It is in the public interest that such pesticides should be given preferential treatment. Time is also saved because exposure and risk assessments can be simplified for substances that have little or no toxicity by any feasible route of exposure. Tragically, the thinking that made the reduced risk pesticide initiative possible, and so appealing to Congress, is incompatible with current implementation of the Guidance. EPA's implementation of policies that standardize data requirements and risk assessment procedures portends the disappearance of the reduced risk initiative. Reduced risk is a comparative property.
Some pesticides are much safer than others.
Unfortunately, inherent in EPA's new policies is the concept that it is not possible to discern such differences among pesticides. Returning to the bottom line, the future will fast be upon us where EPA's pesticide program no longer follows anything that resembles a scientific process. New Guidance has been inserted into the organization like a defective seed from which distorted new policies and regulations are rapidly growing. EPA must with a sense of urgency take action to make the data requirements, policies and procedures within OPP consistent with the Guidance. The data required for the most elaborate of assessments is not required by the Guidance for every situation.