EPA 730-N-01-006
Draft PRN concerning Spray and Dust Drift Label Statements for Pesticide Products

       EPA is issuing for public comment a draft Pesticide Registration Notice (PRN) that
would provide guidance to registrants on product labeling statements for controlling spray (and
dust) drift from application sites.  The PRN also describes OPP's policy on spray drift and
proposed plans for implementing these statements on product labels. The purpose of the
proposed new labeling guidance is to provide pesticide registrants, applicators, and other
individuals responsible for pesticide applications with improved and more consistent product
label statements for controlling pesticide drift to ensure protection of public health and the
environment. The PRN would not apply to certain types of pesticide products and uses which
raise special considerations for appropriate labeling. Further, the Agency does not intend for its
new guidance to conflict with or supersede more stringent restrictions by states or tribes or which
are currently on product labels. The draft PRN is available at www.epa.gov/pesticides.
Comments on the proposed PRN are due ninety days after publication of the Notice of
Availability in the Federal Register.

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                                                          EPA 730-N-01-006
                  PESTICIDE REGISTRATION (PR) NOTICE 2001-X

        NOTICE TO MANUFACTURERS, FORMULATORS, PRODUCERS, AND
                      REGISTRANTS OF PESTICIDE PRODUCTS

 ATTENTION:      Persons Responsible for the Registration of Pesticide Products

 SUBJECT:          Spray and Dust Drift Label Statements for Pesticide Products

       This Notice sets forth the U.S. Environmental Protection Agency's (EPA or Agency)
 guidance for labeling statements for controlling spray drift and dust drift from application sites
 and for implementing these statements for risk mitigation. The purpose of this new labeling
 guidance is to provide pesticide registrants, applicators, and other individuals responsible for
 pesticide applications with improved and more consistent product label statements for controlling
 pesticide drift in order to be protective of human health and the environment. This Notice also
 includes EPA's position on drift, a rationale for the label statements, and an implementation plan.

 I. SCOPE AND PURPOSE

 A.  Affected Products and Uses

       This PR Notice applies to all pesticide products labeled for use outdoors that can be
 applied as sprays or dusts, including applications with ground hydraulic, airblast, aerial,
 chemigation, handheld, or backpack equipment, except for products stated below.  Application
 sites for affected products include, but are not limited to,  agricultural crops, forestry, rights-of-
 way, recreational areas, lawns, and home gardens.

       While most of the science and regulatory emphasis has been on off-target drift of sprays,
 the Agency recognizes that applications of dust formulations also drift. Many of the same
 concerns and principles apply to products that are applied as dusts. The Agency's use of the term
 "spray drift" in this notice also applies to drift of dust formulations unless stated otherwise.

       This notice does not to apply to: 1) products labeled solely for indoor use; 2) products
 labeled for outdoor use which are applied in a form other than a spray or dust, such as a granular
 formulation; 3) fumigant products, due to their different physical state and behavior (vapor rather
than liquid or solid particles); and 4) mosquito adulticide products labeled solely for use in public
health programs. These and certain other products will require special consideration for
 appropriate labeling.

       Many states and tribes have restrictions and policies for controlling spray drift, including
requirements of no-spray zones for certain or all pesticides, maximum spray release heights, and
allowing applications only during certain wind speeds.  EPA does not intend for its new guidance
to conflict with or supersede more stringent restrictions by states or tribes or which may currently
be on product labels.

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B. Applicable Definitions   .    •      •

       The Agency's current focus on pesticide spray drift is within relatively short distances (up
to Vz mile) from the application site in which most deposition occurs. However, EPA recognizes
that under certain circumstances lower levels of pesticides may drift considerably farther. For the
purpose of this draft notice, EPA limits the meaning of the term "spray (or dust) drift" to the
following definition:

       "Spray or dust drift is the physical movement of pesticide droplets or particles through the
       air at the time of pesticide application or soon thereafter from the target site to any non- or
       off-target site. Spray drift shall not include movement of pesticides to non- or off-target
       sites caused by erosion, migration, volatility, or windblown soil particles that occurs after
       application or application of fumigants unless specifically addressed on the product label
       with respect to drift control requirements."

