· Web viewTrifluralin is one choice among other numerous synthetic pesticides. Parties and...

Exploration of management options for Trifluralin

May 2010

Prepared by:

BiPRO GmbH

Table of Content

Executive Summary....................................................................................................................................3

1 Introduction....................................................................................................................................5

2 Characteristics of Trifluralin.............................................................................................................7

2.1 Definition..................................................................................................................................................7

2.2 Names, registry numbers and formula.....................................................................................................7

2.3 Chemical and physical properties.............................................................................................................8

3 Current sources of emission.............................................................................................................9

3.1 Emissions from production and use.........................................................................................................9

3.2 Unintentional emissions.........................................................................................................................14

3.2.1 Emissions from manufacturing processes of products containing the substance..................................................14

3.2.2 Emission from use of products containing the substance......................................................................................14

3.2.3 Emissions from waste containing the substance, historic emissions......................................................................14

3.2.4 Emissions from recycling and dismantling activities...............................................................................................14

4 Management options....................................................................................................................15

4.1 Overview of existing legislation in the UNECE region.............................................................................15

4.1.1 Substitution, alternatives and emission control techniques...................................................................................16

4.1.2 Redesign of product or process..............................................................................................................................24

4.1.3 Possible adverse effects of substitutes...................................................................................................................26

4.2 Possible management actions................................................................................................................26

4.3 Cost implications....................................................................................................................................27

4.3.1 Cost implications for eliminating production and use............................................................................................28

4.3.2 Cost implications for controlling unintentional emissions......................................................................................36

4.3.3 Cost implications for consumers............................................................................................................................36

4.3.4 Cost implications for state budgets........................................................................................................................36

4.4 Possible management options under the UNECE POPs Protocol...........................................................37

4.4.1 Options...................................................................................................................................................................38

4.4.2 Discussion of the options........................................................................................................................................38

References................................................................................................................................................41

Annex.......................................................................................................................................................49

2

Executive Summary

Trifluralin is a synthetic fluorinated dinitroaniline herbicide. It was first registered in 1963 and is marketed in a number of formulations, often in combination with other active ingredients. Currently the substance is widely registered for use throughout the world although the registration within the EU was withdrawn in autumn of 2009.

Production, use and emissions

Trifluralin is produced in a number of countries inside and outside the UNECE region including inter alia Hungary, Italy and the USA as well as Argentina, Australia and China.

The herbicide trifluralin is used to control annual grasses and broad-leaved weeds in agriculture, horticulture, viticulture, amenity and home gardens. The major crops, on which it is used, are oilseed rape and sunflowers and, to a lesser extent, cotton and cereals as well as some other minor uses.

Emissions

Given the specific herbicidal uses of trifluralin, all of the applied amounts are emitted to the environment through its agricultural use. Further, emissions from production arise from discharges, losses and emissions from waste and waste water.

Trifluralin is incorporated as a usual agricultural practice into the soil and therefore shows small immediate loss into the air. However, if trifluralin is applied to the soil surface without incorporation, the majority of the substance volatilises into the atmosphere due to its high vapour pressure.

Management options

Substitution and alternatives

Trifluralin is one choice among other numerous synthetic pesticides. Parties and observers reported several chemical and non-chemical alternatives to trifluralin. In addition to several chemical alternatives also non-chemical alternatives such as integrated pest management, organic farming and other specific agricultural practices seem to be a good option to reduce and prevent the need for trifluralin or other chemical alternatives. It was also reported from several countries that for some crops there is no need for chemical alternatives. For other crops different combinations of herbicides in combination with application of other agricultural practices would be an appropriate alternative to the use of trifluralin (e.g. [PT Reply 2010]; [SI Reply 2010]).The USA has indicated that no cost impacts are expected from the inclusion of trifluralin to the POPs protocol [UNECE 2010, USA].

In contrast, other parties and stakeholder reported the crucial importance of trifluralin as a low cost herbicide applied for specific grass and weed controls for which mainly more expensive synthetic pesticides would be available and would lead therefore to significant cost impacts ([UNECE 2010, Dow II]; [UK Reply 2010]; [Defra 2006]).

Information on several risk indicators for possible adverse effects of available chemical alternatives indicates

that trifluralin would be replaceable by safer chemical alternatives.

Cost implications

3

Cost impacts on industry are expected to be nil to negligible in countries where trifluralin is not produced or already banned. Non-quantified annual losses for manufacturers would occur in countries where trifluralin is still produced. It is expected that globally the losses will be more or less outweighed by sales of chemical and non-chemical alternatives

Annual cost impacts on agricultural production are expected to amount up to 10.86 million USD. Due to possible price increases of agricultural products the annual cost impacts for consumers could amount up to 10.86 million USD.

One time administrative costs for governments and authorities could range from 0.15 to 0.83 million USD considering UNECE countries where trifluralin is not yet banned for redrafting and reissuing of guidance and notifying of regional authorities. One time costs for the management of stockpiles range from about 18,800 to 45,200 USD for residues from known use quantities in the UNECE region.

Trifluralin causes significant adverse effects on human health and the environment. As a consequence it can be expected that its current use causes significant non quantifiable environment and health costs.

Possible management options under the UN-ECE POP protocol

If the use of trifluralin according to current restriction to specific uses and use conditions will continue, emissions from production and use of trifluralin will continue in many UNECE countries. A possible management option is to list trifluralin in the UNECE POP protocol in order to eliminate or reduce its production and use throughout the UNECE region and thus related emissions and possible risks for health and environment.

Option 1: listing trifluralin in Annex I of the POPs protocol in order to eliminate its production and use

Option 2: listing trifluralin in Annex II of the POPs protocol and to specify allowed uses and related conditions in the implementation requirements

It is suggested to add trifluralin as a substance to Annex I, to end production and use of trifluralin.

4

1 Introduction

In 2007, the European Commission, DG Environment, prepared a dossier in support of a proposal for Trifluralin to be considered as a candidate for inclusion in the Annex I of the Protocol to the 1979 Convention on Long-Range Transboundry Air Pollution on Persistent Organic Pollutants (LRTAP Protocol on POPs).

The UNECE Task Force on POPs (TFPOP) reviewed the proposal in its seventh meeting in June 2009 and agreed that trifluralin fulfils POP criteria. Therefore, a management option dossier should be developed on trifluralin for consideration of the next UNECE task force meeting.

Furthermore, an addendum to trifluralin was elaborated as Canada raised some concerns at the September meeting of the Working Group on Strategies. Additional information has been provided and assessed with regard to the bioaccumulation potential of trifluralin and monitoring information in remote area for trifluralin.

At the 26th session of the Executive Body of the Convention in December 2009, the Parties to the 1998 Protocol on POPs took note of the conclusions of the Task Force and recommendations of the WGSR on trifluralin. It was agreed that for trifluralin further risk assessment is needed. Therefore, the TFPOP was requested to continue with the Track A review for trifluralin and additionally with the Track B review to explore management strategies for trifluralin. In order to gather further information and to explore management options, a questionnaire should be circulated to relevant contacts of Parties to the Convention and other stakeholders. It aimed at gaining a better view on management strategies and options in the UNECE region.

This document “Exploration of Management Options for Trifluralin” reports on management options for trifluralin. It is mainly based on the information provided in the dossier which was prepared by the European Commission. Further, sources which were available in literature and on the internet were reviewed to incorporate new information.

This document is mainly based on information from the Trifluralin Risk Profile prepared by the European Commission [UNECE 2007], the OSPAR background document on trifluralin [OSPAR 2005] and the peer review of the pesticide risk assessment of the active substance trifluralin elaborated by EFSA [EFSA 2009]. Further reference documents are listed under ‘References’.

The questionnaire was sent to the Parties to the LRTAP Convention and to a group of stakeholders from industry. The results and information on trifluralin available from the questionnaire are included in the present report. As the information on alternative substances and production technics was very limited an additional query was sent to EU Member State authorities. A number of chemical alternatives to trifluralin were reported and essential data were submitted for the cost impact analysis.

From the 51 UNECE Member States contacted 211 answers to the UNECE questionnaire survey were received. In addition, 52 stakeholders replied to the questionnaire of which the answers of the Dow AgroSciences LLC and the Utility Solid Waste Activities Group (USWAG) were relevant for trifluralin ([UNECE 2010, Dow I], [UNECE 2010, Dow II], [UNECE 2010, USWAG]). However, for the evaluation of management options only the information submitted by Dow AgroSciences LLC [UNECE 2010, Dow II] was relevant.

1 Belgium, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Italy, Ireland, Netherlands, Norway, Slovenia, Spain, Sweden, Switzerland, Ukraine, USA, UK.

2 ANAPE (Plastics National Association), Cefic, Dow Chemical, EBFRIP (European Brominated Flame Retardant Industry Panel), PCP Task Force, USWAG (Utility Solid Waste Activities Group)

5

Furthermore, information on trifluralin was submitted on request by other institutions, mainly agricultural ministries of different Member States.3

About this document

This document gives information on the substance under consideration (chapter 2), gives an overview of the known use and sources of emissions in the UNECE region (chapter 3), and presents information on management options (chapter 4).

3 Austria, Czech Republic, Denmark, France, Germany, Greece, Lithuania, Netherlands, Portugal, Romania, Slovenia, Slovak Republic and UK.

6

2 Characteristics of Trifluralin

2.1 Definition

Trifluralin is a synthetic fluorinated dinitroaniline herbicide which is used in the control of annual grasses and broad-leaved weeds in agriculture, horticulture, viticulture, amenity and home gardens. The major crops on which it is used, are oilseed rape and sunflowers and, to a lesser extent, cotton and cereals (quoted from [UNECE 2007]).

2.2 Names, registry numbers and formula

CAS chemical name

2,6-dinitro-N,N-dipropyl-4-(trifluoromethyl)benzenamine

Synonyms

Trifluralin (ISO 1750)

α,α,α-Trifluoro-2,6-dinitro-N,N-dipropyl-p-toluidine (IUPAC)

Benzenamine

2,6-Dinitro-N,N-dipropyl-4-(trifluoromethyl)-benzenamine

2,6-Dinitro-N,N-dipropyl-4-trifluoromethylaniline

Trade names

Agriflan; Agriflan 24; Crisalin; Digermin; Eloncolan; Ipersan; Ipifluor; L 36352; Lilly 36,352; Nitran; Nitran K; Olitref; Su Seguro Carpidor; Sinflouran; Synfloran ;TR-10; Trefanocide; Treflan; Treflan EC; Treflan-R; Treficon; Trifloran; Trifluraline; Triflurex; Triflurex 48EC; Trikepin; Trim; Tristar.

In addition, formulations containing trifluralin (alone or together with other active ingredients) are marketed under many different names. These include: Portman Trifluralin; Ardent; Tandril 48; Axit GR; Das-320; Premiere; Alpha Trifluralin 48 EC; Arizona; Blois; O-Tan; Sword; Uranus; Zimbali; Autumn Kite; MAGDELIN; Snitch; Triflur; Trimaran; Digermin; Triplen; Hawk; Reserve; Trilogy.

CAS registry number

1582-09-8

Former CAS registry numbers

39300-53-3; 52627-52-8; 61373-95-3; 71281-30-6; 75635-23-3

7

Formula

C13H16F3N3O4

2.3 Chemical and physical properties

The chemical and physical properties of trifluralin are listed in Table 2-1.

Table 2-1: Physical and chemical properties of trifluralin

Property Unit Value ReferenceMolecular formula C13H16F3N3O4 [OSPAR 2005]Molecular mass g/mole 335.28 [OSPAR 2005]Appearance at normal temperature and pressure

bright orange crystalline solid [OSPAR 2005]

Vapour pressure Pa9.5 x 10-3Pa at 25 °C (100% pur.)6.1 x 10-3Pa at 25 °C (96.8% pur.)

[OSPAR 2005]

Water solubility

g/l g/l

mg/lmg/lmg/l

1.94 x 10-4 (unbuffered 100% pur.)pH 7: 2.21 * 10-4

pH 5: 0.184pH 7: 0.221pH 9: 0.189

[OSPAR 2005][OSPAR 2005]

[Health Canada 2008]4



Melting point °C 43.0-47.5 °C [OSPAR 2005]Boiling point °C not determined, decomposition [OSPAR 2005]Log Kow - 5.27 at 20 °C (100% pur.) [OSPAR 2005]

Log Koc [l/kg]4.13 (calc.)

3.81-4.13 (meas.)no pH-dependency

[OSPAR 2005]

Henry´s Law Constant Pa m3/mol19 x 10-3 (calc.)

4.12 x 10-3 (meas. 20 °C)15 Pa m3 mol-1

[OSPAR 2005][OSPAR 2005]


Atmospheric OH Rate Constant cm3/molecule-sec 24.0039 x 10-12 5 [EU DAR 2005]

4 http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_prvd2008-22/index-eng.php#additional, March 2010

5 Reactivity with OH-radicals atmospheric half-life [d] is given by [OSPAR 2005] as 0.22 d. The half life calculated from the figure shown in the table is 0.446 d.

8

http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_prvd2008-22/index-eng.php#additional

3 Current sources of emission

3.1 Emissions from production and use

Production

Countries and production sites for trifluralin are Argentina (Atanor), Australia (Nufarm), Brazil (Defensa Industria de Defensivos), China (Zhejiang Dongyang Pesticide Factory), Guatemala (Agrotran SA), Hungary (Budapest Chemical Works), Italy (Dintec Agroquimica, Milan), South Africa (Sanachem, Canelands) and USA (Eli Lilly (Dintec Agroquimica)) [Fluoride Action Network 2006], UNECE countries are bold). According to the US EPA (1996), the main producers are DowElanco (Indiana, USA), Makhteshim-Agan (Israel), Industria Prodotti Chimici S.P.A (I.Pi.Ci.) (Italy), Tri Corporation (Texas, USA) and Albaugh Inc. (Missouri, USA).

The annual worldwide production in 1991 was between 20,000–25,000 tonnes [IARC 1991].

Precise information on current production is not available. However, as trifluralin is banned in the European Union since 2009, the demand within the UNECE region decreased.

According to the USA trifluralin is produced by Dow Agrosciences LLC (Trade name: Trifluralin Technical; intended use: formulate into end use product), Aceto Agricultural Chemicals Corp (Trade name: Trifluralin Technical; intended use: formulate into end use product), Drexel (Trade name: Drexel Trifluralin 96% Technical, Drexel Trifluralin Technical II, DrexelITRifluro Technical; intended use: formulate into end use product), Atanor S.A (Trade name: Albaugh Trifluralin Technical; intended use: formulate into end use product) and Dintec Agrichemicals (Trade name: Technical Trifluralin; intended use: formulate into end use product) [UNECE 2010, USA].

Trifluralin is produced for the global market for use as herbicide by FINCHIMICA S.p.A., Via Lazio 13, Italy ([UNECE 2010, Dow I]; [UNECE 2010, Dow II]).

Trifluralin production stopped in the Netherlands and in Denmark [UNECE 2010]; [DK Reply 2010]. 6 In 2008 the production of trifluralin ended also in Spain due to Commission Decision of 20 September 2007 concerning the non-inclusion of trifluralin in Annex I to Council Directive 91/414/EEC and the withdrawal of authorisation for plant protection products containing the substance [UNECE 2010, ES];. In France, the production of trifluralin stopped in 2000 [UNECE 2010 FR].

Trifluralin has never been produced in Canada, Croatia, Cyprus, Estonia, Germany, Ireland and Sweden [UNECE 2010, CA, CR, CY, EE, DE, IE, SE]. In the Czech Republic the substance is currently not produced. It is not known whether it has been produced [UNECE 2010, CZ]. In the USA production stopped in the 1980ies [UNECE 2010, CA, USA].

Switzerland has no information whether trifluralin has ever been produced within the country [UNECE 2010, CH].

Ukraine continues with the search of corresponding information and will provide additional data if available [UNECE 2010, UKR].

Use

Trifluralin is a herbicide for pre-sowing or pre-emergence treatment of grasses and dicotyledonous weeds. A rate of 1200 g active substance per hectar, using 150–500 L/ha, is usually applied. The US EPA calculated

6 It was not indicated in which year the production of trifluralin stopped.

9

workers exposure based on assumed maximum trifluralin application rates of 2.24 kg a.i./ha and maximum area treated per day of 325 ha by air and 32.5 by ground. 1 The major crops for which trifluralin is applied are oilseed rape and sunflowers. In addition, it is used to a lesser extent for weed control in cotton and cereals. There are other minor uses in a wide range of agricultural and horticultural crops including vegetables. Non-agricultural uses of trifluralin are not known ([OSPAR, 2005], [UNECE 2007]).

Currently in the USA trifluralin is used in an amount of 2,500 to 3,000 t/a [UNECE 2010, USA]. The use generally appears to be declining. [UNECE 2010, USA]. The use of trifluralin in California in 2005 was over 500 tonnes [PAN 2007]. Prior to the ban in the EU, approximately 3,200 tonnes active substance trifluralin have been annually used in the EU [OSPAR 2005].The following amounts have been used in Belgium (15.1 t/a), France (1,600 t/a), Germany (< 102 t/a), Switzerland (0.5 t/a) and UK (657 t/a) [OSPAR 2005]. Denmark reported minor uses for seed production (2002, 19 kg) as a derogation to the ban of trifluralin in this country. In Finland, uses oscillate around 16 t/a with a minimum in 1997 (6 t) and a maximum in 2002 (20 t) [OSPAR 2005].According to industry, sales of trifluralin remained in the past years at a constant level of this amount in Europe until its cessation ([UNECE, 2007]; [OSPAR 2005]). In Switzerland 1.97 t were used in 2008 [UNECE 2010, CH].

Trifluralin is registered for use in Canada on ornamentals, shelter belts, terrestrial food/feed crops, oil seed and fiber production crops [UNECE 2010, CA]; [Brimble et al. 2005]; [Donald, D. et al. 1999]. According to Brimble et al. 2005 annual use of trifluralin in Canada amounted to approximately 320 tonnes in the time period around the year 2000. Use quantities in North America are decreasing [UNECE 2010, Dow II]. Sales in 2006 amounted to 214 tonnes7. Specific information on current use quantities is not available.

In Germany, Finland, France, Ireland and Spain the use of trifluralin stopped in 2008 [UNECE 2010, DE; ES, FI, FR, IE].

In Croatia, Cyprus, Czech Republic and Estonia the use of trifluralin as an active ingredient in pesticides in the agricultural sector of plant protection stopped in 2009 [UNECE 2010, CR, CY, EE]. In the Czech Republic trifluralin was used as herbicide in amount of about 100 t/a [UNECE 2010, CZ].

Slovenia reported that triflrualin has never been used [UNECE 2010, SI]. However, within the additional query for information it was reported that in Slovenia trifluralin was registered for use in following crops: carrots, peppers, cabbage, cauliflower, onion, beans, tomatoes, sunflowers, soya, cotton, oil rape.

In Sweden its use stopped in 1990 [UNECE 2010, SE].

Ukraine continues with the search of corresponding information and will provide additional data if available. According to the Ministry of Health, the substance is currently not included into the list of pesticides banned for use in agriculture, registration and re-registration [UNECE 2010, UKR].

Although there are 8 technical registrations, Dow AgroSciences LLC is the primary producer in the USA. In addition, there are well over a 100 end use products containing trifluralin registered in the USA. These products range from containing 0.2 % to 60% active ingredient [UNECE 2010, USA].

In the USA trifluralin is used in the agricultural sector for cotton (amount: 1,000-1,500 t/a in 2006-2008), soybeans (500-700 t/a in 2006-2008), alfalfa (150-200 t/a in 2006-2008), in numerous other crops (400-600 t/a in 2006-2008) and turf/ornament uses in the mid-1990s (industrial sector: turf/residential, amount: 50-100 t/a). Use appears to have declined to about 75% of its mid-1990s use levels [UNECE 2010, USA].

Dow AgroSciences LLC is using/processing the substance as the active ingredient in several herbicide products which are sold to different countries. In consequence of the Commission Decision of 20 September

7 According to Health Canada at the TFPOP meeting, Montreal, 18 to 20 Mai 2010

10

2007 concerning the non-inclusion of trifluralin in Annex I to Council Directive 91/414/EEC the global demand of trifluralin decreased [UNECE 2010, Dow I].

Table 3-2: Known use of trifluralin within the UNECE region in 2010

UNECE Parties Current use of trifluralin in t/a SourceEU Member States 0 DecisionCH 1.97t/a [UNECE 2010, CH]Norway 0 [UNECE 2010, NO]USA 2,500-3,000 [UNECE 2010, USA]Other UNECE Parties No data available n.a.

