[Table of Contents]{.underline}

Background 1

Comments Regarding Proposed Rulings 2

Possible Solutions 5

Conclusion 6

References 7

[Background]{.underline}

According to EPA's (2008) Pesticide Reregistration Facts, all pesticides
sold or distributed for human consumption in the United States must be
registered and meet tolerances under the Federal Food and Drug Cosmetic
Act (FFDCA) as amended by the Food Quality Protection Act (FQPA) of
1996, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),
and the Environmental Protection Agency (EPA). In agricultural terms, a
tolerance is described as the maximum concentration (ppm) of pesticide
chemical residue legally allowed to remain at market. Industries such as
crop production, animal production, food manufacturing, and pesticide
manufacturing must abide by these regulations. If industries refuse to
meet regulations, their foods containing pesticides are considered
harmful. Scientists are able to monitor safe tolerance levels of a
pesticide by achieving the maximum crop residue as is allowed under the
current regulation and comparing that to human health implications; the
tolerance level is usually set slightly above the maximum crop residue
provided it is still safe. A safe tolerance is defined as one where,
"there is a reasonable certainty that no harm will result from aggregate
exposure to the pesticide chemical residue" (EPA, 2008).

Before the Agency can propose to reregister a pesticide or reassess a
tolerance, they must assess current industrial use of the pesticide as
well as current studies on human and environmental health risks (EPA,
2008). They take into account FQPA's specifications to consider all
sources of pesticide contaminant, the cumulative toxicity effects on the
general population, and the safety of infants and children. After the
pesticide has been evaluated, EPA submits a Reregistration Eligibility
Decision (RED) which describes any exposure risks or concerns they have.
The Agency also submits a Tolerance Reassessment Progress and Risk
Management Decision (TRED) which describes their reason for amendment of
the pesticide's tolerance as long as it meets FFDCA's safety standard of
"reasonable certainty of no harm" (EPA, 2008). Both REDs and TREDs allow
EPA to make revocations, modifications, and recommendations on
commercial pesticides.

While this docket proposes tolerance actions on multiple pesticides, my
comments are focused on the proposed rules concerning the revoking and
modifying of fenamiphos residue tolerances. Fenamiphos is part of the
family of organophosphates which represent a broad class of different
structural and chemical compounds (Astroff & Wagner, 1998).
Organophosphate compounds are the most prevalent pesticides used in the
United States (Coronado, Vigoren, Thompson, Griffith, & Faustman, 2006).
Fenamiphos is a Category I Restricted Use Pesticide (RUP) meaning high
mammalian toxicity and is its label reads "Danger " or "Poison" (Cornell
University, 1994). Specifically, it is used to rid of nematodes or round
worms on crops and can therefore be called a nematicide. It works by
inhibiting cholinesterase activity (Astroff & Wagner, 1998). In 1969,
Bayer CropScience developed Nemacur, the most common form of fenamiphos
in the agribusiness world (Cornell University, 1994). However, as a
result of EPA's review of organophosphates, Bayer was forced to
terminate all production of Nemacur effective May 31, 2007 (Crow, 2005).

[Comments Regarding Proposed Rulings]{.underline}

*"Proposal to revoke the tolerance in/on cotton, undelinted seed in 40
CFR 180.349(a)(1) for fenamiphos residues."*

Not only is cotton is a major crop produced in the United States,
according to a study conducted by EPA's Biological and Economic Analysis
Division, more then 60% of all organophosphates used in agriculture are
applied to corn and cotton fields (Guillebeau, 2002). Cotton fields
provide habits for many edge species of birds. These birds do not
adversely affect the crop, but nest along the edge of cotton fields and
feed on its insects (Palmer & Bromley, 2006). A study conducted in 1978
found that 35% of quail nesting near cotton fields had high enough
levels of organophosphates in their system to produce sickness or death
(Palmer & Bromley, 2006). The LD~50~ value for fenamiphos in a variety
of birds ranged from 1.0 to 2.4 mg/kg indicating how toxic it is to this
wildlife (Smith, 1993). In 2000, Sonoma County, California experienced
the death of more then 400 birds resulting from a leaky pipe used to
administer Nemacur to a vineyard (Bliss, 2000). Furthermore, out of
three different nematicides used in cotton production, Palmer and
Bromley (2006) express that Nemacur was one of the most hazardous
because of its long duration in soil and rate of wildlife mortality. The
authors go on to describe the hazards of Nemacur in the following
wildlife: In birds, the active ingredient has caused mortality and is
highly toxic with LC~50~ \< 500 ppm. In mammals, it is highly toxic with
LC~50~ \< 500 ppm and in fish, it is extremely toxic with a 96-hour
LC~50~ \< 0.1 ppm (Palmer & Bromley, 2006). Therefore, because of this
new information presented, I propose cotton, undelinted seed remain at
its current residue tolerance of 0.05 ppm (Code of Federal Regulations,
2007).

