1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
DATE:
June
23,
2004
SUBJECT:
Response
to
Public
Comments
on
the
Diazinon
IRED
TO:
Diazinon
EDOCKET
OPP­
2002­
0251
FROM:
Debra
Edwards,
Director
Special
Review
and
Reregistration
Division
The
Environmental
Protection
Agency
has
reviewed
the
public
comments
submitted
on
the
Interim
Reregistration
Eligibility
Decision
(
IRED)
document
for
diazinon.
The
comment
period
ended
January
10,
2003.
32
sets
of
comments
were
received
from
growers,
crop
associations,
non­
governmental
environmental
groups,
state
environmental
organizations,
the
registrant
(
Makhteshim­
Agan),
and
pest
management
researchers.
The
range
of
comments
ran
from
groups
who
believe
the
Agency
is
being
too
conservative,
and
thus
overstating
risks
in
its
risk
estimates,
to
those
who
believe
the
Agency
needs
to
take
measures
beyond
those
proposed
in
the
IRED
in
order
to
protect
humans
and
the
environment.

This
document
contains
the
EPA's
responses
to
comments
submitted
on
the
diazinon
IRED.
Most
comments
addressed
one
or
a
few
use
sites;
and
those
issues
that
were
raised
repeatedly
have
been
addressed
generically.
EPA
considered
all
comments
and
made
changes
to
the
IRED
where
deemed
appropriate.

1X
Safety
Factor
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides)

1.
Comment:
EPA
should
use
a
10X,
not
a
1X
FQPA
safety
factor
in
its
diazinon
risk
assessments.
The
1X
safety
factor
does
not
adequately
protect
all
fetuses,
infants,
and
children.
Developmental
neurotoxicity
studies
are
not
available
for
diazinon,
but
those
for
other
organophosphorous
pesticides
show
that
infants
and
children
may
be
more
sensitive
than
adults.
2
Response:
The
DNT
study
was
submitted
to
the
Agency
in
February
2004,
after
this
comment
was
submitted.
The
data
will
be
reviewed
and
the
results
incorporated
into
both
the
individual
diazinon
risk
assessment
and
the
cumulative
effects
risk
assessment
for
the
organophosphate
pesticides.
Accordingly,
this
information
will
be
fully
considered
in
issuing
the
RED
for
diazinon.

Children's
Exposure
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides)

2.
Comment:
EPA
should
consider
children
of
farm
workers
and
residents
of
agricultural
communities
as
identifiable,
high
risk
sub­
populations.
EPA
has
not
taken
into
account
the
higher
pesticide
exposures
these
children
receive
as
a
result
of
contact
with
their
parents'
clothing,
dust
tracked
into
their
homes,
contaminated
soil
in
areas
where
they
play,
food
brought
directly
from
the
fields
to
the
table,
or
airborne
pesticide
drift.

Response:
In
assessing
the
risk
to
infants
and
children,
EPA
takes
an
approach
which
is
designed
to
be
protective
of
all
children,
including
farm
children.
These
commenters
assert
that
EPA
is
not
fully
considering
pesticide
exposures
to
farm
children.
EPA
is
carefully
considering
similar
and
more
detailed
comments
that
NRDC
has
made
with
regard
to
exposure
to
farm
children
in
a
series
of
objections
to
various
tolerance
actions.
EPA
expects
that
its
response
to
NRDC's
objections
to
these
tolerance
actions
will
be
completed
in
the
next
few
months.
Any
change
to
exposure
assessment
procedures
that
comes
out
of
this
review
of
NRDC's
objections
will
be
considered
as
EPA
completes
the
diazinon
RED.

3.
Comment:
Diazinon
occurs
most
frequently
on
the
foods
that
are
eaten
most
by
children.
Therefore,
in
seasons
where
pest
pressures
result
in
high
uses
of
diazinon,
it
is
very
likely
that
children
will
be
exposed
at
unacceptably
high
levels
through
their
"
favorite
foods."

Response:
EPA
agrees
that
many
of
the
food
commodities
children
eat
most
are
treated
with
diazinon.
The
fact
that
many
commodities
consumed
by
children
may
have
diazinon
residues
and
that
these
levels
vary
depending
on
how
much
diazinon
is
used,
however,
does
not
mean
that
such
levels
are
"
unacceptably
high."
In
calculating
the
level
of
risk
faced
by
children,
it
is
necessary
to
look
not
only
at
the
number
of
foods
that
may
contain
residues,
but
also
at
the
levels
of
residues
in
those
foods
and
the
amounts
of
those
foods
that
are
consumed
by
children.
EPA's
risk
assessment
for
diazinon
did
precisely
that.
Therefore,
EPA
does
not
expect
that
children
will
be
exposed
to
unacceptably
high
levels
of
diazinon
through
foods.
3
Water
Assessment
Process
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides)

4.
Comment:
EPA
should
have
considered
urban,
public
health,
and
section
18
emergency
uses
of
diazinon
in
its
drinking
water
risk
assessment.
69
percent
of
diazinon
used
is
not
used
agriculturally,
and
inclusion
of
these
other
uses
would
clearly
result
in
higher
risk
than
the
EPA
estimates
based
on
the
current
model
that
only
considers
agricultural
uses,
since
most
diazinon
used
in
applied
in
urban
settings.

Response:
The
Agency
does
not
believe
it
was
necessary
to
include
urban,
public
health,
or
section
18
emergency
diazinon
uses
in
its
drinking
water
assessment
for
diazinon,
due
to
the
fact
that
the
decision
had
been
made
to
cancel
all
non­
agricultural
diazinon
uses
at
the
time
the
IRED
was
written.
All
diazinon
products
formulated
for
non­
agricultural
use
are
being
phased
out
through
an
agreement
that
was
made
with
the
technical
registrants
in
December
of
2000.
All
such
products
will
be
sold
only
until
December
31,
2004.
Additionally,
there
is
a
relatively
large
amount
of
monitoring
data
available
for
diazinon
that
reflects
urban
uses.
These
monitoring
data
do
not
indicate
a
concern
for
residues
in
drinking
water
from
urban
uses
of
diazinon.

5.
Comment:
The
acute
DWLOC
for
surface
water
is
exceeded
for
all
reported
populations.
This
means
that
people
are
exposed
to
excessive
diazinon
residue
levels,
which
pose
health
risks.
However,
the
Agency
has
ignored
its
own
results
and
determined
that
these
exceedances
are
"
probably
not
of
concern."

Response:
The
Agency
acknowledges
that
the
DWLOC
is
exceeded
for
populations
from
the
PRZM­
EXAMS
modeling
cited
in
the
IRED.
However,
the
Agency
did
not
ignore
these
data
in
concluding
that
there
probably
should
not
be
concern
from
diazinon
residues
in
drinking
water.
Rather,
EPA
took
into
account
that
the
modeling
did
not
reflect
significant
mitigation
measures
in
the
IRED
and
also
far
exceeded
monitoring
values.

The
PRZM­
EXAMS
modeling
estimate
is
considered
to
be
conservative,
since
it
is
based
on
the
maximum
allowable
rate
for
three
aerial
applications
of
diazinon
to
peaches
at
seven
day
intervals.
The
aerial
application
spray
drift
default
value
assumes
that
5%
of
the
application
goes
directly
to
the
water
body.
This
also
assumes
a
default
percent
cropped
area
of
87%
of
the
watershed
and
that
the
entire
cropped
area
is
treated
with
diazinon.
The
site
is
chosen
as
a
vulnerable
area
which
can
be
cropped.
The
model
is
intended
to
be
provide
an
upper­
bound
conservative
estimate
so
that
the
Agency
is
protective
in
the
absence
of
monitoring
data.
Additionally,
as
a
result
of
mitigation
from
the
IRED,
aerial
applications
are
no
longer
allowed
(
except
to
lettuce),
and
only
one
application
can
be
made
to
peaches
per
year.
These
mitigation
measures
will
lower
the
water
modeling
estimates.

