CRE's Position on NRDC's Opposition to Continued Use of Atrazine

CRE believes that NRDC's opposition to and Petition to ban atrazine are unfounded for the following reasons

Human Health Effects

EPA's SAP and IARC have both concluded that there is no reliable evidence that atrazine causes cancer in human beings. For non-cancer LH attenuation effects, EPA's concerns about atrazine are based primarily on adult-rat test results which the Agency is using to establish endpoints for children who, based on the best available data, are less sensitive to LH attenuation from atrazine than are adults.

Indirect Environmental Effects

CRE does not believe that EPA should or could reach any reliable conclusions regarding atrazine's indirect environmental effects until and unless EPA has data and a risk assessment method able to assess such effects. CRE believes that EPA should develop a probabilistic method able to assess al risks from atrazine and all other pesticides.

Endocrine Effects on Frogs and Other Organisms

EPA and most other federal agencies have established a government-wide data quality standard that requires proper validation of tests before the test results can be considered reliable:

Before a new or revised test method is used to generate information to support regulatory decisions, it must be...validated to determine its reliability and relevance for its proposed use...

Evaluation of the Validation Status of Toxicological Methods: General Guidelines for Submissions to ICCVAM, Prepared by Interagency Coordinating Committee on the Validation of Alternative Methods , et. al., p. v., October 1999. ("Validation Guidelines").

EPA's statements regarding atrazine's endocrine effects on fish and amphibians do not meet this Government-wide Data Quality standard. Consequently, and for other reasons, CRE and and several agricultural groups have filed a Request or Correction under the new Data Quality Act and EPA's Data Quality Act Guidelines. This Petition requests EPA to correct the Environmental Risk Assessment to state that EPA cannot reach any conclusions regarding atrazine's endocrine effects on fish and amphibians until and unless there are properly validated tests for those effects.