UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

OFFICE  OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

PC Code: 059201

DP Barcode: D296581

Date:  February 2, 2006

MEMORANDUM

SUBJECT:	Comparison of Currently Supported Phosmet Use Rates to those Assessed Previously

TO:		Diane Isbell,, Risk Manager Reviewer

Special Review and Reregistration Division

FROM:	Thomas M. Steeger, PhD, Senior Biologist

Environmental Risk Branch IV

Environmental Fate and Effects Division (7507c)

APPROVED

BY:	Elizabeth Behl, Branch Chief

Environmental Risk Branch IV

Environmental Fate and Effects Division

The Environmental Fate and Effects Division (EFED) has completed its comparison of the currently supported use rates for phosmet to those originally assessed in the Environmental Fate and Ecological Risk Assessment chapter (D188325; dated 4/28/98) in support of the reregistration eligibility decision for phosmet.  Although the label modifications may have changed estimated environmental concentrations to some extent, they do not result in substantial changes to the overall risks estimated.  Currently supported use rates for phosmet will likely exceed acute risk levels of concern (RQ(0.05) for aquatic animals by factors ranging from 1 to 1,400x and will exceed the chronic risk level of concern (RQ(1.0) for aquatic animals by factors ranging from 1 to 10X.  For terrestrial animals, currently supported uses will exceed acute risk levels of concern (RQ(0.1) by factors ranging from 1 to 24X for birds and 1 to 46X for mammals.  The chronic risk level of concern (RQ(1.0) will be exceeded by factors ranging from 1 to 20X for birds and from 1 to 60X for mammals based on maximum residues.

As noted in an email dated 1/12/06, Table 1 illustrates that currently supported use rates are relatively consistent with those previously assessed except for phosmet use on grapes, peaches, pears and plums.  For grapes, the original assessment used 4 applications of 1.5 lbs a.i./A with a 20-day reapplication period; the currently supported use calls for 3 applications of 1.5 lbs a.i./A with a considerably shorter reapplication interval, i.e., 7 days.  Also for use of phosmet on grapes, the original chapter did not assess the current rate of 4 applications of 1.0 lb a.i./A with a 7-day reapplication interval.  For use on peaches, the original chapter relied on a reapplication interval of 7 days while the supported use calls for a longer (10-day) reapplication interval.  For pears, the original chapter assessed an maximum application rate of 5 lbs a.i./A (3 applications with a 21-day reapplication interval) while the currently supported maximum rate is lower, i.e., 4 lbs a.i./A (3 applications with a 21-day reapplication interval).  Finally, for plums/prunes, the original chapter assessed 5 applications of 3 lbs a.i./A with a 14-day reapplication interval while the current supported use calls for a lower number of applications (3) of 3 lbs a.i./A with the same reapplication interval.

Table 1.  Comparison of most recent supported  application rates to those initially assessed in the environmental fate and ecological risk assessment in support of the reregistration eligibility decision on phosmet (DP Barcode D188325).

Most Recent

Use

Application Rate

lbs a.i./A

(No. App / Reapplication Interval)

Original Assessment

Application Rate

lbs a.i./A

(No. App / Reapplication Interval)

Apples (Eastern)

1.5 lbs a.i./A

(10 / 7)

1.5

(10 / 7)

Apples (Western)

4.0 lbs a.i./A

(5 / 7)

4.0

(5 / 7)

Apricots, Nectarines

3.0 lbs a.i./A

(3 / 7)

not assessed

Blueberries

1.0 lbs a.i./A

(5 / 7)

1.0

(5 / 7)

Grapes

1.5 lbs a.i./A

(3 / 7)

1.5

(4 / 20)

Grapes

1.0 lb a.i./A

(4 / 7)

lower rate not assessed

Peaches

3 lbs a.i./A

(4 / 10)

3

(4 / 7)

Pears

4 lbs a.i./A

(3 / 21)

5

(3 / 21)

Plums / Prunes

3.0 lbs a.i./A

(3 / 14)

3

(5 / 14)

Original risk quotients (RQs) for both freshwater and estuarine/marine invertebrates are reported in Table 2 (estuarine/marine invertebrate RQs have been corrected to reflect an acute LC50 value of 1.6 µg/L).  Estimated environmental concentrations used to generate RQ values would not change for use rates that have remained the same.   Except for the use on grapes, currently supported uses are either the same or involve lower application rates, in terms of lbs a.i. applied or frequency of application, than those assessed previously and aquatic exposure estimates resulting from these reduced loadings would be lower.  For use on grapes, the frequency of application has increased from 20 to 7 days; however, the total number of applications per season has decreased from 4 to 3.  The effects of these changes on estimated environmental concentrations are uncertain; however, in situations (e.g. acute and chronic risks to invertebrates) where the levels of concern are exceeded by large margins, the most recent reductions will not substantially change the estimated risks.

