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Information Requests Monitoring System

Request ID: 148
Request From: Steve Toth
Date Requested: Mar 10, 2006
Request: Note the following request for information on proposed use rates and intervals for permethrin-registered crops. Please send to your specialists and stakeholders and submit any responses directly to me by e-mail or send to the Southern Region IPM Center Information Requests Monitoring System. Thanks. Steve Toth ---------------------------------- I know it is a quick turn around on this one but I just received the notice. All that is needed are comments on the proposed rates, etc. mentioned in the attached table. Please send this out to those commodities affected and send comments back to Jacqueline Querry at EPA: Guerry.Jacqueline@epamail.epa.gov This table was put together by the registrants and I include the original notice. Please respond by March 16th. I apologize for the short turn around time. Wilfred Wilfred, The permethrin registrants have proposed a number of reductions in application rates and number of applications. I am forwarding their e-mail and attached proposal for review. Chris Davis from FMC has contacted IR4 and asked them to contact their stakeholders to see if these proposed reductions are acceptable. The IR4 point of contact is Keith Dorschner. Please let me know you thoughts, and if you feel additional outreach to any grower group is warranted. Thank you, Jacqueline Guerry Chemical Review Manager Special Review and Reregistration Division, RB3 (703) 305-0024 Rm. 604W34 Dear Jacqueline, Attached is an updated spreadsheet of proposed use rates and intervals for permethrin crops. Both United Phosphorous and FMC are in agreement on all of the proposed rates per application, retreatment intervals and maximum seasonal rates shown in the table. Chris Davis at FMC will be forwarding the spreadsheet to IR4 for their review and comment. Let me know if you have any questions on the spreadsheet. Regards, Jim Wagner (SynTech) Consultant to UPI tel 302 234 8550 fax 302 234 7570 (See attached file: Permethrin proposed use rates and intervals Mar 6, 2006.xls) Wilfred Burr USDA/OPMP 1400 Independence Ave. SW Washington, DC 20250-0315 202-720-8647

Responses
Responder: Darrell Hensley
State: KY
Date Requested: Mar 13, 2006
Response: Response forwarded from Ric Bessin at UKY. Darrell, We could get by with the new restrictions, as there are many alternatives, inlcuding numerous pyrethroids. One problem I have with this is that they still maintain different use rates on differents crops within the crop groupings. It would streamline educational programs if there was just one rate within the fruiting vegetables! Ric Bessin

Responder: Mark Mossler
State: FL
Date Requested: Mar 13, 2006
Response: In reviewing our FL crop profiles, there are four commodities for which we would like to see higher seasonal maximums. These are: Avocado (proposed 0.6 – would like 0.8) Watermelon (proposed 0.75 – would like 0.9) Celery (proposed 0.6 – would like 1.0) Papaya (proposed 0.45 – would like 0.75)

Responder: Darrell Hensley
State: TN
Date Requested: Mar 14, 2006
Response: see attached file submitted to Darrell Hensley from PictSweet
Attachment included in response [Download]

Responder: Mark Mossler
State: PR
Date Requested: Mar 14, 2006
Response: Proposed modifications to rates are acceptable but would like the seasonal maximums proposed by FL.

Responder: Mark Mossler
State: VI
Date Requested: Mar 14, 2006
Response: Proposed modifications to rates are acceptable but would like the seasonal maximums proposed by FL.

Responder: Charles Luper
State: OK
Date Requested: Mar 14, 2006
Response: According to Dr. Phil Mulder the rates are fine for Peaches and Alfalfs in Oklahoma.

Responder: Charles Luper
State: OK
Date Requested: Mar 14, 2006
Response: I also recieved a Response from William Russell at Allen Canning Company on the rate changes especailly on spinach, turnips, and collards. Please note his response below. Charles Luper and other state and federal agencys. During the last 10 years, since the inception of the FQPA act the vegetable industry has been losing the use of many insecticides. Also a few newer insecticides have been added to the list for vegetable growers. The problem with the newer chemistry is that it works on specific insects and is narrow in its spectrum. Examples are Provado (mostly aphids), Spintor and Intrepid (mostly lep larvae), and any of the Organo-Phosphates that are still labeled have PHI's that are too long to accomidate the narrow harvest windows required today to insure a insect free product. Permethrin currently has a 1 day PHI and an apply as needed allowance on the label. It is critical to continue to have this option in spinach, turnips, and collards. Without this option for pest control near harvest growers of these crops would be put in jeperdy of losing the crops due to excessive cntamination from insects such as grasshoppers, moths, and various beetles. Finally, USDA has establised limits on how many insect parts can be present in finished products, as metioned above, and these standards could not be acheived with the proposed changes. If you neen more info please contact me at 4792280068 William Russell [WRussell@allencanning.com]

