.:)~\'1E.D S1"-41l 

i ~6'. 

0 ~ w \ ~ ~~ ~ '4(. PRO"tf-~ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

AUG 1 8 2014 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

TO: 

BEAD Chemical Profile (BCP) for Registration Review: Fluazifop-P-butyl 

(122809) . 

Biological 

Bill Phillips, 

Analysis 

Agronomist 

Brnncf"1!'N 

~ ~ r 

Sepehr Haddad, Environmental Protection Specialist 

Science Information and Analysis Branch 

Economic 

Stephen Smearman, 

Analysis Branch 

Economist 

r-r 

J.,-, ~ ~~ 

Biological and Economic Analysis Division (7503P) 

Amet Jones, Chief 

Biological Analysis Branc 

Diann 

Science 

Sims, 

Information 

Chief ~ and Analysis Branch ~ .. 

Timothy Kiely, Chief ~ ~ 

Economic Analysis Branch 

Biological and Economic Anal~s Division (75 ) 

Matthew Manupella, Chemical Review Manager 

Pesticide Re-evaluation Division (7508P) 

Peer Review Panel date: May 21, 2014 
SUMMARY 

Fluazifop-P-butyl is an herbicide and was first registered in the United S~ates in December 1992 

(USEPA, 2014). A Tolerance Reassessment Progress and Risk Management Decision (TRED) 

was completed for fluazifop-P-butyl in 2005. 

Based on private market usage data from 1998-2012, usage averaged approximately 223,000 

pounds active ingredient ( a.i.) applied annually on approximately 1. 73 million acres treated. The 

average a.i. rate over this time period was 0.13 pounds a.i./acre. In terms of pounds applied and 

acres treated there has been a sharp decline in use from 1998 through 2005 with use remaining 

fairly steady from 2005 through 2012. 

Fluazifop-P-butyl is used to control annual and perennial grass weeds in numerous crops. 

Between the years of2008 and 2012 this herbicide was applied primarily postemergence in 

soybean to control volunteer com. Grass herbicides like fluazifop-P-butyl can be a tool in the 

control of herbicide resistant volunteer com in broadleaf crops such as soybeans. However, the 

use of this herbicide in soybeans has declined since 1998 and as such its use in soybeans has 

fallen to approximately one percent of the crop. This low use in soybeans may be due to many 

factors including the availability of cost-effective alternative herbicides. 

While most of this herbicide is used in soybean crops, it is applied in a large percentage of the 

carrot crop. Because approximately 25 percent of the carrot crop receives treatments with this 

herbicide, it seems that fluazifop-P-butyl is important in controlling grass weeds in carrot 

production. 

INTRODUCTION 

FIFRA Section 3(g) mandates that EPA periodically review 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 

consider the risks and benefits of any use ofthe pesticide. 

The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an 

overview of the pest management roles and quantitative usage information for fluazifop-P-butyl. 

The BCP includes summaries of previous BEAD products and available public and/or private 

use and usage data for fluazifop-P-butyl to describe the role of this chemical in pest 

management. Additional information on use is available in the fluazifop LUIS Label Data 

Report and Screening Level Usage Analysis (SLUA). Information provided in this BCP may be 

used by stakeholders (e.g., users and registrants), OPP risk and benefit assessors, OPP risk 

managers, and the general public during the Registration Review process of this pesticide. 

Page2 
USE SITES 

Agricultural Use Sites 

Fluazifop-P-butyl registered agricultural use sites include: almonds, apples, asparagus, carrots, 

cherries, com, cotton, Christmas tree plantings, dry beans/peas, garlic, grapes, non-bearing 

orchards, onions, oranges, peaches, peanuts, pecans, peppers, pistachios, prunes, soybeans, 

strawberries, and walnuts. 

Non-Agricultural Use Sites 

Registered non-agricultural use sites of fluazifop-P-butyl include: non-agricultural outdoor 

buildings, building foundations, curbs, driveways, fencerows, non-agricultural areas (wildlife 

refuge), non-crop areas, ornamentals (lawns, flowering shrubs, flowering plants, gardens, ground 

covers, plants, trees, turf, and woody shrubs), patios, pathways, rights-of-way, sidewalks, and 

storage yards) 

FORMULATIONS AND APPLICATION METHODS 

Fluazifop-P-butyl is formulated as an emulsifiable concentrate and applied using ground or aerial 

equipment. It may be applied preplant, at-planting and/or postemergence (to the plant). 

HISTORY OF FLUAZIFOP-P-BUTYL and BEAD PRODUCTS 

Fluazifop-P-butyl was first registered in 1992. A Tolerance Reassessment Progress and Risk 

Management Decision (TRED) was completed for fluazifop-P-butyl in 2005. 

