SMART
Meeting/
Aliphatic
Solvents
Case
Page
1
4/
19/
06
SMART
Meeting:
April
19,
2006
Aliphatic
Solvents
Case
Mineral
Oils
/
Aliphatic
Petroleum
Hydrocarbons
Attendees:

Name
Division/
Company
Akiva
Abramovitch
EPA/
RD
Brian
Anderson
EPA/
EFED
Wilfred
Burr
USDA/
OPMP
Robert
Butz
ChemReg
Steve
Carey
EPA/
EFED/
ERBB
Mark
Corbin
EPA/
EFED
Becky
Daiss
EPA/
HED
Jim
Damico
SciReg,
Inc.

David
Dawe
SciReg,
Inc.

Michael
Fefer
Petro
Canada
Anne
Goldsmith
Calumet
Lubricants
Co.

Bentley
Gregg
EPA/
SRRD
Arthur
Grube
EPA/
BEAD/
EAB
Jennifer
Hall
Sunoco,
Inc.

John
Hebert
EPA/
RD
Kelly
McAloon
Versar,
Inc.

Richard
Michell
EPA/
BEAD/
BAB
Nathan
Mottl
EPA/
SRRD
Roy
Olson
Drexel
Chemical
Co.

John
Pates
EPA/
SRRD
Mark
Perry
EPA/
SRRD
Fred
Smith
SciReg,
Inc.

Stephanie
Syslo
EPA/
OPP/
EFED
Bob
Vincent
BVA
Kedra
Wherry
Drexel
Chemical
Co.

Nancy
Wright
Sunoco,
Inc.
SMART
Meeting/
Aliphatic
Solvents
Case
Page
2
4/
19/
06
A.
Introduction
and
Purpose
of
the
SMART
meeting
Ben
Gregg
of
EPA/
SRRD
welcomed
everyone
to
the
meeting
and
began
with
introductions
of
those
present,
and
then
provided
some
background
information:


A
meeting
was
held
with
the
Horticultural
Spray
Oil
Task
Force
back
on
October
13,
1999
on
the
aliphatic
solvents
and
SRRD
has
received
the
PowerPoint
presentations
from
that
meeting,
and
they
have
been
very
helpful
in
providing
information
on
the
production
methods
for
the
spray
oils,
as
well
as
some
data
on
the
mammalian
toxicity
and
the
environmental
fate
and
effects
(
although
it
is
somewhat
historical
information).


There
is
an
August
3,
2006
deadline
for
the
aliphatic
solvents
RED,
as
mandated
by
FQPA.


The
information
found/
provided
indicates
that
there
are
two
food
tolerances
still
active,
for
post­
harvest
corn
and
sorghum,
but
SRRD
asked
those
in
attendance
if
anyone
has
any
information
on
whether
these
usage
patterns
are
still
in
use
(
a
preliminary
survey
of
the
165
labels
does
not
reveal
any
labels
which
still
list
these
uses).


EPA
still
has
some
information/
data
needs,
and
the
purpose
of
this
meeting
is
to
share
what
EPA
does
have
and
an
update
on
the
status
within
the
various
divisions
in
their
assessments,
and
what
information
is
still
needed.

B.
Current
Status
of
the
RED
Data
and
Assessments
SRRD:

Ben
Gregg
of
SRRD
gave
a
brief
synopsis
of
the
role
of
SRRD
in
the
RED
process.


RED
stands
for
Reregistration
Eligibility
Decision.


The
process
has
been
in
use
for
a
long
time,
since
the
early
1990s
for
REDs,
and
back
into
the
1980s
for
developing
Registration
Standards
for
the
various
active
ingredients.


Congress
had
mandated
the
reregistration
of
pesticide
chemicals.


For
the
low
risk
REDs,
a
more
expedited
single­
phase
process
has
been
developed
as
opposed
to
that
used
for
most
products,
either
a
4­
phase
or
6­
phase
process
for
other
REDs.


Since
the
chemicals
in
these
low
risk
REDs
are
expected
to
have
low
toxicity,
SRRD
receives
little
data
from
HED,
but
does
receive
help
from
EFED
and
BEAD
and
also
has
interactions
with
the
Registration
Division
(
RD).


All
these
divisions
pull
together
their
own
sections
of
the
RED
document
and
SRRD
combines
these
materials
into
the
one
final
document.


