Pesticides: Improvements Needed to Ensure the Safety of Farmworkers and
Their Children (Letter Report, 03/14/2000, GAO/RCED-00-40).

Pursuant to a congressional request, GAO provided information on issues
related to the safety of children who may be exposed to pesticides in
agricultural settings, focusing on: (1) what federal requirements govern
the safe use of pesticides, particularly as they relate to protecting
children in agricultural settings; (2) what information is available on
the acute and chronic effects of agricultural pesticide exposure,
particularly on children; and (3) what the Environmental Protection
Agency (EPA) has done to ensure that its Worker Protection Standard
considers the needs of children and is being adequately implemented and
enforced.

GAO noted that: (1) two laws principally govern the safe use of
pesticides: (a) the Federal Insecticide, Fungicide, and Rodenticide Act,
which requires that pesticides be approved by EPA for specified uses;
and (b) the Federal Food, Drug, and Cosmetic Act, which regulates the
residues of pesticides on or in foods; (2) in 1996, the Food Quality
Protection Act amended these two laws, requiring EPA to reevaluate the
amount of pesticide residues allowed on or in food, taking into account
consumers' aggregate exposure from other sources, including residential
exposures; (3) EPA is generally required to apply an additional margin
of safety in setting limits on pesticide residues to ensure the safety
of food for infants and children; (4) EPA must also consider any
available information concerning "major identifiable subgroups of
consumers" in reevaluating the amount of pesticide residues that can
remain on or in foods; (5) in October 1998, the Natural Resources
Defense Council and others petitioned EPA to identify children living on
and near farms as a major identifiable subgroup for the purposes of the
Food Quality Protection Act; (6) in its initial response, EPA said it
was funding several studies aimed at assessing the effects of farm
children's exposure to pesticides; (7) comprehensive information on
acute and chronic health effects due to pesticide exposure does not
exist, and data sources to track acute--short term--pesticide illnesses
are incomplete and have limitations that result in the underestimation
of both the frequency and the severity of such illnesses; (8) a number
of federally sponsored studies are under way related to the chronic
effects of pesticide exposure, but it will be many years before
conclusive results from these studies are known; (9) EPA implemented the
Worker Protection Standard to reduce farmworkers' exposure to
pesticides; (10) according to EPA, one of the most important protections
afforded by the Standard is the time intervals between when the
pesticides are applied and when workers may enter treated areas; (11)
these entry intervals were designed for adults and children 12 years and
older; (12) EPA has little assurance the protections in the Standard are
being provided at all; and (13) GAO found EPA regions have been
inconsistent in whether they set goals for the number of worker
protection inspections states should conduct, in defining what
constitutes a worker protection inspection, and in the extent to which
they oversee and monitor states' implementation and enforcement of the
Standard.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-40
     TITLE:  Pesticides: Improvements Needed to Ensure the Safety of
	     Farmworkers and Their Children
      DATE:  03/14/2000
   SUBJECT:  Labor law
	     Agricultural industry
	     Health hazards
	     Occupational safety
	     Children
	     Safety standards
	     Pesticides
	     Environmental monitoring
	     Pesticide regulation
	     Medical information systems
IDENTIFIER:  DOL National Agricultural Workers Survey
	     EPA Worker Protection Standard
	     NIOSH Sentinel Event Notification System for Occupational
	     Risks Program
	     California
	     Texas

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Testimony.                                               **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************

GAO/RCED-00-40

Appendix I: Scope and Methodology

28

Appendix II: Comments From the Environmental Protection Agency

30

Appendix III: GAO Contact and Staff Acknowledgments

34

Figure 1: Children as Young as 6 Picking Onions, April 1998 18

CDC Centers for Disease Control and Prevention

EPA Environmental Protection Agency

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

NIOSH National Institute for Occupational Safety and Health

Resources, Community, and
Economic Development Division

B-284152

March 14, 2000

The Honorable Henry A. Waxman
Ranking Minority Member
Committee on Government Reform
House of Representatives

The Honorable Tom Lantos
The Honorable Bernard Sanders
House of Representatives

Pesticides are designed to kill or control living organisms such as unwanted
species of plants, insects, and animals. Because pesticides are designed to
be toxic, they have the potential to cause adverse effects on humans.
Children are at greater risk from pesticide exposure than most adults
because, pound for pound of body weight, children breathe more and eat more.
They also have more hand-to-mouth contact than adults. The Environmental
Protection Agency (EPA) is responsible for ensuring that when properly used,
pesticides do not pose an unreasonable risk to human health or the
environment. In this regard, EPA has developed a Worker Protection Standard
that is intended to reduce the risks to agricultural workers from pesticide
exposure and the possible adverse health effects of pesticides because these
workers are among the primary populations exposed to pesticides.

Concerned about the possible adverse effects of pesticides, you asked us to
report on issues related to the safety of children who may be exposed to
pesticides in agricultural settings. As agreed with your offices, we have
addressed a series of questions pertaining to this overall topic and have
consolidated these questions into three overall issues: (1) What federal
requirements govern the safe use of pesticides, particularly as they relate
to protecting children in agricultural settings? (2) What information is
available on the acute and chronic effects of agricultural pesticide
exposure, particularly on children? (3) What has EPA done to ensure that its
Worker Protection Standard considers the needs of children and is being
adequately implemented and enforced?

Two laws principally govern the safe use of pesticides: (1) the Federal
Insecticide, Fungicide, and Rodenticide Act, which, among other things,
requires that pesticides be approved by EPA for specified uses, and (2) the
Federal Food, Drug, and Cosmetic Act, which regulates the residues of
pesticides on or in foods. In 1996, the Food Quality Protection Act amended
these two laws and required EPA to, among other things, reevaluate the
amount of pesticide residues allowed on or in food, taking into account
consumers' aggregate exposure from other sources, including residential
exposures. Unless another safety factor is determined to be appropriate, EPA
is generally required to apply an additional margin of safety in setting
limits on pesticide residues to ensure the safety of food for infants and
children. This law also directed EPA to consider available information
concerning "major identifiable subgroups of consumers" in reevaluating the
amount of pesticide residues that can remain on or in foods. In October
1998, the Natural Resources Defense Council and others petitioned EPA to
identify children living on and near farms as a major identifiable subgroup
for the purposes of the Food Quality Protection Act. In its initial response
to the Council, EPA said it was funding several studies aimed at assessing
the effects of farm children's exposure to pesticides. As of November 1999,
EPA was still considering the Council's petition.

