Nursery Treatment 

Efficacy Study within 

Worcester County, 

Massachusetts, to 

Support the Asian 

Longhorned Beetle 

Cooperative Eradication 

Program

Environmental Assessment

April 2010

United States

Department of 

Agriculture

Marketing and 

Regulatory 

Programs

Animal and 

Plant Health 

Inspection 

Service
Nursery Treatment Efficacy 

Study within Worcester

County, Massachusetts, to 

Support the Asian Longhorned 

Beetle Cooperative Eradication 

Program

Environmental Assessment

April 2010

 

Agency Contact

Julie Twardowski, Coordinator

National Asian Longhorned Beetle Program 

USDA, APHIS, PPQ

ALB Eradication Program

4700 River Road, Unit 137

Riverdale, MD 20737

__________________________________________________________

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__________________________________________________________

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others not mentioned. USDA neither guarantees nor warrants the standard of 

any product mentioned. Product names are mentioned solely to report 

factually on available data and to provide specific information.

__________________________________________________________

This publication reports research involving pesticides. All uses of pesticides 

must be registered by appropriate State and/or Federal agencies before they 

can be recommended. 

__________________________________________________________

CAUTION: Pesticides can be injurious to humans, domestic animals, 

desirable plants, and fish or other wildlife—if they are not handled or applied 

properly. Use all pesticides selectively and carefully. Follow recommended 

practices for the disposal of surplus pesticides and pesticide containers.
Table of Contents

I. Introduction....................................................................................1

A. Biology......................................................................................2

B. Purpose and Need....................................................................2

II. Alternatives ....................................................................................3

A. No Action..................................................................................4

B. Preferred Alternative................................................................4

III. Environmental Impacts .................................................................6

A. No Action..................................................................................6

B. Preferred Alternative................................................................6

C. Cumulative Effects.................................................................18

D. Threatened and Endangered Species...................................18

E. Other Considerations.............................................................19

IV. Agencies Consulted ....................................................................20

V. References ...................................................................................21
1

I. Introduction

Asian longhorned beetle (Anoplophora glabripennis) (ALB) is a foreign 

wood-boring beetle that threatens a wide variety of hardwood trees in 

North America. The native range of ALB includes China and Korea. 

Introduction and establishment of ALB into the United States would likely 

result in significant economic, environmental, and social impacts. While 

ALB spreads slowly by natural means, it can spread much faster through 

artificial spread. New infestations are difficult to detect and are often not 

found for 10 years or longer. If it becomes established in the 

United States, ALB could destroy as much as 60 percent of the tree 

population in some areas. Susceptible host species may never 

significantly recover and regenerate thus resulting in negative impacts to 

forest-dependent terrestrial and aquatic species. Negative economic 

impacts could include loss or reduction of exports of host species logs and 

live trees and shrubs, loss of saw logs and other forest products, and 

negative impacts to the maple syrup industry. In addition, the cumulative 

loss of urban trees over a 30- to 50-year period could amount to hundreds 

of billions of dollars in replacement costs (USDA–APHIS, 2009a).

ALB is believed to have been introduced into the United States from wood 

pallets and other wood packing material accompanying cargo shipments 

from Asia. ALB was first discovered in August 1996 in the Greenpoint 

neighborhood of Brooklyn, New York. Within weeks, another infestation 

was found on Long Island in Amityville, New York, after officials learned 

that infested wood had been moved from Greenpoint to Amityville.

In July 1998, due to the U.S. Department of Agriculture’s (USDA) 

national ALB pest alert campaign, a separate infestation was discovered in 

the Ravenswood area of Chicago. This discovery prompted USDA’s 

Animal and Plant Health Inspection Service (APHIS) to amend its existing 

quarantine of wood movement in infested areas and place additional 

restrictions on importing solid wood packing material into the 

United States from China and Hong Kong. 

In October 2002, ALB was discovered in Jersey City, New Jersey, and in 

August 2004, ALB was discovered in the Borough of Carteret, the Avenel 

section of Woodbridge Township, and in the nearby cities of Rahway and 

Linden, New Jersey. It was subsequently found in 2007 in Richmond 

County, New York (Staten Island), across the Arthur Kill River from the 

New Jersey infestation sites. 

In August 2008, ALB was discovered in Worcester County, 

Massachusetts. This infestation appeared to be 8 to 10 years old. The 

infested area is being treated according to the new pest response 

guidelines (USDA–APHIS, 2008a). The treatment consists of cutting, 
2

chipping, and disposing (either by burning or mulching) of infested trees 

and other host trees in close proximity to those infested. Uninfested host 

trees beyond the cutting zone are treated with either trunk injections or soil

applications at the base of the tree using the insecticide imidacloprid. 

Imidacloprid is taken up and distributed throughout the tree, and has been 

found to be effective against adult ALB as it feeds on small twigs, the 

female when depositing eggs, and young larvae (USDA–APHIS, 2008b).

A. Biology

ALB is in the wood-boring beetle family Cerambycidae. Adults are 1 to 

11⁄2 inches in length with long antennae, and are shiny black with small 

white markings on the body and antennae. After mating, adult females 

chew depressions into the bark of various hardwood tree species in which 

they lay (oviposit) their eggs. There are 12 known genera of host trees: 

Acer (maple and box elder), Aesculus (horsechestnut), Salix (willow), Ulmus 

(elm), Betula (birch), Albizia (mimosa), Celtis (hackberry), Cercidiphyllum 

(katsura tree), Fraxinus (ash), Plantanus (sycamore and London planetree), 

Sorbus (mountain ash), and Populus (poplar) (USDA–APHIS, 2008b; 

Commonwealth of Massachusetts, 2009). 

