UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D

.C

. 20460 

### MAR 30 2016

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUT ION PREVENTION SUBJECT: BEAD Chemical Profile Case (BCP) for Registration Review: Triadimefon (109901 ) and Triadimenol (127201) FROM: Tara Chandgoyal, Ph.D. , Plant Pathologist 

# /tUA**~** Biological Analysis .Branch
......(**~**

THRU:

TO: Jihad Alsadek, Ph.D. , Economist J 

# '-MI}- A Science Information and Analysis Branch Stephen Smearman, Economist 

## J.
_ J.**~** Economic Analysis Branch

### ~ Biological and Economic Analysis Division (7503P) Colwell Cook, Acting**Chief~_.¥** 

# 6-L Biological Analysis Branch Diann Sims,

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

# ~**~** Economic Analysis Branch ·

### ~ Biological and Economic Analysis ivision ( 3P) Christina Motilall, Chemical Review Manager Risk Management and Implementation Branch 1 Pesticide Re-evaluation Division (7508P)
Peer Review Panel date: November 18, 2015



### 1SUMMARY This profile case covers two active ingredients, triadimefon (109901) and triadimenol (127201 ). These fungicides will be discussed separately in this document. These fungicides inhibit sterol demethylation in fungi, causing fungal cell wall collapse and inhibition ofhyphal growth. These antifungal properties result in fungal growth control on various use sites (crops and treated wood). These fungicides belongs to fungicide group 3 (SBI: Class I, such as fenbuconazole, myclobutanil, propiconazole, prothioconazole, tebuconazole, tetraconazole and some others) of Fungicide Resistance Action Committee (FRAC, 2015) classification offungicides. Triadimefon was first registered as a fungicide in the U.S. in 1968 (USEPA, 2006) and was published in 2006. Triadimefon is used agricultural and non-agricultural sites as well as for antimicrobial purposes. Based on market research data from 2008 to 2013, agricultural use of triadimefon has declined significantly and seems to have stabilized at approximately 200-300 pounds a.i. to treat 1600-2500 acres annually for use on non-bearing fruit trees. The average application rate over this time period ranged from 0.12 to 0.13 lbs
. a.i
. I acre . There are no reported agricultural usage data in 2011 and 2013
. For non-agricultural use oftriadimefon, proprietary data report that there was about 1,900 lbs. a.i. oftriadimefon used in 2006 and 600 lbs
. a.i. used in 2009 on nursery and floriculture
. The most recent estimate ofuse oftriadimefon on turf and floriculture is 114 thousand lbs. a.i. (Kline, 2011 )
. Triadimenol ·was first registered as a fungicide in the U.S. in 1984 (USEPA, 2006) and reregistered in 2006. It is mainly used as a cotton seed treatment to protect seed from soil-borne fungal pest. Based on market research data from 2006-2012, usage for triadimenol averaged approximately 1 ,500 pounds active ingredient (lbs. a.i.) applied annually on approximately 678,000 acres. The average application rate for this fungicide is 0.002 lbs. a.i. per acre. The use oftriadimeriol, both in terms ofpounds a.i. applied and total area treated, increased significantly during the 2006-2012 timeframe (Market Research Data, 2006-2012). INTRODUCTION FIFRA Section 3(g) mandates that EPA periodically reviews the registrations ofall pesticides to insure that they do not pose unreasonable adverse effects to human health and the environment. This periodic review is necessary in light of scientific advancements , changes in policy, and changes in use patterns that may alter the conditions underpinning previous registration decisions. In determining whether effects are unreasonable, FIFRA requires that the Agency considers the risks and benefits of any use ofthe pesticide. The Biological and Economic Analysis Division (BEAD) chemical profile case (BCP) provides an overview ofthe pest management roles and quantitative usage information for these two chemicals, triadimefon and triadimenol. The BCP case includes summaries ofprevious BEAD products and available public and/or use and usage data for triadimefon and triadimenol that describes their role in pest management. Additional information on use is available in the triadimefon and triadimenol LUIS Label Data Reports. Information provided in this BCP case may be used by stakeholders (e.g., users and registrants) , OPP risk assessors, OPP risk managers, and the general public during the Registration Review process ofthese fungicides.
2This document addresses the usage and role oftriadimefon, followed by the usage and role of triadimenol , for conventional uses . Information on the antimicrobial use of triadimefon is found in Triadimefon and Triadimenol Preliminary Work Plan
. Scoping Document in Support of Registration Review for Human Health Assessment, and EFED and AD Registration Review Problem Formulation for Triadimefon and Triadimenol in Docket Number EPA-HQ-OPP-2016- 0114. TRIADIMEFON USE SITES for TRIADIMEFON Agricultural Use Sites Triadimefon registered agricultural use sites include: non-bearing fruit trees , and pine seedlings
. Non-agricultural Use Sites Triadimefon registered non-agricultural use sites include: Christmas trees , commercial/industrial lawns , forest trees , golf course turf , ornamentals , recreation area lawns , and residential lawns
. Antimicrobial Use Sites Antimicrobial uses include wood treatment for wood-based composite products , wood products intended for above ground and in-ground contact, reconstituted wood-based composite products , and veneer-based wood products. FORMULATIONS AND APPLICATION METHODS for TRIADIMEFON Triadimefon is formulated as wettable powder, fluid concentrate, dry flowable , ready-to-use, granular and soluble concentrate. Triadimefon is applied as chemigation, spray, broadcast, tree injection treatment, seed treatment, dip treatment, mixing or milling treatment and wood protection treatments . HISTORY OF TRIADIMEFON and BEAD PRODUCTS Triadimefon is a fungicide registered for use in the U.S. since 1968. A Screening Level Usage Analy sis (SLUA) was prepared by BEAD for this chemical in 2014 that provides the national level ofpounds applied by active ingredient (a.i.) and percent crop treated (PCT) data for crops for which usage data are available. Benefits Assessments - A search of BEAD ' s Official Records database for BEAD benefits assessments specifically for triadimefon did not find any records ofprior BEAD assessments specifically for this chemical in the last 10 years.

