a broad consensus among scientists, based
on extremely strong studies, that early life exposure to organophosphate insecticides, and in
particular chlorpyrifos, cause serious neurocognitive deficits. EPA first restricted chlorpyrifos use
15 years ago, when its adverse effects were already evident, and recently proposed to ban
chlorpyrifos, an extreme step the Agency never takes without solid (not “evolving”) research. The
evidence associating pesticide exposure with childhood leukemia is also strong and long-standing.
JFFSG should remove weakening qualifiers such as “new,” “emerging” and “evolving” in describing
the neurocognitive and cancer impacts of pesticide exposure in children.
Kaua‘i data
As JFFSG notes: “If pesticide exposure occurs primarily through chemical drift and dust, then only
populations in the immediate surrounding area of spraying or those located in the down-wind areas
from application should be surveyed for exposure. Tabulating all illnesses from the entire area
dilutes the potentially harmful effects of the pesticides studies (Appendix, p. 125).
Yet much of the reporting on disease incidence on Kaua‘i involves extremely large geographic areas,
such as “West Kaua‘i” (e.g. birth defects data) that encompasses nine zip codes including nearly all
of southern Kaua‘i as well; or similarly “Lihue-Waimea” (prostate cancer data). We urge JFFSG,
wherever possible, to report Kaua‘i health data for the smallest units possible centering on Waimea
and surrounding areas where seed companies maintain fields. This would provide the best chance
of discovering potential health effects by mitigating the “dilution” effect noted above.
Birth defects
JFFSG should include in the main report that the U.S. national birth defect rate is 3% (this is already
in the Appendix, p. 113).
Adverse birth outcomes
JFFSG states that the specific pesticides associated with low birth weight seem to be primarily legacy
products such as DDT that are no longer used (p. 58). In fact, a considerable number of studies
have associated in utero exposure to organophosphate insecticides with low birth weight and/or
delivery of small for gestational age (SGA) babies (Perera et al 2003; Wolff et al 2007; Eskenazai et
al. 2004; reviewed in Roberts and Karr 2012). There is also evidence of similar outcomes for in utero
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exposure to atrazine (Chevrier et al. 2011; Villanueva et al 2005). Thus, JFFSG should not limit the
association of these adverse birth outcomes to primarily legacy pesticides.
Illness episodes at Waimea Canyon Middle School
The critical information that JFFSG does not report but should add to the main report is that
stinkweed “odors” have never been documented to cause the severe symptoms reported by the
Kaua‘i victims (Milton Clark’s report, Appendix, pp. 150-160); while these same reported symptoms
are extremely common side effects of exposure to many different kinds of pesticides (Roberts and
Karr 2012, Table 2). If stinkweed odors at concentrations to be found in the open air do not cause
nausea, vomiting and the other symptoms, then it matters little whether first responders smelled
something like stinkweed or not when they arrived at the school. If one assumes stinkweed odors
were present, they may even have masked the smell of a pesticide that did cause the symptoms.
This section should be rewritten to include the best available information for the number of people
sickened in each episode, broken down by children, teachers, personnel; the number hospitalized; a
thorough description of their symptoms and any treatment (e.g. nebulizer) they received; a full list of
pesticides applied on the days of the two episodes and in the period of time preceding them; and a
description of side effects from inhalation of those pesticides from corresponding labels, Material
Safety Data Sheets, medical literature or other valid sources (e.g. Roberts and Karr 2012, Table 2).
JFFSG should state in the main report that UH monitoring in 2010 found a peak concentration of
stinkweed volatile MITC at Waimea that was 230-fold below California health screening levels
(Milton Clark’s report, Appendix, pp. 159-160); this is needed to balance a similar statement with
regard to the pesticides detected. JFFSG should explicitly acknowledge that even if stinkweed were
established as the cause of an “odor” (and there is dispute on this point), this does not mean that it
caused the severe symptoms. In general, Milton Clark’s fact-based testimony should be better
incorporated into the discussion in this section.
REGULATION AND OVERSIGHT
The California model
JFFSG holds up California’s pesticide regulatory and oversight system as “exemplary” (Appendix, p.
