UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
May
23,
2005
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
BEAD
Deliverables
for
the
EBDC
RED
DP
Barcode:
D305829
FROM:
Richard
E.
Michell,
Ph.
D.,
Plant
Pathologist
Bill
Phillips,
MSc.,
Agronomist
Biological
Analysis
Branch
David
Donaldson,
Economist
Economic
Analysis
Branch
THRU:
Arnet
Jones,
Chief
Biological
Analysis
Branch
David
Widawsky,
Chief
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503C)

TO:
Tawanda
Spears,
Maneb
&
Metiram
CRM
Christina
Scheltema,
Mancozeb
CRM
Reregistration
Branch
3
Special
Review
&
Reregistration
Division
(
7508C)

Product
Review
Panel
Completed:
April
20,
2005
Introduction
The
Agency
prepared
the
deliverables
in
this
document
during
Phases
2
and
3
of
the
reregistration
process
for
the
ethelenebisdithiocarbamate
(
EBDC)
fungicides
(
mancozeb,
maneb,
metiram)
to
obtain
additional
information
about
specific
use
patterns
of
concern
and
to
potentially
refine
risks
identified
in
the
risk
assessments.

Summary
of
Requests,
Conclusions
and
Deliverables
I]
Sod
Farm
Use:
SRRD
requested
that
BEAD
explore
several
different
issues
associated
with
EBDC
use
on
sod
farm
turf.
The
information
was
to
be
used
to
estimate
typical
human
exposure
levels
in
newly
established
residential
sod
lawns.
The
information
requested
included:
1)
common
post­
application
practices
associated
with
the
harvest,
2)
shipment,
installation,
and
establishment
of
sod
in
a
residential
setting,
3)
maximum
feasible
preharvest
interval
(
PHI),
typical
rates
and
application
practices
on
sod
farms.

A
summary
of
BEAD's
Conclusions
follows:
1.
Common
post­
application
practices
in
residential
destined
sod:
Given
the
reentry
interval
(
REI)
of
one
day
plus
a
one
to
three
day
planting
window,
the
minimum
time
that
would
elapse
between
treatment
and
installation
of
sod
in
a
residential
setting
would
be
within
the
range
of
two
to
four
days.
However,
the
frequent
and
long
duration
of
watering
of
newly
installed
sod
and
the
need
to
restrict
foot
traffic
for
several
weeks
after
planting
should
also
serve
to
deter
people
from
using
newly
installed
sod.
Additionally,
when
harvested
sod
is
stacked
or
rolled
for
shipment,
the
moist
roots
and
soil
are
in
contact
with
the
sod
foliage
and
may
impact
the
level
of
EBDC
residue
exposure
after
the
sod
is
installed.
Note:
Comments
submitted
by
the
EBDC
Task
Force
also
support
these
findings.
2.
Maximum
PHI:
Through
information
obtained
from
Florida
(
FL),
the
maximum
PHI
acceptable
to
sod
growers
would
be
two
days.
3.
Typical
rates,
number
of
applications
and
use
practices
on
sod
farms:
While
BEAD
was
unable
to
obtain
nationwide
data
on
typical
application
rates
for
EBDC
fungicides
used
on
sod
farms,
feedback
from
FL
indicate
that
a
maximum
use
rate
of
about
15
lbs.
ai/
A
is
commonly
used
when
severe
pest
pressure
conditions
exist,
and
lower
rates
are
used
when
lower
disease
pressure
exists.
Since
the
nationwide
typical
application
rate
used
on
golf
courses
ranged
from
9
to
14
lbs.
ai/
A
and
averaged
about
10.5
lbs.
ai/
A
(
see
Appendix
B),
BEAD
suggests
that
these
rates
may
be
somewhat
representative
of
the
rates
used
on
sod
farms.
FL
sod
farm
information
also
indicated
that
a
maximum
of
4
to
5
applications
may
be
applied
during
the
10­
to
14­
month
crop
cycle,
however
a
nationwide
survey
indicates
that
on
average
about
2
fungicide
applications
are
applied
per
year.
See
Appendix
A
for
BEAD's
full
assessment
and
supporting
information.
Note
that
Appendix
A
differs
from
the
original
version
submitted
in
that
it
now
addresses
the
dosage
rate
issue.

II]
Recreational
Turf
Use
of
EBDC
Fungicides:
Due
to
human
post
application
exposure
risk
concerns,
BEAD
was
asked
to
characterize
the
use
of
EBDC
fungicides
on
golf
courses,
and
other
recreational
turf,
including
the
average
application
rates,
number
of
applications
per
year,
and
percentage
of
courses
treated
in
support
of
the
assessment
of
occupational
exposure
to
mancozeb.
Since
the
data
indicate
that
little
if
any
maneb
is
used
our
response
only
includes
information
on
the
predominant
EBDC
fungicide
mancozeb.
The
available
data
indicate
that
about
19
percent
of
the
US
golf
courses
used
mancozeb
on
at
least
some
portion
of
their
turf
acreage.
The
typical
application
rate
used
on
golf
courses
ranged
from
9
to
14
lbs.
ai/
A
and
averaged
about
10.5
lbs.
ai/
A.
The
average
number
of
fungicide
applications
is
estimated
to
range
from
about
5
to
8
times
per
year.
Although
no
specific
information
was
available,
the
use
of
pesticides
in
general
on
sports
turf
is
reportedly
limited
to
professional
and
some
college
fields
and
is
estimated
to
involve
about
1
percent
of
the
sports
turf
acreage.
A
summary
of
the
relevant
information
available
is
provided
in
Appendix
B.
III]
Home
Garden
Use:
Due
to
human
risk
concerns
associated
with
hand
harvesting
of
sweet
corn,
BEAD
was
asked
to
determine
the
essentiality
of
foliar
treatments
to
sweet
corn
in
home
gardens.
BEAD
verbally
indicated
that
this
was
a
relatively
unimportant
use
for
homeowners
due
to
the
general
inability
of
homeowners
to
predict
or
recognize
the
labeled
diseases
(
Puccinia
rust,
Helminthosporium
leaf
spot)
plus
the
fact
that
these
diseases
seldom
cause
serious
damage
in
home
gardens.
Note:
USDA
also
provided
a
docket
comment
which
stated
that
home
sweet
corn
production
is
not
a
disease
management
intensive
scenario.

