Information Requests Monitoring System

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Request ID: 152
Request From: Steve Toth
Date Requested: Apr 07, 2006
Request: Please note the following request from EPA and USDA for feedback on proposed changes in malathion uses. They are asking a lot with this request and need any feedback by April 27. Please circulate the attached pdf file to your experts and submit any responses to the Southern Region IPM Center Information Requests Monitoring System by April 27, 2006. Thanks. Steve Toth ------------------------------------------ Dear Colleagues: USDA is assisting EPA in soliciting feedback on needed application rates, numbers of applications, minimum days between applications, and needed reentry intervals for malathion. While EPA's proposed values could change, we need to know your feedback now as to whether the currently proposed values will meet the pest needs of your crop. If the proposed values do not meet the needs of your crop, please provide us what you believe is necessary . EPA's instructions are contained in the cover letter. We have been through a number of discussions already for many of these crops but we are continuing to refine our numbers. Additional tox data will be folded in after we receive your input on the proposed values. The tables only pertain to EC and WP formulations. A table on ULV uses will be sent out shortly. Because EPA must complete all tolerance reassessments by August 2006, as required by the Food Quality Protection Act, we need your feedback by April 27. A three week time frame makes an allowance for those who take an Easter recess because of school kids. Please forward this request also to those who will also be interested in filling this out. Email or fax back your responses. We apologize with the complexity of this request due to the many crops involved. EPA plans to issue the malathion Reregistration eligibility decision (RED) relatively soon after receiving your feedback. A 60 day comment period following the publication of the RED can be used to address overlooked grower needs. Please do not hesitate to contact me if you have any questions. I will be on travel from April 17 to 24. Many thanks in advance! Teung F. Chin, Ph.D. Biological Scientist Office of Pest Management Policy Agricultural Research Service United States Department of Agriculture LOCATED AT: USDA Animal & Plant Health Inspection Service 4700 River Road, Unit 149 (Room 3D-06.8) Riverdale, MD 20737-1237 Phone (301) 734-8943 Fax (301) 734-5992 Teung.F.Chin@usda.gov http://www.ars.usda.gov/opmp

Responses
Responder: Tom Kuhar
State: VA
Date Requested: Apr 11, 2006
Response: I don't see these proposed regulations having very much of an impact on vegetable production in Virginia. I can't tell you a single vegetable crop that I've been aware of a grower spraying malathion on.

Responder: Rod Youngman
State: VA
Date Requested: Apr 17, 2006
Response: I looked over the document with regard to my commodity responsibilities, which include alfalfa, field corn, grass hay and pasture. 1. EPA has proposed no changes for 'Alfalfa" and 'Grasses (i.e., Bermuda, forage)'. 2. The proposed EPA change for field corn is minor and should not pose a problem for farmers. 3. For 'Hay, other', there is nothing in the table except the proposed REI change from 12-24 hours. Also, I'll need some clarification with the following text under the 'Notes' section: "EPA requests additional information on typical application rates on malathion applications to hay." I suspect hay farmers would typically make no more than 2 applications per growing season, with most averaging from 0-1. 4. For 'Pasture and Rangeland', my comments are similar to what I wrote for number '3'; and since farmers average 1.2 applications per growing season, I suspect the proposed change from 2-1 applications per growing season would not pose a significant burden for them. Again, I'm not sure what EPA/you want in regard to text under 'Notes' section.

Responder: Rod Youngman
State: VA
Date Requested: Apr 17, 2006
Response: I looked over the document with regard to my commodity responsibilities, which include alfalfa, field corn, grass hay and pasture. 1. EPA has proposed no changes for 'Alfalfa" and 'Grasses (i.e., Bermuda, forage)'. 2. The proposed EPA change for field corn is minor and should not pose a problem for farmers. 3. For 'Hay, other', there is nothing in the table except the proposed REI change from 12-24 hours. Also, I'll need some clarification with the following text under the 'Notes' section: "EPA requests additional information on typical application rates on malathion applications to hay." I suspect hay farmers would typically make no more than 2 applications per growing season, with most averaging from 0-1. 4. For 'Pasture and Rangeland', my comments are similar to what I wrote for number '3'; and since farmers average 1.2 applications per growing season, I suspect the proposed change from 2-1 applications per growing season would not pose a significant burden for them. Again, I'm not sure what EPA wants in regard to text under 'Notes' section.

Responder: Charles Luper
State: OK
Date Requested: Apr 24, 2006
Response: Dr. Phil Mulders response below other than grapes all other crops grown in Oklahoma no real concern over the changes. Charles, I have one comment about the need for an REI that is longer than the PHI. This does not seem right, but that is what they are suggesting for grapes, a crop that needs regular work to be done. They have a 3 day PHI and a 5 day REI. This is too long in grapes. I can understand this is some of the other crops if there is a 7 day PHI and a 4 day REI, like pecan but for grapes this is not wise.

Responder: Mark Mossler
State: VI
Date Requested: Apr 27, 2006
Not Important/Relevant to my state(s)
Response:

Responder: Mark Mossler
State: PR
Date Requested: Apr 27, 2006
Not Important/Relevant to my state(s)
Response:

Responder: Mark Mossler
State: FL
Date Requested: Apr 27, 2006
Response: Please see attached Word file.
Attachment included in response [Download]

Responder: Mark Matocha
State: TX
Date Requested: Apr 27, 2006
Response: According to Dr. Noel Troxclair, the proposed changes for malathion in peaches should not have significantly adverse effects for the Texas Wintergarden production area.

Responder: Tom Kuhar
State: VA
Date Requested: Apr 27, 2006
Response: I don't see these proposed regulations having very much of an impact on vegetable production in Virginia. I can't tell you a single vegetable crop that I've been aware of a grower spraying malathion on. Tom Kuhar Virginia Tech University

Responder: Jack Bacheler
State: NC
Date Requested: Apr 27, 2006
Response: No present uses of malathion on cotton in NC. However, continued registration on cotton could be very important if boll weevils became reestablished. (Some state containment programs are increasingly being managed sloppily and on the cheap.) Jack Bacheler Extension Cotton Entomologist North Carolina State University

Responder: Roy Parker
State: TX
Date Requested: Apr 27, 2006
Response: I think the listed number of malathion applications for grasses (bermuda, forage) and pasture/rangeland should be two per year to possibly take care of a reoccurring problem with several insects to include grasshoppers, armyworms, etc. In most cases ULV malathion is used for which we evidently get to comment on at a later date; however, the EC formulation is used with ground application equipment. Roy Parker Texas A&M University

Responder: Darrell Hensley
State: TN
Date Requested: Apr 27, 2006
Response: Please see the attached file for the response concerning malathion usage in Tennessee. Darrell Hensley University of Tennessee
Attachment included in response [Download]

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