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Office of Pesticide Programs Stakeholders Letter

Dear Stakeholder:

I wanted to share with you a recent Federal Register Notice the Environmental Protection Agency issued responding to recommendations of the Children's Health Protection Advisory Committee (CHPAC). CHPAC was formed to advise, consult, and recommend to the EPA, actions that would help prevent adverse health effects on children. We support the goals set forth by this committee and believe that their recommendations, and our responses, are consistent with the efforts we have already begun in our work to implement the Food Quality Protection Act and our existing regulatory framework under the Federal Insecticide, Fungicide, and Rodenticide Act.

In their report to EPA's Office of Children's Health Protection (OCHP) in May 1998, the advisory committee issued recommendations to re-evaluate eight issues in light of children's health protection goals. Three major areas concern pesticide regulation:

  1. Implementation and enforcement of the Worker Protection Standard (WPS);
  2. The drinking water maximum contaminant level (MCL) and pesticide tolerances (pesticide residue limits on foods) for atrazine; and
  3. Pesticide tolerances for methyl parathion, dimethoate, and chlorpyrifos.

Since these issues have been the subject of considerable debate and dialogue within OPP and its stakeholder community, I would like to share some thoughts with you regarding how these efforts relate to our work in OPP.

The Office of Pesticide Programs (OPP) agrees with CHPAC that the Agency needs to improve its regulatory efforts to protect the health of children in agricultural areas. We believe that we can do this without making significant regulatory changes to the existing worker protection standards, focusing instead on a broad-based review of our current implementation and enforcement policies for the existing standards. This review will include internal evaluations plus dialogue with the Department of Agriculture (USDA), the Department of Labor (DOL), and the Department of Health and Human Services (DHHS). Also in the group will be state regulators, state extension service safety educators, farm worker advocacy groups, farm worker service/training associations, agricultural employer associations, farm worker clinicians networks, and others to provide national direction to state programs.

In response to CHPAC's recommendation to reassess the drinking water MCL and pesticide tolerances for atrazine, EPA's Science Advisory Board and the FIFRA Scientific Advisory Panel will examine key issues regarding the risk assessment in fall 1999. Based on recommendations from these two advisory groups, we will complete a comprehensive review of the triazine pesticides, including atrazine. The Agency's preliminary risk assessment for atrazine should be completed by March 2000, and is expected to be published as part of the Reregistration Eligibility Decision (RED) in September 2000. EPA will also use the results of this risk assessment to review our existing drinking water standard for atrazine.

OPP agrees that we should give reassessment of the tolerances for the organophosphate chemicals like methyl parathion, dimethoate, and chlorpyrifos, top priority under Food Quality Protection Act (FQPA) implementation. As many of you know, careful evaluation of the organophosphate insecticides has been a major focus. Our commitment to OCHP is consistent with the process we have established through discussions with the Tolerance Reassessment Advisory Committee and other advisory groups. We have already completed preliminary risk assessments on 28 organophosphates, including methyl parathion and dimethoate. We will also be completing preliminary risk assessments for the other registered OPs including chlorpyrifos, which are now in various phases of the review process. After evaluating the comments we receive, and working with USDA, we will begin a period of public comment on risk management for these pesticides. You can review the preliminary risk assessments, and other documents related to EPA's ongoing review of the OPs, on our internet web site by visiting

Let me emphasize that we see continued dialogue through CHPAC, TRAC, and PPDC as critical to our continued progress in protecting public health and the environment. Each group gives us a perspective on the important issues. We also recognize that ensuring consistency across efforts is important. The CHPAC recommendations and the commitments that rise out of them are important steps in protecting children. These commitments are faithful to the work we have already begun with OPP stakeholders to protect workers, children, and the safety of our nation's food supply.


Marcia E. Mulkey
Office of Pesticide Programs

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updated February 26, 1999