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Governmental Watchdogging Pyrethrins / Pyrethroids: cumulative risk assessment

EPA has approved Beyond Pesticides request to extend the comment period for the cumulative risk assessment for pyrethrins/pyrethroids until February 8, 2012. Beyond Pesticides will be submitting comments for this assessment and hopes your organization will also be able to sign on or submit your own comments. We will share comments for sign-on the second week in January. If you would like to provide input, please contact Nichelle Harriott at [email protected].

Pyrethroids are a widely used class of insecticides used for mosquito control and various insects in residential and agricultural settings. Pyrethroids are highly neurotoxic and have been linked to cancer, endocrine disruption, suppression of the immune system, and various reproductive effects. Despite this, EPA concluded that the assessment supports consideration of registering additional new uses of these pesticides, potentially opening the flood gates for manufacturers to bombard the market with more pyrethroid pesticides, endangering the health of the public.

Background

On November 9, 2011, EPA issued its cumulative risk assessment for the pyrethroid class of insecticides, concluding that these pesticides “do not pose risk concerns for children or adults,” ignoring a wealth of independent data that links this class of chemicals to certain cancers, respiratory and reproductive problems, and the onset of insect resistance.

Most troubling is the agency’s decision to reduce the Food Quality Protection Act (FQPA) protective safety factor from 10X (an additional margin of safety of 10 times) to 1X for children and adults over six years, and to 3X for children under six years of age. Given that children are especially sensitive to the effects of pesticides, this reduction in the special safety factor is egregious, especially since some studies find low-dose, short-term exposures to synthetic pyrethroids delays the onset of puberty at doses two times lower than EPA’s no observable effect level. Certain pyrethroids such as permethrin and bifenthrin are classified as possible carcinogens and have been identified as endocrine disruptors, data which EPA has ignored.

The agency claims that more pyrethroid registrations may help combat recent pervasive pest problems, such as stink bugs and bed bugs, even though this class of chemicals is already known to be ineffective against these pests due to growing resistance issues compounded with continued pesticide use. Already, bed bugs have developed the ability to defend themselves against pyrethroid pesticides, with a required dosage of as much as 1,000 times the amount that should normally be lethal.

In addition to human health effects which this cumulative risk assessment addresses, pyrethroids are also persistent in the environment and adversely impact non-target organisms. Pyrethroid contamination has been documented in streams and sewage sludge around the country. Pyrethroid residues even at relatively low concentrations (10-20 parts per trillion) in river and creek sediments have been shown to be toxic to bottom dwelling fish and sensitive aquatic organisms.

It is clear that given the health risks associated with pyrethroid uses, including the onset of insect resistance, increased use of synthetic pyrethroid use is hazardous and unnecessary.

Comments can be submitted at docket number: EPA-HQ-OPP-2011-0746 at Regulations.gov.