August 8, 2006

Public Information and Records Integrity Branch

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460-0001

Re:	EPA-HQ-OPP-2005-0061 Azinphos Methyl Proposed Reevaluation Decision

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.   USApple appreciates this opportunity to comment on the U.S.
Environmental Protection Agency’s (EPA) azinphos methyl proposed
reevaluation decision.

USApple is strongly opposed to EPA’s proposed reevaluation decision to
phase out the azinphos methyl use on apples in 2010.  The agency
acknowledges in its decision documents that there are significant
benefits from azinphos methyl use, but it predicts these benefits will
erode by 2010 and justify removal of the apple industry’s most
important insecticide.  USApple suggests the agency’s preliminary
decision to phase out the use in 2010 is premature, because it attempts
to predict the risks and benefits of azinphos methyl in 2010, but limits
itself to today’s set of facts.  

USApple believes the agency could make a more accurate and informed
decision regarding the disposition of azinphos methyl in 2010, if it
removed the phase out and made a commitment to weigh the risks and
benefits based on a risk benefit evaluation in 2010.  Such an approach
would provide stakeholders the opportunity to generate more information
about the risks and benefits of azinphos methyl, and the agency could
make an informed decision at that time.  

USApple strongly recommends this approach, because the decision could
have such a dramatic impact on apple growers.  We continue to believe
azinphos methyl has immense benefits for growers, the agency’s
ecological risk assessment overestimates the potential risk and new data
would remove the agency’s uncertainty regarding farm worker risk.  We
encourage the agency to make the best possible decision by removing the
phase out, working with stakeholders to develop new information and
agreeing to conduct a reassessment in 2010.

Azinphos Methyl’s Benefits are Immense

More than 40 insects are known to feed on or damage apples and apple
trees.  These insects may be plant bugs, leafhoppers, aphids, scale,
mites, grubs, caterpillars, maggots, beetles, moths or flies.  Some suck
leaves, others chew bark, roots and shoots while others pierce fruits or
lay eggs in fruit that hatch and burrow into apple fruits.  Left
uncontrolled, these insects destroy individual apples, spread diseases,
debilitate, and even kill, apple trees.  Of these insects the most
destructive are lepidoptera insects that lay eggs on leaves near fruit,
or on fruit, that hatch as small worms that burrow into apples where
they feed and mature.

Apple growers must be vigilant in controlling these insects, because
even a small percentage of damaged fruits will reduce grower
profitability or result in the closing of critically important export
markets.  Azinphos methyl is preferred by apple growers for control of
lepidoptera insects, because it is economical and highly effective. 
Azinphos methyl also controls a broad spectrum of other harmful pests,
but it does not harm beneficial insects.  The combined benefits of
superior efficacy, low cost and broad spectrum effectiveness make
azinphos methyl one the most widely used pesticides in the apple
industry.

Azinphos methyl is an essential tool that provides growers dependable
insect control.  While apple growers do their best to keep harmful
insects in check variations in weather or other unpredictable events can
cause pest outbreaks.  When this happens growers must be able to respond
with an insecticide that quickly eliminates the threat.  This is
especially important for pests that attack the fruit.  Azinphos methyl
is an excellent insecticide for this purpose, because it is highly
effective on all life stages and it can eliminate the threat of
infestation quickly before insects can cause much fruit damage. 
Alternative insecticides do not possess all of these advantages.

Other pesticide alternatives, such as neonicitinoids are not as useful,
because they are not equally effective on all insect life stages. 
Additionally, azinphos methyl is useful in keeping pest populations low
which provides a better environment for the use of other insecticides
that are not as effective when pest populations are high.  

 

EPA suggests in its azinphos methyl apple impact assessment that apple
growers have effective alternatives to azinphos methyl.  However none of
these alternatives are direct replacements that provide the same level
of efficacy on as many pests.  If apple growers do not have access to
azinphos methyl they will forced to use other pesticides that are more
difficult and costly to use.  The alternatives require more precise
timing, better spray coverage and more knowledge about pest populations
and life stages.  Determining this information for as many as twenty
harmful insects and ten diseases simultaneously is a daunting task.

For this reason apple pest management is one of the most complex
biological systems to manage in agriculture.  Azinphos methyl has helped
growers control the most harmful insects and maintain some manageability
in the system.  Removing azinphos methyl will make apple pest management
more unpredictable and increase risk for growers.  Many growers will
find it difficult to manage the complex alternative scenario without
azinphos methyl.  EPA does not factor this significant factor into its
impact assessment.  

