UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

FROM: 

THRU: 

Jose Gayoso d 

Chemical Review Manager 

Risk Management and Implementation Branch II .-

Pesticide Re-evaluation Division 

Kevin Costello, Branch Chief ~ j ;r-H-/ '5 /t "r /; '-j 

Risk Management and Implementation Br{Jt[o/(fvl/lo 

Pesticide Re-evaluation Division 

TO: Metam and MITC Registration Review Public Dockets (EPA-HQ-OPP-2013-

0140 and EPA-HQ-OPP-2013-0242) 

RE: Responses to Public Comments on the Metam and MITC Preliminary Work Plan 

This memorandum is written in response to comments submitted on the metam and MITC 

registration review preliminary work plan and supporting documents found in dockets EPA-HQOPP-2013-0140 (metam) and EPA-HQ-OPP-2013-0242 (MITC) at www.regulations.gov as well 

as other related public comments. The Agency considered the concerns raised by each of the 28 

comments submitted, but the registration review timeline, data-requirements, and anticipated risk 

assessment needs did not change as a result of these comments, as outlined in the metam and 

MITC final work plan. For responses to comments associated with a fumigant active ingredient 

other than metam or MITC, please see the registration review docket for that chemical, located at 

www.regulations.gov. 

Comments submitted by the FIFRA Endangered Species Task Force (FESTF) in EPA-HQOPP-2013-0140-0014 

1. Comment: FESTF submitted a comment informing the Agency that the technical registrant of 

metam is a member of the FESTF (or a company having met its data compensation 

obligations) and is entitled to rely on FESTF data. 

Response: The Agency thanks FESTF for its comment and will take this under consideration. 

Comments submitted by the American Farm Bureau (AFB) in EPA-HQ-OPP-2013-0140-

0022 and EPA-HQ-OPP-2013-0242-0017 

1 
2

1. Comment: The EPA should base its implementation of FIFRA on credible scientific 

information; test pesticides based on realistic levels of exposure or consumption; consider the 

risks and benefits when determining whether to cancel or restrict pesticides or chemicals used 

in agricultural production; and consider actual use data in the risk assessment process and 

not make decisions based on worst-case assumptions. 

Response: The Agency uses the best available data in making its decisions, which includes 

actual use and usage information, field studies, monitoring data, modeling, and information 

from incidents. The Agency considered both the risks and benefits of soil fumigants during 

the reregistration process, and those decisions were issued in 2008 and amended in 2009. 

During registration review of the soil fumigants, the Agency is looking at what has changed 

since the last assessments, how significant these changes are, if there is a need for any new 

information or studies to conduct the risk assessments, and if the Agency’s regulatory position 

is likely to change as a result of any new information. 

Comments submitted by the Center for Biological Diversity (CBD) in EPA-HQ-OPP-2013-

0140-0023 and EPA-HQ-OPP-2013-0242-0018

1. Comment: Under the Endangered Species Act, it is EPA’s duty to consult with the U.S. Fish and 

Wildlife Service and National Marine Fisheries Service on the reregistration of metam and MITC 

and approval of all metam and MITC end-use product labels. In addition, the EPA must make 

defensible “Not Likely to Adversely Affect” and “Likely to Adversely Affect” determinations 

as a prerequisite for defensible “Jeopardy” and “No Jeopardy” determinations. EPA and the 

services must assess the adverse impacts of metam and MITC in critical habitat.

Response: EPA plans to address many of the concerns raised in the comments from Center 

for Biological Diversity as part of the implementation plan for assessing the risks of pesticides 

to listed species based on the recommendations of the April 2013 National Academy of 

Sciences (NAS) report. EPA will address concerns specific to metam and MITC in connection 

with the development of its registration review decisions for metam and MITC. 