IV]
Metiram
Apple
Use:
Due
to
mixer/
loader
worker
exposure
risk
concerns,
determine
the
incidence
of
metiram
aerial
applications;
and
the
timing
of
ground
and
aerial
applications
relative
to
summer
pruning.
Aerial
application
use
was
investigated
in
the
seven
major
states
using
metiram
on
apples.
NY
was
the
only
State
reportedly
using
aerial
applications.
Such
use
was
estimated
to
occur
on
~
3
to
5
percent
of
the
metiram
treated
acreage
in
New
York.
Aerial
applications
typically
are
used
in
early
spring
when
the
ground
is
too
wet
for
ground
applications
and
when
trees
need
to
be
treated
quickly
before
disease
infections
occur.
Eighty­
three
percent
of
NY
orchards
are
<
50
acres
and
97
percent
are
less
than
250
acres.

Growers
have
two
use
pattern
choices
on
apples:
1)
apply
up
to
4.8
lbs.
ai/
acre/
application
between
green
tip
and
petal
fall,
or
use
up
to
2.4
lbs.
ai/
acre/
application
between
green
tip
and
77
days
before
harvest.
The
available
data
indicates
that
only
about
one­
third
of
users
choose
the
77­
day
preharvest
interval
(
PHI)
option.
BEAD
found
that
in
the
major
metiram
usage
states,
when
the
last
application
occurs
at
petal
fall
there
is
a
5
to
7
week
gap
between
the
last
application
and
the
beginning
of
summer
pruning.
For
those
growers
that
choose
to
use
the
alternate
77­
day
PHI
application
schedule,
the
gap
between
the
last
application
and
summer
pruning
narrows
to
about
1
to
3
weeks.

See
Appendix
C
for
BEAD
=

s
official
response
documents
on
these
two
issues.
Note:
Appendix
C
differs
from
the
original
version
submitted
by
the
inclusion
of
a
statement
which
addresses
the
77­
day
PHI
use
pattern.
Winter
pruning
was
not
addressed
since
it
occurs
in
the
dormant
season
prior
to
the
initial
green
tip
metiram
applications.

V]
Leatherleaf
Fern
Use:
Due
to
worker
exposure
concerns,
determine
the
number
of
metiram
applications
per
year.
Based
on
the
Florida
response,
metiram
use
is
minimal
on
Leatherleaf
Fern.
Therefore,
it
is
BEAD's
conclusion
that
a
seasonal
maximum
of
20
applications
per
calendar
year
would
be
more
than
sufficient
for
Leatherleaf
Fern
growers.
See
Appendix
D
for
BEAD
=

s
response
document.

VI]
Wettable
Powder
(
WP)
Formulations:
Due
to
worker
exposure
concerns,
determine
the
need
for
wettable
powder
formulations.
An
analysis
conducted
by
BEAD
found
that
there
is
no
niche
market
or
location
within
the
country
where
the
WP
formulations
are
used.
However,
the
data
did
show
that
of
all
EBDC
formulations,
the
WP
formulations
constitute
~
10%
of
the
market.
Overall,
BEAD
was
unable
to
determine
if
there
is
a
specific
need
for
the
WP
formulation.
Comments
received
by
the
EBDC
Task
force
stated
that
the
dry
flowable
or
flowable
formulation
allows
for
greater
ease
of
handling
than
wettable
powders.
See
Appendix
E.
VII]
Cut
Flower
Use:
Due
to
worker
exposure
concerns,
determine
the
maximum
number
of
EBDC
applications
likely
to
be
applied
per
year.
After
several
weeks
of
searching
for
information,
BEAD
determined
that
none
of
the
existing
studies
addressed
this
issue
and
we
would
have
to
contact
too
many
people
to
encompass
the
numerous
crops
and
states
involved.
Based
on
our
preliminary
searching
it
appeared
that
most
users
did
not
apply
any
one
fungicide
all
year
long.
In
addition,
a
public
comment
submitted
by
Mary
Hausbeck
of
the
University
of
Michigan,
stated
that
field
grown
cut
flowers
in
this
state
received
five
to
seven
applications
of
mancozeb
annually.
After
discussing
other
options
with
HED,
we
advised
them
that
an
annual
use
limitation
of
20
applications
should
be
proposed
as
a
risk
mitigation
measure.

VIII]
Mancozeb
Pear
24(
c)
use:
Although
BEAD
was
not
officially
requested
to
conduct
an
assessment
of
this
use,
it
was
mentioned
that
this
use
was
a
potential
concern
to
HED
because
it
involved
a
very
high
application
rate.
Accordingly,
we
conducted
a
cursory
inquiry
into
a
docket
comment
from
the
Northwest
Horticultural
Council
claiming
that
a
state
local
need
use
on
pears
for
control
of
pear
psyllid
is
important.
Our
findings
were
that
two
State
Local
Need
registrations
exist
for
use
in
Washington
State.
2002
NASS
data
indicate
that
the
6.4
lbs.
ai/
acre
rate
is
applied
an
average
of
1.1
times/
year
to
16
percent
of
the
acreage
grown
in
Washington.
The
Council
recommended
a
crop
specialist
that
could
be
contacted
for
obtaining
economic
impact
information.
See
Appendix
F
for
BEAD
=

s
report
on
this
inquiry.

IX]
Provide
Average
Application
Rates
and
Refine
EBDC
Usage
Data:
Average
EBDC
application
rates
were
provided
to
assist
in
the
dietary
and
occupational
risk
assessments.
Additionally,
more
refined
pesticide
usage
data
covering
the
pounds
applied
and
percent
crop
treated
for
metiram,
mancozeb,
and
maneb
were
provided
to
assist
in
refinement
of
the
dietary
risk
assessment.
These
data
were
delivered
to
the
SRRD
as
official
BEAD
documents
on
March
22
2005.
See
Appendix
G
for
application
rates.

X]
Public
Comments:
We
have
reviewed
the
public
comments
and
referred
to
relevant
information
when
completing
the
above
tasks.
The
information
from
the
public
comments
received
by
BEAD
from
SRRD
will
be
summarized
in
a
future
document.

Attachments:
Appendices
A
through
G
contain
BEAD's
official
response
documents.
APPENDIX
A
Information
Relating
to
Sod
Farms
and
EBDC
Use
and
Usage
Over
the
past
several
months
the
Agency
has
explored
several
different
issues
associated
with
EBDC
use
on
sod
farm
turf.

The
ultimate
concern
behind
the
requests
is
to
determine
the
typical
human
exposure
scenarios
in
newly
established
residential
lawns
from
sod.
The
various
types
of
information
we
were
asked
to
provide
were
common
post­
application
practices
in
residential
destined
sod,
maximum
preharvest
interval
(
PHI),
and
typical
rates
and
application
practices
on
sod
farms.

