UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
April
25,
2006
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Qualitative
impact
assessment
of
extensions
to
restricted
entry
intervals
for
phosmet
in
apples
(
DP
#
296575)

FROM:
Donald
W.
Atwood,
Entomologist
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

Stephen
Smearman,
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

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

Tim
Kiely,
Chief,
Acting
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

TO:
Diane
Isbell,
Chemical
Review
Manager
Margaret
Rice,
Chief
Reregistration
Branch
II
Special
Review
and
Reregistration
Division
Product
Review
Panel:
April
7,
2006
Summary
EPA
is
considering
mitigation
strategies
to
address
concerns
for
workers
exposed
to
phosmet
following
applications
to
apple
orchards.
This
is
a
preliminary,
qualitative
assessment
of
the
impact
of
extending
the
restricted
entry
interval
(
REI).
2
The
current
REI
for
apples
is
3
days
for
those
protected
by
the
Worker
Protection
Standards
(
WPS)
and
14
days
for
those
individuals
not
protected
by
the
WPS.
A
REI
greater
than
7
days
would
interfere
with
irrigation,
mowing,
limb
propping
and
hand
harvesting
activities
and
a
REI
greater
than
14
days
would
interfere
with
fire
blight
removal
activities.
If
a
REI
longer
than
3
days
is
imposed,
growers
would
have
to
replace
phosmet
with
one
or
more
of
several
available
alternatives.
BEAD
tentatively
concludes
that
no
yield
or
quality
losses
are
likely
if
growers
switch
to
alternative
insecticides.
Production
costs
would
likely
increase
by
2.5%
because
alternatives
are
more
costly
and
would
have
to
be
applied
more
often.

Background
Based
on
post­
application
worker
risk
assessments,
EPA
is
considering
mitigation
strategies,
including
extending
the
restricted
entry
interval
(
REI)
for
phosmet
use
on
apples.
The
current
REI
for
apples
is
3
days
for
those
protected
by
the
Worker
Protection
Standards
(
WPS)
and
14
days
for
those
individuals
not
protected
by
the
WPS
(
e.
g.,
pick
your
own
operations).
The
risk
assessment
for
apples
indicates
that
an
REI
of
13
days
would
be
necessary
to
reduce
risks
to
workers
below
the
Agency's
level
of
concern
at
the
use
rate
of
1.5lb
AI/
A.
At
the
use
rate
of
4
lb
AI/
A,
west
of
the
Rockies,
the
REI
necessary
to
reduce
worker
risks
to
that
below
the
Agency's
level
of
concern
would
be
28
days.
The
current
preharvest
interval
for
apples
is
7
days
as
a
stand
alone
spray
and
8
days
when
tank
mixed
with
methomyl.
For
operations
not
covered
by
WPS,
such
as
pick
your
own,
the
PHI
is
effectively
14
days
due
to
the
extended
REI.
The
purpose
of
this
assessment
is
to
provide
a
preliminary,
qualitative
assessment
of
the
impact
of
increasing
the
REI
to
13
and
28
days
on
apple
producers
and
the
apple
industry.

Apple
Production
The
most
recent
available
statistics
indicate
that
about
394,800
acres
of
apples
are
grown
in
the
U.
S.
(
USDA
NASS,
2005).
Washington
State
is
the
largest
producer
and
accounts
for
40%
of
the
acreage
in
production
followed
by
New
York
(
12%),
Michigan
(
11%),
California
(
7%)
and
Pennsylvania
(
5%).
Apples
are
grown
in
other
states
(
West
Virginia,
Ohio,
Maryland,
etc.
but
bearing
acreage
in
these
states
combined
does
not
exceed
5%
of
the
total
U.
S.
acreage.
Acreage
is
evenly
divided
between
the
eastern
and
western
regions
of
the
U.
S.
Washington
State
supplies
between
65­
75%
of
the
U.
S.
fresh
apple
market.
Acreage
has
been
declining
since
the
late
1990'
s,
but
average
yields
have
increased
from
about
11
tons
per
acre
on
average
to
almost
13
tons
per
acre
on
average
for
the
U.
S.
Production
has
been
fairly
stable,
at
about
10.4
billion
pounds
annually
with
a
total
value
of
about
$
1.629
billion.
Producer
prices
are
around
$
354
per
ton
on
average
for
both
fresh
and
processed
apples
nationally.

