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 /l.~ k 0 . Biological Analysis Branch l ... , I ~ 

Sepehr Haddad, Environmental Protection Specialist /If _ ~ I. 4 

Science Information and Analysis Branch r~ 

Elizabeth Hill, Economist .~ 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 

Economic 

Timothy Kiely, 

Analysis 

Chief 

Branch 

il V'A I~ ~ 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 of Terbacil, 

Tessenderlo Kerley, Inc. (TKI) on the BEAD Chemical Profile (BCP) prepared for registration 

review of the 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 utilized by BEAD (GjK Kynetec) focused on some but not all 

crops that are important to terbacil in the United States; no data was provided on two of the key 

uses ofterbacil (e.g., mint and blueberries). 

BEAD Response: The BEAD chemical profile (BCP) is a scoping level document that is 

intended to provide a broad overview of pesticide usage information and the pest management 

roles of pesticides 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 of usage data for mint and offered to 

provide its proprietary sales data if needed. The discussion with the registrant was very useful in 

highlighting the importance ofterbacil in mint and lowbush blueberry. This information will be 

considered as terbacil moves through the registration review· process. 

TKl Comment 2: The BEAD analysis utilized a 10 year data span for its calculations, which is 

misleading considering the dramatic changes in terbacil use patterns; the crop use information 

is dated and skewed towards historical uses of terbacil rather that the current product use. 

BEAD Response: The usage data in BEAD's BCP reflects a 10-year span because the purpose 

of the document is to provide a use pattern and a time period use trend. The registrant is correct 

in that the use pattern has changed in recent 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 "Over the 1998-2008 time period usage on sugarcane has decreased from a 

high of more than 50,000 Lbs. active ingredient applied to almost none." Additionally, the 

decrease in use on peaches is reflected in the document on page 5 where it states, "The use on 

peaches decreased by over 95 percent between 2007 and 2008." If the registrant intends to 

submit latest usage information, the Agency will consider such information in the re-registration 

process. 

TKl Comment 3: BEAD did not provide a modern estimate of the percent crop treated (PCT), 

which will be an important refinement for risk assessment purposes. 

BEAD Response: BEAD acknowledges the value of the PCT for risk assessment purposes. The 

PCT estimates are not within the scope of the BCP. However, the Agency welcomes PCT or any 

other relevant data that would be helpful for the re-registration process of terbacil.