UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D

. C. 20460

MEMORANDUM Date: March 26, 2014 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

SUBJECT: Methyl Bromide. HED 's Response to the Methyl Bromide Preliminary Work Plan Comments Submitted by the Methyl Bromide Industry Panel (MBIP); D417431. PC Code: 05320 I DP Barcode: 0417431 Decision No.: 486878 Registration No.: GDCI-053201-26629 Petition No.: N / A Regulatory Action: PWP Response Risk Assessment Type: N / A Case No.: N/A**TXRN~ :**  NM**CASN~:** NM MRID No.: 4860270 I 40 CFR: N/A FROM: Matt h ew Lloyd, Risk Assessor 

# /1/lf,Jl

# ~ Risk Assessment Branch 7 (RABV II ) Health Effects Division (7509P) THROUGH: Jeff Dawson, Chemist HED Immedia te Office

### ~ 

# ' J ()**~~hael** Metzger, Branch Chief 

# 'J )(· Risk Assessment Branch VII (RA I) Health Effects Division (7509P) TO: Sue Bartow , Chemical Review Manager Cathryn Britton, Team Leader Pesticide Re-Evaluation Division (7508P) Attached is HED's response to the Methyl Bromide Industry Panel' s comments submitted to the Agency on November 25 , 20 13 on the methyl bromide Preliminary Work Plan (PWP). There were two submissions to address the post-harvest commodity uses of methyl bromide as we ll as the pre-plant methyl bromide uses.

Page 1 of 3POST HARVEST: MBIP Su mmarized Comment: E PA 's characterization that thi s data requirement [" 875.2500- Inh a lation exposure ( post-application)" from GDCI-05320 1-26629 ] i s "outstand in g" is incorrect.
EPA Response: The Agency acknowledges the receipt of a study to addre ss the data requirement (MRID 48602701), although that study does not fulfill the Agency data requirement. The M BIPs ubmitted protocol included monitoring to be comp leted fo r California (Long Beach), the mid

At lantic (PA, DE , NJ) , and Florida (Miami). The Agency has only re ce iv ed data for the Lon g Beach location. Si nce th e study has not b ee n comp leted, the data requirement remains ou t standing

.
MBIP Summarized Comment: If EPA conducts an updated risk asse ss ment for methyl bromide as used in cold storage facilities, the B est Manag emen t Practices (BMP s) currently in place at facilities handling treated commodities s hou ld be taken into account.
EPA Re spon se: The Age ncy co mpletes hum an health risk assessments based on a number of facto r s. In the case of methyl bromide , the prod uct labels outline requirem e nts for occupational handlers and bystander s who may be exp osed to methyl bromide around ports, cold sto ra ge facilities, and for pre-p lant so il fumigations. EPA completes an exposure a nd risk assessment for the se wo rker s/bystanders and avai lab le use and usage informat ion to help characterize exposure and risk estimates fo r risk managers. EP A can consider how additional measures , like BMPs , can influence the risk picture. These practice s can help risk managers in miti gating risks.

PRE-PLANT: MBIP Summarized Comment: The ambient air monitor in g data requirement (GDC I-05320 1- 836) applies to soi l u ses an d the registrants are under no legal obligation to co nduct the st ud ies si nce the DCI referen ces commodity fumigation si te s. EPA Response: The PWP response from MBIP claims that the Hum an Health Scoping Document misch aracterize d the outstandin g GDCI as requiring ambi e nt a ir monitoring near commodity fumi gati on s ites in Miami , Florida and th e D e laware Ri ver bas in

. The Human Health Scoping Document summari ze d the data gaps identified in order to comp lete a comprehensive risk assessment for methyl bromide. The Agency needs longitudinal ambient air monitoring data from areas of highest methyl bromide use - both for pre-plant and post-harvest commodity uses. HED be lie ves that the appropriate choice for significant use areas in cludes: Page 2 of 31. 

### Siskiyou County, CA o The Agency believes that monitoring data from Siskiyou County is important because of unique co nditions that can not be translated from existing/on-goi ng monitoring effo rt s (e.g .- due to weather, topographical, and use diff erences) 

### 2. Georgia forestry nurseries; and 3. the Maritime Exchange Region for the Delaware River a nd Bay o The Agency believes that monitoring from this region is app ropriate to refl ect the post-harv est commodity fumigations that occur in mid-Atlantic ports (Pennsylvania, New J ersey, Delaware). Another suitable high use location may be appropriate. Criteria that must be cons idered in sele cting the monitoring sites include: (1) areas of highest methyl bromide use , (2) duration of the u se of methyl bromide for a candidate study area, (3) geographically unique features that could affect ambient air conce ntration lev e ls (e.g., valleys, flat terrain), (4) weather cons iderations which may adversely impact amb ient exposures (e.g., frequent inversions or air stagnation events) , (5) proximity of methyl bromide use to bystander populations , (6) proximity of methyl bromide use to sensitive populations (e.g

. , school children), (7) proximity of methyl bromide use to minority populations to define potential environmental justice concerns such as disparate exposures to certain populations, and (8) logistical access. Because of the sampli ng design necessary to meet this DC I requirement, HED believes the registrants should be required to obtain a comprehensive Agency protocol review before study initiation.

Page 3 of 3