	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

     OFFICE OF	

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

Date:  July 3, 2008

MEMORANDUM

SUBJECT:	Ethoprop . Anticipated Residues to Support New Uses on Hops and
Mint.

PC Code:  041101	DP Barcode:   352476 and 352477

Decision No.: 382076, 299884	Registration No.: N/A

Petition No.: 5E4491 and 7E7247	Regulatory Action: New
Registration/Tolerance

Risk Assessment Type: Single Chemical Aggregate	Case No.: N/A

TXR No.: N/A	CAS No.: 13194-48-4

MRID No.: N/A	40 CFR:  180.262



FROM:	Christine L. Olinger, Chemist

		Reregistration Branch 1

		Health Effects Division (7509P)

THROUGH: 	Toiya Goodlow, Chemist,

		Sheila Piper, Chemist,

		David Hrdy, Sr. Scientist,

		Dietary Exposure Science Advisory Council

		Health Effects Division (7509P)

			and

		Michael S. Metzger, Chief

Reregistration Branch 1

		Health Effects Division (7509P)

TO:		Kit Farwell, D.V.M.

		Reregistration Branch 1

		Health Effects Division (7509P)

and

Susan Stanton

Risk Integration, Minor Use & Emergency Response Branch

Registration Division (7505P)

I.	ACTION REQUESTED

IR-4 is requesting new uses of the organophosphate insecticide ethoprop
on hops and mint.   Ethoprop is currently registered on numerous crops. 
The most recent anticipated residues were generated in support of the
Interim Reregistration Eligibility Decision (IRED) (C. Swartz,
21-Jul-1999, DP D257828).  The residue estimates are updated herein to
incorporate the most recent USDA Pesticide Data Program (PDP) data and
percent crop treated estimates.

II.	BACKGROUND

  SEQ CHAPTER \h \r 1 Ethoprop [S,S-dipropyl O-ethyl phosphorodithioate]
is an organophosphate  (OP) insecticide/nematicide registered for use on
bananas/plantains, beans (lima and snap), cabbage, citrus (non-bearing),
corn, cucumbers, pineapples, potatoes, sugarcane, sweet potatoes, and
tobacco.  Ethoprop is manufactured by Bayer CropScience under the trade
name MOCAP® and is formulated as either an EC or G for application to
food/feed crops.  These products may be applied as broadcast or banded
preplant to preemergence applications and as banded postemergence
applications directed to the soil.  Use directions specify the use of
only ground equipment, except on potatoes where aerial applications are
allowed.  The use of ethoprop on peanuts was withdrawn in association
with the Reregistration Eligibility Decision (RED).

IR-4 previously submitted a petition requesting the use of ethoprop (EC
and G) on mint in the U.S. (PP#5E4491).  The mint petition was
originally submitted in 1995 and was reviewed by the Agency (DP#
D214091, G. Otakie, 8/14/1995), but later with the inception of FQPA was
rendered inactive pending completion of the OP cumulative risk
assessment.  Now that the cumulative risk assessment has been completed,
the petition has been reactivated.   Additionally, IR-4 has submitted a
new petition (PP#7E7247) requesting the use of ethoprop (EC) on hops in
the U.S.  In conjunction with these uses, IR-4 is proposing the
establishment of permanent tolerances for ethoprop residues on mint and
hops at 0.02 ppm. 

Tolerances are currently established for numerous commodities in 40 CFR
180.262 for residues of the parent only and are listed in Table 1.  In
association with the RED the Agency recommended for the revocation of
the peanut tolerances since the use on peanuts was withdrawn.

Table 1.  Tolerance Levels for Residues of Ethoprop

Commodity	Tolerance Level, ppm

Banana	0.02

Bean, lima	0.02

Bean, snap, succulent	0.02

Cabbage	0.02

Corn, forage	0.02

Corn, grain	0.02

Corn, stover	0.02

Corn, sweet, kernel plus cob with husks removed	0.02

Cucumber	0.02

Peanut	0.02

Peanut, hay	0.02

Pineapple	0.02

Potato	0.02

Sugarcane, cane	0.02

Sweet potato, roots	0.02



The residues of concern for the acute and chronic risk assessments in
crops are parent and Metabolites II and III (S-ME and O-ME); for cancer
dietary risk, the residues of concern are parent and Metabolites II
through IV (S-ME, O-ME and M-1).  Structures of the parent and
metabolites may be found in Table 2.

