OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

March, 2014

PC Code: 123301

MEMORANDUM DP Barcode: 352367

SUBJECT: Preliminary Ecological Risk Assessment for Registration Review of FosetylAluminum

FROM: Kristina Garber, Senior Biologist

ERB2/EFED (7507P)

THROUGH: Brian Anderson, MEM, Branch Chief

ERB2/EFED (7507P)

TO: Kelly Ballard, Chemical Review Manager

Neil Anderson, Branch Chief

RMIB1/PRD (7508P)

This memorandum transmits the preliminary ecological risk assessment for the registration 

review of the fungicide fosetyl-aluminum (referred to as fosetyl-Al). Based on currently 

registered uses and labeled rates, this preliminary assessment identifies potential risks to nontarget organisms. This assessment is focused on species that are not Federally listed as 

threatended or endangered (referred to as “listed”); however, some general discussion of taxa 

of listed species for which “no effect” determniations are expected is included in this 

assessment. For taxa where there may be risk, specific determinations for listed species are 

considered uncertain at this time. Currently labeled rates of fosestyl-Al pose a potential for 

adverse effects, i.e., risk, to non-target terrestrial animals, including insects, birds, reptiles, 

terrestrial-phase amphibians and mammals. In addition, applications may impact sensitive 

species of dicotyledenous plants (dicots) in terrestrial habitats. These risks may be reduced 

through label changes, including decreases in maximum single applications, decreases in the 

number of applications allowed per year, removal of aerial applications, use of spray drift 

buffers and specification of coarse droplet spectrum to reduce spray drift. In addition, section 

2.1.4 addresses ambiguous label language that could be revised to reduce conservative 

assumptions used in assessing potential risks. 
Ecological Risk Assessment for the Registration Review of 

FOSETYL-Al

IUPAC name: aluminium tris(ethylphosphonate)

CAS Number 39148-24-8

USEPA PC CODE 123301

Prepared by:

Kristina Garber, Senior Biologist

Amy Blankinship, Senior Biologist

Reviewed by:

R. David Jones, Ph.D., Senior Agronomist

Donna Judkins, Ph.D., Biologist

Jean Holmes, DVM, MPH, Risk Assessment Process Leader

Thomas Steeger, Ph.D., Senior Science Advisor (Review Panel)

Rochelle Bohaty, Ph.D., Chemist (Review Panel)

Michael Wagman, M.S., Biologist (Review Panel)

Approved by:

Brian Anderson, MEM, Branch Chief, Environmental Risk Branch II

Environmental Fate and Effects Division

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460

March 20, 2014

- 3+
Table of Contents

1. Executive Summary...................................................................................................... 4

2. Problem Formulation .................................................................................................... 6

2.1. Use Characterization......................................................................................... 6

2.1.4. Uncertainties Surrounding Label Language ....................................... 15

2.2. Exposure Assessment...................................................................................... 17

2.3. Effects Assessment ......................................................................................... 19

2.4. Risk Assessment ............................................................................................. 23

3. Exposure Analysis ...................................................................................................... 26

3.1. Direct Deposition onto Food Items (located on treated field) ........................ 26

3.2. Spray Drift Transport...................................................................................... 27

4. Effects Analysis.......................................................................................................... 29

4.1. Toxicity of Fosetyl-Al..................................................................................... 30

4.1.1. Terrestrial Organisms.......................................................................... 30

4.1.2. Aquatic Organisms.............................................................................. 36

4.2. Endocrine Disruptor Screening Program........................................................ 37

5. Risk Characterization.................................................................................................. 38

5.1. Terrestrial Organisms...................................................................................... 38

5.2.1. Birds, Amphibians and Reptiles ........................................................... 38

5.2.2. Mammals............................................................................................... 42

5.2.3. Terrestrial invertebrates........................................................................ 49

5.2.4. Plants..................................................................................................... 50

5.2. Aquatic Organisms.......................................................................................... 51

5.3. Listed Species ................................................................................................. 52

5.4. Risk Conclusions ............................................................................................ 52

Appendix A. Detailed description of available effects data for fosetyl-Al............................. 54

Appendix B. MRID Bibliography for Environmental Fate and Toxicity Studies................. 70
1. Executive Summary

The purpose of this assessment is to evaluate the potential risks to non-target organisms from 

registered uses of fosetyl-aluminum (fosetyl-Al). This assessment is focused on non-listed 

species and does not consider risks to individual federally listed endangered and threatened 

(listed) species. 

Fosetyl-Al is used to control several fungal pathogens and can be applied either as a 

preventative measure (i.e., prophylactically) or to treat existing fungal infections of plants. 

Fosetyl-Al acts as a systemic fungicide that can move throughout the treated plant (as 

ethylphosphonate). It is applied as a root treatment (soil application, root dip), trunk spray 

and as a foliar treatment to crops by ground or air spray. It is also soil-incorporated or some 

ornamental uses. Maximum single applications range from 2-70 lbs a.i./A; however for most 

uses, the maximum single rate is 4 lbs a.i./A. Multiple applications are allowed for most uses 

at reapplication intervals that vary from weeks to months.

Fosetyl-Al is a salt and is not expected to persist in the environmental as a complex. 

Dissociation is expected to occur rapidly releasing aluminum (Al3+) and three 

ethanophosphonate ions. Fate data indicate ethanophosphonate degrades rapidly in soil 

through microbially mediated processes to degradates (aluminum, phosphonic acid and 

ethanol) that are not considered residues of concern in this assessment. Fosetyl-Al and 

ethanophosphonate are not expected to volatilize or bioaccumulate. Fosetyl-Al, as 

ethanophosphonate, appears to be more persistent in plants following uptake. The primary 

transport mechanism away from treated areas is spray drift. Although fosetyl-Al is soluble 

and mobile, transport via runoff and leaching are not expected to be primary dissipation 

routes in the environment due to the rapid disscoation and subsequent degradation of the 

dissocisation products in soil.

Fosetyl-Al is practically non-toxic to birds and mammals on an acute exposure basis. In a 

chronic toxicity study with birds, no effects were observed in any of the dietary treatment 

levels tested, resulting in a NOAEC of 1414 mg/kg-diet. Available chronic toxicity data for 

mammals indicate effects to body weights of offspring at 12,000 mg/kg-diet, resulting in a no 

observed adverse effect concentration (NOAEC) of 6,000 mg/kg-diet. Although fosetyl-Al is 

practically non-toxic to honey bees (Apis mellifera) on an acute exposure basis, toxicity data 

for other species of insects (e.g., predatory mites and sweet-potato whiteflies) suggest that

other insect species may be more sensitive to fosetyl-Al and that they may be impacted at 

currently registered application rates (i.e., as low as 1.8 lb a.i./A). Available data for 

terrestrial plants indicate that dicotyledenuous (dicots) species are more sensitive than

monocotyledenous (monocots) species and that the most sensitive tested dicot expressed a

25% decrease in growth when exposed to fosetyl-Al at a treatment rate equivalent to 7.6 lbs 

a.i./A. Only two incident reports are available for fosetyl-Al, both of which involve damage 

to spinach crops (dicot species). 

For aquatic animals, fosetyl-Al is slightly toxic to fish and moderately toxic to invertebrates

on an acute exposure basis. No chronic toxicity data are available for fish. Chronic toxicity 
data for freshwater invertebrates include decreased survival of adult daphnids at 84 mg a.i./L, 

resuting in a NOAEC of 16 mg a.i./L. The most sensitive aquatic plant species had a no 

effect level of 0.32 mg a.i./L and a 50% decrease in growth at 0.780 mg a.i./L. 

Currently labeled rates of fosestyl-Al pose a potential risk to non-target terrestrial 

animals, including insects, birds, reptiles, terrestrial-phase amphibians and mammals

as well as sensitive species of terrestrial dicot plants. The risk conclusions are summarized 

as follows:

• For terrestrial invertebrates, most applications of fosetyl-Al may decrease the 

reproduction of sensitive species. Less sensitive species, such as honey bees, are only 

expected to be impacted at higher application rates (i.e., ≥5.6 lb a.i./A). Potential risks 

apply to insects located on fields where fosetyl-Al is sprayed and to areas subject to

spray drift. Risks to sensitive terrestrial invertebrates are estimated to extend as far 

out as 266 feet from the edge of the field for aerial applications and 26 feet for ground 

applications.

• For birds (and terrestrial-phase amphibians and reptiles, for which birds are 

considered surrogates), fosetyl-Al poses a potential acute and chronic risk for most 

uses, except those on asparagus, bananas, hops (Section 3 use) and stone fruits. 

• For mammals, fosetyl-Al exposures pose an acute risk for most uses, with the 

exception of almonds, asparagus, bananas, citrus, cranberry, kiwis, peaches, plums, 

prunes, stone fruits and walnuts. All uses of fosetyl-Al pose a potential chronic risk to 

mammals.

• Although fosetyl-Al is practically non-toxic to birds and mammals on an acute oral 

exposure basis, and the chronic toxicity endpoints suggest low toxicity, risk is 

identified for many uses due to potential high exposures from high application rates.

• Effect determinations for listed species of birds, terrestrial-phase amphibians, reptiles, 

mammals and terrestrial insects are uncertain.

• Although applications of 7.6 lb a.i./A and greater may result in a >25% effect to 

growth of dicots, risks are expected to be negligible to non-listed dicot species since

risk is only estimated to extend only 7 feet from the edge of the field. Effects are not 

expected to monocots.

• Effect determinations for listed species of dicots (in terrestrial and wetland habitats) 

are uncertain. Risks to these species may extend beyond 7 feet from the edge of the 

field.

• Direct adverse effects are not expected for aquatic animals and plants exposed to 

fosetyl-Al following spray drift and runoff. 

• No Effect determinations can be made for listed species of fish, aquatic-phase 

amphibians (that do not have terrestrial-phases), aquatic invertebrates, aquatic plants 

and terrestrial monocots (in terrestrial and wetland habitats) that 

o do not rely upon birds, terrestrial-phase amphibians, reptiles, mammals and 

terrestrial insects (for food or shelter), and 

o do not have obligate relationships with dicot plants (in terrestrial and wetland 

habitats). 
2. Problem Formulation

This problem formulation is based on the preliminary problem formulation for the 

registration review of fosetyl-Al (DP342370; October 30, 2007). Modifications have been 

made to accomidate newly available data and methods currently approved for use in 

ecological risk assessments. The purpose of this assessment is to evaluate the potential risks 

of the registred uses of fosetyl-Al on non-target organisms. This assessment is focused on

species that are not federally listed as threatended or endangered (referred to as “listed”); 

however, some general discussion of taxa for which “no effect” determniations are expected 

is included in this assessment. For taxa where there may be risk for non-listed species, 

specific determinations for listed species are considered uncertain at this time.

2.1. Use Characterization

2.1.1. Target Pests and Mode of Action

Fosetyl-Al is used to control several fungal pathogens, including crown and root rot 

(Phytophtora spp.), leaf spot (Alternaria spp.), anthracnose (Colletotrichum spp.), downy 

mildew (Plasmopara spp. and Peronospora spp). This chemical can be applied either as a 

preventative measure, i.e., prophylactically, or to treat existing fungal infections of plants. 

Fosetyl-Al acts as a systemic fungicide that can move downward (as ethylphosphonate) 

throughout the treated plant (from the leaves to the roots). As a fungicide, it is thought that 

increases production of phytoalexin (antimicrobial) chemicals in the plant, and it may also 

cause direct inhibition of the target fungi (Guest and Bompeix, 19901

; Oku, 19942). It has 

also been suggested that fosetyl-Al is broken-down to phosphonic acid, which inhibits 

mycelial growth of fungal pathogens (Oku, 1994). It appears to trigger a defensive reaction 

in the affected plant that sequesters the fungus and prevents spread (Harte, Holdren, 

Schneider, & Shirley, 19913). 

2.1.2. Registered Uses

At this time, there are 10 Section 3 registrations for formulated products containing fosetylAl; all of which contain fosetyl-Al as the sole active ingredient. These registrations are 

maintained by five different registrants. Table 1 summarizes the formulated products 

currently registered for fosetyl-Al. In addition, there are three registrations for technical 

fosetyl-Al (264-466, 11678-69 and 83504-1), which will not be discussed further in this 

assessment. Table 2 lists the nine special local needs registrations (Section 24c) that are 

currently allowed, all of which apply to the Alliette® WDG Section 3 label. 

 1 Guest, D.I. & Bompeix, G. (1990). The complex mode of action of phosphonates. Australasian Plant Path., 

19, 113-115 2 Oku, Hachiro. (1994). Plant Pathogenesis and Disease Control. Boca Raton, FL: CRC Press, Inc. p. 134-

136.

3 Harte, J., Holdren, C., Schneider, R., Shirley, C (1991). Toxic A to Z: a guide to everyday pollution hazards, 

1st ed. Berkely and Los Angeles, California: University of California Press. pp. 322.
Table 1. Current Section 3 Registrations of Fosetyl-Al

Product Name Registrant

EPA Registration 

#

(latest label date)

% Active 

Ingredient Form Use(s)

Aliette® Fungicide Bayer CropScience 264-467

(12/18/95) 80 wettable powder/ water soluble packet turf

Aliette® Injectable 

Fungicide Bayer CropScience 264-504(02/22/94) 9.5 ready-to-use solution avocado trees

Aliette® WDG 

Fungicide Bayer CropScience 264-516(08/08/08) 80 water dispersible granule

avocado, citrus, macadamia nuts, pome fruit, 

almonds, stone fruit, blueberry, caneberry, 

cranberry, grapes, strawberry, asparagus, 

brassica crops, cucurbit crops, leafy vegetables, 

onions, tomato, banana, ginseng, hops, 

pineapple, tobacco

Aliette® WDG Brand 

Fungicide

Bayer Environmental 

Science

432-890

(10/15/07) 80 water dispersible granule turf and ornamentals

Chipco Aliette® WSP 

Brand Fungicide

Bayer Environmental 

Science

432-894

(07/01/94)

(formally 264-542)

80 soluble concentrate/ 

wettable powder turf and ornamentals

Aliette® HG Brand 

Fungicide

Bayer Environmental 

Science

432-897

(12/02/08) 80 emulsifiable concentrate turf and ornamentals

Terronate® WDG Winfield 9779-353

(06/05/98) 80 water dispersible granule

avocado, citrus, pome fruit, stone fruit, 

caneberry, almonds, strawberry, asparagus, 

brassica crops, cucurbit crops, leafy vegetables, 

onions, tomato, ginseng, hops, pineapple

Linebacker® WDG 

Fungicide Tessenderlo Kerley 61842-9(05/15/07) 80 water dispersible granule

citrus, pome fruit, stone fruit, caneberry, 

almonds, strawberry, asparagus, brassica crops, 

cucurbit crops, leafy vegetables, onions, tomato, 

ginseng, hops, pineapple, macadamia nuts, 

bananas, avocado, turf, ornamentals

Autograph® Tessenderlo Kerley 61842-10

(08/07/07) 70 emulsifiable concentrate turf and ornamentals

Legion® 80 WDG Makhteshim-Agan of 

N. America, Inc

66222-161

(06/12/08) 80 water dispersible granule

citrus, pome fruit, stone fruit, caneberry, 

almonds, strawberry, brassica crops, cucurbit 

crops, leafy vegetables, onions, tomato, ginseng, 

hops, pineapple, macadamia nuts, bananas, 

avocado, tobacco, cranberry, grapes, turf, 

ornamentals
Table 2. Current Section 24c Registrations of Fosetyl-Al*

EPA Registration # Use(s)

CA95000300 avocado

CA97000800 strawberry

CA97001300 almonds, walnuts, peaches, plums, prunes, kiwi

FL0400300 citrus

ID03000100 peas

ID96001300 hops

OR03000100 peas

OR04001800 hops

WA02003000 peas

* All registrations involve the use of Aliette® WDG.

Table 3 summarizes the registered uses of fosetyl-Al, by crop. Uses of fosetyl-Al apply to 

residential and agricultural areas. Registered application methods for fosetyl-Al include: foliar 

spray (ground and aerial methods), soil drench, chemigation, root dip, tree trunk spray or paint, 

tree injections, and seed treatment. 

It should be noted that the labels specify the maximum amount of fosetyl-Al that may be used 

per season or per year (varies by crop) as well as the maximum single application rates by crop. 

The maximum number of applications allowed per season or per crop is determined by dividing 

the maximum total application by the maximum single application rate. It is possible that 

applicators may make more applications per year or per season at lower rates. For those crops 

that specify applications by season (e.g., strawberries, tomoatoes) and where those crops may be 

grown multiple times per year (e.g., California), the maximum number of applcitions per year 

may be greater. 
Table 3. Current Registered Uses of Fosetyl-Al

Crop

Application 

rate

lbs a.i./A

Number of 

Applications (per 

season or year)

Application 

Method

Minimum Application 

Interval

(days)

Registration Number(s)*

almonds 4 4 aerial; ground 60;

30-60 (CA only)

264-516; 264-516; 9779-353; 61842-

9;66222-161; CA970013

almonds (non-bearing) NS to 41 NS to 4 (max of 

16 lb a.i./A/year)1 trunk spray/paint NS 264-516

asparagus (in ca only) 4 1 aerial; ground -- 264-516; 9779-353; 61842-9

avocado 0.0625 lb 

a.i./tree NS drench NS 264-516

avocado (non-bearing and bearing)

NS (nonbearing) or 4 

(bearing)2

NS; bearing 

indicates max of 

16 lb a.i./A/year

trunk spray/paint NS 264-516

avocado 9.5 mL 

a.i./tree 2 injection NS 264-504

banana 4.8 4 aerial; ground 90 264-516; 61842-9; 66222-161

banana 4.8

NS

(max 4.8 lb 

a.i./A/year)

injection NS 264-516

brassica

(broccoli, broccoli raab, brussels 

sprouts, cabbage, chinese broccoli, 

chinese cabbage, chinese cabbage, 

chinese mustard cabbage, 

cauliflower, cavalo broccolio, 

collards, kale, kohlrabi, minzuna, 

mustard greens, mustard spinach, 

rape greens)

4 7 Aerial; Ground 7-21 264-516; 9779-353; 61842-9; 66222-161

citrus (bearing and non-bearing) 4 4 Aerial; Ground; 

Chemigation NS to 30-45 264-516; 9779-353; 61842-9; 66222-161; FL040003

citrus (non-bearing) 2.4/100 

gallons3 NS Root Dip NS 264-516

citrus (bearing and non-bearing) NS4 4; max of 16 lb 

a.i./A/year Trunk Spray/Paint NS 264-516
Crop

Application 

rate

lbs a.i./A

Number of 

Applications (per 

season or year)

Application 

Method

Minimum Application 

Interval

(days)

Registration Number(s)*

cranberry, blueberry, caneberry 

(blackberry, loganberry, raspberry, 

cultivars and/or hybrids of these)

4 4 Aerial; Ground

30 –cranberry;

14-21 blueberry; 

caneberry – 45 E of 

Rockies, 21 W. of 

Rockies

264-516; 9779-353; 61842-9; 66222-161

cucurbits (chinese waxgourd, citron 

melon, cucumber, gherkin, gourd, 

momordica spp, muskmelon, 

pumpkin, summer and winter squash, 

watermelon)

4 7 Aerial; Ground 7-14 264-516; 9779-353; 61842-9; 66222-161

ginseng 4 9 Ground 7 264-516; 9779-353; 66222-161

grapes (east of rockies only) 4 7 Aerial; Ground 21 264-516; 66222-161

hops (section 3) 2 4 Ground 21-60 264-516; 9779-353; 61842-9; 66222-161

hops (section 24 (c) id and or only) 4 4 Ground; Aerial 21-60 ID960013;

OR040018

kiwis, peaches, plums, prunes (ca 

only) 4 4 Aerial; Ground 30-60 CA970013

leafy vegetables 

(amaranth, arugula, cardoon, celery, 

celtuce, chervil, chrysanthemum 

edible, corn salad, cress, dandelion, 

dock, endive, fennel, lettuce, orach, 

parsley, purslane, radicchio, rhubarb, 

spinach, swiss chard)

4 7 aerial; ground 7-21 264-516; 9779-353; 61842-9; 66222-161

macadamia nuts 6 4 aerial; ground 21 264-516; 61842-9; 66222-161

onion (dry) 2.4 7 aerial; ground 7-14 264-516; 9779-353; 61842-9; 66222-161

ornamentals and/or conifer nurseries 16 NS Aerial;ground7

(foliar) 30 432-890 & 894; 61842-9 & 10; 66222-161

ornamentals 69.78 NS ground (drench) 30 432-890 & 894; 61842-9; 66222-161

ornamentals (bacterial blight 

suppression) 

12.8/12.99

NS ground7 (foliar) 7 432-890 & 894; 61842-10; 66222-161

ornamentals (bedding plants) 12.8/12.99 NS ground7 (foliar) 14-30 432-890 & 894;

61842-9 & 10; 66222-161

ornamentals (downy mildew control 

in roses, fire blight suppression)

8.0/9.610

NS ground7 (foliar) 7 432-890; 61842-9; 432-894
Crop

Application 

rate

lbs a.i./A

Number of 

Applications (per 

season or year)

Application 

Method

Minimum Application 

Interval

(days)

Registration Number(s)*

peas (succulent) 0.15/100 lbs 

seed 1 seed treatment -- ID030001; WA020030;OR030001

pineapple 12 6 aerial; ground 905 264-516; 979-353; 61842-9; 66222-161

pineapple 2 NS pre-plant dip NS 264-516

pome fruits & stone fruits

(apples, crabapple, loquat, mayhaw, 

pear, oriental pear, quince, apricot, 

avocado nectarine, peaches, cherry 

(sour & sweet), plum, chickasaw

plum, damson plum, japanese plum, 

plumcot, prune)

4 4 aerial; ground

4-7 pome

60 stone

264-516; 9779-353; 61842-9; 66222-

161;

CA950003 (avocado only)

pome fruits 2.4/100 

gallons3 NS root dip NS 264-516

strawberries 4 6 aerial; ground 7-14 264-516; 9779-353; 61842-9

CA970008

strawberries 2/100 

gallons6 NS root dip NS 264-516

tobacco 3.2 5 aerial; ground 7-10 264-516; 66222-161

tomato 4 4 aerial; ground 7-14 264-516; 9779-353; 61842-9; 66222-161

turf 17.3-17.6 NS ground7

(foliar) 14/21 432-890 & 897 & 894;61842-9 & 10; 66222-161; 264-467

walnut 4 4 aerial; ground 30-60 CA970013

NS=not specified on label

*: While every crop listed in the “Crop” column may not be a registered use for every EPA Registration numbers listed at least one crop is for every reg #. 

