[Ogen] IMPORTANT: EPA Proposal to Remove Grapes from Mancozeb Label -- How to comment and take action

[Smith, Maria]

Good afternoon,

I'm following up from the August 5<https://ohiograpeweb.cfaes.ohio-state.edu/blog/august-5-2024-711pm/mancozeb-proposed-interim-registration-review-decision-crop-cancellations> Buckeye Appellation Blog post on the proposed EPA changes that would cancel the use of mancozeb labelling for all grape use, in addition to numerous other restrictions outlined in the post.

This should be perceived as a major, pressing issue for Ohio grape producers, since mancozeb is extensively used for early-season Phomopsis, black rot, and downy mildew control. The way to respond to the proposed changes is through individual and collective voicing of comments through the EPA website.

To facilitate an Ohio industry-wide response through OGIC, we are requesting feedback on Ohio grape producer use of mancozeb that we can use as supplemental data. Please respond to the following brief survey by Friday, August 30, 2024. https://osu.az1.qualtrics.com/jfe/form/SV_4MlxY7NAnHL6CYC

Copied below is information from Megan Luke at the Lake Erie Regional Grape Program on points to use when crafting an impactful comment and how to navigate to the appropriate comment section of the EPA website.

*It should be noted that the current comment period closes on September 16.

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Mancozeb- has been added to the pesticide review process and has a docket number. Currently, all applications in grapes are being removed from the label, registration of this chemistry will be canceled ONLY in grape production and seed applications in other cropping seasons.

Other cropping systems are receiving label changes including (but not limited to): increased PPE requirements, closed cab tractor application, 48-hour rain event non-application requirement, increased REI, and respirator requirements for handlers.

If you are interested in commenting on the mancozeb docket, here are a few pointers for creating an impactful statement. Remember: while many of the organizations, processors, researchers, and institutions will be submitting documentation to support the continued use of this chemistry in grape production, they cannot tell your personal story and how this impacts your individual operation. Those stories are important and need to be told as well.

Impactful comments include:

*         Anecdotes regarding the benefits of use
*         Numbers and percentages where possible: for example, stating that skipping mancozeb in your spray program one year resulted in a 20% crop loss to black rot.
*         Concerns around the loss of additional chemistries (cost or resistance issues)
*         Practices that you already use that allow for the safe use of this chemistry
o   Mechanization
o   Timing of applications
o   Reduced rate from max allowed
*         Possible changes that you would be willing to make to make applications safer

When commenting, avoid:

*         Angry or abusive language
*         Accusations- these changes are not due to malice
*         Typos and grammar errors (We are happy to review your comment prior to submitting if requested!)

Our team is working diligently to mobilize efforts to respond to this issue and present an industry-wide unified front. We deeply appreciate your help in these efforts and will update as relevant.

Comment on changes to the mancozeb label: here<https://www.regulations.gov/docket/EPA-HQ-OPP-2015-0291/document>

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[Click this box to write your comment!]



A breakdown of the timeline for pesticide label review*:


Current: The Proposed Interim Decision (PID) will be published and posted for public comment.

60 Days: From the publication of PID, there will be a final 60-day public comment period.

6 months: After the 60-day comment period closes, the EPA will review the comments and finalize the decisions, including publishing the Interim or Final Decision (ID or FD). As per above, the ID is expected to be published two quarters after the PID

60 Days: Once the Final Decision is made, labels are updated within 60 days and sent for a federal stamp. It can take over 60 days to review updated labels, receive a federal letter, and stamp it.

12 Months: From the date the federal letter is stamped, there is a 12-month "grace period" to utilize or responsibly dispose of any remaining product within the supply chain. This includes on-farm products and products located at suppliers and distributors.

*This timeline is general and may be longer or shorter depending on the response from the public and situations where additional research is conducted

[The Ohio State University]

Maria Smith, PhD
Viticulture Outreach Specialist

The Ohio State University
College of Food, Agricultural, and Environmental Sciences
Horticulture and Crop Science
205 Gourley Hall
1680 Madison Ave., Wooster, OH 44691
330-263-3825 Office
smith.12720 at osu.edu<mailto:smith.12720 at osu.edu> / go.osu.edu/grapes<http://go.osu.edu/grapes>

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