UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Proposed
Decisions
on
Nine
Phosmet
Restricted
Entry
Intervals
June
9,
2006
Part
I:
Summary
and
Background
The
purpose
of
this
document
is
to
outline
the
Agency's
rationale
for
its
decisions
on
whether
the
existing
restricted
entry
intervals
(
REIs)
are
appropriate
and
solicit
comment.
Each
crop­
specific
impact
assessment
lists
information
of
particular
interest
to
the
Agency
relevant
to
the
risk
benefit
determination,
such
as
regional
pest
problems,
comparative
efficacy
data,
non­
chemical
controls,
and
constraints
on
use
of
alternatives.
The
Agency
is
also
soliciting
comment
on
the
particular
reentry
activities
for
each
crop
and
the
timing
of
these
activities
relative
to
phosmet
applications.
All
supporting
documents,
including
the
worker
and
ecological
risk
assessments,
and
the
crop­
by­
crop
grower
impact
assessments
are
available
at:
www.
regulations.
gov
under
docket
number
EPA­
HQ­
OPP­
2002­
0354.
Public
comments
will
be
accepted
for
60­
days
following
publication
of
a
Federal
Register
Notice
of
Availability
on
June
9,
2006.
After
the
close
of
the
comment
period
(
August
9,
2006),
the
Agency
will
review
all
comments
received
and
issue
its
final
decision
later
this
Fall.
That
final
decision
will
include
consideration
of
the
results
of
the
cumulative
risk
assessment
of
the
organophosphate
(
OP)
pesticides.

This
document
is
divided
into
two
parts.
Part
I
contains
general
background
information
and
summaries
of
risk
concerns.
Part
II
contains
the
crop­
by­
crop
proposed
decisions
and
rationale.

Proposed
Decision
and
Comment
Opportunity
Based
on
its
reevaluation
of
the
risks
and
benefits
of
the
current
REIs
for
nine
phosmet
crops
(
apples,
apricots,
highbush
blueberries,
grapes,
nectarines,
peaches,
pears,
and
plums/
prunes)
the
Agency
is
proposing
the
following
intervals:

Crop
Current
REI
Proposed
REI
Apples
3
days
7
days
Apricots
3
days
14
days
Blueberries
24
hours
3
days
Grapes
14
days
14
days
peaches/
nectarines
3
days
7
days
Pears
3
days
7
days
plums/
prunes
3
days
7
days
2
Regulatory
Context/
Background
Phosmet,
an
organophosphate
insecticide
first
registered
in
1966,
is
currently
used
on
a
variety
of
orchard
fruits,
berries,
nuts,
and
other
crops.
In
connection
with
the
Federal
Insecticide,
Fungicide
and
Rodenticide
Act
(
FIFRA)
reregistration
requirements
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA)
tolerance
reassessment
processes,
EPA
issued
an
Interim
Reregistration
Eligbility
Decision
(
IRED)
for
phosmet
in
October
2001.

In
the
phosmet
IRED,
the
Agency
concluded,
based
on
evaluation
of
the
risks
and
benefits
of
the
use
of
phosmet,
that
three
uses
would
be
cancelled,
36
uses
were
eligible
for
reregistration,
and
nine
uses
would
be
time­
limited
for
a
period
of
five
years,
contingent
on
the
submission
of
additional
data
and
pending
completion
of
the
cumulative
risk
assessment
for
OPs.
Concurrent
with
the
IRED
in
2001,
a
Memorandum
of
Agreement
(
MOA)
between
EPA
and
the
sole
technical
registrants
of
phosmet,
Gowan
Company,
provided
for
the
development
of
biomonitoring
and
other
data
by
the
registrants
and
a
reevaluation
by
EPA
of
the
nine
REIs
in
2006.
In
addition
to
reevaluating
the
REIs,
the
Agency
has
updated
the
ecological
risk
assessment
for
phosmet
in
order
to
compare
it
to
azinphos­
methyl
(
AZM),
an
alternative
for
several
uses.
After
considering
comments
on
this
proposal,
the
Agency
intends
to
publish
its
final
decision
on
the
REIs
later
this
year.

New
Information
The
Data
Call­
In
associated
with
the
2001
IRED
required
use
and
usage
information
and
biomonitoring
studies
of
post­
application
agricultural
workers.
These
data
have
been
submitted
by
registrants,
reviewed
by
the
Agency,
and
incorporated
into
the
revised
grower
impact
and
worker
assessments.
As
stated
above,
EPA
has
also
updated
the
ecological
risk
assessment
for
phosmet,
with
a
view
toward
better
understanding
the
comparative
risk
of
phosmet
and
AZM,
since
these
chemicals
are
substitutes
for
oneanother
in
some
situations.
All
of
these
supporting
documents
are
available
in
the
public
docket.

United
Farm
Workers
v.
Johnson
This
proposed
decision
is
also
being
issued
in
response
to
a
settlement
agreement
with
the
United
Farm
Workers
and
the
other
plaintiffs
who
sued
the
Agency
in
January
2004
in
the
U.
S.
District
Court
for
the
Western
District
of
Washington
regarding
the
pesticides
AZM
and
phosmet.
The
suit
alleged
that
the
AZM
and
phosmet
IREDs
were
inconsistent
with
the
requirements
of
FIFRA
because
EPA
did
not
appropriately
consider
the
risks
and
benefits
of
these
pesticides.
The
settlement
agreement
effectively
stays
the
legal
challenge
pending
EPA's
reconsideration
of
these
pesticides.
Prior
to
agreeing
to
the
settlement
agreement,
EPA
took
public
comment.

The
settlement
agreement
established
milestones
for
EPA
to
propose
decisions
on
the
reevaluation
of
the
ten
AZM
time­
limited
uses
as
well
as
the
nine
REIs
for
phosmet,
take
3
comment,
and
then
finalize
a
decision
on
these
remaining
uses
by
August
3,
2006.
EPA
has
informed
the
plaintiffs
that
it
now
intends
to
issue
its
final
decision
this
Fall.

