UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C

. 20460 

## MAY II 20U

OFFICE OF CHEM ICAL SAFETY AND POLLUTION PREVENTION MEMORANDUM
SUBJECT: BEAD Chemical Profile for Registration Review: Permethrin (109701) FROM: David Brassard, Senior Entomologist

## ~~ Biological Analysis Branch Sepehr Haddad, Environmental Protection Specialist

# It/?./ I", , · Science Information and Analysis Branch 

## 1"1 "

## j/~"'-{ Derek Berwald, Economist 

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# Q VA(' Economic Analysis Branch 

### '\.j 

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# 0 Biological and Economic Analysis Division (7503P) THRU:



### TO: Arnet Jones, Chief Biological Analysis Branch Diann Sims, Chief Science Information and Analysis Branch Timothy Kiely, Chief 

# lli**~~** Economic Analysis Branch Biological and Economic Anal' is Divisio " 03P) Kaitlin Keller, Chemical Review Manager Risk Management and Implementation Branch 3 Pesticide Re-evaluation Division (7508P) Product Review Panel Review Date 12-8-10 Summary The purpose ofthis BEAD Chemical Profile is to convey usage information and a broad overview ofthe pest management roles ofpesticides that are beginning registration review. The intended audience for this document is the OPP registration review team and the general public. Permethrin is a broad spectrum synthetic pyrethroid insecticide used against a wide variety of insect, mite, and tickpests. Permethrin is registered for use on/in numerous agricultural crops,

1forest trees, ornamentals, livestock, pets, wood structures, commercial and residential buildings, wide areamosquito adulticide use, and clothing. Between 1998 and 2008, the usage of permethrin averaged approximately 400,000 pounds active ingredient (A.I.) applied to 3 million acres ofagricultural crops. Approximately 2.5 million pounds ofpermethrin A.I. is applied annually by consumers, pest control professionals, nursery/greenhouse operators, and mosquito abatementpersonnel. INTRODUCTION The purpose ofthis document is to convey usage information and a broad overview ofthe pest management roles ofpesticides that are beginning registration review. The intended audience for this document is the OPP registration review team and the general public. This document builds upon the data already provided in the "Usage and Label Use Data Packages" that are also provided to Registration Review teams by the Biological and Economic Analysis Division (BEAD). Permethrin is a broad spectrum synthetic pyrethroid insecticide used against a wide variety of insect, mite, and tick pests. Permethrin was first registered in the United States in 1979. Similar to otherpyrethroids, permethrin alters nerve function by modifying the normal biochemistry and physiology ofnerve membrane sodium channels. USE SITES Agricultural Crop and Livestock Use Sites Permethrin is registered for use on/in numerous agricultural crops including fruit, nut, vegetable, fiber and cereal crops. Permethrin is also registered for use on livestock and poultry and on their premises (i.e, living quarters and associated outdoor areas) Non-Agricultural Use Sites Permethrin is also registered for use on forest trees, lawns and turf, ornamental flowers, shrubs, and trees, transportation vehicles, structural wood termiticide treatment, buildings (including food handling establishments), wide areamosquito adulticide use, and numerous residential use sites including use in outdoor and indoor spaces, pets, and clothing.
. Permethrin also has non-FIFRA pharmaceutical uses as a pediculicide for the treatment ofhead lice and scabies. The Food and Drug Administration (FDA) approved the use ofthe pesticidecontaining pharmaceutical under the Federal Food, Drug, and Cosmetic Act (FFDCA).
COMMON FORMULATIONS AND APPLICATION METHODS Permethrin is formulated as Emulsifiable Concentrate, Liquid, Wettable Powder, Liquid-Ready to Use, Granules, Dust, Pressurized Gas, Pressurized Liquid, and Water Dispersable Granule (dry flowable, DF). Application methods include direct spray, surface treatment, soil broadcast,

