Page 1 of 60 OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

A ugust 3 , 2015
PC Code s : 034801, 079801
MEMORANDUM DP Barcode s : 427810, 427924

SUBJECT: Registration Review: Preliminary Problem Formulation for Environmental Fate, Ecological Risk, Endangered Species, and Human Health Drinking Water Exposure Assessments for Ferbam and Thiram

F ROM: Elyssa Arnold , Biologist Ron Parker, Senior Environmental Engineer

Environmental Risk Branch 2 Environmental Fate and Effects Division ( 7507P)

REVIEWED Melissa Panger, Senior Science Advisor

BY: James Lin , Environmental Engineer

Environmental Risk Branch 2 Environmental Fate and Effects Division ( 7507P)

THROUGH: Brian Anderson, Branch Chief

Environmental Risk Branch 2 Environmental Fate and Effects Division ( 7507P)

TO: Khue Nguyen, Chemical Review Manager Tom Moriarty

, Team Leader Neil Anderson, Branch Chief Risk Management and Implementation Branch 1

Wilhelmena Livingston, Chemical Review Manager Kevin Costello, Branch Chief Risk Management and Implementation Branch 4

Pesticide Re

- e valuation Division (7508P)Page 2 of 60 

# Table of Contents

1. Executive Summary

................................ ................................ ................................ ................ 3

2. Introduction

................................ ................................ ................................ ............................. 4

3. Use Charact erization

................................ ................................ ................................ ............... 5

4. Conclusions from Previous Risk Assessments

................................ ................................ ....... 8

4.1. Ecological Risk Assessment

................................ ................................ ............................. 8

4.2. Drinking Water Exposure Assessments

................................ ................................ ......... 10

4.3. Clean Water Act Programs

................................ ................................ ............................. 10

5. Environmental Fate and Transport

................................ ................................ ........................ 10

5.1. Transformation Products

................................ ................................ ................................ 13

6. Receptors

................................ ................................ ................................ ............................... 17

6.1. Effects to Aquatic Organisms

................................ ................................ ........................ 17

6.2. Effects to Terrestrial Organisms

................................ ................................ .................... 19

6.3. Ecological Incidents

................................ ................................ ................................ ....... 21

7. Exposure Pathways of Concern

................................ ................................ ............................ 22

8. Analysis Plan

................................ ................................ ................................ ........................ 22

8.1. Stressors of Concern

................................ ................................ ................................ ....... 22

8. 2. Measures of Exposure

................................ ................................ ................................ .... 22

8.3. Measures of Effect

................................ ................................ ................................ ......... 23

8.4. Endangered Species Assessments

................................ ................................ .................. 23

8.5. Endocrine Disruptor Screening Program

................................ ................................ ....... 24

9. Preliminary Identification of Data Gaps

................................ ................................ ............... 24

9.1. Environmental Fate

................................ ................................ ................................ ........ 24

9.2. Effects

................................ ................................ ................................ ............................. 26

10. References

................................ ................................ ................................ .......................... 35

10.1. Submitte d Environmental Fate Studies

................................ ................................ ...... 36

10.2. Submitted Ecological Toxicity Studies

................................ ................................ ...... 42 Appendix A. SIP Modeling Results

................................ ................................ .............................. 45 Appendix B. STIR Modeling Results

................................ ................................ ........................... 46 Appendix C. Summary of Ferbam and Thiram Fate and Transport Data

................................ ..... 47 Appendix D. Ziram, Thiram, and Ferbam Ecotoxicity Data

................................ ........................ 52Page 3 of 60 

# 1. Executive S ummary

The Environmental Fate and Effects Division (EFED) has completed the preliminary problem

formulation for the ecological risk, environmental fate, endangered species, and drinking water assessments to be conducted as part of the registration review of the fungicides ferbam (PC 034801) and thiram (PC 079801)

. The problem formulation describes the methods planned to be used during the completion of drinking water and ecological r isk assessments in support of registration review and provide s an ove rview of the environmental fate, ecological effects

, potential risks associated with the use, and uncertain ties unique to the risk assessment of ferbam

and thiram

. This document also identifies additional studies that would be beneficial to the conduct of an ecological risk assessment. Ferbam and thiram are being assessed together because ferbam rapidly degrades to the more persistent thiram. Thiram is also the major degradate of concern for ziram, which is a nother dimethyldithio carbamate fungicide. The problem

formulation for ziram can be found under DP 427965 (USEPA, 2015)

.

The ferbam Reregistration Eligibility De cision ( RED ) was completed in 2005 and the thiram RED was completed in 200 4

. The ferbam and thiram RED s concluded that there was risk of

acute and chronic adverse effects to aquatic organisms and risk of chronic adverse effects to

bir ds, and mammals

. Acute risks to birds and mammals were considered unlikely due to thiram’s

use as a wildlife repellent for mammals

. Data submitted following the RED s will be incorporated into the registration review risk assessment.

The following are the needed data and u ncertainties for ferbam and thiram :

Data Needs

• Environmental Fate and Transport Data

o None

• Ecotoxicity Data

– Studies to be conducted with thiram only

o Aquatic animal studies

 OCSPP 850.1350: Mysid chronic toxicity

 OCSPP 850.1400: Estuarine/marine fish early

- life stage toxicity

o Aquatic plant studies

 OCSPP 850.4500: Algal toxicity, studies with freshwater diatom Navicula pelliculosa and marine diatom Skeletonema costatum

 OCSPP 850.4550: Cyanobacteria toxicity

o Avian studies

 OCSPP 850.2100: Avian acute toxicity

, passerine species

o Terrestrial invertebrate studies 1



###  Non

- guideline (Tier 1) : Honey bee adult acute oral toxicity

 Non

- guideline (Tier 1) : Honey bee larvae acute toxicity

 Non

- guideline (Tier 1): Honey bee adult chronic oral toxicity

1 Tier 2 and 3 studies are conditional on the outcome of the screening

- level assessment where acute and/or chronic

risk levels of concern have been exceeded for terrestrial invertebrates based on Tier I studies of individual bees.Page 4 of 60 

###  Non

- guideline (T ier 1): Honey bee larvae chronic toxicity

 Non

- guideline (Tier 2): Semi

- field testing for pollinators (tunnel or colony feeding studies)

 Non

- guideline (Tier 2): Field trial of residues in pollen and nectar

 OCSPP 850.3040 (Tier 3): Field testing for pollina t ors

o Terrestrial plant studies

 OCSPP 4100 : Seedling Emergence

 OCSPP 4150 : Vegetative Vigor

Other Major Uncertainties

For many of the labeled uses of thiram , the labels do not specify the annual maximum application rate, number of applications, or minimum retreatment intervals when multiple applications are permitted. Absence of such information on the labels may result in conservative assumptions for modelin g of use patterns in the registration review risk assessment

.

The only Section 3 ferbam label does not specify the minimum retreatment interval for most uses

and presents conflicting information for application rate and application method for some uses.

A dditionally, the treated area permitted at the spot treatment rate for cranberries is not defined. These label uncertainties may result in conservative assumptions for exposure modeling.



# 2. Introduction

F erbam, ferric dimethyldithiocarbamate

, and t hiram, tetramethyl thiuram disulfide

, are dimethyldithiocarbamate fungicide s. These fungicides are non

- systemic and act by concomitant inhibition of spore germination and mycelial growth through multi

- site interference of enzyme processes associated with respirat ion. As an animal repellent, thiram create s a taste aversion to deter feeding by rabbits, deer, and rodents

.

Ferbam is registered for foliar use on food crops and ornamentals. There is one active Section 3 registration, a water dispersible granule formulation, and one active special local needs label for

ferbam in the United States. There are no registered co

- formulated products with ferbam.

Thiram is registered as a foliar spray, seed protectant

, and animal repellent

. There are 19 active

Section 3 registrations and six active special local needs labels for thiram in the United States.

Thiram seed treatments are co

- formulated with tebuconazole, ipconazole, triticonazole, carboxin, metalaxyl, and imidacloprid . No products labeled for foliar applicati ons are co

- formulated. Thiram formulations include dust, dry flowable, emulsifiable concentrate, flowable concentrate, ready

- to

- use, suspension concentrate, and wettable powder.

EFED evaluated the most recent ecological risk assessments for ferbam and thi ram in association with the update d toxicity, exposure, and usage information to determine if sufficient data are available and if further updates are needed to support registration review. The most r ecent riskPage 5 of 60 

### assessments were the 2004 EFED RED Chapter s ( USEPA

, 2004a, 2004b) . In addition, EFED considered the latest Agency science policies and risk assessment methodologies.



# 3. Use Characterization

Ferbam is registered for use via chemigation or ground spray on apples, pears, citrus, nectarines, peaches, and cranberries. A special local needs label is registered for use on mangoes in Florida. The primary uses for ferbam are on grapefruit (5

- 10% of crop treated) and oranges (<2.5% crop treated) , at approximately 20,000 lbs a.i./yr for each crop from 2004

- 2012 (USEPA, 2014a).

Thiram is registered for foliar use on fruit trees, strawberries, vegetation surrounding airport landing fields, ornamentals, and golf course turf. It can be applied throu gh chemigation, aerial (peaches and strawberries, only) and ground spray, and dips for transplants, bulbs, and tubers. It is also used as a seed protectant for a variety of vegetables, grains, cotton, ornamentals, and other seeds, and as an animal repellen t to protect ornamentals, nursery stock, and non

- bearing vines

and fruit trees from damage by rabbits, rodents, and deer

. Vegetation surrounding airport runways can be treated to deter deer from moving onto the runways. The primary foliar agricultural uses for thiram are on apples (<2.5

- 10% of crop treated) and strawberries ( 20

- 30% of crop treated), at approximately 50,000 lbs a.i./yr for each crop (USEPA, 2014b). T he primary

seed treatment uses for thiram are on cotton (5

- 15% of crop treated), soybeans (<2 .5

- 5% of crop treated), and wheat (<2.5% of crop treated), at approximately 6,000, 40,000, and 20,000 lbs a.i./yr, respectively from 2004

- 2012 (USEPA, 2014b)

. No usage data is available for non

agricultural use sites such as turf and ornamentals.

Table 1 and Table 2 list the maximum use patterns for the registered uses of ferbam and thiram, respectively. EFED will use application scenarios that result in maximum exposure scenarios for a given use for the risk assessment. For seed treatments with thiram, maximum seeding rates for each crop in the T

- REX model will be assumed unless alternative seeding rates are specified on

the label. For labels th at do not include a maximum annual or seasonal application rate, maximum number of applications, o r minimum retreatment interval, conservative assumptions

will be made as illustrated in the following examples:

• A maximum single application rate is specified with a re

- application interval of 7 days without specifying a maximum annual rate may result in an assumption of 52 applications with 7

- day intervals;

• A label that does not specify an application interval may result in assumptions of short application int ervals such as 1

- or 3

- day intervals.

Table 1. Maximum Use Patterns for Current Uses of Ferbam

Use Max Single App. Rate (lbs a.i./A) Max App. Rate per
CC (lbs a.i./A) Max # of App. per CC Max App. Rate per

Year (lbs a.i./A) Max # of App. per

Year Min

Ret reatment

Interval

(days) Application

Methods

Apple 3.5 NS NS 10.5 3 NS Chemigation & ground sprayPage 6 of 60 Use Max Single App. Rate (lbs a.i./A) Max App. Rate per
CC (lbs a.i./A) Max # of App. per CC Max App. Rate per

Year (lbs a.i./A) Max # of App. per

Year Min

Ret reatment

Interval

(days) Application

Methods

Citrus 6 NS NS 18 3 NS Chemigation & ground spray

Cranberry 4.56 NS NS 30 5 14 Chemigation & ground spray

2264 1 NS NS 2264 1 NA Spot treatment to 1 sq. foot

Peach 3.4 NS NS 10.2 3 NS Chemigation & ground spray

Mango 3.0 NS NS 30 10 10 Ground spray

Nectarine 3.4 NS NS 10.2 3 NS Chemigation & ground spray

Pear 3.5 NS NS 10.5 3 NS Chemigation & ground spray NS=Not Specified; App.=Applications; CC=Crop Cycle

1 Equivalent to 0.05 lbs a.i./ft 2 . The label does not restrict the total number of spot treatments per acre.



### Table 2

. Maximum Use Patterns for Current Uses of Thiram

Use Max Single App. Rate (lbs a.i./A) Max App

. Rate per
CC (lbs a.i./A) Max #

of App. per CC Max App. Rate per

Year (lbs a.i./A) Max # of App. p er

Year Min

Retreatment

Interval

(days) Application

Methods

Vegetation surrounding

a irports/ landing

fields 32.7 NS NS NS NS NS Spray &

brush

- on

Fruit trees 43.5 NS NS NS NS NS Hand

- held spray wand &

brush

- on Golf course

turf 16.3 NA NA NS NS 14 Spray & sprinkler Nursery
stock &

ornamentals 43.5 NS NS NS NS NS Hand

- held spray wand &

brush

- on

Peach 2.63 15.9 6 NS NS 7 Aerial & ground spray

Strawberry 3.3 NS NS 16.5 5 10 Aerial & ground spray 2.96 NS NS 29.6 12 10 Alfalfa, barley, beans, beets, broccoli, Brussels sprouts, buckwheat, cabbage, canola, carrot, castor bean, cauliflower, celery, Swiss chard, chicory, clover, collards, conifers, coriander, field corn, sweet corn, cowpeas, cucumber, eggplant, endive, flax, grass grown for forage or seed, kale, kohlrabi, lentils, lettuce, melons, millet, mustard, oats, okra, onion, ornamentals, peanuts, peas, pepper, pumpkin, radish, rice, rye, safflower, sesame, small seeded legumes, sorghum , soybeans, spinach, squash, sugar beets, sunflower, tomato, triticale, turnip, vegetables, vetch, wheat Seed treatment

N S = N ot Specified; App.=Applications; CC=Crop Cycle



### Ma ps of estimated annual use for f erbam and t hiram in 2012 are presented in Figures 1 and 2

, respectively.Page 7 of 60 

### Figure 1. Estimated Agricultural Use for Ferbam (USGS, 2012)Page 8 of 60 

### Figure 2. Estimated Agricultural Use for Thiram (USGS, 2012)



# 4. Conclusions from Previous Risk Assessments

4.1. Ecological Risk Assessment

The most r ecent ecological risk assessments for thiram and ferbam are the 2004 EFED RED chapter s ( USEPA, 2004a, 2004b )

. The REDs for both chemicals concluded that there was risk of acute and chronic adverse effects to aquatic organisms and risk of chronic adverse effects toPage 9 of 60 

### birds, and m ammals. Acute risks to birds and mammals were considered unlikely due to thiram’s use as a wildlife repellent. While chronic aquatic risk was considered likely, no chronic aquatic toxicity data were available at the time of the RED assessments

. Figure 3 and Table 3

summarize the potential risks identified in previous assessments and the supporting evidence

.

Figure 3 . Graphic Summary of Potential Risks of Current Uses

Table 3 . Evidence of Risk to Taxonomic Groups from Thiram and Ferbam Uses

Predominant Evidence of Negligible Risk Predominant Evidence of Risk

None Mammals and birds : Acute and chronic risk LOC

exceedances for listed and non

- listed species from a single application. Acute risk is uncertain due to the repellent nature of the chemicals, but chronic risk is considered likely.

Fish and aquatic invertebrates: Acute risk LOC

exceedances for listed and non

- listed freshwater fish, freshwater invertebrates, and estuarine/marine invertebrates. No chronic toxicity data available.



### Limited Evidence of Negligible Risk Limited Evidence of Risk

Aquatic plants: No LOC exceedances for green algae or duckweed . Toxicity data not available for other aquatic plant species. None

Terrestrial plants: No toxicity data available. No incidents reported.

Terrestrial invertebrates: Thiram and ferbam are practically non

- toxic to adult honey bees on an acute contact exposure basis. No other toxicity data available.Page 10 of 60 

## 4.2. Drinking Water Exposure Assessments

A drinking water exposure assessment for thiram was completed as part of the RED in 2004 (USEPA, 2004a )

. Maximum Tier 2 exposure estimates for the residues of concern in surface

water were 180 μ g/L (1

- in

- 10

- year peak), 4 .3 μg/L (1

- in

- 10

- year annual mean) , and 3.0 μg/L ( cancer ) using the PRZM and EXAMS models . For ground water, screening l evel exposure

estimates were 0.84 μg/L for both acute and chronic exposure using the SCI

- GROW model.

A drinking water exposure assessment for ferbam was completed as part of the RED in 2004. The assessment calculated thiram concentrations in drinking water resulting from ferbam applications due to the rapid degradation of ferbam to thiram. The estimated residues of concern

in surface water were 81 μg/L 1

- in

- 10

- year peak) and 2.5 μg/L (1

- in

- 10

- year annual mean ). The exposure estimates for ground water were 0.02 μg/L fo r both acute and chronic exposure using

the SCI

- GROW model.



## 4.3. Clean Water Act Programs

Thiram and ferbam are not identified as a cause of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act

. 2 

### No Total Maximum Dai ly Load (TMDL) criteria have been developed for thiram or ferbam

. 3 

### Aquatic life benchmarks have been

established for thiram and are available at http://www.epa.gov/oppefed1 /ecorisk_ders/aquatic_life_benchmark.htm ; no benchmarks have

been established for ferbam . Any data submitted or otherwise located as part of the registration review process may be used to update aquatic life benchmarks if applicable.



# 5. Environmental Fate and Transport

The available environmental fate data are summarized for both ferbam and thiram below . The risk assessments for both thiram and ferbam will focus on exposure to thiram given the rapid

transformation of ferbam to thiram. Therefore, thira m data will be used in both the ferbam and

thiram risk assessments

. F erbam studies also provide useful information on thiram because of the rapid degradation of ferbam to thiram.

