Re: [MDOsprey] Pesticide Threat - Your Support Needed
David (dstrother@pop.dn.net)
Thu, 02 Sep 1999 19:16:36 -0400
Marcia Watson-Whitmyre's alert on chlorfenapyr is well taken. Here's
what it says within the web site for for EPA's Office of Pesticide
Programs ( http://www.epa.gov/pesticides/ where one finds info on
specific pesticides by entering the name in the search box on the
upper left):
Chlorfenapyr is a member of a new class of chemical compounds known as
"pyrroles"- a class which has a unique mode of action, clear economic
benefits to the cotton industry, and data indicating avian reproductive
effects.
OPP has concluded that the use of chlorfenapyr on cotton meets the
Food Quality Protection Act (FQPA) standard of a "reasonable certainty
of no harm" with respect to human health; and, that it has not been
found to be carcinogenic. In addition, chlorfenapyr has clear economic
benefits to the cotton industry because it can play an important role
in control of several important cotton pests. However, chlorfenapyr
appears to be persistent in the environment, and studies show a
potential adverse impact to wildlife, particularly birds. For these
reasons - and our limited experience with pyrroles - we believe this
chemical presents special issues for pesticide regulation. Accordingly,
we are taking this extra step of seeking public comment, of a specific
nature, on this chemicalīs human health and ecological risk, and
benefits
assessments before we make any regulatory decision.
All the material in the docket on chlorfenapyr can be reviewed at
http://www.epa.gov/pesticides/reg_assessment/toc.htm
EPA's Risk Assessment document
http://www.epa.gov/pesticides/reg_assessment/memoeco.pdf
concludes that "terrestrial wildlife dietary residues associate with
all label application rates present a substantial risk to avian
species both for acute lethal effects and impairment of reproduction.
The exposure opportunities for acute lethal effects occur for many
days following treatment. ...... Timing of chlorfenapyr applications
to the cotton crop coincide with the reproductive window of most of
the more than 50 species of birds that the registrant reports to be
associated with cotton fields."
At the bottom of that page, under "An Avian Ecological Risk Assessment
for Chlorfenapyr in Cotton" there are ten relevant documents submitted
by the maker of chlorfenapyr, American Cyanamid. Their Executive Summary
is at
http://www.epa.gov/pesticides/reg_assessment/pirate_7.pdf
which will require the use of the Adobe Acrobat Reader (which can be
downloaded free from Adobe's net site by clicking on the "Free Acrobrat
Reader" message near the top of the page) to access.....and be ready for
a long down-load of the 1284K document.
As for sending an e-mail to Browner....well, don't expect it to be read,
let alone have any impact. A hard copy to
Carol M. Browner, Administrator
US Environmental Protection Agency
Washington, DC 20460
showing copies to your Senators and Representatives will, in the long
run,
be far more effective.
David Strother
Bethesda
dstrother@pop.dn.net