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DP 'BARCODE: 

CASE : 

SUBMISSION: 

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Dl88115 

016380 DATA E5435262 BEAN SHEET Page 1 of 1 

* * * CASE/SUBMISSION INFORMATION * * * 

CASE TYPE: REGISTRATION ACTION: 100 NC-FOOD/FEED USE 

CHEMICALS: 097805 Deltamethrin 2.8600% 

ID#: 034147-1 DECIS INSECTICIDE 

COMPANY : 0 3 4 14 7 ROUSSEL UCLAF I 

PRODUCT MANAGER: 13 GEORGE LAROCCA 703-305-6100 ROOM: CM2 204 

PM TEAM REVIEWER: JOHN HEBERT 703-30,5-5419 ROOM: CM2 202 

RECEIVED DATE: 02/12/93 DUE OUT DATE: 08/21/93 

* * * DATA PACKAGE INFORMATION * * * 

DP BARCODE: 188115 EXPEDITE: N DATE SENT: 02/12/93 DATE RET.: / / 

CHEMICAL: 097805 Deltamethrin 

DP TYPE: 001 Submission Related Data Package 

ADMIN DUE DATE: 06/12/93 CSF: N 1 LABEL: N 

ASSIGNED TO @PC DATE OUT 

DIV : EFED 

BRAN: EEB 

/ / 

85 4(/ (3 / / 

SECT: / / / DUE- - 3, /IT j54- 

REVR : / / / / zc, f=& J 77-57 5 :-'~:y& ~-+,i C-, 

CONTR : / / / / --.- - . - 

* * * DATA REVIEW INSTRUCTIONS * * * 

EFED HAS PASSED THE SCREENING OF NEW CHEMICAL. THE 

DATA/CHEMICAL SHOULD BE PLACED IN FULL REVIEW. DATA HAS 

BEEN IN YOUR SECTION SINCE 9-29-92 WHEN PACKAGE WAS 

SUBMITTED FOR SCREENING. 

* * * ADDITIONAL DATA PACKAGES FOR THIS SUBMISSION * * * 

DP BC BRANCH/SECTION IIATE-OUT DUE BACK INS CSF LABEL 

188114 TSCB 02/12/93 06/12/93 Y N N 

188116 EFGB 02/12/93 06/12/93 J! Y Y 

188172 TB-1 02/12/93 06/12/93 Y N N 

Text Searchable Document
Chemical : Deltame*h 

100.0 Submission Purpose and Label Information: , 

100.1 Submission Purpose: 

\ 

Hoescht Roussel has requested full registration of 

deltamethrin, active ingredient of Decis 0.2 EC Insecticide 

for use on field cotton nationwide. Decis insecticide has 

been used on cotton under experimental use permits since 

1991. This use was on small plots(50 acres) and limited to 

approximately 1000 acres total in 14 states. , Cotton 

production in the U.S. is primarily concentrated in the 

south central and southwestern states. Total grown 

nationwide exceeds 9,826,000 acres (based on 1987 Ag. 

Census). Major cotton growth states listed in the census 

include Ala., Ariz., Ark., Ca., Fla., Ga., Idaho, Ill., 

Ind., Iowa, Ls., ~iss., Ms., N.M., N.\C., Okla., S.C., Tenn 

and Texas. 

L / 

100.2 Fo,rmulation Information 

Active Ingredient: (IR, 3~) -392,2-dimethylcyclopropanecarboxzylic acid (s)-a-cyano-3-phenoybenzyl ester 

................................................2.86%* 

Inert Ingredients: ......................... 97.14% I 

Total 100% 

, *Equivalent to 0.2 lb active ingredient per U.S. gallon. 

100.3 Application Methods:Decis 0.2 EC Insecticide 

1 

) 

Application would be made on an as needed basis depending on 

insect populations and weather conditions. 

General Information: Dilute Decis Insecticide in water or 

at least once-refined crop oil according to the directions 

and use as a foliar spray at rates listed below. Uniform 

coverage is essential. Begin applications when economic 

infestations occur based on local information and repeat as 

needed (observe the restrictions in Note 2). Do not enter 

the treated field before spray is dried. 

