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Home , Imiprothrin, Prallethrin, Pyrethrum

Indoors: Differences in Risk, Regulation, and Necessary Precautions

Presentation to: CAPE Webinar Series June 16, 2020 Kathleen Cooper, Senior Researcher, CELA Dr. Meg Sears, Chair, Prevent Cancer Now

1 About CELA and PCN

• Legal aid clinic; poverty law • National civil society group mandate including scientists • Legal representation; public • Primary cancer prevention legal education; law reform is the cure (over 30 years addressing • Many factors contribute to law and policy) cancer • Among our priorities: • We apply scientific rigour to • Human health effects of identify least-toxic options toxic substances, esp. to minimize hazardous among vulnerable exposures populations

2 Pesticides used indoors – why it matters

. Most time is spent indoors (80% – 90%) . Direct exposure, may be higher than other pesticide sources . Regulatory differences and limitations . Persistence is greater indoors . Some health endpoints not assessed . Indoor “environment” poorly characterized . **Low income factors unaddressed – older housing, crowding, cleaning challenges, etc. → higher use of pesticides** . Context: Multiple pesticide exposures and multiple chemical exposures (PBDEs, BPA, PFOs/PFAs, metals, etc.). . Nobody wants fleas, ants, , bed bugs, mice, etc. . Choices exist for lower risk and/or non-chemical alternatives

3 and

. Most pesticides used indoors are in this class . Replaced more toxic (OPs) and . Neurotoxic to insects; lower acute mammalian neurotoxicity because mammals break down the pesticide quickly . Widely used in agriculture, medical and veterinary products . Pyrethrins (from ) degrade quickly in sunlight . Pyrethroids → greater stability, persistence and toxicity . Emerging evidence of endocrine toxicity at low exposure levels . Routinely produced as mixtures with 1. synergists that slow insect enzymes to break down pesticide 2. other pyrethroids, or other neurotoxic . Semi-volatile organic chemicals linger in dust and on surfaces, along with other toxins (e.g., lead, mould, outdoors pollution)

4 PESTICIDE Co-formulant Pyrethrins and Pyrethroids Synergists MIXTURES insecticides Momfluorothrin Beta D Pyriproxifen - - Pyrethrins Co-formulated cyfluthrin - Lambda MGK264 Pesticide Active Allethrin Ingredients PBO

Allethrin (various ✔ ✔ ✔ ✔ ✔ isomers) Cyfluthrin ✔ ✔ Beta-cyfluthrin ✔ D-Phenothrin ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ Imiprothrin ✔ ✔ Lambda-cyhalothrin NO CO-FORMULANTS Momfluorothrin ✔ ✔ Permethrin ✔ ✔ ✔ ✔ Prallethrin ✔ ✔ ✔ Pyrethrins ✔ ✔ ✔ ✔ Tetramethrin ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔

Octylbicyclo Heptene Dicarboximide ✔ ✔ ✔ ✔ ✔ ✔ (MGK264) Piperonyl Butoxide ✔ ✔ ✔ ✔ ✔ ✔ ✔ (PBO)

Methoprene ✔ ✔ Imidacloprid ✔ ✔ ✔ 5 Progression of pesticide persistence [and toxicity] Original organic low human toxicity, breaks down quickly in the environment

Successive pyrethroids include atoms and groups that may make them more persistent and/or toxic

6 Progression of pesticide toxicity

Reactive alkyne (triple-bond C) and N-containing ring

Prallethrin

Imiprothrin

7 Progression of pesticide persistence [and toxicity] Halogens: (Cl) and fluorine (F) Permethrin

Cyfluthrin

Lambda-cyhalothrin

8 Potential health effects of containing insecticides Known effects • Symptoms: numbness, itching/burning, nausea, dizziness, headache, cough, allergic reaction, twitching and writhing • Interfere with nerve fibre signal transmission (alter sodium channels in cell membranes) • Synergist piperonyl butoxide slows pesticide breakdown in humans as well as insects • Mixtures with other types of insecticides more toxic Evidence building on longer term effects • Affect behaviour – Canadian, US, French, Korean and other studies, correlate child behaviour with urinary metabolites • Earlier puberty in boys and later puberty in girls • Liver cancer, child brain tumours • Impacts on hormone systems (endocrine disruption) related

to child development and cancer 9 Law, Regulation, Guidance

Pest Control Products Act and Regulations . Assessment of risk (hazard x exposure) and value (efficacy) of product . Risks to humans, environment (therein, persistence and environmental fate) . Residues in food, feed, and environment . And a lot more… Therein: . “Environment“ = outdoors only . Legal requirement to set residue limits only for agricultural use

