Submitted on behalf of

NORTHWEST COALITION FOR ALTERNATIVES TO PESTICIDES, et al. Petitioners

This petition for rulemaking is submitted on behalf of 180 organizations seeking full disclosure of ingredients in pesticide products. The petition is submitted pursuant to the provisions of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. § 136w, and the Administrative Procedure Act, 5 U.S.C. § 553(e). Petitioners request that EPA amend its pesticide labeling regulation, 40 C.F.R. § 156.10, to require that pesticide product labels clearly list all ingredients, including inert ingredients, by common name.

INTRODUCTION

EPA's current pesticide labeling regulation, 40 C.F.R. § 156.10, does not require that pesticide manufacturers disclose all ingredients in their products. Rather, 40 C.F.R. § 156.10 requires only that "active" ingredients be disclosed.1 There are a number of compelling reasons to amend this regulation to require disclosure of all ingredients in pesticide products. First, contrary to their name, "inert" ingredients are not inert in a biological or chemical sense.2 Inert ingredients can be poisonous, carcinogenic, flammable, and dangerous to human and environmental health.3 Pesticide labels that disclosed all ingredients would allow consumers to make better informed judgments about which pesticide products to buy. Second, EPA does not have the resources necessary to evaluate the toxicity of all inert ingredients, and therefore should require disclosure so that consumers can make their own evaluations of toxicity. Third, since the public assumes that potential harms are disclosed on product labels, unless EPA amends its regulation to match public expectations, the public may incorrectly assume that products containing toxic "inert" ingredients pose no risk. Fourth, disclosure of all ingredients on labels will facilitate faster and more accurate medical diagnoses and treatment for people injured by exposure to pesticides. Finally, requiring full disclosure of all ingredients provides an incentive for manufacturers to use less toxic ingredients.

"INERT" INGREDIENTS ARE OFTEN HARMFUL TO HUMAN AND ENVIRONMENTAL HEALTH

As we noted above, many inert ingredients are toxic -- sometimes more toxic than "active" ingredients. For example, one of the inert ingredients used with the common herbicide glyphosate is more acutely toxic than glyphosate itself.4 A chemical may even be an "active" ingredient in one pesticide and an "inert" ingredient in another, depending entirely on the manufacturer's designation of the pest targeted by the product.5 Under EPA's current regulation, ingredients identified as "active" in one product need not be disclosed if designated as "inert" in another product. An investigation conducted by the Northwest Coalition for Alternatives to Pesticides, one of the petitioners here, revealed that almost 400 ingredients, currently designated as "inerts," are or were at one time registered as active ingredients.6 This same investigation also revealed that many ingredients EPA lists as "inerts" are classified as "hazardous" under federal environmental laws. In fact, over 633 so-called "inert" ingredients have been identified under the Superfund Amendments and Reauthorization Act (42 U.S.C. § 1101 et seq.), the Clean Water Act (33 U.S.C. § 1251, et seq.), the Clean Air Act (42 U.S.C. § 7401 et seq.) or some other environmental statute as "hazardous."7 Metabolites and breakdown products of inert ingredients may also pose significant health risks. For example, nonylphenol ethoxylates, a common "inert" ingredient in pesticides, degrade into nonylphenol, an ingredient so toxic that is required to be listed on pesticide labels even under EPA's current labeling regulation. This chemical conversion occurs readily in waterways8 and municipal sewage treatment plants.9 Nonylphenol is not only toxic, but is a member of an ever- growing group of chemicals proven or suspected to have an effect on the normal function of sex hormones in humans and many other species.10 It makes no sense not to require disclosure of compounds that readily degrade to form nonylphenol when nonylphenol itself is required to be disclosed on product labels.

FULL DISCLOSURE SHOULD BE REQUIRED BECAUSE EPA DOES NOT HAVE THE RESOURCES TO EVALUATE THE TOXICITY OF INERTS ON A CASE-BY-CASE BASIS

Although EPA has been trying to address the problem of inert ingredients since at least 1984, it has addressed to date only a tiny fraction of the universe of inerts. Because EPA simply does not have the resources necessary to conduct case-by-case analyses of inert ingredients in a timely fashion, it should require disclosure so that concerned consumers can make their own determinations with respect to particular inerts.

EPA Has Not Evaluated the Toxicity of Most Inerts

EPA currently lists over 2,500 substances on its "List of Pesticide Product Inert Ingredients," yet EPA has evaluated the toxicity of only a small fraction of these ingredients. Well over 1,900 "List 3" inert ingredients are identified as being of "unknown toxicity," meaning that EPA claims not to know whether these substances are toxic or innocuous.11 If label disclosure must await full toxicity testing for each of the 1,900 inerts of "unknown" toxicity, the public will continue to bear the risks of exposure to toxic ingredients for the foreseeable future. Without the resources to even research its own data bases for information on the toxicity of these ingredients (See Part I of this Petition, and accompanying exhibits), the only way for EPA to inform consumers is to require disclosure of the identities of these ingredients on pesticide labels.

EPA Does Not Currently Require Manufacturers to Submit Toxicity Data Necessary to Evaluate the Toxicity of Inert Ingredients.