Application rates represent maximum application rate for a least one of the EPA Registration number listed. Other labels may have slightly different application 

rates.

1 Almond trunk spray - Rate is specified as 2 – 4 lb a.i./5 gals and solution is applied to tree. Label does not indicate maximum amount of solution to apply only 

to thoroughly wet the lesion. Label has general restriction of no more than 4 lb a.i./A per application or 16 lb a.i./A per year or four applications per year. 2 Avocado trunk spray - Rate for both non-bearing and bearing is specified as 2 – 4 lb a.i./5 gals and solution is applied to tree. Label does not indicate 

maximum amount of solution to apply only to thoroughly wet the lesion or from soil line up the trunk approximately two feet. For bearing, label has general 

restriction of no more than 4 lb a.i./A per application.

3 Citrus and Pome Fruit root dip - Label states to make solution per the rate above and then dip entire root system 30-60 minutes prior to planting in field. 4 Citrus trunk spray - Rate for both non-bearing and bearing is specified as 2 – 4 lb a.i./5 gals and solution is applied to tree. Label does not indicate maximum 

amount of solution to apply only to thoroughly wet the lesion or from soil line up the trunk approximately two feet. Label has general restriction of no more than 

four applications or 16 lb a.i./A per year.

5 Pineapple foliar -The label has conflicting information. It states do not apply more than six foliar applications, but it also states to make applications every 90 

days therefore it is not possible to make six applications in one year or season. 
6 Strawberry root dip - Label states to dip roots and crowns for 15-30 minutes and plant with 24 hours of dipping. 7 Ornamentals - Labels do not indicate if ground or aerial application, however, based on information provided by BEAD only conifer nurseries were assumed to 

use aerial application methods. All other ornamental and turf uses were assumed to be ground application. . 8 Ornamentals soil drench. This application rate was calculated to a lb a.i./A rate based on the registered label rate of 0.8 lb product for every 400 square feet. 9 Ornamentals - From label 61842-10 only, all other labels 12.8 lb a.i./A 10 Ornamentals -From label 432-894 only, all other labels 8.0 lb a.i./A
2.1.1. Estimated Use in the United States

From 1992-2009, the U.S. Geological Survey (USGS) estimated annual use of fosetyl-Al to 

range from 0.2-1.0 million pounds, with the majority of use being attributed to vegetable, fruit, 

orchard and grape production (Figure 1). The Biological and Economic Analysis Division 

(BEAD) estimated that each year, an average of 584,000 pounds of fosetyl-A1 is applied to crops 

in the US, with the majority (51%) applied to lettuce (300,000 lbs). Major agricultural uses of 

fosetyl-Al also include citrus (62,000 lbs), spinach (50,000 lbs), hops (30,000 lbs), strawberries 

and tomatoes (20,000 lbs each). When considering the proportion of acres of a crop that are 

treated in the U.S., a substantial amount of acres of lettuce (30%) spinach (20%) and caneberries 

(20%) are estimated to be treated with fosetyl-Al (Table 4)

4

. Major agricultural use sites of 

fosetyl-Al re located in California, the Pacific Northwest, the Great Lakes states and Florida 

(Figure 15). No data are available to characterize the spatial distribution and pounds applied for 

ornamental and residential uses of fosetyl-Al.

 4 From Screening Level Usage Analysis (SLUA)

5 http://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=2009&map=FOSETYL&hilo=L
Figure 1 USGS Estimated (high and low) Annual Agricultural Use of Fosetyl-Al From 1992-2009 

(http://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=2009&map=FOSETYL&hilo=L)
Table 4. Average Annual Use of Fosetyl-Al in the U.S.

Crop lbs a.i. applied per year Percent Crop Treated

Average Max

Lettuce 300,000 30 40

Oranges 50,000 <2.5 5

Spinach 50,000 20 30

Hops 30,000 Not calculated 10

Caneberries 20,000 20 25

Strawberries 20,000 10 20

Tomatoes 20,000 <2.5 <2.5

Asparagus 10,000 10 15

Lemons 10,000 5 10

Peppers 9,000 5 5

Pistachios 9,000 <2.5 <2.5

Watermelons 9,000 <2.5 5

Onions 7,000 <2.5 <2.5

Cabbage 6,000 5 10

Peaches 4,000 <1 <2.5

Prunes 4,000 <1 <2.5

Avocados 3,000 <1 <2.5

Celery 3,000 5 10

Pears 3,000 <2.5 5

Sod 3,000 Not calculated 5

Almonds 2,000 <1 <2.5

Apples 2,000 <1 <2.5

Grapefruit 2,000 <1 <2.5

Grapes 2,000 <1 <2.5

Pumpkins 2,000 <1 <2.5

Squash 2,000 <1 <2.5

Broccoli 1,000 <1 <2.5

Cherries 1,000 <1 <2.5

Cauliflower <500 <1 <2.5

2.1.2. Uncertainties Surrounding Label Language

The information provided on the Section 3 and 24(c) labels is used to parameterize the fate and 
16

transport models that estimate exposure concentrations of fosetyl-Al in terrestrial and aquatic 

habitats. Relevant parameters include: maximum single application rate, number of applications 

per year, interval between applications and application method. In many cases, these parameter 

values can be obtained directly from the label; however, when the labels are not clear about these 

parameters, assumptions are made. Unless there is evidence to the contrary and conservative 

assumptions are made. This section discusses cases where fosetyl-Al labels are unclear and 

explains the conservative assumptions that are made in this assessment to compensate for the 

lack of clearly defined parameters relevant to application of fosetyl-Al. 

1. The labels do not specify if foliar applications are permitted via ground, aerial nethods or 

both. Because aerial application methods are expected to have greater spray drift 

exposure than ground methods, the conservative assumption is that applications are made 

via aerial methods. Based on information compiled by BEAD 6

, aerial application is not 

expected to occur on ornamentals (except for conifer nurseries), turf and ginseng.

2. The labels do not indicate specific nozzles or intended spray droplet sizes; therefore, the 

conservative size of “very fine” to “fine” was used to determine an effect area off-field. 

3. The current labels do not indicate the maximum number of applications allowed for turf 

and ornamentals. The most conservative number of applications per year is modeled

(assuming turf or ornamentals are present 365 days/year), given minimum application 

intervals.

4. The registered label Aliette® HG does not indicate maximum application rates for use on 

turf and ornamentals in landscaping (EPA Reg # 432-897). The use rates for this label 

are given in terms of using tablespoons of the fosetyl-Al solution to one gallon of 

solution. This would suggest that the volumes used for this label are small and exposure 

would be limited; therefore, the other uses for turf and ornamentals are expected to result 

in greater exposure and potential risk to non-target organisms. 

5. The currently registered fosetyl-Al label Linebacker® (EPA Reg # 61842-9) does not 

indicate the maximum number of gallons of product to apply per acre for use on conifer 

nurseries. Other labels prohibit the application of more than 400 gallons per acre; 

therefore, for this assessment an assumption of 400 gallons per acre was used. 

6. The currently registered label CHIPCOALIETTE® EXTRA and CHIPCOALIETTE®

WF2 (EPA Reg # 264-467 and # 432-894), for which the fosetyl-Al is packaged as water 

soluble packets, does not indicate the amount of material/solution contained in a packet. 

The labels (EPA Reg # 264-542 and 432-894) do not specifically state one pound per 

packet, but for the EPA Reg # 432-894 label it states to mix for example “2 to 4 pounds 

of product (2 to 4 WS packets)” or “3 pounds of product (3 WS packets)” suggesting that 

one packet contains one pound of product. Therefore, the assumption used in this 

assessment was that one packet did equal one pound of product.

7. The application intervals for citrus are not well defined. According to the Alliette WDG 

label (registration #264-516), fosetyl-Al can be applied to citrus (bearing and non-bearing) 

by root dip, trunk spray or paint, foliar, and chemigation. The labels state that any 

combination of the labeled application methods can be used; however, applications are 

 6 United States Environmental Protection Agency (EPA). Office of Pesticide Programs (OPP), Biological, 

Economical and Analysis Division (BEAD). 20111. Becker, J., Chism, W., and Yourman, L. Refinements to 

the Exposure Scenarios Used in the Registration Reivew Ecological Risk Assessment and Effects 

Determination of Fosetyl-Al. May 31, 2011. 
17

not to exceed four applications or 20 lb product per acre per year (16 lb a.i./A per year). 

Except for Alternaria Brown Spot suppression in Florida, in which case subsequent 

applications should be at 30 to 45-day intervals. The label is unclear about the application 

interval for all types of applications, however, for foliar applications, an interval of 30-45 

days is recommended. Therefore, for this assessment, the minimum application interval 

of 30 days is used. There is some uncertainty associated with this interval, since some 

uses do not specify an interval.

8. The application interval for use on pineapple is also not clearly defined on the label. The 

application interval for pineapples is stated as 90 days on the label with a post-harvest 

interval of 90 days, but the label also indicates not to apply more than six applications. 

The time interval for the six applications is not clearly stated. Based on the information 

compiled by BEAD, a newly planted crop is first harvested at 18 months. Six 

applications at three month intervals are consistent with the 18-month crop cycle. 

Therefore, on an annual basis, pineapple was modeled with four applications 90-days 

apart. 

9. Use of fosetyl-Al on grapes is only permitted in locations that are east of the Rocky 

Mountains. In addition, application instructions (specifically related to intervals between 

applications) differ for locations that are east or west of the Rocky Mountains. It would 

be useful if the labels would clarify which states are east and which are west of the Rocky 

Mountains (including definitions for the 48 contiguous states, as well as Hawaii and 

Alaska). 

2.2. Exposure Assessment

2.2.1. Environmental Fate and Transport

Fosetyl-Al is a salt and is not ecpected to persist in the environmental as a complex. Dissociation 

is expected to occur rapidly releasing aluminum (Al3+) and three ethanophosphonate ions. Fate 

data indicate ethanophosphonate degrades rapidly in soil through microbially mediated 

processes. This degradation process is expected to form ethanol (C2H5OH) and phosphonic acid 

(H2PO3

-

, also known and phosphorous acid) which dissociates rapidly to hydrogen phosphite 

(H2PO3

-

) and phosphite (HPO3

2-

). Aluminum is abundant in soil, and the aluminim from fosetylAl would add only trivial amounts of aluminum to what exists naturally. In the conditions found 

in most agricultural soils, the aluminum from fosetyl-Al would form hydration species (e.g. 

Al(OH)2+ , [Al(OH)3]) and would mostly precipitate. These species are indistinguishable from 

the natural aluminum minerals present.

Although fosetyl-Al is soluble and mobile, transport via runoff and leaching are not expected to 

be major dissipation routes due to the rapid dissociation fosetyl-Al and subsequent degredation 

of the dissociation product, ethanophosphate, in soil (half life is less than 2 hours). Fosetyl-Al 

may reach non-target areas via spray drift. Available data suggest that fosetyl-Al is efficaceous 

in plants for weeks after application7 (trunk application via paint), suggesting that fosetyl-Al is 

more persistent in plants than in soil. Fosetyl-Al is not expected to volatilize or bioaccumulate. 

Table 5 summarizes the physical, chemical and fate properties of fosetyl-Al. It should be noted 

 7 For example, see: Thomidis, T. 2002. Persistence of the sustemic activity of metalaxyl and fosetyl-Al applied as a 

soil drench or foliar spray to control Phytophthora crown rot of peach. Phytopathol. Mediterr., 41, 28-32.
18

that aerobic aquatic and terrestrial field dissipation studies have not been submitted for fosetylAl.

Table 5. Summary of Physical, Chemical, and Fate Properties of Fosetyl-Al

Property Value Source (MRID) Comments

Molecular weight (g/mol) 354 none

calculated based on 

structure

Vapor Pressure not applicable 00098325 fosetyl-al is a 

ionicsolid 

Henry’s Law Constant not calculated 00098325 fosetyl-al is a ionic 

solid 

Water solubility (mg/L at 20 °C) 120,000 00098325 none

Hydrolysis no significant degradation 00098370 none

Photolysis (Air, Water and soil) no significant degradation 00098371 none

Aerobic Soil Metabolism (halflife in hours)

sandy loam soil: 0.24

clay loam soil: 1.5

loamy sand: 1.2 and 0.69

00106018

ethanol and co2 were 

the only degredates 

identified 

Anaerobic Aquatic 

Metabolism(half-life in hours)

silty clay loam: 40 

sandy loam: 14 00147361

ethanol and co2 were 

identified as 

degredates. 

phosphonic acid was 

not monitored.

Kd-ads (mL/g) 6.5 00106019 none

Octanol-water partition 

coefficient (Kow)

Empirical: 0.0020

Estimated: 0.20 Episuite v. 4.1*

Values derived using 

fosetyl 

(ethanophosphate)

* http://www.epa.gov/oppt/exposure/pubs/episuitedl.htm

2.2.2. Residues of Concern

Fosetyl-Al is considered to be the residue of concern for this risk assessment. 

Aluminum (AL3+) and ethanol are not considered residues of concern because applications of 

fosetyl-Al are expected to contribute negligible amounts of mass relative to what is already 

present in the environment. 

Phosphonic acid (hydrogen phosphite and phosphite) is also registered as a fungicide (PC code 

076416)8

. Available acute toxicity data for birds, mammals, honey bees suggest that like fosetylAl, phosphonic acid is practically non-toxic to terrestrial animals. Available acute toxicity data 

for aquatic animals suggests that phosphonic acid is less toxic on an acute exposure basis 

compared to fosetyl-Al. Therefore, phosphonic acid will not be considered in the residues of 

concern. Toxicity data available for the same test species exposed separately to phosphonic acid 

and fosetyl-Al are compared in Table 6. It should be noted that several of the available studies 

did not establish definitive LC50 and EC50 values, making direct comparisons of values for 

fosetyl-Al and phosphonic acid difficult (i.e., for birds, rats and bees).

Table 6. Comparison of Toxicity Data (acute) Available for Phosphonic Acid and FosetylAl

 8 http://www.epa.gov/opp00001/chem_search/reg_actions/registration/fs_PC-076416_1-Oct-98.pdf
19

Test species Endpoint (units) Fosetyl-Al 

value

Phosphonic acid 

value

Fosetyl-Al 

MRID

Phosphorus 

acid MRID

Rainbow trout LC50 (μg a.i./L) 83,400 790,000 00128944 44873510

Daphnia EC50 (μg a.i./L) 304,000 1,200,000 00128943 44873511

Green algae EC50 (μg a.i./L) 4,500 (7-d) 5,900 (3-d) 41128604 47408717

Bobwhite quail

LD50 (mg a.i./kgbw) >8,000 >2,000 00098360

44873508 

and 

46708207

LC50 (mg a.i./kgfood) >20,000 >5,620 00098362 46708208

Mallard LC50 (mg a.i./kgfood) >20,000 >5,000 00098363 44873509

Rat LD50 (mg a.i./kgbw) 5793 3300 00098330 44873501

Honey bee LD50 (μg a.i./bee) >986 >25 47418003 44873512

2.2.3. Exposure Estimation

To estimate exposure concentrations, the ecological risk assessment considers application at the 

maximum rate to fields that have vulnerable soils. This assessment will focus on fosetyl-Al only. 

For this assessment, the Terrestrial Residue Exposure (T-REX) model (version 1.5.2) is used to 

assess risks to terrestrial vertebrates (i.e., mammals, birds, terrestrial-phase amphibians and 

reptiles) consuming food directly from the treated field. The distance from the edge of the field 

(to a non-target area that is downwind) where risks extend to terrestrial plants and insects is 

estimated using the AgDRIFT model (version 2.0). For aquatic organisms, the concentration in 

water due to spray drift from foliar spray applications will be calculated using the AgDRIFT 

model. Since fosetyl-Al is only expected to persist in soil for a matter of hours, runoff transport 

will not be quantified and thus estimated environmental concentration (EEC) values will not be 

calculated.

2.3. Effects Assessment

2.3.1. Ecosystems of Concern

The ecosystems that are potentially at greatest risk are those in close proximity to fosetyl-Al use 

sites. These include agricultural fields and residential areas (i.e., with turf and ornamentals) and 

the surrounding areas that may receive fosetyl-Al via spray drift. Organisms of concern include 

birds, mammals, reptiles, fish, and terrestrial and aquatic invertebrates, plants, and amphibians. 

2.3.2. Assessment and Measurement Endpoints

Assessment endpoints are intended to relate to ecosystems at risk. If risks are expected for a 

given species/taxa based on the risk assessment, then risks might be expected to translate to 

higher levels of biological organization. Assessment endpoints are represented by measurement 

endpoints, which are the most sensitive toxicity endpoints from a surrogate test species to 

estimate treatment-related direct effects following acute and chronic exposure. Measurement 

endpoints are standardized so that acute toxicity is represented by levels that result in mortality 

to 50% of tested individuals (i.e., LC50, LD50 and EC50) and chronic toxicity is represented as a 
20

no observed adverse effect concentration or dose (i.e., NOAEC or NOAEL). Tables 7 and 8

include the most sensitive toxicity endpoints available for fosetyl-Al that will be used as 

measurement endpoints to assess risks to terrestrial and aquatic organisms (respectively). These 

values were used to derive risk quotients.
TABLE 7. Measurement Endpoints for Terrestrial Organisms Exposed to Fosetyl-Al

Taxa 

represented Species Toxicity Value*

Citation

(MRID)

Study 

Classification Comments

Birds, terrestrialphase 

amphibians and 

reptiles**

Colinus virginianus

(bobwhite quail) and Anas 

platyrhynchos (Mallard 

Duck) 

LC50>20,000 mg

a.i./kg-food

00098362 

and 

00098363

Acceptable

No observed mortalities at highest treatment level. 

RQs not calculated using this endpoint.

Coturnix japonica

(Japanese quail)

LD50 = 4976 mg

a.i./kg-bw 00098361

Supplemental Confidence interval: 3678-6788. Since LD50 was 

calculated using moving average method, no slope 

was calculated.

Average body weight of control birds at test 

initiation was 192 g.

NOAEC = 1414 

mga.i./kg-food 47408710 Supplemental No observed effects at highest treatment level. LOAEC not established.

Terrestrial 

mammals

Mus musculus. (mouse) LD50 = 3712 mg 

a.i./kg-bw 00098330 Mean body weight = 20 g

Rattus norvegicus

(laboratory rat)

NOAEC =6000 mg 

a.i./kg-food

NOAEL = 300 mg 

a.i./kg-bw

00247174 LOAEC = 12,000 mg/kg-food based on decreased 

body weight in offspring

Terrestrial 

invertebrates

Typhlodromus pyri

(predatory mite) LOAEC = 1.8 lb a.i./A 48803208

Supplemental

Based on 22% decrease in reproduction

Apis mellifera (honey bee) LD50 = 14 lb a..i./A 47418003

Supplemental The oral LD50 of 455 μg a.i./bee was converted to 

an application rate using the pollinator risk 

assessment method.

Non-target 

terrestrial and 

wetland plants -

dicots

Solanum esculentum 

(tomato) 

EC25 = 7.6 lb a.i./A 47395701

Supplemental

Decrease in shoot weight observed in vegetative 

vigor study.

Non-target 

terrestrial and 

wetland plants -

dicots

Avena sativa (oat), Allium 

cepa (onion)

EC25 >66 lb a.i./A 47395701

Supplemental

From vegetative vigor study.

*LC50 and LD50 values are used to evaluate acute exposures and NOAEC and NOAEL values are used for chronic exposures.

** Birds represent surrogates for terrestrial-phase amphibians and reptiles. Fish represent surrogates for aquatic-phase amphibians.
22

TABLE 8. Measurement Endpoints for Aquatic Organisms Exposed to Fosetyl-Al

Taxa represented Test Species (common 

name)

Toxicity Value (μg 

a.i./L)*

Citation 

(MRID)

Study 

Classification

Comments

freshwater and 

saltwater fish and 

aquatic-phase 

amphibians**

Oncorhynchus mykiss

(rainbow trout)

96-hr LC50 = 83,400 00128944

Acceptable Most sensitive endpoint used as screen. Value 

selected from available from freshwater and 

saltwater test species.