*"Proposal to revoke all of the tolerances in 40 CFR 180.349(a)(2) for
raw agricultural meat commodities."*

As far as the pathway of pesticides into dairy products, Liener (2002)
explains that, "Because of the widespread distribution of toxic
substances in plants used as feed or forage for cows, it is not
unexpected that cow's milk can be the back door whereby many naturally
occurring toxins can gain entry into the food chain" (p. 175). The most
common pesticides found in milk include organochlorine derivatives,
polychlorinated biphenyls, organophosphates, and pyrethroids (Liener,
2002). For example, Gronberg, Flint, and Pither (1974) conducted a study
on the main metabolite in fenamiphos, fenamiphos sulfoxide, to
investigate the distribution of the compound in cattle. In soil,
fenamiphos is oxidized to its metabolites fenamiphos sulfoxide and
fenamiphos sulfone both of which have similar properties to its parent
compound (Singh, Walker, Morgan, & Wright, 2003). A lactating dairy cow
was administered a single dose of fenamiphos sulfoxide according to its
body weight and diet (Gronberg et al., 1974). A fenamiphos residue was
identified at 0.004 mg/kg in fat, 0.006 mg/kg in liver, and was non
detectable or less then 0.001 mg/kg in meat, kidney, and milk. A
fenamiphos sulfoxide residue was identified at 0.002 mg/kg in liver and
milk and non detectable in fat, meat, and kidney (Gronberg et al.,
1974). Concentrations of residues found at 0.002 mg/kg or higher in this
study are slightly higher then EPA's current residue tolerance on cattle
fat, meat, meat byproducts, and milk set at 0.05 ppm (Code of Federal
Regulations, 2007). In a similar study conducted by Schenk and Wagner
(1995), samples of grade A homogenized milk and raw milk were fortified
with five organophosphorus and organochlorine pesticide residues. The
average recovery for both sets of pesticide residues was almost
identical with 75.0-104.5% of organophosphorus residue recovered in the
milk. Therefore, because Grogen et al. (1974) demonstrated the ability
for fenamiphos and its metabolites to be found in an animal commodity
and Schenk and Wagner (1995) recovered such a high percentage of
organophosphate residue in milk, EPA should reconsider revoking the
tolerance for all raw agricultural meat commodities with particular
emphasis on residues in cattle.

*"Proposal to establish an expiration/revocation date of December 31,
2009 on tolerances in 40 CFR 180.349 for fenamiphos residue on all
commodities except for those imported (banana; fruit, citrus, group 10;
citrus dried pulp; citrus, oil; garlic; grape; and pineapple)."*

I propose to add the commodity apple, part of the pome fruit family, to
the list of import commodities. Coronado et al. (2006) conducted a study
on farm workers and their families across 24 communities in eastern
Washington State for organophosphates in urine. Over long periods of
exposure, deficits in verbal and visual attention and lapses in memory
have been observed. Crops that the sample harvested were grouped into
pome fruits (apples, pears) or non-pome fruits. Farmers who worked with
pome fruits had significantly higher concentrations of organophosphate
metabolites in their urine. Because these farmers and their families
also showed elevated levels of metabolite concentrations in their homes
and vehicles, Coronado et al. (2006) results was able to support the
take-home pesticide pathway of exposure. Therefore, because pome fruits
have shown to contain increased levels of organophosphate, EPA should
also keep the current tolerance for the apple commodity at 0.25 ppm
(Code of Federal Regulations, 2007).

[Possible Solutions]{.underline}

I am proposing EPA educate and establish regulations for farmers in
alternative methods to pesticide use and how to minimize their impact on
wildlife. Crow (2005), a landscape nematologist, conducted a two year
study on the effects of using alternatives to nematicides on golf turfs.
He was able to improve both turf density and turf color using a mustard
bran product or natural nematicide. Because golf courses rely heavily on
pesticides for the quality of turf and their susceptibility to
nematodes, unwanted runoff is created affecting the environment
surrounding the course. Two examples of this type of impact on the
environment include reports of duck poisonings on golf courses in
Australia (APVMA, 2003) and fish poisonings in the Swan River, Australia
after heavy application of fenamiphos (Swan River Trust, 1998). As far
as protecting wildlife, Palmer and Bromley (2006) suggest cultural
practices such as harvesting and planting during appropriate seasons,
rotating crops, and using IPM techniques all of which help to reduce
pesticide use as well.

