> Action Advisory
>
> Ethyl Parathion: known lethal and sub-lethal hazard for birds in the US
>
> Public comment needed -- deadline 1 May 2000
>
>American Bird Conservancy (ABC) urges conservationists, scientists, bird
>watchers, and the public to respond to an Environmental Protection Agency
>(EPA) request for comment on the ecological effects of ethyl parathion.
>Ethyl parathion, an organophosphate insecticide, is known to be very highly
>toxic to birds and has caused numerous wildlife mortality incidents. Bird
>die-offs have been documented in a wide range of species including
>waterfowl, shorebirds, raptors, and songbirds. Also, even after extensive
>efforts to mitigate hazards to humans, ethyl parathion continues to raise
>significant safety concerns for farm workers.
>
>According to the U.S. Fish and Wildlife Service "substantial evidence
>verifies that mortality of migratory birds and other non-target organisms
>occurs even when parathion is applied in complete conformance with the
>label." Birds can be poisoned by ingestion of insects or grains with
>residues, by preening or bathing, via inhalation of spray particles or
>dermally through feet or exposed skin (especially of chicks and also brood
>patches of nesting birds).
>
>In 1991, after numerous lethal incidents involving humans, wildlife, and
>domestic animals, ethyl parathion was restricted to use on nine crops:
>alfalfa, barley, corn, cotton, canola, sorghum, soybean, sunflower, and
>wheat. Further restrictions attempted to minimize worker contact with the
>product by not allowing the harvest of crops by hand and by delaying
>entrance into the field for any reason for 3 to 6 days after spraying.
>Nevertheless, applications are made by plane and helicopter and, besides
>being present during spraying, birds and other wildlife cannot be
>restricted from entering the field where residues are available for
>extended periods after application.
>
>Currently, approximately 600,000 pounds of active ingredient is used
>annually on over 775,000 acres of land. (See <www.abcbirds.org> for crop
>specific information.) In the overwhelming majority of cases, there are
>economical and effective alternatives to ethyl parathion.
>
>Additional concerns:
> * The EPA risk assessment states "uses of parathion are likely to result
>in bird deaths. In addition to mortality, a suite of sub-lethal effects has
>been documented in avian species. These include reproductive effects,
>health impacts for nesting birds and their young, damage to food resources,
>feeding and behavioral changes and greater vulnerability to predation and
>environmental stress."
> * Use of ethyl parathion is highest in the Great Plains and prairie
>pothole region where effects can be devastating to wetland ecosystems
>critical to bird populations even when certified applicators take
>extraordinary precautions. This region accounts for 50% or more of the
>annual waterfowl production in North America. Ethyl parathion is relatively
>persistent with a metabolic half-life of 50-140 days in aerobic soils
>(26-30 degrees C, pH 6-7) and 6-88 days in aquatic anaerobic soils (30
>degrees C, pH 5.5-6.5). Parathion is unusually resistant to hydrolysis,
>with a 108-day hydrolytic half-life (pH 7.4).
> * The primary degradate of ethyl parathion, paraoxon, is five times more
>easily absorbed than parathion and 40 to 50 times more toxic. The
>opportunity for multiple applications in a single year and the extended
>toxicity and persistence of paraoxon (in dry and wet conditions) increases
>potential for ongoing acute and chronic exposures of birds and other
>wildlife for weeks. Residues of parathion and paraoxon have been found at
>relatively high concentrations on crop foliage and soils for at least 45
>days after parathion was applied at normal rates under dry conditions.
> * Abundant incident data confirm that avian mortality and significant
>adverse effects result from dietary exposures, inhalation, dermal exposures
>and secondary exposures of non-target species eating contaminated prey
>species. For example: predatory birds such as kites, kestrels, and hawks
>feeding on insects or small mammals; or ducks feeding on tadpoles which
>have been shown to concentrate ethyl parathion and seem to be able to
>tolerate higher levels of exposure.
> * By implementing restrictions after 1991 to protect the health of
>agricultural workers (i.e. no treated crop can be harvested by hand and
>prohibiting entry into fields for several days), opportunities to identify
>wildlife kills and the responsibility of reporting adverse effects has been
>mitigated.
> * Besides the strengthening of label warnings, EPA has been unable to
>identify other risk mitigation strategies that might reduce the ongoing
>risks to wildlife and humans from use of ethyl parathion.
>
>All members of the public are encouraged to comment to EPA on the risk
>assessment and re-registration of ethyl parathion. Identify all comments
>with the number OPP 34197A.
>
>Action:
>
>Ask EPA to cancel all registered uses of ethyl parathion based on known
>hazards to birds and other wildlife species including, bees, fish, reptiles
>and mammals. Let them know that the time has come to remove the older and
>most hazardous pesticides in the chemical arsenal. Tell them that their
>assessment clearly indicates that the ongoing and unavoidable hazards of
>ethyl parathion use far outweigh the benefits.
>
>Where to find more information:
> * The full assessment is available via EPA at:
><www.epa.gov/pesticides/op/ethyl_parathion.htm>
> * Or go to the ABC website and click on pesticides: <www.abcbirds.org>
>
>How to submit comment:
>
>All comments must be identified with the docket number OPP-34197A.
>
>Comments may be submitted by mail, electronically, or in person.
>
>By mail. Submit comments to: Public Information and Records Integrity
>Branch, Information Resources and Services Division (7502C), Office of
>Pesticide Programs, Environmental Protection Agency, Ariel Rios Bldg., 1200
>Pennsylvania Ave., NW., Washington, DC 20460.
>
>In person or by courier. Deliver comments to: Public Information and
>Records Integrity Branch, Information Resources and Services Division,
>Office of Pesticide Programs, Environmental Protection Agency, Rm. 119,
>Crystal Mall #2, 1921 Jefferson Davis Hwy., Arlington, VA. The PIRIB is
>open from 8:30 a.m. to 4 p.m., Monday through Friday, excluding legal
>holidays. The PIRIB telephone number is (703) 305-5805.
>
>Electronically. Submit electronic comments by e-mail to: <opp-docket at epa.gov>
>