UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

CERTIFIED MAIL 

Dr. Kerry Kriger 

Executive Director, Save the Frogs 

303 Potrero Street #5 1 

Santa Cruz, CA 95060 

AUG 2 7 2013 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

Re: Response to Save the Frogs May 6, 20 I I Petition Requesting a Federal Ban on the Use and 

Production of Atrazine 

Dear Or. Kriger: 

The Environmental Protection Agency (EPA or the Agency) Office of Pesticide Programs (OPP) 

received Save the Frogs' May 6, 201 1 petition requesting "a federal ban on the use and 

production of Atrazine." The petition included over 10,000 signatures; several statements from 

members ofthe public; and two brief summaries of published literature, one by Dr. Jason Rohr 

and one by Dr. Tyrone Hayes that is co-authored by 39 other scientists. In conjunction with the 

petition, EPA received nearly 50,000 emails from supporters of the Center for Biological 

Diversity and the Natural Resources Defense Council requesting that EPA immediately take 

steps to phase out atrazine use in the United States, and asserting that atrazine poses an 

unreasonable risk to the environment. The emails expressed concern for impacts on amphibians 

and other aquatic species as well as concern for potential risks to human health. 

On September 14,2011, EPA armounced receipt ofthe Save the Frogs' atrazine petition in the 

Federal Register (76 FR 56745) and posted the petition in the public docket (EPA-HQ-OPP2011-0586) for a 60-day public comment period during which interested stakeholders could 

review and comment on the petition. During the comment period, EPA received approximately 

I ,300 comments from a wide range of stakeholders including members of the public, pesticide 

industry groups, farmers, environmental non-profit groups, and farm growers associations, 

representing those both supporting and opposed to the requested atrazine ban. The Agency has 

conducted a preliminary review of the public comments to identify any new information or 

points of view. 

Save the Frogs' atrazine petition is not sufficient to support the requested relief under the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. § 136 et seq. Regarding 

the request that EPA ban use of atrazine, EPA reviewed your petition as a request for EPA to 

cancel and suspend atrazine's registrations. 

Internet Address (URL) • hHp:f/www.epa gov 

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In order to cancel a pesticide's registration for risk reasons, EPA must make a determination that 

use of the pesticide "generally causes unreasonable adverse effects on the environment." [FIFRA 

§ 6(b)]. The statute provides that "unreasonable adverse effects on the environment" means "any 

unreasonable risk to man or the environment, taking into account the economic, social, and 

environmental costs and benefits ofthe use of any pesticide." [FIFRA § 2(bb)(1)]. 1 FIFRA also 

provides authority for EPA to suspend the registration of a pesticide if it determines that "action 

is necessary to prevent an imminent hazard during the time required for cancellation" 

proceedings [FIFRA § 6(c)]. The statutory definition of"imminent hazard" is "a situation which 

exists when the continued use of a pesticide during the time required for cancellation preceeding 

would be likely to result in unreasonable adverse effects on the environment or will involve 

unreasonable hazard to the survival of a species declared endangered or threatened." [FIFRA § 

2(1)]. This standard incorporates FIFRA's risk-benefit "unreasonable adverse effects" standard. 

EPA reviews all pesticides periodically against this standard and continually updates regulatory 

assessments based on new scientific data or other information. Under the FIFRA reregistration 

program, EPA completed a detailed examination of whether use of atrazine products causes 

unreasonable adverse effects on the environment. In 2003 EPA issued an Interim Reregistration 

Eligibility Decision (IRED) finding that atrazine products could meet the risk-benefit standard of 

FIFRA provided certain changes were made to the terms and conditions ofregistration.2 Since 

2007, EPA has held nine FIFRA Scientific Advisory Panel (SAP) meetings for atrazine as the 

state of the science has continued to evolve and new data have become available. The most 

recent SAP meeting was held from June 12- 15,2012. In general, the 2012 SAP recommended 

that EPA further analyze existing data; the SAP also provided more specific recommendations 

including additional refinements to the methodology, and alternative approaches for EPA to 

consider when interpreting uncertainty in atrazine water monitoring data. 

EPA recently began the registration review process for atrazine. Registration review is EPA's 

periodic re-evaluation program pursuant to Section 3(g) of FIFRA to ensure that, as the ability to 

assess risk evolves and as policies and practices change, all registered pesticides continue to 

meet the statutory standard of no unreasonable adverse effects on the environment. The 

registration review process for atrazine started on June 26,2013 with the opening of the docket 

for a 60-day public comment period on the Agency's Preliminary Work Plan (PWP). The PWP 

describes how EPA intends to update the human health and ecological risk assessments for 

atrazine. The PWP and its supporting scientific documents explain what EPA knows about 

atrazine, highlighting anticipated data and assessment needs, identifying the types of information 

that would be especially useful to the Agency in conducting the review, and providing an 

estimated timeline for completion of the atrazine registration review. The Final Work Plan for 

1 The definition of the term in FIFRA section 2(bb )(2) also includes "a human dietary risk from residues that 

result from a use of a pesticide in or on any food inconsistent with the standard under section 346a ofTitle 21" 

(section 408 of the Federal Food, Drug, and Cosmetic Act). However, your petition did not include any assertions 

regarding a human dietary risk from atrazine residues in or on food. 

2 The 2003 IRED addressed risks.associated with the chemical other than potential cumulative dietary risk from 

exposure to all triazine pesticides. In 2006, EPA completed a cumulative dietary risk assessment for all triazine 

chemicals and determined that dietary exposure to the triazines meets the safety standard in section 408 of the 

Federal Food, Drug, and Cosmetic Act (FFDCA). 

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Registration Review, expected around November 2013, will address public comments received 

on the PWP. The procedures for registration review provide multiple opportunities for public 

participation, ensuring that all regulatory decisions related to atrazine will be developed in a 

transparent manner. EPA will also take the recommendations from the SAPs into account as it 

updates the state of the science during the registration review of atrazine. 

In summary, the 2003 IRED determined that atrazine products could meet the risk-benefit 

standard of FIFRA, and the 2006 cumulative assessment determined that dietary risks posed by 

atrazine meet the safety standard in section 408 of the FFDCA. Petitioners do not point to any 

asserted deficiency in any of the assessments that supported the Agency's 2003 and 2006 

determinations; they do not assert why the regulatory determinations were incorrect in light of 

the underlying assessments; and they do not identify any new information or circumstances that 

could warrant a different regulatory determination. Under such circumstances, the petition fails 

to demonstrate that immediate regulatory action is either necessary or appropriate. Therefore, 

EPA finds that the atrazine registration review process is the most appropriate mechanism for 

EPA to fully evaluate whether atrazine pesticide products continue to meet the FIFRA standard 

for registration or whether regulatory action is called for, and hereby denies Save the Frogs' 

petition. 

Please contact Monica Wait at (703) 347-8019 or wait.monica@epa.gov if you have any 

questions regarding this response. 

~~u. Steven 

Office of 

P. 

Pesticide 

Bradbury, 

Programs 

Ph.D., D~ 

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