1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Proposed
Decisions
for
the
Remaining
Uses
of
Azinphos­
methyl
June
9,
2006
Part
I:
Summary
and
Background
Proposed
Decision
and
Comment
Opportunity
Based
on
its
reevaluation
of
the
risks
and
benefits
of
the
10
remaining
uses
of
azinphosmethyl
(
AZM),
the
Agency
is
proposing
to
phase
out
AZM
use
on
almonds,
pistachios,
walnuts,
Brussels
sprouts,
and
nursery
stock
in
2007,
and
phase
out
use
on
apples/
crabapples,
blueberries,
cherries,
pears
and
parsley
in
2010.
The
purpose
of
this
document
is
to
outline
the
Agency's
rationale
for
these
proposals
and
solicit
comment.
Comments
are
specifically
requested
on
the
time
frame
for
phasing
out
uses,
the
terms
and
conditions
of
the
phase­
out,
and
what
mitigation
and
monitoring
should
be
required
during
the
phase­
out.
All
supporting
documents,
including
the
worker
and
ecological
risk
assessments,
the
crop­
by­
crop
grower
impact
assessments,
comments
received
to
date,
and
EPA's
response
to
comments
can
be
found
at:
www.
regulations.
gov
under
docket
number
EPA­
HQ­
OPP­
2005­
0061.
Public
comments
will
be
accepted
for
60­
days
following
publication
of
a
Federal
Register
Notice
of
Availability
on
June
9,
2006.
After
the
close
of
the
comment
period
(
August
9,
2006),
the
Agency
will
review
all
comments
received
and
issue
its
final
decision
later
this
Fall.
That
final
decision
will
include
consideration
of
the
results
of
the
cumulative
risk
assessment
of
the
organophosphate
(
OP)
pesticides.

This
document
is
divided
into
two
parts.
Part
I
contains
general
background
information
and
summaries
of
risk
concerns.
Part
II
contains
the
crop­
by­
crop
proposed
decisions
and
rationale.

Regulatory
Context/
Background
AZM,
an
organophosphate
insecticide
first
registered
in
1959,
is
currently
used
only
on
orchard
fruits,
berries,
nuts,
and
other
crops.
In
connection
with
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
reregistration
and
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA)
tolerance
reassessment
processes,
EPA
issued
an
Interim
Reregistration
Eligibility
Decision
(
IRED)
for
AZM
in
October
2001.
2
In
the
azinphos­
methyl
IRED,
the
Agency
concluded,
based
on
evaluation
of
the
risks
and
benefits
of
the
use
of
AZM,
that
35
uses
should
either
be
immediately
canceled
(
Group
1)
or
phased
out
over
a
four­
year
period
(
Group
2).
The
remaining
ten
timelimited
AZM
uses
(
Group
3:
almonds,
apples/
crabapples,
highbush
and
lowbush
blueberries,
Brussels
sprouts,
cherries,
nursery
stock,
parsley,
pears,
pistachios,
and
walnuts)
were
eligible
for
reregistration
for
a
period
of
four
years,
contingent
on
the
submission
of
additional
data
and
pending
completion
of
the
cumulative
risk
assessment
for
OPs.
Subsequent
to
the
IRED,
a
Memorandum
of
Agreement
(
MOA)
in
2002
between
EPA
and
the
AZM
registrants,
Bayer
Corporation,
Gowan
Company,
Makhteshim­
Agan
of
North
America,
Inc,
Micro­
Flo
Corporation,
and
Platte
Chemical
Company,
provided
among
other
things,
that
registrants
could
submit
applications
for
amended
registration
to
extend
the
life
of
their
azinphos­
methyl
registrations
beyond
the
four­
year
period.
EPA
would
consider
applications
to
remove
the
time
limitation
on
the
registrations
taking
into
account
additional
data
EPA
required
the
registrants
to
submit.
In
July
2004,
the
AZM
registrants
submitted
applications
to
remove
the
time
limitation
for
the
ten
uses.
The
Agency
intends
to
publish
its
final
decision
later
this
Fall
which
will
also
serve
as
the
response
to
the
registration
amendment
requests.

New
Information
The
Data
Call­
In
associated
with
the
2001
IRED
required
usage
information,
ecological
effects
data
as
well
as
biomonitoring
of
agricultural
workers.
These
data
have
been
submitted
by
registrants,
reviewed
by
the
Agency,
and
incorporated
into
the
revised
grower
impact,
worker
and
ecological
risk
assessments.
The
Agency
has
also
updated
ecological
and
worker
exposure
incident
information,
consulted
with
other
EPA
offices,
USDA,
states
and
stakeholders,
and
evaluated
national
water
monitoring
data.

The
ecological
assessment
and
grower
impact
assessments
for
the
individual
Group
3
crops
were
made
available
for
public
comment
on
December
7,
2005.
The
Agency
has
considered
the
public
comments
received
on
those
documents
for
this
proposed
decision.
The
revised
worker
assessment
is
being
made
available
for
comment
along
with
this
proposed
decision.
The
revised
worker
assessment
includes
a
discussion
of
a
repeat­
dose
human
toxicity
study
conducted
in
1999
that
was
submitted
to
the
Human
Studies
Review
Board
in
April,
2006.

United
Farm
Workers
v.
Johnson
This
proposed
decision
is
also
being
issued
in
response
to
a
settlement
agreement
with
the
United
Farm
Workers
and
the
other
plaintiffs
who
sued
the
Agency
in
January
2004
in
the
U.
S.
District
Court
for
the
Western
District
of
Washington
regarding
the
pesticides
azinphos­
methyl
and
phosmet.
The
suit
alleged
that
the
azinphos­
methyl
and
phosmet
Interim
Reregistration
Eligibility
Decisions
(
IREDs)
were
inconsistent
with
the
requirements
of
FIFRA
because
EPA
did
not
appropriately
consider
the
risks
and
benefits
of
these
pesticides.
The
settlement
agreement
effectively
stays
the
legal
challenge
pending
EPA's
reconsideration
of
the
"
time
limited"
uses
of
these
pesticides.
Prior
to
finalizing
the
settlement
agreement,
EPA
took
public
comment
on
it
3
The
settlement
agreement
established
milestones
for
EPA
to
propose
decisions
on
the
reevaluation
of
the
ten
azinphos­
methyl
time­
limited
uses,
take
comment,
and
then
finalize
its
decision
on
these
remaining
uses
by
August
3,
2006.
EPA
has
informed
the
plaintiffs
that
it
now
intends
to
issue
its
final
decision
by
the
Fall
of
this
year.

EPA
is
preparing
a
detailed
response
to
issues
raised
in
declarations
supporting
the
United
Farm
Workers
suit
that
will
be
completed
and
released
along
with
EPA's
final
decisions
on
azinphos­
methyl.

This
document
explains
the
logic
and
considerations
behind
EPA's
risk/
benefit
decisions
in
the
crop­
by­
crop
discussions
in
Part
II.
In
general,
EPA
has
ranked
ecological
and
worker
risk
as
high,
medium
or
low
and
explained
the
rationale
for
these
rankings.
Similarly,
impacts
to
growers
have
been
ranked
high
to
low
based
on
availability,
cost
and
performance
of
alternatives.

Summary
of
Ecological
Risk
Concerns
(
For
more
information,
see
the
Ecological
Risk
Assessment
for
the
Use
of
AZM,
dated
September
29,
2005,
and
located
in
the
AZM
docket
(
EPA­
HQ­
OPP­
2005­
0061)
located
on
the
internet
at
www.
regulations.
gov.)

EPA's
ecological
assessment
explored
multiple
lines
of
evidence
including
laboratory
toxicity
data
for
surrogate
species,
modeled
exposure
estimates
(
taking
into
account
buffer
strips
and
application
rates
on
current
labels),
field
studies,
and
ecological
monitoring
information.
The
ecological
assessment
shows
concerns
for
both
aquatic
and
terrestrial
animals,
even
taking
into
account
the
ecological
risk
mitigation
implemented
as
a
result
of
the
IRED
in
2001.

AZM
is
mobile
and
relatively
persistent;
aquatic
exposures
are
predominantly
driven
by
runoff
from
treated
orchards.
AZM
is
very
highly
toxic
to
freshwater
and
marine
fish
and
invertebrates
as
well
as
to
birds,
mammals,
and
beneficial
insects,
such
as
honey
bees.
All
of
the
assessed
Group
3
uses
are
likely
to
result
in
azinphos­
methyl
exposures
that
exceed
known
toxicity
thresholds
for
fish
(
surrogate
for
aquatic­
phase
amphibians),
aquatic
invertebrates,
birds
(
surrogate
for
reptiles
and
terrestrial­
phase
amphibians),
mammals,
and
beneficial
insects.
Depending
on
the
magnitude
and
duration
of
exposure,
acute
(
i.
e.
mortality)
and/
or
chronic
(
i.
e.
reproductive)
effects
are
expected.

Further,
five
water
bodies
are
listed
as
impaired
by
azinphos­
methyl
under
the
Clean
Water
Act
section
303(
d).
Section
303(
d)
requires
states
to
identify
impaired
waters
and
develop
allocations
of
the
maximum
amount
of
a
pollutant
each
water
body
can
receive
and
still
meet
water
quality
standards.
The
Agency
considered
these
impairments
in
its
decision
on
AZM.

