UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

JUN 2 7 2012 

MEMORANDUM 

SUBJECT: BEAD Chemical Profile for Registration 

FROM: Bill Phillips, Agronomist 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

Biological Analysis Branch ,/ 

Sepehr Haddad, Environmental Protection Specialist/~-./~ Science Information and Analysis Branch / 

Derek Berwald, Economist ~ (\\__ ~ t 

'Y 

Economic Analysis Branch \_l) ~ ~ Biological and Economic Analysis Division (7503P) 

THRU: Arnet Jones, Chief 

Biological Analysis Bra 

Sc

Diann 

ience 

Si

Inf

ms

ormation 

, hief~~ and Analysis Branch 

Timothy Kiely, Chief ~V'v\.~ Economic Analysis Branch \J J 

Biological and Economic Analysis Division ( P) 

TO: Jill Bloom, Chemical Review Manager 

Risk Management and Implementation Branch 2 

Pesticide Re-evaluation Division (7508P) 

Product Review Panel date: May 8, 2012 

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 

of2,4-D, and eventually the general public. This document builds upon the data already provided 

1 
by BEAD. The document is based on information and data available to BEAD as of May 5, 

2012. Use patterns may change in response to future conditions and market opportunities. 

The herbicide 2,4-D has a long history of efficacy research dating back to the early 1940's where 

it was evaluated in agricultural settings as well as on turf; including the lawn of the White House 

where it was tested for the control of dandelions ( Taraxacum officina/e). Following the initial 

entry of 2,4-D into the market place in 1946 this herbicide was quickly adopted by farmers and 

has been a staple of agricultural weed control since. 1 In fact, in the 2007 rankings of use based 

on total pounds active ingredient (lbs ai), 2,4-D was ranked number seven among all crop 

protectants and number five for herbicides used in agriculture. In home and garden use it ranked 

number one, and was number one in commercial, governmental, and industrial use? In addition 

to the uses as an herbicide, 2,4-D is also used as a growth regulator in citrus. 

This herbicide is an auxin-like plant hormone with the mechanism of action like that of the in 

vivo plant growth regulator indole acetic acid. 2,4-D effects its control on weeds via disrupting 

the flow in the vascular system. This flow is disrupted in two ways, elongation of plant cells 

which results in constricted and twisted of the stems, and swelling at the nodes (e.g., leaf 

attachments). 

2,4-D as an herbicide is used in many agricultural crops and is applied postemergence to the 

weed species, preemergence to broadleaf crops, and preemergence and early postemergence in 

some grass crops. In addition to agricultural uses, 2,4-D is used to control weeds in nonagricultural and industrial use sites. There are currently nine different synthetic auxin resistant 

weed species reported in the United States. Some of these weed species are considered 

problematic in crop production. 

The Weed Science Society of America classifies this herbicide in the mechanism of action group 

4.

3 Formulations of2,4-D are emulsifiable concentrate, granules, soluble concentrate/solid, 

water dispersible granules, and wettable powder. 2,4-D may be applied with a wide range of 

application equipment including fixed-wing aircraft, backpack sprayer, band sprayer, boom 

sprayer, granule applicator, ground-directed sprayers, hand held sprayer, helicopter, injection 

equipment, tractor-mounted granule applicator, and tractor-mounted sprayers. 

Overall, the primary agricultural crop uses for 2,4-D is for selective broadleaf weed control in 

pasture land, wheat and com. In non-crop areas the primary use of this herbicide is in home lawn 

care and golf course weed control. Because of the many lawn and turf species to which 2,4-D 

can be applied, it is very useful for controlling broadleaf weeds in many grasses. Added to its 

flexibility and efficacy is its relatively low cost. From 2006 - 2010, agricultural use of2,4-D 

was less expensive (under $2.00 per acre) than other broad spectrum herbicides like glyphosate 

(over $6.00 per acre) or paraquat (over $7.00 per acre), although they are not direct substitutes. 

