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CR comments to EPA on present uses of oxytetracycline in plant agriculture

SUMMARY: Consumer Reports comments on the Environmental Protection Agency’s Proposed Interim Registration Review Decision (PID) for the use of the active ingredient oxytetracycline in plant agriculture. Given the importance of  reducing antimicrobial resistance, and that EPA has not adequately addressed the risk to the environment (particularly pollinators like the honey bee), and to human health (through promotion of antibiotic resistance), we urge EPA to cancel all uses of oxytetracycline in plant agriculture. Any approval for oxytetracycline use should require a lot more data.  At a minimum EPA should classify oxytetracycline as a Restricted Use Pesticide so it can only be applied by a licensed trained applicator and  only via trunk injection.