Stop Cause Marketing on Toxic Pesticide Products
You can submit your letter online at http://www.regulations.gov by entering Docket # EPA-HQ-OPP-2007-1008, or mail to: Office of Pesticide Programs (OPP) Regulatory Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.
March 21, 2008
Office of Pesticide Programs (OPP)
Regulatory Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave., NW.
Washington, DC 20460-0001
Re: Draft Guidance for Pesticide Registrants on Label Statements Regarding Third-Party Endorsements and Cause Marketing Claims (EPA-HQ-OPP-2007-1008)
To Whom It May Concern:
I appreciate the opportunity to comment on the proposed rule concerning label statements regarding third-party endorsement and cause marketing claims. EPA should prohibit such labeling claims and reject the proposed guidance for several reasons, public health and safety being not the least of these.
To associate a pesticide, through its product label with an organization that implies protection of public health, safety or the environment, lends a false sense of safety to that product, misleading users on its hazardous ingredients and the need for strict label compliance. The proposed guidance goes against the very language of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), section 136a(c)(9),which states that labeling “shall not be false or misleading, shall not conflict with or detract from any statement required by law or the Administrator as a condition of registration, and shall be substantiated on the request of the Administrator.” EPA has established no justifiable reason for changing its current position that, “Symbols implying safety or nontoxicity, such as a Red Cross or a medical seal of approval (caduceus)” may not be used on pesticide labels.
Not only does the EPA proposal
violate established law, but it misleads consumers to assume a product
is not toxic. The presence of such a cause marketing symbol also detracts
from warning language on the label, or may confuse consumers who either
do not or cannot read the full label. This puts vulnerable populations,
such as non-English speakers and children, at risk. For this reason, we
believe EPA should be concerned about placing logos of organizations that
provide services to or protect vulnerable population groups (such as children,
the elderly or those with illnesses that can be caused or exacerbated
by pesticides) and the environment.|
We appreciate your consideration of our concerns.