UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Revised
Projected
Percent
Crop
Treated
for
Insecticide
Bifenthrin
(
PC
128825)
on
Seven
Crops
FROM:
Alan
Halvorson,
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

TO:
Barbara
Madden
MUIERB
Registration
Division
(
7505P)

I.
SUMMARY
This
memorandum
replaces
previous
projected
percent
crop
treated
(
PPCT)
estimates
for
bifenthrin
on
collards,
kale,
mustard
greens
and
sweet
potatoes
with
PPCTs
each
of
100%.
In
addition,
it
provides
suggested
Federeal
Register
(
FR)
language
for
the
previously
submitted
PPCT
estimates
for
dry
beans/
peas,
potatoes
and
okra.
Tabulated
biological
justifications/
comments,
provided
by
Angel
Chir,
entomologist
with
BEAD,
give
both
explanations
for
these
PPCT
replacements
as
well
as
background
for
the
proposed
FR
language.
In
the
final
analysis,
BEAD
has
determined
that
there
are
no
factors
that
clearly
indicate
that
the
actual
PCTs
for
bifenthrin
on
dry
beans/
peas,
potatoes
and
okra
in
the
next
five
years
will
exceed
the
estimated
PPCT
provided
for
bifenthrin
on
these
crops.
Below
is
the
recommended
boilerplate
FR
language,
as
well
as
the
tabulated
background
information
on
all
seven
crops.
This
memorandum
has
been
reviewed
by
Jihad
Alsadek,
an
economist
with
BEAD,

II.
FR
LANGUAGE
EPA
estimates
PPCT
for
a
new
pesticide
use
by
assuming
that
the
percent
crop
treated
(
PCT)
during
the
pesticide's
initial
five
years
of
use
on
a
specific
use
site
will
not
exceed
the
average
PCT
of
the
market
leader
(
i.
e.,
the
one
with
the
greatest
PCT)
on
that
site
over
the
three
most
recent
surveys.
Comparisons
are
only
made
among
pesticides
of
the
same
pesticide
types
(
i.
e.,
the
dominant
miticide
on
the
use
site
is
selected
for
comparison
with
the
new
miticide).
The
PCTs
included
in
the
average
may
be
each
for
the
same
pesticide
or
for
different
pesticides
since
the
same
or
different
pesticides
may
dominate
for
each
year
selected.
Typically,
EPA
uses
USDA/
NASS
as
the
source
for
the
PCT
data
because
they
are
publicly
available.
When
a
specific
use
site
is
not
surveyed
by
USDA/
NASS,
EPA
uses
proprietary
data
and
calculates
the
estimated
PCT.

This
estimated
PPCT,
based
on
the
average
PCT
of
the
market
leader,
is
appropriate
for
use
in
the
chronic
dietary
risk
assessment.
This
method
of
estimating
a
PPCT
for
a
new
use
of
a
registered
pesticide
or
a
new
pesticide
produces
a
high­
end
estimate
that
is
unlikely,
in
most
cases,
to
be
exceeded
during
the
initial
five
years
of
actual
use.
The
predominant
factors
that
generally
can
be
analyzed
based
on
readily
available
information
and
that
bear
on
whether
the
estimated
PPCT
could
be
exceeded
are
whether
there
are
concerns
with
pest
pressures
as
indicated
in
emergency
exemption
requests
or
other
readily
available
information,
whether
the
new
pesticide
controls
a
broader
spectrum
of
pests
than
the
dominant
pesticide(
s)
and/
or
whether
the
new
pesticide
has
a
shorter
post­
harvest
interval
(
PHI).

All
such
relevant
information
currently
available
has
been
considered
for
bifenthrin
on
dry
beans/
peas,
potatoes
and
okra,
and
it
unlikely
that
actual
PCT
for
bifenthrin
will
exceed
the
estimated
PPCT
for
bifenthrin
on
each
of
these
three
crops
during
the
next
five
years
mainly
because
of
the
relatively
longer
PHI
of
bifenthrin
relative
to
each
of
the
respective
leading
insectide(
s).

CONCLUSION
See
the
Appendix
for
both
for
justifications
for
replacing
previous
PPCT
estimates
for
collards,
kale,
mustard
greens
and
sweet
potatoes
with
estimates
of
100
percent
and
for
background
information
for
the
above
suggested
FR
language.
APPENDIX
Biologist
Review
of
projections
of
bifenthrin
PCT
for
seven
new
uses
June
8,
2006
New
use
Market
leader
Could
market
leader's
PCT
be
exceeded?
Justification/
Comments
Bt
Yes
Bt
is
narrow
spectrum
(
certain
lepidopterous
larvae)
and
is
slow­
acting
relative
to
bifenthrin.
Bifenthrin
is
broad­
spectrum.
Bt
has
a
PHI
of
0
days,
vs.
7
days
for
bifenthrin,
but
this
advantage
would
only
affect
control
of
lep
larvae.
Collards,
kale,
and
mustard
greens
(
leafy
brassicas)

Mevinphos
n/
a
All
U.
S.
uses
have
been
cancelled.
Only
import
tolerances
left
Dry
beans/
peas
Dimethoate
No
Bifenthrin
has
broader
action
spectrum
than
dimethoate,
but
bifenthrin's
PHI
is
14
days
vs.
0
for
dimethoate.
Potatoes
Imidacloprid
No
Bifenthrin
and
imidacloprid
are
both
broad
spectrum.
However,
imidacloprid
can
be
used
both
as
a
soil
insecticide
before,
during,
and
shortly
after
planting
(
no
PHI
applies
here)
or
as
a
foliar
(
PHI:
7
days).
The
longer
proposed
PHI
for
bifenthrin
(
21
days)
would
limit
its
usefulness
relative
to
imidacloprid.
Okra
Carbaryl
No
Proposed
bifenthrin
label
includes
many
more
target
pests
(
17)
than
carbaryl
(
2).
However,
the
PHI
for
bifenthrin
is
7
days,
while
for
carbaryl
it
is
only
3
days.
Sweet
potatoes
Chlorpyrifos
Yes
There
are
Section
18
uses
for
bifenthrin
in
Louisiana,
Mississippi,
and
North
Carolina.
Chlorpyrifos
is
used
as
a
preplant
treatment,
but
is
only
effective
for
4­
6
weeks,
whereas
the
most
critical
period
for
root
production
is
the
last
30­
50
days.
Chlorpyrifos
will
have
dissipated
by
this
time.
Also,
target
pests
have
developed
resistance
to
available
foliar
insecticides.
Bifenthrin
can
be
applied
as
an
at
plant
treatment
or,
much
later,
as
a
foliar
treatment.
Chlorpyrifos
has
125
day
PHI
vs.
a
21
day
PHI
for
bifenthrin.
Both
chemicals
target
the
same
pest
complex
(
soil­
borne
beetles).