1 

- - __;"l"-l"-^- - """ ~ b wa,z*>=%, = # L " -- - 
Application Rates: 0.013 to 0.020 lbs ai/A (8.32 to 12.8 F1. 

oz/A) 

1, Do not apply more than ten (10) applications (0.2 pound 

of active ingredient per acre or 128 fluid ounces/A) 

per growing season. 

2. Do not apply through irrigation system, 

3. Do not graze treated forage. i 

100.4 Target Organisms: 

Boll weevil, cotton bollworm, 

leafperforator, fall armyworm 

looper, tobacco budworm. 

cotton fleahopper, cotton 

pink bollworm, soybean 

100.5 Precautionary Labeling: 

"This pesticide is toxic to fish and aquatic invertebrates. 

Do not apply directly to water,'to areas where surface water 

is present, or to intertidal areas below the mean high 

water mark. Drift and runoff may be hazardous to aquatic 

organisms in areas near the application site. Do not 

contaminate water when disposing of equipment washwaters or 

rinsate. This pesticide is highly toxic to bees exposedfto 

direct treatment. Do not apply it or allow it to drift to 

crops or weeds on which bees are actively foraging. 

Notify State and/or Federal authorities and Hoechst-Roussel' 

Agri-Vet company immediately if you observe any adverse. 

environmental effects due to the use of ~ecis Insecticide. 

Notice: '1t is a federal offense to use any pesticide in 

manner that results in the death of a member of an 

endangered species. 

,Spray Drift Precautions for Cotton Use 

1. All aerial and ground application equipment must be 

properly maintained and calibrated using appropriate 

carriers. 

2. Do not make aerial or ground applications during 

temperature inversions. 

3, Make aerial or ground applications when the wind 

velocity favors on-target product deposition 

(approximately 3 to 10 mph). Do not apply when wind 

velocity exceeds 15 mph. 

4, Do not apply by ground within 25 feet, or by air within 

75 feet of lakes; reservoirs; rivers, permanent 

2 

- -- - - -. - - - - Q 
\ streams, marshes or natural ponds, -estuaries and 

commercial fish farm ponds. 

5. For aerial applications, the spray boom must be mounted 

on the aircraft so as to minimize drift caused by 

wingtip' or rotor vortices. Boom length must not exceed 

75% of wing span or rotor diameters. 

6. Do not make more than a total of 10 synthetic 

pyrethroid applications (of one product or combination 

of products) to a cotton crop in one growing season. 

Synthetic pyrethroid products include Ambusho, Ammoo, 

Asanao, XL, Baythroido, Captureo, ~ymbush~, Fury0, 

Karateo, ounce^, and Scouto. 

101.0 Hazard Assessment:In view of the large acreage involved 

cotton production areas are expected to oEfer exposure 

potential to a most types of habitats found in lowland areas 

of the niajor cotton producing states. Recently the Agency 

has discussed possible mitigation measures for pyrethroids 

presently under conditional registration for use on cotton. 

101.1 Discussion: 

Environmental Fate Characteristics: 

~nvironmental fate data for deltamethrin is not complete at 

this time. The parent compound, Tralomethrin, has been 

studied with some detail in regard to environmental fate. 

A limited picture of deltamethrin's behavior in the 

environment is possible by reviewing the monitoring for 

deltamethrin residues conducted in tralomethrin field 

studies. As an application interval is not specified a 2 

day interval with 10 applications could be construed as a . reasonable maximum application scenario. It is likely that 

a larger interval would be employed in normal use patterns 

unless harmful insect pressure was abnormally high. 

Based on 0.019 lb ai/acre maximum applicatidn rate(sing1e I application) 

~ 

- PPM Shortarass ~ons~rasses Leaves Seed vods Fruit / 

Typical 2.37 1.74 0.66 0.057 0.03 

maximum 4.56 2.09 2.38' 0.23 0.13 

! 

Maximum exposure (no degradation) 

10 applica. 45.6 20.9 23.80 2.3 1.3 

3 

\ 
Toxicity Characteristics: 

I 

Avian Toxicity Data: 

The Agency has reviewed 5 studies with avian species and 

deltamethrin. These studies are summarized below. 

