Information Requests Monitoring System

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Request ID: 179
Request From: Steve Toth
Date Requested: Oct 12, 2007
Request: Please note the "heads up" on the aldicarb 60-day comment period from Teung Chin. A list of crops that could be impacted are provided below. Attached are proposed crop-specific mitigation measures for aldicarb. This will hopefully give you extra time to contact the stakeholders and experts in your respective states/territories to determine if a response is neccessary. ------------------------------------------------- Dear Colleagues: We are sending this to you before the Federal Register Notice is published to provide you additional time should you wish to prepare comments. Pesticide information Request Active ingredient: aldicarb Crops/Target sites: Alfalfa, Dry Beans/Peas, Citrus (Grapefruit, Lemons, Oranges), Coffee (imported), Cotton, Peanuts, Pecans, Potatoes, Sorghum, Soybeans, Sugar Beets, Sugarcane, Sweet Potatoes, Tobacco Respond to: EPA Public Docket. (I will alert you when the FR Notice is published in 2 - 3 weeks). Deadline: 60 day comment period for the RED will begin in 2 - 3 weeks following publication in the Federal Register. ************************************** Background and additional information: On September 26, 2007 EPA posted the RED for aldicarb. Public comments on the risk assessment must be received by the EPA Public Docket 60 days following publication in the Federal register. Attached below is a summary of the cancelled uses, geographic restrictions and final labelling changes. Cancelled uses are: coffee, ornamentals, pecans, sugarcane, sorghum, tobacco, alfalfa grown for seed Risk management decisions were driven primarily to reduce ecological risk concerns to birds, mammals, fresh water and marine fish and invertebrates. For peanuts, drinking water concerns were of concern. Comments and benefits information may be submitted to appeal the decision for those canceled uses and label changes. Please provide as much detail and documentation in your comments as possible so that the Agency is fully informed in its decision-making. For more information: See attached file: Aldicarb-RED-mitigation-final-label-Sept-2007 The 191 page RED also may be reviewed at: http://www.epa.gov/pesticides/reregistration/REDs/aldicarb_red.pdf Contact: Teung.F.Chin@aphis.usda.gov Teung F. Chin, Ph.D. Office of Pest Management Policy Agricultural Research Service 4700 River Road, Unit 149 (Room 3D-06.29) Riverdale, MD 20737-1237 Phone (301) 734-8943 Fax (301) 734-5992 http://www.ars.usda.gov/opmp

Responses
Responder: Darrell Hensley
State: TN
Date Requested: Oct 15, 2007
Response: For Soybeans and Cotton Dr. Scott Stewart sent the following email ====================== Darrell, I've already had the opportunity to provide input on the proposed changes of Temik use for cotton and soybean via Bayer and Bayer/EPA. I believe these "mitigations" are acceptable and do not pose a significant burden to growers. Regards, Scott Scott D. Stewart, IPM Specialist West TN Research and Education Center 605 Airways Blvd, Jackson, TN 38301 Phone: (731) 425-4709 Fax: (731) 425-4720 Mobile (731) 267-6085 Email: sdstewart@utk.edu Web: www.utcrops.com

Responder: Holly Gatton
State: VA
Date Requested: Oct 19, 2007
Response: From an email submitted by Dr. Paul Semtner:
I am writing concerning the proposal to withdraw the tobacco label for aldicarb (Temik). From an insect control standpoint, it is not as important as it was between 1981 and 1996 when it was one of the most important systemic soil insecticides used for aphid control on tobacco. The tobacco-adapted form of the green peach aphid is potentially the most serious pest of tobacco in Virginia, causing yield losses of 30% or more in some years. Admire, a neonicotinoid insecticide, was registered for aphid, flea beetle, and wireworm control on tobacco in 1996. After its registration, tobacco farmers in Virginia quickly adopted Admire for aphid control on tobacco. This change greatly reduced Aldicarb use on tobacco in Virginia. Although the neonicotinoids are currently widely used on tobacco, Aldicarb still has a place in an insect management program on tobacco. When Aldicarb is applied for nematode control, it controls both aphids and nematodes so the need for aphid control with another insecticide such as Aldicarb or Orthene is greatly reduced. The potential that the green peach aphid may become resistant to the neonicotinoids is another concern. The number of alternatives to the neonicotinoids for aphid control on tobacco is declining rapidly. The label for endosulfan is being discontinued, Aldicarb is threatened, and Orthene (acephate) is being banned on tobacco in Europe. If these products are lost, only one nonneonicotinoid insecticide will be available for use in resistance management programs to control aphids on tobacco.

