UNJTED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMO;RANDUM 

DATE: 

SUBJECT: 

FROM: 

THROliGH: 

TO: 

January 23, 2013 

Revised: Section 3 New Use of Spirotetramat on Taro Leaves, Watercress, 

Pomegranate, Banana, Bulb Vegetable, Low Growing Berry, Bushberry, Globe 

Artichoke, Fruiting Vegetable, Pome Fruit, Citrus Fruit, Pineapple, and Coffee 

(PC Code 392201; DP Barcode 0398764) t>EC<SlDN: 4'St:fOE3'1 

Jose L. Melendez, Chemist ~ ~ ~ ; 1 . ; Joseph DeCant, Ecologist .;:tft'7·i - " c_ O:rif t''/•')''t3 

Environmental Risk Branch 5 '....-

Environmental Fate and Effects Division (7507P) / 

. 0/ /:<.3 /3 

En

Mah 

vironmental 

T. Shamim

Risk 

, Ph.D, 

Branch 

Branch 

5 

Chief 

~ 

~~ 

Environmental Fate and Effects Division (7507P) 

Rita Kumar, Risk Manager Reviewer 

John Hebert, Risk Manager #07 

Insecticide and Rodenticide Branch 

Registration Division (7505P) 

The Em ironmental Fate and Effects Division (EFED) has completed its review of an IR-4 

petition ::or the use of Spirotetramat, MOVENTOTM (Reg. No. 264-1 050), Ultor (Reg. No. 264-

1065), atJd BYI8330 (Reg. No. 264-1051), on taro leaves, watercress, pomegranate, banana, bulb 

veget bl• , low growing berry, bushberry, globe artichoke, fruiting vegetable, pome fruit, citrus 

fruit, in;~apple, and coffee. The Section 3 New Chemical assessment (D345278, 05/30/2008), is 

relevant to this assessment and provides background information on the chemical, its 

environmental fate and transport properties, ecotoxicity, and the overall problem formulation and 

conceptual model for spirotetramat. The recent Section 18 assessment (D403255, 07/26/2012), 

for the use on watercress, also provides information on the risk associated with the use of 

spirotetr<tmat on watercress. This assessment builds on the foundation, and relies heavily on the 

previqus risk assessments. Table 1 presents a summary of the risk conclusions associated with 

the proposed uses. Following this tabl~, this revised memo presents an overview of the 

remaining uncertainties and data needs, as well as an outline of relevant bee protective label 

language by crop. This memo has been revised to update and clarify the list of data gaps and the 
status of the data requirements, as well as information on coffee related to the need for label 

language. 

Table 1. Summary of Environmental Risk Conclusions for Various Taxa Exposed t(l 

Spirotetramat for the Proposed Uses 

~ssessment Endpoint Identified Concerns Proposed Uses Associated with Risk • 

Acute and Chronic Risk to Acute Watercress, Cranberry 

Freshwater and 

Estuarine/marine Fish 

Acute and Chronic Risk to Acute to all aquatic Watercress, Cranberry 

Freshwater and invertebrates and Chronic 

Estuarine/Marine Invertebrates to benthic invertebrates 

Aquatic Non-Vascular and Risk to Non-Vascular Watercress, Cranberry 

Vascular Plants 

Acute and Chronic Risk to Chronic Watercress, Banana/Plantain, Globe Arti 

Birds Citrus, Pome, Bushberry/Low Growing B 

Coffee, Pineapple, Pomegranate, Bulb 

Vegetables 

Acute and Chronic Risks to Chronic Banana! Plantain 

Mammals 

Risks to Upland and Wetland None N/A 

Plants 

Concerns to Terrestrial Non- Acute and Chronic Citrus, Bushberry/Low Growing Berry, P 

Target Insects Coffee, Bulb Vegetable 

Risks to Earthworms None N/A 

aN/A = Not Applicable 

The current status of the outstanding data requirements for toxicity testing based on the pn; vious 

risk assessment (D384525) as well additional data gaps identified in this assessment, are as 

follows: 

• 850.1075 Freshwater Fish Toxicity with Fathead Minnows: in review 

• 850.1350 Aquatic invertebrate life-cycle Estuarine/Marine: in reserve 

• 850.2100 Avian Oral Toxicity Study with a Passerine Species: in review 

• 850.2300 Avian Reproduction Study with the Mallard Duck (Anas platyrhynchos): in 

review 

• Non-guideline Study for Systemic Field Residues in Tree Crops/Citrus: study in pro.?ress 

• Non-guideline Study for Systemic Field Residues in Bushberry/Low Growing Beny: 

additional data needed on bushberryllow growing berry 

o Based on the physical properties of spirotetramat and its systemic nature ~; well 

as the higher tier studies, EFED identifies that the period of concern for 

11 
spirotetramat applications is the period before bloom, during bloom, and until 

petal fall is complete. Uncertainties in exposure to invertebrate pollinators related 

to the proposed use on bushberry/low growing berry remain due to the perennial 

nature of bushberry/low growing berry and potential for carry-over of residues 

from one season to the next. Therefore, non-guideline residue data are needed 

that addresses the systemic residues in this crop group and the extent to which 

residues from a previous season's application may persist into pollen and nectar 

that bees would collect. A protocol should be submitted to the Agency prior to 

study initiation and may employ blueberry. as the test crop with a study duration to 

address residues that may carry-over from application in one year to flowering in 

the following year. 