       This definition is based on a definition of spray drift composed by participants of the
National Coalition on Drift Minimization, which include representatives from federal (including
EPA and the U. S. Department of Agriculture) and state agencies and tribes., pesticide and
equipment manufacturers, university scientists, and others, who have focused their attention on
enhancing pesticide applicator education, application research, and regulatory initiatives to foster
reductions in spray drift.                  •    .

       The Agency recognizes that pesticide vapor and the off-target movement of pesticides by
other means, not included in this definition, can nevertheless present substantial risks to humans
and the environment. EPA generally addresses these routes of exposure and associated risk at the
individual pesticide level through its regulatory programs.

       EPA defines the term "no-spray zone" (also known as "buffer zone") for the purposes of
this notice as follows:

       "A no-spray zone is an area in which direct application of the pesticide is prohibited; this
       area is specified in distance between the closest point of direct  pesticide application and
       the nearest boundary of a site to be protected, unless otherwise specified on a product
       label."

For example, a no-spray zone of 100 feet to protect a specified site would require the applicator to
leave a distance of 100 feet between the point of spray application and the nearest boundary of the
specified protected site.

       In summary, through this PR Notice, EPA provides its guidance to applicants and
registrants of pesticide product registrations for appropriate labeling statements for controlling
spray and dust drift.  This approach represents EPA's interpretation of the labeling language

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 generally appropriate to implement the requirements of 40 CFR Part 156 and section 2(q) of
 FIFRA, which if not met the Agency may find a product to be misbranded and may take
 appropriate enforcement and/or regulatory action. 'EPA generally expects to follow this approach
 in its individual licensing actions.  This guidance does not itself impose any binding requirements.
 The requirement to adopt the approach provided here would be imposed in the context of
 individual licensing actions. And, EPA may depart from the guidance where circumstances
 warrant and without prior notice.  Accordingly, changes to these statements or additional
 statements may be warranted for certain products depending on uses, product hazard potential,
 and other considerations, and may be proposed by the applicant or registrant or by the Agency in
 conjunction with any application for registration or amended registration.  The, Agency also
 provides here its underlying position-on spray drift and how it plans to implement these and other
 label statements for new and currently registered pesticides.

 II. BACKGROUND

       EPA has been working to improve the underlying science of pesticide spray drift, its
 understanding of the science, and the most effective means to control or mitigate spray drift.
 These and other related efforts are discussed below and hi the publication "For Your
 Information-Spray Drift of Pesticides," December 1999
 (www.epa.gov/pesticides/citizens/spraydrift.htm.

 A. EPA's Concern About Off-target Spray Drift

       Pesticide spray drift has been and continues to be of concern to EPA in its responsibility to
 ensure that pesticide use does not cause unreasonable adverse effects to human health and the
 environment. Each year, states receive about 2,500 complaints of drift from individuals.  These
 complaints are investigated and, if appropriate, enforcement action is taken (1999 AAPCO
 Pesticide Drift Enforcement Survey, http://aapco. ceris.purdue. eduY. Other reports of drift
 incidents are reported to EPA under adverse reporting requirements, the National Pesticide
 Telecommunications Network "(NPTN1999 Annual Report, (http://ace. orst. edu/info/nptn/}, and to
 agriculture insurers. The Agency believes many incidents are unreported.

 B. Drift Labeling Statements Prior to This Notice

       At the time of registration and reregistratiori, EPA has and currently requires various
product label statements for preventing or controlling spray drift.  EPA has required more detailed
label statements, including the use of no-spray zones and maximum application heights, for
certain products, especially those which can be applied aerially. Additionally, agricultural
products to which worker protection regulations (40 CFR, Part 170) apply bear labeling which
includes the  required statement "Do not apply this product in a. way that will contact workers or
other persons either directly or through drift." This PR Notice does not alter this worker
protection requirement and is not expected to  guide in circumstances where other label statements

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 are more stringent than the guidance in this Notice. The Agency and many other, stakeholders
 believe product labeling for spray drift control should be improved and standardized to the degree
 possible to provide applicators with more consistent and appropriate directions for controlling
 drift. Such changes are consistent with the requirements of 40 CFR Part 156 and section 2 (q) of
 FIFRA.                ,                                 ;....'

