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July 3, 2002

OPP Public Regulatory Docket (7502C)
Docket OPP-34237C
U.S. Environmental Protection Agency
1200 Ariel Rios Building
Washington, DC 20460

Re: Revised Risk Assessments and Related Documents for the Triazine Pesticide, Atrazine

Dear Madam/Sir:

Thank you for the opportunity to comment on the revised risk assessments and related documents for the triazine pesticide, atrazine. These comments are submitted on behalf of Beyond Pesticides and its membership. Beyond Pesticides is an organization committed to pesticide safety and the adoption of alternative pest management strategies that reduce or eliminate a dependency on toxic chemicals. To that end, we would like to use this opportunity to comment on risk mitigation measures for atrazine.

I. Atrazine Poses Unreasonable Risks to Human Health

Atrazine is the most widely used herbicide in the United States and applied by farmers in the Midwest and used in residential lawn management in much of the southeastern U.S. Due to the dangers on humans and the environment associated with its routine use and production, atrazine must be immediately banned and all tolerances revoked. Some of these dangers are as follows:

Atrazine is a Powerful Endocrine Disruptor

· Hayes et al. found that at levels commonly found in rivers, atrazine causes sexual hermaphroditic deformities in frogs.
· Pesticides at low concentrations interfere with the production and activity of sex hormones in salmon, causing decreases in the production of sperm.
· Porter et al. found synergistic effects in mice exposed to aldicarb, atrazine, and nitrate at levels of contamination within the range often encountered in U.S. water supplies.

U.S. EPA
PAGE TWO
July 3, 2002A

· USGS National Water Quality Assessment Study found alterations in sex steroid hormones and vitellogenin in blood of wild carp that appear to be related to certain chemical groups including atrazine disolved in river water.

Atrazine Causes Cancer in Rats and is Linked with Cancer in Humans

· Atrazine has been shown to cause cancer in the mammary glands of rats.
· Studies have linked atrazine exposure to breast cancer in human females.
· Donna et al. found that woman exposed to triazine pesticides had an elevated relative risk (RR) of 2.7 for malignant epithelial ovarian tumors.
· A study conducted by Syngenta found a statistically significant increase in prostate cancer among longtime workers at its St. Gabriel LA atrazine production facility.
· Several studies have found a possible risk for Non-Hodgkin's lymphoma to be associated with atrazine exposure.

II. Risk Mitigation Measures for Atrazine Use

Any continued use of atrazine must be strongly controlled and total consumption must be reduced. Suggestions for measures that would reduce potential exposure to atrazine and therefore reduce risk are as follows:

Strengthen and Enforce Federal Drinking Water Standards for Atrazine

· 97% of surface drinking water systems in midwestern states show atrazine contamination.
· 10.7% of surface water systems tested in an EPA cross section had atrazine levels that exceeded the Maximum Contaminant Limit (MCL).
· EPA Health Effects Division's Revised Preliminary Human Health Risk Assessment for atrazine (dated 1/19/2001) identified 24 out of 28 tested community water systems using surface water contained seasonal chlorotriazine residues exceeding levels of concern for infants and children.
· Using yearly averages for atrazine contamination in drinking water underestimates seasonal acute exposure.

Immediately Ban All Residential Use of Atrazine

· Children face unnecessary exposure to atrazine when applied to lawns.

U.S. EPA
PAGE THREE
July 3, 2002


· In 1990, the EPA classified atrazine as a Restricted Use Pesticide (RUP), which included label amendments that reduced application rates for agricultural uses and limited the maximum annual application rate for industrial weed control. It also restricts the sale and use to certified applicators or persons under their direct control.
· Even as an RUP atrazine containing lawn care products can still be purchased over the counter for unsupervised residential use.
· Home use cannot be monitored for safe use or handling.
· A Minnesota Department of Agriculture survey discovered that lawn herbicides were found in 80% of the storm runoff events sampled between April and October.

III. Alternatives to Atrazine are Widely Available
The continued use of atrazine represents an "unreasonable risk to man or the environment" when "taking into account the economic, social, and environmental costs and benefits of the use" of the pesticide. (Federal Insecticide, Fungicide and Rodenticide Act [(FIFRA), Sections 2(bb) and 3(c)5(D)] Given the availability of alternative pest management practices that incorporate alternative cultural practices and/or less toxic pest management products, including other registered pesticides, the agency has a statutory duty to revoke all registrations of atrazine products. To the extent that EPA assumes the benefits of atrazine in the marketplace, the agency is not fulfilling its statutory and regulatory duty to evaluate benefits in light of risk criteria being exceeded. Certainly, a review of the literature and an inventory of field experience in integrated pest management and organic agriculture evidence the viability of alternative practices that do not use atrazine. If EPA is unable to access this literature and field experience, Beyond Pesticides/NCAMP would be happy to assist in this process. Suffice it to say, EPA fails to meet its legal responsibility under FIFRA in this case if it allows any continued use of atrazine without making a showing that alternatives to atrazine are not viable.

Under the Food Quality Protection Act (FQPA), EPA is prohibited from issuing any tolerances for atrazine if the chemical exceeds the "reasonable certainty of no harm" standard. The data cited here, in other public comments, and in other literature not cited here show that atrazine exposure in the aggregate, and in combination with other chemicals that have a common mechanism of effect, exceed the risk criteria established by the law. EPA's own description of FQPA states the following:
U.S. EPA
PAGE FOUR
July 3, 2002

Health-Based Safety Standard for Pesticide Residues in Food
The new law [FQPA] establishes a strong, health-based safety standard for pesticide residues in all foods. It uses "a reasonable certainty of no harm" as the general safety standard:
· Sets a single, health-based standard, which eliminates longstanding problems posed by multiple standards for pesticides in raw and processed foods;
· Requires EPA, when setting tolerances, to consider all non-occupational sources of exposure, including drinking water, and exposure to other pesticides with a common mechanism of toxicity.

Thank you for this opportunity to comment on the revised risk assessments and related documents for the triazine pesticide, atrazine, and, for your consideration of the substantive points made above. We expect that EPA will carry out its statutory and regulatory responsibility and move to cancel the registration of atrazine, including all formulations that contain atrazine, and revoke all atrazine tolerances. We further expect that EPA will take the utmost care in protecting our health and the health of our environment.

Sincerely,

Jessica Lunsford
Program Associate

Jay Feldman
Executive Director