UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
April
13,
2006
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Qualitative
impact
assessment
of
extensions
to
restricted
entry
intervals
for
phosmet
in
grapes
(
DP
#
296575)

FROM:
Monisha
Kaul,
Biologist
Nikhil
Mallampalli,
Biologist
Biological
Analysis
Branch
TJ
Wyatt,
Agricultural
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

THRU:
Arnet
Jones,
Chief
Biological
Analysis
Branch
Timothy
Kiely,
Acting
Chief
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

TO:
Diane
Isbell,
Chemical
Review
Manager
(
7509C)
Margaret
Rice,
Chief
Special
Review
and
Reregistration
Division
Product
Review
Panel
Date:
April
7,
2006
SUMMARY
EPA
is
considering
mitigation
strategies
to
address
concerns
for
workers
exposed
to
phosmet
following
applications
to
grapes.
This
is
a
preliminary,
qualitative
assessment
of
the
impact
of
extending
the
restricted
entry
interval
(
REI).
2
Growers
would
likely
stop
using
phosmet
if
the
REI
is
greater
than
14
days
(
Cook
and
Kiely,
2001).
A
REI
longer
than
14
days
would
likely
interfere
with
manual
labor
activities
such
as
leaf
pulling
and
hand
harvesting.
Were
growers
not
to
use
phosmet,
increased
production
costs
from
more
expensive
chemicals
would
be
expected
in
California
and
the
Pacific
Northwest,
although
yield
and
quality
loss
is
not
expected.
In
the
Northeast
and
South,
decreased
yield
as
well
as
increased
production
costs
and
would
be
expected
because
growers
rely
more
heavily
on
phosmet
than
in
other
regions.

BACKGROUND
Based
on
post­
application
worker
risk
assessments,
EPA
is
considering
mitigation
strategies,
including
extending
the
restricted
entry
interval
(
REI)
for
phosmet
use
on
grapes.
The
risk
assessment
indicates
that
a
REI
of
29
days
would
be
necessary
to
reduce
risks
to
worker
below
the
Agency's
level
of
concern.
The
purpose
of
this
assessment
is
to
provide
a
preliminary,
qualitative
assessment
of
the
impact
of
extending
the
REI
on
grape
producers
and
the
grape
industry.

Grapes
Grapes
are
produced
in
nearly
every
state
of
the
U.
S.
The
most
recent
statistics
indicate
that
about
940,000
acres
of
grapes
are
grown
in
the
U.
S.
(
USDA
NASS,
2006).
Over
85%
of
the
total
acreage
is
in
California.
Washington
and
New
York
are
the
other
main
producers.
Total
grape
production
is
about
6.7
million
tons
annually
with
a
total
value
of
about
$
2.9
billion.
Producer
prices
average
around
$
430/
ton,
but
vary
considerably
by
state
and
by
end
use.
Table
1
provides
acreage,
production
and
value
figures
as
reported
by
USDA.

Table
1.
U.
S.
grape
acreage,
production
and
value,
2001
 
2005
average.
Region
Bearing
Acres
Production
(
1000
tons)
Yield
(
ton/
acre)
Value
($
1000)
Price
($/
ton)
California
809,400
6,057.8
7.4
2,623,964
435
Pacific
Northwest
1
61,720
351.8
5.7
169,463
485
Northeast
2
58,380
311.9
5.3
76,460
245
South
3
8,900
23.9
2.7
22,596
945
U.
S.
940,260
6,752.7
7.2
2,884,764
425
Source:
Noncitrus
Fruits
and
Nuts
Summary
(
USDA
NASS,
various
years).
U.
S.
totals
do
not
equal
the
sum
of
the
columns
because
some
states
are
not
included
in
the
table.
1
Oregon
and
Washington.
2
Michigan,
New
York,
Ohio,
and
Pennsylvania.
3
Arkansas,
Georgia,
Missouri,
North
Carolina,
Texas,
and
Virginia.

Grapes
may
be
sold
fresh
or
processed
into
juice,
wine
or
raisins.
Typically,
certain
varieties
are
targeted
into
specific
uses,
although
there
is
some
flexibility.
Table
2
provides
a
summary
of
utilization,
by
region.
Wine
is
produced
in
all
parts
of
the
U.
S.
In
contrast,
raisins
are
almost
completely
produced
in
California.
Nationally,
juice
varieties
make
up
less
than
10%
of
3
production,
but
they
are
the
dominant
types
in
the
Pacific
Northwest
and
the
Northeast.
California
produces
little
or
no
juice
varieties.

