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
4.1
Management options .................................................................................................................. 15
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 nonchemical 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
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
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.
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
Molecular formula
Molecular mass
Appearance at normal
temperature and pressure
Pa
Water solubility
g/l
g/l
mg/l
mg/l
mg/l
Log Koc
Henry´s Law Constant
Atmospheric OH Rate Constant
Value
C13H16F3N3O4
335.28
Reference
[OSPAR 2005]
[OSPAR 2005]
bright orange crystalline solid
[OSPAR 2005]
g/mole
Vapour pressure
Melting point
Boiling point
Log Kow
4
Unit
°C
°C
[l/kg]
Pa m3/mol
9.5 x 10-3Pa at 25 °C (100% pur.)
6.1 x 10-3Pa at 25 °C (96.8% pur.)
1.94 x 10-4 (unbuffered 100% pur.)
pH 7: 2.21 * 10-4
pH 5: 0.184
pH 7: 0.221
pH 9: 0.189
43.0-47.5 °C
not determined, decomposition
5.27 at 20 °C (100% pur.)
4.13 (calc.)
3.81-4.13 (meas.)
no pH-dependency
19 x 10-3 (calc.)
4.12 x 10-3 (meas. 20 °C)
cm3/molecule-sec
[OSPAR 2005]
[OSPAR 2005]
[OSPAR 2005]
[Health Canada 2008]4
[Health Canada 2008]1
[Health Canada 2008]1
[OSPAR 2005]
[OSPAR 2005]
[OSPAR 2005]
[OSPAR 2005]
15 Pa m3 mol-1
[OSPAR 2005]
[OSPAR 2005]
[Health Canada 2008]1
24.0039 x 10-12 5
[EU DAR 2005]
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
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
6
It was not indicated in which year the production of trifluralin stopped.
9
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
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. Nonagricultural 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-
7
According to Health Canada at the TFPOP meeting, Montreal, 18 to 20 Mai 2010
10
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
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 3-1: Known use of trifluralin within the UNECE region in 2010
UNECE Parties
EU Member States
CH
Norway
USA
Other UNECE Parties
Current use of trifluralin in t/a
0
1.97t/a
0
2,500-3,000
No data available
Source
Decision
[UNECE 2010, CH]
[UNECE 2010, NO]
[UNECE 2010, USA]
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
8
http://prtr.ec.europa.eu/PollutantReleases.aspx, March 2010
11
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
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
13
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 EPRTR 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.
14
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
15
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
17
http://www.helcom.fi/Recommendations/en_GB/rec19_5/?u4.highlight=trifluralin
16
dicotyledonous weeds. The major crops for which trifluralin is applied to 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.
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].
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.
17
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
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 4-1.
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 4-1 and [LfL 2009/10] in
Annex Table 2). As demonstrated in Table 4-1, 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 4-1: Chermical alternatives indicated in the UNECE questionnaire and in the received answers to the additional query
No
Substance
Frequency of
mentions
Pest or
pest type
Crops
01
Acetachlor (5) (8) (10)
3
cotton (8), sunflower (10)
weed (10)
02
Aclonifen (13)
1
sunflower (13)
not specified
03
Bensulide (1)
1
not specified
not specified
Bentazon (1) (7)
2
cotton (8), field peas, beans (7)
Bifenox (7) (11)
2
oilseed rape, brassicas (7)
Carbetamide (7)
1
oilseed rape, cabbage (7)
Chlortoluron (13) (7) (1) (11)
4
wheat (13), winter wheat (7)
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
04
05
06
07
18
broad leaved weeds (narrow weed
spectrum), charlock (7)
broad leaved weeds , grasses,
charlock, runch, volunteer spring rape
(7), weeds, grasses (11)
black grass, wild oats, Italien rye grass,
grass weeds (7)
wild oats, rye grass, annual meadow
grass, grass weeds (7), grasses, weeds
(11)
annual grasses,
No
Substance
Frequency of
mentions
Pest or
pest type
Crops
(7)
weed (11)
1
winter wheat (7)
wild-oats, grasses (7)
Clomazone (7) (11) (13) (15)
4
rape (11), cabbage (13) (15), peas,
beans, brassicas, carrots, oilseed rape
(7), winter oilseed rape, seed crops of
cabbage and other brassicas (15)
annual grasses, weeds (11), cleavers
and other broadleaved weeds, grasses
(7), weeds (15)
Clopyralid (1) (9) (11) (7)
4
oilseed rape (9), turnip (11), sugar
beet, brassicas, oilseed rape (7)
Cycloxydim (1) (7) (8) (11)
4
oilseed rape (1), cotton (8), brassicas,
oilseed rape, sugar beet (7)
DCPA (1) (6) (8)
3
carrots, caulifower, onion, cabbage,
ladies finger, pepper, tomatoes (8)
not specified
15
Diclofop-methyl (8)
1
cabbage (8)
not specified
16
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 specified
20
Ethalfluralin (1) (8)
2
cotton (8)
not specified
21
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)
Fluazifop-P-butyl (1) (8) (11)
(7)
4
cotton, sunflower (8), oilseed rape (7)
(11), sugar beet (7)
Flufenacet (13) (7)
2
wheat (13), winter wheat (7)
25
Flumioxazin (13)
1
wheat (13)
not specified
26
Fluometuron (8)
1
cotton (8)
not specified
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 specified
Fluroxypyr (7) (11)
2
winter wheat (7)
broad leaved weeds (7) (11), grasses
(7) (11), cleavers, volunteer potato (7)
Glufosinate (1) (8) (13)
3
cotton (8), turnip (13)
not specified
Glyphosate (1) (8) (11) (7)
4
cotton (8), wheat (11), beans, peas,
Weeds, grass weeds (11), couch grass
winter wheat, oilseed rape, sugar beet
(7)
(7)
33
Imazamox (1) (4)
2
not specified
not specified
34
Imazethapyr (1)
1
not specified
not specified
Iodosulfuron (1) (11) (7)
3
Isoproturon (1)* (6) (7) (11)
4
grasses, weed (11), black grass, rye
grass (7)
grasses , weed (7) (11), black-grass (7),
wild-oats (7), annual meadow grass (7)
Linuron (8) (10)
2
wheat, barley, rye (11), winter wheat
(7)
wheat (7) (11), winter wheat (7),
barley, rye (11), winter cereals (7)
sunflower (8), parsley, carrot, celery,
soya, lupin, peas (10), carrots (7)
Mecoprop-P (7) (11)
2
winter wheat (7)
Mesosulfuron (1) * (7)
2
winter wheat (7)
Mesotrione (1)
1
not specified
10
Clodinofop-propargyl (7)
11
12
13
14
23
24
27
30
31
32
35
36
37
38
39
40
19
weeds (9) (7) (11), thistle, mayweed,
broadleaved weeds (7), grasses (7)
(11)
annual grasses (11), grass weeds,
volunteer cereals (7), as shepherds
purse, cranesbill, charlock (7)
annual grasses, weeds (11), grass
weed, barley cover crop, volunteer
cereals, weeds (7)
rye grass, annual meadow grass, grass
weeds (7)
not specified
broad leaved weeds (7), weeds (11),
grasses (7) (11), cleavers (7)
black-grass, rye-grass, Italian rye grass,
annual meadow grass (7)
not specified
No
41
Substance
Frequency of
mentions
Pest or
pest type
Crops
Metazachlor (1) (6) (7) (10)
(11) (13)
6
oilseed rape (7) (9) (10),
brassicas/cabbage (7) (10) (13),
mustard (10), turnip (13)
weed (7),
annual grasses (10), black grass,
broadleaved weeds, poppy (7)
Metsulfuron-methyl (7)
1
winter wheat (7)
broad leaved weeds, grasses (7)
Metribuzin (8) (10) (14)
3
44
Napropamide (1) (7) (8) (9)
(13)
5
45
Oxadiargyl (7)
1
oilseed rape, brassicas (7)
weed (7)
46
Oxadiazon (10)
1
onion, garlic, leak (10)
weed (10)
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
Paraffin oil (8)
1
cotton (8)
not specified
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)
Pethoxamide (13)
1
sunflower, rape (13)
not specified
Pinoxaden (7)
1
winter wheat (7)
wild oats, Italien rye grass (7), weeds,
grasses (11)
Propachlor (1) (6) (7)
3
brassicas, oilseed rape (7)
broadleaved weeds, grasses (7)
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)
Propoxycarbazone (7) (11)
2
winter wheat (7)
grasses, weeds (7)
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)
Prosulfocarb (7) (11) (13)
3
sunflower, wheat, barley (13), oilseed
rape, brassicas (7)
weeds (11)
Quizalofop-P (11)
1
oilseed rape (11)
annual grasses, weeds (11)
42
43
47
48
49
50
51
52
53
54
55
56
57
58
tomatoes (8) (14) (10), peppers (10)
(14), carrots (7)
pepper, tomatoes (8) (10), winter
oilseed rape (7) (10) (13)
cotton, sunflower, carrots, onion,
cabbage, pepper, tomatoes (8),
oilseed rape (7)
cotton, sunflower, tomatoes (8),
oilseed rape (7)
weeds, annual grasses (10)
broad leaved weeds, grasses (7)
Quizalofop-p-ethyl (7) (8)
2
Quizalofop-p-tefuryl (7) (8)
2
60
Sethoxydim (1)
1
not specified
not specified
61
s-Metolachlor (1) (5) (8)
3
cotton, tomatoes (8)
not specified
62
Sulfentrazone (1)
1
not specified
not specified
63
Sulfosulfuron (7)
1
winter wheat (7)
brome grasses (7)
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)
Tri-allate (7)
1
winter wheat, beans, peas (7)
grass weeds, wild-oats (7)
Tribenuron (1) (11)
2
wheat, barley, rye (11)
grasses,
weed (11)
59
64
65
66
20
volunteer cereals, grass weeds (7)
grass weeds (7)
No
Substance
Frequency of
mentions
Crops
Pest or
pest type
(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]
* 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
21
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
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].
