OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON

, D.C. 20460

November 6, 2014

PC Code: 129131

MEMORANDUM DP Barcode: 421244

SUBJECT: EFED Registration Review Probl em Formulation for Fenpyroximate

FROM: Christina Wendel, Biologist Greg Orrick, Environmental Scientist

Environmental Risk Branch 2

Environmental Fate and Effects Division (7507P)

REVIEWED N.E. Federoff, Wildlife Biologist

BY: James Lin, Environmental Engineer Jean Holmes, DVM, MPH, Risk Assessment Process Leader

Environmental Fate and Effects Division (7507P)

THROUGH: Brian Anderson, Branch Chief

Environmental Risk Branch 2

Environmental Fate a nd Effects Division (7507P)

TO: Miguel Zavala, Chemical Review Manager Patricia Parrott, Branch Chief Risk Management and Implementation Branch 3

Pesticide Re-evalua tion Division (7508P)

### 2 

## Table	of	Contents

1. Executive summary ............................................................................................................. .... 3

2. Introduction .................................................................................................................. ........... 3

a. Mode of Action ................................................................................................................ .... 3

3. Use Characterization .......................................................................................................... ..... 4

4. Conclusions from Previous Risk Assessments ....................................................................... 8

a. Ecological Risk Assessment ................................................................................................ 8

b. Drinking Water Exposure Assessments ............................................................................... 9

c. Clean Water Act Programs ................................................................................................ 10

5. Environmental Fate and Transport........................................................................................ 10

a. Transformation Products .................................................................................................... 12

6. Receptors...................................................................................................................... ......... 17

a. Effects to Aquatic Organisms ............................................................................................ 18

b. Effects to Terrestrial Organisms ........................................................................................ 19

c. Ecological Incidents .......................................................................................................... . 20

7. Exposure Pathways of Concern ............................................................................................ 21

8. Analysis Plan ................................................................................................................. ....... 21

a. Stressors of Concern .......................................................................................................... 21
b. Measures of Exposure ........................................................................................................ 2 2

c. Measures of Effect ............................................................................................................ . 22

9. Endangered Species Assessments ......................................................................................... 22

10. Endocrine Disruptor Screening Program ........................................................................... 23

11. Preliminary Identification of Data Gaps ............................................................................ 23

a. Environmental Fate ............................................................................................................ 23
b. Effects ....................................................................................................................... ......... 26

12. References .................................................................................................................... ...... 35

a. Submitted Product Chemistry and Environmental Fate Studies ........................................ 35

b. Submitted Ecological Toxicity Studies .............................................................................. 36 APPENDIX A. STIR & SIP Model Outputs ................................................................................ 41

### 3 

## 1. Executive summary

The Environmental Fate and Effects Division (E FED) has completed the preliminary problem formulation (attached) for the ecological risk, environmental fate, endangered species, and drinking water assessments to be conducted as pa rt of the registration re view of fenpyroximate. The problem formulation describes the methods planned to be used during the completion of drinking water and ecological risk assessments in support of regi stration review and provides an overview of the environmental fate, ecological eff ects, potential risks associated with the use, and uncertainties unique to the risk assessment of fenpyroximate. This document also identifies

additional studies that would be beneficial to the conduct of an ecological risk assessment. Major findings include:

Data Needs

 Aerobic soil metabolism study (OCSPP Guid eline 835.4100) of one to three soils

 Anaerobic aquatic metabolism study (OC SPP Guideline 835.4400) of one system

 Fish bioconcentration st udy (OCSPP Guideline 850.1730)

 ILVs of ECMs in soil and water (OCSPP Gu ideline 850.6100) or new, state-of-the-art methods and associated ILV reports

 Chronic mysid toxicity study (OSCPP Guideline 850.1350)

 Freshwater fish full life-cycle toxicity study (OSCPP Guideline 850.1500)

 Sediment toxicity study (OSCPP Guideline 850.1735)

 Avian acute oral toxicity – passe rine species (OSCPP Guideline 850.2100)

 Acute and chronic larval oral honeybee toxi city studies (OECD Guideline 237 and NonGuideline, respectively)

 Chronic adult oral honeybee t oxicity study (Non-Guideline)

 Semi-field testing for pollinators (OECD Guideline 75)



## 2. Introduction

Fenpyroximate is a pyrazole contact insecticide and miticide that was first registered in 2000, with new agricultural uses added since. Thr ee end-use formulations containing fenpyroximate are currently registered for use in the United States.



## a. Mode of Action

Fenpyroximate is a pyrazole contact insecticide a nd miticide that inhibits mitochondrial complex I electron transport. The mode of action blocks cell respiration by blocking formation of adenosine triphosphate (ATP), cau sing the target pest to lose motor control and collapse. Fenpyroximate specifically targets the proton-tr anslocation in NADH:ubi quinone oxidoreductase enzyme blocking ubiquinone reduction.

NADH:ubiquinone oxidoreductase, also known as respiratory complex I of mitochondria,

transfers electrons from NADH to ubiquinone (coenzyme Q) a nd links this process with

### 4 translocation of protons across the inner membrane to the cyt oplasmic side creating a proton gradient which drives the s ynthesis of ATP. NADH:ubiqui none oxidoreductase enzyme is comprised of a number of subunits. The number of subunits and total mass of this enzyme and density within mitochondria depends on the organism. It consists of at least 41 different subunits in mammals. The highest number of subunits is 46 for bovine heart mitochondria, whereas bacteria have a minimum of 14 subunits. The total mass of the enzymes ranges from approximately 500 to 1000 kiloDaltons (kDa), depending on the organism. Sensitivity of an organism to fenpyroximate is expected to be affected by the specific organism NADH:ubiquinone oxidoreductase enzyme affinity with fenpyroximate, the density of the NADH:ubiquinone oxidoreductase enzyme within mito chondria, and the pres ence of alternative energy pathways.

In addition to the acute respiratory activity, at sublethal levels fenpyroximate causes inhibition of molting of all immature stages (as in insect growth regulators), i nhibits oviposition, and decreases feeding action.



## 3. Use Characterization

Three end-use formulations containing 5% fenpyroxi mate are currently regi stered for use in the United States. Fujimite ® 

### 5EC (EPA Reg. No. 71711-19) and NAI-2399-2 ® 

### 5EC (EPA Reg. No. 71711-40) include many of the same outdoor agri cultural, ornamental, and greenhouse uses. Specific use sites, some of whic h overlap, include exotic fruits, citrus fruits, cotton, cucumbers, corn, fruiting vegetables, grapes, hops, low-gr owing berries except cranberries, melons, mint, pome fruits, tuberous and corm vegetables (EPA Reg. No. 71711-40 only), stone fruits (EPA Reg. No. 71711-40 only), snap beans, tree nuts, nonb earing deciduous fruit, tree nuts and vines, ornamentals, greenhouse cucumbers, and greenhouse tomatoes.

Akari ® 

### 5SC Miticide/Insecticide (E PA Reg. No. 71711-4) was origin ally for ornamental and greenhouse use sites. The label still has a section for control of mites “on greenhouse cucumbers, greenhouse tomatoes, and greenhouse peppers, all ornamental crops including flowering and foliage crops, nurse ry crops, nonbearing fruit trees and vines, and Christmas trees. These include those crops grown in greenhouses , shade and lathe houses, outdoor nurseries and fields, and in interiorscapes.” However, all of the agricultural crops on th e other two labels have

been added to this label as well.

Table 1 lists the maximum use patterns for the labeled use sites. Multiple table rows for the same crop and label indicate that th e use site appears in multiple sections of the label. There are

no label directions that resulted in ambiguous maximum use patterns.5Table 1. Maximum Use Patterns for Current Uses of FenpyroximateUseEPA Reg.No.Max. SingleApp. Rate(lbs a.i./A)AMax. AnnualApp. Rate(lbs a.i./A)AApp.Interval(d)ApplicationTypeAdditional Application DirectionsAvocado, black sapote, canistel, mamey sapote,mango, papaya, sapodilla, and star apple71711-471711-1971711-400.11 0.21B14Aerial orgroundDo not use products with the same mode ofaction in consecutive applications.Do not apply through any type of irrigationsystem.Do not apply within 75 feet of fish-bearingwaters.Citrus: Do not apply by air to citrus except inFL and TX.Citrus: For aerial use on citrus in FL, do notapply within 150 feet of all aquatic areas.Citrus, nonbearing plants, & ornamentals:Do not apply to citrus nurseries or citrus ingreenhouses.Corn: Use on corn is limited to CA, CO, HI,KS, NM, OK, and TX (and AZ on EPA Reg.No. 71711-4).Pome: Do not apply by Alternate RowMiddle (ARM) spray method.Citrus fruits (crop group 10-10) east of theMississippi River0.21 0.21BCitrus fruits (crop group 10-10) west of theMississippi River0.21 0.42BCitrus fruits (crop group 10-10)71711-19H71711-40H0.210.42BGround only71711-40H0.210.21BAerial orgroundCotton71711-471711-1971711-400.110.11BCucumbers0.110.21CCorn (field, pop, silage, and seed)Fruiting vegetables (crop group 8-10)Grapes (raisin, table, wine)71711-471711-190.110.11BGround onlyGrapes (crop subgroup 13-07F)71711-40Low-growing berries (crop subgroup13-07G) except cranberries71711-471711-1971711-400.110.21CHops0.160.16BMelons (crop subgroup 9A)0.110.21CMint (peppermint, spearmint)0.110.21B7Nonbearing deciduous fruit, tree nuts, and vines0.110.11B14OrnamentalsPome fruits (crop group 11-10)Potato tuberous and corm vegetables (cropsubgroup 1C)71711-471711-400.110.21C7Aerial orgroundStone fruits (crop group 12-12)0.110.21B, C14Ground onlySnap beans71711-471711-1971711-400.110.21C14Aerial orground6UseEPA Reg.No.Max. SingleApp. Rate(lbs a.i./A)AMax. AnnualApp. Rate(lbs a.i./A)AApp.Interval(d)ApplicationTypeAdditional Application DirectionsAlmonds and pistachios71711-40H0.210.42B14Ground onlyDo not use products with the same mode ofaction in consecutive applications.Do not apply through any type of irrigationsystem.Do not apply within 75 feet of fish-bearingwaters.Greenhouse uses: Do not apply in Ultra LowVolume equipment.Almonds and pistachios west of the MississippiRiver71711-471711-1971711-40Tree nuts (crop group 14) west of the MississippiRiver, excluding almonds and pistachios0.21BTree nuts (crop group 14, excluding almonds andpistachios71711-40HTree nuts (crop group 14) and pistachios east ofthe Mississippi River71711-471711-400.110.11BNotapplicableTree nuts (crop group 14) and pistachios (allgeographies)71711-1971711-40HGreenhouse cucumbers71711-40.21DOne cropcycleAerial orgroundE71711-1971711-400.42F14, onecrop cycleGround onlyGreenhouse tomatoes and greenhouse peppers71711-4Aerial orgroundEGreenhouse tomatoes71711-1971711-40Ground onlyOrnamental trees, vines, shrubs, foliage, andflowering plants71711-40.340.6914GA Maximum annual application rates are wholemultiples of maximum single application rates, all of which were rounded to two significant figures.B The labeled application rate limit is given per growing season, which is interpreted as per year.C The labeled application rate limit is given per crop cycle. These crops are not typically planted more than once per year inthe same field (USEPA, 2007).Therefore, the application rate limits per crop cycle were used as annual rate limits.D The label allows only one application per growing season or crop cycle, but allows two applications per year.E Ground application is recommended but not required.F Two applications are allowed per crop cycle.Four applications are allowed per year.G The labeled application rate limit is given per crop cycle orgrowing season, whichever is longer, which is interpreted as per year.H This use pattern is from a supplemental label.

### 7 Figure 1 depicts a national-level su mmary of the estimated agricu ltural usage of fenpyroximate in 2011 (USGS, 2014). National agricultural usag e of fenpyroximate has been increasing since 2004, mostly on orchards.