Ferbam is a short lived chemical that degrades rapidl y ( up to 31 minutes) via hydrolysis, photolysis and aerobic soil metabolism to thiram, the major degrade of ferbam. Ferbam hydrolyzed with half

- lives of less than 12.1 minutes at pH 5 to 9. In aqueous photolysis, soil photolysis , and aerobic soil metabolis m stud ies , ferbam degraded too quickly to allow for the

measurement of the degradation rate. Thiram was the major degradate in all degradation pathways. There are no acceptable soil adsorption and mobility data for ferbam. EFED acknowledges that it is diff icult to conduct a scientifically sound batch equilibrium study for

2 http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=885

3 http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id=885&p_pollutant _group_name=PESTICIDESPage 11 of 60 

### ferbam since it is very unstable under hydrolytic and aerobic conditions. There is little potential for ferbam to leach into groundwater due to its rapid degradation rate.

Thiram is moder ately persistent and is degraded by a combination of abiotic and biotic processes in soil and water to produce non

- persistent degradates such as COS, CS 2 

### and CO 2 

### . Thiram is essentially immobile (Koc = 2245 to 24526 in 4 soils)

. The chemical has a potential to reach surface water through runoff via erosion or spray drift.

H ydrolysis, photodegradation, and aerobic soil metabolism are the main degradation processes for thiram. Observed half

- lives are generally less than 18 days under the expected use conditions

and environmental ly relevant pHs. When exposed to sunlight, thiram is expected to degrade within approximately a day via photolysis. When exposed to water, thiram degradation is pH dependent with half

- lives of several days to several weeks at pH 7, and much slower at pH 5 (half

- life of approximately 2 to 6 months). Thiram degrades relatively rapidly via microbial

me tabolism in soil and water with half

- lives of approximately 2 weeks in soil and 2 days in water

under aerobic conditions. Thiram is m ore persistent under anaerobic conditions with half

- lives of approximately 4 to 40 days.

Thiram residues appear to have low mobility in the environment with Koc values that range from approximately 2000 to 25,000 L/kg.

T errestrial field dissipation s tudies are consistent with the laboratory data. In studies conducted in California, thiram (Spotrete TM 

### 75 WDG), broadcast applied eight times as a spray, at a nominal application rate of 10.3 lbs a.i./A/application, dissipated with half

- lives of 14 and 27 d ays for

bare

- ground and turf plots of sandy loam soil (pH 8.2 to 9.6), respectively

. In studies conducted in North Carolina, Thiram (Spotrete ® 

### 75WDG), broadcast applied eight times as a spray at a nominal application rate of 10.3 lb a.i./A/application, dis sipated with half

- lives of 36 and 62 days

on a bare ground plot of sand soil (pH 4.1 to 4.7) and a turf plot of loamy sand soil (pH 4.4 to 4.5), respectively.

Table s 4 and 5 below summarize the chemical and environmental fate proper ties of ferbam and

thiram , respectively

. A detailed description of the available data can be found in Appendix C

.

Table 4. Chemical Properties and Environmental Fate Parameters of Ferbam

Parameter Value Description Source

Selected Physical/Chemical Parameters

Molecular mass (molecular formula) 416.49 g/mol (C 9 H 18 Fe N 3 S 6 ) NA (Calculated)

Vapor pressure (25 °C) <2.05 x 10

- 6 Pa

1.54 x 10

- 8 mm Hg Low potential for

volatilization MRID 00262064

Aqueous solubility (2 0 ° C) 130 mg/L Soluble PPDB

Henry’s Law Constant (20°C) 1. 58 x 10

- 8 Low potential for

volatilization PPDB

Log octanol

- to

- water partition coefficient (log K OW ) - 1.6 Moderately hydroph ilic MRID 40600608Page 12 of 60 Parameter Value Description Source

Persistence

Hydrolysis half

- life (25 ° C) pH 5: 12 min pH 7: 8 min pH 9: <0.2 min Very rapid degradation pathway MRID 44071801

Aqueous photolysis half

- life (25 ° C) <1 hr Hydrolyzes too rapidly

to measure MRID 43999801

Soil photolysis half

- life (25 ° C) <1 hr Hydrolyzes too rapidly

to measure MRID 45742501

Aerobic soil metabolism half

- life (25°C) <1 hr Hydrolyzes too rapidly

to measure MRID 44368901

Anaerobic soil metabolism half

- life (25°C) NA Hydrolyzes too rapidly

to measure MRID 44565305

A erobic aquatic metabolism half

- life (25 ° C) NA NA NA

A na erobic aquatic metabolism half

- life (25 ° C) NA NA NA

Mobility

Mobility in Soils NA Rapid degradation prevents measurement of mobility NA

Field Dissipation

Terrestrial field dissipation half

- life; leaching depth NA NA NA

NA: Not Available



### Table 5

. Chemical Properties and Environmental Fate Parameters of Thiram

Parameter Value Description Source

Selected Physical/Chemical Parameters

Molecular mass (molecular formula) 240.4 3 g/mol (C 6 H 12 N 2 S 4 ) (Calculated)

Vapor pressure (2 5 °C) 2.3 mPa

1.72 x 10

- 5 Torr Low potential for

volatilization PPDB USEPA, 2004a

Aqueous solubility (20 ° C) 16 .5 mg/L Soluble PPDB

Henry’s Law Constant (20°C) 3 .3 x 10

- 7 Pa

- m 3 /mol

1.4 x 10

- 5 (dimensionless) Low potential for

volatilization (Calculated)

Log octanol

- to

- water partition

coefficient (log K OW ) 1.73 Moderately hydrophobic PPDB

PersistencePage 13 of 60 Parameter Value Description Source

Hydrolysis half

- life (days) (25 ° C) pH 5: 169 d pH 7: 17.9 d pH 9: 6.9 d

pH 5: 68.5 d pH 7: 3.5 d pH 9: 6. 9 hr Slow to very rapid degradation pathway

depending on pH MRID 45714101

MRID 41840601

Aqueous photolysis half

- life (days) ( pH 5 buffer, 25 ° C) 10.4 hr

7.2 hr May photolyze in clear,

shallow waters MRID 4175 38 01

MRID 45651201

Soil photolysis half

- life (25 ° C) 17.3 hr 43.2 hr (dark controls) Effects soil surface only MRID 4 5724501

Aerobic soil metabolism half

- life (25 °C) 17.2 d

2.09 d (non

- linear regression) Moderately rapid degradation pathway MRID 4 3734901

Anaerobic soil metabolism half

- life (25°C) NA NA NA

Aerobic aquatic metabolism half

- life (25 ° C) 1.5 d (pond water )

2.1 d (river water ) Rapid degradation pathway in water column M RID 45243401

Anaerobic aquatic metabolism half

life (25 ° C) 43.1 d Not a rapid degradation pathway MRID 43628501

Mobility

Mobility in Soils K
oc = 2245 to 24526 in 4

soils Slightly to hardly mobile MRID 43787501

Maximum volatile concentration (23°C) 313 μg/m 3 (24 hrs post

treatment) (35% volatilized by 4 d
post

- treatment) NA MRID 43754001

Field Dissipation

Terrestrial field d issipation half

- life North Carolina

36 d (bare ground)

62.5 d (turfed sandy loam) NA MRID 44724502

NA: Not Available



## 5.1. Transformation Products

Ferbam degrades rapidly via hydrolysis, photodegradation , and aerobic soil metabolism. It has a very short half

- life, ranging from too low to assess to 31 minutes under abiotic and biotic (natural) degradative processes. Rapid degradative processes of ferbam suggest that the chemical would not persist in the en vironment. Ferbam degradates are detailed in Table 6

. The major transformation product is tetramethylthiuram disulfide (TMTD, also commonly known as

thiram ), which is moderately persistent in soil or water. Theoretically, for every two ferbam molecules, th ree thiram molecules could potentially be formed (see Figure 4 ) . Some of the environmental fate studies indicated almost quantitative formation of thiram and for previous

assessment s , a quantitative formation was assumed. This approach will also be used fo r the registration review risk assessment, see Section 8 for additional details.Page 14 of 60 

### Degradates of thiram include dimethyldithiocarbamate anion (DTC), carbonyl sulfide (COS), carbon disulfide (CS 2 

### ), and carbon dioxide (CO 2 

### ). There are no major (≥10%) non

- vola tile degradates. Thiram degradates are detailed in Table 7

.

Figure 4. Conversion from Ferbam to ThiramPage 15 of 60 

### Table 6. Ferbam and i ts Major Environmental Degradates

Code Name/ Synonym Chemical Name Chemical Structure Study Type MRID Maximum %AR (day) Final

%AR (study length)

PARENT

Parent Ferbam

(PC Code:

034801) ferric dimethyldithiocarbamate

CAS No.: 14484

- 64

- 1

Formula: C 9 H 18 FeN 3 S 6

MW: 416.49 g/mol

MAJOR TRANSFORMATION PRODUCTS
Degradate
Thiram (PC Code: 079801) tetramethylthiram disulfide

CAS No.: 137

- 26

- 8

Formula: C 6 H 12 N 2 S 4

MW: 240.43 g/mol Hydrolysis and

aqueous photolysis 44071801 63.3% (1 day) 1.1% (7 days) 0.5% (15 days) 15 days

Aerobic soil 43999802 77.9% (0 days) 49.9% (7 days) 26.3% (150 days) 150 days

Anaerobic soil 44565305 33.8% (0 days) 50% (184 days) 364 days

CS 2 carbon disulfide Hydrolysis and

aqueous photolysis 44071801 44.6% (14 days) 15 days

Soil photolysis 43999802 44.6% (15 days) 15 days

CO 2 carbon dioxide Hydrolysis and

aqueous photolysis 44071801 28.6% (14 days) 15 days

Soil Photolysis 43999802 28.6% (15 days) 15 daysPage 16 of 60 

### Table 7. Thiram and its Major Environmental Degradates

Code Name/ Synonym Chemical Name Chemical Structure Study Type MRID Maximum %AR (day) Final %AR (study length)

PARENT

Thiram tetramethylthiram disulfide

CAS No.: 137

- 26

- 8

Formula: C 6 H 12 N 2 S 4

MW: 240.43 g/mol

MAJOR TRANSFORMATION PRODUCTS

thiosulfinic acid Hydrolysis pH 7 45714101 27.2% (30 days ) 30 days

Soil photolysis 45724501 82.5 % (0 day s )

17.2 % (15 day s ) 15 day s

sodium dimethyl

dithiocarbamate Hydrolysis pH 7 45714101 12% ( 12 days ) 0.0% ( 30 days ) 30 days

sodium dimethyl

dithiocarbamate +

thiosulfenic acid Hydrolysis pH 9 45714101 66.8% (13 days ) 66.8% (34 days ) 34 days

CO 2 carbon dioxide Aerobic soil 43734901 9% (4 days ) 74.9% ( 205 days ) 205 days

CS 2 carbon disulfide Hydrolysis pH 9 & Aqueous photolysis 43999801 35% (30 days ) 30 days

Anaerobic

Aquatic 43628501 17% (7 days)Page 17 of 60 

# 6. Receptors

Table 8 and Table 10 provide a summary of the aquatic and terrestrial taxonomic groups, respectively, and most sensitive surrogate species tested to characterize the potential acute and chronic ecological effects of thiram. Tables 9 and 11 provide this same information

, as available,

for ferbam

. A complete list of the ecotoxicity data available for thiram

, ferbam, and the related dimethyldithiocarbamate ziram can be found in Appendix D

.



## 6.1. Effects to Aquatic Organisms

Thiram and ferbam are highly to very highly toxic to freshwater and estuarine/marine fish and aquatic invertebrates on an acute exposure basis. Chronic ef fects on growth and reproduction are seen consistently across tested aquatic species with NOAEC s of approximately 0.0 0 2 to 0.02 mg a.i./L. A mysid chronic study conducted with ferbam failed to establish a NOAEC (<0.0012 mg a.i./L). Effects of thiram on biomass and frond number were observed on tested non

- vascular and
vascular aquatic plant species , respectively

.

Addit ionally , a supplemental mesocosm study with T hiram 80WG was designed to simulate effects of spray drift to a freshwater ecosystem (MRID 46249304). Phytoplankton taxa abundance, diversity, evenness, and similarity were significantly reduced at 0.32 mg a.i./L (NOAE C = 0.1 0 mg a.i./L). Zooplankton taxa abundance was significantly reduced at 0.010 mg a.i./L (NOAEC = 0.0032 mg a.i./L) and zooplankton community similarity was affected at the lowest tested concentration (NOAEC <0.001). Macrozoobenthic community similarit y was impacted at 0.10 mg a.i./L (NOAEC = 0.032 mg a.i./L). No treatment

- related effects were observed for the emergent insect community up to the highest concentration tested, 1.0 mg a.i./L. Population densities of the aquatic snail Gyraulus albus and the leech Helobdella stagnalis were reduced at 0.10 mg a.i./L (NOAEC = 0.032 mg a.i./L).

Table 8

. Summary of Most Sensitive Toxicity Endpoints for Aquatic Organisms Exposed to Thiram

Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured mg a.i./L (Acute Toxicity Category or Most Sensitive Endpoints ) MRID and Study
Classification

Aquatic Vertebrates

Freshwater

fish Acute TGAI (80%) Harlequin Fish ( Rasbora heteromorpha ) 96

- hr LC 50 = 0.007 (Very highly toxic) 05020144 Supplemental

Chronic (Full Life

Cycle ) TGAI (98.7%) Fathead minnow ( Pimephales promelas ) 210

- d NOAEC = 0.0011

210

- d LOAEC = 0.0022 (Spawning frequency, egg production, time to hatch, 4

- week survival) 47824101 Acceptable

Estuarine/

marine fish Acute TGAI (98.3%) Sheepshead Minnow ( Cyprinodon variegat u s ) 96

- hr LC 50 = 0.54 (Highly toxic) 42514401 Acceptable

Chronic No data availablePage 18 of 60 Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured mg a.i./L (Acute Toxicity Category or Most Sensitive Endpoints ) MRID and Study
Classification

Aquatic Invertebrates

Freshwater

invertebrates Acute TGAI (98.0%) Water Flea ( Daphnia magna ) 48

- hr EC 50 = 0.21 (Highly toxic) 00164662 Acceptable

Chronic TGAI (98.7%) Water Flea 21

- d NOAEC = 0.020

21

- d LOAEC = 0.040 (Dry weight, clinical signs of toxicity) 47495001 Acceptable

Estuarine/

marine

invertebrates Acute (Larval develop

ment) TGAI (98.3%) Pacific Oyster ( Crassostrea gigas ) 48

- hr EC 50 = 0.0047 (Very highly toxic) 42488301 Acceptable

Acute TGAI (98.3%) Mysid Shrimp ( Mysidopsis bahia ) 96

- hr LC 50 = 0.00336 ( Very highly toxic ) 42488302 Acceptable

Chronic No data available
Aquatic Plants

Aquatic plants and algae Vascular TGAI (98.7%) Duckweed ( Lemna gibba ) 7

- d NOAEC < 0.057

7

- d EC 50 = 1.6 (Frond number) 45441202 Acceptable

Non

vascular TGAI (99.0%) Green Algae ( Pseudokirchneriella subcapitata ) 120

- hr EC 0 5 = 0. 003

120

- hr EC 50 = 0.14 (Biomass) 44086101,

44086001 Acceptable



### Table 9 . Summary of Most Sensitive Toxicity Endpoints for Aquatic Organisms Exposed to Ferbam

Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured mg a.i./L (Acute Toxicity Category or Most Sensitive Endpoints ) MRID and Study
Classification

Aquatic Vertebrates

Freshwater

fish Acute TGAI (% unknown) Carp ( Cyprinus carpio ) 48

- hr LC 50 = 0.09 (Very highly toxic) 05001997 Supplemental

Chronic No data available

Estuarine/

marine fish Acute TGAI (76%) Longnose killifish ( Fundulus similis ) 96

- hr LC 50 = 0.80 (Highly toxic) 40228401 Supplemental

Chronic No data available
Aquatic Invertebrates

Freshwater

invertebrates Acute No data available

Chronic No data available

Estuarine/

marine

invertebrates Acute (Shell Deposition) TGAI (76%) Eastern Oyster ( Crassostrea

virginica ) 96

- hr EC 50 = 0.052 (Very highly toxic) 40228401 Supplemental

Acute TGAI (76%) Pink Shrimp ( Penaeus duorarum ) 48

- hr LC 50 > 40 (Slightly toxic) 40228401 Supplemental

Chronic TGAI (97.6%) Mysid Shrimp ( Americamysis

bahia ) 28

- d NOAEC < 0.0012

28

- d LOAEC = 0.0012

F 0 body length 47784401 SupplementalPage 19 of 60 Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured mg a.i./L (Acute Toxicity Category or Most Sensitive Endpoints ) MRID and Study
Classification

Aquatic Plants

Aquatic plants and algae Vascular No data available

Non

vascular No data available



## 6.2. Effects to Terrestrial Organisms

Thiram and ferbam are slightly to moderately toxic to birds and mammals on an acute exposure basis. In chronic studies, the most sensitive endpoints for birds were measures of reproductive output and viability while the mo st sensitive endpoints f or mammals were growth related. Toxicity studies on birds may provide some insight into whether the repellency properties for mammals also apply to birds. The acute oral and sub

- acute dietary studies were conducted by

federal labora tories in the 1970s and 1980s, and the associated food consumption and body weight data are not available. An avian reproduction study on bobwhite quail showed reductions in food consumption and hen bodyweight at 2500 ppm, the highest concentration tested (MRID 43612502). Food consumption and bodyweight were not affected in the avian reproduction study on mallard duck, up to 40 ppm (MRID 45441201). These studies also d emonstrated that the bobwhite quail and mallard duck will ingest a sufficient amount of tr eated feed to cause adverse reproductive effects.