3USAGE for TRIADIMEFON Based on market research data from 1998-2013 , use oftriadimefon has been decreasing over time in terms ofpounds active ingredient (lbs
. a.i
.) applied, shown in Figure 1, and total area treated in acres , Figure 2 (Market Research Data, 1998-2013)
. Triadimefon was reregistered in 2006 , at which time all food uses were cancelled, leading to a sharp decline in use between 2007 and 2008
. There was no reported agricultural use in 2011 and 2013. In 2012 , there was reported use on apples and pears that was a fraction ofthe historical use for both crops. FIGURE 

## 1· _

Triadimefon Usage in_**~ounds** Active Ingredient Applied (1998-2013) 14,000

"'C**~** c.. c.. <( <i. Ill "'C c :J 0 0..

0 0 .-i 8 

### 8 N N

Source: Market Research Data, 1998-2013 N 8 N

Note : there are no reported usage data in 2011 and 201 3. m <ot Lil ID ,.... 00 0\ 

### 8 8 8 8 8 8 8 N N N N N N N Years

4 0 8 N N 8 NFIGURE 2.**TriadiJ!!~fon** Total Area Treated in Acres (1998-2013) 120,000

0 0 ..... N rn 'o:t Lil ,.._ 8 8 8 

### 8 8 8 8 N N N N N N N Years Source: Market Research Data, 1998-2012 Note : there are no reported usage data in 2011 and 2013
. 00 C7I 0 N 

