### - 2 of 85

-

problem formulation provides an overview of what is currently known about the environmental fate and ecological effects associated with cloransulam

- methyl and its degradates. It a l so describes the preliminary ecological risk hypothesis and analysis plan for evaluating and characterizing risk to non

- target species in support of the registration review of cloransulam

methyl. This document also recommends studies that should be inclu ded in a generic data call

- in (DCI) to address uncertainties surrounding the environmental fate and potential ecological effects of cloransulam

- methyl.

### - 3 of 85

-



# Problem Formulation for the Environmental Fate, Ecological Risk , Endangered Species, and Drinking Water Exposure Assessment s in Support of the Registration Review of Cloransulam

- methyl

(chemBlink, 2010)


## methyl 3

- chloro

- 2

- [[(5

- ethoxy

- 7

- fluoro[1,2,4]triazolo[1,5

- c]pyrimidin

- 2

- yl) sulfonyl]amino]benzoate C AS Registry Number: 147150

- 35

- 4 PC Code: 129116

Prepared by: Elizabeth Bosecker, Biologist Alicia Korol, Biologist Reuben Baris, Environmental Scientist U. S. Environmental Protection Agency Office of Pesticide Programs Environmental Fate and Effects Division Environmental Risk Branch IV 1200 Pennsylvania Ave., NW Mail Code 7507P Washington, DC 20460 Reviewed by: Thomas Steeger, Ph.D
, Senior Biologist Cheryl Sutton, Ph.D., Environmental Scientist Marietta Echeverria, Branch Chief, ERB IV



### December 10 , 2010

### - 4 of 85

-

Table of Contents

1. Purpose

................................ ................................ ................................ ................................ ....... 5 2. Problem Formulation

................................ ................................ ................................ ................. 5 2.1. Nature of Regulatory Action

................................ ................................ ............................... 5 2.2. Previous Assessments

................................ ................................ ................................ ......... 6 2.2.1. Ecological Risk Assessments

................................ ................................ ....................... 6 2.2.2. Drinking Water Exposure Assessments

................................ ................................ ....... 6 3. Stressor Source and Distribution

................................ ................................ ............................... 6 3.1. Mechanism of Action

................................ ................................ ................................ .......... 6 3.2. Overview of Pesticide Use and Usage

................................ ................................ ................ 7 3.3. Environmental Fate and Transport

................................ ................................ .................... 11 3.5. Water Quality

................................ ................................ ................................ .................... 14 4. Receptors

................................ ................................ ................................ ................................ .. 15 4.1. Effects to Aquatic Organisms

................................ ................................ ........................... 15 4.2. Effects to Terrestrial Organisms

................................ ................................ ....................... 20 4.3. Incident Databases Review

................................ ................................ ............................... 23 4.4. Ecosystems Potentially at Risk

................................ ................................ ......................... 24 5. Assessment Endpoints

................................ ................................ ................................ ............. 24 6. Conceptual Model

................................ ................................ ................................ .................... 24 6.1. Risk H ypothesis

................................ ................................ ................................ ................ 25 6.2. Conceptual Diagram

................................ ................................ ................................ ......... 25 7. Analysis Plan

................................ ................................ ................................ ........................... 27 7.1. Stressors of Concern

................................ ................................ ................................ ......... 28 7.2. Measures of Exposure

................................ ................................ ................................ ....... 28 7.3. Measures of Effect

................................ ................................ ................................ ............ 30 7.4. Integration of Exposure and Effects

................................ ................................ ................. 31 7.5. Deterministic and Probabilistic Assessment Methods

................................ ...................... 31 7.6. Endangered Species Assessments

................................ ................................ ..................... 32 7.7. Drinking Water Assessment

................................ ................................ ............................. 32 7.8. Preliminary Identification of Data G aps

................................ ................................ ........... 33 7.8.1. Environmental Fate

................................ ................................ ................................ .... 33 7.8.2. Effects Data

................................ ................................ ................................ ................ 35 8. References

................................ ................................ ................................ ................................ 41 APPENDIX A: Registered Uses and Application Rates for Cloransulam

- methyl.

..................... 47 APPENDIX B. Major Environmental Degradates of Cloransulam

- methyl.

............................... 52 APPENDIX D. Submitted Ecological Effects Toxicity Data for Cloransulam

- methyl

.............. 68 APPENDIX E: SIP v.1.0 Inputs and Outputs

................................ ................................ .............. 74 APPENDIX F: Data Call

- In Tables

................................ ................................ ............................. 77

### - 5 of 85

-

1. Purpose

The purpose of this problem formulation is to provide an understanding of what is known about the environmental fate and ecologica l effects of cloransulam

- methyl , considering its currently registered use

. C loransulam

- methyl is a t riazolopyrimidine sulfonanilide herbicide currently registered for use on soybeans. There are no residential uses for cloransulam

- methyl nor are t here formulations of cloransulam

- methyl classified as “restricted use” pesticides. This document provide s a plan for analyzing data relevant to cloransulam

- methyl and for conducting environmental fate, ecological risk, endangered species, and drinking water exposure assessments for its registered use. Additionally, this problem formulation identifies data gaps, uncertainties, and potential as sumptions used to address those uncertainties relative to characterizing the potential ecological risk associated with the registered use of cloransulam

methyl on soybean.

2. Problem Formulation

2.1. Nature of Regulatory Action

Under the Federal Insect icide, Fungicide, and Rodenticide Act (FIFRA), all pesticides distributed or sold in the United States generally must be registered by the Environmental Protection Agency (Agency). In determining whether a pesticide can be registered in the U.S., the Agen cy evaluates its safety to non

- target species based on a wide range of environmental and health effects studies. In 1996, FIFRA was amended by the Food Quality Protection Act, and the Agency was mandated to implement a new program for the periodic review of pesticides, i.e
., Registration Review ( http://www.epa.gov/oppsrrd1/registration_review/ ). The Registration Review program is intended to ensure that, as the ability to assess risk evolves a nd as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effects to human health and the environment. Changes in science, public policy, and pesticide use practices will occur over t ime. Through the new Registration Review program, the Agency periodically reevaluates pesticides to make sure that as change occurs, products in the marketplace can be used safely.
As part of the implementation of the new Registration Review program purs uant to Section 3(g) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Agency is beginning its evaluation of cloransulam

- methyl to determine whether it continues to meet the FIFRA standard for registration. This problem formulation for the environmental fate, ecological risk, endangered species, and drinking water assessment chapter in support of the registration review of cloran sulam

- methyl will be posted in the initial docket which will open the public phase of the review process.

### - 6 of 85

-

2.2. Previous Assessments

2.2.1. Ecological Risk Assessments

C loransulam

- methyl was first registered in 1997 by DowElanco . According to the chemical's initial assessment (D223558, D223605; USEPA, 1997), risk to non

- target terrestrial plants resulting from cloransulam

- methyl use was identified based on Risk Quotients (RQs) ranging from <1 to 12. In contrast, the Agency‟s Le vel of Concern (LOC) was not exceeded for non

target aquatic plants, nor Federally listed threatened and endangered (listed) or non

- listed terrestrial or aquatic animals. Label precautions for non

- target insects were deemed unnecessary because cloransulam

- methyl was categorized as practically non

- toxic to young adult honey bees (USEPA, 1997) on an acute contact exposure basis. Further, cloransulam

- methyl and its similar ly structured transformation products were determined to exhibit characteristics simila r to those pesticides that are known to leach to ground water. Thus a prospective ground water study was requested as a condition of registration.

After reviewing the previous risk assessment, modifications to the previous risk analyses are expected. Th ese changes are due to an evolution of Agency policy since cloransulam

- methyl was first registered ( e.g., evaluating drinking water exposure to birds and mammals). While non

target terrestrial and aquatic plants were previously assessed, an assessment on listed species in these taxa was not performed. Further, environmental fate and ecological toxicity data were re

evaluated as part of the Registration Review process and certain studies that previously met guideline standards or registration requirements may no longer meet current guideline standards ( e.g. , terrestrial plant toxicity studies).

2.2 .2 . Drinking Water Exposure Assessments

A full drinking water assessment has not been conducted for cloransulam

- methyl. While a limited

- scope water resources assessment was completed as part of the new chemical registration in 1997 (DP Barcodes D223558 and D223560), that assessment is not consistent with the current standards used by EFED to assess drinking water exposure. A full drinkin g water exposure assessment using up

- to

- date models and data will be completed during the registration review process. At that time
, the Health Effects Division (HED) will be consulted in order to determine which , if any, of cloransulam

- methyl‟s degradate s are residues of toxicological concern and should be included in the drinking water exposure assessment in support of the human health dietary risk assessment. Many degradates detected in the fate studies are considered major degradates due to their form ation at concentrations >10% of the applied parent (identified in Section 3.4).

3. Stressor Source and Distribution

3.1. Mechanism of Action

### - 7 of 85

-

Cloransulam

- methyl is an Acetohydroxyacid Synthetase ( AHAS) inhibitor also known as an A cetolactate S ynthase inhibito r (ALS inhibitor) in the triazolopyrimidine herbicide fami ly (HRAC, 2009). Acetolactate S ynthase is responsible for the production of three essential amino acids. An inhibition of this enzyme causes stunting and delayed growth that can ultimately lead to plant death (UM Extension, 2009). Cloransulam

- methyl is a systemic herbicide that moves through the xylem and phloem (as opposed to certain ALS inhibitors that only move through phloem) to areas of new growth, and it is taken up by the plant through root s and foliage (UM Extension, 2009).

3.2. Overview of Pesticide Use and Usage

Cloransulam

- methyl is currently registered for use as a p re

- and post

- emergent herbicide in soybean production. Eight end

- use products containing cloransulam

- methyl are currently registered for use in the United States ( Table 3.2 ) . End

- use products are formulated as suspension concentrates (SC)
, water soluble packets (WSP), and wettable powders (WP). Five of these end

- use products are co

- formulated or co

- packaged with o ne of three other active ingredients; three with sulfentrazone (CAS number 122836

- 35

- 5 ; GAUNTLET ® 

### 70 DF HERBICIDE, GAUNTLET ® 

### 70 WP HERBICIDE, and AUTHORITY ® 

### DF Herbicide); one with flumetsulam ( CAS number 98967

- 40

- 9 ; FRONTROW ® 

### ); and one with flumioxazin (CAS number 103361

- 09

- 7; GANGSTER ® 

### HERBICIDE WSP).

Ta ble 3.2. Currently Registered Cloransulam

- methyl End

- Use Products. FORMULATION EPA REG.

NO. % ACTIVE METHODS OF APPLICATION USE RESTRICTIONS

RIVERDALE ® 565 SELECTIVE HERBICIDE

SC 228

- 380 84 Ground

- Do not mix, load, rinse, or wash equipment or containers within 50 feet of any wells or other bodies of water.

- Do not apply through an irrigation system

- Avoid direct or indirect contact with non

- target plants.

- Do not apply under conditions which favor runoff or wind erosion, or when conditions favor drift to

non

- target sites.

- Aerial application is prohibited.

- If used in OH, MN, MI, WI, IA, NE, KS,OK, MO (excluding bootheel), IL and IN (nort h of Interstate 64), SD, ND, PA, and NY, if soil OM is 3% or less, use 0.6 oz/acre. If soil OM is greater than 3% use 0.75 oz/acre. South of Interstate 64 in IL and IN at all OM levels use 0.75 oz/acre. GAUNTLET ®

WSP 279

- 3231 42 Ground

- Do not mix, load, rinse, or wash equipment or containers within 50 feet of any wells or other bodies of water.

- Do not apply through an irrigation system

- Do not apply under conditions which favor runoff or wind erosion, or when conditions favor drift to

non

- tar get sites. GAUNTLET ® 70 DF HERBICIDE 279

- 3246 7.9 Ground

- Do not mix, load, rinse, or wash equipment or containers within 50 feet of any wells or other bodies of water.

### - 8 of 85

-

FORMULATION EPA REG.

NO. % ACTIVE METHODS OF APPLICATION USE RESTRICTIONS

WP

- Do not apply under conditions which favor runoff or wind erosion, or when conditions favor drift to

non

- target sites. GAUNTLET ® 70 WP HERBICIDE

WP 279

- 3247 7.9 Ground

- Do not mix, load, rinse, or wash equipment or containers within 50 feet of any wells or other bodies of water.

- Do not apply through an irrigation system

- Do not apply under conditions which favor runoff or wind erosion, or when conditions favor drift to

non

- target sites. GANGSTER ®
HERBICIDE

WSP 59639

- 131 84 Ground Aerial (Except New York) - Do not apply through an irrigation system

- Do not graze treated fields or feed treated forage or hay to livestock

- Do not apply under conditions which favor runoff or wind erosion, or when conditions favor drift to

non

- target sites.

- If applying by air, observe drift management restrictions and precautions issued under Aerial Application

- Do not apply during low

- level inversion conditions when winds are gusty, etc.

- Do not apply within 40 ft. of non

- target plants or crops

- Do not apply within 100 ft. of emerged cotton crops

- Do not apply within 40ft of streams, wetlands, marshes, ponds, lakes, and reservoirs

- Do not apply by air in the state of New York CLORANSULAM

METHYL ®
TECHNICAL 62719

- 274 97.5 N/A (Manufacturing Use) - Do not discharge effluent containing this product

into lakes, streams, ponds, estuaries, oceans, or other water unless with the requirements of the NPDES permit and the primary authority has been notified.

- Do not discharge effluent containing this produ ct into sewer systems without previously notifying the local sewage treatment plant authority FIRSTRATE ®

WP 62719

- 275 84 Ground Aerial (Except New York) - Do not mix, load, rinse, or wash equipment or

containers within 50 feet of any wells or other bodies of water.

- Do not apply through an irrigation system

- Do not apply under conditions which favor runoff or wind erosion, or when conditions favor drift to

non

- target sites

- If used in DE, CT, IA, KS, MD, ME, MI, MN, MO (excluding the bootheel), ND, NE, NH, OH, OK, SD, VT, WI, PA, NY, and areas north of Interstate 64 in the states of IL, IN, KY, WV, and VA is soil OM is 3.0% or less use 0.6 oz/acre. If soil OM is greater than 3.0% use 0.75 oz/acre. All areas south of the above mentioned geographic

a rea at all OM levels use 0.75 oz/acre. FRONTROW ® 62719

- 299 84 Ground Aerial (Except in - Do not apply directly to water, areas where

surface water is present, or intertidal areas below

### - 9 of 85

-

FORMULATION EPA REG.

NO. % ACTIVE METHODS OF APPLICATION USE RESTRICTIONS

WSP New York) the mean high water mark.

- Do not mix, load, rinse, or wash equipment or containers within 50 feet of any wells or other bodies of water.

- Do not apply through an irrigation system

- Do not apply more than 0.84 oz per acre per crop growing season.

- Do not exceed 0.07 lb cumulative application of the active ing redient flumetsulam.

- Do not exceed 0.055 lb per year of the active ingredient cloransulam

- methyl

- Do not graze treated fields or feed treated forage or hay to livestock

- If applying by air, observe drift management restrictions and precautions issued und er Aerial Application

- Do not apply during low

- level inversion conditions when winds are gusty, etc.

- Do not apply within 40 ft. of non

- target plants or crops

- Do not apply within 100 ft. of emerged cotton crop s

- Do not apply within 40ft of streams, wetlands, marshes, ponds, lakes, and reservoirs

- Do not apply by air in the state of New York

- Avoid all direct and indirect contact with non

target plants

- Do not harvest soybeans for 70 days after application of Frontrow ®

.



### T he maximum seasonal application rate for cloransulam

- methyl on soybeans is 0. 055 pounds of active ingredient per acre (lbs a.i./A ), while the maximum single application rate is 0.040 lbs a.i./A. The risk assessment will assess one cropping season per year of soybeans, an annual rate of 0.055 lbs a.i./A, which reflects the majority of cloransulam

- methyl use in the United States (USD A, 1997). As can be seen in APPENDIX A , t he labels permit slightly higher application rates for soils with greater than 3% soil organic matter. APPENDIX A provides a complete list of registered products and their corresponding single and seasonal maximum application rates.
According to the United States Geological Survey‟s (USGS; http://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=02&map=m9103 ) national pe sticide usage data, an annual average of 82,155 lbs of cloransulam

- methyl, based on data for the years 1999 to 2004, were applied nationally to soybeans in the United States. The highest use areas are in the Midwest and along the Mississippi River watersh ed ( Figure 3.1 ). Additional data b ased on a Screening Level Usage Analysis (SLUA) conducted by the Agency ( USEPA
, 20 10 ), using data from 1998 to 2008, reported the average annual cloransulam

- methyl use was 44,000 lb a.i./ year . This yearly average is almo st half of that reported by the USGS, but the SLUA data covers 11 years of usage rather than the 6 years covered by the USGS. The SLUA data indicate that cloransulam

- methyl usage increased from 1998

- 2001 and then almost steadily

### - 10 of 85

-

decreased from 2002 to 200 7, where 4 of the 5 highest annual average usages occurred in the years 1999

– 2002 ( Figure 3.2 ).

FIGURE 3.1. USGS Estimated, Annual, National, Agricultural Cloransulam

- methyl Usage from 1999

- 2004 (USGS 2010 ; http://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=02&map=m9103 

### ). 1

1 The pesticide use maps available from National Pesticide Synthesis site show the average annual pesticide use intensity expressed as average weight (in pounds) of a pesticide applied to each square mile of agricultural land in a county. The area of the map is based on state

- level estimates of pesticide use rates for individu al crops that were compiled by the CropLife Foundation, Crop Protection Research Institute based on information collected during 1999 through 2004 and on 2002 Census of Agriculture county crop acreage. The maps do not represent a specific year, but rather show typical use patterns over the five year period 1999 through 2004.

### - 11 of 85

-

FIGURE 3.2

. Screening Level Usage Analysis (SLUA) of National, Annual, Agricultural Cloransulam

- methyl Usage from 1998

- 2008 (USEPA, 2010)

3.3. Environmental Fate and Transport

Laboratory and field data indicate that cloransulam

- methyl ( methyl 3

- chloro

- 2

- [[(5

- ethoxy

- 7

- fluoro[1,2,4]triazolo[1,5

- c]pyrimidin

- 2

- yl)sulfonyl]amino]benzoate ) is highly mobile in the environment (mean Freundlich adsorption constant ( K f 

### ) of 0.84 mL/g; MRID s 43003435, 43216602 ) and is essentially non

- volatile (v apor pressure of 3.0 x 10 - 16 

### torr ; MRID 43668933 ). The major routes of dissipation appear to be biotic metabolism, abiotic photolysis in water and soil, and leaching. Hydrolysis may be an important mode of dissipation in alkaline environments (pH 9). However, there is uncertainty about the fate of cloransulam

- methyl in aquatic environments since acceptable aerobic aquatic metabolism data have not been submi tted.

The initial transformation of cloransulam

- methyl involves modifications of functional groups while the structural “backbone” of the chemical remains intact. The three transformation products that retain a similar struct ure to the parent (cloransu lam, 5

- hydroxy

- chloransulam, and 5

- hydroxy

- cloransulam

- methyl) appear to be mobile, and more persistent than the parent. In studies done on Green Alga ( Psuedokirchneriella subcapitata, reported as Selenastrum

c apricornutum Printz) , the demethylated cloran sulam is the only degradate that is shown to have similar toxicity to parent cloransulam

- methyl based on aquatic nonvascular plant toxicity data (MRID s 44744514 and 43668917 ) . Later degradation involves cleavage of the sulfonamide bridge or a break in the triazolopyrimidine ring and requires more energy (from photolysis) or special conditions (alkaline hydrolysis or anaerobic metabolism). Laboratory studies reported cloransulam

- methyl had a transformation half

- life of 9 to 30 days in aerobic soil under la boratory conditions. In an anaerobic aquatic water/sediment system, cloransulam

- methyl degraded with a total system half

- life of 16 days. Acceptable guideline data showing the fate of the compound in an aerobic aquatic water/sediment system are not avail able. In field studies, half of the parent

### - 12 of 85

-

dissipated from the surface in less than 6 days (DT 50 

### ) largely attributed to metabolism and photolysis at the surface in the warm
, moist soil exposed to sunlight at both field sites. However, parent cloransulam

- methyl and structurally similar transformation products were detected at a maximum depth of 45 cm (27 DAT), and at 30 cm (155 DAT) indicating that cloransulam

methyl and its structurally similar transformation products may persist longer in the subsurface soil layers relative to surface layers

. Microbial transformation and abiotic soil photolysis occur in the surface layer of the soil, but these processes may not be major factors if the chemical leaches to the subsurface, where hydrolysis or other slower d egradation processes may dominate. So, cloransulam

- methyl and its structurally

- similar transformation products may be more persistent when leached into the subsurface. However, there are several uncertainties about the fate of cloransulam

- methyl, namely the biotic degradation in anaerobic environments (e.g., subsurface below 1 meter) due to lack of anaerobic soil metabolism data. Further, the potential risk of ground water contamination resulting from applica tions of cloransulam

- methyl is uncertain due to the potential persistence in the subsurface layers where metabolic activity is low . In an attempt to address this uncertainty, a prospective ground water (PGW) study conducted at three U.S. sites was submitt ed as a condition of the registration of the compound, and is currently under review.

Additional data submitted in support of the PGW studies has been reviewed and classified as supplemental. Two sites, La Porte, Indiana, and Janesville, Iowa, used for a cloransulam

- methyl prospective groundwater (PGW) study had been previously used for flumetsulam (La Porte, IN) and flufanacet (Janesville, IA) PGW studies. In a study (MRID 44809201) conducted to investigate whether enhanced degradation of cloransulam

- me thyl might occur in field soils previously treated with flumetsulam or flufanacet, it was found that there was no enhanced degradation of cloransulam

- methyl due to the previous treatment with the other pesticides.

Table 3.4 summarizes the general physical , chemical, and fate and transport properties of cloransulam

- methyl.

Table 3.4. General Chemical Properties and Environmental Fate Properties of Cloransulam

- methyl.

Parameter Value Reference Comments

Selected Physical/Chemical Parameters Molecular mass 429.82 g/mol MRID 43668933 Vapor press ure (20°C) 3.0 x 10 - 16 torr MRID 43668933 Water solubility (20 °C) 3 mg/L (pH 5) 180 mg/L (pH 7) 3400 mg/L (pH 8.5) MRID 43668933

Henry‟s law constant (20°C, pH 7) 9.43 x 10 - 19 Calculated HLC = (VAPR ÷ 760) ÷ (SOL ÷ MWT) Octanol

- water partition coefficient (LogK OW ) (20°C) pH 5 = 1.12 pH 7 =

- 0.365 pH 8.5 =

- 1.24 MRID 43668933

Persistence

### - 13 of 85

- Parameter Value Reference Comments

Hydrolysis pH 5: stable pH 7: stable pH 9: 3 days MRID 43003432 pH 7 half

- life was extrapolated beyond the study duration (118

- 231 days)

Aqueous Photolysis (t 1⁄2 ) 0.015 days (22 minutes) MRID 43715402 Corrected environmental half

- life (40oN)

Soil Photolysis (t 1⁄2 ) 30

- 70 days MRID 43760001 There are significant differences in the half

lives of the two radio

labeled studies.

Aerobic Soil Metabolism
, parent only (t 1⁄2 ) Biphasic Kinetic Model: 13 days (loam) Observed DT50=22 days Observed DT90=225days 9 days (loamy sand) Observed DT50=14 days Observed DT90=150 days MRID 43003433 Cloransulam

- methyl does not appear to fit the 1 st order model, exhibits biphasic degradation.

An additional study is currently under review (MRID 44809201). 15, 15, 15, 18, 22, 21, 21, 13, 30, 15, 17, 17, 18, 19, 20, 19 days MRID 43216602, 43003435 † (ancillary data)
Aerobic soil metabolism Half

- lives not useful other than for comparison to data for previously treated soils. MRID 44809201 Supplemental study with

some deficiencies precluding use of t1⁄2‟s for assessment purposes

.

Anaerobic Soil Metabolism No data

--

Anaerobic Aquatic Metabolism (t 1⁄2 ) 16 days MRID 43715403 Supplemental study. The pH of the system was not reported.

Aerobic Aquatic Metabolism No data

--

Mobility Freundlich K f (mL/g) 0.82, 0.40, 0.49, 1.45, 0.32, 0.21, 4.89, 0.29, 1.06, 0.45, 0.97, 0.29, 0.33, 0.19, 1.06, 0.25 MRID 43003435, 43216602 There was no correlation

between K f and % organic carbon. Mean K f of 0.84 mL/g

. Organic Carbon Partitioning Coefficient K oc (mL/g oc) 67, 16, 158, 242, 16, 20, 157, 60, 54, 18, 262, 28, 12, 34, 51 , 27 MRID 43003435, 43216602 Coefficient of variance is

less for K f than K oc
Field Dissipation

### - 14 of 85

- Parameter Value Reference Comments Terrestrial Field Dissipation (t 1⁄2 ) (top 15 cm of soil) 3.5 days (Indiana) 5.0 days (Mississippi) MRID 43716002 Dissipation half

- lives are based on a non

- linear 2

- compartment model. DT90‟s at both sites were less than 45 days. Warm sunny weather and moist soil favored photolysis and metabolism as dissipation routes.

