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
peaches
and
nectarines
(
DP
#
296575)

FROM:
T
J
Wyatt,
Agricultural
Economist
Economic
Analysis
Branch
Angel
Chiri,
Entomologist
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

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

TO:
Diane
Isbell,
Chemical
Review
Manager
Margaret
Rice,
Chief
Reregistration
Branch
2
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
peach
and/
or
nectarine
orchards.
This
is
a
preliminary,
qualitative
assessment
of
the
impact
of
extending
the
restricted
entry
interval
(
REI).
2
A
REI
greater
than
seven
days
would
interfere
with
crop
production
practices,
such
as
thinning,
although
the
REI
for
hand­
harvest
could
be
extended
to
14
days
to
match
the
pre­
harvest
interval.
If
a
longer
REI
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
an
alternative.
Production
costs
would
likely
increase
because
alternatives
are
more
costly,
would
have
to
be
applied
more
often
to
achieve
similar
control,
or
would
result
in
applications
of
additional
pesticides
to
control
secondary
pests.

Background
Based
on
post­
application
worker
risk
assessments,
EPA
is
considering
mitigation
strategies,
including
extending
the
REI
for
phosmet
use
on
these
crops.
The
risk
assessment
indicates
that
an
REI
of
24
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
this
strategy
on
peach
and
nectarine
producers
and
the
peach
and
nectarine
industry.

Peaches
and
Nectarines
Peaches
and
nectarines
are
varieties
of
Prunus
persica,
a
tree
native
to
China.
The
same
pests
attack
the
fruit,
and
growers
use
essentially
the
same
chemical
and
non­
chemical
control
practices.
Therefore,
BEAD
considers
the
two
crops
together
in
this
memo.

The
most
recent
statistics
indicate
that
about
140,000
acres
of
peaches
are
grown
in
the
US
(
USDA
NASS,
2006).
California
accounts
for
almost
half
of
the
peach
acreage
and
about
threefourths
of
production.
South
Carolina
and
Georgia
are
the
other
main
peach
producers
with
about
five
percent
of
production
each.
Peach
acreage
has
been
declining
since
the
late
1990'
s.
Production
has
also
declined
and
is
currently
about
1.25
million
tons
annually
with
a
total
value
of
over
$
500
million.
Producer
prices
are
around
$
280/
ton
in
California,
which
has
a
high
proportion
of
clingstone
peaches
for
processing,
but
are
higher
in
other
regions
of
the
country
where
freestone
varieties
are
dominant.
Table
1
provides
peach
acreage,
production
and
value
information
for
key
regions
of
the
country.
3
Table
1.
Peach
acreage,
production
and
value,
2001
 
2005
average.
Region
Bearing
Acres
Production
(
1000
tons)
Yield
(
tons/
acre)
Value
($
1000)
Price
($/
ton)
California
67,440
923.3
13.7
259,082
280
South
1
34,790
144.7
4.2
85,279
590
Northeast
2
24,470
109.3
4.5
81,114
740
Other
3
18,480
66.9
3.6
53,867
805
U.
S.
145,190
1,244.1
8.6
479,343
385
Source:
Noncitrus
Fruits
and
Nuts
Summary
(
USDA
NASS,
various
years).
1
Alabama,
Georgia,
Louisiana,
North
Carolina,
South
Carolina,
Tennessee,
Virginia,
and
West
Virginia.
2
Connecticut,
Illinois,
Indiana,
Kentucky,
Maryland,
Massachusetts,
Michigan,
New
Jersey,
New
York,
Ohio,
and
Pennsylvania.
3
Arkansas,
Colorado,
Idaho,
Missouri,
Oklahoma,
Oregon,
Texas,
Utah,
and
Washington.

NASS
statistics
indicate
almost
40,000
acres
of
nectarines
grown
in
the
U.
S.,
most
of
which
are
located
in
California.
Between
2001
and
2005,
production
averaged
about
273,300
tons
for
an
annual
value
of
about
$
116.7
million.
Nectarines
yield
slightly
lower
than
peaches,
at
about
7.4
tons
per
acre,
and
command
a
price
of
about
$
425/
ton.

