Comments in Response to Risk Mitigation Options for EBDC Fungicide Use on Papayas in Hawaii

Date: June 23, 2005

To: Rick Melnicoe
WIPMC Director

From: Cathy Tarutani
American-affiliated Pacific Islands (API) Comment Coordinator
University of Hawaii
Honolulu, HI 96822

Rick,

The forwarded message below is apparently an exchange that occurred subsequent to a reply I sent to Dr. Michell (and cc'd you) on June 8.

Cathy

Cathy Tarutani
Phone: (808) 956-2004
Department of Plant and Environmental Protection Sciences
3190 Maile Way, St John 307
University of Hawaii
Honolulu, HI 96822

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Date: June 20, 2005

To: Richard Michell
USEPA

From: Wayne Nishijima
University of Hawaii

CC: Cathy Tarutani
M. Nishina
University of Hawaii

Subject: Papaya EBDC

Rich,

I'm not sure how to answer your question but any increase in the REI from 24 hours will affect growers. The longer it is increased the more growers it will affect. My question is how much is the hazard is reduced to the worker by extending the REI from, say 24 hrs to 48 hrs.

My understanding is that the exposure hazard of the EBDC fungicides is very minimal once the spray dries. If increasing the REI is necessary to maintain registration, then I can see the growers being able to live with a 48 hr REI. EBDC fungicides are applied once every 2 to 4 weeks depending on weather. Harvesting is done weekly so that is the field activity that would be affected the most. Harvesting is the field activity that is done the most frequently (weekly). Field activities and estimated frequency are:

• harvesting: weekly; some may harvest twice a week during summer
• fertilizing: once every 30 to 45 days
• weed control (herbicide application): once ever 2 to 3 months
• trim leaves & thin fruits: once every 4 to 6 months

The fertilizing, weed control and trim leaves & fruit thinning operations will not be affected much since those activities are not done every week. However, the harvesting will definitely be affected, especially during the summer months when fruits tend to ripen on the tree faster. I hope this answers your questions. If not let me know and I can try to answer them.

Wayne Nishijima
County Administrator, Island of Hawaii
University of Hawaii at Manoa
Komohana Ag Complex
875 Komohana St.
Hilo, HI 96720
Phone: (808) 981-5199
Fax: ( 808) 981-5211

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Date: June 20, 2005

From: Richard Michell, Ph.D.
USEPA

To: Wayne Nishijima
University of Hawaii

Dear Dr. Nishijima:

I noticed your response to the EBDC docket earlier this year. I am working with the risk assessors on risk mitigation options for EBDC fungicide use on papayas. They are interested in knowing if the REI could be increased and what the maximum acceptable REI could be on papayas.

What can you suggest and what worker activities typically follow EBDC applications?

Thanks,
Richard Michell, Ph.D.
Plant Pathologist-Nematologist
BEAD, USEPA
Phone: (703) 308-8119
Fax: (703) 308-8091