### Fw: RED Amendment Posted DuPont Comment Jack Cain to: Jim Tompkins 01/11/2010 12:16 PM Cc: Russell Wasem

Hello Jim,

My apologies. I sent the attached to Rusty on Friday and forgot to copy you in.

Jack Cain DuPont Crop Protection Stine-Haskell Research Center 1090 Elkton Rd. Newark, DE 19711 jack.cain@usa.dupont.com Office: 302 366-6417 Cell: 610 316-5006 Fax: 302 351-6841 ----- Forwarded by Jack Cain/AE/DuPont on 01/11/2010 12:13 PM -----

Jack Cain/AE/DuPont To 01/08/2010 02:17 Wasem.Russell@epamail.epa.gov@DUPON PM T_MHUB

cc Moriarty.Thomas@epamail.epa.gov Subject Re: RED Amendment Posted DuPont Comment(Document link: Jack Cain)

Hello Rusty,

I really want to thank you again for all your work involving the Sulfometuron Methyl (SMM) RED. It has been a long process but I think we are nearing closure. Confirming our conversation earlier today, there are a few discrepancies in the RED Amendment that I feel need to be addressed.

There are a number of references to "liquid formulations". These should all actually refer to "formulations applied in a liquid matrix", To my knowledge there are no liquid formulations containing SMM. The amendment restricts applications to "Extremely coarse" nozzles >500 micron VMD, yet all of the modeling tables presented in both the EFED Response to Comment, and the RED Amendment report most conservative assumptions using "Very Coarse to Extremely Coarse" nozzles ( VMD 519). I would suggest that a label mitigation requiring "Very coarse or coarser" nozzles is really commensurate with the revised riskassessment. Further, its my understanding after reviewing available literature that from a practical perspective "Extremely Coarse" nozzles are not normally used when applying pesticides.

In addition to the above which we discussed by phone, I also would note the following:

Label mitigation language is requiring PPE text pertaining to gloves, yet there is no requirement for gloves as PPE based on the revised HED Risk Assessment. The stated requirement for all mixers, loaders and applicators is "baseline PPE" (long sleeve shirt, long pants, shoes and socks). Gloves are only required for early reentry under the WPS. The single application rates have been reduced for forestry and non-crop ROW applications but the total maximum annual application rate is still 0.375 lb a.i. per acre. Also, since only the maximum non-crop single application rate made to ROW's has been reduced to 0.281 lb a.i.. other non-crop applications such as under asphalt/concrete, and to industrial sites such as tank farms, utility sub stations, etc. are still allowed to be made at the maximum single application rate of 0.375 lb a.i.. I would recommend that all this be clarified.

Best Regards,

Jack Cain DuPont Crop Protection Stine-Haskell Research Center 1090 Elkton Rd. Newark, DE 19711 jack.cain@usa.dupont.com Office: 302 366-6417 Cell: 610 316-5006 Fax: 302 351-6841

Wasem.Russell@epa mail.epa.gov To 01/08/2010 10:04 Jack Cain/AE/DuPont@DuPont AM cc Moriarty.Thomas@epamail.epa.gov Subject RED Amendment Posted

Good Morning Jack,

The Amended RED has posted in the docket: http://www.regulations.gov/search/Regs/contentStreamer?objectId=0900006480a75f 9f&disposition=attachment&contentType=pdfRegards,

Rusty____________

__________ Rusty Wasem / Chemical Review Manager Risk Management & Implementation Branch 1* Pesticide Re-evaluation Division* / Office of Pesticide Programs 703 / 305 6979

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