UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGT O N , D

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. 20460 

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MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION P REVENTION



### SUBJECT: BEAD Chemical Profile for Registration Review : 

### lmazalil (111901) and Imazalil Sulfate (111902) FROM : Tara Chandgoyal, Ph. D., Plant Pathologist Biological Analysis Branch 

# /'}." , Cynthia Doucoure, Environmental Protection Specialist L:**~**



### THRU: Science Information and Analysis Branch Andrew Lee, Economist 

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Economic Analysis Branch

### ~ Biological and Economic Analysis Division (7503P) ArnetJones, Chief 

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. .**~AJ** Biological Analysis Branch

### ~ Y ( Diann Sims, Chief

# )..[)c:z**~** Science Information and Analysis Branch Timothy Kiely, Chief 

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## ]Dt~ Economic Analysis Branch 

# r . I -v<! Biological and Economic Analysis Division (7503P) 

### TO: Margaret Hathaway, Chemical Review Manager Risk Management and Implementation Branch 2 Pesticide Reevaluation Division (7508P) 

### Product Review Panel date: June 19, 2013

Page 1 of10INTRODUCTION The purpose of this document i s to convey usage inf ormation and a broad overview of t he pest management roles of pesticides that are beginnin g to undergo registrati on re view. The anticipated au di ence consists of the team of EPA staff currently eval uati ng the reg i strat i on status of im azalil , and eventuall y the general publi c. This d ocument build s upon the dat a B EAD provides in the Label Use Information System (LU IS ) reports and the Screening Level Us age Analysis (SLUA) to Registration Review teams. The document is based on information and data available to BEAD as of May 2013. Im azal il i s a systemic fungicide that was re g is tered in the U.S. in 1983. lmazalil sulfate was registered in March. 200 4. Imazal il and imazalil s ulfate are syste mic fungicides used for the contro l of fungal pathogens on postharv est citrus fruits and on wheat, barl ey and triticale. Imazalil i s also use d in chicken hatcheries for the control of poultry aspergi ll osis (caused by 

### Aspergillusfumigatus). R es istance in many fungal p es ts has been reported and FRAC (2013) recommend s resistance management. Im azalil s ulfate is effective ag ains t fungal pests on citrus fru its. The "Report of FQPA Tolerance Reassess ment Progress and Interim Ri sk Management D ecisio n (TRED) fo r Imazalil" w as completed on Jul y 12 , 2002. The Im azalil Reregi stration Eli gibility Decis ion (RED) was approved on February 25 , 2005 and amended March 16 , 2005.
HISTORY OF BEAD ASSESSMENTS FO R IMAZALIL T here are no BEAD assessments for this chemical that are relevant to the current registration rev iew work.
COMMON FORMULATIONS AND APP LICATION METHODS Imazalil is commo nl y formulated as a liquid ready

-to
- u se, pressurized liquid , emulsifiable concentrate , water so luble granule, and smoke cand les. Im azalil is applied as a seed treatment us in g mi st-type equi pment and mechanical slurries. Imazalil is a l so applied as a postharvest treatment us ing a foarner , spray brush, dips, wash t anks , wax and drenches. In chicken hatc h er i es, im azal il is app li ed using a smoke candle treatment to di s infect equipment (empty hatch ery cabi nets, se tters, coolers, storeroom s, and egg handling equipment) prior to the introducti o n of the eggs. Imazalil sulfate is commonly formu lated as a so luble powder, water solub le granule , an d a flowable co ncentrate and applied as a postharv est treatment using dip and wash tanks, drench ers, and in aqueous line and sto rage wax line spray app li cations , as we ll as in non-recovery spray and water spray brush application s.

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### USE SITES Agric ul tural Use Sites: Imazalil is registered alone for postharvest use on c itrus and alone or in combination with metalaxyl, tebuconazole, and/or imidacloprid for p replant use on wheat, barley, and triticale seeds. Imazalil sulfate is registered alone or in combination with pyrimethanil for postharvest use on the citrus fruit crop group including calamondin, citrus c itron, grapefruit , kumquat , lemon, lime, mandarin, orange (sweet & sour), pummel, and Satsuma mandarin. Non-Agricultural Use Sites: Imazalil is registered for use as a chicken hatchery treat ment, and in commercial greenhouses on ornamentals, bedding plants, cut flowers, fl owerin g hanging basket s, foliage, potted flowering plants, and perennials. There are no non-agricultural uses registered for imazalil sulfate


### IMAZALIL & 

### IMAZALIL SULFATE USAGE BEAD reviewed avai lable data sources for reported use of imazalil on wheat , barley, postharvest citrus, and other agricu ltural and non-agricultural uses and for repo rted use of imazalil sulfate on postharvest citrus since approval of the RED in February 2005. BEAD fo und usage information that far exceeds estimates in the RED for wheat from private market research surveys and for postharvest citrus and other uses as reported in California Department of Pes t icide Regulation (DPR) and shown in the sectio n s below. 

