UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D

. C

. 20460 

### JAN 2 2 2015

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION MEMORANDUM
SUBJECT: BEAD Chemical Profile for Registration Review: Mancozeb (014504) FROM:

THRU:



### TO: Carl Chen, Plant Pathologist Biological Analysis Branch 

# C. \ , I Cynthia Doucoure, Environmenta l Protection Specia li st**~** Science Information and Analysis Branch**~** Derek Berwald, Economist

# ~~ Economic Analysis Branch Biological and Economic Analy · Arnet Jones, Chief Biological Analysis Branc Diann Sims,

# Chief~ Science Information and Analysis Branch Timothy Kiely, Chief 

# Ql**~** Economic Analysis Branch 

# \AA- Biological and Economic Analy · Division (7 ) Christina Schelterha, Chemical Review Manager Risk Management and Impl ementation Branch III .Pesticide Re-evaluation Division (7508P)
Product Review Panel date: November 26, 2014

Page 1 of 11

### SUMMARY
. Mancozeb, a broad spectru m fungicide, was fir st registered in the U.S. in 1948. A Reregistration E ligibility Deci s ion (RED) was issued for mancoz eb in September 2005
. Review of recent u se patterns and previou s assessments of mancozeb indicate that it i s an important fungicide in many areas of agriculture. 

### INTRODUCTION Th e purpose of this document is to convey u sage inf o rm ation and a b road overv iew of the pest management ro les of mancozeb that is beginning to undergo reg ist ration review. The anticipated audi ence consists of the team of EPA staff curren tly evalua ting the registration statu s ofmancozeb, and eventually the general public. Thi s document builds up on th e data BEAD provides in the Screening Level Usage Analys is (SLUA ) to Regi s tration Review teams. The d oc ument i s base d on info rmation and data available to BEAD as of November 2014. 

### IDSTORY OF BEAD ASSESSI\1ENT S FO R MANCOZEB BEAD prepared a Scr ee ning Level Usage Analys is (S LUA) in Augu st 2014 that provided ave ra ge perc ent crop treated (PCT) values f or 35 cro p s. The crops with the highest PCT values are onions (60%) , p otatoes (55%), potatoe s ( seed treatment), pears, and watermelon (45% each), apples (40%) , and walnuts (35%). Other crops with PCT values b etw ee n 2 0 % a nd 30% are c ucumbers, le ttuce, s quash, and tomato es. The crops with the hi gh est ave rage annual pound s a.i. a pplied are po tatoes (2.2 million), apples (1.2 million) , tomatoes (50 0 , 000) , and onion s a nd walnuts (4QO,OOO each). Other crop s with avera ge annual pound s a.i. applied of between 100,000 and 300 ,000 include c ucumbers, grap es, pears, sweet corn, and watermelon. Other recent BEAD assess ments for mancoz eb include evaluation of Sectio n 1 8 emergency exemption u ses for man cozeb in walnut (Yourman 2012, 2011, and 2009, g inse ng (Chandgoyal 2 010 and 200 8) , and peppers (Yourman and Faulkn er , 2010), all high value crop s . These assess men ts echo the information in the 2005 mancozeb Reregi s tration Eli gib ility Decision (EPA 2005), which indicate s th at man cozeb is an imp ortan t tool to man age re s i stance to other fung ic ides s u ch as cop pe r. The section 18 requests for wa lnuts in parti cular were longs tanding, hav ing been granted s in ce th e early 1990 s. Mancozeb was grante d a S ecti on 3 reg is tration on walnuts in 20 1 3.


### COMMON FORMULATIONS AND APPLICATION .METHODS Mancozeb is formulated as either a dry flowable , flowable concentrate , wettable powder, or du st an d applied via ground s prays, aircra ft, chemigat ion, seed treaters, drenchers o r dip tanks.

Page 2 of 11USE SITES Agricultural Use Sites Mancozeb is registered for use on fruit , including pome fruit, tropical fruit, bananas, cranberry, grapes, and papaya; vegetables, including cucurbits, cruciferslbrassica, asparagu s, beets, sugar beet, carrots, lettu ce, peppers, sp inach , tomatoes, endive escarole, fennel, Swiss chard, garlic, leek, onion , shallot, and parsnip; herbs, including coriander, parsley, dill, and arugula; nut trees , inclu ding almonds and walnuts; row crop s.1 including corn, cotton, p eanuts, potatoes, tobacco , and cereal grains (barley , oat, rye, whe at, triticale, and rice); and other crops, including plantain, caprifig, flax, ginseng, safflower, and sorghum. Mancozeb i s also used on the seeds of row crops, flax, safflower, sorghum, and tomatoes. Non-Agricultural Use Sites: Mancozeb is reg istered for use on ornamental s plants in nurseries and greenhouses, conifers, sod farms, and commercial lawns and turf (go lf courses, parks, cemeteries , etc.).
MANCOZEB USAGE Agric ultural Usage Trend Based on available private and public market research, mancozeb use in terms of pounds a.i. app li ed in the U.S. h as remained fairly constant during the 1998 -2012 time frame with very s light decreases in years (2006-2009) as shown in Figure 1. Similar trend s were found for total area treated, as shown in Figure 2. During the 1998 -2 012 time frame, approximately 6.4 million pounds a.i. were applied on average annually to treat 4.5 million acre s at an overall average a.i. application rate of 1 .4 lb s a.i. per acre. During the 2008-2012 time frame , approximately 6 mi ll ion pounds a.i. were applied annually on average to treat 4 million acres at overall average a. i. application rate of 1.5 lb s a.i. per acre.