The NAS report, available at http://www.nap.edu/catalog.php?record_id=18344, outlines 

recommendations on specific scientific and technical issues related to the development of 

pesticide risk assessments that are compliant with the Endangered Species Act and the Federal 

Insecticide, Fungicide, and Rodenticide Act. In November, the EPA, along with the U.S. Fish 

& Wildlife Service (USFWS), the National Marine Fisheries Service (NMFS) (collectively, 

the Services), and the U.S. Department of Agriculture (USDA), released a summary of their 

joint Interim Approaches for assessing risks to listed species from pesticides. The Interim 

Approaches were developed in response to the NAS' recommendations and reflect a common 

approach to risk assessment shared by the Agencies as a way of addressing scientific 

differences between EPA and the Services. The joint Interim Approaches were released prior 

to the stakeholder workshop held on November 15, 2013. EPA presented the joint Interim 

Approaches at the December 2013 PPDC and SFIREG meetings, allowing additional 

opportunities for stakeholders to comment on the Interim Approaches. The Agencies will 

consider public comments on the Interim Approaches prior to implementing them. The 

Agencies intend to jointly implement these approaches as part of a phased iterative process. 

EPA will refine its listed species risk assessments based on these interim approaches. The 
3

details of the joint Interim Approaches are contained in the white paper "Interim Approaches 

for National-Level Pesticide Endangered Species Act Assessments Based on the 

Recommendations of the National Academy of Sciences April 2013 Report," dated November 

1, 2013, available at http://www.epa.gov/espp/2013/nas.html.

Regarding the Center for Biological Diversity's request for EPA to begin informal 

consultation with the Services immediately after the workplans for metam and MITC is 

finalized, EPA plans to follow the March 2013 stakeholder engagement paper ("Enhancing 

Stakeholder Input in the Pesticide Registration Review and ESA Consultation Processes and 

Development of Economically and Technologically Feasible Reasonable and Prudent 

Alternatives") to identify the appropriate time for initiation of consultation, either formal or 

informal, with the Services. The stakeholder engagement paper, jointly developed by the 

EPA, USDA, and the Services and available at 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2012-0442-0038, allows for 

early interaction with the Services under informal consultation. EPA and the Services 

acknowledge that early interaction as part of informal consultation may result in refinements 

to EPA's effects determinations that can improve the efficiency of the ESA compliance 

process. For example, EPA may involve the Services at the earliest stages of registration 

review. In general, EPA plans to initiate formal ESA consultation, if necessary, at the final 

decision stage in the registration review process. Consulting later in the process allows the 

EPA to develop more refined ecological risk assessments and to engage stakeholders in 

discussions that should result in more focused consultation packages that may include risk 

mitigation for listed species.

Comments submitted by the North Carolina Department of Agriculture and Consumer 

Services (NCDACS) in EPA-HQ-OPP-2013-0140-0024, the National Potato Council (NPC) 

in EPA-HQ-OPP-0140-0018 and EPA-HQ-OPP-2013-0242-0016, Ratto Bros. Farms in 

EPA-HQ-OPP-2013-0140-0015, United Potato Growers of America in EPA-HQ-OPP-2013-

0140-0030 and EPA-HQ-OPP-2013-0242-0021, Washington State Potato Commission

WSPC) in EPA-HQ-OPP-2013-0140-0017, Responsible Farmers Coalition in EPA-HQOPP-2013-0140-0020, Bolthouse Farms in EPA-HQ-OPP-2013-0140-0021, and Mercer 

Canyons in EPA-HQ-OPP-2013-0140-0031

1. Comment: NCDACS stated the use of soil fumigants plays a critical role in North Carolina’s 

crop production. NHC stated the use of soil fumigants is critical in the Pacific Northwest’s 

deciduous fruit tree industry. NPC stated the use of soil fumigants is indispensable to the 

commercial potato growers in the United States. Ratto Bros. Farms outlined the necessity of 

metam for growing various crops in Modesto, California. United Potato Growers of America 

provided information on the benefits of metam to U.S. potato growers. The WSPC stated that 

metam products are critical tools in production of potatoes and will be conducting a survey of 

growers to gauge impacts of recent mitigation. The Responsible Farmers Coalition provided 

detailed information on the benefits of metam to California carrot production. Bolthouse 

Farms also provided detailed information on the importance of metam to the California 

carrot industry. Mercer Canyons provided information on the importance of metam sodium in 
4

the production of various crops in Washington, as well as expressed concerns over the impact 

of Phase II soil fumigant risk mitigation measures.

