Sulfometuron Methyl RED

Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460-0001 RE: Docket # EPA-HQ-OPP-2008-0129 The attached letter provides the comments of the American Forest & Paper Association (AF&PA) on the Acrolein, d-Phenothrin, and Sulfometuron Methyl, Reregistration Eligibility Decision; Notice of Availability, 73 Fed. Reg. 66893 (November 12, 2008). In summary, 1. We recommend that the RED either specify label language that recognizes forestry BMPs for streamside management zones as adequate buffers or as "equivalent risk reduction" that satisfies all FIFRA requirements. 2. For overall safety and efficiency, we recommend the label require that spray height be the minimum level that meets safety standards and drift prevention objectives. Any reference to 10 feet should be limited to level areas of relatively uniform canopy height.