Dave Barnekow, John Busacca, Nick Poletika

Dow AgroSciences

Indianapolis, IN

1,3-Dichloropropene - Consultation

Biological Opinion on Endangered Salmonids

September 19, 2011
Objectives

 Provide information relevant to assessing the biological 

impact of 1,3-dichloropropene to areas sensitive to 

salmonids in California, Washington, Oregon and Idaho

 Provide information about the value and use of TeloneTM 

products in California, Idaho, Oregon and Washington 

 Demonstrate the commitment of Dow AgroSciences to 

develop and implement effective Product Stewardship 

programs to minimize risk to the environment

TMRegistered Trademark of Dow AgroSciences LLC
Expected Outcomes

 Demonstrate that Telone products represent a negligible risk 

to salmonids or habitat that may impact salmonids when 

used according to the label

 Provide an overview of how Telone products are used under 

commercial conditions in these states

 Show that DAS is committed to stewarding our fumigant 

products aggressively to help ensure they are used 

appropriately
Agenda

 Importance of fumigants in the economic production of 

high value crops

 Broad Overview of 1,3-Dichloropropene

 Product Use Information

 Exposure potential in ESUs
What is a fumigant?

 A fumigant is a formulation {liquid (e.g. 1,3-D) or gas (methyl 

bromide)} that quickly begins to volatilize when it is applied in 

the soil.

 It moves through the soil air space as a gas to provide very 

high levels of control to soil borne pests such as nematodes, 

pathogens or weeds.

 Dow AgroSciences (DAS) is the sole manufacturer of 1,3-D 

in the US and all 1,3-D used in the US is manufactured by 

DAS
Overview: Key Attributes – 1,3-D

 Highly effective fumigant to control all species of nematodes that 

affect production of many high value fruits, vegetables, nursery 

crops and ornamentals

 Supported by a strong product stewardship program that requires 

training before purchase or use of the product

 Critical Role in Sustainable Agriculture – High Value Crops

 Mixtures with chloropicrin are the key alternative to methyl 

bromide as it is phased out Globally

 Supported by a dedicated sales staff that provides strong 

technical advice
Overview: Importance

 Most effective fumigant for control of nematodes

 Key mixing partner for alternatives to methyl bromide

 Essential management tool for economic production of 

many high value crops such as fruits and vegetables

 No crop residues from pre-plant use
Overview: Spectrum of Activity

Nematodes Controlled

Burrowing Citrus

Cyst Dagger

Lance Needle

Pin Reniform

Ring Root knot

Root lesion Spiral

Sting Stubby root

Insects controlled

Symphylans (garden centipedes)

Wireworms

Diseases suppressed

Rhizomania disease

Fusarium wilt of cotton

Verticillium wilt of mint
Overview: Registration History

 Telone® First registered in 1960

 Telone II registered in 1975

 Special Review in 1987

 Registration Eligibility Decision in 1998

 Fumigant Cluster Assessment in 2005

®TMTrademark of Dow AgroSciences LLC

Telone is a federally Restricted Use Pesticide.

Always read and follow label directions.
Product Information: Use Profile

 Formulations (liquid only)

 1,3-Dichloropropene by itself

 Telone II

 Telone EC

 Curfew

 Cordon

 1,3-Dichloropropene plus chloropicrin

 Telone C-17

 Telone C-35

 InLine

 Telone II is the most frequently 

used formulation in CA, ID, OR and WA
Why Use a Soil fumigant?

 Nematodes, pathogens and 

weeds are soil borne 

organisms that cause 

significant economic losses to 

high value crops

 Soil fumigants control one or 

more types of soil borne 

organisms and their use results 

in significant increases in yield 

and quality of the crop
Damage Potential of Nematodes

 Estimates of economic losses 

associated with nematode 

damage are $77.7 billion 

annually

 Global losses for some crops 

such as bananas, coffee, 

sugarcane and tobacco can 

be as high as 15-20%
Characteristics of the 

Soil Fumigation Business

 Pre-plant fumigants are used 

primarily in high value fresh fruit 

and vegetable markets.

 Use of a fumigant is essential to 

produce a sustainable, 

economically viable crop in major 

production areas.

