Page
1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
Date:
February
5,
2002
SUBJECT:
BEAD's
Impact
Analysis
of
the
Seed
Treatment
Uses
of
Lindane
on
Wheat,
Barley,
Oats,
Rye,
Corn,
Sorghum,
and
Canola
FROM:
David
W.
Brassard,
Senior
Entomologist
Herbicide
and
Insecticide
Branch
Istanbul
Yusuf,
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(7503C)

THRU:
Arnet
Jones,
Chief
Herbicide
and
Insecticide
Branch
Arthur
Grube,
Senior
Economist
David
Widawsky,
Chief
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(7503C)

TO:
Mark
Howard,
Chemical
Review
Manager
Betty
Shackleford,
Chief
Reregistration
Branch
III
Special
Review
and
Reregistration
Division
(7508C)

Peer
Review
Date:
January
16,
2002
SUMMARY
In
response
to
a
request
for
SRRD,
BEAD
conducted
an
impact
analysis
of
the
seed
treatment
uses
of
lindane
on
wheat,
barley,
oats,
rye,
corn,
sorghum,
and
canola.
Lindane
seed
treatments
are
applied
to
9.
7
million
acres
of
small
grains,
corn,
and
sorghum
annually.
Imidacloprid
and
thiamethoxam,
the
primary
seed
treatment
alternatives
to
lindane,
are
as
effective
as
lindane
but
are
costlier
to
use.
There
are
no
registered
alternatives
to
lindane
for
oats
and
rye.
Grower
level
impacts
of
cancellation
of
lindane
seed
treatments
would
be
minor
for
all
uses,
except
oats
and
rye
where
they
are
considered
major
due
to
an
estimated
9
percent
yield
loss
Page
2
without
registered
alternatives.
Treatment
cost
increases,
associated
with
the
alternatives
for
the
remaining
crops
average
$1.45
per
acre
(or
0.8%
of
gross
revenues).
The
total
aggregate
increase
in
treatment
costs
is
$14
million.
Total
aggregate
value
of
yield
loss
(on
oats
and
rye)
is
$354,000
(Tables
1
and
3).

Lindane
is
not
currently
registered
on
canola
but
the
registrant
is
seeking
registration.
The
currently
registered
alternatives
are
equally
effective
for
wireworm
control
and
more
effective
for
flea
beetle
control
but
are
costlier
to
apply.
The
registration
of
lindane
would
result
in
an
average
cost
savings
to
growers
of
$1.83
per
acre
(2%
of
gross
revenues)
which
BEAD
considers
to
be
a
minor
gain.

GENERAL
BACKGROUND
ON
LINDANE
SEED
TREATMENTS
Approximately
142,000
pounds
of
lindane
are
applied
annually
to
9.7
million
acres
of
small
grains,
corn,
and
sorghum.
Lindane
is
applied
at
an
average
application
rate
of
0.
0147
pounds
active
ingredient
per
acre.
The
vast
majority
(98%)
of
lindane
seed
treatments
are
incorporated
into
the
seed
on
farm;
very
little
is
incorporated
into
the
seed
by
seed
processors.
Lindane
is
marketed
as
a
seed
treatment
under
trade
names
such
as
Agrox
Premiere®,
Germate
Plus®,
Isotox
F®,
and
Kernel
Guard®.
Lindane
treated
seed
is
applied
at
planting
time
mainly
for
wireworm
control.
Lindane
is
relatively
ineffective
against
seed
corn
maggot,
seed
corn
beetle,
and
white
grubs
(Brassard
and
Grube,
1996).
On
corn,
lindane
is
frequently
formulated
with
diazinon
to
control
these
other
insect
pests
and
with
fungicides
(e.
g.
captan,
carboxin,
and
maneb)
to
control
seedling
fungal
diseases.
On
small
grains
lindane
is
frequently
formulated
with
maneb,
but
is
rarely
formulated
with
diazinon.
Lindane
seed
treatments
are
also
applied
for
fire
ant
control
on
sorghum
and
the
registrant
has
petitioned
the
Agency
for
registration
on
canola
for
flea
beetle
and
wireworm
control.

Wireworm
damage
to
small
grains,
corn
and
sorghum
is
largely
a
problem
in
the
northern
wheat­
growing
areas
west
of
the
Mississippi
River.
Wireworms
require
from
3
to
5
years
to
complete
their
growth
and
are
most
common
in
muck
and
other
loose­
textured
soils
that
were
planted
to
grain
crops
in
previous
years.
Wireworms
attack
the
seeds
and
the
portion
of
the
stem
below
ground,
often
damaging
or
killing
the
growing
point.
Infested
fields
usually
have
spotty
stands
with
significant
reductions
in
plant
population
in
some
areas.
BEAD's
review
of
available
data
shows
that
untreated
plots
may
experience
yield
losses
of
0
to
18
percent
relative
to
lindane
treated
plots.

