August 5, 2014 

VIA E-MAIL and US MAIL 

Ms. Tracy Perry 

Team Leader 

Risk Management and Implementation Branch III (RMIB III) 

Pesticide Re-Evaluation Division 

U.S. Environmental Protection Agency 

One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

Re: Fenamiphos Stocks – Request for Continued Golf Course Use Until October 6, 2017 

Dear Tracy: 

I write on behalf of the members of the Golf Course Superintendents Association of America 

(GCSAA) regarding the continued use of existing stocks of fenamiphos on golf courses. In light 

of the circumstances as described below, the GCSAA is asking EPA to allow for the continued 

use of existing Nemacur stocks in a responsible labeled manner past the October 6, 2014 

deadline. The ideal extension would be to allow for the continued use of remaining stocks to 

October 6, 2017. 

GCSAA is a leading golf organization and has as its focus golf course management. Since 1926, 

GCSAA has been the top professional association for the men and women who manage golf 

courses in the United States and worldwide. From its headquarters in Lawrence, Kan., the 

association provides education, information and representation to more than 19,000 members in 

more than 72 countries. GCSAA’s mission is to serve its members, advance their profession and 

enhance the enjoyment, growth and vitality of the game of golf. 

As you are aware, the registrant voluntarily requested that EPA cancel all uses of fenamiphos, 

the active ingredient in the nematicide Nemacur, in 2002. The use deletion and product 

cancellation order of fenamiphos products registered under section 3 of FIFRA is dated 

December 10, 2003. The agency gave golf courses a 5 year phase out to purchase Nemacur by 

May 31, 2008. When golf courses made their final purchase of Nemacur in 2008, they knew that 

what they bought could be used until the stocks were exhausted, as outlined in the cancellation 

order. 

Golf courses also knew there was not a viable alternative to the nematicide Nemacur and it 

would take many years of additional research to identify one. Back in 2008, many golf courses 
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purchased at least 10 years’ worth of existing stocks, especially courses in the Southeast and 

California, hoping their existing stocks would last long enough for an alternative to be found. 

The December 10, 2003 Use Deletion and Product Cancellation Order (FRL-7332-5) (68 FR 

68901) established for Bayer Corporation a production cap on the manufacture of fenamiphos, 

which limited fenamiphos production to 500,000 pounds of active ingredient for the year ending 

May 31, 2003, and reduced production by 20% each subsequent year during the 5-year phase-out 

period. Bayer has reported that approximately 400,000 pounds of the nematicide Nemacur was 

purchased by golf courses in 2008, the last year of the phase out. 

On October 5, 2011, EPA made a decision to prohibit the use of all fenamiphos products in the 

United States after October 6, 2014. Previously, the agency had allowed end users with existing 

stocks of products containing fenamiphos to continue to use these products until their stocks 

were exhausted, provided that the use complied with previously EPA-approved product label 

requirements for the respective products. 

GCSAA has recently learned that golf courses were not aware of the October 6, 2014 deadline 

whereby stocks must be used up. There has been an outcry from GCSAA members who still 

have remaining product that was purchased back in 2008. Golf courses were completely caught 

off guard by the compliance deadline announcement we put in our communications vehicles this 

spring. Golf courses were not made aware of the change in the cancellation order in 2011 which 

prohibits use of the nematicide Nemacur after October 6, 2014. 

The industry has an inventory problem on its hands. Again, many golf facilities purchased 10 

years’ worth of supply and have been using the product judiciously on limited areas of the course 

in order to extend its use for those 10 years. They have not used up their supply and have a few 

more years left remaining. There still is no alternative on the market. 

GCSAA and its members strongly believe that the best way to dispose of remaining stocks of the 

nematicide Nemacur is to put it down on the turfgrass for its intended use. We believe that 

shipping old product in old containers over roads and highways for short or long distances to 

landfills or incineration facilities is a less than an optimal solution. 

There will be negative effects on golf courses if they are not allowed to use up their remaining 

Nemacur stocks after the October 6, 2014 deadline. Below is a history on the use of Nemacur in 

the Southeast United States and California that puts the current inventory problem into 

perspective. 