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
22
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].
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-weedemergence 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 4-1.
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].
23
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, fathen, 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
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 agroecosystems 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 environment24.
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
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)
24
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.
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].
25
http://www.acresusa.com/toolbox/reprints/Organic%20weed%20control_aug02.pdf, February 2010
26
http://ohioline.osu.edu/b789/pdf/01.pdf, February 2010.
25
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
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.
26
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 4-2 shows an overview of the expected cost impacts:
Table 4-2: Overview on expected cost impacts
Type of cost impact
Quantification
In countries where trifluralin is already banned and where trifluralin is not produced the cost
impacts on industry are nil or negligible.
Cost impacts on industry
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 agriculture
Expected annual cost impacts on agricultural production would range from 9.02 to 10.86 million
USD.
Cost impacts on consumers
Annual cost impacts due to possible price increases of agricultural products could amount up to
10.86 million USD.
Cost impacts for
governments and authorities
Cost impacts on environment
and health
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.
High, non-monetarised benefits for environment and health.
27
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 4-3 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-pbutyl and haloyxyfop-r [INERIS 2007].
28
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: 17.6423.41 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 4-3: Crop specific chemical alternatives and their cost differences in % to the mean application costs of trifluralin
(15.49 USD/ha)
Crop
Cotton
Alternative
substance to
trifluralin
Acetachlor
Clethodim
Bentazon
Cycloxydim
Ethalfluralin
Fluazifop-P-butyl
Oilseed rape
Fluometuron
Glufosinate
Glyphosate
Oxyfluorfen
Paraffin oil
Pendimethalin
Propaquizafop
Propyzamide
Quizalofop-p-ethyl
Quizalofop-p-tefuryl
s-Metolachlor
Bifenox
Carbetamide
Clethodim
Clomazone
Clopyralid
Cycloxydim
efficiency
Weed
Annual grasses,
weeds
weeds, grasses
Annual grasses, grass
weeds
Not specified
Annual grasses,
weeds
Not specified
Not specified
Weeds, couch grass
Not specified
Not specified
Annual grasses, weed
Grasses, weeds
weeds, grasses
grass weeds
grass w eeds
Not specified
Weeds, grasses
Grass weeds
Annual grasses,
weeds
Annual grasses,
weeds
Weeds, grasses
Annual grasses, grass
weeds
28
Average cost a.i./ha
overview [US$/ha]
Cost difference in %
No information
28.52
+84
68.34
45.59
+341
+194
41.07
28.57
+165
+84
No information
30.25
42.64
No information
No information
36.39
34.02
78.06
No information
No information
56.25
17.86
No information
28.52
+95
+175
+135
+120
+404
+263
+15
59.19
+282
72.79
45.59
+370
+194
+84
Dow Chemicals indicated costs range for the USA from 3.25-6.50 US$/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].
29
Dimethachlor
Dimethenamid-P
Fluazifop-P-butyl
Glyphosate
Metazachlor
Napropamide
Oxadiargyl
Oxyfluorfen
Propachlor
Pethoxamide
Prosulfocarb
Propaquizafop
Propyzamide
Quizalofop-P
Sunflower
Wheat/Winter wheat/Winter
Cereals
Quizalofop-P-ethyl
Quizalofop-P-tefuryl
Tepraloxydim
Aclonifen
Acetachlor
Dimethenamid-P
Fluazifop-P-butyl
Flurochloridone
Linuron
Oxyfluorfen
Pendimethalin
Pethoxamide
Prosulfocarb
Quizalofop-p-ethyl
Quizalofop-p-tefuryl
Clodinafop
Clodinafop-propargyl
Chlortoluron
Diflufenican
Fenoxaprop
Fenoxaprop-P-ethyl
Flufenacet
Flumioxazin
Fluroxypyr
Flupyrsulfuron
Flupyrsulfuronmethyl
Glyphosate
Iodosulfuron
Isoproturon
Mecoprop-P
Mesosulfuron
Metsulfuron-methyl
Pendimethalin
Pinoxaden
Prosulfocarb
Propoxycarbazone
Sulfosulfuron
Tri-allate
Tribenuron
Weeds
Weeds, grasses
Annual grasses,
weeds
Weeds, couch grass
Weeds, annual
grasses
broad leaved weeds,
grasses
Not specified
Not specified
Broadleaved weeds,
grasses
Not specified
Weeds
Grasses, weeds
weeds, grasses
annual grasses,
weeds
Grass weeds
Grass weeds
weeds, grasses
Not specified
Weed
Weeds, grasses
Annual grasses,
weeds
Not specified
Not specified
Not specified
Annual grasses, weed
Not specified
Weed
grass weeds
grass weeds
Annual grasses, weed
grasses
Grasses, weeds
weeds
weeds
grasses, weed
grasses
Not specified
grasses and weeds
grasses and weeds
Broadleaved weeds,
grasses
weeds, couch grass
grasses and weed
grasses and weed
grasses and weeds
grasses
grasses, weeds
grasses and weeds
grass and weeds
weeds
grasses, weeds
grasses
grass weeds
grasses, weed
30
No information
32.65
28.57
+111
+84
42.64
61.37
+175
+296
121.88
+687
No information
No information
No information
-
No information
68.69
34.02
78.06
29.25
+343
+120
+404
+89
No information
No information
No information
No information
No information
32.65
28.57
+111
+84
No information
No information
No information
36.39
No information
68.69
No information
No information
65.31
No information
No information
No information
38.10
No information
No information
No information
37.09
35.38
No information
+135
+343
+322
+146
+139
+128
-
42.64
43.54
27.21
31.60
No information
No information
36.41
40.53
68.69
36.41
No information
No information
20.28
+175
+181
+76
+104
+135
+162
+343
+135
+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
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 4-4 and Annex
Table 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 4-4.
31
Table 4-4:
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
Average
Cost range
Average
Cost range
No. of
No of
Pest spectrum
cost
trifluralin
costs
alternatives
available
alternativ
covered by
trifluralin
[USD/ha]
alternatives
[USD/ha]
alternatives
es with
alternatives
(number of
lower to
Cotton
15.49
7.57-23.41
44.52 (187)
17.25-92.52
equal
indication)
costs
17 (6)
4
7
4
No info
without cost
in %)
weeds
alternatives
Grasses or
[USD/ha]
(cost increase
weeds
[USD/ha]
Grasses &
Crop
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 4-4 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
32
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 4-4 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
33
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 4-4. 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 4-5.
Table 4-5: 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
Cheaper
crop
alternatives
Cotton
Oilseed rape
Sunflower
Wheat
Lowest cost on
Average cost cheapest
alternative
alternatives [USD/ha)
[USD/ha]
Clethodim
19.54
Ethalfluralin
17.88
Fluazifop-p-butyl
23.13
Glyphosate
17.25
Bifenox
17.86
Clethodim
19.54
Fluazifop-p-butyl
23.13
Glyphosate
17.25
Quizalofop
21.77
Fluazifop-p-butyl
23.13
Glyphosate
17.25
Isoproturon
14.97
Mecoprop-P
23.35
Tribenuron
10.63
Average
corresponding increase in
comparison to trifluralin
(15.49USD/ha)[%]
19.45
26
19.91
29
23.13
49
16.55
7
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 4-6).