27), and recommends that the Hawai‘i Department of Agriculture and the Pesticide Advisory
Committee consult it in the process of revising Hawai‘i’s regulatory system. Key aspects of
California’s system that Hawai‘i should emulate or exceed are: 1) Mandatory collection of full data
on use of all pesticides, not just RUPs, and full disclosure of same to the public; 2) California’s Air
Monitoring Network;2
and 3) California’s Pesticide Illness Surveillance Program (PISP), which
contains data on complaints of pesticide-induced illness dating back to 1992.3
PISP information is
publicly accessible in an on-line, searchable database, and is supplemented with annual reports. We
urge JFFSG to add an additional recommendation that the Hawai‘i State government establish such
a surveillance program. In addition, California is presently moving towards additional restrictions on
use of pesticides near schools, as well as more comprehensive posting and notification rules for
anyone living near sites of application. JFFSG should investigate and describe these pending actions
in the main report.
2
See http://www.cdpr.ca.gov/docs/emon/airinit/air_network.htm.
3
See http://www.cdpr.ca.gov/docs/whs/pisp.htm.
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JFFSG should revise and expand the section in the main report that compares the pesticide
regulatory systems of California and Hawai‘i to better reflect the breadth and scope of California’s
system. The color-coded table lacks sufficient information to be comprehensible and is confusing to
readers. JFFSG should specify the Hawai‘i state law or regulation that justifies its coding of Hawai‘i
“online reporting” as “mandatory” for “all known RUP records, reports and forms.”
Inaccurate statements about EPA regulation
The discussion of the saying “the label is the law” gives a greatly exaggerated impression of the
degree of compliance with pesticide label provisions (Appendix, p. 6). JFFSG should note that there
is evidence for frequent label violations in the realm of pesticide use, on Hawai‘i and elsewhere. To
take one example, the Association of American Pesticide Control Officials, an organization of state
pesticide regulators, testified to EPA that it “has experience that supports that there are numerous
pesticide applications made when it is too windy” (i.e. application in violation of label-specified
maximum wind speed) (AAPCO 2002; cited in Pesticides in Paradise, Section 8.1.1).
JFFSG should remove the inaccurate statement that EPA’s pesticide registration process is
“precautionary” based on the statement that “until a pesticide has been sufficiently studied, it
doesn’t warrant registration” (Appendix, pp. 8-9). EPA regulates according to a risk-benefit
standard that weighs economic benefits of a pesticide’s use against proven or potential harms. For
this reason, and because of deficiencies in EPA’s assessment process and the pesticide industry’s
political influence, EPA has a long record of approving hazardous pesticides. The fact that
chlorpyrifos has remained registered for many years despite its demonstrated neurobehavioral harms
to infants and young children is just one example of EPA’s lack of “precaution.”
JFFSG states that “EPA creates toxicity tolerance levels by setting an aggregate, non-occupational
exposure and establishing the cumulative effects from exposure to different pesticides….”
(Appendix, p. 17, emphasis added). In fact, EPA considers cumulative effects from exposure to
different pesticides only in the rare cases when those “different pesticides” belong to a single
pesticide class for which the Agency has made the explicit determination that individual pesticides of
the class share a common mechanism of toxicity, which the Agency has done for only five classes of
pesticide.4
The cumulative effects of “different pesticides” are NOT assessed when they belong to
different pesticide classes; or to a single pesticide class other than those five cited in the footnote.
The EPA gives far too little consideration to the additive and synergistic impacts that can occur
upon exposure to multiple pesticides, an area that merits increased scrutiny and regulation (e.g.
Zaunbrecher et al. 2016). See also Pesticides in Paradise, Section 7.3, for studies demonstrating
cumulative effects of different pesticides not considered by EPA (e.g. atrazine/chlorpyrifos re:
aquatic invertebrates and frogs).
In the section entitled “EPA Drinking Water Regulations” (Appendix, p. 43), we urge JFFSG to
revise the discussion to clearly explain the distinct meanings of MCLG and MCL, as defined in
footnotes to the table on the same page. Suggested language follows:
“The level of a drinking water contaminant below which there is no known or expected health risk is
known as the maximum contaminant level goal (MCLG), and is not legally enforceable. The EPA
sets legally enforceable limits for contaminants, known as maximum contaminant levels (MCLs),
4
See https://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/cumulative-assessment-risk-pesticides.
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that are set as close to MCLGs as feasible using the best available treatment technology and taking
cost into consideration.”