Table 2.	Nomenclature of Ethoprop and its Metabolites of Concern.

Compound	

Common name	Ethoprop

Company experimental name	Ethoprop

IUPAC name	O-ethyl-S,S-dipropyl phosphorodithioate

CAS name	O-ethyl-S,S-dipropyl phosphorodithioate

CAS registry number	13194-48-4

Compound	

Common name	Metabolite II (ethoprop S-Me)

Chemical name	O-ethyl-S-methyl-S-propyl phosphorodithioate

Compound	

Common name	Metabolite III; ethoprop O-Me

Chemical name	O-ethyl-O-methyl-S-propyl phosphorodithioate

Compound	

Common name	Metabolite IV (M-1)

Chemical name	O-ethyl-S-propyl phosphorodithioate



III.	DETAILED CONSIDERATIONS

Usage Data

BEAD has provided updated percent crop treated estimates in a Screening
Level Usage Analysis (SLUA) dated 2/14/08 (and attached to this memo)
for established uses of ethoprop.  Usage for most crops is generally
less than 5% crop treated, with the exception of sweet potatoes, with an
estimated percent crop treated of 15%.  Usage information was not
provided for bananas, lima beans, and pineapple, so 100% crop treated
was assumed.  Projected percent crop treated information was not
available for the proposed new uses on hops and mint, so 100%CT was
assumed for these crops as well.  

PDP Monitoring Data

PDP monitoring data are available for bananas, snap beans (fresh and
canned), corn syrup, sweet corn (canned), cucumber, pineapple, potato,
and sweet potato.  Residues were non-detectable for all commodities with
the exception of bananas (six detects), fresh snap beans (one detect),
and sweet potatoes (four detects).  Only the parent compound was
monitored by PDP; metabolite data are not available.

Field Trial Data

Field trial data are available for all commodities and generally show
non-detectable residues for the combined residues of parent and
metabolite M-1.    

Metabolite Ratios

Since residue data are not available for all residues of risk concern,
metabolite ratios were estimated using data from metabolism and confined
rotational crop studies.  Ethoprop is applied to the soil, so the use
pattern from the rotational crop studies is applicable to the primary
crop as well.  The maximum metabolite ratio from all studies was used in
the acute analyses for all non-blended and partially blended crops,
except root crops.  Radish data were used for root crops. Cabbage
metabolism data were used for cabbage.  Average ratios were used for
acute blended commodities as well as the chronic and non-cancer
assessments.  The residues of concern are different for chronic and
cancer assessments, so the ratios are different as well.  A summary of
the calculations used to derive the metabolite ratios may be found in
Table 3.  The metabolism data were obtained from the Sheila Piper memo
of 4/23/99 (DP Barcode 245022).  Example calculations of the ratio may
be found below the table.  Total residues of concern were estimated
using the following equation:

Total Residues = Metabolite Ratio X Residues of Parent

Table 3.  Summary of Residue Data and Metabolite Ratios

Results from Metabolism and Rotational Crop Studies

	Residues, ppm

	Corn Forage	Corn Fodder	Cabbage Leaves	Cabbage Head	Radish	Spinach
Wheat Forage	Wheat Straw	Wheat Straw

