The EPA has developed standards designed to protect human health, with an adequate margin of safety... and to protect public welfare from any known or anticipated adverse effects of a pollutant (1). Used as risk assessment benchmarks, "Reference Dose (RfD)" the maximum acceptable oral dose of a toxic substance is not an enforceable standard as are National Ambient Air Quality Standards (NAAQS). According to the EPA, "[a]n aggregate daily exposure to a [chemical] at or below the RfD (expressed as 100 percent or less of the RfD) is generally considered acceptable... (2)." The public has no choice of zero exposure other than to leave toxic areas. When assessing inhalation exposure, the EPA uses "Reference Concentrations," (RfCs), instead of RfDs (3). A burden of proof for causation of illness although stated in known applied pesticide M.S.D.S labeling by legal standard is the affected individuals. EPA acceptable exposure limits do not take into account the synergistic effects of combined chemicals, volatilization rates, or chronic low-dose exposure. The final governmental risk evaluation includes the evaluation of economic and political consequences (4). There is no record of an Environmental Impact Assessment (EIAs) for the use of Organophosphate / Chlorpyrifos pesticides on the island of Kauai, Hawaii by Dow Agrosciences; however, they are hiring (5).
1. "America's Children and the Environment"
http://www.epa.gov/economics/children/index.html
2.EPA - Reregistration Eligibility Decision
http://www.epa.gov/oppsrrd1/REDs/0328red.pdf
3.EPA - Environmental Assessment
http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=71993#Download
4. Framework for Risk Assessment and Risk Management
http://www.box.net/shared/4nsee5jvmx1ztfjuz8ds
5. Dow Agrosciences
http://careers.dowagro.com/key/dow-agroscience-kauai-jobs.html
August 1, 2011
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