Once the eggs hatch, small white larvae bore into the tree, feeding on the 

vascular layer beneath. The larvae continue to feed deeper into the tree's 

heartwood forming tunnels, or galleries, in the trunk and branches. This 

damage cuts off nutrient flow and weakens the integrity of the tree which

will eventually die if the infestation is severe enough. Sawdust debris and 

insect waste and excrement (or frass) is commonly found at the base of 

afflicted trees, as well. Infested trees are also prone to secondary attack by 

other diseases and insects.

Over the course of a year, a larva will mature and then pupate. From the 

pupa, an adult beetle emerges chewing its way out of the tree, forming 

characteristic round holes approximately three-eighths of an inch in 

diameter. The emergence of beetles typically takes place from June 

through October, with adults then flying in search of mates and new egglaying sites to complete their life cycle.

B. Purpose and Need

APHIS has the responsibility for taking actions to exclude, eradicate, 

and/or control plant pests under the Plant Protection Act (7 United States 

Code (U.S.C.) 7701 et seq.). It is important that APHIS implement a 

quarantine and eradicate ALB from Massachusetts to prevent damage to 

hardwood trees in North America. To eliminate ALB in Massachusetts, 

the program utilizes removal of host trees, intensive tree surveys, 

insecticide injections into trees or soil applications, and herbicide 
3

treatments to host plant stumps and sprouts. Activities undertaken in the 

Massachusetts eradication effort have been the subject of a previous 

environmental assessment (EA) (USDA–APHIS, 2008b). Links to this 

EA, as well as other EAs that are pertinent to ALB eradication, are online 

and available: http://www.aphis.usda.gov/plant_health/ea/alb.shtml. 

Currently, APHIS has only one insecticide to use for soil treatment or 

trunk injection; this is applied in the spring to ensure effectiveness. 

Additional chemicals and treatment schedules are being evaluated to 

determine if additional chemicals and/or fall chemical applications can be 

used, thereby significantly increasing the amount of time available to 

conduct eradication treatments, which could expedite the eradication effort 

given the large size of the Worcester infestation. The potential 

environmental impact of the additional treatment options was the subject 

of a previous EA (USDA–APHIS, 2009b). Links to this EA are available, 

as noted above.

Due to the wide scope of the ALB infestation in Worcester, 

Massachusetts, (currently 74-square miles) commercial nurseries are now 

being impacted by quarantine restrictions placed on the movement and 

sale of nursery stock. Treatment options for the nursery industry are 

needed so that host material can be moved outside of regulated areas. 

Guidelines, based on an understanding of the dynamics of uptake and 

resultant residues from material applied around several species and sizes 

of trees in a nursery situation, need to be developed. The proposed study 

has been designed to determine if soil applications of various insecticides 

will result in effective levels of insecticides in tree tissues upon which

beetles feed. 

This EA has been prepared consistent with the National Environmental 

Policy Act of 1969 (NEPA) and APHIS’ NEPA implementing procedures 

(7 Code of Federal Regulations (CFR) part 372) for the purpose of 

evaluating how the proposed action, if implemented, may affect the 

quality of the human environment.

II. Alternatives

This EA analyzes the potential environmental consequences associated 

with the proposed nursery treatment study of insecticides being considered 

in the ALB Cooperative Eradication Program.

Two alternatives are being considered: (1) no action by APHIS, and

(2) the preferred alternative, to determine if soil applications of various 

insecticides will result in effective levels in tree tissues that beetles feed 

upon. 
4

A. No Action

Under the no action alternative, APHIS would continue to implement the 

ALB eradication program in Worcester County, Massachusetts, without 

consideration of adding treatments specifically for susceptible nursery 

trees. This would prohibit the movement of host nursery stock out of the 

quarantine.

B. Preferred Alternative

Under the preferred alternative, APHIS would also continue to implement 

the ALB eradication program in Worcester County. In addition, APHIS 

would actively seek to determine whether labeled soil applications of 

systemic insecticides can achieve acceptable residue levels in several ALB 

host tree species grown in ground within a commercial nursery. This 

would be useful information in the design of a fully integrated eradication 

program for ALB wherever it may occur. If acceptable residue levels are 

detected, host nursery stock would be able to be moved out of the 

quarantine. 

Several sizes and species of ALB host trees commonly sold and planted in 

the Worcester area by the public and municipalities will be included in the 

study in order to provide the most relevant information to the program. 

The proposed study will test four tree species and two size groupings of 

red maple, sugar maple, elm, and London plane trees. The applications 

will be drench treatments along a row of planted trees using industry 

equipment and personnel (row spacing = 11 feet). All tests will be 

conducted on property owned and operated by Bigelow Nurseries, Inc.,

within Worcester County, Massachusetts (see figure 1).

Trees will be randomly assigned to an early summer application of one of 

four chemical treatments; a minimum of 50 trees of each size class and 

chemical will be treated. Chemical applications are planned for May/June 

of 2010, 2011, and 2012. All application rates will be the maximum 

allowed by the U.S. Environmental Protection Agency (EPA)-registered 

pesticide label. The chemical treatments will include the following 

amounts of product in a minimum of 2 gallons of water per 1,000 ft2

:

1) drench application with Marathon 60 WP (60% imidacloprid; 

1 packet/1,000 ft of row);

2) drench application with Safari 20 SG (20% dinotefuran; 

8 oz/1,000 ft2); 

3) drench application with Arena 50 WDG (50% clothianidin; 

8.3 g/1,000 ft2); and

4) drench application with Flagship 25 WG (25% thiamethoxam; 

1.47 oz/1,000 ft2). 
5

 

Figure 1. The treatment area (outlined in red) is adjacent to Route 62 just 

east of Moore’s Corners in Worcester, Massachusetts.

