UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY WAS HINGT ON D. C. , 204 60 

### APR 0 6 2015

MEMORANDUM
SUBJECT: Sulfentrazone Usage Information (PC # 129081). OfF I CF OF C H E MI CAL SA F E T Y AND P O I I l.JT I ON PR E V ENT I ON

FROM: Bill Chism, Ph.D., Senior Biologist

# ~ Biological Analysis Branch**~**



# . .

# ~A-**>r~k** Jihad Alsadek, Ph.D. , Economist 

## T Science Information and Analysis Branch Elizabeth Hill , M.S
. , Economist 

## <:::) Economic Analysis Branch L ' Biological and Economic Analysis Division (7503 P) THRU: Arnet Jones, Chief

# ~~ Biological Analysis Branch
. 

# U
Diann Sims , Chief

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

# (.+-

# ~**~~,** Economic Analysis Branch

### ~ )
. Biological and Economic Analysis Division (75 P) TO: Christine Scheltema, Chemical Review Manager Neil Anderson, Chief Risk Management and Implementation Branch III Pesticide Reevaluation Division (7505P) BEAD Product Review Panel date: February 11, 20 1 5SUMMARY This document describes the use and usage of sulfentrazone which is undergoing registration reevaluation in the Office of Pesticide Programs. The Biological and Economic Analysis Division (BEAD) received a request by the Pesticide Reevaluation Division (PRD) to provide usage information to be used to develop risk assessment estimates. BEAD was asked to describe the key crops where sulfentrazone is used, its use rate in key states, the average and upper bounds oftreatment rates, application timing, crops where applications are made by air, and use in California. BACKGROUND Sulfentrazone is a broad spectrum herbicide that inhibits the germination of propagules and seeds ofbroadleaf, grass, and sedge weeds
. It is used on field crops, fruits, ornamentals, turf grass, and vegetable crops in many states. It is used on field crops, fruits, ornamentals, turf grass, and vegetable crops at ra tes from 0.01 to 0.38 lb ai/acre. This document describes the usage of sulfentrazone on a number of different crops in several states
. The rates and acres treated may differ slightly between tables because of differences in the way in which the data were selected and summarized. Sulfentrazone is a soil-applied, pre-emergent and postemergence herbicide which can be applied either preplant incorporated, preemergence or postemergence to the weeds. Sulfentrazone is a ProtoPorphyrinogen Oxidase (PPO) Inhibitor (WSSA Group 14). Thi s herbicide inhibits the protoporphyrinogen oxidase enzyme which is important in the production of chlorophyll which causes a peroxidation of lipids in the cell membrane leading to cell leakage. Sulfentrazone is absorbed primarily by the roots and leads to rapid fo li ar des iccation (WSSA, 2014). Because sulfentrazone inhibits seed and propagule germination, for pre -emergent treatment it needs to be applied as close to the soil surface as possible with the lowest possible amount of pesticide intercepted by leaf surfaces and the minimum amount of exposure to evaporation or the wind. For example, the Sulfentrazone XP herbicideTM label says to "apply large dropl ets 1 setting the boom at the lowes t height which provides uniform coverage reduces the exposure of droplets to evaporation and wind." For postemergence applications uniform foliar coverage is critical for optimum weed control. USAGE Data on sulfentrazone usage i s provided in Tables 1 through 5
. Additional re gistered uses may exist but are not included because the available surveys do not report usage (e.g., sma ll acreage crops). Lack ofreported pesticide usage data on a crop does not imply zero usage . Nonagricultura l use sites (e.g., turf, other ornamentals, etc.) are generally not reported.

1 The Sulfentrazone XP label lists th e wrong size for large droplets it should read 350-450 microns not> 150

- 200 microns. Page 2Table 

### 1. Screening Lev el Usage Analysis (SLUA) Estimates ofAgricultural Uses of S 

### lfi R
. Y · 200 20 1 "

u entrazone. eportmg ears: 4

- .) 