Without azinphos methyl, many growers will be required to hire
additional consultants or staff to develop additional information and
assist with monitoring and decision making.  It will be expensive and
time consuming.  In some apple producing regions, this expertise does
not currently exist, so growers will be left to manage on their own. 
However, the consequences of making a mistake are extreme.  Growers
could lose entire orchards to insect infestations.  USApple urges EPA to
recognize that the elimination of azinphos methyl will create an
enormous management burden for growers in addition to the higher cost of
using alternative insecticides.

Processor Rejections

Apple growers are expected to deliver perfect fruit to its customers, so
growers must do whatever is necessary to ensure their fruit is delivered
without insect damage.  While it is generally accepted that fresh market
fruit must meet this standard it is mistakenly assumed that processors
accept apples with worm damage.

Processors do not accept worm damage because they are required by the
Food and Drug Administration (FDA) to meet strict standards for
wholesomeness when processing apple products.  Processors must minimize
the amount of insect damage in their products to meet consumer demand
for pure and wholesome products and to meet FDA standards.  To comply
with these strict standards processors reject entire truck loads of
apples if even one larva is found in an inspection. Azinphos methyl is
an extremely beneficial insecticide for growers who must have absolute
certainty that their apple are free of insect larvae.

Export Market Demands

The apple industry exports nearly a quarter of its fresh market
production to markets around the world.  In some markets, strict
phytosanitary protocols govern the standards for the presence of certain
quarantine pests.  Taiwan, the apple industry’s third largest apple
market allows only two codling moth larvae detections each year.  All
apples exported from California and Washington must meet this standard
to prohibit the introduction of codling moth in Taiwan.  In 2004, the
U.S. apple industry exported 2.3 million cartons of apples to Taiwan.

Last year, three codling moth larvae were detected by early December
resulting in the loss of the Taiwan market for the balance of the 2004
crop season.  The loss of the Taiwan market caused Fuji apple prices to
drop from an over supply of Fuji apples in the U.S. domestic market. 
Taiwan has detected two codling moth larvae this season.  An additional
detection will lead to the loss of the Taiwan market again this season.

Azinphos methyl is a dependable and economical tool to control codling
moth.  The loss of this important tool will lead to disruptions in the
current system, make it more difficult to control codling moth and
potentially jeopardize the industry’s access to the Taiwan apple
market.

Tolerances Are Not Established in Major Apple Export Markets 

Newly registered insecticides that EPA suggests should be used as
alternatives to azinphos methyl do not have maximum residue levels (MRL)
established in the apple industry’s major export markets.  The apple
industry exports approximately one-quarter of its fresh production. 
These exports are essential to the economic health of the apple
industry.  Some export markets require CODEX MRLs which take time to
establish.  Without CODEX MRLs some markets would be off limits to U.S.
exporters if the chemical were used by apple growers.  Table 1 shows the
apple industry’s top 10 export markets and the status of MRLs in those
markets.

Table 1. Top U.S. Apple Export Markets and MRLs for Selected

Azinphos-methyl Alternatives by Country

Country	Cartons 

(000)	Dollars

($)	Acetamiprid

MRL Value (ppm)	Novaluron

MRL Value (ppm)	Thiacloprid

MRL Value (ppm)

Canada	5,960	91,435	1.0a	none	None

Mexicod	6,157	73,017	none	none	0.6

Taiwan	2,261	34,113	1.0a	none	None

United Kingdom	1,808	37,616	none	none	0.5b

Hong Kong	1,778c	23,259	none	none	None

Indonesiad	1,737	22,531	none	none	None

United Arab Emiratesc	1,434	16,441	none	none	None

Malaysiad	1,299	18,918	none	none	None

Indiac	1,199	16,011	none	none	None

Chinad	689	9,114	none	none	None

proposed value- obtained from country’s website

temporary value-obtained from country’s website

accepts CODEX values. Note: No CODEX values are listed for these
products.

not published in English or not posted on their website

	Source: Northwest Horticultural Council

USApple compliments EPA for recognizing in its preliminary reevaluation
decision the importance of this issue to apple growers.  In its
preliminary decision EPA acknowledges that it would be difficult for
apple growers to use azinphos methyl alternatives while maintaining
export markets without having MRLs in place.  The apple industry
appreciates the agency’s willingness to reassess this issue in 2010,
and make a decision regarding the need to extend the use of azinphos
methyl.   However, EPA should not restrict its reevaluation in 2010 to
only impacts arising from issues associated with MRLs.  Alternatively,
USApple urges EPA to consider all relevant issues that may impact the
risks and benefits of azinphos methyl in 2010.