Figure 1. Agricultural Usage of Fenpyroximate in 2011 (USGS, 2014)

### 8 

## 4. Conclusions from Previous Risk Assessments

a. Ecological Risk Assessment

The Agency has conducted multiple ecological ri sk assessments on fenpyroximate over the past 14 years that serve as a basis for this scoping document. The most recent full ecological risk assessment for proposed new uses of fenpyroxi mate is dated Mar. 21, 2012 (DP 394291). Two partial assessments followed within one year (DP 394367, 2012; DP 406242, 2013). Primary

risk issues were chronic risk to mammals and bird s, acute and chronic risk to fish (surrogates for aquatic-phase amphibians), acute risk to aquatic invertebrates, and risk to non-vascular aquatic plants (see Table 2 ), although some high-rate us es resulted in further risk s. In addition, although fenpyroximate is categorized as practically non -toxic to adult honeybees, and by extension, to

other beneficial terrestrial i nvertebrates on an acute exposure basis, there is considerable uncertainty regarding the potential effects of the compound on terr estrial invertebrates’ larval development and survival. The mode of action of fenpyroximate causes inhibition of molting of all immature stages, inhibits oviposition, and de creases feeding action. Therefore, risk was presumed for terrestrial invert ebrates due to potential effect s to larvae are not known, and additional data is needed to fully characterize th e risk associated with fenpyroximate use to all developmental stages, as sensitivity may vary according to life-stage.

Specifically, in recent risk assessments, propos ed uses of fenpyroximate had the potential for

direct adverse effects on liste d and non-listed freshwater fish and aquatic-phase amphibians (based on acute and chronic exposure), listed fr eshwater and estuarine/ marine invertebrates (based on acute exposure), listed freshwater in vertebrates (based on chronic exposure), listed aquatic non-vascular plants, list ed estuarine/marine fish and non-listed freshwater invertebrates (based on acute exposure), and li sted and non-listed birds (sur rogates for terrestrial-phase amphibians, and reptiles) and mammals (based on chronic exposure). Agai n risk to terrestrial invertebrates was presumed due to potential effects to the larval life-stage is not known; due to mode of action of fenpyroximate, causing inhibition of molting of all immature stages, inhibiting oviposition, and decreasing feeding action the sens itivity may vary according to life-stage. A summary of exceedances of the leve l of concern (LOC) is listed in Table 2

. Figure 2 and Table

3 summarize the potential risks and the supporting evidence.

Table 2. LOC Exceedances for Recently Assessed Proposed Uses

Effect Taxonomic Group

Birds Mammals Terrestrial

Plants Terrestrial

Inverts Fish Aquatic

Inverts Aquatic

Plants

Direct Effect LOC

Exceedance 

### √ √
-- √ a 

### √ √ √

Indirect Effect

Potential 

### √ √ √ √ √ √ √

a Risk presumed, potential effects to la rvae are not known, and are considered to be an uncertainty due to the nature

of the chemical.

### 9 Figure 2. Graphic Summary of Potential Risks of Recently Assessed Proposed Uses

Table 3. Evidence of Risk to Taxonomic Gr oups from Proposed Fenpyroximate Uses

Greater Certainty of Negligible Risk Conclusion Greater Certainty of Potential for Environmental Impact

Terrestrial Plants: All RQs < LOC. Aquatic Organisms: RQs > LOC (up to 5.0).

Mammals & Birds: RQs > LOC (up to 9.8 for mammals and 1.3 for birds).

Lower Certainty of Negligible Risk Conclusion Lower Certainty of Potential for Environmental Impact

Terrestrial Invertebrates: No toxicity observed in acute studies for adult life stages. Unknown/Presumed toxicity for larval life stages due to mode of action of chemical.



## b. Drinking Water Exposure Assessments

The most recent full drinking water exposure assessment for proposed new uses of fenpyroximate is dated Jan. 23, 2012 (DP 391431). Two partial assessments followed in the same year (DP 392472; DP 404840). The residues of concern were the parent compound, M-1, and M-3. Maximum screening exposure estimates for the residues of concern were 43 μg/L (1- in-10-year peak) and 8.6 μg/L (1-in-10-year annual mean) for surface water (based on a proposed use on cranberries) and ≤ 0.27 μg/L for ground water.

### 10 

## c. Clean Water Act Programs

The Clean Water Act requires the Agency to publish water quality criteria that accurately reflect the latest scientific knowledge on the kind and ex tent of all identifiable effects on health and welfare that might be expected from the presen ce of pollutants in any body of water, including ground water. While these recommended cr iteria do not, in themselves, impose any requirements, states and authorized tribes can us e them to develop water quality standards. An Aquatic Life Ambient Water Quality Crite ria document has not been published for fenpyroximate (see url: http://www.epa.gov/waterscience/criteria/ ).

The Office of Pesticide Programs (OPP) publishes a quatic life benchmarks for freshwater species based on toxicity values for the most sensitive species from the most recent risk assessments. However, aquatic life benchmarks have not been published for fenpyroximate (see url: http://www.epa.gov/oppefed1/ecorisk_ders/a quatic_life_benchmark.htm#benchmarks ). Any

data submitted or otherwise locat ed as part of the registration review process may be used to update aquatic life benc hmarks if applicable.

Fenpyroximate is not identified as a cause of impair ment for any water bodies listed as impaired under section 303(d) of the Clean Water Act, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_ nation_cy.cause_detail_303d?p_cause_group_id=88

5 . No Total Maximum Daily Load (TMDL) crit eria have been developed for fenpyroximate, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_ nation.tmdl_pollutant_de tail?p_pollutant_group_id =885&p_pollutant_group_name=PESTICIDES

. 

## 5. Environmental Fate and Transport

Fenpyroximate is a trans stereoisomer and a tert -butyl ester (chemical st ructure and name are in

Table 4 ). The compound is relatively non-volatile, li pophilic, and slightly to hardly mobile in soil. Fenpyroximate degrades mainly via biodegr adation in soil and water bodies (half-lives of 23-41 days in aerobic and anaerobic systems). Th e compound is also rapidly photoisomerized to reach equilibrium with its cis isomer M-1 and photolyzed in shallow, illuminated water (fenpyroximate half-life of 1.5 hours; M-1 half-life of 10.5 hours) . However, the importance of this degradation pathway is expected to be limited because fenpyroximate and its isomer are expected to partition to sediment in water bodies, where aqueous phot olysis is limited. Fenpyroximate does not hydrolyze readily and may bioconcentrate in fish.

Fenpyroximate is not expected to move to groun d water in appreciable amounts but may move to surface water bodies via spray dr ift and runoff of residues sorb ed to suspended sediment. Table

4 summarizes the submitted chemical and environmental fate data for fenpyroximate.

### 11 Table 4. Chemical Properties and Environmen tal Fate Parameters of Fenpyroximate

Parameter Value Source

Selected Physical/Chemical Parameters

Molecular mass (molecular formula) 421.50 g/mol (C 24 H 27 N 3 O 4 ) (Calculated)

Vapor pressure (25 °C) 5.6 x 10 -8 torr MRID 44781003

Aqueous solubility (25  C) pH 5: 0.023 mg/L pH 7: 0. 026 mg/L pH 9: 0.034 mg/L MRID 44781003

Henry’s Law Constant (25°C, pH 7) 1.2 x10 -6 atm-m 3 /mol (Calculated)

Log octanol-to-water partition coefficient (log K O W ) 5.01 MRID 44781003

Dissociation constant (pKb) Not determined MRID 44781003

Persistence in Water

Hydrolysis half-life (25  C) pH 5: 180 d pH 7: 226 d pH 9: 221 d MRID 44847909

Aqueous photolysis half-life (25  C) 1.8 hrs (0.15 solar days) MRID 44781016

Anaerobic aquatic metabolism half-life (25  C) 33 d MRID 45649707

Aerobic aquatic metabolism half-life (20  C) 23, 34 d MRID 47521406

Persistence in Soil

Soil photolysis half-life (25  C) 24 d MRID 45649705

Aerobic soil metabolism half-life (25°C) 28, 41 d MRID 45187901/

45649706

39 d MRID 46158501

Mobility

Freundlich organic carbon-normalized coefficients (K FOC ) A 7,550; 18,600; 41,400; 44,000; 58,300 L/kg OC MRID 45649709

Field Dissipation

Terrestrial field dissipation half-life 1 d (German sandy silt loam), 11 d (German sandy loam), 12 (German loamy sand), 24 d (German sandy loam) MRID 45649710/

45649711

3.6 d (Commerce silt loam, AR), 4.1 d (Cajon sandy loam, CA), 15 d (Norfolk sandy loam, NC) MRID 45649712/

45734203

Fish Bioconcentration

Fish bioconcentration factors (steady-state, total residues); depuration half-life 770-1100 (edible), 2800-4100 (inedible), 1800-2700 (whole fish); 5.3 d MRID 48381102

A The coefficient of variation for K FOC (0.60) was less than that for K F (1.4), indicating that sorption to organic

carbon is important.

### 12 

## a. Transformation Products

Fenpyroximate’s cis isomer M-1, its carboxylic acid M-3, and cleavage products M-6, M-8, M11, M-16, and carbon dioxide are its major transformation products (chemical names and

structures are in Table 4

. Figure 3 illustrates the transformati on pathway of fenpyroximate in

the environment.

Major organic degradates of fenpyroximate (and M- 1) tend to have higher mobility in soil than the parent compound (and its isomer). Mean K FOC 

### values for M-3, M-8, and M-11 are 660, 90, and 611 L/kg OC 

### (n=4; MRID 45649708 and 47521401). As e xpected for a carboxylic acid, M-3 is orders of magnitude more so luble in water (solubility of ≥ 25 mg/L at 25°C; MRID 45649708) than fenpyroximate.

It is uncertain whether unextracted residues in th e laboratory studies were well sorbed to soil and not readily available because extraction solvents with a wide range of dielectric constants (including polar and nonpolar solv ents) were not explor ed and concentrations of unextracted residues were up to 60% of the applied and disp layed variable formati on patterns (peaking prior to study termination in some systems and at study termination in others). Use of reflux, Soxhlet,

and/or harsh extraction methods (using strong acids or bases) does not substitute for the use of multiple polar and nonpolar solvents.