In
the
crop­
by­
crop
discussions
in
Part
II
of
this
document,
EPA
is
providing,
in
a
qualitative
manner,
the
logic
and
considerations
that
go
into
its
risk/
benefit
decision
making.
For
phosmet,
since
the
primary
risks
of
concern
are
related
to
re­
entry
workers,
EPA
has
focused
its
reevaluation
on
refining
post­
application
worker
risk
estimates
based
on
a
new
biomonitoring
study.
For
the
grower
impacts,
EPA
focused
on
estimating
the
maximum
feasible
REI
(
i.
e.,
the
point
at
which
phosmet
would
not
be
useful
to
growers),
and
what
alternatives
would
likely
be
used
at
that
point.
The
grower
impact
assessments
are
qualitative
in
that
they
do
not
attempt
to
calculate
the
actual
dollar
cost
of
switching
to
alternative
controls.
In
weighing
risk
management
options,
however,
EPA
considered
whether
the
disruption
to
crop
management
systems
of
switching
to
available
alternatives
would
result
in
less
risk
to
humans
and
the
environment
than
that
posed
by
phosmet.

Summary
of
Revised
Post­
Application
Worker
Assessment
Risks
were
estimated
using
the
Margin
of
Exposure
(
MOE)
approach,
which
is
a
ratio
of
the
body
burden
to
the
toxicological
endpoint(
s)
of
concern.
EPA
believes
an
MOE
of
100
or
greater
(
that
is,
an
exposure
that
is
at
least
100
times
greater
than
the
level
at
which
no
effects
are
seen)
is
not
of
concern
for
phosmet.
EPA's
previous
worker
assessment
in
the
2001
IRED
used
route­
specific
dermal
endpoints.
Because
biomonitoring
data
are
now
available,
EPA
has
selected
oral
endpoints
because
these
are
more
appropriately
compared
to
the
absorbed
dose
calculated
in
the
biomonitoring.

The
toxicological
endpoint
of
concern
is
cholinesterase
(
ChE)
inhibition,
and
in
one
instance
decreased
motor
activity.
For
the
short­
term
risk
calculations
(
up
to
30
days
exposure),
EPA
selected
an
acute
oral
neurotoxicity
study
in
rats.
The
no
observable
adverse
effect
level
(
NOAEL)
in
this
study
was
4.5
mg/
kg/
day;
the
lowest
observed
adverse
effect
level
(
LOAEL)
in
this
study
was
22.5
mg/
kg/
day
(
over
5­
fold
higher)
based
on
red
blood
cell,
plasma,
and
brain
ChE
inhibition
and
decreased
motor
activity.
The
use
of
this
acute
endpoint
for
the
short­
term
worker
assessment
is
supported
by
a
21­
day
dermal
study
also
in
rats,
with
a
LOAEL
of
22.5
based
on
ChE
inhibition
of
plasma
(
males)
and
brain
(
females).
The
NOAEL
in
the
dermal
study
was
15
mg/
kg/
day,
indicating
that
use
of
the
4.5
mg/
kg/
day
NOAEL
from
the
acute
study
is
likely
protective
of
longer
durations
of
exposure.

A
NOAEL
of
1.1
mg/
kg/
day
from
an
oral
chronic
toxicity
study
in
rats
was
used
to
calculate
intermediate
term
risks
(
over
30
days
exposure).
The
LOAEL
in
this
study
was
1.8
mg/
kg/
day
based
on
red
blood
cell
and
plasma
ChE
inhibition,
noted
at
6
months
of
dosing.
The
intermediate­
term
endpoint
is
supported
by
a
LOAEL
of
1.5
mg/
kg/
day
in
a
sub­
chronic
oral
toxicity
study
in
rats
with
interim
measurements
of
ChE
inhibition
beginning
at
7
weeks.
EPA
generally
uses
only
short
term
endpoints
to
estimate
postapplication
risks,
based
on
the
assumption
that
up
to
30
days
of
sustained
exposure
is
a
reasonable
worst­
case
exposure
for
most
re­
entry
activities.
EPA
has
presented
the
4
intermediate­
term
MOEs
in
its
risk­
assessment
as
an
upper­
bound
estimate
for
risk
characterization
purposes.

The
absorbed
dose
values
used
in
risk
calculations
were
from
a
chemical
specific
biomonitoring
study
of
workers
hand
thinning
peaches
treated
with
phosmet
(
MRID
466823­
01).
In
this
study,
two
days
after
the
peaches
had
been
treated
with
phosmet
by
airblast
at
an
application
rate
of
3.0
lbs/
ai/
A,
16
workers
hand
thinned
peaches
for
6.5
hours
on
one
day.
The
workers
in
the
study
wore
long­
sleeved
shirts,
long
pants,
shoes,
socks,
some
head
wear,
and
occasionally
jackets
in
the
morning.
Total
phosmet
absorbed
doses
were
calculated
from
urine
samples
collected
on
the
day
of
exposure
and
for
four
days
after
exposure.
A
thunderstorm
occurred
in
the
afternoon
of
the
monitoring
day.
Workers
took
cover
during
the
storm.
Following
the
storm,
the
workers
re­
entered
the
orchard
to
thin,
even
though
there
was
still
a
light
rain.
According
to
the
crew
foreman,
the
subjects
would
normally
be
expected
to
work
in
light
rain.
When
rain
intensity
increased,
workers
left
the
orchard,
after
only
a
6.5
hour
work
day.
As
a
result,
EPA
has
deemed
it
appropriate
to
apply
certain
"
correction
factors"
to
this
study
to
correct
the
calculation
of
absorbed
dose.

The
dislodgeable
foliar
residue
(
DFR)
values
used
in
the
current
assessment
were
taken
from
a
phosmet
study
on
pear
trees
at
5
lbs/
ai/
A,
the
same
DFR
study
used
in
the
2001
IRED.
A
DFR
study
on
peaches
in
Georgia,
conducted
concurrently
with
the
biomonitoring
could
not
be
used
because
the
rain
storm
precluded
development
of
a
meaningful
residue
dissipation
curve.

The
numerous
correction
factors
applied
to
the
phosmet
biomonitoring
study
are
outlined
in
the
updated
risk
assessment,
"
Phosmet:
Postapplication
Risk
Analysis,"
dated
April
18,
2006,
and
available
in
the
public
docket.
Table
1,
below,
gives
an
overview
of
MOEs
at
3
days
(
the
most
common
current
REI)
and
at
various
application
rates.
Part
II
of
this
document
gives
specific
current
and
proposed
REIs
for
each
crop.

