I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D

.C

. 20460 

## 'JUL 15 20f3

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION 

### MEMORANDUM

SUBJECT: BEAD Chemical Profile (BCP) for Registration Review: Methyldithiocarbamate Salts Chemical Case [Includes Metam-sodium (039003) and Metam-potassium (039002)] FROM:

THRU:

TO: Tara Chandgoyal, Plant Pathologist Biological Analysis Branch Rafael A. Prieto, Environmental Protection Specialist$ W { ·

# ~ Science Information and Analysis Branch 

# L · ' lf'' -f**~** AndrewLee, Economist 

# ;;i(**~** Economic Analysis Branch Biological and Economic Analysis Division (7. 3P) Arnet Jones, Chief 

# /l · IJ,) Biological Analysis

## Branc**~** { Diann Sims, Chief

# ~~ W Science Information and Analysis Branch Timothy Kiely, Chief 

# rtJ -J- 

# VVl

# ~ Economic Analysis Branch 

### I 

# WJ Biological and Economic Analysis Division (7 P) Jose Gayoso, Chemical ReviewManager Risk Management and ImplementationBranch2 Pesticide Re-evaluation Division (7508P) 

### ProductReview Panel Date: April 3, 2013 INTRODUCTION The purpose ofthis document is to convey usage information and a broad overview ofthe pest managementroles ofpesticides that are beginning to undergo registration review. The anticipated audience consists ofthe team ofEPA staffcurrently evaluating the registration status Page 1 of13ofmethyldithiocarbamate salts and eventuallythe general public. This document builds uponthe data already provided inthe usage and label use datapackages that are also providedto Registration Reviewteams byBEAD. The document is based on information and data available to BEAD as ofMarch 20,2013. Metam-sodium andmetam-potassium are broad spectrum non-selective fumigants with fungicidal, herbicidal, insecticidal andnematicidal properties. Metam-sodium and metampotassium were registered inthe United States in 1975 and 1973, respectively. A Reregistration Eligibility Decision (RED) for methyldithiocarbamate salts (metam-sodium, metam-potassium and methyl isothiocyanate (MITC) was issued in 2008. (http://www.epa.gov/oppsrrdl/REDs/metamsodium-red.pdt). The RED imposes some restrictions (such as buffer zones) onthe use ofmetam-sodium andmetam-potassium that may affectthe use ofthese fumigants. These changes are notreflected in current usage data. 

### COMMONFORMULATIONSAND APPLICATION METHODS Both metam-sodium and metam-potassium are formulated as soluble concentrate, ready-to-use solution, andpressurized gas. They are applied as fumigation, chemigation, soil treatment, soil drenchtreatment, soil fumigation, soil broadcasttreatment, soil contact fumigation, soil shanking treatment, soil incorporatedtreatment by irrigation, transplant watertreatment, soak, foam application, bore-hole treatment, spray, spray blade, tarp, preservative treatment, sewage treatment, manure treatment, additive treatment, watertreatment, watertreatment (recirculating system), off-line treatment, and on-line treatment. 

### Agricultural Use Sites Metam-sodium Metam-sodium is registered for use on alfalfa, Douglas-fir (forest/shelterbelt), forest nursery plantings (fortransplantpurposes), forest plantings (reforestationprograms)(tree farms, tree plantations, etc.), forest trees, golfcourse turf, grasses grown for seed, nursery stock, ornamental herbaceous plants, ornamental lawns and