Emissions

Given the specific herbicidal uses of trifluralin, practically all amounts produced are ultimately released to the environment [UNECE 2007]. The herbicide is usually incorporated into the soil and has with this application a loss of < 2% in 24 hours. Considering an annual use of 3,200 tonnes of trifluralin in the past years in whole Europe and an evaporation of 2% from agricultural use a load to air of about 64 t/a can be estimated until the withdrawal of trifluralin in the EU. This is the case when trifluralin is mainly used in oilseed rape and sunflower with incorporation into soil. However, in case trifluralin is applied to the soil surface without incorporation, a large amount (approximately 60% in 24 h) will volatilise into the atmosphere due to the vapour pressure of 9.5 * 10-3 Pa. This is particularly relevant when the substance is applied directly to uncultivated soil without incorporation (only in cereals). During the autumn application, evaporation rather than photodegradation is mainly responsible for the loss from the soil surface without incorporation [OSPAR 2005].

The European Pollutant Release and Transfer Register (E-PRTR)8 covers the 27 EU Member States as well as Iceland, Liechtenstein and Norway. The register contains annual data reported by some 24.000 industrial facilities covering 65 economic activities within 9 industrial sectors. Data regarding releases to air, water and land is provided in the register for 91 pollutants including trifluralin. According to E-PRTR in 2007 no releases of trifluralin to air and soil occured. Three sites reported releases to soil amounting to a total of 83.7 kg. The reporting sites were located in Italy (81.1 kg), Spain (1.53 kg) and the United Kingdom (1.16 kg). The highest amount of trifluralin (81.1 kg) was released during industrial scale production of basic pharmaceutical products (chemical industry) followed by incineration of non-hazardous waste included in Directive 200/76/EC (1.52 kg) and waste-water treatment (1.16 kg) [E-PRTR 2010].

Belgium reported the following data with regard to release to the environment: Flanders has a specific legislation on soil management and remediation. In the framework of this legislation there is an obligation to investigate the soil and groundwater at certain moments, e.g. at the moment of property transfer or closure of an exploitation. The obligation exists only for sites on which certain activities take or have taken place. The exploratory investigations include a limited investigation in the past history of the soil, as well as a restricted sampling. All substances of which can be assumed that the might have caused soil or groundwater contamination, are analysed. E.g. substances used in production processes that take place or have taken place on the site. For the new POPs considered, investigation and analysis is needed when those substances are produced or used in a production process on the site, or when stored on the site. For the normal use in agricultural and horticultural practice, there is no obligation for soil investigation and analysis. The Soil Management Department of the OVAM is responsible for the implementation of the Soil Decree and has a database with all information collected in this legislative framework. To remediate soil and groundwater

8 http://prtr.ec.europa.eu/PollutantReleases.aspx , March 2010

11

http://prtr.ec.europa.eu/PollutantReleases.aspx

contaminated with the new POPs including trifluralin the usual remediation technologies are applied. More information is available on the website [UNECE 2010, BE].9

France reported that no trifluralin has been released in 2007 to water likely to product synthesis.10 In 2007 an estimated quantity of 1,000 t has been released to soil likely to use in the field scale as well as several tonnes in 2006 to air due to volatilisation of products used (quantified through sample analysis). Distribution between air, water and soil after crop treatment is unknown. A high probability for a release into air was mentioned [UNECE 2010, FR].

In Ireland about 6,167 kg trifluralin used as agricultural herbicide has been released to soil in 2006, 8,602 kg in 2007and about 7,065 kg in 2008 (quantities imported into the country) [UNECE 2010, IE].

The UK reported input of trifluralin in rivers (lower input level did not exceed 100 kg/a; upper input level of about 0.25 t/a (1991- 1997)) which increased to 0.56 t/a in 1999 in total [OSPAR 2005]. In Germany, a total input of trifluralin to rivers by run-off of about 1 kg/a in 1999 was reported [Böhm et al. 2002].

Further emissions may occur on the level of farms through the cleaning of spraying equipment. Böhm et al. (2002) identified this as the major source of surface water contamination with pesticides in general. In addition, it seems to be the only pathway for trifluralin to sewage treatment plants. However, trifluralin has not been reported in sewage treatment plants (except for the production site in Manerbio, Northern Italy) [UNECE 2007].

Until 2009 in Czech Republic trifluralin was released to soil in an annual amount of about 100 t [UNECE 2010, CZ]. In Finland, trifluralin was released to soil as a result from herbicidal uses in increasing annual amounts until 2008 (2004: 17,364 kg, 2005: 29,477.00 kg, 2006: 33,747.00 kg, 2007: 37,738.00 kg, 2008: 0 kg) [UNECE 2010, FI].

In Germany about 1 kg trifluralin was released to water due to surface run-off events in 2003.11

Scientific publications have reported the detection of trifluralin in Spanish surface water at low ng/l level (< 50);[Planas et al. 2006] (< 20 ng/L) in the Ebro river [UNECE 2010, ES]; [Claver et al. 2006].

In Switzerland, the total amount of used trifluralin (1,970 kg) in 2008 was released to the environment. Information on groundwater concentrations is available for 2002/2003 in the NAQUA report on national groundwater monitoring.12

Trifluralin has not been found in Sweden in any environmental sample at levels above the limit of quantification (water: 0.01 μg/l, sediment: 3 ng/g dry weight, biota: 0.05 µg/g lipid) [UNECE 2010, SE].

Ukraine continues the search for corresponding information and will provide data if available [UNECE 2010, UKR].

9 www.ovam.be, March 2010

10 http://www.pollutionsindustrielles.ecologie.gouv.fr/IREP/index.php, February 2010

11 http://www.umweltdaten.de/wasser/themen/stoffhaushalt/trifluralin.pdf.

12 http://www.bafu.admin.ch/publikationen/publikation/00371/index.html?lang=de.

12

http://www.pollutionsindustrielles.ecologie.gouv.fr/IREP/index.php

http://www.ovam.be/

3.2 Unintentional emissions

3.2.1 Emissions from manufacturing processes of products containing the substance

Emissions from the production process of trifluralin are known as discharges, losses and emissions from waste and waste water, e.g. the Manerbio site discharged waste water containing trifluralin up to 50 μg/l into the river Mella. Alternatively wastewater containing halogenated pesticides up to 50 μg/l was discharged into the sewage system. Emissions may arise in high extent when mechanical failures occur [OSPAR 2005].

3.2.2 Emission from use of products containing the substance

Practically all amounts produced are ultimately released to the environment (see chapter 3.1; [UNECE 2007]; [INERIS 2007]).

3.2.3 Emissions from waste containing the substance, historic emissions

Emissions have been observed in waste waters. Further, liquid or solid waste was stored for burning or disposal by licensed waste treatment companies in the case of a production facility in Italy. The manufacturing equipment of the Drusenheim (France) facility housed on retained areas from which all liquid was collected and incinerated in a dedicated special facility on site [OSPAR 2005]. For more details see E-PRTR data included in chapter 3.1. The respective sites which reported releases of trifluralin to soil working in the field of waste or waste water management are located in Spain (1.53 kg) and the United Kingdom (1.16 kg).2

Another possibility for emissions from waste is the disposal of incompletely emptied containers.

3.2.4 Emissions from recycling and dismantling activities

Emissions from recycling and dismantling activities are not relevant.

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4 Management options

4.1 Overview of existing legislation in the UNECE region

Canada

Trifluralin is registered to be used in Canada ([UNECE 2007]; [UNECE 2010, CA]). Currently, 18 products containing trifluralin as active ingredient are registered in Canada [Health Canada, PMRA 2010]. These substances have to be re-registered every five years. Failure to re-registration may result in the product not being eligible for renewal [Health Canada 2010]. After a re-evaluation of the herbicide trifluralin, Health Canada’s Pest Management Regulatory Agency (PMRA), under the authority of the Pest Control Products Act and Regulations, has granted continued registration of products containing trifluralin for sale and use in Canada in September 2009 with its Re-evaluation Decision RVD2009-09. An evaluation of available scientific information was regarded to proof that products containing trifluralin do not present unacceptable risks to human health or the environment when used according to label directions. As a condition of the continued registration of trifluralin uses, new risk-reduction measures were required to be included on the labels of all products.13

European Union

Trifluralin has been banned in Sweden since 1993 and Denmark since 1997, but a derogation for use in seed production was in force from 1999 to 2004 ([OSPAR 2005], [PAN 2010]). The use of trifluralin has been reviewed by the EU (Draft Assessment Report on Trifluralin under Council Directive 91/414/EEC, January 2005). In addition, trifluralin has been evaluated for carcinogenicity by the International Agency for Research into Cancer. It was concluded that trifluralin was unclassifiable as to its carcinogenicity to humans, because the data are incomplete or ambiguous (IARC group 3); ([IARC 1991], [UNECE 2007]).

The outcome of the review under the EU Plant Protection Product Directive 91/414/EEC was that the substance was deemed not to be included in Annex I to the directive. No plant protection products containing trifluralin are expected to meet the general requirements set by Article 5(1)(a) and (b). Trifluralin is banned in the EU since 2009.14,15

Trifluralin was designated under the Water Framework Directive 2006/60/EC as a “priority substance” of particular concern for the aquatic environment.

Norway

Trifluralin is banned in Norway since 1993 because of its properties as non-readily biodegradable, bioaccumulative and toxic to water-living organisms ([PAN UK 2010]16, [UNECE 2007], [UNECE 2010, NO]).

13 http://www.hc-sc.gc.ca/cps-spc/alt_formats/pdf/pubs/pest/decisions/rvd-drv/rvd2009-09-eng.pdf

14 COMMISSION DECISION of 20 September 2007 concerning the non-inclusion of trifluralin in Annex I to Council Directive 91/414/EEC and the withdrawal of authorisations for plant protection products containing that substance (notified under document number C(2007) 4282) (Text with EEA relevance) (2007/629/EC).

15 UNECE/EB.AIR/WGS/2009/7

16 http://www.pan-uk.org/pestnews/Actives/Triflura.htm , February 2010

14

Switzerland

Trifluralin is registered for use in Switzerland [UNECE 2010, CH].

United States

Trifluralin is registered for use in the United States ([UNECE 2007], [UNECE 2010, USA]).

International agreements

Trifluralin has been added to the OSPAR (Convention for the Protection of the Marine Environment of the North-East Atlantic) List of Chemicals for Priority Action in 2002, because it is considered to be a ‘PBT’ substance fulfilling the criteria for Persistence, Bioaccumulation and Toxicity [OSPAR 2005].

Trifluralin is not listed under Stockholm Convention on Persistent Organic Pollutants. Further, the substance is not listed under the Rotterdam Convention on the Prior Informed Consent (PIC) Procedure for Certain Hazardous Chemicals and Pesticides in International Trade (Rotterdam Convention) [UNECE 2007].

HELCOM Recommendation 19/5 which was adopted in March 1998, having regard to Article 13, Paragraph b) of the Helsinki Convention, also includes trifluralin in several lists. Trifluralin has been added to the list of potential substances of concern to be considered by HELCOM according to the Strategy to Implement HELCOM Objective with Regard to Hazardous Substances. Trifluralin is indicated in the list of substances identified as of concern by HELCOM (HELCOM 12/18, Annex 6, and HELCOM 14/18, Paragraph 6.40, Helsinki Convention 1992, Annex I, Part 2, Banned substances, and Part 3, Pesticides). Further, the substance has been added to the list of substances agreed by the Third North Sea Conference (Annex 1A, The Hague Declaration) [HELCOM 201017]

Outside the UNECE region

Trifluralin is registered to be used, among others, in Australia, India, Japan, New Zealand, South Africa and Vietnam [UNECE 2007].

WHO does not consider trifluralin as an outdated pesticide. Based on an allocation of 10% of the TDI to drinking water, WHO has recommended a guideline value of ~20 μg/L of trifluralin for drinking water [WHO 2003].

4.1.1 Substitution, alternatives and emission control techniques

Alternatives to trifluralin include not only alternative substances that can be used without major changes in the process design, but also innovative changes such as agricultural processes or other practices that do not require the use of trifluralin or chemical substitutes. Possible alternatives are chemical alternatives, and agro-ecological practices such as Integrated Pest Management (IPM), organic farming and other specific agricultural practices.

Generally it is important that the whole range of alternatives is considered when evaluating possible alternatives.

Accessibility refers to whether an alternative can be used considering geographic, legal or other limitations [UNEP/POPS/POPRC.5/10]. It is vital to consider the accessibility of all (chemical and non-chemical) alternatives. Trifluralin is used as herbicide for pre-sowing or pre-emergence treatment of grasses and dicotyledonous weeds. The major crops for which trifluralin is applied to are oilseed rape and sunflowers. In

17 http://www.helcom.fi/Recommendations/en_GB/rec19_5/?u4.highlight=trifluralin

15

addition, it is used to a lesser extent for weed control in cotton and cereals. There are other minor uses in a wide range of agricultural and horticultural crops including vegetables.

From the UNECE Member States contacted, until end of April 2010 2118 answers to the UNECE questionnaire survey were received. In addition, 519 stakeholders replied to the questionnaire of which the answers of the chemical company Dow AgroSciences LLC and the Utility Solid Waste Activities Group (USWAG) were relevant for trifluralin ([UNECE 2010, Dow I], [UNECE 2010, Dow II], [UNECE 2010, USWAG]). However, for the evaluation of management options for trilfluralin only the information submitted by Dow AgroSciences LLC [UNECE 2010, Dow II] was relevant.

Furthermore, information on trifluralin alternatives was submitted on request by other institutions, mainly agricultural ministries and plant protection institutes of different EU Member States.20

Canada did not mention alternatives to trifluralin. It was noted that buffer zones and precautionary label statements (additional advisory statements) are required to reduce the entry of spray drift into aquatic systems and to prevent volatilisation into the air [Health Canada 2009].

Ukraine continues the search of corresponding information and will provide data on alternatives if available [UNECE 2010, UKR].

In France the agricultural sector has replaced trifluralin by other herbicides and adoption of modified processes, which are generally available and also currently in use. Further information on substitution (cyanizine, carbetamine, propyzamide) can be found in the report on socio-economic impacts of the identification of priority hazardous substances under the Water Framework Directive [RPA 2000]. Modification of processes include organic agriculture, biological control, mechanical weeding (houe rotative, herse etrille, bineuse) [UNECE 2010, FR].

Germany proposed implementation of measures for reduction of use of chemicals in plant protection and optimisation of the application as well as reinforced erosion protection by taking farmland measures and consideration of suitable crop rotations [UNECE 2010, DE].21 No chemical alternatives substances were indicated [UNECE 2010, DE].

Ireland reported that alternative plant protection products and cultural techniques are (potential) alternatives and technologies [UNECE 2010, IE].

In Sweden various herbicides are generally available and also currently in use. However, the substances were not specified [UNECE 2010, SE].

Herbicides with similar pest control characteristics are generally available in the United States and currently in use in the agricultural sector. There are no comparative analysis data available. Concerning costs it is not expected that the alternatives have significant impact on total cost per acre. The likely alternative technology is the use of other herbicides. Among the likely alternatives with a similar pest spectrum are metolachlor and acetachlor [UNECE 2010, USA].

Substantial information on alternatives is being provided by Dow AgroSciences LLC in a document entitled "Trifluralin: Information on the Costs, Benefits, and Role of Trifluralin in the Production of a Wide Variety of

18 Belgium, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Italy, Ireland, Netherlands, Norway, Slovenia, Spain, Sweden, Switzerland, Ukraine, USA, UK

19 ANAPE (Plastics National Association), Cefic, Dow Chemical, EBFRIP (European Brominated Flame Retardant Industry Panel), PCP Task Force, USWAG (Utility Solid Waste Activities Group)20 Austria, Czech Republic, Denmark, Germany, Greece, Lithuania, Netherlands, Portugal, Romania, Slovenia, Slovak Republic and UK.21 http://www.umweltdaten.de/wasser/themen/stoffhaushalt/trifluralin.pdf.

16

Crops" [UNECE 2010, Dow II]. This document, which was received in course of the UNECE questionnaire, was used as data basis for the identification of alternative chemical substances.

However, the information related to alternative chemical substances, which was received from the UNECE questionnaire, was very limited, and a second query was sent to EU Member State authorities on 23 February 2010. In total 40 additional requests for information were sent and 12 responses with information on alternatives to trifluralin were received from Austria, Czech Republic, Denmark, Germany, Greece, Lithuania, The Netherlands, Portugal, Romania, Slovenia, Slovak republic and United Kingdom. Hence, a number of additional alternative substances have been mentioned and can be compared to trifluralin.

An overview of the chemical alternative substances to trifluralin mentioned in the UNECE questionnaire (sources (1), (4) and (5)) and the additional query (sources (2), (3), (6)-(10), (12)-(15)) according to Table 4-3. Many of the listed alternatives can be used for comparable crop-pest-combinations instead of trifluralin.

In total, 66 chemical alternatives to trifluralin have been identified in the UNECE questionnaire survey, the additional request on trifluralin alternatives and documents from stakeholders and parties submitted in this context ([UNECE 2010, Dow II], [UNECE 2010, FI], [UNECE 2010, USA], [UK Reply 2010], [Defra 2006], [GR Reply 2010], [LT Reply 2010], [SK Reply 2010], [RO Reply 2010], [AT Reply 2010], [PT Reply 2010], [DK Reply 2010]). Assessing the availability of alternatives to trifluralin for each individual crop-pest-combination is difficult as information on crops and pests on which the alternative substances can be used for were often rather incomplete. Therefore, such data has been as far as possible completed with information from the database of the Bavarian Institute for Plant Protection (see source (11) in Table 4-3 and [LfL 2009/10] in Annex Table 2). As demonstrated in Table 4-3, a wide spectrum of chemical alternatives is available which covers the main uses oilseed rape (23 quoted alternatives), sunflowers (12 quoted alternatives) as well as the uses in a lesser extent cotton (17 quoted alternatives) and wheat (24 quoted alternatives). Also numerous uses on other crop categories as brassicas, field peas and beans were reported.

Most frequently pendimethalin was mentioned (9 times quoted), followed by metazachlor (6), napropamide and oxyfluorfen (both 5). All four chemicals can be used for various crop categories for which trifluralin is used. Also a number of other chemical alternatives were mentioned several times and for different crop and pest types.

