MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

AUG 19· 2014 

OFFICE OF CHEMICAL SAFET' 

AND POLLUTION PREVENTim 

SUBJECT: Profenofos: General information on its use and alternatives to support registration 

review 

FROM: 

THRU: 

TO: 

Nikhil Mallampalli, Entomologist #{'(c(. M.L--

Biological Analysis Branch ;_---

Michelle Ranville, Economist ~ lnJ rfr)} 

Economic Analysis Branch "- · \JJUJ 

Biological and Economic Analysis Division (7503P) 

Amet Jones, Chief 

Biological Analysis Bran ~ 

Timothy Kiely, Chief ~ 

Biological and Economic~ Divisio ( ) 

Economic Analysis Branch 

Christina Scheltema, Chemical Review Manager 

Risk Management and Implementation Branch III 

Pesticide Re-evaluation Division (7 508P) 

BEAD Peer Review Panel date: August 6, 2014 

SUMMARY 

In this document, the Biological and Economic Analysis Division (BEAD) is providing 

information on the usage of and likely alternatives to profenofos to the Pesticide Re-evaluation 

Division (PRD) to help inform their efforts to evaluate and mitigate risks assessed for this 

insecticide as part of registration review. This genera) description focuses on usage trends as 

derived from proprietary market survey data and the publicly available pesticide use database 

maintained by the California Department of Pesticide Regulation (CDPR). It also presents 

information on likely target pests and alternative insecticides based on selected recent extension 

Page 1 of6 
service references from major cotton producing states. Profenofos (Curacron ®)is an 

organophosphate insecticide that is currently registered only for use on cotton in the United 

States. An interim reregistration eligibility decision (iRED) was issued in 2000. The final RED 

for profenofos was completed in 2006. Data indicate that profenofos usage, already low at the 

time of the iRED, has shown a declining trend. 

Although several pests are listed on the label, usage data and extension literature indicate that the 

main targets of recent use are certain Lepidopteran pests (such as armyworm, com earworm, and 

tobacco budworm), plant bugs, and stink bugs. Several alternatives are available for these pests 

in cotton. While these lines of evidence indicate a low and declining importance of profenofos, 

BEAD cautions that there may be occasional situations where its comparative importance as a 

pest control option may be elevated. For example, in any given year, individual fields facing 

unusually high levels of target pests may require multiple different insecticide sprays across the 

season. Growers facing pest populations resistant to other Modes of Action (e.g., pyrethroids) 

may need profenofos to supplement their pest management programs. While usage information 

suggests that such situations are rare, BEAD has not evaluated the likelihood comprehensively, 

and suggests that feedback from regional crop experts (such as university researchers, extension 

agents, and independent crop consultants) familiar with local pest trends may be valuable in this 

context. 

PROFENOFOS USAGE 

Table 1 shows profenofos usage on cotton, pounds applied and total acres treated for the years 

1998 through 2012. Since 1998, percent crop treated has averaged less than 2% annually and has 

averaged less than 1% annually since 2007. Proprietary usage data indicates that profenofos is 

primarily applied through ground applications. The percent of total acres treated with aerial 

application was approximately 50% on average over the years 1998-2000 but shrank to 25% or 

less, on average, in subsequent years. The average acres treated with aerial applications 

increased again in the years 2007-2009, but this was primarily due to a high incidence of aerial 

applications in one state. There were no aerial applications in 2010 or 2011 and no reported 

usage in 2012. Overall, total acres treated has decreased substantially in recent years with 

average acres treated over the most recent three years being less than 2% of the three-year 

average from 1998 to 2000. The average totallbs applied annually from 1998-2000 was less 

than 60% of average totallbs applied annually over the years 1995-1997 (775,000 lbs) (Sterling 

1999). Percent crop treated has also declined in recent years but at a slower rate than total usage 

since total acreage of cotton grown has also decreased (Proprietary data; USDA NASS). Use (in 

terms of average total acres treated across 2005-20 11) appears to be concentrated in the 

southeastern U.S., mainly Arkansas, Mississippi, Missouri, and Georgia. 