Feeding choice studies with bobwhite quail and mallard ducks have demonstrated that while birds prefer untreated feed to feed treated with thiram, they will still consume the treated feed in quantities sh own to cause adverse reproductive effects (MRIDs 43612505, 43612506). Also, multiple field studies have demonstrated that granivorous birds will consume seeds treated with
thiram. Dhinsa et al. (1991) demonstrated that thiram did not effectively repel the common house crow from eating planted sunflower seeds treated with thiram. The study compared bird consumption of seek in plots of untreated sunflower seeds to plots of thiram treated sunflower seeds. The results showed no significant difference between se ed consumption between the untreated and treated plots. Furthermore, a Danish study found that more than half of the daily energy intake of pink

- footed geese ( Anser brachyrynchus ) could be obtained from foraging in newly

- sown fields. Also based on observat ions in fields sown with thiram

- treated peas, the study predicted that individuals consumed enough pesticide to elicit effects on reproduction in less than an hour (Madsen, 1996). Additionally, the European union risk assessment (Appendum to Monogram, Nove mber 2, 2002; Page 9

- 3) for thiram references a study which demonstrates that thiram may not serve as an effective avian repellant. The study results showed that when wheat seeds treated with 600 ppm of thiram were broadcasted on the ground at initial dens ities of 100
seeds/m 2 

### , 49 to 32% of the seeds were consumed within three days and were completely devoured them within seven days.

Thiram and ferbam are both practically non

- toxic to honey bees on an acute contact exposure basis. No other toxicity data ar e available for terrestrial invertebrates. No terrestrial plant toxicity
data are available for thiram or ferbam

.Page 20 of 60 

### Table 10

. Summary of Most Sensitive Toxicity Endpoints for Terrestrial Organisms Exposed to

Thiram

Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured a.i. (Acute Toxicity Category
or Most Sensitive Endpoints ) MRID and Study
Classification

Birds Acute Oral TGAI (99.0%) Ring

- neck Pheasant ( Phasianus

colchicus ) LD 50 = 673 mg/kg

- bw (Slightly toxic) 00160000 Supplemental

TGAI (% unknown) Passerine: Red

- wing Blackbird ( Agelaius phoeniceus ) LD 50 >100 mg/kg

- bw (Moderately toxic) 00073683

, 00020560 Supplemental

Sub

- acute

dietary TGAI (95.0%) Bobwhite quail ( Colinus virginianus ) LC 50 = 3950 mg/kg

- diet (Slightly toxic) 00022293 Acceptable

Chronic TGAI (98.7%) Mallard duck (Anas platyrhynchos) NOAEC = 9.6 mg/kg

- diet LOAEC = 39.7 mg/kg

- diet (E ggs set, viable embryos,

live 3

- wee k embryos, normal

hatchlings, 14

- d survivors, eggs set/eggs laid, normal

hatchlings/live 3

- w ee k embryos, normal hatchlings/eggs laid ) 45441201 Acceptable

Mammals 1 Acute Oral TGAI (99.0%)

Laboratory rat ( Rattus norvegicus ) LD 50 = 1800 mg/kg

- bw (Slightly toxic) 00153548 Acceptable

Acute

Inhalation TGAI (% unknown) 2.60 < LC 50 < 5.04 mg/L 40216501 Acceptable

Chronic (2

- generation reproduction) TGAI (100%) NOAEC = 1.4 mg/kg

bw/day LOAEC = 4.2 mg/kg

bw/day (F0 & F1 body weight) 45441203 Acceptable

Terrestrial

Invertebrates Acute

contact TGAI (% unknown) Honey bee ( Apis mellifera ) 48

- hr LD 50 = 73.72 μg/bee (Practically non

- toxic) 00036935 Acceptable

Terrestrial

Plants Seedling Emergence No data available

Vegetative Vigor No data available

1 Mammalian toxicity endpoints provided and reviewed by the U.S. EPA Office of Pesticide Programs Health Effects

Division (HED).



### Table 11 . Summary of Most Sensitive Toxicity Endpoints for Terrestrial Organisms Exposed to

Ferbam

Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured a.i. (Acute Toxicity Category
or Most Sensitive Endpoints ) MRID and Study
Classification

Birds Acute Oral No data availablePage 21 of 60 Taxonomic

Group Study Type Test
Substance

(% a.i.) Surrogate Species Toxicity Value

measured a.i. (Acute Toxicity Category
or Most Sensitive Endpoints ) MRID and Study
Classification

Sub

- acute

dietary TGAI (% unknown) Bobwhite quail ( Colinus virginianus ) LC 50 = 2940 mg/kg

- diet (Slightly toxic) 00106146 Supplemental

Chronic No data available

Mammals 1 Acute Oral TGAI (91.8%) Laboratory rat ( Rattus norvegicus ) LD 50 >5,000 mg/kg

- bw (Practically non

- toxic) 40561501 Acceptable

Acute

Inhalation TGAI (91.8%) LC 50 = 0.40 mg/L (Toxicity Category II

– Moderately toxic) 41508101 Acceptable

Chronic No data available

Terrestrial

Invertebrates Acute

contact Fermate
Formulation Honey bee ( Apis mellifera ) 48

- hr LD 50 >12.09 μg/bee (Practically non

- toxic) 00036935 Acceptable

Terrestrial

Plants Seedling Emergence No data available

Vegetative Vigor No data available

1 Mammalian toxicity endpoints provided and reviewed by the U.S. EPA Office of Pesticide Programs Health Effects

Division (HED).



## 6.3. Ecological Incidents

The ecological incident information system (EIIS) is an OPP database that houses ecological

incidents that ha ve been reported to the Agency. When available, EIIS includes date and location of an incident, type and magnitude of effects observed in various species, use(s) of pesticides known or suspected of contr ibuting to the incident, and results of any chemical residue analysis or other analyses conducted during incident investigation. EIIS incidents are categorized according to the certainty that the incident resulted from pest icide exposure. The Avian

Monitor ing System (AIMS) is a database administered by the American Bird Conservancy that contains publicly available data on reported avian i ncidents involving pesticides. Many of the

incidents listed in this database are also in the EIIS. Additionally, the U.S. EPA Office of Pesticide Progr ams Incident Data System (IDS) compiles aggregate incidents reported to the agency. These reports do not include detailed information about the incidents. An absence of reports does not necessarily equate to an absence of inci dents given the nature of incident reporting.

EIIS returned one fish incident and one bird incident for thiram . The fish inciden t, I025285

- 001,

occurred in Indiana in 1999, when 4.6 million fish over 50 miles were killed as a result of an intentional misuse involving discharge into a river. This incident was attributed to thiram exposure with “highly probable” certainty. The bird incident, I005754

- 012, occurr ed in California in 1972 when 200 cedar waxwings were found dead in a residential area. No detectable residues were found in tissue samples or on food sources and the incident was considered unlikely to have been caused by thiram exposure. The birds were f eeding on pyracantha berries, which can intoxicate birds when they are fermented. This incident was alsoPage 22 of 60 

### reported in AIMS. No incidents were reported for ferbam in EIIS or AIMS. Based on information in IDS, n o aggregate incidents were reported by registran ts for thiram or ferbam.



# 7. Exposure Pathways of Concern

The environmental fate properties and use patterns of thiram and ferbam indicate that direct spray, spray drift, and runoff represent potential transport mechanisms to aqu atic and terrestrial organism s. Thiram residues appear to have low mobility in the environment and would not be expected to leach. Consumption of treated seeds by birds and mammals and consumption of seedlings from seeds treated with thiram may also pose a risk of concern (USEPA, 2004 a). The repellent nature of thiram at dietary concentrations sufficient to cause acute lethality may mitigate the concern for acute risk to birds and mammals. However, this is not the case for

concentrations of concern for chronic risk (see discussion in S ection 6 )

.

Drinking water and inhalation exposure pathways were screened using the SIP (Screening Imbibition Program) and STIR (Screening Tool for Inhalation Risk) screening methods with

thiram data . SIP results indicated that drinking water alone is a po tential chronic exposure pathway of concern for birds and mammals (see Appendix A ). STIR results showed that droplet inhalation may be an exposure pathway of concern for birds, but exposure via vapor inhalation is not likely to be significant (see Appendix B ). This is based on the highest ground application rate for golf course turf (16.3 lbs a.i./A) ; however, droplet exposure from this use is expected to be limited as birds are likely to leave the field during a ground application

. If the highest aerial

ap plication rate is modeled (strawberry, 3.3 lbs a.i./A), STIR results show no risk concerns for

birds or mammals. The STIR output is based on a lower bound rat inhalation toxicity endpoint (2.60 < LC 50 

### < 5.04 mg/L ) and therefore may overestimate the potenti al for risk. SIP and STIR

are described in detail at: http://www.epa.gov/oppefed1/models/terrestrial/index.htm

.



# 8. Analysis Plan

8.1. Stressors of Concern

For both ferbam and thiram, thiram is the stressor of concern for both the ecological and drinking water risk assessments for registration review. The major degradates of thiram, COS, CS 2 

### , and

CO 2 

### , are volatile compounds and are not expected to persist in water or soil. CS 2 

### may cause respi ratory distress to wildlife in the immediate area if it is if inhaled. 4 

### This exposure pathway

for CS 2 

### will be considered in the risk assessment.



## 8.2. Measures of Exposure

EFED will use standard available models to evaluate potential exposures to aquatic and terrestrial organisms as described at http://www.epa.gov/oppefed1/models/water/index.htm and

4 See http://www.epa.gov/ttnatw01/hlthef/carbondi.html#ref1 and http://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=474&tid=84 for additional information on car bon disulfide.Page 23 of 60 

### http://www.epa.gov/pesticides/science/models_db.htm

. T he Surface Water Concentration Calculator (SWCC) is currently the model typically use d to estimate aquatic exposure. T

- REX and TerrPlant are currently m odels typically used to estimate terrestrial exposure. Thiram’s use as a wildlife repellent will be considered when characterizing potential exposure to terrestrial

animals.

Exposure to ferbam (X) will be calculated in thiram equivalents (Y) using the mol ecular weight conversion detailed in the following equation. This equation assumes that for every two ferbam molecules, three thiram molecules are formed. This is consistent with the approach used in the ferbam RED (USEPA, 2004b).

Y lb thiram/A = X lb fer bam/A * [(240.43 g/mole thiram * 3) / (416.49 g/mole ferbam * 2)]

This equation simplifies to:

Y lb thiram/A = X lb ferbam/A * 0.865

At this time, there are limited monitoring data available for thiram in either ground or surface

wate r, with no reported detections. The Pesticides in Ground Water Database (1991) contains no records for thiram; STORET co ntains no detections of thiram. No detections of thiram have been

repor ted to the Agency under 6(a)2. The US Geological Survey National Water Quality Assessment program (NAWQA) is not currently analyzing for thiram in their samples, and they do not have analytical methods in place for this chemical.



## 8.3. Measures of Effect

Toxicity data presented in Section 6 of this problem formulation will be used to calculate risk quotients. Thiram toxicity data will be used to evaluate both ferbam and thiram uses

. Where data

a re available for ferbam and the endpoints are lower (more toxic) than the equivalent study with thiram, the ferbam data will be used to evaluate ferbam uses. Any additional information submitted by the registrant or found in the open literature prior to co n duct of the risk assessment

will also be considered. The open literature studies are identified using EPA’s ECOTOXicology

database ( ECOTOX) (USEPA, 2007), which employs a literature search engine for locating chemical toxicity data for aquatic life, terre strial plants, and wildlife. The evaluation of both sources of data can also provide insight into the direct and indirect effects of pesticides on biotic communities from loss of species that are sensitive to the chemicals and from changes in

structure and functional characteristics of the affected communities.



## 8.4. Endangered Species Assessments

Consistent with EPA’s responsibility under the Endangered Species Act (ESA), the Agency will evaluate risks to federally listed threatened and endangered (listed) species from registered uses of pesticides in accordance with the Joint Interim Approaches developed to implement the recommendations of the April 2013 National Academy of Sciences (NAS) report, Assessing

Risks to Endangered and Threatened Species from Pesticides

. The NAS report outlines recommendations on specific scientific and technical issues related to the development ofPage 24 of 60 

### pesticide risk assessments t hat EPA and the Services must conduct in connection with their obliga tions under the ESA and FIFRA. EPA will address concerns specific to thiram and ferbam in connection with the development of its final registration review decision for thiram and

ferbam

.

In November 2013, EPA, the U.S. Fish and Wildlife Service, National Marine Fisheries (the Services), and USDA released a white paper containing a summary of their joint Interim Approaches for assessing risks to listed species from pesticides. These Inte rim Approaches were developed jointly by the agencies in response to the NAS recommendations, and reflect a common approach to risk assessment shared by the agencies as a way of addressing scientific

differences between the EPA and the Services. Details of the joint Interim Approaches are contained in the November 1, 2013 white paper

, Interim Approaches for National

- Level Pesticide Endangered Species Act Assessments Based on the Recommendations of the Na tional Academy of Sciences April 2013 Report.

Given that the agencies are continuing to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticides to listed species and their designated critical habitat, this ecological problem formulation supporting the Preliminary Work

Plan for thiram and ferbam does not describe the specific ESA analysis, including effects determinations for specific listed species or designated critical habitat, to be conduct ed during registration review. While the agencies continue to develop a common method for ESA analysis, the planned risk assessment for the registration review of thiram and ferbam will describe the level of ESA analysis completed for this particular registration r eview case. This assessment will allow EPA to focus its future evaluations on the types of species where the potential for effects exists, once the scientific methods being developed by the agencies have been fully vetted. Once the agencies have fully deve loped and implemented the scientific methods necessary to complete risk assessments for listed species and their designated critical habitats, these methods will be applied to subsequent analyses of thiram and ferbam as part of completing this registration

review.



## 8.5. Endocrine Disruptor Screening Program

Thiram and ferbam were not included in the first group of 67 chemicals issued an orde r to conduct Tier 1 EDSP testing

. Th iram and ferbam are not on the second list of chemicals for Tier 1 screening

. For additional information the EDSP program, visit http://www.epa.gov/endo/

.



# 9. Preliminary Identification of Data Gaps

9.1. Environmental Fate

Table s 1 2 and 1 3 identif y environmental fate studies by MRID for ferbam and thiram, respectively, that offer data for each guideline requirement, as well as study classifications and

whether or not fu rther data are needed in order to support risk assessment.Page 25 of 60 

### A cceptable guideline studies on hydrolysis and adsorption/desorption have not been submitted

for thiram

. However, the supplemental data listed in the tables below can be used in conjunction with the acceptable guideline study data to quantitatively assess the environmental fate of the

chemical.

Independently validated environmental chemistry methods (ECM/ILV) for measuring thiram in

soil and water are available. W hile separate methods are not available for ferbam, the thiram methods are fully adequate to assess residues from a ferbam treated field.

Table 1 2

. Submitted Environmental Fate Data for Ferbam

OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classifications Are Additional

Data Needed to
Conduct Risk

Assessment?

835.2120 Hydrolysis 45714101

41840601 S upplemental

S upplemental No

835.2240 Photodegradation in

Water 45651201

41758301 A cceptable

S upplemental No

835.2410 Photodegradation on Soil 45724501

43661801 A cceptable

I nvalid No

835.4100 Aerobic Soil

Metabolism 43734901 A cceptable No

835.4200 Anaerobic Soil

Metabolism 40768103 I nvalid No

835.4300 Aerobic Aquatic

Metabolism 45243401 A cceptable No

835.4400 Anaerobic Aquatic

Metabolism 43628501 A cceptable No

835.1230

835.1240 Leaching

Adsorption/Desorption 43787501 S upplemental No

835.6100 Terrestrial Field Dissipation 44724501

44724502 S upplemental

A cceptable No



### Table 1 3 . Submitted Environmental Fate Data for Thiram

OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classification s Are Additional

Data Needed to
Conduct Risk

Assessment?

835.2120 Hydrolysis 45714101

41840601 S upplemental

S upplemental No

835.2240 Photodegradation in

Water 45651201

41758301 A cceptable

S upplemental NoPage 26 of 60 835.2410 Photodegradation on

Soil 45724501

43661801 A cceptable

I nvalid No

835.4100 Aerobic Soil

Metabolism 43734901 A cceptable No

835.4200 Anaerobic Soil

Metabolism 40768103 I nvalid No

835.4300 Aerobic Aquatic

Metabolism 45243401 A cceptable No

835.4400 Anaerobic Aquatic

Metabolism 43628501 A cceptable No

835.1230

835.1240 Leaching

- Adsorption/ Desorpti o n 43787501 S upplemental No

835.6100 Terrestrial Field Dissipation 44724501

44724502 S upplemental

A cceptable No



## 9.2. Effects

Table s 1 4 and 1 5 identif y aquatic and terrestrial ecological effects studies , respectively, by MRID that offer data for each guideline requirement, as well as study classifications and whether or not further data are needed in order to support risk assessment. These tables are presented only for thiram because thiram toxicity data is considered sufficient for the assessment of both ferbam

and thiram uses. No additional toxicity data on ferbam are requested. Rationale for the additional

non

- guideline data requested is presented below the tables.

Table 1 4

. Submitted Aquatic Ecological Effects Data for Th iram

OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classifications Are Additional

Data Needed to
Conduct Risk
Assessment? Current Additional Data

Need

850.1010 Freshwater

invertebrate acute toxicity 00164662 Acceptable No None

850.1025

850.1035

850.1045

850.1055 Saltwater

invertebrate acute toxicity 42488301 Acceptable

No None

42488302 Acceptable

850.1075 Freshwater fish acute toxicity TN 996 Acceptable

No None TN 1001 Acceptable

00002923 /

00021610 Supplemental

00090293 Supplemental

00090294 Supplemental

05020144 SupplementalPage 27 of 60 OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classifications Are Additional

Data Needed to
Conduct Risk

Assessment? Current Additional Data

Need

46249301 Supplemental

850.1075 Saltwater fish acute toxicity 42514401 Acceptable No None

850.1300 Freshwater

invertebrate

life cycle 47495001 Acceptable No None

850.1350 Saltwater

invertebrates

life cycle None NA Yes Data are needed to reduce uncertainty in the

assessment of chronic risk

to estuarine/marine

invertebrates. A chronic mysid study conducted

with ferbam (MRID 47784401) did not

establish a NOAEC. A new study with thiram is

recommended.

