### Data Evaluation Report on the Toxicity of BCS-AU66443 (AE F140584) to Aquatic

Vascular Plants (Lemna gibba G3)

Data Requirement: EPA DP Barcod

. e
EPA MRID

EPA Guideline

Test material: BCS-AU66443 (AE F140584)*

Common name: AE F140584

Chemical name: IUPAC: Not reported 422360 and 422509

49447203

850.4400

Purity: 98.4% MRID 49447203

CAS name : Methyl 4-methanesulfonamidomethyl-2-sulfamoylbenzoate

CAS No

. : 393509-80-3 Synonyms: BCS-AU66443; AE Fl40584

* AE F140584 is a degradate ofmesosulfuron-methyl

Primary Reviewer: Kindra Bozicevich

Environmental Scientist, COM Smith

Secondary Reviewer: Teri S. Myers

Senior Scientist, COM Smith

Primary Reviewer: Michael Lowit, Ph

. D. Ecologist, EPA/OCSPP/OPP/ EF ED/ERB 1

EPA PC Code: 122009

Date Evaluation Completed: 4/10/2015 Signature:

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Date: 10129114

Signature:

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Date: 01/13/15

Signature: 

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Date: 4/10/2015 (/""

CITATION: Bruns, E. 2014

. Lemna gibba G3- Growth inhibition test with BCS-AU66443 (AE Fl40584) under semi

static conditions. Unpublished study performed by Bayer CropScience AG, Monheim, Germany. Activity ID

EBMMNl 19. Report IDE 221 4603-8

. Study sponsored by Bayer CropScience AG. Study initiated 17 April 2014

and completed 27 May 2014.

DISCLAIMER: This document provides guidance for EPA and PMRA reviewers on how to complete a data

evaluation record after reviewing a scientific study concerning the acute toxicity of a pesticide to aquatic vascular plants

. It is not intended to prescribe conditions to any external party for conducting this study nor to establish

absolute criteria regarding the assessment of whether the study is s¢ientifically sound and whether the study satisfies

any applicable data requirements. Reviewers are expected to review and to determine for each study, on a case-bycase basis, whether it is scientifically sound and provides sufficient information to satisfy applicable data requirements. Studies that fail to meet any of the conditions may be accepted, if appropriate; similarly, studies that

meet all of the conditions may be rejected, if appropriate. In sum, the reviewer is to take into account the totality of

factors related to the test methodology and results in determining the acceptability of the study

.

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

EXECUTIVE SUMMARY

In a 7

- day toxicity study, the freshwater floating aquatic vascular plants ( duckweed, Lemna gibba G3 ) were exposed to

BCS

- AU664 43 (AE F140584 ) , a degradate of mesosulfuron

- methyl, at nomina l concentrations of 0 (negative control )

and 10.0 m g /L under semi

- static conditions. Mean m e asured concentrations were <0. 000 672 (negative control , assumed

value

- see discussion of uncertainti es ) and 4.78 mg ai/L

. NOAEC and IC 50 values based on all endpoints ( frond number

y ield , frond number growth rate, frond area yield , and fond area growth rate) were 4.78 and > 4.78 mg ai /L, in terms of

mean measured concentrations

. The % growth inhibition of frond number in the treated culture as compared to the negative con trol was

- 4.1 %.

No morphological abnormalities were observed. There were increases in pH during the study (7.5

- 7.9 in fresh media

and 8.3

- 8.7 in old media)

.

This study is scientifical ly sound and is classified as Acceptable . Although there is uncertainty about decline rate and the limit of detection, this study is sufficient to demonstrate that AE F140584 is less toxic than mesosulfuron

- methyl (the parent compound, IC 50 = 0.00064 mg a i/L ; MRID 45386310 ) to aquatic vascular plants

.

Results Synopsis

Frond number yield

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Frond number growth rate

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L

Probit Sl ope: N/A

Frond area yield

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Frond area growth rate

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Endpoint s a ffected : None

Page 2 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

I. MATERIALS AND METH ODS

GUIDELINE FOLLOWED: The study was designed to comply with the procedures of the USEPA OCSPP 850.4400 and OECD Guideline 221 (2006 )

.