Recent
Use
of
Phosmet
Phosmet
is
applied
to
about
28%
of
the
U.
S.
apple
acreage
(
USDA/
NASS,
2004).
BEAD
proprietary
data
indicate
that
phosmet
use
on
apples
increased
between
1997
and
2004
from
over
18%
to
about
28%
of
the
crop
treated.
Use
has
remained
at
about
28%
for
the
past
several
years.
There
is
typically
a
single
application
per
year,
but
there
may
be
as
many
as
three
depending
upon
the
application
rate
and
pest
pressure.
Approximately
48%
of
the
eastern
apple
crop
is
3
treated
with
phosmet
while
approximately
15%
of
the
western
apple
crop
is
treated
with
phosmet.

Table
1.
Apple
Production,
Value,
and
Phosmet
Usage*
States
(
greater
than
7000
acres)
Acres
in
Production
Total
Production
(
million
pounds)
Production
as
a
Percentage
of
Total
US
Production
Total
Value
of
Production
(
1,000
dollars)
Phosmet
Usage
2003**
(
Percent
of
Crop
Treated)

California
28,000
390
3.7%
57,185
28%
Michigan
43,500
760
7.3%
90,480
69%
New
York
45,000
1,280
12.3%
193,560
42%
North
Carolina
7,000
155
1.5%
17,420
54%
Ohio
7,500
90
<
1%
24,831
Oregon
7,000
163
1.6%
26,057
26%
Pennsylvania
22,000
405
3.9%
40,353
37%
Washington
155,000
6,050
58.1%
962,458
12%
US
Total
394,800
10,419.9
1,629,071
28%
*
Sources:
USDA/
NASS
2005,
Noncitrus
Fruits
and
Nuts
2004
Summary.
**
USDA/
NASS
2004,
Agricultural
Chemical
Use
2003
Fruit
Summary
Maximum
Feasible
REIs
The
2001
BEAD
assessment
concluded
that
extension
of
REI's
to
levels
that
keep
workers
from
entering
fields
for
extended
periods
of
time
could
impact
a
grower's
ability
to
maintain
labor
crews
throughout
the
growing
season
(
Anderson
and
Keily,
2001).
It
also
could
severely
limit
the
amount
of
time
a
labor
crew
has
to
complete
necessary
orchard
activities
such
as
hand
thinning,
tree
training,
limb
propping,
summer
pruning
for
fire
blight,
and
hand
harvesting.
This
could
impact
growers
by
forcing
them
to
not
achieve
the
desired
results
from
those
activities.
If
field
activities
are
delayed
for
too
long
a
period
of
time
because
of
extended
REI's,
the
impact
on
the
fruit
could
be
quite
extensive
and
the
grower
may
also
lose
work
crews
to
other
growers
whom
can
provide
more
consistent
work.
Any
extension
of
the
apple
REI
beyond
7
days
could
force
growers
to
abandon
the
use
of
phosmet
on
apples
and
force
them
to
switch
to
one
of
the
other
registered
alternative
insecticides.

Impacts
of
Extending
the
REI
beyond
the
Maximum
Feasible
Length
Extending
the
REI
beyond
the
maximum
feasible
length
(
7
days)
would
result
in
growers
turning
to
one
of
several
available
alternatives
for
control
of
pests
targeted
by
phosmet.
The
primary
pests
targeted
for
control
with
phosmet
include
codling
moth,
plum
curculio,
apple
maggot,
and
oriental
fruit
moth.
Other
pests
that
may
be
controlled
with
phosmet
include
leafroller
species,
tarnished
plant
bug,
and
European
sawfly.

Alternatives
Alternatives
(
chemical
class)
for
control
of
these
pests
are:

 
azinphos­
methyl,
diazinon,
and
dimethoate
(
organophosphate);
4
 
acetamiprid,
imidacloprid,
thiacloprid
(
neonicotinoids)
 
indoxacarb
(
oxadiazine)
 
carbaryl
(
carbamate);
 
esfenvalerate,
fenpropathrin,
and
lambda­
cyhalothrin
(
synthetic
pyrethroids);
 
methoxyfenozide,
novaluron
(
where
registered),
pyriproxyfen,
and
tebufenozide
(
insect
growth
regulators);
 
mating
disruption
(
pheromones)
 
Kaolin
(
clay)

BEAD
believes
that
acetamiprid,
thiacloprid,
novaluron
and
methoxyfenozide
are
among
the
most
effective
and
promising
alternatives
to
phosmet.
BEAD
believes
that
growers
will
substitute
two
applications
of
neonicotinoids
and
two
applications
of
insect
growth
regulators
to
provide
season
long
control
of
the
pests
which
are
currently
controlled
with
phosmet.
Attachments
1
and
2
provide
comparative
insecticide
efficacy
for
pests
currently
targeted
for
control
with
phosmet
for
eastern
and
western
apple
production,
respectively.