I.  Ethoprop	0.17	0.01	0.62	0.02	0.33	0.08	1.82	0.62	0.13

II.   O-ethyl-S-methyl-S-propylphosphorodithioate	0.01	0.02	0.09	0.01
0.01	0.34	0.22	0	0.02

III.  O-ethyl-O-methyl-S-propylphosphorothioate	0.02	0.03	0.26	0.05	0.01
0	0.08	0.27	0.16

IV.  O-ethyl-S- propylphosphorothioate (Metabolite I)	0.05	0.01	0.39
0.01	0.91	0	0	0	0.09

Individual Crop Ratios

Ratio of Parent + II + III/Parent	1.18	6	1.56	4	1.06	5.25	1.16	1.44	2.38

Ratio of Parent + II + III + IV /Parent	1.47	7	2.19	4.5	3.82	5.25	1.16
1.44	3.08

Summary of Ratios

Average Ratio of Parent + II + III/Parent	2.7

	Average Ratio of Parent + II + III + IV /Parent	3.3

	Maximum Ratio of Parent + II + III/Parent	6

	Maximum Ratio of Parent + II + III + IV /Parent	7

	Average Cabbage Ratio of Parent + II + III/Parent+ IV	1.8

	Average Cabbage Ratio of Parent + II + III + IV/ Parent+ IV	2.2

	

Example Calculations

Corn Forage, Ratio of Parent + II + III/Parent

Ratio  = (0.17 + 0.01 + 0.02)/0.17 = 1.18

Corn Forage, Ratio of Parent + II + III + IV/Parent

Ratio  = (0.17 + 0.01 + 0.02 + 0.05)/0.17 = 1.47

Note:  Unless otherwise specified for individual crops (such as root
crops), the Maximum Ratio of Parent + II + III/Parent was used for the
acute assessment.  The average Ratio of Parent + II + III/Parent was
used for the chronic assessment.  The average Ratio of Parent + II + III
+ IV /Parent was used for the cancer assessment.  



Individual Crop Anticipated Residues

For each type of assessment (acute, chronic, cancer) the percent crop
treated, the appropriate metabolite ratio, and the unmodified residue
value (from PDP or field trial data) are reported separately.  For
commodities requiring a residue distribution file (RDF) the residue
value is multiplied by the metabolite ratio in the RDF and not reported
separately.

Bananas

Classification:  Non-Blended/Partially Blended

Data Used:  PDP

Years of PDP Data:  2001-2002

Summary of PDP Data:  1429 samples; six detects (0.025, 0.013, 0.012,
0.007, 0.003, 0.003) and 1423 non-detects at the following limits of
detection (LODs): 0.002 ppm (590 samples) and 0.015 ppm (833 samples).

Summary of Banana Anticipated Residues

Acute Percent Crop Treated	100

Acute Metabolite Ratio	6 (maximum ratio of all studies)

Acute RDF

Note:  The RDF values are the product of the PDP values and the
metabolite ratio.	Banana PDP

100%CT

Totalfreq=2

TotalNZ=6

833,0.09

590,0.012

0.15

0.078

0.072

0.042

0.018

0.018

Chronic Percent Crop Treated	100

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.0048 (average of detects and ½ LODs)

Cancer Percent Crop Treated	100

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.0048 (average of detects and ½ LODs)



Snap Beans, Fresh

Classification: Partially Blended

Data Used:  PDP

Years of PDP Data:  2000-2001; 2004

Summary of PDP Data:  1588 samples; one detect (at 0.002 ppm) and 1587
non-detects at the following limits of detection (LODs): 0.001 ppm (1015
samples) and 0.002 ppm (572 samples).

Summary of Snap Bean (Fresh) Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	6

Acute RDF 

Note:  The RDF values are the product of the PDP values and the
metabolite ratio.	Snap Bean, Fresh, 5%CT PDP

TotalNZ=1

TOTALZ=1509

Totalfreq=1

79, 0.006

0.012

Chronic Percent Crop Treated	5

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.001; (average of detects and 79 ½ LODs that
represent treated samples)

Cancer Percent Crop Treated	5

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.001; (average of detects and 79 ½ LODs that
represent treated samples)



Snap Beans, Canned

Classification: Partially Blended

Data Used:  PDP

Years of PDP Data:  2003-2004

Summary of PDP Data:  269 samples; all non-detects at a limit of
detection (LODs) of 0.002 ppm.

