Thiabendazole and Salts Registration Review

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

July 12, 2019 Dana Friedman Pesticide Re-Evaluation Division (7508P) Office of Pesticide Programs Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460-0001 RE: Thiabendazole Registration Review; Draft Human Health and/or Ecological Risk Assessments for Several Pesticides, Docket Identification Number EPA-HQ-OPP-2017-0720; FRL-9993-04 Dear Ms. Friedman: The Northwest Horticultural Council (NHC) represents the growers, packers, and shippers of apples, pears, and cherries from Washington, Oregon, and Idaho. Approximately 67 percent of the fresh apples, 88 percent of the fresh pears, and 81 percent of the fresh cherries produced in the United States are grown in the Pacific Northwest. We write today to provide comment regarding the Draft Human Health Assessment and Registration Review of Thiabendazole (TBZ). TBZ is a fungicide used to control postharvest decay and rot in apples and pears. It is applied postharvest, primarily in liquid formulations via drenching as the bins of fruit arrive at a packing or cold storage facility immediately following harvest. Standard treatment is 30 bins per 100 gallons of drench solution, with tank sizes typically ranging from 2,000 gallons to 3,000 gallons. TBZ may also be applied via fogging once fruit bins are unloaded into a cold storage room, or as wettable powder applied on the packing line. It is routine to use different fungicide chemistries on fruit as it is coming in from the field and during the packing process to prevent resistance development, so maintaining access to these different chemistries is critical. The NHC supports the proposal included in the Environmental Protection Agencys (EPA) Draft Human Health Risk Assessment to increase the tolerance for TBZ from 5 parts per million (ppm) to 11 ppm for apples and pears. The risk assessment also notes that personal protection equipment (specifically the use of a PF10 respirator) is necessary to address concerns regarding inhalation exposure for handlers when mixing wettable powders for use of TBZ in postharvest automated systems. The NHC encourages EPA to consult with industry in developing any additional mitigation measures to ensure they are workable while meeting the human health protection objective. If any additional information is needed on how TBZ is used on apples and pears in the Pacific Northwest, or if the NHC can provide feedback on the impact of any proposed mitigation measures EPA is considering, please do not hesitate to contact us. Thank you for your consideration of these comments. Sincerely, NORTHWEST HORTICULTURAL COUNCIL Kate Tynan Senior Vice President

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