Table
1.
Impaired
Water
Bodies
Associated
with
Azinphos­
methyl
Use
State
Impaired
Water
Body
Predominant
Crops
Cycle
4
CA
Colusa
Basin
Drain
(
Central
Valley)
Nuts,
stone
fruits
2002
CA
Orestimba
Creek 
above
Kilburn
Road
(
Central
Valley)
Nuts,
stone
fruits
2002
CA
Orestimba
Creek 
below
Kilburn
Road
(
Central
Valley)
Nuts,
stone
fruits
2002
OR
Neal
Creek
Pears,
apples
2002
WA
Mission
Creek
Apples
1998
A
recently
published
USGS
National
Water
Quality
Assessment
Program
(
NAWQA)
10­
year
report1
indicates
14
of
83
agricultural
watersheds
monitored
had
AZM
concentrations
that
exceeded
EPA's
levels
of
concern
for
aquatic
species.
Eight
of
these
watersheds
are
in
apple
production
states
(
2
in
CA,
2
in
OR,
1
in
PA,
and
3
in
WA).

Because
of
the
acute
and
chronic
risks
to
aquatic
animals
identified
in
the
IRED
and
subsequent
litigation,
a
risk
assessment2
was
conducted
to
determine
whether
AZM
may
affect
threatened
and
endangered
Pacific
anadromous
salmonids
and
their
designated
critical
habitat.
The
endangered
species
assessment
concluded
that
in
spite
of
the
mitigation
measures
taken
(
i.
e.
reduction
of
maximum
application
rates,
cancellations,
phase
outs),
AZM
may
affect
25
out
of
26
salmonid
evolutionarily
significant
units
of
concern
(
ESUs)
listed
as
threatened
or
endangered
under
the
Endangered
Species
Act.
One
of
those
ESUs
has
since
been
delisted.

Azinphos
methyl
has
an
extensive
history
of
adverse
ecological
incidents.
EPA
databases
document
report
of
148
fish
kills
and
15
honey
bee
kills.
Ecological
incidents
have
declined
in
the
past
several
years,
presumably
in
part
because
many
of
the
use
sites
associated
with
a
large
number
of
incidents
have
been
cancelled
(
e.
g.
cotton,
sugar
cane).
Nevertheless,
predicted
environmental
exposures,
monitoring
data,
and
field
studies
support
EPA's
risk
conclusions
for
the
Group
3
uses.

Summary
of
Worker
Risk
Concerns
(
For
more
information
see
the
Revised
Occupational
Exposure
and
Risk
Assessment
for
Azinphos­
Methyl,
dated
June
6,
2006)

The
toxicity
endpoints
used
for
estimating
risks
from
dermal
(
0.56
mg/
kg/
day)
and
inhalation
(
0.2
mg/
kg/
day)
exposures
using
PHED
(
Pesticide
Handlers
Exposure
Database)
data
are
the
same
as
those
used
in
the
2001
assessment.
These
endpoints
are
from
route­
specific
toxicity
studies
in
animals.
The
recent
biomonitoring
studies
have
allowed
EPA
to
refine
many
of
the
exposure
estimates.
The
toxicity
endpoint
used
to
estimate
risks
from
worker
exposures
based
on
an
internal
dose
from
biomonitoring
data
1
Gilliom,
Robert
J.,
Jack
E.
Barbash,
Charles
G.
Crawford,
Pixie
A.
Hamilton,
Jeffrey
D.
Martin,
Naomi
Nakagaki,
Lisa
H.
Nowell,
Jonathan
C.
Scott,
Paul
E.
Stackelberg,
Gail
P.
Thelin,
and
David
M.
Wolock.
2006.
The
Quality
of
Our
Nations
Waters:
Pesticides
in
the
Nations's
Streams
and
Groundwater,
1992­
2001.
U.
S.
Geological
Survery
Circular
1291.
172
p.
2
U.
S.
E.
P.
A.,
Office
of
Pesticide
Programs,
Environmental
Field
Branch.
2003.
Azinphos
methyl:
Analysis
of
Risks
to
Endangered
and
Threatened
Salmon
and
Steelhead.
5
is
from
an
oral
study
in
the
dog
(
0.15
mg/
kg/
day).
This
is
considered
a
protective
endpoint,
and
is
supported
by
a
weight­
of
evidence
re­
evaluation
of
the
entire
toxicity
data
base.
In
comparison,
the
endpoint
in
the
repeat
dose
human
study
was
0.25
mg/
kg/
day,
within
the
range
of
endpoints
that
have
been
selected
for
use
in
the
occupational
risk
assessment.
All
worker
endpoints
used
in
the
assessment
are
based
on
cholinesterase
inhibition,
a
sensitive
marker
of
exposure.
EPA's
"
level
of
concern"
for
AZM
is
a
margin
of
exposure
(
MOE)
of
100.
That
is,
EPA
believes
there
is
some
concern
that
workers
may
show
cholinesterase
inhibition
when
they
are
exposed
to
AZM
at
levels
that
are
not
at
least
100­
fold
below
the
"
no
effect"
level
measured
in
animal
data.
EPA
considered
a
repeat
dose
study
with
human
subjects,
and
presented
it
to
the
Human
Studies
Review
Board
(
HSRB).
The
Agency
had
proposed
to
use
the
study,
both
as
an
endpoint
for
risk
assessment
and
to
reduce
the
inter­
species
uncertainty
factor
from
10
to
1.
At
the
HSRB
public
meeting
and
in
their
draft
final
report,
the
HSRB
raised
some
issues
that
caused
EPA
to
question
reliance
on
that
study.
Further,
the
Agency's
revisit
of
the
entire
toxicity
data
base
indicates
that
in
the
absence
of
the
human
study,
there
is
no
basis
to
reduce
the
inter­
species
uncertainty
factor
and
in
fact
a
relatively
steep
dose
response
curve
argues
for
retaining
it.

EPA
used
biomonitoring
data
for
airblast
application
for
all
the
Group
3
crops.
MOEs
using
the
biomonitoring­
airblast
study
range
from
14­
18
for
all
open
cab
scenarios
for
mixing/
loading/
applying
azinphos­
methyl
to
apple,
pear,
crabapple,
almond,
pistachio
and
walnut.
For
closed
cab
scenarios
MOEs
range
80­
102.
MOEs
for
cherry
and
nursery
stock
range
are
205
and
155
respectively,
with
closed
cabs.

For
post
application
workers,
EPA
used
the
2003
AZM
biomonitoring
data
for
blueberry,
apple,
and
walnut
to
estimate
risk
for
all
Group
3
uses
except
parsley.
Walnuts
and
almonds
are
the
only
group
3
crops
with
MOEs
of
at
least
100
for
current
REI
(
30
days).
Other
Group
3
crops
would
require
significantly
longer
REIs
for
MOEs
to
reach
100.
The
MOEs
for
apples,
cherries,
blueberries,
and
pears
range
from
7
to
30.
Currently
labeled
REIs
are
considered
to
be
the
maximum
feasible
for
growers
due
to
the
need
to
perform
certain
crop
maintenance
tasks
at
specific
stages
in
the
growth
cycle
of
the
crops.

In
addition
to
the
risk
estimates
based
on
biomonitoring
and
other
data,
EPA
has
considered
incidents
reports
and
Washington
state
medical
monitoring
information.
Limited
information
from
Poison
Control
Centers
shows
a
decline
of
about
50%
in
reported
poisonings
involving
azinphos­
methyl
from
1993­
2003
or
a
reduction
in
average
number
of
reported
poisonings
per
year
from
19
to
10.
Washington
state
medical
monitoring
found
two
workers
with
inhibition
reported
in
2004
related
to
azninphosmethyl
exposure
alone
out
of
580
workers
tested
(%
ChE
inhibition
was
not
provided).
In
2005,
the
second
year
of
Washington
state's
monitoring
program,
one
worker
was
reported
with
inhibition
related
to
AZM
exposure
alone,
out
of
611
workers
tested.
(
It
is
not
known
how
many
of
the
611
workers
were
exposed
to
AZM.)
His
red
blood
cell
acetyl
ChE
inhibition
varied
from
8
to
21%
over
a
3
month
period.

Summary
of
Usage
6
Table
2.
Comparison
of
AZM
Usage
Information
in
the
2001
and
2006
Assessments
Crop
2001
Assessment
2006
Assessment
Pounds
Applied
Percent
Crop
Treated
Pounds
Applied
Percent
Crop
Treated
Apples
932,792
72
945,272
73
Sweet
Cherries
30,200
44
33,100
46
Tart
Cherries
39,400
77
33,700
68
Blueberries
(
lowbush)
2,700
36
no
data
no
data
Blueberries
(
highbush)
8,300
44
7,037
52
Pears
65,552
42
66,345
50
Almonds
83,076
10
89,000
10
Pistachios
31,000
21
35,000
24
Walnuts
33,123
10
17,000
5
Brussels
sprouts
­­
41
­­
7
Nursery
stock
1,400
1
1,700
1
Parsley
no
data
no
data
 
400
<
1
Total
Pounds
Applied
 
1,227,543
 
1,228,554
 
­
1,011
pounds
7
Part
II:
Crop
Specific
Considerations,
Proposed
Decisions
and
Rationale
(
For
more
information
on
usage,
alternatives
and
impacts,
see
the
crop­
specific
grower
impact
assessments
located
in
the
AZM
docket
(
EPA­
HQ­
OPP­
2005­
0061)
located
on
the
internet
at
www.
regulations.
gov.)

