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

27 Brassica Vegetables ability to competitively produce processed vegetable crops and consequently would severely hamper the entire processed vegetable industry in the state. Oregon Processed Vegetable Commission The directors of the Maine Vegetable and Small Fruit Growers Association support the continued use of the active ingredient chlorpyrifos for agricultural production. In Maine, the principle agricultural uses of chlorpyrifos are in field corn, sweet corn, broccoli, cabbage and other cole crops, and strawberries. For broccoli and other cole crops, it is the only active ingredient available that effectively controls root maggot. For our other crops, this is an important active ingredient to maintain in order to be able to provide a rotation to effectively manage insect resistance development. Maine Vegetable and Small Fruit Growers Association Crop Consultant Perspective In preparing this report, growers and crop consultants were recently asked to share their thoughts on the benefits and use of chlorpyrifos for pest control. For cole crops, chlorpyrifos provides good protection against seed corn maggot at planting. It s a valuable pest control tool. We keep losing products that were previously available to us for pest control, and now there are very few soil-applied options available. As a result, we are seeing pests like garden symphylans appear, which didn t happen back when we had more options to rotate in. Kevin Vaughan, Crop Production Services, Greenfield, CA, (April 2009) References 1. U.S. Department of Agriculture, National Agricultural Statistics Service. Database Quick Stats. Accessed April 10, University of California, UC IPM Online. How to Manage Pests, Cole Crops. November Accessed March 3, Griffin, R.P., Williamson, J. Clemson University. Cabbage, Broccoli & Other Cole Crop Insect Pests. April. Accessed April 1, Van Wychen Bennett, K. University of Minnesota. Cabbage Maggot. January Accessed March 16, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 27

28 Citrus Citrus Overview In, citrus orchards totaled 972,662 acres in the U.S. Citrus crops are mainly divided into four major groups: oranges, grapefruit, lemons, and limes. Overall, data show that total acres grown in the U.S. are declining, with citrus acres planted in the U.S. down 13% in compared to the 1,129,205 acres planted in. The top citrus producing states are Florida (oranges and grapefruit), California (oranges, lemons, and grapefruit), Texas (grapefruit), and Arizona (lemons). Sixty-six percent of U.S. citrus acres are in Florida. Florida and California account for 90% of total U.S. citrus acres grown. Oranges The U.S. is the second largest orange-producing country in the world. Florida is the leading U.S. state for orange production, followed by California. Florida s orange crop, most of which is processed, was forecasted to reach 7.6 million tons in the 2008 season. If realized, it would be the biggest production since the 2003 season. California was forecasted to produce 2.2 million tons of oranges in season, 29% more than the prior year s freeze-damaged crop. Most of California s oranges are marketed as fresh fruit for domestic and export use [1] [2]. U.S. Orange Production Average Oranges Florida 692, , , , ,637 California 234, , , , ,024 Total 926, , , , ,670 Lemons California produces approximately 77% of the U.S. lemon crop, with Arizona producing the remaining balance. Over the past three seasons, California produced an average of 754 million tons of lemons annually. During this time, about 66% of the crop went to the fresh market, with the remainder used in processing. U.S. per capita fresh lemon consumption reached a high of 3.96 lb in -. Since 2000, Americans have consumed an average of 3.3 lb per person, up from the average of 2.7 lb throughout the 1990s. While imports account for only about 8% of fresh lemon consumption since 2000, they account for almost half the lemon juice consumption [2]. U.S. Lemon Production Lemons Average - California 56,734 55,473 55,473 56,734 56,104 Arizona 17,537 17,182 15,997 15,997 16,678 Total 74,271 72,655 71,470 72,731 72,782 Grapefruit The U.S. is one the major producers of grapefruit around the world. Only four states, Florida, California, Texas, and Arizona, produce grapefruit commercially in the U.S. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 28

29 Citrus U.S. Grapefruit Production Grapefruit Average Florida 96,976 83,661 70,464 67,636 79,684 California 12, n/a Texas 18,352 18,352 18,352 18,352 18,352 Total 128, ,013 88,816 85, ,234 Chlorpyrifos Use Nationally, chlorpyrifos was the third most often applied insecticide on citrus, accounting for 12% of active ingredient acres (an acre treated with an individual active ingredient, some products may contain more than one active ingredient). Chlorpyrifos is also the third leading active ingredient used in California and ranks fourth in Florida. The total number of chlorpyrifos active ingredient acres has more than doubled in citrus over the past four years, from 207,495 acres in to 438,399 acres in. U.S. Chlorpyrifos Use Active Ingredient Chlorpyrifos a.i. Chlorpyrifos a.i. Chlorpyrifos a.i. Chlorpyrifos a.i. Average Chlorpyrifos a.i. 207, , , , ,452 In, 926,896 lb a.i. of chlorpyrifos were used to treat insect pests in U.S. citrus. Of that, 770,452 lb a.i. were used in oranges (419,218 in California and 351,234 in Florida), 90,106 lb a.i. in grapefruit and 66,338 lb a.i. for lemons. (See California Citrus section for additional use data.) Florida Target Pests In Florida, the top three citrus pests treated with insecticides are Asian citrus psyllid, rust mite and citrus leaf miner. These insects account for 67% of active ingredient acres used in Florida. Top Pests in Florida Citrus All Active Ingredients Pest Asian Citrus Psyllid 1,500,922 Rust Mite 1,127,594 Citrus Leaf Miner 695,465 Total 4,988,398 Asian Citrus Psyllid Asian citrus psyllid is important in citrus production because it is the vector for economically devastating citrus greening. Citrus greening, also called Huanglongbing or yellow dragon disease, is one of the most serious diseases of citrus. Infected trees are stunted and sparsely foliated and twig dieback and leaf and fruit drop occur. Fruit produced by infected trees are small, lopsided, hard and do not properly color. The juice is bitter. This bacterial disease is thought to have originated in China in the early 1900s. The disease is primarily spread by two species of psyllid insects. One species, the Asian citrus psyllid, Diaphorina citri, has been present in Florida since 1998 [3]. 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 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 29

30 Citrus Agriculture. Since the introduction of the Asian citrus psylla, chlorpyrifos has become one of the most widely used insecticides to control this pest [4] [5]. Citrus Rust Mite The citrus rust mite and the pink citrus rust mite are found on all citrus varieties throughout Florida. Although they can co-exist on the same leaf or fruit, the citrus rust mite is usually the prevalent species. However, the pink citrus rust mite develops to greater damaging populations early in the season (April- May). Both rust mites are important pests of fruit grown for the fresh market. Fruit damage is the main concern with other varieties. Both mites feed on green stems, leaves and fruit with the pink citrus rust mite being potentially more destructive [6]. Chlorpyrifos Use in Florida Citrus Florida accounts for 74% of all treatment acres and 70% of all treatment expenditures. In Florida, chlorpyrifos is the fourth leading active ingredient. The use of chlorpyrifos in Florida citrus has increased significantly from to, due primarily to control the Asian citrus psyllid which is the vector of the bacteria that causes citrus greening. Leading Active Ingredients - Florida Citrus Active Ingredients in Florida Pest Management Average PETROLEUM OIL 1,083, , , , ,208 ABAMECTIN 160, , , , ,735 IMIDACLOPRID 42,212 20, , , ,345 CHLORPYRIFOS 47,134 42,214 67, , ,621 SULFUR 151, , , , ,232 Florida citrus crops are currently being treated up to eight times per year with broad-spectrum pesticides to reduce Asian citrus psyllid and slow the spread of the disease. Pesticides can reduce the number of psylla, but an adult psyllid carries the bacteria its entire life and can transmit the disease faster than some pesticides will kill it [7]. A total of 43 insecticide active ingredients were reported used on citrus; only 17 were used on the Asian citrus psyllid. Three insecticides, imidacloprid (a neonicotinoid), chlorpyrifos and fenpropathrin (a pyrethroid), account for 60% of the active ingredient acres treated for Asian citrus psyllid in Florida. Due to its broad spectrum, applications of chlorpyrifos are also targeted to control scale insects, mealybugs, aphids, whitefly, ants, orange dog, grasshoppers, and katydids and knock back the adults of rust mites and leaf miners. Nearly all chlorpyrifos applications in citrus are put out with petroleum oil. Chlorpyrifos application costs are less compared to the two other leading active ingredients. For Asian citrus psyllid, chlorpyrifos costs growers around $20 per acre based on 5 pt/a. Use of Chlorpyrifos in California Citrus In California, chlorpyrifos has been one of the most frequently applied active ingredients for controlling pests in oranges. According to Doane data, chlorpyrifos was applied on more than 120,000 citrus acres in and on an average of 154,000 citrus acres. Petroleum oil is used as a tank mix product with chlorpyrifos in about 25% of applications. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 30

31 Citrus Leading Active Ingredients Sprayed on All California Citrus Total Active Ingredient Average PETROLEUM OIL 125, , , , ,579 CHLORPYRIFOS 151, , , , ,066 SPINOSAD 145,892 99, , , ,117 CYFLUTHRIN 85,828 66,981 60, ,481 82,871 California Oranges Leading arthropod pests: Mites, thrips and scale Leading Active Ingredients Sprayed on California Oranges Total Active Ingredient Average SPINOSAD 141,939 96, , , ,170 CHLORPYRIFOS 121, , , , ,455 PETROLEUM OIL 77,700 90, , , ,815 CYFLUTHRIN 83,948 66,981 58, ,714 81,907 California Lemons Leading arthropod pests: Mites, thrips and scale Leading active ingredients Sprayed on California Lemons Total Active Ingredient Average - PETROLEUM OIL 47,198 67,592 83,074 48,404 61,567 ABAMECTIN 28,316 33,030 42,633 35,333 34,828 CHLORPYRIFOS 26,946 24,131 41,431 19,533 28,010 The CDPR reports the following data regarding chlorpyrifos use in citrus crops within the state [8]. Chlorpyrifos Use on California Oranges Pounds a.i Average Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Use Use Use Use Use Use , , , , , ,579 Source: California Department of Pesticide Regulation 2009 California Orange with Chlorpyrifos Average , , ,346 77,931 46,239 76,487 Source: California Department of Pesticide Regulation 2009 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 31

32 Citrus Chlorpyrifos Use on California Lemons Lbs a.i Chlorpyrifos Use 2003 Chlorpyrifos Use Chlorpyrifos Use Chlorpyrifos Use Chlorpyrifos Use Average Chlorpyrifos Use ,917 52,848 44,145 44,660 29,413 45,397 Source: California Department of Pesticide Regulation 2009 California Lemon with Chlorpyrifos Average ,591 17,033 12,507 12,479 9,631 13,648 Source: California Department of Pesticide Regulation 2009 California Target Pests A number of insect pests threaten California oranges, including scale (red and citricola), thrips, katydids and mites. Chlorpyrifos is one of the most frequently used active ingredients for control of scale and katydids. California Red Scale California red scale is one of the key pests of citrus in California. Significant economic damage results from these scale insects settling on the fruit, causing cosmetic flaws and downgrading the fruit quality. There is a very low threshold for California red scale in citrus orchards. To keep populations below the threshold, growers have traditionally relied on high-volume sprays (up to 1,000 gallons per acre) of insecticides [9]. Citricola Scale Citricola scale can be a serious pest of citrus in the San Joaquin Valley. A severe infestation may reduce tree vigor, kill twigs, and reduce flowering and fruit set. As they feed, citricola scale excrete honeydew, which accumulates on leaves and fruit. Sooty mold grows on honeydew and interferes with photosynthesis in leaves and causes fruit to be downgraded in quality during packing [10]. Use of Chlorpyrifos in Controlling Citricola and Red Scale Use of chlorpyrifos is favored by growers due to high efficacy against citricola and red scale and relatively short residual profile compared to other products. Other insecticides that are effective against red scale are not effective against citricola scale. The bulk of California citrus is targeted at the fresh market, and a large percentage of the crop is grown for export and marketed as fresh fruit. There is a low threshold for cosmetic injury, and significant dockage and loss of export opportunity occurs with detectable California red scale on the fruit. Importance of Chlorpyrifos in Integrated Pest Management Programs in Citrus Chlorpyrifos has minimal impact on the beneficial Aphytis wasp, which is important for late season biocontrol of California red scale populations. Control of scales in California citrus, especially oranges and lemons is a high anxiety issue for the producers. It has been documented that some insecticide alternatives to chlorpyrifos have a negative impact on the vedalia beetle, a beneficial predatory insect used as biological control to naturally regulate populations of cottony cushion scale in citrus. The vedalia beetle is very sensitive to Baythroid [cyfluthrin], an insecticide being used for citrus thrips control. Baythroid kills the beetles and prevents them from laying eggs for about one month. The vedalia beetle is also very sensitive to the insect growth regulators, Esteem (=Knack, pyriproxifen) and Applaud (buprofezin) which are applied for California red scale May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 32

33 control. The insect growth regulators prevent vedalia from pupating and emerging as adults and in the case of Esteem they prevent the adults from laying fertile eggs [11]. Citrus Asian Citrus Psyllid The Asian citrus psyllid was previously only important in Florida citrus, but has recently been found in San Diego and Imperial Counties in California according to the California Department of Food and Agriculture. Since the introduction of the Asian citrus psylla in Florida in 1998, chlorpyrifos has become one of the most widely used insecticides to control this pest. Chlorpyrifos Formulations, Rates, and Applications The formulations of chlorpyrifos listed for controlling insect pests in citrus include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban Advanced and Lorsban 75WG. In California, all industries and sources of volatile organic compounds (VOC) are being required to reduce emissions to meet the ozone standards of the federal Clean Air Act. The CDPR has been working for several years to reduce pesticide VOC emissions by specified amounts to meet obligations under the 1994 State Implementation Plan. VOC issues have immediate ramifications at the grower level. In certain counties, growers are already limited in their product choices, their method of application and their application timing with certain crop protection products. Emulsifiable Concentrate (EC) pesticide formulations are to top contributor to nonfumigant pesticide VOC emissions in the San Joaquin Valley, and Lorsban Advanced has less than half the VOC emissions potential as EC formulations of chlorpyrifos. Location: CA Pests: California red scale (CRS) or citricola scale (CS) Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer Rate: lb a.i./a Number of Applications: 1 Season of Application: May August Location: CA Pests: foliar lepidoptera (very limited use) Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer Rate: lb a.i./a Number of Applications: 1 Season of Application: May August Location: CA Pests: katydids (very limited use) Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer Rate: 0.5 lb a.i./a Number of Applications: 1 Season of Application: May August May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 33

34 Citrus Location: CA Pests: ant (grove floor or directed to trunk) Product: Lorsban-4E, Lorsban Advanced Application Type: ground and trunk Application Method: airblast sprayer Rate: lb a.i./a Number of Applications: 1 Season of Application: May August Location: FL Pests: Asian Citrus Psyllid Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer Rate: 2.35 lb a.i./a(lorsban Advanced); 2.5 lb a.i./a Lorsban-4E Number of Applications: 1 Season of Application: Jan Dec Location: FL Pests: foliar lepidoptera (very limited use) for young trees Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer or hand gun on young trees Rate: 1.5 lb a.i./a Lorsban-4E Number of Applications: 0.25 of areas with young trees treated Season of Application: May October Location: FL Pests: katydids (very limited use) Product: Lorsban-4E, Lorsban Advanced Application Type: Foliar Application Method: Airblast sprayer Rate: 1.5 lb a.i./a Number of Applications: 0.25 of areas with young trees treated Season of Application: May October Location: FL Pests: ants (grove floor) Product: Lorsban-4E, Lorsban Advanced Application Type: ground and trunk Application Method: herbicide sprayer Rate: 1.0 lb a.i./a Number of Applications: 2 Season of Application: May November Location: FL Pests: citrus rust mite Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 34

35 Citrus Rate: 2.5 lb a.i./a Number of Applications: 1 Season of Application: April June Location: FL Pests: scale insects Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer Rate: 1.5 lb a.i./a Number of Applications: 2 Season of Application: April October Location: FL Pests: mealy bugs Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer Rate: 2.0 lb a.i./a Number of Applications: 1 Season of Application: April May Location: FL Pests: aphids Product: Lorsban-4E, Lorsban Advanced Application Type: foliar Application Method: airblast sprayer or hand gun on young trees Rate: 1.5 lb a.i./a Number of Applications: 0.5 of areas with young trees treated Season of Application: April May Location: FL Pests: grasshoppers Product: Lorsban-4E, Lorsban Advanced Application Type: foliar and ground Application Method: airblast sprayer or hand gun on young trees Rate: 2.0 lb a.i./a Number of Applications: 1 Season of Application: August October May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 35

36 Citrus Chemical Treatments for Insect Control in Citrus 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 (organophosphate) Lorsban-4E, Lorsban Advanced Highly efficacious against citricola and red scale. Relatively short residual profile. In young trees where ant feeding can girdle a young tree in a few days, chlorpyrifos is only viable solution. Best for katydid control. PETROLEUM OIL Moderately effective. Not suitable for heavy infestation of scale. Compatible with biocontrol. High rates required in CA for CRS make economics questionable. Often tank mixed with chlorpyrifos or other products used in citrus. ABAMECTIN (carbamate) Clinch Ant Bait, Agri-Mek Effective for broadcast application against ants; applied prophylacticly due to its slow action. Works in young trees where ant feeding can girdle a tree in a few days. Also used to control citrus rust mite and citrus leafminer. IMIDACLOPRID Provado, Admire (neonicotinoid) Thrips, Asian citrus psylla control SPINETORAM Delegate Asian citrus psylla control ALDICARB (carbamate) Temik Asian citrus psylla control FENPROPATHRIN (pyrethroid) Danitol Citrus thrips, toxic to vedalia beetle FENBUTATIN OXIDE Vendex Foliar applied for control of mites. Applied aerially, airblast or groundboom. CYFLUTHRIN (pyrethroid) Baythroid Used in tank mixes with other products for katydid control, toxic to vedalia beetle PYRIPROXIFEN Esteem Insect growth regulator (juvenoid) with good homopteran activity. This product has been used in rotation with chlorpyrifos and has helped to prevent or minimize the development of resistance by red scale to organophosphates. Grower cost of this product is roughly 2X that of chlorpyrifos. It does not control citricola scale and is highly toxic to vedalia beetle (the most effective biological control agent for cottony cushion scale). Non-Chemical Alternatives Biocontrol is widely practiced in citrus production, particularly the management of homopteran pests (scales, mealybugs and aphids). Focus is to minimize impact of pesticide sprays on biocontrol programs. Chlorpyrifos has been shown to be compatible with most of the biological control agents in use in citrus. Grower Perspective In preparing this report, growers and crop consultants were recently asked to share their thoughts on the benefits and use of chlorpyrifos for pest control. Chlorpyrifos knocks down citricola scale, a very hard to control scale in citrus that has no natural predators. It is effective on a wide range of pests including red scale, cutworms, and katydids. In granular form, Lorsban 15G offers excellent ant control. In the winter, we use a half gallon per acre of Lorsban for mealybug control in grapes. Dennis McFarlin, Pest Control Advisor, Gar Tootelian, Inc., Reedley, CA (April 2009) May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 36

37 References 1. U.S. Department of Agriculture, National Agricultural Statistics Service, Citrus January Forecast. January 12, Accessed February 2, Pollack, S.L. and Perez, A. U.S. Department of Agriculture, Economic Research Service. Fruit and Tree Nuts Outlook. November, 28,. Accessed February 2, Citrus 3. U.S. Department of Agriculture, Animal and Plant Health Inspection Service. Plant Health, Citrus Greening. March 25, Accessed April 10, 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, Childers, C.C., Rogers, M.E., McCoy, C.W., Nigg, H. N., and Stansly P.A., University of Florida Extension Service Florida Citrus Pest Management Guide: Rust Mites, Spider Mites, and Other Phytophagous Mites. Accessed April 10, University of California, UC IPM Online. A New Pest in California, Diaphorina citri (Asian Citrus Psyllid): Provisional Treatment Guidelines for Citrus in Quarantine Areas. January 14, Accessed April 10, California Department of Pesticide Regulation. Summary of Pesticide Use Report Data 2003-, Indexed by Chemical. Accessed April 12, University of California, UC IPM Online. How to Manage Pests, Citrus/California Red Scale and Yellow Scale March Accessed April 10, University of California, UC IPM Online. How to Manage Pests, Citrus/Citricola Scale. January Accessed April 10, Hoffmann, M.P., Shelton, A.M., Weeden, C.R. Cornell University. Biological Control: A Guide to Natural Enemies in North America. Rodolia cardinalis (Coleopter: Coccinellidae) Vedalia Beetle. Accessed March 3, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 37

