EPA Pesticide Program Updates: January 26, 2001

Malathion: Possible Label Changes from EPA Review of Malathion

• Malathion: Possible Label Changes from the EPA Review of Malathion
  
• Malathion: Lists of Information Concerning Possible Label
  Changes Based on the EPA Review of Malathion

TO: Commodity Representatives and Others Concerned about Possible Malathion Label Changes

SUBJECT: Possible Label Changes from the EPA Review of Malathion

FROM: USDA Office of Pest Management Policy (Therese Murtagh, Phil Poli, and Teung Chin)

The following information was prepared to assist those preparing public comments to EPA on possible malathion label changes.

This note describes the status of the malathion review by EPA and gives web links to the EPA assessment.

Below this memo is information about malathion uses supported for reregistration, about the uses not supported for reregistration, and about possible label changes.

If you know of others interested in possible malathion label changes, please forward this note to them.

1. What is the status of the malathion review?

On November 23, 2000, EPA held a public meeting in Washington, D.C., to discuss the malathion risk assessment. Then, on December 12, 2000, in the Federal Register (FR), EPA formally announced the release of the assessment and requested public comment on possible risk mitigation measures (label changes).

The EPA assessment and related documents are on the EPA web site.

The December 12 FR notice (Volume 65, No. 239, Pages 77624-77626) also is on the EPA web site.

2. When are public comments due to EPA?

Comments on possible malathion label changes are due to EPA by February 12. The lists below are provided to help with comment preparation.

3. Where should comments be submitted?

The December 20 FR notice gives these directions: Electronic comments can be submitted to opp-docket@epa.gov. Comments can be submitted by mail to Public Information and Records Integrity Branch, Information Resources and Service Division (7502C), Office of Pesticide Programs, EPA, 1200 Pennsylvania Ave., N.W., Washington, D.C. 20460. Comments can be delivered to that office in Room 119, Crystal Mall #2, 1921 Jefferson Davis Highway, Arlington, VA. That office is open from 8:30 am to 4 pm, Monday through Friday, excluding legal holidays. The office phone number is 703-305-5805.

Also, USDA would appreciate a copy of your comments. Please send it to tmurtagh@ars.usda.gov

4. What are the possible label changes?

USDA is providing the information below to help readers determine what label changes might be required by the EPA risk assessment. If these label changes could present production difficulties, commodity specialists and representatives should contact EPA by February 12 with information about the likely effect of these changes.

5. What label changes might be required based on the EPA chronic risk assessment?

This message and the attachment focus on the label changes (REIs, PPE, use rates) that might result from the EPA assessment of acute (short term) risk to pesticide handlers and post-application workers.

The EPA malathion risk assessment also considered chronic occupational risk but it was difficult for USDA to determine what label changes might result from the chronic assessment. USDA plans to work further with EPA to determine the possible changes and then contact affected commodities directly.

6. Who are the USDA contacts who can help with questions about the EPA review of malathion and about possible changes to the malathion label?

Therese Murtagh, 202-720-6998, tmurtagh@ars.usda.gov. Phil Poli, 202-720-1991, ppoli@ars.usda.gov Teung Chin, 301-734-8943, teung.f.chin@aphis.usda.gov

7. What lists are provided with this message?

List A. List of crops and uses supported for reregistration by malathion registrants.
List B. List of crops and uses NOT supported for reregistration.
QUESTION: Are there unsupported uses of malathion important for production? Identify these uses to EPA and explain the importance of malathion.
List C. List of possible PPE (Personal Protective Equipment) requirements for various work scenarios.
QUESTION: Are the PPE requirements workable for your commodity? If not explain to EPA.
List D. List of likely REIs (Restricted Entry Intervals) and use rates.
QUESTION: Are the REIs and use rates workable for your commodity? If not, identify the needed REIs and use rates to EPA. Explain.
List E. Possible label changes for protection of aquatic species.
QUESTION: Please comment to EPA if a buffer requirement would pose difficulties for your use of malathion.

