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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460 

 OFFICE OF CHEMICAL SAFETY

 AND POLLUTION PREVENTION

MEMORANDUM

Date: December 9, 2013

SUBJECT: Methoxyfenozide: Registration Review – HED Review of Comments Received in 

Response to the Preliminary Work Plan (PWP).

PC Code: 121027 DP Barcode: D415832

Decision No.: 484448 Registration No.: NA

Petition No.: NA Regulatory Action: Registration Review 

Risk Assessment Type: NA Case No.: 7431

TXR No.: NA CAS No.: 161050-58-4

MRID No.: NA 40 CFR: §180.544 

FROM: Christina Swartz, Chemist 

Risk Assessment Branch II

Health Effects Division (7509P)

Office of Pesticide Programs

THROUGH: Linnea J. Hansen, Ph.D., Biologist

Risk Assessment Branch II

Health Effects Division (7509P)

Office of Pesticide Programs

TO: Bonnie Adler, Chemical Review Manager

Pesticide Re-Evaluation Division (7508P)

Office of Pesticide Programs

Attached is the Health Effects Division’s (HED) response to comments received following publication of 

the Preliminary Work Plan (PWP) for registration review of the insecticide methoxyfenozide.

Background

The Health Effects Division (HED) completed a human health assessment scoping document to 

determine the data needed and level of effort required to support registration review for the 

insecticide methoxyfenozide (C. Swartz, et al.; D408668, 5/10/13). The scoping document 

conclusions were incorporated into a PWP issued by the Pesticide Re-evaluation Division (PRD) 
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June, 21, 2013 [Docket ID No. EPA-HQ-OPP-2012-0663]. The Agency received comments 

from the following:

FIFRA Endangered Species Task Force (FESTF), 8/8/13; the Western Integrated Pest 

Management Center (representing 7 western states, Alaska, California, Idaho, Montana, Oregon, 

Utah, and Washington), 8/26/13; Dow AgroSciences, LLC, 8/22/13; and the Northwest 

Horticultural Council, 8/26/13.

The FESTF response was related only to the endangered species aspects of the Agency’s review 

of methoxyfenozide, whereas the WIPM response included usage information to be addressed by

the Biological and Economic Analysis Division (BEAD). However, the Dow AgroSciences and 

Northwest Horticultural Council responses are relevant to HED and are addressed below.

Dow AgroSciences LLC

Dow provided updated usage information for numerous crops; a comprehensive use pattern 

summary table, which includes application rate/frequency as well as pests controlled, comments 

related to the Environmental Fate and Effects Division (EFED) problem formulation, and 

changes/clarifications for the use pattern summary in HED’s scoping document.

HED Response:

During registration review, HED will consult the use pattern summary provided by Dow to 

ensure all relevant scenarios have been assessed in accordance with current labels. The 2 tables 

provided below were taken from the 5/10/13 human health assessment scoping document, and 

have been corrected with the information provided by Dow. For Table 3.1, this includes a 

maximum single application rate of 0.38 lb ai/A for tree nuts on the Intrepid 2F label, and a 

maximum single application rate of 0.25 lb ai/A for the other crops listed, as originally indicated 

by HED. Dow also noted that the use on peanut was omitted, and this has now been added. For 

Table 3.2, Dow provided updated information for the Special Local Need (SLN) labeling, 

specifically the cancellation of the LA06001, and the addition of an SLN label in CO -

CO120002. These changes have been included in Table 3.2.

Table 3.1. Methoxyfenozide Sec. 3 Product Formulations of Methoxyfenozide Insecticide.

Registered

products & 

Formul. Types 

% AI Use Sites and 

Applicable ORE Reviews 

Application 

equipment Comments 

62719-437

Technical 98.2 NA NA

62719-438

Intrepid WSP

MUP

80

Apples, Crabapples, Loquat. Mayhaw, Pears 

including Oriental, Quince, Cotton

0.05 to 0.4 lb ai/A

Ground, aerial

Allow 14 days 

between 

applications

62719-442

Intrepid 2F 22.6

Bushberries (Subgroup 13 07B); Cilantro Leaves, 

Brassica (Cole) Leafy Vegetables (Crop Group 5), 

Leafy Vegetables (Crop Group 4), Leaves of Root 

and Tuber Vegetables (Crop Group

2),Turnip Greens, Citrus Fruits (Crop Group 10-

10), Corn (Field, Sweet, Seed), Cotton, Cranberry, 

Cucurbit Vegetables (Crop Group 9), Fruiting 

aerial, 

chemigation 

and ground 

equipment 

(airblast), 

ground boom, 

hand held 

Up to 0.38 lb 

ai/A for single 

application to 

tree nuts, and 

0.25 lb ai/A 

for all other 

crops; 1.0 lb 
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Table 3.1. Methoxyfenozide Sec. 3 Product Formulations of Methoxyfenozide Insecticide.

