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I'd rather err on the side of caution.

The EPA does not require businesses to face the same rigorous tests for the release of new chemicals that medicines are required to pass

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Voicing Concerns About Environmental Issues and Actions in the Community

Today's environmental, green and sustainable techniques and world views are based on centuries of concern about human health, wildlife, the role of all the species in our closed living system.

When I hear people talk about "those crazy environmentalists", it concerns me. It brings a lot of cliches to mind... "throwing the baby out with the bath water"..."biting the hand that feeds you"..."the children shall lead us"... all cliches based on folk wisdom that recognizes that visionaries are often sidelined by calling them names.

The most recent name calling was in an article about families evacuating the Fresno area because pesticides are being sprayed to reduce a moth infestation in agricultural crops.

"The light brown apple moth, a tiny Australian pest that attacks 250 plant species, was first spotted in California in March and has since spread to 12 counties, from Marin to Los Angeles. The eradication program is centered on the Monterey Peninsula, home to many organic farms, in part because agricultural authorities fear the moth could jump inland from there to San Joaquin Valley croplands and cause billions in losses." Source:

Parents are rightly concerned about the chemicals in the sprayed pesticide, but environmentalists weren't able to convince a Superior court judge that the health risks were sufficient to outweigh the financial damage to the region's agricultural businesses. What is often not calculated are the $billions of financial impact on the health and productivity of people, wildlife and natural systems that are affected by chemical pollutants.

"We're not crazy environmental people, we're just concerned for the health of our kids and the other people in town," commented one mother. "I'd rather err on the side of caution."

To shore up the protective walls of "best practices" is what most environmentalists are working for. Our business-heavy culture puts the burden of proof on environmentalists to prove that business actions will harm...rather than on business to prove their actions will NOT harm. The "do no harm" philosophy upon which our health care system does not apply to the chemical industry.

That's why environmentalists are concerned about spraying pesticides that will drift into children's bedrooms and playgrounds.

We know that. Now what do we do about it.

The EPA does not require businesses to face the same rigorous tests for the release of new chemicals that medicines are required to pass before launch. (See the example below) We need to change that because we're realizing more each year that air borne and water borne and food borne chemicals affect health just as much as ingested chemicals.

Example of Pesticide Campaign and Court Case

The California Department of Food and Agriculture is using a pesticide called CheckMate, which contains a synthetic pheromone that fouls up the moth's mating cycle. But after communities along the scenic stretch of coastline were doused from the air last month, more than 100 residents filed complaints claiming they couldn't breathe and experienced shooting stomach pains.

"I'd rather err on the side of caution."

An environmental group sued, claiming the state broke the law by not preparing an environmental impact report to ensure the chemical droplets were safe. Anxiety over the spray's potential health hazards only mounted with confusion about its ingredients, with regulators saying the spray contained a potentially harmful inert ingredient, then reversing course and saying it did not.

Who do we trust?

What process do we put in place so that we can trust one another's best practices? And intentions? And competency to deal with long term impacts?

First, we must look at the complex set of issues involved:

  • Invasive, alien species are a danger to local ecoystems and agricultural/human communities.
  • Invasive species are brought in by largely uncontrollable outsourcing and importing of goods.
  • Invasive species can destroy native species and agricultural systems
  • Many chemicals are found to have detrimental health impacts years or decades after they are widely used in communities
  • Children are more vulnerable than adults to chemical pollutants
  • Government's first responsibility is mandated to be the protection citizens, not economics
  • Big money in agriculture sways politics because of the "follow the money" free enterprise system
  • Industrial chemicals are released onto the market without stringent testing
  • People are fallible.
  • The environmental support system has no voice in court.

It gets complicated very fast. Living together in a community requires trust and respect...and restraint. It requires "erring on the side of caution."

There are green or sustainable ways to deal with invasive species -- it takes a lot of manual labor and sustainable agricultural systems such as "integrated pest management"...and maintaining sustainable natural systems requires that sustainable constraints be put on international trade.

California Secretary of Food and Agriculture, A.G. Kawamura says the CheckMate spray "is nontoxic to humans, plants, animals and insects." In recent weeks he ordered a panel of public health officials and pesticide experts to review the product's safety, and opened a 24-hour hotline to take health complaints.

Toll-free PEST HOTLINE: (800) 491-1899

Eradication Webpage: California Dept of Food & Agri: Light Brown Apple Moth Project

Based on news story on

Voicing Your Concerns to the EPA

Being heard isn't the same as "sounding off". Being heard effectively can require the efforts and talents of several people...or a group. This is why environmental groups form. They find the hurdles too daunting for most individuals to comply with.

General guidelines to help you enter the public discussion about environmental issues are found on the EPA website. Here's one example of the EPA's guidelines:

What Should I Consider when I Prepare My Comments for EPA?

You may find the following suggestions helpful for preparing your comments:
  1. Explain your views as clearly as possible and provide specific examples.
  2. Describe any assumptions that you used.
  3. Provide copies of any technical information and/or data you used that support your views.
  4. If you estimate potential burden or costs, explain how you arrived at the estimate that you provide.
  5. Provide specific examples to illustrate your concerns.
  6. Offer alternative ways to improve the collection activity.
  7. Make sure to submit your comments by the deadline identified under DATES.
  8. To ensure proper receipt by EPA, be sure to identify the docket ID number assigned to this action in the subject line on the first page of your response. You may also provide the name, date, and Federal Register citation.
SOURCE: EPA: Agency Information Collection Activities; Proposed Collection; Comment Request; Chemical-Specific Rules, TSCA Section 8(a); EPA ICR No. 1198.08, OMB Control No. 2070-0067

III. What Information Collection Activity or ICR Does this Action Apply to?

Affected entities: Entities potentially affected by this action are companies that manufacture, process, or import or propose to manufacture, process, or import chemical substances and mixtures.

Abstract: TSCA section 8(a) authorizes the Administrator of EPA to promulgate rules that require persons who manufacture, import, or process chemical substances and mixtures or who propose to manufacture, import, or process chemical substances and mixtures, to maintain such records and submit such reports to EPA as may be reasonably required.

Any chemical covered by TSCA for which EPA or another Federal Agency has a reasonable need for information and which cannot be satisfied via other sources is a proper potential subject for a chemical-specific TSCA section 8(a) rulemaking.

Information that may be collected under TSCA section 8(a) includes, but is not limited to, chemical names, categories of use, production volume, byproducts of chemical production, existing data on deaths and environmental effects, exposure data, and disposal information.

Generally, EPA uses chemical-specific information under TSCA section 8(a) to evaluate the potential for adverse human health and environmental effects caused by the manufacture, importation, processing, use or disposal of identified chemical substances and mixtures.

Additionally, EPA may use TSCA section 8(a) information to assess the need or set priorities for testing and/or further regulatory action. To the extent that reported information is not considered confidential, environmental groups, environmental justice advocates, state and local government entities and other members of the public will also have access to this information for their own use.

Responses to the collection of information are mandatory (see 40 CFR part 704). Respondents may claim all or part of a notice confidential. EPA will disclose information that is covered by a claim of confidentiality only to the extent permitted by, and in accordance with, the procedures in TSCA section 14 and 40 CFR part 2.

Burden statement: The annual public reporting and recordkeeping burden for this collection of information is estimated to average 68.8 hours per response.

Edited by Carolyn Allen, owner/editor of California Green Solutions
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