UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C DEC i 4 20"

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1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C DEC i 4 20" OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION MEMORANDUM SUBJECT: BEAD Chemical Profile for Registration Review: Clothianidin (044309) FROM: THRU: TO: David Brassard, Senior Entomologist Pw ~ Biological Analysis Branch Rafael Prieto, Environmental Protection Specialist,IlL it J I fa. 'p ~ Science Information and Analysis Branch ~ Ltf ~ Derek Berwald, Economist Economic Analysis Branch Biological and Economic Analysis Division (7503P) Arnet Jones, Chief /.) ~ ~~ Biological Analysis Branch ~U Diann Sims, Chief. J~ Science Information and Analysis Branch,.. Timothy Kiely, Chief ~ DiviSiOn~) \ A ~ Economic Analysis Branch V"'-- Biological and Economic Analy' Russell Wasem, Chemical Review Manager Risk Management and Implementation Branch 1 Pesticide Re-evaluation Division (7508P) Product Review Panel date: December 7, 2011 INTRODUCTION The purpose of this document is to convey usage information and a broad overview of the pest management roles of pesticides that are beginning to undergo registration review. The anticipated audience consists of the team of EP A staff currently evaluating the registration status 1

2 of clothianidin (044309), and eventually the general public. This document builds upon the data already provided in the "Usage and Label Use Data Packages" that are also provided to Registration Review teams by BEAD. The document is based on infonnation and data available to BEAD as of November 31, Clothianidin is a nicotinoid insecticide which was first registered for use as pesticide in the United States in Nicotinoid insecticides are similar to and modeled after the natural nicotine. The nicotinoids act on the central nervous system of insects, causing irreversible blockage of the postsynaptic nicotinergic acetylcholine receptors (via a selective agonistic mechanism). The primary pests targeted for control with clothianidin include; wirewonn, seed maggot, rootwonns (com and western com), cutwonns, grubs, and European com borer. USE SITES Agricultural Use Sites Clothianidin is labeled for use on root and tuber vegetables, bulb vegetables, leafy vegetables (brassica and non-brassica), legumes, fruiting vegetables, cucurbits, citrus fruit, pome fruit, stone fruit, berries and small fruit, tree nuts, cereal grains, oilseed crops, and other unclassified crops (Table 1). T a bi e 1 R egis. t ere d U se S t I es fi or CI 0 tho lam d In b )Y EPA G roup S t Ie. Crop Group Site Crops Vegetable, root and tuber, group 01 Ginger, Turmeric, Turnip, Artichoke (Chinese, Jerusalem), Carrot, Dasheen, Potato, Sweet potato, Yam, Cassava (bitter, sweet), Arrowroot, Tanier, Leren, Chufa, Arracacha, Sugarbeet Vegetable, bulb, group 03 Leek, Bulb onion Vegetable, leafy, except bras sica, Celery, Radicchio, Com salad, Dandelion, Endive, Fennel, Cress (garden, group 04 upland), Parsley, Rhubarb, Spinach, Swiss chard, Lettuce (head, leaf), Cardoon, Chinese spinach, Amaranth, New Zealand spinach, Chervil, Arugula, Celtuce, Chrysanthemum, Dock, Orach, Purlane (garden, winter) Vegetable, brassica leafy, group 05 Broccoli, Brussels Sprouts, Cabbage, Cauliflower, Collards, Chinese cabbage (celery, napa, bok choy, mizuna), Kale, Kohlrabi, Mustard green, Rapeseed greens, Broccoli raab, Chinese broccoli, Chinese mustard, Mustard spinach Vegetable, legume, group 06 Soybean Vegetables, fruiting, group 08 Eggplant, Pepper (sweet, bell, chili, cooking), Tomato, Pepino, Tomatillo, Ground cherry Vegetable, cucurbit, group 09 Golden pershaw melon, snake melon, pineapple melon, santa claus melon, Cantaloupe, Casaba melon, Crenshaw melon, Honey ball melon, Honeydew melon, Muskmelon, Watermelon, Chinese waxgourd, Chinese cucumber, Cucumber, Pumpkin, Squash (scallop, straight neck, acorn, crookneck, summer, hubbard, winter, zucchini, spaghetti, hyotan butternut), Citron melon, Bitter melon, Balsam pear, Gourd, Gherkin, Mango melon, Chayote Fruit, citrus, group 10 Citron, Lemon, Lime Fruit, pome, group 11 Apple, Crabapple, Pear, Oriental pear, Quince, Loquat Fruit, stone, group 12 Peach Berry and small fruit, group 13 Blueberry, Cranberry, Grapes 2

