April
26,
2005
Via
Email
Office
of
Pesticide
Programs
(
OPP),
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington,
DC,
20460­
0001
RE:
Comments
on
Closed
Mixing/
Loading
Systems
for
Propanil
The
USA
Rice
Federation
(
USA
Rice),
located
at
4301
N.
Fairfax
Drive,
Suite
425,
Arlington,
VA
22203,
is
the
national
advocate
for
all
segments
of
the
rice
industry.
USA
Rice
members
are
active
in
all
major
rice­
producing
states:
Arkansas,
California,
Florida,
Louisiana,
Mississippi,
Missouri,
and
Texas.
The
USA
Rice
Producers'
Group,
USA
Rice
Council
and
the
USA
Rice
Millers'
Association
are
charter
members
of
the
USA
Rice
Federation.

We
are
writing
you
today
to
express
USA
Rice's
support
for
the
continued
use
of
propanil.
Our
following
comments
are
intended
to
help
continue
the
use
of
propanil
and
we
appreciate
the
time
that
EPA
has
spent
with
our
industry
in
meetings
and
teleconferences.

In
past
conversations
with
EPA,
the
agency
has
suggested
a
requirement
for
closed
mixing/
loading
systems
for
both
liquid
and
dry
formulations
of
propanil.
USA
Rice
has
serious
concerns
about
how,
when
and
if
such
a
system
could
be
emplaced
and
the
resulting
costs
to
the
producer.
These
concerns
are
as
follows:

Loading
Speed
Any
system
for
propanil
must
be
able
to
mix
and
load
large
volumes
of
products
in
a
short
amount
of
time.
While
the
weather
is
appropriate,
applicators
must
apply
as
much
as
possible
during
their
windows
of
opportunity,
therefore
the
system
must
be
able
to
keep
up
with
them.

Mixing
Propanil
is
not
normally
applied
alone
but
is
mixed
with
other
products
such
as
Facet,
Clincher,
Grandstand,
and
others.
This
is
part
of
our
IPM
and
conservation
practices
 
to
scout
pests
in
the
fields
and
tailor
the
loads
to
those
pests
for
the
most
efficient
applications.

We
believe
that
one
unknown
is
what
will
happen
when
propanil
requires
a
closed
system,
necessitating
a
redesigned
and
valved
container,
and
the
other
mixed
Propanil
Closed
System
Comments
USA
Rice
Page
2
of
3
products
do
not
require
a
closed
system
with
appropriately
valved
containers.
We
can
foresee
the
closed
system
valves
having
to
be
taken
off
and
the
system
refitted
for
an
open
system
for
non­
propanil
products
thus
violating
the
"
closed
system"
for
propanil
and
increasing
the
potential
for
release.
Any
such
requirements
would
lower
the
speed
of
applications.

Also,
sometimes
the
"
recipe"
is
changed
from
field
to
field
on
the
same
farm,
meaning
there
could
be
several
switches
of
valves
or
between
systems
just
to
complete
a
job
on
one
farm.
In
a
situation
such
as
Clearfield
rice,
next
to
another
rice,
the
systems
must
be
triple
rinsed
as
well
as
switched
between
loads.

In
many
instances
the
mixing
of
products
requires
the
mixing
of
liquid
formulations
with
dry
formulations.
If
a
liquid
closed
system
is
used
for
propanil
we
do
not
see
how
to
maintain
closure
when
we
have
to
trickle
in
a
different
dry
product
or
drop
in
water­
soluble
bags.

Any
system
for
drawing
out
liquid
propanil
from
a
container
must
allow
for
air
entering
the
container,
which
is
supplied
by
opening
a
vent
bung.
We
assume
this
vent
negates
the
closed
system
scenario.

Metering
With
the
current
induction
system,
metering
is
completed
by
placing
the
marked
induction
hose
in
the
liquid
propanil
at
the
desired
gallon­
mark
on
the
hose.
That
metering
system
would
end
with
a
closed
system
and
have
to
be
replaced
at
the
applicator's
and
producer's
cost
with
a
new
system.
The
new
metering
system
would
also
have
to
work
for
metering
the
other
products
that
are
mixed
into
propanil.

Logistics
In
some
states
aerial
applicators
use
satellite
airstrips
located
on
individual
farms.
For
example,
in
Texas
applicators
can
fly
40
to
50
miles
to
apply
propanil.
They
also
have
some
chemical
plants
that
they
must
fly
around
instead
of
over.
The
use
of
satellite
strips
is
increasing
along
with
the
increasing
cost
of
fuel.
Not
only
would
they
have
to
use
closed
systems
for
their
main
strip,
but
they
would
have
to
purchase
new,
or
upgrade
old
systems
at
each
satellite
strip,
adding
to
the
cost
of
compliance.

Rinsing
The
induction
systems
that
are
currently
used
to
draw
the
propanil
from
the
33­
gallon
containers
are
also
used
to
triple
rinse
the
containers.
In
a
closed
system,
there
must
be
an
open
vent
allowing
air
to
escape
so
that
the
water
can
be
added
for
the
rinse
system.
We
believe
this
will
violate
the
closed
system
scenario.
Also,
a
closed
system
utilizing
a
container­
valve
system
for
induction,
will
also
need
modification
to
allow
rinsate
flowing
back
into
the
container
and
then
out
again.
Propanil
Closed
System
Comments
USA
Rice
Page
3
of
3
Dry
Formulations
There
is
no
closed
system
for
dry
formulations.

Water­
soluble
bags
are
not
considered
viable
by
our
producers.
A
large
bag
cannot
be
dropped
into
a
mixing
tank
to
dissolve
the
bag
because
the
product
will
not
mix
but
will
harden
as
a
lump
in
the
bottom
of
the
tank.

Using
small
bags,
such
as
one
pound,
will
add
too
much
time
to
the
mixing/
loading
process
as
the
applicator/
producer
tries
to
add
one
bag
at
a
time
while
letting
each
dissolve
and
will
increase
the
time
of
contact
and
the
opportunity
for
a
spill.

For
any
size
bags,
the
bags
do
not
completely
dissolve.
Additional
smaller
bags
would
only
exacerbate
the
problem.
The
undissolved
portions
flow
into
the
spray
system
and
clog
various
portions
of
it
but
especially
the
nozzles.
Cleaning
the
nozzles
only
enhances
contact
with
the
product
and
increases
the
likelihood
of
contamination.

USA
Rice
believes
that
requiring
water­
soluble
bags
for
dry
formulations
of
propanil
will
cause
the
loss
of
those
formulations.

If
you
have
any
questions
on
these
comments,
please
don't
hesitate
to
give
me
a
call
at
703­
236­
1445.

Sincerely,

Steve
Hensley
Director,
Regulatory
Affairs