### . Crop Average Annual Percent Cro D Treated Pounds (a.i.) Aoolied Avera2e Maximum 

### 1 Alfalfa 1 ,000 < 1 <2 .5 

### 2 Asp aragus 1 , 000 15 30 

### 3 Barley <500 < 1 <2.5 

### 4 Beans, Green <500 10 15 

### 5 Beans, Lima <5 00 10 15 

### 6 Cabbage <5 00 <2
. 5 5 

### 7 Com 5,000 < 1 <2 .5 

### 8 Cucumber <5 00 <2.5 <2.5 

### 9 Dry Beans/Peas 30,000 15 25 

### 10 Fa llow 3,000 <1 <2 .5 11 Peanuts 1 ,000 <1 <2.5 

### 12 Peas, Green <500 <1 <2.5 

### 13 Potatoes 4,000 <2. 5 <2.5 

### 14 Rice 4,000 <2 .5 <2
. 5 

### 15 Soybeans 500,000 5 15 

### 16 Strawberries 1 , 000 5 10 

### 17 Sugarcane 3,000 <2.5 <2 .5 

### 18 Sunflowers 100,000
. 50 65 

### 19 Tomatoes <5 00 <2.5 <2
. 5 

### 20 Tobacco 3 0,000 45 65 

### 21 Watermelons <500 <2.5 <2.5 

### 22 Wheat 3,000 <1 <2.5 • Footnote : E PA
. 2015
. See Appendix 1 for c omplete informati on. National average application rate, rate app lications b etween the goth and 1 ooth percentile , acres treated , and acres grown (Table 2) are de signed to provide additional usage data on an individual crop bas is for refined risk assessments. The average app li cation rates range from 0.061 to 0.2 2 1 lb ai/acre while applications rates falling between the goth and 1 ooth perc entile ran ge fro m 0.06 to 0.31 lb ai/acre.

Page 3

### Table 2. Sulfentrazone National Crop Acres Grown, Average Annual Total Acre Treatments, L abel Maximum, Average Application Rate per Trea tme nt , and Upper Percentile A 

### 1'

. R D 

### f 2008 2012

.pp 1catlon ate. ata rom 

### - 

### Maximum Application Average Annual Average Single Average Rate Annual Application Application between Crop Crop Acres Total Acres From Label Rate (lb the SOth 

### Grown Treated (lb ai/acre) ai/acre) and iooth 

### Percentile 1 Asparagus 30,060 5,550 0
. 38 0.19 0.19 Barley 3,174,200 150 0
. 19 0.09 0 .09 Cabbage 63,680 950 0.38 0.22 0.31 Com 89,526,009 28,700 0.25 0.06 0.07 C ucumbers 131,249 500 0
. 25 0.20 0.2 Dry 2 ,737,479 4 1 4,000 0 .2 5 0
.09 0.12 Beans/Peas Lima Beans 36,345 950 0 .1 9 0.08 0.07 Peas (Fresh/Green/ 180,037 <50 0.19 0.13 0.13 Sweet) Soybeans 76,297,988 3,084,800 0.38 0. 1 5 0.22 Strawberries 54,31 4 2,200 0.38 0.22 0.25 Sunflowers 1 ,955,000 1,233,950 0.25 0.11 0.16 Tobacco 335,386 173 ,500 0
. 38 0.18 0.25 Tomatoes 0.38 0.11 0.11 Watermelons 130, 460 400 0.25 0.11 0.13 Win ter Wheat 0.19 0 .0 6 0.06 

### Total 174,733,527 4 ,950 ,000 0
. 14 0.22 Proprietary data, 2008-2012. Numbers may not add due to rounding . 1 Represents the highes t rate between the 80 1h and l 00 1 h percentile (varies by crop). Crop application timing by state (Ta ble 3) is des igned to prov ide additional usage data on an individual crop basis for more refined risk assessments. In over 95% o f cases, sulfentrazon e is applied before planting but it is also occasionally applied ear ly and late post emergence or in the late fall
. Barley i s the only crop in which sulfentrazone i s exclusively appl ied in the late fall for chemical fallow
.

