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From September 14, 2006                                                                                                        

Tell EPA to Provide Health Warnings on Pesticide-Impregnated Clothing
(Beyond Pesticides, September 14, 2006)
Buzz Off™ Insect Shield Insect Repellent clothing, a line of clothing that has been impregnated with the insecticide permethrin to ward against mosquitoes, is being sold in stores across the country without traditional pesticide labels that warn against possible exposure and contamination routes and provide first aid information. EPA has completed its Reregistration Eligibility Decision (RED) for permethrin, which has an open public comment period until September 26, 2006. Environmentalists are asking the public to ask the agency for full labeling as part of the RED.

In addition, Beyond Pesticides is encouraging consumers to write to companies selling Buzz Off apparel and asking them to stop exposing the public to dangerous chemicals that are known to leach from their clothing. The following is a partial list of companies, telephone numbers and customer service links for brands and retailers selling Buzz Off™ Insect Shield Insect Repellent clothing: (Brands) Georgia Workwear, 877-795-2410, info@georgiaboot.com; Oxford Golf, 866-727-4693, info@oxfordgolf.com; Stearns Inc., 800-333-1179, stearns@stearnsnet.com; Orvis, 800-635-7635, customer_service@orvis.com; Gold Toe, 866-714-8486, www.goldtoe.com/contact.shtml; Shakespeare, 800-845-2110, sales@yardgear.com; Ex Officio, 800-644-7303, info@exofficio.com; Tommy Hilfiger Golf, 1-800-445-3443, THG@oxfordgolf.com; Rocky Outdoor Gear, 740-753-1951, www.rockyboots.com; L.L.Bean, 800-809-7057, www.llbean.com/customerService/contactUs/contactUsEmail.html; Imperial Headwear, 800-950-1916, www.imperialforyou.com/contactus.html; MUMZ, 800-995-6869, info@mumzgarden.com; Liz Claiborne Golf, 866-549-7467. (Retailers) Macy’s, 1-800-289-6229, www1.macys.com/service/contact.jsp; REI, 1-800-426-4840, www.rei.com/shared/help/feedback/servicefb.html; EMS, 888-463-6367, customerservice@ems.com; Talbots, 800-825-2687, Customer.service@talbots.com.

Buzz Off states that its clothing is effective for 25 washings, and that the clothing should be washed separately. This indicates that the chemical comes off in water. Research has shown that some permethrin from impregnated clothes comes off onto the skin, and a portion of that is absorbed into the body. If a person is sweating or swimming while wearing the clothing, more of the chemical will likely come off onto the skin. The longer one wears the clothes, the more permethrin will be absorbed into the body. But the label does not caution against wearing the clothing while in water nor does it warn against prolonged exposure to the clothes. Although the acute toxicity of permethrin is fairly low, there are some serious long-term health problems associated with this pesticide.

Permethrin is a possible carcinogen and a suspected endocrine disruptor. Endocrine disruptors interfere with normal hormone function and can contribute to breast and testicular cancer, birth defects, learning disorders, and other problems. Animal studies indicate that small amounts of permethrin may cause immunotoxicity, or corruption of the immune system. Exposure to sunlight may worsen this response, according to the research of Virginia Tech Professor Steven D. Holladay, Ph.D., and colleagues. Although Holladay's research is based on higher doses than that found in the clothing, he points out the need for studies that examine immunotoxicity at comparable doses to the clothing. "Nobody really knows at this point the risk that the clothes pose," he explained.

A major concern with this clothing is the potential for people to receive combined exposures to a mix of pesticides. The clothing label advises that people should use the clothing "in conjunction with an insect repellent registered for direct application to skin," and at least one of the manufacturers suggests that the clothes be used specifically with DEET. According to EPA, approximately one-third of the U.S. population uses DEET every year. Use of DEET in combination with permethrin likely facilitates enhanced dermal absorption of permethrin - meaning more permethrin could be absorbed into the bloodstream than EPA has taken into account. Additionally, when registering active ingredients, EPA does not consider the synergistic effects of the active ingredient with other chemicals.

