# Problem Formulation for the Environmental Fate

and Ecological Risk Assessment in Support of the R egistration Review of Flutolanil

F F F O N H O C H 3



### C H 3



### Flutolanil (CAS 66332 - 96 - 5 )

May 19 , 2008 Prepared by: Larry Liu , Chemist, ERB - 5 Keith Sap pington , Biologist, ERB - 5 Reviewed by: Mah Shamim , Branch Chief , ERB - 5 U. S. Environmental Protection Agency Office of Pesticide Programs Environmental Fate and Effects Division Environmental Risk Branch IV 1200 Pennsylvania Ave., NW Mail Code 7507P Washington, DC 20460Page 2 of 45 

## Ta ble of Contents Table of Contents ................................ ................................ ................................ ................ 2 List of Tables ................................ ................................ ................................ ...................... 3 List of Figures ................................ ................................ ................................ ..................... 3 I. Purpose ................................ ................................ ................................ ........................... 4 II. Problem Formulation ................................ ................................ ................................ ..... 4 A. Nature of Regulatory Action ................................ ................................ ..................... 4 B. Conclusions from Previous Risk Assessments ................................ .......................... 4 1. Drinking W

ater Assessment for Use of Flu tolanil on Rice ................................ .... 4 2. Drinking W

ater Assessment for Use of Flutolanil on Potato Seed Piece .............. 6 3. Section 3 New Use on Potato Seed -Pieces (2000) ................................ ................. 7 4. Human Health Risk Assessment: Request for Inadvertent or Indirect Tolerances for Use on Soybean, Wheat, Corn and Cotton (2007) ................................ ................ 9 III. Stressor Source and Distribution ................................ ................................ ............... 10 A. Mechanism of Action ................................ ................................ .............................. 10 B. Overview of Pesticide Usage ................................ ................................ .................. 10 C. Environmental Fate and Transport ................................ ................................ .......... 13 IV . Receptors ................................ ................................ ................................ ................... 18 A. Aqu atic and Terrestrial Effects ................................ ................................ ............... 18 B. Ecos ys tems Potentially at Risk ................................ ................................ ............... 21 V. Assessment Endpoints ................................ ................................ ................................ . 21 VI . Conceptual Model ................................ ................................ ................................ ....... 21 A. Risk Hy

pothesis ................................ ................................ ................................ ...... 22 B. Conceptual Diagram ................................ ................................ ................................ 22 VII. Anal ys is Plan ................................ ................................ ................................ ............ 25 A. Stressors of Concern ................................ ................................ ............................... 25 B. Measures of Exposure ................................ ................................ ............................. 25 C. Measures of Effect ................................ ................................ ................................ .. 27 D. Integration of Exposure and Effects ................................ ................................ ........ 28 1 . Deterministic and Probabilistic Assessment Methods ................................ ......... 28 E. Endangered Species Assessments ................................ ................................ ........... 28 F. Preliminary Identification of Data Gaps ................................ ................................ .. 30 1. Environmental Fate ................................ ................................ .............................. 30 2. Ecological Effects ................................ ................................ ................................ . 31 3. Rationale for Data Call In ................................ ................................ .................... 34 VIII. Bibliograph y ................................ ................................ ................................ ............. 37 A. Fate References ................................ ................................ ................................ ........ 37 B. Ecological Effects References ................................ ................................ ................. 39Page 3 of 45 

## List of T ables Table 1 . Drinking Water Estimated Concentrations Based on the July 2, 1998 Risk Assessment. ................................ ................................ ................................ ......................... 5 Table 2 Drinking Water Estimated Concentrations Based on the December 13, 1999 Risk Assessment. ................................ ................................ ................................ ......................... 7 Table 3. Uses and application rate s for flutolanil. ................................ ............................ 11 Table 4. Phy sical and Chemical Properties for Flutolanil and its Degradate [desisopropyl flutolanil (DIP)]. ................................ ................................ ................................ ............... 14 Table 5. Summary of Environmental Fate data for Flutolanil ................................ ......... 15 Table 6. Test Species Evaluated for Assessing Potential Acute and Chronic Ecological Effects of Flutolanil. ................................ ................................ ................................ ......... 19 Table 7. Environmental Fate Data Requirements for Flutolanil. ................................ ...... 30 Table 8. Ecological Effects Data Requirements for Flutolanil. ................................ ........ 32 Table 9. Environmental Fate and Ecological Effects Data Needs for Flutolanil. ........... 35 

## List of Figures Figure 1. Conceptual model for flutolanil effects on aquatic organisms. ........................ 23 Figure 2. Conceptual Model of Flutolanil Effects on Terrestrial Organisms. .................. 24Page 4 of 45



## I. P urpose T he purpose of this problem formulation is to provide an understanding of what is known about the environmental fate and ecological effects of the registered uses of flutolanil . This document will provide a plan for analyzing data relevant to flutolanil and for characterizing the ecological risks of its registered uses . Additionally , this problem formulation is intended to identify data gaps , uncertainties and potential assumptions to address those uncertainties relative to characterizing the ecological ris k associated with the registered uses of flutolanil . Flutolanil is a fluorinated toluanilide fungicide with uses on potatoes, rice, peanuts, turf and ornamentals. 

## II. Problem Formulation A. Nature of Regulatory Action The Food Quality Protection Act of 1996 mandated the EPA to implement a new program, i.e ., registration review (http://www.epa.gov/oppsrrd1/registration_review/) . All pesticides distributed or sold in the United States gen e rall y must be registered by EPA. The decision to register a pesticide is based on the consideration of scientific data and other factors showing that it will not cause unreasonable risks to human health, workers, or the environment when used as dire cted on product labeling. The registration review program is intended to ensure that, as the ability t o assess risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effect s to human health and the environment . Changes in science, public policy , and pesticide use practices will occur over time. Through the new registration review program, the Agency periodically reevaluates pesticides to make sure that as change occurs, prod ucts in the marketplace can be used safel y. As part of the implementation of the new Registration Review program pursuant to Section 3(g) of the Federal Insecticide, Fungicide and Rodenticide Act ( FIFRA ) , the Agency is beginning i t s evaluation to det ermi ne whether flutolanil continues to meet the FIFRA standard for registration. This problem formulation for the environmental fate and ecological risk assessment chapter in suppo rt of the registration review is intended for the initial docket opening the pub lic phase of the review process . 

### B. Conclusions from Previous Risk Assessments 1. Drinking W

ater Assessment for Use of Flutolanil on Rice The Agency completed a drinking w ater a ssessment for u se of flutolanil on rice on July 2, 1998. GENEECX - Beta V ersion Model and EFED Interim Rice Model were used to estimate concentrations in surface water used as a source of drinking water. Ground water EECs were modeled using SCI - GROW, a screening groundwater regression model developed using data from prospectiv e groundwater studies submittedPage 5 of 45

to the OPP in support of registration. SCI - GROW provides a reasonable high - end estimate of ground water concentrations of pesticides within a defined set of fate and transport characteristics on soils that are known to be vulnerable to pesticide leaching (high sand content with shallow depth to groundwater). The EECs from the modeling mentioned above are summarized in Table 1 . Table 1 . Drinking Water Estimated Concentrations Based on the July 2, 1 998 Risk Assessment. Groundwater Surface Water Modeling Concentration Acute EECs Chronic EECs Estimated Groundwater Conc.( SCI GROW Model ) 0.5 lb ai/A/ application, 2 applications/year, and 1.0 lb ai/A/year 0.999 ppb N/A N/A Estimated Surfac e Water Conc. ( GENEECX - Beta Version) 0.5 lb ai/A/ application, 2 applications/year, and 1.0 lb ai/A/year N/A 565 ppb 542 ppb + Estimated Surface Water Conc. ( EFED Interim Rice Model ) 0.5 lb ai/A/ application, 2 applications/year, and 1.0 lb ai/A/year N/A 11.7 ppb 3.78 ppb The 1998 drinking water assessment concluded that b ecause of the high uncertainty associated with the estimated surface water concentrations of flutolanil generated b y either GENEECX - Beta Version Model or the Interim Rice Model , neither model was recommended over the other for drinking water risk assessments . The Agency further noted the difficulties with extrapolating concentrations of pesticides in “paddy water” to concentrations that may be observed at the drinking water intak e. However, the Agency considered the estimated concentrations using GENEECX as establishing a conservative upper - end bounding estimate of concentrations that might have been o bserved at drinking water intakes. As a result, the Agency concluded if the leve ls of concern for flutolanil were not exceeded with these concentrations, real world exposure would not likely exceed these levels. Estimates generated with the Interim Rice Model may have well provide d an upper end estimate of concentrations at drinking w ater intakes as well. However, because these estimates were substantially lower than an equally reasonable model, GENEECX, the Agency did not select one over the other . The SCI GROW indicate d that flutolanil w ould not likely be found in significant concentrations in groundwater. Concentrations of this compound were calculated based on a maximum annual application rate of 1.0 lb a.i/A . Since the groundwater concentrations were developed through a screening model and no monitoring data were used, the Agency w asPage 6 of 45

only moderately confident of these estimates. It should be noted that the application rates used in the 1998 Drinking Water Assessment for Use of Flutolanil on Rice were slightl y different from those in the labels for the registration review. The sin gl e application rate and the yearly application rate used in GENEECX, Interim Rice, and SCI - GROW modeling in the 1998 Drinking Water Assessment for Use of Flutolanil on rice were 0.5 lb ai/A and 1.0 lb ai/A, respectively . However, according to the labels in the registration review, flutolanil can be aerially applied to the rice plants with a single application rate ranging from 0.35 - 0.75 lb ai/A and with a maximum yearl y r ate of 1.0 lb ai/A. The labels that allow the use of flutolanil on rice under the registration review include: Reg. No. 71711 - 3 (Moncut 50W) Reg. No. 71711 - 14(Moncut 70 DF) Reg. No. 71711 - 1(Moncut 70WP) SL N No. AR - 050007 (Moncut SC

– it does not have a Reg. No. because it is still a pending registration) 2. Drinking W

ater Assessment for Use of Flutolanil on Potato Seed Piece The Agency completed a drinking w ater a ssessment for u se of flutolanil on potato seed piece on December 13, 1999. PRZM/EXAMS modeling using the Index Reservoir (IR) and the Percent Crop Area (PCA) adjustment w as used to estimate concentrations in surface water used as a source of drinking water. The index reservoir represents a watershed that is more vulnerable than most used as drinking water sources. Ground water EEC were modeled using SCI - GROW, a screening groundwater regression model developed using data from prospective groundwater studies submitted to the OPP in support of registration. SCI - GROW provides a reasonable high - end estimate of ground water concentrations of pesticides within a defined set of fate and transport characteristics on soils that are known to be vulnerable to pesticide leaching (high sand content with shallow depth to groundwater). PRZM/EXAMS 1 - in - 10 year estimated environmental concentrations suggest ed that f lutolanil might have been found in surface water used as a source of drinking water at peak concentrations up to 0.63 μg/L and 0.28 μg/L from use on potatoes in I daho and Maine, respectivel y and on a long - term basis (mean) at 0.13 μg/L and 0.05 μg/L from use on potatoes in Idaho and Maine, respectivel y. SCI - GROW estimated environmental concentrations in ground water, independent of the use area, were found at concentrations up to 0.34 μg/L ; peak and mean concentrations. The Agency concluded that d ue to flutolanil’s low adsorp tion coefficients and long metabolic half - life, the major mechanism of dissipation in surface and ground water w ould likel y be dilution. Based on flutolanil’s structure, the Agency indicated that flutolanil would not likely be significantl y a ffected b y ch emical oxidation employed at most community water s ys tems. EECs from the modeling mentioned above are summarized in Table 2 .Page 7 of 45

Table 2 Drinking Water Estimated Concentrations Based on the December 13, 1999 Risk Assessment. Agricult ural Setting Surface Water Concentrations

