Use and Benefits of Chlorpyrifos in U.S. Agriculture

Transcription

1 Use and Benefits of Chlorpyrifos in U.S. Agriculture May 18, 2009 Luis Enrique Gomez Dow AgroSciences LLC 9330 Zionsville Road Building 308/2E, Indianapolis IN Phone: May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 1

2 Acknowledgements Special thanks go to Kimberly Mulcahy of Achieva, Inc. for her important contributions and data analysis. Appreciation is also expressed to the following Dow AgroSciences, Achieva, Inc., and dmr kynetec Inc. experts who contributed information as well as reviewed this report for accuracy. Barat Bisabri Sam Ferguson Garry Hamlin Don Hennenfent Ralph Lassiter Linda Lindenberg Cindy Loy Bruce Maddy Herbert Miller Jack Mitenbuler Dwayne Morton James Mueller Brett Oemichen Brian Olson Kenneth Racke Jesse Richardson Mike Shaw Marvin Stewart Larry Walton Tony Weiss Harvey Yoshida May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 2

3 Table of Contents Section Pages Introduction 4 Overview of Chlorpyrifos 5 Chlorpyrifos Brand Names and Formulations 6 Overview of Agricultural Uses of Field, Fruit, Nut and Vegetables Crops 7 Chlorpyrifos Use Analysis - EPA s Screening Level Usage Analysis Versus 10 Actual Use Data Chlorpyrifos Agricultural Crops Use Analysis 16 Alfalfa 17 Brassica (Cole) Vegetables Broccoli, Cauliflower, and Cabbage 23 Citrus Oranges, Lemons, and Grapefruit 28 Corn 38 Cotton 41 Grapes 44 Mint 49 Onion 52 Peanuts 54 Pome and Stone Fruits Cherries, Peaches, Nectarines, Plums, Prunes, and Apples 57 Soybeans 75 Sugar Beets 81 Sunflowers 87 Sweet Corn 90 Sweet Potatoes 94 Tree Nuts Almonds, Pecans, and Walnuts 96 Wheat 109 Glossary 113 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 3

4 Introduction Insect pests cause billions of dollars worth of damage and threaten our food supply, our property, our health, and the livelihood of growers. Insects have a remarkable ability to adapt to environmental pressures, to changes in cropping systems, cultural practices and climate, and to tolerate or resist management strategies, including insecticides. To protect our food supply and satisfy the needs of a growing population, growers need full access to a broad range of effective and sustainable insect management tools to manage insect infestations. Insecticides, such as chlorpyrifos, have played, and will continue to play, an important role in a sustainable insect management strategy. "Insecticides enable U.S. farmers to produce and harvest greater marketable yields than would otherwise be possible. By mitigating the effects of crop-feeding insects, U.S. farmers produce 144 billion pounds of additional food, feed and fiber and reap $22.9 billion in farm income increases. Growers in California benefit the most from the use of insecticides ($7.5 billion/year), followed by [growers in the states of] Washington and Florida ($2.8 and $2.5 billion/year, respectively).before the use of insecticides became widespread, insects consumed about 50% of the nation's crops" [1]. A multi-year regulatory review of chlorpyrifos by the Environmental Protection Agency (EPA) known as Registration Review opened in early This report is a guide to growers, commodity groups, and regulatory decision-makers regarding the benefits of chlorpyrifos in U.S. agriculture. This report will provide the reader with the information and resources needed to answer questions regarding chlorpyrifos use on major crops throughout the U.S. Chlorpyrifos products in the U.S. underwent a rigorous re-registration process that began in 1984 and concluded in. This included evaluation for potential human health and environmental impacts as well as a cumulative consumer risk assessment for the organophosphate class of insecticides [2]. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 4

5 Overview of Chlorpyrifos Chlorpyrifos is one of the most widely used active ingredients in insecticides in the world. It is used to protect a number of important agricultural crops such as soybeans, wheat, alfalfa, citrus, tree nuts, peanuts, vegetables, and others, from losses to insect pests. Chlorpyrifos was first registered in the U.S. in 1965 and received its first crop use approvals in Products containing chlorpyrifos have been on the market for more than 40 years [3]. Today, chlorpyrifos is registered in more than 98 countries worldwide for use on more than 50 different crops against damage caused by a wide range of insect pests. Mode of Action Chlorpyrifos is an organophosphate insecticide. Its insecticidal action is due to the inhibition of the enzyme acetylcholinesterase, resulting in the accumulation of the neurotransmitter, acetylcholine, at nerve endings. This results in excessive transmission of nerve impulses, which causes mortality in the target pest. Efficacy Chlorpyrifos provides broad spectrum control of insect pests in cereal, oil, forage, fruit, nut, and vegetable crops. The efficacy of chlorpyrifos has been tested under both laboratory and field conditions using a variety of formulations. Chlorpyrifos is effective primarily by contact, but it also has action through ingestion and by vapor. Chlorpyrifos has proven activity on a wide range of pests in a large number of crops worldwide. It has generally exhibited short residual activity on plant foliage. Chlorpyrifos Attributes Broad spectrum insecticidal activity High efficacy Active on foliar-feeding and soil-dwelling insect pests Fast knockdown Does not flare mites Flexible application timing and method Important tank mix partner for controlling tough pests Good rotational partner to manage insect resistance Broad label International tolerances and maximum residue limits in place in export destination countries Moderate mammalian toxicity Easy to handle Strong technical support database Manufacturers Dow AgroSciences LLC is the primary manufacturer of chlorpyrifos. Other companies in China, Denmark, India, and Israel also manufacture chlorpyrifos. For more information about chlorpyrifos, visit May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 5