Table 4-3: Chermical alternatives indicated in the UNECE questionnaire and in the received answers to the additional query

No Substance Frequency of mentions Crops Pest or

pest type01 Acetachlor (5) (8) (10) 3 cotton (8), sunflower (10) weed (10)02 Aclonifen (13) 1 sunflower (13) not specified03 Bensulide (1) 1 not specified not specified04 Bentazon (1) (7) 2 cotton (8), field peas, beans (7) broad leaved weeds (narrow weed

spectrum), charlock (7)05

Bifenox (7) (11) 2 oilseed rape, brassicas (7)broad leaved weeds , grasses, charlock, runch, volunteer spring rape (7), weeds, grasses (11)

06 Carbetamide (7) 1 oilseed rape, cabbage (7) black grass, wild oats, Italien rye grass, grass weeds (7)

07Chlortoluron (13) (7) (1) (11) 4 wheat (13), winter wheat (7)

wild oats, rye grass, annual meadow grass, grass weeds (7), grasses, weeds (11)

08 Clethodim (1) (8) (11) 3 cotton, tomatoes (8), oilseed rape (11) annual grasses, weeds (11)09 Clodinafop (1) (11) 2 wheat, barley, rye (11), winter wheat

(7)annual grasses,weed (11)

10 Clodinofop-propargyl (7) 1 winter wheat (7) wild-oats, grasses (7)11 Clomazone (7) (11) (13) (15) 4 rape (11), cabbage (13) (15), peas, annual grasses, weeds (11), cleavers

17


pest typebeans, brassicas, carrots, oilseed rape (7), winter oilseed rape, seed crops of cabbage and other brassicas (15)

and other broadleaved weeds, grasses (7), weeds (15)

12Clopyralid (1) (9) (11) (7) 4

oilseed rape (9), turnip (11), sugar beet, brassicas, oilseed rape (7)

weeds (9) (7) (11), thistle, mayweed, broadleaved weeds (7), grasses (7) (11)

13Cycloxydim (1) (7) (8) (11) 4

oilseed rape (1), cotton (8), brassicas, oilseed rape, sugar beet (7)

annual grasses (11), grass weeds, volunteer cereals (7), as shepherds purse, cranesbill, charlock (7)

14 DCPA (1) (6) (8) 3 carrots, caulifower, onion, cabbage, ladies finger, pepper, tomatoes (8)

not specified

15 Diclofop-methyl (8) 1 cabbage (8) not specified16 Diflufenican (7) 1 winter wheat (7) weeds (7)17 Dimethachlor (7) (9) 2 oilseed rape (7) (9), brassicas (6) weed (9)18 Dimethenamid-P (7) (10)

(11) 3 sunflower (10), oilseed rape, brassicas (7)

weeds (11) (10) as shepherds purse, cranesbill, charlock (7), grasses (11)

19 EPTC (1) 1 not specified not specified20 Ethalfluralin (1) (8) 2 cotton (8) not specified21 Fenoxaprop (1) (11) (7) 3 wheat (11), winter wheat (7) weed (11), wild-oats (7)22 Fenoxaprop-P-ethyl (7) 1 winter wheat (7) grasses, weed (7)23 Fluazifop-P-butyl (1) (8) (11)

(7) 4cotton, sunflower (8), oilseed rape (7) (11), sugar beet (7)

annual grasses, weeds (11), grass weed, barley cover crop, volunteer cereals, weeds (7)

24 Flufenacet (13) (7) 2 wheat (13), winter wheat (7) rye grass, annual meadow grass, grass weeds (7)

25 Flumioxazin (13) 1 wheat (13) not specified26 Fluometuron (8) 1 cotton (8) not specified27 Flupyrsulfuron (1) (11) (7) 3 wheat, barley, rye (11), winter wheat

(7)grasses, weed (11), grass weeds (7)

28 Flupyrsulfuron-methyl (7) 1 winter wheat (7) broad leaved weeds, grasses (7)29 Flurochloridone (8) (13) 2 sunflower (8) (13) not specified30 Fluroxypyr (7) (11) 2 winter wheat (7) broad leaved weeds (7) (11), grasses

(7) (11), cleavers, volunteer potato (7)31 Glufosinate (1) (8) (13) 3 cotton (8), turnip (13) not specified32

Glyphosate (1) (8) (11) (7) 4cotton (8), wheat (11), beans, peas, winter wheat, oilseed rape, sugar beet (7)

Weeds, grass weeds (11), couch grass (7)

33 Imazamox (1) (4) 2 not specified not specified34 Imazethapyr (1) 1 not specified not specified35 Iodosulfuron (1) (11) (7) 3 wheat, barley, rye (11), winter wheat

(7)grasses, weed (11), black grass, rye grass (7)

36 Isoproturon (1)* (6) (7) (11) 4 wheat (7) (11), winter wheat (7), barley, rye (11), winter cereals (7)

grasses , weed (7) (11), black-grass (7), wild-oats (7), annual meadow grass (7)

37 Linuron (8) (10) 2 sunflower (8), parsley, carrot, celery, soya, lupin, peas (10), carrots (7)

not specified

38 Mecoprop-P (7) (11) 2 winter wheat (7) broad leaved weeds (7), weeds (11), grasses (7) (11), cleavers (7)

39 Mesosulfuron (1) * (7) 2 winter wheat (7) black-grass, rye-grass, Italian rye grass, annual meadow grass (7)

40 Mesotrione (1) 1 not specified not specified41 Metazachlor (1) (6) (7) (10)

(11) (13) 6oilseed rape (7) (9) (10), brassicas/cabbage (7) (10) (13), mustard (10), turnip (13)

weed (7),annual grasses (10), black grass, broadleaved weeds, poppy (7)

42 Metsulfuron-methyl (7) 1 winter wheat (7) broad leaved weeds, grasses (7)

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pest type43 Metribuzin (8) (10) (14) 3 tomatoes (8) (14) (10), peppers (10)

(14), carrots (7) weeds, annual grasses (10)

44 Napropamide (1) (7) (8) (9) (13) 5 pepper, tomatoes (8) (10), winter

oilseed rape (7) (10) (13) broad leaved weeds, grasses (7)

45 Oxadiargyl (7) 1 oilseed rape, brassicas (7) weed (7)46 Oxadiazon (10) 1 onion, garlic, leak (10) weed (10)47

Oxyfluorfen (1) (7) (8) (13) (14) 5

cotton (8) (13) (14), sunflower (8) (13) (14), cauliflower (8) (13), onion (8) (13), cabbage/brassica (7) (8) (13), oilseed rape (7)

not specified

48 Paraffin oil (8) 1 cotton (8) not specified49

Pendimethalin (1) (6) (7) (8) (10) (11) (12) (13) (14) 9

cotton (14) (13) (8), sunflower (14) (8), carrots (8), cauliflower (8), onion (8), cabbage (8), pepper (8) (14), tomatoes (14) (8) wheat (13), peas, beans, brassicas, carrots, winter wheat (7)

annual grasses (10) (11), weeds (7) (10) (11), black grass, wild oats, rye grass, annual meadow grass, volunteer oilseed rape, polygonums, broadleaved weeds, grasses, black grass (7)

50 Pethoxamide (13) 1 sunflower, rape (13) not specified51 Pinoxaden (7) 1 winter wheat (7) wild oats, Italien rye grass (7), weeds,

grasses (11)52 Propachlor (1) (6) (7) 3 brassicas, oilseed rape (7) broadleaved weeds, grasses (7)53

Propaquizafop (7) (8) (11) 3 cotton (8), oilseed rape (7) (11), sugar beet (7)

weeds, grasses (11), grass weed, barley cover crop, volunteer cereals (7)

54 Propoxycarbazone (7) (11) 2 winter wheat (7) grasses, weeds (7)55

Propyzamide (6) (7) (8) (11) 4 cotton (8), rape (11), beans, peas, (winter) oilseed rape (7)

black grass (10), weed, grasses (11), grass weeds, volunteer cereals, broadleaved weeeds, grasses (7)

56 Prosulfocarb (7) (11) (13) 3 sunflower, wheat, barley (13), oilseed rape, brassicas (7) weeds (11)

57 Quizalofop-P (11) 1 oilseed rape (11) annual grasses, weeds (11)58

Quizalofop-p-ethyl (7) (8) 2cotton, sunflower, carrots, onion, cabbage, pepper, tomatoes (8), oilseed rape (7)

volunteer cereals, grass weeds (7)

59 Quizalofop-p-tefuryl (7) (8) 2 cotton, sunflower, tomatoes (8), oilseed rape (7) grass weeds (7)

60 Sethoxydim (1) 1 not specified not specified61 s-Metolachlor (1) (5) (8) 3 cotton, tomatoes (8) not specified62 Sulfentrazone (1) 1 not specified not specified63 Sulfosulfuron (7) 1 winter wheat (7) brome grasses (7)64 Tepraloxydim (1) (7) 2 oilseed rape (1) (7), beans, peas,

carrots, brassicas, sugar beet (7)weeds, grasses, volunteer cereals, grass weeds, barley cover crop (7)

65 Tri-allate (7) 1 winter wheat, beans, peas (7) grass weeds, wild-oats (7)66 Tribenuron (1) (11) 2 wheat, barley, rye (11) grasses,

weed (11)(1) [UNECE 2010, Dow II](4) [UNECE 2010, FI](5) [UNECE 2010, USA](6) [UK Reply 2010](7) [Defra 2006](8) [GR Reply 2010](9) [LT Reply 2010](10) [SK Reply 2010](11) [LfL 2009/10](12) [RO Reply 2010](13) [AT Reply 2010](14) [PT Reply 2010](15) [DK Reply 2010]

19


pest type* The substance is eventually only applicable in combination with a further substance or with trifluralin.

Austria listed several chemical alternative substances for sunflower, oilseed rape, turnips, wheat and barley. It was concluded that sufficient alternatives are available for main crops like oilsee rape and sunflower. Nevertheless, the available alternatives are often not registered for use in cultivation of secondary crops like vegetables. In these cases, there are not sufficient active substances or groups of active ingredients available to enable an appropriate resistance management by change of the active ingredients [AT Reply 2010].

Denmark reported that different alternative herbicides and technologies could be identified during the last years since trifluralin was banned. Especially for winter oil seed rape, cabbage and seed crops of cabbage and other brassicas clomazone or products containing clomazone (e.g. in combination with pendimethalin) could be identified. However, for cabbage for human consumption clomazone containing products are not yet registered for that use. In seed crops of radish and cress no alternatives have been identified so far [DK Reply 2010].

It was pointed out by Finland that alternatives have been difficult to identify or have been removed from the market. Imazamox may potentially become an alternative but it is not yet on the national market [UNECE 2010, FI]

According to an assessment carried out for France it seems to be difficult to find one single substance which is appropriate to replace endosulfan. However, for the single crop pest complexes equivalent alternatives are available [UNECE 2010, FR]; [INERIS 2007].

Greece reported 16 products authorised for cotton and several alternatives for sunflower, carrots, cauliflower, onion, cabbage, ladies finger, pepper and tomatoes. No efficacy problems have been reported to Greek authorities since the withdrawal of trifluralin from the market [GR Reply 2010].

The use of Trifluralin in Lithuania was authorised for weed control in winter and spring oilseed rape. After withdrawal of the authorisation, in Lithuania metazachlor, dimethachlor and clopyralid and their formulations are used [LT Reply 2010].

In Portugal alternative herbicides are registered for the same uses for which trifluralin was registered. Particularly plant protection products containing pendimethalin, oxyfluorfen, flufenacet+metribuzin and metribuzin are used. Crops involved are artichoque, cotton, brassicas, sunflower, soya and transplanted peppers and tomatoes. Trifluralin based products have never had a significant importance in cropping in Portugal. Illustrative data can be given by the sales information. In fact, in 2008, trifluralin sales represented only 7,544 kg a.s., whereas for pendimetalin, oxyfluorfen and metribuzin based products represented 28,151; 11,694 and 12,460 kg a.s., respectively [PT Reply 2010].

At least 10 alternative substances are available for different crops in Slovak Republic. Most of the listed active substances (except pendimetalin and partially metribuzin and metazachlor) are not effecacious on annual grasses. Practically all listed substances cover sufficiantly the spectrum of economically significant weeds in individual crops. Except efficacy on annual grasses they do not fall short of trifluralin. On the contrary their economic advantage is that they do not have to be incorporated into soil [SK Reply 2010].

In Romania two alternative herbicides are registered. Both products contain pendimethalin as active ingredient (STOMP 330 EC and PENDIGAN 330 EC). These are efficient on annual monocotyledonus weeds and partially dicotyledonus weeds for use on sunflower, pepper, onion, tomato, carrots, autumn cabbage, aubergines, garlic, soybean and tobacco. Nevertheless, trifluralin covers a very large range of other crops as

20

beans, peas, cauliflower, cotton, artichoke and others, for which pendimethalin uses are not registered in Romania [RO Reply 2010].

UK reported 25 potential alternative chemicals to trifluralin considering the report on the „Assessment of the Agronomic Impact of Directive 91/414/EEC and Legisaltion on Maximum Residue Levels“ [Defra 2006]. It was stated that trifluralin was important in agriculture and horticulture for broad-leaved and grass weed control in a wide range of crops. It was annually applied to around 1 million hectare agricultural and horticultural crops, placing it in the top 25 pesticides used in the UK. It was noted that for some crops there are no suitable alternatives. Trifluralin has many of the same uses as pendimethalin, both active substances belong to the dinitroanilines. However, trifluralin is safe for use on a greater number of brassica crops. Trifluralin was also essential for resistance management of Acetyl-CoA carboxylase (ACCase)22 and Acetolactate synthase (ALS) resistant black-grass. Alternatives in brassica crops include propyzamide which controls resistant black-grass, but is expensive. Pendimethalin has off-label approvals for use at low rates, and is effective against polygonums. Propachlor and chlorthal-dimethyl were alternatives but these have not been included on Annex I. Metazachlor is also a possible alternative, but its dose has been restricted as a condition of its Annex I inclusion and this also excludes annual use. For grass weeds, the only real option are ‚fops‘ and ‚dims‘23, though some of these do not control annual meadow grass. Alternatives are extremely limited for transplanted crops. Trifluralin was incorporated into soil and therefore compatible with mechanical weeding - the alternatives are not, because hoeing disturbs sealed soil surfaces ([UK Reply 2010], [Defra 2006]).

It is further mentioned that trifluralin as a cheap herbicide is of crucial importance in wheat production in the context of low profitability margins for wheat production. In particular for the management of herbicide resistant grass weeds this could be relevant for black-grass where there are difficulties with herbicide resistance to key selective herbicides [Defra 2006].

In winter wheat production, broad-leaved weed control of black-grass in particular can be realised instead of trifluralin by pre-emergence/early post-emergence broad-spectrum soil acting herbicide isoproturon, pendimethalin or fenoxaprop-P-ethyl. One of the more recent introductions for weed control is the formulated mixture of mesosulfuron/iodosulfuron which is very effective on both black-grass and rye-grass. Pinoxaden is used for Italian rye-grass control which is also achieved by chlorotoluron, flufenacet/pendimethalin and iodosulfuron. Brome grasses can be controlled with sulfosulfuron whereas couch grass is controlled by glyphosate as a pre-harvest spray [Defra 2006].

Isoproturon, chlorotoluron and pendimethalin also give a useful control of wild-oats at early stages of growth. In addition, tri-allate is important for this weed, as are a number of post-emergence sprays such as fenoxaprop, clodinafop-propargyl and pinoxaden (ACCase inhibitor) [Defra 2006].

With regard to oilseed rape there is little herbicide choice for spring rape. It is reported that the loss of trifluralin would lead to increased costs and reliance on metazachlor (broad spectrum) ½ dose + clomazone, cost 96.84 USD/ha, or 83.29 USD/ha full dose of metazachlor alone. It would be difficult to control the following pests: spring-emerging resistant black-grass, knotgrass, black bindweed, fat-hen, fumitory in spring rape, or pansy, fumitory in poorly established winter rape. It is estimated that production costs would increase by 55.99 USD/ha as the alternative, propyzamide is more expensive [Defra 2006].

22 Acetyl-CoA carboxylase (ACC) is a biotin-dependent enzyme that catalyzes the irreversible carboxylation of acetyl-CoA to produce malonyl-CoA through its two catalytic activities, biotin carboxylase (BC) and carboxyltransferase (CT). ACC is a multi-subunit enzyme in most prokaryotes and in the chloroplasts of most plants and algae, whereas it is a large, multi-domain enzyme in the endoplasmic reticulum of most eukaryotes. The most important function of ACC is to provide the malonyl-CoA substrate for the biosynthesis of fatty acids (quoted from [Oligae 2010]; http://www.oilgae.com/ref/glos/acetyl_coa_carboxylase__accase_.html).

23 ‘fops’: aryloxyphenoxypropionates, ‘dims’: cyclohexanediones

21

In field peas and field beans, trifluralin may be replaced by pendimethalin for weed control as a formulation with clomazone. Effective early post-emergence herbicides for broad-leaved weeds are also available [Defra 2006].

In brassicas propachlor, metazachlor, clomazone are reported as alternative substances to trifluralin for residual weed control. Pendimethalin is not widely used because soil disturbance at planting reduces efficacy within the row. The substance is effective on polygonums, thistle and mayweed. Further options for grass weed or volunteer cereals control are tepraloxydim and cycloxydim. Carbetamide (cabbage only) is another alternative and can be used in case grass weed resistance increases [Defra 2006].

Herbicides developed for oilseed rape are likely to be suitable for brassicas. Reported active substances are oxadiargyl, prosulfocarb, oxyfluorfen, dimethachlor, dimethenamid-p formulation and post-weed-emergence bifenox [Defra 2006].

The stakeholder Dow AgroSciences LLC provided information in course of the UNECE questionnaire [UNECE 2010, Dow I] and a background document “Trifluralin: Information on the Costs, Benefits, and Role of Trifluralin in the Production of a Wide Variety of Crops” elaborated by Steve A. McMaster, C. Bruce Clements and Barry K. Gibbs in February 2010 [UNECE 2010, Dow II]. Latter contains information on use, application and costs of trifluralin as well as in lesser extent on alternatives in different regions (USA, Canada and UK). In addition, a summary of comments of stakeholders and third party experts and selected newspaper articles are collected. Trifluralin is being described as crucial herbicide due to its price, broad application range and action of mode. In total, 30 chemical alternatives to trifluralin as clethodim, EPTC, fenoxaprop etc. are indicated.

Also according to literature, a number of chemical alternatives substances to trifluralin exist. An overview of

indicated substances is given in Table 4-3.

Problems if trifluralin would not be available

According to Slovenia and Portugal, trifluralin could be replaced without difficulty by other substances for specific crops or never has played a key role in agriculture ([SI Reply 2010], [PT Reply 2010]). However, the substitution may be related to specific problems. The application of chemical alternative substances to trifluralin imply a probable risk of further development of herbicide resistance [WRAG 2007].

In particular, there may be a potential impact with trifluralin’s cessation with regard to grass weed resistance management in winter wheat, especially for black-grass control. UK reported increasing problems of herbicide resistance, e.g. to the ACCase inhibitors ('fops & dims'), and limited alternative chemical controls. Resistance to herbicides could increase with the application of sulfonylureas (SUs) [Defra 2006].

Loss of trifluralin could lead to increased costs for producers of oilseed rape and wheat as more expensive chemical alternatives as metazachlor (broad spectrum) ½ dose + clomazone, cost 96.84 USD, or 83.29 USD/ha for the full dose of metazachlor alone, have to be used. In [Defra 2006] it is stated that for the following weeds no alternative herbicide to trifluralin would be available: knotgrass, black bindweed, fat-hen, fumitory in spring rape, or pansy, fumitory in poorly established winter rape. Nevertheless, the sreening assessment of the effectivity of the individual alternatives por specifc crops/pest combinations showed various alternatives thereto.

4.1.2 Redesign of product or process

Alternatives are not limited to alternative substances (chemical alternatives) that can be used without major changes in the process design, but also include innovative changes such as agricultural processes or other

22

practices that do not require the use of trifluralin or other chemical substitutes.

Possible alternatives to trifluralin other than chemical alternative substances comprise:

Integrated pest management systems

Organic farming

Specific agricultural practices

No information with regard to biological control systems and integrated pest management (IPM) systems was provided neither from the UNECE questionnaire nor from the additional request.

In integrated pest management systems all available plant protection methods are carefully considered for the subsequent integration of appropriate measures that discourage the development of populations of harmful organisms and keep the use of plant protection products and other forms of intervention to levels that are economically and ecologically justified and reduce or minimise risks to human health and the environment. IPM emphasises the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms

According to established IPM principles (a) non-chemical alternatives must be preferred to chemical alternatives if they provide satisfactory pest control and (b) chemicals used shall be as target specific as possible and shall have the least side effects on human health, non-target organisms and the environment 24. However it should be noted that IPM systems accept critically selected plant protection products that should be available to the grower despite certain negative aspects (especially for reasons of resistance management or earmarked for exceptionally difficult cases). These products should have a short persistence and are permitted only for precisely identified indications with clearly defined restrictions [IOBC 2004]. As a consequence, in IPM systems trifluralin as a chemical alternative should be considered only as a last resort if all non-chemical alternatives fail. Furthermore, between chemical alternatives those with a short persistence should be preferred.

Organic farming is a form of agriculture that relies on cultural practices such as crop rotation, green manure, compost, biological pest control, and mechanical cultivation to maintain soil productivity and control pests. Organic farming excludes the use of synthetic pesticides. Therefore, it requires the duly planification of an effective weed-control program considering important factors including soil conditions, weather, crop rotations and field histories, machinery, etc. Weed control strategies have to be adjusted to the unique and ever-changing conditions throughout the year. Both, cultural and mechanical methods play the key role for successful weed control in organic farming.

Cultural methods include according to Martens [Martens; Martens 2002]25

Crop competition Soil fertility and condition Crop rotation Alleopathy Variety selection Sanitation.

24 See e.g. [IOBC 2004] and EU Directive 2009/128/EC related to sustainable use of pesticides (General principles of IPM; principles 4 and 5)

25 http://www.acresusa.com/toolbox/reprints/Organic%20weed%20control_aug02.pdf, February 2010

23

http://www.acresusa.com/toolbox/reprints/Organic%20weed%20control_aug02.pdf

Mechanical methods comprise in particular appropriate tillage. See also information provided below (specific agricultural practices).

Specific agricultural practices comprise cultural and mechanical (non-chemical) weed control. Preventative cultural practices that do not allow weeds to become established comprise a number of possible practices of which only some for illustration are indicated.

Considerations for cultural and mechanical weed control in cotton includes inter alia

Removing light or spotty infestations of weeds by hand hoeing or spot cultivation to prevent spreading weed seed, rhizomes or roots;

Planting only high quality weed-free crop seed to protect against weed infestations in the row and the introduction of new weed species;

Thoroughly cleaning harvesting equipment between fields to avoid transport of weed seed on cropland;

Using mechanical tillage to remove initial weed flushes prior to planting, thereby eliminating or at least reducing the potential for continued infestation;

Harrowing and cultivation; Practicing rotation to crops which physically out-compete certain weeds, resulting in their

gradual decline [Baumann 2010].

One of the most effective cultural practices indicated above for improving long-term weed control is crop rotation. It allows controlling weed by enabling rotation of herbicides as well as crops and by providing the possibility to plant highly competitive crops that prevents weed establishment [Loux et al. 2010]26.

Harrowing and cultivation for example are important methods of weed control in sunflowers. Since sunflowers normally do not emerge for ten days to two weeks after planting, those practices can be used about one week after planting to avoid many weeds. Normally, harrowing may be performed several times in case weeds continue to emerge and provided that field conditions are suitable. Further, weeds that have been missed by early tillage can be controlled by cultivation between the rows [Durgan 2010].

