### 2 of 18 AMENDMENT TO SEPTEMBER 18, 2008 SULFOMETURON METHYL

REREGISTRATION ELIGIBILITY DECISION

The Environmental Protection Agency (EPA, or the Agency) is publishing an amendment to the September 18, 2008 Sulfometuron Methyl Reregi stration Eligibility Decision (SMM RED)

document.

Stakeholder comments, mitigation proposals, an d other information received by the Agency following the publication of the SMM RED have provided reason for the Agency to further refine the ecological risk assessment for non- target plant species and the buffer zone requirements imposed in the SMM RED document to mitigate those risks. Based on these changes, the Agency was also able to revise the occupational handler exposure scenarios and revisit the Personal Protective Equipment (PPE) requirements of the SMM RED. All submitted comments, mitigation proposals, and other inform ation connected to the Agency’s decision to revisit the RED mitigation measures can be found in the sulfometuron methyl docket ( EPA-HQOPP-2008-0129 ) at www.regulations.gov . The Agency’s response to comments received on the

SMM RED are also located in the docket.

This document addresses public comments and m itigation proposals submitted to the Agency that effect the estimated risk and mitigation m easures for sulfometuron methyl. This document also presents an updated label table for su lfometuron methyl that includes the amended mitigation as well as mitigation requirements re quired by the SMM RED that were not effected by public comments.

Public comments that did not affect the risk assessment conclusions or mitigation decisions for sulfometuron methyl are addressed in separate documents: comments relating to human health are addressed in the document, Sulfometuron Methyl: Response to Public Comments for Phase 3 Amendment of Sulfometuron Methyl: HED Chapter of the Registration Eligibility Decision (RED) , (W.Britton, D346177). Comments regarding eco logical fate or ecotoxicity are addressed in the document, Response to Environmental Fate and Effects Related Comments on Sulfometuron Reregistration Eligibility Document (M.Barrett, K.Sappington, D346169). Comments regarding policy or proc ess are addressed in the document, Response to Comments Received Following the Publication of the Sulfo meturon Methyl Reregistration Eligibility

Document (R.Wasem, 11-20-09). These documents can be found in the sulfometuron methyl docket: ( EPA-HQ-OPP-2008-0129 ) at www.regulations.gov

.

Various stakeholders from both the commercial forestry and th e railroad industry commented on mitigation measures outlined in the SMM RED. Most commenters expressed concern about the measures (including application parameters a nd buffer zones), intended to mitigate potential ecological risk to non-target organisms (endangered and non-e ndangered plant species).

Commenters noted that some of the measures required in the RED would make it difficult or dangerous to use sulfometuron methyl in a co mmercial forestry or railroad rights-of-way settings. During the comment period, EPA met w ith representatives from National Association of Forest Owners (NAFO) and National Council for Air and Stream Improvement (NCASI) to discuss elements of the Agency’s risk asse ssment including application methods (such as

### 3 of 18 equipment and practices) and applicati on rates relevant to forestry uses. 1 

### Following the comment period, the technical regi strant, DuPont, also proposed reduced application rates and modified application requirements. 2 

### These documents can be found in the sulfometuron methyl docket: ( EPA-HQ-OPP-2008-0129 ) at www.regulations.gov

.

Based upon proposed changes to the application para meters for both the commercial forestry use and other non-forestry uses (e.g. non-crop areas , rights-of-way), the Agency revised its ecological exposure risk estimates for non-target plant species, as well as certain occupational risk estimates. A brief discussion of change s and summary of the revised ecological and occupational risks are presented below.

Application (Release) Height

RED label language requirement : Aerial applications more than 10- feet above the canopy are prohibited

.

Various stakeholders commented that a prohibition of aerial a pplications higher than 10 feet above the canopy is not appropriate for forestry settings. When modeling aerial applications, the Agency can model several release heights, but typically models a 10 f oot release height. However, many commercial forest ry operations are sited on land w ith varying terrain, also, in commercial forestry practices, there may be “leave” trees (stag stands that can drastically vary the canopy height.

Given the terrain of commercial forestry stands, th e Agency agrees that a fixed aerial application height is potentially unsafe and impractical. As a result, the Agency will change the aerial application height restriction to la nguage that prescribes the lowest application height that is safe for the applicator and efficacious for the target spray area. Th e mandatory statement about spray height now contains a condition to allow for greater heights when necessary for applicator safety.

