UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 

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MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

SUBJECT: BEAD Chemical Profile (BCP) for Registration Review: Pyraclostrobin (099100) FROM:

THRU: Leonard Yourman, Ph.D., Plant Pathologist Biological Analysis Branch Jihad Alsadek, Ph.D., Economist Science Information and Analysis Branch 

### AndrewLee,Ph.D.,Econornist 

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Economic Analysis Branch 

# ?__ Biological and Economic Analysis Division (7503P) Arnet Jones, Chief Biological Analysis Branch Diann Sims, Chief Science Information and Analysis Branch
r Timothy Kiely, Chief 

# 9: W\_\. Economic Analysis Branch**~** Biological and Economic Analysi Division (7 TO: Jill Bloom, Chemical ReviewManager Risk Management and Implementation Branch 2 Pesticide Re-evaluation Division (7508P)
Peer Review Panel date: January 22,2014

SUMMARY Pyraclostrobin was first registered as a pesticide in the U.S. in 2002. This fungicide belongs to the quinone outside inhibitor (Qoi) group offungicides that includes azoxystrobin and numerous other fungicides.Based onprivate market usage data from 2002-2012, usage in agriculture averaged approximately one millionpounds active ingredient (a.i.) applied annually onapproximately 15 million acres treated. The average a.i. rate overthis time period was 0.067 pounds a.i./acre. A supplemental label for pyraclostrobin was given for use for "planthealth" in 2008. The use for this purpose may have resulted in anincrease inpyraclostrobinuse around 2008, onwheat (Hershman, 2011), com (UNL, 2007), soybean (Kyverygaet al., 2013), andpossibly sugarbeet (forpossible enhanced postharvest benefits) (Campbell et al., 2012). Florida and Louisianahave had emergency exemptions to use pyracl9strobin to manage brownrust and orange rust of sugarcane since no otherregistered products provided acceptable control. The most recent data onuse ofpyraclostrobin for non-agriculture is from 2011. There were approximately 33,000 pounds used by professional turfmanagement andhorticulture, 39,000 pounds a.i. on golfcourses, and 1,000pounds a.i. on institutional turffacilities (Kline, 2011). There were approximately 900,000 lb a.i. used in 2009 onnursery and floriculture (NASS 2009).



### INTRODUCTION The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an overviewofthe pest management roles and quantitative usage information for pyraclostrobin. The BCP includes summaries ofprevious BEAD products and available public and/orprivate use andusage data for pyraclostrobinto describe the role ofthis chemical in pest management. Additional information onuse is available in the pyraclostrobin PRD Label Data Report. Informationprovided in this BCP may be used by stakeholders (e.g., users and registrants), OPP risk assessors, OPP risk managers, and the general public during the Registration Review process ofthis pesticide.



### USE SITES Agricultural Use Sites Pyraclostrobin registered agricultural use sites include berries, currant, grapes, citrus, nuttrees, pome fruits, stone fruits, small fruits, tropical fruits, hops, mustard, safflowers, turmeric, cucurbits, melons, okra, conifer, fruiting vegetables, leafy vegetables, parsley, root crops, beans, com, peas, lentils, alfalfa, barley, oats, rye, wheat, triticale, sugarcane, ginseng, oil crops, cotton, flax, mint, olives, sorghum, sugar, sunflowers, soybeans, vegetable crops, forest plantations and rapeseed. Non-agricultural Use Sites Pyraclostrobin registered non-agricultural use sites include ornamentals, lilies, tulips and roses.

2FORMULATIONS AND APPLICATION METHODS Pyraclostrobin formulations include some forms containingpyraclostrobin as the sole fungicide material, such as Cabrio® EG and Headline®, and some formulations are marketed as a premixture ofpyraclostrobinplus other active ingredients, such as the Pristine® product. Some formulations marketed are granular, emulsifiable, flowable and soluble concentrate, solutionready to use and soluble concentrate/solid. Depending onlabel specifications pyraclostrobin may be applied as a ground spray, aerial application, in-furrow, orthrough irrigation systems.