(ppb) Ground Water Concentrations (ppb) 1 - in - 10 ye ar Peak 1 - in - 10 year

Mean Rice 11.6 3.75 1 in 10 Year Peak 1 in 10 Year

Mean Potatoes in Idaho 0.63 0.1 3 1 in 10 Year Peak 1 in 10 Year

Mean Potatoes in Maine 0.28 0.050 0.34

It should be noted that the application rates used in the 1998 Drinking Water Assessment for Use of Flutolanil on Potato Seed Piece were slightly different from those in the la bels for the registration review. The application rate used in PRZM/EXAM and SCI - GROW modeling in the 1999 Drinking Water Assessment for Use of Flutolanil on Potato Seed Piece was 0.65 lb ai/A which is more than twice the rate (0.25 lb ai/A) as stated in the current MonCoat MZ (Reg. No. 71711 - 8) label considered for registration review. . However, the application rate (0.65 lb ai/A) used in the PRZM/EXAM S and SCI - GROW modeling in the 1999 Drinking Water Assessment for Use of Flutolanil on Potato Seed Piec e was lower than the rate (0.75 lb ai/A) when flutolanil is sp rayed around and over the seed pieces in a 4 - 8 inch band prior to covering with soil (Moncut 50W. Reg. No. 71711 - 3). 3. Section 3 New Use on Potato Seed -Pieces (2000) Pursuant to FIFRA Sect ion 3, the Agency completed a screening - level environmental fate and ecological risk assessment for a new flutolanil use on February 15, 2000 (US EPA 2000 ; D260099 ). This proposed new use consisted of a single application of 

### 1.0 lbs product (0.015 lbs. a.i .) per 100 lbs of cut potato seed pieces for the control of Fusarium dry rot and Rhizoctonia stem canker. According to this new use, f lutolanil is co - formulated with Mancozeb (6 percent) in an Adler bark dust formulation and is applied immediately after cutting followed by general planting practices. This new use assessment was based on laboratory /field fate and ecotoxicological data submitted by the registrant and from data in publicly available literature . The environmental fate assessment concluded that flutolanil is practically resistant to all modes of abiotic and biotic degradation. Degradation half lives were not calculated for a

biotic processes (h ydroly sis, photoly sis) because they extended well beyond the study duration. Biotic degradation hal f lives (metabolism in aerobic soils,Page 8 of 45

aerobic aquatic, anaerobic aquatic) were all greater than 200 day s . The degradate, desisopropyl f

lutolanil (DIP) is considered more mobile than the parent and n o other degradate data were availabl e. The ecological toxicity assessment concluded that flutolanil is practically nontoxic to birds, mammals, and insects (honey bee) on an acute and subacute basis. Flutolanil was found to be moderatel y t oxic to freshwater fish and invertebrates on an a cute basis and highly toxic to estuarine/marine invertebrates on an acute basis. On a chronic toxicity basis, flutolanil was found to cause adverse effects on avian reproduction ( decreased egg production and egg shell thickness ), growth of fish, freshwater invertebrate reproduction rate (number of young/adult) and survival, reproduction and growth of estuarine/marine invertebrates. Based on the available information, the 2000 screening level risk assessment concluded that flutolanil would not likely to pose a risk of acute or chronic toxicity to non - target animals . The risk associated with the co - formulated product was not addressed due to the lack of information on effects to terrestrial and aquatic organisms. Flutolanil was considered persistent in the environment under aerobic and anaerobic conditions and likely to reach surface water sorbed to soils, organic materials, and in dissolution and reach ground water despite information from the field dissipation studies which showed that f

lutolanil appeared to bind to soils. The assessment further concluded that the proposed application method ( seed - piece dust treatment) and the general agricultural practice (planting the seed - piece at 2 or more inches below the surface followed b y m ounding of approximate ly 

### 2 inches of additional soil ) would likely reduce the likelihood of surface water runoff but potentially exacerbate leaching to ground water. The primary environmental concerns identified in the environmental fate and ecological risk assessment in supp ort of the registration for flutolanil associated with the (now historical) uses of flutolanil (USEPA , 2000) were the behavior of the co - formulated product ( flutolanil is co - formulated with mancozeb (6%) in an Adler bark dust formulation) in the environment. Specificall y, it was uncertain whether the two active ingredients would behave independentl y or impart a sy nergistic or antagonistic effect on non - target species. As a result of this assessment, a number of data needs were identified. Regarding environmental fate, a bare ground terrestrial field dissipation study was recommended. In response, the registrant submitted one aerobic soil metabolism study (MRID 45756601) and two terrestrial field dissipation studies (MRIDs 45756602 and 45756603) which are under review. Regarding ecological effects, studies on the acute toxicity of the co - formulated end use product Moncoat MZ fungicide ( co - formulated with Mancozeb) were requested as part of its conditional registration on February 22, 2001 (EPA Reg. No. 71711 - 8) . These tests include :Page 9 of 45 Acute avian oral (71 - 1) Acute avian dietary

– mallard (71 - 2) Avian reproduction (71 - 4) Acute Freshwater Fish (72 - 1) Acute freshwater invertebrate (72 - 2) Chronic life cycle / estuarine invertebrate (72 - 4) Three t o xicity tests of the technical grade active ingredient (TGAI) were also requested as part of the aforementioned conditional registration. These tests include: Acute estuarine/marine fish (72 - 3) Chronic freshwater fish life cycle (72 - 5) Chronic marine fi sh life cycle (72 - 5) In response to this the ecotoxicity data request, the registrant (Nichino America, In c.) submitted a waiver request of the data requirements to the Agency on Sept 9 th , 2002. The required data and waiver request are being considered as part of the data needs outlined in this problem formulation. It should also be noted that the ecological risk assessment was conducted based on a lower application rate for potato seed piece, not on the much higher rates for rice, peanuts and turf. According to the labels under the registration review, the maximum ye arl y application rates for other crops or non - crop (rice, peanuts, and turf) are much higher than that for potato piece treatment. Table 3 showed that the yearl y rate for potato piece treatment ranges from 0.25 - 0.75 lb ai/A whereas those for rice, peanuts and turf are 1 lb ai/A, 2 lb ai/A and 8.5 lb ai/A, respectivel y. 4 . Human Health Risk Assessment: Request for Inadvertent or Indirect Tolerances for Use on Soybean, Wheat, Corn and Co tton (2007) A recent human health risk assessment was conducted on flutolanil in response registrant petitions proposing the establishment of permanent tolerances for inadvertent or indirect residues in/on corn, cotton, so ybean, and cotton commodities (U SEPA, 2007). Although this assessment did not address ecological risks, it does contain information that is relevant to the current problem formulation. For example, based on mammalian toxicity data, flutolanil was not identified as a reproductive or dev elopmental toxicant nor was it identified as being neurotoxic. The chronic NOAEL of 50 mg/kg/day (increased incidence of clinical toxic signs ) was identified based on a 2 - ye ar dietary study in dogs (relevant to the chronic mammalian toxicity assessment) . Furthermore, the major metabolite identified in plants and rotational crops (potentially relevant to herbaceous birds and mammals) were M - 4 (N - (3’ - hydroxy phenyl) - 2 - (trifluoromethyl)benzamide) and M - 5 (N - (3’,4’ - (dih ydrox yp henyl) - 2 - (trifluoromethyl)benzamide ). There are no established MCL for residues of flutolanil in drinking water. No health advisory levels for flutolanil in drinking water have been established. The residuesPage 10 of 45

in water are the parent compound and M4; and the parent is the major resid u e. HED concluded that onl y the parent needs to be included in the drinking water exposure assessment for flutolanil . In the chronic dietary assessment , HED used EECs in surface water and groundwater that were estimated by EFED based on the use of flutolani l on rice paddy ( 0.5 lb ai/ a x 2 applications/year. S ee Section 2 above for detail ). The chronic dietary assessment (food and drinking water) showed that for all included commodities, the dietary risk estimates were below the Agency ’s level of concern (< 100% cPAD) for the general U.S. population (<1% of the cPAD) and all population subroups ( < 1% cPAD). 

## III. Stressor Source and Distribution A. Mechanism of Action Flutolanil, [N - (3 - (1 - methylethoxy) - phenyl ) - 2 - (trifluoromethyl) - benzamide], is a sy stemi c fungicide that exhibits both curative and protective action against fungal diseases of crops . Its specific mode of action in fung i (e.g., Rhizoctonia sp.) is to i nhibit mitochon drial respiration through the interference of succinate metabolism (inhibiti on of succinate deh ydrogenase complex ) (IFAS/UF, 2006; Motoba et al., 1988). 

### B. Overview of Pesticide Usage Flutolanil is for control of black scurf ( Rhizoctonia solani ) in potatoes, for control of sheath blight (Rhizoctonia solani) in rice, for co ntrol of southern stern rot (white mold) and the limb/pod rot complex ( Rhizoctonia sola ni ) in peanuts, for control of diseases caused b y Basidiomycetes on turf, and for control of diseases caused by rusts, species of Rhizoctonia and Sclerotium rolfsi on or namentals. Under the registration review, there are 1 1 Section 3 registrations and 5 Section 24C registrations f

or products containing flutolanil . Flutolanil can be applied as a product containing only flutolanil (i.e., Moncut 50WP , ProStar 70 WDG ) or as a co formulated product that contains other active ingredients (see below).

· Mancut CL Flowable (Reg. No. 71711 - 2) contains flutolanil (10.3%) and chlorothalonil (38.6%). · MonCoat MZ (Reg. No. 71711 - 8) contains flutolanil (1.5%) and mancozeb (6%). · Artisan (Reg. No. 71711 - 17) contains flutolanil (32%) and propiconazole (6%). · NAI - 301 4SE (also known as Artisan Trifecta; Reg. No. 71711 - 24) contains flutolanil (17.2%), chlorothalonil (21.85%) , and propiconazole (1.8%). There are a total of three Section 3 registrations/labels [ Reg. No. 71711 - 1 (Moncut 70WP) , 71711 - 3 (Moncut 50W) , and 71711 - 14 (Moncut 70 DF) ] that allow the use of flutolanil on rice. However, each of these three label s contains the following geographical restrictions on rice in the State of Arkansas due to concern on the endangered species.Page 11 of 45 “The use of flutolanil on rice is restricted to protect the endangered fat pocketbook pearly mussel ( Potamilus capax) and its habitat. Use is prohibited in the following areas of Arkansas: Mississip pi County : Within the basin that drains directly into the Right Hand Chute of Little River, south of Big Lake National Refuge. Poinsett County : Between Cowley ’s Ridge and the levee east of the Right Hand Chute of Little River and the St. Francis Floodway. Use is also prohibited west of Rt. 140 and north of Rt. 63 at the SIPHON near Marked Tree. Except that the prohibited area does not include the area bounded by Arkansas Highway 373 on the west, Highway 63 on the east and Highway 14 on the south. Cros s, St. Francis, and Lee Counties: Between Crowley’s Ridge and the levee east of the Right Hand Chute of Little River and the St. Francis Floodway as far south as the confluence of L’Anguille River (Lee County).” It should be noted that , according to SLN AR - 050007, flutolanil can still be used on rice in Arkansas until 2010. This is because the "pending" label (Moncut SC) used in the SL N does not contain any geographic al restrictions in Arkansas. A list of registered flutolanil uses, along with their respective application methods, single application rates , application intervals, and maximum seasonal/yearly application rates are presented in Table 3 . Table 3 . Uses and application rates for flutolanil. Crop/Labels/Restrictions Single Application Rate (lb a.i./A)/Methods Number of Applications per Season Application Interval (days) Maximum

Application rate per Season (lb a.i./A/Season) Potato Reg. No. 71711 - 3 (Moncut 50W) Restrictions in CA Reg. No. 71711 - 8 (MonCoat MZ) 0. 5 - 0.75 (spray around and over the seed pieces in a 4 - 8 inch band prior to covering with soil) 0.25 (apply to the seed pieces immediately after cutting at 0.011 - 0.015 lb ai per 100 lbs of cut seed) 1 1 N/A N/A 0.75

0.25Page 12 of 45

Crop/Labels/Restrictions Single Application Rate (lb a.i./A)/Methods Number of Applications per Season Application Interval (days) Maximum

Application rate per Season (lb a.i./A/Season) Rice Reg. No. 71711 - 3 (Moncut 50W) Restrictions in CA, AR

Reg. No. 71711 - 14 (Moncut 70 DF) Restrictions in CA, NY, AR Reg. No. 71711 - 1 (Moncut 70WP) Restrictions in CA, AR SLN No. AR- 050007 (Moncut SC