38 Corn Corn Overview Corn is the most widely produced feed grain in the U.S., accounting for more than 90% of the total value and production of feed grains. The number of acres of corn in the U.S. grew dramatically in and 2008, increasing from an average of around 80 million acres for through to a record 92.2 million acres in and 86.7 million acres in 2008 [1]. The majority of corn crops are grown in the Midwest region. Most of the crop is used as the main energy ingredient in livestock feed. Corn is also processed into a multitude of food and industrial products including starch, sweeteners, corn oil, beverage and industrial alcohol, and fuel ethanol. The U.S. is a major player in the world corn trade market, with approximately 20% of the corn crop exported to other countries. Eighty-six percent of 2008 corn acres were grown in the Midwest and Plains states. Five states, Iowa, Illinois, Nebraska, Minnesota and Indiana, account for 56% of planted acres. U.S. Corn Production Planted 2008 Total Planted Total Planted Total Planted Total Planted Total Planted 2008 Average Planted ,968,005 80,990,086 78,765,028 92,230,017 86,705,020 83,931,631 Growth in Insect Traits in Corn Above- and below-ground pests such as the corn rootworm, black cutworm, western bean cutworm, and European corn borer can destroy corn, minimizing the yield that growers can produce on each acre of their farming operation. The economic impact of these pests can be devastating. The USDA estimates that corn rootworm causes more than $1 billion in lost revenue each year, which includes $800 million in yield loss and $200 million in treatment costs, making it the costliest pest in corn. Increased adoption of corn with insect-resistance traits that protect against a number of pests including the corn rootworm and European corn borer have greatly reduced the need to apply insecticides. Since, Doane data show insect trait acres have grown from 30% of planted acres to 66% of planted acres. During the same time period, seed treatments have grown from 9% of application acres to 31% and soil applied treatments have declined from 30% to 10% of application acres. Growers who plant Bt (Bacillus thuringiensis) corn hybrids are required to implement an insect resistance management plan by planting a portion of refuge acres that do not have the Bt genes. Planting a refuge of non-bt corn helps decrease the natural selection pressures that can lead to insect resistance. These refuge acres ensure that rare resistant insects that feed on insect-protected varieties of corn will mate with susceptible insects and delay the development of resistance. Target Pests While the growth in popularity of Bt corn has changed growers use of insecticides, chlorpyrifos continues to be used on corn refuge acres to control corn rootworm, Western bean cutworm, cutworm, and secondary pests. Treatment of first year corn represents about 10% of the volume of chlorpyrifos applied to corn. It is also important to ensure that post-emergence insecticide treatments like chlorpyrifos remain available for use in the event of an insect pest outbreak. In 2008, 960,555 lb a.i. of chlorpyrifos were used on U.S. corn crops, down about 15% from the 1,131,260 lb a.i of chlorpyrifos used to treat insect pests on corn in. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 38

39 Corn Chlorpyrifos Use in Corn Lbs a.i Used Used Used Used Used 2008 Average Used ,674,600 2,208,453 1,672,318 1,131, ,555 1,929,437 Chlorpyrifos Formulations, Rates, and Applications Formulations typically used for controlling insect pests in corn are Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 15G (and other chlorpyrifos granular formulations), Lorsban Advanced, and Cobalt. Location: Midwest and Northeast Pest: armyworm, cutworms Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a (EC) Number of Applications: 1 Timing of Applications: preplant, at-plant, preemergence Location: Midwest and Northeast Pest: grasshoppers Application Type: ground, air, chemigation Application Method: post application Rate: lb a.i./a (EC) Number of Applications: 1 Timing of Applications: post to corn emergence Location: Midwest Pest: armyworm, cutworms, aphids, rootworm adults, European corn borer, flea beetle adults, southern corn leaf beetle, webworms, western bean cutworm Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a (EC) Number of Applications: 1 Timing of Applications: post to corn emergence Location: Midwest and Northeast Pest: armyworm, cutworms, aphids, European corn borer, flea beetle adults, webworms Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a (EC) Number of Applications: 1 Timing of Applications: post to corn emergence Location: Midwest and Northeast Pest: corn earworm Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a (EC) Number of Applications: 1 Timing of Applications: post to corn emergence May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 39

40 Corn Location: Midwest Pest: rootworm larvae, lesser cornstalk borer, common stalk borer Application Type: ground, air, chemigation Application Method: broadcast Rate: 1.0 lb a.i./a (EC) Number of Applications: 1 Timing of Applications: post to corn emergence Location: Midwest and Northwest Pest: rootworms, cutworms, wireworm, lesser seed corn borer, billbugs Application Type: ground Application Method: at plant Rate: 1.30 lb a.i./a (granular) Number of Applications: 1 Timing of Applications: at planting Location: Midwest Pest: European corn borer Application Type: aerial, ground Application Method: broadcast or directed Rate: lb a.i./a (granular) Number of Applications: 1 Timing of Applications: in relation to corn growth from V9 to R1 References 1. United States Department of Agriculture (2008). Economic Research Service Corn Briefing Room. Accessed February 3, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 40

41 Cotton Cotton Overview More than 9.3 million acres were planted with cotton in the U.S. in Nearly 85% of cotton is produced in the Southern and Plains states. In the Western states of California and Arizona, cotton is grown on more than 400,000 acres. Most of the cotton grown in California is in the San Joaquin Valley. Since 2000, losses due to insect pests in cotton nationwide have remained below 5%. This is attributed to the boll weevil eradication and widespread use of transgenic (Bt) cottons. Today, around 90% of U.S. cotton acreage had some type of transgenic technology. According to a recent study compiled by Mike Williams, Extension Entomologist at Mississippi State University, the new number one damaging cotton pest in the U.S. is Lygus, or plant bug, with losses of 1.08%. It infested about 61% of cotton acreage. States with the highest percentage of losses include Arizona, California, Louisiana and Missouri [1]. Chlorpyrifos Use Although chlorpyrifos usage in cotton in recent years typically represents less than 0.5% of all active ingredients used on this crop, it is an important tool in U.S. cotton production systems. The strongest fit for chlorpyrifos in cotton insect management is in the Western U.S. According to Doane data, in 45,731 lb a.i. of chlorpyrifos were used to combat insect pests in cotton; in 2008, 33,191 lb a.i. of chlorpyrifos were used. In 2008, 150,000 active ingredient acres were treated with chlorpyrifos; 43% of these were in California and Arizona. While chlorpyrifos is seldom used for pest control in cotton in the Plains and Southern states, in 2008 it was reported through Doane that chlorpyrifos was used to control thrips on 36,753 treatment acres, primarily in Alabama; and for black cutworm control on 37,840 acres, primarily in Tennessee. The CDPR reports that in, 41,105 lb a.i. of chlorpyrifos were used in 385 applications to control insect pests on 46,862 acres of cotton. In California, chlorpyrifos is an important ingredient for control of cotton aphid and late season armyworm populations. Chlorpyrifos is typically applied at 0.75 lb a.i./a for control of these pests, but is rarely utilized as a stand-alone treatment. Chlorpyrifos Use in California Cotton Lbs a.i Chlorpyrifos 2003 Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Average Chlorpyrifos Lb a.i , , , ,854 41, ,802 Source: California Department of Pesticide Regulation California Cotton with Chlorpyrifos Average , , ,565 46, ,097 Source: California Department of Pesticide Regulation Maintaining the availability of chlorpyrifos in the cotton insecticide complex is important for viability of long-term resistance management programs. Target Pests The target pest most often treated with chlorpyrifos was Lygus bug. In the West, chlorpyrifos was one of the top five ingredients used to control Lygus bug, treating 37,891 active ingredient acres in 2008, according to Doane. At $3.42 per acre treated, chlorpyrifos costs 63% less than all active ingredient May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 41

42 Cotton ($9.48) treatments for Lygus bug. Chlorpyrifos is also used to control armyworms in California. It is still used by growers for cotton aphid control, though its use has been reduced by other products introduced for this purpose. Top Active Ingredients for Lygus Bug Control 2008 Western Region Active Ingredient Active Ingredient 2008 FLONICAMID 96,558 OXAMYL 50,194 BIFENTHRIN 43,275 ACEPHATE 38,180 CHLORPYRIFOS 37,891 Chlorpyrifos Formulations, Rates, and Applications The formulations listed for controlling insect pests in cotton include Lorsban-4E (and other 4 lbs per gallon EC formulations of chlorpyrifos), Lorsban Advanced, and Lock-On (in Arizona and California). Location: California, Arizona Pests: cotton aphid, beet armyworm, yellowstriped armyworm, Lygus bug Application Type: foliar Application Method: ground and air Rate: lb a.i./a Number of Applications: cotton aphid (3), armyworms (2), Lygus (3) Season of Application: aphids and armyworms July to September; Lygus July to August Chemical Treatments for Insect Control in Cotton 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, Nufos, Yuma, Lorsban Advanced, Lock- On Effective for Lygus and aphids CHLORPYRIFOS THIAMETHOXAM Centric Aphid foliar, air & ground, very effective ACETAMIPRID Assail Aphid foliar, air & ground, effective IMIDACLOPRID Provado Aphid foliar, air & ground, effective FLONICAMID Carbine Lygus foliar, air & ground, very effective Steward Armyworms foliar, air & ground, very INDOXACARB effective, no effect on Lygus Non-Chemical Alternatives Avoid late-season nitrogen applications, which are very conducive to cotton aphid population increases. Avoid planting safflower near cotton Lygus reproduce very well in safflower. Grower Perspective In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is an excerpt from a grower organization that 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 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 42

43 Cotton Chlorpyrifos in cotton is used primarily against cotton aphids, and particularly late-season infestations. These infestations are potentially very damaging in terms of sticky cotton. Chlorpyrifos is a highly effective chemical and one we can ill afford to lose. California Cotton Ginners and Growers Association References 1. Robinson, E. Delta Farm Press. Plant bug most damaging pest. January 23, Accessed March 9, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 43

44 Grapes Grapes Overview The U.S. wine, grape, and grape products industries contribute more than $162 billion annually to the American economy. The U.S. grape and grape products industries are largely concentrated in California, which accounts for virtually all table grapes and raisins, and roughly 90% of the nation's wine production, with New York and Washington State each at about 3% and the rest of the states at 4% combined, according to a study by MKF Research LLC of Napa Valley [1]. Almost all U.S. raisins are produced in California s San Joaquin Valley. According to Doane, California dominates the grape market with 96% of the acres in. Wine grapes account for 58% of the acres grown. U.S. Grape Production 2003 (Note: No data reported in - for Michigan, Pennsylvania and Washington) State Type of Grape 2003 Average 2003 California Raisin 346, , , , , ,883 Table 103,357 90,176 91,263 90,176 90,176 93,030 Wine 555, , , , , ,813 California Total All 1,005, , , , , ,726 New York Raisin Table ,065 3,537 1,571 2,999 Wine ,651 33,179 38,698 33,110 New York Total All ,716 36,716 40,269 36,593 Raisin 139 n/a Table n/a Michigan Wine n/a Michigan Total All n/a Table n/a Pennsylvania Wine n/a Pennsylvania Total All n/a Table n/a Washington Wine n/a Washington Total All n/a Grand Total (Includes all states) All 1,119,069 1,000, , , , ,419 Target Pests Mealybug Insect pests in grapes include leaf hoppers, leafrollers and mealybugs. The most important insect pests in table grapes are mealybugs. Mealybugs are also among the most troublesome pests in raisin grapes. According to the University of California Integrated Pest Management program, three species of mealybug (Pseudococcus) can infest vineyards, including grape, obscure, and longtailed mealybugs. The primary species of concern in North Coast and San Joaquin Valley vineyards are the grape and obscure mealybugs. In Central Coast vineyards, obscure and longtailed mealybugs can cause damage. In the Coachella Valley, longtailed mealybug may occur [2]. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 44

45 Grapes In recent years there have been increases in the number of grape mealybug infestations in the San Joaquin Valley and North Coast and an increase in the incidence of obscure and longtailed mealybugs in Central Coast vineyards. Susceptibility to mealybug damage varies by variety. It is worse on varieties that produce clusters close to the base of the shoot because the fruit often touches old wood. Mealybugs damage grapes by contaminating clusters with cottony egg sacs, larvae, adults, and honeydew. Often the honeydew is covered with a black sooty mold. All three species can transmit grape viruses [2]. Within the last decade, a new species of mealybug, the vine mealybug, Planoccoccus ficus, has been spreading in California vineyards. Damage by the vine mealybug, is similar to that of other grapeinfesting mealybugs in that it produces honeydew that drops onto the bunches and other vine parts and serves as a substrate for black sooty mold [2]. This species produces several generations per year, feeds more and produces significantly more honeydew than the other three species, consequently causing significantly more economic damage to the crop than the other species. Also, the mealybug itself will be found infesting bunches making them unfit for consumption. Vine mealybug can also transmit grape viruses [2]. In California, the vine mealybug occurs in the Coachella and Central valleys, the Central and North coasts, and the Sierra foothills. The host range of the vine mealybug includes grape, fig, date palm, apple, avocado, citrus, and a few ornamentals. To date, vine mealybug has only been found feeding on grapevines in California, however this pest is spreading to new areas of the state [3]. Chlorpyrifos Use According to Doane, in 147,804 lb a.i. of chlorpyrifos were used to control insect pests in table grapes, 106,845 lb a.i. for wine grapes and 84,780 for raisins. Chlorpyrifos has steadily grown in importance over the last five years for the grape industry. Chlorpyrifos Use 2003 As Percentage of Total Type of Grape Chlorpyrifos % of 2003 Chlorpyrifos % of Chlorpyrifos % of Chlorpyrifos % of Chlorpyrifos % of Average Chlorpyrifos % of 2003 Raisin 0.60% 0.88% 2.38% 2.98% 5.72% 2.9% Table 10.34% 7.20% 14.50% 16.24% 13.73% 12.0% Wine 1.09% 4.07% 5.22% 5.04% 6.27% 4.3% All 2.91% 4.10% 6.59% 6.54% 7.42% 5.6% Doane data show chlorpyrifos as the leading active ingredient in table grapes, accounting for 14% of all active ingredient acres. For wine grapes and raisins, chlorpyrifos accounted for approximately 6% of total acres treated. At an average cost of $28.35 per acre, using chlorpyrifos on table grapes costs 15% and 7.2% less, respectively, than the second and third most used active ingredients. Leading Active Ingredients - Active Ingredient Table Grape % of Total Table Grape Cost per Acre CHLORPYRIFOS 48, % $28.35 IMIDACLOPRID 42, % $33.23 SPINOSAD 40, % $30.53 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 45

46 According to the CDPR, the major insecticides applied in by acres treated for wine grapes were imidacloprid, oils, chlorpyrifos, dinotefuran and buprofezin. The acres treated with insecticides increased by 17% from to. In, 90,141 lb a.i. of chlorpyrifos were used in 811 applications on 46,559 acres of wine grapes; and 73,683 lb a.i. were used in 1,006 applications on 39,471 acres of table grapes. California Chlorpyrifos Use Lbs a.i California Grapes Chlorpyrifos 2003 Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Average Chlorpyrifos Table 50,047 59,879 52,330 66,202 73,683 60,428 Wine 26,880 54,117 78,156 76,877 90,141 65,234 Total 76, , , , , ,662 Source: California Department of Pesticide Regulation 2009 California with Chlorpyrifos 2003 w/chlorpyrifos w/ Chlorpyrifos 2003 w/ Chlorpyrifos w/ Chlorpyrifos w/ Chlorpyrifos w/ Chlorpyrifos Average w/ Chlorpyrifos Table 25,214 28,441 27,759 35,834 39,471 32,876 Wine 14,071 27,725 39,046 40,289 46,559 33,538 Total 39,285 56,166 66,805 76,123 86,030 66,414 Source: California Department of Pesticide Regulation 2009 Based on Doane data, chlorpyrifos is the leading active ingredient for control of vine mealybug in all California grapes, accounting for 75,498 active ingredient acres in. Leading Active Ingredients for Vine Mealybug Control Active Ingredient CHLORPYRIFOS 75,498 MALATHION 45,296 BUPROFEZIN 36,305 Grapes The majority of chlorpyrifos used in grapes is applied as a dormant spray just prior to bud break in table and wine grapes in California and the Pacific Northwest for control of grape, vine and obscure mealybugs. Chlorpyrifos is also used as a post harvest for control of vine mealybug. Both applications are typically applied at 2.0 lb a.i./a at GPA and are often combined with lime-sulfur treatments. In addition to dormant and post harvest sprays for mealybug, chlorpyrifos is used as a directed spray to the soil in grapes at 1 2 lb a.i./a for control of ants. Since the ants tend mealybugs, effective mealybug suppression occurs as a result of controlling ant population. Chlorpyrifos was granted a Special Local Needs label, Section 24(c), for control of grape mealybug in California in A similar Special Local Needs label was approved in Washington in Usage has grown to approximately 100, ,000 lb a.i. per year. Prior to the approval of dormant use of chlorpyrifos, the only management option for grape mealybug was directed ground sprays for suppression of ants. The use of chlorpyrifos for grape mealybug control is primarily in table grapes with some use in wine grapes. Raisin grapes are not currently treated for mealybugs. With the spread of vine mealybug in all grape growing regions of the state of California, the need for post harvest May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 46

47 treatment of grapes has significantly increased in the recent years. This trend will continue and may even intensify as there is no effective biological control for this pest. Grapes Chlorpyrifos is considered by the University of California to be the foundation of an effective and reliable mealybug management strategy. Timing of application is critical. If applied too early, efficacy is compromised; however, if applications go on post bud break, significant phytotoxicity can result. Post harvest applications of chlorpyrifos have been very effective, since new infestations are generally discovered during the harvest process and a timely treatment is critical for curtailing the spread of the pest to new vineyards. Chlorpyrifos Formulations, Rates, and Applications The formulations of chlorpyrifos listed for controlling insect pests in grapes include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos) and Lorsban Advanced for areas east of the Continental Divide. Oil-applied delayed dormant application of chlorpyrifos is most effective. Location: California Pests: grape and vine mealybug; obscure mealybug Application Type: airblast GPA Application Method: ground Rate: 2.0 lb a.i./a Number of Applications: maximum 2 per year Season of Application: post harvest (1) and dormant/delayed dormant (1) Chemical Treatments for Insects in Grapes 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, Nufos 4E, Oil-applied delayed dormant application of CHLORPYRIFOS Yuma, Lorsban Advanced Applaud chlorpyrifos is most effective for mealybugs Applied post bloom; supplemental to chlorpyrifos applications BUPROFEZIN IMIDACLOPRID Admire Pro Applied only in drip irrigated vineyards; not effective in all soil types, especially heavier soils IMIDACLOPRID Provado Foliar in-season application; supplemental to chlorpyrifos dormant and post harvest applications SPIROTETRAMAT Movento Foliar in-season application; supplemental to chlorpyrifos dormant and post harvest applications. Grower Perspectives 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 For California wine grapes, chlorpyrifos predominantly is used for managing the recently introduced vine mealybug, a significant problem in some regions and threat across the state. Approximately 39,000 wine grape acres were treated in, as published by the California Department of Pesticide Regulation. Chlorpyrifos is one of the few registered products and most efficacious for controlling vine mealybug, particularly its spread to noninfested areas. When used, the material is carefully applied at May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 47

48 Grapes delayed dormancy or post harvest for direct kill or to suppress ants that impede biological control of mealybugs. It is important to maintain all safe and effective uses of chlorpyrifos in California wine grapes, at least until other efficacious alternatives become available. California Association of Wine Grape Growers Chlorpyrifos is needed for control of a wide variety of pests. In California there are 17 counties infested with vine mealybug and once established, vine mealybug is difficult to eradicate. Black widow spider has become a serious issue due to quarantine requirements on U.S. table grape exports, and for stone fruit growers there are similar demands for zero tolerance of Oriental fruit moth on exports destined to Mexico. Chlorpyrifos continues to provide a significant benefit in managing these pests. California Grape and Tree Fruit League Additional Perspectives In preparing this report, growers and crop consultants were recently asked to share their thoughts on the benefits and use of chlorpyrifos for pest control. For wine grapes, I use Lorsban to control vine mealybug. We re limited to using Lorsban only during the dormant season. While there are other replacements out there, they are far more costly. For mealybug, you just can t afford not to use chlorpyrifos. I also grow lemons and there s really no other product available that has the broad spectrum control we need for citrus. I spray once with Lorsban for scale, leafhoppers, etc. If I didn t have Lorsban for citrus, I d have to spray two to three times with two or three other products just to get the same control. Bernie Borges, Vineyard Management, Monterey Pacific, Inc. Soledad, CA (April 2009) Chlorpyrifos knocks down citricola scale, a very hard to control scale in citrus that has no natural predators. It is effective on a wide range of pests including red scale, cutworms, and katydids. In granular form, Lorsban 15G offers excellent ant control. In the winter, we use a half gallon per acre of Lorsban for mealybug control in grapes. Dennis McFarlin, Pest Control Advisor, Gar Tootelian, Inc., Reedley, CA (April 2009) References 1. National Grape and Wine Initiative. Economic Impact Study. January 19,. Accessed April 10, University of California, UC IPM Online. How to Manage Pests, Grape/Mealybugs. October Accessed April 10, University of California, UC IPM Online. How to Manage Pests, Grape/Vine Mealybug. October Accessed April 10, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 48

