UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Response
to
Comments
for
Dicamba,
D317713
FROM:
Nicole
Zinn,
Biologist
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

THRU:
Arnet
Jones,
Chief
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

TO:
Kendra
Tyler,
Chemical
Review
Manager
Susan
Lewis,
Chief
Special
Review
and
Reregistration
Division
PEER
REVIEW
PANEL:
March
29,
2006
SUMMARY
During
the
Phase
3
comment
period
during
the
dicamba
reregistration
process,
BEAD
received
comments
from
the
University
of
Hawaii
at
Manoa
and
the
San
Francisco
Department
of
Environment
(
SFE).
The
comment
from
Hawaii
highlights
the
important
uses
of
dicamba
in
Hawaiian
agriculture.
The
comment
from
San
Francisco
encourages
the
Agency
to
consider
safer
alternatives
when
conducting
a
benefits
assessment.
Both
comments
will
be
considered
if
a
benefits
assessment
is
deemed
necessary
for
this
chemical.

RESPONSE
TO
COMMENTS
Comments
were
received
from
the
University
of
Hawaii
at
Manoa
and
the
San
Francisco
Department
of
Environment
(
SFE).
BEAD
has
summarized
and
responded
to
the
individual
comments
below.
2
Comment
from
the
University
of
Hawaii
at
Manoa:

Dicamba
is
important
for
golf
courses,
seed
corn,
sugarcane
and
asparagus.
Dicamba
is
important
for
resistance
management
purposes
on
golf
courses.
For
seed
corn,
it
is
believed
that
dicamba
tolerance
has
been
incorporated
into
the
breeding
stock
and
that
it
may
take
considerable
effort
to
find
a
suitable
alternative
broadleaf
herbicide.
In
sugarcane,
dicamba
is
useful
when
other
herbicides,
such
as
atrazine
and
2,4­
D,
are
not
used
or
used
to
a
lesser
extent
and
to
control
weed
species
(
Desmodium
spp.)
not
controlled
with
2,4­
D.
No
additional
details
were
provided
for
the
asparagus
use.

BEAD
Response:

BEAD
has
limited
data
and
information
for
crops
grown
in
Hawaii.
For
the
sites
described
in
the
comments,
with
the
possible
exception
of
sugarcane,
there
is
little
information
available
that
pertains
to
production
in
Hawaii.
Therefore,
it
is
very
useful
for
the
University
of
Hawaii
to
indicate
the
important
uses
of
dicamba
in
Hawaii.
Comments
that
include
specific
information
about
target
pests,
alternatives
and
usage
are
most
useful.
If
a
benefits
assessment
is
needed,
these
comments
could
help
BEAD
focus
its
assessment.

Comment
from
San
Francisco
Department
of
Environment
(
SFE):

When
conducting
a
benefits
assessment,
the
Agency
should
consider
available
alternatives,
including
those
alternatives
that
are
considered
safer.
Not
considering
alternatives
"
skews
the
perceived
need
for
the
products
being
considered
for
registration."
SFE
is
particularly
concerned
with
"
weed
and
feed"
products.
The
comment
further
indicates
that
SFE
is
currently
using
safer
alternatives.

BEAD
Response:

BEAD
evaluates
the
available
alternatives
in
our
alternatives
and
benefits
assessments.
If
a
benefits
assessment
is
conducted
for
dicamba,
BEAD
would
be
interested
to
learn
which
alternatives
are
being
used
by
SFE.