Summary of Snap Beans (Canned) Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	6

Acute RDF

Note:  The RDF values are the product of the PDP value (1/2 LOD) and the
metabolite ratio.	Snap Bean 5%CT PDP

TOTALZ=19

TOTALLOD=1

LODRES=0.006

Chronic Percent Crop Treated	5

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.001 (1/2 LOD)

Cancer Percent Crop Treated	5

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.001 (1/2 LOD)



Lima Beans, Succulent

Classification: Partially Blended

Data Used:  Tolerance Level

Summary of Lima Beans (Succulent) Anticipated Residues

Acute Percent Crop Treated	100

Acute Metabolite Ratio	6

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	Lima Bean 100%CT Tol

TOTALZ=0

TOTALLOD=1

LODRES=0.12

Chronic Percent Crop Treated	100

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.02

Cancer Percent Crop Treated	100

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.02



Lima Beans, Dried

Classification: Blended

Data Used:  Tolerance Level

Summary of Lima Beans (Dried) Residues

Acute Percent Crop Treated	100

Acute Metabolite Ratio	6

Acute Residue Value	0.02

Chronic Percent Crop Treated	100

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.02

Cancer Percent Crop Treated	100

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.02



Cabbage

Classification:  Non-Blended/Partially Blended

Data Used:  Field Trial (See Table 4)

Comments:  The combined residues of ethoprop and MIV were used from the
field trials, so the metabolite ratio is based on residues of Parent +
MII+MIII/Parent + MIV for acute and chronic ARS, and Parent +
MII+MIII+MIV/Parent + MIV for cancer.  Since a cabbage metabolism study
is available, the ratios from the cabbage study were used instead of the
average from all studies.

  SEQ CHAPTER \h \r 1 Table 4.  Residues of ethoprop and M1 in/on
cabbage heads without wrapper leaves treated with a single broadcast
application of ethoprop (EC) at planting at 12 lb ai/A (2x).  (From J.
Abbotts, 9/4/97, DP Barcode D213957 MRID 43583201)

Location	Application Rate (lb ai/A)	PHI (days)	Residues Found (ppm) a



	Ethoprop	M1

San Benito, CA	12.05	147	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01

Dade County, FL	12.0	124	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01

Seminole County, FL	12.33	86	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01

Salem County, NJ	12.25	80	<0.01	0.016



	<0.01	0.013



	<0.01	<0.01

Ontario County, NY	12.0	86	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01

Seneca County, NY	11.83	90	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01

Johnston County, NC	12.0	76	<0.01	0.033, 0.033, 0.047b

(0.038)c



	<0.01	0.037, 0.041, 0.040b

(0.039)c



	<0.01	0.015

Wharton County, TX	12.01	128	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01

Iola, WI	12.0	95	<0.01	<0.01



	<0.01	<0.01



	<0.01	<0.01



a  Residue values were not corrected for recoveries.

b  Numbers listed sequentially represent duplicate analyses of a single
sample.

c  Values in parentheses are mean of three analyses of one sample.

Summary of Cabbage Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	1.8

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	Cabbage FT  5%CT

totalNZ=3

TOTALZ=171

Totalfreq=1

6, 0.018

0.0846

0.0738

0.0288

Chronic Percent Crop Treated	5

Chronic Metabolite Ratio	1.8

Chronic Residue Value	0.0182 (field trials;  ½ combined LOQ used for
all non-detects)

Cancer Percent Crop Treated	5

Cancer Metabolite Ratio	2.2

Cancer Residue Value	0.0182



Sweet Corn

Classification: Non-Blended/Partially Blended

Data Used:  Field Trial.  All residues were non-detectable, so used ½
limit of quantitation (LOQ) of parent (1/2 LOQ = 0.005 ppm). (J.
Abbotts, 1/1/98, MRID 43748203, DP Barcode No. D235686)

Comments:  PDP data are available for canned sweet corn, but the maximum
LOD was greater than the LOQ from the field trial data, so field trial
data were used.  PDP data are provided for comparison.

Years of PDP Data:  2001-2003

Summary of PDP Data:  1455 samples; all were non-detects at limits of
detection (LODs) ranging from 0.002 ppm to 0.015 ppm.

