Comment submitted by James Scarborough

Re: EPA-HQ-OPP-2026-0331; PP 5E9201; Mancozeb Tolerance on Longan I submit this comment regarding PP 5E9201, which requests establishment of a tolerance for residues of the fungicide mancozeb in or on longan at 15 ppm. EPA’s notice properly identifies this action as a notice of receipt of a pesticide petition, not as a final determination that the requested tolerance should be granted. The supporting document in the docket provides a petitioner-prepared notice-of-filing summary that includes residue chemistry, toxicology, exposure, cumulative-effects, safety-determination, and international-tolerance assertions. That summary is useful, but it should not substitute for EPA’s independent explanation in any final tolerance action. First, EPA should clearly identify or place in the docket the underlying residue-review materials on which any final decision will rely. The petitioner states that this import-tolerance request relies on data reviews from the Joint Meeting on Pesticide Residues and cites JMPR Evaluation 2022, Part 1 — Residues, pages 2153–2192. The petitioner also states that Codex has established an MRL for mancozeb on longan at 15 ppm. If EPA grants the requested tolerance, EPA should explain how the JMPR/Codex residue basis maps onto U.S. statutory requirements under FFDCA section 408, U.S. dietary exposure assumptions, U.S. commodity definitions, import conditions, and U.S. enforcement practice. Second, EPA should clearly distinguish the petitioner’s safety determination from EPA’s own final safety finding. The petitioner summary states that, based on EPA risk assessments dated February 10, 2023, there is reasonable certainty that no harm will result from aggregate exposure to mancozeb residues and ETU from imported longan. Before final action, EPA should either place the relevant EPA risk assessment in the docket or clearly identify where the public can review it, and should explain how that assessment supports the proposed longan tolerance specifically. Third, EPA should provide a transparent ETU analysis. The petitioner identifies ETU as the key metabolite of concern for mancozeb and describes ETU as a probable human carcinogen for risk-assessment purposes. The summary also reports food and drinking-water exposure estimates for ETU, including a chronic dietary estimate for infants under one year old at 77 percent of the cPAD. That figure may remain below EPA’s level of concern, but it is high enough that EPA should explain the assumptions, exposure pathways, population subgroups, drinking-water inputs, import-volume assumptions, and uncertainty treatment supporting the final conclusion. Fourth, EPA should explain its treatment of the FQPA safety factor for infants and children. The petitioner summary states that no additional FQPA safety factors were applied to either mancozeb or ETU to account for increased susceptibility to infants and children. If EPA adopts that conclusion, it should provide the basis for doing so, including how the Agency evaluated developmental, thyroid, neurotoxicity, and ETU-related concerns in relation to infants and children. Fifth, EPA should explain the enforcement method for longan. The petitioner summary states that the residue of concern for tolerance enforcement is mancozeb measured as CS2, and that the Keppel colorimetric method is preferred because it determines EBDCs as a group by degradation to CS2. EPA should explain whether the method has been validated for longan specifically, including sensitivity, specificity, matrix interference, and practical import-enforcement use. EPA should also explain how residues will be attributed where the enforcement method measures dithiocarbamates or EBDCs as a group rather than uniquely identifying mancozeb. Finally, EPA should explain whether the requested 15 ppm tolerance should be granted as requested, modified, narrowed, or supported by additional residue or enforcement data before final action. EPA has stated that it has not fully evaluated the sufficiency of the submitted data or whether the data support granting the petition. The final action should therefore show EPA’s independent reasoning, not merely the petitioner’s summary assertions or Codex alignment. I do not object to EPA receiving and reviewing this petition. My request is that EPA ensure any final tolerance rests on a transparent, publicly reviewable record showing the Agency’s own application of the FFDCA reasonable-certainty-of-no-harm standard, including the residue basis, ETU exposure analysis, infant and child safety-factor rationale, and longan-specific enforcement-method support.