 

The list of tree species selected for this study and their approximate size 

expressed as diameter at breast height (DBH) is as follows— 

Tree Species DBH DBH Minimum # of Trees

Sugar maple 1.0–1.5” 2.0–2.5” 400

Red maple 1.0–1.5” 2.0–2.5” 400

Elm 1.0–1.5” 2.0–2.5” 400

London plane 1.0–1.5” 2.0–2.5” 400

Treatments will be identified by attaching colored flagging tape to trees on 

each end of a production row: Marathon = red stripe; Safari = yellow 

stripe; Arena = green stripe; Flagship = blue stripe.

Pesticide residue analysis will be conducted on foliage collections made 

each year in early July (to coincide with the expected first emergence of 

ALB adults) and early September (near end of flight season) under 

supervision by the APHIS Otis Methods Laboratory. Sampling will be 

done by collecting leaves from terminal branches located within the lower 

one-third to one-half of each tree canopy, selecting a total of 4 to 

8 samples from all sides of the tree. The goal is to determine whether 

applications made using standard nursery practices and rates are sufficient 

to control ALB. In order to confirm the efficacy of these treatments, they 

will be compared to parallel studies being conducted in China in 2010 by 

Otis Methods Laboratory scientists. Potential treatment sites are located 
6

in eastern China near/along the Yangtze River, within Anhui Province and 

Zhejiang Province.

III. Environmental Impacts

A. No Action

Environmental impacts that could result from choosing the no action 

alternative would likely be related to preventing the eradication program 

from fully utilizing the information and experience that could be gained 

from carrying out research to improve the efficacy and efficiency of the 

program. Information that could be gained from the proposed action could 

lead to a treatment that would allow certification of nursery stock so it 

could be moved out of the regulated area, thus reducing the potential 

impact of the ALB program on the nursery industry.

B. Preferred Alternative

APHIS proposes to evaluate the efficacy of four insecticides to control 

ALB. All four compounds are systemic neonicotinoid insecticides that are 

currently registered for use on a wide variety of crops to control a variety 

of pests. All products proposed for use in this study are currently 

registered for these types of applications. The potential environmental 

risks from the proposed use of each of the four proposed insecticides 

(imidacloprid, dinotefuran, clothianidin, and thiamethoxam) are discussed 

below.

a. Toxicity 

Technical and formulated imidacloprid has low to moderate acute oral 

mammalian toxicity with median toxicity values ranging from 400 to 

greater than 2,000 milligram/kilogram (mg/kg). The technical material, as 

well as several formulations, are considered practically nontoxic from 

dermal or inhalation exposure (FS, 2005; USDA–APHIS, 2002a). Acute 

lethal median toxicity values are typically greater than 2,000 mg/kg and 

2.5 milligrams/Liter (mg/L) for dermal and inhalation exposures, 

respectively. Available data for imidacloprid and associated metabolites 

suggest a lack of mutagenic, carcinogenic, or genotoxic effects at relevant 

doses. Developmental, immune, and endocrine related effects have been 

observed in some mammalian toxicity studies. In all developmental 

studies, the noted effects were observed at doses above maternal effects 

and at concentrations and durations not expected in the proposed efficacy 

study (FS, 2005).

Imidacloprid has low to moderate acute toxicity to wild mammals based 

on the available toxicity data. Imidacloprid is considered toxic to birds 

1. Imidacloprid
7

with acute oral median toxicity values ranging from 25 to 283 mg/kg 

(USDA–APHIS, 2002a; EPA, 2008; FS, 2005). Reproduction studies 

using the mallard and bobwhite quail have shown no effect concentrations 

of approximately 125 parts per million (ppm) for both species. 

Technical and formulated imidacloprid is considered acutely toxic to some 

terrestrial invertebrates, such as honey bees and other related bee species,

by oral and contact exposure. Median lethal toxicity values range from 

3.7 to 230 nanograms (ng)/bee (Schmuck et al., 2001; Tasei, 2002; FS, 

2005; EPA, 2008). Acute sublethal effects in laboratory studies have 

shown that the no observable effect concentrations (NOEC) may be less 

than 1 ng/bee (FS, 2005). Imidacloprid metabolite toxicity to honey bees 

is variable with some of the metabolites having equal toxicity to 

imidacloprid, while other metabolites are considered practically nontoxic 

(FS, 2005). Due to concerns regarding the potential sublethal impact of 

imidacloprid to honey bees, several studies have been conducted to 

determine potential effects in laboratory and field situations. Studies to 

assess the effects of imidacloprid on homing behavior, colony 

development, foraging activity, reproduction, wax/comb production, and

colony health, as well as other endpoints, revealed that there was a lack of 

effects, or effects were observed at test concentrations not expected to 

occur under realistic exposure scenarios (Tasei et al., 2000; Tasei et al. 

2001; Tasei, 2002; Bortolloti et al., 2003; Maus et al., 2003; Morandin and 

Winston, 2003; Stadler et al., 2003; Schmuck, 2004). 

Imidacloprid has low toxicity to aquatic organisms including fish, 

amphibians, and some aquatic invertebrates. Acute toxicity to fish and 

amphibians is low with acute median lethal concentrations (LC50)

typically exceeding 100 mg/L (EPA, 2008; FS, 2005). Chronic toxicity to 

fish is in the low parts per million range, depending on the test species and 

endpoint. Aquatic invertebrates are more sensitive to imidacloprid when 

compared to fish with acute median toxicity values in the low parts per 

billion range to greater than 100 mg/L, depending on the test species 

(USDA–APHIS, 2002a; EPA, 2008; FS, 2005). 

b. Exposure and Risk

Based on the limited use pattern for the proposed use of imidacloprid in 

this study, potential exposure will be primarily to applicators and workers. 