Even if EPA had significantly greater resources to conduct case-by-case analyses of inert ingredients, EPA does not require manufacturers to submit the data necessary to assure consumers that potentially harmful inerts will be disclosed. EPA's current criteria for determining whether an inert ingredient is of "toxicological concern," and therefore should be identified on the label of a pesticide product, include: carcinogenicity, adverse reproductive effects, neurotoxicity or other chronic effects, developmental toxicity, documented ecological effects, and potential for bioaccumulation.12 EPA does not, however, require pesticide manufacturers to submit data on most of these effects. For example, EPA does not require manufacturers to submit data on carcinogenicity testing, testing for reproductive effects (other that teratogenicity), testing for chronic effects in either laboratory animals or wildlife, or testing for bioaccumulation potential.13 Without this information, EPA cannot apply the criteria it is supposedly using to determine whether or not an inert ingredient is harmful. EPA's Criteria for Determining Toxicity Are Incomplete EPA's toxicity evaluation criteria do not in any event consider several important toxicological concerns. Disruption of the hormone system, synergistic interactions between chemicals, individual variation in susceptibility to toxins, and damage to the immune system have all been identified in other fora as significant toxicological problems,14 but these potential toxicological problems are not evaluated at all under EPA's current approach to inert ingredients. This means that even if EPA had the resources to address the toxicity of inert ingredients on a case-by-case basis, it would still not reach many of the toxicological risks that are of concern to the public. Because EPA does not have the resources to adequately classify inerts in the foreseeable future, it should simply require disclosure, so that consumers, and consumer protection organizations, can make their own evaluations.

EPA'S CURRENT LABELING SYSTEM MAY CAUSE CONSUMERS TO INCORRECTLY ASSUME THAT PRODUCTS CONTAINING TOXIC INGREDIENTS POSE NO RISK

Last year, EPA instituted the "Consumer Labeling Initiative" (CLI) in order to "foster pollution prevention, empower consumer choice, and improve consumer understanding of safe use, environmental, and health information" for the labeling of pesticides and disinfectant cleaners.15 Consumer interviews conducted by EPA in the course of this study indicate that the public wants and expects detailed ingredient information on product labels.16 Consumers also expect federal labeling laws to protect the public by requiring disclosure of potentially hazardous ingredients.17 Under 40 C.F.R. § 156.10 as currently written, these expectations are not met. Among a list of typical consumer items bought at a grocery store--a can of beans, a bottle of skin lotion, and a can of insect spray--the label on the can of insecticide, the only obviously toxic item on the list, will disclose the least ingredient information. Under most consumer protection statutes, the responsible agency either requires disclosure of ingredients to aid the consumer in assessing risk, or requires that a product be tested to determine risks. To assure the public's safety, the Federal Food, Drug and Cosmetic Act, 21 U.S.C. § 301 et seq., the Consumer Product Safety Act, 15 U.S.C. § 2051 et seq., the Flammable Fabric Act, 15 U.S.C. § 1191 et seq., and the Fair Packaging and Labeling Act, 15 U.S.C. § 1451 et seq. require either disclosure of ingredients or product safety testing. Neither EPA registration of pesticide products nor its approval of pesticide labels provide an assurance of safety to the public - in part because much of the product (i.e., inert ingredients) has not even been evaluated. In the spirit of consumer protection and the right to know, when EPA cannot guarantee that a registered pesticide is safe, it should provide the public with all information necessary for consumers to decide for themselves whether risks posed by a product are acceptable.

DISCLOSURE OF INERT INGREDIENTS SHOULD BE REQUIRED TO ENSURE FASTER AND MORE ACCURATE MEDICAL DIAGNOSES AND DETERMINATIONS OF RISK

Without disclosure of inert ingredients, health risks associated with inert ingredients cannot be assessed by those who are exposed. The CLI Phase I Report concludes that consumers select pesticides and other products based on perceived risk, as indicated by label contents.18 Consumers with health conditions, small children, or pets, already rely on the (currently limited) information on pesticide labels to refrain from buying products containing substances they know to avoid.19 Under the current regulations, however, these consumers must simply hope that the ingredients not disclosed on the label do not pose a health risk. If disclosure were required by EPA, consumers would be more fully informed as to potential chemical exposure when selecting and using a pesticide product. Labels that fail to disclose complete ingredient information also prevent doctors from performing necessary diagnostic tests and accurately interpreting test results. See Ziem decl. at ¶¶ 3-10. Treatment delays resulting from incomplete ingredient disclosure are detrimental to patient health, and can increase medical expenses. Id. Complete disclosure will more fully enable consumers to monitor their chemical exposure, and will lead to faster, more accurate, medical diagnoses. See Ziem decl. at ¶¶ 3-7.

REQUIRING FULL DISCLOSURE OF INGREDIENTS WILL PROVIDE INCENTIVES TO REDUCE THE USE OF HARMFUL INGREDIENTS IN PESTICIDE PRODUCTS.

Requiring full disclosure of ingredients in pesticide products will encourage pesticide manufacturers to use less toxic inerts in their formulations, thereby making pesticides less harmful. In 1987, EPA's Office of Pesticide Programs (OPP) identified 57 List 1 inerts, and required that these ingredients be disclosed on the labels of products containing the ingredient.20 At the time, these 57 inert ingredients were used in approximately 1300 products. Today, only eight List 1 inerts are in use, on approximately 160 products.21 The requirement that the identity of those inert ingredients be disclosed obviously provided an incentive for manufacturers to use less toxic inert ingredients. A full disclosure rule would provide this incentive for all pesticide products.