PREVIOUS BEAD PRODUCTS REGARDING PYRACLOSTROBIN
A Screening Level Usage Analysis (SLUA) for pyraclostrobin was prepared in 2013 (BEAD, 2013). The SLUAprovided percent crop treated for more than 50 crops for which usage data were available. For pyraclostrobin, the agricultural sites withthe greatest number ofpounds used were for corn, soybeans and wheat. In terms ofthe percentcrop treated, corn averaged 1 0 percent crop treated followed by soybeans and wheat which averaged 5 percent crop treated each. Strawberries averaged 65 percent crop treated followed by cherries and caneberries 50 percent each, and blueberries and sugar beets 45 percent each. There are quite a few crops (seven ofthem inthe cropprofile) that are less than 2.5 percent crop treated such as lemons and pecans (BEAD 2013). The relativelyhighpercent crop treated on strawberries, cherries and cane berries may indicate high benefits, or at the very least, a high reliance onpyraclostrobinto control plantpests inthose crops. The OPP issued emergency exemptions for use ofpyraclostrobin (see Appendix B) to control Sclerotinia leafdrop in Belgian endive in California, orange rust in sugarcane in Florida, Texas, and Louisiana, and brownrust in Louisiana. For sugarcane uses emergency exemptions have been approved and are effective through 2014.

USAGE Agricultural Usage Based onprivate market usage data from 2002-2012, usage averaged approximately one million pounds active ingredient (a.i.) applied annually on approximately 15 million acres treated. The average a.i. rate overthis time period was 0.067 pounds a.i. /acre. Figure 1presents pyraclostrobin usage in pounds a.i. overthe 2002-2012 timeframe. Figure 2 presents total area treated in acres overthe same timeframe (Proprietary Data, 2002-2012). Pyraclostrobin use has increased steadily for 5-6 years following registration, buthas been steadythe last 5 years. This maybe due to the availability ofnewfungicide chemistries and the increasing importance of resistance management strategies that, for example, may limitthe number ofapplications. This might also be reflected in the total area treated may increase while amount applied may not follow the same trend.

3

### FIGURE 1. 

### Pyraclostrobin Usa e in Pounds Active Ingredient 2002-2012) 3,000,000 .,.--------------------------

Total Pounds AI

N 0 0 N m 0 0 N """ 0 0 N

Source: Proprietary Data, 2002-2012 1.() 0 0 N 1.0 0 0 N I' 0 0 N Years 00 0 0 N 0'1 0 0 N 0 rl 0 N rl rl 0 N



### FIGURE 2. Pyraclostrobin TotalArea Treated in Acres (2002-2012) 35,000,000

Total Area

Treated

N 0 0 N m 0 0 N """ 0 0 N

Source: Proprietary Data, 2002-2012 1.() 0 0 N 1.0 0 0 N I' 0 0 N Years 00 0 0 N 0'1 0 0 N 0 rl 0 N rl rl 0 N N rl 0 N

N rl 0 N

Table 1 shows the percentage oftotal pounds (lbs) applied and total acres treated (TAT) for the five crops withthe greatest usage. The increased use is likely due (at least in part) to a supplemental label approved by the Agency in 2008 that allowed the use ofpyraclostrobin for "planthealth" purposes without regard to the presence orpotential for disease (see the section "Role ofPyraclostrobin in Disease Management", below).

4

### Table 1. 

### PyraclostrobinTop Crops in Terms ofPercent ofTotalLbs. A.I. Applied & 

### Total AreaTreated (TAT) in Acres, 2008-2012 Crop Total Pounds Applied (A.I ) Total Area Treated Com 39% 33% Soybeans 24% 35% Wheat, Winter 7% 8% Wheat, Spring 5% 7% Sugar Beets 5% 2% Source: Propnetary data, 2008-2012 As seen in Table 2 below, pyraclostrobintop states interms ofbothpounds applied and total area treated are Illinois and Iowa. Ofthe majorusers, Indianahas the lowest use interms of pyraclostrobin percentages ofpounds applied and acreage treated, 6 percent for each.



### Table2. Pyraclostrobin Top States 1

### in Terms ofTotalLbs. A.I. Applied & 

### TotalArea treated (TAT) in Acres, 2008-2012 STATE Total Pounds Applied Total Area Treated Illinois 14% 15% Iowa 14% 14% California 8% 6% Minnesota 8% 8% North Dakota 7% 8% Nebraska 7% 7% Indiana 6% 6% Source: Propnetary data, 2008-2012 1. There over40 other statesthat use pyraclostrobin. The average a.i. rate for the top crops interms ofpounds a.i. applied was the highest for sugar beets at 0.146 lbs a.i. /acre andthe lowest for soybeans at 0.053 lbs a.i. /acre as shown in Table 3. Application Rates 

