SFIREG Joint EQI/POM Committee Meeting April 10, 2018 Nan - PowerPoint PPT Presentation

SFIREG Joint EQI/POM Committee Meeting April 10, 2018 Nan Singhasemanon Environmental Program Manager Environmental Monitoring Branch California Department of Pesticide Regulation (CDPR)

Outline — CDPR Overview — CA Registration — Continuous Evaluation — Environmental Monitoring & Surface Water Protection — Fipronil Background — Data Collection & Analysis — Risk Management Decision — Mitigation Modeling — Stakeholder Engagement — Mitigation Proposal — Product Label Change — Outreach — Next Steps

CDPR Overview — CA SLA for FIFRA (part of CalEPA) — Implement & enforce FIFRA + CA statutory authority under CA Food & Agricultural Code — ~430 employees – headquarter in Sacramento — 6 branches in Pesticide Programs Division (PPD): — Registration — Environmental Monitoring — Worker Health & Safety — Human Health Assessment — Pest Management & Licensing — Enforcement — Funded by mil assessment on pesticide sales in CA

CA Registration — CDPR registers pesticide products to be sold & use in CA — Can only do so after EPA grants registration — But may review products for CA registration sequentially or concurrently — CDPR’s Product Registration Branch oversees this registration evaluation process & coordinates review by PPD branches — Includes Environmental Monitoring Branch (EMB) — EMB evaluates products for potential for environmental impacts (Air, Groundwater & Surface Water) – often rely on models — Can influence product label at this stage prior to CA registration to manage CA-specific eco-risks — Preventative risk management — Powerful tool

CA Continuous Evaluation — DPR also continuously evaluates pesticide products after registration is granted for environmental impacts from their use — Continuous Evaluation = environmental monitoring = safety net — Some products & associated active ingredients (A.I.’s) may move off-site based on labeled-use perhaps at levels that may cause significant adverse impacts to the environment — EMB scientists lay out risk picture for CDPR management — If CDPR management finds risk to be too high → mitigation — EMB scientists assist in finding appropriate risk mitigation tools/solutions → collaborative problem solving — Engage stakeholders — Finalize mitigation approach — Implement solution — Conduct outreach — Monitor for effectiveness (i.e., back to continuous evaluation)

Fipronil Case Study

Fipronil Background — Fipronil - insecticide/termiticide, first registered in CA in 1997 → ant baits (very low A.I.%) — Works on GABA receptors of insects — Causes excessive neural excitation → paralysis → death — Currently 153 products registered — Primary uses in CA today: Treatment in and around structures for termites, ants & other insect pests; also pet spot-on for fleas and ticks — % A.I. range: 0.00045 – 9.8%, many formulations — New uses sought post-1997. SWPP resistant in recommending registration initially due to toxicity to aquatic invertebrates, mobility, persistence & degradate concerns

Fipronil Background – cont. — 1999 crayfish mortality in Louisiana rice growing regions → CDPR did not grant registration on CA rice — Homeowner use sought in CA 2002 → CDPR did not grant registration — Several granular product registrations sought ~2000 -2004 → registration granted after data submissions w/ conditions — Use in Coachella Valley only (fire ant) — Restricted to driest months (April–Sept.) — For pest control operator (PCO) use only

Fipronil Background – cont. — Structural perimeter spray use for non-termiticide insect control by PCO’s appeared ~2003? — This new use pattern = mixing of liquid concentrate mainly for ant control on outdoor impervious surface — CA urban areas are notorious for being heavily paved → urbanization + flood control — Urban pest control A.I. shift post diazinon & chlorpyrifos home & garden use → voluntary cancellation by registrants ~2003 — Pyrethroids & fipronil became main replacements

CA Structural Pest Control Fipronil Use Fipronil Use (lbs A.I. used in CA) from 2008-2015 100000 90000 80000 70000 60000 50000 40000 30000 20000 10000 0 2008 2009 2010 2011 2012 2013 2014 2015 Source: CDPR Pesticide Use Data

CDPR’s Surface Water Protection Program (SWPP) 11

SWPP Monitoring — 4 distinct urban and agricultural watersheds monitoring projects: NorCal/SoCal urban & NorCal/SoCal ag — Receiving water + “edge-of-field” samples — Water, sediment & toxicity samples — Monitoring protocols & data reports generated annually — Site & analyte monitored change annually based on our Surface Water Monitoring Prioritization (SWMP) Model — Data → upload to SURF database → analysis

Monitoring Prioritization

CDPR Urban Monitoring Locations Urban maps & data - credit Robert Budd, CDPR SWPP