6 Chlorpyrifos Brand Names and Formulations Chlorpyrifos is commercialized as solvent-based emulsifiable concentrate (EC), water-based (EC, emulsion in water), granular (G), wettable granule (WG), and wettable powder (WP) formulations. It is available under several brand names. Table 1. Chlorpyrifos Brands, Formulations, and Concentrations Brand Name Formulation Type EC = Emulsifiable Concentrate WG = Wettable Granule G = Granular WP = Wettable Powder Lorsban Advanced EC lb/gallon Concentration of Active Ingredient Lorsban-4E Nufos 4E Yuma 4E Warhawk Hatchet Chlorpyrifos 4E AG Drexel Chlorpyrifos 4E-AG Whirlwind EC 4.0 lb/gallon Cobalt EC 2.5 lb/gallon chlorpyrifos lb/gallon gamma-cyhalothrin Lock-On EC 2.0 lb/gallon Lorsban 15G G 150 g/kg (15%) Lorsban 75WG WG 750 g/kg (75%) Lorsban 50W in WSP Dursban 50W in WSP WP 500 g/kg (50%) 1 Lorsban Advanced is a water-based emulsion, low volatile organic carbon solvent content May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 6

7 Overview of Agricultural Uses Overview of Agricultural Uses for Field, Fruit, Nut and Vegetable Crops Following is an overview of the crops that represent 97.4% of the average chlorpyrifos pounds used yearly in the U.S. Use rates are listed as pounds of active ingredient per acre (lbs a.i./a). Alfalfa Products containing chlorpyrifos are widely used and highly effective against the most important insect pests of alfalfa. These pests include alfalfa weevil, leafhoppers, aphids, and Lepidoptera pests. Use rates in the Midwest and Plains, which represent 60% of the total alfalfa area, are 0.75 lb a.i./a for alfalfa weevil and 0.50 lb a.i./a for leafhoppers. Rates in the West and Southern U.S. (nearly 35% of total alfalfa area) range from lb a.i./a. Brassica (Cole) Vegetables Broccoli, Cauliflower, and Cabbage Based on root ratings and damage estimates, products containing chlorpyrifos are among the most effective soil insecticides for controlling root maggots in cruciferous vegetables. Effective control of cabbage maggot, turnip maggot, and root aphid is achieved with at-plant applications of either a liquid or granular chlorpyrifos formulation. Rates range from lb a.i./a. Citrus Oranges, Lemons and Limes, Grapefruit, Nectarines, and Tangerines Products containing chlorpyrifos are widely used in citrus for control of scale, mealybug, citrus rust mite, various Lepidoptera larvae, and ants. Since the introduction of the Asian citrus psylla to the continental U.S. in 1998, chlorpyrifos has become one of the most widely used insecticides to control this pest. Currently, the Asian citrus psylla is present in Florida and Texas and recently it has been found in San Diego and Imperial Counties in California according to the California Department of Food and Agriculture [4] [5]. The typical use rate in Florida is 2.5 lb a.i./a. In California, use rates vary by pest: 3 6 lb a.i./a for California red scale and citricola scale, and 2 4 lb a.i./a for ants. Corn Products containing chlorpyrifos are used for the control of soil and foliar insect pests of non-transgenic corn. Chlorpyrifos use in corn has been declining since the introduction and wide adoption of insecticidal traits. Chlorpyrifos for control of rootworm, cutworm, wireworms, grubs, and European corn borer in corn is used mainly for refuge acres that do not contain the insecticidal traits. Use rates range from lb a.i./a. Cotton Products containing chlorpyrifos are primarily used in cotton production for control of cotton aphid, armyworms, and plant bugs in California and Arizona. Both ground and aerial application equipment are used for foliar application. Use rates range from lb a.i./a. Grapes Chlorpyrifos is used as dormant and post-harvest sprays for mealybug control. Use rate is 2.0 lb a.i./a. Additionally, chlorpyrifos is used as a soil-directed spray at a rate of lb a.i./a for ant control as part of mealybug management practices. Mint Chlorpyrifos is one of only a few chemical treatments registered for mint root borer and is also used to control other pests like redbacked cutworm and garden symphylans. Use rates for insect control in mint range from lb a.i./a. Onion Chlorpyrifos is currently one of only two treatment options for root maggot control (onion and seedcorn maggot) along with cyromazine, and the only non-seed treatment option available in dry bulb onion production. To keep both chemistries working, a rotation between chlorpyrifos and cyromazine is required. The use rate for insect control in onions is 1.0 lb a.i./a. Peanuts Products containing chlorpyrifos have been extensively utilized for the control of soil insect pests on peanuts in the U.S. A granular chlorpyrifos formulation at 2.0 lb a.i./a applied as band either at-plant or post-plant prior to pegging of the peanuts has shown to be highly effective for control of cutworms, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 7

