Comment submitted by D. Glennon, Spectros Instruments Inc

Re: Docket ID Number EPA-HQ-OPP-2005-0123 Comment on Revised Risk Assessment and Mitigation Proposals for Methyl Bromide in Relation to EPA?s Re-registration Eligibility Assessment Background on Spectros Instruments, Inc. Spectros Instruments provides innovative optical analyzers for gas analysis. These monitors are used extensively in the sterilization, semiconductor, refrigerant and fumigation sectors. Manufacture of these monitors is in accordance to various quality and safety standards including IS9002, CE, UL and FM approvals. Spectros Instruments, Inc. Accomplishments for Fumigant Gas Monitors: ? USDA/APHIS/PPQ Approved Methyl Bromide Fumigation Monitor for Quarantine Schedules (MB-ContainIR) ? Factory Mutual (FM)approved ethylene oxide monitor for spice fumigation (EOS-200) ? Dow AgroSciences LLC Approved Clearance Monitor for Sulfuryl Fluoride concentrations 0-5ppm (Profume/Vikane) the SF-ExplorIR *PERFORMANCE TEST DATA AVAILABLE UPON REQUEST FOR ALL FUMIGATION MONITORS Reliable methyl bromide air monitoring equipment is readily available from Spectros Instruments, Inc. with the following benefits 1. real-time continuous monitoring (not just spot testing as with color- metric tubes that have a shelf life and variance within production lots) 2. unambiguous answers (spectroscopic fingerprints) This monitor (MB-ContainIR) is immune from cross contamination and interferences that plague other outdated monitors (thermo conductivity based). Reference data and testing Dr. Alan V. Barak; USDA,APHIS,PPQ. 3. AFFORDABLE: Current configurations from $6,000 to $8,000 USD. 4. available for quick integration into a Fumigation Management Plan 5. ppm, g/m3,ounces/1000ft3 units 6. continuous logging of data points at user defined intervals 7. WEB based monitoring (option) encrypted site 8. bright, backlit digital display 9. portable (9lbs)with 10 hour battery life 10. multiple communication interfaces (RS485, 4-20mA, WiFi, MODBUS) 11. audible alarm There is a wealth of technical data in the fumigation community that details cross interference, inaccuracies and unreliable measurements of existing thermo- conductivity, extractive and pyrolytic fumigation monitors and clearance devices. Inclusion of a monitor on a product label is no guarantee of performance to specified requirements. There is no burden of proof on these monitors and fumigators have learned to live with the inaccuracies while no regulatory agency polices the industry on this account. Spectros Instruments, Inc. certifies in writing the performance of our fumigation and clearance monitors like no other vendor. Spectros Instruments, Inc. has a proven history of success providing monitors with defined specifications and features for the fumigation market. Real-time, continuous air monitoring of methyl bromide would ELIMINATE CUMBERSOME BUFFER ZONES and associated problems. (i.e. in California buffer zones require reduced dosage rates and have given reduced penetration with increased fumigation times.) Spectros Instruments currently has a methyl bromide monitor and proprietary flux chamber for direct sampling of flux emissions of methyl bromide from a treated field. If the appropriate United States Government Agency will define a 1. technical specification for methyl bromide detection 2. define a market potential 3. request a price point for delivery to market Then as any commercial for profit corporation, Spectros Instruments, Inc. ,can respond to the feasibility of such a monitor. As of this date no discussions or request on this matter has been forthcoming from ANY government agency. Mathematical modeling of air concentrations reflecting different conditions based on changing factors such as application rates, field sizes, weather and other conditions is important. The basis for all this modeling needs to be authoritative spectroscopic data of actual fields given their geographic uniqueness. ( i.e. it is not reasonable to assume that a field on one given day in California should give representative data transferable to a field in Georgia under different soil and environmental conditions on another day). What Spectros Instruments can do in real time is deliver in a easy, economical manner a site specific testing for data that can be incorporated on the fly to meteorological data for more precise point source modeling. It would therefore be possible to give more authoritative methyl bromide flux emission data for a specific location. The economics and performance criteria currently exist to implement this solution for methyl bromide. There is a high probability that Spectros Instruments, Inc. has or can in a reasonable period provide a compliant solution and can assure the properly trained end-user that all safety requirements are met for working with methyl bromide. Regards Dennis Glennon Chief Technical Officer Spectros Instruments, Inc.