BIOPESTICIDES REGISTRATION ACTION DOCUMENT

Trichoderma asperellum strain T34

Pesticide Chemical (PC) Code: 119209

U.S. Environmental Protection Agency

Office of Pesticide Programs

Biopesticides and Pollution Prevention Division

October 14, 2011
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Biopesticides Registration Action Document

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY ................................................................................................ 4

II. ACTIVE INGREDIENT OVERVIEW............................................................................. 5

III. REGULATORY BACKGROUND..................................................................................... 5

A. Applications for Pesticide Registration .................................................................................................5

B. Food Tolerance Exemption .....................................................................................................................5

IV. RISK ASSESSMENT .......................................................................................................... 5

A. Product Analysis Assessment (40 CFR § 158.2120)..............................................................................6

B. Human Health Assessment (40 CFR § 158.2140)..................................................................................6

C. Environmental Assessment (40 CFR § 158.2150) ...............................................................................10

V. ENVIRONMENTAL JUSTICE .......................................................................................... 12

VI. RISK MANAGEMENT DECISION................................................................................ 13

VII. ACTIONS REQUIRED BY THE APPLICANT ............................................................ 13

A. Final Printed Labeling ..........................................................................................................................13

B. Terms of Registration............................................................................................................................13

C. Reporting of Adverse Effects and Hypersensitivity Incidents...........................................................14

VIII. GLOSSARY OF ACRONYMS AND ABBREVIATIONS........................................... 15

IX. BIBLIOGRAPHY................................................................................................................ 16

A. Studies Submitted to Support Pesticide Product Registrations.........................................................16

B. Environmental Protection Agency Risk Assessment Memoranda.....................................................20

APPENDIX A. MICROBIAL PESTICIDES DATA REQUIREMENTS............................ 21

APPENDIX B. PESTICIDE PRODUCT................................................................................. 26
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BIOPESTICIDES REGISTRATION ACTION DOCUMENT TEAM

Office of Pesticide Programs (OPP)

Biopesticides and Pollution Prevention Division

Microbial Pesticides Branch

Science Reviews

John L. Kough, Ph.D.

Ibrahim S. Barsoum, Ph.D.

Shannon Borges

Zigfridas Vaituzis

Product Characterization and Human Health 

Assessment 

Product Characterization and Human Health 

Assessment 

Environmental Effects Assessment

Environmental Effects Assessment

Regulations

Sheryl K. Reilly, Ph.D.

Anna Gross

Matthew Thompson

Chief, Microbial Pesticides Branch

Regulatory Action Leader

Regulatory Action Leader

Michael Glikes Regulatory Action Leader
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I. EXECUTIVE SUMMAR

Trichoderma asperellum strain T34 is a naturally occurring fungus that increases plant 

defenses against Fusarium oxysporum, a pathogenic, soil-born fungus of significant 

economic importance in the United States. When Trichoderma asperellum strain T34 

(“T34”), is preventatively applied, it protects plants from this disease-causing organism by

initially colonizing the roots and building a physical barrier against pathogens. T34 induces 

the synthesis of defense proteins in the plant, which increases the plants’ resistance to 

infection by Fusarium oxysporum. T34 also has the ability to parasitize and kill the plant 

pathogen. Biocontrol Technologies, S.L. (“applicant”) has proposed to register an end-use 

microbial pesticide product, T34 Biocontrol (EPA File Symbol 87301-R), containing T34 as 

the active ingredient. The proposed product is intended for use in greenhouses to control 

Fusarium oxysporum on nonfood crops, specifically, carnations. 

Environmental Protection Agency (“EPA” or “Agency”) scientists have reviewed product 

analysis, toxicology, and nontarget organism data (reference 40 Code of Federal Regulations 

(CFR) §§ 158.2120, 158.2140, and 158.2150, respectively), and other information submitted 

by the applicant to support the registration. The submitted data and information fulfill the

current data requirements and demonstrate that the proposed greenhouse use of T34 will not 

generally cause unreasonable adverse effects on the environment, in accordance with the 

requirements for pesticide registration under Section 3(c)(5) of the Federal Insecticide, 

Fungicide, and Rodenticide Act (FIFRA).

On October 1, 2009, EPA announced a new policy to provide a more meaningful opportunity

for the public to participate in major registration decisions before they occur. According to 

this policy, EPA intends to provide a public comment period prior to making a registration 

decision for, at minimum, the following types of applications: new active ingredients; first 

food uses; first outdoor uses; first residential uses; or any other registration actions for which 

EPA believes there may be significant public interest.

 

Consistent with the policy of making registration actions more transparent, the proposed 

pesticide products containing T34 as a new active ingredient were subject to a 30-day

comment period. The docket identification number, associated with these registration actions

and accessed through either http://www.regulations.gov/ or 

http://www.epa.gov/pesticides/regulating/registration-status.html, is EPA-HQ-OPP-2010-

0247. The following documents were made available for comment in EPA-HQ-OPP-2010-

0058: (1) draft Trichoderma asperellum strain T34 Biopesticides Registration Action 

Document (BRAD); (2) environmental risk assessment for T34; and (3) draft product label 

for the end-use product, T-34 Biocontrol (EPA File Symbol 87301-R). While a final decision 

on registration is contingent upon review and consideration of public comments, EPA 

presently believes that, based upon the risk assessment and information submitted in support 

of T-34 Biocontrol, it is in the best interest of the public and the environment to issue these 

registrations. The basis for this decision can be found in the risk assessment for T34, which is 

characterized throughout this BRAD. 
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II. ACTIVE INGREDIENT OVERVIEW

Biological Name: Trichoderma asperellum strain T34

Product Name: T-34 Biocontrol

Culture Deposit: Spanish Collection of Type Cultures, University of 

Valencia in Valencia, Spain under CECT No. 20417.

OPP Chemical Code: 119209

Type of Pesticide: Microbial Pesticide – Fungicide

See Appendix B for specific information (e.g., use sites, 

application rates, methods of application, formulation 

types, and target pests) regarding the registered 

pesticide products containing this active ingredient.

