UNITED STATES ENVIRONMENTAL PROTECT I ON AGENCY WASH I NGTON D

. C., 20460 O F F I CE OF CHE MI CA L SAF E TY AND PO LLU TIO N PREVE N TIO N

PC Codes : 112602, 125601 , 128976 DP Barcode: D426420 Date: May 6 , 20 1 5


### MEMORANDUM SUBJECT: Review of Three Ecotoxicity Stu di es in S upport of Paclobutrazol Reg istration Review 

### TO:

FROM: Khue Nguyen, C hem ic al Review Manager To m Mo ri arty, Team Leader Nei l Ande rson, Branch Chief Risk Management and Impl eme ntation Branch 1 Pesticide Re-Evaluation D ivis i o n (7508P) Office of Pesticide Pro grams 111' 

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## Its' Meghan Radtke, Ph.D. , Biologist , 

# ·y - - fl«.tA,/ I Env ironm e nt al Risk Branch I Env ironme ntal Fate and Effects Di v is ion (7507 P) Office of P est ic ide Programs APPROVED 

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# ~**~~** BY: Sujatha Sanku la, Ph.D ., Branch Chief 

# / \J \**~** -= ;.;=-- Env iro nm e nt a l Risk Branch l · Env iro nm e ntal Fa te and Effects Di visio n (7507 P) Office of Pesticide Pro gra m s The Envi ro nm enta l Fate and Effects Division (EFE D ) has reviewed three ecotox i c ity studies that were subm itted by Sy nge nt a Crop Protection in support of Registration Review. The studies were from the scie nt ific peer-reviewed literat ure a nd address transpo11 and uptake of paclobutrazol , uniconazole (a structurall y similar plant growt h regulator) and trinexapac-ethyl in grass and sap lin g trees. Open li terature review su mm a ri es have been prepared for eac h s tud y th at ou tlin e the study's findings , limit ations, and potent ial use for risk assess men t. See Table I for m ore details

.

### TABLE 1. 

### Detai l s for the Paclobutrazo l , Uniconazo le, an d Trinexapac-et b y l St udi es
S tud y T yp e Orga ni s m MRID S tud y Cila ti on S tud y Summary Class ifi cati o n Metaboli sm Kentucky bluegrass 49577 101 Beasley , J.S. , and B.E. Qualitative Paclobutrazol uptake wa s and uptake of (Poa pratensis) Branham. 2005. Analysi s higher in creeping paclobutrazol of paclobutrazol and bentgrass than Kentucky and trinexapac Cr e eping bentgrass trinexapac acid in turfgra ss bluegrass , re gardless of acid (A g ro stis clippings. !111ernatio11a/ temperature . Trinexapac (degradate of stolonifera) Tur/grass So c ie ty Resear ch ac id uptake did not vary tr inexapac- Journal, I0: 1170-1175

. between spec ies , eth yl) re gardless of temperature . Open Half-lives were shorter at Literature hi g her temperatures. Trinexapac acid half-live s ranged trom 3.1 to 6.4 day s and paclobutrazol trom 6 to 15 days, depend in g on spec ie s and temperature. Rationale: Limited information available on number of plants tested and replication. Growth Bean 49577102 Sterrett, J.P. 198 5. Qualitative Growth inhibition inhibition , (Phaseolus Pac l obutrazo l : a promising obse rved for mo s t species , tran s locat ion. vul g aris ) growth inhibitor for but timing and doses and injection into woody plants. differed. metabolism of California privet J. Amer. So c. Ho rt. S c i., paclobutrazol (Ligus trium 11 0(1): 4-8. Movement of o valifolium) paclobutrazol documented Open from injection s ite to Literat ure R ed maple shoots and root s. Little (Acer rubrum) degradation observed with a 27-day interval in side of White ash the plant. (Frai:inus am e ricana) Rationale: Quality contro l data for th e Yellow poplar analytica l methods wa s ( Liri o d e ndr o n not presented

. t ul ipifera) American sycamore (Platanus occ ident a/is) Apple (A ,

fa=lus d o m es tica)



### 2Uniconazo le Silver maple 49577 1 03 Arron , G.P. 1990. Qualitative Uniconazole reduced translocat ion (A ce r Translocation of shoot l e ngth. and saccharinu111 ) uniconazole after trunk metaboli s m injection of si lv er maple For up to two growing saplings. J o urnal of Plant seaso ns, the majority of Open Growth Reg ulation, 9: 141- uniconazol e staye d nea r Literature 146. the injection s ite; only a sma ll percent wa s tran s locate d to leaves, where it was ob ser ved to accumulate until leaf fa ll. Uniconazol e metaboli s m was s low and did not app reciably occur in the stems an d/or near the injection site of the plant.

