Minutes: FOR REGISTRANT/USER MEETING WITH EPA STAFF ON PROPOSED INTERIM REGISTRATION REVIEW DECISION (PID) FOR THE BORATES
                                       

Date/Time:  Thursday, November 2, 2017 from 2-3PM

Attendees: (Sign in sheet below)
Greg Baumann, Nisus Corporation (BTTF Member)
Andrew Bray, Jim Fredericks, National Pest Management Association (NPMA)
Teri Muchow, Lonza, Inc.
Eliot Harrison, Borate Testing Task Force (BTTF)

BTTF and NPMA called for this meeting to discuss registrant/user comments on the PID.  

 Main topics: 
       Respirator requirements: for ORE assessment in residential, commercial, and industrial buildings- calculation of boric acid assumed and subsequent respirator requirements.
       Treated Wood: Requirement for treated wood to be covered in case of rain.
                   
 Documents discussed:
 NPMA Survey Data, Results from Survey, BTTF comments on the Boric Acid Sodium Salts PID
                  
 Presentation: 
 The BTTF and NPMA representatives presented alternative mitigation measures to the proposed respirator requirements listed in the PID for various occupational handler scenarios in the DRA, which included: use limitations for residential/commercial/industrial uses and results of their survey indicating a lower amount of boric acid used.
 Representative from Lonza Inc. discussed issues with the label requirement to cover wood treated with boric acid in the event of rain.  Lonza claimed this requirement is not on other products and would discourage use of boric acid products.
         
 Discussion:
Respirators:
 Agency representatives described process for calculating the amount of boric acid used in residential, commercial and industrial settings, which is based on current labels.  In the case of boric acid, which has around 250 products, many of the labels were first registered over 20 years ago and have never been updated.  As a result, many are unclear as to the amount required to treat pests and do not indicate the appropriate application method to use or limit the application type (eg. the potential for broadcast use, which uses a large quantity of product as compared to a spot treatment or crack and crevice).  In addition, boric acid and its sodium salts are used for a variety of pests including being used as a fungicide, herbicide, algicide, insecticide, miticide, among others.  In the event that a label is unclear as to the amount or application method to use, then assumptions must be made in the assessment calculation, which may result in a more conservative assessment.  
         
 Possibilities to address concerns over respirators could be handled by: 
  Collect information on pest control operators (PCO) that is required to be submitted to that States. This information may be able to inform EPA assessments with regards to the amount of product used in industrial, commercial and residential use sites. Since not all states require reporting and not all companies collect information electronically, a survey might have to be again sent out by NPMA. 
  Have label language specify how much product and which application methods to use, which could limit the amount of boric acid used for these scenarios to reflect actual amounts.
   Wood Treatment:
 Biological and Economic Evaluation Division (BEAD) will work with Antimicrobial Division (AD) to confirm current uses.  Another meeting on this issue will be arranged with Lonza and BTTF.
               
 Next Steps:
 NPMA will consider polling members to ultimately submit to the Agency raw data which may or may not be required by states; however, regardless if required, PCOs do keep service tickets and NPMA will evaluate the possibility of obtaining the data to share with the Agency. NPMA will get back to the Agency with suggestions by November 10.  
      The survey may include the following type of information:
 Applicator identifiers, dates, amounts, dilution, use sites, etc... 	
            TIME FRAME: the week of 11-6-17 
 HED will review use patterns and confirm applicability.  
 Interim Decision for Boric Acid and Sodium Salts is scheduled for publication March 2018.

         