III. REGULATORY BACKGROUND

A. Applications for Pesticide Registration

On December 31, 2009, Wagner Regulatory Associates, Inc. (address: P.O. Box 640, 7460 

Lancaster Pike, Suite #9, Hockessin, DE 19707-0640) on behalf of Biocontrol Technologies, 

S.L. (address: 08028 Barcelona, Spain, C/ Baldiri Reixac, 15-21), submitted applications to 

register an end-use product (EP) T34 BIOCONTROL (EPA Reg. No. 87301-R) containing a 

new TGAI Trichoderma asperellum strain T34 (“T34”), under section 3(c)(5) of FIFRA. On 

November 24, 2010, EPA announced receipt of these applications to register pesticide 

products containing a new active ingredient (75 Federal Register (FR) 71697) and opened a 

30-day public comment period pursuant to the provisions of FIFRA section 3(c)(4). No 

comments were received following this publication. 

B. Food Tolerance Exemption

No tolerance or exemption from the requirement of a tolerance is associated with or required 

for this regulatory action as only nonfood uses are currently proposed for T34. Accordingly, 

this action is outside the scope of the Food Quality Protection Act (FQPA). There are no 

CODEX maximum residue levels established for T34.

IV. RISK ASSESSMENT

In the Federal Register of October 26, 2007, EPA issued a Final Rule on the data 

requirements to support registration of microbial pesticides and updated the definition for 

microbial pesticides (72 FR 61002). The rule became effective on December 26, 2007. The 

data and information evaluated for this BRAD were considered in light of these requirements.

The classifications for each data submission are assigned by EPA science reviewers, and are 

an indication of the usefulness of the information contained in the documents for risk 
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assessment. A rating of “ACCEPTABLE” indicates the study is scientifically sound and is 

useful for risk assessment. A “SUPPLEMENTAL” rating indicates the data provide some 

information that can be useful for risk assessment. The studies may have certain aspects 

determined not to be scientifically acceptable (“SUPPLEMENTAL: UPGRADEABLE”). If a 

study is rated as “SUPPLEMENTAL: UPGRADEABLE,” EPA always provides an 

indication of what is lacking or what can be provided to change the rating to 

“ACCEPTABLE.” If there is simply a “SUPPLEMENTAL” rating, the reviewer will often 

state that the study is not required by 40 CFR Part 158. Both “ACCEPTABLE” and 

“SUPPLEMENTAL” studies may be used in the risk assessment process as appropriate. An 

“UNACCEPTABLE” rating indicates that new data need to be submitted.

For the acute toxicity data requirements, Toxicity Categories are assigned based on the 

hazard(s) identified from studies and/or other information submitted to EPA in support of a 

pesticide registration. The active ingredient or particular product is classified into Toxicity

Category I, II, III, or IV, where Toxicity Category I indicates the highest toxicity and Toxicity

Category IV indicates the lowest toxicity. 

A. Product Analysis Assessment (40 CFR § 158.2120)

All product analysis data requirements for T34, have been fulfilled. Refer to Table 1 in 

Appendix A for a brief summary of the data requirements, including both generic and 

product-specific information.

B. Human Health Assessment (40 CFR § 158.2140)

1. Toxicity

All toxicology data requirements for T34, have been fulfilled. Acceptable Tier I mammalian 

toxicology data and information support registration of the T34 pesticide products. 

Furthermore, Tier II and Tier III studies were not required for T34, based on the lack of acute 

toxicity/pathogenicity in the Tier I studies.

For a comprehensive summary of the generic toxicology data requirements described in 

sections IV(B)(1)(a) and IV(B)(1)(b), as well as additional product-specific data submitted to 

support the individual registrations, refer to Table 3 Appendix A.

a. Acute Toxicity/Pathogenicity – Tier I

Acute Oral Toxicity/Pathogenicity (Office of Chemical Safety and Pollution Prevention 

(OCSPP) Guideline 885.3050; Master Record Identification Number (MRID No.) 48067401 

and 48067403): In an acute oral toxicity study (MRID 48067401), groups of fasted, 8-12 

week old HsdRccHan:32 WIST rats (3/sex) were given a single oral dose of T34 (Batch No. 

5170708;11.71% T-334, 1.8 x 109/g), at a concentration of 0.1 g in 1.5 mL water per animal 

(~108cfu/animal).The animals were observed up to 21 days with interim sacrifices on Days 

3, 7, and 14. Two untreated males and 2 females were housed together with the treated 

animals as shelf controls, and two untreated animals were housed separately from the test 

groups as room controls. 
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There were no treatment related clinical signs, necropsy findings, or significant changes in 

body weight. The clearance of T34 from the feces was established by day 19, and no viable 

counts were noted from any organ of animals sacrificed on day 21. No viable counts were 

noted in the organ samples of untreated shelf control animals.

Based on the results of this study, T34 does not appear to be infective and/or pathogenic in

HsdRccHan: 32 WIST rats, when dosed at 1.1 x 108cfu/animal. Toxicity has been observed 

in the pancreas and adrenal glands of treated animals at necropsy. This study satisfies the

requirement for an acute oral toxicity and pathogenicity study, and is classified as 

ACCEPTABLE.

Acute Pulmonary Toxicity/Pathogenicity (OCSPP Guideline 885.3150; MRID No. 47946906 

and 48067404): In an acute pulmonary toxicity and pathogenicity study (MRID 

No.47946906), groups of 8-12 week old HsdRccHan: 44 WIST rats (3 or 5/sex) received 

intratracheal treatment with T34 (Batch No. 5170708; 11.71% T-334, 1.8 x 109/g). The 

animals were observed for up to 21 days. Five males and five females served as untreated 

controls.

Following instillation of 0.2 mL test substance, one male and one female died immediately

and one male and two females died approximately 10 minutes thereafter. Thereafter, the 

instillation volume was decreased to 0.1mL. One female was found dead 2.5 hours after test 

material instillation but all other animals survived to scheduled sacrifice. No clinical signs 

were observed in surviving animals. Body weight gain of the treated animals was slightly

lower than that in the control group. Slight effects on lungs, pancreas, liver, thymus, adrenal 

glands, and/or spleen in treated animals were noted at necropsy. No grossly observable 

pathological changes were found in control animals. The test material showed slight toxic 

effects but did not proliferate in the treated animals following a single intratracheal 

instillation. Nevertheless, the organism could be detected in selected tissue samples, 

particularly the lung, until day 21 of the study. 

Based on these results, T34 appears to be slightly toxic but not infective and/or pathogenic in 

rats. 

The dose the animals received may be less than that suggested by guideline requirements. 

The study report states the test material (1.8 x 109cfu/g) was diluted 1:10 (~1.8 x 108

cfu/mL) and the animals received 0.1 mL (~1.8 x 107cfu/animal). This study satisfies the 

acute pulmonary toxicity and pathogenicity guideline requirement and is classified as 

ACCEPTABLE. 

