UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C

., 20460 

## JUL 16 2012

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION



### MEMORANDUM

SUBJECT:
FROM:



### THRU:

TO: Response to Comments for Triasulfuron, DP# 402820

. Rafael A. Prieto 

# Af--A, I 

## I 

# It 

# , -P**~** Environmental Protection

# Kpelaii~ Science Information & 

### Analysis Branch Biological andEconomic Analysis Division (7503P)
Diann Sims, Chief

# ~ Science Information & 

### Analysis Branch Biological and Economic Analysis Division (7503P)
Andrea Mojica, Chemical Review Manager Risk Management and Implementation Branch4 Pesticide Re-evaluation Division (7508P)

I looked atthe comments pertaining to BEAD and all are related to what used to beknown as the Appendix A (now named PRD Label Data Report). Belowyouwill find a briefsummary ofmy responses
. 1. The Appendix A correctly identifies "NS" instead of2 for Max # Apps / CC. Please see attachment 1 for additional details. 2. The corrected Appendix A is now displaying 0.0391b/ a under A.I. Max App RatelYear. 3. The Appendix A correctly included 24 hours minimumreentry interval. Please see attachment 1for additional details. 4. The Appendix A correctly identifies ''NS'' instead of2 for Max # Apps / year. Please see attachment 1 for additional details.

### We have generated a newreportto reflect these findings. A corrected PRD Label DataReport (newname for Appendix A) was delivered separately, along withthe other LUIS reports usually generates.
AttachmentAttachment 1 12 July 2012 Response to Comments from Svngenta on Triasulfuron. BEAN Number 402820 Registrant's Comments Use Site Max# Max# A.I. Max Minimum Apps/CC Appsl App Reentry Year RatelYear Interval (MRI) Agricultural 2a .041blA 12 hr 1\4 hr FallowlIdle Land



# .

Barley 2a 12 hr 1\4 hr

PastureslConservatio 2b .041blA 12 hr 

## II 4 hr nReserve

Rangeland 2b .041blA 12 hr 114 hr Findin£s/Response Labels consulted/or,this response to comments: 100-701 (dated I 101812003), 100-768, (dated 11120/2003) and100-927 (dated 812012009). I

1. The Appendix A correctly identifies ''NS'' instead of2 for Max # Apps I CC. Based on our research, the labels with this use do not currently have a specific maximum number ofapplications per crop cycle. 2. The corrected Appendix A is now displaying 0.039 lb I a underA.I. Max App RateN ear. 3. The Appendix Acorrectly included 24 hours minimum reentry interval. The change from the 12to 24 hour REI was aresult ofthe dicambaRED issued on June 8, 2006. The original triasulfuron reports were generated in June 2011. 1. Appendix A correctly identifies ''NS'' instead of2 for Max # Apps ICC. Based on our research, the labels with this use do not currently have a specific maximum number ofapplications per crop cycle. 2. The Appendix Acorrectly included 24 hours minimum reentry interval. The change from the 12 to 24 hour, REI was a result ofthedicambaRED issued on June 8, 2006. The original triasulfuron reports were generated in June 2011. 1. The Appendix A correctly identifies ''NS'' instead of2for Max # Apps I year. Based on our research, the labels with this use do not currently have a specific maximum number ofapplications peryear. 2. The corrected Appendix A is now displaying 0.039 lb I a underA.1. Max App RateN ear
.. 3. The Appendix A correctly included 24 hours minimum reentry interval. The change from the 12 to 24 hour REI was a result ofthe dicamba RED issued on June 8, 2006. The original triasulfuron reports were generated in June 2011. 1. The Appendix A correctly identifies**~'NS"** instead of2 for Max # Apps I year. Based on our research, the labels with this use do not currently have a specific maximum number ofapplications peryear. 2. The corrected Appendix A is now displaying 0.039 lb / a underA.1. Max App RateN ear
.. 3. The Appendix A correctly included 24 hoursminimum reentry interval. The change from the 12 to 24 hour REI was a result ofthe dicambaRED issued on June 8, 2006. The original triasulfuron reports were generated in June 2011.Wheat 2a 12 hr 114 hr L The AppendixA correctly identifies "NS" instead of2 for Max# Apps / CC. Based on ourresearch, the labels with this use do not currently have a specific maximum number ofapplications per crop cycle. 2. The AppendixA correctly included 24 hours minimum reentry interval. The change from the 12 to 24 hour REI was a result ofthe dicamba RED issued on June 8, 2006. The original triasulfuron reports were generated in June 2011.

-- ------ a One application of.013 lb AIl A maybe followed by a second application no sooner than 60 days later at up to .013 lb AIl A; total application not to exceed .0263 lbAll AlCrop season 

### -+ EPA response: The above statement was not found on any ofthe labels used to generate the Appendix A. Labels approved by the Agency after June 2011 mayor may nothave this statement. b One application of.013 lb AliA maybe followed by a second applicationnot more than 60 days later at up to .0263 lb AIlA; total application not to exceed .041b AIlAlYear 

### -+ EPAresponse: EPAresponse: The above statementwas notfound on any ofthe labels. Labels approved by the Agency after June 2011 mayor may nothave this statement.