The following deviations from the U.S. EPA OCSPP 850.4400 (2012) guideline are noted:

1. The test substance was highl y unstable under test conditions , falling below the level of detection at each renewal period (24 hour intervals)

. There is uncertainty what the level of detection was for the study as it was variously reported as <0.000672 mg ai/L, <0.00672 mg ai/L and < 0.672 mg ai /L

. Ideally, additional data points should have been included to determine the decline rate.

2. The initial number of plants was three to four per replicate. Ideally, the number of plants should be the same in each replicate; however, the number of fronds was the same in each replicate (12).

These deviations do not affect the validity of the study (see study deficiencies for discussion about # 1 )

.

COMPLIANCE: S igned and dated GLP, Quality Assurance

, and No Data Confidenti ality

statements were provided. The study was performed in accordance with OECD Principles of GLP, the Principles of GLP according to Annex 1 of the German chemical law (ChemG)

, except for the screening work for

contaminants in the dilution water and for the automated recodin g of air

temperature and the light

- dark cycle in testing environment

.

A. MATERIALS

1. Test material BCS

- AU66443 (AE F140584 )

Description: White powder

Lot No./Batch No. : AE F140584

- 01

- 01

Purity: 98.4 %

Stability of compound

under test conditions: Unstable. M easur e d concentrations in old test media (24 hour intervals)

were all <0.672 μ g ai /L, which was used as the lowest standard concentration during the study ( see guideline deviations for further information )

.

Storage condition s of

test chemicals: Stored at 25 ± 5 ° C

.

Page 3 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

Table 1. Physicochemical properties of BCS

- AU66443 (AE F140584)

Parameter Values Comments

Water solubility at 20 ° C pH 5: 0.12 g/L

pH 7: 0.10 g/L

Vapor pressure Not reported

UV absorption Not reported

pKa Not reported

Kow Not reported

2. Test organism

Name: Duckweed, Lemna gibba Strain, if provided: G3

Source: In

- house cultures originally obtained from Eurofins Agroscience Services EcoChem GmbH, Eut inger Stra ß e 24, 75223 Niefern

- Ö schelbronn, Germany Age of inoculum : 7

- 10 days

Method of cultivation: Cultures were maintained in glass dishes filled with 20X AAP medium

under illumination of 650 0

- 7000 l u x and temperature of 23

- 26 ° C

. Transfers

were made r egularly into fresh medium to provide 7

- 10 days old colonies as

test inoculum.

B. STUDY DESIGN

1. Experimental Conditions

a. Range

- find ing study:

The range of test concentrations w as selected based on pre experiments.

Page 4 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

b. Definitive s tudy

Table 2. Experimental Parameters

Parameter Details Remarks

Criteria

Acclimation period

C ulturing media and conditions

Health Continuously cultured in

- house

Same as test

Not reported but it was reported that cultures were exponentially growing.

Test system

Static/static renewal

Renewal rate for static renewal S emi s tatic

Daily Test material was unstable even with daily renewal.

Static renewal intervals should be sufficient to maintain test

concentrations.

I ncubation facility Growth incubator

Duration of the test 7 days

7 days

Test vessel

Material (glass/stainless steel)

Size

Fill volume Glass

4 7 0 mL

20 0 mL Glass dishes (10 cm diameter , 6 cm height) covered with glass lids to

p ermit gas exchange

.

Page 5 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

Parameter Details Remarks

Criteria

Details of 20X AAP medium pH in new solutions pH in old solutions

Chelator used

Carbon source 7.5 to 7.9

8.3 to 8. 7

Na 2 EDTA

· 2H 2 O

NaHCO 3 EPA recommends the following

culture media: 20X

- AAP for Lemna gibba. Chelating agents (e.g. EDTA)

are recommended in the nutrient medium for optimum cell growth. Lower concentrations of chelating agents (down to one

- third of the

normal co ncentration recommended for AAP medium) may be used in the nutrient medium used for test solution preparation if it is suspected that the chelator will

interact with the test material. ASTM reference, E1415

- 91and D

3978

- 80 (reapproved 1987).

If non

- standard nutrient medium was used, detailed composition provided (Yes/No) A standar d medium was used. A detailed composition was provided

.

