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### 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)

. Bill Phillips, Agronomist

# ~ Biological Analysis Brnncf"1!'N

# ~

# r Sepehr Haddad, Environmental Protection Specialist Science Information and Analysis Branch Stephen Smearman, Economist 

## J.,-,

# ~**~~** Economic Analysis Branch 

# r-r Biological and Economic Analysis Division (7503P) Amet Jones, Chief Biological Analysis Branc Diann Sims, Chief

# ~ Science Information 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, 2014SUMMARY Fluazifop-P-butyl is an herbicide and was first registered inthe 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 onprivate 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 overthis time period was 0.13 pounds a.i./acre. In terms ofpounds applied and acres treated there has been a sharp decline inuse 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. Betweenthe 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 inthe control ofherbicide resistant volunteer com in broadleafcrops such as soybeans. However, the use ofthis herbicide in soybeans has declined since 1998 and as such its use in soybeans has fallen to approximately one percent ofthe crop. This lowuse in soybeans may be due to many factors including the availability ofcost-effective alternative herbicides. While most ofthis herbicide is used in soybean crops, it is applied in a large percentage ofthe carrot crop. Because approximately 25 percent ofthe 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 EPAperiodically reviewthe registrations ofall pesticides to insure thatthey do not pose unreasonable adverse effects to human health and the environment. This periodic review is necessary in light ofscientific advancements, changes inpolicy, and changes inuse 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 ofany use ofthe pesticide. The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an overview ofthe pestmanagementroles and quantitative usage information for fluazifop-P-butyl. The BCP includes summaries ofprevious BEAD products and available public and/or private use and usage data for fluazifop-P-butyl to describe the role ofthis chemical in pest management. Additional information on use is available inthe fluazifop LUIS Label Data Report and Screening Level Usage Analysis (SLUA). Information provided inthis 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 Reviewprocess ofthis pesticide.

Page2USE 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 offluazifop-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 APPLICATIONMETHODS Fluazifop-P-butyl is formulated as an emulsifiable concentrate and applied using ground or aerial equipment. Itmay 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 ofBEAD's Official Records database for BEAD benefits assessments specifically for fluazifop and fluazifop-P-butyl did not find any records ofprior 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 thatprovides the percent crop treated for 27 crops. Based onthe SLUA, there is one agricultural site (soybeans) with the greatest number ofpounds 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 ofBEAD'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 notregistered for use on a particular site. 

### An emergency exemption request may yield information about a particular chemical's importance orvalue that is not found in otherEPArecords. However, a lack ofSection 18 assessments by BEAD does not specifically indicate the relative importance ofthe chemical. Page 3

### USAGE Agricultural Usage Based onprivate 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 overthis time period was 0.13 pounds a.i./acre. Figure 1presents 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 interms ofpounds 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

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

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### "'" --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) 

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..... 0I0 !'Jco ?Jo,**~(;) ~"'** **~"' ~,**  ...{',bo**~<,** d<>**~ ~co** **~o, ~(;)** **~"' ~"'** **~ ~** **~ ~** **~ ~** **~-** .,_<J**~** .,_<J**~ ~**  "'(;) "'(;) "'(;) Years Source: Proprietary Data, 1998-2012



### Table 1. Comparison ofCrops in Years with the Highest Use ofFluazifop-P-Butyl- Percent 0

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### 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 bothtime frames include garlic, oranges, l'eanuts, l'eaches, and 20 additional crol's Source: Proprietary Data, 1998 -2012. Table 1 shows thatthe crop with the mostpounds applied during boththe 1998-2002 and 2008- 2012 timeframes has been soybeans accounting for approximately 90 percent oftotal pounds applied. The average annual usage inpounds has decreased approximately 70 percent from 432,000 lbs/year to approximately 125,000 lbs/year inthe 2008-2012 timeframe.

Page 5

### Table 2. Comparison ofStates with Highest Use ofFluazifop-P-Butyl- Percent ofTotal 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 bothtime frames accounting for approximately 50 percent oftotal pounds applied in the 1998-2002 timeframe and 60 percent oftotal pounds applied in the 2008-2012 timeframe, eventhoughtotal pounds applied has dropped 70 percentbetween the two timeframes. Application Rates The average a.i. rate for the top crops in terms ofpounds 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 AnnualAverage A vg. A.I. Rate (lbs Crop TotalAcres 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 thatreceive multiple treatments. Source: Proprietary Data, 2008 -2012 There are approximately 7 5 million acres ofsoybeans planted inthe U.S. and the data showthat fluazifop-P-butyl is used on approximately one million ofthose acres, which isjustless than two percent crop treated. Therefore, relatively speaking, it does not seem that many growers are relying onthis chemical. Onthe otherhand, there is approximately 85,000 acres ofcarrots planted, so approximately 25 percent ofcarrot acreage/production is relying onthis herbicide, which seems to indicate that use in carrot production appears important to growers.

