UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APR 19 Z013 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECf: BEAD Chemical Profile for Registration Review: Chloropicrin (081"501) 

FROM: 

TIIRU: 

TO: 

Biological 

Tara Chandgoyal, 

Analysis 

Ph. 

Branch 

D., and Plant Pathologist kiut f,lllrl~ /l. ., .. ~ 

Science 

Cynthia 

Information 

Doucoure, Environmental 

and Analysis Branch 

Protection Specialist (;. ~ 

Andrew Lee, Economist /J~ cA , 

Economic Analysis Branch ~ ~ ~ 

Biological and Economic Analysis D · ion (7503P) 

A-met Jones, Chief 

Biological Analysis Branch · 

Diann Sims, Chief Jfl~ Science Information and Analysis Branch 

Timothy 

Economic Kiely, Analysis 

Chief 

Branch ~ 1 !. ~. '\1\.. ~ 

Biological and Economic Analy s Division · 3P) 

Andrea Mojica, Chemical Review Manager 

Risk Management and Implementation Branch 4 

Pesticide Reevaluation Division (7508P) 

Product Review Panel date: October 24, 2012 

Page 1 ofll 
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 

of chloropicrin, and eventually the general public. This document builds upon the Label Use 

Information System (LUIS) reports and the Screening Level Usage Analysis (SLUA) that BEAD 

also provides to the Registration Review teams. The document is based on information and data 

available to BEAD as of October 24, 2012. 

Chloropicrin is a broad spectrum fumigant with fungicidal, herbicidal, insecticidal, nematicidal, 

and bacteriocide/bacteriostat properties that is often combined with other fumigants to broaden 

the pest control spectrum. Chloropicrin was initially registered in the U.S. in 1975 for use on 

agricultural crops/soils, greenhouse soils, and ornamentals, as wood protection treatments, and 

for enclosed space fumigation. However, under the Reregistration Eligibility Decision (RED) 

for chloropicrin issued in 2008 and amended in 2009, structural greenhouse and/or enclosed 

space fumigation of commodities or other uses were canceled and additional restrictions were 

added for the pre-plant soil uses. 

COMMON FORMULATIONS AND APPLICATION METHODS 

Chloropicrin is commonly formulated alone or with methyl bromide or tel one (1 ,3- · 

dichloropropene) as an emulsifiable concentrate, soluble concentrate/liquid, liquid ready to use, 

or as pressurized gas and applied as a pre-plant soil fumigation and soil broadcast treatment. 

Chloropicrin is applied using tractor-mounted and other soil fumigation injection equipment, 

shanks, chisels, or plowsoles, drip irrigation, hand operated soil injection equipment, and the 

encapsulated vial method. 

USE SITES 

Agricultural Use Sites: 

Chloropicrin is registered for use as an agricultural pre-plant soil fumigant for crops including 

beans, beets, bell peppers, caneberries, carrots, citrus, cole crops, cucumber, cucurbit vegetables 

such as melons, deciduous fruit trees, eggplant, field crops such as com, soybeans, and sugar 

beets, fruits unspecified, ginger, grapes, hops, legume vegetables, lettuce, mint, onions, 

orchards, peanuts, pepper, pineapple, potatoes, radish, stone fruit, strawberry, sweet potatoes, 

tomatoes, tree nuts, yams, and vegetables unspecified. 

Other registered non-food sites include Christmas tree plantations, conifers, forest nursery 

plantings (for transplant purposes), forest plantings (reforestation programs), golf course turf, 

nonagricultural uncultivated areas/soils, nursery stock, ornamental and/or shade trees, 

ornamental grasses, ornamental herbaceous plants, ornamental lawns and turf, ornamental 

nonflowering plants, ornamentals unspecified, ornamental woody shrubs and vines, potting 

soiVtop soil, recreation area lawns, preplant soil, tobacco, and wood protection treatment to 

buildings/products outdoor, forest products (seasoned), and aquatic structures/items. 