Table
1.
Phosmet
Risk
Summary
for
Fruit
Tree
Thinning
Activities
Application
Rate
lbs/
ai/
A
MOE
at
3
days
Short­
term
MOE
at
3
days
Intermediateterm
Days
to
MOE
of
100
Short­
term
Days
to
MOE
of
100
Intermediate­
term
1.0
110
26
2
24
2.0
54
13
13
34
3.0
36
9
19
40
3.75
29
7
22
44
In
general,
the
biomonitoring
study
increased
the
Agency's
confidence
that
the
risks
to
workers
are
less
than
those
calculated
for
the
IRED.
However,
since
there
were
numerous
residual
uncertainties
associated
with
the
biomonitoring
study,
due
both
to
problems
in
the
conduct
of
the
study
and
also
due
to
inclement
weather,
the
Agency
intends
to
require
additional
biomonitoring
data
to
confirm
the
Agency's
determination.
5
Summary
of
Revised
Ecological
Assessment
EPA
completed
a
limited
update
to
the
2001
Phosmet
IRED
for
the
nine
subject
uses,
taking
into
account
the
most
recent
use
parameters.
For
a
complete
discussion
please
see
the
docket
item
"
Comparison
of
Currently
Supported
Phosmet
Use
Rates
to
those
Assessed
Previously"
dated
February
2,
2006.

Table
2,
below,
summarizes
the
risk
quotients
(
RQs)
and
level
of
concern
(
LOC)
exceedences
at
maximum
labeled
rates.

Table
2:
Summary
of
Phosmet
Risk
Quotients
and
LOC
Exceedences
Species
LOC
Summary
(
acute)
LOC
Summary
(
chronic)
Freshwater
fish
1/
9
uses
exceed
Pear
RQ
=
2.0
1/
9
uses
exceed
Pear
RQ
=
1.2
Freshwater
invertebrates
9/
9
uses
exceed
RQ
range:
4.2
 
70
5/
9
uses
exceed
RQ
range:
1.0
 
5.0
Estuarine/
marine
Fish
1/
9
uses
exceed
Pear
RQ
=
0.8
1/
9
exceeds
Pear
RQ
=
1.5
Estuarine/
marine
invertebrates
9/
9
uses
exceed
RQ
range:
5.3
 
88
9/
9
uses
exceed
RQ
range:
1.1
­
10
Birds
9/
9
uses
exceed
RQ
range:
0.04
 
2.4
9/
9
uses
exceed
RQ
range:
0.15
­
20
Small
mammals
(
feeding
on
short
grass)
9/
9
uses
exceed
RQ
range:
0.01
 
4.6
9/
9
uses
exceed
RQ
range
0.5
­
60
Since
azinphos­
methyl
is
an
alternative
for
phosmet
on
several
of
the
subject
crops,
EPA
has
compared
the
risk
to
non­
target
species
of
these
two
chemicals.
For
example,
while
phosmet
RQ
values
exceed
acute
risk
LOCs
across
all
of
the
uses
evaluated
for
freshwater
invertebrates,
RQ
values
only
exceed
the
acute
risk
LOC
for
fish
for
a
single
use,
pears,
at
the
maximum
application
rate.
In
contrast
for
AZM,
RQ
values
exceed
acute
risk
LOCs
across
all
uses
for
freshwater
fish
(
range:
12
 
54).
For
freshwater
invertebrates,
RQ
values
for
AZM
ranged
from
26
­
121;
this
range
is
wider
than
that
of
phosmet.

The
single
phosmet
use
that
exceeded
the
chronic
risk
LOC
for
freshwater
fish
has
an
RQ
roughly
equal
to
the
LOC.
RQ
values
for
freshwater
invertebrates
exceed
the
chronic
risk
LOC
for
five
out
of
the
nine
uses
evaluated
by
factors
as
high
as
4.9X.
However,
for
AZM
all
of
the
uses
evaluated
exceed
the
chronic
risk
LOC
for
fish
and
invertebrates
by
factors
ranging
between
5
 
24X
and
13
 
61X,
respectively.

RQ
values
however,
are
dimensionless
numbers
and
their
magnitude
cannot
be
legitimately
compared
across
chemicals
and
taxa
unless
it
can
be
demonstrated
that
the
dose­
response
curves
are
similar.
However,
analyses
conducted
on
AZM
indicate
that
for
freshwater
organisms,
the
dose
response
curves
have
relatively
steep
slopes
and
that
minor
increases
in
AZM
concentrations
will
result
in
marked
increases
in
toxicity
and
therefore,
risk.
6
Summary
of
Usage
Table
3.
Current
Phosmet
Usage
2004­
20051
Crop
Pounds
Applied
Percent
Crop
Treated
Average
Rate
Lb
ai/
Application
Apples
615,000
28
1.56
Apricots
9,300
5
2.292
Blueberries
(
highbush)
63,400
52
0.76
Grapes
38,100
20
2.193
Nectarines
76,500
44
1.84
Peaches
245,900
37
1.37
Pears
80,200
20
3.06
Plums/
prunes
42,800
20
2.914
Total
Pounds
Applied
1,171,200
1
Source:
USDA
NASS
Agricultural
Chemical
Usage,
2005
Fruit
Summary
2
Source:
USDA
NASS
Agricultural
Chemical
Usage,
2002
Fruit
Summary
3
California
rate
only.
Michigan
=
1.07
4
California
plums
and
prunes
=
100%
of
reported
usage
in
2004.

Part
II:
Crop
Specific
Considerations,
Proposed
Decisions
and
Rationale
Apples
Current
Use
Parameters
Label
rate:
3.73
lbs
ai/
A
per
application,
repeat
as
necessary
in
accordance
with
insect
infestation
and
local
and
state
spray
programs.
Max
application
rate:
21
lbs
ai/
A
per
season
Typical
rate:
1.56
lbs
ai/
A
per
application,
1­
3
applications
per
season
Current
REI:
3
days
for
high
contact
activities
such
as
thinning
Current
PHI:
7
days
for
agricultural
workers;
14
days
for
"
pick­
your­
own"
operations
Post­
Application
Worker
Risks
The
calculated
short
term
MOE
for
high
contact
post­
application
activities
at
the
maximum
application
rate
at
3
days
is
29.
The
Intermediate
term
MOE
is
7.