Page4Table 3. Appl ication Tim in g, Percent of Total Acre Treatments by Crop and State, for 2008- 2012 Early CROP STATE Before &Late Last Planting Post Fall Asparagus Michigan 100% 0% 0% Barley Montana 0% 0% 100% Cabbage North Carolina 100% 0% 0% Cabbage Wisconsin 100% 0% 0% Com Illinois 100% 0% 0% Com Indiana 100% 0% 0% Com Iowa 100% 0% 0% Com Minnesota 100% 0% 0% Com Missouri 100% 0% 0% Com Ohio 100% 0% 0% Cucumbers South Carolina 100% 0% 0% Dry Beans/Peas Colorado 100% 0% 0% Dry Beans/Peas Idaho 97% 0% 3% Dry Beans/Peas Minnesota 100% 0% 0% Dry Beans/Peas Montana 97% 0% 3% Dry Beans/Peas Nebraska 100% 0% 0% Dry Beans/Peas North Dakota 98% 0% 1% Dry Beans/Peas Washington 28% 72% 0% Lima Beans Delaware 1 00% 0% 0% Peas (Fresh/Green/Sweet) Wisconsin 100% 0% 0% Soybeans Arkansas 100% 0% 0% Soybeans Illinois 91% 0% 9% Soybeans Indiana 99% 0% 1% Soybeans Iowa 99% 0% 1% Soybeans Kansas 84% 0% 16% Soybeans Kentucky 100% 0% 0% Soybeans Louisiana 100% 0% 0% Soybeans Maryland 100% 0% 0% Soybeans Michigan 100% 0% 0% Soybeans Minnesota 100% 0% 0% Soybeans Mississiooi 100% 0% 0% Soybeans Misso uri 87% 0% 13% Soybeans Nebraska 94% 0% 6% Soybeans North Carolina 100% 0% 0% Soybeans North Dakota 100% 0% 0% Soybeans Ohio 

### 87% 0% 13% Soybeans Oklahoma 100% 0% 0% Page 5Early CROP STATE Before &Late Last Plantim! Post Fall Soybeans South Dakota 100% 0% 0% Soybeans T ennessee 100% 0% 0% Soybeans Wisconsin 100% 0% 0% Strawberries Michigan 100% 0% 0% Strawberries Oregon 100% 0% 0% Strawberries Pennsylvania 100% 0% 0% Strawberr ie s Washington 100% 0% 0% Sunflowers Colorado 100% 0% 0% Sunflowers Kans as 99% 0% 1 % Sunflowers Minnesota 100% 0% 0% Sunflowers Nebraska 1 00% 0% 0% Sunflowers North Dakota 97% 2% 1 % Sunflowers South Dakota 96% 1% 3% Sunflowers Texas 100% 0% 0% Tobacco Florida 100% 0% 0% Tobacco Georgia 72% 28% 0% T obacco Kentucky 96% 3% 0% Tobacco North Carolina 97% 3% 0% Tobacco Ohio 100% 0% 0% Tobacco Penn sylvania 100% 0% 0% Tobacco South Carolina 98% 2% 0% Tobacco Tennessee 99% 1% 0% Tobacco Virginia 100% 0% 0% Averaee 95.2% 0.5% 4 .2% Footnote: Proprietary data 2008

- 20 1 2
. All numbers are rounded. Early and late post indicate an application approximately two to six weeks after planting
. Fall app licat ion indica tes a treatment the previous fall after the last crop is harvested. Fall applications can provide control of winter weeds. Crop aerial applications are reported for soybeans and sunflower (T able 4) and are designed to provide additional usage data on an individual crop basis for more refined risk assessments. A majority of aerial applications are made to soybeans, with most applications occurring in Illinois. Sunflowers are al so treated aerially, with the highest proportion of acreage treated aerially occurring in North Dakota. Aerial applications were not reported for any other crop or state and can be assumed to be ground applications
. Soybean aerial application rates range from 0.09 to 0.136 lbs. ai/acre at the state level, with aerial application to soybeans accounting for 2% oftotal soybean acres treated nationally . Sunflower aerial app lication rates range from 0.089 to 0.149 lbs. ai/acre at the state level, with aerial Page 6applications to sunflowers accounting for 5% of total sunflower acres treated nationally . Overall, total aerial applications of sulfentrazone made at the national level account for 2% of the total acres treated with sulfentrazone. Table 4. Sulfentrazone Aerial App lication, Total Area Treated (acres), Percent Crop Treated, d A 

## r . R (lb
. 

### I ) A 

### fl 2009 20 1 3 an •PP 1cat1on ate
. a.1. acre, verages or 

### - Total Area Percent of Total Average Aerial Crop State Treated Area Treated that Application Rate Aeriallv is made Aeriallv (lb . ai/acre) Soybeans Arkansas 3,700 6% 0.090 Soybeans Illinois 57,400 8% 0.136 Soybeans Iowa 3 , 900 <1% 0.120 Soybeans Ohio 28,100 2% 0.131 Sunflowers Kansas 5,600 7% 0.089 Sunflowers North Dakota 12 ,200 12% 0.122 Sunflowers South Dakota 40 , 000 8% 0.149 Footnote: Proprietary data 2009