### 8 8 

## s s N N N N

Between 2008 and 2013, the most recent for which data are available, use on non-bearing apples and pears has averaged 200 to 300 pounds a.i. per year on 1,600 to 2,500 acres per year. Overall, the application rate ranged from about 0.12 to 0.13 lbs a.i./acre the same time period. In terms of the percent crop treated, data from the 2012 Census ofAgriculture (USDA, 2014) indicates that there were about 52,000 acres ofnon-bearing apples and pears in the U.S., suggesting that around five percent ofthe pear acreage and about 2
.5% ofthe apple acreage is treated with triadimefon. The relatively low percent crop treated on these crops is probably an indication of the impacts ofthe voluntary cancellations as reported in the 2006 RED (EPA 2006)
. However, pesticide use specifically on non-bearing acres is not extensively surveyed so this use may be underestimated. For non-agricultural use, the most recent data reporting use for triadimefon is on turf and floriculture totaling approximately 114 thousand lbs. a.i. (Kline, 2011 ). Geographic Distribution ofTriadimefon Use No Total Area Treated (TAT) map was generated due to the small sample size for triadimefon. BIOLOGICAL ASPECTS RELEVANT TO TRIADEMEFON Triadimefon inhibits sterol demethylation in fungi, causing fungal cell wall collapse and inhibition ofhyphal growth. These antifungal properties result in fungal growth control on various use sites (such as treated plants and wood). Triadimefon belongs to fungicide group 3 (SBI: Class I, such as fenbuconazole, myclobutanil, propiconazole, prothioconazole, tebuconazole, tetraconazole and some others) ofFRAC classification offungicides (FRAC, 2015). There is medium risk of developing resistance in fungal plant pathogens against metconazole (FRAC, 2015). Many fungi have developed resistance against triadimefon (Wong 

### 5and Midland, 2007). Triadimefon is registered for use on non-bearing fruit trees . Triadimefon can be used as a stand-alone fungicide or in combination/alternation with fungicides with different mode of action (such as azoxystrobin, pyraclostrobin). ROLE OF TRIADEMEFON IN PEST MANAGEMENT Since 2006 , triadimefon is predominantly applied as foliar sprays on non-bearing apples and pears in Michigan, California, New York, Ohio , Virginia, and Washington to control fungal diseases
. Triadimefon can be used stand alone and/or in combination with other fungicides with different modes ofaction (such as azoxystrobin, pyraclostrobin) for better disease control and resistance management. Triadimefon is used on Christmas trees, commercial/industrial lawns, forest trees , golf course turf , ornamentals , recreational area lawns , residential lawns to suppress and control fungal pests. It is also used a wood treatment to protect wood from decaying. DATA NEEDS FOR TRIADIMEFON The Agency currently does not have important information on triadimefon. Obtaining information on agricultural use sites, such as seedling pines , and on non-agricultural use sites , such as Christmas trees , commercial/industrial lawns , forest trees , golf course turf , ornamentals, recreational area lawns , residential lawns as well as use as a wood protection treatment for outdoor building products may improve future assessments conducted by the Agency related to the use and importance ofthis fungicide
. TRIADIMENOL USE SITES for TRIADIMENOL Agricultural Use Sites Triadimenol registered agricultural use sites include: barley, com, cotton, oats , rye and wheat. Non-agricultural Use Sites Triadimenol registered non-agricultural use sites includes grasses . FORMULATIONS AND APPLICATION METHODS for TRIADIMENOL Triadimenol is formulated as flowable concentrate and soluble liquid concentrate and is applied as a seed treatment. HISTORY OF TRIADIMENOL and BEAD PRODUCTS Triadimenol is a fungicide registered for use in the U
.S. since 1984
. A Screening Level Usage Analysis (SLUA) was prepared by BEAD for this triadimenol in 2014 that provides the national level ofpounds applied by active ingredient (a.i
.) and percent crop treated (PCT) data for crops for which usage data are available
.