AMENDING EPA'S LABELING REGULATIONS TO REQUIRE FULL DISCLOSURE WILL NOT HARM MANUFACTURERS

Requiring that manufacturers disclose inert ingredients on pesticide labels will not cause competitive harm to manufacturers. Most inert ingredients in pesticides already may be identified through publicly available sources, although with considerable difficulty to the average consumer. Material Safety Data Sheets (MSDS's), for example, are required by the Emergency Planning and Community Right to Know Act, 42 U.S.C. § 11021, and OSHA's Hazard Communication Standards, 29 C.F.R. § 1910.1200(g), and are available to the public under 42 U.S.C. § 11021(c)(2) and 11044. The identities of inert ingredients are frequently disclosed on these MSDS's. In addition, reverse engineering can identify specific pesticide ingredients in most products.22 Manufacturers themselves frequently release ingredient information in response to public requests, although again this is a cumbersome and laborious process.23 Any financial burden to manufacturers from label modification will be negligible, and in fact disclosure of inert ingredients on product labels may actually benefit manufacturers. The Consumer Labeling Initiative Report cites research finding that consumers look positively upon detailed safety information on labels: they view the manufacturer as more concerned with consumer safety and are more likely to buy products with explicit warnings.24 In addition, full disclosure of inert ingredients would encourage pesticide manufacturers to conduct complete toxicological profiles on each inert they use. With this information in hand, manufacturers could reassure the public that product risk has been fully assessed and disclosed.

EPA HAS THE AUTHORITY TO AMEND ITS LABELING REGULATIONS TO REQUIRE DISCLOSURE OF INERT INGREDIENTS

EPA itself has determined that FIFRA authorizes EPA to require disclosure of inert ingredients on pesticide labels. EPA has stated that "FIFRA authorizes EPA to regulate all ingredients used in pesticide products, including inert ingredients that are not in themselves pesticidally active." As explained by EPA: The statutory standard that is the basis for [EPA] regulation of pesticide labeling is contained in section 2(q) of FIFRA, which defines a misbranded pesticide and enumerates specific labeling deficiencies that constitute misbranding....

The Agency is empowered to enforce its labeling requirements pursuant to its authority to regulate pesticide distribution and sale. FIFRA sec. 3 requires that a pesticide be registered prior to distribution and sale. As a prerequisite to registration, the labeling of the pesticide must comply with the requirements of the Act. Failure to comply with the labeling requirements may result in a denial of an application for registration or may provide grounds for cancellation of the registration of the pesticide under FIFRA sec. 6.

49 Fed. Reg. 37960 (1984). In addition, EPA recognizes that "FIFRA authorizes EPA to regulate all ingredients used in pesticide products, including inert ingredients that are not in themselves pesticidally active." Id. at 37965. Under both FIFRA and the Freedom of Information Act (FOIA), there is a presumption that inert ingredients should be disclosed.25 The only inerts which are exempt from mandatory disclosure under FOIA are those which have been proven by the manufacturer to be confidential commercial information. To make such a showing, a manufacturer must prove that it has taken measures to protect the confidentiality of the identity of an inert ingredient and that the identity is not reasonably obtainable without the business's consent. 40 C.F.R. § 2.208. As discussed above, the identities of inert ingredients are regularly disclosed in sources available to the public such as Material Safety Data Sheets, patents, and scientific papers. In addition, the identity of inert ingredients can be ascertained by other manufacturers through reverse engineering. EPA should use its authority to require disclosure of all inert ingredients on pesticide labels.

ACTION REQUESTED

Petitioners request that EPA modify 40 C.F.R. § 156.10(g) as follows: [Proposed changes of 40 C.F.R. §156.10(g) are in bold/italic; deletions are in strikeout] 40 C.F.R. § 156.10 Labeling requirements. ...

(g) Ingredient statement--

(1) General. The label of each pesticide product must bear a statement which contains the name and percentage by weight of each active ingredient; the common chemical name of each inert ingredient, and total percentage by weight of all inert ingredients; and if the pesticide contains arsenic in any form, a statement of the percentages of total and water-soluble arsenic calculated as elemental arsenic. The active ingredients must be designated by the term "active ingredients" and the inert ingredients must be designated by the term "other ingredients," or the singular forms of these terms when appropriate. Both terms shall be in the same type size, be aligned to the same margin and be equally prominent. The statement "Other Ingredients, none" is not required for pesticides which contain 100 percent active ingredients. Unless the ingredient statement is a complete analysis of the pesticide, the term "analysis" shall not be used as a heading for the ingredient statement. ... (7) Inert ingredients. The Administrator may require the name of any inert ingredient(s) to be listed in the ingredient statement if [s]he determines that such ingredient(s) may pose a hazard to man or the environment.

CERTIFICATION

The undersigned certifies that, to the best knowledge and belief of the undersigned, the information presented in this petition is true.

Mike Axline

Western Environmental Law Center

1216 Lincoln Street

Eugene, OR 97401

Norma Grier

Northwest Coalition for Alternatives to Pesticides

P.O. Box 1393 Eugene, OR 97440-1393 (541) 485-2471 (541) 344-5044

Respectfully submitted this 20th day of January, 1998.