Exposure to applicators will be reduced by following label directions,

including recommendations for personal protective equipment, resulting in 

minimal risk to applicators. Exposure to the general public is not expected 

because none of the treated trees will be used to yield products that would 

be used for human consumption. Dietary risk from exposure to 

contaminated drinking water is also not expected based on the limited area 

of application, the proposed method of application, adherence to label 
8

recommendations regarding the protection of ground water, and 

monitoring data that has been collected in association with ALB 

eradication efforts in other States. Ground water sampling between 2003 

and 2006 in Suffolk County, New York, demonstrated that approximately 

half of the samples had no detectable levels of imidacloprid and, of those 

where detections occurred, the average concentration was 3.2 parts per 

billion (ppb) which is below levels of concern for human health. Samples 

with detectable levels of imidacloprid do not suggest a contribution from 

the ALB eradication program because other uses of imidacloprid occurred 

in these areas, and there did not appear to be a significant correlation 

between ALB-related treatment activities and increased residues. 

Exposure and risk to terrestrial vertebrates is expected to be minimal,

based on the proposed method of application, limited area of application,

and available effects data. Exposure from drift is not expected, nor is any 

significant runoff, based on the use pattern for imidacloprid in the ALB 

eradication program. There is the possibility of some imidacloprid 

exposure to mammals and birds that may feed on insects or vegetation 

from treated trees; however, under worst-case exposure scenarios, the risk 

is considered minimal.

Imidacloprid exposure to terrestrial invertebrates, especially honey bees, is 

also not expected to result in significant risk to pollinators. Impacts to 

individual insects that feed on twigs and leaves from treated trees and are 

sensitive to imidacloprid are expected to occur; however, population level 

impacts are not expected due to the small area of treatment within the 

managed nurseries. Pollinator exposure to imidacloprid will be minimized 

by the fact that only treated trees and their associated flowers and pollen 

could have residues while other flowering plants in the area of treatment 

will not contain residues. The potential level of imidacloprid in pollen and 

nectar from trees that have been treated for ALB is unknown, but is

expected to be low based on the available pollen and nectar residue data 

for other plants. Previous studies have shown that imidacloprid levels in 

pollen and flowers are low compared to other parts of the plant. Schmuck 

et al. (2004) found that levels of imidacloprid and associated metabolites 

were below the level of detection (0.001 mg/kg) in sunflowers. Laurent 

and Rathahao (2005) found average imidacloprid residues from sunflower 

pollen of 13 micrograms/kilograms (μg/kg), while Bonmatin et al. (2005) 

found average imidacloprid levels of 6.6 and 2.1 μg/kg in flowers and 

pollen from treated maize seed. These reported sunflower and corn pollen 

residues are within the range of values from other studies, and are similar 

to imidacloprid residue levels found in the nectar and pollen for rape 

(Maus et al., 2003). Chauzat et al. (2006) found that approximately 

50 percent of the pollen samples collected from pollen traps in apiaries 

contained measurable levels of imidacloprid with an average concentration 

of 1.2 μg/kg. 
9

As part of the environmental monitoring program, APHIS analyzed for 

imidacloprid residues in flowers collected from imidacloprid-treated 

willow, horse chestnut, and maple trees from New York during and after 

ALB eradication efforts (USDA–APHIS, 2003, 2002b). With the 

exception of one maple flower sample (0.13 mg/kg), all residues were 

below the level of quantification or detection (level of detection = 

0.03 mg/kg) over a 2-year sampling period. Residues in flowers were 

lower than in twig and leaf residues which are similar to observations in 

other plant species, such as corn and sunflowers. APHIS is working in 

cooperation with USDA–Agriculture Research Services (ARS) to collect 

pollen and nectar samples, where applicable, to characterize exposure to 

honey bees in nursery trees from these types of treatments. The risk to 

honey bees and other pollinators is expected to be minimal based on the 

small number of trees proposed for treatment, expected residues from the 

method of application and the presence of other nontreated flowering 

plants (both of which minimize exposure), and the available acute and 

chronic honey bee toxicity data for imidacloprid.

Imidacloprid exposure in aquatic environments is also expected to be 

minimal and not pose a significant risk to aquatic biota. The method of 

application eliminates the potential for drift and reduces the probability of 

off-site transport via runoff. There is a potential for subsurface transport 

of imidacloprid to aquatic habitats from applications made directly into 

soil. This type of exposure will be minimized by only making

applications where the ground water table is not in proximity to the zone 

of application, and avoiding soils that have a high leaching potential. Any 

aquatic residues that could occur would be below effect levels for aquatic 

biota due to the low probability of off-site transport and environmental 

fate for imidacloprid. There is the potential for leaf litter from treated 

trees to be washed into surface water during leaf drop. Kreutzweiser et al. 

(2009, 2008, 2007) demonstrated imidacloprid-related impacts on 

decomposition rates in aquatic systems, as well as sublethal impacts to 

some aquatic invertebrates that feed on leaf litter. The risk to benthic 

aquatic invertebrates through this exposure pathway in the proposed study 

is expected to be minimal. A small number of trees are being treated 

(relative to the amount of leaf litter from nontreated plants) that could be 

deposited into aquatic systems and applications will not occur in close 

proximity to natural bodies of water. A small retention pond is present at 

the nursery and is within the drainage area where applications will occur. 

APHIS will collect water samples to determine if any residues are present 

as a result of the proposed treatment.

c. Environmental Quality

Imidacloprid is soluble in water and is considered to have moderate 

mobility based on soil adsorption characteristics for several soil types. 
10

Based on field dissipation studies, the foliar half-life is less than 10 days 

while the persistence in soil can range from 27 to 229 days, (CDPR, 2006; 

FS, 2005). In cases of soil application, exposure of imidacloprid to soil 

invertebrates is possible; however, the impacts would be localized to the 

areas of treated soil and would be transient, based on available data (FS, 

2005). In water, imidacloprid is stable to hydrolysis at all relevant pH 

values but breaks down rapidly in the presence of light with aqueous 

photolysis half-life values typically less than 2 hours. Imidacloprid does 

exhibit properties consistent with pesticides that can contaminate surface 

and ground water; however adherence to label recommendations and the 

lack of close proximity of the study site to ground water and surface water 

resources mitigates the potential for ground and surface water 

contamination. 