Agricultural statistics were submitted in support of these comments.

Response: The Agency appreciates the economic and production information and will take it 

into consideration moving forward in registration review.

2. Comment: NCDACS recognizes the importance of a conservative approach in evaluating 

new pesticides; but since soil fumigants have been registered for decades, they suggested the 

information gained through the experience of using them, the regulations, use directions, and 

training programs that have been developed are effective at mitigating the exposure risks. 

Information regarding inspections and incidents were provided to support the current 

measures are effective.

Response: The soil fumigant mitigation that went into effect in December 2012 as a result of 

the Agency’s reregistration eligibility decisions (REDs) were intended to reduce the risk of 

fumigant exposure to workers and bystanders. Incidents are only one piece of the puzzle in the 

Agency’s risk assessments, so field studies, monitoring data, modeling will also be evaluated 

during registration review, and the Agency’s risk conclusions and mitigation strategies will 

take all of this information into account. In addition, since it has only been a short time since 

the full suite of mitigation measures appeared in labels in the field, the Agency does not 

believe the effect these measures have had on reducing exposure risks can be adequately 

evaluated at this time. 

Comments submitted by the Minor Crop Farmer Alliance (MCFA) in EPA-HQ-OPP-2013-

0140-0025 and EPA-HQ-OPP-2013-0242-0019, and the Florida Fruit and Vegetable 

Association (FFVA) in EPA-HQ-OPP-2013-0140-0026 and EPA-HQ-OPP-2013-0242-0020

1. Comment: The MCFA and FFVA are anticipating the need to move forward with interim 

changes to the most current product labels to address problems that users are experiencing.

Response: The Agency is committed to discussing progress on post-RED label 

implementation whenever questions or issues arise. Please contact the active ingredient 

chemical review manager in the Pesticide Re-evaluation Division who will consult with the 

fumigant review team on the appropriate path forward for any issues with labeling required by 

the RED. For other label changes, please contact the appropriate Product Manager in the 

Registration Division.

2. Comment: The MCFA and FFVA would appreciate periodic updates regarding the progress 

being made, and any information needs that could be supplied by its’ members.

Response: The Agency appreciates the offer for assistance with information, and will keep 

this in mind moving forward in the registration review process. The framework for 

registration review includes milestones such as the final work plans, preliminary risk 
5

assessments, and proposed decisions which will be posted to the chemical docket at 

www.regulations.gov. Information from external meetings on registration review cases will 

also be posted to the docket. For any other updates, please contact the active ingredient 

chemical review manager in the Pesticide Re-evaluation Division.

Comments submitted by the University of Florida (UF) in EPA-HQ-OPP-2013-0140-0029, 

the Minor Crop Farmer Alliance (MCFA) in EPA-HQ-OPP-2013-0140-0025 and EPA-HQOPP-2013-0242-0019, and the Florida Fruit and Vegetable Association (FFVA) in EPAHQ-OPP-2013-0140-0026 and EPA-HQ-OPP-2013-0242-0020

1. Comment: UF is concerned about further increases in regulatory costs’, or the loss of 

chemical fumigants’, impact on the fruit and vegetable industries of Florida and other support 

industries. A summary of some UF fumigant research was provided. FFVA and MCFA 

provided similar comments and FFVA endorsed those submitted by UF.