There
is
a
relatively
large
amount
of
water
monitoring
data
available
for
diazinon
which
4
was
summarized
in
a
May
1999
drinking
water
memorandum
from
R.
Matzner
to
C.
Eiden.
This
memorandum
is
available
on
the
EPA
website.
Much
of
these
data
are
likely
to
reflect
the
residential
uses
of
diazinon,
which
have
been
canceled.
Nonetheless,
even
assuming
that
all
values
are
related
solely
to
agricultural
uses,
these
monitoring
data
show
levels
to
be
significantly
below
modeling
values
and
also
below
the
DWLOC.
Some
of
these
summarized
monitoring
data
are
separated
into
urban
and
agricultural
uses
of
diazinon,
while
other
sources
do
not
differentiate.
The
maximum
reported
concentration
of
diazinon
from
any
source
was
3.8
ppb,
but
it
was
not
clear
whether
this
was
an
urban
or
an
agricultural
source.
For
agricultural
usage,
the
monitoring
value
recommended
for
comparison
to
the
acute
DWLOC
is
2.3
ppb.
This
is
the
95th
percentile
residue
value
which
was
derived
by
considering
the
maximum
value
from
each
of
the
94
agricultural
monitoring
sites.
The
acute
DWLOC
for
children
is
9
ppb.

6.
Comment:
The
chronic
DWLOC
is
exceeded
for
surface
water
for
all
reported
populations.
This
means
that
people
are
exposed
to
excessive
diazinon
residue
levels,
which
pose
health
risk.
However,
the
Agency
has
ignored
its
own
results
and
determined
that
these
exceedances
are
"
not
of
concern."

Response:
As
with
the
surface
water
modeling
values
used
for
acute
risk
assessment,
the
PRZM­
EXAMS
chronic
modeling
estimate
is
considered
to
be
conservative,
since
it
is
based
on
the
maximum
allowable
rate
for
three
aerial
applications
of
diazinon
to
peaches
at
seven
day
intervals.
The
aerial
application
spray
drift
default
value
assumes
that
5%
of
the
application
goes
directly
to
the
water
body.
The
model
also
assumes
a
default
percent
cropped
area
of
87%
of
the
watershed
and
that
the
entire
cropped
area
is
treated
with
diazinon.
The
site
is
chosen
as
a
vulnerable
area
which
can
be
cropped.
The
model
is
intended
to
be
provide
an
upper­
bound
conservative
estimate
so
that
the
Agency
is
protective
in
the
absence
of
monitoring
data.

While
the
monitoring
studies
do
cite
a
single
value
of
3.8
ppb
which
is
above
the
DWLOC
for
children,
the
vast
majority
of
samples
are
well
below
the
2
ppb
DWLOC
for
children.
In
assessing
chronic
risk,
EPA
calculates
the
highest
value
to
which
a
person
may
likely
be
exposed
on
a
chronic
basis,
rather
than
focusing
on
a
single
high
value
that
may
be
present
occasionally.
The
average
diazinon
monitoring
data
point
recommended
for
comparison
is
0.5
ppb,
which
is
well
below
the
DWLOC
for
all
populations.
This
value
includes
monitoring
from
urban
and
agricultural
sites.
Based
on
cancellation
of
residential
uses
and
mitigation
required
by
the
IRED,
these
monitoring
data
can
be
considered
an
upper
estimate
of
what
would
be
found
from
current
use.
The
Agency
stands
by
its
conclusion
that
for
chronic
risk
assessments,
the
reported
modeling
exceedances
are
"
not
of
concern
for
diazinon,"
based
on
(
1)
the
extensive
changes
in
the
diazinon
use
pattern
and
(
2)
the
conservative
nature
of
the
modeling
runs
when
compared
with
the
monitoring
data.

Worker
Risks
Unacceptably
High
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund)

7.
Comment:
Even
with
the
mitigation
measures
called
for
in
the
IRED
in
place,
EPA
5
cannot
quantify
the
level
of
protection
being
provided
to
farm
workers,
and
so
cannot
guarantee
adequate
protection
of
workers,
some
of
whom
are
children
and
pregnant
women.
Therefore,
farm
workers
are
still
at
unacceptable
levels
of
risk
of
injury
during
their
work
day.
EPA
should
cancel
all
uses
of
diazinon
that
threaten
the
health
and
safety
of
agriculture
workers.

Response:
It
is
important
to
note
that
EPA
is
required
by
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
to
perform
risk­
benefit
analyses
when
reregistering
all
pesticides.
Diazinon
applications
have
been
restricted
to
those
where
benefits
are
considered
to
be
high.

While
EPA
acknowledges
that
the
level
of
protection
provided
to
farm
workers
as
a
result
of
the
mitigation
measures
in
the
IRED
cannot
be
explicitly
quantified,
the
Agency
does
expect
that
these
mitigation
measures
will
provide
some
added
protection
of
farm
workers
as
a
result
of
significantly
reduced
exposure.
Mitigation
measures
called
for
in
the
IRED
that
protect
workers
include:
1)
reduction
in
application
rate
and
frequency
2)
deletion
of
all
aerial
applications,
except
to
lettuce
(
See
response
#
16.),
3)
deletion
of
foliar
applications
to
most
crops,
4)
requirement
of
lock/
load
engineering
controls
for
all
ground
equipment,
except
for
use
on
apples
(
See
response
#
32.),
and
5)
establishment
of
crop
specific
re­
entry
intervals,
ranging
from
two
to
18
days.

Protecting
Only
99.9
Percent
of
the
Population
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides)

8.
Comment:
NRDC
claims
that
EPA's
use
of
the
99.9th
percentile
population
exposure
in
estimating
acute
risk
violates
the
FQPA's
safety
standard
because
EPA
is
allowing
"
as
many
as
one
in
twenty
children
to
be
exposed
to
levels
of
pesticides
in
excess
of
agencyestablished
safe
levels."
EPA
needs
to
do
more
than
protect
"
most"
children.

Response:
As
EPA
has
explained
in
its
policy
statement
with
regard
to
use
of
population
percentiles
of
exposure
in
risk
assessment,
EPA,
in
estimating
exposure
and
risk
through
the
selection
of
exposure
at
a
certain
population
percentile,
is
not
attempting
to
precisely
define
exposure
to
that
population
percentile
and
protect
that
population
group.
See
U.
S.
EPA,
Choosing
a
Percentile
of
Acute
Dietary
Exposure
as
a
Threshold
of
Regulatory
Concern
(
March
16,
2000).
In
other
words,
when
EPA
uses
a
population
percentile
of
99.9
(
or
95,
for
that
matter),
EPA
is
not
implying
that
only
99.9
percent
of
the
population
need
to
be
protected.
Rather,
EPA
chooses
different
population
percentiles
of
exposure
in
estimating
risk
depending
on
the
data
used
to
calculate
exposure
so
as
to
ensure
that
its
risk
assessment
provide
protection
to
the
general
population
and
all
major,
identifiable
subgroups.
EPA
generally
uses
a
higher
population
percentile
to
estimate
overall
exposure
when
data
used
on
exposure
are
more
realistic.
As
EPA
explained
in
its
policy
document,
"
it
is
[
EPA's
Office
of
Pesticide
Programs']
view
that,
with
probabilistic
6
assessments,
the
use
of
the
99.9th
percentile
generally
produces
a
reasonable
high­
end
exposure
such
that
if
that
exposure
does
not
exceed
the
safe
level,
OPP
can
conclude
there
is
a
reasonable
certainty
of
no
harm
to
the
general
population
and
all
significant
population
groups."
Id.
at
31.