### turf, ornamental sodfarm (turf), ornamentals (unspecified), ornamental woody shrubs and vines, southernpines (forest), anise, artichoke, asparagus, barley, basil, beans, beets, broccoli, Chinese broccoli, Brussels sprouts, cabbage, Chinese cabbage, canolalrape, carrot, cauliflower, celeriac, chive, citrus, clover, collards, coriander/cilantro, com, cotton, cucurbitvegetables, dill, eggplant, flavoring/spice crops, garlic, ginger, grapes, greens, guava, herbs, kale, kiwi fruit, kohlrabi, leafy greens, leek, mango, mint, mustard, mustard cabbage (gai choy, pak-choi), oats, onion, orchards (unspecified), parsnip, passion fruit (granadilla), peanuts, peas, pepper, pome fruits, radish, potatoes, Chinese radish, daikon, rutabaga, rye, salsify, seeds, shallot, skirret, small fruits, soybeans, stone fruits, strawberry, sugar beet, sweetpotato, tree nuts, turnip, wheat, and yam. Metam-potassium Metam-potassium is registered for use on alfalfa, forest nursery plantings (for transplant purposes), golfcourse turf, orchards, ornamental and/or shade trees, ornamental herbaceous Page 2 of13plants, ornamental lawns and

### turf, ornamental nonflowering plants, ornamental woody shrubs and vines, pine seedlings, amaranth, anise, apple, apricot, artichoke, asparagus, barley, basil, beans, limabeans, beets, broccoli, broccoli raab, Brussels sprouts, cabbage, Chinese cabbage, calamondin, cardoon, carrot (including tops), cauliflower, celeriac, celery, celtuce, Swiss chard, chayote, cherry, chervil, chinquapin, chrysanthemum;citron (citrus), citrus hybrids otherthan tangelo, collards, coriander/cilantro, corn, cotton, crabapple, upland cress, cucumber, cucurbit vegetables, cucuzzi (spaghetti squash), currant, dandelion, dill, dock (sorrel), eggplant, endive (escarole), fennel, garlic, gherkin, ginger, gourds, grapefruit, grapes, Chinese greens, guava, herbs, kale, kiwi fruit, kohlrabi, kumquat, leek, lemon, lettuce, lime, loquat, mango, mayhaw (hawthorn), melons (bitter, balsampear, cantaloupe, citron, honeydew, mango, musk, watermelon, casaba, crenshaw, persian), mint, mustard, nectarine, nursery stock, Chinese okra (hechima), onion, orach (mountain spinach), orange, parsley, peach, peanuts, pear, peas, pepper, plum, prune, purnmelo (shaddock), pumpkin, gardenpurslane, winterpurslane, quince, radicchio, radish, Chinese radish, rhubarb, roquette (arugula), rye, small fruits, soybeans, spinach, NewZealand spinach, squash (butternut, summer, winter [hubbard], zucchini), sugar beet, sweetpotato, tangelo, tangerines, tobacco, tree nuts, turnip (greens), turnip (root), wheat, and yam. 

### Non-Agricultural Use Sites Metam-sodium Metam-sodium is registered as an antimicrobial agent for: (1) wood poles/timbers, (2) leather processing (e.g., brine-cured hides and skins), 

### (3) raw cane and beet sugarprocessing facilities, and (4) sewage sludge/animal wastes. Metam-potassium Metam-potassium is registered as an antimicrobial agent for: (1) pulp and paperproduction, (2) leatherprocessing, (3) raw cane and beet sugarprocessing facilities, (4) coatings (protective colloids, emulsionresins, and water-thinnedpaints), (5) metal working cutting fluids and oils, (6) petroleum operations, (7) water cooling tower systems, and (8) industrial waterpurification systems. 

### AGRICULTURAL USAGE TRENDS Metam-sodium Figure 

### 1 depicts usage trends, interms ofpounds A. 

### I. applied, for metam-sodium's surveyed crops. Overall, the chart below shows thatthe use ofmetam-sodium is showing a fluctuation in usage from 1998 through 2011, withusage spikes in 2004 and 2007. Figure 2 shows average pounds ofmetam-sodium applied onits majoruses. (Proprietary data, 1998-2011).