49 Mint Mint Overview Mint is grown in the following states: Oregon, Washington, Idaho, Montana, California (northern), South Dakota, Indiana (northern), Michigan, and Wisconsin. Mint production in the U.S. in 2008 totaled 60,000 acres of peppermint and 20,400 acres of spearmint [1] U.S. Mint Production Harvested by State Peppermint Harvested 2008 (000s) Spearmint Harvested 2008 (000s) Oregon 19.0 Washington 13.3 Washington 16.0 Oregon 2.0 Idaho 14.0 Michigan 1.5 Indiana 6.5 Indiana 1.4 Wisconsin 3.7 Idaho 1.2 Michigan 0.8 Wisconsin 1.0 Source: USDA - NASS Chlorpyrifos Use There are limited data available on chlorpyrifos use in mint. Chlorpyrifos, which provides effective broad spectrum insect pest control, is used on peppermint and spearmint in the Pacific Northwest and other areas. Target Pests Several insect pests can cause damage to mint. The two-spotted spider mite is the number one pest, which is generally controlled by presence of other predator mites. Other annual insect pests include variegated cutworm, mint root borer, mint looper, mint flea beetle, and mint aphid. Some of these pests are controlled with products based on mineral or horticultural oils, as well as oils from various herbs/spices and insecticides, like azadirachtin from the neem tree, that are commonly used on organic crops and ornamental and greenhouse plants [2] [3] [4]. Only a few insecticides are registered for use to control insect pests in mint. Mint Root Borer The mint root borer has been a major pest in mint for many years and can severely reduce stands. Larvae feed inside mint rhizomes and on mint roots, largely from late July through September and into October in some years. This pest over-winters in the soil around mint roots and is present in most mintproducing areas except the Midwest. The practice of using new certified or quarantined planting materials have helped minimize infestations of mint root borer. This pest has not been present in the Midwest in part due to quarantine practices and requirements that growers use only certified planting material. However, in 2008 there were some reports of mint root borer in Michigan. CropLife Foundation notes that approximately 30% of the mint acres in the Pacific Northwest are treated to control mint root borers [5]. Chlorpyrifos is one of only a few chemical treatments registered for mint root borer; permethrin and ethoprop are the other alternatives. In Washington, where chlorpyrifos is the only registered active ingredient for mint root borer, the Pacific Northwest Insect Management Handbook notes that, In Washington, incorporating a broadcast Lorsban application with strip tillage has given good control [2]. Redbacked Cutworm Redbacked cutworm is a key pest of mint east of the Cascades. As mint begins to send up aerial growth in the spring, larvae feed underground by day, clipping off new spring shoots at or below ground May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 49

50 level. At night, larvae feed on and above the soil surface. In some years, damage to mint during May and early June in central Oregon has been severe enough to result in extensive stand loss in absence of larval control. Chlorpyrifos is one of the two products (acephate is the other) recommended for control of this insect pest. Garden Symphylan The garden symphylan feeds on mint hairs and root tissue and underground stems. Heavy feeding causes plant stunting, poor stem elongation, and small, chlorotic leaves. This insect is a very serious pest of many crops in western Oregon. Chlorpyrifos is one of three active ingredients listed for control of symphylan. It has the best toxicological profile of the three and is easy to use compared to metam sodium (a soil fumigant with long pre-plant interval). According to CropLife Foundation, 69% of mint acres in western Oregon are treated for symphylans [4]. Unique Uses of Chlorpyrifos Chlorpyrifos controls other important/secondary pests like craneflies, when applied to control primary pests included in the label. Craneflies feed on roots and underground rhizomes from fall through spring months. Research and field use in Oregon indicate it is effective against craneflies [2]. Mint Chlorpyrifos Formulations, Rates, and Applications The formulations of chlorpyrifos listed for controlling insect pests in mint include Lorsban-4E (and other 4 lbs per gallon EC formulations of chlorpyrifos) and Lorsban Advanced. Location: Pacific Northwest Product: chlorpyrifos (Lorsban-4E and other 4 lb per gallon EC formulations of chlorpyrifos) Pests: redback cutworm Application Method: sprinkler irrigation or ground Rate: 1.0 lb 2.0 lb a.i./a (1 lb rate when larvae are less than 0.75 inch long; 2-lb rate if larvae are longer than 0.75 inch) Number and season of Applications: 1, growing season Alternatives: acephate Location: Pacific Northwest Product: chlorpyrifos (Lorsban-4E and other 4 lb per gallon EC formulations of chlorpyrifos) Pests: mint root borer Application Method: chemigation Rate: 2.0 lb a.i./a postharvest Number and season of Applications: 1, post-harvest (August early September) Alternatives: permethrin, ethoprop Location: Pacific Northwest Product: chlorpyrifos (Lorsban-4E and other 4 lb per gallon EC formulations of chlorpyrifos) Pests: garden symphylan Application Method: broadcast and at planting Rate: 2.0 lb a.i./a Number and season of Applications: 1, growing season Alternatives: ethoprop; metam sodium May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 50

51 Non-Chemical Alternatives Parasitic nematodes - Applied at 2 billion/a preharvest, at 1.5 billion/a postharvest. Nematodes are applied most effectively by chemigation. This method allows for enough water to keep nematodes alive and to move them to the target pests. Mint References 1. Agri-View Crop Production Review. January 21, Accessed March 30, Pacific Northwest Insect Management Handbook. Accessed April 10, Drees, B. Texas Agricultural Extension Service. Management of Insects on Herbs. Accessed March 20, University of Florida IPM Center. Crop Profile for Herbs in Florida (Basil, Cilantro, Dill, Mint, Parsley, Rosemary, Sage, Thyme), July. Accessed March 20, Gianessi L. The Benefits of Insecticide Use: Mint. CropLife Foundation. March Accessed April 10, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 51

52 Onion Onion Overview According to the National Onion Association, U.S. farmers plant approximately 142,000 acres of onions, producing approximately 6 billion pounds of onions (excluding dehydration production) each year. Onions are grown in more than 20 states; the top producing states based on acres planted are Washington (22,790 acres), Idaho-Eastern Oregon (21,100 acres) and California (20,950 acres), followed by Texas, Georgia, New York, and Colorado [1]. Total Onion Planted Planted 2003 Planted Planted Planted Planted Planted 2008 Average Planted , , , , , , ,638 Source: USDA NASS Target Pests Maggots (onion maggot, root maggot, corn seed maggot and bean seed maggot) are important pests of onions. Larvae of seed corn maggots attack germinating seedlings, feeding on the developing roots and epicotyl. Their damage is usually restricted to the very early seedling stage. Onion maggots inflict similar damage but can continue to feed on the expanding bulb during later stages of growth. This results in increased rot in bulbs held in storage [2]. Chlorpyrifos Use According to Doane, 59,764 lb a.i. of chlorpyrifos were used on onions in A total of 65,593 acres were treated with chlorpyrifos in 2008 to control insect pests; 68.2% of the acres were in the West. The CDPR reports that in, 3,845 acres were treated in 92 applications with 3,406 lb a.i. of chlorpyrifos to control insects in dry bulb onions [3]. Chlorpyrifos Use - Lbs a.i. all U.S. Onion Total Lbs a.i Total Total Total Total Total 2008 Average ,507 50,388 94,562 81,005 67,561 59,764 67, Onion with Chlorpyrifos all U.S. % of Total Region 2008 West 44, % Atlantic 9, % South % Plains % Total 65, % Chlorpyrifos is currently one of only two treatment options for root maggots (onion, seedcorn root maggot) along with cyromazine and the only non-seed treatment option available in dry bulb onion production. Doane data show nearly 59,000 acres (pest acres treated) of onions were treated with chlorpyrifos to control maggots in May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 52

53 Onion The availability of chlorpyrifos allows onion producers to rotate between two different insecticide modes of action which helps delay resistance development to both compounds. Although onion maggot is resistant to chlorpyrifos in many areas, in the absence of chlorpyrifos, resistance development to cyromazine would definitely proceed at an accelerated rate. Resistance to cyromazine by root maggots has also been reported from some areas. U.C. Davis Integrated Pest Management lists chlorpyrifos for control of seed corn maggot in dry bulb onions [2]. Lorsban-4E should be applied as an in-furrow drench (1.1 fl oz/1000 row ft at 18-inch spacing or Lorsban 15G at 3.7 oz/1000 row ft at 18-inch spacing). Maximum one application per crop per year. Chlorpyrifos Formulations, Rates, and Applications Current chlorpyrifos formulations listed for controlling insect pests in onions include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos) and Lorsban 15G (and other chlorpyrifos granular formulations). Location: Pacific Northwest, NY, MI, WI Pests: onion maggot Application Type: ground/at plant soil drench Application Method: banded (2-4 inch) over the row Rate: 1.0 lb a.i./a Number and season of Applications: 1, Spring (at plant or early season postplant) Alternatives: Cyromazine is a seed treatment applied at a specialty seed treatment facility. To keep both chemistries working, a rotation between chlorpyrifos and cyromazine is required. References 1. National Onion Association,. About Unions: Bulb Onion Production. Accessed March 23, University of California, UC IPM Online. How to Manage Pests, Onion and Garlic/Maggots. November. Accessed March 23, California Department of Pesticide Regulation. Summary of Pesticide Use Report Data, Indexed by Chemical.. Accessed April 11, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 53

54 Peanuts Peanuts Overview The 2008 U.S. peanut crop was the largest peanut crop on record along with the highest average yield on record. In Georgia, where more than half of U.S. peanuts are produced, some experts are expecting significant acreage declines in 2009 due primarily to the demand for land from competing crops. Total U.S. peanut production for 2008 was estimated at 5.15 billion lb, up 3% from earlier forecasts and 40% more than was produced in. The southern states of Georgia, Alabama, and Texas account for 78% of planted peanut acres in the U.S. Other peanut producing states include Florida, North and South Carolina, Virginia, and Oklahoma. According to Doane, in 2008, more than 1.4 million acres of peanuts were grown in the U.S. U.S. Peanut Production by State 2008 State 2008 Average 2008 Georgia 580, , , , , ,999 Texas 260, , , , , ,000 Alabama 200, , , , , ,000 Florida 130, , , , , ,999 North Carolina 105,000 97,000 85,001 92,999 92,000 94,400 South Carolina 30,000 62,000 60,000 59,000 65,000 55,200 Virginia 35,000 23,000 17,000 22,000 22,000 23,800 Oklahoma 30,000 35,000 23,000 17,001 19,999 25,000 New Mexico 16,000 Total 1,386,004 1,626,998 1,210,000 1,195,993 1,428,993 1,366,398 Chlorpyrifos Use Chlorpyrifos is one of the leading active ingredients used to control insect pests in peanuts due to its efficacy and broad spectrum pest control. In 2008, 160,785 peanut acres were treated with chlorpyrifos. According to Doane, in 2008, 255,142 lb a.i. of chlorpyrifos were used to control insect pests in peanuts more than double the 111,844 lb a.i. reported used in. Total Chlorpyrifos Use in Peanuts Lbs a.i. Total 2003 Total Total Total Total Total 2008 Average Total , ,473 93, , , , ,868 Peanut with Chlorpyrifos 2008 Total Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos 2008 Average Chlorpyrifos ,522 61, ,157 61, ,785 92,443 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 54

55 Peanuts Leading Active Ingredients 2008 Total Total Active Ingredient All pests 2008 % of Total Active Ingredient 2008 ALDICARB 374, % PHORATE 277, % LAMBDA-CYHALOTHRIN 253, % ACEPHATE 165, % CHLORPYRIFOS 160, % Target Pests Peanuts are targeted by a number of damaging insect pests, including thrips, corn rootworm, threecornered alfalfa hoppers, lesser cornstalk borer, southern corn rootworm, and cutworms. Corn Rootworm The southern corn rootworm is one of the most troublesome pests in peanut production. The southern corn rootworm is the larvae of the spotted cucumber beetle, but the beetles do not damage peanuts. The larvae feed on roots, pegs, and pods below the ground surface. Often the only signs of a rootworm infestation are the tiny holes they leave in the pods after feeding. Chlorpyrifos is used on 46% of the acres treated for corn rootworm and is the second leading active ingredient used to control this pest. At a cost of $12.09 per acre, chlorpyrifos is 22% lower than the average cost of all other active ingredients. Active Ingredients Corn Rootworm Active Ingredient Corn Rootworm Pest 2008 % 2008 ALDICARB 121,146 52% CHLORPYRIFOS 106,601 46% Total Corn Rootworm a.i. 232,449 Lesser Cornstalk Borer The lesser cornstalk borer also is destructive to peanut production. Penetration of peanut pods by insects enhances risk of infection of pods by A. flavus/parasiticus and aflatoxin contamination. Aflatoxins are highly toxic chemicals produced by certain mold fungi and are harmful or fatal to livestock and considered carcinogenic to animals and humans. Chlorpyrifos is the leading active ingredient for controlling the lesser cornstalk borer in peanuts, particularly in Florida, accounting for 30,334 treatment acres in Active Ingredients Used to Control Lesser Cornstalk Borer Pest Active Ingredient 2008 CHLORPYRIFOS 30,334 PHORATE 20,804 ALDICARB 524 Grand Total 51,662 White Mold White mold is a common and often destructive soil-born disease in Georgia peanut fields and has become more prevalent and more severe. Chlorpyrifos has been widely used to inhibit the growth and development of white mold. Based on results from a study published in to examine the impact of May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 55

56 Peanuts adding Lorsban 15G to reduced fungicide rates, Dr. Tim Brenneman, University of Georgia Extension plant pathologist, noted that, Lorsban 15G is a good multi-purpose tool and good supplement for a white mold control program [1]. Chlorpyrifos Formulations, Rates, and Applications The formulation for chlorpyrifos for controlling insects in peanuts is Lorsban 15G (and other chlorpyrifos granular formulations). Location: AL, GA, FL, SC, NC, VA, TX, OK, MS, LA Pests: lesser cornstalk borer, southern corn rootworm, cutworm, Application Type: post plant Application Method: ground granular applicator Rate: 2.0 lb a.i./a Number of Applications: 1 Season of Application: June August Grower/Researchers In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is a selection of excerpts from a grower organization and a university specialist 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 Chlorpyrifos is the only active ingredient labeled to protect peanut crops from lesser corn stalk borers, southern corn rootworm, burrower bugs, and wireworms. There is great potential to have problems with any or all of these insects in peanut farming regions. With no replacement chemistry available, the loss of chlorpyrifos would eliminate the only option for control of these destructive insects. The potential of economic loss to farmers caused by these insects could virtually eliminate peanut production in many regions. Western Peanut Growers Association Lorsban 15G is a cost-effective option that provides protection against the lesser cornstalk borer and Southern corn rootworm, as well as suppression of white mold. Tim Brenneman, University of Georgia Extension Plant Pathologist References 1. Huber, A. and Bader Rutter and Associates. Revisiting A Product, Lorsban 15G was studied for cost-saving potential with white mold control. The Peanut Grower, June. pg. 19. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 56

57 Pome and Stone Fruit Pome and Stone Fruit Overview U.S. stone fruit production includes cherries, peaches and nectarines, plums and prunes. Pome fruit includes apples and pears. Cherries The U.S. is the world s second largest cherry producing country. Michigan and Washington are the largest cherry producing states; other states include New York, Utah, Wisconsin, Pennsylvania, and Oregon. More than 135,000 acres of cherries are grown in the U.S. Michigan produces approximately 75% of the tart cherry crop, and Washington and Oregon account for about 65% of the sweet cherries produced. US Cherry Production/ by State State Average Washington 42,857 45,222 46,626 48,104 45,702 Michigan 43,843 44,343 44,843 41,095 43,531 California 26,507 27,527 28,546 30,585 28,291 Oregon 15,692 15,692 15,631 16,243 15,815 Grand Total 128, , , , ,339 Total all Active Ingredients by State 2003 State 2003 Average 2003 Washington 184, , , , , ,634 Michigan 184, , , , , ,919 California 83,469 86, ,661 96,432 72,771 87,949 Oregon 78,162 74, ,857 83,961 74,832 83,716 Grand Total 531, , , , , ,218 Insecticide Active Ingredient by State State Active Ingredient % of Total Active Washington 268, % Michigan 145, % Oregon 74, % California 72, % Grand Total 561, % Chlorpyrifos Use Chlorpyrifos is among the top four most used insecticides for controlling insect pests in cherries. In, growers used 79,264 lb a.i. of chlorpyrifos to control insect pests in cherries; 47,630 lb a.i. were applied in Washington state and 16,045 in Michigan. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 57

58 Pome and Stone Fruit Insecticide Active Ingredient All U.S. Cherries 2003 Active Ingredient Active Ingredient 2003 Active Ingredient Active Ingredient Active Ingredient Active Ingredient Average a.i AZINPHOS-METHYL 140, , , ,197 84, ,228 SPINOSAD 29,034 53,675 80, , ,420 77,995 PETROLEUM OIL 59,976 66,665 74,647 62,832 62,559 65,336 CHLORPYRIFOS 39,985 45,162 50,177 62,370 49,587 49,456 ESFENVALERATE 54,437 45,192 48,212 46,844 32,879 45,513 MALATHION 64,669 51,080 39,811 33,964 20,438 41,992 Top Insecticide Active Ingredients/Cherries/All U.S. % of Active Ingredient Total Active Ingredient AI SPINOSAD 113, % AZINPHOS-METHYL 84, % PETROLEUM OIL 62, % CHLORPYRIFOS 49, % Target Pests in Cherries Some of the most troublesome insect pests in cherries are fruit flies, plum curculios and fruit greenworm. Top Pests based on /Cherries/All U.S. Pest All Active Ingredients Cherry Fruit Fly 258,018 Plum Curculio 64,276 Top Pests based on /Cherries/Michigan Target Pests Michigan All Active Ingredients Plum Curculio 64,276 Cherry Fruit Fly 63,842 Green Fruitworm 32,857 Chlorpyrifos and several other insecticides are used to control these most troublesome pests. Other products that provide good control of plum curculio, green fruitworm, and cherry fruit fly in cherries include permethrin, esfenvalerate, indoxacarb, lambda-cyhalothrin, gamma-cyhalothrin, spinosad and imidacloprid. In addition, Michigan cherry growers rely on chlorpyrifos every year for American plum borer and peachtree borer control. In the Michigan Fruit Management Guide for 2009, Lorsban is the only product listed for control of these two pests. Left uncontrolled, these pests could seriously impact cherry production. In Washington, San Jose scale is a target pest in cherries. San Jose scale is most destructive on apple and pear, but it can be a serious pest of sweet cherry, peach, prune and other tree fruits. Chlorpyrifos is the leading active ingredient used in Washington to control San Jose scale. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 58

59 Pome and Stone Fruit Top Pests based on /Cherries/Washington Target Pests Washington All Active Ingredients Cherry Fruit Fly 158,277 San Jose Scale 29,645 Top Active Ingredients based on Active Ingredient /Cherries/Washington Washington Active Leading Active Ingredients Ingredient PETROLEUM OIL 19,746 CHLORPYRIFOS 18,766 Chlorpyrifos Formulations, Rates, and Applications The formulations listed for controlling insect pests in cherries include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 15G (and other chlorpyrifos granular formulations), Lorsban 50W and Lorsban 75WG, and Cobalt. Location: ID, OR, WA Pests: leafrollers, San Jose scale Application Type: air blast Application Method: broadcast Rate: 2.0 lb a.i./a Number of Applications: 1 Season of Application: dormant/delayed dormant Location: CA Pests: San Jose scale Application Type: dormant Application Method: airblast Rate: 2.0 lb a.i./a Number of Applications: 1 per year Season of Application: dormant Location: CA Pests: American plum borer, greater and lesser peach tree borer Application Type: post harvest, avoid contact with foliage Application Method: directed trunk spray Rate: lb a.i./a Number of Applications: 2 3 per year Season of Application: late season Location: MI, PA, NY Pests: American plum borer Application Type: spray Application Method: trunk spray Rate: 0.75 lb a.i./a Number of Applications: one application per season May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 59

60 Pome and Stone Fruit Season of Application: Petal fall application (spring) Alternatives: No chemical or non-chemical alternative Location: MI, PA, NY Pests: peachtree borer Application Type: spray Application Method: trunk spray Rate: 0.75 lb a.i./a Number of Applications: 1 application per season Season of Application: apply Lorsban timed for peach tree borer moth flights (late June in Michigan) Alternatives: no chemical or non-chemical alternative Location: MI, PA, NY Crop: sour cherry Pests: green fruitworm (excellent), cherry fruit fly (good), plum curculio (good) Application Type: spray Application Method: foliar applications Rate: lb a.i./a Number of Applications: 8 application per season Season of Application: dormant through last cover (entire season) Alternatives: no non-chemical alternative Location: MI, PA, NY Product: Lorsban 50W and Lorsban 75WG formulations only Crop: sweet cherry Pests: green fruitworm (excellent), cherry fruit fly (good), plum curculio (good) Application Type: spray Application Method: foliar applications Rate: lb a.i./a ( lb of Lorsban 50W/A or lb of Lorsban 75WG/A) Number of Applications: 1 application per season Season of Application: dormant through last cover (entire season) Chemical Treatments for Insect Control in Cherries 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 Advanced, Lorsban-4E, Yuma 4E, Lorsban 50W and Lorsban 75W All pest complex, reliable broad spectrum to control cherry fruit fly, plum curculio, green fruitworm and other arthropods, effective on borers; only insecticide listed for borer control in Michigan Dormant/delayed dormant sprays for borers 1-2%, air blast, effective on soft-bodied insects (e.g., scale, mite eggs) CHLORPYRIFOS + GAMMA- Cobalt CYHALOTHRIN PETROLEUM/ Superior Spray Oil HORTICULTURAL MINERAL N.W., Omni Supreme OIL Spray PYRIPROXYFEN Esteem, Seize 35W 4-5 oz/a, air blast (Esteem), effective on San Jose scale, dormant/delayed dormant application METHIDATHION Supracide 8 pt/a, air blast, San Jose scale May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 60