8 Overview of Agricultural Uses lesser cornstalk borer, southern corn rootworms, and wireworms. Effective suppression of white mold, Sclerotium rolfsii, can be achieved as an added value of a granular chlorpyrifos application. Pome and Stone Fruits Cherries, Peaches, Nectarines, Plums, Prunes, and Apples Dormant and delayed dormant applications of products containing chlorpyrifos in combination with petroleum oil spray have demonstrated excellent efficacy and are widely used in commercial pome and stone fruit production. Pests controlled by chlorpyrifos include San Jose scale, peach twig borer, rosey apple aphid, pandemis and oblique-banded leafrollers, and climbing cutworms. The most common use rate for chlorpyrifos for pest control in these crops is 2.0 lb a.i./a. Applications of products containing chlorpyrifos directed to the trunk and main scaffold branches are highly effective for control of peach tree borer, lesser peach tree borer, and American plum borer in peaches, nectarines, and cherries. Soybeans Chlorpyrifos has a broad spectrum and is effective in treating a number of Arthropod pests in soybeans, including soybean aphid, bean leaf beetle, caterpillars, grasshoppers, leafhopper, two-spotted mites, and others. Use of chlorpyrifos has grown significantly in the last few years in soybeans as a result of the increased presence of the soybean aphid in the Midwest and the Great and North Plains areas that represent the largest soybean producing area in the U.S. (80% of total soybean producing area). Use rates in the Midwest and the Great and North Plains are lb a.i./a and lb a.i. in the Southeast. Sugar Beets At-plant soil applications of a granular chlorpyrifos formulation as well as post-emergence applications of either a liquid or granular chlorpyrifos formulation are highly effective for controlling sugarbeet root maggot and cutworms. Foliar applications of a liquid chlorpyrifos formulation are effectively used to control armyworms, cutworms, grasshoppers, and aphids. Application rates range from lb a.i./a, depending on pest and application type. Sunflower Chlorpyrifos provides broad spectrum control of several pests including banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil in sunflowers. Application rates range from lb a.i./a for pests such as moths and weevils to lb a.i./a for cutworms. Sweet Corn With its broad spectrum control, chlorpyrifos is used in Florida on the following insects that attack sweet corn: aphids, beet armyworm, chinch bugs, corn earworm, corn rootworm (adult), cutworms, fall armyworm, and grasshoppers. Chlorpyrifos granular applications are made at planting for control of corn rootworm larvae, cutworms, lesser corn stalk borer, seed corn maggot, and wireworms. Use rates in the Pacific Northwest are lb a.i./a and are lb a.i./a in Florida. Sweet Potatoes Chlorpyrifos has been the foundation insecticide for sweet potato growers for many years. There are few, if any, alternatives that provide effective sweet potato pest control. Chlorpyrifos is used at a rate of 2.0 lb a.i./a for controlling wireworms and flea beetles. Tree Nuts Almonds, Hazelnuts, Pecans, and Walnuts Chlorpyrifos is used as a foliar treatment and as a dormant or delayed dormant spray on almonds to control peach twig borer, navel orangeworm and San Jose scale. Walnut scale, codling moth and walnut husk fly are effectively controlled with foliar applications of a liquid chlorpyrifos formulation. Dormant or delayed dormant applications in combination with dormant oil are effective against walnut scale. The use rate of chlorpyrifos for almonds and walnuts is 2.0 lb a.i./a. Pecan insect pests controlled with chlorpyrifos include black pecan aphid, hickory shuckworm, Phylloxera, pecan nut casebearer, spittlebugs and yellow aphid complex. Rates to control these insect pests in pecans vary from lb a.i./a. Wheat Control of wheat midge, aphid pests, grasshoppers, brown wheat mite, and cutworms is achieved by use of products containing chlorpyrifos. Chlorpyrifos is particularly important to control the wheat midge, a devastating pest that affects yield if not controlled with an effective insecticide. Use rates range from lb a.i./a. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 8

9 Overview of Agricultural Uses References 1. Gianessi L. The Value of Insecticides in U.S. Crop Production. CropLife Foundation. March Accessed April 21, Dow AgroSciences. Chlorpyrifos North America. Chlorpyrifos Reregistration. Accessed April 21, Dow AgroSciences. Chlorpyrifos North America. About Chlorpyrifos. Accessed April 21, U.S. Department of Agriculture, Animal and Plant Health Inspection Service. Plant Health, Citrus Greening. March 25, Accessed April 10, Western Farm Press. Asian Citrus Psyllids Detected in Imperial County. October 20, Accessed April 21, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 9

10 Chlorpyrifos Use Analysis Chlorpyrifos Use Analysis - EPA s Screening Level Usage Analysis Versus Actual Use Data EPA Use Analysis On March 18, 2009, the EPA initiated the Registration Review process for chlorpyrifos through publication of a Federal Register Notice. EPA posted a number of documents in the Federal Docket including: Screening level use analysis Summary of labeled uses The Screening Level Usage Analysis (SLUA) dated February 7, 2008, for chlorpyrifos (059101) estimates that approximately 8,005,000 lb of chlorpyrifos are applied annually (Table 2). The analysis was made based on use data available for the years 2001 to as described by EPA. The higher percentages of uses in EPA s analysis are attributed to 16 commodities: alfalfa, almonds, apples, corn, cotton, grapes, oranges, peanuts, pecans, soybeans, sugar beets, sweet corn, sweet potatoes, tobacco, walnuts, and wheat. Those 16 commodities accounted for 7.2 million lb a.i. of chlorpyrifos or approximately 90% of the total estimated use. Chlorpyrifos Benefits and Use Analysis Data included in this report is based on information from Doane and dmrkynetec, inc., as well as actual reported use data from the California Department of Pesticide Regulation (CDPR). Data from CDPR were included in this report when the crop represented more than 40% of the total reported chlorpyrifos use. This approach differs from that used in EPA s SLUA, which included data from CDPR only when the crop represented 95% or more of the total use in the U.S.A. The sum of all chlorpyrifos uses on average between the years 2003 and was estimated by this analysis to be approximately 7,260,912 lb a.i., which is 10.2% lower than the estimation by EPA s SLUA. This estimate excludes data for cranberries, figs, mint, and sweet potatoes as no information on chlorpyrifos use for these crops was available at the time this report was written. The authors believe that uses in other crops like Brussels sprouts, nectarines, tangelos, and tangerines are included within a larger group of crops (Brassica (Cole) vegetables, peaches, and citrus, respectively). The use analysis data presented in this report (Table 3) shows the following major differences when compared to the numbers presented in EPA s SLUA (Table 2). 1. In this report the authors consider the total amount of chlorpyrifos used on average between the years 2003 and to be 7,260,912 lb, 10.2% lower than the estimation by EPA s SLUA of approximately 8,005,000 lb a.i. 2. According to this use analysis, 341,991 lb of chlorpyrifos are applied annually in almonds, which is 46.2% lower than the EPA s estimated value of 500,000 lb. This difference can be attributed to the decision to use actual CDPR data in this report since nearly all almonds are grown in California. 3. According to this use analysis, all crucifer crops have a lower input of chlorpyrifos yearly when compared to EPA s SLUA. Broccoli, the biggest crop in this group, has almost 30,000 lb a.i. more in EPA s SLUA (49.0% higher), followed by cauliflower with almost 5,000 lb more (31.24% higher), and cabbage with roughly 1,000 lb more (13.7% higher estimation). The total over-estimated active ingredient use for this group of crops in EPA s SLUA is 35,579 lb (42.15%). The product of choice for these crops is the 15% granular formulation of chlorpyrifos (e.g., Lorsban 15G), which contains 35% and 33% less active ingredient when compared to the other available chlorpyrifos formulations (50% WP and 4EC formulations, respectively). Thus, the main difference between the actual use reported in this document and EPA s SLUA may be due to a calculation error of product vs. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 10

