UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D

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OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION FROM:

THRU: Jose Gayoso 

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Chemical Review Manager Risk Management and Implementation Branch II .- Pesticide Re-evaluation Division Kevin Costello, Branch Chief

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# 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

12 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 issue d in 2008 and amended in 2 009. 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 th e Agency’s regulatory position is likely to change as a result of any new information. C omments 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 “No t 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 Natio nal Academy of Sciences (NAS) report

. EPA will address concerns specific to metam and MITC in connection with the development of its registration review decision s 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 Fed eral 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 present ed the joint Interim Approaches at the December 2013 PPDC and SFIREG m eetings, 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

. The3 details of the joint Interim Approaches are contained in the white paper "Interim Approaches for National

- Level Pesticide Endang ered 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 th e Center for Biological Diversity's request for EPA to begin informal consultation with the Services immediately after the workplan s for metam and MITC is finalized, EPA plans to follow the March 2013 stakeholder engagement paper ("Enhancing Stakeholder In put 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 inf ormal, with the Services

. The stakeholder engagement paper, jointly developed by the EPA, USDA, and the Services and available at http://www.regulations.gov/#!docume ntDetail;D=EPA

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- 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 dec ision 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 i nclude 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 - H Q OPP - 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 t he use of soil fumigants plays a critical role in Nor th 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 import ance of metam to the California carrot industry. Mercer Canyons provided information on the importance of metam sodium in4 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: NCDA C S 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 t raining 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 expos ure 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 Allianc e (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 - 002 6 and EPA - HQ - OPP - 2013 - 0242 - 0020 1

. Comment: The MCFA and FFVA are anticipating the need to move forwar d 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 appreciat es 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 risk5 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 m anager 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 - 00 25 and EPA - HQ OPP - 2013 - 0242 - 0019, and the Florida Fruit and Vegetable Association (FFVA) in EPA HQ - OPP - 2013 - 0140 - 002 6 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 veget able 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 d eveloped 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 benefi ts of soil fumigants. During registration review of the soil fumigants, the Agency is looking at what has changed si nce the last risk assessments. While this includes a review of new data and policies, it a lso 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. Comment s submitted by California Tomato Research Institute (CTRI) , In c. in EPA - HQ OPP - 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 understan ding 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 metho d 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 emission6 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

- regis tration 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 m ethods. 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 co mment 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 assessment s and data needs. T hese 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 stakeho lders on issues associated with recent mitigation that resulted from the previous re

evaluation of the soil fumigants. Comment s submitted by Stanl e y Culpepper, University of Georgia in EPA - HQ - OPP - 2013 - 0140 - 0016 1. Comment: Dr. Culpepper provided detail ed 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 Ex tensions 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, m etam 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 sign ificant hazard to human health. In addition, t here 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 hazardou s 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 applica tions, 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, a fter taking public comment on the proposed mitigation in 2008, t he Agen cy concluded t hat monitoring every 2 hours would address the need for flexibility for chemigation applications, which can occur over ma ny hours, while still addressing the need to visual ly monitor the application to address any potential problems that coul d result in occupational and bystander exposure. S ince it has only been a short time since the full suite of mitigation measures appeared o n 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. Respon se: 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. Bas ed 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 fo r their application is too large, there are several options to reduce the buffer zone. He can use a lower application rate, divide the application8 block into smaller application block sizes, or use a different application method. Also, for applications tha t 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 bu ffer 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 o ffers 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.

Comment s 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 f or 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, t he applicator would prefer to remove all the sig ns for all the fields on the same trip . However, the minimum time to remove the T.A. sign s 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 sign s 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. A n additional day should be added to the B.Z. removal time or a day should be removed from t he 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 c omplex 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 impr oved. 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. R egistrants are free t o request amendments and improve the clarity of their labels at any time

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. 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, th en 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 Ag ency 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, includ ing 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 st ill 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 givin g 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 not10 present a major problem when wind is present. T he 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

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- 0140. 5. Comment: EPA has reduced buffer zones for chemigation systems that have drizzl e 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 techno logies 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 qualif y 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 D rop®), 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 upcomin g 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

- i n itiated action. Comments submitted by the Metam Task For ce in EPA - HQ - OPP - 201 3 - 0140 - 0028 1

. Comment: The Metam Task Force will address issues related to data requirements, post

RED 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 b eginning 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 t he 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 Isothiocyan ate (MITC) (DP Barcode: D416688) , dated February 10, 2014, available in the metam registration review docket, EPA

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