### Imazalil Wheat Seed Treatments BEAD found availab le proprietary data based on private market research data fo r wheat seed treatment for the years 2009-2011. The vendor of the proprietary data did not conduct surveys on the use of fungicide as seed treatments until 2009. During the 2009-2011 period, imazalil usage, in terms of pounds of active ingredient (a.i.) applied to wheat seeds and the total area treated (TAT) or planted with those seeds, decreased as shown in Figures 1 and 2. Approx imatel y 5,300 pounds of imazalil were applied to wheat seeds on average annually and planted on 2,526,000 acres at an overall average application rate of 0.002 lbs ai/ acre . Spring wheat seed treatments , when compared to the total pounds of imazali l appl ied, accounted for 70% of the pounds a.i. applied and total area treated or planted during this period, fo ll owed by w inter wheat seed treatments at 30%. As for the percent crop treated (PCT), spring wheat seed treatments accounted for 1 0% PCT while winter wheat accounted for < 2.5% PCT (lmazalil SLUA, 20 13). The top states in terms of pounds a.i. applied to seeds and total area treated or planted during this period were Montana (26%) and North Dakota (45%). Other states that reportedly use imazalil include the following: CA , ID, KS , MN , MO, OH , OK , OR, SD , TN , VA , and WA.

Page 

### 3 oflOFigure 1. Imazalil Wheat Seed Treatments: Pounds AI Applied, 2009-20 I I

-a**-~** 

### a. a. ct 

## < "' -a c :s 0 Q. 6,000

2009 2010 Year Source: EPA Propri etary Data, 2009-201 1 2011**Wheat,** Spring

- Wheat, Winter

Fi gure 2 : Imazalil Wheat Seed Treatments: Total Area Treated/P lanted , 2009

- 20 11

-a Cll 

# .. c 1'0 0:: 

# - -a Cll 

# .. 1'0 Cll 

## ... 1- 1'0 Cll 

## ... ct -;;

### ~ 2,500,000 

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2009 20 10 2011 Year Sou r ce: EPA Proprietary Data, 2009

- 2011

Page 4 oflO**he at,**  Spring

- Wheat, Winter

### Agricultural Usage on Planted Wheat Seeds by 

### Crop Reporting District Another measure of usage is the use intensity. In th i s analysis, the use intensity is expressed as the pounds a.i. applied on planted wheat seeds per 1,000 acres of land in farms. This differs from the application rate, which is expressed as 0.002 pounds a.i. applied on seeds per treated/ planted area or 0.2 pounds a.i. per 1,000 acres in farmland. In contrast, the maximum observed use intensity is between 0.053 and 0.085 pounds per 1 , 000 acres in farmJand. Figure 5 spatially represents imazalil use intensity in the U.S. on planted wheat seeds, which is relatively greater in North Dakota. This reflects a high concentration of spring whea t production

- Montana, North Dakota, and Minnesota account for approximately 80 percent of the U.S. spring wheat acreage (NASS, 2013)

- and a higher percentage of acres of spring wheat than of winter wheat. 

### Figure 3. Wheat: lmazalil Use Intensity by 

### Crop Reporting District (2009- 2011)

Average Pounds Per 1,000 Acres of Farmland

- <0.004

- 0
.004-0
. 006 

## D o.oo1- o . o15

- 0.016-0
. 052

- 0
.053- 0.085 Sources: Proprietary Data. 2007-20 II. USDA , 2007. Census of Agriculture. Online: http: //www.agcensus.usda.gov / Publications/2007/ index.asp
.