Import Threats and International Competitiveness

The People’s Republic of China has petitioned the U.S. Department of
Agriculture (USDA) for access to the U.S. apple market.  USDA’s Animal
and Plant Health Inspection Service (APHIS) is in the early stages of a
review process that could ultimately permit imports of fresh apples from
China.  The general absence of regulations or regulatory requirements
along with China’s low labor costs makes China a formidable
competitor.  In 1995, China’s exports of apple juice concentrate to
the United States were infinitesimal.  In 2004, China was the dominate
supplier of apple juice concentrate in the United States with a 57
percent market share.

Other apple producing countries continue to put pressure on U.S.
producers domestically and in export markets around the world.  The loss
of azinphos methyl in this environment of intense competition will make
U.S. apple producers less competitive and vulnerable to erosion of U.S.
market share here and abroad.  Apple growers are further disturbed by
the prospect that its international competitors would be free to use
azinphos methyl on exports destined for the U.S. market, but U.S.
growers could be denied the use. 

Economic Vulnerability

Available statistics do not provide an accurate picture of profitability
in the apple industry.  However, knowledgeable experts in the apple
industry report that growers are not thriving economically.  Lighter
apple crops in 2002 and 2003 boosted prices, and provided a respite to
the desperate economic situation the apple industry faced from 1996
through 2001.

Over the last two years apple production has increased while the apple
industry has coped with export impediments in Mexico and Taiwan.  More
apple marketing firms have recently gone out of business and growers are
under greater and greater economic stress.  Margins for processing apple
growers are razor thin and urban sprawl continues to put greater
pressure on growers to sell barely profitable orchard operations.

A decision by EPA to revoke the use of azinphos methyl on apples will
accelerate the loss of orchard operations and harm apple growers.  It is
likely that growers will not have the means to profitably control
insects without azinphos methyl.  Their only choice will be to reduce
acreage, thus reducing supply or to abandon their orchards.  Processing
apple growers will find it particularly difficult to afford more
expensive alternatives, since margins for processing apples are small. 
Many growers would be much more likely to rely on pyrethroids and other
more economic alternatives.  This response will eventually lead to
greater miticide applications and future resistance problems with
pyrethroids and miticides. This would lead to the erosion of well
established integrated pest management programs.

Without azinphos methyl, growers will be forced to adopt the more
expensive options, which will reduce profitability.  Some of these
growers, and possibly a significant number, will choose to sell their
orchards to developers for housing developments.  Much of the apple
acreage in New York’s Hudson Valley, Maryland, Pennsylvania, West
Virginia, Virginia, Michigan and New England is under pressure for
commercial development.  Loss of azinphos methyl will certainly
accelerate the conversion of orchard landscapes to residential housing
and shopping malls in these regions.

Economic Impact

In its azinphos methyl proposed reevaluation decision document EPA
states “While these impacts will remain in the millions of dollars
nationally, it is important to note that the overall impact on grower
revenue is relatively small.”  USApple disagrees with EPA’s
characterization of the impact as “relatively small.”  EPA’s
calculation estimates the additional cost from the loss of azinphos
methyl to be as high as $80 million a year.  While EPA chooses to
characterize the cost as a loss in revenue, it is really a loss in
profit, because every additional dollar spent as a cost comes out a
grower’s bottom line profit.  USApple maintains that an $80 million
loss in grower profits is a significant sum and the loss in profits
would be a great burden on the apple industry.  USApple urges EPA to
remove the phase out of azinphos methyl and conduct a reassessment of
the potential risks and benefits in 2010 to avoid creation of a
potentially unnecessary and enormous financial and management burden on
apple growers.   

