Oregon accepting public comment on state pesticide use

Read the comments submitted by Beyond Toxics (PDF)

Roadside spraying (R) endangers a passing school bus with children and adjacent school bus stops, homes and gardens. Photo by Tom Hitchcock.

Why Care? Do you care about pesticide policies in Oregon? Do you wonder what state agencies do to minimize the risks of the pesticides? Did you know that, by law, state agencies must implement Integrated Pest Management (IPM) to protect health and the environment? Are you aware of the role of state agencies to control and reduce animal, insect and plant pests that may impact Oregon’s environment and economy?

What: Oregon has opened up the first-ever public comment opportunity! Oregon’s Integrated Pest Management Coordinating Committee (IPMCC ) released their first report describing state agency responsibilities and programs to implement integrated pest management. This report (PDF) is available for public comment. You can read the entire report and submit your comments on this website sponsored by Oregon State University and filling out the form.

When: SUBMIT your public comments by 5 PM tomorrow, August 15th on the OSU website.

Take Action: Please comment on the State’s IPM Report to influence the future of pesticide policies in Oregon! It’s important because the State IPM Report will soon be presented to the State Legislature. Your comments make a difference in what Legislatures learn about pesticides, human health and the environment! Please use our talking points (see, “SAMPLE TALKING POINTS FOR YOUR TESTIMONYbelowas a guide to making comment on the draft report.

Comments submitted by Beyond Toxics (PDF)

Background. In 2013, the Oregon Legislature passed HB 3364, a bill to update and coordinate Oregon’s State Integrated Pest Management policies and programs. (Read ORS 634.657 the statute language). Beyond Toxics was instrumental in advocating for HB 3364, a bill to update and coordinate Oregon’s State Integrated Pest Management policies and programs. HB 3364 set a precedent by amending ORS 634.650, the definition of Integrated Pest Management, to clearly prioritize the protection of health and environment, and adopt current science around pest solutions and toxicology. HB 3364 was introduced by Representative Alissa Keny-Guyer and passed with overwhelming bipartisan support in both chambers of the Legislature. The bill established the Integrated Pest Management Coordinating Committee (IPMCC) and required state agencies and Oregon’s universities to meet regularly with the State Integrated Pest Management Coordinator. Their statutory assignment included:

1. Find solutions to a complex world of pest pressures, including invasive plant and animals species;
2. Address public concerns about pesticide poisonings and pesticide exposure related to state agencies practices (e.g., roadside herbicide sprays, pesticide applications at public schools);
3. Reduce water quality impacts and wildlife harm from pesticides;
4. Incorporate new science of health and environmental risks associated with pesticides;
5. Emphasize alternatives to toxic pesticides and reduce the risk of using pesticides.

Important for Public Comment: HB 3364 emphasizes that state agencies must reduce the risks from pests” and simultaneously reduce the risk “from strategies relating to pest management.” The focus must not solely be on pest elimination. State agencies must also reduce risks resulting from strategies related to pest management, including the risk of chemical exposure.

Short List: What To Ask For:

We ask the State IPMCC to adopt these recommendations:

• Adopt and implement state policy/practices that measure progress toward reducing pesticides in the environment to protect people who use public facilities, in particular children and pregnant women because of their special vulnerability; to safeguard wildlife populations and endangered species; to protect native and endangered plants; to protect drinking water and ground water, aquatic systems, estuarine and marine environments.

• Adopt safe pesticide management strategies based on IPM to promote a sustainable, green economy and protect state workers.

• Incorporate IPM best management practices, reduced toxic alternatives, monitoring and metrics in all invasive species control programs.

• Insure better public oversight by creating two permanent public representative positions on the Interagency IPM Coordinating Committee reserved for environmental protection and environmental justice advocates.

• Provide legislative oversight by requiring IPM progress reports to the Legislature every 2 years based on verification, monitoring, metrics and analysis.

• Acknowledge IPM is about reducing risks, both from pests and pesticides, that it must be progressive and science-based, requiring:

* Continuous innovation, capacity building
* Need to engage and involve stakeholders and incorporate local knowledge
* Communication, elimination of borders and silos, employment of new technologies

The IPMCC Report lacks many of the required pathways and directions spelled out in statutory language. Use your public comments to call these areas out. Also you can refer to our chart comparing the legal requirements to the failure to comply.