4.1.3 Possible adverse effects of substitutes

Alternatives should be safer than the currently used trifluralin. For the evaluation of the safety of alternatives information on several risks indicators for adverse effects on the environment and health can be used. Corresponding risk indicators are POPs screening criteria (persistence, bioaccumulation, toxicity and potential for long-range transport) and several hazardous criteria (mutagenicity, carcinogenicity, reproductive and developmental toxicity, endocrine disruption, immune suppression, neurotoxicity).

In addition to the risks, consideration should also be given to the exposure situation of the environment, workers, farmers and consumers. However, it is assumed that the exposure situation for different herbicides is more or less comparable due to usually comparable use conditions. It can be expected that exposure generally increases with the persistence and bioaccumulation potential of the herbicides. This is however already reflected in the above listed risk indicators.Given the multitude of available alternatives a comprising assessment of risks related to alternatives is difficult. For a screening assessment of the risks related to the identified chemical alternatives, available information on the risk indicators has been compiled. On the basis of the compilation it is possible to evaluate the risks related to the identified alternatives and to indicate

26 http://ohioline.osu.edu/b789/pdf/01.pdf, February 2010.

24

http://ohioline.osu.edu/b789/pdf/01.pdf

priorities for more and less appropriate alternatives (concerning their risks to environment and health) and to identify alternatives for which information on risk indicators is lacking. The results of a screening assessment of the alternatives can be found in Annex Table 1to the present document.

On the basis of the results of the screening risk assessment it can be assumed that if trifluralin would not be available for plant protection it would be replaceable by safer chemical alternatives in the majority of crops.

Concerning risks of alternatives no information was provided by the parties within the answers to the UNECE questionnaire or the additional query.

4.2 Possible management actions

Possible management actions according to the POPRC3.20 comprise the following:

Ban Restriction Release control Sound management of waste and stockpiles Clean-up of contaminated sites.

Current measures cover the whole spectrum of management actions. In the EU trifluralin is presently banned as herbicide (see 4.1). Where the substance is in use, it is usually authorised for specific uses and use conditions. As a possible risk mitigation and release control measure, Canada proposed to install a ban mile to surface water so that trifluralin is inhibited at least partly to enter surface water [Health Canada 2009].

The management of waste and stockpiles containing trifluralin is carried out according to national waste management standards.

Information to clean-up of uncontaminated sites was not provided and not identified in current literature.

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4.3 Cost implications

Costs and benefits depend strongly on the status of control in the individual countries and the assessed control measures.

Possible costs related to the use of trifluralin versus chemical and non-chemical alternatives include

Cost impacts on industry (manufacturing and retailing of plant protection products), see chapter 4.3.1.1;

Cost impacts on agriculture (costs for use of alternatives and costs due to altered productivity in terms of quantity or quality) include the cost impacts on consumer prices , see chapter 4.3.1.2;

Cost impacts on consumer (consumer costs for agricultural products), see chapter 4.3.3;

State budget incorporating administrative costs and waste management costs (costs for management of obsolete pesticides and remediation of contaminated sites, waste disposal costs); see chapter 4.3.4;

Cost impacts on environment and health. According to the conclusions of the risk profile the substance causes significant adverse effects on human health and the environment. As a consequence it can be expected that its current use causes significant non quantifiable environment and health costs.

In the course of the UNECE questionnaire and the additional request for information on alternatives to trifluralin, substantial information on cost impacts were received from the industry and UK ([UNECE 2010, Dow I]; [UNECE 2010, Dow II]; [UNECE 2010, UK]; [UK Reply 2010]; [Defra 2006]).

Table 4-4 shows an overview of the expected cost impacts:

Table 4-4: Overview on expected cost impacts

Type of cost impact Quantification

Cost impacts on industry

In countries where trifluralin is already banned and where trifluralin is not produced the cost impacts on industry are nil or negligible.

Non-quantified annual losses for manufacturers would occur in countries where trifluralin is still produced.

Globally the losses will be more or less outweighed by sales of chemical and non-chemical alternatives.

Cost impacts on agricultureExpected annual cost impacts on agricultural production would range from 9.02 to 10.86 million USD.

Cost impacts on consumersAnnual cost impacts due to possible price increases of agricultural products could amount up to 10.86 million USD.

Cost impacts for governments and authorities

One time administrative costs for governments and authorities could range from 0.15 to 0.83 million USD considering 28 UNECE Parties where trifluralin is not yet banned.

One time costs for the management of stockpiles range from about 18,800 to 45,200 USD for residues from known use quantities in the UNECE region.

Cost impacts on environment and health

High, non-monetarised benefits for environment and health.

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4.3.1 Cost implications for eliminating production and use

According to a cost benefit assessment of [RPA 2008] the following assumption with regard to the cost impacts can be made.

4.3.1.1 Cost impacts on industry

Cost impacts on industry for the UK if trifluralin will be added to the Stockholm Convention are considered nil or negligible due to existing restrictions on marketing and use within the EU [RPA 2008]. This allows to conclude that in countries where trifluralin is already banned and where trifluralin is not produced the cost impacts on industry are nil or negligible.

The corresponding manufacturers in countries where trifluralin is still produced will have losses if they have to stop selling trifluralin containing products. The losses could be estimated based on current production quantities and the market value. It is assumed that the current production amounts are significantly lower than the 20,000 to 25,000 tonnes produced worldwide in 1991 [IARC 1991]. Current production amounts are not known and production losses can not be quantified for the UNECE region. However, globally it is expected that the corresponding losses of sales of products containing trifluralin will be more or less outweighed by sales of chemical and non-chemical alternatives.

4.3.1.2 Cost impacts on the agriculture

For the evaluation of direct cost impacts on agriculture, it is considered most important to identify possible alternatives (chemicals, IPM, organic farming and eventually specific cultural practices), related costs, their efficiency compared to trifluralin, impacts on yields and output prices of agricultural products.

UK states in its response to the additional request for information that it is difficult to assess the impact of trifluralin loss (since there exists a range of possible alternative weed control strategies in different crops each of which could entail different costs in different situations). However, alternative weed control strategies are estimated to cost around 27.24-45.40 USD/ha more in average suggesting a total cost of around 23-38 million USD [Defra 2006].

France analysed the economic and environmental impact of the chemical alternatives for the crop soya. It is concluded that the substitution of trifluralin by the indicated chemicals27 could lead to increased costs [INERIS 2007].

Alternatives to trifluralin will have positive economic impacts if they contribute to increased yield, higher output prices and lower production costs and vice versa. As a consequence it is possible to analyse the impacts of alternatives on the individual factors (i.e. yields, prices, and production costs) or the overarching impacts on the income (i.e. incomes of farmers, net cash return) for an assessment of possible economic impacts of the substitution of trifluralin with alternatives.

In Table 4-5 cost per hectare of crop specific chemical alternatives to trifluralin and their application for pest/pest type are listed. The main crops for which trifluralin is used are indicated. An overview of the average costs per application of active ingredient per hectare is given. The mean cost for trifluralin was calculated on the basis of the indicated cost ranges of the provided background documents in course of the UNECE questionnaire ([UNECE 2010, Dow II] submitting data for Canada, USA and UK) and the additional

27 Alachlor, bentazon, clomazone, linuron, oxadizon, pendimethalin, propyzamide, s-metolachor, cletodime, cycloxydim, fluazifop-p-butyl and haloyxyfop-r [INERIS 2007].

27

query ([UK Reply 2010], [Defra 2006]) and can be found in Annex Table 2. In this context, the following cost ranges per application and per hectare were calculated on the basis of the documents: Canada: 17.64-23.41 USD/ha, UK: 7.57-9.84 USD/ha28, USA: 8.13-16.25 USD/ha. Based on the ranges average costs for the application per hectare of trifluralin is estimated to amount to 15.49 USD a.i./ha. The costs for the alternative chemical substances were provided in the course of the UNECE questionnaire by the industry [UNECE 2010, Dow II], Canada and the additional query from UK ([UK Reply 2010], [Defra 2006]). It has to be noted that the costs vary depending on the country from where the cost information was obtained. Missing information on costs was completed with data from the Bavarian Institute for Plant Protection [LfL 2009/10].

Nearly all chemical alternatives to trifluralin, for which cost factors were indicated, have higher application costs per hectare. For cotton the cost differences for the alternatives range from +84% for clethodim and fluazifop-P-butyl controlling annual grasses and weeds to +404% for propyzamide.

For oilseed rape the costs for alternative chemicals range from additional costs of +15% for Bifenox to +687% for napropamide. Both chemicals are used for different grass and weed control.

For sunflowers, the mentioned alternatives and indicated costs are rather expensive with a range of +84% for fluazifop-P-butyl to +343% for prosulfocarb which controls weed. For wheat/cereals costs for chemical alternatives vary from +31% for tribenuron controlling grasses and weed to 343% for prosulfocarb.

Table 4-5: Crop specific chemical alternatives and their cost differences in % to the mean application costs of trifluralin (15.49 USD/ha)

CropAlternative substance to trifluralin

efficiency Average cost a.i./ha overview [US$/ha] Cost difference in %

Cotton Acetachlor Weed No information -Clethodim Annual grasses,

weeds28.52 +84

Bentazon weeds, grasses 68.34 +341Cycloxydim Annual grasses, grass

weeds45.59 +194

Ethalfluralin Not specified 41.07 +165Fluazifop-P-butyl Annual grasses,

weeds28.57 +84

Fluometuron Not specified No information -Glufosinate Not specified 30.25 +95Glyphosate Weeds, couch grass 42.64 +175Oxyfluorfen Not specified No information -Paraffin oil Not specified No information -Pendimethalin Annual grasses, weed 36.39 +135Propaquizafop Grasses, weeds 34.02 +120Propyzamide weeds, grasses 78.06 +404Quizalofop-p-ethyl grass weeds No information -Quizalofop-p-tefuryl grass w eeds No information -s-Metolachlor Not specified 56.25 +263

Oilseed rape Bifenox Weeds, grasses 17.86 +15Carbetamide Grass weeds No informationClethodim Annual grasses,

weeds28.52 +84

Clomazone Annual grasses, weeds

59.19 +282

Clopyralid Weeds, grasses 72.79 +370Cycloxydim Annual grasses, grass

weeds45.59 +194

Dimethachlor Weeds No information -Dimethenamid-P Weeds, grasses 32.65 +111

28 Dow Chemicals indicated costs range for the USA from 3.25-6.50 US$/ha, for Canada from 18.10-24.03 Cnd$/ha and for UK 6.5 £/ha. UK indicated in the reply to the query a price of 5 £ which was also indicated by the background document [Defra 2006].

28

Fluazifop-P-butyl Annual grasses, weeds

28.57 +84

Glyphosate Weeds, couch grass 42.64 +175Metazachlor Weeds, annual

grasses61.37 +296

Napropamide broad leaved weeds, grasses

121.88 +687

Oxadiargyl Not specified No information -Oxyfluorfen Not specified No information -Propachlor Broadleaved weeds,

grassesNo information -

Pethoxamide Not specified No information -Prosulfocarb Weeds 68.69 +343Propaquizafop Grasses, weeds 34.02 +120Propyzamide weeds, grasses 78.06 +404Quizalofop-P annual grasses,

weeds29.25 +89

Quizalofop-P-ethyl Grass weeds No information -Quizalofop-P-tefuryl Grass weeds No information -Tepraloxydim weeds, grasses No information -

Sunflower Aclonifen Not specified No information -Acetachlor Weed No information -Dimethenamid-P Weeds, grasses 32.65 +111Fluazifop-P-butyl Annual grasses,

weeds28.57 +84

Flurochloridone Not specified No information -Linuron Not specified No information -Oxyfluorfen Not specified No information -Pendimethalin Annual grasses, weed 36.39 +135Pethoxamide Not specified No information -Prosulfocarb Weed 68.69 +343Quizalofop-p-ethyl grass weeds No information -Quizalofop-p-tefuryl grass weeds No information -

Wheat/Winter wheat/Winter Cereals

Clodinafop Annual grasses, weed 65.31 +322Clodinafop-propargyl grasses No information -Chlortoluron Grasses, weeds No information -Diflufenican weeds No information -Fenoxaprop weeds 38.10 +146Fenoxaprop-P-ethyl grasses, weed No information -Flufenacet grasses No information -Flumioxazin Not specified No information -Fluroxypyr grasses and weeds 37.09 +139Flupyrsulfuron grasses and weeds 35.38 +128Flupyrsulfuron-methyl

Broadleaved weeds, grasses

No information -

Glyphosate weeds, couch grass 42.64 +175Iodosulfuron grasses and weed 43.54 +181Isoproturon grasses and weed 27.21 +76Mecoprop-P grasses and weeds 31.60 +104Mesosulfuron grasses No information -Metsulfuron-methyl grasses, weeds No information -Pendimethalin grasses and weeds 36.41 +135Pinoxaden grass and weeds 40.53 +162Prosulfocarb weeds 68.69 +343Propoxycarbazone grasses, weeds 36.41 +135Sulfosulfuron grasses No information -Tri-allate grass weeds No information -Tribenuron grasses, weed 20.28 +31

It can be concluded that the costs for the substitution of trifluralin with available chemical alternatives are significantly higher for the main crops when taking into account the average cost values calculated from

29

information received by the UNECE survey and the additional query respectively. This is because in the calculation of the average alternative costs, all substances including expensive ones, are considered for the calculated average cost for trifluralin (15.49 USD/ha). In chapter 4.3.1.2 the cost impact of the substitution of trifluralin by the use of the identified possible alternatives are analysed in detail (see Table 4-6 and AnnexTable 2).

Costs related to chemical alternatives

Impacts on yields

It can be assumed that the use of chemical alternatives will not have negative impacts on yields if alternatives are equally efficient compared to trifluralin (see chapter 4.1.1).

Impacts on prices

The use of chemical alternatives will not enable to achieve higher output prices for crops. Prices of output crops will remain stable or increase slightly if increased production costs will have to be compensated.

Impact on production costs

Annex Table 2 gives an overview on alternatives to trifluralin, their pest control spectrum for individual crops and the corresponding costs per application. The overview is based on information of [UNECE 2010, Dow II], [UK Reply 2010], [Defra 2006] and [LfL 2009/10] where specific information on costs per crop and pest specific application are available. An assessment of the information contained in Annex Table 2 is summarised in Table 4-6.

30

Table 4-6: Overview on average cost and cost ranges for trifluralin and chemical alternatives, the availability of lower/equal cost chemical alternatives and conclusions on possible cost impacts

Crop Average

cost

trifluralin

[USD/ha]

Cost range

trifluralin

[USD/ha]

Average

costs

alternatives

[USD/ha] (cost increase

in %)

Cost range

alternatives

[USD/ha]

No. of

available

alternatives (number of

alternatives

without cost

indication)

No of

alternativ

es with

lower to

equal

costs

Pest spectrum

covered by

alternatives

Gras

ses &

Gras

ses o

r

No

info

Cotton 15.49 7.57-23.41 44.52 (187) 17.25-92.52 17 (6) 4 7 4 6

Conclusion cotton: according to the information ofAnnex Table 2, there is no alternative for cultivation in cotton, which average cost is lower than the average cost of trifluralin. Regarding the individual cost ranges of the alternatives and comparing them with the average trifluralin cost, no alternative with lower cost can be identified. This is also the case for comparison of average alternative costs with the cost range of trifluralin. Comparison of the cost ranges of the alternatives with the cost range of trifluralin results in identification of four alternatives, which are likely to lie in the cost range of trifluralin. These substances are clethodim (19.54 USD/ha), ethalfluralin (17.88 USD/ha), fluazifop-P-butyl (23.13 USD/ha) and glyphosate (17.25 USD/ha). For these substances an impact on costs is likely to be low to moderate. All of these substances except ethalfluralin, for which no information on the target pest was submitted, are used for control of weeds and grasses.

Oilseed rape 15.49 7.57-23.41 50.18 (224) 17.25-162.50 23 (9) 5 15 5 0

Conclusion oilseed rape: according to the information of Annex Table 2, there is no alternative for cultivation in (oilseed) rape, which average cost is lower than the average cost of trifluralin. Regarding the individual cost ranges of the alternatives and comparing them with the average trifluralin cost, no alternative with lower cost can be identified. Comparison of the cost ranges of the alternatives with the cost range of trifluralin results in identification of five alternatives, which are likely to lie in the cost range of trifluralin. These substances are bifenox (17.86 USD/ha), clethodim (19.54 USD/ha), fluazifop-P-butyl (23.13 USD/ha), glyphosate (17.25 USD/ha) and quizalofop (21.77 USD/ha). For these substances an impact on costs is likely to be low to moderate. All of these substances are used for control of weeds and grasses.

Sunflower 15.49 7.57-23.41 41.58 (168) 23.13-68.69 12 (8) 1 3 5 4

Conclusion sunflower: according to the information of Annex Table 2, there is no alternative for cultivation in sunflower, which average cost is lower than the average cost of trifluralin. Regarding the individual cost ranges of the alternatives and comparing them with the average trifluralin cost, no alternative with lower cost can be identified. Comparison of the cost ranges of the alternatives with the cost range of trifluralin leads to identification of one substance (fluazifop-P-butyl with 23.13 USD/ha), which lies in the cost range of trifluralin. Therefore, impact on costs due to replacement of trifluralin with fluazifop-P-butyl is likely to be low to moderate. Fluazifop-P-butyl is used for grass as well as weed control.

Wheat 15.49 7.57-23.41 40.24 (160) 10.63-68.69 24 (11) 4 15 8 1

Conclusion wheat: according to the information of Annex Table 2, there is no alternative for cultivation in (winter) wheat, which average cost is lower than the average cost of trifluralin. Regarding the individual cost ranges of the alternatives and comparing them with the average trifluralin cost, there are two alternatives with lower costs (isoproturon with 14.97 USD/ha and tribenuron with 10.23 USD/ha). Furthermore, the average cost for tribenuron (20.28 USD/ha) lies in the cost range of trifluralin. Comparison of the cost ranges of the alternatives with the cost range of trifluralin leads in total to the identification of four alternatives, which are likely to lie in the cost range of trifluralin. These substances are glyphosate (17.25 USD/ha), isoproturon (14.97 USD/ha), mecoprop-P (23.35 USD/ha) and tribenuron (10.63 USD/ha). For these substances an impact on costs is likely to be low to moderate. All of these substances are used for control of weeds and grasses.

The information in Table 4-6 and the underlying information in Annex Table 2 allow to conclude that alternatives are available at comparable or moderatlely increased costs as for trifluralin. The average of costs for alternatives are generally comparatively elevated compared to trifluralin because a limited number of very high cost alternatives (e.g. propytamide, clopyralid, bentazon) contribute to high averages of cost

31

alternatives. However, it can be demonstrated that besides these high cost alternatives there is a selection of equal cost alternatives or at least a selection of only slightly higher cost alternatives available. It can be expected that in practice trifluralin will be replaced by the most appropriate alternative at low costs. In rare cases even cheaper alternatives, e.g. isoproturon (14.97 USD/ha) or tribenuron (10.63 USD/ha) both for wheat cultivation, could be used instead of trifluralin. Only in a few specific cases the use of a high cost alternative may be necessary (e.g. according to [Defra 2006] for control of black-grass propyzamide can be used).

None of the average costs calculated for the alternatives which can be used for the main crops cotton, rape, sunflower and wheat turned out to be smaller than the average costs calculated for trifluralin (15.49 USD/ha).

Comparing the cost ranges given for the alternatives according to information of Annex Table 2 with the average costs of 15.49 USD/ha for trifluralin, costs of two substances, both used for cultivation of wheat, are identified to be cheaper. These are isoproturon (14.97 USD/ha) and tribenuron (10.63 USD/ha). Furthermore, comparison of average costs for alternatives with the trifluralin cost range (7.57-23.41 USD/ha) resulted in identification of two further substances with calculated average costs lying within the trifluralin cost range: bifenox used on oilseed rape with an average costs of 17.68 USD/ha and tribenuron used on wheat with an average costs of 20.28 USD/ha. According to Annex Table 2 there are in total 14 substances known, which calculated cost values are lying within the cost range of trifluralin (7.57-23.41 USD/ha) and in this way can be regarded as alternatives with possibly low to moderate overall cost impacts if trifluralin would not be available.

For cotton these substances are clethodim (19.54 USD/ha), ethalfluralin (17.88 USD/ha), fluazifop-P-butyl (23.13 USD/ha) and glyphosate (17.25 USD/ha), for oilseed rape these are bifenox (17.86 USD/ha), clethodim (19.54 USD/ha), fluazifop-P-butyl (23.13 USD/ha), glyphosate (17.25 USD/ha) and quizalofop (21.77 USD/ha), for sunflower fluazifop-P-butyl (23.13 USD/ha) and for wheat glyphosate (17.25 USD/ha), isoproturon (14.97 USD/ha), mecoprop-P (23.35 USD/ha) and tribenuron (10.63 USD/ha). These estimations are based on information to be found in Annex Table 2, which is based on information available in [UNECE 2010, Dow II], [UK Reply 2010], [Defra 2006] and [LfL 2009/10]. All of these substances, except ethalfluralin for which no information on target pest was available, are being used for control of several weed and grass pests.

