UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D

.C

. 20460 

### JUN 0 12015

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION


### SUBJECT: BEAD Chemical Profile (BCP) for Registration Review: Sabadilla alkaloids (002201) FROM: Nikhil Mallampalli, Ph.D., Entomologist 

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# ML-- Biological Analysis Branch

-- Jihad Alsadek, Ph.D., Economist

# f~h...,..17**~** ,;-.,+MA."f,e,,l__ Science Information and Analysis Branch Andrew Lee, Ph.D
., Economist 

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# ~ Economic Analysis Branch Biological and Economic Analysis Division ( 503P) 

### THRU: Arnet Jones, Chief

# ~~ Biological Analysis

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Diann Sims, Chief

# ~J,--J Science Information and Analysis**Branch~** Timothy Kiely, Chief

# ~**~** • Economic Analysis Branch

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# J. Biological and Economic Analysis Division (1 P) TO: Roy Johnson, Chemical Review Manager Risk Management and Implementation Branch 5 Pesticide Re-evaluation Division (7508P)


### PeerReview Panel date: April 29, 2015

Page 1 of7SUMMARY The plant-derived Sabadilla alkaloids- primarily a mixture ofveratradine & cevadine

- are currently registered under the brand name Veratran in the U.S. Registration was first granted in 1961, and the formulation underwentreregistration in 2004 (USEPA, 2004). Based onprivate marketusage data from 2009-2013, usage averaged approximately 30pounds active ingredient (a.i.) applied annually on approximately 1,000 acres treated. The average a.i. rate overthis time period was 0.030 pounds a.i. /acre. INTRODUCTION This documentprovides an overview ofthe pest management roles and quantitative usage information for Sabadilla alkaloids, a complex mixture ofinsecticidal plant-derived chemicals marketed inthe United States underthe brand name Veratran®· The BCP includes summaries of previous BEAD products and available public and/orprivate use and usage data for Sabadilla alkaloids to describe its role in pest management. There will be no LUIS report due to the small number ofproducts. Information provided in this BCP may be used by stakeholders (e.g., users and registrants), OPP risk assessors, OPP risk managers, and the general public during the Registration Review process ofthis insecticide. USE SITES Registered agricultural use sites include avocadoes, citrus (all types), and mangoes.
FORMULATIONS AND APPLICATION METHODS Sabadilla alkaloids are applied both aerially and by ground based equipment, and are formulated as a wettable powder. REGULATORY HISTORY OF SABADILLAALKALOIDS and ASSOCIATED BEAD PRODUCTS Sabadilla alkaloids are insecticides registered for use inthe U.S. since 1961. Sabadilla alkaloids underwent reregistration and an eligibility decision was issued in 2004 (EPA 2004). A Screening Level Usage Analysis (SLUA, 2014) was prepared by BEAD in 2014. Itprovides national level usage in terms ofpounds ofactive ingredient (a.i.) applied and percent crop treated (PCT) datafor crops for which usage data are available. There is no official record ofother earlier BEAD work products (e.g., emergency exemption reviews, benefits assessments) that focused on Sabadilla alkaloids. An emergency exemption request may indicate a need for a particular chemical that is not registered for use on a particular site, and may yield information about a particular chemical's importance or value that is not
Page 2 of7found in otherEPArecords. However, a lack ofsuchreviews by BEAD does not specifically indicate the relative importance ofthe chemical. 

### USAGE In terms ofthepercent crop treated for the Screening Level usage Analysis (SLUA, 2014), all crops are less than 2.5 percent crop treated. The relatively lowpercent crop treated on these crops suggests infrequent reliance on Sabadilla alkaloids to control pests on these crops in conventionally produced crops within the label. However, growers ofcertified organic crops may use Sabadilla alkaloids to a greater extent than reported inthe usage databases monitored by BEAD, because organic growers are not specifically surveyed. Based onprivate market usage data from 2009-2013, reported usage averaged approximately 30 pounds active ingredient (a.i.) applied annually on approximately 1,000 acres treated. The average a.i. rate over this time period was 0.030 pounds a.i. /acre. Figure 1presents reported Sabadilla alkaloids usage in pounds a.i. overthe 1998-2013 timeframe. Figure 2 presents total area treated in acres over the same time period (Proprietary Data, 1998-2013). Figures 1 and 2 show the use ofSabadillaalkaloids is decreasing significantly except for a noticeable increase in 2003. Private market usage data sources reported no usage for 2006 and 2011. However California Department ofPesticide Regulation (Cal DPR) reported usage data for thattime frame and the data are included in Figures 1 and 2 below. 

