Home: CCE Logo Slogan: Empowering Communities, Advocating Solutions.
About CCE/ContactWhat's New/CalendarNewsletterMedia/News CenterJobsContribute Now
Subscribe For Email Updates
Take Action!
Campaign Information, by Category:
Water ProtectionPublic Health and Toxic Chemical ContaminationOpen Space and Wildlife HabitatClimate Change and Energy PolicyLegislative Campaigns
 

HEADER SECTION

Comments on the Draft Scope Proposed Suffolk County Vector Control and Wetlands Management Long Term Plan, and the Draft Scope for the Draft Generic Environmental Impact Statement

Comments by Citizens Campaign for the Environment
Submitted to the Council on Environmental Quality for Suffolk County
September 25, 2002

Citizens Campaign for the Environment (CCE) is an 80,000-member independent, not-for-profit advocacy organization working for the protection of public health and the natural environment in New York State. CCE has been providing public input to Suffolk County’s vector control plan since 1999. The participation of the public and non-governmental organizations has helped to diversify and spark discussion, which we anticipate will lead to a plan more responsive to all of the public’s legitimate concerns.

CCE is pleased to have this opportunity to review and comment on the draft scope for the proposed Suffolk Vector Control and Wetlands Management Plan. In general, CCE wishes to acknowledge the technical and professional quality of the draft plan. The level of effort and expertise is greatly appreciated.

The comments CCE offers are submitted in the hope that while the avoidance of nuisance mosquitoes and of human disease from arthropod-borne viruses should be attempted, there are equally important considerations concerning the wide-spread use of poisons and their impacts on both human and wildlife populations, which must also be incorporated into any vector control program.


COMMENTS ON THE SCOPE OF THE DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT (DGEIS)

1. The Proposal for Suffolk County Vector Control and Wetlands Management Long Term plan and Environmental Impact Statement submitted by Cashin Associates states on page 16, “The toxicological literature included in this review will be derived largely from previous EISs conducted by New York City and Westchester County.” CCE believes this strategy is inadequate. Both of these studies were performed solely for the purpose of West Nile Virus control. The Westchester Plan was performed anticipating a maximum number of seven adulticide applications per year. This is a dramatically different scenario than we have in Suffolk, and should not be viewed as a similar set of circumstances. CCE’s review of the Westchester EIS found that it was deficient in it’s review of health and environmental data which assessed impacts of repeated exposure to pyrethoids.

2. CCE requests that the DGEIS include the review of health studies listed in The Health Effects of Pesticides Used for Mosquito Control a report by Citizens Campaign for the Environment and Citizens Environmental Research Institute, August 2002. (See attachment A).

3. The DGEIS doesn’t specifically mention Malathion. Since the SC Vector Control Department has used this adulticide in the past several years and it is included in the proposed 2003 Suffolk County Vector Control Plan it should be included in the assessment. In addition, private contractors use Malathion for mosquito control in some Fire Island communities.

4. CCE was pleased to see that the information from the New York State Department of Health (NYSDOH) pesticide-poisoning registry would be included in the human health risk assessment. In specific, please note that in 2000 the NYSDOH reported that 14 people became ill from WNV and 14 people were confirmed by members of the medical community to be made sick from the adulticide spray application for WNV. In addition, over 200 people called the poison control hotline to register health complaints associated with the spraying.

5. In addition to using NYSDOH data and scientific literature, CCE requests that past credible news reports be utilized for assessing public health impacts associated with adulticide spraying. For example:

  • “Workers Say Chemicals Used in Mosquito Spraying Made Them Ill,” by Susan Saulny, published in the New York Times, January 25, 2001, Section B, p. 2. This article discusses the story of five men who sprayed pesticides for mosquito control for a NYC contractor. The exposure to the chemicals made them sick.
  • “Artist: I’m a Victim of Sketter Spraying,” published in the Daily News, by Michael R. Blood on September 9, 2000. This article tells of how a Manhattan woman ended up in the hospital after she was exposed to Anvil during spraying for mosquitoes.
  • “Town Probes Park’s Spraying” by Jim Rogalski of the Times-Union, Albany, NY June 27, 2001. This article reports on the incident where Malathion was sprayed on a ball field in Moreau, NY during a soccer game causing thirty-seven people to be hospitalized. A total of 37 youth softball players and spectators ranging in age from 6 to 52 were rushed to Glen Falls hospital for respiratory problems from exposure to Malathion sprayed from a truck.


6. The DGEIS should give substantial evaluation to the larvicides used as well as the adulticides. The study, Photoproducts and Metabolites of a Common Insect Growth Regulator Produce Development and Deformities in Xenopus, performed by the Scripps Research Institute of Oceanography, La Jolla, California was published in Environmental Science Times, 1998. This study found that break down products of methoprene, a common larvacide used in Suffolk, cause deformities in amphibians. In 1997 scientists from the USGS and the U.S. Fish and Wildlife Service conducted a study in which it was reported, “In wetland areas treated with Altosid, 15 percent of the frogs experienced deformity, most notably involving partially or totally missing legs. In untreated control wetlands, a deformity rate of only 3 percent was observed.” Methoprene is the active ingredient in Altosid. (See attachment B).

7. The Vector Control Department has stated that the larvacide, Vectorlex, can cause negative impacts to filter feeder organisms. Vectorlex should be thoroughly explored in the DGEIS.

8. The DGEIS should assess the potential health effects on the most vulnerable populations to pesticide contamination including children, developing fetuses, and individuals with compromised immune systems, multiple chemical sensitivities or asthma.

9. Certain communities in Suffolk experience repeated and frequent adulticide spray applications for nuisance control. For example, Mastic beach, Shirley, Babylon and numerous Fire Island communities. The environmental and public health impacts of repeated exposures should be assessed.

