New York State Department of Environmental ... - PMEP Home

New York State Department of Environmental Conservation
Division of Materials Management
Bureau of Pest Management
Product Registration & Pest Management Alternatives Section
625 Broadway, Albany, New York 12233-7257
Phone: (518) 402-8768 • Fax: (518) 402-9024
Website: www.dec.ny.gov
E-mail: ppr@gw.dec.state.ny.us
Via UPS (Co. No. 352)
Ms. Annette Marine
E.I. du Pont de Nemours and Co., Inc.
Stine-Haskell Research Center, S300/423
Newark, DE 19714
Dear Ms. Marine:
November 5, 2012
Joe Martens
Commissioner
Re: Registration of a Major Change in Labeling for the Active Ingredient
Chlorantraniliprole as Contained in DuPont Altriset Termiticide (EPA Reg. No.
352-829)
The New York State Department of Environmental Conservation (Department) has evaluated
your application (received April 7, 2011) and supplemental materials received to date in support of the
registration of the above-referenced pesticide product.
Chlorantraniliprole was initially registered by the Department on August 4, 2009 for use on
numerous agricultural crops with a maximum use rate of 0.2 pounds of chlorantraniliprole per acre per
year. Registration for use on turf and ornamentals followed on November 27, 2009. The approved use
rates for turf and ornamental uses are 0.2 pounds of chlorantraniliprole per acre per application and 0.5
pounds of chlorantraniliprole per acre per year. Numerous conditions were placed on the registrations of
chlorantraniliprole-containing products as part of the negotiated registration decision with E.I. du Pont
de Nemours and Co., Inc (DuPont). These conditions included classification of all products as
Restricted Use Pesticides in New York State, prohibition from sale, distribution, and use in Nassau,
Suffolk, Kings, and Queens counties of New York State, buffer zones to aquatic areas of 25 feet (greens
and tee boxes), 50 feet (fairways), and 100 feet (all other use sites), and prohibition of aerial application.
The current major change in labeling application for DuPont Altriset Termiticide (Altriset)
proposes application for remedial and preventative termite control, including control of subterranean
termites. Altriset contains 18.4% of the active ingredient chlorantraniliprole and is a 100% repack of
DuPont Coragen Insecticide, which was registered by the Department on August 4, 2009. Application is
limited to individuals/firms registered by the state to apply termiticide products.

Ms. Annette Marine 2.
The application was deemed complete for purposes of technical review on June 6, 2011.
Pursuant to the review time frame specified in Environmental Conservation Law §33-0704.2, a
registration decision date of November 3, 2011 was established. Technical reviews of the proposed uses
included on the DuPont Altriset Termiticide label have been performed by the Department and the
New York State Department of Health. These reviews encompassed the expected impacts of labeled use
of the subject products with respect to human health, environmental fate, and ecological effects. On
October 6, 2011, the Department sent a “Technical Issues” letter to DuPont describing unmitigated
concerns with respect to the expected impacts of the use of Altriset on the water resources in New York
State. A meeting was held between Department staff and DuPont representatives on December 2, 2011.
Subsequent to this meeting, DuPont submitted additional information in support of registration. In
addition, DuPont has added language to the Altriset label prohibiting the use of the product in Nassau
and Suffolk counties. The additional information and label modifications provided by DuPont have
sufficiently mitigated the Department’s concerns. The technical reviews are shown below.
HUMAN HEALTH ASSESSMENT:
The following technical review was produced by staff within the Bureau of Toxic Substance
Assessment at the New York State Department of Health (DOH):
Neither chlorantraniliprole nor the formulated product DuPont Altriset (Coragen) was very
toxic in acute oral, dermal or inhalation exposure studies in laboratory animals. In addition, neither the
active ingredient nor the formulated product was irritating to skin and eyes (tested on rabbits) or skin
sensitizers (tested on guinea pigs).
