UNITED STATES ENV I RONMENTAL PROTECTION A G EN CY WASHINGTON , D

. C

. 20460 

### MAR 13 

## 2014

OFFICE OF CHEMICA L SAFETY AND POLLUTION PREVENTION MEMORANDUM SUBJECT:
FROM:

THRU:

TO : BEAD Chemical Profile (BCP) for Registration Review: Triclopyr Case(116001, 116002, 116004) Sunil Ratnayake, Biologist

# ~ .

# ~**~ ~**  Biological Analysis Branch \_

### ~ \ Sepehr Haddad, Environmental Protection Specialist

# h./~ Science Information and Analysis Branch 

## 1 S tephen Smearman , Economist Economic Analysis Branch Biolog ical and Economic Analysis Division (7503P) Amet Jones , Chief /.)

# 11)~~ Biological Analysis Branch

# ~ Diann Sims, Chief

# J.{l~~ Science Information and Analysis Branch Timothy Kiely, Chief

### ~ Economic Analysis Branch 

# \J. )**~** Biological and Economic Analysis Divisi 3P) Steve Snyderman, Chemical Re view Manager Pesticide Re-evaluation Division (750 8P)

Peer Review Panel date: January 15, 2014SUMMARY Triclopyr was first registered in the United States as an herbicide in 1979 (USEPA, 1998). This is a systemic herbicide that belongs to the pyridine carboxylic acid family and it is used as a post-emergence herbicide to contro l annual and perennial broadleaf weeds and woody plant species in many agricultural and non-agricultural use sites. Triclopyr acts like a plant growth regulator by mimicking natural plant growth hormones (auxins). According to the Weed Science Society of America (WSSA) mechanism of action ofherbici des , triclopyr belongs to the Group 4 herbicides (synthetic auxins). Applications oftriclopyr at effective rates causes uncontrolled ce ll division and disorganized p lant growth that leads to plant death. Based on private market usage data from 1998

-2012 , usage averaged approximate ly 1.3 million pounds acid equivalent (a.e.) applied annually on approx imately 2.75 million acres treated. The ma j or agricultural use sites are pasture and rice which account for approximately 98 percent of all agricultural usage. INTRODUCTION The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an overview of the pest management roles and quantitative usage information for triclopyr. The BCP includes summaries of previous BEAD products and available public and/or private use and usage data for triclopyr to describe the rol e of this chemical in pest management. Additional informat ion on use is available in the triclopyr LUIS Label Data Report. Information provided in this BCP may be used by stakeholders (e.g., users and registrants) , OPP risk assessors, OPP risk managers, and the general public during the Registration Review process of this pesticide. USE SITES Agricultural Use Sites Triclopyr registered agricultural use sites include: a lfalfa, almonds, apples, asparagus, beans, beech nut, blackberries, brazil nut, cashews, chestnuts , cole crops, citrus trees , conifer release, Christmas tree plantin gs, corn (field , pop , and sweet) , flax, hazelnuts , lentils , macadamia nuts , mint , oats, onions , pastures, peas, pecans , pistachio nuts , potatoes , rice, safflower, sorghum , soybeans, strawberries, sugar beets, sunflower, vegetable crops, walnuts, wheat, and yucca as well as acreage enro lled in the co nservati on reserve program (CRP). Non-Agricultural Use Sites Registered non-agricultural use sites of triclopyr include: agricultural buildings, airports, cabins, camp sites, canals, domestic dwellings, patios, fencerows, forest l ands, industrial sites, ornamental woody plants , ornamental lawns, ornamental turf , ornamental trees , farm buildings , aquatic areas , wetlands, rights-of-way , and recreational areas.

