UNITED STATES ENVIRONMENTAL PROTECTION AGEN C Y WASHINGTON , D
. C

. 20460 

### MAY 2 3 2014

MEMORANDUM OFFICE OF CH E MICAL SAFETY A N D POLLUTION PREVENTIO N

SUBJECT : 

### BEAD Chemical Profile (BCP) for Registration Review ofMecoprop Chemical Case [Includes Mecoprop (03150 1 ); Mecoprop-potassium ( 031503 ); Mecoprop dimethylamine salt (031519); MCPP-P , DMA salt (031520); Mecoprop-PFROM:

THRU: 

### potas si um (1 19046 ); and MCPP-p (1290 46)] Leonard Y ourman, Plant Pathologi st 

# P Biological Analysis Branch

## ~ ( Rafael A. 

### Prieto, Env ironmental Protection Specialist Science Information and Analysis Branch Elizabeth Hill , Economist Economic Analysis Branch Biological and Economic Analysis Division (7503 P ) Arnet Jones , Chief Biological Analysis Br Diann Sims, Chief Science Information and Analysis Branch Timothy Ki ely, Chief

# ~ (

# ~ Economi c Analysis Branch 

## \AA. Biological and Ec onomic Analys· Division ( P) TO: Kaitlin Keller, Chemical Review Manager Risk Management and Impl ementation Branch 3 Pesticid e Re-evaluation Division (7508P)
Peer Review Panel: May 7, 20 14INTRODUCTION The Biological and Economic Analysis Division (BEAD) Chemical Profil e (BCP) provides an overview of th e pe st management roles and quantitative usage information for mecoprop and similar herbicide s. The BCP includes summaries of previous B E AD products and available public and/or pri vate u se and usage data for mecoprop to describe the rol e ofthis chemical in pest management. Additional information on use is available in the m ecoprop Label Use Information System (LU I S) reports. Information p rovided in this B CP may be used by stakeho lders (e.g., users and registrants), OPP risk assesso rs, and OPP ri sk managers, and the general p ublic during th e Registration Revi ew process of this pesticide.
USE SITES Various fo rms of th e m ecoprop family of herbi cides are registered
. Mecoprop (MC PP) (03 150 1 ) is registered for use on residential lawns. Mecoprop-potassium (031503) is registered for use o n lawns and turf. Mecoprop dimethylamine salt (031519) is regi stered for use on lawn s and turf, rights-of-way and nonagricultural unculti vated areas. MCPP -P , DMA s alt (031520) is registered for use on rights-of -wa y, airport landing fields, lawn s and turf , ornamentals, ou tdoor building premises , drainage ditch banks, outdoor construction areas , n o nagricultura l uncultivated areas and recr eational areas. Mecop rop - P-potas sium (1 1 9046) is registered for use on lawns and turf
. MC PP-p (129046) is reg is tered for use on right s -of-way, airport landin g fields, lawns and t urf , ornamenta l s, outdoor building premises, outdoor constr uction areas , nonagricultural uncultivated areas and recreational areas.
FORMULATIONS AND APPLICATION METHODS Mecoprop (031501) i s formulated as a granular for broadcast applications. M ecoprop-potassium (031503) i s formulated a s a liquid-ready to use (RTU) for broadcast and spot treatment application s. Meco prop dimethylamin e salt (031519) i s formulated as granular, liquid so lubl e concentrate, flowable concentrate, and liqui d

- read y to use (RTU) f or broadcast, spot treatment , spray and foliar treatment ap plication s .

2MCPP-P, DMA salt (031520) is formulated as gran ular, liquid so lubl e concentrate, flowable concentrate, liquid-ready to use (RTU), emulsifiable concentrate, and pressurized liquid for broadcast, spot treatment, sp ra y, foliar treatment, basal bark treatment, basal spray treatment, crack and crevice treatment, high

- volume (dilute) spray, and low-vol um e (concentrate) spray app li cat ions. Mecoprop -P-potassium ( 1 19046) is formulated as emulsifiabl e concentrate, li quid-ready to use (RTU), and liquid soluble concentrate for broadcast and spot treatment applications. MCPP

-p (129046) is formulated as granular , liquid soluble concentrate, soli d soluble concentrate, flowab le concentrate, liquid

- ready to use (RTU), emulsifiable concentrate, and wettable powder/dust for broadcast, dust, foliar treatment , low volume (concentrate) spray, soil broadcast treatment, spot treatment, and spray applications
. HISTORY OF MECOPROP AND BEAD PRODUCTS A search of the BEAD database for previous BEAD products for mecoprop indicates that there are no benefits assessments or Sect ion 18 Emergency Exe mption Requests for any mecoprop typ e herbicides. Re cent Sec tion 18 Emergency Exemption Reque sts might suggest that a chemical is important for the uses granted in the request; however, a lac k of Section 18 Emergency Exemption Requests is not an indication of the relati ve importance of the chemical. In 2007, BEAD conducted a preliminary evaluation ofmecoprop use and potential alternatives (Phillips and Lee, 2007)
. This document concluded that individual alternatives to mecoprop are hard to determine s i nce mecoprop herbicides are typically included in tank mixes with other herbicide active ingredien ts. Dicamba, 2,4-D, and dichlorprop are noted as possible alternatives to mecoprop.
USAGE The vast majori ty of mecoprop use is for non - agri cultural uses, primarily for res idential l awns, with smaller uses for commercial turf, such as for go lf courses (Table 1). A relative l y small amount of th e various chemical formulations is for agricultural pastureland. 