In Review MRID 44231501
† MRID 43216602 an adsorption/desorption study provides ancillary data for aerobic degradation of cloransulam

- methyl which will be used as additional aerobic soil metabolism degradation half

- lives.



### 3.4. Degradates of Concern

Major degradates are compounds that form at greater than 10% of the applied in at least one fate study, or are known to be toxicologically significant. There were nine major degradates reported in the fate studies. These include the structurally similar transformation products cloransulam (37

- 38% at 28 days), 5

- hydroxy

- cloransulam

- methyl (17% at 14 days) and 5

- hydroxy

cloransulam (11

- 21% after 120 days) which were observed in the aerobic and anaerobic metabolism studies. Other degradates such as cloransu lam

- methyl fluorethenyl (49

- 54% at 365 days) were found in anaerobic conditions. Cloransulam

- methyl fluorethenyl appears to be persistent under anaerobic conditions (concentrations were increasing at the termination of the study 365 DAT). Sulfonic acid ( TSPA) was the major photolytic degradate in the soil photolysis study (peak concentration of 22% at the end of the study). Sulfinic acid was detected in the aqueous photolysis study (23% at the end of the study ). Cloransulam

- methyl imidate ( max. of 29 %) and cloransulam

- methyl acetic acid ( max. of 54 %) were associated with the hydrolysis of cloransulam

- methyl. Appendix B lists all the major degradates , chemical structures, chemical names, and which studies are associated with the formation of each degradat e.

3.5. Water Quality

Cloransulam

- methyl is not identified as a cause of impairment for any water bodies under section 303(d) of the Clean Water Act 2 

### . In addition, no Total Maximum Daily Loads (TMDL) have been developed for cloransulam

- methyl 3 

### and there are n o aquatic life criteria for cloransulam

- methyl 4



### . More information on impaired water bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/

.

2 based on information provided at http://iaspub.epa.gov/tmdl_waters10/attain s_nation_cy.cause_detail_303d?p_cause_group_id=885 , accessed July 21 , 2010 3 based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id=885&p_pollutant_ group_name=PESTICIDES , accessed Jan. 26, 2010 4 based on information provided at http://www.epa.gov/waterscience/criteria/aqlife/index.html

### - 15 of 85

-

The Agency invites submission of water quality data for this pesticide. To the extent possible, data should conform to the quality standards in Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and Other Water Quality Dat a in OPP’s Registration Review Risk Assessment and Management Process (see: http://www.epa.gov/oppfead1/cb/ppdc/2006/november06/session1

- sop.pdf ), in order to ensure they ca n be used quantitatively or qualitatively in pesticide risk assessments.

No monitoring data were available for cloransulam

- methyl. Neither the USGS‟s National Water Quality Assessment ( NAWQA ) program nor the California Department of Pesticide Regulation

m onitoring programs included cloransulam

- methyl as an analyte.

4. Receptors

Consistent with the process described in the Overview Document (USEPA
, 2004), the risk assessment for c loransulam

- methyl relies on a surrogate species approach. T oxicological data generated from surrogate test species, which are intended to be representative of broad taxonomic groups, are used to extrapolate the potential effects on a variety of species (receptors) included under these taxonomic groupings.

A cute and chronic toxicity data from studies submitted by pesticide registrants along with the available open literature are used to evaluate the potential direct and indirect effects of

c loransulam

- methyl to aquatic and terrestrial receptors. This includ es toxicity on the technical grade active ingredient, degradates, and when available, formulated products ( e.g. , “Six

- Pack” studies). The open literature studies are identified through EPA‟s ECOTOXicology (ECOTOX) database , which employs a literature sear ch engine for locating chemical toxicity data for aquatic life, terrestrial plants, and wildlife. The evaluation of both sources of data may also provide insight into the direct and indirect effects of cloransulam

- methyl on biotic communities from loss of species that are sensitive to the chemical and from changes in structure and functional characteristics of the affected communities. O pen literature studies from an ECOTOX run conducted in April of 2010 for cloransulam

- methyl have not been formally reviewed as part of this Problem Formulation. A preliminary screen of the data reveals an acceptable study on terrestrial plants, mentioned in Section 4.2. References to all studies, both acceptable and unacceptable for EFED‟s use, are presented in Appe ndix C . Data from these studies and data from an up

- dated ECOTOX run for cloransulam

- methyl will be evaluated for possible quantitative and/or qualitative inclusion in the risk assessment in support of Registration Review.

A summary of the most sensitive data representing non

- target organisms exposed to cloransulam

- methyl in aquatic and terrestrial habitats is provided in Section 4.1. A summary of ecological incidents associated with cloransulam

- methyl and a description of ecosystems potentially at risk are provided in Section 4.2.

4.1. Effects to Aquatic Organisms

Effects data are available on aquatic animals and plants for cloransulam

- methyl, as well as

### - 16 of 85

-

aquatic plants for the degradates 5

- hydroxy

- cloransulam

- methyl, 5

- hydroxy

- cloransulam, and cloransulam. Based on the available data, cloransulam

- methyl is categorized as slightly toxic on an acute exposure basis to freshwater fish and practically non

- toxic on an acute basis to estuarine/ marine fish and invertebrates. There are no acute toxicity data for freshwater invertebrates. Additionally, because chronic data on aquatic organisms were not required at the time cloransulam

- methyl was first registered, no c hronic toxicity data exists for freshwater and estuarine/ marine fish and invertebrates . The most sensitive species for each taxa from submitted aquatic animal toxicity studies are presented in Table 4.1

. A summary of all submitted ecotoxicity data for cloransulam

- methyl and degradates is provided in Appendix D

.
Table 4.1

. Summary of the M ost S ensitive Species by Taxon from S ubmitted A quatic Animal T oxicity S tudies for Cloransulam

- methyl

.

TAXON SPECIES ENDPOINT CHEMICAL/ FORMULATION MRID STUDY CLASSIFICATION

Freshwater Fish (Acute) Rainbow Trout

( Oncorhynchu s mykiss ) 96

- hr LC 50

>86 mg a.i./L Cloransulam

methyl (97.3%) 430034

- 10 Acceptable

Estuarine/ Marine Fish (Acute) Inland

Silverside ( Menidia beryllina ) 96

- hr LC 50

>121 mg a.i./L Cloransulam

methyl (97.4%) 437189

- 01 Acceptable

Estuarine/ Marine Invertebrates (Acute) Eastern Oyster

( Crassostrea virginica ) 96

- hr LC 50

>111 mg a.i./L Cloransulam

methyl (97.4%) 437189

- 02 Acceptable

Freshwater Fish (Chronic) -- -- -- -- --

Freshwater Invertebrates (Acute & Chronic) -- -- -- -- --

Estuarine/ Marine Fish (Chronic) -- -- -- -- --

Estuarine/ Marine Invertebrates (Chronic) -- -- -- -- --



### Data from acceptable acute 96

- hour freshwater fish studies were submitted for rainbow trout, Oncorhynchus mykiss , (MRID 430034

- 10) and bluegill sunfish, Lepomis macrochirus (MRID 430034

- 11). No treatment

- related mortalities nor sublethal effects were observed for either study; the resulting LC 50 

### values were >89 mg a.i./L for the rainbow trout (most sensitive freshwater fish species tested) and >154 mg a.i./L for the bluegil l sunfish, based on mean measured concentrations of filtered samples. Both studies were conducted as limit concentrations of nominal 300 mg a.i./L, but due to the limit of solubility, filtered samples of average concentrations over the 96

- hr study period were 89 mg a.i./L and 154 mg a.i./L for the

### - 17 of 85

-

rainbow trout and bluegill study, respectively. Based on this data, cloransulam

- methyl‟s toxicity to freshwater fish is limited by solubility. Data are available for one estuarine/marine fish, the inland silver side, Menidia beryllina (MRID 437189

- 01), resulting in a 96

- hr LC 50 

### >121 mg a.i./L. The solubility of cloransulam

- methyl was determined to be 232 mg/L for the test, and as such, insoluble material was not noted in the test media (pH ranged from 7.7

– 8.1) . Nominal and mean

- measured concentrations were 125 mg a.i./L and 121 mg a.i./L, respectively. No mortality or signs of toxicity were reported for the duration of the study.

Two acceptable toxicity studies were submitted on aquatic invertebrates, an a cute toxicity study to the grass shrimp, Palaemonetes pugio , (MRID 437189

- 03) and an acute toxicity to the Eastern oyster, Crassostrea virginica , (MRID 437189

- 02). No mortality or sublethal effects from cloransulam

- methyl exposure were reported for the gr ass shrimp; the 96

- hr LC 50 

### was >121 mg a.i./L. In contrast, effects on mean shell deposition to the Eastern oyster were reported at the limit concentration (111 mg a.i./L) tested. Mean shell deposition was decreased 18% compared to the negative control, and no additional adverse effects were noted. The 96

- hr EC 50 

### for Eastern oyster was >111 mg a.i./L (most sensitive estuarine/marine invertebrate acute toxicity endpoint) and the 96

- hr NOAEC was < 111 mg a.i./L based on mean shell deposition. No insoluble material was noted in either the grass shrimp or eastern oyster study throughout the duration of the test. An acute study for freshwater invertebrates, looking at the waterflea ( Daphnia magna ),

was submitted but classified invalid (MRID 43003412 ). No ch ronic study on aquatic invertebrates has been submitted.

The most sensitive species for both vascular and nonvascular aquatic plants for cloransulam

methyl and degradates from submitted toxicity studies are presented in Table 4.2.

Table 4.2 . Summary of the M ost S ensitive E ndpoints from S ubmitted A quatic Plant T oxicity S tudies for Cloransulam

- methyl and Degradates

. TAXON ENDPOINT CHEMICAL/ FORMULATION MRID STUDY CLASSIFICATION Aquatic Nonvascular Plants Green Alga ( Psuedo

kirchneriella subcapitata, formerly Selenastrum capricornutum ) 96

- hr EC 50 = 0.003 mg a.i./L Slope: 1.04 0.159 NOAEC = 0.00094 mg a.i./L (algal cell density) Cloransulam

- methyl

(Firstrate ® ; 82.2%) 447445

- 17 Acceptable

Cyanobacteria ( Anabaena flos

aquae ) 120

- hr EC 50 = >29.9

mg a.i./L NOAEC = 29.9 mg a.i./L (algal cell density) 5

- hydroxy

cloransulam

- methyl (>95%) 447445

- 01 Supplemental

Freshwater Diatom ( Navicula pelliculosa ) 120

- hr EC 50 = >10.7 mg a.i./L NOAEC = 5.64 mg a.i./L (algal cell density) 5

- hydroxy

cloransulam (>96%) 447445

- 07 Supplemental

### - 18 of 85

-

Green Alga ( P. subcapitata, formerly S. capricornutum ) 96

- hr EC 50 = 0.00 7 4 mg a.i./L Slope: 1.0 6 0.1 45 EC 05 = 0.00 21 mg a.i./L (algal cell density) Cloransulam (>96%) 447445

- 14; 436689

- 17 Acceptable

Aquatic Vascular Plants

Duckweed ( L. gibba ) 14

- day EC 50 = 110

mg a.i./L (frond number) Slope: 6.44 0.159 NOAEC = 58.3 mg a.i./L (frond number & growth rate) 5

- hydroxy

cloransulam

- methyl (>95%) 447445

- 05 Supplemental

Duckweed ( L. gibba ) 14

- day EC 50 = ≥ 100

mg a.i./L (frond number) NOAEC = 53.6 mg a.i./L 5

- hydroxy

cloransulam (>97%) 447445

- 10 Acceptable

Duckweed ( L. gibba ) 14

- day EC 50 = 0.130

mg a.i./L (frond number) Slope: 4.51 0.439 NOAEC = 0.0611mg a.i./L Cloransulam (>96%) 447445

- 15 Acceptable



### An acceptable Tier II toxicity study on the green alga
, Psuedokirchneriella subcapitata , (MRID 447445

- 17) was submitted for cloransulam

- methyl using the formulated product Firstrate ® 

### (82.2%); the resulting 96

- hr EC 50 

### was 0.003 mg a.i./L with a correspon ding NOAEC of 0.00094 mg a.i./L. A study conducted on the toxicity to nonvascular plants with the technical grade active ingredient was not submitted. A Tier II study (MRID 436689

- 16) conducted on the aquatic vascular plant duckweed, Lemna gibba , with th e technical grade active ingredient is classified as invalid and cannot be used in an assessment

. Tier II algal toxicity studies on aquatic plants have been submitted for the degradates 5

- hydroxy

cloransulam

- methyl, 5

- hydroxy

- cloransulam, and cloransulam. For 5

- hydroxy

- cloransulam

methyl, three scientifically valid Tier II toxicity studies were submitted, a study on the green alga P. subcapitata (MRID 447445

- 04), the cyanobacteria Anabaena flos

- aquae (MRID 447445

- 01), and the saltwater diatom Skeletonema costatum (MRID 447445

- 03). A second toxicity study is available with P. subcapitata (MRID 437600

- 04) for 5

- hydroxy

- cloansulam

- methyl; however, it was conducted as a preliminary experiment, where numerous guideline deviations and data omissions were appare nt, and the study is considered supplemental information for qualitative use only. A submitted study for 5

- hydroxy

- cloransulam

- methyl on the freshwater diatom Navicula pelliculosa (MRID 447445

- 02) was determined to be scientifically unsound and is classif ied invalid. The EC 50 

### and NOAEC values from the acceptable studies are presented in Appendix D

. Overall, the acceptable studies demonstrate that 5

- hydroxy

- cloransulam

- methyl is less toxic to fresh

- and saltwater algae than is cloransulam

- methyl. EC 50 

### va lues for 5

- hydroxy

cloransulam

- methyl based on algal cell density range from >26.3 mg a.i./L to >93.3 mg a.i./L (for both 96

- hr and 120

- hr studies), much higher than the most sensitive 96

- hr EC 50 

### for cloransulam

- methyl (0.003 mg a.i./L). For two of these studies, the green alga and

### - 19 of 85

-

cyanobacteria, a major change in pH occurred at the two highest test concentrations (nominal 50.0 and 100 mg a.i./L). Between both studies, pH ranged from 3.7

- 5.9 at the two highest test concentrations. The drop in pH did not appear to affect the solubility of 5

- hydroxy

- cloransulam

methy l.

Four Tier II algal studies were submitted for 5

- hydroxy

- cloransulam on P. subcapitata (MRID 447445

- 09), A. flos

- aquae (MRID 447445

- 06), S. costatum (MRID 447445

- 08), and N. pelliculosa (MRID 447445

- 07). A second study was submitted for P. subcapitata (MRID 437600

- 04), but it was conducted as a preliminary experiment, where numerous guideline deviations and data omissions were apparent, and the study is considered supplemental informati on for qualitative use only. The EC 50 

### and NOAEC values, if available, are presented for these studies in Appendix D. Overall, the acceptable studies demonstrate that 5

- hydroxy

cloransulam is less toxic to fresh

- and saltwater algae than is cloransulam

- me thyl. The 96

- hr and 120

- hr EC 50 

### values for 5

- hydroxy

- cloransulam

- methyl based on alga cell density ranged from >10.7 mg a.i./L to >103 mg a.i./L, higher than the most sensitive 96

- hr EC 50 

### for cloransulam

methyl (0.003 mg a.i./L). The 5

- hydroxy

- cloransula m degradate demonstrated the same effects on pH that 5

- hydroxy

- cloransulam

- methyl exhibited. Test media for the higher concentrations (nominal 25.0, 50.0, 100 mg a.i./L) tested for the freshwater green alga, freshwater diatom, and freshwater cyanobacteria , had pH values in the range of 3.3 to 5.0. The drop in pH did not appear to affect the solubility of 5

- hydroxy

- cloransulam for the duration of the tests.

Four Tier II algal studies submitted for cloransulam on P. subcapitata (MRID 447445

- 14), A. flos

- aq uae (MRID 447445

- 11), S. costatum (MRID 447445

- 13), and N. pelliculosa (MRID 447445

- 12). A summary of the EC 50 

### and NOAEC or EC 05 

### values are presented for these studies in Appendix D. Based on a comparison of toxicity to P. subcapitata , cloransulam is rou ghly as toxic to nonvascular plants as cloransulam

- methyl: the 96

- hr EC 50 

### based on alga cell density for cloransulam and cloransulam

- methyl is 0.0074 mg a.i./L and 0.003 mg a.i./L, respectively (see Table 4.3 ). The toxicity of cloransulam to other algae is magnitudes less than the toxicity to P. subcapitata , with 120

- hr EC 50 

### values ranging from >3.65 mg a.i./L to >90.8 mg a.i./L. Cloransulam appeared to affect pH at the highest concentration tested (nominal 100 mg a.i./L) with the freshwater diatom ( N. pelliculosa ); no effect on solubility was noted.

Toxicity studies on the aquatic vascular plant, L. gibba , were also submitted for the degradates 5

- hydroxy

- cloransulam

- methyl (MRID 447445

- 05), 5

- hydroxy

- cloransulam (MRID 447445

- 10), and cloransulam (MR ID 447445

- 15). The EC 50 

### and NOAEC are presented for these studies in Appendix D. Overall, cloransulam is orders of magnitude more toxic to L. gibba based on algal cell density than the other two degradates: The 14

- d EC 50 

### for cloransulam, 5

- hydroxy

clora nsulam

- methyl, and 5

- hydroxy

- cloransulam is 0.130, 110, ≥100 mg a.i./L, respectively (see Table 4.3 ). No effects on pH were observed for these studies. A study on L. gibba submitted for cloransulam

- methyl was classified as invalid because it was scientif ically unsound.

Table 4.3 presents a comparison of toxicity to P. subcapitata and L. gibba between cloransulam

methyl and degradates. The data indicate that cloransulam

- methyl and cloransulam are equally toxic to P. subcapitata , while 5

- hydroxy

- cl ornasulam

- methyl and 5

- hydroxy

- cloransulam are order of magnitude less toxic.

### - 20 of 85

-

Table 4.3: Most Sensitive Endpoints for Aquatic Plant Toxicity Studies using P. subcapitata and L.gibba for Cloransulam

- methyl and Degradates

CHEMICAL SPECIES ENDPOINT (mg

a .i./L) MRID STUDY CLASSIFICATION

Aquatic Nonvascular Plants

cloransulam

- methyl (First

- rate; 82.2%)
Green Alga

( P. subcapitata, formerly S. capricornutum Printz) 96

- hr EC 50 = 0.003

NOAEC = 0.00094 (algal cell density) 447445

- 17 Acceptable

cloransulam (>96%) 96

- hr EC 50 = 0.00 7 4 EC 05 =0.00 21 (algal cell density) 447445

- 14; 436689

- 17 Acceptable

5

- hydroxy

cloransulam

- methyl (>95%) 96

- hr EC 50 = >26.3 NOAEC = 26.3 (algal cell density) 447445

- 04 Supplemental

5

- hydroxy

cloransulam (>97%) 96

- hr EC 50 = >27.9 NOAEC = 27.9 (algal cell density) 447445

- 09 Supplemental

Aquatic Vascular Plants

cloransulam (>96%)

Duckweed

( L. gibba ) 14

- day EC 50 = 0.130

(frond number) NOAEC = 0. 447445

- 15 Acceptable

5

- hydroxy

cloransulam

- methyl (>95%) 14

- day EC 50 = 110 (frond number) NOAEC = 58.3 (frond number & growth rate) 447445

- 05 Supplemental

5

- hydroxy

cloransulam (>97%) 14

- day EC 50 = ≥ 100 (frond number) NOAEC = 53.6 447445

- 10 Acceptable



### 4.2. Effects to Terrestrial Organisms

Table 4.2 summarizes the most sensitive terrestrial animal toxicity endpoints for cloransulam

methyl based on an evaluation of submitted studies. Cloransulam

- methyl is categorized as practically nontoxic to birds on both an acute oral and subacute dietary exposure basis and it practically nontoxic to mammals on an acute oral exposure basis. Cloransulam

- methyl is practically nontoxic to young adult honey bees on an acute contact exposure basis. Chronic toxicity studies of mallard duck ( Anas platyrhynchos ; MRID 436 993

- 01) and bobwhite quail ( Colinus virginianus ; MRID 436689

- 05), originally submitted for the registration of cloransulam

- methyl, were re

- evaluated and are included in the summary table below. Available terrestrial plant toxicity studies are also reported in this section. Terrestrial plant toxicity studies examining vegetative vigor and seedling emergence were submitted for cloransulam

- methyl (MRID 437154

- 04) and for the degradates 5

- hydroxy

- cloransulam

- methyl, 5

- hydroxy

cloransulam, and cloransulam (MRID 447445

- 16). Additionally, one open literature study was available on the effects of the degradate cloransulam to soybean growth and development, which will be evaluated for possible quantitative and/or qualitative inclusion in the final environmental fat e and ecological effects risk assessment

.

### - 21 of 85

-

Table 4.4 . Summary of the M ost S ensitive E ndpoints from S ubmitted Terrestrial T oxicity S tudies for Cloransulam methyl

. TAXON ENDPOINT CHEMICAL/ FORMULATION MRID STUDY CLASSIFICATION BIRDS Acute Oral Bobwhite quail (Colinus virginianus) 14

- day LD 50 > 2250

mg a.i./kg

- bw Cloransulam

- methyl

(97.3%) 430034

- 07 Acceptable

Sub

- Acute Dietary Mallard Duck ( Anas platyrhynchos ) 8

- day LC 50 > 5620

mg a.i./kg

- diet Cloransulam

- methyl

(97.3%) 430034

- 08 Acceptable

Bobwhite quail ( Colinus virginianus ) 8

- day LC 50 > 5620

mg a.i./kg

- diet Cloransulam

- methyl

(97.3%) 430034

- 09 Acceptable

Chronic

Mallard Duck ( Anas platyrhynchos ) NOAEC:127 mg

a.i./kg diet LOAEC: 485 mg a.i./kg diet Cloransulam

- methyl

(97.3%) 43 6993

- 0 1 Acceptable

Bobwhite quail ( Colinus virginianus ) NOAEC: <654 mg

a.i./kg diet LOAEC: 654 mg a.i./kg diet Cloransulam

- methyl

(97.3%) 43 6689

- 0 5 Supplemental

MAMMALS Acute Laboratory Rat ( Rattus norvegicus ) LD 50 > 5000 mg/kg

bw Cloransulam

- methyl

(97.3%) 430034

- 13 Acceptable
Chronic

Rat ( Rattus norvegicus ) NOAEL = 10 mg/kg

bw LOEAL = 100 mg/kg

- bw Based on parental systemic toxicity Cloransulam

- methyl 436689

- 11 Acceptable

TERRESTRIAL INVERTEBRATES Honey Bee (Apis melifera) LD 50 > 25 μg a.i./bee Cloransulam

- methyl (97.3%) 430034

- 31 Acceptable

TERRESTRIAL VASCULAR PLANTS : SEEDLING EMERGENCE

Monocot EC25 = > 0.0613 lbs

ai/A Cloransulam

- methyl

(97.3%) 44744516 Acceptable.

Dicot (Radish) EC25 = >0.0484 lbs

ai/A Cloransulam

- methyl

(97.3%) 44744516 Acceptable.

TERRESTRIAL VASCULAR PLANTS: VEGETATIVE VIGOR

Monocot (Wheat) NOAEC: 0.0559 lbs

a.i./A Cloransulam

- methyl

(97.3%) 44744516 Acceptable.

Dicot (Radish) EC 25 : 0.0118 lbs ai/A Cloransulam

- methyl (97.3%) 44744516 Acceptable

### - 22 of 85

-

An acceptable avian single oral dose toxicity study with bobwhite quail ( Colinus virginianus ) is available for cloransulam

- methyl (MRID 43003407); the resulting 14

- day LD 50 

### was determined to be > 2250 mg a.i./kg with a corresponding NOAEL of 2250 mg a.i./kg

- bw. No mortality, sign

o f toxicity, or effect on body weight or feed consumption occurred at any dose level. All birds were normal in appearance and behavior throughout the study. Two acceptable avian dietary toxicity studies were submitted to the Agency for cloransulam

- methyl using the bobwhite quail ( C. virginianus ) (MRID 43003409) and mallard duck ( Anas platyrhunchos ) (MRID 43003408). The resulting 8

- day LC 50 

### for both studies was >5620 mg a.i./kg

- diet, with a corresponding NOAEC of 5620 mg a.i./kg

- diet. No mortality, effect on body weight gain or feed consumption, or any other sublethal effect occurred in either study at any tested concentration level. Based on these three studies, cloransulam

- methyl is classified practically non

- toxic to birds on an acute oral and subacute dietary exposure basis. Two toxicity studies on avian reproduction for the mallard duck (MRID 43699301) and Bobwhite quail (MRID 43668905) were re

- evaluated. These studies were originally submitted for the registration of cloransulam

- methyl and the prev ious reviews identified effects to mallard ducks; effects to bobwhite quail were not identified. The mallard duck ( A. platyrhunchos ) study revealed a NOAEC of 127 mg ai/kg

- diet and a LOAEC of 485 mg ai/kg

- diet with the most sensitive endpoint being eggshe ll thickness, while the bobwhite quail ( C. virginianus ) study showed a NOAEC and LOAEC of <654 mg ai/kg diet and 654 mg ai/kg diet, respectively.

