Comment submitted by Luis Castro, Gowan Company

GOWAN COMPANY RESPONSE ON PROPOSED TOLERANCES ACTIONS FOR EPTC (Docket No. EPA-HQ-OPP-2010-0262) Gowan Company thanks the Agency for this opportunity to comment on the proposed changes to tolerances for S-Ethyl dipropylthiocarbamate (EPTC). The changes proposed are consistent with the current uses of EPTC except for a special use which arose recently for carrots in CA. Growers in CA identified a critical need for suppression of nutsedge and groundsel weeds that still exists. Based on that need, Gowan Company developed data for residues in or on carrots treated with EPTC to support a Special Local Need in CA. The California Department of Pesticide Regulation (CDPR) reviewed this data and granted SLN CA-080024 based on its compliance with the existing root crop tolerance [Vegetable, root… 0.1 (N)]. The data demonstrated that EPTC residues did not exceed the established tolerance for that crop group. We respectfully request that EPA delay its proposed action on the established root vegetable tolerance until the Agency has reviewed the residue data and established a carrot tolerance for EPTC at the current Vegetable, root level of 0.1 (N), as appropriate. Since the tolerance for the crop group already exists and the carrot-specific residue data supports that level, this action could be expedited. Gowan Company proposes to submit the residue data for EPTC on carrots by Friday, July 30, 2010. Please do not hesitate to contact Luis Castro at (928) 819-1569 or lcastro@gowanco.com to discuss this issue.