SRRD
also
tracks
data
call­
in
materials
and
reviews
these
documents.
After
REDs
are
issued,
the
Agency
prefers
to
receive
product
specific
data,
especially
for
product
chemistry
data,
but
for
acute
toxicity
testing,
it
will
allow
for
some
batching
if
the
chemicals
are
similar
(
to
reduce
the
number
of
animals
which
may
be
needed
for
acute
toxicity
testing).
SMART
Meeting/
Aliphatic
Solvents
Case
Page
3
4/
19/
06
**
At
this
point
in
the
meeting,
Nancy
Wright
of
Sunoco,
Inc,
and
Jim
Damico
of
SciReg,
Inc.,
(
both
representatives
of
the
Horticultural
Spray
Oil
Task
Force
[
HSOTF])
asked
to
read
aloud
an
anti­
trust
compliance
statement
from
the
Task
Force.**

BEAD
Arthur
Grube
of
BEAD
provided
some
background
on
the
information
available
on
usage
of
spray
oils
on
various
crops,
typical
application
rates
versus
maximum
application
rates
listed
on
labels,
and
the
sources
of
information
on
amounts
and
crops.


Grube
indicated
that
the
data
sources
suggest
there
is
information
on
fewer
products
than
the
full
number
of
those
registered;
it
was
difficult
at
first
to
identify
the
full
data
set
of
names
for
the
chemicals
as
collected
within
each
of
the
various
data
bases;
it
was
assumed
that
this
may
be
due
to
the
diversity
of
data
reporting
and
the
fact
that
most
products
are
reported
as
petroleum
oils
or
petroleum
distillates;
they
are
lumped
together
by
name
in
most
cases.


Based
on
the
sources
of
data,
BEAD
has
prepared
a
SLUA
(
Screening
Level
Usage
Analysis),
which
provides
a
broad
outline
summary
of
usage
(
including
pounds
of
active
ingredient,
percent
of
crop
treated,
and
maximum
percent
of
crop
treated).


The
pounds
of
active
ingredient
and
percent
of
crop
treated
are
average
numbers.


The
percent
of
crop
treated
provided
in
SLUA
comes
from
several
data
sources,
including
2
major
sources
and
2
additional
sources,
which
are
used
if
the
required
information
is
not
available
from
the
major
sources:
o
NASS
(
National
Agricultural
Statistics
Service)
of
USDA
(
Major
source)


Been
collected
since
1990

Collect
data
by
state,
yearly
for
several
major
field
crops
and
alternate
years
for
fruit
and
vegetables

Information
includes:
percent
crop
treated,
pounds
of
active
ingredient
used,
application
rates,
number
of
applications

Publicly
available
information
o
Doane
Marketing
Research
(
Major
source)


Proprietary
information

Provided
in
the
form
of
a
database

Information
includes:
pounds
of
active
ingredients,
acres
treated,
application
rates,
pest
targets

Doane
collects
data
yearly
for
most
crops
and
for
most
states
o
California
Department
of
Pesticide
Regulation
(
CalDPR)
(
Additional
source)


Data
can
be
very
detailed,
down
to
the
field
level

CalDPR
requires
all
farmers
to
report
pesticide
applications

Information
includes:
summary
of
pounds
of
active
ingredients
by
pesticide
and
crop,
as
well
as
individual
application
information
by
date
and
location.
SMART
Meeting/
Aliphatic
Solvents
Case
Page
4
4/
19/
06

Used
mostly
when
most
of
crop
is
grown
in
California
and
neither
NASS
nor
Doane
provide
adequate
information
o
National
Center
for
Food
and
Agricultural
Policy
(
NCFAP;
specifically
Leonard
Gianessi)
(
Additional
source)


Data
tends
to
be
older;
and
it
is
not
always
clear
when
it
was
collected

Information
includes:
percent
crop
treated,
pounds
of
active
ingredient
used,
and
application
rates

Database
updated
every
5
years

NASS
and
Doane
data
based
on
surveys;
therefore,
the
data
do
show
some
fluctuations,
and
there
is
some
degree
of
uncertainty
associated
with
those
datasets.


Handouts
were
provided
showing
SLUA
data
for
petroleum
oils,
as
well
as
data
collected
from
NASS.