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

assessments specifically for fluazifop and fluazifop-P-butyl did not find any records of prior 

BEAD assessments specifically for this chemical in the last 1 0 years. 

A Screening Level Usage Analysis (SLUA) was prepared by BEAD for this chemical in 2014 

that provides the percent crop treated for 27 crops. Based on the SLUA, there is one agricultural 

site (soybeans) with the greatest number of pounds used (average 100,000 lbs), followed by 

carrots (average 4,000 lbs) and cotton and onions (average 3,000 lbs.). The highest average 

percent crop treated according to the SLUA is for carrots at 25 percent, followed by garlic at 10 

percent. 

Emergency Exemptions- A search of BEAD's Official Records did not find any Section 18s 

requests for fluazifop and fluazifop-P-butyl 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. 

Page 3 
USAGE 

Agricultural Usage 

Based on private market usage data from 1998-2012, usage averaged approximately 223,000 

pounds active ingredient (a.i.) applied annually on approximately 1.73 million acres treated. The 

average a.i. rate over this time period was 0.13 pounds a.i./acre. Figure 1 presents fluazifop-Pbutyl usage in pounds a.i., and Figure 2 shows total area treated in acres over the 1998-2012 

timeframe (Proprietary Data, 1998-2012). Figure 1 shows that in terms of pounds applied and 

acres treated there has been a sharp decline in use from 1998 through 2005 with use remaining 

fairly steady from 2005 through 2012. 

FIGURE!. Fluazifop-P-Butyl Usage in Pounds Active Ingredient (1998-2012) 

800,000 

"'0 

.!!.! 

a. 

c. 

<( 

<i. 

Ill 

"'0 

c 

:::l 

0 

0.. 

0 

f'Jq, f>J"> ...r'l<;:) c~ c"' c'? ~ c~ c(o ~ cq, c"> ~<;:) ~~ Y. ~ ~ "'" --ss --ss --ss --ss --ss --ss --ss --ss --ss ~ ~ ~ 

Years 

Source: Proprietary Data, 1998-2012 

Page4 
FIGURE 2. Fluazifop-P-Butyl Total Area Treated in Acres (1998-2012) 

5000000 

Ill 

(I) 

... 

u 

<( 

.5 

"C 

(I) 

..... 

"' (I) 

... 

I-

(I) "' 

... 

<( 

Ri 

..... 

0 

I0 

!'Jco ?Jo, ~(;) ~"' ~"' ~, ...{',bo ~<, d<> ~ ~co ~o, ~(;) ~"' ~"' ~ ~ ~ ~ ~ ~ ~- .,_<J ~ .,_<J ~ ~ "'(;) "'(;) "'(;) 

Years 

Source: Proprietary Data, 1998-2012 

Table 1. Comparison of Crops in Years with the Highest Use of Fluazifop-P-Butyl- Percent 

0 _ _.. .. -.. .. .... ,_. ___ ---- .. ---- ----... 

1998-2002 2008-2012 

Average annual= 432,000 lbs/yr Average annual= 125,000 lbs/yr 

Crop %Lbs Crop %Lbs 

Soybeans 87% Soybeans 90% 

Cotton 9% Carrots 4% 

Other 4% Other 6% 

Other crol's in both time frames include garlic, oranges, l'eanuts, l'eaches, and 20 additional crol's 

Source: Proprietary Data, 1998 -2012. 

Table 1 shows that the crop with the most pounds applied during both the 1998-2002 and 2008-

2012 timeframes has been soybeans accounting for approximately 90 percent of total pounds 

applied. The average annual usage in pounds has decreased approximately 70 percent from 

432,000 lbs/year to approximately 125,000 lbs/year in the 2008-2012 timeframe. 

Page 5 
Table 2. Comparison of States with Highest Use of Fluazifop-P-Butyl- Percent of Total Lbs. 

1998-2002 2008-2012 

Average annual= 432,000 lbs/yr Average annual= 125,000 lbs/yr 

State %Lbs State %Lbs 

Iowa 25% Iowa 21% 

Illinois 13% Illinois 20% 

Minnesota 10% Minnesota 19% 

Indiana 5% Nebraska 10% 

Missouri 5% Indiana 6% 

Other* 42% Other* 24% 

*Other States in the 1998-2002 and 2008-2012 timeframes include Kentucky, Arkansas, Texas, Ohio 

and 25 additional states. ~- --- --

Source: Proprietary Data, 1998 -2012 

As shown in Table 2, Iowa, Illinois and Minnesota were the top three states with the highest use 

offlliazifop-P-butyl in both time frames accounting for approximately 50 percent of total pounds 

applied in the 1998-2002 timeframe and 60 percent of total pounds applied in the 2008-2012 

timeframe, even though total pounds applied has dropped 70 percent between the two 

timeframes. 