Summary of Sweet Corn Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	6

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	sweetcorn 5%CT FT

TOTALZ=19

TOTALLOD=1

LODRES=0.03

Chronic Percent Crop Treated	1

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.005

Cancer Percent Crop Treated	1

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.005



Field Corn (except corn syrup)

Classification: Blended

Data Used:  Field Trial.  All residues were non-detectable, so used ½
limit of quantitation (LOQ) of parent (1/2 LOQ = 0.005 ppm).  (J.
Abbotts, 1/1/98, MRID 43748203, DP Barcode No. D235686)

Summary of Field Corn (Except Corn Syrup) Anticipated Residues

Acute Percent Crop Treated	2.5

Acute Metabolite Ratio	6

Acute Residue Data Value	0.005

Chronic Percent Crop Treated	1

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.005

Cancer Percent Crop Treated	1

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.005



Field Corn (Corn Syrup)

Classification: Blended

Data Used:  PDP

Years of PDP Data:  1998-1999

Summary of PDP Data:  438 samples; all non-detects at a limit of
detection (LOD) of 0.003 ppm.  Used ½ LOD value for residue.

Summary of Field Corn (Corn Syrup) Anticipated Residues

Acute Percent Crop Treated	2.5

Acute Metabolite Ratio	6

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	CornSyrup 2.5%CTPDP

TOTALZ=0

TOTALLOD=438

LODRES=0.009

Chronic Percent Crop Treated	1

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.0015

Cancer Percent Crop Treated	1

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.0015



Cucumber

Classification: Non-Blended

Data Used:  PDP

Years of PDP Data:  1999-2000, 2002-2004

Summary of PDP Data:  2380 samples; all non-detects at the following
limits of detection (LODs): 0.015 ppm (690 samples) and 0.002 ppm (1690
samples). 

Summary of Cucumber Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	6

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	cucumber 5%CT PDP

TOTALZ=2261

TOTALLOD=119

LODRES=0.045

Chronic Percent Crop Treated	1

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.0029 (average of LODs)

Cancer Percent Crop Treated	1

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.0029 (average of LODs)



Pineapple

Classification: Non-Blended

Data Used:  PDP

Years of PDP Data:  1999-2000, 2002-2004

Summary of PDP Data:  1454 samples; all non-detects at the following
limits of detection (LODs): 0.01 ppm (1031 samples) and 0.002 ppm (423
samples).  Used ½ the maximum LOD for the acute AR.

Summary of Pineapple Anticipated Residues

Acute Percent Crop Treated	100

Acute Metabolite Ratio	6

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	Pineapple 100%CT PDP

TOTALZ=0

TOTALLOD=1454

LODRES=0.03

Chronic Percent Crop Treated	100

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.0038 (average of ½ LODs)

Cancer Percent Crop Treated	100

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.0038 (average of ½ LODs)



Potatoes (Non-Blended and Partially Blended Food Forms)

Classification: Non-Blended

Data Used:  PDP

Years of PDP Data:  2000-2002

Summary of PDP Data:  1472 samples; all non-detects at the following
limits of detection (LODs): 0.016 ppm (1048 samples) and 0.002 ppm (424
samples).

Summary of Potato (Non-Blended, Partially Blended) Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	1.1

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	Potato 5%CT PDP

TOTALZ=1398

TOTALLOD=74

LODRES=0.0088

Chronic Percent Crop Treated	1

Chronic Metabolite Ratio	1.1

Chronic Residue Value	0.006 (average of ½ LODs)

Cancer Percent Crop Treated	1

Cancer Metabolite Ratio	3.8

Cancer Residue Value	0.006 (average of ½ LODs)



Potatoes (Blended Food Forms)

Classification: Blended

Data Used:  PDP

Years of PDP Data:  2000-2002

Summary of PDP Data:    1472 samples; all non-detects at the following
limits of detection (LODs): 0.016 ppm (1048 samples) and 0.002 ppm (424
samples).