The most important reason for keeping the Aldicarb label on tobacco is that it is the only effective contact nematicide still registered for this purpose in Virginia. Contact nematicides are less expensive to apply for nematodes than fumigant nematicides, the only chemical alternatives for nematode control. It is probably less hazardous to apply than the fumigants due to the closed Lock and Load system used to apply Aldicarb. The use of contract nematicides appeals to small farmers because equipment costs and the cost of the treatments are lower. In addition, tobacco can be transplanted 2 days after applying Aldicarb compared with a 3-week pretransplanting period for the soil fumigants. In 2007, over 10% of the flue-cured tobacco acreage in Virginia was treated with Aldicarb.

It is critical that Aldicarb continue to be available as an option to soil fumigants for nematode control and for aphid control aphids on tobacco.

Paul J. Semtner
Professor, Entomology
psemtner@vt.edu
Phone: 434-292-5331 Ext. 224
Fax: 434-292-5623

Responder: Holly Gatton
State: VA
Date Requested: Oct 22, 2007
Response: From an e-mail submitted by Dr. Charles Johnson:
Holly:
Dropping tobacco from the Temik label would be a major loss for tobacco farmers in Virginia, and I am sure for growers in North Carolina as well (Mina Mila at NCSU would be the source). With the loss of Nemacur at the end of this year, Temik will constitute the only registered non-fumigant nematicide available to tobacco producers. Growers, especially part-time and small acreage, limited resource farmers, tend to prefer applying Temik for nematode control rather than fumigating. I think the reasons for this are due to fear of fumigants, the cost of fumigants and fumigation equipment, the much longer reentry and planting intervals after soil fumigation versus Temik application, etc. We also seem to be detecting increasing problems with lesion and root-knot nematodes on tobacco in some areas of Virginia. One of our prominent hypotheses regarding this apparent change is that these growers quit using Temik for aphid control (with the advent of the neonicotinoid insecticides), and the populations of these nematodes have been gradually increasing so that they have been reaching economic threshold levels over the past several growing seasons. We have discussed fumigation with these producers, and many are reluctant to fumigate. Losing Temik would really be a blow.

Both Paul Semtner and myself attempted to make these or similar points in telephone conversations with Dr. Chin of EPA several months ago. At that time he indicated some proposed changes in application methods that I opposed, but I understood no intention to cancel the use. I assumed that these conversations should be sufficient, but apparently that wasn't the case. Dr. Semtner has contacted Bayer to find out more specifically what the thinking was on the 24c tobacco-Temik label, at least from the registrant. However, we are both opposed to this change and should be willing to do whatever is appropriate to inform the appropriate decision-makers regarding our position and justifications. We can certainly do our best to obtain additional information regarding Temik use on tobacco in Virginia, and could inform grower groups of the impending change for their input on the subject.

Thanks for the information!

Chuck

Responder: Mark Mossler
State: FL
Date Requested: Oct 26, 2007
Response: The inclusion of the citrus group rather than just orange and grapefruit will help FL growers with the citrus psyllid/greening problem. All other metrics are acceptable to Florida growers.

Responder: Mark Mossler
State: VI
Date Requested: Oct 26, 2007
Response: The inclusion of the citrus group rather than just orange and grapefruit will help Caribbean growers with the citrus psyllid/greening problem. All other metrics are acceptable to VI growers.

Responder: Mark Mossler
State: PR
Date Requested: Oct 26, 2007
Response: The inclusion of the citrus group rather than just orange and grapefruit will help Caribbean growers with the citrus psyllid/greening problem. All other metrics are acceptable to PR growers.

Responder: Will Hudson
State: GA
Date Requested: Dec 10, 2007
Response: From Will Hudson My best guess is that somewhere around 5000 - 7000 acres are treated with Temik yearly in Georgia (out of 140K total). Admire has replaced some of the acres previously treated, and better aphicides have changed the way growers see their options. The main problem I see is the loss of an option for systemic treatment should aphids ever become resistant to imidacloprid. Even then, there are effective options for foliar treatment that are arguably better and cheaper than Temik without the toxicity issues. In any case, my talks with the EPA and Bayer left me with the impression this is already pretty much done. Will Hudson University of Georgia

Responder: Blake Layton
State: MS
Date Requested: Dec 10, 2007
Response: From Blake Layton Aldicarb is certainly a useful tool for insect pest management in pecans, and I am not sure the we have ever fully appreciated all of the benefits it may give. {In one large plot demonstration that I did many years ago we got about a 10% increase in nut weight, even though insect/mite populations in the check plots were below threshold.} But, because of the high use rate in pecans and the cost of use, we have very few growers that actually use it. Blake Layton, Ph.D. Extension Entomology Specialist Mississippi State University

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