Subject: Docket ID Number **OPP-2005-0050**

May 9, 2005

Comments in Response to *Petition to Modify or Revoke Tolerances
Established for Alachlor, Chlorothalonil, Methomyl, Metribuzin, and
Thiodicarb; Notice of Availability*

There are a number of important uses for these pesticides in Hawai'i.

**Alachlor**

Under the current situation, if tolerances are revoked and alachlor is
NOT available for use on **seed corn**, the seed corn industry could be
irreparably harmed. S-metolachlor (Dual Magnum) is a possible
alternative for alachlor. However, changes to the Hawai'i Administrative
Rules governing pesticides are required for S-metolachlor to become an
alternative to alachlor. The changes are not yet approved.

**Chlorothalonil**

1\. Important component of rotational programs. Vegetable growers cannot
afford to lose this resistance management and IPM tool. Specific
important uses include **celery** (in rotation for blight control ) and
**cabbage, broccoli, tomatoes**, and **cucumber**.

2\. While not a very common use, chlorothalonil (Bravo) is used in
**papaya**, for crops grown for local consumption. Growers need to
retain this use as a possible alternative to the more commonly used
mancozeb (Dithane).

**Methomyl**

Methomyl (Lannate) is one of the few carbamates remaining for use in
rotation programs. It is used on **tomatoes, cucumbers, cole crops** and
**corn seed** for lepodoptera type insects among others.

**Metribuzin**

1\. Sencor/Lexone is used at 3/4 lb/A in potato as a preemergence
herbicide in about 100 acres in Hawai'i.

2\. Sencor is used as an pre/post herbicide in sugarcane.

**Stakeholder Responses:**

Hawai'i Farm Bureau Federation:

The Hawaii Farm Bureau Federation expresses concern that

the alteration or elimination of tolerances for any of the listed

pesticides could have very serious economic consequences for Hawaii

growers. All of the listed pesticides are important pieces of the

integrated pest management programs for the crops currently listed on

their labels except for thiodicarb. With constant year round pest

pressure the loss of these pesticides are potentially devastating for
our

farmers and especially for the seed producers who comprise a
considerable

portion of the Hawaii Farm Bureau membership.

Hawai'i Agriculture Research Center:

In the crop list for metribuzin, potato and sugarcane should be

added. Sencor/Lexone is used at 3/4 lb/A in potato as a

preemergence herbicide in about 100 acres in Hawaii. Sencor is

used as an pre/post herbicide in sugarcane.

Local chemical distributor:

Just a quick comment on alachlor- Here in Hawaii, the failure of our DOA

to license S-metolachlor (Dual Magnum) for use leaves our growers,

especially the seed corn industry in a precarious position.

In short, DOA wants to license S-metolachlor (& acetochlor) as RUPs in

Hawaii because of a Ground Water Advisory Statement on the label. The

manufacturers refuse to allow that to happen so we are at a stalemate-

those products will NOT be licensed in Hawaii. (There are exceptions-

pre-packs or combination products that have one RUP component, can and
are

licensed such as Bicep Magnum- atrazine & s-metolachlor.)

S-metolachlor would be the product of choice for most growers but they
are

\"forced\" to use alachlor. If tolerances are revoked and alachlor is
NOT

available for use on seed corn, the seed corn industry could be

irreparably harmed. (My opinion.)

This situation is unique to Hawaii.

(update) Thanks for the reminder.

RE: alachlor/S-metolachlor- Might be a non-issue as the HDOA\'s proposed

rules come into effect. While we are a ways off since a series of Public

Hearings must be held prior to promulgation, the new rules do allow for

licensing of s-metolachlor in Hawaii (as RUP). (Confusing but

manufacturers have refused to VOLUNTARILY license as RUP but if
designated

RUP by rules, they are OK.)

Another local chemical distributor:

Lasso- Corn Seed widely used under brand name Intrro instead of Lasso in

\> hawaii. Chlorothalonil- Used in veg crop(Celery-Rotation) for blight

\> control, other veg crops ie cabbage,broccoli,tomatoes,some

\> papaya,cucumber. Excellent rotational product like Mancozeb, we
cannot

\> afford to lose this resistant management and IPM tool. Lannate- One
of

\> the few carbamates left to rotate w/. Used on tomatoes,cucumbers,cole

\> crops and corn seed, for lepodoptera type insects among others.
Larvin-

\> not much used in Hawaii. Sencor- Mostly used widely in turf for

\> goosegrass control. Very important to the GC industry.

Extension agent:

Hi Cathy, I guess we would like to have bravo as a standby should

anything happen to Dithane. The problem with Bravo is that it has a

sticker already in the fungicide and it causes fruit scalding when heat

treated. In the local market it is not a problem. In addition white skin

people (and dark) tend to get blisters when the product gets on their

clothes when picking fruits in the rain. But still a standby fungicide
is

essential if the alternative is no Dithane.

**Comments compiled and submitted by:**

Dr. Michael Kawate

voice: 808/956-6008

e-mail: mike@hpirs.stjohn.hawaii.edu

Cathy Tarutani

voice: 808/956-2004

e-mail: cathy@hpirs.stjohn.hawaii.edu

Department of Plant and Environmental Protection Sciences\
3190 Maile Way, St John 307

University of Hawai'i

Honolulu, HI 96822