UNITED STATES ENVIRONMENTAL PROTE C T ION AGENC Y WASHINGTON , D

. C

. 20460 

### AUG 

## 0 8 2014

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENT I ON MEMORAND UM
SUBJECT:
FROM:

THRU : Charac teriza tion ofFluto l anil Use and Usage on Major Crops (Peanuts, Potatoes and R ice), Turf and Ornamenta l s (PC Code # 128975) Tara Chandgoya1, Ph. D., Plant Patho logist Bio logical Analysis Branch Leonard Yourman, Ph
. D
. , Plant Pathologist Biolog ical An alysis Branch J ihad Alsadek , Ph.D
. ,

# Economist**~** 

# r Science Information and Analysis Branch Stephen Smearman, Economist

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## ~ Economic Analysis Branch


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. Biological and Econom ic Anal ys i s Divi sion (7503P) Amet Jones, Chief Bio logica l An alysis Branch D iann Sims , Chief Science Information and Analysis Branch Timothy Kiely , C hi ef 

# Q**~** Economic Analys i s B r anch

## ~ Bio log ical an d Economic Analysi ivision (750 TO : Kevin Costello, Chief Risk Management an d Implementation Branch II Pestic ide Re-evaluation Division (7508P) Product Review Panel date : July 30, 2014

Page I of8

### SUMMARY Flutolanil is a fungicide registered for the control of fungal diseases on peanuts , potatoes, rice and other crops (such as leafy vege tabl es, cole crops, cotton and sugar beets), turf, and ornamentals. In this document we have focused on use and usage characteristic of flutolanil on three agricultural crops (peanut s, potatoes and rice), turf, and ornamentals. When compared with other registered fungic ide alte rnatives, flutolanil is a viable alternat i ve for contro l of white mold, (caused by Sclerotium sp.) & limb/pod rot (caused by Rhizoctonia sp.) on peanuts , Rhizoctonia diseases (scurf and blight) on potatoes (seed and foliar treatment), and Rhizoctonia diseases on turf and ornamentals. Accord ing to private pesticide market research, flutolanil use on potatoes and peanuts has increased while the use on rice has decreased during the 2008-2012 time period. The data show that during 2008-2012 , the average percent crop treated (PCT) with flutolanil for peanuts and potatoes (foliar) treated with flutolanil was 15% and 10 %, respectively , while for potato seed treatment PCT was 5% percent and rice PCT was less than 1%
. EPA Propriety Data (2008- 20 12) showed that on peanuts 95% of the applied flutolanil was v ia ground app li cation and 5% was v i a aerial application. Simi lar data for potatoes and rice was no t collected. An average of 2 applications per year of flutolanil was applied on peanut and 1 application each for potatoes and rice over the five year period
. Th e average app licat ion rate for peanuts is 0.4 pounds of active ingredient (lbs a .i. ) per ac re , 0.5 lbs. a .i
. for potatoes (foliar and seed) and 0.3 lbs. a.i. for rice (2008 -20 12, EPA Proprietary Data)
. Fluto lanil u se on turf and ornamentals is typically li mited to treatment for Rhizoctonia diseases and as s u ch hig hl y dependent on d i sease pressure in a g i ven season as well as typical use patterns that involve spot treatments where pockets of disease may b e observed or anticipated. 

### BACKGROUND FIFRA Section 3(g) mandates that EPA periodically review the registrations of all pesticides to in sure th at 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 chan ges in use patterns that may alter the conditions underpinning previous registrati on decisions. In determining whether effects are unreasonable, FIFRA requires that the Agency consider the risks and benefits of any use of th e pesticide. BEAD is providing a description of flutolanil in pest management on peanuts , potatoes, rice, turf and ornamental s as well as information on use and usage to support risk assessment and risk management for the chemical. These sites account for the majority of the usage of flutolanil.