• ~ 50.3040 Field Testing for Pollinators: in reserve 

o The EFED has developed crop specific label language that can be used. to 

eliminate exposure to pollinators for some crops, but not all crops. For tree crops 

and bushberryllow growing berry, the EFED believes that additional data, as 

identified above, on translocated residues are needed to better characterize 

exposure. Further data that addresses toxicity to bees will be held in reserve 

pending the outcome of residue characterization in the field. 

Additional Recommended Label Language 

EFED uotes that the following language already appears m the proposed label under 

"Environmental Hazards": 

" l!or Terrestrial Use: This pesticide is toxic to aquatic invertebrates and oysters. Do not 

apply directly to water, to areas where surface water is present, or to intertidal areas 

below the mean high water mark. This product may contaminate water through drift of 

s:xay in wind. Do not apply when weather conditions favor drift from treated areas. Drift 

1d 'runoff from treated areas may be hazardous to aquatic organisms in neighboring 

a :·eas. Do not contaminate water when disposing of equipment wash waters or rinsate. 

This chemical has properties and characteristics associated with chemicals detected in 

ground water. The use of this chemical in areas where soils are permeable, particularly 

where the water table is shallow, may result in ground-water contamination. 

This product is potentially toxic to honey bee larvae through residues in pollen and 

~ctar, but not to adult honeybees. Exposure of adult bees to direct treatment or residues 

0:1 blooming crops can lead to effects on honeybee larvae. See the "Directions for Use" 

section of this label for specific crop application instructions that minimize risk to honey 

b ;:e larvae." 

Recommendations regarding spray drift, runoff, and wind speed also appear in the labels. 

Addition:tlly, as a potential mitigation measure, EFED advises a restriction on applications over 

cranb-!IT)' to occur no sooner than 30-days pre-flood. 

111 
Spirotetramat is toxic to bee brood, yet exposure can be mitigated for various crops given 

specific label langua~e. Due to the systemic nature of spirotetramat, applications madt! prebloom may translocate to pollen and/or nectar during the bloom period. Therefore, applic :~.ti ns 

made after petal fall is complete eliminates the potential for this exposure. EFED has 

coordinated with the U.S. Department of Agriculture (USDA) in order to further evaluate the 

proposed crops that would benefit pollinators given the specific label language. The USDA 

provided information related to the attractiveness of the crop, whether it is comme1cially 

pollinated, and the overall crop acreage of the crop group and specific minor crops

1

. The 

recommendations by EFED for each group are presented in Table 2. 

Table 2. List of proposed crops and EFED recommendations on pollinator label language to address 

exposure concerns to pollinators.• 

Crop(s) Crop Subgroup 

Australian lime (desert, finger, 

and round), Brown River 

finger lime, Japanese summer 

grapefruit, Mediterranean 

mandarin, Mount White lime, 

New Guinea wild lime, Citrus Russell River lime, sweet 

lime, Tachibana orange, Tahiti 

lime, Trifoliate orange, uniq 

fruit, including cultivars, 

varieties and/or hybrids of 

these commodities) 

aronia berry, bearberry, 

bilberry, blueberry (highbush 

and lowbush), Chilean guava, 

cloudberry, cranberry, currant 

(black, buffalo, native, and 

red), elderberry, European Bushberry/low barberry, gooseberry, edible growing berry honeysuckle, jostaberry, 

Juneberry, muntries, 

lingonberry, Partridge berry, 

salal, sea buckthorn, and 

cultivars, varieties, and/or 

hybrids of these) 

azarole, Chinese quince, 

Po me Japanese quince, medlar, 

tejocote 

cayenne, chili pepper, 

habanero, jalapeno, pablano, 

pimento and serranero, 

African eggplant, Bush 

Fruiting Vegetable tomato, cocona, currant 

tomato, garden huckleberry, 

goji berry, martynia, 

naranjilla, pea eggplant, 

roselle, scarlet eggplant, 

1 USDA email communication, November 5, 2012. 

EFED Recommendation for 

Label Laneuaee and Rationale 

Appropriate language is already 

applied to the labels for this 

crop group 

Due to commercial pollination 

and being highly attractive to 

pollinators, as well as fairly 

extensive cultivation, EFED 

recommends appropriate 

protective label language 

Appropriate language is already 

applied to the labels for this 

crop group. 