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### Open Literature Review Chemical Na me: Paclobutrazol and Trinexapac-ethyl PC Codes: 12560 l , I 12602 CAS Nos. 76738-62 , 95266-40-3 MRID: 49577101 ECOT OX Record Number and Citation: Beasley , J.S., and B.E. Branhan1

. 2005

. Ana lys i s of paclobutrazol and trinexapac acid in turf grass clippings. 

### Int e rnational Twfgrass Society Res earch Journal , 1 0: 11 70

- 1175. Purpo se of Review : Paclobutrazol Registration Review Date of Review: 4/24/ 15 De sc ription of Use: Qualitative Summary of Study Findings: 

### Executive Summary Paclobutrazol and trinexapac acid (active ingredient derived from trinexapac-ethyl) are systemi c plant growth regulators. The objective of the study was to evaluate the effect of temperature on the metabolism of paclobutrazo l and trinexapac ac id in coo l season turf grasses . Ha lf-lives were calculated for each temperature/ species comb in ation, based on residue measurements collected at 5 different time points. 

### Methods Kentucky bluegrass cv 'Moo

. nlight ' and creep in g bentgrass cv 'L

- 93' were seeded into 5 x 20 cm containers . At I 

### 0 weeks , an equal number of eac h spec ies (t he number was not specified) was tran s ferred into 18 or 30 ° growth chambers and allowed to acc lim ate to the env ironmental conditions for 2 weeks. After acclimation , equa l numbers of both species in each growth chamber ( 18 or 30° C) were treated with either 0.27 kg ai/ha of trinexapac-ethyl (0.24 lb ai/ A) or 0.42 kg ai/ha of paclobutrazol (0.37 lb ai/ A)

. The plants were returned to their r espect ive growth chambers and rema ined there until harvesting. Trinexpac-ethyl treated plants were harvested at 2, 5 , 8 , l l , and 14 

### days after app li cation. Paclobutrazol treated p lants were harvested at 2 , 10, 18 , 26 , and 34 days after application. The experiment was repeated once.

1Residues were analyzed using high performance liquid chromatography with ultraviolet detection (HPLC-U V) for paclobutrazol or trinexapac acid in leaves. Detai Is of the extraction and analysis process can be found in the journal article. Plant growth regulator metabolism was analyzed as a complete block design with repeated measures with SAS (2003). Turfgrass species and temperature regime were analyzed as fixed factors over time and sampling time was transformed to a logarithmic scale for the linear regression analysis. For trinexapac acid , o nl y four harvest dates were incorporated into the analysis because the fifth date yielded residues below the detection limit. 

### R es ults Trinexapac acid uptake was si milar for both spec i es of grass at both temperatures, based on th e residue measurements at 2 days after applicati o n. Metabolism rates increased at the higher temperatures (see Table 1 for the half-lives). Paclobutrazol uptake varied by species with c reeping bentgrass taking up more paclobutrazol than Kentucky bluegrass , regardless of the temperature. Metabolism rates also varied with creeping bcntgrass metabolizing paclobutrazol faster at 18° C, but not at 30° C (see Table I for the halflives). 

### Ta bl e 

### 1. Half-li ves for trinexapac a cid and paclobutrazo l K e ntuckv Blu eer ass C r ee oine Benterass 18 ° 

# c 30 ° 

# c 18 ° 

# c 30 ° 

# c Trinexpac acid 5.3 days 3.4 days 6.4 days 3.1 days Paclobutrazol 11-1 5 days 7-9 days 9 -1 1 days 6 -8 days 

### Data Quality Evalu ation Recovery from fo11ificd samp les was 78% ± 6% for trin exapac acid and 84% ± 7% for paclobutrazol. Recoveries are generally reasonable , although the trinexapac acid residue measurements may somewhat underestimate th e true residues in plants. 

