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E-M:/ Human testing data for EPA wanted and supported by pesticide industrytrade group that includes Michigans Dow Agroscience LLC and others.


Dear All,

In response to growing controversy over human testing, U.S. EPA issued a directive against such tests in 2001. But CropLife America, a trade group for chemical companies, filed suit and a federal appeals court in June 2003 ordered U.S. EPA to accept data from human tests.

Comment on the Web at http://cascade.epa.gov/RightSite/dk_public_collection_detail.htm?ObjectType=dk_docket_collection&cid=OPP-2003-0132&ShowList=items&Action=view

Comment by Email: opp-docket@epa.gov, U.S. EPA Docket Number OPP-2003-0132

By mail:
Environmental Protection Agency
EPA Docket Center (EPA/DC)
Human Testing; Advance Notice of Proposed Rulemaking Program Docket 1200 Pennsylvania Avenue, NW
Washington, DC 20460
RE: EPA Docket Number: OPP-2003-0132

Dear Agency Officials, I am writing in response to your request for public comment on the issue of accepting studies that rely on exposing people to pesticides to determine health effects. Testing pesticides on people is unethical and unnecessary, and I urge you to develop a policy that disallows consideration of these studies.

Please stick to tough and appropriate standards for exposure levels for children and pregnant moms, and use the agency's resources to promote known alternatives to reduce the need for toxic pesticides.

EPA's approach to regulating pesticides should be based on the precautionary principle, an approach that will protect public health much more effectively. Encouraging intentional dosing of people with toxic pesticides by accepting these studies would be irresponsible, and I urge you not to support such a move.

- signature -

Sources: The 1998 Science Advisory Board/Scientific Advisory Panel (SAB/SAP), http://www.epa.gov/science1/pdf/ec0017.pdf ; U.S. Court Lifts Ban on Human Testing of Pesticides, Planet Ark, June 5, 2003,


Samuel DeFazio
2723 116th Ave
Allegan, MI 49010

For more information about CropLife International, go to http://www.croplife.org.

CropLife America Member Companies
(April 18, 2003)

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