BEAD
collected
the
requested
information
from
several
different
sources,
as
follows:
1998
Sod
Farm
Use
and
Usage
survey
[
proprietary
data];
Florida
Fruit
and
Vegetable
Association
[
Mr.
M.
Aerts]
feedback
collected
from
anonymous
Florida
sod
farmers;
International
Sod
Producers
Association
[
Mr.
D.
Fender,
Executive
Director];
and
BEAD
expertise
accrued
from
personal
experience
and
previous
contacts
with
sod
specialists.

Summary
The
following
is
a
summary
of
the
information
arranged
by
subject
that
was
received
from
all
sources,
followed
by
the
individual
references
in
their
entirety.

1)
Identify
common
post­
application
practices
associated
with
sod
destined
for
use
in
residential
settings
that
should
impact
exposure.
a)
Pesticide
use
on
sod
farms
is
considered
an
agricultural
use
and
as
such
is
subject
to
Worker
Protection
Standards;
therefore
a
24
hour
REI
is
in
effect
for
mancozeb
use
on
sod
farms.
b)
Eighty
percent
of
the
sod
produced
is
intended
for
residential
use
and
involves
direct
purchases
by
landscape
firms
that
install
the
sod.
c)
Sod
must
generally
be
planted
between
24
and
72
hours
after
it
is
cut.
d)
On
6/
9/
04
SRRD
asked
whether
there
were
any
sod
industry
practices
that
could
lower
EBDC
residue
levels
on
newly
planted
sod.
i)
What
we
know
from
previous
experiences
and
personal
contacts
with
growers
and
turf
extension
specialists
is
that
turf
is
commonly
watered
prior
to
shipment
to
keep
the
roots
from
drying
out
prior
to
installation
at
the
final
planting
site.
ii)
Secondly,
when
sod
is
rolled
up,
or
layered
(
stacked),
for
shipment
the
roots
and
soil
directly
contact
the
foliage.
This
will
typically
result
in
a
layer
of
moist
soil
being
deposited
on
the
turf
foliage,
which
may
impact
the
level
of
EBDC
residue
exposure
after
the
sod
is
installed.
iii)
Additionally,
all
newly
planted
turf
is
supposed
to
be
watered
extensively
for
at
least
several
weeks.
Also
a
minimal
amount
of
foot
traffic
needs
to
be
observed
during
this
time
in
order
for
the
sod
to
become
firmly
established.
All
these
common
practices
are
perceived
as
measures
which
should
significantly
lower
exposure
and
levels
of
the
available
EBDC
and
metabolite
(
ethylenethiourea)
residues.
2)
The
maximum
preharvest
interval
(
PHI)
that
sod
farmers
could
utilize.
a)
The
maximum
acceptable
PHI
is
considered
to
be
2
days.
This
is
considered
to
be
necessary
by
FL
growers
because
they
have
weather
conditions
conducive
to
disease
problems
virtually
all
year
long
and
often
need
to
treat
two
days
before
harvest
due
to
the
extremely
disease­
favorable
microclimate
created
when
the
harvested
sod
is
stacked
(
i.
e.,
soil
and
roots
are
in
direct
contact
with
the
sod
foliage
until
the
sod
is
laid).
b)
Pesticide
use
on
sod
farms
is
considered
an
agricultural
use
and
as
such
is
subject
to
Worker
Protection
Standards;
therefore
a
24
hour
REI
is
in
effect
for
mancozeb
use
on
sod
farms.

3)
Typical
rates
of
EBDC
fungicides
and
application
practices
on
sod
farms.
a)
The
maximum
use
rate
is
about
15
lbs.
ai/
acre
and
would
apply
to
situations
when
either
severe
pest
pressure
conditions
exist,
or
curative
applications
are
utilized.
However,
typical
application
rates
are
lower.
b)
A
maximum
number
of
4
to
5
EBDC
applications
are
utilized
during
the
10
to14
month
crop
cycle.
c)
The
major
EBDC
target
pests
are
gray
leaf
spot
(
Pyricularia
grisea),
Pythium
blight
(
Pythium
spp.),
and
brown
patch
(
Rhizoctonia
solani).
d)
Specific
Fungicide
Information:
i)
Chlorothalonil
was
the
predominant
fungicide
used.
A
total
of
14,000
acretreatments
of
chlorothalonil
were
applied
which
constituted
about
37
percent
of
the
total
fungicide
usage.
ii)
Mancozeb
and
PCNB
fungicides
were
the
next
most
popular
fungicides.
A
total
of
about
5,000
acre­
treatments
of
each
of
these
two
fungicides
were
applied
which
constitutes
about
13
percent
of
the
total
fungicide
usage.
This
means
that
mancozeb
is
probably
used
on
about
2,600
acres,
which
equates
to
about
0.9
percent
of
the
total
turf
farm
acreage.
iii)
No
information
was
collected
on
the
actual
application
rates
utilized
on
sod
farms.
iv)
Based
on
the
label
rates
associated
with
the
target
pests
on
mancozeb
labels,
the
maximum
rate
(
17.4
lbs
ai/
A)
is
the
only
rate
recommended
for
a
third
of
the
pests
and
13
to
17.4
lbs
ai/
A
are
recommended
for
another
third
of
the
pests.
Accordingly,
without
specific
use
rate
data
we
can
presume
that
a
significant
number
of
users
are
likely
to
use
these
labeled
rates.
v)
Note:
Acre­
treatments
is
a
figure
obtained
by
multiplying
the
average
number
of
applications
by
the
base
acreage
treated.
Therefore
to
estimate
the
base
acreage
treated
you
divide
acre
treatments
by
the
average
number
of
applications.
In
this
survey,
the
national
average
number
of
applications
applied
was
1.9.

[
Bill
Phillips,
II,
21April2005]
Below
are
the
accounts
of
Dr.
Richard
Michell's
conversation
with
Doug
Fender
and
Michael
Aerts,
as
well
as
a
summation
of
the
1998
turf
farm
survey
[
proprietary
data].

