Comment submitted by Jim T Criswell, Oklahoma State Univ. Pesticide Safety Edu Program

July 15, 2009 To Whom It May Concern: We are writing regarding EPA-HQ-OPP-2009-0191 docket on the arsenical herbicides. These comments are those of the Pesticide Safety Education Program and do not represent those of Oklahoma State University. We do not dispute EPA’s decision to cancel these herbicide uses. We commend EPA for extending the use of existing stock dates. We express our concern for the limited time for the use of existing stocks for residential lawn uses. This period of use ends December 31, 2010. That is just over one spray season away. We have observed several non-box store companies in Oklahoma with ample supply of MSMA on their shelves. These must be sold by June 10, 2010. If these are sold, the product is not likely to be used by December 31, 2010. Therefore, our concern is a disposal problem primarily for homeowners. Otherwise, states will be dealing with illegal use and disposal issues by homeowners. We encourage EPA to extend the use of existing stock date for residential lawns to December 31, 2011. This should assist in getting most of the product applied and out of homes. We have been told by commercial and public applicators that supply of MSMA for right-of-way uses is tight. It appears that the use of existing stocks date of December 31, 2013 should provide for limited disposal problems. Sincerely, Jim T Criswell Pesticide Coordinator