Based
on
the
numbers
provided
on
SLUA
for
petroleum
oils,
citrus
appears
to
have
the
highest
usage,
but
SLUA
covers
many
other
crops
as
well.


Some
crops
are
listed
that
are
not
registered,
and
it
is
believed
that
this
may
indicate
some
misuse
of
the
products
OR
it
could
indicate
cancelled
products/
uses.


A.
Grube
also
provided
usage
data
obtained
from
NASS
(
National
Agricultural
Statistics
Service).


He
indicated
that
all
use
rates
were
lower
than
the
maximum
application
rates
listed
on
the
various
product
labels,
and
that
there
is
a
need
for
information
on
what
rates
are
actually
typically
used
by
applicators.


J.
Damico
indicated
that
the
Task
Force
was
in
the
process
of
gathering
data
and
should
be
able
to
provide
it
within
a
week
or
two.
He
indicated
that
it
was
fairly
specific
(
by
state
and
crop),
and
would
need
to
be
treated
as
confidential,
because
the
various
companies
on
HSOTF
view
their
own
data
as
proprietary.

EFED
Mark
Corbin
provided
some
information
on
the
status
of
EFED
with
respect
to
the
aliphatic
solvents.


On
the
exposure
side
of
the
assessment,
one
issue
is
a
lack
of
data;
specifically,
the
lack
of
information
on
the
physical
and
chemical
properties
of
the
chemicals,
which
reflect
their
environmental
fate
properties.


EFED
is
using
a
tiered
approach
and
screening
level
models
in
a
generic
way
in
order
to
do
the
assessment
with
the
limited
data
on
hand.


Their
assessment
is
focused
mostly
on
the
aquatic
side,
in
terms
of
effects
of
offsite
drift
and
of
run­
off.


The
environmental
risk
assessments
related
to
mosquito
applications
are
being
done
separately
from
the
agricultural
uses
of
spray
oils.


The
agricultural
spray
oil
assessment
is
being
conducted
using
the
HydroCarbon
Block
Method,
which
is
based
on
published
information.
This
Block
Method
is
used
to
get
an
idea
of
the
range
of
constituents
of
the
petroleum
oil,
and
to
SMART
Meeting/
Aliphatic
Solvents
Case
Page
5
4/
19/
06
provide
estimates
of
the
environmental
fate
properties
of
the
spray
oils
based
on
the
individual
components.


On
the
terrestrial
side
of
the
assessment,
the
approach
is
an
even
more
simplified
tiered
approach;
there
are
some
laboratory
toxicity
data
for
birds
and
mammals,
and
a
screening
level
approach
will
be
taken;
the
resulting
assessment
suggests
that
the
main
concern
is
for
bird
eggs.


Regarding
the
aquatic
toxicity
data,
it
appears
that
for
fish,
the
spray
oils
are
not
very
toxic;
however,
for
aquatic
invertebrates,
the
acute
data
indicate
a
high
level
of
toxicity
to
daphnia;
the
oyster
is
fairly
sensitive
as
well,
based
on
one
oyster
shell
deposition
study.


J.
Damico
indicated
that
the
Task
Force
has
submitted
two
studies
to
EPA
relative
to
Generic
Data
Call­
Ins
for
environmental
fate
data:
one
document
on
adsorption/
desorption
(
MRID
459453­
01)
and
another
on
spray
drift
(
MRID
460428­
01).

HED
Ben
Gregg
provided
some
background
on
the
acute,
sub­
chronic
and
chronic
toxicity
information
available,
as
well
as
the
status
of
the
worker
exposure
and
risk
assessment.


For
the
acute
toxicity
studies,
toxicity
does
not
appear
to
be
high;
all
the
LD50
values
are
quite
high.


For
the
sub­
chronic
and
chronic
toxicity,
repeated
dose
studies,
there
is
some
information
available
(
various
28­
day
dermal
studies
and
a
variety
of
repeat
dose
inhalation
studies).


An
IARC
document
from
1982
indicates
that
one
of
the
chemicals
included
in
the
aliphatic
solvents
Case
(
i.
e.,
Mineral
Oil)
is
a
carcinogen;
however,
IARC
revised
this
decision
in
1987
to
reflect
that
only
the
untreated
form
of
Mineral
Oil
is
carcinogenic.
When
Mineral
Oils
are
moderately
to
highly
treated,
there
is
no
carcinogenic
risk.


