UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

                                                                        
                                                                        
                    OFFICE OF

             CHEMICAL SAFETY AND 

POLLUTION PREVENTION

					

MEMORANDUM:

Date:		March 29, 2015

Subject:	RD Response to Comments on Public Comments Submitted on the
Federal Register Notice of Receipt for the Clothianidin Experimental Use
Permit (59639-EUP-RI)

The Notice of Receipt of an application for a clothianidin experiment
use permit (59639-EUP-RI) was open for a 30 day public comment period in
the docket EPA-HQ-OPP-2014-0667 at regulations.gov.  The purpose of this
document is to address public comments submitted by the Pollinator
Stewardship Council (PSC) and the Center for Food Safety (CFS) that were
not answered by the Environmental Fate and Effects Division (EFED).

CFS Comment:  CFS comments that granting the EUP would cause severe and
unreasonable adverse effects on the environment, including but not
limited to unassessed harm to honey bees and other beneficial
invertebrates, as well as to birds that are directly and indirectly
harmed by the corn plantings. 

PSC Comment:  Clothianidin is documented as causing both acute and
chronic harm to honey bees when used on corn.  PSC encouraged the EPA to
maintain its position against approving experimental use permits until
pollinator risk assessments are complete.  The PSC had concerns
regarding the solubility of clothianidin in water which were addressed
by EFED’s Response to Comments.  

EPA Response:  The proposed EUP is an in-furrow soil treatment for
clothianidin treated corn seed and will only be applied to a combined
total of 500 acres in three states: Minnesota, South Dakota, and
Wisconsin.  According to the proposed use rates on the EUP label, the
maximum rate of clothianidin per corn seed is 0.5 mg active ingredient
(a.i.)/seed which is lower than the currently labeled maximum rate of
1.25 mg a.i./seed.  Therefore, the exposure to clothianidin residues
from abraded dust is likely to be lower than those from the currently
registered use on corn seed.  The in-furrow application of the EUP will
be conducted at low boom heights which are unlikely to result in
significant spray drift.  EPA considers that acute exposures to honey
bees foraging in or near the field at the time of application are likely
to be similar or lower than those from the currently registered use on
corn.  

The registrant will collect pollen samples from the EUP treated fields
to determine if this method of application is effective against corn
rootworm and to determine if the systemic uptake of the clothianidin has
increased.  The registrant has also committed to develop and carryout a
protocol to record native pollinators’ activity on corn tassels and on
flowers in field margins and natural habitats adjacent to the treated
fields.

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