 Fumigation represents a significant 

investment in time, money and 

equipment for the grower.
Characteristics of Soil Fumigation

 Pre-plant application

 High rates of use

 Gas distributes through the soil

 High rate of initial control

 Rapid dissipation 

 No residual control

 Crop is planted after the fumigant 

dissipates from the soil

 No residues in the crop
Benefits of Soil Fumigation

 Yield: enables sustainable yields of high value fresh fruits and 

vegetables

 Quality: produce high grade fresh produce

 Productivity: Crops, especially permanent crops, produce fruit 

earlier and become productive sooner

 Economics: enable production at economically viable costs 

 Quarantine: prevent distribution of soil borne pests between 

areas
Fumigant Application Types

Raised beds-row

Injection ~12” deep

Beds mulched w/plastic

Broadcast

Injection 12-18” deep

Usually no mulch

Raised beds-row

Drip irrigation

Beds mulched w/plastic
Product Information: Use Profile Shank

 Primary use is as a pre-plant 

application by shank injection

 Shanks inject 1,3-D 12-18 

inches below the soil surface 

 Injection ‘trace’ is disrupted 

and sealed to retain fumigant 

in the soil

 Applications are restricted to 

specific soil moisture and 

temperature conditions
Product Information: Use Profile - Drip

 Drip applications through 

surface tarped or deep, 

buried, non-tarp

 Products are applied 

pre-plant
Product Information: Use Rates – Telone -II

Broadcast Application Rate

Gal/Acre Lbs ai/Ac

Mineral 9 - 12 90.9 - 121.2

Muck or peat 25 252.5

Mineral 9 - 12 90.9 - 121.2

Muck or peat 18 181.8

272.7 - 353.5

424.2 - 555.5

27 - 35

42 - 55

Crop

Soil Type or 

Texture

Vegetable Crops

Field Crops

Fruit and Nut Crops

Nursery Crops

Mineral

Mineral
Product Information: Use Rates – Telone -II

Label Rate Use Rate1

(Lbs ai/Ac) (Lbs ai/Ac)

90.9 - 121.2

Crop

Soil Type or 

Texture

1

 Data based on 2009 California PUR. Only crops with 5 or more applications were 

included in the assessment

 55 - 118

Mineral 90.9 - 121.2 insufficient 

data

101 - 353

insufficient 

data

Vegetable Crops: incl Tomato, 

Carrot, Sweet potato, Potato, 

Cabbage, Pepper and 

Watermelon

Field Crops

Fruit and Nut Crops: incl Cherry, 

Prune, Orange, Walnut, Peach, 

Grape, Almond, Blueberry, 

Plum, Strawberry and Raspberry

Mineral 272.7 - 353.5

Nursery Crops Mineral 424.2 - 555.5

Mineral
Key Markets - California

Source: 2009 California PUR Data

Crop

Number of 

Applications

Total Acres 

Treated 

with 1,3-D

Average lbs 

ai/Ac

Percent of 1,3-D 

Acres Treated

Cummulative 

Percent of 1,3-D 

Treated Acres

1 Strawberry 325 10,336 109 27.3 27.3

2 Sweet potato 185 4,374 98 11.6 38.9

3 Carrot 70 3,424 115 9.1 48.0

4 Soil Fumigation/ preplant 171 3,004 252 7.9 55.9

5 Almond 139 1,948 306 5.2 61.0

6 Tomato, processing 27 1,862 118 4.9 66.0

7 Potato 30 1,855 95 4.9 70.9

8 Walnut 74 1,219 328 3.2 74.1

9 Grape, wine 50 1,136 262 3.0 77.1

10 Pepper 33 1,095 77 2.9 80.0
Key Markets - Idaho

Crop

Percent of DAS 

Sales in Idaho 

(approximate) Average use rate Application Method

Crop Rotation 

Interval

Potato 80 Telone II @ 17 gpa 

Telone C-17 @ 27 gpa

Broadcast 

14-18" deep 3 - 4 years

Telone II @ 15 gpa 

Telone C-17 @ 24 gpa; 

Broadcast 

16 - 18" deep; 