61 Pome and Stone Fruit PHOSMET Imidan 70WP Plum curculio and cherry fruit fly - excellent PERMETHRIN Ambush, Pounce Green fruitworm (excellent), cherry fruit fly (flair), plum curculio (good) ESFENVALERATE Asana Green fruitworm (excellent), cherry fruit fly (good), plum curculio (good) INDOXACARB Avaunt Plum curculio (excellent) SPINOSAD Entrust Green fruitworm (excellent) SPINOSAD GF-120 NF Naturalyte Cherry fruit fly (excellent control of adult flies) SPINETORAM Delegate Green fruitworm (excellent), cherry fruit fly (fair), plum curculio (fair) LAMBDA-CYHALOTHRIN Warrior Green fruitworm (excellent), cherry fruit fly (good), plum curculio (good) Non-Chemical Alternatives There are currently no practical non-chemical control alternatives effective for management of the target pests mentioned in cherries. Expert Perspectives Following is a selection of excerpts from a grower organization and university specialist who responded to the EPA s request for input by explaining why they considered chlorpyrifos essential for protecting crops. Submissions to the docket are public information and have been posted by the EPA at docket number EPA-HQ-OPP Tart and sweet cherries are important crops in Michigan. The state grows 75 percent of the nation s tart cherries, and we have 7,500 acres of sweet cherries in production. Although these two cherries are different species, they have an indistinguishable pest complex. Borers feed on tree cambium, and an infested four-to-six-inch limb will become unproductive within two years. A severe borer infestation can result in outright tree mortality, especially in young trees. The primary means for borer control in cherry is chlorpyrifos. Growers use borer insecticide sprays in conjunction with orchard monitoring techniques that utilize pheromone-based traps. [B]ased on chemical trials we can safely say that [chlorpyrifos] is currently the only registered insecticide that provides reliable control of the borer complex. Without chlorpyrifos, the Michigan cherry industry would suffer tremendous losses in production, yield and orchard acreage. Dr. Nikki Rothwell, Northwest Michigan Horticultural Research Station Chlorpyrifos is the best material available to growers to control borers in cherry orchards (American plum borer, lesser peach tree borer and greater peach tree borer). In fact, I would argue that it s the only material that we have available today to successfully control these insects. Borers are a serious problem that can devastate an orchard. Chlorpyrifos is a key material for cherry farmers today and needs to be part of the IPM [Integrated Pest Management] tool box for growers. Chlorpyrifos is an essential tool that provides growers with dependable control of the borer complex that attack cherry orchards. Growers need effective tools that work. Without effective tools, orchards will collapse and die over a very short period of time. Cherry Marketing Institute, Inc. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 61

62 Pome and Stone Fruit Peaches and Nectarines In, nearly 146,000 acres of peaches were grown in the U.S. Three states, California, South Carolina, and Georgia lead the way in peach production, with California producing 57% of peaches in. Nearly all nectarines are produced in California where 35,500 of the total 36,900 acres nationwide are grown. US Peach Production/ by State Top States Average California 91,925 88,461 82,999 83,265 83,265 South Carolina 17,500 16,897 16,897 16,897 16,897 Georgia 12,800 12,267 12,267 12,800 12,800 Grand Total (includes other states) 166, , , , ,930 Chlorpyrifos was the fourth most used active ingredient in controlling pests in peaches nationwide. Leading Active Ingredients/ Peaches All U.S Total Active Ingredients 2003 Average 2003 PHOSMET 212, , , , , ,286 ESFENSVALERATE 99, , , , , ,655 PETROLEUM OIL 103, , , , , ,888 CHLORPYRIFOS 37,190 82,538 54,846 62,615 51,924 57,823 Top Insecticide Active Ingredients/Peaches All U.S Active Ingredients Active Ingredient % of Total ESFENVALERATE 201, % PHOSMET 130, % PETROLEUM OIL 115, % CHLORPYRIFOS 51, % Target Pests in Peaches While oriental fruit moth, stink bug and twig borers are the top target pests in peaches, other insect pests like San Jose scale and lesser twig borer can damage thousands of acres of peaches. Top Pests/ Peaches All U.S. Total Pest All Active Ingredients Oriental Fruit Moth 195,770 Stink Bug 143,302 Twig Borer 132,658 Scale 82,635 Plum Curculio 66,144 San Jose Scale 58,717 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 62

63 Pome and Stone Fruit Peach Tree Borer There are two species of borers that can be harmful to peach trees: the lesser peach tree borer (Sanniniodea exitiosa) and the peach tree borer (Synanthedon pictipes). The peach tree borer attacks healthy bark near the soil line, (just below the ground line or lower 12 inches of the trunk). Peach tree borer injury occurs a few inches above/below the ground. Lesser peach tree borer injury often occurs in peach tree borer wounds but may also occur in any other spot above ground where the larvae can get under dead bark and feed on growing inner bark. The wounds expand rapidly, and limbs or trunks may be girdled. Open wounds permit entry of disease organisms that may also kill live tissue or decay the heartwood. The peach tree borer has long been an important pest; the lesser borer has been important only in the past ten years [1]. Chlorpyrifos is the most used active ingredient for controlling both the lesser peach borer and the peach tree borer. In, chlorpyrifos was used to control peach tree borer and lesser peach tree borer on a total of 22,205 acres. The University of Tennessee Extension names chlorpyrifos as the material of choice for controlling peach tree borers, Peachtree borers attack the trunks every year so protect the lower scaffolds, vase, trunk and exposed roots. Insecticide should be applied at the normal post harvest time (July or so). The preferred application method is to use a handgun applied bark spray. Chlorpyrifos (Lorsban-4E) is the material of choice [2]. San Jose Scale in Peaches San Jose scale causes injury by feeding on twigs, branches, and fruit; they may also inject salivary toxins while feeding. Heavy populations on the bark can cause gumming and kill twigs, branches, and entire trees if left uncontrolled [3]. Chlorpyrifos is the second most-used active ingredient (after petroleum oil) for San Jose scale control in peaches. According to Doane, 68,134 lb a.i. of chlorpyrifos were used nationwide to control insect pests in peaches. In Georgia, chlorpyrifos is one of the most-used active ingredients for controlling insect pests in peaches and representing nearly 20% of all treatment acres in the state. For, CDPR shows 17,405 lb a.i. of chlorpyrifos were used in 644 applications on 9,735 acres of peaches; and 12,879 lb a.i. of chlorpyrifos were used in 490 applications on 7,103 acres of nectarines. According to Doane, 17,224 acres in the West were treated with chlorpyrifos in. Chlorpyrifos Formulations, Rates, and Applications Chlorpyrifos is used in several formulations to effectively control insect pests in peaches and nectarines including Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 50W, Lorsban 75WG, and Cobalt. Location: ID, OR, WA Pests: leafrollers, San Jose scale Application Type: air blast Application Method: broadcast Rate: 2 lb a.i./a Number of Applications: 1 Season of Application: dormant/delayed dormant May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 63

64 Pome and Stone Fruit Location: CA Pests: peach twig borer, San Jose scale, European red mite Application Type: dormant Application Method: airblast Rate: 2 lb a.i./a Number of Applications: 1 Season of Application: dormant (December-January) Location: All peach producing states Pests: peach tree borer Application Type: handgun Application Method: trunk spray Rate: lb a.i./a Number of Applications: 1 Season of Application: timed for emergence of peachtree borers Alternatives: none in Northeast Chemical Treatments for Insect Control in Peaches Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Brand Names Benefits, Application, Use, and Active Ingredient CHLORPYRIFOS CHLORPYRIFOS + GAMMA CYHALOTHRIN PETROLEUM AND HORTICULTURAL MINERAL OIL Lorsban Advanced, Lorsban-4E, Lorsban 50W, Lorsban 75WG, Yuma 4E Cobalt Superior Spray Oil N.W., Omni Supreme Spray Efficacy Very effective in controlling scale and borers; no other alternatives for peach tree borer control in Northeast Trunk spray or preplant dip for peach tree borer control and as dormant/delayed dormant sprays 1-2 %, air blast, effective on softbodied insects (e.g., scale, mite eggs) PYRIPROXYFEN Esteem; Seize 4-5 oz/a, air blast, effective San Jose scale ESFENVALERATE Asana Dormant for peach twig borer METHIDATHION Supracide 8 pt/a, air blast; San Jose scale Non-Chemical Alternatives There are currently no practical non-chemical control alternatives effective for management of the target pests mentioned in peaches. Expert Perspectives Following is a selection of excerpts from university specialists who responded to the EPA s request for input by explaining why they considered chlorpyrifos essential for protecting crops. Submissions to the docket are public information and have been posted by the EPA at docket number EPA-HQ-OPP Chlorpyrifos is an absolutely key material for southeastern peach growers. Policy-driven incentives to either eliminate or restrict its use in peaches would further degrade grower options for successfully managing lesser peachtree borer. It would almost certainly further increase pyrethroid use. Any restrictions on the availability of chlorpyrifos to southeastern peach growers would be ill advised. Dan Horton, Professor of Entomology, University of Georgia; and Ted Cottrell, research scientist, U.S. Department of Agriculture May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 64

65 Pome and Stone Fruit Peachtree borer has historically been regarded as the southeastern U.S. s key borer species, as uncontrolled peachtree borer infestations will debilitate and kill trees more rapidly than the lesser peachtree borer. Control of peachtree borer in southeastern peach production has been, and remains, almost entirely dependent on post-harvest application of chlorpyrifos. Pheromone mating disruption, or substitution of either endosulfan or pyrethroids are dramatically inferior to the current use of chlorpyrifos. Dan L. Horton, University of Georgia, Entomology Plums and Prunes California, the dominant producer of plums, produces more dried plums/prunes than the rest of the world combined. Four other states also grow plums commercially: Idaho, Michigan, Oregon, and Washington. According to Doane, a total of 131,204 acres of plums were grown in California in. California plum growers spent more than $5 million on insecticides to control insect pests in plums. Chlorpyrifos was the third most used active ingredient for controlling insect pests in California plums, representing 20,044 active ingredient acres. Doane reports a total of 39,076 lb a.i. of chlorpyrifos were used to control insect pests in plums and prunes in. Insecticide Active Ingredient /Plums/Prunes All U.S Active Ingredient Active Ingredient 2003 Active Ingredient Active Ingredient Active Ingredient Active Ingredient Average a.i PETROLEUM OIL 95,457 97,022 95, ,006 87,216 96,853 ESFENVALERATE 71,410 56,219 68,137 84,392 85,732 73,178 DIAZINON 27,540 26,827 32,073 27,538 18,222 26,440 CHLORPYRIFOS 17,636 19,873 17,880 17,320 20,044 18,551 PHOSMET 15,434 18,172 12,280 11,527 11,404 13,763 Top Active Ingredients Active Ingredient Active Ingredient Leading Active Ingredients California Plums PETROLEUM OIL 87,215 ESFENVALERATE 85,731 CHLORPYRIFOS 20,044 According to the CDPR, in 15,029 lb a.i. of chlorpyrifos were used in 423 applications on 8,269 plum/prune acres to control pests. Chlorpyrifos Use in California Plums and Prunes 2003 Year Chlorpyrifos Lbs a.i. Total Active Ingredient Used ,803 13,389 20,014 10,596 20,065 10,679 18,220 9,667 15,029 Source: California Department of Pesticide Regulation ,269 Target Pests in Plums and Prunes The most troublesome insect pests in California plums include twig borers, aphids, scale and San Jose scale and mites. Chlorpyrifos is used primarily to control twig borers, scale, and San Jose scale in May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 65

66 Pome and Stone Fruit California plums. San Jose scale is one of the most destructive pests of stone fruits in the U.S. San Jose scale can infest branches, shoots, leaves, and fruit. Adults and nymphs suck plant juices and cause considerable damage. They have been known to seriously weaken branches and main scaffold limbs, causing permanent injury to mature trees. Crawlers settling on fruit may cause fruit spotting [4]. Leading Insect Pests in Plums/Pest Pest -All Top Target Pests-Plums Active Ingredients Twig Borer 92,121 Aphid 52,802 Scale 48,742 San Jose scale 46,698 Mites 44,971 Chlorpyrifos is among the three most used active ingredients on these target pests in California plums. In a good percentage of the applied acres, chlorpyrifos is applied mixed with oil, another of the three most used active ingredients. Most Used Active Ingredients to Control Scale and San Jose Scale in Plums Leading Active Ingredients a.i. for Scale Leading Active Ingredients a.i. for San Jose Scale PETROLEUM OIL 20,655 PETROLEUM OIL 30,428 ESFENVALERATE 11,542 CHLORPYRIFOS 9,772 CHLORPYRIFOS 6,981 ESFENVALERATE 3,464 Most Used Active Ingredients to Control Twig Borer in Plums a.i. for Twig Leading Active Ingredients Borer ESFENVALERATE 49,582 PETROLEUM OIL 17,997 CHLORPYRIFOS 7,435 Chlorpyrifos Formulations, Rates, and Applications Formulations listed for controlling insect pests in plums include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), and Cobalt. Location: ID, OR, WA Pests: San Jose scale Application Type: air blast Application Method: broadcast Rate: 2 lb a.i./a Number and season of Applications: 1, dormant/delayed dormant Location: CA Pests: peach twig borer, San Jose scale, European red mite Application Type: dormant Application Method: airblast Rate: 2 lb a.i./a Number of Applications: 1 Season of Application: dormant (December-January) May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 66

67 Pome and Stone Fruit Chemical Treatments for Insect Control in Plums and Prunes 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 & Efficacy CHLORPYRIFOS Lorsban Advanced, Lorsban-4E, Nufos 4E Dormant/delayed dormant; broad spectrum provides effective control of San Jose scale, borers and European red mites Dormant/delayed dormant for effective control of borer 1 2 %, air blast, effective on soft-bodied insects (e.g., scale, mite eggs) CHLORPYRIFOS + GAMMA- Cobalt CYLHALOTHRIN PETROLEUM AND Superior Spray Oil N.W., HORTICULTURAL MINERAL Omni Supreme Spray OIL PYRIPROXYFEN Esteem 4 5 oz/a, air blast; effective San Jose scale METHIDATHION Supracide 8 pt/a, air blast; for San Jose scale Non-Chemical Alternatives There are currently no practical non-chemical control alternatives effective for management of the target pests mentioned in peaches. Apples The U.S. is the world's second-largest producer of apples, behind China. Apples are grown commercially in 36 states; however, the top six apple-producing states are Washington, New York, Michigan, Pennsylvania, California, and Virginia. Apples are the number one cash crop in the state of Washington according to the Washington State Department of Agriculture. U.S. apple production trails only oranges and grapes in the amount of U.S. acreage committed to fruit production. Approximately one out of every four apples harvested in the U.S. is exported. Almost 63% of the apples grown in the U.S. are sold as fresh fruit, the rest of the apples are processed into apple products. The majority of the processing apples went to apple juice production, followed by canned, frozen and dried apple products [5]. U.S. Apple Production by Region % of Total Average Region State 2003 West Washington 166, % 171,384 California 31, % 34,335 Oregon 5, % 6,729 Atlantic New York 54, % 58,012 Pennsylvania 30, % 31,307 Virginia 15, % 19,269 North Carolina 8, % 8,318 West Virginia 6, % 7,323 Midwest Michigan 40, % 46,699 Ohio 7, % 8,436 Grand Total 366, % 391,812 Chlorpyrifos Use in Apples Chlorpyrifos is one of the leading active ingredients used to control insect pests in apples. In, growers nationwide used 395,207 lb a.i. of chlorpyrifos to protect orchards from insect pests. Active ingredient acres treated with chlorpyrifos totaled 266,822 in, representing more than 9% of total active ingredient acres. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 67

68 Pome and Stone Fruit Insecticide Active Ingredient /Apples All U.S Active Ingredient Active Ingredient 2003 Active Ingredient Active Ingredient Active Ingredient Active Ingredient Average a.i AZINPHOS-METHYL 1,180, , , , , ,955 PHOSMET 523, , , , , ,021 PETROLEUM OIL 356, , , , , ,429 CHLORPYRIFOS 300, , , , , ,380 METHOXYFENOZIDE 106, , , , , ,447 ACETAMIPRID 127, , , , , ,955 Top Insecticide Active Ingredients/Apples All U.S. Active Leading Active Ingredients Ingredient % of Total a.i. AZINPHOS-METHYL 583, % PHOSMET 326, % PETROLEUM OIL 304, % CHLORPYRIFOS 266, % According to the CDPR, in 6,508 lb a.i. of chlorpyrifos were used in 222 applications for insect control on 3,464 acres of apples. Target Pests in Apples The codling moth is by far the number one insect pest in apples, with more than 1.4 million active ingredient acres treated to control codling moth. Other damaging insect pests include oriental fruit moth, leafrollers, aphids, mites, maggots and plum curculio. Top Insect Pests in Apples/ All a.i. Insect Pest Codling Moth 1,423,150 Oriental Fruit Moth 386,492 Leafroller 332,036 Aphid 256,197 Apple Aphid 189,796 Mite 174,226 Rosy Apple Aphid 162,019 Apple Maggot 161,874 Plum Curculio 150,983 Leafrollers Leafrollers (oblique-banded, red-banded, fruit tree leafroller, Pandemis) are among the most important pests of apples in the northeastern part of the U.S. These pests, in their larval stages, can damage fruit from April through early August. Nationwide, chlorpyrifos was the second most-used active ingredient in controlling leafrollers in apples in. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 68

69 Pome and Stone Fruit Leading Active Ingredients to Control Leafrollers in Apples All U.S. Pest Pest Active Ingredient for Leafrollers Leading Active Ingredients SPINOSAD and SPINETORAM 51,907 CHLORPYRIFOS 48,697 METHOXYFENOZIDE 42,309 PETROLEUM OIL 37,519 San Jose Scale San Jose scale is an extremely important indirect pest of apples, pears, peaches, and plums. Discoloration on the fruit is caused by toxin injected from this sucking insect as it feeds. Left uncontrolled, San Jose scale can kill the entire tree in a couple of years. Often this very small insect goes unnoticed until large populations have developed. San Jose scale overwinter as immature scales. In the spring, the tiny winged males emerge and mate with the wingless females [6]. Aphids Aphids can cause terminal leaves to curl downward and may become sticky with honeydew secreted by the aphids. This honeydew may drip onto the fruit causing russet spots and promote growth of black sooty mold. Highly infested shoots of young trees can be stunted or malformed. Chlorpyrifos is the leading active ingredient used to control aphids in Washington apples. Leading Active Ingredients to Control Aphids in Apples/Washington Pest Active Ingredient In Washington Leading Active Ingredients Aphids CHLORPYRIFOS 35,771 PETROLEUM OIL 26,272 Chlorpyrifos is the preferred product in the Pacific Northwest for use as a dormant or delayed dormant treatment to control overwintering generations of a number of insect pests including oblique-banded and red-banded leafrollers, Pandemis leafrollers and San Jose scale. Chlorpyrifos is typically used in combination with a 1 2% solution of oil. This combination continues to provide effective control of overwinter leafroller larvae long after the applications are made by imparting some level of mortality inside the hibernacula (overwintering shelter) either by actual penetration or volatile action. Chlorpyrifos used with the oil solution also provides control of San Jose scale populations and early colonies of rosy apple aphid. Control of these pests during the dormant/delayed dormant timing is critical toward the overall in-season management of these pests. Chlorpyrifos Formulations, Rates, and Applications The formulations listed for treating apple include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban Advanced, Lorsban 50W, and Cobalt. Location: Pacific Northwest Pests: leafroller, San Jose scale, rosy apple aphid Application Type: air blast Application Method: broadcast Rate: 2.0 lb a.i./a (Lorsban-4E) and 1.9 lb a.i./a (Lorsban Advanced) Number of Applications: 1 Season of Application: dormant/delayed dormant May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 69

70 Pome and Stone Fruit Location: Northeast and Midwest (MI, OH, NY, PA, VA, MD, MA, VT, ME, WI, NC) Pests: San Jose Scale, rosy apple aphid Application Type: foliar Application Method: airblast sprayer Rate: lb a.i./a (2 4 pt/a) Number of Applications: 1 Season of Application: dormant or delayed dormant application (green tip to early tight cluster) Alternative: no non-chemical alternatives are available to treat the over-wintering insects Chemical Treatments for Insect Control in Apples Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts and other contributors to this report. Brand Names IRAC Mode Benefits, Application, Use and Efficacy of Action Active Ingredient CHLORPYRIFOS CHLORPYRIFOS + GAMMA-CYHALOTHRIN PETROLEUM AND HORTICULTURAL MINERAL OIL Lorsban-4E, Nufos 4E, Hatchet, Lorsban Advanced, Lorsban 50W Group 1B Highly effective in combination with dormant oil as delayed dormant spray for control of scale insects and overwintering leafrollers Cobalt 1B + 3A Highly effective in combination with dormant oil as delayed dormant spray for control of scale insects Damoil, Superior Spray Oil N.W., Omni Supreme Spray 1 2% v/v, air blast; effective on softbodied insects (e.g., scale, mite eggs) PYRIPROXYFEN Esteem 7C 4 5 oz/a, air blast, effective San Jose scale, rosy apple aphid 5 oz/a dormant and summer application (good) BUPROFEZIN Centaur 70WSB 16 San Jose scale, 34.5 oz/a summer application (good) ACETAMIPRID Assail 30 SG 4A Rosy apple aphid, 2.5 oz/a, pre-bloom and summer application (excellent) THIACLOPRID Calypso 480SC 4A Rosy apple aphid, 204 oz/a, pre-bloom and summer application (excellent) METHIDATHION Supracide 1B 8 pt/a, air blast, San Jose scale SPINETORAM Delegate 5 Post-bloom application; highly effective on oblique-banded leafrollers and pandemis leafrollers; SPINOSAD Entrust 5 Post-bloom application; effective on oblique-banded leafrollers and pandemis leafrollers CHLORANTRANILIPROLE Altacor 28 Post-bloom application; labeled for oblique-banded leafroller only EMANECTIN BENZOATE Proclaim 6 Post-bloom application; effective against oblique-banded leafroller and pandemis leafrollers; METHOXYFENOZIDE Intrepid 2F 18 Post-bloom application; effective against oblique-banded leafroller and pandemis leafrollers FLUBENDIAMIDE Belt 28 Post-bloom application; effective against oblique-banded leafroller and pandemis leafrollers May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 70