Comprehensive information on the occurrence of acute and chronic health
effects due to pesticide exposure does not exist--whether for farmworkers,
farm children, or the population in general. The data sources that are
available to track acute (short-term) pesticide illnesses are incomplete and
have limitations that result in the underestimation of both the frequency
and the severity of such illnesses. In 1993, we reported that without a
means of monitoring pesticide illnesses, there was no way to determine
whether risk assessment or management practices were effective in preventing
hazardous exposure incidents. Our current work shows that this problem
remains largely unaddressed. Information on the chronic (long-term) effects
of agricultural pesticide exposure generally, and for farm children in
particular, is also limited. According to the National Center for
Environmental Health of the Centers for Disease Control and Prevention, the
studies that have been conducted to date have been limited, inconsistent,
and inconclusive. A number of federally sponsored studies are under way
related to the chronic effects of pesticide exposure, but because of the
complexity of the issues involved, it will be many years, and perhaps
decades, before conclusive results from these studies are known.

Recognizing the potential for pesticides to cause a variety of illnesses,
EPA has implemented the Worker Protection Standard, which is intended to
reduce farmworkers' exposure to pesticides. According to EPA, one of the
most important protections afforded by the Standard is the time intervals
between when pesticides are applied and when workers may enter treated areas
(called entry intervals). However, EPA officials told us that these entry
intervals were designed for adults and children at least 12 years old who do
farm work, but were not designed for children younger than 12 years of age.
Furthermore, EPA has little assurance that the protections called for in the
Standard are actually being provided to farmworkers generally or to children
who work in agriculture. We found that EPA regions have been inconsistent in
whether they set goals for the number of worker protection inspections
states should conduct, in defining what constitutes a worker protection
inspection, and in the extent to which they oversee and monitor the states'
implementation and enforcement of the Standard.

We are making a number of recommendations pertaining to (1) improving the
data on acute pesticide illnesses, (2) taking steps to protect children
younger than 12 years old who work in agriculture or are otherwise present
in pesticide-treated fields, (3) completing the documentation on the
adequacy of the Standard's entry intervals for children 12 years of age or
older who work in agriculture, and (4) strengthening EPA's oversight of the
states' implementation and enforcement of the Standard.

Although pesticides play a significant role in increasing food production by
reducing the number of crop-destroying pests, exposure to pesticides can be
harmful to humans. The ill effects may follow from short- or long-term
exposure through skin contact, inhalation, or ingestion. Acute symptoms
range from relatively mild headaches to fatigue, nausea, skin rashes, eye
irritation, burns, paralysis, and even death. Chronic illnesses and those
with delayed onsets, such as cancer, which may only appear years after
exposure to pesticides, can also occur. Some chronic illnesses linked to
pesticide exposure may be subtle--such as neurological disorders or reduced
cognitive skills.

EPA has reported that of the 1.2 billion pounds of pesticides used in the
United States annually, 76 percent, or about 950 million pounds, is used in
the agriculture industry. According to EPA, farmworkers are among the
primary populations exposed to these pesticides. Children may be exposed to
pesticides by doing farm work, by eating fruits and vegetables directly from
the fields, by being caught in the drift from field applications of
pesticides, or by direct contact with treated plants and soil. Children are
more vulnerable than adults are to the effects of pesticides. For example,
some pesticides pose a greater risk to infants and children because they
breathe more and eat more than adults per unit of body weight, and their
bodies and internal organs are still developing, which makes them much more
susceptible to the effects of pesticides.

The Department of Labor estimates that there are about 2.5 million hired
farmworkers and that about 1.8 million of them work on crops. The number of
children who work in agriculture is not reliably known. In 1998, we reported
that recent estimates from the Department of Labor's National Agricultural
Workers Survey (the Survey) indicated that about 129,000 14- to 17-year-olds
were being hired to work on crops in the United States, although this number
may be an underestimate.1 The Department did not survey workers under 14
years of age, but the Survey does contain limited information on children of
farmworkers from interviews conducted with their parents. For example, the
Survey indicated that, in 1996 and 1997, 7 percent of farmworkers with
children 5 years of age or younger took their children with them, at least
sometimes, when they worked in the fields. In this connection, on the basis
of thousands of inspections of agricultural establishments, the Department
of Labor's Wage and Hour Division reported in 1999 that "farmworker children
[are] forced to suffer long hours in the fields with both parents working
and [virtually] no day care alternatives."

Children

The primary federal requirements pertaining to the registration, sale, and
use of pesticides are in the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) and the Federal Food, Drug, and Cosmetic Act, both as amended by
the Food Quality Protection Act.

Under FIFRA, pesticides must generally be registered with EPA in order to be
sold or distributed. EPA will register a pesticide if it determines, among
other things, that the pesticide will not generally cause unreasonable
adverse effects on human health or the environment when used in accordance
with commonly recognized practices. EPA's principal means of ensuring that
pesticides are used properly is enforcement of the agency-approved label
directions, restrictions, and precautions. Also under FIFRA, EPA established
the Worker Protection Standard. States generally carry out the
implementation and enforcement of pesticide requirements, including the
Standard, under cooperative agreements with EPA.

According to EPA, the Worker Protection Standard is EPA's primary means to
reduce farmworkers' risks of exposure to pesticides. EPA established the
Standard in 1974, but in 1980, the agency reviewed the Standard and found it
inadequate to protect agricultural workers from exposure to pesticides. In
1992, EPA made major revisions to the Standard that the agency began
enforcing in January 1995. The revised Standard contains general protections
applicable to farmworkers and others, including prohibiting the spraying of
pesticides while anyone is in a field or allowing the exposure of people to
pesticide spray drift. The Standard also contains provisions that
specifically apply to farmworkers, including restricting entry into treated
areas for specified periods and requiring employers to provide workers with,
among other things, (1) information about when and where pesticides were
applied, (2) basic pesticide safety training, and (3) supplies (soap, water,
and towels) for workers to use to decontaminate themselves.

According to EPA, the Standard applies to any person who is compensated for
activities related to producing agricultural plants, including children who
are below the legal age to work in agriculture (generally 12 years of age or
older). However, enforcement of the Standard specifically for these young
children is problematic because proving that children are working for
compensation is difficult when such activity is illegal. For example, EPA
told us that it is unlikely that records of any illegal employment are being
kept and that neither the farmer nor the worker is likely to be forthcoming
about such an arrangement.