Dilution water Source/type pH

W ater pretreatment (if any)

Total o rganic car bon

Particulate matter

Metals

Pesticides

Chlorine Ultra

- pure water Not reported

Purified (Milli

- Q

- water)

None detected Not reported

Some detected

None detected

None detected Metals (mg/L) Calcium ( 15 ) Magnesium ( 2.4 ) Sodium ( 2.8 )

Potassium ( 0.6 )

pH of 7.5 ± 0.1 is acceptable if 20X

AAP nutrient media is used.

Indicate how the test material is added to the medium (added directly or used stock solution) A stock solution was prepared by dissolving 20.1 mg o f the test

substance in 2 00 0 g of test medium. The resulting sol ution was stirred

and sonicated

.

Aeration or agitation None

Page 6 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

Parameter Details Remarks

Criteria

Sediment used (for rooted aquatic vascular plants) Origin

Textural classif ication (%sand, silt, and clay) Organic carbo n (%) Geograph ic location N/A

Number of replicates Negative control

Solvent control

Treatments 6

N/A

6 4 minimum

Number of plants/replicate 3

- 4 plants/replicate

3

- 5 plants

Number of fronds/plant 3

- 4 (total of 12 fronds per vessel ) Idea lly the number of plants should be the same in each replicate; however, the number of fronds was the same in each replicate.

3

- 4 fronds per plant

Test concentrations

Nominal

Mean measured * 0 (negative control ) and 10.0 mg /L

<0. 000 672 ( negative con trol ) and

4.78 mg ai /L *Mean measured concentrations were determined by the review er as the mean of Day s 1

- 7 measured

concentrations in fresh and old test

media

. There is uncertainty in the reported limit of detection ( old test

media for the AE F140584 tr eated samples and control samples ) due to apparent typographical errors in the study. Therefore, c alculations of

mean

- measured concentrations in

treated media were conservative and based on the lowest reported limit of detection (0.000672 mg ai/L) in the study.

EPA requires at least 5 test concentrations with a dose range of 2X or 3X progression.

Solvent None used

Page 7 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

Parameter Details Remarks

Criteria

Method and interval of analytical

verification Test concentrations were measured in newly pr epared solutions on Day s 0

- 6 and from expired solutions on Day s 1

- 7 using HPLC

- MS/MS

.

Test conditions Temperature Photoperiod Light intensity and quality 2 4.0 to 24.1 o C

Continuous

6500 to 6690 lux fluorescent light

Reference chemical None used

Other parameters, if any N/A

2. Observations

Table 3. Observation parameters

Parameters Details Remarks/Criteria

Parameters me asured (e.g., number of fronds, pl ant dry weight or other toxicity symptoms) Frond number

Frond area

Growth rate

Measurement technique for frond

number and other end points Counting of fronds and

determination of total frond area was carried out using a

Lemna Tec Scanalyzer machine.

Observation intervals Fronds were counted on days 0, 2, 5, and 7

.

Other observations, if any Visual observati ons were made on study days 2 , 5 , and 7.

Indicate whether there was exponential growth in the control Yes, the doubling time in the negative control was 1.8 days.

Were raw data included? Yes

II. RESULTS and DISCUSSION

A. INHIBITORY EFFECTS

After 7 days, the mean frond number of the ne gative control was 185 fronds , yielding inhibitions relative to the

Page 8 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

negative control of

- 4 .1 % for the nominal concentration of 10 m g /L

. The study author did not assess frond

number data.

The mean 0

- 7 day frond number growth rate o f the negative control was 0.391 /day, yielding inhibitions relative to the negative control of

- 1.5 % for the nomin al concentration of 10 m g/L

. The NOAEC and I C 50 values reported by the study author based on fro nd number growth rate were >10.0 and >10.0 m g/ L, respectively, in

terms of nominal concentrations.

The mean 0

- 7 day frond number yield of the negative control was 173 f ronds, yielding inhibitions relative to the negative control of

- 4.3 % for the nominal concentration of 10 m g/L

. The NOAEC and IC 50 values reported by the study author based on frond number yield were >10.0 and >10.0 m g/ L, respectively, in terms of nominal

concentrations.