Page2FORMULATIONS AND APPLICATION METHODS Triclopyr formulations include soluble concentrate, emulsifiable concentrate, liquid (pressurized and ready-to-use) , granular, wettable powder, and pelleted. Ground and aerial are the application methods of this chemical. HISTORY OF TRICLOPYR and BEAD PRODUCTS Triclopyr was first registered in 1979 as an herbicide for control of broadleaf weeds and woody plants in non- crop and forestry areas. Triclopyr was reregistered in 1997. A Screening Level Usage Analysis (SLUA) was prepared by BEAD .for this chemical in 2013 that provides the percent crop treated for 10 crops for which usage data was available (alfalfa, apples, corn , fallow, haze lnuts, oranges, pasture, pecans , rice and wheat). For triclopyr, based on the SLUA, there are two agricultural sites with th e greatest number of pounds used. The sites are pasture with nearly 90% of the use followed by rice. Benefits Assessments- A search of BEAD's Official Records data base for BEAD benefits assessments specifically for triclopyr did not find any records ofprior BEAD assessments in the last 10 years. Emergency Exemp tions

- a search of BEAD's Official Records did not find any Section 18s requests for triclopyr in the last 1 0 years. Emergency exemptions may indicate that there is a need for a particular c hemical that is not registered for use on a particular site. App roval of an emergency exemption request may yield information through the emergency exemption process about a particular chem ical' s importance or value that is not found in other EPA records. However, a lack of Section 18 assessments by BEAD doe s not specifical ly indicate the relative importance of the chemical.

USAGE Agricultural Usage Based on private market usag e data from 1998-2012, usage averaged approximately 1.3 million pounds acid equivalent (a.e.) applied annually on approximately 2.75 million acres treated. The average a.e. rate over this time period was 0.475 pounds a.e ./ acre. Figure 1 presents triclopyr usage in pounds a.e. and total area treated in acres over the 1998-2012 timeframe (Proprietary Data, 1998-20 12). F igure I shows that over this time period in terms of pounds applied and acres treated there has been a steady decline in use.

Pag e 3

### FIGUREl. Triclopyr Usage in Pounds Acid Equivalent & 

### Total Area Treated in Acres (1998-2012) 4500000

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## ,_cs ,_cs ,_cs ,_cs ,_cs ,_ cs ,_ cs 

## ,_cs ,_cs ,_<::> ,_<::> ,_<::> Years Source: Proprietary Data, 1998-2012 -+- Pounds AE**Tot<~** I Are<t Tre<tted



### Table 

### 1. Comparison of Crops with Highest Use of Triclopyr- Percent of Total Lbs. Applied 2003-2007 and 2008-2012) 2003-2007 2008-2012 Average annual= l million lbs/yr Average annual = 1.2 million lbs/yr 

### Crop %Lbs Crop %Lbs Pasture 90% Pasture 89%

Rice 8% Rice 9% Pecans l% Fallow l% Oranges 1% Oranges 1% Source: Propnet.ary Data, 2003 -2012. Table 1 s hows that the crops with the most pounds applied during both the 2003-2007 and 2008- 201 2 timeframes have been pas ture and rice accounting for approximately 98 percent of total pounds applied. The average annual usage in pounds has increased approximately 20 percent from 1 million lbs/year to 1.2 million pound s per year in the 2008-2012 timeframe.

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### Table 2. Comparison of States with Highest Use of Triclopyr- Percent of Total Lbs. Applied (2003-2007 

### and 2008

- 2012) 2003-2007 2008-20 1 2 Average annual= I million lbs/yr Averag e annual = l.2 million lbs/yr 

### State % L bs State %Lbs Texas 28% Tex as 24% Oklahoma 15% Oklahoma 18% Arkansas 9% Arkansas 12% Alabama 6% Mis so uri 8% Missouri 6% Georgia 5%

Other* 36% Other* 33% *Other S tates in the 20 03-2007 a nd 200 8-201 2 tim eframes include Florida, Ten nessee, California , Kan sas , Virginia , Loui s iana and more t h an 20 other s tates. Source : Propnetary Data , 2003

