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) AmetJones, 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 PesticideRe-evaluation Division (7508P) 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 ofand 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 ofregistration review. This genera) description focuses onusage trends as derived from proprietary market survey data and the publicly available pesticide use database maintained bythe CaliforniaDepartment ofPesticide Regulation (CDPR). Italso presents information on likely targetpests and alternative insecticides based on selected recent extension Page 1 of6service references from major cotton producing states. Profenofos (Curacron ®)is an organophosphate insecticide that is currentlyregistered 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 thatprofenofos usage, already low at the time ofthe iRED, has shown a declining trend. Although several pests are listed onthe label, usage data and extension literature indicate that the maintargets ofrecent use are certain Lepidopteranpests (such as armyworm, comearworm, and tobacco budworm), plant bugs, and stink bugs. Several alternatives are available for these pests in cotton. While these lines ofevidence indicate a low and declining importance ofprofenofos, BEAD cautions that there maybe occasional situations where its comparative importance as a pest control option maybe elevated. For example, in any given year, individual fields facing unusually high levels oftarget pests mayrequire multiple different insecticide sprays across the season. Growers facing pestpopulations resistantto other Modes ofAction (e.g., pyrethroids) may need profenofos to supplementtheirpest managementprograms. While usage information suggests that such situations are rare, BEAD has not evaluatedthe likelihood comprehensively, and suggests that feedback from regional crop experts (such as university researchers, extension agents, and independent crop consultants) familiar with local pesttrends 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 oftotal acres treated with aerial application was approximately 50% on average overthe years 1998-2000 but shrankto 25% or less, on average, in subsequent years. The average acres treated with aerial applications increased again inthe years 2007-2009, butthis was primarily due to a high incidence ofaerial 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 overthe most recent three years being less than 2% ofthe three-year average from 1998 to 2000. The average totallbs applied annually from 1998-2000 was less than 60% ofaverage totallbs applied annually overthe years 1995-1997 (775,000 lbs) (Sterling 1999). Percent crop treated has also declined inrecent years but at a slower rate thantotal usage since total acreage ofcotton grownhas also decreased (Proprietary data; USDA NASS). Use (in terms ofaverage total acres treated across 2005-2011) appears to be concentrated in the southeasternU.S., mainly Arkansas, Mississippi, Missouri, and Georgia.

Page 

### 2 of6

### T bl 1 P**~ ~**  

### U C 

### tt

. th US Th 

### y 

### A 1998 2012 1 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 TotalAcres Treated 696,415 197,499 107,316 25,044 9,454 Proportion ofAcres 50% 17% 24% 34% 0% Treated Aerially Percent CropTreated 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 oncotton in California, in terms ofboth amount applied and total acres treated, for the years 1998-2012. Like the national-level proprietary data, the California usage data showthatprofenofos usage has decreased to near zero inrecent years. No usage was reported in 2009 or 2011. Only one application was reported inthe state in 2012 and only seven in 2010, comparedto more than 400 applications in 1998. 

### T bl 2 P**~ ~**  

### U c 

### tt · c**r~** 

### · 2ooo 2012

a e 

# . ro eno os sa2e on o onm a 1 orma, 

## -

Total LbsApplied TotalAcres Treated Proportion ofAcres Treated Aerially Numberofapplications reported 1No 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: CaliforniaDept ofPesticide Regulation, 1998-2012



### BIOLOGICALIMPORTANCE 2007-20091 2010-20122 1,927 805 2,399 895 100% 94%

13 3

Proprietary survey data indicate that in the years 1998-2012, mosttreatments targeted "worms" (e.g., tobacco budworm, armyworms, and boll worms). Other pests treated for include spider mites, boll weevil, plant bugs, and stinkbugs. A review ofUSDA Crop Profiles for cottonin 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 ofthe 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 Carolinado notmention profenofos as a recommended material for any pest (Roberts and Toews 2014, Reisig 2014). This suggests that at most, profenofos is a minor component ofcurrent cotton insect managementprograms. Page 3 of6Historically, aerial application ofprofenofos was quite rare, probably because growers only used the method whenthe cotton canopy had matured, making ground equipment difficult to use without causing crop injury. However, as ofJuly 2014 the profenofos label was amended to exclude aerial application. The widespread adoption oftransgenic Btcotton varieties, which express a toxin that effectively controls a range offoliar feeding caterpillars (including all the "worms"mentioned inproprietary data) has been a majorfactor underlying the decline inprofenofos usage (Stevenson and Matocha 2005). The elimination ofthe boll weevil eradicationprogram in almost all states (except Texas) has also probably contributedto the decline in use, because those programs required season long prophylactic applications ofmultiple different insecticides (ofwhich

