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	<title>Comments on: Proposed Rulemaking in Maine Undermines Comprehensive School Pesticide Reform</title>
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	<link>http://www.beyondpesticides.org/dailynewsblog/?p=8210</link>
	<description>News on pesticide science, policy and activism</description>
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		<title>By: Beyond Pesticides</title>
		<link>http://www.beyondpesticides.org/dailynewsblog/?p=8210#comment-156700</link>
		<dc:creator>Beyond Pesticides</dc:creator>
		<pubDate>Tue, 02 Oct 2012 14:23:16 +0000</pubDate>
		<guid isPermaLink="false">http://www.beyondpesticides.org/dailynewsblog/?p=8210#comment-156700</guid>
		<description><![CDATA[Mr. Fish,

Thanks for reaching out on this. We are pleased that you and the state of Maine are working to protect children from toxic pesticide use. While we support attempts to clarify the interest in moving toward non-pesticide controls and your efforts in that regard, we would like to see a lot more clarity in the definition of IPM and less discretion given to applicators to make determinations on exposure and safety –areas that are outside their expertise, generally. Unless the regulations are clear about practices and allowed materials, including the prohibition of substances that are associated with adverse effects, unnecessary pesticide use may occur. In our experience, with sound pest prevention and exclusion techniques (caulking, doorsweeps, habitat modification, and cultural practices) and the use of biological management outdoors (attention to soil health, natural predators, and ecological balance), the use of toxic substances is not necessary and, in fact, less effective than the preventive approach. On behalf of Beyond Pesticides’ members in Maine, we look forward to working with you.]]></description>
		<content:encoded><![CDATA[<p>Mr. Fish,</p>
<p>Thanks for reaching out on this. We are pleased that you and the state of Maine are working to protect children from toxic pesticide use. While we support attempts to clarify the interest in moving toward non-pesticide controls and your efforts in that regard, we would like to see a lot more clarity in the definition of IPM and less discretion given to applicators to make determinations on exposure and safety –areas that are outside their expertise, generally. Unless the regulations are clear about practices and allowed materials, including the prohibition of substances that are associated with adverse effects, unnecessary pesticide use may occur. In our experience, with sound pest prevention and exclusion techniques (caulking, doorsweeps, habitat modification, and cultural practices) and the use of biological management outdoors (attention to soil health, natural predators, and ecological balance), the use of toxic substances is not necessary and, in fact, less effective than the preventive approach. On behalf of Beyond Pesticides’ members in Maine, we look forward to working with you.</p>
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		<title>By: Gary Fish</title>
		<link>http://www.beyondpesticides.org/dailynewsblog/?p=8210#comment-156541</link>
		<dc:creator>Gary Fish</dc:creator>
		<pubDate>Sat, 29 Sep 2012 03:08:39 +0000</pubDate>
		<guid isPermaLink="false">http://www.beyondpesticides.org/dailynewsblog/?p=8210#comment-156541</guid>
		<description><![CDATA[The introduction of the article says: 
 
” Unfortunately, new amendments to Maine’s school pesticide legislation make no mention of safer, preventive pest management practices, or the use of least-toxic pesticides only as a last resort, setting back efforts to reform pesticide legislation for schools in Maine. Should these new amendments be approved, students in Maine will not receive the same protections as students in other states that have been eliminating unnecessary pesticide use by adopting pest prevention practices and using least-toxic pesticides as the last resort.” 
 
But the existing Maine rules which are not part of the proposed changes in this latest notice of proposed rulemaking state:

“B. Prior to any pesticide application the following steps must be taken and recorded:

1. monitor for pest presence or conditions conducive to a pest outbreak,

2. identify the pest specifically,

3. determine that the pest population exceeds acceptable safety, economic or aesthetic threshold levels, and

4. utilize non-pesticide control measures that have been demonstrated to be practicable, effective and affordable.

C. When a pesticide application is deemed necessary, the applicator must comply with all the requirements of Chapter 31 – Certification and Licensing Provisions/Commercial Applicator. The applicator must also take into account the toxicity of recommended products and choose lowest risk products based on efficacy, the potential for exposure, the signal word on the pesticide label, the material safety data sheet, other toxicology data and any other label language indicating special problems such as toxicity to wildlife or likelihood of contaminating surface or ground water.”

And a new section of the proposed rule if adopted as written says, 

“All pest management activities shall be undertaken with the recognition that it is the policy of the State to work to find ways to use the minimum amount of pesticides needed to effectively control targeted pests in all areas of application. In addition, it is the Board’s policy that pesticide applications on school grounds, strictly for aesthetic purposes, should be avoided.

Seems like the existing and proposed law does all the things mentioned in the intro of the article?

