### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION



## MEMORANDUM

SUBJECT:

TO:

FROM:

THRU: PC Code: 077501

DP Barcode: D405977

May 29,2013

Environmental Fate and Ecological Effects Preliminary Risk Assessment for

the Registration Review of Sulfur

Jose Gayoso, Chemical Review Manager

Cathryn Britton, Team Leader

Kevin Costello, Chief

Risk Management and Implementation Branch II

Pesticide Reevaluation Division (7508P)

# ~~k4-- Jose L. Melendez, Chemist 

# f

. -::-

Keith Sappington, Senior Science Advisor 

# fJ. 'I?!

Environmental Risk Branch V

Environmental Fate and Effects Division (7507P)

· 

# .:;jz q 

# /13

Mah T. Shamim, Ph.D., Chief

# .JJIJ~ Environmental Risk Branch V // 

# ;rr _:::..::.-----

Environmental Fate and Effects Division (7507P)

The**Environm~ntal** 

## Fate and Effects Division completed the environmental fate and ecological

effects risk assessment for the Registration Review of the active ingredient elemental sulfur (PC

Code 077501). The qualitative assessment concludes that terrestrial arthropods on the target

areas may be adversely affected by the registered uses of sulfur. Based on assumed

concentrations of sulfur in water at its reported solubility (4.87 ppb), risks to aquatic animals are

below levels of concern for listed species. Qualitatively, acute risks to mammals, birds, and by

extension, risks to terrestrial-phase amphibians and reptiles for which avian toxicity data are use

as a surrogate, also appear to be very low from registered uses of sulfur. For terrestrial plants, in

this risk assessment, it is assumed that some terrestrial plants may be susceptible to the effects of

sulfur application; although the number and spatial extent of these potentially susceptible species

are considered uncertain.

1

# Preliminary Environmental Fate and Ecological Risk

Assessment for the Registration Review of Sulfur

Sulfur

CAS Registry Number 7704

- 34

- 9

List A, Case #0031, PC Code 077501

April 30 , 2013

DP Barcode D405977

Prepared by:

U. S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch IV

1200 Pennsylvania Ave., NW

Mail Code 7507P

Washington DC 20460 José L. Meléndez, Chemist, ERBV

Keith Sappington, Senior Science Advisor, ERBV

Reviewed by:

Allen Vaughan, RAPL , ERBV

Michael Barrett, Senior Fate Scientist , ERBV

Mah T. Shamim, Ph.D., Branch Chief, ERBV

## Page 1 of 59 

## Table of Contents

I. Executive Summary

................................ ................................ ................................ .................... 2

II. Problem Formulation

................................ ................................ ................................ ........... 4

A. Nature of Regulatory Action

................................ ................................ ............................ 5

B. Stressor Source and Distribution

................................ ................................ ...................... 5

C. Receptors

................................ ................................ ................................ ........................ 10

D. Assessment Endpoints

................................ ................................ ................................ .... 11

E. Conceptual Model

................................ ................................ ................................ .......... 15

III. Risk Characterization

................................ ................................ ................................ .............. 16

A. Ri sk Estimation

................................ ................................ ................................ ................... 16

B. Risk Description

................................ ................................ ................................ .................. 18

B. Endangered Species Considerations

................................ ................................ ..................... 20

IV. Bibliography

................................ ................................ ................................ .......................... 24

Appendix A. Listed Arthropods in the US

................................ ................................ ................... 27

Appendix B. Registered uses for Sulfur

................................ ................................ ....................... 29

Appendix C. Environmental Fate and Effects Data Requirements for Sulfur

.............................. 57

## Page 2 of 59 

## I

. Executive Summary

Elemental sulfur is a fungicide/insecticide /acaricide undergoing Registration Review.

Additionally, s ulfur is used as an amendment to decrease the pH of alkaline soils; usually the

chemical is applied at much higher rates for this purpose than when it is used as a pesticide

. For

example, the maximum single application rate allowed for sulfur is 122.5 lb S/A on citrus crops,

while according to , for example, an Ohio State University Extension Fact Sheet

, up to 3310 lb

S/A would be applied to a clay soil to lower the pH from 8.5 to 5.5 (Mullen et al. 2007 1 

## )

. S ulfur

is widely used as a soil amendment to increase fertility and/or reduce the pH of highly alkaline

soils. Since they are not pesticidal, uses of sulfur for soil amendments are not assessed in this

review. Finally, this assessment does not include the uses of sulfur in fumigant gas cartridges,

which were evaluated separately (DP Barcode D375973, March 30, 2010)

.

Formulations of sulfur pesticides include dust (D), water dispersible granules or dry flowable

(DF), emulsifiable concentrate (EC), flowable concentra te ( F ), liquid (L), liquid ready

- to

- use

(RTU), wettable powder (WP), and wettable powder/ d ust (WP/D). Sulfur has pesticidal uses on

numerous crops including field crops, vegetable crops, fruits/nuts and berries, and ornamentals.

Elemental sulfur is regi stered for use on crops as a fungicide/insecticide at relatively high rates

up to 122.5 lb a.i./ A per application

. Ex amples of target pests include a pple cedar rust, b lack rot,

f rog eye leaf spot, p owdery mildew, q uince rust, s cab an d s ooty blotch on apple crops ; and

Yuma spider mite, r ust mite and c lover mite on citrus crops. Historically, sulfur has been

extensively used in the U.S. ; grapes is the major crop, with available information indicating

application of 4 2 million pounds annually on grapes s ee Table 3 . According to the table, six

other crops have estimated usage exceeding 1 million pounds annually.

Although sulfur has insecticidal and fungicidal properties when used as directed , it is also an

abundant and ubiquitous element in the natural e nvironment

. E lement al sulf u r is required for the

existence of animal and plant life. As indicated above, s ulfur also is used as a soil amendment /

fertilizer and/or reduce the pH of soils. Finally, available evidence indicates that sulfur is rapidly

and extensively incorporated into the natural sulfur cycle via oxidation to sulfate and/or

reduction to sulfide with subsequent volatilization.

The submitted ecological toxicity data indicate that sulfur is practically nontoxic on an acute

toxicity basis to birds, mammals, freshwater fish

, freshwater and estuarine/marine aquatic

invertebrates , and the honey bee

. A ll other ecological toxicity data were waived due to the

presumption of minimal ecological risk concerns with sulfur pesticidal uses at that time

. Available toxicity data from the open literature also indicate sulfur is practically non

- toxic to

freshwater fish, freshwater aquatic invertebrates and aquatic

- phase amphibians on an acute basis.

Based on assumed concentrations of sulfur in water at its reported solubility (4.87 ppb), risks to

aquatic animals are at least three orders of magnitude below levels of concern for listed species.

Qualitatively, acute risks to mammals, birds , and by exte nsion, risks to terrestrial

- phase

amphibians and reptiles for which avian toxicity data are use d as a surrogate, also appear to be

1 

### Available at http://ohioline.osu.edu/agf

- fact/0507.html (accessed 04/03/2013).

## Page 3 of 59 

## very low from registered uses of sulfur based on it being practically non

- toxic to these taxa on an

acute basis

. T his conclus ion is further supported by the lack of any ecological incidents reported

for these taxa despite its extensive use throughout history. Also important to note is that

applications of elemental sulf u r are rapid ly incorporat ed into the natural sulfur cycle on ce

released

.

Elemental s ulfur, when applied as a pesticide

, will become incorporated in soils and animals and

plants tissues

. The main processes and transformation s of elemental sulfur into the natural sulfur

cycle are oxidation into sulfate ( SO 4 2

- 

## , under aerobic [oxic or suboxic] conditions) and reduction

into sulfide ( S 2

- 

## , under anaerobic [anoxic] conditions). These processes are mainly mediated by

microbes. The subsequent fate of S 2

- 

## is dependent on metal sulfide precipitation or volatilization

of H 2 

## S (g)

. The dissipation of SO 4 2

- 

## is dependent on leaching and soil organic matter

immobilization. The oxidation of sulfur leads to formation of sulfuric acid, which may decrease

the pH of some soils and shallow water bodies. Elemental sulfur, in fa ct

, is used as a soil

amendment to supplement sulfur fertility

. Microbes and plants can assimilate SO 4 2

- 

## with

subsequent immobilization into organic compounds ( e.g.

, cysteine, cystine, and methionine)

(Hergert, 2000) (see Section II.B.1 )

.

For terrestrial plants, two lines of evidence suggest that some plant species may be adversely

affected by registered sulfur applications. First, all five available ecological incident reports for

sulfur involve terrestrial plants

. Second, current label and agricultural extension guidance

indicate that certain crops should not be treated with sulfur due to their increased sensitivity.

These include (but may not be limited to): certain varieties of gooseberries, currants, apricots,

raspberries, and cucurbits . Therefore, for this risk assessment, it is assumed that some terrestrial

plants may be susceptible to the effects of sulfur application; although the number and spatial

extent of these potentially susceptible species is not presently known.

Given the insecticidal uses of sulfur, it stands to reason that some non

- target terrestrial

arthropods may be adversely affected when exposed. The data available on the honey bee,

however, indicates low toxicity based on acute contact and oral exposure. A subset of

arthropods located within the target area may be adversely affected from sulfur addit i ons, for

example flying or leaf

- dwelling insects. Given its rapid incorporation into the sulfur cycle via

oxidation/reduction processes and subsequent biological uptake/metabolism, risks to terrestrial

invertebrates would likely diminish rapidly over time and with distance from the application

site(s)

.

There are 77 listed insects and arachnids; 18 of which are listed as ‘subterraneous’ (including 11

of the 12 arachnids) in the LOCA TES database. Therefore, the greatest potential for direct

affects to listed species is expected to be limited to the remaining 5 8 insect and 1 arachnid

species. Indirect effects may occur to listed and non

- listed terrestrial insectivorous birds,

amphibi ans, reptiles, invertebrates and mammals that prey on susceptible insect populations on

the use sites.

## Page 4 of 59 

## Table 1. Potential Adverse Effects to Federally Listed Taxa Associated with Direct or

Indirect Effects from the Current Uses of Sulfu r

Listed Taxon Direct Effects Indirect Effects a



### Terrestrial Invertebrates Uncertain b 

### Uncertain c



### Terrestrial plants

– monocots Uncertain d 

### Uncertain

Terrestrial plants

– dicots Uncertain d 

### Uncertain

Birds No effect Uncertain c



### Terrestrial

- phase amphibians and reptiles No effect Uncertain c



### Mammals No effect Uncertain c



### Aquatic nonvascular plants No effect No effect

Aquatic vascular plants No effect No effect

Freshwater fish No effect No effect

Aquatic

- phase amphibians No effect No effect

Freshwater invertebrates No effect No effect

Marine/estuarine fish No effect No effect

Marine/estuarine invertebrates No effect No effect

a. Until a detailed endangered species assessment is complete, indirect effects to certain taxa as indicated

cannot be precluded, i.e. whether there are relationships between the directly affected invertebrates and

terrestrial vertebrates ( which rely on the invert ebrate s as a food source).

b. Further evaluation of specific life history characteristics of listed terrestrial invertebrates, including the

potential for overlap between listed terrestrial invertebrates and sulfur use sites is needed to reduce the

uncertainty associated with the final effects determination.

c. The potential for indirect effects to listed birds, terrestrial

- phase amphibians and reptiles, and mammals that

rely extensively on sulfur

- sensitive terrestrial invertebrates is possible. Further evaluation of the potential

for re lationships between insectivorous taxa and terrestrial invertebrates is needed to reduce the uncertainty

associated with the final effects determination.

d. Available information indicate s some crops may be sensitive to sulfur exposure. However, the nature o f

this sensitivity has not been evaluated quantitatively in this risk assessment due to lack of data. It is

conceivable that some listed plant species may be adversely affected by registered uses of sulfur. However,

further evaluation of the potential fo r spatial and temporal overlap between registered uses of sulfur and

listed terrestrial plants is needed

.



## II. Problem Formulation

The purpose of this problem formulation is to provide the foundation for the ecological risk

assessment that will be conducted for sulfur. It includes all sulfur uses except for the gas

cartridge use , which was evaluated separately (DP Barcode D 375973, March 30, 2010)

. As

such, it articulates the purpose and objectives of the risk assessment, evaluates the nature of th e

problem, and provides a plan for analyzing the data and characterizing the risk (EPA, 1998).

The Fungicide Resistance Action Committee (FRAC 2 

## ) has designated sulfur as FRAC Code M2

(the only chemical in the group); the chemical belongs to the broader mo de of action (MOA) of

“ multi

- site contact activity ” , belonging to the target site and code “multi

- site contact activity

, ”

and group name and chemical group “ inorganic ”

. Generally, it is considered as a low risk group

for resistance development, without any signs of resistance developing to th is fungicide. Its risk

is generally considered low. The risk assessment provides a quantitative assessment of the

potent ial adverse effects from the registered outdoor uses of s ulfur on aquatic organisms a nd a

qualitative assessment for terrestrial organisms

.