11 Chlorpyrifos Use Analysis concentration. The authors observed a similar difference when comparing CDPR data to that available from other sources used in this report. 4. According to this use analysis, chlorpyrifos use in cherries has steadily increased to reach 80,140 lb per year on average from the years 2003 to. EPA s SLUA considers 25.13% less use or 20,140 lb compared to the actual use in this crop. 5. According to this use analysis, EPA s SLUA over estimates the use of chlorpyrifos in corn by 382,568 lb (14.6%). This difference in use is mainly due to the steady reduction in insecticide uses in corn due to the adoption of transgenic corn in all major corn-growing areas. 6. This use analysis considers 85,350 lb (29.9%) more chlorpyrifos being used in cotton when compared to EPA s SLUA. 7. The citrus crop group shows another major difference between this use analysis and EPA s SLUA. Oranges, the biggest crop in this group, has close to 60,000 lb more reported in EPA s SLUA (24.1%). For lemons, chlorpyrifos input in EPA s SLUA is almost double the estimation in this report (91.4% more or 42,967 lb) and grapefruit has roughly 5,000 lb more (9.4%) when compared to the estimation in this report. Overall, the difference between EPA s SLUA and the estimation in this report for the whole group is 106,377 lb more (30.2%), mainly due to the differences between oranges and lemons, two very important crops in California. 8. According to this use analysis, EPA s SLUA considers that 80,787 lb more of chlorpyrifos are used in peanuts (67.8%). Part of this difference may be due to a conversion ratio of product and concentration since the 15% granular formulation of chlorpyrifos is widely used for this crop rather than the 50% WP or 48% EC formulations. 9. This use analysis shows that 317,953 lb more of chlorpyrifos are used in soybeans compared to EPA s SLUA. The main difference between the two amounts is due to the fact that EPA s SLUA considers data from The analysis in this report considers data from, years in which there has been a steady increase in the use of chlorpyrifos in soybeans to control the soybean aphid especially in the Midwest where most of the soybeans are grown. 10. This use analysis shows that 204,495 (104.6%) fewer pounds of chlorpyrifos are used in walnuts. The difference between the estimated values may be due to the fact that this analysis only considers data from CDPR since most of the chlorpyrifos use in walnuts is in the state of California. 11. When combining chlorpyrifos use in grapes in this analysis (table and wine grapes), there is a difference of 29,031 more pounds being used versus EPA s SLUA, which considers grapes as a whole group. 12. This use analysis shows that 21,326 less pounds of chlorpyrifos are used in plums and prunes, 15,810 fewer pounds are used in sorghum, 14,857 more pounds are used in sunflowers, and 20,881 more pounds are used in sweet corn. 13. Finally, the following crops, which are considered in EPA s SLUA, do not have chlorpyrifos approved U.S. uses: apricots, artichoke, avocado, cantaloupes, carrots, chicory, lettuce (tolerance but no U.S. use) olives, pistachios, potatoes, seed crops, spinach, squash, tomatoes, and watermelons. These crops account for more than 30,000 lb of chlorpyrifos according to EPA s SLUA. In addition to the uses listed in Tables 2 and 3, chlorpyrifos is used in greenhouse applications and nursery applications. For instance, the Federal quarantine requirements from APHIS specify insecticide treatment of either chlorpyrifos or bifenthrin for ant control for all containerized and B&B (balled & burlapped) nursery stock moved from quarantined to non-quarantined regions. Other similar quarantine and specialty uses are also listed for chlorpyrifos, but they are not included in this report. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 11

12 Table 2. EPA Screening Level Estimates Table 2. EPA Screening Level Estimates of Agricultural Uses of Chlorpyrifos (059101).** May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 12

13 Table 2. EPA Screening Level Estimates Table 2. Cont. EPA Screening Level Estimates of Agricultural Uses of Chlorpyrifos (059101). **Source: EPA Registration Review Docket, March 18, 2009 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 13

14 Table 3. Chlorpyrifos Usage Data Comparison Table 3. Chlorpyrifos Usage Data Comparison Following is a comparison of chlorpyrifos usage data from 2003 based on information from Doane, dmrkynetec, inc., CDPR, and usage estimates provided by EPA. Major Crops Annual Usage Lb a.i Annual Usage Lb a.i. Annual Usage Lb a.i. Annual Usage Lb a.i. Annual Usage Lb a.i. Average Annual Usage 2003 EPA s SLUA Estimate % Diff. EPA Estimate vs. Actual Data Alfalfa 423, , , , , , , % Almonds 202, , , , , , , % Apples 457, , , , , , , % Asparagus 38,183 22,106 12,530 19,972 17,728 22,104 20, % Beans (Green) 1 n/a 4,535 6,176 5, , % Broccoli 65,916 62,475 61,428 58,336 53,771 60,385 90, % Brussels Sprouts 6,000 n/a Cabbage 6,547 12,801 5,024 12,560 7,055 8,797 10, % Cauliflower 15,995 16,366 16,623 14,960 12,249 15,239 20, % Cherries 68,992 79,241 83,095 90,108 79,264 80,140 60, % Corn 4,400,527 3,674,600 2,208,453 1,672,318 1,131,260 2,617,432 3,000, % Cotton 341, , , ,874 67, , , % Cranberries 50,000 n/a Cucumbers ,001 10,475 n/a n/a 3,832 3, % Dry Beans/Peas 1 4,134 n/a 170 6,181 1,648 3,033 4, % Figs 5,000 n/a Grapefruit 73,749 32,393 57,438 20,591 90,106 54,855 60, % Grapes (Table) 50,047 59,879 52,330 66,202 73,683 60, , % Grapes (Wine) 29,407 68,435 78,156 76,877 90,141 68,603 n/a % Hazelnuts 2,915 12,704 8,062 7,764 4,984 7,286 7, % Lemons 56,330 55,656 47,030 45,654 30,496 47,033 90, % Mint 50,000 n/a Nectarines 20,000 n/a Onions 50,507 50,388 94,562 81,005 67,561 68,805 60, % Oranges 124, , , , , , , % Other 2 16,482 7,539 22,719 7,813 6,806 22,515 33,500 n/a Peaches 60,243 97,073 58,767 80,736 52,447 69,853 70, % Peanuts 96, ,473 93, , , , , % Pears 30,218 29,930 30,027 20,259 37,384 29,564 30, % Peas 1 (Fresh/Green/Sweet) 286 n/a n/a ,012 <500 n/a Pecans 264, , , , , , , % Peppers 1 2, n/a 1,807 n/a 1,509 2, % Plums/Prunes 26,803 20,014 20,065 18,220 8,269 18,674 40, % Pumpkins 2,106 1,122 4,221 3,427 3,079 2,791 2, % Sod 2,000 n/a Sorghum 17,388 5,035 21,483 24,523 2,523 14,190 30, % Soybeans3 107,517 1,079,434 1,057,374 1,827,485 1,017, , % May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 14

