Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON, D.C. 20460

 

 Office of Chemical Safety & Pollution Prevention

 Office of Pesticide Programs 

MEMORANDUM March 16, 2015

SUBJECT: Science Review in Support of the Registration of Checkmate VMB-F, 

An End-Use Product (EP) Containing 19.35% 2-Butenoic, 3-Methyl-, 

5-Methyl-2-(1-Methylethenyl)-4-hexenyl Ester (Lavandulyl 

Senecioate; Vine Mealy Bug Pheromone). Review of New Food Use. 

 EPA Reg. No.: 56336-AT

 Tolerance Petition No.: 4F8292

 Decision Nos.: 492433

 DP Nos.: 424659

 Chemical Class: Biochemical

 PC Codes: 036005

 CAS Nos. 23960-07-8 

 MRIDs: 494132-01 to -05; 494803-01 & 495193-01

FROM: Russell S. Jones, Ph.D., Senior Scientist /s/ 03/16/2015 

Biochemical Pesticides Branch

Biopesticide & Pollution Prevention Division (7511P) 

THRU: Colin Walsh, Regulatory Action Leader /s/ 03/16/2015 

Biochemical Pesticides Branch

 Biopesticide & Pollution Prevention Division (7511P)

Action Requested

On behalf of Suterra LLC, T. Tipton requests registration of Checkmate VMB-F (EPA 

File Symbol No. 56336-AT), containing 19.35% Vine Mealybug (Planococcus ficus) 

pheromone as its active ingredient (a.i.). This is a new food use application. The product 

is intended for use in disrupting the mating activities of the Vine Mealybug in raisin, 

table, and wine grape vineyards. In support of the registration, the applicant has 

submitted product chemistry information and rationales in support of the Tier I Human 

health and Tier I non-target organism data requirements.
Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

RECOMMENDATIONS AND CONCLUSIONS

1a. The product chemistry submission is ACCEPTABLE. No additional 

information is required. Storage Stability and Corrosion Characteristics 

studies are in progress and will be submitted for review upon completion. 

1b. The Confidential Statement of Formula (dated 06/12/2014) is 

ACCEPTABLE. 

2a. The rationales submitted in support of the TGAI and EP human health data 

requirements are ACCEPTABLE and support the New Food Use for Vine 

Mealy Bug pheromone. A human health assessment for the Vine Mealy Bug 

pheromone (Lavandulyl Senecioate) is contained in the Lavandulyl Senecioate

BRAD, dated 01/20/2010. 

2b. Vine Mealy Bug pheromone is classified in Toxicity Category IV for acute 

oral toxicity, acute dermal toxicity, and primary eye irritation; and Toxicity 

Category III for primary dermal irritation (see Table 1 below). 

2c. Vine Mealy Bug pheromone is not considered to have subchronic (90-day) 

toxicity by any route of exposure (oral, dermal, inhalation), is not a mutagen, 

and is not a developmental toxicant. These conclusions are based on the 

following (see discussion in Section II A below for details): 

 i. low acute toxicity (see Table 1 below);

 ii. a low application rate of no more than10 grams a.i. per acre per 

application; 

 iii. a low estimated maximum emission rate of 0.48 grams (480 mg) a.i. per 

acre per day over a 21 day period; 

 iv. an Estimated Environmental Concentration (EEC) of 0.0000486 mg/L 

(or ppm; within a simulated grape orchard); and 

 v. the high volatility and rapid degradation of arthropod pheromones in 

the environment (OECD, 2002), resulting in extremely low exposure to 

humans and the environment. 

There are no dietary concerns for Lavandulyl Senecioate when applied in 

accord with EPA-approved label use directions, based upon extremely low 

application rate, extremely low potential for residues, minimal toxicity, and 

the extremely low likelihood of oral exposure to the pheromone due to its high 

volatility and rapid biodegradation. All intentionally added inert ingredients 

in the end-use product (EP) are cleared for food use under 40 CFR 180.910; 

180.920; and/or 180.950. 

3a. Non-target organism studies are not required for non-target organisms when 

applied at no more that 150 g a.i. per acre per year [40 CFR 158.2060(a)(2)].
Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

3b. There are no concerns for non-target organisms as a result of exposure to the 

sprayable end-use product (see Conclusion 2c above). 