 C. Data Availability

       Under 40 CFR part 158, EPA may require data on drift to support the registration or
 reregistration of certain products. In recent years, the Agency has received a new collection of
 studies conducted by a group of registrants, named the "Spray Drift Task Force" (SDTF), to
 satisfy generic data requirements (see PR Notice 90-3, dated April 6, 1990, entitled "Announcing
 the Formation of an Industry-Wide Spray Drift Task Force"). Also, the SDTF in collaboration
 with EPA and USDA co-developed AgDRIFT, a new model, to provide estimates of spray drift
 deposition under different pesticide application and meteorological conditions. The Agency
 reviewed these new studies, AgDRIFT, and other scientific reports from the open literature and a
 data set from Germany.  EPA's conclusions from its review of this collection. Of data and the
 utility of AgDRIFT were peer reviewed in 1997 and 1999 by independent scientific experts,
 including the FIFRA Scientific Advisory Panel (SAP).  These independent scientists generally
 agreed with the Agency's conclusions regarding the data and the usefulness of AgDRIFT. EPA
 intends to use its conclusions from the review of these data, new data it may receive, and
 AgDRIFT or other appropriate models in its assessments of pesticides.

, D. Collaborations with Stakeholders

       EPA has communicated with other federal, state, and tribal government agencies and other
- stakeholders, including registrants, pesticide applicators, and equipment manufacturers, to gain a
 better understanding of their needs and concerns regarding pesticide application and the control of
 spray drift. The Agency has also discussed with regulatory authorities of other countries their
 approaches to assessing and regulating off-target spray drift. The Agency has'carefully considered
 the concerns and suggestions expressed by these stakeholders in formulating this notice.  •

 IH. EPA'S POSITION ON PESTICIDE DRIFT

       The Agency has the responsibility to ensure that the use of pesticides will not cause
 unreasonable adverse effects to human health and the environment.  Those involved in pesticide
 application decisions have an important responsibility to protect people, domestic animals,
 wildlife, and the environment from pesticide exposures and potential harm from drift. States,
 tribes, and EPA have responsibilities to carry out enforcement to ensure compliance with pesticide
 use requirements.                                                           •
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       EPA's position on pesticide drift is that applicators must not allow pesticide spray or dust
to drift from the application site and contact people, animals, and certain sensitive sites, including
structures people occupy at any time and the associated property, parks and recreation areas,
nontarget crops, aquatic and wetland areas, woodlands, pastures, or rangelands. The Agency
believes this is prudent public policy. It sets high but appropriate standards for applicators to
protect people and the environment. Applicators must consider and use necessary application
practices and measures required by states or tribes in addition to mandatory drift control measures
that are stated on product labels.  EPA believes the suggested labeling in this Notice will reduce
risks associated with pesticide drift without a significant reduction hi product efficacy.
Accordingly, EPA believes that these label statements will help ensure that the requirements of
FIFRA are met and, specifically, that pesticides are used in a manner that does not result in
"unreasonable adverse effects on the environment."

       The Agency's understanding of drift and available means to control it has significantly
improved; however, EPA recognizes there will always exist controllable and uncontrollable
factors which lead to drift, potential exposures, and risks of harm.  The factors that contribute to
drift are unique to each application and depend on weather, the application site, application
equipment, and applicator behavior.  EPA takes very seriously the potential adverse impact drift
can have on human health and the environment. For these reasons, labeling for applicators must
be clear and enable enforcement authorities, including states, tribes, and EPA, to take action when
appropriate.

       EPA recognizes that some de minimus level of drift would occur from most or all
applications as a result of the uses of pesticides. The Agency believes the approach set forth here
will .not have an undue impact on agriculture or other uses of pesticides.  EPA believes many
responsible applicators already take added measures to control drift. This position and new
labeling will clarify expectations for applicators and set definitive standards for application
practices.  For many years EPA and many states and tribes have had requirements or policies
prohibiting drift. Wording to this effect (e.g., "Do not allow drift." and "A person may not apply
a pesticide when wind speed exceeds 10 miles per hour.") appears on many pesticide product
labels and/or in state laws (see Theodore A. Feitshans, An Analysis of State Pesticide Drift Laws,
San Joaquin Agricultural Law Review, vol. 9(1), 1999).  Enforcement authorities have carried out
their actions to enforce such language in a reasonable manner. That position and label wording •
prohibiting drift are at least as, if not more, restrictive than the position and new wording
expressed in this notice.

