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 . ael ~:._~rieto, .Envirodnmealntal.Protectihon Sp~1 j (_ , /) '. , Cience uuormation an An ysis Branc f/ - (/ V"'-' -r (TAU/,{_) 

Economic 

Derek Berwald, 

Analysis 

Eco~omist Branch ~ \._) ~ J ~ 

Biological and Economic Analysis Division (7503P) · 

Biological 

Arnet Jones, 

Analysis 

Chief 

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 of this document is to convey usage information and a broad overview of the pest 

management roles of pesticides that are beginning to undergo registration review. The 

anticipated audience consists of the team of EPA staff currently evaluating the registration status 

ofMGK-264, and eventually the general public. This document builds upon the data already 

Page 1 of5 

' WJ Jl](, 
provided in the "Usage and Label Use Data Packages" that are also provided to Registration 

Review teams by BEAD. The document is based on information and·data available to BEAD as 

of April2012. 

MGK-264, first registered in the 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 in the US market, 

and that is piperonyl butoxide (PBO). MGK-264 underwent reregistration review in 2006 (see 

http://epa.gov/oppsrrdl/REDs/mgk red.pdffor the eligibility decision document). The 

chemical's common name derives from the current manufacturer of the technical-grade product 

(McLaughlin-Gormley-King). It has no Mode of Action 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 of formulations with other insecticides) to control insects both inside 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 abatement programs. 

Agricultural Use Sites 

MGK is not registered for agricultural uses, as a result of the 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 by the 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 of5 
COMMON 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 of the publicly accessible pesticide use database maintained by the 

California Department of Pesticide Regulation (CADPR). Based on these data, MGK-264's 

annual agricultural usage averaged 5,169 pounds of active 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 of inadvertent mischaracterization on the part of the 

people recording the usage data. For example, use ofMGK-264 in products applied to 

commodity storage areas for structural pest control may have been erroneously recorded as 

treatment of the commodity (e.g., grapes) itself. CADPR data are often based on reporting 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 of data entry confusion by some of these applicators. 

From 2008-2010, based on CADPR data, Structural Pest Control (94%) and Landscape 

Maintenance (3%) accounted for the largest proportion of usage in terms of pounds 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 of formulations sold "over the counter'' to homeowners and other nonprofessional 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 half what was used in 2008 (see Appendix A). BEAD has no 

information on usage in other states and thus cannot draw any conclusions as to whether or not 

trends seen in California are representative of other regions. 

Page 3 of5 
BIOLOGICAL ASPECTS RELE:V ANT TO MGK-264 

Pest insect resistance to MGK-264 has apparently not been reported in the scientific literature, 

for either the U.S.A. and globally. For example, the Arthropod Pesticide Resistance Database 

maintained by Michigan State lJniversity (on the web at http://www.pesticideresistance.org/) 

shows no published reports for this chemical. BEAD's search of the accessible technical 

literature (primarily the referred journals published by the Entomological Society of America) 

also did not show any reports of resistance to MGK-264. Interestingly, there are several such 

reports for PBO, the other commercially available synergist on the U.S. market. Also interesting 

is a report that pyrethroid resistant populations of the diamondback moth (Plutella xylostella) 

continued to 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 and researchers for its 

propensity to rapidly develop resistance to a variety of insecticides. 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-resistant pests 

become a problem. 

IDSTORY OF BEAD ASSESSMENTS FOR MGK-264 

There are no BEAD impact assessments or Section 18 evaluations for MGK-264. 

DATA NEEDS RELEVANT TO BEAD's FUTURE WORK ON MGK-264 

Obtaining additional information on the following general item would improve BEAD's future 

assessment of the importance ofMGK-264 as a pe~t management tool. This assessment is may 

be required as part of the registration review of this pesticide. 

Usage information (particularly total amount a.i. applied per year, application rate, and 

application method) for each non-agricultural site currently on labels. 

REFERENCES 

California Department of Pesticide Regulation, 2008-2010. 

Chen, J.S. and C.N. Sun. 1986. Resistance of diamondback moth (Lepidoptera: Plutellidae) to a 

combination offenvalerate and piperonyl butoxide. J. Econ. Entomol. 79: 22-30. 

2006 EPA RED: http://www.epa.gov/oppOOOOl/reregistration/REDs/mgk red.pdf 

Page 4 of5 
Appendix A 

MGK-264 usage reported by the California Department of Pesticide 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 FUMIGATION 25 15 9 

FEED/FOOD STORAGE AREAS (UNSPECIFIED) 7 2 

FOOD PROCESSING/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 PEST CONTROL 1 3 

RIGHTS OF WAY 1 16 

STRUCTURAL PEST CONTROL 6840 4471 3779 

UNCULTIVATED NON-AG AREAS CALL OR UNSPEC) 2 

Grand Total 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. -

Page 5 of5