Page 3 of13

### Figure 

### 1. TotalPounds ofMetam-sodium Applied on All Surveyed Crops (1998-2011)
80,000,000

0 0 0 N

Source: (Proprietary data, 1998-2011) .-t 0 0 N N 0**~** C'l'l 0 0 N



### Fi ure 2. Avera e Pounds ofMetam-sodium A



## < ., "':J c :s 0 Q.

0 co 0\ 0 .-t 0\ 0\ 0 0 0\ 0\ 0 0 .-t .-t N N N 0 0 N C'l'l 0 0 N '<:!' 0 0 N L/') 

### 8 N Year '<:!' 0 0 N L/') 0 0 N Year

ID 0 0 N ..... 0 0 N ID 0 0 N**~** 0 N 0\ 0 0 N ..... 0 0 N

0

.-t 0 N co 0 0 N

.-t .-t 0 N 0 .-t 0 N .-t .-t 0 N

- Potatoes

-.-carrots**Tomatoes**

Note: "Other"refers to (in order ofhigh to low average pounds applied): Onions, peppers, watermelons, cantaloupes, peanuts, lettuce, strawberries, spinach, broccoli, garlic, cucumbers, squash, sweet com, celery, beans (snap, bush, pole, string), cabbage, apples, artichoke, cauliflower, cherries, oranges, tobacco, peas (fresh/green/sweet), table grapes, peaches, caneberries, walnuts, pears, pumpkins, asparagus, almonds, wine grapes, grapefruit, and lemons. Source: Proprietary data, 1998-2011 

### Metam-potassium Figure 3 depicts usage trends, interms ofpounds A. I. 

### applied, for metam-potassium's surveyed crops. Overall, the chart below shows thatthe use ofmetam-potassium increased rapidly from 2000 with a spike in 2009. Figure 4 includes average pounds (a.i.) ofmetam-potassiumused on major crops from 2000 through 2011. (Proprietary data, 2000-2011). Page 4 of13

### Figure 3. Total Pounds ofMetam-potassium Applied onAll Surveyed Crops (2000-2011)
20,000,000

Year Source: (Proprietary data, 2000-2011) 

### Fi re 4. Pounds ofMetam- otassium A lied on Main Cro s 2000-2011

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Year - Potatoes

-.-Tomatoes**Other**

Note: "Other"refers to (in order ofhigh to low average pounds applied): Lettuce, peppers, carrots, onions, strawberries, watermelons, spinach, beans (snap, bush, pole, string), cantaloupes, garlic, celery, squash, cotton, pumpkins, cucumbers, asparagus, cabbage, sweet com, and peanuts. Source: Proprietary data, 2000-2011 

### NON- AGRICULTURAL USAGE TRENDS Non-agricultural usage datafor metam-sodium and metam-potassium are not available

.

Page 5 

### of13

### CURRENT USAGE Metam-sodium Basedonprivate market pesticide usage data from 2006-2011, metam-sodium's annual agricultural usage averaged 42 millionpounds ofactive ingredient (A. I.), treating an average of approximately 307 thousand acres, for an average applicationrate of 136 pounds active ingredientper acre. These data do notreflect changes in label directions specified inthe recent 

### RED. From 2006-2011, potatoes (57%) and carrots (17%) accounted for the largest percentages of usage interms oftotal pounds ofA. I. applied. Again, for the same time period, potatoes (55%) and carrots (14%) accounted for the largestpercentages oftotal area treated (TAT). As shownin Table 1below, the states with highest pounds active ingredient (lbs. a.i.) applied andtotal areatreated (TAT) for metam-sodium are Washington, California and Idaho. 

### Table 

### 1. Metam-sodium's Top States in Terms ofLbs. Applied & 

### TAT in Acres (2006- 201

Source: (Proprietary data, 2006-2011). 

### Metam-potassium Based onprivate market pesticide usage data from 2006-2011, metam-potassium's annual agricultural usage averaged 12 millionpounds ofactive ingredient (A. I.), treating an average of approximately 77 thousand acres, for an average applicationrate of 150 poundsper acre. From 2006-2011, potatoes (56%) andtomatoes (14%) accounted for the largestpercentages of usage interms oftotal pounds ofA. I. applied. Forthe same period oftime potatoes (51%) and tomatoes (16%) accounted for the largestpercentages oftotal areatreated (TAT). As shown in Table 2 below, the states with highestpounds (lbs.) applied andtotal areatreated (TAT) for metam-potassium are Idaho, California, andWashington. 