850.1400 Freshwater f ish early

- life stage 46249303 Supplemental

No None 47495002 Not reviewed (preliminary

report for 850.1500)

850.1400 Saltwater fish early

- life stage None NA Yes Data are needed to reduce uncertainty in the

assessment of chronic risk

to estuarine/marine fish.

850.1500 Fish life cycle 47824101 Acceptable No None

850.1735 Whole sediment 10

- d

freshwater

invertebrate None NA No None. Thiram is not expected to accumulate in

sediment.

850.1740 Whole sediment 10

- d

estuarine/marine

invertebrate None NA No None. Thiram is not expected to accumulate in

sediment.

850.4400 Aquatic plant Toxicity Test using Lemna spp. 45441202 Acceptable No None

850.4500 Algal toxicity 44086001 /

44086101 Acceptable Yes Studies with two additional species will reduce uncertainty in the

assessment of risk to non

vascular plants . Suggested species are the freshwater

diatom Navicula pelliculosa and the marine

diatom Skeletonema

costatum

.Page 28 of 60 OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classifications Are Additional

Data Needed to
Conduct Risk

Assessment? Current Additional Data

Need

850.4550 Cyanobacteria None NA Yes A cyanobacteria will reduce uncertainty in the

assessment of risk to non

vascular plants.



### Table 1 5

. Submitted Terrestrial Ecological Effects Data for Th iram

OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classifications Are Additional

Data Needed to
Conduct Risk

Assessment? Current Additional Data

Need

850.2100 Avian oral toxicity 00160000 Acceptable

Yes A n acceptable study with a passerine species will reduce uncertainty in the

assessment of risk to birds. 00073683/

00020560 Supplemental

850.2200 Avian dietary toxicity 00022293 Acceptable No None

850.2300 Avian reproduction 43612501 Supplemental

No None 43612502 Acceptable

45441201 Acceptable

Non

guideline Avian inhalation None NA No While STIR indicated a potential risk to birds from droplet inhalation, this was only for ground applications and the inhalation toxicity endpoint

used was a lower bound

estimate. R isk concerns

from this exposure pathway are expected to be minor compared to diet ary exposure and a study is not requested at this time.

850.3020 Honey bee acute contact toxicity 00036935 Acceptable No None

850.3030 Honey bee residue on foliage None NA No None. Acute contact toxicity endpoint is >11 μg/bee.

850.3040 Field testing for pollinators (Tier III) None NA Yes See justification tables

below for additional

details.

Non

guideline

(Tier I) Honey bee adult acute oral toxicity None NA Yes An adult acute oral study will reduce uncertainty in

the risk assessment for pollinators. See justification tables below

for additional details.Page 29 of 60 OCSPP
Guideline Data Requirement Submitted
Studies (MRID) Study
Classifications Are Additional

Data Needed to
Conduct Risk

Assessment? Current Additional Data

Need

Non

guideline

(Tier I) Honey bee larvae

acute toxicity None NA Yes A larvae acute study will reduce uncertainty in the

risk assessment for

pollinators. See justification tables below

for additional details.

Non

guideline

(Tier I) Honey bee adult chronic 10d toxicity None NA Yes An adult chronic oral study will reduce uncertainty in

the risk assessment for pollinators. See justification tables below

for additional details.

Non

guideline

(Tier I) Honey bee larvae chronic toxicity None NA Yes A larvae chronic study will reduce uncertainty in the

risk assessment for

pollinators. See justification tables below

for additional details.

Non

guideline (Tier II) Semi

- field testing for pollinators (tunnel or colony feeding studies) None NA Yes See justification tables

below for additional

details.

Non

guideline (Tier II) Field trial of residues in pollen

and nectar None NA Yes See justification tables

below for additional

details.

850.4100 Seedling Emergence None NA Yes A seedling emergence study will reduce uncertainty in the

assessment of risk to

terrestrial plants.

850.4150 Vegetative Vigor None NA Yes A vegetative vigor study will reduce uncertainty in

the assessment of risk to

terrestrial plants.



### Study Title: Pollinator Acute Oral Toxicity, Adult Rationale for Requiring the Data Terrestrial invertebrates are likely to be impacted if exposed to pesticides in various use settings. Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to the hive. Therefore, potential acute effects to adult honeybees and other pollinators from oral exposure to some pesticides could exist. Currently available toxicity studies do not address possible effects of oral exposure on adult terrestrial insect survival. Because of the potential for pollen and nectar to be contaminated with pesticide residues, and subsequently brought back to the hive, it is important to determine the acute oral toxicity of thi s compound to adult honeybees and other insect pollinators.

The Office of Pesticide Programs has made available a guidance regarding ecological testing forPage 30 of 60 

### terrestrial invertebrates using the honeybee as a surrogate test species. The guidance discusses Ti er I laboratory

- based acute oral toxicity studies of individual adult bees as a critical component of the screening

- level risk assessment process for examining potential adverse effects from specific routes of exposure. The guidance can be found at: http://www2.epa.gov/pollinator

- protection/pollinator

- risk

assessment

- guidance . Additional guidance on the honeybee oral toxicity test design can be found in

OECD Test Guideline 213 http://www.oecd

- ilibrary.org/en vironment/test

- no

- 213

- honeybees

- acute

oral

- toxicity

- test_9789264070165

- en

. Practical Utility of the Data

How will the data be used? The Tier I acute oral toxicity d ata on adult bees serve as a foundation for the screening

- level assessment of potential risk to non

- target organisms such as federally listed threatened or endangered

and non

- listed terrestrial invertebrate insects, including pollinators, from acute oral e xposures to pesticides. The data will be used to reduce uncertainties associated with the risk assessment for terrestrial invertebrates and will improve EPA’s understanding of the potential direct and indirect effects on a broad range of taxa. This study w ill also provide information with which to compare whether oral toxicity estimates differ from contact toxicity estimates obtained from other Tier I studies. If acute oral effects data for adult honeybees and insect pollinators are not available, risks to terrestrial insects from acute oral exposure will be assumed.

How could the data impact the Agency’s future decision

- making? The data will inform the determination required under FIFRA or the ESA as to whether continued registration of a pesticide is like ly to result in unreasonable adverse effects to non

- target species or is likely to adversely affect listed threatened or endangered species and/or modify their designated critical habitat. Without these data, EPA may need to presume risk which will limit t he flexibility of pesticide products to comply with FIFRA and the ESA, and could result in use restrictions.

Study Title: Pollinator Acute Oral Toxicity, Larvae Rationale for Requiring the Data Terrestrial invertebrates are likely to be impacted if exposed to pesticides in various use settings. Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to the hive where larvae and pupae may be ex posed. Therefore, potential adverse effects to developing bees and other insect pollinators could result from exposure to pesticide residues. Available toxicity studies do not address possible effects on brood (larvae and pupae) survival/development.

Becau se of the potential for pollen and nectar to be contaminated with pesticide residues, and subsequently brought back to the hive, it is important to determine the acute oral toxicity of this compound to bee brood.

The Office of Pesticide Programs has made available a guidance regarding ecological testing for terrestrial invertebrates using the honeybee as a surrogate test species. The guidance discusses Tier I laboratory

- based acute toxicity studies of individual honeybee larvae as a critical component of the screening

- level risk assessment process for examining potential risks from specific routes of exposure. The guidance can be found at: http://www2.epa.gov/poll inator

- protection/pollinator

- risk

- assessment

guidance . Additional guidance on larval honeybee toxicity test design can be found in OECD Test

Guideline 237 http://www.oecd

- ilibrary.org/environment/test

- no

- 237

- honey

- bee

- apis

- mellifera

- larval

toxicity

- test

- single

- exposure_9789264203723

- en

. Practical Utility of the Data

How will the data be used?

The Tier I acute oral toxicity d ata on honeybee larvae serve as a foundation for the screening

- levelPage 31 of 60 

### assessment of potential risk to non

- target organisms such as federally listed threatened or endangered

and non

- listed terrestrial invertebrate insects, including pollinator s, and/or modify their designated critical habitat from acute oral exposures to pesticides. The data will be used to reduce uncertainties associated with the risk assessment for terrestrial invertebrates and will improve EPA’s understanding of the potentia l effects on terrestrial species and whether there is a differential sensitivity of larval bees relative to adult bees. If acute oral effects data for larvae are not available, risks to terrestrial insects from acute oral exposure will be assumed.

How cou ld the data impact the Agency’s future decision

- making? The data will inform the determination required under FIFRA or the ESA as to whether continued registration of a pesticide is likely to result in unreasonable adverse effects to non

- target species or is likely to adversely affect listed threatened or endangered species and/or modify their designated critical habitat. Without these data, EPA may need to presume risk which will limit the flexibility of pesticide products to comply with FIFRA and the ESA, and could result in use restrictions.

Study Title: Pollinator Chronic Oral Toxicity, Adult Rationale for Requiring the Data Terrestrial invertebrates are likely to be impacted if exposed to pesticides in various use settings. Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to the hive. Therefore, potential chronic effects to adult honeybees and other pollinators from oral exposure to some pesticides could exist. Currently available toxici ty studies do not address possible lethal and sublethal effects of chronic oral exposure on adult terrestrial invertebrates and will assist in determining whether the sensitivity of adult bees differs from that of earlier life stages. Because of the
potent ial for pollen and nectar to be contaminated with pesticide residues, and subsequently brought back to the hive, it is important to determine the chronic oral toxicity of this compound to adult honeybees and other pollinators.

The Office of Pesticide Prog rams has made available a guidance regarding ecological testing for invertebrates with the honeybee. The guidance discusses Tier I laboratory

- based chronic oral toxicity studies of individual adult honeybees as a critical component of the screening

- level r isk assessment process for examining potential risks from specific routes of exposure. The guidance can be found at: http://www2.epa.gov/pollinator

- protection/pol linator

- risk

- assessment

- guidance . Study design elements

for the chronic 10

- day oral toxicity test with honeybees are similar to the OECD Test Guideline 213 acute oral toxicity test http://www.oecd

- ilibrary.org/environment/test

- no

- 213

- honeybees

- acute

- oral

toxicity

- test_9789264070165

- en

. Practical Utility of the Data

How will the data be used? The Tier I chronic oral toxicity d ata on adult bees serve as a foundation for the screening

- level assessment of potential risk to non

- target organisms including federally listed threatened or endangered species and non

- listed terrestrial invertebrate insects, including pollinators, from chronic o ral exposures to pesticides. The data will be used to reduce uncertainties associated with the risk assessment for terrestrial invertebrates and will improve EPA’s understanding of the potential direct and indirect lethal

and sublethal effects on a broad r ange of terrestrial species, particularly insect pollinators and to determine whether adult toxicity differs substantially from other life stages evaluated in other Tier I tests. If chronic oral effects data for adults are not available, risks to terrestri al insects from chronic oral exposure will be assumed.

How could the data impact the Agency’s future decision

- making? The data will inform the determination required under FIFRA or the ESA as to whether continuedPage 32 of 60 

### registration of a pesticide is likely to result in unreasonable adverse effects to non

- target species or is likely to adversely affect listed threatened or endangered species and/or their designated critical habitat. Without these data, EPA may need to pre sume risk which will limit the flexibility of pesticide products to comply with FIFRA and the ESA, and could result in use restrictions.

Study Title: Pollinator Chronic Oral Toxicity, Larvae Rationale for Requiring the Data Terrestrial invertebrates are likely to be impacted if exposed to pesticides in various use settings. Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to the hive where larvae and pupae may be ex posed. Therefore, potential effects to developing bees could result from chronic oral exposure to pesticide residues. Available toxicity studies do not address possible chronic effects on brood (larvae and pupae) survival. Because of the potential for poll en and nectar to be contaminated with pesticide residues, and subsequently brought back to the hive, it is important to determine chronic larval/pupal toxicity and whether adult emergence is adversely affected. This study will provide information on whethe r honeybee larvae differ in sensitivity from adult bees following chronic exposure.

The Office of Pesticide Programs has made available a guidance regarding ecological testing for invertebrates with the honeybee. The guidance discusses Tier 1 laboratory

- based chronic oral toxicity studies of individual honeybee larvae as a critical component of the screening

- level risk assessment process for examining potential risks from specific routes of exposure. The guidance can be found at: http://www2.epa.gov/pollinator

- protection/pollinator

- risk

- assessment

- guidance

. Additional information on larval honeybee toxicity repeat exposure test design can be found in the

OECD draf t guidance http://www.oecd.org/env/ehs/testing/Draft_GD_honeybees_rep_exp_for_2nd_CR_25_November_201 3.pdf

. Practical Utility of the Data

How wi ll the data be used? The Tier I chronic oral toxicity d ata on bee larvae serve as a foundation for the screening

- level assessment of potential risk to non

- target organisms including federally listed threatened or endangered

and non

- listed terrestrial invertebrate insects, including pollinators, from chronic oral exposures to pesticides. The data will be used to reduce uncertainties associated with the risk assessment for terrestrial invertebrates and will improve EPA’s understanding of the potential di rect and indirect lethal and sublethal effects on a broad range of terrestrial species, particularly insect pollinators. These data will also assist in determining whether early life stages of the bee differ in their sensitivity to pesticides

relative to a dults. If chronic oral effects data for larvae are not available, risks to terrestrial insects from chronic oral exposure will be assumed.

How could the data impact the Agency’s future decision

- making? The data will inform the determination required under FIFRA or the ESA as to whether continued registration of a pesticide is likely to result in unreasonable adverse effects to non

- target species or is likely to adversely affect listed threatened or endan gered species and/or modify their designated critical habitat. Without these data, EPA may need to presume risk which will limit the flexibility of pesticide products to comply with FIFRA and the ESA, and could result in use restrictions.

Study Title: Pollinator Tier II Semi

- Field Toxicity Testing (tunnel/enclosure studies) Rationale for Requiring the Data Tier II studies are conditional on the outcome of the screening

- level assessment where acute and/orPage 33 of 60 

### chronic risk levels of concern have been exceeded for terrestrial invertebrates. Terrestrial invertebrates are likely to be impacted if exposed to pesticides in various use settings. Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to t he hive and may adversely affect developing brood (egg, larvae, and pupae) and adult bees . Screening

- level (Tier I) studies of individual bees do not address possible effects and/or exposure to pesticide residues at the colony

- level. Because of the potenti al for pollen and nectar to be contaminated with pesticide residues, and subsequently brought back to the hive, it is important to determine whether bee colonies may be negatively affected under relatively controlled exposure conditions of a semi

- field stu dy. In addition to providing effects data, these studies can provide data on exposure as pesticide residues in pollen/nectar of treated plants.

The Office of Pesticide Programs has made available a guidance regarding ecological testing for

invertebrates w ith the honeybee. The guidance describes the tiered testing process and can be found at: http://www2.epa.gov/pollinator

- protection/pollinator

- risk

- assessment

- guidance . Additional information on honeybee colony studies under semi

- field conditions can be found in the OECD Guidance 75 http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=env/jm/mono%28

. Practical Utility of the Data

How will the data be used? Tier II colony

- level data will be used to assess potential risk to non

- target organisms including listed

and non

- listed terrestrial social invertebrate species and to determine whether effects observed in the screening

- level (Tier I) laboratory

- based studies of individual bees are evident in co lony

- level studies

under semi

- field conditions. The Tier II semi

- field test of whole colonies is a relatively controlled study, i.e ., bees are confined to a specific area, that is designed to represent potential field

- level exposure and account for hive dy namics, which are not achievable from other pollinator studies. This study will be used to determine whether adverse effects to insect pollinators at the whole colony level, may result for the use of pesticides and will help to refine risk estimates derive d in the screening

- level risk assessment for beneficial terrestrial invertebrates. Measured residues in pollen/nectar can also be

used to refine risk estimates derived from model

- based or default values in the screening

- level

assessment.

How could the data impact the Agency’s future decision

- making? The data will inform the determination required under FIFRA or the ESA as to whether continued registration of a pesticide is likely to result in unreasonable adverse effects to non

- target species or is likely to adversely affect federally listed threatened or endangered species or their designated critical habitat. Without these data, EPA may need to presume risk which will limit the flexibility of pesticide products to comply with FIFRA and the ESA, and could result in significant use restrictions.

Study Title: Pollinator Tier II Semi

- Field Toxicity Testing (feeding studies)
Rationale for Requiring the Data
Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to the hive, and may adversely affect developing brood (egg, larvae, and pupae) and adult bees

. Tier II feeding studies are conditional on the outcome of the screening

- level assessment where acute

and/or chronic risk levels of con cern have been exceeded for terrestrial invertebrates based on Tier I studies of individual bees. Feeding studies utilize free foraging bee colonies that are “dosed” with specific quantities of test material and represent a means of ensuring exposure to th e test material through spiked pollen and/or sugar solutions fed to the colony while still allowing the bees to forage freely. Since bee colonies are not confined to enclosures, colonies can be exposed for longer duration periods without subjecting the bee s to stress that typically results from Tier II tunnel studies. Available toxicity studies of individual bees (Tier 1) conducted to support screening

- level assessments do notPage 34 of 60 

### address possible effects and/or exposure to pesticide residues at the colony

- leve l. Because of the potential for pollen and nectar to be contaminated with pesticide residues, and subsequently brought back to the hive, it is important to determine whether bee colonies may be negatively affected where bees are free foraging and have the option to collect/consume alternative forage items beyond the spiked food. Since multiple dose levels can be more readily tested, feeding studies can help to define

dose

- response relationships at the whole colony level.

The Office of Pesticide Programs ha s made available a guidance regarding ecological testing for invertebrates with the honeybee. The guidance describes the tiered testing process and can be found at: http://www2.epa.gov/pollinator

- protection/pollinator

- risk

- assessment

- guidance

. Additional information

on honeybee colony feeding studies can be found in the EPPO Guidance 170 at: http://www.nationalbeeunit.com/index.cfm?pageId=187

. Practical Utility of the Data

How will the data be used? Tier II colony feeding data will be used to assess potential risk to non

- target organisms including listed

and non

- listed terrestrial social invertebrate species. The colony feeding study is designed to represent potential field

- level exposure and account for hive dynamics using longer duration exposure periods than are possible in Tier II tunnel studies. The study will be used to determine whether potential adverse effects to insect pollinators at the whole colony level when bees are able to forage natural ly beyond the spiked food. Results from the feeding study will help to refine the screening

- level risk

assessment for beneficial terrestrial invertebrates that were based on Tier I studies on individual bees. Since feeding studies can help to define a dose

- response relationship at the colony level, the studies can provide a means of determining exposure thresholds below which the likelihood of adverse effects on colonies may be low.

