2

REGISTRATION REVIEW

PROBLEM FORMULATION

______________________________________________________________________________

Triallate

CAS Number 2303-17-5

US EPA PC CODE 078802

Prepared by:

He Zhong, Ph.D., Biologist 

Faruque Khan, Ph.D., Senior Fate Scientist

Edom Seifu, Intern

Environmental Risk Branch 1

Reviewed by:

Meghan Radtke, Ph.D., Acting RAPL

Steve Wente, Ph.D., Biologist

Environmental Risk Branch 1

U.S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch I

1200 Pennsylvania Ave., NW

Mail Code 7507P

Washington, DC 20460

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1 Executive Summary

The Environmental Fate and Effects Division (EFED) has completed the preliminary problem 

formulation for the ecological risk, environmental fate, endangered species, and drinking water 

assessments to be conducted as part of the Registration Review of triallate. The problem 

formulation describes the methods planned to be used during the completion of drinking water 

and ecological risk assessments in support of Registration Review and provides an overview of 

the environmental fate, ecological effects, and potential risks associated with the use of triallate

as well as uncertainties unique to the risk assessment of triallate. This document also identifies 

the label deficiencies and additional studies that are required for an ecological risk assessment. 

Pesticide Label Clarification Needed:

For All Labels

 The maximum number of applications per year

 The maximum annual application rate (lb a.i. per acre)

 The minimum application intervals

For Granular Labels: 

 The average size and a.i. of a single granule

Major Data Needs

 Guideline 835.4400 – Anaerobic Aquatic Metabolism for triallate

 Guideline 850.6100 – Environmental Chemistry and Independent Laboratory Validation 

methods for triallate and its degradate 2,3,3-trichloro-2-propenesulfonic acid (TCPSA), 

(water and soil).

 Guidelines 850.1035, – Acute toxicity for estuarine/marine invertebrates (mysid shrimp)

for triallate

 Guidelines 850.1025, 850.1045 and 850.1055 – Acute toxicity for estuarine/marine 

mollusk (select one -oyster, penaeid or bivalve) for triallate 

 Guideline 850.1075 – Saltwater fish acute toxicity for triallate (recommend the same 

saltwater fish species for acute and chronic studies)

 Guideline 850.1350 – Saltwater invertebrate life cycle for triallate

 Guideline 850.1400 – Saltwater fish early-life stage for triallate (recommend the same 

saltwater fish species for acute and chronic studies)

 Non-guideline – Whole sediment invertebrate chronic toxicity (Chironomus dilutus, 

freshwater amphipod Hyalella azteca, and estuarine/marine amphipod Leptocheirus 

plumulosus) for triallate

 Guideline 850.4550 – Cyanobacteria toxicity for triallate

 Guideline 850.2100 – Avian acute oral toxicity (passerine) for triallate

 Guideline 850.2300 – Avian reproduction (waterfowl) for triallate

 Non-guideline honeybee adult chronic oral toxicity for triallate

 Non-guideline honeybee larval acute and chronic oral toxicity for triallate

Justifications for these data needs as well as assumptions that will be made in the absence of the

data are provided in Section 11.
4

2 Introduction

Triallate was first registered as a pesticide in the U.S. in 1961 (USEPA 2001). Triallate is a 

thiocarbamate pre-emergence selective herbicide that inhibits the synthesis of lipids and 

prohibits shoot growth of emerging seedlings.

3 Use Characterization

Triallate is a thiocarbamate pre-emergence selective grass herbicide that is used to control wild 

oats, black grass, and annual meadow grass. The chemical profile produced by the Biological 

and Economic Analysis Division (BEAD), located in the docket, lists the use patterns of 

maximum exposures for the current uses of triallate. The usage data show a declining trend in 

recent years from an average of 2 million lbs/yr (1998-2002) to 156,000 lbs/yr (2008-2013) and 

the registered agricultural use sites of triallate include: Bermuda grass (grown for seed or hay), 

dry beans and peas, green peas, lentils, barley, spring wheat, triticale, and sugar beets (USEPA 

2014a). The highest average annual rate (a.i.) is 1.109 lbs a.i./acre on barley in 2008-2012

(Table 3-1). 

Table 3-1. Triallate Use on Top Crops, 2008 – 2012

Crop Average Annual 

Applied (lbs a.i.)

Average Annual 

Total Acres Treated*

Average Annual Rate

(lbs a.i. / acres)

Barley 54,533 49,177 1.109

Spring Wheat 50,567 49,441 1.023

Dry Bean/Pea 33,139 34,397 0.963

Winter Wheat 17,968 17,889 1.000

*Total Acres Treated sums all acres treated for a crop, including those acres that received multiple treatments

Triallate is available as an emulsifiable concentrate (Far-GO® Herbicide (EPA Reg. No. 100163-

286)), foliar spray, water-dispersible granule (WDG), and granular formulations (Avadex 

MinTill Herbicide (EPA Reg. No. 100163-287) and (BUCKLE, EPA Reg. No. 100163-289). 

The BUCKLE granular herbicide is a mixture of triallate and trifluralin, must only be applied by 

ground methods. Depending on the crop that is treated, the herbicide is applied either before or 

after planting. According to the label, triallate can be applied as a surface broadcast (no-till) or 

incorporated in the soil with a maximum single application rate of 1 to 1.5 lbs a.i. per acre. 

There are two major issues on the labels: 1). the average granular size and a.i. are not specified 

on the granular labels; 2). the minimum application intervals, the maximum annual application 

rate (lb a.i. per acre) and numbers are not specified for all registered labels. Without the 

maximum annual application numbers, EFED will use application scenarios that result in 

maximum exposure scenarios, such as: multiple crop seasons in a year, for a given use for the 

risk assessment (see Appendix A for summary of labels).

4 Conclusions from Previous Risk Assessments

4.1 Ecological Risk Assessments
5

The most recent triallate assessments include a RED (USEPA 2001) and a Section 3 new use 

registration request for use on Bermuda grass seed treatment (USEPA 2009a, DPs 351896, 

352259 and 358774). These two assessments indicated that the use of triallate may cause direct

and indirect effects to listed aquatic invertebrates, land-phase amphibians, reptiles and small 

mammals; listed and non-listed terrestrial and semi aquatic plants; and non-listed aquatic 

invertebrates in unprotected shallow water habitats, such as potholes, bogs, or wetlands. 

The following data gaps were identified in the 2009 assessment:

 Guidelines 850.1025, 850.1035, 850.1045 and 850.1055 – Estuarine/marine acute 

toxicity data for invertebrates, and mollusks. 

 Guideline 850.1075 – Estuarine/marine fish acute toxicity data

 Guideline 850.1350 – Estuarine/marine invertebrate life cycle data

 Guidelines 850.1400 and 850.1500 – Estuarine/marine fish chronic toxicity data

4.2 Drinking Water Exposure Assessments

The most recent drinking water exposure assessment for triallate was conducted in 2008 to 

establish tolerances for triallate and its degradate 2,3,3-trichloro-2-propenesulfonic acid 

(TCPSA) on Bermuda grass (USEPA 2009b, D358774). Recommended Estimated Drinking 

Water Concentrations (EDWCs) were modeled for the total toxic residues (TTR) of parent 

triallate and its degradate 2,3,3-trichloro-2-propenesulfonic acid (TCPSA). Recommended 

surface water EDWCs for TTR of triallate from currently labeled uses are 9.45 μg/L (1-in-10-

year peak) for acute, and 1.26 μg/L (36-year mean) for chronic; the groundwater EDWC is 0.02 

μg/L for both acute and chronic (USEPA, 2001). 

4.3 Clean Water Act Programs

Triallate is not identified as a cause of impairment for any water bodies listed as impaired under 

section 303(d) of the Clean Water Act. No Total Maximum Daily Load (TMDL) criteria have 

been developed for triallate. Aquatic benchmarks have been established for triallate and are 

available at http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm. Any data 

submitted or otherwise located as part of the Registration Review process may be used to update 

aquatic life benchmarks, if applicable. 

5 Environmental Fate and Transport

A summary of physical, chemical and environmental fate properties of triallate (S-(2,3,3-

trichloro-2-propenyl)bis(1-methylethyl) carbamothioate) are presented in Table 5-1. The 

physicochemical properties indicate that triallate has a low water solubility (4 mg/L at 25°C). 

The vapor pressure of 1.20 x 10-4 mm Hg indicates that triallate is a semi-volatile chemical and 

Henry's law constant of 1.20 × 10-5atm-m3/mol suggests volatilization is expected to be a major 

route of dissipation from moist soil and water. Triallate volatilized with a flux rate of 3.6 x 10-3

μg/cm2/hr from sand treated at a rate of 1.5 lb. a.i./A in a laboratory study. Open literature data 

also indicate that triallate volatilization is a major route of dissipation under actual use 
6

conditions. In a USGS review, triallate volatilization accounted for 15% and 74% of applied 

materials for incorporated and unincorporated triallate respectively (Majewski and Capel, 1995). 

In another study (Smith et al., 1997), 21 % of applied triallate volatilized over a 24-day period 

after application of granular triallate.

Triallate has a potential to bioaccumulate (log Kow = 4.55). The potential to bioaccumulate was 

supported by the results of a fish bioconcentration factor (BCF) study (BCF’s of 700 in edible 

tissue, 2700 in visera and 1600 in whole fish). However, the depuration of triallate from fish is 

relatively quick (> 90% within 14 days following the end of the exposure); therefore, 

bioconcentration will only occur in situations with continued or repeated exposure of triallate in 

surface water. 