Several studies done by a team of Duke University researchers lead by pharmacologist Mohammed Abou-Donia suggest that DEET in conjunction with permethrin-impregnated clothing may be linked to Gulf War Syndrome. The symptoms, which affect thousands of veterans from the first Persian Gulf War, include headaches, fatigue, loss of memory, and chronic muscle and joint pain. The researchers exposed animals to the same doses of DEET and permethrin experienced by the war veterans using the same routes of exposure and found neurological damage that lead to motor deficits and learning and memory dysfunction, like the damage characterized by Gulf War Syndrome. (See a review of the study)

According to Dr. Abou-Donia, there are three main problems with these clothes (and their inadequate labels): Prolonged exposure to permethrin, combined exposure to permethrin and DEET, and increased sensitivity of certain segments of the population - particularly the elderly, pregnant women, and young children. He explained that even though the clothes might not pose that much risk to the average person, certain populations are more at risk.

Another danger that these clothes pose is that of environmental contamination. Although the label states that the clothing should not be stored or disposed of in water, it does not warn against washing or wearing the clothes in bodies of water, such as while swimming, camping, or washing in streams, lakes or other water bodies. Permethrin is well known for its high toxicity to fish and other aquatic organisms, in notably small doses. A University of California Berkeley study also found that low doses of synthetic pyrethroids are accumulating in creek sediments in levels toxic to freshwater bottom dwellers, which could have an adverse affect on a water body's entire ecosystem.

Additionally, pesticide impregnated clothing is only one of permethrin's many registered uses. Permethrin is registered for use on/in numerous food/feed crops, livestock and livestock housing, modes of transportation, structures, buildings (including food handling establishments), mosquito abatement programs, and numerous residential use sites including use in outdoor and indoor spaces, pets, and clothing (ready to use formulations in addition to impregnated).

TAKE ACTION! It is key that people make themselves heard by sending in comments to EPA during the public comment period, which ends September 26, 2006. Tell EPA that the permethrin RED does not go far enough in providing adequate protection to children and the public. Use the following talking points to draft your comments:

1. EPA does not have adequate data to eliminate the 10X FQPA safety factor.
EPA has reduced the 10X safety factor to 1X for permethrin. However, EPA does not have adequate data to abandon the 10X safety factor assigned by the Food Quality Protection Act (FQPA) to protect infants and children. Congress overwhelmingly passed FQPA to address, among other concerns, the particular hazards faced by children from exposure to pesticides. Children’s bodies do not respond in the same manner as adults. In the case of permethrin, many levels of concern have already exceeded or are close to being exceeded for various exposure scenarios for both adults and children. If EPA would retain the 10X safety factor, most uses would have to be cancelled or severely restricted.

2. EPA does not adequately take into account risks from permethrin-impregnated clothing. Based on comments sent to the Agency about permethrin-impregnated clothing losing efficacy after washing, EPA “is requiring product specific efficacy data for all permethrin impregnated fabric products, and wash-off data to support the efficacy claims.” However, EPA ignores numerous comments about the underestimated risks of permethrin-impregnated clothing. In the RED, EPA uses a generic model that considers the clothing residue concentration, surface area of the skin that is in contact with the fabric, the transfer factor, and body weight to assess exposure risk. Actual exposure may be much greater, however, because real world conditions, such as rainy weather, sweating and other factors, could increase the transfer factor. Despite acknowledging that permethrin-impregnated clothing are a source of dermal and oral exposure to permethrin, EPA does not require health warnings to be put on the clothing label, nor does the label caution against improper uses, such as prolonged exposure to the clothes. Additionally, the label of Buzz Off clothing recommends to “use in conjunction with an insect repellent..." However, use of permethrin-impregnated clothing in conjunction with DEET, one of the most commonly used insect repellents, creates numerous health problems, yet this aggregate risk is not taken into account in the RED.