Apples
Current
Use
Parameters
Label
rate:
1.0
­
1.5
lbs
ai/
A
per
application
Max
application
rate:
4.5
lbs
ai/
A
per
season;
7
days
between
applications
Typical
rate:
0.78
lbs
ai/
A
per
application,
3
applications
per
season
Current
REI:
14
days
for
hand
harvesting,
and
hand
thinning,
2
days
for
all
other
activities
Current
PHI:
14
days
(<
1.0
lb
ai/
A),
21
days
(>
1.0
lb
ai/
A)

Worker
Risks
Of
particular
concern
are
the
relatively
low
margins
of
exposure
(
MOE)
for
post
application
activities
in
apple
orchards.
As
explained
above
in
the
summary
of
worker
risk,
the
target
MOE
for
these
activities
is
100.
After
14
days,
the
MOE
for
thinning
apples
in
Oregon
is
24
and
the
MOE
is
only
7
for
harvesting
apples
in
either
New
York
or
Oregon.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers
performing
these
activities.
Based
on
the
grower
impact
assessment,
setting
the
REI
longer
than
14
days,
to
achieve
an
MOE
that
does
not
present
risks
of
concern,
would
not
be
feasible
for
this
chemical
on
apples.
Further,
additional
worker
protection
measures
such
as
more
clothing
or
gloves
for
these
activities
are
not
considered
feasible
due
to
heat
stress
and
other
factors
associated
with
these
activities.

Also,
EPA
has
concluded
that
the
MOE
is
18
for
applicatiors
using
an
open
cab
airblast
application
to
apples.
This
result
was
also
based
on
biomonitoring
data
of
current
use
practices.
This
risk
can
be
mitigated
through
the
use
of
closed
cabs.
With
closed
cabs,
the
MOEs
for
these
pesticide
handlers
would
be
102.

Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

The
use
of
AZM
on
apples
poses
the
most
significant
ecological
risks
of
all
the
remaining
uses
due
to
application
rate,
timing,
volume
of
use,
and
use
pattern.
At
nearly
1
million
pounds
applied
yearly,
the
apple
use
is
the
largest
remaining
use
of
AZM.

Aquatic
exposures
were
estimated
for
western
(
OR)
and
eastern
(
PA)
apples
and
took
into
account
the
current
label
rate
and
buffer
strips.
Air
blast
exposures
for
apples
in
the
8
Pacific
Northwest
(
OR)
are
estimated
to
be
8
times
the
median
lethal
dose
for
brook
trout
(
a
salmonid
species),
and
32
times
the
chronic
no­
effect
level
for
a
common
freshwater
invertebrates
species.
Even
if
spray
drift
could
be
completely
eliminated
from
apple
orchard
applications,
runoff
of
the
pesticide
into
aquatic
environments
would
still
result
in
acute
and
chronic
risk
quotients
for
aquatic
animals
that
exceed
the
Agency's
levels
of
concern
at
2
times
the
median
lethal
dose
for
brook
trout,
and
7
times
the
chronic
noeffect
level
for
freshwater
invertebrates.
Risks
to
aquatic
animals
are
even
greater
for
eastern
(
PA)
apples
due
to
increased
runoff
potential.
As
a
result,
EPA
believes
there
is
a
high
risk
of
mortality
for
aquatic
species.

EPA's
modeling
predictions
are
confirmed
by
recent
NAWQA
monitoring
data
indicate
that
there
continue
to
be
AZM
detections
above
the
level
of
concern
in
apple­
growing
areas,
and
two
of
five
impaired
water
bodies
are
associated
with
azinphos­
methyl
applications
to
apples,
as
noted
in
Table
1,
above.
(
See
the
following
website
for
more
information:
http://
infotrek.
er.
usgs.
gov/
traverse/
f?
p=
NAWQA:
HOME:
4416958071450237443]

Further,
the
endangered
salmonid
species
assessment
concluded
that
counties
where
apples
are
grown
in
the
Pacific
Northwest
overlap
with
the
spawning,
rearing,
and/
or
migration
corridors
for
more
than
20
listed
salmon
groups.

The
use
of
AZM
on
apples
also
poses
acute
and
chronic
risks
to
terrestrial
animals,
such
as
mammals,
birds,
and
beneficial
insects,
particularly
honey
bees.
Predicted
dietary
exposures
for
animals
in
and
around
apple
orchards
exceed
known
acute
and
chronic
toxicity
thresholds.
Further,
field
studies
in
Washington
and
Michigan
apple
orchards
have
documented
the
poisoning
of
a
variety
of
terrestrial
animals
following
exposure
to
spray
applications
of
AZM
at
rates
that
are
very
similar
to
the
current
label
rate.
These
studies
also
show
that
there
is
concordance
between
EPA's
predicted
dietary
exposures
and
actual
measured
field
residues.
In
addition,
the
are
six
known
honey
bee
kills
specifically
associated
with
the
use
of
AZM
on
fruit
orchards
in
Washington
State.

Grower
Impacts
AZM
use
on
apples
accounts
for
76%
of
the
total
Group
3
uses;
73
%
of
the
apple
crop
is
treated
with
AZM.
If
AZM
were
not
available
the
estimated
biological
and
economic
impact
of
each
alternative
scenario
varies
by
region.
The
following
is
a
summary
of
EPA's
evaluation
of
grower
impacts
for
eastern
and
western
US
apple
production.

In
the
Eastern
US,
49%
of
apples
grown
go
to
the
fresh
market
and
51%
are
processed.
EPA
considered
two
alternative
scenarios:
1.
Phosmet
as
an
alternative
resulted
in
3
%
quality
loss
plus
increase
in
control
costs,
and
a
12
%
reduction
in
per
acre
net
revenue.
2.
Using
a
combination
of
phosmet
and
non­
OP
alternatives
(
thiacloprid,
novaluron,
acetamiprid)
resulted
in
no
yield
or
quality
loss
but
significant
increase
in
control
costs,
and
a
6%
reduction
in
per
acre
net
revenue.
Estimated
aggregate
losses
to
growers
range
from
$
9
million
to
$
31
million
across
all
9
scenarios.

In
the
Western
US
70%
of
apples
grown
go
to
the
fresh
market
and
30%
are
processed.
1.
Phosmet
as
an
alternative
resulted
in
1
%
yield
and
5
%
quality
loss
plus
increase
in
control
costs,
and
an
18%
reduction
in
net
revenue.
2.
Using
a
combination
of
phosmet
and
non­
OP
alternatives
showed
no
yield
or
quality
loss
but
significant
increase
in
control
costs,
and
a
4%
reduction
in
net
revenue.
Estimated
aggregate
losses
to
growers
range
from
$
9
million
to
$
50
million
across
all
scenarios.

Estimated
losses
to
the
apple
industry
nationally
range
from
$
18
million
to
$
81
million
across
all
scenarios.
Total
impacts
are
estimated
to
range
from
5%
­
18%
of
current
net
revenues.

In
addition
to
grower
impacts
for
domestic
apple
production,
EPA
also
evaluated
the
effect
the
loss
of
AZM
would
have
on
the
export
market.
In
order
for
US
growers
to
export
apples
that
have
pesticide
residues,
there
must
be
established
maximum
residue
levels
("
MRL")
which
are
similar
to
the
requirements
of
US
tolerances.
The
Agency
researched
whether
there
are
established
MRLs
for
the
alternatives
to
AZM
in
the
countries
that
receive
US
apples.
The
absence
of
MRLs
for
multiple
AZM
alternatives
could
have
major
impacts
that
are
not
included
in
the
loss
estimates
given
above.
The
following
is
a
summary
of
the
current
status
of
MRLs
in
key
export
markets.

Status
of
MRLs
for
AZM
Alternatives
 
The
US
Apple
trade
association
indicates
that
leading
markets
for
US
apples
include
Canada,
Mexico,
Taiwan,
Hong
Kong,
and
Malaysia.
 
The
main
alternatives
discussed
by
BEAD
in
its
2005
assessment
are
phosmet,
acetamiprid,
novaluron,
and
thiacloprid.
 
Phosmet
has
an
MRL
in
all
apple
export
markets.
The
largest
single
export
market,
Mexico,
has
an
MRL
for
all
key
alternatives.
However,
the
other
countries
have
few
MRLs
established
for
materials
other
than
phosmet.

Table
3.
Apples:
Availability
of
MRLs
for
selected
alternatives
to
AZM
Country
Phosmet
Acetamiprid
Novaluron
Thiacloprid
Mexico
10
1
2
0.3
Canada
10
1
b
­
­
Taiwan
2a
1
a
­
­
Hong
Kong
10
­
­
­
Malaysia
10
a
­
­
­

US
10
1
2
0.3
Codex
c
10
­
{
3}
­
 
It
should
be
noted
that
the
UK
does
NOT
have
an
MRL
for
phosmet.
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com);
Northwest
Horticultural
Council
(
www.
nwhort.
org).
10
Notes:
a
From
Northwest
Horticultural
website.
b
Proposed
as
per
the
Canadian
PMRA
Website
http://
www.
pmra­
arla.
gc.
ca/
english/
legis/
max­
re­
e.
html.
c
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
{}
=
under
development
according
to
the
Report
of
the
Thirty
Eighth
Session
of
the
Codex
Committee
on
Pesticide
Residues,
Fortaleza
Brazil,
3­
8
April,
2006.
Available
at
http://
www.
codexalimentarius.
net.
­
=
MRL
not
listed.
*
MRL
figures
are
given
in
parts
per
million
(
ppm);
Codex
values,
are
in
mg/
kg,
which
are
equivalent
Proposed
Decision/
Mitigation/
Rationale
As
explained
above,
EPA
believes
there
is
a
high
risk
of
mortality
to
numerous
aquatic
and
terrestrial
species
from
the
apple
use
of
AZM.
Additional
label
mitigation
can
reduce
this
risk
but
EPA's
assessment
indicates
it
is
insufficient
to
reduce
the
risk
to
acceptable
levels.
The
Worker
risk
assessment
indicates
that
existing
MOEs
at
current
label
rates
are
insufficient
to
ensure
that
there
is
not
a
concern
that
workers
will
be
exposed
to
levels
of
AZM
that
will
result
in
cholinesterase
depression
 
a
precursor
of
adverse
neurological
effects.
Current
label
restricted
entry
intervals
likely
cannot
be
extended
in
light
of
the
need
for
field
re­
entry
to
conduct
necessary
cropping
practices.

