Information Requests Monitoring System

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Request ID: 157
Request From: Steve Toth
Date Requested: Jun 01, 2006
Request: Please note the following request for information on aldicarb use on a number of crops. Since comments must be submitted to EPA by July 17, 2006, we need to have them submitted to the Southern Region IPM Center Information Response System by Tuesday, July 11, 2006. Be sure to see the attcahed file. Steve Toth ---------------------------------------------------------------------------- The email address for EPA's Sherrie Kinard is incorrect on the Federal Register Notice. Please send your comments to the EPA Pubic Docket, teung.f.chin@usda.gov AND (not sherrie.kinard@epa.gov). ------------------------------------------------------------------------------------------------------------------------------------------------------ On May 17, EPA released its health effects risk assessment for aldicarb and related documents for a 60-day public comment period. Public comments on the risk assessment must be received by the EPA Public Docket by July 17, 2006 as part of its Reregistration Eligibility Decision (RED) for the pesticide. All the EPA risk assessment documents may be reviewed in the EPA docket under Docket Identification Number "EPA-HQ-OPP-2005-0163" at http://www.regulations.gov . Enter the Docket identification Number into the appropriate space in the "Advanced Search" tab and in the "Docket ID" space. EPA considered the use or proposed use of aldicarb on the following crops: Bananas (proposed imported tolerance) Citrus, Other (includes kumquats, limes, tangelos and tangerines), Grapefruit, Lemons, Oranges, Pecans, Potatoes, Sweet Potatoes, Yams, Beans/Peas, Dry, Beans/Peas, Green, Sorghum, Alfalfa, Peanuts, Soybeans, Sunflower, Cotton, Sugar Beets, Sugarcane, Coffee (imported), and Tobacco. The following benefits information is needed: In what regions (state/county, etc.) of the U.S. is aldicarb use occurring? What is the percent crop treated in the states where aldicarb is used? (this is especially important information for potatoes) What are the pests that aldicarb is critical for controlling? What are the details of typical usage patterns (e.g., number of applications per season, use rate per application, acres treated, and time of application in the season?) What worker activities typically occur when aldicarb is applied? What alternatives, if any, are available to replace aldicarb? Please provide as much detail and documentation in your comments as possible so that the Agency is fully informed in its decision-making. The EPA May 17 Federal Register provides additional information including how to submit your comments to the docket: http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/E6-7496.htm Besides submitting your comments directly to the EPA public docket, please also send a copy to teung.f.chin@usda.gov and kinard.sherrie@epa.gov [NOT sherrie.kinard@epa.gov] so USDA and EPA may better coordinate. For your information, EPA is also requesting interested parties: 1. To provide comments and input on the Agency’s risk assessments for aldicarb. Such comments and input could address, for example, the availability of additional data to further refine the risk assessments, such as, additional toxicological data, worker exposure data, and usage information, or could address the Agency’s risk assessment methodologies and assumptions as applied to this specific pesticide. 2. To provide risk management proposals for aldicarb. Risks of concern associated with the use of aldicarb are: acute dietary risk estimates for the general U.S. population and all population subgroups at the 99.9th percentile of exposure; acute aggregate food and water risk estimates for adults and children; and worker risk estimates for most mixers, loaders and applicators. 3. To submit risk management proposals for ecological risks of concern including those to birds, mammals, fresh water and marine fish and invertebrates. In targeting these risks of concern, the Agency solicits information on effective and practical risk reduction measures." (See attached file: Aldicarb Quantitative Usage Analysis (QUA) 1999 and 2000.doc) Please do not hesitate to contact me if you have any questions or comments. Teung F. Chin, Ph.D. Biological Scientist Office of Pest Management Policy Agricultural Research Service United States Department of Agriculture LOCATED AT: USDA Animal & Plant Health Inspection Service 4700 River Road, Unit 149 (Room 3D-06.8) Riverdale, MD 20737-1237 Phone (301) 734-8943 Fax (301) 734-5992 Teung.F.Chin@usda.gov http://www.ars.usda.gov/opmp --------------------------------------------------------------- 5/17/06 Request for Additional Information and Suggestions for the Reregistration of Aldicarb Public Comment Period: Dear Reader: The purpose of this document is to summarize the current human health risk picture for aldicarb and solicit mitigation options. The preliminary human health risk