UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WAS H I N GT O N , D

. C

. 204 60 

## AUG 

## I 9 2015

MEMORANDUM OFF ICE OF C H EMICAL SAFETY AND POLLU T ION PREVEN T ION



### SUBJECT: Respo n se to Comments on U sage Data in Forchlorfenuron (128819) Prelimin ary Work Plan , Docket ID No. EPA-HQ-OPP-2014-0641, DP# 428394 

### FROM:

THRU: Carl Chen , Plant Pathologi st Biological Analysis Branch Cynthia Doucoure , Environmental Protection Spec

. iali st 

# f**1** Science Information and Analy s is Branch Stephen Smearman, Economi st /" 

## rfl-- \/\A. f_,.. _'

## ~ Economic Analy s i s Branch 

### -rz>/ I)

### ~ Biolo g ical and Economic Analy s i s Divi si on (7503P)
Arnet Jon es, Chief Biological Analysis Branch
Diann Sims , Chief

# ~ Science Information and Analysis Branch Timothy Kiely , Chief (.)__ f, · 

# 0 Economic Analys is Branch \J

# J U;\."D Biological and Economic Analysis Di vis ion (7503P) 

### TO: Wilhelmena Li ving ston, Chemical Revi ew Manager Ri sk Management and Impl e mentation Branch IV

· Pe sticide Re-evaluation Divi s ion (7508P)

BEAD has reviewed the comments submitted by KIM -C l , LLC on June 25, 2015 concerning th e Forchlorf e nuron Preliminary Work Plan (PWP), Docket ID No. EPA-HQ-OPP-2014-0641. Page 1 of3·Listed below are the spec ifi c questions from th e registrant related to variou s PWP sect ion s that are relevant to BEAD , followed by BEAD 's re sponses.


### 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 th e Final Work Plan:

I) Confinn, a nd clarify, the correct first regis tration date. • lfthe July 1 2, 1989 date is correc t , specify who is listed in EPA's records as the registrant for the Jul y 12, 1989 "first registration"? What crop/c rops 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 asso c iated therewith ? 

### • If the 2005 dat es are correct , specify who is listed in EPA 's re co rds (presumably KIM

Cl , UC) as th e r egistrant and wha t cro p/crops are associated th erewith. 

### BEAD Response : Thanks for calling our attention to the first registrat

. ion date discrepancies on the variou s EPA web s ites. According to the Registration Divi s ion , the correct initial reg istration date is February 2 , 2005. The dates found on other web sites and in the BEAD Chemical Profile are incorrect. BEAD has corrected th e initial reg istration date in the attached update of the Forchlorfenuron BEAD Chemica l Profile and will notify other EPA s taff 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 " sectio n the PWP document des cribes additional areas of use and usage r e lated information of parti c ular interest to EPA. KIM-Cl, LLC look s forward to cooperating with BEAD repre se ntative s to clarify/edify items li sted under th e "G uidance for Cornmenters" section , page 7 , of the PWP. KIM C 1 is, herewith, pro v idin g the following information relative to forchorfenuron (CPPU) product u se:

• California Department of Pe stici d e Regulation (CDPR ) reported u sage rates of CPPU in table grape s averaged 2.24 and 2.45 gr ams a .i

. per acre in 2013 and 2012, respectively , the mo s t recent data available. These rates correlate with anecdotal information intermittently reported to the registrant. The rationale for th ese low rates is that the u se of CPPU for s izing 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 ac id re s pond well to application s 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, mo st often applied in co njunction with gibbere llic acid, in order to improve s ize, shap e and storage characteri stic s of the fruit.

Page 2 of 

## 3• Annual CDPR statewide Pesticide Use Reports (PUR) estimate that CPPU is used annually on abo ut 20 , 000 of the 100 , 000 acres of table grapes in California.

• CDPR PUR's s how that CPPU is u sed on 1 ,400 of the 4,000 acres ofkiwifruit 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 indu stry 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 geograp hy is for about 400 treated acres at a rate of4 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.

Attachme nt

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