EPA ignores SAP feedback, continues on path toward chlorpyrifos revocation
WASHINGTON, DC – On Nov. 24, the U.S. Environmental Protection Agency (EPA) released documents to the federal docket regarding food-use tolerance revocations of chlorpyrifos. This proposed action follows a long review of chlorpyrifos that has included three separate Scientific Advisory Panels (SAPs), the first two held in 2008 and 2012 and the most recent this past April (see transcript). All three SAPs came to the same conclusion, questioning EPA’s shift to the use of certain epidemiological study outcomes rather than toxicological data in human health risk assessments. In particular, the SAPs have cautioned EPA against using the study outcomes from the Columbia Center for Children’s Environmental Health (CCCEH).
EPA has not consistently provided opportunity for stakeholder input and, generally, has not responded to the thousands of comments that have been submitted on the chlorpyrifos docket. “EPA’s most recent move represents a major proposed action that sets a precedent of using study outcomes for regulatory decision making in lieu of laboratory data. This change in approach creates an unpredictable system for companies that have put hundreds of millions of dollars and decades of work into ensuring their products meet the highest human health and safety requirements,” stated Jay Vroom, president and CEO of CropLife America (CLA). “Upon examination of the 55 documents, the decision to continue on the path toward the revocation of a vital crop protection product seems to have been made with almost no new relevant information to back the result.”
“EPA stated that it planned to revise its previous approach to drinking water assessment. Yet upon initial review of the docket, nothing has changed to enhance the refinement of the models,” noted Dr. Janet Collins, senior vice president of science and regulatory affairs at CLA. “The overly conservative assumptions used in both the human health and the drinking water assessments create unrealistic limitations to the use of chlorpyrifos. We are disappointed that EPA continues to use the epidemiological study reports from the literature to assess exposure and health outcome when, as they state, EPA does not have access to the data that can be used in a meaningful and relevant risk assessment. Rather, EPA has added assumptions based on expected use of chlorpyrifos with no record of actual use.”
Due to the volume of data added to the docket, CLA will need the full 60 days allotted to review the documents adequately and prepare comments.