I read the proposed regulation changes. I apologize to the moderators
for long quotes.

Matthew Shepherd (Xerces Society) wrote:

> Stop the EPA from Removing Restrictions on Pesticides

> The U.S. Environmental Protection Agency is proposing to change the
> labels for pesticides used to control adult mosquitoes. These label
> changes will weaken the basic regulations that protect our waterways,
>  aquatic and terrestrial invertebrates, including pollinators, and
> other animals from these chemicals.

The changes are a result of problems when there is a natural disaster
(hurricane was the example) and there is an explosion in the population
of mosquitoes and flies. It is a public health issue. The States had a
problem in spraying after such a disaster because of the restrictions.
The changes relate to the States (and tribal councils), not to all in
the great unwashed (as more or less noted at the very end of the post).

> Tell the EPA not to make changes to adult mosquito pesticide labels,
> because the changes will result in harming, not improving, the public
>  health and the environment.

If there is no spraying, the public health will be harmed, so there is a
contridiction here.

> (1) Keep all label protections for water bodies. Pesticides should
> not be sprayed over water unless they are proven safe for all aquatic
>  organisms. Buffer zones should be mandated for pesticides that are
> toxic to aquatic life.

The regs take this into account. The issue is emergency spraying. The
changes also require the affected species to be listed and not a broad
statement of aquatic life so the States can determine if they can or
cannot spray. The example here was the floodwaters after a hurricane.
The label will list thing like mollusks, shrimp, Barney, which, except
for the latter, would not normally be found in flood waters. The regs as
currently written do not allow spraying over any body of water, even if
they are floodwaters.

> (2) Keep bee labeling to protect pollinators, most importantly bees
> and butterflies, from being needlessly harmed. Pollinators are vital
> to life as we know it. They are responsible for much of the food we
> eat, not to mention food for wild animals. .

Depends on the definition of needlessly. Mosquitos are usually sprayed
in the evening or night, when they are most active. The change is only
if it is an emergency pronounced by the State and to protect public
health. It is not for routine spraying. In the situation noted by the
change, then the State can apply the pesticide in the day. Otherwise,
there is no change in when it can be sprayed.

> (3) Fully disclose all aquatic species that may be impacted by the
> pesticide, whether the animals have been specifically tested or if
> evidence from related species indicates that they may be harmed by
> specific pesticides. Species lists on labels should not be limited
> only to groups that have been subjected to tests on that particular
> pesticide.

Part of this is in the change, to state what species are impacted so the
State has better info on what to base there decision. I have no idea how
you would implement the last sentence in the preceeding paragraph.

> (4) Mandate consultation with state and local agencies before
> spraying to assure that all regulations and laws are being followed
> and that there are no at-risk species, including invertebrates, in
> the area that might be harmed by spraying.

It is the State or Tribal agency that is doing the authorization. The
change also narrows who can spray. Part of the change requires them to
notify the public of any spraying. This seems reasonable until you have
to figure out just who needs to be consulted. Again, this is not a
private companmy or group that is authorizing the spraying, it is the State.

> (5) Not give a "blank check" permitting pesticide spraying at any
> time, in any place when there is a perceived "public health threat."
> After all this time living with mosquitoes, mosquito abatement
> districts and vector control offices should have plans in place to
> control mosquito levels using techniques and chemicals with the least
>  impact on human health and the environment.

Even the EPA notes that there are different levels of pesticide control
in the States, which is why the change narrows who can do the spraying.
This is an area of concern, and the EPA agrees there needs to be
stricter controlls. Hence part of the change.

> Note: the proposed changes would apply only to products labeled for
> wide-area application of adulticides (not larvicides) by ground or
> aerial equipment, typically as Ultra Low Volume sprays or fogs, and
> not to home and garden use products that may list mosquitoes on the
> label. ________________________________________________________

True. But I would have put this at the top (as I did), not at the end
after all the links and just before my signature.

The change also makes the pesticide only for mosquitoes and not anything
else, so the same pesticide, if broad based on the label (even if
restricted to qualified appliers), will still be restricted in its use
near water. The label for the mosquitoes only pesticide is restricted to
approval by the State for use over/near water and, in those cases, only
for emergency public health. Otherwise, its use is as before- not to be
used over or near water bodies.

In a nutshell, not much has changed here for bees except if they are
near a water source after a natural disaster and there is a public
health problem. We will still have to be notified. It was interesting
that bees were a major issue with the EPA in protecting them as much as
possible, even with the emergency authorization.

The changes looked reasonable to me. The major problem is the level of
competency and control in individual States, but that is a problem now,
before the change in the regs (as noted by the EPA). Just look at many
posts on this list about pesticide spraying. Truth is, in those cases,
it did not matter what the regs said.

Bill Truesdell
Bath, Maine

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