Petition to Amend and add New Tolerances on Specific Crops for Thiamethoxam

The Center for Biological Diversity is attaching comments recently submitted to this docket on January 16, 2018 We are also attaching a letter sent to pesticide registrants by the EPA dated April 2, 2015. The purpose of this letter was to inform registrants that the EPA was "unlikely to be in a position to determine that such [new uses of neonicotinoids] would avoid "unreasonable adverse effects on the environment" as required under FIFRA to support further regulatory expansion of these pesticides in outdoor settings." And that "... until EPA receives and assesses the outstanding pollinator health data, EPA is unlikely to be in a position to grant any submitted registration action that involves a request with one of these pesticides for a new outdoor use or use expansion." We would like to remind the EPA that it has still not fully assessed outstanding pollinator health data for thiamethoxam. The agency has only completed a preliminary bee risk assessment. That document was posted for public review and comment and the agency is in receipt of many comments pointing out the deficiencies in this assessment. So until the agency has fixed the many deficiencies in its preliminary bee health risk assessment, the agency cannot consider the regulatory expansion for new uses of thiamethoxam. With a ban on neonicotinoids in place in European Union, new restrictions just proposed for thiamethoxam in Canada, and the state of California no longer considering new uses of neonicotinoids, the U.S. EPA stands out as incredibly out of touch with scientific consensus on the harms of neonicotinoids. By even considering such an ill-advised proposal, the agency is isolating itself from its peers within the U.S. and around the world. We strongly urge the EPA to deny this application.

Please see attached files submitted by the Center for Biological Diversity and the Center for Food Safety