Table 2.  Summary of acute and chronic risk quotients for freshwater and estuarine/marine fish and invertebrates based on original ecological risk assessment for phosmet (dated 4/18/98).  Estuarine/marine invertebrate RQ values are corrected to reflect acute LC50=1.6 µg/L.  RQ values exceeding acute or chronic risk levels of concern are highlighted.

Crop

App. Rate (lbs ai/A), App. No. (Days)

Organism

Freshwater

Acute RQ

(EEC/LC50)5

Freshwater

Chronic RQ6

(EEC/NOEC)

Estuarine/marineAcute RQ

(EEC/LC50)5

Estuarine/marineChronic RQ

(EEC/NOEC)6

Apples (Eastern Low)

1.5(10)

Fish

0.22xx

0.09

0.09x

0.13

Invertebrates

7.8xxx

0.80

10xxx

1.62+

Apples (Western High)

4(5)

Fish

0.16xx

0.15

0.06x

0.21

Invertebrates

5.6xxx

1.07+

7.0xxx

2.16+

Berries

1(5)

Fish

0.17xx

0.06

0.07x

0.08

Invertebrates

5.9xxx

0.53

7.4xxx

1.08+

Grapes

1.5(4)

Fish

0.27xx

0.19

0.11xx

0.25

Invertebrate

9.4xxx

1.3+

11.7xxx

2.70+

Peaches–High

3(4)

Fish

0.23xx

0.16

0.1xx

0.21

Invertebrate

8.1xxx

1.33+

10xxx

2.70+

Pears

5(3)

Fish

2.0xxx

1.13+

0.8xxx

1.52+

Invertebrate

70xxx

4.9+

88xxx

10+

Plums/Prunes

3(5)

Fish

0.12xx

0.13

0.05x

0.17

Invertebrate

4.2xxx

0.53

5.3xxx

1.08+

1) Bluegill sunfish LC50 = 70 ppb; Gammarus fasciatus LC50 = 2.0 ppb;Sheepshead minnow LC50 = 170 ppb; Mysid shrimp LC50 = 1.6 ppb.

2) Rainbowtrout NOEC = 3.2 ppb; Daphnia NOEC = 0.75 ppb; Since a NOEC for marine fish was not available, an extrapolation was calculated based on the rainbow  trout chronic to acute ratio.  Acute values for rainbow trout were calculated at 250 ppb (150 - 350 ppb ) and the NOEC at 4.4 ppb, while the marine/estuarine fish, sheepshead minnow, had an LC50 of 170 ppb.  Since the sheepshead minnow acute toxicity value is within the rainbow trout 95% confidance interval, a NOEC of 2.36 ppb was calculated for marine fish.

3) Peak EEC values derived through PRZM/EXAMS modeling.

4) For each crop, two PRZM/EXAMS EEC values are provided: the upper value reprsents the 60-day EEC value used in calculating chronic RQ values for fish; the lower value represents the 21-day EEC value used in calculating chronic RQ values for invertebrates.

5) Acute RQ values were calculated by dividing the peak EEC by the LC50.

6) Chronic RQ values for fish were calculated by dividing the 60-day EEC by the NOEC; chronic  RQ  values for invertebrates were calculated by dividing the 21-day EEC by the NOEC.

* exceeds acute risk level of concern (RQ(0.5), restricted use level of concern (RQ(0.1) and acute risk to endangered species level of concern (RQ(0.05).

