UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON

, D

. C

. 20460

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

Da t e: November 24, 2015

PC C od e : 138009

DP Barc o d es: 425591, 425593, 425596, and 425599

MEMOR A NDUM

S U BJECT:

TO :

FROM :

THROU G H : E col ogica l risk assess m e nt fo r t he pr opose d new u ses o f th e f un g i ci d e, fl u xa p y r oxa d

,

a ppl ic at io n t o citr u s; g r ass fo r age, fo d d er
, st r aw, and h a y ; g r ass for see d ; and non

grass a nim al f ee d

, includin g a l fa lfa a nd cl ove r

Driss B en mh end, Risk Mana ger Reviewer
Shaja Joyner, Product Manager

Rachel Holl oman, Branch Chief
Fungicide Herbicide Branch
Registration Divi s i on (7505P)

Catherine Au bee, Senior Scientist

Chuck P eck

, Environme nt al Fa t e Scientis t

Environmental Risk Branch IV

Environmental Fate and Effects Division (7507P)

Jean Holmes, DV M

, Branch Ch i ef

Thomas S t eeger
, Ph

. D., Senior Science Adv i sor

James N. Carleton, Ph.D.

, Senior Fate Scientist

Environmental Risk Branch IV

Environmenta l Fate a nd Effect s Division (7507P)

Office of Pesticide Programs 2015

. 11.24 08:08:58

- 05'00 '

BASF Corporatio n
, the technical registrant for the fungicide active ingredien t (a.i.)

, fluxapyroxad ( PC Code 138009), submitte d a Section 3 New Use (S3NU) petition for uses on ci tru s, grass forage, fodder, s tra w,
and hay, grass for seed, and non

- g r ass animal feed, including alfalfa a nd clover. The u ses are propo se d

for th e formulated end

- u se product s
, Sercadi s ® (27 % a.i.) and lmbr ex ® (6 % a.i.), and for the dua l a.i. produ c t

, Priaxor ® (14.4% flux a pyro xa d

, 27

. 1% pyraclostrobin)

. The Environmental Fate a nd Effects

Divi sio n (EFED) has completed its ecological risk assess ment for the proposed new uses

.

1

### 2 The risk conclusions for th e new uses are similar to those for previously assessed uses. The proposed application rates are lower than those previously assessed for proposed uses on turf and ornamentals (DP Barcode 424038, 2015)

. The key finding is that aerial spray of Priaxor® to citrus presents acute (mortality) risks of concern from spray dri ft exposure in fish and amphibians in aquatic habitat , including species that are not federally listed as threatened or endangered ( i.e. , “non

- listed”). Acute r isks of concern to listed species are identified both for runoff and spray drift of the fluxapy roxad active ingredient (a.i.), for citrus only, and for spray drift of the Priaxor® product , from all proposed uses . For conclusions based on spray drift only, this assessment incorporates peak estimated environmental concentrations (EECs) resulting
from applications of each formulated product in a single year of use . A single year (as opposed to a longer time frame) is modeled for acute exposures from spray drift because, in this case, the relative proportions of formulation ingredients in the environme nt are expected to change over time. Toxicity and therefore risk conclusions differ to some extent across formulated products. S pray drift buffers may reduce these risks below the level of concern (LOC). Regarding chronic risks , f luxapyroxad is persistent , and reduced growth has been seen in laboratory studies with aquatic and terrestrial organisms. Chronic r isks exceed
the LOC in freshwater fish and aquatic

- phase amphibians (for use on citrus) and in mammals

, birds, reptiles, and terrestrial

- ph ase amphibians (all proposed uses)

. There is less certainty in the risk conclusion
for birds because growth effects have been observed at relatively low exposure levels in one test species only . For plants, t he proposed uses of Priaxor® present risks of concern to listed species of terrestrial dicotyledonous (dicot) plants, but risks to other terrestrial and aquatic plants are below levels of concern.
The risk conclusions are summarized in Table 1

.

Table 1. Summary of risk conclusions for proposed new uses of fluxapyroxad on citrus ; grass forage, fodder, straw, and hay ; grass for seed ; and nongrass animal feed, including alfalfa and clover

. “Yes” indicates that risk exceeds the Agency’s level of concern based on risk estimates (risk quotient values) and other lines of evidence.

Animals Status TGAI Sercadis® Imbrex® Priaxor® TGAI
Acute Risk (Mortality) Acute Risk (Mortality

– Spray Drift Only) Chronic Risk

Freshwater fish and amphibians Listed Yes ( C itrus only) No No Yes Yes
Reduced growth
(Citrus only) Nonlisted No No No Yes (Citrus

- aerial only)
Freshwater
invertebrates Listed No No No Yes No Nonlisted No No No No

Estuarine/marine
fish Listed No No a No a Yes a

No Nonlisted No No a No a Yes a
(Citrus

- aerial only) Estuarine/marine
invertebrates Listed No No a No a Yes a No Nonlisted No No a No a No a

Mammals Listed No No b No b No b Yes
Reduced growth Nonlisted No No b No b No b

Birds, reptiles, and amphibians c Listed No No b No b No b Yes
Reduced growth Nonlisted No No b No b No b

Bees Listed No No No No ND Nonlisted

Plants Status Risk (Reduced growth) Risk (Spray Drift Only)

Aquatic vascular Listed No No b No b ND

### 3 Nonlisted No No b No b ND Aquatic
nonvascular Listed No No b No b No
Nonlisted No No b No b No
Terrestrial

monocots Listed ND d No No e No
Nonlisted ND d No No e ND f

Terrestrial dicots Listed ND d No No e Yes
Nonlisted ND d No No e ND f

ND Not determined. Bold cells exceed the listed species LOC. Shaded cells also exceed the nonlisted species LOC.

a Based on magnitude of exceedance for spray drift exposure to freshwater fish, amphibians, and invertebrates. Typical end

- use product toxicity data were not submitted for estuarine/marine organisms.

b Based on risk conclusions for the TGAI.

c Exposed thro ugh the diet.

d Risk estimates were calculated using toxicity data for Priaxor®.

e Based on risk conclusions for Sercadis ®

. f Risk estimates were not calculated for nonlisted species because no effects >25% were observed. However, the studies with Priaxor ® only tested up to 0.087 lbs a.i./A, which is 71% of the maximum single application rate proposed for citrus.