Use
of
Percent
Crop
Treated
Data
in
Acute
Risk
Assessments
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides)

9.
Comment:
Section
408(
b)(
2)(
F),
which
addresses
use
of
percent
crop
treated
data
in
chronic
risk
assessments
impliedly
bars
use
of
such
data
in
acute
risk
assessments.
Use
of
percent
crop
treated
data
is
appropriate
only
where
the
Agency
is
not
concerned
about
exposure
to
residues
in
individual
food
items,
but
exposure
to
residues
in
multiple
items
over
time.
In
the
latter
instance,
people's
exposure
to
pesticide
residues
are
likely
to
even
out
as
they
consume
a
mixture
of
treated
and
untreated
food.

Response:
EPA
believes
NRDC
and
WWF
have
misinterpreted
the
statute
as
regards
percent
crop
treated
data.
EPA
does
not
rely
on
section
Section
408(
b)(
2)(
F)
for
the
authority
to
use
percent
crop
treated
data
in
acute
risk
assessment,
but
rather,
section
408(
b)(
2)(
D).
Section
408(
b)(
2)(
D)
directs
EPA
to
consider
information
on
"
aggregate
exposure,"
as
well
as
"
other
relevant
factors"
in
making
its
safety
determinations.
This
broad
and
open­
ended
authorization
clearly
covers
use
of
percent
crop
treated
data
in
acute
risk
assessments.
Moreover,
section
408(
b)(
2)(
F)
should
not
be
read
as
implicitly
limiting
the
direction
provided
in
section
408(
b)(
2)(
D).
On
its
face,
subparagraph
(
F)
does
nothing
more
that
establish
specific
conditions
on
use
of
percent
crop
treated
data
when
such
data
are
used
in
chronic
risk
assessments.
It
neither
speaks
to
acute
risk
assessments,
nor
includes
"
use
in
a
chronic
risk
assessment"
as
one
of
the
conditions
that
must
be
met
when
using
percent
crop
treated
data.

Further,
NRDC
and
WWF
are
incorrect
in
their
argument
that
EPA's
use
of
percent
crop
treated
data
in
acute
risk
assessments
is
scientifically
unsound.
NRDC
and
WWF
contend
that
use
of
percent
crop
treated
data
only
makes
sense
in
chronic
risk
assessments
where
the
treated
and
untreated
crop
are
uniformly
mixed.
In
these
circumstances,
the
two
groups
acknowledge
that
a
consumer,
over
the
long
term,
is
likely
to
be
exposed
to
an
average
of
the
residue
amounts
on
treated
and
untreated
commodities.
The
two
groups
argue,
however,
that
if
residues
among
treated
and
untreated
commodities
are
averaged
in
assessing
acute
risks,
acute
risks
will
be
understated.
NRDC
and
WWF
correctly
note
that
with
acute
risks,
EPA
needs
to
be
concerned
with
the
highest
residue
values
found
in
individual
commodities,
and
an
averaging
of
residue
values,
especially
when
values
from
untreated
commodities
are
included,
can
mask
the
high
end
values.
The
flaw
in
this
argument
is
the
assumption
that
EPA,
in
using
percent
crop
treated
data
in
acute
risk
assessments,
uses
such
data
to
average
residue
values,
and
thus
masks
high
end
residue
values.
This
is
incorrect.
EPA
only
uses
percent
crop
treated
data
in
acute
risk
assessments
when
it
can
be
incorporated
in
a
manner
that
preserves
all
individual
high
end
residue
values
that
can
be
expected
on
the
treated
commodity.
The
risk
assessment
technique
EPA
uses
to
accomplish
the
integration
of
percent
crop
treated
data
with
actual
7
residue
data
on
the
range
of
possible
residue
values
is
a
probability­
based
approach.
With
probabilistic
assessments
such
as
was
used
for
diazinon,
EPA
uses
all
residue
values,
including
high
end
values
to
create
a
data
set
representing
the
full
range
of
pesticide
residue
values
in
commodities
that
a
consumer
may
encounter.
These
residue
values
are
then
matched
randomly
and
reiteratively
with
consumption
data
to
project
likely
exposure
values.
In
such
a
probabilistic
assessment
"
information
on
the
percent
of
the
crop
which
is
treated,
if
available,
is
.
.
.
used
to
adjust
the
probability
of
encountering
a
treated
commodity."
U.
S.
EPA,
Choosing
a
Percentile
of
Acute
Dietary
Exposure
as
a
Threshold
of
Regulatory
Concern
14
(
March
16,
2000).
This
is
done
by
populating
the
data
set
of
commodity
residue
values
with
residue
values
of
zero
in
a
percentage
directly
proportional
to
the
percentage
of
the
crop
that
is
not
treated
with
the
pesticide.
In
no
way
does
EPA
average
residue
values
from
untreated
and
treated
commodities
or
otherwise
reduce
high
end
residue
values
that
may
occur
in
the
treated
crop.
Probabilistic
techniques
such
as
this
for
assessing
risk
from
pesticide
residues
in
food
have
frequently
been
endorsed
by
the
FIFRA
Scientific
Advisory
Panel.
See,
e.
g.,
Final
Report
of
the
SAP
on
EPA's
Policy
Document
on
Acute
Dietary
Risk
Assessment
and
the
Product
Chemistry
and
Residue
Chemistry
Testing
Guidelines
of
the
Harmonized
Test
Guidelines
for
OPPTS
9
(
October
19,
1995).

Consideration
of
Worker
Exposure
in
FQPA
Safety
Finding
(
Natural
Resources
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides)

10.
Comment:
In
calculating
aggregate
exposure
to
a
pesticide
for
the
purpose
of
making
the
safety
finding
under
FFDCA
section
408(
b)(
2)(
A)(
ii),
EPA
must
include
exposure
to
the
pesticide
that
persons
incur
as
part
of
their
occupations.

Response:
EPA
disagrees
with
this
interpretation
of
the
statute.
Although
the
general
language
in
section
408(
b)(
2)(
A)(
ii)
can
arguably
be
interpreted
as
extending
to
worker
exposures,
to
adopt
such
an
interpretation
would
be
to
read
out
of
the
statute
the
very
specific
exclusion
of
occupational
exposure
from
aggregate
exposure
in
section
408(
b)(
2)(
D).
8
Restricting
Uses
When
Alternatives
Are
Available
(
Bay
Area
Stormwater
Management
Agencies
Association,
California
Regional
Water
Quality
Control
Board,
San
Francisco
Department
of
the
Environment)

11.
Comment:
EPA
should
restrict
applications
of
diazinon
to
situations
where
less
toxic
alternatives
will
not
work,
and
design
restrictions
to
make
sure
water
quality
criteria
are
met.
EPA
should
avoid
recommending
harmful
pesticide
alternatives
when
less
toxic
ones
exist.

Response:
FIFRA
requires
the
EPA
to
perform
risk­
benefit
analyses
when
reregistering
all
pesticides.
Diazinon
applications
have
been
restricted
to
those
where
benefits
are
high.
Phase­
out
periods
have
been
established
to
allow
growers
ample
time
to
seek
effective
alternatives.
Furthermore,
EPA
believes
that
the
mitigation
measures
it
has
taken
regarding
diazinon
use,
such
as
cancelling
all
residential
uses,
cancelling
some
agricultural
uses,
and
reducing
the
numbers
of
applications
per
year
for
most
crops,
will
significantly
reduce
loading
of
diazinon
to
water
bodies.
As
a
general
policy,
the
EPA
does
not
endorse
specific
alternatives,
but
rather,
informs
stakeholders
of
which
alternatives
are
efficacious.

Integrated
Pest
Management
(
San
Francisco
Department
of
the
Environment)

12.
Comment:
EPA's
economic
assessments
for
diazinon
use
did
not
consider
viability
of
non­
pesticidal
controls
(
integrated
pest
management),
nor
did
they
consider
the
economic
costs
of
the
significant
risk
to
aquatic
organisms.