10 Hazard Assessment

. Toxicity evaluation → the same for all pesticides . Pyrethroids - focus is on acute neurotoxic hazard; not (yet) considering chronic neurotoxicity, endocrine toxicity, cancer . Part of hazard assessment → persistence & dissipation . Persistent substances – often more toxic and more chemically stable/active (e.g., POPs) . Outdoors – processes of chemical breakdown (wind, sun, rain, microbial action) . Indoors – quasi-persistence/continuous presence; e.g., indoor surfaces, carpets, dust

11 Examples of differences in persistence Outdoors vs indoors . - pesticide now banned for indoor use: . Env’l dissipation outdoors – a few days, up to 4 years depending on outdoor env’l factors . indoor residence time of nearly 7 years . Permethrin – pesticide commonly used indoors: . Env’l dissipation outdoors – a few days up to several months depending on outdoor env’l factors . indoor residence time of nearly 4 years . Persistence indoors: parallels to POPs outdoors

12 Exposure Assessment

. Outdoors - analytical, laboratory and field studies of environmental chemistry, fate, residues measuring: . breakdown products, metabolites, impurities, tracking of env’l pathways (in soil, sediment, water, air, biota) crop residue trials, crop residue decline studies, effects of processing of food or feed, etc. . All of above under different circumstances (variations in location, crop type, etc.) . Maximum residue limits for food and animal feed . Addressed across very large # of guidance documents . Indoors – how much pesticide is used . Exposure assessment guidance from USEPA

13 USEPA Standard Operating Procedures (SOPs) for Residential Pesticide Exposure Assessment

By 2012, ~ 20-year development: . Some recognition of indoor differences but concludes: . Can estimate exposure from transferable residues right after use . Direction regarding “durations of exposure” . Short-term (up to 30 days), intermediate-term (1-6 months) and long-term (> 6 months) . Assumptions throughout: . Pesticide exposure on day of application will be the same for entire exposure duration period; measure it as such . Dust? - too hard to measure, likely irrelevant since rest of analysis is “conservative and protective” . No consideration of low income circumstances

14 Models and Biomonitoring Data (to test results of SOP modelling) . Complex exposure models (USEPA) . Combine sources (diet, residential, etc.), pathways (inhalation, dermal, etc.) and exposure factors (dermal absorption, hand-to- mouth transfer, etc.) . Compare results to biomonitoring data ( >99% detection of pyrethroid metabolites in Canadians) . Various model results align with biomonitoring results . But, model results are compared to older biomonitoring data (and none for very young children) . Use of pyrethrins and pyrethroids has steadily increased across time of biomonitoring . Models also do not account for low-income differences

15 Canadian PMRA Exposure Assessment USEPA SOPs are de facto guidance For indoor uses (Domestic and Commercial products used in residential settings): . Demonstrate access to Residential Exposure Joint Venture - REJV (proprietary data on use) . Don’t account for dust . Don’t account for low income circumstances Most pyrethrins and pyrethroids now subject to re- evaluation/recently re-evaluated . Exposure assessments are “conservative” using day-of- application levels across exposure durations  Cancellations or restrictions on indoor uses  E.g., Cancellations on some halogenated pyrethroids (for

domestic products) 16 Changes resulting from re-evaluation Largely achieved via label changes Bringing consistency to labels: . E.g., broad definition of “residential” “Commercial” products: . New use restrictions (e.g., no fogging, hand-held mist sprayers/blowers, broadcast or space spraying) . Greater PPE . Longer re-entry times; leaving literature for clients “Domestic” products: . Crack and crevice applications only . Don’t spray over your head; ventilate well . Remove “repeat treatment as necessary” . Added precautions about kids, pets, food contact Changes affect 100s of products

17 Incidents, non-compliance among PCOs . Registrants must report pesticide incidents . Incident reports influence PMRA enforcement of compliance . E.g., was large # of rodenticide poisonings → use restrictions, tamperproof/inaccessible bait (incident #s dropped) Control Operators (PCOs): . High rates of non-compliance; priority for inspections since 2013. E.g.,: . Not following labels – uses not listed; incorrect application sites or rates (e.g., products limited to crack and crevice sprayed more broadly) . Use/possession of unregistered pesticides/expired products . Inadequate use of PPE . Non-compliant advertising

