UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

DfC 2· 2 .zmo 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

BEAD Chemical Profile for Registration Review: Sulfosulfuton 

Jihad· Alsadek, Ph.D. Economist y~A-~ J.t..~. Science Information and Analysis Branch 

Stephen Smearman, Economist ~ L.. r _ 1 . . Ec;;onomic Analysis Branch pup ~~ 

Bill 

Biological 

Phillips, 

Analysis 

II, Ph.D. 

Branch 

Agronomist ~ 

Biological and Economic Analysis Di . ion (7503P) 

Arnet Jones, Chief () J. II 

Biological Analysis Branch ~~ 

Diann Sims, Chief h r ~ k 0 

Science Information and Analysi\s Branch ~ 

Timothy 

Economic 

Kiely, 

Analysis 

Chief 

Branch ,,

~ _! '0_ \.AI\.. ~ 

Biological and Economic Analysis Division (7 ) 

TO: Carissa Cyran, Chemical Review Manager 

Pesticide Re-evaluation Division (7508P) 

Peer Review Panel Date: November 24, 2010 

OFFICE; OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

Attached is the Biological and.Economic Analysis Division (BEAD) Chemical Profile for 

Registration Review for the chemical Sulfosulfuron. The purpose of this document is to convey 

usage information and a broad overview of the pest management roles of pesticides that are 

beginning registration review. The intended audiences for this document are the OPP registration 

review team and the general public. This document builds upon the data that has been provided 

in the "Use· and Label Use Data Packages" that are also provided to Registration Review teams 

by BEAD. 

1 
INTRODUCTION 

The purpose of this document is to convey usage information and a broad overview of the ·pest 

management roles of pesticides that are beginning registration review. The intended audience for 

this document is the opp registration review team and the general public. This document builds 

upon the data already provided in the "Usage and Label Use Data Packages" that are also 

provided to Registration Review teams by the Biological and Economic Analysis Division 

(BEAD). 

In agronomic production, sulfosulfuron is an herbicide that is used pre and post emergence in 

winter and spring wheat as well. as post emergence in alfalfa and pastures. In addition to these 

uses, this herbicide is applied post emergence in variouS non-agricultural/industrial sites. Weed 

species controlled are grass and broadleaf weeds. 

Sulfosulfuron is a sUlfonylurea herbicide with .the mode of action of inhibiting 

acetolactate/acetohydroxyacid synthase. The Herbicide Resistance Action Committee and Weed 

Science Society of America classify this herbicide in group B/21. Currently, there are reported 

weed biotypes resistant to this herbicide in the U.S. 

USE SITES 

Agricultural Use Sites 

The agricultural use sites for this herbicide for hay and pasture land are, 

agricultural fallow land, reserve bermudagrass, forage, fodder, hay, 

rangeland, and wheat. 

Non-Agricultural Use Sites 

The non-agricultural use sites for this herbicide include airports and landing . 

. fields, private roads and walkways, exterior 

commercial/intuitional/industrial premises, commercial storage/warehouse 

premises, drainage systems, ~xterior household/domestic dwellings, 

no~gricultural and utility pole rights-of-ways/fencerowslhedgerows, and 

nonagricultural uncultivated areas/soils. 

In addition, ornamental trees, shrubs, and vines, herbaceous and nonflowering plants, commercial/industrial lawns, ornamental turf, golf course 

turf, residential/recreational lawns, sod farm, gJ;ound covers. 

COMMON FORMULATIONS AND APPLICATION.METHODS 

Sulfosulfuron is formulated as water dispersible granules and emulsifiable conce.ntrate only. 

Sulfosulfuron may be applied via broadcast (aerial or ground) spray, directed spz:ay, ground 

1 Herbicide Resistant Action Committee 

http://www. weedscience.org/summary/ChemFamilySum.asp?lstActive=4 78&btnSub 1 =Go&lstHRAC= 

2 
spray, or injection treatment. Applications may be made using various types of sprayers 

(backpack, hand held, pump-up, and high- volume ground), aircraft, and soil injection 

equipment. 

USAGE 

Agricultural 

Based on private market pesticide usage data, the annual total agricultural usage averaged 27,000 

pounds active ingredient (A.O for approximately 1 million acres from 1998-2008 (G£K. Kynetec, 

1998-2008). The use of sulfosulfuron, in pounds A.I., is mainly on winter ~heat (99%) Data 

indicate that there is some use nationally on pasture and gr~slands but the use in terms of 

pounds A.1. as a percent of the total pounds applied is less than 1 percent annually. 