The Standard makes employers responsible for providing farmworkers with
basic pesticide safety training. EPA regional officials told us that
children who work in agriculture receive the same worker protection training
as adults. While FIFRA requires those who register pesticides to pay fees to
offset EPA's registration costs, none of these fees may be used for
pesticide safety training. However, EPA was recently authorized to provide
grants for farmworker training (about $200,000 a year). In addition,
according to EPA, several EPA regional offices have provided funds to either
supplement or develop programs to enhance farmworker training. EPA also
provides about $2 million per year to the Department of Agriculture for
training pesticide applicators, but none of this funding is used to train
farmworkers. During our work, we asked EPA and others about whether there
are additional sources of funding or models of funding being provided for
the purpose of pesticide safety training. We identified one such model.
Specifically, an official of the Iowa State University Extension Service
told us that Iowa assesses fees from pesticide dealers that are used to
train and certify pesticide applicators.

Under the Federal Food, Drug, and Cosmetic Act, the amount of pesticides
that may remain on or in foods is limited to a level (referred to as a
tolerance) that EPA has determined to be safe. Under the Food Quality
Protection Act, EPA sets tolerances by considering the anticipated dietary
exposures to the pesticide and other exposures for which there is reliable
information. EPA must consider risks to infants and children and must
generally include in tolerances an additional ten-fold safety margin to
protect infants and children unless another safety factor is determined to
be appropriate. EPA is also required to consider available information on
the aggregate exposure levels of major identifiable subgroups of consumers
to the pesticide and other related substances, including exposure from
dietary and other sources. 2 EPA will not register a pesticide under FIFRA
for use on foods unless it has also issued all necessary tolerances for that
pesticide.

In October 1998, the Natural Resources Defense Council and other groups
petitioned EPA to consider farm children as an identifiable subgroup for the
purpose of setting tolerances because they contended that children living on
or near farms may have substantially greater exposure to pesticides than
other groups of children. The Council also argued that these children
represent a significant proportion of the population and should be
protected. Several agricultural groups subsequently submitted comments to
EPA arguing that the Council had not presented any scientific data showing
farm children to be suffering from greater health problems than other
populations. The agricultural groups' position is that even if there were
problems with farm children being exposed to pesticides from occupational
uses, such problems should be addressed under FIFRA. The groups contend that
FIFRA was specifically designed to deal with occupational concerns, while
the Congress excluded occupational sources from the tolerance-setting done
under the Food Quality Protection Act. In December 1998, EPA stated that it
was evaluating the issues raised in the Council's petition. EPA is funding
several studies aimed at assessing farm children's exposure to pesticides
and the effects of this exposure on children's growth and development.
However, as of November 1999, EPA had not completed its response to the
Council.

As part of its implementation of the Food Quality Protection Act, EPA is
revising the way it assesses residential pesticide exposures to better
account for farm children's exposures. Among other things, in setting
tolerances, EPA will consider pesticides that are tracked into homes and
pesticide exposures children receive through spray drift in agricultural
areas. As of November 1999, EPA had not completed its revision of methods to
assess residential pesticide exposures.

Finally, Executive Order 13045--Protection of Children From Environmental
Health Risks and Safety Risks--required each federal agency to identify and
assess environmental health risks that may disproportionately affect
children. In response to the Order, EPA established the Children's Health
Protection Advisory Committee to advise and make recommendations to EPA on
issues related to children's environmental health. In 1998, the Committee
identified five existing EPA regulations that it believed should be
reevaluated to better protect children, including the Worker Protection
Standard. The Committee stated that the current Standard had not considered
children's exposure to agricultural pesticides, but EPA has not yet
responded to the Committee.

Agricultural Pesticide Exposure Is Limited

The degree to which farmworkers generally, and their children specifically,
suffer adverse effects from pesticide exposure compared with the general
population is not conclusively known. The data sources that EPA uses to
track acute pesticide illnesses have limitations that may result in the
significant underestimation of both the frequency and the severity of
pesticide illnesses. The National Institute for Occupational Safety and
Health (NIOSH) and the National Center for Environmental Health identified a
number of steps that could be taken to improve data collection and reporting
of acute pesticide illnesses.3 Information on the chronic effects of
agricultural pesticide exposure generally, and for farm children in
particular, is also limited. For example, researchers at the National Cancer
Institute have reported that farmworkers and their children are frequently
exposed to potentially carcinogenic pesticides, but little is known about
the occurrence of cancer among farmworkers. The studies that have been
conducted to date have been limited, inconsistent, and inconclusive.
Nevertheless, the Center for Children's Environmental Health Research at the
University of California at Berkeley, recently reported that despite the
lack of information on this topic, concerns still exist about the chronic
effects of children's exposure to agricultural pesticides.4 A number of
federally sponsored studies are under way on the chronic effects of
pesticide exposure, but it will be many years, perhaps decades, before
conclusive results from these studies are known.

In 1993, we reported that while some sources of information about acute
pesticide illnesses existed, they were generally limited in coverage,
comprehensiveness, and quality of information.5 As a result, there was no
capability to determine the precise national incidence or prevalence of
pesticide illnesses that occur in the agricultural sector. We concluded that
without a valid means of monitoring pesticide illnesses, there was no way to
identify problems that may occur with the different uses of pesticides or to
determine whether risk assessment and management practices were effective in
preventing hazardous exposure incidents. Six years later, we have found that
this problem remains largely unaddressed.

During our current work, officials from EPA told us that no comprehensive
national data exist on the extent to which farmworkers (and farm children)
are experiencing acute pesticide incidents or illnesses. EPA officials
referred us to the National Institutes of Health--specifically, the National
Cancer Institute and the National Institute of Environmental Health
Sciences--and the Centers for Disease Control and Prevention
(CDC)--specifically, the National Center for Environmental Health and NIOSH.
Officials from these agencies that collect data on pesticide illnesses
confirmed that a lack of comprehensive national data exists not only for
farmworkers and farm children, but for the general population as well.

In the absence of comprehensive nationwide information, EPA uses four
databases to provide some indication of the extent of acute pesticide
incidents and illnesses. These databases are (1) the American Association of
Poison Control Centers' Toxic Exposure Surveillance System, (2) the data
reported to EPA under FIFRA, (3) the National Pesticide Telecommunications
Network, and (4) the California Pesticide Illness Surveillance Program.
However, each of these databases has limitations:

ï¿½ The American Association of Poison Control Centers maintains information
on poison exposures. However, its database does not isolate pesticide
exposures that occurred from agricultural work (or from any other
occupation). In addition, some poison control centers do not report to the
national database, and reports that poison control centers receive by
telephone may lack medical confirmation.

