Registration Decision for New Use Based on Method of 

Delivery of Lavandulyl Senecioate 

Update to the Lavandulyl Senecioate 

Biopesticides Registration Action Document (BRAD) 

Approved by: 

Robert McNally, Director 

Biopesticides and 

Pollution Prevention Division 

Date: 
1. Background 

On June 12, 2014, the U.S. Environmental Protection Agency ("EPA") received an application 

from Suterra LLC for the registration of a new use based on method of delivery of 5-methyl-2-

(1-methylethenyl)-4-hexenyl 3-methyl-2-butonate (common name: lavandulyl senecioate; CAS 

Number 23960-07-8), an arthropod pheromone first registered on January 29,2010. There will 

be one new product sold under the trade name "CheckMate YMB-F" (EPA File Symbol No. 

56336-A T). Lavandulyl senecioate is classified as a biochemical pesticide based on its history of 

exposure to humans and the environment demonstrating minimal toxicity and its non-toxic mode 

of action to the target pest(s). Lavandulyl senecioate has been previously summarized in the 

Biopesticides Registration Action Document (BRAD) dated January 20, 2010 available in 

Docket ID EPA-I-IQ-OPP-2009-0044 via http://www.regulations.gov. 

Lavandulyl senecioate is a teclmical grade synthetic arthropod pheromone. This arthropod 

pheromone is structurall y similar to and mimics a naturally occurring pheromone produced by 

the fema le vine mealybug (Planococcus ficus) to attract males for mating. This pheromone is 

used to disrupt the normal mating cycle of the vine mealybug in raisin, table and wine grapes and 

has a non-toxic mode of action. As an arthropod pheromone, lavandulyl senecioate is exempt 

from the requirement of a tolerance when used in retrievably sized polymeric matrix dispensers 

in or on all raw agricultural commodities when applied to growing crops only at a rate not to 

exceed 150 grams active ingredient/acre/year in accordance with good agricultural practices (40 

CFR 180. 11 24). The one new product, CheckMate VMB-F (EPA File Symbol No. 56636-AT), 

put forth by Suterra LLC is intended to be applied in an aqueous micro-bead/dispensers via 

normal spray equipment. The proposed new use based on method of delivery of lavandulyl 

senecioate is not covered under the existing arthropod pheromone tolerance exemption listed in 

40 CFR 180. 1 124. Therefore, Suterra LLC has requested that 40 CFR part 180 be amended by 

establishing an exemption from the requirement of a tolerance for residues of the arthropod 

pheromone, lavandulyl senecioate, in or on all raw agricultural commodities when applied or 

used in microbeads/dispensers at a rate not to exceed 150 grams active ingredient/acre/year. A 

copy of the petition is available in Docket ID EPA-HQ-OPP-20 15-00 17 via 

http://www.regulations.gov. 

2. Evaluation 

In evaluating a pestic ide registration application, the EPA assesses a wide variety of 

environmental fate (i.e., how the chemical will move in the environment) and toxicity studies 

(i. e., effects on non-target organisms) to determine the likelihood of adverse effects (i.e., risk) 

from exposures associated with the proposed use of the product. Risk assessments are developed 

to evaluate the environmental fate of the compound as well as how it might affect a wide range 

of non-target organisms including humans, terrestrial and aquatic wildlife (plants and animals), 

On the basis of these assessments, EPA evaluates and approves language for each pesticide label 

to ensure the directions for use and safety measures are appropriate to mitigate any potential risk. 

In this way, the pesticide's label helps to communicate essenti al limitations and mitigations that 

are necessary for public safety. In fact, the pesticide law has a provision which indicates that it is 

a violation to use a pesticide in a way that conflicts with the label. 

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2.1 Assessment of Risk to Human Health 

EPA requires a wide range of studies in order to assess a pesticide. For lavandulyl senecioate, 

adequate data/information has been received by the Agency to support the assessment of risk to 

human health for the use of this arthropod pheromone in or on all raw agricultural commodities 

when applied/used at a rate not to exceed 150 grams acti ve ingredient/acre/year (new use based 

on method of delivery). 

The acute toxicity for lavandulyl senecioate is low for all routes of exposure (oral, dermal, 

inhalation), with the exception of skin irritation (moderately irritating). The labeling 

precautionary signal word is "CAUTION." · 

The evaluation of the data and information submitted indicate that lavandulyl senecioate is not 

genotoxic. There are no known effects of lavandulyl senecioate on endocrine systems via oral, 

dermal, or inhalation routes of exposure. To address the subchronic and prenatal developmental 

toxicity data requirements for this exemption from the requirement of a tolerance for this 

arthropod pheromone, lavandulyl senecioate, the petitioner submitted scientific rationales that 

demonstrate that it is highly unlikely that there will be significant repeated exposure, including 

dietary exposure and exposure to female humans, to this pheromone when used as proposed 

based on the extremely low application rate, low emission rate, rapid volatilization after emission 

from the microbeads, and rapid biodegradation. Taking into account the petitioner's rationale, 

EPA has concluded that there is unlikely to be exposure that could result in subchronic and 

developmental effects and so has waived the requirements for subchronic and prenatal 

developmental testing. Furthem1ore, EPA has not found lavandul yl senecioate to share a 

common mechanism of toxicity with any other substances, and lavandulyl senecioate does not 

appear to produce a toxic metabolite produced by other substances. 

Given the low likelihood of adverse effects on humans, more refined estimates of acute and 

chronic dietary risk were not necessary for lavandulyl senecioate. Lavandulyl senecioate is 

already present in the environment wherever vine mealybugs are present and mating, and 

humans are already exposed on a repeated basis. Furthermore, human exposure to lavandulyl 

senecioate via dietary exposure to pesticide-treated commodities, such as raisin, table and wine 

grapes, is highly unlikely. Residues on food commodities are not anticipated as arthropod 

pheromones, including lavandulyl senecioate, are highly volatile and rapidly biodegrade. 