What the law requires: USE SCIENCE, BENCHMARKS AND METRICS TO MINIMIZE RISKS: Report on and develop a set of performance metrics to adequately describe state agency and public university progress in “adopting pest management practices in a manner that minimizes risks to human health, non-target organisms, native fish and wildlife habitat, watersheds and the environment” as required in statute.

What the Report omitted: State agencies did not evaluate the pesticide used on public property, types of pesticides, reductions in pesticides, alternatives to pesticides, quantifiable reductions in pests and chemicals over time, etc.

Example: As an example of the lack of metrics and analysis of pesticides in the environment, some agencies are spraying pesticides that are listed as pesticides of concern on the DEQ Priority Toxics Focus List. These pesticides include glyphosate, atrazine and 2,4D. The report never addresses how state agencies adopt non-toxic alternatives as a strategy to keep pesticides on the State’s own Toxics Focus List out of our streams and rivers to reduce environmental and public health risks.


What the law requires: PRIORITIZE CHILDREN’S HEALTH, ELDER HEALTH AND PUBLIC HEALTH: Include strict metrics, policies and procedures to protect children and the health other vulnerable populations. Pesticide exposure in children is especially problematic, given the vulnerability of their still-developing neurological systems.

What the Report omitted: The Report does not have a single reference to children’s health, elder health or vulnerable communities. Without specifics, without goals and benchmarks, without any metrics, the IPMCC has skirted the requirement to protect the health and welfare of children and other vulnerable populations.

Example: Oregon State University developed the Low-Impact Pesticide List for our public schools, K-12 and college campuses, but their list includes pesticides that are carcinogens and endocrine disruptors. This ill-conceived list does not protect school children.


What the law requires: FOLLOW OREGON’S ENVIRONMENTAL JUSTICE POLICIES: Adhere to Oregon’s Environmental Justice Policies. This IPMCC Report fails to recognize the connections between the protecting human health and environmental justice which protects vulnerable Oregon individuals and communities. Those who bear the greatest burden of exposure are the communities and individuals identified in Oregon’s Environmental Justice policies.

What the Report omitted: The Oregon Environmental Justice Task Force, which guides state agency practices, wrote a 2012 letter to the Governor’s office “acknowledging that exposure to pesticides and other toxic materials is of long-standing concern to communities of color and low-income communities” and asking State agencies to “make specific provisions to include environmental justice criteria in their mechanism to report to legislature.”

Example: The IPMCC never once discussed nor followed the EJTF recommendation to “investigate environmental justice implications and account for them when setting priorities and strategies for reducing pesticide exposure and finding alternatives to toxics.”


What the law requires: Control practices selected and applied to achieve desired pest management objectives in a manner that minimizes risks to human health, non-target organisms, native fish and wildlife habitat, watersheds and the environment.

What the Report omitted: The report skirts around mentioning protecting non-target living things from pesticide applications. Only the DEQ mentioned the necessity of understanding water quality impacts without suggesting actual action steps.

Example: ODOT sprays tank mixtures of pesticides along state highways that are adjacent to rivers and protected public lands. There is a sordid history of ODOT poisoning people and killing trees, including nearly 2,000 Ponderosa pine trees in Central Oregon. The report should honestly report these deficiencies and the State IPMCC should resolve to change agency practices to prevent any re-occurrences.

TELL YOUR STORY! Have you had a positive or negative experience with pesticides or pests related to the practices of any of the following state agencies? Tell you story!

• State Department of Agriculture [including the control of noxious weeds]
• State Department of Fish and Wildlife
• Department of Transportation
• State Parks and Recreation Department
• State Forestry Department
• Department of Corrections
• Oregon Department of Administrative Services
• Department of State Lands
• Department of Environmental Quality
• Oregon Health Authority
• Public universities for building and grounds maintenance


CHART: Comparison of Statutory Requirements and the State IPM Coordinating Committee’s 2018 Report (PDF)

Case Studies