UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

li ,V~ 2 0 2016 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: Usage Report in Support of Registration Review Draft Risk Assessment Purposes 

for Fomesafen (PC Code# 123802 and 123803) 

FROM: Aruna P. Shah, Biologist .. ) /\{ 

Science and Information Analysis Branch AJ-4 Y1.l--- f. ~h Biological and Economic Analysis Division (7503P) 

THRU: 

Scie

Diann 

nce 

Sims, 

lnfonnat

Chjef 

ion 

~~ and Analysis Branch 

Biological and Economic Analysis Division (7503P) 

TO: Leigh Rimmer, Chemical Review Manager 

Risk Management and Implementation Branch II 

Pesticide Re-Evaluation Division (7508P) 

This memorandum transmits an update of the Screening Level Usage Analysis (SLUA) report 

for Fomesafen that was done in 2012. The usage data in the updated 2015 SLUA are an 

amalgamation ofUSDAINASS and Private Pesticide Market Research data from 2005 to 20 14. 

As measured by average annual lbs. a.i. applied, the current SLUA shows increases in usage on 

green beans, cotton and soybeans. In addition, this SLUA shows decreases in usage on 

watermelons. The usage on dry beans and peas stayed the same. The SLUA reports observed 

usage on corn, peanuts, green peas, peppers, potatoes and pumpkins. 

For questions, comments and other usage information requests, please contact me at 

703-347-0303. 
December 29, 2015 

Screening Level Estimates of Agricultural Uses of 

Sodium salt of Fomesafen (123802) and Fomesafen (123803) 

Sorted Alphabetically- Reporting Time: 2005-2014 

Percent Crop Treated 

Crop Average Lbs. A.l. 

Applied per Year 

1 Beans, Green 9,000 

2 Corn+ 70,000 

3 Cotton 300,000 

4 Dry Beans/Peas 40,000 

5 Peanuts+ 1,000 

6 Peas, Green <500 

7 Peppers <500 

8 Potatoes <500 

9 Pumpkins <500 

10 Soybeans 1,000,000 

11 Watermelons* 4,000 

All numbers rounded. 

<500 Less than 500 pounds of active ingredient 

<2.5 Less than 2.5 percent of crop treated 

< I Less than 1 percent of crop treated 

NC Pounds not calculated 

Average Maximum 

15 25 

<1 <2.5 

10 20 

10 15 

<2.5 <2.5 

<1 <2.5 

<2.5 5 

<1 <2.5 

<2.5 <2.5 

5 15 

5 5 

+ Crops are not known to be listed on active end use product registrations or as Section 18 

emergency exemptions when this report was run 

* Watennelons have a tolerance and no active registrations 

SLUA data sources include: 

USDA-NASS (United States Department of Agriculture's National Agricultural Statistics Service) 

Private Pesticide Market Research 

These results reflect amalgamated data developed by the Agency and are releasable to the public. 
Sodium salt of Fomesafen (123802) and Fomesafen (123803) 

Screening Level Usage Analysis (SLUA) 

Date: December 29,2015 

What is a Screening Level Usage Analysis (SLUA)? 

• Available estimates of pesticide usage data for a par1icular active ingredient that is used on agricultural crops 

in the United States. 

• Pesticide usage data obtained from various sources. The data are then merged, averaged, and rounded so that 

the presented information is not proprietary, business confidential, or trade secret. 

What does it contain? 

• Pesticide usage data for a single active ingredient only. 

• Agricultural use sites (crops) that the pesticide is reported to be used on. 

• Available pesticide usage information from states that produce 80% of crop acres planted in the United States, 

in most cases, or less than 80%, in rare cases, depending on the scope of the survey and available resources. 

• Annual percent of crop treated (average & maximum) for each agricultural crop. 

• Average annual pounds of the pesticide applied for each agricultural crop (i.e., for the states surveyed, not for 

the entire United States). 

What assumptions can I make about the reported data? 

• Average pounds of active ingredient applied- Values are calculated by merging pesticide usage data 

sources together; averaging across all observations, then rounding. Note: If the estimated value is less than 

500, then that value is labeled <500. Estimated values between 500 & < 1,000, 000 are rounded to 1 

significant digit. Estimated values of 1,000,000 or greater are rounded to 2 significant digits.) 

• Average percent of crop treated - Values are calculated by merging data sources together; averaging by 

year, averaging across all years, & rounding to the nearest multiple of 5. Note: If the estimated value is less 

than 2.5, then the value is labeled <2.5. If the estimated value is less than 1, then the value is labeled <1. 

• Maximum percent of crop treated - Va lue is the single maximum value reported across all data sources, 

across all years, & rounded up to the nearest mu ltiple of 5. Note: If the estimated value is less than 2.5, then 

the value is labeled <2.5. 

What are the data sources used? 

• United States Department of Agriculture's National Agricultural Statistics Service (USDA-NASS)- pesticide usage data from 2005 to 20 14. NASS data are based on surveys that focus on the top-producing states 

that together account for the majority of U.S. acres or production of the surveyed commodity. NASS aims to 

cover at a minimum 80 percent of the targeted fruit, vegetable, and field crop acres planted in the United States. 

Farm level data are combined during summary and, pending compliance with disclosure rules, published at the 

state and national levels. NASS collects agricultural usage data for various crops on a rotating schedule. 

• Private pesticide market research -pesticide usage data from 2005 to 2013. The Private Pesticide Market 

Research data is also a survey that covers pesticide usage on agricultural crops. The survey data accounts for at 

least 80 percent of US acres/production ofthe surveyed commodities. Surveys are conducted annually. 

• California Department of Pesticide Regulation (DPR) Pesticide Use Reporting (PUR) data for 2005 to 

2012. The PUR database contains detailed records and summaries of agricultural applications of pesticides on 

crops that are obtained from a census and published annually. 

What are the limitations to the data? 

• Additional registered uses may exist but are not included because the ava ilable surveys do not report usage 

(e.g., sma ll acreage crops). 

• Lack of reported usage data for the pesticide on a crop does not imply zero usage. 

• Usage data on a par1icular site may be noted in data sources, but not quantified. In these instances, the site 

would not be repor1ed in the SLUA. 

• Non-agricultural use sites (e.g., turf, post-harvest, mosquito control, etc.) are not reported in the SLUA. A 

separate request must be made to receive these estimates. 

• Some sites show some use, even though they are not on the label. This usage could be due to various factors, 

including, but not limited to Section 18 requests, existing stocks of the chemical, data collection errors, and 

experimental use permits (EUPs).