UNITED STATES ENVIRONMENTAL PROTE C TION AGENCY WASHING TON , D

. C. 20460 

### AUG 18 

### 201 5

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

MEM O RANDUM

SUBJE C T: BEAD Chem ica l Pro fil e (BCP) for Registration Rev iew: Tebuconazo le (128997)
F ROM :

T HRU: Tara Chandgoyal , Ph

.D

. , P lant Pathologist Biological Analysis B ranch
Don Atwood , Ph.D. , Entomologist Science Information and Analysi s Branch Andrew Lee, Economist Eco nomic Analys is B ranc h

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Biological and Eco nomic Analysis Division (7503P) Arnet Jone s, Chief Biological Analysis Br Diann Sims, Chief 

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. Science Information and Analysis Branch Timothy Kie ly , Chief 

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# CJ Economic Analysis Branch Bio logical and Economic Analysis Division (7503P) TO : Jose Gayoso , Chemical Rev iew Manager Kevin Costell o, Chief Risk Management and Imp lementat ion Branch II Pesticide Re

- evaluation D iv ision (7508P)

Peer Review Panel date: August 5 , 2015

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### SUMMARY Tebuconazole is a systemic fungic ide with protective, curative, and erad icant properties. These antifungal properties result in fungal disease co ntrol on various crops (barley , wheat, p eanuts, and many others). Tebuconazole belongs to gro up 3 ofFRAC classification of fungicides (FRAC, 20 1 5)

. There is medium risk of developing resistance in fungal p lant patho gens against tebuconazole (FRAC , 2015). According to avail able proprietary information, the highes t u sage of tebuconazole , in terms of total pounds applied, was in Georgia and North Dakota. Tebuconazole use has generally been increasing s ince 2008, both in terms of pounds used and ac res treated. Thi s may be due to increased disease pressure of fo li ar and seed-borne disease s on diff erent crops. INTRODUCTION
The Bio logical and Economic AnaJysis Division (BEAD) Chemical Profil e (BC P) provides an overview of the pest management roles and quant itative usage information for tebuconazole. The BCP includes availab le public and/or p rivate u se and usage data for tebuconazole and a ge neral discussion of biological aspects , intended to de scri be the role of this c hemical in pest management. Additional information on use i s available in the Tebucon azo le Label Data Report provided in the public docket for this c hemical. Info rmation provided in this BEAD Chemical Profile (BCP) may be used by stakeholders (e.g

. , u sers and re g istrants) , Office of Pesticide Programs (OPP) risk and benefit assessors , and OPP risk managers , and the general public during the Registration Review process of thi s pesticide. AGRICULTURAL USE SITES
Tebuconazo le i s re g i stered for use on asparagus , barley, beans, bean s (dried

- type), beets , brassica (head and stem vegetables), bulb vegetables , field com, popcorn , sweet com, cotton , c ucurbit vegetables , fruiting vegetables (except okra), garli c, grapes, hop s, leek , oats , okra , dry bulb onions, green o ni ons, peanuts, pome fruits , rye , shallo t, soybeans , stone fruits , subtrop ical/tropical fruit , sunflower, tree nuts , turnip , and wheat. NON-AGRICULTURAL USE SITES
Non

- agric ultu ral use s ites which are lab eled for tebuconazole application include industrial adhesives, industrial coat ings , golf course turf , grasses grown for seed, metalworking cutting fluids , ornamenta l s (grasses, trees, shrubs, vines , and flowering plant s), plastic , specialty industrial products, and wood protection treatments. FORMULATIONS AND APPLICATION METHODS
Tebuconazole is formulated as a granul ar, pelleted/tableted , wettable powder, water dispersible granu les , emulsifiable concentrate, flowable concentrate, so luble concentrate , and solution

- ready to use (RTU). Application may be made u si ng e ither ground or air equipment and as a seed treatment.

Page 2 of 9HISTORY OF BEAD ASSESSMENTS FOR TEBUCONAZOLE There are no benefits assessments or recent Section 18 Emergency Exemption Requests for tebuconazole in the BEAD official record database. An emergency exemption may indicate that there is a need for a particular chemical that is not registered for use on a particular site. An emergency exemption request may yield information about a particular chemical's importance or value that is not found in other EPA records. However, a lack of Section 18 assessments by BEAD does not specifically indicate the relative importance of the chemical. TEBUCONAZOLE USAGE Agricultural Usage Usage of tebuconazole and number of acres treated was re latively stable from 1998 to 2008. Since 2008, there has been a significant increase in both total area treated and pounds a.i. applied. The increase in pounds a.i. applied and acreage treated was 

### 40% and 

### 71 %, respectively

. This increase after 2008 reflects tebuconazole usage as a seed treatment for wheat.

