UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 

## SEP 2
..

# a 2014

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
MEMORANDUM
SUBJECT: BEAD Chemical Profile (BCP) for Registration Review: Napthalene Acetates (NAA) (Case Number 0371) (1-Naphthaleneacetamide (056001), 1- Naphthaleneacetic acid (056002), Potassium 1-naphthaleneacetate (056003), Ammonium 1-naphthaleneacetate (056004), Sodium 1-naphthaleneacetate (056007), and Ethyl 1-naphthaleneacetate (056008)). FROM:

THRU: Carl Chen, Biologist Biological Analysis Branch Claire Paisley-Jones, Environmental Protection Specialist }_.
_ Science Information and Analysis Branch (__

### ~"-,

# _U' Michelle Ranville, Economist { 

## tnf rr-Y) Economic Analysis Branch 

### U**~** Biological and Economic Analysis Division (7503P) Arnet Jones, Chief Biological Analysis Branc Diann Sims, Chief Science Information and Analysis Branch Timothy Kiely, Chief 

# r::\-

# ~ Economic Analysis Branch'\J 

### J Biological and Economic Analysis

### Divi~· 7503P) TO: Christina Scheltema, Chemical ReviewManager Risk Management and Implementation Branch 1 Pesticide Re-evaluation Division (7508P)
PeerReview Panel date: August 3,2014



### 1SUMMARY NAA is a plant growth regulator registered for use in fruit crops such as apples and pears, olives, citrus, and avocados. It is also registered for use in nursery crops to control flower initiation. It is mainly used as a thinning agent to increase fruit size and quality and reduce fruit drop losses. Between 1998 and 2012, NAA was applied annually over approximately 200,000 acres of agricultural crops. The majority ofusage is on apples and pears, and occurs onthe west coast of the United States. Approximately five percent ofolive acreage was treated with less than 500 pounds ofNAAbetween 2004 and 2012.
INTRODUCTION The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an overview ofthe pestmanagementroles and quantitative usage information for Napthalene Acetates (NAA) (Registration Review case number 0371). The BCP includes summaries of previous BEAD products and available public and/or private use and usage data for NAAto describe the role ofthis chemical in pestmanagement. Additional information on uses is available in the NAA Label Data Report. Information provided in this BCP may be used by stakeholders (e.g., users and registrants), OPP risk and benefit assessors and OPP risk managers, and the general public during the Registration Reviewprocess ofthis pesticide.
CHEMICAL AND USE CHARACTERISTICS NAA is a synthetic plant growth hormone registered for use in fruit crops such as apples, pears, olives, avocados, and citrus. It is also registered for ornamental uses. Itcontains an auxin that mimics the natural plant growthregulator, !-indoleacetic acid. NAA is mainly used for thinning offruit to increase pome fruit size and quality and reducing pre-harvest fruit drop and losses from wind and mechanical knockdown (USDA, 1999a/2001). For citrus crops, it may be used as a fruit thinning agent or a separate concentrated formulation may be used to control sprouting (CCQC, 2003). For ornamentals, it delays leafdrop ofholly boughs or acts as a rooting hormone labeled for use in greenhouses and nurseries (USDA, 2004).
HISTORY OF NAA and BEAD PRODUCTS The NAA case includes six Als: 1-Naphthaleneacetamide (056001), 1-Naphthaleneacetic acid (056002), Potassium 1-naphthaleneacetate (056003), Ammonium 1-naphthaleneacetate (056004), Sodium 1-naphthaleneacetate (056007), and Ethyll-naphthaleneacetate (056008), all ofwhich are plant growthregulators (PGRs). The first ofthese Ais, naphthaleneacetamide, was registered in 1952 to stimulate root growth ofcuttings for a number ofornamentals and trees. In 1981, tolerances were established for apples, pears, quinces, olives, and pineapple. A Registration Standard was published in 1981, and a Registration Eligibility Decision was published in 2007. Currently, NAAproducts are registered on fruit trees to prevent preharvest



### 2fruit drop, delay flower induction, and thin foliage. NAAproducts are registered on ornamentals to stimulate growth and delay leafdrop. To date, no Section 18 emergency exemption requests have been submitted to the EPAfor this chemical. However, this should notbe interpreted as a lack ofassociated benefits.


