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Registration Review of Chlorpyrifos (PC Code 059101)

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Natural Resources Defense Council (NRDC) filings
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Natural Resources Defense Council (NRDC) filed 2 comments on this docket between May 20, 2009 and May 28, 2015. 66 other organizations filed here. The comment window closed 1969d ago.

What Natural Resources Defense Council (NRDC) filed (2)

May 28, 2015· Mass Comment Campaign submitted by Pesticide Action Network North America, United Farm Workers, and Natural Resources Defense Council (26896 web)· EPA-HQ-OPP-2008-0850-0835

Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 April 30, 2015 Docket ID: EPA-HQ-OPP-2008-0850 Dear Administrator McCarthy, We urge EPA to ban the neurotoxic insecticide chlorpyrifos by heeding evidence in its own risk assessment. Even though the assessment significantly underestimates both exposure and harm, it points to unacceptable risks for both farmworkers and children. After years of waiting, the agency finally released its human health risk assessment for this widely used pesticide but only after a legal petition and several lawsuits filed by a coalition of environmental health groups. In the assessment, EPA found that exposure to chlorpyrifos damages the development of the brain. And yet it inexplicably allows the use of this dangerous pesticide to continue. Additionally, the agencys assessment is fundamentally flawed. While it does incorporate an added safety factor for children as required, it relies heavily on studies conducted by Dow the company that manufactures chlorpyrifos which represents a serious conflict of interest. The assessments models are based on faulty assumptions, such as data from a study that used testing on humans and failed EPAs peer review. Despite these failings, EPAs assessment still finds that unacceptably high risks to workers health cant be avoided. Immediate action to ban chlorpyrifos is needed to: * Protect children from reduced IQ, autism, ADHD, and other harms to the brain and nervous system; * Protect communities from effects of chlorpyrifos when it drifts off crops and into nearby neighborhoods and schools; * Protect infants from contaminated drinking water and other unsafe exposures; and * Protect workers from being poisoned at unconscionable rates. Action on this toxic chemical is long overdue. We urge you to ensure that your agency moves quickly to ban chlorpyrifos now. Thank you for your consideration of this important issue. Sincerely, Pesticide Action Network North America, United Farm Workers, and Natural Resources Defense Council On behalf of the 26,869 signatories below, concerned citizens from all 50 states, Washington, DC and several Canadian provinces.

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May 20, 2009· Comment submitted by Mayra Quirindongo, Natural Resources Defense Council· EPA-HQ-OPP-2008-0850-0011

Attached please find comments by the Natural Resources Defense Council (NRDC) regarding the registration review of the pesticide chlorpyrifos (Docket number EPA-HQ-OPP-2008-0850). Respectfully submitted, Mayra Quirindongo Health & Environment Program Natural Resources Defense Council

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Co-filers (66)

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