UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

OCT 28 2014 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

TO: 

BEAD Response to Comments for Propargite (DP# 423025) 

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Don Atwood, PhD., Entomologist i)./ ov¥?)!.,(/ y7; (.A/~-' 

Science and Information Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Diann 

Science 

Sims, 

Information 

Branch Chief and Analysis ~ Branch 

Biological and Economic Analysis Division (7503P) 

Wilhelmena Livingston, Chemical Review Manager 

Pesticide Re-evaluation Division (7508P) 

This memorandum transmits BEAD response to comments for Propargite Registration Review 

(Case# 0243). This memo addresses comments submitted by MacDermid Agricultural Solutions, 

Inc./Chemtura Corporation on August 20, 2014. 

Comment: "Inclusion of several Crops in Geographic Distribution of Propargite use. 

Strawberries are discussed as having a niche market in Florida (April 10, 2014, Propargite 

BEAD Chemical Profile) (page 6). The Agency is aware the strawberry tolerance was 

voluntarily cancelled by the Registrant with 9 other tolerances in 1999 (Federal Register 64, page 

390068, July 21, 1999). Thus one would think there should be no sales on non-bearing 

strawberries since that time due to a restrictive 365-day PHI (strawberries bear fruit the year 

transplanted). This additionally should be true in other strawberry states with hot summers 

conducive of mite infestations, along with the registration of several new miticides with just a 

few days PHI during this period. Yet the Agency estimates 3,000 lbs ofpropargite used annually 

during the 2004-2011 reporting years (March 12, 2013, Propargite (097601) Screening Level 

Usage Analysis (SLUA)." 
Agency Response: BEAD appreciates the comments on the Propargite BCP and SLUA. The 

almost 3,000 lbs ofpropargite used on strawberries represents the average yearly use based on 

two years of reported propargite use from 2004-2012. BEAD stands by this figure as 

representative of propargite use on strawberries as propargite is still labeled for non-bearing use 

on this crop (Omite label, March 14, 2012). However, BEAD concurs that the designation of 

propargite use in Florida to strawberries was in error and appreciates the commenter bringing 

this to our attention. The intensity of use in Florida actually reflects use on citrus rather than 

strawberries. 

Comment: "Additionally, the peaches and prunes/plum tolerances were cancelled in 1999 and 

the Agency predicted similar estimates of lbs. of propargite as strawberries during the reported 

years. " 

Agency Response: As propargite is still registered for use on non-bearing peach and plum/prune 

and based on available usage data, BEAD believes use of propargite is still occurring on these 

crops. BEAD stands by the usage estimates that are provided in the SLUA for peach. and 

plum/prune production. The non-bearing nature of these uses will be appropriately assessed 

during the registration review process. 

Comment: "Furthermore, the non-bearing avocado use was voluntarily removed from propargite 

formulation labels by the Registrant in 2011." 

Agency Response: BEAD has reviewed the most recent Omite labels (March 14, 2012) and 

determined that propargite is still labeled for use on non-bearing avocados. As such, the data 

reported in the BCP and SLUA are accurate and appropriate for consideration in registration 

review. 

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