This
analysis
estimates
the
economic
impacts
of
cancellation
of
lindane
quantitatively
(revenue
losses
or
cost
increases
in
US
dollars)
and
qualitatively
(in
terms
of
the
effects
of
projected
impacts
on
grower
net
revenues).
The
criteria
for
qualitative
impact
characterizations
(minor:
0­
3%
loss
in
gross
revenues,
moderate:
3­
7%
loss,
and
major
7­
20%
loss)
are
adapted
from
Brassard
and
Grube
(1998).

BEAD
could
only
obtain
prices
for
multiple
active
ingredient
lindane
products
which
contained
diazinon
and
captan
in
addition
to
lindane.
In
contrast,
alternative
seed
treatment
insecticides
are
marketed
only
as
single
active
ingredient
products.
In
order
to
estimate
the
value
Page
3
of
the
lindane
component
of
the
formulated
product,
BEAD
prorated
the
cost
by
assuming
that
all
active
ingredients
in
the
product
had
an
equal
value
on
a
weight
to
weight
basis.

WHEAT
AND
BARLEY
Background
About
62
million
acres
of
wheat
and
5.
8
million
acres
of
barley
are
planted
in
the
U.
S
annually
(USDA
2001).
Kansas,
Montana,
North
Dakota,
Oklahoma,
and
Texas
are
the
major
wheat
producing
states
and
Idaho,
Montana,
North
Dakota,
and
Washington
are
the
major
barley
producing
states.
Wheat
and
barley
are
relatively
low
cash
value
crops
with
gross
revenues
of
$113
and
$122
per
acre
respectively.

Lindane
is
applied
to
about
7
percent
of
U.
S.
grown
wheat
and
barley
for
control
of
wireworms.
Lindane
is
frequently
formulated
with
maneb
(for
control
of
seedling
diseases),
but
is
rarely
formulated
with
diazinon.
The
majority
(96%)
of
lindane
seed
treatment
on
wheat
and
barley
occurs
on
farm
(Glogoza
et
al,
2001;
Zollinger,
1996).
One
reason
for
this
is
that
much
of
the
seed
is
produced
on
farm
(KSU,
1999).
For
this
reason,
most
growers
are
not
likely
to
purchase
pre­
treated
commercial
seed
if
lindane
is
no
longer
available.
Some
thiamethoxam
and
imidacloprid
products
can
only
be
applied
by
commercial
seed
treaters
and
therefore
would
not
be
useful
as
an
alternative
to
lindane
for
many
small
grain
producers.

Comparative
Performance
of
Alternatives
Imidacloprid
(Gaucho®)
and
thiamethoxam
(Adage®)
are
the
primary
alternatives
to
lindane.
Review
of
two
comparative
efficacy
trials
for
control
of
wireworms
on
wheat
and
three
for
wireworm
control
on
corn
lead
BEAD
to
conclude
that
imidacloprid
is
as
effective
as
lindane
in
controlling
wireworms
(at
the
rate
of
0.
005
to
0.
01
lb
ai/
cwt
seed).
In
wireworm
trials
on
corn,
thiamethoxam
is
as
effective
as
lindane
and
imidacloprid.
Thiamethoxam
is
labeled
for
use
on
wheat
at
higher
rates
(0.
029
to
0.
052
lbs
ai/
cwt
seed)
than
imidacloprid,
but
in
BEAD's
opinion
(based
on
available
data)
would
be
as
effective
as
imidacloprid
or
lindane
at
the
lower
rates
(0.005
to
0.01
lb
ai/
cwt
seed).

Economic
Impacts
of
Cancellation
Minor.
In
the
absence
of
lindane,
wheat
and
barley
growers
would
substitute
imidacloprid
seed
treatments
and
experience
increased
treatment
costs
of
$0.
36­
1.
71
per
acre
(0.
3­
1.
5%
of
gross
revenues)
(Tables
2a
and
3).
At
currently
registered
rates,
thiamethoxam
seed
treatments
would
be
prohibitively
expensive
($
8
to
$14
per
acre)
and
would
not
be
adopted
by
growers
(Table
2b).
Assuming
an
average
treatment
cost
increase
of
$1.035
per
acre,
the
aggregate
value
of
increased
treatment
cost
is
$5
million.