Recent
Use
of
Phosmet
According
to
data
from
the
California
Pesticide
Use
Reports,
phosmet
use
on
peaches
has
remained
fairly
steady
between
1999
and
2003,
at
just
over
20%
of
the
crop
treated
(
CDFA,
various
years).
Use
on
nectarines
is
higher,
at
about
40%
over
the
same
period.
This
difference
may
be
due
to
the
fact
that
nectarines
are
typically
grown
for
the
fresh
market.
Slightly
more
than
half
of
California
peach
production
is
clingstone,
which
is
grown
for
the
processed
market.
If
phosmet
is
primarily
used
on
freestone
varieties,
the
percent
of
acres
treated
with
phosmet
would
be
similar
to
that
of
nectarines.
There
is
typically
a
single
application
per
year,
but
there
may
be
as
many
as
three.
Average
application
rate
is
about
3.1
lb
phosmet/
acre
per
year
in
both
peaches
and
nectarines.

NASS
statistics
report
chemical
use
in
select
states
over
the
same
period
(
USDA
NASS,
various
years).
Table
2
presents
this
information
for
phosmet
used
on
peaches.
Usage
is
greatest
in
the
south,
with
nearly
two­
thirds
of
peach
acreage
treated
with
phosmet.
Usage
decreases
as
one
moves
northward.
Phosmet
does
not
appear
particularly
important
in
more
westerly
areas,
including
Texas
and
the
Pacific
Northwest.
Frequency
of
application
is
higher
in
the
South
as
well,
with
Georgia
and
South
Carolina
producers
averaging
five
or
six
applications
per
year.
In
the
Northeast,
average
frequency
is
two
to
three
per
year.
On
average,
growers
use
a
rate
of
about
1.3
lb
phosmet/
acre
per
application.
4
Table
2.
Phosmet
usage
on
peaches,
1999
 
2003.
Region
Bearing
Acres
1
%
Acres
Treated
Acres
Treated
lb
Phosmet
Applied
Rate
(
lb/
acre/
year)
California
76,430
23.0
17,540
54,170
3.1
South
2
32,880
66.4
21,830
119,230
5.5
Northeast
3
18,950
35.7
6,760
18,250
2.7
Other
4
9,750
3.8
370
1,700
4.6
U.
S.
130,280
35.5
46,220
189,970
4.1
Source:
Agricultural
Chemical
Usage,
Fruit
Summary,
various
years
(
USDA
NASS)
1
Bearing
acres
are
not
the
same
as
in
the
production
summary
due
limited
states
sampled
and
to
different
sampling
techniques.
U.
S.
totals
are
different
from
the
sum
of
the
columns
because
not
all
states
are
sampled
each
year,
leading
to
differences
in
averages.
2
Georgia,
North
Carolina,
and
South
Carolina.
3
Michigan,
New
Jersey,
New
York,
and
Pennsylvania.
4
Texas
and
Washington.

Phosmet
usage
may
be
increasing
in
the
past
several
years
as
use
of
azinphos­
methyl
(
AZM)
is
restricted,
as
they
are
both
broad­
spectrum
organophosphates
that
may
target
similar
pests.
AZM
use
has
been
very
low
in
California,
but
it
has
been
an
important
insecticide
in
much
of
the
rest
of
the
country.
Table
3
provides
information
on
AZM
usage
for
peaches.
The
typical
AZM
user
in
the
U.
S.
applies
it
to
peaches
about
four
times
per
year,
indicating
average
an
average
rate
of
0.6
lb/
acre
per
application.
As
with
peaches,
use
of
AZM
on
nectarines
in
California
is
very
low.

Table
3.
Azinphos­
methyl
usage
on
peaches,
1999
 
2003.
Region
Bearing
Acres
1
%
Acres
Treated
Acres
Treated
lb
AZM
Applied
Rate
(
lb/
acre/
year)
California
2
80,780
1.3
1,060
1,730
1.6
South
3
32,880
20.1
6,610
15,300
2.3
Northeast
4
18,950
62.5
11,850
32,680
2.8
Other
5
9,750
36.0
3,510
4,300
1.2
U.
S.
130,280
15.2
19,830
48,970
2.5
Source:
Agricultural
Chemical
Usage,
Fruit
Summary,
various
years
(
USDA
NASS)
1
Bearing
acres
are
not
the
same
as
in
the
production
summary
due
limited
states
sampled
and
to
different
sampling
techniques.
U.
S.
totals
are
different
from
the
sum
of
the
columns
because
not
all
states
are
sampled
each
year,
leading
to
differences
in
averages.
2
California
data
from
California
Pesticide
Use
Reports,
which
imply
larger
acreage
than
NASS
statistics.
3
Georgia,
North
Carolina,
and
South
Carolina.
4
Michigan,
New
Jersey,
New
York,
and
Pennsylvania.
5
Texas
and
Washington.