### Table3. Pyraclostrobin Use on Top Crops: Average A.I. Rate, 2008-2012 Crop AveragePounds Average Total Acres Avg. A.I. Rate (lbs Treated* a.i./acres) Com 829,027 8,966,593 0.092 Soybeans 500,368 9,379,542 0.053 Sugar Beets 98,329 669,534 0.146 Wheat, Spring 111,427 1,954,031 0.057 Wheat, Winter 153,920 2,043,353 0.075 *Total Acres Treated sums all acres treated for a crop, mcludmg those acres that receive multiple treatments. Source: Proprietary Data, 2008 -2012



### 5Geographic Distribution ofPyraclostrobin Use Agricultural Use Intensity ofPyraclostrobinUse inthe U.S. Another measure ofusage is the use intensity. In this analysis, the use intensity is expressed as the average annual amount (in pounds) ofthe active ingredient applied per 1,000 acres ofcrop acres grown. This differs from the application rate, which is expressed as the pounds a.i. applied per treated area. Figure 3 spatially represents pyraclostrobin use intensity in the U.S., which appears particularly high in Connecticut and Massachusetts, althoughBEAD was unable to determine a reason. California also shows relatively high use intensity due to use onthe high value crops almonds, grapes, strawberries and tomatoes. Formore information about the methodology ofthis map see Appendix A. Figure 3. Annual average agricultural use intensity ofpyraclostrobin (2008-2012).

Pounds Active Ingredient per 1,000 Crop Acres Grown 0No0ata 

### 0 <4 c:J4-7 8-12

- 13-19

- >19

Non-Agricultural Usage There were approximately 33,000 pounds used by professional turfmanagement and horticulture, 39,000 pounds a.i

. on golfcourse and 1,000 pounds a.i. in institutional turffacilities.

6There was approximately 900 pounds a.i. used in 2009 onnursery and floriculture (Kline, 2011; NASS, 2009). BIOLOGICAL ASPECTS RELEVANT TO PYRACLOSTROBIN The Fungicide Resistance Action Committee (FRAC) has designed a group cla

. ssification system based on a fungicide's mode ofaction (FRAC, 2013). Pyraclostrobin is classified as a quinone outside inhibitor (Qoi) fungicide and FRAC lists it as a Group 11 fungicide. Qoi fungicides (some Qoi fungicides are also called "strobilurin" fungicides) have been very important in disease management since the first product (azoxystrobin) was released in the late 1990s. They inhibit fungal respiration by binding to the "quinone outside" site ofthe mitochondrial cytochrome b protein. Whenthe compound binds to the site itblocks electrontransferbetween cytochrome b and cytochrome c, which disrupts synthesis ofATP and ultimately inhibits cell respiration. Several Qoi fungicides are currently registered including pyraclostrobin, azoxystrobin, trifloxystrobin, famoxadone, fenamidone, kresoxim-methyl. Pyraclostrobin, like other Qoi fungicices, exhibits translaminarmovement withinthe leaf(Vincelli, 2012). After application, most ofthe active ingredient is bound bythe leafcuticle, while some ofthe material moves into the underlying plant cells so that some ofthe chemical maybe effective ona side of the leafthat was not initially exposed upon application. Pyraclostrobin, and other Qoi fungicides, acts as an effective preventative fungicide since it inhibits fungal germination. Itis less effective as a curative treatment (afterthe plant is infected). Inthis case the fungicide is less effective against already present mycelial growththan as an inhibitor ofspore germination.

ROLE OF PYRACLOSTROBIN IN DISEASE MANAGEMENT Com, soybeans and wheat were the agricultural sites with the greatest number ofpounds used. Interms ofthepercent crop treated, com averaged 10 percent crop treated followed by soybeans and wheat which averaged 5 percent crop treated each. Strawberries averaged 65 percent crop treated followed by cherries and caneberries-50percent each, and blueberries and sugar beets-45 percent each. There are several crops (seven ofthem were listed inthe SLUA crop profile) that show less than 2.5 percent crop treated, such as lemons andpecans (BEAD, 2013). The relatively highpercent crop treated on strawberries, cherries and cane berries may indicate high benefits, or at the very least, a high reliance onpyraclostrobinto control plantpests in those crops. In 2008, the Agency granted a supplemental label for pyraclostrobin (Headline®) for use on registered crops for "disease control and plant health". The promotion ofthe use ofthe fungicide to gain additional "plant health" benefits (including stalk strength and increased yield) even in the absence ofdisease pressure has caused controversy withinplantpathology circles (e.g., Letter, 2009) and has been questioned interms ofeconomic returns (e.g., Anderson, 2012). A real orperceived benefit for increased yield orotherproperties (such as stalk strength) may have resulted in an increase inpyraclostrobin use around 2008, on wheat (Hershman, 2011), com (UNL, 2007), soybean (Kyveryga et al., 2013), and possibly sugarbeet (forpossible enhanced postharvest benefits) (Campbell et al., 2012).