2 

### Information available at http://www.frac.info/ (accessed 02/27/2013).

## Page 5 of 59 

# A. Nature of Regulatory Action

This risk assessment builds on the Environmental Fate and Effects Division’s Problem

Formulation for the Registration Review of Sulfur (DP Barcode 346696, dated 02/07/2 008)

. This chemical belongs to Reregistration List A and Case #0031. In 1991, the EPA issued a

Reregistration Eligibility Decision for Sulfur (RED), and in February 2008 the Agency issued the

preliminary Problem Formulation for Ecological Risk Assessment for Sulfur . These previous

reviews serve as the basis for this assessment (USEPA, 1991; USEPA, 2008). At the time of the

RED, it was concluded that since sulfur is a ubiquitous element in the environment and an

essential nutrient for some organisms, it appears to pose a small hazard to non

- target organisms.

This is supported by data that shows low order of toxicity to various species tested. The re view

indicated at the time

, that there was a concern that upon oxidation, elemental sulfur forms

sulfuric acid, which may acidify soil and water. I t was recommended that lime, i.e. calcium

carbonate, was applied to neutralize the acidity produced by the sulfur. I n addition, i t was

concluded at the time, that elemental sulfur should not pose a problem to the environment

because it rapidly incorporates into the natural sulfur cycle.



# B. Stressor Source and Distribution

1. Nature of the Chemical Stressor

Sulfur (CAS No. 7704

- 34

- 9; PC Code 077501) is a fungicide and insecticide with an atomic

mass of 32.06 g/mol. It s rhombic allotrope is nearly insoluble in water (see Table 2 and

additional characterization below)

. Table 2 provides some basic characteristics of sulfur.

Numerous other allotropes exist. Sulfur may exist as disu lfur (S 2 

## ), trisulfur (S 3 

## ), tetrasulfur (S 4 

## ),

ρ

- sulfur (cyclohexasulfur, S 6 

## ), α

- , β

- , γ

- , and δ

- cycloheptasulfur (S 7 

## ), α

- sulfur (rhombic sulfur,

S 8 

## ), β

- sulfur (monoclinic sulfur, S 8 

## ), γ

- sulfur (S 8 

## ), cyclo

- (nona; deca; undeca; dodeca; trideca;

tetradeca; pen tadeca; octadeca; eicosa)

- sulfur, fibrous (ψ) sulfur, and lamina sulfur ( e.g. , see

Meyer 1964 & Meyer 1976)

. In the figure below ( Figure 1 ), a part of the structure of rhombic

sulfur

, extended in three dimensions , is depicted (S 8 

## , eight atoms of sulfur : rhombic elemental

sulfur is its predominant allotrope in the environment at room temperatures )

. 3

3 

### Structure of rhombic sulfur (S 8 

### ), accessed 2/26/13, and available at

http://www.science.uwaterloo.ca/~cchieh/cact/c123/sulfur.html

.

## Page 6 of 59 

## Fig ure 1. Structure of Rhombic S ulfur

The majority of the citations say that sulfur is insoluble in water. However, a literature article

provides the solubility of sulfur in moles/ kg of S 8 

## at 298 0K (250C) (Boulegue 1978). The

solubility is equivalent to 4.87 ppb of sulfur active ingredient ( Table 2 )

. Little else could be

readily found about the concentrations of elemen tal sulfur in the environment. Richard et al.

(1977) give s environmental concentrations in natural untreated water ranging from 0.1 to 9.5 ppb

(Table V of the reference ). The latter concentration exceeds the solubility, but all other

concentrations were 0.1

- 1.0 ppb

. It is noted that another exception was 38.0 ppb reported in

from a coal washing plant , which does not represent pesticidal uses

. Despite the observed

concentrations being low, t he authors conclude that "[ t ]he data show sulfur to be an expected

ubiquitous contaminant. " ( Richard et al. 1977)

In order to observe elemental sulfur at pH 7, the total sulfur species must exceed 0.028 M (903

ppm), and the system should be confined to prevent escape of hydrogen sulfide (H 2 

## S (g)).

Furthermore, elemental sulfur should not exist in sub

- oxic and oxic environments (Lindsay,

1978). In other words, a concentration of 903 ppm represents the total sulfur species

concentration to allow precipitation of elemental sulfur in soil at pH 7.

Table 2 . Nature of the Chemical Stressor

C ommon/Chemical name Sulfur 1



### Pesticide type Fungicide, Insecticide, Acaricide

CAS number 7704

- 34

- 9

Empirical formula S (can exist as rhombic or alpha S 8 

### in the environment)

Atomic mass (g/mol) 32.064

Color/Form Precipitated sulfur is in form of very fine, pale yellow,

amorphous or microcrystalline powder

Odor/Taste Pure sulfur is o dorless/ t asteless or f aint t aste

Melting Point 112.8 to 120°C

Boiling Point 444.6 °C

Vapor pressure 3.95 x 10 - 6 

### mm Hg at 30.4°C

## Page 7 of 59 

## C ommon/Chemical name Sulfur 1



### Henry’s Law Constant (atm

- m 3 

### /mol) 3.42x10 - 5 

### (calculated)

Solubility in water (at 298 0 K = 25 0 C) 1.9(±0.6)x10 - 8 

### mol S 8 

### /L = 4.87 ppb 

## ( Boulegue, 1978)

Solubilities 1 g/2 ml carbon disulfide

Sol uble in Toluene

2.65% dissolves in acetone at 25°C

9.1% dissolves in methylene iodide at 10°C

~1.5% dissolves in chloroform at 18°C

1 

### Source is HSDB 201 3 , except where otherwise identified.



## Sulfur is unevenly distributed on land surfaces of the earth. The weight percent of elemental

sulfur in soil has been reported to ran ge widely from 0.003 to 1% (HSDB, 2013) . The average

amount of sulfur in soils of the conterminous US has been reported as 700 mg/kg, ranging from

30 to 10,000 mg/kg (Lindsay, 1978). An average sulfur content of 700 mg/kg is equal to

~ 1400

lbs S/A. This value is contrasted against the theoretical soil concentration for an application rate

of 122.5 lb a.i./A (maximum rate allowed on citrus), an assumed soil density of 1.6 g/cm 3 

## , and a

soil depth of 15 cm (6 inches) , the expected soil concentration is

~ 57 m g/kg.

Sulfur may exist in numerous forms or species in the environment. Occurrence of elemental

sulfur in soil is unlikely because low redox condition (2.5 to 4.0), total sulfur must exceed 0.028

M (903 ppm), and system must be confined to limit H 2 

## S (g) escape. Elemental s ulfur, when

applied on a field as a pesticide or soil amendment, become s incorporated into the natural sulfur

cycle. When released in the environment, elemental sulfur may undergo reduction to the sulfide

form, mediated by bacteria, whi ch could subsequently be lost via volatilization of H 2 

## S (g).

Sulfide is the predominate species in highly anoxic environments (pe + pH <4). Further, metal

sulfides ( e.g. , Hg, Cu, Pb, Ag, Zn, Fe, Mn, Ca, Mg) are expected to occur under anoxic

conditions ( pe + pH <5.27). Alternatively, in oxic and suboxic environments, it may undergo

oxidation, which is a process that can also be mediated by bacteria. The most common form of

oxidized sulfur is the sulfate ion (SO 4 2

- 

## ). Sulfate may exist as salts of numero us metals such as

N a +



## , Ca 2+ 

## , Mg 2+ 

## , Cu 2+ 

## , Zn 2+ 

## , Fe 2+ 

## , Fe 3+



## , etc ., or sulfuric acid (H 2 

## SO 4 

## ) (Lindsay, 1978). The

sulfate ion may be taken up and used by plants, from which it may be removed by crop

harvesting or animal consumption. It may also be removed b y leaching from the soils. Sources

of sulfate ions other than elemental sulfur, are fertilizers, atmospheric sulfur, soil minerals, and

irrigation water (Hergert, 2000)

.

In order for the s ulfur reaction to occur in soil

, it should be incorporated to in crease the speed of

oxidation. The oxidation reaction that occurs is as follows, noted there that hydrogen cations

( H + 

## ) are released into the soil environment, causing a decrease in the soil pH:

CO 2 

## + S 0 

## + 1⁄2O 2 

## + 2H 2 

## O → CH 2 

## O + SO 4 2

- 

## + 2 H +



## Elemental s ulfur’s main product in the environment is the consequence of its oxidation to sulfate,

which is produced in soils and when bacteria are growing

. Freney (1967), for example , said t hat

the reaction was believed to be carried out mainly by microorganisms. Lee et al. (1988) found

that fine particles of sulfur appeared to undergo oxidation faster

, where more sulfate ion was

taken up by plants from fine than f rom coarse particles. Dire ct measurement of the elemental

sulfur confirmed these findings. Chapman (1989) measured the rate of oxidation of elemental

## Page 8 of 59 

## sulfur in three soils at temperatures in the range of 2

- 20 0 C. At 20 0 C

, t he DT 50 

## ’s ranged from 6

- 10 days. Temperature had a marked effect, with DT 50 

## ’s of 36

- 42 days at 2 0 C. Germida &

Hanzen (1993) reiterated the se findings and added to some of the factors that affect the oxidation

of sulfur in soils: soil temperature, water potential, aeration, effective surface area of the sulfur

e xposed to microbial activity ( i.e. , sulfur oxidation is favored by reducing the particle size and

increasing the population of heterotrophic bacteria and fungi that could oxidize the sulfur). It

was also noted that previous application of sulfur could fav or faster oxidation. Finally, more

recently

, Hinckley and Matson (2011) evaluated the fate of sulfur fungicide and its related

compounds, when applied in Napa Valley, California vineyards in a three year study. They

found that S 0 

## , when applied to crops ( i.e.

, vineyards ) rapidly oxidizes to the SO 4 2

- 

## species on

soils. The sulfate then accumulates over the course of the growing season. Seven to 13% of the

applied sulfur was found in the grape leaf and fruit tissue during the growing season. The

majority of the sulfur in the leaf/fruit tissue occurred as sulfate an ion and ester bonded sulfates.

During the dormant season storms, the majority of the sulfur is lost in dissolved oxidized forms.

A ccording to USEPA 2003, “ Sulfates are naturally occurring subst ances that are found in

minerals, soil, and rocks. They are present in ambient air, groundwater, plants, and food. The

principal commercial use of sulfate is in the chemical industry. Sulfates are discharged into

water in industrial wastes and through a tmospheric deposition. Sulfate concentration in seawater

is about 2,700 milligrams per liter (mg/L). It ranges from 3 to 30 mg/L in most freshwater

supplies, although much higher concentrations (≥1000 mg/L) are found in some geographic

locations. In the United States, the median concentration for a 20

- State cross

- section was 24

mg/L; the 99 th 

## percentile value was 560 mg/L.” This illustrates th at sulfate , the product of

oxidation of sulfur, is a natural and ubiquitous component of U.S. waters and is not l ikely a

concern with the pesticidal uses of elemental sulfur

.

2. Overview of Pesticide Usage

Sulfur may be applied by chemigation, soil band treatment (ground sprayer, aircraft), soil

treatment (soil incorporation treatment), low volume spray concentr ate (low volume ground

concentrate), high volume spray or dilute (high volume ground sprayer), or dust (ground or

aircraft). Formulations include dust (D), water dispersible granules or dry flowable (DF),

emulsifiable concentrate (EC), flowable concentrat e ( F ), liquid (L), liquid ready

- to

- use (RTU),

wettable powder (WP), and wettable powder/Dust (WP/ D ).

Sulfur may be used on numerous crops and there are numerous products containing the chemical

as the active ingredient. For example

, the Golden

- Dew Fungicide and Insecticide, Reg. No.

2935

- 407 , 92.0% a.i. (micronized sulfur) , label obtained from the Pesticide Product Label

System ( PPLS 4 

## on 02/27/2013 ), provides some insight on the types of applications and how its

registrant divided its use sites into various major categories (instead of the usual crop groups)

. The methods of application include ground and aerial or sprinkler chemigation.

The label says that “[s] ulfur will cause severe fruit and leaf injury to sulfur sensitive crops. Do

not allow this material to drift into sulfur sensitive melons, squash, cucumbers, apricots or other

plants which may be injured by sulfur .” According to the Purdue University extension service,

4 

### Available at http://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1 ( accessed 02/27/13).

## Page 9 of 59 

## some crops are sensitive to sulfur treatment include varieties of goose berries, currants, apricots,

raspberries, and cucurbits and should not be treated with sulfur 5



## . It appears that sulfur may be

hazardous to sensitive plant species. Crop categories in the label are :

Field Crops : such as alfalfa, cereals, clover , cotton, grass seed crops, hops, peanuts, soybeans,

sugar beets, spearmint and peppermint

Vegetable Crops : such as asparagus, beans and peas, carrots, garlic, peppers and onions, celery,

broccoli, cauliflower and others, lettuce, melons and squash, turnips and oth ers, potatoes, and

tomatoes.

Fruits, Nuts and Berries : such as almond, apples, avocadoes, berries (various), citrus, figs,

grapes, mangos, pears, pecans, pistachios, stone fruits (various), strawberries, walnuts and

macadamias.