ï¿½ Under section 6(a)(2) of FIFRA, registrants are required to submit
information they obtain about unreasonable adverse effects of their
pesticide products. The 6(a)(2) database was designed to gather information
on the effects of pesticides rather than on the extent of pesticide
incidents. Therefore, according to EPA, the database contains detailed
reports on serious and rare incidents, but little information on less
serious incidents.

ï¿½ The National Pesticide Telecommunications Network (a cooperative effort
between EPA and Oregon State University) is a toll-free telephone service
that provides the general public and health professionals with information
on pesticide health and safety and pesticide incidents. While the Network
categorizes pesticide incidents by the age, sex, and occupation of the
affected person, the Network's data rely on self-reporting, and most of the
information has not been verified or substantiated by independent
investigation, laboratory analysis, or any other means. Moreover, many
farmworkers, particularly migrant or seasonal workers, may not have ready
access to a telephone to report pesticide incidents.

ï¿½ The California Pesticide Illness Surveillance Program, often cited as the
most comprehensive state reporting system, obtains most of its case reports
through the Workers' Compensation system. Therefore, illnesses that occur in
farm children who are not officially workers are unlikely to be reported in
this system. Also, according to EPA and farmworker advocacy groups,
farmworkers may be reluctant to report pesticide exposures because of the
potential for retaliatory actions such as loss of job or pay cuts.

Notwithstanding the limitations of California's program, EPA used this
information in 1999 to make a nationwide estimate that there were 10,000 to
20,000 incidents of physician-diagnosed pesticide illnesses and injuries per
year in farm work. However, EPA recognized that its estimate represents
serious underreporting. Moreover, according to officials from the California
Department of Pesticide Regulation, because California's crops and pesticide
regulations are different from those of other states, it is inappropriate to
extrapolate California's data to the rest of the nation. In addition, there
are other reasons why acute pesticide incidents are underreported, including
farmworkers' hesitancy to seek medical care for financial reasons or for
fear of retaliation by employers and physicians' misdiagnosis or failure to
report incidents.

Given the limitations of the information on acute pesticide illnesses, we
asked officials from CDC what steps are needed to develop a model system for
monitoring and reporting acute pesticide illnesses. Two CDC agencies--NIOSH
and the National Center for Environmental Health--provided responses.

NIOSH identified a number of steps that could be taken to improve data
collection and reporting of acute pesticide illnesses, including the
following:

ï¿½ Establish reporting systems that are based on standardized data elements
for pesticide illnesses in all states. Currently, EPA and NIOSH are funding
such a program (referred to as the Sentinel Event Notification System for
Occupational Risk--or SENSOR--program). The program provides funding and
technical assistance to state health departments to support the pilot
testing of standardized data collection on pesticide illnesses and injuries.
However, federal funding for this program is limited to five states, and one
other state is participating on its own.

ï¿½ Improve the training of health care professionals to help them recognize
acute pesticide illnesses and injuries. In 1998, EPA launched an initiative
to provide health care professionals with educational and training
opportunities on the health issues pertaining to pesticides. EPA is
developing a national plan to fully implement this initiative.

ï¿½ Conduct a periodic survey of agricultural workers to identify individuals
with pesticide illnesses who have not sought health care and therefore have
not been reported in surveillance systems. Currently, the Department of
Labor's National Agricultural Workers Survey collects limited information on
the health effects on the agricultural labor force associated with pesticide
exposure. NIOSH indicated that it would like to expand the Survey to include
more extensive questions about pesticide exposures and their effects on
farmworkers and their family members.

ï¿½ Improve the collection of data on pesticide use. While some data are
available nationally on the quantities of agricultural pesticides used
annually, only a few states require the reporting of pesticide use. NIOSH
stated that to make the needed calculations of risk and illness rates, it
would be useful to have data on pesticide use from all states.

NIOSH stated that implementing these steps would result in better
information on the number of illnesses; identify trends in diseases,
epidemics, and emerging problems; and provide a means to evaluate the
effectiveness of illness prevention and intervention efforts. However, NIOSH
estimated that implementing these improvements would cost more than $20
million per year.

The National Center for Environmental Health added suggestions aimed at
collecting data on nonoccupational exposures to agricultural pesticides,
both for family members of farmers and farmworkers and for the general
public. The Center proposed establishing a national reporting system for
pesticide incidents that are nonoccupational to complement ongoing
occupational reporting. Such a system is currently being piloted in Texas,
involving active data collection and case investigations of all pesticide
exposures and illnesses in the state that are not associated with work.

Conclusively Researched

Some studies have reported associations between pesticide exposure and a
range of chronic effects on humans, including fetal deaths and deformities,
cancers, and neurological and developmental effects. However, officials from
EPA, CDC (including the National Center for Environmental Health and NIOSH),
and the National Institutes of Health (including the National Cancer
Institute and the National Institute for Environmental Health Sciences) told
us that the chronic effects of agricultural pesticide exposure on humans
have not yet been conclusively researched. For example, the National
Institutes of Health stated that while pesticide exposure increases the risk
of certain tumors, there is scientific disagreement over the specific agents
in the pesticide formulation, the specific pesticides within large chemical
classes, and the specific doses and timing of exposure that might be
responsible. The National Center for Environmental Health told us that
"studies of the long-term health effects of pesticide exposures have been
inconsistent and inconclusive; therefore, it is not possible to state with
any degree of certainty what the long-term effects of pesticide exposure may
be."

Even less is known about the combined effects of human exposure to different
pesticides. During the course of their work, farmworkers may be exposed to
several different types of pesticides. While pesticides may combine their
effects in controlling insects (known as a common mechanism of toxicity), it
is unknown whether pesticides combine their effects in the same way to cause
harm to humans. For example, NIOSH told us that virtually nothing is known
about the combined effects of different pesticides on human health.

The chronic effects of pesticides on children have been researched even less
than these effects on adults. The National Institutes of Health told us that
while links have been identified between some pesticides and leukemia,
lymphoma, and brain cancer in children, the results are not conclusive. The
research on pesticide-related cancer in children has been limited by the
availability of information, such as uncertainty about the levels and types
of pesticides involved, and the small numbers of subjects and studies.
Similarly, researchers have linked in utero pesticide exposure to defects in
fetuses' physical development and to fetal death, but these studies have
been limited by methodological constraints similar to those occurring in
cancer research.

