Environmental Fate and Effects IDivision Review 

Pirimor 50-DF (Pirimicarb) 

100 Submission Pumose and Label Informmeon 

100.1 Submission Pumose and Pesticide Use 

The State of Washington is requesting an emergency exemption (Section 18) for the use 

of Pirimor to control aphids on vegetable seed crops. No new data were sub 

this request. 

100.2 Formulation Information 

ACTIVE INGREDIENT: 

Pirimicarb .................. -50% 

INERT INGREDIENTS ............... -50 % 

100.3 Avvlication Methods, Directions, Rates I 

Application is.to be made with ground or aerial equipment; according to the ~ubmission 

package, the majority of applications will be by ground. Rate is 2-6 oz. pf product 

(0.0625-0.1875 lb ai) per acre. Two applications are allowed under this 

a maximum of 6 oz per acre per year. 

100.4 Target Organisms 

Target organisms are bean aphid (Aphis fabea), green peach aphid 

turnip aphid (Hydaphis pseudobrassicae) , lettuce aphid (Acyrthosiph 

aphid (Aphis gos&ii). *i 

100.5 Precautionan Labeling 

Under Environmental Hazards 

This pesticide is toxic to birds and aquatic invei-tebrates. For 

apply directly to water, or to areas where surface water is present or to inteqtidal areas 

below the mean high water mark. Do not contaminate water when di~posing of 

equipment washwaters. Do not apply PIRIMOR 50-DF where runoff is likelt to occur. 

Under Directions for Use 

A maximum of 2 applications of PIRIMOR 50-DF may be made. Dd not apply 

more than 6 oz. PIFUMOR 50-DF per acre per season. 

Make aerial applications when the wind velocity favors on target product . 

TEXT SEARCHABLE DOCUMENT - 2010
deposition, (approximately 3-10 mph). Do not apply when wind velocity exceeds 

10 mph. 

For aerial applications, the spray boom slhould be mounted on the aircraft so as 

to minimize drift caused by wingtip or rotor vortices. Boom length must not 

exceed 75% of wing span or rotor diameter. 

Do not apply by air within 100 yards olf lakes; reservoirs; rivers;( permanent 

streams, marshes or natural ponds; estuaries and commercial fish popds. 

Ultra Low Volume (ULV) applications are prohibited. 

The largest dioplet size consistent with good pest control is required. Formation 

of very small droplets may be minimized by appropriate nozzle s d lection, by 

orienting nozzles away from the air stream as much as possible, and )y avoiding . 

excessive spray boom pressure. 

Spray should be released at the lowest height consistent with p6st control and 

flight' safety. 

To avoid risk of exposure to sensitive aquatic areas aerial applicators should avoid 

application when wind direction is toward aquatic areas. 

0 Low humidity and high temperatures increase the evaporation rate of spray 

droplets and therefore the likelihood of increased spray drift to aquatic areas. 

Avoid spraying during conditions of low liumidity and/or high temperature, 

Do not make aerial applications during temperature inversions. lnv'prsions are 

characterized by stable air and increasing temperatures with height( above the 

ground. Mist or fog may indicate the presence of an inversion in hqmid areas. 

The applicator may detect the presence of an inversion by producing ismoke and 

observing a smoke layer near the ground surface. 

Applicators and all small seeded.vegetable seed are requird to report 

EPA Headquarters, the EPA Regional Office and the State dephrtment of 

agriculture any adverse effects to birds resulting from the use of this @esticide in 

connection with the exemption and/or amendment to the exemption. 

Livestock may not be grazed in treated fields. 

All of the sm& seeded vegetable crops listed are conside&xi non-food and nonfeed sites of pesticide use, and the harvest or forage or use of any poqtion of the 

crop, seed or seed by-product'as food or feed is prohibited in ~ash4gton State 

according to Washington Administrative Code 16-228-600. , I 

. ~ 

10 1 Hazard Assessment . ' 

10 1.1 Discussion 

The state of Washington is requesting an exemption for the use of Pirimor to control 

aphids on vegetables grown for seed. Maximum application rate is 0.1875 lb qi per acre, 

with two applications allowed. Exemption period is May 1 - September 15, 1997. This 

request is for use on 10,228 acres of vegetable seed crops in all counties in Washington. 
10 1.2 Environmental Fate and Groundwater Assessme@ 

, Executive Summary and Conclusions (see Assessment below) 

The environmental fate database for the unregistered chemical pirimicarb is incomplete 

and inconclusive (see tentative fate characteristics below). However, ylnless this 

compound or its degradates exhibit very high toxicities, this specific us@ will not 

significantly impact local ecology or groundwater 

limited acreage, and l~w use rates imply that it 

in ground or surface water or actual 

will be significant in the short term. 