1 Industry Task Force II on 2,4-D Research Data. http://www.24d.org/ 2 EPA, Pesticides Industry Sales and .Usage, 2006 and 2007 Market Estimates. 

http://www. epa. gov/ oppOOOO 1 /pestsales/07pestsales/market_ estimates2007. pdf 

3 Herbicide Resistant Action Committee 

http://www.hracglobal.com/Publications/ClassificationofHerbicidcModeofActionltabid/222/Default.aspx 

2 
It was also cheaper than herbicides in general, which had an average cost for an herbicide 

treatment of over $7.50 per acre

4

. 

In addition to the agricultural uses, there are other uses for 2,4-D as a growth regulator in citrus. 

As a growth regulator it is applied pre-harvest to oranges and post-harvest to lemons. The 

growth regulator is applied to oranges prior to harvest in order to delay fruit drop. This is 

accomplished by using the chemical to inhibit the formation of an abscission layer between the 

tree branch and the ripened fruit. By inhibiting the abscission layer the fruit can remain on the 

tree to continue to grow higher quality fruit. 5 

The post harvest application of2,4-D to lemons relies on the same basic physiological function 

as it does for the orange crop, however this done for a different reason. In the case of postharvest applications to lemons the abscission layer between the "button," a small brown stem 

attachment (calyx), and the stem end ofthe fruit are kept attached. By retaining the button on the 

end of the fruit the incidence of Alternaria fruit rot is greatly reduced. The method of 

application for this use of2,4-D is by applying 2,4-D at 500 ppm in a wax and water emulsion. 

This emulsion is applied to the fruit following the final rinse. 

USE SITES 

Agricultural Use Sites 

The chemical2,4-D is an herbicide registered for many agricultural use sites including 

bushberries, caneberries, strawberries, grapes, citrus, nut crops, pome fruits, stone fruits, hops, 

cucurbits, root crop vegetables, sweet corn, com, asparagus, forage grasses (including those for 

hay and silage), uncultivated agricultural areas, forage legumes, grain crops (such as rice, 

barley, oats, wheat rye, etc.), sugarcane, corn, sorghum, buckwheat, soybeans, cotton, peanuts 

and crops grown for oil (safflower, $unflower, rapeseed). 

Non-Agricultural Use Sites 

Non-agricultural use sites for which 2,4-D is registered includes forest trees, ornamental plants, 

ornamental lawns and turf, ornamental- trees, woody shrubs and vines, domestic dwellings, 

aquatic sites (ditch banks, irrigation systems, lakes, ponds etc.), wide area and general 

indoor/outdoor treatments (vacant lots, hedgerows, fencerows etc.), commercial industrial and 

institutional maintenance (schools, hospitals, warehouses, airports, parks, etc.). 

USAGE 

Agricultural Usage 

4 Proprietary Data, 2000-20 I 0 

5 Zur, A. and R. Goren. 1977. Reducing preharvest drop of 'Temple' orange fruits by 2,4-D - Role of cellulase in 

the calyx abscission zone. Scientia Hort. 7:237-248. 

http://www.sciencedirect.com/science/article/pii/0304423877900206 

3 
Based on private market usage data from 2000-2010, usage averaged approximately 29 million 

pounds active ingredient (lbs a.i.) for 55 million acres treated. The private market usage data 

available presents the data as just 2,4-D (2,4-dichlorophenoxyacetic acid) and does not break 

down the data into the various salts and esters of2,4-D. The 2,4-D task force has supplied the 

Agency with a master label in which they describe the 2,4-D chemical forms they are supporting, 

which does include the various salts and esters. Figure 1 presents usage of 2,4-D in lbs a.i. and 

total area treated in acres over this time period. The average a.i. rate during the 2000-2010 time 

period was approximately 0.53 lbs a.i./A (acre); however, for individual use sites the average a.i. 

rate over this same time period ranged from 0.1 lbs a.i./A to as high as 1.0 lbs a.i./A (0.1 lbs 

a.i./A for caneberries; 0.43 lbs a.i./A for winter wheat and fallow; 0.49 lbs a.i./A for com and 

soybeans to as high as 1.0 lbs a.i./A for cherries, and pears)(Proprietary Data, 2000-2010). 