assessments will be released for 60-day public comment period May 17, 2006, and will end July 17, 2006. Human Studies Review Board \A human toxicity intentional dosing study was used in the aldicarb risk assessment. EPA’s use of a human toxicity study in the aldicarb risk assessment is in accordance with the Agency’s Final Rule promulgated on January 26, 2006. For additional information relating to the Human Studies Review Board determination for the adicarb-specific study used in the risk assessment, refer to EPA’s website at http://www.epa.gov/osa/hsrb/. Dietary Risks Under the Food Quality Protection Act (FQPA), all food and drinking water risks for a given pesticide must fit within the pesticide’s “risk cup”. The risk cup can be simply defined as the “acceptable level of exposure” to an individual from a pesticide, on an acute or chronic basis. When dietary risks are of concern, EPA is required to mitigate the risks down to acceptable levels. The current dietary (food only) risk assessment utilizes PDP and the Carbamate Task Force (CTF) market-basket data for potatoes and citrus, respectively. Field trial data were used for all other commodities (except sorghum, sugar beet and sugar cane); however, residues were either very low or non-detectable. Percent crop treated information and processing/cooking data were also utilized where appropriate. It’s important to note that since aldicarb is systemic, typical food preparation practices such as washing and peeling are not expected to significantly reduce residues. Sugar beet and sugarcane were excluded from the assessment since aldicarb residues are not expected in the processed commodities as consumed. A low tolerance level was used for sorghum as well as percent crop treated but resulting estimates did not contribute to risk. Estimated acute dietary exposure and risk from food alone exceed EPA’s level of concern (i.e., >100 % of the aPAD) for children 1-2 years and children 3-5 years old when compared to the rat red blood cell (RBC) cholinesterase inhibition (ChEI) endpoint. The estimated dietary risks for these two population subgroups at the 99.9th percentile of exposure were 159% and 129%, of the acute population adjusted dose (aPAD), respectively. For the general U.S. population, the dietary risk was 72% of the aPAD. Estimated risks were below EPA's level of concern (i.e., <100 % of the aPAD) at the 99.8th percentile for both children 1- 2 years old and children 3-5 years old. Because dietary exposure estimates were above EPA’s level of concern at the 99.9th percentile of exposure, an analysis was conducted to determine which food or food forms made the greatest contribution to dietary risk. For all population subgroups, aldicarb residues in potatoes were the most significant source of dietary exposure. When potatoes are removed from the dietary exposure assessment, all remaining risk estimates are below EPA’s level of concern. Drinking Water Risks Since acute dietary risks from food alone were above EPA's level of concern (i.e., >100 % of the aPAD), a drinking water only assessment was conducted. If all of the allowable exposure occurred through drinking water, EPA would not have concerns for acute exposure to aldicarb residues in surface water. Acute surface water risk estimates for infants, the most highly exposed population subgroup, range from 1% of the aPAD [potatoes] to 15% of the aPAD [cotton] at the 95th percentile of exposure. Acute surface water risk estimates for the general U.S. population and all other population subgroups ranged from <1% of the aPAD to 7% of the aPAD. Seven regional ground water monitoring residue levels were used to derive an acute dietary exposure estimate for ground water alone. The data indicate that acute exposure from ground water sources of drinking water is of concern, with acute risk estimates ranging from 20% of the aPAD to 945% of the aPAD. Drinking water risks based on ground water monitoring data overestimate the risks for all but those who obtain their drinking water from wells in vulnerable aldicarb use areas. However, since acute food only exposures exceed the aPAD, EPA is concerned about any additional exposure (to all subpopulations) through drinking water, regardless of the source. Occupational Risks The occupational risk assessment for aldicarb is based on potential exposure to agricultural workers during loading and application of granular products. Aldicarb is applied early in the growing season, and labels require immediate soil incorporation of granules; postapplication exposures are not expected for workers, so a quantitative postapplication risk assessment has not been conducted. Unlike some pesticides, aldicarb has worker exposure data that has been conducted with aldicarb and mirrors how aldicarb is packaged, handled, and used in agriculture. This study was used to conduct the occupational risk assessment for aldicarb. Pesticide Handler's Exposure Data (PHED) were also used in conducting the risk assessment since the aldicarb-specific