Application Rates 

The average a.i. rate for the top crops in terms of pounds a.i. applied was the highest for carrots 

at 0.25 lbs a.i./acre and the lowest for soybeans at 0.09 lbs a.i./acre as shown in Table 3. 

--------- ------- -- ' 

Annual Average Annual Average A vg. A.I. Rate (lbs Crop Total Acres Pounds Treated* a.i./acres) 

Soybeans 112,950 1,324,000 0.09 

Carrots 5,37Q_- 21,200 0.25 -

*Total Acres Treated sums all acres treated for a crop, including those acres that receive multiple treatments. 

Source: Proprietary Data, 2008 -2012 

There are approximately 7 5 million acres of soybeans planted in the U.S. and the data show that 

fluazifop-P-butyl is used on approximately one million ofthose acres, which is just less than two 

percent crop treated. Therefore, relatively speaking, it does not seem that many growers are 

relying on this chemical. On the other hand, there is approximately 85,000 acres of carrots 

planted, so approximately 25 percent of carrot acreage/production is relying on this herbicide, 

which seems to indicate that use in carrot production appears important to growers. 

Page 6 
Geographic Distribution ofFluazifop-P-Butyl Use 

Figure 3 provides a very broad geographical view of the average annual amount (in pounds) of 

fluazifop-P-butyl applied per 1,000 acres of crop acres grown. The calculated values presented 

in the map are not equivalent to an application rate (lb ai/A), therefore, the map may show areas 

of high use intensity that do not correspond to the states listed in Table 2 since those states are 

the states with the highest use offluazifop-P-butyl based on pounds active ingredient applied. 

As shown in the map, Illinois and Minnesota depict a high use intensity of acres treated with 

fluazifop-P-butyl. Please see Appendix I for a more detailed explanation of the information 

presented on the map. 

FIGURE 3. Annual Average Agricultural Use Intensity ofFluazifop (2008-2012). 

Pounds Active Ingredient 

per 1,000 Crop Acres Grown 

0NoData 

CJ <o.os 

CJ o.os-0.5 

. 0.5-1 

- >1 

Page 7 
Non-Agricultural Usage 

Most available non-agricultural usage data for fluazifop-P-butyl is limited and dated. There are 

two data sources for fluazifop-P-butyl non-agricultural usage. These are the publically available 

USDA's National Agricultural Statistics Service (NASS) 2006 and 2009 Nursery and 

Floriculture reports, and the proprietary Kline & Company data. In addition to NASS 2006 and 

2009 data which reported 1,000 lbs a.i. used in 2006 and 200 lbs a.i. used in 2009 for nursery, 

other reported data is available from Kline for the years 2002, 2004, 2006 for 

nursery/greenhouse, 2004, 2006 for golf courses, 2004 for landscape and turf farms, and 2004 

and 2011 for institutional turf as shown in Table 4. Total non-agricultural usage between 2004 

and 2006 appears to have increased for golf courses, and institutional turf, but decreased for 

nursery/greenhouse; however, more recent data (post-2006) are not available to determine if this 

trend has continued since only one category of non-agricultural usage (institutional turf) was . 

available for 2011. 

--- --------- - --- -- - - -~-CI ------ -- -~--- 2-2011) 

Site 2002 2004 2006 2011 

Golf Courses NIA 25 2500 N/A 

Institutional Turf N/A 620 N/A 7340 

Landscape NIA 2700 N/A N/A 

Nursery/Greenhouse 40 3120 240 N/A 

Turf Farms N/A 10 N/A NIA -

N/A= Not Available 

Source: Proprietary Data 2002-2011 

BIOLOGICAL ASPECTS RELEVANT TO FLUAZIFOP-P-BUTYL 

Fluazifop-P-butyl is a preplant, at-planting and/or postemergence herbicide that is used to control 

annual and perennial grass weeds in numerous crops. This herbicide is in the Weed Science 

Society of America group one and works by inhibiting the production of fatty acids through the 

mechanism of action of inhibiting the enzyme acetyl-CoA carboxylase (ACCace) (Senseman 

2007). The "-P-" designation in the active ingredient indicates that this is the isolated "R" 

isomer, or the active fraction of the active ingredient. 