18 Conclusions Regulatory evaluation of pesticides used indoors Conservative assumptions about exposure – adequate? . Day-of-application levels assumed over entire timeframe of exposure assessment. . Seems unlikely to address risk . Pesticides persist indoors much longer than durations chosen . Increased restrictions following re-evaluations → hoped-for conservatism likely insufficient Additional risks . Not addressing all health endpoints – e.g., endocrine toxicity . Unaddressed risk of overexposure for those on low income . Heavy reliance on individuals or PCOs following labels

Lack of awareness that labels are the law . Label instructions flow directly from the risk assessment . If exceed allowed use, also exceed risk thresholds

19 Conclusions cont’d Regulatory evaluation of pesticides used indoors

Much depends on labels . Addressing immediate but not long-term exposure . Label changes poorly communicated . Need clear alerts, esp. on Commercial products → when and how allowed uses changed . Often disallowing “space spraying” but can be very unclear what that means . Ingredients and instructions in tiny font . Need clear, easier to read/see instructions; pictograms; URLs for on-line instructions in multiple languages

Given regulatory shortcomings - prudent to choose lowest risk and/or non-chemical alternatives 20 Making informed choices Choosing lower risk alternatives Recall: . Crucial link between label instructions and underlying risk assessment → ALWAYS FOLLOW THE LABEL . “Domestic” products contain the same “Commercial” chemicals used by PCOs (just at lower concentrations) Reading labels: . PCP# and Active Ingredient(s) . Are there multiple Active Ingredients? . Read instructions, toxicity information, and precautions . (Deep dive: PMRA Label Search https://pr-rp.hc- sc.gc.ca/ls-re/index-eng.php) Learn about the pests (to seek prevention) and about non-pesticide options . E.g., extreme cold, or extreme heat or steam for bed bugs Good example: https://ruralroutespestcontrol.com/our- process 21 Making informed choices Know the pest; seek prevention

What do pests need? Make your space inhospitable Food Clean. Store in glass/plastic. Shelter Fill cracks, cover mattresses Safety Repel, trap, kill

They “built a better mouse trap”

22 Reading labels; making informed choices low risk, common chemicals Common chemicals are relatively benign BUT Not risk-free (allergies, dust)

Recall: Law requires efficacy (they have to work) LABEL

23 Label changes after re-evaluation “spraying” increases risks Two-year delay for label change (unless immediate risk) . “60 Day Residual Control of Cockroaches” - Pressurized Contact and Residual Spray Claims: Kills Ants, Bedbugs, Cockroaches, Earwigs, Spiders, Sowbugs, Silverfish, Dog & Cat Fleas, Brown Dog , House Flies “This product has a special valve that sprays in all directions even upside down for hard to reach areas.” “Hold container approximately 30 cm from surface being sprayed and spray until thoroughly wet but not until run‐off. Thorough applications produce a coating which will vaporize into cracks and crevices for insect control. If reinfestation occurs, repeat application as necessary. Unpainted or unsealed concrete surfaces may require repeated application after two weeks if necessary. Provide adequate ventilation after indoor use. KEEP PETS AND CHILDREN AWAY FROM SURFACE UNTIL DRY. Do not use as a space spray.” . Re-evaluation: no broadcast application; localized spot spraying - unadjoining spots. Cracks and crevices, not on surfaces. 24 Example Fact Sheet – Bed Bugs and Pesticides – Information for Tenants in Ontario

Addressing bed bugs needs coordinated strategy: . eliminating bug habitat and preparing for Who applies the pest control? . Making informed choices about Domestic or Commercial pesticide products Collaboration between tenant and landlord is essential . Law as last resort https://cela.ca/bed-bugs-and-pesticides-information-for- tenants-in-ontario/

25 25 Reading labels; making informed choices Anticipate and apply label changes Options for pesticide products allowed for use against bedbugs Pesticide Active Ingredient Why make this choice? Precautions

Least toxic alternatives (also recall the non-pesticide options of extreme cold or extreme heat) Silicon dioxide • Non-toxic chemical made from tiny dried-up sea • Fine powder can be a strong irritant to lungs. (label may say “present as creatures. • Label will warn against breathing dust. ”) • Very fine powder that cuts open the bug, causing it to dry out and die. • Repeat treatments are often needed.