** exceeds restricted use level of concern (RQ(0.1) and acute risk to endangered species level of concern (RQ(0.05).

***exceeds acute risk to endangered species level of concern (RQ(0.05).

A refined assessment of estimated environmental concentrations was conducted for salmonids in the Pacific Northwest (DP Barcode D296583; Attachment 1).  These aquatic exposure estimates (Attachment Table 1.1) are lower than those contained in the RED although similar application rates were used to derive them.  Different input parameters to the pesticide root zone model (PRZM) account for the change in estimated environmental concentrations.  However, even using refined estimated environmental concentrations, risk quotients still exceed acute and chronic risk levels of concern (Attachment Table 1.2).

As noted in an email dated 1/02/06, terrestrial risk quotients were re-evaluated using the most recent estimates of supported use rates on nine food crops.  Table 3 summarizes the number of uses exceeding acute and chronic risk levels of concern (LOC) and the range of risk quotient (RQ) values.  For terrestrial animals, acute and chronic risk quotients are exceeded across all of the uses evaluated.  A more thorough discussion of the avian and mammalian risk quotients follows.

Table 3.  Summary of acute and chronic risk quotients (RQ) and number of uses exceeding acute and chronic risk levels of concerns (LOC) for the food uses of phosmet based on current use rates.

ENDPOINT	 ADVANCE \d6 LOC Summary (acute high risk)	 ADVANCE \d6 LOC Summary (chronic risk)

	 ADVANCE \d6 ACUTE	 ADVANCE \d6 CHRONIC

 ADVANCE \d6 Freshwater fish	 ADVANCE \d6 1/9 uses exceed

(Pear RQ=2.0)  	 ADVANCE \d6 1 use exceeds (pears)

RQ = 1.13

 ADVANCE \d6 Freshwater invertebrate	 ADVANCE \d6 9/9 uses exceed

(RQ range: 4.2 - 70)	 ADVANCE \d6 5/9 uses exceed

(RQ range: 1.07 - 4.9)

 ADVANCE \d6 estuarine/marine fish	 ADVANCE \d6 1/9 uses exceed

(RQ=0.8)	 ADVANCE \d6 1/9 exceed (pears)

(RQ=1.5)

 ADVANCE \d6 estuarine/marine invertebrate	 ADVANCE \d6 9/9 exceed

(RQ range: 5.3 - 88)*	 ADVANCE \d6 9/9 exceed

(RQ range: 1.08 - 10)

 ADVANCE \d6 bird	 ADVANCE \d6 9/9 exceed

(RQ range: 0.04 - 2.4) 	 ADVANCE \d6 9/9 exceed

(RQ range: 0.15 - 20)

 ADVANCE \d6 mammal (small mammals feeding on short grasses)	 ADVANCE \d6 9/9 exceed

(RQ range: 0.01 - 4.6)	 ADVANCE \d6 9/9 exceed

(RQ range: 0.44 - 60)

 ADVANCE \d6 plant	 ADVANCE \d6 	not evaluated	 ADVANCE \d6

not evaluated

Acute and chronic risk quotients (RQ) were re-evaluated using the most recent use rates for phosmet on food crops (Table 4).  Acute RQ values exceed the acute risk level of concern (LOC) (RQ(0.5) for birds feeding on short grasses (RQ range: 0.60 - 2.4) across all of the uses evaluated.  The acute risk to endangered species LOC (RQ(0.1) is exceeded across all of the uses evaluated for birds feeding on all forage categories except seeds.  For birds foraging on seeds, the acute endangered species LOC is exceeded for western apples (RQ=0.15), pears (RQ=0.12), apricots/nectarines (RQ=0.11) and peaches (RQ=0.10).  These results are relatively consistent with the original assessment in which all of the uses evaluated exceeded acute  risk levels of concern for birds.

Based on maximum phosmet residues on forage items, the chronic risk LOC (RQ(1.0) is exceeded for birds across all uses and forage categories except seeds (RQ range: 1.3 - 20) (Table 5).  Only one use, i.e., pears (RQ=1.0), exceeded the chronic risk LOC for birds feeding on seeds.  Based on mean residues, the chronic risk LOC is exceeded across all uses except blueberries and grapes for birds feeding on short and tall grasses (RQ range: 1.1 - 7.1).   These results are similar to previous assessment in which all of the uses evaluated exceeded the chronic risk level of concern for birds.