ROLE OF FLUAZIFOP-P-BUTYL IN PEST MANAGEMENT 

Between the years of2008 and 2012, the largest amount offluazifop-P-butyl was applied 

primarily in soybean to control volunteer com, based on both the total area treated and the total 

pounds applied (Proprietary Data 2012). As herbicide resistant crops have become the mainstay 

of crop production, volunteer com has become a weed that is more difficult to control than in the 

past. These com plants are currently being developed to be resistant to multiple herbicides some 

of which may have otherwise been used to control volunteer com. Grass herbicides like 

fluazifop-P-butyl can be a tool with which other herbicides can be rotated to control herbicide 

resistant com in broadleaf crops such as soybeans. However, the use of this herbicide in 

soybeans has declined since 1998 and as such its use has fallen to approximately one percent of 

Page 8 
the total crop. This low use in soybeans may be due to many factors including the availability of 

cost-effective alternative herbicides. 

While most of the fluazifop-P-butyl is used in soybean crops, it is applied in a large percentage 

of carrots. Since carrots are a crop that is sensitive to competition from weeds it is important that 

weeds are controlled while they are still at an early growth stage (Davis et al., 1999). It is for 

this reason that this herbicide is applied early postemergence in this crop. Because 

approximately 25 percent of the carrot crop receives treatments with this herbicide, it seems that 

fluazifop-P-butyl is an important tool in controlling grass weeds in carrot production. 

DATA NEEDS 

The Agency currently does not have complete information for fluazifop-P-butyl. Obtaining the 

following information may improve future assessments conducted by the Agency related to the 

use and importance of this herbicide. 

Non Agricultural Use 

Except for recent usage data on consumer lawns in 2011, BEAD does not have recent 

(post-2006) data on non-agricultural usage for golf courses, nursery/greenhouse and turf 

farms. Usage data such as pounds a.i. applied and application rates would be useful if 

available. 

Agricultural Use 

It would be helpful to have more information on why growers feel this herbicide is 

important to carrot and garlic production. 

REFERENCES 

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

Division, Office of Pesticide Programs, US Environmental Protection Agency. 2014 

Davis, M., E. Sorensen, and J. Nunez. 1999. Crop Profile for Carrots in United States. USDA 

Center for Integrated Pest Management. Accessed At: 

http://www.ipmcenters.org/cropprofiles/docs/uscarrots.pdf 

Proprietary Data. 2002-2011. (non-agricultural usage data) 

Proprietary Data. 1998-2012. (pesticide agricultural usage data) 

Page 9 
Senseman, S.A. (2007), Herbicide Harid Book Ninth Edition. Weed Sci. Soc. of Am. 810 E. 

lOth Street, Lawrence, KS 66044-8897. U.S.A. 

US Census. 2012. Statistical Abstract of the United States 2012. Table 358. 

USEPA. 2005. Tolerance Reassessment Progress and Risk Management (TRED) Decision for 

Fluazifop-P-butyl. http:/ /www.epa.gov/oppsrrd I /REDs/fluazifop tred.pdf . 

Accessed Date. May 1st, 2014. 

USDA, 2006 and 2009. NASS Nursery and Floriculture Report. Online: 

http:/ /guickstats.nass.usda.gov/results/E4 B4 F A4 B-15DB-3 5DO-A5CD-9889E6D7689F 

Page 10 
APPENDIX I. 

The map included herein is primarily for the use of the risk assessors in the Environmental Fate 

and Effects Division. The map provides a very broad geographical view of the average annual 

amount (in pounds) of the active ingredient applied per 1,000 acres of crop acres grown. These 

data are included in the maps because risk assessors are interested in the amount of a pesticide 

used across agricultural land. The calculated values presented in the map are not equivalent to 

an application rate (lb ai/ A). 

The data used to make these maps have several limitations. Any interpretation of the maps 

should consider the underlying data and the associated limitations carefully. 

The numerator (annual average pounds applied) is based on private market surveys of pesticide 

use in agriculture averaged over the last five years (Proprietary Data, 2008-2012). 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 usage may actually have a small amount 

of the active ingredient being used. _ In some cases the displayed use intensity may be distorted 

because the surveyed crops and the reported pesticide usage may not accmately represent the 

actual pesticide usage on the crops produced iiJ. the state. 

The denominator (1,000 crop acres grown) was also obtained from the same private market 

survey database. The "Crop Acres Grown" variable represents the total acres grown in a given 

state of all of the surveyed crops. This value is independent of pesticide usage and pesticide 

registration. It is important to note that the surveyed crops (about 60) are sampled from states 

that are major producers of each crop. Therefore, there are cases where the actual crop acreage in 

a state is higher than that reported by crop acres grown in the survey because either that state 

and/or crop was not included in the survey. 

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 legend bins will likely be different. 

Page 11