The closest surface water resource to the proposed treatment site is a 

retention pond at the nursery which will be sampled to insure protection of 

surface water resources. The low volatility and proposed method of 

application in this program minimizes the potential for impacts to air 

quality from the use of imidacloprid.

a. Toxicity 

The available acute mammalian toxicity data suggest that technical and 

formulated dinotefuran has low oral, dermal, and inhalation toxicity (EPA, 

2004). Irritation to the eye and skin is considered minor based on the 

available material safety data sheet. Dinotefuran is not considered to be 

mutagenic, carcinogenic, or teratogenic based on the available mammalian 

toxicity data. Subchronic and chronic no observable effect levels (NOEL)

for mammals range from less than 3 mg/kg/day in chronic dosing studies 

in mice to 5,414 mg/kg /day in a 90-day dosing study in mice (EPA, 

2004).

The toxicity of dinotefuran to nontarget terrestrial vertebrates is low. 

Available mammalian and avian toxicity data show low toxicity to both 

groups based on available surrogate toxicity data. Acute oral and dietary 

median lethality studies using the quail and mallard duck show toxicity to 

be greater than the highest test concentration (EPA, 2009, 2004). Chronic 

toxicity to birds is also low with reproductive NOEC values of 2,150 and 

5,270 ppm for the mallard and bobwhite quail, respectively. 

Toxicity to insects, such as the honey bee, is high with oral and contact

median lethal dose (LD50) values of 0.023 and 0.047 μg/bee, respectively. 

Available acute freshwater and marine fish toxicity data suggest that 

dinotefuran is practically nontoxic with LC50 values greater than the 

highest test concentration. Acute and chronic toxicity to aquatic 

2. Dinoferuran
11

invertebrates is low for most test organisms with the exception of the 

mysid shrimp, which reports a LC50 of 0.79 ppm. Acute toxicity to other 

aquatic invertebrates is low, with acute and chronic toxicity values greater 

than 95 ppm (EPA, 2009, 2004). 

b. Exposure and Risk

Dinotefuran applications proposed in this efficacy study are expected to 

have minimal impacts to human health, based on the available toxicity 

data and low potential for exposure. Applications will be made as a soil 

drench where the active ingredient will then be taken up and distributed 

throughout the tree. None of the treated trees will be used to yield 

products that would be used for human consumption; therefore, dietary 

exposure is not expected. The potential for exposure is greatest for 

applicators; however, the low mammalian toxicity and adherence to label 

recommendations regarding personal protective equipment will minimize 

exposure and risk to applicators (EPA, 2004).

Exposure and risk of dinotefuran applications proposed in this study are 

expected to be low for most terrestrial nontarget organisms. Applications 

of dinotefuran to soil will result in exposure to terrestrial vertebrates that 

may feed on treated twigs, leaves, or seeds as part of their diet. 

Significant dietary risk to terrestrial vertebrates is not expected, based on 

the available toxicity data and conservative assumption that feeding would 

occur only from treated trees. Indirect impacts to birds and mammal 

populations that rely on insects for food would also not be significant 

because of the method of application for dinotefuran and the low number 

of trees being treated. There could be impacts to some terrestrial 

invertebrates that feed on treated trees and are sensitive to dinotefuran. 

No negative impacts to invertebrate populations are expected due to the 

low number of trees being treated and the availability of other nontreated 

vegetation.

Similar to other neonicotinoid insecticides, there are concerns regarding 

dinotefuran risk to honey bees. Treatments will occur in the spring and, 

based on the systemic nature of this class of insecticides, there is the 

potential for dinotefuran exposure to nectar and pollen. Residue data for 

this class of insecticides from nectar and pollen have been measured in 

several crops and, to date, residues have typically been below levels that 

would suggest impacts (Franklin et al., 2004; USDA–APHIS, 2008). 

There is some uncertainty in this assessment because the potential residues 

from dinotefuran applications using this method of application have not 

been characterized in trees. To address this uncertainty, nectar and pollen 

samples will be collected from treated trees during this study and analyzed 

for dinotefuran by USDA–ARS. Residue data on pollen and nectar will 

allow for a more accurate characterization of exposure to honey bees. 
12

This data can then be compared to the available toxicity data for 

dinotefuran, and related insecticides, to provide a more accurate 

representation of risk to honey bees from these types of treatments. The 

study itself is not anticipated to result in a major impact to honey bees 

because of the small number of trees that will be treated relative to the

number available to bees. In addition, dinotefuran exposure to honey bee 

populations from these types of treatments will be reduced compared to 

conventional broadcast applications of insecticides and the presence of 

other flowering vegetation in the area that has not been treated. 

Exposure and risk of dinotefuran to aquatic organisms is not expected. 

Dinotefuran has low toxicity to most aquatic organisms, and significant 

exposure from drift and runoff are not expected because the material will 

be applied as a soil drench. The potential exists for leaf litter from treated 

trees to be washed into surface water during leaf drop the following fall. 

Studies using another neonicotinoid insecticide, imidacloprid, have 

demonstrated some impacts on decomposition rates in aquatic systems, as 

well as sublethal impacts to some aquatic invertebrates that feed on leaf 

litter (Kreutzweiser et al., 2009, 2008, 2007). There is uncertainty 

whether this type of impact could result from dinotefuran applications; 

however, the potential for contamination through this pathway is expected 

to be minor in this study because there will be leaf litter contributions 

from plants that have not been treated in the area, and trees selected for 

treatment will not be in proximity to surface water. A retention pond 

present at the nursery and in the same drainage as the proposed efficacy 

study will be sampled to determine if dinotefuran is present as a result of 

treatment. 

c. Environmental Quality

Dinotefuran degrades slowly in soil with a reported aerobic soil 

metabolism half-life of 138 days. Degradation in water is rapid in the 

presence of light with a half-life of 1.8 days, but is stable to hydrolysis. 