Unextracted residues appear to include degradat es of fenpyroximate rather than the parent compound because the sterile system in MR ID 47521406 did not produce appreciable amounts of unextracted residues ( i.e. , up to 1.3% of the applied) 105 da ys after treatment. This means that the uncertainty in the availa bility of the unextracted residu es leads to uncertainty in the amounts of degradates formed, not uncertainty in the degradation rates of the parent compound.13Table 5. Fenpyroximate and Its Environmental Transformation ProductsCode Name/SynonymChemical NameChemical StructureStudy TypeMRIDMaximum%AR (day)Final %AR(study length)PARENTFenpyroximate(E-isomer)IUPAC:tert-butyl (E)-α-(1,3-dimethyl-5-phenoxypyrazol-4-ylmethyleneaminooxy)-p-toluateCAS:1,1-dimethylethyl 4-[[[(E)-[(1,3-dimethyl-5-phenoxy-1H-pyrazol-4-yl)methylene]amino]oxy]methyl]benzoateCAS No.:134098-61-6Formula:C24H27N3O4MW:421.50 g/molNNNOOOOTRANSFORMATION PRODUCTSM-1(Z-isomer)tert-butyl (Z)-4-[(1,3-dimethyl-5-phenoxypyrazol-4-yl)methyleneaminooxymethyl]-benzoateFormula:C24H27N3O4MW:421.50 g/molOONNNOOHydrolysis 44847909 4.5% (30 d) 4.5% (30 d)Aq photolysis 4478101660%(4 hrs) 1.5% (73 hrs)Soil photolysis 4564970537%(30 d) 37% (30 d)Aerobic soil 45187901 3.0% (7 d)0.3% (112 d)Anaerobic aquatic 45649707 1.7%(30 d)n.d. (366 d)M-3(E)-4-[(1,3-dimethyl-5-phenoxypyrazol-4-yl)methylene-aminooxy-methyl]-benzoicacidFormula:C20H19N3O4MW:365.39 g/molNNNOOHOOHydrolysis 44847909 8.5% (30 d) 8.5% (30 d)Aq photolysis 44781016 2.5% (4 hrs) n.d. (73 hrs)Soil photolysis 45649705 1.5% (30 d) 1.5% (30 d)Aerobic soil 4615850116%(90 d) 4.0% (365 d)Aerobic soil 4518790111%(14 d)0.1% (112 d)Anaerobic aquatic 4564970750%(59 d)18% (366 d)Aerobic aquatic45734202/4752140626%(14 d)3.3% (105 d)Terrestrial field45649710/4564971113%(14, 29 d)n.d. (370 d)Terrestrial field45649712/4573420332%(7 d)n.d. (120 d)14Code Name/SynonymChemical NameChemical StructureStudy TypeMRIDMaximum%AR (day)Final %AR(study length)M-61,3-dimethyl-5-phenoxypyrazole-4-carbaldehydeFormula:C12H12N2O2MW:216.24 g/molNNOOAq photolysis 44781016 8.5% (12 hrs) 0.5% (73 hrs)Soil photolysis 45649705 1.4% (30 d) 1.4% (30 d)Aerobic soil 46158501 3.6% (273 d) 1.1% (365 d)Aerobic soil 45187901 0.4% (14 d)0.1% (112 d)Anaerobic aquatic 45649707 6.7%(366 d)6.7%(366 d)M-81,3-dimethyl-5-phenoxypyrazole-4-carboxylic acidFormula:C12H12N2O3MW:232.24 g/molNNOOOHSoil photolysis 45649705 4.1% (30 d) 4.1% (30 d)Aerobic soil 4615850112%(90 d) 2.1% (365 d)Aerobic soil 45187901 3.5% (84 d)2.7% (112 d)Anaerobic aquatic 4564970736%(366 d)36%(366 d)Aerobic aquatic45734202/4752140631%(61 d)15% (105 d)M-111,3-dimethyl-5-phenoxypyrazole-4-carbonitrileFormula:C12H11N3OMW:213.24 g/molNNONAq photolysis 4478101622%(24 hrs) 15% (73 hrs)Aerobic soil 46158501 5.9% (90 d) 1.6% (365 d)Aerobic soil 45187901 8.8% (28 d)6.8% (112 d)Anaerobic aquatic 4564970721%(366 d)21%(366 d)Aerobic aquatic45734202/4752140633%(105 d)33% (105 d)M-164-hydroxymethylbenzoic acidFormula:C8H8O3MW:152.15 g/molOHOHOAerobic soil 46158501 3.6% (273 d) 1.1% (365 d)Aerobic soil 45187901 0.1% (7 d)n.d. (112 d)Anaerobic aquatic 4564970758%(182 d)45% (366 d)UNK-1Unidentified photodegradate UNK-1Not identified Soil photolysis 4564970517%(30 d) 17% (30 d)PS-6Unidentified biodegradateNot identified Aerobic aquatic45734202/4752140617%(30 d) 3.5% (105 d)15Code Name/SynonymChemical NameChemical StructureStudy TypeMRIDMaximum%AR (day)Final %AR(study length)UnextractedresiduesNot applicableNot applicableSoil photolysis-light456497054.5% (30 d) 4.5% (30 d)Soil photolysis-dark 1.5% (30 d) 1.5% (30 d)Aerobic soil-sandyloam4615850137%(60 d)55%(182 d)39%(98 d)28%(61 d)37% (60 d)38% (365 d)31% (285 d)27% (365 d)Aerobic soil-sand4518790149%(112 d)22%(112 d)49% (112 d)22% (112 d)Aerobic soil-sand60%(112 d)42%(112 d)60% (112 d)42% (112 d)Anaerobic aquatic 4564970717%(273 d)14%(366 d)15% (366 d)14% (366 d)Aerobic aquatic-river45734202/4752140623%(105 d) 23% (105 d)Aerobic aquatic-pond28%(105 d) 28% (105 d)Carbon dioxideCarbon dioxideFormula:CO2MW:44.1 g/molOOSoil photolysis 45649705 1.6% (30 d) 1.6% (30 d)Aerobic soil 4615850159%(365 d) 59% (365 d)Aerobic soil 4518790170%(112 d)70% (112 d)Anaerobic aquatic 45649707 9.6% (366 d)9.6% (366 d)Aerobic aquatic45734202/475214062.0% (105 d) 2.0% (105 d)16Figure 3. Environmental TransformationRoute of Fenpyroximate (MRID 45187901, p 52)

### 17 

## 6. Receptors

Fenpyroximate is very highly toxic to freshwater and estuarine/mari ne fish and invertebrates on an acute exposure basis. The M-3 degradate of fenpyr oximate is moderately t oxic to freshwater fish and invertebrates on an acute exposur e basis. No toxicity data is currently available for the M-1 degradate of fenpyroximate; however th is is not considered to be a data gap. Reductions in length, dry weight and survival (immobile neonates and F 0 

### mysids) were noted effects resulting from chronic exposure of fenpyroximate to freshw ater fish, freshwater invertebrates, and estuarine/marine invertebrates (recently reviewed ), respectively. However, the reported NOAEC from the mysid life-cycle study is uncertain because it does not necessarily account to effects to offspring; no information was measured or record ed for the second generation mysids. As a result the submitted study does not fulfill guideline re quirements and there are key reproductive endpoints missing. In addition, preliminary results from the recently submitted and reviewed fish full life-cycle study with fr eshwater fish indicates a significa nt reduction in eggs per spawn, and delays in time to hatch observed for the F 1 

### generation in the second lo west test concentration. Preliminary results from recently submitted and revi ewed 10-day sediment toxicity study with the Midge ( Chironomus tentans ) indicated that the LC50 and EC50 values were empirically determined to be greater than the highest test le vel in both endpoints. Toxicity values were based on all three strata concentrations ( i.e., sediment, pore water, and overlying water), including

concentrations normalized for TOC (2.1%). Aquatic plant toxicity testing indicated that vascular plants, e.g. , duckweed ( Lemna gibba ) are not sensitive to fenpyroximate at the concentrations tested, whereas, non-vascular plants, e.g ., marine diatoms ( Skeletonema costatum ) and green algae ( Scendesmus suspicatus ) are sensitive to fenpyroximate at the concentrations tested, based on effects on cell density.

Fenpyroximate is practically non-t oxic to young adult honey bees and birds, and moderately toxic to mammals on an acute exposure basis. Howeve r, mortality and sublethal effects were both observed in the subacute dietary toxicity st udy for mallard ducks. Although mortality was
observed it was less than 50% in all treatment le vels (three total); however, clinical signs of toxicity were observed in all treatment groups (for a majority of the birds) up to 7 days after dosing. Reductions in female body we ight gain in birds and decrea sed parental and pup weight in mammals were noted effects resulting from chroni c exposure of fenpyroximate. Tier II terrestrial plant testing using both seedling emergence and ve getative vigor assays indicated that neither monocotyledonous nor dicotyledonous plants are sensitive to fenpyroxi mate at the application rate

tested.

Table 6 provides a summary of the most sensitiv e ecological toxicity endpoints of aquatic organisms for both the parent compo und fenpyroximate and degradate M-3, and Table 7 summarizes the most sensitive endpoints of terre strial organisms for both the parent compound fenpyroximate and degradate M-3.

### 18 

## a. Effects to Aquatic Organisms

Table 6. Summary of the Most Sensitive Endp oints from Aquatic Toxicity Studies for Fenpyroximate and Degradate M-3

Aquatic Animals

Species Test
Substance

(% a.i.) Acute Toxicity Chronic Toxicity

96-hr LC 50 /EC 50 (95% CI) (μg a.i./L) (Toxicity Classification) 48-hr EC 50 (95% CI) (μg a.i./L) (Toxicity Classification) MRID (Study Classification) NOAEC/

LOAEC (μg a.i./L) (Endpoints) MRID (Study Classification)

Rainbow trout ( Oncorhynchus mykiss ) TGAI

98.8% 0.73 (0.59-1.3) (very highly toxic) -- 46799201 (Acceptable) ND ND

EP
5.2% 0.44 (0.37-0.57) (very highly toxic) -- 47098102 (Acceptable) ND ND

M-3
metabolite 6200 (3000-28000) (moderately toxic) -- 46974402 (Supplemental) ND ND

Fathead

minnow ( Pimephales promelas ) TGAI

98.6%

ND -- ND 0.11/0.23 (length) 45649808 (Acceptable;

850.1400)

TGAI

97.2% 0.016/0.031 (Spawn per

female & F 1 time to hatch) 48735301 (Preliminary

Review; 850.1500) Sheepshead

Minnow ( Cyprinodon variegates ) TGAI

98.8% 36 (17-71) (very highly toxic) -- 47098101 (Acceptable) ND 1 ND 1

Waterflea ( Daphnia

magna ) TGAI

99.35% -- 3.6 (2.9-4.6) (very highly toxic) 44781015 (Acceptable) <0.17/0.17 (dry weight)

&
0.56/1.0 (immobile neonates) 47098103 (Acceptable)

EP

5.2% -- 1.6 (1.3-2.0) (very highly toxic) 46800801 (Acceptable) ND ND

M-3
metabolite -- 13050 (9500-20000) (moderately toxic) 46974401 (Acceptable) ND ND

Eastern oyster ( Crassostrea virginica ) TGAI

98.8% -- 3.3 (1.6-6.7) (very highly toxic) 47021401 (Acceptable) -- --

Mysid ( Americamysis

bahia ) TGAI

98.8% 3.7 (2.2-7.7) (very highly toxic) -- 45649804 (Acceptable) 1.46/4.58 (F 0 Day-15 & Day-32 survival) 47521405 (Supplemental) 2

### 19 Aquatic Animals

Species Test
Substance

(% a.i.) Acute Toxicity Chronic Toxicity

96-hr LC 50 /EC 50 (95% CI) (μg a.i./L) (Toxicity Classification) 48-hr EC 50 (95% CI) (μg a.i./L) (Toxicity Classification) MRID (Study Classification) NOAEC/

LOAEC (μg a.i./L) (Endpoints) MRID (Study Classification)

Midge ( Chironomus

tentans ) TGAI

99.8% ND ND ND 10-day

EC 50 : 0.624 μg
TTR/L

NOAEC: 0.400 μg TTR/L

LOAEC: 0.624 μg TTR/L (Growth) 48381101 (Preliminary

Review; 850.1735; b ased

upon meanmeasured overlying water concentrations) Aquatic Plants

Species Test
Substance Endpoint (μg a.i./L) Effect (MRID; Study Classification)

Duckweed ( Lemna gibba ) EP

5.1% 7-day EC 50 >190

NOAEC = 31 Frond number (45649811; acceptable)

Marine Diatom ( Skeletonema

costatum ) EP

5.1% 96 hr EC 50 = 1.9

NOAEC = 0.26 Cell density (45649815; acceptable)

Green alga ( Scendesmus suspicatus ) TGAI

99.4% 72 hr EC 50 = 0.66

NOAEC <1.8 Cell density (45649816; supplemental) 3

EP = End-Use Product; ND = No data; -- = not applicable

1 No chronic estuarine/marine fish toxicity data is available.

2 The NOAEC is uncertain because it does not necess arily account to effects to offspring.

3 A preferred test species was not used, and the st udy was conducted for 72-hrs and not the recommended 96-

hrs.



## b. Effects to Terrestrial Organisms

Table 7. Summary of the Most Sensitive Endp oints from Terrestrial Toxicity Studies for Fenpyroximate

Terrestrial Animals

Species/

Test

substance (% a.i.) Acute Toxicity Chronic Toxicity

48-hr LD 50 (μg a.i./bee) 14-day LD 50 (95% CI) (mg/kg-bw)

(Toxicity Classification) 13-day LC 50 (mg a.i./kg-diet (ppm)) (Toxicity Classification) MRID (Study Classification) NOAEC/LOAEC (mg a.i./kg-diet (ppm)) (Endpoints) MRID (Study Classification)

Bobwhite Quail ( Colinus virginianus )/ (TGAI; 99%) -- >2000 (practically non-toxic) >5000 1 (practically non-toxic) 45649715 (Acceptable)

&

44847908 (Acceptable) ≥ 255 (no effects) 47521404 (Supplemental) 2

### 20 Terrestrial Animals

Species/

Test

substance (% a.i.) Acute Toxicity Chronic Toxicity

48-hr LD 50 (μg a.i./bee) 14-day LD 50 (95% CI) (mg/kg-bw)

(Toxicity Classification) 13-day LC 50 (mg a.i./kg-diet (ppm)) (Toxicity Classification) MRID (Study Classification) NOAEC/LOAEC (mg a.i./kg-diet (ppm)) (Endpoints) MRID (Study Classification)

Mallard Duck ( Anas platyrhynchos )/ (TGAI; 99%) -- >2000 (practically non-toxic) >5000 1 (practically non-toxic) 45649714 (Acceptable)

&

45649716 (Acceptable) 35 / 182 (reductions in female body weight gain) 45649718 (Supplemental) 3

≥ 255 (no effects) 47521403 (Supplemental) 2
Laboratory rat ( Ratus norvegicus )/ (TGAI; 98 & 97.3%) -- 245 (167-323) (moderately toxic) -- 43560501 (Acceptable) 30/100 4 (decreased parental and pup weight) 43429506 (Acceptable)

Laboratory rat (TGAI; 88.7%) -- Inhalation LC 50 = 0.24 mg/L (Males) (Toxicity category II) 44847903 (Acceptable) -- --
Honey Bee ( Apis mellifera )/ (EP; 5.2%; acute contact) >479.8 (practically non-toxic) -- -- 45649818 (Acceptable) -- --

Terrestrial Plants

Species/

Test

substance (% a.i.) Seedling Emergence Vegetative Vigor

MRID Study

Classification EC 25 (lb a.i./acre) NOAEC (lb a.i./acre) EC 25 (lb a.i./acre) NOAEC (lb a.i./acre)
All plants

tested / (EP; 5.2%) >0.30 0.30 (no effects) >0.30 0.30 (no effects) 45649809;

45649810 Acceptable; Acceptable

EP = End-Use Product; ND = No data; -- = not applicable

1 5 days of exposure via the diet, followed by 8 days of observation of chemical free diet; however, clinical signs of toxicity, body weight reductions and decreas ed food consumption were observed in all treatment levels. Mortality was observed in two test concentrations, but was <50%.