FOOTNOTES

1 Active ingredients frequently constitute only a small percentage of the chemicals in a pesticide product. The remainder of the pesticide formula is made up of other chemicals, collectively called "inert ingredients." FIFRA defines inert ingredients as ingredients that are not "active." 7 U.S.C. §136(m). 2 In 1987, EPA designated four categories, or "lists," of inert ingredients. 52 Fed.Reg. 13305. In 1989, List 4 was subdivided, creating Lists 4A and 4B. 54 Fed.Reg. 48314. EPA describes the lists as follows:

List 1 Inerts of toxicological concern (8 compounds)

List 2 Potentially toxic inerts, with high priority for testing (101 compounds)

List 3 Inerts of unknown toxicity (1981 compounds)

List 4A Inerts generally regarded as safe (119 compounds)

List 4B Inerts for which EPA has sufficient information to reasonably conclude that the current use patterns in pesticide products will not adversely affect public health and the environment (309 compounds)

2. Id. As of 1995, EPA recognized a total of 2,518 inert ingredients in pesticide products sold in the United States. (USEPA, Office of Pesticide Programs. May, 1995. List of Pesticide Product Inert Ingredients.)

3 EPA itself recognizes that "[t]he definition in FIFRA section 2(m) of such ingredients as 'inert' is intended only to distinguish them from those that are pesticidally active, and in no way signifies that they are toxicologically or chemically inert. Inert ingredients may or may not be hazardous by themselves, or in combination with other ingredients." 49 Fed. Reg. 37960, 37965 (1984). Although inerts can constitute as much as 99% of a product, 40 C.F.R. § 156.10 as currently written does not require identification of most inert ingredients on pesticide labels. Only the eight List 1 inerts (54 Fed.Reg. 48314), plus four additional inert ingredients, must be identified on pesticide labels. 49 Fed. Reg. 37980.

4 Glyphosate is far from unique. As numerous published studies document, many pesticide products contain toxic inert ingredients. See Sawada, Y., Y. Nagai, M. Ueyama, and I. Yamamoto. 1988. Probable Toxicity of Surface-Active Agent in Commercial Herbicide Containing Glyphosate. The Lancet, 1(8580):299 (finding the surfactant, rather than the active ingredient, caused the symptoms of acute toxicity in 56 human poisoning cases); Wan, M. T., R. G. Watts, and D. J. Moul. 1991. Acute Toxicity to Juvenile Pacific Northwest Salmonids of Basacid Blue NB755 and Its Mixture with Formulated Products of 2,4-D, Glyphosate, and Triclopyr. Bull. Environ. Contam. Toxicol., 47:471-478 (finding an inert ingredient, a blue tracer dye, was toxic to salmonids and increased the toxicity of herbicide formulations to which it was added); Saunders, L. D., R. G. Ames, J. B. Knaak, and R. J. Jackson. 1987. Outbreak of Omite-CR-Induced Dermatitis Among Orange Pickers in Tulare County, California. J. of Occ. Med., 29(5):409-413 (finding worker injuries after orchard re-entry were caused by increased persistence of the active ingredient due to an inert preservative added to formulation); Harville, J. and S. S. Que Hee. 1989. Permeation of a 2,4-D Isooctyl Ester Formulation through Neoprene, Nitrile, and Tyvek Protection Materials. Am. Ind. Hyg. Assoc. J., 50(8):438-446 (finding solvent, an inert ingredient, in 2,4-D herbicide formulation increased likelihood that herbicide would penetrate protective clothing).

5 EPA "has also identified several inerts of toxicological concern which are present in pesticide formulations to act against some pest. . . . Although these ingredients have traditionally been designated as inert ingredients, EPA believes that they are actually active ingredients." 52 Fed. Reg. 13305, 13307 (1987).

6 See Declaration of Holly Knight at ¶ 4.

7 Id. at ¶ 9.

8 See Talmage, S. A. 1994. Environmental and Human Safety of Major Surfactants: Alcohol Ethoxylates and Alkylphenol Ethoxylates. Boca Raton: Lewis Publishers.

9 See Giger, W., P. H. Brunner, and C. Schaffner. 1984. 4-Nonylphenol in Sewage Sludge: Accumulation of Toxic Metabolites from Nonionic Surfactants. Science, 225, 623; and Ahel, M., T. Conrad, and W. Giger. 1987. Persistent Organic Chemicals in Sewage Effluents. Environmental Science and Technology, 21(7), 697.

10 See e.g., White, R., S. Jobling, S. A. Hoare, J. P. Sumpter, and M. G. Parker. 1994. Environmentally Persistent Alkylphenolic Compounds Are Estrogenic. Endocrinology, 135(1), 175-182.

