(August 21, 2019) – In comments submitted August 15, NACWA asked EPA to consider exposure pathways from pesticides used indoors in its revised Endangered Species Act (ESA) biological evaluation method for pesticides.
Pesticides used indoors can be washed into the sewer system when surfaces, clothing, and pets are washed and when people wash their hands and shower. These pesticides can then pass through the treatment plant and be discharged into the aquatic environments. Despite these potential pathways from indoor use to the environment, the draft biological evaluation method listed “indoor use” as an example of a pesticide use location with no environmental exposure pathway.
NACWA also recommended that EPA consider cumulative effects of indoor pesticide use and other sources on POTW receiving waters. In addition, all pesticide uses that EPA considers approving should be evaluated, not just historic usage. NACWA provided a statement with these points during a June 10 public meeting on the biological evaluation method.
NACWA members with concerns or comments about pesticide impacts on wastewater utilities should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.