Wednesday, July 9, 2014

EPA is Sued Cyantraniliprole Approval Farce

"Despite specific comments urging EPA to consult and EPA's conclusions in the Risk Assessment that additional analyses and cooperation with the Services were necessary, EPA finalized its CTP Registration Decision without consulting with NMFS or FWS as required by Section 7 of the ESA [Endangered Species Act]," states the complaint.
The groups say the government's authorization of the pesticide violates the Endangered Species Act. They want a court order vacating the EPA authorization of CTP use.
The groups' lead counsel is Patti Goldman, with Earthjustice, of Seattle.

The EPA registered the pesticide in January, including product mixtures containing other pesticides such as thiamethoxam.
Photo: Summer Solstice comes at the precise moment when the sun’s power is at its peak. Solstice means ‘sun stands still’ because the sun rises and sets in the same spot for a few days. Here in the northern hemisphere, this is the longest day and shortest night of the year. From then on, the days will get shorter. This phenomenon is a direct result of the Earth-Sun relationship. After peaking, the Sun begins to wane, and the journey into the harvest season begins. 

It has always been an important solar event throughout the evolution of humankind. The axis of Stonehenge and the Temple of the Sun in Mexico are both oriented in the direction of the Midsummer sunrise.

Astrologically the Summer Solstice corresponds to the entry of the Sun into Cancer, interestingly a water sign governed by the moon. Cancer symbolizes the moving waters of our inner life, our moods and cycles, our instincts, intuition, 
our juiciness. It is the force & power of our imagination, our emotions, our roots. A reflective, passive, cyclic force, this sign marks the intimate inner world, personal & family bonds, as well as our larger collective family, with an accent on the tribe, the clan, and a sense of belonging. 

The Festival of Summer Solstice is sometimes called Midsummer’s Eve or St. John’s, and it is celebrated like other ‘holy days’ on the Eve, starting at twilight, when the power is most concentrated. 

Midsummer’s Eve is a magical time to communicate with the plant & fairy spirits, as it is the time of the herb harvest. All plants gathered this night are considered exceptionally potent for healing and ritual purposes.

St. John’s Wort & other healing herbs are placed around the home for protection as they dry. They are also thrown into the Midsummer bonfire, and when the coals have cooled down the ashes are mixed with water and sprinkled on the fields, the 4 corners of the home, and the on the head or feet of the children. 

Royal fern seeds gathered at midnight on the eve are said to make you invisible; rub the blossoms on your eyelids to see the wee folk, which will also make you wealthy and wise, but be sure to carry a bit of rue in your pocket or you might be ‘pixie-led’. Can’t find the rue, then turn your jacket inside out and follow the old ‘Ley-Lines’, which will keep you from getting lost in fairy land. 
Divination on matters of love are especially powerful on Midsummer’s Eve. Young women place yarrow or other herbs and flowers native to their part of the world peaking at this time, under their pillows, to dream of their future mates. 

Called St. John’s Eve by the church, this is traditionally the time when the herb St. John’ Wort reaches its full potency. Since it is a solar herb, it is used to bring the power of the sun to people who suffer from depression.      

The ancient Druids celebrated the Summer Solstice as the Wedding of Heaven and Earth. The Goddess manifests as Mother Earth & the God as the Sun King.

In even earlier times, the sun was perceived in its shinning prime and glory –
giver of light and heat and life, as the effulgent force of the Feminine - 
a passionate aspect of the versatile Great Mother, who issues forth & supports all life. 

The Solar Goddess was known in many ancient cultures and Her Priestess’ were highly regarded as healers and Psychopomps - Spiritual guides, initiating supplicants into the mysteries hidden behind the blinding light and fire of the solar disk. They used the 1st mirrors or lenses to harness the sun, to start the altar fires and to cauterize wounds for healing.

During the time of the ancient Egyptians, Sirius, the Dog Star rose on the Summer Solstice, heralding the beginning of their new year, just before the season of the Nile’s flooding.