Acute Injection Toxicity/Pathogenicity (Intravenous) – Rat (OCSPP Guideline 885.3200; 

MRID No. 47946903 and 48067406): In an acute intravenous injection toxicity and 

pathogenicity study (MRID No. 47946903), three male and three female young adult 8-12 

week old HsdRccHan:10 WIST rats were injected IP with T34 (Batch No. 5170708;11.71% 

T-334, 1.8 x 109/g), at a dose of 0.1 g/animal, at a dose volume of a 1 mL suspension. The 

test material was suspended in water prior to use. Two males and two females not treated 

served as controls. Surviving animals were observed for up to 21 days.

All treated animals died or were euthanized within 19-52 hours of test material injection. 
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Before death, the animals had reduced spontaneous activity, apathy, sunken flanks and ruffled 

fur. All control animals survived, gained weight, and had no clinical symptoms during the 

study. All decedents had an accumulation of fluid in the peritoneum and stomach, brightened 

fringes of the liver, and slightly reddish and swollen pancreas. The control animals had no 

gross pathological changes at necropsy. 

The test for enumeration of the test organisms in tissues and feces of treated animals were 

validated in MRID 48067406.

Based on the results of this study, T34 showed toxic characteristics in rats following a single 

intrapertioneal injection administration of 0.1 g/animal; however, infectivity and 

pathogenicity were not addressed. Oral and pulmonary studies have shown that the test 

organism does appear infective or to be a pathogen. 

The Agency requested further testing of the spores vs. the filtrate to elucidate the mortality

and pancreatic toxicity observed in the acute toxicity/pathogenicity studies. Specifically, 

further testing will determine if the presence of the toxins is the cause of the observed 

mortality and pancreatic toxicity in the treated animals. 

The applicant responded to the Agency request noting: The high mortality observed in the 

rats from the study “Acute Injection Toxicity/Pathogenicity with Biocontrol Technologies, 

S.L., T34” (dosed at 1 x 108cfu/rat) was not due to the production of toxins by T34, but 

rather to the high concentration of spores injected intrapertioneally to the rats. This 

conclusion is based on:

1. New GLP studies conducted to find the test dose that causes moderate but 

non-lethal symptoms in rats, and a new acute toxicity/pathogenicity study with 

T34 (MRID 48348306, 48348307).

2. No toxins have been detected in T34 compared with other Trichoderma 

species that do produce toxins (MRID 48377002).

Hypersensitivity Incidents (OCSPP Guideline 885.3400; MRID No. 47945023): No 

hypersensitivity incidents, including immediate-type or delayed-type reactions of humans and 

domestic animals that occurred during research, development, or testing of T34, were 

reported by the applicant. Any future hypersensitivity incidents must be reported per OCSPP 

Guideline 885.3400.

Cell Culture (OCSPP Guideline 885.3500): This study is not required because T34 is not a 

virus (refer to test note #4 of 40 CFR § 158.2140(d)).

b. Acute Toxicology and Subchronic Toxicity/Pathogenicity – Tier II;

 Reproductive Fertility Effects, Carcinogenicity, Immunotoxicity, and 

 Infectivity/Pathogenicity Analysis – Tier III

Tier II and Tier III studies were not required for T34, based on the lack of acute 

toxicity/pathogenicity in the Tier I studies.
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c. Endocrine Disruptors

As required under FFDCA section 408(p), EPA has developed the Endocrine Disruptor 

Screening Program (EDSP) to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a “naturally occurring estrogen, or other such endocrine effects as the 

Administrator may designate.” The EDSP employs a two-tiered approach to making the 

statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to 

identify the potential of a chemical substance to interact with the estrogen, androgen, or 

thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and are 

found to have the potential to interact with E, A, or T hormonal systems will proceed to the 

next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests are 

necessary based on the available data. Tier 2 testing is designed to identify any adverse 

endocrine-related effects caused by the substance, and establish a quantitative relationship 

between the dose and the E, A, or T effect.

Between October 2009 and February 2010, EPA issued test orders/data call-ins for the first 

group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. 

This list of chemicals was selected based on the potential for human exposure through 

pathways such as food and water, residential activity, and certain post-application agricultural 

scenarios. This list should not be construed as a list of known or likely endocrine disruptors.

T34 is not among the group of 58 pesticide active ingredients on the initial list to be screened 

under the EDSP. Under FFDCA section 408(p), EPA must screen all pesticide chemicals. 

Accordingly, EPA anticipates issuing future EDSP orders/data call-ins for all pesticide active 

ingredients. 

For further information on the status of the EDSP, the policies and procedures, the list of 67 

chemicals, the test guidelines and the Tier 1 screening battery, please visit our website: 

http://www.epa.gov/endo/.

2. Food Quality Protection Act (FQPA) Considerations

Although no tolerance or exemption from the requirement of a tolerance is associated with or 

required for this regulatory action as only nonfood uses are currently proposed for T34, the 

applicant submitted waiver requests for Residue Chemistry Guidelines OCSPP 885.2100, 

885.2200, 885.2250, 885.2500, 885.2550, and 885.2600.

The following points were made to support the waivers for Residue Chemistry requirements: 

(1) the proposed use pattern for T34 Biocontrol EP is limited to closed greenhouse systems 

on nonfood crops, specifically, carnations; (2) T34 occurs naturally in soil. It can grow only

in soil, under specific conditions (high soil organic matter content, humidity, and 

temperatures <35OC); (3) the T34 mode of action is to protect roots by inducing the plant’s 

own enzyme production to stimulate growth and biological control of plant disease; (4) T34 

does not produce any known toxins. No T2 toxin (trichodermin; harzianum A) was found in a 

sample of 0.25 g of the EP that was sonicated, extracted with ethyl acetate, and the 

supernatant evaluated by mass spectroscopy, and (5) T34 is not hazardous to humans, based 

on acute oral, pulmonary, and intravenous toxicity studies conducted in rats. Rats treated with
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5.5 x 105to 108units/animal had color changes in unspecified organs, but these effects were 

not sufficient to classify T34 as toxic. It was determined that the provided rationale was 

adequate to justify a waiver for the requested Residue Chemistry Guidelines. 