Southeast United States: 

Historically, the coastal region of the southeastern United States has been the largest user of 

Nemacur for nematode management on golf courses. While nematode problems on golf course 

turf can occur anywhere, they are more common and more severe in areas with warm 

temperatures and native soils with high sand content. For these reasons, and because some of the 

most damaging nematodes in the world are native to the region, golf courses in the coastal areas 
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of the southeastern United States have the most severe nematode problems in the world. These 

coastal sands stretch along the gulf coast from coastal Texas through Florida and along the 

Atlantic coast from Florida through North Carolina. Outside of this region, nematodes are 

primarily a problem only on sand-based putting greens, which are both the most critical 

component of a viable golf course and a relatively small amount of the total acreage. However, 

in the southeastern coastal plains where all the soil is sandy, nematodes can be a problem 

anywhere on the golf course, including greens, tees, fairways, driving ranges and even roughs. 

This region also has the highest concentration of golf courses in the world. These golf courses 

are large drivers of the local economies. In Florida alone, golf generated >$9.2 billion in income 

and 226,000 jobs in 2000 (Haydu and Hodges, 2002). 

In the Southeast, all of the nematodes that damage turfgrasses feed on roots. The damaged roots 

are not able to supply water and nutrients to the turf, which then sickens and dies. Severe 

infestation can cause the golf course to become unplayable, leading directly to decreased 

revenue. Additionally, nematode-weakened turf causes; a) more weed and fungal disease 

problems, leading to increased use of herbicides and fungicides, b) more frequent irrigation 

usage to prevent turf from wilting, and c) increased labor costs due to hand-irrigating nematode 

hot spots, spraying, etc. 

It is important to realize that there are many species of nematodes that cause damage to 

turfgrasses. Certain species may be more problematic on some kinds of grass than others, are 

active at different times of year, or occur primarily at different locations in the soil and plant. At 

the broadest level, nematodes parasitizing turfgrasses can be grouped as ectoparasites and 

endoparasites. Ectoparasitic nematodes live in soil and feed on turf roots from the outside. These 

types of nematodes can be managed with contact nematicides, nematicides that move through 

soil and kill nematodes on contact. Endoparasites feed and reproduce inside of the plant. 

Endoparasites are primarily managed with systemic nematicides that move within the plant. 

Most nematicides have contact activity but not systemic activity, and consequently work better 

on ectoparasitic nematodes than on endoparasites. 

Photograph 1. Photo of damage from sting and lance nematode on a bermudagrass green. 
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The active ingredient in Nemacur products is fenamiphos. Fenamiphos affects the nervous 

system of nematodes and causes paralysis. It is not a preventative treatment, it is used to treat 

existing nematode infestations on established turf. It does not kill all the nematodes, but reduces 

their numbers and activity when pest pressure is high to let the turf establish a healthier root 

system. The unique quality of fenamiphos is that it has both systemic and contact activity. This 

makes it very effective against both ectoparasitic and endoparastic nematodes. 

 

For the past fourteen years, the focus of Dr. William T. Crow’s research program at the 

University of Florida IFAS has been to identify and develop new nematode management tools 

for use on golf course turf. Dr. Crow works in the Entomology and Nematology Department and 

is a leading nematologist in the U.S. While Dr. Crow has made strides, and some new products 

have been registered for use, none of the products currently on the market are as broadly 

effective and versatile as fenamiphos. Below is a description of the relative strengths and 

weaknesses of the different alternative nematicides currently on the market that have 

demonstrated some degree of effectiveness in Dr. Crow’s field trials. 
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1,3-Dichloropropene (1,3-D) is the active ingredient in Curfew Soil Fumigant. It is injected into 

established turf using specialized equipment by custom applicators. This is contact nematicide 

and is the most effective treatment currently on the market against ectoparasitic nematodes. 

However, 1,3-D has several drawbacks that limit its versatility. It only has a Section 24(c) 

registration in a few states, it is only used in areas with a high density of nematode-infested golf 

courses. It cannot be used in areas with Karst geological features, which include large portions 

of Florida. It has a 24-hour reentry interval, so the golf course is closed for one to two days, 

resulting in revenue losses. Since it is a contact, it has very little activity on endoparasitic 

nematode species. It can only be used once per year. Because it is custom-applied, it is cost 

effective only when large areas need treatment, small problem areas cannot be treated 

practically. It cannot be applied near houses or other inhabited structures. 