From 1998-200.8, the largest markets in terms of total pounds of activ~ ingredient applied to all 

crops and use sites are: winter wheat (99%), and spring wheat (~1 %). Usage in terms of the 

acres treated for all crops and use sites is the same; winter wheat (99%), and spring wheat (~1 %). 

(G£K. Kynetec, 1998-2008). 

The states with $e most agricultural usage in terms of Pounds AI applied are: 

Oklahoma (43%), Washington (23%), and Kansas (10%). (G£K. Kynetec, 1998-2008). 

Non-Agricultural 

The non-agricultural data shQwed less than 500 pounds active ingredient of sulfosulfuron are 

used on golf courses, nationally, in 2006 (Kline Studies, Inc.). There are no currently available 

usage data for residential"comm~rciallawns, or sod farms. Usage for these sites may be 

occurring below the reporting threshold. 

USE TRENDS 

Historical usage data from 1998-2008 are detailed for winter wheat (Figure 1). The graph shows 

an average of 40,000 pounds active ingredients for the period 2000-2004, and an average of 

15,000 pounds active ingredient for the time'period 2005-2008. This is in contrast to the annual 

total agricultural usage that averaged 27,000 pounds active ingredient (A.I.) for the time period 

1998-2008. The data do not show a clear trend, with a significant increase in the number of 

pounds applied to wheat from 1999 to 2000, then fluctuating for the period 2000-2004, followed 

by a significant decrease in pounds applied in 2005. For the period 2005-2008, the number of 

pounds applied appears to show modest increases year to year. BEAD is trying to determine 

why there was a significant increase in use starting in 2000 followed by a sudden drop in use in 

2005. The data used were for preliminary scoping purposes only. 

3 
ci. 

-3 

c 

::I 

o 

Q. 

Winter Wheat 

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 

Years 

Figure 1. Pounds ofSulfosulfuron Applied to Winter Wheat (1998-2008) 

BIOLOGICAL ASPECTS RELEVANT TO SULFOSULFURON 

Currently, there ~e many weed species and biotypes reported as resistant to this family of 

herbicides in the U.S. There are a few weeds that are specifically resistant to this herbicide. As 

an example, weeds resistant to sulfosulfuron in Kansas, where wheat is a major crop, are 

broadleaf weeds such as bushy wallflower and flaxseed (e.g. Erysium repandum and Descurainia 

sophia, respectively) and grasses such as Japanese brome and rye brome (bromus japonicus and 

scalimus, respectively). 

mSTORY OF BEAD ASSESSMENTS FOR SULFOSULFURON 

The following documents and. assessments were found: 

Use Related Documents 

Two use related references without documents found: 

- There was ·reference to a public interest document in support of a request for Section 3 

registration for MON 37500 (sulfosulfuron} technical grade active ingredient and for 

Maverick herbicide end use product. 

Section 18 Emergency Requests 

There were 28. Section 18 requests for sulfosulfuron. The requests were for grass control in grass 

crops and/or pastures. Overall there were 20 requests for the use of this herbicide to control 

johnsongrass in pasture and hay crops. In addition to these requests, there· were seven requests 

4 
for the use of sulfosulfuron to control grasses in -wheat ·and one request for grass control in rice 

for the years 1997 through 2007 (see Appendix A). 

DATA NEEDS RELEVANT TO BEAD'S FUTURE WORK ON SULFOSULFURON 

Obtaining additional jnfonnation on the following items would improve future BEAD 

assessments of the importance of sulfosulfuron and may be required as part of the registration 

review of this pesticide. 

Usage Information·Requested for Sulfosufuron: 

Usage data for use on: 

agricultural sites including pasture/rangeland/agricultural. fallow 

- non-agricultural sites including rights-of way, conservation areas, ditch backs, fencerows 

etc. 

forestry/nursery conifer release programs. 

Usage data should include the average application rate, use sites, pests and number of acres 

treated for each agricultural use site. 

OPP is also requesting infonnation regarding the drop in use of sulfosulfuron on winter wheat 

following the 2004 season. 

REFERENCES 

Appendix A Section 18 Data Base link: http://cfpub1 .epa.gov/oppref/section18/search.cfm 

GfK Kyrletec, 1998-2008. Proprietary Data. 

Kline Studies, Inc. 2006. Proprietary D.ata. 