The DOH previously reviewed the toxicological properties of the active ingredient
chlorantraniliprole in the pesticide products DuPont Coragen Insect Control, DuPont Altacor Insect
Control, and DuPont Acelepryn Insecticide and Grubex I. In the previous reviews DOH indicated that
the active ingredient was neither carcinogenic, genotoxic, neurotoxic, teratogenic nor did it cause
reproductive effects. Chlorantraniliprole was shown to cause some effects in only one study of many
studies in the toxicological database; the presence of eosinophilic foci accompanied by hepatocellular
hypertrophy and increased liver weight in male mice in a chronic toxicity/oncogenicity feeding study at
a dose of 935 milligrams chlorantraniliprole per kilogram bodyweight per day (mg/kg/day); the noobserved-effect-level
(NOEL) was 158 mg/kg/day. The U.S. Environmental Protection Agency (U.S.
EPA) derived a chronic reference dose (RfD) of 1.58 mg/kg/day for chlorantraniliprole using this NOEL
and an uncertainty factor of 100. In addition, the U.S. EPA classified chlorantraniliprole as “not likely
to be carcinogenic to humans” based on a lack of treatment related tumors in chronic
toxicity/oncogenicity feeding studies in laboratory animals and negative results in a number of
genotoxicity studies. A current search of the toxicological literature did not find any significant new
information on the toxicity of chlorantraniliprole.
The U.S. EPA did not conduct occupational or residential risk assessments for the use of
chlorantraniliprole as a termiticide. A risk assessment for worker exposure to this active ingredient was
not required because the U.S. EPA did not identify toxicity endpoints for short-/intermediate-term
dermal and inhalation exposures. However, the U.S. EPA identified a potential long-term toxicity
endpoint for residential post-application inhalation exposure to chlorantraniliprole from application to a
home’s perimeter. The U.S. EPA concluded that post-application inhalation risks to residents, including

Ms. Annette Marine 3.
children, would be negligible given the low toxicity of chlorantraniliprole and extremely low exposure
estimates based on the vapor pressure of chlorantraniliprole (2.1 x 10 -13 millimeters of mercury at 25
degrees Celsius) and the Ideal Gas Law.
There are no chemical specific federal or New York State drinking water/groundwater standards
for chlorantraniliprole. Based on its chemical structure, chlorantraniliprole falls under the 50 microgram
per liter (μg/L) general New York State drinking water standard for an “unspecified organic
contaminant” (10 NYCRR Part 5, Public Water Systems).
In the previous review of DuPont Coragen Insect Control, DuPont Altacor Insect Control, and
DuPont Acelepryn Insecticide, DOH expressed some concern about the leaching potential of
chlorantraniliprole and its degradates to contaminate groundwater and drinking water. The
environmental fate data indicate adsorption coefficients (Koc) in various soil types between 153 and 509
and soil half-lives ranging from 228 to 924 days. Consequently, chlorantraniliprole may have high
mobility through some soils and extended use is expected to cause accumulation of residues in soil from
year to year. These concerns were mitigated in the previously registered products by prohibiting use in
vulnerable areas of the state (Nassau, Suffolk, Kings, and Queens Counties) and restrictions on
applications near bodies of water.
The available information on chlorantraniliprole and the formulated product DuPont Altriset
Termiticide indicates that they are not very acutely toxic in laboratory animal studies.
Chlorantraniliprole was not carcinogenic, genotoxic, neurotoxic, teratogenic and it did not cause
reproductive effects. Although data from the chronic feeding/oncogenicity study in mice indicated some
liver effects, the expected exposure from the labeled uses of DuPont Altriset Termiticide should not pose
a significant risk to workers or the general public. While the large quantities of product that are
sometimes applied near house foundations during termiticide applications can pose a concern for indoor
air impacts, chlorantraniliprole has a low vapor pressure and the formulated Altriset end product does
not contain a volatile organic solvent system. The DuPont Altriset Termiticide label indicates that
individuals who use this product must be licensed by the state to apply termiticides, which indicates that
it would be classified as a “Restricted Use Pesticide” if registered in the state.
