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LETTER SENT TO EPA AND FEDERAL LEGISLATORS

November 2005

Dear EPA Administrator and Federal Legislators:

We, the undersigned organizations and individuals, are appalled by the EPA proposed rule; Protection for Human Subjects, that allows orphans, neglected or abused state awarded children, mentally challenged children and children from foreign countries to be tested on with toxic pesticides by the EPA and independent companies.

The rule is in blatant violation of the 2006 Interior and Environment Appropriations amendment, so much so that some EPA employees have expressed concern that they could be legally charged with crimes against humanity when asked to implement pesticide studies under the rule. The proposed rule states:
  • EPA will accept human studies on pregnant women or children if the study is crucial to the protection of public health;

  • If a child's capability is so limited that he or she cannot reasonably be consulted, such as orphaned newborns, severely mentally challenged children, they can be experimented on with the permission of the institution or other guardian;

  • EPA can waive the entire regulation when conducting or funding chemical tests on children outside the United States.
Testing pesticides on human beings will not serve to protect our food supplies, better control West Nile Virus, or secure a greater good to our country.

At stake are simply a dozen pesticide products that will be taken off the market because they do not meet a health protective requirement of the Food Quality Protection Act. The pesticide manufacturers of at risk chemicals do not want to loose their market share to safer alternatives.

For the EPA and pesticide industry to use innocent children, some whom have already suffered from abuse, for the end goal of maintaining a space in the marketplace for the most toxic of pesticides is reprehensible.

We are asking our Federal Legislators to take a stand and ensure that EPA permanently prohibits, without exception, that pregnant women and children never become pesticide exposure test subjects.

Sincerely,