Ornamentals : such as laur els, chrysanthemums, juniper, spruce, English ivy, petunia, sage,

cosmos, dogwood, hibiscus, holly, Lady’s, lilac, sunflower , roses and violets.

A complete list of uses of sulfur as a pesticide is provided in Appendix B

. Elemental sulfur is

utilized on crops as a fungicide/insecticide at relatively high rates. In the same sample label

mentioned above ( EPA Reg. No. 2935

- 407 ) , application rates for sulfur are up to 32 lb a.i./A

, with instructions to apply throughout the sea son at 7

- 10 day intervals ( e.g.

, on asparagus)

. Variation in application rate is probably related to crop and their tolerance to the chemical.

However, there are other labels with application rates up to 122.5 lb a.i./A (from BEAD’s use

profile

, e.g.

, o n citrus crops aerial or ground dust applications , refer to the Appendix B )

. Ex amples of target pests include a pple cedar rust, b lack rot, f rog eye leaf spot, p owdery mildew,

q uince rust, s cab an d s ooty blotch on apple crops ; and r ust mite and c lover mite on citrus crops.

Additionally, s ulfur is used as an amendment to decrease the pH of alkaline soils; usually the

chemical is applied at higher rates for this purpose than when it is used as a pesticide

. F or

example

, an Ohio State University Extension Fac t Sheet (Mullen et al. 2007) suggests

application rates used for soil acidification of up to

~ 3,300 lb sulfur/A

, for highly alkaline clay

soils th at need extensive acidification

. This rate is over 27x higher than the highest application

rate in BEAD’s pro file . Since they are not pesticidal, uses of sulfur for soil amendments are not

assessed in this review.

The Screening Level Usage Analysis (SLUA) represents available estimates of pesticide usage

for sulfur when used on agricultural crops in the U

. S. T he data is assumed to represent the

average pound s of active ingredient applied from a variety of data sources

. Also, the SLUA

provides the average percent of crop treated and the maximum percent of crop treated 6



## . The

SLUA does not provide data on non

- agricultural uses

.

5 

### http://www.extension.purdue.edu/extmedia/bp/bp

- 69

- w.pdf

6 

### The percent crop treated is what percentage of the cropped area is treated with the chemical. This term should not

be confused with the percent cropped area, which is the percentage of all the land that is planted with a given crop.

## Page 10 of 59 

## The SLUA, which is dated 12/05/2007, indicates that the crops of major use for elemental sulfur

(the form which is being assessed in this review), are as summarized in Table 3

. The major crop

by far (45,200,000 lb applied) is grape s, which also has a significantly high percent crop treated

(average 80%). It is noted that there may be other forms of inorganic sulfur used as pesticides

( e.g. , sulfur dioxide SO 2 

## and sodium metabisulfite Na 2 

## S 2 

## O 5 

## ). According to USGS statistics, the

app arent U.S. consumption of sulfur (all forms) from 2007 to 2011 ranged from a low of 9,520

thousand metric tons to a high of 11,900 thousand metric tons. In 2011 (last year for which

statistics were available), the consumption was 11,600 thousand metric to ns. “About 90% of

sulfur consumed was in the form of sulfuric acid. Agricultural chemicals (primarily fertilizers),

composed about 68% of identified sulfur demand

... ” 7



## Table 3. Sulfur Major Crops (at or exceeding 500,000 lb a.i. applied), According to SLU A

dated 12/05/ 20 07

Crop lb a.i. applied % C rop T r td A ve % C rop T rtd M ax



## Grapes 45,200,000 80 90

Tomatoes 6,400,000 50 60

Peaches 2,800,000 60 70

Oranges 1,600,000 10 20

Apples 1,600,000 30 35

Cherries 1,200,000 50 50

Grapefruit 1,000,000 40 65

Sugar beets 800,000 5 5

Pistachios 600,000 35 45

Pears 600,000 50 65

Strawberries 500,000 45 60

Prunes 500,000 25 40

Carrots 500,000 25 55

Trtd=Treated



## U sage data available for the state of California 8 

## indicates that for the years 2003

- 2006, there was

a de crease in the total use of sulfur, as a pesticide, from 53,180,000 lb in 2003 to 45,92 0,000 lb

in 2006. The major crops involved were grapes, tomatoes (processing), sugar beets, pistachios

, peaches, and tomatoes

. Potential causes for the decrease in usage could involve reduced pest

pressure, availability of other fungicides, or improved crop management practices.



# C. Receptors

1. Terrestrial Effects

The receptor is the biological entity that is exposed to the stressor (EPA, 1998

. ) Due to the

outdoor uses of sulfur, the types of receptors that could potentially be exposed to the chemical

include terrestrial receptors, such as birds, reptiles, mammals and non

- target invertebrates.

7 

### Data from http://minerals.usgs.gov/m inerals/pubs/commodity/sulfur/mcs

- 2012

- sulfu.pdf (accessed 04/09/13).

8 

### Cal ifornia D epartment of P esticide R egulations or CDPR, http://www.cdpr.ca.gov/docs/pur/purmain.htm , in a

usage analysis prepared by BEAD on 01/17/08.

## Page 11 of 59 

## The process described in the Overview Document (EPA, 2004) uses a surrogate species approach

to risk assessment. In this approach, toxicological data generated from surrogate test species,

which are intended to be representative of broad taxonomic groups, are used to extrapolate to

potential effects on a variety of species (receptors) included under these taxonomic groupings.

For example, birds are considered surrogates for reptiles and terrestrial

- phase amphibians ( also

see Table 4 )

. The submitted ecological toxicity data on mammals, birds, fish, and aquatic

invertebrates indicate that sulfur is practically nontoxic on an acute toxicity basis and all other

ecological toxicity data were waived

.

2. Ecosy stems Potentially at Risk

The ecosystems at risk are often extensive in scope, and as a result it may not be possible to

identify specific ecosystems during the development of a baseline risk assessment. However, in

general terms, terrestrial ecosystems potentially at risk due to the use of sulfur, could include the

treated field and areas immediately adjacent to the treated field that may receive drift or runoff.

Areas adjacent to the treated field could include cultivated fields, fencerows and hedgero ws,

meadows, fallow fields or grasslands, woodlands, riparian habitats and other uncultivated areas.

As mentioned earlier, sulfur may be used on multiple crops

.

Aquatic ecosystems potentially at risk due to the use of sulfur include water bodies adjacent to,

or downstream from, the treated field and might include impounded bodies such as ponds, lakes

and reservoirs, or flowing waterways such as streams or rivers. For uses in coastal areas, aquatic

habitat also includes marine ecosystems, including estuari es. Sulfur undergoes oxidation or

reduction in the environment, depending on the redox environmental conditions; it is nearly

insoluble in water; therefore, its use is not expected to result in high levels of e xposure of

elemental sulfur to aquatic ecosyst ems.



# D. Assessment Endpoints

Assessment endpoints are defined as “explicit expressions of the actual environmental value that

is to be protected.” Defining an assessment endpoint involves two steps: 1) identifying the

valued attributes of the environm ent that are considered to be at risk; and 2) operationally

defining the assessment endpoint in terms of an ecological entity ( i.e. , a community of fish and

aquatic invertebrates) and its attributes ( i.e. , survival , growth and reproduction). Therefore,

se lection of the assessment endpoints is based on valued entities ( i.e. , ecological receptors), the

ecosystems potentially at risk, the migration pathways of pesticides, and the routes by which

ecological receptors are exposed to pesticide

- related contamination. The selection of clearly

defined assessment endpoints is important because they provide direction and boundaries in the

risk assessment for addressing risk management issues of concern. Changes to assessment

endpoints are typically estimat ed from the available toxicity studies, which are used as the

measures of effects to characterize potential ecological risks associated with exposure to

pesticides, such as s ulfur

.

To estima te exposure concentrations, the ecological risk assessment consid ers a single

ap plication at the maximum application rate to fields that have vulnerable soils . T he most

## Page 12 of 59 

## sensitive toxicity endpoints are used from surrogate test species to estimate treatment

- related

direct effects on acute mortality and chronic reproduct ive, growth and survival assessment

endpoints. Toxicity tests are intended to determine effects of pesticide exposure on birds,

mammals, fish, terrestrial and aquatic invertebrates, and plants. These tests include acute, sub

acute, and reproduction studi es and are typically arranged in a hierarchical or tiered system that

progresses from basic laboratory tests to applied field studies. The toxicity studies are used to

evaluate the potential of a pesticide to cause adverse effects, to determine whether fu rther testing

is required, and to determine the need for precautionary label statements to minimize the

potential adverse effects to non

- target animals and plants

.

Table 4 provides a summary of the taxonomic groups and the surrogate species tested to help

understand potential acute ecological effects of pesticides to these non

- target taxonomic groups.

In addition, the table provides a preliminary overview of the potential acute toxicity of sulfur by

providing the acute toxicity classifications.

Table 4 . Test Species Evaluated for Assessing Potential Ecological Effects of Sulfur and the

Associated Acute Toxicity Classification

Taxonomic Group Example(s) of Surrogate Species Acute Toxicity Classification

Birds 1 

### Mallard ( Anas platyrhynchos )

Bobwhite ( Colinus virginianus ) ; LC 50 

### >5,620 ppm diet Practically non

- toxic

Mammals Laboratory rat ( Rattus norvegicus ) LD 50 

### > 5000 mg/kg bw Practically non

- toxic

Insects Honey bee ( Apis mellifera L. ) Practically non

- toxic

Freshwater fish 2 

### Bluegill sunfish ( Lepomis macrochirus )

LC 50 

### >180 ppm

Rainbow trout ( Oncorhynchus mykiss )

LC 50 

### >180 ppm Practically non

- toxic

Freshwater invertebrates Water flea ( Daphnia magna ) LC 50 

### >5,000 ppm Practically non

- toxic

Estuarine/marine fish Sheepshead minnow (Cyprinodon

variegatus) Data waived

Estuarine/marine

invertebrates Mysid shrimp (Americamysis bahia)

LC 50 

### 736 ppm

Eastern oyster ( Crassostrea virginica) Practically non

- toxic

Terrestrial plants 3 

### Monocots

– corn ( Zea mays )

Dicots

– soybean ( Glycine max ) Data waived

Aquatic plants and algae Duckweed ( Lemna gibba )

Green algae ( Selenastrum

capricornutum ) Data waived

1 

### Birds represent surrogates for terrestrial

- phase am phibians and reptiles.

2 

### Freshwater fish may be surrogates for aquatic

- phase amphibians.

3 

### Four species of two families of monocots, of which one is corn; six species of at least four dicot families, of which one is

soybeans.



## Registrant Submitted Studies:

The registrant

- submitted ecotoxicity database for sulfur includes s even acceptable toxicity

studies. No chronic studies were submitted. Th e acute studies indicate that sulfur is practically

nontoxic on an acute basis to both terrestrial and aquatic animals. With birds, a n eight

- day

## Page 13 of 59 

## dietary study conducted on bobwhite quail resulted in an LC 50 

## value of > 5620 ppm (Acc. No.

GS0031

- 003)

. In that study, a single mortality was reported at a test concentration of 1780 ppm

. Some weakness and lethargy was noted in the study review, but birds recovered by day 6 and

beyond. With mammals, a n acute oral rat toxicity study resulted in an L D 50 

## value of > 5g/kg

with no mortalities reported (Acc. No. 252262)

. Information on suble thal effects was not

available.

Acute toxicity tests on two fish species, rainbow trout and bluegill sunfish, resulted in LC 50



## value s of >180 ppm (Acc. No. GS0031

- 0004; 0005)

. No information on sublethal effects was

available from these studies. Acute toxicity tests with D. magna and mysid shrimp resulted in a

48

- h LC 50 

## of >5,000 ppm and a 96

- h LC 50 

## of 7 36 ppm

, respectively (Acc. No. GS00031

- 0002)

. Sublethal effects on mysid shrimp included immobilization, loss of equilibrium, erratic

swimming and excessive mucous production. Sulfur particles were observed sticking to the

body and appendages. With all of these aquatic studies, the concentration of sulfur was based on

nominal concentrations that greatly exceeded its solubility limit in water (4.87 ppb) and in some

cases, precipitates were documented

. It is therefore possible that the effects observed in the

mysid study were due to physical interaction with the sulfur particles instead of (or in addition

to) dissolved sulfur.

Two beneficial insec t studies demonstrated that sulfur is low in toxicity to the honey be e through

contact and ingestion (Atkins et al, 1967)

.

Additional ecotoxicity data requirements were previously waived for sulfur due to : 1) the low

solubility of sulfur in water , 2) i ts overall low acute toxicity as indicated in the available data

, and 3) its ubiquitous occurrence in nature and rapid incorporation into the sulfur cycle ( e.g.

, oxidation to sulfate; reduction to sulfide). See Section III.B for additional lines of evidence that

are considered in this registration review of sulfur with respect to potential effects on terrestrial

invertebrates and plants.

Open Literature Studies:

A review of the open literature was conducted on the effects o f sulfur on aquatic and terrestrial

organisms contained in the U.S. EPA ECOTOX database. As expected, very little toxicity data

were available in the database. Table 5 below summarize s toxicity data for sulfur that are

consistent with assessments endpoin ts considered in this assessment ( e. g.