How could the data impact the Agency’s future decision

- making?

Tier II co lony

- level data will be used to refine screening

- level risk estimates derived using Tier I laboratory

- based data on individual bees. The Tier II data will inform the determination required under FIFRA or the ESA as to whether continued registration of a pe sticide is likely to result in unreasonable

adverse effects to non

- target species or is likely to adversely affect federally listed threatened or endangered species or their designated critical habitat. Without these data, EPA may need to presume

risk whic h will limit the flexibility of pesticide products to comply with FIFRA and the ESA, and could result in significant use restrictions.

Study Title: Residues in Pollen and Nectar Rationale for Requiring the Data Terrestrial invertebrates are likely to be impacted if exposed to pesticide residues in various use settings. Pesticide residues may be transferred to pollen and/or nectar of treated plants and subsequently brought back to hive where all life stages may be exposed. For some pesticides, the
quant ification of pollinator

- relevant residues in treated flowering plants is needed, since pollinators will be exposed to residues from either current or prior season applications (due to the potential for residues to accumulate in plants and trees). Residues in edible/transportable

- to

- hive parts of treated trees and plants, including (where appropriate), but not limited to, guttation water, sap/resins, whole plant tissue ( e.g., leaves, stems), as well as blooming, pollen

- shedding, and nectar producing parts ( i .e. , flowers and, if present, extra

- floral nectaries) of plants may inform the potential for risk. Studies should be designed to provide residue data for crops and application methods of concern.

The Office of Pesticide Programs has made available a guida nce regarding ecological testing for invertebrates with the honeybee. The guidance can be found at: http://www2.epa.gov/pollinator

-Page 35 of 60 

### protection/pollinator

- risk

- asse ssment

- guidance

. Practical Utility of the Data

How will the data be used?

Measured residue d ata will be used to refine conservative estimates of pesticide exposure and reduce uncertainties associated with the Tier I exposure assessment by providing direct measurements of pesticide concentrations resulting from actual use settings. Measured residues may provide a more realistic understanding of exposure through contact or ingestion with which to calculate risk quotients

for individual bees as well as to characterize exposure to the colony. If measured residue data are not available, risk estimates for terrestrial insects will be based on model

- generated or default values used to support the screening

- level assessment.

How could the data impact the Age ncy’s future decision

- making? The data will inform the determination required under FIFRA or the ESA as to whether continued registration of a pesticide is likely to result in unreasonable adverse effects to non

- target species or is likely to adversely aff ect federally listed threatened or endangered species or their designated critical habitat. Without these data, EPA will have to rely on conservative estimates of exposure which will limit the flexibility of pesticide products to comply with FIFRA and the ESA, and could result in use

restrictions.



# 10. References

Dhinsa, Manjit S, P.S. Sandhu, Harjeet K. Saini, and H.S. Toor. 1991. House crow damage to sprouting sunflower. Department of Zoology, Punjab Agricultural University, Ludhiana, Punjab

- 141,004, India

Madsen, J. 1996. Exposure of spring

- staging pink

- footed geese Anser brachyrhynchus to pesticide

- treated seed. Wildlife Biology 2:1

- 9.

United States Environmental Pro tection Agency ( USEPA). 2004a. Carleton, J., F. Jenkins, and

W. Eckel. Environmental Fate and Ecological Risk Assessment for the Reregistration of

Thiram. U.S. Environmental Protection Agency, Office of Prevention, Pesticides, and Toxic Substances, Environmental Fate and Effects Division. Sept. 30 , 200 4.

USEPA. 2004 b . Federoff, N.E. and J. Melendez

. EFED RED Chapter for Fe r b am . DP B arcod e 281025

. U.S. Environmental Protection Agency, Office of Prevention, Pesticides, and Toxic Substances, Environmen tal Fate and Effects Division. Memorandum to the Special

Review and Reregistration Division. Dec . 2 2 , 200 4

.

USEPA. 2004 c

. Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs

. U.S. Environmental Protection Agency, Office of Pesticide Programs,

Environmen tal Fate and Effects Division . Available at http://www.epa.gov/espp/consultation/ecorisk

- overview.pdf

USEPA. 2007 . ECOTOXicology Database. Of fice of Research and Development National Health and Environmental Effects Research Laboratory’s (NHEERL’s) Mid

- Continent Ecology Division (MED). http://cfpub.epa.gov/ecotox/Page 36 of 60 

### USEPA. 2014a. Screening Level Usage Analysis (SLUA) for Ferbam (034801). U.S. Environmental Protection Agency, Office of Pesticide Programs, Biological and Economic Analysis Division. June 11, 2014.

USEPA. 2014b. Screening Level Usage Analysis (SLUA) for Thiram (079801). U.S.

Environmental Protection Agency, Office of Pesticide Programs, Biological and Economic Analysis Division. Nov. 4, 2014.

USEPA. 2015. Arnold, E. and R. Parker. Registration Review: Preliminary Problem Formulation for Environmental Fate, Ecological Risk, Endangered Spec ies, and Human Health Drinking Water Exposure Assessments for Ziram

. DP B arcode 427965. U.S. Environmental Protection Agency, Office of Chemical Safety and Pollution Prevention

, Environmental Fate and Effects Division. Memorandum to the Pesticide Re

- evaluation

Division.

USEPA, PMRA, and CDPR

. 2014. Guidance for Assessing Pesticide Risks to Bees. Office of Pesticide Programs, USEPA, Washington D.C. Health Canada Pest Management Regulatory Agency, Ottawa, ON, Canada. California Department of Pestic ide Regulation, Sacramento, CA. June 23, 2014.



## 10.1. Submitted Environmental Fate Studies

034801 Ferbam Fate Chemistry Bibliography Revised 21 May 2014

161

- 1 Hydrolysis

MRID Citation Reference

40088201 2002199
2002008 Warren, J. (1987) Determination of the Hydrolysis Rate of [Carbon 14]

- Ferbam: ABC Preliminary Report #34375. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 248 p.

44071801 2015163 Nixon, W.; Atkins, R. (1996) Hydrolysis of (car bon

- 14) Ferbam in Aqueous Buffered Solutions of pH 5, 7 and 9: Lab Project Number: 990: 1898: 95044. Unpublished study prepared by PTRL East, Inc. 150 p.



### 161

- 2 Photodegradation

- water

MRID Citation Reference

40088202 2002200
2002208 Warren, J. (1986) Determination of the Photolysis Rate of [Carbon 14]

- Ferbam: ABC Preliminary Report #34373. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 230 p.

43999801 2015164 Nixon, W. (1996) Aqueous Photolysis of (Carbon 14) Ferbam in Artificial Light: Lab Project Number: 1002: 1884. Unpublished study prepared by PTRL East, Inc. 123 p.



### 161

- 3 Photodegradation

- soil

MRID Citation Reference

40088203 2002201
2002208 Carpenter, M. (1987) Determination of the Photodegradation Rate of [Carbon 14]

- Ferbam: ABC Laboratory Project ID: #34374. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 192 p.Page 37 of 60 43999802 2015165 Nixon, W. (1996) Soil Surface Photolysis of (Carbon 14) Ferbam in Artificial Light: Lab Project Number: 1003: 1883. Unpublished study prepared by PTRL East, Inc. 100 p.



### 162

- 1 Aerobic soil metabolism

MRID Citation Reference

40550601 2002206
2002209 Daly, D. (1987) Aerobic Soil Metabolism of ?carbon 14|

- Ferbam: ABC Draft Final: 34369. Unpublished study prepared by ABC Laborat

- ories, Inc. 37 p.

44368901 2015166 Nixon, W.; Atkins, R.; Coody, P. (1997) Aerobic Soil Metabolism of (carbon 14 )Ferbam: (Final Report): Lab Project Number: 1004: 1903: 95047. Unpublished study prepared by PTRL East, Inc. 110 p.



### 162

- 2 Anaerobic soil metabolism

MRID Citation Reference

40365301 2002202
2002208 Daly, D. (1987) Anaerobic Soil Metabolism of [Carbon 14]

- Ferbam: ABC Preliminary Report #34370. Unpublished study prepared by ABC Laboratories, Inc. 226 p.

44565305 2015167 Coody, P.; Atkins, R. (1998) Anaerobic Metabolism of (carbon 14)Ferbam : Lab Project Number: 1005: 1969. Unpublished study prepared by PTRL East, Inc. 152 p.



### 162

- 3 Anaerobic aquatic metabolism

MRID Citation Reference

44565305 2015167 Coody, P.; Atkins, R. (1998) Anaerobic Metabolism of (carbon 14)Ferbam : Lab Project Number: 1005: 1969. Unpublished study prepared by PTRL East, Inc. 152 p.



### 163

- 1 Leach/adsorption/desorption

MRID Citation Reference

98839 Munnecke, D.E. (1961) Movement of nonvolatile, diffusible fungi

- cides through columns of soil. Phytopathology 51(Sep):593

- 599. (Also~In~unpublished submission received Jan 4, 1978 under

239

- 1246; submitted by Chevron Chemical Co., Richmond, Calif.; CDL: 232569

- S)

162088 2002222 Drury, P. (1986) Determination of Adsorptio n/Desorption Constants of [Carbon 14]

- Ferbam: ABC Preliminary Rept. #34371. Unpub

- lished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 282 p.

5001190 Helling, C.S.; Dennison, D.G.; Kaufman, D.D. (1974) Fungicide movement in soils. Phyto pathology 64(8):1091

- 1100.

40088204 2015168 Warren, J. (1986) Determination of Adsorption/Desorption Constants of [Carbon 14]

- Ferbam: ABC Laboratory ID: #34371. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 306 p.



### 164

- 1 Terrestrial field dissipation

MRID Citation Reference

40550902 2002205
2002209
2015169 Selman, F.; Moezpoor , E. (1988) Ferbam Peach Terrestrial Field Dissipation: Preliminary Report No. 35506. Unpublished study prepared by Analytical Bio

- chemistry Laboratories, Inc. 65 p.

40603401 2002204
2002209 Selman, F.; Moezpoor , E. (1988?) Ferbam Apple Terrestrial Field Dissipation: Preliminary Report No. 35507. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 138 p.Page 38 of 60 

### Non

- Guideline Study

MRID Citation Reference

11559 Richardson, L.T. (19??) The persistence of Thiram in soil and its relationship to the microbiological balance and damping

- off con

- trol. Canadian Journal of Botany 32(? ):335

- 346. (Also in un

published submission received Sep 26, 1972 under 1023

- 15; sub

- mitted by Upjohn Co.,
Ka lamazoo, Mich.; CDL:024388

- B)

117716. 2002203
2002008 Lemal, R. (1985) Determination of Vapor Pressure of Ferbam: [Iron tris (Dimethyldithiocarbamate)]:
LPCD No. 162

- 85. Unpublished study prepared by UCB. 4 p.

98833 Kluge, E. (1969) The Effect of the Soil Reaction on the Degradation and Persistence of Thiuram, Ferbam, and Captan in the Soil. A translation of: ?Without Title|. Archiv furer Pflanzenwchutz, 5(4):263

- 271. (Unpublished study received Jan 4, 1978 under 239

- 1246; submitted by Chevron
Chemical Co., Richmond, Calif.; CDL:232569

- J)

41340903 Vandegans, J. (1987) Determination of the Stability Constant of Iron III

- tris (N,N

Dimethyldithiocarbamate) or Ferbam: Lab Project Nos. F80312; UCB #F80312. Unpublished study prepared by C.P.R.S.

-- C.E.R.I.A . 18 p.



### 079801 Thiram Chemical Fate Bibliography Revised 21 July 2014

161

- 1 Hydrolysis

MRID Citation Reference

148414 2009574 Lemal , R. (1983) Note L.P.C.D. No. 80: TMTD [(Tetramethylthiuram Disulfide)]: Determination of Rate of Hydrolysis as a Function of pH. Unpublished translation of Note L.P.C.D. No. 80: DTMT: Determination de la Vitesse d'Hydrolyse a Differents pH prepared by UCB . 7 p. Same citation as

145796

149192 2009616
2075947

- draft Lemal, R. (1983) TMTD: Determination of Rate of Hydrolysis as a Function of pH: Aff. 2.24.007: Note L.P.C.D. No. 80. Unpublished translation of study prepared by UCB, Drogenbos Laboratories. 7 p.

40444703 2009617
2075948 Cranor, W. (1987) Determination of the Hydrolysis Rate of ?Carbon 14|

- Thiram: Laboratory Project ID: 34030. Unpublished study prepared by Analytical Bio

- Chemistry Laboraotries, Inc. 675 p.

41840601 2009626
2009637

- memo Norris, K. (1991) Determination of the Hydrolysis of ?carbon

- 14|

- Thiram: Lab Project Number:
91

- 007: 1156. Unpublished study prepared by Analytical Development Corp. 65 p.

42245602 2009574
2009637 Norris, K. (1991) Determination of Hydrolysis of ?carbon 14|

- Thiram: Addendum No. 1: Lab Project Number: 1156. Unpublished study prepared by Analytical Development Corp., (ADC). 7

p.

45714101 2011403
2013242 Shepler, K.; Runes, H. (2002) Hydrolysis of (C arbon 14) Thiram at pH 5, 7, and 9: Lab Project Number: 1041W. Unpublished study prepared by PTRL West, Inc. 110 p.

47337903 See 41840601 Norris, K. (1991) Determination of the Hydrolysis of (Carbon 14)

- Thiram. Project Number: 1156, 9106. Unpublished stu dy prepared by Analytical Development Corp., Inc. 38 p.



### 161

- 2 Photodegradation

- water

MRID Citation Reference

40444704 2009618 Cranor, W. (1987) Determination of the Photolysis Rate of ?Carbon 14|

- Thiram: Laboratory Project ID: 33571. Unpublished study prepared by ABC Laboraotries, Inc. 385 p.

41753801 2009625
see below Norris, K.J. 1991. Determination of the Aqueous Photodegradation of 14C

- Thiram. Performed by Analytical Development Corporation, Colorado Springs, CO. Submitted by Thiram Task Force.
MRID# 41753801Page 39 of 60 41758301 2009625
2009637

- Norris, K. (1990) Determination of the Aqueous Photodegradation of ?Carbon 14|

- Thiram: Lab Proj ect Number: 1157. Unpublished study prepared by Analytical Development Corp. 58 p.

42245601 2009574
2009637 Norris, K. (1991) Determination of the Aqueous Photodegradation of ?carbon 14|

- Thiram: Addendum No. 1: Lab Project Number: 1157. Unpublished stu dy prepared by Analytical Development Corp., (ADC). 6 p.

45596101 DER not
located Shelper, K.; Runes, H. (2001) Photodegradation of (Carbon

- 14) Thiram in Sterilized Buffer at pH 5 by Artificial Light: Lab Project Number: 1042W. Unpublished study prepared by PTRL West, Inc. 116

p.

45651201 2004591
2013242 Shepler, K.; Runes, H. (2002) Photodegradation of (Carbon 14) Thiram in Sterilized Buffer at pH 5 by Artificial Light: Lab Project Number: 1042W. Unpublished study prepared by PTRL West, Inc. 117

p.


### 161

- 3 Photodegradation

- soil

MRID Citation Reference

40768102 2009620 Carpenter, M.; Fennessey, M. (1987) "Determination of the Photode

- gradation Rate of ?Carbon 14|

- Thiram on the Surface of Soil": ABC Final Report #33572. Unpublished study prepared by Analyti

- cal Bio

- Chemistry Laboratories, Inc. 600 p.

43661801 2009628 Burri, R. (1995) Photodegradation Study of (Carbon 14)

- Thiram on Soil: Lab Project Number:

3 26171. Unpublished study prepared by RCC Umweltchemie AG. 113 p.

45724501 2011690 Shepler, K.; Runes, H. (2002) Photodegradation of (Carbon 14) Thiram in/on Soil by Artificial Light: Lab Project Number: 1043W: 1043W

- 1: 1042W

- 004. Unpublished study prepared by PTRL West, Inc. 115 p.



### 162

- 1 Aerobic soil metabolism

MRID Citation Reference

2935

98833 2009589

2009613 Chin, W.T.; Dannals, L.E.; Kucharczyk, N. (1972) Environmental Fate Studies on Vitavax^(R)I: Status Report on PR 70

- 15. (Unpublished study received Mar 6, 1972 under 2F1191; submitted by Uniroyal Chemical, Bethany, Conn.; CDL:093515

- A)

Kulge, E. 1969. The effect of the soil reaction on the degradation and persistence of thiuram, ferbam, and captan in the soil . A translation of : without title . Archivfurer pflanzens

- chutz, 5(4):263

- 271.

40768104 2009622 Daly, D.; Cranor , W. (1988) "Aerobic Soil Metabolism of ?Carbon 14|

- Thiram": ABC Final Report #33569. Unpublished study pre

- pared by Analytical Bio

- Chemistry Laboratories, Inc. 1475 p.

43734901 2009629 Morgenroth, U.; Mueller

- Kallert, H. (1995) (Carbon 14)

- Thiram: Degr adation and Metabolism in One Soil Incubated Under Aerobic Conditions: Lab Project Number: 326182. Unpublished study prepared by RCC Umweltchemie Ag. 114 p.