We welcome all comments, but hope they will be based on the existing law and the changes shown in the notice of proposed rulemaking found at http://www.maine.gov/agriculture/pesticides/laws/documents/BPC_Chapter_27_8-7-12.pdf]]></description>
		<content:encoded><![CDATA[<p>The introduction of the article says: </p>
<p>” Unfortunately, new amendments to Maine’s school pesticide legislation make no mention of safer, preventive pest management practices, or the use of least-toxic pesticides only as a last resort, setting back efforts to reform pesticide legislation for schools in Maine. Should these new amendments be approved, students in Maine will not receive the same protections as students in other states that have been eliminating unnecessary pesticide use by adopting pest prevention practices and using least-toxic pesticides as the last resort.” </p>
<p>But the existing Maine rules which are not part of the proposed changes in this latest notice of proposed rulemaking state:</p>
<p>“B. Prior to any pesticide application the following steps must be taken and recorded:</p>
<p>1. monitor for pest presence or conditions conducive to a pest outbreak,</p>
<p>2. identify the pest specifically,</p>
<p>3. determine that the pest population exceeds acceptable safety, economic or aesthetic threshold levels, and</p>
<p>4. utilize non-pesticide control measures that have been demonstrated to be practicable, effective and affordable.</p>
<p>C. When a pesticide application is deemed necessary, the applicator must comply with all the requirements of Chapter 31 – Certification and Licensing Provisions/Commercial Applicator. The applicator must also take into account the toxicity of recommended products and choose lowest risk products based on efficacy, the potential for exposure, the signal word on the pesticide label, the material safety data sheet, other toxicology data and any other label language indicating special problems such as toxicity to wildlife or likelihood of contaminating surface or ground water.”</p>
<p>And a new section of the proposed rule if adopted as written says, </p>
<p>“All pest management activities shall be undertaken with the recognition that it is the policy of the State to work to find ways to use the minimum amount of pesticides needed to effectively control targeted pests in all areas of application. In addition, it is the Board’s policy that pesticide applications on school grounds, strictly for aesthetic purposes, should be avoided.</p>
<p>Seems like the existing and proposed law does all the things mentioned in the intro of the article?</p>
<p>We welcome all comments, but hope they will be based on the existing law and the changes shown in the notice of proposed rulemaking found at <a href="http://www.maine.gov/agriculture/pesticides/laws/documents/BPC_Chapter_27_8-7-12.pdf" rel="nofollow">http://www.maine.gov/agriculture/pesticides/laws/documents/BPC_Chapter_27_8-7-12.pdf</a></p>
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		<title>By: A Owens</title>
		<link>http://www.beyondpesticides.org/dailynewsblog/?p=8210#comment-156514</link>
		<dc:creator>A Owens</dc:creator>
		<pubDate>Fri, 28 Sep 2012 16:55:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.beyondpesticides.org/dailynewsblog/?p=8210#comment-156514</guid>
		<description><![CDATA[I know that synthetic pesticides administered on land and in buildings (and from planes) cannot be called “safe” by the manufacturers or the purveyors. Pesticides were created to kill bad bugs and “weeds” but there are consequences to health and the environment. Peoples’ health issues from Cancers to Endocrine Disruption and Asthma are being linked to pesticide exposures. Only small amounts can cause problems and over time, more exposures bio-accumulate in our bodies and in frogs, fishes, bats, bees, too. 

 
 
I am but a simple citizen who knows that she gets toxic symptoms from exposures to pesticides. I know a bit about them because I did my own research. The fact is, these chemicals were created for profit of big Chemical Industry without regard for human and animal and environmental health. These products were and continue to be, tested, by the manufacturers. When “tested” they are viewed separately and not together for their synergistic effect.
 
 
 
I ask you to please, be as prudent as possible wrt the use of synthetic pesticides which have been proven to be an ineffective long term solution to bugs and weeds. There are plenty of natural, SAFE alternative products. I enclose my blog which I put together as an educational piece on the topic.
 
 
 
Thank you for listening.
 
 
 
I live in New Hampshire and we are moving towards legislation to eliminate Pesticides and Synthetic Fertilizers off school grounds, playing fields and parks, following the excellent examples of New York State, New Jersey and Connecticut. Massachusetts is going to have such legislation soon, as well.
 
 
 
Sincerely,
 
 
 
Alyssa Owens,  Blog: http://backtoclover.blogspot.com.]]></description>
		<content:encoded><![CDATA[<p>I know that synthetic pesticides administered on land and in buildings (and from planes) cannot be called “safe” by the manufacturers or the purveyors. Pesticides were created to kill bad bugs and “weeds” but there are consequences to health and the environment. Peoples’ health issues from Cancers to Endocrine Disruption and Asthma are being linked to pesticide exposures. Only small amounts can cause problems and over time, more exposures bio-accumulate in our bodies and in frogs, fishes, bats, bees, too. </p>
<p>I am but a simple citizen who knows that she gets toxic symptoms from exposures to pesticides. I know a bit about them because I did my own research. The fact is, these chemicals were created for profit of big Chemical Industry without regard for human and animal and environmental health. These products were and continue to be, tested, by the manufacturers. When “tested” they are viewed separately and not together for their synergistic effect.</p>
<p>I ask you to please, be as prudent as possible wrt the use of synthetic pesticides which have been proven to be an ineffective long term solution to bugs and weeds. There are plenty of natural, SAFE alternative products. I enclose my blog which I put together as an educational piece on the topic.</p>
<p>Thank you for listening.</p>
<p>I live in New Hampshire and we are moving towards legislation to eliminate Pesticides and Synthetic Fertilizers off school grounds, playing fields and parks, following the excellent examples of New York State, New Jersey and Connecticut. Massachusetts is going to have such legislation soon, as well.</p>
<p>Sincerely,</p>
<p>Alyssa Owens,  Blog: <a href="http://backtoclover.blogspot.com" rel="nofollow">http://backtoclover.blogspot.com</a>.</p>
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