UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D
.C

. 20460 

## DEC 08 20\\

MEMORANDUM OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION



### SUBJECT: 

### BEAD Chemical Profile for Registration Review: Aldicarb (098301) FROM:

THRU:

TO: 

### David Brassard, Entomologist Biological Analysis Branch Katherine Stebbins, Biologist

### ~ Science Information and Analysis Branch Derek Berwald, Economist

# ~ Economic Analysis Branch Biological and Economic Analysis Division (7503P) Arnet Jones, Chief 

# /J A "'\ Biological Analysis Branch

## ~ Diann Sims, Chief

# J1}~--l"-'Y Science Information and Analysis Branch Timothy Kiely, Chief [\- 

# k. I 

# J Economic Analysis Branch

# ~ \). V"

# \J Biological and Economic Analysis Division (7503P) Susan Bartow, Chemical Review Manager Anne Overstreet, Team Leader Eric Olson, Acting Branch Chief Risk Management and Implementation Branch 4 Pesticide Reevaluation Division (7508P)


### Peer Review Panel date: July 14,2010 INTRODUCTION 

### The purpose ofthis document is to convey usage information and a broad overview ofthe pest management role ofpesticides that are beginning to undergo registration review. The anticipated audience consists ofthe team ofEPA staffcurrently evaluating the registration status ofaldicarb,and eventually the general public. 1bis document builds uponthe data already provided inthe "Usage and Label Use DataPackages" that are also providedto Registration Reviewteams by BEAD. The document is based on infonnation and data available to BEAD as ofNovember 23, 2011. Aldicarb is a systemic carbamate insecticide, acaricide, and nematicide used on agricultural crops including cotton, dry beans, peanuts, soybeans, sugarbeets, and sweetpotatoes. Aldicarb is fonnulated as a granular pesticide and is usually applied early inthe growing season (preplant, at-plant, or early post-emergent) using ground application equipment. Inpast BEAD analyses, aldicarb has been shownto have significant value to growers. Because aldicarb is a high value chemical with significant risks, BEAD anticipates thatregistration review will require substantial effort.


### REGULATORY HISTORY Aldicarb**w~** first registered inthe U.S. in 1970. The use ofaldicarb on coffee, ornamentals, pecans, sugarcane, sorghum, tobacco, and alfalfa grown for seed were cancelled as a result ofthe RED issued in 2007. The RED also required new risk mitigation language on labeling for cotton, dry beans, peanuts, soybeans, sugarbeets, and sweetpotatoes. OnAugust 16, 2010, Bayer signed a Memorandum ofAgreement that resulted intheremoval ofthe citrus and potato uses from the label and a phase-out ofall remaining uses by 2018. Later in 2010, the Registration Divisionreceived a new application from AgLogic, LLC to register a 15% granular fonnulation ofaldicarb for use on cotton, dry beans, peanuts, soybeans, sugar beets, and sweet potatoes. USE 

### SITES Aldicarb is registered for use oncotton, dry beans, peanuts, soybeans, sugar beets, and sweet potatoes. 

### COMMON FORMULATIONS AND APPLICATION METHODS The only labeled fonnulation for aldicarb is granular. Aldicarb maybe applied as a soil treatment using ground equipmentby any ofthe following methods: sidedress, bandiT-band, and in-furrowtreatment. When applied as a post-emergence application to peanuts (pegging application), aldicarb may be applied in a band 12 to 18 inches wide onto the row and into the plantcanopy. The granules must be dislodged from the plant and the application should be followed immediately by irrigation (unless rainfall is received). USAGE Overthe 1998-2010 timeframe, usage overall (excluding sweetpotatoes because usage data are not available) was relatively stable (Figure 1). In 1999, there was a notable increase inuse 2

### which was largely driven by use in citrus. During the mostrecent years of2006-2010, on average, approximately 3.7 million pounds ofaldicarb was used to treat 3.6 million acres (Proprietary Data 2006-2010). Depending onthe crop, aldicarb is typically applied at a rate of 0.6-4.2 pounds AI per acre (Proprietary Data 2006-2010).
Pounds AI A lied 1998-2010 6,000,000 .,--------------------------

