Notes

Meeting with Metam Alliance

June 2, 2010

Participants:  

Registrants

Lisa Campbell – BERGESON & CAMPBELL, P.C.  

Ian Chart - AMVAC

Dawn Kominski - TKI

Vince Piccirillo – Taminco

EPA

Margaret Rice, John Leahy, Steven Weiss, Andrea Carone, Susan Bartow,
Peter Caulkins, Erik Kraft, Jose Gayoso, Cathryn O’Connell

Notes:

EPA explained that in in the course of label reviews, if the last
stamped approved label had more restrictive language than is required by
a RED, the more restrictive language is generally retained on new
labels.  The Alliance explained that they intended the prototype label
they had submitted to establish universal language for all products
containing metam sodium or metam potassium.

Issue #1:  Spray Drift Statements

Previous labels had different versions of drift statements.  The
Alliance would like all labels to be changed to include this text:

“Do not apply when wind speed favors drift beyond the area intended
for treatment.”

Issue #2:  Greenhouse and Confined Areas

Previous labels had different versions of the statement prohibiting use
in greenhouses and confined areas.  The Alliance does not see issues
with the restrictions against applications in either areas, but would
like labels to have the same statement.  

Possible change to all affected labels would be to add this language:

“Do not use in greenhouses or any other enclosed structure or confined
area.”

Some of the old labels also contain other statements such as “Do not
use in confined areas without adequate ventilation or when fumes may
enter nearby dwellings.”  This statement was not discussed
specifically.

Issue #3:  California Language

The Alliance will talk with DPR to determine if this language will be
required for approval of amended labels in California.

Issues #4:  Language Defining the Treated Area

EPA explained the language in question is not necessary on 2010 labels
since there will not be buffers, and no need to include specific terms
that define the application area.  The Alliance agreed with this edit.

Also, not all labels include  all of the application methods that are
allowed for metam, so some labels approved by EPA had certain methods
removed from the new label if the old label did not contain those
methods.

Issue #5:  Definition of Handlers

Everyone seemed to agree that the additional information describing
handlers was acceptable although it was not on the prototype label the
Alliance submitted. 

Issue #6:  Fumigant Safe Handling Information

EPA accidentally omitted the phrase “in a manner they can
understand…” from the original label table for metam, but this
phrase was and is included in the label tables for methyl bromide,
chloropicrin, and dazomet.  These changes are consistent with the
changes for the other chemicals and the Alliance agreed this was
acceptable.  The content and scope of this requirement will be raised in
a separate meeting with the other registrant representatives.

Issue #7:  Air Monitoring Language

The chemical that should trigger the air monitoring requirements should
be MITC not metam.  Everyone agrees with this change.

Issue #8:  Chemigation Parameters

The Alliance is checking on the specific concerns with this item.

Issue #9:  Air Temperature

An air temperature restriction on applications above 90 degrees F was
required on all labels for applications via Center Pivot; Solid Set
Sprinkler; Drench; and Drip, Flood Basin, Furrow and Border
applications.  It appears from the conversation at the meeting that this
restriction was included on the old labels, but the Alliance does not
want this restriction applied to all application methods, and may not
want it applied to the ones required in the label approval letters.  

EPA will discuss this before the next meeting. 

Issue #10:  Soil Moisture 

The Alliance noted that new labels do not have consistent soil moisture
statements.

EPA explained that the soil moisture language is different depending on
the application method. For methods for which tillage is possible either
prior or during application, such as shank applications, the new labels
allow tillage either prior to or during application.  For methods for
which tillage is not practical during application, such as center pivot,
new labels require tillage prior to application., since the instructions
are not practical for every situation.

The Alliance is checking to make sure the labels are consistent
depending on application method, but EPA’s approach was generally
acceptable to the participants.  

Issues #11:  Plant Residue

The Alliance is comfortable with EPA’s change as long as it is
consistent across labels.

Issue # 12:  Tillage

Same discussion and outcome as Issue #10.

Issue #13:  Optional GAPs

EPA explained that the phrase “(registrants may also include optional
GAPs)” was intended by EPA to allow companies to submit their own GAPs
if they wanted to do so.  Since no additional GAPs were submitted with
the labels, this statement was deleted from the approved labels.  The
Alliance is comfortable with the change given the explanation from EPA.

Issue #14:  Application Rates

The Alliance had questions about the maximum rates allowed on some of
the product labels.  The Alliance will provide some specific examples
and calculations of the rates for the products of concern.  EPA
explained that not all products are formulated with the same percent
active ingredient, so the maximum application rates for each product
would be different across products.

Issue #15:  Soil Covering Method

The Alliance will follow up with this and provide some additional
information.

Issue #16:  Weed Sprayer

The Alliance is checking with users to help define this term.

Issue #17:  User Safety Recommendations

The Alliance wants all labels to contain the same restrictions and they
will propose a common change for all products. 

 PAGE   

 PAGE   3 

