Anonymous public comment

Thank you for the opportunity to review this rulemaking and for your continued dedication to rigorous, science-based pesticide regulation. The establishment of these standardized tolerances provides essential certainty for the agricultural and food manufacturing sectors while safeguarding public health. Context: The Agency decided to withdraw separate propylene chlorohydrin (PCH) tolerances, relying instead on a unified PPO tolerance expression (at 300 ppm) that encompasses reaction products. 1. Because PPO is a volatile fumigant that rapidly reacts and dissipates over time in stored commodities like dried spices and seeds, parent PPO levels can drop significantly while reaction products like PCH persist. Inquiry: However, if a food commodity sits in storage, PPO levels might drop to near-zero (because it has fully reacted into PCH), while PCH remains high. If an enforcement inspector tests for PPO and finds nothing, they might miss an underlying high concentration of PCH. The analytical burden shifts entirely to whether the multi-residue enforcement methods can accurately back-calculate PCH back to a meaningful "PPO equivalent. To ensure smooth enforcement and compliance for producers and regulators, could the Agency provide further assurance on the rule on withdrawing PCH tolerance? Can the EPA establish operational guidance on how multi-residue analytical methods will correlate low parent PPO levels with the underlying presence of PCH during inspections? Inquiry: PCH is not uniquely born only from PPO fumigation. PCH can also form as a chemical byproduct in various food manufacturing processes. Have the agency assess cumulative background dietary exposure to PCH from the sum of food manufacturing processes to be within public health limits? 2: PPO’s true toxicity driver is its classification as a B2 Probable Human Carcinogen via inhalation, causing severe nasal and respiratory tissue damage. Workers in spice-processing facilities, fumigation chambers, and manufacturing plants face the real, high-risk inhalation hazard of PPO, but unfortunately this is separated into FIFRA/OSHA regulations rather than being factored into the holistic risk picture of this rule. Unfortunately I am unsure how to proceed with this either, so I am simply presenting as-is without inquiry or action needed by the agency. Summary of Action: 1. could the Agency provide further assurance on the rule on withdrawing PCH tolerance? Can the EPA establish operational guidance on how multi-residue analytical methods will correlate low parent PPO levels with the underlying presence of PCH during inspections? 2. Have the agency assess cumulative background dietary exposure to PCH from the sum of food manufacturing processes to be within public health limits?