This assessment considers only the data on costs per hectare for alternatives provided by Dow AgroSciences LLC and UK ([UNECE 2010, Dow I], [UNECE 2010, Dow II], [UK Reply 2010]) completed by data from the Bavarian Institute for Plant Protection [LfL 2009/10].

As data of use quantities are available for the USA, EU, Norway and Switzerland, only a very vage estimation of total used amounts of trifluralin within the UNECE region is possible.

For the calculation of the increased production costs per year of replacement of trifluralin by chemical alternatives, only rough estimates can be made for the total UNECE region as well as for the rest of the world. Two different scenarios have been assumed.

In scenario 1 (high cost scenario) the average costs taking all available alternatives into account and the corresponding cost increases in percent for the four different main crops cotton, oilseed rape, sunflower and wheat is used. According to Table 4-6 for cotton the mean alternative cost of 44.52USD/ha (cost increase of 187%), for oilseed rape 50.18USD/ha (224%), for sunflower 41.58USD/ha (168%) and for wheat 40.24USD/ha (160%) have been calculated. Since the cost values are in a comparable range (range of 40.24-50.18USD/ha) for the estimation a mean value of 185% cost increase has been assumed for all four crop types. This is an

32

average value calculated by considering all identified alternatives. Hence, a limited number of very expensive alternative substances are included in this scenario. In reality, substances available for lower or equal costs will be preferred.

In scenario 2 (low cost scenario) for the main crops cotton, oilseed rape, sunflower and wheat only the cheaper alternatives are regarded according to Table 4-6. For cotton these are clethodim, ethalfluralin, fluazifop-p-butyl and gylphosate, for oilseed rape bifenox, clethodim, fluazifop-p-butyl, glyphosate and quizalofop, for sunflower fluazifop-p-butyl and for wheat glyphosate, isoproturon, mecoprop-P and fluazifop-p-butyl. Related values to these substances can be found summarised in Table 4-7.

Table 4-7: Summary on scenario 2 - cheapest alternatives available for the main crops with lowest cost on alternative, overall average cost on alternative for specific crop and corresponding cost increase in %

Scenario 2

crop

Cheaper

alternatives

Lowest cost on

alternative

[USD/ha]

Average cost cheapest

alternatives [USD/ha)

corresponding increase in

comparison to trifluralin

(15.49USD/ha)[%]

Cotton

Clethodim 19.54

19.45 26Ethalfluralin 17.88

Fluazifop-p-butyl 23.13

Glyphosate 17.25

Oilseed rape

Bifenox 17.86

19.91 29Clethodim 19.54

Fluazifop-p-butyl 23.13

Glyphosate 17.25

Quizalofop 21.77Sunflower Fluazifop-p-butyl 23.13 23.13 49

Wheat

Glyphosate 17.25

16.55 7Isoproturon 14.97

Mecoprop-P 23.35

Tribenuron 10.63Average 19.76 28

For the cheapest alternatives available for cotton an average cost of 19.45USD/ha (cost increase of 26% in comparison to the average cost of trifluralin with 15.49USD/ha) can be assumed, for oilseed rape 19.91USD/ha (29%) and for wheat 16.55USD/ha (28%). For the cultivation of sunflower only little information on the costs of alternatives to trifluralin has been available. Therefore, only one alternative was identified to be pricely competitive to trifluralin (fluazifop-p-butyl). An overall average alternative cost of 19.76USD/ha has been assumed which would lead to a cost increase of 28% in comparison to the average cost of trifluralin (15.49USD/ha).

Comparing both scenarios, scenario 1 would therefore represent a mean expected impact on agricultural costs taking all alternatives into consideration, while scenario 2 would lead to a lower agricultural cost impact only using the cheaper available alternatives on the market.

Based on these assumptions for scenario 1 and 2 the increased production cost per year can be roughly estimated in million USD for the UNECE regions and the rest of the world for both scenarios (Table 4-8).

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Table 4-8: Cost impact scenario if pesticide costs would increase by 28 to 185% due to the replacement of trifluralin with chemical alternatives

Country Use [t]

Use area [mio ha]

Average pesticide costs for trifluralin

per year [USD/ha]

Pesticide cost increase for use of

alternatives [%]

Increased production costs

per year [mio US$]

Scenario 1 (all alternatives)

UNECE region known use quantity (min)

2,500 2.08 15.49 185 59.61

UNECE region known use quantity (max)

3,000 2.50 15.49 185 71.64

Rest of the UNECE region

unknown unknown 15.49 185 unknown

Total (min-max) 59.61-71.64

Scenario 2 (only cheaper alternatives)

UNECE region known use quantity (min)

2,500 2.08 15.49 28 9.02

UNECE region known use quantity (max)

3,000 2,505 15.49 28 10.86

Rest of the UNECE region

unknown unknown 15.49 28 unknown

Total (min-max) 9.02-10.86

For scenario 1 the possible cost increase for agricultural production due to known use quantities of trifluralin within the UNECE region would lay between 59.61 to 71.64 million USD per year. This increase can be regarded as unlikely since a reasonable selection of alternatives will lead to a preferred use of the cheaper alternatives to trifluralin. Therefore, the estimations in scenario 2 seem to be more realistic.

According to the more realistic scenario 2 the costs for agricultural production within the UNECE region would increase by approximately 9.02 to 10.86 million USD if trifluralin would be replaced by chemical alternatives. Considering both scenarios, the expected agricultural production cost increase due to replacement of trifluralin by the cheapest alternatives could range between 9.02-71.64 million USD per year for the known use quantities in the UNECE region.

A wide range of alternatives has been identified for current uses of trifluralin (see chapter 4.1.1). In total information on more than 66 chemical alternatives have been identified and it can be expected that a reasonable selection of available chemical alternatives would allow the replacement of trifluralin also for all other uses without significant negative economic impacts.

Conclusion cost impacts chemical alternatives

Assuming that yields and prices/costs remain stable and regarding the more realistic scenario 2 of 28% pesticide cost increase, the annual cost impacts due to the replacement of trifluralin are expected to amount up to 10.86 million USD.

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4.3.1.3 Costs related to non-chemical alternatives

Non-chemical alternatives for trifluralin are agro-ecological practices such as integrated pest management (IPM), organic farming and other specific agricultural practices. These non-chemical alternatives are applied in practice in IPM systems (where the use of synthetic pesticides is the last resort), organic farming systems (where the use of synthetic pesticides is prohibited) and in any other farming systems where the use of trifluralin is not allowed (e.g. in those countries where the use of trifluralin is banned).

The information available on cost impacts under such conditions is the following:

Impacts on yields and production costs

Information for the impact on yields is not available.

Impacts on prices

If trifluralin is replaced and conventional farming systems are converted to organic farming systems significant price premiums for agricultural products can be obtained. Price premium for organic farming on the world market is 35 to 100% [IJF 2005]. Price premiums for organic products in the USA amount to 20% [USDA 2005]. Farmer price premiums for organic farming products in the EU range from 20 to 257% [FIBL 2005].

Non-quantified price premiums are also possible for certified integrated farming systems29.

Conclusion cost impacts non-chemical alternatives

As the provided information is very limited a conclusion is not possible.

4.3.2 Cost implications for controlling unintentional emissions

This section is not relevant.

4.3.3 Cost implications for consumers

Prices of agricultural products could increase up to a similar range as agricultural production costs increase.

Therefore, the main impact on consumer prices is assumed to be dependent of production cost increases in agriculture as explained in (1). As estimated in Table 4-8 possible cost impacts on agriculture and therefore on consumers in the UNECE region, for which the used trifluralin quantity is known (USA), range from 59.61-71.64 million USD per year for scenario 1 (considering all identified alternatives; not realistic) and 9.02-10.86 million USD per year for scenario 2 (considering only cheapest alternatives; realistic). As no agricultural cost impact for the rest of the UNECE region could be estimated due to lack of information, no assumption on the consumer cost impact for the other UNECE regions can be made.

29 See for example http://www.pan-uk.org/pestnews/Issue/Pn32/pn32p9.htm

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4.3.4 Cost implications for state budgets

In a cost benefit analyses the UK estimates administrative costs for the UK government and authorities if trifluralin will be added to the Stockholm Convention costs for the UK authorities. Costs are estimated 1,800 GBP (5 work days) for updating the UK implementation plan for the Stockholm Convention as a task for government personnel and another 1,800 GBP for re-drafting and re-issuing guidance documents and notifying the staff of the regional authorities (for the UK for England and Wales, Scottish EPA, Northern Ireland). The implementation costs for the UK are estimated to range from 1,800 to 7,200 GBP or 2,710 to 10,840 USD [RPA 2008].

Assuming that within the 28 UNECE Member States where trifluralin is not yet banned similar implementation costs would be necessary; the administrative cost could range from 0,15 to 0,83 million USD30. The low range is based on the assumption that per signatory one update of the national implementation plan for the Stockholm Convention and one re-drafting and re-issuing of guidance and notifying of regional authorities would be required. The high range is based on the assumption that per signatory one update of the national implementation plan for the Stockholm Convention and ten re-draftings and re-issuing of guidance and notifying of regional authorities would be required.

Additional cost impacts on state budget will occur if waste from trifluralin containing products would have to be disposed of after a ban of trifluralin. Trifluralin containing plant protection products usually contain 0.2 to 60% of trifluralin by weight [UNECE 2010, USA]. According to [RPA 2008] an average content of 30% by weight can be assumed. The amounts of waste arising from trifluralin containing products are approximately 3 fold the amount of the active ingredient. It can be expected that in countries where trifluralin is already phased out remaining stockpiles of trifluralin are already disposed of or negligible. It is assumed that particularly in countries where trifluralin is still manufactured considerable amounts of waste and stockpiles will have to be managed. Information on production volumes in the UNECE region is very limited. As shown in chapter 3.1 production of trifluralin stopped in the EU Member States and other countries. It has never been produced in Canada. Thus, estimation of disposal costs for remaining stockpiles in the UNECE region is based on current use amounts in the USA. Annual trifluralin use in the USA ranges between 2,500 and 3,000 tonnes [UNECE 2010, USA]. Assuming residual stocks of 1% of the current use (i.e. 25 to 30 tonnes residual stocks active substance) containing 30% of trifluralin by weight (i.e. 83 to 100 tonnes residual stocks of waste containing trifluralin) the total disposal costs31 in the USA would range between 18,800 and 45,200 USD. The estimated costs can be considered representative for disposal costs for trifluralin containing products resulting from a ban of trifluralin. These costs would particularly incur in countries where trifluralin is currently manufactured. It is assumed that before a ban of trifluralin becomes effective, most of the trifluralin produced will be consumed. Therefore the 1% scenario could be considered realistic. If lower or higher shares of the production would have to be disposed of, corresponding lower or higher disposal costs would incur.

4.4 Possible management options under the UNECE POPs Protocol

The Task Force on POPs concluded that trifluralin is bioaccumulating, toxic and generally persistent and has potential for long-range environmental transport.

30 Within the UNECE region rifluralin is currently banned for use at least in the EU Member States and Norway (see chapter 4.1).

31 In an Analysis of the Costs and Benefits of the Addition of New Persistent Organic Pollutants to the Stockholm Convention [RPA 2008] for the UK the disposal cost for Trifluralin containing waste are estimated between 150 and 300 GBP. For the cost impact assessment it is therefore assumed that the disposal cost for trifluralin containing waste ranges between 226 and 452 USD/tonne.

36

Releases of trifluralin can occur during production, storage, transportation, and use of trifluralin. Production and use of trifluralin has been restricted in several UNECE countries and is banned in the European Union since 2009. On the other hand, production and use of trifluralin continues in many other countries. As trifluralin can move in the atmosphere far from its sources, single countries or groups of countries alone cannot abate the pollution caused by trifluralin. Due to the harmful POP properties and risks related to its widespread production and use, international action is warranted to control this pollution.

Possible options to manage trifluralin are to

restrict or eliminate production and use of trifluralin totally in order to completely remediate the above mentioned concerns and potential risks (option 1),

ban all uses of trifluralin except those where no viable alternatives exist (option 2).

4.4.1 Options

The objective of the POPs protocol is to control, reduce or eliminate discharges, emissions and losses of persistent organic pollutants. The most relevant emissions of trifluralin are related to its agricultural use for pre-sowing or pre-emergence treatment of grasses and dicotyledonous weeds. If the use of trifluralin according to current restriction to specific uses and use conditions will continue, emissions from production and use of trifluralin will continue in many UNECE countries. A possible management option is to list trifluralin in the UNECE POP protocol in order to eliminate or reduce its production and use throughout the UNECE region and thus related emissions and possible risks for health and environment.

Therefore, the following management options of trifluralin have been identified:

Option 1: listing trifluralin in Annex I of the POPs protocol in order to eliminate its production and use;

Option 2: listing trifluralin in Annex II of the POPs protocol and to specify allowed uses and related conditions in the implementation requirements.

Option 2 could be defined by restricting the use of trifluralin to specific agricultural uses (selected crops) where viable alternatives are currently not available.

The options could be related to specific conditions for a stepwise phase-out such as limited derogations for specific uses and a re-assessment of the allowed uses in the light of technical progress and additional knowledge.

4.4.2 Discussion of the options

Releases of trifluralin in the UNECE region arise from production, use, handling and transport as well as from waste containing trifluralin. In this context releases from production and agricultural use can generally be regarded as fields of major concern.

Management options should aim to remediate adverse environmental or human health effects as a consequence of all possible releases.

With respect to “option 1”, the following advantages and disadvantages have to be taken into account:

37

Advantages option 1:

General concerns and all definite risks from production and use of trifluralin would be completely remediated.

Existing market distortions that are due to the already existing ban of trifluralin in all major uses in several UNECE countries would be remediated.

Compliance could be easily ensured if a ban will be effective throughout the UNECE region (no problems in trade between UNECE countries)

Benefits are expected for environment and health.

Disadvantages option 1:

Significant cost implications may be possible.

Adverse effects of alternatives.

It can be stated that a ban is related to important advantages and contributes fully to the objective of the POPs protocol to control, reduce or eliminate discharges, emissions and losses of trifluralin as releases from all uses. The precautionary principle would be fully applied.

On the other hand possible disadvantages have to be taken into consideration when discussing a complete ban of the substance.

Generally this option is related to possible cost implications in the agricultural sector. As long as the economic impacts are not exhaustively assessed, it could be reasonable to include provisions for a stepwise phase-out.

Due to a number of alternative herbicides to trifluralin and non-chemical management options, cost implications are expected to be acceptable in the agricultural sector.

In particular, for specific agricultural uses significant cost implications or problems may occur.

Conclusion option 1:

Option 1 could be a reasonable recommendation. If the cost implications are economically justifiable, option 1 could be selected in order to achieve a maximum and long term elimination of releases and to prevent a re-introduction of trifluralin. In this way a maximum of non-quantifiable benefits will be achieved and all concerns and potential risks will be completely remediated.

With respect to option 2 (ban with exceptions) the following advantages and disadvantages have to be taken into account:

Advantages option 2:

Possibility to mitigate inacceptable cost implications in specific cases.

Possibility to mitigate inacceptable risks in specific cases.

38

Possibility to phase out allowed uses within a reasonable time frame against the background of economic aspects, risk assessment and technical development

Major concerns and possible risks would be remediated.

Reasonable time frames for re-assessment of allowed uses would enable to invent appropriate substitutes for critical or low emissive uses

Benefits are expected for environment and health

Disadvantages option 2:

Medium to long term releases from allowed uses of trifluralin would remain.

A number of releases and related risks would continue as long as the corresponding uses will be allowed.

Existing market distortions that are due to the already existing ban of trifluralin in all major uses in several UNECE countries would remain.

It would be more difficult to ensure compliance if a ban will be effective in some countries of the UNECE region and in others not (problems in trade between UNECE countries)

The non-quantifiable benefits would not be maximised

Option 2 is related to the mentioned advantages as it allows maintaining uses for specific crops. Thus inacceptable possible impacts of a total ban can be mitigated even if major emissions would be reduced.

On the other hand option 2 is related to the specific disadvantages that, if specific agricultural uses will be allowed, emissions will partly continue, the general concerns related to trifluralin would not be completely remediated and the non-quantifiable benefits would be reduced. Thus, the objective of the POPs protocol to control, reduce or eliminate discharges, emissions and losses of trifluralin would not be completely targeted.

It is furthermore noteworthy, that currently market distortions exist within the UNECE region because the use of trifluralin is already banned in several UNECE countries. Diverging restrictions between UNECE countries lead to competitive advantages in those countries where the use of trifluralin is less restricted.

39

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[PAN 2010] Pesticide Action Network (2010): Pesticides Database. http://www.pesticideinfo.org/Detail_Chemical.jsp?Rec_Id=PC35146, February 2010.

[PAN PDB 2010]Pesticide Action Network, North America, Pesticide Action Network Pesticide Database, http://www.pesticideinfo.org/, February 2010.

[Planas et al. 2006]Planas C, Puig A, Rivera J, Caixach J. (2006): Analysis of pesticides and metabolites in Spanish surface waters by isotope dilution gas chromatography/mass spectrometry with previous automated solid-phase extraction.Estimation of the uncertainty of the analytical results. J Chromatogr A 2006; 27: 242-252.

[PT Reply 2010] Portugal (2010): Divisão de Homologação e de Avaliação Toxicológica, Ecotoxicológica, Ambiental e da Identidade de Produtos Fitofarmacêuticos. Submitted information in course of the additional request on alternatives to trifluralin, Feb/March 2010.

[RPA 2000]Risk & Policy Analyst Ltd. prepared for and published by the European Commission (2000): Socio-Economic Impacts of the Identification of Priority Hazardous Substances under the Water Framework Directive. European Commission, DG Environment, Brussels.

[RPA 2008] Pesticide Safety Directorate Defra (2006): Assessment of the Agronomic Impact of Directive 91/414/EEC and Legisaltion on Maximum Residue Levels. Department for Environment, Food and Rural Affairs, York.

[SI Reply 2010] Slovenia (2010): Ministry of Agriculture, Forestry and Food, Administration for Plant Protection and Seeds. Submitted information in course of the additional request on alternatives to trifluralin, Feb/March 2010.

[SK Reply 2010] Slovak Republic (2010): UKSUP (Central Controlling and Testing Institute of Agriculture). Submitted information in course of the additional request on alternatives to trifluralin, Feb/March 2010.

[RO Reply 2010] Romania (2010): Ministry of Agriculture, Forests and Rural Development, National Phytosanitary Agency. Submitted information in course of the additional request on alternatives to trifluralin, Feb/March 2010.

[UK Reply 2010] UK (2010): Chemicals Regulation Directorate, Health and Safety Executive. Submitted information in course of the additional request on alternatives to trifluralin, Feb/March 2010.

44

http://www.pesticideinfo.org/Detail_Chemical.jsp?Rec_Id=PC35146

http://www.pesticideinfo.org/Detail_Chemical.jsp?Rec_Id=PC35146

[UNECE 2007] European Commission (2007): Trifluralin. Dossier prepared in support of a proposal of trifluralin to be considered as a candidate for inclusion in the Annex I to the Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution on Persistent Organic Pollutants (LRTAP Protocol on POPs), DG Environment, Brussels.

[UNECE 2010, BE]Belgium (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, CA] Canada (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, CH] Switzerland (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, CR] Croatia (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, CY]Cyprus (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, CZ] Czech Republic (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, DE] Germany (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, Dow I] Dow AgroSciences LLC (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, Dow II] Background Document for Trifluralin received from Dow AgroSciences LLC (2010): Trifluralin: Information on the Costs, Benefits, and Role of Trifluralin in the Production of a Wide Variety of Crops Steve A. McMaster, C. Bruce Clements, Barry K. Gibbs, February 12, 2010.

[UNECE 2010, EE] Estonia (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, ES] Spain (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, FI] Finland (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, FR] France (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

45

[UNECE 2010, IE] Ireland (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, IT] Italy (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, NL] The Netherlands (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, NO] Norway (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, SI] Slovenia (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, SE] Sweden (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, UK]Untied Kingdom (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, UKR] Ukraine (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, USA] USA (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNECE 2010, USWAG] Utility Solid Waste Activities Group (USWAG) (2010): Submitted form with information in course of the UNECE questionnaire, Feb/March 2010.

[UNEP/POPS/POPRC.5/6] Stockholm Convention on Persistent Organic Pollutants. October 2009. Summary of intersessional work on substitution and alternatives.http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5Documents/tabid/592/language/en-US/Default.aspx

[UNEP/POPS/POPRC.5/10] Stockholm Convention on Persistent Organic Pollutants. October 2009. Report of the Persistent Organic Pollutants Review Committee on the work of its fifth meeting. http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5Documents/tabid/592/language/en-US/Default.aspx.

[USDA 2005]United States Department of Agriculture (2005): Price Premiums Hold on as U.S. Organic Produce Market Expands, May 2005.

