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 Docketfor Cyprodinil FROM:

THRU:



### TO: Cynthia Doucoure, Environmental Protection Specialist (}

.

### ~~ Science Information and Analysis Branch (SlAB) Biological and Economic Analysis Division (7503P) Diann Sims,

# Chief**~~** Science Information 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 onthe 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 theformulation type is an oil-inwater emulsion (EW) andas specifiedonpage 9 of the Environmental Fate andEcological 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 SuperTMFungicide 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 andthe number of applications updatedto reflect the same information in Table 2. Summary ofUse Informationfor Cyprodinil as listedonpages 9-11 of the Environmental Fate andEcological RiskAssessment. 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 AppendixA. BEAD Response: As much as we would like to have the Max# Apps/CC (crop cycle) inthe PRD Appendix A match Table 2. Summary ofUse Information for Cyprodinil as listed onpages9-11 ofthe Environmental Fate and Ecological Risk Assessment, the fact is, the PRD Appendix A max# ofapplications allowed per CC is based on application method timings (e.g., bloom and preharvest) identified in the remarks and specific use restrictions onthe actual labels. For example, for stone fruits applied at the 5 ozlarate (0.23 lb a.i./A), the remarks state to "begin applications at bloom stage
...Make a second application at full bloom." Based onthese statements, the Max # Apps per Year or CC would be "2" at bloom timing. If

### the max # 

### of applications allowed, basedon the max doseperyeardoes notappear on the label, 

### this information is not picked up in 

### the PRD 

### Appendix A. Onthe other hand, it appears that the Table 2. Summary ofUse Information does nottake into account the number ofapplications based onthe timings but based onthe max dose per year. Svngenta Comment #3: Please note canol a andrape shouldnotbe 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 inthe report. The PRD Appendix A Report will be corrected and re-issued. Syngenta Comment #4: Please note Chickpea shouldbe 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 andlime shouldbe 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 inthe report. The PRD Appendix A Report will be corrected and re-issued.

BEAD has reviewed and addressed all ofSyngenta's comments related to the PRD Appendix A: Food/Feed Uses Considered in Registration Review Work Planning.

Page 2 of2