Triallate is stable to abiotic degradation processes including hydrolysis, aqueous photolysis, and 

photolysis on soil. The major mode of triallate degradation is aerobic soil metabolism (DT50s of 

18-60 days), which occurs with significant mineralization. In addition, DT50s of 45 days and 49 

days were observed for the encapsulated and unencapsulated triallate formulations, respectively. 

Triallate metabolizes much more slowly and is considered stable under anaerobic conditions. 

Under aerobic aquatic conditions, DT50 values ranged from 64 to 74 days in a sediment-water 

system. Volatilization of the parent may have contributed to the overall dissipation during the 

laboratory studies. No major degradate was identified except CO2. Several unidentified minor 

metabolites and < 5% of 2,3,3-trichloroprop-2-ene sulfonic acid (TCPSA) were detected in the

laboratory studies (Appendix B). 

The batch equilibrium data for adsorption coefficients (Kads) ranged from 5.3 ml/g to 35 ml/g. 

Calculated Koc values for triallate ranged from 1305 ml/g to 2730 ml/g, which suggests triallate is 

slightly mobile according to the pesticide mobility classification of the Food and Agriculture 

Organization (FAO 2000). Soil column leaching studies appear to confirm triallate's lack of 

mobility in soil. In an aged column leaching study, 7% of the applied radioactivity was found in 

the leachate. In a supplemental study comparing the leaching behavior of encapsulated and 

unencapsulated formulations, the concentration of radioactivity in the leachate was 4.7 % and 

17.5 % of the applied C14-activity for encapsulated and unencapsulated triallate, respectively. 

However, the leached material was mainly the triallate metabolite 2,3,3-trichloroprop-2-ene 

sulfonic acid (TCPSA), which is a concern for the Health Effects Division’s tolerance expression 

but it is not a concern for ecological risk assessment. Since TCPSA is a minor degradate and 

unstable in the environment (EPISUITE 4.1 predicted DT50s of 38 hours in water and 62 hours 

in soil) as well as several fold less toxic to aquatic organisms, it will be not included in aquatic 

exposure assessment.

Field dissipation studies with a granular formulation suggest that triallate dissipated with DT50s

of 20-190 days in six U.S. locations (ID 60 days, SD 20 days, MT 30 days, ND 50 days, KS 85 

days, and WA 190 days). In five of the six locations, the half-life was 85 days or less. Factors 

contributing to the rate of dissipation include volatilization, soil binding, and how favorable 

conditions are for microbial growth.

Table 5-1. Physical, Chemical and Environmental Fate Properties of Triallate and its 

Major Environmental Degradate (TCPSA)
7

Property Value Source & Study 

Classification

PARENT

Common name Triallate US EPA, 2001

CAS Registry No. 2303-17-5

PC Code 078802

Chemical name (CAS) S-(2,3,3-trichloro-2-propenyl)bis(1-methylethyl)

carbamothioate

Class thiocarbamate

SMILES notation CC(C)N(C(C)C)C(=O)SCC(CL)=C(CL)CL EPI Suite, v3.12 

SMILES

IUPAC name S-2,3,3-tricloroallyl di-isopropylthiocarbamate IUPAC

Synonyms None Identified.

Structure EPI Suite, v3.12

Molecular formula C10H16C13NOS US EPA, 2001

Physical and Chemical Properties

Molecular weight 304.66 USEPA, 2001

Physical state Amber or white crystalline solid

Vapor pressure 1.2 x 10-4 mm Hg 

Henry’s Law constant 1.2 x 10-5 atm x m3/mol

Specific gravity/density 1.38g/cm3 @ 20oC MRID 44731803

Acceptable

Solubility in water 4 mg/L @ 25oC USEPA, 2001

log Kow 4.55

Laboratory Volatility 3.6 E-03 (μg/cm2-hr) MRID 42651101 

Acceptable

Laboratory accumulation in fish

bioaccumulation factor (BCF)

670x in edible tissues

2700x non-edible (viscera) tissues

1600x for whole body

MRID 41497601

Supplemental
8

Property Value Source & Study 

Classification

Depuration half-life 14 days 

Environmental Fate Properties

Hydrolysis half-life Stable at pH 4, 6, 7, and 8, MRID 00144567

Acceptable

Photolysis half-life in water Stable MRID 00144567

MRID 41541301

Acceptable

Photolysis half-life in soil Stable MRID 41892301

Acceptable

Aerobic soil metabolism half-life 18 days (Silt loam) @ 30°C

No major degradates detected except CO2

MRID 00144567

Acceptable

Encapsulated Formulated Product

45 days (Silt loam) @ 30°C

Unencapsulated Formulated Product

49 days (Silt loam) @ 30°C

No major degradates

Minor degradates-TCPSA (3.4% @ day 31)

MRID 44611302

Supplemental

37 days (clay loam) @ 20°C

57 days (sandy loam 1) @ 20°C

60 days (sandy loam 2) @ 20°C

58 days (silty clay loam) @ 20°C

98 days (sandy loam 1) @ 10°C

Major Degradates

No major degradates detected except CO2. 

Minor Degradates

3.74% TCPSA @ Day 120

5 unidentified degradates @ Day 120

MRID 44715601 

Supplemental

Anaerobic soil metabolism half-life Stable MRID 00144567

MRID 44611302

Supplemental

Aerobic aquatic metabolism half-life 

for total system

74 days (Total system-Sandy loam) @ 20°C

64 days (Total system-Clay loam) @ 20°C

14 days (Sterile deionized water) @ 20°C

5 days (Sterile deionized water) @ 26°C

4-25 days (water s/naturally suspended solids) @ 

20°C to 26°C

MRID 44715501

Supplemental

MRID 44715502

Supplemental
9

Property Value Source & Study 

Classification

TCPSA and other more polar, unidentified, 

triallate degradates (< 4%) were reported to be 

detected in river water and sediment. 

Soil adsorption coefficient 

Koc (L/kg)

Adsorption

Kads

19 (silt loam)

35 (silty clay loam)

24 (sandy loam)

5.3 (sandy loam)

Koc (ml/g) (calculated)

2730 (silt loam)

1775 (silty clay loam)

1724 (sandy loam)

1305 (sandy loam)

MRID 00144567

(Acceptable)

Terrestrial field dissipation half-life Six U.S. Locations

60 days (ID)

20 days (SD)

30 days (MT)

50 days (ND)

85 days (KS)

190 days (WA)

MRID 00145426

(Acceptable)

6 Receptors

Summaries of the submitted toxicity data used to characterize the toxicity of triallate to terrestrial 

and aquatic organisms are provided in Table 6-1. 

Triallate is practically non-toxic to water-fowl and upland game birds on acute oral and subdietary basis; practically non-toxic to adult honey bees on an acute contact and oral basis; 

slightly toxic to mammals on an acute oral basis; moderately toxic to earthworm; and very highly 

toxic to freshwater fish and freshwater invertebrates on an acute basis. Triallate was reported to 

form CO2 as a sole major degradate. A minor degradate, TCPSA, is of concern for drinking 

water exposure. The eco-toxicity data for TCPSA were not submitted. The estimated toxicity by 

the ECOSAR shows that the TCPSA is much less toxic than the parent triallate (Appendix C). 

Therefore, TCPSA is not considered as a stressor of the concern in this ecological risk 

assessment. 
10

Table 6-1. Summary of Endpoints from Toxicity Studies with Triallate 

Study Type Test Substance

(% a.i.)

Species Toxicity Endpoints and

Acute Toxicity Classification (If Applicable)

Source & Study 

Classification

Avian acute oral:

5-week observation 

Triallate 

Technical

(95.1)

Bobwhite quail

(Colinus virginianus)

LD50 = 2,251 mg a.i./kg-bw (95% C.I.:1,792-2,828)

LOAEL = 398 mg a.i./kg-bw (the lowest dose)

NOAEL < 398 mg a.i./kg-bw

(A dose related decline in body weights were observed in all test 

concentrations. Signs of general toxicity include lethargy, 

reduced reaction to external stimuli and depression, loss of 

coordination head tremors, strong dorsal flexion of the head and 

convulsions) 

Practically non-toxic

MRID 00083035

Acceptable

NA Passerine species No data NA

Avian sub-acute 

dietary: 8-day 

observation

Triallate 

Technical

(96.3)

Bobwhite quail

(Colinus virginianus)

LD50 > 5,620 mg a.i./kg-diet

LOAEL = 5,620 mg a.i./kg-diet 

(One bird displays head curling and somersaulting from Day 1 to 

Day 12. Weight reduction is observed at the 5620 ppm treatment 

group at Day 5)

Practically non-toxic

MRID 40370609

Acceptable

Avian sub-acute 

dietary: 8-day 

observation

Triallate 

Technical

(98.26)

Mallard duck

(Anas platyrhynchos)

LC50 > 5,620 mg a.i./kg-diet 

LOAEC = 1,780 mg a.i./kg-diet

(Reviewer reported a body weight reduction in 1,780, 3,160 and 

5,620 ppm concentrations and a reductions in feed consumption at 

the 3,160 and 5,620 ppm concentrations). 