6Benefits Assessments - A search ofBEAD ' s Official Records data base for BEAD benefits assessments specifically for triadimenol did not find any records ofprior BEAD assessments specifically for this chemical in the last 10 years . Emergency Exemptions-A search ofBEAD ' s Official Records did not find any Section 18s requests for triadimenol in the last 10 years. Emergency exemptions may indicate that there is a need for a particular chemical that is not registered for use on a particular site. An emergency exemption request may yield information about a particular chemical ' s importance or value that is not found in other EPA records
. However, a lack of Section 18 assessments by BEAD does not specifically indicate the relative importance ofthe chemical. 

### USAGE for TRIADIMENOL Agricultural Use Sites Based on market research data from 2006-2013 , usage for triadimenol averaged approximately 2,000 pounds active ingredient (lbs
. a.i
.) applied annually on approximately 759 ,000 acres . The average application rate for this fungicide , used as a seed treatment, is 0.003 lbs. a.i. per acre. Figure 3 presents triadimenol usage in lbs. a.i. over the 2006-2013 timeframe ; Figure 4 presents total area treated in acres over the same time period (Market Research Data, 2006-2012). The use oftriadimenol , both in terms ofpounds a.i. applied and total area treated in acres , has increased recently , averaging about 4,500 lbs a.i
. applied annually to over 1.6 million acres each year between 2011 and 2013
. The average application rate remains approximately 0.003 lbs a.i. per acre. 

### FIGURE 3. Triadimenol Usage for Cotton Seed Treatment in Pounds Active Ingredient Ap_plied (2006-2013)

"C

.!!:! c.. c.. <( <i. 

### "' "C c: ;:, 0 0.. 6,000

0

Source: Market Research Data, 2006-2013 Years

7FIGURE 4. Triadimenol Total Area Treated in Acres (2006-2013) 2,500,000

VI cu 

## ... .., <( c: "'O cu 

# - "' cu 

## ... I- 

## "' cu 

## ... <( Iii 

# - 0I0 <D ,.... 00 

## °' 0**~** N 

### ..., 8 8 8 8**~ ~**  g g 0 0 N N N N N N N N Years Source: Market Research Data, 2006-2013 A Screening Level Usage Analysis (SLUA) was prepared by BEAD for triadimenol in 2015 that provides national level poundage applied by active ingredient (a.i.) and percent crop treated (PCT) data for crops for which usage data are available
. The analysis indicates about five percent ofthe cotton crop was treated, on average , from 2006 to 2012. Between 2011 and 2013 , however, about 12 percent ofcotton acreage has been treated while a small amount ofwinter wheat has been treated. It is unclear whether the increased use in recent years represents an increased reliance on triadimenol by cotton and wheat growers or is the result of some unusual conditions. Figure 5 presents the geographical distribution oftriadimenol use as a seed treatment. Use is found in most cotton growing areas and appears consistent with the extent ofcotton production.

8Total Acres Treated**NoData ~**  <3,000 J.001

- 20
.000

- 20 ,001

- 42 ,000

- 42
.001

- 105
. 500

- •105
. 501 Figure 5. Average annual acres treated with triadimenol (2009-2013). (Source: Market Research Data) The map included herein is for general use in the registration review process . The map provides a very broad geographical view oftriadimenol ' s average annual total acres treated (TAT) over 5 years of a pesticide on all agricultural crops. The map units are of average annual total acres treated, which accounts for all agricultural acreage treated with this chemical and includes multiple treatments to the same area. The data used to make these maps have many limitations. Any interpretation ofthe maps should consider the underlying data and the associated limitations carefully. For example, there may be significant differences in the crop acres grown between states and there may be variation in the percent ofeach ofthe various crops treated by the pesticide. TAT is based on market surveys ofpesticide use in agriculture averaged over the last five years (Market Research Data, 2009-2013). These surveys cover about 60 crops and are targeted in states that produce the majority ofthe crop. ·Although the surveys capture most ofthe use of a particular active ingredient in agriculture, there are several limitations to these surveys . • States with minor production ofa surveyed crop are not sampled • Not all types ofpesticides are surveyed in every crop in every year • Many specialty crops with very small acreages are not included in the survey The result ofthese limitations is that states that show no acres treated may actually have a small amount ofthe active ingredient being used. In some cases , the displayed TAT may be distorted 

