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E-M:/ Human testing coments due by August 5, 2003. More dangerous andcowardly behavior being advanced.



Title:
 Factual pesticide risk information can be such a headache in lawsuits when trying to protect the public health and the environment.

Solution? Remove it.

Dear All,

Re:

Here's the link to 40CFR, Part156.10.
Paragraph (h),Warnings and precautionary statements proposed for removal, is
the section on Toxicity Categories and also includes that Environmental
hazards section. You know, like statements stating:  "Keep out of lakes,
ponds, or streams..."
http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_40/40cfr156_00.html
 

More remarkable cowardice is being exhibited in the timing of this proposed amendment by public employees who's behavior
has no bearing on public safety or the common good of our great nation, the job that they are paid for.  Removing warning language from pesticide labels, a long time holy grail of pesticide lobbyists appears to serve only the overly influential chemical pesticide corporations that have already co-opted our land grant university system, and continue to promote an agenda that benefits a tiny subsection of the population, chemical pesticide company stockholders, at the expense of every man, women,
and child in America.  This proposal come at a time when most people and the media are distracted and is in our opinion contemptible and mean spirited.
 
Praxis would view this change if made as criminally irresponsible.  Praxis would ask you to contact the EPA and the Michigan Department of Agriculture to protest this change as we intend to.  We hope you view this as we do, as a clear indication of our long time grave concerns about pesticide promotion and endorsement by government employees as wrong and valid, more like state capitalism and not a free market economy.  This makes the repression and disparagement of cheaper, safer, more effective options like biological control in general and Praxis and its Biotool Kit products in particular by public employees (historically this has included some MSU, MSU Extension MDA employee's and other State of Michigan employee's) all the more unacceptable.  We hope you share our concern about how dangerous this problem has become, thank you for your help and it appears we will need more of your help to serve an environment that will support alternative problem solving and a free market economy.
 
EPA has published in the Federal Register to amend CFR40 on pesticide labeling requirements. EPA proposes to delete the use of the signal word (Caution, Warning, Danger) on the label. This is quite a serious development. The public will have no way of discerning lesser toxic from greater toxic levels of prducts on the market that they purchase or that people they hire to apply pesticides use. It would appear that EPA is bending to industry interests at the expense of public right-to-know.  Please be sure and comment on this proposal, including sending letters from your organizations.  If you deem it acseptable we would like to recive a copy of your recomondations.

THIS DATA CURRENT AS OF THE FEDERAL REGISTER DATED DECEMBER 14, 2001

40 CFR -- PART 156 --
View Printed Federal Register page 66 FR 64764 in PDF format.

Amendment(s) published December 14, 2001, in 66 FR 64764

Effective Date(s) February 12, 2002
b. In §  156.10, by revising paragraph (a)(1)(vii) and removing paragraph
(h), to read as follows:

§  156.10    Labeling requirements.
(a) * * *
(1) * * *
(vii) Hazard and precautionary statements as prescribed in subpart D of this
part for human and domestic animal hazards and subpart E of this part for
environmental hazards.

Here's the link to 40CFR, Part156.10.
Paragraph (h),Warnings and precautionary statements proposed for removal, is
the section on Toxicity Categories and also includes that Environmental
hazards section. You know, like statements stating:  "Keep out of lakes,
ponds, or streams..." that can be such a headache in lawsuits.
http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_40/40cfr156_00.html
 
Sincerely,
 
 

Samuel M. DeFazio

Praxis
2723 116th Ave.
Allegan, MI  49010