UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

PC Code: 098301 

OFFICE OF 

CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

DP Barcode: D413680, D413685 & 

D413688 

Date: September 4, 2013 

MEMORANDUM 

SUBJECT: EFED Response to Ag Logic Chemical LLC Regarding the Submission of 

Literature Data for an Acute Passerine Study and Waiver Requests for Terrestrial 

Plant Data Regarding the DCI for the Registration Review Problem Formulation 

for Aldicarb 

FROM: N.E. Federoff, Wildlife Biologist 

Environmental Risk Branch 2 

Environmental Fate and Effects Divisi n 

Office of Pesticide Programs (7507P) 

THROUGH: Brian Anderson, Chief -h 14/.----ct/ ~~~ 1.. 

Environmental Risk Branch 2 f f./ 

Environmental Fate and Effects Division 

Office of Pesticide Programs (7507P) 

TO: Kevin Costello, Chemical Review Manager 60 

Susan Bartow, Risk Manager Reviewer 

Pesticide Re-evaluation Division 

Office of Pesticide Programs (7508P) 

Attached please find the Environmental Fate and Effects Division (EFED)'s response to a 

passerine literature data submission by Ag Logic Chemical LLC, as well as waiver requests for 

terrestrial plant data regarding the problem formulation DCI for Registration Review of 

Aldicarb. The comments are provided below, along with EFED's responses. · 

MRID 49176401 & 49176402 Waiver Request For Terrestrial Plant Studies 

AgLogic Chemical LLC feels that a tier II seedling emergence (SE) study using tomato and 

ryegrass is unwarranted. AgLogic Chemical LLC also feels that the submission of a tier II 

vegetative vigor (VV) study is unwarranted. 

Tier 1 SE studies were submitted where the concentration levels were 0 (negative control) and 75 

kg product/ha (10.3lbs ai/A). The most sensitive monocot species was ryegrass, with a 12 and 

44% difference in shoot length and weight, respectively, compared to the control. The most 

sensitive dicot species was tomato, with a 28 and 25% difference in shoot length and weight, 

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respectively, compared to the control. Phytotoxic effects, including stunting and necrosis, were 

observed in ryegrass and tomatoes. Based on the observance of>25% effects in ryegrass and 

tomato, a tier II study with these two species is necessary to fulfill the guideline requirement for 

850.4100. The Tier I studies with ryegrass and tomato are considered supplemental. The data 

from the Tier I studies with com, oat, onion, cucumber, oilseed rape, soybean, sugarbeet and 

sunflower are all considered acceptable. Overall, this toxicity study was classified as 

supplemental and does not satisfy the guideline requirement for a seedling emergence toxicity 

study because >25% effects were observed in two species (i.e., ryegrass and tomato) and tier II 

studies have not been submitted for those species. 

TheSE studies used 10.3 lbs ai/A, while the current maximum label rate is 5 lbs ai/A. However, 

Kennedy (2002) did find pearl millet exposed to 15% Temik at 2.05, 3.08 and 4.1 lbs ai/A had 

reductions in SEat 3.08lbs ai/A (%reduction was not reported) and 4.llbs ai/A (57% reduction 

in emergence). Aldicarb had inhibitory effects on pearl millet at concentrations >2.05 lbs ai/A. 

The biomass of seedling plants (shoot dry wt) that did emerge was significantly reduced by 

aldicarb at application rates of~4.1lbs ai/A. 

As stated earlier, aldicarb is phytotoxic to some plants (phytotoxic effects, including stunting 

and necrosis, were observed in ryegrass and tomatoes). A waiver request was granted for the 

vegetative vigor study in 2009 (DP299878). EFED has reviewed the request to waive the VV 

study and agrees that aldicarb would not require a vegetative vigor study because; 1) aldicarb is 

not a volatile compound, and 2) there is minimal potential exposure of foliar surfaces of nontarget plants to aldicarb as it is only applied as a granule. 

We recommend that the waiver be granted for the VV study but not for theSE study. Even 

though we recommend that the VV study be waived at the present time, it may be required in the 

future as guidelines may change. 

MRID 49176403 Acute Passerine Data 

LD50 data for passerine species is available for the red-winged blackbird and house sparrow in 

the literature. EFED has reviewed the submitted references (MRID 49176403). An LD50 of 

0.75 mg/kg (0.33-1.69) will be used as the endpoint for passerines and we recommend that the 

requirement for a new passerine study be waived. 

EFED has determined that these data offer enough information so as to waive the acute passerine 

study requirement (Moore et al. 2009, Balcolm et al. 1984 and Schafer and Brunton 1979). They 

are deemed as supplemental data because an unknown number of birds and few concentrations 

were used. It is unlikely that the studies were conducted to current guidelines. However, it 

would be unlikely that an additional avian acute oral toxicity study with a passerine species 

would yield any valuable new data that could be used for risk assessment purposes. 

Schafer and Brunton (1979) found that acute oral testing with the grackle and the house sparrow 

resulted in LD50 values of0.75 mg/kg (using 95% technical aldicarb) for both these species; 

however, these data were not validated. Technical aldicarb was more toxic than granular aldicarb 

to sparrows (0.75 mg/kg and 3.8 mg/kg, respectively). Balcomb et al. (1984) did test granular 

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aldicarb 15G on the house sparrow resulting in 40% and 83% (6 birds tested) mortality from 

ingestion of only 1 granule and 40% and 80% mortality for the red wing blackbird (5 birds tested 

at each concentration) after ingesting 1 and 5 granules, respectively. Birds died within 15 to 18 

minutes of granule ingestion. An acute avian toxicity test submitted to the Agency using the 

Mallard duck resulted in an LD50 value of 1.0 mg/kg (MRID 001 07398) which is consistant in 

toxicity with other acute avian oral endpoints from the submitted literature studies. 

Citations 

Balcomb, R., R. Stevens and C. Bowen. 1984. Toxicity of 16 granular insecticides to wildcaught songbirds. Bulletin of Environmental Contamination and Toxicology 33:302-307. 

Kennedy, C.W. 2002. Phytotoxicity in pearl millet varies among in-furrow insecticides. 

Crop Protection 21(9):799-802. 

Moore D. R. J., R. S. Teed, S. I. Rodney, R. P. Thompson and D. L. Fletcher. 2009. Refined 

Avian Risk Assessment for Aldicarb in the United States. Integrated Environmental 

Assessment Management 6 (1): 83-101. 

Schafer, E.W. Jr. and R.B. Brunton. 1979. Indicator bird species for toxicity determinations. 

Vertebrate pest control and management materials, ASTM STP 680. West Conshohocken 

(PA): American Society for Testing and materials. pp 157-168. 

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