7There are, however, many disease control uses ofpyraclostrobin on many crops targeting numerous pathogens. Pyraclostrobin is used to manage Cercospora leafspot, an important disease ofsugarbeet (Harveson, 2013). Recently, though, field resistance by Cercospora beticolato Qol fungicides has been reported for the first time (Kirk et al., 2012). Pyraclostrobin may be used on soybean where soybeanrust has been identified (Rupe and Sconyers, 2008). Soybean rust was first identified in the U.S. (it has been an important disease in Asia, Africa, and South America for several years) in 2004, but it has not generally been a significantpest problem. Florida and Louisiana have had emergency exemptions to use pyraclostrobinto manage brownrust and orange rust ofsugarcane since no otherregisteredproducts appearto provide acceptable control. Orange rust was first identified inFlorida in 2007 and brownrust was first identified inthe 1970s. Breedingresistance has beenthe standard means ofcontrol but pathogens breakdownresistance rapidly and fungicides are used to manage the diseases until new cultivars are released. Currently, there is a limited-time supplemental label coveringthe use on sugarcane. Resistance has been documented for some fungal pathogens (e.g, Kirk et al., 2012) andproduct labels have extensive resistant management language to maintain the effectiveness ofthis group offungicides. In spite ofresistance to some pathogens, Qolproducts are among the most widely used fungicides due to their effectiveness in managing many diseases caused by numerous fungal pathogens (Vincelli, 2012). Group 11 fungicides have been shownto exhibit cross-resistance; that is, apathogenthat has developed resistance to one ofthe Group 11 active ingredients is regarded to have resistance to the other Group 11 active ingredients. Nevertheless, each Qol active ingredient has a different chemical structure and characteristic (e.g., systemic mobility within the plant can vary among different active ingredients). Formany uses Qol fungicides may be considered interchangeable in terms ofeffectiveness, while in other situations individual Qol active ingredients may exhibit different levels ofefficacy (depending onthe crop system and pathogen). As such, in some situations, a particular Qol active ingredient maybe recommended, or not, in preference to another Qol fungicide. For example, azoxystrobin (a Qol fungicide) is highly phytotoxic to some apple varieties (due to genetic factors ofthe varieties) even when exposed by drift (Purdue, 2008). Other Qol fungicides including pyraclostrobin are used on apple trees to control apple scab. Pyraclostrobin is used as a foliar treatment for blackleg of several Brassica (cole) crops and is the only Qol fungicide listed by some extension services for managing blackleg for these crops (e.g., Cornell, 2013; Midwest, 2013; KY, 2013). Pyraclostrobin is usedto treat 15 percent ofapples, 10 percent ofcabbage, 5percent ofbroccoli and less than 2.5 percent ofcauliflowers.

DATANEEDS The Agency currently does not have important information onpyraclostrobin. Our databases do not survey certain registered crops such as: currant, tropical fruits, hops, mustard, safflowers, turmeric, okra, conifer, parsley, lentils, alfalfa, barley, oats, rye, triticale, ginseng, flax, mint, olives, sorghum, sugar, sunflowers, rapeseed, ornamentals, lilies, tulips and roses. Information such as typical rates, pounds applied, application methods and timing may be useful in future assessments ifrisks are indicated and may improve future assessments conducted bythe Agency related to the use and benefits ofpyraclostrobin. Information regarding recent incidences of ·

8resistance to pyraclostrobin leading to any failures in disease management will help inbenefits assessments.

