- SAMPLE LETTER -
July 12, 2000
and Records Integrity Branch
Re: Public Comments in Response to Reregistration Eligibility Decision, Preliminary Risk Assessment, Diazinon; Control Number OPP-34225
Dear Sir or Madam:
Thank you for the opportunity to comment on the preliminary risk assessment of the Regregistration Eligibility Decision (RED) Document for the organophosphate diazinon. A RED for diazinon should be issued only if data on diazinon and its contaminants, metabolites and the inert ingredients in its formulations are complete and support reregistration under the standards of authorizing legislation and corresponding regulations.
The identified data gaps and the excessive risks of exposure to diazinon preclude EPA from abandoning the tenfold margin of safety required by the Food Quality Protection Act (FQPA). Because diazinon is one of the most widely used insecticides, the fifth most commonly used pesticide by homeowners alone, it represents a significant source of organophosphate exposure in non-occupational settings. Since all organophosphate pesticides act on the body in similar ways and their effects are additive, it raises questions about multiple exposure to these chemicals through the many uses in and around homes and food production.
According to the risk assessment, there are many dangers associated with the current use of diazinon, including occupational risks, residential risks, accidental exposure, and numerous environmental hazards. There is a particular concern for the following residential handlers: residential post-application exposures; toddlers, following lawn and indoor crack and crevice treatments; and workers who apply or prepare the pesticide or work in greenhouses within 12 hours of application.
A memo written by a Health Statistician with the Health Effects Division in the Office of Prevention, Pesticides, and Toxic Substances, EPA, stated that 11,808 unintentional diazinon residential exposures were reported to Poison Control Centers from 1993-1996. That memo also stated diazinon is one of the leading causes of acute reactions to insecticide use reported as poisoning incidents in the U.S. And EPAs now defunct Pesticide Incident Monitoring System reported 903 diazinon related human poisonings between 1966-1980.
Although diazinon use on golf courses and sod farms was cancelled in 1988, wildlife mortalities due to diazinon exposure continue. According to the risk assessment, the Environmental Fate and Effects Divisions Ecological Incidents Database has documented 300 incidents of wildlife mortality, mostly birds, which is approximately 10% of all ecological incidents in the database. The risk assessment also stated that the endangered species level of concern is exceeded for wildlife, aquatic life and terrestrial plants in semi-aquatic areas for all currently registered uses and application rates of diazinon.
The EPA should take immediate steps to file a final determination and notice of intent to cancel and deny application for reregistration of pesticide products containing diazinon. It is unacceptable to phase-out diazinon and allow its use to continue while existing stocks exist. Exposure to diazinon is an imminent hazard, given its widespread use in and around homes, schools and our communities. My child will get sick when exposed to this chemical. I do not want a repeat of what happened with chlorpyrifos.