(Lighting the way to Less Toxic Living)


P.O. Box 40441, Providence, RI 02940

Tel. 401-351-9193, E-Mail: 






SAFETY ISSUES:  Surveys show most people assume that if a product is allowed to be sold, it is safe.  Unfortunately, that’s not true.  In fact, the EPA has made it clear that no pesticide can legitimately be described as safe, and penalties have been assessed on companies making such false claims.  Dow Chemical, was fined $2 million dollars for persisting in such dishonest corporate behavior even after being reprimanded by NY State Attorney General Spitzer.  Secondly, the reason EPA does not permit such claims is that no research can truly support the claim that any registered pesticide will do no harm, because:


1.      Toxicity is the reason that the product needs to be registered.

2.      Testing is limited to single chemicals, yet exposure is always to combinations.

3.      It has been shown that interaction between chemicals may product different or greater reactions and health effects that one lone ingredient.

4.      Many problems caused by pesticides are chronic conditions that do not become apparent for years after the first exposure.

5.      Many problems are associated with low level exposure over time, yet testing is usually done with acute doses and short time frames.

6.      Most testing is done by the companies themselves, who stand to make billions of dollars by selling the product when approved.  Clouds of questions about such studies have arisen, including claims of pressure on researchers to suppress or alter findings.  It certainly seems a “conflict of interest” and “fox guarding the henhouse” situation.


EFFICACY OF REGULATION:  The federal government’s record of protecting the public from toxic pesticides is a dismal pattern of failure.  Over and over again, products are thrown onto the market, only to be withdrawn, many years later, when evidence of their deadly effects cannot be ignored.  This happened, most famously, with DDT, originally advertised as so safe you could bathe in it.  Sometimes, as older pesticides are phased out because of toxicity, their replacements are ultimately found to be just as toxic.  This was so with chlorpyrifos [Dursban], an organophosphate that became popular as chlordane was phased out.  Once widely used as a pesticide in household and professional applications, chlorpyrifos was found to accumulate heavily on surfaces long after it was applied, and complaints of health effects included headaches, dizziness, muscle twitching, vomiting, blurred vision, and other problems.  The product was withdrawn for residential uses by 2000, but is still on some store shelves, and remaining supplies are still being used.  In short, the real “testing” of these products is on the American public. 


Protection at the state level has its own problems.  Especially in these times of reduced state budgets, it is difficult to find the money to allow RI DEM to effectively monitor or police pesticide use, much less engage in or fund the extended studies that might produce significant health data.  Moreover, to be valid, such research would need to take many years.  Even if state lawmakers pass strong protective legislation, follow-up is challenging. One difficulty with provisions requiring use of Integrated Pest Management (IPM) for example, is the wide range of choice permitted by that concept – and differing interpretations of what it means.  Too often, the lawn care company or even the individual pest control operator makes that choice – and may decide that the accustomed pesticide application practices are the “least toxic” because that is the easiest thing to do. 


OTHER CONSIDERATIONS:  It is common to make decisions based on a “risk-benefit ratio” model.  Because absolute “proof” of causation in many cases is difficult to produce, the chemical companies claim we should not remove their products from consumer use.  I urge you to think carefully about what, in this case, “benefit” and “risk” really entail.  The benefit?  Sometimes a beautiful green field of grass.  This is not even assured – the efficacy of repeated pesticide applications is questionable.  There are problems with developed resistance, the need to apply more product to get results.  Also, broad spectrum pesticides kill off natural lawn care helpers, such as ladybugs and worms.  Even a High School student in this year’s RI Science Fair demonstrated this principle – by a project showing how insecticide killed beneficial fungi that could have been working to keep the lawn healthy.  Ask yourself, also – haven’t you ever seen a gorgeous grassy field that did not have the “benefit” of pesticides?  Of course you have. 

Moreover, the question must be asked – how important is it that the field be “perfect”?  Kids play in many places on fields without chemicals or even much care.  They still have fun, the game goes on.  The chemical mavens suggest, in desperation it would seem, that the young people might trip on the deadly crabgrass and fall down!  The truth is, kids do fall down sometimes no matter how even the grassy surface, skin their knees, come home covered with dirt or even mud from an imperfect spot on the field.  You give them a bandaid for the knee, throw the kid in the shower and their clothes in the washer. 


On the other hand, what are the risks of allowing children to roll around on fields doused with poison?  A team of medical researchers with the Ontario College of Family Physicians, a Canadian professional society for family doctors, released a report last year that analyzed 250 previously published epidemiological studies from around the world on possible adverse effects of pesticides on human health.  The report found "consistent positive associations" between popular pesticides used in lawn care and cancers, reproductive problems, neurotoxic effects and other serious illnesses.  This is just one of many studies linking pesticide exposure to health effects, especially in children.  Children face unique hazards from pesticide exposure. They take in more pesticides relative to their body weight than adults in the food they eat and air they breathe.  Their developing organ systems often make them more sensitive to toxic exposure.  The U.S. EPA, National Academy of Sciences, and American Public Health Association, among others, have voiced concerns about the danger that pesticides pose to children. The body of evidence in scientific literature shows that pesticide exposure can adversely affect a child's neurological, respiratory, immune, and endocrine system, even at low levels.  Some pesticides, such as pyrethrins and pyrethroids, organophosphates and carbamates, are also known to cause or exacerbate asthma symptoms.