- 2012
As s hown in Table 2, Texas , Okla homa and Arkansas were the top three states with the highest us e of triclopyr in both time frames accounting for more than 50 p ercent of total pounds appli ed. Application Rates The average a. e. rate for the top crops in t e rms ofpounds a. e. applied was the hi g hest for p asture at 0.50 lbs a. e./ac re and the lowe st for rice at 0.19 lb s a.e./acre as s hown in Table 3.
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### I

a e 

# . nc opyr 

## u se on 

### T C op rops: A**vera~** 

### e A E R t 2008 2012 

# . . a e, 

# - Annual Average Annual Average Avg. A.E. Rate (lbs Crop Pounds Total Acres a.e./acres) Treated* Pastur e 872 ,000 1 , 719 ,200 0.50 Rice 88 ,290 453 ,5 00 0.19 *Total Acres Treated s ums all acres treated for a cro p , mcludm g those acres th at receive mu lt ip le treatments. Source: Proprietary Data, 2008 -2012
Geographic Distribution of Triclopyr Use Figure 2 pro vides a very broad geogra phi cal view of the average annual amount (in pound s) o f t ricl o pyr applied per 1,000 acres of crop acres grown. T hese data are inclu ded in the map s bec au se risk assessors are inte rested in t he amount of a pesticide use d across agricu ltural land. The calculated values presented in th e map are not equiva lent to an applicati on rate (lb 

### ailA) , therefore , the map may s ho w areas of high use intensity that do not correspond to the states li sted in Table 2 since those states (suc h as T exas , Oklahoma and Arkansas for example ) are the states with the highe st use oftriclopyr based on pounds activ e ingredient applied. As s ho wn in the map , th e southern states espec ially Florida, Georgia , Alabama , Arkans a s and Page 5Oklahoma, in addition to Texas and California, depict a high use intensity of acres treated with triclopyr. Please see Appendix I for a more detailed explanation of the information presented on the map. 

### FIGURE 2. Triclopyr Usage by State (2008 -2012)

Pounds Active Ingredient per 1.000 Crop Acres Grown 0 No0ala <03

. 0. 3 · 0.6

. 0

.7 ·1 9

. 2

.0·6-9

- >69 Non-Agricultural Usage Most available non-agricultural usage data for triclopyr is limited and dated. The only reported data available are for the years 2002, 2004, 2006 (for land scaping, lawn care operators, golf cours es, ins titutional turf, nursery/greenhouses, and turf farms) aquatic uses and consumer lawn s for 2005, and the most recent for consumer l awns in 2011 as shown in Table 4. Total nonagricultural usage between 2002 and 2006 appears to have declined for golf courses, turf farms , and landscape , but increased for nursery/greenhouse; however , more recent data (post-2006) are not available to determine if this trend has continued since only one category of non-agricultural usage (consumer lawns) was available for 20 11.

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### Table 4. T riclopyr Non

-Ag ricultural Usage (Pounds A.E ) (2002-2011 Site 2002 2004 2005 2006 2011 Golf Courses 76 ,000 31 , 300 

### N I A 20 , 000 N/A Ins titutional Turf 76 ,5 00 61 ,200 

### NIA 63 , 3 00 N/A Landscape 3 1 9 , 000 64 , 100 

### N I A 84 , 700 

### NI A Lawn Care Operators 113 , 000 80 , 800 

### N I A 90,700 

### N I A Nursery / Greenhouse 1 , 500 3 , 750 

### N I A 11 , 950 

### N I A Turf F arm s 3 4 ,350 100 

### NIA 1 2 , 65 0 

### NIA Aquatic Areas 

### N I A N I A 44 , 000 

### N I A N I A Consumer Lawns 

### N I A N/A 1 52 , 000 N /A 100 , 000 N

/A = Not Available Source: Proprietary Data 2002-2011


### BIOLOGICAL ASPECTS RELEVANT TO TRI CLOPYR Triclopyr is a selective and systemic herbici de that belongs to the pyridine carboxylic acid family. Aminopyralid, fluroxypyr, and clopyralid are other h erbicides that belong to the pyridine carboxylic acid fami ly. Triclopyr is applied as a post-emergence treatment to control annual and perennial broad leaf weeds and woody plant species in many agric u ltural and non-agricultural use sites. According to the Weed Science Society of America (WSSA) mechanism of action cl ass ificat ion , triclopyr b elongs to the group of synthetic auxins (Group 4) (WSSA, Undated). Th e se herbi cides act like natural plan t gro wth regu lators by mimicking natural plant growth hormones. Triclopyr i s absorbed by the p lants through foliage and roots and translocated throughout the p lant (Her bi cide Handbook , 2003). Applicatio n ofherbicides belonging to group 4 causes uncontro lled cell devision leadin g to the death of susceptible plants It h as been reported that biotyp es of 8 we ed species have developed re sistance to triclopyr in th e United States (Hea p , Weedsc ience.org , Undated Onli ne publication). 