Summary of Potato (Blended) Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	1.1

Acute Residue Value.	0.006 (1/2 average of LODs)

Chronic Percent Crop Treated	5

Chronic Metabolite Ratio	1.1

Chronic Residue Value	0.006 (1/2 average of LODs)

Cancer Percent Crop Treated	5

Cancer Metabolite Ratio	3.8

Cancer Residue Value	0.006 (1/2 average of LODs)



Sugarcane

Classification: Blended

Data Used:  Field Trial

Summary of Data:  Residues were non-detectable at an exaggerated rate;
concentration in processed commodities was not observed. One-half the
ethoprop LOQ (LOQ = 0.01 ppm) will be used as the residue value in the
assessments.

Summary of Sugarcane Anticipated Residues

Acute Percent Crop Treated	5

Acute Metabolite Ratio	6

Acute Residue Value.	0.005 ppm (1/2 LOQ)

Chronic Percent Crop Treated	5

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.005 ppm (1/2 LOQ)

Cancer Percent Crop Treated	1

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.005 ppm (1/2 LOQ)



Sweet Potato

Classification: Non-Blended

Data Used:  PDP

Years of PDP Data:  2003-2004

Summary of PDP Data:  1477 samples; four detects (0.0067, 0.003, 0.002,
0.002) and 1473 non-detects at the following limits of detection (LODs):
0.002 ppm (428 samples) and 0.0012 ppm (1045 samples).

Summary of Sweet Potato Anticipated Residues

Acute Percent Crop Treated	15

Acute Metabolite Ratio	1.1

Acute RDF 

Note:  The RDF values are the product of the tolerance and the
metabolite ratio.	Sweet Potato 15%CT PDP

TOTALZ=1255

TOTALNZ=4

Totalfreq=1

218,0.0022

0.00737

0.0033

0.0022

0.0022

Chronic Percent Crop Treated	15

Chronic Metabolite Ratio	1.1

Chronic Residue Value	0.002 (average of detects and 218 LODs that
represent treated samples)

Cancer Percent Crop Treated	15

Cancer Metabolite Ratio	3.8

Cancer Residue Value	0.002 (average of detects and 218 LODs that
represent treated samples)



Mint

Classification: Blended

Data Used:  Proposed Tolerance

Summary of Mint Anticipated Residues

Acute Percent Crop Treated	100

Acute Metabolite Ratio	6

Acute Residue Value.	0.02 (Proposed Tolerance)

Chronic Percent Crop Treated	100

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.02 (Proposed Tolerance)

Cancer Percent Crop Treated	100

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.02 (Proposed Tolerance)



Hops

Classification: Blended

Data Used:  Proposed Tolerance

Summary of Hops Anticipated Residues

Acute Percent Crop Treated	100

Acute Metabolite Ratio	6

Acute Residue Value.	0.02 (Proposed Tolerance)

Chronic Percent Crop Treated	100

Chronic Metabolite Ratio	2.7

Chronic Residue Value	0.02 (Proposed Tolerance)

Cancer Percent Crop Treated	100

Cancer Metabolite Ratio	3.3

Cancer Residue Value	0.02 (Proposed Tolerance)



Cc:  COlinger



ATTACHMENT 1.  Ethoprop SLUA

ETHOPROP  041101

Screening Level Usage Analysis (SLUA)

February 14, 2008

What is a Screening Level Usage Analysis (SLUA)?

Available estimates of pesticide usage data for a particular active
ingredient that is used on agricultural crops in the United States.

Pesticide usage data obtained from various sources.  The data are then
merged, averaged, and rounded so that the presented information is not
proprietary, business confidential, or trade secret. 

What does it contain?

Pesticide usage data for a single active ingredient only.

Agricultural use sites (crops) that the pesticide is reported to be used
on. 

Available pesticide usage information from U.S. states that produce 80%
or more of a crop, in most cases, or less than 80%, in rare cases,
depending on the scope of the survey and available resources.

Annual percent of crop treated (average & maximum) for each agricultural
crop.

Average annual pounds of the pesticide applied for each agricultural
crop (i.e., for the states surveyed, not for the entire United States).