REFERENCES Anderson, B. B. 2012. Question fungicide use. Com & Soybean Digest. Dec. 14, 2012. http:/I comandsoybeandigest.com/ crop-chemicals/ question-fungicide-use BEAD. 2013. Screening Level Usage Analysis-Pyraclostrobin. Biological and Economic Analysis Division, Office ofPesticide Programs, US Environmental Protection Agency. April 15, 2013. http://iaspub.epa.gov/apex/pesticides/f?p=CHEMICALSEARCH:3:0::N0:1,3,31,7,12,25:P3 XC HEMICAL ID:3649 Campbell, L., Fugate, K., and Smith, L. 2012. Effect ofpyraclostrobin onpostharvest storage and quality ofsugarbeet harvested before and after a frost. USDA-ARS. https:/ /www.ars.usda.gov/researchlpublications/publications.htm?seg no 115=271284 Cornell. 2013. Chapter 15-Cabbage, Broccoli, Cauliflower, and Brussels Sprouts. 2014 Integrated Crop and Pest Management Guidelines for Commercial Vegetable Production, Cornell University Cooperative Extension. http:/ /veg-guidelines.cce.comell.edu/15frameset.html Harveson, R. M. 2013. Cercospora leafspot ofsugar beet. University ofNebraskaExtension Publ. G1753. http://ianrpubs.unl.edu/live/g1753/build/g1753.pdf Hershman, D. E. 2011. Fungicide use in wheat. University ofKentucky Extension Publ. PPFSAG-SG-05. http:/ /www2.ca.uky.edu/agcollege/plantpathology/ ext files/PPFShtml/ppfsagsg5.pdf Kirk, W. W., Hanson, L. E., Granc, G. D., Stump, W. L., Gachango, E., Clark, G., and Stewart, J. 2012. First report ofstrobilurinresistance in Cercospora beticola in sugar beet (Beta vulgaris) in Michigan andNebraska, USA. New Disease Reports 26:3. http:/ /www.ndrs.org.uk/pdfs/026/NDR 026003.pdf Kline. 2011. Kline Professional Turfand Ornamental Markets for Pesticides and Fertilizers 2012.
KY. 2013. 2014-2015 Vegetable Production Guide for Commercial Growers. Cole Crops, p. 33. http:/ /www2.ca.uky.edu/agc/pubs/id/id36/020-077.pdf Kyveryga, P.M., Blackmer, T. M., and Mueller, D. S., 2013. When do foliar pyraclostrobin fungicide applications produce profitable soybean yield responses? PlantManagement Network Plant Health Progress, Sept. 28, 2013. http://www.isafarmnet.com/pdf/Fungicide Soybean Plant Health Progress 2013.pdf



### 9Purdue. 2008. Facts for fancy fruit. Purdue University Extension vol. 8, Issue 7, July 14, 2008. http://www.hort.purdue.edu/fff/FFF08/FFF08-07.pdf
Letter. 2009. Letter from Universities Regarding the Strobilurin, Pyraclostrobin (Headline), Supplemental Label, Feb. 13, 2009. http://www.epa.gov/pesticides/regulatinglheadline-letter.pdf Midwest. 2013. Brassica and Leafy Greens, p. 82. Midwest Vegetable Production Guide for Commercial Growers, 2014. http://www.btny.purdue.edu/pubs/id/id-56/80 ColeBrassica.pdf NASS. 2009. USDA Nursery and Floriculture. http://www.nass.usda.gov/Data and Statistics/PreDefined Queries/2009 Nursery and Floriculture Chern Usage/index.asp Proprietary Data. 2002-2012. (pesticide usage data) Rupe, J. and Sconyers, L. 2008. Soybean Rust. APSnet, The Plant Health Instructor. http://www.apsnet.org/edcenter/intropp/lessons/fungi/Basidiomycetes/Pages/SoybeanRust.aspx
UNL. 2007. Results ofNebraskafoliar fungicide trials on com. University ofNebraska Extension CropWatch, July 13, 2007. http:/ /cropwatch.unl.edu/web/cropwatch/archive?articleid=.ARCHIVES.2007.CROP18.CORN FUNGICIDES.HTM USDA, 2006-2010. NASS Crop Reporting Districts (shape file ofCRDs). Available at: http://www.ers.usda.gov/briefing/arms/resourceregions/resourceregions.htm#nass

. http://www.nass.usda.gov/Data and Statistics/County Data Files/Frequently Asked Questions /county list.txt USDA, 2007. Census ofAgriculture. (Land in Farms). Available at: http://www.agcensus.usda.gov/Publications/2007/index.asp

. Vincelli, P. 2012. Qoi (strobilurin) fungicides: Benefits and risks. Plant Health Instructor, APSnet Publication. http://www.apsnet.org/edcenter/advanced/topics/Pages/StrobilurinFungicides.aspx

.

10APPENDIX A The map included herein is primarily for the use ofthe risk assessors in the Environmental Fate and Effects Division. The map provides a very broad geographical view ofthe average annual amount (in pounds) ofthe active ingredient appliedper 1,000 acres ofcrop acres grown. These data are included inthe maps because risk assessors are interested inthe amount ofa pesticide used across agricultural land. The calculated values presented inthe map are not equivalentto an application rate (lb ail A). The dataused to make these maps have several limitations. Any interpretation ofthe maps should consider the underlying data and the associated limitations carefully. The numerator (annual average pounds applied) is based onprivate market surveys ofpesticide use in agriculture averaged overthe last five years (Proprietary Data, 2008-2012). These surveys cover about 60 crops and are targeted in states that produce the majority ofthe crop. Although the surveys capture most ofthe use ofa particular active ingredient in agriculture, there are several limitations to these surveys.