2 At this time a new study is not required as the residue values at this time are below the level that would result in chronic effects. However, if the label is ad justed in the future, the study may not be adequate to

evaluate risk to birds.

3 Animals used were 51 weeks of age and laid eggs 3 weeks into the study.

4 30 ppm a.i. = 1.99 mg a.i./kg-body wt/day for males and 2.44 mg a.i./kg-body wt/day for females; 100 ppm a.i. = 6.59 mg a.i./kg-body wt/day for males and 8.60 mg a.i./kg-body wt/day for females



## c. Ecological Incidents

The ecological incident information system (EIIS ) is an OPP database that houses ecological incidents that have been reported to the Agency. When available, EIIS includes date and location of an incident, type and magnitude of effects obs erved in various species, use(s) of pesticides known or suspected of contributing to the incident, and results of a ny chemical residue analysis or other analyses conducted during incident investig ation. EIIS incidents are categorized according to the certainty that the incide nt resulted from pesticide exposu re. The Avian Monitoring System

### 21 (AIMS) is a database administered by the Amer ican Bird Conservancy th at contains publicly available data on reported avian inci dents involving pesticides. Many of the incidents listed in this database are also in the EIIS. The Aggregate Incide nt Reports database is an Agency database that may contain minor wildlife and plant incidents for chemicals.

As of August 12, 2014 no ecological incidents invol ving fenpyroximate were identified in EIIS, AIMS or the aggregate incident database. Incident databases will be reviewed again at the time of

the risk assessment.



## 7. Exposure Pathways of Concern

The conceptual model will consider the parent co mpound and its degradates (M-1 and M-3) for the drinking water exposure assessment; whereas for th e ecological risk assessment the residues of concern are the parent com pound and the M-1 degradate.

The environmental fate properties and use patter ns of fenpyroximate indi cate that direct spray, spray drift, and runoff represent potential transport mechanisms to aquatic and terrestrial organisms. Drinking water and inhalation expo sure pathways were sc reened using the SIP (Screening Imbibition Program, version 1.0) and STIR (Screening Tool for Inhalation Risk, version 1.0) screening methods a nd were found to be exposure path ways of low concern (no LOC exceedances are expected; outputs for each model are located in Appendix A ). SIP and STIR are

described in detail at: http://www.epa.gov/oppefed1/models/terrestrial/index.htm

. 

## 8. Analysis Plan

a. Stressors of Concern

i. Ecological Risk Assessment

Fenpyroximate, M-1, and M-3 are th e residues of concern for ma mmals (and other terrestrial organisms, by extension). Due to structural simila rity and lack of toxicity data, the residues of

concern for mammals are assumed to ha ve equivalent toxi city (USEPA, 2003).

Acute ecotoxicity data indicate th at M-3 is four orders of magn itude less toxic than the parent compound to fish and aquatic invertebrate s (MRIDs 46974401 and 46974402). Due to the large difference in acute toxicity between fenpyroximate and M-3 to aquatic animals, M-3 is also considered to be less toxic to aquatic animals on a chronic exposure basis and less toxic to aquatic plants. Therefore, the residues of concern fo r aquatic organisms are fenpyroximate and its cis isomer M-1, which are assumed in the lack of data to have equivalent toxicity.

ii. Drinking Water

The drinking water assessments conducted to suppor t the registration review human health risk assessments of fenpyroximate will incorporate model estimates of fenpyroximate residues of concern, which are parent compound, M-1, and M- 3 (USEPA, 2003), in surface and ground waters using the total residues of concern (TR) mode ling approach. Unextracted residues may be included if additional information ( e.g. , solvent exploration) indicate s that the unextracted residues

in MRIDs 45187901 and 46158501 are not well sorbed to so il or if additional information are not

### 22 available. Current exposure models, currently including SWCC and PRZM-GW, will be used. The fenpyroximate residues of concern may be reevaluated pending receipt and review of additional environmental fate and toxicity data for fenpyroximate and its degradates.



## b. Measures of Exposure

EFED will use standard available m odels to evaluate potential expos ures to aquatic and terrestrial organisms as described at http://www.epa.gov/oppefed1/models/water/index.htm and http://www.epa.gov/pesticides/science/models_db.htm

.

Screening level calculations have suggested that drinking water a nd inhalation exposure pathways are likely not of concern ( Appendix A ). These exposure pathways will not be considered at the

time of the risk assessment.

i. Available Monitoring Data

The Agency is not aware of m onitoring conducted by federal and st ate agencies for fenpyroximate, as of May 21, 2014. Monitoring will be considered in the assessment to the extent that data on fenpyroximate are available.



## c. Measures of Effect

Toxicity data presented in Section 3 of this pr oblem formulation will be used to calculate risk quotients. Any additional information submitted by th e registrant or found in the open literature prior to conduct of the risk assessment will also be considered. The open literature studies are identified using EPA’s ECOTOXicol ogy database (ECOTOX) (USEPA, 2007 c ), which employs a literature search engine for locating chemical toxici ty data for aquatic life, terrestrial plants, and

wildlife. The evaluation of both sources of data can also pr ovide insight into the direct and indirect effects of pesticides on biotic communities from loss of species that are sensitive to the chemicals and from changes in structure and functional characteristics of the affected

communities.

Initial searches of the ECOTOX database has identified literature highlighting potenti al interaction of fenpyroximate and other pesticides within hives, resulting in in creased toxicity of fenpyroximate toxicity to bees relative to toxi city of the compound alone. The risk assessment will consider all available information, including open literature, examining potential uncertainties surrounding and evaluating potential exposure and risk to various taxa of concern including pollinators. Additional information is needed, but uncer tainty associated with risks to bees needs to be evaluated with more data to different life stages. Open literature data may address some

uncertainties.



## 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 (listed) 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/endange r/litstatus/riskasses.htm

.

### 23 

## 10. Endocrine Disruptor Screening Program

As required by FIFRA and FFDCA, EPA reviews num erous studies to asse ss potential adverse outcomes from exposure to chemicals. Collectiv ely, these studies includ e acute, subchronic and chronic toxicity, including asse ssments of carcinogenicity, ne urotoxicity, developmental, reproductive, and general or systemic toxicity. These studies include e ndpoints which may be susceptible to endocrine influe nce, including effects on endocri ne target organ histopathology, organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and chronic studies that assess growth, deve lopmental and reproductive effect s in different taxonomic groups. As part of its most recent registration decision, EPA reviewed these data and selected the most sensitive endpoints for relevant risk assessment scenarios from the existing hazard database. However, as required by FFDCA section 408(p), di clofop-methyl is subject to the endocrine screening part of the Endocrine Di sruptor Screening Program (EDSP).

EPA has developed the EDSP to determine whether certain substances (inc luding pesticide active and other ingredients) may have an effect in humans or wildlife si milar to an effect produced by a “naturally occurring estrogen, or ot her such endocrine effects as th e Administrator may designate.” The EDSP employs a two-tiered approach to making the statutorily required determinations. Tier 1 consists of a battery of 11 scr eening assays to identify the poten tial of a chemical substance to interact with the estrogen, androge n, or thyroid (E, A, or T) horm onal systems. Chemicals that go through Tier 1 screening and are foun d to have the potential to interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 testing is designed to identify any

adverse endocrine-related eff ects caused by the substance, an d establish a dose-response relationship between the dose a nd the E, A, or T effect.

Under FFDCA section 408(p), the Agency must scre en all pesticide chemicals. Between October 2009 and February 2010, EPA issued test orders/dat a call-ins for the firs t group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredient s. A second list of chemicals identified for EDSP screening was published on June 14, 2013 and includes some pesticides scheduled for registration review and chemicals found in water. Neither of these lists should be

construed as a list of known or likely endocrine disruptors.

Fenpyroximate was not include d in either the first or second list of chemicals issued an order to conduct Tier 1 EDSP testing. For further informati on on the status of the EDSP, the policies and procedures, the lists of chemicals, future lists, the test guidelines and the Tier 1 screening battery, visit the website, http://www.epa.gov/endo/

. 

## 11. Preliminary Identification of Data Gaps

a. Environmental Fate

Table 8 and Table 9 identify environmental fate 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.

### 24 Table 8. Submitted Environmental Fate Data for Fenpyroximate

OCSPP

Guideline Data Requirement Submitted Studies (MRID) Study

Classifications Sufficient

for risk

assessment? Current Additional Data Need

835.2120 Hydrolysis 44847909 Acceptable Yes —
835.2240 Aqueous photolysis 44781016 Acceptable Yes —
835.2410 Soil photolysis 4 5649705 Acceptable Yes —

835.4100 Aerobic soil

metabolism 44781017 Unacceptable

No Depending on whether the soils in

MRID 45187901 are similar to domestic soils where fenpyroximate may be used, studies on 1-3 additional soils are needed (see p. 25 for discussion). 44847910 Unacceptable

45187901/

45649706 Upgradeable

46158501 Supplemental

835.4200 Anaerobic soil

metabolism (None) (Not applicable) Yes —

835.4300 Aerobic aquatic

metabolism 47521406 Supplemental Yes —

835.4400 Anaerobic aquatic

metabolism 4564 9707 Acceptable No A guideline-compliant study of one

sediment and its associated water is

needed.

835.1230

835.1240 Adsorption/ desorption and leaching 44781018 Unacceptable

Yes — 44781019 Unacceptable
44781020 Unacceptable
44847911 Unacceptable
45649709 Supplemental

835.6100 Terrestrial field dissipation 45649710/

45649711 Supplemental

Yes The field studies are not acceptable, in part, because the storage stability data are inadequate. However, additional studies are not expected to change assessment conclusions. 45649712/

45734203 Supplemental

850.1730 Fish

bioconcentration 45649713 Supplemental No A guideline-compliant study with

two test concentrations is needed. 48381102 Supplemental
850.6100 Analytical method

in soil 45649915 Upgradeable

No ILV reports are needed to upgrade

MRIDs 45649914 and 45649915. Analytical method

in water 45649914 Upgradeable

Analytical method

in freshwater 46847201 Unacceptable



### Table 9. Submitted Environmental Fate Da ta for Degradates of Fenpyroximate

OCSPP

Guideline Data Requirement Degradates Submitted Studies (MRID) Study

Classifications Sufficient for

risk assessment? Current Additi onal Data

Need 835.1230 Adsorption/ desorption M-3 45649708 Acceptable Yes — M-8, M-11 47521401 Supplemental



### Aerobic Soil Metabolism

Soil taxonomy information for the studied soils in MRID 45187901 are needed. If this information

indicates that the soils are not comparable to domestic soils wher e fenpyroximate is used, then the study will be unacceptable and a new aerobic soil me tabolism study should include three soils. If soil taxonomy information indicates that the tw o soils are similar to domestic soils where fenpyroximate is used, then a new aerobic soil metabolism study of only one soil will be needed.

### 25 It is uncertain whether unextracted residues in th e laboratory studies were well sorbed to soil and not readily available because extraction solvents with a wide range of dielectric constants (including polar and nonpolar solv ents) were not explor ed and concentrations of unextracted residues were up to 60% of the applied and displa yed variable formation pa tterns (peaki ng prior to study termination in some systems and at study te rmination in others). Use of reflux, Soxhlet,

and/or harsh extraction methods (using strong acids or bases) does not substitute for the use of multiple polar and nonpolar solvents.

Unextracted residues appear to include degradat es of fenpyroximate rather than the parent compound because the sterile system in MRID 47521406 did not produce appreciable amounts of unextracted residues (i.e., up to 1.3% of the applied) 105 days afte r treatment. This means that the uncertainty in the availability of the unextracted residues leads to uncertainty in the amounts of degradates formed, not uncertainty in the degrad ation rates of the pare nt compound. Therefore,

this issue is relevant to dri nking water exposure assessment, not to ecological risk assessment.

