1
Follow
up
on
submission
of
USA
response
to
MBTOC
inquiries
Message
from
Jonathan
Banks
dated
September
15,
2003
1)
The
CUNs
we
have
received
are
based
to
a
considerable
extent
on
work/
references
that
was
carried
out
some
years
ago
(
e.
g.
3­
5
years
ago).
MBTOC
is
aware
of
a
number
of
publications
for
the
US
that
are
more
recent
than
this
and
which
also
give
a
more
positive
results
on
the
performance
of
several
alternatives.
Is
there
any
way
that
these
more
recent
results
can
be
incorporated
into
the
CUNs,
possibly
leading
to
altered
quantities
nominated.

In
order
to
be
included
as
part
of
our
decision­
making,
studies
on
the
performance
of
alternatives
were
required
to
report
four
attributes:
a
methyl
bromide­
treated
standard;
an
untreated
control;
the
pests
and
pest
pressure
present
(
and
whether
they
were
the
same
as
those
included
in
the
U.
S.
nomination);
and
yield
changes.
If
any
one
of
these
factors
was
missing,
the
study
was
considered
of
insufficient
rigor
to
be
used
to
determine
whether
there
were
technically
and
economically
feasible
alternatives.
This
is
in
keeping
with
the
generally
accepted
practices
of
the
scientific
community.

We
evaluated
studies
conducted
by
IR­
4
and
those
reported
on
in
the
proceedings
of
the
Methyl
Bromide
Alternatives
Organization
(
MBAO)
and
well
as
those
contained
in
more
general
journals,
including
the
most
recent
reports
from
these
sources.
We
believe
that
we
have
not
overlooked
any
studies,
including
recent
studies,
that
meet
the
above
criteria.
If
MBTOC
is
aware
of
additional
studies
that
it
believes
meet
these
criteria,
we
would
like
to
know
so
we
can
assess
their
applicability
to
future
U.
S.
nominations.
Given
the
limited
time
available
and
the
uncertainty
as
to
which
specific
studies
are
referred
to
here,
we
have
not
altered
the
quantity
of
methyl
bromide
nominated.

2)
Buffer
zones
make
a
considerable
difference
to
the
practical
and
commercial
availability
of
otherwise
registered
and
proven
alternatives.
Please
clarify
the
buffer
zones
required
for
the
various
methyl
bromide
and
methyl
bromide/
chloropicrin
formulations
used
in
the
US,
particularly
California
and
Florida.

Buffer
zone
requirements
are
not
part
of
the
Federal
label
for
methyl
bromide
or
chloropicrin.
There
is
a
buffer
requirement
in
the
state
of
California
that
is
a
function
of
the
acreage
(
area)
to
which
methyl
bromide
has
been
applied.
There
is
no
buffer
requirement
for
methyl
bromide
or
chloropicrin
in
the
state
of
Florida.

Exhibit
1.
Buffer
Zone
Requirements
in
California
and
Florida
MB/
Pic
Formulations
California
Florida
2
Methyl
Bromide
 
Minimum
50
feet
for
adjoining
agricultural
property
 
Minimum
60
feet
for
schools,
residences,
hospitals,
and
employee
housing
 
Required
notification
of
residences
within
300
feet
from
the
perimeter
of
the
outer
buffer
zone
(
CDPR
2002b)
 
None
in
addition
to
those
stated
on
the
label
(
Tucker
2003).


1,3­
Dichloropropene
 
Minimum
of
100
feet
measured
from
the
perimeter
of
the
application
block
to
any
occupied
residences,
occupied
onsite
employee
housing,
schools,
convalescent
homes,
hospitals,
or
other
similar
sites
 
May
extend
across
roads
or
highways
 
If
utilizing
the
label
exemption
(
100
foot
permit
condition
buffer
zone)
one
year,
the
labeling­
required
300
foot
buffer
zone
shall
be
utilized
for
the
next
three
years.
(
CDPR
2002a)
 
The
Florida
Bureau
of
Pesticide
Registration
indicates
that
there
are
no
specific
Florida
statutes
or
regulations
of
buffers
for
1,3­
D
in
addition
to
the
label
(
Tucker
2003).
The
label
states
that
"
An
application
of
Telone
®
C­
17
shall
not
be
made
within
100
feet
of
an
occupied
structure,
such
as
a
school,
hospital,
business,
or
residence."
The
buffer
is
300
feet
for
Telone
®
C­
35.
 
