Comment submitted by S. Kenney

I am opposed to the use of Carbofuran. These facts as outlined by the Rachel Carson Council show why the EPA should oppose the registration of Carbofuran and the EPA will be held accountable for the deaths and illnesses of wildlife and human life if they do not oppose use of this pesticide. Below are points outlined by the Rachel Carson Council: 1. Birds: Carbofuran is so toxic to birds that its use routinely violates the Migratory Bird Treaty Act. US environmental regulations do not permit the killing of migratory songbirds or waterfowl with pesticides. A farmer following the FIFRA rules is still putting himself at risk for violating the Migratory Bird Treaty Act. Ecological risk assessments revealed widespread and repeated mortality events involving carbofuran and birds. Data from adverse reaction reports validates this risk assessment. In addition to songbirds and waterfowl, carbofuran also kills raptors, including the Bald Eagle, which is both our national emblem and a threatened species. If carbofuran reregistration is allowed, there is great concern that the Bald Eagle and/or other threatened or endangered avian species would be placed in harm's way. 2. Groundwater: When pesticides get into ground water, they frequently get into surface water as well due to movement from underground to the surface as part of the hydrologic cycle - reported on by USGS in their recent publication, Pesticides in the Nation's Streams and Ground Water, 1992-2001. It should be kept in mind that carbofuran presents a danger of entering surface water as it was detected in ground water sampling according to the report, Pesticides in Groundwater Database: A Compilation of Monitoring Studies, 1971-1991, hence its danger to fish and aquatic insects. In 2006, the USGS reported that carbofuran has a half- life in streams of up to 289 days. This is significantly longer than the other pesticides most frequently detected in water according to Pesticides in Groundwater Database: A Compilation of Monitoring Studies, 1971-1991 (USGS circular 1291). 3. Government Agency Environmental Concerns: The USEPA expressed concern about the ecological effects of carbofuran on fish, mammals and groundwater ("Eco Chemical Final List," 1999). In 2006 there are concerns about carbofuran's toxicity in streams to fish and invertebrates in Pesticides in Groundwater Database: A Compilation of Monitoring Studies, 1971-1991 (USGS circular 1291). 4. Bees: Based on a 1997 Bee Kill Survey by the American Beekeeping Federation, Inc., sixty beekeepers operating 127,950 colonies in 22 states reported that bee losses from pesticides are a significant issue in their operations. A carbofuran-containing product was the pesticide most commonly identified with bee kills by the beekeepers. In March 2005 the Minnesota Supreme Court recognized a common-law duty to protect bees from pesticide poisoning when applicators have notice of foraging honey bees on the property. 5. Integrated Pest Management: Carbofuran is broadly poisonous to all insects, so that its usage virtually eliminates all methods of controlling pests with beneficial insects. Therefore, any attempts at integrated pest management become impossible once carbofuran is used. 6. Crop Rotation: The label on a carbofuran-containing-product states that no crops can be rotated with those using [this product] for at least 10 months after pesticide application. This effectively eliminates crop rotation as a possible method of reducing insect damage. Thus its usage inevitably leads to a greater necessity for pesticide application in the future. 7. Humans: Human risk assessments done for carbofuran point to an increasing number of dangers to farm workers posed by exposure to the chemical. "In a recent action an EPA advisory group criticized both the scientific and ethical components of three carbofuran intentional human dosing studies, concluding that they should not be used by EPA in its regulatory actions for the insecticide" (Pesticide and Toxic Chemical News, May 6, 2006). 8. 2007 and Rachel Carson's Centenary: Next May will be the 100th anniversary of Rachel Carson's birth. Rachel Carson expressed strong concerns about the hazardous effects of pesticides, on people as well as on the environment. Through her landmark book Silent Spring, Carson is credited with initiating the modern environmental movement, and the momentum that created the USEPA. How wonderful it would be to include in her centennial celebration the announcement from the EPA that they had banned carbofuran, a pesticide most hazardous to birds and other life forms. CONCLUSION: Significantly reducing the use of carbofuran could avoid serious problems and at the same time help encourage its replacement with less hazardous forms of pest management. We have heard that less dangerous alternatives are available for use on crops for which carbofuran-containing products are now registered. If chemicals such as carbofuran continue to be available, there will be no incentive to use less-hazardous means of pest management.