Amendment : For commercial forestry applications, spray should be released at the lowest height consistent with pest control and flight safety. Do not spray from heights greater than 10 feet unless it is required for applicator safety

.

Application Equipment

RED label language requirement : The Agency did not prohibit or specify certain fo rmulations for sulfometuron use scenarios in the

SMM RED.

1 NAFO and NCASI’s discussion on typical commercial fore stry pesticide application parameters and settings can be found in the sulfometuron methyl docket under the letter entitled “4/13/09 - NAFO and NCASI Response to 2.25.09 Meeting with EPA.”

2 DuPont’s proposal of mitigation options was communicated via email and can be found in the sulfometuron methyl docket under the title “7/24/09 – Email Correspondence between DuPont and US EPA Regarding Sulfometuron Methyl RED Mitigation.”

### 4 of 18 The technical registrant, DuPont, proposed to limit aerial application of su lfometuron methyl to rotary craft for all uses except for sulfometuron methyl impregna ted fertilizer. NAFO, NCASI, and other commenters to the public docket indica ted that this proposal was consistent with current forestry practices. The potential for drif t is generally much higher for applications made via fixed wing aircraft than applications made by helicopter, and ther efore, restriction to application by rotary aircraft represents some risk reduction. (While sulfometuron methyl can continue to be applied via fixed wing aircraft as an impre gnated fertilizer, this formulation is expected to produce less drift than applicati on of the liquid formulation and therefore, is expected to present less risk concern.)

Amendment : Aerial applications of liquid formul ations of sulfometuron methyl ar e restricted to rotary aircraft only

.

Application Rates

RED label language requirement : Maximum single application rate is 0.375 lb ai/A for all uses.

No comments were submitted that discussed typical application rates for the commercial forestry use of sulfometuron methyl. In its meeting wi th the Agency, NAFO and NCASI indicated that an acceptable maximum single application rate for commercial forestry use is 0.199 lb ai/A. The technical registrant, DuP ont, proposed an application rate of 0.281 lb ai/A. Since the application practices associated with commercial forestry lead to greater drift than applications associated with the non-forestry uses of sulfometuron methyl, the Agency will adopt the lower single maximum application rate of 0.199 lb ai/A for commercial forestry uses (proposed by the NAFO). The Agency will reduce the application ra te of sulfometuron methyl to 0.281 lb ai/A for all other sulfometuron methyl uses which currently exceed this value (i.e., non-crop areas, rightsof-way).

Amendment : Maximum single application rate for forestry use (hardwoods, conifers) is 0.199 lb ai/A. Maximum single application rate for non-agricul tural rights-of-way uses is 0.281 lb ai/A.

Nozzle Size Requirements

RED label language requirement : All applications must be made using medium or coarser droplet size spectrum according to American Society of Agricultural and Biol ogical Engineers (ASABE) (S572) definition.

The technical registrant proposed that sulfometuron methyl product la bels be modified to require extremely coarse droplet size for all uses (> 500 Volume Median Diamet er (VMD)) according to ASABE (S572) guidelines). In its meeting with the Agency, the NAFO did not indicate that there was a specific typical drople t size spectrum for commercial fo restry uses but indicated that typical droplet spectrum size wa s indeed greater than fine to medium (100 – 250 VMD), which the Agency assumed in its 2007 ecological risk a ssessment. Various commenters indicated that

### 5 of 18 typical droplet size spectrum used in commercial forestry was greater than fine to medium and can be as large as extremely coarse. Because larger droplets result in less off target movement of a product, the requirement to increase the droplet size redu ces the Agency’s concern for sulfometuron methyl drift. Therefore, the Agen cy will modify the sulfometuron methyl label to require that all liquid applications be made using a droplet spectr um size of extremely coarse or greater. The Agency notes that dry impregnate d fertilizer is not applied through spray tip nozzles and, therefore, is considered sepa rately from requirements for liquid formulation applications.

Amendment : All applications of liquid formulation sulfometuron methyl must be made using extremely coarse droplet size (>500 VMD) or larger, according to ASABE (S572) definition.

Required Weather Conditions for Application

RED label language requirement : Applications may not be made to powdery dr y soil or light sandy soil when less than a 60% chance of rainfall is predicted to occur in the treatment area within 48 hours of application.

The Agency received comments regarding the soil characterization “light sandy soil,” noting that

this is not a soil texture class and therefore is not enforceable or helpful to applicators. However, the Agency believes that it is no t feasible from either a techni cal or practical standpoint to precisely define soil types based on textural content or organic matter content. The Agency also

believes that additional characterization can be ad ded to the label language to better describe erodible soil which may lead to offsite pesticide movement.