### Rationale for Use : The study presents information about the half-lives of paclobutrazol and trinexapac acid in two species of turf grass and how these are affected by different temperatures. In addition , it shows th at paclobutrazo l uptake may vary by spec ies whereas trinexapac-ethyl up take was similar for the two species that were tested. 

### Limitations of S tud y : The study did not specify the number of plants that were analyzed for each treatment level. The study acknowledged that the extraction method used for trinexapac acid may not have accurately estimated the amount of trinexapac taken up by the p lants. The method measured trinexapac 2acid ; however , the initial chemica l taken into the plant i s trinexapac-ethyl. A better approach would have been to measure both tr in exapac-ethyl and trinexapac acid at the first harvest date and add these two measurements together. Raw data were not included in the study re port. 

### Description of 

### Use in Document: Qualitative. The half-lives should be treated as qualitative information because the study did not provide details about the number of plants that were analyzed per treatment group or the number of times that the study \Vas replicated. Variation appeared to be high for some of the sampled time points and it is important to understand the extent of the samp li ng effort. 

### References: SAS Institute. 2003. The SAS system for Windows. Release 9.1

. SAS Inst. , Cary , NC. 

### Primary Reviewer: Meghan Radtke, Ph.D., Biologist 

### Date: 4/2 4/ 15

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Secondary Reviewer: Edward Odenkirchen , Ph.D. , Senior Science Adv isor 

### Date: 5/4 / 15 

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### Open Literature Review C hemica l Name: Paclobu tr azo l P C C ode : l 2560 I CAS No. 76738-62 M RID : 49577102 EC OTOX Record Number and Citation: S terrett , J.P. 1985. P ac lob utra zo l: a promis ing growth inhibitor fo r inj ect io n into woody plant s. 

### J. Amer. Soc. Hort. Sci., 110 

### (I) : 4 - 8

. Purpo se of R ev i ew: Pac lobutrazo l Regis trati o n Review Date o f Revi ew : 4/ 27115 D esc ription of Use : Qua li tative S ummary of Study Findings: 

### Exec uti ve Summary The object ives of the s tud y we re to d eterm in e 

### I ) i f in jected paclobut razo l s lowe d the growth of bean, shade trees , a nd appl e trees; and 2) th e ex te nt of tran s location and m e tabo li sm in app le trees after injection. Th e s tud y demon s trated th at paclobu tr azo l suppresses growth in a numb e r of different spec i es a nd th at it is tran s located to diff e rent parts of the plant , away from the inj ec ti o n s ite . Metabo li s m of paclobutrazo l is s low to occ ur. 

### Me thods Growth Inhibition Beans 

### (Phaseo/us vu/garis) were g rown from see d s and we re inj ected w i th p aclobu trazol at doses o r 0, 0

. 0 l , 0.1 , I , I 0, 100 , and 1000 μ g/ plant. S te m heig ht was m eas ured immed iately before the treatm e nt a nd at 7 day s fo ll owin g th e trea tm ent, along w ith s h oot weigh t and leaf a rea . T he re we re 5 replicates p e r tr eatme nt level a nd th e e ntire exper iment wa s re p ea ted o nce . Two-yea r o ld California privet 

### ( Ligus trium oval ifo lium ) see dling s wi th a s ingle 1 cm diameter s tem were injected w ith 0

. I , 10, l 00 , and I 000**~tg** a i/ plant. Imme di a t e ly fo ll owi ng the inj ectio n , th e s tem of the plant was cu t off at 10 cm above the soil. The numb e r a nd le ng th of ne w stu mp spro uts was measured during a 64

- day obse r vat ion period. Each treatment was replicated 5 tim es in a randomized b lock des ign and the e ntire experiment was repea ted o nce.
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### Trunks of several species of saplings were injected with paclobutrazol emulsion. In 198 l, red maples 

### (Acer rubrum) and white ash 

### (Fraxinus americana) saplings ranging 3 to 4 cm in diameter were injected at bud break in April with 4 ml of paclobutrazol. Branches were then pruened to a single lateral of two-year old wood following the treatment. Data were collected on height increase from three tagged branches per plant throughout the growing season. There were 5 replicates per treatment. In 1983, red maple (4.1 cm diameter) , white ash (4.3 cm diameter) , and yellow poplar 

### (Lir iodendron tulipifera) (3 .6 cm diameter) were injected with 4 ml of paclobutrazol and Ame ri can sycamore trees 

### (P!atanus occidentalis) (3 .0 cm diameter) were injected with 2 ml of paclobutrazol. The tops of the main stems were pruned before the injection. Inj ections were made 100 cm below the pruned part of the main stem at bud break and one month after bud break. Data on height were collected from three tagged branches per sapling during the growing season . T he treatments were replicated 5 times in a randomized complete block design and linear regression analysis included the growth of untreated trees. 