Avian Dietary- ~allard ACC 264510 Core/Fulfilled 

ACC 262456 

Avian Reproduction 421148-08 Core/Fulf illed 

Bobwhite quail 

Avian Reproduction 421148-09 Core/Fulf illed 

Mallard duck 

Data Requirement 

Avian Oral-Bobwhite quail 

Avian Dietary- Bobwhite 

Avian ~okicit~: Toxicity to avian wildlife is low with the 

LDS0 >2250 mg/kg for bobwhite quail, and dietary LC,, of 

>10000 ppm and >4620 ppm for bobwhite quail and mallard 

duck, respectively. At the low rates of application residue 

levels will not approach levels of concern for birds, 

despite the multiple applications proposed. Maximum residue 

levels would be 45 ppm with 10 applications and no 

degradation. Recently submitted avian reproduction studies 

no effect levels of up to 450 ppm for bobwhite quail and 

mallard duck(highest doses tested). This residue level is 

not expected to be exceeded at the proposed application 

rate. 

MRID # 

ACC 262456 

ACC 264510 

ACC 262456 

Category/Status 

~ore/~ulfilled 

Core/Fulfilled 
Aquatic organisms Toxicity: Deltamethrin demonstrates very 

high toxicity to all aquatic species tested to date. The A 

summary of acceptable aquatic toxicity data submitted to 

date is listed below. Unless indicated(*), these studies are 

considered acceptable to support this registration 

Deltamethrin: Aquatic Organism Toxicity Data 

Bluegill/ ACC 262456 99.3 

I 

Daphnia magna/ACC 262456 199.3 

I 

I Daphnia magna/41651014 1 2.54 TEP I 

*Daphnia magna/42114813 Tech. 

Fathead minnow - Early I 

I 

Fathead minnow-Full Life Tech 

Cycle/427786801 

I Sheepshead minnow/42114815 I 

Sheepshead minnow/42114811 25.4% 

TEP 

I ~~sid/42114810 I Tech. 

I 

Mysid/42114812 I TEP 

I 

1 1 Eastern oyster/41651016 199.2% 

~ 

I' 1 Eastern oyster/41651017 I TEP 

I 

I I I 

~ * The Invertebrate Full Life Cycle 

acceptable due to the incomplete s. 

Result II 

LC50 = 1.4 PPB II 

LC50 = 0.91 PPB 

LC50 = 0.36 PPB 

LC50 = 0.25 PPB II 

EC50 = 3.5 PPB II 

>.0041<0.0089 PPB -1 

36 Day MATC 

Chronic MATC 

>0.017<0.035 PPB 

LC50 = 0.0037 PPB 

LC50 = 0.0017 PPB 

EC50(shell 

deposition) =12 

PPB 1 

EC50 (shell dep. ) 

= 17.9 PPB I 

Study was not fully 

tbmission of raw data.. I 

I Non target aquatic organisms are highly sensitive to very 

low concentrations of deltamethrin. Using a conservative 5% 

drift scenario from'a 0.02 lb ai/Acre aerial application,the 

~ exp'ected EEC levels from direct drift to a shallow marsh - 

~ area(6" deep-1 acre size) could exceed 0.73 PPB. With rapid 
dissipation to a 6 foot depth a direct 5% drift to a one 

acre waterbody could result in -an instantaneous residue 

level of 0.061 PPB. The estimated runoff from a ten acre 

field to a 6 foot 1 acre body of water could reach'0.12 PPB 

with a 1% runoff of the applied chemical(sing1e 

application). Due to high adsorption characteristics, much 

of material may reach habitats with soil runoff. If bound 

to .sediments deltamethrin may prove less bioavailable to 

midwater organisms, but more bioavailable to benthic 

organisms. 

These EEC levels are well above acute 50% mortality levels 

for daphnia and mysids. They also exceed chronic effect 

levels of concern far fish.and invertebrate species 

(EEC=LOEC). They ,are above or equivalent to levels of 

concern(lll0 LC50) for all species tested to date with 

exception of the eastern oyster shell deposition effect 

levels. It is not known if larval stages of shellfish would 

be more sensitive than the spat. 