FIGURE 1. 2,4-D Usage in Pounds AI. Applied & Total Area Treated in Acres 

2000-2010 

90,000,000 

Pounds AI 

- Total Area Treated {in 

Acres) 

20,000,000 

8 

N 

8 

N 

8 

N 

8 

N 

8 

N 

8 

N 

8 

N 

8 

N g N 

8 

N ~ N 

Years 

Source: Proprietary Data, 2000-2010 

Table 1 compares the states with the most agricultural usage between the 2001-2005 and 2006-

2010 timeframes, and Table 2 compares the crops with the highest use between those same time 

periods. These two timeframes were chosen since the Reregistration Eligibility Decision 

Document (RED) for 2,4-D was issued in 2005, and a comparison of the data before and after the 

issuance of the RED may have resulted in the changes in usage (Tables 1 and 2). 

4 
TABLE 1. Comparison of States with Highest Use of2,4-D- Percent of Total Lbs. Applied and 

Percent ofTotal Area Treated (Acres) Between the 2001-2005 and the 2006-2010 Timeframes 

2001-2005 2006-2010 

State %Lbs %TAT 

Texas 14 

Oklahoma 9 

Kansas 8 

Montana 7 

N. Dakota 5 

Arkansas 4 

S. Dakota 4 

Illinois 4 

Nebraska 4 

Other 42 .. Average Lbs A.I./yr = 30 m1lhon 

Average TAT (Acres)/yr = 58 million 

13 

7 

g 

11 

7 

3 

4 

4 

4 

39 

State %Lbs %TAT 

Texas 12 11 

Kansas 10 12 

Oklahoma 8 7 

Montana 5 8 

Mississippi 4 3 

Colorado 4 6 

Illinois 4 4 

Missouri 4 3 

Indiana 3 3 

Other 46 44 

Average Lbs A.l./yr = 28 million 

Average TAT (Acres)/yr = 54 million 

TABLE 2. Comparison of Crops with the Highest Use of2,4-D- Percent ofTotal Lbs. Applied and 

Percent of Total Area Treated (Acres) Between the 2001-2005 and the 2006-2010 Timeframes 

2001-2005 2006-2010 

Crop %Lbs 0

/o TAT 

Pasture land 44 35 

Winter 12 IS 

Wheat 

Corn 10 11 

Spring 8 12 

Wheat 

Soybeans 7 8 

Fallow 6 9 

Sorghum 3 4 

Barley z 3 

Cotton 2 1 

Other 5 4 

Average Lbs A.I./yr = 30 mtllion 

Average TAT (Acres)/yr = 58 million 

Source: Proprietary Data, 2001-2010 

Crop %Lbs %TAT 

Pasture land 33 25 

Winter 14 18 

Wheat 

Corn 13 14 

Soybeans 12 12 

Fallow 9 10 

Spring 6 9 

Wheat 

Cotton 3 3 

Sorghum 3 4 

Sugarcane 2 1 

Other 5 4 

.. Average Lbs A.l./yr = 28 m1lhon 

Average TAT (Acres)/yr = 54 million 

The states with the highest use in both the 2001 -2005 and the 2006-2010 timeframes were Texas, 

Oklahoma, Kansas and Montana while the sites with the highest use in terms of total pounds 

applied in both timeframes were pastureland, winter wheat, and corn. These three highest use 

5 
states are those with some of the highest amo·unt of pasture land, two of which are major wheat 

producing states. The "other" states depicted in Table 1 included more than 30 other states. 

There was a slightly lower average use in the latter period with the top four states remaining the 

same, although the relative ranking has changed. Other states used relatively small shares of the 

nationwide use of2,4-D. 

The "other" crops depicted in Table 2 included more than 40 other crops. The share of2,4-D use 

on pastureland declined considerably from the 2001-2005 to the 2006-2010 timeframes. Overall 

use did not decline as much, because of small increases in crops with substantial acreages, like 

wheat, corn, and soybeans. 

Non-Agricultural Usage 

In terms of non-agricultural usage, as presented in Table 3, data are available for usage by lawn 

care operators (LCO's) and consumers, and for uses such as golf ~ourses, landscape, 

nursery/greenhouse, turf farms, and aquatic areas, although all data are not available for each 

year. Usage on golf courses and by LCO's has remained fairly steady, use on institutional turf 

and landscape has fluctuated, and use in turf farms has decreased substantially; however, limited 

data makes it impossible to be definitive in these cases. The most non-agricultural usage in 

terms of pounds a.i. applied as reported in 2003 and 2005, was by consumers for lawn use, direct 

application or as a fertilizer combination. 