study did not quantify potential risks from closed loading and closed cab scenarios. Therefore, for the portion of the occupational assessment which used the aldicarb-specific worker exposure data, risks were not of concern for most loader and applicator exposure scenarios. However, risks for loaders were identified for two scenarios (MOEs for loaders range from 14 to 130 and MOEs for applicators range from 34 to 324). When using the PHED data for the closed loading and closed cab scenarios, similar results to those found with the aldicarb-specific study were noted for loaders. However, when using PHED data for applicators, all scenarios exceeded EPA’s level of concern (MOEs for loaders range from14 to 139; MOEs for applicators range from 1 to 13). Environmental Risks The environmental risk assessment is based on maximum rates and average usage rates of aldicarb. The environmental risk assessment includes risks to terrestrial and aquatic organisms. Using multiple lines of evidence (such as use scenarios, average or “typical” application rates, registrant submitted toxicity studies, open literature data, and field monitoring data), aldicarb poses acute risks (mortality) to birds, mammals, and aquatic organisms. In addition, there is the potential for chronic reproductive effects in fish and invertebrates. Terrestrial Organisms For terrestrial organisms, acute levels of concern are consistently exceeded by a factor of greater than 100x and are frequently exceeded by more than 1000x. Granules left exposed on the surface appear to be the main source of exposure, but other sources such as residues taken up by plants and contaminated earthworms may also serve as a means of exposure. Aquatic Organisms For aquatic organisms, there are acute risks for freshwater fish and invertebrates and estuarine/marine fish and invertebrates for all of the registered uses with the exception of potatoes for freshwater fish and invertebrates and estuarine/marine fish. The chronic level of concern is exceeded for freshwater invertebrates (reproductive effects) and estuarine/marine invertebrates (average number of offspring endpoint) for all of the registered uses. Chronic concerns (larval and juvenile survival) also exist for freshwater fish for soybean, cotton, and pecan use patterns. Aldicarb residues are most likely to exceed levels of concern for fish and aquatic invertebrates in low-order streams because these streams are dominated by base flow conditions (where 100% of stream flow consists of discharged groundwater), and most of the toxic residues are believed to form within the subsurface (especially within the saturated zone). In addition, much larger contributing land areas sustain higher-order streams, so there is a greater dilution effect. In addition to risk based exposure estimates from modeling, there were also exceedances of the Agency levels of concern based on monitoring data. Solicitation for Benefits Information and Risk Management Suggestions At this time the dietary and occupational risks from aldicarb are of concern for some registered uses. In addition, the Agency has performed preliminary alternatives analyses, to identify available alternatives for the uses of aldicarb that pose the highest risks (see “Preliminary Impact Analysis for Aldicarb on Potatoes”, “Preliminary Impact Analysis for Aldicarb on Major Citrus Crops”, and “Impact Analysis for Aldicarb on Cotton”). It is important to note that FQPA does not allow for the consideration of benefits analyses for risks associated with dietary exposure assessments; therefore, benefits analyses play an important role in only non-dietary considerations, such as ecological and worker risks. Alternative analyses for potatoes, citrus and cotton are available in the docket, and show that although there are alternatives available for aldicarb, they tend to be more costly and less effective. At this time, the Agency has not been able to identify many viable options for effectively mitigating the dietary risks from aldicarb. Thus, EPA is soliciting input from interested stakeholders on benefits information (i.e. critical uses of aldicarb, and impacts to growers from the loss of aldicarb), as well as risk management suggestions. If you would like to provide this type of input, please submit your comments directly to the docket. Here is a list of sample questions that may help you in preparing comments: (1) In what regions (state/county, etc.) of the U.S. is aldicarb use occurring? (2) What are the pests that you feel aldicarb is critical for controlling? (3) What are the details of typical usage patterns (e.g., number of applications per season, use rate per application, acres treated, and time of application in the season?) (4) What worker activities typically occur when aldicarb is applied? (5) What alternatives, if any, do you believe are available to replace aldicarb? Please provide as much detail and documentation in your comments as possible so that the Agency is fully informed in its decision-making.

