an
Akzo
Nobel
Company
Eka
Chemicals
Inc.

1775
W.
Oak
Commons
Ct.

Marietta,
GA
30062
Tel.
+
770
578­
0858
Fax
+
770
578­
1359
info@
eka.
com
www.
eka.
com
May
13,
2005
Jacqueline
Guerry
USEPA
Headquarters
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
D.
C.
20460
Dear
Jacqueline:

Thank
you
for
giving
us
the
opportunity
to
review
and
comment
on
the
Ecological
Risk
Assessment
for
the
reregistration
of
sodium
chlorate.
Let
us
address
a
few
points
where
we
disagree.

1)
Application
Rate
We
see
in
the
market
place
two
distinct
applications.
a.
as
a
defoliant/
desiccant
on
a
variety
of
crops,
b.
as
weed
control
in
non­
agricultural
areas.

Our
own
sales
of
sodium
chlorate
outside
the
traditional
market
of
pulp
bleaching
are
only
for
the
defoliant
application.
We
have
not
sold
any
sodium
chlorate
for
several
years
to
the
weed
control
application.
Our
assessment
is
that
sodium
chlorate
has
been
replaced
by
other
products.
We,
therefore,
intend
not
to
maintain
registration
for
sodium
chlorate
for
this
application.

In
the
defoliant/
desiccant
market
it
seems
that
the
common
practice
is
a
one
time
application
of
sodium
chlorate
without
a
repeat
treatment
within
30
days
as
assumed
in
your
assessment.
However,
we
have
found
anecdotal
reference
to
a
"
repeat"
application
within
a
few
days
after
the
initial
dose.
We
are
investigating
whether
this
is
still
practical.
Based
on
our
current
practical
knowledge,
we
have
not
seen
application
rates
of
more
than
12
pounds
sodium
chlorate
per
acre.

2)
Environmental
Fate
Based
on
work
performed
in
Europe
and
published
in
"
GB
Rikken,
AGM
and
CG
van
Ginkel
(
1996);
Transformation
of
(
per)
Chlorate
into
Chloride
by
a
Newly
Isolated
Bacterium;
Reduction
And
Dismutation,
Applied
Microbiology
and
Biotechnology,
45
Page
420­
426,"
sodium
chlorate
is
reduced
to
sodium
chloride
very
effectively
in
the
environment.
Sodium
chlorite
will
be
intermittently
formed,
but
it
does
not
accumulate
as
the
further
breakdown
of
chlorite
is
much
faster
than
the
time
limiting
step
of
the
chlorate
reduction.
Therefore,
we
would
not
consider
that
sodium
chlorite
is
a
viable
product
of
the
environmental
reduction
of
sodium
chlorate.

Based
on
the
above
and
the
comments
throughout
your
document,
we
recognize
short
comings
in
our
existing
product
labels
which
we
are
committed
to
amend.

Sincerely,

Michael
S.
Wenk
Manager
of
Regulatory
Affairs