Nontarget Insect Toxicity: 

Studies with honey bees indicate high acute contact 

toxicity(MR1D 42114815). The acute contact LD50 for the 

honey bee was determined to be 1.5 ug/bee. In a field 

application studies(MR1D 42773902 and 42475905) the reported 

LD,,,was 0.067 ug/bee and the RTZ5 for deltamethrin was 

determined to be less than 8 hours but greater than 2 hours 

for honeybees exposed to treated foliage. This indicates 

the the insecticide should be applied no less than 8 hours 

prior to expected foraging of honeybees in treated fields to 

reduce concerns for adverse effects from treated foliage. 

This data does not address the toxicity of deltamethrin to I other species of beneficial insects, but high toxicity is 

expected based on the honeybee studies and the efficacy of 

the product toward numerous target species. 

Nontarget Plant Toxicity 

EEB presently has no data to indicate any possible 

phytotoxic effects of this compound. Due to it's use as an 

insecticide no plant testing requirements have been 

requested to date. However the company's disclaimer does 

mention that crop damage resulting from misuse will notibe , the responsibility of Hoechst-Roussel. 

During microcosm testing(MR1D 42114816) wikh tralomethrin 

and deltamethrin a substantial percentage of total residues 

of deltamethrin were measured in plant tissues indicating 

the propensity of ,the insecticide to bioconcentrate, in plant 

matter. 
/ 

100.4 Endangered Species concerns: 

EEB does not believe that the proposed use will offer hazard 

to listed terrestrial avian or mammalian species as chronic 

and acute toxicity values fall well below predicted EEC 

levels. 

Though the Agency has not requested any recent consultation 

with the Dept. of Interior regarding Deltamethrin use on 

cotton, the Agency did receive a 1985 response from The U.S. 

Fish and Wildlife regarding use olf Tralomethrin on cotton. 

At the time the number of listed species was lower and 

therefore may not reflect the number of species which might 

be affected by a 1994 registration of a pyrethroid on 

cotton. In the response the Acting Associate Director made 

the conclusion that "the proposed registration of 

Tralomethrin for use on cotton is likely to jeopardize the 

continued existence and adversely modify associated 

designated critical habitats of all listed fishes and 

amphibians which occur in counties where cottrn is grown." I 

I The buffer zones of 25-75 feet have not been shown by the 

I industry's Spraydrift Task Force to be adequate protection 

from possible contamination to unlisted aquatic species. 

i Thus, the same conclusion regarding listed aquatic species 

I will apply when they are located adjacent to cotton 

production sites. In order to avoid violations of the 1 

~i Endangered Species Act through contamination of critical I aquatic habitats or endangered terrestrial insect habitats, 

* it is recommended that thorough research into locations of 

any potentially exposed critical habitat sites and their t 

, proximity to the proposed application sites be conducted by 

i the responsible parties involved with any cotton use of 

/F deltamethrin. EEB cannot dismiss the possibility of 

I, exposure of endangered aquatic species from the proposed 

label precautions. The table provided on the following 

pages lists endangered fish, amphibian, aquatic i. reptile(excepting sea turtles), and aquatic invertebrate i species for major cotton production states in the U.S. 
Listed Freshwater Aquatic species - Major Cotton Crop States 

As of October 1992 

I species 1 8tates(counties) 

Cahaba shiner ( Alabama(Bibb,Shelby) I I N 

, Gulf sturgeon 

'~labama red belly turtle 

ALabama(Balduin), Florida(Escambia,Okaloosa, Santa Rosa,Wal ton, Jackson), 

Georgia(Decatur,Seminole), and Mississippi(Hinds, Rankin) 

Alabama(Ba1duin) 

Blue shiner 

~lattened musk turtle 

Red Hills salamander 

Pygmy sculpin 

Rough pigtoe pearly mussel Alabama(Colbert, LauderdaPe, Madison, Marshall, Morgan) I II 

Alabama(Calhoun, Cherokee) 

Alabama(Fayette, Marshall, Tuscaloosa) 

Alabama(Conecuh, Covington, Monroe) 

Alabama(Ca1houn) 

Upland Combshell clam 

Tulotoma snail 

Southern acornshell 

Pink mucket pearly mussel - 

Dark pigtoe mussel Alabama(Blount, Tuscaloosa) 

White uarty back pearly mussel ALabama(Colbert, Lauderdale) 

Ovate clubshell clam .ALabama(Dallas, Lamar, Macon, Perry, Pickens, Tuscaloosa), and 

Georgia(Bartow) 

