From Save the
Frogs!
November 2013
Read Dr. Kriger's original letter to the EPA requesting a ban on Atrazine
Read Dr. Kriger's letter in response to EPA's refusal to ban Atrazine
On August 26th, I submitted this comment to the EPA as part of their official call for comments related to their 15-year review of Atrazine, which is one of the world's most common pesticides. Over 80 million pounds of it were used on American crops last year. This harmful pesticide is an endocrine disruptor that can turn male frogs into females at concentrations as low as 2.5 parts per billion. Atrazine is one of the most commonly detected pesticides in rainwater, groundwater and tapwater in the USA and is used on corn, sugar, sorghum, yams, rice, christmas trees, and for lawn care. Here is my comment:
As the Founder & Executive Director of SAVE THE FROGS! and as a concerned citizen, I seek a clean America in which to live: an America where I am not afraid to drink the tap water or to eat the food being served in restaurants or supermarkets; an America where pesticides do not rain down out of the sky on top of me; an America where our wildlife do not get deformed by the chemicals we introduce into their habitats without their consent. Thus I urge you to place an immediate federal ban on the use and production of Atrazine, a heavily used herbicide and a known endocrine-disruptor that is already banned in the European Union. The EPA’s mission to protect human and environmental health will not be fulfilled so long as Atrazine continues to contaminate our land and water.
Read Dr. Kriger's original letter to the EPA requesting a ban on Atrazine
See PDF version
As the Founder & Executive Director of SAVE THE FROGS! and
as a concerned citizen, I seek a clean America in which to live: an America
where I am not afraid to drink the tap water or to eat the food being served
in restaurants or supermarkets; an America where pesticides do not rain down
out of the sky on top of me; an America where our wildlife do not get
deformed by the chemicals we introduce into their habitats without their
consent.
Thus I urge you to place an immediate federal ban on the use and production
of Atrazine, a heavily used herbicide and a known endocrine-disruptor that
is already banned in the European Union. The EPA’s mission to protect human
and environmental health will not be fulfilled so long as Atrazine continues
to contaminate our land and water.
Numerous peer-reviewed scientific publications from laboratories around the
world have demonstrated that Atrazine is extremely harmful to environmental
and public health. Atrazine is particularly harmful to amphibians, many of
which spend a portion or all of their lives in water. Gravity inevitably
brings the 2 billion pounds of pesticides that get sprayed on American crops
each year directly to the water bodies where amphibians live and breed.
Amphibians have permeable skin that readily absorbs these pollutants.
Atrazine has been shown to cause immunosuppression, hermaphroditism and even
complete sex reversal in male frogs at concentrations as low as 2.5 parts
per billion. As humans and frogs share half their DNA, it is unfathomable to
think that Atrazine is harmless to humans or the other species with whom we
inhabit this planet. The vast majority of Americans are exposed to Atrazine
via drinking water, ground water, rainfall and our food supply, so it is not
surprising that Atrazine has indeed been linked to increased cancer rates in
human communities surrounding heavy Atrazine usage.
In the interest of public and environmental health and to create a healthy
planet, I urge you to take advantage of your privileged role in government
and do what is best for the environment and the people of the United States
of America: place an immediate federal ban on the use and production of
Atrazine. Thank you for protecting human and environmental health by banning
Atrazine.
The mission of the USEPA is to protect human and environmental health. It is
not to protect the profits of large corporations, nor is it to guarantee
consistent monetary income for those whose farming methods wittingly or
unwittingly pollute the land and deform wildlife. That being said, removing
Atrazine from the market will be unlikely to significantly disrupt the
American economy; on the contrary, it will positively affect many aspects of
the American economy. For instance, an Atrazine ban would likely reduce the
price differential between organic food and pesticide-laden conventional
foods, benefitting the organic farmers who provide a valuable service to
Americans by delivering us food that is safe to eat. An Atrazine ban will
also stop billions of dollars from leaving American shores, as currently it
is the Swiss manufacturer of Atrazine (Syngenta) that is the primary
recipient of the billions of dollars Americans spend on Atrazine each year.
Thank you for taking action and doing what is right by canceling Atrazine's
registration and banning its sale, purchase, use and production in the USA.
Please these these webpages and videos for more information on Atrazine:
Sincerely, Kerry Kriger, Ph.D.