, survival, growth,

reproduction and development). Data are available for four species including the western

mosquitofish ( Gambusia affinis ), the mayfly ( Cleon dipterum )

, the aquatic reed ( Phragmites sp.)

and the bog frog ( Rana limnocharis ). For three species, no definitive toxicity endpoints were

reached because the necessary effects were not observed up to and including the highest test

concentrations (see Table 5 ) . This is consistent with the toxicity profile previously discussed

using registrant

- submitted data. L imitations in test methods and/or available information about

study conditions precluded quantitative use of these toxicity endpoints in this risk assessment

( i.e., they are not used for RQ c alculation). However, these data are considered qualitatively in

this assessment

.

## Page 14 of 59 

## Interestingly, in the study by Howes et al. (2005), difficulties were reported in achieving desired

concentrations of sulf ide in pore water due to incorporation and transfo rmation of elemental

sulfur into the sulfur cycle ( e.g. , oxidation to sulfate). Specifically, the authors concluded that

sulfide levels were limited by re

- oxidation to sulfate and/or sequestration with biologically

available carbon , despite the exceptiona lly high rates applied to the soil/sediment system. This

finding supports the expectation that anthropogenic sulfur additions to the environment (semi

aquatic in this case) are readily assimilated into the natural sulfur cycle without causing

observable a dverse effects on non

- target organisms tested in these studies

.

Table 5. Open literature toxicity data for sulfur.

Species Dur ation

(days) Endpoint Concentration 1 

## Cit ation

[ECOTOX #]

Western Mosquitofish

( Gambusia affinis ) 4 LC 50 

## > 10,000 mg a.i./L Wallen et al. (1957)

[#508]

Phragmites sp. 292 NOAEC > 2396 lb a.i./A Howes et al. (2005)

[#103042]

Mayfly ( Cloeon

dipterum ) 2 L C 50 

## > 40 mg a.i./L Nishiuchi and Asano

(1979) [#6954]

Bog frog ( Rana

limnocharis ) 2 LC 50 

## 2,560 mg a.i./L Pan and Liang (1993)

[#16056]

1 

## all endpoints greatly exceed the aqueous solubility limit for elemental sulfur (4.87 μ g/L = 0.00487 mg/L ).

Ecological Incident Reports :

There were a total of five incidents in the United States found in the Ecological Incident

Information System (EIIS) associated with sulfur applications. All five incidences involve

terrestrial plants and span a time period from 1999 to 2001. In one incident, there was reported

damage to 127 acres of citrus in Polk County, FL treated directly with sulfur. The symptoms

were described as “miscellaneous”. It is unknown as to whether the application was made

according to label guidelines. Also, no chemical analysis was conducted. The certainty index for

this incident was probable. The second inc ident report indicated damage to 44 acres of a grape

vineyard in Yolo County, CA treated directly with sulfur and trifloxys t robin based on registered

uses . The symptoms noted were spotting and speckling. The application rate and method were

not reported for sulfur but were reported for trifloxystrobin. The certainty index for this incident

was possible for sulfur and probable for trifloxystrobin. Available t errestrial plant data for

trifloxystrobin result in an EC 25 

## greater than the highest concentratio n tested; therefore an

assessment of risks is not possible. However, another strobilurin fungicide is highly toxic to

terrestrial plants. In the third reported incident a tank mixture of sulfur, fenarimol, and

oxyfluorfen applied to 20

- acre plot of grape s in Fresno County, CA may have caused burnt

leaves and berries. The certainty index for sulfur and fenarimol was unlikely and was probable

for oxyfluorfen. The plant damage was more likely caused by the herbicide oxyfluorfen rather

than to the fenorimol and sulfur fungicides. In the forth incident report, 4 acres of apples in

Grant County, WA reportedly experienced plant damage due to drift of sulfur

- application. The

legality of this application is unknown and certainty index is possible. The last rep orted incident

involved plant damage to an unknown acreage woody ornamental cherry laurel . The legality

## Page 15 of 59 

## of this use is unknown and certainty index is considered possible. Since 2001, no further

incidents have been reported to have associations with sulf ur applications.

A lack of reported incidents does not necessarily mean that such incidents have not occurred. In

addition, incident reports for non

- target plants and animals typically provide information on

mortality events only. Reports for other adv erse effects, such as reduced growth or impaired

reproduction, are rarely received.

A search of the ‘Aggregate Incident Reports’ (v. 1.0) database contained in the Incident Data

System (IDS), and the Avian Monitoring Information System (AIMS) for ecological incidents

involving sulfur was completed on March 12, 2013. AIMS did not report a ny incidents in

relation to avian species. IDS reported one minor fish and wildlife incident from 3 rd 

## quarter of

2000 (July 1

– Sept. 30) that was associated with the Thiolux sulfur product. No other details of

this incident are available.



# E. Conceptual Model

For a pesticide to pose an ecological risk, it must reach ecological receptors in biologically

significant concentrations. An exposure pathway is the means by which a pesticide moves in the

environment from a source to an ecological receptor. For an ecological pathway to be complete,

it must have a source, a release mechanism, an environmental transport medium, a point of

exposure for ecological receptors, and a feasible route of exposure.

In the spec ific case of s ulfur , the source and mechanism of release of the chemical may be

applied by chemigation, soil band treatment (ground sprayer, aircraft), soil treatment (soil

incorporation treatment), low volume spray concentrate (low volume ground concentra te), high

volume spray or dilute (high volume ground sprayer), or dust (ground or aircraft) to an

agricultural or ornamental plants field. Surface runoff from the areas of application is assumed

to depend on factors such as topography, irrigation, and rai nfall events . H owever, due to the fact

that sulfur is relatively insoluble in water, this compound is not expected to runoff substantially

as elemental sulfur. Conceptually, runoff of some particulate (yet dissolved) sulfur is possible

immediately after a pplication via a rainfall event; although rapid oxidation to sulfate would

likely result in low concentrations of particulate sulfur in receiving waters. Consequently,

sulfate is considered the predominant species in large rain events

.

Additional transpor t mechanisms include spray drift and wind erosion ( e.g

. , when applied

aerially), which may potentially transport contaminants to the surrounding sites. In addition,

direct deposition may result in contamination of food items that may be consumed by terres trial

organisms. Sulfur is believed to be relatively reactive in soils with high bacteria population,

where it is oxidized to a sulfate; therefore, long

- term exposure of non

- target organisms to sulfur

is uncertain.

For aquatic receptors, the major point of exposure is through direct contact with the water

column, sediment, and pore water (gill/integument) contaminated with spray drift (from spray

and aerial applications) and/or runoff (which appears to be a minor route) from treated areas.

Indirect effec ts to aquatic organisms (especially fish) can also occur through impact to various

food chains. However, due to the fact that s ulfur is insoluble in water, minimal exposure is

## Page 16 of 59 

## expected. S ulfur exposure to terrestrial animals could occur through ingestion of contaminated

food items such as grass, foliage, and small insects. Exposure to plants may occur mostly

through direct contact, since root uptake is unlikely (due to low or no solubility of s ulfur ). On

the other hand, root uptake of sulfate, the major derivative of sulfur, is beneficial to plants (this

form of sulfur constitutes a needed nutrient to the plants).

Based on a review of the available data, it is hypothesized that terrestrial receptors may

potentially be at risk from s ulfur exposure

. This is based on potential exposure due to the large

application rates ( e .g.

, 12 2.5 lb a.i./A on citrus crops ). The exposure to aquatic organisms is

lower or minimal because sulfur is insoluble. The representative terrestrial receptors are certain

mammals

, bi rds and plants . The attribute changes used to assess risk for terrestrial receptors

depend on the type of test ( e.g. , reduced survival, growth, or reproduction). Although a full

evaluation of risk to aquatic and terrestrial animals and plants was not possible due to the lack of

a whole toxicity data set, based on the data available, it is not expected that sulfur will be of any

toxic concern. Sulfur appears to be relatively non

- toxic.

1. Risk Hypothesis

For s ulfur , the following ecological risk hypothesis is being employed for this baseline risk

assessment:

Given the large annual sulfur usage and the high application rates, s ulfu r when used in

accordance with the label, may resul t in potential adv erse effects upon survival of non

target terrestrial organisms.



## III. Risk Characterization

Risk Characterization typically consists of two parts: Risk Estimation and Risk Description. For

sulfur, a quantitative risk assessment is conducted for aquatic organisms (presented in the Risk

Estimation Section) and a qualitative risk assessment is conducted for terrestrial organisms

(presented in the Risk Description section).



# A. Risk Estimation

Risk to A quatic A nimals

Based on the lack of suitable environmental fate data, it appears unfeasible to conduct modeling

for this inorganic substance. Given the high rates at which sulfur applications are conducted,

EFED assumed that the EECs of sulfur in water resulting from sp ray drift or runoff would reach

it s solubility limit. F or sulfur, the peak EEC was assumed to be at the limit of solubility of the

chemical (4.87 ppb, Boulegue 1978).

Table 6

. Acute RQs for freshwater and estu arine/marine fish and invertebrates based on

the most sensitive acute toxicity values for each taxonomic group (peak EEC = 4.87 ppb) a , b ,c

## Page 17 of 59 FW Fish

LC 50 

## FW Invert

LC 50 

## E/M Fish

LC 50 

## E/M Invert

LC 50 

## FW

Fish

Acute RQ FW

Invert

Acute RQ E/M

Fish

Acute RQ E/M

Invert

Acute RQ

>180 ppm > 5000 ppm >180 ppm 736 ppm <<0.01 <<0.01 <<0.01 <<0.01

a 

### The peak EEC was assumed to be the same than the solubility limit for sulfur or 4.87 ppb or 0.00487 ppm

. b 

### Toxicity values are based on studies with bluegill sunfish ( Lepomis macrochirus ) for freshwater fish (LC 50 

### > 180 mg

a.i./L), daphnia ( Daphnia magna ) for freshwater invertebrates (LC 50 

### 5000 μ g a.i./L), rainbow trout ( Oncorhynchus

mykiss or Salmo gairdneri ) for estuarine/marine fish (LC 50 

### >180 mg a.i./L), and mysid shrimp ( Americamysis bahia

or Mysidopsis bahia ) for estuarine/marine invertebrates (EC 50 

### = 736 mg a.i./L).

c 

### All acute RQ values for fish and aquatic invertebrates are below the acute endangered species LOC (0.05).



## The actual RQ values were < 1x 10

- 5 

## in all instances; however, they are expressed as <<0.0 1 in

Table 6

. All the RQ values are below the acute risk to non

- listed and listed LOCs (0.5 and 0.05,

respectively). There are uncertainties associated with these RQ values which relate to the nature

of the toxicity endpoints used in their calculation. Specifically, the acute toxicity endpoints were

based on nominal concentrations that far exceeded the solubility limi t of sulfur. Additional

discussion on this uncertainty is provided in the subsequent section: Risk Description.

Risk to Terrestrial Animals

A quantitative assessment of risks to terrestrial organisms was not conducted for reasons

described earlier in Se ction II : Problem Formulation. A qualitative assessment was conducted

and is described in the following section: Risk Description.

## Page 18 of 59 

# B. Risk Description

Elemental sulfur is the stressor of concern for this risk assessment. Although sulfur has

insecticidal and fungicidal properties, it is ubiquitous in the natural environment and an element

required for the existence of animal and plant life

. Furthermore, sulfur is widely used as a soil

amendment to increase fertility and/or reduce the pH of highly alkaline soils. Finally, available

evidence indicates that sulfur is rapidly and extensively incorporated into the natural sulfur cycle

via oxidation to sulfate and/or reduction to sulfide with subsequent volatilization. Due at least in

part to the ubiquitous nature of sulfur in the environment and its low toxicity to aquatic and

terrestrial animals, available evidence suggest low risks to non

- target animals (aquatic and

terrestrial) associated with registered sulfur applications. Although no t oxicity data are available

for the effects of sulfur on aquatic plants, the risk of sulfur to aquatic plants at its limit of

solubility is also considered low based on the aforementioned considerations.

For aquatic animals, the acute toxicity endpoints reported for the effects of sulfur on

representative fish and invertebrates are at least five orders of magnitude above its reported

solubility limit in water (4.87 ppb). Given that these aquatic toxicity endpoints were based on

nominal concentrations tha t greatly exceed the aqueous solubility of sulfur, actual exposure to

dissolved concentration of sulfur from these tests is undoubtedly much lower ( e.g. , at or near its

solubility limit). However, in all but one study, no acute toxicity was observed based on a

combination of exposure that likely included both dissolved and particulate sulfur in water. In

order to observe elemental sulfur in the environment, at pH 7, the total sulfur species must

exceed 903 ppm. In addition, the system should be confined to prevent escape of hydrogen

sulfide (H 2 

## S (g) )

. In other words, a concentration of 903 ppm represents the total sulfur species

concentration ( e.g. , elemental sulfur, sulfate, sulfide , and other sulfur species ) to allow

precipitation of elemental sulfur i n soil at pH 7 (Lindsay, 1978)

. E lemental sulfur should not

exist in sub

- oxic and oxic environments , where it is oxidized (Lindsay, 1978). In aquatic

ecosystems, confined systems are unlikely. While the aquatic toxicity database for sulfur is

incomplete , the assumption of negligible risks of registered applications of sulfur to aquatic

animals appears to have a wide margin of safety based on extremely low calculated risk

quotients on the basis of total exposure (dissolved + assumed particulate forms) . I t is worth

considering other mechanisms from which sulfur applications to the environment may affect

aquatic ecosystems. One such mechanism may be through acidification resulting from

conversion to sulfate and formation of hydrogen ( H + 

## ) ions in water. Al though conceptually

feasible, the acidification of aquatic ecosystems from sulfur applications to crops is considered

unlikely due to the natural capacity of most soils to buffer effects of the sulfur

- induced

acidification. Furthermore , widespread acidifi cation of agricultural soils is considered unlikely

because soil pH and acidity or alkalinity tend to be closely managed to optimize crop production

yields.