71 Pome and Stone Fruit AZINPHOS-METHYL Guthion 1B Post-bloom application; resistance concerns and worker safety limit use. azinphos-methyl applications preferred for codling moth PYRETHROIDS 3A Post-bloom application; effective but not recommended due to disruptive mortality of predatory mites in orchard system; use not sanctioned by official spray guides Bt - Bacillus thuringiensis 11 Must make two applications around bloom period to be effective; primarily utilized as bloom spray Non-Chemical Alternatives Pheromone disruption - Under development for oblique-banded leafrollers in Pacific Northwest. No commercial successes have yet been achieved. Mating disruption for codling moth management in apples has been the focus of the majority of research efforts and funding. Commercial success of codling moth disruption is serving as enabling technology for leafroller mating disruption. Approximately 60 70% of bearing apple acreage in the Pacific Northwest is under a mating disruption program for codling moth. Granulosis virus Codling moth virus products (e.g., Cyd-X) have been used with some success in organic systems. The use of the virus requires a long-term management approach as effective control of codling moth is usually not achieved in one season. Entomophagous nematodes Parasitic nematodes have been evaluated both academically and commercially for control of lepidoptera pests of apples, especially codling moth and leafrollers. No consistent commercially acceptable control has been achieved by this means. In addition, commercially developed products based on entomophagous nematodes have been difficult to apply, have had poor shelf life and have had a very high cost structure relative to standard insecticides. Grower Perspective Following is an excerpt from a grower organization that responded to the EPA s request for input by explaining why they considered chlorpyrifos essential for protecting crops. Submissions to the docket are public information and have been posted by the EPA at docket number EPA- HQ-OPP Chlorpyrifos is one of the most versatile pesticides and is used to control borers, Oriental fruit moth, red-banded leafroller, plant bugs, obliquebanded leafroller, tufted apple bud moth, green fruitworm, plum curculio, green apple aphid, rosy apple aphid, woolly apple aphid, San Jose scale and European apple sawfly. Chlorpyrifos is considered an excellent choice to control these pests because it effectively controls many target pests simultaneously and it is economical. While pyrethroids represent a possible alternative for some pests, they are so disruptive to Integrated Pest Management (IPM) they are not considered a viable alternative. James Cranney, Jr., U.S. Apple Association Pears Washington grows nearly half of the nation s total pear production. Total U.S. production in was 880,950 tons, valued at $346 million. Pears are the leading tree fruit crop in Oregon and the second largest fruit crop in Washington. Approximately 35% of U.S. pears are exported. About 60% of the U.S. pear crop is sold as fresh. The rest is processed, primarily in the form of canned product [7]. Approximately 5,000 acres of pears are planted in the Northeast apple growing region (Wisconsin through New York and down to North Carolina). May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 71

72 Pome and Stone Fruit U.S. Pear Production State % of Total Washington 29, % Oregon 19, % California 18, % In, 37,384 lb a.i. of chlorpyrifos were used to control insect pests in pears. While not the primary active ingredient, chlorpyrifos is used in some cases to control leafrollers (oblique-banded, Pandemis) and San Jose scale. Pear psylla is the main insect pest of pears and most applications start at cluster bud stage, which is beyond the dormant/delayed dormant timing allowed for chlorpyrifos. Chlorpyrifos is used primarily for San Jose scale control in pears in the Northeast region as a delayed dormant application. Chlorpyrifos Formulations, Rates, and Applications Formulations listed for treating pear include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban Advanced, and Cobalt. Location: OR, WA Pests: San Jose scale Application Type: air blast Application Method: broadcast Rate: 2.0 lb a.i./a Number of Applications: 1 Season of Application: dormant/delayed dormant Location: CA Pests: San Jose scale, European red mite Application Type: foliar Application Method: airblast Rate: 2.0 lb a.i./a Number of Applications: 1 Season of Application: dormant Location: Northeast and Midwest (MI, OH, NY, PA, VA, MD, MA, VT, ME, WI, NC) Pests: San Jose scale, Application Type: foliar Application Method: Airblast sprayer Rate: lb a.i./a (2 4 pt/a) Number of Applications: 1 Season of Application: dormant or delayed dormant application (green tip to early tight cluster) Alternative: no non-chemical alternatives are available to treat the over-wintering insects May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 72

73 Pome and Stone Fruit Chemical Treatments for Insect Control in Pears Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Brand Names IRAC Mode of Benefits, Application, Use, and Efficacy Active Ingredient CHLORPYRIFOS CHLORPYRIFOS + GAMMA-CYHALOTHRIN PETROLEUM AND HORTICULTURAL MINERAL OIL Lorsban-4E, Yuma, Nufos 4E, Lorsban Advanced Action Group 1B Highly effective in combination with dormant oil as delayed dormant spray for control of scale insects and overwintering leafrollers; only major use in pears Cobalt 1B + 3A Highly effective in combination with dormant oil as delayed dormant spray for control of scale insects Superior Spray Oil N.W., Omni Supreme Spray 1-2 %, air blast, effective on soft-bodied insects (e.g., scale, mite eggs) PYRIPROXYFEN Esteem, Seize 7C 4-5 oz/a, air blast; effective San Jose scale, dormant METHIDATHION Supracide 1B 8 pt/a, air blast; San Jose scale SPINETORAM Delegate 5 Post-bloom application; highly effective on oblique-banded leafrollers and pandemis leafrollers SPINOSAD Entrust 5 Post-bloom application; effective on oblique-banded leafrollers and pandemis leafrollers CHLORANTRANILIPROLE Altacor 28 Post-bloom application; labeled for oblique-banded leafroller only EMAMECTIN BENZOATE Proclaim 6 Post-bloom application; effective against oblique-banded leafroller and pandemis leafrollers METHOXYFENOZIDE Intrepid 2F 18 Post-bloom application; effective against oblique-banded leafroller and pandemis leafrollers FLUBENDIAMIDE Belt Post-bloom application; effective against oblique-banded leafroller and pandemis leafrollers AZINPHOS-METHYL Guthion 1B Post-bloom application; resistance concerns and worker safety limit use. Prefer to save azinphos-methyl applications for codling moth PYRETHROIDS 3A Post-bloom application; effective but not recommended due to disruptive mortality of predatory mites in orchard system; use not sanctioned by official spray guides Bt Bacillus thuringiensis Must make two applications around bloom period to be effective; primarily utilized as bloom spray Non-Chemical Alternatives Granulosis virus Codling moth virus products (e.g., Cyd-X) have been used with some success in organic systems. The use of this virus requires a long-term management approach as effective control of codling moth is usually not achieved in one season. Entomophagous nematodes Parasitic nematodes have been evaluated both academically and commercially for control of lepidoptera pests of pears, especially codling moth and leafrollers. No consistent commercially acceptable control has been achieved by this means. In addition, commercially developed products based on entomophagous nematodes have been difficult to apply, have had poor shelf life and have had a very high cost structure relative to standard insecticides. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 73

74 Pome and Stone Fruit References 1. University of Illinois Extension, Integrated Pest Management, Peach Tree Borers. Accessed April 10, Bost, S. and Hale, F. University of Tennessee Extension. Fruit Pest News. Volume 8, No. 5. April 10,. Accessed March 18, University of California, UC IPM Online. How to Manage Pests, Peach/San Jose Scale. March. Accessed April 10, University of California, UC IPM Online. How to Manage Pests, Plum/San Jose Scale. March. Accessed April 10, U.S. Apple Association. and Accessed February 5, Bessin, R. University of Kentucky Entomology. San Jose Scale. January Accessed February 5, Geisler, M. Agricultural Marketing Resource Center. Pears. May products/fruits/pears.cfm. Accessed February 5, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 74

75 Soybeans Soybeans Overview Processed soybeans are the largest source of protein feed and vegetable oil in the world. The U.S. is the world's leading soybean producer and exporter. Soybeans equal about 90% of U.S. total oilseed production, while other oilseeds such as cottonseed, sunflower seed, and peanuts account for the remainder [1]. Over the past five years ( to 2008), on average, more than 72 million acres of soybeans have been grown annually in the U.S., with more than 74 million acres planted in three of the five years, including U.S. Soybean Production 2008 Region 2008 Average 2008 Midwest 46,350,030 45,199,992 46,450,072 39,749,991 44,549,941 44,460,005 Plains 15,919,989 15,599,995 16,060,010 13,150,017 15,960,003 15,338,003 Atlantic 5,823,999 5,879,999 5,759,990 5,394,987 6,224,998 5,816,795 South 6,714,988 6,289,999 6,540,001 5,680,008 7,670,007 6,579,001 Grand Total 74,809,006 72,969,985 74,810,073 63,975,003 74,404,949 72,193,803 Chlorpyrifos Use The total number of active ingredient acres has grown from nearly 2.7 million acres in to nearly 40.8 million acres in One of the main reasons for this steady increase in number of treated acres is the presence of the soybean aphid in the Midwest and Great and North Plains, the largest soybean producing area in the U.S. All Active Ingredients Total Soybean 2008 a.i. a.i. a.i. a.i. a.i Average a.i ,690,566 7,824,567 13,563,485 18,305,803 40,768,699 16,630,624 Chlorpyrifos is one of the three most widely used insecticides to control pests in soybeans due to its broad spectrum, fast knockdown of key pests and price. The three leading active ingredients include thiamethoxam (a second-generation neonicotinoid seed treatment insecticide), lambda-cyhalothrin (a synthetic pyrethroid), and chlorpyrifos. Leading Active Ingredients/ 2008 Insecticide 2008 Average 2008 THIAMETHOXAM 5,366,800 6,246,049 12,028,157 7,880,335 LAMBDA- CYHALOTHRIN 987,599 3,090,793 3,196,278 4,263,471 10,619,366 4,431,501 CHLORPYRIFOS 207,609 2,200,323 2,210,358 4,159,205 7,999,561 3,351,441 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 75

76 Soybeans U.S. Soybean with Chlorpyrifos The number of acres treated with chlorpyrifos has grown from 207,609 acres in, representing 0.3% of planted acres and 7.7% of treated acres, to 7,999,561 planted acres in 2008, which represents 10.8% (36X compared to ) of planted acres and 19.6% (2.5X compared to ) of treated acres. In, 1,827,485 lb a.i. of chlorpyrifos were used to treat insect pests in soybeans. For 2008, the amount nearly doubled, totaling 3,167,938 lb a.i. of chlorpyrifos used on soybeans. Leading Active Ingredients/Percent of 2008 Ingredient % % % % % 2008 Average % 2008 THIAMETHOXAM 0.0% 0.0% 39.6% 34.1% 29.5% 28.43% CYHALOTHRIN- LAMBDA 36.7% 39.5% 23.6% 23.3% 26.0% 26.65% CHLORPYRIFOS 7.7% 28.1% 16.3% 22.7% 19.6% 20.18% Midwest and Plains Region The Midwest (Iowa, Illinois, Minnesota, Indiana, Missouri, Ohio, Michigan, and Wisconsin) and Plains (Nebraska, South Dakota, North Dakota, Kansas, Oklahoma, and Texas) states represent approximately 80% of total soybean acres grown in the U.S. Of the 74.4 million soybean acres grown in 2008 across the U.S., 60.5 million of those acres were grown in the Midwest and Plains region. Five Midwest states, including Iowa (with the most soybean acres), Illinois, Minnesota, Indiana, and Missouri account for 49% of 2008 planted acres. Chlorpyrifos is the second most widely used insecticide in the Midwest and Plains region for soybeans. In 2008, chlorpyrifos was used to treat 7.8 million acres in the region, which represents 24.4% of total acres treated in the Midwest and Plains states. Use of chlorpyrifos has grown more in this region than the national average. Chlorpyrifos use is surpassed only by thiamethoxam, which was used on 29.8% of acres (9.6 million acres) in the Midwest and Plains states. Target Pests Soybeans typically harbor an incredible diversity of insects that feed on the plants from the time they start to crack the soil until the last leaf has dropped in the late summer. And somewhere between these two extremes, insect and spider mite populations occasionally build up to economically damaging populations. When this happens, often the most effective pest management tactic for most growers and crop managers is to apply a foliar insecticide to reduce the population [2]. Chlorpyrifos has a broad spectrum and is effective in treating a number of insect pests in soybeans, including soybean aphid, bean leaf beetle, caterpillars, grasshoppers, leafhopper, two-spotted mites, and others. Other primary insecticide products used in the market have a narrower pest spectrum compared to chlorpyrifos broad pest spectrum. Soybean Aphid For soybeans, the number one pest in the Midwest and Plains is the soybean aphid. Soybean aphids feeding on soybean crops can result in a reduction in photosynthetic capacity as well as cause leaf curling and stunted plant growth. Infestations of soybean aphid spread rapidly since it was first detected in Wisconsin in By 2002, soybean aphid presence was reported in 20 states across the Plains and into the Northeast and South. Since 2000, heavy infestations of the soybean aphid have caused economic yield losses up to 45% in some untreated fields [3]. Chlorpyrifos has been used in the U.S. since 2000 to control soybean aphid [4]. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 76

77 Soybeans Of the 38.9 million total acres treated with insecticides in 2008, 51.9% (20,192,575 acres) of acres were treated to control aphids. Top Pests in Soybeans/2008 Pest Top U.S. Soybean Pests all Active Ingredients 2008 % Total Soybean Aphid 20,192, % Bean Leaf Beetle 3,822, % Total with Insecticides 38,923,951 While a total of 26 insecticide active ingredients were reported used on soybeans, only 16 were used to treat soybean aphids. Three of these, chlorpyrifos, lambda-cyhalothrin and thiamethoxam, accounted for 82% of the U.S. acres treated for soybean aphid. Soybean aphid is a targeted pest in 52% of all U.S. soybean insecticide applications and a targeted pest in 64% of the Midwest and Plains region applications. In the Midwest and Plains region, chlorpyrifos is the leading active ingredient for controlling soybean aphids due to its fast knockdown and control of other pests present in the field at the time of application, such as bean leaf beetles. Pest in Midwest and Plains for Soybean Aphid and Bean Leaf Beetle % Top Pests - Midwest and Plains treated for Soybean Aphid 19,419, % treated for Bean Leaf Beetle 4,026, % Total in ,412,163 Bean Leaf Beetle In 2008, the next most-treated insect pests in soybeans were the bean leaf beetles. Of total treated acres in 2008, 9.8% of acres (3.8 million acres) were treated for bean leaf beetle. The bean leaf beetle is also one of the most widespread soybean pests in the U.S. The resulting damage from these pests is loss of seed weight and quality. These beetles can also cause breakage and complete pod loss. Grain value is discounted when 2% damaged seed is exceeded. Chlorpyrifos is the third most widely used pesticide for bean leaf beetles. af Beetle Damage Cost of Treatment Chlorpyrifos is less costly compared to alternatives based on Doane data. Although chlorpyrifos accounted for 20% of treated acres, it represented only 14% of all insecticide expenditures in The national average cost of chlorpyrifos was $4.03 per acre in 2008, which was 31% less than the average cost of all alternatives ($5.84 per acre). The Midwest and Plains region accounts for 78% of treated acres and 80% of expenditures for insecticides. In this region, the cost of chlorpyrifos was $4.01 in 2008, which was 34% less than the average cost of all alternatives ($6.06 per acre). Based on cost estimates of alternatives, growers in this region would have spent approximately $16.1 million more in 2008 had chlorpyrifos not been available for use on soybeans. This does not take into May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 77

78 Soybeans account that some of the alternative products would control only one of the main pests present at the time of application. The cost of using chlorpyrifos to control soybean aphids is 21% less than the average of all options, (based on chlorpyrifos cost per acre for soybean aphid of $3.97 and $5.00 average cost per acre for all other alternatives in treating soybean aphids). The cost to control bean leaf beetle with chlorpyrifos is 45% less than the average price of all options. Chlorpyrifos Formulations, Rates, and Applications Current chlorpyrifos formulations listed for treating soybeans include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 15G (and other chlorpyrifos granular formulations), and Cobalt. For foliar application, chlorpyrifos is most commonly applied as a broadcast spray using aerial or ground equipment. Location: IA, IL, IN, OH, MN, WI, SD, MO, NE Pests: soybean aphid, bean leaf beetle, spider mite Application Type: foliar Application Method: broadcast aerial or ground Rate: lb a.i./a Number of Applications: 1 Season of Application: July/August Location: LA Pests: stink bug, bean leaf beetle Application Type: foliar Application Method: broadcast aerial and ground Rate: lb a.i./a Number of Applications: 1 3 Season of Application: May August Chemical Treatments for Insect Control in Soybeans 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 (organophosphate) CHLORPYRIFOS + GAMMA-CYHALOTHRIN (Organophosphate + pyrethroid) THIAMETHOXAM (neonicotinoid) LAMBDA-CYHALOTHRIN (pyrethroid) Lorsban-4E, Cobalt, Lorsban Advanced, Nufos, Chlorpyrifos 4E AG, DuraGuard ME, Saurus, Whirlwind, Govern, Warhawk Cobalt Cruiser Warrior, Warrior II, Karate, Lambda-T., Silencer, Helena Easy to use, fast knockdown; Controls multiple pest species with a single application. Easy to use. Good knock down, costeffective product, controls multiple pest species with a single application. In general, this product will be effective against pyrethroid resistant populations of insects. Applied prior to seed bagging, easy to use: effective for a few weeks following planting; soybean aphids don t show up until several weeks after planting; controls sap-feeding insects. Easy to use; slow knockdown but good residual; less effective stand-alone alternative when pyrethroid-resistant May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 78

79 Soybeans ESFENVALERATE (pyrethroid) ZETA-CYPERMETHRIN (pyrethroid) CYFLUTHRIN (pyrethroid) GAMMA-CYHALOTHRIN (pyrethroid) ACEPHATE (organophosphate) IMIDACLOPRID (systemic, chloro-nicotinyl) Asana Hero, Mustang Max, Mustang Baythroid, Defcon Proaxis Acephate 90SP Gaucho, Admire insects are present Easy to use, limited efficacy; less effective stand-alone alternative when pyrethroidresistant insects are present Easy to use, slow knockdown, good control; less effective stand-alone alternative when pyrethroid-resistant insects are present Easy to use, limited efficacy; less effective stand-alone alternative when pyrethroidresistant insects are present Easy to use, slow knockdown, good control; less effective stand-alone alternative when pyrethroid-resistant insects are present Higher rate than most, less control Seed treatment easy to use. Does not provide adequate soybean aphid control BIFENTHRIN (pyrethroid) PERMETHRIN (pyrethroid) THIAMETHOXAM + LAMBDA-CYHALOTHRIN (Neonicotinoid + pyrethroid) METHYL PARATHION (organophosphate) Capture, Hero Pounce Endigo Easy to use, slow knockdown, good control; less effective stand-alone alternative when pyrethroid-resistant insects are present Easy to use, slow knockdown, limited efficacy; less effective stand-alone alternative when pyrethroid-resistant insects are present. Easy to use and overall good control Methyl parathion Difficult to handle; control lasts just 24 hours Non-Chemical Alternatives A trait (RAG1) that has limited efficacy against soybean aphid in soybean is being introduced this season, but it is not expected to handle large infestations. Some speculate that aphids will develop resistance to it rather quickly. No other non-chemical alternatives exists for soybean pests. Grower Perspective In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is an excerpt from a state grower organization that 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 Chlorpyrifos is an extremely important insecticide for soybean production in Minnesota, as well as most of the upper Midwest. Chlorpyrifos effectively controls two very significant pests in soybean production spider mites and soybean aphids. Infestations of spider mites can be sporadic [and when they] do occur, yield reductions of greater than 50% can result. Based on University of Minnesota research, chlorpyrifos is the product of choice for controlling spider mites in soybeans. Chlorpyrifos is one of only two types of products that have proven to provide effective control of soybean aphids. The other products are synthetic pyrethroids and their use has sometimes resulted in the need to make supplemental applications of chlorpyrifos to control spider mites. Minnesota Soybean Growers Association May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 79

80 Soybeans References 1. United States Department of Agriculture, Economic Research Service. Soybeans and Oil Crops. December Accessed February 20, Rice, E., O Neal, M. Integrated Crop Management, University of Iowa Extension. Soybean Insecticides for. March 27,. Accessed February 20, Gianessi, L. CropLife Foundation. The Benefits of Insecticide Use: Soybeans. March Accessed April 10, Hendrix, W. and Ferguson, S. Lorsban-4E Insecticide Offers Excellent Control of Soybean Aphids. March g/ pdf&frompage=getdoc. Accessed February 2, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 80