34
Table 4-6: 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
unknown
unknown
15.49
185
unknown
Rest of the UNECE
region
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
unknown
unknown
15.49
28
unknown
Rest of the UNECE
region
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.
35
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 4-6 possible cost impacts on agriculture and therefore
on consumers in the UNECE region, for which the used trifluralin quantity is known (USA), range from 59.6171.64 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.
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
29
See for example http://www.pan-uk.org/pestnews/Issue/Pn32/pn32p9.htm
36
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 redraftings 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.
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
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.
37
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:
38
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.
39

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.
40
References
[AT Reply 2010]
Austria (2010): Agency for Health and Food Safety. Submitted information in course of the additional request
on alternatives to trifluralin, Feb/March 2010.
[Baumann 2010]
Baumann, P. A. (2010): Suggestions for Weed Control in Cotton. Texas Agricultural Extension Service, The
Texas A&M University System; http://lubbock.tamu.edu/cotton/pdf/weedcot.pdf, January 2010.
[Böhm et al. 2002]
Böhm, E., Hillenbrand, T., Marscheider-Weidemann, F. (2002): Ermittlung der Quellen für die prioritären
Stoffe nach Artikel 16 der Wasserrahmenrichtlinie und Abschätzung ihrer Eintragsmengen in die Gewässer in
Deutschland. Fraunhofer-Institut für Molekularbiologie und Angewandte Ökologie im Auftrag des
Umweltbundesamtes.
[Boutsalis 2006]
Boutsalis, P. (2006): Trifluralin resistance in annual ryegrass. Research Update for Advisers - Southern
Region. Grains Research and Development Corporation, Adelaide.
[Brimble et al. 2005]
Brimble, S., Bacchus, P. and Caux P.-Y. (2005): Pesticide Utilisation in Canada: A Compilation of Current Sales
and Use Data.
[Claver et al. 2006]
Claver, A., Ormad, P., Rodriguez, L. And Ovelleiro, J.L. (2006): Study of the presence of pesticides in surface
waters in the Ebro river basin (Spain). Chemosphere 64 (9), 1437-1443.[Crowe et al. 2006]
Crowe, B., Lindner, B., Llewellyn, R. (2006): The benefits and beneficiaries of “public” investment in herbicide
use research and development. Contributed paper prepared for presentation at the International
Association of Agricultural Economists Conference, Gold Coast, Australia, August 12-28, 2006.
[Davies 2005]
Davies, K. (2005): Weed Management in Spring Oilseed Rape Crops, Technical Note (TN579), SAC 2005,
Edinburgh.
[Defra 2006]
Department for Enviornment, Food and Rural Affairs. Pesticides Safety Directorate (2006): Assessment of the
agronomic impact of Directive 91/414/EEC and legislation on maximum residue levels, submitted by Dremo
Associates Ltd., Defra, York.
[D’Emden et al. 2006]
D'Emden, F.H., Llewellyn, R.S., Burton, M.P. (2006): Adoption of conservation tillage in Australian cropping
regions: An application of duration analysis. Technological Forecasting and Social Change, in press, corrected
proof.
[DK Reply 2010]
Denmark (2010): Aarhus University. Faculty of Agricultural Sciences. Department of Integrated Pest
Management. Submitted information in course of the additional request on alternatives to trifluralin, April
2010.
41
[Donald, D. et al. 1999]
Donald, D., Syrgiannis, J., Hunter, F., Weiss, G. (1999): Agricultural pesticides threaten the ecological integrity
of northern prairie Wetlands. The Science of the Total Environment, 231, 173-181.
[Durgan 2010]
Durgan, B.R. (2010): Weed Control in Sunflower.
http://appliedweeds.cfans.umn.edu/weedbull/Sunflower%202008.pdf.
[EC 2003]
http://ec.europa.eu/food/plant/protection/evaluation/newactive/mesosulfuron_en.pdf, February 2010.
[EC 2009]
Globally Harmonized System of Classification and Labelling of Chemicals including first adaption of the
regulation 1272/2008/EC. (2009):
http://www.unece.org/trans/danger/publi/ghs/ghs_rev01/01files_e.html
http://www.unece.org/trans/danger/publi/ghs/ghs_rev01/01amend_e.html
[EFSA 2009]
European Food Safety Authority (2009): Conclusion on Pesticide Peer Review. Peer review of the pesticide
risk assessment of the active substance trifluralin, Parma.
http://www.efsa.europa.eu/de/scdocs/doc/327r.pdf
[E-PRTR 2010]
The European Pollutant Release and Transfer Register (2010): Pollutants Releases of Trifluralin.
http://prtr.ec.europa.eu/PollutantReleases.aspx, March 2010.
[ESIS 2010]
European chemical Substances Information System. http://ecb.jrc.ec.europa.eu/esis/, February 2010.
[EU DAR 2005]
EU DAR (2005): Draft Assessment Report (DAR). Public version. Initial Risk Assessment provided by the
rapporteur Member State Greece for the existing active substance Trifluralin of the second stage of the
review programme referred to in Article 8(2) of Council Directive 91/414/EEC. January 2005.
[FIBL 2005]
Research Institute of Organic Agriculture (2005): Overview of international organic market development and
potential export markets for organic products of Ukraine.
[Fluoride Action Network 2006]
Fluoride Action Network (2006): Pesticide Project. Trifluralin. (Note the website does not contain
information about when this page was last updated, but the site contains references to documents dated
2006), http://fluoridealert.org/pesticides/trifluralin-page.htm.
[FOOTPRINT PPDB 2010]
FOOTPRINT Pesticide Properties Database. http://sitem.herts.ac.uk/aeru/footprint/en/index.htm, February
2010.
[Gestis 2010]
Institute for Occupational Safety and Health of the German Social Accident Insurance (IFA), GESTISSubstance Database. http://biade.itrust.de/biaen/lpext.dll?f=templates&fn=main-h.htm, February 2010.
42
[Greenpeace 2010]
Greenpeace (2010): Die Schwarze Liste der Pestizide II - Vergleichende Umwelt- und Gesundheitsbewertung
von Pestizidwirkstoffen, Greenpeace 2010.
http://www.greenpeace.de/fileadmin/gpd/user_upload/themen/umweltgifte/Schwarze_Liste_der_Pestizide
_II_2010.pdf.
[GR Reply 2010]
Greece (2010): Hellenic Ministry of Agriculture, Directorate of Plant Protection, Department of Pesticides.
Submitted information in course of the additional request on alternatives to trifluralin, Feb/March 2010.
[Health Canada 2008]
Health Canada (2008): Re-evaluation Decision Trifluralin. PRVD2008-22. Health Canada Pest Management
Regulatory Agency. http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_prvd2008-22/index-eng.php.
[Health Canada 2009]
Health Canada (2009): Re-evaluation Decision Trifluralin RVD2009-09; Health Canada Pest Management
Regulatory Agency, 2009.
[Health Canada 2010]
Health Canada (2010): http://www.hc-sc.gc.ca/cps-spc/pest/registrant-titulaire/index-eng.php, February
2010.
[Health Canada, PMRA 2010]
Health Canada, Pest Management Regulatory Agency (2010): Database for registered pesticides in Canada
(search field: active ingredient, operator: contains, criteria: trifluralin, registration status: registered,
marketing type: domestic, commercial, manufacturing concentrate, technical active, historically not
specified), http://pr-rp.pmra-arla.gc.ca/portal/page?_pageid=34,17551&_dad=portal&_schema=PORTAL,
February 2010.
[HELCOM 2010]
Helsinki Commission, Baltic Marine Environment Protection Commission (2010):
http://www.helcom.fi/Recommendations/en_GB/rec19_5/?u4.highlight=trifluralin, February 2010.
[IARC 1991]
International Agency for Research on Cancer (1991): Occupational Exposures in Insecticide Application and
some pesticides. IARC Monographs on the evaluation of carcinogenic risks to humans, Volume 53. IARC,
Lyon, France, 1991, p. 515-535.
[IJF 2005]
Indian Journal of Fertilisers (2005): Current Status of Organic Farming in India and other Countries. Vol. 1 (9).