However, the Center for Children's Environmental Health Research at the
University of California at Berkeley (designated by EPA as one of two
university research centers for studying pesticides and children's health)
recently reported that notwithstanding the paucity of information about the
effects of pesticides on children, "there is substantial evidence in
developing rodents and limited evidence in adult humans . . . that low-level
chronic exposure to organophosphates may affect neurological functioning,
neurodevelopment, and growth."

Federal researchers have several projects under way to begin determining the
nature and extent of chronic pesticide exposure on farm children. However,
this will be a long and complicated process. The federal research projects
under way include the following efforts:

ï¿½ The Center for Children's Environmental Health Research at the University
of Washington is studying the special vulnerabilities of children to health
risks from pesticides.

ï¿½ The Center for Children's Environmental Health Research at the University
of California at Berkeley is studying pesticide exposures and their effects
on approximately 500 pregnant women and their children in the Salinas Valley
area of California.

ï¿½ The National Cancer Institute, in collaboration with the National
Institute for Environmental Health Sciences and EPA, has recently begun the
Agricultural Health Study, a large study of pesticide applicators,
farmworkers, and their families in Iowa and North Carolina.

These efforts will yield results slowly over a number of years or even
decades. Recognizing the potential for pesticides to cause a variety of
illnesses, EPA has implemented the Worker Protection Standard intended to
help mitigate the possible health effects of pesticide exposure on
farmworkers.

Children, and Questions Exist About Whether the States Are Adequately
Implementing the Standard for Farmworkers Generally

One of the most important parts of the Worker Protection Standard--the time
intervals between pesticide applications and when workers may enter treated
areas (called entry intervals)--was designed to protect adults and children
who are 12 years of age or older, but was not designed for children younger
than 12 years of age. Nevertheless, there is evidence that young children
are either working in agriculture or are present in the fields for other
reasons and that they have greater vulnerability to the adverse effects of
pesticides than adults. Furthermore, although EPA has stated that
implementing the Standard is a high priority, EPA has little assurance that
the protections the Standard calls for are actually being provided to
farmworkers generally or to children working in agriculture. Under
cooperative agreements with EPA, the states monitor and enforce the
implementation of the Standard by inspecting agricultural establishments.
However, we found that EPA regions have been inconsistent (1) in whether
they set goals for the number of worker protection inspections that states
should conduct, (2) in defining what constitutes a worker protection
inspection, and (3) in the extent to which they oversee and monitor the
states' implementation and enforcement of the Standard.

Children Exposed to Agricultural Pesticides

Although young children are present in agricultural fields, either working
or accompanying their parents, and are especially vulnerable to the
potential adverse effects of pesticides, they may not be adequately
protected from pesticide exposure. While the Worker Protection Standard
applies to anyone compensated for activities related to producing
agricultural plants (regardless of age), according to EPA, the Standard's
entry intervals were designed for adults and children at least 12 years old
who do farm work, but were not designed for children younger than 12. In
1998, the Children's Health Protection Advisory Committee recommended that
EPA expeditiously reevaluate whether the Standard adequately protects
children's health. EPA officials told us that the agency had reviewed the
process used to establish the entry intervals and, in November 1999, had
concluded that the entry intervals protect children 12 years of age or
older. However, as of February 2000, EPA had not completed documenting the
analysis on which its conclusion is based. Furthermore, EPA officials told
us that the agency has not considered whether the intervals protect children
younger than 12 because their focus has been on workers of legal age.

Children below 12 years of age, whether working in agriculture or
accompanying their parents to the fields, have greater vulnerability to the
adverse effects of pesticides:

ï¿½ Because young children's internal organs and bodily processes are still
developing and maturing, their enzymatic, metabolic, and immune systems may
provide less natural protection than those of an adult. In 1997, EPA
reported that children's tissues absorb chemicals more readily and are less
effective at excreting some chemicals from the body. Also, there are
critical periods in human development when exposure to toxins can
permanently alter the way an individual's biological system operates. In
1993, the National Academy of Sciences reported that children's pesticide
exposures are of special concern because "exposure to neurotoxic compounds
at levels believed to be safe for adults could result in permanent loss of
brain function if it occurred during the prenatal and early childhood period
of brain development."

ï¿½ In addition to breathing more and eating more than adults per unit of body
weight, children behave in ways that may make them more susceptible to
pesticide poisoning than adults. Because children have greater hand-to-mouth
contact compared with adults, oral transfer rates of pesticides from
objects, dust, or soil are greater for children. Crawling, sitting, or lying
on contaminated surfaces may also increase the exposure rates of children to
pesticides.

ï¿½ Young children may not wear clothing that protects them from exposure as
well as adults' clothing. In developing entry intervals, EPA has assumed
that workers would be wearing typical farm apparel (i.e., long sleeves, long
pants, and work boots). However, this may not always be the attire young
children wear when they are in the fields.

While the federal Fair Labor Standards Act generally prohibits children
below 12 years of age from working in agriculture, the Department of Labor's
Wage and Hour Division has found children as young as 6 years old working in
agricultural fields during its inspections (see fig. 1). The Association of
Farmworker Opportunity Programs (a public interest group that collects data
on farmworkers for the National Cancer Institute) has also reported children
as young as 6 years old working in agriculture. Officials from the
Department of Labor's Wage and Hour Division told us that they have recently
increased their attention to child labor violations in agriculture. However,
officials from the Division stated that it will never be possible to uncover
all cases of underage children working in agriculture. In addition to
underage children who work in agriculture, children accompany their parents
to the fields for other reasons, such as the lack of childcare. These
children are not covered by the Fair Labor Standards Act or most provisions
of the Worker Protection Standard.

Figure 1: Children as Young as 6 Picking Onions, April 1998

Source: Department of Labor's Wage and Hour Division.

EPA considers the entry intervals it sets to be one of the most important
protections in its Worker Protection Standard. When EPA issued the revised
Standard (which became effective in January 1995), the agency adopted
interim entry intervals until all pesticides could be individually
reevaluated. These interim entry intervals were designed to protect against
acute reactions to pesticides, but chronic health effects and potential
effects on children and fetuses were not considered. In reevaluating the
entry intervals, EPA has adopted a new methodology that is more detailed and
considers chronic health effects and in utero effects. As of August 1999,
EPA had applied the new methodology to 189 pesticides (or groups of related
ingredients); EPA estimated that the new methodology may not be applied to
the remaining 192 pesticides (or groups of related ingredients) until 2006.