81 Sugar Beets Sugar Beets Overview In 2008, sugar beets were grown on more than 1 million acres in the U.S. The Midwest states of Minnesota and Michigan account for more than 52% of the U.S. sugar beet crop. North Dakota is the second largest sugar beet producing state with 206,000 acres planted, followed by Idaho with nearly 131,000 acres. Sucrose from sugar beets is the principal use for sugar beets in the U.S. Sugar beets have gained a greater share of U.S. sugar production over the past decade, now accounting for 58.8% of the nation s sugar output, while sugarcane fell to 41.2% [1]. Sugar beet byproducts include beet pulp, sold for animal feed and molasses. The sugar beet industry is also looking to new technology for use of sugar beets for ethanol production. U.S. Sugar Beet Production 2008 Region State 2008 % of Total U.S. Midwest Minnesota 425, % Michigan 137, % West Idaho 130, % Colorado 34, % Montana 31, % California 31, % Wyoming 28, % Plains North Dakota 205, % Nebraska 45, % Grand Total 1,071, % Chlorpyrifos Use In each of the past three years, chlorpyrifos was the most often used active ingredient for insect pest control in sugar beets. Chlorpyrifos as a percent of all active ingredient acres has grown from 15% in to 21% in. Four states, Minnesota, California, Idaho, and North Dakota account for 87% of treatment acres. Michigan, with 13% of acres grown only accounts for 3% of treatment acres. California, with 3% of the planted acres account for 14% of the treatment acres. Leading Active Ingredients 2008 Active Ingredient 2008 Average 2008 % Total 2008 TERBUFOS 415, , , , , , % ZETA- CYPERMETHRIN 100, , , , , , % CHLORPYRIFOS 131, , , , , , % ALDICARB 126, ,618 96, ,893 68, , % In, 184,358 lb a.i. of chlorpyrifos were used by growers to control insect pests in sugar beets; 134,992 lb a.i. were reported used in 2008 according to Doane. The CDPR reported that in, 30,862 lb a.i. of chlorpyrifos were used in 537 applications on 43,656 acres of California sugar beets to control insect pests. Sulfur was the only active ingredient used on more acres in California than chlorpyrifos, treating 44,888 acres [2]. Sulfur is used as a fungicide to control powdery mildew in sugar beets. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 81

82 Sugar Beets Target Pests The most important insect pests in sugar beets are root maggot, cutworm, and wireworm. Of the nearly 1 million pest acres treated in 2008, 17.9% were to control root maggot, 15.4% to control cutworm, and 13.5% to control wireworms in sugar beets. Top Target Pests 2008 All Active Ingredients % of All a.i. Insect Pests Root Maggot 176, % Cutworm 150, % Wireworm 132, % Root Maggot Root maggot larvae cause damage and reduce yield tonnage and lower root sucrose content by scraping the root surface with rasping mouthhooks. Seedlings are most susceptible to injury because maggot feeding can cut the root and kill the plant. Probability of stand loss is greatest for late planted sugar beets that are in the seedling stages when flies reach seasonal peaks. When infestations are severe, lesions may cover the entire root surface. Feeding on the root tip causes the taproot to fork and branch. Damaged plants wilt during May and June, especially between irrigations. Losses are compounded when root-rot pathogens invade maggot feeding wounds. In fields with histories of root rot, even minor root maggot infestations can combine with soil pathogens and eliminate the stand [3]. Chlorpyrifos is the second most used active ingredient to control root maggot and accounts for 22% of root maggot active ingredient acres. At $9.40 per acre, chlorpyrifos costs 39% less than the average of all active ingredients at $ Leading Active Ingredient to Control Root Maggot 2008 Sugar Beet % of Total Active Ingredient for Root Maggot TERBUFOS 105, % CHLORPYRIFOS 38, % ALDICARB 15, % Cutworm Cutworms feed at night just below the soil surface during dry periods. Typical damage will be areas of wilted or dead beets in the fields. Large areas can be damaged within a beet field overnight if cutworm populations are high [4]. For cutworm, chlorpyrifos is also the second most used active ingredient accounting for 19% of all active ingredient acres (29,582). Leading Active Ingredient to Control Cutworm 2008 Sugar Beet Active Ingredient for Cutworm ZETA-CYPERMETHRIN 54,393 CHLORPYRIFOS 29,582 Armyworm Armyworms skeletonize leaves leaving the veins largely intact. In severe infestations as food becomes scarce, they will consume the veins, petioles, and will even feed on the exposed portions of the beet May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 82

83 Sugar Beets root. Infestations can occur very early in the crop, particularly during cotyledon stages of fall-planted beets. Larvae can consume the entire plant and cause reductions in stand. During mid-season, severe defoliation can cause reductions in root size. During the latter parts of the season, regrowth that occurs to compensate for skeletonized leaves can reduce the percentage of sucrose in the harvested root [5]. Chlorpyrifos is the leading active ingredient used to control armyworm, accounting for 24,656 active ingredient acres; of that, 18,450 were acres reported treated in California. Leading Active Ingredient to Control Armyworm 2008 Sugar Beet Active Ingredient for Armyworm CHLORPYRIFOS 24,656 TERBUFOS 1,200 Chlorpyrifos has been an integral component in sugar beet pest management programs for decades due to its efficacy and broad spectrum pest control using conventional agricultural application equipment. Chlorpyrifos offers broad spectrum control of numerous pest species including aphids, root maggot, and worms. In contrast to esfenvalerate and methomyl, chlorpyrifos is labeled for sugar beet root maggot control; a serious pest of sugar beet production. Chlorpyrifos can be used as a foliar (post) treatment following an at-plant application of terbufos, the leading at-plant material for sugar beet root maggot control. Chlorpyrifos applied as a foliar treatment controls adult sugar beet root maggot flies and also provides some soil activity for active maggots. Chlorpyrifos has provided superior control of Lygus plant bug (a late season pest) compared to the other materials. Chlorpyrifos has been recoginzed as a less hazardous material to handle (Caution signal word) compared to terbufos, which carries a Poison signal word. At-plant soil applications of a granular chlorpyrifos formulation are effective for controlling sugar beet root maggot and cutworms. Post-emergence applications of either a liquid or a granular chlorpyrifos formulation are highly effective for controlling sugarbeet root maggot. Foliar applications of a liquid chlorpyrifos formulation are effectively used to control armyworms, cutworms, grasshoppers, Lygus plant bug (tarnish plant bug) and aphids. Sugar beet growers need chlorpyrifos as an alternative product for foliar treatments in heavy maggot pressures. Chlorpyrifos also provides superior control of Lygus compared to other products. Chlorpyrifos Formulations, Rates, and Applications Formulations listed for controlling insect pests in sugar beets include Lorsban 15G, (and other chlorpyrifos granular formulations), Lorsban-4E, (and other 4 lb per gallon EC formulations of chlorpyrifos), and Lorsban Advanced. Location: Pacific Northwest Pests: worm pests, flea beetles, aphid Application Type: ground Application Method: broadcast directed Rate: lb a.i./a Number and season of Applications: 1, Spring/Summer Location: WA, OR, ID Pests: black bean aphid, cutworm, sugarbeet root maggot Application Type: aerial and ground Application Method: post-emergence/broadcast Rate: 1.0 lb a.i./a May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 83

84 Sugar Beets Number of Applications: 1 Timing: maggot/cutworm April, May; Aphid July-September Location: Midwest ND, MN Pest: root maggot, cutworms, wireworms Application Type: ground Application Method: at-plant Rate: lb a.i./a (Lorsban 15G) Number of Applications: 1 Timing of Applications: at-plant Location: Midwest ND, MN Product: Lorsban 15G Pest: root maggot, cutworms, wireworms Application Type: ground Application Method: directed Rate: lb a.i./a Number of Applications: 1 Timing of Applications: post Location: Midwest ND, MN Product: Lorsban-4E, Lorsban Advanced, Cobalt, etc. Pest: leaf miners, spider mites Application Type: ground, air, chemigation Application Method: broadcast Rate: 0.5 lb a.i./a Number of Applications: 1 Timing of Applications: post Location: Midwest ND, MN Product: Lorsban-4E, Lorsban Advanced, Cobalt, etc. Pest: fall armyworm, yellow stripped armyworm, webworms Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Applications: post Location: Midwest ND, MN Product: Lorsban-4E, Lorsban Advanced, Cobalt, etc. Pest: beet armyworm Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Applications: post Location: Midwest ND, MN Product: Lorsban-4E, Lorsban Advanced, Cobalt, etc. Pest: flea beetle adults, sugarbeet root maggot larvae Application Type: ground, air, chemigation Application Method: broadcast Rate: 1.0 lb a.i./a Number of Applications: 1 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 84

85 Sugar Beets Timing of Applications: post Location: Midwest ND, MN Product: Lorsban-4E, Lorsban Advanced, Cobalt, etc. Pest: sugarbeet root maggot adults Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Applications: post Location: Midwest ND, MN Product: Lorsban-4E, Lorsban Advanced, Cobalt, etc. Pest: sugarbeet root maggot larvae Application Type: ground Application Method: band Rate: lb a.i./a Number of Applications: 1 Timing of Applications: post Chemical Treatments for Insect Control in Sugar Beets 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 (organophosphate) TERBUFOS (organophosphate) Lorsban-4E, Lorsban Advanced, Nufos, Yuma, Warhawk Counter 15G Broad spectrum control of pests, including sugar beet maggot control; superior control of lygus; flexible application type and method Root maggot, Lygus bug, aphid at-plant, efficacious; nematicidal benefit; carries Poison signal word ALDICARB (carbamate) Temik 15G Lock n Load 1-2 lb ai/a Root maggot, aphid, at-plant, efficacious PHORATE Thimet 20G Root maggot; post-emergence treatment 1 application/year ZETA CYPERMETHRIN (pyrethroid) Mustang Max Root maggot, cutworm, Lygus bug, at-plant, foliar (root maggot control is for adults only ESFENVALERATE (pyrethroid) METHOMYL (carbamate) METHAMIDOPHOS (organophosphate) METHYL PARATHION (organophosphate) CLOTHIANIDIN + BETA CYFLUTHRIN SPINOSAD (naturalyte) Asana Lannate Monitor Methyl 4EC Poncho Beta Success as a foliar spray) Armyworm, cutworm, Lygus bug, foliar, atplant (root maggot control is for adults only as a foliar spray) Good activity against armyworm; Class I tox and REI of 48 hours Good activity against armyworm; Class I tox and REI of hours Low cost; not as effective as chlorpyrifos against armyworm; Class I tox; REI 4-5 days Seed treatment applied on the seed by sugar beet seed companies labeled for control of wireworm, cutworm, sugarbeet root maggot and leafminer, flea beetle, black bean aphid and garden springtail Excellent control of armyworm at low use rates; Favorable environmental profile limits impact on beneficial arthropods; Limited use due to price as compared to pyrethroids May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 85

86 Sugar Beets Non-Chemical Alternatives There are currently no practical non-chemical control alternatives effective for management of either sugarbeet root maggot or armyworms. Grower Perspectives In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is a selection of excerpts from growers 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 Chlorpyrifos is an important tool in pest management for sugarbeet production in [Southern Idaho]. It provides a much-needed change in chemical formulation to help prevent sugarbeet root maggot resistance... It helps ensure that good quality products are produced to meet market demands and consumer preference. When used properly, chlorpyrifos only improves the quality that we work so hard to provide. Jentzsch-Kearl Farms Our sugarbeet acres occasionally require treatment for the control of cutworm and sugarbeet root maggot. Both of these pests have a major impact on yield. The American sugarbeet growers have very few options when these pests reach beyond economic thresholds We will be among the first to adapt to better control methods when they become available Until then, please maintain one of the few tools we have to control the serious pest problems that confront us. North Dakota grower References 1. Jacobs, J. Rural Cooperatives. USDA Rural Development. Ethanol for Sugar: What are the Prospects for U.S. Sugar Co-ops? Rural Cooperatives. September-October. Accessed March 1, California Department of Pesticide Regulation. Summary of Pesticide Use Report Data, Indexed by Chemical.. Accessed April 5, Bechinski, E.J., Gallian J.J., Stoltz, R.L. University of Idaho, College of Agriculture. Integrated Pest Management Guide for Sugarbeet Root Maggot. Accessed March 1, NDSU Extension Service, North Dakota State University. Sugarbeet Insects. Accessed March 1, University of California, UC IPM Online. How to Manage Pests, Sugarbeet/Armyworms. November. Accessed April 10, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 86

87 Sunflowers Sunflowers Overview According to the U.S. Department of Agriculture National Agricultural Statistics Service, in ,516,500 acres of sunflowers were planted in the U.S. [1]. U.S. Sunflower Production Planted Planted 2003 Planted Planted Planted Planted Planted 2008 Planted 2009 Average Planted ,344,000 1,873,000 2,709,000 1,950,000 2,070,000 2,516,500 2,069,500 2,218,857 Source: USDA NASS 2008 U.S. Sunflower Production Planted Leading States State Planted (000s) As % of Total North Dakota 1,115, % South Dakota 600, % Kansas 241, % Colorado 194, % Minnesota 115, % Texas 101, % Nebraska 64, % Source: USDA - NASS Target Pests The National Sunflower Association identifies a number of insect pests that can cause injury and economic loss in sunflowers. These pests include: banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower midge, sunflower moth, sunflower seed weevil, sunflower stem weevil, and wireworm. Chlorpyrifos is labeled for use to control all of these pests, except for wireworm and sunflower midge. Currently there are no effective chemical controls recognized for midge. Thiamethoxam, a seed treatment, is the only insecticide labeled for wireworm in sunflowers [2]. Chlorpyrifos Use In 2008, 115,700 lb a.i. of chlorpyrifos were applied to sunflowers. Chlorpyrifos Use in Sunflowers Lbs a.i Total 2003 Total Total Total Total Total 2008 Average lb a.i ,126 21,132 24,855 41,591 75, ,700 48,331 Chlorpyrifos Formulations, Rates, and Applications Current chlorpyrifos formulations listed for controlling insect pests in sunflowers include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 15G (and other chlorpyrifos granular formulations), and Cobalt. Location: Midwest ND, SD, CO, NE, KS Product: Lorsban 15G Pest: cutworms Application Type: ground Application Method: preplant incorporated May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 87

88 Sunflowers Rate: lb a.i./a Number of Applications: 1 Timing of Applications: prior to plant Location: Midwest ND, SD, CO, NE, KS Product: Lorsban-4E, Lorsban Advanced, Cobalt Pest: banded sunflower moth, seed weevil, stem weevil, sunflower beetle larvae and adults, sunflower moth, woolly bears Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Applications: post Location: Midwest ND, SD, CO, NE, KS Product: Lorsban-4E, Lorsban Advanced, Cobalt Pest: cutworms Application Type: ground, air, chemigation Application Method: broadcast Rate: 1.0 lb a.i./a Number of Applications: 1 Timing of Applications: post Chemical Treatments for Insect Control in Sunflowers 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 (organophosphate) CHLORPYRIFOS + GAMMA- CYHALOTHRIN (organophosphate + pyrethroid) ESFENVALERATE (pyrethroid) CYFLUTHRIN (pyrethroid) CARBOFURAN (carbamate) GAMMA- CYHALOTHRIN (pyrethroid) TRALOMETHRIN (pyrethroid) ZETA- CYPERMETHRIN (pyrethroid) LAMBDA- CYHALOTHRIN (pyrethroid) CARBARYL (carbamate) Lorsban-4E, Yuma, Nufos 4e, Lorsban Advanced, Lorsban 15G Cobalt Asana XL Baythroid Furadan 4F Proaxis Scout X-TRA Mustang Max Warrior Sevin Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Banded sunflower moth, cutworm, grasshopper, sunflower beetle, sunflower moth, sunflower seed weevil and stem weevil Cutworm, sunflower beetle, sunflower moth, sunflower stem weevil May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 88

89 Sunflowers THIAMETHOXAM (neonicotinoid) METHYL OR ETHYL PARATHION (organophosphate) Cruiser Sunflower beetle, wireworm Sunflower moth, sunflower seed weevil References 1. United States Department of Agriculture, National Agricultural Statistics Service. Accessed April 11, National Sunflower Association. Approved Chemicals. 14=View&submit.x=49&submit.y=12. Accessed April 11, 2009 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 89

90 Sweet Corn Sweet Corn Overview According to USDA reports, commercial sweet corn production in surpassed $860 million in value, with over 631,000 acres under production. Of all processed (e.g., canned, frozen) vegetables, processed sweet corn accounted for the second largest and second most valuable crop in. While sweet corn is grown in all 50 states, the production of sweet corn for processing is heavily concentrated in the upper Midwest and the Pacific Northwest. Since, the value of Minnesota s sweet corn crop for canning and freezing has surpassed the value of Washington s and Wisconsin s sweet corn crop. Coastal states dominate the commercial fresh sweet corn market. During, Florida remained the leading producer of fresh sweet corn; California, New York, and Georgia produced significant amounts of sweet corn as well [1]. U.S. Sweet Corn Production Planted Planted 2003 Planted Planted Planted Planted Planted 2008 Average Planted Fresh 261, , , , , , ,467 Processing-All 438, , , , , , ,142 Source: USDA NASS Target Pests According to the University of Florida, IFAS Extension, foliar, ear and root feeding insects can routinely cause economic losses to sweet corn if left untreated. The most important pests of sweet corn in Florida are the fall armyworm, corn earworm, lesser cornstalk borer, cutworms, corn silk fly, cucumber beetles, aphids and wireworms [2]. Chlorpyrifos Use In 2008, Doane reported 98,254 acres of sweet corn were treated with just over 87,000 lb of chlorpyrifos. Lbs a.i. Chlorpyrifos Use Average , , , , ,841 87, ,244 The largest use of chlorpyrifos on sweet corn was in the south, where nearly 63,000 acres were treated with chlorpyrifos Chlorpyrifos Use by Region Region 2008 Atlantic 7,044 Midwest 13,398 South 62,657 West 15,155 Grand Total 98,254 Because of 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 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 90

91 Sweet Corn armyworm, and grasshoppers. In granular form at planting, chlorpyrifos is also used for corn rootworm larvae, cutworms, lesser corn stalk borer, seed corn maggot, and wireworms [2]. According to Doane, in ,000 acres of sweet corn were treated in the South to control corn earworm. In the Midwest, corn rootworm was the insect pest most often targeted with chlorpyrifos, with 13,289 acres treated, followed by cutworm, corn earworm, and flea beetle. In Western region states, 6,411 acres of sweet corn were treated with chlorpyrifos to control armyworm and 5,735 acres were treated to control symphylan. Corn earworm is another primary target pest in Western sweet corn. In the Atlantic region, chlorpyrifos use is primarily as Lorsban 15G at-plant for corn rootworm control. The CDPR reported that in, 11,863 lb a.i. of chlorpyrifos were used in 305 treatments on 12,857 acres of corn grown in California for human consumption [3]. Control of many of the insect pests in sweet corn, such as the corn earworm, requires multiple sequential applications. Therefore, there is a great need for alternative efficacious products that can be rotated to delay resistance. Chlorpyrifos is a valuable component in an insect resistance management program due to its different mode of action to pyrethroids and carbamate insecticides, two insecticide classes where there is known insect resistance and that are used to control target pests in sweet corn. Externally applied Bts (Bacillus thuringiensis, a biopesticide bacteria specially formulated for insect control) are another mode of action, but are considered less effective than chlorpyrifos. Chlorpyrifos Formulations, Rates, and Applications Current chlorpyrifos formulations listed for controlling insect pests in sweet corn include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 50W, Lorsban 15G (and other chlorpyrifos granular formulations), and Cobalt. Location: Pacific Northwest Pests: corn earworm Application Type: ground, chemigation, aerial Application Method: broadcast Rate: lb a.i./a Number of Applications: 1-3 Timing of Application: during the Summer Alternatives: lambda cyhalothrin; methomyl Location: FL Pests: fall armyworm, corn earworm, silk fly Application Type: ground and aerial Application Method: low pressure sprayers Rate: lb a.i./a Number of Applications: 3 (max) Timing of Application: October-June Alternatives: lambda-cyhalothrin; methomyl Location: Midwest and Northeast Pest: armyworm, cutworms Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Application: preplant, at-plant, preemergence May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 91

92 Sweet Corn Location: Midwest and Northwest Pest: armyworm, cutworms, aphids, rootworm adults, European corn borer, flea beetle adults, southern corn leaf beetle, webworms, western bean cutworm Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Application: post to corn emergence Location: Midwest and Northeast Pest: corn earworm Application Type: ground, air, chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Application: post to corn emergence Location: Midwest and Northwest Pest: rootworms, cutworms, wireworm, lesser seed corn borer, billbugs Application Type: ground Application Method: at plant Rate: 1.30 lb a.i./a (granular) Number of Applications: 1 Timing of Application: at planting Location: Midwest Pest: European corn borer Application Type: aerial, ground Application Method: broadcast or directed Rate: lb a.i./a (granular) Number of Applications: 1 Timing of Application: in relation to corn growth from V9 to R1 Grower Perspective In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is an excerpt 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 Chlorpyrifos is widely used in Oregon as a seed treatment to control pests that feed on snap bean and sweet corn and young seedlings Producers also use it on sweet corn at planting, to help control corn rootworm larvae, cutworms and symphylans. Growers have not found alternative products that offer the control of chlorpyrifos. Elimination of chlorpyrifos would have significant negative impacts on Oregon growers ability to competitively produce processed vegetable crops and consequently would severely hamper the entire processed vegetable industry in the state. Oregon Processed Vegetable Commission Other Perspective In preparing this report, growers and crop consultants were recently asked to share their thoughts on the benefits and use of chlorpyrifos for pest control. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 92

93 Sweet Corn We need Lorsban in our pest management rotation, as it is one of only a few organophosphates left that control silk flies in sweet corn. Right now, silk flies are a major pest and require frequent sprays. Growers use chlorpyrifos at tassel push and green silk. Lorsban is also used on lesser corn stalk borer and wireworms. Loren Horseman, Glades Crop Care (April 2009) References 1. Agricultural Marketing Resource Center. Sweet Corn. products/grains oilseeds/corn/sweet_corn.cfm. Accessed April 1, Nuessly, G.S. and Webb, S.E. University of Florida, IFAS Extension. Insect Management for Sweet Corn. Revised September. Accessed April 10, 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 93

