UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

       OFFICE OF PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

 

										

MEMORANDUM

SUBJECT:  	EFED Drinking Water and Ecological Risk Review for Coumaphos
(036501) IR-4 Use on Beehives DP Barcode D315770   

TO:    		Shaja Brothers, Risk Manager Reviewer

          		Daniel Rosenblatt, Risk Manager

		Registration Division ()

FROM:     	Edward Odenkirchen, Ph.D., Senior Biologist

          		Environmental Risk Branch I

          		Environmental Fate and Effects Division (7507P)

THROUGH:	Nancy Andrews, Ph.D., Chief

Environmental Risk Branch I  

          		Environmental Fate and Effects Division (7507P)

The Registration Division has requested the Environmental Fate and
Effects Division to review an IR-4 petition for the use of coumaphos
impregnated strips CheckMite+® Pest Control Strip in beehives for the
control of varroa mites and small hive beetles within the honeybee
colony.  The labeling for the IR-4 petition differs from previous
Section 18 emergency exemptions for the use of coumaphos in only two
ways.  The labeling would allow use of the coumaphos product during
periods of honey production. The labeling also has been revised for
first aid statements in compliance with PR Notice 2001-1.

EFED has reviewed the proposed label use and found a number of key
aspects of this use as it relates to both ecological risks and drinking
water assessment.  First the material is impregnated on a solid
substrate which is placed inside the commercial beehive structure.  Once
in the beehive, the material is sheltered from the elements so that no
runoff or drift of coumaphos to surrounding environments would likely
occur even during precipitation events.  Secondly, the pesticide
impregnated strips are placed on the floor of the beehive or between
center-most combs of the beehive to eliminate or reduce bee contact with
the strips.

μg coumaphos equivalents/L for the maximum annual concentration (acute)
and 1.22 μg coumaphos equivalents/L for the 56 day average
concentration (chronic).   SCI-GROW modeling predicted that the total
coumaphos residue concentration in groundwater used as drinking water is
not likely to exceed 0.17 μg coumaphos equivalents/L.

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 xposure to surface waters or to the surrounding non-target terrestrial
environment.  Therefore, without evident complete exposure routes to
aquatic and non-target terrestrial organisms, there are no acute or
chronic risk concerns and no concerns for effects to federally listed
threatened or endangered species.