To
the
extent
that
phosmet
is
the
most
likely
alternative
to
AZM,
the
importance
of
phosmet,
in
terms
of
acres
treated
and
amount
applied,
is
likely
to
increase
in
the
immediate
future.

Maximum
Feasible
REIs
5
The
2001
BEAD
assessments
for
peaches
and
nectarines
concluded
that
extending
the
REI
for
hand
harvesting
to
14
days,
equivalent
to
the
pre­
harvest
interval
(
PHI),
would
not
result
in
grower
impacts.
However,
within
the
season,
the
maximum
REI
that
would
not
interfere
with
orchard
activities
is
around
seven
days
(
Atwood
and
Alsadek,
2001;
Gross
and
Alsadek,
2001).
In
particular,
peaches
and
nectarines
must
be
thinned,
preferably
by
hand,
to
guarantee
that
fruit
growth
is
consistent
with
fresh
market
standards.
Extension
of
phosmet
REI
=

s
beyond
seven
days
would
interfere
with
this
practice.

Impacts
of
Extending
the
REI
Beyond
the
Maximum
Feasible
Length
Extending
the
REI
beyond
the
maximum
acceptable
(
seven
days
for
in
season
production
activities,
14
days
for
hand
harvesting)
would
result
in
growers
turning
to
one
of
several
available
alternatives
for
control
of
pests
targeted
by
phosmet.
These
pests
include
the
Oriental
fruit
moth,
peach
twig
borer,
and
the
plum
curculio.

Phosmet
is
a
broad­
spectrum
insecticide
and
may
be
controlling
a
number
of
secondary
insects
that
BEAD
has
not
identified.
Use
of
alternatives
that
have
a
more
narrow
range
of
activity
may
result
in
populations
of
these
pests
increasing
to
damaging
levels.

Alternatives
Alternatives
for
control
of
these
pests
are:
 
chlorpyrifos,
diazinon,
malathion,
naled,
methidathion
(
organophosphates);
 
carbaryl,
methomyl
(
carbamates);
 
endosulfan
(
organochlorine);
 
cyfluthrin,
esfenvalerate,
gamma­
cyhalothrin,
lambda­
cyhalothrin,
permethrin
(
synthetic
pyrethroids);
 
diflubenzuron,
methoxyfenozide,
and
pyriproxyfen
(
insect
growth
regulators);
 
imidacloprid,
thiamethoxam
(
neonicotinoids)
 
spinosad
(
actinomycete
derivative);
 
Bacillus
thuringiensis
(
biopesticide);
and
 
mating
disruption
(
pheromones).

Table
4
indicates
the
chemicals
that
are
registered
for
use
against
the
various
pests,
their
efficacy
ratings
and
typical
cost
per
acre.
Some
of
these
alternatives
may
provide
adequate
control
over
most
or
all
of
the
pests
controlled
by
phosmet.
However,
these
alternatives
may
not
be
as
efficacious
as
phosmet
and
could
require
more
than
one
application
to
achieve
the
same
level
of
control.
This
may
be
particularly
true
of
the
plum
curculio,
which
is
a
significant
pest
in
the
eastern
U.
S.
If
the
same
control
cannot
be
achieved,
growers
may
experience
yield
and/
or
quality
losses.
In
other
situations,
growers
may
have
to
use
multiple
chemicals
if
they
face
multiple
pests.
6
Table
4.
Available
alternatives
and
efficacy
ratings
for
phosmet
target
pests1
Oriental
fruit
moth
Peach
twig
borer
Plum
Curculio
Cost
2
$/
acre
phosmet
G­
E
G
E
9
 
12
chlorpyrifos
G
G­
E
G­
E
11
 
18
diazinon
G
G­
E
F
6
 
15
naled
3
P
G­
E
NR
malathion
x
x
x
3
 
4
methidathion
NR
E
NR
28
carbaryl
G
G
F­
G
13
 
23
methomyl
F­
G
F­
G
NR
9
 
12
endosulfan
P­
E
F­
G
NR
9
 
22
pyrethrins
3
G
E
NR
cyfluthrin
3
x
x
x
esfenvalerate
G
G­
E
F­
G
3
 
9
gamma­
cyhalothrin
3
x
x
x
lambda­
cyhalothrin
E
x
F­
G
8
permethrin
G
G
F­
G
8
 