In developing entry intervals under its new process, EPA determines the
amount of time that is required for pesticide residues to dissipate to the
level at which it is safe for agricultural tasks to be performed. As part of
this process, EPA considers, among other factors, how much exposure workers
receive in performing specific agricultural tasks, per unit of body weight.
Body weight is a significant factor in calculating entry intervals. All
other factors being equal, lower body weight would result in longer entry
intervals. For example, EPA generally uses a body weight of 154 pounds when
calculating the entry intervals, but if the pesticide has potential fetal
developmental effects, EPA uses a body weight of 132 pounds to account for
women in their childbearing years. However, EPA told us that the entry
intervals protect children who are 12 years of age or older despite their
smaller body size (the median weight for 12-year-olds is about 100 pounds)
because their bodies have less surface area and they perform less work,
resulting in less physical contact with pesticide-treated plants. Finally,
EPA officials told us that in setting entry intervals, the agency has not
considered whether the intervals protect children younger than 12 years of
age because its focus has been on workers of legal age.

Concerned about how well the Worker Protection Standard considers children's
exposures to agricultural pesticides, in 1998 the Children's Health
Protection Advisory Committee recommended that EPA expeditiously reevaluate
the Standard to determine whether it adequately protects children's health.
The Committee made this recommendation because it believed that the current
Standard did not fully consider the pesticide exposures that children
receive through employment in farm work and through other means. EPA agreed
to this recommendation, stating that in 1999, it would review its new
process for establishing the Standard's entry intervals to affirm that the
process adequately factors in the special needs of children employed as
farmworkers. In November 1999, as discussed above, EPA officials told us
that they had reviewed the available data and concluded that the current
process for establishing entry intervals protects children who are 12 years
of age and older working in agricultural fields and that this review
fulfilled EPA's commitment to the Advisory Committee. However, as of
February 2000, EPA had not completed documenting the analysis on which its
conclusion was based and therefore had not presented its analysis to the
Committee. The Chairman of the Children's Health Protection Advisory
Committee told us that the Committee would like to assess how EPA came to
the conclusion that children of legal age are protected under the current
process. Moreover, the Chairman stated that the Committee is still
significantly concerned about the lack of protection for children below the
legal working age.

Being Adequately Implemented and Enforced for Farmworkers Generally

EPA's response to the Children's Health Protection Advisory Committee also
stated that EPA believes that the health of children who work in agriculture
can be protected by better implementation and enforcement of the Worker
Protection Standard. EPA stated that it planned to review the implementation
and enforcement of the Standard at the state level to confirm that there is
national consistency. As of November 1999, this effort was still in the
planning stages. However, we found that EPA's regions have been inconsistent
(1) in whether they set goals for the number of worker protection
inspections states should conduct, (2) in defining what constitutes a worker
protection inspection, and (3) in the extent to which they oversee and
monitor the states' implementation and enforcement of the Standard.

The implementation and enforcement of pesticide requirements, including the
Worker Protection Standard, are primarily carried out by the states under
cooperative agreements with EPA. The agency has developed guidance for the
states to use in reporting their pesticide enforcement activities to EPA
under the cooperative agreements. Under these agreements in fiscal year
1999, EPA provided the states with about $20 million (or about $400,000 per
state, on average) to carry out pesticide enforcement activities, of which
$2 million was specifically allocated for worker protection enforcement.
EPA's regional offices oversee the states' activities under the agreements.
The funds EPA provides cover enforcement activities not only for worker
protection but also for pesticide uses in urban settings, among other
activities. The ultimate use of these funds among federal pesticide programs
is determined by the states in conjunction with EPA's guidance.

In fiscal year 1998, 5 states reported to EPA that they had conducted no
routine worker protection inspections, and 11 other states each reported
conducting fewer than 10 routine inspections under the cooperative
agreements with EPA.6 In addition to the inspections conducted under the
cooperative agreements, states can conduct additional worker protection
inspections using state resources. However, EPA regional officials told us
that they generally do not receive information on the number of inspections
conducted with state resources. Moreover, officials from several EPA regions
told us that worker protection enforcement is in its infancy in some states
and that the states had conducted few, if any, routine worker protection
inspections on their own.

We also found inconsistency among EPA's regions in whether they negotiated
goals for the number of routine worker protection inspections that the
states should conduct under the cooperative agreements. Specifically, while
three of EPA's regions had established goals for the number of routine
worker protection inspections that states in their regions should conduct,
the remaining seven regions had not. Within the three regions, the goals
have established at least a minimum number of routine worker protection
inspections to be conducted under the cooperative agreements. For example,
beginning in fiscal year 1999, EPA's Atlanta region reached agreement that
each of the eight states in the region would conduct between 60 and 100
routine worker protection inspections annually. These goals call for several
of the states in the region to do many more inspections than they have done
in the past. In fiscal year 1998, Alabama reported that it had conducted
only five routine inspections under its cooperative agreement, and Tennessee
reported it had conducted four such inspections. The remaining seven EPA
regions had not negotiated routine worker protection inspection goals, and
according to officials from several regions, it is up to the states to
decide how to spend their federal pesticide resources.

Besides the inconsistency in setting inspection goals, EPA was also
inconsistent in establishing minimum requirements for what constitutes a
worker protection inspection for reporting purposes under the cooperative
agreements. Officials from six regions told us that states have varying
interpretations of what constitutes a worker protection inspection for
reporting purposes. For example, as part of our analysis of the number of
worker protection inspections conducted under the cooperative agreements
during fiscal year 1998, we noted that Oklahoma had reported conducting 174
such inspections, while New Mexico reported conducting 1 inspection.
Officials in EPA's Dallas region told us that the reason for this variation
is that some states report having conducted a worker protection inspection
if they asked a single question about worker protection during an
agricultural use inspection, while other states only report what they
consider to be comprehensive worker protection inspections. The Dallas
officials attributed this inconsistency to a lack of specificity about what
constitutes an inspection for reporting purposes under EPA headquarters'
guidance. Officials in four other EPA regions told us that they have
addressed this situation by developing regional guidance that for the
purposes of the cooperative agreements, calls for worker protection
inspections to cover all federal requirements contained in the Standard.
Although we obtained and analyzed data on the number of inspections states
reported for fiscal years 1996, 1997, and 1998, we are not including this
information in this report because of the concerns about the data's
reliability for most regions.