– it does not have a Reg. No. because it is still a pending reg istration) 0.35 - 0.50 (aerial application to rice plant) 0.35 - 0.70 (aerial application to rice plant) 0.35 - 0.50 (aerial application to rice plant) 0.35 - 0.70 (aerial application to rice plant) 0.35 - 0.50 (aerial application to rice plant) 0.35 - 0 .75 (aerial application to rice plant) 2 2 or more (max application frequency wa s not specified) 2 2 or more (max application frequency wa s not specified) 2

2 10 - 14 Not specified

10 - 14 Not specified

10 - 14 Not specified 1.0

1.0

1.0 1.0

1.0

1.0

Peanuts Reg. No. 71711 - 17 (Artisan)

Reg. No. 71711 - 3 (Moncut 50W) Restrictions in CA Reg. No. 71711 - 1 (Moncut 70 WP) Restrictions in CA 0.61 - 0.75 (when applying Artisan alone) (ground, chemigation, ae rial) 0.305 - 0.493 (w

hen applying Artisan with chlorothalonil) (ground, chemigation, aerial) 0.25 - 2 (ground, chemigation, aerial) 1 - 2 (ground, chemigation, aerial) 2 - 3 applications for the 0.61 lb ai/application 2 applications for the 0.75 lb ai/application Make sequential applications as needed 1 - 4 2 21 - 30 21 - 30 10 - 14 10 - 30 30 2.0

2.0 2.0 2.0 2.0Page 13 of 45

Crop/Labels/Restrictions Single Application Rate (lb a.i./A)/Methods Number of Applications per Season Application Interval (days) Maximum

Application rate per Season (lb a.i./A/Season) Turf Reg. No. 432 - 1223 (ProStar 70 WP) Reg. No. 432 - 1477 (ProStar 70 WDG) 2.86 - 5.71 (broadcast application) (see Fo otnote 1) 2.86 - 8.53 (broadcast application) (see Footnote 2) 2 2 14 - 30 14 - 30 8.53

8.53 Ornam entals Reg. No. 432 - 1223 (ProStar 70 WP) Restrictions in NY Reg. No. 432 - 1477 (ProStar 70 WDP) Restrictions in NY SLN No. WA - 040032 (tulips an d iris) Not specified (broadcast foliar, soil drench, cutting/bulb dip, chemigation, overhead/microjet/drip irrigation) 1.14 - 4.57 (in - furrow application) No more than 4 application s

1 14 - 21

N/A Not specified

4.57 Footnote s: 1. For the use of ProStar 70 WP on turf, the single application rates were converted from oz product/1,000 square feet to lb ai/A with the exceptions of the control of fairy ring and gray snow mold. Since the label states that “do not treat more than 10, 000 square feet per acre of turf area” when the highest rates are used (4.5 oz product/1,000 square feet for fairy ring and 3 - 4.5 oz product/1,000 square feet for gray snow mold), the corresponding lb ai/A was adjusted accordingly. 2. For the use of ProSt ar 70 WDG on turf, the maximum single application rate (i.e., 8.53 lb ai/A) for the curative control of Rhizoctonia zeae wa s calculated directly from oz product per 1,000 square feet to lb ai/A because the label did not state any restriction in treated are a, such as that stated on ProStar 70 WDG for the control of fairy ring and gray snow mold (see Footnote 1 above). Note - the use of flutolanil in control of Rhizoctonia zeae was not mentioned in the ProStar 70 WP. 

### C. Environmental Fate and Transpor t Registrant - submitted data defining the phy sical and chemical properties for flutolanil and its most significant degradate [desisopropyl flutolanil (DIP)] are summarized in Table 4 , and the fate and transport parameters associated with flutolanil and DIP ar e summarized in Table 5 . In past assessments involving flutolanil , values for vapor pressure, water solubility , Henry ’s Law Constant and Kow were obtained from EFED One - Liner. According to the review of Flutolanil

– Human H ealth Risk A ssessment : Request for Inadvertent or Indirect T olerances for U se on S oybeans, Wheat, C orn and C ottom completed by HED on 11/27/07, vapor pressure, water solubility , and Lo g K ow recorded in EFED One - Liner were reported in MRID 42606601.Page 14 of 45

Table 4 . P hysical and Chemical Properties for F lutolanil and its D egradate [desisopropyl flutolanil (DIP)]. Parent Common Name Flutolanil PC Code 128975 Chemical Names IUPAC α,α,α - Trifluoro - 3 ′ - isopropoxy - o - toluanilide CAS N - [3 - (1 - Methylethoxy)phenyl] - 2 - (trifluoromethyl)benzamide CAS Number 66332 - 96 - 5 Chemical Structure

F F F O N H O C H 3

C H 3

Molecular Formula C 17 H 16NO 2 F 3 Molecular Weight (g/mole) 323.3 SMILES Code C(F)(F)(F)c1ccccc1C(=O)Nc2c ccc(OC(C)C)c2 ( EPI Suite, v3.12) Water Solubility 6.53 ppm at 20C Vapor Pressure 4.87e - 8 mm Hg at 25C Henry’s Law Constant 2.12e - 9 atm m 3 /mo le LogKow 3.74 (initial conc. 10 - 2 M) 3.79 (initial conc. 10 - 3 M) Major Transform ation Pr oduct of Flutolanil Common Name Desisopropyl flutolanil (DIP) Chemical Names IUPAC NA CAS N - (3 - Hydroxyphenyl) - 2 - (trifluoromethyl)benzamide CAS Number NAPage 15 of 45

Chemical Structure

F F F O N H O H

Molecular Formula C 14 H 10NO 2 F 3 Molecular Weight (g/mole) 281.2 SMILES Cod e C2C=CC=C(C(F)(F)F)C=2C(=O)NC1C=CC=C(O)C=1 ( EPI Suite, v3.12) Water Solubility N/A Vapor Pressure N/A Henry’s Law Constant N/A LogKow N/A Table 5 . Summary of Environmental Fate data for Flutolanil Guide - line # Data Requirement Study MRID Results 161 - 1 Hydroly sis 40342940 Stable at pH 5, 7, and 9 161 - 2 Photolysis in Water 41841208 41841209 Stable at pH 7 161 - 3 Photodegradation

on Soil 41841210 43175810 Stable (unacceptable study).

Additional dat a (43175810) submitted by the registrant to upgrade 41841210 are under review. 162 - 1 Aerobic Soil

Metabolism 40342941

40342942 45756601 T1/2 = 190 days (volcanic ash); 320 days

(loam); and 300 days (sandy loam). Less than 3% of the applied was det ected as DIP (desisopropyl flutolanil ) Irrelevant (a publication for benthiocarb w hich wa s accidentally listed under flutolanil ) T1/2 = 217 days (sandy loam) (still under review). Preliminary review indicated that n o major degradates were detected 16 2 - 3 Anaerobic Aquatic

Metabolism 41841211 T1/2 > 13 years. Less than 1% of the applied wa s found as DIP 162 - 4 Aerobic Aquatic

Metabolism 41841212 T1/2 = 1 year. No major degradates were detectedPage 16 of 45

Guide - line # Data Requirement Study MRID Results 163 - 1 Leaching Adsorption/ Desorption 42606626 42606627 40342943 41841213 Degradate DIP Koc = 288 (sand); 293 (loam);

396 clay loam); 317 (loamy sand) Parent Koc = 571 (sand); 592 (loam); 457 (clay loam); 628 (clay loam); 1,005 (loamy sand) Parent Koc = 1340 (sand); 883 (clay); 528 (sediment); 653 (clay loam); 1,150 (sandy loam) No useful information 164 - 1 Terrestrial Field

Dissipation 41837803 41837804 43175809

45756603 45756602 Unacceptable

Turf field in CA. T1/2 was not reported. Parent was found in 24 - 30 inch soil zone. Degradate DIP wa s found in 12 - 18 inch zone Peanuts field in FL. T1/2 = 44 days (0 - 121 days); T1/2 = 225 days (121 days

– 18 mo nths). Degradate DIP was not detected below 8 cm . Turf field in CA. T1/2 = 65 days (still under review) Bare field in FL. T1/2 = 182 days (still under review) 164 - 2 Aquatic Dissipation 42606618 43292603 Rice paddies in CA and GA.

Sediment T1/2 = 303 days (GA); Sediment T1/2 = 63 days (CA) Unacceptable 164 - 5 Long - term Soil

Dissipation 43175804 Peanuts field in FL. T1/2 = 118 days (1st year); 126 days (2 nd year); 123 days (3 rd year) 165 - 3 Accumulation in

Irrigated Crops 42606615 Rice paddies in AR and LA. Parent and DIP did not accumulate in irrigated crops 165 - 4 Accumulation in

Fish 40342944

41841214 41841215 Japanese carp .

BCF in whole fish = 13 - 26 (in 0.1 ppm water) BCF in whole fish = 9.3 - 24 (in 0.01 ppm water) Bluegill sunfish. BCF = 13 (edible); 270 (non edible); 150 (whole fish) 165 - 5 Aquatic Non - target

Organism 42641101 Rice paddy in LA. Parent and degradate DIP were not found in Grayfish Soil Storage Stability 42606616 Stable at least 2 yearsPage 17 of 45 Flutolanil has a very low solubility , has a low propensity to volatilize, and will remain in the aqueous phase based on the low Henry's Law Coefficient. In laboratory tests, Flutolanil was resistant to hydrol ys is at all pHs tested and practicall y resistant to photoly sis on both soils and in water. Flutolanil also appears to be relatively resistant to aerobic and anaerobic degradation in both soils and aquatic environments with half - lives of more than 200 day s in soils and greater than one year in water. In laboratory aerobic metabolism studies, no major transformation product s were identified. Three minor degradates were identified. 3' - hydroxy- 2 - trifluoromethyl benzanilide (DIP) was formed no more than 3% of the applied. Two other degradates were formed in minor amounts (< 1 %). These were 3' - methoxy- 2 - trifluoromethyl benzanilide 

### (MDP) and 4' - hydroxy- 3 - methoxy- 2 - trifluoromethyl - benzanilide (HMD). Flutolanil was obser

ved to degrade faster under anaerobic conditions during the flooded stage of the study. Two minor degradates not identified under aerobic conditions were observed. These were : 3' - (hydroxy methy 1ethox y) - 2 - trifluorometh yl - benzanilide (HIP) and 4' - hydrox y- 3' - i sopropoxy- 2 - triflourometh yl - benzanilide (HFT). Batch equilibrium studies for flutolanil and the transformation product DIP (desisoprop yl flutolanil) determined 

### kd values to range from 0.997 - 15.8 and 0.5 - 1 1.3, respectivel y. There is a minimal propenc ity for flutolanil to leach based on Koc ’ s ranging from 457

– 1340 ml/g (MRID Nos. 41837803, 41837804, 43175809, 45756603, 45756602) and solubility of 6.53 ppm. This is supported i n the field dissipation studies where the parent or DIP were not detected b elow the 36 - inch sample depth. However, a prospective ground water has not been conducted nor requested to confirm whether or not it may leach. A ground water study was waived. Flutolanil and the primary degradate DIP may be transported to surface water through erosion of soil particles containing bound flutolanil or dissolved in runoff water. Partition coefficients were not available for the other degradates, but, would appear, based on their structure, to be as mobile as the parent. The maximum BCF for flutolanil was 270X non - edible fish 

### (1 3X edible tissue, 150X whole fish) as determined by total 1 4C . Depuration after termination of exposure was rapid with more than 95 percent eliminated in 3 days. These results would indicate minimal propensity to bioconcentrate or bioaccumulate. The estimated log octanol - air partition coefficient (Log KOA) of 10.6 (EPIsuite, v.3.20) suggests that bioaccumulation of flutolanil in terrestrial organisms is possible (Kelly et al . 2007). However, there is uncertainty associated with this Log KOA since the value is obtained b y m odel estimation.Page 18 of 45