OATS
and
RYE
Background
Page
4
About
4.
5
million
acres
of
oats
and
1.
3
million
acres
of
rye
are
planted
in
the
U.
S.
annually
(USDA
2001).
California,
Iowa,
Minnesota,
North
Dakota,
Oklahoma,
South
Dakota,
Texas,
and
Wisconsin
are
the
major
oat
producing
states
and
Georgia,
Oklahoma,
and
Texas
are
the
major
rye
producing
states.
Oats
and
rye
are
relatively
low
cash
value
crops
with
gross
revenues
of
$71
per
acre.
Additionally,
only
about
52
percent
of
oats
and
25
percent
of
rye
are
harvested.
The
remainder
is
pastured,
grown
as
a
cover
crop,
or
experienced
a
crop
failure.
BEAD
assumed
that
all
lindane
treated
acreage
is
harvested.

Lindane
is
applied
to
about
1
percent
of
U.
S.
grown
oats
and
rye
for
control
of
wireworms.
Lindane
seed
treatment
on
oats
and
occurs
only
on
farm
(Glogoza
et
al,
2001;
Zollinger,
1996).
Oats
and
rye
are
less
susceptible
to
wireworm
attack
than
wheat
and
barley
(Glogoza,
2001).

Comparative
Performance
of
Alternatives
There
are
no
registered
alternatives
for
wireworm
control
on
oats
and
rye.
If
registered,
imidacloprid
and
thiamethoxam
are
likely
to
be
as
effective
as
lindane.
BEAD's
review
of
available
efficacy
data
shows
that
lindane
treated
plots
had
0
to
23
percent
more
plants
than
untreated
plots.
Assuming
that
the
stand
loss
to
yield
loss
ratio
is
the
same
as
field
corn,
this
translates
to
yield
losses
of
0
to
18
percent
if
wireworm
populations
are
not
controlled.
(Brassard
and
Grube,
1996).
BEAD
estimates
that
growers
with
wireworm
infestations
would
suffer
an
average
yield
loss
of
9
percent
if
lindane
were
no
longer
available.

Economic
Impacts
of
Cancellation
Major.
In
the
absence
of
lindane,
growers
may
suffer
a
9%
yield
loss
which
would
be
partially
offset
by
a
$0.77
per
acre
cost
savings.
Assuming
that
all
lindane
treated
acreage
is
harvested,
the
total
aggregate
value
of
yield
loss
is
$354,000
(Tables
1
and
3).
These
losses
would
be
partially
offset
by
a
cost
savings
of
$45,000
to
net
an
aggregate
impact
of
cancellation
of
$309,000
(or
0.
2%
of
the
total
US
crop
value)
(Table
4).
These
impacts
would
be
significantly
reduced
if
imidacloprid
were
registered
for
use
on
oats
and
rye.

FIELD
CORN
Background
About
80
million
acres
of
field
corn
are
planted
in
the
U.
S
annually
(USDA
2001).
Illinois,
Indiana,
Iowa,
Kansas,
Minnesota,
Nebraska,
Ohio,
South
Dakota,
and
Wisconsin
are
the
major
corn
producing
states.
Field
corn
gross
revenues
average
$256
per
acre.

Lindane
is
applied
at
planting
time
as
a
seed
treatment
to
about
6
percent
of
U.
S.
grown
field
corn
for
wireworm
control.
Lindane
is
relatively
ineffective
against
seed
corn
maggot,
seed
corn
beetle,
and
white
grubs
(Brassard
and
Grube,
1996).
Lindane
is
frequently
formulated
with
diazinon
to
control
these
other
pests
and
with
fungicides
(e.
g.
captan,
carboxin,
and
maneb)
to
control
seedling
fungal
diseases.
Lindane
seed
treatment
on
corn
occurs
exclusively
on
farm
Page
5
(Buckley,
2002).

Comparative
Performance
of
Alternatives
Imidacloprid
(Gaucho®),
thiamethoxam
(Adage®),
permethrin
(Kernel
Guard
Supreme®)
and
tefluthrin
(Raze®)
seed
treatments
are
the
primary
seed
treatment
alternatives
to
lindane.
Review
of
available
comparative
efficacy
data
for
control
of
wireworms
on
field
corn
lead
BEAD
to
conclude
that
imidacloprid
and
thiamethoxam
are
as
effective
as
lindane
in
controlling
wireworms
(at
the
rate
of
0.
05
lb
ai/
cwt
seed)
but
that
permethrin
and
tefluthrin
seed
treatments
perform
inconsistently
and
are
less
effective
than
lindane
some
of
the
time.

Economic
Impacts
of
Cancellation
Minor.
In
the
absence
of
lindane,
growers
would
substitute
imidacloprid
or
thiamethoxam
seed
treatments
and
experience
increased
treatment
costs
of
$1.82
per
acre
(0.7%
of
gross
revenues).
The
aggregate
value
of
the
increased
treatment
cost
would
be
$8.
7
million.