46

http://chm.pops.int/Convention/POPsReviewCommittee/hrPOPRCMeetings/POPRC5/POPRC5Documents/tabid/592/language/en-US/Default.aspx




[US EPA 1996] US Environmental Protection Agency (1996): Registration Eligibility Decision (RED): Trifluralin. United States Environmental Protection Agency Office of Prevention, Pesticides and Toxic Substances (7508W) EPA 738-R-95-040, April 1996.

[WHO 2003] World Health Organization (2003): Trifluralin in Drinking-water. Background document for development of WHO Guidelines for Drinking-water Quality._WHO/SDE/WSH/03.04/43. World Health Organization 2003. Originally published in Guidelines for drinking-water quality, 2nd ed. Vol.2. Health criteria and other supporting information. World Health Organization, Geneva, 1996. http://www.who.int/water_sanitation_health/dwq/chemicals/trifluralin.pdf.

[WHO 2010]World Health Organization Pesticide List. http://www.wpro.who.int/hse/pages/wholistpertype.html, February 2010.

[WRAG 2007] Weed Resistance Action Group (2007): Update to Response from Weed Resistance Action Group in Relation to Trifluralin and Annex 1

47

Annex

Results from the screening risk assessment of chemical alternatives compared to trifluralin

For an evaluation of the safety of alternatives information on several risks indicators for adverse effects on the environment and human health can be used. Appropriate risk indicators are POPs screening criteria (persistence, bioaccumulation, toxicity and potential for long-range transport) and several hazardous criteria (mutagenicity, carcinogenicity, reproductive toxicity, developmental toxicity, endocrine disruption, immune suppression, neuro-toxicity) (see UNEP/POPS/POPRC.5/6).

In addition to the risks, consideration should also be given to the exposure situation (see UNEP/POPS/POPRC.5/6) of the environment, workers, farmers and consumers. However, it is assumed that the exposure situation for different herbicides is more or less comparable due to usually comparable use conditions. It can be expected that exposure generally increases with the persistence and bioaccumulation potential of the herbicides. This is however already reflected in the above listed risk indicators.

Given the multitude of available alternatives a comprising assessment of risks related to alternatives is difficult. For a screening assessment of the risks related to the identified chemical alternatives, available information on the risk indicators has been compiled. On the basis of the compilation it is possible to evaluate the risks related to the identified alternatives and to indicate priorities for more and less appropriate alternatives (concerning their risks to environment and health) and to identify alternatives for which information on risk indicators is lacking. The results of a screening risk assessment of chemical alternatives are presented in Annex Table 1.

For the risk assessment information on the POP screening criteria of identified alternative substances was investigated. Information on PBT criteria was among others taken from [Greenpeace 2010]. The criterion “Bioaccumulation” was furthermore based on the evaluation of the Log K ow values of the corresponding substances. The criterion was considered to be fulfilled if the Log Kow is > 4. The criterion “Toxicity” was furthermore based on the classification according to Regulation (EC) No 1272/2007. The criterion was considered to be fulfilled if (1st priority) according to Regulation (EC) No 1272/2007 the acute toxicity of the corresponding substance is classified 1 or 2 or if acute or chronic aquatic toxicity is classified 1 or (2nd priority, if the substance is not classified according to Regulation (EC) No 1272/2007) if the substance belongs to class Ia, Ib or II according to WHO toxicity classification (Ia = Extremely hazardous; Ib = Highly hazardous; II = Moderately hazardous). The information on the WHO classification was taken from [IOBC 2005].

Information on the further risk indicators was compiled from the classification according to Regulation (EC) No 1272/2007 (related to mutagenicity (M), carcinogenicity (C) and reproductive toxicity (R); criterion considered to be fulfilled if classified C, M or R according to Regulation (EC) No 1272/2007 or not considered to be fulfilled if not classified C, M or R) as well as from [IOBC 2005] and [Greenpeace 2010].

48

A ranking has been established by summing up the number of criteria fulfilled for trifluralin and each chemical alternative.

According to this procedure trifluralin obtains 5 points in the ranking because it fulfils the four POPs criteria persistence, bioaccumulation, toxicity and potential for long range transport and is considered to have carcinogen potential. Out of the identified chemical alternatives only 5 substances fulfil 4 criteria. 11 substances fulfil 3 criteria, 23 substances fulfil 2 criteria and 22 substances fulfil only 1 criterion. 6 substances does not fulfil any of the criteria. It should be noted that according to FOOTPRINT Pesticide Properties Database several criteria might be potentially fulfilled for some alternative substances. In these cases, in absence of clear evidence for fulfilment of a criterion, no additional points were noted for the respective chemical alternative and the wording “possibly” has been noted in the respective cell of Annex Table 1. Therefore, some of the substances with a low score might have to be upgraded in future.

Against the background of the screening risk assessment it can be assumed that if trifluralin will be replaced by a substance with a lower ranking it will be replaced by a safer alternative. This is the case for 67 chemical alternatives. For 6 substances a conclusion is not possible. It is expected that none of the substances may cause equal risks as trifluralin (however these substances fulfil only one, two or three of the POP criteria risk indicators but in addition 1 to 3 of the adverse effect risk indicators; they could therefore be considered less hazardous than trifluralin which fulfils all POP criteria risk indicators). It can be concluded that if trifluralin would not be available for plant protection, it would be replacable by safer alternatives in the majority of cases.

49

Annex Table 1: Overview of results from the screening risk assessment of chemical alternatives compared to trifluralin

NoSubstance/

Substance group

CAS-No

(2) (3) (8)

Risk indicators: POP criteria Risk indicators: adverse effects

PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

0 Trifluralin 1582-09-8y (a), (b)

(11) (8)5.27 (8) y (16) y (11) n (11) y (16)

no data

(8)

no data

(8)

no data

(8)5

1 Acetachlor 34256-82-1y (a)

(8)4.14 (8) y (13)

no data

(8)y (8)

no data

(8)n (8) 4

2 Linuron 330-55-2 y (a) (8) 3 (8) y (13) y (13) y (8)(13)possibly

(8)n (8) 4

3 Bensulide 741-58-2y (a)

(8)4.2 (8) y (13) n (8)

no data

(8)

no data

(8)y (8) 4

4 Fluazifop-P-butyl 79241-46-6y (a)

(8)

4.5 (8)

4.5-5.3

(12)

y (13)no data

(8)y (8)

possibly

(8)

no data

(8)4

5 Pendimethalin 40487-42-1y (a)

(8)5.2 (8) y (13)

possibly

(8)

no data

(8)y (8) n (8) 4

6 Metribuzin 21087-64-9 y (a) (8) 1.65 (8) y (13) n (8) y (8)possibly

(8)

no data

(8)3

7Quizalofop-p-

tefuryl119738-06-6 n (8) 4.32 (8) y (15)

possibly

(8)y (8)

no data

(8)

no data

(8)3

50

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

8 Oxadiazon 19666-30-9 y (b) (8) 5.33 (8)possibly

(8)y (8) no data n (8) 3

9 Isoproturon 34123-59-6y (a)

(8)2.5 (8) y (13) y (13) n (8)

no data

(8)n (8) 3

10 Imazamox 114311-32-9y (a)

(8)5.36 (8) y (13) n (8) n (8) n (8) n (8) 3

11 Propyzamide 23950-58-5

y (a), (b)

(8)

3.3 (8) y (13) y (8) n (8)no data

(8)n (8) 3

12 Tepraloxydim 149979-41-9y (a)

(8)0.2 (8) y (16) y (16) no data no data 3

13 EPTC 759-94-4y (a)

(8)3.2 (8) y (15) n (8)

possibly

(8)

no data

(8)y (8) 3

14 Aclonifen 74070-46-5 y (a) (8) 4.37 (8) y (8)possible

(8)

possible

(8)

no data

(8)n (8) 3

15 Oxadiazon 19666-30-9 y (b) (8) 5.33 (8) n (13) (16)n (13)

(16)

possibly

(8)y (8) no data n (8) 3

16 Oxadiargyl 39807-15-3 y (a) (8) n (8) y (13) n (13) n (13) (16) y (16) no data no data 3

51

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

(16)

17 Dimethachlor 50563-36-5 y (a) (8) 2.17 (8)possibly

(8)y (8) no data n (8) 2

18 Clethodim 99129-21-2y (a)

(8)4.14 (8) n (8)

possibly

(8)n (8) n (8) 2

19 Clomazone 81777-89-1y (a)

(8)2.54 (8) y (15) n (8)

possibly

(8)

no data

(8)n (8) 2

20DCPA (chlorthal

dimethyl)1861-32-1

y (a)

(8)4.28 (8)

possibly

(8)

possibly

(8)

no data

(8)

no data

(8)2

21 Ethalfluralin 55283-68-6y (a)

(8)5.11 (8) n (9)

possibly

(8)

no data

(8)

no data

(8)n (8) 2

22Fenoxaprop-p-

ethyl71283-80-2

y (a)

(8)4.58 (8)

no data

(8)

possibly

(8)

no data

(8)

no data

(8)2

23Glufosinate

(ammonium)77182-82-2

y (a)

(8)-3.96 (8) n (13) n (8) y (8) (16)

no data

(8)n (8) 2

24 Glyphosate 1071-83-6y (a)

(8)-3,2 (8) y (13)

no data

(8)n (8) n (8) n (8) 2

25 Mesotrione 104206-82-8 y (a)

(8)0.11 (8) y (13) n (8) n (8) no data

(8)

n (8) 2

52

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

26 s-Metolachlor 51218-45-2y (a)

(8)3.4 (8) y (13)

possibly

(8)

no data

(8)

possibly

(8)n (8) 2

27 Oxyfluorfen 42874-03-3y (a)

(8)

4.86 (8)

4.47-5.21

(12)

possibly

(8)

no data

(8)

no data

(8)n (8) 2

28 Fluometuron 2164-17-2y (a, b)

(8)2.38 (8) y (15) n (8)

possibly

(8)

no data

(8)n (8) 2

29 Diclofop-methyl 51338-27-3 n (8) 4.8 (8) y (13)possibly

(8)

possibly

(8)

no data

(8)n (8) 2

30Quizalofop-p-

ethyl100646-51-3 y (a) (8) 4.61 (8) n (8)

possibly

(8)

no data

(8)

no data

(8)2

31 Pethoxamide 106700-29-2 y (a) (8) 2,96 (8) y (8)no data

(8)

no data

(8)

no data

(8)n (8) 2

32 Prosulfocarb 52888-80-9y (a, c)

(8)4.48 (8) n (8)

no data

(8)

no data

(8)

no data

(8)

no data

(8)2

33 Flufenacet 142459-58-3 y (a) (8) 3.2 (8) y (8) n (8)no data

(8)

no data

(8)n (8) 2

34 Flumioxazin 103361-09-7 n (8) 2.55 (8) y (8) n (8) y (8) no data n (8) 2

53

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

(8)

35 Diflufenican 83164-33-4y (8)

(a, b, c)

y

4.2 (8)n (13) (16)

n (13)

(16)n (13) (16) n (13) (16)

no data

(8)n (8) 2

36 Fluroxypyr 69377-81-7 y (a) (8) n (8) n (13) (16)n (13)

(16)n (13) (16) n (13) (16)

no data

(8)y (8) 2

37 Mecoprop-P 16484-77-8 y (a) (8) n (8) y (6)n (13)

(16)n (13) (16) n (13) (16) n (8) n (8) 2

38Metsulfuron-

methyl74223-64-6 y (a) (8) n (8) y (6)

n (13)

(16)n (13) (16) n (13) (16)

no data

(8)n (8) 2

39 Tri-allate 2303-17-5 n (8)y

4.06 (8)y (16)

n (13)

(16)n (13) (16) n (13) (16)

no data

(8)n (8) 2

40Clodinafop-

propargyl105512-06-9 n (8) n (8 y (16)

n (13)

(16)

n (13)

(16)

n (13)

(16)n (8) n (8) 1

41 Iodosulfuron 185119-76-0no data

(8)

no data

(8)n (8)

no data

(8)

no data

(8)y (8) 1

42 Bentazon 25057-89-0y (a, c)

(8)-0.46 (8) n (13) n (8) n (8)

no data

(8)n (8) 1

43 Clodinafop 114420-56-3y (a)

-0.44 (8)no data no data no data no data

1

54

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

(8) (8) (8) (8) (8)

44 Cycloxydim 101205-02-1y (a)

(8)1.36 (8) n (8)

possibly

(8)

no data

(8)n (8) 1

45 Imazethapyr 81335-77-5y (a)

(8)1.49 (8) n (8) n (8)

no data

(8)n (8) 1

46 Clopyralid 1702-17-6y (a)

(8)-2.63 (8) n (16) n (8)

possibly

(8)

no data

(8)n (8) 1

47 Metazachlor 67129-08-2y (a)

(8)2.49 (8) n (8)

no data

(8)

no data

(8)n (8) 1

48 Napropamide 15299-99-7y (a, c)

(8)3.3 (8) n (8)

possibly

(8)no data n (8) 1

49 Propachlor 1918-16-7 n (8) 1.6 y (13)possibly

(8)n (8)

no data

(8)n (8) 1

50 Sethoxydim 74051-80-2y (a, c)

(8)1.65 n (10) n (8)

no data

(8)

no data

(8)n (8) 1

51 Sulfentrazone 122836-35-5y (a, b)

(8)1 (8) n (8)

no data

(8)

no data

(8)no data 1

52 Propaquizafop 111479-05-1 n (8) 4.78 (8) possibly possibly no data n (8) 1

55

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

(8) (8) (8)

53 Fluorchloridone 61213-25-0y (a, d)

(8)3.36 (8)

no data

(8)

possibly

(8)

no data

(8)n (8) 1

54 Dimethenamid-P 163515-14-8 y (a) (8) 1.89 (8)possibly

(8)

possibly

(8)

no data

(8)1

55 Chlortoluron 15545-48-9y (a, c)

(8)2.5 (8)

no data

(8)

possible

(8)

no data

(8)n (8) n (8) 1

56 Paraffin oil 8042-47-5no data

(8)5.0 (8) n (8) n (8) n (8) n (8) 1

57 Bifenox 42576-02-3y (8)

(a) (8)n (8) n (13) (16)

n (13)

(16)n (13) (16) n (13) (16)

no data

(8)

no data

(8)1

58 Carbetamide 16118-49-3y (8)

(a) (8)n (8) n (13) (16)

n (13)

(16)n (13) (16) n (13) (16)

no data

(8)n (8) 1

59 Fenoxaprop 95617-09-7 y (a) (8) n (8)no data

(8)

no data

(8)

no data

(8)

no data

(8)

no data

(8)

no data

(8)1

60Propoxycarbazon

e145026-81-9

no data

(8)

no data

(8)y (6)

n (13)

(16)n (13) (16) n (13) (16)

no data

(8)

no data

(8)1

61 Sulfosulfuron 141776-32-1 n (8) n (8) y (6) n (6) possible no data no data n (8) 1

56

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

(8) (8) (8)

62 Tribenuron 106040-48-6no data

(8)

no data

(8)

possibly

(8)n (8)

no data

(8)n (8) 0

63 Mesosulfuron 400852-66-6 n (8) n (14) n (8) n (8)no data

(8)

possibly

(8)0

64 Flupyrsulfuron 150315-10-9no data

(8)

no data

(8)

no data

(8)

no data

(8)

no data

(8)

no data

(8)0

65Flupyrsulfuron-

methyl144740-54-5 n (8) 1.16 (8)

no data

(8)

no data

(8)

no data

(8)

no data

(8)0

66 Quizalofop-P* no data no data no data no data no data no data 0

67 Pinoxaden 243973-20-8 n (8) n (8) n (13) (16)n (13)

(16)n (13) (16) n (13) (16) n (8) n (8) 0

Remark:

y: criteria fulfilled

n: criteria not fulfilled

Bioaccummulation criteria: for KOW > 4 criteria fulfilled Persistence criteria: for

(a) persistent in water

(b) persistent in soil

(c) persistent in sediment

(2) [Gestis 2010]

(3) [ESIS 2010]

(8) [FOOTPRINT PPDB 2010]

(10) [IOBC 2005]

(11) [OSPAR 2005]

(12) [Miljominstriet 2004]

(14) [EC 2003]

(15) [WHO 2010]

(16) [EC 2009]

57

NoSubstance/

Substance group

CAS-No

(2) (3) (8)


PB

[log kow]T LRT

Muta-

genicity

Carcino-

genicity

Reproduc-

tive tox.

Endocrine

disruption

Immune

suppres

sion

Neuro-

toxicityRank

(9) [PAN PDB 2010] (13) Classification according to Regulation (EC) No 1272/2008/EC

58

Annex Table 2: Overview on costs for trifluralin and chemical alternatives in crop/pest specific applications

Substance Cost impact factor

per application, with

range and average

values [US$/ha]

Pest Country (origin of

costs)

Source of cost

information

Trifluralin - Cotton, rape, sunflower, wheat

Trifluralin 17.64-23.41 Weeds, grasses Canada [UNECE 2010, Dow II]7.57-9.84 UK [UNECE 2010, Dow II],

[UK Reply 2010], [Defra 2006]

8.13-16.25 USA [UNECE 2010, Dow II]Range 7.57-23.41

Average 15.49

Alternatives for cotton

Acetachlor No information Weeds

Bentazon 68.34 Weeds, grasses Canada [UNECE 2010, Dow II]

Clethodim 19.54 Annual grasses, weeds

Canada [UNECE 2010, Dow II]

32.50-37.50 USA [UNECE 2010, Dow II]28.57-35.38 Germany [LfL 2009/10]19.54-37.5028.52

Cycloxydim 34.02-57.15 Annual grasses, grass weeds

Germany [LfL 2009/10]45.59

Ethalfluralin 38.53-64.25 No information Canada [UNECE 2010, Dow II]

17.88-35.63 USA [UNECE 2010, Dow II]

17.88-64.25

41.07

Fluazifop-P-butyl 23.13-34.02 Annual grasses, weeds

Germany [LfL 2009/10]

28.57Fluometuron No information No information

Glufosinate 30.25 No information USA [UNECE 2010, Dow II]

Glyphosate 47.62-68.03 Weeds, couch grass Germany [LfL 2009/10]17.25 USA [UNECE 2010, Dow II]17.25-68.0342.64

Oxyfluorfen No information No information

Paraffin oil No information No information

Pendimethalin 32.65 Grasses, weeds Germany [LfL 2009/10]30.00-45.50 USA [UNECE 2010, Dow II]27.28 UK [Defra 2006]

59

27.28-45.5036.39

Propaquizafop 28.57-39.46 Grasses, weeds Germany [LfL 2009/10]34.02

Propyzamide 63.95-92.52 Weeds, grasses Germany [LfL 2009/10]63.60 UK [Defra 2006]63.60-92.5278.06

Quizalofop-P-ethyl No information Grass weeds

Quizalofop-P-tefuryl No information Grass weeds

s-Metolachlor 42.11-62.74 No information Canada [UNECE 2010, Dow II]

37.50-75.00 USA [UNECE 2010, Dow II]

37.50-75.00

56.25

Comparison Alternatives TrifluralinRange 17.25-92.52 7.57-23.41Average 44.52 15.49

Oilseed rape/rape – AlternativesBifenox 17.86 Weeds, grasses Germany [LfL 2009/10]

Carbetamide No information Grass weeds

Clethodim 28.57-35.38 Annual grasses, weeds

Germany [LfL 2009/10]32.50-37.50 USA [UNECE 2010, Dow II]19.54 Canada [UNECE 2010, Dow II]19.54-37.5028.52

Clomazone 44.90-73.47 Annual grasses, weeds


59.19Clopyralid 48.98-96.60 Weeds, grasses Germany [LfL 2009/10]

90.86 UK [UNECE 2010, Dow II]48.98-96.6072.79

Cycloxydim 34.02-57.15 Annual grasses, grass weeds


45.59Dimethachlor No information Weeds

Dimethenamide-P 32.65 Weeds, grasses Germany [LfL 2009/10]



28.57Glyphosate 47.62-68.03 Weeds, couch grass Germany [LfL 2009/10]

17.25 USA [UNECE 2010, Dow II]17.25-68.0342.64

Metazachlor 83.29 Weeds, annual grasses

UK [Defra 2006]39.46-83.29 Germany [LfL 2009/10]39.46-83.29

60

61.37Napropamide 81.25-162.5 Broad leaved weeds,

grassesUSA [UNECE 2010, Dow II]

121.88Oxadiargyl No information No information


Pethoxamide No information No information

Propachlor No information Broadleaved weeds, grasses

Propaquizafop 28.57-39.46 Grasses, weeds Germany [LfL 2009/10]34.02

Propyzamide 63.95-92.52 Weeds, grasses Germany [LfL 2009/10]63.60 UK [Defra 2006]63.60-92.5278.06

Prosulfocarb 68.69 Weeds Germany [LfL 2009/10]

Quizalofop-P 21.77-36.74 Annual grasses, weeds


29.25Quizalofop-P-ethyl No information Grass weeds


Tepraloxydim No information Weeds, grasses


Sunflower- AlternativesAcetachlor No information Weeds

Aclonifen No information Weeds

Dimethenamide-P 32.65 Weeds, grasses Germany [LfL 2009/10]



28.57Flurochloridone No information No information

Linuron No information No information


Pendimethalin 32.65 Grasses, weeds Germany [LfL 2009/10]30.00-45.50 USA [UNECE 2010, Dow II]27.28 UK [Defra 2006]27.28-45.5036.39

Pethoxamide No information No information


Quizalofop-P-ethyl No information Grass weeds

61



Wheat - AlternativesChlortoluron No information Grasses, weeds

Clodinafop 65.31 Annual grasses, weeds


Clodinafop-propargyl No information Grasses

Diflufenican No information Weeds

Fenoxaprop 38.10 Weeds Germany [LfL 2009/10]

Fenoxaprop-P-ethyl No information Grasses, weeds

Flufenacet No information Grasses

Flumioxazin No information No information

Flupyrsulfuron 35.38 Weeds, grasses Germany [LfL 2009/10]

Flupyrsulfuron-methyl No information Broadleaved weeds, grasses

Fluroxypyr 24.73-49.46 Weeds, grasses Germany [LfL 2009/10]37.09

Glyphosate 47.62-68.03 Weeds, couch grass Germany [LfL 2009/10]17.25 USA [UNECE 2010, Dow II]17.25-68.0342.64

Iodosulfuron 43.54 Weeds, grasses Germany [LfL 2009/10]

Isoproturon 14.97-39.46 Weeds, grasses Germany [LfL 2009/10]27.21

Mecoprop-P 23.35-39.84 Weeds, grasses Germany [LfL 2009/10]31.56

Mesosulfuron No information Grasses

Metsulfuron-methyl No information Weeds, grasses

Pendimethalin 32.65 Grasses, weeds Germany [LfL 2009/10]30.00-45.50 USA [UNECE 2010, Dow II]27.28 UK [Defra 2006]27.28-45.5036.39

Pinoxaden 34.35-46.71 Weeds, grasses Germany [LfL 2009/10]40.53

Propoxycarbazone 27.48-45.34 Weeds, grasses Germany [LfL 2009/10]36.41


Sulfosulfuron No information grasses

Triallate No information Grass weeds

62

Tribenuron 10.63-21.25 Grasses, weeds USA [UNECE 2010, Dow II]16.33-29.93 Germany [LfL 2009/10]10.63-29.9320.28


63

Annex Table 3: Substances for weed control in cotton

Alternative plant protection

product (ppp) (active substance or name or type)

Product example Crop or crop type

Controlled herbicide or herbicide type

Spray volume per acre broadcast

Time to apply Note Information source

cyanazine Bladex ® 4L0.8 to 2.0 qts.DuPont

cotton Henbit (weed) 10 to 30 gals. of water by ground. Add surfactant or crop oil if weeds have emerged.