3. Occupational Exposure and Risk Characterization

Handler exposure to T34 is not expected to pose any undue risk. Regardless, appropriate 

personal protective equipment and precautionary statements are required on pesticide product 

labels to mitigate any potential risks to pesticide handlers due to prolonged or numerous

exposures. Handlers applying T34 end-use products in commercial and agricultural settings 

must wear a long-sleeved shirt, long pants, and shoes plus socks. Additional PPE, other than 

the standard described above, may be required on a product-specific basis.

4. Human Health Risk Characterization

The Agency considered human exposure to T34 in light of the standard for registration in 

FIFRA and the relevant safety factors in FFDCA. A determination has been made that T34

has no known potential to cause adverse human health effects or to produce a mammalian 

toxin, and that residues are not likely to be present in or on food when used in accordance 

with EPA-approved labeling.

C. Environmental Assessment (40 CFR § 158.2150)

The data and data waiver rationale, submitted by the applicant to support the pesticide 

products containing T34, are sufficient to fulfill the Tier I nontarget organism data 

requirements and for risk assessment purposes. Further testing of nontarget organisms at 

higher tier levels (i.e., Tiers II, III, and IV) is not required for the current uses and application 

methods. EPA has performed an environmental risk assessment based on the data and data 

waiver rationale provided by the applicant and has determined that the proposed use of T34

does not pose significant risk to nontarget organisms when used according to label directions. 

For a comprehensive summary of the generic data requirements described in sections 

IV(C)(1), refer to Table 4 in Appendix A.

1. Ecological Exposure and Risk Characterization 

a. Terrestrial Animals and Plants

The proposed registration limits use to indoor environments within greenhouses and the 

proposed maximum application use rates result in concentrations that are not above measured 

concentrations of Trichoderma spp. naturally occurring in soil. Therefore, exposure in the 

terrestrial environment is expected to be negligible, if it occurs at all. 

The applicant submitted data waiver rationales to fulfill the requirement of acute oral and 

avian inhalation toxicity/pathogenicity studies. Data from an optimum growth temperature 

study was also submitted, and showed that T34 does not grow at normal avian body

temperatures. Based on this information, exposure of birds to T34 is not expected to result in 

adverse effects on birds and risk to birds resulting from the proposed use of T34 is not 
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anticipated.

Acute oral toxicity/pathogenicity testing indicated no significant adverse effects to laboratory

rats dosed at 1.1 x 108cfu/animal after 21 days (MRID 48067401). There is no reason that 

tests on laboratory mammals are not representative of the potential hazard to wild mammals 

in this case; therefore, based on this information, adverse effects on wild mammals are not 

expected from exposure to T34. Since the proposed use is also expected to minimize 

exposure, risk to wild mammals resulting from the proposed registration of T34 is not 

anticipated.

The applicant submitted information on the toxicity/pathogenicity data for several insect 

species exposed to Trichoderma harzianum (the former classification of some strains of 

Trichoderma asperellum) and Trichoderma gamsii. While these data cannot be used directly

to determine the potential hazard of this particular strain of Trichoderma asperellum, they do 

provide some evidence of the lack of effects of Trichoderma spp. on insects. The Agency had

previously expressed concern over the potential hazard of Trichoderma harzianum, strain 

T39 (USEPA 2000), and several papers have shown adverse effects of this related fungus on 

nontarget insects, particularly coleopteran species (Cardoza et al., 2006; Jassim et al., 1990;

Shakeri and Foster 2006). Nontarget insect testing has not been performed for T34 because 

nontarget insects’ exposure to this strain is not expected. Future expansion of the uses of T34

may require nontarget insect toxicity/pathogenicity testing.

As with other nontarget insects, the Agency had previously expressed concerns for potential 

effects on honey bees for a related Trichoderma spp., Trichoderma harzianum strain T39 

(USEPA 2000); however, data were subsequently submitted to show that adverse effects are 

not expected from exposure to that strain. Trichoderma spp. are widely understood to present 

no potential adverse effects to honey bees, which is supported by data submitted by the 

applicant showing lack of effects of honey bees and bumble bees (Bombus terrestris) 

following exposure to several Trichoderma spp. Therefore, BPPD concluded that T34 will 

not pose risk to honey bees as a result of the proposed labeled uses.

Studies on the toxicity/pathogenicity of T34 to terrestrial plants were not required because 

Trichoderma asperellum, and other Trichoderma spp., are not taxonomically related to any

known plant pathogens. Therefore, adverse effects to plants are not expected as a result of the 

proposed uses of T34.

b. Aquatic Animals and Plants

The applicant presented extensive rationale to show that exposure of T34 in aquatic 

environments would be negligible, if it occurred at all, and would have no effects on fish or 

aquatic invertebrates if this biopesticide were to reach surface waters. Data from a study was 

submitted to show that at four months after the last application of T34 to potted plants, 

leachate from the pots contains 102cfu/mL of T34, which is less than the amount of 

Trichoderma spp. found naturally in soil. Therefore, spillage onto greenhouse soil and 

outdoor disposal of treated potting material would not increase the amount of Trichoderma

spp. normally found in soil or in runoff. Incidents such as these are expected to have 

negligible contribution to exposure. The applicant presented additional data from public 

literature to show that if T34 were to reach surface waters, it would be unable to proliferate 
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and would be unlikely to survive. Based on the information provided, exposure to aquatic 

environments is expected to be negligible and adverse effects in these environments are not 

expected. Therefore, BPPD concludes that the proposed use of T34 will not result in risk of 

adverse effects to fish and aquatic invertebrates in freshwater and marine environments. 

Studies on the toxicity/pathogenicity of T34 to aquatic plants were not required because 

Trichoderma asperellum and other Trichoderma spp. are not taxonomically related to any

known plant pathogens and exposure in these environments is not expected. Therefore, 

adverse effects to aquatic plants are not expected as a result of the proposed uses of T34.

c. Open Literature Information

Literature searches were performed to determine if other effects have been reported that were 

not contained within the information provided by the applicant. Both the Science Citation 

Index Expanded database (1970-present) and the Environmental Information Search service 

(1964-present) were searched using the terms “Trichoderma asperellum,” “Trichoderma

asperellum strain T34,” and “asperellum strain T34.” The Environmental Information Search

service includes the Agricola; Biosis Previews; CAB Abstracts; Energy, Science, and 

Technology; General Science Abstracts; National Technical Information Service; and 

Waternet databases. None of the records found in any of the searches described here reported 

effects on any non-target species. 

