Comment submitted by J. R. David

Document ID: EPA-HQ-OPP-2010-0306-0004
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: September 08 2010, at 12:00 AM Eastern Daylight Time
Date Posted: September 9 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: August 25 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: February 22 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80b48d3d
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St. Lucie County has repeatedly used Resmethrin for effective mosquito control. It is very effective at extremely low dose against our saltmarsh mosquito, Aedes taeniorhynchus, and our WNv vector, Culex nigripalpus. We have seen 'little' to 'no' resistance by switching to other pyrethroids every few years, and switching back again to Resmethrin. Part of this resistance-management may involve the photolability of the product, since research on pyrethroids suggests that the shorter the term in the environment the less resistance we should see under repeated use. We also have successfully used Resmethrin in spray zones with pesticide sensitive individuals, with much less allergic sensitivity being observed. Loss of this chemical removes an effective, non-resistant, less allergenic chemical and leaves us with less resistance-management options. St. Lucie County experiences an average of 55-65 inches of rainfall per year. This level of rainfall offers a great number of mosquito breeding opportunities (billions are produced each year) and repeated spraying is required to maintain the quality of life, as well as, to protect public health. Staff recomends that you consider consultation with DHHS to fund the testing for the endocrine disruption studies, since the vendor is not in a position to do so, based on the continued usefulness and public health benefits associated with Resmethrin.

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Comment submitted by J. R. David
Public Submission    Posted: 09/09/2010     ID: EPA-HQ-OPP-2010-0306-0004

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