EPA should ban pesticide atrazine

November 12, 2011

Richard P. Keigwin Jr., Director
Pesticide Re-evaluation Division (7508P)
Office of Pesticide Programs (OPP)
Environmental Protection Agency
1200 Pennsylvania Ave., NW.,
Washington, DC 20460-0001

Re: Petition Requesting Ban on Use and Production of Atrazine, Docket Number: EPA-HQ-OPP-2011-0586

Dear Mr. Keigwin,

As the largest consumer-owned and consumer-operated grocer in the nation, PCC Natural Markets urges EPA to ban the herbicide atrazine.

We’re thankful for the research done by Beyond Pesticides documenting many negative health and environmental effects of this herbicide, and ask EPA to accept Beyond Pesticides’ comments — along with comments from the Environmental Resources Defense Council and the Center for Biological Diversity — as the concerns of our own 47,000 member/owners. We ask you to implement the ban requested by Save the Frogs.

We support the comments of these groups and wish to add our own perspective representing consumer concerns. A July 2011 NPR-Thomson Reuters Health Poll found that nearly six out 10 U.S. consumers — 58 percent — say they prefer to eat organic over non-organic food. Thirty-four percent say a top reason they prefer organics is concern about toxins, such as herbicides, in non-organic food.

Concern about toxic herbicides is changing the food industry and EPA policies should reflect this trend. The Organic Trade Association reports, for instance, that the organic sector grew 8 percent in 2010, dramatically outpacing the food industry as a whole, which grew less than 1 percent. Organic fruits and vegetables showed the fastest growth, up 11.8 percent from 2009 to nearly $10.6 billion in sales. This growth is reflected at our nine certified organic stores, where sales have increased by more than 8 percent this year, projected to exceed $150 million.

Regulatory agencies must consider the public’s concern about foods grown with toxic herbicides. While the European Union and other countries have banned atrazine, U.S. policies are lagging behind the views of our people.

Despite clear evidence that use of atrazine over the decades has led to widespread environmental contamination threatening public health and wildlife, it’s the most widely used herbicide in the United States – 73 to 78 million pounds are used annually, primarily on non-organic corn. It persists in soil and is the most common pesticide detected in rivers, streams and groundwater. The Department of Agriculture found it in 94 percent of drinking water tested — more than any other pesticide. U.S. Geological Survey routinely has found atrazine in rivers and other waters at levels near or above EPA’s levels of concern.

Atrazine is linked to human health problems such as endocrine disruption, cancer and birth defects. Researchers at the U.S. Geological Survey have found atrazine also harms the immune, hormone and reproductive systems of wildlife. Fish and amphibians exposed to atrazine can exhibit hermaphrodism. Male frogs exposed to concentrations within federal standards can become so female that they mate and lay viable eggs.

Less-toxic, registered pesticides and alternative practices are effective in producing corn and other food without atrazine. Since Germany and Italy banned atrazine in 1991, corn yields and acres of corn harvested actually have gone up, rather than down. Farmers in Minnesota and other states are using innovative production systems to raise corn without atrazine and, according to the Pesticide Action Network North America, banning atrazine would result in yield losses of less than 1 percent, much lower than industry estimates.

In allowing registration of atrazine, EPA currently is failing to meet its legal responsibility (under the Federal Insecticide, Fungicide and Rodenticide Act) to consider if the pesticide poses "unreasonable risk to man or the environment." EPA’s current and proposed risk mitigation measures, including best management practices, are inadequate.

EPA has said it will decide whether to revise its current assessment of the pesticide and whether new restrictions are necessary to protect public health. We urge EPA to move quickly to conclude its review of atrazine and cancel its registration.

Sincerely,

Trudy Bialic, Director of Public Affairs
PCC Natural Markets

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