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EPANonrulemakingEPA-HQ-OPP-2005-0162

Reregistration of Carbofuran

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Sep 10, 2025
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closed 6398d ago
Center for Biological Diversity filings
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Center for Biological Diversity filed 1 comment on this docket between Aug 23, 2005 and Aug 23, 2005. 60 other organizations filed here. The comment window closed 6398d ago.

What Center for Biological Diversity filed (1)

Aug 23, 2005· Comment submitted by Michael Fry, Ph.D.,Director of Pesticides and Birds Program,American Bird Conservancy,Peter Galvin,Conservation Director,Center for Biological Diversity et al.· EPA-HQ-OPP-2005-0162-0008

August 23, 2005 Public Information and Records Integrity Branch (PIRIB) (7502C) Office of Pesticide Programs Environmental Protection Agency 1200 Pennsylvania Ave., NW. Washington, DC 20460-0001 Attention: Docket ID Number OPP-2005-0162. Thank you for the opportunity to comment on the Reregistration Eligibility Science Chapter for Carbofuran Environmental Risk Assessment and Human Drinking Water Exposure Assessment (Docket ID Number OPP-2005-0162). These comments are submitted on behalf of the groups listed below, which collectively have a membership of more than 1.5 million members. These comments are limited to the risks to avian wildlife, and do not address the ground water or drinking water portions of the reregistration eligibility science chapter. The environmental risk assessment for carbofuran makes a compelling case for terminating all uses of this pesticide, based on the toxicity of legal pesticide use and kills of wild birds. The authors have compiled three lines of evidence to support conclusions of historical adverse effects of carbofuran use: a deterministic or screening-level risk assessment, a refined risk assessment, and field data. The refined probabilistic risk assessment reflects the screening-level deterministic risk assessment, with the conclusion that ?For all registered uses and labeled rates, all three lines of evidence support the conclusion that non-target birds and mammals are being exposed to carbofuran levels that result in direct mortality and that exposure to and mortality of non-target birds and mammals occurs frequently with carbofuran registered uses. The number of individuals and species affected increases with increasing application rates.? Therefore, there are NO uses of carbofuran that are safe for populations of wild birds. The executive summary of the report gives definitive estimates based on the refined risk assessment. ?Flocks of mallard ducks foraging in an alfalfa field (single feeding e

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