EPA And Syngenta Agree on Interim Atrazine Re-Registration Requirements
EPA and Syngenta have reached agreement on some interim atrazine re-registration requirements under FIFRA and the FQPA. The agreement establishes a trigger for atrazine and its metabolites in "raw water" of 37.5 ppb on a 90-day rolling average. CRE has been notified that Syngenta does not consider it appropriate to use raw water concentrations as measurements as triggers to protect human health, but agreed to raw water triggers in order to reach this agreement with EPA.
CRE also notes that this agreement reemphasizes EPA's conclusion that atrazine is not a human carcinogen. This conclusion was reached after 8 years of review of the best available science and facts. There is no scientific or factual basis for challenging it.
Other issues, including questions about the potential for amphibian effects, will be addressed in another atrazine registration decision to be issued in October 2003 after SAP review.
File Joint Data Quality Act Petition on Atrazine
The Kansas Corn Growers Association and the Triazine Network joined
CRE in filing a joint Data Quality Act Petition requesting corrections
to influential information in EPA's Final Registration Eligibility
Science Chapter for Atrazine: Environmental Fate and Effects Chapter
(April 22, 2002). The Petition, filed November 25, 2002, requests
correction of those parts of EPA's Environmental Risk Assessment
stating that the herbicide atrazine causes endocrine effects in
the environment. EPA's statements do not meet the Data Quality Act's
reliability, reproducibility and utility standards because there
are no validated tests for determining whether atrazine causes environmental
You can support the atrazine Data Quality Act Request for Correction by sending EPA a statement in support at the following address: firstname.lastname@example.org. Use the information on the Atrazine.US website to fashion your comments. Please also feel free to contact Scott Slaughter at: Slaughter@mbsdc.com for assistance in developing your supporting comments.
Science Panel Unable To Reproduce Hayes Frog Tests
Dr. Tyrone Hayes has published several articles discussing tests by him that show advers endocrine effects on frogs exposed to atrazine. A distinguished international panel of scientists has been unable to reproduce the results of Dr. Hayes' tests. CRE believes that this conflict in test results demonstrates the need for properly validated tests, with reproducibility between laboratories a requirement for validation. This issue is, of course, addressed in CRE's Data Quality Act petition for atrazine.
EPA Does Not Deny Atrazine Data Quality Act Petition
On November 25, 2002, the Triazine Network, the Kansas Corn Grower's
Association and CRE filed a Data Quality Act Petition asking EPA to correct statements in its FIFRA/FQPA Environmental Risk Assessment regarding atrazine's purported endocrine effects on various organisms including frogs. On January 30, 2003, EPA sent Petitioners a letter regarding their Petition.
The thrust of EPA's letter is to defer action on the Petition until EPA has finished action on the atrazine IRED. However, based on the letter and on reported statements by EPA officials, CRE can only infer that EPA believes it can use a weight of the evidence approach to determine atrazine's effects, if any, on amphibians and other wildlife. Under this weight of the evidence approach, EPA apparently believes that it can use, rely on or endorse evidence based on non-validated tests, including tests that have never been shown to be reproducible.
CRE believes that this apparent EPA position is a direct violation of the Data Quality Act and the Data Quality Guidelines. As explained in detail in the atrazine Data Quality Act Petition, the atrazine Environmental Risk Assessment is influential scientific information, and EPA's Data Quality Act Guidelines require that EPA ensure the reproducibility of all influential scientific information disseminated by the Agency. The Environmental Risk Assessment statements regarding atrazine's purported endocrine effects are based on tests that have never been demonstrated to be reproducible. In addition, EPA is member of ICCVAM, and ICCVAM has established a government-wide data quality standard that requires proper test validation before the tests are used by federal agencies. These reproducibility and test-validation standards are irreconcilable with a weight of the evidence approach and with reported EPA statements that it can and will use "all data."