Miscellaneous
JFFSG should remove or revise the paragraph speculating that the endocrine-disrupting impacts of
birth control pills in water may “dwarf” those of atrazine use (Appendix, pp. 13-14). The paper
cited for this statement (Bhandari et al. 2015) explores epigenetic, transgenerational effects of
bisphenol A and ethinylestradiol on medaka (a type of fish), and has not a single word to say about
atrazine, much less the magnitude of its endocrine-disrupting effects relative to estrogen from birth
control pills. Entirely undocumented speculation of this sort has no place in JFFSG’s report.
JFFSG reports that “[t]he Good Neighbor Program includes 2 buffer zone requirements”
(Appendix, pp. 31-32). However, the first “buffer zone” is actually a “notification zone” within the
bounds of which a pesticide is sprayed following notification. Because “buffer zone” is used to
designate “no-spray zone,” JFFSG should re-label this zone a “notification zone” to avoid
confusion.
JFFSG says: “Seed companies have also been implementing voluntary buffer zones. These zones
may vary but 660 feet was stated as an example of typical distances” (Appendix, p. 32, emphasis
added), but also “No existing maps showing the buffer zones were located” (Appendix, p. 31). In
the absence of maps or other solid evidence of the existence and size of any buffer zones that may
be implemented by the seed companies in their various fields, loose talk of “typical” distances that
“may vary” without any geographical reference or documentation is unacceptable. We recommend
that JFFSG remove this section, or alternately to rephrase appropriately, for instance as follows:
“Seed companies report that they implement voluntary buffer zones, however no maps were found
showing where the reported buffer zones were located; and there is also no documented
information on their size.”
Organophosphates put endangered species at risk
The EPA recently found that 97% of more than 1,700 animals and plants protected under the
Endangered Species Act are likely to be harmed by malathion and chlorpyrifos, while another 79%
are likely to be harmed by diazinon (CBD 2016). Given the wealth of threatened and endangered
species in Hawai‘i, and the extremely intensive use of chlorpyrifos, we urge JFFSG to address this
finding in the main report.
RECENT PESTICIDE DEVELOPMENTS
Glyphosate
We recommend that JFFSG balance out its discussion by giving a fuller explanation of IARC’s
determination, and also provide references to IARC’s decision, as has been done for those of the
German pesticide regulator, BfR (three references) and EFSA (one reference). Here is possible
additional language:
“WHO’s International Agency for Research on Cancer categorized glyphosate as a “probable human
carcinogen” (Group 2A) after an exhaustive evaluation of relevant studies. The determination was
based on three classes of evidence: 1) Sufficient evidence that glyphosate causes cancer in animals; 2)
Limited evidence that glyphosate causes non-Hodgkin’s lymphoma, a cancer, in farmers; and 3)
Strong evidence that glyphosate damages DNA and causes oxidative stress, two pathways to cancer
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(Guyton et al. 2015). IARC relied in part on a study that the U.S. EPA also regarded as evidence of
glyphosate’s carcinogenic potential in the 1980s (IARC 2015a, 2015b). Ninety-four (94) medical
scientists recently published a peer-reviewed paper defending IARC’s determination that glyphosate
is a probable human carcinogen and criticizing EFSA’s contrary position on glyphosate.”
Glyphosate has not been deemed “safe” by regulators, and this passage should be stricken. EPA
employs a risk-benefit approach to pesticides according to which a pesticide is registered under
federal law (Federal Insecticide, Fungicide and Rodenticide Act) if it is judged not to pose “an
unreasonable adverse effect on the human environment.” Adverse effects on the “human
environment,” which encompasses human (particularly farmer) health, can be “reasonable” if
counterbalanced by putative economic benefits. The fact that EPA registers a pesticide as general
use rather than restricted use is not equivalent to deeming it “safe.”
Under “Studies which show risk,” an important class of evidence (tumors in animals) is missing.
Please add/rephrase first sentence as follows: “…associated with the following: tumors in laboratory
animals, the cancer non-Hodgkin’s lymphoma in farmers, cellular DNA damage….”