### 162

- 2 Anaerobic soil metabolism

MRID Citation Reference

2935 2009589
Vitavax = Carboxin Chin, W.T.; Dannals, L.E.; Kucharczyk, N. (1972) Environmental Fate Studies on Vitavax^(R)I: Status Report on PR 70

- 15. (Unpub

- lished study received Mar 6, 1972 under 2F1191; submitted by Uniroyal Chemical, Bethany, Conn.; CDL:093515

- A)



### 16 2

- 3 Anaerobic aquatic metabolism

MRID Citation Reference

40768103 2009621 Daly, D.; Cranor, W. (1988) Anaerobic Aquatic Metabolism of ?Carbon 14|

- Thiram: ABC Final Report #33570. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 875 p.Page 40 of 60 43628501 2009627 Wyss

- Benz, M. (1995) (Carbon 14)

- Thiram: Degradation and Metabolism in an Anaerobic Aquatic System: Revised Report: Lab Project Number: 329635. Unpublished study prepared by RCC Umweltchemie AG. 110 p.



### 162

- 4 Aerobic aquatic metabolism

MRID Citati on Reference

45243401 2075949
2075950
2079014 Wyss

- Benz, M. (1992) Degradation and Metabolism of Thiram in Aquatic Systems (Amended Report): Lab Project Number: 303456. Unpublished study prepared by RCC Umweltchemie Ag. 156

p.



### 163

- 1 Leach/adsorption/desorption

MRID Citation Reference

2935 Vitavax=
Carboxin Chin, W.T.; Dannals, L.E.; Kucharczyk, N. (1972) Environmental Fate Studies on Vitavax^(R)I : Status Report on PR 70

- 15. (Unpublished study received Mar 6, 1972 under 2F1191; submitted by Uniroyal Chemical, Bethany, Conn.; CDL:093515

- A)

3151 DER not
located Mamadou, D. (1976) Evaluation of a Soil

- Plate Screening Technique in Develop

- ing Fungicidal
Control for Southern Stem Rot of Pea

- nuts. Master's thesis, North Carolina State Univ., Dept. of Plant Pathology. (Unpublished study including abstract, received Sep 13, 1976 under 400

- 129; submitted by Uniroyal Chemi

- cal, Bethany, Conn.; CDL: 225604

- AA)

65859 2009615 open lit Helling, C.S., D.G. Dennison, and D.D. Kaufman. 1974. Fungicide movement in soils. Phytopathology 64(Aug):1091

- 1100. Also I n unpublished submission received Mar. 5,
1976 under 661754.

98839 2009614 open lit Munnecke, D.E. (1961) Movement of nonvolatile, diffusible fungicides through columns of soil. Phytopathology 51(Sep):593

- 599. (Also~In~unpublished submission received Jan 4, 1978 under

239

- 1246; submitted by Chevron Chemical Co., Richmond, Calif.; CDL: 232569

- S)

148178 DER not
located Bayer AG (1977) Pesticide Residue in Groundwater: [Pomarsol Forte 80 WP]: Study No. 8800/77. Unpublished translation. 1 p.

148179 DER not
located Bayer AG (1977) Pesticide Residue in Groundwater: [Pomarsol Forte 80 WP]: Study No. 8801/77. Unpublished translation. 1 p.

148180 DER not
located Bayer AG (1974) Pesticide Residue in Groundwater: [Pomarsol For

- te]: Study No. 8803/74. Unpublished translation. 1 p.

148181 DER not
located Bayer AG (1974) Pestici de Residue in Groundwater: [Pomarsol Forte]: Study No. 8804/74. Unpublished translation. 1 p.

148182 DER not
located Bayer AG (1974) Pesticide Residue in Groundwater: [Pomarsol Forte]: Study No. 8805/74. Unpublished translation. 1 p.

158665 DER not
located Warren, J.; Drury, P.; Connor, S. (1986) Determination of Adsorption/ Desorption Constants of [Carbon

- 14]

- Thiram: ABC Final Report #33573. Unpublished study prepared by Analytical Bio

Chemistry Laboratories, Inc. 334 p.

5001190 DER not
located H elling, C.S.; Dennison, D.G.; Kaufman, D.D. (1974) Fungicide movement in soils. Phytopathology 64(8):1091

- 1100.

158665 DER not
located Warren, J.; Drury, P.; Connor, S. (1986) Determination of Adsorption/Desorption Constants of [Carbon

- 14]

- Thiram: ABC Final Report #33573. Unpublished study prepared by Analytical Bio

Chemistry Laboratories, Inc. 334 p.

43787501 2009630
2009640
2009567 Morgenroth, U. (1995) Adsorption/Desorption of (carbon 14)

- Thiram on Four Soils: Lab Project Number: 354780. Unpublished study prepared by RCC Umweltchemie AG. 80 p.

47337902 DER not
located Nag, J. (2001) Aged

- Soil Column Leaching of (Carbon 14)

- Thira m in One Soil. Project Number: 2000/090. Unpublished study prepared by Uniroyal Chemical Co., Inc., Agvise Inc. and Springborn Laboratories, Inc. 132 p.Page 41 of 60 47495003 Contract
Draft
available Reibach, P. (2008) Column Leaching of Radiolabeled Thiram in Five S oils. Project Number: KP/2008/02. Unpublished study prepared by JRF America. 66 p.

40768104 2009623
2031960
2075951 Rockwell, J. C. 1986. Determination of Adsorption/Desorption Constants of 'C

- Thiram. Performed by Analytical Bio

- Chemistry Laboratories, Inc. submitted by the Thiram Task Force. MRID 40768104,



### 164

- 1 Terrestrial field dissipation

MRID Citation Reference

2935 Vitavax =
Carboxin
DER not
located Chin, W.T.; Dannals, L.E.; Kucharczyk, N. (1972) Environmental Fate Studies on Vitavax^(R)I: Status Report on PR 70

- 15. (Unpublished study received Mar 6, 1972 under 2F1191; submitted by Uniroyal Chemical, Bethany, Conn.; CDL:093515

- A)

40768101 2009619 Selman, F.; Moezpoor, E. (1987) Terresterial Soil Dissipation of Thiram on Turf in Georgia: Final Report #34569. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 1082 p.

40953301 2009624 Selman, F. (1988) Terrestraial Soil Dissipation of Thiram on Turf in Missouri: Final R ept. #34570. Unpublished study prepared by Analytical Bio

- Chemistry Laboratories, Inc. 178 p.

44724501 2009631
2009638
2009633=E
CM method Dykeman, R. (1998) Determination of the Dissipation of Residues of Thiram in California Turf and
Bare Ground Plots T reated with Spotrete 75WDG: Lab Project Number: 95049: F96318

- 810: 95049

- CA1. Unpublished study prepared by Compliance Services International. 818 p.

44724502 2009632
2009639 Dykeman, R. (1998) Determination of the Dissipation of Residues of Thiram in No rth Carolina Turf and Bare Ground Plots Treated with Spotrete 75WDG: Lab Project Number: 95051: 95051

- NC1:
F96194

- 054. Unpublished study prepared by Compliance Services International. 1322 p.

N/A 2009635 1996 Letter from registrant regarding Protocol for Terrestrial Field Study



### Non Guideline Studies

MRID Citation Reference

N/A 2009612 Contract Draft

– Environmental Fate and Exposure Assessment

N/A 2009633 Memo re Analytical Methods part of study report 44724501

N/A 2009634
2031960 1991 EFED Fate Data Summary

N/A 2009636 Data Waiver for Irrigated Crop acculmulation and also submission of supplemental data for Photodegradation on Soil

N/A 2009638
2009643
2009644 Thiram Lab Method Evaluation Report No. ECM 0151S1 for ECM for Thiram in Soil and ABC Labs summary of Method development

N/A 2009639 Thiram Lab Method Evaluation Report No. ECM 0151W1 for ECM for Thiram in Water

N/A 2009641
2009642 1991 and 1992 Fate Database One

- liner reports

Not provided 2075951
2075952 1989 Dynamac Contract Draft Groundwater assessment and Mike Barrett’s response to Registrants

3151 Not an
EFED guideline study Mamadou, D. (1976) Evaluation of a Soil

- Plate Screening Technique in Developing Fungicidal
Control for Southern Stem Rot of Pea

- nuts. Maste r's thesis, North Carolina State Univ., Dept. of Plant Pathology. (Unpublished study including abstract, received Sep 13, 1976 under 400

- 129; submitted by Uniroyal Chemi

- cal, Bethany, Conn.; CDL:225604

- AA)Page 42 of 60 

## 10.2. Submitted Ecological Toxicity Studies

MRID Cita tion

TN 1001 McCann, J.A. ,1976. Rainbow trout Test No. 1001. (U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory; With 99 % technical

TN 996 McCann, J.A. (1968: Bluegill (Lepomis macrochirus)|: Test No. 996. (U.S. Agricultural Research Service, Pesticides Regul ation Div., Animal Biology Lab oratory; With 99 % technical

00002923 /

00021610 Mastri , C. (1970) Report to Uniroyal Chemical, Division of Uniroyal, Inc.: Four

- Day Fish Toxicity Study on Three Samples of Vitavax Seed Protectants: IBT No. A8585. (Unpublished study received Feb 18, 1972 under 400

- 81; prepared by Industrial Bio

- Test Laboratori es, Inc., submitted by Uniroyal Chemical, Bethany, Conn.; CDL:003261

- D)

00003074 Heitmuller, T. (1975) Acute Toxicity of Vitavax to Pink Shrimp (Penaeus duorarum) and Fiddler Crabs (Uca pugilator). (Unpublished study received May 16, 1975 under 400

- 116; pre

- pared by

Bionomics

-- EG&G, Inc., submitted by Uniroyal Chemical, Bethany, Conn.; CDL:165048

- A)

00003308 Mastalski, K. (1970) Report to Uniroyal Chemical, Division of Uniroyal, Inc.: Acute Oral Toxicity Study on Vitavax Seed Protectant with Thiram in Bobwhite Quail: IBT No. J8584. (Unpublished study received May 8, 1972 under 2F1191; prepared by Industrial Bio

- Test Laboratories, Inc., submitted by Uniroyal Chemical, Bethany, Conn.; CDL:091003

- C)

00022293 Hill, E.F.; Heath, R.G.; Spann, J.W.; et al. (1975) Lethal Dietary Toxicities of Environmental Pollutants to Birds: Special Scientific Report

-- Wildlife No. 191. (U.S. Dept. of the Interior, Fish and Wildlife Service, Patuxent Wildlife Research Center; unpublished report)

00036935 Atkins, E.L.; Greyw ood, E.A.; Macdonald, R.L. (1975) Toxicity of Pesticides and Other Agricultural Chemicals to Honey Bees: Laboratory Studies. By University of California, Dept. of Entomology. UC, Cooperative Extension. (Leaflet 2287; published study.)

00073683 /

00020560 Schafer, E.W. (1972) The acute oral toxicity of 369 pesticidal, pharmaceutical and other chemicals to wild birds. Toxicology and Applied Pharmacology 21(? ):315

- 330. (Also in unpublished submission received Apr 25, 1978 under 476

- 2180; submitted by Stauffe r Chemical Co., Richmond, Calif.; CDL:233577

- C

0007368 /

00020560 Schafer, E.W. (1972) The acute oral toxicity of 369 pesticidal, pharmaceutical and other chemicals to wild birds. Toxicology and Applied Pharmacology 21(? ):315

- 330. (Also in unpublished

su bmission received Apr 25, 1978 under 476

- 2180; submitted by Stauffer Chemical Co., Richmond, Calif.; CDL:233577

- C

00090293 McCann, J.A. (1972) Tersan 75: Rainbow trout. Test No. 463. (U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory, Fish Toxicity Laboratory; unpublished study; CDL:130512

- A)

00090294 McCann, J.A. (1972) Tersan 75: Bluegill sunfish . Test No. 446. (U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory, Fish Toxicity Laboratory; unpublished study; CDL:130513

- A)

00152556 Debets, F. (1985) Evaluation of the Acute Inhalation Toxicity of TMTD Technic al in the Rat: NOTOX 0113/232. Unpublished study prepared by Notox V. O. F. 17 p.

00153548 Thouin, M. (1985) Evaluation of the Acute Oral Toxicity of TMTD Technical in the Rat: Study No. 0174/238. Unpublished study prepared by Notox v.o.f Hambakenwetering 31. 19 p.

00154264 Van Leeuwen, C. (1985) The Toxicological Consequences of the Use of Dialkyldithiocarbamates for Some Softwater Organisms. Unpublished translation of journal article with related data prepared by RIZA Ecotoxicology Laboratory. 14 p.

00 160000 Hudson, R.; Tucker, R.; Haegele, M. (1984) Handbook of toxicity of pesticides to wildlife: Second edition. US Fish and Wildlife Service: Resource Publication 153. 91 p.

00164662 Husson , R. (1986) Letter sent to J. Rockwell dated Sept 17, 1986: [Data requested to complete review of 48 hour LC50 study on Daphnia magna: thiram]. Prepared by UCB Societe Anonyme. 3

p.Page 43 of 60 05020144 Tooby, T.E., Hursey, and Alabaster. 1975. The acute toxicity of 102 pesticides and miscellaneous substances to fish. Chemistry and Industry (21):523

- 526.

40216501 Maedgen, J.; Lain, D. (1987) Rat Acute Inhalation Toxicity: [Thiram Technical]: Laboratory Project

ID: 4730

- 87. Unpublished study prepared by Stillmeadow, Inc. 19 p.

42095901 York, R. (1991) Two

- Generation Reproduction Study in Rats Using Thiram: Lab Project Number:

399

- 104. Unpublished study pre

- pared by International Research and Development Corp. 764 p.

42488301 Thompson, R.; Croudace, C.; Grinell , A. (1992) Thiram: Acute Toxicity to Larvae of the Pacific Oyster (Crassostrea gigas): Lab Project Number: W199/C: BL4547/B. Unpublished study prepared by Imperial Chemical Industries PLC. 20 p.

42488302 Thompson, R.; Croudace, C.; Grinell, A. (1992) Th iram: Acute Toxicity to Mysid Shrimp (Mysidopsis bahia): Lab Project Number: W199/D: BL4562/B. Unpublished study prepared by Imperial Chemical Industries PLC. 19 p.

42514401 Croudace, C.; Caunter, J.; Johnson, P. (1992) Thiram: Acute Toxicity to Sheepshe ad Minnow (Cyprinodon variegatus): Lab Project Number: W199/B. Unpublished study prepared by Imperial Chemical Industries PLC. 22 p.

42646001 Douglas, M. (1993) Thiram: Algal Growth Inhibition (Selenastrum capricornutum): Lab Project
Number: UCB 442/9212 55. Unpublished study prepared by Huntingdon Research Centre Ltd. 30 p.

43612501 Beavers, J.; Chafey , K.; Mitchell, L. et al. (1995) Thiram Technical: A Reproduction Study with the Mallard: Lab Project Number: 357/104: CHR24. Unpublished study prepared by Wildlife International Ltd. 278 p.

43612502 Beavers, J.; Chafey, K.; Mitchell, L. et al. (1995) Th iram Technical: A One Generation Reproduction Study with the Northern Bobwhite (Colinus virginianus): Amended: Lab Project Number: 357/103: CHR24. Unpublished study prepared by Wildlife International Ltd. 250 p.

43612505 Beavers, J.; Haberlein, D.; Grimes, J. et al. (1995) Thiram Technical: A Palatability/Repellancy Study with the Mallard (Anas platyrhynchos) Under Multiple Choice Conditions: Lab Project Number: 357/106: CHR17. Unpublished study prepared by Wildlife International Ltd. 183 p.

436125 06 Beavers, J.; Haberlein, D.; Grimes, J. et al. (1995) Thiram Technical: A Palatability/Repellancy Study with the Northern Bobwhite (Colinus virginianus) Under Multiple Choice Conditions: Lab Project Number: 357/105: CHR17. Unpublished study prepared by W ildlife International Ltd. 184

p. 44086101 Coates, M. (1996) Thiram: Algal Growth Inhibition: Addendum to MRID 426460

- 01: Lab Project Number: UCB 442/960953: UCB 442/921255. Unpublished study prepared by Huntingdon Life Sciences, Ltd. 10 p.

45441201 Gallagher, S.; Martin, K.; Beavers, J. (2001) Thiram Technical: A Reproduction Study with the Mallard: Final Report: Lab Project Number: 357

- 107. Unpublished study prepared by Wildlife International, Ltd. 143 p.

45441202 Sutherland, C.; Kendall, T.; Krue ger, H. (2001) Thiram Technical: A 7

- Day Toxicity Test with Duckweed (Lemna gibba G3): Final Report: Lab Project Number: 357A

- 101. Unpublished study prepared by Wildlife International. Ltd. 79 p.

45441203 Turck, P. (1997) Two Generation Reproduction/Fertility Study in Rats with Thiram: Lab Project
Number: 399

- 180. Unpublished study prepared by MPI Research. 1579 p.

46249301 Peither, A. (2000) Acute Toxicity of Thiram Technical to Rainbow Trout (Oncorhynchus mykiss) in

a 96

- Hour Static Te st. Project Number: 775552. Unpublished study prepared by VJP Consulting, Inc. and RCC Ltd. 46 p.

46249303 Memmert , U. (2001) Sublethal Effects of Thiram 80 WG to Rainbow Trout (Oncorhynchus mykiss) After a Fourfold Application to a Water

- Sediment System. Project Number: 8043363. Unpublished study prepared by RCC Umweltchemie Ag. 60 p.

46249304 Memmert, U. (2000) Eco logical Effects of Thiram 80 WG in A Freshwater Mesocosm Study. Project Number: 733454. Unpublished study prepared by RCC Ltd. and Aachen Univ. of Technology. 319 p.Page 44 of 60 47495001 Krueger, H.; Kendall, T. (2008) (Carbon 14)

- Thiram: A Flow

- Through Life

- Cycle To xicity Test with the Cladoceran (Daphnia magna): Final Report. Project Number: 657A/101. Unpublished study prepared by Wildlife International, Ltd. 59 p.

47495002 Krueger, H.; Kendall, T. (2008) (Carbon 14)

- Thiram: An Early Life

- Stage Toxicity Test with the Fathead Minnow (Pimephales promelas): Final Report. Project Number: 657A/102. Unpublished study prepared by Wildlife International, Ltd. 70 p.