 Telone C-17 @ 18 gpa Row 12" deep

Onions 17 3 - 5 years
Key Markets - Oregon

Crop

Percent of DAS 

Sales in Oregon 

(approximate) Average use rate Application Method

Crop Rotation 

Interval

Potato >90 Telone II @ 17 gpa 

Telone C-17 @ 27 gpa

Broadcast 

14-18" deep 3 - 4 years

Carrots <5 Telone II @ 15 gpa Broadcast 

16 - 18" deep 3 - 4 years

Onions <3 Telone II @ 15 gpa 

Telone C-17 @ 24 gpa

Broadcast 

16 - 18" deep 3 - 5 years
Key Markets - Washington

Crop

Percent of DAS 

Sales in Washington 

(approximate) Average use rate Application Method

Crop Rotation 

Interval

Potato 80 Telone II @ 17 gpa 

Telone C-17 @ 27 gpa

Broadcast 

14-18" deep 3 - 4 years

Carrots 8 - 10 Telone II @ 15 gpa Broadcast 

16 - 18" deep 3 - 4 years

Onions 8 - 10 Telone II @ 15 gpa 

Telone C-17 @ 24 gpa

Broadcast 

16 - 18" deep 3 - 5 years

Tree and 

Vine

< 3 Telone II @ 30gpta Strip (~1/3 of acre) 

14-18" deep 10-20 years
Potential Routes of Exposure of Salmonids to 

Pesticides

Typical potential transport processes

 Drift – not applicable to fumigants

 Volatility with re-deposition

 Generally area-wide for fumigants, therefore 

should be detected in general ambient monitoring 

programs, if present

 Surface runoff

 Spills
How does DAS Mitigate Risk?

Effective Product Stewardship programs can 

significantly reduce potential risk:

 Label requirements

 Dedicated technical and sales staff

 Mandatory training programs
Product Stewardship – Label Requirements

 Environmental Hazards and Groundwater Advisory:

 Do not apply directly to water, or to areas where surface water 

is present or to intertidal areas below the mean high water 

mark

 Do not contaminate water when disposing of equipment 

rinsate.

 Do not apply within 100 feet of any well used for potable water.

 Where groundwater aquifers exist at a depth of 50 feet or less 

from the surface, do not apply this product where soils are 

Hydrologic Group A.
Product Stewardship – Label Requirements

 Application Directions

Soil Conditions

 Soil temperature

 Soil moisture 

 Soil preparation

 Placement of fumigant

 Soil sealing requirements
Product Stewardship – Label Requirements

Equipment requirements to prevent spillage

 End-Row Spillage Control: The dispensing system must shut off the feed stream 

when chisels are raised out of the ground.

 With all bulk and mini-bulk containers, Telone II CA must be transferred through 

connecting hoses, pipes, and/or couplings sufficiently tight to prevent workers or 

other persons from coming in contact with liquid Telone II CA.

 All hoses, piping, and tanks used in connection with Telone II CA shall be of type 

appropriate for use under the pressure and vacuum conditions to be encountered.

 Shut-off devices must be installed on the exit end of all hoses and at

all disconnect points to prevent leakage of Telone II CA product when

the transfer is stopped and hose is removed or disconnected. 

 A dry coupler that will minimize pesticide leakage must be installed at the

disconnect point.

 The pressure in hoses used to move Telone II CA beyond a pump must not exceed 

the manufacturer’s maximum pressure specification.
Product Stewardship

 Product Stewardship is a critical element in mitigating 

potential off-target exposure from 1,3-D

 Multiple elements contribute to effective Stewardship

 Dedicated sales and technical staff to train and support 

stakeholders and enforce use of our products

 Labels

 The label is the law

 Required practices and safeguards

 Required training

 All stakeholders must be trained as a condition of purchase and use
Dedicated 

Sales and 

Technical 

Support

 The sales organization in the US is unique in that they are all 

specialists that support only 1,3-D products.

 Additional support is provided by local field scientists and a dedicated 

Global Technical Expert
Product Stewardship –Training and Certification

 DAS trains/certifies all Dealers (i.e. ‘Train 

the Trainer’) and also helps train 

applicators.

 Training programs all contain basic use, 

safety and application components and 

are tailored to meet the needs of local 

agronomic and application considerations.

 DAS maintains a list of Certified Dealers 

and also a list of who has completed the 

training within the Dealership.

 State certification is required to purchase 

1,3-D or 1,3-D/CP.

