UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON

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. 20460 

### APR 1 7 2014

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION



### SUBJECT: BEAD Responses to Public Comments Concerning the Registration Review of Dithiopyr from EPA Docket ID No. EPA-HQ-OPP-2013-0750, DP# 418541 FROM: Cynthia Doucoure, Environmental Protection Specialist 

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### ~~ Science Information and Analysis Branch Biological and Economic Analysis Division (7503P) 

### THRU: Diann Sims, Chief

## ~ Science Information and Analysis Branch TO: Veronica Dutch, Chemical Review Manager Risk Management and Implementation Branch V Pesticide Re-evaluation Division (7508P)
Product Review Panel Date: Through this memo, BEAD is responding to Dow AgroSciences (DAS) Comments on the U.S. EPA's Dithiopyr Registration Review Docket EPA-HQ-OPP-2013-0750. Comments about the label data report and general usage data are listed below, followed by BEAD's responses.
DAS Comments on Dithiopyr BEAD Chemical Profile: 1. 

### Reference: GeneralReference to BEAD ChemicalProfile Document. The Registration Review docket contains the Agency's Biological andEconomic Analysis Division (BEAD) Chemical Profile, intended toprovidepesticide use-related information andeconomic analyses in support of pesticide regulatory activities. As the economic, social, andenvironmental costs and benefits of the use of anypesticide are considered in the reviewprocess, DAS isproviding a benefits document as an Appendix tofurther substantiate value, benefits, and economic impact of dithiopyr
. Stakeholder input will further help the Agency to understand and validate the importance of dithiopyr to the turf care industry, ornamental nurseries, golf courses, and the real estate market. A successful Registration Reviewprocess for dithiopyr will ensure that this tool for the US. turf andornamental community remains viable and beneficial. 

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### BEAD Response: BEAD appreciates the "Dithiopyr Benefits Assessment Review," which further clarifies the benefits ofdithiopyr in the U.S.
2. Reference: Common Formulations andApplication Methods: Page 2. Paragraph 1. Documentstates: Dithiopyr is formulated as emulsifiable, suspension, and soluble concentrates, water solublepouches, granules, and liquids ready-to-use. Comment: Primary DAS end useproducts containing dithiopyr are EW (emulsion in water) andgranular formulations
. These twoformulations comprise the majority of product sales associatedwith DAS dithiopyr registrations. EC, SC and WPIWSP formulations are also associatedwith DASdithiopyr registrations.


### BEAD Response: BEAD appreciates the clarification ofthe various dithiopyr product formulations.

3. Reference: Use Sites: Page 2. Paragraph 1. Documentstates: Dithiopyr is labeled for use on landscape,fteldandcontainergrown ornamentals locatedin ornamentalgardens,parks, golf courses, and residential areas; on nonbearingfruitandnuttrees (nonfoodproducing trees); on turfsites (residential and institutional lawns, athleticfields, commercial sod farms, and golf coursefairways, and roughs); and uncultivated nonagricultural areas including roadsides, utility right-of-ways, railways, and industrial areas. Comment: Suggested clarifications to "
... container grown ornamentals located in nurseries, ornamental gardens
... " and "
...golfC(JIJ]"se tees, greens, fairways, and roughs
... ".


### BEAD Response: BEAD appreciates the clarification on the container grown ornamental use site ofdithiopyr.

4. Reference: Information ThatMay be Useful for BEAD's Future Work on Dithiopyr: Page 5. Paragraph 1. Documentstates: Obtaining additional information on the current use of dithiopyr in uncultivated non-agricultural and industrial sites would improve future BEAD assessments andmay be required aspart of the registration review of thispesticide. Information needed regarding the current use of dithiopyr on allsites includes the annualpounds of 

### a.i. applied in the U.S., the number of acre treatments, typical application rates (single andyearly), and the number of applications peryear. Comment: DAS wouldcite California Department of Pesticide Regulation use reporting data as supportive to this request. Dithiopyr, as an effectivepre-emergence herbicide, can be a keypart of fire risk mitigation on roadsides and rights of way. This 

### Page 2 of3herbicide, can be a keypart of fire risk mitigation on roadsides andrights of way. This is evidenced by the use of dithiopyr in the state of California. CA DPR has reported increasing usage of dithiopyr in rights of waygrowing from 7785 lbs in 2009 to 11, 732lbs in 2011 [14-16}.
BEAD Response: 

### BEAD appreciates the CA DPR usage data on use ofdithiopyr on**rights~of** 

### way. DAS Comment on Dithiopyr EFED Label Data and HED Master Label Reports: 

### 1. Reference: Spreadsheet, Columns 

### I 

### &N Comment: A single maximum application rate of0.5 lb a. i./acre exists for all DAS registrations containing dithiopyr. Several rows in this document suggest otherwise. For example, Row 67 indicates that the maximum application ratefor Dimension® Ultra SC as 0. 5115 lb/a, while the actual maximum single application rate 0. 2 gallonsper acre, equivalent to 0.5 lb a. i./acre [17]. DAS respectfully requests that risk assessments for DAS registrations areperformed using the maximum application rate of0.5 lb ail acre. References Dimension Ultra SC Product Label. EPA Reg. No. 62719-467 http:// www. epa.gov / pesticides /chem search/ppls /062 719-00467-2002050l
.pdf
BEAD Response: 

### The maximum application rate for the Dimension Ultra SC Product label (62719-467) was calculated in BEAD using a density of9.3 lb per gal. BEAD acknowledges that the DAS method ofcalculation for this label has resulted in a slightly different maximum application rate.
This concludes the comments that BEAD received from DAS on the Dithiopyr Registration Review Docket. BEAD appreciates the feedback from DAS on the label data report and general usage data in the docket.
Sources: 

### C. Doucoure, S. Ratnayake, D. Berwald. 2013. BEAD Chemical Profile for Registration Review: Dithiopyr (128994). Office ofPesticide Programs, U.S. Environmental Protection Agency EFED Label Data Report: Dithiopyr (128994). Office ofPesticide Programs, U.S. Environmental Protection Agency HED Master Label Report: Dithiopyr (128994). Office ofPesticide Programs, U.S. Environmental Protection Agency Page 

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