Toxics Action Center and Environment Maine support the Board of Pesticides Control’s proposed rules Chapter 26 because it reduces exposure to pesticides through Integrated Pest Management techniques and through increasing Mainers’ right-to-know about pesticides used in their homes and their workplaces.
Through requiring Integrated Pest Management, this rule will reduce pesticide use. Identifying conditions conducive to causing pest problems and implementing practical, cultural and non-toxic methods of pest control measures can go a long way to stopping the pest problem but also further protects the structural integrity and value of homes and buildings. Most importantly, by reducing pesticide use, we are reducing exposure.
By increasing Mainers’ right-to-know about pesticides use where they live and work, this rule is further reducing pesticide exposure. Information about toxic chemicals used in homes is crucial to parents who want to protect their children from the dangers pesticides pose. By providing workers with the right-to-know about pesticides in the workplace, this rule further helps reduce exposure, providing Mainers, especially those with Multiple Chemical Sensitivity, immune problems, and/or other health problems with information they need to ensure they are protected.
While we recommend that this rule be enacted, we also propose two small changes to further protect Maine residents from toxic exposure.
First, while the rule outlines what information applicators are required to provide, it does not spell out to residents and workers the type of information they can request. We recommend that in the applicators be required to identify in notification letters and postings, that residents and workers can request the trade name and EPA Registration number of the pesticide to be applied; the proposed date and time of the application; the location of the application; the reasons for the application; the re-entry interval listed on the product label; what IPM steps have been taken before application; and the name and phone number of the person whom further inquiry regarding the inquiry might be made.
Secondly, we recommend that applicators post or provide (either through a paper copy or virtually) the material safety data sheets for the pesticides used to residents (in the case of residential applications) or the client (in the case of commercial applications).
Simply stating that residents and workers have the right to ask for more information is not that useful for those who do not know what kinds of information to ask for or know what kind of information is available. By outlining what information is available and by providing the material safety data sheets, residents and workers will have even more information with which to protect themselves.
Submitted by:
Will Everitt, Toxics Action Center, 39 Exchange Street Ste 301, Portland, ME 04101,
(207) 871-1810
and
Matthew Davis, Environment Maine, 39 Exchange Street Ste 301, Portland, ME 04101,
(207) 253-1965