Table
2.
Grape
utilization,
amount
(
tons)
and
percent
of
total,
2001
 
2005
average.
Region
Fresh
(%
of
total)
Juice
(%
of
total)
Wine
(%
of
total)
Raisin
(%
of
total)
Total
California
885,600
(
14.6%)
3,618,000
(
59.7%)
1,559,200
(
25.7%)
6,057,800
Pacific
Northwest
1
219,400
(
62.4%)
131,000
(
37.2%)
351,680
Northeast
2
3,560
(
1.1%)
234,820
(
75.3%)
57,040
(
18.3%)
311,940
South
3
2,080
(
8.7%)
18,680
(
78.3%)
23,870
U.
S.
896,420
(
13.3%)
455,690
(
6.7%)
3,806,960
(
56.4%)
1,560,570
(
23.1%)
6,752,670
Source:
Noncitrus
Fruits
and
Nuts
Summary
(
USDA
NASS,
various
years).
Totals
may
equal
the
sum
of
columns
because
of
rounding
or
because
minor
uses
are
not
reported.
U.
S.
totals
do
not
equal
the
sum
of
the
columns
because
some
states
are
not
included
in
the
table.
1
Oregon
and
Washington.
2
Michigan,
New
York,
Ohio,
and
Pennsylvania.
3
Arkansas,
Georgia,
Missouri,
North
Carolina,
Texas,
and
Virginia.

Recent
Use
of
Phosmet
According
to
data
from
the
California
Pesticide
Use
Reports
(
CDFA,
various
years),
phosmet
use
on
grapes
declined
between
1999
and
2004,
from
less
than
two
percent
crop
area
treated
to
less
than
one
percent.
Reports
distinguish
between
wine
grapes
and
other
grapes
(
table
and
raisin),
but
there
is
little
difference.
However,
if
phosmet
is
applied
solely
to
table
grapes,
the
percentage
of
acreage
currently
treated
is
about
1.6%,
down
from
around
8%
in
1999.
Total
amount
of
phosmet
applied
has
fallen
from
about
26,000
lb
in
1999
to
about
5,700
lb
in
2004,
as
the
number
of
acres
treated
declined.
Only
about
10%
of
the
acreage
is
treated
more
than
once.
The
application
rate
has
remained
fairly
constant
at
about
1.5
lb/
acre
per
year.

Data
from
other
states
are
sparse.
The
National
Agricultural
Statistics
Service,
USDA
(
various
years),
has
published
very
limited
information.
It
appears
that
growers
in
the
Northeast
rely
relatively
more
heavily
on
phosmet
than
do
California
producers.
Data
suggest
that
15­
20%
of
the
acreage
is
treated,
although
recent
data
are
particularly
sparse.
EPA
proprietary
data
also
indicate
about
20%
of
crop
area
treated
in
the
Northeast.
EPA
proprietary
data
indicate
that
less
than
10%
on
average
of
crop
area
is
treated
in
the
Pacific
Northwest
and
seems
to
be
declining
in
recent
years.
Like
NASS
statistics,
these
figures
depend
on
small
sample
sizes
and
should
be
viewed
with
caution.

In
the
Northeast,
the
average
application
rate
is
about
1.2
lb
phosmet
per
acre.
Growers
sometimes
make
multiple
applications;
on
average,
growers
make
1.4
applications
per
year
(
USDA
NASS,
various
years).
Data
are
not
available
for
the
Pacific
Northwest.
4
MAXIMUM
FEASIBLE
REI
The
2001
BEAD
assessment
concluded
that
growers
would
likely
stop
using
phosmet
if
the
REI
is
greater
than
14
days
in
both
California
and
the
Northeast
(
Cook
and
Kiely,
2001).
In
California,
a
longer
REI
would
interfere
with
hand
harvesting
activities.
California
wine
grapes
can
be
either
hand
or
mechanically
harvested,
while
table
grapes
are
generally
hand
harvested.
Phosmet
is
typically
applied
around
mid­
July
through
September
while
hand­
harvesting
begins
in
mid­
August
and
runs
through
October.
Secondary
pests
may
account
for
some
additional
phosmet
applications,
either
at
the
delayed
dormant
stage
or
during
the
summer,
which
overlap
many
worker
activities
that
take
place
at
those
times.