• States with minor production ofa surveyed crop are not sampled • Not all types ofpesticides are surveyed in every crop in every year • Many specialty crops with very small acreages are not included in the survey The result ofthese limitations is that states that showno usage may actually have a small amount ofthe active ingredient being used. In some cases the displayed use intensity may be distorted because the surveyed crops and the reported pesticide usage may not accurately represent the actual pesticide usage onthe crops produced in the state. The denominator (1,000 crop acres grown) was also obtained from the same private market survey database. The "Crop Acres Grown" variable represents the total acres grown in a given state ofall ofthe surveyed crops. This value is independent ofpesticide usage and pesticide registration. Itis important to note that the surveyed crops (about 60) are sampled from states that are majorproducers ofeach crop. Therefore, there are cases where the actual crop acreage in a state is higher thanthat reported by crop acres grown in the survey because eitherthat state and/or crop was not included in the survey. The reader shouldpayparticular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical as the legend bins will likely be different.



### 11A 

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### b. b OPP lppen IX 

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### wn ctwns on :'yrac os ro m ::>Y Site Pest Applicant Response Status Date BELGIANENDIVE White Mold (Sclerotinia CALIFORNIA Il/Il/20II ISSUED sclerotiorum) BELGIAN ENDIVE White Mold (Sclerotinia CALIFORNIA Il!I5/20I2 ISSUED sclerotiorum) BELGIANENDIVE White Mold (Sclerotinia CALIFORNIA IO/I4/20IO ISSUED sclerotiorum) BELGIAN ENDIVE White Mold (Sclerotinia CALIFORNIA Il/29/2007 CRISIS APPROVED sclerotiorum) BELGIAN ENDIVE White Mold (Sclerotinia CALIFORNIA 9/30/2008 WITHDRAWN sclerotiorum) BELGIAN ENDIVE White Mold (Sclerotinia CALIFORNIA I 11I4/2008 ISSUED sclerotiorum) BELGIAN ENDIVE White Mold (Sclerotinia CALIFORNIA I 1120/2007 WITHDRAWN sclerotiorum) BELGIANENDIVE White Mold (Sclerotinia CALIFORNIA I0/30/2013 WITHDRAWN sclerotiorum) BELGIAN ENDIVE White Mold (Sclerotinia CALIFORNIA Il/I3/2009 ISSUED sclerotiorum) SUGARCANE ORANGE RUST FLORIDA 11Il/20I2 ISSUED SUGARCANE ORANGE RUST FLORIDA 11II/20I2 ISSUED SUGARCANE ORANGE RUST FLORIDA IO/I/2009 ISSUED SUGARCANE ORANGE RUST FLORIDA IO/I/2009 ISSUED SUGARCANE ORANGE RUST FLORIDA 4/I8/2008 CRISIS APPROVED SUGARCANE ORANGE RUST FLORIDA 4/I8/2008 CRISIS APPROVED SUGARCANE ORANGE RUST LOUISIANA 3/27/20I2 ISSUED SUGARCANE ORANGE RUST LOUISIANA 3/27/20I2 ISSUED SUGARCANE BROWNRUST LOUISIANA 2/I2/20I3 ISSUED SUGARCANE BROWN RUST LOUISIANA 2/I2/20I3 ISSUED SUGARCANE ORANGERUST LOUISIANA I0/112009 ISSUED SUGARCANE BROWN RUST LOUISIANA 3/22/20I2 ISSUED SUGARCANE BROWN RUST LOUISIANA 2/4/2009 ISSUED SUGARCANE BROWNRUST LOUISIANA 2/4/2009 ISSUED SUGARCANE BROWNRUST LOUISIANA 4/29/2008 ISSUED SUGARCANE BROWN RUST LOUISIANA 4/29/2008 ISSUED SUGARCANE BROWN RUST LOUISIANA 3/22/20I2 ISSUED SUGARCANE ORANGE RUST LOUISIANA I0/112009 ISSUED SUGARCANE ORANGE RUST TEXAS 6/I4/20IO ISSUED SUGARCANE ORANGE RUST TEXAS 6/I4/20IO ISSUED

12