Anonymous public comment

It is plausible that several of the current or future-use pesticides might exert trans-generational epigenetic effects that have not been studied yet. Families of applicators may be at highest risk for these kinds of effects. It is hard to imagine a scientifically valid study of these effects that would not require inclusion of children (but these children need not be exposed). A finer distinction should be made in the regulation between assent of children to participate in studies where they will be exposed to a pesticide, and assent of children to participate in studies where someone else will be exposed to a pesticide. On another note, the phrasing of this proposed regulation is very broad and I worry could have a negative impact on research intended to intervene against the childhood obesity and diabetes epidemics, which disproportionately affect socially and environmentally disadvantaged communities. Is consumption of a conventional apple in an obesity study considered an intentional exposure to pesticide? EPA should clarify in its final regulation that this statute does not limit assent of minors for studies involving conventionally grown foods.