Chlorpyrifos
JFFSG should provide a fuller discussion of the chlorpyrifos poisoning symptoms suffered by the
Syngenta employees following the episode on Kaua‘i on January 20, 2016. JFFSG maintains that
three of the ten employees were hospitalized overnight “because of symptoms such as headaches,”
but headaches are not normally sufficient reason for hospitalization. No privacy considerations
prevent a full reporting of the symptoms (obtained from the treating physician(s) or the victims), as
long as names are not released. As with the Waimea School episodes, JFFSG needs to do a better
job of reporting the acute effects of known episodes of pesticide exposure. JFFSG should also
describe EPA’s planned investigation of the incident. JFFSG should also provide a summary of
other worker protection standard enforcement actions involving pesticides that have been
undertaken in the recent past.
Enlist Duo
The treatment is inaccurate in places, biased and incomplete. At the end of the first paragraph,
JFFSG should mention that GE crops resistant to many herbicides, including 2,4-D and glyphosate,
have been field-tested in Hawai‘i (see Pesticides in Paradise, Section 3.4, based on USDA data).
JFFSG should also include the following relevant information.
EPA manipulated the science to justify overlooking 2,4-D’s kidney toxicity in laboratory animal
experiments in the context of its Enlist Duo review (Callahan 2015), and a meta-analysis of cancer
epidemiology found that 2,4-D exposure is associated with a higher incidence of non-Hodgkin’s
lymphoma, an immune system cancer, in farmers (Schinasi and Leon 2014).
JFFSG should remove the following entirely speculative and undocumented assertion: “However, it
is sure to create anxiety for the agriculture industry since many weeds have become resistant to
glyphosate, commonly used on genetically modified corn and soybeans.” Actually, farmers burned
by Monsanto’s sales pitch that using glyphosate alone with Roundup Ready crops would NOT lead
to glyphosate-resistant weeds (Hartzler 2003, Hartzler et al. 2004) are proving to be more skeptical
of Dow’s marketing of Enlist crops and Enlist Duo as the “solution” to glyphosate-resistant weeds
(Stecker 2015). Farmers at least seem to have more “anxiety” about exacerbating, with the Enlist
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system, the resistant weed epidemic that was triggered with Roundup Ready crops than about being
unable to access Enlist Duo.
JFFSG should also objectively report that scientists as well as sustainable farming advocates are
skeptical of and/or opposed to Enlist crops and Enlist Duo (and similar multiple herbicide-resistant
crop systems) because of concerns over impacts to human health, the environment, drift damage,
emergence of 2,4-D resistance in weeds, rising costs for farmers, among other concerns. Even
USDA has conceded that the Enlist system will lead to greater selection pressure for 2,4-D-resistant
weeds;5
this is not merely the “claim” of “critics,” it is a view shared by most weed scientists (e.g.
Mortensen et al. 2012; Harker et al. 2012; Keim 2014a, 2014b).
REFERENCES
AAPCO (2002) Letter from Donnie Dippel, President of Association of American Pesticide Control
Officials, to Jay Ellenberger of EPA, March 25, 2002.
Bhandari, R. K., vom Saal, F. S., & Tillitt, D. E. (2015). Transgenerational effects from early developmental
exposures to bisphenol A or 17(alpha)-ethinylestradiol in medaka, Oryzias latipes. Scientific Reports, 5. doi:
10.1038/srep09303. Available from http://www.nature.com/articles/srep09303
Callahan P (2015). EPA tosses aside safety data, says Dow pesticide for GMOs won’t harm people.
Chicago Tribune, December 8, 2015. http://www.chicagotribune.com/news/watchdog/ct-gmo-
crops-pesticide-resistance-met-20151203-story.html.
CBD (2016). EPA Analysis: 97 Percent of Endangered Species Threatened by Two Common
Pesticides. The Center for Biological Diversity, Press Release, April 7, 2016.
http://www.biologicaldiversity.org/news/press_releases/2016/pesticides-04-07-2016.html.
Chevrier C, Limon G, Monfort C, Rouget F, Garlantezec R, Petit C, Durand G, Cordier A (2011)
Urinary biomarkers of prenatal atrazine exposure and adverse birth outcomes in the PELAGIE
birth cohort. Environmental Health Perspectives 119(7): 1034-1041.
Eskenazi B, Harley K, Bradman A, Weltzien E, Jewell NP, Barr DB, Furlong CE, Holland NT
(2004) Association of in utero organophosphate pesticide exposure and fetal growth and length of
gestation in an agricultural population. Environmental Health Perspectives 112(10): 1116–1124.