The sun itself was deemed to be the all-seeing, all knowing, all powerful eye; but It was also known to be the “scorching eye of Ra” burning away the shadows, like a laser in the hands of a surgeon, cutting away disease, a power not to be taken (pardon the pun) lightly. 

Probably the most ancient source of the Solar Force known to humanity is an Egyptian lion-headed Goddess called Sekhmet. She displays all the passion of the noonday-sun at its peak, burning away all that does not serve, rousing us to dance our true power, in the magic ritual of our transformation.

Solar energy & its radiations are said to be the cause of evolution itself, reminding us that we can take an active role in our evolutionary process by aligning ourselves with this Solar Power, plugging in directly to the source of ourselves, to the source of action and passion.

But remember, at this time of the zenith, the brightest light, casts the deepest shadow. 

~Hazel Archer Ginsberg, Festivals Coordinator & Council Member of the Chicago Rudolf Steiner Branch

Cyantraniliprole; Pesticide Tolerances
This is how it works...I took the time to find out...Even read the entire paper!
ACTION...Final Rule.
SUMMARY...This regulation establishes tolerances for residues of cyantraniliprole in or on multiple commodities that are identified and discussed later in this document. E.I. du Pont de Nemours & Company (DuPont) requested these tolerances under the Federal Food, Drug, and Cosmetic Act (FFDCA).

ϟ ...a quantitative acute dietary exposure assessment is unnecessary.

ϟ ...dietary exposure assessment for the purpose of assessing cancer risk is unnecessary

ϟ be provided 5 years after the tolerance is established,

ϟ ...An acute dietary risk assessment was not conducted

ϟ ...intermediate-term exposures are not likely because of the intermittent nature of applications by homeowners.

ϟ ...In addition, the submitted data support the conclusion that the effects on the thyroid are secondary to effects on the liver.

ϟ ...Post-application incidental oral exposures for children may occur for short- and intermediate-term durations due to the persistence of cyantraniliprole. Further information regarding EPA standard assumptions and generic inputs for residential exposures may be found at EPA.

ϟ ...EPA has assumed that cyantraniliprole does not have a common mechanism of toxicity with other substances.

ϟ need for a developmental neurotoxicity study or additional UFs to account for neurotoxicity.

ϟ ...No adverse effect resulting from a single oral exposure was identified and no acute dietary endpoint was selected. Therefore, cyantraniliprole is not expected to pose an acute risk.

ϟ ...2. Chronic risk. Using the exposure assumptions described in this unit for chronic exposure, EPA has concluded that chronic exposure to cyantraniliprole from food and water will utilize 50% of the cPAD for children 1-2 years old (the population group receiving the greatest exposure) and 22% of the general U.S. population.

ϟ ...Determination of safety. Based on these risk assessments, EPA concludes that there is a reasonable certainty that no harm will result to the general population or to infants and children from aggregate exposure to cyantraniliprole residues.

ϟ ...In making its tolerance decisions, EPA seeks to harmonize U.S. tolerances with international standards whenever possible, consistent with U.S. food safety standards and agricultural practices. EPA considers the international maximum residue limits (MRLs) established by the Codex Alimentarius Commission (Codex), as required by FFDCA section 408(b)(4). The Codex Alimentarius is a joint United Nations Food and Agriculture Organization/World Health Organization food standards program, and it is recognized as an international food safety standards-setting organization in trade agreements to which the United States is a party. EPA may establish a tolerance that is different from a Codex MRL; however, FFDCA section 408(b)(4) requires that EPA explain the reasons for departing from the Codex level. Currently there are no Codex MRLs for cyantraniliprole.

ϟ ...Therefore, tolerances are established for residues of cyantraniliprole, 3-bromo-1-(3-chloro-2-pyridinyl)-N-[4-cyano-2-methyl-6-[(methylamino)carbonyl]phenyl]-1 H-pyrazole-5-carboxamide, including its metabolites and degradates, in or on....

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