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Appendix A 

Chemical Site Pest Applicant Received Response Status Tolerance Tolerance 

Date Date Publication Expiration 

SULFOSULFURON BERMUDA, JOHNSONGRASS GEORGIA 12715106 2/17/07 ISSUED 

BAHIA,GRASS, PASTURE 

HAYFIELD 

SULFOSULFURON BERMUDA AND BAHIA JOHNSONGRASS ARKANSAS 5/15107 5/29/07 ISSUED 

PASTURES, GRASS 

SULFOSULFURON BERMUDA, JOHNSONGRASS MISSISSIPPI . 1/17/07 2/17/07 ISSUED 

BAHIA;GRASS PASTURE 

HAYFIELD 

SULFOSULFURON BERMUDA, GRASS, JOHNSONGRASS ALABAMA 12/15106 2117/07 ISSUED 

PASTURE HAYFIELD 

SULFOSULFURON BERMUDAGRASS JOHNSONGRASS OKLAHOMA 6/7/06 9/18/06 WITIIDRA 

WN -

SULFOSULFURON BERMUDAGRASS JOHNSONGRASS OKLAHOMA 2/22/07 5/11/07 ISSUED 

SULFOSULFURON BERMUDAGRASS JOHNSONGRASS -South Carolina 3/20/07 4/2107 WITIIDRA 

WN 

SULFOSULFURON BERMUDAGRASS JOHNSONGRASS TEXAS 5/17/07 6/14/07 ISSUED 

SULFOSULFURON GRASS, PASTURE JOHNSONGRASS ALABAMA 3/3/05 9/23/05 ISSUED 1lI16/05 12/31/09 

SULFOSULFURON GRASS, PASTURE JOHNSON GRASS ARKANSAS 5/11106 5119/06 WITIIDRA 11/16/05 12131109 

WN 

SULFOSULFURON GRASS, PASTURE JOHNSONGRASS GEORGIA 2114/05 9/23/05 ISSUED 11116/05 12/31/09 

SULFOSULFURON GRASS, PASTURE JOHNSONGRASS GEORGIA 6/22/04 2/14/05 WI11HI>RA 11/16/05 12/31/09 

WN 

6 
SULFOSULFURON GRASS, PASTURE JOHNSONGRASS LOUISIANA 6/23/04 9123/05 ISSUED 11116/05 12131109 

SULFOSULFURON GRASS, PASTURE JOHNSONGRASS MISSISSIPPI 7/14/04 21f!05 VVI11HI>RA 11/16/05 12131109 

WN 

SULFOSULFURON GRASS, PASTURE JOHNSONGRASS MISSISSIPPI 211105 9/23/05 ISSUED 11/16/05 12131109 

SULFOSULFURON GRASS, PASTURE JOHNSONGRASS OKLAHOMA 6/15/04 10/18/04 VVI11HI>RA 11/16/05 12/31109 

WN 

SULFOSULFURON GRASS, PASTURE JOHNSON GRASS TEXAS 3/21106 7/26/06 ISSUED ll/16/05 12/31109 

SULFOSULFURON GRASS, PASTURE, JOHNSONGRASS LOUISIANA 6/12/07 6/25/07 VVI11HI>RA 

BERMUDA, BAHIA WN 

SULFOSULFURON GRASS, PASTURE, JOHNSONGRASS LOUISIANA 7/25/07 7/30/07 ISSUED 

BERMUDA, BAHIA 

SULFOSULFURON PASTURES, GRASS, JOHNSONGRASS ARKANSAS 5/15/07 5/29/07 ISSUED 

BERMUDA AND BAHIA 

SULFOSULFURON RICE BARNYARD GRASS ARKANSAS 2/10/00 317/00 ISSUED 

SULFOSULFURON WHEAT DOWNYBROME IDAHO 7/29/97 12/3/97 DENIED 

SULFOSULFURON WHEAT DOWNYBROME IDAHO 5/6/98 10/1/98 ISSUED 

SULFOSULFURON WHEAT CHEAT OKLAHOMA 8/10/98 10/1198 ISSUED 

SULFOSULFURON WHEAT DOWNYBROME OREGON 7/29/97 12/3/97 DENIED 

SULFOSULFURON WHEAT DOWNYBROME OREGON 4/27/98 10/1198 ISSUED 

SULFOSULFURON WHEAT DOWNYBROME WASHINGTON 7/29/97 '12/3/97 DENIED 

SULFOSULFURON WHEAT DOWNYBROME WASHINGTON 5/6/98 10/1/98 ISSUED 

7