### T bl 1 M

a e 

# . ecoprop 

## u se on T f&O ur t 

### I 2012 rnamen as, Chemical Turf & Ornamental US 2012 (Lbs)

MCPP 643,000 Mecoprop 136 ,000 Mecoprop

- p 18,000 Total 797,000 Source: EPA Propnetary Data, 2012 Agricultural Usage

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### The agricultural use for mecoprop is for pasture and rangeland
. A BE AD proprietary database for 2003 to 2012 indicates very little use on pasture. A survey of severa l hundre d farms resulted in limited use for only three of those years (2004, one sam ple; 2006, three s amples ; 2007, two sa

mpl es ).
CHEMICAL AND USE CHARAC TERISTI CS 

### MC PP (mecoprop), MCPA, and the chlorophenoxy family ofherbicides (whic h includes 2 ,4-D) are used primarily as residential herbicides to control broadleaf weeds in lawns. Premixing with 2,4-D p rovides an overall g reater range of targeted weeds than each in gredient would provide if used independentl y (Phillips and Lee, 2007). Fo r example, the MCPP-p 4 Amine label list s " less susce ptible " w ee d s such as knotwee d, mornin g glory, black medoc , and some others
. A lab el with MC PP-p with 2 ,4 -D and 2, 4-DP

- p includes those spec ie s and several more as susceptible t o the product. Accordi n g to Phillips and Lee (2007) M CPP -p is "an integral part of a wee d management program in professional and homeowner turfgrass and i s primarily formulated with fertilizers and other herbicides. In 

### addition, thi s herbici de is the onl y phenoxy he rbicide that is not phytotoxic to bentgrass (Agrostis stolonifera L.) 

### turf and will control white clover (Trifolium repens L.) 

### and other BL W [broadleafweeds]." According to Fish el (2005): MCPA has many of th e same use patt e m s as 2,4-D, and most produ c t s co ntaining MCPA a re premixed with 2,4-0 and other her b i

c id es. I t i s a l so available in amin e a nd este r formulations. It is u sed as a s pecialty herbicide in th e United States on a small scale. M C PA is less injurious to cereal g rain cro ps and has been labeled for weed co ntrol u se in small -seeded legumes, such as clover. It was first regi ste red in the U ni ted States in 

### 1973. MC PP acts re lativel y slowly compared to the oth e r ch l orop henoxy herb icides. In most cases , i t is prepackaged with ot h er herbicidal active in gredients.
ROLE OF MECOPROP IN PEST MANAGMENT 

### BEAD did not fmd substant i ve additional usage information beyond what was described in the p rev ious Registration Eligibi lity Decision (RED) (E PA , 2007) and a B EAD memo from the same period (Phil li ps and Lee, 2007). BEAD d oes not have updated usage i nfo rm ation for pastur e use and cannot confirm figures li sted in the 200 7 RED. According to the RE D (E PA, 2007): The majority of M CPP- p us e is associated with residential lawns , with smaller usage on oth er recreational turf and no n-agricultural grassy areas. Based on usage informati o n provided by the MCPP-p Task Force (also referred to as t he Task Force), t o tal annual d omest i c usage ofMCPP-p i s approximately 5 million pou nds: >97% are app li ed to r es ide ntial lawn s, 2% i s applied to golf courses, an d <1% i s app lied to tu rf farms and oth er uncultivated non-agri cultu ral land
. Accordi n g to the Tas k Force , geograp hi cal use areas for applications to turf in roughl y descending o rder : M id west, Northeast , South , Northwest, and West. MC PP-p i s often co-formulate d with ot h er chlorophenoxy herbicides, including 2 ,4 -D and dicamba.

4DATA NEEDS The Agency currently doe s not have important information on MCPP. Obtaining the following information may improve future assessments conducted by the Agency related to the use and importance of mecoprop.

• T otal pounds active ingredient applied o n residential, ornamental, turf , r ights-of-way, and pastureland including updated u sage information reported in the 2007 RED (i.e. , 5 million lb used) • Percent crop/site treated • Application rates: typical and maximum • Frequency of application • Application Intervals • Methods of application • Target or ni che pests • E fficacy information/product performance
REFERENCES EPA. 2007. Registration Eligibility Decision for Mecoprop-p (MCPP). Aug. 29, 2007. http :/ / www.epa.gov/ oppsrrd 1 / reregistration!REDs / mcpp red.pdf Fishel , F
. M. 2005 (rev ised 2013). Pesticide Toxicity Profile: Chlorophenoxy Herbicides. U niversi ty of Florida Extension Publ. PI-83. http: // edis.ifas.ufl.edu/pi 120 ; http: //edis.ifas.ufl.edu/pdffiles/PIIPI12000.pdf Phillips, W. and Lee, A. 2007. A Preliminary Evaluation ofMecoprop (MCPP -p) and Dichlorprop (2 , 4-DP-p) Use and Potential Alternatives. BEAD memo , Aug. 21, 2007. EPA Proprietary Data, 2012. (pesticide usage data)

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