UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

JUL 11 2013 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

TO: 

Responses to Public Comments Submitted by Syngenta Crop Protection, LLC. 

Concerning the Registration Review ofPrometryn (PC Code 080805) from EPA 

Docket ID No. : EPA-HQ-OPP-2013-0032 < 

Jihad Alsadek, PhD, Economist ~ /1--= J!t~ Science Information and Analysis Branch 

Diann Sims, Chief hLI41At/ ~ J> .. ~tyt/.1-' Science Information 'UA;;~;sis Branch 

Christina Scheltema, Chemical Review Manager 

Risk Management and Implementation Branch 4 

Pesticide Re-evaluation Division (7508P) 

PRP Review Panel Date: July 9, 2013 

Through this memo, BEAD is responding to comments submitted by Syngenta Crop Protection, 

LLC concerning the registration review of Prometryn. 

Syngenta Comment 1: 

PRD Label Data Report: Food/Feed & Non-Food/Non-Feed Uses Considered in 

Registration Review Work Planning (EPA-HQ-OPP-2013-0032-0005) 

"The formulation type for the product Caparol4L is a Suspension Concentrate (SC). We believe 

that Caparol4L has been listed as an Emulsifiable Concentrate (EC), and that this should be 

updated in the PRD Label Data Report." 

BEAD Response: BEAD agrees that the Caparol4L product is a Suspension Concentrate. We 

have now identified the Syngenta registration as a flowable concentrate. The PRD Label Data 

Report has been updated (July 3, 2013). 

Syngenta Comment 1 Continued- "We also believe that the changes bolded in the table below 

should be made based on the Caparol4L label." 

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Syngenta Table 

Form. A.l. Max Max# A.l. Max Max# A.l. Max PGI/ PHI 

Des c. App Ap/CC App ApNr App I PSI 

Use Site Rate/App Rate/CC RateNr 

F Carrot sc 2lb/A 3 4lb/A NS NS H01(30) 

F Celeriac sc 2.0 lb/A NS 2.0 lb/A NS NS H01(60) 

F Coriander sc 1.61b/A NS 1.6 lb/A NS NS H01(30) 

Cotton sc 2.81b/A NS NS NS 5.951b/A NS F (unspecified) 

Leafy sc 2.0 lb/A NS NS NS NS H01(40) F Vegetables 

F Okra sc 1.5lb/A 2 1.51b/A NS NS H01_(_14) 

F Parsley sc 2lb/A NS NS 3 NS H01(30) 

BEAD Response: As noted in the header of all PRD Label Data Reports, this report contains 

aggregated label data and represents label data from all prometryn registrations. See BEAD's 

responses below for each bolded annotation in the Syngenta table: 

Carrots, Celeriac and Okra 

BEAD agrees that the information provided by Syngenta for carrots, celeriac and okra reflects 

the label use information for Caparol 4 L. However the data reflected in the PRD Label Data 

report are aggregated and not specific to this product. No change to the PRD Label Data Report 

is needed as a result of these suggested modifications. 

Coriander 

BEAD agrees that the a.i. maximum application rate per crop cycle of 1.6 lbs. a.i. /a of Caparol 

4L for coriander is correct. The PRD Label Data Report has been updated to reflect this rate. 

Cotton 

BEAD agrees that the a.i. maximum application rate per application is 2.8 lbs. a.i. I a. This rate 

is represented in the PRD Label Data Report. BEAD also agrees with the 5.95 lbs. a.i. I a max 

app rate per year. The PRD Label Data Report aggregates label data based on the highest single 

maximum application rate, not on the highest maximum application rate per year. No change to 

the PRD Label Data Report is needed as a result of these suggested modifications. 

Leafy Vegetables 

BEAD agrees with Syngenta regarding the a.i. maximum application rate per application of 2.0 

lbs. a.i. I a. This rate is represented on the PRD Label Data Report and reported under the celery 

use site. The 40 days pre-harvest interval reflects a non-Syngenta registration. No changes to 

the PRD Label Data Report are needed as a result of Syngenta suggested modifications. 

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Sources: 

PRD Label Data Report on Prometryn (080805), EFED Label Data Report on Prometryn 

(080805) 

Syngenta Crop Protection, LLC. Comments Submitted by Syngenta Crop Protection, LLC. 

Concerning the Registration Review ofPrometryn (PC Code 080805) from EPA Docket ID No.: 

EPA-HQ-OPP-2013-0032, May 28,2013 

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