UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASH I NGTON , D
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OFFICE OF CHEMICAL SAFETY AND PO L LUTION P REVE NTIO N MEMORANDUM SUBJECT :

FROM:

THRU :

TO: BEAD Response to Comments Received During the Indoxacarb Registration Review Docket Opening (PC Code: 067710) from EPA Docket ID: EPA-HQOPP-2013-0367 Monisha Kaul, Biologist

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# {euJ Biological Analysis Branch Stephen Smearman, Economist

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... A •• __ Economic Analysis Branch

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# Jf~~ Science Information & Analysis Branch Biological and Economic Analysis Division (7503P) Arnet Jones, Chief Biological Analysis Branc Timothy Kiely, Chief 

# !':\-**ltv\_'(-~** Economic Analysis Branch

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# J Diann Sims, Chief

# ;t}~ Science Information & Analysis Branch Biological and Economic Analysis Division (7503P) Marquea King, Acting Team Leader RMIB-V Pesticide Re-evaluation Division (7508P) Peer Review Panel Date: November 6, 2013 The indoxacarb registration review docket opened for comment on June 26, 2013. The Agency received comments related to the Indoxacarb Preliminary Work Plan (PWP) and other supporting documents placed in the docket. The PWP provided guidance for commenters rega rding the types ofuse and usage information that would be useful to the Agency. The following includes a brief summary ofthe use and usage information received from the California Stormwater Quality Association (CASQA), the California Central Valley Regional Water Quality Control Board(Central Valley Water Board), and the National Alfalfa and Forage Alliance (NAFA) followed by the Agency's response*. Comment 1: The Agency received information/rom the Central Valley Water Board (Docket ID: EPA -H Q-OPP-2013-0367-0011) andNAFA (Docket ID: EPA-HQ-OPP-2013-0367-0010) addressing the use ofindoxacarb on alfalfa. The Central Valley Water Board stated that indoxacarb use on alfalfa accounted for a substantialportion of indoxacarb use in California in 2011
. NAFA stated that indoxacarb is an important insecticide in alfalfa seed and forage production. NAF A also stated that indoxacarb is an important tool because it has a broad spectrum insect control. BEAD Response: The Agency's data sources indica te little use of indoxacarb on alfalfa nationally during 2007-2011 , which was the time period discussed in Table 4 ofthe PWP (Docket ID: EPA

-HQ

- OPP

-2013-0367-0002) and the BEAD Chemical Profile for Registration Review (Docket ID : EPA-HQ-OPP-2013

-0367-0006). However, newly released information indicates an increase in national indoxacarb use on alfalfa in 2012. The Agency plans to update and refine indoxacarb usage information during the registration review process. The information submitted by the Central Valley Water Board and NAFA will be considered as needed during this process. Comment 2: The Agency received information from the Central Valley Water Board (Docket ID: EPA -HQ-OPP-2013-0367-0011) and CASQA (Docket ID: EPA -HQ-OPP-2013-0367 -0014) related to the request in the PWP for use and usage information. The Central Valley Water Board submitted an overview of the timing of indoxacarb applications made in California and provided a summary of agricultural and non-agricultural usage data from the California Department of Pesticide Reporting (CDPR)for 2007-2011
. The CASQA submitted the most recent California sales data of 46,000pounds in 2011
. BEAD Response: State-level information regarding pesticide application timing, usage and sales is helpful to the Agency for understanding use patterns particularly ifthe patterns vary by region. The Agency plans to update and refine the use and usage information of indoxacarb during the registration review process and will consider the information submitted by the Central Valley Water Board and CASQA as needed during this process.
*All EPA documents and submitted comments can be found under docket ID: EPA-HQ-OPP-2013-0367 at http: //www.regulations.gov/# !docketDetail;D=EPA-HQ-OPP-20 13-0367
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