Given the above, the New York State Department of Health does not object to the registration of
DuPont Altriset Termiticide in the state on the basis of direct health risks from worker and residential
post-application exposures.
ECOLOGICAL EFFECTS ASSESSMENT:
The application was reviewed by staff within the Department’s Division of Fish, Wildlife &
Marine Resources’ Bureau of Habitat (BOH). BOH staff stated that fish and wildlife are unlikely to
be exposed due of the manner of application of Altriset in and around structures. Therefore, the
Bureau of Habitat does not object to registration of the Altriset product on the basis of expected
impacts to non-target organisms.

Ms. Annette Marine 4.
ENVIRONMENTAL FATE ASSESSMENT:
The following technical review was produced by the Department’s Engineering Geology
staff within the Bureau of Pest Management:
The Altriset label indicates a use rate of 0.05% for all use sites and application methods. The
product is applied via trenching, rodding, sub-slab injections, and treated backfill, all at four gallons per
ten linear feet per foot of depth to top of footing. Backfill is allowed at one gallon per one cubic foot of
soil, and horizontal applications at one to 1.5 gallons per ten square feet. Non- structural applications
are allowed at one gallon per ten square feet, or four gallons per ten linear feet. One gallon of Altriset
contains 1.67 lb ai, and a 0.05% solution contains 0.0008 lb ai/gallon. The label does not indicate a
retreatment rate, so one year is assumed. The label indicates that if the depth to the footer is greater than
four feet, the treatment must extend to a minimum depth of four feet.
The review on this active ingredient was done as part of a global work share by the U.S. EPA,
Canada, Australia, United Kingdom and Ireland, thus there are no Data Evaluation Record reports.
Solubility: Chlorantraniliprole has a solubility at pH 7 of 1.023 mg/L.
Hydrolysis: Chlorantraniliprole is stable to hydrolysis in pH 5 and 7 buffer solutions. In pH 9 solution,
it undergoes rapid hydrolysis. The major degradation product is IN-EQW78.
Aqueous Photolysis: Chlorantraniliprole has a half-life of 0.37 days in a pH 7 buffer solution and 0.31
days in a natural water.
Soil Photolysis: In a water/sediment system, chlorantraniliprole had photodegradation half-lives of 22
days in a loamy sand sediment system and 0.9 days in a sandy loam sediment system. Major
degradation products at pH 7 were IN-LBA22 at 52.1%, IN-LBA24 at 90.2% and IN-LBA23 at 40%.
Aerobic Soil Metabolism: Chlorantraniliprole had half-lives of 228-924 days at 25 o C. No major
degradation products were found at 25 o C. Staff consulted the global work share document, and using
additional information from DuPont, were able to determine that the Marietta sandy loam had a grain
size distribution closest to the Riverhead sandy loam, with a half-life of 888.6 days.
The EPA=s Ecological Risk Assessment did not mention degradates, but the global work share document
indicated that IN-EQW78 was found at greater than 10% in the studies.
Aerobic Aquatic Metabolism: In a sand and loam sediment water system, chlorantraniliprole was
persistent 125-231 days. Major degradation product IN-EQW78 was found at 30.2%.
Anaerobic Aquatic Metabolism: The half-life in a flooded loam soil (pH 7.0, %OC 0.87) was 208
days.
Adsorption/Desorption Studies: In a loamy sand from Spain (pH 7.7, % OC 0.5), the Koc was 153; in a
silty clay loam (pH 5.7, % OC 1.7) the Koc was 509; in a sandy loam from Mississippi (pH 6.7, % OC
0.6) the Koc was 272, in a loamy sand from Georgia (pH 5.9, % OC 0.2) the Koc was 526 and in a loam

Ms. Annette Marine 5.
soil from Italy (pH 7.7, % OC 1.3) it was 180. The EPA=s Ecological Risk Assessment did not mention
degradates, but the global work share document indicated that IN-EQW78 had a Koc of 22,196 in a
loamy sand soil (pH 6.7, %OC 0.5).
