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. Risk 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, sulfur 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. 20071

). Sulfur 

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 concentrate (F), liquid (L), liquid ready-to-use 

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

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

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

up to 122.5 lb a.i./A per application. Examples of target pests include apple cedar rust, black rot, 

frog eye leaf spot, powdery mildew, quince rust, scab and sooty blotch on apple crops; and 

Yuma spider mite, rust mite and clover 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 42 million pounds annually on grapes see 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 environment. Elemental sulfur is required for the 

existence of animal and plant life. As indicated above, sulfur 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. All 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 extension, risks to terrestrial-phase 

amphibians and reptiles for which avian toxicity data are used 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. This conclusion 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 sulfur are rapidly incorporated into the natural sulfur cycle once 

released.

Elemental sulfur, when applied as a pesticide, will become incorporated in soils and animals and 

plants tissues. The main processes and transformations of elemental sulfur into the natural sulfur 

cycle are oxidation into sulfate (SO4

2-

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

into sulfide (S2-

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

microbes. The subsequent fate of S2- is dependent on metal sulfide precipitation or volatilization

of H2S (g). The dissipation of SO4

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 fact, is used as a soil 

amendment to supplement sulfur fertility. Microbes and plants can assimilate SO4

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 additions, 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 LOCATES database. Therefore, the greatest potential for direct 

affects to listed species is expected to be limited to the remaining 58 insect and 1 arachnid

species. Indirect effects may occur to listed and non-listed terrestrial insectivorous birds, 

amphibians, 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 Sulfur

Listed Taxon Direct Effects Indirect Effectsa

Terrestrial Invertebrates Uncertainb Uncertainc

Terrestrial plants – monocots Uncertaind Uncertain

Terrestrial plants – dicots Uncertaind Uncertain

Birds No effect Uncertainc

Terrestrial-phase amphibians and reptiles No effect Uncertainc

Mammals No effect Uncertainc

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 invertebrates 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 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, 

further evaluation of the potential for 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 D375973, March 30, 2010). As 

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

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

The Fungicide Resistance Action Committee (FRAC2

) has designated sulfur as FRAC Code M2 

(the only chemical in the group); the chemical belongs to the broader mode 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 this fungicide. Its risk 

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

potential adverse effects from the registered outdoor uses of sulfur on aquatic organisms and 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 02/07/2008). 

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 review 

indicated at the time, that there was a concern that upon oxidation, elemental sulfur forms 

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

carbonate, was applied to neutralize the acidity produced by the sulfur. In addition, it 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. Its 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 disulfur (S2), trisulfur (S3), tetrasulfur (S4), 

ρ-sulfur (cyclohexasulfur, S6), α-, β-, γ-, and δ-cycloheptasulfur (S7), α-sulfur (rhombic sulfur, 

S8), β-sulfur (monoclinic sulfur, S8), γ-sulfur (S8), cyclo-(nona; deca; undeca; dodeca; trideca; 

tetradeca; pentadeca; 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 (S8, eight atoms of sulfur: rhombic elemental 

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

3

 3 Structure of rhombic sulfur (S8), accessed 2/26/13, and available at 

http://www.science.uwaterloo.ca/~cchieh/cact/c123/sulfur.html.
Page 6 of 59

Figure 1. Structure of Rhombic Sulfur

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 S8 at 2980K (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 elemental sulfur in the environment. Richard et al.

(1977) gives 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, the 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 (H2S (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

Common/Chemical name Sulfur1

Pesticide type Fungicide, Insecticide, Acaricide

CAS number 7704-34-9

Empirical formula S (can exist as rhombic or alpha S8 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 odorless/tasteless or faint taste

Melting Point 112.8 to 120°C

Boiling Point 444.6 °C

Vapor pressure 3.95x10-6 mm Hg at 30.4°C
Page 7 of 59

Common/Chemical name Sulfur1

Henry’s Law Constant (atm-m3/mol) 3.42x10-5 (calculated)

Solubility in water (at 2980K = 250C) 1.9(±0.6)x10-8 mol S8/L = 4.87 ppb (Boulegue, 1978)