In
the
short
term,
EPA
believes
that
the
benefits
of
the
apple
are
use
are
high
and
with
the
additional
mitigation
measures
outlined
below,
these
benefits
outweigh
the
risks,
largely
for
four
reasons:
(
1)
While
there
are
now
numerous
efficacious
registered
alternatives
to
AZM,
many
of
the
alternatives
that
are
the
most
likely
to
be
used
lack
maximum
residue
level
regulations
(
known
as
"
MRLs")
that
allow
for
residues
of
these
pesticides
on
apples
sold
in
countries
to
which
U.
S.
apples
are
exported,
leaving
growers
at
risk,
in
some
cases,
of
losing
the
export
market
for
lack
of
an
appropriate
alternative.
EPA's
"
worstcase
estimate
is
that
loss
of
certain
export
markets
could
result
in
a
loss
to
the
apple
industry
of
well
over
$
100
million.
(
2)
Development
of
effective
alternative
pest
control
practices
using
new
pesticides
often
takes
multiple
use
seasons
to
perfect.
With
73%
of
apples
treated
with
AZM,
most
growers
will
need
to
switch
to
new
practices
and
would
have
no
experience
or
guidance
regarding
such
practices
were
EPA
to
cancel
this
use
immediately
or
allow
only
for
a
more
limited
phase
out.
Without
prior
development
of
such
practices,
there
is
a
risk
that
grower
impacts
would
exceed
EPA's
estimates.
(
3)
While
EPA
believes
the
risk
concerns
from
AZM
use
are
significant,
EPA
is
not
aware
of
incident
information,
monitoring
data
or
other
sources
of
information
that
suggest
AZM
is
having
immediate
large­
scale
environmental
impacts
(
such
as
a
clear
link
to
species
population
declines
or
extirpations)
or
that
severe
worker
poisoning
incidents
are
occurring.
Although
incident
and
monitoring
databases
are
not
sufficiently
robust
to
capture
the
extent
of
likely
adverse
effects,
EPA
believes
that
if
severe
adverse
human
health
and
environmental
effects
were
occurring
on
a
broad
scale,
these
databases
would
reflect
that
fact.
(
4)
EPA
believes
the
risk
mitigation
measures
outlined
below
are
feasible
and
will
reduce
the
existing
risks
to
some
extent.

EPA
believes,
however,
that
with
the
development
of
MRLs
for
newer
pesticides
and
with
the
development
of
alternative
pest
control
practices,
this
risk­
benefit
balance
for
apples
changes.
EPA
believes
it
is
reasonable
to
assume
that
a
number
of
export
countries
will
adopt
additional
MRLs
for
the
newer
pesticides
within
4
years,
and
that
11
growers
will
have
at
their
disposal
appropriate
guidance
and
practice
with
using
these
alternatives
effectively
by
that
time.
At
that
point,
EPA
believes
the
benefits
of
AZM
will
track
the
grower
impact
scenarios
outlined
above
and
that
the
risk
associated
with
AZM
will
outweigh
those
benefits.
While
these
impacts
will
remain
in
the
millions
of
dollars
nationally,
it
is
important
to
note
that
the
overall
impact
on
grower
revenue
is
relatively
small.
These
numbers
should
decline
further
as
additional
alternatives
become
available
over
the
next
four
years.
Further,
EPA
has
not
reviewed
any
information
that
suggests
there
will
be
a
measurable
impact
on
consumers
in
the
price
or
availability
of
apples
from
the
cancellation
of
AZM.
Indeed,
the
loss
of
a
single
agricultural
pesticide
rarely
translates
into
consumer­
level
impacts.

As
discussed
above,
EPA
believes
it
is
likely
that
by
2010
there
will
be
in
place
additional
MRLs
for
AZM
alternatives
in
export
countries
for
apples,
that
will
eliminate
the
concern
for
possible
impacts
to
the
US
export
market.
Should
that
not
be
the
case,
however,
EPA
would
consider
appropriate,
time­
limited
requests
to
extend
AZM
use
on
apples
for
a
period
necessary
for
the
development
of
the
critical
additional
MRLs
for
AZM
alternatives.

During
the
phase
out
period,
EPA
is
proposing
to
put
in
place
the
following
mitigation
measures:

­
require
label
amendments
to
increase
buffer
zones
around
permanent
water
bodies
from
25
to
100
feet;
­
require
label
amendments
to
reduce
yearly
maximum
application
rate
from
4
to
3
lbs/
ai/
A
­
require
label
amendments
to
establish
buffer
zones
around
houses
and
occupied
buildings
­
issue
a
data
call­
in
for
the
registrant
to
conduct
medical
monitoring
of
post­
application
workers
to
provide
information
to
better
assess
the
full
nature
of
the
risks
to
such
workers
and
to
help
determine,
as
a
result,
the
need
for
any
regulatory
action
during
the
phase
out
period.

Pears
Current
Use
parameters
Label
rate:
1.0
 
1.5
lbs
ai/
A
per
application
Max
application
rate:
3.0
lbs
ai/
A
per
year;
7
days
between
applications
Typical
rate:
1.05
lbs
ai/
A,
3
applications
per
season
Current
REI:
14
days
for
hand
harvesting,
and
hand
thinning,
7
days
for
fireblight
pruning
with
PPE.
Current
PHI:
14
days
(<
1.0
lbs
ai/
A),
21
days
(>
1.0
lbs
ai/
A)

Worker
Risks
12
Like
apples,
of
particular
concern
are
the
relatively
low
margins
of
exposure
(
MOE)
for
post
application
activities
on
pears.
As
explained
above,
the
target
MOE
for
these
activities
is
100.
After
14
days,
the
MOE
for
thinning
pears
in
Oregon
is
24
and
only
7
for
harvesting
pears
in
either
New
York
or
Oregon.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers
performing
these
activities.
Although
the
biomonitoring
study
used
for
pears
was
conducted
with
apples,
the
Agency
believes
that
apples
are
an
appropriate
surrogate
for
pears.

Also
of
concern
is
the
MOE
of
18
for
open
cab
airblast
applications
to
pears,
based
on
apple
biomonitoring
data
of
current
use
practices.
This
risk
can
be
mitigated
through
the
use
of
closed
cabs.
With
closed
cabs,
the
MOEs
for
these
pesticide
handlers
would
be
102.

Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

The
use
of
AZM
on
pears
poses
acute
and
chronic
risks
to
all
aquatic
and
terrestrial
animals.
Aquatic
exposures
were
estimated
for
Oregon
pears,
and
predicted
exposures
exceed
known
toxicity
thresholds.

The
states
of
California,
Oregon,
and
Washington
have
declared
water
bodies
in
their
state
as
impaired
due
to
AZM
use
(
a
total
of
5
water
bodies).
One
of
the
five
impaired
water
bodies
is
listed
because
of
AZM
use
on
pears
(
Neal
Creek
in
Oregon).

The
endangered
salmonid
species
assessment
concluded
that
counties
where
pears
are
grown
in
the
Pacific
Northwest
overlap
with
the
spawning,
rearing,
and/
or
migration
corridors
for
more
than
20
listed
salmon
groups.

Grower
Impacts
Pears
are
produced
on
about
64,500
total
bearing
acres
in
the
U.
S.
Washington,
Oregon,
and
California
represent
about
94%
of
the
national
production
of
pears.
Washington
State
alone
accounts
for
40
percent
of
the
total
acreage.
Approximately
66,000
pounds
of
AZM
are
applied
annually
to
pears
with
50
%
of
the
pear
crop
treated
with
this
pesticide.

AZM
is
applied
to
pears
primarily
for
the
control
of
codling
moth
(
Cydia
pomonella)
and,
to
a
lesser
extent,
for
the
suppression
of
grape
mealybug
(
Pseudococcus
maritimus)
populations.

Several
new
insecticides
have
been
registered
on
pears
since
the
2001
AZM
IRED.
The
following
insecticides
are
potential
alternatives
to
AZM:
abamectin,
acetamiprid,
buprofezin,
diflubenzuron,
indoxacarb,
lambda
cyhalothrin,
methoxyfenozide,
novaluron,
pyriproxyfen,
spinosad,
thiacloprid,
and
thiamethoxam.
With
the
exception
of
diflubenzuron,
indoxacarb,
lambda
cyhalothrin,
novaluron,
and
spinosad
all
of
these
13
insecticides
have
been
adopted
to
some
degree
by
pear
growers
for
codling
moth
control
and/
or
grape
mealybug.

Based
on
the
latest
information
available
with
respect
to
alternative
insecticides
for
AZM,
no
yield
or
quality
losses
are
expected
if
AZM
is
not
available
for
use
on
pears.
However,
alternative
pest
control
scenarios
(
phosmet
or
acetamiprid
and
methoxyfenozide)
are
more
expensive
than
AZM.
Nationally,
the
increased
control
costs
are
estimated
to
decrease
the
value
of
production
by
less
than
1%
for
pear
growers.
Regionally,
the
Pacific
Northwest
will
experience
the
greatest
losses
with
a
reduction
in
per
acre
net
revenues
from
1.5%
to
1.6%
if
AZM
is
not
available.

These
new
alternatives
give
growers
more
treatment
options
and
may
be
useful
for
resistance
management
when
rotated
with
phosmet,
the
primary
alternative
to
AZM.

Status
of
MRLs
for
AZM
Alternatives
 
The
leading
export
markets
for
pears
include
Mexico,
Canada,
Brazil,
Sweden,
and
Russia.
 