Amendment : Applications may not be made to soil that is subject to wind erosion when less than a 60% chance of rainfall is predicted to occur in the treatment area within 48 hours. Soils that are subject to wind erosion usually ha ve a high silt and/or fin e to very fine sand fractions. Soils with low organic matter also tend to be prone to wind erosion.

Revised Estimated Ecological Risk and Buffer Zone Requirements

The Agency’s ecological risk mitigation actions in the RED were based upon potential direct risk to aquatic or terrestrial non-ta rget plants, and potential indirect risks to animals that depend upon plants for growth, survival and reproduction (via off target drift or surface water runoff). Based upon changes to application methods, rates, and droplet size requirements, EPA revised the sulfometuron methyl ecological exposure assessment. No new data or comments were submitted that modified the Agency’s ecological hazard pr ofile for sulfometuron met hyl and, therefore, the revised ecological risk assessment of sulfometuron methyl results from changes that reduced the

estimated environmental concentrat ions and improved the overall risk picture. Overall, potential risk to non-target plants has been redu ced due to comments and proposals submitted by

stakeholders.

### 6 of 18 During the reregistration process, the Agency determ ined that suflometuron methyl uses resulted in risk quotients (RQs) that exceeded its leve l of concern (LOC), but also determined that sulfometuron methyl provides a benefit to users. Limited use information at the time of the RED indicated that sulfometuron methyl was among the top 10 chemicals used for: forestry, roadside, railroad, electric utilities, and pipeline and industrial usage (1990 data ); and California data (2001 – 2006) indicated that sulfometuron me thyl was among the top 10 chemicals for forestry/timberland use. Although no benefits data were submitted in response to the SMM RED, the volume and substance of comments i ndicating the need for SMM containing products

reflects the value of sulfometuron methyl to the user community.

RED label language requirement : For Ground Applications: Do not apply within 100 feet of aquatic vegetation (such as, but not limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, a nd commercial fish ponds, or water used as an irrigation source) and crops.

For Aerial Applications: Do not apply within 500 feet of aquatic vegetation (such as, but not limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, a nd commercial fish ponds, or water used as an irrigation source) and crops.

Through the RED, the Agency required buffer zone s of 500 feet for aerial applications, and 100 feet for ground applications. The Agency selected 500 foot buffer zones, even though unacceptable RQs were modeled 900 feet downwi nd from applications because the Agency believed requiring buffers zones gr eater than 500 feet would have gr eatly reduced the benefits of sulfometuron methyl. When considering options to mitigate the ecological risk, the Agency also considered the benefits of sulfometuron methyl, namely its efficacy at extremely low rates and, its low ecological toxicity pr ofile to other non-target organi sms. After considering these

variables in the absence of other relevant use information, th e Agency selected buffer zones of 500 feet and 100 feet respectively for aerial and gr ound applications as part of its registration eligibility decision for sulfometuron methyl (see Tables 1 and 2 below).

Table 1. Tier II AgdriftTM RQs for Aerial Applications from the RED
Distance Down wind RQs

Non-Endangered Species Endangered Species

0 10411 189293

50 3567 64848

100 2039 37071

200 978 17778

500 400 7273

750 289 5253
Input Parameters: Air Tractor (Fixed Wing Aircraft); Rate 0. 375 lb ai/A; Wind Speed 10mph; Re lease Height 10ft; Droplet Size Fine to Medium (100-250 VMD)

### 7 of 18 Table 2. Tier I AgdriftTM RQs for Gr ound Applications from the RED
Distance Down wind RQs

Non-Endang Endang

0 21233 386061

50 367 6667

100 200 3636

200 106 1919
Input Parameters: Ground Boom; Rate 0.375 lb ai/A; Wind Speed 10mph; Release Height 4.17ft; Droplet Size Fine to Very Fine (<100-175 VMD)



### Public comments regarding typical use patterns for sulfometuron methyl in commercial forestry settings, and in rights-of-way settings, has allowe d the Agency to revise application parameters that reflect actual use scenarios. Based on change s to the application parameters for these uses, the Agency has revised the estimated ecological exposure from sulfometuron methyl. Revised deposition values for commercial forestry and ri ghts-of-way uses of sulfometuron methyl are presented below in Table 3.

