### UN IT E D STATES ENVIRONMENTAL PROTE CTION AGENCY

MEMORANDUM
Date: 14-JUL-2015 

### WASHINGTON, D.C. 20460

OFFI CE OF C H EM I CA L SAFETY ANO P OLLUT I ON PREV ENTI ON



### SUB J ECT : Spirodic lofen: Response to Comments on the Human Health Scoping Document for Registration Review

PC Code: 124871 Dec is ion No.: 505569 Petition No.: NI A Ri s k A ssess m e nt Type: NIA TXR No.: NIA MR ID No.: N IA DP B a r code: 0427620 Registration No .: NIA Regulatory Actio n : Registration Review Case No.: 7443 CAS No.: 148477-71-8 40 CFR : § 180.608 

### FROM:

# t~ientist**-?"c..e""'~ ~**  Thomas B loem,**Che m--1s** **~-::1,** J**~** . Monique M. Perron , Sc .D. , Toxicologist

### 1lln1~**/~** Risk Assessment Branch I (RAB I) '

...

# ,-- tr

- H ea lth Effects Division ( HED, 7509?)


### THROUGH: Thurston G. Morton, Acting Branch Chief 

### RAB 1/H E D (7509P)


### TO: Jolene Trujillo , Chemical Review Manager Pesticide Re-Evaluat ion Div i sio n (PRO ) (7508P)

The Spirodiclofen Risk Assessment team has received comments on the Spirodiclofen Human Health Scoping Document (EPA Docket ID : EPA -H Q-OPP-20 1 4-0262) and attached is the response to comments. Comments relevant to the preliminary work plan, usage overview, environmental safety and drinking wate r assessment, and human safety were provided by Bayer CropScience. Those that pertain to the use pattern and app li cation method are addressed herein.

Page I of2Spirodiclofen Resp onse to Co mment s 0427620 

### Use Pa ttern commen ts:
The R egistrant provided several comments on the use pattern reported in the Preliminary Work Plan (PWP) and in the Human Health Scoping Document (Scoping).


### # I Overview Page 1 (PWP): Product is listed as registered to control mites, leafhopp er s, and San Jose scale on crops including citrus , grapes, stone fruit, pome fruit, and tree nuts. Bayer comment: The product i s registered to control mites and San Jose scale on crops including tropical fruits (avocado, black sapote, canistel, mango , mamey sapote, papaya, citrus, grapes, hoppome fruit , sapodilla, star app le), stone fruit , tree nuts , and Christmas tree plantations. There are no indic ations to control leafhoppers and severa l uses are om itted.
# 2 Table 3 in Use Si t es Pag e 6 (PWP): Uses are listed as citrus, grapes, pome fruit , stone fruit , tre e nuts, tropical fruits , berrie s , hops and Christmas tree plantations. Bayer comment: This section includes berries which are not a registered crop.
#3 Introduction Page 4 (Scoping) Bayer comment: Lists registered crops. Tropical fruit uses (avocado, black sapote, canistel , mango , mamey sapote, papaya, citrus, grapes , hop, pome fruit , sapod illa , star app le ) were omitted. Only lychee , g uava , sugar apple , and persimmon were withdrawn in the April 2014 action.
EPA Response: The Agency wi ll rev i se the PWP and the HED scoping document to accurately reflect the target pests as only mites and San Jose sca le , and the spirod iclofen registe red u se pattern as follows

- Ci tru s, grapes, hops , pome fruit , stone fruit, tree nuts , tropical fruits (avocado, black sapote, canistel, mango, mamey sapote, papaya , sapodilla , star apple) , and Christmas tree plantations. 

### Applica tio n m eth o d com men t:
Table 3 Application Method Page 6: States the product app lied once per crop season by ai rbl ast equipment for all registered crops and by aeria l equipment on avocado and Chris tmas tre es only. B aye r comment: Bayer is no t aware of any re striction s re garding the use of other application equipment.
EPA Respon se : The product label indicates applications are to be made by grou nd equipment , and in some places specifica ll y references ground airblast sprayers. Since the product is a miticide , it is assumed that for the registered u se sites (e

. g., trees and vines) , airbla s t equipment will be the primary application method. Further, the product lab e ls indicat e that aerial appl ications are only allowed for avocado and Christmas trees. The applica ti on equipment information will be r ev ised to the following

- Product applied o nc e per crop season by ground (airblast) equipment fo r all registered crops. Product can also be applied by aerial equipment on avocado and C hri stmas trees.

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