       The Agency believes that the new labeling statements provides improvements  over current
labeling which is inconsistent or inadequate and for many products unclear to applicators and
others. Use of the new statements, or some variation, by registrants for all affected products will
provide a level of consistency among product labels.  The statements also address for each
application method specific application requirements that are key to drift mitigation. These
application requirements are based on the Agency's conclusions of the supporting science of drift.

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And, the Agency has written the labeling statements in a manner that it believes the meaning is
clear and enforceable and allows flexibility for the use of new application technology.  These are
labeling characteristics that meet the interests expressed by stakeholders as mentioned above.

IV.  LABEL STATEMENTS

       The Agency has developed a set of labeling statements as guidance for use on agricultural,
home lawn and garden, and other outdoor use product labels. EPA considers these statements to
be generally appropriate for all pesticides affected by this notice. These mitigation measures
generally can be implemented for most products, regardless of the active ingredient and
formulation chemistry. However, the Agency acknowledges that this guidance may not be
appropriate for all products and their uses  and that for certain products  there may be exceptions to
the wording of these statements in which some part(s) should not apply and/or other wording may
be more appropriate. For example, while this notice applies to biopesticides applied as sprays or
dusts, label statements will be determined on a case-by-case basis due to their usual low risk
characteristics.

A. Label Statement Guidance

1. Products Applied as Sprays—All Affected Products, Except Home and Garden Products:

       "Do not allow spray to drift from the application site and contact people, structures people
       occupy at any time and the associated property, parks and recreation areas, nontarget
       crops, aquatic and wetland areas, woodlands, pastures, rangelands, or animals.

       For ground boom applications, apply with nozzle height no more than 4 feet above the
       ground or crop canopy and when wind speed is 10 mph or less at the application site as
       measured by an anemometer. Use	(registrant to fill in blank with spray quality, e.g.
       fine or medium) or coarser spray according to ASAE 572 definition for standard nozzles
       or VMD for spinning atomizer nozzles.

       For orchard/vineyard airblast applications, do not direct spray above trees/vines and turn
       off outward pointing nozzles at row ends and outer rows. Apply only when wind speed is
       3-10 mph at the application site as measured by an anemometer outside of the
       orchard/vineyard on the upwind side.

       For aerial applications, the boom width must not exceed 75% of the wingspan or 90% of
       the rotary blade. Use upwind swath displacement and apply only when wind speed is 3 —
       10 mph as measured by an anemometer. Use	(registrant to fill in blank with spray
       quality, e.g. fine or medium) or coarser spray according to ASAE 572 definition for
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 standard nozzles or VMD for spinning atomizer nozzles. If application includes a no-spray zone,
 do not release spray at a height greater than. 10 feet above the ground or the crop canopy.

       For overhead chemigation, apply only when wind speed is 10 mph or less.

       The applicator also must use all other measures necessary to control drift."

 2.  Products Applied as Dusts-All Affected Products, Except Home and Garden Products:

       "Do not allow dust to drift from the application site and contact people, structures people
       occupy at any time and the associated property, parks and recreation areas, nontarget
       crops, aquatic and wetland areas, woodlands, pastures, rangelands, or animals.

       For ground rig applications, apply product no more than 4 feet above the ground or the
       crop canopy and only when wind speed is 10 mph or less at the application site as
       measured by an anemometer.

       For orchard/vineyard ground applications, do not direct dust above trees/vines and shut off
       application at row ends and toward outer rows.  Apply only when wind speed is 3 -10
       mph at the application site as measured by an anemometer outside of the orchard/vineyard
       on the upwind side.

       For aerial applications, use upwind swath displacement and apply only when wind speed
       is 3 — 10 mph as measured by an anemometer.  If application includes a no-spray zone, do
       not release dust at a height greater than 10 feet above the ground or the crop canopy.