## IV . Receptors A. Aquatic and Terrestrial Effects Consistent with the process described in the Overview Document (USEPA, 2004), the risk assessment for flutolanil will rel y on a surrogate species approach. T oxicological data generated from surrogate test species, which are intended to be representative of broad taxonomic groups, are used to extrapolate to potential effects on a variety of species (rec eptors) included under these taxonomic groupings. A cute and chronic toxicity data from studies submitted by pesticide registrants along with the available open literature are used to evaluate the potential direct and indirect effects of flutolanil to the aquatic and terrestrial receptors. This includes toxicity data on the technical grade active ingredient, degradates, and when available, formulated products ( e.g . “Six - Pack” studies). The open literature studies are identified through EPA’s ECOTOX data

base (USEPA 2007 d

), which employ s a literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, and wildlife. The evaluation of both sources of data can also provide insight into the direct and indirect effects of f

lutolanil on biotic communities from loss of species that are sensitive to the chemical and from changes in structure and functional characteristics of the affected communities. Table 6 provides a summary of the taxonomic groups and the surrogate speci es tested to help understand potential acute and chronic ecological effects of flutolanil. In addition, the table provides a preliminary overview of the potential acute toxicity of flutolanil by providing the acute toxicity classifications. Technical grade flutolanil is classified as practically non - toxic to birds, mammals and terrestrial insects on an acute toxicity basis. Flutolanil is considered moderatel y t oxic to freshwater fish, estuarine/ marine fish and freshwater invertebrates. Estuarine/marine crustaceans (m ys id shrimp) appear to be the most sensitive taxa tested with flutolanil and are classified as highl y t oxic. Molluscs (eastern oyster) appear to be less sensitive to flutolanil compared to crustaceans on an acute toxicity basis . Chronic exposure to flutolanil resulted in reduced egg production and egg shell thickness in birds, but did not exhibit chronic toxicity in rats up to 1000 mg/kg bw. Chronic exposure to flutolanil was associated with reduced growth and reduced reproduction in fr eshwater fish and invertebrates, respectivel y. Survival, reproduction and growth were significantly reduced following chronic exposure to flutolanil by estuarine/marine invertebrates (m ys id shrimp). Based on Tier 1 screening tests, flutolanil is classifi ed as moderately toxic to aquatic vascular and nonvascular plants based on significantl y r educed growth following exposure to 8.01 mg a.i./L.Page 19 of 45

Table 6 . Test Species Evaluated for Assessing Potential Acute and Chronic Ecological Ef

fects of Flutolanil . Taxonomic Group Surrogate Species Acute Toxicity

-- Chronic Toxicity Citation MRID Acute Toxicity Classification Mallard ( Anas platyrhynchos ) LD 50 = > 2000 mg/kg bw

LC 50 = > 5243 ppm in diet

-- NOAEC = 1920 ppm LOAEC = 4800 ppm 40342929 40342931

-- 42932302 Practically non - toxic

Birds 1 Northern bobwhite

quail (Colinus virginianus) LD 50 > 2000 mg/kg bw

LC 50 = > 5243 ppm in diet

-- NOAE C = 1920 ppm LOAE C = 4800 ppm 40342930 40342932

-- 42932301 Practical ly non - toxic

Mammals Laboratory rat

(Rattus norvegicus ) LD 50 > 10,000 mg/kg bw

-- NOAE L > 1000 mg/kg 40342906

-- 40342923 Practically non - toxic Insects Honey bee ( Apis mellifera L. ) LD 50 (contact) = > 650

ppm 40342938 Practically non - toxic

Freshwater fish2 Rainbow trout

( Oncorhynchus mykiss ) 96 - hour LC 50 = 5.4 mg/L 40342933

-- Moderately toxic Bluegill sunfish (Lepomis ma crochirus) 96 - hour LC 50 > 5.4 mg/L 40342934 Moderately toxic Carp (Cyprinus carpio) 96 - hour LC 50 = 2.5 - 6.4

mg/L (3 tests, different formulations) 40342936 Moderately toxic Fathead minnow (Pimephales promelas ) 96 - hour LC 50 = 4.8 mg/L

-- NOAEC 0.233 mg/L LOAEC = 0.486 mg/L 41841216

--- 43552001 Moderately toxic Freshwater invertebrates Water flea

( Daphnia magna ) 48 - hour EC 50 > 6.8 mg/L

-- NOAEC = 0.53 mg/L LOAEC = 1.1 mg/L 41841217

-- 4 1850807 Moderately toxic Estuarine/ marine fish Sheepshead

minnow ( Cyprinodon variegatus ) 96 - hour LC 50 > 6.1 mg/L 41841218 Moderately toxic Estuarine/ marine invertebrates My sid shrimp

(Americamysis bahia) 96 - hour EC 50 = 0.13

mg/L

-- NOAEC = 11.3 μg/L 41841220

-- 43511601 Highly toxicPage 20 of 45 Taxonomic Group Surrogate Species Acute Toxicity

-- Chronic Toxicity Citation MRID Acute Toxicity Classification LOAEC = 21.7 μg/L Eastern oyster (Crassostrea virginica) 96 - hour EC 50 > 1.5 mg/L 41841219 Moderately toxic Vascular Plants: Duckweed (Lemna gibba) Ti er 1: 8.01 mg/L (31%

reduction in frond count) Tier 2 42606622 Non - Vascular Plants: Salt Water Diatom ( Skeletonema costatum ) Tier 1: 8.01 mg/L (13%

grow th inhibition 42606623

Blue - green Algae ( A. flos - aquae ) Tier 1: 8.01 mg/L

(significantly growth effects) 42606621 Fresh Water Diatom ( Navicula pelliculosa ) Tier 1: 8.01 mg/L (58%

grow th inhibition Tier 1: 8.01 mg/L (no effect) 42606624 42606625 Aquatic plants and algae

Green Algae

(Selenastrum capricornutum) Tier 1: 8.01 mg/L (51%

grow th inhibition 41841224 Moderately toxic

1 Birds represent surrogates for terrestrial - phase amphibians and reptiles. 2 Freshwater fish may be surrogates for aquatic - phase amphibians. Flutolanil is registered for use in a number of co - formulated products. Other co formulated active ingredients include: chlorothalonil, mancozeb, thiophanate methylethoxy , and propicanazol. The potential for greater toxicity of the formulated product compared to the TGAI, acute was evaluated based on 8 acute oral toxicity stu dies with rats (MRID 40342906 = TGAI; MRID 40342907, 42255205, 43594004, 43971414, 45103901, 45136401, 45524003 = formulated products). Reported LD 50 values of the formulated products were > 5000 mg/kg or > 2000 mg/kg in 6 of the 7 formulated products. In onl y one study was a definitive LD 50 quantified (MRID 43594004 which tested a 38.8% chlorothalonil + 10.3% flutolanil formulation) . This study reported a LD 50 of 3940 mg/kg for female rats and 1570 mg/kg for male rats . Compared to the toxicity of the TGAI (LD 50 > 10,000 mg/kg), the formulated products does not appear to be substantially greater in toxicity on an acute oral basis to the rat , since LD50 values were > 2000 mg/kg (practically nontoxic) for 6 of the 7 formulations. In the remaining study that tested a mixture of chlorothalanil and flutolanil (MRID 43594004), the formulation was practically nontoxic to females and only slightl y t oxic to males. Appropriate data for comparing the toxicity formulated product with the TGAI were not identifie d for other non - target species. Based on these comparisons with the rat, there does not appear to be evidence of substantially greater toxicity of the formulated products compared to the TGAI. Based on these findings, this problem formulation will focus on ecological risks associated with the TGAI .Page 21 of 45



### B. Ecosystems Potentially at Risk The ecos ys tems potentially at risk are often extensive in scope, therefore, it may not be possible to identify specific ecos ys tems during the development of a nation - wide ecological risk assessment. However, in general terms, terrestrial ecos ys tems potentially at risk could include the treated field and areas immediately adjacent areas that may receive drift or runoff. Areas adjacent to the treated field could include cultivated fields, fencerows and hedgerows, meadows, fallow fields or grasslands, woodlands, riparian habitats and other uncultivated areas. Aquatic ecos ys tems potentially at risk include water bodies adjacent to, or down stream from, the treated field and might include impounded bodies such as ponds, lakes and reservoirs, or flowing waterway s such as streams or rivers. For uses in coastal areas, aquatic habitat also includes marine ecos ys tems, including estuaries. A preliminary review of the Ecologic al Incident Information System (EII S) maintained by the Agency ’s Office of Pest icide Programs (OPP) indicates only one reported ecological incident associated with the use of flutolanil (Incident ID I014123 - 001) . However, the observed effect (yellowing an d stunting of 40 acres of oats) was thought to be more likel y due to fertility issues than the pesticide containing flutolanil and is classified as ‘unlikely .’ 

## V. As sessment End points Assessment endpoints represent the actual environmental value that is to be protected, defined b y an ecological entity (species, community , or other entity) and its attribute or characteristics (EPA , 1998). For flutolanil, the ecological entities include the following: birds, reptiles, terrestrial - phase amphibians, mammal s, freshwater fish, freshwater aquatic - phase amphibians and invertebrates, estuarine/marine fish and invertebrates, terrestrial plants, insects, and aquatic plants and algae. The attributes for each of these entities include growth, reproduction, and survi val. 

## VI. Conceptual Model For a pesticide to pose an ecological risk, it must reach ecological receptors in biologicall y s ignificant concentrations. An exposure pathway is the means by which a pesticide moves in the environment from a source to an ecological receptor. For an ecological pathway to be complete, it must have a source, a release mechanism, an environmental transport medium, a point of exposure for ecological receptors, and a feasible route of exposure. The conceptual model for flutolanil provides a written description and visual representation of the predicted relationships between flutolanil, potential routes of exposure, and the predicted effects for the assessment endpoint. According to EPA’s ecolog ical risk assessment guidelines (USEPA 1998) a conceptual model consists of twoPage 22 of 45

major components: a risk hy pothesis and a conceptual diagram 

### A. Risk Hypothesis A risk hy pothesis describes the predicted relationship among the stressor, exposure, and assessment endpoint response along with the rationale for their selection. For flutolanil, the following ecological risk hypothesis is being emplo yed for this national - level ecological risk assessment: Flutolanil

, when us ed in accordance with current labels, can result in off -site movement of the compound via runoff, spray drift, and eroded soil leading to exposure of nontarget plants and animals. Furthermore, the high environmental persistence of flutolanil and its high K OA suggest a potential for bioaccumulation in terrestrial food webs, although such evidence is indirect. These potential exposure pathway

s may result in adverse effects upon the survival, growth, and reproduction of non - target terrestrial and aquatic organisms. These nontarget organisms include Federally- listed threatened and endangered species. 

### B. Conceptual Diagram The environmental fate properties of flutolanil indicate that runoff, erosion, and spray drift represent p otential transport mechanisms of flutolanil to aquatic and terrestrial organisms. In addition, its high environmental persistence combined with a large KOA suggest that atmospheric transport and subsequent deposition may be a potential exposure pathway for flutolanil, although existing evidence is indirect and inconclusive (indicated by the dashed lines in Figures 1 and 2 . These transport mechanisms ( e.g . sources) are depicted in the conceptual models below ( Figures 1 and 2 ) and result in the movement of f lutolanil into aquatic (water) and terrestrial (soil and foliage) habitats which in turn serve as exposure media for a broad range of biological receptors of concern (nontarget animals) and the potential attribute changes, i.e. , effects such as reduced sur vival, growth and reproduction, in the receptors due to flutolanil exposure.Page 23 of 45

Figure 1 . Conceptual model for flutolanil effects on aquatic organisms . 

### Stressor Source

Receptors

Attribute Change Flutolanil applied to use site

Spray drift

Fish/aquatic - phase amphibians Eggs Larvae Juveniles / Adults Individual organisms Reduced survival Reduced growth Reduced reproduction Food chain Reduction in algae Reduction i n prey Habitat integrity Reduction in primary productivity Reduced cover Community change Surface water/ Sediment Runoff

Aquatic Animals In vertebrates Vertebrates 

### Exposure Media Uptake/gills

or integument Ingestion In gestion Soil Ground water

Uptake/gills or integument Aquatic Plants

Non - vascular Vascular Uptake/cell, roots, leaves Riparian plant terrestrial exposure pathways see Figure 2Page 24 of 45

Figure 2 . Conceptual Model of Flutolanil Effects on Terrestrial Organisms. 