Page 2 ofll 
USAGE 

Agricultural Use Trend. 1998-2011 

Available data on use of chloropicrin in the U.S., as found in private market surveys, show that 

that the pounds a.i. applied increased between_1998 and 2011 as shown in Figure 1. The total 

area treated (acres) with chloropicrin increased steadily until2004, after which the acre 

treatments declined with slight increases in recent years as shown in Figure 2. Approximately 10 

million pounds of chloropicrin were applied on average annually to 200,000 acres at an overall 

average application rate of 50 lbs ail acre. 

Figure 1-: Chloropicrin: Pounds A.l. Applied, 1998-201 1 

0 +-~-r~------~~-r------r-~,--r~~ 

_p,fb ..A ...D ~"' ~'\. ~, r:l' ~<, ~C'o ,$- ~fb ..0 ~~ ~"' ~- ~J '\.~ '\...,... '\...,... ~- ~ '\...,... ~ "\)" ~- '\.~ ~ ~ 

Year 

Source: EPA Proprietary Data, 1998-2011 

Page3 ofll 
Fi 

J 

J 

J 

0 +-~~~r-~,-~~~~,--r~--.-~~ 

~OJfb $'0) ,# ,r§'"" ,r§'"' ,r§'~ ,# ,r§'~ ,# -1 ,# ,# ~...,~ ~...,..., 

Year 

Source: EPA Proprietary Data, 1998-2011 

A&ricultural Use 2007-2011 

During the 2007-2011 timeframe, approximately 12 million pounds of chloropicrin were applied 

on average annually to 200,000 acres at an overall average application rate of 60 lbs ail acre. The 

increase in average application rate during this period is-probably due to chloropicrin being used 

at a higher percentage of total fumigant applied when it is used with methyl bromide and 1,3-

dichloropropene. The top crops in terms of pounds a.i. applied during this period were 

strawberries (33%), tobacco (20%), tomatoes (17%) and peppers (11 %) as shown in Figure 3 

below. The top crops in terms of total area treated were the same; however the percentages of 

the area of peppers, strawberries, and tomatoes treated were lower than the percentage of pounds 

ai. applied, implying higher than average ai. rates of application. Conversely, the percentage of 

the total area of tobacco treated was higher than the percentage of pounds ai. applied, implying a 

lower than average a.i. rate of application as shown in Table t ·below. 

Page4ofll 
Figure 3. Chloropicrin Use: Top Crops, 2007-2011 

/ Pound~ A.l. Applied r-----11-bta-l A-r-ea-Tr-ea-t-ed---...., 

Source: EPA Proprietary Data, 2007-2011 

Other crops include almonds, apples, beans, cabbage, caneberries, cantaloupes, carrots, cherries, cotton, 

cucumbers, wine grapes, onions, oranges, peaches, peanuts, plums/prunes, potatoes, pumpkins, squash, 

sugar beets, sweet corn, walnuts, and watermelon. 

T a e bl 1 . Chl orop1cnn .. U se on· :r Oj) c rops: A verage A I .. Rat e, 2007 -2011 

NDl Al!R• M Rate,(lbl Lhla,erel 

Peppers 71 

. S1rawbenies 108 

Tobacco 30 

Tomatoes 67 

Source: EPA Propnetary Data, 2007-2011 

The top states in terms of pounds a.i. applied during this period were California (33%), Florida 

(28%), and North Carolina (20%). The top states in terms of total area treated were the same; 

however the percentage of the total area treated with chloropicrin in California (17%) was lower 

than the pounds a.L applied, implying higher than av~ge a.i. rates of application on peppers, 

strawberries, and tomatoes. In North Carolina, the percentage of the total area treated (34%) was 

higher than the pounds a.i. applied, implying lower than average a.i. rates of application on 

tobacco. In Florida, the percentage of the total area treated was slightly higher than the pounds 

a.i. applied, implying slightly higher than·average a.i. rates of application on peppers, 

strawberries, and tomatoes. 

PageS ofll 
Figure 4. Chloropicrin Use: Top States, 2007-2011 .---------------------------~, 

Pounds A.l. Applied Total Area Treated 

It 

Source: EPA Proprietary Data, 2007-2011 

Other states include AL, AR, AK., CO, GA, ID, IN, KY, MI. NE, NM. NY, OR, PA, SC, 1N, TX, VA, 

andWA. 