Responses
Responder: Darrell Hensley
State: KY
Date Requested: Jun 02, 2006
Response: Doug Johnson indicated no aldicarb use in Soybean or Grain sorghum production in Kentucky Ric Bessin indicated no aldicarb use in Kentucky on the remainder of crops mentioned in the inquiry, submission by Darrell Hensley

Responder: Charles Neill
State: TX
Date Requested: Jun 02, 2006
Response: At this time there is no usage of the product in question in Foard county which is located in northwest central texas extension district 3.

Responder: Roy Parker
State: TX
Date Requested: Jun 02, 2006
Response: I am reporting for the Texas Gulf Coast region for about 900,000 acres of cotton. A small amount of aldicarb may be applied to sorghum, but it is so small there is no need to report. The pests include thrips and aphids with a small acreage using the product for nematodes. One application is made per season into the seed furrow at-planting at 0.525 lb AI per acre on an estimated 135,000 acres (it would be no more than that). The granular product is applied through boxes mounted on 8 to 24 row planters. Alternatives include seed treated with imidacloprid and thiamethoxam, but the various chemical classes need to be retained from which to choose.

Responder: Charles Charles Neill
State: TX
Date Requested: Jun 02, 2006
Response: At this point in time, there is no usage of this product in Foard county. North central texas district 3. Charles Neill CEA-AG Foard County

Responder: Richie Griffin
State: TX
Date Requested: Jun 05, 2006
Response: Not Being Used to my knowledge

Responder: Henry Fadamiro
State: AL
Date Requested: Jun 06, 2006
Response: With the exception of peanuts, Aldicarb is not used on most of the listed crops in Alabama. Below is the response regarding Aldacarb's use on peanuts in Alabama In what regions (state/county, etc.) of the U.S. is aldicarb use occurring? In the Wiregrass area of Alabama (SE counties- Houston, Henry, Dale, Coffee, Geneva, Barbour, Pike, Crenshaw, Covington) aldicarb is used on peanuts for thrips control and for peanut root-knot nematode control. In the newer areas of peanut production including Baldwin, Mobile, Monroe, Escambia, Macon,Elmore and Dallas counties aldicarb use on peanuts is generally limited to thrips control. Statewide in all peanut counties approximately 200,000 acres of peanuts are planted in 2006. What is the percent crop treated in the states where aldicarb is used? About 35% of peanut crop is treated with thrips rate of aldicarb in-furrow at planting. This rate is typically 5-7 lbs of formulated product per acre. About 25% of the peanuts planted are treated with nematocidal rates of aldicarb. This application will include a 10-13 lb/acre formulated which is applied with some in-furrow and some banded behind the press wheel of the planter unit. About 5% of these acres will get an addditional 10 lb /A formulated pegging-time application. This would usually occur sometime in July. What are the pests that aldicarb is critical for controlling? As noted above, insects= seedling thrips ; nematodes= peanut root-knot, lesion What are the details of typical usage patterns (e.g., number of applications per season, use rate per application, acres treated, and time of application in the season?) As noted in previous comments. What worker activities typically occur when aldicarb is applied? Loading planter insecticide hoppers with aldicarb granules during planting operation The pegging time application is applied with wheel driven noble applicators which are filled with aldicarb granules by hand. What alternatives, if any, are available to replace aldicarb? For thrips control, phorate insecticide is the only other efficacious granule for at-planting use. For nematode control, Telone is the only alternative and it is much more costly and more difficult to apply and no more efficacious.

Responder: Tom Kuhar
State: VA
Date Requested: Jun 06, 2006
Not Important/Relevant to my state(s)
Response: There is no aldicarb use (labels available) for vegetable crops in Virginia. This is mostly due to label restrictions based on water quality issues.

Responder: steven sparkman
State: TX
Date Requested: Jun 09, 2006
Response: I am located in Hardeman Co. TX. The producers in my area have stopped using temik and started using a seed applied insecticide. Its easier and safer.

Responder: Roger Youngman
State: VA
Date Requested: Jun 11, 2006
Response: I am responding to the question about aldicarb use on alfalfa and sorghum for Virginia. Currently, there are several Temik 15G brand products labeled for use on "sorghum (grain) soil treatment" in Virginia, but not alfalfa. I have not conducted a pesticide use survey for grain sorghum. However, it is my impression that aldicarb use on grain sorghum is very low.

Responder: Clyde Crumley
State: TX
Date Requested: Jun 12, 2006
Response:
Attachment included in response [Download]

Responder: Tommy Doederlein
State: TX
Date Requested: Jun 12, 2006
Response: Aldicarb is used at planting in both Dawson and Lynn Counties of Texas. Its use is targeting nematodes and thrips in cotton. Typically the rate of use is 3.5 to 5 pounds per acre on irrigated acres and it is not used on dryland acres.