STUDY SUMMARIES

I. Product Chemistry (MRIDs 494132-01 to -03) 

A. Product Identity and Composition (MRID 49413201, Confidential Appendix, 

p. 7; OCSPP 830.1550/880.1100): Checkmate VMB-F (EPA File Symbol 

No. 56336-AT), is an end-use product (EP) containing 19.35% Vine Mealy 

Bug pheromone. The product is an aqueous, flowable, sprayable, microbead 

formulation, with each microbead encapsulating synthesized components of 

the naturally-occurring vine mealybug (Planococcus ficus) pheromone 

(lavanduyl senecioate). The source of the active ingredient in the EP is VMB 

Technical Pheromone (EPA Reg. No. 56336-55). All intentionally added 

inert ingredients are cleared for food use under 40 CFR 180.910; 180.920; 

and/or 180.950 (see CSF dated 06/12/2014 for the identity of the intentionally 

added inert ingredients; and MRID 49413201, Confidential Appendix pp. 15-

89). 

 Active Ingredient: Lavanduyl Senecioate (19.35%) 

 Synonyms: Vine Mealy Bug pheromone; 5-Methyl-2-(1-

methylethenyl)-4-hexenyl-3-ethyl-2-butonate 

 CAS No.: 23960-07-8 

 Mol Wgt: approx 236 

 

 Inert Ingredients: 80.65% 

Structure of Lavandulyl Senecioate

B. Starting Materials, Manufacturing Process, and Formulation Process (OCSPP 

830.1600, 830.1620, &830.1650/880.1200): (See Confidential Appendix) 

 For a detailed description of the manufacturing process see MRID 49413201, 

Confidential Appendix, pp. 90-94. All MSDS for ingredients are contained in 

MRID 49413201. 

Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

Table 1. Physical and Chemical Properties for CheckMate® VMB-F (56336-AT)

Guideline Reference No./Property Description of Result Methods

830.6302 Color Not required for EP -

830.6303 Physical State Clear liquid Visual inspection

830.6304 Odor Not required for EP -

830.6313 Stability Not required for EP -

830.6315 Flammability Not applicable; product is an 

aqueous suspension

-

830.6317 Storage Stability Study is in progress -

830.6319 Miscibility Not Applicable; product is not an 

emulsifiable liquid and is not 

diluted with petroleum solvents

-

830.6320 Corrosion Characteristics Study is in progress -

830.7000 pH Not applicable; product is a solid 

microbead in aqueous suspension

-

830.7050 UV/Visible Absorption Not required for EP -

830.7100 Viscosity Not applicable; product is a solid 

microbead in aqueous suspension

-

830.7200 Melting Range Not required for EP -

830.7220 Boiling Range Not required for EP -

830.7300 Density/Relative Density/Bulk 

Density

0.98 g/cm3 Method JIS K 2249

MRID 47595803

830.7520 Particle Size Not required for EP -

830.7550 Partition Coefficient Not required for EP -

830.7840 Water Solubility Not required for EP -

830.7950 Vapor Pressure Not required for EP -

Classification: ACCEPTABLE 

II. TGAI: Tier I Human Health Assessment (MRIDs 49480301 & 49413204): 

The acute toxicity database for the active ingredient, Lavandulyl Senecioate, has 

been previously reviewed and deemed Acceptable by the Agency (see Lavandulyl 

Senecioate BRAD, dated 01/20/2010). The active ingredient is classified in 

Toxicity Category IV for acute oral toxicity, acute dermal toxicity, and primary 

eye irritation; and Toxicity Category III for primary dermal irritation. Studies 

were not submitted for acute inhalation toxicity, dermal sensitization, subchronic 

testing, developmental toxicity, and mutagenicity. The data requirements for 

acute inhalation toxicity, dermal sensitization, and mutagenicity were based on 
Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

rationales demonstrating low application rates and low exposure due to the 

product being contained in a retrievable dispenser. 

The subject product is applied as a microbead formulation and, therefore, is not 

exempt from all of the Tier I Human Health data requirements under 40 CFR 

158.2050(d). In support of the remaining data requirements and the new food use, 

applicant submitted additional information in support of the data requirements for 

acute inhalation toxicity, primary eye irritation, primary dermal irritation, dermal 

sensitization, subchronic (90-day) studies for oral, dermal, and inhalation toxicity. 