Not available none none no chronic toxicity studies are available. 

Freshwater and 

Estuarine/ Marine 

Invertebrates

Crassostrea virginica 

(Eastern oyster)

96-hr EC50 =1,850 000147359 Acceptable none

NOAEC = 179 Calculated 

value

None Based on ACR of 19 from toxicity data for Daphnia 

magna applied to the acute grass shrimp LC50 of 

3,400 μg a.i./L..Acute endpoint = 304,000 μg a.i./L 

(MRID 00128943; Acceptable classification).

Chronic endpoint = 16,000 μg a.i./L (MRID 

47395703; supplemental classification).

Aquatic Plants 

(unicellular and 

vascular)

Skeletonema cosatum 

(marine diatom) 7-d EC50 = 780 41128605

Acceptable

NOAEC = 320 μg a.i./L

*LC50 values are used to evaluate acute exposures and NOAEC values are used for chronic exposures.

** Birds represent surrogates for terrestrial-phase amphibians and reptiles. Fish represent surrogates for aquatic-phase amphibians.
2.4.Risk Assessment

2.4.1. Conceptual Model

Figures 2-4 depict the conceptual models of the fate and potential effects associated with spray 

applications, soil drench to ornamentals, and seed treatments of fosetyl-Al. These figures are 

modified from the preliminary problem formulation. One notable change is that the original 

conceptual models from the problem formulation indicated that runoff would be considered a 

relevant transport route. This assessment focuses on parent fosetyl-Al alone. In the figures, 

dashed lines represent pathways of exposure that are unlikely to occur because of physical or 

chemical properties. Based on the rapid degredation of fosetyl-Al in soil, runoff and leaching are 

not expected to represent substantial transport pathway. In addition, fosetyl-Al is not expected to 

volatilize or bioaccumulate. Therefore, major non-target organism exposure routes of concern for 

this assessment include ingestion of food items that have received direct deposition (i.e., on the 

treated field) or spray drift to non-target areas.

Figure 2. Ecological Conceptual Model for Fosetyl-Al from Ground and Aerial Foliar 

Application and Trunk Spray

Stressor

Fosetyl- Al applied as a ground/aerial foliar spray and trunk spray to an agriculture field 

Source/

Transport

Pathways

Volatilization 

of degradates/ 

Wind 

Suspension*

Direct

Deposition

Spray

Drift

Runoff/

Erosion

Leaching

(Infiltration/

Percolation

Source/

Exposure

Media

Terrestrial Food 

Residues (foliage, 

fruit, insects

Upland

Foliage/Soil

Riparian/

Wetland 

Foliage/Soil

Receiving 

Water Body/ 

Sediment

Groundwater

Exposure

Route

Ingestion Direct contact/

Root Uptake

Direct contact/

Root Uptake

Gill/

Integument 

Uptake

Receptors

Attribute

Changes

Terrestrial Invertebrates

Birds, Mammals,

Reptiles, Terrestrial 

Phase Amphibians

Terrestrial

Upland

Plants, Inverts

Individual Animals

Reduced survival

Reduced growth

Reduced

reproduction

Aquatic 

Invertebrates

Aquatic 

Vertebrates

Wetland/ 

Riparian

Plants

Individual Plants

Seedling emergence

Vegetative vigor

Individual 

vertebrates and 

invertebrates

Reduced

survival

Reduced

growth

Reduced

reproduction

Plant 

population

Reduced

population

growth

Aquatic 

Plants

Uptake/ 

Adsorption

Ingestion 

up the 

Food Chain

Piscivourous

Vertebrates

Birds, 

Mammals

Individual 

Animals

Reduced

survival

Reduced

growth

Reduced

reproduction *Long -

range transport with dry/wet deposition onto soil, foliage, receiving water body resulting in same 

exposure pathway concerns identified for direct deposition, spra y drift, runoff/erosion, and leaching
24

Figure 3. Ecological Conceptual Model for Fosetyl-Al from Soil Drench to Ornamentals 

Stressor Fosetyl-Al applied as a soil drench to ornamentals 

Source/

Transport

Pathways

Direct

Deposition

Runoff/

Erosion

Leaching

(Infiltration/

Percolation

Source/

Exposure

Media

Terrestrial Food 

Residues (foliage, 

fruit, insects

Upland

Foliage/Soil

Riparian/

Wetland 

Foliage/Soil

Receiving 

Water Body/ 

Sediment

Groundwater

Exposure

Route

Ingestion Direct contact/

Root Uptake

Direct contact/

Root Uptake

Gill/

Integument 

Uptake

Receptors

Attribute

Changes

Terrestrial Invertebrates

Birds, Mammals,

Reptiles, Terrestrial 

Phase Amphibians

Terrestrial

Upland

Plants, Inverts

Individual Animals

Reduced survival

Reduced growth

Reduced

reproduction

Aquatic 

Invertebrates

Aquatic 

Vertebrates

Wetland/ 

Riparian

Plants

Individual Plants

Seedling emergence

Vegetative vigor

Individual 

vertebrates and 

invertebrates

Reduced

survival

Reduced

growth

Reduced

reproduction

Plant 

population

Reduced

population

growth

Aquatic 

Plants

Uptake/ 

Adsorption

Ingestion 

up the 

Food Chain

Piscivourous

Vertebrates

Birds, 

Mammals

Individual 

Animals

Reduced

survival

Reduced

growth

Reduced

reproduction -
25

Figure 4 Ecological Conceptual Model for Fosetyl-Al from Seed Treatment to Peas

2.4.2. Risk Hypothesis

For fosetyl-Al, the following ecological risk hypotheses are being employed for this risk 

assessment: 

Terrestrial Environment

• Exposure to fosetyl-Al residues on seeds, insects, and foliage due to direct deposition or 

spray drift from labeled use of the pesticide will cause reduced survival, growth and 

reproduction to terrestrial vertebrates (birds, mammals, reptiles, terrestrial-phase 

amphibians) and terrestrial invertebrates.

• Exposure to fosetyl-Al residues on foliage due to spray drift resulting from labeled use of 

the pesticide will result in reduced survival and biomass to upland plants and 

riparian/wetland plants in areas adjacent to a treated field. 

Stressor Fosetyl Al applied to pea seeds that are then planted

Source/

Transport

Pathways

Direct

Deposition

Source/

Exposure

Media

Terrestrial Food 

Residues (on seeds)

Exposure

Route

Ingestion

Receptors

Attribute

Changes

Terrestrial Vertebrates

Birds, Mammals,

Reptiles, Terrestrial 

Phase Amphibians

Individual Animals

Reduced survival

Reduced growth

Reduced Reproduction

-
26

Aquatic Environment

• Exposure to fosetyl-Al residues in water due to spray drift resulting from labeled uses of 

fosetyl-Al will cause reduced survival, growth and reproduction to aquatic invertebrates 

and fish in surface waters adjacent to a treated field.

• Exposure to fosetyl-Al residues in water due to spray drift from labeled uses of fosetyl-Al 

will cause reduced survival and biomass to aquatic vascular and non-vascular plants in 

surface waters adjacent to a treated field.

3. Exposure Analysis

3.1.Direct Deposition onto Food Items (located on treated field)

The T-REX model is used to generate upper-bound concentrations of fosetyl-Al on food items 

(i.e., grass, broadleaf plants, seeds and arthropods) located on the treated field. This is 

accomplished by modeling the single maximum foliar applications as allowed on registered 

labels. The resulting concentrations from single applications are depicted in Figure 5. These 

values will be used to represent dietary-based exposures and will be converted to dose-based 

exposures using food ingestion rates for mammals and birds.

Figure 5. Estimated Upper-bound Pesticide Concentrations of Fosetyl-Al on Different Food 

Items Following One Applications at Various Application Rates Estimates generated by TREX model.

Exposures resulting from multiple applications will also be modeled using the maximum number 

of applications allowed per year, separated by the minimum allowed reapplication intervals

(Table 9). Labels with uses on ornamentals, conifer nurseries and turf did not specify the 

maximum number of applications allowed per year. For modeling purposes, it was assumed that 

the maximum number of applications that are possible per year may occur, when considering the 

minimum application interval. 

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

0 5 10 15 20

Short grass

Tall Grass

Broadleaf plants

seeds

arthropods

application rate (lb a.i./A)

estimated concentration (mg a.i./kg)
Page 27 of 78

Table 9. Use-specific Input Parameters for Estimating Exposure in T-REX for Foliar 

Applications of Fosetyl-Al Based on Maximum Labeled Rates and Minimum Retreatment 

Intervals Summarized in Table 3

Crop Application rate

lbs a.i./A

Number of 

Applications

Application Interval

(days)

hops 2 4 21

onion (dry) 2.4 7 7

tobacco 3.2 5 7

asparagus 4 1 NA

stone fruits 4 4 60

almonds, citrus, cranberry, kiwis, 

peaches, plums, prunes, walnuts

4 4 30

caneberry, hops (24 c) 4 4 21

blueberry 4 4 14

tomato 4 4 7

pome fruits 4 4 4

strawberries 4 6 7

grapes 4 7 21

brassica, cucurbits, leafy vegetables 4 7 7

ginseng 4 9 7

banana 4.8 4 90

macadamia nuts 6 4 21

pineapple 12 6 90

ornamentals 12.9 NS (52)* 7

ornamentals and/or conifer nurseries 16 NS (12)* 30

turf 17.6 NS (26)* 14

*Value not specified on labels. Number of applications in parentheses was assumed to be the maximum number of 

applications per year based on the application interval.

Fosetyl-Al is systemic in plants and the data suggest that once taken up by the plant it is shielded 

from the relatively rapid degradation via soil microbes. For instance, in a study examining the 

efficacy of fosetyl-Al applied to peach trees via trunk paint, it appeared to protect plants from 

fungal spread up to 40 days after the application (but not 60 days later) (Thomidis 2002). 

Therefore, for multiple applications of fosetyl-Al, the default foliar dissipation half-life of 35 

days will be used for terrestrial assessments. Available magnitude of the residue and metabolism 

studies submitted for fosetyl-Al are insufficient to derive a chemical-specific half-life for various 

reasons, for instance, lack of day 0 measurements and insufficient mass balance. 

3.2. Spray Drift Transport

The spray deposition curves as calculated by AgDRIFT are provided in Figures 6, 7 and 8. Note 

that these figures represent point estimates of spray drift depiction at distances from the edge of 

the field. Values are expressed as the percent of the applied rate so as to apply to various rates of 

fosetyl-Al. When multiplied by the appropriate single maximum application rate, these values 

can be used to determine the distance from the edge of the field where effects to non-target 

organisms are no longer of concern.
Page 28 of 78

Figure 6. Percent of Applied Pesticide at Different Distances from the Edge of the Field 

Treated by Aerial Application Methods 

Figure 7. Percent of Applied Pesticide at Different Distances From the Edge of the Field 

Treated by Ground Application methods 

0%

10%

20%

30%

40%

50%

0 200 400 600 800 1000

% of applied

Distance from edge of field (feet)

ASAE very fine to fine

ASAE fine to medium

ASAE medium to 

coarse

0%

10%

20%

30%

40%

50%

0 100 200 300 400 500

% of applied

Distance from edge of field (feet)

High boom, ASAE very 

fine to fine

High boom, ASAE fine 

to medium/coarse

Low boom, ASAE very 

fine to fine

Low boom, ASAE fine 

to medium/coarse
Page 29 of 78

Figure 8. Percent of Applied Pesticide at Different Distances From the Edge of the Field 

Treated by Airblast Equiptment

For the aquatic assessment, the aquatic deposition tool of AgDRIFT was used to estimate the 

pesticide concentrations in the standard farm pond following aerial and ground foliar spray 

applications made at the maximum rates. For aerial applications, the maximum rate of 16 lb 

a.i./A (made to conifer nurseries) yielded an EEC of 92 μg a.i./L. For ground applications, the 

maximum rate of 17.6 lb a.i./A (made to turf) yielded an EEC of 3.5 μg a.i./L. For airblast

applications (sparse setting), the maximum rate of 6 lb a.i./A (made to macadamia nut) yielded 

an EEC of 0.35 μg a.i./L.

4. Effects Analysis

This section summarizes the availale toxicity data for fosetyl-Al Additional details on the 

fosetyl-Al studies are provided in Appendix A. The endpoints used for deriving risk quotient 

(RQ) values are depicted in Tables 7 and 8. Toxicity data were obtained from registrantsubmitted studies and the scientific literature. 

In addition, the Ecological Incident Information System (EIIS), the Avian Incident Monitoring 

System (AIMS) and aggregate incident databases were searched for reports. Two ecological 

incidents involving fosetyl-Al have been reported, both of which relate to plant damage observed 

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

45.0%

50.0%

0 200 400 600 800 1000

% of applied

Distance from edge of field (feet)

Orchard

Vineyard

Sparse
Page 30 of 78

on a treated crop, specifically spinach (Appendix A, Section A.1.4).

4.1.Toxicity of Fosetyl-Al

4.1.1. Terrestrial Organisms

Birds

On an acute oral and sub-acute dietary exposure basis, fosetyl-Al is practically non-toxic to birds 

(i.e., LD50 >2000 mg/kg-bw and LC50>5000 mg/kg-diet). In an acute oral toxicity study with the 

Japanese quail (MRID 00098361), the acute oral LD50 of technical fosetyl-Al was 4,976 (3678-

6788) mg/kg-bw. There is uncertainty in this endpoint due to the test design of this study (i.e.,

close spacing of test doses, low number of birds per treatment, observation of mortality at all test 

doses). In another acute oral toxicity study (MRID 00098360), the LD50 was >8000 mg/kg-bw 

for bobwhite quail dosed with technical fosetyl-Al. At the highest test concentration (i.e., 8000 

mg/kg-bw), 30% mortality was observed. In a study with a formulated product containing 

fosetyl-Al (79.4%), no significant mortalities to bobwhite quail were observed at the highest 

dose of 5082 mg a.i./kg-bw (MRID 47408712). In sub-acute dietary toxicity studies with fosetylAl, LC50 values were >20,000 mg a.i./kg-diet for bobwhite quail and mallard and no significant 

mortalities were observed at the highest treatment groups (i.e., 20,000 mg a.i./kg-diet; MRIDs 

00098362 and 00098363). 

In a chronic reproduction study with the Japanese quail fed technical fosetyl-Al, no statistically 

significant effects were observed on endpoints representing parental survival and reproduction, 

and offspring growth and survival at the highest dose tested (i.e., 1414 mg/kg-diet; MRID 

47408710). The NOAEC from this study is 1414 mg/kg-diet; however, this value should be 

considered uncertain since no LOAEC was established in this study. Chronic toxicity data for 

birds is required for two test species, which are typically the bobwhite quail and the mallard 

duck. Lack of toxicity data for two test species represents a data gap in this assessment, leading 

to uncertainty associated with the quantification of an endpoint to represent reproductive effects 

of fosetyl-Al on birds. 

Mammals

On an acute oral exposure basis, fosetyl-al is practically non-toxic to mammals (i.e., LD50 >2000 

mg/kg-bw). The acute oral LD50 values for the rat, mouse, rabbit and guinea pig are 5793, 3712, 

2682 and 2789 mg/kg-bw for fosetyl-Al, respectively (MRID 00098330). When considering the 

process for adjusting acute oral toxicity values from tested to assessed mammals, the mouse 

LD50 would yield the most conservative LD50 values (due to its small size relative to the other 

test species); therefore this value is considered the most sensitive for evaluating acute oral-based 

dietary toxicity of fosetyl-Al. Available acute toxicity data for formulated products containing 

fosetyl-Al do not suggest an increased toxicity of the formulations. In an acute oral study 

involving Aliette® WDG, LD50 value was 2,860 mg/kg-bw. All other available tests with 

formulations resulted in non-definative LD50 values (Aliette® WP, Aliette® Injectable, 10361A 

WG, and EXP® 10100G LD50 values were >5,000 mg/kg-bw and the LD50 value of EXP®

11047A was >2,000 mg/kg-bw. 
Page 31 of 78

A multiple generation rat reproduction study (MRID 00247174) had a NOAEC of 6,000 mg/kgdiet (NOAEL = 300 mg/kg-bw/day), and a LOAEC of 12,000 mg/kg-diet. The LOAEC is based 

on decreased litter and pup body weight (day 8) in both matings of each generation, F1 and F2.

Invertebrates

Toxicity data involving exposures of terrestrial invertebrates to fosetyl-Al are available from 

registrant-submitted studies and the scientific literature. These studies have a variety of designs, 

endpoints, results, and uncertainties. Available toxicity information indicate that many species,

including the honey bee9 are insensitive to fosetyl-Al; however, some species, such at the 

predatory mite (Typhlodromus pyri) and sweet-potato whitefly (Bemisia tabaci) appear to be 

impacted by fosetyl-Al at levels that are relevant to currently registered application rates (i.e., as 

low as 1.8 lb a.i./A). The available insect data are summarized in Table 10. Note that studies 

from open literature that did not provide sufficient information to allow for conversion of 

exposure values to lbs a.i./A were not included in this table. 

 9 In the standard acute contact study with the honey bee, Fosetyl-Al is classified as practically non-toxic (contact 

LD50 >986 μg a.i./bee; MRID 47418003).
Page 32 of 78

Table 10. Summary of Effects Data for Laboratory and Field Tests Involving Exposures of Insects to Fosetyl-Al

Application 

rate (lb a.i./A) Effect observed? Effect assessed Exposure route

Study 

type MRID/Citation Test Species (common name)

1.8 no mortality contact Lab 48803208 Typhlodromus pyri (predatory mite)

1.8 yes (22% decrease) reproduction contact Lab 48803208 Typhlodromus pyri (predatory mite)

2.6 no Population size contact Field 48803214 Predatory mites (primarily Typhlodromus pyri)

2.8 no Population size contact Field Palumbo et al.

199310 Bemisia tabaci (Sweetpotato whitefly)

2.9 yes (25% reduction) Population size contact Field 48803214 Predatory mites (primarily Typhlodromus pyri)

3.2 yes (42% decrease) Number of eggs contact Field Chu et al. 1994a11 Bemisia tabaci (Sweetpotato whitefly)

3.2 no

Number of 

nymphs contact Field Chu et al. 1994a Bemisia tabaci (Sweetpotato whitefly)

4 yes (75% decrease) Number of 

adults contact Field Stansly and Cawley 199412 Bemisia tabaci (Sweetpotato whitefly)

4 yes (90% decrease) Number of eggs contact Field Stansly and Cawley 

1994 Bemisia tabaci (Sweetpotato whitefly)

4 yes (83% decrease) Number of 

nymphs contact Field Stansly and Cawley 1994 Bemisia tabaci (Sweetpotato whitefly)

4 no Population size contact Field Chu et al. 1994 b13 Bemisia tabaci (Sweetpotato whitefly)

4 no Population size contact Field Schuster 199314 Bemisia tabaci (Sweetpotato whitefly)

4 no Population size contact Field Riley 199415 Bemisia tabaci (Sweetpotato whitefly)

5.1 yes (25-40% 

reduction) Population size contact Lab 48803214 Predatory mites (primarily Typhlodromus pyri)

5.4 yes (61% increase) Mortality contact Lab 48803212 Typhlodromus pyri (predatory mite)

5.4 yes (77% decrease) Reproduction contact Lab 48803212 Typhlodromus pyri (predatory mite)

6.3 no mortality contact Lab 48803208 Typhlodromus pyri (predatory mite)

6.3 yes (59% decrease) reproduction contact Lab 48803208 Typhlodromus pyri (predatory mite)

 10 Palumbo, J.C, C.H. Mullis, and F.J. Reyes. 1993. Control of sweetpotato whitefly in cantaloupe with various pesticides. Insecticide and Acaricide Test. Vol. 

18. P 117. 35E.

11 Chu, C. C., Henneberry, T. J., and Akey, D. H. ( 1994). Insecticide Control of Sweetpotato Whitefly on Spring Cantaloupe, 1992. Arthropod Manag.Tests 19: 

78-79 (29E) 12 Stansly, P. A. and Cawley, B. M. (1994). Control of Immature Sweetpotato Whitefly (SPWF) on Staked Tomato, Spring, 1992. Arthropod Manag.Tests 19: 

156-158 (121 & 122E) 13 Chu, C. C., Henneberry, T. J., and Akey, D. H. ( 1994). Insecticide Control of Sweetpotato Whitefly on Cotton, 1992. Arthropod Manag.Tests 19: 221 (61F) 14 Schuster, D.J. 1993. Management of the Sweetpotato Whitefly and Geminivirus on Fresh Market Tomatoes in West-Central Florida, Spring 1992. Insectic. 

