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 

Science 

A. 

Information 

Prieto, Environmental 

and Analysis 

Protection 

Branch 

SpecialistL$

·'lf W '' { -f · ~ ~ 

Andrew 

Economic 

Lee, 

Analysis 

Economist 

Branch 

;;i ( ~ 

Biological and Economic Analysis Division (7. 3P) 

Arnet Jones, Chief /l · IJ,) 

Biological Analysis Branc~ { 

Diann Sims, Chief ~~ W 

Science Information and Analysis Branch 

Economic 

Timothy Kiely, 

Analysis 

Chief 

Branch 

rtJ 

I WJ -J- VVl ~ 

Biological and Economic Analysis Division (7 P) 

Jose Gayoso, Chemical Review Manager 

Risk Management and Implementation Branch 2 

Pesticide Re-evaluation Division (7508P) 

Product Review Panel Date: April 3, 2013 

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 

Page 1 of13 
of methyldithiocarbamate salts and eventually the general public. This document 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 March 20,2013. 

Metam-sodium and metam-potassium are broad spectrum non-selective fumigants with 

fungicidal, herbicidal, insecticidal and nematicidal properties. Metam-sodium and metampotassium were registered in the 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) on the use ofmetam-sodium and metam-potassium that may 

affect the use of these fumigants. These changes are not reflected in current usage data. 

COMMON FORMULATIONS AND APPLICATION METHODS 

Both metam-sodium and metam-potassium are formulated as soluble concentrate, ready-to-use 

solution, and pressurized gas. They are applied as fumigation, chemigation, soil treatment, soil 

drench treatment, soil fumigation, soil broadcast treatment, soil contact fumigation, soil shanking 

treatment, soil incorporated treatment by irrigation, transplant water treatment, soak, foam 

application, bore-hole treatment, spray, spray blade, tarp, preservative treatment, sewage 

treatment, manure treatment, additive treatment, water treatment, water treatment (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 (for transplant purposes), forest plantings (reforestation programs)(tree farms, tree 

plantations, etc.), forest trees, golf course turf, grasses grown for seed, nursery stock, ornamental 

herbaceous plants, ornamental lawns and turf, ornamental sod farm (turf), ornamentals 

(unspecified), ornamental woody shrubs and vines, southern pines (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, cucurbit vegetables, 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, sweet potato, tree nuts, turnip, wheat, and yam. 

Metam-potassium 

Metam-potassium is registered for use on alfalfa, forest nursery plantings (for transplant 

purposes), golf course turf, orchards, ornamental and/or shade trees, ornamental herbaceous 

Page 2 of13 
plants, ornamental lawns and turf, ornamental nonflowering plants, ornamental woody shrubs 

and vines, pine seedlings, amaranth, anise, apple, apricot, artichoke, asparagus, barley, basil, 

beans, lima beans, 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 other than 

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, balsam pear, 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, garden purslane, winter purslane, quince, 

radicchio, radish, Chinese radish, rhubarb, roquette (arugula), rye, small fruits, soybeans, 

spinach, New Zealand spinach, squash (butternut, summer, winter [hubbard], zucchini), sugar 

beet, sweet potato, 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 sugar processing facilities, 

and ( 4) sewage sludge/animal wastes. 

Metam-potassium 

Metam-potassium is registered as an antimicrobial agent for: (1) pulp and paper production, (2) 

leather processing, (3) raw cane and beet sugar processing facilities, (4) coatings (protective 

colloids, emulsion resins, and water-thinned paints), (5) metal working cutting fluids and oils, (6) 

petroleum operations, (7) water cooling tower systems, and (8) industrial water purification 

systems. 

AGRICULTURAL USAGE TRENDS 

Metam-sodium 

Figure 1 depicts usage trends, in terms of pounds A. I. applied, for metam-sodium's surveyed 

crops. Overall, the chart below shows that the use of metam-sodium is showing a fluctuation in 

usage from 1998 through 2011, with usage spikes in 2004 and 2007. Figure 2 shows average 

pounds of metam-sodium applied on its major uses. 

(Proprietary data, 1998-2011). 

Page 3 of13 
Figure 1. Total Pounds ofMetam-sodium Applied on All Surveyed Crops (1998-2011) 

80,000,000 

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- Potatoes 

-.-carrots 

Tomatoes 

Note: "Other" refers to (in order of high 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, in terms of pounds A. I. applied, for metam-potassium's surveyed 

crops. Overall, the chart below shows that the use of metam-potassium increased rapidly from 

2000 with a spike in 2009. Figure 4 includes average pounds (a.i.) ofmetam-potassium used on 

major crops from 2000 through 2011. (Proprietary data, 2000-2011). 

Page 4 of13 
Figure 3. Total Pounds of Metam-potassium Applied on All 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 of high 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 data for metam-sodium and metam-potassium are not available. 