Locations & Timing Storm Drain Receiving Water Dry Season Rain Event

Detection Frequencies & Benchmark Exceedances

Site Type 1.00 0.50 Stormdrain Receiving Waters Concentration (ug/L) 0.15 0.10 0.05 0.00 Bifenthrin Bifenthrin Fipronil Fipronil Credit: Robert Budd Data queried Feb 13, 2018

Event Type 1.00 0.50 0.30 Concentration (ug/L) Dry Season 0.25 Storm 0.20 0.15 0.10 0.05 0.00 Bifenthrin Bifenthrin Fipronil Fipronil Credit: Robert Budd Data queried Feb 13, 2018

Regional Differences 1.50 1.00 NorCal 0.50 Concentration (ug/L) SoCal 0.15 0.10 0.05 0.00 Bifenthrin Bifenthrin Fipronil Fipronil Credit: Robert Budd Data queried Feb 13, 2018

Monitoring Findings — SWPP released Feb. 2016 data analysis report — Over 500 water samples from storm drains & urban receiving waters between 2008 & 2015 — Fipronil found in ~50% of samples — EPA aquatic life benchmarks (BMs) = 0.11 ppb (invert. acute), 0.011 ppb (invert. chronic) — Statewide receiving water conc. > acute BM = 15% of samples, > chronic BM = 48% — Degradates: f. sulfone & f. desulfinyl detected 43 & 33%, respectively. — F. sulfone > acute BM = 1%, > chronic BM = 37%

Label Review — Most products are for flea/tick control for pet uses — No Ag products in CA — No homeowner/consumer use products (except containerized baits) — Some outdoor termiticide use (underground injection) but use small & low runoff risk — 99% of reported use → structural pest control → outdoor perimeter spray use for general insect control = ants — Only 2 products fit this use pattern → BASF Termidor SC & CSI Taurus SC

Modeling to Validate Real-World Baseline — ? Is it plausible that the perimeter spray use pattern could generate conditions seen in receiving waters ? — SWPP has a CA-specific pesticide runoff PRZM- VVWM model (based on EPA’s model) — Been using for registration evaluations — Fipronil modeling incorporated more “real-world” input data, including industry survey data — Also used application instructions from labels — Apply 2 quarts of 0.06% finished spray (low-pressure) per 160 linear feet as perimeter spray, 1’ up & 1’ out, 2 times/year

CA Urban module: USEPA residential settings 58 residential lots (1/4 acre each) in a 10-ha watershed, runoff routed to a 1-ha pond Ref: USEPA, 2007, https://www3.epa.gov/pesticides/endanger/ litstatus/effects/redleg-frog/carbaryl/determin-memo.pdf

Fipronil Modeling Results vs. Monitoring Data 78% Reduction in modeled EEC needed to meet acute EPA BM Credit: Yuzhou Luo, CDPR SWPP

Risk Management Decision — In July 2014, (24) registrants of (109) fipronil containing products were informed initially of CDPR’s concerns — Based on early monitoring data — Early conversations took place w/ potentially affected parties — Municipal stormwater programs — CA clean water agencies (State & Regional Water Boards) — Pest Control Operators of CA — EPA — Did not choose CA data call-in → reevaluation

Department of Pesticide Regulation Mitigation of Fipronil Timeline Early Stakeholder Engagement Stakeholder (EPA, Water Boards/ CASQA, PCOCs) Mtgs July Oct Nov ^ Jan Feb May ^^ Jul Oct Nov Dec Jan Feb May Jun Jul Aug Sep Oct Nov Dec 2014 2015 2016 DPR Planning SWBs/ DPR/ BASF Mtg DPR EPA Mtg Mtg (2) CASQA Mtg May 11, 2016 Oct. 28, 2014 DPR Fipronil PCOC Mtg Oct. 9, 2015 (Urb) Mitigation DPR Registrants Mtg Nov. 16, 2015 Planning Mtg May 4, 2016 draft Fipronil Mitigation Feb. 19, 2015 Fipronil Monitoring & Model Scenarios Doc Concepts Document (Regs, PCOCs, EPA, WQRs) DPR Mtg w/ Fipronil Registrants (Urban + Waste) July 23, 2014 Water Quality Regulators (WQRs) Mtg Rulemaking Drafting Stakeholder Outreach/ Input Mit. Concept Document Drafting Research & Information Gathering Nov ^ Washoff (Fipronil) Study started (Anticipated completion Spring 2016) May ^^ Field (Urban Outdoor) Application Research Trials started (Anticipated completion Fall 2016) (rev.7/5/16) 1