SORGHUM
About
9
million
acres
of
sorghum
are
planted
in
the
U.
S
annually
(USDA
2001).
Kansas
and
Texas
are
the
major
sorghum
producing
states.
Sorghum
is
a
relatively
low
cash
value
crop
with
gross
revenues
averaging
$107
per
acre.

Lindane
is
applied
at
planting
time
as
a
seed
treatment
to
about
1
percent
of
U.
S.
grown
sorghum
for
control
of
wireworms
and
suppression
of
imported
fire
ants
.

Comparative
Performance
of
Alternatives
Imidacloprid
(Gaucho)
and
thiamethoxam
(Adage®
,
Cruiser®
)
are
the
primary
alternatives
to
lindane.
BEAD
was
unable
to
locate
comparative
efficacy
data
for
control
of
wireworms
on
sorghum.
In
the
absence
of
suitable
data,
BEAD
assumes
that
imidacloprid
and
thiamethoxam
performance
against
wireworms
on
sorghum
is
about
the
same
as
what
was
reported
in
the
field
corn
comparative
efficacy
studies.
BEAD
reviewed
several
non­
comparative
studies
for
suppression
of
fire
ants
on
sorghum
and
concluded
that
lindane
and
imidacloprid
are
equally
effective
in
fire
ant
suppression.
Imidacloprid
and
thiamethoxam
also
control
chinch
bugs,
greenbug,
and
yellow
sugarcane
aphid
on
sorghum
and
their
use
against
these
pests
has
been
shown
to
significantly
increase
yields
by
an
average
of
40
bushels
per
acre
in
moderate
to
heavy
infestations
(Brassard,
1994).

Economic
Impacts
of
Cancellation
Minor.
In
the
absence
of
lindane,
growers
would
substitute
imidacloprid
and
thiamethoxam
seed
treatments
and
experience
increased
treatment
costs
of
$3.70­
4.69
per
acre
(3.
5
to
4.4%
of
gross
revenues).
Because
these
treatment
cost
increases
are
likely
to
be
offset
by
increased
yields
due
to
control
of
chinch
bugs
and
aphids,
the
overall
impact
of
lindane
Page
6
cancellation
is
believed
to
be
minor.
The
aggregate
value
of
the
increased
treatment
cost
is
estimated
to
be
$311,000.

CANOLA
About
1.
5
million
acres
of
canola
are
planted
in
the
U.
S
annually
(USDA
2001).
Minnesota,
North
Dakota,
and
Washington
are
the
major
canola
producing
states.
Canola
is
a
relatively
low
cash
value
crop
with
gross
revenues
averaging
$90
per
acre.

Lindane
is
not
currently
registered
for
use
on
canola
in
the
U.
S.
Lindane
is
used
on
canola
in
Canada
for
wireworm
and
flea
beetle
control.
Imidacloprid
is
currently
applied
to
about
58
percent
of
US
canola
acreage;
thiamethoxam
is
applied
to
about
2
percent
of
U.
S.
canola
acreage.
These
materials
are
incorporated
into
the
seed
entirely
by
seed
processors.
Parsons
(1998)
evaluated
21
field
trials
comparing
the
performance
of
thiamethoxam
with
lindane
and
imidacloprid
against
flea
beetle
on
canola
in
Canada.
Parsons
concluded
that
thiamethoxam
was
equal
to
or
better
than
lindane
in
performance
and
provided
longer
residual
activity
than
lindane
(14­
28
days
vs
4­
10
days).
Brassard
and
Alsadek
(1999)
reviewed
27
comparative
performance
comparisons
for
imidacloprid
and
14
for
thiamethoxam
and
concluded
that
both
materials
effectively
controlled
flea
beetles
and
achieved
yield
increases
of
17
and
59
percent
respectively
over
untreated
controls.

Comparative
Costs
If
registered,
lindane
seed
treatments
would
cost
about
$3.67
per
acre.
Currently
registered
seed
treatments
cost
about
$5.40
to
8.40
per
acre
(weighted
average
is
$5.50)
but
provide
more
effective
control
of
flea
beetles.
Registration
of
lindane
would
provide
growers
a
lower
cost
alternative
to
these
materials
for
short
term
control
of
low
to
moderate
flea
beetle
populations.
If
registered,
BEAD
estimates
that
10
percent
of
the
US
canola
crop
(150,000
acres)
would
be
treated
with
a
resultant
cost
savings
of
$1.83
per
acre
(2%
of
gross
revenues)
or
$274,500
nationally.