11 U.S. EPA, Office of Pesticide Programs. May, 1995. List of Pesticide Product Inert Ingredients.

12 See 52 Fed. Reg. 13305, 13306 (1987).

13 See 52 Fed. Reg. 13308.

14 See e.g., Davis, D. L., and H. L. Bradlow. 1995. Can environmental estrogens cause breast cancer? Scientific American, 273(4):166-172; Bukowski, J. A., M. G. Robson, B. T. Buckley, D. W. Russell, and L. W. Meyer. 1996. Air levels of volatile organic compounds following indoor application of an emulsifiable concentrate insecticide. Environmental Science & Technology, 30(8):2543-2546; Sharpe, R. M., et al. 1995. Gestational and lactational exposure of rats to xenoestrogens results in reduced testicular size and sperm production. Environmental Health Perspectives, 103(12):1136-1143 (endocrine disruption caused by 4-octylphenol and benzyl butyl phthalate); Jobling, S., et al. 1996. Inhibition of testicular growth in rainbow trout (Oncorhynchus mykiss) exposed to estrogenic alkylphenolic chemicals. Environmental Toxicology and Chemistry, 15(2):194-202 (endocrine disruption caused by nonyl phenol and octyl phenol); Nelson, B. K. 1994. Interactions in developmental toxicology: A literature review and terminology proposal. Teratology, 49(1):33-71 (showing one third of the combinations of teratogenic agents acted synergistically); Abou-Donia, M. B., et al. 1996. Neurotoxicity resulting from coexposure to pyridostigmine bromide, DEET, and permethrin: Implications of Gulf War chemical exposures. Journal of Toxicology and Environmental Health, 48(1):35-56 (neurotoxic agents acted synergistically); Muto, M. A. 1992. Embryotoxicity and neurotoxicity in rats associated with prenatal exposure to Dursban. Veterinarian and Human Toxicology, 34(6):498-501 (formulated pesticide caused toxicity not seen when animals were exposed only to the active ingredient); Furlong, C. E. 1989. Spectrophotometric assays for the enzymatic hydrolysis of the active metabolites of chlorpyrifos and parathion by plasma paraoxonase/arylesterase. Anal. Biochem., 180(2):242-247 (documenting low-activity forms of detoxification enzymes in some individuals); Agency for Toxic Substances and Disease Registry, U. S. Dept. of Health and Human Services. 1997. Toxicological profile for chlorophenols: Draft for public comment, 53-54 (immune system is sensitive to 2,4-dichlorophenol, an inert ingredient).

15 Executive Summary, "Consumer Labeling Initiative, Phase I Report," EPA Office of Pollution Prevention and Toxics, September 30, 1996.

16 See CLI at 11, 23.

17 See id. at 12, 49.

18 Id. at 35.

19 Id. at 32.

20 See EPA Office of the Inspector General. September 27, 1991. Inert Ingredients in Pesticides. Audit Report #E1EPF1-05-0117-1100378.

21 U.S. EPA, Office of Pesticide Programs. October 22, 1997. Introductory Statement prepared for the OPP Pesticide Program Dialogue Committee Meeting. See Attachment A

22 See Northwest Coalition for Alternatives to Pesticides v. Browner, 941 F. Supp. 197, 202 (D.D.C. 1996) (hereinafter NCAP v. Browner).

23 See Attachments B, C.

24 See CLI at 47. 25 See NCAP v. Browner, 941 F. Supp. 197, 201 (D.C. Cir. 1996). See also Defendant's Memorandum of Points and Authorities in Response to Plaintiffs' and Intervenor's Motions for Summary Judgment in NCAP v. Browner, supra (Attachment D) at 10 ("The plain language of FIFRA § 10 requires inert ingredients to meet the legal standard for confidentiality before [EPA] can withhold them from release under the FOIA.")

Submitted on behalf of the following organizations and businesses:

NATIONAL/INTERNATIONAL ORGANIZATIONS

Peg Seminario AFL-CIO 815 16th Street, NW Washington, D.C. 20006

Brad Easterson American PIE PO Box 340 South Glastonbury CT 06073-0340

Sandy Schubert Children's Health Environmental Coalition PO Box 846 Malibu CA 97265

Jonathan Talbot EarthSave 706 Frederick St Santa Cruz CA 95062-2205

Peter Montague Environmental Research Foundation PO Box 5036 105 Eastern Ave. Suite 101 Annapolis MD 21403-7036

Richard Wiles Environmental Working Group 1718 Connecticut Av. NW, Ste 600 Washington DC 20009

Shelley Davis Farmworker Justice Fund 1111 19th St NW, Suite 1000 Washington DC 20036-3603

Martin Bourque Food First Institute for Food & Development Policy 398 60th St. Oakland CA 94618

Corinna Gilfillan Friends of the Earth 1025 Vermont Ave NW, Suite 400 Washington DC 20005-6303

Mark Ritchie Institute for Agriculture & Trade Policy 2105 First Avenue South Minneapolis MN 55404-2505

Terry Gips International Alliance for Sustainable Agriculture 1701 University Ave. SE Minneapolis MN 55414-2076

Albert Donnay MCS Referral & Resources 508 Westgate Road Baltimore MD 21229

Wendy Gordon Mothers and Others for a Livable Planet 40 West 20th Street, Ninth Floor New York NY 10011

Mary Lamielle National Center for Environmental Health Strategies, Inc 1100 Rural Ave. Voorhees NJ 08043

Jay Feldman National Coalition Against the Misuse of Pesticides 701 E St., SE Washington DC 20003

Ellen Hickey Pesticide Action Network North America Regional Center 116 New Montgomery St. #810 San Francisco CA 94105-3607

Hope Shand RAFI USA PO Box 640 Pittsboro NC 27312

Fernando Bejarano Pesticide Action Network in Mexico RAPAM Amado Nervo 22-2, Col San Juanito 56100 Texcoco, Edo de México

Carolyn Raffensperger Science & Environmental Health Network Rt. 1, Box 73 Windsor ND 58424

Jane Rissler Union of Concerned Scientists 1616 P St NW, Suite 310 Washington DC 20036

Carolyn Hartmann US Public Interest Research Group 218 D St SE Washington DC 20003

Richard Liroff World Wildlife Fund 1250 24th Street NW, Suite 500 Washington DC 20037-1175

LOCAL AND REGIONAL ORGANIZATIONS AND BUSINESSES

Allen Spalt Agricultural Resources Center 115 W Main St Carrboro NC 27510

Kevin Harun Alaska Center for the Environment 519 W 8th Ave., Suite 201 Anchorage AK 99501-3549