### Stressor Source

Receptors

Attribute Change Flutolanil ap plied to use site

Direct application Spray drift

Birds / Terrestrial phase amphibians / reptiles / mammals Terrestrial insects

Individual organisms Reduced survival Reduced growth Reduced reproduction Food chain Reduction in prey Habitat integrity Reduction in primary productivity Reduced cover Community change Terrestrial/riparian plants grasses/forbs, fruit, seeds (trees, shrubs) Runoff

Mammals 

### Exposure Media Soil

In gestion In gestion In gestion In gestion Dermal uptake/Ingestion Root uptake

Terrestrial food web In gestionPage 25 of 45



## VII. An al ys is Plan In order to address the risk hypothesis, the potential for adverse effects on the environment is estimated. The use, environmental fate, and ecological effects of flutolanil are characterized and integrated to assess the risks. This is accomplished using a risk quotient (ratio of exposure concentration to effects concentration) approach. Although risk is often de fined as the likelihood and magnitude of adverse ecological effects, the risk quotient - based approach does not provide a quantitative estimate of likelihood and/or magnitude of an adverse effect. However, as outlined in the Overview Document (USEPA , 2004) , the likelihood of effects to individual organisms from particular uses of flutolanil is estimated using the probit dose - response slope and either the level of concern (discussed below) or actual calculated risk quotient value. This analy sis plan will b e revisited and may be revised depending upon the information submitted by the public in response to the opening of the Registration Review docket for flutolanil . 

### A . Stressors of Concern The most significant degradate of flutolanil is DIP . Submitted environmental fate studies for flutolanil do not identify DIP , as it does not form >10% of residues, indicating that it is not expected to be a major degradate of flutolanil in aquatic and terrestrial environments. The Agency concluded that only the parent compound needs to be included in the drinking water exposure assessment for flutolanil , DIP may not be of greater toxicological concern compared to flutolanil and exposure to this transformation product may not be included in this assessment . The stress ors of concern for this assessment includes only the parent compound (flutolanil) with respect to e xposures in aquatic and terrestrial habitats . 

### B . Measures of Exposure In order to estimate risks of flutolanil expos ures in aquatic and terrestrial environments, all exposure modeling and resulting risk conclusions will be based on maximum application rates and methods cited in Table 3 and will be estimated for each use of flutolanil. Measures of exposure are based on aquatic and terrestrial models that predict estimated environmental concentrations (EECs) of flutolanil . The models used to predict aquatic EECs are the Pesticide Root Zone Model coupled with the Exposure Analy sis Model S ys tem (PRZM/EXAMS). The model used to predict terrestrial EECs on food items is T - REX. The model used to derive EECs relevant to terrestrial and wetland plants is TerrPlant. These models are parameterized using relevant reviewed registrant - submitted environmental fate data.Page 26 of 45

PRZM (v3.12 . 2 , May 200 5) and EXAMS (v2.98. 4 .6 , April 2005 ) are screening simulation models coupled with the input shell pe 5.pl (Aug 200 7 ) to generate dail y exposures and 1 - in - 10 year EECs of flutolanil that may occur in surface water bodies adjacent to application sit es receiving flutolanil through runoff and spray drift . PRZM simulates pesticide application, movement , and transformation on an agricultural field and the resultant pesticide loadings to a receiving water body via runoff, erosion and spray drift. The E XAMS model simulates the fate of the pesticide and resulting concentrations in the water body . The standard scenario used for ecological pesticide assessments assumes application to a 10 - hectare agricultural field that drains into an adjacent 1 - hectare water body that is 2 meters deep (20,000 m 3 volume) with no outlet. PRZM/EXAMS is used to estimate screening - level exposure of aquatic organisms to flutolanil . The measure of exposure for aquatic species is the 1 - in - 10 year return peak or rolling mean conc entration. The 1 - in - 10 year peak is used for estimating acute exposures of direct effects to aquatic organisms. The 1 - in - 10 - ye ar 60 - day mean is used for assessing chronic exposure to the fish and aquatic - phase amphibians. The 1 - in - 10 - ye ar 21 - day mean is u sed for assessing aquatic invertebrate chronic exposure . Exposure estimates for terrestrial animals assumed to be in the target area or in an area exposed to spray drift are derived using the T - REX model (version 1.3.1, 12/07/2006). This model incorporates the Kenega nomograph, as modified by Fletcher et al. (1994), which is based on a large set of actual field residue data. The upper limit values from the nomograph represented the 95 th percentile of residue values from actual field m easurements (Hoerger and Kenega , 1972). The Fletcher et al. (1994) modifications to the Kenega nomograph are based on measured field residues from 249 published research papers, including information on 118 species of plants, 121 pesticides, and 17 chem ical classes. EECs for terrestrial plants inhabiting dry and wetland areas are derived using TerrPlant (version 1.2.2, 12/26/2006). This model uses estimates of pesticides in runoff and in spray drift to calculate EECs. EECs are based upon solubility, a pplication rate and minimum incorporation depth. Two spray drift models, AGDisp and AgDRIFT are used to assess exposures of terrestrial plants to flutolanil deposited on terrestrial habitats by spray drift. AGDisp (version 8.13; dated 12/14/2004) (Tes ke and Curbishley , 2003) is used to simulate aerial and ground applications using the Gaussian far - field extension. AgDrift (version 2.01; dated 5/24/2001) is used to simulate spray blast applications to orchard crops.Page 27 of 45



### C . Measures of Effect Ecological effect data are used as measures of dir ect and indirect effects to biological receptors . Data were obtained from registrant - submitted studies or from literature studies identified by ECOTOX. The ECOTOXicology database (ECOTOX) was searched on May 1, 2008 in order to provide more ecological effects data to bridge existing data gaps. ECOTOX is a source for locating single chemical toxicity data and potentially chemical mixture toxicity data for aquatic life, terrestrial plants, and wildlife. ECOTOX was created and is maintained by the USEPA, Office of Research and Development, and the National Health and Environmental Effects Research Laboratory's Mid - Continent Ecology Division (ECOTOX, 2006). In formation on the potential effects of flutolanil on non - tar get animals is also collected from the Ecological Incident Information System (EIIS; USEPA 2007 c ). The EII S is a database containing adverse effect (typically mortality) reports on non - target organisms where such effects have been associated with the us e of pesticides. Where available, sublethal effects observed in both registrant - submitted and open literature studies will be evaluated qualitatively . Such effects have included behavioral changes ( e.g. , lethargy , changes in coloration and effects ol faction). Quantitative assessments of risks, though, are limited to those endpoints that can be directly linked to the Agency ’s assessment endpoints of impaired survival, growth and reproduction. The assessment of risk for direct e ffects to non - target organisms makes the assumption that toxicity of flutolanil to birds is similar to terrestrial - phase amphibians and reptiles . The same assumption is made for fish and aquatic - phase amphibians . The acute measures of effect use d for animals in this screening - level assessment are the LD 50 , L C 50 and EC 50 . LD stands for "Lethal Dose", and LD 50 is the amount of a material, given all at once, that is estimated to cause the death of 50% of the test organisms. L C stands for “Lethal Concentration” and L C 50 is the concentration of a chemical that is estimated to kill 50% of the test organisms. EC stands for “Effective Concentration” and the EC 50 is the concentration of a chemical that is estimated to produce a specific effect in 50% of the te st organisms. Endpoints for chronic measures of exposure for listed and non - listed animals are the NOAEL/NOAEC and NOEC. NOAEL stands for “No Observed - Adverse - Effect - Level” and refers to the highest tested dose of a substance that has been reported to have no harmful (adverse) effects on test organisms. The NOAEC ( i.e. , “No - Observed - Adverse - Effect - Concentration”) is the highest test concentration at which none of the observed effects were statisticall y different from the control. The NOEC is the No - Obse rved - Effects - Concentration. For non - listed plants, only acute exposures are assessed ( i.e. , EC 25 for terrestrial plants and EC 50 for aquatic plants); for listed plants, either the NOAEC or EC 05 is used.Page 28 of 45



### D . Integration of Exposure and Effects Risk characterization is the integration of exposure and ecological effects characterization to determine the potential ecological risk from the use of flutolanil on rice, peanuts, potatoes, turf and ornamentals, and the likelihood of direct and indirect effects t o non - target organisms in aquatic and terrestrial habitats. The exposure and toxicity effects data are integrated in order to evaluate the risks of adverse ecological effects on non - target species. For the assessment of flutolanil risks, the risk quotient (RQ) method is used to compare exposure and measured toxicity values. EECs are divided by acute and chronic toxicity values. The resulting RQs are then compared to the Agency ’s levels of concern (LOCs) (USEPA , 2004). These criteria are used to indicat e when the use of flutolanil , as directed on the label, ha s the potential to cause adverse direct or indirect effects to nontarget organisms .

1. Deterministic and Probabilistic Assessment Methods The quantitative assessment of risk wi ll primarily depend on the deterministic point - estimate based approach described in the risk assessment. Should further refinement of the risk assessment be deemed necessary , an effort will be made to further qualitatively describe risk using probabilisti c tools that the Agency has developed. These tools have been reviewed by FIFRA Scientific Advisory Panels and have been deemed as appropriate means of refining assessments where deterministic approaches have identified risks. 

### E. Endangered Species Asses sments Consistent with the Agency ’s responsibility under the Endangered Species Act (ESA), EPA will evaluate risks to Federall y- listed threatened and/or endangered (listed) species from registered uses of flutolanil . This assessment will be conducted i n accordance with the Overview Document (USEPA , 2004) , provisions of the E SA , and the Services’ Endangered Species Consultation Handbook (USFWS/NMFS 1998) . T he assessment of effects associated with registrations of flutolanil is based on an action area. The action area is considered to be the area directly or indirectly affected by the federal action, as indicated b y the exceedance of Agency Levels of Concern (LOCs) used to evaluate direct or indirect effects. The Agency ’s approach to defining the acti on area under the provisions of the Overview Document (USEPA , 2004) considers the results of the risk assessment process to establish boundaries for that action area with the understanding that exposures below the Agency ’s defined LOCs constitute a no - effe ct threshold. For the purposes of this assessment, attention will be focused on the footprint of the action ( i.e. , the area where flutolanil application occurs), plus all areas where offsite transport ( i.e. , spray drift, runoff, long - range atmospheric transport, etc.) may result in potential exposure that exceeds the Agency’s LOCs. Specific measures of ecological effect that define the action area for listed species include any di rect and indirect effects and/or potential modification of its critical habi tat, including reduction inPage 29 of 45

survival, growth, and reproduction as well as the full suite of sublethal effects available in the effects literature. Therefore, the action area extends to a point where environmental exposures are below any m easured lethal or sublethal effect threshold for any biological entity at the whole organism, organ, tissue, and cellular level of organization. In situations where it is not possible to determine the threshold for an observed effect, the action area is not spatially limi ted and is assumed to be the entire United States. As part of the “effects determination , ” one of the following three conclusions will be reached regarding the potential for registration of flutolanil at the use sites described in this document to aff

ect listed species and/or result in modification of designated listed species’ critical habitat: · “No effect”; · “ May affect, but n ot likely to adversel y a ffect”; or · “May affect and l ikely to adversel y affect”. Critical habitat identif

ies specific areas that have phy sical and biological features, known as primary constituent elements ( PCEs) , which are essential to the conservation of the listed species. If the results of initial screening - level assessment methods show no direct or indirect effects (no LOC exceedances) upon individual listed species of any taxonomic group or upon the PCEs of the species’ designated critical habitat, a “no effect” determination is made for the FIFRA regulatory action regarding flutolanil as it relates to this species and its designated critical habitat. If, however, direct or indirect effects to individual listed species are anticipated and/or effects may impact the PCEs of the listed species’ designated critical habitat , a preliminary “may affect” determination is made f or the FIFRA regulatory action regarding flutolanil . If a determination is made that use of flutolanil within the action area(s) associated with the listed species “may affect” this species and/or its designated critical habitat, additional information i s considered to refine the potential for exposure and for effects to the species and other taxonomic groups upon which these species depend. Additional information, including spatial anal ys is (to determine the geographical proximity of species habitat and flutolanil use sites) may also be used to determine whether modification to designated critical habitat may occur. Based on the refined information, the Agency uses the best available information to distinguish those actions that “ may affect, but are not likely to adversel y affect” from those actions that “may affect and are likel y t o adversel y affect” the listed species and/or result in modification of its d esignated critical habitat.Page 30 of 45



### F. Preliminary Identification of Data Gaps

1. Environmental Fate Several studies have been submitted to fulfill the conditional registration requesting soil photol ys is, aerobic soil metabolism, soil storage stability , and terrestrial field dissipation data for flutolanil . These studies are under review. The resulting data will be incorporated into future flutolanil assessments as appropriate. In order to quantify the risk potential for flutolanil , additional studies are required (anaerobic soil metabolism , e nvironmental chemical m ethods (ECM)/Independent Laboratory Validation (ILV) and measurement of octanol - air partition coefficient (KOA) ). The lack of data mentioned above for flutolanil represents an uncertainty o f the fate of flutolanil in th e environment. Table 7 includes the current environmental fate data requirements. Table 7 . Environmental Fate Data Requirements for Flutolanil. Guide line # Data Requirement Study ID Study Classification Are Additional

