Public Statement to EPA and Pesticide Program Dialogue Committee
PPDC Public Comments May 11, 2005
by Shawnee Hoover
In the background section of Pesticide Registration notice 2005-1 of March 9, 2005, EPA stated that the proposed changes to adulticide labels were presented to the PPDC and that “in general” PPDC agreed that the initial set of recommendations were “generally appropriate”. Although not all the objections that were later made through the public comment process were made in this PPDC forum, some of them were. Therefore, it is not accurate to say there was general agreement in the PPDC and in fact is a gross misrepresentation when public interest groups raised serious concerns that still have not been addressed.
I just want to make it very clear that public interest groups and several industries including those that are not otherwise represented here such as fishing associations, the honeybee industry and others object very strongly to the Agency’s proposal to change the labels of adulticides. The changes allow the environmental mitigation measures on the label to be overridden when the vague, widely subjective and undefined notion of a “public health threat” declared by vector control agencies (or state, tribal or local health agencies).
The addition of “vector control agency” to those that can declare a public health threat is extremely troubling. We believe it is vital that public health departments be integral to any decision to use adulticides.
Lastly and separately, I would like to remind the agency that in the face of uncertainty of the effects of this change on environment – the agency should be erring on the side of caution. There is no viable evidence to show that the use of adulticides reduces or prevents WNV incidents or illnesses. Furthermore, there is a severe dearth of real world studies on general efficacy in varying conditions of adulticides. Therefore, there really is no evidence that the use of adulticides results in a benefit to public health protection. As a group with thousands of members and partners in small and large localities all across the U.S., we are obligated to share with the agency that every mosq season since 1999, we receive countless reports of poor practices, including the sole reliance on adulticides without any surveillance, monitoring or attempt at larval control.
There are no standards for mosquito control and as I said in communities across the country, vector control agencies are using a wide range of practices that most would not believe to be prudent, including daily and weekly spraying in the same areas and for example, the use of chlorpyrifos (Kentucky) and naled (Colorado). It should not be forgotten that the policies being implemented by the agency will apply to the use of these adulticides known to be particularly hazardous and is in fact encouraging the use of adulticides rather than discouraging their use.