Pesticides are by far the most extensively tested substances on the U.S. market and are already required to undergo dozens of separate animal-poisoning studies before they are marketed, which spells suffering and death for at least 12,000 rats, fish, birds, and even dogs. Now, the Environmental Protection Agency’s (EPA) pesticide office wants to raise the body count even further by expanding its “data requirements” for pesticide chemicals, including the addition of a test for “developmental neurotoxicity,” which kills upwards of 2,600 animals at a time.

 Before the EPA can move forward with its latest animal-poisoning scheme, it needs approval from the White House Office of Management and Budget (OMB). Ironically, the EPA’s request comes in the wake of an OMB finding that the EPA’s pesticide registration and re-registration programs are not only “unable to demonstrate the effects they are having in areas such as improvements to human health, environmental protection, or efficiency,” they are, in fact, among the EPA’s least effective programs! It should therefore come as no surprise that pesticides such as atrazine, 2,4-D, and lindane (which have been banned in a number of other countries) are still in widespread use in the U.S., while the EPA continues to reassess its already well-established adverse effects on human health and/or the environment.

 Your help is urgently needed to convince the OMB to pull the plug on this EPA-sanctioned blood bath before it can begin! Please ask OMB to reject the EPA’s proposed rule to amend its data requirements for pesticide registration under 40 CFR Part 158. Here are some additional points you may wish to include in your letter to the OMB:

• The costs of the EPA’s proposed rule—both economic and in terms of animal suffering and death—will vastly exceed any perceived benefits to the environment or human health.

 • The EPA’s ineffectiveness in protecting public health and the environment is directly connected to the agency’s addiction to animal tests that have never been “validated” to determine their reliability and relevance to human beings.

 • There are no scientifically validated test methods to assess proposed new effects such as “developmental neurotoxicity” and “immunotoxicity,” and it is unlawful for the EPA to require the use of a new test that has not been properly validated.

 • The EPA’s proposed rule makes a mockery of the agency’s stated commitment to reduce the amount of animal testing it requires.

 • More animal testing just means that dangerous pesticides will remain safe from regulation for years while they are tested and re-tested.

Send polite letters to:

Dr. John D. Graham
Administrator
Office of Information & Regulatory Affairs
Office of Management and Budget
725 17th St. N.W.
Washington, DC 20503
202.395.3888 (fax)