Page
1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
Date:
June
26,
2002
SUBJECT:
Revised
Estimates
of
the
Number
of
Acres
Treated
per
Day
for
Lindane
Seed
Treatment
Use
on
Field
Corn
FROM:
David
W.
Brassard,
Senior
Entomologist
Herbicide
and
Insecticide
Branch
Biological
and
Economic
Analysis
Division
(7503C)

THRU:
Arnet
Jones,
Chief
Herbicide
and
Insecticide
Branch
Biological
and
Economic
Analysis
Division
(7503C)

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

Peer
Review
Date:
June
26,
2002
SUMMARY
On
June
6,
2002,
BEAD
met
with
representatives
from
the
lindane
registrants,
Gustafson
and
Uniroyal,
to
reconcile
differences
in
the
assumptions
used
in
the
derivation
of
estimates
of
the
number
of
field
corn
acres
planted
with
lindane
treated
seed
per
day.
BEAD's
original
assumptions
produced
estimates
of
200
acres
treated
daily
whereas
the
registrant's
assumptions
produced
estimates
of
80
acres
treated
daily.
Based
on­
farm
size
information
obtained
from
pesticide
usage
data
and
the
USDA
Agricultural
Census,
BEAD
refuted
the
registrants'
assumption
that
lindane
treated
seed
is
only
used
on
small
and
medium
size
farms
with
8
row
planters.
BEAD
believes
that
some
growers
planting
500
or
more
acres
of
corn
use
20
row
planters
to
apply
lindane
treated
seed.
BEAD
agreed
with
the
registrant's
assumption
of
longer
hopper
refill
times
(than
those
experienced
by
applicators
of
granular
pesticides)
for
pouring
and
mixing
the
seed
with
a
lindane
seed
treatment
product.
Based
on
the
revised
assumptions
provided
by
the
registrant,
BEAD
is
revising
its
previous
estimate
of
200
acres
of
field
corn
treated
with
lindane
seed
treatment
per
day
downward
to
180
acres
treated
per
day.
Page
2
BACKGROUND
In
response
to
a
request
from
SRRD,
BEAD
reviewed
the
"Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
United
States"
submitted
by
Uniroyal
Chemical
Company.
In
a
memo
dated
May
15,
2002,
BEAD
disagreed
with
Uniroyal's
estimate
of
80
acres
planted
per
day
for
corn
(Brassard,
2002).
Based
on
the
Science
Advisory
Council
for
Exposure
Policy
Number:
9.1
(Sandvig,
2001),
BEAD
estimated
that
200
acres
planted
per
day
was
a
more
reasonable
upper
end
estimate.
The
EPA
policy
estimates
were
based
(in
part)
on
an
analysis
by
Brassard
and
Ng
(1993)
which
assumed
the
use
of
20
row
planters
for
application
of
granular
insecticides
and
an
eight
hour
work
day.

DIFFERENCES
BETWEEN
BEAD
AND
REGISTRANT
SEED
TREATMENT
ASSUMPTIONS
On
June
6,
2002,
BEAD
met
with
representatives
from
the
lindane
registrants,
Gustafson
and
Uniroyal,
to
discuss
the
assumptions
used
in
the
derivation
of
these
exposure
estimates.
The
registrants
indicated
that
they
assumed
that
on­
farm
products
are
typically
used
by
small
to
medium­
sized
farm
operations
who
generally
use
8
row
planters.
When
queried,
the
registrants
indicated
that
they
had
no
factual
basis
for
this
assumption.
BEAD
explained
that
its
use
information
sources
indicated
that
the
average
field
size
for
lindane
treated
field
corn
was
145
acres
which
is
close
to
the
national
average
of
162
acres
(USDA,
1997a).
Nationally,
37%
of
all
field
corn
acreage
occurs
on,
and
7%
of
all
field
corn
growers
harvest,
over
500
acres
of
field
corn
(Table
1,
USDA,
1997b).
BEAD
believes
that
many
growers
planting
more
than
500
acres
of
corn
would
be
using
20
row
planters.

The
registrants
also
assumed
that
it
would
take
at
least
30
minutes
to
pour
and
mix
the
seed
and
lindane
seed
treatment
product
for
an
8
row
planter
(which
is
equivalent
to
about
3.
75
minutes
per
hopper)
and
that
an
8
row
planter
traveling
at
5
miles
per
hour
can
treat
an
acre
in
about
5
minutes
(assuming
a
30
inch
row
spacing)
or
about
84
acres
in
an
8
hour
day.