 Retraining is required to maintain 

certification.
Examples of Stewardship Brochures

9/26/2011
Product Stewardship – Storage

Pictures –

Top: Bulk storage with concrete 

containment area

Bottom: Temporary field storage 

tank in PNW

• All bulk sites are surrounded by a concrete 

containment area that has a capacity of 

125% of the volume of material stored

• Bulk sites are inspected every three years

• Typical bulk site. All tanks in containment
Product Stewardship – Transportation

Pictures:

Top: DOT 407 compliant transport 

truck. All product is transported in 

DOT approved vessels. 

Bottom: Top of DOT 407 tank showing 

rollover and dome to protect contents 

in the event of an accident

• Telone is transported from bulk sites 

in trucks that meet or exceed DOT 407 

safety and security requirements

• DOT compliant vehicles meet 

collision and roll-over specifications and 

have self closing internal valves to 

minimize the potential of leaks 
Product Stewardship – Product Transfer

Pictures: 

Top: custom applicator suited up 

making a product transfer using dry 

disconnects

Bottom: close-up of a dry disconnect 

fitting.

• Telone is transferred from storage 

containers to the application equipment via 

a closed system that prevents leaks or drips

• Dry disconnects are used in all transfers 

to prevent spills or leaks
Product Stewardship – Application

• Everyone who purchases or applies 

Telone must be certified and trained 

annually 

• All Telone is applied by licensed, 

custom applicators in California

• 70% of Telone is applied by licensed 

custom applicators in PNW

Pictures

Top: Telone pigs

Bottom: Telone application rig with 

pigs, nitrogen tanks, injection shanks 

and soil sealing equipment
Product Stewardship – Application

• Telone is typically applied 12 to 

18” deep depending on the crop.

• Various implements are used to 

thoroughly cover the chisel trace 

and seal the soil 

• Typical ripper shank. Product is 

placed at 16 to 20” below the soil 

surface.

• Typical applicator. Ripper, 

followed by a disc followed by a 

culti-packer.
Product Stewardship – Application

• Telone can also be applied through 

existing drip irrigation lines

• Drip application is common for 

strawberries in California but is rarely 

used in the PNW

• Specific equipment is required to 

monitor injection into irrigation lines and 

prevent backflow into water supply

Pictures

Top: Drip irrigation setup for 

experimental trials

Bottom: Bed prepared and treated 

via drip irrigation
Zero Detects in Surface Water Monitoring 

Data for cis-1,3-D and trans-1,3-D

Chinook Lower Columbia River (Threatened) 14 14

Chinook Puget Sound (Threatened) 270 270

Chinook Sacramento River Winter-run (Endangered) / 

Central Valley Spring-run (Threatened) 55 55

Chinook Upper Columbia River Spring-run (Endangered) 1 1

Chinook Upper Willamette River (Threatened) 27 27

Chum Columbia River (Threatened) 14 14

Chum Hood Canal Summer-run (Threatened) 2 2

Coho Lower Columbia River (Threatened) 14 14

Steelhead California Central Valley (Threatened) 55 55

Steelhead Lower Columbia River (Threatened) 14 14

Steelhead Middle Columbia River (Threatened) 3 3

Steelhead Puget Sound (Threatened) 270 270

Steelhead Upper Columbia River (Threatened) 1 1

Steelhead Upper Willamette River (Threatened) 27 27

 USGS: National Water Quality Assessment Program (NAWQA) Data Warehouse:

 National Marine Fisheries Service (NMFS): Evolutionary Significant Units (ESU) boundaries

Species ESU Name (Status) Number of 

Observations

Number of NonDetects

Data Sources:

 State of Washington, Department of Ecology; Environmental Information Management 
Use Intensity in CA is Low in Relation to 

Application Rate < 0.005 < 0.005 < 0.005

< 0.005

ESU

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

USE INTENSITY (pounds ai/A)

0.0

0.1

0.2

0.3

0.4

0.5

0.001

The Use Intensity calculation is the quotient of the 

average annual use and the ESU area in pounds per acre.

