UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

MAY~ 0 2014 

MEMORANDUM 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: BEAD Chemical Profile (BCP) for Registration Review: Yellow Mustard Seed 

FROM: 

THRU: 

(014901) and Sodium Alphaj}efin Sulfonate (000905) 

Colwell Cook, Biologist ~~ Biological Analysis Branch J 

Sepehr Haddad, Environmental Protection Specialist / f( ....../ 

Science Information and Analysis Branch 

Stephen Smearman, Economist ):t~~ Economic Analysis Branch 

Biological and Economic Analysis Division (7503P) 

Amet 

Biological 

Jones, 

Analysis 

Chief 

Branch 

~ (/ 

Diann 

Science 

Sims, 

Information 

Chief ~ and Analysis Branch 

Timothy Kiely, Chief ~ ' 

Economic Analysis Branc 

Biological and Economic Analy · s Division ( 

TO: Shirley Keel, Chemical Review Manager 

Risk Management and Implementation Branch 5 

Pesticide Re-evaluation Division (7508P) 

Peer Review Panel date: May 14,2014 

Page 1 
SUMMARY 

There is only one active registration (EPA Reg.# 87972-1 (formerly #72919-1) with the 

registration name VargonTM, that has the active ingredients of sulfonic acids (C14-16 alkane 

hydroxy and C14-16-alkene, sodium salts) and yellow mustard (Brassica hirta) seed. This 

product was registered in 2003 and is used for control of Richardson's ground squirrel and 

Wyoming ground squirrel. This product has not been manufactured or sold in the United States 

since it was acquired by a new company, Rodent Control, Inc. There are no available 

agricultural or non-agricultural usage data for sulfonic acids and yellow mustard seed from any 

of public or proprietary databases available to the Biological and Economic Analysis Division. 

INTRODUCTION 

The Biological and Economic Analysis Division (BEAD) Chemical Profile (BCP) provides an 

overview of the pest management roles and quantitative usage information for sulfonic acids and 

yellow mustard seed. The BCP includes summaries of previous BEAD products and available 

public and/or private use and usage data for sulfonic acids and yellow mustard seed to describe 

the role of this chemical in pest management. Information provided in this BCP may be used by 

stakeholders (e.g., users and registrants), OPP risk assessors, OPP risk managers, and the general 

public during the Registration Review process of this pesticide. 

The yellow mustard seed and sulfonic acid product is a rodenticide product that is applied as a 

foam to the burrows of Richardson's and Wyoming ground squirrels, suffocating these pests. 

USE SITES 

Agricultural Use Sites 

Sulfonic acids and yellow mustard seed agricultural use sites include forest trees (nursery and 

seedbeds), and seed orchard trees (foliar treatment). 

Non-Agricultural Usage 

Non-agricultural use sites include ornamental plants (annual), ornamental turf (golf courses), 

parks, rangeland, and rights-of-way. 

FORMULATIONS AND APPLICATION METHODS 

Sulfonic acids are formulated as a soluble concentrate and yellow mustard seed is formulated as 

a powder. This product is mixed with water and then injected via an aeration nozzle as a foam 

into burrows. 

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HISTORY OF BEAD PRODUCTS 

A search of the BEAD databases for previous analyses for sulfonic acid and yellow mustard seed 

indicates that there are no records of prior BEAD benefits assessments nor emergency exemption 

requests for either of these to compounds. Note that a lack of emergency exemption requests 

does not indicate the relative importance of the chemicals. 

USAGE 

There is only one active registration (VargonTM, EPA Reg.#87972-1) with the active ingredients 

sulfonic acids ( C 14-16 alkane hydroxy and C 14-16-alkene, sodium salts) and yellow mustard 

(Brassica hirta) seed. This product is used for mechanical rodent control, specifically 

Richardson's ground squirrel and Wyoming ground squirrel. The registrant has stated that their 

primary focus is currently the Canadian market (Greenhough, 2014). They have not 

manufactured nor sold any product for the US market since transfer of ownership. They have 

been maintaining the annual registration fees as they anticipate targeting the US market in the 

next 12 months (Greenhough, 2014). 

Agricultural Usage 

There are no available usage data for yellow mustard seed or sulfonic acids from any of our 

public or proprietary databases. 

Non-Agricultural Usage 

There are no available non-agricultural data from any of our public or proprietary databases. 

BIOLOGICAL ASPECTS RELEVANT TO SULFONIC ACIDS & YELLOW MUSTARD 

SEED 

Richardson's ground squirrel [Urocitellus richardsonii, formerly Spermophilus richardsonii 

(Sabine)] and Wyoming ground squirrel (Urocitellus elegans formerly Spermophilus elegans 

Kennicott) are native rodent pests that inhabit the North American Great Plains (Helgen, et al., 

2009; Salmon & Gorenzel, 2010). The feeding habits ofthese squirrels result in direct damage 

to fruit and vegetable crops. Their burrowing and mounding habits result in soil problems, such 

as holes which are hazardous to pedestrians, livestock, and machinery; erosion; and destabilizing 

the areas beneath buildings and structures (Salmon & Gorenzel, 201 0). The product 

incorporating yellow mustard seed and sulfonic acids is used as a foam that is placed into the 

ground squirrel burrows which suffocates them. 

BEAD has no data to provide information as to the use of this compound in ground squirrel 

control. However, this product works by physically asphyxiating the pests, offering essentially a 

mechanical control method as an alternative to other rodenticide chemistries. 

Page 3 
DATA NEEDS 

The Agency does not have necessary and important information on sulfonic aCids and yellow 

mustard seed. Obtaining the following information may improve future assessments conducted 

by the Agency related to the use and importance of sulfonic acid and yellow mustard seed if the 

product is eventually registered in the United States: 

Since BEAD proprietary databases do not contain survey data on use of sulfonic acids 

and yellow mustard seed, usage data such as pounds a.i. applied,application rates, and 

number of applications in an area per year would be useful information if available. In 

addition, the number of burrows that could be treated in a day as well as the typical 

number of burrows that are usually treated per day would be helpful information. 

REFERENCES 

Greenhough, Earl. President Rodent Control Inc. May 2014. Personal Communication to 

Shirley Keel, USEP A/PRD. 

K. M. Helgen,F. R.Cole, L. E. Helgen, And D. E. Wilson. 2009. Generic revision in the 

holarctic ground squirrel genus Spermophilus. Journal ofMammalogy, 90(2):270-305. 

T. P. Salmon and W. P. Gorenzel. 2010. Ground Squirrel. Pest Notes Publication 7438. 

University of California Statewide Integrated Pest Management Program Agriculture and Natural 

Resources. Website: http:/ /www.ipm.ucdavis.edu/PMG/PESTNOTES/pn7 438.html. Accessed: 

May 6, 2014. 

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