Assessment, below). 

any other use. However, we 

are likely to remain intact on the vegetation until time of harvest (reasons &en in Pate 

I 

~ 

At the maximum application rate of 0.188 lb a.i.lacre and for a uniform Cj-inch soil 

dispersal depth, corresponding soil concentration would be approximately 0.1 pm (parts 

per million). For the purpose of an extremely coarse screen, hypothetical P maximum 

estimates of concentrations in surface water and groundwater are as follows: ~ 

I 

Surface water: Concentration as estimated from the EFED GEFEC simula(ion model 

without allowance for any degradation or sorption to soil: 10-1 1 ppb (parts der billion) Y 

I 

Groundwater: Hypothetical maximum concentration after years of widespreap use with 

no allowance for degradation or other routes of dlissipation, no sorption to soil, and a 

groundwater recharge rate of 30 inches per year: 28 ppb. To our knowledge, this 

relative (not absolute) concentration, (based on relative use &e) in groundkate4 has never 

been exceeded by non-point source contamination caused by any pesticide 

~askd on this specific, limited use, it is unreasonable to expect that this co 

'would ever be approached in the field. I \ 

ENVIRONMENTAL FATE ASSESSMENT. ' __ -- I 

The environmental fate database for the Pnregistered chemical pirimi&b is +complete 

and inconclusive at this time, and, therefore, inadequate to support rtgistration 

(comprehensive review by D. Edelsteiq, 7 Jan 1994). Very tentatively, irimicarb P 

appears to exhibit a degree of persistence characterized by an aerobic soil etabolism "t half-life as long as 10 months (1 to +months may be more typical). Under anaerobic 

conditions the compound appears even more resistant to degradation. The+ is some 

evidence that some of the degradates also exhibit similar persistence. Pqicarb also 

appears to be mobile. The leaching potential of degradates is unknown, Based on 

persistence and mobility, there is potential for pirimicarb movement to grou 

surface water, especially in coarse, acid soils of low biological activity. 

. J summary and conclusions above)? 

7 octanol/water ratio* and aqueous solubility, bioaccumulation is not 

\ i., 

, J 

A 29 Mar 1994 memo from D. Edelstein of EFGWB makes clear that since tqe weather 
during the period of pirimicarb application will typically be very dry, little degradation 

of pirimicarb is probable. (Drought stress is the major force which spurs seed 

production rather than vegetative growth. For this reason, irrigation is alfo typically 

withheld during the summer, especially during the time of Pirimor application). For 

these reasons, Edelstein concluded it is likely that the compound will re$ain on the 

foliage, and, therefore, that HED should be informed that pirimicarb residuds are likely 

to remain intact on the vegetation until time of harvest. 

Background. "SmalLseeded" vegetable seed crops (see attached list of 27 crops) grown 

for seed in Washington State .are being seriously affected by aphids. All couhties would 

be included in this exemption. We are told that there are presently nd permitted 

satisfactory alternatives to pirimicarb. In addition, the selective pirimicarb qects only 

aphids, leaving pollinating bees and other beneficial predators and parasites !unharmed. 

It is important to note that since no part of the treated crops wjU be used tor food or 

feed, HED has classijied this use @ "non-food and non-fedfl. We note th4 the States + 

of Oregon, Idaho, Nevada, and Washington have requested Section 18s for use of 

pirimicarb on seed alfalfa in previous years. 