### Table2. Metam-potassium's Top States in Terms ofLbs. Applied & TAT in Acres (2006-

20% Source: (Proprietary data, 2006-2011).

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### Figure 5. Metam-sodium Usage by Crop ReportingDistrict (2007-2011) Another measure ofusage is the use intensity. The average applicationrate of 136 pounds per acre implies a rate of 136,000 pounds per 1,000 treated acres. The higher intensity depicted in the map (Figure 5) in Southern Californiacorrespond to areas where cucurbits, peppers and tomatoes are grown in that State. The higher intensity inthe map belowfor Central Washington corresponds to metam-sodium usage for the cultivation ofpotatoes. 

### Metam-Sodium Usage by Crop ReportingDistrict (2007- 2011)

Average Pounds Per 1,000Acres of Farmland

- <11 11- 28 0 29-71 72- 120 121

- 190

This is a map ofagricultural pesticide usage at the Crop 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 ofcounties. Pesticide usage is displayed as average pounds (for the years 2007-2011) per 1,000 acres offarmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acreage was obtained from USDA (2007). Farmland or "land in farms" is defmed as follows: The acreage designated as "land in farms" consists primarily ofagricultural land used for crops, pasture, or grazing. It also includes woodland and wasteland not actually under cultivation or used for pasture or grazing, provided it was part of the farm operator's total operation

. Large acreages of woodland or wasteland held for nonagricultural purposes were deleted from individual reports during 

### Page 7 of13the edit process. Land in farms includes CRP, WRP, FWP, and CREP acres. Land in farms is an operating unit concept and includes land owned and operated as well as land rented from others. 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 ofa farm or ranch. Land under the exclusive use ofa 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 the potential of grazing livestock was included as land in farms

. Land in reservations not reported by reservation, individual American Indians or nonNative Americans was reported in the name ofthe cooperative group that used the land

. In many instances, an entire American Indian reservation was reported as one farm (USDA, 2007). Usage is based on private market surveys ofpesticide use in agriculture (Proprietary Data, 2007-2011). 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 ofpesticide use in the region or non-participation 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. This map displays ratio data (i.e., average pounds per I,000 acres offarmland) 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 ofthe 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) ofa crop or crops with a high application rate and frequency ofapplication

. The reader should pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical. Scale and units of measurement do matter and may be different between maps. Sources: Proprietary Data. 2007-2011. USDA, 2007. Census ofAgriculture.



### Page 8 of13

### Figure 6. Metam-potassium Usage by Crop ReportingDistrict (2007-2011) Another measure ofusage is the use intensity. The average application rate of 139 pounds per acre implies a rate of 139,000 pounds per 1,000 treated acres. The higher intensity depicted in the map below for the lower Central Valley ofIdaho corresponds to metam-potassiumusage for the cultivation ofpotatoes. 

### Metam-potassium Usage by Crop ReportingDistrict (2007- 2011)

Average Pounds Per 1,000Acres of Farmland



# - <4

4- 15 

## D 16-27 28-65 66- 115

This is a map ofagricultural pesticide usage at the Crop 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 ofcounties

. Pesticide usage is displayed as average pounds (for the years 2007-2011) per 1,000 acres offarmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acreage was obtained from USDA (2007)

. Farmland or "land in farms" is defined as follows: The acreage designated as "land in farms" consists primarily ofagricultural land used for crops, pasture, or grazing. It also includes woodland and wasteland not actually under cultivation or used for pasture or grazing, provided it was part of the farm operator's total operation. Large acreages of woodland or wasteland held for nonagricultural purposes were deleted from individual reports during the edit process. Land in farms includes CRP, WRP, FWP, and CREP acres. 

