Comment submitted by Gene McAvoy, University of Florida

June 15, 2010 Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P) Environmental Protection Agency 1200 Pennsylvania Ave., NW. Washington, DC 20460-0001 Dear Sir/Madam, I am the Regional Vegetable Extension Agent with the University of Florida in SW Florida and am writing in regards to EPA-HQ-OPP-2010-0327 docket concerning the revocation of maneb tolerances. In the Federal Register Notice of April 16, 2010, EPA proposed that all tolerances for this fungicide will be revoked after July 26, 2010 unless the EPA receives significant comments justifying that the tolerances be extended to enable supplies to be exhausted. Many of our growers in Florida especially pepper and lettuce producers have been dependent on copper maneb for the control of bacterial diseases. We have been hopeful that some of the cancelled uses of maneb would have been replaced by mancozeb registrations but this has not happened leaving producers without adequate management tools for bacterial diseases. This has resulted from delays in the registration of new uses of mancozeb which are now expected in September of this year. This has been especially true of bacterial spot on pepper. Many of our growers still have significant existing stocks of maneb and hoped that they would be allowed to use these existing stocks, pending registration of mancozeb or other alternatives, As a result, the revocation of maneb tolerances may result in illegal residues in their products. This lack of control options and cancelling of maneb and not allowing growers to exhaust stocks will pose serious logistical and financial issues to growers. I urge that EPA maintain its April 16, 2010 proposal to allow for the use of existing stocks and to allow for the movement of product through the channels of trade with legal residues. Please feel free to call if you have questions on this matter. Sincerely Gene McAvoy Regional Vegetable Extension Agent IV