Page 2 of8FL UTOLANIL USE AND USAGE CHARACTERIZATION Peanuts, Potatoes and Rice Among these t hree agricul tural crops (peanu ts , potatoes and rice), peanuts and pota toes accounted for more than 99% of the flutolani l usage in the United S tates during 2008

-2012. The average a . i
. application rates for peanuts, potatoes (foliar), po tatoes (seed) and rice were 0.45, 0.47, 0.50 and 0.35 lbs a.i., re spec tively (Table 1). Based on the available data, two app li cations of flutola nil were typically applied on peanuts whereas potatoes and rice received one per year. T bl 1 Fl t I 

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# - 2008-2012 Avg Annual Lbs A. I. Applied = 285,000 Crop Propo rtion of Total Lbs Avg. A
. I. Rate of #of A. I. of Flutolanil Applied Application (lb Apps a. i./acre) Peanuts 75 0.4 2
.0 Potatoes (foliar) 25 0.5 1.0 Potatoes (seed) 3 0.5 1.0 Rice < I 0.3 1.0 Source: EPA Propnetary Data, 2008-2012 Flutolanil Percent of Crop Treated: Peanuts, Potatoes and Rice (2008-2012) Availab le data show that during 2008

- 2012, the average percent crop treated with flutolanil for peanuts and potatoes (folia r) was 15 and 10 %, respectively, whi le potato seed treatment was 5% and rice was le ss than 1 % (Table 2). T bl 2 Fl t I 

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- 2012 Avera2e PCT MaxPCT Peanuts 15 25 Potatoes (fo liar) 10 20 Potatoes (seed treatm ent) 5 10 Rice < I <2.5 Source: EPA Propn etary Da ta 2008 -20 12 and USDA NASS (2014) Tables 3 through 4 identify the states w ith the most use in terms of the total pound applied of flutolanil for peanuts, potatoes and rice for the year s 2008

- 2012. The total pounds applied for each s tate was averaged over the five year period. A rank is provided to show the states with the highest use over the five year period. For peanuts the total pounds app li ed has been steadily increasing over the five year period of2008 through 2012. Georgia's use offluto lanil accounted fo r almost 82% of the 212,400 total pounds used over the five year period (Tab le 3)
. For potatoes (Table 4), the total pounds applied have been re lat ively steady for the five years from 2008 through 2012 averaging 72,770 lb a.i. per year. Idaho accounted for nearly 50% of the use over that time period. F luto lanil use on rice h as declined significantly over the five year period from 2008 to 2012. There is a 3 mil e buffer restriction when using flutolan il on rice grown near any marine /es tuarine Page 3 of8waterway or watershed due to fluto lanil's high tox i city to shrimp
. This may have impacted rice growers use of flutolanil and may explain the significant use decline in rice . 

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### a e Flutolanil Use on Peanuts by State State 5 Year Averae:e ofTotal Pounds Applied Rank Georgia 173 ,400 I South Carolina 18,200 2 Alabama 16 , 600 3 North Carolina 3 , 580 4 Florida 660 5 T otal Pounds 212,440 Source : EPA Propnetary Data 2008-2012 T 

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### ae Flutolanil Use on Potatoes by State State 5 Year Average of Total Pounds Applied Rank Idaho 34 , 300 I North Dakota 12 , 000 2

Minnesota 8,000 3 Nebraska 3,000 5 Oregon 5 , 000 4 Washington 2,700 6

Others* 7 , 000 Total Pounds 72,700 Source: EPA Propn e tary Data 2008-2012 *Others includes the states of California, Maine, Michigan, Montana, New York, Texas and Wisconsin.
FLUTOLANIL ALTERNATIVE FUNGICIDES (2008-2012) ON PEANUTS, POTATOES AND RICE (2008-2012) Available data (2008