Two acute oral toxicity studies on Fischer 344 rats were conducted for the registration of cloransulam

- methyl. In one study conducted on cloransulam

- methyl (97.3%) (MRID 430034

- 13), a limit dose of 5,000 mg/kg was administered to both males and females and no significant clinical signs of toxicity were reported; the LD 50 

### was >5,000 mg/kg

- bw. I n a second study conducted on the formulation FirstRate ® 

### a formulated product with the active ingredient cloransulam

- methyl only (84.4% a.i.) (MRID 430034

- 19), a limit dose of 5,000 mg form/kg

- bw was administered to both male and female rats. Sublethal si gns of toxicity included perineal urine, fecal soiling, loose stool, and salivation. Based on a lack of mortality, the LD 50 

### was >5,000 mg form/kg

- bw.

An acute rat single

- oral dose toxicity study was submitted to the Agency for the formulation Gauntlet ® 

### 70 DF (MRID 45388202), a mixture of the two active ingredients cloransulam

- methyl (8.1%) and sulfentrazone (61.8%). Young adult Sprague

- Dawley rats (5 male and 5 female) were orally gavaged with Gauntlet ® 

### 70 DF as a 50% w/v concentration in tap water at the doses 1,000 mg/kg (males only), 2,500 mg/kg, 4,000 mg/kg, and 5,000 mg/kg. None of the males dosed at 1,000 mg/kg died; at 2,500 mg/kg 3 males and 1 female died; at 4,000 mg/kg 3 males and 2 females died; and at 5,000 mg/kg all 5 males and females die d. Observed symptoms of toxicity were abdominal gripping, colonic convulsions, diarrhea, decreased locomotion, hypersensitivity to touch/sound, loss of muscle control, oral discharge, tremors, and writhing. Necropsy revealed one 5,000 mg/kg male with red urine in its bladder. The LD 50 

### = 2504 mg/kg based male mortality, and the LD 50 

### = 3803 mg/kg based on female mortality. This study was classified acceptable.

A two

- generation (chronic) reproduction study in male and female Sprague

- Dawley rats (MRID 43 668911) was submitted to the Agency for registration of cloransulam

- methyl. Test rats received nominal daily doses of 0 (control), 10, 100, and 500 mg/kg

- bw/day in their feed. Based

### - 23 of 85

-

on decreased live pups and increased pup deaths, the NOAEL and LOAEL for developmental/offspring systemic toxicity is 10 0 mg/kg

- diet/day and 500 mg/kg

- bw/day, respectively. Histopathological alterations of the kidney occurred at 100 mg/kg

- bw/day in both male and female parental rats. Thus the NOAEL for parental systemic toxi city is 10 mg/kg

bw/day. The NOAEL based on developmental/offspring systemic toxicity will be used to assess chronic risk of cloransulam

- methyl use to mammals.

Cloransulam

- methyl is classified practically non

- toxic to young adult honey bees ( Apis mell ifera ) based on the one acute contact toxicity study (MRID 430034

- 31). The resulting LD 50 

### and NOAEL based on immobile/lethargic bees is >25 μg a.i./bee and 25 μg a.i./bee, respectively.

4.3. Incident Databases Review

Preliminary reviews of the Ecological Incident Information System (EIIS, version 2.1) and the Avian Incident Monitoring System (AIMS) 5 

### were conducted on July 27, 2010. A total of 54 incidents associated with cloransulam

- methyl use have been reported (all involving plants
, mostly soybeans and corn ) in EIIS . The reported incidents occurred between 1998 and 2005
, with affected areas ranging from 5 acres to 677.5 acres

. Most of the incidents were the result of a broadcast application, while a number of others involved spray application. Most of the incidents involved the application of FirstRate ® 

### , a formulated product with the active ingredient cloransulam

- methyl only. Moreover, t he certainty with which these incidents were a result of cloransulam

- methyl use was described as highly probable in two incidents, probable in thirty

- six incidents, possible in thirteen incidents, and unlikely in three incidents. Thirty

- seven of the incidents were the result of registered use, four were the result of misuse (intentional)
, seven were the result of misus e (accidental); however, it is unknown if the other five incidents resulted from misuse or registered uses. Specific details of the incidents are described below. No incidents involving birds were reported in the AIMS database for clora n sulam

- methyl.

In addition to the incidents recorded in EIIS, additional incidents have been reported to the Agency in aggregated incident reports. Pesticide registrants report certain types of incidents to the Agency as aggregate counts of incidents occurring per product per quarter. Ecological incidents reported in aggregate reports include those categorized as „minor fish and wildlife‟ (W

B), „minor plant‟ (P

- B), and „other non

- target‟ (ONT) incidents. „Other non

- target‟ incidents include reports of adverse effects to insects and other terrestrial invertebrates. For cloransulam

methyl, as of July 27, 2010, registrants have reported 102 minor plant incidents associated with the use of clora n sulam methyl , all of which occurred between 1998 and 2006. The number of indiv idual plants affected in these incidents was not specified. Unless additional information on these aggregated incidents become s available, they will be assumed to be representative of registered uses of cloransulam

- methyl in the risk assessment. All of th e reported incidents invol v ed terrestrial plants.

The total number of actual incidents associated with the use of clora n sulam

- methyl may be higher than what is reported to the Agency. Incidents may go unreported since effects may not

5 http://www.abcbirds.org/abcprograms/policy/pesticides/aims/aims/index.cfm

### - 24 of 85

-

be immediately appar ent and/or readily attributed to the use of a chemical. As such, the absence of incident reports cannot be construed as the absence of incidents.

4.4. Ecosystems Potentially at Risk

The ecosystems at risk are often extensive in scope; therefore, it may not b e possible to identify specific ecosystems during the development of a nation

- wide ecological risk assessment. However, in general terms, terrestrial ecosystems potentially at risk could include the treated field and immediately adjacent areas that may re ceive drift or runoff. Areas adjacent to the treated field could include cultivated fields, fencerows and hedgerows, meadows, fallow fields or grasslands, woodlands, riparian habitats and other uncultivated areas.

Aquatic ecosystems potentially at risk include water bodies adjacent to, or downstream from, the treated field and could include impounded bodies such as ponds, lakes and reservoirs, or flowing waterways such as streams or rivers. For uses in coastal areas, aquatic habitat also includes marin e ecosystems, including estuaries.

5. Assessment Endpoints

Assessment endpoints represent the actual environmental value that is to be protected, defined by an ecological entity (species, community, or other entity) and its attribute or characteristic s (USEPA, 1998 a ). For cloransulam

- methyl, the ecological entities may include the following: birds, mammals, terrestrial

- phase amphibians, reptiles, freshwater fish and invertebrates, aquatic

phase amphibians, estuarine/marine fish and invertebrates, ter restrial plants, terrestrial invertebrates, and aquatic plants. The attributes for each of these entities include growth, reproduction, and survival.
6. Conceptual Model

For a pesticide to pose an ecological risk, it must reach ecological receptors in biologically significant concentrations. An exposure pathway is the means by which a pesticide moves in the environment from a source to an ecological receptor. For an ecological pathway to be complete, it must have a source, a release mechanism, an envi ronmental transport medium, a point of exposure for ecological receptors, and a feasible route of exposure.

The conceptual model for cloransulam

- methyl provides a written description and visual representation of the predicted relationships between clorans ulam

- methyl, potential routes of exposure, and the predicted effects for the assessment endpoint. A conceptual model consists of two major components: risk hypothesis and a conceptual diagram (USEPA
, 1998).

Based on the submitted environmental fate data, cloransulam

- methyl is not expected to volatilize and persist ence in surface waters is uncertain ; however, its soil mobility and persistence in the soil subsurface is of concern. The compound , and its major degradates, may potentially leach to ground wate r where they could persist (a PGW study is currently under review). Cloransulam

methyl is degraded mainly by photolysis in clear shallow water and aerobic microbial

### - 25 of 85

-

degradation in soil, and degrades by hydrolysis under alkaline conditions

. Due to its low K ow 

### value, cloransulam

- methyl is not expected to bioaccumulate in aquatic or terrestrial food chains.

P revious ecological risk assessments for cloransulam

- methyl identified risk to listed and non

listed terrestrial plants from cloransulam

- methyl use

. As such, listed species in all taxa may potentially be affected indirectly due to alterations in their habitat and effects on primary productivity

. It was determined that all other taxa were not at direct risk from cloransulam

methyl use in soybean. Howeve r, this determination was based on an incomplete dataset, and risks to freshwater and estuarine/marine fish and invertebrates and aquatic plants are uncertain. Additionally, effects data on birds, aquatic vascular plants, and terrestrial plants are being re

evaluated. These preliminary conclusions are used to derive the risk hy pothesis and conceptual diagram discussed below.

6.1. Risk Hypothesis

A risk hypothesis describes the predicted relationship among the stressor, exposure, and assessment endpoint response along with the rationale for their selection. Because data are either not available with which to assess the chronic effects of cloransul am

- methyl on aquatic animals or data are incomplete with which to assess chronic effects to birds or effects to aquatic vascular and nonvascular plants, there is uncertainty regarding potential risk to these taxa. Based on this lack of data, and on an ant icipated risk determination for listed aquatic plant species , the following ecological risk hypothesis is being employed for this ecological risk assessment:

Given the uses of cloransulam

- methyl as a pre

- and post

- emergent herbicide in soybean production and its environmental fate properties, there is potential exposure from cloransulam

- methyl and its degradates of concern to non

- target terrestrial and/or aquatic organisms. When used in accordance with the label, cloransulam

- methyl and its degradates may result in potential adverse effects upon the survival, growth, and reproduction of non

- target terrestrial and/or aquatic organisms.

6.2. Conceptual Diagram

The environmental fate properties of cloransulam

- methyl indicate that runoff, spray drift and direct spray represent potential transport mechanisms to aquatic and terrestrial habitats where

non

- target organisms may be either directly or indirectly exposed

. These transport mechanisms ( i.e ., sources) are depicted in the conceptual diagrams below ( Figures 6.1 and 6.2 ) along with the receptors of concern and the potential attribute changes in the receptors due to exposures of clorans u lam

- methyl. While not captured in Figure 6.2 , exposure of terrestrial vertebrates from drinking water containing cloransulam

- methyl and degradates of concern is also a route of exposure that will be assessed.

### - 26 of 85

-

FIGURE 6.1. Conceptual Model for Cloransulam

- methyl and Degradate Effects on Aquatic Organisms. Dotted Lines Indicate Exposure Pathways that Have a Low Likelihood of Contributing to Ecological Risk.

### - 27 of 85

-

FIGURE 6.2. Conceptual Model for Cloransulam

- methyl and Degradate Effects on Terrestrial Organisms . Do tted Lines Indicate Exposure Pathways that Have a Low Likelihood of Contributing to Ecological Risk.

7. Analysis Plan

In order to address the risk hypothesis, the potential for adver se effects on the environment will be estimated. The use, environmenta l fate, and e cological effects of cloransulam

- methyl will be characterized and integrated to assess the risks

. Risk quotients (RQ ) will be derived for cloransulam

- methyl by dividing estimated environmental concentrations (EEC) by the most sensitive endpoi nt from the relevant, available toxicity data for cloransulam

- methyl

. This analysis plan will be revisited and may be revised depending upon a full review of the data available in the open literature and the information submitted by the public in response to the opening of the Registration Review docket.

### - 28 of 85

-

7.1. Stressors of Concern

The stressors, or residues, of concern in this assessment will include cloransulam

- methyl and any degradates determined to be of to xicological concern . Terrestrial and aquatic plants studies are available on three of the degradates identified in Section 3.4 determined to be mobile and more persistent than the parent: 5

- hydroxy

- cloransulam

- methyl, 5

- hydroxy

- cloransulam, and cloransulam. All available s tudies on terrestrial plants have been review ed for both cloransulam

- methyl and degradates, as well as a study on vascular plants for cloransulam

methyl. Based on the available toxicity data, as seen in Table 4.3 , cloransulam

- methyl (MRID 44744517) and c loransulam (MRID 44744514; 43668917) are similarly toxic (same order of magnitude) to the green alga, P. subcapitata . The toxicity endpoints of 5

- hydroxy

- cloransulam

methyl (MRID 44744504) and 5

- hydroxy

- cloransulam (MRID 44744509) to P. subcapitata are
mo re than four times less toxic. Thus, the stressors of concern for this assessment will include cloransulam

- methyl and cloransulam, as well as any other degradates determined to be of toxicological concern at the time the risk assessment is completed. Mod eled exposure estimates resulting from cloransulam

- methyl use will reflect the predicted environmental fate of cloransulam

- methyl and any residues of toxicological concern

.

T he Agency does not routinely include an evaluation of mixtures of active ing redients in its ecological risk assessments , either those mixtures of multiple active ingredients in product formulations or those in the applicator‟s tank. In the case of the product formulations of active ingredients (that is, a registered product containing more than one active ingredient), each active ingredient is subject to a n individual risk assessment for regulatory decision regarding the active ingredient on a particular use site. If effects data are available for a formulated product containing more than one active ingredient, the data may be used qualitatively or quantit atively in accordance with the Agency‟s Overview Document and the Services‟ Evaluation Memorandum (USEPA
, 2004; USFWS/NMFS
, 2004).
Available toxicity data for environmental mixtures of cloransulam

- methyl with other pesticides will be presented as part of the ecological risk assessment. It is expected that the toxic effect of cloransulam

- methyl, in combination with other pesticides used in the environment, is likely to be a function of many factors including but not necessarily limited to: (1) the expo sed species, (2) the co

- contaminants in the mixture, (3) the ratio of cloransulam

- methyl and co

- contaminant concentrations, (4) differences in the pattern and duration of exposure among contaminants, and (5) the differential effects of other physical/chemi cal characteristics of the receiving waters ( e.g. organic matter present in sediment and suspended water). Quantitatively predicting the combined effects of all these variables on mixture toxicity to any given taxa with confidence is beyond the capabiliti es of the available data and methodologies. However, a qualitative discussion of implications of the available pesticide mixture effects data on the confidence of risk assessment conclusions will be addressed as part of the uncertainty analysis.

7.2. M easures of Exposure

In order to estimate risks of cloransulam

- methyl exposures in aquatic and terrestrial environments, all exposure modeling and resulting risk conclusions will be made based on

### - 29 of 85

-

maximum application rate for the currently registered use [ i .e ., soybeans ] as discussed in Section 3.2. Measures of exposure are based on aquatic and terrestrial models that estimate environmental concentrations of cloransulam

- methyl using the maximum labeled application rate and application methods that have the greatest potential for off

- site transport of the chemical. The models used to generate aquatic estimated environmental concentrations (EEC) are the Pesticide Root Zone Model (PRZM) coupled with the EXposure Analysis Model System (EXAMS) . The EECs will be based on the parent compound plus the degradate cloransulam, as well as any other degradates that are determined to be of toxicological concern based on information available at the time of the assessment. Environmental inputs for the total toxic residue s in aquatic systems (cloransulam

- methyl + cloransulam) will be calculated using the total residue approach (TR). The model used to produce terrestrial EECs on food items is T

- REX. The model used to derive EECs relevant to terrestrial and wetland plants is TerrPlant. These models are parameterized using relevant reviewed registrant

- submitted environmental fate data.

PRZM (v3.12.2, May 2005) and EXAMS (v2.98.4.6, April 2005) are screening simulation models coupled with the graphical user interface, PE (v 5.0, November 2006) to generate daily exposures and 1

- in

- 10

- year EECs of cloransulam

- methyl (and residues of concern) that may occur in surface water bodies adjacent to application sites receiving cloransulam

- methyl through runoff and spray drift. PRZM si mulates pesticide application, movement and transformation on an agricultural field and the resultant pesticide loadings to a receiving water body via runoff, erosion, and spray drift. EXAMS simulates the fate of the pesticide and resulting concentrations in the water body. The standard watershed geometry used for ecological pesticide assessments assumes application to a 10

- hectare agricultural field that drains into an adjacent 1

- hectare water body that is 2 meters deep (20,000 m 3 

### volume) with no outlet. The composite model PRZM/EXAMS is used to estimate screening

- level exposure of aquatic organisms to cloransulam

- methyl. The measure of exposure for aquatic species is the 1

- in

- 10

- year peak or rolling mean concentration. The 1

- in

- 10

- year peak is used for estimating acute exposures of direct effects to aquatic organisms. The 1

- in

- 10

- year 60

- day mean is used for assessing the effects to fish and aquatic

- phase amphibians from chronic exposure. The 1

- in

- 10

- year 21

- day mean is used f

or assessing the effects on aquatic invertebrates from chronic exposure.

Exposure estimates for terrestrial animals assumed to be in the target area or in an area exposed to spray drift are derived using the T

- REX model (version 1.4.1, 10/08/2008). This model incorporates the Kenaga nomograph, as modified by Fletcher et al. (1994), which is based on a large set of actual field residue data. The upper limit values from the nomograph represent the 95 th 

### percentile of residue values fro m actual field measurements (Hoerger and Kenaga 1972). The Fletcher et al. (1994) modifications to the Kenaga nomograph are based on measured field residues from 249 published research papers, including information on 118 species of plants, 121 pesticides , and 17 chemical classes. For input into T

- REX, the default foliar dissipation half

- life of 35 days will be used due to insufficient foliar dissipation rate data on cloransulam

- methyl. If terrestrial plant toxicity data are available, EECs for terrestri al plants inhabiting dry and wetland areas are derived using TerrPlant (version 1.2.2, 12/26/2006). This model uses estimates of pesticides in runoff and in spray drift to calculate EECs. EECs are based upon solubility, application rate and minimum incor poration depth.

### - 30 of 85

-

The AgDRIFT spray drift model (v2.01; May
, 2001) is used to assess exposures of organisms to cloransulam

- methyl deposited on terrestrial habitats by spray drift.

The Screening Imbibition Program (SIP v.1.0, Released June 15, 2010) was u sed to calculate an upper bound estimate of exposure using cloransulam

- methyl‟s solubility, the most sensitive acute and chronic avian toxicity endpoints (bobwhite quail LD 50 

### >2250 mg a.i./kg

- bw; NOAEC unavailable) and the most sensitive acute and chronic mammalian toxicity endpoints (laboratory rat LD 50 

### >5,000 mg a.i./kg

- bw and NOAEL = 100 mg a.i./kg

- bw, respectively). Appendix E provide s a description of the model and assumptions in deriving an upper bound exposure estimate. At a pH of 8.5, cloransulam

- methyl‟s reported solubility in water at 20°C is 3400 mg/L (MRID 43668933). Drinking water exposure alone was determined to be a potential concern for mammals on a chronic basis, and a potential pathway of concern for birds on chronic basis due to non

- de finitive endpoints ( see Appendix E for model results ). Although this model flags acute exposure to birds and mammals as a potential concern based on potential estimated environmental concentrations in drinking water at pH 8.5 and above , toxicity data demo nstrate that acute/subacute effects from cloransulam

- methyl exposure is not likely a concern for birds or mammals. This pathway will be explored further with the development of SIP v.2.0 in the Ecological Risk Assessment for cloransulam

- methyl. Detailed information about the SIP v.1.0, as well as the tool, can be found on the EPA‟s website at http://www.epa.gov/pesticides/science/models_pg.htm#terrestrial

.

7.3. Measures of Effect

Ecological effects data are used as measures of dir ect and indirect effects to biological receptors

. As discussed previously, d ata are obtained from registrant

- submitted studies or from literature studies identified by ECOTOX. The ECOTOX dat abase provide s more ecological effects data in an attempt to bridge existing data gaps. ECOTOX is a source for locating single chemical toxicity data and potential chemical mixture toxicity data for aquatic life, terrestrial plants, and wildlife. ECOTOX was created and is maintained by the USEPA, Office of Research and Development, and the National Health and Environmental Effects Research Laboratory's Mid

Continent Ecology Division.

Also as discussed previously, information on the potential effects of cloransulam

- methyl on non

target animals is also collected from the Ecological Incident Information System (EIIS; USEPA, 2007 c ). The EIIS is a database containing adverse effect (typically mortality) reports on non

target organisms where such effects have been associated with the use of pesticides.

Incidents reported in the aggregate incident reports and the Avian Incident Monitoring System (AIMS) will also be searched again. AIMS is a database administered by the American Bird Conservancy with partial f und ing from EPA). It contains publicly available data on reported avian incidents involving pesticides ( http://www.abcbirds.org/abcprograms/policy/pesticides/aims/aims /index.cfm )

. Where available, sub

- lethal effects observed in both registrant

- submitted and open literature studies will be evaluated qualitatively. Such effects may include behavioral changes ( e.g. ,

### - 31 of 85

-

lethargy and changes in coloration). Quantitative asse ssments of risks, though, are limited to those endpoints that can be directly linked to the Agency‟s assessment endpoints of impaired survival, growth and reproduction.

The assessment of risk for direct effects to non

- target organisms makes the assumption that toxicity of cloransulam

- methyl to birds is similar to terrestrial

- phase amphibians and reptiles

. The same assumption is made for fish and aquatic

- phase amphibians

.
The acute measures of effect use d for animals in this assessment are the LD 50 

### , LC 50 

### and EC 50 

### . LD stands for "Lethal Dose", and LD 50 

### is the amount of a material, given all at once, that is estimated to cause the death of 50% of the test organisms. LC stands for “Lethal Concentration” and LC 50 

### is the concent ration of a chemical that is estimated to kill 50% of the test organisms. EC stands for “Effective Concentration” and the EC 50 

### is the concentration of a chemical that is estimated to produce a specific effect in 50% of the test organisms. Endpoints for c hronic measures of exposure for listed and non

- listed animals are the NOAEL/NOAEC and NOEC. NOAEL stands for “No Observed

- Adverse

- Effect

- Level” and refers to the highest tested dose of a substance that has been reported to have no harmful (adverse) effect s on test organisms. The NOAEC ( i.e. , “No

- Observed

- Adverse

- Effect

- Concentration”) is the highest test concentration at which none of the observed effects were statistically different from the control. The NOEC is the No

- Observed

- Effects

- Concentration. F or non

- listed plants, only acute exposures are assessed ( i.e. , EC 25 

### for terrestrial plants and EC 50 

### for aquatic plants ); for listed plants either the NOAEC or EC 05 

### is used

.

7.4. Integration of Exposure and Effects

Risk characterization is the integra tion of exposure and ecological effect characterization s to determine the potential ecological risk from the use of cloransulam

- methyl and the likelihood of direct and indirect effects to non

- target organisms in aquatic and terrestrial habitats. The expos ure and effects data are integrated in order to evaluate potential adverse ecological effects

on non

- target species. For the assessment of cloransulam

- methyl risks, the risk quotient (RQ) method is used to compare estimated exposure and measured toxicity values. Acute and chronic EECs are divided by acute and chronic toxicity values. The resulting RQs are then compared to the Agency‟s L evels of Concern (LOC ) (USEPA 2004). These criteria are used to indicate when cloransula m

- methyl‟s use , as directed on the label s, has the potential to cause adverse direct or indirect effects to non

- target organisms

. In addition, incident data from EIIS, aggregate incident reports, and AIMS will be considered as part of the risk characteriz ation.

7.5. Deterministic and Probabilistic Assessment Methods

The quantitative assessment of risk will primarily depend on the deterministic point estimate

based approach described in the risk assessment. Depending on the risk manager‟s need for addi tional information regarding risk, an effort will be made to further qualitatively describe risk using probabilistic tools that the Agency has developed. These tools have been reviewed by FIFRA Scientific Advisory Panels ( http://www.epa.gov/scipoly/sap/index.htm ) and have been

### - 32 of 85

-

deemed as appropriate means of refining assessments where deterministic approaches have identified risks.

7.6. Endangered Species Assessments

Consistent with the Agency‟s res ponsibility under the Endangered Species Act (ESA), the Agency will evaluate risks to Federally

- listed threatened and/or endangered (listed) species from registered uses of cloransulam

- methyl . This assessment will be conducted i n accordance with the Overv iew Document (USEPA, 2004) , provisions of the E SA , and the Services‟ Endangered Species Consultation Handbook (USFWS/NMFS, 1998).

T he assessment of effects associated with the registration of cloransulam

- methyl is based on an action area. The action area is considered to be the area directly or indirectly affected by the federal action, as indicated by the exceedance of Agency Levels of Concern (LOCs) used to evaluate direct or indirect effects. The Agency‟s appr oach to defining the action area under the provisions of the Overview Document (USEPA, 2004) considers the results of the risk assessment process to establish boundaries for that action area with the understanding that exposures below the Agency‟s defined LOCs constitute a no

- effect threshold. F or the purposes of this assessment, attention will be focused on the footprint of the action ( i.e ., the area where cloransulam

- methyl application occurs), plus all areas where offsite transport ( i.e ., spray drift,

r unoff, etc .) may result in potential exposure that exceeds the Agency‟s LOCs. Specific

measure s of ecological effect that define the action area for listed species include any direct and indirect effect s and /or potential modification of its critical habit at, including reduction in survival, growth, and reproduction as well as the full suite of sub

- lethal effects available in the effects literature. Therefore, the action area extends to a point where environmental exposures are below any measured lethal or sub

- lethal effect threshold for any biological entity at the whole organism, organ, tissue, and cellular level of organization. In situations where it is not possible to determine the threshold for an observed effect, the action area will be assumed to e ncompass the entire United States.