SEED
TREATMENTS
IN
THE
REGISTRATION
PIPELINE
Clothianidin,
a
chloronicotinyl
insecticide,
is
currently
in
the
registration
pipeline
for
corn
and
canola.
BEAD's
review
of
efficacy
data
submitted
by
the
registrant
indicate
that
it
is
effective
against
wireworms,
cutworms,
seedcorn
maggots,
white
grubs,
flea
beetles,
and
rootworms
on
corn
and
flea
beetles
on
canola
(Brassard,
2001).
Acetamiprid,
another
chloronicotinyl
insecticide,
is
currently
in
the
registration
pipeline
for
canola.
Efficacy
data
submitted
by
the
registrant
show
that
it
is
equal
to
or
more
effective
than
lindane
and
imidacloprid
for
control
of
flea
beetles
on
canola
(Christian
et
al.,
1999).
Preliminary
information
indicates
that
these
materials
will
cost
about
the
same
as
imidacloprid
and
thiamethoxam.

REFERENCES
Page
7
Brassard,
D.
W.
2001.
BEAD
Review
of
Clothianidin
seed
treatment
on
corn
and
canola.
Internal
Document.
Biological
and
Economic
Analysis
Division/
OPPTS/
EPA.

Brassard,
D.
W.
and
J.
Alsadek.
1999.
BEAD's
Review
of
Documentation
Submitted
by
Gustafson
and
Bayer
Corporation
in
Rebuttal
of
an
Emergency
Exemption
Request
for
the
Use
of
Thiamethoxam
(Helix®)
Seed
Treatment
on
Canola
to
Control
Flea
Beetles.
Internal
Document.
Biological
and
Economic
Analysis
Division/
OPPTS/
EPA.

Brassard,
D.
W.
1994.
BEAD
Review
of
Additional
Information
Provided
by
Gustafson
and
Gerald
Wilde
Regarding
the
Effectiveness
of
Imidacloprid
in
Controlling
Chinch
Bugs
and
Other
Insect
Pests
on
Sorghum.
Internal
Document.
Biological
and
Economic
Analysis
Division/
OPPTS/
EPA,
3
pp.

Brassard,
D.
W.
and
A.
Grube.
1996.
Final
Benefits
Evaluation
of
the
Use
of
At­
Plant
Insecticides
on
Field
Corn.
Internal
Document.
Biological
and
Economic
Analysis
Division/
OPPTS/
EPA.
150
pp.

Brassard,
D.
W.
and
A.
Grube.
1998.
Using
Economic
Impacts
to
Qualitatively
Characterize
Grower
Level
Impacts
in
Agricultural
Crops:
The
QBCM
Model.
Internal
Document.
Biological
and
Economic
Analysis
Division/
OPPTS/
EPA.
2
pp.

Buckley,
M.
2002.
Telephone
Communication
with
David
Brassard
(1­
18­
01).
Mike
Buckley
Associates,
Lake
Tahoe,
CA,
775­
832­
3600.

Cress,
D.
2001.
Personal
Communication
with
Istanbul
Yusuf.
Kansas
State
University.

EPA
Proprietary
Data.
2001.

Glogoza,
P.
A.
2001.
Telephone
Communication
with
David
Brassard
(12­
6­
01).
Department
of
Entomology,
North
Dakota
State
University,
Fargo,
ND.
701­
231­
7581.

Glogoza,
P.
A.,
R.
Zollinger,
and
M.
McMullen.
2001.
Assessment
of
Insecticide
Use
for
Field
Crops
in
North
Dakota
for
2000.
North
Dakota
State
University,
Fargo,
ND.

Dollarhite,
G.
2001.
Personal
Communication
with
Istanbul
Yusuf.
Gustafson.
800­
368­
6130
KSU.
1999.
Kansas
Agricultural
Chemical
Usage:
1998
Wheat
and
Sorghum
Pesticide
Usage
Summary.
Kansas
State
University,
Manhattan
KS
Parsons,
J.
1998.
Efficacy
Review:
Helix
Seed
Treatment
for
Canola.
Canada
Pest
Management
Regulatory
Agency.
10
pp.

USDA
2001.
Agricultural
Statistics
2001.

