Competitive Enterprise Institute | 1899 L ST NW Floor 12, Washington, DC 20036 | Phone: 202-331-1010 | Fax: 202-331-0640
June 1, 2000 – “Americans may face increased risks of contracting potentially deadly and debilitating diseases under a recently proposed rule,” said Jennifer Zambone, environmental policy analyst for the Competitive Enterprise Institute. Zambone recently filed comments to the U.S. Environmental Protection Agency (EPA) on its rule addressing public health pests [Fed. Reg., March 29, 2000, pps. 16615-16616].<?XML:NAMESPACE PREFIX = O />
The Food Quality Protection Act of 1996 instructed EPA to compile a list of “pest of significant public health importance.” The purpose of this list was to emphasize that pesticides play an important role in controlling vector borne diseases, such as West Nile virus, encephalitis and Lyme Disease, by killing the carriers of such diseases. Placing a pest on the list increases the legal options for controlling the pest with pesticides. However, in its proposed rule, the EPA devised a narrow definition of public health pest.
“The EPA has defined ‘a public health pest’ in an arbitrary fashion, – excluding some of the most dangerous vectors, such as ticks. ” noted Zambone. “Ticks constitute a significant public health threat, carrying a variety of diseases including Lyme Disease, Rocky Mountain Spotted Fever, and varieties of ehrlichiosis,” she continued. In 1999, there were 13,306 cases of Lyme Disease alone, a number that almost equals the incidence of tuberculosis in the United States. M. tuberculosis is included on the pest list, but the tick is not.
“It is unconscionable that EPA omitted such a ubiquitous, dangerous, and potentially lethal pest from the list of pests of significant public health importance. Lack of inclusion of a pest on the list could potentially abolish several useful pesticides from production, increasing the difficulty of containing a disease outbreak,” Zambone concluded.
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