From: Leap, Sherrill [mailto:sleap@...]
Sent: Wednesday, October 24, 2007 11:53 AM
To: Hakim, Jacquelyn; Forte, Leonard; Barbara Lathrop; Brian Pilarcik; Brian Swistock; Ed Molesky; Frank X. Browne; Fred Lubnow; Gretchen Schatschneider; Jack Hanish; Jason Smith; Joe Gallagher; Lance Bowes; Lorraine Sloss Amato; Mike Lovegreen; Todd Sampsell
Subject: FW: [volmonitor] Opportunity to comment on better pesticide labeling

This sounds like something licensed applicator-type people and those concerned with lakes and water quality might be interested in commenting on, either yea or nay.  This was sent out on the Volunteer Monitoring list, which will gather some comments, but people using the stuff must have some opinion since they are the ones directly affected.  It shouldn't change much of what you guys probably do, since most of the changes just reinforce common sense (which we all possess, right?). 

 Subject: Re: [volmonitor] Opportunity to comment on better pesticide labeling

The list has been discussing how volunteer monitors should move to the next level, action. Here is a pretty non-controversial opportunity to be effective in the area of water pollution from pesticides:

U.S. EPA has proposed to revise its guidance for certain directions on the labels of pesticide products sold retail (U.S. EPA calls these "residential pesticides").  Current instructions are vague: "Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate."  Folks who buy these products can logically conclude that it's OK to apply common products like Round-Up -- with surfactants lethal to aquatic life -- just before rain, or right where water will rise on the next high tide.  

Basically, the proposed instructions are clearer and more specific. For example, for liquid concentrates:

    "To prevent contamination of the environment, do not apply near
    water, storm drains, gutters or ditches. Do not apply when rain is
    predicted for that day or when wind is strong enough to carry spray
    away from treatment area. Rinse applicator equipment over the lawn
    or garden area that was treated, and away from water, storm drains,
    gutters or ditches."

This language would not be required. Manufacturers would be able to use a streamlined process to voluntarily put this language on their labels. U.S. EPA also could require this language on a product-specific basis when it registers or is reviewing registration of products. Different language could be used case-by-case at EPA's discretion (i.e., the notice says that products that should be watered in or that claim to be "rain resistant" can omit the instruction not to apply when rain is forecast).

The proposal would almost certainly be an improvement. One might discuss whether it goes far enough. 

In any event, U.S. EPA is accepting comments on this proposal until Friday, November 2. Commenting instructions -- which are important to follow exactly -- are at http://www.epa.gov/fedrgstr/EPA-PEST/2007/October/Day-03/p19448.htm.

This document also includes the rather elaborate instructions you need to follow exactly in order to download the proposal itself. (It's hard to believe they have to be that complicated. If nothing works, email me and I'll send you the document.)

I hope that the EPA will hear from groups nationwide who are concerned about water pollution, supporting or seeking to strengthen this proposal. Thanks to Kelly Moran of TDC Environmental and the Urban Pesticide Pollution Prevention Project for information.

Susan Schwartz, President

Friends of Five Creeks

See what's new at AOL.com and Make AOL Your Homepage.