In
the
Northeast,
phosmet
may
be
applied
several
times
during
the
season
for
grape
berry
moth
control.
After
the
early
season
application,
worker
activities
such
as
cluster
thinning,
shoot
thinning,
and
shoot
positioning
are
required
within
two
to
three
weeks
(
Cook
and
Kiely,
2001).
The
last
application
of
the
season
targets
the
third
generation
of
the
grape
berry
moth
and
requires
an
insecticide
with
a
short
REI
as
workers
must
complete
manual
labor
tasks
such
as
leaf
pulling
activities.
Such
manual
labor
tasks
are
important
for
maintaining
crop
quality.
Phosmet
is
used
in
this
situation
because
of
its
short
REI;
a
REI
longer
than
14
days
may
interfere
with
hand
labor
activities
(
Colwell
and
Kiely,
2001).
This
situation
may
also
apply
to
growers
in
the
South,
primarily
because
the
third
generation
grape
berry
moth
is
more
common
there
than
in
the
North.

According
to
the
Pest
Management
Strategic
Plan
for
Washington
State
Wine
Grape
Production
(
2004),
if
phosmet
is
used,
it
will
be
pre­
bloom
in
the
spring
or
summer,
which
may
coincide
with
leaf
pulling
activities,
which
occur
two
to
three
weeks
post­
bloom,
similar
to
the
early
applications
in
the
Northeast.

IMPACTS
OF
EXTENDING
REI
BEYOND
MAXIMUM
FEASIBLE
LENGTH
Extending
the
REI
beyond
the
current
14
days
would
result
in
growers
turning
to
one
of
several
available
alternatives
for
control
of
pests
targeted
by
phosmet.

The
primary
target
pests
in
California
are
the
omnivorous
leafroller
and
the
Western
grape
leaf
skeletonizer.
Secondary
pests
controlled
by
phosmet
are
the
grape
mealybug
and
vine
mealybug.
In
the
Pacific
Northwest,
the
primary
target
pests
are
the
grape
mealybug
and
cutworms.

In
the
Northeast,
the
primary
target
pest
is
the
grape
berry
moth.
The
most
common
secondary
pest
for
which
phosmet
is
used
is
the
Japanese
beetle.

Alternatives
The
omnivorous
leafroller
and
Western
grape
leaf
skeletonizer
are
usually
controlled
with
a
mix
of
Bacillus
thuringiensis
(
Bt)
and
cryolite.
Spinosad
and
methoxyfenozide
were
registered
after
the
2001
BEAD
assessment
was
conducted
for
phosmet.
Although
efficacy
data
is
sparse,
these
two
chemicals
appear
to
be
efficacious
(
A
Pest
Management
Strategic
Plan
for
Winegrapes
in
California,
2004).
5
Alternatives
for
mealybugs
include
chlorpyrifos
and
imidacloprid.
Chlorpyrifos
has
been
reported
to
provide
excellent
control
of
mealybugs
while
imidacloprid
provides
good
control
(
A
Pest
Management
Strategic
Plan
for
Winegrapes
in
California,
2004).

Table
3
indicates
the
chemicals
that
may
be
efficacious
against
the
various
California
pests
and
their
typical
cost
per
acre.
However,
these
alternatives
may
not
be
as
efficacious
as
phosmet
and
could
require
more
than
one
application
to
achieve
the
same
level
of
control.
If
the
same
control
cannot
be
achieved,
growers
may
experience
yield
and/
or
quality
losses.

Table
3.
Available
alternatives
for
phosmet
target
pests
in
California
Alternative
Omnivorous
leafroller
Western
grape
leaf
skeletonizer
Mealybugs
Cost
1
$/
acre
phosmet
x
x
x
9­
14
Bacillus
thuringiensis
x
x
7­
10
cryolite
x
x
11­
13
carbaryl
x
x
x
10
methomyl
x
x
x
15­
22
chlorpyrifos
x
18­
19
imidacloprid
x
45­
65
fenpropathrin
x
10­
12
methoxyfenozide
x
16­
19
spinosad
x
x
22
acetamiprid
2
x
pheromone
mating
disruption
3
x
clay
2
x
x
An
"
x"
indicates
the
chemicals
that
may
be
efficacious
according
to
Cook
and
Kiely
(
2001)
and
A
Pest
Management
Strategic
Plan
for
Winegrapes
in
California
(
2004).
1
EPA
proprietary
data,
based
on
treatment
costs
for
target
pests,
2001­
2004
average.
2
Insufficient
usage
from
which
to
calculate
cost.
3
EPA
data
do
not
include
the
cost
of
pheromones.