- 2013
. All numbers are rounded. All other applications are ground applied. Sulfentrazone usage in California by crop (Table 5) is designed to provide additional usage data on alternative crops that national level data did not capture which could allow for more refined risk assessments. App licat ions to alternative crops in California are relative ly low , however it should be noted that application rates to asparagus are the highest rate shown at 0.37 lbs. ai/acre. Note that with 3 , 500 acres of mint grown in California in 2011, sulfentrazone could be used on as much as 20% of mint acres grown in the state (Wil son 

### et al. , 20 1 1 ). Tabl 5 

### S lfi 

## u · c r fi · 2010 2012 

### e 

# . u entrazone sage m a i orn1a,


### - Total Application Crop Area Rate Treated (lb ai/acre) Asparagus 77 0
. 37 Landscape Maintenance 6.14 0.01 Mint 718 0.25 Ornamentals

- Greenhouse Grown, Cut Flowers or Greens 14.21 0.13 Ornamenta l s - Outdoor Grown Cut Flowers or Greens 2.6 0.07 Ornamental Turf 265.1 0 0.17 Strawberry Fruit 18 0.23 Uncultivated Non

-Ag Areas 3.5 0.25 Source: California Department ofPesticide Regulation (CALDPR).

Page 7REFERENCES EPA. 2013. Sulfentrazone (129081), Screening Level Usage Analysis (SLUA)
. February 27, 2013. Proprietary data on pesticide usage, 2004-2012
. Wilson, R., D.B. Marcum, K.M. Klonsky, and R.L. De Moura
. 2011. Sample Costs to Establish a Mint Stand and Produce Peppermint Oil. University of California Cooperative Extension
. http :/ /co st studi es .ucdav is.edu/files/PeppermintIM2011
.pdf. WSSA. 2014. Herbicide Handbook, Weed Science Society of America, Tenth Edition, 2014.

Page 8APPENDIX 

### 1. 

### What is a Screening Level Usage Analysis (SLUA)? • Available estimates of pesticide usage data for a particular active ingredient that is used on 

### agricultural crops in the United States. • Pesticide usage data obtained from various sources. The data are then merged, averaged, and rounded so that the presented information is not proprietary , business confidential, or trade secret. 

### What does it contain? • Pesticide usage data for a 

### single active ingredient only. • Agricultural use sites (crops) that the pesticide is reported to be used on. • Available pesticide usage information from U.S. states that produce 80% or more of a crop, in most cases, or less than 80%, in rare cases, depending on the scope of the survey and available resources. • Annual percent of crop treated 

### (average & 

### maximum) for each agricultural crop. • Average annual pounds of the pesticide applied for each agricultural crop (i.e., for the states surveyed, not for the entire United States). 

### What assumptions can I make about the reported data? • Average pounds of active ingredient applied

- Values are calculated by merging pesticide usage data sources together; averaging across all observat ions, then rounding. Note: 

## If the estimated value is less than 500, then that value is labeled < 500. Estimated values between 500 & < l, 000, 000 are rounded to 1 significant digit. Estimated values of 1, 000, 000 or greater are rounded to 2 significant digits.) 

### • Average percent of crop treated

- Values are calculated by merging data sources together; averaging by year, averaging across all years, 

### & rounding to the nearest multiple of 5. Note: 

## If the estimated value is less than 2.5, then the value is labeled <2.5
. If the estimated value is less than 1, then the value is labeled <l
. 

### • Maximum percent of crop treated

- Value is the single maximum value reported across all data sources, across all years, & rounded up to the nearest multiple of 5. Note: 

## If the estimated value is less than 2.5, then the value is labeled <2
. 5. 

### What a r e the data sources used? • USDA

- NASS (United States Department of Agriculture 's National Agricultural Statistics Service)

- pesticide usage data from 2004 to 2012. 

### • Private pesticide market research

- pesticide usage data from 2004 to 2012. 

### • California Department of Pesticide Regulation (DPR) Pesticide Use Reporting (PUR) data for 2004 to 2011. 

### What are the limitations to the data? • Additional registered uses may exist but are not included because the availab le surveys do not report usage (e
.g., small acreage crops). • Lack ofreported usage data for the pesticide on a crop 

### does not imply zero usage. • Usage data on a particular site may be noted in data sources, but 

### not quantified. In th

ese instances, the site would not be reported in the SLUA. • Non-agricultural use sites (e.g., turf, post-harvest, mosquito control, etc.) are not reported in the SLUA.
Page 9• Some sites show some use, even though they are no t on the label. This usage could be due to various factors, including, but no t limited to Section 18 requests, existing s tocks of the chemica l , data collect ion errors, and experimental use permi ts (EUPs).

Page 10