UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D .C. , 20 46 0 

### APR 13 2015

OFFICE OF CHEM I CAL SAFETY AND POLLUTION PREVENTION
.MEMORANDUM SUBJECT : Response to Dow Agro Science (DAS) Comments on Oxyfluorfen (111601) BEAD Chemical Profile (BCP) FROM:

THRU: Rafael A. Pri e to , Environmental Protection Specialist 

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. ...,, Sun ii Ratnayak e, Biologi s t

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## I Stephen Smearman, Economi st Economic Analy s is Branch

# ~~ Biological and Economic Analysis Division (7503P) Diann Sim s, Chief

# £}-~ Science Information & Anal ysis Branch Arnet Jones , C hi ef 

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## Branch**~Y /**  Timothy Kiely , Chief /\__

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_ lll Biological and Economic Ana lys is Division P) TO: Benjamin Ask in , Chemical Review Manager Risk Management an d Implementation Branch 1 Pesticide Re-evalu ation Divi s ion (75 08P)

Peer Review Panel Date: 8 April, 2015BEAD reviewed the co mments submitted by Dow Agro Sciences, LLC (DAS) on EPA's oxyfluorfen registration review docket. Our responses to the registrant' s comments are provided below. The comment s were all r e lated to the BEAD Chemi cal Profile (BCP) o n oxyfl uorf en.
1. DAS comment on use s ites: ''Th e non-agri cu ltural u se sites are li sted incorrectl y. A s per curre nt product l abels, this entry sho uld be updated to read: Oxyfluorfen is also registered for non -cro p u se, incl ud ing nonfood producing, non-cultivated agricultural or non -agricu ltural areas such as highway and utility rights-of-way, roadway s, industrial sites, tank farms, s torage areas, airports, fencerows, l evee b anks (only on s id e way from water channe l) , farmsteads, w indbreaks and s helter break s." BEAD's response: The non-agricultural s ite listing in BEAD 's Chemical Profile is not intended to present every specific use s ite. Rather the documents presents an overv iew of the use sites found across all oxyfluorofen registrations. The Label Data Report for oxyfluorfen, found on the public do cket , ha s a comple te list of u se s ites. 2
. DAS comment on formu lation types: "The l isting of formulation types is incorrect. This entry s hould be corrected so that it reads : emu ls ifiabl e concentrate, sus p ens ion concentrate, and granular." BEAD 's re spo n se: BEAD appreciates the cl arification and acknow l edges t h at oxyfluorfen i s not formulated as a flowabl e concentra te. However, there are act ive non-D AS regi s trations formul ated as ready to use (RTU) (239-2516 is an examp l e). 3. DAS comment on application method s: ''Th e listing of application equipment is incorr ect. Thi s portion of the e ntry should be updated so that it reads: Band/broadca s t app l ication · equipment includes handheld sprayers, tractor mounted conventional ground s prayers, ground sprayers mounted on wheels pulled by tractors or A TV's, and by aerial. " O rigin al l an g u age on BCP: It i s app li ed as band treatme nt , broadca st, and by chemigation. Applicati on equip ment includes handheld sprayers and t ractor mounted conventional ground sp rayer s . BEAD 's re spo n se:BEAD appreciates the specifics offered in the registrant's response. How ever, the purpose of this listing is to bro adly characterize the application equipment across all registrations for thi s c hemical. The Label Data Report for oxyfluorfen, found on the public docket, has a co mplete li st of app li cation methods for oxyfl u orfen. 4. DAS comment on ro le of oxyfluorfen in pes t management: "The Agency states on page 8 of 11 : Oxyfluorfen (Goal2XL) formulation is used at the two- to four-leaf s tage of the crop, but the Goal Tender formulat i on can be used at the l st true leaf s tage. (Unive rs ity of California IPM Guidelines, 2014 (2))."

" DAS disagrees with this statement. As p er the current product l abels, for direct seeded onion, both Goa l Tender and Goa l 2XL can be applied when the onion is at greater than two-leaf s tage to control two- to four-leaf weeds. For dry bulb onion, Goal Tender on l y (not Goal2XL) can be app lied when the onion is at 1 leaf or greate r growth stage." BEAD 's response: BEAD ap preciat es the clarification from DAS a nd will consider this information as the registration review contin ues.

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