Agricultural Usage by Crop Reporting District 

Another measure of usage is the use intensity. In this analysis, the use intensity is expressed as 

the pounds a.i. applied per 1,000 acres of land in farms. This differs from the application rate, 

which is expressed as the pounds a.i. applied per treated area. Figure S spatially represents 

chloropicrin's use intensity in the U.S., which is relatively greater in California, Florida, and 

North Carolina. 

Page6ofll 
Figure 5. Chloropic:rlll Usage by Crop Reporting District (2007 - 2011) 

Average Pounds Per 

1,000 Acres of Farmland 

- <4 

4·11 

012·23 

24~44 

45·70 

This is a map of agricultural pesticide usage at the Crop Reporting District (CRD) level prepared by BEAD 

for use in the Environmental Fate and Effects Division documents. These maps are used to help visualize 

where the pesticide being considered is most likely to be used and can be helpful in scenario selection and 

plac.ing the ex:pOsure assessment. in context. CRDs are boundaries created by USDA NASS which are 

aggregates of counties. Pesticide usage is displayed as average pounds (for the years 2007-20II) per 1,000 

acres of farmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acieage was 

obtained from USDA (2007). Farmland or "land in farms" is defined as follows: 

The acreage designated as "land in farms" consists primarily of agricultural land 

used for crops, pasture, or grazing. It also includes woodland and wasteland not 

actually under cultivation or used for pasture or grazing. provided it was part of 

the fium. operator's total operation. Large acreages of woodland or wasteland 

held for nonagricultural purposes were deleted from individual reports during 

the edit process. Land in farms includes CRP, WRP, FWP, and CREP acres. 

Land in farms is an operating unit concept and includes land owned and 

operated as well as land rented from others. Land used rent free was reported as 

land rented from others. All grazing land, except land used under government 

permits on a per-head basis, was included as "land in farms" provided it was 

part of a farm or ranch. Land under the exclusive use of a grazing association 

was reported by the grazing association and included as land in farms. All land 

in American Indian reservations used for growing crops, grazing livestock, or 

the potential of grazing livestock was mcluded as land in farms. Land in 

reservations not reported by reservation, individual American Indians or nonPage 7 ofll 
Native Americans was reported in the name of the cooperative group that used 

the land. In many instances, an entire American Indian reserv!ltion was reported 

as one farm (USDA, 2007). 

Usage is based on private market surveys of pesticide use in agriculture (Proprietary Data, 2007-2011). The 

survey data are limited to the states that represent the top 80-90% of acreage for the indi~dual crops, 

therefore, use may be occurring in regions outside the scope of the survey. CRDs showing no usage of 

pesticides may be due to either the lack of pesticide use in the region or non-participation in the· agricultural 

surveys. In addition, across the years, there may be variations in the specific crops included in the CRD 

survey. This may result in a lower annual average for the CRD. 

This map displays ratio data (ie., average pounds per 1,000 acres of farmland) summarized at a very highlevel. Readers are strongly cautioned against trying to over interpret the map without examination of the 

underlying data. The underlying data may explain some of the many reasons that a Crop Reporting District 

may have a high value for a particular active ingredient such as significant acreage (compared with the CRD 

as a whole) of a crop or crops with a high application rate and frequency of application. 

The reader should pay particular attention to the figure legends and realize that a map prepared for a 

particular chemical is not directly comparable to a map prepared for a different chemical. Scale and units of 

measurement do matter and may be different between maps. 

Sources: 

Proprietary Data. 2007-2011. 

USDA, 2007. Census of Agriculture. Online: http://www.agcensus.usda.gov/Publications/2007/index.asp. 

Non-Agricultural/Non-Food Usage 

BEAD reviewed available sources for non-agricultural usage information and found that USDA 

NASS surveys use of chloropicrin in nurseries and in floriculture. The three most recent years of 

data are found in Table 2 below. 

