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Human Health and Environmental Relative Risks of WNV Mosquito Control Products

Appendix VIII. Public Comments

Appendix VIII. Table 1. Comments on the March 5, 2001 Relative Risk of Mosquito Control Pesticides
Individual: Affiliation	Comments	Response
Michael Hertz Sheepscot Valley Conservation Assn	concern for Atlantic Salmon; use of adults for toxicity testing; concerns about "taking" under Endangered Species Act; prohibit products which have not been tested on egg and larval stages of salmon	We recognize these concerns and will be dealing with NMFS and USF&W if this becomes an issue regarding WNV treatment
Mary Adams	feels the report is not accurate, as specific effects were not mentioned	See appendix IV Table 2.
Beedy Parker	copy on both sides of pages; reduce legal size to 8.5 by 11 (or omit) add summary; consider inerts; more general warning of nontarget species effects; enclosed Rachel's weekly on WNV	will add executive summary, it's not a general warning type document
Sharon Tisher MOFGA	need for executive summary; add an introduction about what we don't know; risk of creating a resistant population of mosquitoes; bee risks?; multiple exposure risks and fetal protection?	will add executive summary, and consult with state apiarist; resistant mosquitoes and multiple exposures are beyond scope
Leslie Poole	concern for birds, insects and fish (including lobster); food chain disruption; need for executive summary; add an introduction about what we don't know; risk of creating a resistant population of mosquitoes; bee risks?; multiple exposure risks and fetal protection?; concern for organic growers	will add executive summary, and consult with state apiarist; resistant mosquitoes and multiple exposures are beyond scope; MOFGA is in the loop
James Wood Amvac	naled shorterm NOEL is now 10 mg/kg/day: dermal absorption 23% in rat; 2.3 in vitro human/rat epidermis	will adjust tables and risk estimates
Ann Manley Amvac	Public information session; reiterated James Wood's written comments	will adjust tables and risk estimates
Razelle Hoffman-Contois VT DPH	executive summary, technical and layperson's summary, including why we are taking this approach; rename graphs "comparison of modified MOEs" rather than relative risk ratio and let the graphs speak for themselves; Units for ModMOE are inverted	will add executive summary and make suggested changes
Terry Couch Becker Microbial Products	accurate and excellent format
William Sugg Maine Environmental Policy Institute	question regarding are these the only substances that could be used in Maine for possible control of WNV? Public information session had more questions and sparked a discussion, no further written comments	general discussion
Cy Lessor MD Dept of Ag	need acronym list	will add list of acronyms
Adrian Krygsman Aventis	gaps in the databases are not addressed; tables should include descriptors and duration of studies, current labels were supplied to correct label information; Aventis corporation's "Comparative Aquatic Risk Assessment for Resmethrin"	this is a snapshot of what was registered in 1999, new labels will be reviewed prior to any decisions; will adjust tables and risk estimates
Cathy Elmi Wellmark Corporation	submitted more up-to-date labels; Change maximum concentration following the use of the briquets (from 8.1 ppb to 4 ppb); indicated that there are two methoprene isomer combinations the S-methoprene and the RS-Methoprene. Soon all will be S-methoprene; Corrected tox information in the 1991 EPA RED (grass shrimp; not toxic up to 10 ppm in adults, > 50% survival in larval shrimp at 1 ppm) (mud crabs not very highly toxic to larval mud crabs; Corrected 1/2 life and water solubility values	this is a snapshot of what was registered in 1999, new labels will be reviewed prior to any decisions; will adjust tables and risk estimates
Wayne Millington National Park Service technical specialist at Penn State	I have gone over the pesticide information you sent me from Maine and really have no additional comments I can add. The information is good and will be very useful if Maine needs to respond to a significant West Nile Virus outbreak. I really don't think that Maine is going to have a problem with WNV is coming summer, but it will be interesting to see how they utilize the toxicology information they have now compiled. Thanks for sending me the information, it is the best product review I have seen.

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