Acaric. Tests18: 177-179 15 Riley, D. (1994). Insecticide Control of Sweetpotato Whitefly in South Texas. Subtrop.Plant Sci. 46: 45-49.
Page 33 of 78

Application 

rate (lb a.i./A) Effect observed? Effect assessed Exposure route

Study 

type MRID/Citation Test Species (common name)

8 no Mortality and 

reproduction contact Lab 48803215 Coccinella septempuncatata (ladybird beetle)

8.3* no mortality Oral Lab 47418002 Apis mellifera (honey bee)

8.6 no Mortality and 

parasitism contact Lab 48803202 Aphidius rhopalosiphi (parasitoid wasp)

8.6 yes (81% increase) Mortality contact Lab 48803204 Typhlodromus pyri (predatory mite)

8.6 yes (almost 100% 

decrease) Reproduction contact Lab 48803204 Typhlodromus pyri (predatory mite)

8.6 no Mortality and 

reproduction contact Lab 48803205 Coccinella septempuncatata (ladybird beetle)

8.6 no Mortality and 

reproduction contact Lab 48803211 Aleochara bilineata (rove beetle)

8.7 no Mortality and 

parasitism contact Lab 48803210 Aphidius matricariae (predatory wasp)

11 no mortality contact Lab 48803201 Poecilus cupreus (carabid beetle)

13 no Mortality and 

parasitism contact Lab 48803202 Aphidius rhopalosiphi (parasitoid wasp)

13 yes (89% increase) Mortality contact Lab 48803204 Typhlodromus pyri (predatory mite)

13 yes (almost 100% 

decrease) Reproduction contact Lab 48803204 Typhlodromus pyri (predatory mite)

13 yes (66% increase) Mortality contact Lab 48803205 Coccinella septempuncatata (ladybird beetle)

13 no mortality contact Lab 48803208 Typhlodromus pyri (predatory mite)

13 yes (58% decrease) reproduction contact Lab 48803208 Typhlodromus pyri (predatory mite)

13 no Mortality contact Lab 48803211 Aleochara bilineata (rove beetle)

13 yes (15% decrease) Reproduction contact Lab 48803211 Aleochara bilineata (rove beetle)

13 yes (87% increase) Mortality contact Lab 48803212 Typhlodromus pyri (predatory mite)

13 no Mortality and 

reproduction contact Lab 48803215 Coccinella septempuncatata (ladybird beetle)

15* yes (47% increase) Mortality Oral Lab 47418003 Apis mellifera (honey bee)

17 no mortality contact Lab 48803201 Poecilus cupreus (carabid beetle)

18* yes (77% increase) mortality Oral Lab 47418003 Apis mellifera (honey bee)

23 no Mortality and 

reproduction contact Lab 48803215 Coccinella septempuncatata (ladybird beetle)
Page 34 of 78

Application 

rate (lb a.i./A) Effect observed? Effect assessed Exposure route

Study 

type MRID/Citation Test Species (common name)

36 yes (43% decrease)

Mortality/Repro

duction 

(amount of 

capped brood)

oral Field 47408716 Apis mellifera (honey bee)

39 yes (17% decrease) Reproduction contact Lab 48803216 Aleochara bilineata (rove beetle)

40 no Mortality and 

reproduction contact Lab 48803215 Coccinella septempuncatata (ladybird beetle)

46 yes (22% decrease) Reproduction contact Lab 48803216 Aleochara bilineata (rove beetle)

57 no Mortality and 

parasitism contact Lab 48803207 Aphidius rhopalosiphi (parasitoid wasp)

57 no Mortality and 

reproduction contact Lab 48803213 Typhlodromus pyri (predatory mite)

57 no Mortality and 

reproduction contact Lab 48803215 Coccinella septempuncatata (ladybird beetle)

71 yes (50% decrease)

Mortality/Repro

duction 

(amount of 

capped brood)

oral Field 47408716 Apis mellifera (honey bee)

71 yes (14% increase) Mortality contact Lab Cabrera et al. 200416 Statiolaelaps scimitus (Soil-Dwelling 

Predatory Mite)

89 yes (65% increase) Mortality contact Lab 48803203 Pardosa amentata (wolf spider)

89 no Mortality contact Lab 48803206 Poecilus cupreus (carabid beetle)

115* no mortality contact Lab 47418002 Apis mellifera (honey bee)

365* no mortality contact Lab 47418003 Apis mellifera (honey bee)

*Converted from ug a.i./bee using methods described in USEPA, PMRA, CADPR 2012

 16 Cabrera A.R., Cloyd, R.A., and Zaborski, E.R. 2004. Effects of Greenhouse Pesticides on the Soil-Dwelling Predatory Mite Statiolaelaps scimitus (Acari: 

Mesostigmata: Laelapidae) Under Laboratory Conditions. The Journal of Toxicological Sciences 19:25-35.
Page 35 of 78

Plants

Toxicity data involving exposures of terrestrial plants to fosetyl-Al are available from registrantsubmitted studies, open literature as well as reported incidents. These studies have a variety of 

designs, endpoints, results and uncertainties. The available data are summarized in Table 11, 

with detailed descriptions provided in Appendix A. As described below, separate endpoints are 

used in this assessment to assess potential effects of fosetyl-Al on non-listed species of dicots 

and monocots.

Table 11. Effects to Plants Observed in Studies Involving Foliar Applications of Fosetyl-Al 

Species

(scientific 

name)

Application 

rate (lb a.i./A)

Magnitude of 

Effect Description of effect Source (ECOTOX #, MRID #, Incident #)

Cantaloupe

(Cucumis 

melo var. 

cantalupensis)

3.2 none number of melons E97787; Chu et al. 

1994a

cantaloupe 4 none melon size and number E97955; Riley 1994

cantaloupe 4 49% decrease sugar in melons E97955; Riley 1994

Cotton

(Gossypium 

sp.)

4 none Lint yield E97788; Chu et al. 

1994b

Cabbage

(Brassica 

oleracea)

4 none Cabbage head size E97955; Riley et al. 

1994

cabbage 4 none Leaf damage E97955; Riley et al. 

1994

Tomato

(Solanum 

lycopersicum)

4 none Visible phytotoxicity E98097;Schuster 1993

tomato 4 none Fruit size and number E98097; Schuster 1993

tomato 4.2 none Shoot dry weight ( NOAEC in this 

study) MRID 47395701

tomato 7.6* 25% decrease shoot dry weight (EC25) MRID 47395701

tomato 8.4 30% decrease shoot dry weight ( LOAEC in this 

study) MRID 47395701

cabbage 34 Not quantified chlorosis MRID 47395701

Cucumber

(Cucumis 

sativus)

66 9% decrease Shoot dry weight MRID 47395701

Oat (Avena 

sativa) 66 Not quantified chlorosis MRID 47395701

cabbage 66 none Shoot dry weight MRID 47395701

oat 66 none Shoot dry weight MRID 47395701

Onion (Allium 

cepa) 66 none Shoot dry weight MRID 47395701

Soybean

(Glycine max) 66 none Shoot dry weight MRID 47395701

tomato 67 Not quantified chlorosis MRID 47395701

*This value represents the endpoint used for deriving RQs for dicots.
Page 36 of 78

Dicots: The EC25 value for tomato, i.e., 7.6 lb a.i./A (MRID 47395701) is used quantitatively in 

this risk assessment to calculate RQs for non-listed terrestrial and semi-aquatic dicot plants and 

to determine indirect effects to listed species of animals which depend upon terrestrial or semiaquatic plants (e.g., for food or shelter). Of all of the available toxicity data involving exposures 

of terrestrial dicots to fosetyl-Al, this endpoint is the most certain because it was conducted 

under standard test procedures, with known application rates and quantified response variables. 

All other tested dicot species experienced effects less than 25% even at higher application rates. 

Monocots: The EC25 value used to assess risks to non-listed monocots is >66 lb a.i./A. This is 

based on the results of the vegetative vigor study with fosetyl-Al, where monocots were tested at 

a limit concentration of 66 lb a.i./A and the percent dry weight inhibition compared to the 

controls was <25% (i.e., 0 and -8%, for the onion and oat, respectively).

Two incident reports exist in EFED’s EIIS database, both of which apply to effects to spinach, 

following applications to this crop. Both of the incidents were considered registered uses at the 

time of the incident. The first incident report was of plant damage following an application of 

Aliette® WDG (Incident # I010772-031). The application rate is uncertain. The second incident 

involved leaf burn following an application of 3 lb a.i./A of Aliette® 80WDG (Incident # 

I016232-005). The certainty categories regarding the likelihood that the use of fosetyl-Al caused 

the two incidents are both possible. Neither of the incidents involved reported additional 

chemicals besides fosetyl-Al. In addition, registrants have reported one minor plant incident for 

fosetyl-Al. 

4.1.2. Aquatic Organisms

Fish

Information is available from eight acute toxicity studies of fosetyl-Al with freshwater fish, and 

one study for an estuarine/marine fish. Fosetyl-Al is classified as slightly toxic to practically 

non-toxic to freshwater and estuarine/marine fish on an acute basis. The most sensitive 

endpoints for all fish (LC50 = 83,400 μg a.i./L for rainbow trout; MRID 00128944) will be used 

to derive RQs for freshwater and saltwater species.

Invertebrates

On an acute exposure basis, fosetyl-Al is practically non-toxic to freshwater invertebrates and 

slightly toxic to estuarine-marine invertebrates. For acute exposure, EC50 values for freshwater 

and saltwater invertebrates are 304,000 μg a.i./L and 1,850 μg a.i./L, respectively. A chronic 

NOAEC of 16,000 μg a.i./L is available for waterfleas (Daphnia magna) exposed to fosetyl-Al; 

however, no chronic toxicity data are available for saltwater invertebrates. For this risk 

assessment, RQs were derived using the most sensitive acute toxicity endpoint (i.e., 1,850 μg 

a.i./L for saltwater invertebrates) and a chronic endpoint of 179 μg a.i./L will be used based on 

an acute-to-chronic ratio of 19 from the available data for D. magna. 

Plants
Page 37 of 78

The most sensitive non-vascular aquatic plant is the marine diatom Skeletonema costatum, with a 

reported the 7-d EC50 value of 780 μg a.i./L(MRID 41128605). The corresponding NOAEC

from that study, which is used to characterize effects of fosetyl-Al on listed aquatic plants is 320

μg a.i./L. the EC50 values for the other species range from 4,200 to 7,200 μg a.i./L (MRIDs 

41128601, 41128602, 41128604, 47408718, and 47408719, see Appendix A for more details).

Available data do not indicate an increase in toxicity of formulations compared to technical 

fosetyl-Al. 

The aquatic vascular plant, Lemna gibba, study using technical grade fosetyl-Al, reported a 7-d

EC50 value of 80,000 μg a.i./L and a NOAEC of 20,400 μg a.i./L based on the most sensitive 

endpoint of reduced frond count (MRID 41128603). 

4.2.Endocrine Disruptor Screening Program

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse 

outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and 

chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, 

reproductive, and general or systemic toxicity. These studies include endpoints which may be 

susceptible to endocrine influence, including effects on endocrine 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, developmental and reproductive effects in different 

taxonomic groups. As part of the Preliminary Problem Formulation for Registration Review (DP 

Barcode 342370), 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), fosetyl-Al is subject to the endocrine screening part of the Endocrine 

Disruptor Screening Program (EDSP). 

EPA has developed the EDSP to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator 

may designate.” The EDSP employs a two-tiered approach to making the statutorily required 

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a 

chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal 

systems. Chemicals that go through Tier 1 screening and are found 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 effects caused by the substance, and 

establish a dose-response relationship between the dose and the E, A, or T effect. 

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between 

October 2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 

chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. A second list 
Page 38 of 78

of chemicals identified for EDSP screening was published on June 14, 201317 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. 

Fosetyl-Al is on the second list. This list represents the next set of chemicals for which EPA 

intends to issue test orders/data call-ins in the near future. For further information 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, please visit our website.18

5. Risk Characterization

For this preliminary assessment of fosetyl-Al, the deterministic RQ method was used to provide 

a metric of potential risks. The RQ is a comparison of exposure estimates to toxicity endpoints

(i.e., RQ = EEC/toxicity endpoint). The resulting RQs are compared to the Agency’s risk levels 

of concern (LOC), which are the Agency’s interpretive policy such that when acute or chronic 

risk LOCs are exceeded, the need for regulatory action may be considered. These criteria are 

used to indicate when the use of a pesticide, as directed on the label, has the potential to cause 

adverse effects to non-target organisms. For acute and chronic risks to animals, the LOCs are 0.5 

and 1.0, respectively, and for plants, the LOC is 1.0. For each taxa, RQs are generated and risks 

are discussed. This discussion includes consideration of additional data and lines of evidence.

5.1.Terrestrial Organisms

5.2.1. Birds, Amphibians and Reptiles

RQs were calculated (using T-REX) to represent risks to birds following consumption of dietary 

items directly sprayed with fosetyl-Al. As noted previously, birds are considered surrogates for 

terrestrial-phase amphibians and reptiles. Therefore, conclusions related to risks to birds also 

applied to risks to terrestrial-phase amphibians and reptiles.

Although fosetyl-Al is practically non-toxic to birds on an acute oral exposure basis (LD50=4976

mg/kg bw), and the chronic toxicity endpoint (NOAEC = 1414 mg/kg-diet) suggests low 

toxicity, risk is identified for uses due to potential high exposures from high application rates. 

Figures 9-11 include acute, dose-based RQs for small-, medium- and large-sized birds. Exposure 

estimates represent multiple applications of fosetyl-Al (see Table 9). As indicated in these 

figures, most uses of fosetyl-Al pose an acute risk to non-listed birds, with the exception of uses 

on asparagus, bananas and stone fruits. The Section 3 hops use of fosetyl-Al does not pose an 

acute risk; however, the Section 24 c use, which involves a higher rate, does pose an acute risk. It 

should be noted that in Figures 9 and 10, RQs for uses on ornamentals, conifer nurseries and 

turf exceed the upper bound of the y-axis (i.e., 2). 

 17 See http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0477-0074 for the final second list of 

chemicals. 18 http://www.epa.gov/endo/
Page 39 of 78

Figure 12 includes chronic RQs. For fosetyl-Al use on asparagus, bananas, hops (Section 3 only)

and stone fruits, chronic effects are not expected. For all other uses, RQs exceed the chronic risk 

LOC, indicating that fosetyl-Al may impact the reproduction of birds, terrestrial-phase 

amphibian and reptiles. There is uncertainty associated with these risk conclusions that can be 

attributed to the toxicity endpoint used to derive chronic RQs. First, data are only available for 

one species, i.e., Japanese quail; however, two species are required according to 40 CFR Part 

158. Typically, these species are represented by the mallard duck and the bobwhite quail. 

Second, no effects were observed at the highest test level, resulting in no LOAEC value and a 

lack of confidence in how well the NOAEC endpoint truely represented a threshold for where 

effects would not occur.

There is some uncertainty associated with the magnitude of exposure resulting from applications 

to ornamentals, conifer nurseries and turf (labels do not define the maximum number of 

applications so the maximum number of applications were calculated based on label-defined 

intervals); however, a single application at the maximum labeled rate to these uses is sufficient to 

pose both acute and chronic risk to birds. Single applications of less than or equal to 6 lbs a.i./A 

do not pose either an acute or chronic risk to birds above concern levels.

Figure 9. Acute Dose-based RQs for Small-sized Birds (20 g) Exposed to Fosetyl-Al 

Through Consumption of Plants and Arthropods Located on Treated Fields 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was 

assumed)

LOC 

(0.5)

acute, dose-based RQs for small birds
Page 40 of 78

Figure 10. Acute Dose-based RQs for Medium-sized Birds (100 g) Exposed to Fosetyl-Al 

Through Consumption of Plants and Arthropods Located on Treated fields. 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(0.5)

Acute, dose-based RQs for medium birds
Page 41 of 78

Figure 11. Acute dose-based RQs for large-sized birds (1000 g) exposed to fosetyl-Al 

through consumption of plants and arthropods located on treated fields. 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(0.5)

acute, dose-based RQs for large birds
Page 42 of 78

Figure 12. Chronic Dietary-based RQs for All Sizes of Birds Exposed to fosetyl-Al Through 

Consumption of Plants and Arthropods Located on Treated Fields 

5.2.2. Mammals

RQs were calculated (using T-REX) to represent acute and chronic risks to mammals following 

consumption of dietary items directly sprayed with fosetyl-Al. Figures 13-15 include acute, 

dose-based RQs for small-, medium- and large-sized mammals. Exposure estimates represent

multiple applications of fosetyl-Al (see Table 9). 

Fosetyl-Al uses pose an acute risk to non-listed mammals above concern levels, with the 

exception of uses on almonds, asparagus, bananas, citrus, cranberry, kiwis, peaches, plums, 

prunes, stone fruits and walnuts. The Section 3 hops use of fosetyl-Al does not pose an acute

risk; however, the Section 24c use on hops, which involves a higher rate, does pose a risk above 

concern levels. It should be noted that in Figures 13-15, RQs for uses on ornamentals, conifer 

nurseries and turf exceed the upper bound of the y-axis (i.e., 2). Figures 16-18 includes chronic 

RQs for mammals and indicate that all uses of fosetyl-Al result in at least one RQ value that 

exceeds the chronic risk LOC of 1.0. Single applications <2.9 lb a.i./A would result in RQ values 

below the acute and chronic risk LOCs for mammals, thereby resulting in no risk concerns for 

non-listed species. 

Although fosetyl-Al is practically non-toxic to mammals on an acute oral exposure basis 

0

1

2

3

4

5

6

7

8

9

10

Short Grass Tall Grass Broadleaf plants Fruits/pods/seeds Arthropods

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(1.0)

Chronic, dietary-based RQs for birds
Page 43 of 78

(LD50=3712 mg/kg bw), and the chronic toxicity endpoint (NOAEC = 6000 mg/kg-diet) 

suggests low toxicity, risk exceeds concern levels for uses due to potential high exposures from 

high application rates. It should be noted that exposure estimates are conservative, representing 

high end exposures on food residues. For many uses, acute exposures are only of concern for 

mammals consuming short grass. For animals that consume other dietary items, most uses of 

fosetyl-Al do not pose an acute risk. For chronic exposures, many EECs exceed the NOAEC for 

mammals consuming various food items, resulting in RQs that exceed the LOC. EECs also 

exceed the LOAEC, where growth effects were observed in offspring.

Figure 13. Acute Dose-based RQs for Small-sized Mammals (15 g) Exposed to Fosetyl-Al 

Through Consumption of Plants and Arthropods Located on Treated Fields 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(0.5)

Acute, dose-based RQs for small mammals
Page 44 of 78

Figure 14. Acute Dose-based RQs for Medium-sized Mammals (35 g) Exposed to Fosetyl-Al 

Through Consumption of Plants and Arthropods Located on Treated Fields 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(0.5)

Acute, dose-based RQs for medium mammals
Page 45 of 78

Figure 15. Acute Dose-based RQs for Large-sized Mammals (1000 g) Exposed to Fosetyl-Al 

Through Consumption of Plants and Arthropods Located on Treated Fields 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(0.5)

acute, dose-based RQs for large mammals
Page 46 of 78

Figure 16. Chronic Dose-based RQs for Small-sized Mammals (15 g) Exposed to Fosetyl-Al 

Through Consumption of Plants and Arthropods Located on Treated Fields 

0

1

2

3

4

5

6

7

8

9

10

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(1.0)

Chronic, dose-based RQs for medium mammals
Page 47 of 78

Figure 17. Chronic Dose-based RQs for Medium-sized Mammals (35 g) Exposed to FosetylAl Through Consumption of Plants and Arthropods Located on Treated Fields 

0

1

2

3

4

5

6

7

8

9

10

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(1.0)

Chronic, dose-based RQs for medium mammals
Page 48 of 78

Figure 18. Chronic Dose-based RQs for Large-sized Mammals (1000 g) Exposed to FosetylAl Through Consumption of Plants and Arthropods Located on Treated Fields 

0

1

2

3

4

5

6

7

8

9

10

Short Grass Tall Grass Broadleaf plants Fruits/pods Arthropods Seeds

Fosetyl-Al uses

(* indicates that number of applications was assumed)

LOC 

(1.0)

Chronic, dose-based RQs for large mammals
Page 49 of 78

5.2.3. Terrestrial invertebrates

Exposure values for terrestrial invertebrates are expressed as application rates (i.e., lb a.i./A). 

Therefore, for assessing risks to invertebrates on treated fields, maximum single application rates 

will be used (Table 3). Since all spray application rates exceed the measurement endpoint for 

non-Apis terrestrial invertebrates (i.e., 1.8 lb a.i./A), there is a potential risk to non-Apis

terrestrial invertebrates. AgDRIFT model estimates of how far risks from spray drift exposure 

extend from the edge of the field are provided in Table 12. These estimates were made using 

very fine to fine droplet spectrum since labels do not specify a specific nozzle that would result 

in a less conservative droplet spectrum.

Table 12. Distances from edge of field where risks extend for terrestrial invertebrates. 