### FIGURE 1. 

### SabadillaAlkaloids Usage in Pounds Active IngredientApplied (1998-2013) 1,800

"'C**.~** 

### a. c. <t <r VI "'C c: :J 0 a..

0 00 C7l C7l

..... C7l 0 ..... C7l 0 0 C7l 0 0

..... N N

Source: Proprietary Data, 1998

-2013 California Data, 2006 and 201 lN 

### ..,, 0 0 0 0 N N <t Lf) 

### 5 0 0 0 0 ID N N 0 0 N Years

Page 3of7 r-.. 0 0 N 00 0 0 N C7l 0 0 N 0

..... 0 N 

### 5

.....
..... 0 N N fVl

..... ..... 0 0 N N

### FIGURE 2. SabadillaAlkaloidsTotalArea Treated in Acres (1998-2013) 60,000

0 00 O'l 0 M O'l O'l 0 0 O'l O'l 0 0 M M N N

Source: Proprietary Data, 1998-2013 California Data, 2006 and 2011 N 0 0 N l'l'1 <t LJ'\ <'.) 0 0 8 0 0 ID N N N 0 ,.._ 00 O'l 0 0 0 0 M 0 0 0 0 N N N N 0 N Years N M 0 N l'l'1 M 0 N



### Table 1. 

### Comparison ofCropswith HighestUse ofSabadillaAlkaloids, PercentPounds AI Aoolied (1998-2002 and 2009-2013) 1998-2002 2009-2013 Average Annual Usage= 4,000 lbs. a.i. /yr. Average Annual Usage= 100 lbs. a.i. /yr. 

### Crop %Lbs Crop %Lbs Avocado 56 Oranges 96 Oranges 24 Lemons 4 Grapefruit 11 

# - -

Lemons 9 

## - - Source: Proprietary Data, 1998 -2013. 

### Table 2. Comparison ofStateswith Highest Use ofSabadilla alkaloids, PercentPounds AI A lied 1998-2002 and 2009-2013 1998-2002 2009-2013 Avera e Annual Usa e = 4,000 lbs. a.i. I Avera e Annual Usa e = 100 lbs. a.i. I 

### State % Lbs State % Lbs California 100 California 100 Source: Proprietary Data, 1998 -2013. Use ofsabadilla alkaloids increased on oranges during the 2009-2013 time frame and decreased on lemons during the same period. There are no reported usage data for avocado and grapefruit during the 2009-2013 time frame to compare with the 1998-2002 time frame. The average a.i. rate for the top crops interms ofpounds a.i. applied was for lemons at 0.04 lbs. a.i./acre and for oranges at 0.020 lbs. a.i. /acre, as shown inTable 3. There are no reported usage data for avocado and grapefruit during the 2009-2013 time frame. Page 4 of7

### T bl 3 S b d"ll lk I 

### "d U a e 

# . a a 1 

### a a a OI S 

### seon

### T C op Average Annual Crop Pounds AI Applied Lemons 40 Oranges 100 *Total Acres Treated sums all acres treated for a crop. Source: Proprietary Data, 2009 -2013 

### rops: A

### verage AIR ate, 2009 2013 

# - Average Annual Average Annual TotalAcres Al Rate (lbs.

Treated* a.i./acre) 1,000 0.040 5,000 0.020



### BIOLOGICAL ASPECTS RELEVANT TO SABADILLA ALKALOIDS These alkaloids have notbeen assigned a Mode ofAction (MoA) category by the Insecticide Resistance Action Committee (a group ofindustry technical experts). However, their activity appears to be similarto that ofpyrethrins and synthetic pyrethroids, inthat they interfere with sodium channels innerve cells, thus disrupting nervous control ofmuscles (Duke et al. 2010). Sabadilla alkaloids are "approved for use in the USA as an organic insecticide
...bythe Organic Materials Review Institute (OMRI)" (Duke et al. 2010). They act only upon contact or ingestion (i.e., no plant systemic activity) and degrade rapidly in air and sunlight (Rechcigl and Rechcigl 1998). While Sabadilla alkaloids canbe synergized bythe addition ofeither piperonyl butoxide (PBO) orMGK-264 (Rechcigl and Rechcigl 1998), neither is currently included inthe registered formulation. According to Rechcigl and Rechcigl (1998), "sabadillaalkaloids [are] derived from the ripe seeds ofSchoenocaulon officinale, also known as cevadilla orcaustic barley, a tropical lily that grows in Central and SouthAmerica. Sabadilla alkaloids were used historically for the control ofinsects on crops, animals, and humans (Allenet al. 1944)
. Since the advent ofsynthetic insecticides, sabadilla alkaloids uses have declined to the point that organic [growers] currently provide the major market for sabadilla alkaloids products." As early as the 1950s, it was noted that Sabadilla alkaloids are highly toxic to honeybees (Atkins and Anderson 1954); thus their use in :flowering crops may be constrained bythe need to protect these insects. 

