UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

				

Memorandum								February 15, 2007

SUBJECT:	Chlorflurenol: Response to comments from Maui Pineapple
Company, Ltd.

FROM:	Shanna Recore, Industrial Hygienist

		Reregistration Branch II

Health Effects Division (7509P)

THROUGH:	Alan Nielsen, Branch Senior Scientist

		Reregistration Action Branch II

Health Effects Division (7509P)

			

TO:		Tracy Perry

		Special Review and Reregistration Division (7508P)

	

PC Code:	098801

DP Barcode:	336736

	Attached are HED’s response to comments from the Maui Pineapple
Company, Ltd .

Comment from Maui Pineapple Company, Ltd:  Maintain CF-125
(chlorflurenol) is used for rapid production of pineapple planting
material.  It has been used in Hawaii safely without any incidents since
the early 1980’s.  Chlorflurenol is applied at 1.0 lb. active
ingredient in 250 gallons of water per acre using foliar groundboom
application methods.  A second application may be applied 4 to 7 days
after the first application to ensure maximum planting material
production. . . . . Agricultural workers are well protected by the
Agricultural Worker Protection Standards.  Mixers, handlers, and
applicators use rubber boots, long pants, short-sleeve shirts, tyvek
coveralls, eye protection, and half face respirators.  Applicators apply
chlorflurenol from enclosed cabs increasing worker safety through
engineering controls.  The current restricted entry interval of 12 hours
can be increased to 5 days to further mitigate risks that may be
associated with occupational exposure.  Personal protective equipment
requirements and restricted entry intervals can be changed on product
labels to decrease calculated occupational risks to below levels of
concern. . . .  Pineapple will suffer severe economic hardships if
chlorflurenol is voluntarily cancelled.

HED Response:  The occupational exposure and risk assessment indicates
that handler exposures to chlorflurenol related to applications to
pineapple are not a concern for systemic toxicity provided all handlers
(i.e., mixers, loaders, applicators) wear long-sleeve shirts, long
pants, shoes, socks, and, when mixing and loading, chemical-resistant
gloves.  The more stringent personal protective equipment requirements
for handlers on the Maintain CF-125 label are the default requirements
in the Worker Protection Standard for Agricultural Pesticides (WPS),
which are triggered by the corrosive nature of the product.  Increasing
personal protective equipment requirements for handlers is not proposed
for chlorflurenol and is not necessary to mitigate handler risk.  

Similarly, the occupational exposure and risk assessment indicates that
postapplication worker exposures to chlorflurenol related to
applications to pineapple are not a concern for systemic toxicity
provided a 12-hour restricted entry interval is observed.  The 48-hour
restricted entry interval and the more stringent personal protective
equipment requirements for early entry workers on the Maintain CF-125
label are the default requirements in the Worker Protection Standard for
Agricultural Pesticides (WPS), which are triggered by the corrosive
nature of one or more of the active ingredients in the product. 
Lengthening the restricted entry interval or increasing personal
protective equipment requirements for early entry workers is not
proposed for chlorflurenol and is not necessary to mitigate
postapplication worker risk.  