Alternatives
and
Qualitative
Grower
Impacts
Extending
the
REIs
for
phosmet
could
severely
limit
the
amount
of
time
a
labor
crew
has
to
complete
necessary
orchard
activities
such
as
hand
thinning,
tree
training,
limb
propping,
summer
pruning
for
fire
blight.
This
could
impact
growers
by
forcing
them
not
to
achieve
the
desired
results
from
these
activities.

Extending
REIs
beyond
the
maximum
feasible
length
of
7
days,
would
likely
force
growers
to
abandon
phosmet
use
in
favor
of
another
OP
(
AZM,
diazinon,
dimethoate)
or
7
pyrethroids
such
as
fenpropathrin,
esfenvalerate
or
lambda
cyhalothrin
which
also
have
either
worker
or
ecological
concerns.

Some
new
chemistries
are
available
such
as
neonicitinoids.
However,
two
applications
of
neonicitinoids
and
two
applications
of
insect
growth
regulators
would
be
required
to
replace
the
typical
three
applications
of
phosmet.
The
cost
of
these
applications
would
be
double
the
cost
of
the
three
applications
of
phosmet.

Pyrethroids
are
also
not
a
desirable
alternative
as
they
tend
to
be
less
compatible
with
integrated
pest
management
and
mating
disruption
programs
than
is
phosmet.
An
additional
concern
with
pyrethroids
is
that
use
of
these
pesticides
tends
to
precipitate
secondary
pest
outbreaks,
such
as
spider
mites,
necessitating
the
use
of
a
miticide
at
an
additional
cost
of
about
$
50
per
acre.

Proposed
Decision/
Mitigation/
Rationale
EPA
is
proposing
to
increase
the
REI
from
3
to
7
days
which
would
increase
the
short
term
MOEs
for
high
exposure
re­
entry
activities
from
29
to
37.
While
this
MOE
falls
short
of
the
target
of
100,
EPA
believes
risk
is
not
underestimated
because
these
estimates
include
worst
case
assumptions
that
may
overestimate
risk.
For
example,
these
calculations
assume
that
the
maximum
application
rate
is
always
used
and
that
workers
always
re­
enter
treated
fields
for
at
least
30
consecutive
days
on
the
day
the
REI
expires.
Harvesters
are
already
subject
to
a
7
day
pre
harvest
interval,
since
apples
cannot
be
picked
for
7
days
after
the
last
phosmet
application.
Also,
because
there
is
a
5­
fold
difference
between
the
NOAEL
used
in
the
risk
assessment
and
levels
at
which
shortterm
effects
are
actually
seen
(
LOAELs)
there
is
an
additional
margin
of
safety
built
into
the
calculation.

With
the
extension
of
the
REIs
as
described
above,
EPA
believes
that
the
benefits
of
the
phosmet
use
on
apples
are
high
and
with
the
additional
mitigation
measures
outlined
below,
these
benefits
outweigh
the
risks,
for
the
following
reasons:
(
1)
It
is
likely
that
production
costs
will
increase
because
the
alternatives,
other
than
AZM,
are
more
costly.
(
2)
The
alternatives
would
have
to
be
applied
more
often,
therefore,
increasing
the
environmental
loading
of
other
chemicals
with
similar
or
greater
ecological
risks.
(
3)
Some
alternatives
tend
to
create
secondary
pest
control
concerns
which
require
additional
pesticides
to
control
these
pests
which
in
turn
may
result
in
higher
environmental
loading
of
pesticide
chemicals.

EPA
recognizes
that
the
worker
risk
assessment
indicates
that
existing
MOEs
at
current
label
rates
are
insufficient
to
ensure
that
there
is
not
a
concern
that
workers
will
be
exposed
to
levels
of
phosmet
that
will
result
in
cholinesterase
depression
­
a
precursor
of
adverse
neurological
effects.
The
Agency
is
proposing
to
extend,
as
practicable,
the
REI
to
mitigate
these
concerns.
Although
the
mitigation
will
not
result
in
an
MOE
of
100,
the
Agency
believes
that
the
MOEs
may
likely
overestimate
the
risk
to
reentry
workers
and
EPA
is
not
aware
of
incident
information,
monitoring
data
or
other
sources
of
information
that
numerous
worker
poisoning
incidents
are
occurring.
Lastly,
the
8
mitigation
measures
outlined
below
are
feasible
and
will
also
reduce
the
existing
risks
to
some
extent.

In
addition
to
extending
the
REI
EPA
is
proposing
the
following
mitigation
and
followup

­
issue
a
data
call­
in
for
a
confirmatory
biomonitoring
study
of
workers
­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
­
require
label
amendments
to
eliminate
phosmet
use
in
"
pick­
your­
own"
operations
­
require
label
amendments
to
eliminate
aerial
application
EPA
considered
additional
clothing
for
re­
entry
workers.
However,
this
is
not
considered
feasible
due
to
heat
stress
and
other
concerns.

Apricots
Current
Use
Parameters
Label
rate:
3.0
lbs
ai/
A
per
application,
repeat
as
necessary
in
accordance
with
insect
infestation
and
local
and
state
spray
programs.
Max
application
rate:
9.1
lbs
ai/
A
per
season
Typical
rate:
2.29
lbs
ai/
A
per
application,
1.4
applications
per
season
Current
REI:
3
days
for
agricultural
workers,
14
days
for
"
pick­
your­
own"
operations
Current
PHI:
14
days
Post­
Application
Worker
Risks
The
calculated
MOE
for
short
term
exposures
at
the
maximum
application
rate
at
3
days
is
36.
(
Intermediate
term
MOE
is
9,
although
exposure
greater
than
30
days
are
unlikely
given
the
small
percent
crop
treated.)

Alternatives
and
Qualitative
Grower
Impacts
Use
of
phosmet
on
apricots
appears
to
have
declined
between
1999
and
2002
from
18%
to
5%
of
the
crop
treated.
An
REI
greater
than
7
would
interfere
with
crop
production
practices,
such
as
propping,
although
the
REI
for
hand
harvesting
is
effectively
14
days,
since
that
is
the
pre­
harvest
interval
(
PHI).
Longer
REIs
would
likely
result
in
growers
switching
to
one
or
a
combination
of
alternatives,
including
diazinon,
carbaryl,
endosulfan,
pyrethroids,
spinosad,
Bt,
and
mating
disruption.
Some
alternatives,
such
as
pyrethroids,
are
less
compatible
with
integrated
pest
management
and
mating
disruption
programs
than
is
phosmet.
Pyrethroids
often
precipitate
secondary
pest
outbreaks,
such
as
spider
mites,
necessitating
the
use
of
miticides,
that
can
cost
over
$
50
per
acre
(
twice
the
cost
of
phosmet.
9
Proposed
Decision/
Mitigation/
Rationale
EPA
is
proposing
to
increase
the
REI
to
14
days
for
harvesting
and
7
days
for
other
high
contact
activities,
such
as
propping
of
late
varieties.
This
would
increase
short
term
harvester
MOE
to
74.
The
MOE
for
other
high
contact
activities
would
increase
to
44.
Given
the
small
volume
of
phosmet
used
on
apricots
intermediate
term
exposure
is
unlikely.

