UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

'JUL28 2012 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

MEMORANDUM 

SUBJECT: Response to Public Comments from Syngenta on PRD Appendix A from Initial 

Docket for Cyprodinil 

FROM: 

THRU: 

TO: 

Cynthia Doucoure, Environmental Protection Specialist (} . ~~ Science Information and Analysis Branch (SlAB) 

Biological and Economic Analysis Division (7503P) 

Diann 

Science 

Sims, 

Information 

Chief ~~ and Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Wilhelmena Livingston 

Chemical Review Manager 

Registration Division (7505P) 

Through this memo, BEAD is providing responses to Syngenta's comments on the PRD 

Appendix A: Food/Feed Uses Considered in Registration Review Work Planning provided in 

the initial docket for cyprodinil. 

Svngenta Comment #1: Please note that Syngenta believes the formulation type is an oil-inwater emulsion (EW) and as specified on page 9 of the Environmental Fate and Ecological Risk 

Assessment. Preliminary Problem Formulation in Support of Registration Review ofCyprodinil, 

February 13, 2012. PC Code 288202; DP Barcode: D393800 (EPA-HQ-OPP-2011-1008-005) 

BEAD Response: Thanks for calling to our attention the correct formulation type for the Inspire 

SuperTM Fungicide product. The PRD Appendix A Report will be corrected and re-issued. 

Syngenta Comment #2: Please note Syngenta requests this header (Max #Apps/CC) is changed 

to indicate Max # Apps/Year and the number of applications updated to reflect the same 

information in Table 2. Summary of Use Information for Cyprodinil as listed on pages 9-11 of 

the Environmental Fate and Ecological Risk Assessment. Preliminary Problem Formulation in 

Support of Registration Review ofCyprodini/, February 13, 2012. PC Code 288202; DP 

Barcode: D393800 (EPA-HQ-OPP-2011-1008-005). Additionally, CC is not defined in the 

Appendix A. 

BEAD Response: As much as we would like to have the Max# Apps/CC (crop cycle) in the 

PRD Appendix A match Table 2. Summary of Use Information for Cyprodinil as listed on pages 
9-11 of the Environmental Fate and Ecological Risk Assessment, the fact is, the PRD Appendix 

A max# of applications allowed per CC is based on application method timings (e.g., bloom and 

preharvest) identified in the remarks and specific use restrictions on the actual labels. For 

example, for stone fruits applied at the 5 ozla rate (0.23 lb a.i./A), the remarks state to "begin 

applications at bloom stage ... Make a second application at full bloom." Based on these 

statements, the Max # Apps per Year or CC would be "2" at bloom timing. If the max # of 

applications allowed, based on the max dose per year does not appear on the label, this 

information is not picked up in the PRD Appendix A. On the other hand, it appears that the 

Table 2. Summary of Use Information does not take into account the number of applications 

based on the timings but based on the max dose per year. 

Svngenta Comment #3: Please note canol a and rape should not be included in the table since 

there is not a domestic tolerance. 

BEAD Response: Thanks for calling our attention to the fact that canola and rape should not be 

included in the report. The PRD Appendix A Report will be corrected and re-issued. 

Syngenta Comment #4: Please note Chickpea should be included in the table as a use site for 

the oil-in-water formulation (EPA Reg. No. 100-1317). 

BEAD Response: Chickpeas is included in the table as a use site. See "Garbanzos (including 

chick peas)" in the PRD Appendix A report. 

Syngenta Comment #5: Please note only lemon and lime should be included in the table since 

there is not a crop group tolerance for citrus. 

BEAD Response: Thanks for calling our attention to the fact that only lemon and lime should be 

included in the report. The PRD Appendix A Report will be corrected and re-issued. 

BEAD has reviewed and addressed all of Syngenta' s comments related to the PRD Appendix A: 

Food/Feed Uses Considered in Registration Review Work Planning. 

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