- 20 12) showed that the number of acres ofpeanuts treated with tebuconazole and chl orothalonil were greater than the number of ac res treated w ith flutolan il (Table 5) for the control of white mo ld (Sclerotium sp.) and limb/pod rot (Rhizoctonia sp.). Similarly, the number of acres of potatoes treated with azoxystrobin, mancozeb and fludioxonil each were greater than the number of acres of peanut s treated with fluto l an il (Table 6) for controlling black scurf disease. Flutolanil is on average slightly more expensive than the alternati ves. However, given that the acreage treated for peanuts and potatoes is significant it is an indication that growers find flutolanil beneficial. On rice fl utolanil ranked sixth among the fungic i des used to control sheath blight disease caused by Rhizoctonia (T ab l e 7). The average number flutolanil applications applied per year on peanuts , potatoes and rice for these diseases were 2.5 , 1 , and 1 , respectively.

Page 4 of8Table 5 . Top Fungicides Used on Peanuts to Control White Mold (Sclerotium sp .), Limb/Pod Rot and (Rhizoctonia) (2008-2012).
Active ln2redient T otal Area Treated Avg. Num of Apps per year? Teb uconazo le 6,408,483 3.0 Chlorothalonil 2,318 ,77 3 3.4 Flutolanil 2 ,276,983 2
. 5 Source: EPA Propri etary Data, 2008-2012 Table 6. Top Fungicides Used on Potatoes to Control Black Scurf caused by Rhizoctonia (2008-2012)

Active lntzredient Total Area Treated Avg. Num of Apps per yea r Azoxystrobin 1 ,179,689 1.1 Mancozeb 758 ,114 1.0
. Fludioxonil 687,836 1.0 Flutolanil 421 ,730 1.0 Source: EPA Propnetary Data , 2008

-2012 Ta ble 7. Top Fungicides Used on Rice to Control Sheath Blight (caused by Rhizoctonia sp), 2008-2012 Active Ingredient Total Area Treated Avg. Num of Apps per year Azoxystrobin 6 , 156,301 1.2 Propiconazo le 4 ,4 64,338 1.0 Trifloxystrobin 1,502,363 1.0 Pyraclostrobin 79 , 868 1. 0 Bacillus Pumilis 12,387 1.0 F1utolanil 1,613 1.0 Sourc e : EPA Propnetary Data, 2008-2012
TURF AND ORNAMENTALS Turf Flutolani l is used to manage Rhizoctonia diseases on turfg rass (e.g. , brown patch , large patch , ye llow patch , and red thread) (e.g., NCSU , 2007; Tredway 

### et al. , 2005). BEAD proprietary da t a from 2007, indicated that in 2006, on average, no t quite half of golf courses nationally used some fungicides to manage brown patch (only a small portion was used in the western U.S.). Fairy ring was responsible for use of fungicides on average on approximately 10% of golf courses nationally. According to BEAD proprietary data from 2012 , on average 66,000 lb a.i
. ofProStar 70WP was used on go lf course turfgrass in the U.S. annually over the past five years. This represente d less than 1% of the total pounds of fungicides used on go lf course turf grass . The low usage may be due to flutolanil being used primarily only where and when Rhizoctonia diseases are prevalent while other more heavily used fungicides, such as chlorothalonil (2 million pounds Page 5 o f8were used on golfturf in 2006), have a broader range oftarget pathogens and thus are more widely used throughout a season . California Pesticide Use Reporting database for nonagricultural crops reported some use of flutolanil for landscape maintenance, greenhouse use and turf/sod, but data lacked reliable reporting of area treated (Cal PUR, 20 12). In North Carolina State University experimental trials for brown patch control , 28 days control was the target interval , with an application (equivalent to 4.3 and 5 .7 lb ai per acre) in 3 gallons fungicide suspension per 1000 sq ft (Tredway 