10
diflubenzuron
x
x
NR
20
methoxyfenozide
x
x
NR
22
pyriproxyfen
3
x
x
NR
imidacloprid
NR
NR
x
10
thiamethoxam
3
NR
NR
G­
E
spinosad
x
x
NR
24
 
29
Bacillus
thuringiensis
P
G­
E
NR
9
 
10
Pheromones
(
mating
disruption)
E
F
NR
Source:
UC
Pest
Management
Guidelines
(
2006),
Pest
Management
Strategic
Plan
for
Nectarine
Production
in
California
(
2003),
Pest
Management
for
Strategic
Plan
for
Peach
Production
in
California
(
2003),
Pest
Management
Strategic
Plan
for
Eastern
Peaches
(
2003),
and
CDMS
data.
1
Efficacy
ratings:
E
=
excellent,
G
=
good,
F
=
fair,
P
=
poor,
x
=
efficacy
status
unclear,
NR
=
not
registered
for
this
use.
2
Cost
information
from
EPA
proprietary
data;
2001­
2004
average
chemical
cost
for
treatment
of
target
pest.
Range
results
from
differences
in
cost
between
regions.
3
Insufficient
usage
to
determine
cost.

A
simple
comparison
of
costs
may
not
be
the
only
factor
in
selecting
a
pesticide.
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
pests
outbreaks,
such
as
spider
mites,
and
cause
growers
to
resort
to
the
use
of
miticides,
which
may
cost
over
$
50
per
acre.

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
7
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.

Impacts
Because
a
REI
for
phosmet
beyond
seven
days
(
or
14
days
prior
to
harvest)
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
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
alternative
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:

 
particular
regional
or
pest
problems
leading
to
phosmet
use;
 
timing
of
applications
and
critical
orchard
activities;
 
comparative
product
performance
data,
including
yield
and
quality
impacts;
 
relative
product
costs;
 
non­
chemical
control
methods,
efficacy
and
cost;
and
 
restrictions
or
other
constraints
on
the
use
of
alternatives.

References
A
Pest
Management
Strategic
Plan
for
Nectarine
Production
in
California.
2003.
http://
www.
ipmcenters.
org/
pmsp/
pmsp_
form.
cfm?
usdaregion=
National%
20Site
A
Pest
Management
Strategic
Plan
for
Peach
production
in
California.
2003.
http://
www.
ipmcenters.
org/
pmsp/
pmsp_
form.
cfm?
usdaregion=
National%
20Site
Atwood,
D.
and
J.
Alsadek.
2001.
Nectarine
Initial
Benefits
Assessment
for
Azinphos­
methyl
and
Phosmet.
Unpublished
EPA
report.

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
.

Crop
Data
Management
System.
2006.
ChemSearch
Database.

Crop
Profile
for
Nectarines
in
California.
2001.
Web
site:
http://
www.
ipmcenters.
org/
cropprofiles/
docs/
canectarines.
html
8
Crop
Profile
for
Peaches
in
California.
1999.
Web
site:
http://
www.
ipmcenters.
org/
cropprofiles/
docs/
capeaches.
html
Crop
Profile
for
Peaches
in
Georgia
and
South
Carolina.
2003.
Web
site:
http://
www.
ipmcenters.
org/
cropprofiles/
docs/
GASCpeaches.
html
Gross,
W.
and
J.
Alsadek.
Peach
Initial
Benefits
Assessment
for
Azinphos­
methyl
and
Phosmet.
Unpublished
EPA
report.

Pest
Management
Strategic
Plan
for
Eastern
Peaches.
2003.
Web
site:
http://
www.
ipmcenters.
org/
pmsp/
pmsp_
form.
cfm?
usdaregion=
National%
20Site
UC
Pest
Management
Guidelines.
2006.
Nectarines.
University
of
California,
Statewide
Integrated
Pest
Management.
Web
site:
http://
www.
ipm.
ucdavis.
edu/
PMG/
selectnewpest.
nectarine.
html
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/
