UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C., 20460
                                   OFFICE OF
                              CHEMICAL SAFETY AND
                             POLLUTION PREVENTION
                                   OFFICE OF
                              CHEMICAL SAFETY AND
                             POLLUTION PREVENTION


                                                              PC Code: 288201  
                                                             DP Barcode: 416873
                                                                  June 30, 2014

MEMORANDUM

Subject:	Drinking water assessment for the new use of Pyrimethanil as a post-harvest treatment of pomegranates.
 
To: 		Hope Johnson, Product Manager
		Tamue Gibson, Reviewer
		Fungicide Branch
		Registration Division (7505P)

		Charles Smith, Branch Chief
      Jennifer R. Tyler, Chemist
      Risk Assessment Branch 1
		Health Effects Division (7509C)
	
From:		James K. Wolf, Ph.D., Environmental Scientist
      Environmental Risk Branch 3
		Environmental Fate and Effects Division (7507P)

Through: 	Dana S. Spatz, Branch Chief
	     	Environmental Risk Branch 3
	     	Environmental Fate and Effects Division (7507P)


Janssen PMP, a Division of Janssen Pharmaceutica NV, has requested a modification to add post-harvest dip treatment of pomegranates to the PENBOTEC[(R)] 400 SC label (EPA Reg. No. 43813-32). The active ingredient (a.i.) is pyrimethanil (288201). The post-harvest dip treatment of citrus fruits, pome fruits, and some stone fruits is currently included on the PENBOTEC label (EPA Reg. No 43813-32).  The proposed use rate is 32 fl oz of product per 100 gallons, which results in a treatment concentration of 1,000 ppm (a.i.). Currently registered dip treatment concentrations range between 500 and 1,000 ppm (a.i.).

Based on the information provided, EFED considers the proposed post-harvest dip use of pyrimethanil as an indoor use that would pose minimal exposure to the environment, provided that release of the chemical and contaminated water are controlled. Therefore, an updated drinking water assessment is not needed for this new use. 

Although the petition does not specify how spent treatment solution will be disposed, the product label states:

      Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA.
