Comment submitted by b sachau

Document ID: EPA-HQ-OPP-2006-0530-0003
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: August 11 2006, at 10:11 AM Eastern Daylight Time
Date Posted: August 11 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: August 11 2006, at 08:42 AM Eastern Standard Time
Comment Due Date: August 28 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 801b4d6c
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public comment on federal register of 8/11/06 vol 71 #155 pg 46224 georgia wants an emergency use of pyridalyl. i note that many privat eagencies believe this product has severe health and environment effects. i agree with them some of them are: Pesticide Directory : A - E | F | G-P | Q-Z Pesticide Project Homepage Abstracts Adverse Health Effects Federal Register Open Comments Glossary of terms MSDS/Labels Pesticide Groups Pesticide Manafacturers Pesticides in the News PFOA-PFOS Reports etc. Submissions Useful Links Contact Project Pesticides Adverse Effects Pyridalyl CAS No. 179101-81-6 Return to Pyridalyl Index Page Activity: Iinsecticide (unclassified) Structure: Adverse Effects: Blood Body Weight Decrease Endocrine: Adrenal Endocrine: Ovary Endocrine: Testes Kidney Liver Lung Reproductive Spleen Environmental - persistence in soil On December 5, 2003, Valent petitioned US EPA for the first-time tolerances for residues in food commodities. Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Blood (click on for all fluorinated pesticides) Subchronic toxicity. -- Pyridalyl technical was tested in rats in a 3-month feeding study. Effects included decreased body weight gain, altered blood biochemistry, increased relative liver weight and histopathological changes in the liver, ovary, adrenal and lung. The NOAEL is 100 ppm (5.56 mg/kg/day in males and 6.45 mg/kg/day in females). -- A 13-week feeding study in mice was conducted. Effects included decreased body weight gain, hematological and blood biochemical effects,increased liver weight, decreased kidney and ovary weights and histopathological changes in liver, kidney, ovary and adrenal. The NOAEL is 70 ppm in males (8.169 mg/kg/day) and 700 ppm in females (86.78 mg/kg/day). -- A 13-week oral (capsule) toxicity study was conducted in dogs. Effects included decreased body weight gain, clinical signs indicative of respiratory distress, hematological and blood biochemistry effects, increased liver, lung and kidney weights and histopathological alterations of the lung, kidney, adrenal and liver. The NOAEL was 10 mg/kg/day. Chronic toxicity. -- In a 104-week combined chronic/oncogenicity study in rats, effects included decreased body weight gain, increased frequency of rearing (high dose females only), hematological alterations and histopathological alterations of the spleen. No oncogenicity was found. The NOAEL for this study is 100 ppm (3.4 mg/kg/day in males and 4.1 mg/kg/day in females). -- Pyridalyl was administered for 12-months by capsule to dogs. There were alterations in blood biochemistry (alkaline phosphatase and alanine aminotransaminase) and increased liver weights. The NOAEL of the study was 20 mg/kg/day. Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Body Weight Decrease (click on for all fluorinated pesticides) Subchronic toxicity. -- Pyridalyl technical was tested in rats in a 3-month feeding study. Effects included decreased body weight gain, altered blood biochemistry, increased relative liver weight and histopathological changes in the liver, ovary, adrenal and lung. The NOAEL is 100 ppm (5.56 mg/kg/day in males and 6.45 mg/kg/day in females). -- A 13-week feeding study in mice was conducted. Effects included decreased body weight gain, hematological and blood biochemical effects,increased liver weight, decreased kidney and ovary weights and histopathological changes in liver, kidney, ovary and adrenal. The NOAEL is 70 ppm in males (8.169 mg/kg/day) and 700 ppm in females (86.78 mg/kg/day). -- A 13-week oral (capsule) toxicity study was conducted in dogs. Effects included decreased body weight gain, clinical signs indicative of respiratory distress, hematological and blood biochemistry effects, increased liver, lung and kidney weights and histopathological alterations of the lung, kidney, adrenal and liver. The NOAEL was 10 mg/kg/day. Chronic toxicity. -- In a 104-week combined chronic/oncogenicity study in rats, effects included decreased body weight gain, increased frequency of rearing (high dose females only), hematological alterations and histopathological