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Ples Spradley

AAPSE President

C/O University of Arkansas Extension

2301 S. University

Liftle Rock, AR 72204

501-671-2234

October 29,2008

Ms. Veronique Lacapra

Special Review and Registration Division

Office of Pesticide Programs Regulatory Docket (7502P)

US Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460-0001

RE: Reregistration Eligibility Decision (RED) for Soil Fumigant Dockets

EPA-HQ-OPP-2005: 0123 Methyl Bromide, 0124 1,3 Dichloropropene,}l25 Metam Sodium,

0l28 Dazomet, 0252 lodomethane, and 2007-0350 Chloropicrin

The comments below were submitted via Regulationr.g'ov on October 29,2008

The American Association of Pesticide Safety Educators (AAPSE) is a professional organization

that represents State Lead Agency applicator certification management personnel and state

Cooperative Extension pesticide safety educator faculty and staff, including county extension

agents and specialists who conduct pesticide safety education programs. AAPSE also has

associate members from the agrichemical industry, pest control companies, and nongovernmental agencies. AAPSE members develop and review pesticide safety education

programs (materials and methods), develop and assess certification exams, track certification of

applicators, and assess the quality and impact of these programs.

In reviewing the Soil Fumigant fact sheet and REDs, AAPSE has some areas of agreement and

other areas ofconcern.

RED Issue #1. Classification of all soil fumigants as federally restricted use (R{IP).

AAPSE supports this decision. We stress that this allows states to implement mitigation through

their existing Certification and Training Programs.

AAPSE suggests there are other RUP and certification measures that could be considered to

mitigate the risks associated with soil fumigants that may remove the need for several other

proposed RED mitigation measures. For example, EPA could utilize the Restricted Use Pesticide

box on soil fumigant labels to restrict application of soil fumigants to only certified applicators

with no provision for direct supervision of uncertified applicators (For retail sale and use only by

Certified Applicators and onlyfor those uses covered by the Certified Applicator's certification;

Direct supervision is prohibited). However, AAPSE recognizes this idea and other potential

certification or RUP restrictions require fuither evaluation and development.
As an association we offer our expertise and advice on identifying and evaluating various

strategies to reduce these risks by certification, initial training, and recertification measures. We

believe it is important for EPA's Certification and Worker Protection Branch as well as the

Registration Division to be involved in any discussions with interested parties. We also urge

EPA to seek the advice and input of the Association of American Pest Control OfFrcials

(AAPCO), the Certification and Training Advisory Group (CTAG), and other stakeholders on

these issues.

RED Issue #2. Label-mandated, registrant-provided training.

AAPSE has clearly outlined to EPA its concerns for label-mandated, registrant-provided training

in a July 28, 2008letter from our Association to Debbie Edwards on the herbicide picloram. EPA

reviewed the submitted comments and agreed to remove the requirement for registrant-provided

training. If EPA pursues a label-mandated certification or training requirement, AAPSE strongly

suggests the requirement fall within existing Certification & Training Programs with the State

Lead Agencies and Cooperative Extension Service working cooperatively with EPA's

Certification and Worker Protection Branch.

AAPSE strongly supports registrant-provided stewardship programs as long as they are not

mandated on the label with corresponding compliance issues (tracking, recordkeeping,

requirements for point of sale, etc.). Current Certification & Training Programs in states with a

fumigation or soil fumigation category rely on collaborative efforts of the State Lead Agencies,

Cooperative Extension Service, application equipment and agrichemical dealers, and product

registrants.

RED Issue #3. Notice to State and Tribal Lead Agencies.

AAPSE members are also concerned for the burden on state lead agencies regarding notification.

Notification could be burdensome for states to process, track, conduct enforcement activity, and

process freedom of information requests.

AAPSE appreciates EPA's consideration of the above concerns related to the soil fumigant fact

sheet and REDs. We look forward to working directly with EPA to assess Certification and

Training programs as a mitigation function

Bill Diamond, Kevin Keaney, FEAD

Jack Peterson, SFIREG Chair

Maureen Serafini" AAPCO President

Roger Flashinski, CTAG Co-Chair

Dirk Helder, SRRD