1 **Summary of Meeting with Pyrethroid Work Group To Discuss Pyrethroid Ecological Risk Assessment** 

**March 4, 2013**
**A ttendees**  **Pyrethroid Work Group (PWG ):**  Dave Haughey

(BASF Corporation) Annette Bloomberg (Bayer CropScience) Michael Dobbs (Bayer CropScience) Ann Orth (FMC Corporation) Richard Allen (Valent BioSciences) Dick Collier (Landis International) Robert Morris (FMC Corporation , via Teleconference ) Gary Mitchell (FMC Corporation , via Teleconference ) Jeff Giddings (Compliance Services Intern ational , via Teleconference ) Alex Porges (Landis International, via Teleconference ) Paul Hendley

(Phasera Limited , via Teleconference ) **Environmental Protection Agency (EPA or Agency) :**  Environmental Fate and Effects Division Don Brady Mah Shamim James Wolf Melissa Panger Reuben Baris Steve Wente Rosanna Louie

- Juzwiak Dana Spatz Jose Melendez (via teleconference) Keith Sappington (via teleconference) Donna Judkins (via teleconference) Pesticide Re

- evaluation Division Rick Keigwin Patty Parrott Monica Wait Molly Clay ton Tracy Perry **Purpose** The purpose of the meeting was for the PWG to meet with members of the EPA ’s Pestici de Re

evaluation Division (PRD) and the Environmental Fate and Effects Division (EFED) to discuss PWG’s plans for conducting “unifi ed ” p yr ethroid risk assessments, including an explanation of what a unified approach entails, progress to date, and other information PWG may be able to2

provide to EPA to inform the ecological risk assessments for the p yrethroid class of insecticide s that EPA will be conducting during registration review.
**Presentation** PWG’s presentation covered:
 Concept for a unified higher tier py rethroid ecological a ssessment
 C urrent status of PWG risk a ssessment
 Proposal to collaborate with EPA through future meetings **Discussion** Explanation of Unified Approach PWG explains that it is proposing conducting nine separate , higher tier risk assessments for the active ingredients (ai’s) represented b y the PWG (bifenthrin, cyfluthrins, cypermethrin, cyahalothrins, deltamethrin, esfenvalerate, fenpropathrin, permethrin, tefluthrin, and zeta

cy permethrin), unified by

a common approach to ri sk assessment and management , i.e., employing the same assessment methodologies for each and implementing similar mitigation/label changes as necessary

. EPA Feedback E PA currentl y emplo ysa consistent approach in its ecological risk assessment s , particularl y in assessments conducted for various ai’s within a chemical class such as the py rethroids. Based on this meeting and previous conversations , EPA believes PWG’s approach is similar to a py rethroid ecological risk assessment conducted by industry an d considered by

a Scientific Advisory Panel (SAP) in 1999. The 1999 assessment employed a probabilistic landscape anal ys is , which the SAP found to be flawed

. The landscape approach use d a Mississippi watershed for cotton, and conclude d from modeling this scenario that drift from py rethroid applications does not reach water bodies. This conclusion was based on the topography of the Mississippi site, and on the local distance from fields to water bodies. This Mississippi watershed cannot be extrapolated to the entire U.S. Furthermore, PWG’s modeling can no t negate the large amount of monitoring data co llected by C alifornia and others which does show that py rethroids reach water bodies. In 2000, EFED provided extensive comments on this risk assessment methodology , and EPA is unclear if or how those comments will be addressed in the new py rethroid risk assessments proposed b y the PWG

. EPA asks PWG to submit a brief paper describing the PWG’s planned approach, and to the extent that it is similar to the approaches previousl y considered b y EPA and the SAP, PWG should address the previous comments. EPA do es not advise PWG to expend resources pursuing a new py rethroid risk assessment which is based on similar methodology to that which was previously found to be deficient.3

Any drastic change to EPA’s risk assessment methodology would need to undergo extensive peer review , and EPA must consider the timeframe allowed for p yrethroid risk assessment s during registration review. Therefore, EPA anticipates conducting risk assessments for all py rethroi d active ingredient s following the Agency ’s standard pol icies and procedures

. Rather than conducting alternative assessments, PWG may be able to provide other information , such as monitoring data and use information, which could potentially help inform the Agency ’s ecological py

rethroid risk assessments. Additional Information Requested by EPA EPA request s that PWG continue to submit the following : data generated on r unoff from impervious surfaces, California monitoring data , and additional data from other PWG studies that have been submitted to Californi a Department of Pesticide Regulation ( CDPR). EPA request s crop and urban use pattern information , specificall y information that is generall y not included on product label s . This includes non - agricultural label application rates (maximum single application rate, number of applications per year, retreatment intervals, etc.) with the understanding that ambiguous use instructions on labels may necessitate that the Agency make conservative assumptions in its upcoming registration revi ew ecological risk assessments. PWG indicated during the meeting it will soon initiate a survey to determine urban outdoor use patterns (Kline survey)

. The survey will focus on ty pical use patterns around the country , including worst case scenario outdoo r uses. PWG requested EPA input on the proposed survey prior to initiation . The survey would take approximately one month to conduct . EPA agrees to review survey

design. **Action Items** PWG will p repare a white paper describing the unified risk assessm ent approach, including the basic concepts, proposals, and progress , by end of April 2013

. PWG will address EPA’s comments on previous, similar risk assessments. PWG will perform a review of current p yr ethroid end use product labels to determine actual and intended use patterns. PWG will continue to submit data it has generated on r unoff from impervious surfaces, California monitoring data , and additional data from other PWG studies that have been submitted to CDPR

. PWG will submit to EPA its plans for the urban outdoor use pattern survey by end of April 2013

. **Next Steps** EPA and PWG will schedule another meeting to discuss PWG’s plans for unified assessments once the white paper describing the assessments has been submitted and EPA has completed its review. If PWG submits the white paper in April, this meeting could take place in earl y June.4

EPA plans to complete the first of the planned p yr ethroid ecological risk assessments for registration review in 2015 and post them for public comment in the docket

.