We have concerns that the diazinon preliminary report lacks factual information that is necessary for a science-based risk analysis. Sound science, actual-use data monitoring and transparency must be given priority in the risk assessment process. The risk report reflects the use of diazinon on numerous crops in which the product has been restricted. However, those crops are included in the analysis. We question the risk assessment's validity because of this and urge EPA to take into account only those crops for which the product is registered.
Transparency is critical when analyzing re-registration eligibility decisions.
The assessment process must be fully disclosed and communicated openly in order for USDA, producers and chemical manufactures to review and respond to the assessments within in the 60 day public notice period. USDA received the diazinon risk assessment on June 15, nearly one-month after the notice was filed in the Federal Register. This left USDA and the product registrant, Novartis, only one month to review and respond. CFBF respects that EPA is working within a time frame, having ten years to complete more than 9,700 tolerance reassessments. Higher standards of public health protection must be determined by sound science, actual-use monitoring data and transparency within the process.