Copper Cases; Coppers Reregistration Eligibility Decision, Notice of Availability

March 23, 2006 Public Information and Records Integrity Branch (PIRIB) Information Resources and Services Division (7502C) Office of Pesticide Programs (OPP), Environmental Protection Agency Room 119, Crystal Mall #2 1801 S. Bell St. Arlington, VA 22202 RE:Comments on the Risk Assessments for Copper Containing Crop Protection Chemicals Docket Control Number OPP-2005-0558 To Whom It May Concern: This communiqu? is being provided in response to the U.S. EPA?s announcement of the availability of the copper containing pesticide?s Preliminary Risk Assessments and subsequent opening of the comment period, as outlined in the January 25, 2006 Federal Register Notice. The Florida Fruit and Vegetable Association (FFVA) is a private, non-profit agricultural cooperative whose mission is to enhance the business and competitive environment for producing fruits, vegetables and other crops by managing issues and providing collective services for our members. Florida Citrus Mutual (FCM) is a voluntary citrus grower?s trade association representing more than 10,000 citrus producers. FFVA and FCM are submitting these comments on behalf of our citrus, vegetable and tropical fruit production industry members. We appreciate and welcome the opportunity to supply the Agency with input on this important topic. The comments contained herein are intended to be constructive and assist the Agency in refining the proposed risk assessments for the coppers. Florida?s citrus, vegetable and tropical fruit industries have had an extended history with copper and the copper regulatory dossier. The copper registration maintenance and reregistration processes thus far have been both lengthy and exhaustive. The coppers as a whole are used to manage bacterial and fungal diseases of fruit, vegetable, nut and field crops. Some of the diseases that are controlled by this fungicide include mildews, leaf spots, leaf specks, citrus canker, blights and scabs. It is used as a protective fungicide for foliar application and seed treatment. It is also used as an algaecide, a herbicide in irrigation and municipal water treatment systems and as a molluscicide used to repel and kill slugs and snails. Copper is a naturally-occurring inorganic salt and an essential trace element in plant and animal nutrition. P.O. Box 948153, Maitland, FL 32794-8153 ? 800 Trafalgar Court, Suite 200, Maitland, FL 32751 321.214.5200 ? fax 321.214.0210 ? www.ffva.com PRIB Docket Control Number OPP-2005-0558 FFVA/FCM, March 23, 2006 Page 2 of 8 The coppers are fungicidal/bactericidal products that have been used extensively for pest management purposes commercially in crops such as citrus, cucurbit crops, fruiting vegetable crops, tropical fruits, Cole crops, legume vegetables, leafy vegetables and melons/watermelons for many, many decades. The coppers are one of the original products ever used for disease management purposes, with a documented history dating back to the late 1880s. These products are a popular form of fungicidal/bacterial protection around the world because of their broad- spectrums of control, lack of overriding resistance problems, effectiveness, and favorable environmental and economic cost profiles associated with their use. Clearly, this level of use and corresponding historic safety record in the state, nationally and internationally is an indication of the value of these products to agriculture and our nation?s food supply. Decisions concerning the coppers and their future will therefore have a profound effect on: 1) agriculture; 2) other small business-related economics; 3) resistance management and integrated pest management strategies; and, 4) the country?s agricultural commodity economic competitiveness on a worldwide basis. The coppers are naturally occurring products, which are not only an essential element for the homeostasis of life but also an element that is efficiently regulated biologically in/by the human system.…