UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

NOV 18 20B 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

TO: 

BEAD Response to Comments Received During the Indoxacarb Registration 

Review Docket Opening (PC Code: 067710) from EPA Docket ID: EPA-HQOPP-2013-0367 

Monisha Kaul, Biologist !11~t0)tw {euJ 

Biological Analysis Branch 

Stephen Smearman, Economist ~ . L ... A •• __ 

Economic Analysis Branch J""~ 

Jihad Alsadek, Economist ,;r~ A- Jf~~ Science Information & Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Arnet Jones, Chief 

Biological Analysis Branc 

Timothy Kiely, Chief !':\- ltv\_'(-~ Economic Analysis Branch v J V"' J 

Diann 

Science 

Sims, 

Information 

Chief ;t}~ & Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Marquea King, Acting Team Leader 

RMIB-V 

Pesticide Re-evaluation Division (7508P) 

Peer Review Panel Date: November 6, 2013 

The indoxacarb registration review docket opened for comment on June 26, 2013. The Agency 

received comments related to the Indoxacarb Preliminary Work Plan (PWP) and other supporting 

documents placed in the docket. The PWP provided guidance for commenters regarding the 

types of use and usage information that would be useful to the Agency. The following includes a 

brief summary of the use and usage information received from the California Storm water Quality 

Association (CASQA), the California Central Valley Regional Water Quality Control Board 
(Central Valley Water Board), and the National Alfalfa and Forage Alliance (NAFA) followed 

by the Agency's response*. 

Comment 1: The Agency received information/rom the Central Valley Water Board (Docket 

ID: EPA-HQ-OPP-2013-0367-0011) and NAFA (Docket ID: EPA-HQ-OPP-2013-0367-0010) 

addressing the use ofindoxacarb on alfalfa. The Central Valley Water Board stated that 

indoxacarb use on alfalfa accounted for a substantial portion of indoxacarb use in California in 

2011. NAFA stated that indoxacarb is an important insecticide in alfalfa seed and forage 

production. NAF A also stated that indoxacarb is an important tool because it has a broad 

spectrum insect control. 

BEAD Response: The Agency's data sources indicate little use of indoxacarb on alfalfa 

nationally during 2007-2011 , which was the time period discussed in Table 4 of the PWP 

(Docket ID: EPA-HQ-OPP-2013-0367-0002) and the BEAD Chemical Profile for Registration 

Review (Docket ID: EPA-HQ-OPP-2013-0367-0006). However, newly released information 

indicates an increase in national indoxacarb use on alfalfa in 2012. The Agency plans to update 

and refine indoxacarb usage information during the registration review process. The information 

submitted by the Central Valley Water Board and NAFA will be considered as needed during 

this process. 

Comment 2: The Agency received information from the Central Valley Water Board (Docket 

ID: EPA-HQ-OPP-2013-0367-0011) and CASQA (Docket ID: EPA-HQ-OPP-2013-0367-0014) 

related to the request in the PWP for use and usage information. The Central Valley Water 

Board submitted an overview of the timing of indoxacarb applications made in California and 

provided a summary of agricultural and non-agricultural usage data from the California 

Department of Pesticide Reporting (CDPR) for 2007-2011. The CASQA submitted the most 

recent California sales data of 46,000 pounds in 2011. 

BEAD Response: State-level information regarding pesticide application timing, usage and 

sales is helpful to the Agency for understanding use patterns particularly if the patterns vary by 

region. The Agency plans to update and refine the use and usage information of indoxacarb 

during the registration review process and will consider the information submitted by the Central 

Valley Water Board and CASQA as needed during this process. 

*All EPA documents and submitted comments can be found under docket ID: EPA-HQ-OPP-2013-0367 

at http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-20 13-0367 . 

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