UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D
.C
. 20460 

## JUN 1 52015

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

SUBJECT: 

### BEAD Chemical Profile for Registration Review: Chlorophacinone (067707)



### .,}' FROM: 

### Colwell Cook, Biologist 

## e W Biological Analysis Branch

THRU:

TO: 

### Cynthia Doucoure, Environmental Protection Specialist 

## {!.

# ~ Science Information and Analysis Branch Elizabeth Hill, 

### Economist Economic Analysis Branch Biological and Economic Analysis Division (7503P) Amet Jones, Chief Biological Analysis Branc Diann Sims, Chief Science Information and Analysis Branch Timothy Kiely, Chief

# ~ 

# \M.;iJ Economic Analysis Branch Biological and Economic Anal ts Division 503P) Russell Wasem, Chemical Review Manager Risk Management and Implementation Branch I Pesticide Re-evaluation Division (7508P) Product Review Panel date: May 27,2015



### Page 1 of5

### SUMMARY Chlorophacinone was registered in 1971 as a vertebrate control agent. Based on available USDA NASS survey data, chlorophacinone is reported to be used to treat rodents in apples and cherries in very small quantities . The average percent crop treated (PCT) for both crops is <2.5 % and the average annual pounds a.i. applied is <500. INTRODUCTION The purpose ofthis document is to convey usage information and a broad overview ofthe pest management roles ofpesticides that are beginning to undergo registration review. The anticipated audience consists ofthe team ofEPA staffcurrently evaluating the registration status of chlorophacinone and the general public. This document builds upon the data BEAD provides in the Label Use Information System (LUIS) reports and the Screening Level Usage Analysis (SLUA) to Registration Review teams. The document is based on information and data available to BEAD as ofApril 2015 HISTORY OF BEAD ASSESSMENTS FOR CHLOROPHACINONE BEAD prepared a Screening Level Usage Analysis (SLUA) in April 2015 that contained agricultural usage information on the predominant uses of chlorophacinone during the 2004- 2013 time frame. Chlorophacinone was reported to be used on two crops : apples and cherries. The average percent crop treated (PCT) for both crops was <2.5% and the average pounds a.i. applied annually for both crops was <500 lbs a.i. BEAD conducted an analysis ofrodenticide bait use in 2006 (Chiri, 2006) which examined nine rodenticide products, including chlorophacinone. Chlorophacinone is considered a firstgeneration anticoagulant for use against commensal rats and mice and other rodents . This analysis concluded that rodenticides are necessary for managing rodents, which are a significant public health risk and are capable ofcausing significant economic damage. It also concluded that rodenticide active ingredients, in general, are interchangeable and can be considered alternatives to one another. In 2010, BEAD conducted a benefits assessment for the use of chlorophacinone to control blacktailed prairie dogs (Chiri, et al., 2010). This assessment was done in response to a petition submitted by multiple environmental groups over concerns of secondary impacts to non-target species. BEAD found that the principle benefits of chlorophacinone baits to users was that these baits significantly reduced the time and labor required to effectively control black-tail prairie dogs. That is, the use does not result in bait aversion and does not require pre-baiting, which is necessary for alternatives that deliver a sublethal dose. It also reduces post-application requirements for disposal ofprairie dogs.

Page 2 of5To date, BEAD has not reviewed any Section 18 Emergency Exemption Requests for the use of chlorophacinone. However, this should not be interpreted as a lack ofbenefits associated with the chemical. COMMON FORMULATIONS AND APPLICATION METHODS Chlorophacinone is formulated as pelletized and granular (hulled rolled oat) baits, and a powdered formulation. These are applied via aircraft, funnels, granule applicators, hand bulb dusters, mechanical burrow builders, dippers , and trap/bait stations. USE SITES Agricultural Use Sites: Chlorophacinone is registered for use in alfalfa, artichoke, barley, fruit tree orchards (pome and stone fruit) crops, nurseries, oats, pastures/rangelands, nurseries , Christmas tree plantations, and tree and forestry plantations. Non-Agricultural Use Sites: Chlorophacinone is registered for use in and around animal burrows and buildings (agricultural, public, industrial/commercial, homes, and food processing facilities) and transport vehicles (ships, trains, and aircraft) and in noncrop areas (fence lines, gullies, ditches, railroad rights-ofway, etc.), lawns/turf, golfcourses, and ornamental flower and shrub gardens . CHLOROPHACINONE USAGE According to USDA NASS survey data, chlorophacinone was reportedly used in apple and cherry orchards in relatively low quantities; total acres treated, pounds applied, and average AI rates of application as shown in Table 1below. Chlorophacinone was also reported to be used by consumers in very low quantities in 2009 as shown in Table 2 below. 