Data Need ed for Risk Assessment? 161 - 1 Hydrolysis 40342940 Acceptable No 161 - 2 Photo lysis in Water 41841208 41841209 Acceptable No 161 - 3 Photodegradation on Soil 41841210 43175810 Unacceptable Under review No 161 - 4 Photodegradation in Air No data submitted N/A No 162 - 1 Aerobic Soil Metabolism 40342941 40342942 45756601 Acceptable Irrelevant (publication for benthiocarb) Under review No 162 - 2 Anaerobic Soil Metabolism No data submitted N/A Yes 162 - 3 Anaerobic Aquatic

Metabolism 41841211 Acceptable No 162 - 4 Aerobic Aquatic Metabolism 41841212 Acceptable No 163 - 1 Leaching - Adsorption/

Desorption 42606626 42606627 40342943 41841213 Acceptable Acceptable Acceptable Acceptable No 163 - 2 Laboratory Volatility No data submitted N/A No 163 - 3 Field Volatility No data submitted N/A No 164 - 1 Terrestrial Field Dissipation 41837803 4317580 4 43175809 45756603 45756602 Unacceptable Acceptable Supplemental Under review Under review NoPage 31 of 45

Guide line # Data Requirement Study ID Study Classification Are Additional

Data Need ed for Risk Assessment? 164 - 2 Aquatic Dissipation 42606618 43292603 Acceptable Unacceptable No 164 - 3 Forestry No data submitted N/A No 164 - 4 Combination and Tank

Mixes No data submitted N/A No 164 - 5 Long - term Soil Dissipation 43175804 Supplemental No 165 - 3 Accumulation in I rrigated Crops 42606615 Acceptable No 165 - 4 Accumulation in Fish 403 42944 41841214 41841215 Acceptable Acceptable Acceptable No 165 - 5 Aquatic Non - target

Organism 42641101 Acceptable No 166 - 1 Gr ound Water Monitoring No data submitted N/A Waived on 2/22/95

Storage Stability 42606616 Under review No Environmental Chemic al Methods (ECM)/I

ndependent Laboratory Validation (ILV) No data submitted N/A Yes Non Guideline Study Measurement of Octanol Air Partition Coefficient (KOA) No data submitted N/A Yes N/A=Not Applicable 2. Ecological Effects The ecological effects data requirements and preliminary classification of the submitted data for flutolanil are summarized in Table 8 . The ecological effects data requirements were determined according to CFR Part 158 data requirements for conventional pesticides (Federal Regi ster, Vol. 72 : 60934 - 60988. October, 26, 2007 ) . In cases where the data requirement was not met with an acceptable study , but the results of a new study would appear to not likely change the forthcoming risk assessment , the study was kept in ‘reserve.’ F or example, while the new CFR Part 158 require an avian oral LD50 study with a passerine species, this study is being held in reserve because the submitted data indicate that flutolanil is practically non - toxic on an acute basis to mallard and bobwhite quail. Thus, passerine birds would have to be several orders of magnitude more sensitive to flutolanil in order to impact the ecological risk assessment, which appears unlikel y given the typical variability i n toxicity among avian species. Similarly , while the estuarine acute LC50 study on o ys ters is now considered supplemental (reclassification as part of this registration review), the likelihood that oy sters would be more sensitive than the most sensitive invertebrate (mysid shrimp) appears low and thus, a repeated test is not recommended at this time. In the case of the Tier II plant seedling emergence and vegetative vigor studies, requirement of these studies depends on thePage 32 of 45

outcome of the yet to be submitted Tier 1 studies ; hence, they are being held in reserve . Table 8 . Ecological Effects Data Requirements for Flutolanil. Guideline Data Requirement Test Species MRID Preliminary Study Classification More Data

Needed For Risk Assessment ? 71 - 1 (850.2100) Avian Oral LD 50 Mal lard Bobwhite Quail Passerine Species 40342929

40342930 No data Acceptable

Acceptable No data No

No Reserved (5) 71 - 2 (850.2100) Avian Dietary LC 50 Mallard Bobwhite Quail 40342931

40342932 Acceptable

Acceptable No 71 - 4 (850.2300) Avian Reproduction Mallard Bobwhite Quail 42932302

42932301 Acceptable

Acceptable No

72 - 1 (850.1075) Freshwater Fish

LC 50 Rainbow Trout

Bluegill Sunfish Carp Fathead Minnow 40342933

40342934 40342936 41841216 Acceptable

Acceptable Supplemental Acceptable No

72 - 2 (8 50.1010) Freshwater

Invertebrate Acute LC 50 Water flea 41841217 Acceptable No 72 - 3(a) (850.1075) Estuarine/Marine

Fish LC 50 Sheepshead

Minnow 41841218 Acceptable ( 3 ) No 72 - 3(b) (850.1025 or 1055) Estuarine/Marine

Mollusk EC 50 Eastern Oyster 41841 219 Supplemental (4) Reserved (6) 72 - 3(c) (850.1035 or 1045) Estuarine/Marine

Shrimp EC 50 My sid S hrimp 41841220 Acceptable No 72 - 4(a) (850.1400) Freshwater Fish

Early Life - Stage Fathead Minnow 43552001 Acceptable No 72 - 4(b) (850.1300) Aquatic

Invertebrate Life Cycle (freshwater) Water flea 4 1850807 Acceptable No 72 - 4 Estuarine/Marine Sheepshead No Data No data Reserved (7 )Page 33 of 45

Guideline Data Requirement Test Species MRID Preliminary Study Classification More Data

Needed For Risk Assessment ? (850.1400) Fish Early Life

Stage (1) Minnow No Guideline Available (1) Whole Sediment

Chronic Invertebrate Marine No Data No data Yes 123 - 2 (850.4150) Vegetative Vigor

(Tier I) Multiple species No Data No Data Yes 123 - 2 (850.4100) Seedling

Emergence (Tier I) Multiple species No Data No Data Yes 123 - 2 (850.4150) Vegetative Vigor

(Tier II) (1) Multiple species N o Data No Data Reserved (2) 123 - 2 (850.4100) Seedling

Emergence (Tier II) (1) Multiple species No Data No Data Reserved (2) (850.4400) Aquatic Vascular

Plant (Tier I) Duckweed 42606622 Acceptable No

Freshwat er Diatom 42606624

42606625 Acceptable

Acceptable No Blue - green Algae 42606621 Acceptable No Salt Water Diatom 42606623 Acceptable No (850.5400) Aquatic

Nonvascular (Tier I) Green algae 41841224 Acceptable No (850.5400) Aquatic

Nonvascular (Tier II) (1) Freshwater

Diatom Green A lgae No Data No Data Reserved ( 8 ) (850.3020) Honey Bee Acute

Contact Honey bee 40342938 Acceptable No (1) Conditionally required per Pesticide Data Requirements for Conventional Chemicals. CFR Part 158. Federal Register. Vol. 72 (No. 207): 60934 - 60988. Octob er, 26, 2007. (2) Conditionally required pending results of Tier 1 plant testing. (3) Study likely to be reclassified from “supplemental” to “acceptable” (4) Study likely to be reclassified from “acceptable/core” to “supplemental.”Page 34 of 45

(5) Reserved pending results from review of other information (e.g., literature review, data from compounds with the same modes of action) that suggests Passerine species may be substantially more sensitive than upland game or waterfowl avian species such that the risk assessment conclusions wou ld be affected by additional data for Passerines . (6) Reserved pending other information (e.g., literature review, data from compounds with the same mo des of action) that suggest s mo llusks may be sensitive to flutolanil such that the risk assessments conclusio ns would be affected by additional data for mollusks. (7) Reserved pending other information (e.g., literature review, data from compounds with the same mo des of action) that suggest s estuarine/marine fish may be sensitive to flutolanil such that the risk asse ssments conclusions would be affected by additional data for estuarine/marine fish. (8) Reserved pending other information (e.g., literature review, data from compounds with the same mo des of action) that suggests aquatic plants are substantially more sensitiv e com pared to existing Tier 1 tests such that the risk assessment conclusions would be affected by additional data for aquatic plants. 3. Rationale for Data Call In As part of the conditional registration of Moncoat MZ (PCC511) use on potato seed pieces on February 22, 2001(EPA Reg. No. 71711 - 8), EPA requested the registrant to conduct and submit nine ecotoxicity studies related to flutolanil ty pical end use product (TEP) and TGAI: (TEP) Acute avian oral (71 - 1) Acute avian dietary

– mallard (71 - 2 ) Avian reproduction (71 - 4) Acute Freshwater Fish (72 - 1) Acute freshwater invertebrate (72 - 2) Chronic life cycle / estuarine invertebrate (72 - 4) (TGAI) Acute estuarine/marine fish (72 - 3) Chronic freshwater fish life cycle (72 - 5) Chronic marine fis h life cycle (72 - 5) The TEP studies were requested to address uncertainty in the combined toxicity of the co - formulated product (containing both mancozeb and flutolanil). The TGAI acute LC 50 study with an estuarine/marine fish was requested because the s ubmitted study with sheepshead minnow as classified as supplemental (MRID 41841218). The TGAI chronic life cycle studies were requested on the basis of EECs triggering full life cycle studies when compared to the ELS study with fathead minnow. In respo nse to this ecotoxicity data request, the registrant (Nichino America, Inc.) submitted a waiver request of the data requirements to the Agency on Sept 9 th , 2002. Part of the rationale for requesting a waiver from the TEP studies was that there was no evid ence to support the synergistic action of the two active ingredients in the co formulated product. The Agency has evaluated this waiver request and conducted its own comparison of TGAI vs. TEP toxicity (see Section IV.A above) and agrees that additional s tudies of the TEP are not required for the ecological risk assessmentPage 35 of 45

supporting the registration review of flutolanil. The Agency has also re - evaluated the need to conduct the full life cycle studies with the TGAI and does not believe that absence of the se data will hinder the ecological risk assessment. Finall y, with respect to the acute toxicity test with sheepshead minnow (MRID 41841218), the Agency has re reviewed this study and has upgraded this study to acceptable due to lack of toxicity at the solubility limit of flutolanil. The Agency has identified other environmental fate and ecological effects data that are needed to reduce major sources of uncertainty in the ecological risk assessment of flutolanil. These data needs and associated rationale are provided in Table 9 . Table 9 . Environmental Fate and Ecological Effects Data Needs for Flutolanil. Environmental F ate D ata G aps OPPTS Guideline Study Title Cost (if special study) Rationale 835 - 4200 Guideline 16 2 - 2

Anaero bic Soil Metabolism N/A CFR158 requires this study. Currently no acceptable studies have been submitted. Flutolanil can be used on potatoes, rice, peanuts, turf, and ornamentals. Since no information is available to determine the fate properties EFED m

ust assume that it will runoff/drift in the environment and persist. In order to calculate EEC’s in PRZM and assess the ecological risk and the drinking water risk, anaerobic soil data are needed. Environmental chemical Methods (ECM)/Independent Labor atory Validation (ILV) N/A CFR158 indicates that ECM used to generate data associated with terrestrial field dissipation study (835.6100), aquatic dissipation study (835.6200), forestry dissipation (835.6300), ground water mo nitoring (835.7100), and aquati c non target organism field dissipation (850.1950) studies must include results of a successful confirmation method trial by and independent laboratory (ILV). Currently no acceptable studies have been submitted. In order to use the data with confidence in the terrestrial dissipation, aquatic dissipation, and aquatic non - target organism field accumulation studies as well as assess the ecological risk, ECM and ILV data are needed. Non Guideline Study Measurement of Octanol Air Partition Coefficient (KOA) N/A Recent peer - reviewed studies in the scientific literature indicate that KOA is an important factor in assessing the potential of organic chemicals to bioaccumulate and biomagnify i n terrestrial food chains (e.g., Armitage and Gobas, 2007; Kelly et al ., 2007; Czub and McLachlan, 2004; Kelly and Gobas, 2003;Page 36 of 45 Sharp and Mackay, 2000; McLachlan, 1996). No measured data on the KOA of flutolanil were found. However, model - predicted log KOA for flutolanil is high (10.6) based on EFED’s EPI suite program, ver . 3.20. Measured data on KOA are being requested in order to confirm model - predicted values of KOA , which may be uncertain. This measurement is very important in evaluating the potential for flutolanil to bioaccumulate in terrestrial food chains. Ecotox icity Data Gaps OPPTS Guideline Study Title Cost (if special study) Rationale

