UNJTED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D

. C. 20460

OFFIC E OF CHEMICAL SAFET Y AND P OLLUT I ON PREV E N T I O N 

### MEMO ; RANDUM
DATE: SUBJECT:

FROM:

THROl i GH:

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 

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Jose L. 

### Melendez, Chemist



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# ; Joseph DeCant, Ecologist



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# O : rif t''/•')''t3 Environmental Risk Branch 5 '....- Environmental Fate and Effects Division (7507P) /



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### T. Shamim, Ph.D, Branch Chief

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### En vironmental Risk Branch 5

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### 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

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### low growing berry, bushberry, glob e 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 provide s 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 ( D40 3255 , 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 thestatus of the data requirements, as well as information on coffee related to the need for la b el 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 Assoc iated 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 C hronic Estuarine/Marine Inv ertebrates to benthic invertebrates Aquatic Non-Vascular and Risk to No n-Vascular Watercress, Cranberry Vascular Plants Acute and Chronic Risk to Chronic Watercress , Banan a/ Plantain, Globe Art i Birds Citrus, Pome , Bushberry / Low Growing B Coffee , Pineapple , Pomegran a te , Bulb Vegetables Acute and Chronic Risks to Chronic Banana! Plantain Mamma l s Risks to Upland and Wetland None N / A Plants Concerns to Terrestr i al Non- Acute and Chronic Citrus, Bushberry / Low Growing Berry , P Target Insects Coffe e , Bulb Vegetable

Risks to Earthworms None N / A aN/A = No t Applicable The current status of the outstanding data requirements for toxicity testing based on the pn ; v i ous risk assessment (D384525) as well additional data ga p s 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 platyrhy n c hos): in review • No n-guid eline Study for Systemic Field Residues in Tree Crops / Citrus: study in pro.?re s s • Non - guideline Study for Systemic Field Residues in Bushberry / Low Growing Beny: additional data needed on bushberry l low growing berry o Based on the physical properties of spirote trama t and its systemic nature
**~;** w e ll as the higher tier studies, EFED identifies that the per iod of concern f or 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-guidel ine 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. 

### Addi tional Recommended Label Language EFED uotes tha t the following language already appears m the proposed label under "Env i ronmental 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 w ind. 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 washwaters 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 applica tion 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 m itigation measure, EFED advises a restriction on applications over cranb-!IT) ' to occur no sooner than 30-da ys pre-flood.

111Spirotetramat is toxic to bee brood, yet exposure can be mitigated for various crops given specific label **langua~e.** Due to the systemic nature of spiro t etramat, applicat i ons mad t ! p r ebloom may translocate to pollen and/or nectar during the bloom period. Therefore, applic

**:~.ti ns** 

made after petal fall is complete eliminat es 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 languag e . The USDA provided information related to the attractiveness of the crop , whether it is comme 1 cia ll y pollinated, and the overall crop acreage of the crop group and specific min o r crops 1 . The recommendations by EFED for each group are presented in Table 2. Tab l e 2. List of proposed crops and EFED re commendat ion s on pollinator label lan guage to address exposure concerns to pollinators.• Crop(s) Crop Subgroup Au s tra l ian lime (desert, finger , and round) , Brown River fin g er lime , Japanese summer gr ap e fruit , Mediterranean mandarin , Mount White lim e, N ew Guinea wild lime , C itrus Ru sse ll Riv e r lime , sweet lime , Tachibana orange , Tahiti lime , Trifoliate orange , uniq fruit , including cultivars, varieties and/or hybrids of the s e 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 c ultivar s, varieties, and/or h y brid s of these ) azar o l e, C hinese quince , Po me Japane s e quince , medlar , tejocote cayenne , chili pepper, habanero, jalapeno, pablano ,

pimento and serranero, African eggp l ant, Bush Fruiting Vegetable tomato , cocona , currant tomato , garden huckleberry , g oji b e rry , martynia, naran ji lla , pea e ggplant , ro s ell e, sc arle t eggplant, 1 U SDA emai l communication , November 5, 2012 .

EFED Recommendation for Label Laneua ee and Rationale Appropriate language is alread y applied to the labels for thi s crop group Due to commercial pollination and being highly attractive to pollinators , as well as fairly

extensive cultivation, EFED recommends appropriate protective label lan guage Appropriat e language is alread y

applied to the labels for thi s 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

E FED does not recommend s pecific label languag e IV

**Spt~cific** Lang ; " Do not appl y pr o duct withi1

da y s prior to bl during bloom

w1til petal fal complete" " Do not apply after petal fa " Do not appl y

**th i~**  I 10 oo m, , or I is 1nti II" after pet a l fa . N ! ATa bl e2. List of pr o po sed crop s a nd EFE D reco mmend ations on p oUinator label la nguage to a ddress e c on cerns to p ollinators. • t•op (s) Crop S ubgroup EFED Re co m mend atio n fo r Specific L a ng uage Label L ang uage and R a t iona le sunberry, tree tom a to , t including varieties and/ or hybrids ofthese commodities Coffee is highly attractive to pollinators, but it is neither commercially pollinated nor covers extensive acreageb; appropriate protective label 

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e NIA language may therefore offer N/A localized benefits but is of low

priority due to the minimal acreage of cu lti v ation; EFED does not recommend specific label language C rop s 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 ofthe crop groups have pearl , potato onion), sh all ot low acreage in production ; ( bulb) , plus cult iv ars , garlic and o nio ns 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 0 7B, (i ncluding : Chinese the se crops are commercially after petal fall" chive (fresh leaves), chive pollinated f or seed production• ; ( fre sh leaves), elegans hosta, EFED recommends appropriate fritillaria (leaves), kurrat, leek protective label langua ge

for (Allium porrum, Lady's, those crops grown specifically
w ild), onion (Beltsville for seed production bunchin g, fresh, green, macrostem , tree [to ps), welsh [tops]), shallot (fresh leaves), p lus cultivars,. varieties, and/or hyb rids of these) ;:apple These crops are neither attractive nor grown in large t:granate N/A acreage therefore EFED doe s N/A

a. Plantain not recommend specific label language This crop is harve sted prior to

bloom a nd is un attractive to G lobe 1 \rtichoke N /A pollinators there fore EFED does N/A not recomme nd specific label language Leaves These crops are harve sted prior N/A to b loom and therefore EFED N/A 

### ::rcress do es not recommend specific label language

**:** aEElicable



### v· Table 2. List of proposed crops and EFED recommendations on pollinator label language to address expo su re concerns to oollin ators.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. Ins ec t Pollination of Cultivated Crop Piants . http :/ /xa.yi mg.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. Ts charntk e. 2002. Bee pollination and fruit set of Cojj e a arabica and C . canephora (Rubiaceae). American Journal of Botan y. 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 /Ann ual 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 Is land 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: //anr catalog . ucdavis.edu / pdf/8008.pdf VI