Comment submitted by Thomas A. Parker, PhD, Pest Control Services, Inc.

As an entomological consultant in the urban pest management industry, I have been involved in at least a dozen chlorpyrifos pesticide contamination and personal injury litigation matters over several decades. These matters primarily involve the labeled applications of the Dursban TC formulation in unventilated crawlspaces and basements. Air handling systems redistribute chlorpyrifos molecules throughout the dwelling, resulting in the contamination on the home and contents. Personal injury, loss of personal property, abandonment of the home, and long-term health problems have been the result of these "legal" applications. Subterranean termite application labels require substantial revision in favor of the homeowner. Thomas A. Parker, PhD President, Entomologist 469 Mimosa Circle Kennett Square, PA 610-348-9890 Cell 610-444-2277 Office 610-444-2615 Fax