Information is needed to demonstrate that a ra nge of nonpolar and polar ex traction solvents do not substantially reduce the unext racted residue concentra tions at a latter sampli ng interval at or near study termination when unextracted residues are at least >20% of th e applied in one of the aerobic soil metabolism studies. Informal (non-GLP-comp liant) documentation of solvent exploration may suffice rather than a new aerobic soil metabolis m study. If the solvent exploration indicates directly or by inference that the unextr acted residues in MRIDs 45187901 and 46158501 are well sorbed to soil, their kinetics half-lives will be less than otherwise. If the solvent exploration

indicates that the unextracted residues in MRIDs 45187901 and 46158501 are not well sorbed to soil, then the unextracted residue s may be considered available re sidues of concern and included in

the kinetics half-lif e calculations for drinking water exposure assessment.

Anaerobic Aquatic Metabolism

Anaerobic aquatic metabolism information are ava ilable for only one sedime nt:water system. A study of a second sediment and its associated wa ter is needed to reduce uncertainty in the environmental fate of fenpyroximate in suboxic waters.

Fish Bioconcentration

Additional fish bioconcentration data are needed due to the de ficiencies noted in MRID 45649713 and MRID 48381102. Among other deficien cies, both MRID 45659713 and 48381102 were conducted with only one test concentration. Tw o test concentrations need to be studied concurrently in a fish bioconcentration study to characterize the uptake an d depuration kinetics. Given that fenpyroximate has already been shown to bioconcentrate to a de gree that could be of concern, the additional information provided by testi ng two concurrent test concentrations will be important to risk assessment. This study shoul d include two test con centrations, should not include a solvent, should identify and quantify any transformation product s of the test compound, and should meet the other guideline crit eria for conducting an acceptable study.

Independent Laboratory Validations

The submitted analytical methods in water and soil (MRIDs 45649914 and 46549915) are not acceptable without independent laboratory valida tion (ILV) reports indicating that they are reproducible, accurate, and precise at the stated limits of quantita tion (LOQ). Rather than submit

### 26 ILV reports for the submitted methods, submission is encouraged of new, st ate-of-the-art methods (and associated ILV reports), typi cally using LC/MS/MS equipment, that can be performed with the least amount of cost and effort. It is also recommended to base the submitted methods on any existing multi-residue methods. The LOQs for the submitted methods are less than toxicological levels of concern for aquatic organisms and terre strial plants. Therefor e, if new methods are submitted, their LOQs need not be lower.

E-fate Data Gap Summary

In summary, an aerobic soil metabolism study (O CSPP Guideline 835.4100) of one to three soils with adequate extraction efforts is needed. The number of soils tested depends on whether MRID 46158501 is upgraded with soil taxonomy data relati ng the soils to domestic soils. An anaerobic aquatic metabolism study (OCSPP Gu ideline 835.4400) of one sediment:water system is needed. A fish bioconcentration study (OCSPP Guide line 850.1730) is needed. And ILVs (OCSPP Guideline 850.6100) of the submitted analytical met hods in soil and water are needed. However, new, state-of-the-art methods and associated ILV reports may be (and are encouraged to be) submitted rather than ILV reports for the submitted analytical methods.



## b. Effects

Table 10 and Table 11 identify ecological effects 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. Rationale for the additional data requ ested is presented below

the tables.

For the degradate M-3, toxicity da ta are available for acute freshwater fish and invertebrates (see

Table 12 ). No toxicity data is currently availabl e for the M-1 degradate of fenpyroximate, and no toxicity data will be requested. A cursory look at the modeling indicated that the conducting of these studies to demonstrate that M-1 degradat e was less toxic would not provide substantive changes to the risk assessment because it is a major degradate only from degradation from photolysis, which is a minor degradation pa thway in PRZM/EXAMS modeling. Therefore, exposure to the M-1 degradate is expected to be negligible. Therefore, the data for M-3 are sufficient for the registration review risk assessment for fenpyroximate.

Table 10. Submitted Aquatic Ecologica l Effects Data for Fenpyroximate

OCSPP

Guideline Data Requirement Submitted

Studies (MRID) Study Classifications Are data

needed to

conduct

risk

assessment? Comments

850.1010 Freshwater

invertebrate acute toxicity 44781015 Acceptable
No None 46800801* Acceptable

850.1025

850.1035

850.1045

850.1055 Saltwater

invertebrate acute toxicity 45649804 Acceptable

No None 45649806 Invalid

47021401 Acceptable

850.1075 44781014 Supplemental No

### 27 OCSPP

Guideline Data Requirement Submitted

Studies (MRID) Study Classifications Are data

needed to

conduct

risk

assessment? Comments

Freshwater fish acute toxicity 45477201 Addendum #1 to

44781014 With a review of the addendums

associated with 44781014 & 4569803 (45477201 (DP, 46188801 (DP332653) & 47021402 (DP336524), respectively) the risk conclusions would not change as the endpoint values in these studies are less sensitive than the acceptable toxicity data for freshwater fish 47098102 (EUP = 0.44 ppb) & 46799201 (TGAI = 0.73 ppb). 45649721 Acceptable

45649801* Acceptable

45649803 Supplemental

46188801 Addendum #2 to

44781014

46799201 Acceptable

47021402 Addendum to

45649803

47098102* Acceptable

850.1075 Saltwater fish acute toxicity 45649805 Invalid

No None 46188802 Supplemental

47098101 Acceptable

850.1300 Freshwater

invertebrate life cycle 47098103 Acceptable

No With a review of the addendum

associated with MRID 45649807 (46188804 under DP332653) the risk conclusion would not change as the endpoint value in this study is slightly less sensitive than the acceptable chronic toxicity data for daphnids MRID 47098103 (TGAI NOAEC = 0.68 ppb vs. 0.56 ppb (from the acceptable study)). 45649807 Invalid

46188804 Addendum to

45649807

850.1350 Saltwater

invertebrates life cycle 47521405 Supplemental YES Data is needed; See explanation

below

850.1400 Freshwater fish early-life stage 45649808 Supplemental

No The DER reported that the stability of fenpyroximate the test systems was not sufficiently verified. Only at the highest

concentration were both LSC and HPLC/RAM analyses performed, and HPLC/RAM analyses revealed that fenpyroximate accounted for only 53 to 89% of the applied radioactivity. Since

HPLC/RAM results were not consistent with LSC results, it is unclear if fenpyroximate degraded in the test systems, was limited by solubility, or if

some other factor was involved. This deviation affects the acceptability of the study. The submitted information in

the addendum does provide a logical and scientifically based argument support for the registrant’s argument. Although, the information provided does not upgrade the study; no

additional data is needed. 46188803 Addendum to

45649808

### 28 OCSPP

Guideline Data Requirement Submitted

Studies (MRID) Study Classifications Are data

needed to

conduct

risk

assessment? Comments

850.1400 Saltwater fish early-life stage None; No
data N/A – No data No No chronic data. However, freshwater fish are two orders of magnitude more

sensitive on acute basis than

estuarine/marine fish and on a chronic basis it is likely we already have the most sensitive fish species. Freshwater

fish data can be used as a conservative estimate of fish toxicity. Therefore, no additional resources to conduct a study

with estuarine/marine fish is needed.

850.1500 Fish full lifecycle 48735301 In Review In Review;

No The study was submitted in response to a data requirement from a previous registration action. Preliminary review of the study suggests that it may be usable within the fenpyroximate risk

assessment. However, a more refined analysis of the data is being completed

to determine the scientific soundness and usability of the study within the

risk assessment.

850.1735 Freshwater
invertebrate –

acute sediment toxicity 48381101 In Review In Review;

No The study was submitted in response to a data requirement from a previous registration action. While, a more refined analysis of the data will be completed to determine the scientific soundness of the study for use within the risk assessment, based on a preliminary review, suggests that it may be usable within the fenpyroximate risk assessment.

Nonguideline Freshwater

invertebrate –

chronic

sediment toxicity 46847202 Invalid No Based on a preliminary review of the data, no effects were observed in the 10-day Midge ( Chironomus tentans ) study using spiked sediment and

therefore no additional sediment toxicity data is needed.

850.4400 Aquatic plant Toxicity Test using Lemna

spp. 45649811 Acceptable No None

850.4500 Algal toxicity 45649812 Acceptable

No None 45649814 Acceptable

45649815 Acceptable

45649816 Supplemental

45649817 Supplemental

850.4550 Cyanobacteria 4564 9813 Acceptable No None
*Formulated product exposure.

### 29 Table 11. Submitted Terrestrial Ecologi cal Effects Data for Fenpyroximate

OCSPP

Guideline Data Requirement Submitted

Studies (MRID) Study

Classifications Are data

needed for

risk

assessment? Comments

850.2100 Avian oral toxicity 45649714 Acceptable

Yes Passerine species - acute oral toxicity study is not available. Chemical is practically non-toxic; however, clinical signs of toxicity, body weight reductions and decreased food consumption were

observed in all treatment levels in the mallard duck subacute dietary study. Mortality was observed in two test concentrations, but was <50%,

see discussion below. 45649715 Acceptable

850.2200 Avian dietary toxicity 44847908 Acceptable

No None 45649716 Acceptable

850.2300 Avian reproduction 45649717 Supplemental (range finder for 45649718)

No At this time a new study is not required as the residue values at this

time are below the level that would result in chronic effects. However, if the label is adjusted in the future, the study may not be adequate to

evaluate risk to birds. The mallard duck study used birds that were 51 weeks of age and laid eggs 3 weeks into the study. 45649718 Supplemental

45649719 Supplemental

45649720 N/A (see comments)

47521403 Supplemental

47521404 Supplemental

Nonguideline Avian inhalation None N/A No None

850.3020 Honeybee acute contact toxicity 45649818* Acceptable No None

OECD 213 Honeybee acute oral toxicity 45649819 Supplemental No None

OECD 237 Honeybee larval acute toxicity No data N/A YES Data is needed; See explanation

below

Nonguideline Honeybee larval chronic toxicity No data N/A YES Data is needed; See explanation below, protocol submission required prior to study initiation

Nonguideline Honeybee adult chronic toxicity No data N/A YES Data is needed; See explanation below, protocol submission required prior to study initiation

850.3030 Honeybee residue on foliage None N/A No Chemical is practically non-toxic.

### 30 OCSPP

Guideline Data Requirement Submitted

Studies (MRID) Study

Classifications Are data

needed for

risk

assessment? Comments

OECD 75 Semi-field testing for pollinators None N/A YES 1 1 Dependent on the results of the

lower Tier 1 effects studies. Higher tier studies are recommended

if the ratio of the EEC and larval or

adult bee acute LD50> 0.4 or the

ratio of the EEC and the chronic

NOAEC> 1 . Incident data and/or compelling open literature studies can also be used to support the need for higher tier studies. 850.3040 Field testing for pollinators None N/A YES 1

850.6200/

OECD 207 Sub-chronic
exposure to
earthworms 45649820 Supplemental

Not applicable None

Nonguideline Predatory mite

acute contact toxicity 45649821* Supplemental

Green lacewing

acute contact test 45649822* Supplemental

Ladybug acute

oral and contact

test 45649823* Supplemental

Predacious thrips

acute contact toxicity 45649824* Supplemental

Beneficial arthropods- acute contact toxicity 45649825* Supplemental

Predatory wasp ( Aphidius rhopalosiphi ),

extended residue study 48735302 In review No The study was submitted in response to a data requirement from a previous registration action. The study is currently in review, and the scientific soundness nor study

classification are not known. However, additional data will not be

needed to conduct the risk

assessment.

850.4100 Seedling Emergence and Seedling Growth 45649809 Acceptable No None

850.4150 Vegetative Vigor 4 5649810 Acceptable No None
*Formulated product exposure.

### 31 Table 12. Aquatic Ecological Effects Data for the Fenpyroximate Degradate, M-3

OCSPP

Guideline Data Requirement Submitted
Studies (MRID) Study

Classifications Are data needed

for risk

assessment? Comments

850.1010 Freshwater

invertebrate acute toxicity 46974401 Acceptable No Toxicity data was submitted for the M-3 degradate only.

850.1075 Freshwater fish acute toxicity 46974402 Supplemental No Toxicity data was submitted for the M-3 degradate only.



### Freshwater Fish Full-Life Cycl e Toxicity (Still in Review)

A study was received by the Agency evaluating toxi city to freshwater fish looking at the fish full life-cycle, and it is currently under review. Until the review is finalized, potential risk to freshwater fish on a chronic exposure basis remain s an uncertainty. A more thorough analysis of the data will be completed to determine the scient ific soundness of the study for use within the risk assessment; however, initial revi ew of the study suggests that it may be usable within the fenpyroximate risk assessment.