Tabl e . 2 Chi .. U . N orop1cnn sem ursery an d Fl one . ulture T 0 tal A ~PPJI: red and Rate per A ere 

Y• PQUri48, .I. Appli¢ Avg:A.I. Ra~ ~lb, Li~aci'e ) 

2003 255,000 121.6 

2006 253,600 122.9 

•2009 433,500 105.4 . Source: USDA NASS Agricultural Chemical Usage Reports, Nursery & Floriculture, 2003, 2006, and 

2009. 

Future Use 

Future use of chloropicrin may be impacted by additional regulations (EPA, 2008) that went into 

effect in December 2012. These include buffer zones, restricted entry into the treated zone, 

Good Agricultural Practices, and additional worker protection standards. Also, further 

reductions in methyl bromide use may result in increased reliance on chloropicrin. 

BIOLOGICAL ASPECTS RELEVANT TO CHLOROPICRIN 

Page 8 ofll 
Chloropicrin is a non-selective fumigant biocide. It is used as a preplant soil fumigant to kill soil 

dwelling pests. It is also used in.combination with methyl bromide or 1,3-dichloropropene as 

~lant soil fumigant to kill soil-borne pests. It is also applied with dimethyl disulfide (DMDS). 

The non-agricultural use of chloropicrin (nursery and floriculture) also involves soil fumig~tion 

for killing soil-borne pests. The recent increase in chloropicrin use (2007~2011) for soil 

fumigation is probably due to methyl bromide phaseout (http://www.epa.gov/ozonelmbrD. The 

growers are experimenting with alternatives of methyl bromide. Chloropicrin has many q~ities 

of methyl bromide in killing soil-borne pests. Chloropicrin usage is expected to increase after 

methyl bromide phase out because it is an alternative to methyl-bromide. 

WSTORY OF BEAD ASSESSMENTS FOR CHLOROPICRIN 

Most of the BEAD work on chloropicrin has been in the _context of benefits assessments or 

impact-assessments for other fumigants including methyl bromide, -for. which chloropicrin could 

be an alternative. In.2007, BEAD conducted an assessment ofbenefi~ of using chloropicrin on 

17 different crops listed in Table 3. Chloropicrin has been documented to have excellent efficacy 

against soil-borne plant pathogenic fungi. It is often used in combination with methyl bromide or 

metam sodium and/or 1 ,3-dichloropropene for a wider plant pest control (fungi, nematodes, 

insects and w~ed.s). Among the major crops, chloropicrin seems to have very high benefits as 

evidenced by the average percent of the crop treated on peppers (20%), strawberries (55%), 

tobacco (20%), and tomatoes (15%) because these crops are highly affected by soil-borne fungal 

pests. 

Table 3: Assessment of Benefits of Chloropicrin Soil Fumigation for Different Crops (2007). 

Crop Title Authon 

Cucurbits Assessment of the Benefits on Soil Fumigation Bill Chism and David 

with Chloropicrin, Methyl Bromi,de, and Metam Donaldson 

Sodium in Cucurbit production 

Eggplant Assessment of Benefits of Soil Fumigation with Angel Chiri and David 

Chloropicrin, Metam Sodium, and Methyl Donaldson 

Bromide in Eggplant Production 

Forest Seedlings Assessment of the Benefits of Soil FUmigants John Faulkner and 

(Methyl Bromide, Chloropicrin, Metam Sodium, Leonard Yourman 

and Dazomet) Used by Forest Tree Seedling 

Nurseries Production 

Nursery, Fruit, Nut, Assessment ofthe Benefits of Soil Fumigation Leonard Yourman and 

&Rose with Chloropicrin, Dazomet, Metam Potassium Steve Smearman 

and Metam Sodium Use for Fruit and Nut 

Deciduous Tree Nurseries and Rose Bush 

Nurseries in California 

Onion Assessment of the Benefits of Soil Fumigation Tara Chandgoyal and Jin 

with Metam Sodium and Chloropicrin in Onion Kim 

Production 

· Page 9 ofll 
Orchard Replant- Assessment of the Benefits of Soil Fumigation Leonard Yourman and 

Grapes with Metam Sodium and Chloropicrin in TJWyatt 

Orchard Replant of Grapes 

Orchard Replant- Assessment of the Benefits of Soil Fumigation Leonard Yourman and 