USDA Office of Pest Management Policy

Malathion: Lists of Information Concerning Possible Label Changes Based on the EPA Review of Malathion

List A. Crops and Uses Supported for Reregistration:

Root and Tuber Vegetables, including beets (garden), carrots, chayote root, horseradish, parsnip, potatoes, radish, rutabaga, salsify, sweet potatoes, turnip and yams;

Bulb Vegetables, including garlic, leeks, onion (bulb and green), shallots;

Leafy Vegetables (except Brassica), including celery, dandelion, endive (escarole), lettuce (head and leaf), parsley, spinach and Swiss chard;

Brassica Vegetables, including broccoli, broccoli raab, Brussels sprouts, cabbage, cauliflower, collards, kale, kohlrabi and mustard greens;

Legume Vegetables, including peas (dried and succulent);

Fruiting Vegetables (except Cucurbits), including eggplant, peppers, tomatoes and tomatillo;

Cucurbit Vegetables, including chayote fruit, cantaloupe, cucumber, melon, pumpkin, squash (summer and winter) and watermelon;

Citrus Fruits, including grapefruit, kumquat, lemon, lime, orange, tangelo and tangerines;

Pome Fruits, including apples, pear and quince;

Stone Fruits, including apricots, cherries (sweet and tart), nectarines and peaches;

Berries, including blackberries, boysenberries, dewberries, raspberries, strawberries, blueberries and loganberries

Tree nuts, including chestnut, macadamia, pecans and walnuts;

Cereal Grains, including barley, corn (field, sweet and pop), oats, rice, rye, sorghum grain, wheat (spring and winter) and wild rice;

Grass Forage, Fodder, and Hay Group, including grasses;

Nongrass Animal Feeds, including alfalfa, clover, lespedeza, lupin, and vetch;

Pineapples

Cotton

Grapes

Flax

Hops

Mango

Mint

Okra

Papaya

Watercress

Turf, including turf in parks, pastures, sod farms, and golf courses.

ULV Agricultural Crops, including the aforementioned crops sprayed in ultra low volume over large land areas.

Ornamentals, including flowers, shrubs, flowering plants, nursery stock, and woody plants.

Pine Trees, including pine seed orchards, Christmas tree plantations, slash pine plantations, shrubs, shade trees, and forest trees.

Mosquitoes, including fruit flies, and other swarming flying insects sprayed/fogged over large land areas.

ULV Mosquitoes, including flies, and other swarming flying insects sprayed/fogged in ultra low volumes over large land areas.

Grape Root Dip, including the process of dipping grape roots.

Storage Grain Facility, including stored commodities such as corn, wheat, barley, oats, and rye.

Agricultural Premises, including agricultural premises outside barns, applied as a bait only.

Mushrooms, including mushrooms in mushroom houses.

List B. Crops and Uses NOT SUPPORTED for Reregistration:

QUESTION: Are there unsupported uses important for production? Identify these uses to EPA and explain the importance of malathion.

All pet uses for all formulations; All livestock uses with all formulations;

All indoor uses (except stored commodities and storage facilities); All greenhouse uses (except that mushroom use is presumed to be in mushroom houses for purposes of this assessment); All open-forest uses; All seed treatments with all formulations; All formulations for the following uses: - Almonds (including hulls and shells) - Cranberries - Filberts - Peanuts (including forage, hay, storage and storage facilities) Peavines (including hay) - Safflower seed - Soybeans (including hay and forage) - Sugar beets - Sunflower seed - Treated raisin trays. All pressurized can formulations.

Because these uses were identified to EPA as unsupported for reregistration, many of these use sites are not specifically included in EPA’s risk assessment.

List C. Possible Personal Protective Equipment (PPE) Requirements for Various Work Scenarios:

QUESTION: Are the PPE requirements workable for your commodity? If not, explain to EPA.

Note: The analysis of PPE requirements was prepared and submitted to EPA by Cheminova (the malathion registrant). This assessment concludes that almost all exposure scenarios have MOEs (Margins of Exposure) greater than 100 (the target MOE) if gloves are required as baseline PPE for malathion products.

However, there are seven exposure scenarios where MOEs (even with gloves) were found to be less than 100. For each of these exposure scenarios, the Cheminova assessment identifies methods of achieving acceptable MOEs with minimum requirements for PPE and/or engineering controls.

1. Mixing/loading liquids for aerial or chemigation application to turf. Based on Cheminova’s calculations, gloves and coveralls are required to demonstrate an MOE greater than 100 for the maximum application rate of 8.7 lb ai/A (MOE with gloves is 78; MOE with gloves and coveralls is 105). To limit the required PPE to gloves only, the maximum application rate should be reduced to 6.6 lb ai/A.

2. Mixing/loading wettable powders for groundboom application to berries. Based on Cheminova’s calculations, gloves and coveralls would be required to demonstrate an MOE greater than 100 for the maximum application rate of 2 lb ai/A to berries (MOE with gloves is 86; MOE with gloves and coveralls is 103). To limit the required PPE to gloves only, the maximum rate for groundboom applications would have to be reduced to 1.7 lb ai/A. Another option would be to use water-soluble packaging (MOE is 2,130).