Solubilities 1 g/2 ml carbon disulfide

Soluble 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 2013, 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 range 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/cm3

, and a 

soil depth of 15 cm (6 inches), the expected soil concentration is ~57 mg/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 H2S (g) escape. Elemental sulfur, when 

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

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

form, mediated by bacteria, which could subsequently be lost via volatilization of H2S (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 (SO4

2-

). Sulfate may exist as salts of numerous metals such as 

Na

+

, Ca2+, Mg2+, Cu2+, Zn2+, Fe2+, Fe3+, etc., or sulfuric acid (H2SO4) (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 by 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 sulfur reaction to occur in soil, it should be incorporated to increase 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:

CO2 + S0 + 1⁄2O2 + 2H2O → CH2O + SO4

2- + 2H+

Elemental sulfur’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 that 

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 from coarse particles. Direct 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 2-200C. At 200C, the DT50’s ranged from 6-

10 days. Temperature had a marked effect, with DT50’s of 36-42 days at 20C. Germida & 

Hanzen (1993) reiterated these 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 

exposed 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 favor 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 S0

, when applied to crops (i.e., vineyards) rapidly oxidizes to the SO4

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 anion and ester bonded sulfates. 

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

According to USEPA 2003, “Sulfates are naturally occurring substances 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 atmospheric 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 99th percentile value was 560 mg/L.” This illustrates that sulfate, the product of 

oxidation of sulfur, is a natural and ubiquitous component of U.S. waters and is not likely 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 concentrate (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 concentrate (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 (PPLS4 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 gooseberries, currants, apricots, 

raspberries, and cucurbits and should not be treated with sulfur5. 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 others, 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 laurels, 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 season 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., on citrus crops aerial or ground dust applications, refer to the Appendix B). 

Examples of target pests include apple cedar rust, black rot, frog eye leaf spot, powdery mildew, 

quince rust, scab and sooty blotch on apple crops; and rust mite and clover mite on citrus crops.

Additionally, sulfur 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. For 

example, an Ohio State University Extension Fact 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 that need extensive acidification. This rate is over 27x higher than the highest application 

rate in BEAD’s profile. 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. The data is assumed to represent the 

average pounds 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 treated6

. 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 grapes, 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 SO2 and sodium metabisulfite Na2S2O5). According to USGS statistics, the 

apparent 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 tons. “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 SLUA 

dated 12/05/2007

Crop lb a.i. applied % Crop Trtd Ave % Crop Trtd Max

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

Usage data available for the state of California 8 indicates that for the years 2003-2006, there was 

a decrease in the total use of sulfur, as a pesticide, from 53,180,000 lb in 2003 to 45,920,000 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/minerals/pubs/commodity/sulfur/mcs-2012-sulfu.pdf (accessed 04/09/13).

8 California Department of Pesticide Regulations 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. Ecosystems 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 hedgerows, 

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 estuaries. 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 exposure of 

elemental sulfur to aquatic ecosystems.

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 environment 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, 

selection 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 estimated 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 sulfur.

To estimate exposure concentrations, the ecological risk assessment considers a single 

application at the maximum application rate to fields that have vulnerable soils. The 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 reproductive, 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, subacute, and reproduction studies 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 further 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

Birds1

Mallard (Anas platyrhynchos)

Bobwhite (Colinus virginianus); LC50

>5,620 ppm diet

Practically non-toxic

Mammals Laboratory rat (Rattus norvegicus) LD50

> 5000 mg/kg bw Practically non-toxic 

Insects Honey bee (Apis mellifera L.) Practically non-toxic

Freshwater fish2

Bluegill sunfish (Lepomis macrochirus)

LC50 >180 ppm

Rainbow trout (Oncorhynchus mykiss)

LC50 >180 ppm

Practically non-toxic

Freshwater invertebrates Water flea (Daphnia magna) LC50

>5,000 ppm Practically non-toxic

Estuarine/marine fish Sheepshead minnow (Cyprinodon 

variegatus) Data waived

Estuarine/marine 

invertebrates

Mysid shrimp (Americamysis bahia)

LC50 736 ppm

Eastern oyster (Crassostrea virginica)

Practically non-toxic

Terrestrial plants3 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 amphibians 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 seven acceptable toxicity 

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

nontoxic on an acute basis to both terrestrial and aquatic animals. With birds, an eight-day 
Page 13 of 59

dietary study conducted on bobwhite quail resulted in an LC50 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, an acute oral rat toxicity study resulted in an LD50 value of > 5g/kg

with no mortalities reported (Acc. No. 252262). Information on sublethal effects was not 

available. 