, profenofos was a component). However, there may still be sporadic use on a small acreage, at leastpartly because sap-sucking insects, in particular a set ofstink bug species, have become more serious pests. This is likely because they are no longer suppressed by the large number ofcontact insecticides growers were using against the "worm" complex (Stevenson and Matocha 2005). Thesepests are unaffected by the Bttoxinin cotton, and appearto be more widespread in southeastern states than elsewhere. Since at least 2012, some stinkbugs, particularlythe brown stink bug, Euschistus servus, also seem to be increasing inpopulation in western states such as Arizona and California, where they have historically been minorpests (Ellsworth and Brown 2014). Despite the increase in importance ofthese pests, profenofos usage data clearly indicate a minor pest control role in recent years. Atthe 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 ofinsects 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, theprincipalvalue of profenofos is that it is an economical choice for use against mixed populations of bollworms,plantbugs, armyworms andbuildingpopulations of aphids and/or spider mites. Althoughprofenofos labels include cottonjleahopper, Lygus andotherplant bugs, it is notrecommended

...for cotton because of the lackof demonstratedefficacy andthe availability of more effectiveproducts

. " (Stevenson andMatocha 2005)

. According to proprietary survey data, materials with comparatively greater use against these insects include at least eight other insecticides, comprised oforganophosphates, synthetic pyrethroids, and neonicotinoids. Extension literature list several other insecticides also, depending on whichpest is considered (see, for example, Stewart and McClure 2013, Reisig 2014). Organophosphates with comparatively higher use in cotton (interms ofpercent 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 greatestusage against the bugpest complex. Sulfoxaflor, a new (registered since 2011) chemistry effective

Page 4 of6against the tarnished plantbug, showed lowusage, but BEAD expects this to increase as growers adapt pestmanagementprograms 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 bythe registrants to EPA also show a declining presence ofprofenofos 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 oftarget 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 pesttrends may be valuable inthis context.

REFERENCES Atwood, D. 2012. Review ofBenefits for Sulfoxaflor for Fruiting Vegetables, Cucurbit Vegetables, Citrus, and Cotton. (DP# 384640). Internal BEAD memorandum available through the Official Records database. CaliforniaDept ofPesticide Regulation. Ellsworth, P. and L. Brown. 2012. FrequentlyAsked Questions: Brown Stink Bugs. Extension factsheet from the University ofArizona Cooperative Extension Service. Available onthe web at https:/ /cals.arizona.edu/crops/cotton/files/BSB FAQlo.pdf[Accessed May 2014] Proprietary Data. 1998-2012 Reisig, D.D. 2014. Insect Control on Cotton. Pp 78-81 In: 2014North CarolinaAgricultural Chemicals Manual. Available onthe 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 onthe web at www.ugacotton.com Sterling, S. A. 1999

...Analysis ofthe 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 onthe web atwww.ipmcenters.org [Accessed June 2014]. Stewart, S. and A. McClure. 2013. Insect Control Recommendations for Field Crops:

Page 5 of6Cotton, Soybean, Field Com, Sorghum, Wheat and Pasture. Publication# PB 1768 ofthe University ofTennessee Extension. Available onthe web at https://utextension.tennessee.edu/publications. [Accessed May 2014]. USDA. 2000. Crop Profile for Cotton in Arkansas. Available onthe web at www.ipmcenters.org. [Accessed July 2014]. USDA. 2002. Crop Profile for Cotton in Mississippi. Available onthe web at www.ipmcenters.org. [Accessed July 2014]. USDA. 2009. Crop Profile for Cotton in Texas. Available onthe web at www.ipmcenters.org. [Accessed July 2014].

Page 6 of6