We have reminded Commissioner Hidalgo in our letters that Ag Commissioners can restrict pesticide use that “will present an undue hazard when used under local conditions” (The Food & Agricultural Code 14006.6(a)). An undue hazard is an excessive or disproportionate hazard. We have given the Commissioner the following examples with requests for actions:

1. Brain-harming Dacthal: The US EPA says it is 1,500 times more damaging to fetuses than we knew, and the reentry-interval into fields should be a month rather than 12 hours. Half of all Dacthal use in California is in Monterey County. That is certainly an undue disproportionate hazard, so we are calling on the Ag Commissioner to restrict Dacthal with:

a) 48-hour Notice of Intent requirements on growers/applicators;
b) 1-mile buffer zones around schools, residences, field crews, and other sensitive sites; and
c) 30-day field reentry intervals.

2. Cancer-causing 1,3-D aka Telone: The air monitor at Ohlone Elementary School has measured levels of 1,3-D more than twice the lifetime cancer risk warning level (established by the Office of Environmental Health Hazard Assessment in 2022) over the span of 11 years of testing. At an elementary school. That is certainly an undue excessive and disproportionate (Ohlone Elementary is more than 98% Latino) hazard, so we are calling on the Ag Commissioner to restrict 1,3-D by:

a) Immediately web-posting the Notices of Intent for 1,3-D applications that the growers send to him in real time in the entire county;
b) Restricting 1,3-D approvals to keep the air concentration below OEHHA's cancer risk warning level of 0.04 parts per billion; and
c) Expanding the buffer zones for 1,3-D use around schools to at least 1-mile, from their current legally required 1/4-mile.

3. Brain- and lung-harming Organophosphates: The CHAMACOS researchers from UC Berkeley have documented harm to Salinas Valley children from organophosphate exposure for more than 25 years now. The harms include cognitive and behavioral deficits, neurodevelopment disorders, and lung damage. A quarter of all organophosphate use in California is in Monterey County. That is certainly an undue disproportionate hazard, so we are calling on the Ag Commissioner to:

a) Demand Notices of Intent (NOIs) from growers for the organophosphates that are not currently “restricted materials”;
b) Web-post the NOIs for all organophosphate pesticides in real-time;
c) Apply emergency safety buffers of at least one mile around all residences, schools, hospitals, and other sensitive sites in which these organophosphate pesticides cannot be applied.

4. Childhood cancer-causing pesticides: Researchers at the UCLA Fielding School of Public Health identified 13 pesticides linked to childhood cancers, if the pregnant mother lived within 2.5 miles of their application. In Monterey County, 9 of every 10 pounds of these pesticides are concentrated in the Latino-majority region of the Salinas Valley. That is certainly an undue disproportionate hazard, so we are calling on the Ag Commissioner to:

a) Demand Notices of Intent (NOIs) from growers for the childhood cancer-causing pesticides that are not currently “restricted materials”;
b) Web-post the NOIs for all childhood cancer-causing pesticides in real-time;
c) Apply emergency safety buffers of at least 2.5 miles around all residences, schools, hospitals, and other sensitive sites in which these pesticides cannot be applied.

Government Center, Schilling Place Cayenne Room
Salinas, CA
April 3, 2024

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