Comment submitted by George Nealis

July 22, 2026 Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 Re: Comments on Notice of Filing of Pesticide Petitions and Request for Comment — Docket IDs EPA-HQ-OPP-2025-0110 (PP 3F9099), EPA-HQ-OPP-2025-0094 (PP 4F9133), and EPA-HQ-OPP-2026-1818 (PP 6F9228) Dear Mr. Messina: I am submitting the following comments in response to the above-referenced notice of filing of pesticide petitions, published in the Federal Register (FR Doc. 2026-12417). I do not take a position for or against any of the three petitions at this time. Instead, I respectfully request that the Agency clarify several points as it evaluates the submitted data, so that the public record is as complete as possible before final action is taken. PP 3F9099 (EPA-HQ-OPP-2025-0110) — Ascribe Bioscience, Inc. — Ascr#18 The petitioner requests a tolerance exemption for residues of Ascr#18 on all raw agricultural commodities and processed food, and states that no analytical method is needed because the compound is naturally occurring and non-toxic. I would appreciate clarification on the following: 1. What baseline levels of naturally occurring Ascr#18 already exist in or on the commodities covered by this petition, and how were those levels established? 2. Given the requested exemption applies to "raw agricultural commodities or processed food" broadly, does EPA intend to request a more precise commodity scope consistent with the Food and Feed Commodity Vocabulary referenced in Unit I.C. of the notice? 3. Were the acute, subchronic, developmental toxicity, and mutagenicity studies cited by the petitioner conducted using the same application rate and formulation as the proposed end-use product (20 fl. oz. per acre), and are summaries of those studies available in the docket? PP 4F9133 (EPA-HQ-OPP-2025-0094) — CH Biotech R&D Co. — Melatonin The petitioner requests an exemption from the requirement of a tolerance for melatonin residues on all raw agricultural commodities, without any numerical limitation, and asserts that no analytical method is required as a result. I would appreciate clarification on the following: 1. Because melatonin is an endogenous hormone present in humans as well as many plants and animals, what data has the petitioner submitted to distinguish exogenous residues from background/endogenous levels, and how does this factor into the Agency's exposure assessment? 2. Does an exemption without any numerical limitation account for cumulative exposure across multiple treated commodities, and if so, how? 3. Will the docket summary include information on the intended use pattern (e.g., application method, rate, and timing) for melatonin as a pesticide, since this is not described in the notice itself? PP 6F9228 (EPA-HQ-OPP-2026-1818) — Corteva Agriscience — Sulfoxaflor The petitioner requests a tolerance for the insecticide sulfoxaflor in or on pistachio at 0.5 ppm, supported by an offline solid-phase extraction and LC-MS/MS analytical method. I would appreciate clarification on the following: 1. How does the proposed 0.5 ppm tolerance for pistachio compare to existing sulfoxaflor tolerances on other tree nuts, and what residue field trial data supports this specific commodity and level? 2. Sulfoxaflor is known to pose risks to pollinators. Does the petition include, or will EPA separately evaluate, pollinator exposure data specific to pistachio cultivation and bloom timing? 3. Consistent with Unit I.C. of the notice, will EPA evaluate whether a tolerance on pistachio nutmeat also requires a related tolerance on pistachio hulls or other rotational/feed commodities? General Request For all three petitions, I ask that EPA make the full petitioner-prepared summaries (per 40 CFR 180.7(f)) readily accessible in each docket, and that the Agency's response to comments explicitly address how public input affected the final tolerance or exemption determination, including any variation from the tolerance level, commodity definition, or scope originally requested by the petitioner. Thank you for the opportunity to comment. Sincerely, George