alterations of the spleen. No oncogenicity was found. The NOAEL for this study is 100 ppm (3.4 mg/kg/day in males and 4.1 mg/kg/day in females). -- Pyridalyl was administered in the diet to mice for 78-weeks. Effects included decreased body weight gain and food consumption/efficiency, and increased liver and kidney weights. The NOAEL of the study was 50 ppm (5.04 mg/kg/day in males and 4.78 mg/kg/day in females) Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Endocrine: Adrenal (click on for all fluorinated pesticides) Subchronic toxicity. -- Pyridalyl technical was tested in rats in a 3-month feeding study. Effects included decreased body weight gain, altered blood biochemistry, increased relative liver weight and histopathological changes in the liver, ovary, adrenal and lung. The NOAEL is 100 ppm (5.56 mg/kg/day in males and 6.45 mg/kg/day in females). -- A 13-week feeding study in mice was conducted. Effects included decreased body weight gain, hematological and blood biochemical effects,increased liver weight, decreased kidney and ovary weights and histopathological changes in liver, kidney, ovary and adrenal. The NOAEL is 70 ppm in males (8.169 mg/kg/day) and 700 ppm in females (86.78 mg/kg/day). -- A 13-week oral (capsule) toxicity study was conducted in dogs. Effects included decreased body weight gain, clinical signs indicative of respiratory distress, hematological and blood biochemistry effects, increased liver, lung and kidney weights and histopathological alterations of the lung, kidney, adrenal and liver. The NOAEL was 10 mg/kg/day. Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Endocrine: Ovary (click on for all fluorinated pesticides) Subchronic toxicity. -- Pyridalyl technical was tested in rats in a 3-month feeding study. Effects included decreased body weight gain, altered blood biochemistry, increased relative liver weight and histopathological changes in the liver, ovary, adrenal and lung. The NOAEL is 100 ppm (5.56 mg/kg/day in males and 6.45 mg/kg/day in females). -- A 13-week feeding study in mice was conducted. Effects included decreased body weight gain, hematological and blood biochemical effects,increased liver weight, decreased kidney and ovary weights and histopathological changes in liver, kidney, ovary and adrenal. The NOAEL is 70 ppm in males (8.169 mg/kg/day) and 700 ppm in females (86.78 mg/kg/day) Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Endocrine: Testes (click on for all fluorinated pesticides) Possible effect of pyridalyl on the steroid synthesis pathway was surveyed in rats. It was revealed that pyridalyl affected the sex hormone synthetic pathway in the testis at the concentration of 3 ?M and higher, and this effect was caused by an inhibition of testosterone synthesis, via weak but significant inhibition of 17a-HSD activity. (Ref. 44. Effect of pyridalyl on the sexual hormonal synthetic pathway in rats: Sumitomo Chemical Co., Ltd., 2002, unpublished.) Ref: Evaluation Report. PYRIDALYL. January 14, 2004. Japan Food Safety Commission. Pesticides Expert Committee. Kidney (click on for all fluorinated pesticides) Subchronic toxicity. -- A 13-week feeding study in mice was conducted. Effects included decreased body weight gain, hematological and blood biochemical effects,increased liver weight, decreased kidney and ovary weights and histopathological changes in liver, kidney, ovary and adrenal. The NOAEL is 70 ppm in males (8.169 mg/kg/day) and 700 ppm in females (86.78 mg/kg/day). -- A 13-week oral (capsule) toxicity study was conducted in dogs. Effects included decreased body weight gain, clinical signs indicative of respiratory distress, hematological and blood biochemistry effects, increased liver, lung and kidney weights and histopathological alterations of the lung, kidney, adrenal and liver. The NOAEL was 10 mg/kg/day. Chronic toxicity. -- Pyridalyl was administered in the diet to mice for 78-weeks. Effects included decreased body weight gain and food consumption/efficiency, and increased liver and kidney weights. The NOAEL of the study was 50 ppm (5.04 mg/kg/day in males and 4.78 mg/kg/day in females) Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Liver (click on for all fluorinated pesticides) Subchronic toxicity. -- Pyridalyl technical was tested in rats in a 3-month feeding study. Effects included decreased body weight gain, altered blood biochemistry, increased relative liver weight and histopathological changes in the liver, ovary, adrenal and lung. The NOAEL is 100 ppm (5.56 