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T bl 1 P ~ ~ U C tt . th US Th y A 1998 20121 a e . ro eno os sa2e on o onm e . ., ree- ear vera2es, -

1998-2000 2001-2003 2004-2006 2007-2009 2010-20122 

Total Lbs Applied 447,154 159,067 67,938 19,757 6,767 

Total Acres Treated 696,415 197,499 107,316 25,044 9,454 

Proportion of Acres 50% 17% 24% 34% 0% Treated Aerially 

Percent Crop Treated L7% 1.4% 1.1% 0.6% 0.7% 

1 States reporting use in 1998-2006: AL, AZ, AR, CA, FL GA, LA, MS, MO, NC, OK, SC, TN, TX; 

States reporting use in 2007-2011: AR, GA, MS, MO, TX 

2 No usage reported in 2012 

Source: Proprietary Usage Data, 1998-2012 

Table 2 shows profenofos usage on cotton in California, in terms of both amount applied and 

total acres treated, for the years 1998-2012. Like the national-level proprietary data, the 

California usage data show that profenofos usage has decreased to near zero in recent years. No 

usage was reported in 2009 or 2011. Only one application was reported in the state in 2012 and 

only seven in 2010, compared to more than 400 applications in 1998. 

T a e bl 2 P . ro ~ eno ~ os U sa2e on c o tt onm · c a r~ 1 orma, · 2ooo -2012 

Total Lbs Applied 

Total Acres Treated 

Proportion of Acres 

Treated Aerially 

Number of applications 

reported 

1 No usage reported in 2009 2 No usage reported in 2011 

1998-2000 

50,025 

45,810 

90% 

380 

2001-2003 2004-2006 

19,776 20,143 

21,098 19,105 

90% 94% 

159 115 

Source: California Dept ofPesticide Regulation, 1998-2012 

BIOLOGICAL IMPORTANCE 

2007-20091 2010-20122 

1,927 805 

2,399 895 

100% 94% 

13 3 

Proprietary survey data indicate that in the years 1998-2012, most treatments targeted "worms" 

(e.g., tobacco budworm, armyworms, and boll worms). Other pests treated for include spider 

mites, boll weevil, plant bugs, and stink bugs. A review of USDA Crop Profiles for cotton in 

major producing states (available at www.ipmcenters.org), as well as selected extension service 

literature, suggests that in addition to Lepidopteran caterpillar "worms", profenofos has also 

historically been recommended for control of the cotton aphid and silverleafwhitefly (see, for 

example, USDA 2000, 2002). However, recent crop production guides from major cotton 

producing states such as Georgia and North Carolina do not mention profenofos as a 

recommended material for any pest (Roberts and Toews 2014, Reisig 2014). This suggests that at 

most, profenofos is a minor component of current cotton insect management programs. 

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Historically, aerial application ofprofenofos was quite rare, probably because growers only used 

the method when the cotton canopy had matured, making ground equipment difficult to use 

without causing crop injury. However, as of July 2014 the profenofos label was amended to 

exclude aerial application. 

The widespread adoption of transgenic Bt cotton varieties, which express a toxin that effectively 

controls a range of foliar feeding caterpillars (including all the "worms" mentioned in proprietary 

data) has been a major factor underlying the decline in profenofos usage (Stevenson and 

Matocha 2005). The elimination of the boll weevil eradication program in almost all states 

(except Texas) has also probably contributed to the decline in use, because those programs 

required season long prophylactic applications of multiple different insecticides (of which 

,profenofos was a component). 

However, there may still be sporadic use on a small acreage, at least partly because sap-sucking 

insects, in particular a set of stink bug species, have become more serious pests. This is likely 

because they are no longer suppressed by the large number of contact insecticides growers were 

using against the "worm" complex (Stevenson and Matocha 2005). These pests are unaffected by 

the Bt toxin in cotton, and appear to be more widespread in southeastern states than elsewhere. 

Since at least 2012, some stinkbugs, particularly the brown stink bug, Euschistus servus, also 

seem to be increasing in population in western states such as Arizona and California, where they 

have historically been minor pests (Ellsworth and Brown 2014). 

Despite the increase in importance of these pests, profenofos usage data clearly indicate a minor 

pest control role in recent years. At the moment, several effective alternatives exist for control of 

all these cotton pests. Although some growers appear to have used profenofos against stink bugs, 

its utility against these types of insects was apparently considered poor as far back as 2005. The 

Pest Management Strategic Plan for Texas cotton, published in that year, stated the following 

about profenofos: 

"Presently, the principal value of profenofos is that it is an economical choice for use against 

mixed populations of bollworms, plant bugs, armyworms and building populations of aphids 

and/or spider mites. Although profenofos labels include cottonjleahopper, Lygus and other plant 

bugs, it is not recommended ... for cotton because of the lack of demonstrated efficacy and the 

availability of more effective products. " (Stevenson and Matocha 2005). 

