Oct 16, 2024· Comment submitted by Natural Resources Defense Council (NRDC) et al.· EPA-HQ-OPP-2011-0865-1418
We are submitting these comments on Clothianidin's, Imidacloprid's, and Thiamethoxam's Updated Occupational Exposure Assessments for Seed Treatment Uses. These comments are submitted on behalf of the Natural Resources Defense Council (NRDC, Jennifer Sass) and the following organizations with a long-standing interest in protecting workers and preventing health harms from pesticides: Alianza Nacional de Campesinas, Inc.; Center for Food Safety; Friends of the Earth; Migrant Clinicians Network; Pesticide Action Network; Public Employees for Environmental Responsibility (PEER); The Farmworker Association of Florida, Inc.; Toxic Free NC.
Dec 29, 2020· Comment submitted by Lucas Rhoads, Staff Attorney, et al., Natural Resources Defense Council (NRDC), Margaret Reeves, Senior Scientist, Environmental Health and Workers’ Rights, Pesticide Action Network North America, and Bruce Hamilton, National Policy Director, Sierra Club· EPA-HQ-OPP-2011-0865-1399
See attached comments on behalf of the Natural Resources Defense Council (NRDC), Pesticide Action Network North America, and Sierra Club as well as the attached petition and comment on behalf of NRDC.
Aug 6, 2020· Comment submitted by Lucas Rhoads, Staff Attorney, Natural Resources Defense Council (NRDC)· EPA-HQ-OPP-2011-0865-1389
Attached are Supplemental Comments submitted on behalf of the Natural Resources Defense Council. These comments supplement those submitted by NRDC, Sierra Club, and Pollinator Action Network North America on May 4, 2020, as well as the comments and petition submitted by NRDC on that date. Both previous comments are attached for reference.
As indicated in our May 4th submission, we request that all attached documents are included in the record for all five neonics: Imidacloprid (EPA-HQ-OPP-2008-0844); Thiamethoxam (EPA-HQ-OPP-2011-0581); Clothianidin; (EPA-HQ-OPP-2011-0865); Acetamiprid (EPA-HQ-OPP-2012-0329); and Dinotefuran (EPA-HQ-OPP-2011-0920).
Because attachments to the comments exceed file size limitations, NRDC is submitting attachments in several batches.
Thank you for your consideration.
Jul 22, 2020· Comment submitted by Lucas Rhoads, Staff Attorney, Natural Resources Defense Council (NRDC)· EPA-HQ-OPP-2011-0865-1387
Attached are Supplemental Comments submitted on behalf of the Natural Resources Defense Council. These comments supplement those submitted by NRDC, Sierra Club, and Pollinator Action Network North America on May 4, 2020, as well as the comments and petition submitted by NRDC on that date. Both previous comments are attached for reference.
As indicated in our May 4th submission, we request that all attached documents are included in the record for all five neonics: Imidacloprid (EPA-HQ-OPP-2008-0844); Thiamethoxam (EPA-HQ-OPP-2011-0581); Clothianidin; (EPA-HQ-OPP-2011-0865); Acetamiprid (EPA-HQ-OPP-2012-0329); and Dinotefuran (EPA-HQ-OPP-2011-0920).
Thank you for your consideration.
Jul 8, 2019· Comment submitted by Lucas J. Rhoads, Staff Attorney, Nature Program on behalf of the Natural Resources Defense Council (NRDC)· EPA-HQ-OPP-2011-0865-1155
Filed on regulations.gov — full text not in the inline record.
Aug 24, 2017· Comment submitted by Jennifer Sass, PhD, Senior Scientist, Natural Resources Defense Council (NRDC)· EPA-HQ-OPP-2011-0865-0232
Filed on regulations.gov — full text not in the inline record.