2spot treatment, chemigation, soil injection, etc. Application equipment includes mist sprayer, fogger, aircraft, truck-mounted sprayer, sprinkler irrigation, airblast and duster, etc PERMETHRIN USAGE Agricultural Usage Based on private market pesticide usage data from 1998-2008, usage ofpermethrin averaged approximately 400,000 pounds active ingredient applied to 3 million acres (proprietary Data, 1998-2008). Figure 1 presents the acres treated with permethrin overthis time period. FIGURE 1. Permethrin Acres Treated 1998-2008 Permethrin Acres Treated

Acres



### o 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Year Source: Proprietary Data, 1998-2008 Figure 2 presents the pounds a.i. used from 1998-2000 on com, lettuce, sweet com, potatoes, peaches, and pistachios, compared to use on the same crops from 2006-2008. (proprietary Data, 1998-2008). The "other".category ofcrops shown in Figure 2 include alfalfa, almonds, spinach, celery, soybeans, tomatoes, cotton, onions, cucumbers, watermelons, etc. Use on com, sweet com and peaches decreased between those periods, while use on pistachios and potatoes increased.



### 3

### FIGURE 2. Comparison ofPermethrin Usage in Pounds A.I. Between 1998-2000 and 2006-2008 Timeframes Permethrln Pounds AI Used (1998-2000)

Potatoes 5%

Permethrln Pounds AI Used (2006-2008)

SweetCorn 3%



### Source: Proprietary Data, 1998-2008 Figure 3 compares the states with the highestuse in pounds a.i. betweenthe 1998-2000, and the 2006-2008 timeframes. In 1998-2000, the state with the highest use was California (24%), followed by Illinois (9%), Missouri (8%), Wisconsin (7%), and Minnesota, Arizona, Nebraska, Iowa and Kentucky with less 

### than 5% ofuse. In the 2006-2008 timeframe, the state with the highest use was also California (49%), followed by North Dakota, Illinois, Arizona and Ohio all at 4%, and Washington, Texas, Florida all at 3% (proprietary Data, 1998-2008). The widespread use ofpermethrin on almonds, lettuce, and pistachios contributed to the large proportion of permethrin use in California.

4

### FIGURE 3. Comparison ofStates with HighestUse ofPermethrin in 

### Pounds A.I. Between 1998-2000 and 2006-2008 Timeframes 1998-2000

KENTUCKY 3% IOWA 4% ARIZONA

4'\ NEBRASKA MINNESOTA 5% 5% 2006-2008

MISSOURI 2% MICHIGAN 2%

FLORIDA

3% TEXAS

3% WASHINGTON 3% OHIO 4% ARIZONA

4% 

### Source: Proprietary Data, 1998-2008 Non-Agricultural Usage In terms ofnon-agricultural usage, data are available to address usage by lawn care operators and pest control operators, and for uses such as mosquito abatement, golfcourses, nursery/ greenhouse, and food handling establishments, in addition to consumers for outdoor use. Generally, over the reported years (1999 through 2008), the majority ofuse was by consumers for outdooruse. Consumers used 1.6 million pounds A.I. 

### in 2000, approximately 2.5 million pounds A.I. in 2003, and 1.75 millionpounds A.I. in 2005 for outdooruse. Pest control
5operators used approximately 580,000 pounds A.I. 

### in 2000 and 450,000 pounds A.I


### .in 2003
. Use for mosquito abatement included approximately 34,000 pounds A.I. in 2000, increasing to 100,000 pounds A.I. in both 2003 and 2005
. Nursery/Greenhouse use in 2002 was approximately 25,000 pounds A.I.with use decreasing in 2004 to approximately 14,000 pounds A.I. and in 2006 to 12,000 pounds A.I. (Kline and Co., Inc., 2000-2005). USE TRENDS As shown in Figure 4, permethrin use peaked in the year 2000 for corn, while use on pistachios has increased from 2002 onwards
. Use on com and sweet comhas decreased from 2000 through 2008
. FIGURE 4. Permethrin Usage on Top Crops

400,000 -r-----' P
...... ermethrin Usageon..Pistachios, SWf!etCOrn, Lettuce and Corn (1998-2008)



