Comment submitted by Rajendra Sundaresan, Executive Director, All India Rice Exporters Association

The following is a letter of support for a Tricyclazole import tolerance on rice submitted to the open comment period for docket Tricyclazole Import Tolerance, PP 2E8114 (EPA-HQ-OPP-2012-0903), FR Date January 16, 2013, pg 3378. As an association comprising over 110 members who collectively account for over 90 percent of India’s rice exports, we express our strong support to the said petition filed By Dow AgroSciences for the establishment of a 3.0 ppm tolerance for residues of the pesticide “Tricyclazole” in/on rice. Tricyclazole is a pesticide used to combat a disease known as blast which is found only in rice. Blast disease manifests initially as leaf blast and subsequently as neck blast and quite devastative in nature and has the potential of decimating almost the entire seasonal crop, if left unprotected. Keeping in mind the Agro-climatic and socio-economic conditions prevalent in the Indian subcontinent, Tricyclazole has proven to be extremely effective fungicide in combating blast disease in rice and is a widely used fungicide. Tricyclazole has been found to be a safe pesticide as can be seen from the MRL’s been granted by various countries in the table below. Country MRL Japan 3 Thailand 3 EU 1 China 2 The Asian countries mentioned in the above list have rice as their staple diet and consume far more rice per capita than the USA. After decades of rice consumption and scores of tests conducted by these countries, the grant of an MRL above 2PPM and as much as 3PPM in Japan and Thailand can be construed as proof enough enough that Tricyclazole is indeed a safe pesticide and residues upto 3PPM are acceptable. Furthermore, it may be noted that the MRL is sanctioned for raw milled rice and not for the final product which is obtained after cooking and steaming. A substantial amount of the residues are degraded when cooked and this further reduces the level in the cooked rice.