Comment submitted by R. Apricio

Although ultimately I am in favor of all pesticide residues being removed from food, I will support any regulation that limits the amount of pesticides left on food to the absolute minimum that the EPA believes is safe. Because of this I am in favor of the proposed regulation for lychee and startfruit that will set the level of Chlorothalonil residue tolerance at 15 ppm and 3.0 ppm, respectively. I appreciate the EPA testing and determining the safe levels of pesticide residue for foods and feel it is better than no tolerance limits at all. The EPA has the power and resources to test what is safe for the American people and between the EPA and the growers of food, we are at your mercy, unless we are to solely purchase organic produce, which at this time is cost prohibitive or inconvenient for most consumers. Ideally, I would like the USDA to eliminate pesticide use all together, which would make our food safer and eliminate the money and time spent testing what are safe levels of pesticide residues. According to the proposed regulation document the EPA has “classified Chlorothalonil as a likely human carcinogen by all routes of exposure” and this is of great concern. I understand that the EPA testing of residue at the tolerance levels suggested falls under the level of concern for cancer, but that is still difficult to understand when the chemical itself has been classified as an agent that produces cancer. I would like to take this opportunity to bring up a concern having to do with pesticide use on the fruits and vegetables we eat. The testing that was done for Chlorothalonil is just one of the chemicals used in many different kinds of pesticides. According to one website, 41 pesticide residues were found on apples tested and 57 pesticide residues were found on lettuce samples. (Please see the following website: http://encyclopedia.stateuniversity.com/pages/17121/pesticide.html. My concern is that the aggregate amount of chemical residues that are left on our food or penetrate our food can be increasingly dangerous to humans in the form of cancers occurring. I do not see anywhere in this proposed regulation that addresses the aggregate use of chemicals or if this issue is addressed anywhere at all. Due to my concern about pesticide use, I purchase organic produce whenever possible. I would also support the USDA and EPA in any measures that would increase the efficiency and use of organic farming. In conclusion, I am in favor of any regulation that will limit the amount of residue on the food we eat to the lowest amount possible, but if the EPA and USDA are truly concerned about the safety of the American people, they will review eliminating the use of pesticides all together and support organic farming to be a cost effective commercial success.