101.3 Likelihood of Adverse Effects on Nontarpet Or~unisms 

Terrestrial 

Data from previous EEB reviews indicate that pirimicarb is slightly toxic'to upland game 

birds (bobwhite LC50= 3415 ppm) and moderately to highly totric to ~aterfowl (mallard, 

LC50 = 740 ppm; mallard LD50 = 17.2 mglkg). 'I'he available data on rats suggest that 

the chemical is moderately toxic to mammals (lLD50 is in the range of 100 to 200 

- mglkg)?~t a ate of 0.1875 lb ailacre, the maximum estimated residuelon ternstrial food 

items (short grass) would be 45 ppm. This is well below 112 the LC50 of the most 

sensitive species (mallard), indicating We potential for acute hazard tb bGd$. 

In the absence of avian reproduction studies, EB cannot assess potedtid fbr chronic 

avian hazard. However, the following 'points should be noted: I I' I 

," ' I 

- vegetable crops are utilized by upland game birds, waterfowl, shorkbirds and 

songbirds for feeding, cover, nesting, and brood-rearing; 

- a memo from D. Edelstein to R. Forrest (D200865) concludes that little 

degradation of pirimicarb residues on foliage will occur during a typical seed 

alfalfa growing season; 

- thus, the use of pirimicarb on. seed alfalfa represents a "repeated or dontinuous 

exposure" situation for birds. 

Pirimicarb is practically nontoxic to bees and other nontarget insects. 
Aauatic 

Data from previous Em reviews-indicate that pirimicarb is slightly toxic to freshwater 

fish, with reported LC5O's ranging from 29 to 129 ppm. Daphnid studies adicate that 

pirimicarb is highly toxic to aquatic invertebrates (LC50 = 19 ppb [technical], 14 ppb 

[50 % WP]). No chronic data were available. 

Calculation of freshwater El3C (from GENFZC--see Environmental Fate and 

Groundwater section) provides a value of 10.51 ppb following application. This value 

is above the level of concern (112 of the LC50 of 14 ppb = 7 ppb) for aquatic 

invertebrates, indicating potential for acute hazard, Chronic hazard to aquatic (organisms 

cannot be evaluated, as no chronic data are availalble. 

101.3 Endangered Species Considerations 

Of the several listed species found in the subject counties, none are likely to be exposed 

to pirimicarb through its use on vegetable seed crops. Hazard to endangered species is 

not anticipated from use under the proposed exemption. 

101.4 Adeauacv of Toxicitv Data 

Available data are sufficient to assess acute hazard under the proposed S&tion 18; 

chronic data are lacking. I 

\ 

101.5 Adequacv of Labeling 

Environmental precautions labeling is adequate for this exemption. 

103 Conclusions 

,, 

EFED has reviewed the proposed emergency exemption for pirimicarb use on vegetable 

seed crops in Washington. While the environmental fate database is incompljzte at this 

time, the specialized use, limited acreage, and low use rate make it unlikely that potential 

concentrations in ground or surface water or actual concentrations in the imm&ate area 

of application will be significant in the short term. b 

Based on the ecological effects data submitted by the registrant, we concludiz that the 

proposed use does not represent acute hazard to birds. However, residues on vegetation 

are likely to remain intact until the time of harvest, making long-term and repeated 

exposure possible for birds and mammals. Since no chronic avian or ma-- data 

were available at the time of this assessment, the risk from long-term and repeated 

exposure to terrestrial wildlife cannot be evaluated. 

Aquatic toxicity values and exposure estimations do not indicate an acute hazard to 

freshwater fish. This use does exceed the LOC for aquatic invertebrates, indicating 

possible acute risk to these species; however, due to the limited acreage involved with 
this use, we do not expect it to result in significant adverse effects to freshwater aquatic 

invertebrates. Chronic risk to aquatic organisms cannot be evaluated, as chrqnic data are 

lacking. 

- 

There are no endangered species in Washington that would be adversely affwted by the 

proposed use on vegetable seed crops. 

Alex T. Clem, Environmenw Scientist 

ERB I 

EFED (75Q7C) , - 

Kathryn V. Montague, M.S., 

ERB III 

EFED (7507C) 

Daniel Rieder, Chief 

ERB m 

/ 

EFED (7507C) 
A maximum of two applications per growing season is requested. No more than 6 

ounces of Pirimor 50-DF shall be applied pe:r acre per season. - 

e) Total Number of Acres to be treated: 

All uses listed below are vegetable crops being grown for seed in Washington ad the 

acreage is based primarily on 1993 data for the listed crop from the publicatioi 

Washington Minor Crops authored by Alan Schreiber and Laura Ritchie of 

State University. 'I'here will be variations from year to year and the divulg 

acreage of some crops would be releasing proprietary information. 