7.7. Drinking Water Assessment

A drinking water assessment will be conducted to support future human health dietary risk assessments of cloransulam

- methyl. The drinking water assessment will incorporate model estimates of cloransulam

- methyl residues of concern, including cloransulam

- methyl and any degradates of toxicological concern, in surface water and ground water. Concentrations of cloransu la m

- methyl and its residues of concern in surface water will be estimated using PRZM/EXAMS (see description in Section 7.2 ). Ground water exposure estimates for cloransulam

- methyl and its residues of concern will be estimated using the Screening Concentration in Ground Water (SCI

- GROW) model (v.2.3, July 2003) followed by a higher tier model if necessary. The drinking water assessment will also include a summary of available surface and ground water monitoring data.

### - 33 of 85

-

7.8. Pr eliminary Identification of Data Gaps

7.8.1. Environmental Fate

The studies submitted to fulfill environmental fate data requirements for cloransulam

- methyl are not sufficient for an exposure assessment. Six guideline requirements have not been satisf ied. 1) The current supplemental anaerobic aquatic metabolism study will be used for risk assessment purposes, however an additional acceptable study in an acidic (low pH) system is required to fulfill the guideline and better understand the potential var iability in the biotic degradation of cloransulam

- methyl in oxygen limiting aquatic environments. 2) There is no anaerobic soil metabolism study. 3) There is no acceptable terrestrial field dissipation study , currently reviewed studies are classified as su pplemental but will be used for risk assessment

. There is an additional terrestrial field dissipation study that was submitted to the Agency and is currently under review. 4) There is no acceptable frozen storage stability study, and a n aerobic soil meta bolism study ( MRID 43003434 )
, show ed that extracted residues decreased as a result of frozen storage prior to analysis. I t is important to have an acceptable frozen storage stability study using the same soils

as the terrestrial field dissipation study in order to be confident that any degradation measured in the test system was due solely to the environment of that test system, and not due to handling and storage. 5) Acceptable aerobic aquatic metabolism data are not available. A submitted study (MRID 44265302 ) was classified as un acceptable and cannot be used for risk assessment

. 6) Although not crucial for risk assessment purposes, the Agency does require that an acceptable method and two independent laboratory validations (ILVs) be submitted for sedi ment.

Table 7. 2 identifies studies by MRID that offer data for each guideline requirement, as well as study classifications and whether or not further data are needed in order to support risk assessment ( i.e. , whether there is a data gap). Draft Data Ca ll

- In (DCI) tables for requested data are provided in APPENDIX F

.
TABLE 7. 1 . Environmental Fate Data Requirement Table for Cloransulam

- methyl.

OPPTS Guideline Data Requirement Submitted Studies (MRID ) Classification Data Gap? Comment

835.2120 Hydrolysis 43003432 Acceptable No

835.2240 Aqueous photolysis 43715402 Acceptable No

835.2410 Soil photolysis 43760001 Supplemental No Study has been reclassified as SUPPLEMENTAL because there are significant differences in the half

- lives of the two labeled studies. Light intensity and aerobic soil metabolism appeared to be dominant, however when corrected for metabolism and day light at 40oN half

- lives are still significantly different.

835.4100 Aerobic soil

metabolism 43003433 Acceptable

No Classified acceptable in EUP memo (Clem to Taylor 12/23/95) 43216602 (aka 43003435) Supplemental Supplemental aerobic metabolism data on 16 soils from an adsorption/desorption study.

43003434 Supplemental Supplemental data (same study as MRID

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-

OPPTS Guideline Data Requirement Submitted Studies (MRID ) Classification Data Gap? Comment

43003433)

43003435 Supplemental Supplemental data (Same study as MRID 43216602)

44809201 Under review Study was conducted using soils form two sites (IA & IN) that were previously used for flufanacet and flumetsulam PGW studies, respectively.

Currently under review.

835.4200 Anaerobic soil

metabolism No data

-- Yes 1997 fate assessment (D223558+) stated that anaerobic aquatic metab study was submitted in place of the anaerobic soil to fulfill this requirement. Current data requirements include both studies.

835.4300 Aerobic aquatic

metabolism 44265302 Not Acceptable Yes Multiple deficiencies including inadequate duration of study and failure to demonstrate patterns of formation and decline of degradates.

835.4400 Anaerobic aquatic

metabolism 43715403 Supplemental Yes Data are needed for two additional sediment system s, one each at a neutral and an acidic pH

.

835.1230 Adsorption/

desorption and leaching 43003434 Acceptable

No Also includes ancillary data on aerobic soil metabolism. 43003435 and 43216602 Acceptable Also includes ancillary data on aerobic soil metabolism.

835.6100 Terrestrial field

dissipation 43760002 Supplemental

Yes A frozen storage stability study has not been submitted. 44231501 Under review Currently under review

Freezer storage stability No data

-- Data from another study (MRID 43003434) show extracted residues decreased as a result of frozen storage prior to analysis. An acceptable freezer storage stability study using the soils used in the TFD studies is needed. Analytical method

– soil 44231502 Acceptable No
Analytical method

- water 44231503 Acceptable No
Analytical method

- sediment No data

-- Yes

835.7100 Prospective

Ground Water Monitoring 46161601 Under review

-- Study was submitted as a condition of registration. Currently under review.

850.1730 Fish

bioconcentration No data

-- No Low K ow value indicates a low potential for cloransulam

- methyl to bioconcentrate in fish, therefore a study is not required under 40 CFR part 158 Subpart G

.

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- 7.8.2. Effects Data

Although many submissions have been made to provide studies on the effects of cloransulam

methyl to aquatic and terrestrial organisms, data gaps remain ( Tables 7. 3

- 7. 5 ). D ata gaps include the following: avian acute oral, avian reproduction, freshwater invertebrate, freshwater invertebrate life

- cycle, freshwater fish early life stag e, terrestrial plant tier II vegetative vigor
, and aquatic vascular and nonvascular plant toxicity studies . These data gaps are discussed below.

TABLE 7. 2

. Available Ecological Effects Data for Terrestrial Animals Exposed to Cloransulam

- methyl and Remai ning Data Gaps.
Guideline Description MRID/ Accession Classification Data Gap? Comments

850.2100 Avian acute oral

toxicity 430034

- 07 Acceptable Yes * *Avian acute oral toxicity data are not available for passerines, which are required under the new 40 CFR Part 158. Therefore, this is identified as a data gap.

** Adverse significant effects were found at the lowest treatment concentration. 850.2200 Avian sub

- acute

dietary toxicity 430034

- 08 Acceptable No

430034

- 09 Acceptable

850.2300 Avian reproduction 4 36689

- 05 Supplemental Yes **
436993

- 01 Acceptable No
850.3020 Honeybee acute

contact toxicity 430034

- 31 Acceptable No

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-

TABLE 7. 3

. Available Ecological Effects Data for Aquatic Animals Exposed to Cloransulam

- methyl and Remaining Data Gaps.

Guideline Description MRID/ Accession Classification Data Gap? C omments

850.1075 Freshwater fish

–

Acute toxicity 430034

- 11 Acceptable No * Toxicity data for freshwater fish and invertebrates , which

are required, are not currently available. Therefore, these are identified as data gaps.

* * Conditional data requirement not triggered based on ecotoxicity data, predicted EECs, fate properties, and use pattern criteria 430034

- 10 Acceptable

850.1010 Freshwater

invertebrates

– Acute toxicity 430034

- 12 Invalid Yes *

850.1075 850.1025 850.1035 Estuarine and Marine

Organisms

– Acute toxicity 437189

- 01 Acceptable

No

437189

- 02 Acceptable

437189

- 03 Acceptable

850.1300 Freshwater

invertebrate

– life cycle test None Not applicable Yes *

850.1350 Saltwater invertebrates

– life cycle test None Not applicable No**

850.1400 Freshwater fish

–

early life stage test None Not applicable Yes*

850.1400 Saltwater fish

–

early life stage test None Not applicable No **

850.1500 Fish life cycle test None Not applicable No **

### - 37 of 85

-

TABLE 7. 4

. Available Ecological Effects Data for Plants Exposed to Cloransulam

- methyl and Remaining Data Gaps.

Guideline Description MRID Classification Data Gap? C omments

850.4100 Terrestrial Plant

toxicity: Tier I seedling emergence None Not applicable No T ier I t oxicity data for terrestrial plants are not required for known phytotoxicants.

850. 4225 Te rrestrial Plant

toxicity: Tier II seedling emergence 44744516 Acceptable Yes The study was conducted using the TGAI (typical grade active ingredient) instead of the required TEP (typical end

use product)

850.4150 Terrestrial Plant

toxicity: Tier I vegetative vigor None Not applicable No T ier I t oxicity data for terrestrial plants are not required for known phytotoxicants.

850. 4250 Te rrestrial Plant

toxicity: Tier II vegetative vigor 44744516 Acceptable Yes The study was conducted using the TGAI (typical grade active ingredient) instead of the required TEP (typical end

use product); Study duration was not reported

850.5400 Aquatic Plant Growth:

algae 44744517 Acceptable Yes Data are required for four species: a freshwater green alga, freshwater diatom, nitrifying cyanobacteria, and saltwater diatom. Data were only submitted for the parent compound on a green alga.

850.4400 Aquatic Plant Growth:

vascular plants 43668916 Invalid Yes T he results of this study do not fully meet guideline standards for an aquatic plant growth test using L. gibba

.



### Avian Acute Oral and Reproduction Toxicity

Acceptable acute avian oral toxicity data were submitted for exposures of bobwhite quail and mallard duck to cloransulam

- methyl ; however, data are not available for passerines, which are required under the new 40 CFR Part 158 (Oct. 26, 2007) data requireme nts for conventional pesticides (72 FR 60934; USEPA 2007 d ). The new Part 158 data requirements specify that avian acute oral toxicity data (OCSPP Guideline 850.2100) be submitted for either a mallard duck or bobwhite quail and a passerine species. Due to lack of reported toxicity in mallard duck and bobwhite quail to cloransulam

- methyl on an acute oral and subacute dietary exposure basis, significant acute oral effects to passerines are not expected. Unless new information suggests passerines might be se nsitive to cloransulam

- methyl, EFED will not otherwise ( i.e. in the absence of data) assume acute risk for passerine species.

### - 38 of 85

-

Under the 40 CFR Part 158 (Oct. 26, 2007) data requirements for conventional pesticides
, avian reproduction data are require d on waterfowl and upland game species (OCSPP Guideline 850.2300). Data for cloransulam

- methyl were review ed for both an upland game species (bobwhite quail), MRID 43668905, and waterfowl species (mallard duck), MRID 436993

- 01. The bobwhite quail study resulted in significant adverse effects at the lowest treatment concentration. T he NOAEC for the bobwhite quail was statistically determined to be <654 mg a.i./kg

- diet based on number of eggs set, number of viable embryos, number of live embryos, number hatched, and hatchling survival. The preliminary NOAEC based on these five parameters in the mallard study is 1,505 mg a.i./kg

- diet, indicating that for certain parameters the bobwhite quail is more sensitive to cloransulam

- methyl. Therefore, since a pre liminary review suggests that the bobwhite study failed to determine a NOAEC, and because additional avia n reproduction data on bobwhite quail for cloransulam

- methyl would result in a more sensitive avian r eproductive endpoint for certain parameters, we re commend re questing a second avian reproduction study with the bobwhite quail for cloransulam

- methyl at this time.

Acute and Chronic Freshwater Invertebrate and Fish Studies

A n a cut e freshwater invertebrate study (OCSPP Guideline 850.1010), a chronic freshwater invertebrate life cycle study (OCSPP Guideline 850.1300), and a chronic freshwater fish early life stage study (OCSPP Guidelin e 850.1400) are all required for registration of pesticides with outdoor uses (CFR Part 158). To meet the freshwater fish early life stage study requirement, data must be submitted on one of the two species tested for the acute freshwater fish toxicity st udies. If the test species is different than the two species used for the freshwater fish acute toxicity tests, a 96

- hour LC 50 

### on that species must also be provided. Currently, only one of the three aforementioned studies has been submitted, i.e ., an acu te freshwater invertebrate study (MRID 430034

- 12), however, this study was classified invalid. As such, we recommend requesting toxicity data on acute effects to freshwater invertebrates, and chronic effects to freshwater invertebrates and fish. In the a bsence of these data, EFED will assume risk to these taxa from use of cloransulam

- methyl.

Chronic toxicity studies for cloransulam

- methyl with estuarine/marine fish or invertebrates are not available at this time. In the absence of this data, an assumpti on of chronic risk to these taxa will be made using an acute

- to

- chronic ratio (ACR). A chronic effects endpoint for either estuarine/marine fish or invertebrates will be derived by applying a ratio of acute and chronic freshwater endpoints (from the same species) to an acute estuarine/marine endpoint. Risk to estuarine/marine fish and invertebrates will be based on the newly derived endpoint.

Terrestrial Plant Studies

Terrestrial plant toxicity studies are required for registration of pesticides with outdoor uses (CFR Part 158). For known phytotoxicants, Tier II vegetative vigor (OSCPP 850.4100) and Tier II seedling emergence (OCSPP 850.4150) studies are required on a TEP to investigate the effects of the pesticide end

- use product on t he growth and survival of terrestrial plants. A seedling emergence study, MRID 437154

- 04, and vegetative vigor study, MRID 437154

- 04, were review ed . Because the seedling emergence study was conducted on the TGAI and not the TEP,

### - 39 of 85

-

the study will not fully meet registration requirements for a phytotoxicant. Likewise, the available vegetative vigor study was conducted on the TGAI and not a TEP; additionally, this study had notable Guideline deviations ( e.g. study duration not reported) and thus does not appe ar to fully meet Guideline standards nor meet registration requirements. Because the toxicity of cloransulam

- methyl to terrestrial plants may be enhanced when formulated as a product with additional ingredients, such as surfactants, and due to the number of reported incidents on terrestrial plants, we recommend requesting both a second Tier II seedling emergence and Tier II vegetative vigor toxicity study conducted on a TEP containing the single active ingredient cloransulam

- methyl ( i.e. , Riverdale® and Fi rstrate® formulations). In the absence of these data, the extent of risks to plants could potentially be underestimated.

Statement of Possible Future Data Call In (DCI) for Plant Reproductive Study on Acetohydroxyacid Synthetase (AHAS) Inhibitors (historically referred to as Acetolactate Synthase (ALS) Inhibitors )
There is evidence that some Sulfonylurea herbicides (SUs) have been associated with effects on reproduction in plants under field conditions (See chlorsulfuron RED (D330621)). It is unc ertain at this time whether the Agency‟s standard vascular plant toxicity testing provides endpoints that are adequately protective of possible reproduction effects to plants resulting from applications of SUs. The uncertainty lies in whether reproductive effects occur at rates lower than the vegetative vigor endpoint. To address this uncertainty, plant reproduction testing is now being requested by EPA‟s Environmental Fate and Effects Division (EFED) in the Office of Pesticide Programs (OPP) for all SUs.

It is possible that reproduction effects to plants associated with SUs are mediated by the presently understood mechanism of action for this class of herbicide which is inhibition of Acetohydroxyacid Synthetase ( AHAS). The inhibition of AHAS disrupt s the synthesis of branched chain amino acids (valine, leucine, and isoleucine) that are important for a variety of plant cellular functions. Historically, this class of herbicides has been referred to as Acetolactate Synthase (ALS) inhibitors (specificall y referring to inhibition of the formation of acetolactate in the synthesis of valine and leucine), but this ignores the role of AHAS in isoleucine synthesis and is therefore referred to herein as AHAS inhibitors. If AHAS mediation for reproduction effects is factual for the SUs, then other chemical classes which also exert herbicidal effects through AHAS inhibition may potentially exhibit effects on plant reproduction. At this point the Agency believes that there is insufficient data to determine if, in the case of SUs, reproduction effects from available data are reproducible in the proposed testing scheme and whether any observed effects would be adequately represented by the more routinely tested effects endpoints for plants. The Agency expects that the currently required testing for SUs will be important in making that determination. Until then, the Agency is looking for public input regarding scientific evidence for the conservation of reproduction concerns across the other AHAS inhibiting herbicides.

As SU testing results become available, the Agency will compare the results with other standard effects endpoints and review any public input on evidence associating AHAS inhibition with reproduction effects for other chemical classes of herbicides. This will inform the Agency in

### - 40 of 85

-

making decisions regarding the need for any expansion of plant reproduction testing with a larger set of AHAS inhibiting herbicide chemicals

. Vascular Aquatic Plant and Alga Studies

Aquatic plant toxicity studies and associated risk analysis of plants are required for registration of pesticides with outdoor uses (40 CFR Part 158). For known phytotoxicants, a Tier II aquatic vascular plant to xicity study (OCSPP Guideline 850.4400) and four Tier II non

- vascular plant toxicity studies (OCSPP Guideline 850.5400) on either the TGAI or TEP are required. The available vascular aquatic plant study with the TEP using L. gibba , MRID 436689

- 16, was
rev iew ed and does not fully meet OCSPP Guideline standards due to a number of noted deficiencies and uncertainties ( i.e., test substance instability, solvent control contamination, and solvent control effect uncertainty). In contrast, the available freshwate r green alga toxicity study (MRID 447445

- 17) is classified "acceptable"; however, three more nonvascular plant studies are required, i.e ., freshwater diatom, saltwater diatom, and a nitrifying cyanobacteria. Because cloransulam

- methyl is a known phytotoxi cant, EFED recommends requesting another toxicity study on an aquatic vascular plant and three additional toxicity studies on nonvascular aquatic plants. EFED will assume risk to aquatic plants (vascular and nonvascular) in the absence of these data.

### - 41 of 85

-

8. References ChemBlink. 2010. Online database for chemicals from around the world (cloransulam

- methyl structure) Accessed on July 20, 2010. Online at: http://www.chemblink.com/structures/147150

- 35

- 4.gif.

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA food

- chain (Kenaga) nomogram, an instrument for estimating pesticide residues on plants. Environ. Tox. Chem. 13 :1383

- 1391.

Herbicide Resistance Action Committee (HRAC). 2009. Classification of Herbicide s According to Mode of Action. Accessed on August 20, 2010. Online at http://www.hracglobal.com/Publications/ClassificationofHerbicideModeofAction/tabid/2 22/Default.aspx

. Hoerger, F. and E. E. Kenaga. 1972. Pesticide Residues on Plants: Correlation of Representative Data as a Basis for Estimation of their Magnitude in the Environment. In F. Coulston and F. Korte, eds., Environmental Quality and Safety: Chemistry, Toxicology, and Technology, Georg Thieme Publ., Stuttgart, West Ger many, pp. 9

- 28.

University of Minnesota Extension (UM Extension). 2009. Herbicide and Nonherbicide Injury Symptoms on Spring Wheat and Barley: Amino Acid Synthesis Inhibitors. Accessed August 8, 2010. Online at: http://www.extension.umn.edu/distribution/cropsystems/components/6967_01g.html

USDA. 1997. Usual Planting and Harvesting Dates for U.S. Field Crops. National Agricultural Statistics Service. United States Department of Agriculture. Accessed August 9, 2010. Online at: http://usda.mannlib.cornell.edu/usda/nass/planting/uph97.pdf

U SEPA. 1997. Cloransulam

- methyl Risk Assessment. DP Barcode: D223558; D223605. U.S. Environmental Protection Agency, Office of Pesticide Programs. August 8, 1997.

USEPA. 1998. Guidelines for Ecological Risk Assessment. Risk Assessment Forum, Office of R esearch and Development, Washington, D.C. EPA/630/R

- 95/002F. April 1998. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=30759

USEPA. 2004. Overview of the Ecological Risk A ssessment Process in the Office of Pesticide Programs. U.S. Environmental Protection Agency, Office of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, Washington DC. January 23, 2004.

USEPA. 2007a. Ecological Incident Inform ation System. http://www.epa.gov/espp/consultation/ecorisk

- overview.pdf

USEPA. 2007 b . ECOTOXicology Database. Office of Research and Development National Health and Environmental E ffects Research Laboratory‟s (NHEERL‟s) Mid

- Continent Ecology Division (MED). http://cfpub.epa.gov/ecotox/

.

### - 42 of 85

-

USEPA. 2010. Cloransulam

- methyl (129116): Screening Level Usage Analysis. U.S. Environmental Protection Agency, Office of Prevention, Pesticides and Toxic Substances, Biological and Economic Analysis Division. Jan 21, 2010.

U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS). 1998. Endangered Species Consultatio n Handbook: Procedures for Conducting Consultation and Conference Activities Under Section 7 of the Endangered Species Act. Final Draft. March 1998.

USFWS/NMFS/NOAA.2004. 50 CFR Part 402. Joint Counterpart Endangered Species Act Section 7 Consultatio n Regulations; Final Rule. Federal Register Volume 69. Number 20.Pages 47731

- 47762. August 5, 2004.

U.S. Geological Survey (USGS). 2010. Pesticide Use Maps. U.S. Geological Survey, National Water

- Quality Assessment (NAWQA) Program, Pesticide National Synthesis Program. Accessed on July 20, 2010. Online at: http://water.usgs.gov/nawqa/pnsp/usage/maps/compound_listing.php?year=02

### - 43 of 85

-

SUBMITTED ENVIRONMENTAL FATE STUDIES: MRID: Citation:
43003432 Zabik, S. (1993) Hydrolysis of XDE

- 565 in Three Water Systems: Buffered at pH 5, 7, and 9, Natural

Water and Soil Slurry: Lab Project Number: ENV91086. Unpublished study prepared by DowElanco. 82 p.
43715402 Cook, W.; Saunders, D. (1995) Aqueous Photolysis of XDE

- 565: Lab Project Number: ENV92002.

Unpublished study prepared by DowElanco. 171 p.

44265301 Cook, W.; Powers, F. (1996) Photodegradation of Cloransulam

- methyl in Aqueous Buffer: (Final

Report): Lab Project Number: ENV96085. Unpublished study prepared by DowElanco. 83 p.

43760001 Merritt, D.; Cook, W. (1995) Photodegradation of DE

- 565 (Cloransulam

- Methyl) on Soil: Lab Project

Number: ENV92003: GH

- C 3668. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 89 p.

43003433 Wolt, J.; Smith, J.; Sims, G. (1993) Aerobic Metabolism of (carbon 14)

- (Phenyl)

- and (Pyrimidine)

-

XDE

- 565 in Two Soils: Lab Project Number: ENV91095. Unpublished study prepared by DowElanco. 91 p.

43 216601 Smith, J.; Wolt, J.; Sims, G. (1993) A Kinetic Study of XDE

- 565 Sorption and Degradation on Sixteen

Soils: MRID 43003434: Lab Project Number: ENV91095.01: GH

- C 3095. Unpublished study prepared by DowElanco. 53 p.

44809201 Batzer, F.; Yoder, R. (19 99) Aerobic Soil Metabolism of Cloransulam

- methyl on Soils from La Porte,

IN and Janesville, IA: Lab Project Number: 980072. Unpublished study prepared by Dow AgroSciences LLC. 63 p.

43715403 Erhardt

- Zabik, S.; Havens, P.; Hawes, K. (1995) The Anerobic Aquatic Metabolism of XDE

- 565: Lab

Project Number: ENV91110. Unpublished study prepared by DowElanco. 87 p.

44265302 Hawes, K.; Ulmer, J. (1997) The Aerobic Aquatic Metabolism of DE

- 565: (Final Report): Lab Project

Number: ENV96033. Unpublished study prepared by DowElanco. 70 p.

43003434 Smith, J.; Wolt, J.; Sims, G. (1993) A Kinetic Study of XDE

- 565 Sorption and Degradation on Sixteen

Soils: Lab Project Number: ENV91095.01. Unpublished study prepared by DowElanco. 51 p.

43003435 Cleveland, C.; Ostrander, J.; Miller, J. (1993) Laboratory Mobility Assessments of XDE

- 565 and

Metabolites: Lab Project Number: ENV92042: ENV93086. Unpublished study prepared by DowElanco. 108 p.

43216602 Cleveland , C.; Ostrander, J.; Miller, J. (1993) Laboratory Mobility Assessments of XDE

- 565 and

Metabolites: MRID 43003435: Lab Project Number: ENV92042: ENV93086: GH

- C 3125. Unpublished study prepared by DowElanco. 102 p.

43760002 Zabik, J.; Miller, J.; Ostrander , J.; et al. (1995) Amended Report for Terrestrial Field Dissipation of

Cloransulam

- Methyl: Lab Project Number: ENV93031: GH

- C 3621R. Unpublished study prepared by DowElanco North American Environmental Chemistry Lab. 224 p.