### et al., 2005). Both r ates provided good control. Again spot treatment s, rather than broadcast of. larg e areas of a golf course, would be likely although BEAD does not currently have supporting inf ormation to describe how much area would typically be treated per acre or per course. According to the label, treatment for fairy ring would not exceed 10,000 sq ft per acre; therefore , the maximum treatment would be approx imately 2lb ai per acre at the max use rate of 4.5 oz product per 1000 sq ft

. Fairy rings would typically be treated with flutolanil as a preventative in areas of turf with a history of infestation (Fidanza et al. , 2000). Greens or tees would be the likely use site as these are the most intensively cultivated portion of a golf course.
Ornamentals Flutolanil can be used in nurseries to manage Rhizoctonia rots on ornamental plants and are sometimes used to manage rust diseases (LSU, 2012)
. According to the ProStar 70WP label, a maximum of four applications per year may be made to ornamental p lantings. If the maximum 12 oz product were used (for foliar application), then 0.525lb ai would be added to 100 gall on s water (assumed 100 gallons per acre, which would vary depending on the nursery stock and sprayer type) fo r foliar sprays. If four applications are made , the n a maximum annual application would be 2 .1 lb. For container nurseries, one gallon containers (6 " diameter x 7", actually holds 3 quarts soil) are a standard nursery size for container planting ("#1" pots) (WSU, 2004). One acre will hold 20,000-22,000 1-gallon containers (Halcomb and Fare, 2009). Acco rdin g to the ProStar 70WP label, for 6" pots there could be 2.93 lb ai per acre if all pots were treated (6.5 fl oz . suspension

- at 0.2625 lb ai per 100 gal) into 22,000 pots per acre = 143,000 fl oz. per acre; 143,000/12800= 1 1.17 x 0.2625 lb per 100 gal = 2.93 lb)
. ·
BIOLOGICAL ANALYSIS Flutolanil i s effective in controlling various fungal diseases on peanuts, potatoes , rice, turf and ornamentals. The Fungicide Resistance Action Committee (FRAC , 2014) has designated flutolanil as FRAC Code 7. Fluto lanil is in the phenyl

-benzamides group of succ inate dehydrogenase inhibiting (SDHI) fungicides. Flutolani l is considered medium to high risk for re sistance-development by fungal pathogens. FRAC (2014) recommends resistance management when this fungicide is used. Fungicide resistance can be managed by rotating or tank-mixing fungicides with different modes of action. Page 6 of8The available data suggest that flutolanil is one of many fungicides used for controlling fu ngal diseases on peanuts , po tatoes and rice. This can be due to many factors such as efficacy, a grower's choice, market availability and pricing. EPA Proprietary Data (2008-20 12) s howed that on average les s than 1% of the rice crop was treated with flutolanil (for sheath bli ght control). Flutolanil is an effective fungicide for managing Rhizoctonia diseases on turf and ornamental plants. Along with quinone outside inhibiting (Qol) fungicides (Group 11 , such as azoxystrobi n and pyraclostrobin) flutolanil is considered effective in successfully managing Rhizoctonia di seases (e.g. Tredway et al., 2005). For turf and ornamental uses flutolanil as an SDHI fungicide is considered a useful partner that may be alternated with other fung icide chemistries (such as DMI and Qol fungicides) to provide effective resis tance management as well as effective disease control.
CONCLUSION Flutolanil is used on peanuts, potatoes and rice, turf grass, and ornamental plants to control fu ng al diseases. The majority of flutolanil is reported to be used on peanuts and potatoes. The percent crop treated with flutolanil on peanuts is 15%, on po tatoes (foliar) 10% , 5% for potato seed treatment, and le ss than 1% for rice. Based on PCT and to tal area treated for peanuts , potatoes and rice , flutolanil is a viable alternative for control of fungal diseases especially for peanuts and potatoes while th e buffer restrictions on rice has severely limited flutolanil' s use on rice. However, use on rice is currently minimal (Tables 1, 2, and 8). EPA propriety data (2008- 2012) showed that on peanuts 95% of the applied flutolanil was via ground application and 5% was via aerial application. Similar data for potatoes and rice were not collected. Flutolanil plays a role in resistance management when used on agricultural crops providing a different mode of action (SDHI) from other registered fungicides on these crops. Thi s is also the case for flutolanil use on turf and ornamental plants. Alternating effective fungicides of different modes of action is a standard means of reducing the likelihood of the development of resistance to fungicides by target pathogens. Rhizoctonia rots are the major target diseases for flutolanil use in turf and ornamental plants and as such it may be important where these rots are prevalent. Comparison of total usage with other more broad-spectrum fu ngicides may underestimate the value of flutolanil since it targets a limi ted number of pathogens for disease co ntrol.
REFERENCES Anonymous, 2014. Crop profi le: Po tatoes in New York. http: //pmep.cce.cornell.edu/fqpa/cropp ro:files/potato.html BEAD. 2014. Chemica l Screening Leve l Usage Analysis. Biological and Economic Analysis Di v ision , Office of Pesticide Programs, US Environmental Protection Agency. July 17, 2014. Brandenburg, R.L., Jordan, D.L., Shew, B.B., Wilcut, J.W. and Toth, S.J. 2005. Crop Profile for Peanuts in North Carolina. Accessed on July 1, 2014.
Page 7 of8http: //www.ipmcenters
. org/cropprofiles/docs/ncpeanuts.pdf Cal PUR. 2012. California Pesticide Use Reporting Program. http: //www .cdpr.ca. gov