8
hours
=
480
minutes
30
minutes
to
refill
hoppers
x
2
refills
=
60
minutes
480
­
60
minutes
=
420
minutes
planting
time
remaining
in
8
hour
day
420
minutes
÷
5
minutes/
acre
=
84
acres
treated
in
an
8
hour
day
BEAD
agrees
with
the
registrant's
assumption
of
longer
hopper
refill
times
(than
those
experienced
by
applicators
of
granular
pesticides)
necessary
to
pour
and
mix
the
seed
and
lindane
seed
treatment
product.
Using
the
registrant's
assumptions
regarding
refill
times,
planter
speed,
and
row
spacing,
BEAD
calculated
that
a
grower
using
a
20
row
planter
could
treat
180
acres
in
an
eight
hour
day
8
hours
=
480
minutes
75
minutes
to
refill
hoppers
x
1.
5
refills
=
112.5
minutes
480
­
112.5
minutes
=
367.5
minutes
planting
time
remaining
in
8
hour
day
a
20
row
planter
traveling
at
5
miles
per
hour
can
treat
an
acre
in
about
2
minutes
1
Each
hopper
usually
takes
2
bags
of
seed
which
is
enough
to
treat
6
acres;
20
hoppers
x
6
acres
x
1.
5
refills
=
180
acres.

Page
3
367.5
minutes
÷
2
minutes/
acre
=
183.75
acres
treated
in
an
8
hour
day
However
since
1.
5
refills
of
a
20
row
planter
only
provides
enough
seed
to
treat
180
acres
1
,
BEAD
believes
that
this
is
a
more
realistic
estimate
for
exposure
assessment
purposes.
BEAD
believes
that
halving
the
refill
time
for
the
half
refill
is
practical
since
a
full
refill
requires
that
2
bags
of
seed
be
added
per
hopper
and
treated
and
thus
adding
only
1
bag
of
seed
per
hopper
could
be
accomplished
in
roughly
half
the
time.

CONCLUSION
BEAD
believes
that
the
registrant
estimate
of
84
acres
treated
per
day
represents
a
reasonable
central
value
exposure
scenario.
BEAD's
estimate
of
180
acres
treated
per
day
should
be
considered
as
reasonable
upper
end
estimate
for
an
8
hour
work
day.
However,
BEAD
is
aware
of
situations
in
which
growers
working
long
hours
on
24
row
planters
have
planted
300
to
400
acres
of
field
corn
in
a
day
(Muggeridge,
1997).

References
Brassard,
D.
W.
2002.
BEAD
Review
of
Korpalski
Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
U.
S.
Internal
Memorandum
to
Mark
Howard
dated
May
15,
2002.

Brassard,
D.
W.
and
Y.
Ng.
1993.
Transmittal
of
Corn
Cluster
Exposure
Parameters.
Internal
Memorandum
to
Larry
Dorsey
(HED).
12
pp.

EPA
Proprietary
Data.
2001.

Korpalski,
S.
J.
2002.
Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
United
States.
Exposure
study
submitted
to
EPA
by
Uniroyal
Chemical
Company,
Bethany,
CT
06524,
13
pp.

Muggeridge,
J.
M.
1997.
Up
to
400
acres
a
day.
Farm
&
Country
Magazine,
February
1997
issue,
Agricultural
Publishing
Company
Ltd.,
Ottawa,
Ontario,
Canada.

Sandvig,
R.
2001.
Science
Advisory
Council
for
Exposure:
Policy
Number
9.
1:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture.
HED
internal
document
Revised:
September
25,
2001.

USDA.
1997a.
1997
United
States
Census
of
Agriculture­
State
Data:
Table
26
Grains­
Corn,
Sorghum,
Wheat,
and
Other
Small
Grains:
1997
and
1992.
USDA/
NASS,
Page
4
http://
www.
nass.
usda.
gov/
census/
census97/
volume1/
us­
51/
us2_
25.pdf
USDA.
1997b.
1997
United
States
Census
of
Agriculture­
United
States
Data:
Table
42.
Specified
Crops
by
Acres
Harvested:
1997,
USDA/
NASS
http://
www.
nass.
usda.
gov/
census/
census97/
volume1/
us­
51/
us1_
42.pdf
Table
1.
Farm
Size
Distribution
of
Field
Corn
(for
grain
or
seed)

Acres
Harvested
per
farm
Number
of
farms
Acres
%
of
farms
%
of
acres
1
to
14
62,220
465,114
14.4%
0.7%

15
to
24
36,687
693,524
8.5%
1.0%

25
to
49
63,977
2,252,678
14.9%
3.2%

50
to
99
77,908
5,414,064
18.1%
7.8%

100
to
249
103,096
16,142,856
23.9%
23.1%

250
to
499
55,293
18,895,093
12.8%
27.1%

500
to
999
24,995
16,372,841
5.8%
23.5%

1,000
to
1,999
5,673
7,165,024
1.3%
10.3%

2,000
to
2,999
633
1,458,638
0.15%
2.1%

3,000
to
4,999
195
685,792
0.05%
1.0%

5,000
or
more
34
251,092
0.01%
0.4%

Total
430,711
69,796,716
100.0%
100.0%

Source:

USDA.
1997b.
1997
United
States
Census
of
Agriculture­
United
States
Data:
Table
42.
Specified
Crops
by
Acres
Harvested:
1997,
USDA/
NASS
http://
www.
nass.
usda.
gov/
census/
census97/
volume1/
us­
51/
us1_
42.pdf