Peter Henner Alliance for Environmental Renewal 60 Scutt Road Feura Bush NY 12067

Kenneth Scallon American Lung Association of NY 8 Mountain View Avenue Albany NY 12205

Michael Gregory Arizona Toxics Information PO Box 1896 Bisbee AZ 85603

Brian Smith Ashland Community Food Store 237 N. First St Ashland OR 97520

Dave Davison Association of Bainbridge Communities PO Box 10999 Bainbridge Island WA 98110

Panther Wilde At Home on Earth 4770 Vahalla Drive Boulder CO 80301

Samuel Sage Atlantic States Legal Foundation 658 West Onondaga St. Syracuse NY 13204-3757

Karen Coulter Blue Mt. Biodiversity Project HCR 82 Fossil OR 97830

Lorraine Pace Breast Cancer Help 400 Montauk Hwy. West Islip NY 11795

Elsa Ford Brentwood/Bayshore Breast Cancer Coalition 620 Suffolk Ave, Suite 1 Brentwood NY 11717

Diane Bowen California Certified Organic Farmers 1115 Mission St Santa Cruz CA 95060

Sara Greensfelder California Indian Basketweavers 16894 China Flats Rd. Nevada City CA 95959

Ed Maschke California Public Interest Research Group 474 Terrace Road Santa Barbara CA 93105

Patty Clary Californians for Alternatives to Toxics 860 _ 11th St. Arcata CA 95521

Rose Marie Williams Cancer Awareness Coalition PO Box 931 New Paltz NY 12561

Ann Collins Capital District Community Gardens 295 8th Street Troy NY 12180

Laura Lauffer Carolina Farm Stewardship Association PO Box 448 Pittsboro NC 27312

Britt Bailey Center for Ethics & Toxics PO Box 673 Gualala CA 95445

Kristie Thorp Center for Rural Affairs PO Box 406 Walthill NE 68067

Stephanie Prial Central Co-op Inc. 1835 12th Ave Seattle WA 98122

Michael Lax Central New York Occupational Health Clinical Center 6712 Brooklawn Pkwy Syracuse NY 13211

Mary Bertrand Chums of Barker Creek PO Box 111 Tracyton WA 98393

Annie W Hunt Citizens Against Chemical Contamination 8735 Maple Grove Rd. Lake MI 48632-9511

Jerry Chernow Citizens Against Pesticides P O Box 3010 Madison WI 53704

Nova Turner Citizens Against Pollution PO Box 1634 Choctaw OK 73020

Marion Wise Citizens' Environmental Coalition 33 Central Ave. Albany NY 12210

Leanna Hoelscher Citizens for a Better Environment 407 S Dearborn St., Suite 1775 Chicago IL 60605

John Austin Citizens Reaction Against Pollution 6356 Sundown Drive Jacksonville FL 32244-3112

Wynne Falkowski Coalition Against Toxics 223 Park Avenue Atco NJ 08004

Tony Tweedale Cold Mountain, Cold Rivers 224 E Pine #2 Missoula MT 59802

Barbara DiTommaso Commission on Peace and Justice Roman Catholic Diocese 40 N Main Ave Albany NY 12203

Bene't Luchiow Committee for Universal Security 1095 Smith Grade Rd. Santa Cruz CA 95060

Vivian Stockman Concerned Citizens' Coalition Otto Rt. Box 105A Spencer, WV 25276

Jim Slama Conscious Choice Magazine 920 N. Franklin Suite 202 Chicago IL 60610

John Runkle Conservation Council of North Carolina PO Box 3793 Chapel Hill NC 27515

Bob Shavelson Cook Inlet Keeper Box 1498 Homer AK 99603

G. Mick Smith East Whiteland Historical Commission Broad & Vine M.S. 503 Philadelphia PA 19102

Phyllis Koenings Eastern Shore Pesticide Education Network 6201 Knoll Hill Drive Berlin MD 21811

Paul Faulstick Ecology Center Pitzer College Claremont CA 91711

Mike Garfield Ecology Center of Ann Arbor 117 N Division Street Ann Arbor MI 48104

Judy Braimen Empire State Consumer Association Rochesterians Against Misuse of Pesticides 50 Landsdowne Lane Rochester NY 14618

Kevin Bundy Environmental Protection Information Center PO Box 397 Garberville CA 95542

Audry Thier Environmental Advocates 353 Hamilton St Albany NY 12210

Marc Chytilo Environmental Defense Center 906 Garden St., Suite 2 Santa Barbara CA 93101

Margarita Rono Farmworker Self-Help, Inc 3720 Lock Street Dade City FL 33523

Mary O'Shea Food Co-op 11702 Euclid Ave. Cleveland OH 44106

Martin Keeley Friends of Boundary Bay PO Box 1441, Station A Delta BC V4M 3Y8

James Olsen Friends of the Bitterroot PO Box 442 Hamilton MT 59840

Anita Ward Friends of the Greensprings 15097 Hwy. 66 Ashland OR 97520

Michael Pilarski Friends of the Trees Society PO Box 4469 Bellingham WA 98227

Miranda Holmes Georgia Strait Alliance 1726 Commercial Dr. Vancouver BC CANADA V5N 4Z3

C Bear Golden Florins Box 2118 Chelan WA 98816

Madelyn Hoffman PO Box 146 Grass Roots Environmental Organization Flanders NJ 07836

