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OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

MEMORANDUM

DATE: December 13, 2012

SUBJECT: Section 3 New Use of Spirotetramat on Taro Leaves, Watercress, Pomegranate, 

Banana, Bulb Vegetable, Low Growing Berry, Bushberry, Globe Artichoke, 

Fruiting Vegetable, Pome Fruit, Citrus Fruit, Pineapple, and Coffee

(PC Code 392201; DP Barcode D398764)

FROM: José L. Meléndez, Chemist

Joseph DeCant, Ecologist

Environmental Risk Branch 5

Environmental Fate and Effects Division (7507P)

THROUGH: Mah T. Shamim, Ph.D, Branch Chief

Environmental Risk Branch 5

Environmental Fate and Effects Division (7507P)

TO: Rita Kumar, Risk Manager Reviewer

John Hebert, Risk Manager #07

Insecticide and Rodenticide Branch

Registration Division (7505P)

The Environmental Fate and Effects Division (EFED) has completed its review of an IR-4 

petition for the use of Spirotetramat, MOVENTOTM (Reg. No. 264-1050), Ultor (Reg. No. 264-

1065), and BYI8330 (Reg. No. 264-1051), on taro leaves, watercress, pomegranate, banana, bulb 

vegetable, low growing berry, bushberry, globe artichoke, fruiting vegetable, pome fruit, citrus 

fruit, pineapple, and coffee. The Section 3 New Chemical assessment (D345278, 05/30/2008), is 

relevant to this assessment and provides background information on the chemical, its 

environmental fate and transport properties, ecotoxicity, and the overall problem formulation and 

conceptual model for spirotetramat. The recent Section 18 assessment (D403255, 07/26/2012), 

for the use on watercress, also provides information on the risk associated with the use of 

spirotetramat on watercress. This assessment builds on the foundation, and relies heavily on the 

previous risk assessments. Table 1 presents a summary of the risk conclusions associated with 

the proposed uses. Following this table, this document first presents an overview of exposure 

and the risk associated with that exposure for the proposed uses. 
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Table 1. Summary of Environmental Risk Conclusions for Various Taxa Exposed to 

Spirotetramat for the Proposed Uses

Assessment Endpoint Identified Concerns Proposed Uses Associated with Risk a

Acute and Chronic Risk to 

Freshwater and 

Estuarine/marine Fish

Acute Watercress, Cranberry

Acute and Chronic Risk to 

Freshwater and 

Estuarine/Marine Invertebrates

Acute to all aquatic 

invertebrates and Chronic

to benthic invertebrates

Watercress, Cranberry

Aquatic Non-Vascular and 

Vascular Plants

Risk to Non-Vascular Watercress, Cranberry

Acute and Chronic Risk to 

Birds

Chronic Watercress, Banana/Plantain, Globe Artichoke, 

Citrus, Pome, Bushberry/Low Growing Berry, 

Coffee, Pineapple, Pomegranate, Bulb 

Vegetables

Acute and Chronic Risks to 

Mammals

Chronic Banana/ Plantain

Risks to Upland and Wetland 

Plants

None N/A

Concerns to Terrestrial NonTarget Insects

Acute and Chronic Citrus, Bushberry/Low Growing Berry, Pome, 

Coffee, Bulb Vegetable

Risks to Earthworms None N/A

a N/A = Not Applicable

The current status of the outstanding data requirements for toxicity testing, building upon the 

previous risk assessment (D384525), are as follows:

850.1075 Freshwater Fish Toxicity with Fathead Minnows: in review

850.1350 Aquatic invertebrate life-cycle Estuarine/Marine: in reserve

850.2100 Avian Oral Toxicity Study with a Passerine Species: in review

850.2300 Avian Reproduction Study with the Mallard Duck (Anas platyrhynchos): No 

data submitted

850.3040 Field Testing for Pollinators: in reserve

o The EFED has developed crop specific label language that can be used to 

eliminate exposure to pollinators for some crops, but not all crops. For tree fruits,

tree nuts, citrus, and bushberry/low growing berry, the EFED believes that 

additional data on translocated residues are needed to better characterize 

exposure. Further data that satisfies the Guideline 850.3040 will be held in 

reserve pending the outcome of residue characterization in the field.

Non-guideline Study for Systemic Field Residues with Tree Crops and Bushberry: No 

data submitted. 
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Additional Recommended Label Language

EFED notes that the following language already appears in the proposed label under 

“Environmental Hazards”:

“For Terrestrial Use: This pesticide is toxic to aquatic invertebrates and oysters. Do not 

apply directly to water, to areas where surface water is present, or to intertidal areas 

below the mean high water mark. This product may contaminate water through drift of 

spray in wind. Do not apply when weather conditions favor drift from treated areas. Drift 

and runoff from treated areas may be hazardous to aquatic organisms in neighboring 

areas. Do not contaminate water when disposing of equipment washwaters or rinsate.

This chemical has properties and characteristics associated with chemicals detected in 

ground water. The use of this chemical in areas where soils are permeable, particularly 

where the water table is shallow, may result in ground-water contamination.

This product is potentially toxic to honey bee larvae through residues in pollen and 

nectar, but not to adult honeybees. Exposure of adult bees to direct treatment or residues 

on blooming crops can lead to effects on honeybee larvae. See the "Directions for Use" 

section of this label for specific crop application instructions that minimize risk to honey 

bee larvae.”

Recommendations regarding spray drift, runoff, and wind speed also appear in the labels. 