### 9because the surveyed crops and the reported pesticide usage (or TAT) does not accurately represent the actual pesticide usage on the crops produced in the state. The reader should pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical as the total acre treatment intervals used in the legend will likely be different. Non-agricultural Use Sites There are no reported usage data for non-agricultural use sites for triadimenol. BIOLOGICAL ASPECTS RELEVANT TO TRIADEMENOL Like triadimefon, triadimenol inhibits sterol demethylation in fungi , causing fungal cell wall collapse and inhibition ofhyphal growth
. These antifungal properties result in fungal growth control on treated seeds
. Triadimenol belongs to fungicide group 3 (SBI: Class I, such as fenbuconazole , myclobutanil, propiconazole, prothioconazole, tebuconazole , tetraconazole and some others) ofFRAC classification offungicides (FRAC , 2015). ROLE OF TRIADIMENOL IN PEST MANAGEMENT On cotton, triadimenol is used in combination with different fungicides (with different mode of action) to treat seed for protection against wide spectrum of soil-borne fungi (Kelly, 2013) that cause seed decay and soil-borne seedling diseases. DATA NEEDS FOR TRIADIMENOL The Agency currently does not have important information on triadimenol. Obtaining usage data for agricultural use sites including crops such as barley, com, and oats as well as for nonagricultural use sites such as grasses , may improve future assessments conducted by the Agency related to the use and importance ofthis fungicide
. REFERENCES: BEAD , 2014. Triadimefon Screening Level Usage Analysis. Biological and Economic Analysis Division, Office ofPesticide Programs, US Environmental Protection Agency. July 18 , 2014 BEAD, 2015. Triadimenol Screening Level Usage Analysis. Biological and Economic Analysis Division, Office ofPesticide Programs , US Environmental Protection Agency. FRAC , 2015. Fungicide Resistance Action Committee Code List: Fungicides Sorted by Mode ofAction. http: //www.frac. info/docs/default-source/publications/frac-code-list/frac-code-list-2015- finalC2AD7AA36764.pdf?sfvrsn=4 Accessed on November 6, 2015
.
10Kline & Co. , 2002 , 2004 , 2006 and 2011
. Professional Turf and Ornamental Markets for Pesticides and Fertilizers USA 2012 Market Research Data, 1998-2013. USDA, 2006-2010. NASS Crop Reporting Districts (shape file of CRDs). Available at : http: //www.ers.usda
.gov/briefing/arms/resourceregions/resourceregions
.htm#nass
. USDA, 2006-2010. NASS Crop Reporting Districts
. Available at: http: //www.nass.usda
.gov/Data and Statistics/County Data Files/Frequently Asked Q uestions/county list.txt USDA, 2007
. Census ofAgriculture
. Available at: http ://www .agcensus .usda. gov/Publications/2007/index
.asp . USDA, 2007. Census ofAgriculture. (for Land in Farms data). Available at : http: //www.agcensus . usda
.gov/Publications/2007/index.asp
. http: //www.epa.govI oppOOOO 1/ chem search/reg actions/reregistration/fs UG-6 01-Aug2006.pdf http: //www.epa.govIoppOOOO 1I chem search/reg actions/reregistration/red UG-6 01

- Aug

-2006
. pdf USDA. 2014. 2012 Census ofAgriculture. National Agricultural Statistics Service, United States Department ofAgriculture. May 2014. http: //www.agcensus.usda.gov/Publications/2012/
. Wong, FP and Midland, SL. 2007. Sensitivity Distributions of California Populations of Colletotrichum cereale to the DMI Fungicides Propiconazole, Myclobutanil , Tebuconazole, and Triadimefon ofAction. http: //apsjournals
.apsnet.org/doi/abs/ 10.1094/PDIS-91-12-1547 Accessed on November 12, 2015
.

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