10. It is widely recognized that studies have not been performed to assess the public health impacts of long term exposures to pyrethoid chemicals. The DGEIS should address this gap in the scientific literature.

11. There is currently a gap in scientific data and literature regarding the synergistic effects of pesticides. For example, the synergistic effects when pesticides used for mosquito control and combined with commercially applied pesticides. Such effects, and the gaps in data and literature regarding them, should be addressed in the DGEIS.

12. In addition, a discussion of impacts to the resistance of human and wildlife populations to vector-borne diseases through time should be examined.

13. It is an established fact that insects develop resistance to pesticides after repeated exposures resulting in a decreased effect of the pesticide. The DGEIS should examine this resistance.

14. The methodology for evaluating risk discussed on page five, paragraph one of the Draft Scope for the Proposed Suffolk County Vector Control and Wetlands Management Plan Draft Environmental Impact Statement should be subject to input from the CAC.

15. Monitoring protocols for determining efficacy and impacts to human health and the ecology of pesticide applications should be developed with input from the CAC.

16. The scope should include potential impacts to such endangered and threatened species as the piping plover and turtles.

COMMENTS ON THE LONG TERM PLAN:


1. The plan should state clearly and unambiguously whose responsibility it is to carry out each of the components, actions or responses of the plan, for example:

  • Whose responsibility is it to make the decision to utilize adulticides with a truck application and/or aerial spraying?
  • Which county agency is responsible for advising and educating residential and commercial residents and owners about reducing mosquito populations on their property? What is the public education plan to accomplish this goal?
  • Who is ultimately responsible for implementation of the plan? Is it the County Legislature, SCDOH or SCDPW?
  • What are the consequences if an entity fails to implement an effective education and habitat source reduction campaign? Is there any enforcement component to the plan, and if so, what is it?

2. The Long Term Plan should include criteria which determines the level of response, for example:

  • The plan must have some guidelines regarding the factors that trigger the application of larvicides and adulticides for nuisance control and disease control.
  • How many complaints and/or what do the mosquito counts need to be to warrant control or habitat modification activities for nuisances control? In effect, how many mosquitoes does it take to trigger an action?
  • In how many individual locations must WNV be present to warrant truck application of adulticides?
  • What factors trigger aerial spraying?
  • What determines the geographic boundaries of adulticide responses?

3. The plan should clearly define Health Emergency.

4. The plan should state that the intended goal is that the use of insecticides should be as localized as possible in all circumstances.

5. The plan should emphasize the need for and progress of pilot programs for non-toxic methods of reducing mosquito populations. Although the Town of Huntington and the Suffolk Parks Department have each purchased a mosquito magnet, the Suffolk County Vector Control Department seems to know little about the satisfaction these government entities have had with these non-toxic products. In this way Suffolk can provide some of the science needed to assess the effectiveness of the emerging non-toxic mechanisms.

6. The Long Term Plan’s monitoring plan should include South Shore Estuary water samples taken in Fire Island communities that experience the most frequent adulticide spray events. CCE suggests areas such as Water Island, Davis Park, West Gilgo Beach and Gilgo Beach to name a few. A location such as Water Island, not only experiences frequent spraying but this is also one of the narrowest strips of land on Fire Island. CCE is concerned that the 100-foot set back from aquatic areas may not be adhered to in these geographically challenging areas.

7. The Plan should detail how the program will protect piping plovers, nesting turtles and other endangered and threatened species.

Human Health Impacts

1. Monitoring for human health impacts associated with mosquito control activities should be elevated to the same stature and given the same level of resources as Human Surveillance for WNV. There are inherent risks to human health associated with pesticide exposure, especially for sensitive populations. This is the rationale for the tiered approach to mosquito control and the reason mosquito adulticides are considered the least desirable method of control. Since the relative risk of suffering health impacts from WNV as compared with exposure to pesticides used for mosquito control are not known, or have not been clearly defined, there is no justification for preferring the one type of monitoring over the other.

2. The same tracking and data collecting systems put in place to combat WNV should be utilized for those potentially suffering from pesticide exposure. The Encephalitis/Meningitis Initial Case Report Form utilized by the New York State Department of Health is an excellent way to track accurate information on this disease. A comparable reporting form should be developed and utilized for victims of pesticide exposure. Also, outreach to health care providers, schools, and the media is necessary to provide accurate information on recognizing health effects of, and adverse reactions to pesticides. Educational materials should also be developed and disseminated to health professions.

3. The Long Term Plan should contain a component to educate the public on the symptoms of pesticide exposure so that the County can establish accurate data on health effects.

The NYSDOH has documented human health impacts as a result of exposure to pesticides used for mosquito control. As a result, NYSDOH recommends remaining inside or avoiding the area when spraying takes place. (See attached fact sheets from NYSDOH – Attachment C). Unfortunately, some Long Island media recently reported that SCDHS recommended no specific precautions against pesticide exposure, and that people can remain outdoors during spraying. This is completely irresponsible and inconsistent with the NYS WNV Response Plan. Federal law prohibits pesticide manufacturers from making claims of safety about their products. Health officials should be held to the same high standard. The people of Long Island should never hear again from public health officials that pesticides are safe or that there is no reason to avoid exposure. The best way to mitigate the potential impacts of pesticide exposure is to eliminate, reduce or minimize exposure. In other words, remain indoors or out of the area during applications, just like the NYSDOH recommends!


4. In addition, educational materials to understand the symptoms of pesticide exposure need to be developed and disseminated to veterinarians and the appropriate wildlife agencies.

Respectfully submitted by,

Adrienne Esposito
Associate Executive Director

Jessica Ottney
Long Island Program Coordinator