There
have
been
waiver
requests
submitted
for
the
repeat­
dose
inhalation
studies;
however,
there
are
several
studies
that
have
been
submitted
and
reviewed
by
the
Agency
(
e.
g.,
5­
day,
9­
day
and
28­
day
inhalation
studies,
with
DERs
having
been
written);
these
studies
were
performed
as
whole
body
exposures;
most
effects
seen
were
primarily
physical
effects.


In
addition,
a
90­
day
inhalation
study
was
submitted
in
2000,
which
was
performed
as
a
nose­
only
exposure,
examining
solely
the
technical
product
used
in
the
field.
The
study
was
submitted
for
a
mosquito
larvicide
product,
but
for
extrapolating
these
data
to
agricultural
products
that
may
be
mixed
with
water,
there
may
be
a
potential
for
the
water
mixture
to
alter
the
inhalation
toxicity.
A
DER
is
currently
being
written
for
this
90­
day
inhalation
study,
and
an
inhalation
toxicologist
from
HED
will
assist
SRRD
in
interpreting
these
data.


A
worker
assessment
will
be
performed
for
inhalation
only,
examining
a
range
of
scenarios
and
application
equipment
(
including
homeowner
application).
SMART
Meeting/
Aliphatic
Solvents
Case
Page
6
4/
19/
06

It
is
possible
that
some
scenarios
might
result
in
worker
risk
concerns,
and
thus
there
may
be
a
need
for
additional
PPE
(
for
example,
it
might
be
possible
that
applicators
operating
airblast
equipment
may
be
required
to
wear
a
respirator).

RD
Akiva
Abramovitch
provided
some
information
from
the
Registration
Division
of
EPA.


He
noted
that
normally
EPA
deals
with
chemicals
for
which
there
is
one
specific
name
for
the
active
ingredient.


In
the
case
of
these
petroleum
spray
oils,
however,
there
is
much
more
information
provided
on
the
labels
as
far
as
the
chemical
name
and
some
properties
of
the
active
ingredient,
because
the
labels
are
dealing
with
a
mixture.


Specifically,
there
is
an
issue
with
the
fact
that
there
are
multiple
names
for
similar
chemicals,
and
there
are
different
percents
of
unsulfonated
residues
and
boiling
ranges
reported
on
the
various
labels.


There
is
difficulty
in
finding
correlations
between
what
might
be
similar
products,
and
he
suggested
trying
to
come
to
some
consistency
in
the
naming
of
these
active
ingredients.


There
is
also
an
issue
with
the
PC
codes;
there
are
2
codes
with
no
obvious
explanation
as
to
why
there
are
two;
however,
it
was
suggested
that
the
PC
code
issue
was
related
to
a
historical
issue
within
RD
among
the
PMs;
there
may
have
been
confusion
as
to
how
to
classify
these
chemicals
initially.


J.
Damico
of
the
Task
Force
indicated
that
they
agree
that
there
is
confusion
on
the
naming,
and
noted
that
there
have
been
talks
with
the
Agency
on
condensing
the
names
down
to
one
name,
"
mineral
oil",
with
specifications
associated
with
that
name:
o
Specifications
relate
to
21
CFR
178.3620(
c):


Refined
from
Virgin
Crude
Oil

Color
per
ASTM
D1500
=
5.5
maximum

Distillation
per
D1160
@
10
mmHg
 
Initial
boiling
point
converted
to
atmospheric
pressure
=
450oF
maximum

Ultraviolet
absorbance
limits
per
21
CFR
178.3620(
c)
iii.
o
1997
Series
62
Proposal
 
Modified/
added
requirements:


Distillation
per
D1160
@
10
mmHg
 
Initial
boiling
point
converted
to
atmospheric
pressure
=
550oF
minimum

Unsulfonated
residue
per
ASTM
D483
=
92%
minimum

Michael
Fefer
of
Petro­
Canada
presented
a
somewhat
different
recommendation
concerning
the
nomenclature.


A
representative
of
EFED
(
Steph
Syslo)
indicated
that
it
would
be
helpful
to
identify
and
classify
chain
lengths
since
the
toxicities
could
differ
based
on
the
chain
length.