3. EPA does not take into account the possible endocrine-disrupting effects of permethrin. The RED states, “In the available toxicity studies on permethrin, there was no toxicologically significant evidence [of] endocrine disruptor effects.” However, permethrin was classified as a suspected endocrine disruptor at the 1997 Illinois EPA Endocrine Disruptors Strategy Meeting. Permethrin binds to receptors for androgen (a male sex hormone) and testosterone in cells from human males. In a long-term feeding study of mice, permethrin was shown to cause reduced testes weights. In another study, researchers found that permethrin had significant estrogenic potency as it inhibited the binding of estradiol to the estrogen receptor.

4. Synergistic effects between common pesticide exposure combinations must be considered. EPA does not take into account synergistic effects with other chemicals when registering pesticides. However, studies show that many pesticides have dangerous synergistic effects when exposure is combined with other pesticides and pharmaceuticals, including permethrin combined with DEET. Because of the threat of West Nile virus and other mosquito-borne illnesses, DEET use is recommended by the Centers for Disease Control and Prevention (CDC), and many individuals wear DEET while outside during mosquito season. Permethrin is widely used by communities for mosquito control, as well as on lawns and gardens, in clothing and for a myriad of other uses discussed in the RED. Therefore, the combined exposure to both DEET and permethrin is likely. According to the literature, the use of DEET in combination with permethrin likely facilitates enhanced dermal absorption of permethrin. Additionally, studies done by Duke University researcher Mohammed Abou-Donia suggest that DEET in conjunction with permethrin may be linked to the Gulf War Syndrome, which affects thousands of veterans. However, the RED takes into account only permethrin use, which is not a realistic exposure scenario.

5. EPA fails to consider the health and ecological impacts of permethrin formulated with piperonyl butoxide (PBO). Permethrin is commonly formulated with the synergist piperonyl butoxide (PBO), which is added to increase the potency of the permethrin product. Because of the frequency with which these chemicals are formulated together, EPA should evaluate the combined impact for all health and ecological endpoints. PBO inhibits important liver enzymes responsible for the breakdown of some toxics, including the active ingredients of pesticides. In addition to its effects on humans, the impact of permethrin combined with PBO to aquatic organisms must be considered.

6. Permethrin is highly toxic to bees and other beneficial insects. The RED states that permethrin is highly toxic to bees and other beneficial insects. The continued use of permethrin is likely to reduce and eliminate important insect populations. Pollinators provide an essential ecological function in both agricultural and wildland ecosystems. Protection of pollinators should be of the highest priority, as without them crops would not produce harvests and wild plant communities would decline.

7. EPA does not adequately mitigate the effect of permethrin on asthmatics. In the RED, EPA states, “Although it is a relatively safe product, it can aggravate asthma or lead to asthma like symptoms.” Asthma rates in the U.S. have reached epidemic levels, particular in young children, who are most vulnerable. Nearly 1 in 8 school-aged children have asthma, and the rate is rising. Synthetic pyrethroids have been shown to be respiratory allergens and the use of them may result in asthma-like symptoms, especially in children with a history of asthma or allergies. Numerous cases of people exposed to synthetic pyrethroids have reported symptoms of irritation of the throat and respiratory tract, shortness of breath, coughing, and other asthmatic symptoms. Despite acknowledging the potential impact of permethrin on asthmatics and describing incidents involving asthma and permethrin, EPA fails to take into account the special vulnerability of asthmatics in its analysis.

Submit your comments, identified by docket identification (ID) number EPA-HQ-OPP-2004-0385, by one of the following methods:
Electronically: Federal eRulemaking Portal (http://www.regulations.gov) Follow the on-line instructions for submitting comments.
Mail: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW. Washington, DC 20460-0001.
Delivery: OPP Regulatory Public Docket (7502P), Environmental Protection Agency, Rm. S-4400, One Potomac Yard (South Building), 2777 S. Crystal Drive, Arlington, VA. The Docket telephone number is (703) 305-5805.

EPA's policy is that all comments received will be included in the docket without change and may be made available on-line at http://www.regulations.gov.