44231501 van Wesenbeeck, I.; Bormett, G.; Roberts, D. (1996) Terrestrial Field Dissipation of Cloransulam

methyl: (Final Report): Lab Project Number: ENV95017: GRM95.10. Unpublished study prepared by DowElanco; A&L Great Lakes Labs; and MVTL Labs. 240 p.

44231502 Duebelbeis, D.; Thomas, A. (1996) Method Validation Report for the Determination of Residues of

Cloransulam

- methyl and Cloransulam in Soil by Capillary Gas Chromatography with Mass Selective Detection: (Final Report): Lab Project Number: RES95068: GRM 95.10. Unpublished study prepared by DowElanco. 53 p.

46161601 Carver, L.; van Wesenbeeck, I.; Dolder, S. (2003) Prospective Ground

- Water Monitoring Study for

Cloransulam

- methyl: Final Report. Project Number: ENV98032, 369/02, 369/03. Unpublished study

### - 44 of 85

- prepared by Analytical Bio

- Chemistry Labs, Inc., Crop Management Strategies, Inc., and Agsearch. 2285 p.

43668933 Cleveland, C. (1995) Environmental Fate Summary for Cloransulam

- Methyl (DE

- 565): Lab Project

Number: GH

- C 3629. Unpublished study prepared by DowElanco. 40 p.



### SUBMITTED EFFECTS STUDIES: MRID: Citation:
43003407 Campbell, S.; Lynn, S. (1991) XDE

- 565 Herbicide: An Acute Or al Toxicity Study with the Northern

Bobwhite: Lab Project Number: ES

- DR

- 0314

- 2107

- 3: 103

- 362. Unpublished study prepared by Wildlife International Ltd. 21 p.

43003408 Grimes, J.; Lynn, S.; Smith, G. (1991) XDE

- 565 Herbicide: A Dietary LC50 Study with the Mallard:

Lab Project Number: ES

- DR

- 0314

- 2107

- 2: 103

- 361A. Unpublished study prepared by Wildlife International Ltd. 21 p.

43003409 Grimes, J.; Lynn, S.; Smith, G. (19 91) XDE

- 565 Herbicide: A Dietary LC50 Study with the Northern

Bobwhite: Lab Project Number: ES

- DR

- 0314

- 2107

- 1: 103

- 360A. Unpublished study prepared by Wildlife International Ltd. 21 p.

43668905 Beavers, J.; Foster, J.; Ross, T.; et al. (1995) XDE

- 565 Her bicide: A Reproduction Study with the

Northern Bobwhite (Colinus virginianus): Lab Project Number: 103

- 374: DECO

- ES

- 2514. Unpublished study prepared by Wildlife International Ltd. 156 p.

43699301 Beavers, J.; Foster, J.; Ross, T.; et al. (1995) XDE

- 565 H erbicide: A Reproduction Study with the

Mallard (Anas platyrhynchos): Lab Project Number: 103

- 375: DECO

- ES

- 2513. Unpublished study prepared by Wildlife International Ltd. 153 p.

43003410 Gorzinski, S.; Rick, D.; Richardson, C. (1991) XDE

- 565 Herbicide: A cute Toxicity to the Rainbow

Trout, Oncorhynchus mykiss Walbaum: Lab Project Number: ES

- DR

- 0314

- 2107

- 6. Unpublished study prepared by Dow Chemical Co. 29 p.

43003411 Gorzinski, S.; Rick, D.; Richardson, C. (1991) XDE

- 565 Herbicide: Acute Toxicity to the Bluegill,

Lepomis macrochirus Rafinesque: Lab Project Number: ES

- DR

- 0314

- 2107

- 5. Unpublished study prepared by Dow Chemical Co. 29 p.

43003412 Milazzo, D.; Servinski, M. (1991) XDE

- 565 Herbicide: Acute Toxicity to the Daphnid, Daphnia magna

Straus: Lab Project Number: ES

- DR

- 0314

- 2107

- 8. Unpublished study prepared by Dow Chemical Co. 27 p.

43718901 Ward, T.; Maguzu, J.; Boeri, R. (1992) Acute Toxicity of XDE

- 565 Herbi cide to the Silverside, Menidia

beryllina: Lab Project Number: 54

- DO: ES

- 2495. Unpublished study prepared by T.R. Wilbury Labs, Inc. 23 p.

43718902 Ward, T.; Magazu, J.; Boeri, R. (1993) Acute Flow

- Through Mollusc Shell Deposition Test with XDE

565 Herbi cide: Lab Project Number: 53

- DO: ES

- 2496. Unpublished study prepared by T.R. Wilbury Labs, Inc. 23 p.

43718903 Ward, T.; Magazu, J.; Boeri, R. (1992) Acute Toxicity of XDE

- 565 Herbicide to the Grass Shrimp,

Palaemonetes pugio: Lab Project Number: 52

- DO: ES

- 2494. Unpublished study prepared by T.R. Wilbury Labs, Inc. 23 p.

43003413 Cosse, P.; Berdasco, N. (1992) XDE

- 565: Acute Oral Toxicity Study in Fischer 344 Rats: Lab Project

Number: DR

- 0314

- 2107

- 011A. Unpublished study prepared by Dow Chemical Co. 28 p.
43003419 Gilbert, K.; McGuirk, R. (1993) NAF

- 75: Acute Oral Toxicity Study in Fischer 344 Rats: Lab Project

### - 45 of 85

- Number: DR

- 0339

- 1206

- 001A. Unpublished study prepared by Dow Chemical Co. 29 p.

45388202 Freeman, C.; Scubelek, S. (2001) Gauntlet 70 DF Acute Oral Toxicity Study in Rats: Lab Project

Number: A2000

- 5316. Unpublished study prepared by FMC Corporation. 22 p. {OPPTS 870.1100}

44744516 Porch, J.; Krueger, H.; McCormick, R. (1999) Effect of Three Metabolites of Cloransulam

- methyl on the

Emergence and Vegetative Vigor of Non

- Target Terrestrial Plants (Tier I/II): Lab Project Number: 379

- 101: ENV98050. Unpublished study prepared by Wildlife International Ltd. 281 p. {850.4100, 850.4225}

43715404 S chwab, D. (1995) Evaluating the Effects of XDE

- 565 on the Seedling Emergence and Vegetative Vigor

of Non

- Target Terrestrial Plants: Lab Project Numbers: 41706: RES94064. Unpublished study prepared by DowElanco. 148 p.

44744516 Porch, J.; Krueger, H.; McC ormick, R. (1999) Effect of Three Metabolites of Cloransulam

- methyl on the

Emergence and Vegetative Vigor of Non

- Target Terrestrial Plants (Tier I/II): Lab Project Number: 379

- 101: ENV98050. Unpublished study prepared by Wildlife International Ltd. 281 p. {850.4100, 850.4225}

43668916 Milazzo, D.; Servinski, M.; Weinberg, J.; et al. (1994) XDE

- 565 Herbicide: The Toxicity to the Aquatic

Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: DECO

- ES

- 2582. Unpublished study prepared by The Dow Chemical Co. 33 p.

43668917 Milazzo, D.; Massaro, L.; Kirk, H.; et al. (1995) XDE

- 565 Acid: the Toxicity to the Green Alga,

Selenastrum capricornutum Printz: Lab Project Number: DECO

- ES

- 2906. Unpublished study prepared by The Dow Chemical Co. 31 p.

43760003 Massaro, L.; Milazzo, D. (1995) 5

- Hydroxy

- DE

- 565: Evaluation of the Toxicity to the Green Alga,

Selenastrum capricornutum Printz: Lab Project Number: DECO

- ES

- 2971. Unpublished study prepared by The Dow Chemical Co. 11 p.

43760004 Massaro, L.; Milazzo, D. (1995) 5

- Hydroxy

- DE

- 565 Acid: Evaluation of the Toxicity to the Gr een Alga,

Selenastrum capricornutum Printz: Lab Project Number: DECO

- ES

- 2972. Unpublished study prepared by The Dow Chemical Co. 10 p.

44744501 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565

Exposed Bluegre en Alga, Anabaena flos

- aquae: Lab Project Number: 981109. Unpublished study prepared by The Dow Chemical Company. 36 p.

44744502 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565

Exposed Freshwater Diatom, Nav icula pelliculosa: Lab Project Number: 981104. Unpublished study prepared by The Dow Chemical Company. 35 p.

44744503 Kirk, H.; Gilles, M.; Hugo, J. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565 Exposed

Saltwater Diatom, Skeletonema costatum: Lab Project Number: 981105. Unpublished study prepared by The Dow Chemical Company. 33 p.

44744504 Kirk, H.; Gilles, M.; Rick, D. et al. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565

Exposed Freshwater Green Alga, Selenastrum capricornutum Pri ntz: Lab Project Number: 981110. Unpublished study prepared by The Dow Chemical Company. 36 p.

44744505 Kirk, H.; Gilles, M.; Rick, D. et al. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565

Exposed Aquatic Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: 981106. Unpublished study prepared by The Dow Chemical Company. 38 p.

44744506 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565 Acid

Exposed Bluegreen Alga, Anabaena flos

- aquae: Lab Project Number: 981078. Unpublished study prepared by The Dow Chemical Company. 36 p.

44744507 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxic ological Evaluation of 5

- Hydroxy

- DE

- 565 Acid

### - 46 of 85

- Exposed Freshwater Diatom, Navicula pelliculosa: Lab Project Number: 981075. Unpublished study prepared by The Dow Chemical Company. 35 p.

44744508 Kirk, H.; Gilles, M.; Hugo, J. (1998) Phytotoxicological Eval uation of 5

- Hydroxy

- DE

- 565 Acid

Exposed Saltwater Diatom, Skeletonema costatum: Lab Project Number: 981077. Unpublished study prepared by The Dow Chemical Company. 33 p.

44744509 Kirk, H.; Gilles, M.; Rick, D. et al. (1998) Phytotoxicological Evaluation of 5

- Hydroxy

- DE

- 565 Acid

Exposed Freshwater Green Alga, Selenastrum capricornutum Printz: Lab Project Number: 981076. Unpublished study prepared by The Dow Chemical Company. 37 p.

44744510 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological E valuation of 5

- Hydroxy

- DE

- 565 Acid

Exposed Aquatic Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: 981074. Unpublished study prepared by The Dow Chemical Company. 38 p.

44744511 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological Eva luation of DE

- 565 Acid Exposed Blue

Green Alga, Anabaena flos

- aquae: Lab Project Number: 981031. Unpublished study prepared by The Dow Chemical Company. 36 p.

44744512 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological Evaluation of DE

- 565 Acid Exposed

Freshwater Diatom, Navicula pelliculosa: Lab Project Number: 981028. Unpublished study prepared by The Dow Chemical Company. 35 p.

44744513 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxi cological Evaluation of DE

- 565 Acid Exposed

Saltwater Diatom, Skeletonema costatum: Lab Project Number: 981029. Unpublished study prepared by The Dow Chemical Company. 33 p.

44744514 Milazzo, D.; Massaro, L.; Kirk, H. (1995) XDE

- 565 Acid: The Toxicity to the Green Alga, Selenastrum

capricornutum Printz: Lab Project Number: DECO

- ES

- 2906. Unpublished study prepared by The Dow Chemical Company. 31 p.

44744515 Kirk, H.; Gilles, M.; Hugo, J. et al. (1998) Phytotoxicological Evaluation of DE

- 565 Acid Exposed

Aquatic Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: 981030. Unpublished study prepared by The Dow Chemical Company. 38 p.

44744517 Kirk, H.; Hugo, J.; McFadden, L. (1997) Phytotoxicological Evaluation of XDE

- 565 (NAF

- 75

Formulation) with a F reshwater Green Algae, Selenastrum capricornutum: Lab Project Number: 971123. Unpublished study prepared by The Dow Chemical Company. 44 p.

43003431 Lynn, S.; Hoxter, K. (1991) XDE

- 565 Herbicide: An Acute Contact Toxicity Study with the Honey Bee:

Lab Pr oject Number: ES

- DR

- 0314

- 2107

- 4: 103

- 363A. Unpublished study prepared by Wildlife International, Ltd. 18 p.

### - 47 of 85

-

APPENDIX A: Registered Uses and Application Rates for Cloransulam

- methyl.

USE PRODUCT MAX SINGLE APPL. RATE (lbs a.i./A) MAX APPL.

RATE PER CROP CYCLE (CC) OR YEAR Soybeans Riverdale 565 Selective

Herbicide 0.039 0.055 lbs ai/A/yr

Gauntlet (First Rate) 0.039 0.039 lbs ai/A/cc Authority First DF Herbicide 0.040 0.055 lbs ai/A/cc

Gauntlet 70 WP Herbicide 0.040 0.040 lbs ai/A/cc Gangster Herbicide 0.032 0.032 lbs ai/A/cc FirstRate Herbicide 0.039 0.055 lbs ai/A/yr Frontrow Herbicide 0.018 0.055 lbs ai/A/cc



### Table 1 : Riverdale 565 Selective Herbicide

Table 2 : Gauntlet (FirstRate)

Table 3 : Authority First DF Herbicide

### - 48 of 85

-

Table 4 : Gauntlet 70 WP Herbicide

### - 49 of 85

-

Table 5 : Gangster Herbicide

### - 50 of 85

-

### - 51 of 85

-

Table 6 : FirstRate Herbicide

Table 7 : Frontrow Herbicide

### - 52 of 85

-

APPENDIX B. Major Environmental Degradates of Cloransulam

- methyl.

Table B.1. Chemical Names, Structures, and Maximum Reported Amounts of Cloransulam

- methyl’s Major Degradates. Code Name/ Synonym Chemical Name A 

### Chemical Structure Study Type MRID Maximum %AR (day) Final %AR

(study length)
PARENT



### Cloransulam

- methyl IUPAC: methyl 3

- chloro

- N

- (5

- ethoxy

- 7

-

fluoro[1,2,4]triazolo[1,5

- c]pyrimidin

- 2

- ylsulfonyl)anthranilate

CAS: methyl 3

- chloro

- 2

- [[(5

- ethoxy

- 7

- fluoro[1,2,4]triazolo[1,5

- c]pyrimidin

- 2

- yl)sulfonyl]amino]benzoate

CAS

- no: 147150

- 35

- 4 Formula: C 15 H 13 ClFN 5 O 5 S MW: MAJOR (>10%) DEGRADATES



### Cloransulam Formula: C 14 H 11 ClFN 5 O 5 S

MW: NA Aerobic Soil Metab 43003433 37 (28) 10 (357)

Anaerobic Aquatic Metab 43715403 36 (28) ND (365)



### 5

- OH

cloransulam NA
Aerobic Soil Metab 43003433 16 (28) 2 (357)

Anaerobic Aquatic Metab 43715403 22 (273) 1.8 (365)

### - 53 of 85

-

Code Name/ Synonym Chemical Name A 

### Chemical Structure Study Type MRID Maximum %AR (day) Final %AR

(study length)

5

- OH

cloransulam

methyl NA

Aerobic Soil Metab 43003433 17 (14) 1 (357)

Hydrolysis 43003432 5.8 (termination of study, day 30) 5.8 (30)



### Cloransulam

- methyl fluorethenyl Name: N

- (2

- carbo~p~yZ

- 6

- chloro)

- [I

nzethyl

- 5

- (2

- $uo~oethe~2~.y4~

-- i~ triazolo

- 3

- sulfonamide
Anaerobic Aquatic Metab 47315403 66 (365) 66 (termination of study)



### Sulfonic acid (TSPA) NA

Soil Photolysis 43760001 22 (termination of study) 22



### Sulfinic acid NA NA Aqueous Phot o lysis 43715402 23 (termination of study) 23



### Cloransulam

- methyl imidate Chemical Name: N

- ( 2

- carbomethoxy

- 6

-

chlorophenyl )

- 2

- N

- ethyl imido

- 3

- (1,2,4)

- triazoloacetic acid

- 5

- sulfonamide Hydrolysis 43003432 29 (3) 20 (7)

### - 54 of 85

-

Code Name/ Synonym Chemical Name A 

### Chemical Structure Study Type MRID Maximum %AR (day) Final %AR

(study length)

Cloransulam

- methyl acetic acid Chemical Name: N

- (2

- carbomethoxy

- 6

-

chl orophenyl )

- 3

- (1,2, 4)

- triazoloacetic acid

- 5

- sulfonamide Hydrolysis 43003432 54 (study termination, day 7) 54 (7)



### CO 2 -- O=C=O Aerobic Soil Metab 43003433 10 10
A. IUPAC and CAS chemical names were sourced from the Compendium of Pesticide Common Names (Copyright © 1995

– 2009 Alan Wood). Online at: http://www.alanwood.net/pesticides/

### - 55 of 85

-

APPENDIX C: ECOTOX Open Literature Studies for Cloransulam

- methyl

Acceptable for EcoTox and OPP

Nelson, K. A. (2000). Soybean [Glycine max (L.) Merr] Growth and Development, White Mold [Sclerotinia sclerotiorum (Lib.) de Bary] Incidence, and Yellow Nutsedge (Cyperus esculentus L.) Control as Affected by Glyphosate and Other Herbicides. Ph.D Thesis, Michigan State Univ.,MI 279 p. (UMI# 9971967).

EcoReference No.: 120063 Chemical of Concern: GFS,HSF,IZP,NHSO4,CRM,IZX,CLNS,GYP,THF,LCF,SFZ,RIM,SXD,PTB; Habitat : T; Code : LITE EVAL CODED(CLNS),NO MIXTURE(NHSO4,THF,SXP),OK(CRM,IZP,PTB,GFS,GYP).

Acceptable for EcoTox but not OPP

Lewer, P., Finney

- Bri nk, K. L., and Duebelbeis, D. O. (2000). Nature of the Residue of [14C]Cloransulam

- Methyl in Lactating Goats. J.Agric.Food Chem. 48: 2532

- 2546.

EcoReference No.: 120081 Chemical of Concern: CLNSM; Habitat : T; Effect Codes : ACC; Code : NO ENDPOINT(CLN SM).

Smith, D. A. and Hallett, S. G. (2006). Interactions Between Chemical Herbicides and the Candidate Bioherbicide Microsphaeropsis amaranthi. Weed Sci. 54: 532

- 537 .

EcoReference No.: 119975 Chemical of Concern: ACF,MBZ,GFS,PAQT,PMSM,CFE,ATZ,GIB,CLNS, GYP,BMN,LCF,IZT; Habitat : T; Effect Codes : POP; Code : NO CONC(ATZ,CLNS,CFE,LCF,PAQT,GFS,MBZ),TARGET(GYP).

Excluded

1997). Cloransulam

- methyl; pesticide tolerances. Fed. Regist. 62: 49158

- 49163. Chem Codes : Chemical of Concern: CLNSM Code : FOOD.

Pesticide Fact Sheet: Cloransulam

- Methyl. Govt Reports Announcements & Index (GRA&I), Issue 06, 1998

. Chem Codes : Chemical of Concern: CLNS Code : REVIEW.

Abu

- Farha, M., Niles, J., and Willmore, W. G. (2005). Erythroid

- Specific 5

- Aminolevulinate Syntha se Protein Is Stabilized by Low Oxygen and Proteasomal Inhibition. Biochem Cell Biol Biochemistry and cell biology = Biochimie et biologie cellulaire 83: 620

- 30. Chem Codes : Chemical of Concern: CLNS Code : HUMAN HEALTH,IN VITRO.

Akiyama, Yumi, Matsuo ka, Tomofumi, and Mitsuhashi, Takao (2009). Multi

- residue screening method of acidic pesticides in agricultural products by liquid chromatography/time of flight mass spectrometry. J. Pestic. Sci. (Tokyo, Jpn.) 34: 265

- 272. Chem Codes : Chemical of Concern : CLNS Code : CHEM METHODS.

Alikhanidi, Sokratis and Takahashi, Yoshimasa (2004). Pesticide persistence in the environment

- collected data and structure

- based analysis. J. Comput. Chem., Jpn. 3: 59

- 70. Chem Codes : Chemical of Concern: CLNS Code : FATE.

Anon (2002). 2

- (2,2

- difluoroethoxy)

- 6

- trifluoromethyl

- N

- (5,8

- dimethoxy[1,2,4]t riazolo [1,5

- c]pyrimidin

- 2

- yl)benzenesulfonamide and its use as a herbicide in mixtures. Res. Discl. 462: P1832

- P1833. Chem Codes : Chemical of Concern: CLNSM,PXS Code : MIXTURE.

### - 56 of 85

-

Anon (2002). N

- (5,7

- dimethoxy[1,2,4]triazolo[1,5

- a]pyrimidin

- 2

- yl)arylsulfonamide compounds and their use as herbicides in mixtures. Res. Discl. 459: 1230

- 1231. Chem Codes : Chemical of Concern: CLNS Code : REVIEW.

Bergman, A. M., Munch

- Peterse n, B., Jensen, P. B., Sehested, M., Veerman, G., Voorn, D. A. , Smid, K., Pinedo, H. M., and Peters, G. J. ( 2001). Collateral Sensitivity to Gemcitabine (2',2'

- Difluorodeoxycytidine) and Cytosine Arabinoside of Daunorubicin

- and Vm

- 26

- Resistant Variants o f Human Small Cell Lung Cancer Cell Lines. Biochem Pharmacol Biochemical pharmacology 61: 1401

- 8. Chem Codes : Chemical of Concern: CLNS Code : HUMAN HEALTH.

Camaioni, D. M., Samuels, W. D., Linehan, J. C., Sharma, A. K., and Hogan, M. O. ( Organic T anks Safety Program, Fy97 Waste Aging Studies. Revision 1. Govt Reports Announcements & Index (GRA&I), Issue 08, 1999

. Chem Codes : Chemical of Concern: CLNS Code : FATE.

Cupples, Alison M., Sims, Gerald K., Hultgren, Ryan P., and Hart, Steven E (2000). Effect of soil conditions on the degradation of cloransulam

- methyl. J. Environ. Qual. 29: 786

- 794 . Chem Codes : Chemical of Concern: CLNS Code : BACTERIA,FATE.

Del Carmen Vila M, Aldonatti, C., and San Martin De Viale Lc ( Evaluation of the Porphyrinoge nic Ability of Lindane in Rats. ACTA PHYSIOL PHARMACOL LATINOAM; 36 (1). 1986. 69

- 76. Chem Codes : Chemical of Concern: CLNS,HCCH Code : NON

- ENGLISH .

Fortin, J., Flury, M., Jury, W. A., and Streck, T. ( Rate

- Limited Sorption of Simazine in Saturated Soil Columns. JOURNAL OF CONTAMINANT HYDROLOGY; 25 (3

- 4). 1997. 219

- 234. Chem Codes : Chemical of Concern: CLNS,SZ Code : FATE.

Herman, Rod A. and Scherer, Peter N (2006). Fit of four curve

- linear models to decay profiles for pest control substances in s oil. J. Agric. Food Chem. 54: 4343

- 4349. Chem Codes : Chemical of Concern: CLNS Code : FATE.

Hernandez

- Borges, Javier, Garcia

- Montelongo, Francisco J., Cifuentes, Alejandro, and Rodriguez

- Delgado, Miguel Angel (2005). Analysis of triazolopyrimidine herbi cides in soils using field

- enhanced sample injection

coelectroosmotic capillary electrophoresis combined with solid

- phase extraction. J. Chromatogr., A 1100: 236

- 242. Chem Codes : Chemical of Concern: CLNSM Code : CHEM METHODS.

Hernandez

- Borges, Javier, Garcia

- Montelongo, Francisco J., Cifuentes, Alejandro, and Rodriguez

- Delgado, Miguel Angel (2005). Determination of herbicides in mineral and stagnant waters at ng/L levels using capillary electrophoresis and UV detection combined with solid

- phase extracti on and sample stacking. J. Chromatogr., A 1070: 171

- 177. Chem Codes : Chemical of Concern: CLNSM Code : CHEM METHODS.

Hernandez

- Borges, Javier, Rodriguez

- Delgado, Miguel Angel, Garcia

- Montelongo, Francisco J., and Cifuentes, Alejandro (2005). Analysis of pesticides in soy milk combining solid

- phase extraction and capillary electrophoresis

- mass spectrometry. J. Sep. Sci. 28: 948

- 956. Chem Codes : Chemical of Concern: CLNS Code : CHEM METHODS.

Ibsen, T. G. ( Lims Strategy Review. Govt Reports Announceme nts & Index (GRA&I), Issue 20, 1995

. Chem Codes : Chemical of Concern: CLNS Code : CHEM METHODS/REVIEW.

Igoryanova, N. A., Shukhnov, A. F., Spirichev, V. B., Ivanov, A. A., Fadina, I. V., Guseva, L. I., Meandrova, S. B., and Shatnyuk, L. N. ( Enrichment of High and First

- Rate Wheat's Flour With Vitamins and Mineral Substances. VOPROSY PITANIYA; 0 (5). 1994. 5

- 8. Chem Codes : Chemical of Concern: CLNS Code : NON

- ENGLISH,HUMAN HEALTH.

