To whom it may concern within the Environmental Protection Agency (EPA),
My name is Timothy J. Peters, and I am currently a senior undergraduate studying Energy Resource Science at the University of Wyoming. As a part of my curriculum I am taking a course on Environmental Law and Policy, and one of our assignments is to complete a public comment on a proposed agency rule. Furthermore, I am a concerned citizen of the United States, and I am offering comments with respect to the proposed final rule making on the pesticide tolerances of the fungicide cyazofamid.
According to the summary offered by the EPA, this regulation establishes tolerances for residues of the fungicide cyazofamid in or on multiple commodities. The proposed rule would remove several established tolerances that are superseded by tolerances established by this regulation. My concerns and comments are mostly directed at the Aggregate Risk Assessment and Determination of Safety results that were found by studies completed by the EPA. Although I respect and understand the amount of work that goes into these assessments, I believe there are some substantial shortcomings in certain areas of this particular assessment. Specifically, I am concerned with the scope of the endpoints described in this proposed final rule. I believe the scope of the endpoints involved in this particular study is too narrow to fully understand the implications this final rule could have on human health and the health of the environment.
One endpoint that is briefly discussed and almost entirely left out of the risk assessment is the chronic effects cyazofamid can have on humans as a result of occupational exposure. It is mentioned under the exposure assessment portion of the EPA document that cyazofamid is currently registered for use on turf at golf courses, sod farms, seed farms, college and professional sports fields, residential and commercial lawns, and on ornamental plants in landscapes and those grown in commercial gree
Comment submitted by T. Peters
This is comment on Rule
Pesticide Tolerances: Cyazofamid
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Public Submission Posted: 11/29/2012 ID: EPA-HQ-OPP-2011-0906-0010
Nov 26,2012 11:59 PM ET