UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460      

	OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION                                                    
                                   

	

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date:		8/24/11

SUBJECT:	Abamectin.  Amendment to Include Cowpea in the Tolerance on Dry
Beans.

 

PC Code:  122804	DP Barcode:  D393226 

Decision No.: 436528	Registration Nos.: 100-1351, 100-898, 100-1154

Petition No.: 0E7738 	Regulatory Action: Section 3 Registration

Risk Assessment Type: None	Case No.: None

TXR No.: None	CAS No.: 71751-41-2

MRID No.: None	40 CFR: 180.449

		              									Ver.Apr.08

	          	

FROM:	Nancy Dodd, Chemist

		Risk Assessment Branch III (RAB3)

		Health Effects Division (HED) (7509P) 	  SEQ CHAPTER \h \r 1 

		

THROUGH:	Leung Cheng, Senior Chemist

		RAB3/HED (7509P)

TO:		Barbara Madden, RM#5

		Registration Division (7505P)		  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h
\r 1 

		

I.	CONCLUSIONS

HED, in consultation with the ChemSAC, has determined that the tolerance
for abamectin on dry beans should be on "bean, dry, seed" as originally
proposed by the petitioner.  Cowpea does not need to be excluded from
the tolerance.  A label restriction should be added such as the
following: "To be grown for bean, dry seed only.  Do not feed or harvest
cowpea forage or hay.” 

II.	ACTION REQUESTED

The Interregional Research Project No. 4 (IR-4) proposed a tolerance for
abamectin on “bean, dry, seed.”  HED recommended for a tolerance on
“bean, dry, seed, except cowpea” in DP#380795 (N. Dodd, 5/18/11). 
In review of the Federal Register Notice for the proposed use, HED’s
recommended exclusion of cowpea from the tolerance was questioned.  The
issue was referred to the ChemSAC for review on 8/24/11. 

III.	BACKGROUND

HED intended to exclude cowpea from the dry bean tolerance since Table I
Feedstuffs (June 2008) lists cowpea forage and hay as feeds for dairy
cattle at 20% of the diet.  Cowpea forage and hay are not designated as
under grower control in Table I.  

As part of the review of the FR notice, HED was asked to reconsider
exclusion of cowpea for the following reasons:

1) To harvest dry bean, forage and hay cannot be harvested.

2) The crop is specifically grown for hay or forage in some areas.

3) Forage varieties are distinct from dry seed varieties since they are
developed for high dry seed yields.

4)  If cowpea is excluded, HED should exclude others.  Southern pea,
blackeye pea, cowpea, and crowder are all the same crop (Vigna
unguiculata) (Monograph 450, Food and Feed Crops).  

IV.	RESULTS/DISCUSSION

HED has determined, on advice from the ChemSAC, to include cowpea in the
tolerance for dry beans.  A label restriction to restrict use of cowpea
forage and hay should be added.  

Page   PAGE  1  of   NUMPAGES  2 

