FIFRA States Restricted-Use Pesticides Even Used According To Their Label Generally Cause Unreasonable Adverse Effects

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Subject:   FIFRA States Restricted-Use Pesticides Even Used According To Their Label Generally Cause Unreasonable Adverse Effects
Date:       Fri, 29 Sep 2000 17:18:24 -0400
From:        Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To:     Paul Helliker <phelliker@cdpr.ca.gov>
          Director, State of California, Department of Pesticide Regulation 

Dear Mr. Helliker: As you can clearly see, the very definition of your "registered" Restricted-Use pesticide POISONS clearly indicates there is no safe way to use them.

FIFRA Sec: 3, (C) If the Administrator determines that the pesticide, when applied in accordance with its directions for use, warnings and cautions and for the use for which it is registered, or for one or more of such use, or in accordance with a widespread and commonly recognized practice, may generally cause, without additional regulatory restrictions, unreasonable adverse effects on the environment, including injury to the applicator, the Administrator shall classify the pesticide, or the particular use or uses to which the determination applies, for restricted use:

Well Mr. Helliker, it is obvious that Florida and the U.S. EPA already have confirmed in writing that your "registered" Restricted-Use POISONS can not "protect" or be "safely" or "environmentally" applied, using commonly recognized practice, without generally causing unreasonable adverse effects on the environment, including injury to the "applicator".  If these statements are true and constitute a valid definition, how on earth can you justify "registering" any of these terrible toxins - especially when there are so many safe and far more effective alternatives?  Why do you feel it is "reasonable" to destroy people and the environment in order to create POISON "industry" profits?

Respectfully,  Stephen L. Tvedten


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