A]
Personal
Communication
between
Richard
Michell
and
Doug
Fender,
Executive
Director
of
Turfgrass
Producers
International
­
5/
19/
04
1)
Doug
Fender
discussed
sod
farm
issues
that
relate
to
production
practices,
fungicide
use,
and
pesticide
use.
The
principal
points
he
made
are
as
follows:
2)
A
1998
study
reported
that
only
about
38,000
acre­
treatments
of
fungicides
were
applied
(
Note:
acre­
treatment
totals
include
multiple
treatments
to
the
same
areas).
3)
Pesticide
use
on
sod
farms
is
considered
an
agricultural
use
and
as
such
is
subject
to
Worker
Protection
Standards;
therefore
a
24
hour
REI
is
in
effect
for
mancozeb
use
on
sod
farms.
4)
Most
sod
fields
are
harvested
once
every
12­
18
months
and
contain
blends
of
different
grasses.
5)
Eighty
percent
of
the
sod
produced
is
intended
for
residential
use
and
involves
direct
purchases
by
landscape
firms
that
install
the
sod.
6)
Fungicide
use
is
minimal
on
sod
farms
and
sod
typically
will
not
be
sold
if
there
is
a
reasonable
risk
of
a
disease
problem
developing
when
or
soon
after
the
sod
is
received
and
observed
by
the
ultimate
residential
customers;
the
reason
for
this
is
that
sod
pickup
and
replacement
costs
are
high
and
there
is
a
need
to
maintain
repeat
business
customers
(
e.
g.,
landscape
firms).
7)
Sod
must
generally
be
planted
between
24
and
72
hours
after
it
is
cut.
8)
Only
a
small
percentage
(<
10%)
of
the
farms
are
totally
mechanized;
however;
this
should
increase
significantly
due
to
the
invention
of
a
new
highly
efficient
harvester
in
2003
which
is
in
such
demand
that
the
manufacturer
cannot
keep
up
with
the
demand.
9)
Average
farm
size
is
about
450
acres
(
ranges
from50­
75
to
several
thousand
acres).
10)
Growers
typically
farm
about
half
of
the
acreage
they
own
each
year.
11)
Most
growers
select
turf
varieties
that
do
not
require
high
pesticide
use
to
keep
their
costs
down.
Very
little
fungicide
usage
occurs
with
chlorothalonil
being
by
far
the
predominant
fungicide
used
when
one
is
needed;
mancozeb
was
one
of
the
second
most
used
fungicides.

___________________________________________________________________________
B]
6/
22/
04
Communication
with
Michael
Aerts,
Assistant
Director
of
the
Environmental
&
Pest
Management
Division,
FFVA,
regarding
FL
sod
grower
issues
associated
with
EBDC
fungicides.

His
major
points
were:
1)
The
maximum
acceptable
PHI
is
considered
to
be
2
days.
This
is
considered
to
be
necessary
by
FL
growers
because
they
have
weather
conditions
conducive
to
disease
problems
virtually
all
year
long
and
often
need
to
treat
two
days
before
harvest
due
to
the
extremely
diseasefavorable
microclimate
created
when
the
harvested
sod
is
stacked
(
i.
e.,
soil
and
roots
are
in
direct
contact
with
the
sod
foliage
until
the
sod
is
re­
laid).
2)
The
maximum
use
rate
is
about
15
lbs.
ai/
acre
and
would
apply
to
situations
when
either
severe
pest
pressure
conditions
exist,
or
curative
applications
are
utilized.
However,
typical
application
rates
are
lower.
3)
A
maximum
number
of
4
to
5
EBDC
applications
are
utilized
during
the
10
to14
month
crop
cycle.
4)
The
major
EBDC
target
pests
are
gray
leaf
spot
(
Pyricularia
grisea),
Pythium
blight
(
Pythium
spp.),
and
brown
patch
(
Rhizoctonia
solani).
5)
The
cost
of
using
one
of
the
newer
systemic
alternatives,
azoxystrobin
(
Heritage),
is
about
$
350/
acre.
6)
The
majority
of
the
EBDC
fungicide
alternatives
are
systemic
compounds
that
are
vulnerable
to
pest
resistant
problems.
Accordingly,
use
of
these
compounds
is
typically
limited
to
a
maximum
of
two
consecutive
applications,
after
which
at
least
one
application
of
an
alternative
chemistry
must
be
utilized.
Since
the
EBDC
fungicides
are
inexpensive
and
relatively
effective
non­
systemic
fungicides
they
are
often
the
fungicide
of
choice
to
serve
as
a
rotational
partner
for
the
systemic
fungicides.

On
6/
9/
04
SRRD
asked
whether
there
were
any
sod
industry
practices
that
could
lower
EBDC
residue
levels
on
newly
planted
sod.
What
I
know
from
previous
experiences
and
personal
contacts
with
growers
and
turf
extension
specialists
is
that
turf
is
commonly
watered
prior
to
shipment
to
keep
the
roots
from
drying
out
prior
to
installation
at
the
final
planting
site.
Secondly,
when
sod
is
rolled
up,
or
layered
(
stacked),
for
shipment
the
roots
and
soil
directly
contact
the
foliage.
This
will
typically
result
in
a
layer
of
moist
soil
being
deposited
on
the
turf
foliage,
which
may
impact
the
potential
level
of
EBDC
residue
exposure
after
the
sod
is
installed.
Additionally,
all
newly
planted
turf
is
supposed
to
be
watered
extensively
for
at
least
several
weeks.
Also
a
minimal
amount
of
foot
traffic
needs
to
be
observed
during
this
time
in
order
for
the
sod
to
become
firmly
established.
All
these
common
practices
are
perceived
as
measures
which
should
significantly
lower
exposure
and
levels
of
the
available
EBDC
and
metabolite
(
ethylenethiourea)
residues.
Additionally
we
concur
with
the
findings
of
the
EBDC
Task
Force
relative
to
the
post
treatment
use
practices
associated
with
the
harvesting,
installation,
and
establishment
of
sod
in
residential
settings,
that
were
submitted
in
response
to
the
risk
assessments.

___________________________________________________________________________
C]
Summary
of
the
results
of
a
1998
turf
farm
survey
[
proprietary
data],
which
are
relevant
to
the
use
of
mancozeb
and
fungicides
in
general.