According to proprietary survey data, materials with comparatively greater use against these 

insects include at least eight other insecticides, comprised of organophosphates, synthetic 

pyrethroids, and neonicotinoids. Extension literature list several other insecticides also, 

depending on which pest is considered (see, for example, Stewart and McClure 2013, Reisig 

2014). Organophosphates with comparatively higher use in cotton (in terms of percent crop 

treated nationally, across 2008-2012) include acephate, chlorpyrifos, dicrotophos, and 

dimethoate. The neonicotinoids with greatest use against the pests mentioned above are 

thiamethoxam and imidacloprid; bifenthrin was the synthetic pyrethroid with greatest usage 

against the bug pest complex. Sulfoxaflor, a new (registered since 2011) chemistry effective 

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against the tarnished plant bug, showed low usage, but BEAD expects this to increase as growers 

adapt pest management programs to include it (Atwood 2012). 

CONCLUSION 

Recent trends in usage data for profenofos and its alternatives, as well as the extension literature 

surveyed, indicate a low and declining importance ofprofenofos in U.S. cotton. Confidential 

sales data submitted by the registrants to EPA also show a declining presence of profenofos as a 

pest control option available to growers. However, BEAD cautions that there may be occasional 

situations where its comparative importance as a pest control option may be elevated. For 

example, in any given year, individual fields facing unusually high levels of target pests may 

require multiple different insecticide sprays across the season. While usage information suggest 

that such situations are rare, BEAD has not evaluated the likelihood comprehensively, and 

suggests that feedback from regional crop experts familiar with local pest trends may be valuable 

in this context. 

REFERENCES 

Atwood, D. 2012. Review of Benefits for Sulfoxaflor for Fruiting Vegetables, Cucurbit 

Vegetables, Citrus, and Cotton. (DP# 384640). Internal BEAD memorandum available through 

the Official Records database. 

California Dept of Pesticide Regulation. 

Ellsworth, P. and L. Brown. 2012. Frequently Asked Questions: Brown Stink Bugs. Extension 

factsheet from the University of Arizona Cooperative Extension Service. Available on the web at 

https:/ /cals.arizona.edu/crops/cotton/files/BSB F AQlo.pdf [Accessed May 2014] 

Proprietary Data. 1998-2012 

Reisig, D.D. 2014. Insect Control on Cotton. Pp 78-81 In: 2014 North Carolina Agricultural 

Chemicals Manual. Available on the web at http:/ /fsg.ces.ncsu.edulpublication/north-carolinaagricultural-chemicals-manual/ [Accessed July 2014]. 

Roberts, P.M. and M. Toews. 2014. Cotton Insect Control. Pp 36-41 In: 2014 Georgia Cotton 

Production Guide. Available on the web at www.ugacotton.com 

Sterling, S. A. 1999 ... Analysis of the Use ofProfenofos Insecticide (Curacron® 8E) on Cotton. 

Internal BEAD memorandum. 

Stevenson, D. E. and M.A. Matocha. 2005. A Pest Management Strategic Plan for Cotton 

Production in Texas. Available on the web at www.ipmcenters.org [Accessed June 2014]. 

Stewart, S. and A. McClure. 2013. Insect Control Recommendations for Field Crops: 

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Cotton, Soybean, Field Com, Sorghum, Wheat and Pasture. Publication# PB 1768 ofthe 

University of Tennessee Extension. Available on the web at 

https://utextension.tennessee.edu/publications. [Accessed May 2014]. 

USDA. 2000. Crop Profile for Cotton in Arkansas. Available on the web at www.ipmcenters.org. 

[Accessed July 2014]. 

USDA. 2002. Crop Profile for Cotton in Mississippi. Available on the web at 

www.ipmcenters.org. [Accessed July 2014]. 

USDA. 2009. Crop Profile for Cotton in Texas. Available on the web at www.ipmcenters.org. 

[Accessed July 2014]. 

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