Practically non-toxic

MRID 40730609

Acceptable

Avian reproduction: 

22 weeks

(chronic)

Triallate 

Technical

(98.26)

Bobwhite quail

(Colinus virginianus)

LOAEC = 500 mg a.i./kg-diet 

NOAEC = 200 mg a.i./kg-diet

(Most sensitive endpoints: Adult male bodyweight)

MRID 44700701 

Acceptable

Mammalian acute 

oral; 14-day 

observation

Triallate 

Technical

(90.16 %)1

Rat

(Rattus norvegicus)

LD50 > 1,100 mg a.i./kg-bw (95% C.I.:900 – 1,300)

NOAEL: not determined

MRID 00109746

Acceptable
11

Study Type Test Substance

(% a.i.)

Species Toxicity Endpoints and

Acute Toxicity Classification (If Applicable)

Source & Study 

Classification

Mammalian acute 

oral, 15-day 

observation

Triallate 

Technical

( 96.84 )

Rat

(Rattus norvegicus)

LD50 = 3,382 mg a.i./kg-bw (combined), (male = 3,612 and 

female = 3,445 mg a.i./kg-bw)

NOAEL: not determined

MRID 44660701

Acceptable

Mammalian 2-

generation 

reproduction 

(chronic)

Triallate 

Technical

(94.5)

Rat

(Rattus norvegicus)

Parental, systemic toxicity

LOAEC = 30 mg a.i./kg-bw/day

NOAEC = 7.5 mg a.i./kg-bw/day)

(reduced pregnancy and shortened gestation)

MRID 00144308

MRID 00132880 

Acceptable

Earthworm Triallate 

Technical

(96.84)

(Eisenia foetida) LC50 = 548 mg a.i./Kg soil

LOAEL =270 mg a.i./Kg soil

(adverse effects on earthworm populations at LOAEL)

Moderately toxic

MRID 44581701

Supplemental

Honey bee acute 

contact: single dose, 

48-hour observation

Triallate 

Technical

(97.1)

Adult honey bee

(Apis mellifera)

LD50 > 25 μg a.i./bee

NOAEL = 25 μg a.i./bee

Practically non-toxic

MRID 42304301

Acceptable

Honey bee dietary 

LC50 Study, 48-hour 

observation

Triallate 

Technical

(96)

Adult honey bee

(Apis mellifera)

LC50 > 1000 ppm 

 or > 292 μg a.i./bee (1000 μg a.i./g x 0.292 g/day) 

NOAEC = 63 ppm

 or = 18.4 μg a.i./bee (63 μg a.i./g x 0.292 g/day)

MRID 44700801

Acceptable

Honey bee chronic 

oral toxicity

NA Adult honey bee

(Apis mellifera)

NA NA

Honey bee larval 

acute and chronic 

oral toxicity

NA Larval bee

(Apis mellifera)

NA NA

Terrestrial plant 

seedling emergence: 

Tier II 

Triallate 

Technical

(97.67)

Most sensitive dicot: 

Cucumber

EC50 =0.5 lb a.i./A

EC25 =0.18 lb a.i./A

LOAEC = 0.17 lb a.i./A

NOAEC = 0.056 lb a.i./A

The most sensitive parameter: plant dry weight

MRID 42471801

Acceptable 

Most sensitive 

monocots: Oat

EC50 =0.033 lb a.i./A

EC25 =0.020 lb a.i./A

LOAEC = 0.019 lb a.i./A

NOAEC = 0.010 lb a.i./A
12

Study Type Test Substance

(% a.i.)

Species Toxicity Endpoints and

Acute Toxicity Classification (If Applicable)

Source & Study 

Classification

The most sensitive parameter: plant dry weight

Terrestrial plant

vegetative vigor: 

Tier II, 21 days 

Triallate 

Technical

(97.67)

Most sensitive dicot: 

Cucumber

EC50 = 0.18 lb a.i./A

EC25 = 0.072 lb a.i./A

LOAEC > 0.17 lb a.i./A

NOAEC = 0.056 lb a.i./A

Most sensitive parameter: plant dry weight

MRID 42471701

Acceptable

Most sensitive monocot: 

Oat

EC50 = 0.12 lb a.i./A

EC25 = 0.033 lb a.i./A

LOAEC > 0.019 lb a.i./A

NOAEC = 0.010 lb a.i./A

Most sensitive parameter: plant dry weight

Freshwater fish 

acute: 96 hours, 

flow-through 

Triallate 

Technical

(92.7)

Bluegill sunfish 

(Lepomis macrochirus)

LC50 = 1,330 μg a.i./L (95% C.I.:710-1,400)

NOAEC < 270 μg a.i./L

(NOAEC based on signs of toxicity including paralysis, dark 

pigmentation and lethargy, and loss of equilibrium)

Moderately toxic

MRID 00083641

Acceptable

Triallate 

Formulated 

Product (46.5)

Bluegill sunfish 

(Lepomis macrochirus)

LC50 = 2,400 μg a.i./L (95% C.I.:1,800 -3,200) 

NOAEC: N/A

MRID 00076890

Acceptable

Triallate 

Technical

(96.95)

Rainbow trout 

(Oncorhynchus mykiss)

LC50 = 1,200 μg a.i./L (95% C.I.:960-1,500)

NOAEC = 560 μg a.i./L

(loss of equilibrium and surfacing)

Moderately toxic

MRID 00029469 

Acceptable

Triallate 

Formulated 

Product (46.5)

Rainbow trout 

(Oncorhynchus mykiss)

LC50 = 1,500 μg a.i./L (95% C.I.:1,000 -3,200) 

NOAEC: N/A

MRID 00076889

Acceptable

Freshwater fish early 

life stage: 88 days, 

flow-through 

(chronic)

Triallate 

Technical

(96.84)

Rainbow trout 

(Oncorhynchus mykiss)

LOAEC = 78 μg a.i./L

NOAEC = 38 μg a.i./L

Most sensitive endpoint: growth (31 day post-hatch length, dry 

weight and wet weight). 

MRID 44660901

Acceptable
13

Study Type Test Substance

(% a.i.)

Species Toxicity Endpoints and

Acute Toxicity Classification (If Applicable)

Source & Study 

Classification

Freshwater 

invertebrate acute: 

48 hours, flowthrough 

Triallate 

Technical

(95.53)

Water flea 

(Daphnia magna)

EC50 = 91 μg a.i./L (95% C.I.:79-103) 

NOAEC = 43 μg a.i./L 

Very highly toxic

MRID 41895601 

Acceptable 

Triallate 

Technical

(96.95)

Water flea 

(Daphnia magna)

LC50 = 430 μg a.i./L (95% C.I.:380-490) 

NOAEC = 180 μg a.i./L 

Highly toxic 

MRID 00029470 

Acceptable 

Freshwater 

invertebrate life 

cycle: 21 days, flowthrough (chronic)

Triallate 

Technical

(97.2)

Water flea 

(Daphnia magna)

EC50 > 56 μg a.i./L 

LOAEC =28 μg a.i./L 

NOAEC = 14 μg a.i./L 

(EC50 based on immobility; LOAEC and NOAEC based on total 

length). 

MRID 45775401

Acceptable

Benthic invertebrate NA NA No data NA

Aquatic vascular 

plant: 7 days, staticrenewal

Triallate 

Technical

(97.2)

Duckweed

(Lemna gibba)

EC50 (.) = 2400 μg a.i./L (95% C.I: 16-27) 

LOAEC = 2100 μg a.i./L 

NOAEC = 1100 μg a.i./L 

(NOAEC based on reduction in frond number)

MRID 45653205

Acceptable

Aquatic nonvascular plant: 

96 hours, static

Triallate 

Technical

(97.2)

Marine Diatom

(Skeletonema costatum)

EC50 = 330 μg a.i./L (95% C.I :260 – 400) 

LOAEC = 180 μg a.i./L 

NOAEC = 73 μg a.i./L 

(Most sensitive endpoint: the area under the growth curve)

MRID 45653204

Acceptable

Triallate 

Technical

(97.2)

Freshwater Diatom

(Navicula pelliculosa)

EC50 = 1300 μg a.i./L (95% C.I :1,200 – 1,300) 

LOAEC = 1140 μg a.i./L 

NOAEC = 538 μg a.i./L

(based on biomass) 

MRID 45653203

Acceptable

Triallate 

Technical

(97.2)

Green alga

(Selenastrum 

capricornutum)

EC50 = 21 μg a.i./L (95% C.I.: 0.018-0.023)

LOAEC = 13 μg a.i./L 

NOAEC = 6.31 μg a.i./L 

(based on reduction in cell density)

MRID 45653201

Acceptable

Triallate 

Technical

(96.4)

Green alga

(Selenastrum 

capricornutum)

EC50 = 140 μg a.i./L (95% C.I.: 120-170) 

NOAEC = 32 μg a.i./L 

(Biomass, rather than cell density, was used to assess the response 

of the alga to the test material)

MRID 44700901

Supplemental

C.I. = confidence interval; NA = not applicable; 

1 The % a.i. is calculated by 1.1g a.i./kg / 1.22g/kg x 100 = 90.16 % a.i.
14

6.1 Ecological Incidents

The ecological incident information system (EIIS) is an OPP database for ecological incidents 

that have been reported to the Agency. When available, EIIS includes date and location of an 

incident, type and magnitude of effects observed in various species, use(s) of pesticides known 

or suspected of contributing to the incident, and results of any chemical residue analysis or other 

analyses conducted during the incident investigation. EIIS incidents are categorized according to 

the certainty that the incident resulted from pesticide exposure. The Avian Monitoring System 

(AIMS)

1

is a database administered by the American Bird Conservancy that contains publicly 

available data on reported avian incidents involving pesticides. A review of the EIIS (version 

2.1.1) on March 16, 2014 found four cases of crop damage incidents from 1993 – 2000 related to 

triallate application on wheat and spring wheat, and with one case of possible accidental 

carryover that may not be considered further (Table 6-1). A review of AIMS on May 16, 2014

did not yield any reported ecological incidents associated with the use of triallate. 