After 7 days, the mean frond area of the negative control w as 1641 mm 2 , yielding inhibitions relative to the negative control of

- 2.3 % for the nominal concentration of 10 m g/L

. The study author did not assess frond area

.

The m ean 0

- 7 day frond area growth rate of the negative control was 0.379 /day, yielding inhibitions relative to the negative control of

- 0.5 % for the nominal concentration of 10 m g/L

. The NOAEC and IC 50 values reported by the study author based on frond area g rowth rate were >10.0 and >10.0 m g/L, respectively, in terms of

nominal concentrations.

The mean 0

- 7 day frond area yield of the negative control was 1525 mm 2 , yielding inhibitions relative to the negative control of

- 2.3 % for the nominal concentration of 10 m g/L

. The NOAEC and IC 50 values reported by the study author based on frond area yield were >10.0 and >10.0 m g/L, respectively, in terms of nominal

concentrations.

No morphological abnormalities were observed. There were increases in pH during the s tudy

.

Table 4. Effect of BCS

- AU66443 (AE F140584) on frond number of duckweed, Lemna gibba

Treatment

Mean measured

and (n ominal )

concentrations

m g ai /L Initial frond

number/test

solution Frond number

2 days 5 days 7 days

frond number % in hibition a

Negative control 12 26.8 85.0 185 N/A

4.78 (10.0) 12 27.0 90.3 193

- 4.1

Reference chemical (if used) N/A

a Calculated by the reviewer relative to the negative control. N/A. Not applicable.

Page 9 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

Table 5. Effect of BCS

- AU66443 (AE F140584) on frond number of duckweed, Lemna gibba

Treatment

Mean measured

and (nominal)

concentrations

m g ai /L Ini tial frond

number/test

solution Frond number growth rate (day

- 1 ) Frond number yield

0

- 7 days % inhibition 0

- 7 days % inhibition

Negative control 12 0 .391 N/A 173 N/A

4.78 (10.0) 12 0.396

- 1.5 181

- 4.3
N/A. Not applicable.

Table 6. Effect of BCS

- AU66443 (AE F140584) on biomass of duckweed, Lemna gibba

Treatment

Mean measured

and (nominal)

concentrations

m g ai/L Frond area (mm 2 ) Frond area growth rate (day

- 1 ) Frond area yield

Day 7 % inhibition a 0

- 7 days % inhibition 0

- 7 days % inhibition

Negative control 1641 N/A 0.379 N/A 1525 N/A

4.78 (10.0) 1678

- 2.3 0.380

- 0.5 1561

- 2.3

a Calculated by the reviewer relative to the negat ive control. N/A. Not applicable.

Table 7. Statistical endpoint values (calculated by the study author based on nominal concentrations)

Statistical Endpoint Frond

number Frond

number growth rate Frond

number yield Frond area Frond area growth rate Fron d area yield

NOAEC ( mg /L) Not

calculated > 10.0 > 10.0 Not

calculated > 10.0 > 10.0

LOAEC ( mg /L) Not

calculated >10.0 >10.0 Not

calculated >10.0 >10.0

IC 50 or EC 50 ( mg /L) (95% C.I.) Not

calculated >10.0 (N/A) >10.0 (N/A) Not

calculated >10.0 (N/A) >10.0 (N/ A)

Reference

chemical

NOAEC

IC 50 /EC 50 N/A

N/A. Not applicable.

B. REPO RTED STATISTICS

The study author statistically analyzed the endpoints for frond number growth rate

, frond number yield, frond area growth rate , and frond area yield using ToxRat Prof essional statistical software. The data were assessed for normality using Shapiro

- Wilk’s test . Treatment and control means were compared using the Student’s t

- tes t . The

IC50 values were visually determined

. All analyses were based on nominal concentrati ons.

Page 10 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

C. VERI FICATION OF STATISTICAL RESULTS

The reviewer assessed the endpoints fo r frond number yield , frond num ber growth rate, frond area yield

, and frond area growth rate using CETIS version 1.8.7.12 statistical software using backend database settin gs implemented by EFED on 25 March 2014

. All data were confirmed to be normally distributed and have homogeneous variances using Shapiro

- Wilk’s and Equal Variance tests, respectively

. The I C 50 values were visually determined to be greater than the highes t concentration tested . All toxicity values are reported in terms of mean measured exposure concentrations (new and old test media renewed at 24 hour intervals)

.