Response: During the RED process EPA used field studies, monitoring data, modeling, and 

information from incidents to support a conclusion that these fumigants off-gas and move 

away from treated fields at concentrations that have the potential to cause adverse effects. The 

RED mitigation was developed to reduce these risks. EPA also completed numerous 

assessments looking at the benefits and alternatives available for a number of fumigated 

commodities. Using all of this information, the Agency worked with stakeholders to make 

changes in the way soil fumigants were applied to protect bystanders while striving to 

maintain the important benefits of soil fumigants. 

During registration review of the soil fumigants, the Agency is looking at what has changed 

since the last risk assessments. While this includes a review of new data and policies, it also 

includes updated use and usage information, incident data, and benefits information. This will 

include information from the time-period following the implementation of the RED 

mitigation. EPA thanks UF for the information on the ongoing fumigant research and plans to 

consider this information as we move through the registration review process.

Comments submitted by California Tomato Research Institute (CTRI), Inc. in EPA-HQOPP-2013-0140-0019

1. Comment: A detailed description was provided of the way metam is used to fumigate 

tomatoes in California, consisting of precise field preparation, spray blade metam application, 

followed by an additional layer of soil. CTRI stated that understanding this unique method is 

important in re-evaluation of metam soil fumigant risks. CTRI believes their method for applying 

metam to the soil effectively keeps the fumigant in the ground and prevents volatilization. CTRI 

request that EPA review California Department of Food and Agriculture (CDFA) data that 

confirms low volatilization of this method and that EPA coordinate with California Department 

of Pesticide Regulation (CDPR) in reviewing this application method. 

Response: The Agency thanks CTRI and California tomato growers for the information 

provided in this comment period and those during the re-registration process. The buffer zones 

for metam spray blade applications are based on spray boom/rotary tiller/flatroller emission 
6

study data prepared by CDPR, California Air Resources Board, and CDFA. The emissions, and 

therefore buffer zones, for rotary tiller and spray blade application methods are among the lowest 

of all the application methods for metam products. As during the re-registration process, the 

Agency will coordinate with CDPR as appropriate in re-evaluation of the fumigants.

2. Comment: CTRI requests that spray blade application regulations be kept separate from 

shank application regulations to reduce confusion to growers and California agricultural 

commissioners.

Response: Current metam soil fumigant product labels distinguish between spray blade and 

shank directions and requirements. There are also separate buffer zone tables for the spray blade 

and shank application methods.

Comments submitted by Washington Friends of Farms & Forests in EPA-HQ-OPP-2013-

0242-0014 and Washington State Potato Commission in EPA-HQ-OPP-2013-0242-0015

1. Comment: The 60-day public comment period on the fumigant registration review 

Preliminary Work Plans should be extended because the comment period is taking place during 

a particularly demanding time of the season for growers. Also, growers have not had enough 

experience with the phase 2 soil fumigant label amendments in order to comment on their 

impact.

Response: The Agency did not extend the public day comment period because the primary 

intent was to seek comment on the Preliminary Work Plans and supporting documents that 

outline the anticipated risk assessments and data needs. These documents contain information to 

assist the public in understanding the types of information and issues that may be considered 

during the course of registration reviews. During the comment period, the Agency was seeking 

comments on these documents and information on use parameters. The Agency is interested on 

hearing from the stakeholders about the impacts of recent mitigation and such comments can be 

submitted during or outside of the comment periods. The Agency will continue the dialogue with 

stakeholders on issues associated with recent mitigation that resulted from the previous reevaluation of the soil fumigants.

Comments submitted by Stanley Culpepper, University of Georgia in EPA-HQ-OPP-2013-

0140-0016

1. Comment: Dr. Culpepper provided detailed information to highlight the importance of 

metam as a component of the University of Georgia 3-way method (metam, 1,3-dichloropropene, 

and chloropicrin) that has proven to be an effective alternative to methyl bromide in the 

Southeast. Detailed information on crop value of using this method was provided. A UGA 3-way 

study was included which contains data on effectiveness on weeds and benefits to crop quality 

and yield. Dr. Culpepper requested that EPA continue to work with Cooperative Extensions in 

the re-evaluation of metam to ensure the safe use of the products while avoiding overly 

burdensome regulations.
7

Response: The Agency appreciates the information and data provided by Dr. Culpepper and will 

consider them during the registration review of metam. 

