1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
April
27,
2006
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Qualitative
impact
assessment
of
extensions
to
restricted
entry
intervals
for
phosmet
in
plums
and
prunes
(
DP
#
296575)

FROM:
Nikhil
Mallampalli,
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,
Chief,
Acting
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

TO:
Diane
Isbell,
Chemical
Review
Manager
Margaret
Rice,
Chief
Reregistration
Branch
Two
Special
Review
and
Reregistration
Division
(
7508C)

Product
Review
Panel
date:
April
7,
2006
Summary
EPA
is
considering
mitigation
strategies
to
address
concerns
for
workers
exposed
to
phosmet
following
applications
to
plum
and
prune
orchards.
This
is
a
preliminary,
qualitative
assessment
of
the
impact
of
extending
the
restricted
entry
interval
(
REI).
2
California,
the
major
producer
of
plums
and
prunes,
has
established
a
five­
day
REI
for
phosmet
in
stone
fruit.
A
REI
greater
than
five
days
would
likely
interfere
with
key
mid­
season
crop
production
practices,
such
as
propping
up
fruit­
laden
tree
limbs
to
avoid
breakage.
A
REI
of
seven
days,
equivalent
to
the
pre­
harvest
interval
(
PHI)
would
accommodate
hand
harvesting
and
permit
an
application
of
phosmet
to
protect
fruit
from
insect
damage
immediately
prior
to
harvest.

If
a
longer
REI
is
imposed,
growers
would
have
to
replace
phosmet
with
one
or
more
of
several
available
alternatives.
BEAD
tentatively
concludes,
as
it
did
in
2001,
that
no
large
yield
or
quality
losses
are
likely
if
the
alternatives
are
used
in
place
of
phosmet.
However,
production
costs
would
likely
increase
as
alternatives
may
be
more
expensive,
require
multiple
applications
to
control
target
pests,
and
may
necessitate
additional
pesticide
applications
to
control
secondary
pests.
As
this
is
a
preliminary
assessment,
and
only
limited
data
are
immediately
available,
BEAD
has
not
quantified
the
magnitude
of
these
costs.
Additional
information
is
requested
on
relative
efficacy
and
other
pest
management
aspects
that
would
help
refine
this
assessment.

Background
Based
on
post­
application
worker
risk
assessments,
EPA
is
considering
mitigation
strategies,
including
extending
the
restricted
entry
interval
(
REI)
for
phosmet
use
on
plums
and
prunes.
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
plum
and
prune
producers
and
the
plum
and
prune
industry.

Plums
and
Prunes
Plums
and
plums
grown
for
prune
are
typically
distinct
varieties
with
different
production
practices
although
the
trees
themselves
are
quite
similar
and
suffer
from
similar
pests.
The
most
recent
statistics
indicate
that
about
110,000
acres
of
plums
and
prunes
are
grown
in
the
US
(
USDA
NASS,
2006).
Over
95%
of
the
acreage
is
in
California,
of
which
about
two­
thirds
is
in
prune
varieties.
The
Pacific
Northwest
and
Michigan
are
the
other
main
producers.
Acreage
and
production
have
been
declining
since
the
late
1990'
s.
Over
the
last
five
years,
production
has
averaged
about
320,000
tons
annually
with
a
total
value
of
about
$
197
million.
Producer
prices
average
around
$
610/
ton,
but
prices
tend
to
be
lower
outside
California.
Table
1
provides
information
on
acreage,
production
and
value
for
the
main
producing
states.

Table
1.
Plum
and
prune
acreage,
production
and
value,
2001
 
2005
average.
Region
Bearing
Acres
Production
(
1000
tons)
Yield
Value
($
1000)
Price
($/
ton)
California
110,000
307.2
2.8
192,011
625
plum
36,200
187.0
5.2
79,564
425
prune
1
73,800
120.2
1.6
112,447
935
Pacific
Northwest
2
3,190
13.2
4.1
4,263
325
Michigan
780
2.3
2.9
730
355
3
U.
S.
113,970
322.6
2.8
197,361
610
Source:
Noncitrus
Fruits
and
Nuts
Summary
(
USDA
NASS,
various
years).
1
Prune
production
and
yield
measured
on
a
dried
basis.
2
Idaho,
Oregon,
and
Washington.

