July 12, 2000

The Honorable (full name)
United States Senate (or House of Representatives)
Washington, DC 20510 (or 20515)

Re: Reregistration Eligibility Decision, Preliminary Risk Assessment, Diazinon; Control Number OPP-34225

Dear Senator (or Representative) (last name):

            As part of the ongoing implementation of the Food Quality Protection Act (FQPA), the EPA has released a revised risk assessment of the Regregistration Eligibility Decision Document for diazinon, a highly toxic organophosphate insecticide. I am writing to request that you hold EPA accountable under the requirements of FQPA and the Federal Instecticide, Rodenticide, and Fungicide Act (FIFRA), to protect public health and the environment by canceling the uses of diazinon.

            The identified data gaps and the excessive risks of exposure to diazinon preclude EPA from abandoning the tenfold margin of safety required by 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 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. The risk assessment also reports that diazinon is one of the leading causes of acute reactions to pesticide use and that all indoor home and office uses should be considered for cancellation.

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 EPA’s 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 Division’s 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.

Diazinon presents unacceptable hazards and risks to public health and the environment. The EPA must 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.