1)
General
Information:
A
survey
was
based
on
175
respondents
out
of
1,683
farms,
which
equates
to
about
10%
of
the
population
of
farms.
The
turf
(
sod)
farm
information
was
presented
for
4
regions
(
south,
north
central,
northeast,
and
west)
as
well
as
from
a
national
perspective.
Turf
farms
exist
in
all
states
and
are
usually
situated
near
the
perimeter
of
large
metropolitan
areas.
2)
General
Sod
Production
Information:
About
303,000
acres
of
sod
are
produced
each
year
on
1,683
farms
with
an
average
size
of
about
180
acres/
farm.
The
regional
farm
size
averages
ranged
from
131
­
219
acres;
the
northeast
and
the
south
had
the
smallest
and
largest
average
farm
sizes,
respectively.
Growers
typically
take
steps
to
minimize
disease
problems
due
to
the
relatively
high
cost
of
fungicide
treatments.
Measures
include
selection
of
turf
types
and
varieties
least
likely
to
develop
disease
problems,
blending
of
several
different
turf
varieties,
and
proper
fertilization
and
watering
practices
to
induce
vigorous
plant
growth
and
minimize
the
creation
of
disease
favorable
conditions.
When
small
diseased
areas
develop,
growers
will
typically
destroy
the
diseased
turf
by
plowing
it
under,
as
a
means
of
halting
the
spread
of
the
disease.
Generally
disease
infestations
occur
in
limited
areas
of
a
farm
and
when
fungicide
treatments
are
used
they
are
only
applied
to
the
problem
areas.
The
number
of
turf
farms
in
the
south,
north
central,
west
and
northeast
regions
constitutes
about
47,
31,
14,
and
8
percent
of
the
total
number
of
farms,
respectively.
The
sod
production
acreage
in
the
south,
north
central,
west
and
northeast
regions
constitutes
about
57,
25,
12,
and
6
percent
of
the
total
acreage,
respectively.
3)
General
Fungicide
Information:
The
percentage
of
farms
using
fungicides
in
the
northeast,
south,
west
and
north
central
regions
were
71,
33,
27,
and
22,
respectively.
Although
the
northeast
region
had
the
highest
percentage
of
farms
using
fungicides,
the
total
acretreatments
are
actually
significantly
greater
in
the
south
and
north
central
regions
due
to
the
significantly
higher
volume
of
production
acreages
in
these
two
regions.
The
number
of
fungicide
applications
used
per
year
averaged
1.9
nationally.
The
average
number
of
applications
used
in
the
west,
northeast,
north
central
and
south
were
0.6,
1.6,
1.8
and
3.0,
respectively.
Fungicides
are
typically
applied
by
turf
farm
employees.
Nationally
there
were
38,000
acre­
treatments
of
fungicides
applied,
which
equates
to
about
20,000
acres
being
treated
based
on
the
average
number
of
applications
applied
per
year;
this
equates
to
fungicides
being
used
on
around
7%
of
the
total
acreage
grown.
4)
Specific
Fungicide
Information:
Chlorothalonil
was
the
predominant
fungicide
used.
A
total
of
14,000
acre­
treatments
of
chlorothalonil
were
applied
which
constituted
about
37
percent
of
the
total
fungicide
usage.
Mancozeb
and
PCNB
fungicides
were
the
next
most
popular
fungicides.
A
total
of
about
5,000
acre­
treatments
of
each
of
these
two
fungicides
were
applied
which
constitutes
about
13
percent
of
the
total
fungicide
usage.
This
means
that
mancozeb
is
probably
used
on
about
2,600
acres,
which
equates
to
about
0.9
percent
of
the
total
turf
farm
acreage.
No
information
was
collected
on
the
actual
application
rates
utilized
on
sod
farms.
Based
on
the
label
rates
associated
with
the
target
pests
on
mancozeb
labels,
the
maximum
rate
(
17.4
lbs
ai/
A)
is
the
only
rate
recommended
for
a
third
of
the
pests
and
13
to
17.4
lbs
ai/
A
are
recommended
for
another
third
of
the
pests.
Accordingly,
without
specific
use
rate
data
we
can
presume
that
a
significant
number
of
users
are
likely
to
use
these
labeled
rates.

Note:
Acre­
treatments
is
a
figure
obtained
by
multiplying
the
average
number
of
applications
by
the
base
acreage
treated.
Therefore
to
estimate
the
base
acreage
treated
you
divide
acre
treatments
by
the
average
number
of
applications.
In
this
survey,
the
national
average
number
of
applications
applied
was
1.9.
APPENDIX
B
Golf
Course
Use
of
Mancozeb
The
information
below
on
golf
course
use
of
mancozeb
is
provided
in
response
to
inquiries
by
HED
regarding
the
EBDC
chemicals
and
will
be
used
to
refine
their
occupational
risk
assessment
of
the
use
of
mancozeb
on
golf
courses.
The
information
is
based
on
two
market
research
databases
available
to
EPA
and
survey
data
taken
from
the
Golf
Course
Superintendent's
Association.
This
data
source
coverage
spans
the
years
2001,
2000,
1999,
and
1998.
Note
that
mancozeb
is
the
only
EBDC
fungicide
with
use
on
golf
courses,
according
to
the
available
data
sources.

Percent
of
golf
courses
using
mancozeb
1.
There
are
approximately
16,000
golf
courses
in
the
U.
S.
2.
The
available
data
indicates
that
approximately
3,000
of
them
use
mancozeb
on
an
annual
basis.
3.
Thus,
approximately
18.75%
of
golf
courses
in
the
U.
S.
use
mancozeb.

Application
rate
Use
of
mancozeb
on
golf
courses
averages
about
10.5
pounds
per
acre
nationally
and
over
95%
of
its
use
is
between
9
and
14
pounds.
Mancozeb
was
used
on
golf
courses
in
42
states.

Percent
of
acres
treated
1.
A
total
of
3%
of
the
approximately
16
million
acres
of
golf
courses
are
treated
with
mancozeb.
2.
A
maximum
of
12.5%
of
tees
are
treated
with
mancozeb.
3.
A
maximum
of
51
percent
of
greens
are
treated
with
mancozeb.
4.
A
maximum
of
5%
of
fairways
are
treated
with
mancozeb.

Number
of
applications
Data
describing
the
number
of
times
mancozeb
is
applied
annually
is
not
readily
available.
However,
the
below
general
fungicide
use
information
is
useful
in
setting
upper
bounds
on
mancozeb
usage.
1.
The
Golf
Course
Superintendent's
Association
report
indicates
that
all
fungicides
are
applied
to
golf
courses
an
average
of
6.1
times.
2.
EPA's
proprietary
data
indicates
that,
on
average,
greens
are
treated
8.3
times
with
a
fungicide
annually
and
tees
are
treated
5.1
times.
3.
Given
that
a
variety
of
fungicides
are
applied,
these
numbers
serve
as
a
very
conservative
upper
bound
to
the
number
of
applications.

