UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

MAR 3 0 2016 

MEMORANDUM 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: BEAD Chemical Profile Case (BCP) for Registration Review: Triadimefon 

(109901) and Triadimenol (127201) 

FROM: Tara 

Biological 

Chandgoyal

Analysis 

, Ph.D.

.Branch 

, Plant Pathologist 

...... ( 

/tUA ~ ~ 

THRU: 

TO: 

Jihad Alsadek, Ph.D., Economist J '-MI}- A 

Science Information and Analysis Branch 

Economic 

Stephen Smearman

Analysis 

, 

Branch 

Economist 

~ 

J. _ J. ~ 

Biological and Economic Analysis Division (7503P) 

Colwell Cook, Acting Chief~_.¥ 6-L 

Biological Analysis Branch 

Diann 

Science 

Sims, 

Information 

Chief ~ and Analysis Branch 

Economic 

Timothy Kiely

Analysis , Chief 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 

1 
SUMMARY 

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 of hyphal 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 of fungicides. 

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. of triadimefon used in 2006 and 600 

lbs. a.i. used in 2009 on nursery and floriculture. The most recent estimate of use of triadimefon 

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 

of triadimeriol, both in terms of pounds 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 of all 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 of the pesticide. 

The Biological and Economic Analysis Division (BEAD) chemical profile case (BCP) provides 

an overview of the pest management roles and quantitative usage information for these two 

chemicals, triadimefon and triadimenol. The BCP case includes summaries of previous 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 of these fungicides. 

2 
This document addresses the usage and role of triadimefon, 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 

Analysis (SLUA) was prepared by BEAD for this chemical in 2014 that provides the national 

level of pounds 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 of prior BEAD assessments 

specifically for this chemical in the last 10 years. 

3 
USAGE for TRIADIMEFON 

Based on market research data from 1998-2013, use oftriadimefon has been decreasing over 

time in terms of pounds 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 of the 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 

N 
FIGURE 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 of Agriculture (USDA, 2014) indicates that 

there were about 52,000 acres of non-bearing apples and pears in the U.S., suggesting that 

around five percent of the pear acreage and about 2.5% of the apple acreage is treated with 

triadimefon. The relatively low percent crop treated on these crops is probably an indication of 

the impacts of the 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 of Triadimefon 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 of hyphal 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) of FRAC classification of fungicides (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 

5 
and 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 of action (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 of this 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 of pounds applied by active ingredient (a.i.) and percent crop treated (PCT) data for crops 

for which usage data are available. 

6 
Benefits Assessments - A search of BEAD's Official Records data base for BEAD benefits 

assessments specifically for triadimenol did not find any records of prior BEAD assessments 

specifically for this chemical in the last 10 years. 

Emergency Exemptions-A search of BEAD'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 of the 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 of triadimenol, both in terms of pounds 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 

7 
FIGURE 4. Triadimenol Total Area Treated in Acres (2006-2013) 

2,500,000 

VI 

cu 

... 

.., 

<( 

c: 

"'O 

cu 

-

"' cu 

... 

I-

"' cu 

... 

<( 

Iii 

-0 

I0 <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 of the cotton crop was treated, on average, from 2006 to 2012. Between 2011 and 2013, 

however, about 12 percent of cotton acreage has been treated while a small amount of winter 

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 of triadimenol use as a seed treatment. Use is 

found in most cotton growing areas and appears consistent with the extent of cotton production. 

8 
Total 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 of triadimenol' 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 of the 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 of each of the various crops treated by the pesticide. 

TAT is based on market surveys of pesticide 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 of the crop. ·Although the surveys capture most of the use of a 

particular active ingredient in agriculture, there are several limitations to these surveys. 

• States with minor production of a surveyed crop are not sampled 

• Not all types of pesticides are surveyed in every crop in every year 

• Many specialty crops with very small acreages are not included in the survey 

The result of these limitations is that states that show no acres treated may actually have a small 

amount of the active ingredient being used. In some cases, the displayed TAT may be distorted 

9 
because 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 of hyphal 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 of fungicides (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 of this fungicide. 

REFERENCES: 

BEAD, 2014. Triadimefon Screening Level Usage Analysis. Biological and Economic Analysis 

Division, Office of Pesticide Programs, US Environmental Protection Agency. July18, 

2014 

BEAD, 2015. Triadimenol Screening Level Usage Analysis. Biological and Economic Analysis 

Division, Office of Pesticide Programs, US Environmental Protection Agency. 

FRAC, 2015. Fungicide Resistance Action Committee Code List: Fungicides Sorted by Mode 

of Action. 

http://www. frac. info/ docs/ defaul t-source/publications/frac-code-list/frac-code-list-2015-

final C2AD7AA36764. pdf?sfvrsn=4 Accessed on November 6, 2015. 

10 
Kline & 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 of Agriculture. Available at: 

http://www.agcensus. usda. gov/Publications/2007 /index.asp. 

USDA, 2007. Census of Agriculture. (for Land in Farms data). Available at: 

http://www.agcensus. usda. gov /Publications/2007 /index.asp. 

http://www.epa.gov I oppOOOO 1/ chem search/reg actions/reregistration/fs U G-6 01-Aug2006. pdf 

http://www.epa.gov I oppOOOO 1 I chem search/reg actions/reregistration/red U G-6 01 -

Aug-2006. pdf 

USDA. 2014. 2012 Census of Agriculture. National Agricultural Statistics Service, 

United States Department of Agriculture. 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 of Action. 

http://apsjournals.apsnet.org/doi/abs/10.1094/PDIS-91-12-154 7 

Accessed on November 12, 2015. 

11