Reg Gilbert Great Lakes United Inc. SUCAB, Cassety Hall 1300 Elmwood Ave. Buffalo NY 14222

Joan Kleban Greater Goods 515 High Eugene OR 97401

Christine Weidner GROW, Inc. 38 Llangollen Lane Newtown Square PA 19073

Rick Scudder Hawaii Heptachlor Research and Education Foundation 1188 Bishop St., Suite 2308 Honolulu HI 96813

Julie Norman Headwaters PO Box 729 Ashland OR 97520

Sue Navy High Country Citizens' Alliance PO Box 1066 Crested Butte CO 81224

Paul Goettlich Hoosier Envt'l Council PO Box 6854 South Bend IN 46660-6854

Debra Martin Horton Road Organics 93851 Horton Rd. Blachly OR 97412

Bill Howell Howell's Pest Control PO Box 850407 Yukon OK 73085-0407

Patti Lewis Humane Society of Charlotte PO Box 221028 Charlotte NC 28222

Aspacio Alcantura Independent Farmworkers Center Centro Independiente de Trabajadores Agricolas PO Box 78 Florida NY 10921

Andrea Gladstone Ithaca Breast Cancer Alliance PO Box 853 Ithaca NY 14851

Terry Shistar Kansas for Safe Pest Control 809 East 661 Diagonal Rd. Lawrence KS 66047-9001

Charles Benjamin Kansas Natural Resource Council 935 S. Kansas Ave., Suite 200 Topeka KS 66612

John Keslick Keslick & Son Modern Arboriculture 214 North Penn Street West Chester PA 19380

Cynthia Valencia Legal Envt'l Assistance Foundation 1115 N Gadsden St Tallahassee FL 32303-6327

Amy Schlachtenhaufen Lighthawk 2915 East Madison, #306 Seattle WA 98112

Andrew Manitt Long Island Neighborhood Network 511 Central Ave Massapequa NY 11758

Judy Pannullo Long Island Progressive Coalition 90 Pennsylvania Avenue Massapequa NY 11758

Bob & Jill Herman Lorien Herbs & Natural Foods Inc E. 414 Trent Spokane WA 99202

Elizabeth Mayes Lower Hudson Sierra Club 28 Whitmen Street Hastings NY 10706

Ruth Berlin Maryland Pesticide Network 544 Epping Forest Rd. Annapolis MD 21401

Jean Lemieux Massachusetts Assoc. for the Chemically Injured PO Box 754 Andover MA 01810

James Baker McKenzie Guardians 51013 McKenzie Hwy. Finn Rock OR 97488

Lynn Lawson MCS: Health & Environment PO Box 1732 Evanston IL 60201

Sarah O'Donnell Mendocino Cancer Resource Center 45131 Covelo Mendocino CA 95460

Betty & Gary Ball Mendocino Environmental Center 106 W Standley Ukiah CA 95482

Susan Crampton Methow Forest Watch PO Box 162 Twisp WA 98856

Mary E. Kent Minnesota Herbicide Coalition 4075 W 51st St #107 Edina MN 55424-1408

Anne Hedges Montana Environmental Info. Center Box 1184 Helena MT 59624

Anne Johnson Montanans Against Toxic Burning 324 Fuller Avenue, Suite C2 Helena MT 59601

Billy Stern Native Forest Network PO Box 8251 Missoula MT 59807

Douglas Hunt Network for Envir & Economic Resp of the United Church of Christ 1820 Sanford Road Wheaton MD 20901-4008

Jim Moore New York Coalition for Alternatives to Pesticides 353 Hamilton St Albany NY 12210-1709

Joel Shufro New York Committee for Occupational Safety & Health 95 Sheeman New York NY 11218

Claire Barnett New York Healthy Schools Network 33 Central Avenue Albany NY 12290

Judi Enck New York Public Interest Research Group 107 Washington Ave Albany NY 12210

Susan Mihaly New York Sustainable Agriculture Working Group 121 N. Fitzhugh St. Rochester NY 14614

Howard Kuff Newton County Wildlife Assn. P.O. Box 189 Jasper AR 72641

Amy Goldsmith New Jersey Environmental Federation 902 Main St. Belmar, NJ 07719

Jane Nogaki New Jersey Right to Know and Act Coalition 223 Park Ave. Atco NJ 08004-2749

Peter Vasilas North Shore Environmental Network 11 Hilltop Dr. Bayville NY 11709

Steve Gilman Northeast Organic Farming Association Ruckytucks Farm 130 Ruckytucks Road Stillwater NY 12170

Leslie Fritchman Northwest Co-op Federation 4201 Roosevelt Way NE Seattle WA 98105

Nina Bell Northwest Environmental Advocates 302 Haseltine Building 133 SW 2nd Ave #302 Portland OR 97204-3526

Judy Kulk Northwest Specialties 943 N 83rd St Seattle WA 98103

Colleen Cooney Ontario Health Advocacy Association 1102 Kitchen SR RR #1 Coldwater ON L0K 1E0

Lisa Brenner Oregon Clearinghouse for Pollution Reduction 3816 NE Glisan Portland OR 97232

Laura Weiss Oregon Environmental Council 520 SW Sixth #940 Portland OR 97204

Gilly Lyons Oregon Natural Desert Association 16 NW Kansas Avenue Bend OR 97701

Nick Patel Oregon Natural Resource Council 5825 N. Greeley Ave. Portland OR 97217-4145

