Page 2 of 7 builds upon the data already provided in the “Usage and Label Use Data Packages” that are also provided to Registration Review teams by BEAD. The document is based on information and data available to BEAD as of October 4, 2012.

EPTC is in the Weed Science Society mechanis m of action group 8, a th iocarbamate herbicide (WSSA, 2011). Thiocarbamate herbicides inhibi t seedling growth. EPTC is used as a preemergence and early post-emergence herbicide to control growth of geminating annual weeds, including broadleaves, grasses, and sedges. EPTC does not control established weeds.

HISTORY OF BEAD ASSESSMENTS FOR EPTC

BEAD has not assessed the benefits of EPTC in the past.

COMMON FORMULATIONS A ND APPLICATION METHODS

EPTC is formulated as granular or emulsifiable concentrate and it is applied as a banded treatment, broadcast, chemigation, ground treatm ent, spot treatment, and as a strip spray.

USE SITES

Agricultural Uses

EPTC is labeled for use on alfalfa, beans (sna p, bush, pole, string), sweet corn, sugar beets, sunflowers, tomatoes, almonds, cotton, broccoli, fa llow, walnuts, lima beans, carrots, and citrus.

Non-Agricultural Uses

EPTC is labeled for use on ornamental trees, herbaceous plants, and woody shrubs and vines.

AGRICULTURAL USAGE Based on private market pesticide usage data, EPTC’s annual (2006 – 2011) agricultural usage averaged 1.6 million pounds of active ingredient treating an average of 592 thousand acres, for an average application ra te of 2.7 pounds per acre.

From 2006-2011, potatoes (47%), dry beans/peas (32%), and beans (11%) accounted for the largest percentages of usage in terms of total pounds of active i ngredient applied. For the same period of time (2006-2011), potatoes (40%), dry beans (38%), and beans (11%) accounted for the largest percentages of tota l area treated (TAT). Relative proportions indicate that the application rate for potatoes is somewhat higher th an the overall average rate while that for dry beans and peas is somewhat lower.

Table 1 below shows the top states in te rms of pounds applied and TAT from 2006-2011.Page 3 of 7 Table 1. EPTC’s Top States in Terms of Average Pounds Applied and TAT (2006-2011).

State Pounds Applied Total Area Treated (TAT)

Idaho 29% 26% Washington 15% 14%

Michigan 10% 14% (Proprietary data, 2006-2011).

USE TRENDS Figure 1 depicts usage trends, in terms of pounds a pplied, for EPTC’s largest agricultural market. Overall, the chart below shows that the use of EPTC decreased for all top crops from 1998 through 2011. In Figure 1, “Other” refers to (in order of high to low average pounds applied): alfalfa, beans (snap, bush, pole, string), sweet co rn, sugar beets, sunflowers, tomatoes, almonds, cotton, broccoli, fallow, walnut s, lima beans, and carrots.

Figure 1. Pounds of EPTC Applied on Major Crops (1998-2011).

Source: (Proprietary data, 1998-2011)

Figure 2 depicts the total pounds of EPTC used from 1998 to 2011. In it is eviden t that this chemical’s usage has been in decline. (Pr oprietary data, 1998-2011). Although slowing, this decline has continued through the 2006 to 2011 period analyzed above. 0 5,000,000

Corn

Potatoes

Dry Beans/Peas

OtherPage 4 of 7 Figure 2. Total Pounds of EPTC Applied from 1998-2011.

Source: (Proprietary data, 1998-2011)

ADDITIONAL USAGE INFORMATION

Another measure of usage is the use intensity. In this analysis, the use in tensity 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. applie d per treated acre. Note that the average appli cation rate is about 2.7 pounds per acre, or 2,700 pounds per 1,000 acres. The map shows the highest intensity of use is between 56 and 95 pounds per 1,000 acres. Figure 3 spatially represents EPTC's use intensity in the US. In Figure 3, concentrations of use can be seen. These correspond to potato production areas in the Central Washington, Sout hern Idaho, the San Luis Valley of Colorado, Central Wisconsin and Western Michigan. The use shown around the Saginaw Bay of Michigan is probably a result of use on dry edible beans. There is also high concen tration of use shown in the Willamette Valley and Coastal Oregon, alt hough these are not primary production areas for potatoes or dry beans; in this area the use seems to be on fresh beans. ‐ 10,000,000TotalPoundsAIApplied

YearPage 5 of 7 Figure 3. EPTC Usage by Crop Reporting District (2007 – 2011).