Based on dose-based RQ values, the acute risk LOC is exceeded across all of the uses evaluated for all-sized mammals (15 g, 35 g, and 1000 g) foraging on short grasses (RQ range: 0.78 - 4.6) (Table 46).  The acute risk to endangered species LOC is exceeded for all-sized mammals (RQ range: 0.30 - 4.6) feeding on any of the forage items evaluated other than fruits/pods/large insects and seeds.  For all uses except blueberries and grapes, the acute risk to endangered species LOC is exceeded for small mammals feeding on fruits/pods and large insects.  None of the uses evaluated exceeded the acute risk LOC to endangered species for any size mammal feeding on seeds.  These results are relatively consistent with the original assessment in which all of the uses evaluated exceeded acute  risk levels of concern for mammals.

Based on maximum residues, the chronic risk LOC is exceeded across all of the uses except blueberries and grapes for mammals feeding on any of the forage categories evaluated (RQ range: 1.4 - 60) (Table 7).  For blueberries and grapes (1.0 lb a.i./A), the chronic risk LOC is exceeded for mammals feeding on any of the forage categories except for fruits/pods/seeds and large insects.  Based on mean residues, the chronic risk LOC is exceeded across all of the uses evaluated except blueberries, grapes (both application rates) and forage categories (RQ range: 1.1 - 21).  Using mean residues following application to either grapes or blueberries, the chronic risk LOC is exceed for mammals feeding  on any of the forage categories except fruits, pods, seeds and large insects. .   These results are similar to previous assessment in which all of the uses evaluated exceeded the chronic risk level of concern for mammals.

Table 4.  Acute avian risk quotientsd calculated using an exposure value based on maximum phosmet residues on forage items following multiple applications and a subacute dietary toxicity value based on a bobwhite quail LC50 of 501 mg/kg of diet.  Risk quotients exceeding acute risk levels of concern are highlighted.

Use

Application Rate

lbs a.i./A

(No. App / Reapplication Interval)

Food Items

Maximum EEC (mg/kg)a

LC50

Maximum

RQ

Apples (Eastern)

1.5 lbs a.i./A

(10 / 7)

Short grass

449

501

0.90a

Tall grass

206

501

0.41b

Broadleaf plants/small insects

253

501

0.50a

Fruits, pods, seeds, and large insects

28

501

0.06

Apples (Western)

4.0 lbs a.i./A

(5 / 7)

Short grass

1197

501

2.4a

Tall grass

549

501

1.1a

Broadleaf plants/small insects

673

501

1.3a

Fruits, pods, seeds, and large insects

75

501

0.15c

Apricots, Nectarines

3.0 lbs a.i./A

(3 / 7)

Short grass

891

501

1.8a

Tall grass

408

501

0.82a

Broadleaf plants/small insects

501

501

1.0a

Fruits, pods, seeds, and large insects

56

501

0.11c

Blueberries

1.0 lbs a.i./A

(5 / 7)

Short grass

299

501

0.60a

Tall grass

137

501

0.27b

Broadleaf plants/small insects

168

501

0.34b

Fruits, pods, seeds, and large insects

19

501

0.04

Grapes

1.5 lbs a.i./A

(3 / 7)

Short grass

446

501

0.89a

Tall grass

204

501

0.41b

Broadleaf plants/small insects

251

501

0.51a

Fruits, pods, seeds, and large insects

28

501

0.06

Grapes

1.0 lb a.i./A

(4 / 7)

Short grass

299

501

0.60a

Tall grass

137

501

0.27b

Broadleaf plants/small insects

168

501

0.34b

Fruits, pods, seeds, and large insects

19

501

0.04

Peaches

3 lbs a.i./A

(4 / 10)

Short grass

799

501

1.6a

Tall grass

366

501

0.73a

Broadleaf plants/small insects

450

501

0.90a

Fruits, pods, seeds, and large insects

50

501

0.10c

Pears

4 lbs a.i./A

(3 / 21)

Short grass

968

501

1.9a

Tall grass

443

501

0.89a

Broadleaf plants/small insects

544

501

1.1a

Fruits, pods, seeds, and large insects

60

501

0.12c

Plums / Prunes

3.0 lbs a.i./A

(3 / 14)

Short grass

749

501

1.5a

Tall grass

344

501

0.69a

Broadleaf plants/small insects

422

501

0.84a

Fruits, pods, seeds, and large insects

47

501

0.09

a Exceeds acute risk (RQ(0.5), acute restricted use (RQ(0.2) and acute endangered species (RQ(0.1) levels of concern.

b Exceeds acute restricted use (RQ(0.2) and acute endangered species (RQ(0.1) levels of concern.

c Exceeds acute endangered species (RQ(0.1) levels of concern..

d Risk quotient = EEC ( LC50.