Acute toxicity tests on two fish species, rainbow trout and bluegill sunfish, resulted in LC50

values 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 LC50 of >5,000 ppm and a 96-h LC50 of 736 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 insect studies demonstrated that sulfur is low in toxicity to the honey bee 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) its 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 of 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 summarizes toxicity data for sulfur that are 

consistent with assessments endpoints 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. Limitations 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 calculation). 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 sulfide in pore water due to incorporation and transformation 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 exceptionally high rates applied to the soil/sediment system. This 

finding supports the expectation that anthropogenic sulfur additions to the environment (semiaquatic in this case) are readily assimilated into the natural sulfur cycle without causing 

observable adverse effects on non-target organisms tested in these studies.

Table 5. Open literature toxicity data for sulfur.

Species Duration 

(days)

Endpoint Concentration1 Citation 

[ECOTOX #]

Western Mosquitofish

(Gambusia affinis)

4 LC50 > 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 LC50 > 40 mg a.i./L Nishiuchi and Asano 

(1979) [#6954]

Bog frog (Rana 

limnocharis)

2 LC50 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 μg/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 incident report indicated damage to 44 acres of a grape

vineyard in Yolo County, CA treated directly with sulfur and trifloxystrobin 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 terrestrial plant data for 

trifloxystrobin result in an EC25 greater than the highest concentration 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 grapes 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 reported 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 sulfur 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 adverse 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 any incidents in 

relation to avian species. IDS reported one minor fish and wildlife incident from 3rd 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 specific case of sulfur, 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 concentrate), 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 rainfall events. However, 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 application 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 transport 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 terrestrial 

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 effects to aquatic organisms (especially fish) can also occur through impact to various 

food chains. However, due to the fact that sulfur is insoluble in water, minimal exposure is 
Page 16 of 59

expected. Sulfur 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 sulfur). 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 sulfur exposure. This is based on potential exposure due to the large 

application rates (e.g., 122.5 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, birds 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 sulfur, the following ecological risk hypothesis is being employed for this baseline risk 

assessment:

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

accordance with the label, may result in potential adverse effects upon survival of nontarget 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 Aquatic Animals

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 spray drift or runoff would reach 

its solubility limit. For 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 estuarine/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 

LC50

FW Invert

LC50

E/M Fish

LC50

E/M Invert

LC50

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 (LC50 >180 mg 

a.i./L), daphnia (Daphnia magna) for freshwater invertebrates (LC50 5000 μg a.i./L), rainbow trout (Oncorhynchus 

mykiss or Salmo gairdneri) for estuarine/marine fish (LC50 >180 mg a.i./L), and mysid shrimp (Americamysis bahia 

or Mysidopsis bahia) for estuarine/marine invertebrates (EC50 = 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 <1x10-5 in all instances; however, they are expressed as <<0.01 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 limit 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 Section 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 toxicity 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 that 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 (H2S (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 in soil at pH 7 (Lindsay, 1978). Elemental 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). It 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. Although 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 acidification 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 anion is expected to be the predominant species of sulfur. 

Elemental 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 H2S (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 using the standard EFED terrestrial 

exposure model T-REX (v 1.5.1) is technically 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., exceeding 24,000 ppm on short grass). These high EECs combined 

with the lack of definitive toxicity endpoints (e.g., LD50 > 5,000 mg/kg mammals; > 5,620 ppm 

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

mathematically possible 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 into 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 toxicity 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 additions, for example, flying or leaf-dwelling 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 lines 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 due 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 lines 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 effects 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 review 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, there 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 

statements 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 screening-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. Potential direct effects on listed terrestrial invertebrates and 

terrestrial plants (monocots and dicots) 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, at this current stage of the Registration Review process, 

it is premature to make 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 described 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). Scientific 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., habitat, 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 models. 