These crops are in general only 

moderately attractive to 

pollinators; in addition the crops 

proposed under this JR4 petition 

are low in acreage; therefore 

EFED does not recommend 

specific label language 

IV 

Spt~cific Lang; 

"Do not apply 

product withi1 

days prior to bl 

during bloom 

w1til petal fal 

complete" 

"Do not apply 

after petal fa 

"Do not apply 

thi~ 

I 10 

oom, 

, or 

I is 

1nti 

II" 

after petal fa. 

N!A 
Table2. List of proposed crops and EFED recommendations on poUinator label language to address 

e concerns to pollinators.• 

t•op(s) Crop Subgroup EFED Recommendation for Specific Language Label Language and Rationale 

sunberry, tree tomato, t 

including varieties and/ or 

hybrids of these commodities 

Coffee is highly attractive to 

pollinators, but it is neither 

commercially pollinated nor 

covers extensive acreageb; 

appropriate protective label 

c offe.e NIA language may therefore offer N/A 

localized benefits but is of low 

priority due to the minimal 

acreage of cultivation; EFED 

does not recommend specific 

label language 

Crops of Crop Subgroup 3-

07A (including: daylily (bulb), 

fritillaria (bulb), garlic (bulbs 

of common, great-headed, 

serpent), lily (bulb), onion 

(bulbs of common, Chinese, Most of the crop groups have 

pearl, potato onion), shallot low acreage in production; 

(bulb), plus cultivars, garlic and onions are moderately 

varieties, and/or hybrids of sized acreage; these crops are 

these); of low attractiveness to 

Bulb' 'egetables Crops of Crop Subgroup 3- pollinators, however some of "Do not apply until 

07B, (including: Chinese these crops are commercially after petal fall" 

chive (fresh leaves), chive pollinated for seed production•; 

(fresh leaves), elegans hosta, EFED recommends appropriate 

fritillaria (leaves), kurrat, leek protective label language for 

(Allium porrum, Lady's, those crops grown specifically 

wild), onion (Beltsville for seed production 

bunching, fresh, green, 

macrostem, tree [tops), welsh 

[tops]), shallot (fresh leaves), 

plus cultivars,. varieties, and/or 

hybrids of these) 

;:apple These crops are neither 

attractive nor grown in large 

t:granate N/A acreage therefore EFED does N/A 

a. Plantain 

not recommend specific label 

language 

This crop is harvested prior to 

bloom and is unattractive to 

Globe 1

\rtichoke N/A pollinators therefore EFED does N/A 

not recommend specific label 

language 

Leaves These crops are harvested prior 

N/A to bloom and therefore EFED N/A 

::rcress does not recommend specific 

label language 

: aEElicable 

v 
·Table 2. List of proposed crops and EFED recommendations on pollinator label language to address 

exposure concerns to oollinators.a __ 

I EFED Recommendation for I . 6;rop.(s) _ Crop Subgroup L .. 1 L ......... ''"" d R +" 1 Specific Language ~ . .. . - ~ . a.u.e an~:;u~e,~Ul ~,Ion::t e . ~ 

2 McGregor, S.E. Originally published in 1976. Insect Pollination of Cultivated Crop Piants. 

http:/ /xa.yimg.comlkq/groups/ 13211600/2067097133/name/Insect+Pollination+Of+Cultivated+Crop+Plants.r df 

Accessed January 20,2013. 3 Klein, A.M., Steffan-Dewenter, I., and T. Tscharntke. 2002. Bee pollination and fruit set of Cojjea arabica and C. 

canephora (Rubiaceae). American Journal of Botany. 90(1): 153-157. 4 USDA National Agricultural Statistics Service. 2010. Hawaii Aruma! Statistics Bulletin. 

http://www.nass.usda.gov/Statistics by State/Hawaii/Publications/Annual Statistical Bulletin/stat I 0-20.pdf. 

Accessed January 20,2013. 5 Smith, V.E., S. Steiman, and C.R. Elevitch. 201 0-ll. Fann and Forestry Production and Marketing Profile ft: r 

Coffee (Coffea arabica). In: Elevitch, C.R. (ed.). Specialty Crops for Pacific Island Agroforestry. Permanent 

Agriculture Resources (PAR), Holualoa, Hawai'i. http://agroforestrv.net/scps. 6 University of California. 1999. Onion Seed Production in California. Publication 8008. 

http://anrcatalog.ucdavis.edu/pdf/8008.pdf 

VI