UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

AUG I 9 2015 

MEMORANDUM 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: Response to Comments on Usage Data in Forchlorfenuron (128819) Preliminary 

Work Plan, Docket ID No. EPA-HQ-OPP-2014-0641, DP# 428394 

FROM: 

THRU: 

Carl Chen, Plant Pathologist 

Biological Analysis Branch 

Cynthia Doucoure, Environmental Protection Spec.ialist f 1 

Science Information and Analysis Branch 

Stephen Smearman, Economist /" rfl-- \/\A. f _,.._' ~ Economic Analysis Branch -rz>/ I) ~ 

Biological and Economic Analysis Division (7503P) 

Arnet Jones, Chief 

Biological Analysis Branch 

Science 

Diann Sim

Information 

s, Chief ~ and Analysis Branch 

Timothy Kiely, Chief (.)__ f, · 0 

Economic Analysis Branch \J J U;\."D 

Biological and Economic Analysis Division (7503P) 

TO: Wilhelmena Livingston, Chemical Review Manager 

Risk Management and Implementation Branch IV 

·Pesticide Re-evaluation Division (7508P) 

BEAD has reviewed the comments submitted by KIM-Cl, LLC on June 25, 2015 concerning the 

Forchlorfenuron Preliminary Work Plan (PWP), Docket ID No. EPA-HQ-OPP-2014-0641. 

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Listed below are the specific questions from the registrant related to various PWP sections that 

are relevant to BEAD, followed by BEAD's responses. 

KIM-Cl, LLC Comment on Section A. PWP Overview 

There are multiple dates associated with what, according to various Office of Chemical Safety 

and Pollution Prevention (OCSPP) web sites, is a first registration, KIM-Cl, UC recommends 

the following clarifications be included in the Final Work Plan: 

I) Confinn, and clarify, the correct first registration date. 

• lfthe July 12, 1989 date is correct, specify who is listed in EPA's records as the 

registrant for the July 12, 1989 "first registration"? What crop/crops are associated 

therewith? 

• If the 2004 date is correct add the month/day and specify who is listed in EPA 's 

records as the registrant associated with the Pesticide Fact Sheet "2004 Initial 

Registration" and what crop/crops are associated therewith? 

• If the 2005 dates are correct, specify who is listed in EPA 's records (presumably KIMCl, UC) as the registrant and what crop/crops are associated therewith. 

BEAD Response: 

Thanks for calling our attention to the first registrat.ion date discrepancies on the various EPA 

web sites. According to the Registration Division, the correct initial registration date is February 

2, 2005. The dates found on other web sites and in the BEAD Chemical Profile are incorrect. 

BEAD has corrected the initial registration date in the attached update of the Forchlorfenuron 

BEAD Chemical Profile and will notify other EPA staff about the incorrect date in the Fact 

Sheet. 

KIM-Cl, LLC Comment on Section C. PWP Use and Usage Information 

l) Under the "Guidance for Cornmenters" section the PWP document describes additional areas 

of use and usage related information of particular interest to EPA. KIM-Cl, LLC looks 

forward to cooperating with BEAD representatives to clarify/edify items listed under the 

"Guidance for Cornmenters" section, page 7, of the PWP. KIM C 1 is, herewith, providing 

the following information relative to forchorfenuron (CPPU) product use: 

• California Department of Pesticide Regulation (CDPR) reported usage rates of CPPU in 

table grapes averaged 2.24 and 2.45 grams a.i. per acre in 2013 and 2012, respectively, 

the most recent data available. These rates correlate with anecdotal information 

intermittently reported to the registrant. The rationale for these low rates is that the use 

of CPPU for sizing in table grapes is often in conjunction with gibberellic acid, applied 

either in tank mixes or in sequential applications. Some varieties that are particularly to 

gibberellic acid respond well to applications of CPPU alone at 8 to 10 gramsper acre 

while other varieties respond best at use rates as low as I to 2 grams per acre, most 

often applied in conjunction with gibberellic acid, in order to improve size, shape and 

storage characteristics of the fruit. 

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• Annual CDPR statewide Pesticide Use Reports (PUR) estimate that CPPU is used 

annually on about 20,000 of the 100,000 acres of table grapes in California. 

• CDPR PUR's show that CPPU is used on 1,400 of the 4,000 acres of kiwifruit grown in 

the state of California. CDPR reported the use rate of 4.2 and 4.5 grams per acre 

respectively in 20 13 and 2012. 

• CDPR PUR data also show that CPPU is used on ca. 750 of the 500,000 acres of wine 

grapes in California annually to improve fruit set, at a typical use rate of2 grams per 

acre. 

• The blueberry industry outside of California is beginning to realize that one to two 

applications of CPPU at rates of 1.5 to 2 grams per acre can improve fruit set and 

production and delay harvest beneficially. Less than 1,000 acres of the 70,000 acres 

grown in the U.S. are treated historically, but northern growing areas expect to see more 

usage. 

• 2015 is the first year of commercial usage of CPPU in sweet cherries and pears. Based 

upon the Federal EUP records estimates show that 2,000 acr~s out of the 30,000 acres of 

sweet cherries grown in Washington State were treated at a use rate of 5 grams per acre in 

2015. The estimate for pears in the same geography is for about 400 treated acres at a rate 

of 4 grams per acre. 

BEAD Response: 

1n response to # 1 above, we thank KIM-Cl , LLC for the 2012-2013 CDPR data on grapes, kiwi, 

and blueberries as well as the 2015 data on sweet cherries and pears. These data will be useful in 

BEAD's future work on forchlorfenuron. 

Attachment 

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