UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D

. C

. 20 46 0 

### JUN 0 9 

## 2015

MEMORANDUM OFFICE OF CHEM I CAL SA F E T Y AND PO L LUTION PREVENT I ON



### SUBJECT: BEAD Chemical Profile (BCP) for Regi st ration Review: Thiram (079801) 

### FROM:

THRU: Tara Chandgoyal , Ph.D. , Pathologist Biological Ana lysis Branch

# few**~** Don Atwood, PhD., Entomologist 

# /7**~ ~** **~** Science Information and Analysis Branch Elizabeth Hill, Eco nomist Economic Analysis Branch Biological and Economic Analysis Division ( 7503P) Arnet Jones , Chief Biological Analysis Branc



### TO: Wilhelmena Livingston , Chemical Re v iew Manager Risk Management and Implementation Branch IV Pesticide Re-evaluation Division (7508P)


### Peer Review Panel date: May 6, 2015

Page 1SUMMARY Thiram has been registered in the U
. S. since 1948 for use as a non-systemic , protectant dithiocarbamate fungicide
. Thiram is a member of the ethylene bisdithiocarbamate (EBDC) group offungicides which includes the related active ingredients mancozeb and maneb (FRAC , 2014) The current major agricultural use sites include strawberries , soybeans , cotton and wheat. The major non- agricultural use sites is ornamental turf (golf courses). According to available proprietary information , the highest usage of this fungicide , in terms of both total lbs applied and total acres treated is soybeans
.
INTRODUCTION The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an overview o f the pest management roles and quantitative usage information for thiram. The BCP include s summaries ofprevious BEAD products and available public and/or private use and usage data for thiram to describe the role of this chemical in pest management. Additional information on use is available in the Thiram Labe l Data Report provided in the public docket for this chemical. Information provided in this BEAD Chemical Profile (BCP) may be used by stakeholders (e.g
. , users and registrants), Office of Pesticide Programs (OPP) risk as s essors, and OPP risk managers , and the g eneral public during the Registration Review process of this pesticide.
AGRICULTURAL USE SITES Thiram is registered for crop use on strawberries , apples , and peaches. In addition , thiram is registered for use on dormant and non-bearing fruit trees and deciduous orchards. Thiram is also labeled for us e as an anima l repellent to protect crops from damage by rabbits , rodents , and de er. Thiram is registered for seed treatment use on coriander , cantaloupes , watermelon , cucumb er , pumpkin, squash , eggplant , pepp ers , tomatoes , broccoli , Brussels sprouts , cabbage , cauliflower, collards , kale , kohlrabi , endiv e, lettuce , parsley , spinach , Swiss chard , rape , broccoli raab , be ets , carrots , onions , radishes , be ans (dried and succulent) , sweet corn, field corn , peas , lentil s , okra , catjang , lupine , grasses, sorghum , alfalfa , clover, vetch , barley , oats , ric e, rye, wheat , triticale , guar , safflower , rapeseed , canola , celery , cotton , flax , mustard , peanuts , s e same seed , sugar beets , sunflowers , turnips, soybeans , chicory , millet , and rapes ee d
. N O N-AGRICULTURAL USE SITES Non

- agricultural use s ites which are labeled for thiram application includ e forest trees (foliar) , airport runways , and ornamentals (trees , plants , shrubs , vines , lawns , and turf) ( foliar and seed treatment)
. Page 2

### FORMULATIO NS AND APPLICATION METHODS Formulations include dust , flowable concentrate , dry flowab l e , emulsifiable concentrate , soluble concentrate , and ready-to-use liquid. Thiram formulations may be applied to apples , peaches , and strawberries using ground boom , aerial equipment, air blast sprayer, soil incorporation equipment , high and low pressure hand wand , backpack sprayer, push-type granular spreader , tractor-drawn drop

- type spreader, paintbrush , and sprink ler can. Commercial s ee d applicators use automated machin ery (slurry-type and mist-type) that mixes and applies thiram to seeds as they are rotated through a metal drum or cylinder ; these s ystems are used for both liquid and dust treatments. On-farm liquid applicators use a portable mechanical mixing system that applies thiram to seeds as they are rotated through a metal cylinder. On

- farm dust applicators pour thiram into the seed chamber of the planter and mix the product by hand with a stick or paddle , just prior to planting. Ornamental bulbs may be treated by dip tank application , drill box , and duster.


### HISTORY OF THIRAM AND BEAD PRODUCTS Thiram was first registered for use in the U
. S
. in 1948. The most recent Thiram RED was 2004. There have been no benefits assessments or Section 18 Emerge ncy Exemption Requests for thiram in the la s t 10 years. An emergency exemption may indicate that there is a need for a particu lar ch emical that is not registered for use on a particular site. An emergency exemption request may yield information about a particular che mical ' s importance or value that is not found in other EPA records. However , a lack of S ection 18 assessments by BEAD does not sp ecifically indicate the relative importance of the chemical.


