From Save the
On August 26th, I submitted this comment to the EPA as part of their official call for comments related to their 15-year review of Atrazine, which is one of the world's most common pesticides. Over 80 million pounds of it were used on American crops last year. This harmful pesticide is an endocrine disruptor that can turn male frogs into females at concentrations as low as 2.5 parts per billion. Atrazine is one of the most commonly detected pesticides in rainwater, groundwater and tapwater in the USA and is used on corn, sugar, sorghum, yams, rice, christmas trees, and for lawn care. Here is my comment:
As the Founder & Executive Director of SAVE THE FROGS! and as a concerned citizen, I seek a clean America in which to live: an America where I am not afraid to drink the tap water or to eat the food being served in restaurants or supermarkets; an America where pesticides do not rain down out of the sky on top of me; an America where our wildlife do not get deformed by the chemicals we introduce into their habitats without their consent. Thus I urge you to place an immediate federal ban on the use and production of Atrazine, a heavily used herbicide and a known endocrine-disruptor that is already banned in the European Union. The EPA’s mission to protect human and environmental health will not be fulfilled so long as Atrazine continues to contaminate our land and water.
See PDF version
As the Founder & Executive Director of SAVE THE FROGS! and
as a concerned citizen, I seek a clean America in which to live: an America
where I am not afraid to drink the tap water or to eat the food being served
in restaurants or supermarkets; an America where pesticides do not rain down
out of the sky on top of me; an America where our wildlife do not get
deformed by the chemicals we introduce into their habitats without their
Thus I urge you to place an immediate federal ban on the use and production of Atrazine, a heavily used herbicide and a known endocrine-disruptor that is already banned in the European Union. The EPA’s mission to protect human and environmental health will not be fulfilled so long as Atrazine continues to contaminate our land and water.
Numerous peer-reviewed scientific publications from laboratories around the world have demonstrated that Atrazine is extremely harmful to environmental and public health. Atrazine is particularly harmful to amphibians, many of which spend a portion or all of their lives in water. Gravity inevitably brings the 2 billion pounds of pesticides that get sprayed on American crops each year directly to the water bodies where amphibians live and breed. Amphibians have permeable skin that readily absorbs these pollutants. Atrazine has been shown to cause immunosuppression, hermaphroditism and even complete sex reversal in male frogs at concentrations as low as 2.5 parts per billion. As humans and frogs share half their DNA, it is unfathomable to think that Atrazine is harmless to humans or the other species with whom we inhabit this planet. The vast majority of Americans are exposed to Atrazine via drinking water, ground water, rainfall and our food supply, so it is not surprising that Atrazine has indeed been linked to increased cancer rates in human communities surrounding heavy Atrazine usage.
In the interest of public and environmental health and to create a healthy planet, I urge you to take advantage of your privileged role in government and do what is best for the environment and the people of the United States of America: place an immediate federal ban on the use and production of Atrazine. Thank you for protecting human and environmental health by banning Atrazine.
The mission of the USEPA is to protect human and environmental health. It is not to protect the profits of large corporations, nor is it to guarantee consistent monetary income for those whose farming methods wittingly or unwittingly pollute the land and deform wildlife. That being said, removing Atrazine from the market will be unlikely to significantly disrupt the American economy; on the contrary, it will positively affect many aspects of the American economy. For instance, an Atrazine ban would likely reduce the price differential between organic food and pesticide-laden conventional foods, benefitting the organic farmers who provide a valuable service to Americans by delivering us food that is safe to eat. An Atrazine ban will also stop billions of dollars from leaving American shores, as currently it is the Swiss manufacturer of Atrazine (Syngenta) that is the primary recipient of the billions of dollars Americans spend on Atrazine each year.
Thank you for taking action and doing what is right by canceling Atrazine's registration and banning its sale, purchase, use and production in the USA. Please these these webpages and videos for more information on Atrazine:
Sincerely, Kerry Kriger, Ph.D.
Save The Frogs - Founder, Executive Director, Ecologist
Save The Frogs is the world's leading amphibian conservation organization. We work in California, across the USA, and around the world to prevent the extinction of amphibians, and to create a better planet for humans and wildlife.