15 Table 3. Chlorpyrifos Usage Data Comparison Table 3. Cont. Chlorpyrifos Usage Data Comparison Major Crops Annual Usage Lb a.i Annual Usage Lb a.i. Annual Usage Lb a.i. Annual Usage Lb a.i. Annual Usage Lb a.i. Average Annual Usage 2003 EPA s SLUA Estimate % Diff. Estimate vs. Actual Data Strawberries 3,746 13,550 6,942 13,464 12,514 10,043 9, % Sugar Beets 141, , , , , , , % Sunflowers 11,126 21,132 24,855 41,591 75,580 34,857 20, % Sweet Corn 99, , , , , , , % Sweet Potatoes 100,000 n/a Tangelos 2,000 n/a Tangerines 6,000 n/a Tobacco 96, ,146 87,651 94,355 99,737 98, , % Walnuts 163, , , , , , , % Wheat 228, , , , , , , % Grand Total 7,673,689 7,388,009 6,974,088 6,876,423 6,302,432 7,260,912 8,005, % 1 Average annual usage calculated based on number of years for which data was available. 2 Average for other crops is the sum of all averages per each individual crop taking into account the number of years where data was available for each crop. 3 Soybean average use data is for. - Annual data columns primarily reflect information from Doane and dmrkynetec, inc. for the respective year. - For crops where more than 40% of chlorpyrifos use took place in California, the base data for California usage reflects information reported by CDPR (e.g., almonds and broccoli). May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 15

16 U.S. Chlorpyrifos Agricultural Crops Use Analysis May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 16

17 Alfalfa Alfalfa Overview According the U.S. Department of Agriculture (USDA), alfalfa is the fourth most widely grown crop in the U.S., with an estimated annual value of $11.7 billion. Alfalfa hay is primarily used as a feed mostly for dairy cows, but also for horses, beef cattle, sheep, and other farm animals [1]. More than 20 million acres of alfalfa were grown in the U.S. in Approximately 60% of planted alfalfa acres are in the West and Plains regions. U.S. Alfalfa Production 2008 Region 2008 Average Atlantic 1,636,001 1,310,000 1,419,087 1,330,001 1,289,999 1,397,018 Midwest 6,745,000 6,840,001 6,630,911 6,319,998 6,010,002 6,509,182 Plains 6,540,001 6,270,002 6,700,001 6,260,001 6,010,005 6,356,002 South 20,000 n/a West 7,284,997 7,450,002 7,410,005 7,319,992 7,269,996 7,346,998 Grand Total 22,225,999 21,870,005 22,160,004 21,229,992 20,580,002 21,613,200 According to studies cited by CropLife Foundation, insecticide use in alfalfa varies by region: (numbers in these parentheses represent % acres treated) Northeast (48%), South (80%), North Central (14%), and West (33%) [2]. Chlorpyrifos Use From to 2008, chlorpyrifos was one of the top two active ingredients used to control insect pests in U.S. alfalfa. In and 2008, chlorpyrifos was the most used active ingredient, representing 22.8% and 26.4% of total acres treated, respectively. On average, chlorpyrifos was used in 19.2% of the total treated acres from to In 2008, 783,616 lb a.i. of chlorpyrifos were reported by Doane to be used on alfalfa crops. Top Active Ingredients all U.S Percent of all Alfalfa Active Ingredient % % % % % 2008 Average % 2008 LAMBDA-CYHALOTHRIN 16.54% 19.12% 20.63% 26.32% 23.61% 21.53% CHLORPYRIFOS 15.91% 22.84% 13.50% 13.88% 26.43% 18.69% The West and Plains regions account for 78% of all treated acres in alfalfa. In these two regions, chlorpyrifos is one of the most often used insecticides. Top Active Ingredients 2008 Percent of in West and Plains Region Top Active Ingredients in West and Plains Region 2008 Average 2008 CHLORPYRIFOS 22.58% 27.07% 13.67% 14.43% 28.91% 21.61% LAMBDA-CYHALOTHRIN 9.68% 12.34% 13.81% 16.79% 19.29% 15.02% ZETA-CYPERMETHRIN 16.50% 11.54% 16.88% 19.00% 11.18% 14.69% May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 17

