Malathion Use Pattern Requirements for Hawaii
Date: July 19, 2006
I received your phone message reply to my phone call of this morning (about 8:45 a.m., Hawai'i time, Tuesday, July 18). Thank you.
I have attached a letter which includes the highlights of our concerns about Hawaii's malathion use patterns. These are the concerns which remain after examining EPA's proposed final decisions.
The letter is not intended to substitute for the documentation sent first on May 25 and again on July 17. Instead, I hope it facilitates understanding of our input and serves as a navigation guide to our documentation, especially to the rather lengthy tables, which EPA has seen fit to re-organize. You probably have a lot of material to digest in a short period of time and I want to make every effort to effectively communicate the needs of Hawaii's agriculture stakeholders.
If you have any questions or concerns, please contact either Mike Kawate (email@example.com, 808/956-6008) or me.
On 18 Jul 2006 at 15:11, Paul Whatling, Washington wrote:
Thank you for your response! I had noticed that EPA did not included your comments in its table and sent an e-mail to Tom Moriarity at EPA informing him of this. EPA did not respond, but it has asked to meet with us (Cheminova) on Thursday afternoon (East Coast Time) of this week to discuss EPA's final proposed use patterns, so if you can get back with me before that, it would be much appreciated.
From: Cathy Tarutani [mailto:firstname.lastname@example.org]
Sent: Tuesday, July 18, 2006 12:01 AM
To: Paul Whatling, Washington; Teung.F.Chin@aphis.usda.gov
Cc: Rick Melnicoe; Mike
Subject: Re: FW: tables 1 and 2 for malathion proposed final rates
Dear Mr. Whatling and Teung,
Our answer to question #2 in your message, below, "Does it appear that EPA has included your comments in its tables?" is: Absolutely not.
On May 25, 2006, I sent responses to two sets of questions regarding malathion reregistration and risk mitigation to Teung and Tom Moriarty, EPA-SRRD.
I have attached the files which were sent to Teung and Mr. Moriarty. There is one correction in the cucumber section of the "response"file. In "table 1" there are corrections to the "Pasture and Rangeland" and "Guava" sections. Our stakeholders' proposed values (where different from EPA's then-proposed valued) are still indicated in red and, additionally, I have highlighted the cells which contain the crops of concern and our growers' values for them in yellow. The cover letters and the rest of the files are identical to those which were transmitted on May 25.
As you will see, our answer to your question #3, below, "Do you agree that EPA's final proposed use patterns will not hurt your (growers') ability to manage insect pests on the crops of interest to (them)?" is also: Absolutely not.
I will be contacting the pineapple growers about the acceptability of the proposed final value for the REI for pineapple.
Question: when do you need this (or any other) additional information?
If you any questions or concerns about the attached information, or if you require additional information, please contact either Mike Kawate (email@example.com, 808/956-6008) or me.
On 14 Jul 2006 at 19:31, Paul Whatling, Washington wrote:
Some of you were inadvertently left off of the list of recipients to the e-mail below. My apologies.
From: Paul Whatling, Washington
Sent: Friday, July 14, 2006 12:36 PM
To: Jane Thomas; 'firstname.lastname@example.org'; 'email@example.com'; 'firstname.lastname@example.org'; 'et al
Subject: FW: tables 1 and 2 for malathion proposed final rates
Dear Friends and Collegues:
Many thanks to all of you that have provided me or Teung Chin (USDA) with information on the need for malathion on various crops that are important to you. We very much appreciate your efforts to ensure the availability of the tools needed by the farmers of America to grow our food and to provide well for their families. Teung and I have forwarded to EPA all of the comments received to date. If you have not yet provided us with your comments, we would very much like to hear from you.
At this point in time, EPA has completed its review of all of the comments received to date. EPA has prepared the attached tables that summarize these comments and gives EPA's proposed final decisions concerning the malathion use patterns to be allowed for registration. Unless we can challenge EPA proposed use patterns, these will likely become EPA's final decision to be published in the interim-reregistration eligibility decision (iRED) document later this summer.
We are asking that you take a few moments to review these tables and then let me and/or Teung know the following:
1. Are there any crops missing from the tables that are of interest to you?
2. Does it appear that EPA has included your comments in its tables? If so, has EPA accurately summarized your comments in its tables?
3. Do you agree that EPA's final proposed use patterns will not hurt your ability to manage insect pests on the crops of interest to you. If EPA's proposed use patterns will be problematic, please let us know what growers in your area need and we will fight for it.
In addition to the information provided in the tables, EPA is asking for more information on the following:
For the emulsifiable concentrate (EC), wettable powder (WP), and dust formulations:
1) EPA is proposing to cancel aerial applications for all berry crops. Please let us know if this will be acceptable to these growers.
2) EPA needs to know the pre-harvest interval needed for celery and for dates.
3) EPA needs information on how malathion is used on: "grain crops", "grain elevators", and "stored grains" as it could not locate much information on these sites.
4) EPA needs additional information on application rate needed for nectarine (is it okay to set the highest single application rate at 3.0 lbs ai/A as EPA proposed?)
For the ultra-low volume (ULV) and ready to use (RTU) formulations:
1) EPA needs more information on desired re-treatment interval for the uses on pasture and rangeland.
Please note that for those crops that you feel EPA's proposed use patterns will not be sufficient, we intend to continue our fight with EPA to defend your needs. Again, we appreciate your efforts to defend the existing malathion uses.
If you have any questions about this e-mail, or if you want to discuss anything about EPA's risk assessments for malathion, please feel free to give me a call.
Senior Manager, Regulatory Science
1620 Eye Street NW, Suite 615
Washington, DC 20006