Registration Review: Diphenylamine

The Northwest Horticultural Council (NHC) is a voluntary, nonprofit association that represents the growers, packers, and shippers of apples, pears, and cherries from Washington, Oregon, and Idaho. The NHC growers, packers, and shippers account for 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. In December of 2018, the NHC submitted comments to the Environmental Protection Agency (EPA) to express our concerns on the proposal put forth in the Diphenylamine Proposed Interim Registration Review Decision to revoke the existing tolerance for residues of diphenylamine on pears. Maintaining the pear tolerance is critically important, however, I write today to discuss the importance of this chemical for our apple growers, packers, and shippers. Diphenylamine is commonly used and is essential in our industrys post harvest control of scald on apples. Currently, diphenylamine is the only registered pesticide available for post harvest treatment on apples that provides effective control of scald. Other chemicals have been tested and although they reduce scald, they have not been as effective as diphenylamine. Storage scald is one of the most economically serious post harvest disorders of apples so it is vital to the industry that it be controlled. Therefore it is vital that the registration of diphenylamine on apples be maintained. Scald is the diffuse browning of the skin of apples that appears after storage. Apples can be in storage and maintain their top-eating quality for up to 10 months before reaching the consumer. Storage of apples is a standard industry practice that allows for a constant supply of apples to the U.S. consumer throughout the year. Scald most often appears after fruit have been removed from storage but normally does not appear on fruit while in storage. Signs of scald will appear within a few days after coming out of storage so it is common for apples to look fine leaving the packinghouse, but develop serious scald symptoms by the time they reach the consumer. The NHC believes that growers should be consulted during EPAs mitigation development process to ensure any proposed mitigations are realistic and sensible, while allowing them access to diphenylamine. If any additional information is needed on how diphenylamine is used on apples 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 considering these comments. Sincerely, NORTHWEST HORTICULTURAL COUNCIL Mark Powers President

The existing pear tolerance is very important to the pear industry in the Pacific Northwest and its removal will likely have an adverse impact if EPA goes forward with the proposal in the Diphenylamine Proposed Interim Registration Review Decision to delete the tolerance for diphenylamine on pears.

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