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1 PR NOTICE -- Improving Labels for Adult Mosquito Control Products Jim Roelofs Office of Pesticide Programs US EPA
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2 Origin(s) of Projects SFIREG Issue Paper - 1999 WNV conference in Region 2 - 2001 Ad hoc EPA-State group developed initial recommendations PPDC (April 03) advised EPA to do PRN
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3 Recommendations at April ’03 PPDC Trained applicators, or Restricted Use Separate directions for mosquito control Qualify “terrestrial use” on mixed labels Allow application “over water” if needed to target mosquitoes Make hazard language specific as possible Consult with State lead agency Improve calibration instructions
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4 Current Draft Recommendations Retains the original 7, but merged some of them Adds 2 new ones concerning -- modified bee precaution language (#6); and specify timing and frequency (#7)
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5 Rec. #1 – Trained personnel Broad support for general concept Different views on how to do it Proposal language tries to accommodate various forms of existing training
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6 Rec. #2 -- Separate mosquito labels Mosquito-only labels easiest to deal with for users and regulators Avoid confusion over “terrestrial use” statement
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7 Rec. #3 Improve Hazard Statements Make application over water allowable Make aquatic species hazards more specific (if data support). Raises NPDES issue
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8 Rec. #4 Consult with State Lead Agency We think SLA is most reliable source of info about possible state requirements. Some commenters doubted value, thought it would be burden We still think SLA is best, but make it advisory only.
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9 Rec. #5 Appropriate Calibration Instructions Labels are all over the board in this area. We try to present a consistent approach; registrant identify droplet spectrum; user refers to equipment maker’s instructions to achieve it.
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10 Rec. #6 – Modify bee precaution “Hurricane Floyd” raised issue Current language has no exceptions Adds public health need as an exception – issue is who determines?
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11 Rec. #7 -- Frequency and timing “Repeat as needed” appears on most m. c. labels Problems – (1) does not comply with label regulations (specify timing and frequency); (2) users, regulators and public may perceive “as needed” differently; (3) does not help EPA do risk assessment However – public health protection may require unpredictable retreatments.
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12 Next Steps Send comments to docket – e-mail or hard copy -- (OPP2004-0018) Closes July 27 Questions? roelofs.jim@epa.gov
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