UNITED STATES ENVIRONM.ENTAL PROTECTION AGENCY WASHINGTON, D

.C

. 20460 

## JUN 08 2012

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION



### SUBJECT: BEAD Chemical Profile for Registration Review: MGK-264, Also Known as Noctyl Bicycloheptene Dicarboximide (PC Code: 057001) FROM:

# N~l**~allampal~i,** Entomologist 

# /ltl& Jfj.L_ S""/11/Z.DI'L BIOlogical Analysis Branch



### THRU: Ra.US

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## ~:._~rieto, .Envirodnmealntal.Protectihon

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# 1j (_ , /) '.**,** Cience uuormation an An ysis Branc f /
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# -r (TAU/,{_) Derek Berwald,

# Eco~omist**~ ~** **~** Economic Analysis Branch \._)

# J Biological and Economic Analysis Division (7503P) · Arnet Jones, Chief /)

# ~ Biological Analysis

# Branch**~** , Diann sims, chief

# (}~ Science Information and Analysis Branch**~** Timothy Kiely, Chief

# ~ \M 1 Economic Analysis Branch V ' -.. Biological and Economic Analysis · ision (7503P 

### TO: Katherine St. Clair, Chemical Review Manager Risk Management and Implementation Branch 2 Pesticide Re-evaluation Division (7508P)


### BEAD Product Review Panel date: April 4, 2012 INTRODUCTION The purpose ofthis document is to convey usage information and a broad overview ofthe pest management roles ofpesticides that are beginning to undergo registration review. The anticipated audience consists ofthe team ofEPA staffcurrently evaluating the registration status ofMGK-264, and eventually the general public. This document builds uponthe data already Page 

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' WJ Jl](,provided inthe "Usage and Label Use DataPackages" that are also provided to Registration Reviewteams by BEAD. The document is based on information and·data available to BEAD as ofApril2012. MGK-264, first registered inthe 1940s, is a chemical that is formulated with synthetic pyrethroids and organophosphates to increase their insecticidal activity. This effect is called synergism. Currently there is only one other synergist commercially available inthe US market, and that is piperonyl butoxide (PBO). MGK-264 underwentreregistration review in 2006 (see http://epa.gov/oppsrrdl/REDs/mgk red.pdffor the eligibility decision document). The chemical's common name derives from the currentmanufacturer ofthe technical-grade product (McLaughlin-Gormley-King). Ithas no Mode ofAction designation, according to the classification scheme published by the Insecticide Resistance Action Committee and available on the web at www.irac-online.org

. 

### USE SittS Commercial uses include application to non-food plants,**appli~ations** in food and**non~food** handling commercial and agricultural structures and outdoor premises, housing for veterinary and farm animals, and direct application to veterinary and non-food animals. Residentially, it is used (as part offormulations with other insecticides) to control insects bothinside the home, as well as outside on gardens, lawns and ornamentals, patios, and other outdoor structures. No agricultural crop uses ofMGK-264 were reregistered in the 2006 RED, and MGK-264 is not. used in wide area mosquito abatementprograms. Agricultural Use Sites MGK is not registered for agricultural uses, as a result ofthe 2006 RED. That document states: "It is registered for use in residential, commercial, and industrial sites. No agricultural crop uses ofMGK-264 are being supported, and MGK-264 is not used in wide area mosquito abatement programs." Non-Agricultural Use Sites Based on a list generated bythe National Pesticide Information Retrieval System (NPIRS) pesticide label database (available at http://state.ceris.purdue.edu), the non-agricultural sites on labels currently available to the public are, in summary: · • storage areas in commercial or industrial institutions, restaurants, grain mills/bins, food warehouses, and other facilities where food and animal feed are stored, processed, handled, transported, or marketed; • grain (equipment; storage areas-empty; transportation vehicles); and • ornamentals.

Pagel of5COMMON FORMULATIONS AND APPLICATION METHODS MGK-264 is formulated as granular and impregnated materials; dust; soluble, emulsifiable and flowable concentrates; pressurized gas and liquid; and ready-to-use solutions, according to the label summary generated by the NPIRS database. The 2006 RED for MGK-264 (page 15), summarized application methods available for this chemical as follows: "Applications to small areas may be made with handheld equipment, including low-pressure handwand sprayers, high pressure handwand sprayers, handgun sprayers, hose-end sprayers, thermal misters/foggers, and with ready-to-use application methods, including pump-trigger sprayers, foggers, aerosol cans, shampoos, dips, wipes, roll-ons, impregnated collars, and dust (puffer or shaker) cans." All application methods, except residential outdoor misting systems which the registrant did not support, were deemed eligible for reregistration in the 2006 RED. USAGE The proprietary market survey database that BEAD typically utilizes to obtain pesticide usage data does not include the "non-agricultural" use sites remaining on the MGK-264 labels. However, BEAD did a search ofthe publicly accessible pesticide use database maintained by the California Department ofPesticide Regulation (CADPR). Based onthese data, MGK-264's annual agricultural usage averaged 5,169 pounds ofactive ingredient (A.I.) from 2008-2010. Please see Appendix A for a summary ofthe CADPR data. Since agricultural uses ofMGK-264 are not supported by the registrant, BEAD speculates that the reported use in California on a few crops, such as grapes, may be the result ofinadvertent mischaracterization on the part ofthe people recording the usage data. For example, use ofMGK-264 inproducts applied to commodity storage areas for structural pest control may have been erroneously recorded as treatment ofthe commodity (e.g., grapes) itself. CADPR data are often based onreporting by pesticide applicators (or their companies), and it is possible that the very low use reported for the crops in Appendix A is the result ofdata entry confusion by some ofthese applicators. From 2008-2010, based on CADPR data, Structural Pest Control (94%) and Landscape Maintenance (3%) accounted for the largest proportion ofusage in terms ofpounds ofMGK-264 applied (see Appendix A). Note that CADPR data include only usage by professional pesticide applicators, and not homeowner use, which may be substantial, given that MGK-264 is frequently part offormulations sold "over the counter'' to homeowners and othernonprofessional users. USE TRENDS CADPR data indicate that in California, total use ofMGK-264 (in lb a.i. applied) decreased in 2010 to an amount that is about halfwhat was used in 2008 (see Appendix A). BEAD has no information onusage in other states and thus cannot draw any conclusions as to whether or not trends seen in California are representative ofotherregions.