December 2005 p. 111-123.
[INERIS 2007]
Institut National de l'EnviRonnement industriel et des rISques (2007) : Données technico-économiques sur
les substances chimiques en France : Trifluraline. http://rsde.ineris.fr/fiches_technico.php, February 2010
[IOBC 2004]
International Organisation for Biological and Integrated Pest Managment IOBC / WPRS Commission (2004):
“IP-Guidelines and Endorsement”, Commission “Directives de PI et Agrément” Integrated Production,
43
Principles and Technical Guidelines, 3rd Edition.
[IOBC 2005]
International Organisation for Biological Control wprs Working Group "Pesticides and Beneficial Organisms &
IOBCwprs Commission “IP Guidelines and Endorsement” (05.12.2005 Comm.) and Working Document on
Selectivity of Pesticides (2005). http://www.iobc.ch/2005/IOBC_Pesticide%20Database_Toolbox.pdf and
http://www.iobc.ch/2005/Working%20Document%20Pesticides_Explanations.pdf.
[LfL 2009/10]
Bayerische Landesanstalt für Landwirtschaft, Institut für Pflanzenschutz (2009/10):
winter oilseed rape: http://www.lfl.bayern.de/ips/landwirtschaft/08960/linkurl_0_14.pdf;
wheat: http://www.lfl.bayern.de/ips/landwirtschaft/06460/linkurl_0_28.pdf;
summer wheat: http://www.lfl.bayern.de/ips/unkraut/35241/linkurl_0_3.pdf;
turnip: http://www.lfl.bayern.de/ips/unkraut/16803/linkurl_0_4.pdf.
[Loux et al. 2010]
Loux, M.M., Stachler, J.M, Johnson, W.G., Nice, G.R.W., Bauman, T.T. (2010), Ohio State University Extension,
Department of Horticulture and Crop Science. http://ohioline.osu.edu/b789/index.html, February 2010.
[LT Reply 2010]
Lithuania (2010): State Plant Protection Service. Submitted information in course of the additional request
on alternatives to trifluralin, Feb/March 2010.
[Martens; Martens 2002]
Martens, M.-H., Martens, K. (2002): Organic Weed Control. Cultural & Mechanical Methods. Acres USA; Vol.
32; No. 8.
http://www.acresusa.com/toolbox/reprints/Organic%20weed%20control_aug02.pdf.
[Miljöministeriet 2004]
Danish Environmental Protection Agency.
http://www2.mst.dk/common/Udgivramme/Frame.asp?http://www2.mst.dk/udgiv/publications/2004/877614-434-8/html/bred03_eng.htm, February 2010.
[Oligae 2010]
Oligae (2010): http://www.oilgae.com/ref/glos/acetyl_coa_carboxylase__accase_.html, March 2010.
[OSPAR 2005]
OSPAR Commission (2005): OSPAR background document on trifluralin.
[Owen et al. 2005]
Owen, M., Walsh, M., Powles, S.B. (2005): Frequency of herbicide resistance in annual ryegrass populations
across the WA wheat belt Agribusiness Crop Updates. Department of Agriculture, Western Australia, Perth.
[PAN UK 2010]
Pesticide Action Network UK (2010): factsheet on trifluralin. http://www.panuk.org/pestnews/Actives/Triflura.htm, February 2010.
[PAN 2007]
Pesticide Action Network (2007): Pesticides Database, 2007. Rawlings, N.C., Cook, S.J., Waldbillig, D. (1998):
44
Effects of the pesticides carbofuran, chlorpyrifos, dimethoate, lindane, triallate, trifluralin, 2,4-D, and
pentachlorophenol on the metabolic endocrine and reproductive endocrine system in ewes. J. Toxicol. Env.
Health (Part A) 54: 21- 36.
[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.
45
[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.
46
[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/ta
bid/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/ta
bid/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.
47
[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-R95-040, 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
48
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 Kow 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].
49
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.
50
Annex Table 1: Overview of results from the screening risk assessment of chemical alternatives compared to trifluralin
Risk indicators: POP criteria
No
Substance/
Substance group
CAS-No
(2) (3) (8)
0
Trifluralin
1582-09-8
1
Acetachlor
34256-82-1
2
Linuron
330-55-2
3
Bensulide
741-58-2
4
Fluazifop-P-butyl
79241-46-6
5
Pendimethalin
40487-42-1
6
Metribuzin
21087-64-9
119738-06-6
7
Quizalofop-ptefuryl
Risk indicators: adverse effects
P
y (a), (b)
(11) (8)
y (a)
(8)
y (a) (8)
y (a)
(8)
y (a)
(8)
y (a)
B
[log kow]
T
y (11)
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
n (11)
y (16)
no data
no data
no data
(8)
(8)
(8)
5.27 (8)
y (16)
4.14 (8)
y (13)
3 (8)
y (13)
y (13)
4.2 (8)
y (13)
n (8)
no data
(8)
4.5 (8)
4.5-5.3
no data
y (13)
(8)
(12)
5.2 (8)
y (13)
y (a) (8)
1.65 (8)
y (13)
n (8)
4.32 (8)
y (15)
(8)
LRT
y (8)
y (8)(13)
(8)
possibly
(8)
no data
(8)
(8)
y (8)
no data
(8)
(8)
n (8)
y (8)
(8)
no data
no data
possibly
possibly
51
Immune
Muta-
y (8)
suppres
sion
Neurotoxicity
Rank
5
n (8)
4
n (8)
4
y (8)
4
possibly
no data
(8)
(8)
y (8)
n (8)
possibly
no data
(8)
(8)
no data
no data
(8)
(8)
4
4
3
3
Risk indicators: POP criteria
No
Substance/
Substance group
Risk indicators: adverse effects
CAS-No
(2) (3) (8)
8
Oxadiazon
19666-30-9
9
Isoproturon
34123-59-6
10
Imazamox
114311-32-9
11
Propyzamide
23950-58-5
12
Tepraloxydim
149979-41-9
13
EPTC
14
Aclonifen
74070-46-5
15
Oxadiazon
16
Oxadiargyl
759-94-4
P
y (b) (8)
y (a)
(8)
y (a)
(8)
y (a), (b)
(8)
y (a)
(8)
y (a)
B
[log kow]
T
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
y (8)
no data
possibly
5.33 (8)
(8)
no data
Immune
suppres
sion
Neurotoxicity
Rank
n (8)
3
n (8)
3
n (8)
3
n (8)
3
no data
3
y (8)
3
n (8)
3
2.5 (8)
y (13)
y (13)
n (8)
5.36 (8)
y (13)
n (8)
n (8)
3.3 (8)
y (13)
y (8)
n (8)
y (16)
y (16)
no data
possibly
no data
(8)
(8)
possible
possible
no data
(8)
(8)
(8)
y (8)
no data
n (8)
3
y (16)
no data
no data
3
0.2 (8)
3.2 (8)
y (15)
y (a) (8)
4.37 (8)
y (8)
19666-30-9
y (b) (8)
5.33 (8)
n (13) (16)
39807-15-3
y (a) (8)
n (8)
y (13)
(8)
LRT
Muta-
n (8)
n (13)
possibly
(16)
(8)
n (13)
(16)
52
n (13) (16)
(8)
n (8)
no data
(8)
Risk indicators: POP criteria
No
Substance/
Substance group
CAS-No
(2) (3) (8)
17
Dimethachlor
50563-36-5
18
Clethodim
99129-21-2
19
Clomazone
81777-89-1
20
21
22
23
DCPA (chlorthal
dimethyl)
Ethalfluralin
Fenoxaprop-pethyl
Glufosinate
(ammonium)
Risk indicators: adverse effects
1861-32-1
55283-68-6
71283-80-2
77182-82-2
24
Glyphosate
1071-83-6
25
Mesotrione
104206-82-8
P
y (a) (8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
B
[log kow]
T
LRT
Endocrine
genicity
genicity
tive tox.
