By Ann G. Daniels

Time was, the people who worked for the Environmental Protection Agency believed the agency’s purpose was – wait for it – to protect the environment. That was then. Now, it’s the era of Scott Pruitt, who made his name by suing the EPA and wants to gut the agency.

What’s Up: Under President Obama, the EPA recommended banning chlorpyrifos, a dangerous pesticide. Under Pruitt, the EPA now proposes a regulation that reverses that recommendation and denies a petition to prevent the use of the chemical on crops. Chlorpyrifos is sold by Dow Chemical, which bankrolled Trump’s inauguration and whose CEO, Vanity Fair reports, “was literally standing next to the president in February when he signed an executive order ‘mandating the creation of task forces at federal agencies to roll back government regulations’.”

Fortunately, federal regulatory agencies like the EPA are required to listen to ordinary citizens before their proposed regulations become law. So let’s do it!

Action: Provide public comment to proposed rulemaking via Federal government website in order to keep the EPA from getting rid of environmental protections.

Deadline: June 5, 2017

Background: The EPA is proposing to overturn its own 2015 recommendation to ban the toxic chemical chlorpyrifos, used in pesticides.

There is significant scientific evidence that chlorpyrifos has harmful neurotoxic effects, even in tiny amounts. The EPA’s own evaluation over the course of several years also concluded that the chemical is also likely to adversely affect almost 1800 species of plants and animals, including critically endangered species. After the 2016 elections, however, Dow commissioned its own study that found that this enormous “scientific basis [was] not reliable.” Under a Ninth Circuit court order, the EPA’s decision on chlorpyrifos had to be made final by March 31: on March 29, Pruitt signed an order siding with Dow and overturning the EPA’s previous scientifically-based recommendation.

(For more details about the somewhat complex administrative background of the regulation, follow this link at

What you can do: Administrative orders like the one Pruitt signed are not the end – federal agencies are required to take comments from the public and consider those comments. You can file a comment on the proposed order by the Administrator  denying the “Petition to Revoke All Tolerances and Cancel All Registrations for the Pesticide Chlorpyrifos” (i.e., denying a petition that would ban the pesticide) Some things you might say:

  • Chlorpyrifos affects fetuses in utero, and children born to mothers exposed to the chemical have significant motor and developmental delays.
  • Studies show no safe level of exposure to chlorpyrifos for children.
  • Chlorpyrifos is so unsafe for people it has already been banned for use in the home (it used to be used as an insecticide).
  • The official record contains over 10,000 pages showing that chlorpyrifos is harmful to nearly every endangered species studied.
  • The only scientists to claim that chlorpyrifos is safe are those hired by Dow, which sells the chemical. Even the Agricultural Retailers Association, the National Corn Growers Association, and 40 other major agricultural organizations, which support the use of chlorpyrifos, have protested to the EPA that the agency is “not basing its decisions on science, while also trying to change its longtime review processes.”

More on the health effects of chlorpyrifos was recently reported in the NY Times.

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Ann G. Daniels’ checkered professional background includes practicing law, reproductive rights advocacy, creating web content for nonprofits and educational organizations, and teaching adult and family literacy. She also designs jewelry, teaches knitting, and sings second soprano.


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