The
main
alternatives
listed
by
BEAD
in
its
2005
assessment
are
phosmet,
acetamiprid,
novaluron,
and
methoxyfenozide.
 
Mexico
has
established
MRLs
for
all
the
main
alternative
to
AZM.
Canada
has
MRLs
established
or
proposed
for
3
of
the
4
main
alternatives.

Table
4.
Pears:
Availability
of
MRLs
for
selected
alternatives
to
AZM
Country
Phosmet
Acetamiprid
Novaluron
Methoxyfenozide
Mexico
10
1
2
1.5
Canada
10
1
b
­
1.5
Brazil
­
­
­
­
Sweden
2c
­
­
­
Russia
­
­
­
­

US
10
1
2
1.5
Codex
b
10
­
{
3}
2
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com);
Northwest
Horticultural
Council
(
www.
nwhort.
org).
Notes:
a
From
Northwest
Horticultural
website
only.
b
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
c
EU
MRL
d
Proposed
per
PMRA
Website
http://
www.
pmra­
arla.
gc.
ca/
english/
legis/
max­
re­
e.
html
{}
=
under
development
according
to
the
Report
of
the
Thirty
Eighth
Session
of
the
Codex
Committee
on
Pesticide
Residues,
Fortaleza
Brazil,
3­
8
April,
2006.
Available
at
http://
www.
codexalimentarius.
net.
­
=
MRL
not
listed.
*
MRL
figures
are
given
in
parts
per
million
(
ppm):
Codex
values
are
in
mg/
kg,
which
are
equivalent.

Proposed
decision/
Mitigation
Rationale
14
For
the
reasons
outlined
above
in
the
discussion
regarding
apples,
EPA
believes
that
AZM
use
on
pears
should
similarly
be
phased
out
in
2010.
While
the
Agency
assessment
indicates
that
there
will
be
fewer
domestic
impacts
on
pear
growers
than
apple
growers,
the
concerns
regarding
MRLs
for
pears
in
export
markets
are
similar,
and
in
some
cases
greater,
than
the
concern
for
apples.

As
discussed
above,
EPA
believes
it
is
likely
that
by
2010
there
will
be
in
place
additional
MRLs
for
AZM
alternatives
in
export
countries
for
pears,
that
will
eliminate
the
concern
for
possible
impacts
to
the
US
export
market.
Should
that
not
be
the
case,
however,
EPA
would
consider
appropriate,
time­
limited
requests
to
extend
AZM
use
on
pears
for
a
period
necessary
for
the
development
of
the
critical
additional
MRLs
for
AZM
alternatives.

In
addition,
during
the
phase­
out
period,
the
following
mitigation
is
proposed:

­
require
label
amendments
to
establish
buffer
zones
houses
and
occupied
buildings
­
increase
existing
25
foot
buffer
zone
around
water
bodies
to
100
feet.

­
issue
a
data
call­
in
to
conduct
medical
monitoring
of
post­
application
workers
­
require
label
amendments
to
eliminate
u­
pick
operations.

Blueberries
(
lowbush
and
highbush)

Current
Use
parameters
Label
rate:
0.5
 
0.75
lbs
ai/
A
per
application
(
lowbush
and
highbush)
Max
application
rate:
0.75
lbs
ai/
A
per
season
Typical
rate:
0.25
lbs
ai/
a
for
lowbush
and
0.39
lbs
ai/
A
for
highbush,
2
applications
per
crop
per
season
Current
REI:
10
days
for
lowbush
and
7
days
for
highbush,
u­
pick
is
30
days
Current
PHI:
10
days
for
lowbush
and
7
days
for
highbush
Worker
Risks
Of
particular
concern
are
the
relatively
low
margins
of
exposure
(
MOE)
for
post
application
activities
on
blueberries.
As
explained
above,
the
target
MOE
for
these
activities
is
100.
After
seven
days,
the
MOE
for
harvesting
highbush
blueberries
in
Michigan
is
30.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
or
workers
performing
these
activities.

Based
on
PHED
data,
the
MOEs
for
mixing/
loading
for
aerial
or
groundboom
applications
are
less
than
1.
With
a
closed
system
the
MOEs
would
increase
to
9
and
40,
respectively.
For
goundboom
application
of
AZM
to
blueberries
the
MOE
is
25
for
open
cab
applications.
The
MOEs
for
these
pesticide
handlers
could
be
raised
to
80
with
the
use
of
closed
cabs
and
elimination
of
aerial
applications.
15
Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

Blueberries
are
grown
across
the
U.
S.,
and
fresh­
and
saltwater
ecosystems
may
be
exposed
to
AZM
by
runoff
and
spray
drift.
Aquatic
exposures
were
modeled
for
Michigan
blueberries
and
various
drift
scenarios
were
considered.
Aerial
application
of
AZM
to
blueberries
is
particularly
concerning
due
to
the
increased
likelihood
of
drift
to
aquatic
resources.
Even
if
drift
could
be
reduced
to
1%,
there
still
would
be
acute
and
chronic
concerns.

For
terrestrial
animals,
modeled
dietary
exposures
for
small,
medium
and
large
birds
and
mammals
are
at
risk
regardless
of
preferred
food
items.
Mean
dietary
residues
are
also
likely
to
exceed
known
acute
and
chronic
thresholds
for
birds
and
mammals.

Based
on
these
multiple
lines
of
evidence,
EPA
considers
the
ecological
risk
of
AZM
on
blueberries
to
be
high.

Grower
Impacts
There
are
two
primary
types
of
blueberries
(
Vaccinium
spp.),
lowbush
and
highbush.
The
U.
S.
production
of
lowbush
(
also
called
"
wild")
blueberries
occurs
almost
entirely
in
Maine,
while
highbush
blueberry
production
occurs
primarily
in
three
regions:
the
Pacific
Northwest
(
Oregon
and
Washington),
the
North
Central
(
Michigan
and
Indiana),
and
the
East
(
New
York,
New
Jersey,
Florida,
Georgia,
North
Carolina,
Alabama,
and
Arkansas).

Approximately
7,000
pounds
of
AZM
are
applied
to
highbush
blueberries.
There
are
no
data
on
the
amount
of
AZM
applied
to
lowbush
blueberries.
However,
information
from
crop
experts
indicates
that
AZM
use
has
decreased
since
2001
and
it
appears
that
most
growers
have
already
switched
to
other
alternatives,
primarily
phosmet.
In
the
absence
of
AZM,
the
likely
pest
management
scenarios
indicate
that
lowbush
blueberry
producers
in
the
absence
of
AZM
should
be
able
to
substitute
phosmet
with
low
losses
in
net
cash
returns
since
it
is
comparable
to
AZM
in
terms
of
cost
and
efficacy.

There
appears
to
be
virtually
no
use
of
AZM
in
Pacific
Northwest
blueberries.
Highbush
blueberry
growers
in
the
North
Central
region
(
primarily
Michigan)
will
have
to
use
more
treatments
of
a
set
of
alternative
insecticides
to
substitute
for
the
average
of
approximately
2
sprays
of
AZM
they
have
been
using.
Similarly,
growers
in
the
other
major
highbush
blueberry
producing
region,
the
Eastern
US
(
represented
by
New
Jersey),
will
also
have
to
use
multiple
alternatives
in
place
of
AZM.
EPA's
2005
grower
impact
assessments
concluded
that
in
both
regions
pest
management
costs
will
rise,
along
with
an
estimated
1­
2
%
yield
loss
and
1­
2
%
quality
loss.
Therefore,
for
both
regions,
losses
ranging
from
$
51
to
$
116
per
acre
at
the
grower
level
(
in
terms
of
returns
above
variable
16
costs
per
acre)
are
predicted,
while
at
the
regional
level
losses
of
approximately
$
2.3
million
are
expected.

Status
of
MRLs
for
AZM
Alternatives
 
The
leading
export
markets
for
blueberries
include
Japan,
Canada,
Australia,
Korea,
and
the
UK.
 
The
main
alternatives
are
phosmet,
esfenvalerate,
and
tebufenozide.
 
Japan
and
Canada
have
an
established
MRL
for
phosmet
and
Japan
also
has
an
established
MRL
for
tebufenozide.

Table
5.
Blueberries
(
lowbush
and
highbush):
Availability
of
MRLs
for
selected
alternatives
to
AZM
Country
Phosmet
Esfenvalerate
Tebufenozide
Japan
10
­
3
Canada
5
­
­
Australia
­
­
­
Korea
­
­
­
UK
­
­
­

US
10
3b
3
Codex
a
10
1c
3
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com).
Notes:
UK
defers
to
EU
MRL
levels
for
pesticides
if
the
country
has
not
set
its
own
MRL.
In
the
same
context,
Korea
defers
to
CODEX
MRL
levels.
Australia
follows
only
its
own
MRL
levels.
­
=
MRL
not
listed.
a
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
b
Listed
in
CFR
but
not
in
FAS.
c
Expressed
as
fenvalerate
in
CODEX
database.
*
MRL
figures
are
given
in
parts
per
million
(
ppm);
Codex
values,
are
in
mg/
kg,
which
are
equivalent.

Proposed
decision/
Mitigation
Rationale
The
blueberry
use
of
AZM
presents
high
ecological
risks
and
potentially
high
risk
to
workers
especially
re­
entry
workers
engaged
in
harvesting
activities.
While
the
impact
to
growers
of
losing
AZM
is
less
than
with
the
apple
and
pear
uses,
EPA
ranks
these
impacts
as
medium,
in
large
part
because
the
absence
of
MRLs
for
alternatives
in
certain
blueberry
export
markets
could
have
a
potentially
significant
impact
on
growers
selling
for
the
export
market.
Accordingly,
as
with
apples
and
pears,
EPA
is
proposing
to
phaseout
the
use
of
AZM
on
blueberries
in
2010.