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### 3 of5BIOLOGICAL ASPECTS RELE:V ANT TO MGK-264 Pest insect resistance to MGK-264 has apparently not beenreported inthe scientific literature, for either the U.S.A. and globally. Forexample, the Arthropod Pesticide Resistance Database maintained byMichigan State lJniversity (on the web at http://www.pesticideresistance.org/) shows no published reports for this chemical. BEAD's search ofthe accessible technical literature (primarily the referredjournals published bythe Entomological Society ofAmerica) also did not show any reports ofresistance to MGK-264. Interestingly, there are several such reports for PBO, the other commercially available synergist onthe U.S. market. Also interesting is a report thatpyrethroidresistant populations ofthe diamondback moth (Plutella xylostella) continuedto be susceptible to the synergistic effects ofMGK-264 while also showing resistance to PBO (Chen and Sun 1986). This insect is well-known among farmers andresearchers for its propensity to rapidly develop resistance to a variety ofinsecticides. While this is not a pest in residential or nursery production settings, this information does suggest that MGK-264 may have some utility as a replacement for PBO in non-agricultural areas where PBO-resistantpests become a problem.

IDSTORY OF BEAD ASSESSMENTS FORMGK-264 There are no BEAD impact assessments or Section 18 evaluations for MGK-264.
DATA NEEDS RELEVANTTOBEAD's FUTURE WORKONMGK-264 Obtaining additional information onthe following general item would improve BEAD's future assessment ofthe importance ofMGK-264 as a**pe~t** management tool. This assessment is may be required as part ofthe registration review ofthis pesticide. Usage information (particularlytotal amount a.i. applied peryear, applicationrate, and application method) for eachnon-agricultural site currently on labels. REFERENCES CaliforniaDepartment ofPesticide Regulation, 2008-2010. Chen, J.S. and C.N. Sun. 1986. Resistance ofdiamondback moth (Lepidoptera: Plutellidae) to a combinationoffenvalerate and piperonyl butoxide. J. Econ. Entomol. 79: 22-30. 2006 EPA RED: http://www.epa.gov/oppOOOOl/reregistration/REDs/mgk red.pdf

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### AppendixA MGK-264 usage reported bythe California Department ofPesticide Regulation (CADPR) for the years 2006 through 2010.



## ,,,**·~:r** , I{' !1';·"· •••• ,";•. r. • ,,,., 

### 2008 

### 2009 2010 "· 

# I ) Commodity 

# . Pounds Pounds Pounds I**.1~** ;:: ·"- J**.~·** "· J. ' ,f' • Applied Applied Applied ALMOND 1 5 CHICKENS (ALL OR UNSPEC) 1 COMMODilY FUM IGA TI ON 25 15 9 FEED/FOOD STORAGE AREAS (UNSPECIFIED) 7 2 FOOD PROCESSI NG/HANDUNG PLANT/AREA (ALL/UNSPEC} 5 26 39 FUMIGATION, OTHER 41 21 16 GRAPES, WINE 152 2 19 LANDSCAPE MAINTENANCE 208 121 39 GRAIN CROPS (ALL OR UNSPEC) 56 N-OUTDR CONTAINER/FLO GRWN PLANTS 1 N-DUTDR GRWN CUT FLWRS OR GREENS 14 OUVE 

### CAlL OR UNSPEC) 1 PUBUC HEALTH PEST CONTROL 9 10 REGULATORY PESTCONTROL 1 3 RIGHTS OF WAY 1 16 STRUCTURAL PESTCONTROL 6840 4471 3779 UNCULTIVATED NON-AG AREAS CALL OR UNSPEC) 2 GrandTotal 7289 4675 3993 Date Prepared: 04/04/12 I



### - Cal DPR Data: http://www.cdpr.ca..aov/docs/pur/purmain

.htm



### -- Empty cells indicate no available usage.



### -

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