UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

JUL S 9. 2013 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

TO: 

Response to Public Comments by BASF Concerning the Registration Review of 

Dimethomorph (PC Code 268800) from EPA Docket ID No. EPA-HQ-OPP2013-0045, DP Barco e #4131 7 'J· . L I tA.." Q Rafael A Prieto, Efvrr ent Prot~cf.d Specialist Science Information :Analysis Branch 

Diann Sims, Chief ,(),~ Science Information and Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Monica Wait, Chemical Review Manager 

Risk Management and Implementation Branch 3 

Pesticide Re-evaluation Division (7508P) 

PRP Review Panel Date: 24 July 2013 

Through this memo, BEAD is responding to comments submitted by BASF on May 24,2013 

concerning the registration review of Dimethomorph. 

BASF Comment 1 (pp.16-17): 

"Revised Label Data Report for Forum® Fungicide, EPA Reg. No. 241-427, and 

Stature® SC Fungicide, EPA Reg. No. 241-428." 

BEAD Response to Comment 1: BEAD agrees that the Revised Label Data Reports for 

Forum® and Stature® include the BASF registrations. As noted on the PRD Label Data Report 

(BEAD, 2012a), the report is " ... an aggregate report of registered uses for dimethomorph. Label 

data for chemicals with more than one pesticide product are presented in aggregate form (i.e., 

each line of data may be a combination of data from one or more pesticide)." No changes to the 

PRD Label report are required. 

BASF Comment 2 (p. 18): 

"Label Data Report- Duplicate Entries 

The following entries in the Label Data Report appear to BASF to be duplicates. The A. I 

MaxApp Rate/App (lb aila) appears to be rounded from 0.3992 to 0.4. We believe EPA 

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would like to use the most accurate numbers, so we are using the 0.3992 lb ai/a data. 

BASF would like to note that the following table entries can be removed. " 

BEAD Response to Comment 2: The entries noted by BASF are not duplicate entries. These 

data rows result from different registrations: 241-428 (0.3992lb), and 241-419 (0.4lb). No 

changes to the PRD Label Data Report are required. 

BASF Comment 3 (p. 19): "Label Data Report- Formulations Containing Mancozeb and in 

the Process of Cancellation 

The information in the following section of the Label Data Report applies to the end use products 

containing dimethomorph and mancozeb listed below. As noted previously, BASF is in the 

process of voluntarily cancelling these registrations and therefore is not supporting these uses 

through registration review. As such, BASF would like to note that the following table entries can 

be removed. " 

EPA Re,g. No. 

241-383 

241-395 

241-411 

Tradename 

Acrobat® MZ.fun!(icide 

Acrobat® MZ WDG.fun!(icide 

Stature® MZfungicide 

Formulation Type 

Wettable Powder 

Water Dispersible Granules 

Wettable Powder 

BEAD Response to Comment 3: BEAD appreciates the information regarding pending 

cancellations. The PRD Label Data Report is designed to reflect current active registrations as of 

the date of the report. As appropriate, BEAD will update the report when the noted cancellations 

become effective. 

BASF Comment 4 (p. 25): Dimethomorph (268800) Screening Level Usage Analysis 

(SLUA) 

"BASF interprets "Percent Crop Treated" as follows: out of the total acres grown in US fora 

specific crop, the percent crop treated reflects how many of those acres are treated with 

dimethomorph. As such, BASF has the following comments: 

Based on data from Doane Market Analysis 2012, BASF notes the following estimates of 

agricultural uses of dimethomorph:" 

Percent Crop 

Crop LBSAI T· .3 

Avera!le Maximum 

Cabbal!e <500 5 10 

Cucumbers <500 5 10 

Grapes Wine <500 <1 <2.5 

Lettuce 24600 25 40 

Onions 3,400 5 10 

Pevvers <500 <2.5 5 

Potatoes 600 <2.5 5 

Pumpkins <500 5 10 

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Squash <500 5 10 

Tobacco <500 5 10 

Tomatoes 4200 5 10 

Watermelons <500 <1 <2.5 

BEAD Response to Comment 4: BEAD appreciates the more recent information. We note that 

data from 2012 is largely within the rounding process of the Screening-level Usage Analysis 

(SLUA). The SLUA presents merged, averaged, and rounded usage data from multiple sources 

across an eight-year span (2003-2010) (BEAD, 2012b) and the data presented reflect usage for 

the reported timeframe. OPP will consider the BASF information as the Registration Review of 

dimethomorph continues. No changes are needed as a result of this comment. 

BASF Comment 5 (p. 26): BEAD Chemical Profile for Registration Review: 

Dimethomorph (268800) 

"BASF has the following comments as they relate to the BEAD Chemical Profile document. 