[Conclusion]{.underline}

The comments I have submitted for EPA review reflect in depth research
on past studies and current regulations regarding the pesticide
fenamiphos. The following is a summary of these comments. In accordance
with EPA's proposal to revoke the tolerance in/on cotton, undelinted
seed in 40 CFR 180.349(a)(1) for fenamiphos residues, I propose cotton,
undelinted seed remain at its current residue tolerance of 0.05 ppm. In
accordance with EPA's proposal to revoke all of the tolerances in 40 CFR
180.349(a)(2) for raw agricultural meat commodities, I propose EPA
reconsider the revocation specifically with regard to residues in
cattle. In accordance with EPA's proposal to establish an
expiration/revocation date of December 31, 2009 on tolerances in 40 CFR
180.349 for fenamiphos residue on all commodities except for those
imported (banana; fruit, citrus, group 10; citrus dried pulp; citrus,
oil; garlic; grape; and pineapple), I propose that EPA keep the current
residue tolerance of 0.25 ppm for the apple commodity and add it to the
list of import commodities. Lastly, I propose EPA establish an education
program and enforce regulations for crop producers to integrate
alternative methods to pesticide use into their practices.

[References]{.underline}

Astroff, B.A. & Young, A.D. (1998). The relationship between maternal
and fetal effects

> following maternal organophosphate exposure during gestation in the
> rat. *Toxicology & Industrial Health, 14*(6), 869-889.

Australian Pesticides and Veterinary Medicines Authority (APVMA).
(2003). *The*

> *reconsideration of approvals and registrations relating to
> fenamiphos*. Retrieved April 1, 2008, from
> <http://www.apvma.gov.au/chemrev/downloads/fenamiphos_scope.pdf>.

Bliss, Shepherd (2000, December 21-27). Civil wars: opposition mounts
against forced pest

spraying. *Northern California Bohemian*.

Cornell University. (1994). *Pesticide information profile: fenamiphos.*
Retrieved March 18,

> 2008, from
> <http://pmep.cce.cornell.edu/profiles/extoxnet/dienochlor-glyphosate/fenamiphos-ext.html>.

Coronado, G.D., Vigoren, E.M., Thompson, B., Griffith, W.C., & Faustman,
E.M. (2006).

> Organophosphate pesticide exposure and work in pome fruit: evidence
> for the take-home pesticide pathway. *Environmental Health
> Perspectives, 114*(7), 999-1006.

Crow, W.T. (2005). Biologically derived alternatives to nemacur. *Golf
Course*

*Management,* 147-150.

Gronberg, R.R., Flint, D.R. and Pither, K. (1974). The metabolic fate of
nemacur sulfoxide

> administered orally to a lactating dairy cow. Report No. 41104 from
> the Chemagro Division of Baychem. Corp., submitted by Bayer AG.

Guillebeau, Paul (2002). *Georgia Pest Management Newsletter, 25*(6).

Liener, I.E. (2002). Toxins in cow's milk and human milk. *Journal of
Nutritional &*

*Environmental Medicine. 12*(3), 175-186.

Palmer, W.E. & Bromley, P.T. (2006) *Pesticides and wildlife- cotton*.
Retrieved April 3, 2008,

from <http://ipm.ncsu.edu/wildlife/cotton_wildlife.html>.

Schenk, F.J. & Wagner, J. (1995). Screening procedures for
organochlorine and

> organophosphorous pesticide residues in milk using matrix solid phase
> dispersion (MSPD) extraction and gas chromatographic determination.
> *Food Additives and Contaminants, 12*(4), 535--41.

Singh, B.K., Walker, A., Morgan, J.W., and Wright, D.J. (2003). The role
of soil pH in the

> development of enhanced biodegradation of fenamiphos. *Applied and
> Environmental Microbiology, 69*(12), 7035-7043.

Smith, Gregory J. (1993). *Toxicology and pesticide use in relation to
wildlife:*

*organophosphorus and carbamate compounds*. C.K. Smoley. Boca Raton, FL.

Swan River Trust. (1998). Annual report 1997-98. *Perth: Swan River
Trust*. 40.

United States Environmental Protection Agency. (2008). *Pesticide
reregistration facts*.

> Retrieved February 19, 2008, from
> <http://www.epa.gov/pesticides/reregistration/reregistration_facts.htm>

United States Government Printing Office. (2007). 40CFR180.349---section
180.349

> fenamiphos; tolerances for residues. Retrieved March 19, 2008, from
> Code of Federal Regulations database.