During winter on idle land to be planted to cotton. Preemergence or postemergence to weeds.

Rate will depend upon soil type for preemergence control. If weeds have emerged, use 0.8 to 1.2 qts./ A for 2- to 3-inch henbit or 1.2 to 1.6 qts./A for 6- to 7-inch henbit. A surfactant or oil will enhance postemergence control. Additional herbicides will be needed for spring and summer weed control. This is a restricted use pesticide for use only by certified applicators. 1998 — Do not apply more than 5.0 qts. of Bladex ® 4L per acre per year. 1999-2002 — Do not apply more than 3 qts. of Bladex ® 4L per acre per year.

[Baumann 2010]

prometryn Caparol ® 4L1.2 to 1.6 pts.Novartis

cotton Henbit (weed), seedling dock

20 to 40 gals. of water. Add a surfactant at 1.0 qt. per 50 gals. of spray solution if weeds have emerged.

Fall or winter to bedded land either preemergence or postemergence to weeds.

Use in Gulf Coast and Blacklands only. For best results, apply before weed emergence. If henbit has emerged but is less than 4 to 6 inches tall, add a surfactant or emulsifiable oil. This is for winter weed control only. Additional herbicides will be needed for spring and summer weed control.

[Baumann 2010]

glyphosate + surfactant

Roundup ® Ultra1 pt. to 1 qt.Monsanto

cotton Henbit (weed), sunflower 3 to 10 gals. of water. Postemergence to weeds before planting.

Allow at least 2 weeks after application before tillage. [Baumann 2010]

oxyfluorfen Goal ® 1.6E1 to 2 pts.Rohm and Haas

cotton Selected broadleaf weeds Refer to label.

20 gals. of water by ground or 5 gals. Of water aerially.

Some residual weed control may be expected. [Baumann 2010]

monosodiumacid methanearsenate

MSMA ®1.33 qts. of 6 lbs./gal. productHelena and others

cotton Johnsongrass, nutsedge, cocklebur

30 to 40 gals of water. with surfactant.

Before planting. Apply once to emerged weeds and grass before planting. Cotton may be planted immediately.

[Baumann 2010]

paraquat Gramoxone ® Extra2 to 3 pts.orCyclone ®1.5 to 2 pts.Zeneca

cotton Emerged annual broadleaf weeds and grasses and topkill suppression of perennials

20 to 60 gals. of water plus 8 to 32 ozs. Of nonionic surfactant per 100 gals. of spray solution.

Beds should be preformed to permit maximum weed and grass emergence prior to treatment. Seeding should be done with minimum soil disturbance. Weeds and grasses emerging after application will not be controlled. This is a restricted use herbicide.

Before planting, by ground application to weeds and grasses from 1 to 6 inches high.

[Baumann 2010]

thifensulfuron + tribenuron

Harmony ® Extra0.5 to 0.6 oz.DuPont

cotton Numerous annual broadleaf weeds

Use sufficient carrier to ensure good weed coverage.

Postemergence at least 45 days prior to planting and to weeds less than 4inches tall or wide.

Add nonionic surfactant to spray mixture. Tank mixes with Roundup ® will hasten weed burndown.

[Baumann 2010]

glyphosate 8 ozs. To 2 pts.

Roundup ® Ultra8 ozs. to 2 pts.Monsanto

cotton Control of many annual broadleaf and grass weeds Refer to label for weed specific rates.

3 to 10 gals. of water for ground and 3 to 5 gals. for aerial applications. Add 0.5 to 1 percent nonionic surfactant (1.0 to 2.0 qts./50 gals. Of spray solution).

Prior to emergence of cotton.

Apply when weeds are growing vigorously and are 6 inches or less in height. Consult label for specific rate and weed heights. Do not apply by ground when winds are gusty or more than 5 mph. For aerial applications, do not apply during inversion conditions when winds are gusty, or under other conditions which will allow drift. Do not store, mix or spray in galvanized or unlined steel tanks except stainless steel. Do not mix with any residual pesticide. Allow 3 days before tillage. For burndown of johnsongrass, apply 1 pt./A before johnsongrass is 12

[Baumann 2010]

64







inches tall. For best results, apply 1 qt./A when johnsongrass is in the bootto- head growth stage. Wait 3 days before tillage.

glyphosate 2.0 to 5.0 qts.

Roundup ® Ultra2.0 to 5.0 qts.Monsanto

cotton Perennials: Control of many perennial weeds, such as: Bahiagrass, bermudagrass, bindweed, curly dock, dallisgrass, fescues, hemp dogbane, johnsongrass, milkweed, silverleaf nightshade, swamp smartweed, torpedograss, vaseygrass, wirestem muhly, Texas blueweed, clover (red and white), nutsedge (yellow & purple), perennial ryegrass, Canada thistle, horsenettle, woollyleaf bursage, fescue

10 to 40 gals. of water. Before planting or after harvest.

Apply when actively growing and when weeds have reached early head or early bud growth stage. See label for exact growth stage and rate and water carrier volume per acre. If weeds have been mowed or tilled, do not treat until regrowth has reached recommended stage. Allow 7 days or more after application before tillage. Do not graze treated cotton fields or feed forage to livestock within 8 weeks of application.

[Baumann 2010]

pendimethalin Prowl ® 3.3EC1.2 to 3.6 pts.American Cyanamid

cotton Control of many annual grasses and small-seeded broadleaf weeds Refer to label for weed specific rates

10 gals. of water or more by ground. 5 gals. or more by air. May also be applied impregnated on dry bulk fertilizer and with liquid fertilizer.

Immediately before planting or up to 140 days prior to planting.

Within 7 days after application incorporate 1 to 2 inches deep with a disk harrow, bed conditioner, PTO-driven tiller, cultivator, hoe or rolling cultivator. If loss of crop occurs, cotton or soybeans may be replanted. Other crops can be rotated with cotton the following year. Do not feed forage or graze livestock in treated cotton fields. Winter wheat or barley can be planted in the fall 4 months following application. Prowl ® may be applied at 1.2 to 3.6 pts./A and incorporated up to 60 days prior to planting for rhizome johnsongrass suppression.

[Baumann 2010]

norflurazon Zorial ® Rapid 800.6 to 2.5 lbs.Novartis

cotton Control of many annual grasses and broadleaf weeds Suppression of rhizome johnsongrass, nutsedge, lanceleaf sage, cocklebur, common ragweed, hemp sesbania, kochia, morningglory, Russian thistle, sicklepod, venice mallow Refer to label for weed specific rates.

10 to 20 gals./A by ground, 5 gals./A by air

In areas of Texas east of I-35, apply as a preplant incorporated, preemergence or split application. Consult label for more specific instructions. In areas west of I-35, use only in areas where soils contain less than 60 percent sand. Consult label for more specific instructions.

Rotate only with cotton, soybeans or peanuts the year following application. Not for use on sandy soils in West Texas. Crops other than cotton should not be replanted if stand is lost. Do not apply to furrow-planted cotton.

[Baumann 2010]

prometryn Caparol ® 4L1.6 to 4.8 pts.,

Caparol ® Accu Pak1 to 3 lbs.Novartis,

cotton Control of many annual broadleaf weeds and a few annual grasses Refer to label for weed specific rates.

20 to 40 gals. of water. Preemergence. Do not use on sand or loamy sand. Rainfall or irrigation is needed following application to obtain good weed control. Avoid broadcast applications to cotton planted in furrows more than 2 inches deep. Band applications should be no wider than the bottom of furrows. Cotton may be replanted through treated soil. Do not retreat. If Caparol ® is applied only as a single preemergence treatment during the season, several vegetables and oats, winter barley, wheat or rye

[Baumann 2010]

65







Several other prometrynproducts (Cotton Pro, GowanPrometryne 4L, RiversidePrometryne 4L) are currentlyavailable

may be planted. The small grains cannot be used for food or feed. Do not use on glandless cotton varieties, as crop injury will occur.

metolachlor Dual ® 8EorDual ® II 7.8E1.5 to 2.0 pts.Novartis

cotton Control of many annual grasses and some smallseeded broadleaf weeds

Minimum of 10 gals. Of water or liquid fertilizer.

Preplant incorporated or preemergence.

Do not apply on sand or loamy sand soils. Do not apply to furrow-planted cotton. Apply preemergence or incorporate no more than 1 inch deep before, at or after planting. Plant cotton at least 1 inch deep on fine soils and 1.5 inches deep on medium or coarse soils. For best control of yellow nutsedge, apply preplant incorporated.

[Baumann 2010]

metolachlor+ prometryn

Dual ® 8EorDual II ® 7.8 E1.25 to 2.0 pts.Caparol ® 4L1.6 to 4.8 pts.Caparol ® Accu Pak1.0 to 3.0 lbs.Novartis

cotton Control of many annual grasses and broadleaf weeds Refer to label for weed specific rates.

Minimum of 10 gals. Of water.

Preplant incorporated or preemergence.

Apply either preplant incorporated or preemergence using procedures suggested for Dual ® alone. Choose rate according to soil type. Do not apply to sand or loamy sand soil. Do not use with glandless cotton varieties. Observe label precautions when applying over furrow-planted cotton. Test compatibility of Dual ® and Caparol ® in a jar before mixing in tank.

[Baumann 2010]

Metolachlor +Fluometuron

Dual ® 8E or Dual II ® 7.8E1.25 to 2.0 pts.

Cotoran ® DF1.2 to 2.4 lbs.orCotoran ® 4L2.0 to 4.0 pts.orCotoran ® Accu Pak1.2 to 2.4 lbs.Novartis


Minimum of 10 gals. Of water.

Preemergence. Use in Gulf Coast, Rio Grande Valley and eastern Texas only. Do not apply on sand or loamy sand soils. Observe label precautions when applying to furrow-planted cotton. Test compatibility of Cotoran ® and Dual ® in a jar before mixing in tank. Injury may occur on high pH or low organic matter soils.

[Baumann 2010]

fluometuron Cotoran ® 4L2.0 to 4.0 pts.orCotoran ® DF1.2 to 2.4 lbs.Cotoran ® Accu Pak1.2 to 2.4 lbs.Novartis

Other fluometuron productsavailable include Meturon ®4L or DF and Riverside ®Fluometuron 4L or 80DF.


25 to 40 gals. of water or liquid nitrogen solution. A suspendibility agent may be necessary.

Preemergence or at planting following a preplant incorporated application of Prowl ® or Treflan ®.

Where dry weather conditions prevail, the herbicidal activity of Cotoran ® may be delayed or reduced. Do not plant crops other than cotton within 6 months of the last application. West Texas: Do not use on sand, loamy sand or fine sandy loam soils. Do not feed foliage from treated fields or gin trash to livestock.

[Baumann 2010]

diuron Karmex ® 80DF1.0 to 2.0 lbs.or

cotton Control of many annual grasses and broadleaf weeds Refer to label for

20 to 40 gals. of water by ground. 5 to 10 gals. aerially.

Preemergence. Use on sandy loam or heavier soils. Do not use with furrow-planted cotton. Cotton may be replanted through treated band or rework beds before planting. Do not retreat. If banded preemergence, any crop can

[Baumann 2010]

66







Direx ® 4L0.75 to 2.25 qts.DuPont, Griffin

Other diuron products availableinclude Drexel Diuron4L or 80W, and RiversideDiuron 80DF

weed specific rates be planted after 4 months. If broadcast preemergence or if banded preemergence followed by postemergence, only cotton, soybeans, corn or grain sorghum can be planted the next spring. Direx ® or Karmex ® may be applied at 0.25 to 0.75 lb. preemergence following a preplant application of Treflan ® on heavy soils. See label for specific instructions. Do not use on soils containing less than 1.0 percent organic matter.

Pyrithiobac Staple ®0.6 to 0.9 oz.DuPont

cotton For control of selected broadleaf weeds such as pigweed spp., lanceleaf sage, venice mallow and others Refer to label for weed specific rates.

Use a minimum of 10 gals. of water for ground applications. Use a minimum of 3 gals. Of water for aerial applications.

Preemergence. Refer to label for weed-specific application rates. Staple ® can be combined with diuron, flumeturon or prometryn products for expanded weed control. Refer to the Staple ® label for more information.

[Baumann 2010]

norflurazon Zorial ®1.25 to 2.5 lbs.Novartis

cotton Control of many annual grasses and broadleaf weeds Refer to label for weed specific rates. Suppression of cocklebur, morningglory and nutsedge

10 to 20 gals. of water by ground or 5 gals. aerially.

Preplant incorporated, preemergence or split application

Use preplant incorporated, preemergence or as a split application in East Texas where 40 inches of rain annually is expected. In areas with less than 40 inches of rainfall, apply as a preplant incorporated or split application only. Not for use in sandy soils in West Texas. Incorporate no deeper than 2 to 3 inches within 30 days of planting. Crops other than cotton should not be replanted if stand is lost. Rotate only with cotton, soybeans or peanuts the year following application.

[Baumann 2010]

cyanazine Bladex ® 90DF0.70 to 1.1 lbs.orBladex ® 4L0.6 to 1.0 qt.DuPont

cotton Control of selected annual broadleaf weeds Refer to label for weed specific rates.

20 to 40 gals. of water + 2 qts. of surfactant per 100 gals. of spray mixture.

As a directed spray after cotton is 6 inches tall and before weeds are 2 inches tall.

Direct the spray to the base of the cotton plants. Prevent spray from striking cotton leaves or injury may occur. Leaf lifters or shields on application equipment are recommended. Apply no more than two postemergence treatments following a preemergence application. Rotational crops may be planted in the fall or spring following treatment. Bladex ® may be combined with MSMA for enhanced weed control. For more information, refer to the label for more information. 1998 — apply no more than 3 lbs. active ingredient/A per year. 1999 to 2002 — apply no more than 1 lb. active ingredient/A per year. May not be applied after December 31, 2002. Enclosed cab required for application in 1998 and 1999. Bladex ® is a restricted use herbicide for use only by certified applicators.

[Baumann 2010]

prometryn Caparol ® 4L1.0 pt. early1.0 to 1.3 pts. lateorCaparol ® AccuPak0.6 lb. early0.6 to 0.8 lb. lateNovartis

cotton Control of selected annual broadleaf weeds Refer to label for weed specific rates.

20 to 40 gals. of water. When applied to emerged weeds, add 2 qts. of surfactant per 50 gals. of spray mix.

Early postemergence: 3- to 6-inch cotton. Late postemergence cotton at least 6 inches tall.

Apply as a directed spray being careful to avoid contact with cotton leaves. If applied when cotton is 3 to 6 inches tall, precision equipment with fenders should be used to avoid cotton damage. Do not apply to furrowplanted cotton until furrows are leveled (plowed in). Applications to cotton less than 10 inches tall should be made only when planted on the bed (not in a furrow). If only a single postemergence application is made, small grains and certain vegetables can be planted in the fall, but small grains cannot be grazed. If applied preemergence and postemergence or if multiple postemergence treatments were made, do not plant fall crops. Caparol ® may be combined with MSMA for enhanced weed control. Refer to the label for more information.

[Baumann 2010]

fluometuron Cotoran ® 4L2.0 to 4.0 pts.

cotton Control of selected annual broadleaf weeds

20 to 40 gals. of water. When applied to emerged

Postemergence when cotton is at least 3 inches

Apply as directed, semi-directed or over-the-top spray. Use higher rate after weeds have emerged. Do not plant crops other than cotton

[Baumann 2010]

67







orCotoran ® 85DF1.2 to 2.4 lbs.orCotoran ® AccuPak1.2 to 2.4 lbs.Novartis

Refer to label for weed specific rates.

weeds, add 1 qt. of surfactant per 50 gals. of spray mix.

tall and weeds less than 2 inches.

within 6 months of last application. Do not feed foliage or gin trash to livestock. Caparol ® may be combined with MSMA for enhanced weed control. Refer to the label for more information. West Texas: Do not use on sand, loamy sand or fine sandy loam soils.

diuron Direx ® 4L0.3 to 0.55 qt.Griffinor Karmex ® 80DF0.25 to 0.5 lb.DuPont

Cotton Most seedling broadleaf weeds and some annual grasses Refer to label for weed specific rates.

25 gals. of water + 1 pt. surfactant.

Postemergence directed spray after cotton is 6 inches high, as needed up to two applications.

Spray young, actively growing weeds less than 2 inches tall, not droughtstressed weeds. Apply laterally, not over the top of cotton. Avoid contact with cotton leaves. Any crop may be planted 4 months after last application. If multiple applications are made, see label for rotational crops. Direx or Karmex may be combined with MSMA for enhanced weed control. Refer to label for more information.

[Baumann 2010]

lactofen Cobra ® 2E12.5 ozs.Valent

cotton Control of many annual broadleaf weeds Refer to label for weed specific rates.

10 to 30 gals. of water. Use surfactant (2 pts. per 100 gals. of water) or crop oil concentrate (0.5 - 1 pt./A). Spraying pressure should be kept at 20 to 30 PSI to reduce potential for spray mist getting on cotton foliage.

Postemergence directed only. Cotton must be 6 to 8 inches tall, or apply at layby.

Use as a directed spray only; use equipment designed to keep spray off cotton foliage while maintaining weed coverage. Susceptibility of individual weeds is variable; therefore, consult COBRA ® label for specific application recommendations regarding stage of growth. Cobra ® may be used in combination with MSMA, Bladex ® and Karmex ® to aid in control of certain weeds. Consult specific product labels for recommendations and precautions.

[Baumann 2010]

dimethylsodium-arsenate

DSMA4.0 qts. of 3.6 lbs./gal. productorMSMA1.33 qts. of 6 lbs./gal. product

cotton Cocklebur, johnsongrass, nutsedge, puncturevine, ragweed, sandbur, some annual grasses

40 gals. of water + 1 to 2 pts. of surfactant per 50 gals. if not contained in the product.

Postemergence after cotton is 3 inches high and before first bloom.

Do not apply over the top or by plane. Apply as directed spray. Make a second application if necessary. Do not apply after first bloom. Apply to small broadleaves and grasses. Most effective at temperatures of about 70° F. Do not graze treated fields or feed foliage. Phytotoxic properties are quickly inactivated on contact with the soil.

