From: Robina Suwol
Date: 01 Aug 2006
Remote Name: 18.104.22.168
According to the U.S. Fish and Wildlife Service, all registered uses of carbofuran kill wildlife. Carbofuran is also extremely toxic to humans and continues to poison farmworkers. Carbofuran's manufacturer, the FMC Corporation, is trying to save an outdated pesticide that cannot be used safely and has no justification to remain on the market given viable alternatives. Please join Beyond Pesticides in telling EPA that carbofuran is an imminent hazard and it should cancel and immediately suspend all remaining uses.
EPA must make its re-registration decision on carbofuran by Thursday, August 3, 2006. The science shows that all uses must be cancelled, but FMC is lobbying EPA to try to water down this important decision. Send an email to EPA's Assistant Administrator for Prevention Pesticides and Toxic Substances (OPPTS), Jim Gulliford (firstname.lastname@example.org) before August 3rd and tell him that an immediate suspension, without a lengthy phase-out period, is the only justifiable EPA action considering the risks associated with this toxic pesticide.
When writing to Mr. Gulliford, consider the following points:
a.. Wildlife and Human Health Effects: The U.S. Fish and Wildlife Service has said that all legal uses of carbofuran kill birds, in violation of the Migratory Bird Treaty Act. Carbofuran is extremely toxic to people. Human risk assessments have been done three times and they show greater risks to farmworkers each time they are refined.
b.. EPA Politics: Given the recent uproar by EPA scientists, whose unions representing over 9,000 scientists, risk managers and other specialists sent a letter to EPA Administrator Stephen Johnson saying the agency's scientists are morally and professionally compromised by the Bush administration's partnership with the chemical industry, this is not the time let politics trump sound science.
c.. Regulatory Justification for Action: As part of its re-registration process required by law, EPA has found that carbofuran is extremely hazardous and presents unacceptable risks. This follows on EPA's 1991 Special Review that finds granular carbofuran is highly toxic to birds and led to the cancellation of many uses. It is well past time for the agency to take action to cancel all remaining uses of this pesticide.
If you have time for additional points:
a.. Prevents IPM: Integrated pest management (IPM) is not possible when carbofuran is used. Carbofuran kills all beneficial insects. According to the label, other crops cannot be planted until 10 months after an application, eliminating crop rotation as a pest management tool.
b.. Viable Alternatives: All crop uses can be substituted with organic methods or viable less toxic alternatives.
c.. Importation of Contaminated Crops: Cancellation by the U.S. will send a strong message to Canada, Mexico and the other countries still using this toxic pesticide. Immediately canceling food tolerances for carbofuran would have a huge impact on wildlife in countries that export food to the U.S. and would create a level playing field for U.S. farmers.
For more information, factsheets and past comments sent to EPA, see www.beyondpesticides.org.