Bacillus firmus is a bacteria that is the active ingredient in Nortica, a biological product. 

Research has shown that this product, when used preventatively, can reduce reliance in chemical 

nematicides. The bacteria in Nortica colonize the root rhizosphere and produce metabolites that 

protect roots from parasitic nematodes. Dr. Crow considers Nortica to be an effective 

component in nematode integrated pest management plans for golf course turf. However, 

Nortica is not a stand-alone nematode management tactic. While it reduces reliance on 

nematicides, it usually does not eliminate the need for them. It also is not effective as a curative 

treatment, it is not useful at “fixing” nematode problems once damage is occurring. 

Abamectin is the active ingredient in Avid 0.15 EC, an insecticide used on ornamental plants. 

Abamectin is also very effective against nematodes, if they come in contact with it. 

Unfortunately, abamectin does not move well in soil and binds to soil organic matter. Dr. 

Crow’s research has shown that frequent applications of high rates of abamectin are effective 

against nematodes only in the top two inches of soil profile. While not ideal, two inches of 

protection is often adequate in golf course green situations. Avid is currently being used under 

Section 24(c) labeling in Florida and several other states for golf greens only. It provides 

adequate results against root-knot nematodes that inhabit the top two inches of soil profile. It is 

not as effective against sting nematode and other nematodes that proliferate deeper in the soil. 

Also, because it may be used on greens only, it cannot be used to treat nematode problems on 

tees, fairways, etc. 

Furfural is the active ingredient in Multiguard Protect EC. Dr. Crow’s research has found this 

product to be moderately effective at providing short-term protection against ectoparasitic 

nematodes on turf. Furfural only has contact activity, so it is not effective against endoparasitic 

nematodes. Under certain conditions furfural can damage turf, so it must be used and applied 

very carefully. Furfural is not effective in the top two inches of soil profile. 

Additionally, Dr. Crow has had several new promising nematicide active ingredients performing 

very well in field trials. At least three of these are currently moving through the registration 

process. At least one of these has systemic activity. Dr. Crow is extremely optimistic that within 

the next several years we will have several technologies that will adequately replace fenamiphos 

for the golf course market. 
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Specific reasons for Dr. Crow’s support for this request to extend the Nemacur use deadline are 

twofold: 

1) Currently there are no other nematicides that are as versatile in use and broad-spectrum in 

activity as Nemacur for golf course use. Particularly for use against endoparasitic 

nematodes, none of the products currently on the market have systemic activity. This 

extension will help bridge the gap until the new nematicides under consideration come 

online. 

2) The safest and most economical means of disposal is using Nemacur for its intended use. 

Due to communication breakdown, the golf industry only became aware of the October 

2014 deadline this year. Now that the golf course industry is aware of the use deadline 

they are attempting to use it up. However, some of them have more Nemacur on-hand 

than they can legally use in one year. Having extra time to use their existing inventory 

will prevent expensive transportation and disposal of this Nemacur. 

California: 

The stem gall nematode, Anguina pacificae (Anguina), is the most severe pest problem ever 

observed on Poa annua putting greens in California. This nematode was first discovered in 1978 

by Larry Costello, a University of California Farm Advisor, who observed swollen stems on Poa 

annua (Poa) collected at golf courses in the Monterey Peninsula. Infection by the nematode 

causes the plant to swell creating a gall at the base of the stem. The galls appear as bulb-like 

structures near the crown of the plant and tend to contain eggs and adults or second stage 

juveniles ready to emerge. As the hundreds of nematodes within each gall feed on the Poa annua

plant, the plant is damaged and eventually killed through a combination of interference with 

water and nutrient transport, as well as nutrient and photosynthate deprivation. This unique 

nematode does not colonize the roots. 

The geographic range of Anguina pacificae extends from the Monterey Peninsula of Central 

Coast California to approximately 30 miles north of San Francisco. Approximately 100 to 125 

golf courses with Poa annua greens located in this region show symptoms of Anguina pacificae

infestations. 

Anguina induced turfgrass injury causes coalescing plant collapse and dissipation, resulting in 

Poa annua putting green surfaces that are virtually unplayable based on industry standards for 

the game of golf (Photograph 1). 