Dinotefuran is highly soluble in water, and does not absorb well to soil; 

therefore, it could be susceptible to runoff and potential contamination of 

ground and surface water (EPA, 2004). The closest surface water feature 

to the treatment area is a retention pond which will be sampled for 

residues; however, other surface water resources are not expected to be 

impacted due the distance from the treatment site and the proposed small 

area of treatment. Adherence to precautionary label language regarding 

the protection of ground water (such as avoiding applications to permeable 

soils and avoiding sites with a high water table) will ensure protection of 

ground water resources. Impacts to air quality are not expected based on 

the chemical properties of dinotefuran, which show low volatility, as well 

as the method of application, which will eliminate impacts to air quality 

from drift. 
13

a. Toxicity 

The clothianidin technical ingredient and formulation proposed for use in 

this program has low acute mammalian oral, dermal, and inhalation 

toxicity. The median lethal toxicity values for oral exposure range from 

3,900 to 4,700 mg/kg, and the dermal and inhalation toxicity values are 

greater than 5,000 mg/kg and 3.2 mg/L, respectively. The formulation 

proposed for use in this program is moderately irritating to the eye and is a 

slight skin irritant (Valent, 2007). Clothianidin is not considered to be 

teratogenic, mutagenic, or carcinogenic and, based on the range of 

subchronic and chronic studies that are available, the NOEL ranged from 

9.8 mg/kg/day in reproduction studies to 1,000 mg/kg/day in subchronic 

dermal toxicity studies (EPA, 2003). 

Clothianidin also has low toxicity to birds, based on available toxicity 

values for surrogate test species. Acute oral and dietary LC50 are greater 

than 2,000 mg/kg in oral testing and greater than 5,000 ppm in dietary 

studies. Chronic studies using birds show low toxicity with a NOEC of 

205 ppm (EPA, 2009). 

Clothianidin is highly toxic to honey bees with an acute contact median 

lethal concentration of 0.0439 μg/bee (EPA, 2003). Sublethal impacts 

(such as colony health and foraging ability) have been evaluated for other 

pollinators, such as the bumble bee, with no impacts observed at pollen 

residue values up to 36 ppb (Franklin et al., 2004). 

Clothianidin has low acute toxicity to freshwater and marine vertebrates 

with LC50 values greater than 94 ppm. Chronic toxicity studies of fish 

using the fathead minnow reports a NOEC of 9.7 ppm (EPA, 2009). 

Toxicity to aquatic invertebrates is variable with median effective 

concentration (EC50) and LC50 values ranging from highly toxic with EC50

value of 0.022 ppm for the midge, to practically nontoxic with EC/LC50

values greater than 100 ppm for the freshwater crustacean Daphia magna

and eastern oyster (EPA, 2003; Barbee and Stout, 2009). 

b. Exposure and Risk

Human exposure and risk to clothianidin is expected to be minimal based 

on the method of application, the small area of treatment, and available 

toxicity data. The pesticide will be applied directly to the soil where the 

active ingredient will be translocated upward in the tree. None of the 

treated trees will be used to yield products that would be used for human 

consumption; therefore, dietary exposure would not be expected. 

Exposure through contaminated drinking water is also not expected

3. Clothianidin
14

because treated trees will not be in proximity to surface water or ground 

water drinking sources. The greatest chance for exposure to clothianidin 

will occur with applicators; however, risk will be minimal based on the 

low oral, dermal, and inhalation toxicity. In addition, exposure will be 

low based on the method of application and adherence to label 

recommendations regarding personal protective equipment.

Exposure and risk to most nontarget organisms is expected to be minimal. 

Toxicity to terrestrial vertebrates is low, and exposure to clothianidin 

would only occur through ingestion of soil under treated trees or by 

consuming leaves, twigs, or seeds from treated trees. Using the available 

toxicity data and the unrealistically conservative assumption that only 

items from treated trees are fed upon, residue data for these types of 

treatments using similar insecticides show that levels in various parts of 

the tree would not pose a risk to terrestrial vertebrates. Actual exposure 

and risk would be less based on the different types of food items used by

terrestrial vertebrates and the relatively small number of trees that will be 

treated within the area. 

Indirect effects to terrestrial vertebrates through the loss of invertebrate 

prey is also not expected because only certain insects would be impacted 

by feeding on treated trees, and terrestrial vertebrates would be able to 

forage in the area on insects that are present on untreated trees and other 

vegetation. 

Some insects that feed on treated trees could be impacted; however, based 

on the method of application, no drift would be expected and impacts 

would be restricted only to those insects that are sensitive to clothianidin 

and feed on treated trees. Similar to other neonicotinoid insecticides, there 

are concerns regarding clothianidin risk to honey bees. For this class of 

insecticides, residue data from nectar and pollen have been measured in 

several crops and, to date, residues have typically been below levels that 

would suggest impacts (Franklin et al., 2004; USDA–APHIS, 2008). 

There is some uncertainty in this assessment because the potential residues 

from clothianidin applications using this method of application have not 

been characterized. To address this uncertainty USDA–ARS, in 

cooperation with APHIS, will be collecting nectar and pollen samples 

from treated trees during the efficacy study to evaluate clothianidin levels 

to better characterize exposure and risk to honey bees. The efficacy study, 

itself, is not anticipated to result in major impacts to honey bees because 

of the small number of trees that will be treated relative to the available 

sources for bees to choose from and expected residues based on previously 

published literature for similar insecticides.

Applications of clothianidin, as proposed in this program, are not expected 

to impact aquatic organisms. Although toxicity to fish is low, clothianidin 
15

is toxic to some aquatic invertebrates. The method of application will 

eliminate the potential for off-site drift, and runoff is not expected because 

soil applications will not occur in proximity to natural bodies of water.

