Comment submitted by Dr. J Angel Saavedra, Dow AgroSciences de Mexico

Dear EPA representative: I reffer to the docket id EPA-HQ-OPP-2007-0445 (Acephate, Chlorpyrifos, Fenbutatin-Oxide (Hexakis), Metolachlor (S-Metolachlor), and Pyrethrins; Proposed Tolerance Actions) in order to comment regarding the revocation of tolerance for Chlorpyrifos in tomato that was recently published with due date for comments 10/09/07. As an Industry regulator in Mexico I receive a lot of comments/questions from vegetable growers, packers, exporters, deelers, mainly from the NW area of Mexico, where a lot of tomato exportation to USA happens with the concern of this probable revocation. I comment them that an EPA tolerance revocation does not mean niether a MRL cancelation in Mexico nor a CODEX MRL revocation. Mexican Regulatory Agency currently valid EPA tolerance, Codex MRLs and EU MRL so if those MRLs outside USA are still valid, Mexican MRL will still be valid. If growers export tomatos to USA that were applied with Lorsban (Chlorpyrifos), a trade irritant could be presented. My suggestion is to avoid any commerce irritant and include an IMPORT TOLERANCE FOR THE COMBINATION CHLORPYRIFOS-TOMATO to avoid any problem. Or keep that EPA tolerance that will help a lot Mexican growers. Chlorpyrifos is an efficient tool in vegeltables, including tomato, still used in the field mainly for the control of leaf miner (Liriomyza spp.) without causing resistance; another importat pest that is controled by Lorsbanin tomato is Beat armyworm (Spodoptera exigua). During the last two season there has been a lot of problems with tomato psyllid, that has been very difficult to control, and chlorpyrifos has been a register tool to control it outperformed other products. I hope that you consider this revocation decission, and please take in consideration the following aspects: 1. Lorsban 75 WG authorized in Mexico for tomato has been classified as tox class IV for its safeness in its handling. 2. MRLs will still be available in the EU and Codex. 3. Chlorpyrifos(Lorsban) is still a usefull tool for tomato growers in Mexico. 4. Mexico's main export tomato market is USA 5. Chlorpyrifos is a resitant managment tool for several pests in tomato. Best Regards, Dr. J Angel Saavedra Manager of Regulatory and Government Affairs Dow AgroSciences Mexico e mai: jsaavedra@dow.com Tel 52 33 3678 2452