Azinphos-methyl; Notice of Receipt of Requests to Voluntarily Cancel or to Amend to Terminate Uses of Certain Pesticide Registrations

August 8, 2006 Public Information and Records Integrity Branch Office of Pesticide Programs U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, D.C. 20460-0001 Re:Azinphos Methyl Proposed Reevaluation Decision, EPA Docket No. EPA-HQ-OPP-2005-0061 American Farm Bureau Federation (AFBF) submits these comments regarding the proposed reevaluation decision for the pesticide, Azinphos Methyl (AZM). AFBF represents hundreds of thousands of farmers and ranchers who produce agricultural products all across the United States. Maintaining the use of safe, effective, affordable pest control products is a priority for our farming members. AFBF strongly urges EPA to fairly and thoroughly reevaluate and allow the continued use of AZM for currently labeled uses. We support and endorse the comments and supplemental information, including analysis of EPA?s risk assessment, submitted to the Agency from the pesticide?s registrant and manufacturers, as well as other groups representing agricultural producers and state farming organizations that support the continued use of AZM. Based on the detailed comments submitted by the allied organizations identified above, AFBF emphasizes the following concerns regarding AZM?s reevaluation: 1.We believe that EPA?s benefits assessment is unbalanced. It overestimates the efficacy of existing AZM alternatives given users field experience. EPA has relied only on positive reports from professional research entomologists whose skills and training in pest control are substantially greater than the average. When professional entomologists have expressed reservations regarding the ability of growers to implement these programs successfully they appear to be dismissed. For many of the currently labeled uses, few if any practical alternatives exist. 2.We believe AZM?s ecological risk assessment is unreasonably conservative. Relevant portions of the ecological data and modeling are unrealistic and significantly overestimate risk. Further, we are concerned that some relevant, ?lower risk? incident data may not have fully considered. ?Where ecological risk concerns remain, we believe that EPA should more thoroughly explore potential risk mitigation measures that may allow for the continued use of AZM. 3.One of AZM?s primary target pests, the codling moth, is a major quarantine concern for U.S. producers exporting fresh products. Detection of a single, live codling moth larva can prompt a foreign market to close their doors to U.S. products. EPA must more fully consider this consequence of losing AZM and the lack of practical alternatives for those on the export market. 4.We do not believe the administrative process followed for AZM?s reassessment provided for maximum grower/production input and discussion on this chemical. 5.We urge EPA not to phase out the use of AZM on the current proposed schedule. Rather, we believe EPA should conduct ?near future? review of the potential risks and benefits. This would allow registrants the opportunity to conduct additional studies that would help remove uncertainty regarding the risk assessments. AFBF appreciates the opportunity to comment on this vital agricultural crop protection tool and thank you for your consideration of our comments and those we endorse from allied organizations. We look forward to ongoing engagement with the agency on this product ? please contact me in the meantime if you have questions or concerns about our comments. Sincerely, Rebeckah (Freeman) Adcock Director, Congressional Relations - Crop Protections/Chemicals American Farm Bureau Federation 600 Maryland Avenue SW, Suite 1000W Washington DC 22024 202-406-3663 rebeckah@fb.org

Filed on regulations.gov — full text not in the inline record.