Memorandum
to
the
Docket
From:
Diane
Isbell,
Special
Review
and
Reregistration
Division
Date:
November
29,
2005
Subject:
Questions
to
Consider
While
Reviewing
the
Assessments
in
the
Azinphos­
methyl
Docket
OPP­
2005­
0061
On
October
19,
2005,
EPA
will
announce
availability
the
Environmental
Fate
and
Ecological
Effects
Risk
Assessment,
dated
September
29,
2005,
the
2005
Grower
Impacts
Assessments
for
Azinphos­
methyl,
and
the
BEAD
Assessment
of
Citations
Submitted
by
Plaintiffs
(
Case
2:
04­
Cv­
00099­
RSM)
in
Regard
to
EPA's
2001
Benefits
Assessments
for
Azinphosmethyl
These
documents
will
be
available
for
a
90­
day
public
comment
period.
These
assessments
pertain
to
the
following
crops:
almonds;
apples
and
crab
apples;
blueberries,
lowbush
and
highbush;
Brussels
sprouts;
sweet
and
tart
cherries;
nursery
stock;
parsley;
pears;
pistachios;
and
walnuts.
While
all
public
comments
are
welcome,
certain
types
of
information
are
most
useful
to
the
Agency
for
refining
these
assessments
and
developing
risk
management
options.
The
information
requested
below
is
intended
to
guide
commenters
toward
the
most
pertinent
types
of
information
Generally,
comments
supported
by
published
literature
or
data
are
of
greater
utility
than
expressions
of
opinion.
If
you
believe,
based
on
your
own
expertise
or
experience,
that
the
assumptions
used
in
the
assessments
are
well
founded,
that
is
also
useful
information
to
provide
to
EPA.

EPA
will
make
the
human
health
assessment
available
for
public
comment
in
2006,
prior
to
or
in
conjunction
with
the
Agency's
proposed
decisions
on
the
continued
use
of
azinphosmethyl
for
above
listed
uses.
For
the
current
comment
period,
please
confine
your
comments
to
the
ecological
and
grower
impact
assessments
made
available
on
October
19,
2005.
The
following
topics
are
suggested
for
comment:

1.
The
Agency
is
seeking
data
for
pest
management
scenarios
applicable
to
commercial
scale
commodity
production
(
that
include
domestic
and
export
markets)
other
than
those
discussed
in
the
azinphos­
methyl
assessments.
Please
describe
in
detail:

a)
Whether
these
alternatives
to
azinphos­
methyl
would
be
likely
to
be
used
by
a
significant
number
of
growers
and
if
so,
why.
b)
The
cost
per
acre
of
these
alternatives.
c)
The
efficacy
of
these
alternatives,
focusing
on
yield
and
quality
effects.
d)
The
implications
of
the
proposed
scenarios
on
the
marketability
of
the
commodity.
2
2.
The
Agency
invites
the
submission
of
data
or
other
relevant
information
that
addresses
economically
important
pests
currently
controlled
most
effectively
or
only
by
AZM,
and
which
were
not
discussed
in
the
assessments,
please
submit
data
that
address
the
following:

a)
The
proportion
of
crop
acres
by
region
affected
by
the
pest.
b)
Details
on
the
life
cycle
of
the
pest
and
nature
of
damage
inflicted.
c)
Efficacy
studies
comparing
AZM
to
potential
alternatives
for
control
of
the
pests,
focusing
on
yield
and
quality
impacts.
If
such
studies
have
been
done,
also
provide
copies
of
the
studies,
citations,
or
contact
information
so
that
we
may
obtain
the
studies.

3.
If
available,
the
Agency
is
seeking
new
crop
budgets
for
any
crops
discussed
in
these
assessments,
please
provide
copies
or
citations
for
these
documents.

4.
The
Agency
is
seeking
any
information
related
to
the
use
patterns
(
location
where
the
crop
is
grown
(
county
and
state),
application
rate,
lowest
effective
application
rate,
number
of
applications,
the
timing
of
each
application,
or
increased
buffer
zones)
that
differs
from
what
was
relied
upon
in
the
assessments.

5.
The
Agency
is
interested
in
information
concerning
any
typical
practices,
not
reflected
on
current
labels,
that
serve
to
reduce
exposure
to
non­
target
species
and
water
resources,
for
example,
special
equipment
to
reduce
spray
drift.

6.
The
Agency
is
seeking
information
related
to
any
additional
measures
that
could
be
added
to
current
labels
to
reduce
exposure
to
non­
target
species
and
water
resources,
for
example,
larger
buffers
for
some
or
all
crops.
