UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

MEMORANDUM 

Date: 14-JUL-2015 

WASHINGTON, D.C. 20460 

OFFICE OF CHEM ICA L SAFETY ANO 

POLLUTION PREVENTION 

SUBJ ECT: Spirodiclofen: Response to Comments on the Human Health Scoping Document for 

Registration Review 

PC Code: 124871 

Decision No.: 505569 

Petition No.: NIA 

Risk Assessment Type: NIA 

TXR No.: NIA 

MRID No.: NIA 

DP Ba rcode: 0427620 

Registration No.: NIA 

Regulatory Action: Registration Review 

Case No.: 7443 

CAS No.: 148477-71-8 

40 CFR: § 180.608 

FROM: 

Thomas Bloem, Chem--1s~-::1, 

t~ientist J ~ -?"c..e""'~ . ~ 

Monique M. Perron, Sc.D., Toxicologist 1lln1~ /~ 

Risk Assessment Branch I (RAB I) ' ... ,-tr - - Health Effects Division (HED, 7509?) 

THROUGH: Thurston G. Morton, Acting Branch Chief 

RAB 1/HED (7509P) 

TO: Jolene Trujillo, Chemical Review Manager 

Pesticide Re-Evaluation Division (PRO) (7508P) 

The Spirodiclofen Risk Assessment team has received comments on the Spirodiclofen Human 

Health Scoping Document (EPA Docket ID: EPA-HQ-OPP-20 14-0262) and attached is the 

response to comments. Comments relevant to the preliminary work plan, usage overview, 

environmental safety and drinking water assessment, and human safety were provided by Bayer 

CropScience. Those that pertain to the use pattern and application method are addressed herein. 

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Spirodiclofen Response to Comments 0427620 

Use Pattern comments: 

The Registrant 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, leafhoppers, and 

San Jose scale on crops including citrus, grapes, stone fruit, pome fruit, and tree nuts. 

Bayer comment: The product is 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 apple), stone fruit, tree nuts, and Christmas 

tree plantations. There are no indications to control leafhoppers and several uses are 

omitted. 

#2 Table 3 in Use Sites Page 6 (PWP): Uses are listed as citrus, grapes, pome fruit, stone fruit, 

tree nuts, tropical fruits, berries, 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, sapodilla, star 

apple) were omitted. Only lychee, guava, sugar apple, and persimmon were withdrawn 

in the April 2014 action. 

EPA Response: The Agency will revise the PWP and the HED scoping document to accurately 

reflect the target pests as only mites and San Jose scale, and the spirodiclofen registered use 

pattern as follows -

Citrus, 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. 

Application method comment: 

Table 3 Application Method Page 6: States the product applied once per crop season by airbl ast 

equipment for all registered crops and by aerial equipment on avocado and Christmas trees only. 

Bayer comment: Bayer is not aware of any restrictions regarding the use of other 

application equipment. 

EPA Response: The product label indicates applications are to be made by ground equipment, 

and in some places specifically references ground airblast sprayers. Since the product is a 

miticide, it is assumed that for the registered use sites (e.g., trees and vines), airblast equipment 

will be the primary application method. Further, the product labels indicate that aerial 

applications are only allowed for avocado and Christmas trees. The application equipment 

information will be revised to the following -

Product applied once per crop season by ground (airblast) equipment for all registered crops. 

Product can also be applied by aerial equipment on avocado and Christmas trees. 

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