USDA.
1999­
2001.
Crop
Profiles
for
Wheat,
Barley,
Oats,
Corn,
Sorghum,
and
Canola.
Office
Page
8
of
Pest
Management
Policy,
USDA,
http://
pestdata.
ncsu.
edu/
cropprofiles/

Zollinger
et
al.,
1996.
Pesticide
Use
and
Pest
Management
Practices
for
Major
Crops
in
North
Dakota
1996.
Table
4:
On
Farm
Seed
Treatment.
North
Dakota
State
Univ.,
Fargo,
ND,
http://
www.
ag.
ndsu.
nodak.
edu/
aginfo/
entomology/
ndpiap/
Major_
Crops_
GS/
01table_
of_
c
ontents.
htm
EFFICACY
DATA
REVIEWED:

Arthropod
Management
Tests:
Vol
26:
F31,
Vol
25:
F41,
Vol
24:
F30,
Vol
23:
129F
Barr,
C.
L.,
B.
Drees,
and
B.
Vinson.
1991.
Evaluation
of
the
Lindane
Seed
Treatment,
Gammasan®,
To
Prevent
Predation
by
the
Red
Imported
Fire
Ant
on
Sorghum
Seed.
Department
of
Entomology,
Texas
A&
M
University
System,
in:
http://
fireant.
tamu.
edu/
research/
arr/
Category/
Site/
89­
91Pg06/
89­
91Pg06.pdf
Christian,
M.
L.
et
al
1999.
Reduced
Risk
and
Organophosphate
Replacement
Rationale
for
Acetamiprid:
Agricultural
Uses.
Rhone
Poulenc
Ag.
Company,
Research
Triangle
Park,
NC
27709,
p.
250­
253.

Jarvi,
K.
and
T.
Hunt.
Insecticide
Screening
at
Emerson,
Nebraska
in
2001.
In
Crop
Watch
Newsletter
(October
12,
2001
issue),
University
of
Nebraska
Institute
of
Agriculture
and
Natural
Resources
Cooperative
Extension,
4
pp.

Keaster,
A.,
D.
Hoffman,
and
M.
O'Day.
1999.
Insecticide
Evaluations
for
Control
of
Wireworms
in
Corn.
In
Integrated
Crop
Management
Newsletter,
April
1999.

KSU.
2001.
Efficacy
of
Some
Common
Wheat
seed
Treatments
in
Kansas
2001.
Kansas
State
University
Wheat
Page
Rice,
M.
2000.
Wireworms
Part
1:
Insecticides
Evaluated
in
Missouri.
Integrated
Crop
Management
Newsletter,
March
2000,
p
19­
20.

Gustafson.
2000.
Wireworm
Protection
with
Gaucho
480®
Low
Rate.
Page
9
Table
1
Economic
Impacts
of
Cancelling
Lindane
Seed
Treatment
Uses.
Crop
Lindane
usage
Alternatives
Comparative
Performance
Economic
Impacts
of
Cancellation
acres/%
treated
pounds
applied
Grower
level
impacts**

Aggregate
Impacts
wheat
barley
4,786,110
7%

89,
500
imidacloprid
thiamethoxam
Alternatives
equally
effective
for
wireworm
control.

Minor
Increased
treatment
costs
of
$0.36­
1.71
per
acre
(0.3­
1.5%

of
gross
revenues).

The
aggregate
value
of
increased
treatment
cost
is
$5
million
(0.06%

of
total
US
crop
value).
oats
rye
58,120
1%

843
none
registered
Untreated
plots
may
suffer
a
9%
yield
loss
relative
to
lindane
treated
plots.

Major
Growers
may
suffer
a
9%
yield
loss
which
would
be
partially
offset
by
a
$0.77
per
acre
cost
savings.

The
aggregate
impact
of
cancellation
would
be
$310,000
(0.
2%

of
the
total
crop
value).
canola
0%

0
imidacloprid
thiamethoxam
Alternatives
equally
effective
for
wireworm
control
and
more
effective
for
flea
beetle
control.

Not
Registered
Registration
of
lindane
would
result
in
an
aggregate
cost
savings
of
$1.83
per
acre
(2%

of
gross
revenues).
These
are
likely
to
be
offset
by
increased
yields
from
superior
flea
beetle
control
from
the
use
of
currently
registered
alternatives.

Lindane
is
not
currently
registered
on
canola
therefore
there
is
no
economic
impact.
Registration
of
lindane
would
result
in
an
aggregate
cost
savings
of
$275,000
corn
4,772,700
6%

51,
688
imidacloprid
thiamethoxam
permethrin
tefluthrin
Alternatives
equally
effective
for
wireworm
control.

Alternatives
also
control
seed
corn
maggot,
white
grubs
and
flea
beetles.

Minor
Increased
treatment
costs
of
$1.82
per
acre
(0.7%

of
gross
revenues).

The
aggregate
increased
treatment
cost
is
$8.
7
million
sorghum
91,950
1%

332
imidacloprid
thiamethoxam
Alternatives
equally
effective
for
wireworm
and
fire
ant
control.
Alternatives
also
control
chinch
bugs
and
aphids
Minor
Increased
treatment
costs
of
$3.70­
4.69
per
acre
(3.5­
4.4%

of
gross
revenues)
are
likely
to
be
offset
by
increased
yields
due
to
control
of
chinch
bugs
and
aphids.

