March 31, 2006

Ms. Deborah Edwards

Director

Special Review and Reregistration

US Environmental Protection Agency

Office of Pesticide Programs (7508C)

Ariel Rios Building

1200 Pennsylvania Ave., N.W.

Washington, D.C. 20460

Re: Azinphos Methyl Ecological Risk Assessment

Dear Ms. Edwards:

The U.S. Apple Association (USApple) is the national trade association
representing all segments of the apple industry.  Members include 36
state apple associations representing 7,500 apple growers throughout the
country, as well as over 300 individual firms involved in the apple
business.  The apple industry is interested in assisting the agency in
its efforts to protect the environment while finding a way to provide
apple growers with effective and affordable tools to control important
insect pests.  The purpose of this letter is to discuss potential
additional mitigations that the apple industry would be willing to
consider.

By way of background, the apple industry has already agreed to
significant restrictions on the use of azinphos methyl, which have
contributed to substantive environmental risk reduction.  Effective Dec.
31, 1999 the apple industry agreed to reduce maximum yearly azinphos
methyl use from 6 lbs to 4.5 lbs of active ingredient, increase the
pre-harvest interval to 21days if the last application is greater than 1
lb. of active ingredient and eliminate chemigation and fixed wing aerial
applications.

In 2002, the apple industry agreed to further restrictions on the
azinphos methyl use including establishing a 30 day preharvest interval
for “pick your own” operations, limiting total annual use to 4 lbs.
of active ingredient, increasing the reentry interval from 7 days to 14
days for all activities, requiring closed mixing systems or water
soluble bags and closed transfer systems for mixing and loading
activities, requiring maximum personal protective equipment for
applicators, prohibiting aerial applications, prohibiting dormant use
and adding a 25-foot buffer between orchards and permanent surface
water.

The apple industry also agreed to additional label language to reduce
spray drift by instructing growers to direct applications into the
canopy and turn off outward pointing nozzles at row ends and when
spraying the outer two rows.

In addition to these measures, the apple industry would agree to the
following mitigation to allow apple growers continued access to this
important tool:

Increase the ground cover buffer between orchards and permanent bodies
of water from 25 feet to 60 feet

Reduce the total seasonal use of azinphos methyl from 4 lbs. to 3 lbs of
active ingredient, which is equivalent to reducing the full product use
from 8 lbs. to 6 lbs.

USApple also plans to seek program support funding in the 2007 Farm Bill
to help apple growers transition to spray equipment that has a greater
capacity to reduce spray drift.  This assistance would augment the
transition growers are already making to “smart sprayers” that have
the capacity to turn off spray nozzles when gaps are detected in tree
rows or canopy.  Additionally, USApple plans to explore ways that apple
growers could access U.S. Department of Agriculture programs that
enhance water quality and prevent runoff.  

We look forward to discussing this issue with you further, and would
welcome the opportunity to answer questions you might have about this
proposal.

Please contact me by telephone at (703) 442-8850 or via e-mail at  
HYPERLINK "mailto:jcranney@usapple.org"  jcranney@usapple.org .

Sincerely yours,

James R. Cranney, Jr.

Vice President

cc: USApple Board of Trustees

703 442-8850

800 781-4443

fax 703 790-0845

Web site www.usapple.org

8233 Old Courthouse Road, Suite 200  (  Vienna, VA 22182-3816 USA