Page 5 of13 
CURRENT USAGE 

Metam-sodium 

Based on private market pesticide usage data from 2006-2011, metam-sodium's annual 

agricultural usage averaged 42 million pounds of active ingredient (A. I.), treating an average of 

approximately 307 thousand acres, for an average application rate of 136 pounds active 

ingredient per acre. These data do not reflect changes in label directions specified in the recent 

RED. 

From 2006-2011, potatoes (57%) and carrots (17%) accounted for the largest percentages of 

usage in terms of total pounds of A. I. applied. Again, for the same time period, potatoes (55%) 

and carrots (14%) accounted for the largest percentages of total area treated (TAT). 

As shown in Table 1 below, the states with highest pounds active ingredient (lbs. a.i.) applied 

and total area treated (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 on private market pesticide usage data from 2006-2011, metam-potassium's annual 

agricultural usage averaged 12 million pounds of active ingredient (A. I.), treating an average of 

approximately 77 thousand acres, for an average application rate of 150 pounds per acre. 

From 2006-2011, potatoes (56%) and tomatoes (14%) accounted for the largest percentages of 

usage in terms of total pounds of A. I. applied. For the same period oftime potatoes (51%) and 

tomatoes (16%) accounted for the largest percentages of total area treated (TAT). 

As shown in Table 2 below, the states with highest pounds (lbs.) applied and total area treated 

(TAT) for metam-potassium are Idaho, California, and Washington. 

Table 2. Metam-potassium's Top States in Terms ofLbs. Applied & TAT in Acres (2006-

20% 

Source: (Proprietary data, 2006-2011). 

Page 6 of13 
Figure 5. Metam-sodium Usage by Crop Reporting District (2007-2011) 

Another measure of usage is the use intensity. The average application rate 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 California correspond to areas where cucurbits, peppers and 

tomatoes are grown in that State. The higher intensity in the map below for Central Washington 

corresponds to metam-sodium usage for the cultivation of potatoes. 

Metam-Sodium Usage by Crop Reporting District (2007- 2011) 

Average Pounds Per 

1,000 Acres of Farmland 

- <11 

11- 28 

0 29-71 

72- 120 

121 - 190 

This is a map of agricultural 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 of counties. Pesticide usage is displayed as average pounds (for the years 2007-2011) per 1,000 

acres of farmland 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 of agricultural 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 of13 
the 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 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 

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 of the 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 of pesticide 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 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 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 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 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. 2007-20 11. 

USDA, 2007. Census of Agriculture. 

Page 8 of13 
Figure 6. Metam-potassium Usage by Crop Reporting District (2007-2011) 

Another measure of usage 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 of Idaho corresponds to metam-potassium usage for 

the cultivation of potatoes. 

Metam-potassium Usage by Crop Reporting District (2007- 2011) 

Average Pounds Per 

1,000 Acres of Farmland 

- <4 

4- 15 

D 16-27 

28-65 

66- 115 

This is a map of agricultural 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 of counties. Pesticide usage is displayed as average pounds (for the years 2007-2011) per 1,000 

acres of farmland 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 of agricultural 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 of13 
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 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 

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 of the 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 of pesticide 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 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 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 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 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 of Agriculture 

Future Use 

Future use of metam-sodium and metam-potassium may be impacted by 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 worker protection standards. Also, 

future reductions in methyl bromide use may result in increased reliance on metam-sodium and 

metam-potassium. 

BIOLOGICAL ASPECTS RELEVANT TO METHYLDITHIOCARBAMATE 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 crops to kill soil dwelling pests (fungi, 

weeds, insects, and nematodes). There are several non-agricultural uses of these fumigants. After 

application metam-sodium and metam-potassium break down quickly to the primary toxic 

degradate, methyl isothiocyanate (MITC) gas. MITC is highly volatile and is responsible for 

biocidal properties of these fumigants. 

Page 10 of13 
Usage data indicate that there is an increase in the use ofmetam-potassium from 2005 to 2011 

(Figure 3) whereas this was not the case with metam-sodium. Metam sodium and metam 

potassium, when applied to soil as fumigants, generate methyl isothiocyanate gas that kills soil 

borne pests. These fumigants are alternatives to methyl bromide for controlling soil-borne pests 

of agricultural crops. The use of these fumigants is likely to increase in the 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 FOR METHYLDITIDOCARBAMA TE SALTS 

Most of the BEAD work on metam-sodium and metam-potassium has been in the context of 

benefits assessments or impact assessments for other fumigants including methyl bromide, for 

which metam-sodium and metam-potassium could be alternatives. In 2007, BEAD summarized 

the assessed benefits of soil fumigation with metam-sodium on 14 different crops as summarized 

in Table 3 (Wyatt 2007). It was concluded that metam-sodium is used to treat a variety of pests, 

including soil plant pathogens, nematodes, weeds, and insects. The benefits of fumigation with 

metam-sodium include increases in yields and reductions in production costs. In some cases, 

metam-sodium makes crop production viable where pest pressure would otherwise be too great. 