Response:
The
practice
of
integrated
pest
management
includes
the
use
of
pesticides,
along
with
cultural,
biological,
and
other
non­
chemical
control
measures.
The
Agency
did
take
into
consideration
the
availability
of
effective,
non­
chemical
alternatives.
In
many
cases,
however,
non­
chemical
control
measures,
although
contributing
to
the
management
of
particular
pests,
may
not
act
as
quickly
when
used
alone,
nor
will
they
provide
the
degree
of
economic
control
required
by
many
crops.
EPA
assesses
the
range
and
combination
of
available
control
options
and
identifies
the
least
costly
alternatives
in
predicting
impact.
The
benefits
assessments
that
the
Agency
performed
for
diazinon
are
available
in
EPA's
public
docket
(
docket
#
OPP­
2002­
0251).
Also,
EPA
historically
has
not
assessed
the
economic
impacts
from
risks
to
aquatic
organisms,
particularly
because
the
Agency
does
not
have
a
reliable
source
of
information
as
to
what
the
costs
of
water
quality
management
are.
(
See
response
to
#
14.)
9
Benefits
Assessment
Process
(
Makhteshim­
Agan
of
North
America)
13.
Comment:
A
clear,
quantitative
process
for
evaluating
the
benefits
of
using
diazinon
(
including
uncertainty)
should
be
provided
in
the
IRED.
The
benefits
assessment
summary
in
the
IRED
does
not
provide
this
information.

Response:
Each
of
EPA's
benefits
assessments
includes
a
description
of
the
scope
and
limitation
of
the
methodology.
The
benefits
assessments
are
designed
to
respond
to
risk
managers'
requests
for
information
on
the
impact
of
regulatory
changes
proposed
to
protect
workers
or
the
environment
(
as
per
FIFRA),
and
as
such,
are
based
on
what
risk
managers
believe
are
viable
mitigation
options.

In
estimating
the
impacts
of
proposed
mitigation
options,
the
Agency
first
identifies
the
major
pests
controlled
by
the
pesticide
and
any
particularities
of
use,
such
as
timing
of
applications
and
application
methods.
Sources
of
information
include
USDA
Crop
Profiles,
USDA
Agricultural
Statistics,
field
experts,
state
recommendations,
and
proprietary
data.
EPA
then
examines
those
sources
for
alternate
chemical
or
non­
chemical
control
measures
for
each
major
pest.
EPA
estimates
yield
and
quality
impacts
from
field
studies,
efficacy
or
product
performance
data,
and
experts
in
the
production
systems,
and
also
considers
the
implications
to
IPM
programs
and
potential
outbreaks
of
secondary
pests.

Based
on
the
biological
impacts,
EPA
calculates
the
economic
impacts,
taking
into
consideration
revenue
losses
stemming
from
yield
and
quality
losses,
as
well
as
cost
increases
stemming
from
more
expensive
alternatives
and
other
changes
in
production.
Sources
used
include
USDA
Crop
Profiles,
USDA
Agricultural
Statistics,
and
crop
budgets
prepared
by
land
grant
universities
or
state
agencies.
EPA
examines
the
per­
acre
losses
to
the
individual
dependent
on
the
pesticide,
and
compares
that
to
estimated
returns
with
the
pesticide.
The
Agency
also
aggregates
losses
at
the
state,
regional
and/
or
national
levels,
given
the
percent
of
acres
treated
with
the
pesticide,
and
compares
that
to
the
gross
value
of
production.
In
general,
EPA
assumes
that
there
will
be
no
changes
in
the
price
of
the
commodity,
which
could
reduce
the
impacts
to
the
growers,
and
the
Agency
does
not
consider
the
possibility
of
growers
switching
to
an
alternative
crop.

(
Bay
Area
Stormwater
Management
Agencies
Association
and
California
Water
Quality
Control
Board)

14.
Comment:
EPA
should
include
costs
to
water
quality
agencies
and
economic
impacts
from
habitat
impairment
in
all
pesticide
use
economic
assessments.
Only
with
such
analyses
can
EPA
present
a
fair
picture
of
the
benefits
and
detriments
of
continued
diazinon
use.
10
Response:
Historically,
EPA
has
not
assessed
the
economic
impacts
to
water
quality
agencies
and
from
habitat
impairment,
particularly
because
the
Agency
does
not
have
a
reliable
source
of
information
as
to
what
the
costs
of
water
quality
management
are.
Also,
EPA's
benefits
assessments
typically
focus
on
how
proposed
regulatory
actions
would
affect
pesticide
users,
mainly
growers
of
particular
commodities,
rather
than
water
quality
agencies.
In
addition,
in
its
drinking
water
assessment,
the
Agency
did
not
consider
acute
or
chronic
risks
resulting
from
use
of
diazinon
to
be
of
concern
for
any
populations,
and
so
would
not
have
deemed
a
benefits
assessment
necessary,
according
to
the
normal
criteria
for
benefits
assessments
(
see
response
to
#
18).

Stop
Sale
Date
(
Oklahoma
State
University
Extension)

15.
Comment:
EPA
should
establish
a
stop
use
date
that
is
different
from
the
stop
sale
date
for
outdoor
non­
agricultural
use
products,
because
people
who
buy
products
containing
diazinon
at
the
end
of
the
two­
year
phase
out
period
will
not
be
given
ample
time
to
use
them.
Retailers
should
be
provided
with
a
system
by
which
to
dispose
of
diazinoncontaining
products
after
the
stop­
sale
date.

Response:
The
stop
sale
date
for
outdoor
non­
agricultural
use
products
by
retailers
is
December
31,
2004;
however,
use
of
such
products
may
continue
until
stocks
are
exhausted.
Any
such
uses
must
be
in
accordance
with
the
label.
After
December
31,
2004,
the
technical
registrants,
Syngenta
Crop
Protection,
Inc.
and
Makhteshim
Chemical
Works,
Ltd.,
will
buy
back
any
unopened
diazinon­
containing
products
formulated
for
outdoor
non­
agricultural
use
from
retailers.

Additionally,
the
two
year
phase­
outs
recommended
in
the
IRED
apply
to
agricultural,
not
outdoor
non­
agricultural
diazinon
products,
and
so
will
not
affect
people
who
buy
outdoor
non­
agricultural
products
close
to
the
December
31,
2004,
end
sale
date.

Cancellation
of
Aerial
Application
(
California
Melon
Research
Board,
Michigan
Blueberry
Growers
Marketing,
National
Agricultural
Avian
Association,
Western
Growers
Association,
MANA)

16.
Comment:
EPA
should
continue
to
allow
aerial
applications
on
melons,
lettuce,
and
blueberries.
Late
in
the
growing
season,
spray
rigs
cannot
move
through
the
fields
without
crushing
fruit.
In
addition,
in
cases
where
furrow
irrigation
is
used,
it
is
impossible
to
enter
fields
after
water
begins
to
run.

Response:
In
the
Occupational
and
Residential
Exposure
Assessment,
the
Agency
identified
six
major
aerial
handler
scenarios,
which,
when
combined
with
the
typical
range
of
application
rates,
resulted
in
nine
handler
risk
scenarios
for
all
crops
treated
with
diazinon.
Dermal
and
inhalation
risk
estimates
are
expressed
in
terms
of
the
margin
of
11
exposure
(
MOE),
which
is
the
ratio
of
the
NOAEL
or
LOAEL
to
the
exposure.
Of
the
scenarios
considered
in
the
diazinon
risk
assessment,
only
two
short
term
inhalation
MOEs
exceed
the
target
values,
and
are
therefore
below
EPA's
level
of
concern.
Additionally,
it
is
the
Agency's
belief
that
aerial
applications
of
diazinon
are
directed
primarily
at
late
season
pests,
and
that
adequate
alternatives
are
available
for
their
control.

