October 7,
2002
Public Information and Records Integrity Branch
Information Resources and Services Division (7502C)
Office of Pesticide Programs
U.S. Environmental Protection Agency
Rm. 119, Crystal Mall #2, 1921
Jefferson Davis Hwy., Arlington, VA
RE: Docket ID number OPP-2002-0196 -- Diazinon; Receipt
of Requests for Amendments, and Cancellations
These comments are submitted on behalf of the
Children’s Environmental Health Network (the
Network), Consumers Union of United States, Inc. (CU),
and the Institute for Children's Environmental Health
(ICEH). These organizations welcome the opportunity to
comment on the requests received by the Agency to delete
certain uses and to cancel certain registrations for the
organophosphorus pesticide diazinon.
The Network is a non-partisan and multi-disciplinary
national project whose mission is to protect the fetus
and the child from environmental hazards and to promote a
healthy environment. The Network’s three areas of
concentration are education, research and policy.
Consumers Union is a nonprofit membership organization
chartered in 1936 to provide consumers with information,
education and counsel about goods, services, health, and
personal finances and to initiate and cooperate with
individual and group efforts to maintain and enhance the
quality of life for consumers. Consumers Union’s
income is solely derived from the sale of Consumer
Reports, its other publications and from noncommercial
contributions, grants and fees.
The Institute for Children's Environmental Health (ICEH),
founded in 1999, is a non-profit, non-partisan
educational organization working to ensure a healthy,
just and sustainable future for children and the planet.
ICEH's primary mission is to foster collaborative
initiatives to reduce and ultimately eliminate
environmental exposures that can undermine the health of
current and future generations.
Our organizations applaud the proposed elimination of all
permitted indoor uses of this pesticide. The Network
submitted comments in July 2000 on the Health Effects
Division’s (HED) April 12, 2000 memorandum on
“DIAZINON. Revised HED
Preliminary Human Health Risk Assessment for the
Reregistration Eligibility Decision (RED) D262343. PC
Code: 057801. List A Case No. 0238” (HRA) and March
23, 2000 memorandum on “Occupational and Residential
Exposure Assessment and Recommendations for the
Reregistration Eligibility Decision Document for
Diazinon” (ORE).
We have serious concerns regarding children’s
exposure to this pesticide, especially related to indoor
uses. The EPA exposure assessments referenced above
provide ample evidence that the extent of children’s
exposure to diazinon from home, lawn and garden uses is
excessive and makes a case that this pesticide cannot be
used safely in these settings.
The EPA examined a number of “likely use
scenarios” for this pesticide; in these scenarios,
children’s potential exposures to diazinon resulting
from indoor treatments were unacceptable. For example:
“Children’s postapplication short-term dermal
exposures . . . result in MOEs (or “margin of
exposure”) less than 100. For children, the
inhalation exposure, based on chemical-specific data,
results in a MOE of 1.2.” (In this scenario, an
“acceptable” MOE would be 100 or above; the
larger the number the better.) Other concerns that were
identified include:
þ “Toddlers are the most highly exposed subgroup
following lawn and carpet treatments through direct
dermal exposures (crawling) and oral exposures
(hand-to-mouth).”
þ Air monitoring data showed the presence of diazinon at
significant levels in residential air in homes in both
northern and southern areas.
þ Diazinon was found in a variety of media.
“Diazinon has been detected in influent and effluent
from Publicly Owned Treatment Works (POTWs) indicating
that diazinon is entering sewer systems in urban areas as
a result of residential uses. Diazinon has also been
detected in air, rain, and fog in California.”
“In general, diazinon was the most frequently
detected insecticide in surface water in the NAWQA
program. It is detected more frequently and at higher
concentrations in samples from urban sites than at
agricultural sites.”
þ “About 15% of households (in EPA’s one-time
survey of homeowner pesticide usage) reported using
diazinon. Of those, approximately 23% of all applications
were made indoors, most commonly to the kitchen.”