Use Application 

rate (lb a.i./A)

Application 

method

Distance from the edge 

of the treated field to 

where the concetration 

is expected to be equal 

to concentration of 

concern (i.e., 

endpoint)(feet)

almond, brassica, citrus, berry, cucurbit, 

ginsing, grape, stonefruit, leafy vegetable, 

tomato, walnut

4 aerial 7

almond, brassica, citrus, berry, cucurbit, 

ginsing, grape, stonefruit, leafy vegetable, 

tomato, walnut

4 ground 7

banana 4.8 aerial 23

banana 4.8 ground 7

hops 2 aerial 0

hops 2 ground 3

ornamental and/or conifer nursery 16 ground 26

ornamental and/or conifer nursery 16 aerial 266

ornamental (bacterial blight suppression and 

bedding plants) 

12.9 ground 20

ornamental (downy mildew control in roses, 

fire blight suppression)

9.6 ground 16

pineapple 12 aerial 180

pineapple 12 ground 20

turf 17.6 ground 26

macadamia nut 6 aerial 52

macadamia nut 6 ground 10

onion (dry) 2.4 aerial 0

onion (dry) 2.4 ground 3

tobacco 3.2 aerial 0

tobacco 3.2 ground 7

This analysis indicates that most applications of fosetyl-Al may decrease the reproduction of 

sensitive species of non-Apis terrestrial invertebrates. Effects to predatory mites and sweet-potato 

whiteflies, which serve as surrogates for non-Apis terrestrial invertebrates in this risk assessment 
Page 50 of 78

were observed at ≤4 lb a.i./A, which represents the single maximum application rate for the 

majority of fosetyl-Al uses. Potential risks apply to non-Apis insects located on fields where 

fosetyl-Al is sprayed as well as to areas receiving spray drift. Risks to sensitive non-Apis

terrestrial invertebrates are estimated to extend as far out as 266 feet from the edge of the field 

for aerial applications (to ornamentals or conifer nurseries) and 26 feet for ground applications

(to ornamentals, conifer nurseries or turf).

Less sensitive species, such as honey bees, are only expected to be impacted at higher 

application rates (Table 10). For honey bees, the acute oral 96-h LD50 for technical fosetyl-Al 

was 455 μg a.i./bee. Using the exposure methodology for foliar sprays as presented in the 

pollinator white paper19, where an application rate of 1 lb a.i./A generates a dietary dose of 32 μg 

a.i./bee, the greatest LD50 value of 455 μg a.i./bee is equivalent to 14 lb a.i./A. Since the LOC for 

acute exposures to bees is 0.4, application rates ≥5.6 would pose a potential risk to honey bees. 

5.2.4. Plants

As noted in the problem formulation, the measurement endpoint (EC25) for non-listed plants is 

7.6 lb a.i./A, based on potential effects to vegetative vigor. The most comparable exposure route 

for this type of endpoint is through spray drift. Since the LOC for plants is 1.0, any application 

rate below 7.6 would not be expected to generate spray drift exposures that would pose a risk to 

plants. The distances from the edge of the field where risks from spray drift extend were 

calculated for all single applications ≥7.6 lb a.i./A using the AgDRIFT model. This analysis was 

conducted for all ground and aerial spray applications (ground drench and tree trunk applications 

were excluded). AgDRIFT model estimates of how far risks from spray drift exposure extend

from the edge of the field are provided in Table 13. These estimates were made using very fine 

to fine droplet spectrum since labels do not specify a specific nozzle that would result in a less 

conservative droplet spectrum.

Table 13. Distances where risks extend for plants. 

Use Application rate 

(lb a.i./A)

Application 

method

Distance (in feet) from edge of field to:

7.6 lb a.i./A* 3.0 lb a.i./A**

Ornamentals and/or Conifer 

Nurseries 16 Ground 7 20

Ornamentals and/or Conifer 

Nurseries 16 Aerial 3 130

Ornamentals (Bacterial Blight 

Suppression and bedding plants) 

12.9 Ground 3 14

Ornamentals (downy mildew 

control in roses, fire blight 

suppression)

9.6 Ground 3 7

Pineapple 12 Aerial 0 80

Pineapple 12 Ground 3 12

Turf 17.6 Ground 7 23

*Equivalent to EC25 for dicots

**Application rate of incident report for possible effects of fosetyl-Al on spinach.

 19 USEPA, PMRA, and CADPR (2012) White paper in support of the proposed risk assessment process for bees. 

United States Environmental Protection Agency, Office of Pesticide Programs, Washington DC. Pest Management 

Regulatory Agency, Health Canada, Ottawa. California Department of Pesticide Regulation, Sacramento, CA.
Page 51 of 78

These results indicate that ≥25% degrease in growth of non-target dicotyledenous plants may 

occur following uses on ornamentals, conifer nurseries, pineapple and turf; however, those 

effects are only expected to extend up to 7 feet from the edge of the field. The potential risks are 

considered negligible because the spatial extent of the effect area is small since it only applies to 

the downwind side of the field. 

There is some uncertainty associated with the toxicity endpoint of 7.6 lb a.i./A because available 

data indicate that effects to plants may occur at application rates <7.6 lb a.i./A. As noted in 

section 4.1.1, an incident report is available where an application of 3.0 lb a.i./A fosetyl-Al 

possibly resulted in leaf burn to spinach. In addition, a 49% decrease in the sugar content of 

melons was noted in canalope. The distance from the edge of the field to the level where leaf 

burn was reported in the incident (i.e., to a deposition of 3.0 lb a.i./A fosetyl-Al) could 

potentially potentially extend as far as 23 feet for ground applications and 130 feet for aerial 

applications (Table 13). 

5.2.Aquatic Organisms

RQs were generated using the most conservative EEC derived from AgDRIFT (i.e., 92 μg a.i./L) 

and the most conservative acute and chronic endpoints for animals and plants (Table 14). No 

acute RQs for animals exceed the LOC for non-listed species (i.e., 0.5). In addition, the aquatic 

plant and chronic invertebrate RQs do not exceed the LOC of 1.0. 

Table 14. RQs for acute and chronic exposures to aquatic organisms. 

Exposure 

duration Taxa EEC (μg a.i./L) Endpoint (μg a.i./L) RQ

acute

fish

92

83400 0.0011

invertebrates 1850 0.049

plants 780 0.12

chronic invertebrates 179 0.51

When considering the probability of individual mortality to fish and invertebrates, the Individual 

Effect Chance (IEC) model (v.1.1) can be used along with the acute RQ values and slopes 

associated with the endpoints. It should be noted that these estimates of probability are assumed 

to be conservative due to the conservative nature of the EECs used to derive the RQs. For fish, 

based on a slope of 19 and an RQ of 0.0011, the chance of individual mortality is 1 in 1016. For 

invertebrates, based on a slope of 4.5 (default) and an RQ of 0.050, the chance of individual 

mortality is 1 in 4.2 x 108. Given that the chance of mortality is less than one in a million, the 

likelihood that any of the fosetyl-Al uses will cause mortality to individual aquatic animals as a 

result of spray drift is considered low. 

Although an RQ was not calculated for determining chronic risk to fish (due to a lack of toxicity 

data), effects to growth and reproduction are not expected because: 1) the exposure estimate for 

spray drift is expected to be conservative (since it represents a conservative modeling scenario 

due to lack of consideration of degredation and the highest application rate allowed for fosetylAl) and 2) the chronic toxicity of fosetyl-Al would have to be a factor of >907 lower than the 

acute toxicity. It is considered unlikely that fosetyl-Al would be orders of magnitude more toxic 
Page 52 of 78

to fish on a chronic exposure basis than the acute toxicity value because this pattern has not been 

observed in other taxa (i.e., birds, mammals and aquatic invertebrates). In addition, an ACR of 

>907 is unlikely given the available toxicity data in the EFED toxicity database (for aquatic 

organisms), where the median and 90th percentile ACRs were 8.3 and 79.5, respectively 

(Raimondo et al. 200720). Therefore, the likelihood that spray drift from use of fosetyl-Al will 

result effects on survival, growth and reproduction of non-listed aquatic organisms via long-term 

exposure is considered low.

Although RQs for plants were based on EC50 values, NOAECs can be used to characterize low 

thresholds of effect. The lowest available NOAEC for aquatic plants is 320 μg a.i./L (MRID 

41128605) for the marine diatom. The high-end estimate of exposure, i.e., 92 μg a.i./L, is a 

factor of 3.5 lower than the NOAEC. This indicates that adverse effects to plants are unlikely.

5.3.Listed Species

This analysis indicates that direct effects to fish, aquatic invertebrates, aquatic plants and 

monocot plants (in terrestrial and wetland habitats) are unlikely. Also, fosetyl-Al poses both 

acute and chronic risk to birds, terrestrial-phase amphibians, reptiles, mammals, terrestrial 

insects and sensitive species of dicot plants (in terrestrial and wetland habitats). 

Indirect effects may occur to listed animals and plants that rely upon birds, terrestrial-phase 

amphibians, reptiles, mammals, and terrestrial insects for food or shelter. Also, indirect effects 

may occur to listed species that have obligate relationships with dicot plant species in terrestrial 

or wetland habitats. 

No Effect determinations can be made for listed species of fish, aquatic-phase amphibians (that 

do not have terrestrial-phases), aquatic invertebrates, aquatic plants and monocot plants (in 

terrestrial and wetland habitats) that do not rely upon birds, terrestrial-phase amphibians, reptiles, 

mammals and terrestrial insects (for food or shelter), and do not have obligate relationships with 

dicot plants (in terrestrial and wetland habitats). For all other species, the effect determinations 

are uncertain.

5.4.Risk Conclusions

Currently labeled rates of fosestyl-Al pose a potential risk to non-target terrestrial animals, 

including insects, birds, reptiles, terrestrial-phase amphibians and mammals as well as 

sensitive species of terrestrial dicot plants. The risk conclusions are summarized as follows:

• For terrestrial invertebrates, most applications of fosetyl-Al may decrease the 

reproduction of sensitive species. Less sensitive species, such as honey bees, are only 

expected to be impacted at higher application rates (i.e., ≥5.6 lb a.i./A). Potential risks 

apply to insects located on fields where fosetyl-Al is sprayed and to areas subject to spray 

drift. Risks to sensitive terrestrial invertebrates are estimated to extend as far out as 266 

 20 Raimondo, S., B.J. Montague and M.G. Barron. 2007. Determinants of variability in acute to chronic ratios for 

aquatic invertebrates and fish. Environ. Toxicol. Chem. 26:2019-2023.
Page 53 of 78

feet from the edge of the field for aerial applications and 26 feet for ground applications.

• For birds (and terrestrial-phase amphibians and reptiles, for which birds are considered 

surrogates), fosetyl-Al poses a potential acute and chronic risk for most uses, except 

those on asparagus, bananas, hops (Section 3 use) and stone fruits. 

• For mammals, fosetyl-Al exposures pose an acute risk for most uses, with the exception 

of almonds, asparagus, bananas, citrus, cranberry, kiwis, peaches, plums, prunes, stone 

fruits and walnuts. All uses of fosetyl-Al pose a potential chronic risk to mammals.

• Although fosetyl-Al is practically non-toxic to birds and mammals on an acute oral 

exposure basis, and the chronic toxicity endpoints suggest low toxicity, risk is identified 

for many uses due to potential high exposures from high application rates. 

• Effect determinations for listed species of birds, terrestrial-phase amphibians, reptiles, 

mammals and terrestrial insects are uncertain.

• Although applications of 7.6 lb a.i./A and greater may result in a >25% effect to growth 

of dicots, risks are expected to be negligible to non-listed dicot species since risk is only 

estimated to extend only 7 feet from the edge of the field. Risks are not expected to 

monocots.

• Effect determinations for listed species of dicots (in terrestrial and wetland habitats) are 

uncertain. Risks to these species may extend beyond 7 feet from the edge of the field.

• Direct adverse effects are not expected for aquatic animals and plants exposed to fosetylAl following spray drift and runoff. 

• No Effect determinations can be made for listed species of fish, aquatic-phase 

amphibians (that do not have terrestrial-phases), aquatic invertebrates, aquatic plants and 

terrestrial monocots (in terrestrial and wetland habitats) that 

o do not rely upon birds, terrestrial-phase amphibians, reptiles, mammals and 

terrestrial insects (for food or shelter), and 

o do not have obligate relationships with dicot plants (in terrestrial and wetland 

habitats). 

In regards to the risk conclusions, the following risk hypotheses related to aquatic organisms are 

rejected:

• Exposure to fosetyl-Al residues in water due to spray drift resulting from labeled uses of 

fosetyl-Al will cause reduced survival, growth and reproduction to aquatic invertebrates and 

fish in surface waters adjacent to a treated field.

• Exposure to fosetyl-Al residues in water due to spray drift from labeled uses of fosetyl-Al 

will cause reduced survival and biomass to aquatic vascular and non-vascular plants in 

surface waters adjacent to a treated field.

The following risk hypotheses related to terrestrial organisms are not rejected:

• Exposure to fosetyl-Al residues on seeds, insects, and foliage due to direct deposition or 

spray drift from labeled use of the pesticide will cause reduced survival, growth and 

reproduction to terrestrial vertebrates (birds, mammals, reptiles, terrestrial-phase amphibians) 

and terrestrial invertebrates.

• Exposure to fosetyl-Al residues on foliage due to spray drift resulting from labeled use of the 

pesticide will result in reduced survival and biomass to upland plants and riparian/wetland 

plants in areas adjacent to a treated field. 
Page 54 of 78

Appendix A. Additional information related to effects data for fosetyl-Al

A.1. Terrestrial Organisms

A.1.1. Birds

Table 1 Affect of Fosetyl-Al on Birds

Chemical/Guideline No. / 

Study Type / Test Material Toxicological Effects(a) Source / Study Classification and Exposure Groups

Fosetyl-Al/71-1 Avian Single 

Dose Oral Toxicity –

Japanese Quail (C. japonica), 

young adult (mean body 

weight for concentrations 

ranged from 168 to 200 

grams), intubation /

Technical Fosetyl-Al (LS 741-

783)

Purity not given

LD50 = 4976 mg/kg-bw

(95% CI 465-6386)

NOAEL <4117 mg/kg-bw

(Some evidence of depressed food 

consumption, but no evidence to suggest 

body weight was affected)

Slope = 4.43 (0.259-8.61)

Classified as practically nontoxic 

MRID 00098361 Ross, et. al., 1977 

(Unpublished) / Supplemental

0 (0.5% sodium 

carboxymethylcellulose), 4117, 

4852, 6288, 7056, 8929 mg/kg-bw, 6 

birds (3 males, 3 females) per group

Fosetyl-Al/71-1 Avian Single 

Dose Oral Toxicity –

Bobwhite Quail (Colinus

virginianus), young adult 

(mean body weight for 

concentrations ranged from 

177 to 197 grams), intubation /

Technical Fosetyl-Al (LS 741-

783)

95% fosetyl-Al

LD50 >8000 mg/kg-bw

(7600 mg ai/kg-bw)

NOAEL = 5000 mg/kg-bw

(Three mortalities in the highest treatment 

group. 30% affected, binomial 95% CI for 

mortality at this concentration is 6.7 to 65%. 

Food consumption and body weight changes 

within acceptable limits. One control bird 

had small cyst in body cavity at termination.)

Classified as practically nontoxic 

MRID 00098360 Roberts, et. al., 

1981 (Unpublished) / Acceptable

0 (corn oil), 500, 1000, 3000, 5000, 

8000 mg/kg-bw (475, 950, 2850, 

4750, 7600 mg ai/kg-bw), 10 birds (5

males, 5 females) per group

Fosetyl-Al/850.2100 Avian 

Single Dose Oral Toxicity –

Bobwhite Quail (Colinus 

virginianus), 11-month old 

(body weight ranged from 173 

to 207 grams), intubation /

Formulation EXP10369F 

(79.4% Fosetyl-Al )

LD50 >5082 mg a.i/kg-bw 

NOAEL < 1270 mg ai/kg-bw

(One mortality in 2541 and 5082 mg a.i./kgbw. 10% affected, binomial 95% CI at these 

concentrations is 0.2 to 44.5%). No other 

mortality, clinical signs of toxicity, or postmortem findings were observed in any bird 

during the study. In addition, no treatmentrelated effect on male body weight or male or 

female food consumption was observed. 

However, statistically-significant reductions 

in female body weights were observed at all 

dose levels on Day 7, albeit not doseresponsive. In addition, although not 

statistically significant, a 22-27% reduction 

in weight gain compared to the control was 

observed in the females from Day 0 to 14)

Classified as practically nontoxic 

MRID 47408712 Gillham, 1999 

(Unpublished) / Acceptable

0 (water), 1270, 2541, 5082 mg 

ai/kg-bw, 10 birds (5 males, 5 

females) per group
Page 55 of 78

Table 1 Affect of Fosetyl-Al on Birds

Chemical/Guideline No. / 

Study Type / Test Material Toxicological Effects(a) Source / Study Classification and Exposure Groups

Fosetyl-Al/71-2 Avian Dietary 

Toxicity –

Northern Bobwhite (Colinus 

virginianus), 10-day old 

chicks /

Technical Fosetyl-Al

97.5% fosetyl-Al

8-d LC50

(b) > 18,330 mg ai/kg-diet

NOAEC = 13,748 mg ai/kg-diet

(one mortality in control and highest test 

concentration (nominal 20,000 ppm), no 

effects on food consumption or body weight 

observed)

Classified as practically nontoxic

MRID 00098362 Roberts et al., 1982 

(Unpublished) / Acceptable

0, 2353, 3361, 4802, 6860, 9800, 

14,000 and 20,000 mg/kg-diet [0, 

2506, 3773, 5002, 6718, 10,238, 

13,748 and 18,330 mg ai/kg-diet 

measured]; 10 birds per group; 

Fosetyl-Al/71-2 Avian Dietary 

Toxicity –

Mallard duck (Anas 

platyrhynchos), 12-day old 

chicks /

Technical Fosetyl-Al

97.5% fosetyl-Al

8-d LC50

(b) > 18,330 mg ai/kg-diet

NOAEC = 13,748 mg ai/kg-diet

(no mortalities in control or any test 

concentrations, no effects on food 

consumption or body weight observed)

Classified as practically nontoxic

MRID 00098363 Roberts et al., 1981

(Unpublished) / Acceptable

0, 2353, 3361, 4802, 6860, 9800, 

14,000 and 20,000 mg/kg-diet [0, 

2506, 3773, 5002, 6718, 10,238, 

13,748 and 18,330 mg ai/kg-diet 

measured]; 10 birds per group; 

FOSETYL-AL/850.2300 

Avian Reproduction Toxicity 

– Japanese quail (Coturnix 

coturnix japonica), 10-wk old 

/ (body wt 131-243 g)/

Technical Fosetyl-Al

99.6% fosetyl-Al

NOAEC(c) at least 1414 mg ai/kg-diet, 

highest concentration tested

(No treatment-related effects were observed 

on any adult or offspring parameter at any 

treatment level)

(6 week exposure)

MRID 47408710 Gallagher, et.al., 

1999 (Unpublished) / Supplemental

0, 166, 459, 1414 mg ai/kg-diet; 

(a) Effect levels are expressed in terms of the chemical.: mg/kg-bw is milligrams of the test material per kilogram of 

body weight; mg ai/kg-bw is milligrams of fosetyl-Al per kilogram of body weight; mg ai/kg-diet is milligrams of 

fosetyl-Al per kilogram of diet..