Sediment-Dwelling Invertebrate Toxicity (Still in Review)

A study was received by the Agency regarding to xicity to sediment-dwelling organisms and is currently under review. Preliminar y review of the study s uggests that it may be usable within the fenpyroximate risk assessment.

Estuarine/Marine Fish Early Life-Stage Toxicity Study

Although no chronic toxicity data to evaluate the risks to estuarin e/marine fish is available, freshwater fish are two orders of magnitude more sensitive on acute basis than estuarine/marine fish and on a chronic basis it is likely we alread y have the most sensitive fish species. The

freshwater fish data can be used as a c onservative estimate of fish toxicity; and the estuarine/marine fish toxicity on a chronic basi s will likely not be more sensitive than freshwater fish. Therefore, no additional resources to conduct a study with estuarine/marine fish is needed.

Mysid Chronic Toxicity

The reported NOAEC from the mysid life-cycle toxi city study is uncerta in because it does not account for effects to offspring. No informa tion was measured or recorded for the second generation mysids, whereas the OCSPP (form. OPPTS) guidance recommends that the offspring be maintained. Additionally, the survival and gr owth parameters (length and weight) were not separated by sex, and so no sex-specific anal yses could be conducted from the available information. The study cannot be used to fulfill guideline requirements. Effects to estuarine/marine invertebrate offspring may be underestimated using the reported NOAEC. As a result, the submitted study does not fulfill gui deline requirements and there were key reproductive endpoints missing from the submitted study, and a new study is needed.

### 32 Avian Acute Oral Toxicity – Passerine Species

The dietary and dose-based EECs fo r small birds consuming short grass (most conservative) are 143 ppm and 163 mg/kg-bw, respectively. No mort ality or sublethal effects were observed in either the acute oral or subacute dietary toxicity tests for bobwhite quail or the acute oral toxicity study for mallard ducks. However, mortality an d sublethal effects were both observed in the subacute dietary toxicity study for mallard duc ks. Although mortality was observed it was less than 50% in all treatment levels (three total); how ever, clinical signs of toxicity were observed in all treatment groups (for a majority of the birds) up to 7 days afte r dosing. Observations include a reduction in body weight and feed consumption, nut ation, unkemptness, decr eased growth, and the NOAEC < 2017 ppm). Although there is a low applica tion rate, there is a pot ential for exposure to passerine birds that cannot be dismissed, especially in light of the observed sublethal effects in the mallard duck dietary study. Based on this review , toxicity testing usi ng passerine species is

needed.

Honeybee Toxicity

Although fenpyroximate is categorized as practically non-toxic to adult h oneybees on contact and oral exposure basis, and by extension, to other beneficial terrestrial i nvertebrates on an acute exposure basis, there is consider able uncertainty regarding the potential effects of the compound on honeybee larval development and survival as we ll as potential for chr onic effects due to the mode of action. Fenpyroximate causes inhibition of molting of all immature stages, inhibits oviposition, and decreases feeding ac tion. Therefore, additional da ta on pollinators is needed to fully characterize the risk asso ciated with fenpyroximate use to all developmen tal stages of honeybees, as sensitivity may vary according to lif e-stage and length of exposure (adult vs. larval and acute vs. chronic, respectivel y). Additional information is n eeded, but uncertainty associated

with risks to bees need to be eval uated with more data to different life stages. Open literature data is needed to help better characterize some uncer tainties regarding potential effects to bees and other non-target terrestrial inve rtebrates. In addition, higher tier effects toxicity tests ( i.e., semifield and/or field studies – Tier II and Tier III, respectively) may be needed, based on the results of

the larval and chronic adult toxici ty studies. Higher tier studies ar e recommended if the ratio of the

EEC and larval or adult bee acute LD50> 0.4 or the ratio of the EEC and the chronic NOAEC> 1

. Incident data and/or compelling op en literature studies can also be used to support the need for higher tier studies. Should th e screening level risk assessment iden tify that there are risk concerns to bees, mitigation measures may need to be consid ered or the registrant may need to conduct Tier II or Tier III effects studies ( e.g. OECD Guideline 75 and/or 850.3040 guideline studies) that reduce uncertainty by characterizing fenpyroxima tes’s effects at th e whole-colony level 1



### .

1 http://www2.epa.gov/pollinator-protection/pollinator-risk-assessment-guidance

.

### 33 Guideline Number: Non-Guideline Study Title: Larval Honey Bee Acute and Chronic Oral Toxicity Rationale for Requiring the Data

These studies are needed for the assess ment to evaluate risks to hone y bees if the registered uses will result in bee exposure. Fenpyroximate uses include ae rial and ground applications to agricultural crops including citrus, cotton, vegetables including cucumber s, melons, fruits including pome, stone, and tree nuts as well as ornamentals and greenhouse uses wher e spray drift may land on blooming non-target plants and result in residues in pollen and nectar (w hich could then be transported to the hive). Additionally, fenpyroximate is rela tively non-volatile, lipophilic, and slight ly to hardly mobile in soil. Fenpyroximate causes inhibition of molting of all imma ture stages, inhibits oviposition, and decreases feeding action. Therefore, additiona l data on pollinators is needed to fu lly characterize the risk associated with fenpyroximate use to all developmental stag es of honeybees, as sensitivity may vary according to life-stage and length of exposure. R esidues 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. Therefore, exposure at all bee life stages would be expected.

The Agency finalized its framewo rk to assess risk to pollinators (USEPA, 2014). EPA now requires these studies for all use sites where potential exposure to pollinators may occur. Registrants may request a waiver of the studies if use practices significantly restrict exposure of the pesticide to bees.

Although EPA has not developed a guideline for this study, the 21-day larval toxicity study currently under development by OECD provides both acute and chr onic oral toxicity data on developing bee brood and (when this guidance is finalized) may be used to satisfy the requirement for both acute and chronic oral toxicity to honey bee larvae. Registrants are at liberty though to submit a separate acute (single dose) larval toxicity study following OECD TG 237 as well as the 21-day repeat dose chronic toxicity study. For the chronic toxicity study though, since no guideline is available, a protocol is required to be submitted prior to study initiation. Practical Utility of the Data

How will the data be used and how could the data impact the Agency’s future decision-making?

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 (LD 50 ) 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. Effects on survival and development (adult bee emergence) from repeat expo sures to the active ingredient will be used in estimating chronic risk to individual brood. Risk estimates based on these data will be considered along with other lines of evidence to determine whether highe r-tier studies are needed at the whole colony level.

These data are needed for the registration review risk assessment and for future endangered species assessments. The data would allow the Agency be tter characterize the potential for risk to insects (including beneficial pollinators) from the use of fenpyroximate. This data may help the Agency determine whether any mitigations are needed. If the registration review a nd any future endangered species risk assessments are performed without these data, the Agency would have to assume that fenpyroximate "may affect" insects, including bees a nd beneficial pollinators, directly (and endangered species from other taxa indirectly), and uses of fenpyr oximate might need to be restricted in areas where pollinators could be exposed.

### 34 Guideline Number: Non-Guideline Study Title: Adult Honey Bee Chronic Oral Toxicity Rationale for Requiring the Data

These studies are needed for the assess ment to evaluate risks to hone y bees if the registered uses will result in bee exposure. Fenpyroximate uses include ae rial and ground applications to agricultural crops including citrus, cotton, vegetables including cucumber s, melons, fruits including pome, stone, and tree nuts as well as ornamentals and greenhouse uses wher e spray drift may land on blooming non-target plants and result in residues in pollen and nectar (w hich could then be transported to the hive). Additionally, fenpyroximate is rela tively non-volatile, lipophilic, and slight ly to hardly mobile in soil. Fenpyroximate causes inhibition of molting of all imma ture stages, inhibits oviposition, and decreases feeding action. Therefore, additiona l data on pollinators is needed to fu lly characterize the risk associated with fenpyroximate use to all developmental stag es of honeybees, as sensitivity may vary according to life-stage and length of exposure. Therefore, exposur e at all bee life stages would be expected and may extend for chronic exposures.

The Agency finalized its framework to assess risk to pollinators (USEPA, 2014). EPA now requires this study for all use sites where potential exposure to pollinators may occur. Registrants may request a waiver of the study if use practices significantly restrict exposure of the pesticide to bees.

Although EPA has not developed a guideline for this study and OECD has yet to finalize test guidance for chronic studies, efforts are currently underway to develop standardized guidelines for assessing effects from chronic (10-day) exposures to adult bees in the laboratory. A protocol is required to be submitted prior to study initiation. Practical Utility of the Data

How will the data be used and how could the data impact the Agency’s future decision-making?

The 10-day toxicity study with young adult bees pr ovides 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 indi vidual adult bees. Risk estimates based on these data will be considered along with other lines of evidence to determine whether higher-tier studies are needed at the whole colony level.

These data are needed for the registration review risk assessment and for future endangered species assessments. The data would allow the Agency be tter characterize the potential for risk to insects (including beneficial pollinators) from the use of fenpyroximate. This data may help the Agency determine whether any mitigations are needed. If the registration review a nd any future endangered species risk assessments are performed without these data, the Agency would have to assume that fenpyroximate "may affect" insects, including bees a nd beneficial pollinators, directly (and endangered species from other taxa indirectly), and uses of fenpyr oximate might need to be restricted in areas where pollinators could be exposed.

### 35 

## 12. References

United States Environmental Protection Agency (USEPA). 2003. Stokes, J., G. Reddy, and J. Breithaupt. Fenpyroximate: Conclusion and Briefing Memorandum for 07/09/03 Meeting of the Health Effects Division (HED) Me tabolism Assessment Review Committee (MARC). DP barcode 292639. U.S. Envir onmental Protection Agency, Office of Prevention, Pesticides, and Toxic Substan ces, Health Effects Division. Internal memorandum. Aug. 12, 2003.

USEPA. 2004. Overview of the Ecological Risk Assessm ent Process in the Office of Pesticide Programs . U.S. Environmental Protection Agency, Office of Pesticide Programs,

Environmental Fate and Eff ects Division. Available at http://www.epa.gov/espp/consultation/ecorisk-overview.pdf

USEPA. Kaul, M. 2007. Maximum Nu mber of Crop Cycles per Year in California for Methomyl Use Sites. U.S.Environmental Protection Ag ency, Office of Prevention, Pesticides, and Toxic Substances, Biological and Economic Analysis Division. Memorandum to M. Panger, Environmental Fate a nd Effects Division. Feb. 28, 2007.

United States Geological Survey (USGS). 2014. National Water-Quality Assessment (NAWQA) Program, Pesticide National Synthesis Pr oject, Pesticide Us e Maps – Diclofop. http://water.usgs.gov/nawqa/pnsp/usage/ maps/show_map.php?year=2011&map=FENPY ROXIMATE&hilo=L&disp=Fenpyroximate (accessed May 23, 2014)

USEPA, PMRA and CDPR, 2014. Guidance for Asse ssing Pesticide Risks to Bees. Office of Pesticide Programs, USEPA, Washington D.C. Health Canada Pest Management Regulatory Agency, Ottawa, ON, Canada. Ca lifornia Department of Pesticide Regulation, Sacramento, CA. June 23, 2014. Available at http://www2.epa.gov/pollinator-protectio n/pollinator-risk-assessment-guidance

.



## a. Submitted Product Chemistr y and Environmental Fate Studies

MRID Citation Reference

44781003 Todhunter, J.; Hill, J. (1999) Fenpyroximate--Technical Activ e Ingredient (TGAI) and Fenpyroximate 5% SC (End Use Product): Product Chemistry, Series 63: Lab Project Number: NNI-FENPY-99-003. Unpublished study prepared by SRS International Corporation. 19 p.

44781016 Swanson, M. (1993) Direct Photolysis of Pyrazole- 14 C-Fenpyroximate in a Buffered AqueousSolution Under Artificial Sunlight: Final Report: Lab Project Number: SC910077: SC910089: E4015. Unpublished study prepared by Battelle Memorial Institute. 126 p.

44847909 Saxena, A.; McCann, D. (1992) Hydrolysis of Pyrazole- 14 C-Fenpyroximate in Buffered Aqueous Solutions: Final Report: Lab Project Number: SC900192. Unpublished study prepared by Battelle Memorial Institute. 97 p.

45187901 Funayama, S.; Atsuko, H.; Izawa, Y. (1990) Degradation of [Pyrazole-14C] and [Benzyl-14C] Fenpyroximate in Soils Under Laboratory Conditions: Lab Project Number: E-4005. Unpublished study prepared by Nihon Nohyaku Co., Ltd. 52 p.

45649705 Concha, M. (2001) Photodegradation of 14 C-Fenpyroximate in/on Soil by Artificial Light: Lab Project Number: E-4030: 870W-1: 870W. Unpublished study prepared by PTRL West, Inc. 188 p.