Page 3 of 11Figure 1. Mancozeb Pounds A.I. Applied, 1998-2012

"'0**~** a. 0.. <! <i Ill "'0 c: ::l 0 0.. 8,000,000

0 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Year S o urce: Pro prietary Data , 1998-2012 Figure 2. Mancozeb Total Area Treated (In Acres), 1998-2012
6,000,000

0 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Year Source: Proprietary Data, 1998-2012 Page 4 of 11Mancozeb T op Crops, 2008-2012 During the 2008-2012 time frame, mancozeb is reported to be used on over 30 crops. However, in terms of the percent of total pounds a.i. applied , mancozeb is used predominantly on potatoes (33%) and apples (23%) as shown in Table 1. Together, these crops constitute over 50% of the total mancozeb use during this period. For potatoe s, approximately 2 million pounds a.i. were applied on average annually to 1 .8 million acres at an application rate of approximately 1.0 lb a.i. per acre. For app les, approximately 1.4 million pounds a.i. were applied on average annually to 550,000 acres at an application rate of2.6lbs a.i. per acre. The remainder of the mancozeb use is divided amongst the 28 remaining crops with extensive use (5-6% of total pounds a.i. applied) on onions, tomatoes, walnuts, and watermelon. 

### T b l 1 M

a e ancozebT C op rops, 2008 2012


## - Top Crops Percentage Percentage Avg A.I. Rate Labeled Max App of Total of Total (lb a.i./acre) Rate per Pounds A.I. Area Application

App li ed Treated ( lb a.i./ac re) Potatoes 33% 43% 1.0 1.6 Apples 23% 13% 2.6 4.9 Onions 6% 6% 1.4 2.4 Tomatoes 5% 7% 1.0 2.4 Walnuts 5% 4% 1. 8 1.8 Watermelon 5% 5% 1.4 2.4 Other* 23% 22% *Other crops include almonds , asparagus, beans , broccoli , cabbage , cantaloupes , carrots, cauliflower, cherries , cotton , cucumbers, garlic , grapes (raisin, table , and wine), lettuce , oranges, peaches, peanuts , pears , peppers, pumpkins, spinach , squash, suga r beets, sweet com , tobacco , and wheat (sp ring and winter)
. Sources: Propnetary Data , 2008 -201 2 Mancozeb LUIS Report, EPA, 2014
Mancozeb Top States, 2008-2012 During the 2008-2012 time frame , mancozeb is reported to be used in over 30 states. However , in terms of the percent of total pounds a.i. applied , mancozeb is used predominantly in the states of California (17%) , New York (13%), Florida (12%), Michigan (12%) , and Idaho (8%) as shown in Table 2. Together , these states constitute 60% of the total mancozeb use during this period.

Page 5 of 11T bl 2 M a e bT S ancoze op tates, 2008 2012



### - Top States Percentage of Percentage of A vg A. I. Rate To tal Pound s A.I. Total Area (lb a.i./acre) Applied Treated California 17% 15% 1.6 New York 13% 9% 2.0 Florida 12% 17% 1.0 Michigan 12% 8% 2
. 2 Idaho 8% 10% 1.0 Other* 38% 41% *Other states include AL, AR, CO, DE , GA, IL, IN , KS , KY , ME, MD, MA, MN , Ml , MT , NE, NJ, NM, NC, ND, OH, OK , OR, PA, SC, TN, TX, VA, WA, WV, and WI. Source: Propnetary Data, 2008-2012 Agricultural Use Intensity of Mancozeb Use in the U
. S
. Another measure of usage is the use intensity
. In this analysis, the use intensity is expressed as the average annual amount (in pounds) of the active ingredient applied per 1,000 acres of crop acres grown. This differs from the application rate, which is expressed as the pounds a.i. applied per treated area. F i gure 3 spatially represents mancozeb's use intensity in the U.S. in New York, which is driven by production of apples, wine grapes, and onions; in California, which is driven by production of walnuts, pears, lettuce, and table grapes; in Florida, which is driven by production of tomatoes, sweet corn and watermelon; and in Michigan, which is driven by production of apples and potatoes. The higher use intensity in New Jersey, Maine, and Massachusetts results from low crop acres grown within the states. For more information on Figure 3, see Appendix A.