94 Sweet Potatoes Sweet Potatoes Overview It is estimated that in 2009, 102,000 acres of sweet potatoes will be planted in the U.S. The total number of U.S. acres planted has remained steady since. In 2008, the top sweet potato producing states, based on the value of production, included North Carolina (41%), California (34%), Mississippi (18%), Louisiana (5%), and Alabama (1%) [1]. Chlorpyrifos has been the foundation insecticide for sweet potato growers for many years. Chlorpyrifos provides broad spectrum control of target pests in sweet potatoes and is an important tool in farmers integrated pest management plans. There are few, if any, alternatives that provide effective sweet potato pest control. Most insect damage occurs on the root surface of sweet potatoes. Market tolerance for cosmetic injury in this crop is very low and insect damage can drastically affect its marketability. The use of chlorpyrifos as a preplant treatment to help control a variety of insect pests in sweet potatoes is recommended in the Insect Management Program for Sweet Potatoes at North Carolina State University [2]. Louisiana State University Ag Center lists Lorsban-4E and Lorsban 15G for control of wireworms and flea beetles as a preplant treatment at a rate of 0.5 gal per acre (4E) and 13.5 lb per acre of 15G [3]. Mississippi State University also lists chlorpyrifos for the control of wireworms and flea beetles in its Sweet Potato Insect Control Guide [4]. Chlorpyrifos Formulations, Rates, and Applications Current chlorpyrifos formulations listed for controlling insect pests in sweet potatoes include Lorsban Advanced, Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban 15G (and other chlorpyrifos granular formulations). Location: KS, WI, MO, CO, IA, MN, NE Product: Lorsban 15G Pests: wireworms, flea beetles Application Type: ground Application Method: broadcast Rate: 2.0 lb a.i./a (13.5 lb product/a) Number of applications: 1 Timing of Application: Summer (preplant) Alternatives: pyrethroids Location: KS, WI, MO, CO, IA, MN, NE Product: Lorsban-4E/Lorsban Advanced Pests: Wireworms, flea beetles Application Type: ground Application Method: broadcast Rate: 2.0 lbs a.i./a (4 pints product/a), where labeled Number of Applications: 1 Timing of Application: Summer (preplant) Alternatives: pyrethroids May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 94

95 Sweet Potatoes References 1. United States Department of Agriculture, National Agricultural Statistics Service. Accessed April 1, Sorensen, K. and Jester, B. North Carolina State, NC Cooperative Extension Service. Insect Management Program for Sweet Potatoes at NC State University. Accessed April 1, Burris, E., Hammond A. M., Smith, T.P., Story, R.N. Louisiana State University Agricultural Center. Insect Pest Management in Louisiana Sweet Potatoes, December,. 89BBF8AE4BEC/42470/pub2620InsectPestMgmtSweetPotatoesLOWRES.pdf. Accessed April 1, Burdine, B., Cook, D., Henn, A., Reed, J., Shankle, M. Mississippi State University Extension Service. Sweet Potato Insect Control Guide February Accessed April 1, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 95

96 Tree Nuts Tree Nuts Overview Tree nut crops include almonds, walnuts, pecans, and hazelnuts, which are grown on nearly 1.7 million acres in the U.S. Tree nut production since the mid-2000s generated, on average, nearly $4 billion in annual U.S. farm cash receipts, with almonds, walnuts, and pecans accounting for most of the sales. California is the leading producer of tree nuts. Nearly 90% of U.S. tree nut production is harvested from California orchards annually, including virtually all almonds and walnuts. Georgia, New Mexico, and Texas which produce only pecans, each make up 2 3% of total tree nut output. Together, these three states produce nearly three-quarters of the U.S. pecan crop. Other smaller nut crops, compared to total U.S. tree nut production, include hazelnuts in Oregon and macadamia nuts in Hawaii [1]. U.S. Tree Nut U.S. Tree Nut Average Grand Total 1,676,383 1,643,370 1,646,027 1,694,951 1,665,183 California Almond Production Average 702, , , , ,021 California Walnut Production Average 295, , , , ,663 Texas, Georgia and Oklahoma together grow more than 80% of total pecan acres. Of the average acres grown from to, Texas represents 37.2%, Georgia represents 26.5% and Oklahoma represents 17.7%. Total Pecan Production Average 519, , , , ,156 U.S. Pecan Producing States State Pecan % of Total Pecan Texas 180, % Georgia 128, % Oklahoma 85, % New Mexico 37, % Alabama 22, % Arizona 18, % May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 96

97 Tree Nuts Chlorpyrifos Use According to Doane, in 1,124,876 lb a.i. of chlorpyrifos were used on tree nut crops. Doane data show that in California, 531,441 lb a.i. of chlorpyrifos were used to control insect pests in almonds and 334,188 lb a.i. were used on walnut crops. The CDPR reports that in 418,821 lb a.i. of chlorpyrifos were used in 2,681 applications on 227,409 acres of almonds; and 195,101 lb a.i. were used in 3,306 applications on 108,538 acres of walnut crops. For pecans, Doane report 143,453 lb a.i. of chlorpyrifos were used in Georgia and 76,368 lb a.i. were applied in Texas. Almonds The following show chlorpyrifos use in California almonds and acres treated with chlorpyrifos as reported by the CDPR. Use of Chlorpyrifos in California Almond Lbs a.i Chlorpyrifos 2003 Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Average Chlorpyrifos , , , , , ,991 Source: California Department of Pesticide Regulations California Almond with Chlorpyrifos Average , , , , , ,951 Source: California Department of Pesticide Regulations Target Pests in Almonds There are two primary pests in California almonds, twig borer and navel orangeworm. Both pests can severely damage nut crop harvests if not controlled. Target Pests in Almonds Total (all insecticides) Pests Peach Twig Borer 952,800 Navel Orangeworm 678,848 Peach Twig Borer Peach twig borer larvae damage both growing shoots and nuts, causing shallow channels and surface grooves on the nutmeat. There can be as many as four generations of peach twig borers in a season. Chlorpyrifos is one of the two most often used active ingredients to control peach twig borer. Esfenvalerate, a pyrethroid, is the leading active ingredient. Doane shows that in, there were 171,526 total almond acres treated with chlorpyrifos for peach twig borer. At a cost of $16.50 per acre treated to control peach twig borer, chlorpyrifos is 5% higher than the average treatment of $15.70, but because of its broad spectrum control of other arthropod pests present in the field, it is a cost-effective treatment. Navel Orangeworm May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 97

98 Tree Nuts The navel orangeworm is the leading pest in almonds. The larvae feed directly on the nutmeats, making them unsuitable for the marketplace. Usually more than one larva can be found feeding in a nut. Navel orangeworm larval damage can also lead to fungal infections. According to Doane, chlorpyrifos is the most often used active ingredient to control naval orangeworm. A total of 164,521 acres were treated with chlorpyrifos in for navel orangeworm. The cost per acre to control naval orangeworm with chlorpyrifos is $ This is 7.5% less than the average treatment of all active ingredients ($19.60) for navel orangeworm. Other pests that drive use of chlorpyrifos include San Jose scale and ants. The broad spectrum insect control of chlorpyrifos makes it a popular choice for almond growers. Chlorpyrifos Use in Almonds There are four key use patterns for chlorpyrifos to control pests in almonds. These include winter dormant sprays; May sprays for peach twig borer; hull-split sprays for peach twig borer and navel orangeworm; and ant control on the orchard floor. Although some use of chlorpyrifos occurs with each of these patterns annually, an individual orchard does not use all four spray timings to manage key pests. Chlorpyrifos is likely to be used in only one, or at most two, applications per season in a given orchard. Dormant sprays are typically applied during late December through the end of January and are targeted at the overwintering generation of peach twig borer and San Jose scale. Air blast applications at 100 gallons per acre (GPA) are preferred, but if soils are saturated from winter rains aerial applications at GPA will occasionally be utilized. Chlorpyrifos is not registered to be applied for almonds by air as a dormant spray since the minimum spray volume is 100 GPA and this can not be achieved by air. Although not commonly used in dormant spray programs, when used, chlorpyrifos is applied at 2.0 lb a.i./a in combination with 2.0% dormant oil (v/v). May sprays are targeted at first generation of peach twig borer and to a lesser degree naval orangeworm. Some degree of benefit in worker ant suppression is also achieved through a May spray utilizing chlorpyrifos. Traditionally, products that do not harm beneficial arthropods are preferred for May sprays because their use does not flare spider mite populations in almonds. Chlorpyrifos is among those products that do not flare spidermites, making it a product of choice. The rate of 2.0 lb a.i./a of chlorpyrifos is applied at 100 GPA in an orchard airblast application. Orchards that received a dormant application typically do not receive a May spray. Ant sprays with chlorpyrifos are not as common as they used to be a decade ago in almonds. Granular bait applications containing abamectin or pyriproxyfen are the primary products used. Chlorpyrifos is used only as a rescue treatment when the baits were not applied earlier in the season. Ants are direct pests of almonds and consume the nutmeats as the nuts dry on the orchard floor following shaking and prior to sweeping. Chlorpyrifos is applied to the orchard floor at a rate of 2.0 to 4.0 lb a.i./a during the summer months prior to harvest to reduce worker ant activity. Applications are made either directed to the orchard floor with a broadcast boom sprayer modified for directed herbicide applications in orchards as a strip spray, as a total orchard floor spray or through microjet sprinkler irrigation. Hull-split applications are typically made just prior to and during the initial phase of the nut hull splitting open to expose the nutmeat. Peach twig borer and especially naval orangeworm can both feed directly on the nutmeats causing considerable yield and quality losses. Typically one application at 2.0 lb a.i./a of chlorpyrifos is made at % hull split. In high population situations, a second application of an insecticide may be applied within 7 10 days. When a second application is required, typically a different product is used for resistance management reasons. Applications are made with orchard May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 98

99 Tree Nuts airblast sprayers utilizing 100 GPA. Pre-harvest interval, potential for mite outbreak and residual are critical in the selection of the insecticide used for hull-split applications. More than 70% of chlorpyrifos used in almonds occurs during the hull split or the application that occurs within 2-3 weeks of hull split. Chlorpyrifos is a preferred insecticide during this time frame due to its three-way mode of action: contact, ingestion and vapor. This application is targeted primarily against naval orangeworm and to a lesser extent peach twig borer. However, some ant suppression in the orchard floor is also achieved with this application. Approximately 10% of chlorpyrifos used in almonds is used for ant control. Increasing ant populations and damaged nuts in recent years have driven an increased use of chlorpyrifos for ant control. In general, use of chlorpyrifos in the dormant and foliar almond spray segments has been declining in recent years, but overall volume has remained stable due to increased use for ant control. The CDPR noted that, in-season use of chlorpyrifos in was down due in large part to the lack of leaffooted bugs, which were a problem statewide in [2]. Approximately 10% of total chlorpyrifos usage in almonds occurs in dormant applications. Organophosphates had the largest market share of this category, but since 1995 a large number of dormant applications are utilizing pyrethroids. It is estimated that 60% to 80% of all dormant applications made to almonds in 2008 where pyrethroid based. Methoxyfenozide and diflubenzuron sprays during bloom have become very popular on acres where a dormant treatment was not used or desired but weather patterns did not allow dormant sprays to be made. Chlorpyrifos as a dormant spray is used primarily when San Jose scale is a concern. This application will provide control of scale, peach twig borer and overwintering mite eggs particularly when used in combination with supreme oil. May sprays represent approximately 10% of the total chlorpyrifos applied in almonds. Methoxyfenozide and spinosad/spinetoram are favored active ingredients at this timing due to their safety to beneficial arthropods and lack of mite flare. Pyrethroids are being increasingly applied for May sprays due to a very competitive cost position; however, concerns of mite flare have somewhat limited pyrethroid use in this timing. Chlorpyrifos Formulations, Rates, and Applications The formulations listed for treating almonds include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban Advanced, and Cobalt. Location: CA Pests: overwintering generation of peach twig borer and San Jose scale Product: Lorsban-4E Application Type: airblast, aerial, dormant spray Application Method: airblast application at 100 GPA, if soil saturated by rain, aerial applications at GPA may be utilized Rate: 2.0 lb a.i./a in combination with 2% dormant oil (v/v) Number of Applications: 1 Season of Application: late December end of January Location: CA Pests: peach twig borer and navel orangeworm, some ant worker suppression Product: Lorsban-4E Application Type: spray Application Method: airblast application at 100 GPA, if soil saturated by rain, aerial May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 99

100 Tree Nuts applications at GPA may be utilized Rate: 2.0 lb a.i./a in combination with 2% dormant oil (v/v) Number of Applications: 1 Season of Application: May; orchards that receive a dormant application typically do not receive a May spray Chlorpyrifos and Chemical Alternatives in Almonds Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Brand Active Ingredient CHLORPYRIFOS (organophosphate) CHLORPYRIFOS + GAMMA CYHALOTHRIN (organophosphate + pyrethroid) ABAMECTIN Names Lorsban- 4E, Nufos, Yuma, Lorsban Advanced Cobalt Benefits, Application, Use, and Efficacy Does not harm beneficial arthropods; preferred for May sprays because use does not flare spider mite populations in almonds; Broad spectrum of pest control; Used as rescue product when ant baits not applied earlier in season Broad spectrum of pest control; good rotational product Clinch ant Granular bait applications for ants bait SPINETORAM Delegate Registered in. Used on limited acres in Highly effective for control of peach twig borer and navel orangeworm. Used as dormant spray, May spray and hull split spray. Higher price relative to chlorpyrifos and pyrethroids may be limitation. SPINOSAD METHOXYFENOZIDE (diazylhydrazine) PYRIPROXYFEN PETROLEUM OIL DIAZINON (organophosphate) BT Bacillus thuringiensis Success, Entrust Intrepid 2F Esteem ant bait, Seize 35 WP Highly effective peach twig borer control at all foliar and dormant timings, high cost versus pyrethroids and organophosphates. Limited pest spectrum compared to chlorpyrifos (no scale control). Short residual and marginal efficacy against naval orangeworm compared to organophosphates and pyrethroids. Gained in popularity for lepidopteran insect control in almonds. Used for peach twig borer during bloom; navel orangeworm as May spray and for both peach twig borer and navel orangeworm during hull split and post hull split. Bloom time application popular due to safety to bees, long residual and free ride with fungicides during bloom. Granular bait applications for ants. Insect growth regulator (juvenoid) with good homopteran activity. Has been effective where San Jose scale has shown resistance to Organophosphates. High cost. Not broad spectrum. Some concerns with toxicity on some predators (coccinellidae/ladybugs) High rates must be applied when used without an organophosphate. Suppression rather than control. Very good mixing partner for organophosphates. Good control of San Jose scale when combined with dormant oil. Primarily used as bloom spray. Requires two applications with moderate levels of control. Popular a few years ago, but have lost market share to Dimilin and Intrepid as bloom time spray. Not adequately residual for May spray and hull-split applications. Somewhat less expensive per application than organophosphate, but requires two applications. ESFENVALERATE (pyrethroid) Asana Superior efficacy and cost structure; approx 1/3 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Detections in sediments of surface water is an emerging issue and significant barrier to use PERMETHRIN (pyrethroid) Ambush Superior efficacy and cost structure; approx 1/3 cost of May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 100

101 Tree Nuts BIFENTHRIN (pyrethroid) LAMBDA-CYHALOTHRIN (pyrethroid) DIFLUBENZURON (benzoylphenylurea) Capture, Hero, Brigade Warrior Dimilin organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Detections in sediments of surface water is an emerging issue and significant barrier to use. Superior efficacy and cost structure; approx 1/3 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Detections in sediments of surface water is an emerging issue and significant barrier to use. Brigade has shown good efficacy on navel orangeworm and used heavily in season. Superior efficacy and cost structure; approx 1/3 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Detections in sediments of surface water is an emerging issue and significant barrier to use. Insect growth regulator, used for peach tree borer control during bloom. Gained in popularity in recent years due to safety to bees, long residual and free ride with fungicides during bloom. Difficult to handle (dangerous), short lasting control (24 hours) METHYL PARATHION (organophosphate) Methyl parathion METHIDITHION Supracide Good control of San Jose scale when combined with oil. Higher cost than chlorpyrifos. CHLORANTRANILIPROLE Altacor Under development for naval orangeworm control and possibly peach twig borer. Shown good efficacy in university trials. Non-Chemical Alternatives Pheromone disruption Under development for peach twig borer and navel orangeworm. No commercial successes have yet been achieved in almonds with this technology. Development of mating disruption for codling moth management in apples has been the focus of a majority of research efforts and funding. There are significant technical hurdles to overcome in almonds. Not likely to be commercially viable for 5 to 10 years. Entomophagous nematodes Parasitic nematodes have been evaluated both academically and commercially for control of lepidoptera pests of almonds, especially peach twig borer and navel orangeworm. No consistent commercially acceptable control has been achieved by this means. In addition, commercially developed products based on entomophagous nematodes have been difficult to apply, have had poor shelf life and have had a very high cost structure relative to standard insecticides. Mummy removal and early harvest are two main cultural practices for managing populations of navel orangeworm in almonds. University of California Cooperative Extension and UC IPM area wide have successfully promoted and implemented these ideas over the years. Sanitation has been the key in keeping the navel orangeworm populations under manageable levels. Walnuts Target Pests in Walnuts A number of pests threaten California walnut crops, including codling moth, walnut husk fly, spider mites, navel orangeworms, and walnut aphid. Doane data show that in, chlorpyrifos, which provides broad spectrum control of a number of insect pests, was the most used active ingredient of all. Codling Moth Codling moth has been a serious pest of walnuts in California for as long as the crop has been grown in the state and can greatly affect yields. Two to three generations of codling moth attack walnuts in California. First generation larvae cause nutlets to drop from the tree and subsequent generations can May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 101

102 Tree Nuts damage the nut kernel, making them unmarketable. Damaged kernels can also become breeding sites for the naval orangeworm, another crop-damaging pest. Chlorpyrifos remains the leading treatment for codling moth in California walnuts and plays an important role in integrated pest management. In, Doane shows walnut growers treated more than 138,000 acres with the active ingredient chlorpyrifos to control codling moth. Other products used include esfenvalerate (pyrethroid) and methyl parathion (organophosphate). Chlorpyrifos Use in Walnuts According to Doane, applications of chlorpyrifos were made on an average of 207,000 acres per year from to. Chlorpyrifos Use for Insect Control in Walnuts Active Ingredient Average CHLORPYRIFOS 204, , , , ,201 Data from the CDPR show the following annual volume of chlorpyrifos used on walnut crops. Use of Chlorpyrifos in California Walnuts Lbs a.i Chlorpyrifos 2003 Chlorpyrifos Chlorpyrifos Chlorpyrifos Chlorpyrifos Average Chlorpyrifos , , , , , ,505 Source: California Department of Pesticide Regulations California Walnuts with Chlorpyrifos Average , , , , , ,294 Source: California Department of Pesticide Regulations Chlorpyrifos is foliar applied to walnuts with an orchard airblast sprayer at 200 GPA. Three potential application windows are available for the use of chlorpyrifos for control of codling moth or walnut husk fly. Chlorpyrifos is applied at 2.0 lb a.i./a in late April mid May or early June targeted at codling moth. As mentioned above, two to three generations of codling moth attack walnuts in California and each generation is bimodal (i.e., two distinct population peaks are evident). The two populations present in the first generation are designated peaks 1A and 1B respectively and peaks of the second generation are designated 2A and 2B. The majority of chlorpyrifos use is targeted at the first generation. Applications targeted at peak 1A are applied when two conditions have been met. Nuts must be at least one half inch in diameter and degree days have accumulated following first trap capture of moths (known as the biofix). Applications for peak 1B are made at degree days post biofix. These applications usually occur in May. Second generation applications occur at degree days post biofix for peak 2A and degree days post biofix for peak 2B. These applications typically occur in June and July. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 102

103 Tree Nuts Greater than 90% of current volume of chlorpyrifos used on walnuts is for management of codling moth and nearly 70% of chlorpyrifos use for codling moth is for first generation (peaks 1A and 1B) cover sprays. Azinphos methyl and pyrethroids are preferred for control of second generation codling moth, In the late 1980s and early 1990s chlorpyrifos rapidly displaced azinphos methyl to become the preferred active ingredient for codling moth control in walnuts. This was primarily due to use for first generation codling moth cover sprays and the short residual relative to azinphos-methyl. University of California researchers found that use of chlorpyrifos was compatible with biological control of walnut aphid allowing Trioxys sp., a parasitoid of the walnut aphid, to recolonize treated orchards for successful biological control of the aphid. If azinphos methyl was utilized for first generation codling moth, aphid flare-up would occur resulting in an additional application of insecticide. In more recent years, chlorpyrifos market share has declined somewhat due to increased competitive pressures from pyrethroids and introduction of the active ingredient methoxyfenozide, a molting hormone mimic. Extended or bimodal peaks of the first and second generation codling moth flights have favored the use of more residual organophosphates and pyrethoids. Pyrethroids are considered highly disruptive to beneficial arthropod systems but are used by growers due to low cost. Some use of chlorpyrifos occurs at 2.0 lb a.i./a in July August for control of walnut husk fly. In, more than 54,000 acres were treated with chlorpyrifos to control husk fly in California, and according to Doane, chlorpyrifos is the most used active ingredient for husk fly control. This pest appears on a limited number of acres in several pockets of walnut production in California, but it is a key pest in those areas. Husk fly treatments are applied either with air blast applications or by air combined with an attractant bait. Chlorpyrifos Formulations, Rates, and Applications The formulations listed for controlling insect pests in walnuts include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos) and Lorsban Advanced. Location: CA Pests: codling moth Product: Lorsban-4E Application Type: airblast, aerial, dormant spray Application Method: airblast application at 200 GPA Rate: 2.0 lb a.i./a Season of Application: April mid May or early June (first generation); June to July for second generation Location: CA Pests: walnut husk fly Product: Lorsban-4E Application Type: airblast, aerial, dormant spray Application Method: airblast application at 200 GPA Rate: 2.0 lb a.i./a Season of Application: July August May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 103