Dr. Kriger's response letter to EPA's denial of a ban on Atrazine
See entire letter and attachments here PDF
Dear US EPA,
I have received your August 27, 2013 letter stating that: (1) the EPA is unwilling to cancel Atrazine's regulations at this time due to the EPA's determination of there being insufficient evidence to suggest that Atrazine causes "unreasonable adverse effects on the environment" as required by FIFRA; and (2) SAVE THE FROGS! did not provide evidence to suggest that the 2003 IRED and 2006 cumulative assessment were flawed or insufficient.
However, SAVE THE FROGS! submitted in our May 6, 2011 petition a thorough summary of no less than nine unreasonable adverse effects on the environment caused by Atrazine, across a range of vertebrate groups including fish, amphibians, reptiles, birds and mammals, with references to 18 peer-reviewed scientific publications that were published after 2006 and thus were not included in the aforementioned 2003 or 2006 assessments. For the permanent record and to remind the EPA of these adverse effects and studies that the EPA has apparently not included in their assessments of Atrazine, I have included in Attachments 1 and 2 of this letter the complete list of adverse effects and scientific studies that I hand-delivered to the EPA on May 6, 2011.
Furthermore, while the EPA's Office of Pesticide Programs may be unwilling to cancel Atrazine's registration effective immediately for fear of not following proper protocol, the Administrator of the EPA (the first addressee on my May 6, 2011 submission) is able to cancel a pesticide's registration with merely a signature.
Based on the fact that: (1) the SAVE THE FROGS! 2011 petition listed no less than nine unreasonable adverse effects on the environment caused by Atrazine; (2) the SAVE THE FROGS!' 2011 petition referenced 18 peer-reviewed scientific publications that were published after 2006 and thus were not included in the aforementioned 2003 or 2006 assessments, and were apparently excluded from consideration or significantly de-valued in the current petition's review; (3) the Administrator of the EPA has never provided an official response to this petition and has no official statements regarding Atrazine on the public record; and (4) a member of the EPA's June 2012 Atrazine SAP told me after the hearings that members of the SAP were instructed to disregard any paper ever published on the effects of Atrazine on amphibians minus one pesticide-industry funded study,
I find that the EPA’s August 27th, 2013 denial of SAVE THE FROGS!’ 2011 petition to ban the use and production of Atrazine in the United States was made without proper assessment of scientific facts, and was not given proper assessment by the EPA’s Administrator, the primary addressee to whom the petition was submitted.
Thus I hereby officially submit two requests:
(1) that the petition in question and this letter be reviewed by and given an official response by the USEPA Administrator Gina McCarthy; and (2) that I be granted an in-person meeting with both the Director of the Office of Pesticide Programs (Steven P. Bradbury, Ph.D.) and the Administrator of the USEPA Gina McCarthy. I can meet anywhere in the USA, and any meeting longer than 15 minutes will be sufficient. I can meet the Director and Administrator together or separately. For the record, I requested a meeting with the Director of OPP in 2011 and I twice requested meetings with the EPA's Administrator in 2011.
As one of the world's most talented, accomplished, hard-working and passionate protectors of the environment, and as a US citizen who has paid taxes to local, state and federal governments for over 20 years, I hope that the EPA can grant my meeting requests. In the event that the EPA denies these meeting requests I would like an official statement from the EPA detailing how many times since May 6, 2011 the current and former Directors of OPP and the Administrators of the EPA have had personal meetings with representatives of the corn or pesticide industries.
As a final note, I fully support the mission of the EPA. However, it is my scientific opinion that the EPA is not properly protecting America's food, water, air, wildlife, environment, ecosystems or people from the threat of harmful pesticides and is thus not on track to fulfill its mission. To allow the continued use and production of Atrazine, the EPA sets a dangerous precedent by condoning environmental destruction and implying that it is environmentally sound and ethical to dump poison on American soil -- and on Americans.
Sincerely, Kerry Kriger, Ph.D.
SAVE THE FROGS! - Founder, Executive Director, Ecologist
See entire letter and attachments here PDF