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: Tara Chandgoyal, Ph. D., and Plant Pathologist 

# kiut /l. ., ..**~** Biological Analysis Branch

### f,lllrl~ Cynthia Doucoure, Environmental Protection Specialist (;.

## ~ Science Information and Analysis Branch
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 Kiely, Chief

# ~**~. ~**  Economic Analysis 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 ofthis document is to convey usage information and a broad overview ofthe pest management roles ofpesticides that are beginning to undergo registration review. The anticipated audience consists ofthe team ofEPA staffcurrently evaluating the registration status ofchloropicrin, 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 ofOctober 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 ofcommodities 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 ortelone (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), golfcourse 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 ofchloropicrin 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 ofchloropicrin 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 ofchloropicrin were applied on average annually to 200,000 acres at an overall average application rate of60 lbs ail

### acre. The increase in average application rate 

### during this period is

- probably due to chloropicrin being used 

### at a higher percentage oftotal fumigant applied when it is used with methyl bromide and 1,3- dichloropropene. The top crops in

### terms ofpounds 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 

### oftotal area treated were the same; however the percentages of the area ofpeppers, strawberries, and tomatoes treated were lower than 

### the percentage ofpounds ai. 

### applied, implying higher than 

### average ai. 

### rates ofapplication. Conversely, the percentage of the total area oftobacco treated was higher than the percentage ofpounds ai. 

### applied, implying a lower than 

### average a.i. rate ofapplication 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 bl 1 

### Chl

.. U

a e 

# . orop1cnn 

# :r c se on· Oj) 

### rops: A

### verage A I Rat 

### 2007 2011 

# .. e, 

# -**ND l**  

### 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 

### ofpounds 

## a.i. applied during this period 

### were California (33%), Florida (28%), and North Carolina (20%). The top states in

### terms 

### oftotal area treated were the same; however the percentage ofthe total area treated with chloropicrin in

### California (17%) was 

### lower than 

### the pounds a.L applied, implying higher than**av~ge** 

### a.i. rates ofapplication on peppers, strawberries, and tomatoes. In

### North Carolina, the percentage ofthe total area treated (34%) was 

### higher than 

### the pounds a.i. applied, implying lower than 

### average a.i. rates ofapplication on tobacco. In

### Florida, the percentage ofthe total areatreated was slightly higher than 

### the pounds a.i. applied, implying slightly higherthan·average a.i. rates ofapplication on peppers, strawberries, and tomatoes.

PageS ofllFigure 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 ofusage is the use intensity. 

### In this analysis, the use intensity is expressed as the pounds a.i. applied per 1,000 acres ofland 

### in farms. This differs from the application rate, which is expressed as the pounds a.i. applied pertreated area. Figure Sspatially 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 CropReporting District (2007

- 2011)

Average Pounds Per 1,000 Acres of Farmland



# - <4

4·11 012·23**24~44** 45·70
This is a map ofagricultural 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 ofcounties. Pesticide usage is displayed as average pounds (for the years 2007-20II) per 1,000 acres offarmland 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 ofagricultural 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 ofa 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 non

### Page 7 ofllNative Americans was reported in the name ofthe 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 ofpesticide 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 ofpesticide use in the region ornon-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 offarmland) 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 ofthe 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) ofa crop or crops with a high application rate and frequency ofapplication. 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 ofAgriculture. 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 ofchloropicrin in nurseries and in floriculture. The three 

### most recent years of data 

### are found in 

### Table 2 

### below. Tabl 2 Chi 

### e . .. U . N 

### d Fl

. ulture T tal A 

### red and 

### Rate orop1cnn sem ursery an 

### one 0**~PPJI:** A 

### per 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 ofchloropicrin 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 workerprotection 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 ofchloropicrin (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 ofmethyl bromide. Chloropicrin has 

### many**q~ities** 

### ofmethyl bromide in killing soil-borne pests. Chloropicrin usage is expectedto 

### increase after methyl bromide phase out because it is 

### an alternative to methyl

- bromide.

WSTORY OFBEAD ASSESSMENTS FOR CHLOROPICRIN 

### Most ofthe BEAD work on chloropicrin has been 

### inthe

_ context ofbenefits assessments or impact-assessments for other fumigants including methyl bromide, -for. which chloropicrin could be 

### an alternative. In

. 2007, 

### BEAD conducted an assessment**ofbenefi~** 

### ofusing 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 ofthe crop treated onpeppers (20%), 

### strawberries (55%), 

### tobacco (20%), 

### and tomatoes (15%) 

### because these crops are 

### highly affected by soil-borne fungal pests.

Table 3: Assessment ofBenefits ofChloropicrin Soil Fumigation for Different Crops (2007). 