Field Dissipation: Field studies done in Minnesota (loam, pH 6.7, % OM 4.3) and Prince Edward
Island, Canada (sandy loam pH 5.96 and % OM 3.7) showed half-lives ranging from 210 to 274 days
with biphasic degradation kinetics. No major metabolites were noted. There were no detections of the
parent compound below 12 inches.
Radiolabeled field studies done in California and Texas showed half-lives ranging from 181-222 days.
In the Texas study, the major degradate IN-EQW78 was found at 42%. In the California study, it was
found at 29%.
Nonradiolabeled field studies had half-lives of 52 days in California (IN-EQW78 found at 21%), 206
days in Texas (IN-EQW78 found at 20%) (pH 8.2, % OM 1.1), 697 days in New Jersey (pH 6.6, % OM
1.7) and 1130 days in Georgia (IN-EQW78 found at 12%) (pH 6.5, % OM 0.6).
Degradates: IN-EQW78 had a half-life of 651 days in a loamy sand soil. IN-EQW78 had a Koc of
22196 in a loamy sand soil (pH 6.7, %OC 0.5).
Computer Modeling of Chlorantraniliprole: For modeling purposes, staff assumed four houses per
acre, and each house is 24 X 40 feet, making 128 linear feet of trench per house four feet deep.
Application Koc T ½ Application Projections at Accumulation?
Frequency
rate 10 years
Application
Every Year
526 888 days 0.66 lb ai/a* 15 ppb Accumulates
Application
Once Every
Five Years
526 888 days 0.66 lb ai/a* 2.5-3.5 ppb Accumulates
*0.0008 lb/gallon X 4 gallons/10 linear feet X 128 feet long X 4 feet of depth X 4 houses
Modeling the degradate IN-EQW78 using a half-life of 651 days, a Koc of 22,196, and assuming a high
degradation rate of 40% the model predicted no leaching of the degradate.
Label Statements: The following statements appear on the label: “Ground Water Advisory - This
chemical has properties and characteristics associated with chemicals detected in ground water. The use
of this chemical in areas where soils are permeable, particularly where the water table is shallow, may
result in ground water contamination.”
EPA Comments: Chlorantraniliprole is persistent and mobile in terrestrial and aquatic environments.
Extended chlorantraniliprole use is expected to cause accumulation of residues in soil from year to year.
Major routes of dissipation are expected to be alkaline-catalyzed hydrolysis, photodegradation in water,
leaching and runoff.

Ms. Annette Marine 6.
Review of Additional Information Submitted by DuPont: A supplemental technical review was
performed on two field dissipation studies submitted by DuPont:
Field Dissipation of Chlorantraniliprole on Bare Soil and in the Presence of a Leafy Vegetable in
Atwater, California, Under Multiple Water Application Regimes (February 18, 2011):
Chlorantraniliprole was applied at 0.2 lb ai/a, the maximum seasonal use rate for vegetable crops
to a loamy sand soil with >80% sand, a pH of 6.7 and 0.6% organic matter. Two bare ground
plots and one leafy vegetable crop plot were utilized. Irrigation was applied at 125% or 160% of
moisture needs to ensure sufficient water to move into the lower depths of the soil column.
Results indicated that mobility was not affected by the increase in irrigation. Soil and vegetation
samples were analyzed for residues of the parent and degradates IN-EQW78 and IN-ECD73.
Field Dissipation of Chlorantraniliprole Insecticide on Bare Soil in California Valley Site, Under
Multiple Water Application Regimes (February 21, 2011): Chlorantraniliprole was applied at 0.2
lb ai/a, the maximum seasonal use rate for vegetable crop to a loamy sand soil with >80% sand, a
pH of 6.4 and 0.6% organic matter. Two bare ground plots were utilized. Irrigation was applied
at 125% or 160% of moisture needs to ensure sufficient water to move into the lower depths of the
soil column. Results indicated that mobility was not affected by the increase in irrigation. Soil
samples were analyzed for residues of the parent and degradates IN-EQW78 and IN-ECD73.