### USE SITES, FORMULATIONS,AND APPLICATION METHODS The use sites and formulations ofNAA are summarized in Table 1. NAA can be applied by ground or air in sufficient water to ensure thorough coverage. NAA can also be applied as a foliar dip-only treatment for plant cuttings. 

### T bl 1 U

a e 

# . se sites andF I ti ormua ODS 0

### fNAAA f 

### I C IVe d" ogre 1ents NAAActive NonIngredient Formulations Agricultural Use Sites agricultural Use Sites Naphthaleneacetamide Flowable concentrate, Apples, pears 

## -- (056001) Wettable powder Flowable concentrate, Apples, pears, gooseberries; non-bearing Naphthaleneacetic Ready-to-use solution, citrus, non-bearing nuts, non-bearing pome Ornamentals acid (056002) Soluble concentrate fruit, non-bearing stonefruit, non-bearing · berryplantings, non-bearing grapes Potassium 1- Apples, pears, olives, citrus, potato seed naphthaleneacetate Soluble concentrate 

## -- (056003) treatment, holly (cut plant material) Ammonium 1- naphthaleneacetate Soluble concentrate Apples, pears, olives, ornamental fruit trees 

## -- _(056004} Sodium 1- naphthaleneacetate Soluble concentrate Apples, pears, quince, loquat 

## -- (056007) Ethyl1- Emulsifiable Apples, pears; non-bearing citrus, nonnaphthaleneacetate concentrate, Ready-to- bearing olives, non-bearingpome fruit, non-



### -- (056008) use solution, bearing avocado, non-bearing mango, multiple tree species


### USAGE BEAD currentlyhas national usage data on five ofthe NAAproducts: the Naphthaleneacetates [Potassium 1-naphthaleneacetate (056003), Ammonium 1-naphthaleneacetate (056004), Sodium 1-naphthaleneacetate (056007), and Ethyl1-naphthaleneacetate (056008)] and Naphthaleneacetamide (056001). The usage patterns ofthese two groups are discussed below. No usage data were available for Naphthaleneacetic acid (056002). Naphthaleneacetates Between 1998 and 2012, BEAD estimates that an average ofapproximately 7,000 lbs of Naphthaleneacetates [Potassium 1-naphthaleneacetate (056003), Ammonium 1- 3naphthaleneacetate (056004), Sodium 1-naphthaleneacetate (056007), and Ethyl 1- naphthaleneacetate (056008)] were applied annually over approximately 180,000 acres (Figure 1

). While boththe total acres treated and total pounds applied have fluctuated somewhat from yearto year, and increased slightly inthe last three years, overall average usage has remained quite consistent.

300,000

Total Acres

Treated

0 

# I**~ ~**  

### 8 8**~ ~** **~ ~** **~** b**~ ~**  

### S**~ ~**  m m o o o o o o o o o o o o o**~ ~**  N N N N N N N N N N N N N

- Total Acres Treated

- Pounds AI 12,000

Total Pounds

AI Applied

0


### Figure 1. 

### Naphthaleneacetates TotalAcres Treated and Total Pounds AI Applied (1998- 2012). Source: ProprietaryData, 1998-2012
Between 2008 and 2012,, the period following the RED, applications to apples accounted for approximately 70% oftotal pounds ofNaphthaleneacetates applied (4,600 lbs AI) and approximately 80% ofaverage total acres treated (140,000 acres). Applications to pears accounted for the remaining 30% ofpounds applied (2,000 lbs AI) and 20% ofannual acres treated (35,000 acres) withNaphthaleneacetates. While apples account for the vast majority of usage, the average application rate onpeartrees is nearly twice that ofthe average rate used on apples (Table 2).