Chinese Mustard Brassica campestri (Chinesis Group) 

Chinese Cabbage Brassica campestri (Pekinensis Group) - 

Broccoli Raab Brassica campestri (Ruvo Group) 

Mustard Brassica hirta, Brassica juncea 

Rutabaga Brassica napus (Napobrassica Group) 

Rape Greens Brassica napus 

Collard Brassica oleracea (Acephala Group) 

Kale Brassica oleracea (Acephala Group) 

Chinese Kale Brassica oleracea (Alboglabra Group) 

Cauliflower Brassica oleracea (Botrytis Group) 

Cabbage Brassica oleracea (Capitata Group) 

Brussels Sprouts ~rassica oleracea (Gemmifera Group) 

Kohrabi Brassica oleracea (Gongylodies Group) 

Spinach Mustard Brassica rapa (Pervirdis Group) 

Turnip Brassica rapa (Rapifera Group) 

Turnip, Fodder Brassica campestri (Rapifera Group) included above 

Turnip, Fodder Brassica septiceps 

Arugula Eruca sativa 

Radish* Rhaphanu sativus 

Swiss Chard Beta vulgaris (Cicla Group) 

Beet, Table Beta vulgaris 

Spinach Spinacia oleracea 

Endive Cichorium endiva 

Lettuce Lactuca sativa 

Coriander Coriandru sativum 

Parsnip Pastinaca sativa 

Parsley Petroselin crispum 

*Excluding daikon radish 

When a range was given for a crop the higher figure was used to more closely e7timate 

the maximum exposure relative to that crop. Total estimated 1997 acreage of nained seed 

crops in Washington is less than 80 per cent of the 10,228 acres listed above or hot more 
RUN No. 1 FOR pirimicarb INPUT VALUES .................................................................... 

RATE (#/AC) APPLICATIONS SOIL SOLUBILITY % SPRAY INCORP 

ONE (MULT ) NO.-INTERVAL KOC ( PPM )I DRIFT DEPTH (IN) ..................................................................... 

.I88 ( ,188) 1 1 .O 3000.0 5.0 . 10 

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) --------------------------------------------------------------.------- 

METABOLIC DAYS UNT~L HYDROLYSIS PHOTOLYSI[S METABOLIC COMBINED 

(FIELD) RAIN/RUNOFF (POND). (POND-EFF) (POND) (PPND) 

GENERIC EECs (IN PPB) ---------------------------------------------.----------- 

PEAK AVERAGE 4 AVERAGE 21 AVERAGE 56 

GEEC DAY GEEC DAY GEEC DAY GEEC ........................................................ 

10.56 10.55 10.54 10.51 

DO YOU WANT ANOTHER RUM (Y OR N) --- > 

RUN No. 1 FOR pirimicarb * INPUT VALUES .............................................................. 

RATE (#/AC) APPLICATIONS SOIL SOLUBILtITY % SPRAY INC 

ONE (MULT) NO. - INTERVAL KOC (PPM) DRIFT DEPT~I (IN) .................................................................... 

.188( -188) 1 1 .O 3000.0 5.0 .O 

,- 

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) .............................................................. 

METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC CO 

(FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) ( POND ) .................................................................... 

.oo 2 N/A -00- .oo .oo ******* I 

I 

GENERIC EECs (IN PPB) ........................................................ 

PEAK AVERAGE 4 AVERAGE 21 AVERAGE 56 

GEEC DAY GEEC DAY GEEC DAY GEEC 

~ I 

DO YOU WANT ANOTHER RUN (Y OR N) ---> I 

I 

I 
' / )??) , , I LL4 " A 

DP BARCODE: D235364 -7 ;GO 

&a SI i? i CASE: 288614 DATA PACKAGE RECORD DATE: 04/18/

SUBMISSION: S521151 BEAN SHEE:T Page 1 of 

CASE TYPE: EMERGENCY 'XEMP ACTION: 515 SECl8 OC N-F/F USE 

FLANKING : 0 poINfi , 

CHEMICALS: 106101 P rimicarb (ANSI) 

