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 risk
 assessment. 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=pdf
Regards,

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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