This is a map of agricultural pesticide usage at the Cr op Reporting District (CRD) level prepared by BEAD

for use in the Environmental Fate and Effects Division documents. These maps are used to help visualize where the pesticide being considered is most likely to be used and can be helpful in scenario selection and placing the exposure assessment in context. CRDs are boundaries created by USDA NASS which are aggregates of counties. Pesticide us age is displayed as average pounds (for the years 2007-2011) per 1,000

acres of farmland in a CRD to normalize for the vari ation in farmland between CRDs. Farmland acreage was obtained from USDA (2007). Farmland or “land in farms” is defined by USDA (2007) as follows:

The acreage designated as “land in farms” consists primarily of agricultural land used for crops, pasture, or grazing. It also includes woodland and wasteland not actually under cultivation or used for pastur e or grazing, provided it was part of the farm operator’s total operation. La rge acreages of woodland or wasteland held for nonagricultural purposes were deleted from individual reports during the edit process. Land in farms in cludes CRP, WRP, FWP, and CREP acres 1

. Land in farms is an operating unit concept and includes land owned and operated as well as land rented from othe rs. Land used rent free was reported as land rented from others. All grazing land, except land used under government permits on a per-head basis, was included as “land in farms” provided it was part of a farm or ranch. Land under the exclusive use of a grazing association was reported by the grazing association and included as land in farms. All land in American Indian reservations used for growing crops, grazing livestock, or

1 CRP: Conservation Reserve Program; WRP: Wetland Rese rve Program; FWP: Farmable Wetlands Program; CREP: Conservation Reserve Enhancement ProgramPage 6 of 7 the potential of grazing livestock was included as land in farms. Land inreservations not reported by reservation, individual American Indians or nonNative Americans was reported in the na me of the cooperative group that used the land. In many instances, an entire Am erican Indian reservation was reported as one farm (USDA, 2007).

Usage is based on private market surv eys of pesticide use in agriculture (Proprietary Data, 2007-2011). The survey data are limited to the stat es 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 non-participation in the agricultural surveys. In addition, across the years, there may be variations in the specific crops in cluded in the CRD survey. This may result in a lower annual average for the CRD.

This map displays ratio data (i.e., average pounds per 1,000 acres of farmland) summarized at a very highlevel. Readers are strongly cautioned against trying to over interpret the map without examination of the underlying data. The underlying data may explain some of the many reasons that a Crop Reporting District may have a high value for a particular active ingredient such as significant acreage (compared with the CRD as a whole) of a crop or crops with a high application rate and frequency of application.

The reader should pay particular attention to the fi gure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepar ed for a different chemical. Scale and units of measurement do matter and may be different between maps.

NON-AGRICULTURAL USAGE

Available non-agricultural databases were consulted yet no usage was found.

BIOLOGICAL ASPECTS RELEVANT TO EPTC

The Weed Science Society of America documents weed resistance to Group 8/thiocarbamate herbicides but does not list EPTC as the specif ic herbicide with the resistance issue (WSSA, 2012). However, the Montana State University Exte nsion lists a biotype of wild oat as a weed resistant to EPTC in Montana (MSU Extensi on, 2011). Pest manageme nt guidelines indicate that repeated annual use of EPTC may result in weed resistance or decrease herbicide performance (UC IPM, 2011). This may be the re sult of increased levels of soil microbes that degrade EPTC (KSRE, 2010; UC IPM, 2011). Rotati ons with herbicides of different chemistries are an option for preventing resistance as r ecommended by pest management guideline (UC IPM, 2011). Overall, herbicide resistance does no t appear to be a widespread problem with EPTC (WSSA, 2012).

INFORMATION THAT MAY BE USEFUL FO R BEAD’S FUTURE WORK ON EPTC

Obtaining additional information on non-agricultural usage, such as pounds active ingredient applied per year by site, would improve future BEAD assessments of the importance of EPTC and may be required as part of the re gistration review of this pesticide.Page 7 of 7 REFERENCES

KSRE, 2010. Herbicide mode of action. Kansas St ate University research and extension: C-715.

Online: http://www.ksre.ksu.edu/ library/crpsl2/c715.pdf . Verified: October 11, 2012.

MSU Extension, 2011. Preventing and managing he rbicide-resistant w eeds in Montana. Montana State University Extension. MontGuide: MT200506AG. Online: http://msuextension.org/publications /AgandNaturalResources/MT200506AG.pdf . Verified: October 10, 2012.

Proprietary data, 1998-2011.

Proprietary Data, 2007-2011.

UC IPM, 2011. UC IPM Pest Management Guide lines: Corn – special weed problems. UC

ANR Publicaiton 3443. Online: http://www.ipm.ucdavis.edu/PMG/r113700211.html

. Verified: October 3, 2012.

USDA, 2007. Census of Agriculture. Online: http://www.agcensus.usda.gov/ Publications/2007/index.asp and http://www.agcensus.usda.gov/Publications/2007 /Full_Report/Volume_1,_Chapter_1_US/usa ppxb.pdf . Verified: October 10, 2012.

WSSA, 2012. Thiocarbamates and other (N/8) resistant weeds. Online: http://www.weedscience.org/Summary/Us peciesMOA.asp?lstMOAID=22&FmHRACGroup=Go Verified: October 3, 2012.

WSSA, 2011. WSSA classificati on of herbicide mechanism of action (revised June 10, 2011).

Online: http://www.wssa.net/Weeds/Resist ance/WSSA-Mechanism-of-Action.pdf and http://www.wssa.net/Weeds/Resistance/index.htm . Verified: October 3, 2012.