Athletic
Field
Turf
Use
The
Sports
Turf
Managers
Association
CEO,
Kim
Heck,
reported
to
us
that
in
2001
the
total
US
sports
turf
acreage
was
estimated
to
be
~
7
million
acres.
She
also
referred
us
to
Dr.
Dave
Minner
(
Iowa
State
University,
Department
of
Horticulture
for
pesticide
usage
information.
Dr.
Minner
advised
us
that
pesticides
are
only
used
on
professional
and
some
college
fields
which
he
estimated
constitutes
~
1
percent
of
the
sports
turf
acreage.
[
R.
Michell
April
2005]
APPENDIX
C
Survey
of
the
Incidence
of
Metiram
Applications
on
Apples
Aerial
Based
on
the
states
identified
in
the
Nov.
1,
2002
QUA
report,
and
in
recent
usage
surveys
for
2001­
2003
(
EPA
proprietary
information),
over
75
percent
of
the
metiram
apple
usage
occurs
in
seven
states
(
MI,
NY,
VA,
NC,
PA,
OH,
SC).
Accordingly,
apple
fungicide
specialists
in
these
states
were
surveyed
to
determine
the
nature
and
extent
of
aerial
application
use.

The
responses
indicated
that
aerial
applications
are
only
known
to
exist
in
New
York
State,
which
grows
about
44,000
acres
of
apples.
The
reported
incidence
of
aerial
applications
was
estimated
to
range
from
3
to
5
percent
of
the
29,000
metiram­
treated
acres.
It
was
estimated
that
both
fixed­
wing
aircraft
and
helicopters
are
used
in
eastern
NY,
and
that
only
fixed
wing
aircraft
are
used
in
western
New
York.
Commercial
applicators
are
involved
in
applying
all
aerial
applications.

Aerial
applications
are
primarily
used
when
the
ground
is
too
wet
to
use
ground
equipment,
or
when
blocks
of
trees
need
to
be
quickly
treated
before
disease
infection
occurs.
Virtually
all
aerial
applications
are
made
in
early
spring
(
green
tip
thru
petal
fall)
because
the
post
bloom
cover
sprays
include
insecticides
that
require
the
use
of
ground
sprays
to
insure
optimal
coverage
of
foliage
and
developing
fruit.
It
was
reported
that
farms
50
to
100
acres
or
more
in
size
would
use
aerial
applications
and
that
trees
are
typically
planted
in
blocks
of
10
to
20
acres.
According
to
the
2002
Census
of
Agriculture
about
17
percent
of
NY
apple
farms
are
larger
than
50
acres
and
97
percent
are
less
than
250
acres
in
size.

The
fungicide
specialists
contacted
were:
Drs.
Mark
Longstroth
&
Phil
Schwallier
(
MI);
Drs.
David
Rosenberger
&
Deborah
Breth
(
NY);
Dr.
Keith
Yoder
(
VA);
Dr.
Turner
Sutton
(
NC);
Dr.
James
Travis
(
PA);
Dr.
Mike
Ellis
(
OH);
and
Dr.
Guido
Schnabel
(
SC).

[
R.
Michell
4/
7/
05]
Timing
The
table
below
contains
the
timing
for
summer
pruning
and
petal
fall
for
apples
in
the
US
by
region.
The
states
within
each
region
are
listed
accordingly.
The
major
metiram
usage
states
are
MI,
NY,
VA,
NC,
PA,
OH,
and
SC
and
are
addressed
in
the
first
three
regions
listed.

Apple
petal
fall
and
summer
pruning
by
region
and
state.
Region
States
Green
Tip­
Petal
Fall**
Summer
Pruning
Appalachian
Southern
DE,
GA,
MD,
NC,
PA,
SC,
TN,
VA,
WV
1st
of
April
thru
the
end
of
the
2nd
week
of
May
1st
of
July
thru
the
end
of
the
2nd
week
of
August
New
England
CT,
RI,
ME,
MA,
VT,
NH,
NJ,
NY
1st
of
April
thru
the
end
of
the
2nd
week
of
May
3rd
week
of
June
thru
the
end
of
the
2nd
week
of
August
North
Central
MI,
OH
2nd
week
if
April
thru
the
end
of
the
2nd
week
of
May
July
 
August
Pacific
Northwest
WA,
OR,
ID
1st
of
April
thru
the
end
of
the
2nd
week
of
May*
3rd
week
of
May
 
1st
week
of
July
Pacific
South
CA,
AZ
1st
week
of
February
thru
the
end
of
the
2nd
week
of
April
2nd
week
of
April
thru
the
end
of
the
1st
week
of
September
*
Pink­
Petal
Fall
**
As
an
alternative
to
using
a
maximum
rate
of
4.8
lbs.
ai/
acre/
application
thru
petal
fall
a
77­
day
PHI
use
pattern
also
exists
for
apples
that
allows
growers
the
option
of
applying
up
to
two
additional
sprays
beyond
petal
fall.
These
treatments
must
utilize
a
lower
maximum
rate
of
2.4
lbs.
ai/
acre
and
must
be
applied
at
least
77
days
before
harvest.
The
available
data
indicates
that
only
about
one­
third
of
users
choose
to
make
applications
after
petal
fall.
Source:
BEADS's
Benefits
Assessment
(
http://
www.
epa.
gov/
oppsrrd1/
op/
azinphos/
bead_
Apples1.
pdf)
[
B.
Phillips
4/
11/
05]
APPENDIX
D
EBDC
use
on
Leatherleaf
Fern
Information
on
EBDC
use
on
Leatherleaf
Fern
(
LLF)
in
Florida,
where
>
70%
of
the
U.
S.
production
is
located,
was
obtained
from
Dr.
Robert
Stamps,
Professor
of
Environmental
Horticulture
and
Extension
Cut
Foliage
Specialist,
University
of
Florida.
Dr.
Stamps
has
indicated
that
the
EBDC
mancozeb
is
applied
four
times
per
year.
Harvest
is
approximately
once
every
two
to
three
months
and
as
a
result
the
reentry
for
workers
is
not
an
issue
as
there
is
usually
plenty
of
time
between
spray
and
harvest.
Included
below
are
the
questions
posed
by
BEAD
and
the
answers
provided
by
Dr.
Stamps.

Characterization
of
the
Metiram
Exposure
Concerns
Associated
with
the
Production
of
Leatherleaf
Ferns
1.
Identify
all
active
ingredient
and
product
names
for
fungicides
applied
to
leatherleaf
fern
and
their
respective
target
pest(
s).