We also found that EPA's regions were inconsistent in the extent to which
they oversaw and monitored the states' implementation and enforcement of the
Standard. During fiscal year 1998, three of EPA's regional offices limited
their oversight of the states' worker protection enforcement programs to
file reviews, meetings and discussions with state officials, and mid- and
end-of-year reports. No one from these regional offices accompanied state
officials on any worker protection inspections during the year. For example,
the FIFRA Enforcement Coordinator in EPA's Boston region told us that no
regional representative had accompanied state inspectors on any inspections
and that the regional office was unaware of what states check for when they
conduct worker protection inspections. When we inquired about inspection
checklists for the states in the region, regional officials said that the
region did not have any and that they were unsure whether the states in
their region have inspection checklists, although they told us that one
state was developing a checklist. In contrast, seven other EPA regions
supplemented their file reviews by accompanying state officials on at least
some worker protection inspections. Officials from one region told us that
joint EPA-state inspections are the best way to observe the adequacy and
quality of a state's worker protection enforcement program. Many of the
regions said that resource constraints were the primary reason they conduct
few, if any, joint inspections.

Finally, EPA's regions had little or no information on the results of the
states' worker protection inspections. We found that the regions did not
know how many and what types of actions the states had taken in response to
worker protection violations. Although the states report to EPA on the
number and types of actions (such as fines or warning letters) taken under
their pesticide enforcement programs, these statistics do not isolate the
number and types of actions that involved worker protection as opposed to
other pesticide requirements such as the proper labeling of pesticide
products. EPA's Atlanta region, however, has developed a tracking system
that is intended to provide the region with statistics on actions states
have taken in response to worker protection violations.

Exposure to pesticides can be harmful to humans, and farmworkers are among
the primary populations exposed to pesticides. Furthermore, children are
more vulnerable to the adverse effects of pesticides because their bodies
and internal organs are still developing. The ill effects of pesticide
exposure can range from acute symptoms, such as fatigue, nausea, and skin
rashes, to chronic effects, such as cancer, neurological disorders, and
paralysis. However, there is a paucity of information on the extent of acute
and chronic adverse health effects of pesticides on humans. While EPA and
others are sponsoring research on the adverse chronic effects of pesticides,
it will likely be years, or even decades, before the precise extent and
nature of these chronic effects of pesticide exposure on humans are known.
Nevertheless, there are shorter-term steps that can be taken to quantify,
analyze, and reduce the incidence of pesticide illnesses. These steps would
benefit not only farmworkers and their families but the general population
as well. Without a valid means of monitoring acute pesticide illnesses,
there is no way to determine whether risk assessment and management
practices are effective in preventing hazardous exposure incidents.
Farmworkers depend on the implementation of EPA's Worker Protection Standard
to safeguard them from the adverse effects of pesticide exposure. However,
an important part of the Standard--its entry intervals--was not designed for
children below 12 years of age, who are more vulnerable to the adverse
effects of pesticide exposure; and while EPA has concluded that the
Standard's entry intervals adequately protect children who are 12 years of
age or older, it has not completed documenting its analysis supporting this
conclusion. Finally, EPA has little assurance that the protections called
for in the Standard are being adequately implemented for adults or children.

To better understand the overall risks that pesticides pose for farmworkers
and their families as well as for the general public, we recommend that EPA
work with the National Institute for Occupational Safety and Health and the
National Center for Environmental Health to implement their suggestions for
improving the quality of information on acute pesticide illnesses in the
nation, including establishing time frames, assigning responsibilities, and
identifying resource needs and sources to accomplish this important
objective.

We also recommend that the Administrator of EPA take the following actions:

ï¿½ Identify and expeditiously implement steps to mitigate the potential
adverse effects of pesticide exposure on children below the age of 12 who
work in agriculture or are otherwise present in pesticide-treated fields.
Such steps might range from warning farmworker parents about the adverse
effects that agricultural pesticides may have on their young children to
having pesticide labels clearly state that children should not enter
pesticide-treated agricultural areas for specified periods.

ï¿½ Complete the documentation supporting EPA's conclusion that the Worker
Protection Standard's entry intervals adequately protect children 12 years
of age and older, and provide the documentation to the Children's Health
Protection Advisory Committee for its review.

ï¿½ Improve EPA's oversight of the states' implementation and enforcement of
the Worker Protection Standard by, among other things, (1) clearly defining
what constitutes a worker protection inspection for the purposes of the
cooperative agreements, (2) establishing goals for the minimum number of
worker protection inspections that states should conduct annually under
their cooperative agreements, (3) examining whether the resources states
dedicate for this function under the cooperative agreements are adequate to
achieve the goals established, (4) clarifying the roles and responsibilities
of EPA's regional offices to ensure consistency in their oversight of the
program, and (5) taking the necessary steps to obtain and analyze data on
the results of the states' worker protection inspections, including the
number and types of actions taken in response to worker protection
violations.

We provided EPA with a draft of this report for its review and comment. EPA
provided a written response, which is included as appendix II. In addition,
we met with EPA officials including the Director, Health Effects Division,
Office of Pesticide Programs. EPA generally agreed with our findings and
recommendations and noted that it appreciated our efforts to understand
national, regional, and state perspectives on the issues discussed in the
report. With regard to our specific recommendations, EPA had the following
comments:

ï¿½ It strongly welcomes our recommendation to work with the National
Institute for Occupational Safety and Health and the National Center for
Environmental Health to expand and improve data collection and reporting of
pesticide-related illnesses.

ï¿½ It agrees that it is important to fully assess whether farmworkers'
children are currently at risk and to address that risk. However, while
EPA's comments identified a number of actions it is taking generally related
to this issue, it did not identify specific actions it plans to take
directly related to the adequacy of the Worker Protection Standard for
children under 12 years of age who work in agriculture or who are otherwise
present in pesticide-treated fields. We are concerned that this lack of
specificity will allow young children to remain at risk.

ï¿½ It agrees with our recommendation to complete the documentation supporting
its conclusion that the Standard's entry intervals adequately protect
children 12 years of age and older. EPA officials told us that they
anticipate providing the documentation to the Children's Health Protection
Advisory Committee in 2000.

ï¿½ It believes that our recommendation on the implementation of the Worker
Protection Standard is consistent with what EPA has found in looking into
the implementation of the Standard. However, EPA did not specifically
address how it plans to implement the detailed steps laid out in our
recommendation.

EPA also provided technical comments that have been incorporated in the
report, as appropriate.

We conducted our review from June 1999 through February 2000 in accordance
with generally accepted government auditing standards. See appendix I for
our scope and methodology.