18 In 2008, chlorpyrifos was the leading active ingredient in the combined West and Plains regions and accounted for nearly 29% of all active ingredient acres. Top Active Ingredients 2008 Percent of in West and Plains Region 2008 Leading Active Ingredients Active Ingredient % of All a.i. Cost per Acre CHLORPYRIFOS 1,097, % $7.15 LAMBDA-CYHALOTHRIN 732, % $8.15 ZETA-CYPERMETHRIN 424, % $4.50 According to the CDPR, in 189,451 lb a.i. of chlorpyrifos were used in 6,107 treatments on 386,498 acres of California grown alfalfa to control insect pests [3]. California Chlorpyrifos Use Used and Total 2003 Year Total Used , , , , , , , , , ,498 Total 1,091,804 2,293,732 Average 218, ,746 Source: California DPR 2009 Alfalfa According to Doane, an average of 365,891 lb a.i. was used annually in California from 2003 to. Based on data from CDPR during the same timeframe, an average of 458,746 lb a.i. of chlorpyrifos were actually used on alfalfa in California giving a difference of almost 93,000 more pounds applied vs. Doane s estimation. Target Pests Three target pests in alfalfa -- alfalfa weevil, armyworms, and blue alfalfa aphid -- account for 54% of total treated acres. Each causes significant losses in alfalfa as described below. Chlorpyrifos provides broad spectrum control of a number of insect pests in alfalfa and is the leading active ingredient in controlling alfalfa weevil and armyworm. Top Target Pests in Plains and West Regions Based on all Active Ingredients on Total Plains and West Regions Top Pests Total All Active Ingredients 2008 % of All 2008 Alfalfa Weevil 1,695, % Armyworm 666, % Blue Alfalfa Aphid 478, % Total Pest 5,270, % Alfalfa Weevil The alfalfa weevil is one of the primary insect defoliators of alfalfa. Annually, insect pests of alfalfa, including the alfalfa weevil, cause hundreds of millions of dollars in losses. Young larvae damage alfalfa by feeding on terminal buds; larger larvae feed on the leaflets. Feeding by older larvae is the most damaging and is characterized as skeletonization and bronzing of the leaves in spring. Under severe pressure, complete defoliation can occur [4]. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 18

19 Alfalfa The alfalfa weevil is an annual pest in districts east of the Sierra Nevada mountains and in the northernmost counties of California [5]. The alfalfa weevil is the target insect pest in 30% of all treatments nationally and accounts for 32% of all applications in the Plains and West. While 17 active ingredients are used in alfalfa, only 10 are used for alfalfa weevil. Chlorpyrifos is the leading active ingredient to control alfalfa weevil, used in 25% of the treated acres. In treating this pest, the cost of using chlorpyrifos at $5.31 per acre was 16% lower than the average of all active ingredients ($6.31) in Leading Active Ingredients to Control Alfalfa Weevil 2008 Active Ingredient Active Ingredient Active Ingredient % of Total a.i. CHLORPYRIFOS 493, % LAMBDA-CYHALOTHRIN 489, % CARBOFURAN 263, % Total Alfalfa Weevil a.i. 1,976, % Armyworm Armyworms skeletonize foliage, leaving veins largely intact. First and second instar larvae tend to feed in clusters around the egg mass from which they hatch. Chlorpyrifos is the leading active ingredient used to control armyworm; 73% of the active ingredient acres with armyworm as a target were treated with chlorpyrifos. For armyworm, the 2008 price of chlorpyrifos of $9.19 was 8.0% higher than the average cost of $8.52 for all active ingredients. Leading Active Ingredients to Control Armyworm 2008 Application Active Ingredient Application % of Total Applications Cost per Acre CHLORPYRIFOS 488, % $9.19 METHOMYL 101, % $9.09 CYFLUTHRIN 33, % $3.01 Total Armyworm 666, % Chlorpyrifos Formulations, Rates, and Applications Several formulations of chlorpyrifos are listed for treating alfalfa including Lorsban Advanced, Lorsban- 4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 15G (and other chlorpyrifos granular formulations), Lock-On, and Cobalt. Location: Midwest and Northeast Pests: alfalfa weevil Application Type: custom and farmer applied with ground equipment Application Method: ground Rate: 0.75 lb a.i./a Number of Applications: 1 - only highly managed alfalfa (dairy) is treated Timing of Application: application made to first cutting Pests: potato leafhopper Application Type: custom and farmer applied with ground equipment Application Method: ground Rate: 0.5 lb a.i./a Number of Applications: 1 - only highly managed alfalfa (dairy) is treated Timing of Application: application made to second or third cutting May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 19

20 Alfalfa Location: Southern Plains (KS, OK, TX) Pests: alfalfa weevil Application Type: typically custom applied Application Method: equally split between air and ground Rate: lb a.i./a Number of Applications: 1-3 Season of Application: application made to first cutting Location: Southern Plains (KS, OK, TX) Pests: aphids Application Type: typically custom applied Application Method: equally split between air and ground Rate: lb a.i./a Number of Applications: 1 Timing of Application: application made to first cutting Location: CA and AZ Pests: alfalfa weevil, beet armyworm, western yellowstriped armyworm, aphid Application Type: custom applied Application Method: mainly by air Rate: lb a.i./a (aphid control at lower rates) Number of Applications: 1 treatment in Central Valley; Desert alfalfa (Arizona and Imperial Valley) can receive multiple cutting treatments in years when severe armyworm pressure is present Timing of Application: application made to first cutting Chemical Treatments for Insect Control in Alfalfa Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Active Ingredient Brand Names Benefits, Application, Use, and Efficacy Lorsban-4E, Cobalt, Good rotation product to avoid resistance, Lorsban Advanced, reasonably good alfalfa weevil control and very Lock-On, Nufos, good control of various aphids in alfalfa as well Chlorpyrifos 4E AG, as leafhoppers; important tank mix partner for DuraGuard ME, Saurus, Lygus control in alfalfa grown for seed. Whirlwind, Govern, Warhawk CHLORPYRIFOS (organophosphate) CHLORPYRIFOS + GAMMA-CYHALOTHRIN LAMBDA-CYHALOTHRIN (pyrethroid) ZETA-CYPERMETHRIN (pyrethroid) CYFLUTHRIN (pyrethroid) CARBOFURAN (carbamate) Cobalt Warrior, Warrior II, Karate, Lambda-T, Silencer, Helena Lambda Mustang, Mustang Max, Hero, Baythroid Furadan Good rotation product to avoid resistance, reasonably good alfalfa weevil control and very good control of various aphids in alfalfa as well as leafhoppers. Combines two modes of action providing good knock down and residual effect. Pyrethroid that performs well on alfalfa weevil; favorable PHI Pyrethroid that performs well on alfalfa weevil; favorable PHI Pyrethroid for alfalfa looper and cutworms Very good control of alfalfa weevil and good control of aphids, can lead to aphid flaring later in the season; use is continuing to decline as many crop uses have been discontinued. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 20

