Comment submitted by Asa Bradman, PhD,

Thank you for the opportunity to comment on US EPA’s proposal to require disclosure of inert ingredients in pesticide formulations (Docket Number EPA-HQ-OPP-2009-0635). We support the disclosure of all ingredients in pesticides formulations registered under FIFRA. As the Director and Associate Directors of the Center for Children’s Environmental Health Research at UC Berkeley, we study pesticide and other exposures to pregnant women and children. Disclosure of all ingredients would improve our ability to study pesticide exposure and potential health effects in these susceptible populations. The US EPA and State pesticide registration procedures provide clear guidelines for the risk evaluation of pesticide active ingredients and determining appropriate uses. Nonetheless, the history of pesticide regulation shows that post-market evaluation can result in registration changes. For example, the pesticides diazinon and chlorpyrifos were removed from home pesticide use about 10 years ago due to new concerns about health risks. Thus, changes in registration may occur for active ingredients once deemed safe when used according to pesticide labels. Information on other ingredients in pesticide formulations should be available so that researchers can determine if they may have health consequences. Including disclosure of all ingredients in pesticide formulations would simply mean changing packaging labels and would not add additional costs to the manufacture and distribution of pesticide products. Given that some “inert” or other non-label ingredients may pose health concerns, requiring the disclosure of these materials would reflect a basic commitment to transparency in the pesticide registration and regulatory process. Once again, thank you for the opportunity to comment on this proposal. Please feel free to contact us if you need more information. Sincerely, Asa Bradman, PhD, M.S. Brenda Eskenazi, PhD Kim Harley, PhD, MPH