### Page 9 of13Land in farms is an operating unit concept and includes land owned and operated as well as land rented from others

. 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 ofa 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 the potential of grazing livestock was included as land in farms. Land in reservations not reported by reservation, individual American Indians or nonNative Americans was reported in the name ofthe cooperative group that used the land. In many instances, an entire American Indian reservation was reported as one farm (USDA, 2007). Usage is based on private market surveys ofpesticide use in agriculture (Proprietary Data, 2007-2011)

. 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 ofpesticide use in the region or non-participation 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. This map displays ratio data (i.e

., average pounds per 1,000 acres offarmland) 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 ofthe 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) ofa crop or crops with a high application rate and frequency ofapplication. The reader should pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical. Scale and units of measurement do matter and may be different between maps. Sources: Proprietary Data. 2007-2011 USDA, 2007. Census ofAgriculture 

### Future Use Future use ofmetam-sodium and metam-potassium may be impactedby additional regulations (EPA, 2008) that went into effect in December 2012. These include buffer zones, restricted entry into treated zone, Good Agricultural Practices, and additional workerprotection standards. Also, future reductions in methyl bromide use may result in increased reliance onmetam-sodium and metam-potassium. 

### BIOLOGICALASPECTS RELEVANT TOMETHYLDITHIOCARBAMATE SALTS Metam-sodium and metam-potassium are non-selective fumigant biocides. They are used as preplant soil fumigants for use on all food, feed and fiber cropsto kill soil dwelling pests (fungi, weeds, insects, and nematodes). There are several non-agricultural uses ofthese fumigants. After application metam-sodium and metam-potassium break down quickly to the primarytoxic degradate, methyl isothiocyanate (MITC) gas. MITC is highly volatile and is responsible for biocidal properties ofthese fumigants. Page 10 of13

### Usage data indicate thatthere is an increase inthe use ofmetam-potassium from 2005 to 2011 (Figure 

### 3) whereas this was notthe case withmetam-sodium. Metam sodium and metam potassium, when applied to soil as fumigants, generate methyl isothiocyanate gas thatkills soil borne pests. These fumigants are alternatives to methyl bromide for controlling soil-borne pests ofagricultural crops. The use ofthese fumigants is likely to increase inthe future because they are alternatives to methyl bromide, which is being phased out (http://www.epa.gov/ozone/mbr ) under the Montreal Protocol (Chism, 2013). IDSTORY OF BEAD ASSESSMENTS FORMETHYLDITIDOCARBAMA TE SALTS Most ofthe BEAD work on metam-sodium and metam-potassium has been inthe context of benefits assessments or impact assessments for other fumigants including methyl bromide, for whichmetam-sodium and metam-potassium could be alternatives. In 2007, BEAD summarized the assessed benefits ofsoil fumigation withmetam-sodium on 

### 14 different crops as summarized inTable 3 (Wyatt 2007). It

### was concluded that metam-sodium is used to treat a variety ofpests, including soil plantpathogens, nematodes, weeds, and insects. The benefits offumigation with metam-sodium include increases in yields and reductions inproduction costs. In 

### some cases, metam-sodium makes crop productionviable where pestpressure would otherwise betoo great. BEAD assessed a selection ofcrops (see Wyatt 2007 for a summary), representing those with the highest fumigant usage interms ofpercent ofcrop area treated and total pounds applied. The benefits are generally divided betweenproducers, who benefit from higher net operating revenue, and consumers, who benefit from increased supply and lower prices. The details ofthe crop analyses are presented below in Table 3. 