3 Crop Group Site Nut, tree, group 14 Grain, cereal, group 15 Oilseed crop, group 20 No group name, group 99 Crops Almond, Brazil nut, Cashew, Chestnut, Hazelnut, Filbert, Hickory nut, Macadamia nut, Pecan, English Walnut, Butternut, Black walnut, Beech nut, Chinquapin Com (field, pop, and sweet), Millet (pearl, pro so), Barley, Oat, Rye, Wheat, Triticale, Teosinte, Buckwheat, Sorghum Canola, Com, Cotton Strawberry, Fig, Pomegranate, Artichoke (globe), Tobacco Non-Agricultural Use Sites Clothianidin is used on ornamentals, golf courses, airfields, airports, buildings, domestic dwellings, schools, playgrounds, and also on livestock pens and poultry houses. COMMON FORMULATIONS AND APPLICATION METHODS Clothianidin is formulated as a solid in several forms (granular, dust) and as solution in emulsifiable and flowable concentrate, soluble concentrate and as ready-to-use. Clothianidin is applied to agricultural crops as a foliar, soil, or seed treatment. USAGE Agricultural Usage Based on private market pesticide usage data from , on average, approximately 800,000 pounds of clothianidin was applied to 35 million acres per year (Proprietary Data, ). Since clothianidin was registered in 2003 usage has been increasing. Com is the largest market for clothianidin, accounting for 99% of the average pounds applied and acres treated from The states with the most agricultural usage in terms of pounds A. I. applied are Illinois (16%), Iowa (15%), Nebraska (9%), and Indiana (9%). These states also ranked similarly in terms of the total area treated. Non-Agricultural Usage BEAD reviewed available non-agricultural sources and found information was limited to use of clothianidin in golf courses, with 1,000 lbs. AI in (Kline Studies, Inc., 2006) USE TRENDS Figure 1 depicts usage trends, in terms of pounds applied, for clothianidin's largest agricultural markets. The use of clothianidin increased from 2004 through 2009, with a slight decrease in 2010 (Fig. 1). There is also a recent but minor increase in sugar beet use and other crops. 3

4 Figure 1. Usage trends ( ) in tenns of pounds applied for clothianidin main agricultural use sites. 1,400,000 o All Other Crops. Sugar Beets. Corn o Year , Proprietary Data Note: "All other crops" refers to Apples, Cotton, Grapes (Raisin, Table, Wine), Pears, Pecans, Potatoes, Sorghum (Milo), Soybeans, Squash, Wheat (Spring, Winter). BIOLOGICAL ASPECTS RELEVANT TO CLOTIDANIDIN One incident of resistance has been noted for clothianidin in the United States. Mota-Sanchez et al (2006) reported resistance and cross resistance to nicotinoid insecticides and spino sad in the Colorado potato beetle in Long Island, NY. The lack of additional resistance reports for the variety of registered crops indicates that insecticide resistance is not an issue with clothianidin at this time HISTORY OF BEAD ASSESSMENTS FOR CLOTIDANIDIN BEAD has reviewed the use of clothianidin four times in recent years in response to requests for a Section 18 emergency exemption. In 2009, BEAD concluded that clothianidin was an effective control of the exotic white grub in sweetpotato in North Carolina (Brassard and Ranville, 2009). The only other effective chemistry was a soil application of imidacloprid. The 125 day preharvest interval for imidacloprid was longer than the time between sweetpotato planting and harvest, making it infeasible. Non-chemical controls have not shown efficacy. Losses to the exotic white grub can range from 40-95% in the areas where it is a found. 4

5 In 2008, BEAD reviewed a request for an emergency exemption for use of a clothianidin seed treatment against seedcorn maggot, onion maggots, and thrips in leeks, bulb, and green onions in New Jersey (Cook and Faulkner, 2008). These pests had developed resistance against diazinon and chlorpyrifos, and resistance was developing in cryomazine. Cultural controls and other chemicals have proven to be ineffective against these early season pests. BEAD analysts concluded that yield loss in green onions and leeks can be 25-30% and yield losses of 10-20% were likely in bulb onions. For all three crops, BEAD found the situation met the criteria for a Section 18 exemption for the use of clothianidin.. Also in 2008, California requested use of clothianidin to control seedcorn maggot in onion seed in six counties (Kaul and Hill, 2008a). Seedcorn maggot was a relatively recent pest in California, causing damage early in the season. For two counties in Northern California, BEAD analysts concluded that loss estimates of 28-30% were reasonable estimates in the onion growing areas of Siskiyou and Modoc counties. On reviewing later evidence submitted by California, the conclusion was extended to the Central California counties of Kings, Monterey, Santa Clara and Stanislaus, where onion seed may also be grown (Kaul and Hill, 2008b). DATA NEEDS RELEVANT TO BEAD'S FUTURE WORK ON CLOTHIANIDIN Obtaining additional information on the following items would improve future BEAD assessments of the importance of Clothianidin and may be required as part of the registration review of this pesticide. U sage data associated with clothianidin use on ornamental plants and turf. Requested usage data should include use site, application rate, application method, timing of application, acres/area treated, and comparative efficacy to registered alternative insecticides. REFERENCES Brassard, D and M Ranville Review of Section 18 Submission from North Carolina for an Emergency Exemption for the Use ofclothianidin as a Soil Treatment on Sweetpotato to Control the Exotic White Grub, Plectris aliena (09NCOl; DP Number ), July 13,2009 Cook, C and J. Faulkner Review of Emergency Exemption Submission to Use Clothianidin on Onion and Leeks to Control Seedcorn Maggots, Onion Maggots, and Thrips in New Jersey (08NJOl, DP # , Decision # ), September 18,2008. Kaul, M. and E. Hill, 2008a. Review of the Emergency Exemption Request of California to Use Clothianidin to Control Seed Com Maggot in Onion Seed for Dry Bulb Onion Production. DP # , September 10,2008. Kaul, M. and E. Hill, 2008b. Supplemental to the Review of the Emergency Exemption Request of California to Use Clothianidin to Control Seed Com Maggot in Onion Seed for Dry Bulb Onion Production. (08CAI6) (DP # ), October 3,

6 Kline & Co., Inc., Mota-Sanchez, D., Hollingworth, RM, Grafius, EJ, Moyer, DD. (2006). Resistance and crossresistance to neonicotinoid insecticides and spinosad in the Colorado potato beetle, Leptinotarsa decemlineata (Say) (Coleoptera: Chrysomelidae). Pest Management Science, 62, Proprietary Data,