Anne
Goldsmith,
of
Calumet
Lubricants
Co,
indicated
that
the
most
objective
way
(
from
a
manufacturer's
point
of
view)
to
describe
oils
is
to
use
their
boiling
point;
chain
length
could
be
isolated,
but
that
is
not
the
general
practice
and
is
fairly
SMART
Meeting/
Aliphatic
Solvents
Case
Page
7
4/
19/
06
difficult;
the
mineral
oil
specifications
were
developed
to
limit
the
number
of
chains
and
to
require
a
level
of
purity
down
to
very
low
levels
of
aromatic
and
naphtha
components
to
avoid
phytotoxicity
(
but
that
some
small
percentage
of
these
components
were
needed
to
provide
pourability
 
if
the
percents
are
too
low,
the
materials
are
paraffin
waxes
and
will
not
pour).


It
was
noted
by
Ben
Gregg
that
this
discussion
on
nomenclature
would
be
taken
up
again
with
SRRD's
Division
Director
and
maybe
RD's
Division
Director,
and
possibly
the
OPP
Office
Director
as
well,
and
that
the
issue
would
not
be
resolved
at
this
meeting.

Inerts
Ben
Gregg
stated
that
there
are
exemptions
from
the
requirement
for
a
tolerance
listed
in
40
CFR
Part
180.910
for
food
[
and
180.930
for
animal
uses]
which
specifically
list
Mineral
Oil,
as
well
as
petroleum
hydrocarbons,
light
odorless,
and
petroleum
hydrocarbons,
synthetic
isoparaffinic
with
various
sections
of
21
CFR
cited
for
various
of
these
ingredient
oils.
There
is
also
an
exemption
from
the
requirement
for
a
tolerance
listed
in
40
CFR
180.905
for
"
petroleum
oils."
(
In
addition,
there
are
the
two
food
use
tolerances
listed
for
"
Mineral
Oil"
as
an
active
ingredient;
for
post­
harvest
corn
and
for
post­
harvest
sorghum,
at
40
CFR
180.149.)

C.
Areas
where
OPP
still
has
requests
for
additional
data
for
refining
the
RED
Ben
Gregg
presented
several
questions
on
which
OPP
would
appreciate
any
additional
information.
These
questions
are
outlined
below,
along
with
input
received
during
the
meeting.
Additional
input
is
expected
from
the
HSOTF,
and
various
registrants.

Question#
1:
Actual
Use
and
Usage
Data:
Do
you
agree
with
the
Agency's
use
estimates
outlined
in
the
Screening
Level
Usage
Analysis
(
SLUA)?
If
not,
please
explain
the
specific
disagreement
and
provide
rationale
and
data
sources.
In
the
past
three
years,
how
many
pounds
of
active
ingredient
were
used
nationally
for
each
use
site?
Please
provide
regional
information
as
well.
What
are
the
typical
application
rates
for
each
use
site?
Please
provide
regional
information
as
well.
Do
you
have
any
additional
information?
If
your
estimates
are
from
a
single
source,
how
do
they
compare
with
publicly
available
sources,
such
as
from
USDA
and
California
DPR?

Responses:
David
Dawe
(
SciReg):
For
the
most
part,
yes.
Grapes
were
apparently
not
properly
reported
in
the
1997
Gianessi
document.
The
label
rates
will
vary
and
are
specific
to
each
crop
because
the
amount
needed
to
cover
each
crop
is
well
defined.

Arthur
Grube
(
BEAD):
On
the
NASS
handout,
the
maximum
application
rate
identified
on
labels
(
477
lb
ai/
A)
does
not
appear
in
the
averages
reported,
but
this
does
not
mean
this
rate
is
not
being
used.
SMART
Meeting/
Aliphatic
Solvents
Case
Page
8
4/
19/
06
Mark
Corbin
(
EFED):
Knowing
average
application
rates
is
good
in
order
to
characterize
the
actual
maximum
rates;
however,
there
is
a
need
to
know
the
reported
maximum
rates
actually
being
used
and
where
they
are
actually
being
applied,
geographically
(
especially
when
dealing
with
endangered
species).

Question#
2:
By
use
site,
how
many
total
acres
are
treated
per
day?

Responses:
David
Dawe
(
SciReg):
For
orchards,
the
application
method
is
typically
airblast
and
is
not
done
as
a
spot
treatment.
The
high
range
applications
can
reach
800
gal/
A
[
as
the
volume
of
spray
mix],
but
applicators
are
trying
to
cut
back
on
the
volume
being
used.
Typical
ranges
are
from
50­
200
gal/
A
or
from
100­
800
gal/
A.

