October {date}, 2007

Dr. Debbie Edwards
Office Director, Office of Pesticide Programs (7501P)
US Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C.  20460

RE: Comments on Fumigant Revised Human Health Risk Assessment and Solicitation of Risk Reduction Options (FR 72:84, May 2, 2004):
Metam Sodium and Metam Potassium (EPA Docket Identification Number EPA-HQ-OPP-2005-0125), FR 72:84, May 2, 2007; Dazomet (EPA Docket Identification Number EPA-HQ-OPP-2005-0128); Methyl Bromide (EPA Docket Identification Number EPA-HQ-OPP-2005-0123); Chloropicrin (EPA Docket Identification Number EPA-HQ-OPP-2007-350); and, 1,3-Dichloropropens (1.3-D) (EPA Docket Identification Number EPA-HQ-OPP-2005-0124).

Dear Dr. Edwards,

As a producer of {list crops} that depend upon soil fumigation as the foundation of my crop production system, I welcome the opportunity to provide comment on the Environmental Protection Agency’s revised Risk Assessments and proposed mitigation options as referenced in the call for comments published in the Federal Register on May 2, 2007.  The production industry sincerely appreciates the extension of time granted by the Agency to allow for appropriate consideration in the development of comments for these critical compounds.

My production of {list crops} occurs in the following locations and is timed for seasonal access to the market place.  Being highly perishable and time sensitive commodity/ies, any disruptions to production practices or delays in the timeline of production represent significant risks to me as a grower.  My production is scheduled in support of a packing, handling and shipping facility that would not exist without my production of a quality crop in sufficient quantity to allow for efficient operation of that facility.   The economic value of my crop is measured in the farm gate value of {gross production} and employment of {number of employees}.  The associated packing house also employees {number} of persons during our production season with an annual through put of {number of Packages} at an average value of { $$$ }.  The ability to remain in business in the highly competitive fresh vegetable industry has largely been the result of technology such as soil fumigation that has increased yields by over 300 %.

While our production practices do not include all of the above referenced fumigants we do use the following on some portion of our production. 

Many of the mitigation options proposed by the Agency would significantly impact my current production practices.  For those that are particularly significant I would like to comment on the following aspects.

Buffer Zones:

While we recognize the potential benefits of restrictive zones around treated areas, we are extremely concerned that overly large restrictions based entirely on the current modeling may be difficult if not impossible to implement at our locations.  Based on the proposed buffers included in the FR Noticed reference documents, we have provided the following table showing the impacts for our locations if such buffer zones were implemented.  The information included follows the basic criteria as described for the Noling and Culpepper documents in the Docket.  The basic input is distance from the edge of the treated area to an occupied structure.

Sealing Methods:

My farm has utilized alternative methods to reduce use rates including the use of {types of tarps} on {%} of my acreage since {year}.  We have experienced an increased cost of production of {cost} as a result of adoption of these practices.  Additional work continues in this area and as more options become available providing additional reduction in emission with out sacrificing efficacy, we will examine them for adoption into our production practices.  One of the more difficult areas of implementation of this option is the impact on planting schedules as a result of longer residual times in the soil. 

Limitation of Treatment Areas:

As currently proposed, we are concerned over the potential impact of restrictions on size of adjacent areas that can be treated during a given time period.  With our current land preparation and fumigation schedule if patchwork treatments were required over significant acreages the resulting management costs and potential variability in efficacy created by different soil conditions at the time of the different applications to adjacent areas could result in significant economic consequences. 

{Describe the impacts on your farm in as much detail as possible}

Worker Protection Issues:

The fumigation process on my farm is highly regulated at the present time.  Our current practices for protection of those involved in the fumigation process involves direct supervision of the fumigation process by { describe }.  Under normal circumstances our fumigation crew includes a series of steps including {list the sequence of activities in the actual fumigation process) that involves {number} employees.   These employees are required to meet the WPS training level for {workers, handlers, or applicators}.  The persons directly involved in the application of fumigants have the appropriate licensing and work under the supervision of {identify}.  Applications are scheduled based on land preparation activities that allow for a maximum of {acres} to be treated by each crew per day.

The earliest reentry into the filed on my farm would typically be for {activity and occurs {number} of days after the fumigation takes place.    {Describe the required protective clothing or typical clothing worn by these workers}.  If longer reentry intervals than currently required are adopted for fumigants, this would disrupt my production practices in the following ways.  {Describe the specific impacts and the resulting costs or impacts}.

We appreciate the ability to provide comment on these very complex issues and look forward to working with the Agency to develop and implement the appropriate mitigation steps directed toward real risk in the agricultural workplace.  In order to implement the any risk mitigation options adopted by the Agency, EPA and other agricultural support agencies will need to put into place a program and process to provide the regulated industry with the tools necessary to understand and ensure adequate implementation practices.

Sincerely yours,

{Name}
{Title}, {Company}

CC:      Daniel A. Botts/Michael Aerts, E & PM Division, Florida Fruit & Vegetable Association