[Note: This submission is
listed as Federal Register Docket OPP-2005-0069-0007]
The following comments were
submitted to EPA by Fluoride Action Network Pesticide Project
in reference to the
June 1, 2005 - Federal Register:
Inert Ingredients; Proposal to Revoke 34 Pesticide Tolerance Exemptions
for 31 Chemicals
http://www.epa.gov/fedrgstr/EPA-PEST/2005/June/Day-01/p10680.htm
August 1, 2005
Email to <opp-docket@epa.gov>
Comments on Docket OPP-2005-0069 submitted by:
Ellen Connett
Fluoride Action Network Pesticide Project (FAN)
82 Judson Street
Canton NY 13617
Email: pesticides@fluoridealert.org
The Fluoride Action Network Pesticide Project (FAN) supports
EPA's proposal to revoke "tolerance exemptions" for
sodium fluoride (40 CFR 180.920) on the basis that fluoride bio-accumulates
in humans, wildlife, and fish, and is persistent in soil. FAN
believes EPA made a wrong decision to approve the original tolerance
exemption.
There is a major inconsistency with EPA's approach to fluoride.
For example, EPA identified fluoride as the toxicological endpoint
of concern in sulfuryl fluoride as a food fumigant. Yet, EPA has
approved its classification as a List 4B inert.
FAN has expressed its concerns to EPA regarding sodium fluoride’s
considerable adverse effects on bone, brain, male reproduction,
kidney, heart, thyroid, pineal, and lung.
In July 2005, EPA made available its schedule for Reregistration
and Tolerance Reassessment for several pesticides -- available
at http://www.epa.gov/pesticides/reregistration/decision_schedule.htm.
The expected release of a RED for sodium fluoride is August 2008.
Will the revocation of tolerance exemptions for sodium fluoride
in Docket OPP-2005-0069 remove it from the Reregistration and
Tolerance Reassessment schedule?
INERTS:
-- FAN strongly urges EPA to change its unscientific policy
on inerts. It is important for the public to have the most accurate
and updated information on the chemicals and substances used
in food production, and also for non-food purposes, such as
products used in the home, parks, playgrounds, schools, etc.
It is equally important for EPA to adopt transparency in all
matters that involve the public’s exposure to dangerous
substances via the foods they eat or the products they buy.
Inerts commonly [comprise] the largest percentage of a pesticide
product. However for the majority of "inerts" there
is little to no toxicological information available to the public.
The public is deprived of the right-to-know of the substances
they are exposed to when they buy certain products or eat certain
foods. This is a seriously flawed policy that needs to be changed.
-- For example: when the public reads petitions for pesticides
used in food production, information is presented only for the
active ingredient. However, the percent of the active ingredient
in the end-product is often less than one percent. The "other
ingredients" or "inerts" are kept "secret"
and yet commonly constitute the bulk of the pesticide product.
EPA needs to explain how the most relevant public comments can
be submitted on a pesticide petition without information available
on the other ingredients.
-- Toxicological studies must be performed on all "inerts"
that are used in pesticides. No chemical or substance should
be approved for food use without these studies. And these studies
need to be open to public comment.
In our support for the revocation of "tolerance exemptions,"
FAN has questions relating to other pesticidal uses of sodium
fluoride. Is sodium fluoride registered with EPA as an "active"
ingredient? Is sodium fluoride allowed to be used in pesticide
products, wood preservatives, adjuvants, or structural pest control
without EPA's approval? We request that EPA clarify the following:
NON AGRICULTURAL WEED CONTROL.
-- Is sodium fluoride approved by EPA for use in weed control
on Right of Ways? For example, the statistics for sodium fluoride
use in California in 2003 was 41,915 pounds. Of this amount,
41,835 pounds were used for weed control (Right of Way) - with
the highest use in Fresno County of 23,757 pounds. 80 pounds
of sodium fluoride were used for structural pest control.
-- The above are the most recently available statistics from
one year and from one state. Can sodium fluoride be used, without
US EPA approval, for weed control on Right of Ways? Does EPA
maintain statistics on the amounts of sodium fluoride used for
weed control in the US?
WOOD PRESERVATIVES.
-- Is sodium fluoride approved for use in wood preservatives?
Can sodium fluoride be used, without EPA approval, in wood preservatives?
For example, the following six products that contain sodium
fluoride are currently listed as "Active" in the US:
Product Name: Cop-r-plastic wood preserving compound
EPA Approval Date: November 30, 1992
US EPA Reg. No. 75341-5
Formulation: Ready-to-use solution
Manufacturer / Distributor: Osmose Utilities Services, Inc.(Buffalo
NY)
Uses: Fungicide
Pests: Wood pilings (soil contact nonfumigation treatment)
Location: Timbers (soil contact nonfumigation treatment) ,
Wood poles/posts (soil contact nonfumigation treatment) ,
Timbers (heavy wooden members) (soil contact nonfumigation
treatment) , Wood (soil contact nonfumigation treatment)
Product Name: Hollow Heart CF
EPA Approval Date: May 5, 2004
US EPA Reg. No. 75341-12
Formulation: Soluble concentrate
Manufacturer / Distributor: Osmose Utilities Services, Inc.
(Buffalo NY)
Uses: Fungicide
Pests: Wood rot/decay
Locations: Wood poles/posts (nonsoil contact nonfumigation
treatment), Wood pilings (nonsoil contact nonfumigation treatment),
Timbers (nonsoil contact nonfumigation treatment)
Product Name: Osmose Flurods
EPA Approval Date: August 10, 1995
US EPA Reg. No. 75341-6
Formulation: Pelleted/tableted
Manufacturer / Distributor: Osmose Utilities Services, Inc.
(Buffalo NY)
Use: Fungicide
Pests: Wood rot/decay
Locations: Timbers, Wood poles/posts, Wood cross-arms (nonsoil
contact nonfumigation treatment)
Product Name: Patox-lite
EPA Approval Date: December 4, 1987
US EPA Reg. No. 75341-4
Formulation: Impregnated materials
Manufacturer / Distributor: Osmose Utilities Services, Inc.
(Buffalo NY)
Use: Fungicide
Pests: Wood rot/decay fungi
Locations: Wood poles/posts (soil contact nonfumigation treatment)
Product Name: Sodium fluoride powdered
EPA Approval Date: July 14, 1964
US EPA Reg. No. 3008-58
Formulation: Formulation intermediate
Manufacturer/ Distributor: Osmose Inc. (Buffalo NY)
Use: Fungicide
Pests: No pests
Location: Formulating use only no site
STRUCTURAL PEST CONTROL.
-- As cited above, California statistics for sodium fluoride
use in 2003 includes 80 pounds for structural pest control.
Is sodium fluoride approved by US EPA for use in structural
pest control? Can sodium fluoride be used, without EPA approval,
for structural pest control?
ADJUVANT USE.
-- Are there other uses, such as "adjuvants" in pesticide
products, that sodium fluoride could be used, but which EPA
does not regulate?
-- What are the other uses that sodium fluoride is used that
EPA does not regulate? Would EPA please clarify.
TOTAL YEARLY AMOUNT OF SODIUM FLUORIDE
USED IN THE US FOR PESTICIDE USES.
-- Does EPA have information on the amount of sodium fluoride
used in the US, on a yearly basis, for pesticidal purposes,
such as in wood preservatives, that do not need their approval?
NOTE: This submission is also available online at http://www.fluorideaction.org/pesticides/comments.naf.aug.2005.html
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