While
these
MOEs
fall
short
of
the
target
of
100,
EPA
believes
risk
is
overestimated
because
these
estimates
include
some
worst
case
assumptions
that
would
not
always
apply
in
real
world
scenarios.
For
example,
these
calculations
assume
that
the
maximum
application
rate
is
always
used
and
that
workers
re­
enter
treated
fields
for
at
least
30
consecutive
days
on
the
day
that
the
REI
expires.
Harvesters
are
already
subject
to
a
14
day
pre­
harvest
interval,
since
apricots
cannot
be
picked
for
14
after
the
last
phosmet
application.
Also,
because
there
is
a
5
fold
difference
between
the
NOAEL
used
in
the
risk
assessment
and
levels
at
which
short­
term
effects
are
actually
seen
(
LOAELs)
there
may
be
an
additional
margin
of
safety
built
into
the
calculation.

Extending
the
REI
beyond
14
days
for
harvesters
and
7
days
for
other
activities
would
likely
result
in
growers
switching
to
another
OP,
pyrethroid
or
some
combination,
although
some
reduced
risk
alternatives
such
as
spinosad,
Bt
and
mating
disruption,
show
efficacy
for
some
of
the
target
pests.
Both
the
OPs
registered
for
this
use
and
pyrethroids
present
similar
or
greater
ecological
concerns
than
phosmet
With
the
extension
of
the
REIs
as
described
above,
EPA
believes
that
the
benefits
of
the
phosmet
use
on
apricots
are
high
and
with
the
additional
mitigation
measures
outlined
below,
these
benefits
outweigh
the
risks,
for
the
following
reasons:
(
1)
It
is
likely
that
the
alternatives
may
not
be
as
efficacious
as
phosmet
and
could
require
more
that
one
application
to
achieve
the
same
level
of
control,
therefore,
increasing
the
environmental
loading
of
other
chemicals
with
similar
risks.
(
2)
The
use
of
phosmet
on
this
crop
is
rather
low
and
the
Agency
believes
that
this
pesticide
is
a
necessary
tool
for
growers
who
face
relatively
higher
pest
pressure.

EPA
recognizes
that
the
worker
risk
assessment
indicates
that
existing
MOEs
at
current
label
rates
are
insufficient
to
ensure
that
there
is
not
a
concern
that
workers
will
be
exposed
to
levels
of
phosmet
that
will
result
in
cholinesterase
depression
­
a
precursor
of
adverse
neurological
effects.
The
Agency
is
proposing
to
extend,
as
practicable,
the
REI
to
mitigate
these
concerns.
Although
the
mitigation
will
not
result
in
an
MOE
of
100,
the
Agency
believes
that
the
MOEs
likely
overestimate
the
risk
to
reentry
workers
and
EPA
is
not
aware
of
incident
information,
monitoring
data
or
other
sources
of
information
that
numerous
worker
poisoning
incidents
are
occurring.
Lastly,
the
mitigation
measures
outlined
below
are
feasible
and
will
also
reduce
the
existing
risks
to
some
extent.

In
addition
to
extending
the
REI,
EPA
is
proposing
the
following
mitigation
and
followup
10
­
issue
a
data
call­
in
for
a
confirmatory
biomonitoring
study
of
workers
­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
­
require
label
amendments
to
eliminate
phosmet
use
in
"
pick­
your­
own"
operations
­
require
label
amendments
to
eliminate
aerial
application
EPA
considered
additional
clothing
for
re­
entry
workers.
However,
this
is
not
considered
feasible
due
to
heat
stress
and
other
concerns.

Blueberries
(
highbush
only)

Current
Use
Parameters
Label
rate:
1.0
lbs
ai/
A
per
application,
maximum
5
applications
per
season
Max
application
rate:
5.0
lbs
ai/
A
per
season
Typical
rate:
0.76
lbs
ai/
A
per
application,
1
­
3
applications
per
season
Current
REI:
24
hours
Current
PHI:
3
days
Post­
Application
Worker
Risks
The
calculated
short­
term
MOE
at
the
current
REI
of
24
hours
is
approximately
100.
(
Intermediate
term
is
<
25).
The
MOE
for
harvesters
at
the
PHI
of
3
days
is
110
(
26
for
intermediate
term).

Alternatives
and
Qualitative
Grower
Impacts
Extending
the
REI
beyond
3
days
would
interfere
with
key
crop
production
practices,
and
growers
would
likely
stop
using
phosmet
in
favor
of
one
or
more
less
efficacious
available
alternatives,
that
would
likely
result
in
both
quality
loss
and
increased
production
costs,
with
greatest
impacts
seen
in
the
eastern
and
north­
central
regions
of
the
US.
A
relatively
high
percentage
of
the
blueberry
crop
is
treated
with
phosmet
and
that
percentage
has
increased
since
1999.

Proposed
Decision/
Mitigation/
Rationale
Extending
the
REI
to
3
days
would
increase
short­
term
MOEs
to
110.
Intermediate
term
exposures
would
not
be
expected
given
the
low
volume
of
phosmet
(
63,400
lbs/
yr)
used
throughout
the
country.