[Baumann 2010]

pyrithiobac sodium

Staple ®1.2 to 1.8 ozs.DuPont

Cotton Control of many annual broadleaf weeds Refer to label for weed specific rates.

# Postemergence to most weeds when they are 1 to 4 inches tall. Consult label for specific weed, timing, and application rates. Add nonionic surfactant or crop oil concentrate.

Primarily a broadleaf weed herbicide but can be tank-mixed with MSMA, DSMA or Assure II for grass control. Staple has soil residual activity for preemergence control of some weeds. Do not apply more than 2.4 ozs. Of Staple per year, except in West Texas (west of Highway 83) where only 1.5 to 1.8 ozs. per year is allowed. Consult label.

[Baumann 2010]

fluazifop-p-butyl Fusilade ® DX 2E0.5 to 1.5 pts.Zeneca

cotton Control of many annual and perennial grass weeds only Refer to label for regional specifics on rates and weed treatment stages.

5 to 40 gals. of water + crop oil concentrate (1 qt./25 gals. Of final spray volume) or nonionic surfactant (0.5 t./25 gals. of final spray volume). Spray pressure of 30 to 60 PSI is suggested.

Postemergence over the top of cotton when grasses are actively growing. Apply when annual grasses are small (see label for size). Bermudagrass should be treated when no more than 3 inches tall or when runners are 6 to 12 inches. Rhizome johnsongrass should be 12 to 18 inches

Do not apply a total of more than 6.0 pts./A per season. Bermudagrass and rhizome johnsongrass may require two applications (see label). Higher rates or repeat applications are needed in West Texas on some grasses (see label). Where rainfall is adequate, soil residual may occur which will suppress new flushes of annual grasses. Do not plant rotational crops other than cotton or soybeans within 60 days after application. Avoid drift to grass type crops. Do not apply if rainfall is expected within 1 hour. Cultivation from 7 days before until 7 days after application may reduce control. Cultivation after 7 days will often assist grass control. When grasses are droughtstressed, control will be reduced. Do not use whirl chamber or flood-type nozzle tips. Fusilade

[Baumann 2010]

68







tall and before the boot stage.

DX ® may be applied as a spot treatment, using a 1 percent solution (1 qt. per 25 gals. water). Add 1 pt. of nonionic surfactant to this mixture.

fluazifop-p-butyl + fenoxaprop-p-ethyl

Fusion ®6 to 12 ozs.Zeneca

cotton Control of many annual and perennial grass weeds only Refer to label for regional specifics on rates and weed treatment stages.

5 to 40 gals. of water + crop oil concentrate (1 qt./25 gals. of final spray volume) or nonionic surfactant (0.5 pt./25 gals. of final spray volume). Spray pressure of 30 to 60 PSI is suggested.

Postemergence over the top of cotton to actively growing grasses. Avoid application to stressed weeds. Fusion ® may be applied as a spot treatment; refer to label for specific recommendation.

Do not apply more than 24 ozs. per acre of Fusion ® to the same crop per year. Do not plant grass crops such as corn, sorghum or wheat within 60 days of last Fusion ® application. Fusion ® may be applied as a spot treatment using a 1 percent solution (1 qt. In 25 gals. Water). Add 8 ozs. of a nonionic surfactant to this mixture.

[Baumann 2010]

clethodim Select ® 2ECAnnual grasses6 to 8 ozs.Perennial grasses8 to 16 ozs.Valent

Cotton Control of many annual and perennial grasses only Refer to label for weed specific rates.

Minimum of 5 gals./A ground and 3 gals./A by air. Always add 1 percent v/v (4 qts./per 100 gals. of spray solution) crop oil concentrate. Not less than 1 pt./A of finished spray volume.

Postemergence over the top of actively growing grasses. Do not apply to plants under environmental stress or those exceeding recommended growth stage on label. Treat rhizome johnsongrass from 12 to 18 inches tall. Treat bermudagrass up to 3 inches tall or up to 6- inch runners.

Do not cultivate treated grasses 7 days prior to or after herbicide application. Perennial grasses may require sequential applications. Consult label for recommendations specific to East and West Texas. Select ® may be applied as a spot treatment by mixing 8 ozs. into 25 gals. Of water for a 0.25 percent solution. Select ® may be tank mixed with cotton insecticide Orthene ® 90S.

[Baumann 2010]

quizalofop Assure II ® 0.88EC5 to 12 ozs.DuPont

cotton Control of many annual and perennial grasses only Weeds controlled may be area specific and rate specific; consult product label.

Minimum of 10 gals. In area I, 15 gals., in area II; consult label. Always add 1 percent v/v (4 qts. per 100 gals. of spray solution) crop oil concentrate or 0.25 percent v/v (1 qt. per 100 gals. of spray solution) of a nonionic surfactant. Aerial: Minimum of 3 gals./A in Area I. Minimum of 5 gals./A in Area II

Postemergence over the top of actively growing grasses. Do not apply to plants under environmental stress or those exceeding recommended growth stage on label.

Do not cultivate treated grasses 7 days prior to or after herbicide application. Perennial grasses may require sequential applications. Consult label for recommendations specific to East and West Texas. Assure II ® may be applied as a spot treatment by mixing 12 ozs. of product into 25 gals. of water or a 0.375 percent solution. Refer to label for additional instructions.

[Baumann 2010]

sethoxydim Poast Plus ® 1E12 to 48 ozs.BASF

cotton Control of many annual and perennial grasses only Refer to label for weed specific rates.

5 to 20 gals. of water at a minimum pressure of 40 psi + 2 pts. Of nonphytotoxic oil concentrate by ground. By air use a minimum of 5 gals. of water.

Postemergence over the top of actively growing grasses. See label for stages of various grasses.

Do not apply more than 7.5 pts./A in one season. Bermudagrass and rhizome johnsongrass may require two applications (see label). Do not apply to grasses under stress such as lack of moisture or herbicide injury, or unsatisfactory control will result. Cultivation no sooner than 7 days after application may aid season-long control. See label for rates for various grasses and growth stages. Poast Plus ® may be applied as a spot or small area treatment using a 1 percent solution. Refer to the label for more information.

[Baumann 2010]

oxyfluorfen Goal ® 2 XL1 to 2 pts.Rohm and Haas

cotton Control of many annual and perennial grasses only Refer to label for weed specific rates

20 to 40 gals. At 20 to 25 psi pressure. Add 2 to 4 pts. of nonionic surfactant per 100 gals. of spray solution. Two flat fan nozzles on each side of the row are suggested.

Postemergence as a directed spray to weeds not exceeding 4 true leaves. Succulent weeds in 2- to 3-leaf stage can usually be controlled at the low rate. Apply to cotton 6 to 8

Application in cotton less than 6 inches tall may result in severe crop injury. Precision ground spray equipment with fenders or shields should be used to avoid contact with foliage even in 6- to 8-inch cotton. Branch lifters may be necessary on cotton more than 8 inches tall. May be tank-mixed with MSMA.

[Baumann 2010]

69







inches tall.glyphosate + surfactant

Roundup ® Ultra0.5 to 5 qts./AMonsanto

cotton Control of numerous grasses and broadleaf weeds Suppression of some perennial weeds may be expected.

5 to 20 gals. of water by ground. 3 to 15 gals of water by air.

Postemergence to actively growing weeds using shielded application equipment.

Use specifically designed equipment to allow for coverage of target weeds but prevent application or drift of herbicide onto crop. Follow other label precautions. Roundup ® Ultra may be applied as a spot treatment in a 1 to 2 percent solution (1 qt. per 25 gals. water). Refer to label for additional instructions.

[Baumann 2010]


Roundup ® Ultra0.5 to 1 qt./AMonsanto

cotton Control of numerous grasses and broadleaf weeds Suppression of some perennial weeds may be expected

5 to 20 gals. of water by ground. 3 to 15 gals of water by air.

Postemergence over the top of cotton no larger than 4-true leaf stage of growth; then you must apply the product post-directed.

USE ONLY ON ROUNDUP READY COTTON VARIETIES. No more than two over-the-top or two post-directed applications may be made in a growing season. Application for these timings may not exceed 1 qt./A. Roundup ® Ultra may be applied as a broadcast treatment to Roundup ® Ready Cotton after 20 percent boll crack. Refer to label for more specific information.

[Baumann 2010]

bromoxynil Buctril ® 4EC0.75 to 1.0 pt.Rhone-Poulenc

cotton Control of numerous broadleaf weeds (No grass or sedge control)

Apply in 10 to 20 gals. of water to ensure good coverage.

Postemergence over the top of cotton.

Use only on cotton that has been GENETICALLY MODIFIED FOR TOLERANCE TO BUCTRIL ® (BXN COTTONS). Do note exceed 1 pt./acre per application or 3 pts./acre total per season. Do not apply within 75 days of harvest. To control grasses, Buctril ® may be applied 7 days prior to application of Assure ® II, Fusilade ® DX, Poast ® Plus, or Select ®. If the grass herbicides are applied first, wait 3 days to apply Buctril ® to avoid problems.

[Baumann 2010]

cyanazine Bladex ® 90DF0.9 to 1.8 lbs.orBladex ® 4L0.6 to 1.0 qt.DuPont

cotton Annual broadleaf weeds 20 to 40 gals. of water + 2 qts. of surfactant per 100 gals. of spray solution.

Postemergence as a directed spray after cotton is 12 inches tall.

Omit surfactant if no weeds are present at time of treatment. When applied prior to weed emergence, effectiveness depends on rainfall or irrigation. Bladex ® is a restricted use pesticide for use only by certified applicators.

[Baumann 2010]

prometryn Caparol ® 4L1.6 to 3.2 pts./AorCaparol ® AccuPak1.0 to 2.0 lbs.Novartis

cotton Annual grasses and broadleaves such as cocklebur, pigweed, gumweed, morningglory, common lambsquarters, devilsclaw, pie melon

25 gals. of water + 1 pt. of surfactant.

Postemergence as a directed spray when cotton is at least 12 inches tall and weeds are less than 2 inches tall.

Omit surfactant if no weeds are present at treatment time. In High Plains, 1.6 to 2.4 pts./A of Caparol ® 4L is sufficient. Do not use in Rio Grande Valley. See Caparol ® preemergence for rotational crop suggestions. Do not apply when cotton is under stress.

[Baumann 2010]


Roundup ® UltraRefer to label for weedcontrol ratesMonsanto1 pt. to 2 qts. for cottonregrowth inhibition

cotton Control of many annual and perennial grasses and broadleaf weeds Also provides cotton regrowth inhibition

10 to 20 gals. of water by ground or 3 to 15 gals. of water by air.

Apply after sufficient bolls have developed to produce the desired yield of cotton. Applications prior to this time could affect maximum yield potential.

Do not exceed 1 qt./A when applying aerially. For aerial applications, do not apply during inversion conditions, when winds are gusty, or under other conditions which allow drift. Do not apply by ground when winds are gusty or in excess of 5 mph. Do not apply to crops grown for seed. Allow at least 7 days between application and harvest. Do not feed or graze treated cotton seed forage or hay. This product may be combined with Def ® 6, Folex ®, or Prep ® to provide additional enhancement of cotton leaf drop. On ROUNDUP READY COTTON VARIETIES, up to 2 qts. per acre may be applied once boll crack exceeds 20 percent.

[Baumann 2010]


Roundup ® UltraMonsanto

cotton Control of numerous annual and perennial grasses and broadleaf weeds.

Mix 1.0 gal. of product in 2.0 gals. O f water to prepare a 33 percent solution. Some wick applicators may require a less concentrated solution.

When weeds are a minimum of 6 inches above the crop. Better results are obtained when more of the weed is exposed. Do not wipe any closer than 2

Keep wiper surface clean. Weeds not contacted by the herbicide will not be affected. Do not operate at speeds greater than 5 mph. As weed density increases, reduce speed. Wiping a second time in opposite directions may improve control. Do not use wiper when weeds are wet. Repeat treatment may be necessary. Oversaturation of wiper may cause dripping which will injure crop. Mix only enough

[Baumann 2010]

70







inches above desirable vegetation as injury may result.

solution for one day's operation. Drain and flush with water after use of applicators.

Annex Table 4: Substances for weed control in wheat

Alternative plant protection product (ppp) (active substance or name or type)



Spray volume per acre broadcast Time to apply Note Information source

s-metalochlor + prosulfocarb

Boxer GoldBayer 191 wheat ryegrass The product “Boxer Gold” contains a mix of s-metalochlor and prosulfocarb (Group E) providing similar levels of control to trifluralin and is active on trifluralin resistant biotypes.

Grains Research & Development Corporation, VNTFA, BCG, http://www.bcg.org.au/resources/FFST_Factsheet_Triflualin_Use_in_No-till_Farming_Systems.pdf

Annex Table 5: Substances for weed control in sunflowers




Rate range Time to apply Note Information source

imazamethabenz Assert 2.5 E conventional sunflower

wild mustard 0.6 to 0.8 pts (0.19-0.25 lb ai/A) postemergence apply imazethabenz when the majority of wild mustard plants are in the rosette stage and prior to bloom. Assert must always be applied with a nonionic surfactant at a rate of 2 pts/A.

[Durgan 2010]

quizalofop Assure II 0.88 ETarga 0.88 E

conventional sunflower

annual grasses, quackgrass

0.034 to 0.069 lb ai/A (5 to 10 oz/A)

5-10 fl oz (0.034-0.069 lb ai/A)

A crop oil concentrate at 1% v/v or a nonionic surfactant at 0.25% v/v must always be added to the spray solution. However, do not use vegetable oil as an additive, sincecontrol will be reduced compared to other additives.

[Durgan 2010]

imazomox Beyond 1 S clearfield sunflower

several annual grasses and broadleaf weeds

4 oz (0.3 lb ai/A) postemergence to actively growing 3 inch tall weeds

Labeled for use on Clearfield Sunflower varieties only. Do not apply to non-labeled varieties. A nonionic surfactant at 0.25% v/v and either a liquid fertilizer at 1 to 2.5% v/v or ammonium sulfate at 5 to 15 lbs per 100 gal of spray solution is required.

[Durgan 2010]

s-metolachlor Dual Magnum 7.62 E, Charger Basic 7.62 E


annual grass, some annual broadleaf weeds;

1-2 pts (0.96-1.91 lb ai/A), rate is dependent on soil type

preplant incorporated or preemergence

Dual Magnum will give early season control of eastern black and hairy nightshade.

[Durgan 2010]

EPTC Eptam 20 G, Eptam 7 E

conventional

annual grasses Eptam 20 G 10-22.5 Ibs, Eptam 7 E 2.5-5.25 pts (2-4.5 lb

preplant incorporated in fall or spring

Do not apply Eptam 20 G in spring. Wild oat control is generally not adequate. EPTC is volatile, therefore,

[Durgan 2010]

71




Rate range Time to apply Note Information source

sunflower ai/A) it needs to be incorporated immediately after application to prevent herbicide loss.

tribenuron Express 50 SG ExpressSun sunflower

broadleaves 0.25-0.5 oz (0.008-0.016 ib ai/A) postemergence Apply from the 1-leaf stage to prior to bud formation. Do not apply more than 1.0 oz/A postemergence during the same sunflower growing season. Application to non-ExpressSun trait sunflower may cause severe crop injury or death of the plant.

[Durgan 2010]

sethoxydim Poast 1.5 E conventional sunflower

annual grasses andsuppression of perennial grasses

0.5 to 2.5 pts (0.09-0.5 lb ai/A) Postemergence when grasses are 2-6 inches and actively growing

Sunflowers have good tolerance to sethoxydim. An oil concentrate at 1 qt/A must be used for consistently good grass control. Sethoxydim will not control broadleaf weeds. Quackgrass may require two applications.

[Durgan 2010]

pendimethalin Pendant 3.3 E, Pendimax 3.3 E, Prowl 3.3 E, Prowl H20 3.8 CS


annual grassesand some broadleaf weeds.

Pendant 3.3 E, Pendimax 3.3 E, Prowl 3.3 E 1.2-3.6 pts (0.5-1.5 lb ai/A); Prowl H20 3.8 CS 1.5-3 pts (0.7-1.4 lb ai/A)

preplant incorporated in fall or spring; can be appliedpreemergence to no-till sunflowers; apply immediately after planting or up to 30 days before planting

Wild mustard and wild oats control is not satisfactory. Pendimethalin can be tank mixed with EPTC (Eptam) in the fall only. Do not apply to emerged sunflowers.

[Durgan 2010]

pendimethalin Stealth 3.3 E conventional sunflower

annual grasses, some broadleaf weed

1.2-3.6 pts (0.5-1.5 lb ai/A) preplant incorporated in fall or spring; preemergence in no till

[Durgan 2010]

sulfentrazone Spartan 4 F, Spartan 75 DF


several small seeded broadleaf weeds

Spartan 4 F 3-6 oz, Spartan 75 DF 2-4 oz, (0.094-0.188 ib ai/A);rate is dependent on soil type

preplant incorporated or preemergence

Do not apply Spartan after the sunflowers have emerged. Best herbicide activity occurs if Spartan is applied to moist soil and followed by approximately 1 inch of rainfall. One to two inches of rainfall is required on dry soil.

[Durgan 2010]

clethodim Arrow 2 ECIntensity 2 ECIntensity One 0.97 ECSection 2 ECSelect Max 0.97 EC


annual grasses, quackgrass

Arrow 2 EC, Intensity 2 EC, Section 2 EC 6-16 oz/A (0.094-0.25 lb ai/A);Intensity One 0.97 EC 0.56-0.75 pt (0.068-0.09 lb ai/A);Select Max 0.97 EC 9-12 fl oz (0.068-0.09 lb ai/A)

postemergence when grasses are 2-8 inches and actively growing

Sunflower has good tolerance to clethodim. Always add COC at 1-2 pts/A and AMS at 2.5 lb/A (recommended) for Arrow 2 EC, Intensity 2 EC and Section 2 EC.

[Durgan 2010]

ethalfluralin Sonalan 10 G, Sonalan 3 E


annual grasses, common lambsquarters, kochia and pigweed

Sonalan 10 G 5.5-11.5 lbs, Sonalan 3 E 1.5-3 pts (0.57-1.12 lb ai/A);rate is dependent on soil type

preplant incorporated Wild oat control is not adequate. Ethalfluralin has not given satisfactory wild mustard control.

[Durgan 2010]

72

Annex Table 6: Substances for weed control in oilseed rape


Product example Crop or crop typeControlled

herbicide or herbicide type

Costs Time to apply Note Information source

cycloxydim Various e.g. Laser plus adjuvant oilseed rape weeds 25-33£/l, up to 1.5 l/ha postemergence From expanded cotyledons to crop canopy closing, weeds from 2 leafs.

Note label for adjuvant requirements. [Davies 2005]

fluazifop-p-butyl Fusilade Max oilseed rape weeds 22-25£/l, up to 1.5 l/ha postemergence From 1 leaf to before flowerbuds on crop. Weeds from 2 leafs. [Davies 2005]

propaquizafopVarious e.g. Falcon oilseed rape weeds

25-30£/l, up to 1.5 l/ha; some products /excluding Falcon) require LERAP (B)

assessment

postemergence From expanded cotyledons to before flowerbuds appear. Weeds from 2 leafs. [Davies 2005]

quizalofop-p-ethyl CoPilot/Sceptre plus adjuvant oilseed rape weeds 30£/l, up to 0.625l/ha for

CoPilot postemergence From expanded cotyledon to before crop canopy closes. Weeds from 2 leafs. Note label for adjuvant requirement. [Davies 2005]

clomazone Centium oilseed rape broad-leaved weeds

0.25 l/ha90£/l preemergence Preemergence of crop and weeds. Seed covered with 20mm soil. Not on

sands or VLS. [Davies 2005]

propachlor Ramrod oilseed rape broad-leaved weeds 5£/l, 9-13 l/ha preemergence Preemergence or after 3 leafes of crop, but preemergence of weeds. Not

on broadcast crops. May be most active residual on organic soils. [Davies 2005]

clopyralid Dow Shield oilseed rape broad-leaved weeds 55£/l, up to 0.5-1 l/ha postemergence From 2 leafs of crop to flowerbuds visible. Up to 4-6 leafs of weeds. [Davies 2005]

metazachlorVarious e.g. Butisan S weeds, broad-

leaved weeds 20£/kg, up to 1.5 l/ha Pre- or early postemergence

Premergence (within 48 h of sowing) or from fully expanded cotyledons of crop. Preemergence of weeds, or seedling weeds depending on species. Do not use on broadcast crops or stony or very sandy soil.

[Davies 2005]

pyridate (SOLA)Lentagran WP oilseed rape broad-leaved

weeds

10£/kg, 2kg/ha (SOLA 011663 until Dec 2008) LERAP (B) assessment

required

postemergence From 6 leafs on crop to before flower buds. Weeds 4-6 leafs. [Davies 2005]

73

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