### - 57 of 85

-

Johnson, Timothy C (2006 ). The Discovery of Florasulam and Penoxsula m Herbicides. CRM

- 089. Chem Codes : Chemical of Concern: CLNS Code : ABSTRACT.

Johnson, Timothy C., Martin, Timothy P., Mann, Richard K., and Pobanz, Mark A (2009). Penoxsulam

- structure

activity relationships of triazolopyrimidine sulfonamides. Bioorg . Med. Chem. 17: 4230

- 4240. Chem Codes : Chemical of Concern: CLNSM Code : REVIEW.

Kochelaev, V. A., Gaĭ, Sin, N. K., and Sviridiuk, A. I. ( [Providing Safe Work Conditions in Jsc &Quot;Uralasbest&Quot;]. Med Tr Prom Ekol. 2008(3):37

- 42. [Meditsina t ruda i promyshlennaia ekologiia]: Med Tr Prom Ekol

. Chem Codes : Chemical of Concern: CLNS Code : NON

- ENGLISH,HUMAN HEALTH.

Krieger, M. S., Wynn, J. L., and Yoder, R. N (2000). Extraction of cloransulam

- methyl from soil with subcritical water and supercri tical CO2. J. Chromatogr., A 897: 405

- 413. Chem Codes : Chemical of Concern: CLNSM Code : CHEM METHODS.

Krieger, Mark, Yoder, Robin, Stafford, Les, Batzer, Fred, Smith, Joelene, Cook, Wendi, and Lewer, Paul (2000). Environmental fate and metabolism of t he sulfonamide herbicides diclosulam and cloransulam

- methyl . AGRO

- 090. Chem Codes : Chemical of Concern: CLNSM Code : FATE.

Kusell, M., Lake, L., Andersson, M., and Gerschenson, L. E. (1978). Cellular and Molecular Toxicology of Lead. Ii. Effect of Lead on Delta

- Aminolevulinic Acid Synthetase of Cultured Cells. J Toxicol Environ Health 4: :515

- 25. Chem Codes : Chemical of Concern: CLNS,PbN Code : IN VITRO.

Lehotay, S. J. ( Supercritical Fluid Extraction of Pesticides in Foods. JOURNAL OF CHROMATOGRAPH Y A; 785 (1

- 2). 1997. 289

- 312. Chem Codes : Chemical of Concern: CLNS Code : CHEM METHODS.

Liao, Quan, Yao, Jianhua, and Yuan, Shengang (2007). Prediction of mutagenic toxicity by combination of Recursive Partitioning and Support Vector Machines. Mol. Di versity 11: 59

- 72. Chem Codes : Chemical of Concern: CLNS Code : MODELING,REVIEW.

Löwkvist, B., Oredsson, S. M., Holm, I., Emanuelsson, H., and Heby, O. (1987). Inhibition of Polyamine Synthesis Reduces the Growth Rate and Delays the Expression of Differentiated Phenotypes in Primary Cultures of Embryonic Mesoderm From Chick. Cell Tissue Res 249: :151

- 60. Chem Codes : Chemical of Concern: CLNS Code : IN VITRO.

Paulson, B. K., Porter, T. J., and Kent, C. (1989). The Effect of Polycyclic Aromatic Hy drocarbons on Choline Kinase Activity in Mouse Hepatoma Cells. Biochim Biophys Acta 1004: :274

- 7. Chem Codes : Chemical of Concern: CLNS,PAH Code : IN VITRO.

Premi, P. R. and Cornfield, A. H. (1969). Effects of Addition of Copper, Manganese, Zinc and Chr omium Compounds on Ammonification and Nitrification During Incubation of Soil. Plant Soil 31: 345

- 352. Chem Codes : Chemical of Concern: CaSO4,CrS,CuS,ZnS,MnSO4 Code : NO SPECIES.

Rodriguez

- Delgado, Miguel Angel and Hernandez

- Borges, Javier (2007). Rapid analysis of triazolopyrimidine sulfoanilide herbicides in waters and soils by high

- performance liquid chromatography with UV detection using a C18 monolithic column. J. Sep. Sci. 30: 8

- 14. Chem Codes : Chemical of Concern: CLNSM Code : CHEM METHODS.

Rot h, Gary A (1995). Synthesis of Cysteine and Homoglutathione Conjugates of Crop Protection Agents Containing Electrophilic Centers. J. Org. Chem. 60: 8105

- 9. Chem Codes : Chemical of Concern: CLNS Code : CHEM METHODS.

### - 58 of 85

-

Sampedro, M. A., Blanco, A., Llama, M . J., and Serra, J. L. (1995). Sorption of Heavy Metals to Phormidium Laminosum Biomass. Biotechnol.Appl.Biochem. 22: 355

- 366. Chem Codes : Chemical of Concern: CuS,ZnS,FeS,CrS,NiS,CdCl,PbN Code : NO SPECIES.

Scrano, L., Bufo, S. A., Cataldi, T. R., and Albanis, T. A. (2004). Surface Retention and Photochemical Reactivity of the Diphenylether Herbicide Oxyfluorfen

. J Environ Qual Journal of environmental quality 33: 605

- 11. Chem Codes : Chemical of Concern: CLNS,OXF Code : FATE.

Shackelford, Darcy D., Duebelbeis, Dennis O., and Snell, Brian E (1996). Determination of Residues of Cloransulam

- methyl in Soybeans and Soybean Forage, Hay, and Processed Commodities by Capillary Gas Chromatography with Mass Spectrometric Detection. J. A gric. Food Chem. 44: 3570

- 3575. Chem Codes : Chemical of Concern: CLNSM Code : CHEM METHODS.

Shareef, A., Egerer, S., and Kookana, R. (2009). Effect of Triclosan and Triclocarban Biocides on Biodegradation of Estrogens in Soils. Chemosphere 77: :1381

- 6. Chem Codes : Chemical of Concern: CLNS Code : BACTERIA,FATE.

Shi, S., Hudson, F. N., Botta, D., Mcgrath, M. B., White, C. C., Neff

- Laford, H. D., Dabrowski, M. J., Singh, N. P., and Kavanagh, T. J. (2007). Over Expression of Glutamate Cysteine Ligase Incr eases Cellular Resistance to H2o2

- Induced Dna Single

- Strand Breaks. Cytometry A 71: 686

- 92. Chem Codes : Chemical of Concern: CLNS,HOX Code : IN VITRO.

Shier, W. T. (1979). Activation of High Levels of Endogenous Phospholipase A2 in Cultured Cells. Proc Natl Acad Sci U S A 76: :195

- 9. Chem Codes : Chemical of Concern: CLNS Code : IN VITRO.

Sims, G. K (2006). Nitrogen starvation promotes biodegradation of N

- heterocyclic compounds in soil. Soil Biol. Biochem. 38: 2478

- 2480. Chem Codes : Chemical of Conce rn: CLNSM,ATZ Code : BACTERIA,FATE.

Sims, Gerald K. and Cupples, Alison M (1999). Factors controlling degradation of pesticides in soil. Pestic. Sci. 55: 598

- 601. Chem Codes : Chemical of Concern: CLNSM,ATZ Code : FATE.

Stoner, G. D. (1991). Lung Tumors in Strain a Mice as a Bioassay for Carcinogenicity of Environmental Chemicals. Exp.Lung Res. 17: 405

- 423. Chem Codes : Chemical of Concern: BAP,PAH,DMBA,NSA,CH3I,CF,4CE,MnSO4,CrS,CIN,MEN,MAT,MSC,SAC,VNL,DNT Code : REFS CHECKED/REVIEW.

Tarasov, V. A., Ab ilev, S. K., Velibekov, R. M., and Aslanyan, M. M. (2003). Efficiency of Batteries of Tests for Estimating Potential Mutagenicity of Chemicals. Russ.J.Genet.(Translation of Genetika (Moscow Russian Federation)) 39: 1191

- 1200. Chem Codes : Chemical of Conc ern: ACD,PAH,BZD,DDT,Captan,NaNO3,PCP,THM,CHR,Ziram,ETHN,ETO,ACY,BMY,DMT,Cd,CdCl,TPE ,MP,MOR,As,PRN,PCB,SAC,FML,CrS,CrCl3 Code : REFS CHECKED/REVIEW.

van Wesenbeeck, I. J. and Havens, P. L. (1999). A Groundwater Exposure Assessment for Cloransulam

- Methyl in the U.s. Soybean Market. Journal of Environmental Quality [J. Environ. Qual.]. Vol. 28, no. 2, pp. 513

- 522. Mar

- Apr 1999. 28: 513

- 522. Chem Codes : Chemical of Concern: CLNSM Code : FATE,MODELING,REVIEW.

van Wesenbeeck, I. J., Zabik, J. M., Wolt, J. D . , Bormett, G. A., and Roberts, D. W (1997). Field dissipation of cloransulam

- methyl at two sites in the US soybean market. AGRO

- 075.

### - 59 of 85

- Chem Codes : Chemical of Concern: CLNSM Code : FATE.

van Wesenbeeck, Ian, Carver, Les, Cartron, Juliet, Brandt, Jodi, and Snyder, Nathan (2000). Comparison of tracer and herbicide leaching using pipe lysimeters and porous cup lysimeters. AGRO

- 131. Chem Codes : Chemical of Concern: CLNS Code : FATE.

Van Wesenbeeck, Ian J. and Havens, Patrick L (1999). Water quality: a groundwater exposure assessment for cloransulam

- methyl in the U.S. soybean market. J. Environ. Qual. 28: 513

- 522. Chem Codes : Chemical of Concern: CLNS Code : MODELING,REVIEW.

van Wesenbeeck, Ian J., Zabik, John M., Wolt, Jeffrey D., Bormett, Gary A., and Roberts, David W (1997). Field dissipation of cloransulam

- methyl at four sites in the U.S. soybean market. J. Agric. Food Chem. 45: 3299

- 3307. Chem Codes : Chemical of Concern: CLNSM Code : FATE.

Wallace, A., Romney, E. M., and Patel, P. M. (1978). Role of Synthetic Chelating Agents in Trace Metal Uptake by Plants. In: D.C.Adriano and I.L.Brisbin,Jr.(Eds.), Environmental Chemistry and Cycling Processes, Proc.Symp.Held at Augusta, Georgia, April 18

- May 1, 1976, Tech.Info.Center, U.S.Dep of Energy (U. S.NTIS CONF

- 760429) 645

- 657. Chem Codes : Chemical of Concern: Pb,CrS,CdS,Ni,Co Code : REFS CHECKED/REVIEW.

Whiteside, Melanie, Mineau, Pierre, Morrison, Clare, and Knopper, Loren D (2008). Comparison of a score

- based approach with risk

- based ranking of i n

- use agricultural pesticides in Canada to aquatic receptors. Integr. Environ. Assess. Manage. 4: 215

- 236. Chem Codes : Chemical of Concern: CLNS Code : REVIEW.

Wolt, Jeffrey D., Smith, Joelene K., Sims, Jerry K., and Duebelbeis, Dennis O (1996). Product s and kinetics of cloransulam

- methyl aerobic soil metabolism. J. Agric. Food Chem. 44: 324

- 32. Chem Codes : Chemical of Concern: CLNSM Code : FATE.

Yeh, C. K. and Novak, J. T. ( Anaerobic Biodegradation of Gasoline Oxygenates in Soils. WATER ENVIRONMENT RESEARCH; 66 (5). 1994. 744

- 752. Chem Codes : Chemical of Concern: CLNS Code : BACTERIA,FATE.

Zabik, J. M., Ostrander, J. A., Roberts, D. W., and Thompson, G. D (1996). Assessing the dissipation of 14C cloransulam

- methyl under field conditions. AGRO

- 015

. Chem Codes : Chemical of Concern: CLNSM Code : FATE.

Zabik, J. M. Ostrander J. A., Roberts, D. W., and Thompson, G. D. ( Assessing the Dissipation of 14c Cloransulam

Methyl Under Field Conditions . 211TH AMERICAN CHEMICAL SOCIETY NATIONAL MEETING, NEW ORLEANS, LOUISIANA, USA, MARCH 24

- 28, 1996. ABSTRACTS OF PAPERS AMERICAN CHEMICAL SOCIETY; 211 (1

- 2). 1996. AGRO 15. Chem Codes : Chemical of Concern: CLNS Code : FATE.

Zhang, N. and Casida, J. E. (2002). Novel Irreversible Butyrylcholinesterase Inhibito rs: 2

- Chloro

- 1

- (Substituted

Phenyl)Ethylphosphonic Acids. Bioorg Med Chem Bioorganic & medicinal chemistry 10: 1281

- 90. Chem Codes : Chemical of Concern: CLNS,EPH Code : CHEM METHODS,IN VITRO.

Target: Toxicity of Chemical on Intended Pest

Al

- Khatib, Kassim, Peterson, Dallas E., and Regehr, David L (2000). Control of imazethapyr

- resistant common sunflower (Helianthus annuus) in soybean (Glycine max) and corn (Zea mays). Weed Technol. 14: 133

- 139.

Chemical of Concern: CLNS,IZT,CRM,GYP,ATZ; Habitat : T; Code : TARGET(CLNS).

### - 60 of 85

-

Allen, Jayla R., Johnson, William G., Smeda, Reid J., Wiebold, William J., and Massey, Raymond E (2001). Management of acetolactate synthase (ALS)

- resistant common sunflower (Helianthus annuus L.) in soybean (Glycine max)

. Weed Technol. 15: 571

- 575.

Chemical of Concern: CLNS,IZT,CRM,IZQ,IZX; Habitat : T; Code : TARGET(CLNS).

Armel Gregory R., Richardson Robert J., Wilson Henry P., Trader Brian W., Whaley Cory M., Hines Thomas E., Armel Gregory R., Richardson Robert J., Trader Brian W., Whaley Cory M., Wilson Henry P., Hines Thomas E., Armel Gregory R., Richardson Robert J., Tr ader Brian W., and Whaley Cory M. (2009). Evaluation of Acetolactate Synthase

- Inhibiting Herbicides for Weed Control in Transplanted Bell Pepper. HortTechnology, vol. 19, no. 2, pp. 400

- 404, 2009

. Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CL NS).

Ashigh, Jamshid and Tardif, Francois J (2006). ALS

- inhibitor resistance in populations of eastern black nightshade (Solanum ptycanthum) from Ontario. Weed Technol. 20: 308

- 314.

Chemical of Concern: CLNS,IZT,ATZ; Habitat : T; Code : TARGET(CLNS).

As kew, S. D., Wilcut, J. W., and Langston, V. B. (1999). Weed Management in Soybean (Glycine max) with Preplant

- Incorporated Herbicides and Cloransulam

- Methyl. Weed Technol. 13: 276

- 282.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Barnes, J. W. (2003). Factors Influencing Weed Control Potential of Cloransulam in Soybean (Glycine max). Ph.D.Thesis, Univ.of Arkansas,AK 226 p. (Order No.AADAA

- I3097299).

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(FSF,CLNS).

Barnes, J. W. and Oliv er, L. R. (2004). Cloransulam Absorption, Translocation, and Efficacy on Common Broadleaf Weed Species . Weed Sci. 52: 634

- 641.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Barnes, J. W. and Oliver, L. R. (2004). Preemergence Weed Contro l in Soybean with Cloransulam. Weed Technol. 18: 1077

- 1090.

Chemical of Concern: FSF,CLNS; Habitat : T; Code : TARGET(FSF,CLNS).

Barnes, Jeff W. and Oliver, Lawrence R (2004). Cloransulam antagonizes annual grass control with aryloxyphenoxypropionate gr aminicides but not cyclohexanediones. Weed Technol. 18: 763

- 772.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Baumgartner, Jolene R., Al

- Khatib, Kassim, and Currie, Randall S (1999). Cross

- resistance of imazethapyr

resistant common sunf

lower (Helianthus annuus) to selected imidazolinone, sulfonylurea, and triazolopyrimidine herbicides. Weed Technol. 13: 489

- 493.

Chemical of Concern: CLNS,CR,IZX,THF; Habitat : T; Code : TARGET(CLNS).

Brewer, C. (2007). Arkansas glyphosate

- resistant com mon ragweed (Ambrosia artemisiifolia).

Chemical of Concern: CLNS,GYP,PAQT,24D,DMB,GFS; Habitat : T; Code : TARGET(CLNS).

Christoffers, Michael J., Nandula, Vijay K., Howatt, Kirk A., and Wehking, Todd R (2006). Target

- site resistance to

### - 61 of 85

- acetolactate syn thase inhibitors in wild mustard (Sinapis arvensis). Weed Sci. 54: 191

- 197.

Chemical of Concern: CLNS,IZT,THF,IZX; Habitat : T; Code : TARGET(CLNS).

Corrigan, Karen A. and Harvey, R. Gordon (2000). Glyphosate with and without residual herbicides in no

- t ill glyphosate

- resistant soybean (Glycine max). Weed Technol. 14: 569

- 577.

Chemical of Concern: CLNS,GYP,IZT; Habitat : T; Code : TARGET(CLNS).

Davis, Vince M., Gibson, Kevin D., Bauman, Thomas T., Weller, Stephen C., and Johnson, William G (2009). Infl uence of weed management practices and crop rotation on glyphosate

- resistant horseweed (Conyza canadensis) population dynamics and crop yield

- years III and IV. Weed Sci. 57: 417

- 426.

Chemical of Concern: CLNS,RIM,ATZ,GYP,FZF,GFS; Habitat : T; Code : TARGET(CLNS).

Davis, Vince M., Kruger, Greg R., Stachler, Jeff M., Loux, Mark M., and Johnson, William G (2009). Growth and seed production of horseweed (Conyza canadensis) populations resistant to glyphosate, ALS

- inhibiting, and multiple (glyphosate + ALS

- inhibiting) herbicides. Weed Sci. 57: 494

- 504.

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

Dirks, Jeremy F., Johnson, William G., Smeda, Reid J., Wiebold, William J., and Massey, Raymond E (2000). Use of preplant sulfentrazone in no

- till, narrow

- row, glyphosate

- resistant Glycine max. Weed Sci. 48: 628

- 639.

Chemical of Concern: CLNS,SFZ; Habi tat : T; Code : TARGET(CLNS).

Felix, Joel, Doohan, Douglas J., Ditmarsen, Scott C., Schultz, Marvin E., Wright, Terry R., Flood, Brian R., and Rabaey, Thomas L (2002). Sensitivity of sweet corn (Zea mays L.) and potatoes (Solanum tuberosum L.) to cloransul am

- methyl soil residues. Crop Prot. 21: 763

- 772 .

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Fennimore, Steven A., Lanini, W. Thomas, McGiffen, Milton E., and Bell, Carl E (2000). Evaluation of low

- rate herbicides for potential use in vegetable crops. Proc. West. Soc. Weed Sci. 53: 53

- 57.

Chemical of Concern: CLNS,IZX; Habitat : T; Code : TARGET(CLNS).

Franey, R. J. and Hart, S. E. (1999). Time of Application of Cloransulam for Giant Ragweed (Ambrosia trifida) Control in Soybean (Gl ycine max). Weed Technol. 13: 825

- 828.

Chemical of Concern: LCF,CLNS; Habitat : T; Code : TARGET (LCF,CLNS).

Franzen, D. W., O'Barr, J. H., and Zollinger, R. K (2004). Influence of certain postemergence broadleaf herbicides on soybean stressed from iron deficiency chlorosis. Agron. J. 96: 1357

- 1363.

Chemical of Concern: CLNS,IZT,THF,IZM,BT,GYP; Habitat : T; Code : TARGET(CLNS).

Gerwick, B. Clifford, Cseke, Csaba T., Deboer, Gerry, Kleschick, William A., and Schmitzer, Paul R (1996). Translation of in vitro activity to in vivo activity: lessons from the triazolopyrimidine sulfonanilides. Weed Sci. 44: 757

- 762.

Chemical of Concern: CLNSM; Habitat : T; Code : TARGET(CLNS).

Gonzini, Lisa C., Hart, Stephen E., and Wax, Loyd M (1999). Herbicide combinatio ns for weed management in glyphosate

- resistant soybean (Glycine max). Weed Technol. 13: 354

- 360.

### - 62 of 85

- Chemical of Concern: CLNSM,GYP,IZT; Habitat : T; Code : TARGET(CLNS).

Green, Jerry M., Hale, Theresa, Pagano, Margaret A., Andreassi, John L. II, and Gutter idge, Steven A (2009). Response of 98140 corn with gat4621 and hra transgenes to glyphosate and ALS

- inhibiting herbicides. Weed Sci. 57: 142

- 148.

Chemical of Concern: CLNSM,GYP,CRM,SMU; Habitat : T; Code : TARGET(CLNS).

Grey, Timothy L., MacRae, Andrew, and Culpepper, A. Stanley (2008). Transplanted onion response to previously applied residual herbicides. Weed Technol. 22: 477

- 480.

Chemical of Concern: CLNS,DU; Habitat : T; Code : TARGET(CLNS).

Grichar, W. James (2007). Control of smellmelon (Cucumis melo) in soybean with herbicides. Weed Technol. 21: 777

- 779.

Chemical of Concern: CLNS,PDM,GYP,CRM; Habitat : T; Code : TARGET(CLNS).

Griffin, Roy Matthew (2003). Weed control in early

- maturing Mi ssissippi soybean at various row spacings and planting dates.

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

Hanson, B. D., Park, K. W., Mallory

- Smith, C. A. , and Thill, D. C (2004). Resistance of Camelina microcarpa to acetolactate s ynthase inhibiting herbicides. Weed Res. 44: 187

- 194.

Chemical of Concern: CLNS,IZX,MTS,CSF; Habitat : T; Code : TARGET(CLNS).

James Grichar, W., Dotray, Peter A., and Ray Langham, D (2009). Sesame (Sesamum indicum L.) response to preemergence herbicides. Crop Prot. 28: 928

- 933.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Johnson, Bryan F., Bailey, William A., Wilson, Henry P., Holshouser, David L., Herbert, D. Ames Jr., and Hines, Thomas E (2002). Herbicide effects on visible injury, leaf area, and yield of glyphosate

- resistant soybean (Glycine max). Weed Technol. 16: 554

- 566.

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

Krausz, Ronald F., Kapusta, George, and Matthews, Joseph L (1998). Sulfentrazone for weed control in soybean (Glycine max). Weed Technol. 12: 684

- 689.

Chemical of Concern: CLNS,SFZ; Habitat : T; Code : TARGET(CLNS).

Kra usz, Ronald F. and Young, Bryan G (2001). Response of double

- crop glyphosate

- resistant soybean (Glycine max) to broadleaf herbicides. Weed Technol. 15: 300

- 305.

Chemical of Concern: CLNS,IZT,IZX,LCF; Habitat : T; Code : TARGET(CLNS).

Kruger, Greg R., Da vis, Vince M., Weller, Stephen C., Stachler, J. M., Loux, M. M., and Johnson, William G (2009). Frequency, distribution, and characterization of horseweed (Conyza canadensis) biotypes with resistance to glyphosate and ALS

- inhibiting herbicides. Weed Sci. 57: 652

- 659.

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

### - 63 of 85

-

Lamego, F. P., Vidal, R. A., Burgos, N. R., and Federizzi, L. C (2009). Cross

- resistance of Bidens subalternans to acetolactate synthase inhibitors in Brazil. Weed Res. 49: 63 4

- 641.

Chemical of Concern: CLNSM,CRME,IZT; Habitat : T; Code : TARGET(CLNS).

Lamego, Fabiane P., Charlson, Dirk, Delatorre, Carla A., Burgos, Nilda R., and Vidal, Ribas A (2009). Molecular basis of resistance to ALS

- inhibitor herbicides in greater begga rticks. Weed Sci. 57: 474

- 481.

Chemical of Concern: CLNS,IZT,CRM; Habitat : T; Code : TARGET(CLNS).

Legleiter, Travis R. and Bradley, Kevin W (2008). Glyphosate and multiple herbicide resistance in common waterhemp (Amaranthus rudis) populations from Mi ssouri. Weed Sci. 56: 582

- 587.

Chemical of Concern: CLNS,GYP,THF; Habitat : T; Code : TARGET(CLNS).

Manning, Grant R. and Fennimore, Steven A (2001). Evaluation of low

- rate herbicides to supplement methyl bromide alternative fumigants to control weeds i n strawberry. HortTechnology 11: 603

- 609.

Chemical of Concern: CLNS,MB,NPP; Habitat : T; Code : TARGET(CLNS).

McKelvey, Robert A., Wright, John P., and Honegger, Joy L (2002). A comparison of crop and non

- crop plants as sensitive indicator species for r egulatory testing. Pest Manage. Sci. 58: 1161

- 1174.

Chemical of Concern: CLNSM,CZE,TFN; Habitat : T; Code : TARGET(CLNS).

Millar, Katherine, Gibson, David J., Young, Bryan G., and Wood, Andrew J (2007). Impact of interspecific competition on seed development and quality of five soybean cultivars. Aust. J. Exp. Agric. 47: 1455

- 1459.

Chemical of Concern: CLNS,MTC; Habitat : T; Code : TARGET(CLNS).

