2014 Commercial PAT Meeting Cary Giguere What happened? • A licensed pesticide applicator used an illegal pesticide indoors to treat for bed bugs and other pests. Pesticide Exposure in Vermont: Chlorpyrifos misuse Vermont Department of Health Timeline of events • April 29, 2013: Licensed applicator (AAA) treated a home for bed bugs. • May 6, 2013: Owners complained of odor, called the Agency of Agriculture. • May 8, 2013: Agency tested for pyrethroids based on receipts but saw additional unidentified peaks (swab samples). • May 23, 3013: Inspection of storage site finds chlorpyrifos (CPS). Invoices collected. • May 28, 2013: Preliminary qualitative results indicate CPS was used. • June 10, 2013: Quantitative results confirm CPS in residence. Invoices reviewed. • VAAFM and VDH responded with an investigation to identify affected residences and suggested that some residents relocate until the residences can be cleaned (ongoing). Vermont Department of Health Timeline of events… • Week of June 24, 2013: sampling initiated at 10 properties treated by AAA for bed bugs. Develop action levels. • Week of July 1, 2013: two residence test positive for CPS. Action levels reviewed by ATSDR and OPP. VDH coordinates with Red Cross on shelter options. • Week of July 8, 2013: Letters sent to all bed bug jobs since January 2012. VDH opens HOC, and issues press release. Coordinates with 211 and NNEPC. HAN sent to Rutland HCP. • Weeks of July 15 and 31: 20/61 bed bug jobs positive for CPS. Two non-bed bug (NBB) jobs positive (2009 spray date). Request to EPA for assistance in characterization and clean up. 1 2014 Commercial PAT Meeting Cary Giguere Timeline of events, • Week of August 5, 2013: Letters sent to 150 customers of AAA from 2012 and 2013 (NBB jobs). Sampling from the 150 jobs begins. (POM and AAPCO- Pollinator Protection Language) • Week of August 16, 2013: EPA visits, joint sampling strategy developed for 2009- 2011 jobs. • Week of August 23, 2013: Letters sent to 51 bed bug and NBB jobs from 2009-2011. Clean-up procedures tested by contractor. • Week of September 9 2013: EPA Emergency Response (Region 1) arrives to assist in sampling and analyzing AAA jobs from 2009-2011. Chlorpyrifos (CPS) • An organophosphate (OP) insecticide • Registration for indoor use cancelled by EPA in 2001 o Toxicity factors became more stringent o “Risk cup” became full due to dietary contribution Classical symptoms of AChE inhibition • SLUDGE: o o o o o o Vermont Department of Health Biological monitoring • Urine TCP (trichloropyridinol): o TCP is a specific metabolite of CPS o Urine TCP reflects exposure in the past 2-4 days o Most people have TCP in urine due to dietary exposure • Blood ChE: o Blood ChE depression most reflective of exposure within hours or days o Results are difficult to interpret without a baseline Salivation Lacrimation Urination Defecation GI distress Emesis Vermont Department of Health Health Alert Network (HAN) • July 9, 2013: Sent a Health Advisory to Rutland County health care providers • HAN alerted health care providers to CPS contamination of residences, health effects, and contacts at the Health Department • https://han.vermont.go v Vermont Department of Health 2 2014 Commercial PAT Meeting Cary Giguere VT- Health Effects Reported • Residents were contacted when results became available. Health questionnaire given via phone.. • Self-reported health symptoms include: o Headache, nausea, vomiting, diarrhea, leg cramps, increased urination, excessive sweating, excessive salivation, lacrimation, runny nose, difficulty breathing, depression, and chest tightness • Residents were encouraged to follow up with physician for reported symptoms. • VDH staff followed up with physicians of several people. CPS and chronic health effects • Prenatal CPS exposure associated with various adverse neurodevelopmental outcomes in children • Centers for Children’s Environmental Health o EPA/NIEHS funded o 14 current centers o CPS, and all OPs • Pubmed search for “CPS, neurotoxicity”: 182 results • Concerned about re-habitation by sensitive groups (pregnant women most vulnerable) Sampling Procedure  Measured CPS in cord blood plasma to estimate prenatal CPS exposure  Measured 7 year neurodevelopment using Wechsler Intelligence Scale for Children  For each SD increase in CPS exposure:  IQ decreased 1.4%  Working Memory decreased 2.8%  Evidence suggests neurodevelopmental delays due to prenatal CPS exposure • Sample 2-7 sites per residence • Prioritize residences based on indoor pest jobs, bed bug jobs, guarantees on the invoice, multiple application methods • Agency of Agriculture Inspector and Public Health Nurse from Rutland DO • Samples analyzed by the Agency of Agriculture laboratory. o VDH and EPA laboratories as back-up Derivation of Screening Values Sampling Residences • • Derived by VDH and reviewed by EPA OPP, ATSDR Exposure x Toxicity = Risk • Significant challenge to get from wipe sample to exposure estimate o o Exposure: 2011 EPA OPP SOP pesticide Toxicity: Oral reference dose (RfD) with FQPA UF Level (ug/cm2) Description Reference Dose FQPA factor 4 x 10-2 Acute 0.003 mg/kg/day 1 4 x 10-3 Acute, sensitive 0.003 mg/kg/day 10 4 x 10-4 Chronic, sensitive 0.0003 mg/kg/day 10 3 2014 Commercial PAT Meeting Cary Giguere Derivation of Action Levels Detections to date (current as of 4/1/2014) • VDH recommended that some residents relocate until residence could be cleaned • Coordination with Rutland District Office, Department of Children and Families, Department of Environmental