Photograph 2. Severe Poa annua injury and collapse as the result of Anguina pacificae, the stem gall nematode, on a Poa annua

putting green. 
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Nemacur has been the only effective active ingredient for control of Anguina pacificae. The 

properly timed label use of Nemacur does not kill all Anguina nematodes, but reduces 

populations below critical injury thresholds, allowing Poa annua to recover. 

Over the last twelve years, Mark M. Mahady & Associates, Inc., a turfgrass research company, 

has conducted 14 replicated field research trials to evaluate new products for control of Anguina 

pacificae. A primary objective of this field research has been to identify sustainable alternatives 

to Nemacur for suppression and control of Anguina pacificae. These multiple application field 

trials have been jointly developed and funded through the cooperation of golf courses located in 

Central Coast and Northern California (Anguina Field Research Golf Course Working Group), 

the Northern California Golf Association (NCGA), and numerous product development 

companies. To date, more than 45 products have been evaluated for control of Anguina pacificae

in science based replicated field trials. Those products that have not exhibited acceptable 

Anguina control and improvement in Poa annua growth include: Malathion, Avid, Dimethoate, 

Sevin, Merit, ProMax (thyme oil), Biolizer (sea shell deposits), A-1641 (mustard seed), BioSafe 

Nematicide (peroxyacetic acid), NeoTec (sesame seed oil), MultiGuard Protect (furfural), Soil 

Tilth, EndoRoots, Earthworks, CPR, HumaCal, MicroBooster, N-Control (28-0-0), Foli-R-Plus, 
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Milbemectin, Eartheart Program, C-Grow Program (compost tea), BioFence (mustard meal), 

Orthene and Sincocin. 

Key results from this exhaustive and continuing field research effort indicate that azadirachtin 

based products such as Neemix 4.5 EC (Certis U.S.A.) and Azatrol (PBI Gordon Company) 

exhibit marginal control with low to moderate Anguina infestations, but, unfortunately, fail to 

provide adequate control with severe Anguina infestations. If severe infestations occur during 

October and November, Poa annua recovery will not be achieved until March due to the slow 

growth of Poa annua during cool winter months in Northern California resulting in highly 

unacceptable playing conditions for extended periods of time. 

In addition, azadirachtin based products are extremely expensive. Field research has shown that 

approximately 10.8 grams of azadirachtin per 1000 square feet is required for control of Anguina 

pacificae. This is an extremely high rate when compared to the use rates of azadirachtin in 

agriculture. This 10.8 gram azadirachtin rate translates into 9 product ounces per 1000 square 

feet of a product such as Neemix 4.5 EC. Neemix 4.5 EC at the 9 ounce rate needs to be 

deployed at a 14-day interval because the half-life of azadirachtin in turf ranges from only 24-72 

hours. For this reason 26 applications per year are required. The cost of a single application of 

Neemix 4.5 EC at the 9 ounce rate is $43.95 per 1000 square feet. The total product cost per year 

(excluding labor) to treat 3 acres of Poa annua greens with 26 applications of Neemix 4.5 EC at 

the 9 ounce per 1000 square foot rate is $149,328.03. 

This example shows that the azadirachtin program, while an alternative under low to moderate 

Anguina populations, is not a realistic option for 95% of the courses with Anguina pacificae, due 

to the extreme cost of the program. This factor also illustrates why the loss of Nemacur for this 

use has been such a devastating blow to those golf courses with Poa annua greens and Anguina 

pacificae infestations. The only other option is complete green reconstruction to creeping 

bentgrass surfaces which is extremely expensive, costing upwards of $1,000,000, and is not a 

realistic financial alternative for a high percentage of golf courses. 

The responsible use of one or two Nemacur application per year can make the difference 

between devastating injury to Poa annua and acceptable surface quality on putting greens. A 

best management IPM program consisting of Nemacur and a sustainable product such as 

azadirachtin would appear as follows: 

• A very small application footprint: Nemacur use on only 2-3 acres per course. 

• One or two properly timed Nemacur applications per year. 

• The use of azadirachtin based products throughout the remainder of the year to suppress 

Anguina activity and Poa annua injury when Anguina populations are low to moderate. 