With
the
extension
of
the
REIs
as
described
above,
the
MOEs
for
short­
term
exposure
will
be
higher
than
the
target
MOE
of
100.
Therefore,
the
Agency
finds
no
short
term
worker
risks
of
concern.
As
for
the
intermediate
term
exposures,
the
Agency
does
not
believe
these
concerns
are
realistic
with
the
low
usage
of
phosmet
on
blueberries.
If
the
Agency
were
to
assume
that
the
intermediate
term
exposure
was
realistic,
the
benefits
of
the
use
of
phosmet
on
blueberries
outweighs
the
risks
to
workers
for
the
following
reasons:
(
1)
Without
phosmet
as
a
tool
for
controlling
pests
on
blueberries,
the
Agency
11
believes
there
would
be
quality
losses
for
the
growers.
Quality
losses
are
viewed
as
the
transfer
of
a
proportion
of
fruit
from
the
fresh
fruit
(
premium
price)
market
to
the
processed
fruit
(
lower
price)
market,
or
as
the
transfer
of
fruit
from
the
processed
market
to
"
no
sale"
as
a
result
of
buyer
rejection
In
addition
to
extending
the
REI
EPA
is
proposing
the
following
mitigation
and
followup

­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
­
require
label
amendments
to
eliminate
of
phosmet
use
in
"
pick­
your­
own"
operations
Additional
clothing
for
re­
entry
workers
is
not
warranted
as
MOEs
would
exceed
100.

Grapes
Current
Use
Parameters
Label
rate:
0.7
­
1.5
lbs
ai/
A
per
application,
repeat
as
necessary
in
accordance
with
insect
infestation
and
local
and
state
spray
programs.
Max
application
rate:
4.55
lbs
ai/
A
per
season,
Typical
rate:
1.07
lbs
ai/
A
per
application,
1­
3
applications
per
season
Current
REI:
14
days
for
hand
harvesting
Current
PHI:
7
days
(<
1.0
lbs
ai/
A),
14
days
(>
1.0
lbs
ai/
A)

Post­
Application
Worker
Risks
The
calculated
MOE
for
short
term
exposures
at
the
maximum
application
rate
at
14
days
is
approximately
167.
(
Intermediate
term
MOE
is
41.)
The
MOE
for
harvesters
at
the
PHI
of
7
days
is
approximately
105
(
26
for
intermediate
term).

Alternatives
and
Qualitative
Grower
Impacts
Extending
REIs
beyond
14
days
would
likely
interfere
with
hand
harvesting
and
other
in
season
crop
maintenance
activities.
If
REIs
were
extended
beyond
14
days
growers
would
likely
turn
to
carbaryl,
methomyl,
or
fenpropathrin.
All
three
chemicals
have
integrated
pest
management
concerns.
Fenpropathrin
can
be
used
to
control
Japanese
beetle
and
grape
berry
moth.
However,
it
should
not
be
used
more
than
once
per
year
because
of
resistance.
Both
methomyl
and
carbaryl
are
highly
toxic
to
mite
predators,
whereas
phosmet
is
softer
on
beneficial
insects.

Proposed
Decision/
Mitigation/
Rationale
Maintaining
the
REI
of
14
days
will
result
in
a
short
term
MOE
of
167
and
an
intermediate­
term
MOE
of
41.
12
With
the
REIs
as
described
above,
the
MOEs
for
short­
term
exposure
will
be
higher
than
the
target
MOE
of
100.
Therefore,
the
Agency
finds
no
risk
of
concer
to
balance
against
the
benefits
of
the
use
of
phosmet
on
grapes.

In
addition
EPA
is
proposing
the
following
mitigation
and
follow­
up:

­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
Additional
clothing
for
re­
entry
workers
is
not
warranted
as
MOEs
would
exceed
100.

Nectarines/
Peaches
Peaches
and
nectarines
are
varieties
of
the
same
fruit
and
the
trees
themselves
are
indistinguishable.
The
same
pests
attack
the
fruit
and
growers
have
essentially
the
same
chemical
and
non­
chemical
control
means.
Therefore,
the
Agency
is
proposing
the
same
decision
for
both
crops.

Current
Use
Parameters
Label
rate:
1.5
 
3.0
lbs
ai/
A
per
application,
repeat
as
necessary
in
accordance
with
insect
infestation
and
local
and
state
spray
programs.
Max
application
rate:
9.1
lbs
ai/
A
per
season
for
nectarines
11.9
lbs
ai/
A
per
season
for
peaches
Typical
rate:
1.84
lbs
ai/
A
per
season
for
nectarines,
1­
2
applications
per
season
1.37
lbs
ai/
A
per
season
for
peaches,
1­
4
applications
per
season
Current
REI:
3
days
for
agricultural
workers,
14
days
for
"
pick­
your­
own"
operations
Current
PHI:
14
days
Post­
Application
Worker
Risks
The
calculated
short
term
MOE
for
high
exposure
activities
at
the
maximum
application
rate
at
3
days
is
36,
intermediate
term
is
9.
To
get
above
the
target
MOE
of
100
the
REI
would
have
to
be
increased
to
19
days
for
short
term
exposure
and
be
increased
to
40
days
for
intermediate
term
exposure.

Alternatives
and
Qualitative
Grower
Impacts
Extending
REIs
beyond
14
days
would
likely
interfere
with
thinning
and
other
in
season
crop
maintenance
activities.
If
REIs
were
extended
beyond
14
days
growers
would
likely
turn
to
carbaryl,
methomyl,
or
fenpropathrin.
All
three
chemicals
have
integrated
pest
management
concerns.
Fenpropathrin
can
be
used
to
control
Japanese
beetle
and
grape
berry
moth.
However,
it
should
not
be
used
more
than
once
per
year
because
of
resistance.
Both
methomyl
and
carbaryl
are
highly
toxic
to
mite
predators,
whereas
phosmet
is
softer
on
beneficial
insects.
13
Proposed
Decision/
Mitigation/
Rationale
The
Agency
is
proposing
to
extend
the
REI
to
7
days
which
would
increase
the
shortterm
MOE
to
47
and
the
intermediate
term
MOE
to
11.
The
Agency
acknowledges
that
in
2001,
EPA
concluded
that
extending
the
REI
for
hand
harvesting
to
14
days,
equivalent
to
the
pre­
harvest
interval
(
PHI),
would
not
result
in
grower
impacts.
However,
within
the
season,
the
maximum
REI
that
would
not
interfere
with
orchard
activities
is
seven
days.
In
particular,
peaches
and
nectarines
must
be
thinned,
preferably
by
hand,
to
guarantee
that
fruit
growth
is
consistent
with
fresh
market
standards.
Extension
of
phosmet
REIs
beyond
7
days
would
interfere
with
this
practice.
With
the
extension
of
the
REIs
as
described
above,
EPA
believes
that
the
benefits
of
the
phosmet
use
on
nectarines/
peaches
are
high
and
with
the
additional
mitigation
measures
outlined
below,
these
benefits
outweigh
the
risks,
for
the
following
reasons:
(
1)
An
REI
greater
than
seven
days
would
interfere
with
key
crop
production
practices.
(
2)
If
a
longer
REI
is
imposed,
growers
would
have
to
replace
phosmet
with
one
or
more
of
several
available
alternatives
which
would
likely
result
in
increased
production
costs
because
alternatives
are
more
costly.
(
3)
It
is
likely
that
the
alternatives
would
have
to
be
applied
more
often
to
achieve
similar
control,
and
could
result
in
applications
of
additional
pesticides
to
control
secondary
pests.

