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July 17, 2001

Robert F. Kusel
7654 Tripp Avenue
Skokie, IL 60076

Member of the Board of Education
East Prairie District #73
3907 Dobson Street
Skokie, IL 60076

Members of the Committee
Sub-Committee on Department Operations, Oversight, Nutrition and Forestry
Committee on Agriculture
U.S. House of Representatives

Dear Honorable Members of the Committee:

I write you today to urge your support for the School Environmental Protection Act, as contained in the Senate Education Bill. (Senate Amendment 805 to S1)

I do so in the spirit of protecting school children and staff from unnecessary risks related to exposure to pesticides. I am well aware that the members of the committee share my concerns regarding the health of our nation’s youth, and I simply wish to relate one school board member’s perspective on the proposed amendment.

The significant risks to children from pesticide exposure have been reported in many national publications. The following are just a sample:

Education Week: (GAO Finds Information Scant About School Pesticide Use)
“Exposure to pesticides can cause a range of harmful health effects, including cancer, impairment to the nervous system, lung damage, and reproductive dysfunction. Experts say that children are at greater risk from pesticide exposure than most adults.” (January 2000)

U.S. News & World Report: (Kids at Risk)
“A new study from the National Academy of Sciences suggests that a combination of neurotoxicants and genes may account for nearly 25 percent of developmental problems.”(June 2000)

Ladies Home Journal: (Dangers in the Schoolyard)
“Studies show that pesticides can harm children’s health, yet across the country, kids are being exposed to high levels of dangerous chemicals in school.” (May 2000)

Additionally, prominent national organizations have articulated their concerns regarding pesticide exposure in schools.

In 1992, the National PTA adopted a position statement regarding the use of pesticides in schools and day care centers that included the following language:

“ Americans use hundreds of millions of pounds of pesticides, herbicides (plant killers), and fungicides each year, for non-agricultural purposes, including in and around schools and child care centers. Pesticides are, by nature, poisons, and exposure – even at low levels – may cause serious health effects. Our nation’s children, because of a variety of age-related factors, are at increased risk of cancer, neuro-behavioral impairment and other health problems as a result of their exposure to pesticides. The National PTA is particularly concerned about the use of pesticides in and around schools and child care centers because children are there for much of their young lives.”

The National School Boards Association (NSBA) recognized those risks when it endorsed a report by a coalition of national leadership groups that named environmental risks as one of the “Ten Critical Threats Facing Children”. “Potentially dangerous pesticides” was one of the environmental risks mentioned in the report.

In November 1999, the U.S. General Accounting Office issued a report entitled, “Pesticides – Use, Effects, and Alternatives to Pesticides in Schools.”  The report included this statement:

“Because some of these symptoms are similar to those of other illnesses (such as the flu) the effects of pesticides can be misdiagnosed, which may mask the true extent of illnesses caused by pesticides. Long-term illnesses and those with delayed onsets, such as cancer, which may only appear years after exposure to pesticides, can also occur.”

U.S. Senator Joseph I. Lieberman has this to say regarding pesticide-related risks to children: “What we don’t know can indeed hurt us, and in fact, may be hurting us today because there is a lot that we don’t know.”

In light of the above references, one can only conclude that pesticides do indeed pose serious potential risk to children. As adults responsible for their safekeeping, we must ask ourselves, “ How we can minimize that risk?”.

The answer, in my opinion, is Integrated Pest Management (IPM). I’ll rely on the United States Environmental Protection Agency’s definition of IPM:

“IPM is an effective and environmentally-sensitive approach to pest management that relies on a combination of common sense practices. IPM programs use current, comprehensive information on the life cycles of pests and their interactions with the environment. This information, in combination with available pest control methods, is used to manage pest damage by the most economical means, and with the least possible hazard to people, property, and the environment. IPM programs take advantage of all pest management options possible, including the judicious use of pesticides.”