3. Mixing/loading wettable powders for aerial application to berries. Based on Cheminova’s calculations, full PPE (gloves, coveralls, respirator) would not be sufficient to demonstrate an MOE greater than 100 for the maximum application rate of 2 lb ai/A to berries (MOE with gloves, coveralls, respirator is 34). To support the 2.0 lb ai/A rate, water-soluble packaging will be required (MOE = 487). If the registrant of the WP formulation wants to avoid the need for water soluble packaging, the maximum application rate for aerial applications must be reduced to 0.39 lb ai/A (for gloves only), 0.47 lb ai/A (for gloves and coveralls), or 0.68 lb ai/A (for gloves, coveralls, and a respirator). Alternatively, aerial applications to berries could be prohibited if this application method is not needed for these crops.

4. Application via airblast to citrus. Based on Cheminova’s calculations, full PPE (gloves, coveralls, respirator) would not be sufficient to demonstrate an MOE greater than 100 for airblast application to citrus at a rate of 6.25 lb ai/A (MOE with gloves, coveralls, respirator is 63). Therefore, engineering controls (enclosed cabs) will be required to support this application rate (MOE = 705). To avoid a requirement for enclosed cabs, the maximum application rate should be reduced to 3.5 lb ai/A, assuming only gloves are worn.

5. Application via airblast to stone fruits. Based on Cheminova’s calculations, gloves and coveralls would be needed for airblast applications to stone fruits at a rate of 3.75 lb ai/A (MOE = 94 with gloves; MOE = 102 with gloves and coveralls). To achieve an MOE of at least 100 for PPE consisting of gloves only, the application rate should be reduced to 3.5 lb ai/A.

6. Application via non-thermal fogger for mosquito control. Based on Cheminova’s calculations, gloves, coveralls and a respirator would be needed to achieve an MOE of at least 100 for the application of malathion using non-thermal foggers at a rate of 9.9 lb ai/gal (MOE = 89 with gloves; MOE = 97 with gloves and coveralls; MOE = 100 for gloves, coveralls and a respirator). To limit the required PPE to gloves only, the application rate should be reduced to 8.8 lb ai/gal.

7. Flagging for aerial application to turf. (See note below.) Based on Cheminova’s calculations, the use of gloves should be sufficient protection to support an application rate of 8.7 lb ai/A to turf (MOE with gloves is 98; MOE

List D. Likely Revised REIs (Restricted Entry Intervals) and Use Rates:

QUESTION: Are the REIs and use rates workable for your commodity? If not, identify the needed REIs and use rates to EPA. Explain.

Note: Transfer coefficients (TCs) used by EPA to calculate REIs are given in parentheses at the end of the entry for each commodity.]

Berries (representative crops -blueberries, strawberries) - REI = 1st day following application at a rate of 2.0 pounds active ingredient per acre. (Tc = 1500 cm2/hr for hand harvesting, pruning and training)

Field/row crop, low/medium [representative crops- alfalfa, barley, cotton, flax, forage plants, mint, peas (green and dry), rice and wheat (spring and winter)]- REI = 2nd day following application at a rate of 2.5 pounds active ingredient per acre. (Tc = 2500 cm2/hr for hand harvesting)

Field/row crop, low/medium - REI = the same day of application following application at a rate of 2.5 pounds active ingredient per acre. (Tc = 100 cm2 /hr for weeding, thinning, irrigation and scouting)

Field/row crop, tall [representative crops - corn (all types) and sorghum)] - REI = 4th day following application at a rate of 1.5 pounds active ingredient per acre. (Tc = 17,000 cm2/hr for hand harvesting and detasseling corn)

Field/row crop, tall - REI = the same day of application at a rate of 1.5 pounds active ingredient per acre. (Tc = 1000 cm2/hr for scouting, irrigating and hand weeding)

Deciduous fruit trees [representative crops - apples, apricots, cherry, figs, nectarines, peaches and pears] - REI = 3rd day following application at a rate of 3.75 pounds active ingredient per acre. (Tc = 3000 cm2/hr for hand harvesting)

Deciduous fruit trees - REI = 5th day following application at a rate of 3.75 pounds active ingredient per acre. (Tc = 3800 cm2/hr for thinning)