These
are
the
main
fungicides
used
on
leatherleaf
fern
in
Florida;
however,
not
all
trade
names
may
be
listed
(
especially
for
the
generics):

chloroneb
(
Terraneb),
used
only
occasionally
­
Rhizoctonia
chlorothalonil
(
Daconil,
Echo,
Thalonil),
occasionally
used
 
Ascochyta,
Colletotrichum,
Cylindrocladium,
Rhizoctonia
fosetyl­
aluminum
(
Aliette),
rarely
used
 
Phytophthora,
Pythium
mancozeb
(
Dithane,
Penncozeb,
Protect
T/
O),
used
regularly
 
Colletotrichum,
Rhizoctonia
mefenoxam
(
Subdue),
rarely
used
 
Phytophthora,
Pythium
metiram
(
Polyram),
rarely
used
 
Colletotrichum
tebuconazole
(
Folicur),
used
fairly
regularly
during
warm
weather
 
Colletotrichum
thiophanate­
methyl
(
3336,
Systec
1998,
6672),
used
occasionally
 
Ascochyta,
Cylindrocladium
2.
Fully
characterize
the
metiram
fungicide
spray
timelines
for
a
typical
calendar
year
(
e.
g.,
number
of
applications
per
year,
when
applied,
repeat
application
interval).

Maximum
of
four
applications
per
year
(
if
used
at
all
at
a
particular
farm),
usually
applied
when
the
incidence
of
Colletotrichum
is
highest
(
June
through
September).

3.
Provide
Crop
Production
Timelines
for
a
typical
calendar
year.
This
should
include
all
activities
associated
with
production
of
the
crop
(
planting,
harvesting,
pesticide
use,
irrigation,
fertilization,
etc.)
If
individual
activities
are
not
likely
to
result
in
human
exposure
explain
why.
Dealing
with
a
perennial
crop
so
planting
is
not
an
issue.
Fronds
are
harvested
yearround
(
although
more
intensely
during
the
first
six
months
of
the
year)
at
about
an
average
of
once
every
two
to
three
months
for
any
given
fernery.
Most
pesticides
are
commonly
applied
using
the
irrigation
systems
(
chemigation)
during
the
periods
when
harvesting
is
not
occurring
so
direct
exposure
to
applicator
or
workers
is
minimized.
Irrigation/
fertigation
is
done
on
a
more
or
less
weekly
basis.

Source:
Robert
H.
Stamps,
Ph.
D.
,
Professor
of
Environmental
Horticulture
and
Extension
Cut
Foliage
Specialist,
University
of
Florida
Institute
of
Food
and
Agricultural
Sciences,
Department
of
Environmental
Horticulture
Mid­
Florida
Research
and
Education
Center,
2725
Binion
Road,
Apopka,
FL
32703­
8504,
Phone:
(
407)
884­
2034
ext.
164;
Facsimile:
(
407)
814­
6186
APPENDIX
E
EBDC
Wettable
Powder
Use
Analysis
Uses
By
Product
Overall,
the
wettable
powders
constitute
~
10%
of
the
total
lbs
of
EBDC
product
applied
in
the
U.
S.
The
use
of
this
formulation
varies
among
states
and
crops
in
such
a
wide
distribution
as
to
demonstrate
no
pattern,
or
niche,
use.

Products
Maneb
Maneb
80
(
Wp/
D)
 
87%
of
the
pounds
(
ai)
were
applied
to
Peppers,
Lettuce,
Tomatoes,
and
Cucumber.
(
In
order
of
lbs
applied)
 
No
information
on
the
label
as
to
a
D
usage.
 
Chemigation
is
listed.
Aliette/
Maneb
2+
2
 
No
longer
on
the
market.
Amazin
 
Not
able
to
locate
information
to
determine
the
formulation
of
this
product.
Metiram
No
use
of
WP
formulations
found
in
available
use
database.
Mancozeb
Manzate
80
WP
 
89
%
of
the
pounds
(
ai)
were
applied
to
Potatoes,
Apples,
Watermelon,
Cucumber,
and
Wine
Grapes.
(
In
order
of
lbs
applied)
Penncozeb
80
WP
 
Penncozeb
DF
is
~
60%
of
the
Penncozeb
(
WP
&
DF)
market.
 
53%
of
the
WP
(
ai)
was
applied
to
Apples.
 
82%
of
the
pounds
(
ai)
were
applied
to
Apples,
Potatoes,
and
Wine
Grapes.
Ridomil
Gold
MZ
 
The
mancozeb
is
a
WP
but
the
package
mix
is
in
a
water
soluble
bag.
 
Only
1.5%
of
the
total
mancozeb
applied
was
this
product.
Acrobat
MZ
 
83%
of
the
pounds
(
ai)
were
applied
to
Tobacco.
Mancozeb
WP
 
56%
of
the
pounds
(
ai)
were
applied
to
Apples.
 
83%
of
the
total
pounds
(
ai)
were
applied
to
Apples,
Wine
Grapes,
and
Potatoes.
Manex
II
 
Not
able
to
locate
information
to
determine
the
formulation
of
this
product.
Mancocide
 
Not
able
to
locate
information
to
determine
the
formulation
of
this
product.