As
discussed
above,
EPA
believes
it
is
likely
that
by
2010
there
will
be
in
place
additional
MRLs
for
AZM
alternatives
in
export
countries
for
blueberries,
that
will
eliminate
the
concern
for
possible
impacts
to
the
US
export
market.
Should
that
not
be
the
case,
however,
EPA
would
consider
appropriate,
time­
limited
requests
to
extend
AZM
use
on
blueberries
for
a
period
necessary
for
the
development
of
the
critical
additional
MRLs
for
AZM
alternatives.
17
The
Agency
is
also
proposing
the
following
mitigation
measures
to
reduce
the
risks
during
this
phase­
out
period.

­
require
label
amendments
reducing
the
application
rate
to
1
lb
ai/
A/
year
­
require
label
amendments
increasing
the
REI
to
14
days
for
both
lowbush
and
highbush
blueberries
­
require
label
amendments
to
establish
buffer
zones
around
houses
and
occupied
buildings
­
increase
buffer
zones
around
water
bodies
from
25
to
100
feet
­
issue
a
data
call­
in
to
conduct
medical
monitoring
of
post­
application
workers
­
require
label
amendments
to
eliminate
u­
pick
operations
­
eliminate
aerial
application.

Cherries
(
sweet
and
tart)

Current
Use
parameters
Label
rate:
0.75
lbs
ai/
A
per
application
Max
application
rate:
1.5
lbs
ai/
A
per
season
Minimum
14
days
between
applications
Typical
rate:
0.64
lbs
ai/
A
for
tart
cherries,
2.7
applications
per
year
0.46
lbs
ai/
A
for
sweet
cherries,
2
applications
per
year
Current
REI:
tart
cherries:
2
days
for
all
activities
sweet
cherries:
15
days
for
hand
harvesting,
2
days
for
all
other
activities
and
30
days
for
u­
pick
Current
PHI:
15
days
Worker
Risks
Of
particular
concern
are
the
relatively
low
margins
of
exposure
(
MOE)
for
post
application
activities
in
cherry
orchards.
As
explained
above
in
the
summary
of
worker
risk,
the
target
MOE
for
these
activities
is
100.
After
14
days,
the
MOE
for
harvesting
cherries
in
New
York
or
Oregon
is
14.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers
performing
these
activities.
Based
on
the
grower
impact
assessment,
setting
the
REI
longer
than
14
days
to
achieve
an
MOE
that
does
not
present
risks
of
concern
would
not
be
feasible
for
this
chemical
on
cherries.
Further,
additional
worker
protection
mitigation
measures
such
as
more
clothing
or
gloves
for
these
activities
are
not
considered
feasible
due
to
heat
stress
and
other
factors
associated
with
these
activities.

Also
EPA
has
estimated
an
MOE
of
36
for
mixer/
loader/
applicators
using
an
open
cab
for
airblast
application
to
cherries.
This
result
was
also
based
on
biomonitoring
data
of
current
use
practices.
This
risk
can
be
mitigated
through
the
use
of
engineering
controls
such
as
closed
systems
and
closed
cabs.
With
closed
systems
and
closed
cabs,
the
MOEs
for
these
pesticide
handlers
would
be
205.
18
Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

The
use
of
AZM
on
cherries
poses
risks
to
aquatic
and
terrestrial
animals.
Aquatic
exposures
were
modeled
for
Michigan
cherries,
and
various
drift
scenarios
were
considered.
Even
if
drift
could
be
reduced
to
1%,
there
still
would
be
acute
and
chronic
concerns.

For
terrestrial
animals,
modeled
dietary
exposures
for
small,
medium
and
large
birds
and
mammals
are
at
risk
regardless
of
preferred
food
items.
Mean
dietary
residues
are
also
likely
to
exceed
known
acute
and
chronic
thresholds
for
birds
and
mammals.

The
states
of
California,
Oregon,
and
Washington
have
declared
water
bodies
in
their
state
as
impaired
due
to
AZM
use
(
a
total
of
five
water
bodies).
Three
of
the
five
impaired
water
bodies
are
associated
with
AZM
treatments
on
stone
fruits
such
as
cherries
(
Colusa
Basin
Drain
(
Central
Valley),
Orestimba
Creek
 
above
Kilburn
Road
(
Central
Valley),
and
Orestimba
Creek
 
below
Kilburn
Road
(
Central
Valley)
in
California).

The
endangered
slamonid
species
assessment
concluded
that
counties
where
cherries
are
grown
in
the
Pacific
Northwest
overlap
with
the
spawning,
rearing
and/
or
migration
corridors
for
more
than
20
listed
salmon
groups.

Grower
Impacts
­
Sweet
Cherries
Sweet
cherries
are
primarily
produced
in
four
states:
California,
Michigan,
Oregon,
and
Washington.

The
cost
of
currently
available
AZM
alternatives
and
recent
efficacy
data
on
these
pesticides
suggests
that
grower­
level
(
per
acre)
impacts
of
the
loss
of
AZM
for
eastern
(
largely
Michigan)
sweet
cherry
growers
may
be
as
high
as
11
%
loss
in
net
cash
returns,
while
in
Washington
such
losses
are
approximately
2
%.
It
appears
that
effective
new
pest
control
alternatives
(
such
as
thiamethoxam,
multiple
sprays
of
synthetic
pyrethroids,
and
spinosad)
now
exist
that
should
allow
growers
to
meet
the
stringent
quality
standards
required
by
the
sweet
cherry
market.
However,
increases
in
production
costs
are
potentially
significant
for
individual
growers,
at
least
in
the
eastern
U.
S.
Calculated
losses
reflect
the
increased
production
costs
incurred
by
the
need
to
apply
multiple
treatments
of
some
alternatives,
or
the
much
higher
costs
of
other
materials.
Phosmet
is
not
an
alternative
to
AZM
for
sweet
cherries
because
of
phytotoxicity
concerns.

Grower
Impacts
­
Tart
Cherries
Michigan
is
the
primary
producer
of
tart
cherries,
accounting
for
over
70
percent,
followed
by
Washington,
Utah,
and
New
York.
Less
than
one
percent
of
production
is
19
marketed
as
fresh;
the
primary
processed
use
is
as
frozen
cherries
although
a
significant
portion
is
canned.
Bearing
acreage
of
tart
cherries
have
been
declining
steadily
in
the
U.
S.
for
at
least
the
past
decade,
although
the
decline
has
lessened
in
recent
years
and
may
even
have
stabilized.

Based
on
the
current
availability
of
efficacious
alternatives
to
AZM
to
control
plum
curculio
and
cherry
fruit
fly
in
tart
cherries
the
benefits
derived
from
the
use
of
AZM
are
likely
to
be
small.
In
the
absence
of
AZM,
growers
would
most
likely
use
phosmet
to
maintain
the
local,
state,
and
federal
mandated
zero
tolerance
for
these
pests.
Use
of
phosmet
would
likely
raise
production
costs
by
around
$
10
to
$
25
per
acre.
This
could
amount
to
two
to
four
percent
of
a
grower's
net
cash
returns
(
gross
revenue
minus
operating
costs).
However,
recent
increases
in
the
price
of
tart
cherries
may
mean
that
the
benefits
of
AZM
as
a
percent
of
net
cash
returns
are
smaller.

Status
of
MRLs
for
AZM
Alternatives
 
The
leading
export
markets
for
cherries
include
Japan,
Canada,
Taiwan,
the
United
Kingdom,
and
Australia.
 
The
main
alternatives
listed
by
BEAD
in
its
2005
assessment
are
phosmet,
lambda
cyhalothrin,
imidacloprid,
spinosad,
and
thiamethoxam.
 
The
top
5
export
countries
have
an
MRL
established
for
phosmet.
Japan
has
MRLs
established
for
all
the
main
AZM
alternatives.
Australia
and
Canada
have
MRLs
established
or
proposed
for
4
of
the
5
main
alternatives.

Table
6.
Cherries
(
sweet
and
tart):
Availability
of
MRLs
for
selected
alternatives
to
AZM
Country
Phosmet
Lambda
Cyhalothrin
Imidacloprid
Spinosad
Thiamethoxam
Japan
0.1
0.5
3
0.2
5
Canada
7
­
3
0.1b
0.02b
Taiwan
2
a
­
­
­
­
UK
2d
­
­
0.2
a
­
Australia
1
a
0.1
0.5
a
1.0a
­

US
10
0.5
3
0.2
0.5
Codex
c
10
­
{
0.5}
0.2
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com);
Northwest
Horticultural
Council
(
www.
nwhort.
org).
Notes:
a
From
Northwest
Horticultural
website
only.
b
Proposed
per
PMRA
Website
http://
www.
pmra­
arla.
gc.
ca/
english/
legis/
max­
re­
e.
html.
c
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
d
EU
MRL
{}
=
under
development
according
to
the
Report
of
the
Thirty
Eighth
Session
of
the
Codex
Committee
on
Pesticide
Residues,
Fortaleza
Brazil,
3­
8
April,
2006.
Available
at
http://
www.
codexalimentarius.
net.
­
=
MRL
not
listed
in
the
databases
examined.
*
MRL
figures
are
given
in
parts
per
million
(
ppm),;
Codex
values
are
in
mg/
kg.,
which
are
equivalent.

Proposed
decision/
Mitigation
Rationale
20
The
cherry
use
of
AZM
presents
high
ecological
risks
and
potentially
high
risk
to
workers,
especially
re­
entry
workers.
While
the
impact
to
growers
of
losing
AZM
is
less
than
with
the
apple
and
pear
uses,
the
absence
of
certain
MRLs
in
certain
export
markets
could
have
an
impact
on
growers
selling
to
those
markets,
Accordingly,
as
with
apples,
pears,
and
blueberries,
EPA
is
proposing
to
phase­
out
the
use
of
AZM
on
cherries
in
2010.

