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August 2, 2004

Via Electronic Docket

Public Information and Records\
Integrity Branch (PIRIB) (7502C)

Office of Pesticide Programs (OPP),\
Environmental Protection Agency

1200 Pennsylvania Avenue, NW\
Washington, DC, 20460-0001

RE: Docket No. OPP-2003-0237. Interim Reregistration Eligibility
Decision (IRED)for Methyl Parathion

The USA Rice Federation (USA Rice), located at 4301 N. Fairfax Drive,
Suite 425, Arlington, VA 22203, is the national advocate for all
segments of the rice industry. USA Rice members are active in all major
rice-producing states: Arkansas, California, Florida, Louisiana,
Mississippi, Missouri, and Texas. The USA Rice Producers' Group, USA
Rice Council and the USA Rice Millers' Association are charter members
of the USA Rice Federation.

We are writing you today to express USA Rice's support for the continued
use of methyl parathion. Our following comments are intended to help
continue the use of an important herbicide in our arsenal while
protecting human health and the environment. We appreciate the time and
effort that EPA has spent in the reregistration process for this product
and we look forward to working with the agency in the future on this and
other issues.

If you have any questions on these comments, please don't hesitate to
give me a call at 703-236-1445.

Sincerely,

Steve Hensley

Director, Regulatory Affairs

**[Introduction:]{.underline}**

Thank you for including the rice industry in the Reregistration
Eligibility Decision (RED) process. We appreciate the opportunity to
provide input as you work through the data review and final draft of the
RED. These points are meant to facilitate a discussion with EPA and
hopefully clarify issues in the user community for the methyl parathion
Reregistration Eligibility Decision.

Even though methyl parathion is a relatively old compound, it is still
relied on heavily due to its broad spectrum of pesticidal activity and
the lack of a selection of other controls for the same pests. Therefore,
methyl parathion remains an important rice pesticide.

**[Comments:]{.underline}**

1.  Restricted-Entry Intervals (REIs) for rice and Early Reintry
    Personal Protective Equipment (PPE). (IRED, pp. 71-72. "Required
    Labeling")

EPA lists the REI for the emulsifiable concentrate formulation as 4 days
for rice, and 31 days for microencapsulated formulation use on rice.
Regarding the microencapsulated formulation, a 31-day REI on a post
heading application would not allow reentry until after harvest.
Obviously this interval places the owner/operator and pest inspector in
an impossible situation.

Concerning the emulsifiable concentrate formulation, pest inspectors
routinely revisit the field within the next day or two to see if the
product has been effective on the pests. An interval of 4 days does not
allow for a quick reinspection of the field by an owner/operator or pest
inspector and can contribute to a reestablishment of the pest.

The agency also lists PPE for early reentry to treated areas. The PPE
includes:

-   Coveralls worn over long-sleeve shirt and long pants

-   Chemical-resistant gloves made of any water proof material

-   Chemical-resistant footwear plus socks

-   Chemical-resistant headgear for overhead exposures

This PPE is unmanageable in the hot and humid southern climates of rice
fields. Overheating is a chronic problem in these areas, and multiple
layers of clothing, coupled with some chemical-resistant impermeable
barriers will exacerbate the situation and lead to more immediate health
issues. In short, the above combination of PPE will render people unable
to function in the fields due in the climate conditions of the rice
growing areas.

**Recommendation:** Based on efficacy data contained in Appendix A, the
cost and pest data in Appendix B, and the reasons spelled out above, USA
Rice recommends a one week REI for the microencapsulated formulation and
a 2-day REI for the emulsifiable concentrate formulation. If the agency
is unable to reduce the proposed REI levels, we recommend that the PPE
requirements be reduced to a manageable level suitable for the
conditions of the area. The PPE for reentry should include one layer of
clothes and chemical-resistant footwear and gloves.

2.  The 0.75/lbs AI/acre/application (1.5 lbs AI/acre/year) with a
    2-application/year limit. (IRED, pg 73. "Required Labeling")

Because of its spectrum of pest control and the lack of other controls,
methyl parathion needs to be available for use when it is needed. The
proposed restraints on pounds active ingredient (AI) and applications
per year will severely limit the use and effectiveness of the product.
As you go further south into rice growing states, stinkbugs increase as
a problem to crops. Sometimes they are followed up by grasshoppers and
methyl parathion is a major control for both. In many rice states two or
more repeat applications are required. With a 1.5-pound/acre AI seasonal
limit on each acre, repeat applications that would total above the limit
would be prohibited and effective pest control lost. In addition, methyl
parathion must sometimes be applied more than twice in a season due to
severe infestations. Rice growers may sometimes need 3 pounds per season
minimum to save their crops from pests.

**Recommendation:** USA Rice recommends that a 3 lbs/AI/acre/year limit
with 4 applications/year allowed.

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