Special
specimen
labels
for
Florida
state
that
there
must
be
a
100­
foot
buffer
from
drinking
wells
in
Brevard,
Broward,
Charlotte,
Citrus,
Collier,
Dade,
DeSoto,
Glades,
Hardee,
Hendry,
Hernando,
Highlands,
Hillsborough,
Indian
River,
Lake,
Lee,
Manatee,
Martin,
Monroe,
Okeechobee,
Orange,
Osceola,
Palm
Beach,
Pasco,
Pinellas,
Polk,
Sarasota,
Seminole,
St.
Lucie,
Sumter
and
Volusia
counties
(
Dow
Supplemental
Labeling
EPA
Reg.
No.
92719­
12).

Chloropicrin
In
certain
counties
(
Santa
Cruz
and
Monterey
counties)
100
foot
buffer
for
"
sensitive
sites"
(
occupied
residences
nearby)
(
Carpenter
2001)
None
(
Carpenter
2001)

Metam
sodium
 
Sprinkler
irrigation
applications
are
prohibited
within
500
ft
of
occupied
structures.
 
None
(
Trout,
2001)

References
Carpenter,
Janet,
Lori
Lynch
and
Tom
Trout.
2001.
Township
Limits
on
1,3_
D
will
Impact
Adjustment
to
Methyl
Bromide
Phase_
out.
California
Agriculture,
Volume
55,
Number
3.

CDPR.
California
Department
of
Pesticide
Regulation
3
Tucker,
Gary.
Florida
Department
of
Agriculture
3)
Are
there
any
of
the
alternatives
pending
registration,
notably
methyl
iodide
and
sulfuryl
fluoride,
that
are
possibly
available
during
or
before
2005?

Until
a
product
is
actually
registered
it
is
generally
impossible
to
predict
when,
or
even
if,
it
will
acquire
a
U.
S.
registration.
Both
of
these
chemicals
have
been
submitted
for
registration.
The
Agency
is
examining
the
registration
applications
to
determine
whether
they
meet
the
requirements
of
registration
 
that
is,
will
not
result
in
unreasonable
adverse
effects
on
the
environment.

As
we
have
noted
in
our
original
nomination
package,
since
1997,
the
U.
S.
EPA
has
made
the
registration
of
alternatives
to
methyl
bromide
a
priority.
Because
the
U.
S.
EPA
currently
has
more
applications
pending
in
its
review
process
than
the
resources
to
evaluate
them,
U.
S.
EPA
prioritizes
the
applications
in
its
registration
queue.
By
virtue
of
being
a
top
registration
priority,
methyl
bromide
alternatives
enter
the
science
review
process
as
soon
as
U.
S.
EPA
receives
the
application
and
supporting
data
rather
than
waiting
in
turn
for
the
EPA
to
initiate
its
review.
As
one
incentive
for
the
pesticide
industry
to
develop
alternatives
to
methyl
bromide,
the
U.
S.
EPA
has
worked
to
reduce
the
burdens
on
data
generation,
to
the
extent
feasible
while
still
ensuring
that
the
U.
S.
EPA's
registration
decisions
meet
the
Federal
statutory
safety
standards.
Where
appropriate
from
a
scientific
standpoint,
the
U.
S.
EPA
has
refined
the
data
requirements
for
a
given
pesticide
application,
allowing
a
shortening
of
the
research
and
development
process
for
the
methyl
bromide
alternative.
Furthermore,
U.
S.
EPA
scientists
routinely
meet
with
prospective
methyl
bromide
alternative
applicants,
counseling
them
through
the
preregistration
process
to
increase
the
probability
that
the
data
is
done
right
the
first
time
and
rework
delays
are
minimized.
.
In
addition,
individual
states
have
registration
procedures
which
occur
after
the
Federal
registration
and
must
be
completed
before
a
product
can
legally
be
used
within
their
jurisdiction.