Page 6Geographic Distribution ofFluazifop-P-Butyl Use Figure 3 provides a very broad geographical view ofthe average annual amount (in pounds) of fluazifop-P-butyl applied per 1,000 acres ofcrop acres grown. The calculated values presented inthe map are not equivalentto an application rate (lb ai/A), therefore, the map may show areas ofhigh use intensity that do not correspond to the states listed inTable 2 since those states are the states with the highest use offluazifop-P-butyl based onpounds active ingredient applied. As shown in the map, Illinois and Minnesota depict a high use intensity ofacres treated with fluazifop-P-butyl. Please see Appendix I for a more detailed explanation ofthe information presented onthe map. 

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

PoundsActive Ingredient per 1,000 Crop Acres Grown 0NoData 

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Page 7Non-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'sNational 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, otherreported data is available from Kline for the years 2002, 2004, 2006 for nursery/greenhouse, 2004, 2006 for golfcourses, 2004 for landscape and turffarms, and 2004 and 2011 for institutional turfas shown in Table 4. Total non-agricultural usage between 2004 and 2006 appears to have increased for golfcourses, and institutional turf, but decreased for nursery/greenhouse; however, more recent data (post-2006) are not available to determine ifthis trend has continued since only one category ofnon-agricultural usage (institutional turf) was . available for 2011.

--- --------- - --- -- - -**-~-CI** ------**-- -~---**  

### 2-2011) Site 

### 2002 2004 2006 2011 GolfCourses 

### 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 TurfFarms N/A 10 N/A 

### NIA

- N/A= Not Available Source: ProprietaryData 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 inthe Weed Science Society ofAmerica group one and works by inhibiting the production offatty acids through the mechanism ofaction ofinhibiting 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 ofthe active ingredient.


### ROLE OFFLUAZIFOP-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 boththe total areatreated and the total pounds applied (Proprietary Data 2012). As herbicide resistant crops have become the mainstay ofcrop production, volunteer comhas become a weed that is more difficult to control than in the past. These complants are currently being developedto be resistantto multiple herbicides some ofwhich may have otherwise beenused to control volunteer com. Grass herbicides like fluazifop-P-butyl can be a tool with which otherherbicides canbe rotated to control herbicide resistant comin broadleafcrops such as soybeans. However, the use ofthis herbicide in soybeans has declined since 1998 and as such its use has fallen to approximately one percent of Page 8the total crop. This low use in soybeans maybe due to many factors including the availability of cost-effective alternative herbicides. While most ofthe fluazifop-P-butyl is used in soybean crops, it is applied in a large percentage ofcarrots. 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 earlypostemergence in this crop. Because approximately 25 percent ofthe carrot crop receives treatments with this herbicide, it seems that fluazifop-P-butyl is an important tool in controlling grass weeds in carrotproduction.

DATANEEDS 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 ofthis herbicide.

NonAgricultural Use Except for recent usage data on consumer lawns in 2011, BEAD does not have recent (post-2006) data onnon-agricultural usage for golfcourses, 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 ofPesticide 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 9Senseman, S.A. (2007), Herbicide Harid BookNinth Edition. Weed Sci. Soc. ofAm. 810 E. lOth Street, Lawrence, KS 66044-8897. U.S.A. US Census. 2012. Statistical Abstract ofthe United States 2012. Table 358. USEPA. 2005. Tolerance Reassessment Progress and Risk Management (TRED) Decision for Fluazifop-P-butyl. http:/ /www.epa.gov/oppsrrdI/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/E4B4FA4B-15DB-35DO-A5CD-9889E6D7689F

Page 10APPENDIX I. The map included herein is primarily for the use ofthe risk assessors inthe Environmental Fate and Effects Division. The map provides a very broad geographical view ofthe average annual amount (in pounds) ofthe active ingredient applied per 1,000 acres ofcrop acres grown. These data are included in the maps because risk assessors are interested in the amount ofa 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 ofthe maps should consider the underlying data and the associated limitations carefully. The numerator (annual average pounds applied) is based onprivate market surveys ofpesticide use in agriculture averaged over the last five years (Proprietary Data, 2008-2012). These surveys cover about 60 crops and are targeted in states thatproduce the majority ofthe crop. Although the surveys capture most ofthe use ofa particular active ingredient in agriculture, there are several limitations to these surveys.

• States with minorproduction 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 usage may actually have a small amount ofthe 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 onthe 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 ofall ofthe surveyed crops. This value is independent ofpesticide usage and pesticide registration. It is importantto note that the surveyed crops (about 60) are sampled from states that are major producers ofeach 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 inthe survey. The reader should payparticular 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.

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