Question#
3:
For
each
major
use
site,
how
many
different
applications
might
be
made
per
season
for
each
method
of
application?

Reponses:
David
Dawe
(
SciReg):
More
applications
are
made
on
some
crops
than
others.
Most
times
this
is
weather
related.
Typically,
there
is
only
one
application
per
year.

Question#
4:
What
is
the
total
time
during
the
year
that
any
one
commercial
applicator
may
be
applying
these
products
(
more
than
one
month
at
a
time
anywhere
in
the
country)?

Responses:
David
Dawe
(
SciReg):
A
month
is
probably
a
reasonable
time.
The
application
is
performed
late
in
the
season
and
commonly
used
insect
life
cycle
models
are
used
to
pinpoint
the
best
application
time.

Question#
5:
What
are
the
typical
application
rates?
What
information
do
you
have
on
how
often
these
Mineral
Oil
/
Aliphatic
Petroleum
Hydrocarbon
products
are
used
in
combination
with
other
pesticides?

Responses:
David
Dawe
(
SciReg):
Applicators
routinely
use
tank
mixes.
It
is
uncommon
to
just
apply
the
water­
mixed
mineral
oil
alone,
and
typically
other
active
ingredients
would
also
be
applied.

Registrants
will
provide
a
sentence
or
two
to
EPA
on
this
question.

Question#
6:
What
is
the
frequency
and
timing
of
application
(
typical
and
maximum)?
How
often
is
the
pesticide
applied?
What
is
the
typical
and
minimum
interval
between
applications?
Describe
seasonal
variations
in
use.
Provide
information
on
typical
and
maximum
areas
of
application.

Responses:
Registrants
may
provide
details
at
a
later
date
to
EPA.
SMART
Meeting/
Aliphatic
Solvents
Case
Page
9
4/
19/
06
Question#
7:
Do
you
know
of
any
emerging
equipment
or
cultural
practices
that
could
reduce
exposure
to
your
product
in
food,
to
workers,
or
in
the
environment?

Responses:
Registrants
may
provide
details
at
a
later
date
to
EPA.

Question#
8:
What
other
pesticides
(
insecticides/
miticides)
are
used
instead
of
these
products,
from
a
cost/
benefit
point
of
view,
what
are
the
competing
products?
What
is
unique
about
products
containing
this
active
ingredient?
What
alternatives
are
available?
Are
there
any
constraints
to
the
use
of
alternatives
such
as
cost
or
efficacy?
Is
there
any
geographic
area
where
there
are
no
alternatives?

Responses:
Registrants
may
provide
details
at
a
later
date
to
EPA.

Question#
9:
PPE:
Currently
there
seem
to
be
no
requirements
for
respiratory
protection,
even
for
applicators
making
applications
with
air­
blast
equipment
to
orchards.
Does
anyone
think
that
it
would
not
be
prudent
to
add
language
to
labels
to
require
the
use
of
respirators
(
maybe
only
the
dust­
mist­
type)
for
those
applicators
operating
air­
blast
equipment?

Responses:
Registrants
indicated
there
is
no
issue
as
long
as
the
requirements
are
equal
and
reasonable
and
the
equipment
is
proper.

Question#
10:
Homeowner
Uses:
Does
anyone
have
any
information
indicating
that
home­
owner
/
residential
site
applications
(
fruit
trees,
ornamentals)
might
pose
concerns,
during
application
or
post­
application?

Responses:
Registrants
indicated
most
applications
are
performed
by
commercial
applicators
to
home/
residential
areas.
However,
there
are
some
ready­
to­
use
(
RTU)/
diluted
homeowner
products.

Question#
11:
Spray
Zone
Application
Restrictions:
Because
of
the
potential
for
certain
types
of
ecological
risk
concerns
(
toxic
effects
to
aquatic
water
column
invertebrate
organisms),
the
Agency
is
considering
requiring
language
be
included
on
the
labels
for
"
buffer
zones"
for
those
application
sites
adjacent
to
surface
waters.
Is
there
any
information
on
usage
sites
where
these
"
spray
zone
application
restrictions"
adjacent
to
water
bodies
would
be
impossible
or
impractical?
What
would
be
a
practical
buffer
zone,
acceptable
to
growers,
for
applications
to
use
sites,
for
the
distance
to
an
adjacent
surface
water
body?