### Translocation and Metabolism One-year old golden delicious apple trees 

### (Mazlus domestica) were potted and immediately injected with 0 or 500 μg paclobutrazol and 0 .5 % azo su lfamid e dye. The trees were pruned to 85 cm above the injection site immediately follow in g the inj ection

. The growth of the upper I 0 shoots was measured week ly over a period of 46 days after injection. The treatments were replicated 4 times in a randomized complete block design. Another set of one - year o ld apple trees were used to determine the metabolism of paclobutrazol in different plant parts. Dormant trees were injected with 500 14 

### C paclobutrazol (c-2 labeled) 5 cm above the root/stem transition zone . The tops of the trees were pruned to 85 cm above the injection site. One group of 4 trees was harvested imm ediately afte r the inj ect ion wh il e a second group of 4 trees was harvested 27 days after the inj ection, when s igns of growth inhibi tion were apparent. The trees were separated into 4 parts: root stock contain in g the roots and injection site (Section I) , 20 cm long section above the graft (Sect ion 2) , and two additional 20 cm sect ions up the main stem (Sections 3 and 4). The fibrous roots from tap roots , wood (xylem), bark (phloem) , buds, and new shoots from each section we r e analyzed separately. Details of the extraction method can be found in the study

. Treatments we r e replicated 4 times and the experiment was repeated once. 

### Results Growth Inhibition Growth inhibition was observed for most of the species that were tested (Table 1 )

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### Tabl e 1. 

### G row t h inhibition for plants treated with paclobutrazol 

### S pe c ie s Observation Bean Statistically significant decrease in he ig ht , fresh we ig ht, and leaf size afte r 7 days at the 0

. 1, I, I 0 , I 00 , and I 000 μg ai/ plant dose leve ls 

### (p S 0.05) California privet Statistically significan t reduc tion in sprout growth after 64 days at all dose leve l s - 1 , I 0 , I 00, and I 00 μg ai/ plant (p 

### S 0.05) Red maple Stat istica ll y significant s uppress ion of shoot growth afte r 4 mo nths for 0.4 and 8 mg ai/ plant 

### (p S 0.05). A statistically signi ficant difference was observed in J une after trees were i njected at bud break (April) and 30 days after bud break (May). White ash No stat ist ica ll y s i gnifica nt r educt io n s in s ho ot growth 4 months after app li cati on fo r any dose

. A stat ist ically s ig nifi cant difference was observed in June after trees were injected at bud break (April) and 30 days after bud break (May). B y earl y August, there was no stati sti cally significant difference between injec ted plants and th e ne gat ive control. Yell ow poplar A statis ti cally significant difference was observed in Jun e afte r trees were injected at bud break (Apr il ) and 30 days after bud break (May). By early August, there was no stati stically significant difference between injected plants and the negative control. Amer ican sycamore A stat ist ica ll y s ignificant difference was observed in Jun e after trees were injected at bud break (April) and 30 days after bud break (May). By early August, there was no stat ist ica ll y s ig nifi cant difference betwe e n injected p lants and the negative control. 

### Trans/ocation and Metabolism Immediate l y after in jection , the pac lobutrazo l was loca ted in the xylem and p hl oem of the stem and roots w ithin 20 cm of the injection site. At 27 days, 23% of the 14 C act iv ity was i n the shoots, 11 

### % in th e xylem and phloem tissue between the graft a nd apex, 58% in th e xylem and phloem tis s ue near the injection site, and 8 % in th e roots. This indic ates that paclobutrazol moved through the plant to t iss u es away from the in itia l in jection site. Over 90% of the 14 C act iv i ty in the xylem and phloem and ove r 85 % in th e shoot t issue after 27 days was determined to be paclobutrazol , indicating that little degradation occurred. 