Pyrethrins • Purified from plant extract • No re-evaluation done yet by federal government

Pesticides to choose if least toxic alternatives don’t work Permethrin Federal government re-evaluation (will be updated label • May be in both Domestic or Commercial instructions but not required until August of 2021): products • cancel fogging or spraying; limited spot spraying and for • Despite current label instructions, avoid cracks and crevices fogging or spraying now. • Ask PCO to avoid fogging/spraying.

Pesticides to try and avoid Tetramethrin Federal government review, in effect February 2020: • May be in both Domestic or Commercial • cancelled indoor broadcast (floors, carpets) and room products perimeter (baseboards) treatments due to cancer risk • Avoid use of older products containing • removed “repeat as necessary” from label tetramethrin • Watch for and avoid products containing tetramethrin in combinations with other pesticides

Beta-cyfluthrin • Allowed uses don’t include fogging or spraying but is • Found only in Commercial products. used on mattresses. • Ask that PCO use this pesticide only as a last resort. Cyfluthrin Federal government re-evaluation decision: • Avoid products containing cyfluthrin • limit domestic uses to spot spraying • Ask that products with this pesticide not be • disallow all uses other than low pressure spray into used by PCOs. cracks and crevices Lambda-cyhalothrin Federal government re-evaluation is recommending: • Found only in Commercial products. • cancel all indoor residential uses • Ask that products containing this pesticide not be used by PCOs. 26 Precaution and Prevention Policy advocacy to address underlying causes . Preventative policy . Pest control policy in co-ops, apartments, condos, workplaces (IPM, visual inspections, low risk products, etc.) . Housing providers and safe housing advocates . Maintenance responsibilities of landlords (and tenants) . More educational resources . Reform of pesticide regulation (social justice), www.rentsafe.ca including increased enforcement . Poverty reduction . Affordable housing https://chfcanada.coop/submission-to- ontarios-poverty-reduction-strategy/ http://www.basicincomecanada.org/ 27 Thanks to:

. Équiterre (client for research conducted in 2018) and MakeWay, formerly Tides Canada . Jennifer Kuhl, Canadian Association of Physicians for the Environment

Kathleen Cooper, Senior Researcher [email protected] Meg Sears, Chair, Prevent Cancer Now [email protected]

Note: any images of specific products in this presentation do not constitute product endorsement

28 Contact Us; Stay Informed

https://cela.ca/

CELA Bulletin sign-up: https://cela.ca/sign-up-stay-informed- http://www.preventcancernow.ca/ cela-bulletin/ http://www.preventcancernow.ca/join -pcn-and-stay-informed/

29 Selected References (1)

• Brander, Susanne M., Molly K. Gabler, Nicholas L. Fowler, Richard E. Connon, and Daniel Schlenk. “Pyrethroid Pesticides as Endocrine Disruptors: Molecular Mechanisms in Vertebrates with a Focus on Fishes.” Environmental Science & Technology 50, no. 17 (September 6, 2016): 8977–92. https://doi.org/10.1021/acs.est.6b02253. • Davies, T. G. E., L. M. Field, P. N. R. Usherwood, and M. S. Williamson. “DDT, Pyrethrins, Pyrethroids and Insect Sodium Channels.” IUBMB Life 59, no. 3 (2007): 151–62. https://doi.org/10.1080/15216540701352042. • Hwang, Moonyoung, Youngmee Lee, Kyungho Choi, and Choonghee Park. “Urinary 3-Phenoxybenzoic Acid Levels and the Association with Thyroid Hormones in Adults: Korean National Environmental Health Survey 2012–2014.” Science of The Total Environment 696 (December 15, 2019): 133920. https://doi.org/10.1016/j.scitotenv.2019.133920. • Lu, Chensheng, Dana B. Barr, Melanie A. Pearson, Lance A. Walker, and Roberto Bravo. 2009. “The Attribution of Urban and Suburban Children’s Exposure to Synthetic Pyrethroid Insecticides: A Longitudinal Assessment.” Journal of Exposure Science and Environmental Epidemiology; 19 (1):69–78. https://doi.org/http://dx.doi.org.myaccess.library.utoronto.ca/10.1038/jes.2008.49. • Lu, Chensheng, Gary Adamkiewicz, Kathleen R. Attfield, Michaela Kapp, John D Spengler, Lin Tao, and Shao Hua Xie. 2013. “Household Pesticide Contamination from Indoor Pest Control Applications in Urban Low-Income Public Housing Dwellings: A Community-Based Participatory Research.” Environmental Science & Technology 47 (4): 2018–25. doi:10.1021/es303912n . • Nakagawa, Lia Emi, Alan Roberto Costa, Ricardo Polatto, Cristiane Mazarin do Nascimento, and Solange Papini. 2017. “Pyrethroid Concentrations and Persistence Following Indoor Application: Pyrethroid Persistence Indoors.” Environmental Toxicology and Chemistry, June. https://doi.org/10.1002/etc.3860. • Oulhote, Youssef, and Maryse F. Bouchard. “Urinary Metabolites of and Pyrethroid Pesticides and Behavioral Problems in Canadian Children.” Environmental Health Perspectives, October 22, 2013. https://doi.org/10.1289/ehp.1306667. • Pest Management Regulatory Agency, Health Canada – Reports and Publications (numerous) https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides- pest-management.html • Roberts JW, Wallace LA, Camann DE, Dickey P, Gilbert SG, Lewis RG, et al. Monitoring and Reducing Exposure of Infants to Pollutants in House Dust. In: Whitacre DM, editor. Reviews of Environmental Contamination and Toxicology Vol 201 [Internet]. Boston, MA: Springer US; 2009 [cited 2016 Sep 13]. p. 1–39. Available from: http://link.springer.com/10.1007/978-1-4419-0032-6_1