Table
4
indicates
the
chemicals
that
may
be
efficacious
against
the
Northeast
pests
and
their
typical
cost
per
acre.
These
alternatives
may
not
be
as
efficacious
as
phosmet
and
could
require
more
than
one
application
to
achieve
the
same
level
of
control.
If
the
same
control
cannot
be
achieved,
growers
may
experience
yield
and/
or
quality
losses.
6
Table
4.
Available
alternatives
for
phosmet
target
pests
in
the
Northeast
Alternative
Grape
berry
moth
Japanese
beetle
Cost
1
$/
acre
phosmet
x
x
9­
13
Bacillus
thuringiensis
2
x
carbaryl
x
x
10­
11
methomyl
x
8­
16
fenpropathrin
x
x
10­
11
methoxyfenozide
2
x
pheromone
mating
disruption
3
x
clay
2
x
An
"
x"
indicates
the
chemicals
that
may
be
efficacious
according
to
Cook
and
Kiely
(
2001)
and
Crop
Profile
for
Lubrusca
(
Juice)
Grapes
in
Michigan
(
2004).
1
EPA
proprietary
data.
2
EPA
data
indicate
insufficient
usage
from
which
to
calculate
cost.
3
EPA
data
do
not
include
the
cost
of
pheromones.

The
grape
berry
moth
can
be
controlled
with
fenpropathrin,
carbaryl,
and
methomyl.
The
Japanese
beetle
can
be
effectively
controlled
with
fenpropathrin
and
carbaryl.
All
three
chemicals
have
IPM
concerns.
Fenpropathrin
should
not
be
applied
more
than
once
per
year
because
of
reported
resistance
and
is
more
critical
for
grape
berry
moth
control
(
Cook
and
Kiely,
2001).
Both
carbaryl
and
methomyl
are
highly
toxic
to
mite
predators
(
Crop
Profile
for
Lubrusca
(
Juice)
Grapes
in
Michigan,
2004).

According
to
the
Pest
Management
Strategic
Plan
for
Washington
State
Wine
Grape
Production
(
2004),
the
use
of
broadcast
phosmet
applications
is
discouraged
because
phosmet
is
disruptive
to
beneficials
or
non­
targets.
Additionally,
barrier
treatments
such
as
fenpropathrin
may
be
more
efficacious
and
less
costly
than
broadcast
sprays,
especially
for
cutworm
control.

In
recent
years,
broad­
spectrum
insecticides,
such
as
organophosphates,
are
being
replaced
by
insecticides
with
a
narrower
activity
spectrum.
The
older
chemicals
not
only
controlled
the
target
pest(
s),
but
also,
most
other
exposed
insects.
A
consequence
of
the
shift
to
newer
chemistries
is
that
crop
damage
from
insects
that
until
recently
were
considered
minor
pests
appears
to
be
increasing.
However
concomitantly,
the
shift
to
narrower­
spectrum
chemicals
may
result
in
less
mortality
for
beneficial
species,
including
natural
enemies,
which
should
in
turn
increase
natural
mortality
for
some
insect
pests,
ultimately
leading
to
less
pesticide
use.
To
the
extent
that
these
pest
dynamics
continue
to
evolve
and
remain
rather
difficult
to
predict,
this
analysis
examines
only
potential
short­
term
(
two
to
three
years)
impacts
of
replacing
phosmet
with
insecticides
with
a
narrow
activity
spectrum.