       The applicator also must use all other measures necessary to control drift."

3. Hand-applied Products, Including Home and Garden Products, to be Applied as Sprays or
Dusts:                                                                   ,

       "Do not allow spray (or dust) to drift from the application site and contact people,
       structures people occupy at any time and the associated property, parks and recreation
       areas, nontarget crops, aquatic and wetland areas,  woodlands, pastures, rangelands, or
       animals.  Apply only when wind speed is not more than 10 mph. For sprays, apply largest
       size droplets possible."

B. Possible Additional Product-Specific Labeling

       Other labeling statements may be appropriate for certain products depending on the
potential risks from the labeled uses.  In EPA's human health and environmental risk assessments,
the Agency may identify reported adverse effects or potential significant risks associated with drift

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from use(s) of a product or group of similar products. Such incidents and risks could include
adverse effects to humans, plants, and wildlife or contamination of surface water. EPA will
consider the available information on a pesticide's incident history, current uses, and estimated
exposures and risks, including estimates of deposition from available models, to determine the
need for additional drift mitigation measures. Examples of such measures include limiting
application height, spray quality (droplet size), use of no-spray zones, and prohibition of an
application method.

       If the Agency determines that a no-spray zone is necessary for a product, the following
label statement will be used:

       "Do not apply this product within	(distance to be determined) of	(sensitive
       areas to be determined for the product). Under no circumstances apply this product within
       	(distance to be determined) of people or these areas."

       EPA may find that the, addition of no-spray zones to the above labeling statements is
prudent as an additional drift management tool for applicators to protect people and sensitive
areas from drift.  EPA in its risk management decisions will determine whether one or more no-
spray zones and their distance(s) are necessary for products using available information about the
pesticide's uses and risk assessments.

C. Rationale for Label Statements:

       EPA believes these label statements, if adopted, will generally be adequate to protect
people and the environment from unreasonable adverse effects. These statements are also written
in a clear, concise, and readily understood manner that address the most influential factors in
cause and control of spray drift—wind speed, placement of nozzles, spray quality or droplet size,
and application height.  The Agency believes it is important to require applicators to measure
wind speed at the application site and with an anemometer, an inexpensive instrument for this
purpose, hi order to obtain an accurate measurement. Measuring wind speed outside of orchards
and vineyards and on the upwind side, rather than inside, gives a measure before the wind is
obstructed by trees, vines or bushes and is relevant to drift that may move above the orchard
canopy or beyond the rows.  Specific application technology, which is constantly changing, was
not incorporated into the label statements in order to give applicators greater flexibility in using a
choice of evolving technology to achieve the desired results.  EPA supports the development and
use of new application equipment and methods to improve pesticide applications and reduce risks.
EPA encourages registrants to submit information that support engineering controls that
contribute to reducing drift.

       Because of the importance of these factors and applicator/operator decision-making, the
Agency believes it is prudent for these label statements generally  to apply to labels of all affected
pesticide products. Some stakeholders have expressed concerns that specific application

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 restrictions may be impractical in certain application situations, such as in areas where windy
 conditions are very typical. Also, some enforcement authorities may be unable to determine
 whether or not an applicator followed certain specific application requirements, such as proper
 application height.  However, the Agency believes the importance of these application restrictions
 generally outweighs these concerns because when followed these application practices will
 significantly reduce drift and therefore potential risks to people and the environment.

       The Agency intends to use the above considerations for any additional label statements
 that are beyond the generic statements for specific products. These additional statements may be
 applicable for certain products depending on their levels of toxicity, use patterns, predicted spray
 drift deposition and reported incident history in order to meet the Agency's responsibility for
 ensuring that products do not result in unreasonable adverse effects to humans or the environment.

       As stated above, the Agency may see the need for no-spray zones or other risk reduction
 measures for-products associated with higher risks from drift. As defined above, the purpose of a
 no-spray zone is to provide a distance for drifting pesticide particles to dissipate before contacting
 sensitive areas or people. Since higher wind speeds generally result in higher levels of drift from
 the target site, a no-spray zone would be calculated for a product label using the highest wind
 speed allowed by the label. Conversely, lower wind speeds result in lower drift; however spray
 drift modeling suggests that applications under these conditions still may result in unacceptable
 deposition for certain pesticides. Also, low winds are generally highly variable in direction—gusts
 frequently blow contrary to the predominant wind direction.