Responder: Tom Kuhar
State: VA
Date Requested: Mar 15, 2006
Response: I looked over the proposed rate changes for permethrin. For vegetables at least, I don't see a major problem. There are so many pyrethroids now as well as alternative chemicals. As far as I know, the few vegetable crops that have only permethrin labeled as a pyrethroid, such as asparagus, do not need more than 1 or 2 sprays per season. Tom Kuhar Virginia Tech University

Responder: Darrell hensley
State: TN
Date Requested: Mar 15, 2006
Response: Darrell, I have not had time to look over the extensive permethrin proposed use rates. I did look into three crops brought to our attention by William Russell in which he makes the case that in the processed vegetable industry, insecticides are needed to kill a wide range of incidental and pest insects just prior to harvest. Without such insecticides, I agree with Mr. Russell that too many insects and insect parts would be found in the produce, making it worthless for processing. While Mr. Russell leaves the reader with the impression that there are no substitutes for permethrin in these crops, actually there are some for each of the three crops. The pyrethroids that I list should provide the broadest level of pest control just prior to harvest and thus should be the most important. Currently on spinach, permethrin is labeled with a one day PHI while two other pyrethroids, cyfluthrin (Baythroid 2) and B-cyfluthrin (Baythroid XL), are labeled with a zero day PHI. On turnips we also have Baythroid 2 and Baythroid XL with a zero day PHI plus two other insecticides, naled (Dibrom) and spinosad (SpinTor), both with a one day PHI. On collards, we have the pyrethroids Baythoid 2 and Baythroid XL with a zero day PHI and zetacypermethrin (Mustang Max) with a one day PHI. In addition, on collards we have SpinTor with a one day PHI and Dibrom with a one day PHI. There may be other insecticides of which I am not aware. While permethrin is valuable with its one day PHI, there are other pyrethroids available to serve the same purpose on these three crops. If there are no alternatives to permethrin on other crops that require a short PHI, then it would be a hardship to growers of these crops to increase the PHI at this time. Regards, Frank A. Hale, PhD Professor Entomology and Plant Pathology University of Tennessee Extension 5201 Marchant Drive Nashville, TN 37211-5112 (615) 832-6802 fax (615) 781-2568 fahale@utk.edu

Responder: Darrell Hensley
State: TN
Date Requested: Mar 15, 2006
Response: March 13, 2006 Darrell D. Hensley University of Tennessee Entomology & Plant Pathology 2431 Joe Johnson Dr., 218 PSB. Knoxville, TN 37996-4560 Dear Darrell, I am responding to an information packet you sent regarding proposals by FMC and United Phosphorus, Inc. that would make label changes for the use of Permethrin on certain minor use crops. These changes involve labeled rates, re-application intervals, and maximum allowances per season. The crops we produce that were included in this packet are spinach, turnip greens, collards, and squash. My biggest concern with these proposals is the “Retreatment Interval”. Turnip greens are a 30-35 day crop and Permethrin is the only labeled pyrethroid. If the product is only labeled for an application every 15 days, we will struggle to achieve the insect control that would meet our quality requirements. Because of other pest control options, turnip greens would be impacted much greater than the other crops listed. Annually, we will grow 2,000-2,500 acres of greens. With that being said, I cannot emphasize enough the negative impact this would have on our company. If there were other pest control options, we could possibly manage the issue. However, there are none. I’m not exactly sure of the motives behind these proposals, but with proper communications, they could possibly be resolved to the benefit of everyone. Please let me know what I can do to be of assistance. Sincerely, Steve Little Mgr., Farm Operations The Pictsweet Company

Responder: Jack Bacheler
State: NC
Date Requested: Mar 15, 2006
Response: The table must only refer to feed/food uses - cotton is not in the table. We use quite a lot of permethrin on cotton as it's often available in bulk through brokers. Cotton seed is sometimes used for livestock feed, although it didn't make the list in the attachment. Jack Bacheler Extension Entomologist (Cotton) North Carolina State University

Responder: Jack Bacheler
State: NC
Date Requested: Mar 15, 2006
Response: The proposed rates and intervals are fine for field corn and soybeans. Jack Bacheler Department of Entomology North Carolina State University

Responder: Steve Bambara
State: NC
Date Requested: Mar 15, 2006
Response: Regarding alfalfa, I don't have any knowledge whether these rates are good or bad. They look fairly standard for forage crops. Two applications per cutting is generally plenty for any chemical. Steve Bambara Extension Entomologist (Small Grains) North Carolina State University

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