D EPA Statement: Page 2, paragraph 3: 'Dimethomorph is formulated as 

dispersible granules, wettable powder, and emulsifiable and soluble concentrate. ' 

o BASF Response: BASF has dimethomorph end-use products registered as 

suspension concentrate, water dispersible granule, and wettable powder 

formulations only. There are no emulsifiable concentrates registered for 

dimethomorph. BASF intends to voluntarily cancel registration of the wettable 

powder formulations by second quarter 2014." 

BEAD Response to Comment 5: BEAD agrees that there are no emulsifiable concentrates for 

dimethomorph and will update the BEAD Chemical Profile to reflect this. The PRD Label Data 

Report will also be revised to reflect the flowable concentrate formulation for BASF' s 

registrations 241-427 and 421-428. 

BASF Comment 6 (p. 26): 

"EPA Statement: Page 2, paragraph 4, Agricultural Use Sites: ' ... registeredfor use on lettuce, 

onions, tobacco, potatoes, cucurbits (e.g., pumpkins, cucumbers, squash, cantaloupes, 

watermelons), spinach, cabbage, peppers, and tomatoes.' 

o BASF Response: BASF would like to note that this list is not inclusive of the 

registered agricultural uses on the most recently approved EPA stamped Forum label 

because the leafy vegetables group, which replaces lettuce, is not listed. The complete 

list of crop uses registered for dimethomorph is as follows: 

Bras sica leafy vegetables, bulb vegetables, cucurbit vegetables, fruiting vegetables, 

ginseng, grapes, hops, leafy vegetables group, lima beans, potatoes, taro, tobacco, fieldgrown tomatoes, and turnip greens. " 

BEAD Response to Comment 6: BEAD acknowledges BASF' s input on specific sites on their 

labels. BEAD will update the agricultural site list to include leafy vegetables and remove 

lettuce. 

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BASF Comment 7 (p. 26): 

"EPA Statement: Page 2, paragraph 5, Non-Agricultural Use Sites: "Dimethomorph is also 

registered for use on forest trees, herbaceous plants, ornamentals (flowering and foliage types, 

herbaceous and woody types, ground cover) woody shrubs and vines, trees, and ferns." 

o BASF Response: BASF considers the following non-agricultural use sites: 

herbaceous plants, bedding, perennials, foliage and flowering and woody ornamental 

trees, shrubs, vines and groundcovers including conifer nursery-grown seedlings." 

BEAD Response to Comment 7: BEAD appreciates the detailed listing of ornamentals. The 

site list provided in the BEAD Chemical Profile (Chen et al., 2012) is not meant to be 

exhaustive; it is meant to give an overview of uses. A detailed list of sites is provided in the 

PRO Label Report. No changes to the BEAD Chemical Profile are required. 

BASF Comment 8 (p. 26): 

"EPA Statement: Page 2, paragraph 6, Agricultural Usage: ' ... dimethomorph 'sannual 

agricultural usage averaged 35,000 pounds of active ingredient (AI) treating an average of 

180,000 acres from 2006-2010.' 

o BASF Response: BASFwould like to add that in 2012, annual usage totaled 39,769 

pounds AI treating a total of203,456 acres." 

BEAD Response to Comment 8: BEAD thanks BASF for the 2012 usage data. As noted in the 

BEAD Chemical Profile, the data provided by EPA includes data ranging from 2006-2010. 

The data are accurate for the reported time frame. OPP will consider the BASF information as 

the Registration Review of dimethomorph continues. No changes to the BCP are required. 

Sources: 

BEAD. 2012a. PRO Label Data Report on Dimethomorph (268800), EFED Label Data Report 

on Dimethomorph (268800). Biological and Economic Analysis Division, Office of Pesticide 

Programs, U.S. EPA. EPA Docket EPA-HQ-OPP-2013-0045-0007 

Comments Submitted by BASF Concerning the Registration Review of Dimethomorph (PC 

Code 268800) from EPA Docket ID No. EPA-HQ-OPP-2013-0045 

BEAD. 2012b. Screening-level Usage Analysis for Dimethomorph (SLUA) (268800) from 

EPA Docket EPA-HQ-OPP-2013-0045-0006 

Dimethomorph Public Docket. EPA-HQ-OPP-2013-0045-0001 

Chen, C., R. Prieto, and A. Lee. 2012. Dimethomorph (268800) BEAD Chemical Profile 

(BCP). Biological and Economic Analysis Division, Office of Pesticide Programs, U.S. EPA. 

EPA-HQ-OPP-2013-0045-0005 

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