### ROLE OF SABADILLA ALKALOIDS IN PEST MANAGEMENT While Sabadilla alkaloids (or the source seed materials) have historically been used against a wide variety ofinsects, the current label lists only thrips (unspecified species) as target insects to be controlled on the registered crops. The cause ofthe increase in usage in 2003, as reported by proprietary databases (Figs 1 and 2) is unclear. Itmaybethat thrips were a temporarily greater problem on some ofthe registered crops that year (these insects can migrate from other crops or increase populations iftheir biological control by natural enemies is disrupted). The causes ofthe relatively high usage ofthese alkaloids on avocadoes and oranges (Table 1) are also unclear. Itmay be that these crops are often susceptible to thrips injury, orthat they have a higher proportion oforganic production (however, it is notclearto what extent organic growers are a component ofthe proprietary databases upon which the tables above are based)
. Page 

### 5 of7Although thrips are the onlypests listed on current labels, the registrant is apparently interested in the efficacy ofthese alkaloids against a widerrange ofinsect pests ofcroppests. At a recent USDA IR-4 program workshop, a presentationby theregistrant indicates thatthere are ongoing comparative productperformance trials including Veratran and several othermaterials acceptable for organic cropproduction. These trials showpotential for theuse ofSabadilla alkaloids against such incipient invasive insects as the brown marmorated stink bug and the spotted wing drosophila (MOK 2014).
INFORMATION THAT MAY BE USEFUL FORBEAD'S FUTURE WORK ON SABADILLAALKALOIDS The Agency currently does not have important informationon Sabadilla alkaloids. Obtainingthe following usage information may improve future assessments conducted bythe Agency related to the use and importance ofthese chemicals: All details ofuse in organic and non-organic crop production, including application rates, number ofapplications peryear, and typical application timing during a growmg season. Major target pests in avocadoes and oranges (the highest usage crops).
REFERENCES California Department ofPesticide Regulation pesticide use data. Available onthe web at: http://www.cdpr.ca.gov/docs/pur/purmain.htm [Accessed April 2015]. Allen, T.C., R.J. Dicke, and H.H. Harris. 1944. Sabadilla alkaloids, Schoenocaulon spp., with reference to its toxicity to houseflies. J. Econ. Entomol. 37: 400-408. Atkins, E.L., Jr., and L.D. Anderson. 1954. Toxicity ofpesticide dusts to honeybees. J. Econ. Entomol. 47: 969

- 972. BEAD, 2014. Sabadilla alkaloids ScreeningLevel Usage Analysis. Biological and Economic Analysis Division, Office ofPesticide Programs, US Environmental Protection Agency. January 14, 2014. Duke, S.O., C. L. Cantrell, K.M. Meepagala, D. E. Wedge, N. Tabanca and K. K. Schrader. 2010. Natural Toxins for Use in PestManagement. Toxins 2: 1943-1962. EPA. 2004. Reregistration Eligibility Decision Exposure and Risk Assessment on Lower Risk Pesticide Chemicals Sabadilla alkaloids. Available onthe web at: http://www.epa.gov/oppOOOOl/chem search/reg actions/reregistration/red PC002201 27-Sep

-04
.pdf[Accessed April 2015]
. Page 6 of7MGK. 2014. MGK Update: IR-4 Biopesticide Food Use Workshop. Held at Atlanta, GA, September 9-10, 2014 Available on the web at: www.ir4.rutgers.edu/
.../workshoppresentations/MGK.pdf[Accessed April 2015]. Rechcigl, J.E. and N.A. Rechcigl. 1998. Biological and Biotechnological Control ofInsect Pests. 358 pp. Lewis Publishers, Boca Raton, FL.

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