Table 6-1. Triallate Incidents Identified in the EIIS Database

Incident 

Number

Organism Description Legal Other 

Chemicals 

Involved

Caused By 

Triallate?

I003629-

006

Spring wheat Plant damage in all direct 

treatment area

Registered 

use

No Probable

I000360-

013

Spring wheat 75 acres plant damage Registered 

use

No Possible

I000360-

003

Wheat Unspecified acreage plant 

damage 

Registered 

use

No Possible

I003629-

011

Wheat Plant mortality in direct 

treatment area 

Registered 

use

No Probable

I010927-

020

Wheat 240 acres plant damage 

by accidental carryover

Misuse No Possible

Additional incidents are reported to the Agency’s Incident Data System2by pesticide registrants 

as aggregate counts of incidents occurring per product per quarter. Ecological incidents reported 

in aggregate reports include those categorized as ‘minor fish and wildlife’, ‘minor plant’, ‘other 

non-target’ incidents’, ‘drinking water’, ‘surface water’, ‘groundwater’ and ‘domestic animal’. 

‘Other non-target’ incidents include reports of adverse effects to insects and other terrestrial 

invertebrates. For triallate, registrants have reported two groundwater contamination incidents in 

2000 as of a review on May 16, 2014. 

The total number of actual incidents associated with the use of triallate may be higher than what 

is reported to the Agency. Incidents may go unreported since effects may not be immediately 

apparent and/or readily attributed to the use of a chemical. Therefore, a lack of reported 

incidents should not be taken as an indicator of little or no ecological risk. The reported 

incidents suggest possible adverse effects to the crop and contamination to ground water for 

triallate field application. Even though the specific cause for the incidents was not identified, the 

uncertainty and data gap exists for the registration review risk assessment. 

____________________________________________ 

1http://www.abcbirds.org/abcprograms/policy/toxins/aims/aims/login.cfm?CFID=180204405&CFTOKEN=48160013

2https://w2032pcctr563.aa.ad.epa.gov:8500/IDS/index
15

7 Exposure Pathways of Concern

The environmental fate properties and use patterns of triallate indicate that direct spray, spray 

drift, leaching to ground water, and runoff represent potential transport mechanisms of triallate to 

aquatic and terrestrial organisms. 

Drinking water and inhalation exposure pathways were screened using the SIP (Screening 

Imbibition Program) and STIR (Screening Tool for Inhalation Risk) screening methods and were 

found to be exposure pathways of low concern (no LOC exceedances are expected; see 

Appendix D). SIP and STIR are described in detail at: 

http://www.epa.gov/oppefed1/models/terrestrial/index.htm.

8 Analysis Plan

8.1 Stressors of Concern

8.1.1 Ecological Risk Assessment

The stressor of concern for both aquatic and terrestrial organisms is parent triallate only. The 

degradate TCPSA is not a concern because it becomes a much less toxic acid after the loss of the 

carbamate moiety, based on the ECOSAR estimation of the relative toxicity (Appendix C). 

 

8.1.2 Drinking Water Exposure Assessment

An EFED drinking water assessment was conducted for Bermuda grass grown for seed to 

establish tolerances of triallate and its degradate TCPSA for human health risk assessment 

(USEPA 2008; DP358774). Recommended Estimated Drinking Water Concentrations (EDWCs) 

were modeled for TTR of triallate and its degradate TCPSA. EFED will conduct a drinking 

water assessment to support future human health dietary risk based on a TTR assessment of 

triallate and TCPSA. The drinking water assessment will be performed based on EFED’s current 

guidance using appropriate surface and groundwater models. Descriptions of all executable 

versions of current models for drinking water exposure can be obtained from URL link. 

http://www.epa.gov/oppefed1/models/water/

8.2 Measures of Exposure

EFED will use standard available models to evaluate potential exposures of triallate to aquatic 

and terrestrial organisms as described at http://www.epa.gov/pesticides/science/models_db.htm. 

The latest developed and approved models, such as the surface water calculator (SWCC), will 

also be used. 

8.2.1 Available Monitoring Data
16

The Agency is aware of monitoring conducted by federal and state agencies such as U.S. 

Geological Survey (USGS) National Water Quality Assessment (NAWQA) Data Warehouse and 

California Environmental Data Exchange Network (CEDEN). This route of exposure will be 

considered in the assessment to the extent that data on triallate are available.

8.3 Measures of Effect

Toxicity data presented in Section 6 of this problem formulation will be used to calculate risk 

quotients. Any additional information submitted by the registrant or found in the open literature 

prior to conducting the risk assessment will also be considered. The open literature studies are 

identified using EPA’s ECOTOXicology database (http://cfpub.epa.gov/ecotox/), which employs 

a literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, 

and wildlife. The evaluation of both sources of data can also provide insight into the direct and 

indirect effects of pesticides on biotic communities from the loss of species that are sensitive to 

the chemicals and from changes in structure and functional characteristics of the affected 

communities.

9 Endangered Species Assessments

Consistent with the Agency’s responsibility under the Endangered Species Act (ESA), the 

Agency will evaluate risks to federally listed (threatened and/or endangered) species from 

registered uses of pesticides in registration review. The process for evaluating potential risks to 

listed species is further described at 

http://www.epa.gov/oppfead1/endanger/litstatus/riskasses.htm.

10 Endocrine Disruptors Screening Program

Triallate was not included in the first group of 67 chemicals nor the second group of 109 

chemicals that will or have been issued an order to conduct Tier 1 EDSP testing. For additional 

information on the EDSP program, visit http://www.epa.gov/endo/. 

11 Preliminary Identification of Data Gaps

11.1 Environmental Fate

Table 11-1 identifies environmental fate studies that offer data for each guideline requirement 

and whether or not further data are needed to support a risk assessment. There are no 

environmental fate studies available for triallate degradate TCPSA which will be included in the

drinking water assessment. If any empirical environmental fate data related to TCPSA are 

available, agency encourages the registrant to provide them during the comment period. 

Additional environmental fate and physicochemical properties of TCSPA can reduce the 

uncertainties for drinking water assessments. In the absence of physicochemical and 

environmental fate data of TCPSA, the Estimation Programs InterfaceSuiteTM (EPI SuiteTM) will 

be used to estimate fate parameters. EPI SuiteTM is a Windows®-based suite of physical/chemical 
17

property and environmental fate estimation programs developed by the EPA’s Office of 

Pollution Prevention Toxics and Syracuse Research Corporation (SRC). 

Table 11-1. Submitted Environmental Fate Data for Triallate

OCSPP 

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Study 

Classification

Are data 

needed to 

conduct risk 

assessment?

Justification and Assumptions 

EPA will Make in Absence of 

Data 

835.2120 Hydrolysis 00144567 Acceptable No ---

835.2240 Aqueous 

photolysis

41541301 Acceptable No ---

835.2410 Soil photolysis Registration 

Summary 

(00086400)

Acceptable No ---

835.4100 Aerobic soil 

metabolism

00144567

44611302

44715601

Acceptable

Supplemental

Supplemental

No ---

835.4200 Anaerobic soil 

metabolism

Add MRID 

for the one 

study you do 

have

Supplemental No OCSPP guidance recommends 

that these tests be performed with 

radio labelled TGAI/PAIRA for 

four soils. One anaerobic soil 

metabolism study has been 

submitted with formulated 

products and is classified as 

supplemental for risk assessment. 

Additional data are required 

under 40 CFR Part 158 for 

terrestrial outdoor uses. 

Additional data are considered 

to have a low potential to add 

value to exposure assessments 

for the ecological risk and 

drinking water in presence of 

anaerobic aquatic metabolism 

(835.4200).

835.4300 Aerobic aquatic 

metabolism

44715501

44715502

Supplemental No ---

835.4400 Anaerobic 

aquatic 

metabolism

No Data --- Yes Data are required under 40 CFR 

Part 158. OCSPP guidance 

recommends that these tests be 

performed with two sediments. 

The assumption of compound 

stability will be made in the 

absence of acceptable data.

835.1230

835.1240

Adsorption/ 

desorption and 

leaching

00144567 Acceptable No ---

835.1410 Volatility –

laboratory

42651101

46186001

Acceptable No ---
18

OCSPP 

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Study 

Classification

Are data 

needed to 

conduct risk 

assessment?