### o 

# I

1 -.----.- P istachios SweetCorn 

### I'. Lettuce 

# I 

# I Corn 199819992000**2oo120022~20042oo5** 200620072008 Source: Proprietary Data, 1998-2008
BIOLOGICAL ASPECTS RELEVANT TO PERMETHRIN The increase in the use ofpermethrin by consumers since 2000 corresponds to the loss ofmany organophosphate and carbamate insecticides formerly registered for use in and around the home. Permethrin is the most widely used mosquito adulticide in the United States. Permethrin is the only pesticide registered to pre-treatclothing and fabrics to repel mosquitoes, ticks, and other public health pests (U.S. EPA, 2006). Permethrin is also the only pesticide registered for use in conjunction with "4 Poster" deer treatmentbait stations used for area wide control ofticks which vector Lyme disease. The '4-
6Poster' basically consists oftwo application/feeding stations located at either end ofthe device. As deer feed on the bait (usually whole kernel corn), the design ofthe device forces them to rub against permethrin-impregnated applicatorrollers (ALDF, 2010).



### mSTORY OF BEAD ASSESSMENTS FORPERMETHRIN There is no record ofBEAD having done a benefit analysis for pennethrin, although it does appear in many documents as a possible alternative for other insecticides, such as carbofuran, phosmet and azinphos-methyl. In 2002 there was a Section 18 crisis exemption for use of pennethrin against flea beetles on turnip greens 

### in Colorado. Later BEAD analysis concluded that the situation was urgent and non-routine and that losses ofup to 100% could have been expected without pennethrin (Chiri and Halvorsen, 2002). In 2006, BEAD provided qualitative information about the role ofpennethrin for selected crops, based on the amount ofthe crop treated with permethrin and the availability ofalternatives
. Crops with low likelihood for worker exposure were not evaluated
. BEADs findings included relatively high importance ofpermethrin for artichoke, Brussels sprouts, and pistachio and some ornamentals, especially cut cultivated greens. For other crops, alternative pyrethroid insecticides (i.

### e., bifenthrin, lambda-cyhalothrin, cypermethrin, cyfluthrin, deltamethrin, esfenvalerate, fenpropathrin, flucythrinate, fluvalinate, prallethrin, tau-fluvalinate, tefluthrin, tralomethrin, and zeta-cypermethrin) were found to be as effective as permethrin, These would likely be acceptable alternatives as long as they are registered and used on the crops in question. The alternative pyrethroids generally control the same pests and have a longerperiod ofresidual effectiveness than pennethrin. According to.EPA proprietary data, most ofthe alternative pyrethroids were only slightly more expensive than pennethrin, usually costing $2.00 more per acre. Bifenthrin is much more expensive than pennethrin (costs $10 to $40 more per acre) but also controls aphids and mites and thus may replace pennethrin and another insecticide/acaricide application (Brassard and Wyatt, 2006). 

### DATA NEEDS RELEVANT TO BEAD'S FUTURE WORK ON PERMETHRIN Obtaining additional information on the following items would improve future BEAD assessments ofthe importance ofpermethrin and may be required as part ofthe registration review ofthis pesticide: Updated usage information on the use ofpennethrin in in non-agricultural areas. 

### REFERENCES ALDF. 2010. '4-Poster' Deer Treatment Bait Station. American Lyme Disease Foundation. http://www.aldf .com/fourPoster2.shtml Brassard, David and TJ Wyatt. 2006. Qualitative Information about the Role of Permethrin in Select Uses to Inform Risk-BenefitDecisions, March 1, 2006.



### 7Chiri, Angel and Alan Halvorson. 2002 Review ofa Specific Emergency Exemption of Permethrin in Coloradofor Use on Turnip Greens to Flea Beetles
. Section 

### 18 Code (02- CO-020), DP Barcode D284508, August 7, 2002. EPA. 2006. Permethrin Facts: (Reregistration Eligibility Decision (RED) Fact Sheet). EPA 738- F-06-012 http://www.epa.gov/oppsrrdl/REDs/factsheets/permethrinfs.htm GfK Kynetec, 1998-2Q08Proprietary Data Kline and Co, Inc. (1999-2008)

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