November
22,
2002
Public
Information
and
Records
Integrity
Branch
(
7502C)
Office
of
Pesticide
Programs
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington
DC,
20460­
0001
To
Whom
It
May
Concern:

Re:
Diazinon
Availability
of
Interim
Reregistration
Eligibility
Decision
Document
for
Comment;
OPP­
2002­
0251,
FRL­
7274­
4
The
U.
S.
Apple
Association
(
USApple)
is
the
national
trade
association
representing
all
segments
of
the
apple
industry.
Members
include
40
state
and
regional
apple
associations
representing
the
9,000
apple
growers
throughout
the
country,
as
well
as
more
than
400
individual
firms
involved
in
the
apple
business.
USApple
appreciates
this
opportunity
to
comment
on
the
critical
need
for
diazinon
use
on
apples.

USApple
understands
that
the
U.
S.
Environmental
Protection
Agency
(
EPA)
plans
to
delete
from
the
current
diazinon
label
all
pests
and
directions
for
use
except
for
one
application
to
control
woolly
apple
aphids.
USApple
wishes
to
emphasize
the
critical
need
for
diazinon
use
on
apples
to
control
woolly
apple
aphid.
No
other
tool
is
available
to
apple
growers
to
control
infestations
of
this
destructive
pest.
This
use
is
needed
to
avoid
debilitating
apple
tree
damage
that
reduces
tree
vigor,
productivity
and
apple
size.
The
inability
to
control
woolly
apple
aphid
will
result
in
lower
productivity,
which
reduces
grower
revenue
and
our
industry's
international
competitiveness.
Therefore,
USApple
supports
the
agency's
plans
to
maintain
this
critical
use.

Additionally,
USApple
urges
the
agency
to
maintain
a
single
application
of
diazinon
to
control
San
Jose
scale
crawlers.
Apple
growers
are
experiencing
greater
persistence
of
scale
in
apple
orchards
due
to
the
loss
of
methyl
parathion
and
chlorpyrifos.
While
pyriproxyfen
(
Esteem
®
)
provides
excellent
control
of
San
Jose
scale
crawlers,
apple
growers
are
concerned
that
this
is
currently
the
only
available
alternative
for
this
pest.
Thus,
USApple
urges
the
agency
to
maintain
this
use
to
assist
apple
growers
with
their
insect
resistance
management
plans
that
would
prolong
the
efficacy
of
pyriproxyfen
and
avoid
future
problems
controlling
San
Jose
scale.

It
has
come
to
USApple's
attention
that
the
use
of
thiamethoxam
(
Actara
®
)
may
be
limited
to
the
states
of
Michigan,
Pennsylvania
and
New
York.
If
thiamethoxam's
use
is
restricted
to
these
states
in
the
future,
many
apple
growers
will
need
diazinon
to
control
rosy
apple
aphids
and
mealybugs.
Thiamethoxam
controls
both
rosy
apple
aphids
and
mealybugs.
However,
if
growers
do
not
have
access
to
this
tool,
diazinon
would
be
the
preferred
alternative.
Should
North
Carolina
growers
lose
the
thiamethoxam
use,
only
dimethoate
and
diazinon
would
be
available
for
adequate
mealybug
control.
Therefore,
USApple
urges
EPA
to
allow
a
single
application
of
diazinon
to
control
rosy
apple
aphids
and
mealybugs.

The
agency's
interim
reregistration
eligibility
decision
for
diazinon
mandates
use
of
diazinon
in
closed
cabs.
USApple
requests
that
the
agency
remove
this
restriction,
since
the
majority
of
apple
growers
either
do
not
use
closed
cab
tractors
or
they
are
impossible
to
use
in
many
orchard
production
systems
currently
in
use
in
the
apple
industry.
The
U.
S.
apple
industry
has
been
transitioning
to
higher
density
orchards
with
narrower
rows
or
trellis
systems
that
cannot
accommodate
the
higher
profile
of
closed
cab
tractors.
Should
the
agency
maintain
this
restriction,
it
will
effectively
prohibit
diazinon
use
on
significant
apple
acreage.

USApple
recommends
the
following
protective
measures
as
an
alternative
when
closed
cabs
are
not
used
for
diazinon
applications:

 
chemical
resistant
coveralls
over
long­
sleeve
shirt
and
long
pants,
 
chemical­
resistant
gloves,
 
chemical­
resistant
footwear
plus
socks,
 
protective
eyewear,
 
chemical­
resistant
apron
if
exposed
to
the
concentrate,
 
chemical­
resistant
headgear
for
overhead
exposure,
and
 
A
respirator
with
an
organic­
vapor
removing
cartridge
with
a
prefilter
approved
for
pesticides
(
MSHA/
NIOSH
approval
number
prefix
TC­
23C),
or
a
canister
approved
for
pesticides
(
MSHA/
NIOSH
approval
number
prefix
TC­
14G),
or
a
NIOSHapproved
respirator
with
an
organic
vapor
(
OV)
cartridge
or
canister
with
any
N,
R
or
P
or
He
prefilter.

Note:
The
registrant
must
drop
the
N­
series
filter
from
the
respirator
filter
designation
if
the
pesticide
product
contains
or
is
used
with
oil.

USApple
appreciates
your
consideration
of
these
recommendations.

Sincerely
yours,

James
R.
Cranney,
Jr.
Vice
President