Based
on
additional
data
provided
by
the
lettuce
growers
showing
actual
numbers
of
acres
treated
per
day,
EPA
refined
the
exposure
portion
of
the
handler
assessment
for
lettuce
(
See
"
HED's
Refinement
of
Handler
Risks
for
Diazinon
Treated
Lettuce").
In
this
refined
assessment,
EPA
calculated
MOE
and
ARI
values
for
handlers
at
the
90th
percentile
of
acres
treated
at
the
0.5
lb
ai/
Acre
rate,
in
addition
to
the
maximum
application
rate.
Risks
to
aerial
applicators
were
found
to
be
acceptable
at
the
90th
percentile
of
acres
treated
at
the
0.5
lb
ai/
Acre
application
rate.
Therefore,
the
Agency
has
decided
to
allow
one
aerial
application
of
diazinon
per
crop
to
lettuce.

The
risks
to
aerial
applicators
from
diazinon
when
treating
other
crops
are
still
unacceptable
when
the
Agency
default
values
for
acres
treated
are
considered.
These
default
values
are
considered
to
be
reasonable,
based
on
available
cropping
patterns,
and
it
is
Agency
policy
to
use
the
default
values
unless
direct
evidence
allows
the
Agency
to
refine
the
assessment.
The
Agency
believes
that
for
crops
other
than
lettuce,
the
risks
from
aerial
applications
are
high
compared
to
the
benefits,
and
therefore,
continues
to
support
the
cancellation
of
all
other
aerial
applications.

Cancellation
of
Granular
Uses
(
Oklahoma
State
University
Extension,
California
Melon
Research
Board,
Western
Growers
Association,
MANA)

17.
Comment:
EPA
should
allow
continued
use
of
granular
formulations.
Wet
soils
make
liquid
applications
infeasible,
and
no
alternatives
are
currently
available
at
planting
time.
Without
an
at­
plant
application
of
granular
diazinon,
stand
reductions
of
over
50%
may
occur
due
to
soil
borne
pests.

Response:
EPA
acknowledges
that
granular
formulations
are
preferred
to
liquids
by
lettuce
and
melon
growers
because
the
soil
textures
in
the
lettuce
and
melon
growing
regions
of
Arizona
and
California
make
liquid
applications
difficult.
The
lettuce
growers
made
a
strong
case
for
needing
granular
applications
to
lettuce.
Therefore,
EPA
will
continue
to
allow
use
of
granular
diazinon
on
lettuce
at
a
reduced
application
rate
of
2.0
lbs
ai/
A
as
Special
Local
Needs
labels
for
CA
and
AZ
until
December
2008,
in
order
to
give
lettuce
growers
additional
time
to
either
find
an
acceptable
alternative
product,
or
to
adapt
to
the
use
of
other
formulations.
According
to
the
Pest
Management
Strategic
Plan
for
California
Melons,
irrigation
is
used
for
all
California
melons,
and
sprinkler
irrigation
can
be
used
to
germinate
a
direct
seeded
crop.
This
indicates
that
irrigation
is
already
used
on
seedlings;
the
Agency
believes
that
12
the
at­
plant
chemigated
sprays
would
therefore
provide
acceptable
alternatives
to
granular
formulations
for
melons.

Overall,
however,
diazinon
granular
formulations
are
one
of
the
most
toxic
to
birds.
A
single
14G
granule
is
capable
of
killing
small
birds.
Even
when
granules
are
incorporated,
birds
may
still
come
in
contact
with
them
by
foraging
beneath
the
surface.
Granular
formulations
also
pose
risks
to
applicators
(
aggregate
risk
index
values
range
from
0.24
to
0.90),
since
soil
application
rates
tend
to
be
high.

Because
of
the
unacceptable
risks
posed
to
birds
and
the
effectiveness
of
alternative
formulations,
EPA
will
not
allow
the
continued
use
of
granular
formulations
(
except
for
24(
c)
registrations
for
lettuce
and
cranberries.

Nursery
and
Cut
Flower
Uses
(
Bay
Area
Stormwater
Management
Agencies
Association,
California
Regional
Water
Quality
Control
Board,
San
Francisco
Department
of
the
Environment)

18.
Comment:
EPA's
Biological
and
Economic
Analysis
Division
(
BEAD)
should
have
performed
a
benefits
analysis
for
nursery
and
cut
flower
uses
and
considered
whether
they
are
necessary
in
light
of
available
alternatives.

Response:
EPA
selected
diazinon
uses
requiring
benefits
assessments
based
on
several
criteria,
including
occupational
risk,
risk
to
wildlife,
and
percent
of
the
crop's
acreage
treated
with
diazinon.
Because
the
diazinon
human
health
and
environmental
risk
assessments
did
not
identify
risks
of
concern
from
nursery
and
cut
flower
uses,
a
formal
benefits
assessment
was
not
deemed
necessary.
This,
along
with
at
least
one
indication
of
relatively
low
use
of
this
chemical
in
this
sector,
meant
that
these
use
sites
were
not
included
on
the
limited
list
of
sites
EPA
could
reasonably
include
in
its
in­
depth
benefits
assessments.
This
indication
was
a
low
percent
crop
treated
(
4%)
used
in
the
ornamentals
sector,
as
listed
in
the
Quantitative
Usage
Analysis
(
QUA)
generated
for
diazinon
in
1997.

Risks
to
Wildlife
(
Natural
Resource
Defense
Council,
World
Wildlife
Fund,
Beyond
Pesticides,
American
Bird
Conservancy)

19.
Comment:
EPA's
environmental
risk
mitigation
strategy
does
not
adequately
address
risks
to
birds,
aquatic
wildlife,
or
beneficial
insects.
This
risk
is
too
great
to
justify
reregistration
of
diazinon.

Response:
EPA
is
required
under
FIFRA
to
take
both
the
risks
and
benefits
of
a
chemical's
use
into
consideration
during
the
reregistration
process.
Applications
have
13
been
restricted
to
those
uses
with
high
benefits.
For
uses
that
remain,
EPA
is
requiring
mitigation
measures
that
are
expected
to
reduce
risks
to
wildlife.
Deletion
of
granular
formulations
(
except
lettuce
and
cranberries
in
California
and
Arizona),
deletion
of
seed
treatment
uses,
deletion
of
aerial
applications
(
except
lettuce),
reduction
of
allowable
number
of
applications
for
most
crops,
and
deletion
of
foliar
applications
to
most
vegetable
crops
will
substantially
reduce
or
eliminate
the
highest
risk
uses.
Though
it
is
not
feasible
to
calculate
the
amount
of
risk
reduction
that
will
be
achieved,
these
mitigation
measures
are
expected
to
reduce
the
amount
and
duration
of
exposure,
and
therefore,
reduce
the
risks
to
wildlife
from
diazinon.

Use
on
Seedcorn
(
Gustafson
LLC,
National
Corn
Growers
Association,
Ohio
Agricultural
Research
and
Development
Center,
Virginia
Polytechnic
Institute
and
State
University,
MANA)

20.
Comment:
EPA
should
allow
diazinon
to
remain
on
the
market
for
use
as
a
farmerapplied
hopper
box
seed
treatment
for
control
of
pests
such
as
the
seed
corn
maggot.
Without
diazinon,
corn
growers
would
need
to
apply
more
of
an
alternative
active
ingredient,
pay
substantially
more
for
an
effective
alternative,
or
both.
Alternatives
are
more
costly
and
prone
to
resistance.

Response:
EPA
is
canceling
all
diazinon
seed
treatments
because
of
the
associated
high
risks
to
birds.
Risk
Quotient
values
for
seed
corn
treatments
ranged
as
high
as
1.38.
A
single
14G
granule
has
been
shown
to
be
capable
of
killing
a
small
bird,
and
a
single
treated
seed
can
contain
two
and
a
half
times
the
residue
of
a
14G
granule,
which
is
more
than
enough
toxicant
to
kill
a
small
bird.