4)
Please
make
available
to
MBTOC
a
copy
of
the
'
in
press'
publication
of
Buker
et
al
(
2003)
that
refers
to
cucurbit
production.

We
have
contacted
Buker
et
al
with
a
request
that
a
copy
of
the
paper
be
made
available
to
MBTOC.
We
are,
at
present
awaiting
a
reply.
The
paper
has
been
submitted
to
a
refereed
journal
that
has
a
policy
of
not
publishing
a
paper
if
the
results
have
been
publicly
disseminated
so
that
permission
to
forward
the
article
to
MBTOC
must
come
from
the
authors
before
we
can
make
it
available.

5)
To
allow
further
assessment
by
MBTOC,
please
make
available
labeled
plant
back
times
for
4
MB/
Pic,
chloropicrin
alone,
Telone
C17,
Telone
C35,
Metam
sodium,
Basamid
and
any
other
alternatives,
eg.
herbicides,
relating
to
the
principal
crops
involved
in
CUNs
This
is
a
large
request
in
the
short
time
available
for
response
because
it
needs
to
be
addressed
on
a
crop,
soil,
temperature,
rainfall
basis
(
see
metam
sodium).
Since
this
information
was
included
in
our
nomination
package,
could
MBTOC
clarify
the
crops
they
have
specific
questions
about.

For
metam
sodium
for
light
to
medium
textured
soils
that
drain
well
planting
can
begin
within
14
to
21
days.
For
heavy
soils
or
soils
with
high
organic
matter
the
minimum
interval
is
21
days
or
greater.
Soils
should
be
allowed
to
aerate
and
dry
thoroughly
after
treatment
and
before
planting.
During
cold
and
or
wet
weather,
frequent
shallow
cultivation
can
aid
dissipation
of
metam
sodium.
Individual
crop
and
cultivar
differences
in
sensitivity
also
impact
the
plant
back
interval
as
does
the
choice
of
direct
seeded
or
transplanting
of
the
crop.
In
general,
cool
or
wet
weather,
heavy
soils,
or
high
levels
of
organic
material
will
retard
the
diffusion
of
fumigants,
requiring
a
longer
exposure
and
aeration
period.

The
planting
interval
following
soil
fumigation
time
with
Telone
is
dependent
upon
the
application
rate;
one
week
for
every
10
gallons/
acre
(
approximately
94
liters/
hectare).
For
all
but
nursery
crops
the
range
would
be
7­
21
days.
The
planting
intervals
following
fumigation
with
chloropicrin,
metam
sodium
and
dazomet
(
Basamid)
are
provided
as
recommendations
and
are
typically
listed
on
product
labels
as
greater
than
14
days
for
chloropicrin
alone,
21
days
or
more
for
metam
sodium
and,
depending
upon
soil
temperatures,
a
range
of
10­
30
days
for
dazomet.

For
nursery
crops,
higher
application
rates
are
used.
For
Telone
C­
17,
the
recommended
label
rate
is
50­
66
gallons/
acre
(
approximately
470­
620
liters/
hectare)
which
would
translate
to
a
soil
fumigation
interval
of
5­
6
weeks.
For
Telone
C­
35
the
application
rate
is
60­
80
gallons/
acre
(
approximately
560­
750
liters/
hectare).
The
same
7
day
plant
back
interval
per
10
gallons/
acre
applies.

6)
Please
make
comment
as
to
why
Telone
C35,
an
apparent
MB
alternative,
has
not
been
discussed
as
an
alternative
for
some
crops
that
are
involved
in
CUNs
e.
g.
turf,
cucurbits.

Telone/
chloropicrin
combinations
were
discussed
as
methyl
bromide
alternatives
in
the
responses
to
MBTOC/
TEAP
questions.
Although
the
specific
formulations
of
Telone
17
and
Telone
35
were
not
addressed,
the
combination
of
Telone
and
chloropicrin
was
addressed
where
it
was
listed
on
the
MBTOC
Index
for
a
crop/
commodity
(
as
well
as
if
there
was
a
specific
question
in
MBTOC/
TEAP
requests
for
clarification
of
the
CUN).
Finally,
Telone
and
chloropicrin
combinations
do
not
control
the
key
pests
affecting
these
crops.