In aquatic ecosystems , the sulfate an ion is expected to be the predominant species of sulfur.

E lemental sulfur, given its low solubility and tendency to transform microbially

, is unlikely to be

present in dissolved form in high concentrations. It may exist, however, suspended in the water.

Other species of sulfur, like the sulfide anion, is likely to be lost via volatilization as H 2 

## S (g).

The sulfate anion is ubiquitous in the environment and it is unlikely to pose a high risk to aquatic

animals and plants.

## Page 19 of 59 

## For birds, mammals, reptiles and terrestrial

- phase amphibians , primary routes of exposure to

sulfur include consumption of contaminated foliage and surface water. Based on the available

data, sulfur is classified as practically nontoxic to both mammals and birds (surrogate for

terrestrial

- phase amphibians and reptiles). Although u sing the sta ndard EFED terrestrial

exposure model T

- REX (v 1.5 .1 ) is technical ly feasible for liquid spray applications of sulfur to

foliage, the high application rates of sulfur ( e.g.

, , up to 122 lb a

. i

. /A) would yield exceptionally

high terrestrial EECs ( e.g. , excee ding 24,000 ppm on short grass). These high EECs combined

with the lack of definitive toxicity endpoints ( e.g ., LD 50 

## > 5,000 mg/kg mammals; > 5,620 ppm

for birds) would yield RQ values with unknown accuracy and precision. While it is

mathematically possi ble for predicted EECs to exceed the LOC for terrestrial birds and

mammals, actual risks to these taxa are considered very low for the following reasons: 1) sulfur

is a naturally occurring and ubiquitous element in nature; 2) it is rapidly incorporated int o the

natural sulfur cycle; 3) it is practically non

- toxic on an acute basis to representative mammals

and birds (and by extension, amphibians and reptiles); and 4) no ecological incidents have been

reported for terrestrial wildlife despite the widespread use of sulfur throughout recent history.

Given the insecticidal uses of sulfur, it stands to reason that terrestrial arthropods (the target

organisms) may be adversely affected when exposed. Available data on the honey bee, however,

indicates low toxici ty based on acute contact and oral exposure. Nonetheless, it is reasonable to

assume that a subset of arthropods located within the target area would likely to be adversely

affected from direct exposure to sulfur addit i ons, for example

, flying or leaf

- dwe lling insects.

Given its rapid incorporation into the sulfur cycle, risks to terrestrial invertebrates would likely

diminish rapidly over time and with distance from the application site(s)

.

For terrestrial plants, the risk profile is less clear. Two li nes of evidence suggest that some plants

may be susceptible to registered sulfur applications. First, all five ecological incident reports for

sulfur involve terrestrial plants. However, it is worth noting that only one of these incidents is

considered “ probable” with respect to sulfur and that high uncertainty about the nature of sulfur

exposure is apparent with the other four incidents. The second line of evidence is current label

and agricultural extension guidance that indicate certain crops not be treated with sulfur d ue to

their increased sensitivity. These include (but may not be limited to): certain varieties of

gooseberries, currants, apricots, raspberries, and cucurbits . Since no toxicity data are available

for terrestrial plants, there is no other evidence to discount these line s of evidence that suggest at

least some types of terrestrial plants may be at risk from sulfur application. Therefore, for this

risk assessment, it is assumed that some terrestrial plants may be susceptible to the ef fects of

sulfur application; although the number and spatial extent of these potentially susceptible species

is not presently known.

## Page 20 of 59 

# B. Endangered Species Considerations

Environmental fate and ecological risk assessments for registration revie w must address

Endangered Species Act, Section 7 (a) (2) obligations. The environmental fate data requirements

for sulfur were waived based on the availability of public information on this substance. For

aquatic animals and plants, t here is no evidence to suggest that there is a risk to these taxa when

these sulfur

- containing pesticides are used as registered. Available aquatic RQ values are at least

three orders of magnitude below listed species levels of concern (0.05). However, based on label

stateme nts indicating insecticidal efficacy, direct effects to terrestrial arthropods should be

expected. Furthermore, for reasons indicated in Section 1, some species of terrestrial plants may

be susceptible to sulfur insecticidal applications.

Based on this s creening

- level assessment, there are potential risks of direct effects to listed

terrestrial invertebrates and terrestrial plants (monocots and dicots) from the use of sulfur on

some of its registered use sites. Listed species of birds, mammals, reptiles and terrestrial

- phase

amphibians may also be affected through indirect effects because of the potential direct effects

on listed and non

- listed species. Pot ential direct effects on listed terrestrial invertebrates and

terrestrial plants (monocots and dico ts) from the use of sulfur may be associated with

modification of primary constituent elements of designated critical habitats, where such

designations have been made. However, a t this current stage of the Registration Review process,

it is premature to m ake effects determinations for listed species until further refinements are

conducted. To make effects determinations for individual species, useful refinements may

include analyses of 1) more detailed, species

- specific ecological and biological data; 2) more

detailed and accurate information on sulfur use patterns; and 3) sub

- county level spatial

proximity data for the co

- occurrence of potential effects areas and listed species and any

designated critical habitat. Examples of such refinements are describ ed below.

EFED is currently developing tools that are expected to further refine the assessment and are

designed to support effects determinations for individual federally listed species and their

designated critical habitats (where applicable). Scientif ic information obtained from the U.S.

Fish & Wildlife Service (USFWS), the National Marine Fisheries Service (NMFS), and other

reliable sources is being collated by EFED to address all currently listed species. The

information will be stored in an Office of Pesticide Programs Pesticide Registration Information

SysteM (PRISM) knowledgebase. The listed species knowledgebase will consist of an

information repository that houses biological and behavioral information relevant to individual

species ( e.g. , habit at, diet, and life history, including specific temporal and spatial associations)

and a document repository that contains supporting documents ( e.g ., USFWS recovery plans)

and electronic information ( e.g ., GIS data files). For terrestrial taxa, the biological information

relevant to risk quotient (RQ) calculations ( e.g ., diet and body weight) will be used to

parameterize exposure estimates to derive species

- specific RQs using a method consistent with

currently used methods in the T

- REX and T

- HERPS mo dels.

Refinements may also include more detailed analyses of the registered uses and their use patterns

that result in LOC exceedances for federally listed species in the screening

- level assessment.

The analyses may include more information on where, w hen, and how sulfur is used on all use

sites

. Actual usage data (when available) and national land

- cover datasets that indicate potential

## Page 21 of 59 

## use sites [ e.g ., national land cover dataset (NLCD), crop data layer (CDL)] may be used to

support a more refined ana lysis of where sulfur is reasonably expected to be used. Similarly,

refinements for the timing of applications and how sulfur is used may be based on the analysis of

additional usage data, beyond what were available at the time of the screening

- level asse ssment,

and a more in

- depth exploration of agronomic practices.

The U.S. Environmental Protection Agency, along with the U.S. Department of Agriculture

(USDA), the U.S. Fish and Wildlife Service (FWS), and the National Marine Fisheries Service

(NMFS), h ave announced the availability of a report developed by the National Academy of

Sciences’ National Research Council outlining recommendations on specific scientific and

technical issues related to the development of endangered and threatened species risk

a ssessments for pesticides that are compliant with the Endangered Species Act (ESA) and the

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The EPA, USDA, FWS and

NMFS asked the NRC to consider a range of scientific and technical issues includi ng:

• identifying best available scientific data and information;

• considering sub

- lethal, indirect and cumulative effects;

• assessing the effects of chemical mixtures and inert ingredients;

• analyzing the effects of pesticide use through the use of models;

• incorporating uncertainties into the evaluations; and

• using geospatial information and datasets that can be employed by the agencies in the

course of these assessments.

After reviewi ng the NRC’s recommendations on these scientific and technical issues, the EPA

and its federal partners will determine how these recommendations can be implemented and

incorporated into the scientific approaches for developing listed species risk assessmen ts. It is

anticipated that any draft guidance and/or science policies developed by EPA and its federal

partners as a result of the NAS recommendations would be released for public comment prior to

implementation.

The refinements based on individual speci es data; additional, detailed usage information, when

available; and further recommendations from the NRC report are expected to help to more

accurately identify potential areas of effect and to better inform effects and habitat

determinations for listed s pecies and any designated critical habitats. For example, if sulfur is

used when a particular species of concern is not present ( e.g ., it is migratory) or is not co

- located

in space, then risk of potential direct effects to the species may often be preclu ded. If LOCs are

still exceeded for terrestrial invertebrates and terrestrial plants after conducting the refined

analyses, further analyses of the potential spatial and temporal co

- occurrence of listed species of

concern (and any designated critical habi tat) may be conducted. The extent of possible

refinement in the analyses of spatial/temporal co

- occurrence will largely depend on the scale and

quality of the available sub

- county level use site ( e.g ., NLCD, CDL) and species location data

.

For listed ter restrial invertebrates, t here are 77 listed arachnids and insects in the US; no other

arthropods are listed ( Appendix A ). Information that can inform species determinations may

include more specific biological and locational data for each of the listed in sects. It is possible

that many of the listed species have narrow home ranges, which may increase mitigation options

or result in a ‘No Effect’ finding for these species. An example of other information that would

## Page 22 of 59 

## inform a determination includes detail o n whether ground

- dwelling or soil adapted insects have

the same sensitivity as foliar dwelling or flying insects. Actual use and usage data, proposed

label limitations that could preclude exposure of listed terrestrial invertebrate species (such as

limita tions on application timing), information on the overlap between listed insects and sulfur

usage are all examples of the type of information that would be considered in making final

effects determinations for terrestrial insects. Appendix A contains a lis t of all listed arthropods,

Appendix B contains a comprehensive list of registered uses of sulfur in the U.S.

Potential indirect effects to listed insectivorous terrestrial vertebrates cannot be precluded

without further information. Indirect effects are possible to other listed taxa based on effects to

the target insect populations. Many listed mammals, birds, terrestrial

- phase amphibians and

reptiles rely on insects for all or a significant portion of their diet. Those foraging substantially

in treate d areas may be adversely affected. However

, greater understanding of the spatial

overlap of listed insectivores with the use sites would help in determining the potential for

indirect effects due to the application of sulfur. This information could inclu de habitat

descriptions and whether sulfur is likely to be applied on such habitats, since effects are

considered to be limited to the area of application. Indirect effects to listed plant species are not

considered likely as direct effects are expected t o be limited to the target area.

Based on the discussion in this preliminary risk assessment, a No Effect determination is made

for all listed aquatic species. A No Effect determination is made for direct effects to listed

terrestrial vertebrates that do not rely on insects as a primary food source, though further work on

individual species is necessary to determine which particular species this determination applies.

Table 7 . Potential Adverse Effects to Federally Listed Taxa Associated with Direct or

Indirect Effects from the Current Uses of Sulfur

Listed Taxon Direct Effects Indirect Effects a



### Terrestrial Invertebrates Uncertain b 

### Uncertain c



### Terrestrial plants

- monocots Uncertain Uncertain

Terrestrial plants

- dicots Uncertain Uncertain

Birds No effect Uncertain c



### Terrestrial

- phase amphibians and reptiles No effect Uncertain c



### Mammals No effect Uncertain c



### Aquatic nonvascular plants No effect No effect

Aquatic vascular plants No effect No effect

Freshwater fish No effect No effect

Aquatic

- phase amphibians No effect No effect

Freshwater invertebrates No effect No effect

Marine/estuarine fish No effect No effect

Marine/estuarine invertebrates No effect No effect

a. Until a detailed endangered species assessment is complete, indirect effects to certain taxa as indicated

cannot be precluded, i.e. whether there are relationships between the directly affected invertebrates and

terrestrial vertebrates ( which rely on the i nvert ebrate s as a food source).

b. Further evaluation of specific life history characteristics of listed terrestrial invertebrates, including the

potential for overlap between listed terrestrial invertebrates and sulfur use sites is needed to reduce the

uncer tainty associated with the final effects determination.

c. The potential for indirect effects to listed birds, terrestrial

- phase amphibians and reptiles, and mammals that

rely extensively on sulfur

- sensitive terrestrial invertebrates is possible. Further ev aluation of the potential

## Page 23 of 59 for relationships between insectivorous taxa and terrestrial invertebrates is needed to reduce the uncertainty

associated with the final effects determination.

d. Available information indicates some crops may be sensitive to sulfur exposure. However, the nature of

this sensitivity has not been evaluated quantitatively in this risk assessment due to lack of data. It is

conceivable that some listed plant species may be adversely affected by registered uses of sulfur. However,

furthe r evaluation of the potential for spatial and temporal overlap between registered uses of sulfur and

listed terrestrial plants is needed

.