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### ~ 18,000,000

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- •- Pounds Al Applied

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Figure 1. National Tebuconazole Usage (Pounds A.I. and Total Area Treated) from 1998 to 2013.

. Source: Proprietary Data, 1998

- 2013 A review oftotal tebuconazole usage data for the last 4 years indicates that the primary use sites are peanuts and wheat, accounting for approximately 87% ofpounds applied and 79% of total acres treated (Table 1 ). Average tebuconazole application rates range from 0.032 to 0.189 lb a.i. per acre for the major use sites in the United States. Highest average application rate across all registered use sites is 0.251 lb a.i. per acre for sugar beets but only reflects a minor use site with

Page 

### 3 of9application of less than 500 lbs and 2,000 acres annually. Lowest average application rate across all registered crops i s 0.032 lb a.i. per acre for winter wheat and reflects seed treatment tebuconazole application.

Peanuts Spring Wheat 219 Winter Wheat 192 Soybeans 23 Wine Grapes 21 Pecans 15 42 24 21 3 2 2 2 0 10 -2 01 3. % 

### ofTotal Tebuconazo le 

### Treated Acres

14 37 41 2 Avg AI 

### Rate

0.189 0.041 0.032 0.108 0.106 0.118 *Total Acres Treated s um s all ac res treated for a crop , includin g those acres that rece ive multip le treatments. So ur ce: Proprietary D a ta , 20 I 0

-20I 3 In contrast to the u sage data shown in Table 1 , crops with highest tebuconaz ole u sage in terms of Percent Crop Treated (PCT) as determined by the Screening Level Usage Analysis (SLUA) (BEAD, 2015) , are garlic, peanuts, cherries , grapes, watermelon , wheat (seed treatment), peaches, and nectarines (Table 2). No other crop exceed an average 5 PCT. Nevertheless , the SLUA data does indicate that tebuconazo le has important usage on crops other than those with greatest pounds applied.
Treated \Vith Teb u conazo le. Maximum Garlic 95 Peanuts 45 55 Cherries 30 45 Grapes 25 35 Watermelon 15 30 Wheat (seed treatment 15 20 Peache s 10 25 Nectarines 

### IO 20 Source: BEAD 2015 S LUA

Table 3 indicate s the states with a i;ninimum of five percent usage of tebuconazole in terms of total tebuconzaole pounds a.i. applied in the United States. Georgia and North Dakota account for 4 3 percent of total pounds of tebuconazole applied and 33 percent of total acres treated with tebuconazole. Of states with hi ghest tebuconazole usage , Florida has the highe st application rate (0.185 pounds a.i. per acre) and Texas the lowest (0.037 pounds ai per acre).

Page 4 of9Georgia 227 North Dakota 164 Florida 68 Alabama 59 Minnesota 55

Kansas 47 Texas 45 Cali fornia 44 25 18 7 6 344 6 974 5 1 ,080 5 1 ,2 1 9 5 490 9 24 3 2 7 7 8 3 

### Avg 

### Al Rate

0.171 0.047 0.185 0.174 0.057 0.044 0.037 0.092 *Total Acres Treated sums all acres treated fo r a crop , including tho se acres that receive multiple treatments. Sour ce: Pr o prie t01y Data , 2010-2013 According to proprietary data, total acres treated with tebuconazole are evenly split between seed treatment and foliar application (Tab le 4). Seed treatment accounts for approximately I percent of tebuconazole pounds applied but 50 percent of total acres treated. Ground app li cat i on (broadcast , banded , and spot treatment only) represent s 80 percent of total tebuconazole pounds app lied and 3 8 percent of total acres treated. Aerial application accounts for 

### 19 percent of total tebuconazole pounds applied and 1 2 percent of total acres treated.

Ground (broadcast , banded , and s ot treatment Aerial Seed treament 745
175

7 80
19 0.8 5,583 38
1 , 705 12 7 ,280 50 *Total Acres Treated sums all acres treated for a crop, including those acres that receive multiple treatments. S o ur ce: Pr opri e ta ry Data , 2010-2013 Geographic Distribution of Tebuconazo le Use Tebuconazo le ha s widespread reported usage in the United States (Figure 3). States with highest pounds used per 1 , 000 crop acres grown include Georgia , South Carolina, Alabama , and Florida. The greatest us e in the Southeastern U

. S. is primar il y related to peanut production which has a high percent crop treated and a relatively high application rate , both of which contribute to a high intensity of u se relative to cropped acres. Tebuconazo le usage in the central U.S. largely reflects usage on wheat and the lower application rate associated with see d treatment. Usage in California and Michigan reflect usage on wine grapes and cherries , respectively.