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### Figure 3. Annual average agricultural use intensity of Mancozeb (2008-2012)
.

Pounds Active Ingredient per 1 , 000 Crop Ac r es G rown CJNoD ata < 1 1

- 10

- 10

- 100

- 100

- 25 0

- > 250 (Source: Proprietary Data, 2008-2012) Non-agricultural Usage BEAD reviewed available data on mancozeb use in the non-agricultural markets and found that the major non-agricultural use reported was in the nursery and floriculture market and on golf course turf In 2009, approximately 367,400 lb s a.i. were applied in the U.S. nursery and floriculture market at an average a.i. application rate of 1.3 lb s a.i. per acre as shown in Table 3. In 2011, approximately 278,000 lbs a.i. were applied on golf courses in the U.S. , which constitutes nearly 90% of the total pounds a.i. applied in the professional turf market as shown in Table 4 , although it appears that lawn care operators applied more than ten times as much mancozeb in 2004 than they did in 2011.

Page 7 of 

### 11Table 3. Mancozeb Use in Nursery & Floricultur e Sector Year Total Lbs 

### A.I. Avg A.I. Rate (lbs A.I./acre) Nursery & 2006 623,000 Floriculture 2009 367,400 Source: USDA NASS , Ag Chemtcal Usage Reports, 2006 and 2009
Table 4. Mancozeb Use in Professional Turf Market

Sector 2004 Golf Courses 249,000 Landscape Contractors 33,000 Lawn Care Operators 174 ,000 Institutional Turf 4,000 Turf Farms N/A Total 460,000 Sources: Kltne & Company, 2004 and 2006 Propri e tary Data, 20 II Total Lbs A.I. 2006 242,000

15,000 13,000

N/A 10,000 280,000 1.3 1.3

2011 278,000

N/A 13,000 7,000 13 ,000 311,000

BIOLOGICAL ASPECTS RELEVANT TO MANCOZEB Mancozeb is a broad-spectrum non-systemic protectant fungicide and an EBDC (ethylene bisdithiocarbamate) fungicide. It belongs to the chemical group of dithiocarbamates and relatives classified by the Fungicide Resistance Action Committee (FRAC) as M3 and generally considered as a low ri s k group witho ut any s i gns of re s istance developing to the fungicides (FRAC, 2014). Its multi-site contact activity with a low risk in resistance development is an asset in a disease control and resistance management program.
ROLE OF MANCOZEB IN PEST MANAGEMENT Mancozeb is registered for control of many important plant diseases. Late b li ght and early blight are the top two di seases targeted in mancozeb u ses, each of which with over one million acres treated annually in th e United States (Proprietary Data, 2008-2012). Apple scab i s among other top diseases targeted by mancozeb use, which is the mo st common seriou s apple disease worldwide, mainly controlled with fungicide sp ray s (USDA, 2001; USDA, 2004). 