Table 3. Revised Tier I & II Estimated Amount of Sulfometuron Methyl Spray Drift AgDriftTM Tier II II I I

Distance Down Wind (Feet) Lb ai/A [% of app. rate] Lb ai/A [% of app. rate] Lb ai/A [% of app. rate] Lb ai/A [% of app. rate]

0 0.0327 [16.44] 0.0463 [16.47] 0.2845 [101.0] 0.2831 [101.0]

30 0.0103 [5.16] 0.0146 [5.19] 0.0050 [1.79] 0.0031 [1.09]

50 0.007 [3.52] 0.01 [3.56] 0.0034 [1.19] 0.0021 [0.74]

75 0.0048 [2.42] 0.0069 [2.47] 0.0025 [0.87] 0.0015 [0.55

100 0.0031 [1.56] 0.0045 [1.60] 0.0020 [0.70] 0.0012 [0.44]

150 0.0018 [0.90] 0.0026 [0.93] 0.0014 [0.51] 0.0009 [0.33]

200 0.0012 [0.60] 0.0018 [0.63] 0.0011 [0.40] 0.0007 [0.26]

App rate 0.199 0.281 0.281 0.281 Wind speed (mph) 10 10 Unknown 1 Unknown 1

App. height (feet) 10 10 4.17 1.67

Median droplet size (um) 519 519 341 2 341 2

Droplet size

distribution category (ASAE) Very Coarse to Extremely Coarse Very Coarse to Extremely Coarse Fine to Medium

coarse Fine to Medium

coarse

App. equipment WASP Helicopter WASP Helicopter Ground Ground

1 : value not specified in AgDRIFTTM model documentation; like ly reflects 10 mph

2 : for ground application scenarios, the AgdriftTM tier I model is restricted to using Fine to Medium coarse, and cannot model Very Coarse, which is required.

### 8 of 18 The Agency believes that the revised application requirements are in line with typical application practices of both the commercial fo restry and rights-of-way uses of sulfometuron methyl. Based upon revised RQs to non-target plan ts, the Agency is modifying the buffer zones required to mitigate ecological risk from sulfometuron methyl use.

When revising the buffer zone requirements for sulfometuron methyl, the Agency attempted to

maintain a similar risk-benefit balance that it st ruck at the time of the RED by adopting revised buffer zones with associated RQs similar to t hose regulated upon at the time of the RED. Therefore, the revised buffer zone for aerial applica tions is 75 feet (rotary craft only), 50 feet for ground (broadcast) applications, and 30 feet for hand held spot treatment applications. The Agency believes spot treatment applications pr esent less risk for off target movement than broadcast applications an d therefore have the shortest buffe r zone. Revised risk quotients for aerial, ground, and hand held applications are presented in Tables 4, 5, 6 and 7.

Table 4. Revised Tier II AgdriftTM Risk Quotients For Aerial Application (Rotary Wing) at 0.199 lb ai/A for Commercial Forestry Applications

Distance Down Wind (feet) Deposition Value RQs

Non-Endang Endang
0 0.0327 1817 33,030
30 0.0103 572 10,404

50 0.007 389 7071

75 0.0048 267 4848

100 0.0031 172 3131

150 0.0018 100 1818

200 0.0012 67 1212
Input Parameters: Wasp (Hel icopter); Rate 0.200 lb ai/A; Wind 10mph; Hei ght 10ft; Droplet Size Extremely Coarse (>450 VMD)

Table 5. Revised Tier II AgdriftTM Risk Quotients for Aerial Application (Rotary Wing) at 0.281 lb ai/A for Rights-of-Way Applications

Distance Down Wind (feet) Deposition Value RQs

Non-Endang Endang
0 0.0463 2,572 46,768
30 0.0146 811 14,747
50 0.01 556 10,101

75 0.0069 383 6,970
100 0.0045 250 4,545
150 0.0026 144 2,626
200 0.0018 100 1,818
Input Parameters: Wasp (Hel icopter); Rate 0.281 lb ai/A; Wind 10mph; Hei ght 10ft; Droplet Size Extremely Coarse (>450 VMD)

### 9 of 18 Table 6. Revised Tier I AgdriftTM Risk Quotients for Ground Application at 0.281 lb ai/A

Distance Down Wind (feet) Deposition Value RQs

Non-Endang Endang

0 0.2845 15806 287347

30 0.0050 278 5051

50 0.0034 189 3434

75 0.0025 139 2525

100 0.0020 111 2020

150 0.0014 78 1414

200 0.0011 61 1111
Input Parameters: Ground Boom; Rate 0.200 lb ai/A; Wind 10m ph; Height 4.17ft; Droplet Size Fine to Medium Coarse 4