No Guideline Available (1) Chronic, Whole

Sediment Invertebrate Toxicity N/A According to 40CFR Part 158, the use patterns, physical - chemical properties and available toxicity data of flutolanil qualify it for a conditionally - required chronic sediment toxicity test. Specifically, the anaerobic metabolism half life of flutolanil is > 13 years (far exceeding the 10 days criterion for a chronic sediment test). Further, both the log KOW (3.7) and KOC (up to 1300) exceed thresholds for chronic sediment testing (3.0 and 1000, respectively). Finally, there is concern over estuarine/marine benthic invertebrates due to their demonstrated high sensitivity to flutolanil in water column tests (most sensitive aquatic species tested; EC50 and NOAECs of 130 and 11.3 ppb, respectively). Therefore, results of the recommended chronic sediment toxicity testing could reasonably be expected to have a significant impact on the ecological risk asse ssment of flutolanil. Currently, there are no sediment toxicity data submitted for flutolanil. 123 - 2 (850.4150) Vegetative Vigor (Tier I) N/A

123 - 2 (850.4100) Seedling Emergence (Tier I) N/A Currently, no data are available on the toxicity of flutolanil to terrestrial plants. Screening (Tier I) studies are being recommended to address uncertainty regarding the potential impacts of flutolanil to non - target terrestrial plants. Such studies are required as outlined in 40CFR Part 158 and are required in order to assess risks associated with flutolanil uses on terrestrial plants. These results are also needed for endangered species assessment for flutolanil. (1) Other non - OPPT test guidelines are available for conducting assessing sediment chronic to xicity. Registrant should submit study protocol to EPA for review prior to initiation of testing.Page 37 of 45



## VIII. Bibliography A. Fate References MRID 40342940 . Dal y, D.; Ediger, K. (1987) W14 Hydroly sis of [Carbon 14] - Fluto lanil as a Function of pH at 25 [d egrees]C: ABC Final Report #35399. Unpublished study prepared by Anal yt ical Bio - Chemistry Laboratories, Inc. 28 p. MRID 41841208 . Carpenter, M.; Fennessey , M. (1991) Determination of Photodegradat - ion of [Carbon 14 - Flutolanil] in Aqueous Solution: L ab Project Number: 35176R: E642 - 01 - 87. Unpublished study prepared by Analy tical Bio - Chemistry Laboratories, Inc. 41 p. MRID 41841209 . Bashir, M. (1991) Identification of Degradation Products of Flutol anil in an Aqueous Photosensitized Solution: Lab Project Number: 38426: E642.01.87. Unpublished study prepared by Anal yt ical Bio - Chemistry Laboratories, Inc. 34 p. MRID 41841210 . Carpenter, M. (1991) "Determination of the Photolysis Rate of Flut olanil on the Surface of Soil": Lab Project Number: 38480: 500AU Unpublished study prepared b y Anal yt ical Bio - Chemistry Laborato - ries, Inc. 33 p. MRID 43175810 . Hallberg, C. (1994) Determination of the Photolysis Rate of Flutolanil on the Surface of Soil: Amendment 1: L ab Project Number: 38480: 500AU . Unpublished study prepared by ABC Laboratories, Inc. 24 p. MRID 40342941 . Aizawa, H. (1982) W20 - Flutolanil: Decomposition Test of Flutolanil in Soil: L aboratory Project ID No. 56 - 076 - (3). Unpublished study prepared by Mitsubishi - Kasei Institute of Toxicological and Environmental Sciences. 38 p. MRID 40342942 . Nakamura, Y.; Ishikawa, K.; Kuwatsuka, S. (1977) Degradation of benthiocarb in soils as affected b y s oil conditions. Journal of Pesticide Science 2:7 - 16. MRID 45756601 . Swanson, M. (1 996) Aerobic Soil Metabolism of (Carbon 14) - Flutolanil: Final Report: Lab Project Number: A55786/W70: SC920104: 520 AU. Unpublished study prepared by Battelle Columbus Operations. 137 p. MRID . 41841211 . Dal y, D.; Williams, M. (1991) Anaerobic Aquatic Metabolism of [Carbon 14] - Flutolanil: Lab Project Number: 36762: E642.02.88. Unpublished study prepared b y Anal yt ical Bio - Chemistry Laboratories, Inc. 71 p. MRID 41841212 . Dal y, D. (1989) "Aerobic Aquatic Metabolism of [Carbon 14] - Flutola - nil: Lab Project Number: 36763. Unpublished study prepared by Analy tical Bio Chemistry Laboratories, Inc. 42 p.Page 38 of 45

MRID 40342943 . Dal y, D. (1987) W13 - Soil/Sediment Adsorption - Desorption with [Car - bon 14] - Flutolanil: ABC Final Report #35398. Unpublished study p repared b y Analy tical Bio - Chemistry Laboratories, Inc. 52 p. MRID 41841213 . Dal y, D. (1991) "Soil/Sediment Adsorption - Desorption of Soil Incor porated [Carbon 14] - Flutolanil Following Aerobic Aging": Lab Project Number: 37793: E642.03.89. Unpublish ed study prepared by Analy tical Bio - Chemistry Laboratories, Inc. 35 p. MRID 42606626 . Williams, M.; Heim, L . (1992) Soil/Sediment Adsorption - Desorption of (Carbon 14) - Desisopropyflutolanil: Lab Project Number: 40410. Unpublished study prepared b y A BC Labs, Inc. 58 p. MRID 42606627 . Williams, M.; Berghaus, L. (1992) Soil/Sediment Adsorption Desorption of (Carbon 14) - Flutolanil: Lab Project Number: 40130. Unpublished study prepared b y A BC Labs, Inc. 58 p. MRID 41837803 . Castro, L . (1991) Dissipation of Flutolanil on Bare Soil Following Application of Flutolanil 50 WP, USA, 1989: L ab Project Number: R642.07.89. Unpublished study prepared by NOR - AM Chemical Co. 63 p. MRID 41837804 . Castro, L . (1991) Dissipation of Flutolanil in Soil followi ng Application of Flutolanil 50WP to Turf, USA, 1989: L ab Project Number: R642.10.89: 38122. Unpublished study prepared by Nor - Am Chemical Co. in assoc. with ABC Laboratories, Inc. 65 p. MRID 43175809 . Castro, L . (1993) Dissipation of Flutolanil in S oil Following Application of SN 84364 50WP To Peanuts, USA, 1988: Lab Project Number: R642.04.88. Unpublished study prepared by NOR - AM Chemical Co. (Analy tical Services Dept. and Residue Chemistry Dept.). 84 p. MRID 45756602 . Castro, L . (1994) Dissipation of Flutolanil on Bare Soil Following Application of Flutolanil 50 WP: L ab Project Number: FLUTOLANIL/W43: R642.07.89: B002392. Unpublished study prepared by Nor - Am Chemical Company . 97 p. MRID 45756603 . Castro, L . (1995) Dissipation of Flutolanil in Soil Following Application of Flutolanil 50 WP to Turf, USA, 1998: L ab Project Number: 38122: B002400: R642.10.89. Unpublished study prepared by ABC Laboratories, Inc. and AgrEvo Research Center. 117 p. MRID 42606618 . Castro, L . (1992) Aquatic Field Dissipation of Flutolanil following Use at Highest Recommended Label Rates in Rice: L ab Project Number: R642.06.89. Unpublished study prepared by NOR - AM Chemical Co. and ABC Labs. 138 p.Page 39 of 45

MRID 43292603 . Castro, L . (1993) Flutolanil/W62: Aquatic Field Dissipation of Flutolanil Following Application of MONCUT 50WP to Rice at Highest Recommended Label Rates, USA, 1991: L ab Project Number: AU/91R/03. Unpublished study prepared by NOR - AM Chemical Co., Residue Chemistry Dept. 94 p. MRID 43175804 . Castro, L . (1993) Long - Term Field Dissipation of Flutolanil under Conditions of Peanut Cultivation Initiated 1989, USA: L ab Project Number: R642.08.89. Unpublished study prepared by NOR - AM Chemical Co.; ABC Laboratories. 114 p. MRID 42606615 . Castr o, L . (1992) Residues of Flutolanil in Crops and Soil Irrigated with Water Drained from Rice Fields Treated with Flutolanil 50WP: L ab Project Number: R642.03.90. Unpublished study prepared by NOR - AM Chemical Co. 89 p. MRID 40342944 . Sudo, Y. (1984) W 4 - Flutolanil: Test on the Degree of Bioaccumula tion of a, a, a - Trifluoro - 3' - isopropoxy- o - toouanilide (Test Sub - stance No. S - 837) in Carp: Report No. 35524E. Unpublished study prepared b y C hemicals Inspection & Testing Institute. 62 p. MRID 41841214 . Forbis, A. (1991) Uptake, Depuration and Bioconcentration of [Carb on 14] - Flutolanil by Bluegill (Lepomis macrochirus): L ab Project Number: 37902: E642.04.89. Unpublished study prepared by Analy- tical Bio - Chemistry Laboratories, In c. 39 p. MRID 4 1841215 . Heitkamp, J. (1991) Characterization of [Carbon 14] - Flutolanil Residues in Bluegill (Lepomis macrochirus) Water and Tissues: Lab Project Number: 38946: E642.04.89. Unpublished study prepa - red by Analy tical Bio - Chemistry Laboratories, Inc. 58 p . MRID 42641101 . Brady , S. (1992) Flutolanil - Derived Residues in or on Crayfish Grown in Rice Paddies Treated with Flutolanil 50 WP: L ab Project Number: R642.02.90. Unpublished study prepared by Nor - Am Chemical Co. 132 p. MRID 42606616 . Castro, L . (1991) Stability of Flutolanil and Desisopropyl Flutolanil in Soil under Freezer Conditions for a Period of Two Years: Lab Project Number: E642.05.88. Unpublished study prepared by NOR - AM Chemical Co. 42 p. 

### B. Ecological Effects References Studies from the Open Literature Armitage, J.M. and F.A.P.C. Gobas. 2007. A Terrestrial Food - Chain Bioaccumulation Model for POPs. Environ. Sci. Technol ., 41(11):4019 - 4025. Czub, G. and M.S. McL achlan. 2004. Bioaccumulation Potential of Persistent Organic Che micals in Humans. Environ. Sci. Technol . 38:2406 - 2412.Page 40 of 45

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. L iterature review and evaluation of the EPA food - chain (Kenaga) nomogram, an instrument for estimating pesticide residues on plants. Environ . Tox. Chem . 13:1383 - 1391. Hoerger, F. and E. E. Kenaga, 1972. Pesticide Residues on Plants: Correlation of Representative Data as a Basis for Estimation of their Magnitude in the Environment . In : F. Coulston and F. Korte, eds., Environmental Quality and Safety: Chemistry , Toxicology , and Technology , Georg Thieme Publ., Stuttgart, West Germany , pp. 9 - 28. IFAS/UF. 2006. Fungicide Resistance Action Committee's (FRAC) Classification Scheme of Fungicides According to Mode of Action. PI - 94, Pesticide Information Office, Florida Cooperative Extension Service, Institute of Food and Agricultural Sciences, University of Florida. http://edis.ifas.ufl.edu/PI 131 . Kelly , B.C. and F.A.P.C. Gobas. 2003. An Arctic Terrestrial Food - Chain Bioaccumulation Model f or Persistent Organic Pollutants. Environ. Sci. Technol. 37:2966 - 2974. Kelly , B.C., Ikonomou, M.G., Blair, J.D., Morin, A.E., and F.A.P.C. Gobas. 2007. Food Web - Specific Biomagnification of Persistent Organic Pollutants. Science. 317:236 - 239. Motoba, K., Uchida, M., and Tada, E. 1988. Mode of antifungal action and selectivity of flutolanil. Agric. Biol. Chem. 52(6):1445 - 1449. McLachlan, M.S. 1996. Bioaccumulation of Hydrophobic Chemicals in Agricultural Food Chains. Environ. Sci. Technol . 30:252 - 259. Sharpe, S. and D. Mackay. 2000. A Framework for Evaluating Bioaccumulation in Food Webs. Environ. Sci. Technol. 34:2373 - 2379. Teske, Milton E., and Thomas B. Curbishley . 2003. AgDisp ver 8.07 Users Manual. USDA Forest Service, Morgantown, WV. U.S. Environmental Protection Agency . 1998. Guidelines for Ecological Risk Assessment. Risk Assessment Forum, Office of Research and Development, Washington, D.C. EPA/630/R - 95/002F. April 1998. http://cfpub.epa.gov/ncea/cfm/recordisplay .cfm?deid=30759 U.S. Environmental Protection Agency . 2000. Flutolanil Section 3 New Use on Potato Seed - Pieces : Environmental Fate and Ecological Risk Assessment . Offi ce of Pesticide Programs, Environmental Fate and Effects Division. Washington, DC 20460 (DP 260099) U.S. Environmental Protection Agency . 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs, U.S. Environmental ProtectionPage 41 of 45