The condition and surface quality of the highly susceptible Poa annua putting greens in Northern 

California does have a dynamic economic impact in this region. PGA tournaments are some of 

the largest charitable events in all of California every year. Since 1937, over $120 million has 

been raised for charity in Northern California through these events with over $10 million in 2014 
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alone. Excellent course conditions are expected for these events and the loss of Nemacur stocks 

without a suitable replacement could be devastating to these commitments. 

There are presently no alternatives to Nemacur currently registered in California that quickly 

reduce Anguina pacificae populations below critical injury threshold levels. 

Many superintendents purchased quantities of Nemacur before it went off-label for the purpose 

of using it as part of an IPM program, where sustainable products, such as azadirachtin would be 

used during the spring and early summer when Anguina pacificae populations were moderate, 

and then one or two applications of Nemacur would be used in late summer to prevent 

devastating turf injury during the worst Anguina outbreaks. 

Science based, replicated field research is continuing in order to find more effective products and 

agronomic strategies to reduce the effects of Anguina pacificae. To date, more than $500,000 has 

been dedicated to the search for alternative and sustainable control agents. 

Over the last 12 years, golf course superintendents and golf facilities in California have been 

diligent in the search for organic and sustainable products as viable alternatives to the use of 

Nemacur for suppression and control of Anguina pacificae on Poa annua putting greens. These 

groups have invested extensive time, large financial contributions and tremendous effort in a 

discovery process to support environmental stewardship. They are eager to find effective 

alternatives. 

GCSAA specific request to EPA: 

In light of the circumstances as described above, the GCSAA is asking EPA to allow for the 

continued use of existing Nemacur stocks in a responsible labeled manner past the October 6, 

2014 deadline. The ideal extension would be to allow for the continued use of remaining stocks 

to October 6, 2017. We recognize that EPA may have reservations about granting an extension 

of that duration and we are open to finding a different period that is both acceptable to EPA and 

sufficient to allow the golf course industry to adjust to the removal of Nemacur. 

Again, there is no economically or technically viable alternative to fenamiphos products 

available at this time. When golf courses purchased fenamiphos products in 2008, many golf 

facilities purchased 10 years’ worth of product in anticipation there would be an alternative 

found by then. They also bought the product knowing they could use the product until it was 

exhausted. These golf courses were caught by surprise when they learned in April that the 

product purchased back in 2008 would not be available to them until it was exhausted, but rather 

that the agency in 2011 had decided to stop use of the product altogether by October 6, 2014. 

They have been using the product sparingly and judiciously and responsibly since 2008 to make 

it last ten years and many courses still have 3-4 years’ worth of product left. They have counted 

on having this product available to maintain their golf courses and provide the excellent playing 

conditions their customers expect. 
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Golf course superintendents are professional land managers and sound environmental practices 

are implemented on golf courses when using all chemical products including Nemacur. Golf 

course superintendents are among the best-educated and most conscientious users of chemical 

management tools. Modern turfgrass management practices greatly reduce the potential for 

leaching or runoff into water supplies. Today, most superintendents have two or four-year 

university degrees in agronomy, horticulture or other related fields. Golf course superintendents 

are the nation's leading practitioners of integrated pest management, a philosophy that reduces 

the potential environmental risks of pesticide usage. Many superintendents enter the profession 

because of a love of nature and the outdoors, and are strongly committed to conservation. 

Superintendents give extremely high priority to maintenance practices that do not have a 

negative impact on the environment. 

Thank you for your consideration of this request. We would be happy to meet with you and 

others in the Pesticide Re-Evaluation Division to discuss this request further. There is a lot at 

stake with complete loss of fenamiphos products on golf courses if the October 6, 2014 stands. 

We look forward to working with you to ensure the needs of the golf courses are met. We also 

look forward to continuing to work with university researchers to find an economically and 

technically viable replacement. 

Please contact me at (800) 472-7878, ext. 3619 or cmmckeel@gcsaa.org if you have additional 

questions or if you need additional information. 

Sincerely, 

Chava E. McKeel 

Director, Government Relations 

Golf Course Superintendents Association of America 

 

cc: Mark Mahady, President, Mark M. Mahady & Associates, Inc. 

 William (Billy) Crow, Professor of Nematology, University of Florida 

 Rhett Evans, GCSAA Chief Executive Officer