Additionally,
according
to
BEAD's
Quantitative
Usage
Analysis
(
QUA)
of
January,
2002,
diazinon
is
applied
to
0.1
percent
of
corn
(
71,264
acres),
mostly
for
seed
treatment
against
the
seed
corn
maggot.
The
main
seed
treatment
alternatives
available
for
seed
corn
maggot
control
are:
imidacloprid,
permethrin,
tefluthrin,
and
chlorpyrifos.
The
principal
at­
plant
treatment
alternatives
for
seed
corn
maggot
control
include:
chlorpyrifos,
terbufos,
tebupirimiphos
+
cyfluthrin,
chlorethoxyfos,
tefluthrin,
fipronil,
carbofuran
and
phorate.
14
Spray
Drift
Label
Language
(
Oklahoma
State
University
Extension,
Northwest
Horticultural
Council,
U.
S.
Apple
Association,
MANA)

21.
Comment:
EPA
should
not
require
registrants
to
use
either
the
spray
drift
language
from
the
"
Draft
Guidance
for
Pesticide
Registrants
on
New
Labeling
Statements
for
Spray
and
Dust
Drift
Mitigation"
or
the
alternative
language
presented
in
the
IRED.
EPA
should
postpone
spray
drift
changes
or
additions
to
the
label
until
it
has
finalized
its
general
policy
reviews
of
spray
drift
language.

Response:
EPA
acknowledges
that
it
is
important
to
use
consistent
interim
spray
drift
language
until
policy
reviews
of
generic
spray
drift
language
have
been
completed.
The
Agency
will
therefore
change
the
language
that
appears
in
the
IRED
to
the
following:
"
The
Agency
is
currently
working
with
stakeholders
to
develop
appropriate
generic
label
statements
to
address
spray
drift
risk.
Once
this
process
has
been
completed,
diazinon
product
labels
will
need
to
be
revised
to
include
this
additional
language."

Considering
Degradates
in
Risk
Assessments
(
Natural
Resources
Defense
Council
and
American
Bird
Conservancy)

22.
Comment:
EPA
should
consider
diazinon's
toxic
degradates
in
its
modeling
and
monitoring
data,
or
at
least
include
an
uncertainty
factor
to
compensate
for
their
presence.
The
toxicity
of
diazinon's
degradates
is
uncertain,
but
other
OPs
have
toxicologically
significant
degradates.

Response:
Diazinon
has
two
primary
degradates,
diazoxon
and
oxypyrimidine.
EPA
acknowledges
that
diazoxon
is
toxicologically
significant.
However,
in
the
environment,
diazoxon
is
not
persistent,
and
due
to
the
short
duration
of
time
in
which
exposure
could
occur,
EPA
does
not
consider
diazoxon
to
pose
unreasonable
risk.
There
is
some
recent
evidence
to
suggest
that
diazoxon
may
form
during
water
treatment.
EPA
will
be
pursuing
this
evidence
and
may
decide
that
future
mitigation
is
necessary.
However,
this
investigation
is
ongoing
and
it
would
be
premature
to
regulate
based
on
this
evidence
at
this
time.
Oxypyrimidine,
diazinon's
other
primary
degradate,
is
persistent,
but
not
toxicologically
significant.
Therefore,
the
Agency
does
not
believe
it
necessary
to
consider
these
degradates
in
its
modeling
and
monitoring
data.
15
Applications
to
Melons
(
California
Melon
Research
Board,
Western
Growers
Association,
MANA)

23.
Comment:
EPA
should
allow
at
least
three
foliar
applications
on
melons,
with
a
rate
of
3/
4
pound
(
per
acre)
and
a
pre­
harvest
interval
of
three
days.
Multiple
applications
would
give
growers
flexibility
without
a
radical
hardship
in
management
of
sucking
insects
such
as
leafhoppers
and
aphids.
Alternatives
are
more
expensive
and
have
not
proven
effective
at
providing
residual,
late
season
pest
control.
There
are
no
alternatives
for
leafhopper
control
in
California.

Response:
EPA
acknowledges
that
the
pre­
harvest
interval
for
melons
was
listed
in
Table
7
of
the
IRED
as
7
days,
and
that
this
was
in
error.
The
correct
pre­
harvest
interval
for
melons
is
3
days.

Additionally,
EPA
recognizes
that
most
alternatives
are
more
expensive
than
products
containing
diazinon.
Based
on
available
efficacy
information
(
discussed
in
the
original
benefits
assessment),
EPA
believes
that
the
available
alternatives
will
provide
adequate
late
season
pest
control.
EPA
acknowledges
that
two
years
may
be
an
insufficient
phaseout
time
for
growers
to
adjust
to
the
newer
alternatives,
such
as
thiamethoxam
and
pymetrozine;
therefore,
EPA
will
grant
a
5­
year
phase­
out
period
for
foliar
applications
to
melons.
After
this
phase­
out,
the
only
allowable
foliar
application
to
melons
will
be
for
honeydew
melons,
in
order
to
control
thrips
(
See
response
#
25.)

24.
Comment:
Granular
formulations
must
be
maintained
for
melons
grown
in
desert
areas,
where
no
efficacious
alternatives
exist
for
soil­
borne
pests.
Without
an
at­
plant
application
of
granular
diazinon,
stand
reductions
of
over
50
percent
may
occur
due
to
damage
by
soil
pests.

Response:
The
importance
of
diazinon
in
controlling
soil
insect
pests
in
melons
was
addressed
in
some
detail
in
EPA's
benefits
assessment
for
melons.
EPA
believes
that
liquid
formulations
of
diazinon
used
at­
plant
will
provide
efficacious
control
of
soil­
borne
pests.
EPA
acknowledges
that
there
may
be
some
initial
difficulty
in
adapting
application
of
liquid
diazinon
to
desert
conditions.
However,
EPA
is
extending
the
phase­
out
period
for
melons
to
five
years,
and
believes
that
this
phase­
out
time
period,
along
with
effective
alternatives
for
some
of
the
pests
involved
(
e.
g.,
imidacloprid
for
the
cucumber
beetle),
should
provide
for
adequate
pest
control
while
the
use
of
liquid
diazinon
is
being
perfected.

Carbaryl
also
provides
control
of
some
types
of
soil
pests.
These
points
were
made
in
BEAD's
benefits
assessment
for
melons.
In
addition,
EPA
believes
that
the
50
percent
stand
reductions
apply
to
completely
uncontrolled
infestations
of
these
pests,
which
growers
are
unlikely
to
allow.
In
the
original
benefits
assessment
for
this
crop
group,
EPA
described
the
losses
it
believes
are
likely
to
occur
in
melons
in
the
event
of
a
loss
of
diazinon.
16
25.
Comment:
Diazinon
use
on
melons
needs
to
be
maintained,
especially
for
late
season
control.
The
Japanese
market
demands
blemish­
free
fruit.
Alternatives
are
less
effective
at
providing
residual,
late­
season
control.

Response:
EPA
agrees
that
the
Japanese
market
demands
blemished­
free
honeydew
melons,
but
believes
that
this
demand
does
not
extend
to
other
types
of
melons,
such
as
cantaloupes.
Examination
of
data
compiled
by
USDA
indicates
that
only
2
percent
of
the
cantaloupe
harvest
is
destined
for
the
total
export
market.
Thus,
economic
impacts
to
the
overall
industry,
in
the
unlikely
event
of
total
rejection
of
cantaloupes
and
watermelons
by
the
Japanese
market,
can
reasonably
be
characterized
as
low
enough
to
be
survivable.
Data
for
2001,
compiled
by
USDA's
Economic
Research
Service
(
ERS),
available
at
http://
usda.
mannlib.
cornell.
edu/
data­
sets/
specialty/
89011/,
indicate
that
in
terms
of
weight
of
melons
exported,
6.4
percent
of
cantaloupes
and
6.2
percent
of
all
watermelons
grown
in
the
US
were
exported.
It
is
unclear
how
much
of
this
was
destined
for
Japan,
but
these
figures
do
suggest
that
the
cantaloupe
and
watermelon
industries
have
significant
markets
other
than
Japan.
EPA
has
been
unable
to
find
documentation
to
corroborate
the
assertion
that
the
Japanese
market
for
these
melons,
whatever
its
size,
would
be
significantly
affected
by
blemishes
(
whereas
honeydews
are
specifically
mentioned
in
this
context
­
e.
g.,
in
the
USDA
crop
profile
for
California
melons,
2000).
Therefore,
as
stated
above
in
comment
#
23,
EPA
will
allow
continued
foliar
applications
of
diazinon
to
honeydew
melons
only.