### T bl 2 N hth I t t 

## u b 

## c A 

### AI Rat 2008 2012



### a e 

# . ap1 a eneace a es se »Y 

### rop: verage e, 

# - Crop Average Pounds AverageTotalAcres Avg.AIRate Treated* _{!_bs AI/ 

### acres) Apples 4,600 140,000 0.033

Pears 2,000 35,000 0.055 *Total Acres Treated sums all acres treated for a crop, mcludmg those acres that receive multiple treatments. Source: EPA Proprietary Data, 2008-2012
As shoWI) inTable 3, usage by state shows little variation overtwo time periods, immediately before and after the RED, both interms ofaverage annual pounds applied and states withhighest 4percent ofusage. Usage in Washington accounted for over halfoftotal pounds AI applied in bothtime periods, and usage in California accounts for another quarter oftotal usage. The remaining 15 states where usage was observed accounted for less than 10% oftotal pounds applied (Table 3). 

### Table 3. Comparison ofState Usage ofNaphthaleneacetates, P t f T t I P d AIA li 

### d B tw 

### th 2003 2007 d 2008 2012

ercen o oa oun s lpp1 

### e e een e 

# - an 

# - 

# . 2003-2007 2008-2012 AverageAnnual = 6,800 lbs Average Annual =;: 6,600 lbs ,.



### State %Lbs State %Lbs Washington 55 Washington 62

California 18 California 16

Oregon 

### 7 Oregon 8 New York 6 Michigan 4 Michigan 5 New York 3

Other* 10 Other* 

### 7 *Other states: VA, PA, WV, NC, MO, ID, *Other states: VA, PA, WV, NC, OH IN, IL, OH, MA, WI, ME Source: ProprtetaryData, 2003-2012 Figure 2 shows thatusage intensity ofnaphthaleneacetates, interms ofpounds AI applied per 1000 crop acres grown, is highest inthe northwest, where the majority ofapples andpears are grown inthe U.S.

PoundsActive Ingredient per 1,000 CropAcres Grown CJ No Data 0<0.02 C]o.02-oos 0.05-0
.2 ->0
.2 

### Figure2. Annual average agricultural use intensity ofNaphthaleneacetates (2008-2012).



### 5

### Naphthylacetamide Between 1998 and 2012 an average ofapproximately 1,050 lbs ofNaphthylacetamide (056001) were applied annually over approximately 19,000 acres (Figure 2). Usage has fluctuated greatly during this period. Bothtotal acres treated and total pounds applied decreased drastically between 2006 and 2007. Usage remained low until2012, whenbothtotal acres treated and total pounds applied quickly increased to a higher rate than the previous 2006 high. Because we do not have usage data for years after 2012, it is unclear whether this usage spike is an outlier or representative ofan increasing trend.

60,000

Total Acres

Treated

0 

# II II

00 0'1 

# 8 .-i N rtl '<t**~ ~**  

### 8 8 8 8 .-i .-i N N N N N Lfl 10 0 0 0 0 N N I' 00 0'1 0 .-i N 0 0 0 .-i .-i .-i 0 0 0 0 0 0 N N N N N N

- Total Acres Treated

- Pounds AI 2,500

0 Total Pounds AI Applied



### Figure 3. 

### Naphthylacetamide TotalAcres Treated and TotalPounds AI 

### Applied (1998-2012). Source: Proprietary Data, 1998-2012 While Naphthylacetamide is registered for both apples and pears, 100% ofreported agricultural usage is on apples. Usage ofNaphthylacetamide is much lower than usage ofthe Naphthalenacetates on apples (Table 4). Annually, nearly 80% fewer pounds of Naphthylacetamide (800 lbs AI) are applied to approximately 85% fewer acres ofapples (18,000 acres) than the Naphthalenacetates. However, the average AI rate is slightly higher.