Impacts
Because
a
REI
for
phosmet
beyond
14
days
would
interfere
with
key
crop
production
and
pest
management
practices,
growers
would
likely
stop
using
it
altogether
and
turn
to
one
or
more
of
several
available
alternatives.
7
Given
the
availability
of
new
alternatives
and
based
on
recent
low
usage
of
phosmet
in
California,
BEAD
tentatively
concludes
that
yield
or
quality
losses
are
unlikely
if
phosmet
could
not
be
used.
It
is
likely
that
production
costs
will
increase
because
alternatives
are
more
costly,
would
have
to
be
applied
more
often,
or
would
result
in
applications
of
additional
pesticides
to
control
secondary
pests.
Given
the
low
usage
of
phosmet
in
California,
these
impacts
may
be
minor
and
would
not
affect
a
large
number
of
growers.
Similarly,
declining
phosmet
usage
and
more
efficacious
alternatives
suggested
by
specialists
indicate
that
significant
yield
or
quality
impacts
are
unlikely
in
the
Pacific
Northwest
(
Pest
Management
Strategic
Plan
for
Washington
State
Wine
Grape
Production,
2004).

Growers
in
the
Northeast
and
South
are
more
likely
to
experience
yield
and
quality
losses
without
phosmet
than
California
producers
because
they
rely
more
heavily
on
phosmet.
A
longer
REI
may
prevent
necessary
hand
labor
activities,
which
would
compromise
fruit
quality.
Again,
production
costs
will
likely
increase
because
alternatives
are
more
costly,
would
have
to
be
applied
more
often,
or
would
result
in
applications
of
additional
pesticides
to
control
secondary
pests.

REQUEST
FOR
ADDITIONAL
INFORMATION
As
part
of
the
request
for
comments,
BEAD
would
welcome
data
that
could
be
used
to
refine
this
assessment,
if
necessary.
Useful
information
would
include:

 
usage
information
for
states
other
than
California;
 
particular
regional
or
pest
problems
leading
to
phosmet
use;
 
comparative
product
performance
data,
including
yield
and
quality
impacts;
 
relative
product
costs;
 
non­
chemical
alternatives,
efficacy
and
cost;
and
 
restrictions
or
other
constraints
on
the
use
of
alternatives.

REFERENCES
CDFA
(
California
Dept.
of
Food
and
Agriculture).
various
years.
Usage
of
Agricultural
Pesticides
in
California:
Pesticide
Usage
Report.
California
Department
of
Food
and
Agriculture,
Sacramento,
at
http://
www.
ipm.
ucdavis.
edu/
PUSE/
puse1.
html
.

Cook,
C.
and
T.
Kiely.
2001.
Initial
grape
benefits
assessment
for
azinphos­
methyl
and
phosmet.
Unpublished
EPA
report.

Crop
Profiles
for
Grapes
(
Wine)
in
California,
2002.
Web
address:
http://
www.
ipmcenters.
org/
cropprofiles/
docs/
cagrapes­
wine.
html
Crop
Profile
for
Lubrusca
(
Juice)
Grapes
in
Michigan,
2004.
Web
address:
http://
www.
ipmcenters.
org/
cropprofiles/
docs/
MIlabruscagrapes.
html
A
Pest
Management
Strategic
Plan
for
Winegrapes
in
California,
2004.
Web
address:
8
http://
www.
ipmcenters.
org/
pmsp/
pdf/
cawinegrapes.
pdf
A
Pest
Management
Strategic
Plan
for
Washington
State
Wine
Grape
Production,
2004.
Web
address:
http://
www.
ipmcenters.
org/
pmsp/
pdf/
WAWineGrapePMSP.
pdf
USDA
NASS.
2006.
Noncitrus
Fruits
and
Nuts,
2005
Preliminary
Summary.
National
Agricultural
Statistics
Service,
U.
S.
Department
of
Agriculture,
January,
at
http://
usda.
mannlib.
cornell.
edu/
reports/
nassr/
fruit/
pnf­
bb/
ncit0106.
pdf.

USDA
NASS.
various
years.
Agricultural
Chemical
Usage,
Fruit
Summary.
National
Agricultural
Statistics
Service,
U.
S.
Department
of
Agriculture,
at
http://
usda.
mannlib.
cornell.
edu/
reports/
nassr/
other/
pcu­
bb/#
fruits
USDA
NASS.
various
years.
Noncitrus
Fruits
and
Nuts,
Summary.
National
Agricultural
Statistics
Service,
U.
S.
Department
of
Agriculture,
July,
at
http://
usda.
mannlib.
cornell.
edu/
reports/
nassr/
fruit/
pnf­
bb/