### 36 MRID Citation Reference

45649706 Maks, M. (2002) Degradation of [Pyrazole-14C] and [Benzyl-14C] Fenpyroximate in Soils Under Laboratory Conditions: Lab Project Number: E- 4005. Unpublished study prepared by Nichino America, Inc. 8 p.

45649707 McKemie, T.; Shepler, K. (2001) Anaerobic Aquatic Metabolism of [ 14 C] Fenpyroximate: Lab Project Number: 889W-1: 889W: E-4031. Unpublished study prepared by PTRL West, Inc. 232 p.

45649708 Concha, M. (2002) Soil Adsorption/Desorption of [ 14 C] M-3 by the Batch Equilibrium Method: Lab Project Number: 1045W. Unpublished study prepared by PTRL West, Inc. 132 p.

45649709 Concha, M. (2002) Soil Adsorption/Desorption of [ 14 C ] Fenpyroximate by the Batch Equilibrium Method: Lab Project Number: 987W: E-4033. Unpublished study prepared by PTRL West, Inc. 151 p.

45649710 Burstell, H.; Sochor, H. (1994) Fenpyroximate Wa ter Miscible Suspension 50g/l: Investigation of the Degradation Behaviour in Soil Under Field Conditions: Lab Project Number: E-4028: ER91DEU824: A53773. Unpublished study prepared by Hoechst Schering AgrEvo GmbH. 55 p.

45649711 Specht, W. (1993) Determination of the Residues of Fenpyroximate (HOE 094552), M-1 (HOE 112573) and M-3 (HOE 112721) in Soil: Lab Pr oject Number: HOE-9107: 93615/91: A53773. Unpublished study prepared by Chemische Laboratorien GMBH. 146 p.

45649712 Baker, F.; Mickelson, K.; Hiler, R. (2001) Field Soil Dissipation of Fenpyroximate in Bare Ground in North Carolina, Arkansas, and California: Lab Project Number: 803W-1: 803W: E-4032. Unpublished study prepared by Research for Hire. 253 p.

45734203 Hiler, R. (2002) Quantifi cation of Metabolites M-3, M-8, and M-11 in Soil from Field Soil Dissipation of Fenpyroximate in Bare Ground in North Carolina, Arkansas and California: Lab Project Number: E-4038: 1026W: 1026W-1. Unpublished study prepared by Research for Hire. 855 p.

46158501 Shepler, K. (2003) Aerobic Soil Metabolism of [ 14 C ] Fenpyroximate. Project Number: 1038W. Unpublished study prepared by PTRL West, Inc. 160 p.

47521406 Volkl, D. (2001) [ 14 C] Fenpyroximate (NNI-850) [Pyrazole-la belled] Degradation and Metabolism in Aquatic Systems. Project Number: E/4027/SUPP/1 , 7L365. Unpublished study prepared by RCC Ltd. 134 p.

48381102 Thomas, S.; Kendall, T.; Krueger, H. (2010) Fenpyroximate: A Bioconcentration Test with the Bluegill (Lepomis macrochirus): Final Report. Project Number: 397A/140. Unpublished study prepared by Wildlife International, Ltd. 93 p.



## b. Submitted Ecological Toxicity Studies

MRID Citation Reference

45649714 Tolle, D. (1991) Avian Single-Dose LD (50) Test of Fenpyroximate in Mallard Ducks: Final Report: Lab Project Number: SC910033. Unpublished study prepared by Battelle. 46 p.

45649715 Tolle, D. (1991) Avian Single-Dose LD (50) Test of Fenpyroximate in Bobwhite Quail: Final Report: Lab Project Number: SC910018: W-4031. Unpublished study prepared by Battelle. 44 p.

44847908 Tolle, D. (1991) 8-Day Avian Dietary LC50 Test of Fenpyroximate in Bobwhite Quail: Final Report: Lab Project Number: SC910016: W-4015. Unpublished study prepared by Battelle. 76 p.

45649716 Tolle, D. (1991) 8-Day Avian Dietary LD (50) Test of Fenpyroximate in Mallard Ducks: Final Report: Lab Project Number: SC910017: W-4016. Unpublished study prepared by Battelle. 77 p.

45649717 Stadens-Peek, W.; Frieling, W. (1997) 6-Weeks Dietary Study in Mallard Duck with Fenpyroximate (Pilot Dietary Study for Reproduction Study): Lab Project Number: 191778: 67455: W-4046. Unpublished study prepared by NOTOX B.V. 39 p.

### 37 MRID Citation Reference

45649718 van Dreumel, I.; Frieling, W. (1997) Reproduction Study in Mallard Duck with Fenpyroximate (By Dietary Admixture): Lab Project Number: 191047: 67455: W-4047. Unpublished study prepared by NOTOX B.V. 154 p.

45649719 Frieling, W. (2001) Reproduction Study in Bobwhite Quail with Fenpyroximate Technical (By Dietary Admixture): Lab Project Number: 265027: 64577: W-6062. Unpublished study prepared by NOTOX B.V. 210 p. {OPPTS 850.2300}

45649720 Todhunter, J. (2002) Analysis and Evaluation of Data from a Fenpyroximate Reproduction Study in Bobwhite Quail Conducted at NOTOX B.V: Lab Project Number: W-4062: 265027. Unpublished study prepared by SRS International Corp. 21 p.

47521403 Temple, D.; Martin, K.; Beavers, J.; et al. (2008) Fenpyroximate: A Reproduction Study with the Mallard: Final Report. Project Number: 397/106. Unpublished study prepared by Wildlife International, Ltd. 156 p.

47521404 Temple, D.; Martin, K.; Beavers, J.; et al. (2008) Fenpyroximate: A Reproduction Study with the Northern Bobwhite: Final Report. Project Number: 397/105. Unpublished study prepared by Wildlife International Ltd. 159 p.

44781014 Knacker, T.; Brodesser, H.; Schallnab, H. et al. (1992) A Study of the Acute Toxicity to Fish (Oncorhynchus mykiss) of Fenpyroximate Under Fl ow-Through Conditions: Final Report (Revised): Lab Project Number: BF-EA-101-91-01-FIA-1. Unpublished study prepared by Battelle Europe. 62 p.

45477201 Maks, M. (2001) Addendum 1 to A Study of the Acute Toxicity to Fish (Oncorhynchus mykiss) of Fenpyroximate Under Flow-Through Conditions: Lab Project Number: BE-EA-107-91-01-FIA-1. Unpublished study prepared by Battelle Europe, and Nihon Nohyaku Company, Ltd. 15 p.

45649721 Dionne, E. (2001) Fenpyroximate Technical --Acute Toxicity to Bluegill Sunfish (Lepomis macrochirus) Under Flow-Through Conditions: Lab Project Number: 13657.6134: W-4055. Unpublished study prepared by Springborn Laboratories, Inc. 55 p. {OPPTS 850.1075}

45649801 Dionne, E. (2001) Fenpyroximate 5% EC--Acute Toxicity to Bluegill Sunfish (Lepomis macrochirus) Under Flow-Through Conditions: Lab Project Number: 13657.6141: W-4060: 093098/FIFRA/OPPTS/1. Unpublished study prepared by Springborn Laboratories, Inc. 55 p. {OPPTS 850.1075}

45649802 Knacker, T.; Brodesser, J.; Schallnass, H.; et al. (1992) A Study of the Acute Toxicity to Fish (Cyprinus carpio) of Fenpyroximate Under Flow-Through Conditions: Final Report: Lab Project Number: BE-EA-107-91-01-F5A-: W-4004. Unpublished study prepared by Battelle Europe. 66 p.

45649803 Dionne, E. (2001) Fenpyroximate 5% EC--Acute Toxicity to Rainbow Trout (Oncorhynchus mykiss) Under Flow-Through Conditions: Lab Project Number: 13657.6140: W-4059. Unpublished study prepared by Springborn Laboratories, Inc. 55 p. {OPPTS 850.1075}

46188801 Habig, C. (2004) Addendum 2 to A Study of the Acute Toxicity to Fish (Oncorhynchus mykiss) of Fenpyroximate Under Flow-Through Conditions (MRID # 44781014). Project Number: BE/EA/107/91/01/FIA/1. Unpublished study prepared by Battelle Europe and Nihon Nohyaku Co. Ltd. 6 p.

47021402 Maks, M. (2007) Supplement 1 to Fenpyroximate 5 Percent EC-Acute Toxicity to Rainbow Trout (Oncorhynchus mykiss) Under Flow-Through Conditions. Project Number: 13657/6140, W/4059. Unpublished study prepared by Springborn Smithers Laboratories. 7 p.

46799201 Palmer, S.; Kendall, T.; Krueger, H. (2006) Fenpyroximate TGAI: A 96-Hour Static-Renewal Acute Toxicity Test With the Rainbow Trout: Final Report. Project Number: 397A/105. Unpublished study prepared by Wildlife International, Ltd. 40 p.

46974402 Pawlowski, S.; Wydra, V. (2005) Acute Toxicity of M-3, A Fenpyroximate Matabolie, to Rainbow Trout (Oncorhynchus mykiss) in a 96-Hour Static Test: Final Report. Project Number: 23771230. Unpublished study prepared by Institut fuer Biol ogische Analytik und Consulting IBACON. 58 p.

### 38 MRID Citation Reference

47021402 Maks, M. (2007) Supplement 1 to Fenpyroximate 5 Percent EC-Acute Toxicity to Rainbow Trout (Oncorhynchus mykiss) Under Flow-Through Conditions. Project Number: 13657/6140, W/4059. Unpublished study prepared by Springborn Smithers Laboratories. 7 p.

47098102 Palmer, S.; Kendall, T.; Krueger, H. (2007) Fenpyroximate 5% EC: A 96-Hour Flow - Through Acute Toxicity Test with the Rainbow Trout (Oncorhynchus mykiss): Final Report. Project Number: 397A/109. Unpublished study prepared by Wildlife International, Ltd. 43 p.

44781015 Knacker, T.; Zietz, E.; Scha llnab, H. et al. (1992) A Study of th e Acute Toxicity to the Freshwater Aquatic Invertebrate (Daphnia magna) of Fenpyroximate: Final Report (Revised): Lab Project Number: BE-EA-107-90-01-DAK-1. Unpublished study prepared by Battelle Europe. 55 p.

46800801 Palmer, S.; Kendall, T.; Krueger, H. (2006) Fenpyroximate 5%EC: A 48-Hour Static-Renewal Acute Toxicity Test with the Cladoceran (Daphnia ma gna): Final Report. Project Number: 397A/103A. Unpublished study prepared by Wild life International, Ltd. 43 p.

46974401 Motoba, K. (2005) Acute Immobilization Test of M-3, A Fenpyroximate Metabolite on Daphnia Magna: Final Report. Project Number: GC/12, 05/0035. Unpublished study prepared by Nihon Nohyaku Co., Ltd. 41 p.

45649805 Dionne, E. (2001) Fenpyroximate Technical--Acute Toxicity to Sheepshead Minnow (Cyprinodon variegatus) Under Flow-Through Conditions: Lab Project Number: 13657.6135: W-4057: 020499/FIFRA/OPPTS/F. Unpublished study prepared by Springborn Laboratories, Inc. 52 p. {OPPTS 850.1075}

46188802 Dionne, E. (2001) Fenpyroximate Technical - Acute Toxicity to Sheepshead Minnow (Cyprinodon variegatus) Under Flow-Through Conditions. Project Number: 13657/6135, W/4057, 020499/FIFRA/OPPTS/FT/SHM. Unpublished study prep ared by Springborn Laboratories Inc. 52 p.

47098101 Palmer, S.; Kendall, T.; Krueger, H. (2007) Fenpyroximate TGAI: A 96-Hour Flow - Through Acute Toxicity Test with the Sheepshead Minnow (Cyprinodon variegatus): (Fujimite 5EC Miticide/Insecticide): Final Report. Project Number: 397A/110. Unpublished study prepared by Wildlife International, Ltd. 41 p.

45649804 Dionne, E. (2001) Fenpyroximate Technical--Acute Toxicity to Mysids (Americamysis bahia) Under Flow-Through Conditions: Lab Project Number: 13657.6137: W-4058. Unpublished study prepared by Springborn Laboratories, Inc. 56 p. {OPPTS 850.1035}

45649806 Dionne, E. (2001) Fenpyroximate Technical--Acute Toxicity to Eastern Oyster (Crassostrea virginica) Under Flow-Through Conditions: Lab Project Number: 13657.6136: W-4056. Unpublished study prepared by Springborn Laboratories, Inc. 58 p. {OPPTS 850.1025}

47021401 Palmer, S.; Kendall, T.; Krue ger, H. (2006) Fenpyroximate TGAI: A 96-Hour Shell Deposition Test with the Eastern Oyster (Crassostrea virgin ica): Final Report. Project Number: 397A/111. Unpublished study prepared by Wild life International, Ltd. 40 p.

