Fenamiphos Information Request -- Hawaii Response
From: Cathy Tarutani
Sent: Wednesday, August 10, 2011 2:10 PM
To: Chin, Teung F. (APHIS); Kunickis, Sheryl
Cc: Kunickis, Sheryl; Mike Kawate; Rick Melnicoe
Subject: Re: Fenamiphos: Comment Invited on Extension of Existing Stocks Sale and Distribution Date and Establishment of End-Use Date
Teung,
According to the FR Notice, Maui Pineapple Co. requested the one-year extension of the deadline for sales and distribution of Nemacur 3. You are probably aware that Maui Pineapple Co. was the pineapple production subsidiary of Maui Land & Pineapple Co. and that Maui Land and Pineapple shut down the pineapple production operation at the end of 2009. (I'm not absolutely certain about dates.)
A new company, Haliimaile Pineapple Co., has since begun operations on Maui. (Again, I don't know very much about the business details. But, this is what I understand.) While employing a few of the same people and (I believe) leasing land and equipment from Maui Land & Pineapple, Haliimaile Pineapple Co. is an entirely separate entity from Maui Land & Pineapple. And the pineapple production and acreage at Haliimaile is considerably less (a LOT less) than the production of Maui Pineapple.
Maui Pineapple still has Nemacur 3 in its inventory. Because Maui Land & Pineapple and Haliimaile are un-related companies, the Nemacur 3 must be "sold" or "distributed" to Haliimaile. Hence, the need for the extension of the deadline for the sales and distribution.
It is my understanding that the 3-year deadline for use of existing stocks of Nemacur 3 was not a part of Maui Pineapple's request for extension of the deadline for sales and distribution. However, Maui Pineapple did not express objections or concerns about the 3-year deadline. Unfortunately, I do not have contacts at Haliimaile and could not confirm that they anticipate that they will be able to use Maui Pineapple's remaining inventory of Nemacur 3 in three years.
Maui Land & Pineapple did not indicate a need for us to comment on the proposed amendment to the fenamiphos cancellation order. Neither did the Dole pineapple production operation on Oahu. Dole indicated that the stocks of Nemacur 3 that they have on hand will last from 1.5 to 2 years. Therefore, we do not plan to submit comments regarding this issue.
Also, from my reading of the FR Notice, the amended cancellation order will allow for sales and distribution of Nemacur 3 during the one-year extension. This would allow distribution of Nemcur 3 to other parties, if necessary.
If you have any questions or concerns about this issue, please contact me.
Mahalo,
Cathy
Cathy Tarutani
Extension Pesticide Programs
Plant & Environmental Protection Sciences University of Hawaii
voice: 808-956-2004