(b) 5-day exposure and 3-day post-exposure

A.1.2. Mammals
Page 56 of 78

Table 2 Affect of Fosetyl-Al on Mammals

Chemical/Guideline No. / 

Study Type / Test Material Toxicological Effects

Source / Study 

Classification and Exposure 

Groups

FOSETYL-AL/ 81-1 Acute 

Oral – Rat 

(Charles River), body weight 

120-160 g/

Technical Fosetyl-Al

98.4% fosetyl-Al

LD50 = 5,793 mg fosetyl-Al/kg-bw

(95% CI 4827-6758)

LD50 = 5,400 mg acid/kg-bw

weight loss statistically significant at Day 5 for 

2,800 mg/kg-bw group (no mortality), but not 

by Day 15

MRID 00247160 (Unpublished) 

Pasquet, et al. 1977/ (5 females, 5 

males /treatment; 0 (10% aqueous 

soln w/10% gum arabic), 2800, 

4200, 6300, 9400 mg acid/kg-bw)

FOSETYL-AL/ 81-1 Acute 

Oral – Rabbit 

(Fauve de Bourgogne), body 

weight 1.9-2.9 kg/

Technical Fosetyl-Al

98.4% fosetyl-Al

LD50 = 2,682 mg fosetyl-Al/kg-bw

(95% CI not calculable)

LD50 = 2,500 mg acid/kg-bw

No statistically significant weight loss for 

2,000 mg/kg-bw group (highest concentration 

w/no mortality); 4/4 dead at 3000 mg/kg-bw, 

0/4 dead at 2000 mg/kg-bw

MRID 00247160 (Unpublished) 

Pasquet, et al. 1977/ (2 females, 2 

males /treatment; 0 (10% aqueous 

soln w/10% gum arabic), 1350, 

2000, 3000, 4500, 6700 mg acid/kgbw)

FOSETYL-AL/ 81-1 Acute 

Oral – Mouse 

(Specific Pathogen Free), 

body weight 19-22 g/

Technical Fosetyl-Al

98.4% fosetyl-Al

LD50 = 3,712 mg fosetyl-Al/kg-bw

(95% CI 3132-4409)

LD50 = 3,460 mg acid/kg-bw

weight loss statistically significant at Day 10 

for 1350 mg/kg-bw group (highest 

concentration w/no mortality), but not by Day 

15

MRID 00247160 (Unpublished) 

Pasquet, et al. 1977/ (5 females, 5 

males /treatment; 0 (10% aqueous 

soln w/10% gum arabic), 1350, 

2000, 3000, 4500, 6700 mg acid/kgbw)

FOSETYL-AL/ 81-1 Acute 

Oral – Guinea pig 

(Dunkin/Hartley), body 

weight 230-285 g/

Technical Fosetyl-Al

98.4% fosetyl-Al

LD50 =2,789 mg fosetyl-Al/kg-bw

(95% CI not calculable)

LD50 =2600 mg acid/kg-bw

No statistically significant weight loss for 

2,000 mg/kg-bw group (highest concentration 

w/no mortality)

MRID 00247160 (Unpublished) 

Pasquet, et al. 1977/ (5 females, 5 

males /treatment; 0 (10% aqueous 

soln w/10% gum 56rabic), 1350, 

2000, 3000, 4500 mg acid/kg-bw)

FOSETYL-AL/ 81-1 Acute 

Oral – Rat

(Sprague-Dawley), body 

weight 186-310 g/

Formulation Aliette WDG

80% fosetyl-Al

LD50 =2860 mg/kg-bw

(95% CI 2410-3380)

MRID 41641802 (Unpublished) 

Kuhn. 1990/ (5 females, 5 males 

/treatment; 0, 500, 2000, 2500, 

3000, 4000, 5050 mg/kg-bw)

FOSETYL-AL/ 81-1 Acute 

Oral – Rat 

Formulation Aliette WP

80% fosetyl-Al

LD50 > 5,000 mg/kg-bw

(One female died at limit concentration of 

5000 mg/kg-bw. Observations of 

hypomotility, females coats appeared dirty, 

muscular hypotonia in females, congestion in 

lungs, and grayish deposit adhering to mucosa 

of glandular zone of stomach)

MRID 00247186 (Unpublished) 

Pasquet, et al. 1981/ (10 females, 10

males /treatment; 0, 5000 mg/kg-bw)
Page 57 of 78

Table 2 Affect of Fosetyl-Al on Mammals

Chemical/Guideline No. / 

Study Type / Test Material Toxicological Effects

Source / Study 

Classification and Exposure 

Groups

FOSETYL-AL/81-2 Acute 

Dermal toxicity – Rabbit

Technical Fosetyl-Al

97% fosetyl-Al

LD50 > 2000 mg/kg MRID 00247160 (Unpublished) 

Pasquet, et al. 1977

FOSETYL-AL/81-5 Primary 

Skin Irritation – Rabbit

Technical Fosetyl-Al

97% Fosetyl-Al

Non-irritant MRID 00247160 (Unpublished) 

Pasquet, et al. 1977

FOSETYL-AL/81-4 Primary 

Eye Irritation – Rabbit

Technical Fosetyl-Al

97% Fosetyl-Al

Occular Irritant

Category I

MRID 00247160 (Unpublished) 

Pasquet, et al. 1977

FOSETYL-AL/81-3 Acute 

Inhalation Toxicity – Rat

Technical Fosetyl-Al

98% fosetyl-Al

LD50 > 1.73 mg/L MRID 00247160 (Unpublished) 

Pasquet, et al. 1977

FOSETYL-AL/83-4 

Reproduction 3 – generation 

– rat

Technical Fosetyl-Al

NOAEL = 300 mg/kg/day (6000 ppm)

LOAEL = 600 mg/kg/day (12000 ppm)

Decreased litter and pup weight (Day 8) in 

both matings of each generation (F1&F2)

MRID 00247174 (Unpublished) 

Spicer, et. al., 1981/ 0, 6000, 12000, 

24000 ppm

FOSETYL-AL/82-1

90-day Feeding –Rat

Technical Fosetyl-Al

98% fosetyl-Al

NOAEL = 5,000 ppm-diet

LOAEL = 25,000 ppm-diet

Slight increase in extramedullary 

hematopoiesis in the spleen when compared to 

control animals. 

MRID 00098336 (Unpublished)

Coquet, et. al., 1977/ Supplemental/ 

1,000, 5,000, and 25, 000 ppm-diet

A.1.3. Invertebrates

A.1.3.1. Insects (class Insecta)

Beetles (order coleoptera)

Toxicity data are available for six species of beetles exposed to fosetyl-Al. In registrantsubmitted and open literature studies, mortality was not increased in exposed ladybird beetles 

(Coccinella septempuncatata) (MRID 48803215); mealybug ladybird (Cryptolaemus 

montrouzieri) (Mani and Krishnamoorthy (1990)); carabid beetles (Poecilus cupreus) (MRIDs 

48803201 and 48803206), and rove beetles (Aleochara bilineata). Exposures via contact to 

sprayed surfaces were at or above single maximum application rates of fosetyl-Al (based on 

current labels). Development time was not impacted in two ladybeetle species (Cycloneda 

sanguinea and Harmonia axyridis; Michaud 2001). Reproduction was not impacted in the 

ladybird beetle (MRIDs 48803205 and 48803215); however, it was reduced by 15-17% when 

exposed to surfaces treated with 13-39 lb a.i./A (MRIDs 48803211 and 48803216). 
Page 58 of 78

Bees and wasps (order hymenoptera)

No adverse effects (including mortality and parasitism) were observed in three species of wasps, 

including Aphidius rhopalosiphi (MRIDs 48803202 and 48803207), Aphidius matricariae 

(MRID 48803210) and Anagyrus dactylopii (Mani and Krishnamoorthy 1990). 

Two contact toxicity honey bee (Apis mellifera) studies involving technical grade fosetyl-Al 

yielded 48-h LD50 values of >100 μg/bee (MRID 40676301) and >986 μg a.i./bee (MRID 

47418003). In a contact study involving a 79.4% fosetyl-Al formulation, the LD50 value was 

>310 μg a.i./bee (MRID 47418002). Using the exposure methodology presented in the pollinator 

white paper21, where an application rate of 1 lb a.i./A generates a contact dose of 2.7 μg a.i./bee, 

the greatest LD50 value (i.e., >986 μg a.i./bee) is equivalent to >365 lb a.i./A. Oral toxicity 

studies involving technical and formulated (79.4% a.i.) fosetyl-Al yielded 48-h LD50 values of 

709 and >349 μg a.i./bee, respectively (MRIDs 47418003 and 47418002). The 96-h LD50 for the 

technical formulation was 455 μg a.i./bee. Using the exposure methodology for foliar sprays as 

presented in the pollinator white paper, where an application rate of 1 lb a.i./A generates a 

dietary dose of 32 μg a.i./bee, the greatest LD50 value of 455 μg a.i./bee is equivalent to 14 lb 

a.i./A. In a semi-field (tunnel) study examining effects on honey bee colonies following soil 

drench applications of formulated products containing fosetyl-Al at 36 and 71 lb a.i./A, a 

decrease in brood (larval and capped stages) and survival of adults was observed in both 

treatment groups compared to the control (MRID 47408716). 

Bugs (order Hemiptera)

Several studies from the open literature examined the efficacy of fosetyl-Al to the sweetpotato 

whitefly (Bemisia tabaci) in which fosetyl-Al was applied to various crops. Many of the studies 

were conducted at a foliar application rate of 4.0 lb a.i./A Aliette® 80 WP, WG or an unidentified 

formulation to several crops in the field grown under typical culturing conditions (e.g., cotton, 

cabbage, tomato, and cantaloupe (2.8 and 4.0)) and no adverse effects on populations of the 

sweetpotato whitefly were observed (Chu 1994b; Riley 1994; Schuster 1993; and Palumbo 

1993). However, there were two studies in which fosetyl-Al, (Aliette® 80 WDG or WP), foliarly 

applied to either tomato at 4.0 lb a.i./A or cantaloupe at 3.2 lb a.i./A under typical field 

conditions, did result in significant decreases in the number of adults, nymphs and/or eggs when 

compared to the control (Chu 1994a; Stansly and Cawly 1994). A review of these studies did not 

reveal an obvious reason for the differences in results.

A.1.3.2. Arachnids (class arachnida)

Spiders (order araneae)

One species of spider (Pardosa amentata, wolf spider) was tested for effects of fosetyl-Al. 

Although 65% mortality was observed in spiders exposed via direct spray and contact, the 

 21 USEPA, PMRA, and CADPR (2012) White paper in support of the proposed risk assessment process for bees. 

United States Environmental Protection Agency, Office of Pesticide Programs, Washington DC. Pest Management 

Regulatory Agency, Health Canada, Ottawa. California Department of Pesticide Regulation, Sacramento, CA.
Page 59 of 78

exposure rate of 89 lb a.i./A was much higher than the single maximum application rates allowed 

on the label. 

Predatory mite (order mesostigmata)

In a study involving a soil-dwelling predatory mite (Stratiolaelaps scimitus), mortality was 

increased by 14.0%, but reproduction (number and viability of eggs) was not adversely affected. 

It should be noted that the application rate was much higher than allowed on labels (71.4 lb 

a.i./A), which makes these results difficult to interpret relative to actual use rates (Cabrera et al. 

2004).

Predatory mite (order acarina)

In available lab studies involving exposures of predatory mites (Typhlodromus pyri) to fosetylAl, mortality increased (67%) when exposed to 5.4 lb a.i./Aand greater (MRIDs 48803204 and 

48803212). Reproduction was also negatively impacted (22%) in groups of mites exposed to 1.8 

lb a.i./A and higher (MRIDs 48803204, 48803208, and 48803212). Impacts to predatory mites 

from fosetyl-Al applied at similar rates were also observed in a field study. After three 

applications made at 2.9 lb a.i./A, the number of mites on treated apple leaves were lower than 

control (by 25%); however, mite populations appeared to rebound after three weeks. A 25-40% 

decrease in mite numbers was observed in a field study following 2 and 3 applications of 5.1 lb 

a.i./A fosetyl-Al. Following three applications of 2.6 lb a.i./A, mite numbers were not different 

from the control (MRID 48803214). 

A.1.4. Plants

Toxicity data involving exposures of terrestrial plants to fosetyl-Al are available from registrant 

submitted studies, the scientific literature as well as reported incidents. These studies are 

described below.

Registrant-submitted studies

Registrant-submitted studies are available to characterize the toxicity of fosetyl-Al to terrestrial 

plants. These submissions include 1) a Tier I vegetative vigor study with 6 crop species exposed 

to Aliette® 80 WG; 2) a Tier I vegetative vigor study with tomato exposed to Aliette®8 0 WG; 3) 

a Tier I vegetative vigor study with 8 species exposed to a formulated product containing fosetylAl and another fungicide (propamocarb-HCl); and 4) a Tier I seedling emergence study with 8 

species exposed to a formulated product containing fosetyl-Al + propamocarb-HCl. These 

studies are described below.

Tier I studies are essentially limit tests that are designed to indicate whether the maximum 

application rate of a pesticide will cause >25% effects to plants, which would necessitate a Tier 

II study. Tier II studies are designed to establish EC25 values for plants. Tier I studies are not 

used to establish risk assessment endpoints (i.e., NOAEC and EC25 values), but are described in 

this assessment in order to characterize potential effects of fosetyl-Al on plants. 
Page 60 of 78

In a tier I study involving a formulated product applied at 66 lb a.i./A fosetyl-Al (Aliette®80 

WG), <25% effects were observed in shoot dry weights relative to controls for the following test 

species: cucumber (9% decrease),oat (0% decrease), onion (0% decrease) and soybean (0% 

decrease). A 37% inhibition in shoot chlorosis was observed in cucumber and oat (MRID 

47395701). This study was classified supplemental because shoot length was not measured.

Tier II tests were conducted for cabbage and tomato exposed to Aliette® 80 WG. For cabbage, 

the EC25 was not established; however, chlorosis was observed in plants exposed to 34 lb a.i./A. 

For tomato, the EC25 value was 7.6, lb a.i./A. At the NOAEC of 4.2 lb a.i./A, a 18% decrease in 

shoot dry weight was observed. At the LOAEC of 8.4 lb a.i./A, a 30% decrease in shoot dry 

weight was observed. Chlorosis was also observed in tomato plants exposed to 67 lb a.i./A 

(MRID 47395701). This study was classified supplemental because shoot length was not 

measured. 

In a tier I vegetative vigor study involving a formulated product containing fosetyl-Al (29.9%; 

0.75 lb a.i./A) and propamocarb-HCl (57.8%; 1.44 lb a.i./A), statistically significant effects were 

observed in dry weights of onion (17% difference), shattercane (25%), soybean (12%) and 

oilseed rape (19%) exposed to the formulation, relative to controls. No effects were observed in 

corn, oat, sunflower and cucumber (MRID 47370503). This study was classified supplemental 

for a Tier I vegetative vigor study because it was not conducted under Good Laboratory Practices 

(GLP) and no explanation was provided of how the test methods related to GLP. The results of 

this study indicate that fosetyl-Al could cause effects to plants at 0.75 lb a.i./A; however, there is 

substantial uncertainty associated with these results for several reasons. First, the study involved 

two active ingredients and it is unknown whether the toxicity can be attributed to fosetyl-Al 

alone or the mixture of the two ingredients. In a Tier I vegetative vigor study involving a 

formulated product containing propamocarb-HCl as the only active ingredient, 8.0 lb a.i./A 

resulted in <25% effects to 10 test species. This suggests that propamocarb-HCl alone is not 

causing effects to plants (at 0.75 lb a.i./A). The results for four species (i.e., cucumber, oat, onion 

and soybean) tested separately with formulated products containing fosetyl-Al, propamocarbHCl and a combination of fosetyl-Al and propamocarb-HCl do not suggest that fosetyl-Al alone 

is causing the effects (Table A1). All that being said, there are no formulated products registered 

in the U.S. at this time with fosetyl-Al and propamocarb-HCl. Therefore, the results are of little 

utility for this risk assessment.

Table A1. Decrease (%) in shoot dry weight of treatment relative to controls observed in 

Tier I studies.

Test 

species

Fosetyl-Al

(66 lb a.i./A)

(MRID 

47395701)

Propamocarb-HCl

(8 lb a.i./A) 

(MRID 45894311)

Fosetyl-Al

(0.75 lb a.i./A)

+Propamocarb

(1.44 lb a.i./A) 

(MRID 47371503)

cucumber 9 0 2

Oat 0 7.5 0

Onion 0 0 17

soybean 0 14 12

Scientific literature
Page 61 of 78

The scientific literature includes several studies where effects of fosetyl-Al on terrestrial plants 

were examined. These studies include exposures involving direct spray to crops, root dips and 

soil drench applications. This section focuses on studies involving foliar applications to plants, 

which are most representative of potential exposures of non-target plants to fosetyl-Al (through 

spray drift). In general, these studies were not intended to determine the impact of fosetyl-Al on 

plants but rather to examine the efficacy of various pesticides on crop pests; however, these data 

are still useful for the observations of potential effects of fosetyl-Al to plants.

In a field study examining the effects of various pesticides on sweet potato whitefly, Aliette® 80 

WP was applied to cabbage and to cantaloupe at a rate of 4.0 lb a.i./A fosetyl-Al. Relative to the 

controls, no effects to cabbage head weight or leaf damage were observed. No effects were 

observed in number or weight of harvested cantaloupes; however, the % sugars of the fruit were 

significantly decreased (by 49%) in the treated plants relative to controls (Riley 1994). 

Data are available from another field study involving applications of Aliette® 80 WP to 

cantaloupe. In this study, 6 applications were made at a rate of 3.2 lb a.i./A of fosetyl-Al. The 

number of marketable melons harvested per acre was not significantly different compared to the 

untreated plots (Chu et al. 1994a). 

In a field study involving cotton, 9 foliar applications of Aliette® 80 WP were made at a rate of 

4.0 lbs a.i./A of fosetyl-Al. The yield of cotton lint harvested per acre was not significantly 

different compared to the untreated plots (Chu et al. 1994b). 

In another field study, 13 applications of Aliette® were made to tomatoes at a rate of 4.0 lb a.i./A 

of fosetyl-Al. The number and size of tomatoes harvested per 10 plants was not significantly 

different compared to the untreated plots. No visible phytotoxicity was observed in treated plants 

(Schuster 1993). 

Reported incidents

Two incident reports exist in EFED’s EIIS database. Both incidents occurred from registered 

applications in spinach crops. The first incident occurred on 9/1/00 in San Benito County, CA 

and involved a registered use of fosetyl-Al (Aliette® WDG) at an application of 3 ounces/A22

applied as a pre-broadcast spray to spinach that resulted in plant damage to 10 of the 20 acres 

treated (Incident # I010772-031). The type of plant damage observed was not reported. The 

second incident was in Montgomery County, CA on 4/25/05 in which plant damage described as 

leaf burn occurred across all 5.5 acres of spinach sprayed with Aliette® 80WDG at a rate of 3 

lbs/A, assumed to be a.i. (Incident # I016232-005). The certainty categories regarding the 

likelihood that the use of fosetyl-Al caused the two incidents are both possible. Both of the 

incidents were considered registered uses at the time of the incident and are still registered uses. 

Neither of the incidents involved reported additional chemicals besides fosetyl-Al. In addition, 

 22 The 3 oz/A (0.19 lb/A, based on mass) application rate in the I010772-031 incident is substantially lower than the 

registered application rate for this use (4 lb a.i./A). Therefore, it is not known if this is due to a reporting error, or if 

this was the actual application rate; as such, there is uncertainty in this incident regarding application rate.
Page 62 of 78

registrants have reported one minor plant incident for fosetyl-Al. Unless additional information 

on this aggregated incident becomes available, it will be assumed to be representative of 

registered uses of fosetyl-Al in the risk assessment.

There is uncertainty in the incident data for terrestrial plants that are available. Both of the 

incidents were for direct application to spinach at an application rate lower than what was tested 

in the vegetative vigor toxicity study. For the incident I016232-005, the symptom was reported 

as leaf burn. For this incident, the registrant claimed that “speckling of leaves is warned of on 

the label and the crop is growing through the speckling”. However, the overall magnitude of the 

impaired growth (e.g., loss of biomass or stunted height) is not reported. Currently registered 

labels for fosetyl-Al contain a warning regarding the addition of certain additives in regards to 

potential phytotoxicity. In particular, the labels state that the use of foliar fertilizer, copper 

products and adjuvants which enhance pesticide penetration may not be compatible with 

formulations of fosetyl-Al and may cause phytotoxicity. As no further details were provided 

regarding the three incident reports regarding tank mixes, it is not known if a compound that is 

warned of on the label was present during application. Therefore, the assumption was made that 

these other compounds were not present, and the toxicity was attributed to fosetyl-Al. 

A.2. Aquatic Organisms

A.2.1. Fish

Table 3 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Fish

Chemical/Guideline No. / Study 

Type / Test Material Toxicological Effects

Source /

Study Classification and Exposure 

Groups

FOSETYL-AL /72-1 Acute Toxicity 

to Freshwater Fish –

Rainbow trout (Salmo gairdneri), 

juvenile (ave length 75 mm), 16±

1o

C, 7.9 pH, static test /

Technical Fosetyl-Al

95% fosetyl-Al

96-h LC50 = 415.8 ppm (total)

(395.0 ppm ai (total))

(95% CI 309-530 ppm ai (total))

96-h NOAEC = 100 ppm 

(95 ppm ai)

Slope = 5.0 (2.54-7.46)

A white gelatinous precipitate was 

observed on floor of aquaria 

(concentrations not reported); 

centrifugation or filtering not reported. 

1 ppm Tween 80 used as solvent.

Classified as practically non-toxic 

MRID 00098364 Fraser & Pell, 1977 

(Unpublished) / 

Supplemental

0, 100, 200, 300, 500, and 1000 ppm 

nominal (95, 190, 285, 475, 950 ppm 

ai nominal), 10 fish per treatment

FOSETYL-AL /72-1 Acute Toxicity 

to Freshwater Fish –

Rainbow trout (Salmo gairdneri), 

juvenile (mean length 23.3 mm, 

mean wet weight 0.17), 12o

C, static 

test /

Technical Fosetyl-Al

98.39% fosetyl-Al

96-h LC50 = 83.4 ppm ai

(95% CI 67.9-97.0 ppm ai)

96-h NOAEC = 69.4 ppm ai 

Slope = 19.3 (4.85-33.7)

Classified as slightly toxic 

MRID 00128944 Conzelmann., 1983

(Unpublished) /Acceptable

0, 61.4, 69.4, 84.2, 102, 103, 116 ppm

measured (60.4, 68.3, 82.8, 100, 101, 

114 ppm ai measured), 10 fish per 

treatment
Page 63 of 78

Table 3 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Fish

Chemical/Guideline No. / Study 

Type / Test Material Toxicological Effects

Source /

Study Classification and Exposure 

Groups

FOSETYL-AL /850.1075 Acute 

Toxicity to Freshwater Fish –

Rainbow trout (Oncorhynchus 

mykiss), juvenile (mean length 38

mm, mean wet weight 0.86), 13-

15o

C, 7.2-8.1 pH, 132-168 mg/L as 

CaCO3, static renewal test /

Technical Fosetyl-Al

97.8% fosetyl-Al

96-h LC50 > 120 ppm ai

96-h NOAEC = 120 ppm ai

Conducted as limit test

Classified as practically non-toxic 

MRID 47408705 Bell & 

Albuquerque, 1999 (Unpublished) 

/Supplemental

120 ppm ai measured, 20 fish per 

treatment

FOSETYL-AL /850.1075 Acute 

Toxicity to Freshwater Fish –

Rainbow trout (Oncorhynchus 

mykiss), juvenile (mean length 38

mm, mean wet weight 0.86), 13-

14o

C, 7.2-8.1 pH, 132-168 mg/L as 

CaCO3, static renewal test /

FormulationEXP 10369F

79.49% fosetyl-Al

96-h LC50 > 98.1 ppm ai

96-h NOAEC = 98.1 ppm ai

Conducted as limit test

Classified as no more than slightly 

toxic based on measured test 

concentrations

MRID 47408708 Bell, 1999

(Unpublished) /Supplemental

98.1 ppm ai measured, 20 fish per 

treatment

FOSETYL-AL/72-1 Acute Toxicity 

to Freshwater Fish –

Harlequin Fish (Rasbora 

heteromorpha), mean wet weight 0.6 

grams (range 0.43 – 1.0 g)), 

25±1o

C, hardness 25 mg/L as 

CaCO3, flow-through /

Technical fosetyl-Al

Purity not given

96-h LC50 = 170.7 ppm (total)

(95% CI 75-250 ppm)

96-h NOAEC = 75 ppm (total)

No slope, poor fit

Test material described as suspendable 

with difficulty in water; centrifugation 

or filtering of test solution not 

reported. Tween 80 used as solvent.

