Comments on Malathion Use in Florida
General Comments
Florida supports ONE Restricted Use Interval (REI) for each active ingredient. The current REI of 12 hours is the most appropriate for numerous reasons. However, since none of the proposed REI’s are less than one day, it would seem that the REI could be harmonized at one or two days (two days at the most). Any REI greater than two days would basically omit malathion from selection as a potential tool. It would also be beneficial to see REI and PHI’s harmonized so that no PHI is less than an REI.
It is also noted that the table presents maximum number of applications per year. For
Florida, this must be season or crop for all crops other than tree crops or grass/pasture.
Specific Comments
Avocado – State collected information indicates that malathion is used up to two times a year and we would request this as the maximum number of applications. Other considerations are not problematic.
Broccoli (All types) – OK
Cabbage (both types) – Based on Extension queries, six applications is more appropriate than two, and we would request this as the maximum number of applications per
SEASON. Other considerations are not problematic.
Cantaloupe – OK
Carrot – OK
Celery – suggest a PHI of one day
Chestnut – OK
Collards – OK
Sweet Corn – OK
Cucumber – OK
Eggplant (both types) – OK
Endive – OK

For citrus (grapefruit, kumquat, oranges, tangelos, and tangerines) – Florida does not use malathion except in some ULV applications as noted. If it were to be used as an EC or
WP formulation, the rate would be similar to avocado (4.5 lb ai/A).
Grasses/Forage – OK
Guava – FL tropical fruit growers are constrained immensely by lack of pest management tools for the tropical fruit. Although the average presented is 13, the average for FL is
17. The proposed EPA rate should be 1.25 lb ai/A and at least a dozen applications should be allowed.
Lime – Malathion is used in this citrus crop, but at a greater rate than 1.4. We would request a 4.5 lb ai/A maximum application rate with a maximum number of applications of three.
Mango – As stated for guava, few tools exist for tropical fruit growers. A rate of 4.5 lb ai/A should be considered since this is what is truly needed for mature trees. Small trees would need considerably less material (1.25 lb ai/A). The maximum number of applications should be set at five.
Okra – OK
Papaya – 1.25 lb ai/A is an appropriate rate for this crop. FL survey info. suggests that the maximum number of applications should be four.
Parsley – PHI should be as minimal as possible (two days at most), as well as REI (see general comments).
Passion fruit – The maximum single applications rate and number of applications per year should be the supported values.
Pasture – OK
Pecan – OK
Pepper – OK
Potato – OK
Radish – OK
Rice – OK
Squash – OK

Strawberry – OK, Aerial OK to remove – all FL applications done with ground equipment.
Sweet potato – OK
Tomato – OK
Watercress – OK
Watermelon – EPA’s proposed values are QUITE a departure from what is supported.
FL would recommend 1.5 lb ai/A as the maximum single application rate, with the ability to make four applications per SEASON.