2. Environmental Fate Data 

The information provided, for the current uses and application methods is sufficient to satisfy

the Tier I nontarget organism data requirements, and for conducting a nontarget organism risk 

assessment for T34, further testing at higher tier levels (i.e., Tiers II, III, and IV) is not 

required. 

3. Threatened and Endangered Species Assessment

Since EPA has determined that no effects are anticipated for any nontarget species exposed to

T34 as a result of the proposed labeled applications, effects to threatened and endangered 

species and their designated critical habitats also are not expected. Therefore, a “No Effect” 

determination was made for direct and indirect effects to listed species and their designated 

critical habitats resulting from the registered uses of T34.

V. ENVIRONMENTAL JUSTICE

EPA seeks to achieve environmental justice—the fair treatment and meaningful involvement 

of all people regardless of race, color, national origin, or income—with respect to the 

development, implementation, and enforcement of environmental laws, regulations, and 

policies. Fair treatment means that no group of people, including racial, ethnic, or 

socioeconomic groups, should bear a disproportionate share of the negative environmental 

consequences resulting from industrial, municipal, and commercial operations or the 

execution of federal, state, local, and tribal environmental programs and policies. Meaningful 

involvement means that (1) potentially affected community residents have an appropriate 

opportunity to participate in decisions about a proposed activity that will affect their 
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environment and/or health; (2) the public’s contribution can influence the regulatory agency’s 

decision; (3) the concerns of all participants involved will be considered in the decisionmaking process; and (4) the decision-makers seek out and facilitate the involvement of those 

potentially affected. EPA has this goal for all communities and persons across the United 

States. 

To help address potential environmental justice issues, EPA seeks information on any groups 

or segments of the population who, as a result their location, cultural practices, or other 

factors, may have atypical, unusually high exposure to T34 compared to the general 

population. During the comment period, the Agency solicited comments from the public on 

any subpopulations that may have atypical, unusually high exposure compared to the general 

population.

For additional information regarding environmental justice issues, please visit EPA’s web 

site at http://www.epa.gov/compliance/environmentaljustice/index.html.

VI.RISK MANAGEMENT DECISION

Section 3(c)(5) of FIFRA provides for the registration of new active ingredients if it is 

determined that (A) its composition is such as to warrant the proposed claims for it; (B) its 

labeling and other materials required to be submitted comply with the requirements of 

FIFRA; (C) it will perform its intended function without unreasonable adverse effects on the 

environment; and (D) when used in accordance with widespread and commonly recognized 

practice it will not generally cause unreasonable adverse effects on the environment. 

The four criteria of the eligibility determination for pesticidal active ingredients were 

satisfied by the science assessments supporting products containing T34. Such products are 

not expected to cause unreasonable adverse effects and are likely to provide protection as 

claimed when used according to label instructions. Therefore, we have concluded that T34 is 

eligible for registration for the labeled uses. 

VII. ACTIONS REQUIRED BY THE APPLICANT

A. Final Printed Labeling

Before releasing pesticide products containing T34 for shipment, the applicant will be

required to provide appropriate final printed labeling to EPA.

B. Terms of Registration

We propose the following as terms for the T34 Biocontrol registration: the applicant must 

submit the following data upon completion:

(1) Acute Injection Toxicity/Pathogenicity – Rat (OCSPP Guideline 885.3200): Due to 

the results of a previous IP toxicity study and the high potential of toxicity of the 

product, a new toxicity/pathogenicity study, using a lower concentration of the TGAI, 

was performed and has been accepted by the Agency. Another IP injection study

addressing concern relating to culture filtrates and killed cultures is in process and 
Trichoderma asperellum, strain T34 Page 14 of 26

Biopesticides Registration Action Document

will be submitted to the UK and the EU. US EPA also expects to receive this study

upon completion.

C. Reporting of Adverse Effects and Hypersensitivity Incidents

Notwithstanding the information stated in the previous sections, it should be clearly

understood that certain, specific data are required to be reported to EPA as a requirement for 

maintaining the federal registration for a pesticide product. A brief summary of these types of 

data are described below.

Reports of all incidents of adverse effects to the environment must be submitted to EPA

under the provisions stated in FIFRA section 6(a)(2). Additionally, all incidents of 

hypersensitivity (including both suspected and confirmed incidents) must be reported to EPA

under the provisions of 40 CFR § 158.2140(d).
Trichoderma asperellum, strain T34 Page 15 of 26

Biopesticides Registration Action Document

VIII. GLOSSARY OF ACRONYMS AND ABBREVIATIONS

BPPD Biopesticides and Pollution Prevention Division

BRAD Biopesticides Registration Action Document

CFR Code of Federal Regulations

cfu Colony-forming unit(s)

cfu/kg Colony-forming units per kilogram

cfu/mL Colony-forming units per milliliter

cP Centipoise

EDSP Endocrine Disruptor Screening Program

EP End-use product

EPA Environmental Protection Agency (the “Agency”)

FFDCA Federal Food, Drug, and Cosmetic Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FQPA Food Quality Protection Act

FR Federal Register

g/mL Gram per milliliter

LC50

Median lethal concentration. A statistically derived concentration of a substance 

that can be expected to cause death in 50% of test animals. It is usually expressed 

as the weight of substance per weight or volume of water, air, or feed (e.g., mg/L, 

mg/kg, or ppm).

LD50

Median lethal dose. A statistically derived single dose that can be expected to 

cause death in 50% of the test animals when administered by the route indicated 

(oral, dermal, or inhalation). It is expressed as a weight of substance per unit 

weight of animal (e.g., mg/kg).

mg/kg Milligrams per kilogram

mg/L Milligrams per liter

MP Manufacturing-use product

MPCA Microbial Pesticide Control Agent

MPCP Microbial Pesticide Control Product

MRID No. Master Record Identification Number

NIOSH National Institute for Occupational Safety and Health

NRRL Northern Regional Research Laboratory

OCSPP Office of Chemical Safety and Pollution Prevention (formerly OPPTS).

OPP Office of Pesticide Programs

PC Code Pesticide Chemical Code

PP Pesticide Petition

PPE Personal protective equipment

ppm Parts per million

TGAI Technical grade of the active ingredient
Trichoderma asperellum, strain T34 Page 16 of 26

Biopesticides Registration Action Document

IX. BIBLIOGRAPHY

A. Studies Submitted to Support the T34 Pesticide Product Registrations

47946901 Schropp P. 2007. Acute Dermal Irritation/Corrosion. Project No. 070961. 

Unpublished study prepared by Biocontrol Technologies, S.L., 22 pages.

