To: Mary Reaves, Acting Director, Pesticide Re-Evaluation Division
"While we appreciate that EPA will screen these chemicals for effects through the Endocrine Disruptors Screening Program (EDSP), we note that the current EDSP testing battery does not evaluate potential adverse effects of thyroid disruption. EPA must therefore include a thorough assessment of the peer-reviewed scientific literature on the toxic effects of these chemicals consistent with established principles of endocrine science, including the potential for NMDR and the possibility that no threshold for safety exists.
In summary, the data linking early-life neonicotinoid exposure to thyroid disruption is very concerning and EPA should conduct their review of these chemicals, incorporating the latest peer-reviewed science, as a cumulative assessment group."
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