## Page 24 of 59 

## IV. Bibliography

Atkins, E

. L

. Jr., Anderson, L

. D. 1967. Toxicity of pesticides and other agricultural chemicals to

honey bees: laboratory studies. (Unpublished study received Jan. 30

, 1969 under 9G0802; Univ.

California

- Riverside.).

Boulegue, J. 1978. Solubility of Elemental Sulfur in Water at 298 0 K. Phosphorous and Sulfur

and the Related Elements (Short Communica tion. 5(1) 127

- 128. Gordon and Breach Science

Publishers, Ltd., 1978, Printed in Great Britain

Chapman, S.J. 1989. Oxidation of micronized elemental sulphur in soil. Plant and Soil 116, 69

- 76 (1989 )

Freney, J.R. 1967. Oxidation of Sulfur in Soils. Miner alium Deposita 2 , 181

- 187 (1967)

Germida, J.J. and H.H. Janzen. 1993. Factors affecting the oxidation of elemental sulfur in soils.

Fertilizer Research 35 , 101

- 114, 1993

Hazardous Substances Data Bank (HSDB). 201 3 . National Library of Medicine, National

Institute of Health. Each Chemical Profile: < http://www.toxnet.nlm.nih.gov >

Hergert, G.W. 2000

. Nutrient Management for Agronomic Crops in Nebraska. Part I. Fertility

Principles, Chapter 5. Sulfur, pp. 39

- 43 ; R.B. Ferguson and K.M. De Groot, editors, available at

http://www.ianrpubs.unl.edu/epublic/live/ec155/build/ec155

- 5.pdf and accessed 04/03/2013 )

.

Hinckley, E.L. and P.A. Matson. 2011. Transformations, transport, and potential unintended

consequences of high sulfur inputs to Napa Valley vineyards. PNAS 108(24) 14005

- 14010

Howes, B.L., J.M. Teal, and S. Peterson . 2005. Experimental Phragmites Contr ol Through

Enhanced Sediment Sulfur Cycling

. Ecol. Eng. 25(3): 292

- 303

.

Lee, A., C.C. Boswell, J.H. Watkinson. 1988. Effect of particle size on the oxidation of

elemental sulphur, thiobacilli numbers, soil sulphate, and its availability to pasture New Ze aland

Journal of Agricultural Research, 1988, Vol. 31: 179

- 186

Lindsay, 1978. Soil Chemical Equilibria. J.W. Wiley and Sons.

Meyer, B. 1964. Solid allotropes of sulfur. Chem. Rev.

, 1964

, 64 (4), pp 429

– 451.

Meyer, B. 1976. The Structures of Elemental Sulfur

, in Advances in Inorganic Chemistry and

Radiochemistry , H.J. Emeléus and A.G. Sharpe , eds. , Volume 18 , pp. 287

Mullen, R, E. Lentz, and M. Watson. 2007. T he Ohio State University Extension Fact Sheet (Soil

Acidification : How to lower the soil pH, by R. Mullen, E. Lentz, and M. Watson, AGF

- 507

- 07,

dated 2007 )

## Page 25 of 59 

## Nishiuchi, Y., and K. Asano . 1979. Toxicity of Agricultural Chemicals to Some Freshwater

Organisms

– 59

. Suisan Zoshoku 27(1): 48

- 55

.

Pan, D .Y., and X.M. Liang . 1993. Safety Study of Pesticides on Bog Frog, a Predatory Natural

Enemy of Pest in Paddy Field

. J. Hunan Agric. Coll. 19(1): 47

- 54

Richard, J.J., R.D. Vick, and G.A. Junk. 1977. Determination of Elemental Sulfur by Gas

Chromatography . Environ. Sci. & Te ch. 11(12) 1084

- 1086

U.S. Environmental Protection Agency. 1998. Guidelines for Ecological Risk Assessment.

Risk Assessment Forum, Office of Research and Development, Washington, D.C. EPA/630/R

95/002F. April 1998.

U.S. Environmental Protection Ag ency. 1991. Reregistration Eligibility document for Sulfur

List A Case Number #0031. March 1991.

U.S. Environmental Protection Agency. 2003. Drinking Water Advisory: Consumer

Acceptability Advice and Health Effects Analysis on Sulfate, dated 02/2003 ( EPA 822

- R

- 03

-

007

.

U.S. Environmental Protection Agency. 2004. Overview of the Ecological Risk Assessment

Process in the Office of Pesticide Programs, U.S. Environmental Protection Agency.

Endangered and Threatened Species Effects Determinations. Offic e of Prevention, Pesticides

and Toxic Substances, Office of Pesticide Programs, Washington, D.C. January 23, 2004.

U.S. Environmental Protection Agency. 200 8. Problem Formulation f or Ecological Risk

Assessment f or Sulfur . Memorandum from EFED to Speci al Review and Reregistration

Division. Office of Pesticide Programs, Washington, D.C., February 7, 2008.

Wallen, I.E., W.C. Greer, and R. Lasater . 1957. Toxicity to Gambusia affinis of Certain Pure

Chemicals in Turbid Waters

. Sewage Ind. Wastes29(6): 695

- 711

URLs:

Fungicide Resistance Action Committee (FRAC) at http://www.frac.info/ (accessed 02/27/2013).

Pesticide Product Label System (PPLS) at http://iaspub.epa.gov/apex/pesticides/f?p=PPLS:1

(accessed 02/27/13).

Structure of rhombic sulfur: http://www.science.uwaterloo.ca/~cchieh/cact/c123/sulfur.html

(accessed 02/26/13 )

.

## Page 26 of 59 

## USEPA, at http://water.epa.gov/drink/contaminants/index.cfm and

http://water.epa.gov/drink/contaminants/i ndex.cfm#SecondaryList (accessed 0 2/27/13 )

## 27 Appendix A. Listed Arthropods in the US

Common name Scientific name Medium Taxa

Beetle, American Burying Nicrophorus americanus Terrestrial Insect

Beetle, Casey's June Dinacoma caseyi Terrestrial Insect

Beetle, Coffin Cave Mold Batrisodes texanus Subterraneous Insect

Beetle, Comal Springs Dryopid Stygoparnus comalensis Freshwater, Subterraneous Insect

Beetle, Comal Springs Riffle Heterelmis comalensis Freshwater, Subterraneous Insect

Beetle, Delta Green Ground Elaphrus viridis Terrestrial, Vernal pool Insect

Beetle, Helotes Mold Batrisodes venyivi Subterraneous Insect

Beetle, Hungerford's Crawling Water Brychius hungerfordi Freshwater Insect

Beetle, Kretschmarr Cave Mold Texamaurops reddelli Subterraneous Insect

Beetle, Mount Hermon June Polyphylla barbata Terrestrial, Subterraneous Insect

Beetle, Northeastern Beach Tiger Cicindela dorsalis dorsalis Terrestrial Insect

Beetle, Ohlone Tiger Cicindela ohlone Terrestrial Insect

Beetle, Puritan Tiger Cicindela puritana Terrestrial, Coastal Insect

Beetle, Salt Creek Tiger Cicindela nevadica lincolniana Terrestrial Insect

Beetle, Tooth Cave Ground Rhadine persephone Subterraneous Insect

Beetle, Valley Elderberry Longhorn Desmocerus californicus

dimorphus Terrestrial Insect

Butterfly, Bay Checkerspot (Wright's

euphydryas) Euphydryas editha bayensis Terrestrial Insect

Butterfly, Behren's Silverspot Speyeria zerene behrensInsect Terrestrial Insect

Butterfly, Callippe Silverspot Speyeria callippe callippe Terrestrial Insect

Butterfly, Cassius Blue Leptotes cassius theonus Terrestrial Insect

Butterfly, Ceranus Blue Hemiargus ceraunus

antibubastus Terrestrial Insect

Butterfly, El Segundo Blue Euphilotes battoides allyni Terrestrial Insect

Butterfly, Fender's Blue Icaricia icarioides fenderi Terrestrial Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Terrestrial Insect

Butterfly, Lange's Metalmark Apodemia mormo langei Terrestrial Insect

Butterfly, Lotis Blue Lycaeides argyrognomon lotis Terrestrial Insect

Butterfly, Miami Blue Cyclargus thomasi

bethunebakeri Terrestrial Insect

Butterfly, Mission Blue Icaricia icarioides missionensis Terrestrial Insect

Butterfly, Mitchell's Satyr Neonympha mitchellInsect

mitchellInsect Terrestrial, Perm. wetland Insect

Butterfly, Myrtle's Silverspot Speyeria zerene myrtleae Terrestrial Insect

Butterfly, Nickerbean Blue Cyclargus ammon Terrestrial Insect

Butterfly, Oregon Silverspot Speyeria zerene hippolyta Terrestrial Insect

Butterfly, Palos Verdes Blue Glaucopsyche lygdamus

palosverdesensis Terrestrial Insect

Butterfly, Quino Checkerspot Euphydryas editha quino (=E.

e. wrighti) Terrestrial Insect

Butterfly, Saint Francis' Satyr Neonympha mitchellInsect

francisci Terrestrial Insect

Butterfly, San Bruno Elfin Callophrys mossInsect bayensis Terrestrial Insect

Butterfly, Schaus Swallowtail Heraclides aristodemus

ponceanus Terrestrial Insect

## 28 Common name Scientific name Medium Taxa

Butterfly, Smith's Blue Euphilotes enoptes smithi Terrestrial Insect

Butterfly, Uncompahgre Fritillary Boloria acrocnema Terrestrial Insect

Damselfly, Flying Earwig

HawaInsectan Megalagrion nesiotes Terrestrial Insect

Damselfly, Pacific HawaInsectan Megalagrion pacificum Terrestrial Insect

Dragonfly, Hine's Emerald Somatochlora hineana Terrestrial, Freshwater Insect

Fly, Delhi Sands Flower

- loving Rhaphiomidas terminatus

abdominalis Terrestrial Insect

Fly, P icture

- wing Drosophila obatai Terrestrial Insect

Fly, P icture

- wing Drosophila substenoptera Terrestrial Insect

Fly, P icture

- wing Drosophila neoclavisetae Terrestrial Insect

Fly, P icture

- wing Drosophila differens Terrestrial Insect

Fly, P icture

- wing Drosophila tarphytrichia Terrestrial Insect

Fly, P icture

- wing Drosophila heteroneura Terrestrial Insect

Fly, P icture

- wing Drosophila musaphilia Terrestrial Insect

Fly, P icture

- wing Drosophila hemipeza Terrestrial Insect

Fly, P icture

- wing Drosophila ochrobasis Terrestrial Insect

Fly, P icture

- wing Drosophila montgomeryi Terrestrial Insect

Fly, P icture

- wing Drosophila mulli Terrestrial Insect

Fly, P icture

- wing Drosophila aglaia Terrestrial Insect

Fly, P icture

- wing Drosophila sharpi Terrestrial Insect

Grasshopper, Zayante Band

- winged Trimerotropis infantilis Terrestrial Insect

Harvestman, Bee Creek Cave Texella reddelli Terrestrial, Subterraneous Arachnid

Harvestman, Bone Cave Texella reyesi Terrestrial, Subterraneous Arachnid

Harvestman, Cokendolpher Cave Texella cokendolpheri Terrestrial, Subterraneous Arachnid

Meshweaver, Braken Bat Cave Cicurina venInsect Terrestrial, Subterraneous Arachnid

Meshweaver, Government Canyon

Bat Cave Cicurina vespera Terrestrial, Subterraneous Arachnid

Meshweaver, Madla's Cave Cicurina madla Terrestrial, Subterraneous Arachnid

Meshweaver, Robber Baron Cave Cicurina baronia Terrestrial, Subterraneous Arachnid

Moth, Blackburn's Sphinx Manduca blackburni Terrestrial Insect

Moth, Kern Primrose Sphinx Euproserpinus euterpe Terrestrial Insect

Naucorid, Ash Meadows Ambrysus amargosus Terrestrial Insect

Pseudoscorpion, Tooth Cave Tartarocreagris texana Terrestrial, Subterraneous Arachnid

Rhadine exilis (ncn) Rhadine exilis Terrestrial, Subterraneous Insect

Rhadine infernalis (ncn) Rhadine infernalis Terrestrial, Subterraneous Insect

Skipper, Carson Wandering Pseudocopaeodes eunus

obscurus Terrestrial Insect

Skipper, Laguna Mountain Pyrgus ruralis lagunae Terrestrial Insect

Skipper, Pawnee Montane Hesperia leonardus montana Terrestrial Insect

Spider, Government Canyon Bat Cave Neoleptoneta microps Terrestrial, Subterraneous Arachnid

