# Notes from Imazalil All

- Registrant Focus Meeting
Wednesday, October 23 th 

## at 9

- 10am (Eastern Time) Location: Potomac Yards South, Rm. 9100

Color code : Black = included in the meeting agenda Purple = things stated during the meeting itself Red = outstanding action items

Purpose of Meeting:

The upcoming focus meeting is intended as an opportunity for the EPA science divisions to ask registrants use/usage related

- questions that will help refine the problem formulation and scoping document, also to be published publically in December. The final content of those two science documents will feed into the final draft of the preliminary work plan.

EPA Attendees :

AD: Sharon Carlisle, Timothy Dole

, Tim McMahon, Sandra O ’ Neill , Laura Parsons, Marshall Swind ell
BEAD: Tara Chandgoyal, Cynthia Doucoure, Andrew Lee
, Arnet (Skee) Jones
EFED: Brian Anderson, Christine Hartless, RDavid Jones, Paul Mastradone
HED: Jaime D ’ Agostino, Zaida F igueroa, Dennis McNeilly, Karlyn Middleton, Christina Swartz, Jess Rowland PRD: Cathryn Britton, Kevin Costello , Meg Hathaway (Chemical Review Manager) RD: Cynthia Giles

- Parker, Tony Kish

Registrants (All Calling In) :

Certis Europe Marie Spirlet
Janssen PMF Bill Goodwine
M akhteshim Chemical Works Ltd Jonathan Janis

Agenda:

I. Introductions

II. Upcoming regulatory m ilestones

a. December 2013 = D ocket opening & Preliminary Work Plan (PWP) publication
b. February 2014 = C lose of public comment period on Imazalil PWP

c. May 2014 = Final Work Plan (FWP) publishes

III. Brief r eview of type of data supplied thus far by registrants

a. Sales data [ general discussion only

- CBI ]
b. EFED/HED studiesc. Dietary assessment by Janssen
i. Has been supplied by registrant but not yet reviewed by HED.

IV. Discussion of EPA s cience team c oncerns

a. Egg hatchery use
i. Question relating to handler process and potential inhalation risks: What type of equipment is used in hatcheries for imazalil application, an automatic or a handheld fogger?
1. Janssen PMF says they will answer this question.
b. Seed treatment use
i. Is imazalil still being used for seed treatment use (e.g. for barley or wheat)? EPA data indicates low average usage from 2009

- 2011.
1. Certis Europe says seed treatment uses occur for imazalil in both Europe and the United States. In the case of the US, Ce rtis sell’s the technical product to a formulator in the US.

c. P ostharvest use on citrus
i. Process questions
1. Describe how wash water is managed.

a. Janssen PMF and Makhteshim both say they will address this question.
b. Makhteshim notes that there is a diff erence between wash water and treating solution. Notably, treating solution is recycled back into its storage tank, thereby minimizing environmental exposure.
2. Is imazalil used as a postharvest treatment on fresh market citrus only, citrus fruits used for juicin g only, or both fresh market & juicing citrus?

a. If both, what % of citr us treated is processed citrus? Data for juicing in particular would be helpful.
i. Janssen and Makhteshim confirm that only fresh market citrus is treated, not citrus used for juicing/pro cessing.
1. However, some fresh fruit is treated and then diverted back for juicing when it is culled for
cosmetic defects. Janssen says they will provide
an estimate for what % of treated fruit is culled and used for jucing

. ii. Janssen PMF notes that the citru s market share for processed citrus is far greater than the market for fresh
citrus.
3. Labeling ambiguity: Current labels permit two treatments.

a. HED requests clarification on what treatments are included in a postharvest context. For example, a before and a fter long

- termstorage treatment, a dip and then a wax befor e treatment, or something else?
i. Janssen says there are 2 possibilities: the first is a is a dip wash (treatment 1) followed by a rinsing spray (no treatment, just a rinse), then being coated in a fungicide

- impregnated wax (treatment 2). The other possible scenario is of a pre

- and then post

- storage treatment. Janssen notes that the “dip then wax” scenario is the one in which the fruit’s exposure to imazalil is highest, and should be considered the “worst

case scenario” for risk management purposes.
ii. EPA

- BEAD asks if there is any circumstance in which fruit would receive a third treatment, such as after long

term storage.
1. Janssen PMF answers: no. No third treatment is allowed. If fruit is brought out from long

- term storage, the processing plants will reopen boxes and throw out bad fruit, but not retreat the remaining good fruit.
iii. EPA asks whet her the “no third treatment rule” applies to all types of citrus in addition to oranges.
iv. Janssen PMF notes that facilities try to use different fungicidal chemicals for each of the two treatments.
b. Also, what is the required/allowed time interval between
treatments?
i. If it’s not an immediate double

- treatment scenario, such as a wash then wax, in the case of lemons there may be 3

- 6 months between pre

- and post

- storage

treatments.
ii. Gaps in Sales Data provided
1. What volume of imazalil is used on citrus ?

a. Janssen PMF will supply data

. b. The information provided so far by the registr ants gives only the
amount of AI sold in pounds

.
c. Imazalil is not a typical field crop with a specific use in pounds

per acre. The active ingredient is put in spray solutio n and used

. H ow much ci trus is treated for a given solution (i.e. volume AI and dilution factor data) ?
i. Janssen PMF indicates that 2g ai is used to treat one ton
of fruit. They indicate that this amount of ai is for both treatments combined (e.g. a wash and a wax)

. They will
check with end

- use registrants to clarify how this worksin practice. For example, Janssen will check whether the amount of ai used could double to 4 g ai/ton in the case of lemons receiving a pre

- and post

- storage

treatment

. d. Janssen PMF notes that t here is an overall market trend of declining imazalil use. This is due to the recent registration of 4

- 5 other fungicides. While imazalil has historically been the “workhorse” of agricultural fungicides, other fungicides are now replacing imazalil in var ious contexts.

e. EPA discusses the feasibility of bridging PDP data on oranges to
lemons or other citrus. It is noted th at field trial residue studies find high q* values.
2. Of AI used on citrus, how much r emains after treatment (residues )?

a. Janssen PMF will c heck their residue files . They also refer EPA to the available PDP data. EPA responds that due to the limitations of the PDP data, information on lemons would be especially helpful.
b. Janssen PMF notes that residues are desirable in the case of

pre

- storage treatments because they increase the shelf life of
citrus.

c. EPA

- RD asks whether all fresh market citrus is treated in some way (even if not treated with imazalil specifically. Janssen PMF replies that unless the fruit is organic, the answer is yes.
d. Other Concern s ?

V. Questions from the Registrants

VI. Conclusion (Next Steps/Repetition of Action Items)

a. Scheduling follow

- up meeting with Janssen PMF to discuss cancer risk concerns.
i. EPA

- PRD schedules a meeting for Nov. 6, 2013.
ii. EPA

- AD notes that the sales volume of imazalil products used for antimicrobial purposes is low enough that cancer is not a major concern for AD’s risk

assessment. b. Other items as discussed in today’s meeting