EPA
recognizes
that
the
worker
risk
assessment
indicates
that
existing
MOEs
at
current
label
rates
are
insufficient
to
ensure
that
there
is
not
a
concern
that
workers
will
be
exposed
to
levels
of
phosmet
that
will
result
in
cholinesterase
depression
­
a
precursor
of
adverse
neurological
effects.
The
Agency
is
proposing
to
extend,
as
practicable,
the
REI
to
mitigate
these
concerns.
Although
the
mitigation
will
not
result
in
an
MOE
of
100,
the
Agency
believes
that
the
MOEs
likely
overestimate
risks
to
reentry
workers
and
EPA
is
not
aware
of
incident
information,
monitoring
data
or
other
sources
of
information
that
numerous
worker
poisoning
incidents
are
occurring.
Lastly,
the
mitigation
measures
outlined
below
are
feasible
and
will
also
reduce
the
existing
risks
to
some
extent.

In
addition
to
extending
the
REI
EPA
is
proposing
the
following
mitigation
and
followup

­
issue
a
data
call­
in
for
a
confirmatory
biomonitoring
study
of
workers
­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
­
require
label
amendments
to
eliminate
phosmet
use
in
"
pick­
your­
own"
operations
­
require
label
amendments
to
eliminate
aerial
application
EPA
considered
additional
clothing
for
re­
entry
workers.
However,
this
is
not
considered
feasible
due
to
heat
stress
and
other
concerns.
Pears
Current
Use
Parameters
Label
rate:
1.5
­
5.0
lbs
ai/
A
per
application,
repeat
as
necessary
in
accordance
with
insect
infestation
and
local
and
state
spray
programs.
14
Max
application
rate:
11.2
lbs
ai/
A
per
season
Typical
rate:
3.06
lbs
ai/
A
per
application,
1­
2
applications
per
season
Current
REI:
3
days
for
agricultural
workers,
14
days
for
"
pick­
your­
own"
operations
Current
PHI:
7
days
Post­
Application
Worker
Risks
The
calculated
short
term
MOE
for
high
exposure
activities
at
the
typical
application
rate
of
3.06
lbs
ai/
A
at
3
days
is
29,
and
the
intermediate
term
MOE
is
7.
The
maximum
rate
for
pears
is
5.0
lbs
ai/
A,
so
the
calculated
MOEs
would
be
reduced
by
approximately
60%
if
the
maximum
application
rate
is
used.

Alternatives
and
Qualitative
Grower
Impacts
An
REI
of
greater
than
7
days
would
interfere
with
irrigation,
mowing,
scouting
and
hand
harvesting
activities.
An
REI
of
greater
than
14
days
would
interfere
with
fire
blight
removal
activities.

Alternatives
(
chemical
class)
for
pears
include
chlorpyrifos,
diazinon
and
naled
(
organophosphate);
acetamiprid,
imidacloprid,
thiacloprid,
thiamethoxam
(
neonicotinoids)
indoxacarb
(
oxadiazine)
carbaryl
(
carbamate);
esfenvalerate,
fenpropathrin,
lambda­
cyhalothrin,
and
permethrin
(
synthetic
pyrethroids);
diflubenzuron,
methoxyfenozide,
novaluron,
pyriproxyfen,
and
tebufenozide
(
insect
growth
regulators);
spinosad
(
actinomycete
derivative);
Bacillus
thuringiensis
(
biopesticide);
mating
disruption
(
pheromones);
Kaolin
(
clay)

The
Agency
believes
that
acetamiprid
and
methoxyfenozide
are
among
the
most
effective
and
promising
alternatives
to
phosmet.

Proposed
Decision/
Mitigation/
Rationale
The
Agency
is
proposing
to
extend
the
REI
to
7
days
which
would
increase
the
shortterm
MOE
to
47
and
the
intermediate
MOE
to
11.
The
Agency
acknowledges
that
in
2001,
EPA
concluded
that
extending
the
REI
to
7
days
would
not
interfere
with
orchard
activities
for
irrigation,
mowing,
scouting
and
hand­
harvesting.
Extension
of
phosmet
REIs
beyond
7
days
would
interfere
with
these
practices.

With
the
extension
of
the
REIs
as
described
above,
EPA
believes
that
the
benefits
of
the
phosmet
use
on
pears
is
high
and
with
the
additional
mitigation
measures
outlined
below,
these
benefits
outweigh
the
risks,
for
the
following
reasons:
(
1)
A
REI
greater
than
seven
days
would
interfere
with
key
crop
production
practices.
(
2)
If
a
longer
REI
is
imposed,
growers
would
have
to
replace
phosmet
with
one
or
more
of
several
available
alternatives
which
would
likely
result
in
increased
production
costs
because
alternatives
are
more
costly.
(
3)
It
is
likely
that
the
alternatives
would
have
to
be
applied
more
often
to
achieve
similar
control,
and
could
result
in
applications
of
additional
pesticides
to
control
secondary
pests.
15
EPA
recognizes
that
the
worker
risk
assessment
indicates
that
existing
MOEs
at
current
label
rates
are
insufficient
to
ensure
that
there
is
not
a
concern
that
workers
will
be
exposed
to
levels
of
phosmet
that
will
result
in
cholinesterase
depression
­
a
precursor
of
adverse
neurological
effects.
The
Agency
is
proposing
to
extend,
as
practicable,
the
REI
to
mitigate
these
concerns.
Although
the
mitigation
will
not
result
in
an
MOE
of
100,
the
Agency
believes
that
the
MOEs
likely
overestimate
risks
to
reentry
workers
and
EPA
is
not
aware
of
incident
information,
monitoring
data
or
other
sources
of
information
that
numerous
worker
poisoning
incidents
are
occurring.
Lastly,
the
mitigation
measures
outlined
below
are
feasible
and
will
also
reduce
the
existing
risks
to
some
extent.