Additionally, as a potential mitigation measure, EFED advises a restriction on applications over 

cranberry to occur no sooner than 30-days pre-flood.

Spirotetramat is toxic to bee brood, yet exposure can be mitigated for various crops given 

specific label language. Due to the systemic nature of spirotetramat, applications made prebloom may translocate to pollen and/or nectar during the bloom period. Therefore, applications 

made after petal fall is complete eliminates the potential for this exposure. EFED has 

coordinated with the U.S. Department of Agriculture (USDA) in order to further evaluate the 

proposed crops that would benefit pollinators given the specific label language. The USDA 

provided information related to the attractiveness of the crop, whether it is commercially 

pollinated, and the overall crop acreage of the crop group and specific minor crops1. The 

recommendations by EFED for each group are presented in Table 2. 

Table 2. List of proposed crops and EFED recommendations on pollinator label language to address 

exposure concerns to pollinators.1

Crop(s) Crop Subgroup EFED Recommendation for 

Label Language and Rationale Specific Language

Citrus

Australian lime (desert, finger, 

and round), Brown River 

finger lime, Japanese summer 

grapefruit, Mediterranean 

mandarin, Mount White lime, 

New Guinea wild lime, 

Appropriate language is already 

applied to the labels for this 

crop group

“Do not apply this 

product within 10 

days prior to bloom, 

during bloom, or 

until petal fall is 

complete”

 

1 USDA email communication, November 5, 2012.
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Table 2. List of proposed crops and EFED recommendations on pollinator label language to address 

exposure concerns to pollinators.1

Crop(s) Crop Subgroup EFED Recommendation for 

Label Language and Rationale Specific Language

Russell River lime, sweet 

lime, Tachibana orange, Tahiti 

lime, Trifoliate orange, uniq 

fruit, including cultivars, 

varieties and/or hybrids of 

these commodities)

Bushberry/low 

growing berry

aronia berry, bearberry, 

bilberry, blueberry (highbush 

and lowbush), Chilean guava, 

cloudberry, cranberry, currant 

(black, buffalo, native, and 

red), elderberry, European 

barberry, gooseberry, edible 

honeysuckle, jostaberry, 

Juneberry, muntries, 

lingonberry, Partridgeberry, 

salal, sea buckthorn, and 

cultivars, varieties, and/or 

hybrids of these)

Due to commercial pollination 

and being highly attractive to 

pollinators, as well as fairly 

extensive cultivation, EFED 

recommends appropriate

protective label language

“Do not apply until 

after petal fall”

Pome

azarole, Chinese quince, 

Japanese quince, medlar, 

tejocote

Appropriate language is already 

applied to the labels for this 

crop group.

“Do not apply until 

after petal fall”

Fruiting Vegetable

cayenne, chili pepper, 

habanero, jalapeno, pablano, 

pimento and serranero, 

African eggplant, Bush 

tomato, cocona, currant 

tomato, garden huckleberry, 

goji berry, martynia, 

naranjilla, pea eggplant, 

roselle, scarlet eggplant, 

sunberry, tree tomato, 

including varieties and/ or 

hybrids of these commodities

These crops are in general only 

moderately attractive to 

pollinators; in addition the crops 

proposed under this IR4 petition 

are low in acreage; therefore 

EFED does not recommend 

specific label language 

N/A

Coffee N/A

Coffee is highly attractive to 

pollinators, but it is neither 

commercially pollinated nor 

covers extensive acreage; 

appropriate protective label 

language may therefore offer 

localized benefits but is of low 

priority due to the minimal 

acreage of cultivation

“Do not apply until 

after petal fall”

Bulb Vegetables

Crops of Crop Subgroup 3-

07A (including: daylily (bulb), 

fritillaria (bulb), garlic (bulbs 

of common, great-headed, 

serpent), lily (bulb), onion 

(bulbs of common, Chinese, 

pearl, potato onion), shallot 

(bulb), plus cultivars, 

Most of the crop groups have 

low acreage in production; 

garlic and onions are moderately 

sized acreage; these crops are 

of low attractiveness to 

pollinators however some of 

these crops are commercially 

pollinated for seed production; 

“Do not apply until 

after petal fall”
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Table 2. List of proposed crops and EFED recommendations on pollinator label language to address 

exposure concerns to pollinators.1

Crop(s) Crop Subgroup EFED Recommendation for 

Label Language and Rationale Specific Language

varieties, and/or hybrids of 

these);

Crops of Crop Subgroup 3-

07B, (including: Chinese 

chive (fresh leaves), chive 

(fresh leaves), elegans hosta, 

fritillaria (leaves), kurrat, leek 

(Allium porrum, Lady’s, 

wild), onion (Beltsville 

bunching, fresh, green, 

macrostem, tree [tops], welsh 

[tops]), shallot (fresh leaves), 

plus cultivars, varieties, and/or 

hybrids of these)

EFED recommends appropriate

protective label language for 

those crops grown specifically

for seed production

Pineapple

N/A

These crops are neither 

attractive nor grown in large 

acreage therefore EFED does 

not recommend specific label 

language

Pomegranate N/A

Banana Plantain

Globe Artichoke N/A

This crop is harvested prior to 

bloom and is unattractive to 

pollinators therefore EFED does 

not recommend specific label 

language

N/A

Taro Leaves

N/A

These crops are harvested prior 

to bloom and therefore EFED 

does not recommend specific 

label language

N/A

Watercress

1 N/A = not applicable