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/EFED/ERB 1 

EPA PC Code: 122009 

Date Evaluation Completed: 4/10/2015 

Signature: ~ ---e,'l:f'-J;cL 

Date: 10129114 

Signature: ~. S lhyn-v 

Date: 01/13/15 

Signature: ?MM {4 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 Unpublished study performed by Bayer CropScience AG, Monheim, Germany.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-AU66443 (AE F140584), a degradate of mesosulfuron-methyl, at nominal concentrations of 0 (negative control)

and 10.0 mg/L under semi-static conditions. Mean measured concentrations were <0.000672 (negative control, assumed 

value -see discussion of uncertainties) and 4.78 mg ai/L. NOAEC and IC50 values based on all endpoints (frond number 

yield, 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 control 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 scientifically 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, IC50 = 0.00064 mg ai/L; MRID 45386310) to aquatic vascular plants.

Results Synopsis

Frond number yield

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond number growth rate

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond area yield

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond area growth rate

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Endpoints affected: 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 METHODS

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 highly 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: Signed and dated GLP, Quality Assurance, and No Data Confidentiality 

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 recoding of airtemperature 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. Measured concentrations in old test media (24 hour intervals)

were all <0.672 μg ai/L, which was used as the lowest standard 

concentration during the study (see guideline deviations for further 

information).

Storage conditions 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, Eutinger Straße 24, 75223 Niefern-Öschelbronn, 

Germany

Age of inoculum: 7-10 days

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

under illumination of 6500-7000 lux and temperature of 23-26°C. Transfers 

were made regularly into fresh medium to provide 7-10 days old colonies as 

test inoculum.

B. STUDY DESIGN

1. Experimental Conditions

a. Range-finding study:

The range of test concentrations was 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 study

Table 2. Experimental Parameters

Parameter Details Remarks

Criteria

Acclimation period

Culturing 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

Semi static

Daily

Test material was unstable even with 

daily renewal.

Static renewal intervals should be 

sufficient to maintain test 

concentrations.

Incubation facility Growth incubator

Duration of the test 7 days

7 days 

Test vessel

Material (glass/stainless steel)

Size

Fill volume

Glass

470 mL

200 mL

Glass dishes (10 cm diameter, 6 cm 

height) covered with glass lids to 

permit 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

Na2EDTA·2H2O

NaHCO3

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 concentration 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 standard medium was used. A 

detailed composition was provided.

Dilution water 

Source/type

pH

Water pretreatment (if any)

Total organic carbon

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 20XAAP 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 of the test 

substance in 2000 g of test medium. 

The resulting solution 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 classification (%sand, silt, 

and clay)

Organic carbon (%)

Geographic 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) Ideally 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

<0.000672 (negative control) and 

4.78 mg ai/L

*Mean measured concentrations 

were determined by the reviewer as 

the mean of Days 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 treated 

samples and control samples) due to 

apparent typographical errors in the 

study. Therefore, calculations 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 prepared solutions on Days

0-6 and from expired solutions on 

Days 1-7 using HPLC-MS/MS.

Test conditions 

Temperature

Photoperiod

Light intensity and quality

24.0 to 24.1oC

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 measured (e.g., number 

of fronds, plant 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

LemnaTec Scanalyzer machine.

Observation intervals Fronds were counted on days 0, 

2, 5, and 7.

Other observations, if any Visual observations 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 negative 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 mg/L. The study author did not assess frond

number data.

The mean 0-7 day frond number growth rate of the negative control was 0.391/day, yielding inhibitions relative 

to the negative control of -1.5% for the nominal concentration of 10 mg/L. The NOAEC and IC50 values 

reported by the study author based on frond number growth rate were >10.0 and >10.0 mg/L, respectively, in 

terms of nominal concentrations.

The mean 0-7 day frond number yield of the negative control was 173 fronds, yielding inhibitions relative to the 

negative control of -4.3% for the nominal concentration of 10 mg/L. The NOAEC and IC50 values reported by 

the study author based on frond number yield were >10.0 and >10.0 mg/L, respectively, in terms of nominal 

concentrations.