Tree Nuts with Metam Sodium and Chloropicrin in TJWyatt 

Orchard Replant of Almonds and walnut 

Orchard Replant- Assessment of the Benefits of Soil Fumigation Leonard Yourman and 

PomeFruit with Chloropicrin and Methyl Bromide in Pome TJWyatt 

Fruit Production 

Orchard Replant- Assessment of the Benefits of Soil Fumigation Leonard Youiman and 

Stone Fruit with Chloropicrin and Methyl Bromide in Stone TJWyatt 

Fruit Production 

Ornamentals Assessment of the Benefits ofSoil Fumigation Nicole Zinn and Steve 

with Chloropicrin and Methyl Bromide, Metam Smeannan 

Sodium and dazomet in Ornamental Production 

Pepper, Bell Assessment of the Benefits of Soil Fumigation Bill Chism and David 

with Chloropicrin and Methyl Bromide, and Donaldson 

Metam Sodi~ in Bell Pepper _production 

Potato Assessment of the Benefits of Soil Fumigation Tara Chandgoyal and 

with Metam Sodium in Potato Production Derek Berwald 

Strawberry Fruit Assessment of the Benefits of Soil Fumigation Leonard Yourman and 

with Chloropicrin and Methyl Bromide, and Steve Smearman 

Metam Sodium in Strawberry Fruit production 

Strawberry Nursery Chloropicrin and Methyl Bromide, Metam Leonard Yourman and 

Sodium and dazomet Use in Strawberry Nursery Steve Smearman 

Runner Production 

Sweet Potato Assessment of the Benefits of Soil FUmigation Sunil Ratanayake and 

with Metam Sodium and Chloropicrin in Sweet Andrew Lee 

Potato Production 

Tobacco Assessment of the Benefits of Soil Fumigation Sunil Ratanayake and 

with Chloropicrin, Methyl Bromide, and Metam Elisa Rim 

Sodium in Tobacco Production 

Tomato, Fresh Assessment of the Benefits of Soil Fumigation Nikhil Mallampalli and 

with Chloropicrin, Methyl Bromide, and Metam Elisa Rim 

Sodium in Tomato Production 

In May 2009 US-EPA issued an Amendment of the 2008 Re-registration Eligibility Decision 

(RED) for chloropicrin (http://www .epa.gov/pesticides/reregistrationlchloropicrinl). 

Section 18s Status: BEAD did not find any active section 18 on this fungicide 

(http:/ /c:fuub l.epa.gov/oppref/section 18/searchresult.cfm). 

INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON 

Page 10 ofll 
CHLOROPICRIN 

. . 

Additional information on typieal chloropicrin use in the non-agricultural sector would improve 

futme BEAD assessments of the importance of chloropicrin and may be required as part of the 

registration review for this pesticide. Requested data should include, but not be limited to, 

application timing, application rate, application method, and application frequency. 

CONCLUSION 

The chloropicrin overall average a.i. rate of application has increased over time due to an 

increased reliance on chloropicrin as methyl bromide is phased out. Based on this, it appears 

that growers are finding chloropicrin beneficial as a fumigant to control soil-borne plant pests 

(fimgi, weeds, nematodes, insects, and rodents), especially when used in combination with 

methyl bromide, 1,3-dichloropropene or DMDS. 

REFERENCES 

EPA Proprietary Data, 1998-2011 

EPA. 2009. Amended Registration Eligibility Decision (RED) for Chloropicrin, May 27,2009. 

http://www.epa.gov/pesticides/reregistrationlchloropicrinl 

USDA, 2006-2010. NASS Crop Reporting Districts. 

http://www.ers.usda.gov/briefinglarms/resourceregions/resourceregions.htm#nass. 

USDA, 2007. Census of Agriculture. 

http:/ /www.agcensus. usda.gov/Publications/2007 /index. asp. 

USDA, 2007. Census of Agriculture. 

http://www .agcensus.usda.gov/Publications/2007 /index.asp. 

USDA, 2003, 2006 and 2009. NASS Agricultural Chemical Usage Reports, Nursery & 

Floriculture 

Page 11 ofll