Azinphos­
methyl
is
as
effective
as
phosmet
but
its
long
REI's
(
7­
14
days)
and
preharvest
intervals
(
14­
21
days)
severely
hamper
its
usefulness
as
an
alternative.
Additionally,
the
apple
use
of
azinphos­
methyl
is
currently
undergoing
reregistration
and
its
use
on
apples
may
be
further
restricted
in
the
near
future.
Some
of
the
alternatives,
such
as
pyrethroids,
are
less
compatible
with
integrated
pest
management
(
IPM)
and
mating
disruption
programs
than
is
phosmet.
Pyrethroids
often
precipitate
secondary
pest
outbreaks,
such
as
spider
mites,
and
cause
growers
to
resort
to
the
use
of
miticides,
which
may
cost
over
$
50
per
acre.

In
addition,
extension
of
the
REI
for
hand­
harvesting
beyond
7
days
may
lead
to
unnecessary
prophylactic
insecticide
applications
to
ensure
crop
protection
prior
to
harvest.

In
recent
years,
some
broad­
spectrum
insecticides,
such
as
organophosphates,
have
been
replaced
by
insecticides
with
a
narrower
activity
spectrum.
The
older
chemicals
not
only
controlled
the
target
pest(
s),
but
also
controlled
most
other
exposed
insects.
In
some
cases,
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
narrowerspectrum
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
the
potential
short­
term
(
2
to
3
years)
impacts
of
replacing
phosmet
with
insecticides
with
a
narrower
activity
spectrum.

Impacts
Because
an
REI
for
phosmet
beyond
7
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.
Based
on
the
availability
of
new
alternatives,
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.
5
BEAD's
alternative
scenario
of
substituting
two
applications
of
neonicitinoids
and
two
applications
of
insect
growth
regulators
for
the
typical
three
applications
of
phosmet
would
result
in
a
cost
increase
of
$
60
per
acre
($
45
for
phosmet
versus
$
105
for
the
alternatives)
which
is
equivalent
to
a
2.5%
increase
in
production
costs
(
Atwood
and
Smearman
2005,
Table
8).

Request
for
Additional
Information
in
Stakeholder
Comments
As
this
is
a
preliminary
assessment,
BEAD
would
welcome
data
that
could
be
used
to
refine
this
assessment
if
necessary.
Useful
information
would
include:

 
particular
regional
or
pest
problems
leading
to
phosmet
use;
 
comparative
product
performance
data,
including
yield
and
quality
impacts;
 
relative
product
costs;
and
 
restrictions
or
other
constraints
on
the
use
of
alternatives.
 
Information
on
the
feasibility
of
use,
comparative
efficacy,
and/
or
cost
of
use
of
nonchemical
alternatives
to
phosmet.

References
Atwood,
DW
and
S
Smearman.
2005.
2005
Grower
Impact
Assessment
of
Azinphos­
methyl
Use
in
Apples
(
DP307589).
Biological
and
Economic
Analysis
Division,
Office
of
Pesticide
Programs,
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Ave.,
NW,
Washington,
DC
20460­
0001
Brunner
JF,
Beers
EH,
Dunley
JE,
Doerr
M,
Granger
K.
2005.
Role
of
neonicotinyl
insecticides
in
Washington
apple
integrated
pest
management.
Part
I.
Control
of
lepidopteran
pests.
10pp.
Journal
of
Insect
Science,
5:
14,
Available
online:
http://
www.
insectscience.
org/
5.14/
Brunner_
et_
al_
JIS_
5_
14_
2005.
pdf
[
Contains
efficacy
data
from
33
heavily
infested
apple
orchards
in
Washington.
In
these
efficacy
tests,
the
grower
standard
(
azinphos­
methyl
and/
or
phosmet)
provided
significantly
better
control
of
codling
moth
than
acetamiprid
in
20
out
of
33
trials.
Azinphos­
methyl
averaged
94%
control
in
these
trials
compared
to
82%
control
achieved
by
acetamiprid
and
71%
control
achieved
by
thiacloprid.]

Anderson,
N
and
T
Kiely,
2001.
Biological
and
Economic
Analysis
of
AZM
and
Phosmet
on
Apples.
Biological
and
Economic
Analysis
Division,
Office
of
Pesticide
Programs,
Environmental
Protection
Agency
20460.
www.
epa.
gov/
oppsrrd1/
op/
azinphos/
bead_
Pears1.
pdf
Crop
Data
Management
System.
2006.
ChemSearch
Database.
6
Doerr,
M.,
J.
Brunner,
E.
Beers,
J.
Dunley,
and
V.
Jones.
2004.
Building
a
multi­
tactic
pheromone
based
pest
management
system
in
western
orchards.
Unpublished
Progress
Report.
Tree
Fruit
Research
and
Extension
Center,
Wenatchee,
WA
[
Contains
efficacy
data
from
15
operational
apple
orchards
using
mating
disruption
in
Washington.
In
these
efficacy
tests,
the
grower
standard
(
azinphos­
methyl
and/
or
phosmet)
provided
levels
codling
moth
control
equivalent
to
those
seen
in
methoxyfenozide
and
other
selective/
non­
organophosphate
insecticides.]