(341VMD)

Table 7. Revised Tier I AgdriftTM Risk Quotients for Hand Held Equipment at 0.281 lb ai/A

Distance Down Down Wind (feet) Deposition Value RQs

Non-Endang Endang
0 0.2831 1573 285,959

30 0.0031 172 3131

50 0.0021 117 2121

75 0.0015 83 1515

100 0.0012 67 1212
Input Parameters: Ground Boom; Rate 0.281 lb ai/A; Wind 10mph; Height 1.67ft 3 ; Droplet Size Fine to Medium Coarse 4 (341 VMD)



### The Agency notes that for the ground applicatio n scenarios, the AgDriftTM model is limited to using “fine to medium coarse” droplet sizes (i.e., the model cannot be parameterized to reflect an extremely coarse droplet size). Since the Agen cy is requiring that a ll applications, including ground applications, use extremely coarse or coarser nozzles, the RQ’s presented in Table 6 and 7 likely overestimate risk. A summary of revised buffer zone requirements for liquid

formulations of sulfometuron me thyl is presented in Table 8.

Table 8. Summary of Revised Buffer Zone Requiremen ts for Sulfometuron Methyl (Liquid Formulation) App. Method Use Scenario Rate (lb ai/A) Buffer zone Comment Aerial (rotary craft) commercial forestry (desidous, conifer and

christmas tree plantations) 0.199 75 ft

Aerial (rotary craft) non-crop, rights of way, 0.281 75 ft Ground equipment forestry 0.199 50 ft Ground equipment non-crop rights of way, 0.281 50 ft broadcast spray equipment Hand held equipment forestry spot treatment,

non-crop spot treatment 0.281 30 ft

3 While no comments or data were received regarding the release height of non-forest ry uses of sulfometuron methyl, the Agency revised the release he ight for this scenario base upon its own research an inquiry into the rightsof-way use (such as non-crop area use by the railroad industry).

4 Limitations in the model required EPA to assume a droplet spectrum size of Fine to Medium for this scenario.

### 10 of 18 Amendment : For aerial applications to commercial forestry sites, do not apply with in 75 feet of aquatic vegetation including, but not lim ited to, lakes, reservoirs, ri vers, streams, marshes, ponds, estuaries, and commercial fish ponds, or wate r used as an irrigation source, or crops.

For aerial applications to non- forestry sites, do not apply with in 75 feet of aquatic vegetation including, but not limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds, or water used as an irrigation source, or crops.

For broadcast ground applications, do not apply w ithin 50 feet of aquatic vegetation including, but not limited to, lakes, rese rvoirs, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds, or water used as an irrigation source, or crops.

For hand held applications, do not a pply within 30 feet of aquatic vegetation including but not limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds, or water used as an irrigation source, or crops.

Revised Human Health Risk Assessment and Personal Protective Equipment (PPE) Requirements

Based upon changes to application rates for comm ercial forestry and non-crop rights-of-way uses, EPA has revised the sulfometuron methyl occupational handler risk estimates. No new data or comments were submitted that modified the Agency’s human health hazard profile for sulfometuron methyl, therefore, the revised occupati onal handler risk assessment resulted from changes that reduced the handler exposure estim ates and improved the overall risk picture.

RED Label Requirement : All mixers, loaders, applicator s and other handlers must wear: Long-sleeved shirt and long pa nts and shoes plus socks. Chemical-resistant gloves when mixing and lo ading to support aerial a pplications, and when using handheld nozzles or other handheld equipment, and chemi cal-resistant apron when mixing and loading to support aerial applications.

Some materials that are chemi cal-resistant to this product are” (registrant inserts correct chemical-resistant material). If you want more options, follow the instructions for category [registrant inserts A,B,C,D,E,F,G,or H] “on an EPA chemical-resistance category selection chart.

All liquid mixers, loaders, applicat ors, and other handlers must wear: Long-sleeved shirt and long pant s, and Shoes plus socks. Chemical-resistant gloves when mixing, load ing, and applying for low pressure hand wand.

