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) () I

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-----...1.' / Don Atwood, PhD., Entomologist i)./

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### y7;**(.A/~ -'**  Science and Information Analysis Branch Biological and Economic Analysis Division (7503P) Diann Sims, Branch

# Chief**~** Science Information 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 onAugust 20, 2014. Comment: "Inclusion ofseveral Crops in Geographic Distribution ofPropargite 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 strawberrytolerance 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 withhot summers conducive ofmite infestations, along with the registration ofseveral newmiticides withjust 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 onthe Propargite BCP and SLUA. The almost 3,000 lbs ofpropargite used on strawberries represents the average yearly use based on two years ofreported propargite use from 2004-2012. BEAD stands bythis figure as representative ofpropargite use on strawberries as propargite is still labeled for non-bearing use onthis crop (Omite label, March 14, 2012). However, BEAD concurs thatthe designation of propargite use inFlorida to strawberries was in error and appreciates the commenterbringing this to our attention. The intensity ofuse in Florida actually reflects use oncitrus rather than strawberries.
Comment: "Additionally, the peaches and prunes/plum tolerances were cancelled in 1999 and the Agency predicted similar estimates oflbs. ofpropargite as strawberries during the reported years. " Agency Response: As propargite is still registered for use onnon-bearing peach and plum/prune and based on available usage data, BEAD believes use ofpropargite is still occurring onthese crops. BEAD stands by the usage estimates that are provided inthe SLUA for peach
.and plum/prune production. The non-bearing nature ofthese uses will be appropriately assessed during the registration reviewprocess.
Comment: "Furthermore, the non-bearing avocado use was voluntarily removed from propargite formulation labels bythe Registrant in 2011." Agency Response: BEAD has reviewed the most recent Omite labels (March 14, 2012) and determined thatpropargite is still labeled for use onnon-bearing avocados. As such, the data reported inthe BCP and SLUA are accurate and appropriate for consideration in registration review.

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