Applications
to
Blueberries
(
Michigan
Blueberry
Growers
Marketing,
MANA)

26.
Comment:
BEAD's
assessment
states
that
100
percent
of
highbush
blueberry
acreage
is
hand
harvested.
An
estimate
of
20
percent
is
more
realistic.

Response:
The
Agency
acknowledges
that
substantially
less
than
100
percent
of
highbush
blueberry
acreage
is
harvested
by
hand.
In
the
original
assessment,
this
description
was
used
to
characterize
crop
production
of
highbush
blueberries.
However,
a
much
lower
value
for
hand
harvesting
acreage
does
not
affect
the
conclusions
of
the
original
benefits
assessment,
because
the
risks
of
concern
for
diazinon
are
for
workers
who
mix
and
apply
the
chemical,
and
not
for
those
who
conduct
hand
harvesting
activities.
Thus,
mitigation
options
do
not
directly
address
hand
harvest.

27.
Comment:
BEAD's
assessment
states
that
impacts
to
blueberry
growers
from
the
loss
of
diazinon
are
relatively
small.
Just
because
documented
usage
is
small,
it
does
not
mean
that
impact
is
as
well.
In
addition,
the
chemical
costs
used
in
Table
6
of
the
IRED
are
incorrect.
MBG
provides
costs
that
in
its
opinion
should
be
used
by
the
Agency
in
its
benefits
assessment.
17
Response:
The
Agency
acknowledges
that
when
documented
usage
is
small,
it
does
not
necessarily
mean
that
impacts
to
growers
are
small.
EPA
recalculated
the
impacts
of
losing
diazinon
using
data
provided
by
MBG.
Results,
even
when
the
costs
submitted
by
MBG
were
used,
indicated
that
economic
impacts
remain
small.
For
instance,
replacement
of
diazinon
with
azinphos­
methyl
on
those
acres
increases
total
treatment
costs
for
North­
Central
highbush
blueberries
by
about
$
15,000
(
over
the
entire
region),
because
of
a
higher
cost
per
acre
of
azinphos­
methyl
over
diazinon.
Similarly,
replacement
of
diazinon
with
methomyl
increases
total
treatment
costs
by
$
16,000,
while
replacement
with
phosmet,
for
example,
has
essentially
no
impact
on
costs.
Overall
impacts
are
relatively
small
because
diazinon­
treated
acreage
is
small
(
5%
of
the
total
highbush
acreage).
Replacement
of
diazinon
with
azinphos­
methyl
or
phosmet
on
5,200
acre­
treatments
with
diazinon
in
New
Jersey
gives
impacts
of
$
54,000
and
$
27,000,
respectively,
while
replacement
with
a
composite
of
alternatives
gives
essentially
no
impact.
Impacts
in
the
North­
Central
region
of
up
to
$
15,000
­
$
16,000
are
less
than
0.1%
of
the
total
value
in
that
region,
which
equals
$
54,000,000,
while
impacts
in
New
Jersey
of
up
to
$
27,000
­
$
54,000
are
less
0.2%
of
the
total
value
in
that
state,
which
equals
$
36,000,000.
Note
that
the
impacts
being
discussed
here
are
economic
ones.
EPA
believes
the
pest
management
impacts
characterized
in
its
original
benefits
assessments
adequately
addressed
the
non­
economic
impacts.
Essentially,
EPA
believes
the
currently
available
broad­
spectrum
alternatives
­
azinphos­
methyl,
phosmet,
and
carbaryl
­
along
with
the
newly
registered
and
more
selective
alternatives
­
tebufenozide,
spinosad,
and
pyriproxyfen
­
will
give
growers
adequate
options
(
in
terms
of
efficacious
pest
control)
to
control
the
pests
targeted
by
diazinon
at
least
for
the
time
frame
assessed
(
1
to
5
years).

28.
Comment:
The
blueberry
industry
has
no
good
long­
term
alternatives
to
diazinon.
Guthion
and
Imidan
are
currently
under
four
and
five
year
conditional
registrations
and
may
not
be
available
in
the
future.

Response:
The
benefit
assessments
that
were
conducted
by
BEAD
addressed
only
the
potential
short­
term
(
1
to
5
year)
impacts.
As
long
as
other
alternatives
are
available,
EPA
believes
that
adequate
pest
control
measures
are
available
in
the
short
term.
The
Agency
agrees
that
the
losses
of
azinphos­
methyl
and
phosmet,
if
they
were
made
permanent,
would
make
it
harder
for
growers
to
control
some
pests
effectively.
However
for
other
pests
that
diazinon
currently
targets,
the
newly
registered
reduced­
risk
and
OPalternative
compounds
pyriproxyfen,
spinosad,
and
tebufenozide
should
provide
adequate
control,
even
in
the
absence
of
these
broad­
spectrum
organophosphates.

29.
Comment:
EPA
should
allow
up
to
three
foliar
applications
for
foliar
pests
and
fire
ants
for
blueberries,
as
well
as
the
ability
to
apply
aerially.
Diazinon
is
also
needed
for
weevil
control,
since
its
primary
alternative,
azinphos
methyl,
is
registered
conditionally
only
until
October
31,
2005.
Diazinon
is
the
only
effective
product
registered
for
fire
ant
control
in
southern
blueberry
growing
regions.
If
left
uncontrolled,
fire
ants
can
prevent
workers
from
harvesting
the
crop
in
a
timely
manner.
Aerial
applications
are
needed
because
lowbush
blueberries
are
typically
not
planted
in
rows.
Response:
The
information
provided
above
does
not
change
the
conclusion
of
the
18
Agency's
original
benefits
assessment
for
blueberries.
The
percent
crop
treated
in
the
US
is
low
(
16%),
and
the
highbush
blueberry
industry
has
effective
alternatives
to
diazinon
for
all
blueberry
pests;
therefore,
the
Agency
will
allow
only
one
foliar
application
per
season.
Additionally,
the
Agency
acknowledges
that
aerial
application
of
diazinon
is
important
to
the
blueberry
industry;
however,
the
risks
posed
to
workers
from
aerial
application
are
high
when
compared
with
the
benefits
(
see
response
to
#
14).
Therefore
the
Agency
will
not
allow
aerial
application
of
diazinon
to
blueberries.

Applications
to
Lettuce
(
MANA)

30.
Comment:
EPA
should
allow
continued
foliar
and
soil
application
uses
for
lettuce.
There
are
no
adequate
alternatives
to
control
soil
pests,
and
at
least
three
foliar
applications
are
needed
to
control
aphids.
Alternatives
are
more
costly,
less
effective,
or
have
application
restrictions.

Response:
In
its
benefits
assessment,
BEAD
concluded
that
cancellation
of
the
diazinon
use
for
controlling
soil
insects
on
lettuce
would
have
a
major
impact
on
both
head
and
leaf
lettuce
production,
since
there
are
no
suitable
alternatives
available.
EPA
believes
that
a
single
soil
application
should
be
adequate
to
address
soil
pest
problems
for
lettuce.
Additionally,
EPA
has
decided
to
allow
one
foliar
application
of
diazinon
per
crop
to
lettuce.
(
See
response
#
14.)

