Petition to Revoke All Tolerances and Cancel All Registrations for the Pesticide Chlorpyrifos; Notice of Availability

December 17, 2007 Steven Bradbury, Director Special Review and Reregistration Division Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency (EPA) 1200 Pennsylvania Avenue NW Washington, DC 20460-0001 RE: EPA-HQ-OPP-2007-1005, Petition to Revoke All Tolerances and Cancel All Registrations for the Pesticide Chlorpyrifos Dear Mr. Bradbury: The American Farm Bureau Federation (AFBF) urges EPA to deny the petition received from the Natural Resources Defense Council (NRDC) and Pesticide Action Network North America (PANNA) requesting revocation of all tolerances and cancellation of all registrations for the pesticide chlorpyrifos. We believe EPA appropriately evaluated the use of the pesticide, including establishing mitigation measures, during re-registration and the issuance of the 2006 Registration Eligibility Decision (RED). NRDC and PANNA claim EPA did not consider the full spectrum of potential risks. Their claim is not supported by the scientific record on which the RED is based. EPA?s reassessment of chlorpyrifos is scientifically sound. EPA properly and thoroughly evaluated the following alleged deficiencies: the difference in susceptibility to chlorpyrifos across human populations and life stages; the endocrine disrupting effects; cancer risk data and cumulative effects. Chlorpyrifos provides is a critically important crop protection tool for a wide variety of farms, including: corn, specialty crops and ornamentals. For many of these uses, there are few if any effective, reliable alternatives. AFBF strongly urges EPA to deny NRDC and PANNA?s request. The revocation petition is untimely based on chlorpyrifos? expected review in 2008 and, most importantly, it is unjustified based on available science. Sincerely, Mark Maslyn Executive Director AFBF Public Policy