disruption
y (8)
no data
n (8)
2
n (8)
n (8)
2
n (8)
2
n (8)
y (15)
n (9)
4.58 (8)
-3.96 (8)
n (13)
-3,2 (8)
y (13)
0.11 (8)
y (13)
(8)
sion
Neurotoxicity
no data
(8)
(8)
possibly
possibly
no data
no data
(8)
(8)
(8)
(8)
possibly
no data
no data
(8)
(8)
(8)
no data
possibly
no data
no data
(8)
(8)
(8)
(8)
n (8)
y (8) (16)
no data
(8)
n (8)
53
possibly
suppres
possibly
n (8)
4.28 (8)
5.11 (8)
Reproduc-
(8)
4.14 (8)
2.54 (8)
Carcino-
possibly
2.17 (8)
Immune
Muta-
n (8)
n (8)
no data
(8)
n (8)
no data
(8)
n (8)
Rank
2
2
2
n (8)
2
n (8)
2
n (8)
2
Risk indicators: POP criteria
No
26
27
Substance/
Substance group
s-Metolachlor
Oxyfluorfen
CAS-No
(2) (3) (8)
51218-45-2
42874-03-3
28
Fluometuron
2164-17-2
29
Diclofop-methyl
51338-27-3
30
Quizalofop-pethyl
Risk indicators: adverse effects
P
y (a)
(8)
y (a)
(8)
y (a, b)
B
[log kow]
3.4 (8)
T
y (13)
4.86 (8)
4.47-5.21
(12)
2.38 (8)
y (15)
n (8)
4.8 (8)
y (13)
100646-51-3
y (a) (8)
4.61 (8)
y (a) (8)
2,96 (8)
y (8)
4.48 (8)
n (8)
(8)
LRT
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
possibly
no data
possibly
(8)
(8)
(8)
possibly
no data
no data
(8)
(8)
(8)
possibly
no data
(8)
(8)
possibly
possibly
no data
(8)
(8)
(8)
possibly
no data
no data
(8)
(8)
(8)
no data
no data
no data
(8)
(8)
(8)
no data
no data
no data
no data
(8)
(8)
(8)
(8)
no data
no data
(8)
(8)
n (8)
n (8)
31
Pethoxamide
106700-29-2
32
Prosulfocarb
52888-80-9
33
Flufenacet
142459-58-3
y (a) (8)
3.2 (8)
y (8)
n (8)
34
Flumioxazin
103361-09-7
n (8)
2.55 (8)
y (8)
n (8)
y (a, c)
(8)
54
Immune
Muta-
y (8)
no data
(8)
suppres
sion
Neurotoxicity
Rank
n (8)
2
n (8)
2
n (8)
2
n (8)
2
n (8)
2
2
2
n (8)
2
n (8)
2
Risk indicators: POP criteria
No
Substance/
Substance group
CAS-No
(2) (3) (8)
(a, b, c)
4.2 (8)
69377-81-7
y (a) (8)
n (8)
n (13) (16)
16484-77-8
y (a) (8)
n (8)
y (6)
74223-64-6
y (a) (8)
n (8)
y (6)
2303-17-5
n (8)
105512-06-9
n (8)
n (8
no data
no data
(8)
(8)
83164-33-4
36
Fluroxypyr
37
Mecoprop-P
39
40
methyl
Tri-allate
Clodinafoppropargyl
[log kow]
T
y
Diflufenican
Metsulfuron-
P
B
y (8)
35
38
Risk indicators: adverse effects
41
Iodosulfuron
185119-76-0
42
Bentazon
25057-89-0
43
Clodinafop
114420-56-3
y (a, c)
(8)
y (a)
(8)
y
4.06 (8)
-0.46 (8)
LRT
Muta-
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
n (13)
n (13)
n (13)
(16)
(16)
(16)
n (13)
n (13) (16)
(16)
n (13)
(16)
n (13)
(16)
n (13)
(16)
n (13)
y (16)
(16)
y (16)
n (8)
n (13)
-0.44 (8)
55
no data
(8)
no data
(8)
n (8)
no data
(8)
no data
(8)
n (8)
no data
no data
(8)
(8)
no data
Immune
suppres
sion
Neurotoxicity
n (8)
2
y (8)
2
n (8)
2
n (8)
2
n (8)
2
n (8)
1
y (8)
1
n (8)
1
n (8)
n (8)
no data
no data
no data
no data
(8)
(8)
(8)
(8)
(8)
Rank
1
Risk indicators: POP criteria
No
Substance/
Substance group
Risk indicators: adverse effects
CAS-No
(2) (3) (8)
44
Cycloxydim
101205-02-1
45
Imazethapyr
81335-77-5
46
Clopyralid
1702-17-6
47
Metazachlor
67129-08-2
48
Napropamide
15299-99-7
49
Propachlor
1918-16-7
50
Sethoxydim
74051-80-2
51
Sulfentrazone
122836-35-5
52
Propaquizafop
111479-05-1
P
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a)
(8)
y (a, c)
(8)
n (8)
y (a, c)
(8)
y (a, b)
(8)
n (8)
B
[log kow]
T
LRT
Muta-
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
possibly
no data
(8)
(8)
1.36 (8)
n (8)
1.49 (8)
n (8)
-2.63 (8)
n (16)
n (8)
2.49 (8)
n (8)
3.3 (8)
n (8)
1.6
y (13)
1.65
n (10)
possibly
(8)
56
(8)
possibly
no data
(8)
(8)
no data
no data
(8)
(8)
possibly
(8)
n (8)
no data
no data
(8)
no data
(8)
(8)
no data
no data
(8)
(8)
possibly
possibly
no data
(8)
(8)
(8)
n (8)
4.78 (8)
no data
no data
n (8)
1 (8)
n (8)
Immune
suppres
sion
Neurotoxicity
Rank
n (8)
1
n (8)
1
n (8)
1
n (8)
1
n (8)
1
n (8)
1
n (8)
1
no data
1
n (8)
1
Risk indicators: POP criteria
No
Substance/
Substance group
CAS-No
(2) (3) (8)
53
Fluorchloridone
61213-25-0
54
Dimethenamid-P
163515-14-8
55
Chlortoluron
15545-48-9
56
Paraffin oil
8042-47-5
57
Bifenox
42576-02-3
58
Carbetamide
16118-49-3
59
Fenoxaprop
95617-09-7
60
61
Propoxycarbazon
e
Sulfosulfuron
Risk indicators: adverse effects
145026-81-9
141776-32-1
P
y (a, d)
(8)
y (a) (8)
y (a, c)
(8)
no data
(8)
y (8)
(a) (8)
y (8)
(a) (8)
B
[log kow]
Muta-
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
no data
possibly
no data
(8)
(8)
(8)
possibly
possibly
no data
(8)
(8)
(8)
no data
possible
no data
(8)
(8)
(8)
n (8)
n (8)
n (13) (16)
n (13) (16)
n (13) (16)
n (13) (16)
T
LRT
3.36 (8)
1.89 (8)
2.5 (8)
5.0 (8)
n (8)
n (13) (16)
n (8)
n (13) (16)
y (a) (8)
n (8)
no data
no data
(8)
(8)
n (8)
n (8)
n (13)
(16)
n (13)
(16)
Immune
suppres
sion
Neurotoxicity
n (8)
n (8)
n (8)
1
n (8)
n (8)
1
no data
no data
(8)
(8)
no data
(8)
n (8)
no data
no data
no data
no data
no data
(8)
(8)
(8)
(8)
(8)
(8)
n (13) (16)
n (13) (16)
no data
no data
(8)
(8)
possible
no data
no data
(8)
(8)
(8)
n (13)
(16)
y (6)
n (6)
57
1
1
no data
y (6)
Rank
n (8)
1
1
1
1
1
Risk indicators: POP criteria
No
Substance/
Substance group
CAS-No
(2) (3) (8)
62
Tribenuron
106040-48-6
63
Mesosulfuron
400852-66-6
64
Flupyrsulfuron
150315-10-9
65
Flupyrsulfuronmethyl
66
Quizalofop-P*
67
Pinoxaden
Risk indicators: adverse effects
144740-54-5
243973-20-8
P
B
T
[log kow]
LRT
Muta-
Carcino-
Reproduc-
Endocrine
genicity
genicity
tive tox.