Percent
Use
of
Product
The
following
is
a
list
of
the
agronomic
crops
that
represent
the
means
of
the
approximate
pounds
of
EBDC's
applied
between
the
years
2001
to
2003.
In
addition,
included
is
the
percent
of
the
total
pounds
of
wettable
powder
product
applied
base
on
the
total
pounds
of
EBDC
products
applied.
As
an
example,
for
maneb
there
was
220,000
lbs
of
EBDC
product
applied
to
almonds
with
0%
being
wettable
powders.
Please
note
that
there
were
no
wettable
powder
metiram
products
applied
during
this
time
frame.
Ridomil
Gold
MZ
was
not
included
in
the
percent
of
total
wettable
powder
product
applied
since
the
EBDC
product
is
in
a
mix
of
other
products
with
all
being
contained
in
a
water
soluble
packet.
Application
of
Maneb
in
Wettable
Powder
Formulation,
2001­
2003
average
Crop
Approximate
pounds
of
Maneb
Applied
Percent
Applied
in
Wettable
Powder
Formulation
Almonds
220,000
0%
Apples
10,000
0%
Beans,
Snap
<
5,000
0%
Broccoli
20,000
1%
Cabbage
60,000
0%
Cantaloupe
<
5,000
0%
Carrots
<
5,000
0%
Cauliflower
10,000
4%
Cucumber
30,000
46%
Garlic
30,000
0%
Grapes,
Table
<
5,000
33%
Grapes,
Wine
10,000
6%
Lettuce
650,000
7%
Onions
40,000
3%
Peppers
200,000
25%
Potatoes
20,000
5%
Pumpkin
<
5,000
3%
Spinach
10,000
37%
Squash
10,000
0%
Sugar
Beets
10,000
2%
Sweet
Corn
10,000
0%
Tomatoes
120,000
33%
Walnuts
280,000
0%
Watermelon
20,000
35%
Total
1,760,000
9%
Source,
EPA
proprietary
data.
Note,
Usage
of
maneb
was
observed
in
the
following
formulated
products:
(
wettable
powders)
Aliette/
Maneb
2+
2,
Amazin
,
Maneb
80,
(
other)
Maneb
75
DF,
and
Manex.
Application
of
Mancozeb
in
Wettable
Powder
Formulation,
2001­
2003
average
Crop
Approximate
pounds
of
Maneb
Applied
Percent
Applied
in
Wettable
Powder
Formulation
Almonds
10,000
0%
Apples
1,330,000
31%
Asparagus
30,000
33%
Beans,
Lima
<
5,000
0%
Beans,
Snap
<
5,000
0%
Cabbage
10,000
0%
Cantaloupe
40,000
25%
Carrots
<
5,000
0%
Cherries
<
5,000
0%
Cotton
<
5,000
0%
Cucumber
80,000
38%
Garlic
<
5,000
0%
Grapes,
Raisin
10,000
0%
Grapes,
Table
30,000
33%
Grapes,
Wine
200,000
30%
Lettuce
<
5,000
0%
Onions
500,000
2%
Peanuts
10,000
0%
Pears
130,000
23%
Peppers
40,000
25%
Potatoes
3,140,000
19%
Pumpkin
20,000
0%
Squash
60,000
17%
Sugar
Beets
50,000
60%
Sweet
Corn
100,000
0%
Tobacco
40,000
75%
Tomatoes
480,000
15%
Walnuts
<
5,000
0%
Watermelon
300,000
27%
Wheat,
Spring
30,000
67%
Wheat,
Winter
30,000
0%
Total
6,660,000
21%
Source,
EPA
proprietary
data.
Note,
Usage
of
mancozeb
was
observed
in
the
following
formulated
products:
(
wettable
powders)
Acrobat
MZ,
Dithane
M
45,
Mancozeb
WP,
Manzate
80
WP,
Penncozeb
80
WP,
(
other)
Penncozeb
DF,
Ridomil
Gold
MZ,
Dithane
DF,
Dithane
45,
Gavel
75
DF,
Mancozeb
4
F,
Manex
II,
Mancocide,
Manzate
75
DF,
and
Manzate
Flowable
4L.
Note:
Ridomil
Gold
MZ
contains
a
wettable
powder
EBDC
but
was
not
included
in
the
percent
applied
because
the
product
is
in
a
water
soluble
packet.
APPENDIX
F
The
Importance
of
Mancozeb
Use
on
Pears
for
Control
of
Pear
Psylla
Nymphs
in
the
Pacific
Northwest
R.
Michell
3/
23/
05
Telephone
Conversation
with
Dr.
Michael
Willett,
Vice
President
for
Scientific
Affairs,
Northwest
Horticultural
Council,
Yakima,
WA
98901,
(
509)
453­
3193,
willett@
nwhort.
org
Dr.
Willett
was
called
in
response
to
his
comments
sent
to
the
EBDC
docket
regarding
the
importance
of
mancozeb
use
on
pears
for
control
of
pear
psylla
nymphs
in
the
Pacific
Northwest.
Below
are
his
comments
during
our
discussion:

1)
So
far
WA
is
the
only
state
with
SLN
registrations
for
this
pear
use
[
WA030038,
WA040003];
the
maximum
application
rate
(
6.4
lbs
ai/
A)
is
higher
than
the
maximum
application
rate
on
the
Section
3
label
for
pears
(
4.8
lbs
ai/
A).
2)
WA
grows
about
24,800
acres
of
pears.
3)
About
16%
of
the
crop
is
treated
with
mancozeb
(
2003
NASS).
4)
Average
number
of
applications
=
1.1.
5)
A
number
of
insecticide
alternatives
with
different
chemistries
appear
to
be
available
for
control
of
pear
psylla;
he
was
unsure
of
the
relative
economic
impact
of
not
having
mancozeb
for
this
use.
6)
For
additional
information
he
referred
us
to
Dr.
John
Dunley,
extension
entomologist,
WSU
(
509)
663­
8181x236,
dunleyj@
wsu.
edu.
APPENDIX
G
Average
EBDC
application
rates
are
given
below
to
assist
in
the
dietary
and
occupational
risk
assessments.

Average
Application
Rates
for
Mancozeb,
Maneb,
and
Metiram
Crop
Mancozeb
Average
A.
I
Rate
Maneb
Average
A.
I.
Rate
Metiram
Average
A.
I.
Rate
Almonds
1.5
3.574
Apples
2.601
2.741
2.228
Asparagus
1.413
1.6
Beans,
Lima
0.4
Beans,
Snap
0.713
0.847
Broccoli
1.277
Cabbage
0.897
1.086
Cantaloupe
1.185
1.15
Carrots
0.75
0.75
Cauliflower
1.28
Cherries
2.12
Cotton
0.746
Cucumber
1.303
1.333
Garlic
1.5
1
Grapes,
Raisin
2.189
1.8
Grapes,
Table
2.063
1.525
Grapes,
Wine
2.136
2.242
Lettuce
1.259
1.42
Onions
1.513
1.672
Peaches
0.8
Peanuts
1.004
Pears
3.715
6.01
Peppers
0.951
1.177
Potatoes
1.214
0.914
1.392
Pumpkin
1.435
0.939
Spinach
1.251
Squash
1.41
1.119
2.005
Sugar
Beets
1.077
1.388
Sweet
Corn
0.99
0.993
Tobacco
0.846
Tomatoes
1.065
1.627
Walnuts
0.6
1.751
Watermelon
1.381
1.163
Wheat,
Spring
1.092
Wheat,
Winter
1
Source:
U.
S.
Department
of
Agriculture,
National
Agricultural
Statistics
Service
and
EPA
proprietary
data
sources,
2001
 
2003.