Registered

products & 

Formul. Types 

% AI Use Sites and 

Applicable ORE Reviews 

Application 

equipment Comments 

Vegetables (Crop Group 8), Okra, Globe 

artichoke, Grape, Grass Forage Fodder, and Hay 

(Crop Group 17), Green Onion (Subgroup 3-07B), 

Legume Vegetables (Succulent or Dried) (Crop 

Group 6), Foliage of Legume

Vegetables (Except Soybean) (Subgroup 7A),

Nongrass Forage, Fodder, Straw and Hay (Crop 

Group 18), Ornamentals, Peanut, Pome Fruits 

(Crop Group 11), Pomegranate, Popcorn, Root 

Vegetables (Subgroups 1A, 1B), Soybean, 

Spearmint, Peppermint, Stone Fruits (Crop Group 

12), Strawberry, Tree Nuts (Crop Group 14) and 

Pistachios, Tropical Tree Fruits, and Tuberous and 

Corm Vegetables (Except Potato) (Subgroup 1D)

equipment 

(backpack 

sprayer, 

manuallypressurized 

handwand and 

hand gun), and 

hose-end 

sprayer

ai/A/seasonal 

maximum

Various Preharvest 

intervals 

(PHIs) are 

allowed, 

ranging from 1 

to 30 days. 

There are no 

rotational 

restrictions for 

crops on the 

label; all 

others have a 

7-day plantback 

restriction.

Abbreviations used: AI = active ingredient, WSP = water soluble package, MUP = Manufacturing Use Product, F = 

Flowable Concentrate.

Table 3. 2. Special Local Need (SLN) Registrations for Methoxyfenozide Insecticide.

SLN No. and

Parent Reg. No.

% AI of 

Parent Use Site Single Appl. Rateand Method Comments

MS060014, 62719-442

NC060003, 62719-442 22.6 F Sweet potatoes 0.16 lb ai/A; ground/aerial

CA060026, 62719-442

CA060013, 62719-442 22.6 F Alfalfa for seed 

productions 0.25 lb ai/A; ground; aerial

Maximum of 

1lb 

ai/A/season; 

maximum of 

60,000 Acres

CA070015, 62719-442 22.6F Citrus (non-bearing) 0.18 lb ai/A; ground/aerial

Maximum of 

4 applications 

per year to 

avoid 

resistance 

development

FL100001, 62719-442 22.6F Citrus crop group 10 0.25 lb ai/A; ground

Maximum of 

1 lb 

ai/A/season

WY120005, 62719-442 22.6F Beans, dried type; 

sugar beet 0.25 lb ai/A; aerial

Low volume 

spray 

concentrate
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Table 3. 2. Special Local Need (SLN) Registrations for Methoxyfenozide Insecticide.

CO120002, 62719-442 22.6.F Beans, dried type;

sugar beet 0.25 lb ai/A; aerial

Low volume 

spray

concentrate

Northwest Horticultural Council

The Northwest Horticultural Council (NHC) comments addressed several registration review 

cases, including methoxyfenozide. The NHC represents the growers and shippers of deciduous 

tree fruit (apples, pears and cherries) from 3 states, Washington, Oregon and Idaho. The 

comments included details regarding the use of methoxyfenozide on the 3 critical crops, and 

cited the need for continued use of the chemical in pest management for these crops. In addition 

to the region-specific usage information provided, the NHC noted that differences in established 

maximum residue limits (MRLs) in certain countries, when compared with the US tolerances, 

creates trade irritants, and can negatively affect the ability of US growers to export their produce. 

Specifically, the NHC notes the absence of MRLs for residues in pear and cherry in countries 

such as Saudi Arabia, Indonesia, Russia, China, Canada and Brazil, and the absence of an MRL

for residues in apples in Saudi Arabia, Russia and Indonesia. These countries constitute 

important export markets for US growers. Finally, the NHC notes that the MRL of 0.2 ppm for 

methoxyfenozide residues in apples in Brazil is significantly lower than the US tolerance of 1.5 

ppm. Likewise, trade irritants are created by the EU/UK MRLs of 0.3 in pear (US tolerance of 

1.5 ppm) and 0.02 ppm in cherry (US tolerance of 3 ppm).

HED Response:

During registration review, HED will work to minimize trade irritants and harmonize US 

tolerances with MRLs from important export markets, to the extent feasible. The Agency works 

with the Foreign Agricultural Service and the United States Trade Representative to minimize 

trade irritants. EPA is currently working with some of the countries identified by Northwest 

Horticultural Council to assist with the development of science-based MRLs.

In the specific case of methoxyfenozide, HED is working actively to address harmonization 

issues, both in conjunction with new use actions as well as during registration review. For 

example, HED has recently recommended an increase in the pome fruit tolerance from 1.5 ppm 

to 2.0 ppm in order to harmonize with the Codex MRL of 2 ppm. In some cases HED may not 

be able to harmonize with Codex or other countries due to differences in the use pattern and 

associated residues. The concerns of the NHC will be considered in HED’s ongoing 

harmonization efforts for methoxyfenozide.