### i 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 39 2 201; DP Barcode D 398764 )

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 a n 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, pineappl e, 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 formulati on 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 foun dation, 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 tha t exposure for the proposed uses.

### ii

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 Non

Target 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 b erry, 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.

### iii

Additional R ecommended Label Language

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

“Environmental Hazards”:

“ For Terres trial 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

s pray 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.

T his 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 f or 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, EF ED 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 pre

bloom 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 crops 1 

### . The recommendations by EFED for each gr oup 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

p roduct within 10 days prior to bloom, during bloom, or until petal fall is complete ”

1 USDA email communication, November 5, 2012.

### iv

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, lingonberr y, 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 lang uage “ 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,

includin g 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: d aylily (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 ”

### v

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), onio n (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 N/A Pomegranate

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