Table 3. 2,4-D Reported Non-Agricultural Usage (Pounds A.I.) (2002-2006) 

Site 2002 2003 2004 2005 2006 

Golf Courses 311 ,000 333,000 374,000 

Institutional Turf 582,000 966,000 791 ,000 

Landscape 375,000 193,000 262,000 

Lawn Care Operators 2,350,000 2,512,000 2,145,000 

Turf Farms 1,400,000 162,000 414,000 

Nursery/Greenhouse 900 70,000 8,000 

Aquatic Areas 820,000 460,000 

Consumer -Lawn 1,830,000 915,000 

Consumer-Fertilizer 6,400,000 8,100,000 

Combination 

TOTAL Reported (lbs. a.i.) 5,019,000 9,050,000 4,206,000 9,475,000 3,994,000 

Shaded areas of the table are those years for wh1ch there were no reports tssued for the non-agncultural use s1te 

category 

Source: Kline & Co., 2002-2006 

HISTORY OF BEAD ASSESSMENTS FOR 2,4-D 

There have been few BEAD assessments for 2,4-D over the years. This is somewhat surprising, 

as 2,4-D has been the subject of a recent petition for cancellation and revocation of tolerances, 

6 
which was denied6

. Public comments received during the petition process requested an 

alternatives assessment for 2,4-D. The assessment was not done, because no risks of concern 

were identified in evaluating the petition 7

. 

Based on the 2007 rankings ofuse, in totallbs ai, 2,4-D is an important herbicide used in 

agriculture, commercial, goverrunental, and industrial use. Although BEAD has not estimated 

the benefits of2,4-D, it is reasonable to think the benefits wouJd be considerable, because it is 

used on a very large acreage, and is a relatively low cost herbicide. 

INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON 2,4-D 

Non-agricultural usage information (such as for lawn care operators, consumers, and aquatic 

uses) after 2006 would be helpful in determining if these sites remain a significant part of the 

2,4-D market. 

REFERENCES 

Proprietary Data, 2000-2010 

USDA, 2006-2010. NASS Crop Reporting Districts. Online: 

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

USDA, 2007. Census of Agriculture. Online: 

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

6 Bradbury, Steven P., EPA Denial of November 6, 2008 NRDC Petition to Cancel All2,4-D Registrations, Jetter dated April?, 

20 12. http://www .epa.gov/pesticides/chem search/reg actions/24d/24d-fi fra-responsc. pdf 7 Wolf, Joel and Richard Keigwin, EPA Response to Issues Raised in Public Comment, but Unrelated to Issues in NRDS 2,4-D 

Petition, April 07, 2012. Available here: 

http://www.regulations.gov/#!documentDetaii:D=EPA-HO-OPP-2008-0877-0448 

7 
Appendix 

2,4-D Agricultural Usage by Crop Reporting District (2006-2010) 

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

the pounds a.i. applied per acre of land in farms. This differs from the application rate, which is 

expressed as the pounds a.i. applied per treated acre. Figure 2 spatially represents 2,4-D use 

intensity in the US, with the most intense use in the areas depicted in the color red. 

FIGURE 2. 2,4-D Agricultural Usage by Crop Reporting District (2006-2010) 

2,4·0 Use (2006·20 I 0) by Crop 

Reporting District Average Pounds 

per 1,000 Acres of Farmland 

'Sources: 

- < 19 

- 19-44 

0 45 - 85 

- 86 - 145 

- 146-250 

Proprietary Data. 2006-2010 

USDA, 2006-2010. NASS Crop Reporting Districts .. 

USDA, 2007. Census of Agriculture. 

This is a map of agricultural pesticide usage at the Crop Reporting District (CRD) level. CRDs are boundaries created by USDA 

NASS which are aggregates of counties (USDA, 2010). Pesticide usage is displayed as average pounds (for the years 2006-2010) 

per I ,000 acres of farmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acreage was obtained 

from USDA (2007). 

Usage is based on private market surveys of pesticide use in agriculture (Proprietary Data, 2006-2010). The survey data are limited 

to the states that represent the top 80-90% of acreage for the individual 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 nonparticipation 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. 

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