47824101 Krueger, H.; Kendall, T. (2009) (Carbon 14)

- Thiram: A Flow

- Through Life

- Cycle Toxicity Test

with th e Fathead Minnow (Pimephales promelas): Final Report. Project Number: 657A/103. Unpublished study prepared by Wildlife International, Ltd. 144 p.Page 45 of 60 

# Appendix A. SIP Modeling Results

Table 1. Inputs

Parameter Value

Chemical name Thiram
Solubility (in water at 25 o C; mg/L) 16 .5

Mammalian LD 50 (mg/kg

- bw) 1800 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg

- bw) 1.4

Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg

- bw) 673 Avian test species other Body weight (g) of "other" avian species 1135 Mineau scaling factor 1.15

Mallard NOAEC (mg/kg

- diet) 9.6 Bobwhite quail NOAEC (mg/kg

- diet)

Table 2. Mammalian Results

Parameter Acute Chronic Upper bound exposure (mg/kg

- bw) 2.8380 2.8380 Adjusted toxicity value (mg/kg

- bw) 1384.4890 1.0768

Ratio of exposure to toxicity 0.0020 2.6355

Conclusion* Drinking water exposure alone is NOT a potential

concern for mammals Exposure through drinking water alone is a

potential concern for
mammals

Table 3. Avian Results

Parameter Acute Chronic Upper bound exposure (mg/kg

- bw) 13.3650 13.3650 Adjusted toxicity value (mg/kg

- bw) 367.2148 0.4763 Ratio of exposure to acute toxicity 0.0364 28.0612

Conclusion* Drinking water exposure alone is NOT a potential
concern for birds Exposure through drinking water alone is a

potential concern for
birds

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. Therefore, when aggregated with other routes ( i.e ., diet, inhalation, dermal), pesticide exposure through drinking water may contribute to a total exposure that has potential for effects to non

- target animals.Page 46 of 60 

# Appendix B

. STIR Modeling Results

Input

Application and Chemical Information

Enter Chemical Name Thiram

Enter Chemical Use Fungicide Is the Application a Spray? (enter y or n) y If Spray What Type (enter ground or air) ground Enter Chemical Molecular Weight (g/mole) 240.44 Enter Chemical Vapor Pressure (mmHg) 1.7 3 E

- 0 5 Enter Application Rate (lb a.i./acre) 16.3

Toxicity Properties

**Bird**

Enter Lowest Bird Oral LD 50 (mg/kg bw) 673 Enter Mineau Scaling Factor 1.15 Enter Tested Bird Weight (kg) 1.135

**Mammal**

Enter Lowest Rat Oral LD 50 (mg/kg bw) 1800

Enter Lowest Rat Inhalation LC 50 (mg/L) 2.6 Duration of Rat Inhalation Study (hrs) 4 Enter Rat Weight (kg) 0.35



# Output

Results Avian (0.020 kg ) Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 2.24E

- 01

Maximum 1

- hour Vapor Inhalation Dose (mg/kg) 2.81E

- 02

Adjusted Inhalation LD 50 4.11E+00

Ratio of Vapor Dose to Adjusted Inhalation LD 50 6.85E

- 03 Exposure not Likely Significant

Maximum Post

- treatment Spray Inhalation Dose (mg/kg) 1.72E+00

Ratio of Droplet Inhalation Dose to Adjusted Inhalation
LD 50 4.20E

- 01 Proceed to Refinements



### Results Mammalian (0.015 kg ) Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 2.24E

- 01

Maximum 1

- hour Vapor Inhalation Dose (mg/kg) 3.54E

- 02

Adjusted Inhalation LD 50 1.55E+02

Ratio of Vapor Dose to Adjusted Inhalation LD 50 2.29E

- 04 Exposure not Likely Significant

Maximum Post

- treatment Spray Inhalation Dose (mg/kg) 2.17E+00 Ratio of Droplet Inhalation Dose to Adjusted Inhalation
LD 50 1.40E

- 02 Exposure not Likely SignificantPage 47 of 60 

# Appendix C . Summary of Ferbam and Thiram Fate and Transport Data

I. Abiotic Degradation

161

- 1 Hydrolysis (MRID 44071801, Acceptable)

– [ 14 

### C]Ferbam (dimethyldithiocarbamic acid, iron salt) hydrolyzed at

∼ 25.0 ̊C with pH

- dependent rates, increasing with pH. The half

- life at pH 9 could not be assessed because the hydrolysis was too rapid for the type of monitoring equipment utilized (full hydrolysis occurred within 10 seconds).

Table A

- 1. Ferbam hydrolysi s rate. pH Initial concentration (ppm) Half

- life (minutes) r 2

5 10 12.1 0.991

7 50 7.8 0.941

9 50 <0.2 N/A



### Table A

- 2. Ferbam hydrolysis byproducts.

[14 

### C]Ferbam (dimethyldithiocarbamic acid, iron salt), at 9.9 ppm, hydrolyzed and photodegraded too fast to allow the assessment of the photolysis rate. The hydrolysis/photolysis half

- life was found to be 31.0 minutes (r 2 

### = 0.969). The media was continuously exposed to light from a xenon arc lamp for 15 days forming volatile products and thiram. The main difference in degradation between irradiated and dark samples was the rate and extent of formation of volatile products.

Sterilized deionized ultra

- filtered (DIUF) water was used in this study. It appears that the samples were not buffered at any s pecified pH. The initial pH was about 6 and decreased throughout the study for both the dark control and the exposed sample. The irradiated samples pH decreased to an average of 4.5 at 15 days, while the dark control samples pH did not change as much, rema ining at an average of 5.8 after 15 days. The study author suggests that the pH of test solutions became more acidic indicating the formation of acidic products. The previous study

indicated that the half

- lives for hydrolysis of ferbam at pHs 5

– 7 did not d iffer much, with rates of

about 8

– 12 minutes.

The major degradates of ferbam were volatile, mainly CS 2 

### (44.6% of the applied), and CO 2 

### (28.6%). Following 15 days of incubation, volatile products accounted for 73.6% of the applied radioactivity for ir radiated samples compared to 31.4% for dark samples. Degradation to volatile products was rapid in dark samples through day 2 but slowed thereafter, whereas in irradiated samples, degradation to volatile products continued. The major non

- volatile degradate was tetramethylthiuram disulfide (TMTD) which accounted for a maximum of 63.3% of the applied radioactivity at day 1, and decreased to 1.1% by day 7 and 0.5% of the applied radioactivity at day 15. The degradation half

- life for TMTD was 4.7 days.

A diff erence in the degradation pattern between irradiated and dark samples was the rate and extent degradation of thiram, and of formation of volatile products. In the dark controls, thiram was a maximum of 73.1% at day 1, and decreased more slowly (compared to the irradiated sample) to 61.1% of the applied radioactivity by day 15 post

- treatment. For dark samples, CS 2 

### accounted for 27.3% of the applied radiocarbon and 3.5% CO 2



### .Page 48 of 60 

### Two additional products were found exceeding 10% of the applied radiocarbon, designa ted as A and B and characterized as polar, water soluble and acidic in nature. Degradate A increased from 7.7% of the applied radiocarbon (day 1) to a maximum of 16.0% (day 3) then decreased to 9.0% following 15 days of irradiation; degradate B, found only in significant amounts in the irradiated samples, increased from 1.4% (day 2) to a maximum of 11.9% of applied radiocarbon on day 15.

161

- 3 Photodegradation on Soil (MRID 43999802, Acceptable)

– [ 14 

### C]Ferbam (dimethyldithiocarbamic acid, iron salt) was ap plied to a sandy loam soil, at 12.2 ppm. The soil was irradiated continuously with a UV

- filtered xenon arc light source for up to 15 days at 25 ̊C and 75% of FMC at 1⁄3 bar (maintained concurrently with a dark control).

It appears that parent ferbam degrad ed so quickly that even immediately post

- treatment, the only degradate extractable both from the irradiated sample and the dark control was Thiram. The rate of degradation appeared to be similar for Thiram in both irradiated sample and dark control.

Thir am was the only extractable degradate for irradiated and dark samples. This degradate (in irradiated samples) comprised a mean of 82.5% of the applied radioactivity at day 0 (84.5% dark control), and 17.2% at day 15 (20.7% dark). On the other hand, the am ount of volatiles and their relative proportion was much more different. Following 15 days of incubation, volatile products accounted for 38.5% of the applied radioactivity for irradiated samples and 15.8% for dark control samples. Major volatile degrada tes in the irradiated and dark samples were 14 

### CO 2 

### , and 14 

### CS 2 

### . After 15 days of incubation, 14 

### CS 2 

### comprised of 44.6% of the applied radioactivity in the irradiated samples and 27.3% in the dark control samples. After 15 days of incubation, 14 

### CO 2 

### comprised of 28.6% of the applied radioactivity in the irradiated samples and 3.5% in the dark control samples.

161

- 4 Photolysis in Air (Waived)

– The data requirement is waived. The rapid rate of degradation in soil and water and the relatively low vol atility of ferbam, suggest that atmospheric photolysis is not likely to be an important route of dissipation.

II. Metabolism

162

- 1 Aerobic Soil Metabolism (MRID 44368901, Acceptable)

– [ 14 

### C]Ferbam, at 11.2 ppm,

and incubated in the dark on an aerobic sandy loam soil at about 25 ̊C and 75% of 1⁄3 bar (75% of field capacity) for up to 150 days, degraded very rapidly and the degradation rate of the parent compound could not be assessed under the conditions of the study. The primary degradate was tetramethy lthiuram (TMTD), which was a mean (of two replicates) of 77.9% of the applied radioactivity at the initial test interval (0 hours). TMTD (also commonly known as thiram), degraded further, with a half

- life of 4.9 days. Thiram comprised a mean (2 replicate s) of 77.9% of the applied radioactivity at hour 0, 67.1% at hour 4, 50.1% at day 1, 43.8% at day 2, 33.9% at day 4, 23.4% at day 7, 17.3% at day 14, 15.3% at day 21, 7.7% at day 45, 5.8% at day 93, and 2.6% at day 150.

Volatile metabolites included CO 2 

### ( accounted for 56.4% of the initially applied radiocarbon at 150 days post

- treatment), and 14 

### CS 2 

### (accounted for 5.5% of the initially applied radiocarbon at 150 days post

- treatment). Several minor degradates were observed none of which exceeded
1.2% of the applied radiocarbon. Soil bound residue reached a maximum of 49.9% (mean of twoPage 49 of 60 

### replicates) of the applied radiocarbon at day 7, then decreased to 26.3% by day 150. Material balances ranged from 90.5% to 101.6% of the initially applied radioactivity.

1 62

- 2 Anaerobic Soil Metabolism (MRID 44565305, Acceptable)

– [ 14 

### C]Ferbam, at 11.6 ppm, and incubated in the dark on an anaerobic sandy loam soil at about 25 ̊C for up to 364 days, degraded very rapidly and the degradation rate of the parent compound could not be assessed under the conditions of the study.

One primary degradate was tetramethylthiuram (TMTD, thiram), which was a mean (of two replicates) of 33.8% of the applied radioactivity at the initial test interval (0 hours). Thiram degraded further, wi th a half

- life of 184 days. Thiram accounted for 33.8% (mean of 2 replicates) of the applied radiocarbon, following dosing, 28.1% at day 3, 30.2% at day 7, 27.9% at day 14, 15.7% at day 21, 17.5% at day 51, 16.8% at day 93, 8.9% at day 134, 7.4% at day 18 2, 10.9% at day 272, and 8.1% at day 364.

One other major degradate was Co

- DMDTC [cobalt (II)dimethyldithiocarbamate], which was a mean (of two replicates) of 39.6% of the applied radioactivity at the initial test interval (0 hours).

Co

- DMDTC, degraded f urther, with a half

- life of 269 days. Co

- DMDTC reached a level of 39.6% (a mean of two replicates) of the applied radiocarbon, 38.3% at day 3, 40.9% at day 7, 41.8% at day 14, 46.5% at day 21, 36.2% at day 51, 31.2% at day 93, 36.9% at day 134, 29.1%

at d ay 182, 18.3% at day 272, and 16.8% at day 364.

A total of five unknown degradates were detected, of which only one degradate was observed at a level >10% of the applied radiocarbon. This degradate comprised 11.7% (mean of two replicates) of the applied radiocarbon at day 0 in the water samples, then decreased to 2.8% by day 7. Following day 7, the water samples were not analyzed due to low levels of radiocarbons (≤3% of the applied radiocarbon). Soil

- bound residue ranged from 11.0 to 16.1% (mean of

rep licates) of the applied radiocarbon between Day 0 and Day 182 and decrease to 6.6 and 5.6% (mean of replicates) on Day 272 and 364, respectively.

The major volatile metabolites formed during this Anaerobic Metabolism were CS 2 

### and CO 2 

### which accounted for a total of 50.7% and 7.5% of the initially applied radioactivity, respectively.

The overall material balance throughout the study was 95.8± 5.2 (mean± standard deviation) of the applied radiocarbon.

III. Specific Mobility and Persistence Data for Ferbam

163

- 1 Mobility Batch Equilibrium

– Adsorption/Desorption (MRID 40088204, Unacceptable)

– This study does not satisfy the data requirement for ferbam. It cannot be used to satisfy the mobility in soil data requirement for ferbam because the soils were steri lized by autoclaving at 121 ̊C and 15 psi. In addition, no attempt was made to account for volatiles, resulting in a very low mass balance for all soils used in this study. The mobility of 14 

### C

- ferbam was studied at a concentrations of 0.1, 0.5, 1.0, and 5.0 ppm in sieved (2 mm) and sterilized sandy loam, silt loam, sand, and clay loam. Adsorption coefficients ranging from 3.57 to 22.9 were measured, which corresponded to K oc 

### values ranging from 432 to 2207.Page 50 of 6 0 

### EFED acknowledges the difficulty to conduct a scientifically sound batch equilibrium study for ferbam since it is very unstable under hydrolytic and under aerobic conditions. Furthermore, the available studies indicate that parent ferbam is not likely to persist enough to present a significant risk o f contamination of surface or groundwater. Therefore, no new studies will be required for the parent compound.

163

- 1 Mobility Batch Equilibrium

– Adsorption/Desorption (MRID 43787501, Supplemental)

– At this time, EFED has a batch equilibrium study for t hiram, the major non

volatile degradation product of ferbam. However, this study was deemed supplemental.

14 

### C

- thiram at concentrations of 0.01, 0.04, 0.20, and 1.07 mg/L was determined to have low mobility in a sandy loam and silt loam soil, and was immo bile in loamy sand and loamy silt soils. Freundlich adsorption coefficients were 54, 150, 67, and 263 for the sandy loam, loamy sand, silt loam and loamy silt, respectively. Corresponding K oc 

### values were 2,245 (sandy loam), 24,526 (loamy sand), 6,359 (si lty loam), and 12,899 (loam silt). The data from this study including the properties of each soil are shown in Table A

- 3.

Table A

- 3. Thiram soil adsorption and mobility characteristics

. a



### Soil

characteristics Sandy loam,

NY Loamy sand, IL Silt loam, IL Loam, IA

% Clay 14.8 7.5 16.8 25.2
% Silt 29.6 9.4 59.1 33.6
% Sand 55.6 83.1 24.1 41.2 % Organic carbon 2.41 0.61 1.06 2.04 pH 6.7 4.8 6.7 7.3

K d 

### 54 150 67 263

K oc 

### 2245 24526 6359 12899

a 

### MRID 04378501

163

- 2 Laboratory Volatility

– No data are required due to the relatively low vapor pressure of

ferbam.

163

- 3 Field Volatility

– No data are required due to the relatively low vapor pressure of ferbam.

IV. Field Dissipation

Since ferbam appears to be very labile in the environment, as shown in the aerobic soil metabolism study (MRID 44368901), and its major degradation product is thiram, two terrestrial field dissipation studies for thiram (MRID 44724501 and 44724502) will be used as surrogate studies for the ferbam data requirement

.