### T bl 4 N hth I t . d U b C A AI 

### Rat 2008 2012



### a e 

# . api 1y1ace am1 e se**~y** 

### ro >: verage e, 

# - ' 

### Avg.

## AI Rate "' Crop AveragePounds AverageTotalAcres Treated*
,{lbs Al/acres) Apples 800 18,000 0.044 *Total Acres Treated sums all acres treated for a crop, mcludmg those acres thatreceive multiple treatments. Source: EPA Proprietary Data, 2008-2012

6Usage ofNaphthylacetamide is concentrated onthe west coast, with the majority ofusage occurring in Washington. Between 2003 and 2007, approximately 20% oftotal usage was seen inthree eastern states: Virginia, WestVirginia, and Pennsylvania. By 2008, however, only 1% of total observedusage occurred inthe east, with less than 1% oftotal usage occurring in Pennsylvania (Table 5).


### Table5. Comparison ofStateUsage ofNaphthylacetamide, Percent ofTotalPounds AI A 

## r d B tw 

### th 2003 2007 d 2008 2012**~PPJie** 

### e een e 

# - an 

## - 

# . 2003-2007 2008-2012 Average

### Annual= 1,150 lbs Average Annual

### = 800 lbs



### State 

### %Lbs State '"" 

### %Lbs Washington 67 Washington 85

Virginia 18 California 

### 9 California 11 Oregon 5 West Virginia 4 Pennsylvania <1 Other* <1 *Other states: PA, OR Source: ProprietaryData, 2003-2012 Figure 4 shows that usage intensity ofnaphthylacetamide, interms ofpounds AI applied per 1000 crop acres grown, is highest inthe northwest, where the majority ofapples andpears in the U.S. are grown. More information about these maps is presented in Appendix A.

PoundsActive Ingredient per 1,000 CropAcres Grown c::::JNoDala C]<o.oo1 D o . oo1- o.o1 0
.01 -0.02 ->0
.02 

### Figure 4. Annual average agricultural use intensity ofNaphthylacetamide (2008-2012).
7Non-agricultural usage ofNAA Non-agricultural usage data were not available at the national level. However, Californiausage data indicated that the highest non-agricultural use ofNAA was for landscape maintenance (CDPR, 2003-2012). Usage for landscape maintenance has been slowly declining; approximately 100 lbs AI (primarily NAA, ammonium salt) were applied in 2012. ROLE OF NAA IN PEST MANAGEMENT AND CROP PRODUCTION NAAplays a significant role as a plant growth regulator inthe apple and pearproduction. Approximately 60% ofthe pear acreage was treated withNAArecently, comparedto less than 10% treated with all otherplant growthregulators (Proprietary Data, 2011-2012). Itwas also the top plant growthregulator used on apples (Proprietary Data, 2011-2012); it is applied, usually by aircraft, to aid inthe retention offruit onthe tree during the final two to four weeks priorto harvest (USDA, 2001). NAA is recommended for use on apples in Washington and California (USDA, 2001; UC, 2006), whichranked first and second, respectively, among states in term of pounds AI applied inthe last ten years (Proprietary Data, 2003-2012). Approximately 99% ofthe olives grown inthe U
.S. are grown in California. NAA is recommended for use on olive trees, which is an effective fruit thinner when applied 7-14 days following full bloom (USDA, 1999b). It was usedto treat approximately five percent ofthe olive acreage in 1995 (USDA, 1999b ). Similarly, approximately five percent ofolive acreage was treated with less than 500 pounds ofNAAbetween 2004 and 2012 (EPA, 2014). In2012, approximately 1,400 acres ofolives in California were treated with NAA (CDPR, 2012).
DATANEEDS

. The Agency currently does not have certain important information onNAA. Obtaining the

following information may improve future assessments conducted bythe Agency related to the use and importance ofNAA. BEAD currently has no data on agricultural uses for 1-Naphthaleneacetic acid (056002) and no national-level data on non-agricultural usage. Data on lbs applied, target pests, applicationrates, andpercent crop treated could inform future analyses by BEAD.