Spider, Kauai Cave Wolf Adelocosa anops Terrestrial, Subterraneous Arachnid

Spider, Spruce

- fir Moss Microhexura montivaga Terrestrial Arachnid

Spider, Tooth Cave Leptoneta myopica Terrestrial, Subterraneous Arachnid

## 29 Appendi x B. Registered uses for Sulfur

Table B

- 1 . Maximum Sulfur U se R ates and M anagement P ractices by C rop B ased on

BEAD Provided I nformation 9

Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

NO N

- FOOD/NON

- FEED USES

alfalfa 22.5 lb A WP/D NS NS 14 Aircraft/ Ground

//Dust (a)

clover 24.3 lb A WP/D NS NS 7 Aircraft/ Ground

//Dust (a)

dogs/canines (adults/puppies) 45 lb A WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

10 lb 1K sq.ft

*O1 WP/D NS NS AN Sprayer

//Indoor premise treatment (b)

1

-- (L)

*O1 WP/D NS NS AN Duster

//Animal treatment (dust) (c)

golf course turf 43.98 lb A FlC NS NS 30 Sprayer/ Sprinkler irrigation

//Chemigation/ Spray (a)

grasses grown for seed 30 lb A FlC NS NS 7 Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

greenhouses

- in use 1

-- (L)

*I1 RTU NS NS NS Sprayer

//Spray (a)

horses

(show/race/special/ponies) 11.25 lb 1K sq.ft

*M1 WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

1

-- (L)

*M1 WP/D NS NS AN Duster

//Animal treatment (dust) (b)

nonagricultural uncultivated

areas/soils 18 lb A FlC NS NS NS Aircraft/ Ground/ Sprinkler

irrigation

//Soil treatment (a)

16 lb 1K sq.ft

*C1 WP/D NS NS 42 Soil incorporation equipment

//Soil treatment (surface) (b)

.8000 tbsp plant

*C1 WP/D NS NS 60 Spoon

//Soil treatment/ Soil

treatment (surface) (c)

ornamental and/or shade trees 40 lb A WP/D NS NS 7 Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

9 

### Generalized Screening Level Portrayal of Current Label Uses, dated December 6, 2007.

## 30 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

1.6 lb 1K sq.ft

*C2 WP/D NS NS AN Sprayer

//Broadcast (b)

6 lb/100 gal

*C2 FlC NS NS AN Sprayer

//Spray (c)

1

-- (L)

*C2 RTU

WP/D NS NS 5

AN Sprayer/ Sprinkler irrigation

//Chemigation/ Spray (d)

8 pt (L)

*C2 FlC NS NS AN Sprinkler irrigation

//Chemigation (e)

ornamental grasses 18 lb A DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*I1 DF NS NS AN Sprayer

//Spray (b)

ornamental herbaceous plants 45 lb A WP/D NS NS 7 Aircraft/ Ground

//Dust (a)

3 lb 1K sq.ft

*C2 FlC NS NS 5 Ground

//Spray (b)

6 lb/100 gal

*C2 FlC NS NS 5

AN Ground/ Sprayer

//Spray (c)

1

-- (L)

*C2 RTU

WP/D NS NS 2

AN Duster/ Sprayer/ Sprinkler

irrigation

//Chemigation/ Dust/ Spray (d)

8 pt (L)

*C2 FlC NS NS AN Sprinkler irrigation

//Chemigation (e)

ornamental lawns and turf 43.98 lb A FlC NS NS 30 Sprayer/ Sprinkler irrigation

//Chemigation/ Spray (a)

.7500 lb 1K sq.ft

*C2 FlC 4/1 yr NS NS Sprayer

//Soil treatment (b)

1.8 lb 1K sq.ft

*C2 WP/D NS NS 7 Sprayer

//Spray (c)

ornamental nonflowering

plants 45 lb A WP/D NS NS 7 Aircraft/ Ground

//Dust (a)

1.6 lb 1K sq.ft

*C2 WP/D NS NS AN Sprayer

//Broadcast (b)

6 lb/100 gal

*C2 FlC NS NS AN Sprayer

//Spray (c)

1

-- (L)

*C2 RTU

WP/D NS NS AN Sprayer/ Sprinkler irrigation

//Chemigation/ Spray (d)

8 pt (L)

*C2 FlC NS NS AN Sprinkler irrigation

//Chemigation (e)

ornamental woody shrubs

and vines 45 lb A WP/D NS NS 7 Aircraft/ Ground

//Dust (a)

3 lb 1K sq.ft

*C2 FlC NS NS 5 Ground

//Spray (b)

## 31 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

6 lb/100 gal

*C2 FlC NS NS 5

AN Ground/ Sprayer

//Spray (c)

1

-- (L)

*C2 RTU

WP/D NS NS AN

NS Duster/ Sprayer/ Sprinkler

irrigation

//Chemigation/ Dust/ Spray (d)

6 lb (L)*C2 WP NS NS 7 Sprayer

//Broadcast (e)

8 pt (L)

*C2 FlC NS NS AN Sprinkler irrigation

//Chemigation (f)

8 tbsp (L)

*I1 L NS NS NS Sprayer

//Spray (g)

vetch 39.6 lb A WP/D NS NS 7 Aircraft/ Ground

//Dust (a)

FOOD/FEED USES

agricultural crops/soils

(unspecified) 18 lb A FlC NS NS NS Aircraft/ Ground/ Sprinkler

irrigation

//Soil treatment (a)

.0180 lb sq.ft

*A2 WP/D NS NS 42 Soil incorporation equipment

//Soil treatment (surface) (b)

.9000 tbsp plant

*A2 WP/D NS NS 42 Spoon

//Soil treatment (surface) (c)

.1670 gal (L)

*A2 FlC NS NS NS Sprayer

//Soil band treatment/ Soil

sidedress treatment (d)

alfalfa 49 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

alfalfa sprouts 24.5 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

allspice .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

almond 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

58.8 lb A D NS NS 7 Aircraft/ Ground

//Dust (b)

5.52 lb/100 gal*A2 WP NS NS 7 Aircraft/ Ground

//Spray (c)

amaranth, chinese .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

apple 58.8 lb A D NS NS NS Duster

//Dust (a)

## 32 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

.0183 lb/1 gal

*A2 L NS NS AN Sprayer

//Spray (b)

7.36 lb/100 gal

*A2 WP NS NS NS Aircraft/ Ground

//Spray (c)

apricot 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

artichoke 34.3 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

artichoke, chinese 34.3 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

artichoke, jerusalem 34.3 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

asparagus 49 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

avocado 49 lb A D NS NS AN

NS Aircraft/ Duster/ Ground

//Dust (a)

balm .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

banana .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

barley 45 lb A WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

## 33 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

basil .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans 34.3 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

1

-- (L)

*A2 RTU NS NS 7 Sprayer

//Spray (d)

beans, asparagus .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans, broad .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans, dried

- type 6.75 lb A FlC NS NS 14

AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spra y (a)

beans, goa (winged bean) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans, hyacinth .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans, moth .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans, mung .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

## 34 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

beans, rice .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beans, scarlet runner .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal*H1 DF NS NS AN Sprayer

//Spray (b)

beans, succulent (lima) 6.75 lb A FlC NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

beans, succulent (snap) 6.75 lb A FlC NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

beans, tepary .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

beech nut 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

beets 9.2 lb A WP/D NS NS 14 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer/ Sprinkler irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

beets (unspecified) 19.6 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

## 35 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

blackberry 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

blueberry 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

boysenberry 49 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

brazil nut 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

broccoli 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K

sq.ft*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

brussels sprouts 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

bushberries 13.5 lb A FlC NS NS 10 Aircraft/ Ground/ Sprinkler

irrigation

//Broadcast/ Chemigation (a)

butternut 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

cabbage 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

## 36 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

cabbage, chinese .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

caneberries 13.5 lb A FlC NS NS 10 Aircraft/ Ground/ Sprinkler

irrigation

//Broadcast/ Chemigation (a)

canola \ rape .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

caraway .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

carrot (including tops) 49 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

cashew 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

cauliflower 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

celery 12.5 lb A D NS NS 7 Aircraft/ Ground/ Hand held

duster

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

chayote .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

cherry 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

58.8 lb A D NS NS 7 Aircraft/ Duster/ Ground

//Dust (b)

## 37 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

.0366 lb/1 gal

*A1 L NS NS 12 Sprayer

//Spray (c)

2.625 lb/100 gal

*A1 FlC NS NS NS Sprayer

//Broadcast (d)

chervil .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

chestnut 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

chicory .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

chinquapin 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

chive .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

citron (citrus) 24 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

citrus 98 lb A D 3/cc NS 14 Aircraft/ Ground

//Dust (a)

122.5 lb A D NS NS AN Aircraft/ Ground

//Dust (b)

11.04 lb/100 gal

*A2 WP NS NS AN Aircraft/ Ground

//Spray (c)

clover 29.46 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

coconut .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

coffee .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

collards 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

## 38 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

coriander .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

corn (unspecified) 45 lb A WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

corn, field 45 lb A WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

corn, sweet 4.8 lb A DF NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

cotton (unspecified) 49 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

8 lb/100 gal

*A2 FlC NS NS NS Sprayer

//Broadcast (c)

cowpea/blackeyed pea 24.3 lb A WP/D NS NS 7 Aircraft/ Ground

//Dust (a)

cowpea/sitao 24.5 lb A D NS NS 7 Duster

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

cowpeas 24.5 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

cress, water .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

## 39 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

cucumber 34.3 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

cucurbit vegetables 19.6 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

currant 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

dairy cattle (lactating or

unspecified) 11.25 lb 1K sq.ft

*L1 WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

1

-- (L)

*L1 WP/D NS NS AN Duster

//Animal treatment (dust) (b)

date 122.5 lb A D NS NS AN

NS Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

dewberry 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer

//High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

dill .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

eggplant 34.3 lb A D NS NS 7 Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

endive (escarole) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

## 40 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

3.6 lb/100 gal*H1 DF NS NS AN Sprayer

//Spray (b)

field crops (unspecified) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

fig 49 lb A D NS NS AN

NS Aircraft/ Duster/ Ground

//Dust (a)

filbert (hazelnut) 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

flax 30 lb A FlC NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

fruits (unspecified) 8 tbsp (L)

*H1 L NS NS NS Sprayer

//Spray (a)

garlic 39.2 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

goats (meat) 11.25 lb 1K sq.ft

*L1 WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

1

-- (L)

*L1 WP/D NS NS AN Duster

//Animal treatment (dust) (b)

gooseberry 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

gourds .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

## 41 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

grapefruit 30 lb A FlC NS NS NS Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

grapes 39.2 lb A D NS NS 14

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

.0183 lb/1 gal

*A2 L NS NS 14 Sprayer

//Spray (c)

5.52 lb/100 gal

*A2 WP NS NS AN Aircraft/ Ground

//Spray (d)

1

-- (L)

*A2 RTU NS NS 14 Sprayer

//Spray (e)

grasses grown for seed 6.75 lb A FlC NS NS AN

NS Aircraft/ Ground/ Sprinkler

irrigation

//Broadcast/ Chemigation (a)

greenhouses

- in use 1

-- (L)

*H1 RTU NS NS NS Sprayer

//Spray (a)

guar .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

guayule (rubber) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

hickory nut 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

hog/pig/swine (meat) 11.25 lb 1K sq.ft

*L1 WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

1

-- (L)

*L1 WP/D NS NS AN Duster

//Animal treatment (dust) (b)

hops 49 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

## 42 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

huckleberry 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

jojoba .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

kale 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

kenaf .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

kohlrabi .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

kumquat 24 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer

//High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

lavender .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

leafy vegetables .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

leek .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

## 43 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

lemon 30 lb A FlC NS NS NS Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

lentils .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

lettuce 14.7 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

lettuce, head 4.8 lb A WP NS NS 14 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

lettuce, leaf (black seeded

simpson, salad bowl, etc.) 4.8 lb A WP NS NS 14 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

lime 30 lb A FlC NS NS NS Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer

//High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

loganberry 36.86 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

## 44 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

lupine .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

macadamia nut (bushnut) 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

27.6 lb A WP/D NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer/ Sprinkler irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (b)

mango 30 lb A FlC NS NS 20 Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

.0183 lb/1 gal

*A1 L NS NS 20 Sprayer

//Spray (b)

4.6 lb/100 gal

*A1 WP NS NS AN Ground

//Spray (c)

manioc (cassava) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

marigold, pot .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

marjoram/oregano .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

melons 49 lb A D NS NS NS Aircraft/ Duster/ Ground

//Dust (a)

melons, cantaloupe .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

melons, honeydew 48 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

melons, water .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

## 45 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

melons, winter

(casaba/crenshaw/honeydew/

persian) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

millet, proso (broomcorn) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

mint .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

mushrooms .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

mustard 22.5 lb A WP/D NS NS AN Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

mustard cabbage (gai choy,

pak

- choi) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

nasturtium, garden .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

nectarine 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

58.8 lb A D NS NS 7

10 Aircraft/ Duster/ Ground

//Dust (b)

.0366 lb/1 gal

*A1 L NS NS 12 Sprayer

//Spray (c)

9.2 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (d)