The organization Beyond Pesticides has begun compilation of a list of pesticide incidents at schools (40 when I last looked) that involved damage to the health of both students and school staffers.  See their website at: for details.  I have personally heard the stories of numbers of people who have suffered from pesticide exposure at school and elsewhere.  About a year ago, a group of children on a soccer field in Georgia were sickened by lawn pesticide spraying, and two were taken to the hospital in anaphylactic shock.  I just learned from a contact there that now two children in that soccer league have Non-Hodgins lymphoma, an uncommon cancer in youngsters that has been linked to pesticides.  How in the world can the perils of a few weeds be compared to the risk of seeing a child gasping for breath with an asthmatic attack, suffering neurological damage, perhaps autism or ADHD, childhood leukemia or other cancer?  (Understand clearly that this bill does NOT have any prohibition vs. pesticide use for the purpose of protecting human health, such as pest control vs. mosquitoes, ticks or wasps.)



I suggest to you that this is that rare opportunity to achieve a win-win resolution for everyone concerned.  Rhode Island, and its lawn care professionals, can, through this legislation and the switch to organic lawn maintenance, become a model for others.  No work will be lost – it will just be less toxic work!  Pest control applicators are actually a high-risk group themselves for cancer and other health problems.  This change could save the life and health of some of the very people opposing the legislation!  Parents and children around the state can rest easy knowing that they can happily play in any park or athletic field without exposure to poisons.  Moreover, the cost is likely, especially over a few years, to be comparable to or even less than toxic methods.  One school district reduced its pesticide use by 90 per cent and its budget dropped 40 per cent in the process!  We don’t need to wait for a certainty of harm that is unlikely to be found.  We don’t need to continue allowing those who profit from pesticide sales to use us and our children as guinea pigs.  Which of today’s “safer” formulations will be pulled off the market in 10, 20 or 30 years after ruining the health of hundreds of youngsters?  The Precautionary Principle is anathema to the chemical industry – because it says that avoiding harm to people is more important than providing profit to them.  It says if we don’t have all the facts, we should err on the side of protecting precious human life.


In this case, the alternative is a happy one.  With good care and the correct species of plants, we can do it just fine without the risk.  Moreover, there are many resources available to help those who need or want to get off the drugs.  Our organization already has some good information on our website, and is compiling a Less Toxic Landscaping Resource Guide for Rhode Islanders to lead them to information, services and supplies.  We stand ready to try to track down the answers to any questions or problems that may arise in making the change to healthier lawn care, for schools, towns or individual homeowners.


Respectfully Submitted,

Liberty Goodwin, Director

Toxics Information Project (TIP)




(Lighting the way to Less Toxic Living)

Liberty Goodwin, Director

P.O. Box 40441, Providence, RI 02940

Tel. 401-351-9193, E-Mail:





It has been suggested to us that the term “lawn pesticides” in this bill is too vague, and could result in the exclusion of some benign, non-toxic pest control options.  Therefore, we offer the following suggestions on defining what we are proposing to ban, and what would be allowed under the legislation.



(All products should have all “inerts” non-toxic and disclosed.)


(1)  Insecticidal Soaps

Exception:  Insecticidal soap products containing pyrethrin, a restricted material.

(2)  Herbicidal soaps or fatty acids:  Herbicides, animal-derived .

Exception:  Synthetically processed.

(3)  Bt (Bacillus thuringiensis)

Exception:  Bt products developed using genetic engineering, or with prohibited inerts.

(4)  Nematodes & other biological control organisms:  Arthropod parasitoids, arthropod (insect, spider, and mite) predators & parasites.

 (5)  Dormant oils - Vegetable based oils are allowed.

Exception:  Petroleum based oils are prohibited.

(6)  Pheromone traps

(7)  Acetic Acid/Vinegar

Exception:   If prepared by synthetic processes, or containing prohibited wetting agents.

(8)  Diatomaceous Earth

(9)  Biological, living control agents.

(10) Botanical Insecticides.  (But not pyrethrin)

(11) Corn gluten.

(12) “Certified Poison Free”, with Scientific Certification Systems (SCS) logo on the label.

(13) Products without an EPA Pesticide Registration number.

(14) Products without “warning”, “caution” or “danger” on the label.

(15) Products with “Minimal Risk Product EPA exempted under FIFRA Section 25 (b)* on the label.




(Adapted from California's Healthy Schools Act of 2003, AB 1006)


(1) Those with the highest acute toxicity as defined by EPA Toxicity Categories I and II;
(2) Containing N-methyl-carbamate, neurotoxic organophosophorus compounds, or pyrethoids;
(3) Containing active ingredients rated by EPA as known, probable or possible human carcinogens.

(4) Containing active ingredients that cause birth defects, reproductive harm, or developmental

harm as identified by EPA.  (Mutagens, teratogens, reproductive toxins, developmental neurotoxins, endocrine disrupters or immune system toxins.)




Allow use of only those products permitted under Organic Farming regulations.


Include in the bill at this time only the four prohibitions listed above.