### 8REFERENCES CCQC. 2003. Crop Profile- Citrus in California. California Citrus Quality Council (CCQC). Available athttp://downloadily.net/read/ccqc-crop-profile-120503-3-california-citrusquality-council-47710934.html CDPR. 2012. Summary ofpesticide use data- Indexed by Chemicals. CaliforniaDepartment of Pesticide Registration (CDPR). Available at http://www.cdpr.ca.gov/docs/pur/pur12rep/12sum.htm EPA. 2007. Registration Eligibility DecisionNaphthaleneacetic Acid, its Salts, Ester, and Acetamide. Prevention Pesticides and Toxic Substances, US Environmental ProtectionAgency. EPA. 2014. Screening Level Estimates ofAgricultural Use ofNAA (Case 0371). Office ofPesticide Programs, Biological and Economic Analysis Division. Proprietary Data. 1998-2012. (pesticide usage data) UC. 2006. UC PestManagement Guidelines- Apple thinning sprays. UC IPM Online. University ofCalifornia Statewide Integrated Pest Management (IPM) Program. Available at http://www.ipm.ucdavis.edu/PMG/r4900111.html. USDA. 1999a. Crop Profile for Pears in Oregon. 1999. The National Information System ofthe Regional Integrated Pest Management (IPM) Centers. United States Department of Agriculture (USDA). Available at http://www.ipmcenters.org/cropprofiles/docs/orpears.pdf. USDA. 1999b. Crop Profile for Olives in California. The National Information System ofthe Regional Integrated Pest Management (IPM) Centers. United States Department of Agriculture (USDA). Available athttp://www.ipmcenters.org/cropprofiles/docs/Caolives.pdf. USDA. 2001. Crop Profile for Apples in**Was~ngton.** The National Information System ofthe Regional Integrated Pest Management (IPM) Centers. United States Department of Agriculture (USDA). Available at http://www.ipmcenters.org/cropprofiles/docs/W AApples.pdf. USDA. 2004. Crop Profile for Ornamental Plants inNorth Carolina. TheNational Information System ofthe Regional Integrated Pest Management (IPM) Centers. United States Department ofAgriculture (USDA). Available at http:/ /www.ipmcenters.org/cropprofiles/docs/NCornamentals.pdf.

9APPENDIX A The map included herein is primarily for the use ofthe risk assessors inthe Environmental Fate and Effects Division. The map provides a very broad geographical viewofthe average annual amount (in pounds) ofthe active ingredient applied per 1,000 acres ofcrop acres grown. These data are included inthe maps because risk assessors are interested inthe amount ofa pesticide used across agricultural land. The calculated values presented inthe map are not equivalent to an application rate (lb a.i/A). The data used to make these maps have several limitations. Any interpretation ofthe maps should considerthe underlying data and the associated limitations carefully. The numerator (annual average pounds applied) is based onprivate market surveys ofpesticide use in agriculture averaged overthe last five years (Proprietary Data, 2008-2012). These surveys cover about 60 crops and are targeted in states that produce the majority ofthe crop. Although the surveys capture most ofthe use ofa particular active ingredient in agriculture, there are several limitations to these surveys.
• States with minorproduction ofa surveyed crop are not sampled • Not all types ofpesticides are surveyed in every crop in every year • Many specialty crops with very small acreages are not included inthe survey The result ofthese limitations is that states that show no usage may actually have a small amount ofthe active ingredient being used. In some cases the displayed use intensity may be distorted because the surveyed crops and the reported pesticide usage may not accurately represent the actual pesticide usage onthe cropsproduced inthe state. The denominator (1,000 crop acres grown) was also obtained from the same private market survey database. The "Crop Acres Grown" variable represents the total acres grown in a given state ofall ofthe surveyed crops. This value is independent ofpesticide usage andpesticide registration. Itis importantto note thatthe surveyed crops (about 60) are sampled from states that are majorproducers ofeach crop. Therefore, there are cases where the actual crop acreage in a state is higher than that reported by crop acres grown in the surveybecause either that state and/or crop was not included inthe survey. The reader should pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical as the legendbins will likely be different.

10