During the reregistration process, the Agency de termined that all but two of the occupational handler exposure scenarios were not of concer n, (i.e., had Margins of Exposure (MOEs) >100) when baseline PPE was assumed (baseline PPE is defined as long shirt, long pants, shoes and socks). Table 9, which is taken from the SSM RED, presents the two dermal occupational

handler scenarios where MOEs of concern were identified at baseline PPE. To reduce the potential occupational risk, the Agency required additional PPE (gloves and an additional layer

### 11 of 18 of clothing) which increased the MOE’s (90 for water dispersible granules, and 12,000 for liquids).

Table 9. Sulfometuron Methyl Selected Occupational Scenario MOEs of Combined Dermal and Inhalation Exposure From RED (Baseline PPE) a



### No. Scenario Target App. Rate b
(lb ai/acre) Area

Treated (acres) Dermal c

MOEs Inhalation d

MOEs Combined e

MOEs

Mixer/Loaders

1 WDGs: Aerial Equipment (Fixed Wing and Helicopter) Forestry (Hardwoods, Conifers), Non-Crop Areas

(Public, Private, Military Lands) 0.38 1200 65 5600 64

Mixer/Loader/Applicators

4 Liquids: Low

Pressure

Handwand Non-Crop Areas 0.38 1 51 170000 51

a Baseline = Long pants, long-sleeved shirt, no gloves b Application rate based upon maximum labeled value. c Dermal MOE = Dermal NOAEL ( 27.5 mg/kg/day)/ ( Dermal Daily Dose [Reference W.Britton, 345025]) d Inhalation MOE = Inhalation NOAEL (27.5 mg/kg/day) / ( Inhalation Daily Dose [Reference W.Britton, 345025]) e Combined MOE = 1/((1/Dermal MOE)+(1/Inhalation MOE))



### Based on the rate reductions proposed by stakehol ders, the Agency has revised the occupational handler exposure assessment for sulfometuron met hyl for commercial forestry use, and for uses where the application rate exceeded 0.281 lb ai/A (i.e., non-crop areas, rights-of-way). Table 10 presents revised occupational exposure estimates, based on reduced applic ation rates, for these scenarios. The exposure scenario mixing/load ing/applying of liquids for low pressure hand

wand results in a combined MOE = 97 at baselin e PPE. While this expos ure scenario is of potential concern, the Agency notes that the MO E = 97 is conservative since dermal absorption is estimated at 100%, and in reality, dermal abso rption is likely much lower. Based upon these revised risk estimates, the Agency will not require additional PPE beyond baseline PPE for mixers, loaders, applicators and other handlers of sulfometuron methyl products. (A full address of revised occupational exposure and risk estimates can be found in the document: Sulfometuron methyl: Amendment to the “HED Chapter of th e Reregistration Eligibil ity Decision Documents (RED) (D346064)” which presents revised MOE’s for addi tional handler scenarios which were

not of risk concern at the time of the SMM RED.)

### 12 of 18 Table 10. Revised Sulfometuron Methyl Se lected Occupational Scenario MOEs of Combined Dermal and Inhalation Exposure (Baseline PPE) a

No. Scenario Target App. Rate b
(lb ai/acre) Area

Treated (acres) Dermal c

MOEs Inhalation d

MOEs Combined e

MOEs

Mixer/Loaders

1 WDGs: Aerial Equipment (Fixed Wing and Helicopter) Forestry (Hardwoods, Conifers), Non-Crop Areas

(Public, Private, Military Lands), Turf Unimproved 0.19 1200 120 10500 120

Mixer/Loader/Applicators

4 Liquids: Low

Pressure

Handwand Non-Crop Areas 0.28 1 97 320000 97

a Baseline = Long pants, long-sleeved shirt, no gloves b Application rate based upon maximum labeled value. c Dermal MOE = Dermal NOAEL ( 27.5 mg/kg/day)/ ( Dermal Daily Dose [Reference W.Britton, 345025]) d Inhalation MOE = Inhalation NOAEL (27.5 mg/kg/day) / ( Inhalation Daily Dose [Reference W.Britton, 345025]) e Combined MOE = 1/((1/Dermal MOE)+(1/Inhalation MOE))



### Amendment : All mixers, loaders, applicato rs and other handlers must wear: Long-sleeved shirt and long pants, and Shoes plus socks.

A revised sulfometuron methyl labe l table is attached (Table 11) to this document along with the September 2008 RED. All other mitigation measur es, label statements, and data requirements stated in the September 2008 SMM RED, not specifi cally discussed above, remain in effect. Supporting documents for the Amendment of the Sulfometuron methyl RED and submitted public comments are available in the public docket at ( EPA-HQ-OPP-2008-0129 ) at www.regulations.gov

.

