Information Requests Monitoring System

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Request ID: 180
Request From: Steve Toth
Date Requested: Oct 12, 2007
Request: Note the following request from Al Jennings, Director, USDA's Office of Pest management Policy for comments on Endosulfan Risk Mitigation Measures (see message below). Please forward this request to the experts in your respective states/territories and submit your comments to the Southern Region IPM Center Information Requests Monitoring System by Friday, October 26, 2007. Thanks. Steve Toth ---------------------------------------- Colleagues, The purpose of this note is to update you on recent and planned actions affecting ENDOSULFAN and ask that you pass this information along to crop production specialists and growers in your region. The RED for endosulfan was issued in 2002 and identified the risk reduction measures listed below. EPA has now mandated new product labels to reflect these risk reduction measures. The label changes will impact the use of the chemical next growing season. At the same time, EPA has evaluated new toxicological data submitted by the registrant and plans to issue an updated risk assessment for public comment soon. Because of the new data, the risk has shifted to less concern about dietary exposure and greater concern about worker exposure. Although it is not yet clear how EPA would consider new information on the impact of the label changes, please review the following risk mitigation measures and advise me of any potential significant impacts. Thank you. Allen L. Jennings, Ph.D. Director, Office of Pest Management Policy USDA 202-720-5375 allen.jennings@usda.gov Endosulfan Risk Mitigation Measures To mitigate human health and ecological risks of concern for endosulfan, the following measures will be implemented: Dietary (Food) Risk • Delete use on succulent beans, succulent peas, spinach, and grapes Dietary (Drinking Water) and Ecological Risk Several mitigation measures are needed to reduce the potential for contamination of drinking water. • Delete use on pecans; • Reduce maximum seasonal application rates from 3lbs./ai/A to 2.5 lbs./ai/A for pome fruit, stone fruit, and citrus; • Reduce maximum seasonal application rate from 3 lbs./ai/A to 2 lbs./ai/A for melons, cucurbits, lettuce, tomatoes, sweet potatoes, cotton (ground), broccoli, cauliflower, cabbage, kohlrabi, brussels sprouts, strawberries, filberts, walnuts, almonds, macadamia nuts, peppers, eggplant, potatoes, carrots, dry beans, dry peas, and tobacco; • Reduce maximum seasonal application rate from 3 lbs./ai/A to 1.5 lbs./ai/A for sweet corn, cotton (aerial) and blueberries; • Reduce maximum seasonal application rate from 3 lbs./ai/A to 1 lb./ai/A for celery; • Require 100 ft. spray buffer for ground applications between a treated area and water bodies; • Require 30 ft. maintained vegetative buffer strip between a treated area and water bodies; • Require all products to be Restricted Use; • Restrict use on cotton to AZ, CA, NM, OK and TX only; and • Restrict use on tobacco to IN, KY, OH, PA, TN and WV only. Occupational Risk • Require all wettable powers to be packaged in water soluble bags; • Cancel use of wettable powders on tomatoes, sweet corn, sweet potatoes, cotton, small grains, alfalfa (seed), carrots, dry beans, dry peas, pineapples, and tobacco; • Cancel aerial application using the wettable powder formulation on pome fruits, stone fruits, citrus, blueberries, strawberries, collard greens (seed), kale (seed), mustard greens (seed), radish (seed), turnip (seed), rutabaga(seed), broccoli, (seed), cauliflower (seed), kohlrabi (seed), cabbage (seed), filberts, walnuts, almonds, and macadamia nuts; • Require closed mixing/loading systems for aerial application using the EC formulation on pome fruits, stone fruits, citrus, sweet corn, sweet potatoes, cotton, collard greens (seed), kale (seed), mustard greens (seed), radish (seed), turnip (seed), rutabaga (seed), broccoli, (seed), cauliflower (seed), kohlrabi (seed), cabbage (seed), blueberries, small grains, alfalfa (seed), filberts, walnuts, almonds and macadamia nuts; • Require closed cabs for airblast applications on pome fruits, stone fruits, citrus, filberts, walnuts, almonds and macadamia nuts; • Prohibit use of high pressure handwands with rates greater than 0.005 lbs/ai/gal; • Increase REI to 48 hours for all crops except as noted in the following bullets; • Increase REI for WP products to 3 days for melons and cucurbits; • Increase REI for WP products to 4 days for lettuce, celery, pome fruit, stone fruit, citrus, collard greens, kale, mustard greens, radish, turnip, rutabaga, ornamental trees and shrubs; • Increase REI for WP products to 5 days for collard greens (seed), kale (seed), mustard greens (seed), radish (seed), turnip (seed) and rutabaga (seed); • Increase REI for WP products to 9 days for blueberries, broccoli, cauliflower, kohlrabi, cabbage, and brussels sprouts; • Increase REI for WP products to 12 days for broccoli (seed), cauliflower (seed), kohlrabi (seed), and cabbage (seed); • Increase REI for EC products to 3 days for sweet potatoes • Increase REI for EC products to 4 days for broccoli, cauliflower, kohlrabi, cabbage, and brussels sprouts; • Increase REI for EC products to 6 days for blueberries; • Increase REI for EC products to 7 days for broccoli (seed), kohlrabi (seed), and cabbage (seed); and • Increase REI for EC products to 17 days for sweet corn.