mg/kg/day in males and 6.45 mg/kg/day in females). -- A 13-week feeding study in mice was conducted. Effects included decreased body weight gain, hematological and blood biochemical effects, increased liver weight, decreased kidney and ovary weights and histopathological changes in liver, kidney, ovary and adrenal. The NOAEL is 70 ppm in males (8.169 mg/kg/day) and 700 ppm in females (86.78 mg/kg/day). -- A 13-week oral (capsule) toxicity study was conducted in dogs. Effects included decreased body weight gain, clinical signs indicative of respiratory distress, hematological and blood biochemistry effects, increased liver, lung and kidney weights and histopathological alterations of the lung, kidney, adrenal and liver. The NOAEL was 10 mg/kg/day. Chronic toxicity. -- Pyridalyl was administered in the diet to mice for 78-weeks. Effects included decreased body weight gain and food consumption/efficiency, and increased liver and kidney weights. The NOAEL of the study was 50 ppm (5.04 mg/kg/day in males and 4.78 mg/kg/day in females) -- Pyridalyl was administered for 12-months by capsule to dogs. There were alterations in blood biochemistry (alkaline phosphatase and alanine aminotransaminase) and increased liver weights. The NOAEL of the study was 20 mg/kg/day. Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Lung (click on for all fluorinated pesticides) Subchronic toxicity. -- Pyridalyl technical was tested in rats in a 3-month feeding study. Effects included decreased body weight gain, altered blood biochemistry, increased relative liver weight and histopathological changes in the liver, ovary, adrenal and lung. The NOAEL is 100 ppm (5.56 mg/kg/day in males and 6.45 mg/kg/day in females). -- A 13-week oral (capsule) toxicity study was conducted in dogs. Effects included decreased body weight gain, clinical signs indicative of respiratory distress, hematological and blood biochemistry effects, increased liver, lung and kidney weights and histopathological alterations of the lung, kidney, adrenal and liver. The NOAEL was 10 mg/kg/day. Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Reproductive (click on for all fluorinated pesticides) Species Evaluation Test NOAEL Note Rat Two-generation reproductive toxicity study P Male: 2.80 mg/kg bw/day P Female: 3.11 mg/kg bw/day F1 Male: 3.40 mg/kg bw/day F1 Female: 3.62 mg/kg bw/day Delayed sexual maturation in females Ref: Evaluation Report. PYRIDALYL. January 14, 2004. Japan Food Safety Commission. Pesticides Expert Committee. Spleen (click on for all fluorinated pesticides) Chronic toxicity. -- In a 104-week combined chronic/oncogenicity study in rats, effects included decreased body weight gain, increased frequency of rearing (high dose females only), hematological alterations and histopathological alterations of the spleen. No oncogenicity was found. The NOAEL for this study is 100 ppm (3.4 mg/kg/day in males and 4.1 mg/kg/day in females). Ref: Federal Register: December 5, 2003. Pyridalyl; Notice of Filing a Pesticide Petition. http://www.fluorideaction.org/pesticides/pyridalyl.fr.dec.5.2003.htm Environmental (click on for all fluorinated pesticides) The assumed half-life of those regarded as pyridalyl would be 78-361 days, and those regarded as the sum of pyridalyl and degradation products to be more than 82-361 days. (Ref. 17) Table 2. The results of residue in soils (Assumed DT50) Type of test Kind of soil Unchanged compound Total amount of pyridalyl and two degradates ? Vessel Volcanic ash clay loam 118 days 270 days Unsolidified sedimentary rocks clay loam 361 days >361 days Field Unsolidified sediments clay loam 78 days 82 days Unsolidified sedimentary rocks clay loam 245 days 255 days ? S-1812-DP: 3,5-dichloro-4- [3-(5-trifluoromethyl-2-pyridyloxy)]- propoxyphenol ? S-1812-DP-Me: 2-[3-(2,6-dichloro-4-methoxyphenoxy)propoxy]-5- (trifluoromethyl) pyridine Ref: Evaluation Report. PYRIDALYL. January 14, 2004. Japan Food Safety Commission. Pesticides Expert Committee. i personally am sick of mother earth being poisoned by profiteers. we need to find a more natural way to grow our food. americans already carry far too many toxic chemicals aroun din their bodies. this is not good for health at all. this agency allows far to many toxic chemicals to be used. they do not even do combinant testing. it has been shown that combinant testing of two toxic chemicals can result in a toxic cocktail two thousand times more toxic. b. sachau 15 elm st florham park nj 07932

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