Trees, "fruit," evergreen [representative crops - avocado, Christmas trees, grapefruit, lemons, mangos, oranges, and papaya] - REI = 6th day following application at a rate of 6.25 pounds active ingredient per acre. (Tc = 8000 CM2 /hr for hand harvesting)

Trees, "fruit," evergreen - REI = 4 days following application at a rate of 6.25 pounds active ingredient per acre. (Tc = 3000 cm2 /hr for hand pruning)

Trees, "fruit," evergreen - REI = 3 days following application at a rate of 1.25 pounds active ingredient per acre, (Tc = 8000 cm2 /hr for hand harvesting)

Trees, "fruit," evergreen - REI = 2 days following application at a rate of pounds active ingredient per 1.25 acre. (Tc = 3000 cm2 /hr for hand pruning)

Nut trees [representative crops - macadamia nuts, pecans and walnuts) - REI = 4 days following application at a rate of 5.0 pounds active ingredient per acre. (Tc = 2500 cm2/hr for hand harvesting and thinning)

Turf/sod - REI = 2 days following application at a rate of 8.7 pounds active per acre. (Tc = 2500 cm2/hr for sod harvesting and hand weeding)

Ornamentals [representative crops - nursery crops] - REI= 5 days following application at a rate of 2.5 pounds active ingredient per acre. (Tc = 10,000 cm2 /hr for transplanting, ball/burlapping)

Root vegetables [representative crops - Beets (table, carrots onions (dry and green), potatoes, sweet potatoes and turnips)] - REI = 2 days following application at a rate of 1.56 pounds active ingredient per acre. Tc = 2500 cm2/hr for hand harvesting and thinning)

Root vegetables - REI - same day of application following application at a rate of 1.56 pounds active ingredient per acre. Tc = 500 cm2/hr for scouting and irrigating)

Cucurbit vegetables [representative crops - cantaloupe, cucumbers, squash (summer and winter), watermelon and pumpkin] - REI = 2 days following application at a rate of 1.88 pounds active ingredient per acre. Tc = 2500 cm2 /hr for hand harvesting, pruning and thinning)

Cucurbit vegetables - REI = same day of application at a rate of 1.88 pounds active ingredient per acre. Tc = 500 cm2/hr for scouting and irrigating)

Fruiting vegetables [representative crops - eggplant, peppers, tomatoes, okra] - REI = 1st day following application at a rate of 3.43 pounds active ingredient per acre. (Tc = 1000 cm2/hr for hand harvesting, tying, pruning and thinning)

Vegetable, head and stem Brassica [representative crops broccoli, Brussels sprouts, cabbage and cauliflower] - REI = 3 days following application at a rate of ingredient per acre. (Tc = 5000 cm2/hour for hand harvesting, pruning and irrigation.

Leafy vegetables [representative crops - celery, collards, kale, lettuce, parsley, spinach, mustard greens, Swiss chard and watercress] - REI = 2 days following application at a rate of 2.0 pounds active ingredient per acre. Tc = 2500 cm2 /hour for hand harvesting, pruning and thinning)

Stem/stalk vegetables [representative crops - asparagus and pineapples] - REI = same day at a rate of 1.25 pounds active ingredient per acre. (Tc = 1000 cm2/hour for hand harvesting and pruning)

Stem/stalk vegetables - REI = 2nd day following application at a rate of 5.0 pounds active ingredient per acre. (Tc = 1000 cm2/hour for hand harvesting and pruning)

Vine/trellis crops [representative crops - blackberries, blueberries, grapes and raspberries] — REI = 4th day following application at a rate of 2.0 pounds active ingredient per acre. Tc = 10,000 cm2/hour for turning table grapes)

Vine/trellis crops - REI = 3rd day following application at a rate of 2.0 pounds active ingredient per acre. Tc = 5000 cm2/hour for hand harvesting , pruning and thinning)

Vine/trellis crops - REI = 1st day following application at a rate of 2.0 pounds active ingredient per acre. (Tc = 1000 cm2/hour for tying and training)

Mushrooms - REI = 2nd day following application at a rate of 1.7 pounds active ingredient per acre. (Tc = 2500 cm2 /hr for cutting and harvesting)

Bunch/bundle crops [representative crops - hops] - REI = same day of application at a rate of 0.63 pounds active ingredient per acre. (Tc = 2000 cm2/hr for harvesting, pruning, thinning and weeding)

List E. Possible Label Changes for Protection of Aquatic Species

QUESTION: Please comment to EPA if a buffer requirement would pose difficulties for your use of malathion. [Note: no buffer length specified by EPA.]