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 

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## Q Rafael 

### A Prieto, Efvrr ent

# Prot~c**f.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 ofDimethomorph
. 

### BASF Comment 1 (pp.16-17): "Revised LabelDataReport 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 ofregistered uses for dimethomorph. Label data for chemicals with more than one pesticide product are presented in aggregate form (i.e., each line ofdata may be a combination ofdata from one or more pesticide)." No changes to the PRD Label report are required. 

### BASF Comment 2 (p. 18): "Label Data Report- Duplicate Entries Thefollowing 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
1would like to use the mostaccurate numbers, so we are using the 0.3992 lb ai/a data. BASF would like to note that thefollowing 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 DataReport- Formulations ContainingMancozeb and in the Process ofCancellation The information in thefollowing section of the LabelDataReportapplies to the end useproducts containing dimethomorph andmancozeb listed below. Asnotedpreviously, BASFis in the process of voluntarily cancelling these registrations and therefore is not supporting these uses through registration review. As such, BASFwould 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 WaterDispersible 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 ofthe report. As appropriate, BEAD will update the report when the noted cancellations become effective. BASF Comment 4 (p. 25): Dimethomorph (268800) ScreeningLevel Usage Analysis (SLUA) "BASF interprets "Percent Crop Treated" as follows: out of the total acres grown in US fora specific crop, thepercent crop treated reflects howmany of those acres are treated with dimethomorph. As such, BASFhas the following comments: Basedon data from DoaneMarketAnalysis 2012, BASFnotes 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 2Squash <500 5 10 Tobacco <500 5 10 Tomatoes 4200 

### 5 10 Watermelons <500 <1 <2.5 BEAD Response to Comment4: BEAD appreciates the more recent information. We note that data from 2012 is largely within the rounding process ofthe 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 ofthis comment. BASF Comment 5 (p. 26): BEAD ChemicalProfilefor RegistrationReview: Dimethomorph (268800) "BASFhas 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, wettablepowder, and emulsifiable andsoluble concentrate. ' o BASFResponse: BASFhas dimethomorph end-useproducts registeredas suspension concentrate, water dispersible granule, andwettablepowder formulations only. There are no emulsifiable concentratesregistered for dimethomorph. BASFintends to voluntarily cancel registration of the wettable powder formulations by secondquarter2014." 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, paragraph4, Agricultural Use Sites: '
...registeredfor use on lettuce, onions, tobacco, potatoes, cucurbits (e.g., pumpkins, cucumbers, squash, cantaloupes, watermelons), spinach, cabbage, peppers, and tomatoes.' o BASFResponse: BASFwould like to note that this list is not inclusive of the registeredagricultural uses on the most recently approvedEPA stampedForum label because the leafy vegetables group, which replaces lettuce, is not listed. The complete list of crop uses registered for dimethomorph is as follows: Brassica 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.



### 3BASF Comment 7 (p. 26): "EPA Statement: Page 

### 2, paragraph 5, Non-Agricultural Use Sites: "Dimethomorph is also registered for use on forest trees, herbaceousplants, ornamentals (flowering and foliage types, herbaceous andwoody types, groundcover) woody shrubs and vines, trees, and ferns." o BASFResponse: BASFconsiders the following non-agricultural use sites: herbaceousplants, bedding,perennials,foliage and flowering and woody ornamental trees, shrubs, vines andgroundcovers including conifernursery-grown seedlings." BEAD Response to Comment 7: BEAD appreciates the detailed listing ofornamentals. The site list provided in the BEAD Chemical Profile (Chen etal., 2012) is not meant to be exhaustive; it is meant to give an overview ofuses. 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 averaged35,000pounds of active ingredient (AI) treating an average of 180,000 acres from 2006-2010.' o BASFResponse: BASFwouldlike to add that in 2012, annual usage totaled 39,769 poundsAItreating a total of203,456acres." 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 ofdimethomorph continues. No changes to the BCP are required.

Sources: BEAD. 2012a. PRO Label Data Report onDimethomorph (268800), EFED Label Data Report on Dimethomorph (268800). Biological and Economic Analysis Division, Office ofPesticide Programs, U.S. EPA. EPA Docket EPA-HQ-OPP-2013-0045-0007 Comments Submitted by BASF Concerning the Registration Review ofDimethomorph (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 ofPesticide Programs, U
.S
. EPA. EPA-HQ-OPP-2013-0045-0005

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