Southern clubshell Alabama(Dallas, L,amar,Macon,Perry,Shelby, Tuscaloosa) 

Penitent mussel Alabama(Lamar) and Mississippi(ltamba, Loundes, Monroe) 

Triangular kidneyshell Alabama(B1ount) and GeorgiaCBartou) 

Stirrup shell Alabama(Pickens) \ 

Alabama cavefish, Alabama(Colbert, Lauderdale) 

Gold1 ine Darter ALabama(Bibb, Shelby) 

Slackuater darter Alabama(Lauderdale, Limestone) and Tennessee(Lawrence) 

Orange footed pearly msel Alabama(Colbert, Lauderdale, Madison, Marshall, Morgan) 

Alabama mocassin shell mussel ~eorgia(~artou) 

Boulder darter Alabama(Limestone) 

Snaildarter . Alabama(Limestone, Marshall, Morgan) and TenneseeCLincoln) 

Tan riffle shell clam Alabama(Madi son) 

Alabama cave shrinp Alabama(Madison) 

Finel ined pocketbook mussel Alabama(Bibb, ~il las, Elmore) 

Judge Tait's mussel Alabama(Pickens) and ~ississippi(ltauaba, Loundes, Monroe) 

ALabama(Bibb, Shelby) and Georgia(Barstou) 

Alabama(Calhoun, Shelby) 

AlabamaCCherokee) 

Alabama(Colbert, Lauderdale, Limestone, Madison, Marshall, Morgan), 

Missouri(Butler), Arkansas(Clay, Desha, Woodruf) and Kentucky(Canpbel1) 
ale, Shelby, Tipton) 

Fat pocketbook mussel 
-1

* 

Cape Fear shiner 

Roanoke Logperch 

Fountain darter , 

Dwarf wedge mussel 

Pecos gambusia 

Pecos bluntrose shiner 

Boulder darter 

Boirduing pearly mussel 

Cracking pearly mussel 

Cunberland monkeyface mussel 

Fine rayed pigtoe pearly mussel 

Shiny pigtoe pearly mussel 

Concho uater snake 

Houston toad , 

Prairie mole cricket 

Kretsmarr cove mold beetle 

Tooth cave ground beetle 

Bee creek harvestman spider 

Tooth cave pseudo scorpion 

Tooth cave spider 

I 

North Carolina(Harnett) 

Virginia(Greensvil1e) 

Texas(Calduell1 

North Carolina(Johnston, Nash, Wilson) 

New Mexico(Chaves, Eddy) and Texas(Reeves) 

New Mexico(Chaves, Eddy) 

Tennessee(Linco1n) 

Tennessee(Linc0ln) 

Tennessee(Linco1n) 

Tennessee(Limo1n) 

Tennessee(Linc0ln) 

'lennessee(Linco1n) 

Texas(Brown, Coleman, Concho, Runnels, Tom Green) 

Texas(Burleson, Fs. Bend, Lavaca, Leon, Milan1 

Oklahoma 

TexasCTravis, Williamson) 

Texas(Travis, Ui 1 Liamson) 

Texas(Travis, Ui 1 1 iamson) 

Texas(Travis, Ui 1 Liamson) 

Texas(Travis, Williamson) 

101.2 Adequacy of Data: Acute data submitted to date to support 

registration of ~eltamethrin is adequate for purposes of this 

proposed registration. Fish and invertebrate full life cycle 

testing has indicated that adverse effects to reproductive 

success of these groups may occur at concentrations ranging from 

0.0041 ug/L-to 0.0089 ug/L for invertebrates and 0.017 to 0.035 

ug/L for fish species exposed to deltamethrin residues. To date ' 

the Branch has not reviewed data which would eliminate concern 

that these levels will be reached in the environment from labeled 

rates and use patterns. A summary of all data submitted and 

reviewed to date is attached to this review., 

101.3 Adequacy of Labeling: The label presented with this 

~ - registration proposal does not include adequate precautionary I . measures to prevent or runoff drift to adjacent aquatic or 

~ \ critical terrestrial habitats. The label should incorporate I 

I mitigatory precautions recently agreed to at recent Agency I meetings with The Cotton Council. These precautions include the 

following: 

I 

10 

--- ----- -- - - -- "> -- - 
.. ** 

I 

1. A ten foot vegetative buffer zone near non-target habitat., 

2. A -150 foot buffer between aquatic habitats and aerially 

treated fields(Non ULV applications). 