Comments submitted by Agrinorthwest in EPA-HQ-OPP-2013-0140-0032

1. Comment: Private applicators without state certification should be allowed to handle and 

monitor metam sodium applications.

Response: As a result of the RED, metam soil fumigant products are now classified as 

Restricted Use Pesticides and can only be bought and used by state-licensed certified applicators, 

or those under their supervision. Private applicators who wish to buy and use metam soil 

fumigant products must be state certified. The reason for this change was that the MITC 

generated from the use of metam soil fumigant products meet the criteria for restricted use due to 

the potential for significant hazard to human health. In addition, there is a history of metam 

sodium incidents caused by user error that have resulted in exposure and adverse effects to large 

numbers of bystanders. State certification programs ensure that applicators are aware of best 

practices for handling these hazardous pesticides. 

2. Comment: The requirement for monitoring metam sodium chemigation applications should 

be changed from every 2 hours to every 3 hours.

Response: The certified applicator in charge of a metam soil fumigant application through

chemigation is allowed to leave the application block after the fumigant application has been 

initiated, but must return periodically to visually inspect the application to make sure the 

equipment is working properly and to check for fumes. For other types of applications, the 

certified applicator is required to remain on site throughout the entire application in order to 

ensure if problems arise, they are able to be addressed promptly. However, after taking public 

comment on the proposed mitigation in 2008, the Agency concluded that monitoring every 2 

hours would address the need for flexibility for chemigation applications, which can occur over 

many hours, while still addressing the need to visually monitor the application to address any 

potential problems that could result in occupational and bystander exposure. Since it has only 

been a short time since the full suite of mitigation measures appeared on labels in the field, it 

may be too soon to evaluate the effects of this requirement. If this is a significant burden to 

applicators, EPA can reevaluate this requirement in registration review if an adequate alternative 

is provided. 

3. Comment: My buffer zone is too large. Applying metam sodium to over 125 acres results in a 

buffer zone over 500 feet.

Response: The buffer zones for metam soil fumigant applications are based on field volatility 

studies that measured the rate of fumigant emissions for different application methods. Some 

application methods resulted in higher rates of emissions than others. Based on the data, the 

buffer zones, along with other mitigation measures required by the label, provide a distance 

where fumigant emissions are not expected to lead to unreasonable adverse effects to bystanders. 

If an applicator feels that the buffer zone for their application is too large, there are several 

options to reduce the buffer zone. He can use a lower application rate, divide the application 
8

block into smaller application block sizes, or use a different application method. Also, for 

applications that can be tarped, some tarps are eligible for buffer zone reduction credits. For 

more information, please see the buffer zone section of EPA’s Soil Fumigant Toolbox website, 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/index.htm.

4. Comment: The buffer zone period of 48 hours after the application is complete is too large. 

24 hours would be sufficient.

Response: Field volatility data on soil fumigants suggest that it can take up to 48 hours for 

fumigant emissions to dissipate. Therefore, to minimize the potential for exposure to fumigant 

gases, only handlers with appropriate personal protective equipment are allowed within the 

buffer zone during the application and 48 hours afterward.

5. Comment: Enclosed cabs should be allowed in the buffer zone. 

Response: EPA has not prohibited the use of enclosed cabs in the buffer zone. In fact, if an 

applicator uses an enclosed cab, less dermal personal protective equipment (PPE) is required. 

However, since there is no way to ensure a closed cab offers the same level of respiratory 

protection as a respirator, the respiratory protection and stop-work triggers required for all other 

applications must still be followed even when an applicator is using an enclosed cab.