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### Imazalil and Imazalil Sulfate Usage in California BEAD reviewed availab le data sources for reported use of imazalil and imazalil sulfate in the U.S. and found recent data for citrus and other uses from California DPR for the years 2006- 201 1 as seen in Tab les 1 and 2 below. California, however, ranks second in citrus production but dominates Florida, Texas, and Arizona in fresh citrus produce. Florida is the leading producer of citrus fru its, followed by Texas and Ari zona. BEAD did not find any recent survey data from these states reporting use of imazalil and imazalil sulfate on c itrus nor reporting use of imazalil on landscapes. As such, please note that the data below underestimates U.S. usage of imazalil and imaza lil sulfate on postharvest citrus. BEAD also found data in California DPR for reported use on "other" sites as seen in Table 

### 1 below.
T b l 1

I a e 

## nu maza 1 sa 

# . c 1'£

. 2006 2011 lle m a 1 orrua, 

### - Site Pounds A.I. AJ!Piied 2006 2007 2008 2009 2010 2011 Citrus 3 , 987.7 2,332
. 1 2,635.5 1 , 285
. 9 2,005.4 4,822.50 (all or unspecified) Grapefruit 25.2 36.1 121.8 92.1 296.4 74.61 Lemon 2,639.9 2,829.9 4,0 1 6
. 2 1,194
. 5 7,035.9 1,927.32 Lime NA NA NA NA NA 0.06 Oranges 14,503.8 9,074.4 16,539.0 9,909.9 14,313.2 14,744.81 Pomelo (Shaddock) 3.4 1. 8 NA NA NA NA Tangelo/Tangerine 66
.7 58.5 85.2 66.1 326.3 520.56 Commodity 107.8 75.4 45.5 83.7 1,173.3 79.36 Fumigation Other* 289.3 6.3 51.1 1,591.8 2,368
. 1 3583
. 33 

### Total 21,623.80 14,412.7 23,494
. 3 14,224.0 27,518.6 25,752
. 55

. . .. Source: CA DPR, 2006 -2 011, Pest1c1de Use Annual Summanes, Summary ofPesttctde Use Report Data Indexed by Chemical NA : Not Available *Other reported uses in California include landscape maintenance, structural pes t control, wheat (forage/fodder), public health pest control, regulatory pest control, vertebrate pest control, animal husbandry premises, and research commodity. Please note that California reporting categories do not always follow the terminology of labeled use sites.
Table 2 Imazalil Sulfate Usage on Postharvest Citrus in California 2006-2011 

### ' Site Pounds A.l. Applied 2006 2007 2008 2009 2010 2011 Citrus 1,787.9 487
.4 683.5 395.8 724.6 2,909.38 (all or unspecified) Grapefruit NA NA 2.1 5.0 2.8 2.0 Lemon 1 80.8 39.7 0.3 25.3 24.0 35.1 Oranges 756.4 219.3 524
. 6 171.3 676.3 401.3 Commodity NA NA NA NA 351.9 NA 

### Fumigation Total 937.2 746.4 1,210.5 597.4 1,779.6 3,347.78 Page 6 of10Source: CA DPR, 2006-20 II , Pesticide Use Annual Summaries , Summary of Pesticide Use Report Data Ind exed by Chemical NA: Not Available Non-Agricultural Usage in Greenhouses BEAD reviewed available usage data sources but did not fmd any usage information for imazalil use in greenhouses on ornamentals.
BIOLOGICAL ASPECTS RELEVANT TO IMAZALIL Imazalil is a systemic fungicide that belongs to Fungicide Resistance Action Committee mode of acti o n code 3 (FRAC, 20 13). It i s consider e d as med ium risk for resistance. It i s effective against many fungal pests on many crops (CDMS, 2010). Resistance in many fungi has been reported and FRAC (20 13) recommends resistance management. The resistance can be managed by mixing fungicides with different modes of action or alternating them. Imazalil, imazalil sulfate, and imazalil sulfate 