The
aggregate
increased
treatment
cost
is
$386,000.
Page
10
all
uses
9,

708,880
142,364
imidacloprid
thiamethoxam
Alternatives,
when
available,
are
as
effective
as
lindane.

Average
treatment
cost
increase
of
$1.45
per
acre
(or
0.8%

of
gross
revenues).

Aggregate
treatment
cost
increase
of
14
million.
Aggregate
value
of
yield
loss
is
$354,000.
*

criteria
for
qualitative
grower
level
impact
descriptions:
minor:

0­

3%

loss
in
gross
revenues,
moderate:

3­

7%

loss,

major
7­

20%
loss
in
gross
revenues
(adapted
from
Brassard
and
Grube,
1998
Page
11
Table
2a.

Comparative
Costs
of
Lindane
and
Imidacloprid
Seed
Treatments
Crops
Lindane
Cost/
Acre
Imidacloprid
Cost/
Acre*

Increased
Treatment
cost/
Acre
(using
imidacloprid)
Wheat/
Barley
$0.99
$1.35­
2.70
$0.36­
1.71
Oats/
rye
$0.77
N/
A
($

0.77)
Canola**

$3.67
$5.40
$1.73
Corn
$0.58
$2.40
$1.82
Sorghum
$0.19
$4.88
$4.69
*

imidacloprid
costs
obtained
from
Gustafson,
2001
(personal
communication
establishing
price
of
Gaucho®
480
at
$1200
per
gallon
or
$300
per
pound
active
ingredient)
**

assumes
growers
would
use
lower
rate
of
imidacloprid
on
canola
(higher
rate
costs
$18.43/
acre
treated)
Table
2b.

Comparative
Costs
of
Lindane
and
Thiamethoxam
Seed
Treatments
Crops
Lindane
Cost/
Acre
Thiamethoxam
Cost/
Acre*

Increased
Treatment
cost/
Acre
(using
thiamethoxam)
Wheat/
Barley
$0.99
$7.91­
14.03
$6.92­
13.04
Oats/
rye
$0.77
N/
A
($

0.77)
Canola
$3.67
$8.40
$4.73
Corn
$0.58
$2.40
$1.82
Sorghum
$0.19
$3.89
$3.70
*

Cost
data
was
not
available
for
most
thiamethoxam
uses.

Thiamethoxam
costs
for
most
uses
were
estimated
by
assuming
treatment
costs
per
pound
active
ingredient
were
the
same
as
imidacloprid
(i.
e.

$300
per
pound
ai)

Thiamethoxam
seed
treatments
are
applied
at
higher
rates
on
wheat
and
barley
and
would
be
significantly
more
expensive
and
unlikely
to
be
used
as
alternatives
to
lindane.
Prices
for
thiamethoxam
on
canola
($

8.40/
A)

are
from
:

http://
www.
canola­
council.
org/
cpc/

99report/
180­

181.pdf
;

cost
given
is
the
incremental
cost
(total
cost
minus
the
Page
12
cost
of
the
seed
and
a
fungicide
=

$9.02
per
acre
for
Eagle®
seed
treated
with
Benlate
fungicide)
Table
3.

Changes
in
Treatment
Cost
from
Substitution
of
Imidacloprid
and
Thiamethoxam
Seed
Treatments
for
Lindane
Seed
Treatment
(or
in
the
case
of
oats
and
rye,

substitution
of
no
treatment).
Crop
Acres
planted
%

acres
treated
Acres
treated
Increased
treatment
cost/
acre
Total
increased
treatment
cost
($)
Wheat/
barley
68,373,000
7%

4,786,110
$0.36­$
1.71
$4,953,238*
Oats/
rye
5,812,000
1%

58,120
($

0.77)

($

44,752)
Corn
79,545,000
6%

4,772,700
$1.82
$8,686,314
Sorghum
9,

195,000
1%

91,950
$3.70­$
4.69
$385,730**
Total/

Average
162,925,000
6%

9,708,880
$1.45
$14,070,034
*

assumes
average
treatment
cost
increase
of
$1.035
per
acre
**

sorghum
treatment
cost
increases
estimated
by
assuming
equal
adoption
of
imidacloprid
and
thiamethoxam
seed
treatments
Table
4.