Azinphos Methyl Use Reaching Critical Use Level

Azinphos methyl is the apple industry’s most important insecticides. 
However, for a variety of reasons use of azinphos methyl is declining. 
The combined impact of the proposed mitigation along with other causes
of use reduction has led to a critical level that is urgently needed by
the industry.  One significant reason for the decline in use is EPA’s
mandated increase in the 14 day reentry interval.  Table 2 shows
azinphos methyl and phosmet use in 2001, 2003 and 2005.  This table
demonstrates how apple growers have responded to the mandated increase
in the azinphos methyl reentry interval of 14 days.  Azinphos methyl use
decreased 31 percent while phosmet use increased 17 percent from 2003 to
2005.  The average number of applications decreased from 2.8
applications per acre in 2003 to 2.4 applications per acre in 2005 and
it is used on 63 percent of apple acreage.

The reason growers are using less azinphos methyl is because a 14 day
reentry interval makes it so difficult for growers to enter their
orchards to perform essential orchard management practices.  Growers
must be able to reenter orchards frequently to perform hand thinning,
mowing, pruning, irrigation and other cultural practices that will
determine the final quality and value of the crop.  Phosmet is more
attractive to growers, since it has a three day reentry period which
allows growers the flexibility to control pests and reenter orchards to
perform essential tasks.  

		Table 2.  Azinphos Methyl and Phosmet Use on Apples

	2001	2003	2005	Percent

	-----1,000 lbs.-----	Change

Azinphos methyl	466.9	522.9	363	-31%

Phosmet	398.4	319.3	372.8	17%

Source: USDA, NASS, Agricultural Chemical Use, July 2006



With the proposed mitigation in place, only the most critical use will
be left to apple growers.  It is reasonable to expect there will be less
environmental exposure over time due to this mitigation.  USApple
recommends EPA consider this information, and allow the proposed
additional mitigation measures to take effect and then evaluate the
effectiveness of these additional mitigation measures as part of a risk
benefit reassessment in 2010.  Adhering to a phase out predetermines the
effectiveness of the mitigation.

Voluntary Risk Mitigation

In response to EPA’s risk concerns the U.S. apple industry volunteered
to reduce its use of azinphos methyl from 8 lbs. of formulated product
to 6 lbs. and to increase the application buffer between orchards and
permanent bodies of water from 25 feet to 60 feet.  In doing so, apple
growers volunteered to reduce use of azinphos methyl by 25 percent.  
Apple growers willingly took this step to help the agency reduce
environmental exposure and to preserve the most critical use of azinphos
methyl.

USApple feels strongly that the remaining azinphos methyl use must be
preserved, because it is critical to the economic viability of apple
growers and has an important role to play in helping growers maintain a
stable biological orchard environment.

Monitoring data have shown that as mitigation measures have been imposed
on azinphos methyl, residues in water have decreased significantly. 
Additionally, these measures seem to have helped in preventing harsh
impacts on the environment, since there have been no reports of fish
kills resulting from azinphos methyl use since the mitigation measures
were imposed. 

The reduction in azinphos methyl use is already reducing the
environmental impact of azinphos methyl use.  Additional mitigation
represents additional protections for non target organisms which will
further result in less impact on the environment.  USApple urges EPA to
wait until 2010 to determine the results of the mitigation, since the
changes in use could significantly reduce the agency’s concerns
regarding ecological risk.

EPA’s Ecological Risk Assessment Significantly Overestimates Potential
Risk

Table 2. Conservative Assumptions in EPA’s Ecological Risk Model

Actual Apple Orchard Practices

	EPA Model Parameters

	Comparison



Label requirements direct growers to “apply only when the wind speed
is less than 10 mph.”  “For all non-aerial applications, wind speed
must be measured adjacent to the application site on the upwind side,
immediately prior to application.”

	

The model assumes all applications are made at a wind speed of 10 mph
and that the wind is always blowing in the direction of the farm pond.	

The model overestimates the amount of drift into the farm pond because
the wind speed will not be 10 mph all the time and the wind will not
blow in the direction of the pond for every application.  Growers prefer
application s with minimal wind speed for most effective target
coverage.

 



Label requirements direct growers to use the largest droplet size
consistent with acceptable efficacy.  “for groundboom and aerial
applications, use medium or coarser spray nozzles according to ASAE 572
definition for standard nozzles or a volume mean (VMD) of 300 microns or
greater for spinning atomizer nozzles.” (aerial applications on apples
are prohibited)

	

The model assumes the droplet size for airblast applications is a fine
to medium droplet size.

	

The model overestimates the amount of spray drift because fine droplets
will be carried a farther distance from the target.  Additionally,
growers are directed by the label to use larger droplet sizes and will
likely follow the recommendation.



