UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AS IG N, D.C. 20460

MAR2 9 2011

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

MEMORANDUM

SUBJECT:

FROM:

THRU:

TO:

BEAD Response to the California Grape and Tree Fruit League (League)

Regarding the Agency 's Action to Discontinue Methomyl Use on Table Grapes

(PC Code 090301)

Jihad Alsadek, Economist ,,;r:;l-.--f A-c IScience Information & Analysis Branch

Monisha Kaul, Biologist fY7otu!J fvU

Colwell Cook, Entomologis: '..- Biological Analysis Branch

Biological and Economic Analysis Division (7503P)

Sc

Diann

ience

Sims

Information

, Chief ~~& Analysis Branch ')

Arnet Jones, Chief / 1

Biological Analysis r~ Biological and Economic Analysi ivision (7503P)

Tom Myers, Team Leader

Risk Management and Implementation Branch II

Pesticide Re-Evaluation Division (7508P)

The methomyl registration review opened September 20 10 with a 60-day public comment

period. During that time the California Grapes & Tree Fruit League (League) submitted a

document with questions and comments that the Agency is currently addressing. This

memorandum contains BEAD's response to the League' s issues regarding the cancellation of

methomyl on grapes; concerns about the use of alternatives of methomyl on grapes for all

varieties of grapes combined (Kaul and Wyatt, 2006); the use ofmethomyl on grapes, as

reported in the Screening Level Usage Analysis (SLUA); and the pounds of methomyI used on

table grapes in California .between 2002-2008.

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Lea gue Comments: BEAD 's 2006 Alternatives Assessment did not obtain adequate inputfrom

the California table grape industry to sufficiently identify appropriate pests ofCalifornia table

grapes. Methomyl is usedf or two insect pests omitted fro m Kaul and Wyatt, (2006):

Planococcus ficus and Latrodectus Hesperlf§".

BEADIBAB Response: The May 17, 2006 "Alternatives Assessment for Methomyl on Grapes"

was for all grapes (raisin, table , and wine) nationwide, and therefore, did not focus on anyone

type of grape (Kaul and Wyatt (2006). Information was obtained from the publicly available

crop profiles and pest management strategic plans available on the Integrated Pest Management

Centers website tt //www c e J) The Crop Profile for Grapes (Table) in California,

referenced in Kaul and Wyatt (2006), was produced by university researchers, IPM advisors,

growers, and a member of the California Table Grape Commission under the name "California

Grape Advisory Team."

A subsequent analysis "Review of Proposed Label Changes and Use Patterns for Methomyl Use

on Grapes" was conducted in 2008 that included information on California table grape s obtained

from industry input , specifically from Marcy Martin (of the league) in comm unications with

BEAD (Kaul, 2008). In the 2008 BEAD review, two add itional pests (vine mealybug and black

widow spider) of concern and their control practices specific to California table grapes were

considered, which were those identified by the League as omitted from BEAD's 2006

assessment. Additional pest information specific to California table grapes submitted in support

of an emergency exemption request in 20m: was also considered in BEAD's 2008 methomyl

analysis.

Lea gue Comments: "The Methomyl Screening Level Usage Analysis (SLUA) identifies a

screening level estimate on grapes to be based on 20,000 p ounds ofactive ingredient annually,

with the average ofless than 2.5 percent to 5percent afthe crop treated annually. It appears the

Agency has determined that all usage is table grape usage, and that the treated acreage is

greater than 5 percent. How did the agency make this determination?"

" II BEADISIABIULUTResponse: Tbe SLUA sows thh ese va ues or all g apes

Crop Lbs. A.!. PCT Ava. PCT Max.

Graces 20,000 <2.5 5

The data are for all types of grapes (table, raisins and wine) and not for table grapes only. The

20,000 lbs. A.!. are the average annual pounds ofmethomyI appl ied on grapes (2001 -2008).

This includes all the surveyed states and is national in scope. The average value of <2.5% is the

average percent crop treated with methomyl for all grapes combined, and the maximum value of

5% is the maximum percent crop treated across 2001-2008 . The data are from two usage data

sources for the Agency : The United States Department of Agriculture's National Agricultural

Statistics Service (USDA/NASS) and GfK Kynetec. The abo ve reported SLUA values are

calculated by merging pesticide usage data sources, averaging across all observations, then

rounding. The average value « 2.5%) is used for chronic risk analysis and the maximum value,

the highe st of all observations (2001-2008) is used for the acute risk assessment.

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BEAD checked the availab le data for table grapes only and used the same methodology to

calculate average annual pounds used, average percent and maximum percent of methomyl used

on table grapes. The data show the annual average usage of methomyl on table grapes is about

14,000 pounds. The average percent oftable grapes treated with methomyl is 13 percent and the

maximum acreage treated for table grapes is 28 percent.

League Comments: "California's Department of Pesticide Regulation Annual Statewide Use

Summary combines both grape and raisin usage when reponing total chemical applications and

acres treated. In confirming this informaticn we reviewed the annual pounds appliedfor lable

and raisin grapes within the statewide sumr.lary ; betv..een 2002-2008. the 5 year annual average

is 15,./82 pounds, which is significantly less than what the Agency has identified above. "

BEAD/SIABIUL UT Response: California's Department of Pesticide Regulation Annual

Statewide Use Summary reports the annual pounds for grapes (table grapes and raisin grapes

combined) and wine grapes (Cal DPR, 200" -2008). The available data for the period 2002-2008

showed a 5 year avera ge of 15,883 pounds for grapes and 4,293 pounds for wine grapes which is

about 20.000 pounds for both. In addition California data are only for one state and the SLUA

data are national in scope. BEAD 's value d oes not differ significantly from the league's value.

References:

Kaul, M. and T.1. Wyatt, 2006.Altematives Assessment for Methomyl on Grapes, DP # 321899,

Unpublished EPA document.

Kaul, M2008 . Review of Proposed Label Changes and Use Patterns for Methomyl Use on

Grapes, DP # 353390. Unpublished EPA document.

BEAD Screening Level Usage Analysis (SLUA). Screening Level Estimates of Agricultural

Uses of Methomyl, PC Code 090301, October 19, 2009. Unpublished EPA document.

Cal DPR, 2002-2008. Usage Data for Grapes, both table and raisins, and Wine Grapes,

http://www.cdpr.ca.gov/docs/pur/punnain.htm

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