- Other

- Potatoes

- Peanuts

- Oranges

- Cotton



## o 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Source: Proprietary Data (1998-2010) 

### From 2006-2010, the top crops in terms ofthe pounds AI applied were cotton (47%), oranges (23%), peanuts (13%), andpotatoes (6%) (Figure 2). In terms ofthe acres treated, cotton ranked highest at (72%), followed, by peanuts (14%) and oranges (5%) (Figure 3). The differences in ranking between the pounds and acres treated is a function ofthe rate (the typical rates for citrus and potatoes are much higher than for cotton and peanuts). The states with the most agricultural usage interms ofpounds AI applied are Florida (28% ofthe national pounds applied), Georgia (22%), Texas (12%), North Carolina (9%) and Idaho (5%). The top states for acres treated with by aldicarb are Georgia (31% 

### ofnational acres treated), Texas (20%), North Carolina (11%), Florida (7%), Arkansas (5%) and Alabama (5%). Figure 4 spatially represents aldicarb usage (average pounds a.i. applied) in the US. The use pattern shows concentrations ofaldicarb use in the Southeast, where aldicarb was used on peanuts, cotton and citrus, with some significant use inthe potato growing areas ofthe northwest. Because aldicarb is no longer used on potato or citrus, this map would look different in the future.

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### Figure 2. Top Crops for Aldicarb, 2006-2010 (Percent ofTotal Pounds AI Applied)

6%
Peanuts

13% Other

Cotton 47%

Other crops (listed in order ofranking) grapefruit, sugarbeets, soybeans, tobacco, pecans, dry beans/peas, sugarcane, sorghum, and lemons. Source: Proprietary Data, 2006-2010 

### Figure 3. Top Crops for Aldicarb, 2006-2010 (Percent ofTotal Acre Treatments)

Other

Other crops (listed in order ofranking) soybeans, sugarbeets, grapefruit, tobacco, dry beans/peas, pecans, sorghum, sugarcane, and lemons. Source: Proprietary Data, 2006-2010



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### Figure 4. Aldicarb Usage by Crop Reporting District (2006-2010)

Average Pounds per 1,000 Acres of Farmland

_ >0-3

_ 4-10 D ll-19 0 20-62 63

- 210 N 

# I

This is a map ofagricultural pesticide usage at the Crop Reporting District (CRD) level. CRDs are boundaries created by USDA NASS which are aggregates ofcounties (USDA, 2010). Pesticide usage is displayed as average pounds (for the years 2006-2010) per 1,000 acres offarmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acreage was obtained from USDA (2007). Usage is based on private market surveys ofpesticide use in agriculture (Proprietary Data, 2006-2010). The survey data are limited to the states that representthe top 80-90% ofacreage for the individual crops, therefore, use may be occurring in regions outside the scope ofthe survey. CRDs showing no usage of pesticides may be due to either the lack ofpesticide use in the region ornon-participation in the agricultural surveys. Sources: Proprietary Data. 2006-2010 USDA, 2006-2010. NASS Crop Reporting Districts. Online: http://www.ers.usda
.gov/briefing/arms/resourceregions/resourceregions.htm#nass
. USDA, 2007. Census ofAgriculture. Online: http://www.agcensus.usda.gov/Publications/2007/index.asp
.



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### BIOLOGICAL ASPECTS RELEVANT TO ALDICARB Aldicarb is applied to the soil as a pre-plant, at-plant, or early post-emergent treatment, using ground application equipment. The biggest use ofaldicarb is on cotton, where it is used primarily for control ofthrips. Onpeanuts, aldicarb is used to control nematodes and thrips and to provide suppression ofleafhoppers and spider mites. Ondry beans, aldicarb is used to control nematodes, seedcorn maggot, and aphids. The use ofaldicarb on dry beans is only allowed in Colorado, Oregon, Washington, Idaho, and Michigan. On soybeans, aldicarb is used to control nematodes, Mexican beanbeetle, and thrips. The use ofaldicarb on soybeans is only allowed in Georgia, North Carolina, South Carolina, and Virginia. On sugarbeets, aldicarb is used to control nematodes and sugarbeetroot maggot. The use ofaldicarb on soybeans is only allowed in Montana, Nebraska, Oregon, Washington and Wyoming. On sweetpotatoes, aldicarb is used to control nematodes. The use ofaldicarb on sweetpotatoes is only allowed in Louisiana and Mississippi.