47946902 Schropp P. 2007. Acute Oral Toxicity Acute Toxic Class Method. Project No. 

070963. Unpublished study prepared by Biocontrol Technologies, S.L., 21 

pages.

47946903 Schropp P. 2007. Acute Injection Toxicity/Pathogenicity. Project No. 070966. 

Unpublished study prepared by Biocontrol Technologies, S.L., 23 pages.

47946904 Schropp P. 2007. Test for Sensitization (Guinea Pig Maximasation Test). 

Project No. 070965. Unpublished study prepared byBiocontrol Technologies, 

S.L., 33 pages.

47946905 Schropp P. 2007. Acute Eye Irritation/Corrosion. Project No. 070962. 

Unpublished study prepared by Biocontrol Technologies, S.L., 26 pages.

47946906 Schropp P. 2007. Acute Pulmonary Toxicity/Pathogenicity. Project No. 

070969. Unpublished study prepared by Biocontrol Technologies, S.L., 27 

pages.

47946907 Schropp P. 2007. Acute Dermal Toxicity. Project No. 070964. Unpublished 

study prepared by Biocontrol Technologies, S.L., 21 pages.

47946907 Schropp P. 2007. Acute Oral Toxicity/Pathogenicity. Project No. 070967. 

Unpublished study prepared by Biocontrol Technologies, S.L., 42 pages.

47946908 Lowe, C. 2007. Acute Inhalation Toxicity Study in Rats- Limit Test. 

Unpublished study prepared by Biocontrol Technologies, S.L., 20 pages.

47946909 Biocontrol Technologies, S.L. 2009. Microbial Pesticides Residue Data 

Requirements: Rationale and Request for Waivers of Certain Data. 

Unpublished study prepared by Biocontrol Technologies, S.L., 10 pages.

47946911 Byrd, C. 2009. Product Chemistry Data Waivers. Unpublished study prepared 

by Biocontrol Technologies, S.L., 4 pages.

47946912 Trillas, Dr. I. 2009. Molecular Classification. Unpublished study prepared by

Biocontrol Technologies, S.L., 9 pages.

47946913 Trillas, Dr. I. 2007. Morphological Classification of the Biological Control 

Agent. Unpublished study prepared by Biocontrol Technologies, S.L., 28 

pages.
Trichoderma asperellum, strain T34 Page 17 of 26

Biopesticides Registration Action Document

47946914 Trillas, Dr. I. 2008. Specific Detection. Unpublished study prepared by

Biocontrol Technologies, S.L., 25 pages.

47946915 Trillas, Dr. I. 2008. Specific PCR Fingerprinting. Unpublished study prepared 

by Biocontrol Technologies, S.L., 17 pages.

47946916 Biocontrol Technologies, S.L. 2008. Identity. Unpublished study prepared by

Biocontrol Technologies, S.L., 28 pages.

47946917 Samuels, Dr. G, Segarra G. 2007. Document on the Classification of 

Trichoderma asperellum. Unpublished study prepared by Biocontrol 

Technologies, S.L., 8 pages.

47946918 Fytovita S. 2008. Manufacturing Process. Unpublished study prepared by

Biocontrol Technologies, S.L., 35 pages.

47946919 Biocontrol Technologies, S.L. 2008. Protocol to Monitor the Levels of 

Contaminating Microorganisms in the Formulated Microbial Pest Control 

Product. Unpublished study prepared by Biocontrol Technologies, S.L., 4 

pages.

47946920 Fytovita S. 2008. Method to Control Impurities, Study of Contaminants in 

Broth, Study of Contaminants in Formulated Product, Quality Control of 

Formulated Product. Unpublished study prepared byBiocontrol Technologies, 

S.L., 16 pages.

47946921 Trillas, Dr. I. 2007. Identification of Contaminant Microorganisms in the 

Active Substance and the Formulated Microbial Pest Control Product. 

Unpublished study prepared by Biocontrol Technologies, S.L., 6 pages.

47946923 Guerrero, M. 2007. Determination of the Active Components of Different 

Batches of the Microbial Pest Control Agent. Unpublished study prepared by

Biocontrol Technologies, S.L., 5 pages.

47946924 Trillas, Dr. I. 2008. Storage Stability and Shelf Life of the MPCP at 36oC, 

37oC, 38oC, 39oC, 40oC, 45oC, and 50oC. Unpublished study prepared by

Biocontrol Technologies, S.L., 15 pages.

47946925 Trillas, Dr. I. 2008. Study of Storage Stability and Shelf Life of MPCA from 

Different Batches at 4

oC and 25oC. Unpublished study prepared byBiocontrol 

Technologies, S.L., 16 pages.

47946926 Trillas, Dr. I. 2008. Study of Storage Stability and Shelf Life of MPCP from 

Different Batches at 4

oC and 25oC. Unpublished study prepared byBiocontrol 

Technologies, S.L., 19 pages.

47946927 Cassals, Dr. I. 2007. Study of pH. Unpublished study prepared by Biocontrol 

Technologies, S.L., 12 pages.
Trichoderma asperellum, strain T34 Page 18 of 26

Biopesticides Registration Action Document

47964922 Guerrero, M. 2007. Determination of the Active Components of Different 

Batches of the Microbial Pest Control Product. Unpublished study prepared by

Biocontrol Technologies, S.L., 6 pages.

48067402 Hoppner, Dr. C. 2007. Determination of the microbial count of a powdery

formulation of conidia. Project No. 071324. Unpublished study prepared by

Biocontrol Technologies, S.L., 35 pages. 

48067403 Hoppner, Dr. C. 2007. Determination of the microbial count. Project No. 

071405. Unpublished study prepared by Biocontrol Technologies, S.L., 44 

pages. 

48067404 Hoppner, Dr. C. 2007. Determination of the microbial count. Project No. 

071406. Unpublished study prepared by Biocontrol Technologies, S.L., 39 

pages. 

48067405 Hoppner, Dr. C. 2007. Determination of the microbial count of a powdery

formulation of conidia. Project No. 071325. Unpublished study prepared by

Biocontrol Technologies, S.L., 35 pages. 

48067406 Hoppner, Dr. C. 2007. Validation of the determination of the microbial count 

in tissue- and feces samples. Project No. 071327. Unpublished study prepared 

by Biocontrol Technologies, S.L., 37 pages. 