### THIRAM USAGE Agricultura l Usage The number of acres treated wi th thiram remained constant at approximately 85 , 000 acres from 1998 through 2008. Sinc e 2008 , th e number of acre s treated with thiram has significant ly incre ased. In contrast , pounds a . i
. applied tremendous ly decreased from 1998-2008. Since 2008 , there has been a steady increase in pounds a .i
. applied
. These data indicate that application rates were much greater per acre pri or to 2008 and has continu ed to decrease through 2012. It should be noted that when interpreting the data presented in this analysis that EPA ' s proprietary data source did not begin s urveying fungicide seed treatments for field crops until 2006 while seed treatment surveys w ere not initiated for a ll other crops until 2009.

Pag e 3350, 0 00 5 ,000,000 

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### .... N CTI CTI 0 0 0 0 0 0 0 0 0 0 

### .... .... .... CTI CTI 0 0 0 0 0 0 0 0 0 0 0 0 0


### .... .... N N N N N N N N N N N N N Year

..,._ Po u n ds A .I. - .. - Total Are a Trea t e d F ig u re 

### 1. National Thiram Usage (Lbs A.I.) from 1 998 to 2012 S ourc e: Proprietary da t a, 1998 -2012 "t:I QI
.... 

### "' QI**~** "' QI 

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A revi ew of total thiram usage data across all crops for the 5 years prior to the most recent RED (2004) and the most recent 5 y e ars of reported usage indicates that the primary use sites hav e changed between the two periods (Tables l and 2). For the period 1999-2003 , apples and strawberries accounted for approximate ly 98% of lbs app li ed and total acres treated. In contrast , for the period 2008

-2012 , strawberries accounted for 35% of thiram pounds applied and l % of total acres treated with thiram while seed treatments accounted for approximately 63 % of thiram lbs app li ed and 98% of tota l acres treated. The decrease in usage on apples reflec ts the 2004 RED which canc e ll ed all use on apples
. T he change in usage from direct crop application to primarily seed treatment i s verified by the great decrease observed in application rates for the two periods (Tab les l and 2)
. On ly strawberries s h owed consistent usage for both periods. The change in application method is the underlying cause of th e d ecreased appl ication rate suggested in Figure 1. Furthermore, the increased acreage planted w ith treated seed is r e sponsib le for the increa s ing trend in thiram usage in terms of both total lbs applied and total area treated. Tab le 

### 1. Crops w ith Highest Use of Thiram (1999-2003) Crop Lbs A.I. 

### % of Tota l Tota l Acres 

### % of Total A.I. Rate (OOO's) T hiram Treated* Thiram Lbs (OOO 's) Treated Applied Acres Apples 669 56.6 248 48.7 2.696 Strawberries 493 41.7 254 49.8 1.945 Pears 8 0
.7 2 0.4 4.476 Cherri e s 8 0
. 6 ..., .) 0.7 2.25 Peaches 4 0.3 2 0.4 1.955 *Total Acres Treated s ums all acre s treated for a crop , including those acres that receive multiple treatments. Source: Proprietary Data , 1999-2003 Page4Tab le 2
. C rop s with Highe s t Use of Thiram (2008

-2012) Crop Lb s A
. I. % of Tota l %of A.I. (OOO 's) Tota l A cre s Tota l Rate Thiram Treated * Thiram Lb s (OOO 's ) Trea t e d App lied A cre s Soybeans (see d treatment) 252 45 6,914 61.2 0
. 036 Strawberries 1 99 35 1 13 1 l. 7 58 Wheat, Wi n ter (seed treatment) 50 9 1 , 277 11.3 0.039 Cotton (seed treatment) 35 6 2 , 302 20.4 0.015 Wheat , Spring (seed treatment) 18 3 585 5
. 2 0
. 031 *Total Acres Treated sums all acres treated for a crop , includ ing those acre s that rec e ive mu ltip le treat ments . Source: Proprietary D ata , 2008

- 20 12 While strawberries , soy beans , and cotton account for approximate ly 90% of tota l lbs of thiram applied , strawberries hve the greatest percent crop treated at 20% (Tab le 3)
. T hi s indica tes th at thiram use is s till impor tan t to strawb erry p rod uctio n . Furtherm o re , as ind icated in Table 2, app les are no longer a driver for thiram usage an d the apple data shown in Tab le 3 are an artifact of the usage reporti n g period of the Screening Level Usage Analysis (S L UA)
. T bl 3 P

a e 

## . e rcentCrop T t d " th Th' rea e W I 1ram 2004 2012 

## - C r op Percent Crop Treated A v g . Lbs. A
. I. Avera g e M aximum Apples 50 , 000 <2
. 5 10 Strawberries 50 , 000 20 30