Label requirements direct growers making airblast applications to
“turn off outward pointing nozzles at row ends and when spraying the
outer two rows and to minimize spray loss over the top in orchard
applications, spray must be directed into the canopy.”

Many apple growers are utilizing “Smart Sprayers” with built in
devices that detect the structure of the tree canopy, missing trees and
end rows and automatically turn spray nozzles on and off based on the
presence of tree canopy or tree gaps.

	

The model assumes all airblast applications result in spray loss over
the canopy by assuming that the orchard is in a dormant state with no
vegetation.	

The model overestimates the drift calculation because an orchard canopy
with full vegetation is dense and will capture a much higher percentage
of the application than a dormant tree.  Additionally, dormant
applications are prohibited.





Label requirements direct growers making applications to “not apply
within 25 feet of permanent water bodies (rivers, natural ponds, lakes,
streams, reservoirs, marshes, estuaries, or commercial fish ponds).”

 	

The water runoff model assumes the orchard itself starts or ends at the
water line of the pond.  The model would therefore assume that
applications would be made within inches of the farm pond.

	

By not using buffers in its water run off model, the model greatly
overestimates the actual pesticide runoff into water sources. 





Nearly all apple orchards have some form of buffer and vegetation strip
between the orchard and a permanent body of water in excess of 25 feet. 
In most circumstances the vegetation would be dense or even include
thickets, underbrush and trees.  

	

The model assumes no buffer between the edge of the field and the water
body, and does not route the pesticide through the 25 foot wide buffer
area.	

The model overestimates the amount of pesticide runoff by as much as 83
percent by not considering the effect of buffers with vegetative cover
that reduce pesticide loading even though buffers with vegetative cover
are common in apple production. 



Rainfall in apple orchards drains through various soil types, which vary
by region.  The rainfall can then carry pesticide residue into
waterways.

	

The model assumes all apple orchards are composed of soils with high
runoff potential and that pesticide residues carried by water enter the
pond, but the model does not permit water carrying the pesticide to
enter the pond.

 	

The model overestimates the amount of pesticide that would run off into
water sources because some orchards are planted on soils that are not
prone to high runoff potential.



Average rainfall in the regions of Washington state that produce apples
is 6 inches per year.  Washington state produces 57 percent of total
apple production.

  	

The western apple risk scenario was developed using data from an Oregon
site with an average annual rainfall of 36 inches.  	

The model uses a rainfall value that is 6 times greater than the actual
rainfall in majority of Washington orchards.  Using this value will lead
the modeler to predict a greater amount of pesticide entering waterways.









The parameters used by EPA are overly conservative when compared to
actual growing conditions in the apple industry.  Despite the
conservative choices already made for the model’s inputs, EPA makes
the drift value even more conservative by multiplying the generated
value by three.  Tripling the drift value is unreasonable and
unnecessary.

The agency’s preliminary decision document indicates soil particle
runoff is the primary pathway for azinphos methyl entry into its model
farm pond, and that this element is a significant driver in the
calculated aquatic risk.  Important factors in determining the amount of
runoff would be the amount of rainfall, the distance the particles would
have to travel to the pond and the ease at which the particles travel
the distance to the pond.  In this regard, the agency’s approach seems
particularly conservative and unrealistic.

In the Western scenario, the agency uses a site with an average annual
rainfall of 36 inches, when the primary apple production region receives
annual rainfall of 6 inches, and none of that rain falls when azinphos
methyl is used.  The modelers go beyond that to use an annual value of
39.7 inches to capture the 90th percentile of the maximum annual peak
concentration in 30 years to calculate the risk.

Regarding the distance soil particles would travel to the pond, the
model assumes applications are made at the edge of the pond and residues
are on the edge of the pond poised for rain to wash the particles into
the hypothetical pond, even though the label states applications must be
made 25 feet from permanent bodies of water.

Regarding the ease at which soil particles will move, the agency’s
model assumes the ground is bare and free of vegetation when in reality;
grass covers the orchard floor, except for the herbicide strip directly
under trees, in nearly all apple orchards.  EPA maintains it uses
“high runoff potential soils in its model so the simulation will
account for the most sensitive areas where there are apple orchards in
general.”  USApple contends that nearly all apple orchards are covered
in grass and other dense vegetation at the perimeter of orchards, and
this vegetation will prevent soil erosion and movement of soil particles
and pesticides into bodies of water.  