### ROLE OF TRICLOPYR IN PEST MANAGEMENT Tri clopy r can be app lied for controlling woo d y plants, annual and perennial broad leaf weed s, in fores t areas , grass pastures , range lands , conifer release program s, and con servation reserve programs (Herbicide Hand Book, 2007). During the period from 2008 to 2012 a higher percentages of average annual use (lb s a.i.) of triclopyr were ob served on pasture (89 

### %) and in rice production (9 %) (Tabl el)

. The higher usage of this herbicide on pasture indicates that triclopyr is an important herbicide for management o f unnecessary woody species , shrub s , and other broadlea f weed s in pasture land s. In rice production, triclopyr is used to cont ro l many broadleafweed species including, momin gglory 

### (Ipomoea spp.) , Hempsesbania , 

### (Sesbania exaltat a) , north ern jointwetch 

### (Aeschynomene virginia) and Texas weed 

### (Caperonia palustrus). In rice production, to achieve a broader spectrum of weed control triclopyr can be tank mixed with ot h er herbicides suc h as propanil (Street et al. , undated) In terms ofthe percent crop treated, all sites in the SLUA had values o f les s t h an 1 percent , except for pasture with le ss than 2.5 percent, and rice at 15 perc ent of crop t reated

. This ind icates that triclopyr provides benefits to the growers of these crops especiall y pasture and rice. Page 7DATA NEEDS The Agency currently do es not have complete information for triclopyr. Obtaining the following information may imp rove future assessments conducted by the Agency related to the use and importance oftriclopyr. Agricultural Use BEAD proprietary databases do not contain s urvey data on registered agricultural s ites such as cashews, flax , lentils , mint and macadamia nuts. Usage data such as pounds a.i. applied and application rate information would be useful if available Non Agricultural Use Except for recent usage data on consumer lawns in 2011, BEAD does not have recent (post-2006) data on non-agricultural usage for the following: golf courses, institutional turf, landscaping, nursery/greenhouses, and turf farms. Usage data such as pound s a.i. applied and application rates would be useful if available.

Page 8

### REFERENCES Alligare Triclopyr 4 , Specimen Label. 2013. Alligare, LLC. 13 N. 8 1h Street, Opelika, AL 36801. http: //www.alligare.com/assets/pdfffRICLOPYR 4 LABEL.pdf BEAD , 20 1 3. Tr icl o p yr Screening Level Usage Analysis. Biological and Econo mic Analysis Division, Office of Pes ticide Program s, US Environmenta l Protection Agency. 2013 Heap, I. (Undated) The International Survey of Herbi c ide Resistant Weeds. Online. Internet. Tuesday , February 11,2014. Available www.weedscience.org

. . Accessed Da te
. Jan. 8, 201 4. Herbicide Handbook. 2003. Guidance on the use of herbicide s on nature conservation sites, Sec tion s 1-4. Triclopyr. Pp 107

- 108. http: /l publications.naturalengland.org.uk/publication/68019

. Accessed Date. Nov. 18 , 2013. Proprietary Data , 2002

- 2 011 (non-agricultural usage data) Nicker son, C. , R

. Borchers, E. A. and F

. Carriazo

. 2011. Major Uses of Land in the Unite d States , 2007. US DAIERS. Economi c Inf ormation Bull etin Number 89. Proprietary Data. 19 98