Justification and Assumptions 

EPA will Make in Absence of 

Data 

835.6100 Terrestrial field 

dissipation

 00145426 Acceptable No ---

850-6100 Analytical 

method in soil

40117901 Invalid Yes Environmental chemistry method 

(ECM) and independent 

laboratory validations (ILV) for 

soil and water are required for 

triallate and its degradate,

TCPSA

Analytical 

method in water No Data -- Yes

165-4 

(850.1730)

Fish 

bioconcentration

41497601 Supplemental No --

11.2 Ecological Effects

For triallate, there are no data available for acute oral toxicity to a passerine species, acute 

dietary (oral) toxicity to larval honey bees, chronic oral toxicity to adult and larval honey bees 

and chronic toxicity to benthic invertebrates. There are no toxicity data available for 

estuarine/marine fish and invertebrates. Tables 11-2 and 11-3 identify ecological effects studies 

that offer data for each guideline requirement and whether or not further data are needed in order 

to support risk assessment. In the absence of these data, the risk to the above organisms cannot 

be precluded and other lines of evidences may be used to estimate the potential risks as listed in 

the justification and assumption column in the tables. 

11.2.1 Justification for 10-day Adult Chronic Toxicity Study

Bees can be exposed to pesticides through multiple pathways including contact with sprays and 

dusts and through ingestion of residues in food/water (e.g., pollen/nectar and water used to 

maintain colony temperature). Worker bees foraging on flowers for pollen and nectar can be 

repeatedly exposed to residues in pollen and nectar either through direct contamination of these 

matrices by foliar sprays. Residues can in turn be brought back to bee colonies where in-hive 

bees including young adult and developing brood (i.e., eggs, larvae and pupae) may be exposed. 

EPA guidance (USEPA 2014b) on assessing the risk of pesticides to bees identifies a suite of 

laboratory-based studies intended to serve as the foundation for screening chemicals for potential 

acute and chronic exposure effects to individual adult and larval bees. The 10-day toxicity study 

with young adult bees provides no-observed adverse effect level (NOAEL) and lowest-observed 

adverse effect level (LOAEL) for assessing chronic effects. Data obtained from this study will be 

used in estimating chronic risk to individual adult bees. This is a non-guideline study; an OECD 

protocol is expected to be available in October 2014. A protocol should be submitted to the 

Agency for review before commencing the study and should include provisions for measuring 

the concentration of triallate in the actual diet of the honeybee.

11.2.2 Justification for 21-day Larval Toxicity Study
19

Developing bee brood (i.e., larvae and pupae) can be exposed to pesticides through residues 

brought back to the colony by worker bees foraging in areas where the pesticide has been 

applied. While larvae are typically fed royal or brood jelly during their early stages of 

development, worker bee (females) and drone (males) larvae are also fed pollen/honey (bee 

bread) directly by in-hive nurse bees. EPA guidance (USEPA 2014b) on assessing the risk of 

pesticides to bees identifies a suite of laboratory-based studies intended that serve as the 

foundation for screening chemical for potential acute and chronic effects to individual adult and 

larval bees. The 21-day larval toxicity study under development by OECD provides both acute 

and chronic toxicity data on developing bee brood and will yield a median lethal dose (LD50) for 

assessing acute toxicity during the early part of the study as well as a 21-day no-observed 

adverse effect level (NOAEL) and lowest-observed adverse effect level (LOAEL) for assessing 

chronic effects. Alternatively, registrants may submit a separate acute (single dose) larval 

toxicity study following OECD Guideline 237 as well as the 21-day repeat dose chronic toxicity 

study to address both acute and chronic larval endpoints. Effects on survival and development 

(adult bee emergence) from repeat exposures to the active ingredient will be used in estimating 

chronic risk to individual brood. A protocol for the 21-day larval toxicity test should be 

submitted to the Agency for review before commencing the study and should include provisions 

for measuring the concentration of triallate in the actual diet of the honeybee.

________________________________________________

Draft guidance for the 21-day larval toxicity study is available at: 

http://www.oecd.org/env/ehs/testing/Draft_GD_honeybees_rep_exp_for_2nd_CR_25_November_2013.pdf

OECD Guideline 237 is available at: http://www.oecdilibrary.org/docserver/download/9713171e.pdf?expires=1407449911&id=id&accname=guest&checksum=E67BED

EB01DB12D815E858CB45A989FB
20

Table 11-2. Submitted Aquatic Ecological Effects Data for Triallate

OCSPP 

Guideline

Data 

Requirement

Source

MRID

Classification Are Data 

Needed to 

Conduct the 

Risk 

Assessment?

Justification and Assumptions EPA Will Make in the Absence of Data 

850.1010 Freshwater 

invertebrate 

acute toxicity

41895601

00029470

Acceptable No --

850.1035 Saltwater 

invertebrate 

acute toxicity

No data NA Yes Saltwater invertebrate (mysid) acute toxicity data are required under 40 CFR Part 

158 because the product is expected to enter the environment. 

In the absence of the data, surrogate thiocarbamate herbicides – starting with data 

for closely related pesticides and proceeding to data for less related pesticides –

may be used to characterize the triallate impact to saltwater invertebrates. 

850.1025

850.1045

850.1055

Saltwater 

invertebrate 

acute toxicity 

No data NA Yes Saltwater invertebrate acute toxicity data are required under 40 CFR Part 158 

because the product is expected to enter the environment. An invertebrate 

mollusk (oyster, penaeid or bivalve) test may be selected. 

In the absence of the data, surrogate thiocarbamate herbicides – starting with data 

for closely related pesticides and proceeding to data for less related pesticides –

may be used to characterize the triallate impact to saltwater invertebrates.

850.1075 Freshwater fish 

acute toxicity 

00029469

(cold water)

Acceptable No --

00076889

(cold water)

Formulated 

Product

Acceptable

00083641

(warm water)

Acceptable

00076890

(warm water)

Formulated 

Product

Acceptable

850.1075 Saltwater fish 

acute toxicity 

No data NA Yes Saltwater fish acute toxicity data are required under 40 CFR Part 158 if the 

product is expected to enter the environment, (recommend the same saltwater fish 

species for acute and chronic studies). 
21

OCSPP 

Guideline

Data 

Requirement

Source

MRID

Classification Are Data 

Needed to 

Conduct the 

Risk 

Assessment?

Justification and Assumptions EPA Will Make in the Absence of Data 

In the absence of the data, surrogate thiocarbamate herbicides – starting with data 

for closely related pesticides and proceeding to data for less related pesticides –

may be used to characterize the triallate impact to saltwater fish.

850.1300 Freshwater 

invertebrate 

life cycle 

45775401 Acceptable No --

850.1350 Saltwater 

invertebrates 

life cycle 

No data NA Yes Saltwater invertebrate life cycle data are conditionally required under 40 CFR Part 

158 if the product is expected to enter the environment. 

In the absence of the data, surrogate thiocarbamate herbicides – starting with data 

for closely related pesticides and proceeding to data for less related pesticides –

may be used to characterize the triallate impact to saltwater invertebrate life cycle.

850.1400 Freshwater fish 

early-life stage

44660901 Acceptable No --

850.1400 Saltwater fish 

early-life stage 

No data NA Yes Saltwater fish early-life stage data are conditionally required under 40 CFR Part 

158 if the product is expected to enter the environment, (recommend the same 

saltwater fish species for acute and chronic studies).

In the absence of the data, surrogate thiocarbamate herbicides – starting with data 

for closely related pesticides and proceeding to data for less related pesticides –

may be used to characterize the triallate impact to saltwater fish early-life stage.

NonguidelineWhole 

sediment 

invertebrates 

chronic toxicity 

No data NA Yes Chronic sediment invertebrate toxicity data are required under 40 CFR Part 158 

if: 

i. the half-life of the pesticide in sediment if > 10 days in either the aerobic soil 

or aquatic metabolism studies and if any of the following exist:

A. The soil partition coefficient (Kd) is ≥ 50

B. The log Kow is ≥ 3.

C. The Koc is ≥ 1,000.

The half-life of triallate in aerobic aquatic metabolism studies ranges from 64 to 

74 days; the log Kow of triallate is 4.55; and the Koc’s range from 1305 (sandy 

loam) to 2730 (silty loam). 

Because the triallate is likely to be persistence in the sediment, chronic sediment 

tests with the midge Chironomus dilutus, freshwater amphipod Hyalella azteca, 

and estuarine/marine amphipod Leptocheirus plumulosus are needed. 
22

OCSPP 

Guideline

Data 

Requirement

Source

MRID

Classification Are Data 

Needed to 

Conduct the 

Risk 

Assessment?

Justification and Assumptions EPA Will Make in the Absence of Data 

As indicated in 40 CFR Part 158, the registrant is required to submit a protocol for 

approval prior to initiating the study until such time as the OCSPP 850 chronic 

sediment testing guidelines are published. 

In the absence of the data, we will not preclude the risk to the sediment-dwelling 

invertebrates. If it is possible, other chronic toxicity data for surrogate 

thiocarbamate herbicides – starting with data for closely related pesticides and 

proceeding to data for less related pesticides – may be used to characterize the 

chronic toxicity of triallate to sediment-dwelling invertebrates. 

850.4400 Aquatic plant 

toxicity test 

using Lemna

spp.

45653205 Acceptable No --

850.4500 Algal toxicity 45653201

44700901

(green alga)

Acceptable

Supplemental

No --

45653204

(marine 

diatom)

Acceptable

45653203

(freshwater 

diatom)

Acceptable

850.4550 Cyanobacteria 

toxicity

No data

(blue-green 

alga)

NA Yes Cyanobacteria toxicity data are required under 40 CFR Part 158

In the absence of the data, blue-green alga data for surrogate thiocarbamate 

herbicides – starting with data for closely related pesticides and proceeding to 

data for less related pesticides – may be used to characterize the triallate impact to 

cyanobacteria. 