21 Alfalfa MALATHION (organophosphate) GAMMA-CYHALOTHRIN (pyrethroid) DIMETHOATE (organophosphate) METHOXYFENOZIDE (diazylhydrazine) METHOMYL (carbamate) various Proaxis, Prolex various Intrepid 2F Lannate, Nudrin Handling precautions and stricter restrictions limit use. Less effective control of alfalfa weevil, but acceptable on aphids and leafhopper Pyrethroid that performs well on alfalfa weevil; a favorable PHI Aphids and leafhoppers, not alfalfa weevils Very good control of Lepidoptera larvae; reduced risk insecticide that can be tank mixed with other products to broaden the spectrum. Soft on beneficial arthropods. Minor use Non-Chemical Alternatives Early cutting of alfalfa will sometimes substitute for chemical control, although maximum yield is not obtained when the crop has to be cut for insect control. Grower Perspective In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is a selection of excerpts from grower organizations who responded to the EPA s request for input by explaining why they considered chlorpyrifos essential for protecting their crops. Submissions to the docket are public information and have been posted by the EPA at docket number EPA-HQ-OPP Alfalfa and alfalfa seed producers in many parts of the country rely heavily on the pest control benefits Lorsban [i.e., chlorpyrifos] provides. The pests it controls alfalfa weevil, army cutworm, grasshoppers, leafhoppers, lygus bugs, aphids can devastate a crop. Alfalfa seed producers are strongly advised to rotate insecticide families (i.e., organophosphates, carbamates and synthetic pyrethroids) in their lygus control program to help prevent the development of insecticide resistance. Removing [chlorpyrifos] as one of these options increases the likelihood of the development of insect resistance. National Alfalfa and Forage Alliance Alfalfa is not a high insecticide-use crop, but that could change dramatically without chlorpyrifos and cause adjacent crops to also require more pesticide applications. Alfalfa fields are managed as IPM [Integrated Pest Management] tools because they host extremely high numbers of beneficial insects that migrate to adjacent crops. Chlorpyrifos has a moderate effect on beneficial insects. It is well documented that pyrethroids, the chemical class used most often as a substitute, is much more disruptive to beneficial insects. Therefore banning chlorpyrifos would harm IPM programs and increase the need for insecticide use. Additionally, banning the chemical [chlorpyrifos] would greatly increase the potential for insect resistance due to the small number of alternative chemicals registered for alfalfa. California Alfalfa and Forage Association References 1. United States Department of Agriculture, Agricultural Research Services. Alfalfa. May 15, Accessed April 5, Gianessi L. The Benefits of Insecticide Use: Alfalfa. CropLife Foundation. March Accessed April 5, California Department of Pesticide Regulation. Summary of Pesticide Use Report Data, Indexed by Chemical. : Accessed April 5, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 21

22 4. Cook, K., Gray, M., Ratcliffe, S., Steffey, K., Alfalfa Weevil. University of Illinois Extension.. Accessed April 5, University of California, UC IPM Online. How to Manage Pests, Alfalfa. November. Accessed April 10, Alfalfa May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 22

23 Brassica Vegetables Brassica Vegetables (Cole Crops) Overview Brassica vegetable crop production in the Western U.S. represents 78% of all brassica crop acres in the U.S. Among all brassica crops, broccoli is the leading crop accounting for 53% of all acres. California accounts for 73% of all brassica vegetable crop acres and is the largest broccoli producing state with 127,000 acres, according to a number of agricultural sources. The 2002 Census of Agriculture noted that California represented just 21% of all U.S. growers and yet accounted for 85% of total harvested broccoli acreage. California also grows 14,800 acres of cabbage and 33,700 acres of cauliflower. Today, cabbage is grown commercially in 10 states; and cauliflower in 2, California and Arizona. U.S. Brassica Vegetables Production 2003 CROP 2003 Average 2003 Broccoli 136, , , , , ,620 Cabbage 81,791 78,520 72,930 72,885 73,675 75,960 Cauliflower 44,400 42,348 37,000 36,700 38,500 39,790 Total 262, , , , , ,370 U.S. Broccoli Production 2003 Year Arizona California Total , , ,100 11, , ,900 12, , ,000 12, , ,000 12, , , , , ,000 Source: USDA NASS 2009[1] Chlorpyrifos Use In, growers used 118,788 lb a.i. of chlorpyrifos to control insect pests in broccoli. Another 21,199 lb a.i. were used for cauliflower and 12,990 lbs a.i. for cabbage, according to Doane. CDPR reports that in, 53,771 lb a.i. of chlorpyrifos were used in 3,448 applications to control insect pests in 42,140 acres of broccoli. CDPR data on actual product used shows significant differences to the data reported by Doane for California. California Chlorpyrifos Use for Broccoli Used and Total 2003 Year Chlorpyrifos Pounds a.i. Used Total ,836 52,203 61,227 47,713 61,428 47,060 58,336 46,096 53,771 42,140 Source: California DPR 2009 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 23