Responses:
Mark
Corbin
(
EFED):
EFED
is
examining
the
effect
of
buffers
on
exposures,
which
provides
information
on
what
chemicals
and
how
much
of
the
chemical
reaches
water
via
spray
drift,
not
via
runoff.
SMART
Meeting/
Aliphatic
Solvents
Case
Page
10
4/
19/
06
Jim
Damico
(
SciReg):
Noted
that
spray
drift
data
was
submitted
to
the
Agency
and
has
been
requested
to
be
reviewed.

Brian
Anderson
(
EFED):
The
daphnia
study
was
initially
classified
as
invalid
because
the
solubility
had
not
been
characterized
and
they
could
not
be
sure
of
what
was
actually
in
the
water
(
i.
e.,
what
the
daphnia
were
exposed
to).
The
study
is
being
revisited
in
terms
of
looking
at
it
in
correlation
to
a
system
being
loaded
with
oil.

Question
#
12:
Are
there
any
ecological
incidents
(
nontarget
plant
damage
and
avian,
fish,
reptilian,
amphibian
and
mammalian
mortalities)
that
have
been
reported
while
the
current
use
practices
have
been
in
place?

Responses:
EFED
has
a
data
base
where
environmental
incident
reports
are
compiled
(
reporting
is
required
under
Section
6(
a)
2).
SRRD
will
check
with
HED
for
incident
reports
for
any
human
exposures.
Registrants
are
requested
to
provide
any
additional
data
which
they
may
have.

Question
#
13:
Nomenclature:
There
are
many
names
for
the
actual
active
ingredients
which
are
listed
on
the
various
labels.
Should
the
Agency
attempt
to
require
a
more
limited
name
or
set
of
names?
What
would
that
name,
or
those
few
names,
be?

Responses:
This
topic
was
already
discussed
during
the
meeting.

Question
#
14:
Does
anyone
have
any
suggestions
for
a
different
grouping
of
these
active
ingredients,
than
that
currently
being
regulated
and
registered
by
the
Agency?

Responses:
This
topic
was
already
discussed
during
the
meeting.

Question
#
15:
Tolerance
Issues:
Is
there
still
any
use
of
Mineral
Oil
for
treatment
of
"
post­
harvest
corn"
and
"
post­
harvest
sorghum"?
The
only
existing
tolerances
for
this
active
ingredient
are
for
these
grains,
"
to
combat
storage
insect
infestation"
(
40
CFR
180.149).
These
tolerances
apparently
date
back
to
over
50
years
ago.
Does
any
registrant
have
these
uses
on
any
of
their
labels,
or
know
of
any
other
registrants
having
such
labels,
which
would
make
it
important
to
retain
this
tolerance
on
the
active
ingredient?

The
other
uses
for
these
active
ingredients
are
apparently
covered
under
the
section
involving
the
"
exemption
from
the
requirement
for
a
tolerance"
(
40
CFR
180.905,
.910,
and
[
maybe]
.930).

Responses:
Registrants
may
provide
details
at
a
later
date
to
EPA.

Mosquito
Larvicide
Uses:
SMART
Meeting/
Aliphatic
Solvents
Case
Page
11
4/
19/
06
There
are
some
(
apparently
only
three)
labels
for
end­
use
products
which
permit
mosquito
larvicide
uses.
These
will
be
the
subject
of
a
separate
sub­
group
meeting,
but
does
anyone
want
to
bring
up
any
related
issues
during
this
meeting?

Responses:
EPA
is
working
with
three
Registrants
on
their
mosquito
larvicide
labels
(
Bonide,
BVA,
and
Clark
Mosquito).
There
are
other
products
listed
in
OPPIN
Query
which
seem
to
contain
these
oils,
but
further
review
of
CSFs
and/
or
labels
suggest
that
the
oils
are
actually
inert
ingredients.

Ben
Gregg
(
SRRD):
Noted
that
for
the
larvicides,
the
EPA
works
with
Susan
Jennings
of
SRRD
and
with
the
US
Centers
for
Disease
Control
and
Prevention
(
CDC)
and
uses
a
slightly
different
process
of
review
because
of
the
unique
issues
associated
with
these
mosquito
control
products
as
a
result
of
their
unique
public
health
benefits.
