UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
April
19,
2004
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Erik
D.
Olson
Natural
Resources
Defense
Council
1200
New
York
Ave,
NW
Suite
400
Washington,
D.
C.
20005
Fred
H.
Altshuler
Altshuler,
Berzon,
Nussbaum,
Rubin
&
Demain
177
Post
Street,
Suite
300
San
Francisco,
CA
94108
Re:
Amended
Partial
Consent
Decree
in
Natural
Resources
Defense
Council,
et
al.,
v.
Whitman
(
Case
No.
C­
99­
3701
CAL).

Dear
Mr.
Olson
and
Mr.
Altshuler:

This
letter
serves
as
the
notice
required
by
the
Amended
Partial
Consent
Decree,
paragraph
9(
c),
in
case
No.
C­
99­
3701
CAL.

EPA
has
determined
that
those
worker
risks
determined
to
be
an
unreasonable
adverse
effect
on
the
environment
as
identified
in
the
Interim
Reregistration
Eligibility
Decision
(
IRED)
for
diazinon
will
be
eliminated
through
the
implementation
of
several
final,
effective
regulatory
instruments.
Specifically,
those
worker
risks
will
be
eliminated
through
implementation
of
recent
amendments
to
the
terms
and
conditions
of
all
diazinon
registrations
that
require
registrants
to
adopt
specific
engineering
controls
and
personal
protective
equipment
requirements.
The
bases
for
EPA's
determination
that
the
engineering
controls
and
personal
protective
equipment
will
eliminate
those
worker
risks
determined
to
be
an
unreasonable
adverse
effect
on
the
environment
are
detailed
in
the
IRED
and
its
supporting
documents.
Once
the
terms
and
conditions
are
implemented,
EPA
does
not
expect
any
of
the
unacceptable
worker
risks
that
were
determined
to
be
an
unreasonable
adverse
effect
on
the
environment
in
the
IRED
to
remain.

EPA
will
provide
the
public
with
notice
of
this
determination
by
posting
this
letter
on
the
Office
of
Pesticide
Program's
homepage,
which
can
be
found
at
www.
epa.
gov/
pesticides.
Should
you
have
any
questions
regarding
this
determination,
you
may
contact
Susan
Lewis
at
703­
308­
8009.

Sincerely,

//
s
//
Debra
Edwards,
Ph.
D.
Director
Special
Review
and
Reregistration
Division