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days after
the date of this letter. At that time, we will send copies to other
congressional committees with jurisdiction over EPA pesticide programs and
to the Honorable Carol M. Browner, Administrator, EPA. We will also make
copies available to others on request.

If you have any questions about this report, please call me at (202)
512-6111. Key contributors to this report are listed in appendix III.

Peter F. Guerrero

Director, Environmental
Protection Issues

Scope and Methodology

To determine what federal requirements govern the safe use of pesticides,
particularly as they relate to protecting children in agricultural settings,
we reviewed the Federal Insecticide, Fungicide, and Rodenticide Act and
specifically the Environmental Protection Agency's (EPA) Worker Protection
Standard. Additionally, we examined the Federal Food, Drug, and Cosmetic Act
as amended by the Food Quality Protection Act. In doing so, we reviewed the
petition that the Natural Resources Defense Council and other groups
submitted to EPA requesting that farm children be designated as a major
identifiable subgroup for setting pesticide tolerances for foods. We also
reviewed comments from agricultural groups on the petition. Finally, we
reviewed EPA's procedures for assessing residential pesticide exposures to
determine how EPA is better accounting for farm children's exposure.

To establish what information is available on both the acute and chronic
effects of agricultural pesticide exposure, particularly on children, we (1)
evaluated data sources that EPA uses to analyze acute illnesses related to
pesticides and (2) reviewed current research literature on the chronic
effects of pesticide exposure. We also obtained information from leading
researchers currently studying pesticide illnesses, including
representatives from EPA; the National Cancer Institute and the National
Institute for Environmental Health Sciences (both part of the National
Institutes of Health); the National Institute for Occupational Safety and
Health and the National Center for Environmental Health (both part of the
Centers for Disease Control and Prevention); and academic research centers,
including the University of Washington and the University of California at
Berkeley. We also interviewed officials from several offices at EPA
headquarters, most of which were within the Office of Prevention,
Pesticides, and Toxic Substances, Office of Pesticide Programs. Because the
National Institute for Occupational Safety and Health is the federal agency
responsible for conducting research on occupational disease and injury, we
obtained its analysis of the strengths and limitations of the current
pesticide reporting systems as a whole and with regard to agricultural
workers. We also obtained suggestions from the National Center for
Environmental Health on improving the reporting of pesticide illnesses and
injuries that are not associated with work.

To evaluate the adequacy of the Worker Protection Standard, particularly as
it pertains to children, we obtained documents on the issuance and revisions
of the Standard. Our documentary review included EPA's response to public
comments on the proposed Worker Protection Standard; EPA's National Dialogue
on the Worker Protection Standard, March 1997; a Worker Protection Standard
evaluation conducted by EPA's Seattle regional office; a number of states'
worker protection inspection checklists; and other guidance material. We
also interviewed the Chairman and other representatives of the Children's
Health Protection Advisory Committee about its recommendation that EPA
evaluate the Standard to determine whether it effectively protects
children's health. We met with officials from EPA's Health Effects Division
to obtain information on the development and reassessment of the Standard.
We reviewed documents on how EPA currently formulates entry intervals to
protect farmworkers. Finally, to determine whether children were, in fact,
being employed as farmworkers or were present in the fields for other
reasons, we analyzed data provided by (1) the Department of Labor's National
Agricultural Workers Survey, (2) the Department of Labor's Wage and Hour
Division, and (3) a survey conducted by the Association of Farmworker
Opportunity Programs for the National Cancer Institute.

To assess the status of worker protection implementation, we interviewed and
obtained information from officials in EPA's Office of Enforcement and
Compliance Assurance on its guidance to EPA's regions about overseeing the
states' worker protection enforcement programs. (For the purposes of this
report, "states" include all 50 states, the District of Columbia, U.S.
territories, and Native American tribes.) We conducted interviews with the
officials responsible for the implementation and oversight of the worker
protection program in each of EPA's 10 regional offices. We also obtained
data on the number and comprehensiveness of worker protection inspections
conducted by the states. We reviewed the quality and consistency of EPA
regions' oversight of the states' implementation of the Worker Protection
Standard by determining the extent to which regional officials had
accompanied state personnel on worker protection inspections and by
determining whether EPA's regions had any information on the results of
state inspections. Finally, we accompanied representatives from the Virginia
Department of Agriculture and Consumer Services on two worker protection
field inspections.

We conducted our review from June 1999 through February 2000 in accordance
with generally accepted government auditing standards.

Comments From the Environmental Protection Agency

GAO Contact and Staff Acknowledgments

Chuck Barchok, (202) 512-3548

In addition to the individual above, Patricia J. Manthe, Richard A. Frankel,
Donald J. Sangirardi, Gopaul E. Noojibail, and Richard P. Johnson made key
contributions to this report.

(160487)

Figure 1: Children as Young as 6 Picking Onions, April 1998 18
  

1. We reported that information collected by the Bureau of the Census
indicated that the number of 15- to 17-year-old agricultural workers may be
as high as 290,000. This number included workers who work on crops, with
livestock, or in services related to agriculture, such as mechanical
repairs. These young workers may be hired, self-employed, or unpaid family
workers. We also reported that the Fair Labor Standards Act and state laws
provide less protection for children working in agriculture than for
children working in other industries. For example, children as young as 16
may work in agriculture in any capacity, including in some occupations
declared hazardous by the Secretary of Labor, while in nonagricultural
industries, children generally may not perform such tasks until age 18. The
report also stated that the Congress may wish to reevaluate whether the Fair
Labor Standards Act adequately protects children who are hired to work as
migrant and seasonal farmworkers. See Child Labor in Agriculture: Changes
Needed to Better Protect Health and Educational Opportunities
(GAO/HEHS-98-193 , Aug. 21, 1998).

2. The Food Quality Protection Act did not specifically define major
identifiable subgroups of consumers.

3. NIOSH is a federal agency that conducts research on occupational disease
and injury, and the National Center for Environmental Health is a federal
agency that conducts research and monitors and evaluates environment-related
health problems.

4. The Center for Children's Environmental Health Research at the University
of California at Berkeley has been designated by EPA as a research center
for studying the relationship between pesticides and children's health,
including growth and development.

5. Pesticides on Farms: Limited Capability Exists to Monitor Occupational
Illnesses and Injuries (GAO/PEMD-94-6 , Dec. 15, 1993).

6. EPA regional officials told us that one of the states that had reported
doing no routine worker protection inspections had actually conducted many
such inspections but that these inspections were reported under a different
inspection category.
*** End of document. ***