The Food Quality Protection Act of 1996 mandated registration review, wh ere every 15 years the Agency reviews a pesticide to make sure that it will not cause unrea sonable risks to human

health or the environment when used as directed on product labeling. In the future, sulfometuron methyl will be reviewed again unde r the registration review program.13 of 18Table 11. Revised Summary of Labeling Changes for Sulfometuron Methyl(Changes From 2008 SMM RED Highlighted in Yellow)DescriptionAmended Labeling LanguagePlacement on LabelFor all Manufacturing UseProducts“Only for formulation into a herbicide for the followinguse(s) [fill blank only with those uses that are beingsupported by MP registrant].”Directions for UseOne of these statements maybe added to a label to allowreformulation of the productfor a specific use or alladditional uses supported bya formulator or user“This product may be used to formulate products for specific use(s) not listed on the MP label if theformulator, user group, or grower has complied with U.S. EPA submission requirements regarding supportof such use(s).”“This product may be used to formulate products for any additional use(s) not listed on the MP label if theformulator, user group, or grower has complied with U.S. EPA submission requirements regarding supportof such use(s).”Directions for UseEnvironmental HazardsStatements Required by theRED and Agency LabelPolicies"Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or otherwaters unless in accordance with the requirementsof a National Pollution Discharge Elimination System(NPDES) permit and the permitting authority has beennotified in writing prior to discharge. Do notdischarge effluent containing this product to sewer systems without previously notifying the local sewagetreatment plant authority. For guidance contact your State Water Boardor Regional Office of the EPA."Precautionary StatementsEnd Use Products Intended for Occupational UsePPE RequirementsEstablished by the REDfor WDGFormulations“Personal Protective Equipment (PPE)”“Some materials that are chemical-resistant to this product are” (registrant inserts correct chemical-resistantmaterial). “If you want more options, follow the instructions for category”[registrant insertsA,B,C,D,E,F,G,or H] “on an EPA chemical-resistance category selection chart."“All mixers, loaders, applicators and other handlers must wear:Long-sleeved shirt and long pants, and Shoes plus socks.”See engineering controls for more requirementsImmediately following/belowPrecautionary Statements: Hazardsto Humans and Domestic Animals14 of 18PPE RequirementsEstablished by the REDFor LiquidFormulations“Personal Protective Equipment (PPE)”“Some materials that are chemical-resistant to this product are” (registrant inserts correct chemical-resistantmaterial). “If you want more options, follow the instructions for category”[registrant insertsA,B,C,D,E,F,G,or H] “on an EPA chemical-resistance category selection chart."“All liquid mixers, loaders, applicators, and other handlers must wear:Long-sleeved shirt and long pants, and Shoes plus socks.”Immediately following/belowPrecautionary Statements: Hazardsto Humans and Domestic AnimalsUser Safety Requirements“Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washablesexist, use detergent and hot water. Keep and wash PPE separately from other laundry.”“Discard clothing and other absorbent materials that havebeen drenched or heavilycontaminated with thisproduct’s concentrate. Do not reuse them.”Precautionary Statements: Hazardsto Humans and Domestic Animalsimmediately following the PPErequirementsEngineering Controlsfor WDG and Granularformulations that permitaerial application“Pilots must use an enclosed cockpit in a manner that is consistent with the WPS for Agricultural Pesticides[40 CFR170.240(d)(6)].”Precautionary Statements: Hazardsto Humans and Domestic Animals(Immediately following PPE andUser Safety Requirements.)User SafetyRecommendations“User Safety RecommendationsUsers should wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet.Users should remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put onclean clothing.Users should remove PPE immediately after handling this product. Wash the outside of gloves beforeremoving. As soon as possible, wash thoroughly and change into clean clothing.”Precautionary Statements under:Hazards to Humans and DomesticAnimals immediately followingEngineering Controls(Must be placed in a box.)15 of 18Environmental Hazards“For terrestrial uses, exceptfor under the forest canopy: Do not applydirectly to water, or to areas wheresurface water is present or to intertidal areas below the mean high water mark. Do not contaminate waterwhen disposing of equipment washwater or rinsate."