24 Brassica Vegetables California Chlorpyrifos Use for Cauliflower Lb Used and Total 2003 Year Chlorpyrifos Lb a.i. Used Total ,771 15,650 14,853 15,311 16,202 16,521 14,703 14,991 12,249 11,846 Source: California Department of Pesticide Regulation For cauliflower, CDPR reports 12,249 lb a.i. of chlorpyrifos were used in 1,121 applications to control insects in 11,846 acres; 3,730 lb were used in 429 applications on 3,808 acres of cabbage in California. University of California Integrated Pest Management Program advises growers to rotate chemicals with a different [IRAC] mode-of-action Group number, and do not use products with the same mode-ofaction Group number more than twice per season to help prevent the development of resistance [2]. The availability of chlorpyrifos provides producers with another mode-of-action group to rotate with other insecticides, which helps delay resistance development to each of the compounds. In the absence of chlorpyrifos, resistance development to target insect pests in brassica vegetables would definitely proceed at an accelerated rate since few compounds are registered to control some pests like cabbage maggot. Based on the CDPR data, chlorpyrifos is one of the most used active ingredients for pest control in broccoli. Chlorpyrifos has a 24-hour pre-harvest interval, which is shorter than other alternatives. Leading Active Ingredients to Control Insect Pests in California Broccoli Active ingredient OXYDEMETON-METHYL 67,328 INDOXACARB 61,576 CHLORPYRIFOS 53,771 IMIDACLOPRID 52,100 DIMETHOATE 45,860 SPINOSAD 38,548 Source: California Department of Pesticide Regulation Active Ingredients to Control Insect Pests in California Cauliflower Active ingredient IMIDACLOPRID 18,901 INDOXACARB 15,214 OXYDEMETON-METHYL 13,054 CHLORPYRIFOS 11,846 DIMETHOATE 11,699 SPINOSAD 10,758 Source: California Department of Pesticide Regulation Target Pests May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 24

25 Brassica Vegetables The most important pests in brassica crops are cabbage aphids, diamondback moths, and cabbage maggot. Cabbage aphids are also the leading pests in cauliflower and the second most treated pests in cabbage. Cabbage Aphid Cabbage aphids suck plant sap from the leaf. The affected leaves curl and crinkle or form cups, completely lined with the aphids. In severe infestations, the plants wilt and die. The plants, if not killed, are dwarfed, grow slowly and form small light heads. Badly infested plants become covered with a mass of the small soggy aphids, and the dying leaves and plants rapidly decay [3]. Chlorpyrifos is the fourth leading active ingredient used for controlling cabbage aphid in all brassica crops, accounting for 21,602 pest active ingredient acres. At a treatment cost of $15.87 per acre, chlorpyrifos is 18% lower than the average of all active ingredient costs. Leading Active Ingredients Used to Control Cabbage Aphid All Brassica Crops Active Ingredient (Pest ) % of OXYDEMETON-METHYL 111, % DIMETHOATE 59, % IMIDACLOPRID 55, % CHLORPYRIFOS 21, % Total Cabbage Aphid Pest 272,567 Cabbage Maggots Cabbage maggots damage and destroy root systems of all brassica crops, riddling roots with tunnels when infestations are heavy. Tunnels provide entryways for pathogens that cause blackleg and bacterial soft rot. Young plants between seedling emergence until about a month after thinning or transplanting are most vulnerable [4]. Chlorpyrifos is the primary active ingredient used to control cabbage maggots in broccoli, accounting for 93% (24,733) of the pest active ingredient acres. There are limited choices in chemicals approved for use on cabbage root maggot and the limited modes of action registered represents a challenge for insect resistance management. Diazinon, one of the chemical alternatives to chlorpyrifos has a long pre-harvest interval, making it less desirable for use. Chlorpyrifos Formulations, Rates, and Applications The formulations registered for controlling insect pests in brassica vegetables include Lorsban 15G (and other chlorpyrifos granular formulations), Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), and Lorsban 75WG. Location: CA Crops: broccoli, cabbage, cauliflower Pests: cabbage root maggot, root aphid Application Type: spray Application Method: at-plant, band Rate: 1 2 lb a.i./a (Lorsban-4E) Number of Applications: 1 Location: CA May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 25

26 Brassica Vegetables Crops: broccoli, cauliflower Pests: cabbage root maggot Application Type: ground Application Method: at-plant, band Rate: 2.25 lb a.i./a (15 lb/a Lorsban 15G) Number of Applications: 1 Chemical Treatments for Insect Control in Brassica Vegetables Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Active Ingredient Brand Names Benefits, Application, Use, and Efficacy CHLORPYRIFOS Lorsban Effective in controlling cabbage maggot and cabbage aphid in broccoli, Brussels sprouts, cabbage, cauliflower; short 24 hr pre-harvest interval for broccoli DIAZINON ACETAMIPRID DIMETHOATE Diazinon AG500 Diazinon 50W Effective for cabbage maggot; 2 3 qt per acre; 4 6 lb in 50 gals. of water (for drench application), lb for 50W and pt for AG500; longer pre-harvest intervals, especially with cabbage is disadvantage Assail For cabbage aphid; oz; no more than 5 applications per season Dimethoate 4EC, For cabbage aphid in broccoli, cabbage, Dimethoate 2.67EC cauliflower and Brussels sprouts; 0.5 pt 4EC, Admire Pro, Provado 0.75 pt 2.67EC For cabbage aphid; Admire is preplant fl oz; Provado 3.75 fl oz IMIDACLOPRID INSECTICIDAL SOAP M-Pede Contact insecticide with smothering and barrier effects; partial control for cabbage aphid for broccoli, cabbage, cauliflower and Brussels sprouts; may be phytotoxic on Brussels sprouts and cabbage NALED OXYDEMETON- METHYL PYMETROZINE Dibrom8 MSR Spray Concentrate 2SC Fulfill For cabbage aphid in broccoli, Brussels sprouts, cabbage and cauliflower; 1 pt For cabbage aphid in broccoli, cabbage and cauliflower; longer pre-harvest interval for Brussels sprouts; pt For cabbage aphid; best used in a tank mix with another insecticide registered for aphids; no more than 2 applications per crop/season Non-Chemical Alternatives Once cabbage maggot damage is noticed, it is too late to apply control procedures. Thus, economic thresholds are not useful and all management options are preventive. Since the first generation of cabbage maggots is the most damaging, planting seeds or transplants after the peak of adult emergence and egg laying in the spring may provide the best control. Grower Perspective In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following are excerpts from grower organizations explaining why chlorpyrifos is essential for protecting crops. Submissions to the docket are public information and have been posted by the EPA at docket number EPA-HQ-OPP Oregon growers use it [chlorpyrifos] quite regularly to control insects such as cabbage maggot on broccoli and cauliflower Growers have not found alternative products that offer the control of chlorpyrifos. Elimination of chlorpyrifos would have significant negative impacts on Oregon growers May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 26