NA = not applicable
23

Table 11-3. Submitted Terrestrial Ecological Effects Data for Triallate

OCSPP 

Guideline

Data 

Requirement

Source

MRID

Classification Are Data 

Needed to 

Conduct the 

Risk 

Assessment?

Justification and Assumptions EPA Will Make in the Absence of Data 

850.2100 Avian oral 

toxicity

00083035

(upland game)

Acceptable No Acute oral toxicity data for a passerine species are required under the new 40 

CFR Part 158. A study has not been submitted for this data requirement. 

A guideline-compliant passerine acute oral toxicity test is needed. Acute oral 

toxicity data are only available for one avian species (i.e., bobwhite quail). 

Passerine birds may utilize metabolic pathways that are different from larger 

birds and therefore be more sensitive to triallate. Furthermore, passerines 

exhibit behavioral responses to pesticide dosing that are potential indicators of 

reduced fitness in the field (e.g., regurgitation of contaminated diet) even when 

direct biochemically-mediated lethal toxicity is not apparent. 

In the absence of the data, passerine toxicity data for surrogate thiocarbamate 

herbicides – starting with data for closely related pesticides and proceeding to 

data for less related pesticides – may be used to characterize the acute toxicity 

of triallate to passerine species.

No data

(passerine)

NA Yes

850.2200 Avian dietary 

toxicity 

40370609

(upland game)

Acceptable No --

40730609

(waterfowl)

Acceptable

850.2300 Avian 

reproduction

44700701 

(upland game)

Acceptable No Data (TGAI) are required on a waterfowl bird species to support all outdoor 

end-use product uses under the 40 CFR Part 158. A study has not been 

submitted for this data requirement. A guideline-compliant waterfowl 

reproduction is needed. 

In the absence of the data, the upland game bird may be used as surrogate 

species or other thiocarbamate herbicides – starting with data for closely related 

pesticides and proceeding to data for less related pesticides, may be used as 

surrogate pesticide to characterize the reproduction effects of triallate to 

waterfowl species.

No data

(waterfowl)

NA Yes
24

OCSPP 

Guideline

Data 

Requirement

Source

MRID

Classification Are Data 

Needed to 

Conduct the 

Risk 

Assessment?

Justification and Assumptions EPA Will Make in the Absence of Data 

850.3020 Honey bee acute 

contact toxicity

42304301 Acceptable No --

NonguidelineHoney bee acute 

oral toxicity

44700801 Acceptable No The “White Paper in Support of the Proposed Risk Assessment Process for 

Bees” as submitted to the FIFRA Scientific Advisory Panel1 proposes a 

screening-level risk assessment process that includes acute contact with adult 

bees, acute and chronic oral toxicity tests with adult bees and with larval bees. 

Acute oral toxicity data with larval bee and chronic oral toxicity data with adult 

and larval bee are not available. 

Acute and chronic oral toxicity data with larval bee may be collected in a 

combined study. In the absence of these data, larval honey bee oral toxicity 

data for surrogate thiocarbamate herbicides – starting with data for closely 

related pesticides and proceeding to data for less related pesticides – may be 

used to characterize the oral toxicity of triallate to honey bees. 

Honey bee adult 

chronic oral 

toxicity

No data NA Yes

Honey bee 

larval acute oral 

toxicity

No data NA Yes

Honey bee 

larval chronic 

oral toxicity

No data NA Yes

Nonguideline Earthworm 

acute toxicity

44581701 Supplemental No --

850.4100 Seedling 

Emergence and 

Seedling 

Growth

42471801 Acceptable No --

850.4150 Vegetative 

Vigor

42471701 Acceptable No --

NA = not applicable

 

1 http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2012-0543-0004
25

12 References

FAO 2000. Food and Agriculture Organization of the United Nations. FAO PESTICIDE 

DISPOSAL SERIES 8. Assessing Soil Contamination: A Reference Manual. Appendix 2. 

Parameters of pesticides that influence processes in the soil. Editorial Group, FAO 

Information Division: Rome, 2000. 

http://www.fao.org/DOCREP/003/X2570E/X2570E00.htm

Majewski, M..S. and Capel, P.D; Pesticides in the environment: Distribution, Trends, and 

Governing Factors. U.S. Geological Survey. Open-File Report 94-506. National Water 

Quality Assessment Program (1995).

Smith, A.E., Kerr, L.A., and Caldwell, B. Volatility of ethalfluralin, trifluralin, and triallate from 

a field following surface treatments with granular formulations. Journal of Agricultural 

and Food Chemistry. V. 45 (4): 1473-1478 (1997). 

USEPA 2001. Reregistration Eligibility Document for Triallate Environmental Fate and Effects 

Chapter EPA-HQ-OPP-2009-0081. Office of Pesticide Programs, U.S. Environmental 

Protection Agency. March 2001.

USEPA 2009a. Revised Section 3 New Use Registration Request for Triallate (Far-GO) as a 

Bermudagrass Seed Treatment Herbicide. Environmental Fate and Effects Division, 

Office of Pesticide Programs, U.S. Environmental Protection Agency. January 26, 

2009,DPs 351896, 352259, 358774). 

USEPA 2009b. Revised Drinking Water Exposure Assessment to establish tolerances of triallate 

and its degradate 2,3,3-trichloro-2-propenesulfonic acid (TCPSA) on Bermuda grass 

grown for seed. Environmental Fate and Effects Division, Office of Pesticide Programs, 

U.S. Environmental Protection Agency. November 20, 2008, DP 358774).

USEPA 2014a. BEAD Chemical Profile (BCP) for Registration Review: Triallate (078802). 

Biological and Economic Analysis Division, Office of Pesticide Programs, U.S. 

Environmental Protection Agency. May 23, 2014.

USEPA 2014b. Guidance for Assessing Pesticide Risk to Bees. Office of Pesticide Programs, 

USEPA, Health Canada Pest Management Regulatory Agency and California Department 

of Pesticide Regulation. June 23, 2014. 58 pages.

Cited Environmental Fate Studies

41497601 Burgess, D. (1989) Uptake, Depuration, and Bioconcentration of carbon 14|-

Triallate by Bluegill Sunfish (Lepomis macrochirus), Part I. (Part II: MSL9549): Lab Project Number: MSL-9548. Un- published study prepared by 

Monsanto Agricultural Co. 396 p. 
26

00086400 Marvel, J.T.; Henshall, A.; Brightwell, B.B. (1973) Final Report on Avadex 

BW Environmental Studies: Part 3: Photodecomposition Studies (Soil and 

Water) and Leaching through Soil: Agricultural Research Report No. 329. 

(Unpublished study received May 1, 1975 under 524-124; submitted by 

Monsanto Co., Washington, D.C.; CDL:120623-E) 

00144567 Keene, E. (1990) Monsanto Company Phase 3 Summary of MRID 00144567. 

The Environmental Studies of Triallate: Monsanto RD # 618. Prepared by 

Monsanto Agricultural Products Co. 25 p. 

42651101 Shepler, K.; Estigoy, L. (1993) Laboratory Volatility of (carbon 14)-Triallate: 

Lab Project Number: 399W: 1157. Unpublished study prepared by PTRLWest, Inc. 63 p. 

46186001 Shepler, K.; Estigoy, L. (1995) Laboratory Volatility of (Carbon-14) - Triallate. 

Project Number: MSL/12582, 399W, R/D/1625. Unpublished study prepared 

by PTRL West, Inc. 63 p.

44715501 Mackie, J. (1998) The Aerobic Degradation of (carbon 14)-Triallate in Natural 

Sediment/Water Systems: Lab Project Number: 390990: MSL-15172.

Unpublished study prepared by Inveresk Research. 70 p

44715502 Elliot, R.; Klemm, G. (1987) The Aquatic Metabolism of Triallate in Surface 

Water: Lab Project Number: MSL 6162. Unpublished study prepared by 

Monsanto Company. 62 p. 

44715601

40117901

Mackie, J.; Saunders, L. (1998) The Degradation of (carbon 14)-Triallate in 

Soil Under Aerobic Conditions: Lab Project Number: 15908: MSL-15173. 

Unpublished study prepared by Inveresk Research. 88 p. 

Allan, J.M. (1983) Analytical Residue Method for Triallate and the Sodium 

Salt of 2,3,3-trichloroprop-2-ene Sulfonic Acid in Soil. 22 p.

Cited Ecological Effects Studies

00083035 Fink, R.; Beavers, J.B.; Joiner, G.; et al. (1980) Final Report: Acute Oral LD50--

Bobwhite Quail: Project No. 139-184. (Unpublished study received Jan 29, 1981 under 

524-124; prepared by Wildlife International, Ltd. and Washington College, submitted by 

Monsanto Co., Washington, D.C.; CDL:244201-A) 

40730609 Hinken, C.; Grimes, J. (1986) Triallate: A Dietary LC50 Study with the Mallard: Project 

ID. 139-230. Unpublished study prepared by Wildlife International LTD. 24 p. 

