Comment submitted by Tina Bailey
AnonymousOpposeIndividual
Summary: The commenter opposes the proposed increase in allowable residue levels or application rates for afidopyropen due to concerns about environmental loading, impacts on non-target species, and pesticide resistance. They urge the EPA to conduct a transparent, science-based review that considers cumulative exposure and integrated pest management alternatives.
EPA should require a thorough, transparent, and independent review before approving any increase in the allowable residue level or application rates for afidopyropen. Increasing application rates has the potential to increase environmental loading of the pesticide, which could affect pollinators, beneficial insects, aquatic organisms, and other non-target species if appropriate safeguards are not demonstrated.
EPA should ensure that its decision is based on the most current science, including cumulative dietary exposure, potential impacts on children and other vulnerable populations, and any new information regarding chronic toxicity or ecological effects. Any approval should be supported by clear evidence that the proposed changes continue to meet the statutory requirement of providing a reasonable certainty of no harm.
I also encourage EPA to carefully evaluate whether increased application rates could contribute to pesticide resistance, resulting in greater long-term pesticide use and additional environmental impacts. Integrated pest management practices and alternatives that reduce reliance on chemical controls should be considered whenever feasible.
Finally, EPA should maintain a transparent public process by making all relevant risk assessments, supporting studies, and ecological analyses readily available for public review before making a final decision. Protecting public health, pollinators, biodiversity, and the long-term sustainability of agriculture should remain central to EPA's evaluation.