In
addition
to
extending
the
REI
EPA
is
proposing
the
following
mitigation
and
followup

­
issue
a
data
call­
in
for
a
confirmatory
biomonitoring
study
of
workers
­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
­
require
label
amendments
to
eliminate
phosmet
use
in
"
pick­
your­
own"
operations
­
require
label
amendments
to
eliminate
aerial
application
EPA
considered
additional
clothing
for
re­
entry
workers.
However,
this
is
not
considered
feasible
due
to
heat
stress
and
other
concerns.

Plums/
Prunes
Plums
and
plums
grown
for
prunes
are
typically
distinct
varieties
with
different
production
practices
although
the
trees
themselves
are
quite
similar
and
suffer
from
similar
pests,
therefore,
the
Agency's
assessment
and
decisions
are
the
same
for
these
crops.

Current
Use
Parameters
Label
rate:
1.5
 
3.0
lbs
ai/
A
per
application,
repeat
as
necessary
in
accordance
with
insect
infestation
and
local
and
state
spray
programs.
Max
application
rate:
9.1
lbs
ai/
A
per
season,
Typical
rate:
2.91
lbs
ai/
A
per
application,
1­
2
applications
per
season
Current
REI:
3
days
for
agricultural
workers,
14
days
for
"
pick­
your­
own"
operations
Current
PHI:
7
days
Post­
Application
Worker
Risks
The
calculated
short
term
MOE
for
high
exposure
activities
at
the
maximum
application
rate
at
3
days
is
36,
intermediate
term
is
9.

Alternatives
and
Qualitative
Grower
Impacts
California,
the
major
producer
of
plums
and
prunes,
has
established
a
five­
day
REI
for
phosmet
in
stone
fruit.
A
REI
greater
than
five
days
would
likely
interfere
with
key
mid
16
season
crop
production
practices,
such
as
propping
up
fruit­
laden
tree
limbs
to
avoid
breakage.
A
REI
of
seven
days,
equivalent
to
the
pre­
harvest
interval
(
PHI)
would
accommodate
hand
harvesting
and
permit
an
application
of
phosmet
to
protect
fruit
from
insect
damage
immediately
prior
to
harvest.

The
Agency
has
identified
several
alternatives
for
plums
and
prunes
grown
in
the
West:
Bacillus
thuringiensis
(
Bt),
carbaryl,
permethrin,
esfenvalerate,
methidathion,
dormant
oil
(
with
or
without
chlorpyrifos,
diazinon
or
esfenvalerate),
methomyl,
and
mating
disruption
(
for
the
oriental
fruit
moth
only).
In
addition,
several
materials
have
been
registered
including
methoxyfenozide
(
labeled
for
`
control'
of
codling
moth,
oriental
fruit
moth,
and
peach
tree
borer),
pyriproxyfen
(
only
for
`
suppression'
of
oriental
fruit
moth
and
peach
tree
borer),
spinosad
(
controls
oriental
fruit
moth,
peach
tree
borer,
and
citrus
cutworm).

In
the
eastern
U.
S.
region,
esfenvalerate
is
the
most
likely
alternatives
for
plum
curculio.
Currently,
spinosad
is
available
for
the
control
of
the
apple
maggot
and
two
neonicotinoids,
imidacloprid
and
thiamethoxam,
are
available
to
control
the
plum
curculio.
However,
imidacloprid
is
labeled
only
for
`
suppression'
and
may
have
limited
efficacy.

Proposed
Decision/
Mitigation/
Rationale
Extending
the
REI
to
7
days
would
increase
the
short­
term
MOE
to
47.
Intermediate
term
exposures
would
not
be
expected
given
the
low
volume
of
phosmet
(
43,000
lbs/
yr)
used
throughout
the
country.

With
the
extension
of
the
REIs
as
described
above,
EPA
believes
that
the
benefits
of
the
phosmet
use
on
plums/
prunes
are
high
and
with
the
additional
mitigation
measures
outlined
below,
these
benefits
outweigh
the
risks,
for
the
following
reasons:
(
1)
A
REI
greater
than
seven
days
would
interfere
with
key
crop
production
practices.
(
2)
If
a
longer
REI
is
imposed,
growers
would
have
to
replace
phosmet
with
one
or
more
of
several
available
alternatives
which
would
likely
result
in
increased
production
costs
because
alternatives
are
more
costly.
(
3)
It
is
likely
that
the
alternatives
would
have
to
be
applied
more
often
to
achieve
similar
control,
and
could
result
in
applications
of
additional
pesticides
to
control
secondary
pests.

EPA
recognizes
that
the
worker
risk
assessment
indicates
that
existing
MOEs
at
current
label
rates
are
insufficient
to
ensure
that
there
is
not
a
concern
that
workers
will
be
exposed
to
levels
of
phosmet
that
will
result
in
cholinesterase
depression
­
a
precursor
of
adverse
neurological
effects.
The
Agency
is
proposing
to
extend,
as
practicable,
the
REI
to
mitigate
these
concerns.
Although
the
mitigation
will
not
result
in
an
MOE
of
100,
the
Agency
believes
that
the
MOEs
likely
overestimate
the
risks
to
reentry
workers
and
EPA
is
not
aware
of
incident
information,
monitoring
data
or
other
sources
of
information
that
numerous
worker
poisoning
incidents
are
occurring.
Lastly,
the
mitigation
measures
outlined
below
are
feasible
and
will
also
reduce
the
existing
risks
to
some
extent.
17
In
addition
to
extending
the
REI
EPA
is
proposing
the
following
mitigation
and
followup

­
issue
a
data
call­
in
for
a
confirmatory
biomonitoring
study
of
workers
­
require
label
amendments
for
buffer
zones
around
houses
and
occupied
dwellings
­
require
label
amendments
to
eliminate
phosmet
use
in
"
pick­
your­
own"
operations
­
require
label
amendments
to
eliminate
aerial
application
EPA
considered
additional
clothing
for
re­
entry
workers.
However,
this
is
not
considered
feasible
due
to
heat
stress
and
other
concerns.

Debra
Edwards,
Ph.
D.,
Director
Special
Review
and
Reregistration
Division
