Special Concerns about Chlorpyrifos Review

Thus far, EPA has shown an unusual amount of deference to pesticide opponents who have been pressuring the Agency to speed up its established schedule for review of chlorpyrifos. This is affecting the entire review process and has created the potential for flawed regulatory policy as a result of hasty decision making.

For example, in response to issues raised in a petition and subsequent lawsuit filed by the Pesticide Action Network of North America (PANNA) and the Natural Resources Defense Council (NRDC), EPA has shortened the amount of time the Agency will devote to producing a final chlorpyrifos human health assessment.

This raises legitimate concerns among many stakeholders that EPA’s review schedules are now being driven by pesticide opponents, to the detriment of other interests.

Due to the complexity of the draft chlorpyrifos assessment, the precedent-setting application of new EPA policies, and the importance of chlorpyrifos to U.S. agriculture, an extension of the standard 60-day comment period has been requested by Dow AgroSciences to allow sufficient time for public comments to be submitted.  We are asking EPA to allow another 60 days for public comments on this first substantive human health assessment prepared as part of the Registration Review program.  EPA has already granted 60-day public comment period extensions for the first substantive environmental assessments released as part of Registration Review, and we feel it very important that the Agency not rush through the first human health assessment due to interference and pressures by pesticide opponents for hasty decision-making.