### T bl 1 A .

a e . gncu turalUse ofChl h
. oropJ acmone, 2007 d 2009 an Site Year Acres Treated Lbs A.I. Avg AI. No. of Applied Rate Apps Apples 2007 5,760 5.76 0.001 1.1 Cherries 2009 1,176.5 100 0.085 1.1 Source: USDA NASS Agricultural Chemical Usage Reports, 2007 and 2009

Page 3 of5T bl 2 N A . a e on-

**~ogncu** turalUse o Sector Year Consumer 2009 Markets for Pesticides & 2011 Fertilizers Source: Kline & Company, 2009 Proprietary Data, 20I I fChl 

### h . orop acmone, 2009 d 2011 an Lbs A.I. Applied % ofTotal Rodenticides 48 0.3 52 0.3

BEAD also reviewed California data to determine if use of 1 st generation anticoagulant rodenticides is increasing. It appears that, based on California Department ofPesticide Regulations (DPR) data from 2009-2013, chlorophacinone use increased slightly in 2011, followed by a slight decrease at the end of the period, as shown in Table 3 below. 

### T bl 

### 3 Chi

a e 

### h . orop1 acmone 

## u 

## . c l"f sage m a I ornia: A .g andNon-ag Chemical Pounds A.I. Applied 

### 2009 2010 2011 2012 2013 Chlorophacinone 12.95 10.95 28 .6 19.88 13.59

.. Source: California DPR, PestiCide Use Reportmg, Summary Data, 2009-2013 BIOLOGICAL ASPECTS RELEVANT TO CHLOROPHACINONE Chlorophacinone is considered to be a first generation rodenticide, belonging to the indandione class of anticoagulants. These compounds must be ingested and require several feedings for the rodent to ingest a toxic dose. These chemicals interfere with normal blood-clotting mechanisms resulting in capillary damage and hemorrhage. ROLE OF CHLOROPHACINONE IN PEST MANAGEMENT Many rodents are public health pests, such as Norway rats, roofrats, and house mice. These animals carry diseases, impacting human health as well as domestic animals . Rodents also impact agriculture. Many will feed directly on crops, both in the field and after harvest. In addition their gnawing can directly damage farm equipment and structures. Their burrowing activities also impact agriculture and other human activities . Chlorophacinone is a critical component of a rodent management strategy. For a homeowner, along with sanitation and exclusion, chlorophacinone may be used in bait traps . Chlorophacinone, in addition to diphacinone, is an important component of control for prairie dogs, ground squirrels, and other rodent pests in agriculture, especially in orchards, vineyards, and rangelands. Managers of forested areas and parks use these first generation anticoagulant Page 4 

### of5rodenticides to control populations ofrodents to reduce spread of diseases (e.g. Hantavirus) and maintain the grounds. INFORMATION THAT MAY BE USEFUL FOR BEAD'S FUTURE WORK ON CHLOROPHACINONE For future BEAD assessments, the following information would be helpful: usage data for nonagricultural sites (lbs a.i. applied, typical number of applications per year, maximum dose per year), and more detail about how chlorophacinone is used in agriculture to control vertebrate pests . REFERENCES California Department ofPesticide Regulation, Pesticide Use Reporting, Summary Data, 2009- 2013 Chiri, A. 2006. Analysis ofRodenticide Bait Use. U.S. Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention. Chiri, A., C. Cook, T. Wyatt, and E. Hill. 2010. Benefits Assessment for Chlorophacinone (Rozol) Use to Control Black-Tailed Prarie Dogs. U.S . Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention. EPA Screening Level Usage Analysis (SLUA), April 2015 Kline & Company, Inc., 2009 Proprietary Data, 2011 USDA NASS, Agricultural Chemical Usage Reports, 2007 and 2009

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