Comment submitted by Ravali Parsa, New York University

From: Ravali Parsa Re: Pesticide Tolerances: 1-Naphthaleneacetic acid Docket: EPA-OPP-2004-0144 I am writing in response to the regulation that establishes a tolerance for residues of 1-napthaleneacetic acid, potassium and sodium salts in potatoes. Stehekin, LLC petitioned to the EPA for clearance of use of this pesticide under the Federal Food Drug and Cosmetic Act (FFDCA). The regulation is effective as of May 8th, 2012. I am writing in concern for the tolerance of Naphthaleneacetic acid in food production and use after examination of the potential harmful effects of this acid. This regulation affects agricultural producers, food manufacturers, or pesticide manufacturers. It also affects those that engage in crop and animal production. The FFDCA allows the EPA a legal limit of a pesticide if its considered “safe” or there is reasonable certainty that no harm will result from aggregate exposure to the pesticide’s chemical residue and all dietary exposures. This includes exposure to drinking water but does not include occupational exposure. This is the concern at hand. Naphthaleneacetic acid has deleterious effects through repeated exposure that agricultural workers will be exposed to. If you examine the toxicological profile of this acid it is clear of its harmful effects. Napthaleneacetic acid is found to be irritating to the eye and repeated exposure results in decreased body weights and body weight gains accompanied by decreased food consumption. The major target organs affected through oral exposure were the liver, stomach, and lung. In addition, repeated oral exposure resulted in decreased hematocrit and hemoglobin along with reduced RBC count. In addition the material safety data sheet of this acid has identified it as a level 3 hazard. This is considered to be extremely hazardous to skin contact, ingestion, and inhalation. The EPA has determined that tolerance will be established for 1-napthaleneacetic acid in or on a potato at 0.01 ppm. Despite thi