Comments submitted by Randy Quigley, Idaho in EPA-HQ-OPP-2013-0140-0013

1. Comment: The difference in removal time requirements of the Fumigant Treated Area (T.A.)

sign and the Buffer Zone (B.Z.) sign may cause compliance problems. For some applications, the 

minimum time allowed for T.A. sign removal (120 hours) occurs at the same exact time as the 

maximum time allowed for removal of the B.Z. sign (120 hours). For commercial applicators 

that fumigate multiple fields on the same day, the applicator would prefer to remove all the signs 

for all the fields on the same trip. However, the minimum time to remove the T.A. signs can vary 

by several hours between fields. Therefore, the applicator would have to remove the signs from 

the first field, wait several hours, and then remove the signs from the second field, and so forth. 

Applicators need 12-24 hours to remove all signs from all fields on one trip without being in 

violation of the requirements. An additional day should be added to the B.Z. removal time or a 

day should be removed from the minimum T.A. removal time in order to remain complaint and 

efficient in application operations, especially when applying to multiple fields over an extended 

period of time.

Response: The Agency appreciates the comment and will take the proposed sign removal 

timeframe change into consideration during the registration review process. Please note that the 

T.A. sign removal timeframe is consistent with Worker Protection Standard (WPS) requirements.

Please also note that metam labels allow for an exception to posting BZ signs. If multiple 

contiguous application blocks are fumigated within a 14 day period, the entire periphery of the 

contiguous block’s buffer zones may be posted. This situation may apply to multiple field 

applications and would alleviate the problem of removing BZ signs from multiple nearby fields.
9

Comments submitted by Robert Spencer, Idaho State Department of Agriculture (ISDA), 

Division of Agricultural Resources in EPA-HQ-OPP-2013-0140-0027

1. Comment: ISDA provided information on the importance of metam products in the 

production of various crops in Idaho. ISDA recommends that a regional metam label be created 

to address Pacific Northwest growing conditions. Other recommendations were made to simplify 

metam labels, which are now more complex as a result of Phase 2 mitigation.

Response: The Agency appreciates the recommendations on metam labels and will take them 

into consideration during the registration review of metam. The Agency agrees that the clarity of 

metam labels could be improved. Since it is unclear if and when the Agency would require 

additional changes to metam soil fumigant product labels, ISDA may consider reaching out to 

metam registrants to request a Pacific Northwest specific metam product label. Registrants are 

free to request amendments and improve the clarity of their labels at any time.

2. Comment: The Phase I label requirements alleviated the majority of the complaints involving 

soil fumigants. If applicators and growers follow the Good Agricultural Practices that are listed 

in the Phase I labels, it has been Idaho’s experience that there is no need for the large buffer 

zones. EPA should reconsider the need for implementation of Phase II label requirements. If 

Phase I labels do not take care of the problems, then EPA can implement Phase II label 

requirements for the next registration review period.

Response: In the previous re-evaluation process, reregistration, the Agency made the decision 

that continued registrations of metam products would not adversely affect human health or the 

environment, as long as the full suite of risk mitigation measures were put in place. The suite of 

mitigation measures included both Phase I and II. The Agency decided that Phase II mitigation, 

such as buffer zones, are necessary to meet the Agency’s required safety standards. During 

registration review of the soil fumigants, the Agency is looking at what has changed since the 

last assessments, how significant these changes are, and will determine if the Agency’s 

regulatory position is likely to change as a result of any new information that may alter the RED 

mitigation.

3. Comment: ISDA proposed alternatives to various risk mitigation measures required by 

current metam labels.

Response: The risk mitigation measures included on current metam labels are the result of 

years-long development and coordination with stakeholders, including state lead agencies, 

growers, and pesticide registrants. Any change to the final version of mitigation measures, which 

are now on metam soil fumigant product labels, would require a significant review process to 

ensure the changes are feasible while still maintaining the same safety standard. The Agency 

appreciates your comments and recommendations and will take them under consideration during 

the registration review process.