40370609 Grimes, J.; Jaber, M. (1986) Triallate: A Dietary LC50 Study with the Bobwhite: 

Project ID. 139-229. Unpublished study prepared by Wildlife International LTD. 24 p. 

44700701 Beavers, J.; McCollough, C.; Jaber, M. (1990) Triallate Technical: A One Generation 

Reproduction Study with the Northern Bobwhite (Colinus virginianus): Lab Project 
27

Number: R.D.1449: WL-88-346: 139-249. Unpublished study prepared by Wildlife 

International Ltd. 94 p. 

00076889 Thompson, C.M.; Griffen, J. (1981) Acute Toxicity of Fargo^(R)I EC (Lot No. TTBW 

12012) (AB-80-525) to Rainbow Trout (Salmo gairdneri): Static Acute Bioassay Report 

# 26962. (Unpublished study, including letter dated Mar 9, 1981 from R.B. Ole- son to 

E.C. Spurrier, received May 18, 1981 under 524-124; pre- pared by Analytical Bio 

Chemistry Laboratories, Inc., submitted by Monsanto Co., Washington, D.C.; 

CDL:245192-A) 

00076890 Thompson, C.M.; Griffen, J. (1981) Acute Toxicity of Fargo (R)I EC (Lot No. TTBW 

12012) (AB-80-526) to Bluegill Sunfish (Lepomis macrochirus): Static Acute Bioassay 

Report # 26963. (Unpublished study, including letter dated Apr 15, 1981 from R.B. 

Ole- son to E.C. Spurrier, received May 18, 1981 under 524-124; pre- pared by 

Analytical Bio Chemistry Laboratories, Inc., submitted by Monsanto Co., Washington, 

D.C.; CDL:245192-B) 

00083641 Morrill, L.H. (1974) Acute Toxicity of Avadex BW to Bluegill (Lepomis macrochirus). 

(Unpublished study received Sep 18, 1978 under 524-124; prepared by Bionomics, EG 

& G, Inc., submit- ted by Monsanto Co., Washington, D.C.; CDL:097416-N) 

00029469 Thompson, C.M.; Forbis, A.D.; Griffen, J.R.; et al. (1979) Acute Toxicity of Triallate 

(AB-79-071) to Rainbow Trout (Salmo) gairdneri): Static Acute Bioassay Report # 

24010. (Unpub- lished study received Mar 4, 1980 under 524-145; prepared by 

Analytical Bio Chemistry Laboratories, Inc. in cooperation with U.S. Fish and Wildlife 

Service, submitted by Monsanto Co., Washington, D.C.; CDL:241961-B) 

00109746 Auletta, C.; Rinehart, W. (1979) Acute Oral Toxicity study in Rats: [Triallate]: Project 

No. 4919-77. (Unpublished study received Oct 16, 1979 under 524-145; prepared by 

Bio/dynamics, Inc., submitted by Monsanto Co., Washington, DC; CDL:241271-J)

00144308 Kier, L.; Ribelin, W. (1984) Triallate Technical: A Two Generation Reproduction Study 

in the Rat: Final Report: Report No. MSL- 3651. Unpublished study prepared by 

Monsanto Co. 1254 p.

44660701 Blaszcak, D. (1998) Acute Oral Toxicity Study in Rats with Triallate: Lab Project 

Number: R.D.1439: 96-1538: HU-96-249. Unpublished study prepared by Huntingdon 

Life Sciences. 84 p

00029470 Thompson, C.M.; Forbis, A.D.; Oleson, F.B. (1979) Acute Toxicity of Triallate 

Technical (AB-79-073) to Daphnia_magna: Static Acute Bioassay Report # 24012. 

(Unpublished study received Mar 4, 1980 under 524-145; prepared by Analytical Bio 

Chemistry Laboratories, Inc., submitted by Monsanto Co., Washington, D.C.; 

CDL:241961-C) 

41895601 McNamara, P. (1990) Triallate-the Chronic Toxicity to Daphnia magna Under Flowthrough Conditions: Lab Project Number: SB-89-122: 1046. Unpublished study

prepared by Springborn Laboratories, Inc. 64 p. 
28

44660901 Drottar, K.; Swigert, J.; Krueger, H. (1998) Triallate: An Early Life-Stage Toxicity Test 

with the Rainbow Trout (Oncorhynchus mykiss): Lab Project Number: 139A-198B: 

WL-96-278: R.D.1438. Unpublished study prepared by Wildlife International Ltd. 85 p. 

45775401 Plantania, S.; Sutherland, C.; Krueger, H. (2002) Triallate: A Flow-Through Life-Cycle 

Toxicity Test with the Cladoceran (Daphnia magna): Final Report: Lab Project 

Number: RD 1590: 139A-284A: WL-2001-165. Unpublished study prepared by 

Wildlife International, Ltd. 65 p. {OPPTS 850.1300} 

42471701 Chetram, R. (1992) Tier 2 Vegetative Vigor Nontarget Phytotoxicity Study Using 

Triallate: Lab Project Number: BL91-482: R.D. 1125: 0612-91-2. Unpublished study 

prepared by Pan-Agricultural Laboratories Inc. 205 p. 

42471801 Chetram, R. (1992) Tier 2 Germination/Seedling Emergence Nontarget Phytotoxicity 

Study Using Triallate: Lab Project Number: BL91-483|: 0612-91-1: R.D. 1126. 

Unpublished study prepared by Pan-Agricultural Laboratories Inc. 219 p. 

44700901 Georgie, L.; Burgess, D.; Forbis, A. (1984) Acute Toxicity of Triallate to Selenastrum 

capricornutum Printz: Lab Project Number: AB-84-409: 32358: 8004. Unpublished 

study prepared by Analytical Bio-Chemistry Labs., Inc. 38 p. 

45653201 Palmer, S.; Kendall, T.; Frueger, H. (2002) Triallate: A 96-Hour Toxicity Test with the 

Freshwater Alga (Selenastrum capricornutum) that Includes a Recovery Phase: Final 

Report: Lab Project Number: 139A-275: WL-2000-252. Unpublished study prepared by 

Wildlife International, Ltd. 63 p. {OPPTS 850.5400} 

45653203 Desjardins, D.; Kendall, T.; Krueger, H. (2002) Triallate: A 96-Hour Toxicity Test with 

the Freshwater Diatom (Navicula pelliculosa): Final Report: Lab Project Number: 

139A-285A: WL-2001-168. Unpublished study prepared by Wildlife International, Ltd. 

56 p. {OPPTS 850.5400} 

45653204 Desjardins, D.; Kendall, T.; Krueger, H. (2002) Triallate: A 96-Hour Toxicity Test with 

the Marine Diatom (Skeletonema costatum): Final Report: Lab Project Number: 139A286: WL-2001-167. Unpublished study prepared by Wildlife International, Ltd. 57 p. 

{OPPTS 850.5400} 

45653205 Desjardins, D.; Kendall, T.; Krueger, H. (2002) Triallate: A 7-Day Static-Renewal 

Toxicity Test with Duckweed (Lemna gibba G3): Final Report: Lab Project Number: 

139A-287: WL-2001-166: Unpublished study prepared by Wildlife International,Ltd. 

53p. {OPPTS 850.4400} 

42304301 Hoxter, K.; Lynn, S. (1992) Triallate: An Acute Contact Study with the Honey Bee: Lab 

Project Number: R. D. 1091. Unpublished study prepared by Eildlife International LTD. 

14 p. 

44700801 Hoxter, K.; Bernard, W.; Beavers, J. (1993) Technical Grade Triallate: A Dietary LC50 

Toxicity Study with the Honey Bee (Apis mellifera): Lab Project Number: WL-92-264: 

RD 1450: 139-339. Unpublished study prepared by Wildlife International Ltd. 17 p. 
29

44581701 Palmer, S.; Sulaiman, M.; Beavers, J. (1998) Triallate: An Acute Toxicity Study with 

the Earthworm in an Artificial Soil Substrate: Lab Project Number: 139-425: WL-96-

310. Unpublished study prepared by Wildlife International Ltd. 61 p. 
Appendix A: Summary of Triallate Labels

Use

Product Name 

/ EPA Reg # Maximum Single 

Application Rate 

(lb a.i./A)

Application 

Timing1

Method of 

Application Allowed Geographical Areas

Winter wheat, 

Winter Barley

Far-GO Herbicide

/ 10163-286

1.5 F

Broadcast, 

ground band 

treatment, 

chemigation

CA, CO, ID, KS, MN, MT, NE, NV, ND, OR, 

SD, UT, WA, WY

Spring Wheat, 

Duram Wheat 1 F or S

Barley 1.5 F or S

Triticale 1.5 F or S

Sugarbeet 1.5 F or S CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, 

UT, WA, WY

Peas, green, 

field dried, 

chickpeas, 

garbanzo beans 1.5 F,S

CA, CO, ID, KS, MN, MT, NE, NV, ND, OR, 

SD, UT, WA, WY

Lentils 1.5 F,S

Spring Wheat, 

Duram Wheat 1 S

Barley 1.5 S

Triticale 1.5 S

Spring Wheat, 

Barley 1.52 F

Winter Wheat 1.25 F

Spring Wheat, 

Durham Wheat, 

Barley 1.5 F or S
31

Use

Product Name 

/ EPA Reg # Maximum Single 

Application Rate 

(lb a.i./A)