### Data Quality Eva luation Reference samp les were run for the chromatograph analysis, fo r compari so n with samples from the treated trees. All experiments we re rep li cated. Other data quality in formation regarding the analyses we r e not presented in the study. 

### R at ion a l e for Use: The study pres ents information about the tr ans l ocat ion of paclobutrazol in trees and documents that it reduce s p lant growth on a variety of species. 

### It also presents information regarding the degradat ion of paclobutrazol , upon inj e ction into the plant. 3Limi ta tion s of S tud y: 

### The study did not present quality control data regardin g the analytical meth od s . D es cription of 

### Us e in Document: 

### Qualitative. The transloc at i o n and metabo li s m data s ho uld be trea t ed as qua lit ati ve informati o n because th e s tudy did no t provide detail s abo ut the verific ation of the performance of th e ana lytical method s. Prim a ry R evi ewer: 

### Meghan Radtke , Ph.D. , Bio logist Oatc: 4/27/15

# ~**~** Seco ndary R e vi e w e r : 

### Edward Odenkirchen Date: 5/4/ 15 

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### Open Literature Revi e w C h e mi ca l Name : Unico na zole P C Co d e : 128976 CAS No
. 83657

- 22 -1 

### MRID: 49577103 EC OTOX R eco rd Number and Citation: Arron , G.P. 1990. Trans location of unic onazo l e after trunk inj ec tion of s il ve r m ap le sap li ngs. 

### Journal of Plant Grow th Regulation, 9 : 141-1 46. Purpo se of R ev iew: Registration Re v i ew Date of Review: 4/ 28115 Description of Use: Qua li tative S ummary of Study Findings : 

### Executive 

### Summary The object ives of the s tud y were to de te rmin e 1) th e effect of trunk-inj ected uni conazo le on silver maple growth saplings 1 8 month s afte r applicat ion; 2) mo ve ment of uniconazole in the trees; 3) the p roport io n of uni co nazo le in fo li age durin g the fi rst and seco nd fa ll after application; and 4) the amou nt of unmetabolized uniconazole in leaves. T he stu d y s hows that most of the uniconazo le remained in the stem of th e trees , near the inj ec tion s ite durin g two grow ing seasons. A higher percentage of uni conazo le, com p are d to it s metabolites , was detected in fo li age at the end of each grow in g season , thu s suggesting th at metabolism is not occ urrin g in the stems of trees. 

### Methods Four

- year o ld si l ve r maple trees 

### (Acer saccharinum) were u se d for the expe riment. Pri or to injection with uni co nazole , the trees were tri mmed s uch that approximately o n e third of the canopy was removed

. Fo r the " fo li age " experim e nt , l eaves were harvested over two growi ng seasons to track transloca ti on of uniconazole

. For th e " h arvest" expe rim e nt , the d istri bu ti o n of unicona z o le in trees was measured by ha rvest ing the w hol e sapl in g at diff e re nt tim e pe ri ods

. Trees were injected with 18 mg 1 4 C -unic o nazo le approximate ly 40 cm above th e so il s urface. Contro l s were injected with I 

### .4 ml of isopropy l alcohol. For the foliage expe rime nt , 5 trees were in itia ll y injected w ith uni co nazo le , but one of these was not a s uc cessful injection (ver y littl e
1unicona zo l e ac ti v ity was detected in the tree); there were 5 control trees. Fo r the harvest experiment , 12 trees we re injected with uniconazole and 

### 6 with a lco hol (contro ls)

. Shoot growt h (ex tension growth of all s hoot s and sprouts originating at the root collar) was measured to the nearest 0.5 cm in the fall of 1 987 and 1988 for all plants (fo li age and harvest exper ime nt s)

. The median s hoot lengths were compared using a Mann-Whitn ey non-param etric test. For the foliage expe r iment, 30 leaves we re randomly sampled inunediately after injection (day 0) and then at 7 , 17 , 25 , 35 , 45 , 65, 85, 101 , 122, 133 , 375 , 416 , 444 , 472, and 497 days later. In addition, a ll of the remaining fo li age was re moved from th e trees on days 1 33 and 497. For th e harvest expe riment , tlu-ee sap lin gs inj ected w ith uniconazol e were dug up on day 0, 17 , 134 , and 500 and separated by plant part: fibrous roots , tap root, main ste m samples ( 15 cm sec tion s) , branched stem secti ons , 1986 ste m growth sec t ions, and foliage. All samples we re frozen and stored at -1 6 ° C until analysis. See the study fo r details on th e methodology used to measure 14 Ccontent and the metaboli s m of uniconazole. 

