Cumulative Risk Assessment May Be Difficult for Some Pesticides

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Subject:    Cumulative Risk Assessment May Be Difficult for Some Pesticides
 Date:        Fri, 13 Apr 2001 10:33:52 -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 

cc:    Christine Whitman whitman.christine@epa.gov

Dear Mr. Helliker,  I thought you might like to read an article entitled: Cumulative Risk Assessment May Be Difficult for Some Pesticides

In addition to the individual risk assessments required by FQPA, this law also mandates that a cumulative risk assessment be conducted for pesticide groups which have a common toxicological effect. The idea behind the cumulative assessment is that lifetime exposure (and consequent effects) may be greater for a group of compounds with similar mode of toxicity than for a single compound. In addition to having the same toxic effect, the criteria outlined by the EPA requires that the toxic effect be expressed in the same organ or tissue and that the pesticides cause an effect by a common mechanism. The organophosphates, carbamates, and pyrethroids are believed to be three groups that fulfill the definition. However, it may be difficult to find common groups other than these three.

Beyond the common mechanism grouping, scientists performing the assessments will be tasked with trying to normalize the potencies of compounds. For instance, one OP insecticide may be twice as effective as another, and thus have twice the potency units than the less active insecticide. (Chemical Regulation Reporter Vol. 25, No.1)

Well Mr. Helliker, "The scientists" are still completely ignoring all of the "inerts", metabolites, transformation by-products, contaminants and all of the possible/probable synergistic effects.  We may never know the real danger all of your "registered" POISONS present.  The "industry' and now our "environmental" President likes to call this "sound science"!  Amazing!

Respectfully,  Stephen L. Tvedten

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