What assumptions can I make about the reported data?

Average pounds of active ingredient applied - Values are calculated by
merging pesticide usage data sources together; averaging across all
observations, then rounding.  Note:  If the estimated value is less than
500, then that value is labeled <500.  Estimated values between 500 &
<1,000,000 are rounded to 1 significant digit.  Estimated values of
1,000,000 or greater are rounded to 2 significant digits.)

Average percent of crop treated - Values are calculated by merging data
sources together; averaging by year, averaging across all years, &
rounding to the nearest multiple of 5.  Note:  If the estimated value is
less than 1, then the value is labeled <1.

Maximum percent of crop treated - Value is the single maximum value
reported across all data sources, across all years, & rounded up to the
nearest multiple of 5.  Note:  If the estimated value is less than 2.5,
then the value is labeled <2.5.

What are the data sources used?

USDA-NASS (United States Department of Agriculture’s National
Agricultural Statistics Service) – pesticide usage data from 2001 to
2006.

Private pesticide market research – pesticide usage data from 2001 to
2006.

NPUD 2002 (National Pesticide Use Database) pesticide usage data from
NPUD 02 of the CropLife Foundation are used only if data are not
available from the other sources.

California Department of Pesticide Regulation (DPR) Pesticide Use
Reporting (PUR) data for 2000 to 2005 when 95% or more of a crop is
grown California.

What are the limitations to the data?

Additional registered uses may exist but are not included because the
available surveys do not report usage (e.g., small acreage crops).

Lack of reported usage data for the pesticide on a crop does not imply
zero usage.

Usage data on a particular site may be noted in data sources, but not
quantified.  In these instances, the site would not be reported in the
SLUA.

Non-agricultural use sites (e.g., turf, post-harvest, mosquito control,
etc.) are not reported in the SLUA.  A separate request must be made to
receive these estimates.

Some sites show some use, even though they are not on the label.  This
usage could be due to various factors, including, but not limited to
Section 18 requests, existing stocks of the chemical, data collection
errors, and experimental use permits (EUPs).  	 			  	 		

February 14, 2008

Screening Level Estimates of Agricultural Uses of ETHOPROP  041101

Sorted Alphabetically

                           Crop	                                    
Lbs.A.I.                                            Percent Crop Tt.    
                                         

                                                                        
                                                         Avg.          
Max.

	1 	Beans, Green	40,000	                                               
5                 5

	2 	Cabbage	                                     5,000                  
                             5                 5

	3 	Chicory* +	<500	                                            N/C     
      N/C

	4 	Corn	30,000	                                              <1        
   <2.5

	5 	Cucumbers	5,000	                                              <1    
            5

	6 	Onions +	5,000	                                              <1     
      <2.5

	7 	Peanuts	7,000	                                              <1      
     <2.5

	8 	Potatoes	200,000	                                                5  
              5

	9 	Pumpkins +	<500	                                              <1    
       <2.5

	10	Squash +	<500	                                              <1      
     <2.5

	11	Sugarcane	100,000	                                                5 
               5

	12	Sweet Corn	10,000	                                              <1  
              5

	13	Sweet Potatoes (NPUD'02)	50,000	                                    
       N/C               15

	14	Tobacco	30,000	                                               <1    
       <2.5

	  	 		

______________________________________		

	  	 		

All numbers rounded.		

'<500'  indicates less than 500 pounds of active ingredient.		

'<2.5'   indicates less than 2.5 percent of crop is treated.		

'<1'	indicates less than 1 percent of crop is treated.	

   * CA data only, but 95% or more of U.S. acres are in California		

	  	 		

SLUA data sources include:

	USDA-NASS (United States Department of Agriculture's National
Agricultural Statistics Service)-

            2001-2006

	Private Pesticide Market Research-2001-2006

	NPUD 2002 (National Pesticide Use Database) of the CropLife America
Foundation

	California DPR data 2004-2006

	These results reflect amalgamated data developed by the Agency and are
releasable to the public.

	

N/C = Not Calculated

+ = These crops were not listed as active product registrations when
this report was run.

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