Recent
Use
of
Phosmet
According
to
data
from
the
California
Pesticide
Use
Reports,
phosmet
use
on
prunes
has
been
negligible
between
1999
and
2004,
averaging
less
than
one
percent
of
the
crop
acreage
treated
(
CDFA,
various
years).
Use
on
plums
has
remained
fairly
steady
at
about
25%
of
the
crop
acreage
treated
during
the
same
period.
There
is
typically
a
single
application
per
year
on
plums,
but
there
may
be
as
many
as
three.
About
29,400
lb
of
phosmet
are
used
annually
for
an
application
rate
of
about
3.3
lb/
acre
per
year.

USDA
NASS
has
not
published
chemical
usage
data
for
other
states.

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
target
similar
pests.
However,
AZM
has
not
been
used
much
in
California
plums
or
prunes,
with
only
two
percent
of
plum
acreage
treated
and
0.3%
of
prunes.
There
are
no
publicly
reported
data
on
usage
for
other
states.

Maximum
Currently
Feasible
REIs
BEAD
previously
assessed
this
issue
(
Atwood
and
Alsadek,
2001).
Important
worker
activities
corresponding
to
phosmet
use
include
a
second
fruit
thinning
for
those
orchards
that
need
it,
propping
of
tree
limbs
to
prevent
breakage,
and
hand
harvesting.
Fruit
thinning
could
be
managed
with
14­
day
intervals
and
the
current
pre­
harvest
interval
(
PHI)
of
seven
days
allows
growers
to
use
phosmet
and
hand
harvest.
However,
propping
limbs
often
requires
re­
entry
at
intervals
as
small
as
five
days,
and
this
activity
may
occur
throughout
the
season.
BEAD
has
not
located
any
information
to
suggest
that
the
pattern
of
worker
activities
or
the
timing
of
phosmet
applications
has
changed
since
2001
for
either
plums
or
prunes.
Therefore,
BEAD
tentatively
concludes
that
an
REI
greater
than
five
days
would
affect
some
growers
and
that
most
growers
would
stop
using
phosmet
if
its
REI
were
greater
than
seven
days,
as
that
would
interfere
with
frequent
hand
harvest.
California,
the
dominant
producer
of
plums
and
prunes,
currently
has
a
five­
day
REI
in
place.

Impacts
of
Extending
REIs
Beyond
the
Maximum
Feasible
Length
Extending
the
REI
beyond
the
maximum
number
of
days
(
described
above)
would
result
in
growers
turning
to
one
of
several
available
alternatives
for
control
of
pests
targeted
by
phosmet.
In
the
West,
including
California,
the
Pacific
Northwest
and
smaller
producing
states
like
Colorado
and
Utah,
these
pests
include
the
citrus
cutworm,
codling
moth,
peach
twig
borer,
and
oriental
fruit
moth.
In
the
East,
including
Michigan
as
well
as
many
small
producing
states
throughout
the
northeast
and
southeast,
phosmet
is
used
to
control
the
plum
curculio
and
apple
maggot
(
Atwood
and
Alsadek,
2001).
4
Alternatives
Atwood
and
Alsadek
(
2001)
identified
the
following
alternatives
for
the
West:
AZM,
Bacillus
thuringiensis
(
Bt),
carbaryl,
permethrin,
esfenvalerate,
methidathion,
dormant
oil
(
with
or
without
chlorpyrifos,
diazinon
or
esfenvalerate),
methomyl,
and
mating
disruption
(
for
the
oriental
fruit
moth
only).
AZM
is
no
longer
an
option
and
use
of
other
organophosphates
may
be
constrained
by
regulatory
restrictions.
In
addition,
several
materials
have
been
registered
including
methoxyfenozide
(
labeled
for
`
control'
of
codling
moth,
oriental
fruit
moth,
and
peach
tree
borer),
pyriproxyfen
(
only
for
`
suppression'
of
oriental
fruit
moth
and
peach
tree
borer),
spinosad
(
controls
oriental
fruit
moth,
peach
tree
borer,
and
citrus
cutworm).

