December 2, 2005
Comments on Flumiclorac pentyl submitted
to US EPA
Via email: firstname.lastname@example.org
Docket No. OPP-2005-0311
Fluoride Action Network Pesticide Project
82 Judson Street, Canton NY 13617
30, 2005, Pesticide petition for Flumiclorac pentyl
Would EPA please clarify the following:
The August 23, 2005, "Report of the Food Quality Protection
Act Tolerance Assessment Progress and Risk Management Decision
for Flumiclorac pentyl" states:
"An aquatic phototoxicity
study is being required for light-dependent peroxidizing herbicides,
including flumiclorac pentyl. Note: This is a new data requirement
and will be required under a group DCI for Light-Dependent Peroxidizing
Herbicides to be sent under separate cover - (page 7)." This
document is Docket
1. EPA needs to provide more information concerning this study,
including when the study began or when it will begin, and when
results are expected to be available.
2. Would EPA please place in the Docket the new data requirement
"under a group DCI" that is referred to.
3. Will this study be a condition for the pesticide tolerance
(PP 3F6767) if it is approved? If EPA does not make it a condition,
would they please offer their rationale for not doing so.
Concerning the animal studies referred to in the HED Chapter
of the TRED (Docket
4. There is no mention to the amount of light these animals
were subjected to during these studies. Would EPA please comment
on whether the protocols utilized in of all studies cited were
appropriate for ascertaining phototoxic effects.
5. In its determination of risks to exposed individuals (infants,
children, adults, workers, bystanders) did EPA consider the
phototoxic effects of flumiclorac pentyl. Would EPA please offer
to the public its discussion on this issue. If EPA did not consider
the phototoxic effects of this pesticide, how can they assume
it is safe.
Lastly, in the petition it states that "a description of
the analytical method available for the detection and measurement
of the pesticide chemical
residues is available on EPA's Electronic Docket." As of
this date, there is no information available in this docket.