Malathion Use on Citrus in California
Date: April 24, 2006
To: Kari
Mavian, Tom Moriarty, ccqc1946@pacbell.net, Rick
Melnicoe, Teung
Chin
From: Beth Grafton-Cardwell
Kearney Agricultural Center
Subject: Malathion Reregistration Update
Attachment
Kari:
I have attached a summary statement as to the reasons why .75 lb ai/acre malathion is an unacceptable change to the label for citrus pests. The primary reason is that rates below 7.5 lb ai/acre do not control scale insect pests. Thus the label change would render the insecticide useless for several key pests of citrus (cottony cushion scale, black scale, citricola scale). Alternative insecticides are available, but they are primarily organophosphates and carbamates and they have their own issues. The increase of the REI to 5 days would limit use of the product at harvest time, however growers could manage the pests with this limitation. Citrus growers do not need multiple applications of malathion and so if a reduction is needed, I would change the label to once per season.
Beth Grafton-Cardwell
IPM Specialist and Research Entomologist
Kearney Ag Center
9240 S. Riverbend Ave.
Parlier, CA 93648
office: 559-646-6591
fax: 559-646-6593
From: Kari E. Mavian [mailto:KEM.US@cheminova.com]
Sent: Monday, April 24, 2006 12:59 PM
To: Grafton-Cardwell, Beth; ccqc1946@pacbell.net
Subject: Malathion Reregistration Update
Hi Wally and Beth,
I am writing this time concerning the reregistration of malathion. As you may be aware, the Environmental Protection Agency (EPA) is currently reviewing the use patterns for malathion as part of the compound’s reregistration process. The EPA is now inviting comments from stakeholders with regard to some changes they have proposed for emulsifiable concentrate (EC), wettable powder (WP) and dust formulations of malathion.
We are writing to ask if you would once again assist in this review procedure. We have attached a copy of the most recent request for information issued by the EPA. EPA especially needs to know if the application rates, number of applications, and REI’s are appropriate, and if not, the specific reasons why. Unfortunately the EPA has requested that input is received this week, so fairly urgent action is needed.
You will note that we have highlighted certain cells in the attached spreadsheets. These cells represent what we feel are significant changes from current labeled use patterns and require particular scrutiny. If any of these changes severely limit the commercial viability of malathion on citrus, the EPA needs to be informed.
We recommend that you send your comments to the following three people:
Cheminova contact: Paul Whatling |
EPA contact: Tom Moriarty Ariel Rios Building |
USDA contact: Teung F. Chin, Ph.D. |
We once again appreciate your assistance. Please let me know if you have any questions.
Best regards,
Kari
Kari E.
Mavian
Senior RegulatoryAffairs Manager
Cheminova,Inc.
1700 Route 23, Suite300
Wayne, NJ07470
tel:1-800-548-6113x233
fax:973-305-1382