There is the potential for leaf litter from treated trees to be washed into 

surface water during leaf drop the following fall. Studies using another 

neonicotinoid insecticide, imidacloprid, have demonstrated some impacts 

on decomposition rates in aquatic systems, as well as sublethal impacts to 

some aquatic invertebrates that feed on leaf litter (Kreutzweiser et al., 

2009, 2008, 2007). The relatively small number of trees proposed for 

treatment, the leaf litter contributions from plants that have not been 

treated in the area, and not treating trees that are in proximity to surface 

water will reduce the potential for clothianidin leaf litter residues in 

surface water.

c. Environmental Quality

Clothianidin is considered stable in soil with metabolic half-lives of 148 to 

1,155 days, and dissipation half-lives of 277 to 1,386 days. Impacts to 

some soil invertebrates could occur; however, those impacts would be 

restricted to invertebrates sensitive to clothianidin and in areas 

immediately under treated trees. In aquatic environments, clothianidin 

breaks down rapidly in the presence of light with a half-life of 1 day, but is 

considered stable to hydrolysis. Clothianidin is soluble in water and 

considered mobile to highly mobile in soil (EPA, 2003). Impacts to 

ground and surface water quality are not anticipated, based on the method 

of application which reduces the potential for runoff and drift, and 

adherence to precautionary label language regarding the protection of 

these types of resources. A retention pond present at the nursery will be 

sampled for clothianidin to determine if treatments result in residues that 

could impact water quality. Based on the method of application and low 

potential to volatilize into the atmosphere, clothianidin applications are not 

expected to impact air quality (EPA, 2003). 

a. Toxicity 

Thiamethoxam has low acute oral, dermal, and inhalation toxicity, based 

on available data for the technical active ingredient and the formulated 

material. The technical active ingredient is not considered an eye or skin 

irritant; however, the proposed formulation is a slight to mild irritant to the 

eye and skin (EPA, 1999). The active ingredient or formulated material is 

not considered a skin sensitizer, based on available data from the material 

safety data sheet. Thiamethoxam is not considered to be neurotoxic, based 

on acute and subchronic exposures which reported NOEL of 100 and 

95.4 mg/kg/day, respectively (EPA, 1999). Thiamethoxam is not 

mutagenic, and reproductive and developmental effects occur at levels that 

are maternally toxic. 

4. Thiamethoxam
16

Thiamethoxam has moderate to low acute toxicity to avian species, based 

on surrogate toxicity data required for pesticide registration. Median 

lethal oral doses range from 576 mg/kg in the mallard to 1,552 mg/kg in 

the bobwhite quail. Median lethal dietary concentrations show that 

thiamethoxam is considered practically nontoxic to the mallard and 

bobwhite quail with values exceeding 5,200 ppm (EPA, 2010). Chronic 

reproductive effects are low with a NOEC of 300 ppm for the mallard and 

greater than 900 ppm for the bobwhite quail. 

Similar to other neonicotinoids, thiamethoxam is very highly toxic to 

honey bees in both oral and contact exposures. Contact toxicity is 

reported as an LD50 of 0.024 μg/bee with a NOEC of 0.005 μg/bee while 

oral toxicity is greater with an LD50 of 0.005 μg/bee and a reported NOEC 

of 0.002 μg/bee (EPA, 2010). 

 

Aquatic toxicity of thiamethoxam is variable depending on the test 

organism. Acute toxicity ranges from 0.035 mg/L for the midge to greater 

than 90 mg/L for all other aquatic test organisms including fish, aquatic 

invertebrates, and plants (EPA, 2010; Stark, 2005). Chronic toxicity data 

is limited to the cladoceran and the rainbow trout; however, based on 

those values chronic aquatic toxicity is expected to be low with NOEC 

values greater than 20 mg/L (EPA, 2010).

b. Exposure and Risk

Exposure and risk to human health is not expected, based on the proposed 

use pattern for thiamethoxam and the available mammalian toxicity data. 

Exposure through the dietary route is not expected for applicators or the 

general public. No products from the treated trees will be used for human 

consumption and adherence to label requirements for personal protective 

equipment will reduce exposure to workers via dermal and inhalation 

routes. Exposure through contaminated drinking water is also not 

expected because treated trees will not be in proximity to surface water or 

ground water drinking sources. In addition, adherence to label directions 

regarding protection of these resources will further insure protection of 

water quality. The low potential for exposure and the available 

mammalian effects data for thiamethoxam demonstrate wide margins of 

safety to human health. 

Exposure to wild mammals and birds may occur for those groups that feed 

on trees which have been treated; however, based on the available effects 

data, the small area of treatment, varied diets for these types of animals, 

and foraging that would occur where untreated trees are present would all 

result in minimal risk. Indirect impacts to wild mammals and birds that 

depend on invertebrate prey is also not expected to be significant since not 

all insects will be impacted due to differences in sensitivities, the number 
17

of trees being treated is relatively small and wild mammals and birds will 

forage in areas where treatments have not occurred. 

Insects that are sensitive to thiamethoxam, and feed on treated trees, could 

be impacted; however, due to the small area of treatment in these managed 

areas the impacts would not be expected to be widespread. Honey bees 

that may feed from treated trees may be exposed to thiamethoxam levels 

in nectar and pollen. As previously mentioned with the other insecticides 

proposed for use in this study, there is uncertainty regarding the exposure 

levels in nectar and pollen from thiamethoxam soil applications adjacent 

to host trees. Data for other neonicotinoids in other crops suggest the 

pollen and nectar insecticide residues may not reach levels where lethal or 

sublethal impacts have been observed. To address this uncertainty, ARS 

and APHIS will be collecting nectar and pollen samples to better 

characterize exposure of thiamethoxam to honey bees. Impacts to honey 

bee populations from this study are not expected based on the available 

data regarding impacts to honey bees from this class of insecticides and 

the relatively small number of trees being treated relative to other 

flowering plants in the area that have not been treated and would reduce 

exposure and risk.