Guyton KZ, Loomis D, Grosse Y, El Ghissassi F, Benbrahim-Tallaa L, Guha N, Scoccianti C,
Mattock H, Straif K (2015). Carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon,
and glyphosate. Lancet Oncology 16(5): 490-491.
Harker KN, O'Donovan JT, Blackshaw RE, Beckie HJ, Mallory-Smith C, Maxwell BD (2012). Our
View. Weed Science 60(2): 143-144.
Hartzler B (2004). What, Me Worry? Iowa State University Weed Science, May 1, 2003.
http://www.weeds.iastate.edu/mgmt/2003/monad.shtml
5
See https://www.aphis.usda.gov/brs/aphisdocs/24d_feis.pdf.
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Hartzler B et al. (2004). Preserving the value of glyphosate. Iowa State University Weed Science,
Feb. 20, 2004. http://www.weeds.iastate.edu/mgmt/2004/preserving.shtml
IARC (2015a). IARC Monographs Volume 112: evaluation of five organophosphate insecticides and
herbicides. International Agency for Research on Cancer, World Health Organization. March 20,
2015. https://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf.
IARC (2015b). IARC Monograph on Glyphosate. Volume 112, International Agency for Research
on Cancer, World Health Organization. March 20, 2015.
http://monographs.iarc.fr/ENG/Monographs/vol112/mono112-09.pdf.
Keim B (2014a). The next generation of GM crops has arrived – and so has the controversy. Wired,
June 24, 2014. http://www.wired.com/2014/06/the-future-of-biotech-crops/.
Keim B (2014b). New generation of GM crops puts agriculture in a ‘crisis situation’. Wired, Sept.
25, 2014. http://www.wired.com/2014/09/new-gm-crops/.
Mortensen DA, Egan JF, Maxwell BD, Ryan MR, Smith RG (2012). Navigating a Critical Juncture
for Sustainable Weed Management. Bioscience 62(1): 75-84.
http://bioscience.oxfordjournals.org/content/62/1/75.short.
Perera FP, Rauh VA, Tsai WY, Kinney P, Camann D, Barr D, Bernert T, Garfinkel R, Tu YH, Diaz
D, Dietrich J, Whyatt RM (2003) Effects of transplacental exposure to environmental pollutants on
birth outcomes in a multiethnic population. Environmental Health Perspectives 111(2): 201–205.
Portier CJ et al. (2016). Differences in the carcinogenic evaluation of glyphosate between the
International Agency for Research on Cancer (IARC) and the European Food Safety Authority
(EFSA). J. Epidemiol Community Health doi:10.1136/jech-2015-207005.
http://jech.bmj.com/content/early/2016/03/03/jech-2015-207005.full.pdf+html
Roberts JR, Karr CJ (2012) Pesticide Exposure in Children. Council on Environmental Health of
the American Academy of Pediatrics. Pediatrics 130(6): e1765-e1788. http://
pediatrics.aappublications.org/content/130/6/e1765.abstract/
Schinasi L, Leon ME (2014). Non-Hodgkin lymphoma and occupational exposure to agricultural
pesticide chemical groups and active ingredients: a systematic review and meta-analysis. International
Journal of Environmental Public Health 11(4): 4449-4527.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4025008/.
Stecker T (2015). Iowa farmers fearful of pesticide ‘treadmill’ – poll. Greenwire, August 26, 2015.
http://foodandagpolicy.org/news/story/agriculture-iowa-farmers-fearful-pesticide-treadmill-poll-
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Villanueva CM, Durand G, Coutté MB, Chevrier C, Cordier S. Atrazine in municipal drinking water
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Wolff MS, Engel S, Berkowitz G, Teitelbaum S, Siskind J, Barr DB, Wetmur J (2007) Prenatal
pesticide and PCB exposures and birth outcomes. Pediatric Research 61(2): 243–250.
Zaunbrecher B, Hattis D, Meinick R, Kegley S, Malloy T, Froines J (2016). Exposure and
Interaction: The potential health impacts of using multiple pesticides. Sustainable Technology and
Policy Program, UCLA, Feb. 17, 2016. Accessible at http://newsroom.ucla.edu/releases/pesticide-
mixtures-may-increase-health-risks-but-are-still-unregulated-by-california-ucla-report-says.