Number Species ESU Name (Status)

9 Chinook California Coastal (Threatened)

10 Chinook

Sacramento River Winter-run (Endangered) / Central Valley Spring-run 

(Threatened)

14 Coho Southern Oregon & Northern California Coast (Threatened)

15 Coho Central California Coast (Endangered)

25 Steelhead Northern California (Threatened)

26 Steelhead California Central Valley (Threatened)

27 Steelhead Central California Coast (Threatened)

28 Steelhead South-Central California Coast (Threatened)

29 Steelhead Southern California (Endangered)
Improved Land Use Information in Cropland 

Data Layer

 In the biop finalized on 30 Jun 2011, NMFS used land cover 

information from NLCD 2001 to evaluate each a.i. for decline in 

conservation value of designated critical habitat.

 Note, however, that 1,3-D is not found in monitoring data, so the 

land cover data is useful primarily for describing the extent of the 

action.

 DAS suggests that for agricultural uses of 1,3,-D, a better land 

cover database to use for this purpose is the NASS Cropland 

Data Layer (CDL)a.

 CDL can be used as a surrogate for actual usage in OR, WA, and 

ID.

 DPR PUR is best information for actual usage in CA.

 When comparing CDL data to NLCD, DAS recommends using the 

more recent 2006 NLCD product.

a http://www.nass.usda.gov/research/Cropland/SARS1a.htm
Improved Land Use Information in Cropland Data 

Layer for Typical Uses in WA, OR, and ID

Number Species ESU Name (Status)

1 Chinook Puget Sound (Threatened)

2 Chinook Upper Columbia River Spring-run (Endangered)

3 Chinook Snake River Fall-run (Threatened)

4 Chinook

Snake River Fall-run (Threatened) / Snake River Spring/Summer-run 

(Threatened)

5 Chinook Lower Columbia River (Threatened)

6 Chinook Upper Willamette River (Threatened)

7 Chinook Snake River Spring/Summer-run (Threatened)

8 Chinook Lower Columbia River (Threatened) / Upper Willamette River (Threatened)

9 Chinook California Coastal (Threatened)

10 Chinook

Sacramento River Winter-run (Endangered) / Central Valley Spring-run 

(Threatened)

11 Chum Hood Canal Summer-run (Threatened)

12 Chum Columbia River (Threatened)

13 Coho Oregon Coast (Threatened)

14 Coho Southern Oregon & Northern California Coast (Threatened)

15 Coho Central California Coast (Endangered)

16 Coho Lower Columbia River (Threatened)

17 Sockeye Ozette Lake (Threatened)

18 Sockeye Snake River (Endangered)

19 Steelhead Puget Sound (Threatened)

20 Steelhead Upper Columbia River (Threatened)

21 Steelhead Middle Columbia River (Threatened)

22 Steelhead Snake River (Threatened)

23 Steelhead Lower Columbia River (Threatened)

24 Steelhead Upper Willamette River (Threatened)

25 Steelhead Northern California (Threatened)

26 Steelhead California Central Valley (Threatened)

27 Steelhead Central California Coast (Threatened)

28 Steelhead South-Central California Coast (Threatened)

29 Steelhead Southern California (Endangered)

ESU

1 2 3 4 5 6 7 8 9 101112131415161718192021222324

LAND COVER (% ESU)

0

10

20

30

40

NLCD 81+82 

CDL 2009-2010 Mean*

* Sum of potato, onion, carrot, tree/vine for ESUs in WA, OR, and ID 
Summary

1,3-D has negligible potential to impact salmonids or 

their environment because:

1. Application methods

 Shank application methods place the product 12-18 inches 

below the surface of the soil and cover it up preventing the 

possibility of surface runoff...or

 Drip applications place the product into the soil under plastic 

mulch tarps using existing irrigation lines protect the
Summary

1,3-D has negligible potential to impact salmonids or 

their environment because:

2. Product Stewardship commitment of DAS

 Dedicated, experienced, responsive sales and technical staff

 Required annual training

 Extensive support literature 

3. The label is the law

 Detailed specific label use instructions and requirements

 Specific equipment requirements
Summary

1,3-D has negligible potential to impact salmonids or 

their environment because:

4. As a Result of the Label Defined Use Pattern 

 Surface Water Monitoring - USGS: National Water Quality 

Assessment Program (NAWQA) Data Warehouse: Yields

 No Detections of 1,3-D in surface water
Thank you for your kind attention

Questions?