Submitted to EPA on the agency's risk assessment for the pesticide oxytetracycline. KAW strongly encourages EPA to apply risk management steps consistent with the FDA approach. In particular, KAW believes that the prophylactic use of oxytetracycline to treat whole orchards is an inappropriate use of this highly important antibiotic and that this use is inconsistent with risk management options that are appropriate for a pesticide determined to be of medium risk for creating an adverse human health impact.