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 . 

Environmental 

Rafael A. Prieto 

Protection Kpelaii~ 

Af--A, I I It ,-P ~ 

Science Information & Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Diann 

Science 

Sims, 

Information 

Chief ~ & Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Andrea Mojica, Chemical Review Manager 

Risk Management and Implementation Branch 4 

Pesticide Re-evaluation Division (7508P) 

I looked at the comments pertaining to BEAD and all are related to what used to be known as the 

Appendix A (now named PRD Label Data Report). Below you will find a brief summary of my 

responses. 

1. The Appendix A correctly identifies "NS" instead of 2 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 minimum reentry interval. Please see 

attachment 1 for 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 new report to reflect these findings. A corrected PRD Label Data Report 

(new name for Appendix A) was delivered separately, along with the other LUIS reports usually 

generates. 

Attachment 
Attachment 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 .041bl A 12 hr 1\4 hr 

FallowlIdle Land 

. 

Barley 2a 12 hr 1\4 hr 

PastureslConservatio 2b .041bl A 12 hr II 4 hr 

nReserve 

Rangeland 2b .041bl A 12 hr 114 hr 

Findin£s/Response 

Labels consulted/or,this response to comments: 100-701 (dated I 

101812003), 100-768, (dated 11120/2003) and 100-927 (dated 812012009). I 

1. The Appendix A correctly identifies ''NS'' instead of 2 for Max # Apps I 

CC. Based on our research, the labels with this use do not currently have a 

specific maximum number of applications per crop cycle. 

2. The corrected Appendix A is now displaying 0.039 lb I a under A.I. 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 of the dicamba RED 

issued on June 8, 2006. The original triasulfuron reports were generated in 

June 2011. 

1. Appendix A correctly identifies ''NS'' instead of 2 for Max # Apps ICC. 

Based on our research, the labels with this use do not currently have a 

specific maximum number of applications per crop cycle. 

2. 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 of applications per year. 

2. The corrected Appendix A is now displaying 0.039 lb I a under A.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 of the dicamba RED 

issued on June 8, 2006. The original triasulfuron reports were generated in 

June 2011. 

1. The Appendix A correctly identifies ~'NS" instead of 2 for Max # Apps I 

year. Based on our research, the labels with this use do not currently have a 

specific maximum number of applications per year. 

2. The corrected Appendix A is now displaying 0.039 lb / a under A.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 of the dicamba RED 

issued on June 8, 2006. The original triasulfuron reports were generated in 

June 2011. 
Wheat 2a 12 hr 114 hr L The Appendix A correctly identifies "NS" instead of2 for Max # Apps / 

CC. Based on our research, the labels with this use do not currently have a 

specific maximum number of applications per crop cycle. 

2. The Appendix A correctly included 24 hours minimum reentry interval. 

The change from the 12 to 24 hour REI was a result of the dicamba RED 

issued on June 8, 2006. The original triasulfuron reports were generated in 

June 2011. -- ------

a One application of .013 lb AIl A may be followed by a second application no sooner than 60 days later at up to .013 lb AIl A; total application not to exceed .0263 lb All AlCrop 

season 

-+ EPA response: The above statement was not found on any of the labels used to generate the Appendix A. Labels approved by the Agency after June 2011 mayor may 

not have this statement. 

b One application of .013 lb AliA may be followed by a second application not more than 60 days later at up to .0263 lb AIlA; total application not to exceed .041b AIlAlYear 

-+ EPA response: EPA response: The above statement was not found on any of the labels. Labels approved by the Agency after June 2011 mayor may not have this 

statement.