disruption
no data
no data
possibly
(8)
(8)
(8)
n (8)
n (14)
n (8)
n (8)
no data
no data
no data
(8)
(8)
n (8)
1.16 (8)
no data
no data
n (8)
n (8)
n (13)
n (13) (16)
(16)
Immune
suppres
sion
no data
n (8)
(8)
Bioaccummulation criteria: for KOW > 4 criteria fulfilled
n: criteria not fulfilled
0
(8)
(8)
no data
no data
no data
(8)
(8)
(8)
(8)
no data
no data
no data
no data
(8)
(8)
(8)
(8)
no data
no data
no data
no data
0
n (13) (16)
n (13) (16)
n (8)
n (8)
0
Persistence criteria: for
(a)
persistent in water
(b)
persistent in soil
(c)
persistent in sediment
(2) [Gestis 2010]
(10) [IOBC 2005]
(3) [ESIS 2010]
(11) [OSPAR 2005]
(15) [WHO 2010]
(8) [FOOTPRINT PPDB 2010]
(12) [Miljominstriet 2004]
(16) [EC 2009]
(9) [PAN PDB 2010]
(13) Classification according to Regulation (EC) No
58
n (8)
Rank
possibly
(14) [EC 2003]
1272/2008/EC
toxicity
no data
Remark:
y: criteria fulfilled
Neuro-
0
0
0
Annex Table 2: Overview on costs for trifluralin and chemical alternatives in crop/pest specific applications
Substance
Cost impact factor
Pest
Country
per application, with
costs)
(origin
of
Source
of
cost
information
range and average
values [US$/ha]
Trifluralin - Cotton, rape, sunflower, wheat
Trifluralin
17.64-23.41
7.57-9.84
Range
8.13-16.25
7.57-23.41
Average
15.49
Weeds, grasses
Canada
UK
[UNECE 2010, Dow II]
[UNECE 2010, Dow II],
[UK Reply 2010],
[Defra 2006]
USA
[UNECE 2010, Dow II]
Alternatives for cotton
Acetachlor
No information
Weeds
Bentazon
68.34
Weeds, grasses
Canada
[UNECE 2010, Dow II]
Clethodim
19.54
Annual
weeds
Canada
[UNECE 2010, Dow II]
USA
Germany
[UNECE 2010, Dow II]
[LfL 2009/10]
Annual grasses, grass
weeds
Germany
[LfL 2009/10]
No information
Canada
[UNECE 2010, Dow II]
USA
[UNECE 2010, Dow II]
Germany
[LfL 2009/10]
grasses,
32.50-37.50
28.57-35.38
Cycloxydim
19.54-37.50
28.52
34.02-57.15
Ethalfluralin
45.59
38.53-64.25
17.88-35.63
17.88-64.25
41.07
Fluazifop-P-butyl
23.13-34.02
Fluometuron
28.57
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]
USA
[UNECE 2010, Dow II]
Germany
USA
[LfL 2009/10]
[UNECE 2010, Dow II]
UK
[Defra 2006]
Annual
weeds
grasses,
17.25
17.25-68.03
Oxyfluorfen
42.64
No information
No information
Paraffin oil
No information
No information
Pendimethalin
32.65
30.00-45.50
Grasses, weeds
27.28
59
27.28-45.50
36.39
Propaquizafop
Propyzamide
28.57-39.46
34.02
63.95-92.52
Grasses, weeds
Germany
[LfL 2009/10]
Weeds, grasses
Germany
[LfL 2009/10]
UK
[Defra 2006]
Canada
[UNECE 2010, Dow II]
USA
[UNECE 2010, Dow II]
63.60
63.60-92.52
78.06
Quizalofop-P-ethyl
No information
Grass weeds
Quizalofop-P-tefuryl
No information
Grass weeds
s-Metolachlor
42.11-62.74
No information
37.50-75.00
37.50-75.00
56.25
Comparison
Range
Alternatives
17.25-92.52
Average
44.52
Bifenox
17.86
Carbetamide
No information
Grass weeds
Clethodim
28.57-35.38
Annual
weeds
grasses,
Annual
weeds
grasses,
32.50-37.50
19.54
Clomazone
19.54-37.50
28.52
44.90-73.47
Trifluralin
7.57-23.41
15.49
Oilseed rape/rape – Alternatives
Weeds, grasses
Germany
[LfL 2009/10]
Germany
[LfL 2009/10]
USA
Canada
[UNECE 2010, Dow II]
[UNECE 2010, Dow II]
Germany
[LfL 2009/10]
Weeds, grasses
Germany
UK
[LfL 2009/10]
[UNECE 2010, Dow II]
Annual grasses, grass
weeds
Germany
[LfL 2009/10]
59.19
Clopyralid
48.98-96.60
90.86
48.98-96.60
Cycloxydim
72.79
34.02-57.15
Dimethachlor
45.59
No information
Weeds
Dimethenamide-P
32.65
Weeds, grasses
Germany
[LfL 2009/10]
Fluazifop-P-butyl
23.13-34.02
Annual
weeds
Germany
[LfL 2009/10]
Weeds, couch grass
Germany
USA
[LfL 2009/10]
[UNECE 2010, Dow II]
Weeds,
grasses
UK
[Defra 2006]
Germany
[LfL 2009/10]
grasses,
28.57
Glyphosate
Metazachlor
47.62-68.03
17.25
17.25-68.03
42.64
83.29
39.46-83.29
39.46-83.29
annual
60
Napropamide
61.37
81.25-162.5
Oxadiargyl
121.88
No information
No information
Oxyfluorfen
No information
No information
Pethoxamide
No information
No information
Propachlor
No information
Broadleaved
grasses
Propaquizafop
28.57-39.46
34.02
Propyzamide
63.95-92.52
63.60
63.60-92.52
Broad leaved weeds,
grasses
USA
[UNECE 2010, Dow II]
Grasses, weeds
Germany
[LfL 2009/10]
Weeds, grasses
Germany
UK
[LfL 2009/10]
[Defra 2006]
Weeds
Germany
[LfL 2009/10]
Germany
[LfL 2009/10]
weeds,
Prosulfocarb
78.06
68.69
Quizalofop-P
21.77-36.74
Quizalofop-P-ethyl
29.25
No information
Grass weeds
Quizalofop-P-tefuryl
No information
Grass weeds
Tepraloxydim
No information
Weeds, grasses
Comparison
Range
Average
Alternatives
17.25-162.50
50.18
Trifluralin
7.57-23.41
15.49
Acetachlor
No information
Aclonifen
No information
Weeds
Dimethenamide-P
32.65
Weeds, grasses
Germany
[LfL 2009/10]
Fluazifop-P-butyl
23.13-34.02
Annual
weeds
Germany
[LfL 2009/10]
Germany
[LfL 2009/10]
USA
UK
[UNECE 2010, Dow II]
[Defra 2006]
Germany
[LfL 2009/10]
Annual
weeds
grasses,
Sunflower- Alternatives
Weeds
grasses,
28.57
Flurochloridone
No information
No information
Linuron
No information
No information
Oxyfluorfen
No information
No information
Pendimethalin
32.65
Grasses, weeds
30.00-45.50
27.28
Pethoxamide
27.28-45.50
36.39
No information
No information
Prosulfocarb
68.69
Weeds
Quizalofop-P-ethyl
No information
Grass weeds
61
Quizalofop-P-tefuryl
No information
Grass weeds
Comparison
Alternatives
Trifluralin
Range
Average
23.13-68.69
41.58
7.57-23.41
15.49
Wheat - Alternatives
Chlortoluron
No information
Grasses, weeds
Clodinafop
65.31
Annual
weeds
Clodinafop-propargyl
No information
Grasses
Diflufenican
No information
Weeds
Fenoxaprop
38.10
Weeds
Fenoxaprop-P-ethyl
No information
Grasses, weeds
Flufenacet
No information
Grasses
Flumioxazin
No information
No information
Flupyrsulfuron
35.38
Weeds, grasses
Flupyrsulfuron-methyl
No information
Broadleaved
grasses
Fluroxypyr
24.73-49.46
37.09
47.62-68.03
Glyphosate
grasses,
Germany
[LfL 2009/10]
Germany
[LfL 2009/10]
Germany
[LfL 2009/10]
Weeds, grasses
Germany
[LfL 2009/10]
Weeds, couch grass
Germany
[LfL 2009/10]
USA
[UNECE 2010, Dow II]
weeds,
17.25
17.25-68.03
Iodosulfuron
42.64
43.54
Weeds, grasses
Germany
[LfL 2009/10]
Isoproturon
14.97-39.46
Weeds, grasses
Germany
[LfL 2009/10]
Mecoprop-P
27.21
23.35-39.84
Weeds, grasses
Germany
[LfL 2009/10]
Mesosulfuron
31.56
No information
Grasses
Metsulfuron-methyl
No information
Weeds, grasses
Pendimethalin
32.65
30.00-45.50
Grasses, weeds
Germany
USA
[LfL 2009/10]
[UNECE 2010, Dow II]
UK
[Defra 2006]
Weeds, grasses
Germany
[LfL 2009/10]
Weeds, grasses
Germany
[LfL 2009/10]
Prosulfocarb
27.48-45.34
36.41
68.69
Weeds
Germany
[LfL 2009/10]
Sulfosulfuron
No information
grasses
Triallate
No information
Grass weeds
Tribenuron
10.63-21.25
Grasses, weeds
USA
[UNECE 2010, Dow II]
27.28
27.28-45.50
Pinoxaden
Propoxycarbazone
36.39
34.35-46.71
40.53
62
16.33-29.93
10.63-29.93
Germany
Comparison
Range
20.28
Alternatives
10.63-68.69
Trifluralin
7.57-23.41
Average
40.24
15.49
63
[LfL 2009/10]
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
cyanazine
Bladex ® 4L
0.8 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.
prometryn
Caparol ® 4L
1.2 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.
glyphosate +
surfactant
Roundup ® Ultra
1 pt. to 1 qt.
