Steve Tvedten of Get Set, Inc.'s email to Lyndon Hawkins of the California Department of Pesticide Regulation .

Questions have been asked of the California Department of Pesticide Control since Fontana Unified School District declined to consider a pesticide free IPM program because of the Department of Agriculture's opinion about only utilizing registered pesticides to eliminate pests.  The California Department of Pesticide Regulation has remained silent and not responded to these issues:

Lyndon, I thought you might like to read a recent press release:  The Consumers Union Calls EPA'S Implementation of the Food Quality Protection Act Inadequate to Protect Public Health from Pesticide Poison Risks--------

WASHINGTON - Consumers Union today released an analysis of the Environmental  Protection Agency's (EPA) reassessment of over 3200 pesticide tolerances, which the EPA is required to do under the Food Quality Protection Act (FQPA). The CU analysis shows that EPA's actions are inadequate to protect public health from the hazards of pesticides in foods.

"Our analysis shows that EPA has failed to do its job", said Dr. Edward Groth, Director of Technical Policy and Public Service at Consumers Union. "The FQPA requires EPA to ensure that foods are safe for children and to act swiftly on the real world exposures that have the greatest potential to cause harm. If this were a report card, EPA would earn an 'F.'"

Under FQPA, the Agency has to "reassess" all of its legal limits for specific pesticide residues in specific foods, called tolerances. The law gives EPA 10 years to reassess some 9,700 tolerances now on the books, and the Agency has until August 3, 1999-three years after the Act was signed-to complete its reassessment of the first third, 3,200 or so tolerances. The law requires EPA to give priority in this initial phase to pesticide uses that pose the greatest risk to public health.

The FQPA also imposes some very important new requirements in terms of how EPA must assess pesticide risks. The law requires, among other things, that EPA consider the aggregate risks of all of the different ways people are exposed to pesticides-in foods, drinking water, and in their homes and schools-and consider the additive risks of residues that share a common mechanism of toxicity.

"The mandate in FQPA is very clear-EPA must deal with the 'worst first,'" Groth added. "While EPA claims to have met the numerical goal of FQPA, many of the reassessed tolerances are for obsolete or minimal uses with no impact on food safety. In fact, EPA actions up to now have reduced the risk from only two out of the 125 riskiest pesticide uses on foods, and have actually allowed more risk in seven cases. This is a pathetic record."

Consumers Union listed the 125 pesticide uses that account for 99 percent of dietary risk based on its own analysis of toxicity data from the EPA and residue data from the U.S. Department of Agriculture. EPA pesticide regulatory actions announced prior to today affected only 9 of the 125 riskiest pesticide-food combinations. Of those nine tolerances, EPA revoked one, lowered one, and actually increased the other seven. The Agency also has reassessed, but made no changes in, tolerances for 21 more uses.

In addition to failing to reduce the risks from the vast majority of high-priority food-chemical combinations, the EPA has taken few concrete steps to assess the risks of multiple routes of pesticide exposure, or to consider the additive risks of multiple residues in the diet. Until it can accomplish these tasks, EPA cannot demonstrate that the actions it has taken so far on tolerances are adequate to protect children's health.

EPA will announce additional regulatory action today on two high risk insecticides, methyl parathion and azinphos-methyl. Twelve uses of these two very toxic insecticides are among the 125 highest-risk uses. Indeed, these 12 uses account for 23 percent of the overall dietary risk in Consumers Union's analysis.

"Even if EPA does revoke or severely restrict all 12 of those uses," Groth noted, "that means that the cumulative effect of their actions at the three-year mark would affect only 25 percent of the dietary risk. This performance is unacceptable. We urge the Administration to keep its promises to protect children's health by speeding its review of high-risk tolerances and aggressively reducing exposure from the small number of readily identified pesticide uses that drive dietary risk."

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Consumers Union, publisher of Consumer Reports magazine, is an independent nonprofit testing, educational and information organization serving only the consumers. We are a comprehensive source of unbiased advice about products and services, personal finance, health, nutrition and other consumer concerns. Since 1936, our mission has been to test products, inform the public and protect consumers.

Lyndon, unfortunately no one can stay on the fence forever, you either have to be part of the problem or part of the solution.  What are you really for - the public health or poison industry profits?  Respectfully,  Stephen L. Tvedten.