EPA’s re-classification “dangerously ignores science and downplays the risks individuals face when they are exposed to 1,3-D,” wrote the attorneys general of seven states and the District of Columbia in a 2020 letter to the Office of Pesticide Programs. Top law enforcement officers from New York to California charged agency officials with omitting studies linking 1,3-D to cancer in humans, and ultimately relying “entirely on industry-sponsored studies” and “crediting an unsupported Dow theory” to ignore cancer responses at certain doses. Dow did not respond to repeated requests for comment.
The decision also triggered multiple complaints to the Office of Inspector General, which highlighted the attorneys’ general letter in its report.
In one complaint, Timothy Whitehouse, the executive director of Public Employees for Environmental Responsibility, or PEER, said misrepresentations and omissions by EPA officials “put applicators of the fumigant and the public at grave risk, given that 1,3-D is one of the nation’s most-used pesticides.”