Although incidence of ingestion and poisoning reports
provide only limited evidence about exposure, the overall
incident experience of diazinon offered a telling
perspective about widespread consumer use and its
widespread presence in residential settings:
þ “Diazinon ranked 5th as a cause of systemic
poisoning in California from 1990 through 1994.”
“A report of all hospitalized cases in California
for 1982 through 1994 ranked diazinon first as the
leading cause of hospitalization. . . Among the
accidental hospitalized cases most occurred among
homeowners who misused the product or left it within the
reach of very young children.”
þ The data presented on the frequency and pattern of
diazinon poisonings indicated widespread use and presence
in the home. For example: “HED concludes that the
majority of the reported incidents of acute reactions to
diazinon, reported as "poisoning incidents",
occur in the home.”
Our organizations are also concerned about exposure to
diazinon’s degradates. The Agency’s
Environmental Fate and Effects Division Environmental
Risk Assessment (science chapter) for diazinon found that
“in addition to adverse effects resulting from
exposure to parent diazinon, terrestrial vertebrates may
be exposed to the environmental degradates, diazoxon and
oxypyrimidine. . . The toxicity of these degradates to
terrestrial vertebrates is unknown, although submitted
human health effect data implies that diazoxon may be
more toxic than parent diazinon.”
These facts and others raised major and extremely
significant concerns about the impact on human health of
the more than 6 million pounds of diazinon used annually
in the United States
We believe that the proposed registration cancellations
and use deletions will be an important step toward
lowering children’s exposures to this pesticide.
Other Steps
Children in Farm Communities: We are concerned that these
actions will not begin to address the disproportionate
exposures to diazinon by children who live in farm
communities where diazinon is used. EPA has yet to adopt
policies that will assure that this large subgroup of
children are considered in reassessments of this and
other pesticides. All children -- not just urban children
-- deserve adequate protection from potentially harmful
pesticide exposures. Until these children are considered
in risk assessments, we believe that the EPA is not
following through with the requirement to assess
aggregate risks of pesticides to children.
Existing Stocks: Our organizations object to the
continued manufacture of these products for export.
First, this lowers protection for US children since such
pesticides can be illegally reimported for use in the US.
For example, just two years ago, illegal household
formulations of aldicarb were found in the US. These had
been smuggled from other countries. Second, this assures
the continued exposure of children in other countries to
this compound merely because of the accident of their
birth. If this nation has come to agreement that these
products’ uses are no longer deserving of support in
the United States, how can we defend selling them to
others? It is highly unlikely that these pesticides can
be used more safely in developing countries than in the
US. Our organizations strongly urge the Agency to use any
means possible to stop the manufacture of these products
in the US.
Tolerance Revocation: The Agency’s notice of these
actions includes a list of requests to amend the
registrations of their pesticide end-use products
containing diazinon to delete certain uses from certain
products. The crops affected include bananas, celery,
cucumbers, citrus, potatoes and many more. However, the
notice did not indicate that the related tolerances for
these uses would also be revoked. Given that these
products apparently are being permitted to be made for
export (see above), withdrawing these uses without also
revoking their tolerances on these crops will not protect
U.S. children from imported produce treated with these
products. Our organizations urge that EPA revoke these
tolerances as soon as possible, taking into consideration
flow through of food that contains these residues due to
legal use prior to these actions being taken.
Garden and Lawn Uses: As outlined above, the myriad
concerns about children’s exposure to diazinon are
not limited to exposure resulting from indoor uses.
Exposures due to lawn and other outdoor uses are a potent
source of exposure.
þ “Diazinon has a wide variety of homeowner uses
including lawn treatments, spot treatments, and indoor
carpet treatments. Diazinon is applied by many methods
including spray equipment, and granular spreaders.”
