OBSERVATIONS AND COMMENTS

on the

Draft Scope of NYCDOH Analysis Document

in Preparation of an Environmental Impact Statement (EIS)

The following comments will be presented to the Commissioner of the New York City Department of Health, Neal Cohen, M.D. on June 23,2000 at Queens Borough Hall in Kew Gardens, NY. Dr. Cohen will be presiding at an Environmental Impact Study (EIS) Hearing at that time and place to hear comments from the public regarding their concerns and suggestions for the upcoming EIS Plan. Joyce Shepard, President of CACC, Clinical Social Worker and activist will be representing the Citizens’ Action Committee For Change to encourage the City of New York to ensure accountability and minimal health risks connected to pesticide applications within the EIS document.

Chem -Tox.com has published data showing behavior of the mosquito after spraying occurs. Spraying makes the mosquito become overactive, therefore having the tendency to bite more.

Also, as in humans, their immune system is affected making them more susceptible to contracting the WNV. NYCDOH needs to do research into these studies.

Spraying options that are available are back packing, truck and Aerial spraying. There are drift factors associated with all three. NYCDOH has to gather data on the most effective modality with the least drift. Targeted backpack spraying is a more effective mode and less damaging to the health of the population.

Pyrethroids break down under sunlight. However, it does not breakdown in dark enclosed areas such as underground subways. Measures must be taken ,. to monitor run-off in sewers and subways.

inert ingredients of any pesticides used in order to evaluate risks. It would be irresponsible of NYCDOH to use pesticides if the ingredients are not made known for evaluation. Measures must be taken to ensure this accountability is carried out.

The homeless are a vulnerable population during spraying. NYCDOH has to devise a plan to notify shelters and police to protect the homeless from pesticide exposure as well as proprietors of outdoor fruit stands, and organic gardeners

A plan must be in place to take indoor air quality sampling/ swipes and filter sampling for residue after the spraying. Public notification is to be in place to educate the public to replace all air condition filters before turning their units back on.

The NYC Parks Department, Army Corps of Engineers, Federal Parks Department, and NYS Parks Commission must be notified of spraying of wetlands, parks and properties and post the spraying initiative on their grounds 48 hours prior to spraying.

All community facilities, hospitals, senior centers, schools, day care centers, and prisons must be included in the notification plan.

NYCDOH must calculate and factor in how high rise buildings will effect wind conditions and therefore drift of pesticides. NYCDOH must factor in high wind situations.

Agdrift is not tailored for urban situations. The Ag model focuses on agricultural spraying and does not take urban drift and urban air characteristics into consideration? Other than the Agdrift model, a model spraying urban areas with a large population is appropriate and should be the model used in NYC. What federal agencies are overseeing the drift factor?

All private doctors, hospitals, (public and private), and the general public must be made aware of the symptoms and impact of pesticide exposure. The MSDS and label of the pesticide must be made public through the media.

The Poison Control Center must have a more responsible and aggressive role with an educated and appropriate amount of staffing in place. Unlike the last spraying initiative. Seminars on the symptoms and the impact of pesticide exposure should be mandated for all city medical staff and in service presentations provided to all other medical facilities.

A registry must be implemented for risk assessment of the MCS population, children, pregnant women, and those suffering from upper respiratory ailments. It is imperative to implement a separate pesticide hotline separating complaints from the WNV hotline. A comprehensive pesticide exposure intake for data collecting must be initiated to determine the long term effects of pyrethroids?

Information must be available to the public on the acute effects vs. subchronic and chronic effects. The emphasis must be on the (sub)chronic. All toxicology data, (not just listed databases), baseline data on existing usage, and background level of chemicals/pesticides used in the city must be made available to the public.

Is there data to show an increase of mortality associated with last years spraying compared to earlier data?

Presently NYCDOH provides information to the public on the possible threat to asthmatics and respiratory ailments. The public must also be informed of the gastrointestinal, neurological and immunological symptoms, including endocrine disruptions associated with the pyrethroids.

Impacts on Natural Resources

Pyrethroids can have an impact on migratory birds and their protection should be considered.

Pyrethroids are known to be hazardous to fish and aquatics, therefore will kill the mosquito eating fish. This must be taken into consideration.

NYCDOH must eliminate classes of natural resources, which would end further consideration of those classes, until after the risk assessment has been conducted.

The pyrethroids are known to become concentrated on golf courses and ponds and precautions must be in place.

The storing practices of the chemical and label requirements of storing must be made public.

Who is responsible for the storage, transportation and disposal of the chemical? What agencies will oversee the application and disposal initiative.

How are applicators and disposal companies policed.

City workers i.e.: police/fire/ sanitation involved in the spraying initiatives must wear protective gear when involved with the spraying initiative. This was overlooked during the 1999 spraying initiative.

What agency will be involved in monitoring efficacy. An independent agency and citizens should be appointed in monitoring the efficacy of the spraying initiative to ensure accountability to the public.

The NYC Board of Education was remiss in cleaning their playgrounds and must initiate a clean up of all residue left on playgrounds immediately after the spraying.

Reports must me made available on mitigation measures.

Submitted by:

Joyce Shepard,CSW

President