Frond number yield

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Frond number growth rate

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L

Probit Slope: N/A

Frond area yield

IC 50 : > 4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Frond area growth rate

IC 50 : > 4.78 m g ai/L 95% C.I .: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

D. STUDY DEFICIENCIES

Although samples were renewed daily, the test material was below the level of detection after 24 hours. Ideally, additional data points should have been presented to determine the dec line rate.

There is uncertainty about the reported level of detection for BCS

- AU66443 (AE F140584). The study author

indicated that AE F140584 concentrations in the controls and treated vessels were not detected at a concentration higher than 0.672 μ g ai /L , which was the lowest standard concentration used during this study. In comparison, the reported LOQ = 0.1 μ g ai/ L . However, two data tables (pg 23 and 33 of the study report) report the value as < 0.672 mg ai/L, which is 1⁄2 of the highest standard con centration (1344 μ g ai /L ) used during the study. A third value is reported (< 6.72 μ g ai /L which is the middle standard concentration) for an example analysis of one of the control samples ( pages 34 & 35 of the study report )

. Another statement indicates t hat analytical findings ranged between 0 and 1 % of nominal for all aged samples ( this would exclude the 0.672 mg

ai /L concentration). It appears that the discrepancies are likely due to typographical errors; however, it is

unknown which value is correct. The reviewer used the most conservative approach for calculating mean measured concentrations of AE F140584 and used 1⁄2 of the lowest standard concentration (i.e., 0.336 μ g ai /L ).

E. REVIEWER ’ S COMMENTS

The reviewer’s results were in agreement with t hose of the study author. The study author’s toxicity values were

based on nominal concentrations whereas the reviewer’s values were based on mean measured concentrations. The reviewer’s results are presented in the Executive Summary and Conclusions sect ions of this report.

Page 11 of 12

### Data Evaluation Report on the Toxicity of BCS

- AU66443 (AE F140584) to Aquatic Vascular Plants ( Lemna gibba G3)

MRID 49447203

The laboratory portion of the defin itive test was conducted from 22 April to 20 May 20 14

.

The coefficient of variation (CV) of the negative control based on yield was 4.83

- 5.41 % and based on growth rate

was 1.3

- 1.88 %. The guideline requirement for both yield and growth rate is < 20%.

F. CONCLUSIONS

This study is scientifically sound and is classified as Acceptable . Although there is uncertainty about decline rate and the limit of detection, this study is sufficient to demonstrat e that AE F140584 is less toxic than mesosulfuron

methyl (the parent compound, IC 50 = 0.00064 mg ai/L; MRID 45386310 ) to aquatic vascular plants.

Results Synopsis

Frond number yield

IC 50 : >4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Frond number growth rate

IC 50 : >4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L

Probit Slope: N/A

Frond area yield

IC 50 : >4.78 m g ai/L 95% C.I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Frond area growth rate

IC 50 : >4.78 m g ai/L 95% C. I.: N/A

NOAEC: 4.78 m g ai/L Probit Slope: N/A

Endpoint s a ffected : None

III. REFERENCES

OECD Guideline 221 “ Lemna sp. Growth Inhibition Test” ( March 23, 2006 ).

Statistical Software “To xRa t Professional”, version 2.10.05 , produced by ToxRat  Solution s GmbH, 52477 Al sdorf, Germany ( February 20, 2010 ).

ToxRat  Solutions GmbH (2009) ToxRat  Validation Report, release December 01, 2009, valid for ToxRat  Version

2 .10

M. Dorgerloh, “LemnaTec Scanalyzer Validation Program”, Bayer CropScience AG, unpublish ed report DOM 23038 of April 7, 2004.

EPA

- Guideline 712

- C

- 008: OSCPP 850.4400, “Aquatic Plant Toxicity using Lemna spp.”, January 2012.