Soybeans 40 , 000 <2
. 5 5

Wheat 20 , 000 <2.5 <2
. 5 Cotton 6,000 5 15 *Tota l Acres T reate d s um s a l l acre s tre ated for a crop , mc ludmg tho s e acres that receive mu ltiple treatmen t s. Source: EPA SLUA for Thiram , 2014
States w ith hi ghest usage of thi ram in terms of lbs a .i
. applied and acres treated for the period immediately prior to the 2004 RE D and the mos t recent five years of usage data are presented in Tab les 4 and 5. State data also ind icate a s hi ft in thira m usage as California, Florida , and Michigan are the only states of greates t thiran1 usage commo n to both time per i ods. In addition , Florida i s th e only state whic h showed cons i stent lbs ap p lied and total thi ram acres treate d across the time periods. In co n trast , bo th California and Mi chigan indicated
. a sub stantial decrease in lbs of thiram app li ed b ut an increase in number of thiram treated acres. As note d p reviously , th is again reflects the changing nature of thiram usage from crop application to seed treatment. As previously mentioned, seed treat ment usage data was no t fully recorded for a ll crops by EPA ' s prop ri etary data source u nt il 2008. Neverth eless , Ca li fornia was the greatest applier of th iram in terms oflbs a .i
. from both 1999

- 2003 and from 2008

- 2012. H owever, in terms of total ac res treated , thiram usage significantl y decreased in Cal ifornia wi th I ndiana repres entin g most ac re s treated in 2008-2012. Overall , lbs of thiram a pp li ed has decreased b y 52% w hil e total ac res treated h as increased b y 2100%. Page 5

### Table 4. States with Highest Use of Thiram (1999-2003) Crop Lbs A. I. % 

### of Total Total Acres

. % 

### of Total A.I. Rate (OOO 's) Thiram Lbs Treated* Thiram App li ed (OOO's) Treated Acres California 391 33.l 183 36.0 2
. 133 Washington 257 21.8 74 14.5 3.486 New York 171 14.5 65 12.7 2.647 Pennsylvania 102 8
. 6 58 11.5 1.745 Florida 90 7
. 6 67 13.1 1.357 Michigan 45 3.8 13 2.6 3.416 West Virginia 42 3.6 19 3
. 8 2 .20 2 Virginia 32 2.7 12 2.3 2.779 Oregon 2 1 1.7 6 1.2 3
. 34 North Carolina 18 1.5 7 1.4 2.497 *Total Acres Treated s ums all acres treated for a crop, in clud in g those acres that receive multiple treatments. Source: Proprietary Data , 2008-2012 

### Ta ble 5. S tates with Highest Use of Thiram (2008-2012) Crop Lbs A.I. 

### % of Tota l Total Ac re s % 

### of Total A .I. Rate (OOO's) Thiram Lbs Treated* T hir am Ap pli ed (OOO 's ) Treated Acres California 125 22.0 339 3.0 0.368

Indiana 111 19.6 3,040 26.9 0.036 Florida 91 16.0 77 0.7 1.18 Illinois 78 13.8 2 , 059 18.2 0.038

Ohio 45 7.9 1 ,225 10.8 0
. 037 Texas 24 4.2 1 ,5 02 13.3 0.016 Kentucky 16 2.8 444 3.9 0.036 Michigan 14 2.4 326 2.9 0
. 042 Montana 11 1.9 348 3
. 1 0
. 031 *Total Acres Treated sums all acres treated for a crop , including those acres that receive multiple treatment s . Source: Proprietary Data, 2008

-2012

Page 6Geographic D istrib uti on of Thiram Use

Pounds Active Ingredient per 1 , 000 Crop Acre s Grown LJ NoData 

## D < o .os 

## D 0
. 05

- 0
. 1

. 0
. 1

- 1



## - 1

-3



# - > 3 Figure 2. A nnual average ag ricultural use intensity of Thiram (2008 -2012 ). The average agricultural use intensity is greatest in California , Florida , and Indiana. This r eflects use on strawberries in California and Florida, and soybeans in Indiana
. Agricultural use in tensity in the north central and northwestern states reflects use on wheat and soybeans. Use intensity in T exas and Mississipp i results from both soybean and cotton production. 

### Non-Agricultural Usage Data for thiram use on non -agricultural sites is limited. The only ava il able estimate of non agricultural use is approximately 20,000 lbs on go lf courses**Propri~tary** D ata, 2012).