ID#: 97WA0022 

COMPANY / 

PRODUCT 41 ROB FORREST 703-308-8417 ROOM: CSl 6G 

: STEPHENSCHAIBLE 703-308-8337 ~OOM: CS1 6-W

DUE OUT DATE: 05/22/97 

* * * DATA PACKAGE INFORMATION * * * 

EXPEDITE: N DATE SEiNT 

irimicarb (ANSI) 

ssion Related Data Package 

LABEL: Y 

DATE OUT 

/ / 

/ / 

/ / 

ADMIN DUE 

NEGOT 

PROJ 

* * * DATA REVIEW INSTRUCTIONS * * * 

Please review this section 18 request from Washingtod to use 

pirimicarb on vegetable seed crops to control aphids. This 

is the third year this use has been requested. EFGWB waived 

data requirements for a conditional registration of this 

chemical on alfalfa seed crop. Are the conditions unQer 

which these data were waived also applicable to vegethble 

seed crops? Previous 18s have stated that given the low 

volume of product applied (maximum of 6 oz. 

product/acre/season applied to a maximum of 8,000 acrhs) , there is minimal risk of groundwater contamination If 

either of these claims are.found to be true, an abbreylated 

review would be sufficient for our purposes. If I calp be of 

help, please call. 

Steve Schaible (308-8337) 

* * * DATA PACKAGE EVALUATION * * * 

No evaluation is written for this data package 

* * * ADDITIONAL DATA PACKAGES FOR THIS SUBMISSION 

DP BC BRANCH/SECTION DATE OUT DUE BACK . INS 

235362 RCAB/PIRAT 04/18/97 05/08/97 Y 
ZENECA 

Hand Delivered 

May 10, 1995 

ZENECA Ag Products 

1800 Concord Pike 

Wilmington 

Delaware 19897 

Telephone (307) 886-1 000 

Telex 62032 1 12 

Fax (302) 886-11 553 

Mr. Robert Forrest 

Product Manager (14) 

Insecticide-Rodenticide Branch 

Registration Division (7505C) 

U. S. Environmental Protection Agency 

Crystal Mall 2 

192 1 Jefferson Davis Parkway 

Arlington, VA 22202 

Dear Mr. Forrest: 

RE: Pirimor 50DF 

EPA file symbol 10182-GTN 

(containing the active ingredient pirimicarb) 

Confirmation of Meeting May 17,1995 to Discuss the Degradation and Mobility 

of Pirimicarb in Soil and Zeneca's plans to initiate the Terrestrial Field Dissipation 

This letter is to confirm our meeting with you and representatives of the Environmental Fate & E ects 

Division. Our meeting is scheduled to be held on Wednesday May 17, 1995 at 3:00 pm in Crystal Mall 2, 

Room 709. Zeneca will have four (4) attendees: 

K - - Sandy O'Bryan - Regulatory Product Manager $pirimicarbyj 

Jim Wagner - Regulatory Product Manager '----- A "" 

Colleen Spurgeon - Field Study Manager 

Ian Hill - Research Associate & Senior Team Leader in Soil Metabolism (Jealott's Hill Research Station) 

We expect the meeting to be no longer than one (1) hour. I attached an agenda for your convenieqce. If 

you require additional information, please call me at (302) 886-8789. 

Sincerely, 

i 

, Saundra M. O'Bryan 

Regulatory Product Manager u 
Meeting: May 17,1995 

PIRIMICARB Degradation & Mobility in Soil 

Request the Agency Guidance - 

Regarding Plans for Terrestrial Field Dissipation 

Crystal Mall 2 

Room 709 

AGENDA: 

Meeting to beGn 3:00 pm 

S. 0 'Brvan (5 minutes) 

Introductions 

Review of Current Regulatory Status & Intended Uses of Pirinnor 50DF 

I. Hill (30 minutes) 

a. Prediction of Pirimicarb Degradation in Soil 

+ potential routes 

+ likely products 

b. Laboratory Data 

+ rate of degradation 

+ route of degradation 

+ bound residues 

+ mobility in soil 

d. Zeneca Proposal for Further Work - field dissipation 

All (25 minutes) 

e. Discussion 

3 Agency Guidance on Soil dissipation 

3 Laboratory Data in Support of Registration 

Adjourn: 4:00 pm