“Exposure to (Brand Name) can injure or kill plants. Damage to susceptible plants can occur when soilparticles are blown or washed off target onto cropland.Applications may not be made to soil that is subject to wind erosion when less than a 60% chance of rainfallis predicted to occur in the treatment area within 48hours. Soils that are subject to wind erosion usuallyhave a high silt and/or fine to very fine sand fractions. Soils with low organic matter also tend to be prone towind erosion.”Precautionary Statementsimmediately following the UserSafety RecommendationsRestricted-Entry Interval forproducts with directions foruse within scope of theWorker Protection Standardfor Agricultural Pesticides(WPS)Basic REI Statement for all crops:“Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 4 hours.”Directions for Use, UnderAgricultural Use Requirements BoxEarly Entry PersonalProtective Equipment forproducts with directions foruse within the scope of theWPS“PPE required for early entry to treated areas that is permitted under theWorker Protection Standard and thatinvolves contact with anything that has beentreated, such as plants, soil, or water, is:* coveralls,* shoes plus socks, and* chemical-resistant gloves madeof any waterproof material”Direction for UseAgricultural Use Requirements boxEntry Restrictions forproducts havingoccupational uses on thelabel not subject to the WPSEntry Restriction for non-WPSuses applied as a spray:“Do not enter or allow others to enter until sprays have dried.”Entry Restriction for non-WPS uses applied dry:“Do not enter or allow others to enter until dusts have settled.”If no WPS uses on the productlabel, place the appropriatestatement in the Directions for UseUnder General Precautions andRestrictions. If the product alsocontains WPS uses, then create aNon-Agricultural Use Requirementsbox as directed in PR Notice 93-7and place the appropriate statementinside that box.General ApplicationRestrictions“Do not apply this product in a way that will contactworkers or other persons, either directly or throughdrift. Only protected handlers maybe in the area during application.”Place in the Direction for Usedirectly above the Agricultural UseBox.16 of 18Application RestrictionsThe following risk mitigation measures mustbe reflected in the directions for use:New maximum application rates for all formulations:Forestry (Including Deciduous, Conifers, Christmas Trees):0.199 lb ai/A/applicationNon-Agricultural Rights of Way:0.281 lb ai/A/applicationPlace in the Directions for Useunder Application Instructions forEach Crop.Other ApplicationRestrictions (RiskMitigation)“Applications may not be made to soil that is subject to wind erosion when less than a 60% chance of rainfallis predicted to occur in the treatment area within 48hours. Soils that are subject to wind erosion usuallyhave a high silt and/or fine to very fine sand fractions. Soils with low organic matter also tend to be prone towind erosion.”Directions for Use17 of 18Spray DriftDroplet Size“Applications must be made using extremely coarseor coarser droplet sizespectrum according to ASABE(S572) definition.”Wind Direction and Speed“Do not apply when wind speed is greater than 10 mph.”Temperature Inversion“Do not make aerial or ground applications into temperature inversions.”“Inversions are characterized by stable air and increasing temperatures with height above the ground. Mistor fog may indicate the presence of aninversion in humid areas. The applicator may detect the presence ofan inversion by producing smoke and observing a smoke layer near the ground surface.”Additional Requirements for Ground Applications“For ground boom applications, apply spray at lowest height that is consistent with pest control objectives tominimize drift.”Additional Requirements for Aerial Applications“Spray must be released at the lowest height consistent with pest control objectives and flight safety.”“The spray boom should be mounted on the aircraft as to minimize drift caused by wingtip or rotor vortices.The minimum practical boom length should be used and must not exceed 75% of the wing span or 80% rotorblade diameter.”“Flight speed and nozzle orientation must be considered in determining compliance with the allowabledroplet size spectrum.”“When applications are made with a cross-wind, the swath will be displaced downwind. The applicator mustcompensate for this displacement at the downwind edge of the application area by adjusting the path of theaircraft upwind.”Directions for Use18 of 18Buffer Zone RequirementsFor Ground Applications:“For broadcast ground applications, do not apply within 50 feet of aquatic vegetation (including, but notlimited to, lakes, reservoirs, rivers, streams, marshes,ponds, estuaries, and commercial fish ponds), or waterused as an irrigation source, or crops.”“For hand held spot treatment applications, do not apply within 30 feet of aquatic vegetation (including, butnot limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds), orwater used as an irrigation source, or crops.”For Aerial Applications:“Do not apply liquid formulations of [insert product] with fixed wing aircraft. Liquid formulations of [insertproduct] must be applied via rotary aircraft.”“Do not apply within 75 feet of aquatic vegetation (including, but not limited to,lakes, reservoirs, rivers,streams, marshes, ponds, estuaries,and commercial fish ponds), or water used as an irrigation source, orcrops.”Directions for Use under GeneralPrecautions and Restrictions and/orApplication Instructions