Exposure of humans to lavandulyl senecioate in drinking water is not expected because 

lavandulyl senecioate is highly volatile and degrades rapidly in the environment and it is not to 

be applied directly to water. 

For more information, please refer to the document entitled, "Federal Food, Drug, and Cosmetic 

Act (FFDCA) Considerations for Lavandulyl Senecioate (June 30, 2015)," which can be found in 

Docket ID EPA-HQ-OPP-20 15-0017 (Document ID: EPA-HQ-OPP-2015-00 17-0007). 

2.2 Assessment of Ecological Risk 

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According to 40 CFR 158.2060(a)(2), arthropod pheromones when applied at up to a maximum 

use rate of 150 grams active ingredient/acre/year, and that are not expected to be available to 

avian species, are not required to provide non-target toxicity and environmental fate data. 

Lavandulyl senecioate is a synthetic arthropod pheromone that is structurally similar to and 

mimics the pheromone produced by the female vine mealybug. This compound acts on a select 

gro up of insects and has a non-toxic mode of action. The end-use products (EPs), in retrievable 

sized polymeric dispensers and sprayable microbeads, are not expected to be available to avian 

spec1es. 

3. Alternatives 

Lavandulyl senecioate can be used alone or alongside currently registered biochemical or 

conventional pesticides and can be an important component of an Integrated Pest Management 

(IPM) system. According to the petitioner, Suterra LLC, the proposed product, CheckMate 

VMB-F, containing Iavand ul yl senecioate in an aqueous micro-bead/dispensers that can be 

applied via normal spray, is: 1) an improvement in some situations over Suterra 's currently 

registered vine mealybug (VMB) hand-applied dispenser such as when large farms experience 

problems in deployment costs and crew management issues, and 2) at other times is foreseen to 

complement the currently registered VMB hand-applied dispenser in scenarios with longer 

growing seasons(> 150 days). The use of this arthropod pheromone is expected to displace 

and/or reduce the amount of insecticides used against the target pest, vi ne mealybug, that contain 

more toxic conventio nal active ingredients such as imidacloprid, buprofezin, acetamiprid, 

clothianidin, chlorpyrifos, spirotetramat, thiamethoxam, and dinotefuran. Growers may prefer to 

use lavandulyl senecioate as a viable alternative to conventional insecticides because lavandulyl 

senecioate has an established exemption from the requirement of a tolerance for all raw 

agricultural commodities, indicating that it is safe. Conventional insecticides generally have 

tolerances and may result in residues of concern o n food commodities. 

4. Benefits and Public Comments 

By definjtion alone, biochemicals are favorable when compared to currently registered 

conventional alternatives because biochemicals are naturally-occurring substances (or substances 

structurally-similar and functionally identical to naturally-occurring substances) with a history of 

exposure to humans and the environment demonstrating minimal toxicity and a non-toxic mode 

of action to the target pest(s). Benefits of biochemical pesticides as compared to conventional 

pesticides typically include lower toxicity profiles for humans and non-target organisms, and 

faster degradation in the environment. As outlined above, the arthropod pheromone, lavandulyl 

senecioate is a viable alternative to conventional insecticides containing a low toxicity profile, 

high volatility, and rapid degradation in the environment. 

On March 4, 2015, EPA published a Notice of Filing in the Federal Register announcing the 

receipt of the initial filing of the lavandulyl senccioate petition by Suterra LLC, under the 

Federal Food, Drug and Cosmetic Act (FFDCA) requesting the establishment of an exemption 

from the requirement of a tolerance for residues of the arthropod pheromone, lavandulyl 

senecioate, in or on all raw agricultural commodities when applied/used at a rate not to exceed 

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150 grams active ingredient/acre/year. This publication also announced a public comment period 

of30 days. No comments were received on the notice of filing. 

EPA announced (in Docket ID: EPA-HQ-OPP-2015-0017) the proposed decision of the 

unconditional registration of the new use based on method of delivery of the arthropod 

pheromone, lavandulyl senecioate, on July 9, 2015, and held a public comment period for 15 

days, closing July 24, 2015, at 11 :59 PM EST. The announcement included the draft Decision 

Document and the draft product label for "CheckMate VMB-F" (EPA File Symbol No. 56336-

A T). No comments were received during this public comment period. 

5. Regulatory Decision 

The lavandulyl senecioate database is considered to be complete. The proposed new use based 

on method of delivery of lavandulyl senecioate is well supported by this database. In considering 

the assessed risk to human health and the environment, the Agency concludes that lavandulyl 

senecioate meets the regulatory standard under the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA). There are no outstanding data requirements for this biochemical. 

Therefore, the EPA is granting the unconditional registration of the lavandulyl senecioate new 

use based on method of delivery under Section 3(c)(5) of FIFRA. 

One product will be registered. "CheckMate VMB-F" is an EP that contains lavandulyl 

senecioate as its sole active ingredient. Appli cation of this product containing an aqueous 

solution of microbeads/dispsensers can be made any time prior to crop harvest. The product will 

only affect adult vine mealybug males and has no effect on females, eggs, or immatures. The 

application rate is 5-10 grams of active ingredient per acre and the user cannot exceed 150 grams 

active ingredient per acre per year. Raisin, table and wine grape crops may be retreated via 

normal ground and aerial spray equipment as needed based on insect monitoring and field 

scouting programs. 

The risk assessment supporting this decision can be found in the regulatory docket (Document 

10: EPA-HQ-OPP-20 15-00 17-0005). 

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