Comments to government agencies by Beyond Pesticides

For original listings and background information, see EPA Comments Archives

1. General Pesticide Comments
2. Genetic Engineering
3. Lawns and Landscapes
4. Organic Food
5. Water & Mosquito Management
6. Wood Preservatives

1. General Pesticide Comments

• Proposed rulemaking to increase public availability of the identities of inert ingredients in pesticide products (April 23, 2010)
• Insect Repellent-Sunscreen Combination Products (May 23, 2007)
• Review of Data Relevant to Effects of Atrazine on Amphibians<; NRDC and friends (May 4, 2007)
• Chloropicrin Risk Assessments (February 28, 2007)
• Petition on “Cause-Related Marketing”/Fund Raising Logos on Pesticide Labels (February 7, 2007)
• Malathion Reregistration Eligibility Decision; PANNA and friends (January 29, 2007)
• Petition for Suspension and Cancellation of M-44 Sodium Cyanide Capsules & Sodium Fluoroacetate Livestock Protection Collars; Sinapu and friends (January 24, 2007)
• Piscicide Applications on National Forest System Lands; Beyond Pesticides and Defenders of Wildlife (January 16, 2007)
• Food Packaging Treated with a Pesticide (January 5, 2007)
• Organic Arsenical Herbicides Reregistration Eligibility Decision (December 7, 2006)
• EPA's Interim Reregistration Eligibility Decision (IRED) for carbofuran; NRDC and friends (November 20, 2006)
• CSPA Petition to Amend Certain FIFRA Section 25(b) Pesticide Products (November 13, 2006)
• Pyrethrins Reregistration Eligibility Decision (October 24, 2006)
• Resmethrin Reregistration Eligibility Decision (October 24, 2006)
• Organophosphate Cumulative Risk Assessment; PANNA, Farm Worker Pesticide Project and friends (October 2, 2006)
• Permethrin Reregistration Eligibility Decision (September 26, 2006)
• Malathion Revised Human Health Risk Assessment; NRDC and friends (November 22, 2005)
  (see also Beyond Pesticides malathion comments - July 10, 2000)
• Data requirement for Conventional Chemicals; Proposed Rule (September 7, 2005)
• Captan Cancer Classification Change; NRDC and friends. (January 24, 2005)
• Rodenticides cluster ecological risk assessment; Steve Sheffield, PhD, and friends. (January 21, 2005)
• Carbaryl Interim Reregistration Comments with beekeepers, with NRDC and friends. (December 27, 2004)
• The Globally Harmonized System of Classification and Labeling of Chemicals, EPA White Paper. (December 3, 2004)
• Section 18 Exemptions streamlining proposal. (November, 2004)
• Advise to U.S. negotiators regarding Lindane in the North American Regional Action Plan (NARAP), by numerous Non-Governmental Organizations. See also "NGO Statement in Support of the Elimination of Lindane Use in North America". (September, 2004)
• 2,4-D risk assessment by Beyond Pesticides, NRDC, PAN and some 40 others. (August 23, 2004)
• Methyl Parathion reregistration by Farmworker Justice Fund, Beyond Pesticides, and others. Additional comments by Defenders of Wildlife and signed-on to by Beyond Pesticides and others. (August 2, 2004)
• Comments to EPA on the Proposed Counterpart Regulations affecting Endangered Species, by Beyond Pesticides and friends. (April 13, 2004) See also Comments on the Environmental Assessment by Defenders of Wildlife and friends. (July 23, 2004)
• Pesticide Tolerance of Sulfuryl Fluoride by Fluoride Action Network and Beyond Pesticides. (March 23, 2004) Read Daily News story.
• Application of Pesticides to Waters of the United States in Compliance with FIFRA by Beyond Pesticides and friends. (October 14, 2003)
• Guidance for Methodology for Assessing Low Toxicity Pesticide Chemicals Including Inert Ingredients (October 11, 2002)
• Revised Organophosphate Cumulative Risk Assessment (September 9, 2002)
• Atrazine Revised Risk Assessment (July 7, 2002)
• Exemption requests by the state of Louisiana for granular Carbofuran for rice water weevil (July 2, 2002)
• Spray and Dust Drift Label Statements for Pesticide Products (March 27, 2002)
• Chlorpyrifos (Dursban) Revised Risk Assessment (October 16, 2000)
• Proposed Guidance on Cumulative Risk Assessment of Pesticide Chemicals That Have a Common Mechanism of Toxicity (September 15, 2000)
• Diazinon Revised Risk Assessment (July 18, 2000)
• Malathion Revised Risk Assessment (July 10, 2000)