Agency . Endangered and Threatened Species Effects Determinations. Office of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, Washington, D.C. January 23, 2004 . http://www.epa.gov/espp/consultation/ecorisk - overview.pdf U.S. Environmental Protection Agency . 2007a. Flutolanil: Human Health Risk Assessment: Request for Inadvertent or Indirect Tolerances for Use on Soybean, Wheat, Corn and Cotton . Office of Pesticide Programs, Health Effects Division. Washington, DC 20460 (DP 335050, 334156). U. S. Environmental Protection Agency 2007 b . ECOTOXicology Database. Office of Research and Development National Health and Environmental Effects Research Laboratory ’s (NHEERL’s) Mid - Continent Ecology Division (MED). http://cfpub.epa.gov/ecotox/ U. S. Environmental Protection Agency . 2007c. Ecological Incident Information System. http://www.epa.gov/espp/consultation/ecorisk - overview.pdf Registrant Submitted Studies : Guideline: 71 - 1 Avian Single Dose Oral Toxicity MRID: 40342929 Roberts, N.; Fairley , C. (1986) W8 - The Acute Oral Toxicity (LD50) of Flutolanil to the Mallard Duck: Laboratory Project ID No. NNU 21BT/861566. Unpublished study prepared b y Huntingdon Research Centre. 31 p. MRID: 40342930 Roberts, N.; Fairley , C. (1987) W9 - The Acute Oral Toxicity (LD50) of Flut olanil to the Bobwhite Quail: L aboratory Project ID No. NNU 20BT/861565. Unpublished study prepared b y Huntingdon Re - search Centre. 31 p. Guideline: 71 - 2 Avian Dietary Toxicity MRID: 40342931 Roberts, N.; Fairley , C. (1986) W10 - The Subacute Di etary Toxicity (L C50) of Flutolanil to the Mallard Duck: Laboratory Project ID No. NNu 23BT/861568. Unpublished study prepared b y Huntingdon Research Centre. 28 p. MRID: 40342932 Roberts, N.; Fairley , C. (1986) W7 - The Subacute Dietary (LC50) of Flutol anil to the Bobwhite Quail: L aboratory Project ID No. NNU 22BT/861567. Unpublished study prepared b y Huntingdon Research Centre. 29 p. Guideline: 71 - 4 Avian ReproductionPage 42 of 45

MRID: 42932301 Beavers, J.; Hoxter, K.; Jaber, M. (1993) W64 Flutolanil: F lutolanil Technical: A One Generation Reproduction Study with the Bobwhite (Colinus virginianus): Lab Project Number: 244 - 108. Unpublished study prepared by Wildlife International Ltd. 167 p. MRID: 42932302 Beavers, J.; Hoxter, K.; Jaber, M. (1993) W6 4 Flutolanil: Flutolanil Technical: A One Generation Reproduction Study with the Mallard (Anas platyrh ynchos): Lab Project Number: 244 - 109. Unpublished study prepared by Wildlife International Ltd. 173 p. Guideline: 72 - 1 Acute Toxicity to Freshwate r Fish MRID: 40342933 Bowman, J. (1987) W16 Acute Toxicity of Flutolanil Technical to Rainbow Trout (Salmo gairdneri): ABC Final Report #35378. Un - published study prepared by Analy tical Bio - Chemistry Laboratories, Inc. 143 p. MRID: 40342934 Bowman, J. (1987) W17 Acute Toxicity of Flutolanil Technical to Bluegill Sunfish (Lepomis macrochirus): ABC Final Report #35377. Unpublished study prepared by Analy tical Bio - Chemistry Laboratories, Inc. 149 p. MRID: 40342936 Tsuchiya, K.; Sugimoto, T. (1982) W6 - Report on Flutolanil Toxicity Tests on Aquatic Organisms: Laboratory Project ID No. W - 3001. Unpublished study prepared by Institute of Life Science Re - search. 35 p. MRID: 41841216 Bowman, J. (1990) Acute Toxicity of Flutolanil Technical to Fathead Minnow (Pimephales promelas): Lab Project Number: 38101: E642.05 .89. Unpublished study prepared b y Anal yt ical Bio - Chemistry Laboratories, Inc. 39 p. Guideline: 72 - 2 Acute Toxicity to Freshwater Invertebrates MRID: 41841217 Hicks, S.; Young, B.; Forbis, A. (1990) Acute Toxicity of Flutolan - il to Daphnia magna: Lab Project Number: 38718: E642.08.89. Un - published study prepared b y Analytical Bio - Chemistry Laboratori - es, Inc. 40 p. Guideline: 72 - 3 Acute Toxicity to Estuarine/Marine Orga nisms MRID: 41841218 Bowman, J.; Gormley , M. (1991) Acute Toxicity of Flutolanil Technical to Sheepshead Minnow (Cy

prinodon variegatus): Lab Project Number: 38719: 502 AU. Unpublished study prepared by Anal yt ical Bio c hemistry Laboratories, Inc. 30 p.Page 43 of 45

MRID: 41841220 Forbis, A. (1991) Acute Toxicity of Flutolanil to My sidopsis bahia: Lab Project Number: 38720: E642.07.89. Unpublished study prepa red by Analy tical Bio c hemistry Laboratories, Inc. 44 p. MRID: 41841219 Ward, T.; Boeri, R. (1991) Acute Flow - through Mollusc Shell Deposition Test with Flutolanil: L ab Project Number: 9062 - AB: E642.09 .89. Unpublished study prepared by Resource Anal ys ts, Inc. 55 p. Guideline: 72 - 4 Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study MRID: 43552001 Rhodes, J.; Muckerman, M. (1995) W69 Flutolanil: Early Life - Stage Toxicity of Flutolanil to the Fathead Minnow (Pimephales promelas) Under Flow - Through Conditions: Final Report: L ab Project Number: 41685. Unpublished study prepared b y ABC Labs, Inc. 176 p. MRID: 41850807 Blakemore, G.; Burgess, D. (1991) 21 - Day Chronic Static Renewal Toxicity of Flutolanil to Daphnia magna: Flutolanil/W 48: Final Report #38721; 503 AU. Unpublished study prepared b y Anal yt ical Bio - Chemistry Laboratories, Inc. 51 p. MRID: 43511601 Boeri, R.; Kowalski, P.; Ward, T. (1995) Life - Cy cle Toxicity of Flutolanil to the My sid, My sidopsis bahia: Lab Project Number: 522AU: 481 -NI : W66. Unpublished study prepared b y T.R. Wilbury Labs, Inc. 51 p. Guideline: 81 - 1 Acute oral toxicity in rats MRID: 40342906 Kosaka, T.; Saito, T. (1982) T6 -NNF - 136: Acute Toxicity Study in Rats. Unpublished study prepared by The Institute of Environ - mental Toxicology . 17 p. MRID: 40342907 Cummins, H. (1986) T9 - Flutolanil: Mo ncut Wettable Powder: Acute Oral Toxicity in the Rat: L aboratory Project ID No. 86/NNH004/ 227. Unpublished study prepared b y Life Science Research Ltd. 22 p. MRID: 42255205 Rees, S.; Routh, M. (1992) T44 Flutolanil 70 WDG (CR 19769 - 1): Rat Acute Oral Toxicity Study : Lab Project Number: TOX/91/237 - 1. Unpublished study prepared b y Schering Ag., Ltd. 24 p. MRID: 43594004Page 44 of 45

Shults, S.; Brock, A.; L aveglia, J. (1994) ASC 66783: Acute Oral Toxicity (LD50) Study in Rats With Chlorothalonil Plus Flutolanil (ASC 66783 - 0201 - 0202): Lab Project Number: 5933 - 93 - 0350 - TX - 001. Unpublished study prepared by Ricerca, Inc. 42 p. MRID: 43971414 McFarlane, M. (1994) T49 Flutolanil: PC 511 Formulation (CR21305/01/940101): Rat Acute Oral Toxicity Study : L ab Project Number: TOX 94168: TOX/94/237 - 13. Unpublished study prepared by AgrEvo UK Ltd. 22 p. MRID: 45103901 Graver, K. (2000) Acute Oral Toxicity /LD50 in Rats: Systar WDG: Lab Project Number: MB 99 - 7541.01: 1000. Unpublished study prepared by MB Research Labs. 13 p. {OPPTS 870.1100} MRID: 45136401 Cerven, D. (1998) Single Dose Oral Toxicity in Rats/LD 50 in Rats: Sy star Fungicide: Lab Project Number: MB 97 - 6294.01: 67 - 04. Unpublished study prepared by MB Research Laboratories, Inc. 12 p. MRID: 4552400 3 Merkel, D. (2001) Acute Oral Toxicity Study in Rats: NAI - 007: Lab Project Number: 10929. Unpublished study prepared by Product Safety Labs. 21 p. {OPPTS 870.1100} Guideline: 83 - 4 2 -generation repro. - rat MRID: 40342923 Tsujimura, S. (1982) T2 - Flutolanil: Three Generation Reproduction and Teratogenicity Study on Flutolanil in the Rat: Study No. 124. Unpublished study prepared by Imamichi Institute for Animal Reproduction. 264 p. Guideline: 122 - 2 Aquatic plant growth MRID: 41841223 B ogers, M. (1990) Scenedesmus Subpicatus, Fresh Water Algal Growth Inhibition Test with Flutolanil Technical: L ab Project Number: 024467. Unpublished study prepared by R C C Notox B.V. 25 p. MRID: 41841224 Hughes, J. (1990) The Toxicity of Flutolanil T echnical to Selenastrum capricornutum: Lab Project Number: B643 - 01 - 4: 507 AU. Unpublished study prepared by Malcolm Pirnie, Inc. 25 p. MRID: 42606621 Hughes, J. (1990) The Toxicity of Flutolanil Technical to Anabaena flos - aquae: Lab Project Number: B6 43 - 01 - 5. Unpublished study prepared by Malcolm Pirnie, Inc. 23 p.Page 45 of 45

MRID: 42606622 Hughes, J. (1990) The Toxicity of Flutolanil Technical to Lemna gibba G3: L ab Project Number: B643 - 01 - 8. Unpublished study prepared by Malcolm Pirnie, Inc. 22 p. MRID: 42606623 Hughes, J. (1991) The Toxicity of Flutolanil Technical to Skeletonema costatum: L ab Project Number: B643 - 01 - 7. Unpublished study prepared by Malcolm Pirnie, Inc. 23 p. MRID: 42606624 Hughes, J. (1991) The Toxicity of Flutolanil Technical to Navicula pelliculosa: L ab Project Number: B643 - 01 - 6. Unpublished study prepared by Malcolm Pirnie, Inc. 23 p. MRID: 42606625 Hughes, J. (1991) The Toxicity of Flutolanil Technical to Navicula pelliculosa at the Concentration Equivalent to the Maximum Treatment Rate for Rice: Lab Project Number: B643 - 02 - 1. Unpublished study prepared by Malcolm Pirnie, Inc. 23 p. Guideline: 141 - 1 Honey bee acute contact MRID: 40342938 Matsuura, M. (1987?) W3 - Flutolanil: Effects of Moncut Dry Flow - able on Hone y B ee: Laboratory Project ID No. N3001. Unpublished study prepared by Mie University . 8 p.