Table 1. Toxicity Profile for Lavandulyl Senecioate TGAI

Study Type/OCSPP Guideline LD50/LC50/Results Toxicity

Category

MRID

Acute Oral Toxicity/870.1100 >5000 mg/Kg IV 47595804 1

Acute Dermal Toxicity/870.1200 >5000 mg/Kg IV 47595804 1

Acute Inhalation Toxicity/870.1300 >5.21 mg/L IV 49413204, pp. 50-66

Primary Eye Irritation/870.2400 Minimally Irritating IV 47595804 1

Primary Dermal Irritation/870.2500 Moderately Irritating III 47595804 1

Dermal Sensitization/870.2600 Not a sensitizer - 49413204, pp. 67-82; 

49519301

90-Day Oral Toxicity(rat)/870.3100 No subchronic oral toxicity 

based on credible scientific 

rationale (see below)

-

90-Day Dermal Toxicity/870.3250 - 49413204, pp. 36-45

90-Day Inhalation Toxicity/870.3465 -

Prenatal Developmental Toxicity/870.3700 Not a developmental toxicant 

toxicity based on credible 

scientific rationale (see below)

-

49413204, pp. 46-48

Bacterial Reverse Mutation/870.5100 Not a mutagen - 49413204, pp. 81-123

In Vitro Mammalian Cell Gene Mutation 

Assay/870.5300

Not a mutagen - 49413204, pp. 124-173

In Vivo Mammalian Cytogenetics/870.5395 Not a mutagen - 49413204, pp. 174-215 1 cited in Lavandulyl Senecioate BRAD, dated 01/20/2010

Classification: ACCEPTABLE

A. 90-day Oral Toxicity (rat); 90-Day Dermal Toxicity; 90-Day Inhalation 

Toxicity (OCSPP 870.3100; 870.3250; 870.3465; MRID 49413204, pp. 

36-45): In lieu of Guideline studies, the applicant submitted individual 

scientific rationales in support of the data requirements. The rationales are 

essentially the same and are summarized and discussed together below. 

The rationales are based on the following: 

 1. The acute oral LD50 is >5000; the acute inhalation LC50 is >5.21 

mg/L; and the acute dermal LD50 is >5000 mg/kg 

 2. The maximum application rate is no more than 10 grams a.i. per acre 

per application (see calculations in MRID 49413204, p 42); 
Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

 3. The maximum estimated emission rate from the microbeads is 0.48 

grams (480 mg) a.i. per acre per day over a 21 day period; (see 

calculations in MRID 49413204, p 43); 

 4. The Estimated Environmental Concentration (EEC) within a 

treated grape orchard is 0.0000486 mg/L, assuming 

 

 a. An average grape orchard height = 8 ft and a calculated cubic area 

= 348, 480 ft3, or 9,869 m3; 

 b. All of the daily pheromone emission (480 mg/A/day) remains 

within the orchard; 

 c. the product is applied at the maximum label rate (10 g a.i. per acre 

per application; and 

 (see all calculations in MRID 49413204, p 43) 

 NOTE: A hypothetical grape orchard was chosen as the basis for the 

EEC calculations because the product label specifies that the 

product is intended for use on grapes. 

 5. The pheromone a.i. volatilizes and dissipates rapidly in the atmosphere 

rapidly after emission from the microbead. 

 6. The pheromone a.i. readily biodegrades in the environment. 

 7. Lavandulyl senecioate is already present in the environment wherever 

Vine Mealy Bugs are present and mating, and humans are already 

exposed on a repeated basis; 

 8. Significant direct exposure to the active ingredient is highly unlikely. 

The active ingredient is encapsulated in a microbead, from which it is 

emitted slowly, over a period of 21 days. The microbead is a polymer 

cleared for food use under 40 CFR 180.960; 

 9. The mode of action of the pheromone a.i. is non-toxic. It is a mating 

pheromone of the Vine Mealy Bug. 

 Conclusions: Repeated oral and dermal exposure is highly unlikely, based on 

the extremely low application rate (10 g a.i. per acre per application), 

low emission rate (480 mg a.i. per acre per day), rapid volatilization 

after emission from the microbeads and rapid biodegradation. Residues 

on edible commodities are highly unlikely. In addition, the calculated 

atmospheric EEC (0.0000486 mg/L, or 0.0000486 ppm) is over 

100000x less than the non-definitive acute inhalation endpoint of >5.21 

mg/L.