### + pyrimethanil are u sed for the postharvest control of green mold, blue mold, Phomopsis end rot, Diplodia rot and Alternaria rot diseases of citrus fruits. Imazalil al one or in co mbination with metalaxyl, teb uconazol e, and/or imidacloprid are used for treating wheat , barley and triticale seed, prior to p l anting, for protection against fungal pests. Imazalil is also regi stered for us e in chicken hatcheries t o control of pou ltry aspergillo sis (caused by Aspergillus fumigatus).
ROLE OF IMAZALIL IN PEST MANAGEMENT Imazalil fungicide appears to be efficacio u s against many fungal pests of citrus fruits, wheat, barley, and triticale. It is a valuable fungicide for the control of fungal diseases on these crops. It has di fferent mode of action than the other registered alternatives and therefore plays an important role in fungal pest control and pe st res i stance management. Availab l e data on wheat show that the predominant use of imaza lil is on seeds of sprin g wheat, which accounted for 70% of pounds a.i. applied and 10 % PCT. Also , the recent Califo rnia data appears to show that imazalil and imazalil sulfate are very import
. ant to the postharvest citrus production in California, where these chemicals are used predominantly on oranges and l emons and increasingly on grapefrui ts. However, w ithout having production data o n postharvest citrus and the amount of the citrus commodities treated in California, Florida, Arizona, and Texas, it is difficu lt to determine the importance of imazalil and imazalil and imazalil sulfate in citrus production in the U.S.
INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON IMAZALIL T he Agency currently does not have important information on imazalil and imazalil sulfate. Obtaining the following usage information may improve future assessments conducted by the Agency related to the use and importance of imazalil and imazalil sulfate: Page 7 of 10• Information on i mazalil and imazalil sulfate as a postharvest treatment in citrus in California, Arizona , F lorida and Texas, including pounds a.i. applied, application t iming, app li cation rate, application method, and application frequency. • Information on amount of citrus produced in California, Arizona, Florida and Texas and the amount of the c itrus commodities treated with imazalil and imazalil sulfate. • Information on the use of imazalil in greenhouses to treat various ornamentals and in chicken hatc h eries to treat egg handling equipment , including pounds a.i. applied, app li cation timin g, app li cation rate, application method, and application frequency.

REFERENCES California DPR, 2006

- 201 1 , Pest i cide Use Annual Summaries , Summary of Pesticide Use Report Data Indexed by Chemica l. http: //www.cdpr.ca
. gov/ docs/pur /purmain
.htm CDMS. 2010. Label Search. http: //prernier.cdms.net/webapls/FormsLogin.asp?/webapls/ Accessed May 6

- 9 , 2013. EPA Proprietary Da ta , 2009-2011 EPA, Imazali 1 Screening Leve l Usage Analysis (SLU A), January 2013
FRAC. 2013. FRAC Code List 2013: Fungicides sorted by mode of action (including FRAC Code numbering). http: //www .frac.info /publication/anhang/FRAC%20Code%20List%2020 13- update % 20April-20 1 3 .pdf USDA , 2006

- 2010
. NASS Crop Reporting Districts. http: //www .ers. usda. govlbriefing/ arms/resourceregions/resourceregions
.htm#nass
. USDA, 2007
. Census of Agriculture. http: //www.agcensus.usda. go v /Publications/2007/index.asp
. USDA NASS , March 2003 , Agricultural Chemi cal U sage Reports
. http: // usda
. mannlib.cornell.edu/MannUsdalviewDocumentinfo.do?documentiD = 1571
USDA NASS. 2013
. Crop Production 2012 Summary
. National Agric u ltural S tati stics Service, U.S. Department of Agriculture . http: // usdaO 1.library.cornell.edulusdalcurrent/CropProdSu!CropProdSu-0 1-11-2013 .pdf
.

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### APPENDIX A 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 li kely 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 gr. azing. It also includes woodland and wasteland not actually under cultivation or used for pasture or graz ing, provided it was part of the farm operator ' s total operation. Large acreages of woodland or wasteland held for nonagricultural purposes were deleted f rom individual reports during the edit process. Land in farms includes CRP, WRP, FWP, and CREP 1 

### acres . Land in farms is an operating unit concept and includes land owned and operated as we ll as land rented from others. Land used rent free was reported as land rented from others. A ll graz ing land , except land used under government permits on a per-head basis, was included as " l and 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 Amer ican Indian s o r non-Native Americans was reported in the name of the cooperative group that us ed the land. In many instances, an entire Ameri can 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 individu al crops; therefore , use may be occurring in regions outside the scope of the survey. CRDs s howing no usage of pesticides may be due to either the lack of pesticide use in the reg ion or non-participation in the agric ultural 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 th e CRD.

1 CRP: Conservation Reserve Program; WRP : Wetland Reserve P r ogram; FWP: Farmable Wetlands Program; CREP: Conservation Reserve Enhancement Program 

### Page 9 oflO

### This map disp l ays ratio data (i.e., average pounds per I , 000 acres o f farmland) summarized at a very high- level. Readers are strongly cautioned against trying to over int erpret the m ap without examination of the unde rl yi n g data
. The underl y in g da t a m ay exp l ain some of the many reasons th at a Crop Reportin g District may have a hi g h value for a particul ar 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 legend s and realize that a map prepared for a particular chemical i s not directly comparable to a map prepared for a different chemical. Scale and units of measurement do matter and may be different between maps.

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