Table 5. Chronic avian risk quotients calculated using exposure values based on maximum and mean phosmet residues on forage items and a bobwhite quail NOAEC of 60 mg/kg diet.  RQ values exceeding chronic risk level of concern highlighted.

Use

Application Rate

(#/year / interval)

Food Items

Maximum EEC (mg/kg)a

Mean EEC

(mg/kg)

NOAEC

Maximum

RQ

Mean

RQ

Apples (Eastern)

1.5 lbs a.i./A

(10 / 7)

Short grass

449

159

60

7.5a

2.7a

Tall grass

206

67

60

3.4a

1.1a

Broadleaf plants/small insects

253

84

60

4.2a

1.4a

Fruits, pods, seeds, and large insects

28

13

60

0.47

0.22

Apples (Western)

4.0 lbs a.i./A

(5 / 7)

Short grass

1197

424

60

20a

7.1a

Tall grass

549

180

60

1.1a

3.0a

Broadleaf plants/small insects

673

224

60

1.3a

3.7a

Fruits, pods, seeds, and large insects

75

35

60

0.15

0.58

Apricots, Nectarines

3.0 lbs a.i./A

(3 / 7)

Short grass

891

316

60

15a

5.3a

Tall grass

408

134

60

6.8a

2.2a

Broadleaf plants/small insects

501

167

60

8.4a

2.8a

Fruits, pods, seeds, and large insects

56

26

60

0.93

0.43

Blueberries

1.0 lbs a.i./A

(5 / 7)

Short grass

299

106

60

5.0a

1.8a

Tall grass

137

45

60

2.3a

0.75

Broadleaf plants/small insects

168

56

60

2.8a

0.94

Fruits, pods, seeds, and large insects

19

8.7

60

0.31

0.15

Grapes

1.5 lbs a.i./A

(3 / 7)

Short grass

446

158

60

7.4a

2.6a

Tall grass

204

67

60

3.4a

1.1a

Broadleaf plants/small insects

251

84

60

4.2a

1.4a

Fruits, pods, seeds, and large insects

28

13

60

0.46

0.22

Grapes

1.0 lb a.i./A

(4 / 7)

Short grass

299

106

60

5.0a

1.8a

Tall grass

137

45

60

2.3a

0.75

Broadleaf plants/small insects

168

56

60

2.8a

0.93

Fruits, pods, seeds, and large insects

19

8.7

60

0.31

0.15

Peaches

3 lbs a.i./A

(4 / 10)

Short grass

799

283

60

13a

4.7a

Tall grass

366

120

60

6.1a

2.0a

Broadleaf plants/small insects

450

150

60

7.5a

2.5a

Fruits, pods, seeds, and large insects

50

23

60

0.83

0.39

Pears

4 lbs a.i./A

(3 / 21)

Short grass

968

343

60

16a

5.7a

Tall grass

443

145

60

7.4a

2.4a

Broadleaf plants/small insects

544

181

60

9.1a

3.0a

Fruits, pods, seeds, and large insects

60

28

60

1.0a

0.47

Plums / Prunes

3.0 lbs a.i./A

(3 / 14)

Short grass

749

265

60

12a

4.4a

Tall grass

344

112

60

5.7a

1.9a

Broadleaf plants/small insects

422

141

60

7.0a

2.3a

Fruits, pods, seeds, and large insects

47

22

60

0.78

0.36

a Exceeds chronic risk level of concern (RQ(1.0)

Table 6.  Mammalian acute dose-based risk quotients following repeated applications of phosmet during one growing season and based on a rat acute oral LD50 of 113 mg/kg.  Risk quotients exceeding acute risk levels of concern are highlighted.