IPM is actually an elegantly simple systems strategy. It relies on a detailed inspection of the school building, with a focus on sanitation and structural practice. So, for example, in the event of a mouse infestation, one would look at areas of access and hiding (structure), availability of food and water (sanitation), and might use a wonderfully functional mousetrap instead of a rodenticide/poison to eradicate the pest.

The use of IPM in schools to reduce pesticide-related risks to children has been endorsed by national organizations with large constituencies. The following are representative:

• United States Environmental Protection Agency (USEPA)

• National Parent Teacher Association (PTA)

• National Education Association (NEA)

• Physicians for Social Responsibility (Winners of the 1985 Nobel Peace Prize)

The reality is that IPM has worked in schools across the country for almost a decade. I’ll be happy to provide, upon request, geographically diverse district representatives who will speak to the success of their IPM programs, and to their cost effectiveness.

Most schools utilizing IPM strategies tell us that IPM doesn’t cost more, it just costs differently. Thus, a school having a problem with mice might install door sweeps to deny access instead of continuously allocating funds for a pest control professional.

Additionally, an IPM program need not be burdensome with regard to personnel. Typically, it will require some light training, and it then integrates seamlessly into existing roles and responsibilities.

I therefore disagree with the notion that this amendment is an unfunded mandate. But, for the sake of argument, let’s assume that it is.

Do the critics of this amendment actually propose that we allow unsafe conditions to exist in a school simply because it might cost more to correct them? Would that same thinking apply to the dangers of asbestos, lead paint or faulty wiring?

I have been deeply involved in studying pesticide usage as it relates to children’s health   for the past five or six years, and I am convinced that IPM strategies result in cleaner, safer schools. The science is simply irrefutable, as is current practical experience.

If we can agree that pesticides pose significant risks to children, and that IPM is an appropriate and proven means of minimizing those risks, then perhaps we should ask ourselves the following logical question: How can we best insure that America’s schools utilize this strategy?

The answer is making IPM in schools the law of the land. Experience in Illinois and other states demonstrates this unfortunate reality. The Illinois legislature originally “encouraged” schools to utilize IPM concepts to protect children’s health. In spite of the law, a survey conducted several years after it was enacted revealed that only 17% of Illinois schools had any knowledge whatsoever about IPM.

If the risks to children weren’t so significant, we might further explore voluntary compliance.

But the risks are truly profound. One final excerpt regarding risks from a report entitled, “Neurotoxicity  - Identifying and Controlling Poisons of the Nervous System,” issued by the Office of Technology, U.S. Congress.

“In general, (human health) research demonstrates that pesticide poisoning can lead to poor performance on tests involving intellectual functioning, academic skills, abstraction, flexibility of thought and motor skills; memory disturbances and inability to focus attention; deficits in intelligence, reaction time, and manual dexterity; and reduced perceptual speed. Increased anxiety and emotional problems have also been reported.

Thus, the chilling possibility exists that the very school buildings where children go to learn may be stealing from them their ability to do so.

Even the potential that this could be occurring compels us to action.

The Rio Declaration from the 1992 United Nations Conference on the Environment and Development included the following as Principal #15:

“In order to protect the environment, the precautionary approach shall be widely applied by States (meaning nations in this context) according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”

Simply put, this can be extrapolated to the issue of pesticide risks as suggesting we must err on the side of caution. The children in our schools certainly deserve the benefit of the doubt regarding preventable causes of harm. This amendment grants it to them.

It will also allow for the registration and notification of interested parents and staff in the event of certain, but not all, pesticide applications. This will make critical information available, for example, to the parents of children with chemical sensitivities and to concerned members of the instructional staff, giving them the opportunity to make informed decisions.

Ultimately, this amendment builds in a layer of protection for our most vulnerable citizens. If it becomes law, we may never know the magnitude of the good that we have accomplished, or the damage that wasn’t done.

If the School Environmental Protection Act fails, however, the day may come when we realize that we missed a crucial opportunity to protect the children.

Thus, I urgently implore the Honorable Members of the Committee to support this critically important piece of legislation.

Sincerely,

Robert F. Kusel
Click here for Background information on Robert Kusel

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