### Idocs/pur /purmain.htm Collum, E
. 2005. Crop Profile for Rice in Mississippi. http: //www.ipmcenters
. org/cropprofiles/docs/ msrice.pdf Fidanza, M
. , Colbaugh, P
. , and Davis , S
. 2000
. Fairy ring biology and management in turfgrass. Turf Grass Trends. April , 2000. http: //archive.lib.msu.edu/tic/tgtre/ article/2000apr6.pdf FRAC. 2014. Fungicide Resistance Action Committee Fungicides Sorted by Mode of Action. (Accessed on July 29, 2014.) http: //www. frac. info/publication/anhang/ 20 14%2OFRAC%2OCode%20 List.pdf Halcomb, M and Fare , D. Conventional container production. University of Tennessee Extension. 2009. http: //www.utextension.utk.edu/mtnpi/handouts/ Container%20Production/Container Production

Handout -rev%208-09 .pdf LSU. 2012. Diseases of ornamentals and fungicides for control. Louisiana State University Extension. http: / / www.lsuagcenter
. com/NR/rdonlyres/F512A031-FDF9-46C6-AEE2- B800409C9FDF / 84808/ 280rnamenta1Fungicides20 12.pdf Luper , C. , Criswell , JT. , Bolin , P. , Medlin , C., Mulder, P and Damicone, J. 2007. Crop Profile for Peanuts in Oklahoma. Accessed February 10,2014. http ://www.ipmcenters
. org/cropprofiles/docs/ OKpeanuts.pdf NCSU. 2007. Fungicides for turfgrass disease control. North Carolina Sta te Universi ty Extension. http ://www.turffiles.ncsu.edu/PDFFiles/ 004351/fungicides for turfgrass disease control nov 2 007.pdf Proprietary Data, 2008-2012 Tredway, L. P., Butler, E. L. , and Monroe, J. 2005. Turfgrass

- Managing Brown Patch in Tall Fescue Landscapes. North Caro lina Sta t e Uni versi ty Extension
. http :// www . cals
. ncsu.edu/plantpath/extension/fact sheets/Turfgrass

- Managing Brown Patch in Tall Fescue Landscapes.htm USDA NAAS. 2014. http: //www.nass.usda.gov/ WS U
. 2004. Above ground container production. Washington State University E xtension. http: / Igardencenternursery. wsu. edu/ container / AboveGroundContainerProduction.htm

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