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Public Information and Records Integrety Branch (PIRIB)
Office of Pesticide Programs (OPP)
US Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460 - 0001
Attention: Docket Number OPP - 2004 - 0049

EPA Docket ID OPP - 2004 - 0049
Public Comment on standards for pesticide containers and containment

Environment and Human Health, Inc. (EHHI) has been studying lawn-care pesticide labelling and packaging for a number of years. EHHI is a non-profit organization made up of nine members who are medical doctors, public health professionals and policy experts. Our website can be accessed at http://www.ehhi.org . EHHI's purpose is to protect human health from environmental harms through research, education and encouraging sound public policy.

In 2003, EHHI published a research report on The Risks of Lawn-care Pesticides where a chapter was devoted to inadequate packaging and labeling of lawn-care pesticide products. The report can be downloaded from our website in either full or summary form.

The findings of this report show that lawn-care pesticide packages were broken in almost ever store we went into. When store clerks were asked how the packages break, they replied that they break in every manner of transport. There was not one thing that caused the packaging to break, but instead, store clerks reported that many things caused the bags to break including just ordinary handling by customers. Please see pages 39 and 40 of our report for further information on this issue.

Because of the seriousness of the situation we wrote to all the manufacturers of the lawn-care pesticide products and asked them to please put their toxic products in better containers. Only the Scott Company gave us a thoughtful reply. They told us by letter that the lawn-care pesticide products are in packaging that is porous by design. That was not known to us, or many other people studying these issues, previously.

The fact that the packaging is porous by design explains why the stores that sell these products smell of pesticides. To make matters worse, many stores that now sell the lawn-care pesticides in these inadequate large bags, such as WalMart, CostCo, BJ's and KMart, also sell food products - and often the food is in very close proximity to the lawn-care pesticides.

The out-gassing and breakage of these large bags of lawn-care pesticides put the people who work in these stores at risk. Even clerks who do not work in the lawn-care pesticide aisles are at risk, as stores often pile these bags up next to check-out counters where the check-out clerks are exposed for eight hours at a time.

The containers of lawn-care pesticides must be made sturdier and must be made non-porous. The present situation is simply a disaster waiting to happen. We are hopeful that you will rewrite the container regulations for lawn-care pesticide products that will better protect the public from toxic pesticide exposures.

I am enclosing with this letter for your information:

1. A copy of our report: The Risks of Lawn-care Pesticides;
2. Copies of the letters sent to the presidents of the lawn-care pesticide products;
3. The Scott company's reply to our letter,
4. Five (5) pictures showing a sample of the broken bags of lawn-care pesticides found in
stores that EHHI researched.

Sincerely,

Nancy Alderman, President
Environment and Human Health, Inc.
http://www.ehhi.org