Save The Frogs - Founder, Executive Director, Ecologist
Save The Frogs is the world's leading amphibian conservation organization. We work in California, across the USA, and around the world to prevent the extinction of amphibians, and to create a better planet for humans and wildlife.
Read
Dr. Kriger's response letter to EPA's denial of a ban on Atrazine
See entire letter and attachments here
PDF
Dear US EPA,
I have received your August 27, 2013 letter stating that: (1) the EPA is
unwilling to cancel Atrazine's regulations at this time due to the EPA's
determination of there being insufficient evidence to suggest that Atrazine
causes "unreasonable adverse effects on the environment" as required by
FIFRA; and (2) SAVE THE FROGS! did not provide evidence to suggest that the
2003 IRED and 2006 cumulative assessment were flawed or insufficient.
However, SAVE THE FROGS! submitted in our May 6, 2011 petition a thorough
summary of no less than nine unreasonable adverse effects on the environment
caused by Atrazine, across a range of vertebrate groups including fish,
amphibians, reptiles, birds and mammals, with references to 18 peer-reviewed
scientific publications that were published after 2006 and thus were not
included in the aforementioned 2003 or 2006 assessments. For the permanent
record and to remind the EPA of these adverse effects and studies that the
EPA has apparently not included in their assessments of Atrazine, I have
included in Attachments 1 and 2 of this letter the complete list of adverse
effects and scientific studies that I hand-delivered to the EPA on May 6,
2011.
Furthermore, while the EPA's Office of Pesticide Programs may be unwilling
to cancel Atrazine's registration effective immediately for fear of not
following proper protocol, the Administrator of the EPA (the first addressee
on my May 6, 2011 submission) is able to cancel a pesticide's registration
with merely a signature.
Based on the fact that: (1) the SAVE THE FROGS! 2011 petition listed no less
than nine unreasonable adverse effects on the environment caused by
Atrazine; (2) the SAVE THE FROGS!' 2011 petition referenced 18 peer-reviewed
scientific publications that were published after 2006 and thus were not
included in the aforementioned 2003 or 2006 assessments, and were apparently
excluded from consideration or significantly de-valued in the current
petition's review; (3) the Administrator of the EPA has never provided an
official response to this petition and has no official statements regarding
Atrazine on the public record; and (4) a member of the EPA's June 2012
Atrazine SAP told me after the hearings that members of the SAP were
instructed to disregard any paper ever published on the effects of Atrazine
on amphibians minus one pesticide-industry funded study,
I find that the EPA’s August 27th, 2013 denial of SAVE THE FROGS!’ 2011
petition to ban the use and production of Atrazine in the United States was
made without proper assessment of scientific facts, and was not given proper
assessment by the EPA’s Administrator, the primary addressee to whom the
petition was submitted.
Thus I hereby officially submit two requests:
(1) that the petition in question and this letter be reviewed by and given
an official response by the USEPA Administrator Gina McCarthy; and (2) that
I be granted an in-person meeting with both the Director of the Office of
Pesticide Programs (Steven P. Bradbury, Ph.D.) and the Administrator of the
USEPA Gina McCarthy. I can meet anywhere in the USA, and any meeting longer
than 15 minutes will be sufficient. I can meet the Director and
Administrator together or separately. For the record, I requested a meeting
with the Director of OPP in 2011 and I twice requested meetings with the
EPA's Administrator in 2011.
As one of the world's most talented, accomplished, hard-working and
passionate protectors of the environment, and as a US citizen who has paid
taxes to local, state and federal governments for over 20 years, I hope that
the EPA can grant my meeting requests. In the event that the EPA denies
these meeting requests I would like an official statement from the EPA
detailing how many times since May 6, 2011 the current and former Directors
of OPP and the Administrators of the EPA have had personal meetings with
representatives of the corn or pesticide industries.
As a final note, I fully support the mission of the EPA. However, it is my
scientific opinion that the EPA is not properly protecting America's food,
water, air, wildlife, environment, ecosystems or people from the threat of
harmful pesticides and is thus not on track to fulfill its mission. To allow
the continued use and production of Atrazine, the EPA sets a dangerous
precedent by condoning environmental destruction and implying that it is
environmentally sound and ethical to dump poison on American soil -- and on
Americans.
Sincerely, Kerry Kriger, Ph.D.
SAVE THE FROGS! - Founder, Executive Director, Ecologist
See entire letter and attachments here PDF
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