. 3. In the case of ULV spray applications a 450 foot buffer zone 

is suggested. 

C 

4. Restriction of boom length to 70% or the limit of efficay, 4 

5. Spray nozzle pressure of 45 PSI or less. 

102.0 Conclusions: EEB has completed it's risk assessment for 

deltamethrin use on cotton. Based on the available information 

EEB concludes that the proposed use poses serious risk to exposed 

aquatic organisms or nontarget beneficial insects. Many cotton 

production sites are expected to be located adjacent to some type 

of aquatic habitat. Without further precautiohs against drift 

contamination (such as application only when wind direction is 

away from nontarget aquatic habitats), EEB cannot dismiss the 

possibilit,~ of hazard to aquatic species located in waters 

adjacent to application sites. The effects of drift to 

populations of pollinating beneficial insects may also be extreme 

unless applications are made at times of low activity (foraging) 

for these species. Endangered species conce,rns must be addressed 

on a site by site basis in relation to the ecological risk factor 

involved with that particular site location(ie. proximity to 

critical habitat). 

I Reviewed by: Brian Montague, Fisheries Biologist 

I Ecological Effects Branch , Environmental Fate and Effects Division 

I 

I 

I 

11 

I Approved by: Les Touart, Supervisory Biologist 

~ Ecological Effects Branch 

Environmental Fate and Effects Division 

I Approved by: I ;I 

(H7507C) 

I 1 
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4 

I ~eltamethrin Data 

Test Requirement 

71-1 Avian Oral 

71-1 Avian Oral TEP 

, 71-2 Avian Dietary Gamebird 

71-2 Avian Dietary ~amebird TEP 

71-2 Avian Dietary Waterfowl 

71-2 Avian Dietary Waterfowl TEP 

71-3 Wild Mammal Toxicity 

71-4 Avian Reproduction Gamebird 

71-4 Avian Reproduction Waterfowl 

71-5 Terrestrial Field Study 

72-1 Warmwater Fish Acute Tox 

72-1 Warmwater Fish Acute Tox TEP 

72-1 Coldwater Fish Acute Tox 

72-1 Coldwater Fish Acute Tox TEP 

72-2 Freshwater Invertebrate Tox 

72-2 FW Invertebrate Tox TEP 

72-3 Estuarine/Marine Fish Acute 

I 

1 

1 

1 

~ 

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II I 

i 

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I f 

Requirement 

submission 

262456 

264510/262456 

264510/262456 

- 

421148-08 

421148-09 

262456 

41651012 

262456 

41651013 

262456 

41651014 

41651015 

72-3 Estuar/Marine Shrimp Acute 

72-3 Estuar/Marine Shrimp TEP 

72-3 Estuar/Marine Mollusc Acute 

72-3 Estuar/Marine Mollusc TEP 

72-4 Early Life Stage Fish 

72-4 Life Cycle Aquatic Inverteb. 

72-5 Full Life Cycle Fish 

72-7 Aquatic Field StudyMicrocosm 

122-1 Tier I Terrestrial Plants 

, 

122-2 Tier I Aquatic Plants , 

123-1 Tier I1 Terrrestrial Plants 

123-1 Tier I1 g qua tic Plants 

141-1 Nontarget Insect Acute 

141-2 Nontarget Insect ~oliar 

I 

I 

I 

Status 

Status 

Fulfilled 

Not required 

Fulfilled 

Not required 

Fulfilled 

Not required 

Not required 

~ulf illed 

Fulfilled 

Not required 

Fulfilled 

Fulfilled 

Fulfilled 

~ulf illed 

~ulfilled 

Fulfilled 

~ulf illed 

Fulfilled 

II 

421148-10 

421148-12 

41651016 

41651017 

421148-14 

421148-13 

427868021 

41148016 

421148-15 

424759-05 111 42475905 

Fulfilled 

~ulfilled 

~ulf illed 

Fulfilled 

~ulf illed 

Incomplete ;,x"; 

Fulfilled 

Not required 

Not required 

Not required 

Not required 

Not required 

~ulf illed 

Fulfilled