After 7 days, the mean frond area of the negative control was 1641 mm2

, yielding inhibitions relative to the 

negative control of -2.3% for the nominal concentration of 10 mg/L. The study author did not assess frond area.

The mean 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 mg/L. The NOAEC and IC50 values reported 

by the study author based on frond area growth rate were >10.0 and >10.0 mg/L, respectively, in terms of 

nominal concentrations.

The mean 0-7 day frond area yield of the negative control was 1525 mm2

, yielding inhibitions relative to the 

negative control of -2.3% for the nominal concentration of 10 mg/L. The NOAEC and IC50 values reported by 

the study author based on frond area yield were >10.0 and >10.0 mg/L, respectively, in terms of nominal 

concentrations.

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

Table 4. Effect of BCS-AU66443 (AE F140584) on frond number of duckweed, Lemna gibba

Treatment

Mean measured 

and (nominal)

concentrations

mg ai/L

Initial frond 

number/test 

solution

Frond number

2 days 5 days 7 days

frond number % inhibition 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

mg ai/L

Initial 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

mg ai/L

Frond area (mm2) 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 negative 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

Frond 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

IC50 or EC50

(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

IC50/EC50

N/A

N/A. Not applicable.

B. REPORTED 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 Professional statistical software. The data were assessed for 

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

IC50 values were visually determined. All analyses were based on nominal concentrations.

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. VERIFICATION OF STATISTICAL RESULTS

The reviewer assessed the endpoints for frond number yield, frond number growth rate, frond area yield, and

frond area growth rate using CETIS version 1.8.7.12 statistical software using backend database settings 

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 IC50 values were 

visually determined to be greater than the highest 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

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond number growth rate

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond area yield

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond area growth rate

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg 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 decline 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 μg ai/L, which was the lowest standard concentration used during this study. In 

comparison, the reported LOQ = 0.1 μg 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 concentration (1344 μg ai/L) used during the 

study. A third value is reported (< 6.72 μg 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 that 

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 μg ai/L). 

E. REVIEWER’S COMMENTS

The reviewer’s results were in agreement with those 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 sections 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 definitive test was conducted from 22 April to 20 May 2014.

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 demonstrate that AE F140584 is less toxic than mesosulfuronmethyl (the parent compound, IC50 = 0.00064 mg ai/L; MRID 45386310) to aquatic vascular plants.

Results Synopsis

Frond number yield

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond number growth rate

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond area yield

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Frond area growth rate

IC50: >4.78 mg ai/L 95% C.I.: N/A

NOAEC: 4.78 mg ai/L

Probit Slope: N/A

Endpoints affected: None

III. REFERENCES

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

Statistical Software “ToxRat Professional”, version 2.10.05, produced by ToxRat Solutions GmbH, 52477 Alsdorf, 

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, unpublished 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

Species: Lemna Gibba Brine:

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

Material: Mesosulfuron-methyl Project: Unknown

122009 49447203

122009 49447203 using BCS-AU66443 (AE F140584)

Batch Note:

Sample Note:

Comparison Summary

Analysis ID Endpoint NOEL LOEL TOEL PMSD TU Method

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

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

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

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

C-mg ai/L Control Type Count Mean Min Max Std Err Std Dev CV%

Area Growth Rate Summary

95% LCL 95% UCL %Effect

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

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

C-mg ai/L Control Type Count Mean Min Max Std Err Std Dev CV%

Frond Area Summary

95% LCL 95% UCL %Effect

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

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

C-mg ai/L Control Type Count Mean Min Max Std Err Std Dev CV%

Frond Number Summary

95% LCL 95% UCL %Effect

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

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

C-mg ai/L Control Type Count Mean Min Max Std Err Std Dev CV%

Frond Number Growth Rate Summary

95% LCL 95% UCL %Effect

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

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

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

C-mg ai/L Control Type

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

C-mg ai/L Control Type

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

C-mg ai/L Control Type

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

C-mg ai/L Control Type

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

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