Classification: ACCEPTABLE

 B. Prenatal Development – Developmental Toxicity (OCSPP 870.3700; 

MRID 49413204, pp. 46-48): In lieu of a Guideline study, the applicant 

submitted individual scientific rationales in support of the data 
Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

requirements. The rationale is essentially the same as discussed above for 

the 90-day subchronic toxicity data requirements. 

Conclusions: Based on the low application rate (10 g a.i. per acre per 

application), low mission rate (480 mg a.i. per acre per day), extremely 

low atmospheric EEC (0.0000486 mg/L, or 0.0000486 ppm), rapid 

volatilization after emission from the microbeads and rapid 

biodegradation, it is highly unlikely that there will be significant exposure 

to female humans following application of the product according to 

approved EPA-label rates. 

Classification: ACCEPTABLE

III. EP: Tier I Human Health Assessment (MRIDs 49480301 & 49413204): 

Acute toxicity studies were not submitted for the end-use product (CheckMate® 

VMB-F; EPA File Symbol No. 56336-AT). In lieu of studies, the applicant 

submitted rationales based on information used to support currently EPAregistered, sprayable, end-use products, registered by the same applicant, 

including: 

Checkmate® CM-F (EPA Reg. No. 56336-37; cites MRID 45375701 & 

45428301) 

Checkmate® WPCM-F (EPA Reg. No. 56336-40; cites 45858901) 

Checkmate® PTB-F (EPA Reg. No. 56336-41; cites 45891701) 

Checkmate® BAW-F (EPA Reg. No. 56336-43; cites 46019001) 

All of the aforementioned end-use products, including the subject product 

(CheckMate® VMB-F; EPA File Symbol No. 56336-AT) are comprised of slow 

release microbeads that contain the pheromone active ingredient. The microbeads 

containing the Vine Mealy Bug pheromone (Lavandulyl Senecioate) active 

ingredient are composed of the same that is used in the 

currently EPA-registered, CheckMate® flowable end-use products. The MRID 

(45428301) cited for Checkmate® CM-F (EPA Reg. No. 56336-37) contains a 

complete human health toxicology discussion relating to the acute toxicity of 

sprayable, pheromone-containing, microbead products formulated by Suterra. 

In addition, the registrant cites a BPB review of a substantially similar product 

[CheckMate® CM-F (EPA Reg. No. 56336-36) see Memorandum from R. S. 

Jones, through F. Toghrol, to T. Peterson, dated 03/06/2002]. The Agency 

concluded that the information contained in the aforementioned memorandum 

was Acceptable to support the human health and non-target organism data 

requirements for CheckMate® CM-F. For a complete discussion of the rationales 

for each end-use product data requirements, see MRID 49480301, Confidential 

Appendix. 

*Inert ingredient information may be entitled to confidential treatment*
Vine Mealy Bug Pheromone DP Numbers: 424659

PC Codes: 036005 EPA Reg. No.: 56336-AT

Review Type: Product Chemistry, Tier I Tox & Non-target Organism Waivers

Conclusion: The information submitted in support of currently EPA-registered, 

CheckMate® sprayable, pheromone-containing, end-use products is Acceptable 

for use in bridging to support the acute toxicity and non-target organism data 

requirements for CheckMate® VMB-F (EPA File Symbol No. 56336-AT). No 

additional information is required. 

Classification: ACCEPTABLE

REFERENCES

Memorandum from R. S. Jones, through F. Toghrol, to T. Peterson. Science 

Review in Support of the Registration of CheckMate® CM-F (056336-GT) 

Containing 14.40% E, E-8, 10-Dodecadien-1-ol (Chemical No. 129028) As Its 

Active Ingredient. Review of Product Chemistry Studies and Waiver Requests 

for Acute Toxicity and Non-Target Organism Studies. DP Barcode D276198; 

Case No. 070281; Submission No. S599411; MRIDs 453757-01 to -04; and 

454283-01. Dated March 6, 2002. 

OECD, 2002. Guidance for Registration Requirements for Pheromones and Other 

Semiochemicals Used for Arthropod Pest Control. OECD Series on Pesticides, 

Number 12. ENV/JM/MOMO(2001)12 

cc: C. Walsh, R.S. Jones, BPPD Subject File/IHAD

R. S. Jones, Ph.D., Sr. Scientist, Acting Assoc. Branch Chief, FT, OPY: 03/16/2015
Page 10 *Manufacturing process information may be entitled to confidential treatment*