104 Tree Nuts Chemical Treatments for Insect Control in Walnuts Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Brand Active Ingredient CHLORPYRIFOS (organophosphate) PHOSMET (organophosphate) Malathion (organophosphate) SPINETORAM (naturalyte) METHOXYFENOZIDE (diazylhydrazine) PERMETHRIN (pyrethroid) ESFENVALERATE (pyrethroid) BIFENTHRIN (pyrethroid) LAMBDA- CYHALOTHRIN (pyrethroid) METHYL PARATHION (organophosphate) Names Lorsban-4E Imidan Delegate Intrepid 2F Ambush Asana Capture, Hero, Brigade Warrior Methyl parathion Benefits, Application, Use, and Efficacy Excellent control in controlling first generation codling moth; broad spectrum control of several pests; compatible with biological control of walnut aphid. Performance inferior to chlorpyrifos for control of codling moth and walnut husk fly. Requires buffering for optimal efficacy, which creates performance issues. Used primarily for first generation codling moth. Short residual challenges performance against extended flight second generation. Commonly used for husk fly in combination with bait sprays. Registered in late. Has shown excellent efficacy in research trials. Higher cost compared to chlorpyrifos. Used against 1B, 2A, 2B flights of codling moth. More costly relative to chlorpyrifos and does not control walnut husk fly or walnut aphid. Excellent residual efficacy and cost structure approx. 1/2 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods. Superior efficacy and cost structure; approx. 1/3 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Detections in sediments of surface water is an emerging issue and significant barrier to use Excellent residual efficacy and cost structure approx. 1/2 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods. Superior efficacy and cost structure; approx. 1/3 cost of organophosphates. Low cost is over-riding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Detections in sediments of surface water is an emerging issue and significant barrier to use. Difficult to handle (dangerous), short lasting control (24 hours) Non-Chemical Alternatives Pheromone disruption Limited commercial successes have been achieved in walnuts with this technology. Development of mating disruption technology for codling moth management in apples has been the focus of the majority of research efforts and funding, but there are significant technical hurdles to overcome in walnuts. Trees abort any young nuts with injury; hence, a very low tolerance threshold is maintained making commercially acceptable disruption viable. Technologies for delivery systems have been studied extensively over the last decade with limited success. PECANS Target Pests in Pecans The two most important widely distributed insect pests in pecans are pecan nut casebearer and black pecan aphid. Chlorpyrifos was sprayed on more than half of the active ingredient acres in all pecan producing states in according to Doane. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 104

105 Tree Nuts Leading Pests in Pecans with Chlorpyrifos % of a.i. Leading Insect Pests in Pecans with Chlorpyrifos for Target Pest Pecan Nut Casebearer 103, % Black Pecan Aphid 138, % Pecan Weevil 111, % Pecan Nut Casebearer The pecan nut casebearer is the most damaging insect pest of pecans in Texas. Most of the damage is caused by first generation larvae feeding in the young nuts in late May and early June. Due to the small size of the nuts, each larvae feeds in several nuts to complete its development. A larvae often destroys an entire nut cluster. Second generation larvae do similar damage, but usually each larva only damages one nut. Overwintered larvae cause a certain amount of damage by tunneling and killing new shoots early in the spring [3]. Black Pecan Aphid Black pecan aphids can significantly reduce pecan yields. The aphids suck photosynthates from leaves, excrete honeydew and reduce the flow of nutrients to nuts. Black aphid damage is characterized by small, chlorotic areas on the leaflets. Heavy infestations cause rapid leaf shed. These aphids can cause premature leaf shed, reduced nut quality, and subsequent yield reductions the following season [4]. Other pests include yellow pecan aphids and hickory shuckworm. Chlorpyrifos Use in Pecans Chlorpyrifos is especially important to pecan growers and is the leading active ingredient used for treating insect pests in pecan crops in Georgia and Texas. In, 192,796 acres were treated with chlorpyrifos in Georgia to control insect pests; 107,042 acres were treated with chlorpyrifos in Texas. Leading Active Ingredients in Georgia Pecan Crops Leading Active Ingredients Georgia Total Georgia Total Georgia Total Georgia Total Georgia Average CHLORPYRIFOS 199, , , , ,796 IMIDACLOPRID 59,995 34,025 79,451 43,306 54,194 CYPERMETHRIN 57,893 39,520 31,647 17,053 36,528 Leading Active Ingredients in Texas Pecan Crops Leading Active Ingredients Texas Total Texas Total Texas Total Texas Total Texas Average CHLORPYRIFOS 98, , ,796 94, ,042 CARBARYL 25,138 29,105 39,382 22,739 29,091 METHOXYFENOZIDE 4,396 51,160 27,945 12,881 24,096 Chlorpyrifos Formulations, Rates, and Applications The formulations listed for controlling pests in pecans include Lorsban Advanced, Lorsban-4E (and other 4 lbs per gallon EC formulations of chlorpyrifos), and Cobalt. Chlorpyrifos is foliar-applied to pecans with an orchard airblast sprayer at GPA. Three potential application windows are available for the use of chlorpyrifos for control of aphids, hickory nut May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 105

106 Tree Nuts shuckworm, pecan casebearer, and others. Chlorpyrifos will generally account for 1 to 2 applications per season on pecan groves targeted against the following pests: Pest: black pecan aphid Application Rate: 1.0 lb a.i./a Lorsban-4E or 0.5 lb. a.i./a Lorsban-4E + pyrethroid. Pest: hickory shuckworm Application Rate: 1.0 lb a.i./a Timing: August Pest: Phylloxera (sap eating root louse) Application Rate: 1.0 lb a.i./a Timing: at bud break Pest: pecan nut casebearer Application Rate: lb a.i./a (1st generation); 0.5 lb. a.i./a (2nd generation) Timing: April for 1st generation egg hatch; June for 2nd generation egg hatch Pest: spittlebugs (SE U.S.) Rate: 0.75 lb a.i./a Timing: applied May through June Applications: 2 applications may be needed Pest: yellow aphid complex Application Rate: 0.5 lb a.i./a Lorsban-4E + pyrethroid Timing: after July 1 when threshold reached Early season use of chlorpyrifos minimizes aphid and mite flare-up associated with other products, especially pyrethoids; however, low cost of pyrethroids is driving increased use. Use pattern depends on pest history of plantation. Insecticide sprays are generally combined with a scab fungicide program. Most applications are ground applied with an airblast sprayer. Aerial application does occur, but is of minor use. Chlorpyrifos and Chemical Alternatives for Pecans Note: Information in the Benefits, Application, Use and Efficacy section reflect opinions of crop consultants, field experts, and other contributors to this report. Brand Active Ingredient CHLORPYRIFOS (organophosphate) CHLORPYRIFOS + GAMMA CYHALOTHRIN (organophosphate + pyrethroid) PHOSMET (organophosphate) IMIDACLOPRID Names Lorsban-4E Cobalt Imidan Admire Pro, Provado Benefits, Application, Use, and Efficacy Early season use minimized aphid and mite flare-up associated with other products, especially pyrethroids; broad spectrum controlling pecan pest complex. Broad spectrum of pest control. Combination of two active ingredients and two modes of action; lower chlorpyrifos use rates versus straight product. Good knockdown and residual control. Performance similar to chlorpyrifos. Somewhat higher application rate ( lb a.i./a) needed to deliver equivalent control and residual for pecan nut casebearer. Neonicotinoid insecticide with excellent sap-feeding activity; moves within the plant, which can compensate for average application, control limited to homopteran and hemipteran insects CARBARYL (carbamate) Sevin Broad spectrum insecticide; adds one more mode of action for insect resistance management; fast knockdown Bacillus thuringiensis Not widely used for pecan nut casebearer due to required 4-7 May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 106

107 Tree Nuts (Bt) METHOXYFENOZIDE (Insect growth regulator) ESFENVALERATE (pyrethroid) PERMETHRIN (pyrethroid) BIFENTHRIN (pyrethroid) LAMBDA- CYHALOTHRIN (pyrethroid) Intrepid 2F Asana Ambush Capture, Hero, Brigade Warrior day residual for protection of nutlets. Nutlets abort if fed on; since Bt is a stomach poison, its utility is limited. Widely used and effective for control of hickory shuckworm. Used against 1B, 2A, 2B flights of codling moth. More costly relative for chlorpyrifos and does not control walnut husk fly or walnut aphid. Does not affect beneficial populations, residual activity valued. Excellent residual efficacy and cost structure approx. 1/2 cost of organophosphates drives its increased use. Low cost is overriding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Early season sprays for pecan nut casebearer have historically resulted in severe mite and aphid problems later; limited use. Shuckworm applications occur later in season, so mite flare is of lower concern. Excellent residual efficacy and cost structure approx. 1/2 cost of organophosphates drives its increased use. Low cost is overriding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Early season sprays for pecan nut casebearer have historically resulted in severe mite and aphid problems later; limited use. Shuckworm applications occur later in season, so mite flare is of lower concern. Excellent residual efficacy and cost structure approx. 1/2 cost of organophosphates drives its increased use. Low cost is overriding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Early season sprays for pecan nut casebearer have historically resulted in severe mite and aphid problems later; limited use. Shuckworm applications occur later in season, so mite flare is of lower concern. Excellent residual efficacy and cost structure approx. 1/2 cost of organophosphates drives its increased use. Low cost is overriding concerns of disruption of beneficial arthropods and known problems with secondary mite outbreaks. Early season sprays for pecan nut casebearer have historically resulted in severe mite and aphid problems later; limited use. Shuckworm applications occur later in season, so mite flare is of lower concern. Non-Chemical Alternatives There are currently no viable non-chemical alternatives available. Grower Perspective Following is an excerpt from a university specialist who responded to the EPA s request for input by explaining why chlorpyrifos is considered essential for protecting crops. Submissions to the docket are public information and have been posted by the EPA at docket number EPA-HQ- OPP My major concerns regarding the withdrawal of chlorpyrifos from the management options currently available to pecan growers in Texas are 1) that the risk of resistance to remaining materials will increase; 2) that some producers may adopt materials that are more disruptive of the IPM [Integrated Pest Management] program (i.e., pyrethroids) than those currently being used; and 3) that outbreaks of secondary pests like aphids, mites and leafminers may result and trigger more insecticide use than is currently needed to produce large crops of good quality. Texas Entomologist May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 107

108 Tree Nuts References 1. U.S. Department of Agriculture, Economic Research Service. Fruit and Nut Trees Background. February 25, Accessed April 12, California Department of Pesticide Regulation. Summary of Pesticide Use Report Data, Indexed by Chemical.. Accessed April 5, Oklahoma State University, Entomology and Plant Pathology. Pecan Nut Casebearer. Accessed February 25, Texas A & M University, Department of Entomology. Pecan Insect Pests. Accessed April 12, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 108

109 Wheat Wheat Overview The U.S. is a major wheat-producing country, with output typically exceeded only by China, the European Union, and India. Wheat ranks third among U.S. field crops in both planted acreage and gross farm receipts, behind corn and soybeans. Presently, about half of the U.S. wheat crop is exported [1]. Wheat is the main food grain produced in the U.S. Wheat varieties grown in the U.S. are classified as "winter wheat" or "spring wheat," depending on the season in which each is planted. Winter wheat production represents 70% to 80% of total U.S. production. U.S. Wheat Production 2008 Region 2008 Average 2008 Atlantic 2,210,999 1,480,003 1,500,000 1,749,998 2,300,001 1,848,200 Midwest 5,985,002 5,170,001 5,850,002 6,049,999 6,979,997 6,007,000 Plains 36,055,001 35,678,014 35,195,064 36,180,005 36,009,942 35,823,605 South 1,677, , ,000 1,199,999 1,449,999 1,107,600 West 13,789,991 13,710,032 13,149,968 13,415,006 14,094,979 13,631,995 Grand Total 59,718,992 56,578,051 56,365,034 58,595,007 60,834,918 58,418,400 In 2008, 82% of wheat acres were planted in the Plains and West regions. Five states, Kansas, North Dakota, Texas, Oklahoma, and Montana accounted for 60% of 2008 planted acres. Chlorpyrifos Use Chlorpyrifos is approved for use in wheat in states west of the Mississippi only. In 2008, growers applied 867,679 lb a.i. of chlorpyrifos to control insect pests in wheat. Of that, 647,999 lb a.i. were used in winter wheat and 219,680 lb a.i. were applied to spring wheat. In four of the past five years, chlorpyrifos has been the leading active ingredient in treating insect pests in wheat due to its fast knockdown of the most troublesome insect pests. Leading Active Ingredients U.S. Wheat 2008 Leading Active Ingredient % of % of % of % of % of 2008 Average % of Total 2008 CHLORPYRIFOS 43.57% 32.63% 38.77% 20.11% 39.60% 34.14% LAMBDA-CYHALOTHRIN 24.98% 23.07% 28.75% 26.63% 35.63% 29.36% METHYL PARATHION 11.41% 14.56% 8.54% 9.82% 5.38% 8.82% ZETA-CYPERMETHRIN 8.46% 5.99% 5.63% 14.63% 5.55% 8.53% In the Plains region, chlorpyrifos continues as the leading active ingredient used to control insect pests. Plains Region Leading Active Ingredients 2008 Leading Active Ingredient % of % of % of % of % of 2008 Average % of Total 2008 CHLORPYRIFOS 68.30% 47.27% 72.15% 27.29% 69.03% 54.58% ZETA-CYPERMETHRIN 3.76% 9.53% 6.32% 18.60% 2.00% 8.68% LAMBDA-CYHALOTHRIN 8.93% 4.25% 3.65% 11.64% 7.40% 8.20% May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 109

110 In 2008, chlorpyrifos continued to be the leading active ingredient in Texas representing 91% of active ingredient applications (908,319 acres a.i.) and in Oklahoma, representing nearly 85% of the active ingredient applications (379,750 acres a.i.). It was the second most used active ingredient in South Dakota (32% of a.i. acres), and Minnesota (24% of a.i. acres). Target Pests Wheat Aphids Aphids (greenbug, Russian wheat aphids, green peach aphids, and bird cherry-oak aphids) are the most troublesome insect pests in wheat in the U.S. and can inflict substantial losses. Nearly 3 million acres in 2008 were treated with insecticides to control greenbugs, Russian wheat aphids, and other aphids. Chlorpyrifos is the leading insecticide used to control aphids in wheat, with the greenbug being the primary target pest. Growers prefer chlorpyrifos for control of aphids, including greenbug and Russian wheat aphid, because it provides fast knockdown of populations of these damaging pests. Aphids have explosive reproductive capabilities. The Russian wheat aphid causes leaves to roll up, shielding them from direct contact with insecticides. The vapor action of chlorpyrifos penetrates into hard-to-reach areas and is the only active ingredient that can effectively control the pests after they begin to roll leaves in later colonization stages. While 14 active ingredients were reported as being used on wheat, only four were used to control greenbugs. Chlorpyrifos accounted for 91% of all acres in the nation treated for greenbug due to its fast knockdown in controlling this pest known for its explosive population growth Leading Active Ingredients Used to Control Greenbug in Wheat U.S. Active Ingredient Total Pest % of Total Pest CHLORPYRIFOS 1,158, % GAMMA-CYHALOTHRIN 80, % METHYL PARATHION 31, % DIMETHOATE 9, % Total 1,279, % Cost of Treatment The average cost per acre for chlorpyrifos is $3.94. The second most used active ingredient is used on slightly more than 6% of acres treated at a cost of $2.18 per acre. Despite its higher cost per acre, chlorpyrifos is the leading active ingredient due to its high efficacy in controlling aphids and controlling other pests that may be present at the same time of the application Active Ingredient and Cost Per Acre to Control Greenbug in Wheat U.S. Total Area Active Ingredient (Pest ) $/AC CHLORPYRIFOS 1,144,264 $3.94 GAMMA-CYHALOTHRIN 80,267 $2.18 METHYL PARATHION 31,050 $6.00 DIMETHOATE 9,120 $3.92 Chlorpyrifos is also used to control other target pests in wheat including grasshoppers, cereal leaf beetle, cutworms, and orange wheat blossom midge. The vapor action of chlorpyrifos is particularly important to control the wheat midge, a very devastating pest that affects yield if not controlled with an effective insecticide. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 110

111 Wheat Chlorpyrifos provides quick knockdown of aphids and other pests. It provides superior aphid control compared to lambda-cyhalothrin and other pyrethroids which provide slower control and may allow aphid populations to rebuild following treatment. It is the product of choice for control of orange wheat blossom midge. Control of aphids (including Russian wheat aphid) and midges with chlorpyrifos appears to typically be superior to that provided by pyrethroids such as zeta-cypermethrin and beta-cyfluthrin. Chlorpyrifos is particularly well-suited for control of aphids and midge in wheat. Chlorpyrifos Formulations, Rates, and Applications Formulations listed for controlling insect pests in wheat include Lorsban-4E (and other 4 lb per gallon EC formulations of chlorpyrifos), Lorsban Advanced, and Cobalt. Location: TX Pests: greenbugs (aphid) Application Type: foliar ground Application Method: boom sprayer Rate: lb a.i./a Number of Applications: 1 2 Timing of Application: December-February Location: ND, MT, MN Pests: aphid, cereal leaf beetle, cutworm, grasshopper, orange wheat blossom midge Application Type: foliar, ground & aerial Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 2 Timing of Application: Spring/Summer Location: OK, KS, CO Pests: aphids, midge Application Type: foliar ground chemigation Application Method: broadcast Rate: lb a.i./a Number of Applications: 1 Timing of Application: Spring May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 111

112 Wheat Chemical Treatments for Insect Control in Wheat 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 Name Benefits, Application, Use, and Efficacy Lorsban-4E, Hatchet, Nufos, Yuma 4E, Warhawk, Chlorpyrifos 4e AG, Lorsban Advanced CHLORPYRIFOS (organophosphate) CHLORPYRIFOS + GAMMA- CYHALOTHRIN (Organophosphate + pyrethroid) LAMBDA-CYHALOTHRIN (pyrethroid) BETA-CYFLUTHRIN (pyrethroid) METHYL PARATHION (organophosphate) ZETA-CYPERMETHRIN (pyrethroid) DIMETHOATE (organophosphate) GAMMA-CYHALOTHRIN (pyrethroid) PHORATE (organophosphate) Cobalt Warrior Baythroid Various parathion Mustang Max Dimethoate Proaxis Fast knockdown of aphids and other pests, including orange wheat blossom midge. Control of aphids, including Russian wheat aphid and midge is superior to that of pyrethroids as vapor action allows chlorpyrifos to penetrate leaves that have been rolled by these pests, preventing direct contact with insecticide. Fast knockdown and effective control of aphids and other pests. Second-tier aphid product. Slower knockdown, which may allow aphid populations to rebuild following treatment. Second-tier aphid product. Offers suppression of greenbug. Only applied by air; not user-friendly Second-tier aphid product. Offers suppression of greenbug. Second-tier aphid product. Offers suppression of greenbug. Carries Danger-Poison label Non-Chemical Alternatives There are currently no practical non-chemical control alternatives effective for management of aphids and midge in wheat. Grower Perspective In late, the EPA asked for public comments on issues related to the agricultural use of chlorpyrifos. Following is an excerpt from a grower 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 On wheat, chlorpyrifos at low rates provides a reasonable control method for an outbreak of Russian wheat aphid. Aphids can cause significant damage to wheat on our farm by reducing both yield and quality. North Dakota grower References 1. United States Department of Agriculture, Economic Research Services. March 23, Accessed April 3, May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 112

113 Glossary Glossary A abbreviation for acre and used as /A, to represent per acre. Active Ingredient The component which kills or otherwise controls or suppresses target pests. A pesticide product may contain one or more active ingredients, as well as one or more inert ingredients. Represents the cumulative acres treated with a single active ingredient. The same field can be treated more than once in a year with the same active ingredient. For products that contain more than one active ingredient, each ingredient is recorded separately as a single application to the same acres. For example, if a 20-acre field is treated with a product that contains three different pesticide active ingredients, a use report is filed by the farmer correctly recording the application of a single pesticide product to 20 acres. However, in the summary tables, the three different active ingredients will each have recorded 20 acres treated. Adding these values results in a total of 60 acres being treated instead of the 20 acres actually treated. Therefore, acres treated cannot be used to determine the total number of acres of a crop. a.i. abbreviation for active ingredient GPA abbreviation for gallons per acre Lb abbreviation for pound Number of Applications The total number of applications given for each crop may not equal the sum of all applications of each active ingredient on that crop. As explained above, some insecticide products contain more than one active ingredient. Pest Represents the cumulative acres treated with a single active ingredient for each target pest. The same field can be treated with one or more applications of an active ingredient to control multiple pests. For products that are used to control more than one pest, each target pest is recorded separately as a single application to the same acres. For example, if a 20-acre field is treated once with a broad spectrum pest control product targeting two different pests, a use report is filed by the farmer correctly recoding the application of a single insecticide product to 20 acres. However, in the summary tables, the two different pests will each have recorded 20 acres treated. Adding these values results in a total of 40 acres being treated instead of the 20 acres actually treated. Therefore, pest acres cannot be used to determine the total number of acres of a crop. May 18, 2009 Use and Benefits of Chlorpyrifos in U.S. Agriculture 113