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
apricots
(
DP
#
296575)

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

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

TO:
Diane
Isbell,
Chemical
Review
Manager
Margaret
Rice,
Chief
Special
Review
and
Reregistration
Division
Product
Review
Panel:
April
5,
2006
Summary
EPA
is
considering
mitigation
strategies
to
address
concerns
for
workers
exposed
to
phosmet
following
applications
to
apricot
orchards.
This
is
a
preliminary,
qualitative
assessment
of
the
impact
of
extending
the
restricted
entry
interval
(
REI).

A
REI
greater
than
seven
days
would
interfere
with
crop
production
practices,
such
as
propping,
although
the
REI
for
hand­
harvest
could
be
extended
to
14
days
to
match
the
pre­
harvest
2
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,
or
would
result
in
applications
of
additional
pesticides
to
control
secondary
pests.
However,
given
the
low
usage
of
phosmet,
these
impacts
may
be
minor
and
would
not
affect
a
large
number
of
growers.

Background
Based
on
post­
application
worker
risk
assessments,
EPA
is
considering
mitigation
strategies,
including
extending
the
REI
for
phosmet
use
on
apricots.
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
apricot
producers
and
the
apricot
industry.

Apricots
The
most
recent
statistics
indicate
that
about
16,000
acres
of
apricots
are
grown
in
the
US
(
USDA
NASS,
2006).
Over
90%
of
the
acreage
is
in
California.
Utah
and
Washington
are
the
other
main
producing
states.
Acreage
has
been
declining
since
the
late
1990'
s,
but
average
yields
have
increased
to
almost
five
tons
per
acre.
Production
has
been
fairly
stable,
at
about
80,000
tons
annually
with
a
total
value
of
about
$
33.1
million.
Producer
prices
are
around
$
350/
ton
in
California,
but
are
much
higher
in
other
regions
of
the
country.

Recent
Use
of
Phosmet
According
to
data
from
the
California
Pesticide
Use
Reports,
phosmet
use
on
apricots
declined
rapidly
between
1999
and
2002,
from
over
18%
to
about
5%
of
the
crop
treated
(
CDFA,
various
years).
Use
has
remained
at
about
5%
for
the
past
several
years.
The
decline
in
phosmet
use
seems
to
be
due
to
growers
shifting
to
alternatives
because
of
concerns
about
OP
runoff
in
orchards
(
Pest
Management
Strategic
Plan
for
Peach
Production
in
California,
2003).
There
is
typically
a
single
application
per
year,
but
there
may
be
as
many
as
three.

Maximum
Feasible
REIs
The
2001
BEAD
assessment
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).
In
particular,
apricots
must
often
be
propped
to
prevent
limb
breakage
through
the
growing
season
as
fruit
size
increases.
Extension
of
the
phosmet
REI
beyond
seven
days
would
interfere
with
this
practice,
possibly
resulting
in
limb
breakage,
tree
injury,
and
fruit
loss.
3
Impacts
of
Extending
the
REI
Extending
the
REI
beyond
the
seven
days
for
activities
other
than
hand­
harvesting,
such
as
propping
for
late
varieties,
would
result
in
growers
shifting
to
one
of
several
available
alternatives
for
control
of
pests
targeted
by
phosmet.
These
pests
include
the
fruit
tree
leafroller,
green
fruitworm,
Oriental
fruit
moth,
and
peach
twig
borer.

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
pests
targeted
by
phosmet
are:
 
diazinon
and
malathion
(
organophosphates);
 
carbaryl
(
carbamate);
 
endosulfan
(
organochlorine);
 
cyfluthrin,
esfenvalerate,
lambda­
cyhalothrin,
and
gamma­
cyhalothrin
(
synthetic
pyrethroids);
 
diflubenzuron,
methoxyfenozide,
and
pyriproxyfen
(
insect
growth
regulators);
 
spinosad
(
actinomycete
derivative);
 
Bacillus
thuringiensis
(
biopesticide);
and
 
mating
disruption
(
pheromones).

Several
of
these
alternatives
provide
control
over
most
or
all
of
the
pests
controlled
by
phosmet.
Table
1
indicates
the
chemicals
that
are
registered
for
use
against
the
various
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.
Cost
may
be
indicative
of
relative
efficacy
and
phosmet
is
one
of
the
more
expensive
means
of
control.
This
may
also
explain
the
relatively
low
usage.
It
may
be
that
growers
who
use
phosmet
face
relatively
higher
pest
pressure
than
those
who
use
a
less
expensive
insecticide.
If
the
same
control
cannot
be
achieved
with
phosmet
alternatives,
growers
may
experience
yield
and/
or
quality
losses.
4
Table
1.
Registered
alternatives
and
efficacy
ratings
for
phosmet
target
pests
Fruit
tree
leafroller
Green
fruitworm
Oriental
fruit
moth4
Peach
twig
borer4
Cost
1
$/
acre
phosmet
E
x
G­
E
G
22.80
diazinon
G
x
G
G­
E
11.50
carbaryl
F
x
G
G
14.27
endosulfan
2
P
P
F­
G
cyfluthrin
2
x
x
x
gamma­
cyhalothrin
2
x
x
x
lambda­
cyhalothrin
E
x
9.60
esfenvalerate
P
x
G
G­
E
7.50
diflubenzuron
x
x
x
20.40
methoxyfenozide
x
x
x
x
16.50
pyriproxyfen
2
x
x
spinosad
x
x
x
x
27.50
Bacillus
thuringiensis
F­
G
x
P
G­
E
9.70
mating
disruption
3
P
E
F
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),
Atwood
and
Alsadek
(
2001),
and
CDMS
data
(
Efficacy
ratings:
E
=
excellent,
G
=
good,
F
=
fair,
P
=
poor,
x
=
efficacy
status
unclear).
1
EPA
proprietary
data,
based
on
California
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.

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
addition,
extension
of
the
REI
for
hand­
harvesting
beyond
14
days
may
lead
to
prophylactic
insecticide
applications
to
ensure
crop
protection
prior
to
harvest.

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.

Impacts
Because
a
REI
for
phosmet
beyond
seven
days
(
or
14
days
prior
to
harvest)
would
interfere
with
some
crop
production
practices,
such
as
propping
for
late
varieties,
growers
would
likely
stop
5
using
it
and
turn
to
one
or
more
of
several
available
alternatives
(
Atwood
and
Alsadek,
2001).
Based
on
recent
low
usage
of
phosmet
and
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
some
alternatives
are
more
costly,
would
have
to
be
applied
more
often,
or
would
result
in
applications
of
additional
pesticides
to
control
secondary
pests.
However,
given
the
low
usage
of
phosmet,
these
losses
may
be
minor
and
would
not
affect
a
large
number
of
growers.

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
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.
Initial
Apricot
Benefits
Assessment
for
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.

UC
Pest
Management
Guidelines.
2006.
Apricot.
University
of
California,
Statewide
Integrated
Pest
Management
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.
