UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D
.C

. 20460 

### SEP 25 2014

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION 

### MEMORANDUM SUBJECT:
FROM:

THRU:

TO: BEAD Response to DowAgroSciences Comments on Chemical Profile and Label Use Reports for the Clopyralid Case (117401, 117403, 117404, and 117423) Sunil Ratnayake, Biologist 

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_ t_**~** Biological Analysis Branch

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. . Sepehr Haddad, 

### Envirorunental Protection

# Specialist~-ju**1~** Science Information and Analysis Branch Stephen Smearman, Economist

## ~ Economic Analysis Branch Biological and Economic Analysis Division (7503P) AmetJones, Chief 

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# -;T""**~** Biological Analysis

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# J , Diann Sims, Chief

# Jil~ Science Information and Analysis Branch Timothy Kiely, Chief

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# ~ Economic Analysis Branch V v '-- Biological and Economic Analysi Division (750 Steve Snyderman, Chemical ReviewManager Pesticide Re-evaluation Division (7508P)


### PeerReview Panel date: September23, 2014 BEAD has reviewed the comments provided by DowAgroSciences, (Submissionto DocketNo. EPA-HQ-OPP-2014-0167, dated May 26th, 2014). We appreciated the comments from the registrant. Our responses are as follows:Registrant Comment: Clopyralid is not labeled for use in alfalfa, almonds, beans, chestnuts, filberts, lentils, macadamia nuts, peas, pecans, pistachio nuts, potatoes, safflower, sorghum, soybeans, sunflowers, and walnuts. All references to non-labeled crops should be removed from the documents.EPA Response: Thankyou for your response. All appropriate changes have been made to the BCP to reflect only registered use sites, and a revised version ofthe BCP will be placed in the docket. Registrant Comment: The statement onp.8 ofthe BCP that ithas been reported that biotypes of 9 weed species have developed resistance to clopyralid is incorrect. EPA Response: BEAD agrees withthe registrant statement that the number of weeds with resistance to clopyralid onpage no. 8 ofthe BCP is incorrect. The statement onpage 8 underthe Biological Aspects Relevant to Clopyralid will be revised to reflect that clopyralid belongs to the Group 

### 0 herbicides (HRAC classification) and according to the International Survey ofHerbicide Resistant Weeds, biotypes of8 weed species have developed resistance to the mode of action ofGroup 

### 0 herbicides inthe United States. However, no reports could be found onthe development ofweed resistance, specificallyto clopyralid inthe United States. Registrant Comment: EPA registration number 62719-570 Surestart Max labeled rate is 3.5 ptnot 3 pt as perHED document. The normal rate at 3pt/acre should equal 0. 1425 lb ai /a (not 0.149lb ai/a). The max rate at 3.5 pt/acre should equal 0.166lb ai/a (0.126lb ae/a) EPA Response: The HED Label Report and the EFED Label Report reflect different purposes and focus ondifferent aspects ofa chemical'suse pattern. The HED Label Report Document only lists the maximum single application rate, which is 3 pt/acre, for the purpose ofoccupational risk assessments. The registrant is correctthat the maximum seasonal labeled rate, which is an important parameter in ecological risk assessments, is 3.5 pt and that is reflected inthe EFED Label Report Document. Registrant Comment: EPA registration number 62719-315 Hornet WDG The max rate for use in corn is 0.187lb ai/a when using Hornet WDG. Note: there is a further restriction for the use ofclopyralid onfield corn whenother products containing clopyralid are used inthe same season onfield corn. The maxuse rate is 0.25 lb ae/a. EPA Response: The registrant is correctthat the max rate for corn is 0.187 lb a.i./a. The other lower rate shown (2 ounces/acre) is for field corn grown for silage only inNew York State per the label.

Page2Registrant Comment: EPA registration number 62719-262 TURF FERTILIZER CONTAINS CONFRONT Note that 0.75 lb/ a.i listed as the heavy rate ofuse is actually a combinedrate for both active ingredients triclopyr and clopyralid. Itis notthe use rate ofclopyralid alone. EPA Response: EPA appreciates the clarification. The rates for this registration are capturedperthe label directions. No changes to thereport are needed. Registrant Comment: EPA registration number 62719-86 Curtail M Maxuse rate inflax is 0.85 pt. per acre (not 1.75 pt. acre) EPA Response: The max use rate for this product appears on the report as 0.85 pt. peracre, as noted. The 1.75 pt. per acre rate is associated withthe SLN ND090003, whose parent label is 62719-86. Thus, both products have the same name, Curtail M, but different registration numbers. No changes to report are required. · Registrant Comment: EPA registration number 62719-259 Transline REI specified onlabel is 12 hours (sheet indicates NS). EPA Response: BEAD agrees that 12 hour REI should appear in the report rather thanNS and will.make the necessary changes to the affected reports. Registrant Comment: EPA registration number 62719-259 Transline Cottonwood and Poplar canreceive a rate up to 1.33 pt/acre per season; ''Apply at a rate of 1/3 to 1 113 pints/acre in eucalyptus tree plantations and 1/3 to 2/3 pints/ acre in cottonwood/poplar plantations. Sequential applications may be made as long as the total rate per annual use season does not exceed 1 113 pints per acre'' EPA Response: The clarification is appreciated. However, the label for registration number 62719-259 is not explicit in its language on the number of applications peryear, hence the NS inthe reports. The same label statementwas used to capture the total rate perannual use season of 1.33 pt/a. "Sequential applications maybe made as long as the total rate perannual use season does not exceed 1 1/3 pints per acre". No changes to report are required.

Page 3Registrant Comment: EPA registration number 62719-645 Sendaro (GF-2791) The Aquatic food use site ''SWAMPS/MARSHES/WETLANDS/STAGNANT WATER'' is not labeled for Sendaro and is not appropriate for a product containing clopyralid. The max rate at 1.75 pt/acre should equal 0.66 lb aila (0.5 lb ae/a). This equates to the highest use rate of clopyralid for food uses. EPA Response: According to the label language, it is permissible to treat nonirrigation ditch banks, seasonally dry wetlands (such as flood plains, deltas, marshes, swamps, orbogs) and transitional areas betweenupland and lowland sites. Sendero can be used to the water's edge. We are aware ofthat directions that the a.i. is notto be applied directly to water and to take precautions to minimize spray drift onto water. These precautions are captured inthe issues statements that accompany the report. No changes to report are required.

REFERENCES EPA 2013, BEAD Chemical Profile (BCP) for Registration Review: Clopyralid Case (117401, 117403, 117404, and 117423) DowAgroSciences, 2014 (Submissionto DocketNo. EPA-HQ-OPP-2014-0167), dated May 26th,2014

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