2. Genetic Engineering

• Genetically Modified BT Crops Reassessment (September 10, 2001)
• Scientific Advisory Panel in Response to Aventis Request for Genetically Engineered StarLink Corn Approval for Human Consumption (November 27, 2000)

3. Lawns and Landscapes

• 2,4-D risk assessment Phase 5 of 6 by Beyond Pesticides and friends. (March 14, 2005)
• Revised Environmental Guidelines for Responsible Lawn Care and Landscaping by Beyond Pesticides and nearly 20 other groups (January 27, 2005)
• 2,4-D risk assessment by Beyond Pesticides, NRDC, PAN and some 40 others. (August 23, 2004)
• Preliminary Lawn and Environment Guidelines by Beyond Pesticides. (June 14, 2004) See Daily News story.

4. Organic Food

• NOSB comments can be found on Beyond Pesticides' Keeping Organic Strong program page.
• Organic Rule (June 9, 2000)

5. Water and Mosquito Management

• "Pest Management and Fire Suppression Act" HR 1749. Action Alert. Grassroots Letter to Congress against CWA roll backs and Katrina Waiver Bills. BP Congressional Oral Testimony, BP Written Testimony - Appendices (September 29, 2005)
• Public Testimony to EPA and PPDC on EPA mosquito pesticide guidance (May 11, 2005)
• Application of Pesticides to Waters of the United States in Compliance with FIFRA by Beyond Pesticides and friends. (April 4, 2005)
• 'Labeling Statements on Pesticides Used for Adult Mosquito Control' by Beyond Pesticides and friends. (July 27, 2004). See Action Alert. See EPA Issued Guidance (March 3, 2005)
• Application of Pesticides to Waters of the United States in Compliance with FIFRA by Beyond Pesticides and friends. (October 14, 2003) . See EPA's original memo (includes references to relevant lawsuits).
• Letters to EPA Inspector General
  • Abuse of Authority and EPA’s “Labeling Statements on Products Used for Mosquito Control” (October 8, 2004)
  • Malathion and Labeling Statements on Adulticide Products (February 22, 2005)

6. Wood Preservatives

• Revised Risk Assessments for PCP, CCA, and creosote (June 16, 2008) by Beyond Pesticides and friends
• EPA Decision on Hexavalent Chromium and Memorandum (January 29, 2007)
• Registration of Acid Copper Chromate (ACC); Additional Comments by Beyond Pesticides and Healthy Building Network (December 22, 2006)
• Registration of Acid Copper Chromate (ACC); Petition to Cancel Uses & Report by Beyond Pesticides and friends (December 13, 2006)
• Human Hexavalent Chromium Testing by Beyond Pesticides (October 10, 2006)
• Request for Cancellation of All ACC Registrations by Beyond Pesticides and friends (July 5, 2006)
• Preliminary Risk Assessment for Pentachlorophenol by Beyond Pesticides, Toxics Action Center, Maryland Pesticide Network, New Jersey Environmental Federation, Texans for Alternatives to Pesticides, TEDX, Inc, Clean Catch, Northwest Coalition for Alternatives to Pesticides, Pesticide Free Zone Campaign and more (January 31, 2005)
• Risk Assessment on Wood Preservatives Containing Arsenic and/or Chromium by Beyond Pesticides. (May 17, 2004)
• Creosote Preliminary Risk Assessment. (February 3, 2004) See the Assessment.
• Non-Dietary Hazard and Exposure to Children from Contact with CCA-Treated Playground Structures and CCA-Contaminated Soil (October 23, 2001)
• Response to Reregistration Eligibility Decision of Pentachlorophenol (December 21, 1999)

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