UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

I JUL 07 2D15 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

MEMORANDUM 

SUBJECT: Response to Public Comments from Bayer (registrant) on the BEAD Chemical 

Profiles for Spirodiclofen and Spiromesifen (DP #s 427624 and 42762 1) 

FROM: Nikhil Mallarnpalli, Entomologist /tL c/ ll't...A-----

Biological Analysis Branch ----

THRU: 

TO: 

Donald Atwood, Entomologist fr~ .I/fl c J 

Claire Paisley-Jones, Environmental Protection Specialist t-.. '1?, C...., ~ ,.,....,., 

Science and Information Ana lysis Branch ( 

Biological and Economic Analysis Division (7503P) 

Arnet Jones, Chie f ;J /J /3~ .(._ Av.~ ... A ~s Biological Analysis BCncii '/ , 

Sc

Diann 

ience 

Sim

and 

s, 

Informati

Chief ~ on Analysis Branch 

Biological and Economic Analysis Division (7503 P) 

Jolene Trujillo 

Biologist/Chemical Review Manager 

Risk Management and Implementation Branch V 

Pesticide Re-evaluation Divison 

Office of Pesticide Programs (7505P) 

Peer Review Panel date: June 24, 2015 

SUMMARY 

Spiromesifen and spirodiclofen insecti cide are currently undergoing registration review. In this 

memorandum, the Biological and Economi c Analysis Division (BEAD) responds to comments 

received from Bayer (the registrant) on BEAD chemical profiles (BCPs) for these insecticides .. 

The comments addressed are from Bayer CropScience, the registrant fo r both chemi cals. Bayer 

corrected some statements in the BCPs regarding registered use sites and forrnulation methods. 

Bayer a lso provided input on some of the data needs identified by BEAD in its BCPs. BEAD 

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agrees with the information provided; it should assist the registration team in future work on 

registration review of these insecticides. 

SUMMARY OF BAYER'S COMMENTS 

While the registrant provided several comments addressing most of the Agency documents in the 

chemical dockets, this memorandum focuses only on the ones relevant to the BCPs. 

For spirodiclofen, Bayer made the following points relevant to the BEAD chemical profile and 

usage summaries: 

Berries are not a registered crop. 

Decline in use beginning in 2010 may be due to two causes: an increased number of 

registered miticides competing with spirodiclofen; 2) the recent change in commercial status 

of Abamectin to "generic which has increased the suppl y of this market-l eading miticide. 

There are no reports of pest resistance. 

For spiromesifen, Bayer made the following points relevant to the BEAD chemical profile and 

usage summaries: 

There are no emulsifiable concentrate formulations, as mentioned in the BCP. 

Regarding the increase in use from 2005 to 2012, Bayer proposed that this might be due to 

the publicity surrounding its product launch and a drought that increased use in corn in the 

High Plains states (Texas, Oklahoma, New Mexico, and Colorado). 

Bayer also suggested that relatively high usage in strawberries, cantaloupes, and eggplants 

may be due to a lack of alternatives effective against both mites and whiteflies. 

Bayer also provided information on application rates and number of applications per year in 

non-agricultural settings, in response to one of the data requests in BEA D's BCP. 

BEAD'S RESPONSE 

BEAD acknowledges the errors in description of registered use sites (for spirodiclofen) and 

formulations (for spiromesifen). Future registration review work will take these corrections into 

account. BEAD also appreciates the information on application rates and methods, as well as the 

discussion of why usage may have increased or declined, or remained relatively high in various 

crops. This information should assist in future work on the risks and benefits of each of these 

miticides. 

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