According
to
EPA
proprietary
data,
some
alternatives,
like
Bt
and
esfenvalerate,
are
substantially
cheaper
than
phosmet.
However,
their
use
may
require
multiple
applications
to
achieve
similar
control
over
the
pests.
Carbaryl,
chlorpyrifos
and
methoxyfenozide
are
priced
similarly
to
phosmet,
while
methidathion
and
spinosad
are
substantially
more
expensive.

In
the
eastern
US
region,
Atwood
and
Alsadek
(
2001)
identified
esfenvalerate
and
AZM
as
the
most
likely
alternatives
for
plum
curculio
and
AZM
as
the
only
recommended
alternative
for
the
apple
maggot.
Currently,
spinosad
is
available
for
the
control
of
the
apple
maggot
and
two
neonicotinoids,
imidacloprid
and
thiamethoxam,
are
available
to
control
the
plum
curculio.
However,
imidacloprid
is
labeled
only
for
`
suppression'
and
may
have
limited
efficacy.

EPA
proprietary
data
indicate
that
esfenvalerate
is
less
expensive
than
phosmet.
BEAD
does
not
have
efficacy
data,
but
it
may
require
multiple
applications
to
achieve
the
same
level
of
control
over
the
target
pests.
Imidacloprid
does
not
appear
to
be
widely
used
for
these
pests,
but
is
priced
comparably
to
phosmet,
although
it
probably
does
not
result
in
the
same
level
of
control.
Spinosad
and
thiamethoxam
are
substantially
more
expensive
products.

In
other
crops,
novaluron
and
thiacloprid
have
shown
good
efficacy
against
some
of
the
key
caterpillar
pests
and
plum
curculio,
but
these
materials
are
not
yet
registered
on
stone
fruit.
Regarding
alternatives
in
general,
BEAD
notes
that
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
5
Atwood
and
Alsadek
(
2001)
determined
that
extending
the
phosmet
REI
beyond
five
days
would
likely
cause
growers
to
switch
to
some
combination
of
alternatives,
so
as
to
keep
worker
activities
such
as
propping
of
tree
limbs
on
schedule.
No
yield
or
quality
losses
were
expected,
but
outbreaks
of
secondary
pests,
such
as
mites,
were
likely,
especially
with
a
synthetic
pyrethroid
like
esfenvalerate.

BEAD
believes
that
a
seven­
day
REI
may
still
permit
the
use
of
phosmet
for
control
of
pests
in
the
critical
pre­
harvest
period.
However,
a
REI
longer
than
five
days
would
conflict
with
other
orchard
activities
and
lead
growers
to
switch
to
an
alternative
chemical.
While
AZM
is
no
longer
available
as
an
alternative,
the
presence
of
new
alternatives
leads
BEAD
to
again
conclude
that
large
yield
and
quality
losses
are
unlikely
if
growers
do
not
use
phosmet.
Some
growers
may
also
be
able
to
adapt
the
schedule
of
worker
activities
to
incorporate
a
longer
REI,
though
this
is
probably
unlikely.

Production
costs
would
likely
increase
if
growers
substitute
alternatives
to
phosmet
for
the
control
of
target
pests.
Some
alternatives
are
more
expensive,
some
may
require
multiple
applications
and
some
could
necessitate
additional
pesticide
applications
measures
to
control
secondary
pest
outbreaks.
BEAD
does
not
have
sufficient
efficacy
data
at
this
time
to
quantify
these
impacts.

Request
for
Additional
Information
in
Stakeholder
Comments
As
part
of
the
request
for
comments
on
phosmet
reregistration,
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;
 
costs
of
phosmet
products
and
alternative
insecticides;
 
non­
chemical
control
measures,
particularly
their
efficacy,
commercial
feasibility,
and
cost;
 
restrictions
or
other
constraints
on
the
use
of
alternatives;
and
 
timing
of
important
phosmet
application
across
the
season
for
California
and
other
regions.

References
Atwood,
D.
and
Alsadek,
J.
2001.
Plum/
Prune
Initial
Benefits
Assessment
for
Azinphos­
methyl
and
Phosmet.
Available
on
the
web
at
http://
www.
epa.
gov/
oppsrrd1/
op/
azm.
htm.

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
.
6
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/
