Comment submitted by James Scarborough

I submit this comment regarding EPA-HQ-OPP-2025-3824, including pesticide petition PP 5F9177 for fenpropathrin and PP 6F9234 for abamectin. EPA’s notice states that Valent BioSciences, LLC has requested tolerances for residues of fenpropathrin at 0.9 ppm and abamectin at 0.1 ppm in or on all food/feed items, other than items already covered by a higher tolerance as a result of use on growing crops, when these ingredients are used in food/feed handling establishments or as wide-area mosquito adulticides. I do not read this notice as a final risk determination. EPA states that it has not fully evaluated the sufficiency of the submitted data and that additional data may be needed before making a final determination. That posture is appropriate for a notice of filing, but it also means the public record should be strengthened before EPA grants any tolerance based on these petitions. My comment focuses on four record-building requests. First, EPA should publish or summarize the residue-to-threshold rationale supporting the requested 0.9 ppm and 0.1 ppm levels. The notice identifies the requested tolerance levels, but the public-facing notice does not show how those specific ppm values follow from the residue data, exposure assumptions, application scenarios, or enforcement considerations. Before granting the petitions, EPA should provide a clear public explanation of the quantitative bridge from the submitted residue evidence to the requested tolerance levels. Second, EPA should analyze the food/feed-handling use and the wide-area mosquito-adulticide use separately. These two use patterns may produce materially different residue pathways. Food/feed-handling uses may involve residues associated with treated facilities, storage, processing, or handling environments. Wide-area mosquito-adulticide uses may involve different questions of drift, deposition, timing, location, and incidental contact with food or feed commodities. EPA should state whether the same tolerance logic applies to both use scenarios and, if so, why. If the exposure pathways differ, EPA should explain whether separate supporting analyses, restrictions, or tolerance structures are warranted. Third, EPA should provide more detail on analytical-method adequacy. The notice identifies LC-MS/MS methods for measuring and evaluating fenpropathrin and abamectin, but merely naming the method is not enough to let commenters evaluate enforcement reliability. EPA should make available, or summarize in sufficient public detail, the relevant validation information, including limits of quantitation, recovery data, matrix coverage, residue definitions, metabolite or degradate coverage, independent validation status, and any known constraints on routine enforcement. A tolerance is only meaningful if routine monitoring can reliably detect and measure the residues covered by the tolerance. Fourth, EPA should address the breadth of the phrase “all food/feed items.” A broad tolerance structure may be administratively convenient, but it can obscure important differences among commodities, matrices, and exposure conditions. EPA should identify whether any commodities, food/feed categories, or matrices require special treatment because of residue behavior, exposure potential, existing higher crop tolerances, or enforcement limitations. If EPA concludes that one broad tolerance is appropriate across all covered food/feed items, it should explain the basis for treating those commodities uniformly. To improve the final record, I ask EPA to do the following before granting the petitions: 1. Publish or summarize the residue, exposure, and enforcement assumptions supporting the requested 0.9 ppm fenpropathrin tolerance and 0.1 ppm abamectin tolerance. 2. Explain whether food/feed-handling uses and wide-area mosquito-adulticide uses produce comparable residue profiles or require separate analysis. 3. Provide public-facing method-validation detail for the LC-MS/MS methods, including limits of quantitation, matrix coverage, recoveries, residue-definition coverage, and enforcement constraints. 4. Identify whether any commodities or food/feed matrices require narrower, separate, or additional treatment. 5. State what additional data, if any, EPA believes are necessary before it can determine whether the requested tolerances satisfy the applicable FFDCA safety standard. These requests are not objections to mosquito control or to pesticide regulation in principle. They are requests for a clearer administrative record. Because EPA has expressly stated that it has not fully evaluated the sufficiency of the submitted data, the final decision should not rest only on petitioner summaries and conclusory method statements. The public record should show how the requested tolerances were derived, how the two use patterns were evaluated, and how EPA will ensure that any granted tolerances can be enforced in practice.