## 46 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

oats 45 lb A WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

okra 3 lb A FlC NS NS 7 Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

olive 68.6 lb A D NS NS AN

NS Aircraft/ Ground

//Dust (a)

onion 49 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

orange 30 lb A FlC NS NS NS Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

papaya 10.5 lb A FlC NS NS AN

NS Aircraft/ Ground/ Sprinkler

irrigation

//Broadcast/ Chemigation (a)

2.925 gal A

*A1 DF NS NS AN Aircraft/ Hand held sprayer/

Knapsack sprayer/ Mechanical

sprayer/ Pneumatic (compressed

air) applicator

//High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (b)

## 47 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (c)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (d)

parsley .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

passion fruit (granadilla) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

peach 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

58.8 lb A D NS NS 7

10 Aircraft/ Duster/ Ground

//Dust (b)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (c)

.0366 lb/1 gal

*A1 L NS NS 12 Sprayer

//Spray (d)

9.2 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (e)

peanuts .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

peanuts (unspecified) 29.4 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

pear 58.8 lb A D NS NS NS Duster

//Dust (a)

.0183 lb/1 gal

*A1 L NS NS AN Sprayer

//Spray (b)

7.36 lb/100 gal

*A1 WP NS NS NS Aircraft/ Ground

//Spray (c)

peas (unspecified) 34.3 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

1

-- (L)

*A2 RTU NS NS 7 Sprayer

//Spray (d)

## 48 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

peas, pigeon .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

pecan 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

24 lb A DF NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (b)

pepper 34.3 lb A D NS NS 7 Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

peppermint 4.8 lb A DF 2/cc NS 30 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

5.52 lb A WP/D 3/cc NS 30 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer/ Sprinkler irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (b)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (c)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (d)

pineapple .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

pistachio 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

49.5 lb A FlC

WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ Dust/ High

volume spray (dilute)/ Low

volume spray (concentrate)/

Spray (b)

plum 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

## 49 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

58.8 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (b)

.0366 lb/1 gal

*A1 L NS NS 12 Sprayer

//Spray (c)

9.2 lb/100 gal

*A1 WP NS NS AN Aircraft

//Spray (d)

pomegranate 49 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

potato, white/irish 14.7 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

poultry (meat) 11.25 lb 1K sq.ft

*L1 WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

1

-- (L)

*L1 WP/D NS NS AN Duster

//Animal treatment (dust) (b)

pricklypear .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

prune 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

58.8 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (b)

.0366 lb/1 gal

*A1 L NS NS 12 Sprayer

//Spray (c)

9.2 lb/100 gal

*A1 WP NS NS AN Aircraft

//Spray (d)

pumpkin 34.3 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

quince 58.8 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

radish .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

## 50 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

raspberry (black, red) 49 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

7.36 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (b)

rice 4.8 lb A DF NS NS AN Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

roquette (arrugula) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

rosemary .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

rutabaga 24.5 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

rye 45 lb A WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

safflower .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

safflower (unspecified) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

sage .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

## 51 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

savory, summer .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

serviceberry 4.8~ lb A DF NS NS 10 Sprayer

//Broadcast (a)

shallot 7.98 lb A FlC NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

sheep (meat) 11.25 lb 1K sq.ft

*L1 WP/D NS NS AN Sprayer

//Indoor premise treatment (a)

1

-- (L)

*L1 WP/D NS NS AN Duster

//Animal treatment (dust) (b)

sorghum 15 lb A FlC NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

sorghum (unspecified) 45 lb A WP/D NS NS AN Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer

//Dust/ High volume spray

(dilute)/ Low volume spray

(concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

soybeans (unspecified) 14.7 lb A D NS NS 7 Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

spearmint 4.8 lb A DF 2/cc NS 30 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

## 52 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

5.52 lb A WP/D 3/cc NS 30 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer/ Sprinkler irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (b)

specialized field crops 18 lb A DF NS NS 7 Airblast/ Sprayer

//Broadcast/ Directed spray/

Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

spinach 30 lb A FlC NS NS 7 Aircraft/ Ground/ High volume

ground sprayer/ Low volume

ground sprayer/ Sprinkler

irrigation

//Chemigation/ High volume

spray (dilute)/ Low volume

spray (concentrate)/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

squash (all or unspecified) 34.3 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

squash (summer) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

squash (winter) .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

strawberry 49 lb A D NS NS AN Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

4.6 lb/100 gal

*A1 WP NS NS AN Aircraft/ Ground

//Spray (c)

1

-- (L)

*A1 RTU

WP/D NS NS 21

AN Aircraft/ Ground/ Sprayer

//Dust/ Spray (d)

## 53 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

sugar beet 2.25 lb A FlC 2/cc NS 10 Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray

(dilute)/Low volume spray

(concentrate)/ Spray (a)

49 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (b)

sugarcane 6 lb A FlC NS NS NS Aircraft/ Ground/ Sprinkler

irrigation

//Chemigation/ Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

sunflower .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

sweet potato .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

tangelo 30 lb A FlC NS NS NS Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer

//High volume spray (dilute)/

Low volume spray

(concentrate)/ Spray (a)

3 lb/100 gal

*A2 FlC NS NS NS Sprayer

//Broadcast (b)

tangerines 30 lb A FlC NS NS NS Aircraft/ High volume ground

sprayer/ Low volume ground

sprayer //High volume spray (dilute)/

Low volume spray (concentrate)/

Spray (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

taro .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

tarragon .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

## 54 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

thyme .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

tobacco .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

tomato 49 lb A D NS NS AN

NS Aircraft/ Duster/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

12.74 lb ft plant

height

*A2 D NS NS NS Duster

//Dust (c)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (d)

triticale .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

turnip (greens) 24.5 lb A D NS NS 7

AN Aircraft/ Duster/ Ground

//Dust (a)

turnip (root) 19.6 lb A D NS NS 7 Aircraft/ Ground

//Dust (a)

vanilla .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

vegetables (unspecified) 8 tbsp (L)

*H1 L NS NS NS Sprayer

//Spray (a)

vetch 39.2 lb A D NS NS 7 Aircraft/ Duster/ Ground

//Dust (a)

walnut (english/black) 6.094 lb A EC 2/1 yr 12.188

lb/cc 30 Ground

//Spray (a)

49 lb A D NS NS AN Aircraft/ Ground

//Dust (b)

wheat 49 lb A D NS NS AN Aircraft/ Ground

//Dust (a)

.4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (b)

## 55 Use Site Max. Rate

per App Max. Rate

Unit/Area

*UG Form Max.#

Apps

cc & yr Max. App

Rate/

cc & yr Min. App

Interval

(days) Application Equipment

//Type (Reg # Code)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (c)

yam .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

yam bean .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

yautia .4132 lb 1K sq.ft

*H1 DF NS NS AN Duster

//Dust (a)

3.6 lb/100 gal

*H1 DF NS NS AN Sprayer

//Spray (b)

**LEGEND**

**HEADER**

**ABBREVIATIONS**

Use Site : The use site refers to the entity (crop, building, surface or article)

where a

pesticide is applied and/or which is being protected.

Max.Rate per App : Maximum dose for a single application to a single site. System

calculated.

Max.Rate Unit/Area : Units and Area associated with the maximum dose.

*UG : Use Group codes.

Form : The physical form of the end use product found in the container.

Max. # Apps cc & yr : The maximum number of applications.

Max. App Rate/cc & yr : The maximum amount of pesticide product that can be applied to a site

in one

growing season (/cc) or during the span of one year (/yr).

Min. App Inter val (days): The minimum retreatment interval between applications in days

(aggregated).

Application Equipment : The equipment used to apply pesticide (aggregated).

Application Type : The type of pesticide application (aggregated).

**ABBREVIATIONS**

AN

- As Needed.

NA

- Not Applicable.

NS

- Not Specified (on label).

(L)

- The dosage information provided is from the label in terms of product (e.g., ounces,

gallons, or

pounds of the product) because there was insufficient information (e.g ., missing density,

area, or

active ingredient percentages) to provide converted dosage information.

~ - The tilde in "Max. Rate per App" indicates a dosage that includes information from a SLN

label.

UC

- Unconverted due to lack of data (on la bel).

**APPLICATION RATE**

W : PPM calculated by weight

V : PPM calculated by volume

U : Unknown whether PPM is given by weight or by volume

cwt : Hundred Weight.

nnE

- xx : nn times (10 power

- xx), for instance, "1.234E

- 4" is equivalent to

".0001234".

-- : No description available in LUIS unit conversion vocabulary.

~ : The dosage information includes a contr ibution from one or more (TQ,

CL, BR, I)

active ingredients.

## 56 **FORMULATION CODES**

D : Dust

DF : Water Dispersible Granules (dry Flowable)

EC : Emulsifiable Concentrate

FlC : Flowable Concentrate

L : Liquid

RTU : Liquid

- ready To Use

WP : Wettable Powder

WP/D : Wettable Powder/dust

**USE GROUP CODES**

A1 : TERRESTRIAL FOOD CROP

A2 : TERRESTRIAL FOOD+FEED CROP

C1 : TERRESTRIAL NON

- FOOD CROP

C2 : TERRESTRIAL NON

- FOOD+O UTDOOR RESIDENTIAL

H1 : GREENHOUSE FOOD CROP

I1 : GREENHOUSE NON

- FOOD CROP

L1 : INDOOR FOOD

M1 : INDOOR NON

- FOOD

O1 : INDOOR RESIDENTIAL

## 57 Appendix C. Environmental Fate and Effects Data Requirements for Sulfur

Table C

- 1. Su lfur Table of Environmental Fate Data Requirement s

Guide

line # Data Requirement Study

ID Study

Classification Are Additional

Data Needed for

Risk Assessment?

835.2120 Hydrolysis No data Waived 1 

### No

835.2240 Photolysis in Water No data Waived 1 

### No

835.2410 Photodegradation on Soil No data Waived 1 

### No

835.2370 Photodegradation in Air No data Waived 1 

### No

835.4100 Aerobic Soil Metabolis m No data Waived 1 

### No

835.4200 Anaerobic Soil Metabolism No data Waived 1 

### No

835.4300 Aerobic Aquatic Metabolism No data Waived 1 

### No

835.4400 Anaerobic Aquatic Metabolism No data Waived 1 

### No

835.1230 Leaching

- Adsorption/ Desorption No data Waived 1 

### No

835.1410 Laboratory Volatility No data Waived 1 

### No

835.8100 Field Volatility No data Waived 1 

### No

835.6100 Terrestrial Field Dissipation No data Waived 1 

### No

835.6200 Aquatic Field Dissipation No data Not required 2 

### No

835.6300 Forestry Dissipation No data Not required 2 

### No

850.1730 Bioconcentr ation in Fish No data Waived 1 

### No

1. The environmental fate data requirements were waived based on the availability of public information on this

chemical. It is likely that sulfur would eventually react in the soil environments in the presence of soil microflora to

form sulfate and enter the environment al sulfur cycle.

2. Data ar e not required because sulfur does not have aquatic uses.



## Table C

- 2. Ecological Effects Data Requirements for Sulfur

Guideline

# Data

Requirement Formulation Are Additional Data

Needed for Risk

Assessment? MRID or Acc.

Number Study

Classification

850.2100 Avian Acute Oral

Toxicity NA No Data waived N/A

850.2200 Avian Subacute

Dietary Toxicity 95% wettable powder

formulation No GS0031

- 003 Satisfied

850.2300 Avian Reproduction

Toxicity NA No Data waived N/A

850.1075 Freshwater Fish LC 50 99.5% dust formulation No GS0031

- 0004,

GS0031

- 0005 Satisfied

850.1010 Freshwater

Invertebrate Acute

LC 50 90% No GS00031

- 0002 Satisfied

850.1075 Estuarine/Marine

Fish LC 50 NA No Data waived N/A

850.1025 Estuarine/Marine

Invertebrate

(Mollusk ) NA No Data waived N/A

850.1035 Estuarine/Marine

Invertebrate (Mysid) 90% No GS00031

- 0002 Satisfied

850.1400 Freshwater Fish Early

Life

- Stage NA No Data waived N/A

850.1300 Aquatic Invertebrate

Life

- Cycle

(Freshwater) Chronic

Toxicity NA No Data waived N/A

850.1350 Aquatic Invertebrate

Life

- Cycle (Marine)

Chronic Toxicity NA No Data waived N/A

## 58 Guideline

# Data

Requirement Formulation Are Additional Data

Needed for Risk

Assessment? MRID or Acc.

Number Study

Classification

850.1500 Freshwater Fish Full

Life

- Cycle NA No Data waived N/A

850.1950 Aquatic Field

Study NA No Data waived N/A

850.3020 Acute Honeybee

Contact Toxicity

Test 98% No 05012143 Satisfied

850.3030 Residues on Foliage

Honeybee Toxicity

Test 92% No 05017101 Satisfied

850.4100;

850.4150 Terrestrial plant

Seeding Emergence

and Vegetative Vigor

(Tier 1) NA No Data waived N/A

850.4400;

850.5400 Aquatic Plant (non

vascular and

vascular) NA No Data waived N/A

NA=Not Available; N/A=Not Applicable