Applications
to
Apples
(
U.
S.
Apple
Association,
MANA,
Northwest
Horticultural
Council)

31.
Comment:
In
addition
to
one
application
to
control
the
woolly
apple
aphid,
EPA
should
also
keep
one
application
on
the
label
to
control
San
Jose
scale
crawlers,
and
one
application
to
control
rosy
apple
aphids
and
mealybugs.
Although
pyriproxyfen
is
an
excellent
alternative
for
control
of
scale
crawlers,
it
would
be
the
only
insecticide
left,
and
a
second
chemistry
is
needed
for
resistance
management
purposes.
Thiamethoxam
controls
both
rosy
apple
aphid
and
mealybugs,
but
in
the
future
its
use
may
be
limited
to
Michigan,
Pennsylvania,
and
New
York,
leaving
North
Carolina
growers
with
only
diazinon
and
dimethoate
for
mealybug
control.

Response:
EPA
acknowledges
that
resistance
management
is
an
important
consideration
in
apple
production,
and
that
it
is
important
to
allow
more
than
one
tool
for
management
of
a
particular
pest
on
the
market.
The
EPA
will
therefore
allow
two
foliar
applications
per
season
for
control
of
woolly
apple
aphids
and
San
Jose
crawlers.
Although
thiamethoxam
may
not
be
available
for
use
in
North
Carolina
for
control
of
the
rosy
apple
aphids
and
mealybugs,
there
is
little
evidence
indicating
that
diazinon
is
being
used
in
the
State
to
control
these
pests.
USDA
NASS
pesticide
usage
data
indicate
that
diazinon
was
19
not
used
on
North
Carolina
apples
in
1999
or
2001.
Due
to
the
high
occupational
risks
and
the
low
percent
crop
treated,
EPA
stands
by
its
decision
to
cancel
use
of
diazinon
on
apples
for
the
control
of
rosy
apple
aphids
and
mealy
bugs.

32.
Comment:
EPA
should
not
require
use
of
closed
cab
equipment
for
applicators.
Narrow
orchard
rows
and
trellis
systems
do
not
accommodate
closed
cab
tractors.
Incidents
reports
document
no
evidence
that
negative
effects
to
orchard
air
blast
sprayer
operators
result
from
applying
diazinon.
Instead
of
closed
cab
equipment,
EPA
should
require
use
of
maximum
personal
protective
equipment.

Response:
EPA
acknowledges
that
requiring
use
of
closed
cab
equipment
in
apple
orchards
will
make
it
difficult
to
fit
tractors
down
narrow
orchard
rows.
Although
only
four
percent
of
US
apples
are
treated
with
diazinon,
and
risks
to
workers
are
above
the
Agency's
levels
of
concern,
even
with
use
of
closed
cabs,
the
Agency
realizes
that
diazinon
is
the
only
tool
available
for
control
of
woolly
apple
aphids,
which
are
highly
damaging
to
crop
yield.
Because
of
the
high
benefits
of
diazinon
use
on
apples
to
control
woolly
apple
aphids,
and
the
difficulty
posed
by
the
requirement
of
closed
cabs,
the
Agency
has
decided
to
waive
the
requirement
of
closed
cab
equipment
for
application
of
diazinon
to
apples,
and
will
instead
require
use
of
maximum
personal
protective
equipment.

Applications
to
Apricots
(
MANA)

33.
Comment:
MANA
supports
growers
requests
to
allow,
in
addition
to
the
single
proposed
application
per
dormant
season,
a
second
application
during
the
growing
season
for
apricots.
Alternatives
exist,
but
they
are
generally
more
costly.
An
in­
season
diazinon
application
is
important
for
resistance
management
of
target
pests.

Response:
EPA
acknowledges
receiving
this
comment,
but
the
information
provided
above
does
not
change
the
conclusion
of
our
original
benefits
assessment.
As
stated
in
BEAD's
benefits
assessment
for
apricots,
during
the
bloom
period,
satisfactory
twig
borer
control
can
be
achieved
with
one
or
two
applications
of
Bacillus
thuringiensis
(
Bt).
Pheromone
mating
disruption
can
also
be
used
during
this
period.
This
approach
is
most
effective
when
used
as
part
of
an
IPM
program,
on
an
area
wide
basis,
and
least
effective
when
used
in
small
orchards
or
when
incorrectly
timed.
During
the
postbloom
stage,
available
alternatives
include
spinosad,
phosmet,
and
carbaryl.

In
addition,
EPA
did
not
receive
additional
comments
regarding
apricots
from
any
other
group.
The
Agency
believes
that
a
second
application
during
the
dormant
season
is
unnecessary,
and
therefore
is
not
granting
such
an
application.
Phase­
out
Period
for
Mushrooms
(
American
Mushroom
Institute,
MANA)

34.
Comment:
Mushroom
growers
should
be
allowed
a
four­
year,
rather
than
a
two­
year,
phase­
out
period
for
use
on
mushrooms.
Two
years
is
not
enough
time
to
develop
20
effective
alternatives.
Worker
exposure
to
wet
spray
is
very
limited,
because
applications
are
made
to
growing
rooms
when
no
crop
or
workers
are
present.
Response:
EPA
cancelled
all
indoor
uses
of
diazinon,
except
for
mushroom
houses,
in
2002.
EPA
believes
that
the
additional
time
mushroom
growers
have
been
allowed
plus
a
two­
year
phase
out
period
after
the
issuance
of
the
IRED
amounts
to
a
sufficient
time
period
to
develop
alternatives.

Trunk
Wraps
(
Bay
Area
Stormwater
Management
Agencies
Association,
California
Regional
Water
Qulaity
Control
Board,
San
Francisco
Department
of
the
Environment)

35.
Comment:
Label
language
should
be
amended
to
clarify
the
fact
that
trunk
wraps
may
be
used
in
agricultural
settings
only.

Response:
EPA
agrees
to
require
the
registrant
to
change
label
language
to
state
that
trunk
wraps
may
be
used
in
agricultural
settings
only.

Minor
Use
Crops
36.
Comment:
Growers
continue
to
need
diazinon
for
dormant
applications
for
walnuts
and
liquid
soil
applications
for
Chinese
broccoli.
(
MANA)

Response:
These
uses
are
not
on
the
current
diazinon
labels.
EPA
is
of
the
opinion
that
these
uses
are
not
necessary,
and
did
not
receive
comments
from
grower
groups
supporting
them.
Therefore,
the
Agency
is
not
granting
dormant
applications
for
walnuts
or
liquid
soil
applications
for
Chinese
broccoli.

37.
Comment:
MANA
argues
that
cancellation
of
Chinese
cabbage,
Chinese
mustard,
Chinese
radishes,
and
mushrooms
is
not
justified,
as
diazinon
uses
will
be
retained
for
similar
crops,
such
as
broccoli,
Brussels
sprouts,
mustard,
cabbage,
and
radishes,
which
have
similar
use
conditions
and
risks.

Response:
The
current
label
allows
for
foliar
applications
only
for
Chinese
cabbage,
Chinese
mustard,
and
Chinese
radish,
and
does
not
include
pre­
plant
soil
treatments
to
control
soil
insects.
This
pre­
plant
soil
application
is
the
only
use
retained
for
cole
crops
and
root
vegetables;
therefore,
the
deletion
of
diazinon
use
on
Chinese
cabbage,
mustard
and
radish
is
consistent
with
the
other
crops.

It
is
unclear
why
the
use
on
mushrooms
was
in
this
list
since
use
in
mushroom
houses
is
significantly
different
than
applications
to
other
vegetable
crops.
The
use
on
mushrooms
has
been
discussed
earlier
in
this
document.
(
See
response
to
#
34.)
While
EPA
acknowledges
that
there
are
limited
alternatives
to
use
in
mushroom
houses,
the
assessed
risks
to
workers
from
this
indoor
use
are
too
great
to
allow
this
indoor
use
to
continue
21
indefinitely.
