Barb Wilkie's EHN Website
Last updated 2008

NCAMP and Beyond Pesticides has issued the following sample letter to be used as a form to send comments to the EPA in reference to the Preliminary Risk assessment of malathion. Please take a moment to send either this or your own version To: opp-docket@epa.gov and BCC: info@beyondpesticides.org

Important: Please put Control Number OPP-34223 in the subject line.

More information on malathion and other actions you can take is on the NCAMP website: http://www.beyondpesticides.org/

With enough email from us the concerned citizens, it IS possible that the EPA will act to benefit our health and remove malathion from the market. Our input did make a difference with chlorpyrifos, but we must continue our efforts.

Thanks for your action at such short notice,
Connie Eash

To: opp-docket@epa.gov

Public Information and Records Integrity Branch
Information Resources and Services Division (7502C)
Office of Pesticide Programs/ EPA
401 M Street, SW
Washington, DC 20460

Re: Public Comments in Response to Reregistration Eligibility Decision, Preliminary Risk Assessment, Malathion; Control Number OPP-34223

Dear Sir or Madam:

Thank you for the opportunity to comment on the preliminary risk assessment of the Regregistration Eligibility Decision (RED) Document for the organophosphate malathion. A RED for malathion should be issued only if data on malathion and its contaminants, metabolites and the inert ingredients in its formulations are complete and support reregistration under the standards of authorizing legislation and corresponding regulations.

The identified data gaps and the excessive risks of exposure to malathion preclude EPA from abandoning the tenfold margin of safety required by the Food Quality Protection Act (FQPA). Because malathion is so widely used, it represents one of the most significant sources of organophosphate exposure in non-occupational settings. Since all organophosphate pesticides act on the body in similar ways and their effects are additive, it raises questions about multiple exposure to these chemicals through many uses in and around homes and food production.

Malathion attacks the central nervous system and is associated with adverse health effects including respiratory problems, headaches, nausea, dizziness, and behavioral disorders. Malathion has been shown in animal testing and from use experience to affect not only the central nervous system, but also the immune system, adrenal glands, liver and blood. Malathion has shown to be mutagenic in humans and animals. It has also been associated with birth defects in domestic and laboratory animals.

Despite the fact that malathion is one of the less acutely toxic synthetic pesticides, having a LD50 of 1522 mg/kg, numerous human poisonings have been reported. A memo written by a Health Statistician with the Health Effects Division in the Office of Prevention, Pesticides, and Toxic Substances, EPA, stated that 5,222 unintentional residential exposures were reported to Poison Control Centers from 1993-1996. A November 1999 report issued by the Center for Disease Control (CDC) stated that over 230 people had reported being sick after malathion was sprayed aerially during the previous Mediterranean fruit fly Eradication Program.

Malathion should be listed as a carcinogen. Over the past twenty years, malathion has been associated with many cover-ups and controversy over its carcinogenic potential. Just over the past several months, EPA reversed the cancer findings of independent scientists and adopted the conclusions of an industry panel, the Pathology Working Group (PWG), even though an EPA toxicologist, in a memo to the Chairman of the Cancer Assessment Review Committee, concluded, "[U]nder EPA's guidelines in evaluating the tumorigenic response, the PWG report should be discounted, and the original diagnoses retained."

The EPA should take immediate steps to file a final determination and notice of intent to cancel and deny application for reregistration of pesticide products containing malathion. It is unacceptable to phase-out malathion and allow it's use to continue while existing stocks exist. Exposure to malathion is an imminent hazard, given its widespread use in and around homes, schools and our communities. My child will get sick when exposed to this chemical. I do not want a repeat of what happened with chlorpyrifos.

Sincerely,