Use

Application Rate

(# appls./ interval in days)

Body Weight, g

Mammalian Acute Risk Quotients

Short Grass

Tall Grass

Broadleaf Plants/Small Insects

Fruits/pods/

large insects

Seeds

Apples (Eastern)

1.5 lbs a.i./A

(10 / 7)

15

1.7a

0.79a

0.97a

0.11c

0.02

35

1.5a

0.68a

0.83a

0.09

0.02

1000

0.79a

0.36b

0.44b

0.05

0.01

Apples (Western)

4.0 lbs a.i./A

(5 / 7)

15

4.6a

2.1a

2.6a

0.29b

0.06

35

3.9a

1.8a

2.2a

0.25b

0.05

1000

2.1a

0.96a

1.2a

0.13c

0.03

Apricots, Nectarines

3.0 lbs a.i./A

(3 / 7)

15

3.4a

1.6a

1.9a

0.21b

0.05

35

2.9a

1.3a

1.6a

0.18

0.04

1000

1.6a

0.72a

0.88a

0.10c

0.02

Blueberries

1.0 lbs a.i./A

(5 / 7)

15

1.2a

0.53a

0.65a

0.07

0.02

35

0.98a

0.45b

0.55a

0.06

0.01

1000

0.53a

0.24b

0.30b

0.03

0.01

Grapes

1.5 lbs a.i./A

(3 / 7)

15

1.7a

0.78a

0.96a

0.11c

0.02

35

1.5a

0.67a

0.82a

0.09

0.02

1000

0.78a

0.36b

0.44b

0.05

0.01

Grapes

1.0 lb a.i./A

(4 / 7)

15

1.2a

0.53a

0.65a

0.07

0.02

35

0.98a

0.45b

0.55a

0.06

0.01

1000

0.53a

0.24b

0.30b

0.03

0.01

Peaches

3 lbs a.i./A

(4 / 10)

15

3.1a

1.4a

1.7a

0.19c

0.04

35

2.6a

1.2a

1.5a

0.16c

0.04

1000

1.4a

0.64a

0.79a

0.09

0.02

Pears

4 lbs a.i./A

(3 / 21)

15

3.7a

1.7a

2.1a

0.23b

0.05

35

3.2a

1.5a

1.8a

0.20b

0.04

1000

1.7a

0.78a

0.96a

0.11c

0.02

Plums / Prunes

3.0 lbs a.i./A

(3 / 14)

15

2.9a

1.3a

1.6a

0.18c

0.04

35

2.5a

1.1a

1.4a

0.15c

0.03

1000

1.3a

0.60a

0.74a

0.08

0.02

a Exceeds acute risk (RQ(0.5), acute restricted use (RQ(0.2) and acute endangered species (RQ(0.1) levels of concern.

b Exceeds acute restricted use (RQ(0.2) and acute endangered species (RQ(0.1) levels of concern.

c Exceeds acute endangered species (RQ(0.1) levels of concern..

d Risk quotient = EEC ( LC50.

Table 7. Chronic mammalian risk quotients calculated using exposure values based on maximum and mean phosmet residues on forage items and a rat NOAEC of 20 mg/kg diet.  RQ values exceeding chronic risk level of concern highlighted.

Use

Application Rate

lbs a.i./A

(No. App / Reapplication Interval)

Food Items

Maximum EEC (mg/kg)a

Mean

EEC

(mg/kg)

Maximum

RQ

Mean

RQ

Apples (Eastern)

1.5 lbs a.i./A

(10 / 7)

Short grass

449

159

22a

8.0a

Tall grass

206

67

10a

3.4a

Broadleaf plants/small insects

253

84

13a

4.2a

Fruits, pods, seeds, and large insects

28

13

1.4a

0.65

Apples (Western)

4.0 lbs a.i./A

(5 / 7)

Short grass

1197

424

60a

21a

Tall grass

549

180

27a

9.0a

Broadleaf plants/small insects

673

224

34a

11a

Fruits, pods, seeds, and large insects

75

35

3.7a

1.8a

Apricots, Nectarines

3.0 lbs a.i./A

(3 / 7)

Short grass

891

316

45a

16a

Tall grass

408

134

20a

6.7a

Broadleaf plants/small insects

501

167

25a

8.4a

Fruits, pods, seeds, and large insects

56

26

2.8a

1.3a

Blueberries

1.0 lbs a.i./A

(5 / 7)