As
discussed
above,
EPA
believes
it
is
likely
that
by
2010
there
will
be
in
place
additional
MRLs
for
AZM
alternatives
in
export
countries
for
cherries,
that
will
eliminate
the
concern
for
possible
impacts
to
the
US
export
market.
Should
that
not
be
the
case,
however,
EPA
would
consider
appropriate,
time­
limited
requests
to
extend
AZM
use
on
cherries
for
a
period
necessary
for
the
development
of
the
critical
additional
MRLs
for
AZM
alternatives.

In
addition,
during
the
phase­
out
period,
the
following
mitigation
is
proposed:

­
require
label
amendment
to
increase
buffer
zones
around
water
bodies
from
25
to
100
feet
­
require
label
amendment
to
establish
buffer
zones
around
houses
and
occupied
buildings
­
issue
a
data
call­
in
to
conduct
medical
monitoring
of
post­
application
workers
­
require
label
amendment
to
eliminate
u­
pick
operations
Almonds
Current
Use
Parameters
Label
rate:
1.5
 
2.0
lbs
lbs
ai/
A
per
application,
maximum
of
one
application
per
season
Typical
rate:
1.85
lbs
ai/
A
per
application
Current
REI:
30
days
Current
PHI:
30
days
Worker
Risks
For
post
application
activities
on
almonds,
MOEs
range
from
170
to
790
for
rakers,
sweepers,
and
shakers
at
the
labeled
restricted
entry
interval
(
REI)
of
30
days.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers
performing
these
activities.

The
calculated
MOE
of
14
for
open
cab
applications
to
almonds
is
of
concern.
This
estimate
is
also
based
on
biomonitoring
of
current
use
practices.
With
closed
cabs,
the
MOEs
for
these
pesticide
handlers
would
be
80.
21
Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

The
use
of
AZM
on
almonds
poses
risks
to
aquatic
and
terrestrial
animals.
Aquatic
exposures
were
modeled
for
California
almonds,
and
various
drift
scenarios
were
considered.
Even
if
drift
could
be
reduced
to
1%,
there
would
still
be
acute
and
chronic
concerns.

Recent
NAWQA
monitoring
data
indicate
that
there
continue
to
be
AZM
detections
above
the
level
of
concern
in
nut­
growing
areas,
three
of
five
impaired
water
bodies
are
associated
with
AZM
treatments
on
nuts
(
Colusa
Basin
Drain
(
Central
Valley),
Orestimba
Creek
 
above
Kilburn
Road
(
Central
Valley),
and
Orestimba
Creek
 
below
Kilburn
Road
(
Central
Valley)
in
California).

The
endangered
slamonid
species
assessment
concluded
that
counties
where
almonds
are
grown
in
California
overlap
with
the
spawning,
rearing
and/
or
migration
corridors
for
four
listed
salmon
groups.

Grower
Impacts
The
loss
of
AZM
use
is
unlikely
to
have
significant
impacts
on
the
almond
industry
because
there
are
several
alternative
chemicals
that
can
be
used
for
the
pests
of
concern.
AZM
is
applied
to
about
10%
of
the
total
almond
acreage
in
the
US.
Almond
growers
have
several
alternatives
to
AZM
that
are
currently
being
used,
and
the
Agency's
economic
analysis
shows
minimal
loss
if
growers
switch
to
these
alternatives.

The
main
alternatives
for
AZM
use
on
almonds
listed
by
BEAD
in
its
scenarios
in
2005
assessment
are
chlorpyrifos,
phosmet,
spinosad,
esfenvalerate,
and
permethrin.
The
Agency's
economic
analysis
shows
minimal
loss
if
growers
switch
to
these
alternatives.
The
following
is
a
summary
of
the
impacts
on
revenue
as
a
result
of
switching
to
each
of
these
alternatives.

1.
Phosmet
alternative:
0.1%
­
0.3%
reduction
in
per
acre
net
revenue.
2.
Chlorpyrifos
alternative:
2.0%
­
2.8%
increase
in
per
acre
net
revenue.
3.
Non­
OPs
(
spinosad,
esfenvalerate,
permethrin):
0.2%
reduction
in
per
acre
net
revenue
to
5.3%
increase
in
per
acre
net
revenue.

There
are
minimal
estimated
losses
from
the
elimination
of
AZM
as
a
pesticide
on
almonds,
in
fact,
growers
may
see
an
increase
in
their
net
revenues
when
they
move
away
from
AZM
and
use
lower
cost
alternatives.
The
Agency
did
not
assess
the
availability
of
MRLs
for
AZM
alternatives
used
on
almonds.
However,
because
only
10
percent
of
the
crop
is
currently
treated
with
AZM
and
the
crop
is
being
treated
with
numerous
other
alternative
insecticides,
EPA
assumes
that
the
loss
of
AZM
will
have
no
significant
impact
on
the
almond
export
market.
22
Proposed
Decision/
Mitigation/
Rationale
Based
on
high
ecological
risks
and
low
impacts
to
growers,
the
Agency
finds
that
the
risks
outweigh
the
benefits
of
the
use
of
AZM
on
almonds
and
therefore
is
proposing
to
phase­
out
the
use
of
AZM
on
almonds
in
2007.

Pistachios
Current
Use
Parameters
Label
rate:
2.0
lbs
lbs
ai/
A
per
application,
maximum
of
one
application
per
season
Typical
rate:
1.85
lbs
ai/
A
per
application
Current
REI:
21
days
Current
PHI:
21
days
Worker
Risks
For
post
application
activities
on
pistachios,
the
MOE
for
rakers,
sweepers,
and
shakers
at
18
days
is
102.
As
explained
in
the
summary
of
worker
risk,
the
target
MOE
is
100.
The
labeled
REI
requirement
for
pistachios
is
21
days,
so
there
are
no
risks
of
concern
for
workers
as
long
as
they
adhere
to
the
labeled
REI.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers
performing
these
activities.

The
calculated
MOE
of
14
for
open
cab
applications
to
pistachios
is
of
concern.
This
estimate
is
also
based
on
biomonitoring
of
current
use
practices.
With
closed
cabs,
the
MOEs
for
these
pesticide
handlers
would
be
80.

Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

The
use
of
AZM
on
pistachios
poses
risks
to
aquatic
and
terrestrial
animals.
Aquatic
exposures
were
modeled
for
California
pistachios
and
various
drift
scenarios
were
considered.
Even
if
drift
could
be
reduced
to
1%,
there
would
still
be
acute
and
chronic
concerns.

Recent
NAWQA
monitoring
data
indicate
that
there
continue
to
be
AZM
detections
above
the
level
of
concern
in
nut­
growing
areas,
three
of
five
impaired
water
bodies
are
associated
with
AZM
treatments
on
nuts
(
Colusa
Basin
Drain
(
Central
Valley),
Orestimba
Creek
 
above
Kilburn
Road
(
Central
Valley),
and
Orestimba
Creek
 
below
Kilburn
Road
(
Central
Valley)
in
California).
23
The
endangered
slamonid
species
assessment
concluded
that
counties
where
pistachios
are
grown
in
California
overlap
with
the
spawning,
rearing
and/
or
migration
corridors
for
one
listed
salmon
group.

Grower
Impacts
The
loss
of
AZM
use
is
unlikely
to
have
a
large
impact
on
the
pistachio
industry
because
there
are
several
alternative
chemicals
that
can
be
used
for
pests
of
concern
and
are
less
expensive
than
AZM.
Although
AZM
is
applied
to
about
24%
of
the
total
pistachio
acreage
in
the
US,
pistachio
growers
have
several
alternatives
to
AZM
that
are
currently
being
used.
Because
efficacious
alternatives
exist,
EPA
assumes
there
will
be
no
yield
or
quality
loss
from
using
another
chemical
in
place
of
AZM.
The
Agency's
economic
analysis
shows
no
loss
if
growers
switch
to
these
alternatives.

The
main
alternatives
listed
by
BEAD
in
its
2005
impact
assessment
are
permethrin,
phosmet,
tebufenozide,
and
methoxyfenozide.

There
are
no
estimated
losses
from
the
elimination
of
AZM
as
a
pesticide
on
pistachios.

Proposed
Decision/
Mitigation/
Rationale
Based
on
high
ecological
risks
and
low
impacts
to
growers,
the
Agency
finds
that
the
risks
outweigh
the
benefits
of
the
use
of
AZM
on
pistacios,
and
is
therefore
proposing
to
phase­
out
this
use
in
2007.

Walnuts
Current
Use
Parameters
Label
rate:
1.5
­
2.0
lbs
lbs
ai/
A
per
application,
maximum
of
one
application
per
season
Typical
rate:
1.23
lbs
ai/
A
per
application
Current
REI:
30
days
Current
PHI:
30
days
Worker
Risks
For
post
application
activities
on
walnuts,
MOEs
range
from
170
to
790
for
rakers,
sweepers,
and
shakers
at
the
labeled
REI
requirement
of
30
days.
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers
performing
these
activities.

The
calculated
MOE
of
14
for
open
cab
applications
to
walnuts
is
of
concern.
This
estimate
is
also
based
on
biomonitoring
of
current
use
practices.
With
closed
cabs,
the
MOEs
for
these
pesticide
handlers
would
be
80.
24
Ecological
Risks
(
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.)

The
use
of
AZM
on
walnuts
poses
risks
to
aquatic
and
terrestrial
animals.
Aquatic
exposures
were
modeled
for
California
walnuts,
and
various
drift
scenarios
were
considered.
Even
if
drift
could
be
reduced
to
1%,
there
would
still
be
acute
and
chronic
concerns.