### HISTORY OF BEAD ASSESSMENTS FORALDICARB Because it is a pesticide withhigh value to growers but significantrisks, aldicarb has been evaluated many times by BEAD, mostly as a part ofalternative analyses supporting the recent reregistration ofthe chemical. In general, aldicarb is a pesticide with high value to growers because it controls a broad spectrum ofpest control and has a longerperiod ofresidual activity than most alternatives. In addition to the summaries below, BEAD has evaluated aldicarb use on potatoes and citrus. Because aldicarb is no longerregistered onthose crops, summaries are not included, butthey also showed aldicarb to have a high value. The biggest use ofaldicarb is on cotton, where 

### itis used primarily for control ofthrips. As part ofthe risk-benefit analysis for reregistration, BEAD conducted an analysis ofpossible alternatives to aldicarb used on cotton inthe major cotton growing areas. Aldicarb also provides control ofseveral other cottonpests, and itprovides protection for a longertime than any ofthe alternatives. Because ofits long residual activity, inmany cases growers can apply one treatment ofaldicarb, ratherthan multiple treatments ofother chemicals for equivalent control. Although there is no single chemical replacement for aldicarb, a combination ofchemicals could be used effectively. The alternatives for aphid and thrips control could include imidacloprid, thiamethoxam and acephate (Atwood, 2011). The combination ofchemicals was more expensive than aldicarb: example calculations showedthat chemical costs alone wouldbe about $2 per acre higher in Mississippi and $22 per acre higher in California. In addition to insectpests, aldicarb can control nematodes. Ifnematodes are considered the target pest, growers have fe'Yer alternatives to aldicarb. Alternatives for controlling nematodes would be abamectin, chloropicrin, dichloropropene, and metam sodium (Atwood, 2011), although these may be costprohibitive in cotton. Based onEPAproprietary data, the additional cost for replacing aldicarb with 1,3-dichloropropene, along with the combination ofchemicals to provide control ofthrips is about $38 per acre. Ofthat figure, $36 per acre is based onthe chemical cost of 1,3-dichloropropene Ifwe were to assume thatthese acres were treated with 1,3-dichloropropene instead, the additional costs are over $50 million annually. Itis unlikely,
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### however, that all ofthe acreage with aldicarb applied as a nematicide wouldbe treated with 1,3- dichloropropene. Depending onthe local conditions, growers may choose not to apply a nematicide, but rather accept the yield losses from nematode damage. BEAD did nothave an estimate ofthe resulting yield loss (Berwald and Chiri, 2007). Onpeanuts, aldicarb is used to control nematodes and thrips onpeanuts, and it also provides suppression ofleafhoppers and spider mites. Unlike other crops, onpeanuts aldicarb can be applied twice in a growing season. Aldicarb canbe applied when peanuts are planted, or can be used as a split treatment, where aldicarb is applied both at planting time and later in the season, when the plants are forming pegs which develop into peanuts, although that "at-peg" application seems to be used less often than inthe past (Atwood, 2011). While early season control of nematodes may be achieved with a pre-plant soil fumigation with 1,3-dichloropropene (1 ,3-D) or other fumigants, there are no effective alternatives for the at-peg application ofaldicarb for nematode control. Without aldicarb, costs to growers from the yield losses due to nematode damage alone was estimated to exceed $15 million a year in Georgia, and up to $22 million a year nationwide. There were uncertainties in the analysis, but alternatives for late season control for nematodes were up to $300 per acre based on data from field trials performed in Georgia (Chiri and Berwald, 2007). Alternatives to control thrips in peanut include phorate and acephate (Atwood,2011). There are other, smaller uses ofaldicarb where industry participants consider it to be an important chemical. These include production ofsweet potato slips, soybeans inthe southern United States, and pecan growers. DATA NEEDS RELEVANT TO BEAD'S FUTURE WORK ON ALDICARB 

### Usage data for sweet potatoes (ex. pounds a.i. applied, total area treated, percent ofthe crop treated) may be needed for future assessments. REFERENCES 

### Atwood, Don,AlternativesAssessmentforAldicarb on Cotton andPeanut, June 22, 2011. Chiri, Angel and Derek Berwald, Quantitative ImpactAnalysis forAt-PegApplication of Aldicarb on Peanuts (DP 337549), June 20, 2007. Berwald, Derek and Angel Chiri, Significance of Aldicarb Use in the Production of DryBeans, Soybeans, Pecans, SweetPotatoes, Cotton and Citrus, September 20,2007. Gross, William, Angel Chiri and Derek Berwald, Preliminary alternativesAnalysis forAldicarb on Potatoes (DP 299886), December 30, 2005. NPIRS,2011 http://npirs.ceris.purdue.edu Proprietary Data. (1998-2010). U.S. EPA. 2007. Reregistration Eligibility Decision for Aldicarb. http://www.epa.gov /oppsrrd1 /reregistrationlREDslaldicarb red.pdf 

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