UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D

.C

. 20460 

### JUL 28 

## 2011

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION 

### MEMORANDUM SUBJECT:
FROM:

THRU: BEAD Response to Tessenderlo Kerley, Inc. (TKI) Comments on Terbacil (012701) BEAD Chemical Profile Sunil Ratnayake, Biologist

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. Biological Analysis Branch 

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# I**~** Sepehr Haddad, Environmental Protection Specialist 

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_**~** I. 4 Science Information and Analysis Branch

# r~ Elizabeth Hill, Economist

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# 4-**IM.~!J** Economic Analysis Branch 

# U l) Biological and Economic Analysis Division (7503P) Arnet Jones, Chief Biological Analysis Branch Diann Sims, Chief**£:.~~"\...AI"~rI'-""** Science Information and Analysis Branch Timothy Kiely, Chief 

# il**I~** Economic Analysis Branch 

# V'A**~** Biological and Economic Analysis ivision (7503 TO: Carrisa Cyran, Chemical Review Manager Pesticide Re-Evaluation Division (7508P)


### PRP Review Date: 

### July 27, 2011
The Pesticide Re-evaluation Division (PRD) received comments from the registrant ofTerbacil, Tessenderlo Kerley, Inc. (TKI) onthe BEAD Chemical Profile (BCP) prepared for registration review ofthe chemical. PRD requested that BEAD review and respond to the comments as appropriate. TKI commented that they disagree with the BEAD Chemical Profile analysis primarily on three general points, which are listed below with BEAD's accompanying response.TKl Comment 

### 1: The database utilizedbyBEAD (GjKKynetec)focused on some but not all crops that are important to terbacil in the UnitedStates; no data wasprovidedon two of the key uses ofterbacil (e.g., mint andblueberries). BEAD Response: The BEAD chemical profile (BCP) is a scoping level document that is intended to provide a broad overview ofpesticide usage information and the pest management roles ofpesticides that are beginning to undergo registration review. As such, specific usage for all registered sites may not be addressed. With regard to mint, it is important to note that none of the data sources available to BEAD, public or proprietary, survey mint growers. In previous discussions with EPA, TKI has acknowledged the lack ofusage data for mint and offered to provide its proprietary sales data ifneeded. The discussion with the registrant was very useful in highlighting the importance ofterbacil inmint and lowbush blueberry. This information will be considered as terbacil moves through the registration review· process. TKl Comment 

### 2: The BEAD analysis utilizeda 10year data span for its calculations, which is misleading considering the dramatic changes in terbacil usepatterns; the crop use information is datedandskewedtowards historical uses of terbacil rather that the currentproduct use. BEAD Response: The usage data in BEAD's BCP reflects a 10-year span because the purpose ofthe document is to provide a use pattern and a time period use trend. The registrant is correct in that the use pattern has changed inrecent years for crops such as sugarcane and peaches. The BCP reflects this information in the agricultural usage·section on page 5. Specifically, the document states that "Overthe 1998-2008 time period usage on sugarcane has decreased from a high ofmore than 50,000 Lbs. active ingredient applied to almost none." Additionally, the decrease in use onpeaches is reflected in the document onpage 5 where it states, "The use on peaches decreased by over 95 percent between 2007 and 2008." Ifthe registrant intends to submit latest usage information, the Agency will consider such information inthe re-registration process. TKl Comment 

### 3: BEAD didnotprovide a modern estimate of thepercent crop treated (PCT), which will be an important refinement for riskassessmentpurposes. BEAD Response: BEAD acknowledges the value ofthe PCT for risk assessment purposes. The PCT estimates are not within the scope ofthe BCP. However, the Agency welcomes PCT or any other relevant data that would be helpful for the re-registration process ofterbacil.