Nelson, K. A. and Renner, K. A. (1998). Postemergence Weed Control with CGA

- 277476 and Cloransulam

- Methyl in Soybean (Glycine max). Weed Technol. 12: 293

- 299 .

EcoReference No.: 64012 Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Nelson, Kelly A. and Renner, Karen A (2002). Yellow nutsedge (Cyperus esculentus) control and tuber production with glyphosate and ALS

- inhibiting herbicides. Weed Technol. 16: 512

- 519.

Chemical of Concern: CLNS,GYP,IZT,RIM,IZX; Habitat : T; Code : TARGET(CLNS).

Nelson, Kelly Allan (1997). Postmergence weed control in soybean (Glycine max (L.) Merr) with imazamok, imazethapyr, oxasulfuron, and cloransulam

- methyl.

Chemical of Concern: CLNSM,IZT; Habitat : T; Code : TARGET(CLNS).

Norris , Justin L., Shaw, David R., and Snipes, Charles E (2001). Weed control from herbicide combinations with three formulations of glyphosate. Weed Technol. 15: 552

- 558.

Chemical of Concern: CLNS,GYP,FSF,LCF,CRM; Habitat : T; Code : TARGET(CLNS).

Olszyk, Da vid, Pfleeger, Thomas, Lee, E. Henry, and Plocher, Milton (2010). Potato (Solanum tuberosum) greenhouse tuber production as an assay for asexual reproduction effects from herbicides. Environ. Toxicol. Chem. 29: 111

- 121.

### - 64 of 85

- Chemical of Concern: CLNS,DMB,GYP, IZP,SMU; Habitat : T; Code : TARGET(CLNS).

Patzoldt, W. L. and Tranel, P. J. (2007). Multiple ALS Mutations Confer Herbicide Resistance in Waterhemp (Amaranthus tuberculatus). Weed Sci. 55: 421

- 428.

EcoReference No.: 119504 Chemical of Concern: IZT,THF, CLNS,PTB; Habitat : T; Effect Codes : GRO,BCM; Code : OK(IZT,PTB),TARGET(THF,CLNS).

Patzoldt, W. L., Tranel, P. J., Alexander, A. L., and Schmitzer, P. R. (2001). A Common Ragweed Population Resistant to Cloransulam

- Methyl. Weed Sci. 49: 485

- 490.

EcoRe ference No.: 67160 Chemical of Concern: CLNSM; Habitat : T; Code : TARGET(CLNSM).

Patzoldt, William L. and Tranel, Patrick J (2002). Molecular analysis of cloransulam resistance in a population of giant ragweed. Weed Sci. 50: 299

- 305.

Chemical of Conce rn: CLNS,IZT,CRM; Habitat : T; Code : TARGET(CLNS).

Patzoldt, William L. and Tranel, Patrick J (2007). Multiple ALS mutations confer herbicide resistance in waterhemp (Amaranthus tuberculatus). Weed Sci. 55: 421

- 428.

Chemical of Concern: CLNS,IZT,THF,CR M,PTB; Habitat : T; Code : TARGET(CLNS).

Payne, Scott A. and Oliver, Lawrence R (2000). Weed control programs in drilled glyphosate

- resistant soybean. Weed Technol. 14: 413

- 422.

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

Pfleeger, Thomas, Olszyk, David, Plocher, Milton , and Yilma, Solomon (2008). Effects of low concentrations of herbicides on full

- season, field

- grown potatoes. J. Environ. Qual. 37: 2070

- 2082.

Chemical of Concern: CLNSM,IZP,SMM,GYP; Habitat : T; Code : TARGET(CL NS).

Pline, W. A., Wilcut, J. W., and Edmisten, K. L. (2002). Postemergence Weed Control in Soybean (Glycine max) with Cloransulam

- Methyl and Diphenyl Ether Tank

- Mixtures. Weed Technol. 16: 737

- 742.

Chemical of Concern: FSF,CLNSM; Habitat : T; Code : TA RGET(FSF,CLNSM).

Poston, D. H., Wu, J., Hatzios, K. K., and Wilson, H. P. (2001). Enhanced Sensitivity to Cloransulam

- Methyl in Imidazolinone

- Resistant Smooth Pigweed. Weed Sci. 49: 711

- 716.

EcoReference No.: 63726 Chemical of Concern: CLNSM; Habitat : T; Code : TARGET(CLNSM).

Poston, Daniel H., Nandula, Vijay K., Griffin, R. Matt, and Koger, Clifford H (2007). Texasweed (Caperonia palustris) control in soybean with postemergence herbicides. Weed Technol. 21: 670

- 673.

Chemical of Concern: CLNS,FSF,GYP ; Habitat : T; Code : TARGET(CLNS).

Poston, Daniel H., Wilson, Henry P., and Hines, Thomas E (2000). Imidazolinone resistance in several Amaranthus hybridus populations. Weed Sci. 48: 508

- 513.

Chemical of Concern: CLNSM,CRM,THF; Habitat : T; Code : TARGET(CLNS).

### - 65 of 85

-

Reddy, K. N. (2000). Weed Control in Soybean (Glycine max) with Cloransulam and Diclosulam. Weed Technol. 14: 293

- 297.

EcoReference No.: 59626 Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Rundle, Mark F., Walters, S. Alan , and Young, Bryan G (2007). Efficacy of postemergence corn and soybean herbicides on volunteer horseradish (Armoracia rusticana). Weed Technol. 21: 501

- 505.

Chemical of Concern: CLNS,CRM,IZX,24D,IZT; Habitat : T; Code : TARGET(CLNS).

Shaw, D. R., Benne tt, A. C., and Grant, D. L. (1999). Weed Control in Soybean (Glycine max) with Flumetsulam, Cloransulam, and Diclosulam. Weed Technol. 13: 791

- 798 .

EcoReference No.: 64298 Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Shaw, David R. and Arnold, James C (2002). Weed control from herbicide combinations with glyphosate. Weed Technol. 16: 1

- 6.

Chemical of Concern: CLNSM,GYP; Habitat : T; Code : TARGET(CLNS).

Sikkema, Peter H., Brown, Lynette, Shropshire, Christy, Spieser, Helmut, and Solt ani, Nader (2008). Flat fan and air induction nozzles affect soybean herbicide efficacy. Weed Biol. Manage. 8: 31

- 38.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Sikkema, Peter H., Soltani, Nader, Shropshire, Christy, and Cowan, Todd (2 004). Tolerance of white beans to postemergence broadleaf herbicides. Weed Technol. 18: 893

- 901.

Chemical of Concern: CLNSM,THF,CRM,BMN; Habitat : T; Code : TARGET(CLNS).

Soltani, Nader, Shropshire, Christy, Cowan, Todd , and Sikkema, Peter (2004). Whit e bean sensitivity to preemergence herbicides. Weed Technol. 18: 675

- 679.

Chemical of Concern: CLNSM; Habitat : T; Code : TARGET(CLNS).

Soltani, Nader and Sikkema, Peter H (2005). White bean (Phaseolus vulgaris) tolerance to preplant

- incorporated herbic ides. Weed Biol. Manage. 5: 35

- 38.

Chemical of Concern: CLNSM; Habitat : T; Code : TARGET(CLNS).

Stachler, J. (2008). Characterization and management of glyphosate

- resistant giant ragweed (Ambrosia trifida L.) and horseweed [Conyza canadensis (L.) cron q.].

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

Taylor, Jeffrey B., Loux, Mark M., Harrison, S. Kent, and Regnier, Emilie (2002). Response of ALS

- resistant common ragweed (Ambrosia artemisiifolia) and giant ragweed (Ambrosia trifid a) to ALS

- inhibiting and alternative herbicides. Weed Technol. 16: 815

- 825.

Chemical of Concern: CLNSM,GYP,LCF,FSF; Habitat : T; Code : TARGET(CLNS).

Trainer, Geoffrey D., Loux, Mark M., Harrison, S. Kent, and Regnier, Emilie (2005). Response of horsewe ed biotypes to foliar applications of cloransulam

- methyl and glyphosate. Weed Technol. 19: 231

- 236.

### - 66 of 85

- Chemical of Concern: CLNSM,GYP; Habitat : T; Code : TARGET(CLNS).

Trezzi, Michelangelo M., Felippi, C. L., Mattei, D., Silva, H. L., Nunes, A. L., Debast iani, C., Vidal, R. A., and Marques, A (2005). Multiple resistance of acetolactate synthase and protoporphyrinogen oxidase inhibitors in Euphorbia heterophylla biotypes. J. Environ. Sci. Health, Part B B40: 101

- 109.

Chemical of Concern: CLNS,FSF,IZT; Habitat : T; Code : TARGET(CLNS).

Ulloa Cortazar, S. (2007 ). Response of Asiatic dayflower (Commelina communis L.) to glyphosate and alternatives in soybean.

Chemical of Concern: CLNSM,GYP,LCT,MBZ; Habitat : T; Code : TARGET(CLNS).

Ulloa, Santiago M. a nd Owen, Micheal D. K (2009). Response of Asiatic dayflower (Commelina communis) to glyphosate and alternatives in soybean. Weed Sci. 57: 74

- 80.

Chemical of Concern: CLNS,GYP; Habitat : T; Code : TARGET(CLNS).

Vangessel, Mark J (1999). Control of perenn ial weed species as seedlings with soil

- applied herbicides. Weed Technol. 13: 425

- 428.

Chemical of Concern: CLNS,MBZ,CMZ; Habitat : T; Code : TARGET(CLNS).

Vangessel, Mark J., Monks, David W., and Johnson, Quintin R (2000). Herbicides for potential use in lima bean (Phaseolus lunatus) production. Weed Technol. 14: 279

- 286.

Chemical of Concern: CLNS,LCF; Habitat : T; Code : TARGET(CLNS).

Vyn, J. D., Swanton , C. J., Weaver, S. E., and Sikkema, P. H (2007). Control of herbicide

- resistant common waterhemp (Amaranthus tuberculatus var. rudis) with pre

- and post

- emergence herbicides in soybean. Can. J. Plant Sci. 87: 175

- 182.

Chemical of Concern: CLNS,MTL,LNR,F SF,GYP,ACF; Habitat : T; Code : TARGET(CLNS).

Westhoven, Andrew M., Stachler, Jeff M., Loux, Mark M., and Johnson, William G (2008). Management of glyphosate

- tolerant common lambsquarters (Chenopodium album) in glyphosate

- resistant soybean. Weed Technol. 22: 628

- 634.

Chemical of Concern: CLNSM,GYP; Habitat : T; Code : TARGET(CLNS).

Whaley, Cory M., Wilson, Henry P., and Westwood, James H (2006). ALS resistance in several smooth pigweed (Amaranthus hybridus) biotypes. Weed Sci. 54: 828

- 832.

Chemical of Concern: CLNS,IZT,CRM,THF,PTB; Habitat : T; Code : TARGET(CLNS).

Whaley, Cory M., Wilson, Henry P., and Westwood, James H (2007). A new mutation in plant ALS confers resistance to five classes of ALS

- inhibiting herbicides. Weed Sci. 55: 83

- 90.

Chemical of Concern: CLNS,CRM,IZT,THF; Habitat : T; Code : TARGET(CLNS).

Wheeler, Melissa Ann Monique (2005). Impact of mutations in acetolactate synthase on resistance of redroot pigweed (Amaranthus retroflexus L.) and green pigweed (Amaranthus powellii S. Wats) to flucarbazone and pyrithiobac.

### - 67 of 85

- Chemical of Concern: CLNS,PTB,FCB,IZX,CRM,FMS,FTS; Habitat : T; Code : TARGET(CLNS).

Yenish, Joseph P. and Eaton, Nichole A (2002). Weed control in dry pea (Pisum sativum) under conventional and

no

- tillage systems. Wee d Technol. 16: 88

- 95.

Chemical of Concern: CLNS,IZT,FTS,SFZ,BT,FSF,IZX; Habitat : T; Code : TARGET(CLNS).

York, Alan C., Stewart, Alexander M., Vidrine, P. Roy, and Culpepper, A. Stanley (2004). Control of volunteer glyphosate

- resistant cotton in glypho sate

- resistant soybean. Weed Technol. 18: 532

- 539.

Chemical of Concern: CLNS,FTS,IMQ,MBZ,CRM,SFZ,GYP; Habitat : T; Code : TARGET(CLNS).

Zelaya, Ian A. and Owen, Micheal D. K (2004). Evolved resistance to acetolactate synthase

- inhibiting herbicides in

co mmon sunflower (Helianthus annuus), giant ragweed (Ambrosia trifida), and shattercane (Sorghum bicolor) in Iowa. Weed Sci. 52: 538

- 548.

Chemical of Concern: CLNS,IZT,CRM,NSF; Habitat : T; Code : TARGET(CLNS).

Zheng, D. (2007). Resistance to ALS

- inhibiting herbicides in common ragweed, foxtail and horseweed.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

Zheng, D., Patzoldt, W. L., and Tranel, P. J. (2005). Association of the W574L ALS Substitut ion with Resistance to Cloransulam and Imazamox in Common Ragweed (Ambrosia artemisiifolia). Weed Sci. 53: 424

- 430.

Chemical of Concern: CLNS; Habitat : T; Code : TARGET(CLNS).

### - 68 of 85

-

APPENDIX D

. Submitted Ecological Effects Toxicity Data for Cloransulam

- m ethyl

TABLE 1. Ecological Effects Data for Terrestrial and Aquatic Animals

SPECIES ENDPOINT CHEMICAL/ FORMULATI ON MRID STUDY CLASS

IFICATION COMMENTS

BIRDS Birds (Acute) Bobwhite quail (Colinus virginianus) 14

- day LD 50 >

2250 mg a.i./kg

- bw Cloransulam

methyl (97.3%) 43003407 Acceptable

Birds (Acute/Sub

- Acute) Mallard Duck (Anas platyrhynchos) 8

- day LC 50 >

5620 mg a.i./kg

- diet Cloransulam

methyl (97.3%) 43003408 Acceptable

Bobwhite quail (Colinus virginianus) 8

- day LC 50 >

5620 mg a.i./kg

- diet Cloransulam

methyl (97.3%) 43003409 Acceptable

Birds (Chronic)

Mallard Duck ( Anas platyrhynchos ) NOAEC:127

mg a.i./kg diet LOAEC: 485 mg a.i./kg diet Cloransulam

methyl (97.3%) 43 6993

- 0 1 Acceptable Endpoints based on decrease in eggshell thickness and live embryos per viable embryos.

Bobwhite quail ( Colinus virginianus ) NOAEC: <654

mg a.i./kg diet LOAEC: 654 mg a.i./kg diet Cloransulam

methyl (97.3%) 43 6689

- 0 5 Supplemental Endpoints based on decreases in eggs set/pen, viable embryos/pen, No. Hatchlings/pen, Hatchling survival/pen MAMMALS Mammals (Acute) Laboratory Rat (Rattus norvegicus) LD 50 > 5000

mg a.i./kg

- bw Cloransulam

methyl 43003413 Minimum Satisfies guideline requirements Laboratory Rat

– Fischer 344 LD 50 > 5000

mg a.i./kg

- bw (M& F) Firstrate

(84.8%) 43003419 Minimum Satisfies guideline requirements

Sprague

Dawley Rat Male LD 50 =

2504 mg a.i./kg

- bw Female LD 50 = 3803 a.i./kg

- bw Gauntlet 70 DF

(8.1%) 45388202 Acceptable Need to confirm study with RD

Mammals (Chronic)

### - 69 of 85

-

SPECIES ENDPOINT CHEMICAL/ FORMULATI ON MRID STUDY CLASS

IFICATION COMMENTS

Sprague

Dawley Rat NOAEL = 10

mg/kg

- bw LOEAL = 100 mg/kg

- bw Based on parental systemic toxicity Cloransulam

methyl 43668911 Acceptable

TERRESTRIAL INVERTEBRATES Honey Bee (Apis melifera) LD 50 > 25 μg

a.i./bee Cloransulam

methyl (97.3%) 43003431 Acceptable
FRESHWATER FISH Freshwater Fish (Acute) Bluegill Sunfish (Lepomis macrochirus) 96

- hr LC 50 >

154 mg a.i./L Cloransulam

methyl (97.3%) 43003411 Acceptable

Rainbow Trout (Oncorhynchus mykiss) 96

- hr LC 50 > 86

mg a.i./L Cloransulam

methyl (97.3%) 43003410 Acceptable

Freshwater Fish (Chronic)

ESTUARINE/MARINE FISH Estuarine/Marine Fish (Acute) Inland Silverside (Menidia beryllina) 96

- hr LC 50 >

121 mg a.i./L Cloransulam

methyl (97.4%) 43718901 Acceptable

Estuarine/Marine Fish (Chronic)

FRESHWATER INVERTEBRATES Freshwater Invertebrates (Acute) Waterflea (Daphnia magna) -- Cloransulam

methyl (97.3%) 43003412 Invalid

Freshwater Invertebrates (Chronic)

ESTUARINE/MARINE INVERTEBRATES Estuarine/Marine Invertebrate (Acute) Eastern Oyster (Crassostrea virginica) 96

- hr LC 50 >

111 mg a.i./L Cloransulam

methyl (97.4%) 43718902 Acceptable

Grass Shrimp (Palaemonetes pugio) 96

- hr LC 50 >

121 mg a.i./L Cloransulam

methyl (97.4%) 43718903 Acceptable

Estuarine/Marine Invertebrate (Chronic)

### - 70 of 85

-

TABLE 2. Cloransulam

- methyl Ecological Effects Data for Terrestrial Plants

Seedling Emergence Tier II Toxicity Test Species EC 25

(lbs a.i./L) NOAEC

(lbs a.i./L) Most

Sensitive Endpoint Compound MRID Classification Comment

Radish 0.00356 0.00145 Fresh weight Cloransula

m

- methyl (98.2%) 43715404 Supplemental Conducted on the TGAI and not the TEP Onion 0.00356 0.00289 Shoot length

Tomato 0.00487 0.00145 Fresh weight

Carrot 0.00956 0.00 289 Fresh weight Ryegrass 0.0297 0.0231 Shoot length

Corn >0.0462 0.0231 Shoot length Soybean >0.0462 0.0231 Shoot length

Cotton >0.0462 0.02310 Fresh Weight Pinto Bean >0.0462 0.0462 None Wheat >0.0462 0.0462 None 

### TABLE 3. Degradate Ecological Effects Data for Terrestrial Plants

Seedling Emergence Tier I/ II Toxicity Test Species EC 25

(lbs a.i./ A ) NOAEC (lbs a.i./ A ) Most Sensitive Endpoint Compound MRID Classificati

on Comment

Radish >0.048

4 lbs ai/A 0.0484 lbs

ai/A Length,

Fresh Weight, Emergenc

e 5

- hydroxy

cloransulm

methyl 44744516 The study on cloransu lam is Accepta ble; 5

- OH

cloransu l am is Supple mental. The study on 5

- OH

cloransu lam

methyl is Supple mental. Conducted

on the TGAI and not the TEP 5

- hydroxy

cloransulm

cloransulam



### Vegetative Vigor Tier I/ II Toxicity Test

### - 71 of 85

-

Species EC 25

(lbs a.i./ A ) NOAEC (lbs a.i./ A ) Most Sensitive Endpoint Compound MRID Classification Comment

Radish 0.0118

lbs ai/A 0.00654

lbs ai/A Fresh

Weight 5

- hydroxy

cloransulm

methyl 44744516 The study

on cloransula m is Acceptabl
e; 5

- OH

cloransul a m is Suppleme ntal. The study on 5

- OH

cloransula

m

- methyl is Suppleme ntal. Conducted

on the TGAI and not the TEP; Study duration not reported 5

- hydroxy

cloransulm

cloransula

m



### TABLE 4. Ecological Effects Data for Aquatic Plants

SPECIES ENDPOINT CHEMICAL/ FORMULATION (percent active ingredient) MRID STUDY CLASS

IFICATION COMMENTS



### Aquatic Nonvascular Plants Green Alga ( Psuedokirchneriella subcapitata, reported

as Selenastrum apricornutum ) 96

- hr EC 50 =

0.003 mg a.i./L NOAEC = 0.00094 mg a.i./L TEP (FirstRate)

(82.2%) 44744517 Acceptable

Green Alga ( Psuedokirchneriella subcapitata, reported as Selenastrum capricornutum Printz) Unknown;

study could not derive endpoint 5

- hydroxy

cloransulam

methyl (not reported) 43760003 Supplemental

Cyanobacteria ( Anabaena flos

aquae ) 120

- hr EC 50

>29.9 mg a.i./L NOAE C = 29.9 mg a.i./L 5

- hydroxy

cloransulam

methyl (>95%) 44744501 Supplemental

Freshwater Diatom ( Navicula pelliculosa ) -- 5

- hydroxy

cloransulam

methyl (>95%) 44744502 Invalid

Saltwater Diatom ( Skeletonema
costatum ) 120

- hr EC 50 >

93.3 mg a.i./L NOAEC = 93.3 mg a.i./L 5

- hydroxy

cloransulam

methyl (>95%) 44744503 Acceptable

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-

Green Alga ( Psuedokirchneriella subcapitata, reported

as Selenastrum apricornutum Printz) 96

- hr EC 50 >

26.3 mg a.i./L NOAEC = 26.3 mg a.i./L 5

- hydroxy

cloransulam

methyl (>95%) 44744504 Supplemental

Green Alga ( Psuedokirchneriella subcapitata, reported as Selenastrum capricornutum Printz) Unknown;

study could not derive endpoint 5

- hydroxy

cloransulam (not reported) 43760004 Supplemental

Cyanobacteria ( Anabaena flos

aquae ) 120

- hr EC 50 =

>26.5 mg a.i./L NOAEC = 26.5 mg a.i./L 5

- hydroxy

cloransulam (>96%) 44744506 Supplemental

Freshwater Diatom ( Navicula pelliculosa ) 120

- hr EC 50 =

>10.7 mg a.i./L NOAEC = 5.64 mg a.i./L 5

- hydroxy

cloransulam (>96%) 44744507 Supplemental

Saltwater Diatom ( Skeletonema
costatum ) 120

- hr EC 50

>103 mg a.i./L NOAEC = 103 mg a.i./L 5

- hydroxy

cloransulam (>97%) 44744508 Acceptable

Green Alga ( Psuedokirchneriella subcapitata, reported

as Selenastrum apricornutum Printz) 96

- hr EC 50 =

> 27.9 mg a.i./L NOAEC = 27.9 mg a.i./L 5

- hydroxy

cloransulam (>97%) 44744509 Supplemental

Freshwater Diatom ( Navicula pelliculosa ) 120

- hr EC 50 =

>47.5 mg a.i./L NOAEC = 47.5 mg a.i./L Cloransulam

(>96%) 44744512 Supplemental

Cyanobacteria ( Anabaena flos

aquae ) 120

- hr EC 50

>3.65, <7.71 mg a.i./L NOAEC = 3.65 mg a.i./L Cloransulam

(>96%) 44744511 Supplemental

Saltwater Diatom ( Skeletonema
costatum ) 120

- hr EC 50 >

90.8 mg a.i./L NOAEC = 90.8 mg a.i./L Cloransulam

(>96%) 44744513 Acceptable

Green Alga ( Psuedokirchneriella subcapitata, reported

as Selenastrum apricornutum Printz) 96

- hr EC 50 =

0.00 7 4 mg a.i./L EC 05 = 0.00 21 mg a.i./L Cloransulam

(>96%) 44744514;

43668917 Acceptable



### Aquatic Vascular Plants

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-

Duckweed ( L. gibba ) -- Cloransulam

methyl (97.3%) 43668916 I nvalid The results of this study do not fully meet guideline standards based on test substance instability, control contamination, and uncertainty regarding the effects of the solvent

Duckweed ( L. gibba ) 14

- day EC 50 =

110 mg a.i./L (frond number) NOAEC = 58.3 mg a.i./L (frond number & growth rate) 5

- hydroxy

cloransulam

methyl (>95%) 44744505 Supplemental

Duckweed ( L. gibba ) 14

- day EC 50 =

≥ 100 mg a.i./L (frond number) NOAEC = 53.6 mg a.i./L 5

- hydroxy

c loransulam (>97%) 44744510 Acceptable

Duckweed ( L. gibba ) 14

- day EC 50 =

0.130 mg a.i./L (frond number) NOAEC = 0.0611mg a.i./L Cloransulam

(>96%) 44744515 Acceptable

### - 74 of 85

-

APPENDIX E : SIP v.1.0 Description, Assumptions, Inputs and Outputs

SIP v.1.0 provides an upper bound estimate of exposure of birds and mammals to pesticides through drinking water alone. This model is intended for use in problem formulation to determine whether or not drinking water exposure alone is a potential pathway of concern. This does not aggregate drinking water exposure with other exposure routes (i.e., diet, inhalation, dermal).