Economic
Impact
of
lindane
cancellation
on
oats
and
rye
where
there
are
no
registered
alternatives.
Crops
Acres
Planted
%

acres
treated
Acres
treated
%

yield
loss
Lost
bushels
Price/
bushel
Value
of
crop
loss
Decreased
treatment
costs
Economic
impact
of
cancellation
Oats
4,477,000
1%

44,770
9%

258,681
$1.05
$271,615
$34,473
$237,142
Rye
1,

335,000
1%

13,350
9%

33,242
$2.49
$82,771
$10,280
$72,492
Total/

Weighted
average
5,812,000
1%

58,120
9%

291,923
$1.21
354,386
$44,752
$309,634
Page
13
Appendix
Table
1.

Calculation
of
Lindane
application
rates
Crop
average
seeding
rate
(lbs/
A)

Application
rate/
unit
Application
rate/
A
Source
barley
90
2
oz
16.6%
WP/
cwt
0.0187
Labeled
rate
of
sorghum
guard
=

0.

02075
lb
ai/

cwt
oats
70
2
oz
16.6%
WP/
cwt
0.0145
Labeled
rate
of
sorghum
guard
=

0.

02075
lb
ai/

cwt
rye
70
2
oz
16.6%
WP/
cwt
0.0145
Labeled
rate
of
sorghum
guard
=

0.

02075
lb
ai/

cwt
wheat
90
2
oz
16.6%
WP/
cwt
0.0187
Labeled
rate
of
sorghum
guard
=

0.

02075
lb
ai/

cwt
corn
20
1.94
oz.

25%
WP/
bushel
0.01083
Weighted
average
of
labeled
rate
of
Kernel
Guard
(2
oz/
bu)

and
Agrox
D­
L
plus
(1.8
oz/

bu),
the
two
most
commonly
used
productson
corn.

Weights:

of
0.

705
for
Kernel
Guard
and
0.

295
for
Agrox
D­
L
based
on
usage
data.
sorghum
6.
5
3
oz
16.6%/
bushel
0.

003613
Sorghum
Guard
3
oz
16.6%/
bushel
=

0.031125
lb
ai/
bu
=

0.003613
lb
ai/
A
canola
4.5
2250
ml
68%/
100
kg
0.069
labeled
rate
of
Vitavax
=

680g/
l
=

68%

lindane
Appendix
Table
2.

Calculation
of
Lindane
active
ingredient
costs
Product
Cost
per
pound
product
Lindane
%

Diazinon
%

Captan
%

Cost
per
lb
ai
of
lindane
($)

Prorated
cost
of
lindane
per
lb
ai**
Kernel
guard
28.54
25
15
15
114.16
51.89
Agrox
DL
30.84
25
15
15
123.36
56.07
Weighted
average*

29.22
25
15
15
116.87
53.12
*

Weighted
average
of
Kernel
Guard
and
Agrox
D­
L
plus
(most
commonly
used
products)
(Weights:

0.

705/

0.295
based
on
usage
data)
**

estimated
cost
of
the
value
of
the
lindane
component
of
the
formulated
product.
Assumes
all
active
ingredients
in
product
have
an
equal
value
on
a
weight
to
weight
basis
Page
14
Appendix
Table
3.

Calculation
of
Lindane
Chemical
costs.
Crop
Application
rate
(lb
ai/
A)

Cost
per
lb
ai
lindane
Chemical
Cost
per
acre
Total
Product
cost
Prorated
cost
of
lindane
only
Total
Product
cost
Prorated
cost
of
lindane
only
barley
0.0187
$116.87
$53.12
$2.19
$0.99
oats
0.0145
$116.87
$53.12
$1.69
$0.77
rye
0.

0145
$116.87
$53.12
$1.69
$0.77
wheat
0.

0187
$116.87
$53.12
$2.19
$0.99
corn
0.01083
$116.87
$53.12
$1.27
$0.58
sorghum
0.

003613
$116.87
$53.12
$0.42
$0.19
canola
0.069
$116.87
$53.12
$8.06
$3.67
**

estimated
cost
of
the
value
of
the
lindane
component
of
the
formulated
product
(which
contain
other
active
ingredients
such
as
diazinon
and
captan).

Assumes
all
active
ingredients
in
product
have
an
equal
value
on
a
weight
to
weight
basis
Appendix
Table
4.

Calculation
of
Lindane
Usage
Estimates.
Crop
Acres
planted
%

acres
treated
Acres
treated
Application
Rate
(lbs
ai/
A)

Pounds
ai
applied
Wheat/
barley
68,373,000
7%

4,786,110
0.0187
89,500
oats/
rye
5,812,000
1%

58,120
0.0145
843
Corn
79,545,000
6%

4,772,700
0.01083
51,688
Sorghum
9,

195,000
1%

91,950
0.003613
332
Total/

Average
162,925,000
6%

9,708,880
0.01466
142,364