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, when, 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 analysis 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 assessment, 

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), have 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 

assessments 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 including:

• 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 reviewing 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 assessments. 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 species 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 species 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 precluded. 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 habitat) 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 terrestrial invertebrates, there 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 insects. 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 on 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 

limitations 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 list 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 treated 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 include 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 to 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 Effectsa

Terrestrial Invertebrates Uncertainb Uncertainc

Terrestrial plants - monocots Uncertain Uncertain

Terrestrial plants - dicots Uncertain Uncertain

Birds No effect Uncertainc

Terrestrial-phase amphibians and reptiles No effect Uncertainc

Mammals No effect Uncertainc

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 invertebrates 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 
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, 

further 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 2980K. Phosphorous and Sulfur 

and the Related Elements (Short Communication. 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. Mineralium 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). 2013. 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 Control 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 Zealand 

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. The 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. & Tech. 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/R95/002F. April 1998. 

U.S. Environmental Protection Agency. 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. Office of Prevention, Pesticides 

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

U.S. Environmental Protection Agency. 2008. Problem Formulation for Ecological Risk 

Assessment for Sulfur. Memorandum from EFED to Special 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/index.cfm#SecondaryList (accessed 02/27/13)
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, Picture-wing Drosophila obatai Terrestrial Insect

Fly, Picture-wing Drosophila substenoptera Terrestrial Insect

Fly, Picture-wing Drosophila neoclavisetae Terrestrial Insect

Fly, Picture-wing Drosophila differens Terrestrial Insect

Fly, Picture-wing Drosophila tarphytrichia Terrestrial Insect

Fly, Picture-wing Drosophila heteroneura Terrestrial Insect

Fly, Picture-wing Drosophila musaphilia Terrestrial Insect

Fly, Picture-wing Drosophila hemipeza Terrestrial Insect

Fly, Picture-wing Drosophila ochrobasis Terrestrial Insect

Fly, Picture-wing Drosophila montgomeryi Terrestrial Insect

Fly, Picture-wing Drosophila mulli Terrestrial Insect

Fly, Picture-wing Drosophila aglaia Terrestrial Insect

Fly, Picture-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

Appendix B. Registered uses for Sulfur

Table B-1. Maximum Sulfur Use Rates and Management Practices by Crop Based on 

BEAD Provided Information9

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)/ Spray (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 Interval (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 label). 

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 contribution 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+OUTDOOR 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. Sulfur Table of Environmental Fate Data Requirements

Guideline # Data Requirement Study 

ID

Study 

Classification

Are Additional 

Data Needed for 

Risk Assessment?

835.2120 Hydrolysis No data Waived1 No

835.2240 Photolysis in Water No data Waived1 No

835.2410 Photodegradation on Soil No data Waived1 No

835.2370 Photodegradation in Air No data Waived1 No

835.4100 Aerobic Soil Metabolis m No data Waived1 No

835.4200 Anaerobic Soil Metabolism No data Waived1 No

835.4300 Aerobic Aquatic Metabolism No data Waived1 No

835.4400 Anaerobic Aquatic Metabolism No data Waived1 No

835.1230 Leaching-Adsorption/ Desorption No data Waived1 No

835.1410 Laboratory Volatility No data Waived1 No

835.8100 Field Volatility No data Waived1 No

835.6100 Terrestrial Field Dissipation No data Waived1 No

835.6200 Aquatic Field Dissipation No data Not required2 No

835.6300 Forestry Dissipation No data Not required2 No

850.1730 Bioconcentration in Fish No data Waived1 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 environmental sulfur cycle.

2. Data are 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 LC50 99.5% dust formulation No GS0031-0004, 

GS0031-0005 Satisfied

850.1010

Freshwater 

Invertebrate Acute 

LC50

90% No GS00031-0002 Satisfied

850.1075 Estuarine/Marine 

Fish LC50

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 (nonvascular and 

vascular)

NA No Data waived N/A

NA=Not Available; N/A=Not Applicable