48348303 Biocontrol Technologies, S.L. 2011. Discussion of Formation of Unintentional 

Ingredients, Microbiological Analysis Results. Unpublished study prepared by

Biocontrol Technologies, S.L., 5 pages.

48348304 Trillas, Dr. I. 2011. Study of Storage Stability and Shelf Life of MPCP from 

Different Batches at 4

oC and 25oC. Unpublished study prepared byBiocontrol 

Technologies, S.L., 24 pages.

48348305 Trillas, Dr. I. 2011. Study of the Tap Density. Unpublished study prepared by

Biocontrol Technologies, S.L., 7 pages.

48348306 Allingham, Dr. P. 2010. Intrapertioneal Dose Range Finding Study in Rats. 

Study No. 101684. Unpublished study prepared by Biocontrol Technologies, 

S.L., 22 pages.

48348307 Allingham, Dr. P. 2010. Acute Injection Toxicity/Pathogenicity Study. 

Unpublished study prepared by Biocontrol Technologies, S.L., 112 pages.

48377001 Biocontrol Technologies, S.L. 2011. Response to the US EPA Deficiency

Letter of 17th December 2010. Unpublished study prepared by Biocontrol 

Technologies, S.L., 17 pages.

48377002 Biocontrol Technologies, S.L. 2011. Production of Trichotecene. Unpublished 

study prepared by Biocontrol Technologies, S.L., 39 pages.
Trichoderma asperellum, strain T34 Page 19 of 26

Biopesticides Registration Action Document
Trichoderma asperellum, strain T34 Page 20 of 26

Biopesticides Registration Action Document

B. Environmental Protection Agency Risk Assessment Memoranda

U.S. EPA. 2010a. Environmental Risk Assessment for a FIFRA Section 3 Registration for T34 

for Control of Fungal Root Disease in Ornamental and Carnation Plants in Greenhouse 

[EPA File No. 87301-R]; Decision # 425700, DP Barcode # 373656, Submission # 

865549, Memorandum from S. Borges and Z. Vaituzis to A. Gross, dated September 22, 

2010.

U.S. EPA. 2010b. Review of Product Chemistry, Manufacturing Process, Acute Toxicity

Studies, and Waiver Requests for Residue Chemistry Studies, for Section 3 registration 

of a New End Use Product, T34 BIOCONTROL (EPA Reg. No. 87301-R) containing a 

new TGAI Trichoderma asperellum, strain T34, Memorandum from I. Barsoum and J. 

Kough to A. Gross, dated November 23, 2010

U.S. EPA. 2011. Review of the Applicant’s Response to the Deficiencies Found by the Agency

in its Review of Product Chemistry, Manufacturing Process, and Acute Toxicity Studies 

of the Product T-34 Biocontrol containing the AI T34(EPA Reg. No. 87301-R), 

Memorandum from I. Barsoum and J. Kough to A. Gross, dated June 16, 2011. 
Trichoderma asperellum, strain T34 Page 21 of 26

Biopesticides Registration Action Document

APPENDIX A. MICROBIAL PESTICIDES DATA REQUIREMENTS

(40 CFR PART 158 – SUBPART V)

TABLE 1. Product Analysis Data Requirements for the Technical Grade of the Active Ingredient (TGAI) T34 & EndUse Product (EP) T34 Biocontrol, (EPA Reg. No. 87301-R) (40 CFR § 158.2120)

OCSPP 

Guideline 

Number 

Data Requirement

Results

MRID No.

TGAI/MPCA EP/MPCP

885.1100 Product Identity Not applicable. Submitted data fulfill the 

requirement for product 

identity. T34 Biocontrol

contains 12.00% active 

ingredient T34, 88.00% other 

ingredients. 

479461127

885.1200 Manufacturing Process Submitted data fulfill the requirement for manufacturing 

process.

479461127

Not applicable Deposition of a Sample 

in a Nationally 

Recognized Culture 

Collection

T34 is deposited in the 

Spanish Collection of Type 

Cultures, University of 

Valencia in Valencia Spain

(CECT No. 20417).

Not applicable. 47946917

885.1300 Discussion of Formation 

of Unintentional 

Ingredients

Submitted data fulfill the requirement for discussion of 

formation of unintentional ingredients.

479461127

885.1400 Analysis of Samples Submitted data fulfill the requirement for analysis of samples. 479461127

885.1500 Certification of Limits Not applicable. Limits listed on the 

confidential statement of 

formula are acceptable.

479461127

Additional Studies

830.1800 Enforcement Analytical 

Method

Not applicable. Submitted data fulfill the 

requirement for an 

enforcement analytical 

method.

479461127
Trichoderma asperellum, strain T34 Page 22 of 26

Biopesticides Registration Action Document

TABLE 2. Physical and Chemical Characteristics for the Technical Grade of the Active Ingredient (TGAI) T34 & 

End-Use Product (EP) T34 Biocontrol, (EPA Reg. No. 87301-R) (40 CFR § 158.2120)

OCSPP 

Guideline 

Number 

Data Requirement

Results

MRID No.

TGAI/MPCA EP/MPCP

830.6302 Color Colorless (transparent or 

translucent), green or 

brown.

Not applicable. 47946913

830.6303 Physical State Solid (Colony) Not applicable. 47946913

830.6304 Odor Decaying wood or 

forest-like.

Not applicable. 47946913

830.6313 Stability to Normal and 

Elevated

Temperatures, Metals,

and Metal Ions

Viability was maintained

for 14 days at 36-40OC, 

but viability decreased 

at 45OC after 5 days, and 

all colonies died after 3 

days at 50OC. Stability 

to metals is not relevant 

as the product will not 

be packaged in metal 

containers (waiver 

requested).

Not applicable. 47946911

47946924

47946925

47946926

830.6317 Storage Stability Stable at 4OC for 2 years and at 25OC for <5 months. 47946925-26

483483-04

830.6319 Miscibility Not applicable. Not required because T34 

Biocontrol is not an emulsifiable

liquid to be mixed with 

petroleum solvents (refer to test 

note #10 of 40 CFR § 

158.2120(d)).

Not applicable

830.6320 Corrosion

Characteristics

Not applicable. Data Waiver Request; EP has no 

oxidizing properties, inters are 

noncorrosive, and packaging not 

exposed to metal, metal ions or

humidity.