Recent
NAWQA
monitoring
data
indicate
that
there
continue
to
be
AZM
detections
above
the
level
of
concern
in
nut­
growing
areas,
three
of
five
impaired
water
bodies
are
associated
with
AZM
treatments
on
nuts
(
Colusa
Basin
Drain
(
Central
Valley),
Orestimba
Creek
 
above
Kilburn
Road
(
Central
Valley),
and
Orestimba
Creek
 
below
Kilburn
Road
(
Central
Valley)
in
California).

The
endangered
salmonid
species
assessment
concluded
that
counties
where
walnuts
are
grown
in
California
overlap
with
the
spawning,
rearing
and/
or
migration
corridors
for
more
than
20
listed
salmon
groups.

Grower
Impacts
The
loss
of
AZM
is
unlikely
to
have
a
large
impact
on
the
walnut
industry
because
there
are
several
alternative
chemicals
that
can
be
used
for
pests
of
concern
and
are
less
expensive
than
AZM.
Additionally,
AZM
is
only
applied
to
about
5%
of
the
total
walnut
acreage
in
the
U.
S.
Walnut
growers
have
several
alternatives
to
AZM
that
are
currently
being
used.
Because
efficacious
alternatives
exist,
in
some
cases
at
lower
prices,
EPA
assumes
there
will
be
no
significant
yield
or
quality
loss
from
using
other
chemicals
in
place
of
AZM.
The
Agency's
economic
analysis
shows
little
to
no
loss
if
growers
switch
to
these
alternatives.
Additionally,
walnut
acreage
in
the
U.
S.
has
increased
in
recent
years,
and
AZM
use
has
decreased
in
recent
years,
indicating
that
growers
have
decreased
reliance
on
AZM.

The
main
alternatives
listed
by
BEAD
in
its
scenarios
in
2005
are
methyl
parathion,
methidathion,
phosmet,
carbaryl,
esfenvalerate,
permethrin,
lambda­
cyhalothrin,
spinosad,
Bt,
tebufenozide,
methoxyfenozide,
and
diflubenzuron.

The
elimination
of
AZM
as
a
pesticide
on
walnuts
may
result
in
an
increase
or
decrease
in
per
acre
net
revenue
depending
upon
the
alternative
chosen.

Proposed
Decision/
Mitigation/
Rationale
Based
on
high
ecological
risks
and
low
impacts
to
growers,
EPA
is
proposing
to
phaseout
the
use
of
AZM
on
walnuts
in
2007,
because
the
Agency
finds
that
the
risks
outweigh
the
benefits
of
this
use.
25
Brussels
sprouts,
Nursery
Stock,
and
Parsley
Current
Use
Parameters
Brussels
sprouts
Label
rate:
0.75
lb
ai/
A
per
application;
maximum
of
one
application
per
season
to
soil
at
transplant
Current
REI:
7
days
Current
PHI:
7
days
Nursery
Stock
Label
rate:
1
lb
ai/
A
per
application;
maximum
of
4
applications
per
season
in
association
with
state
nursery
stock
inspection
and
certification
requirements
only.
Current
REI:
4
days
Current
PHI:
30
days
between
treatment
and
sale
of
plants
Parsley
Label
rate:
0.5
lb
ai/
A
per
application;
maximum
of
3
applications
per
season
Current
REI:
7
days
Current
PHI:
7
days
Use
restrictions:
Restricted
to
New
Jersey
and
Ohio
Worker
Risks
Brussels
sprouts
As
explained
in
the
summary
of
worker
risk,
the
target
MOE
is
100.
For
occupational
handlers,
the
calculated
MOE
for
mixer/
loaders
supporting
groundboom
applications
on
Brussels
sprouts
is
62
with
engineering
controls.
For
applicators
applying
sprays
for
groundboom
application,
the
MOE
with
engineering
controls
is
127.
These
estimates
are
based
on
default
Agency
assumptions
and
may
overestimate
risk.

No
post
application
exposure
is
expected
from
AZM
use
on
Brussels
sprouts;
therefore
no
post
application
scenarios
were
assessed.

Nursery
Stock
The
calculated
MOE
of
20
for
open
cab
applications
to
nursery
stock
is
of
concern.
This
estimate
is
based
on
surrogate
biomonitoring.
MOEs
for
these
pesticide
handlers
could
be
raised
to
140
with
the
use
of
closed
cabs.

For
post
application
activities
on
nursery
stock,
the
MOE
is
23
at
7
days.
The
labeled
REI
is
currently
4
days.
The
MOE
would
be
below
the
Agency's
level
of
concern
if
there
were
an
REI
of
18
days
(
MOE
would
be
102).
These
results
are
based
on
refined
data,
including
consideration
of
actual
biomonitoring
of
workers.

Parsley
26
As
explained
in
the
summary
of
worker
risk,
the
target
MOE
is
100.
For
occupational
handlers,
the
calculated
MOEs
for
mixer/
loaders
supporting
groundboom
applications
on
parsley
are
93
with
engineering
controls.
For
applicators
applying
sprays
for
groundboom
application,
the
MOE
with
engineering
controls
(
enclosed
cabs)
is
191.
These
estimates
are
based
on
default
Agency
assumptions
and
may
overestimate
risk.

For
post
application
activities
on
parsley,
the
MOE
at
42
days
is
100.
The
labeled
REI
is
currently
30
days.
These
estimates
are
based
on
default
Agency
assumptions
as
no
appropriate
biomonitoring
data
were
available.

Ecological
Risks
See
the
above
Summary
of
Ecological
Risk
Concerns
for
more
information.
Due
to
the
small
acreage
of
these
crops,
ecological
risk
is
of
somewhat
less
concern
than
for
larger
acreage
crops.

Grower
Impacts
Brussels
sprouts
The
loss
of
AZM
use
is
unlikely
to
have
a
large
impact
on
the
Brussels
sprouts
industry
because
there
are
alternative
chemicals
that
can
be
used
for
pests
of
concern
and
are
less
expensive
than
AZM.
AZM
is
applied
to
about
7%
of
the
total
Brussels
sprouts
acreage
in
the
U.
S.
Brussels
sprouts
growers
have
several
alternatives
to
AZM
that
are
currently
being
used.
Many
of
these
alternatives
cost
the
same
or
less
than
AZM.

The
main
alternatives
listed
by
BEAD
in
its
scenarios
in
2005
are
chlorpyrifos,
acetamiprid,
pyretrozine,
and
fenpropathrin.

EPA
does
not
anticipate
any
export
or
MRL
issues
for
Brussels
sprouts
due
to
the
loss
of
AZM.

Nursery
Stock
The
loss
of
AZM
use
is
unlikely
to
have
a
large
impact
on
the
nursery
stock
industry
because
there
are
alternative
chemicals
that
can
be
used
for
pests
of
concern.
AZM
is
applied
to
about
1%
of
the
total
nursery
stock
acreage
in
the
U.
S.
Several
comments
from
the
Southern
Integrated
Pest
Management
Center
indicate
that
AZM
use
in
nursery
stock
is
currently
not
critical
for
any
major
insect
pest.
Nursery
stock
growers
have
several
alternatives
to
AZM
that
are
currently
being
used.

The
main
alternatives
listed
by
BEAD
in
its
scenarios
in
2005
are
acephate,
cryolite,
cyfluthrin
+
imidacloprid,
chlorpyrifos,
bifenthrin,
imidacloprid,
and
parasitic
nematodes.

The
Agency
does
not
anticipate
any
export
or
MRL
issues
for
nursery
stock
due
to
the
loss
of
AZM.

Parsley
27
AZM
is
used
on
less
than
1%
of
the
national
parsley
crop.
Most
of
the
nation's
domestic
parsley
crop
is
grown
in
California,
with
scattered
production
in
other
states,
such
as
Ohio
and
Arizona.
In
parsley,
AZM
is
labeled
for
the
control
of
the
carrot
weevil
(
Listronotus
oregonensis),
which
is
a
pest
unique
to
parsley
in
Ohio.
There
are
few
alternative
insecticides
with
the
carrot
weevil
specifically
listed
on
their
labels.
For
example,
spinosad
does
not
list
the
weevil
as
a
target
pest,
but
may
have
efficacy
for
its
control.
Pyrethrins
does
list
the
weevil,
but
apparently
is
effective
only
during
cold
weather.
Cultural
controls
also
play
a
role
in
reducing
the
survival
of
the
carrot
weevil.
Based
on
the
very
low
recent
usage
of
AZM,
and
the
availability
of
alternative
chemical
and
cultural
controls,
for
the
majority
of
U.
S.
parsley
production,
the
impact
of
the
loss
of
AZM
will
be
minimal,
with
possibly
greater
impacts
in
Ohio
due
to
constraints
on
available
alternatives
EPA
does
not
anticipate
any
export
issues
for
parsley
due
to
the
loss
of
AZM.

Proposed
Decision/
Mitigation/
Rationale
Based
on
ecological
risks
and
minimal
impacts
to
growers,
EPA
is
proposing
to
phaseout
the
use
of
AZM
on
Brussels
sprouts
and
nursery
stock
in
2007.
EPA
is
proposing
to
phase
out
AZM
use
on
parsley
in
2010
because
while
it
too
presents
ecological
risks
of
concern,
it
also
appears
to
have
relatively
high
regional
benefits,
and
a
phase
out
will
allow
those
few
parsley
growers
in
Ohio
and
other
eastern
states
to
transition
to
alternatives.

Debra
Edwards,
Ph.
D.,
Director
Special
Review
and
Reregistration
Division