Application 

Timing1

Method of 

Application Allowed Geographical Areas

Winter Wheat, 

Winter Barley

Avadex MinTill 

Herbicide 

/ 10163-287

1.5 F

Ground 

application, 

air granule 

application

CA, CO, ID, KS, MN, MT, NE, NV, ND, OR, 

SD, UT, WA, WY

Sugar Beet 1.5 F or S

CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, 

UT, WA, WY

Spring Wheat,

Durham Wheat 13 F or S

CA, CO, ID, KS, MN, MT, NE, NV, ND, OR, 

SD, UT, WA, WY

Spring Wheat, 

Durham Wheat 1.25 F or S

Barley and 

Triticale 1.25 F or S

Lentils 1.25 S

Bermuda Grass 1.5 F

Winter Wheat 1.5 F CA, CO, KS, NE, SD

Winter Wheat, 

Barley 1.5 F CA, ID, MT, OR, UT, WA

Spring Wheat, 

Durham Wheat, 

Barley 1.5 F or S CA, ID, MN, MT, ND, UT

Peas, green, 

field dried, 

chickpeas, 

garbanzo beans

1.25 S CA, CO, ID, KS, MN, MT, NE, NV, ND, OR, 

SD, UT, WA, WY

Barley

Buckle Granular 

Herbicide 

1.25 F or S CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, 

UT, WA, WY

Peas 1.25 F or S
32

Use

Product Name 

/ EPA Reg # Maximum Single 

Application Rate 

(lb a.i./A)

Application 

Timing1

Method of 

Application Allowed Geographical Areas

Durham Wheat

/ 10163-289

1.25 F

Ground 

granule 

application

Winter Wheat 1.5 F

Spring Wheat 1 F

ND (Adams, Billings, Bottineau, Burleigh, 

Burke, Divide, Dunn, Emmons, Grant, Golden 

Valley, Hettinger, Kidder, McHenry, 

McKenzie, McLean, Mercer, Morton, 

Mountrail, Oliver, Renville, Sheridian, Sioux, 

Slope, Stark, Ward, and Williams Counties), 

SD (Corson, Dewey, Harding, Perking, 

Zlebach Counties)

Spring Wheat

Buckle Granular 

Herbicide 

/ 10163-289

1 S

Ground 

granule 

application

SD (Corson, Dewey, Harding, Perking 

Zeibach)

N/S4

10163-288

Triallate Technical N/S N/S N/S N/S

1 Application allowed only once per growing season. Application can be made in either the F or S if listed as such. Application suggests 2 

incorporations which can be made both in the Fall (if no spring tillage anticipated), in the Fall and in the spring (applied in fall) , or both in 

the spring (if applied in the spring)

2 Rate applies to fine textured soil only; otherwise 1.25 lb/A is required

3 If using disc press drills; otherwise max rate is 1.25 lb/A

4 N/S = Technical Grade labels; information not specified

Application Key: 

S = Spring 

F = Fall

F or S = Either Fall or Spring application
33

Appendix B: Environmental Transformation Products of Triallate

Table B-1. Environmental Transformation Products of Triallate

Code 

Name/

Synonym

Chemical Name/

Smiles Code Chemical Structure

Study Type/

Corresponding OCSPP 

Guideline

MRID Maximum % AR 

(interval)1

Major Degradate Minor (>10%) Transformation Products

-- Carbon dioxide CO2

Aerobic Soil Metabolism

835.1200

00144567 28% (30 days)

44611302 Need blowbacks

44715601 44% (days 120)

Anaerobic Soil metabolism

835.4200 44611302 13.7 (90 days)

Aerobic Aquatic Metabolism 44715501 4.35% (100 day)

Minor (<10%) Transformation Products

TCPSA

2,3,3-trichloroprop-2ene sulfonic 

acid

C(C(=C(CL)CL)CL)S(=O)(=O)O

Aerobic Soil Metabolism

835.4200

00144567 3.4% (No DER)

44611302 3.4 (days 31)

44715601 3.74 (120 days)

Anaerobic Soil metabolism

835.4200 44611302 3.8 (90 days)

1Bold font indicates maximum concentration of degradate observed in various environmental fate studies.

2 No date mentioned in DER 

Cl

Cl

Cl

S

O

O

HO
34

Appendix C: Results of ECOSAR Modeling

The ECOSAR Programs is a screen-level tool based chemical structure developed by the USEPA Office of Chemical 

Safety and Pollution Prevention for rapid screening of chemicals for ecotoxicity hazards. The modeling results show that 

TCPSA, a minor degradate of triallate, becomes much less toxic than parent triallate after loss of the carbamate toxic 

moiety. The ECOSAR estimate values for triallate is similar to the experimental measured value. 

Taxon Triallate ECOSAR Class (mg/L) Experimental

Vinyl/Allyl Halides Thiocarbamate, Mono Neutral Organic SAR Measured

Acute Chronic Acute Chronic Acute Chronic Acute Chronic

Fish 0.273 0.021 1.743 0.057 1.236 0.160

1.2, 1.3

1.5, 2.4 0.038

Daphnid 0.264 0.043 0.452 0.018 0.890 0.168

0.09

0.43 0.014

Green algae 0.793 0.555 0.126 0.220 1.767 0.785 0.021 -

Marine diatom - - - - - - 0.33 -

Saltwater Fish 0.117 - 0.621 - - - - -

Saltwater Mysid 0.067 - 0.257 - - - - -

Earthworm 256.7 - - - - - - -

Taxon TCPSA ECOSAR Class (mg/L)

Vinyl/Allyl Halides Neutral Organic SAR

Acute Chronic Acute Chronic

Fish 43346.95 82004.13 17296.14 1331.32

Daphnid 30128.90 11.41 8020.06 445.09

Green algae 23435.18 1891.95 2585.51 431.26

Saltwater Fish 46310.52 - - -

Saltwater Mysid 20788.31 - - -

Earthworm 4088.31 - - -
Appendix D: Results of SIP and STIR

SIP (v1.0)

Table 1. Inputs

Parameter Value

Chemical name Triallate

Solubility (in water at 25oC; mg/L) 4

Mammalian LD50 (mg/kg-bw) 1100

Mammalian test species laboratory rat

Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg-bw) 7.51

Mammalian test species laboratory rat

Body weight (g) of "other" mammalian species

Avian LD50 (mg/kg-bw) 2251

Avian test species northern bobwhite quail

Body weight (g) of "other" avian species

Mineau scaling factor 1.15

Mallard NOAEC (mg/kg-diet) 3160

Bobwhite quail NOAEC (mg/kg-diet) 5620

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) 0.6880 0.6880

Adjusted toxicity value (mg/kg-bw) 846.0766 5.7687

Ratio of exposure to toxicity 0.0008 0.1193

Conclusion*

Drinking water exposure 

alone is NOT a potential 

concern for mammals

Drinking water exposure 

alone is NOT a potential 

concern for mammals

Table 3. Avian Results

Parameter Acute Chronic

Upper bound exposure (mg/kg-bw) 3.2400 3.2400

Adjusted toxicity value (mg/kg-bw) 1621.6868 156.7757

Ratio of exposure to acute toxicity 0.0020 0.0207

Conclusion*

Drinking water exposure 

alone is NOT a potential 

concern for birds

Drinking water exposure 

alone is NOT a potential 

concern for birds

1The value was the chronic NOAEL because the acute NOAEL value was not available, 

*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.
36

STIR (v1.0)

Welcome to the EFED 

Screening Tool for Inhalation Risk

This tool is designed to provide the risk assessor with a rapid method for determining the potential

significance of the inhalation exposure route to birds and mammals in a risk assessment.

Input

Application and Chemical Information

Enter Chemical Name Triallate

Enter Chemical Use wheat

Is the Application a Spray? (enter y or n) y

If Spray What Type (enter ground or air) ground

Enter Chemical Molecular Weight (g/mole) 304.66

Enter Chemical Vapor Pressure (mmHg) 1.20E-04

Enter Application Rate (lb a.i./acre) 1.5

Toxicity Properties

Bird

Enter Lowest Bird Oral LD50 (mg/kg bw) 2251

Enter Mineau Scaling Factor 1.15

Enter Tested Bird Weight (kg) 0.178

Mammal

Enter Lowest Rat Oral LD50 (mg/kg bw) 1100

Enter Lowest Rat Inhalation LC50 (mg/L) 5.3

Duration of Rat Inhalation Study (hrs) 4

Enter Rat Weight (kg) 0.35

Output

Results Avian (0.020 kg )

Maximum Vapor Concentration in Air at Saturation 

(mg/m3) 1.97E+00

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 2.47E-01

Adjusted Inhalation LD50 6.05E+01

Ratio of Vapor Dose to Adjusted Inhalation LD50 4.09E-03 Exposure not Likely Significant

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 1.59E-01

Ratio of Droplet Inhalation Dose to Adjusted Inhalation 

LD50 2.62E-03 Exposure not Likely Significant

Results Mammalian (0.015 kg )

Maximum Vapor Concentration in Air at Saturation 

(mg/m3) 1.97E+00

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 3.11E-01

Adjusted Inhalation LD50 3.16E+02

Ratio of Vapor Dose to Adjusted Inhalation LD50 9.85E-04 Exposure not Likely Significant

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 1.99E-01

Ratio of Droplet Inhalation Dose to Adjusted Inhalation 

LD50 6.31E-04 Exposure not Likely Significant