### BIOLOGICAL ASPECTS RELEVANT TO THIRAM Thiram is a fungicide belonging to dithiocarbamate group of fung icides. It belongs to group M3 ofFung ic ide Resistance Action Committee based on mode of action of fungicides (FRAC , 2014). Thiram has multi

- site contact activity and considered as a low risk fungicide without any Page 7sign of resistance developing in fung i. The dithiocarbamate group includes many other fungicides (such as mancozeb , maneb , zineb and ziram). Thiram is registered for use on many crops (s uch as strawberries, cotton, wheat, soybeans) to control many fungal pests. It is used as a standalone fungicide or in comb ination with fungicides belonging to different classes of systemic fungicides (such as carbox in , tebuconazole, triticonazole and metalaxyl) for controlling wide spectrum of fungal pest more effectively. Usually Thiram is mixed with carboxin, tebuconazole , triticonazole or metalaxyl is used for seed treatment.
ROLE OF THIRAM IN PEST MANAGEMENT Thiram is predominantly used on soybeans (seed treatment), strawberry (foliar use) , wheat (seed treatment) and cotton (seed treatment). Thiram seed treatment of soybeans controls seed rot , seedling b li ght and damping off caused by Fusarium spp . , Rhizoctonia spp. Foliar sprays of thiram on strawberry controls gray mold dis e ase (caused by Bottytis cinerae). On strawberry, thiram is used in alternation or combination with other fungicide (such as fenhexamid, cyprodinal, tludioxonil and azoxystrobin) for season long disease management. On wheat, thiram seed treatment controls smut diseases (caused Tilletia caries, T foelida and Ustilago nuda) , seed rot and seedling blight caused by soil-borne fungi such as Fusarium spp . and Allernaria spp. Thiram seed treatment of cotton seed contro l s soil-borne Rhizoctonia solani that causes seed rot , damping-off and sore - shin. It is an important fungic ide in managing plant diseases on different crops . DATA NEEDS The Agency currently does not have important information on thiram. Obtaining the fo ll owing information for al l registered non-agricultural sites may improve future assessments conducted by the Agency related to the use and importance of thiram. Usage • Total pounds active ingredient app li ed • Percent crop/ site treated • App li cation rates : typical and maximum • Frequency of application • Application Intervals • Methods of application • Target or niche pests • Efficacy information/product performance

Page 8REFERENCES FRAC. 2014. http: //www.frac.info/frac/ publication/anhang/20 l 4%20FRAC%20Code%20List.pdf. Assessed on December 2 , 2014. Proprietary Data. 1999

- 2003 Proprietary Data. 2008

- 2012 Proprietary Data
. 2012 EPA
. 2014. BEAD SLUA for Thiram

Page 9APPEN DIX A
The map included herein is primarily for the us e of the risk assessors in the Environmenta l Fate and Effects Division. The map provides a very broad geographical view of the average annual amount (in pounds) o f th e activ e ingredient applied per 1, 000 acres of crop acres grown. The se data are included in the maps because risk assessors are interes ted in the amount of a pesticide used across agricultural land. The calcu lated values presented in the · map are not equivalent to an application rate (lb a i /A). The data used to make these maps have several limitations
. Any interpretation of th e maps s hould consider the underlying data and the assoc i ated li mitations carefull y. The numerator (annual average pounds applied) is bas ed on private market surveys of pestic ide use in agriculture average d over the last five years (Proprietary Oata 1 2008

- 2012). These surveys cover about 60 crops and are targeted in s tates that produce the major ity of the crop . Although the surveys capture most of th e use of a particular acti ve ingredient in agri culture, th ere are severa l limitations to these surveys.
• States with minor production of a surveyed crop are not sampled • Not a ll types ofpesticides are surveyed in every crop in every year • Many specialty crops w i th very small acreages are not included in the survey The result of these limitations is that states that show no usage may actua ll y have a small amount of the active ingredient being used. In some cases the display ed use intensity may be distorted because the surveyed crops and the reported pestic ide usage may not accurately re present the actual pesticide usage on the crops produced in the state . The denominator (1 , 000 crop acres grown) was also obtained from the same private market survey database. The "Crop Acres Grown " variable represents the to tal acres grown in a given state of all of the surveyed crops. Th is value is indep endent ofp es ticide usage and pesticide registration . It is important to note that the surveyed crops (about 60) are sampled from states th at are major producers of each crop . Therefore , there are cases where the actual crop acreage in a state is higher than that reported by crop acres grown in the survey b ecause either that state and/ or crop was not included in the survey. The reader shou ld pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a d ifferent c hemical as the legend bins wi ll likely be diffe rent.

Page 10