Assumptions:

SIP employs the following conservative assumptions to derive upper bound exposure estimates: 1) The chemical concentration in drinking water is at the solubility limit in water (at 25 o C). 2) The assessed animals obtain 100% of their daily water needs through drinking water. 3) The daily water need is equivalent to the daily water flux rate as calculated by Nagy and Peterson (1988). 4) The body weight of the assessed bird is equivalent to the smallest generic bird modeled in T

- REX (i.e., 20 g). This assumption results in the highest ratio of exposure to toxicity for the 3 assessed avian body weights of T

- REX (i.e., 20, 100, 1 000 g). 5) The body weight of the assessed mammal is equivalent to the largest generic mammal modeled in T

- REX (i.e., 1000 g). This results in the highest ratio of exposure to toxicity for the 3 assessed mammalian body weights of T

- REX (i.e., 15, 35, 1000 g).

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-

Table 1. Inputs Parameter Value Chemical name Cloransulam

- methyl Solubility (in water at 25 o C; mg/L) 3400

Mammalian LD 50 (mg/kg

- bw) 5000 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg

- bw) 100 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg

- bw) 2250 Avian test species northern bobwhite quail Body weight (g) of "other" avian species Mineau scaling factor 1.15

Mallard NOAEC (mg/kg

- diet) 0 Bobwhite quail NOAEC (mg/kg

diet) 0 NOAEC (mg/kg

- diet) for other bird species Body weight (g) of other avian species NOAEC (mg/kg

- diet) for 2nd other bird species Body weight (g) of 2nd other avian species

Table 2. Mammalian Results Parameter Acute Chronic Upper bound exposure (mg/kg

bw) 584.8000 584.8000 Adjusted toxicity value (mg/kg

bw) 3845.8028 76.9161 Ratio of exposure to toxicity 0.1521 7.6031

Conclusion* Exposure through drinking water alone is a potential concern for mammals Exposure through drinking water alone is a potential concern for mammals

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-

Table 3. Avian Results Parameter Acute Chronic Upper bound exposure (mg/kg

bw) 2754.0000 2754.0000 Adjusted toxicity value (mg/kg

bw) 1620.9664 0.0000 Ratio of exposure to acute toxicity 1.6990 0.0000

Conclusion* Exposure through drinking water alone is a potential concern for

birds Due to insufficient data, risk

cannot be precluded

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. Therefore, when aggregated with other routes ( i.e ., diet, inhalation, dermal), pesticide exposure through drinking water may contribute to a total exposure that has potential for effects to non

- target animals.

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-

APPENDIX F : Data Call

- In Tables

The Environmental Fate and Effects Division (EFED) has completed a Data Call

- In (DCI) table for the cloransulam

- methyl environmental fate and effects data gaps identified in Registration Review. The attached DCI table, which includes the guideline number and study title for required data, also provides a rationale for requiring the data, an explanation of how the data will be used, and a brief description of how the data could impact the Agency‟s future decision

making.

Guideline Number: 835. 43 00 Study Title: A erobic Aquatic Metabolism Rationale for Requiring the Data Acceptable data on the aerobic aquatic metabolism of cloransulam

- methyl in two sediment systems are required under 40 CFR Part 158, Subpart N (revised July 1, 2009) for labeling that includes terrestrial

uses. Submitted a erobic aquatic metabolism data were classified as not acceptable . The Agency has a limited understanding of how cloransulam

- methyl behaves in aerobic aquatic environments once applied. D ata are needed for t wo sediment

- water systems cond ucted (one each) at neutral and acidic pHs

. Practical Utility of the Data How will the data be used? Aerobic aquatic metabolism data will facilitate a better understanding of the fate of cloransulam

- methyl residues in water. If data indicate that degradation in aerobic conditions occurs rapidly in neutral and acidic aquatic systems and produces nontoxic transformation products, then the Agency could potentially determine that cloransulam

- methyl residues of concern do not persist in these systems. If data indicate that degradation is not appreciable in aquatic systems or that the transformation products are of similar or higher toxicity than the parent compound, then the Agency could conclude that cloransulam

- methyl residues of concern persist in acidic aquatic systems under anaerobic conditions.

How could the data change the Agency’s decision or impact the Agency’s future decision

- making? In the absence of the requested data, cloransulam

- methyl aerobic aquatic metabolism half

- lives will be conservatively assumed to be stable at a neutral pH, or less conserva tively at t wo times the aerobic soil metabolism half

- life modeling input value

. I f the required data indicate that cloransulam

- methyl in aerobic aquatic environments is rapidly biodegraded to nontoxic degradation products, then risk assessment conclusions and associated labeled use precautions and/or restrictions could be made less restrictive.

Guideline Number: 835.4400 Study Title: Anaerobic Aquatic Metabolism Rationale for Requiring the Data Acceptable data on the anaerobic aquatic metabolism of cloransulam

- methyl are required under 40 CFR Part 158, Subpart N (revised July 1, 2009) for labeling that includes terrestrial uses. Anaerobic aquatic metabolism data have only been submitted for one sediment, but were classified supplemental, whereas

acce ptable data for two sediments are required. The Agency has a limited understanding of how cloransulam behaves in anaerobic aquatic environments once applied. An anaerobic aquatic metabolism study of cloransulam

- methyl (MRID 43715403) was submitted to the A gency. However, data are needed for two additional sediment

- water system s conducted at a neutral and an acidic pH. The current

### - 78 of 85

-

supplemental study will be used for risk assessment purposes, however additional studies conducted in an acidic (low pH) system and a neutral pH system is required to fulfill the guideline and better understand the potential variability in the biotic degradation in oxygen limiting aquatic environments. Thus, the Agency is requiring an OCSPP guideline

- compliant anaerobic aquatic met abolism study with two systems, one each at a neutral pH and one at an acidic pH

. Practical Utility of the Data How will the data be used? Anaerobic aquatic metabolism data will facilitate a better understanding of the fate of cloransulam

methyl residues in water. If data indicate that degradation in anaerobic conditions occurs rapidly in acidic and/or neutral aquatic systems and produces nontoxic transformation products, then the Agency could potentially determine that cloransulam

- methyl residue s of concern do not persist in these systems. If data indicate that degradation is not appreciable in aquatic systems or that the transformation products are of similar or higher toxicity than the parent compound, then the Agency could conclude that clora nsulam

- methyl residues of concern persist in acidic aquatic systems under anaerobic conditions.

How could the data change the Agency’s decision or impact the Agency’s future decision

- making? In the absence of the requested data, cloransulam

- methyl anaerobic aquatic metabolism half

- lives will be conservatively assumed to be stable at a neutral pH, or less conservatively three times the current anaerobic soil metabolism half

- life. However, since the compound is hydrolytically stable at neutral and aci dic pHs
, the current study (which does not clearly identify the sy s tem pH) does not accurately capture the potential variability in the anaerobic degradation rates. I f the required data indicate that cloransulam

methyl in anaerobic aquatic environments is rapidly biodegraded to nontoxic degradation products, then risk assessment conclusions and associated labeled use precautions and/or restrictions could be made less restrictive.

Guideline Number: 835.4200 Study Title: Anaerobic Soil Metabolism Rationale for Requiring the Data Acceptable data on the anaerobic soil metabolism of cloransulam

- methyl are required under 40 CFR Part 158, Subpart N (revised July 1, 2009) for labeling that includes terrestrial uses. Currently, there are no submitted studies that satisfy the guideline. Therefore, the Agency has a limited understanding of how cloransulam

- methyl behaves in anaerobic soil environments once applied. Depending on how quickly, to what extent, and to which transformation products the compou nd degrades, cloransulam

- methyl may or may not pose a potential for ground water contami n ation . Because cloransulam

- methyl degradation in anaerobic soil systems is not well understood, the Agency is requiring an OCSPP guideline

- compliant anaerobic soil me tabolism study

.

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- Practical Utility of the Data How will the data be used? Anaerobic soil metabolism data will facilitate a better understanding of the fate of cloransulam

- methyl residues in subsurface soil, and anaerobic sediments. If data indicate that degradation in anaerobic conditions occurs rapidly and produces nontoxic transformation products, then the Agency could potentially determine that cloransulam

- residues residues of concern do not persist in these systems. If data indicate that degradation is not appreciable in anaerobic systems or that the transformation products are of similar or higher toxicity than the parent compound, then the Agency could conclude that cloransulam

- met hyl residues of concern persist in anaerobic soil systems.

How could the data change the Agency’s decision or impact the Agency’s future decision

- making? In the absence of the requested data, cloransulam

- methyl anaerobic soil metabolism half

- lives will be conservatively assumed stable. If the required data indicate that cloransulam

- methyl in anaerobic soil environments is rapidly biodegraded to nontoxic degradation products, then risk assessment conclusions and associated labeled use precautions and/or restrictions could be made less restrictive.

Guideline Number: 835.6100 Study Title: Storage Stability Rationale for Requiring the Data Acceptable data on the frozen storage stability of cloransulam

- methyl are required under 40 CFR Part 158, Subpart N (revised July 1, 2009)
, for labeling that includes terrestrial uses
, as part of the submitted terrestrial field dissipation studies. The Agency has a limited understanding of how cloransulam

- methyl behaves in fro zen storage conditions between the time of sampling and the time of analysis. One study (MRID 430034

- 34) showed extracted residues decreased as a result of frozen storage prior to analysis. Submission of a storage stability study is essential in order to be confident that any degradation measured in the test system was due solely to the environment of that test system, and not due to handling and storage. Practical Utility of the Data How will the data be used? Storage stability data will facilitate a better understanding of the fate of cloransulam

- methyl residues during storage and handling between sampling and analysis. If data indicate that significant degradation of cloransulam

- methyl or its degradates occur then the data from the field studies are no longer valid as it would not be feasible to determine if the degradation measured in the test system was due solely to the environment of that test system, and not due to handling and storage.

How could the dat a change the Agency’s decision or impact the Agency’s future decision

- making? In the absence of the required data, the field data for cloransulam

- methyl will be qualitatively used in the risk assessment. These data are used for confirmatory purposes to ensure that any degradation observed in the test systems is due solely to the test environment and not handling or storage.

### - 80 of 85

-

Guideline Number: 835.6100 Study Title: Analytical Method (and Associated Independent Laboratory Validation) for Residues in Sediment Rationale for Requiring the Data Independently validated analytical methods for residues in soil, water, sediment, and plant material (environmental chemistry methods) submitted by the registrant are used to evaluate analyses described in submitted environmental fate and ecological effects studies. Submitted analytical methods are also used by various Federal, State, Tribal, and local agencies to detect and monitor residues that are or are suspected to be in environmental compartments due to outdoor uses and accidental releases. Independent laboratory validations for submitted analytical methods are necessary to confirm that the methods are functional and to confirm the levels of detection and quantitation reported in registrant

- prepared

v alidations. Practical Utility of the Data How will the data be used? In the absence of independently validated environmental chemistry methods, submitted environmental fate and ecological effects data may not be reviewable and entities outside the Agency may lack chemical

- specific methods for analyses in environmental compartments. Independently validated environmental chemistry methods will be used to evaluate submitted environmental fate and ecological effects data and will be made available for enforc ement and monitoring purposes at the federal, state, and local levels.

How could the data change the Agency’s decision, or impact the Agency’s future decision

- making? Risk assessment conclusions could be altered if they are not supported by either study data or environmental monitoring detections that are based on independently validated environmental chemistry methods. Furthermore, while not directly related to Agency decision

- making, independently validated environmental chemistry methods are necessary to ensure the safety of those in proximity to releases of cloransulam

- methyl residues in the environment.

Guideline Number: 850.2300 Study Title: Avian Reproductio n Test Rationale for Requiring the Data Under the 40 CFR Part 158 (Oct. 26, 2007) data requirements for conventional pesticides, avian reproduction data are required on waterfowl and upland game species (OCSPP Guideline 850.2300). Data for cloransulam

- methyl are have been review ed for both an u pland game species ( b obwhite quail), MRID 436689

- 05, and waterfowl species ( m allard duck), MRID 436993

- 01. The b obwhite quail study resulted in significant adverse effects at the lowest treatment concentration. T he NOAEC for the bobwhite quail was determ ined to be <654 mg a.i./kg

- diet based on number of eggs set, number of viable embryos, number of live embryos, number hatched, and hatchling survival. The NOAEC based on these parameters in the m allard study is 1,505 mg a.i./kg

- diet, indicating that for c ertain parameters
, the b obwhite quail is more sensitive to cloransulam

- methyl. Therefore, since a definitive NOAEC value is required, an additional study of bobwhite quail is recommended. Practical Utility of the Data How will the data be used? Reproduction data for b obwhite quail will be used to reduce uncertainties associated with using data from a potentially

- less sensitive species (mallard duck) to assess chronic risks to birds and by extension to terrestrial

- phase amphibians and reptiles fro m cloransulam

- methyl exposure. If reproduction toxicity data are not submitted for bobwhite quail, the current non

- definitive NOAEC would be used to assess chronic avian risk and all chronic risk quotients would be assumed greater than their actual value. As such, chronic risk to birds from cloransulam

- methyl use on soybeans would be presumed.

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-

How could the data impact the Agency’s future decision

- making? If future endangered species risk assessments are performed without these data, the Agency would have to assume that cloransulam

- methyl “may affect” listed birds, reptiles, and terrestrial

- phase amphibians directly (and listed species from other taxa indirectly), and use of cloransulam

- methyl and its formulated products may need to be restricted in ar eas where listed species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictions for cloransulam

- methyl use that are unnecessarily severe.

Guideline Number: 850.1010 Study Title: Acute Freshwater Invertebrate Toxicity Test Rationale for Requiring the Data The CFR Part 158 data requirements specify that acute toxicity data on freshwater invertebrates are required for the registration of pesticides with outdoor uses. Scientifically valid acute toxicity data are not available for freshwater invertebrates. Additionally, no data exists on the chronic exposure of cloransulam

- methyl to freshwater invertebrates that cou ld suggest cloransulam

- methyl is practically non

toxic to freshwater invertebrates. An acute freshwater invertebrates toxicity test (OCSPP 850.1010) is requested at this time. Practical Utility of the Data How will the data be used? Acute freshwater invertebrate toxicity data will be used to determine the potential for cloransulam

- methyl to affect invertebrate species in freshwater environments. The data will reduce uncertainties associated with the current risk assessment for freshwa ter invertebrates and will improve the Agency‟s understanding of the potential effects of cloransulam

- methyl on aquatic animals. In the absence of data specific for these invertebrates, risk to freshwater invertebrates will be presumed.

How could the dat a impact the Agency’s future decision

- making? If future endangered species risk assessments are performed without these data, the Agency would have to assume that cloransulam

- methyl “may affect” listed freshwater invertebrates directly (and listed species from other taxa indirectly), and use of cloransulam

- methyl and its formulated products may need to be restricted in areas where listed species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming int o compliance with the Endangered Species Act and could result in use restrictions for cloransulam

- methyl use that are unnecessarily severe.

Guideline Number: 850.1300 Study Title: Freshwater Invertebrate Life Cycle Toxicity Test Rationale for Requiring the Data The Agency has worked to finalize the data requirements updates in 40 CFR Part 158. These updated data requirements were promulgated in October 2007. As a result, one freshwater invertebrate life

- cycle study (OCSPP 850.1300) is requir ed to support all terrestrial use patterns. C hronic toxicity data are currently unavailable for freshwater invertebrates and a life cycle toxicity test is requested at this time. Practical Utility of the Data How will the data be used? Chronic freshwater invertebrate toxicity data will be used to determine the potential for cloransulam

methyl to affect reproduction , growth and survival of invertebrate species in freshwater environments following prolonged exposure

. The data will reduce uncertain ties associated with the current risk assessment for freshwater invertebrates and will improve the Agency‟s understanding of the potential chronic effects of cloransulam

- methyl on aquatic animals. In the absence of data specific for these invertebrates, c hronic risk to freshwater invertebrates will be presumed.

How could the data impact the Agency’s future decision

- making?

### - 82 of 85

-

If future endangered species risk assessments are performed without these data, the Agency would have to assume that cloransulam

- methy l “may affect” listed freshwater invertebrates directly (and listed species from other taxa indirectly), and use of cloransulam

- methyl and its formulated products may need to be restricted in areas where listed species could be exposed. The lack of these d ata will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictions for cloransulam

- methyl use that are unnecessarily severe.

Guideline Number: 850.1400 Study Title: Fish Early

- Life Stage Toxicity Test, Freshwater Rationale for Requiring the Data The Agency has worked to finalize the data requirements updates in 40 CFR Part 158. These updated data requirements were promulgated in October 2007. As a result, one freshwater fish early

- life stage study (OCSPP 850.1400) is required to support all terrestrial use patterns. Chronic toxicity data are currently unavailable for freshwater fish and an early

- life stage toxicity test is requested at this time. Pract ical Utility of the Data How will the data be used? Chronic freshwater fish toxicity data will be used to determine the potential for cloransulam

- methyl to affect the reproduction, survival, and growth of fish in freshwater environments. The data will reduce uncertainties associated with the current risk assessment for freshwater fish (and by extension for aquatic

phase amphibians as well) and will improve the Agency‟s understanding of the potential effects of cloransulam

- methyl on aquatic animals. In the absence of data specific for these fish, chronic risk to freshwater fish and aquatic

- phase amphibians will be presumed.

How could the data impact the Agency’s future decision

- making? If future endangered species risk assessments are performed without these data, the Agency would have to assume that cloransulam

- methyl “may affect” listed freshwater fish and aquatic

- phase amphibians directly (and listed species from other taxa indirectly), and use of cloransulam

- methyl and its formulated products may nee d to be restricted in areas where listed species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictions for cloransu lam

- methyl use that are unnecessarily severe.

Guideline Number: 850.4 225 Study Title: Terrestrial Plant Seedling Emergence Test (Tier II) Rationale for Requiring the Data Terrestrial plant toxicity studies are required for registration of pesticides with outdoor uses (CFR Part 158). For known phytotoxicants, a Tier II s eedling emergence study (OCSPP 850.4225) is required on a TEP to investigate the effects of the pesticide end

- use product on the emergence, growth
, and survival of terrestrial plants. Although the available emergence study, MRID 437154

- 04, has been reviewed , the registration requirement for a Tier II seedling emergence test on a TEP has not been met. Because the toxicity of cloransulam

- methyl to terrestrial plants is expected to be enhanced when formulated as a product with additional ingredients, such as surfactants, we recommend requesting a second Tier II seedling emergence toxicity study conducted on 

### a TEP containing the single active ingredient cloransulam

- methyl ( i.e. , Riverdale® and Firstrate® formulations) . In the absence of this data, risk to plants off the application site would pote ntially be underestimated.

### - 83 of 85

- Practical Utility of the Data How will the data be used? Tier II vegetative vigor data for terrestrial plants will be used to determine the potential for cloransulam

methyl to affect non

- target plant species in the terrestrial environment and to reduce uncertainties associated with the current risk assessment to terrestrial plants. In the absence of data specific to the emergence and initial growth life stages, the spatial extent of risk to terrestrial plants off the application site would potentially be underestimated.

How could the data impact the Agency’s fu ture decision

- making? Because plants form the basis of most habitats and significantly contribute to overall environmental quality, a solid understanding of the potential risks to terrestrial plants is essential for sound environmental management. If the data indicates that registered cloransulam

- methyl usage poses an even greater risk of adverse effects to non

- target terrestrial plants above the Agency Level of Concern, the Agency may further explore decision options to mitigate this risk. T he lack of da ta on the spatial extent of risk will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act.

Guideline Number: 850.4 2 50 Study Title: Terrestrial Plant Vegetative Vigor Test (Tier II) Rationale for Requiring the Data Terrestrial plant toxicity studies and associated risk analysis of plants are required for registration of pesticides with outdoor uses (CFR Part 158). For known phytotoxicants, a Tier II vegetative vigor study (OSCPP 850 .4 250 ) is required on a TEP to investigate the effects of the pesticide end

- use product on the growth and survival of terrestrial plants. The available vegetative vigor study , MRID 437154

- 04, has been reviewed
, but does not satisfy registration and g uidel ine requirements. The registration requirement for a Tier II vegetative vigor test on a TEP has not been met, and the study does not appear to fully meet guideline standards based on notable guideline deviations. Because the toxicity of cloransulam

- methy l to terrestrial plants is expected to be enhanced when formulated as a product with additional ingredients, such as surfactants, we recommend requesting a second Tier II vegetative vigor toxicity study conducted

on 

### a TEP containing the single active ingre dient cloransulam

- methyl ( i.e. , Riverdale® and Firstrate® formulations) . In the absence of this data, risk to plants off the application site would potentially be underestimated. Practical Utility of the Data How will the data be used? Tier II vegetative vigor data for terrestrial plants will be used to determine the potential for cloransulam

methyl to affect non

- target plant species in the terrestrial environment and to reduce uncertainties associated with the current risk assessment to terrest rial plants. In the absence of data specific to the vegetative life stages, the spatial extent of risk to terrestrial plants off the application site would potentially be underestimated.

How could the data impact the Agency’s future decision

- making? Beca use plants form the basis of most habitats and significantly contribute to overall environmental quality, a solid understanding of the potential risks to terrestrial plants is essential for sound environmental management. If the data indicates that regist ered cloransulam

- methyl usage poses an even greater risk of adverse effects to non

- target terrestrial plants above the Agency Level of Concern, the Agency may further explore decision options to mitigate this risk. T he lack of data on the spatial extent

o f risk will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act.

### - 84 of 85

-

Guideline Number: 850.4400 Aquatic Plant Growth Tier II Study (Vascular plants ) Rationale for Requiring the Data Aquatic vascular plant toxicity studies and associated risk analysis of aquatic vascular plants are required for registration of pesticides with outdoor uses (40 CFR Part 158). For known phytotoxicants, a Tier II aquatic vascular plant toxicity study (OCS PP Guideline 850.4400) on either the TGAI or TEP is required. The available vascular aquatic plant study with a TEP using L. gibba , MRID 436689

- 16, has been reviewed and does not appear to fully meet OCSPP Guideline standards due to a number of noted defi ciencies and uncertainties ( i.e., test substance instability, solvent control contamination, and solvent control effect uncertainty). Th e s e data are insufficient to quantitatively assess risk to aquatic vascular plants from cloransulam

- methyl use. Practical Utility of the Data How will the data be used? Th e s e data will be used to estimate potential risks to aquatic vascular plants from cloransulam

- methyl exposure. The data will reduce uncertainties associated with the current risk assessment for aquatic vascular plants and will improve our understanding of the potential effects of cloransulam

- methyl use on aquatic vascular plants. Because plants form the basis of most habitats and significantly contribute to overall environmental quality, a soli d understanding of the potential risks to aquatic plants is essential for sound environmental management. The data will also be used in determining whether a “may affect” to Federally

- listed threatened and endangered species is likely under the Endangered Species Act.

How could the data impact the Agency’s future decision

- making? Without aquatic plant growth data for cloransulam

- methyl, the Agency cannot determine the levels of cloransulam

- methyl that result in effects to vascular aquatic plants

. If th e s e data are not available, risk to aquatic vascular plants will be presumed and the extent of risk from cloransulam

- methyl usage c ould potentially be underestimated. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act, and could result in severe use restrictions for cloransulam

- methyl, a known phytotoxicant, which may otherwise be avoided.

Guideline Number: 850.5400 Algal Toxicity Tier II Study Rationale for Requiring the Data Aquatic (both vascular and non

- vascular species) toxicity studies and associated risk analysis of plants are required for registration of pesticides with outdoor uses (CFR Part 158). 

### For known phytotoxicants, four Tier II nonvascular toxicity studies (OCSP P Guideline 850.5400) on either the TGAI or TEP are required. There is currently only one available study on freshwater green algae to determine levels of cloransulam

- methyl that could result in effects to aquatic non

- vascular plants. Three more

nonvascu lar plant studies are required as specified in 40 CFR Part 158 ; these include a study on a freshwater diatom, saltwater diatom, and nitrifying cyanobacteria. Practical Utility of the Data How will the data be used? This Tier II data will be used to adequately assess risks to aquatic nonvascular plants from cloransulam

methyl exposure. The data will reduce uncertainties associated with the current risk assessment for aquatic nonvascular plants based currently on only one species and will improve our understanding of the potential effects of cloransulam

- methyl use on aquatic plants. In the absence of data specific to freshwater diatom s , saltwater diatom s , and a nitrifying cyanobacteria, the extent of effects to nonvas cular plants would be unknown and the extent of risk to aquatic plants c ould potentially be underestimated.

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-

Because plants form the basis of most habitats and significantly contribute to overall environmental quality, a solid understanding of the potentia l risks to aquatic plants is essential for sound environmental management. As a known phytotoxicant, risk to aquatic plants from cloransulam

- methyl use would be presumed in the absen ce of th e s e data. The data will also be used in determining whether a “m ay affect” to Federally

- listed threatened and endangered species is likely under the Endangered Species Act.

How could the data impact the Agency’s future decision

- making? Without additional nonvascular aquatic plant toxicity data for cloransulam

- methyl, the Agency cannot determine with certitude the levels of cloransulam

- methyl that result in effects to nonvascular aquatic plants

. If this data is not available, the extent of risk to aquatic nonvascular plants from c loransulam

methyl usage c ould potentially be underestimated. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act, and could result in severe use restrictions for clora nsulam

- methyl, a known phytotoxicant, which may otherwise be avoided.