Title:
Comment submitted by Jennifer Sass, Ph.D., NRDC

Abstract:
On behalf of Pesticide Action Network North America (PANNA), Farm Worker Pesticide Project, Farmworker Justice and their members and affiliated organizations, as well as the ten cosigners of this letter, and on behalf of more than four million U.S. farm workers and their families who face the greatest risks from exposure to pesticides, including chlorpyrifos, we provide the following comments to the SAP to be considered in its September 16-18, 2008 review of U.S. EPA’s evaluation of the toxicity profile of chlorpyrifos. We understand that the focus of this review is on infants and children from in utero and/or post-natal exposures and on studies that evaluate population variability with respect to response to chlorpyrifos exposure; and that this evaluation will inform the Agency’s registration review of chlorpyrifos in fulfillment of its obligation to ensure that, in practice, chlorpyrifos causes no unreasonable risks to human health, workers, or the environment.