USDA/
NASS,
2004.
Agricultural
Chemical
2003
Fruit
Summary.
http://
usda.
mannlib.
cornell.
edu/
reports/
nassr/
other/
pcu­
bb/
agcf0804.
pdf
USDA/
NASS.
2005.
Noncitrus
Fruits
and
Nuts
2004
Summary.
NASS/
USDA
http://
usda.
mannlib.
cornell.
edu/
reports/
nassr/
fruit/
pnf­
bb/
ncit0106.
pdf
.
7
Attachment
1.
Comparative
Efficacy
of
Phosmet
Alternatives
for
Eastern
Apple
Production
Available
Alternatives
and
Efficacy
Rating1
From
2003
Pest
Management
Strategic
Plan
for
Mid
Atlantic
Apples
and
New
England
Apples
From
Efficacy
Data
Submitted
by
Bayer
Insecticide
Codling
Moth
Oriental
Fruit
Moth
Plum
Curculio
Apple
Maggot
Codling
Moth
Oriental
Fruit
Moth
Plum
Curculio
Apple
Maggot
Azinphos
methyl
E
G­
E
E
G­
E
G­
E
G­
E
E
F­
G
Phosmet
E
G­
E
G
G­
E
Thiacloprid
F­
G
G
F­
G2
F­
G2
F­
G2
F­
G
Imidacloprid
F­
G
F­
G
F­
G
P
Acetamiprid
G
G
G
G1
G1
G1
G
Thiamethoxam
P
P
G
F
F
G
Indoxocarb
G
G
G
F­
G
F­
G2,3
F­
G2,3
E
Spinosad
F
F
F
F­
G
P­
F
P­
F
P­
F
Tebufenozide
F
F
F
P­
F
P­
F
P­
F
Methoxyfenozide
G
G
G2
G2
G2
Clothianidin
P­
F
P­
F
P­
F
P
Azadirachtin
F­
G
F
F
Kaolin
P­
F
F
F
F­
G
F­
G
F­
G
G
Esfenavalerate
G­
E
G­
E
G­
E
G­
E
P­
F
P­
F
P­
F
Bti
F
F
F
Carbaryl
F­
G
F­
G
F­
G
G
Fenpropathrin
E
E
G
G­
E
Diazinon
G
G
G
G
Dimethoate
G
G
G
G
Gamma
Cyhalothrin
F
F
F
Lambda
Cyhalothrin
E
E
G
G­
E
Pyriproxyfen
Novaluron
G2,3
G2,3
G2,3
1Efficacy
ratings:
E=
Excellent,
G=
Good,
F=
Fair,
P=
Poor/
None,
X=
no
data
2
Higher
Rates
perform
better
3
Timing
of
application
critical
to
control
8
Attachment
2.
Comparative
Efficacy
of
Phosmet
Alternatives
for
Western
Apple
Production
Available
Alternatives
and
Efficacy
Rating1
Insecticide
Codling
Moth
(
WSU
2005
Crop
Protection
Guide)
Codling
Moth
(
Bayer
Submission)
Apple
Maggot
(
OSU
PNW
Insect
Management
Handbook)

Abamectin
X
Acetamiprid
E
P­
G
Azadirachtin
X
Azinphos
methyl
E
G­
E
R
Bacillus
thuringiensis
P
Carbaryl
F
Diazinon
F
Dimethoate
F
Endosulfan
P
Gamma­
cyhalothrin
X
Mineral
oil
G
Imidacloprid
X
Indoxacarb
F­
P
Kaolin2
F
F
Lambda­
cyhalothrin
E
Methomyl
X
Methoxyfenozide
G
Oxamyl
X
Pheromone
P­
E
Phosmet
G­
E
R
Pyriproxyfen
G
Spinosad
F­
G
P­
F
Tebufenozide
F­
G
F
Thiacloprid
E
F­
G
Novaluron
F­
G
1
Efficacy
ratings:
E=
Excellent,
G=
Good,
F=
Fair,
P=
Poor/
None,
X=
no
data,
R=
Recommended,
no
efficacy
data
suppled
2
Must
be
applied
as
often
as
needed
to
maintain
coverage.
