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E-M:/ USGS - Pesticide National Synthesis Project 1992 Annual Use

Take Action for Wildlife
Hazardous Insecticide Risk Assessment Comments Needed
As many of you know, the use of organophosphate insecticides often poses a serious threat to fish and wildlife populations worldwide.  In the US, the Fish and Wildlife Service is the designated agency for dealing with wildlife toxicology at the federal level.  Unfortunately, the budgets for enforcement of pesticide laws and environmental monitoring have fallen terribly short and wildlife professionals are just too busy to investigate all problems.  Furthermore, detection of field poisonings in wildlife are difficult for a variety of reasons, not the least of which is that animals often hide before they die.  The best estimates suggest that only a fraction of wildlife poisonings are detected and a fraction of those are brought successfully to an enforcement or remediation action.
One of the bad actors out there when it comes to organophosphates (think sarin, soman and VX - these nerve gases are organophosphates as well) is ethoprop.  Ethoprop is a highly toxic nerve poison that has registered uses which result in exceedences of mammal, bird and fish environmental tolerances.  Ethoprop is also considered a "likely" human carcinogen.  Organophosphates are toxic to a wide variety of lifeforms, so much so that they are considered general biocides.  Despite some progress in removal of hazardous chemicals from the marketplace, much work remains as evidenced by the continued use of ethoprop in agriculture.  A few excerpts from the USEPA risk assessment for ethoprop are provided below:
"Given the extent and magnitude of LOC exceedences, EFED does not believe the risks from the use of Ethoprop can be mitigated effectively."
"All uses (of Ethoprop) at all labeled rates resulted in high risks to all terrestrial and aquatic animals, except for turf slit-placement uses."
"The most highly exposed population subgroup, based on results of DRES analysis, is non-nursing infants (<1 year old)." (not including drinking water as a source).
This URL (http://water.wr.usgs.gov/pnsp/use92/ethoprp.html) is a link to the USEPA pestide database for usage in the US.  If you link to this site, you'll see a map with color-coded use rates (by county) for the lower 48 states.  You would also see that Michigan is one of the few states with a heavy use of ethoprop.  The other Great Lakes with significant use is New York.
If you are concerned about use of high risk, carcinogenic pesticides in the Great Lakes basin, and in Michigan, then now is your chance to make your voice heard.  USEPA is soliciting public input in their risk assessment process for Ethoprop.  I have included the EPA notice below and urge all of you (yes, even you Russ Harding) to write EPA and insist that this toxic nerve poison be withdrawn from all agricultural uses and that substitutes be found for turf use. 
You may submit comments through the mail, in person, or electronically. To ensure proper receipt by EPA, you must identify
docket control numbers OPP-34144C for ethoprop, in the subject line on the first page of your response.

    1. By mail. Submit comments to: Public Information and Records
Integrity Branch, Information Resources and Services Division (7502C),
Office of Pesticide Programs, Environmental Protection Agency, 401 M
St., SW., Washington, DC 20460.
    2. In person or by courier. Deliver comments to: Public Information
and Records Integrity Branch, Information Resources and Services
Division (7502C), Office of Pesticide Programs, Environmental
Protection Agency, Rm. 119, Crystal Mall #2, 1921 Jefferson Davis Hwy.,
Arlington, VA. The Document Control Office (DCO) is open 8:30 a.m. to 4
p.m., Monday through Friday, excluding legal holidays. The PIRIB
telephone number is (703) 305-5805.
    3. Electronically. Submit electronic comments by e-mail to: ``opp-
docket@epa.gov,'' or you may mail or deliver your standard computer
disk using the addresses in this unit. Do not submit any information
electronically that you consider to be CBI. Electronic comments must be
submitted as an ASCII file, avoiding the use of special characters and
any form of encryption. Comments and data will also be accepted on
standard computer disks in WordPerfect 5.1/6.1 or ASCII file format.
All comments in electronic form must be identified by the docket
control numbers OPP-34144C for ethoprop, OPP-34134B for fenamiphos,
OPP-34137B for phorate, and OPP-34139C for terbufos. Electronic
comments may also be filed online at many Federal Depository Libraries.
Thank you very much for working to remove harmful pesticides from the Great Lakes region.
Best Wishes,
David Zaber
Western Lakes Wildlife Center
On Wednesday, September 1, 1999,
EPA released the revised risk
assessments for four organophosphate (OP)
 pesticides: ethoprop, fenamiphos, terbufos,
and phorate.  The release of the risk
assessment was announced in a Federal
Register notice (Volume 64, No. 169,
Pages 47784-47786), available on the
EPA web site at www.epa.gov/fedrgstr/.
In addition, EPA has posted the revised risk
assessment for ethoprop, fenamiphos, terbufos,
and phorate on the OPP web site
The Federal Register notice also announces
an opportunity for a 60-day public participation
period during which the public may submit risk
management and mitigation ideas, and
recommendations and proposals for transition
related to ethoprop, fenamiphos, terbufos,
and phorate.  Comments must be received by
November 1, 1999.
For more information, contact Karen Angulo at
308-8004 or by email at angulo.karen@epa.gov