Monsanto
Goal ® 1.6E
1 to 2 pts.
cotton
Henbit (weed), sunflower
3 to 10 gals. of water.
Postemergence to weeds
before planting.
cotton
Selected broadleaf weeds
Refer to label.
20 gals. of water by ground
or 5 gals. Of water aerially.
oxyfluorfen
Note
Information source
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.
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]
Allow at least 2 weeks after application before tillage.
[Baumann 2010]
Some residual weed control may be expected.
[Baumann 2010]
[Baumann 2010]
Rohm and Haas
monosodiumacid
methanearsenate
MSMA ®
1.33 qts. of 6 lbs./gal.
product
Helena 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 ® Extra
2 to 3 pts.
or
Cyclone ®
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.
Before planting, by ground application to weeds and grasses from 1 to
6 inches high.
[Baumann 2010]
thifensulfuron +
tribenuron
Harmony ® Extra
0.5 to 0.6 oz.
cotton
Numerous annual
broadleaf weeds
Use sufficient carrier to
ensure good weed
coverage.
Add nonionic surfactant to spray mixture. Tank mixes with Roundup ®
will hasten weed burndown.
[Baumann 2010]
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).
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.
Postemergence at least 45
days prior to planting and to
weeds less than 4inches tall
or wide.
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]
DuPont
glyphosate 8 ozs.
To 2 pts.
Roundup ® Ultra
8 ozs. to 2 pts.
Monsanto
64
Alternative plant
protection
product (ppp)
(active substance
or name or type)
glyphosate 2.0 to
5.0 qts.
Product example
Roundup ® Ultra
2.0 to 5.0 qts.
Crop or
crop
type
cotton
Monsanto
pendimethalin
Prowl ® 3.3EC
1.2 to 3.6 pts.
American Cyanamid
cotton
norflurazon
Zorial ® Rapid 80
0.6 to 2.5 lbs.
cotton
Novartis
prometryn
Caparol ® 4L
1.6 to 4.8 pts.,
Caparol ® Accu Pak
1 to 3 lbs.
Novartis,
cotton
Controlled herbicide or
herbicide type
Spray volume per acre
broadcast
Time to apply
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
Control of many annual
grasses and small-seeded
broadleaf weeds Refer to
label for weed specific
rates
10 to 40 gals. of water.
Before planting or after
harvest.
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.
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.
Control of many annual
broadleaf weeds and a
few annual grasses 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 I35, 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.
Preemergence.
20 to 40 gals. of water.
65
Note
inches tall. For best results, apply 1 qt./A when johnsongrass is in the
bootto- head growth stage. Wait 3 days before tillage.
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.
Information source
[Baumann 2010]
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.
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 furrowplanted cotton.
[Baumann 2010]
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]
[Baumann 2010]
Alternative plant
protection
product (ppp)
(active substance
or name or type)
metolachlor
metolachlor
+ prometryn
Metolachlor +
Fluometuron
fluometuron
diuron
Product example
Several other prometryn
products (Cotton Pro,
Gowan
Prometryne 4L, Riverside
Prometryne 4L) are
currently
available
Dual ® 8E
or
Dual ® II 7.8E
1.5 to 2.0 pts.
Novartis
Dual ® 8E
or
Dual II ® 7.8 E
1.25 to 2.0 pts.
Caparol ® 4L
1.6 to 4.8 pts.
Caparol ® Accu Pak
1.0 to 3.0 lbs.
Novartis
Dual ® 8E or Dual II ® 7.8E
1.25 to 2.0 pts.
Cotoran ® DF
1.2 to 2.4 lbs.
or
Cotoran ® 4L
2.0 to 4.0 pts.
or
Cotoran ® Accu Pak
1.2 to 2.4 lbs.
Novartis
Cotoran ® 4L
2.0 to 4.0 pts.
or
Cotoran ® DF
1.2 to 2.4 lbs.
Cotoran ® Accu Pak
1.2 to 2.4 lbs.
Novartis
Other fluometuron products
available include Meturon ®
4L or DF and Riverside ®
Fluometuron 4L or 80DF.
Karmex ® 80DF
1.0 to 2.0 lbs.
or
Crop or
crop
type
Controlled herbicide or
herbicide type
Spray volume per acre
broadcast
Time to apply
Note
Information source
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.
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 furrowplanted 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.
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 furrowplanted cotton. Test compatibility of Dual ® and Caparol ® in a jar
before mixing in tank.
[Baumann 2010]
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.
cotton
Control of many annual
grasses and broadleaf
weeds Refer to label for
weed specific rates.
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]
cotton
Control of many annual
grasses and broadleaf
weeds Refer to label for
weed specific rates.
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]
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
[Baumann 2010]
Alternative plant
protection
product (ppp)
(active substance
or name or type)
Product example
Crop or
crop
type
Direx ® 4L
0.75 to 2.25 qts.
DuPont, Griffin
Pyrithiobac
Other diuron products
available
include Drexel Diuron
4L or 80W, and Riverside
Diuron 80DF
Staple ®
0.6 to 0.9 oz.
DuPont
Controlled herbicide or
herbicide type
Spray volume per acre
broadcast
Time to apply
weed specific rates
cotton
Note
Information source
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.
For control of selected
broadleaf weeds such as
pigweed spp., lanceleaf
sage, venice mallow and
others Refer to label for
weed specific rates.
Control of many annual
grasses and broadleaf
weeds Refer to label for
weed specific rates.
Suppression of cocklebur,
morningglory and
nutsedge
Control of selected
annual broadleaf weeds
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]
10 to 20 gals. of water by
ground or 5 gals. aerially.
Preplant incorporated,
preemergence or split
application
[Baumann 2010]
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.
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.
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.
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.
Apply as directed, semi-directed or over-the-top spray. Use higher rate
after weeds have emerged. Do not plant crops other than cotton
norflurazon
Zorial ®
1.25 to 2.5 lbs.
Novartis
cotton
cyanazine
Bladex ® 90DF
0.70 to 1.1 lbs.
or
Bladex ® 4L
0.6 to 1.0 qt.
DuPont
cotton
prometryn
Caparol ® 4L
1.0 pt. early
1.0 to 1.3 pts. late
or
Caparol ® AccuPak
0.6 lb. early
0.6 to 0.8 lb. late
Novartis
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.
fluometuron
Cotoran ® 4L
2.0 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
67
[Baumann 2010]
[Baumann 2010]
[Baumann 2010]
Alternative plant
protection
product (ppp)
(active substance
or name or type)
Product example
Crop or
crop
type
or
Cotoran ® 85DF
1.2 to 2.4 lbs.
or
Cotoran ® AccuPak
1.2 to 2.4 lbs.
Novartis
diuron
Direx ® 4L
0.3 to 0.55 qt.
Griffin
or Karmex ® 80DF
0.25 to 0.5 lb.
Controlled herbicide or
herbicide type
Spray volume per acre
broadcast
Time to apply
Cobra ® 2E
12.5 ozs.
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.
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]
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.
40 gals. of water + 1 to 2
pts. of surfactant per 50
gals. if not contained in the
product.
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]
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]
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.
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
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]
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]
Valent
dimethylsodiumarsenate
DSMA
4.0 qts. of 3.6 lbs./gal.
product
or
MSMA
1.33 qts. of 6 lbs./gal.
product
cotton
Cocklebur, johnsongrass,
nutsedge, puncturevine,
ragweed, sandbur, some
annual grasses
pyrithiobac
sodium
Staple ®
1.2 to 1.8 ozs.