4. Comment: ISDA encourages EPA to look at wind speed as an option for giving buffer zone 

credits for all applications. EPA already requires applicators to observe weather forecasts prior, 

during and after the soil fumigant application. Odors from off-gassing of soil fumigants do not 
10

present a major problem when wind is present. The majority of the issues occur during calm or 

inversion type conditions. Also, EPA should allow buffer zones for all ground (shank, bedded, 

rototilled, etc.) applications to be 25 feet when followed by 1⁄4 inch of irrigation. This 25 foot 

buffer zone should not be limited only for broadcast applications.

Response: For responses to these comments, please see RESPONSE TO COMMENTS. The 

Health Effects Division’s Response to the Idaho State Department of Agriculture on the Metam 

Sodium, Metam Potassium, Methyl Isothiocyanate Registration Review Scoping Document for 

Human Risk Assessment, dated February 18, 2014, available in the metam registration review 

docket, EPA-HQ-2013-0140.

5. Comment: EPA has reduced buffer zones for chemigation systems that have drizzle boom 

(Smart Drop®) or solid stream adaptations. ISDA has been informed that due to the numerous 

different types of irrigation systems utilized in Idaho, growers do not have the capabilities to 

adapt to this technology. This technology is feasible for use in Washington State where irrigation 

systems are very similar, but may not be for other states. EPA should allow reduction in buffer 

zones for new technologies for chemigation systems as they are developed.

Response: Metam labels do allow for new technologies to take advantage of the reduced buffer 

zones for center pivot and lateral move applications. The label sets a performance standard and 

provides Smart Drop® as an example. As long as new technologies meet the following criteria, 

then they can qualify to use the “low release/solid stream” buffer zone table on metam labels: 1) 

release height AND spray height is less than 4 feet, AND 2) 29lbs. or less PSI at the sprinkler 

head, AND 3) application system produces a solid stream (e.g. drizzle boom/Smart Drop®), 

AND 4) there are no end guns.

6. Comment: When issuing changes in labeling, EPA and registrants need to figure a better way 

to get the information out to the end user when dealing with bulk fumigants. When EPA 

approved the reduced buffer zones for bedded application for metam sodium, it was a fiasco for 

Idaho.

Response: The approval of metam products with reduced bedded application buffer zones was 

staggered because EPA received the label amendment request from the different registrants at 

different times. In the future, the EPA will make every effort to notify states and end users of 

significant changes to soil fumigant labels. However, the registrants also bear a responsibility to 

notify their customers and states of upcoming changes that they are requesting for their products. 

The reduction of metam bedded application buffer zones was the result of a request from metam 

registrants, not an Agency-initiated action.

Comments submitted by the Metam Task Force in EPA-HQ-OPP-2013-0140-0028

1. Comment: The Metam Task Force will address issues related to data requirements, postRED implementation, and anticipated human health and environmental fate and effects 

assessments at a later time.
11

Response: The Agency appreciates the Metam Task Force’s notice of forthcoming materials. 

The Agency is available to discuss any questions or concerns regarding these items as they 

arise. The preliminary work plan, scoping document, and problem formulation outline the 

Agency’s intention for requiring data and conducting risk assessments in registration review. 

The registration review framework provides ample opportunity for registrants, growers, and 

other stakeholders to have their comments evaluated prior to the Agency requesting data and 

beginning work on the risk assessments. The data call-in is typically sent to registrants 

shortly after the issuance of the final work plan, and the clock for study submission begins at 

that time. Barring unforeseen complexities, the Agency will maintain the registration review 

timeframe as listed in the final work plan.

For additional comments and responses from the Metam Task Force, please see EFED Response 

to Metam Task Force Comments to Data Call-In and Problem Formulation on the Registration 

Review of Metam Sodium, Metam Potassium and Methyl Isothiocyanate (MITC) (DP Barcode: 

D416688), dated February 10, 2014, available in the metam registration review docket, EPAHQ-2013-0140.