Extensive research has been done on the movement of pesticides using
various vegetative barriers.  Attached below in Table 3 are thirty
studies that conclude that vegetative buffers do prevent movement of
pesticides. 

USApple asserts that EPA’s model is unreasonably conservative and
overlooks actual practices and conditions in apple production that if
taken into consideration would significantly lessen the agency’s
estimated ecological risk.

Table 3 Studies on Pesticide Movement

Pesticide  	 KOC  	 Study Reference  	 Percent Pesticide Trapped  

 Highly adsorbed pesticides  	 	 

	 Chlorpyrifos 6,070  	6,070  	 Boyd, et al., 1999  	 57–79  

 

 Cole, et al., 1997 	 62–99  

 Diflufenican 1,990  	1,990  	 Patty, et al., 1997 	 97  

 Lindane 1,100  	1,100  	 Patty, et al., 1997 	 72–100  

 Trifluralin 8,000  	8,000  	 Rhode, et al., 1980 	 86–96  

 Moderately adsorbed pesticides  	 	 

 Acetochlor 150  	150  	 Boyd, et al., 1999  	 56–67  

 Alachlor 170  	170  	 Lowrance, et al., 1997 	 91  

 Atrazine 100  	100  	 Arora, et al., 1996  	 11–100  

 

 Boyd, et al., 1999  	 52–69  

 

 Hall, et al., 1983  	 91  

 

 Hoffman 1995  	 30–57  

 

 Lowrance, et al., 1997  	 97  

 

 Mickelson and Baker 1993  	 35–60  

 

 Misra, et al., 1996  	 26–50  

 

 Patty, et al., 1997  	 44–100  

 Cyanazine 190  	190  	 Arora, et al., 1996  	 80–100  

 

 Misra, et al., 1996  	 30–47  

 2,4-D 20  	20  	 Asmussen, et al., 1977  	 70  

 

 Cole, et al., 1997  	 89–98  

 Dicamba 2  	2  	 Cole, et al., 1997  	 90–100  

 Fluormeturon 100  	100  	 Rankins, et al., 1998  	 60  

 Isoproturon 120  	120  	 Patty, et al., 1997  	 99  

 Mecoprop 20  	20  	 Cole, et al., 1997  	 89–95  

 Metolachlor 200  	200  	 Arora, et al., 1996  	 16–100  

 

 Misra, et al., 1996  	 32–47  

 

 Webster and Shaw 1996  	 55–74  

 

 Tingle, et al., 1998  	 67–97  

 Metribuzin 60  	60  	 Webster and Shaw 1996  	 50–76  

 

 Tingle, et al., 1998  	 73–97  

 Norflurazon 600  	600  	 Rankins, et al., 1998  	 65  



The combined effect of all of the agency’s conservative assumptions
unfairly compounds the result generated by the model, and leads one to
believe that azinphos methyl use is unreasonably risky to the
environment.  USApple believes that excessive use of conservative
scenarios is producing a distorted picture of the real risk.

A study conducted by Peter S. Burgoon and Michael Rickel in Washington
state seems to support USApple’s view.  In “Pesticide Use and
Toxicity Assay in Mission, Brender and Yaksum Creeks,” the authors
monitored azinphos methyl use around targeted streams, but no daphnia,
which represents the most sensitive aquatic group, were found to be
harmed.  

EPA could gain a clearer view of the real risk through additional
studies.  USApple recommends EPA remove the phase out of azinphos methyl
and conduct a full assessment of the risks and benefits in 2010.  In the
meantime, registrants could conduct additional studies to remove the
uncertainty regarding the ecological risk.

USApple appreciates this opportunity to comment on the agency’s
preliminary decision regarding the reevaluation of azinphos methyl. 
Please contact me by telephone at (703) 442-8850 or via e-mail at  
HYPERLINK "mailto:jcranney@usapple.org"  jcranney@usapple.org  if you
have questions or need additional information.

Sincerely yours,

James R. Cranney, Jr.

Vice President

cc:	USApple Board of Trustees

 K. Arora, S. K. Mickelson, J. L. Baker, Effectiveness of Vegetated
Buffer Strips In Reducing Pesticide Transport in Simulated Runoff,
American Society of Agricultural Engineers Vol. 46(3): 635–644, 2003. 

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

