Food Quality Protection Act: 

 An Organopliosphate Update - 

 February 2002 



Glenn Morin 



New England Fruit Consultants, Montague, MA 



As the six-year anniversary of the Food Quahty 

 Protection Act (FQPA) approaches, EPA continues to 

 focus on the regulation of the organophosphate (OP) 

 compounds. The protocols for tolerance reassessment 

 mandated by the FQPA were previously not described, 

 and the methodology by which they are ultimately 

 evaluated will be used to review the other classes of 

 compounds in the future. Therefore, EPA has 

 proceeded cautiously, opened the procedure to public 

 review, and provided for stakeholder input at each step 

 of the six-phase review process. 



This process allows for the development of risk- 

 management recommendations by EPA and, when 

 combined with the previously ongoing re -registration 

 process, ultimately results in the publication of a Re- 

 registration Eligibility Document (RED). The RED 

 finalizes the regulatory process and outlines the 

 conditions under which continued use of the product 

 may occur. 



In the case of the organophosphates, which must 

 still undergo a cumulative risk assessment as a class of 

 compounds (see related article in this issue oi Fruit 

 Notes), EPA has issued Interim Re-registration 

 Documents (IRED). These documents may include 

 risk reduction measures and other label changes that 

 will take effect prior to the final RED, which will be 

 released once the cumulative risks of the OP's have 

 been considered fully. It is anticipated that EPA will 

 conclude its review of the organophosphates sometime 

 later this year. 



All seven of the active ingredients most commonly 

 used in commercial tree fruit production are currently 

 in the final phase of the individual risk assessment 

 process. The following is a summary of EPA's findings 

 and actions as of February 18, 2002. 



Azinphos methyl - Initial label amendments for 

 azinphos methyl (Guthion) that effected tree fruit 



production were voluntarily put in place by the 

 registrants prior to the 1999 growing season primarily 

 in response to EPA's concerns regarding dietary risk to 

 children. Further discussions among the registrants, 

 EPA, and the stakeholder community directed at 

 reducing the risk to agricultural workers and the 

 environment have continued since the release of the 

 revised risk assessment in the summer of 2000. 



The results of these discussions were made 

 available for public comment on November 28, 2001 

 in the form of an IRED. This document proposes the 

 cancellation of 28 crop uses (including nectarines), a 

 four-year phase out of seven crop uses (including 

 peaches) and a 4-year, time-limited registration for 

 eight crop uses (including apples, pears, and sweet 

 cherries). Some highlights of the proposed label 

 changes concerning apple production are as follows: 



limit of 3.5 lbs ai/acre per season east of the 

 Mississippi, 4.0 lbs ai/acre west of the Mississippi; 



increase REI to 14 days for all activities; 



require enclosed cabs or maximum personal 

 protective equipment (PPE) for applicators; 



require closed mixing systems or water soluble 

 bags and closed transfer systems for mixing/ 

 loading; 



add 25-foot buffer zones for permanent surface 

 water; 



add spray drift language; and 



prohibit pick-your-own (PYO) usage or restrict 

 application to early season or establish 30 day pre 

 harvest interval (PHI) for PYO operations. 



The public comment period for this document ended 

 on January 28, 2002. Questions concerning which label 

 amendments will ultimately be required, the timeframe 



Fruit Notes, Volume 67, Winter, 2002 



13 