The data results for both studies indicated that chlorantraniliprole, applied at 0.2 lb ai/a/yr, was
persistent throughout the study. The parent moved slowly down the soil column, with most of the
applied mass in the top 6 inches of soil. Detections (above the LOQ) were found at low ppb levels
by the end of the study down to the 28-36 and the 36-45 inch depth. Degradate IN-EQW78 was
found with concentrations highest in the upper layers, as would be expected by the high Koc for
this degradate, decreasing over time. Degradate IN-ECD73 was detected at low ppb levels in the
upper six inches.
Summary: The terrestrial field dissipation studies indicated that the parent is persistent, moving
slowly down through the soil column over the year and a half of the studies. Discussions with the
registrant indicated that the product will likely need to be applied approximately every seven
years, which is verified by the study. LEACHP modeling at four houses per acre, treated every
five years (rather than every year) projects leaching between 2.5 and 3.5 ppb. Modeling supports
the label statements that use of the product as labeled could negatively impact groundwater when
used in vulnerable, sandy areas. With the inclusion of label language prohibiting the application
of the Altriset product in Nassau and Suffolk Counties, Engineering Geology staff does not object
to the registration of this product as labeled.
REGISTRATION DECISION
DuPont has added a label statement prohibiting the sale, distribution, and use of Altriset in
Nassau and Suffolk counties of New York State. This condition has sufficiently mitigated the concerns
expressed during the technical review of the major change in labeling application for chlorantraniliprole.
Therefore, the Department has registered DuPont Altriset Termiticide (EPA Reg. No. 352-829) for
use in New York State. Enclosed for your record are copies of the Certificate of Pesticide Registration

Ms. Annette Marine 7.
and stamped “Accepted for Registration” label.
Please note the yes under the “restriction” column on the enclosed Certificate of Pesticide
Registration and the “Classified for Restricted Use in New York State” stamp on the enclosed product
label. As such, the product is restricted in its purchase, distribution, sale, use and possession in
New York State. Furthermore, the product may only be purchased and used by a certified applicator in
New York State.
The New York State Department of Environmental Conservation Regulations 6 NYCRR
326.3(a) state: “It shall be unlawful for any person to distribute, sell, offer for sale, purchase for the
purpose of resale, or possess for the purpose of resale, any restricted pesticide unless said person shall
have applied for, and been issued a commercial permit.”
Should you require information to obtain a commercial permit, please contact the Pesticide
Reporting and Certification Section, at 518-402-8748.
The Pesticide Reporting Law within Environmental Conservation Law Article 33 Title 12
requires all certified commercial pesticide applicators to report information annually to the Department
regarding each pesticide application they make. Commercial pesticide retailers are required to
report all sales of restricted pesticide products and sales of general use pesticide products to
private applicators for use in agricultural crop production. If no sales are made within New York
State, a report must be filed with the Department indicating this is the case. If you need information
relating to the Pesticide Reporting Law, or annual report forms, please visit the Department’s website at
http://www.dec.ny.gov/chemical/27506.html or call 518-402-8748.
Please note that a proposal by DuPont or any other registrant to register a product that contains
chlorantraniliprole, and whose labeled uses are likely to increase the potential for significant impact on
humans, nontarget organisms, or the environment, would constitute a major change in labeling. Such an
application must be accompanied by a new application fee and meet the requirements listed in Appendix
1.B. of “New York State Pesticide Product Registration Procedures” (April 2009). Such information, as
well as forms, can be accessed at our website as listed in our letterhead.
Please contact Shaun Peterson, of the Pesticide Product Registration Section, at 518-402-8768, if
you have any questions regarding this letter.
Enclosures
Sincerely,
Scott Menrath
Scott Menrath, P.E.
Director
Bureau of Pest Management