### In the United States, approximately two thirds of apple acreage treated by mancozeb , in terms of total acres treated, was for control of apple sca b (Proprietary Data, 2008-2012).
Page 8 of 11Mancozeb is registered fo r use on numerous crops including vegetables, field crops , tree crops, and ornamental s. In 20 12 , it was the either No. 1 or No
. 2 fungicide a m ong all fun gici de s in terms of total ac res treate d in the United Stat es on crops s uch as apple, cucumber, lettuce , onion , pepper , potato , squash, walnut , and watermelon (P roprietary Data , 20 12). Mancozeb plays an important role for contro l ofplant bacterial di se ases. Proprietary Data (2008-20 12) provided informat ion on the top fiv e bacterial diseases in terms of total acres treated in the Un ited States, and mancozeb was the most-applied che mi cal (except for copper hydro x ide) to control four of th e m. One ofthem was walnut blight where manc ozeb had been used under emergency exemptions through Section 18 of the Fed eral In se cticid e, Fun gic ide , and Rod enticide Act (FIFRA) on approximately 45 percent of walnut acreage in California (Proprietary Data , 20 11- 2012). Mancozeb i s now reg is tered for u se on walnuts. Manco zeb has also been used in some states through FIFRA Sect ion 24(c) for pest management including to bacco di seases in Connecticut, Kentucky , No rth Carolina, Ohio, Pennsylvania , South Carolina , and Virginia; pear psylla nymphs in Oregon and Washington ; and diseases of smallseeded vege tabl e seed cro ps in Oregon and Was hin gto n (CDMS , 20 14). In s umm ary, mancozeb is an important fungicide in many areas of agriculture, includ ing its si gnificant role in pest management , resistanc e management , and the U.S
. fu n gic ide market. INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON MANCOZEB The Agency c urrently does not have compl ete information on mancozeb. Obtaining the following usage information ma y impro ve future assessments conducted by the Agency rela ted to the use and importance of mancozeb: the importance of mancozeb for re s is tance management with other fu n gic ides , and any new information on alternati ves to mancozeb.
REFERENCES CDMS. 201 3. C rop Data Management Sys tems. Availabl e at http: // premier.cdms.net/webapl s. Accessed Nove mb er 20 14
. EPA. Reregistration E li gibi lity D ecis ion for Mancozeb, September 2005 EPA, Mancozeb Scree nin g Level Usage Analysis (S LUA), August 20 14 FRAC. 2013. Fu ngicide Re sistance Action Co mmittee. Available at http: //www.f rac.info/fra c/index.h trn
. Accessed November 2014. Proprietary D ata, 1 998-2012. US DA. 2001. C rop Profile for Apples in Washington. Avail able at: http: //www. ipmcenters.org/cropprofiles/docs /WAAppl es.pdf. Accessed November 2014. Page 9 ofllUSDA. 2004. Crop Profile for Apples in Michigan. Available at: http: //www.ipmcente rs .or g/cro pprofiles/docs/M lapples.pdf. Accessed November 2014
. USDA NASS, Ag. Nursery and Floricultur e, 2006 an d 2 009. Yourman, Leonard
. A Review of a Request for an Exemption to Use Mancozeb fo r a Long Running Emergency of Walnut Bli ght in Cali f o rni a (09

- CA

- 13; DP36608 5). July 9, 2009. Yourman, Leonard. A Review of a R ecertification Request for an Emer gency Exemption to Use Mancozeb to Treat Walnut Blight in California (11 CA0 1 ; DP3857 1 9) Febr uary 18 , 2011. Yo urman , Leonard . A Review of an E m erge ncy Exe mption Request to Use Mancozeb in California on Walnut Trees to Control Walnut Bligh t (13CA03; DP 407267)
. Decemb er 19, 20 12. Yourm an, Leonard and John Fa ulkner
. Reque st fo r an Emergency Exemption to Use Mancozeb to Manage Bacterial Leaf Spot on P eppers (IOOADI , DP3 7685 7; 10KY 04 , DP377474; l ONJDI, DP3 76863). July 8, 2010
. C hand goyal , Ta ra. Review of a Sec tion 18 R equest for the Emergency Exempt io n Use of Mancozeb on Ginseng in Michigan (07-MI-07 , DP # 3504 1 · 0) to Cont ro l Phytophthora cactoru m Leaf Blight and Root Rot Disea ses . Ap ril 1 6,20 08
. C handgo yal , Tara. B E AD Review of Wisconsin E mergency Exempti on R equest for Use of Gave l 75DF (a premix ofzoxarni de and mancozeb) o n Ginseng to Contro l Phytophthoro cactorum Blight (10-WI-08 , DP # 3789 6 5 )
. Jul y 29 , 2010.

Page 

### 1 0 of 11APPENDIX A
The map included herein is primarily for the use of the risk assessors in the Environmental Fate and Effects Division. The map provides a very broad geographical view of the average annual amount (in pounds) of the active ingredient applied per 1,000 acres of crop acres grown. These data are included in the maps because risk assessors are interested in the amount of a pesticide u sed across agricultural land. The calculated value s presented in the map are not equivalent to an appl ic ation rate (lb ai/ A). The data used to make these maps have several limitations. Any interpretation of the maps should consider the underlying data and the associated limitations carefully. The numerator (annual average pounds applied) is based on private market surveys of pesticide use in agriculture averaged over the last five years (Proprietary Data, 2008-2012). T h ese surveys cover about 60 crops and are targeted in states that produce the majority of the crop. Although the surveys capture most of the use of a particular active ingredient in agriculture, there are several limitations to these surveys.
• States with minor production of a surveyed crop are not sampled • Not all types of pesticides are s u rveyed in every crop in every year • Many specialty crops with very small acreages are not included in the survey The result of these limitations is that st ates that show no usage may actually have a small amount of the 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 on the crops produced in the state. The denominator (1,000 crop acres grown) was al so obtained from the same private market survey database. The "Crop Acres Grown" variable represents the total acres grown in a given state of all of the surveyed crops. This value is independent of pesticide usage and pesticide registration. It is important to note that the surveyed crops (about 60) are sampled from states that are major producers of each crop. Therefore, there are cases where the actual crop acreage in a state is higher than that reported by crop acres grown in the survey because either that state and/or crop was not included in the survey . The reader should pay particular 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 d if ferent.

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