Classified as practically non-toxic 

MRID 00098365 Fraser & Pell, 1977 

(Unpublished) / 

Unacceptable/0, 50, 75, 150, 250, 500 

ppm nominal, 10 fish per treatment.

Loading- 6 g/L; no reporting of DO, 

or pH.

FOSETYL-AL /72-1 Acute Toxicity 

to Freshwater Fish –

Bluegill Sunfish (Lepomis 

macrochirus), juvenile (mean length 

37 mm, mean wet weight 0.52, 0.35 

g/L), 20.6 (20-21)o

C, 7.0 pH, 

hardness 116 mg/L as CaCO3, static 

test /

Technical Fosetyl-Al

98% fosetyl-Al

96-h LC50 = 141 ppm ai

(95% CI 100-200)

96-h NOAEC = 100 ppm ai 

No slope, poor fit

Classified as practically non-toxic 

MRID 00119526 Spare et.al., 1982

(Unpublished) /Acceptable

0, 100, 200, 300, 400, 500 ppm ai

nominal, 10 fish per treatment
Page 64 of 78

Table 3 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Fish

Chemical/Guideline No. / Study 

Type / Test Material Toxicological Effects

Source /

Study Classification and Exposure 

Groups

FOSETYL-AL /72-1 Acute Toxicity 

to Freshwater Fish –

Bluegill Sunfish (Lepomis 

macrochirus), juvenile (mean length 

47 mm, mean wet weight 1.12 g), 

21o

C, 6.8-7.7 pH, hardness 100 

mg/L as CaCO3, static renewal test /

Technical Fosetyl-Al

97% fosetyl-Al

96-h LC50 >58 ppm ai (total)

96-h NOAEC = 58 ppm ai (total)

Test conducted as limit test. Test 

solution contained very fine particulate 

matter; centrifugation or filtering of 

solutions not reported.

Classified as no more than slightly 

toxic based on mean measured

MRID 47408706 Wetton, 1997

(Unpublished) /Supplemental

58 ppm ai measured, 20 fish per 

treatment

FOSETYL-AL/72-3 Acute Toxicity 

to Estuarine and Marine Organisms

–

Sheepshead minnow (Cyprinodan 

variegatus), juvenile (mean length 

27 mm, mean wet weight 0.43 

grams), 22±1o

C, 4.6-7.9 pH, 32‰ 

salinity, daily renewal test) /

Technical Fosetyl-Al

98.2% fosetyl-Al

96-hr LC50 = 124 ppm (total)

(122 ppm ai (total))

(95% CI 48-157 ppm ai)

NOAEC = 49 ppm (total)

No slope, poor fit

Cloudy test solutions with a precipitate 

at concentrations 45 ppm and greater; 

centrifugation or filtering of solutions 

not reported. Solutions clear and 

colorless at 39 ppm and below.

Classified as practically non-toxic 

MRID 00147360 Sousa, 1985 

(Unpublished)/Acceptable

20, 24, 39, 45, 49, 115 and 160 ppm 

measured (19.6, 23.6, 38.3, 44.2, 113, 

157 ppm ai measured). 10 fish per 

concentration

FOSETYL-AL/NA/ 28-day Juvenile 

Growth Test with Rainbow Trout 

(Oncorhynchus mykiss) – juvenile 

mean length 6.1 cm, mean wet 

weight 3.53 grams), 14-15o

C, 4.6-

7.9 pH 6.6-8.0, daily renewal test /

Technical Fosetyl-Al

97.0% fosetyl-Al

NOAEC = 8.2 ppm

(8.0 ppm ai) 

(based on observation that test 

solutions at this conc. were clear and 

colorless)

No effect on survival or growth 

observed at any concentration tested. 

However, cloudy test solutions with a 

precipitate at concentrations 15 ppm 

(15 ppm ai) and greater; centrifugation 

or filtering of solutions not reported. 

Solutions clear and colorless at 8.2

ppm (8.0 ppm ai).

Non-guideline study

MRID 47408709 Wetton 1998

(Unpublished)/Supplemental

8.2, 15, 28, 53, 95 ppm measured 

(8.0, 15, 27, 51 and 92 ppm ai 

measured). 16 fish per concentration
Page 65 of 78

Table 3 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Fish

Chemical/Guideline No. / Study 

Type / Test Material Toxicological Effects

Source /

Study Classification and Exposure 

Groups

PHOSPHOROUS ACID/850.1075/ 

Acute Toxicity to Freshwater Fish –

Bluegill Sunfish (Lepomis 

macrochirus), juvenile (mean length 

30 mm, mean wet weight 0.62 g), 

22±1o

C, 6.8-7.76 pH, 44.7-46 mg/L 

as CaCO3 hardness, flow-through

test /

Potassium salts of phosphorous acid

29% phosphorous acid

96-h LC50 > 130 ppm 

(38.6 mg phosphorous acid)

96-h NOAEC = 130 ppm 

Test conducted as limit test

Classified as practically non-toxic 

MRID 47408707 Latham, 1999 

(Unpublished)/Supplemental

130 ppm, 30 fish per concentration

Total = indicates that both dissolved and undissolved test material may be present in reported concentration

A.2.2. Invertebrates

Table 4 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Invertebrates

Guideline No. / Study Type / Test 

Material Toxicological Effects Source / Study Classification and Exposure Groups

FOSETYL-AL/72-2 Acute 

Freshwater Invertebrate toxicity test 

–

Waterflea (Daphnia magna), <24-h 

old, static test, 22-23o

C, 4.8-7.0 pH, 

hardness 130 mg/L as CaCO3, 

Technical Fosetyl-Al

94.78% fosetyl-Al

48-h EC50 = 304 ppm ai (total)

(95% CI 178-465 ppm ai)

48-h NOAEC = 178 ppm ai (total)

No slope, poor fit

Flocculant observed in test 

concentrations. Reported collecting 

samples without disturbing flocculant

but no mention of centrifugation or 

filtering of solution.

Classified as practically non-toxic 

MRID 00128943 Spare, 1983 

(Unpublished) / Acceptable

0, 63.7, 100, 178, 277 and 465 ppm 

ai measured

20 daphnia per test concentration

FOSETYL-AL/72-2 Acute 

Freshwater Invertebrate toxicity test 

–

Waterflea (Daphnia pulex), mature 

(at least 5 days old), static test, 

11±1o

C, 7.4 pH, 

Technical Fosetyl-Al

95% fosetyl-Al

48-h EC50 = 161 ppm

(153 ppm ai) 

(95% CI 138-170 ppm ai)

48-h NOAEC < 50 ppm (48 ppm ai)

Classified as practically non-toxic 

MRID 00098366 Cole, 1976 

(Unpublished) /Unacceptable

0, 50, 75, 112, 169, 253, 360, 570 

ppm nominal (48, 71, 106, 161, 

240, 342, 542 ppm ai nominal)

Loading 1 daphnia/mL should be 1 

<24-hr old daphnia/20mL; aeration 

added; temp 11°C instead of 17-

21°C; no reporting of DO or pH.

60 daphnia per test concentration
Page 66 of 78

Table 4 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Invertebrates

Guideline No. / Study Type / Test 

Material Toxicological Effects Source / Study Classification and Exposure Groups

FOSETYL-AL/850.1010 Acute 

Freshwater Invertebrate toxicity test 

–

Waterflea (Daphnia magna), < 24-hr 

old, static test, 21-22oC, 4.9-7.7 pH, 

Formulation EXP10369F

79.4% fosetyl-Al

48-h EC50 = 29 ppm ai (total)

(95% CI 17-84 ppm ai)

48-h NOAEC = 4.6 ppm ai (total)

Slope = 1.82 (95% CI 0.67-2.97)

Precipitate in test solutions at 

concentrations of 25 ppm ai and higher; 

centrifugation or filtering of solutions 

not reported.

Classified as slightly toxic 

MRID 47395702 Bell, 1999 

(Unpublished) /Supplemental

0, 4.6, 8.1, 14, 25, 47, 82 and 146 

ppm ai measured

20 daphnia per test concentration

FOSETYL-AL/850.1010 Acute 

Freshwater Invertebrate toxicity test 

–

Waterflea (Daphnia magna), < 24-hr 

old, static test, 21°C, 5.9-7.7 pH,

270 mg/L as CaCO3 hardness 

Technical Fosetyl-Al

95.9% fosetyl-Al

48-h EC50 > 5.0 ppm ai (total)

48-h NOAEC = 5.0 ppm ai (total)

Study conducted as limit test, precipitate 

in test solutions at limit concentration of 

100 ppm nominal; centrifugation or 

filtering of solution not reported.

Classified as moderately toxic based on 

measured concentration

MRID 47408704 Sewell, 1996 

(Unpublished) /Supplemental

0, 5.0 ppm ai measured

20 daphnia per test concentration
Page 67 of 78

Table 4 Affect of Fosetyl-Al on Freshwater and Estuarine or Marine Invertebrates

Guideline No. / Study Type / Test 

Material Toxicological Effects Source / Study Classification and Exposure Groups

FOSETYL-AL/72-3 Acute 

Estuarine and Marine Organisms

toxicity test – Fiddler Crab (Uca 

pugio), mean weight of 1.91 g, mean 

carapace width of 23 mm, static test, 

21-22o

C, 5.8-8.2 pH,22-23 ‰ 

salinity

Technical Fosetyl-Al

95% fosetyl-Al

96-h EC50 = 114 ppm ai

(95% CI 83.6-156 ppm ai)

96-h NOAEC = 31.0 ppm ai

Slope = 4.63 (95% 2.33-6.92)

Loss of equilibrium observed at 63 ppm 

ai and higher

Classified as practically non-toxic 

MRID 00098367 Rhoderick et. al., 

1981 (Unpublished) / Supplemental

0, 31, 63, 125, 250 and 500 ppm ai 

nominal

10 crabs per test concentration

FOSETYL-AL/72-3 Acute 

Estuarine and Marine Organisms

toxicity test – Grass Shrimp

(Palaemonetes pugio), ~1 month 

old, mean length of 19 mm, mean 

wet weight 0.17 g, static test, 21-

22o

C, 8.0-8.2 pH, 22 ‰ salinity

Technical Fosetyl-Al

95% fosetyl-Al

96-h EC50 = 3.4 ppm ai

(95% CI 2.1-5.4 ppm ai)

96-h NOAEC = <1.0 ppm ai

Slope = 2.21 (95% CI 1.13-3.30)

Loss of equilibrium observed at 8.0 ppm 

ai and higher; 10% mortality at 1.0 ppm 

ai

Classified as moderately toxic 

MRID 00098368 Rhoderick et. al., 

1981 (Unpublished) / Acceptable

0, 1.0, 2.0, 4.0, 8.0, 15 ppm ai 

nominal

10 shrimp per test concentration

FOSETYL-AL/72-3 Acute 

Estuarine and Marine Organisms

toxicity test – Eastern Oyster 

Embryo and Larvae (Crassostrea 

virginica), static test, 22±1o

C, 7.5-

7.9 pH, 20 ‰ salinity

Technical Fosetyl-Al

95% fosetyl-Al

48-h EC50 = 1.85 ppm ai

(95% CI 1.84-1.86 ppm ai)

48-h NOAEC = 1.3 ppm ai

No slope, poor fit

Classified as moderately toxic 

MRID 00147359 Bioassay 

department, 1985 (Unpublished) / 

Acceptable

0, 0.66, 1.30, 2.02, 3.62, 6.52 and 

10.1 ppm measured

FOSETYL-AL/72-4 Aquatic 

Invertebrate Life-cycle toxicity testWaterflea (Daphnia magna), static 

renewal, 21°C, 6.9-7.8 (5.2-5.8 high 

conc) pH

Technical Fosetyl-Al

95.9% fosetyl-Al

21-day NOAEC = 16 ppm ai (total)

(based on survival)

Test solution appearance was not clearly 

stated, but the analytical method 

indicated that many of the samples 

contained very fine particulate matter 

that was solubilized by digestion with 

acid. Solutions not reported to be 

centrifuged/filtered prior to analysis. 

Growth not quantitatively measured.

MRID 47395703 Sewell 1996 

(unpublished)/ Supplemental / 0.96, 

3.1, 9.6, 31 and 96 ppm ai (nominal) 

(0.5, 1.8, 4.2, 16, 84 ppm ai 

(measured))

A.2.3. Plants
Page 68 of 78

Table 5 Affect of Fosetyl-Al on Aquatic Plants

Chemical/Guideline No. / 

Study Type / Test 

Material

EC50

Endpoint Affected

NOAEC 

Endpoint Affected

Source / Study Classification 

and Exposure Groups

Nonvascular

FOSETYL-AL/122-2 (Tier 

II) Algal toxicity test 

Freshwater Diatom 

Navicula pelliculosa, 

freshwater, static

24±2 oC, 

400±60 ftCandles/

Technical Fosetyl-Al

98.5% fosetyl-Al

7-d EC50 = 4.2 ppm ai

(95% CI 2.1-8.3)

Slope = 2.12± 0.475 

(SE)

(area under curve)

7-d NOAEC <1.58 ppm ai

EC05 = 0.7 ppm ai

(95% CI = 0.17-3.0)

(area under curve)

MRID 41128601 Hughes 1989 

/ Acceptable

1.56, 2.72, 5.08, 9.13, 17.0, 

27.8 ppm ai mean measured (0, 

1.58, 2.76, 5.16, 9.27, 17.3, 

28.2 ppm mean measured)

FOSETYL-AL/122-2 (Tier 

II) Algal toxicity test bluegreen algae Anabaena flosaquae freshwater, static

24±2 oC, 

200±30 ftCandles/

Technical Fosetyl-Al

98.5% fosetyl-Al

7-d EC50 = 7.2 ppm ai

(95% CI 6.1-8.6)

Slope = 4.53±1.33 (SE)

(yield)

7-d NOAEC =4.9 ppm ai

(yield)

MRID 41128602 Hughes 1989 

/ Acceptable

0, 0.80, 1.16, 1.37, 3.97, 4.85, 

8.26, 15.4 ppm ai mean 

measured (0.81, 1.18, 1.39, 

4.03, 4.92, 8.39, 15.6 ppm 

mean measured )

FOSETYL-AL/122-2 (Tier 

II) Algal toxicity test green 

algae Selenastrum 

capricornutum freshwater, 

static

24±2 oC, 

400±60 ftCandles/

Technical Fosetyl-Al

98.5% fosetyl-Al

7-d EC50 = 4.5 ppm ai

(95% CI 4.1-4.9)

Slope=5.25±0.343 (SE)

(area under curve)

7-d NOAEC =1.3 ppm ai

(area under curve)

MRID 41128604 Hughes 1989 

/ Acceptable

0, 1.31, 2.25, 4.22, 8.87, 12.3 

ppm ai mean measured (1.33, 

2.28, 4.28, 9.01, 12.5 ppm 

mean measured )

FOSETYL-AL/122-2 (Tier 

II) Algal toxicity test 

marine diatom Skeletonema 

costatum marine, static

20±2 oC, 

400±60 ftCandles/

Technical Fosetyl-Al

98.5% fosetyl-Al

7-d EC50 = 0.78 ppm ai

(95% CI 0.3-2.0)

Slope = 0.851±0.174

(yield)

7-d NOAEC =0.32 ppm ai

(yield)

MRID 41128605 Hughes 1989 

/ Acceptable

0, 0.32, 0.69, 1.00, 2.76, 4.54, 

7.08 ppm ai mean measured 

(0.32, 0.70, 1.02, 2.80, 4.61, 

7.19 ppm mean measured )

FOSETYL-AL/850.5040 

(Tier II) Algal toxicity test 

green algae Scenedesmus 

subspicatus freshwater, 

static

23-24 oC, 

6580-7570 lux/

Technical Fosetyl-Al

97.8% fosetyl-Al

72-hr EC50 =5.6 ppm ai

(area under the curve)

72-hr NOAEC =1.4ppm ai

(area under the curve)

MRID 47408719 Bell et. al. 

1999 / Supplemental

0, 0.63, 1.4, 2.9, 6.9, 16 and 35 

ppm ai mean measured 
Page 69 of 78

Table 5 Affect of Fosetyl-Al on Aquatic Plants

Chemical/Guideline No. / 

Study Type / Test 

Material

EC50

Endpoint Affected

NOAEC 

Endpoint Affected

Source / Study Classification 

and Exposure Groups

FOSETYL-AL/850.5040

(Tier II) Algal toxicity test 

green algae Scenedesmus 

subspicatus freshwater, 

static

22 oC, 

5580-6950 lux/

Formulation EXP 10369F

79.4% fosetyl-Al

72-hr EC50 =7.4 ppm ai

(cell density)

72-hr NOAEC =1.7ppm ai

(cell density)

MRID 47408718 Bell et. al. 