 V.  WHAT REGISTRANTS  SHOULD DO

 A.  Applications for Registration, Amendment, and Reregistration

       EPA will begin immediately evaluating the use of these label statements in reviewing
 applications for registration, amendments, and reregistration of existing products subject to this
Notice. The Agency's goal is to have the process of approving drift statements substantially
 complete by October 1, 2003.

       Accordingly, registrants should be prepared to address drift considerations and the
application of the above generic statements for labels of their affected products when submitting
applications for new and amended product registration. As a general matter, EPA believes that for
currently registered products, existing statements pertaining to drift should be removed and the
suggested new generic statements should be incorporated. Exceptions are the required label
statement "Do not apply this product in a way that will contact workers or other persons either
directly or through drift." to comply with the worker protection regulations and any current drift
label statement that is more restrictive than the generic  statements in this notice. The new generic
statements should be placed near the beginning of the Directions for Use section after the misuse
statement.

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       Registrants may submit an application for amendment for each product. Applications
should be directed to the appropriate Product Managers. An application should include the
following: a completed EPA application form 8570-1; three copies of the revised draft label, and a
description on the application, such as, "Response to PR Notice 2001-	." Because individual
products must be evaluated according to formulation and use, and because individual
circumstances may apply, EPA must review and approve the  labeling of each product.
Notification is not permitted for adding, revising, or deleting  drift statements on the label.

B. Existing Products

       EPA will evaluate the need to include the label statements in this notice in Reregistration
Eligibility Decision (RED) documents and to product labels submitted in response to a RED
document issued prior to this PR Notice.  Registrants of affected products that currently are
subject to reregistration submission requirements do not need to file a separate application for
amendment as above.  Rather, appropriate draft statements along with any other actions necessary
can be included in their response to product reregistration.

C. Alternative Wording

       For either registration or reregistration, if a registrant believes that alternate text is more
appropriate than the above generic statements for their product(s), the company should submit a
rationale for the alternate text along with the application and draft product label. If approved, the
registrant may then use the alternate text.
                                                                     I
D. Previous Labeling

       Once the spray drift mitigation statements are approved by the Agency, registrants will
generally have up to eighteen (18) months from the date of the newj approved label to distribute
and sell products bearing  old labeling unless the Agency establishes an alternative date pursuant
to 40 CFR section 152.130(d).' Persons other than the registrant may continue to distribute or sell
such products until supplies are exhausted.
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 E.  Address for Submission

       Registrants should send or deliver their applications for amendment to either of the
 following addresses:

 U.S. Postal Service Mail Delivery-

       Document Processing Desk (AMEND)
       Office of Pesticide Programs (7504-C)
       U.S. Environmental Protection Agency
       Ariel Rios Building
       1200 Pennsylvania Ave., N.W.
       Washington, D.C. 20460-0001

 Personal/Courier Service Hand-Carried Delivery (Monday - Friday, 8:00 AM - 4:30 PM,
 excluding Federal holidays-

       Document Processing Desk (AMEND)
       Office of Pesticide Programs (7504-C)
       U.S. Environmental Protection Agency
       Room 266A, Crystal Mall Building 2
       1921  Jefferson Davis  Highway
       Arlington, VA 22202

VI. STATE APPROVALS  MAY BE NEEDED

       Please note that some states conduct label reviews prior to approving a modified product.
Various states' requirements should be taken into consideration when deciding on the timing of
your amendment submission to EPA. Some states may require a review of the modified label by
EPA prior to submission to the state for state approval purposes.

VH. FOR FURTHER INFORMATION

       For further information about this notice, contact Jay Ellenberger, Field and External
Affairs Division, by telephone at 703-305-7099 or by e-mail at ellenberger.jav(g),epa.gov.
                                      Marcia E. Mulkey
                                      Director
                                      Office of Pesticide Programs


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