Responses
Responder: Holly Gatton
State: VA
Date Requested: Oct 25, 2007
Response: Compiled from emails received from VA Agents & Specialists:

The restriction on seasonal maximum use on cucurbits could present a problem. Since it is somewhat honey bee "friendly" compared to some other insecticides, it is an important cucumber beetle, squash vine borer, etc. control product.
Phil Blevins, VCE – Washington Co.

We have vegetable growers and pecan growers who will be strongly adversely affected. Thionex is one of the few products that work that are not restricted use. Altering the ability to use this product will make it harder for them to maintain control.
David Smith, VCE - Cumberland Co.

The reduced season ai rates could be a hardship for growers of crops like sweet potatoes that only have a few labeled products to select from. Some of the REI's seem long - it could interfere with the timely harvest of some crops. I am not sure what the pre-harvest interval is for all the crops listed.
Scott Reiter, VCE – Campbell Co.

Why will it not be available on tobacco in VA? The rest of the tobacco burley tobacco producing regional will still be able to use endosulfan. This proposed reductions will really limit its use by our growers. We have many producers in the Southwestern part of the state that like to use endosulfan as a rotational tool with pyrethroids. It is not a perfect product, but it has been very useful. It has been an effective and affordable rotational product. I would like to see the vegetable uses and rates retained.
Allen Straw, Vegetable Specialist, SW Virginia AREC

I work in tobacco insect management. The cancelation of endosulfan for use on tobacco in Virginia is fine. I have been expecting this action for two or three years. I have taken it out of my recommendations for 2008. The tobacco companies have encouraged this action.
Please contact me if you have any questions.
Paul Semtner, VT Professor & Tobacco Specialist

Seems reasonable to me.
Tom Kuhar, VT Assistant Professor & Vegetable Insect Specialist

Responder: Mark Mossler
State: FL
Date Requested: Oct 26, 2007
Response: No responses were received from the FPMIP network, indicating lack of concern regarding these changes to the endosulfan label. One comment was received regarding clarification of closed-cab for applicators (what defines closed-cab - does it have to be a structural partition or will any type of partition be acceptable?).

Responder: Mark Mossler
State: VI
Date Requested: Oct 26, 2007
Not Important/Relevant to my state(s)
Response:

Responder: Mark Mossler
State: PR
Date Requested: Oct 26, 2007
Not Important/Relevant to my state(s)
Response:

Responder: Jack Bacheler
State: NC
Date Requested: Oct 26, 2007
Response: Endosulfan is not presently recommended by us on cotton in North Carolina. Jack Bacheler Extension Entomologist Department of Entomology North Carolina State University

Responder: Robert Bellinger
State: SC
Date Requested: Nov 07, 2007
Response: Finally got a single response back - said they did not know that endosulfan was even registered on some of the crops in question. It would appear we have no issues.

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