Office of Pesticide and Toxic Substances

U.S. EPA, National Pesticide Survey Phased Report, Offiice of Water, Office of Pesticides and Toxic Substances, EPA 570/9-90-015, U.S. Govt. Printing Office, Washington, D.C., 1990. 

EPA. 1985b. Endosulfan technical Review of 13-week toxicity study in mice. Memorandum. Washington, DC U.S. Environmental Protection Agency, Office of Pesticides and Toxic Substances. Document no. 004733. 

EPA. 1990. Uptake of lead from formula and food by infants Reanalysis of the Ryu et al. data. Draft final report. US Environmental Protection Agency, Office of Pesticides and Toxic Substances Exposure Evaluation Division, Office of Toxic Substances. 

The results of that process were commented on by Dr. John Todhunter, EPA s Assistant Administrator for the Office of Pesticides and Toxic Substances (OPTS) in a speech delivered in Rome to representatives of some of our European trading partners (11). He was commenting on the small amount of toxicity data submitted with many of the PMNs submitted to date. He pointed out that EPA s experience shows that to be due largely to the inherently low hazard potential of the bulk of the substances submitted for PMN review. His evidence was the fact of no imminent hazard actions (Section 5(f)) and inadequate information actions (Section 5(e)) on only 9 chemicals out of over 1,000 PMNs submitted. He further noted that in 60 cases, industry had volunteered more data, reduced exposures, or withdrawn PMNs. Dr. Todhunter s conclusion from all this was that industry is doing an effective job of screening substances before submitting PMNs. 

Moreover, the EPA Office of Pesticides and Toxic Substances has grouped pesticide active ingredients into three different categories based on production and exposure potential. One of EPA s three categories consists of "low" production pesticides. The Agency defined this category as an annual production volume of 25,000 pounds or less. 

Two concerns arise which CSIN administration has not addressed so far. First, the emphasis has been to provide access only through well-established existing sources. No apparent effort has been made to consider the need for drawing together the multiplicity of information submitted to the EPA Office of Pesticides and Toxic Substances in an easily accessible form for agency use. With the exception of information contained in the Chemicals In Commerce Information System (CICIS), developed primarily to accommodate TSCA Inventory and other related information, regulatory personnel often are not aware what is already available and request repetitive submissions from industry. Furthermore, conclusions are drawn only from publicly available data-bases. Data already available within the agency are not readily accessible for its own personnel. Apparently, this situation is a result of non-responsiveness, so far, to TSCA Section 10 s mandate. 

EPA. 1984b. Pesticide fact sheet Disulfoton. Washington, DC Office of Pesticide and Toxic Substances, Offices of Pesticide Programs. 

Bernstein, D. N., T. T. Drew, and M. Kuschner (1980). The translocation and fate of sized man-made mineral fibers following exposure by intratracheal instillation in rats, pp. 343-390. In Levin, A., ed. Proceedings of the National Workshop on Substitutes for Asbestos. EPA Doc. No. 560/3-80-001. Office of Pesticides and Toxic Substances, Washington, DC. 

Cone MV, Baldauf MF, Opresko DM et al. 1983. Chemicals identified in human breast milk, a literature search. Oak Ridge National Laboratory report under EPA/DOE lAGNo. DW930139-01-1. Office of Pesticides and Toxic Substances. EPA 560/5-83-009. 

DC U.S. Environmental Protection Agency, Office of Pesticides and Toxic Substances. 

CUT. 1983. Preliminary result of in vivo and in vitro sister chromatidexchange assays on cresol isomers and of an immunological evaluation ofo-cresol. Memorandum to Office of Pesticides and Toxic Substances. Chemicallndustry Institute of Toxicology, Research Triangle Park, NC. CUT Docket no. 12283. 

Some of EPA s programmatic and policy deficiencies can be ascribed to career civil servants with their own agendas, who manipulate EPA-inexperienced political appointees (most often lawyers). A pertinent example is Dr. Elizabeth Milewski, an EPA mid-level manager who has had primary responsibility for biotech policies in the Office of Pesticides and Toxic Substances. At a 1991 interagency meeting that I attended, she announced that the EPA could not accept a certain scientifically based policy because our constituency won t stand for it. ... 

United States Environmental Protection Agency (1980) Chemical Hazard Information Profiles (CHIPa) (EPA 560/11-80-011. Washington DC, Office of Pesticides and Toxic Substances, p. 43... 

Expanding the scope of FIFRA/GLP to include environmental and chemical fate studies will take time. It will mean that studies described by EPA Hazard Evaluation Division, Office of Pesticide and Toxic Substances,for Environmental Fate and Residue Chemistry must meet the requirements outlined in the FIFRA/GLPs, and that... 

ENVIRONMENTAL PROTECTION AGENCY OFFICE OF PESTICIDES AND TOXIC SUBSTANCES 40 CFR PART 160 [OPP-300165 FRL 3245-5]... 

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