Short grass

299

106

15a

5.3a

Tall grass

137

45

6.9a

2.2a

Broadleaf plants/small insects

168

56

8.4a

2.8a

Fruits, pods, seeds, and large insects

19

8.7

0.94

0.44

Grapes

1.5 lbs a.i./A

(3 / 7)

Short grass

446

158

22a

7.9a

Tall grass

204

67

10a

3.3a

Broadleaf plants/small insects

251

84

13a

4.2a

Fruits, pods, seeds, and large insects

28

13

1.4a

0.65

Grapes

1.0 lb a.i./A

(4 / 7)

Short grass

299

106

15a

5.3a

Tall grass

137

45

6.9a

2.2a

Broadleaf plants/small insects

168

56

8.4a

2.8a

Fruits, pods, seeds, and large insects

19

8.7

0.93

0.44

Peaches

3 lbs a.i./A

(4 / 10)

Short grass

799

283

40a

14a

Tall grass

366

120

18a

6.0a

Broadleaf plants/small insects

450

150

22a

7.5a

Fruits, pods, seeds, and large insects

50

23

2.5a

1.2a

Pears

4 lbs a.i./A

(3 / 21)

Short grass

968

343

48a

17a

Tall grass

443

145

22a

7.3a

Broadleaf plants/small insects

544

181

27a

9.1a

Fruits, pods, seeds, and large insects

60

28

3.0a

1.4

Plums / Prunes

3.0 lbs a.i./A

(3 / 14)

Short grass

749

265

37a

13a

Tall grass

343

112

17a

5.6a

Broadleaf plants/small insects

422

141

21a

7.0a

Fruits, pods, seeds, and large insects

47

22

2.3a

1.1a

a Exceeds chronic risk level of concern (RQ(1.0)

Attachment 1. Revised Tier 2 EEC’s for Phosmet in Support of Reassessment of Endangered Species Assessments for Salmonids in the Northwestern United States

Table 1.1 Tier 2 one-in-ten year EEC's for phosmet as applied three crops in the northwestern United States. EEC’s are for the maximum application practice allowed on the label except for typical apples where the application practice is intended to represent a central tendency in actual application practice.

Crop

Maximum

4 Day

21 Day

60 Day

90 Day

apples - high*

μg (L-1

1.6μg (L-1

0.84μg (L-1

0.48μg (L-1

0.32μg (L-1

apples - low*

14.0μg (L-1

2.1μg (L-1

0.45μg (L-1

039μg (L-1

0.26μg (L-1

kiwis - maximum

 19.7 μg (L-1

3.2 μg (L-1

0.83 μg (L-1

0.29 μg (L-1

0.19 μg (L-1

pears - maximum

14.0 μg (L-1

2.1 μg (L-1

0.45 μg (L-1

0.39 μg (L-1

0.26 μg (L-1

* The high apple application rate refers to a higher single application rate with 4 lb acre-1 five times at 7 day intervals. The low application practice is 1.5 lb acre-1 applied ten times at 7 day intervals.

Table 1.2.  Summary of acute and chronic risk quotients for freshwater and estuarine/marine fish and invertebrates based on refined estimated environmental concentrations used for Pacific Northwest salmonid risk assessment.  Estuarine/marine invertebrate RQ values are corrected to reflect acute LC50=1.6 µg/L.  RQ values exceeding acute or chronic risk levels of concern are highlighted.

Crop

App. Rate (lbs ai/A), App. No. (Days)

Organism

Freshwater

Acute RQ

(EEC/LC50)5

Freshwater

Chronic RQ6

(EEC/NOEC)

Estuarine/marineAcute RQ

(EEC/LC50)5

Estuarine/marineChronic RQ

(EEC/NOEC)6

Apples (Eastern Low)

1.5(10)

Fish

0.20**

0.12

0.08***

0.02

Invertebrates

7.0*

0.6

8.8*

1.2

Apples (Western High)

4(5)

Fish

0.16**

0.15

0.07***

0.20

Invertebrates

5.6*

1.1

7.0*

2.3

Pears

5(3)

Fish

0.20**

0.12

0.08***

0.16

Invertebrates

7.0*

0.6

8.8*

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 0.1) and acute risk to endangered species level of concern (RQ(0.05).