Randy Tucker Oregon State Public Interest Research Group 1536 SE 11th Ave. Portland OR 97214

Brian Barker Organic Materials Review Institute P.O. Box 11558 Eugene, OR 97440-3758

Lynn Coody Oregon Tilth 11535 SW Durham Road, Suite C-1 Tigard, OR 97224

Suzanne Pardee Pacific Crest Biodiversity Project 4649 Sunnyside Ave N, #321 Seattle WA 98105

Colette DePhelps Palouse-Clearwater Environmental Institute PO Box 8596 Moscow ID 83843

Kristin Rowles Pamlico-Tar River Foundation PO Box 1854 Washington NC 27889

Paul Schissler Paul Schissler Associates 714 Wilson Avenue Bellingham WA 98225-7349

Linda Conklin People for Healthy Forests PO Box 3252 Sonora CA 95370

Bill Patterson People Opposing Pollution Mobile AL 36606

Ruth Troetschler Pesticide Task Force Loma Prieta Chap. Sierra Club 184 Lockhart Lane Los Altos CA 94022

Jeanne Merrill Pesticide Watch 450 Geary #500 San Francisco CA 94105

Carroll Johnston Physicians for Social Responsibility, Oregon Chapter 2065 High SE Salem OR 97302

Alba Morales Political Ecology Group 965 Mission Street #700 San Francisco CA 94103

Susan K. Snow Pollution Solution 417 Brentwood Blvd Lafayette LA 70503

Chuck Hadd, Sr. Pristine Products 2311 E Indian School Road Phoenix AZ 85016

Samantha McCarthy Regional Environmental Advcy Project 1631 La Habra Ct. Davis CA 95616

Maria Hopple Renssalaer County Environmental Action Hinckle Road Poestenkill NY 12140

Lynn Montandon Response Team for Chemically Injured 5932 Entrada Ave Atascadero CA 93422

Margaret Clabby Right to Know Project 7960 S Tongass Ketchikan AK 99901

Betty Hedges Rockland County Conservation Assn PO Box 213 Pomona NY 10970

Elizabeth Henderson Rose Valley Farm PO Box 149 Rose NY 14542

Merrill Clark Roseland Organic Farms 27427 M-60 W Cassopolis MI 49031

Betty Fowler Safe Water Coalition of Washington W 5615 Lyons Ct Spokane WA 99208-3874

Sonja Puscatane Save Our Lake Environment PO Box 2090 Station A Jamestown NY 14701

Beth Gelber Scenic Hudson, Inc. 9 Vassar St. Poughkeepsie NY 12601

Carl Elliott Seattle Tilth Association 4649 Sunnyside Ave N, Rm 1 Seattle WA 98103

Jeffrey Hollender Seventh Generation, Inc. 1 Mill St, Ste A26 Burlington VT 05401-1531

Nancy Watson Dean Sierra Club, Rochester Regional Group PO Box 39516 Rochester NY 14604-9516

Robert Warrick Sierra Club Agriculture Committee RR 2 Box 11 Meadow Grove NE 68752-9701

Krista Rector Sierra Club Toxics 147 Healdsburg Avenue Cloverdale CA 95425-3601

Michael Seraphinoff South Whidbey Tilth 3830 S 530 E Greenbank WA 98253

Connie Tucker Southern Organizing Committee for Economic & Social Justice Po Box 10518 Atlanta GA 30310

Pat Wood Stop Polluting Orleans County PO Box 102 Fancher NY 14452

Rachel Humphrey Student Environmental Action Coalition at the Univ. of Delaware 301 Student Center Newark DE 19716

Joan-Therese Hudson Suffolk County Breast Health Partnership 395 Oser Avenue Hauppauge NY 11788

Robert Deering TeaPilz Inc Stevenson WA 98648

Luis Fernandez The Balanced Self Organization PO Box 30471 Alexandria VA 22310

Loni Kemp The Minnesota Project RR1, Box 81B Canton MN 55922

Jill Viehweg The Safer Pest Control Project 17 E Monroe, Suite 212 Chicago IL 60603

Jane Williams The Working Group on Carcinogens and Immune Suppressing Chemicals 3813 50th Street West Rosamond CA 93560

Tracy Katelman Trees Foundation PO Box 2202 Redway CA 95560

Schad Scheirman University of Chicago Environmental Center Club 5706 S University Ave #002A Chicago IL 60637

Sarah O'Brien Vermont Public Interest Research Group 64 Main Street Montpelier VT 05602-2951

George & Andra Rauh Volunteers for a Healthy Valley 951 San Pasqual Rd Lompoc CA 93436

Lee Bidgood Volusia-Flagler Environmental Action Committee, Inc 310 QUAY Assisi New Smyrna Beach FL 32169

David Mann Washington Environmental Council 1100 Second Avenue, Suite 102 Seattle WA 98101

Erika Schreder Washington Toxics Coalition 4516 University Way NE Seattle WA 98105

Ron Lambe Western North Carolina Alliance 70 Woodson Place, Suite 4C Asheville NC 28801

Don Francis Willamette Riverkeeper 5615 NE 10th Portland OR 97211

Ellen Drell Willits Environmental Center 316 S Main St Willits CA 95490-3906

Bill Wenzel Wisconsin Rural Development Center 125 Brookwood Drive Mount Horeb WI 53572

Peter Cervantes-Gautschi Workers Organizing Committee PO Box 12292 Portland OR 97212