Page 5 of9Pounds Active I ngredient per 1,000 Crop Acres Grown 0No0ata LJ <1 1 -9 -10

- 15

- >15 

### Figure 2. Annual average agricultural use intensity of tebuconazole (2008-2012). Source: Proprietary Data, 2008-20 I2 Please refer to Appendix A (below) for additional details on the scope and context of this map. 

### Non-Agricultural Usage According to the most recent data available, tebuconazole usage in the Professional Ornamental and Turf market and Consumer market was 38,000 pounds and 10 , 000 lbs, respectively , in 2011 (Proprietary Data , 2012). 

### BIOLOGICAL ASPECTS RELEVANT TO TEBUCONAZOLE Tebuconazole inhibits sterol demethylation in fungi , causing fungal cell wall collapse and inhibition of hyphal growth. Tebuconazole is a systemic fungicide with protective , curative, and eradicant properties. These antifungal properties result in fungal disease control on various crops. Tebuconazole belongs to fungicide group 3 (SBI: Class I, such as fenbuconazole , myclobutanil, propiconazole, prothioconazole, tetraconazole and some others) of FRAC classification of fungicides (FRAC, 2015). There is medium risk of developing resistance in fungal plant pathogens against tebuconazole (FRAC , 2015). Tebuconazole can be used as a stand-alone

Page 6 of9fungicide or in combination/alternation with fungicides with different modes of action (such as azoxystrobin , pyraclostrobin). Since 2008 its use has increased as resu lt of use as a seed treatment on wheat. We do not know the reasons for its sudden increase since 2008. ROLE OF TEBUCONAZOLE IN PEST MANAGEMENT Tebuconazole is predominantly used on peanuts and wheat. Highest percent of total pounds applied was in Georgia followed by North Dakota. In Georgia it is mainly used on peanuts and in North Dakota it is used on wheat to control fungal pests. It can be applied alone or in combination with other fungicides (such as azoxystrobin, pyraclostrobin). On peanuts , it is labeled for controlling soil-borne (Sclerotinia stem and pod rot, Rhizoctonia limb rot and pod rot) and foliar (early leaf spot , late leaf spot , leaf rust, web blotch and pepper spot) fungal diseases. High percent crop treated suggests that there may be limited options and relatively high benefits of tebuconazole use on peanuts. On wheat , it is labeled for controlling leaf rusts and stem rust caused by Puccinia spp., head blight or scab caused by Fusarium spp. The percentage of the wheat crop treated with tebuconazole is not as high as peanuts. This may be because propiconazole and prothioconazole are also used on wheat to control Fusarium head blight , a dominant fungal disease of wheat.

. Highest percent of crop treated with tebuconazole was garlic followed by peanuts , cherries and grapes suggesting high benefits of using tebuconazole on these crops . On garlic , rust disease can cause crop failure and tebuconazole is highly effective in controlling the disease (Koike et al ., 2001 ). On peanuts, tebuconazole is used to control leaf spot disease and soil

-borne diseases (white mold and Rhizoctonia limb rot) (Kemerait et al ., 2008). On cherries, tebuconazo le is used to control leaf spot and powdery mildew diseases (anonymous, 2013 ; Jones et al. , 1993) and on grapes, tebuconazole controls powdery mildew disease. INFORMATION THAT MAY BE USEFUL FOR B EAD'S FUTURE WORK ON TEBUCONAZOLE The Agency currently does not have important non-agricultural information on tebuconazo le. Obtaining the following information for all registered non- agricultural sites may improve future assessments conducted by the Agency re lated to the use and importance of tebuconazole.