Potential aquatic exposure of thiamethoxam is not expected to result in 

adverse impacts to aquatic nontarget organisms. The method of 

application which will eliminate drift as a major pathway of off-site 

transport, as well as low toxicity to most aquatic organisms, will result in 

minimal risk. There is the potential for surface water contamination from 

a retention pond on site; however, following precautionary label language 

to protect surface water will reduce the likelihood of contamination. 

APHIS will collect water samples during the efficacy study to determine if 

thiamethoxam residues occur as a result of the proposed treatments and if 

those residues exceed aquatic organism threshold values.

c. Environmental Quality

Thiamethoxam degrades slowly in soil, based on available aerobic soil 

metabolism and soil photolysis half-lives which ranged from 54 to 

385 days (NYSDEC, 2002). In water, thiamethoxam is stable to 

hydrolysis at pH values of five and seven; however, under more alkaline 

conditions breaks down with a half-life of 8.4 days at a pH of nine. 

Aerobic aquatic metabolism half-lives range from 9.5 to 21.9 days, while 

under anaerobic conditions reported half-lives range from 9.8 to 

353.5 days (NYSDEC, 2002). Field dissipation studies using treated seed 

demonstrate half-lives of 72 to 111 days. Thiamethoxam is considered 

mobile based on the high reported water solubility and low soil adsorption 

coefficients which range from 43 to 77. Concerns over mobility are 

reflected on the label with surface and ground water advisories and 
18

recommendations for mitigating off-site transport. Adherence to label 

recommendations and the small area of treatment proposed in the study 

will mitigate potential contamination of surface or ground water. A small 

retention pond is present on site and will be sampled to determine if any 

residues may be present as a result of treatment. Impacts to air quality 

from drift are not expected based on the method of application. 

Significant volatilization into the atmosphere will not occur based on the 

chemical properties reported for thiamethoxam (Syngenta, 2009).

C. Cumulative Effects

The proposed nursery study in Worcester, Massachusetts, is unlikely to 

result in significant cumulative impacts to the environment. While the 

nursery where the study is to be conducted has not been found to be 

infested with ALB, it is located in the same county and in close proximity 

to the quarantine area and, thus, potentially at risk of future infestation. 

Over 26,000 trees have been removed from the quarantine area in 

Worcester, and an additional 1,200 trees are currently known to be 

infested and will be removed in the near future. In addition, current plans 

call for the chemical treatments of approximately 40,000 trees over the 

next year and for each year in the foreseeable future. The addition of at 

least 1,600 trees for chemical treatment in this study is not expected to 

significantly add to the total number of trees likely to be treated in 

Worcester during the eradication program. The trees proposed for 

treatment are located in a commercial nursery and are subject to pesticide 

treatments, within the legal constraints of the Federal Insecticide, 

Fungicide, and Rodenticide Act, at the discretion of the nursery managers. 

Considering the proximity of the nursery to the Worcester ALB 

infestation, it is reasonable to anticipate that the trees would be treated 

whether they were included in this study or not. 

D. Threatened and Endangered Species

Section 7 of the Endangered Species Act and its implementing regulations 

require Federal agencies to ensure that their actions are not likely to 

jeopardize the continued existence of threatened or endangered species or 

result in the destruction or adverse modification of critical habitat. There 

are no federally listed species within the Federal quarantine area or in 

proximity to the nursery where the proposed action will take place. 

Therefore, the proposed action will have no effect on federally listed 

species.
19

E. Other Considerations

Executive Order (EO) 12898, “Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations,” focuses 

Federal attention on the environmental and human health conditions of 

minority and low-income communities, and promotes community access 

to public information and public participation in matters relating to human 

health and the environment. This EO requires Federal agencies to conduct 

their programs, policies, and activities that substantially affect human 

health or the environment in a manner so as not to exclude persons and 

populations from participation in or benefiting from such programs. It 

also enforces existing statutes to prevent minority and low-income 

communities from being subjected to disproportionately high or adverse 

human health or environmental effects. The human health and 

environmental effects from the proposed applications are expected to be 

minimal and are not expected to have disproportionate adverse effects to 

any minority or low-income family. 

EO 13045, “Protection of Children from Environmental Health Risks and 

Safety Risks,” acknowledges that children, as compared to adults, may 

suffer disproportionately from environmental health and safety risks 

because of developmental stage, greater metabolic activity levels, and 

behavior patterns. This EO (to the extent permitted by law and consistent 

with the agency’s mission) requires each Federal agency to identify, 

assess, and address environmental health risks and safety risks that may 

disproportionately affect children. The proposed treatments are to be 

made directly to trees in a commercial nursery and are not in areas where 

children would be expected to play and climb trees. Based on the 

anticipated lack of significant exposure, no disproportionate risks to 

children are anticipated as a consequence of implementing the preferred 

alternative.
20

IV. Agencies Consulted

U.S. Department of Agriculture

Animal Plant Health Inspection Service

Plant Protection and Quarantine

Emergency and Domestic Programs

4700 River Road, Unit 137

Riverdale, MD 20737

U.S. Department of Agriculture

Animal Plant Health Inspection Service

Plant Protection and Quarantine

Environmental Compliance

4700 River Road, Unit 150

Riverdale, MD 20737

U.S. Department of Agriculture

Animal Plant Health Inspection Service

Policy and Program Development

Environmental and Risk Assessment Services

4700 River Road, Unit 149

Riverdale, MD 20737

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Center for Plant Health Science and Technology

Insecticide and Applied Technology Section

Otis Pest Survey, Detection and Exclusion Laboratory

Buzzards Bay, MA 02542

 
21

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