- 20 1 2. (pesticide agricultural usage data) Street, J. , Alle n R

. L. , and E. M. Johnston. (No Date). Weed Control in Rice with Propanil and Triclopyr Combinat ions . Delta Research and Extension Center. On line Publication. Availab le at: http: //msucares.com/pubs/bulletins/b 1 035.pdf. Accessed Date. Feb. 10 , 201 4. US Cen s us . 20 1 2

. Statistical Abstract of the United States 2012. Tab le 358. USEPA. 1998. Reg i s tration E ligibility Decision

. Triclopyr

. http: //www.epa.gov /oppsrrd 1 /REDs/27 1 Ored.pdf. Accessed D ate
. Nov. 25, 2013. USDA , 2006

-20 10. NASS Crop Reporting Di stricts (shape fi le ofCRDs). Avai lable at: http: //www.ers.usda.gov/briefing/arms/resourceregions/resourceregions.htm#nass

. USDA , 2006-20 I 0. NASS Crop Reporting Di stric ts. Online: http: //www.nass.usda.gov/Data and Statistics/County Data Files/Frequently Asked 

### 0 uestions/county list.txt USDA , 2007. Census of Agriculture. Online : http: //www .agcensus.usda. gov /Publications/ 2007 / index .asp .

Page 9USDA , 2007. Census of Agricu lture. (fo r Land in Farms data)

. Avai lable at: http: //www .agcensus.usda.gov/Pub lications / 2007/index.asp

. WSSA(Weed Science Society of Amer ica , Undated)

. Summary of Herbicide Mechanism of Ac tion. Weed Science Society of America. Available at: http: // wssa. net/wp

content / uploads/WSSA

-Mechani sm-of-Action.pdf

. Acce s sed Date , Jan . 6 , 2014

.

Page 10APPENDIX I . The map included herein primarily for the use of the risk assessors in the Environmental Fate and Effects Division. The map provides a very broad geographical view of the amount (in pounds) ofthe acid equivalent applied per 1,000 acres of"land in farms "

. These data are included in the maps because risk assessors are interested in the amount of a pesticide used across farmland. Because of the definition of Land in Farms, as discussed below, the calculated values presented in the map are not equivalent to an application rate (lbs a.i./A). The data used to make these maps have many limitations. Any interpretation of the maps should consider the underlying data and the associated limitations carefully. The smallest areas shown on the maps within each state are Crop Reporting Districts (CRD). CRDs are defined by USDA and each consists of multiple counties that have similar soils, growing conditions, and farming practices. The CRDs within many states have roughly the same area. Because it is not feasible to conduct an agricu ltural survey that samples every county in the United States, the use of CRDs allow for a sample to be co lle cted that represent a much larger area with relatively homogeneous agricultural characteristics. The numerator (annual average pounds applied) is based on private market surveys of pesticide use in agricu lture averaged over the last five years (Proprietary Data, 

### {dates } ). These surveys cover about 60 crops and are targeted in states that produce the majority of the crop. Although the surveys capture most ofthe use of a particular acid equivalent in agriculture, there are several limi tations to these surveys .
• States with minor product ion of a surveyed crop are not sampled • Not all types of pesticides are surveyed in every crop in every year • Many specialty crops with very small acreages are not included in the survey The result of these limi tations is that CRDs that show no usage may actually have a small amount of the acid equivalent being used. The denominator (1,000 Acres of land in farms) was selected from the Census of Agriculture (USDA, 2007) t o represent agricultural acreage that is actively managed and includes most of the areas treated with pesticides. The category "Land in Farms" is defined by the Census of Agriculture as being made up of four components:

• Total cropland • Permanentpasture • Total woodland • Land in farmsteads, buildings, livestock facilities, ponds, roads, wasteland , etc. This category includes land in the various USDA conservation programs. It should be noted that the Census of Agriculture does not include grazing land rented (on a per-animal basis) from the Bureau of Land Management or Forest Service, thus it i s an underestimate of the land being managed for agricultural purposes. Page 11The reader s hould pay particular attention to the figure lege nd s and realiz e that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical. Scale and units of m easuremen t do matter and may be different between maps.

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