Page 12 of 12

### CETIS Summary Report Report Date: 07 Apr-15 13:38 (p 1 of 2)

Test Code: 122009 49447203 | 00-5637-8566

OCSPP 850.4400 Aquatic Vascular Plant Bayer CropScience AG

Batch ID: 16-8453-5163

Start Date: 22 Apr-14
Ending Date: 20 May-14 Test Type: Lemna Growth (7-d)

Duration: 28d 0h Protocol: OCSPP 850.4400 Aquatic Plant (Lemna) Diluent: Lemna Medium, 20X-AAP

Brine: Species: Lemna Gibba

Source: Lab In-House Culture Analyst:

Age: 7-10

Sample ID: 06-5697-2175
Sample Date: 22 Apr-14

Receive Date: Code: 49447203

Sample Age: NA Source: Bayer CropScience AG

Station: Client: CDM Smith

Project: Unknown Material: Mesosulfuron-methyl

122009 49447203

122009 49447203 using BCS-AU66443 (AE F140584) Batch Note:

Sample Note:

Comparison Summary

NOEL LOEL TOEL

Endpoint Analysis ID Method PMSD TU

4.78 >4.78 NA 17-3800-5482 Equal Variance t Two-Sample Test 3.12% Area Growth Rate

4.78 >4.78 NA 02-6565-2934 Equal Variance t Two-Sample Test 5.95% Frond Area

4.78 >4.78 NA 01-9659-2436 Equal Variance t Two-Sample Test 5.28% Frond Number

4.78 >4.78 NA 13-8865-5092 Equal Variance t Two-Sample Test 1.78% Frond Number Growth Rate

Control Type Mean Min Max Std Dev

Count CV% Std Err C-mg ai/L Area Growth Rate Summary

95% LCL 95% UCL %Effect

0 Negative Control 0.3785 0.372 0.385 0.00493 6 1.3% 0.002012 0.3733 0.3837 0.0%

4.78 0.3805 0.363 0.403 0.0152 6 4.0% 0.006206 0.3645 0.3965 -0.53%

Control Type Mean Min Max Std Dev

Count CV% Std Err C-mg ai/L Frond Area Summary

95% LCL 95% UCL %Effect

0 Negative Control 1525 1415 1614 73.71 6 4.83% 30.09 1448 1603 0.0%

4.78 1561 1460 1720 97.92 6 6.27% 39.98 1458 1664 -2.35%

Control Type Mean Min Max Std Dev

Count CV% Std Err C-mg ai/L Frond Number Summary

95% LCL 95% UCL %Effect

0 Negative Control 173.2 157 182 9.368 6 5.41% 3.825 163.3 183 0.0%

4.78 180.7 171 193 8.066 6 4.47% 3.293 172.2 189.1 -4.33%

Control Type Mean Min Max Std Dev

Count CV% Std Err C-mg ai/L Frond Number Growth Rate Summary

95% LCL 95% UCL %Effect

0 Negative Control 0.3908 0.378 0.398 0.007333 6 1.88% 0.002994 0.3831 0.3985 0.0%

4.78 0.3963 0.389 0.405 0.005854 6 1.48% 0.00239 0.3902 0.4025 -1.41%

CETISTM v1.8.7.12 000-516-187-1 QA:________ Analyst:________

### CETIS Summary Report Report Date: 07 Apr-15 13:38 (p 2 of 2)

Test Code: 122009 49447203 | 00-5637-8566

OCSPP 850.4400 Aquatic Vascular Plant Bayer CropScience AG

Control Type C-mg ai/L Area Growth Rate Detail

Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Rep 6

0 Negative Control 0.381 0.375 0.372 0.385 0.382 0.376

4.78 0.381 0.393 0.403 0.368 0.375 0.363

Control Type C-mg ai/L Frond Area Detail

Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Rep 6

0 Negative Control 1568 1614 1415 1572 1512 1471

4.78 1617 1530 1720 1460 1570 1470

Control Type C-mg ai/L Frond Number Detail

Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Rep 6

0 Negative Control 169 180 157 182 179 172

4.78 175 187 193 171 180 178

Control Type C-mg ai/L Frond Number Growth Rate Detail

Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Rep 6

0 Negative Control 0.388 0.396 0.378 0.398 0.395 0.39

4.78 0.392 0.401 0.405 0.389 0.396 0.395

CETISTM v1.8.7.12 000-516-187-1 QA:________ Analyst:________