Not applicable

830.7000 pH 5.95 (1% suspension of 

TGAI in water)

Not applicable. 47946927

47946916

CSF

830.7100 Viscosity Not applicable. Data not required, the material is 

a powder.

47946911

830.7300 Density/Relative 

Density/Bulk Density 

(Specific Gravity)

200-600kg/m3at 20OC 

per the MSDS

CSF lists 200 kg/m3at 

20OC

Not applicable. 47946911

47946918

CSF
Trichoderma asperellum, strain T34 Page 23 of 26

Biopesticides Registration Action Document

TABLE 3. Toxicology Data Requirements for the Technical Grade of the Active Ingredient (TGAI) T34 & End-Use 

Product (EP) T34 Biocontrol, (EPA Reg. No. 87301-R) (40 CFR § 158.2140)

OCSPP 

Guideline 

Number

Data Requirement Results MRID No.

TGAI/MPCA EP/MPCP

Tier I

885.3050 Acute Oral 

Toxicity/Pathogenicity

T34 does not appear to be 

toxic, infective, and/or 

pathogenic to rats when 

dosed at 1.1 x 108cfu/animal

Classification: Acceptable

Not applicable 48067401

48067403

885.3150 Acute Pulmonary 

Toxicity/Pathogenicity

T34 appears to be slightly 

toxic but not infective and/or 

pathogenic in rats when 

dosed at 1.1 x 108cfu/animal

Classification: Acceptable

Not applicable 47946906

48067404

885.3200 Acute Injection 

Toxicity/Pathogenicity 

(Intravenous)

T34 is associated with mild 

to moderate signs of toxicity 

but no mortality when dosed 

with 4.2 x 107cfu/animal

Classification: Acceptable

Not applicable 47946903

48067406

483483-07

885.3400 Hypersensitivity 

Incidents

No hypersensitivity incidents, including immediate-type or 

delayed-type reactions of humans and domestic animals that 

occurred during research, development, or testing of the 

TGAI/MP, were reported by the applicant. Any future 

hypersensitivity incidents must be reported per OCSPP 

Guideline 885.3400. 

885.3500 Cell Culture Not required because T34 is 

not a virus (refer to test note 

#4 of 40 CFR § 

158.2140(d)).

Not applicable Not 

applicable 

870.1100 Acute Oral Toxicity Not applicable Oral LD50 female rats > 2,000 

mg/kg bw.

Classification: Acceptable

TOXICITY CATEGORY III

47946902

870.1200 Acute Dermal Toxicity Not applicable Dermal LD50 combined (male 

and female) rabbits > 2,000

mg/kg bw.

Classification: Acceptable

TOXICITY CATEGORY III

47946907

870.1300 Acute Inhalation 

Toxicity

Not applicable Inhalation LC50 combined 

(male and female) rats > 2.03

mg/L.

Classification: Acceptable

TOXICITY CATEGORY IV

47946908

870.2400 Acute Eye Irritation Not applicable T34 was mildly irritating to the 

eyes of rabbits.

Classification: Acceptable

TOXICITY CATEGORY III

47946905

870.2500 Primary Dermal 

Irritation

Not applicable T34 was not to the skin of 

rabbits.

Classification: Acceptable

TOXICITY CATEGORY IV

47946901

Tiers II and III

Not required for T34, based on the lack of acute toxicity/pathogenicity in the Tier I studies.

Additional Studies
Trichoderma asperellum, strain T34 Page 24 of 26

Biopesticides Registration Action Document

TABLE 3. Toxicology Data Requirements for the Technical Grade of the Active Ingredient (TGAI) T34 & End-Use 

Product (EP) T34 Biocontrol, (EPA Reg. No. 87301-R) (40 CFR § 158.2140)

OCSPP 

Guideline 

Number

Data Requirement Results MRID No.

TGAI/MPCA EP/MPCP

870.2600 Skin Sensitization T34 was a dermal sensitizer to guinea pigs. Classification: 

Acceptable

47946904

Not applicable Production of Toxins If any trichodermin is produced by T34, the amounts are 

smaller compared to known producer strains and no toxicity is 

expected.

Classification: Supplemental – Not a required study

48377002
Trichoderma asperellum, strain T34 Page 25 of 26

Biopesticides Registration Action Document

TABLE 4. Nontarget Organism Toxicity and Environmental Fate Data Requirements for the Technical Grade of the 

Active Ingredient (TGAI) T34 & End-Use Product (EP) T34 Biocontrol, (EPA Reg. No. 87301-R) (40 CFR § 158.2150)

OCSPP Guideline 

Number

Data Requirement Results MRID No.

Tier I

885.4050

885.4200

885.4240

885.4280

885.4340

885.4380

 Avian Oral 

toxicity/pathogenicity

 Freshwater fish 

toxicity/pathogenicity

 Freshwater invertebrate 

toxicity/pathogenicity

 Estuarine/marine fish and 

invertebrate testing

 Nontarget insect testing

 Honey bee testing

Data waiver rationale provides sufficient 

information to determine that 

toxicity/pathogenicity to avian wildlife, wild 

mammals, freshwater and marine/estuarine fish 

and invertebrates, nontarget insects and honey 

bees is not expected as a result of the proposed 

label. Classification: Acceptable

47068102

885.4150 Wild Mammal 

Toxicity/Pathogenicity

Studies required by 40 CFR § 158.2140 are 

adequate and appropriate for assessment of 

hazards to wild mammals. Acute oral 

toxicity/pathogenicity testing indicated no 

significant adverse effects to laboratory rats dosed 

at 1.1 x 108cfu/animal after 21 days.

Classification: Acceptable for wild mammal 

risk assessment

47945023

885.4100

885.4300

 Avian Inhalation 

Toxicity/Pathogenicity

 Nontarget plant testing

Not required- active ingredient is not related to 

known avian or plant pathogens.

N/A

Tiers II, III, and IV

Not required for T34, based on the current uses and application methods.
Trichoderma asperellum, strain T34 Page 26 of 26

Biopesticides Registration Action Document

APPENDIX B. PESTICIDE PRODUCT

EPA File Symbol Registration 

Name

Percentage 

Active 

Ingredient

Formulation 

Type

Use Site(s) Method(s) of 

Application

Application 

Rate

Target Pest

87301-R T34 

Biocontrol

12.00% End UsePowderGreenhouse 

Carnations

Standard 

ground spray, 

root soak, or 

irrigation

Maximum of 

10g/L

Fusarium 

oxysporum