Conservation Range (ug/cm2) Action recommended category > 4 x 10-2 or Relocate within two days D > 4 x 10-3 and < 4 x 10-2 Relocate within one week C > 4 x 10-4 and < 4 x 10-3 Relocate sensitive populations B < 4 x 10-4 No action A New Pollinator Protection Language Cary Giguere Vermont Agency of Agriculture Background - Dinotefuran • Two incidents involving dinotefuran, the active ingredient in Valent/Safari occurred within a two week period in June 2013. Pollinator Week in the U.S. • Both incidents involved the death of a large number of bumble bees and linden trees (Tilia cordata). • Most bees were Bombus vosnesenskii. Some researchers estimate the number of bees impacted to be 59,000. • The two incidents involved different timing, and application methods (broadcast, drench and basal bark application). Wilsonville Incident  55 Linden trees were treated.  Trees were approx. 25-30 ft tall. • Applicators originally came to the site to treat other plant species for black vine weevils. But then noticed aphids on the linden trees. • Linden trees were in bloom. Allegedly bees were not present at the time of application. • Foliar (primarily) and soil drench applications were made early in the morning in June (approx. 6:30 a.m.). Shoppers at Target store started to complain - dead and dying bees were falling on their cars. 4 2014 Commercial PAT Meeting Cary Giguere Foliar Application Rate • Label allows for foliar application 4-8 oz. per 100 gallons of water. • Application rate - 6 oz. per 100 gallons Dead Bumble Bees were swept up frequently over a period of several days by the retail store. Customers and other community members were concerned by the number of dying and dead bees. Note - A few trees that had cars parked nearby received a soil drench application. According to reports, “still living bees were acting like they were drugged, spinning on the asphalt while others clung and buzzed crazily among the flowers.” Community members held a funeral. 5 2014 Commercial PAT Meeting Cary Giguere Interpretation: Once More.. With Feeling. • “Do not apply (insert name of product) while bees are foraging. Do not apply (insert name of product) to plants that are flowering. Only apply after flower petals have fallen off.” • The term "bee(s)", refers only to honey bees, bumble bees and carpenter bees and does not include wasps, Africanized honey bees or other types of feral bees. EPA has been asked what “bee” species are intended to be protected by the pollinator protection language and if Wasp, Africanized honey bee and other types of feral bee control applications are exempt from the Pollinator Protections. Interpretation: Interpretation: • The Pollinator Protection Label language only prohibits foliar applications to flowering plants (i.e. application to leaves and/or flowers, while the plant is flowering), but would not prohibit the application of the product to the trunk and/or bark of the plant. . • For non-agricultural uses such as residential lawns, perimeter treatments around structures, termite control, etc.; the language ‘do not apply while bees are foraging’ only prohibits applications to plants on which bees are actually foraging at the time of the application. It does not apply when bees are foraging on plants adjacent to areas being treated (e.g.: turf, structure or foundation areas), in other areas of the property or in abutting residential areas. The Pollinator Protection Label language only prohibits foliar applications to flowering plants. Interpretation: • The language ‘after all petals have fallen off’ allows application pre-bloom and after flowering has completed to the extent that bees are no longer foraging on the plants to be treated. Persistent Herbicides (1) • Picloram Dow AgroSciences 1963 • Clopyralid Dow AgroSciences 1978 • Aminopyralid • Aminocyclopyrachlor DowAgroSciences 2005 DuPont 2010 Vermont Organics Recycling Summit March 28, 2013 6 2014 Commercial PAT Meeting Cary Giguere Persistent Herbicides (2) • Pyridine based carboxylic acid compounds • Act as synthetic auxins or growth regulating hormones • Initial applications are effective at killing or repressing broadleaf plants for an entire growing season or beyond • Can pass through mammals into manure and urine unscathed after treated grasses are eaten Persistent Herbicides (3) • In low part per billion range, they can have a significant impact on garden plants such as beans, peas, tomatoes and many common flowers • Symptoms include poor seed germination, twisted and stunted stems, curled leaves, reduced and miss-shaped fruit • Can survive the heated and prolonged compost process intact Vermont Organics Recycling Summit March 28, 2013 Vermont Organics Recycling Summit March 28, 2013 Persistent Herbicides Officially Reported Impact Threshold in Compost • • • • Vermont Organics Recycling Summit March 28, 2013 Challenge # 1 Picloram 5 parts per billion (ppb) Clopyralid 10 ppb Aminopyralid 1 ppb Aminocyclopyrachlor In development Vermont Organics Recycling Summit March 28, 2013 Conclusions: • Aminopyralid has caused the majority of problems with CSWD compost products in 2012. The damage is acute 1. Continued use of growth trials* 2. Better access to chemical testing 3. More effective regulatory oversight 4. Elimination of problem feedstocksa.Horse manure and bedding b. Segregation of grass clippings Vermont Organics Recycling Summit March 28, 2013 • Clopyralid may have caused some damage in CSWD compost products. The damage appears to be chronic Vermont Organics Recycling Summit March 28, 2013 7