164

- 1 Terrestrial Field Dissipation of Ferbam (MRID 40550902, 40603401 Unacceptable) Peach field located in Donalsville, GA, and an apple orchard in Waterloo, NY were considered not acceptable and do not satisfy the data requirement for ferbam because they do not provide information about the degradation, mobility or any other dissipation avenues for the parent under actual use conditions. Additionally, a major degradate, thiram, expected to be formed in the field, was not addressed in the study.Page 51 of 60 

### 164

- 1 Terrestrial Field Dissipation of Thiram (MRID 44724501, Supplemental, and 44724502, Acceptable)

– Thiram was applied eight times at a nominal rate of 10.3 lbs a.i./A to turfed and bare plots of an alkaline sandy soil (pH 8.2 to 9.6) in California. The terrestrial field

half

- life was 27.4 days in a turfed plot and 14.4 days from a bareground plot. A similar study conducted using an acidic bareground sandy soil (pH 4.1 to 4.7) and acidic turfed loamy sand (pH 4.4 to 4.5) in North Carolina where thiram wa s applied eight times at a rate of 10.3 lbs a.i./A/application yielded slightly longer half

- lives. The field half

- life was 36 days on the bareground plot and 62.5 days on the turfed plot.Page 52 of 60 

# Appendix D . Ziram, Thiram, and Ferbam Ecotoxicity Data

1. Toxicity to Aquatic Organisms

1.1. Aquatic Vertebrate Toxicity

1.1.1. Freshwater Fish Toxicity

Table A

- 1. Acute Toxicity to Freshwater Fish

Species % ai 96

- hr LC 50 (ppm ai) Toxicity
Category MRID No.
Author, Year Study

Classification

FERBAM

Bluegill sunfish
( Lepomis macrochirus ) 95 3.6 Moderately toxic 05014941 Pickering &
Henderson, 1966 Supplemental

Carp ( Cyprinus carpio ) Tech 0.09 Very highly toxic 05001997

Hashimoto &
Fukami, 1969 Supplemental

Fathead Minnow
( Pimephales promelas ) 95 3.1 Moderately toxic 05014941 Pickering &
Henderson, 1966 Supplemental

THIRAM

Bluegill sunfish 99.0 0.042 Very highly toxic TN 996
McCann, 1968 Acceptable

Bluegill sunfish 37.5 0.21 1 Highly toxic 00002923, 00021610
Mastri, 1970 Supplemental

Bluegill sunfish 75 0.28 Highly toxic 00090294
McCann, 1972 Supplemental

Harlequin Fish ( Rasbora
heteromorpha ) 80 0.007 Very highly toxic 05020144 Tooby et al., 1975 Supplemental

Rainbow trout
( Oncorhynchus mykiss ) 99.0 0.046 Very highly toxic 46249301
Peither, 2000 Supplemental

Rainbow trout 99.0 0.128 Highly toxic TN 1001
McCann, 1976 Acceptable

Rainbow trout 37.5 0.14 1 Highly toxic 00002923, 00021610
Mastri, 1970 Supplemental

Rainbow trout 75 0.382 Highly toxic 00090293
McCann, 1972 Supplemental

ZIRAM

Bluegill sunfish 98.9 0.0097 Very highly toxic 42386303 Douglas et al., 1991 Acceptable

Bluegill sunfish 98.2 0.57 Highly toxic 47307901
Palmer et al., 2007 Acceptable

Carp Tech 2.28 Moderately toxic 00138215
Dickhaus & Heisler,

1980 Supplemental

Fathead Minnow 99.0 0.008 Very highly toxic 05003523 Maloney & Palmer,

1956 Supplemental

Rainbow trout 76 0.23 Highly toxic TN 1021
McCann, 1976 SupplementalPage 53 of 60 Species % ai 96

- hr LC 50 (ppm ai) Toxicity
Category MRID No.
Author, Year Study

Classification

Rainbow trout Tech 0.27 Highly toxic 00138214
Dickhaus et al., 1980 Supplemental

Rainbow trout 98.9 1.7 Moderately toxic 42386304 Douglas et al., 1991 Acceptable

1 Test substance: Vitavax Seed Protectant, 37.5% thiram and 37.5% carboxin

Table A

- 2. Chronic Toxicity to Freshwater Fish

Species % ai NOAEC / LOAEC
(ppm ai) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAM

Fathead Minnow
( Pimephales promelas ) 98.7 0.0011 / 0.0022 1 F0 % spawning frequency, F0 egg

production, F1
time to hatch, F1

4

- wk survival 47824101 Krueger & Kendall,

2009 Acceptable

Rainbow Trout
( Oncorhynchus mykiss ) 81.2 0.012 / 0.020 2 Growth rate 46249303
Memmert, 2001 Supplemental

ZIRAM

Fathead Minnow 98.2 0.101 / 0.195 3 Post

- hatch

survival 46893104
Palmer et al., 2006 Acceptable

Fathead Minnow 98.2 0.024 / 0.051 4 F 0 length and weight 47435501
Palmer et al., 2008 Supplemental

1 Full life cycle study, 210 days.

2 Non

- guideline 28

- day sub

- chronic study. 4 applications at 7 day intervals to 10:1 water:sediment systems.

3 Early

- life stage study, 33 days (28 days post

- hatch).

4 Full life cycle study, 275 days.



### 1.1.2. Estuarine/Marine Fish Toxicity

Table A

- 3. Acute Toxicity to Estuarine/Marine Fish

Species % ai 96

- hr LC 50 (ppm ai) Toxicity Category MRID No.
Author, Year Study

Classification

FERBAM

Longnose killifish
( Fundulus similis ) 76 0.80 Highly toxic 40228401
Mayer, 1986 Supplemental

THIRAM

Sheepshead Minnow
( Cyprinodon variegatus ) 98.3 0.54 Highly toxic 42514401
Croudace et al., 1992 Acceptable

ZIRAM

Longnose killifish Tech 6.40 1 Moderately toxic 40228401
Mayer, 1986 Supplemental

Sheepshead Minnow 98.9 0.84 Highly toxic 43781601
Machado, 1995 Acceptable

1 48

- hr testPage 54 of 60 Table A

- 4. Chronic Toxicity to Estuarine/Marine Fish

Species % ai NOAEC / LOAEC
(ppm ai) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAM

No data available

ZIRAM

Sheepshead Minnow 98.2 0.027 / 0.058 1 Length and dry weight of larvae 46856401
Sutherland et al.,

2006 Acceptable

1 Early

- life stage study, 34 days (28 days post

- hatch).



### 1.2. Aquatic Invertebrate Toxicity

1.2.1. Freshwater Invertebrate Toxicity

Table A

- 5. Acute Toxicity to Freshwater Invertebrates

Species % ai 48

- hr EC 50 (ppm ai) Toxicity Category MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAM

Water flea ( Daphnia

magna ) 98 0.21 Highly toxic 00164662
Husson, 1986 Acceptable

ZIRAM

Water flea 98.9 0.048 Very highly toxic 42386305 Douglas et al., 1992 Acceptable

Water flea 98.2 0.206 Highly toxic 47405701
Palmer et al., 2008 Acceptable

Table A

- 6. Chronic Toxicity to Freshwater Invertebrates

Species % ai NOAEC / LOAEC (ppm ai) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAM

Water flea 98.7 0.020 / 0.040 Dry weight,
clinical signs of toxicity 47495001 Krueger & Kendall,

2008 Acceptable

ZIRAM

Water flea 98.2 0.039 / 0.078 Length 46823301
Palmer et al., 2006 AcceptablePage 55 of 60 

### 1.2.2. Estuarine/Marine Invertebrate Toxicity

Table A

- 7. Acute Toxicity to Estuarine/Marine Invertebrates

Species % ai 96

- hr EC 50 or LC 50 (ppm ai) Toxicity Category MRID No.
Author, Year Study

Classification

FERBAM
Eastern Oyster
( Crassostrea virginica ) 76 0.052 Very highly toxic 40228401
Mayer, 1986 Supplemental

Pink Shrimp ( Penaeus

duorarum ) 76 >40 1 Slightly toxic 40228401
Mayer, 1986 Supplemental

THIRAM

Pacific Oyster
( Crassostrea gigas ) 98.3 0.0047 1 Very highly toxic 42488301 Thompson et al.,

1992 Acceptable

Mysid Shrimp

( Americamysis bahia ) 98.3 0.00336 Very highly toxic 42488302 Thompson et al.,

1992 Acceptable

ZIRAM

Eastern Oyster 98.0 0.077 Very highly toxic 43781602
Dionne, 1995 Acceptable

Eastern Oyster Tech 1.00 Highly toxic 40228401
Mayer, 1986 Supplemental

Mysid Shrimp 98.0 0.014 Very highly toxic 43781603
Machado, 1995 Acceptable

Mysid Shrimp 98.2 0.14 Highly toxic 47405702
Palmer et al., 2008 Acceptable

Pink Shrimp Tech >5 1 Moderately toxic 40228401
Mayer 1986 Supplemental

1 48

- hr test

Table A

- 8. Chronic Toxicity to Estuarine/Marine Invertebrates

Species % ai NOAEC / LOAEC
(ppm ai) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

FERBAM

Mysid Shrimp 97.6 <0.0012 / 0.0012 F 0 body length 47784401 Gallagher et al., 2009 Supplemental

THIRAM

No data available

ZIRAM

Mysid Shrimp 98.2 0.016 / 0.027 Reproduction and
dry weight 46893103
Sutherland et al.,

2006 Supplemental



### 1.3. Aquatic Plant Toxicity

Table A

- 9 . Toxicity to Aquatic Plants

Species % ai EC 50 (ppm ai) EC 05 or NOAEC (ppm ai) MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAMPage 56 of 60 Species % ai EC 50 (ppm ai) EC 05 or NOAEC
(ppm ai) MRID No.
Author, Year Study

Classification

Duckweed ( Lemna gibba ) 98.7 7

- d EC 50 = 1.6 NOAEC < 0.057 45441202
Sutherland et al.,

2001 Acceptable

Green algae
( Pseudokirchneriella
subcapitata ) 99.0 120

- hr EC 50 = 0.14 EC 05 = 0.003 44086001, 44086101
Coates, 1996 Acceptable

ZIRAM

Duckweed 98.2 7

- d EC 50 = 0.37 NOAEC = 0.035 46823302 Desjardins et al.,

2006 Acceptable

Green algae 98.0 120

- hr EC 50 =
0.067 NOAEC < 0.038 43833901 Hoberg, 1995 Acceptable



### 2. Toxicity to Terrestrial Organisms

2.1. Avian Toxicity

Table A

- 10. Acute Oral Toxicity to Birds

Species % ai LD 50 (mg ai/kg

- bw) Toxicity
Category MRID
Author, Year Study

Classification

FERBAM

No data available

THIRAM

Mallard duck (Anas

platyrhynchos) 99.0 >2800 Practically non

toxic 00160000
Hudson et al., 1984 Acceptable

Red

- wing blackbird
( Agelaius phoeniceus ) Tech >100 Moderately toxic 00073683, 00020560
Schafer, 1972 Supplemental

Ring

- neck pheasant
( Phasianus colchicus ) 99.0 673 Slightly toxic 00160000
Hudson et al., 1984 Supplemental

Starling ( Sturnus vulgaris ) Tech >100 Moderately toxic 00073683, 00020560
Schafer, 1972 Supplemental

ZIRAM

Bobwhite quail ( Colinus
virginianus ) 98.5 97 Moderately toxic 41725701
Hakin & Norman,

1989 Acceptable

Table A

- 11. Sub

- acute Dietary Toxicity to Birds

Species % ai LC 50 (mg ai/kg

- diet) Toxicity Category MRID
Author, Year Study

Classification

FERBAM

Bobwhite quail Tech 2940 Slightly toxic 00106146
Fink & Reno, 1973 Supplemental

Mallard duck Tech >4640 Slightly toxic 00106148
Fink & Reno, 1973 Supplemental

THIRAM

Bobwhite quail 95.0 3950 Slightly toxic 00022293
Hill et al., 1975 AcceptablePage 57 of 60 Species % ai LC 50 (mg ai/kg

- diet) Toxicity
Category MRID
Author, Year Study

Classification

Japanese quail ( Coturnix
japonica ) 95.0 >5000 Practically non

toxic 00022293
Hill et al., 1975 Supplemental

Mallard duck 95.0 >5000 Practically non

toxic 00022293
Hill et al., 1975 Acceptable

Ring

- neck pheasant 95.0 >5000 Practically non

toxic 00022293
Hill et al., 1975 Supplemental

ZIRAM

Bobwhite quail 98.5 >5200 Practically non

toxic 42386301

Hakin et al., 1992 Acceptable

Mallard duck 98.5 5156 Practically non

toxic 42386302 Hakin et al., 1992 Acceptable

Table A

- 12. Chronic Toxicity to Birds

Species % ai NOAEC / LOAEC (mg ai/kg

- diet) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAM

Bobwhite quail 97.5 500 / 2500 Egg production, eggs set/eggs laid,
viable embryos/ eggs set, normal hatchlings/eggs

set, 14

- d survivors/eggs set, feed consumption,

14

- d survivor bodyweight, hen

bodyweight 43612502
Beavers et al., 1995 Acceptable

Mallard duck 97.5 <50 / 50 Egg production, eggs set/eggs laid,
normal hatchlings/ eggs laid 43612501
Beavers et al., 1995 Supplemental

Mallard duck 98.7 9.6 / 39.7 Eggs set, viable embryos, live 3

- week embryos, normal hatchlings,

14

- d survivors,
eggs set/eggs laid, normal hatchlings/

live 3

- wk
embryos, normal hatchlings/eggs

laid 45441201 Gallagher et al., 2001 AcceptablePage 58 of 60 Species % ai NOAEC / LOAEC (mg ai/kg

- diet) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

ZIRAM

Mallard duck 98.8 29 / 64 Eggs set, eggs set/ eggs laid, embryo
viability, hatchability, 14

- day survivors, 14

-

day survivors/

eggs set 47286501 Temple et al., 2007 Acceptable



### 2.2. Mammalian Toxicity

Table A

- 13. Acute Oral Toxicity to Mammals

Species % ai LD 50 (mg ai/kg

- bw) Toxicity Category MRID
Author, Year Study

Classification

FERBAM

Laboratory rat
( Rattus norvegicus ) 91.8 >5,000 Practically non

toxic 40561501 Reijnders, 1987 Acceptable

Laboratory rat Tech >17,000 Practically non

toxic Farm Chemicals

Handbook Unknown

THIRAM

Laboratory rat 99.0 1800 (F)
3700 (M)
2600 (M & F) Slightly toxic 00153548
Thouin, 1985 Acceptable

ZIRAM

Laboratory rat 98.5 320 Moderately toxic 41340401 Liggett & Allan,

1989 Acceptable

Table A

- 14. Acute Inhalation Toxicity to Mammals

Species % ai 4

- hr LC 50 (mg ai/L) Toxicity Category MRID
Author, Year Study

Classification

FERBAM

Laboratory rat 91.8 0.40 Toxicity Category

II 41508101 Hardy & Jackson,

1988 Acceptable

THIRAM

Laboratory rat Tech >0.1 Not determined 00152556
Debets, 1985 Acceptable

Laboratory rat Tech 2.60 < LC 50 < 5.04 Not determined 40216501 Maedgen & Lain,

1987 Acceptable

ZIRAM

Laboratory rat 98.5 0.06 (F)
0.08 (M) Toxicity Category

II 41442001 Jackson & Hardy,

1989 AcceptablePage 59 of 60 Table A

- 1 5. 2

- Generation Reproductive Toxicity to Mammals

Species % ai NOAEC / LOAEC (mg ai /kg

- bw) Most Sensitive
Endpoint MRID No.
Author, Year Study

Classification

FERBAM

No data available

THIRAM

Laboratory rat 97.5 1.5 / 2.9 (M)
2.3 / 4.6 (F) F0: Mean maternal
body weight & food consumption,

male food
consumption 42095901
York, 1991 Acceptable

Laboratory rat 100 1.4 / 4.2 (M)
1.6 / 4.7 (F) F0 & F1: Body weight 45441203
Turck, 1997 Acceptable

ZIRAM

Laboratory rat 97.8 14.8 / 37.5 F0 & F1: Body weight, body
weight gain, food

consumption 43935801
Nemec, 1996 Acceptable



### 2.3. Terrestrial Invertebrate Toxicity

Table A

- 16. Acute Contact Toxicity to Honey Bees

Species % ai 48

- hr LD 50 (μg ai/bee) Toxicity
Category MRID
Author, Year Study

Classification

FERBAM

Honey bee ( Apis
Mellifera ) Fermate

form. >12.09 Practically non

toxic 00036935
Atkins & Anderson,

1967 Acceptable

THIRAM

Honey bee Tech 73.72 Practically non

toxic 00036935
Atkins et al., 1975 Acceptable

ZIRAM

Honey bee Zerlate

form. 46.65 Practically non

toxic 00036935
Atkins & Anderson,

1967 Acceptable

Honey bee 98.5 >200 Practically non

toxic 41667901
Cole, 1989 Acceptable



### 2.4. Terrestrial Plant Toxicity

No terrestrial plant toxicity data is available for ferbam or thiram. Data for ziram, another dimethyldithiocarbamate fungicide that degrades to thiram, are provided here.Page 60 of 60 Table A

- 17. Tier I Seedling Emergence

- Ziram (MRID 46893101; Porch & Krueger, 2006; Acceptable)

Species Seedling Height Seedling Dry Weight Emergence

NOAEC
(lbs ai/A) IC 25 (lbs ai/A) NOAEC
(lbs ai/A) IC 25 (lbs ai/A) NOAEC
(lbs ai/A) IC 25 (lbs ai/A)

Monocots

Corn (Zea mays) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Onion (Allium cepa) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Ryegrass (Lolium perenne) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Wheat (Triticum aestivum) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Dicots

Cabbage (Brassica oleracea) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Lettuce (Lactuca sativa) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Radish (Raphanus sativus) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Soybean (Glycine max) <6.0 1 >6.0 6.0 >6.0 6.0 >6.0

Tomato (Solanum lycopersicum) 6.0 >6.0 6.0 >6.0 6.0 >6.0

Turnip (Brassica rapa) 6.0 >6.0 6.0 >6.0 6.0 >6.0

1 Decrease in height of 16%; not statistically significant but considered biologically significant.

Table A

- 18. Tier I Vegetative Vigor

- Ziram (MRID 46893102; Porch & Krueger, 2006; Acceptable)

Species Plant Height Dry Weight Survival

NOAEC
(lbs ai/A) IC 25 (lbs ai/A) NOAEC
(lbs ai/A) IC 25 (lbs ai/A) NOAEC
(lbs ai/A) IC 25 (lbs ai/A)

Monocots

Corn (Zea mays) 6.1 >6.1 6.1 >6.1 6.1 >6.1

Onion (Allium cepa) 6.1 >6.1 6.1 >6.1 6.1 >6.1

Ryegrass (Lolium perenne) 6.1 >6.1 < 6.1 2 >6.1 6.1 >6.1

Wheat (Triticum aestivum) 6.1 >6.1 6.1 >6.1 6.1 >6.1

Dicots

Cabbage (Brassica oleracea) 6.1 >6.1 6.1 >6.1 6.1 >6.1

Lettuce (Lactuca sativa) 6.1 >6.1 6.1 >6.1 6.1 >6.1

Radish (Raphanus sativus) 1 6.1 >6.1 6.1 >6.1 6.1 >6.1

Soybean (Glycine max) 6.1 >6.1 6.1 >6.1 6.1 >6.1

Tomato (Solanum lycopersicum) 6.1 >6.1 <6.1 3 >6.1 6.1 >6.1

Turnip (Brassica rapa) 6.1 >6.1 6.1 >6.1 6.1 >6.1

1 A Tier II test was conducted for radish because 2 plants died in Tier I. No effects were seen in the Tier II test up to 6.1 l bs ai/A.

2 Decrease in dry weight of 13%; not statistically significant but considered biologically significant.

3 Decrease in dry weight of 12%; statistically significant.