45649808 Sousa, J. (2001) Fenpyroximate Technical--The Toxicity to Fathead Minnow (Pimephales promelas) During an Early Life-Stage Exposure: Lab Project Number: 13657.6142: W-4061. Unpublished study prepared by Springborn Laboratories, Inc. 71 p.

46188803 Sousa, J. (2004) Supplement 1 to Fenpyroximate Technical-The Toxicity to Fathead Minnow (Pimephales promelas) During an Early Life-Stage Exposure (MRID No. 45649808). Project Number: 13657/6142, W/4061, 346230. Unpublished study prepared by Springborn Laboratories Inc. and Nihon Nohyaku Co. Ltd. 25 p.

45649807 Knacker, T.; Brodresser, J.; Reifenberg, P.; et al. (1992) A Study of the Chronic Toxicity to Daphnia of Fenpyroximate: Final Report: Lab Project Number: BE-EA-107-90-01-DCH-: W-4034. Unpublished study prepared by Battella Europe. 97 p.

46188804 Habig, C. (2004) Supplement 1 to A Study of the Chronic Toxicity to Daphnia of Fenpyroximate (MRID No. 45649807). Project Number: BE/EA/107/90/01/DCH/1: W/4034. Unpublished study prepared by Battelle Europe. 9 p.

### 39 MRID Citation Reference

47098103 Palmer, S.; Kendall, T.; Krueger, H. (2007) Fenpyroximate TGAI: A Flow - Through Life - Cycle Toxicity Test with the Cladoceran (Daphnia ma gna): Final Report. Project Number: 397A/106A. Unpublished study prepared by Wild life International, Ltd. 61 p.

47521405 Palmer, S.; Kendall, T.; Krueger, H. (200 7) Fenpyroximate TGAI: A Flow-Through Life-Cycle Toxicity Test with the Saltwater Mysid (Ameri camysis bahia): Final Report. Project Number: 397A/108. Unpublished study prepared by Wildlife International Ltd. 75 p

48381101 Thomas, S.; Krueger, H.; Kendall, T.; et al . (2010) Fenpyroximate: A 10-Day Survival and Growth Toxicity Test with the Midge Chironomus tentans Using Spiked Sediment: Final Report. Project Number: 397A/141. Unpublished study prepared by Wildlife International, Ltd. 73 p.

46847202 Heusel, R. (1997) Fenpyroximate (Carbon 14)- Labelled Chronic Toxicity to the Sediment Dwelling Chironomid Larvae (Chironomus riparius). Project Number: CE96/077, W/4044. Unpublished study prepared by Hoechst Schering Agrevo Gmbh. 60 p.

45649809 Teixeira, D. (2001) Fenpyroximate 5% EC--Determination of Effects on Seedling Emergence of Ten Plant Species: Lab Project Number: 13657.6157. Unpublished study prepared by Springborn Laboratories, Inc. 188 p. {OPPTS 850.4100, 850.4225}

45649810 Teixeira, D. (2001) Fenpyroximate 5% EC--Determ ination of Effects on Vegetative Vigor of Ten Plant Species: Lab Project Number: 13657.6158: 022301/OPPTS/VV. Unpublished study prepared by Springborn Laboratories, Inc. 143 p. {OPPTS 850.4150, 850.4250}

45649811 Hoberg, J. (2001) Fenpyroximate 5% EC--Toxicity to Duckweed, Lemna gibba: Lab Project Number: 13657.6154: N-4060. Unpublished study prepared by Springborn Laboratories, Inc. 54 p. {OPPTS 850.4400}

45649812 Hoberg, J. (2001) Fenpyroximate 5.0% EC--Acute Toxicity to Freshwater Diatom (Navicula pellicullosa): Lab Project Number: 13657.6151: N- 4056. Unpublished study prepared by Springborn Laboratories, Inc. 51 p. {OPPTS 850.5400}

45649813 Hoberg, J. (2001) Fenpyroximate 5.0% EC--Acute Toxicity to Freshwater Blue-Green Alga, Anabaena flos-aquae: Lab Project Number: 13657.6153: N-4057. Unpublished study prepared by Springborn Laboratories, Inc. 50 p. {OPPTS 850.5400}

45649814 Hoberg, J. (2001) Fenpyroximate 5.0% EC--Acute Toxicity to Freshwater Green Alga, Pseudokirchneriella subcapitata: Lab Project Number: 13657.6150: N-4058. Unpublished study prepared by Springborn Laboratories, Inc. 52 p. {OPPTS 850.5400}

45649815 Hoberg, J. (2001) Fenpyroximate 5.0% EC--Acute Toxicity to Marine Diatom, Skeletonema costatum: Lab Project Number: 13657.6152: N-4059. Unpublished study prepared by Springborn Laboratories, Inc. 51 p. {OPPTS 850.5400}

45649816 Heusel, R. (1992) Fenpyroximate-Substance, Te chnical: Effect to Scendesmus suspicatus (Green Alga) in Growth Inhibition Test: Lab Project Number: CE90/119: N-4016: A48254. Unpublished study prepared by Hoechst AG. 31 p.

45649817 Fischer, R. (1990) HOE 094552-Water Miscible Suspension Concentrate; 5%: Effect to Scendesmus suspicatus (Green Alga) in Growth Inhibition Test: Lab Project Number: CE90/085: N-4017: A44948. Unpublished study prepared by Hoechst AG. 24 p.

47021403 Maks, M. (2007) Supplement 1 to Fenpyroximate 5 Percent EC-Acute Toxicity to the Marine Diatom (Skeletonema costatum). Project Number: 13657/6152, N/4059. Unpublished study prepared by Springborn Smithers Laboratories. 9 p.

47021404 Maks, M. (2007) Supplement 1 to Fenpyroximate 5 Percent EC-Acute Toxicity to the Freshwater Green Alga, Pseudokirchneriella Subcapitata. Pr oject Number: 13657/6150, N/4058. Unpublished study prepared by Springborn Smithers Laboratories. 7 p.

### 40 MRID Citation Reference

45649818 Krebs, B. (2000) Contact Toxicity (LD50) to Honey Bees (Apis mellifera L.) Fenpyroximate Water Miscible Suspension Concentrate: Lab Project Number: C008608: KS-023-06-2000: N-4040. Unpublished study prepared by Aventis CropScience GmbH. 16 p.

45649819 Waltersdorfer, A. (2000) Oral Toxicity (LD5 0) to Honey Bees (Apis mellifera L.) Fenpyroximate Substance Technical: Lab Project Number: CW99/137: N-4039. Unpublished study prepared by Hoechst Schering AgrEvo GmbH. 16 p.

47737801 Walsh, D. (2009) Pollinator Pesticide Sa fety Trials 2007: Flonicamid. Project Number: IB/2009/PH/002/01. Unpublished study prepared by Washington State University. 19 p.

45649821 Kimura, M. (1991) Acute Toxicity Study of Fenpyroximate in Phytoseild Mites: Lab Project Number: N-4003. Unpublished study prepared by Nihon Nohyaku Company. 9 p.

45649822 Kimura, M. (1991) Acute Toxicity Study of Fenpyroximate in Green Lacewing: Lab Project Number: N-4004. Unpublished study prepared by Nihon Nohyaku Company. 11 p.

45649823 Kimura, M. (1991) Acute Toxicity Study of Fenpyroximate in Ladybug: Lab Project Number: N4005. Unpublished study prepared by Nihon Nohyaku Company. 11 p.

45649824 Kimura, M. (1992) Acute Toxicity Study of Fenpyroximate in Predacious Thrips, Scolothrips, Sp: Lab Project Number: N-4022. Unpublished study prepared by Nihon Nohyaku Company. 8 p.

45649825 Chisholm, K. (1992) Fenpyroximate and Fenpyroximate 5% SC: Acute Toxicity Studies to Beneficial Arthropods: Lab Project Number: FEN-EC-03: N-4008: CW00/019. Unpublished study prepared by Nihon Nohyaku Company. 230 p.

48381102 Thomas, S.; Kendall, T.; Krueger, H. (2010) Fenpyroximate: A Bioconcentration Test with the Bluegill (Lepomis macrochirus): Final Report. Project Number: 397A/140. Unpublished study prepared by Wildlife International, Ltd. 93 p.

45649820

48735301

48735302 Fischer, R. (1991) HOE 094552--Substance, Technical: Effect to Eisenia fetida (Earthworm) in a 14 Day Artificial Soil Test: Lab Project Number: CE 90/118: N-4014: A 45245. Unpublished study prepared by Hoechst AG. 32 p.

York, D. (2010) [ 14 C] Fenpyroximate – Full Life-Cycle Toxicity Test with Fathead Minnow (Pimephales promelas) Following FIFRA Guide line 72-5 and OPPTS Draft Guideline 850.1500. Laboratory Project ID: Springborn Smithers Study No. 13657.6162. Unpublished study prepared by Springborn Smithers Laboratories. 151 p.

Gray, J. (2011). Evaluation of the Effects of Fenpyroximate on the Parasitoid Wasp Aphidius rhopalosiphi in an Extended Laboratory Aged Residue Study on Broad Bean: Amended Final Report. Huntingdon Life Sciences Study Number: LMS0016. Unpublished study prepared by Huntingdon Life Sciences Ltd. 61 p.

### 41 

## APPENDIX A. STIR & SIP Model Outputs

STIR Model Output



## Input

Application and Chem ical Information

Enter Chemical Name Fenpyroximate

Enter Chemical Use Ag, Greenhouse,

etc. Is the Application a Spray? (enter y or n) y If Spray What Type (enter ground or air) ground
Enter Chemical Molecu lar Weight (g/mole) 421.5 Enter Chemical Vapor Pressure (mmHg) 5.60E-08 Enter Application Rate (lb a.i./acre) 0.34

Toxicity Properties

Bird

Enter Lowest Bird Oral LD 50 (mg/kg bw) 2000 Enter Mineau Scaling Factor 1.15 Enter Tested Bird Weight (kg) 0.158

Mammal

Enter Lowest Rat Oral LD 50 (mg/kg bw) 245

Enter Lowest Rat Inhalation LC 50 (mg/L) 0.24 Duration of Rat Inhalation Study (hrs) 4 Enter Rat Weight (kg) 0.298



## Output
Results Avian (0.020 kg )
Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 1.27E-03 Maximum 1-hour Vapor Inhalation Dose (mg/kg) 1.60E-04
Adjusted Inhalation LD 50 1.31E+01
Ratio of Vapor Dose to Adjusted Inhalation LD 50 1.22E-05 Exposure not Likely Significant Maximum Post-treatment Spray Inhalation Dose (mg/kg) 3.59E-02 Ratio of Droplet Inhalation Dose to Adjusted
Inhalation LD 50 2.75E-03 Exposure not Likely Significant



### Results Mammalian (0.015 kg )
Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 1.27E-03 Maximum 1-hour Vapor Inhalation Dose (mg/kg) 2.01E-04
Adjusted Inhalation LD 50 1.61E+01
Ratio of Vapor Dose to Adjusted Inhalation LD 50 1.25E-05 Exposure not Likely Significant Maximum Post-treatment Spray Inhalation Dose (mg/kg) 4.52E-02 Ratio of Droplet Inhalation Dose to Adjusted
Inhalation LD 50 2.80E-03 Exposure not Likely Significant

### 42 SIP Model Output

Table 1. Inputs

Parameter Value
Chemical name Fenpyroximate Solubility (in water at 25 o C; mg/L) 0.034

Mammalian LD 50 (mg/kg-bw) 245 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg-bw) 1.99 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg-bw) 2000 Avian test species northern bobwhite quail Body weight (g) of "other" avian species Mineau scaling factor

Mallard NOAEC (mg/kg-diet) 35 Bobwhite quail NOAEC (mg/kg-diet) 255 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) 0.0058 0.0058 Adjusted toxicity value (mg/kg-bw) 188.4443 1.5306 Ratio of exposure to toxicity 0.0000 0.0038

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) 0.0275 0.0275 Adjusted toxicity value (mg/kg-bw) 17800.0000 1.7364 Ratio of exposure to acute toxicity 0.0000 0.0159

Conclusion* Drinking water exposure alone is NOT a potential
concern for birds Drinking water exposure alone is NOT a potential
concern for birds

*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 pot ential for effects to non-target animals.