Re: Recent Clothianidin Risk Assessments and Registration Status 

Michael Doherty to: Barbara Madden, Sidney Jackson 

Cc: Christina Swartz, Dennis McNeilly 

From: Michael Doherty/DC/USEPA/US 

To: Barbara Madden/DC/USEPA/US@EPA, Sidney Jackson/DC/USEPA/US@EPA 

Cc: Christina Swartz/DC/USEPA/US@EPA, Dennis McNeilly/DC/USEPA/US@EPA 

Barbara, 

Per our conversation earlier this week: 

01/25/2013 10:48 AM 

The Health Effects Division completed human health risk assessments titled "Ciothianidin - Aggregate Human Health Risk Assessment of New 

Uses on Strawberry, Pistachio, and Citrus; New Tolerance for Tea; and Revised PHI and Tolerance for Pepper and Eggplant (Crop Subgroup 

8-10B)," dated September 27, 2012 and "Ciothianidin- Human Health Risk Assessment for Requested Foliar Uses on Rice, Seed Treatment on 

Leafy Vegetables, Increased Application Rate for Vegetables, and Expanded Uses on Fruiting Vegetables and Pome Fruit," dated February 1, 

2012. Though the EPA is able to make the required safety finding and the human health risk assessments support all of the petitioned-for uses, 

what must still be considered for the uses to be registered in the United States are potential ecological and environmental risks associated with 

clothianidin. Therefore, the Registration Division has informed the Health Effects Division that at this time the EPA is only prepared to establish a 

tolerance on dried tea (without a U.S. registration; i.e., an "import tolerance") and to increase the tolerance on pepper to support the shorter 

pre-harvest interval (PHI). 

The EPA is still in the process of assessing the potential ecological concerns identified with the additional exposures expected from the registration 

of the proposed Pome Fruit Group 11 -10, Pepper/eggplant Subgroup 8-1 OB, Citrus Fruit Group 10-10, pistachio, and strawberry uses. In the 

meantime, in order to support the Office of Pesticide Program's Tea Initiative intended to establish tolerances for residues of pesticides on tea to 

ensure· a safe supply of tea for the U.S. consumer, EPA has determined it will move forward with establishing a tolerance on tea prior to finalizing a 

decision on the other uses. We again note that there is no domestic use of clothianidin associated with the tolerance on tea. Additionally, since 

the shorter PHI on pepper will not result in any additional environmental exposure, the EPA has determined that this label modification is 

acceptable and that a higher tolerance is needed for residues of clothianidin on pepper. 

Until EPA completes its ecological assessment and determines it is appropriate to register and therefore establish tolerances for the proposed 

Pome Fruit Group 11-10, Pepper/eggplant Subgroup 8-1 OB, Citrus Fruit Group 10-10, pistachio and strawberry uses, the appropriate modifications 

to 40 CFR 180.586 are as follows: 

Tea, dried at 70 ppm, 

Pepper at 0.80 ppm and 

Vegetable, Fruiting, Group 8, except pepper at 0.20 ppm. 

Regards, 

Mike 
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Michael A. Doherty, Ph.D. 

Risk Assessment Branch 2 

Health Effects Division/Office of Pesticide Programs 

U.S. Environmental Protection Agency 

703-305-1031