Cotton
Control of many annual
broadleaf weeds Refer to
label for weed specific
rates.
#
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.
DuPont
fluazifop-p-butyl
Fusilade ® DX 2E
0.5 to 1.5 pts.
Zeneca
Information source
Refer to label for weed
specific rates.
DuPont
lactofen
Note
68
Alternative plant
protection
product (ppp)
(active substance
or name or type)
Product example
fluazifop-p-butyl +
fenoxaprop-pethyl
Fusion ®
6 to 12 ozs.
clethodim
Select ® 2EC
Annual grasses
6 to 8 ozs.
Perennial grasses
8 to 16 ozs.
Crop or
crop
type
Controlled herbicide or
herbicide type
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.
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.
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
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.
Zeneca
Valent
quizalofop
Assure II ® 0.88EC
5 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.
sethoxydim
Poast Plus ® 1E
12 to 48 ozs.
cotton
Control of many annual
and perennial grasses
only Refer to label for
weed specific rates.
cotton
Control of many annual
and perennial grasses
only Refer to label for
weed specific rates
BASF
oxyfluorfen
Goal ® 2 XL
1 to 2 pts.
Rohm and Haas
Spray volume per acre
broadcast
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.
Time to apply
Note
tall and before the boot
stage.
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.
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.
Postemergence over the top
of actively growing grasses.
Do not apply to plants
under environmental stress
or those exceeding
recommended growth stage
on label.
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.
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.
Postemergence over the top
of actively growing grasses.
See label for stages of
various grasses.
Postemergence as a
directed spray to weeds not
exceeding 4 true leaves.
Succulent weeds in 2- to 3leaf stage can usually be
controlled at the low rate.
69
Information source
[Baumann 2010]
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]
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]
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.
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]
[Baumann 2010]
Alternative plant
protection
product (ppp)
(active substance
or name or type)
glyphosate +
surfactant
Product example
Roundup ® Ultra
0.5 to 5 qts./A
Crop or
crop
type
Roundup ® Ultra
0.5 to 1 qt./A
Buctril ® 4EC
0.75 to 1.0 pt.
Time to apply
Apply to cotton 6 to 8
inches tall.
Postemergence to actively
growing weeds using
shielded application
equipment.
5 to 20 gals. of water by
ground. 3 to 15 gals of
water by air.
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 4true leaf stage of growth;
then you must apply the
product post-directed.
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.
cotton
Monsanto
bromoxynil
Spray volume per acre
broadcast
Control of numerous
grasses and broadleaf
weeds Suppression of
some perennial weeds
may be expected.
Control of numerous
grasses and broadleaf
weeds Suppression of
some perennial weeds
may be expected
cotton
Monsanto
glyphosate +
surfactant
Controlled herbicide or
herbicide type
Rhone-Poulenc
Note
Information source
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.
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.
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.
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]
[Baumann 2010]
[Baumann 2010]
cyanazine
Bladex ® 90DF
0.9 to 1.8 lbs.
or
Bladex ® 4L
0.6 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.
prometryn
Caparol ® 4L
1.6 to 3.2 pts./A
or
Caparol ® AccuPak
1.0 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]
glyphosate +
surfactant
Roundup ® Ultra
Refer to label for weed
control rates
Monsanto
1 pt. to 2 qts. for cotton
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.
[Baumann 2010]
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
When weeds are a
minimum of 6 inches above
the crop. Better results are
obtained when more of the
weed is exposed. Do not
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.
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
regrowth inhibition
glyphosate +
surfactant
Roundup ® Ultra
Monsanto
70
[Baumann 2010]
[Baumann 2010]
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
less concentrated solution.
Time to apply
Note
wipe any closer than 2
inches above desirable
vegetation as injury may
result.
Information source
wiper may cause dripping which will injure crop. Mix only enough
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)
Product example
Crop or
crop type
Controlled
herbicide or
herbicide type
s-metalochlor +
prosulfocarb
Boxer GoldBayer 191
wheat
ryegrass
Spray volume per acre broadcast
Time to apply
Note
Information source
The product “Boxer Gold” contains a mix of smetalochlor 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
Alternative plant
protection product
(ppp)
(active substance or
name or type)
Product example
Crop or
crop type
Controlled
herbicide or
herbicide type
Rate range
Time to apply
Note
Information source
imazamethabenz
Assert 2.5 E
conventio
nal
sunflower
wild mustard
0.6 to 0.8 pts (0.19-0.25 lb ai/A)
postemergence
[Durgan 2010]
quizalofop
Assure II 0.88 E
Targa 0.88 E
conventio
nal
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)
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
s-metolachlor
Dual
Magnum 7.62 E,
Charger Basic 7.62 E
conventio
nal
sunflower
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
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.
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, since
control will be reduced compared to other additives.
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.
Dual Magnum will give early season control of
eastern black and hairy nightshade.
EPTC
Eptam 20 G,
conventio
annual grasses
Eptam 20 G 10-22.5 Ibs,
preplant incorporated
Do not apply Eptam 20 G in spring. Wild oat control
[Durgan 2010]
71
[Durgan 2010]
[Durgan 2010]
[Durgan 2010]
Alternative plant
protection product
(ppp)
(active substance or
name or type)
Product example
Crop or
crop type
Eptam 7 E
nal
sunflower
tribenuron
Express 50 SG
ExpressSu
n
sunflower
sethoxydim
Poast 1.5 E
pendimethalin
Rate range
Time to apply
Note
Eptam 7 E 2.5-5.25 pts (2-4.5 lb
ai/A)
in fall or spring
broadleaves
0.25-0.5 oz (0.008-0.016 ib ai/A)
postemergence
conventio
nal
sunflower
annual grasses
and
suppression 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
Pendant 3.3 E,
Pendimax 3.3 E,
Prowl 3.3 E,
Prowl H20 3.8 CS
conventio
nal
sunflower
annual grasses
and 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)
pendimethalin
Stealth 3.3 E
conventio
nal
sunflower
annual grasses,
some broadleaf
weed
1.2-3.6 pts (0.5-1.5 lb ai/A)
preplant incorporated
in fall or spring; can be
applied
preemergence to notill sunflowers; apply
immediately after
planting or up to 30
days before planting
preplant incorporated
in fall or spring;
preemergence in no till
is generally not adequate. EPTC is volatile, therefore,
it needs to be incorporated immediately after
application to prevent herbicide loss.
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.
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.
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.
sulfentrazone
Spartan 4 F,
Spartan 75 DF
conventio
nal
sunflower
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 EC
conventio
nal
sunflower
annual grasses,
quackgrass
Arrow 2 EC, Intensity 2 EC,
Section 2 EC 6-16 oz/A (0.0940.25 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]
preplant incorporated
Wild oat control is not adequate. Ethalfluralin has
not given satisfactory wild mustard control.
[Durgan 2010]
Intensity 2 EC
Intensity
One 0.97 EC
Controlled
herbicide or
herbicide type
Intensity One 0.97 EC 0.56-0.75
pt (0.068-0.09 lb ai/A);
Section 2 EC
Sonalan 10 G,
Sonalan 3 E
[Durgan 2010]
[Durgan 2010]
[Durgan 2010]
[Durgan 2010]
Select Max 0.97 EC 9-12 fl oz
(0.068-0.09 lb ai/A)
Select Max 0.97 EC
ethalfluralin
Information source
conventio
nal
sunflower
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
72
Annex Table 6: Substances for weed control in oilseed rape
Alternative plant
protection product
(ppp)
(active substance or
name or type)
cycloxydim
fluazifop-p-butyl
Product example
Crop or crop type
Controlled
herbicide or
herbicide type
Costs
Time to apply
Note
Information source
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]
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]
postemergence
From expanded cotyledons to before flowerbuds appear. Weeds from 2
leafs.
[Davies 2005]
Various e.g. Falcon
oilseed rape
weeds
25-30£/l, up to 1.5 l/ha;
some products /excluding
Falcon) require LERAP (B)
assessment
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]
Centium
oilseed rape
broad-leaved
weeds
0.25 l/ha
90£/l
preemergence
Preemergence of crop and weeds. Seed covered with 20mm soil. Not on
sands or VLS.
[Davies 2005]
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]
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]
Various e.g. Butisan S
weeds, broadleaved 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]
Lentagran WP
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]
propaquizafop
quizalofop-p-ethyl
clomazone
propachlor
clopyralid
metazachlor
pyridate (SOLA)
oilseed rape
73