### Crop Title 

### Authon Cucurbits 

### Assessment ofthe 

### Benefits on Soil Fumigation Bill Chism and David with Chloropicrin, Methyl Bromi,de, and Metam Donaldson Sodium in Cucurbit production Eggplant 

### AssessmentofBenefits ofSoil Fumigation with Angel Chiri and David Chloropicrin, Metam 

### Sodium, and Methyl Donaldson Bromide in Eggplant Production Forest Seedlings 

### Assessment ofthe 

### Benefits ofSoil 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 ofSoil 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 ofthe Benefits ofSoil Fumigation Tara Chandgoyal and Jin with Metam Sodium and Chloropicrin in Onion Kim 

### Production

· Page 9 

### ofllOrchard Replant- 

### Assessment ofthe Benefits ofSoil Fumigation Leonard Yourman and Grapes 

### with Metam Sodium and Chloropicrin in 

### TJWyatt Orchard Replant ofGrapes Orchard Replant- 

### Assessment of

### the Benefits ofSoil Fumigation Leonard Yourman and Tree Nuts 

### with Metam Sodium and Chloropicrin in 

### TJWyatt Orchard Replant ofAlmonds and walnut Orchard Replant- 

### Assessment ofthe 

### Benefits ofSoil Fumigation LeonardYourman and PomeFruit 

### with Chloropicrin and Methyl Bromide in

### Pome TJWyatt Fruit Production Orchard Replant- 

### Assessment ofthe Benefits ofSoil Fumigation Leonard 

### Youiman and Stone Fruit 

### with Chloropicrin and Methyl Bromide in 

### Stone TJWyatt Fruit Production Ornamentals 

### Assessment ofthe Benefits ofSoil Fumigation Nicole Zinn and 

### Steve with Chloropicrin and Methyl Bromide, Metam Smeannan Sodium and dazomet in 

### Ornamental Production Pepper, Bell 

### Assessment ofthe Benefits ofSoil Fumigation Bill Chism and 

### David with Chloropicrin and Methyl Bromide, and Donaldson Metam**Sodi~** in

### Bell Pepper _production Potato 

### Assessment ofthe Benefits ofSoil Fumigation Tara Chandgoyal and with Metam Sodium in Potato Production Derek Berwald Strawberry Fruit 

### Assessment ofthe Benefits ofSoil Fumigation Leonard Yourman and with Chloropicrin and Methyl Bromide, and Steve Smearman Metam Sodium in Strawberry Fruitproduction Strawberry Nursery 

### Chloropicrin and Methyl Bromide, Metam Leonard Yourman and Sodium and dazomet Use in 

### Strawberry Nursery Steve Smearman Runner Production Sweet Potato 

### Assessment ofthe Benefits ofSoil FUmigation Sunil Ratanayake and with Metam Sodium and Chloropicrin 

### in Sweet Andrew Lee Potato Production Tobacco 

### Assessment ofthe Benefits ofSoil Fumigation Sunil Ratanayake and 

### with Chloropicrin, Methyl Bromide, and Metam Elisa Rim Sodium in

### Tobacco Production Tomato, Fresh 

### Assessment ofthe Benefits ofSoil Fumigation Nikhil Mallampalli and with Chloropicrin, Methyl Bromide, and Metam Elisa Rim Sodium in

### Tomato Production

In

### May 2009 US-EPA issued an

### Amendment ofthe 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:fuubl.epa.gov/oppref/section18/searchresult.cfm)

.
INFORMATION THAT MAY BE USEFUL FORBEAD'S FUTURE WORK ON 

### Page 

### 10 ofllCHLOROPICRIN

. . Additional information ontypieal chloropicrin use inthe non-agricultural sector would improve futme BEAD assessments ofthe importance ofchloropicrin and may be required as part ofthe registration review for this pesticide. Requested data should include, butnotbe limited to, application timing, application rate, application method, and application frequency.

CONCLUSION The chloropicrin overall average a.i. rate ofapplication has increased over time due to an increased reliance on chloropicrin as methyl bromide is phased out. Based onthis, it appears that growers 

### are finding chloropicrin beneficial as a fumigant to control soil-borne plantpests (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 ofAgriculture. http:/ /www.agcensus.usda.gov/Publications/2007 /index.asp. USDA, 2007. Census ofAgriculture. http://www.agcensus.usda.gov/Publications/2007 /index.asp

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

Page 

### 11 ofll