### Table 3 

### Assessment ofBenefits ofMetam-Sodium by Crops (Wyatt2007) Crop Title Authors Carrot Assessment ofthe Benefits ofSoil Fumigation with David Donaldson and Metam-Sodium in Carrot Production Richard Michell Cucurbits Assessment ofthe Benefits ofSoil Fumigationwith Bill Chism and David Chloropicrin, Methyl Bromide, and Metam-Sodium Donaldson in Cucurbit Production Eggplant Assessment ofthe Benefits ofSoil Fumigation with Angel Chiri and David Chloropicrin, Metam-Sodium, and Methyl Bromide Donaldson inEggplantProduction Nursery, Fruit, Assessment ofthe Benefits ofSoil Fumigationwith Leonard Yourman and Nut, &Rose Chloropicrin, Dazomet, Metam-Potassium, and Steve Smearman Metam-Sodium Use for Fruit and NutDeciduous Tree Nurseries and Rose BushNurseries in CaliforniaProduction Onion Assessment ofthe Benefits ofSoil Fumigation with Tara Chandgoyal and Metam-Sodium and Chloropicrin in Onion JinKim Production Orchard Replant- Assessment ofthe Benefits ofSoil Fumigationwith Leonard Yourman and Grapes Methyl Bromide, Chloropicrin, and Metam-Sodium TJ Wyatt in Grape Production Page 11 of13

### Orchard Replant- Assessment ofthe Benefits ofSoil Fumigation with Leonard Yourman and Pome Fruits Chloropicrin and Metam-Sodium in Pome Fruit TJ Wyatt Production Orchard Replant Assessment ofthe Benefits ofSoil Fumigation with Leonard Yourman and Stone Fruit Methyl Bromide, Chloropicrin, and Metam-Sodium TJ Wyatt in Stone Fruit Production Ornamentals Assessment ofthe Benefits ofSoil Fumigation with Nicole Zinn and Steve Chloropicrin, Methyl Bromide, Metam-Sodium and Smearman Dazomet inOrnamental Production Peanut Assessment ofthe Benefits ofSoil Fumigationwith Angel Chiri and TJ Metam-Sodium in Peanut Production Wyatt Pepper, Bell Assessment ofthe Benefits ofSoil Fumigation with Bill Chism and David Chloropicrin, Methyl Bromide and Metam-Sodium Donaldson in Bell PepperProduction Potato Assessment ofthe Benefits ofSoil Fumigationwith Tara Chandgoyal and Metam-Sodium inPotato Production Derek Berwald SweetPotato Assessment ofthe Benefits ofSoil Fumigation with Sunil Ratnayake and**Metam~Sodium** 

### and Chloropicrin in Sweet Potato Andrew Lee Production Tomato Assessment ofthe Benefits ofSoil Fumigationwith Nikhil Mallampalli Chloropicrin, Methyl Bromide and Metam-Sodium and Elisa Rim in Tomato Production

In 2008, BEAD assessed alternatives to metam-sodium for the control ofplantroots in sewer lines (Ratnayake and Chandgoyal, 2008). Metam-sodium is used as the major chemical to control plantroots and clean clogs in sewage lines. The alternatives analysis showedthat there are efficacious registered herbicides for the control ofplantroots in sewerlines. Onthe basis of available information in 2008, diquat dibromide seemedto be the likely alternative to metam sodium for the control ofplantroots in sewer lines. 

### INFORMATION THAT MAY BE USEFUL FORBEAD'S FUTURE WORKON METHYLDITHIOCARBAMATE SALTS Additional information on non-agricultural use ofmetam-sodium and metam-potasium use would improve future BEAD assessments ofthe importance ofthese fumigants and may be required as a part ofthe registrationreview for these pesticides. Useful requested data would include, but is not limited to, usage data (application timing, application rates, application methods, and application frequency).



### REFERENCES 1998-2011 Proprietary Data.

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### Chism, B. 2013. Personal communications with the senior agronomist (BEAD, US-EPA) onthe use offumigants in control plantpests. February, 2013. USDA, 2006-2011. NASS Crop Reporting Districts. Online: http://www.ers.usda.gov/briefing/arms/resourceregions/resourceregions.htm#nass. USDA, 2007. Census ofAgriculture. Online: Online: http://www.agcensus.usda

.gov/Publications/2007/index.asp

. Ratnayake Sand Chandgoyal. T. 2008. Alternative assessment onroot control use ofmetamsodium in sewer lines (DP# 293361). BEAD's Official Record. Wyatt, T.J. 2007. Summary ofthe assessments ofthe benefits ofsoil fumigation withmetamsodium in cropproduction (DP# 337501). BEAD's Official Record

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