30 Selected References (2)

• Roberts, J. R., C. J. Karr, and Council on Environmental Health. 2012. “Pesticide Exposure in Children.” Pediatrics 130 (6): e1765–88. doi:10.1542/peds.2012-2758. • Rudel, Ruthann A., David E. Camann, John D. Spengler, Leo R. Korn, and Julia G. Brody. 2003. “Phthalates, Alkylphenols, Pesticides, Polybrominated Diphenyl Ethers, and Other Endocrine-Disrupting Compounds in Indoor Air and Dust.” Environmental Science & Technology 37 (20):4543–53. https://doi.org/10.1021/es0264596. • Saillenfait, Anne-Marie, Dieynaba Ndiaye, and Jean-Philippe Sabaté. “The Estrogenic and Androgenic Potential of Pyrethroids in Vitro. Review.” Toxicology in Vitro 34 (August 2016): 321–32. https://doi.org/10.1016/j.tiv.2016.02.020. • US Environmental Protection Agency Office of Pesticide Programs, Standard Operating Procedures for Residential Pesticide Exposure Assessment. October, 2012. 582 pp. • Viel, Jean-François, Charline Warembourg, Gaïd Le Maner-Idrissi, Agnès Lacroix, Gwendolina Limon, Florence Rouget, Christine Monfort, Gaël Durand, Sylvaine Cordier, and Cécile Chevrier. “Pyrethroid Exposure and Cognitive Developmental Disabilities in Children: The PELAGIE Mother–Child Cohort.” Environment International 82 (September 1, 2015): 69–75. https://doi.org/10.1016/j.envint.2015.05.009. • Viel, Jean-François, Florence Rouget, Charline Warembourg, Christine Monfort, Gwendolina Limon, Sylvaine Cordier, and Cécile Chevrier. “Behavioural Disorders in 6-Year-Old Children and Pyrethroid Insecticide Exposure: The PELAGIE Mother–Child Cohort.” Occupational and Environmental Medicine 74, no. 4 (April 1, 2017): 275–81. https://doi.org/10.1136/oemed-2016-104035. • Weschler, Charles J., and William W. Nazaroff. 2008. “Semivolatile Organic Compounds in Indoor Environments.” Atmospheric Environment 42 (40):9018–40. https://doi.org/10.1016/j.atmosenv.2008.09.052. • World Health Organization, and International Agency for Research on Cancer (IARC). “Report of the Advisory Group to Recommend Priorities for IARC Monographs during 2015–2019,” April 2014. https://monographs.iarc.fr/wp-content/uploads/2018/06/14-002.pdf. • Ye, Xiaoqing, Wuye Pan, Yuehao Zhao, Shilin Zhao, Yimin Zhu, Weiping Liu, and Jing Liu. “Association of Pyrethroids Exposure with Onset of Puberty in Chinese Girls.” Environmental Pollution 227 (August 1, 2017): 606–12. https://doi.org/10.1016/j.envpol.2017.04.035.

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