### Re s ult s Growth Inhibition Uniconaz ole did not affect the number of shoots or sprouts per sapli ng in either experim ent. There was a s ig nificant reducti o n in the mean shoot length per sampling for the h arve st experiment in both years. In addition , th e re was a sign ifi ca nt r ed ucti on in median shoot le ngth in 1 998 for the foliage expe riment. 

### Trans/ocat ion Durin g th e g rowing seasons of 1987 and 1 988 , the 14 C activity in the leaves collected in the foliage experiment lin ea rl y in creased from late May to early October, suggest in g that uniconazole is collecting in the foliage of the trees . 14 C m easu rements at 0 , 1 7 , 134 , and 500 days after injection indicated that most of the injected uniconazole was staying near the injection si te in the main stem of the tree. A s mall am ou nt of 14C was detected in branched ste m sections and foliage at the 17. 134 , and 500 day mea su rement points. Table I shows the 14 C-activity in severa l tissue types from the foliage experiment.

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### Tab le 1. 

### •.ic-activ ity in tissue of s il ve r mapl e sa plin gs h arvested at 0 , 17 , 134 , a nd 500 day s after trunk inj ecti on with uniconazole

Days after 14 C

- activity % of total 14C-activity in jecte d (as % of total 14 C-acti vity in

ject io n ret ri eved retrieved) Who le sapli n gs Stem samp le (45 cm sect io n Fol iage bracketing in jection site) 0 86.7 ± 7 .1 8 84.1 ± 8.8 (97.0 ± 3.5) 0.0 ± 0.0 (0.0 ± 0.0) 1 7 67
. 6 ± 25

. 6 49. I ± 1 8.0 (72.9 ± 4.8) 1. 5 ± 0.7 (2.5 ± 1. 6) 134 62.6 ± 5.3 51.1 ± 4.5 (8 1. 2 ± 4.2) 7.1 ± 1.7 (11.3 ± 2.5) 500 52.7 ± 17.8 45

. 0 ± 18.7 (84

. 2 ± 8.0) 2

. 3 ± 0

. 6 (4.6 ± 1.8 ) ava lu es a r e given as mean ± SD (N 

### = 3) 

### Metabolism To determine the proportion of 14 C -u niconazole versus m e tabo lites, ex tracts were analyzed from samples collected o n days 134 and 497 of the fol iage expe rime nt. Unico n azole m ade up 53% and 71 % of the 14 C

- activity detec ted in the leaves in the 1 34 a nd 497 day collect ions, respec t ively. This suggests that metabo li s m of uniconazole i s not occurring in the s te m s , as a decrease in uniconazol e was not seen at the 497 day samp lin g period. 

### Data Quality Eva lu ation R e ference sa mpl es were run fo r the chroma to grap h a n a lys is, for compar i so n w i th sampl es from the treated trees. The number of replicates was limited (n = 3 for harvest stu dy a nd n 

## = 4 for fo li age study), but usually th e standard deviations were sma ll. 

### R at ional e for Use : The st u dy presents information abou t the translocation of uni co n azole in trees and its accumu lat io n in leaves during the growi n g season. Metabolism of uni conazo le does not appear to take p lace in the stems / trunks of trees . Concentrat ions of uni co n azole are reported for fo l iage sa mples. 

### Limitation s of Study: The study s h ows a peak fo li age acti v ity of 

### 7. I 

### +/

- l.7 

### % at day 134; h owever, it s h o uld be n oted that I I 7 days between th e p r evious m easurement had transpired so the stud y cannot reliably b e used to determine the actual peak valu e . 

### De scrip t io n of Use in Docum e nt: Qualitative

. The tran s location and metabolism data s ho uld be treated as qua li tative information because of limited rep li ca ti on and long interval s between samp li ng .

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### P r im ary Rev iewer : Meg h an Ra dtke , Ph.D., Biologist 

### D a te : 4/ 28/ 15

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