July
30,
2004
Dr.
Debra
Edwards
Special
Review
and
Reregistration
Division
(
7508C)
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
1801
South
Bell
Street
Arlington,
Virginia
22202
Dear
Dr.
Edwards:

Re:
Azinphos
Methyl
(
Guthion)
Phase
Out
for
Potatoes
During
the
reregistration
process
for
Azinphos­
Methyl
(
Guthion),
the
National
Potato
Council
(
NPC)
filed
written
comments
on
January
28,
2002,
on
the
need
to
continue
its
use
on
potatoes.
The
NPC
also
consulted
with
potato
growers
who
were
using
the
product
or
who
would
potentially
need
the
product.
The
consensus,
at
that
time,
was
that
Guthion
was
a
valuable
product
for
the
control
of
the
Colorado
potato
beetle,
banded
cucumber
beetle,
leaf
hopper,
European
corn
borer,
flea
beetle,
leafhoppers,
spittle
bugs,
tarnished
plant
bug,
and
tuber
worms.

At
that
time,
NPC
also
tried
to
look
down
the
road
at
other
newer
products,
still
in
development
or
under
review
for
registration,
to
determine
if
effective
alternatives
to
Guthion
would
be
available
in
the
future.
At
that
point,
the
prospects
for
effective
alternative
products
seemed
bright.
Based
on
that
analysis,
NPC
worked
with
EPA
to
develop
a
scheduled
phase
out
for
Guthion
instead
of
immediate
cancellation.
The
NPC
appreciates
the
work
by
EPA
staff
to
accommodate
this
result.
NPC
has
continued
to
evaluate
the
use
of
Guthion
during
the
phase
out
in
order
to
determine
the
impact
that
adherence
to
the
phase
out
schedule
would
have
on
potato
production.
Alternative
products
have
not
surfaced
so
as
to
be
available
at
the
end
of
the
Guthion
phase
out
for
potatoes.

In
addition,
we
are
informed
that
resistance
to
many
of
the
other
available
insecticides
is
developing
more
quickly
than
expected.
This
increases
the
need
for
broader
spectrum
insecticides,
in
particular,
and
the
need
for
more
products
to
use
in
rotation
to
prevent
resistance
development.

The
NPC
has
been
informed
that
there
continues
to
be
a
significant
need
for
Guthion
in
the
Pacific
northwest,
and
possibly,
also
in
Colorado
and
the
Mid
Atlantic
region
as
Guthion
continues
to
be
an
effective
treatment
for
many
insect
pests.
We
are
informed
that
many
of
the
currently
available
alternatives
are
not
as
effective,
and/
or
have
associated
resistance
problems.
Dr.
Debra
Edwards
July
30,
2004
Page
2
On
behalf
of
the
potato
growers
we
represent,
the
NPC
respectfully
requests
that
EPA
begin
a
process
with
the
potato
industry
and
the
registrant
to
reevaluate
the
decision
to
phase
out
the
use
of
Guthion
on
potatoes.
We
look
forward
to
working
productively
with
you
and
your
staff
to
evaluate
and
update
current
use
and
benefit
data,
resistance
issues,
and
to
identify
possible
strategies
that
could
extend
the
availability
of
Guthion
beyond
2005
for
potatoes.

Sincerely,

John
Keeling
Executive
Vice
President/
CEO
WDC99
954808­
1.027357.0010