** exceeds restricted use level of concern (RQ(0.1) and acute risk to endangered species level of concern (RQ(0.05).

***exceeds acute risk to endangered species level of concern (RQ(0.05).

((((( PAGE  13 ((((( NUMPAGES  2


Fludioxonil (071503)

Screening Level Usage Analysis (SLUA)

Date: August 12, 2010

What is a Screening Level Usage Analysis (SLUA)?

Available estimates of pesticide usage data for a particular active
ingredient that is used on agricultural crops in the United States.

Pesticide usage data obtained from various sources.  The data are then
merged, averaged, and rounded so that the presented information is not
proprietary, business confidential, or trade secret.

What does it contain?

Pesticide usage data for a single active ingredient only.

Agricultural use sites (crops) that the pesticide is reported to be used
on.

Available pesticide usage information from U.S. states that produce 80%
or more of a crop, in most cases, or less than 80%, in rare cases,
depending on the scope of the survey and available resources.

Annual percent of crop treated (average & maximum) for each agricultural
crop.

Average annual pounds of the pesticide applied for each agricultural
crop (i.e., for the states surveyed, not for the entire United States).

What assumptions can I make about the reported data?

Average pounds of active ingredient applied - Values are calculated by
merging pesticide usage data sources together; averaging across all
observations, then rounding.  Note:  If the estimated value is less than
500, then that value is labeled <500.  Estimated values between 500 &
<1,000,000 are rounded to 1 significant digit.  Estimated values of
1,000,000 or greater are rounded to 2 significant digits.)

Average percent of crop treated - Values are calculated by merging data
sources together; averaging by year, averaging across all years, &
rounding to the nearest multiple of 5.  Note:  If the estimated value is
less than 2.5, then the value is labeled <2.5.  If the estimated value
is less than 1, then the value is labeled <1.

Maximum percent of crop treated - Value is the single maximum value
reported across all data sources, across all years, & rounded up to the
nearest multiple of 5.  Note:  If the estimated value is less than 2.5,
then the value is labeled <2.5.

What are the data sources used?

USDA-NASS (United States Department of Agriculture’s National
Agricultural Statistics Service) – pesticide usage data from 2001 to
2008.

Private pesticide market research – pesticide usage data from 2001 to
2008.

NPUD 2002 (National Pesticide Use Database) pesticide usage data from
the CropLife America Foundation are used only if data are not available
from the other sources.

California Department of Pesticide Regulation (DPR) Pesticide Use
Reporting (PUR) data for 2000 to 2008.

What are the limitations to the data?

Additional registered uses may exist but are not included because the
available surveys do not report usage (e.g., small acreage crops).

Lack of reported usage data for the pesticide on a crop does not imply
zero usage.

Usage data on a particular site may be noted in data sources, but not
quantified.  In these instances, the site would not be reported in the
SLUA.

Non-agricultural use sites (e.g., turf, post-harvest, mosquito control,
etc.) are not reported in the SLUA.  A separate request must be made to
receive these estimates.

Some sites show some use, even though they are not on the label.  This
usage could be due to various factors, including, but not limited to
Section 18 requests, existing stocks of the chemical, data collection
errors, and experimental use permits (EUPs).

Thursday, August 12, 2010

Screening Level Estimates of Agricultural Uses of Fludioxonil (071503)

Sorted Alphabetically

	Percent Crop Ttd.

				Crop	Lbs. A.I.	Avg.	Max.

1	Apples	<500	<1	<2.5

2	Beans, Green	<500	<1	<2.5

3	Blueberries	<500	5	10

4	Caneberries	4,000	55	85

5	Cotton	1,000	20	25

6	Cucumbers	2,000	<2.5	5

7	Lettuce	1,000	<1	<2.5

8	Onions	<500	<1	<2.5

9	Pistachios	<500	<2.5	5

10	Soybeans	20,000	10	15

11	Strawberries	5,000	25	50

All numbers rounded.

<500	Less than 500 pounds of active ingredient

<2.5	Less than 2.5 percent of crop treated

<1	Less than 1 percent of crop treated

SLUA data sources include:

USDA-NASS (United States Department of Agriculture's National
Agricultural Statistics Service)

Private Pesticide Market Research

These results reflect amalgamated data developed by the Agency and are
releasable to the public.