BEAD assessed a selection of crops (see Wyatt 2007 for a summary), representing those with the 

highest fumigant usage in terms of percent of crop area treated and total pounds applied. The 

benefits are generally divided between producers, who benefit from higher net operating 

revenue, and consumers, who benefit from increased supply and lower prices. The details of the 

crop analyses are presented below in Table 3. 

Table 3 Assessment of Benefits of Metam-Sodium by Crops (Wyatt 2007) 

Crop Title Authors 

Carrot Assessment of the Benefits of Soil Fumigation with David Donaldson and 

Metam-Sodium in Carrot Production Richard Michell 

Cucurbits Assessment of the Benefits of Soil Fumigation with Bill Chism and David 

Chloropicrin, Methyl Bromide, and Metam-Sodium Donaldson 

in Cucurbit Production 

Eggplant Assessment of the Benefits of Soil Fumigation with Angel Chiri and David 

Chloropicrin, Metam-Sodium, and Methyl Bromide Donaldson 

in Eggplant Production 

Nursery, Fruit, Assessment of the Benefits of Soil Fumigation with Leonard Y ourman and 

Nut, &Rose Chloropicrin, Dazomet, Metam-Potassium, and Steve Smearman 

Metam-Sodium Use for Fruit and Nut Deciduous 

Tree Nurseries and Rose Bush Nurseries in 

California Production 

Onion Assessment of the Benefits of Soil Fumigation with Tara Chandgoyal and 

Metam-Sodium and Chloropicrin in Onion JinKim 

Production 

Orchard Replant- Assessment of the Benefits of Soil Fumigation with Leonard Y ourman and 

Grapes Methyl Bromide, Chloropicrin, and Metam-Sodium TJ Wyatt 

in Grape Production 

Page 11 of13 
Orchard Replant- Assessment of the Benefits of Soil Fumigation with Leonard Y ourman and 

Pome Fruits Chloropicrin and Metam-Sodium in Pome Fruit TJ Wyatt 

Production 

Orchard Replant Assessment of the Benefits of Soil Fumigation with Leonard Y ourman and 

Stone Fruit Methyl Bromide, Chloropicrin, and Metam-Sodium TJ Wyatt 

in Stone Fruit Production 

Ornamentals Assessment of the Benefits of Soil Fumigation with Nicole Zinn and Steve 

Chloropicrin, Methyl Bromide, Metam-Sodium and Smearman 

Dazomet in Ornamental Production 

Peanut Assessment of the Benefits of Soil Fumigation with Angel Chiri and TJ 

Metam-Sodium in Peanut Production Wyatt 

Pepper, Bell Assessment of the Benefits of Soil Fumigation with Bill Chism and David 

Chloropicrin, Methyl Bromide and Metam-Sodium Donaldson 

in Bell Pepper Production 

Potato Assessment of the Benefits of Soil Fumigation with Tara Chandgoyal and 

Metam-Sodium in Potato Production Derek Berwald 

Sweet Potato Assessment of the Benefits of Soil Fumigation with Sunil Ratnayake and 

Metam~Sodium and Chloropicrin in Sweet Potato Andrew Lee 

Production 

Tomato Assessment ofthe Benefits of Soil Fumigation with 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 of plant roots in sewer 

lines (Ratnayake and Chandgoyal, 2008). Metam-sodium is used as the major chemical to 

control plant roots and clean clogs in sewage lines. The alternatives analysis showed that there 

are efficacious registered herbicides for the control of plant roots in sewer lines. On the basis of 

available information in 2008, diquat dibromide seemed to be the likely alternative to metam 

sodium for the control of plant roots in sewer lines. 

INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON 

METHYLDITHIOCARBAMATE SALTS 

Additional information on non-agricultural use of metam-sodium and metam-potasium use 

would improve future BEAD assessments of the importance of these fumigants and may be 

required as a part of the registration review 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. 

Page 12 of13 
Chism, B. 2013. Personal communications with the senior agronomist (BEAD, US-EPA) on the 

use of fumigants in control plant pests. February, 2013. 

USDA, 2006-2011. NASS Crop Reporting Districts. Online: 

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

USDA, 2007. Census of Agriculture. Online: Online: 

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

Ratnayake Sand Chandgoyal. T. 2008. Alternative assessment on root control use ofmetamsodium in sewer lines (DP# 293361). BEAD's Official Record. 

Wyatt, T.J. 2007. Summary of the assessments of the benefits of soil fumigation with metamsodium in crop production (DP# 337501). BEAD's Official Record 

Page 13 of13