Responder: Chris Sansone
State: TX
Date Requested: Jul 05, 2006
Response: This response is from four of the major cotton growing areas in the state and is a compilation of individual reports. The Blacklands Region for this survey consists of 60,000 acres. Primary insects controlled by aldicarb are tobacco thrips and aphids (cotton and cowpea) and some nematodes in the river bottoms. The average rate is 3.5 lbs of formulation (0.525 lbs ai/ac). Most (95%) producers use a closed system so handling is minimal. Alternatives include the seed treatments imidacloprid (Gaucho) and thiamethoxam (Cruiser)and the abamectin product (Avicta Complete Pack). The seed treatments had problems in 2006 with high pressure so aldicarb use is expected to increase in 2007. Foliar products like acephate, dicrotophos and dimethoate are also options. Avicta may not be a good alternative for the root knot nematode and reniform nematode. In the Far West region, consists of 33,000 acres, including Pima cotton. Primary insects controlled by aldicarb are western flower thrips and cotton aphids. The average rate is 3.5 lbs of formulation (0.525 lbs ai/ac). Most (95%) producers use a closed system so handling is minimal. Alternatives include the seed thiamethoxam (Cruiser)and the abamectin product (Avicta Complete Pack). Imidacloprid does not look as good on the western flower thrips in state trials. Foliar products like acephate, dicrotophos and dimethoate are also options. The High Plains region, consists of 5 million acres, . Primary insects controlled by aldicarb are western flower thrips and cotton aphids and nematodes. The average rate is 3.5 lbs of formulation (0.525 lbs ai/ac)except with nematodes where use rates go up to 5 lbs of formulation (0.75 lbs ai/ac). Aldicarb use will be on approximately 70% of irrigated acreage or about 800,000 acres (not including Gaines County which was reported previously). Most (95%) producers use a closed system so handling is minimal. Alternatives include the seed thiamethoxam (Cruiser)and the abamectin product (Avicta Complete Pack). Imidacloprid does not look as good on the western flower thrips in state trials. Foliar products like acephate, dicrotophos and dimethoate are also options. Avicta may not be a good alternative for the root knot nematode. The thiamethoxam does not last as long as the aldicarb and requires a foliar application later in the season if used. Rolling Plains of Texas has about 1.1 million acres. Primary insects controlled by aldicarb are western flower thrips and cotton aphids. The average rate is 3.5 lbs of formulation (0.525 lbs ai/ac). Aldicarb use will be on approximately 70% of irrigated acreage or about 91,000 acres. Most (95%) producers use a closed system so handling is minimal. Alternatives include the seed thiamethoxam (Cruiser)and the abamectin product (Avicta Complete Pack). Imidacloprid does not look as good on the western flower thrips in state trials. Foliar products like acephate, dicrotophos and dimethoate are also options. The thiamethoxam does not last as long as the aldicarb and requires a foliar application later in the season if used.

Responder: Mark Mossler
State: VI
Date Requested: Jul 10, 2006
Response: Please see comments for FL.

Responder: Mark Mossler
State: PR
Date Requested: Jul 10, 2006
Response: Please see comments for FL.

Responder: Mark Mossler
State: FL
Date Requested: Jul 10, 2006
Response:
Attachment included in response [Download]

Responder: Rick Brandenburg
State: NC
Date Requested: Jul 11, 2006
Response: Aldicarb use is present in any area peanuts are grown, primarily 15 counties in eastern North Carolina. Aldicarb is use primarily to control one pest, tobacco thrips, Frankliniella fusca. Ths insect also serves as a vector for tomato spotted wilt virus. Aldicarb is typically applied once per season as an at plant, in-furrow insecticide. It is applied at 1 lb AI per acre. Planting typically takes place in May. Approximately 85,000 of the 95,000 acres planted in North Carolina have aldicarb used. The only worker activity that occurs is driving the tractor with the planter and refilling hopper boxes with seed and aldicarb. Two alternatives are available, acephate and phorate, both which are applied at plant, in-furrow. Neither provides the same level of thrips control (90% vs. 70%), although phorate has been proven to provide better suppression of tomato spotted wilt virus. Farmers overwhelmingly prefer aldicarb due to documented yield increases with its use. Rick Brandenburg Department of Entomology North Carolina State University

Responder: Ames Herbert
State: VA
Date Requested: Jul 17, 2006
Response: I support Temik use in cotton and peanut and it is critical to both crops in VA. It is used on a majority of our 85,000 - 95,000 acres of cotton and 15,000 to 20,000 acres of peanuts. It is the only product that supplies both nematode and thrips control. It goes into the soil at planting..one time...at planting..usually 5 lb/acre in cotton, and 7 lb/acre in peanuts. Although a few growers are moving to alternative seed treatments in cotton, there is no such alternative in peanut. I have loads of yield data over the years that shows significant yield protection with Temik compared with untreated plots (as much as 30-50% in cotton and 15-20% in peanut). As it is packaged (lock-and load) user exposure is minimal. I know of no user related poisonings in the almost 18 years I have been in the area...only very satisfied users. Temik also confers protection from some of the secondary pests like spider mite and aphids in cotton. Ames Herbert Virginia Tech University

Responder: Charles Luper
State: OK
Date Requested: Jul 17, 2006
Response: Aldicarb is important for use on cotton and peanut acreage in Oklahoma. Used mostly for thrip and nematode control in peanuts. Used only at planting. Worker actions would be only handling and loading the product. Other soil applied insecticides could be alternatives but may not work as well.

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