“EPA’s one-time survey of homeowner pesticide
usage found that diazinon was most frequently applied
outdoors by the general public. About 15% of households
reported using diazinon. Of those, approximately 23% of
all applications were made indoors….”
Since an estimated 77% of household uses are for lawns
and gardens, concerns about children’s exposure to
this pesticide around the home will continue until these
uses are discontinued as well. Infants and young children
have much greater potential exposure to pesticides in
lawn and garden use and these are around the environment
of children, and can accidentally be ingested. Thus, our
organizations not only strongly support the cancellation
of all indoor uses, we also strongly urge the Agency to
also immediately eliminate all lawn and garden uses.
On-going Cumulative Risk Assessment Re-evaluation: We
have previously urged the Agency to assure that its
approaches to conducting cumulative and aggregate risk
assessments reflect the new science and data that will
clearly emerge as the Agency meets the challenge of
regulating based on cumulative exposures. Our
organizations are specifically concerned with the example
the Agency is providing in its process of moving forward
with organophosphorus pesticides (OPs). On one hand, the
Agency has issued a cumulative risk assessment (CRA) for
the OPs, yet it is issuing use and tolerance decisions on
individual OPs without clearly indicating how these
individual decisions relate to the CRA or when an updated
CRA, reflecting these changes, will be issued,.
The impact of the cancellation of certain OP uses must be
examined. For example, in the OP CRA, the Agency makes
the implicit assumption that farmers losing the chance to
use a canceled OP will not switch to another OP. Clearly,
some shift in acreage from canceled OPs to still
registered ones is occurring and will continue to occur.
Similarly, the impact of canceling indoor uses of
diazinon while allowing indoor uses of other OPs raises
the question of whether these cancellations will result
in a net decrease of OP exposures, or just a switch from
the OP diazinon to a different organophosphorus
pesticide.
At the same time, new science and data are emerging which
will bring new understanding about the toxicology and
exposure levels of these pesticides. For example, we
anticipate that new information related to down
regulation of muscarinic receptors and decreased brain
DNA synthesis in addition to information about inhibition
of brain acetylcholinesterase will demand a reassessment
of the CRA in the next few years.
Results of future OP-CRAs will be critical in assessing
the degree of progress, or slippage, made in the
attainment of cumulative OP risk reduction goals. OP-CRA
results should serve as an aggregate benchmark of the
adequacy of risk mitigation measures imposed to date. If
the desired and hoped for degree of risk reduction does
not materialize, EPA should then impose another round of
risk mitigation measures targeted at known-risk drivers.
OP-CRA results should be updated annually, incorporating
new residue, usage and exposure data and any updated
toxicological information. As a part of this process, the
Agency should continue to solicit public comment.
We have urged the Agency to move forward to mitigate the
risks that have been identified in the OP CRA; in
particular, the Agency should move promptly to reduce
exposures to children from OP and carbamate pesticides.
In so doing, it should make it clear, perhaps by granting
only time limited tolerances for remaining uses, that
this is a work in progress. Our organizations reiterate
this call. We continue to ask for a schedule under which
EPA will incorporate more complete data on developmental
neurotoxicity and aggregate exposures to children in its
cumulative assessment. In the interim, we would urge
prompt and decisive action to lower exposures to OP and
carbamate pesticides to children.
Conclusion
Our organizations appreciate the opportunity to comment
on these important issues. We commend the Agency for its
prompt action on these matters and we urge action on the
steps listed above.
Sincerely,
| Daniel Swartz |
Adam J. Goldberg |
Elise G. Miller |
| Executive Director, Children's
Environmental Health Network |
Policy Analyst, Consumers Union |
Executive Director, Institute for Children's
Environmental Health |
Cc: The Honorable
Christine Todd Whitman, Administrator, EPA
Mr. John Howard, Council on Environmental Quality
Mr. Steven Johnson, Office of Prevention, Pesticides
& Toxics
Ms. Joanne Rodman, Acting Office Director, Office of
Child Health Protection
|