1999 / Supplemental

0, 1.7, 3.9, 7.8, 20, 38, 82 ppm 

ai mean measured

Vascular

FOSETYL-AL/122-2 (Tier 

II) Algal toxicity test 

duckweed Lemna gibba

freshwater, static

25±2 oC, 

390-540 ftCandles/

Technical Fosetyl-Al

98.5% fosetyl-Al

14-d EC50 = 80ppm ai

(95% CI 69-91)

Slope =3.81±0.337

(frond count)

14-d NOAEC=20.4ppm ai

(frond count)

MRID 41128603 Hughes 1989 

/ Acceptable

0, 12.0, 20.1, 40.4, 88.1, 160, 

300 ppm ai mean measured 

(12.2, 20.4, 41.0, 89.4, 162, 305 

ppm mean measured )
Page 70 of 78

Appendix B. MRID Bibliography for Environmental Fate and Toxicity Studies

71-1 Avian Single Dose Oral Toxicity

MRID Citation Reference

98360 Roberts, N.L.; Phillips, C.N.K. (1981) The Acute Oral Toxicity (LDI50^) of LS 74.783 to the 

Bobwhite Quail: RNP 189 WL/81148. Final rept. (Unpublished study received Apr 5, 1982 

under 359- 705; prepared by Huntingdon Research Centre, England, submitted by RhonePoulenc Chemical Co., Monmouth Junction, N.J.; CDL: 247184-B) 

98361 Ross, D.B.; Cameron, M.McD.; Roberts, N.L. (1977) The Acute Oral Toxicity (LDI50^) of LS 

74.783 to the Japanese Quail: RNP76WL/ 77187. (Unpublished study received Apr 5, 1982 

under 359-705; prepared by Huntingdon Research Centre, England, submitted by RhonePoulenc Chemical Co., Monmouth Junction, N.J.; CDL: 247184-C) 

71-2 Avian Dietary Toxicity

MRID Citation Reference

98362 Roberts, N.L.; Phillips, C.N.K.; Almond, R.H. (1982) The Subacute Dietary Toxicity (LC50) of 

LS 74.783 to the Bobwhite Quail: RNP 190 WL/81699. Final rept. (Unpublished study received 

Apr 5, 1982 under 359-705; prepared by Huntingdon Research Centre, England, submitted by 

Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.; CDL:247184-D) 

98363 Roberts, N.L.; Phillips, C.N.K.; Almond, R.H. (1981) The Subacute Dietary Toxicity (LCI50^) 

of LS 74.783 to the Mallard Duck: RNP 191 WL/81716. Final rept. (Unpublished study received 

Apr 5, 1982 under 359-705; prepared by Huntingdon Research Centre, England, submitted by 

Rhone-Poulenc Chemical Co., Monmouth Junc- tion, N.J.; CDL:247184-E) 

72-1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

98364 Fraser, W.D.; Pell, I.B. (1977) The Acute Toxicity of LS.74.783 to the Rainbow Trout (?~Salmo 

gairdnerii~?): RNP78FT/7782. (Un- published study received Apr 5, 1982 under 359-705; 

prepared by Huntingdon Research Centre, England, submitted by Rhone-Poulenc Chemical Co., 

Monmouth Junction, N.J.; CDL:247184-F) 

98365 Fraser, W.D.; Pell, I.B. (1977) The Acute Toxicity of LS.74.783 to the Harlequin Fish 

(?~Rasbora heteromorpha~?): RNP78FT/77122. (Unpublished study received Apr 5, 1982 under 

359-705; prepared by Huntingdon Research Centre, England, submitted by Rhone- Poulenc 

Chemical Co., Monmouth Junction, N.J.; CDL:247184-G) 

119526 Spare, W.; Hutchinson, C. (1982) The Acute Toxicity of Fosetyl-AL to the Bluegill Sunfish ...: 

Project No. 82-E-380-B. (Unpub- lished study received Oct 28, 1982 under 359-705; prepared 

by Biospherics, Inc., submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; CDL:248674-

A) 
Page 71 of 78

128944 Conzelmann, P.; Brady, S. (1983) Acute Toxicity Bioassay Testing Fosetyl-AL on Rainbow 

Trout: GSRI Project No. 413-B45-41. (Un- published study received Jun 17, 1983 under 359-

705; prepared by Gulf South Research Institute, submitted by Rhone Poulenc, Inc., Monmouth 

Junction, NJ; CDL:250499-B) 

72-2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

98366 Cole, J.H. (1976) The Acute Toxicity of LS 74-783 to~Daphnia~ ?~pulex~?: RNP77/76953. 

(Unpublished study received Apr 5, 1982 under 359-705; prepared by Huntingdon Research 

Centre, England, submitted by Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.; 

CDL:247184-H) 

127765 Spare, W.; Gottfried, G. (1983) The Acute Toxicity of Fosetyl-AL to Daphnia magna Straus: 

Biospherics Project No. 82-E-380DM. (Unpublished study received Feb 4, 1983 under 359-705; 

prepared by Biospherics, Inc., submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; 

CDL:249478-A) 

128943 Spare, W.; Gottfried, G. (1983) The Acute Toxicity of Fosetyl-AL to Daphnia magna Straus: 

Biospherics Project No. 82-E-380DMR. (Unpublished study received Jun 17, 1983 under 359-

705; prepared by Biospherics, Inc., submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; 

CDL:250499-A) 

72-3 Acute Toxicity to Estuarine/Marine Organisms

MRID Citation Reference

98367 Rhoderick, J.C.; Spare, W.C.; Hutchinson, C. (1981) The Acute Toxicity of Aluminum-ethylphosphonate to the Fiddler Crab, Uca pugio: Project No. 381-1. (Unpublished study received 

Apr 5, 1982 under 359-705; prepared by Biospherics, Inc., sub- mitted by Rhone-Poulenc 

Chemical Co., Monmouth Junction, N.J.; CDL:247184-I) 

98368 Rhoderick, J.C.; Spare, W.C.; Hutchinson, C. (1981) The Acute Toxicity of Aluminum-ethylphosphonate to Grass Shrimp, Palao- monetes pugio: Project No. 381-2. (Unpublished study received Apr 5, 1982 under 359-705; prepared by Biospherics, Inc., submitted by Rhone-Poulenc 

Chemical Co., Monmouth Junction, N.J.; CDL:247184-J) 

72-4 Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study

MRID Citation Reference

147359 Ward, G. (1985) Acute Toxicity of Fosetyl-Al to Embryos and Larvae of the Eastern Oyster 

(Crassostrea virginica): ESE No. 85-314- 0200-2130. Unpublished study prepared by 

Environmental Science and Engineering, Inc. 17 p. 

147360 Suprenant, D. (1985) Acute Toxicity of Fosetyl-Al to Sheepshead Minnow (Cyprinodon 

variegatus): Bionomics Report #BW-85-5-1777. Unpublished study prepared by Springborn 

Bionomics, Inc. 55 p. 
Page 72 of 78

81-1 Acute oral toxicity in rats

MRID Citation Reference

98330 Pasquet, J.; Mazuret, A.; Maratrat, ?; et al. (1977) LS 74-783 (Aluminium Ethyl Phosphite; 32 

545 R.P., Aluminium Salt): Acute Toxicity in the Rat and Rabbit: R.P./R.D./C.N.G. No. 19 143-

E. (Translation; unpublished study received Apr 5, 1982 under 359-705; prepared by RhonePoulenc, France, submitted by Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.; CDL: 

247160-B) 

98349 Pasquet, J.; Mazuret, A.; Maratrat, ? (1977) Phosphorous Acid (37 934 R.P.) and Disodium 

Phosphite (37 934 R.P., Disodium Salt): Acute Oral Toxicity in the Mouse and Rat: R.P./R.D./ 

C.N.G. No. 19 089-E. (Translation; unpublished study received Apr 5, 1982 under 359-705; 

prepared by Rhone-Poulenc, France, submitted by Rhone-Poulenc Chemical Co., Monmouth 

Junction, N.J.; CDL:247175-A) 

122781 Pasquet, J.; Mazuret, A.; Gaildrat, P.; et al. (1981) Fosetyl-Al (32 545 R.P., Aluminium Salt); 

Aliette WP 80% (Wettable Powder Containing 80% Fosetyl-Al); Acute Oral Toxicity in the Rat: 

Reference C.R. Vitry/C.N.G. No. 21 165-E. (Translation; unpub- lished study received Apr 5, 

1982 under 359-706; prepared by Centre Nicolas Grillet, Fr., submitted by Rhone-Poulenc, Inc., 

Monmouth Junction, NJ; CDL:247186-B) 

41039404 Siglin, J. (1988) Acute Oral Toxicity Study of Aliette Injectable in Rats--Limit Test (EPA): 

Final Rept.: Study No. 3147.7. Un- published study prepared by Springborn Life Sciences, Inc. 

20 p. 

41641802 Kuhn, J. (1990) Aliette 80WDG: Acute Oral Toxicity Study in Rats: Lab Project Number: 6677-

89. Unpublished study prepared by Stillmeadow, Inc. 25 p. 

42273610 Rush, R. (1992) Acute Oral Toxicity Study in Rats with EXP 10100C: Final Report: Lab Project 

Number: 3147.117. Unpublished study prepared by Springborn Laboratories, Inc. 23 p. 

42786703 Rush, R. (1992) Acute Oral Toxicity Study in Rats with EXP 10361A W.G.: Final Report: Lab 

Project Number: 3147.143. Unpublished study prepared by Springborn Labs, Inc. 35 p. 

43486401 Rieth, J. (1994) START WDG Cotton Fungicide: Response to PRS/RSB's Review of Acute Oral 

Toxicity and Skin Sensitization Studies (MRID Nos. 427867-03 and 427867-08). Unpublished 

study prepared by Rhone-Poulenc Ag Co. 6 p. 

83-4 2-generation repro.-rat

MRID Citation Reference

98348 Palmer, A.K.; Bottomley, A.M.; Barton, S.J.; et al. (1981) Effect of LS 74-783 on Reproductive 

Function of Multiple Generations in the Rat: RNP/89/80745. (Unpublished study received Apr 

5, 1982 under 359-705; prepared by Huntingdon Research Centre, England, submitted by 

Rhone-Poulenc Chemical Co., Monmouth Junc- tion, N.J.; CDL:247174-C) 

114091 Palmer, A.; James, R. (1977) Effect of LS74-783 on Pregnancy of the Rat: (Ethylphosphite of 

Aluminum): RNP/33/76939. (Unpub- lished study received Apr 5, 1982 under 359-705; 

prepared by Huntingdon Research Centre, Eng., submitted by Rhone-Poulenc, Inc., Monmouth 

Junction, NJ; CDL:247174-B) 

123-2 Aquatic plant growth
Page 73 of 78

MRID Citation Reference

41128601 Hughes, J. (1989) The Toxicity of Fosetyl-Al to Navicula pelliculo- sa: Proj. ID 1163-01-1100-

3. Unpublished compilation prepared in cooperation with Malcolm Pirnie, Inc. and Biospherics 

Inc. 4 p. 

41128602 Hughes, J. (1989) The Toxicity of Fosetyl-Al to Anabaena flos- aquae: Proj. ID 1163-01-1100-

2. Unpublished compilation pre- pared in cooperation with Malcolm Pirnie, Inc. and Biospherics 

Inc. 42 p. 

41128603 Hughes, J. (1988) The Toxicity of Fosetyl-Al to Lemna gibba G3: Proj. ID 1163-01-1100-5. 

Unpublished compilation prepared in cooperation with Malcolm Pirnie, Inc. and Biospherics 

Inc. 40 p. 

41128604 Hughes, J. (1989) The Toxicity of Fosetyl-Al to Selenastrum capri- cornutum: Proj. ID 1163-01-

1100-1. Unpublished compilation pre- pared in cooperation with Malcolm Pirnie, Inc. and 

Biospherics Inc. 41 p. 

41128605 Hughes, J. (1989) The Toxicity of Fosetyl-Al to Skeletonema costa- tum: Proj. ID 1163-01-

1100-4. Unpublished compilation prepared in cooperation with Malcolm Pirnie, Inc. and RhonePoulenc Ag Co. 30 p. 

141-1 Honey bee acute contact

MRID Citation Reference

40676301 Hinken, C.; Dingledine, J.; Jaber, M. (1986) Fosetyl-Al: An Acute Contact Toxicity Study with 

Honey Bees: Proj. No. 171-110. Un- published study prepared by Wildlife International Ltd. 15 

p. 

161-1 Hydrolysis

MRID Citation Reference

98370 Buys, M.; Bertrand, A.; Giraud, J.P. (1981) Fosetyl-al (Aluminium Tris-O-ethylphosphonate) 

Hydrolysis Study: Ref. AG/CRLD/An/AB/ MB/JPG/CB/613.81. (Unpublished study received 

Apr 5, 1982 under 359-705; prepared by Rhone-Poulenc Agrochemie S.A., France, submitted by 

Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.; CDL:247185-B) 

98371 Bertrand, A. (1981) Fosetyl-al: UV Absorption Characteristics: Ref. No. 

AG/CRLD/An/AB/DB/324/81. (Unpublished study received Apr 5, 1982 under 359-705; 

prepared by Rhone Poulenc Agrochimie, France, submitted by Rhone-Poulenc Chemical Co., 

Monmouth Junc- tion, N.J.; CDL:247185-C) 

162-3 Anaerobic aquatic metab.

MRID Citation Reference
Page 74 of 78

147361 Chabassol, Y. (1984) Anaerobic Aquatic Metabolism Study: Fosetyl- Al: Ref. No. 

AG/CRLD/An/241.84. Unpublished study prepared by Rhone-Poulenc Agrochimie. 57 p. 

163-1 Leach/adsorp/desorption

MRID Citation Reference

98375 Buys, M.; Giraud, J.P. (1982) Fosetyl-al (Aluminum Tris-O-ethyl- phosphonate) Soil Leaching 

Studies: Ref. AG/CRLD/An/AB/MB/JPG/ CB/025.82. (Unpublished study received Apr 5, 1982 

under 359- 705; prepared by Rhone-Poulenc Agrochimie, France, submitted by Rhone-Poulenc 

Chemical Co., Monmouth Junction, N.J.; CDL: 247185-G) 

106019 Bertrand, A.; Buys, M. (1982) Fosetyl-Al--Soil Sorption Studies: Ref. AG/CRLD/An/163.82. 

(Unpublished study received Jul 13, 1982 under 359-705; prepared by Rhone-Poulenc 

Agrochimie S.A., Fr., submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; 

CDL:247820-B) 

835.1230 Sediment and soil absorption/desorption for parent and degradates

MRID Citation Reference

47408701 Buys, M. (1990) Fosetyl-Al (Aluminum Tris-O-Ethylphosphonate): Soil Leaching Studies. 

Project Number: JPG/1, MB/1, MB/2. Unpublished study prepared by Rhone-Poulenc 

Agrochemie. 49 p.

835.1240 Soil column leaching

MRID Citation Reference

47408701 Buys, M. (1990) Fosetyl-Al (Aluminum Tris-O-Ethylphosphonate): Soil Leaching Studies. 

Project Number: JPG/1, MB/1, MB/2. Unpublished study prepared by Rhone-Poulenc 

Agrochemie. 49 p.

835.2110 Hydrolysis as a function of pH

MRID Citation Reference

47408702 Crowe, A. (2001) Fosetyl-Aluminum: Hydrolysis Under Laboratory Conditions at pH 4, 7 and 9. 

Project Number: AES/042/012732, CO12596. Unpublished study prepared by Huntingdon Life 

Sciences, Ltd. 30 p.

835.3300 Soil biodegradation

MRID Citation Reference
Page 75 of 78

47408703 Mackie, J.; Philips, L. (1999) The Rate of Degradation of (Carbon 14)-Fosetyl-Al in Three Soils 

Under Aerobic Conditions at 20 Degrees Celsius . Project Number: 390519, 12546, R011664. 

Unpublished study prepared by Inveresk Research International. 85 p.

835.4100 Aerobic soil metabolism

MRID Citation Reference

47408703 Mackie, J.; Philips, L. (1999) The Rate of Degradation of (Carbon 14)-Fosetyl-Al in Three Soils 

Under Aerobic Conditions at 20 Degrees Celsius . Project Number: 390519, 12546, R011664. 

Unpublished study prepared by Inveresk Research International. 85 p.

850.1010 Aquatic invertebrate acute toxicity, test, freshwater daphnids

MRID Citation Reference

47395702 Bell, G. (1999) EXP10369F: Acute Toxicity to Daphnia Magna. Project Number: 646/994124. 

Unpublished study prepared by Huntingdon Life Sciences, Ltd. 30 p.

47408704 Sewell, I. (1996) Fosettl-Al: Acute Toxicity to Daphnia Magna. Project Number: 601401, 

R005424, 282/479. Unpublished study prepared by Safepharm Laboratories, Ltd. 38 p.

850.1075 Fish acute toxicity test, freshwater and marine

MRID Citation Reference

47408705 Bell, G. (1999) Fosetyl-Al: Acute Toxicity for Rainbow Trout (Oncorhynchus mykiss). Project 

Number: R014234, RNP/629/993803, 604528. Unpublished study prepared by Huntingdon Life 

Sciences, Ltd. 29 p.

47408706 Wetton, P. (1997) Fosetyl-Al: Acute Toxicity to Bluegill Sunfish (Lepomis macrochirus). 

Project Number: 282/491, 446636, R011743. Unpublished study prepared by Safepharm 

Laboratories, Ltd. 41 p.

47408707 Latham, M. (1999) EXP10679A (Potassium Salts of Phosphorous Acid): Determination of 

Acute Toxicity to Bluegill Sunfish (Lepomis Macrochirus). Project Number: AF0552/B, 

BL6508/B, R005931. Unpublished study prepared by Zeneca, Ltd. 17 p.

47408708 Bell, G. (1999) EXP 10369F: Acute Toxicity for Rainbow Trout (Oncorhynchus mykiss) . 

Project Number: RNP/632/993804, R011807, 604525. Unpublished study prepared by 

Huntingdon Life Sciences, Ltd. 29 p.

850.1300 Daphnid chronic toxicity test

MRID Citation Reference
Page 76 of 78

47395703 Sewell, I. (1996) Fosetyl-Al: Daphnia Magna Reproduction Test. Project Number: 282/480. 

Unpublished study prepared by Safepharm Laboratories, Ltd. 80 p.

850.1400 Fish early-life stage toxicity test

MRID Citation Reference

47408709 Wetton, P. (1997) Fosetyl-Al: Fish, Juvenile Growth Test- 28 Days. Project Number: 282/492, 

R011793, 602645. Unpublished study prepared by Safepharm Laboratories, Ltd. 78 p.

850.2100 Avian acute oral toxicity test

MRID Citation Reference

47408712 Gillham, A. (1999) EXP10369F: Acute Oral Toxicity (Lethal Dose 50) to Bobwhite Quail. 

Project Number: RNP/634/993102, R011797. Unpublished study prepared by Huntingdon Life 

Sciences, Ltd. 43 p.

850.2300 Avian reproduction test

MRID Citation Reference

47408710 Gallagher, S.; Beavers, J.; Jaber, M. (1999) Fosetyl-Aluminum: A Reproduction Study with the 

Japanese Quail (Coturnix coturnix japonica). Project Number: 171/138, R014231, 604145. 

Unpublished study prepared by Wildlife International, Ltd. 144 p.

850.3020 Honey bee acute contact toxicity

MRID Citation Reference

47418001 Schmitzer, S. (2000) Laboratory Testing for Toxicity (Acute Oral LD50) of EXP10679A 

(Potassium Salts of Phosphorous Acid) on Honey Bees (Apis mellifera L.) (Hymenoptera, 

Apidae): Final Report. Project Number: 8341036, B003052. Unpublished study prepared by 

Institut fuer Biologische Analytik und Consulting IBACON. 25 p.

47418002 Schmitzer, S. (1999) Laboratory Testing for Toxicity (Acute Contact and Oral LD50) of 

EXP10369F on Honey Bees (Apis mellifera L.) (Hymenoptera, Apidae): Final Report. Project 

Number: 5961036, 604490, R011801. Unpublished study prepared by Institut fuer Biologische 

Analytik und Consulting IBACON. 29 p.

47418003 Schmitzer, S.; Stork, N. (1999) Laboratory Testing on the Acute Contact and Oral Toxicity of 

Fosetyl-Al to Honey Bees (Apis mellifera L.) (Hymenoptera, Apidae): Final Report. Project 

Number: 6300036, 604366, R014232. Unpublished study prepared by Institut fuer Biologische 

Analytik und Consulting IBACON. 29 p.

850.3040 Field testing for pollinators
Page 77 of 78

MRID Citation Reference

47408716 Schur, A. (2000) Assessment of the Side Effects of Soil Application of EXP 10369F (Fosetyl-Al 

80% w/w) on the Honey Bee (Apis mellifera L.) under Semi-Field Conditions: Final Report. 

Project Number: 20001108/01/BZEU, EXP/10369F. Unpublished study prepared by 

Arbeitsgemeinschaft GAB Biotechnologie. 46 p.

850.4100 Terrestrial plant toxicity, Tier 1 (seeding emergence)

MRID Citation Reference

47370502 Nguyen, D.; Gosch, H. (2005) Non-Target Terrestrial Plants: An Evaluation of the Effects of 

Propamocarb-fosetylate SL 840 in the Seedling Emergence Test (Tier 1). Project Number: 

SE05/01, EBPRX020. Unpublished study prepared by Bayer Cropscience Gmbh. 17 p.

850.4150 Terrestrial plant toxicity, Tier 1 (vegetative vigor)

MRID Citation Reference

47370503 Nguyen, D.; Gosch, H. (2005) Non-Target Terrestrial Plants: An Evaluation of the Effects of 

Propamocarb-fosetylate SL 840 in the Vegetative Vigour Test (Tier 1). Project Number: 

VV05/01, EBPRX021. Unpublished study prepared by Bayer Cropscience Gmbh. 17 p.

850.4250 Vegetative vigor, Tier II

MRID Citation Reference

47395701 Teixeira, D. (2000) Aliette 80WG-Determination of Effects on Vegetative Vigor of Six Plant 

Species. Project Number: 13726/6121. Unpublished study prepared by Springborn Laboratories, 

Inc. 101 p.

850.5400 Algal toxicity, Tiers 1 and II

MRID Citation Reference

47408717 Hutchings, M.; Latham, M.; Morris, D. (1999) EXP10679A (Potassium Salts of Phosphorous 

Acid): Toxicity to the Green Alga Selenastrum capricornutum. Project Number: BL6509/B, 

AF0552/C, R005933. Unpublished study prepared by Zeneca, Ltd. 23 p.

47408718 Bell, G. (1999) EXP 10369F: Algal Growth Inhibition Assay on Scenedesmus subspicatus. 

Project Number: RNP/633/994529, R011813. Unpublished study prepared by Huntingdon Life 

Sciences, Ltd. 37 p.

47408719 Bell, G. (1999) Fosetyl-Al: Algal Growth Inhibition Assay on Scenedesmus subspicatus. Project 

Number: RNP/630/994528, R014235. Unpublished study prepared by Huntingdon Life 
Page 78 of 78

Sciences, Ltd. 41 p.

870.1100 Acute oral toxicity

MRID Citation Reference

47248402 Griffon, B. (2000) EXP 11047A: Acute Oral Toxicity in Rats. Project Number: 20374/TAR, 

R014240. Unpublished study prepared by CIT Centre International de Toxicologie. 24 p.

47274002 Tillman, A.; Haferkorn, J. (2007) Acute Toxicity Data for Fosetyl-Al Technical: Compilation 

Report. Project Number: MC/200703, 20495/06, R/20835. Unpublished study prepared by 

Laboratory of Pharmacology & Toxicology. 166 p.

850.1790 Chironomid Sediment Toxicity Test

MRID Citation Reference

47408711 Odin-Feurtet, M. (1999) EXP10679A (Potassium Salts of Phoshorous Acids): Toxicology to the 

Sediment Dwelling Chironomid Larvae (Chironomus riparius). Project Number: SA/98608, 

R005971. Unpublished study prepared by Rhone-Poulenc Agrochemie. 79 p.