• Total pounds active**in~edient** applied • Percent crop/site treated • Application rates: typical and maximum • Frequency of application • Application Intervals • Methods of application • Target or niche pests • Efficacy information/product performance
In addition , obtaining the following usage information may improve future assessments conducted by the Agency related to the use and importance of tebuconazole in agricultural settings: 1) Typical application timing in each registered crop.
Page 7 of92) If more than one appl ic ation is typicall y m ade, the typical re - applicatio n interval (per crop). 3) Recent resistance reports for tebucon azo le in populations of imp ortant target pests , in particular cases of cross-resistance to other fungicides.
REFERENCES Anonymous. 2013. https: //das.wsu.edu/news/ storv/ 2013 /04/0 1/Powdery Mildew of C herry New Fungicide Tool and Re sistan ce Management Guidelines. Accessed o n A ugust I 0 , 2015.
BEAD

. 2015. Screening L eve l Usage Analy s i s (SLUA) for Tebuconazo le. (Acc ess ible in the tebuconazole registration review docket at www.regulations.gov]. FRAC. 20 1 5. http ://www.frac.i nfo/do cs/defau lt-so urce /publicati o ns /frac-co de -li st/frac

- code-list 2015-finalC2AD7AA36764.pdf?sfvrsn=4. Accessed on J ul y 25 , 20 1 5
Jones , AL. , Ehre t, GR. , Garcc i a, SM. 1 993. Co ntrol of cherry leaf spot and powdery mildew on sour cherry with alternate-side application of fenar i no l , myclobutani l and tebuconazole. Plant Disease 77:703-706. Kamerait, BK. , Brennem an , T., Culbreath , A. 2008. The University of Georgia, College of Agriculture and Env ironmental Sciences. 2008 Peanut Update. http: //www.caes.uga.edu/commoditie s/fi e ldcrops/peanuts/2008peanutupdate/d iseases.html Koike , S.T., Smith , R.F

. , Davis , R.M. , N unez , J.J. , Voss , R.E. 2001. Rust co nti nu es to threaten California garli c crop. Ca lifornia Agriculture (Sep tember- Octob er, 200 1 ): 35-39. Proprietary D a ta. 1998 -2013. Data on u se co ll ec t ed nationall y from farme rs by a private marketing firm u sing statistically valid s urvey methods. Proprietary Data

. 2008-2012. Data on use co ll ecte d nationally from farmers by a private marketing firm u sing statistically valid survey methods.
Prop ri etary Data

. 2010-20 1 3. D ata on use collected nationally from farmers by a private marketing firm us ing statist ica ll y valid survey methods. Proprietary Data. 20 12. Data collected nation all y fo r non-agricultural u se by a private marketing firm u s in g s tatistically valid survey method s. Schilder, A. 2012. Fungicide update for grapes. http: //grapes .ms u. edu/uploads/files/Newsletters/20 1 2/Apri lFun gicide update for grapes 20 1

_ 2.pdf. Accesse d August 1 0, 2015.

APPENDIX A

Page 8 of 9The map included herein is primarily for the use of the risk assessors in the Environmental Fate and Effects Division. The map provides a very broad geographical view of the average annual amount (in pounds) of the active ingredient applied per 1 , 000 acres of crop acres grown. These data are included in the maps because risk assessors are interested in the amount of a pesticide used across agricultural land. The calculated values presented in the map are not equivalent to an application rate (lb ail A). The data used to make these maps have several limitations. Any interpretation of the maps should consider the underlying data and the associated limitations carefully. The numerator (annual average pounds applied) is based on private market surveys of pesticide use in agriculture averaged over the last five years (Proprietary Data, 2008-2012). These surveys cover about 60 crops and are targeted in states that produce the majority of the crop. Although the surveys capture most of the use of a particular active ingredient in agriculture , there are several limitations to these surveys.

• States with minor production of a surveyed crop are not sampled • Not all types of pesticides are surveyed in every crop in every year • Many specialty crops with very small acreages are not included in the survey The result of these limitations is that states that show no usage may actually have a small amount of the active ingredient being used. In some cases the displayed use intensity may be distorted because the surveyed crops and the reported pesticide usage may not accurately represent the actual pesticide usage on the crops produced in the state

. The denominator (1 , 000 crop acres grown) was also obtained from the same private market survey database. The " Crop Acres Grown " variable represents the total acres grown in a given state of all of the surveyed crops. This value is independent ofpesticide usage and pesticide registration. It is important to note that the surveyed crops (about 60) are sampled from states that are major producers of each crop. Therefore, there are cases where the actual crop acreage in a state is higher than that reported by crop acres grown in the survey because either that state and/or crop was not included in the survey. The reader should pay particular attention to the figure legends and realize that a map prepared for a particular chemical is not directly comparable to a map prepared for a different chemical as the legend bins will likely be**diffe~ent.**

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