### Previous Risk Assessments

EFED first assessed t he ecological risk s resulting from fluxapyroxad use in 2012 (DP Barcode 376883) following a global joint review of data for its initial registration (DP Barcode 376981, 2011) (DP Barcode 377186, 2011)

. Shortly thereafter , a Section 18 emergency exemption petition was assessed for use to control sheath blight on rice in Louisiana (DP Barcode 398595, 2012) . Subsequent risk assessments addressed proposed new uses for field application s (foliar, banded, in furrow, s prinkler) and agricultural
seed treatment s on multiple crops and on turf (DP Barcode 403913, 2013) (DP Barcode 413485, 2014) (DP Barcode 419669, 2015) (DP Barcode 425707, 2015) (DP Barcode 426251, 2015) (DP Barcode 426422, 2015) . The most recent fluxapyroxad assessment addresse d a proposed foliar use on or namentals and a
rate increase for the existing use on turf (DP Barcode 424038, 2015)

.

R isks identified in the most recent S3NU assessment included

• Risk of acute mortality in aquatic organisms exposed to spray drift of fluxapyroxad co

- formulated with pyraclostrobin ; and

,

• acute dietary risk to honey bees ( Apis mellifera ) that consume residues of fluxapyroxad co

formulated with pyraclostrobin (BAS 703 Orn) when applied to ornamentals at the maximum proposed rate

.

The envi ronmental fate and ecotoxicity of fluxapyroxad have been thoroughly reviewed in prior assessments. A comprehensive discussion of these data is available in the most recent S3NU for cotton and sugar beet seed (DP Barcode 419669, 2015)

. To summarize b riefly, fluxapyroxad is a persistent and moderately mobile compound which inhibits fungal growth by limiting activity of the succinate dehydrogenase enzyme needed for mitochondrial respiration ( MRID 47923771)

. There are no additional stressors of concern other than the parent compound. As a newer active ingredient, monitoring data for fluxapyroxad are not available, but a similarly

- structured fungicide (boscalid, PC Code 128008) ha s been
detected in air, surfac e water, sediment, and beeswax (Reilly, Smalling, Orlando, & Kuivila, 2012) (Schumer, Mothiron, Appenzeller, Rizet, & Millet, 2010) (Smalling & Orlando, 2011) (DP Barcode 418672, 2014)

. Fluxapyroxad is at least moderately toxic to aquatic organisms and practically nontoxic to terrestrial organisms on an acute exposure basis. Chronic effects on growth and reproduction have been
noted in both animals and plants. End

- use products containing fluxapyroxad co

- formulated with the fungicide, pyraclostrobin (PC Code 099100 ), are generally more toxic than fluxapyroxad alone.

### 4 S3NU Assessment for Proposed New Uses

The analysis plan and data used to evaluate potential ecological ri sks associated with the proposed new

uses ( Table 2 ) are generally the same as those used in the previous S3NU assessment (DP Barcode 424038, 2015) . However, this assessment considers only one year of use when calculating acute (peak) EECs for spray drift exposure to formulated product s , as the toxicity of the formulated product is dependent o n contributions of the relative proportions of the product’s constituents, which are expected to change in
the environment over long periods of time . Previous assessments have determined peak spray drift EECs based on accumulated exposure over a 30

- year timeframe and have presented a one

- year refinement only when recommending minimum buffer distances . This assessment does not provide recommended
buffer distances.

Table 2 . Fluxapyroxad application rates and retreatment intervals for proposed foliar uses.

Use(s) App.
Method Max. Single App. Rate (lbs a.i./A) No. of Apps. Per

season a Retreatment

Interv al (days) b PHI (days) Max. Annual App.

Rate (lbs a.i./

A/yr)

Citrus Foliar 0.122 4 10 0 0.488

Grass forage, fodder, and hay Foliar 0.089 3 14 14 0.267

Grass for seed Foliar 0.089 3 14 14 0.267

Non

- grass animal feed, including alfalfa
and clover Foliar 0.089 3 14 14 0.267

App.

- Application. Max.

- Maximum. N/A

- Not applicable. No.

– Number. PHI

– Pre

- harvest interval.

a Maximum number of applications specified on label.

b Label specifies no more than 2 consecutive applications before alternating to a fungicide with a different mode of action.



### This assessment tests the risk hypothes i s that the proposed new uses may result in exposure at magnitudes sufficient to cause adve rse effects to plants and /or animals in terrestrial and aquatic habitats.
The assessment determines whether the likelihood of such adverse effects exceeds the Agency’s
established LOCs. Where available, typical end

- use product (TEP) toxicity data are use d to assess risks from acute exposure to spray drift of formulated product to aquatic habitats and for terrestrial plant risk ( Table 3 )

.

### 5 Table 3. Fluxapyroxad products proposed for new uses and their TEPs used in the ecotoxicity assessment.

New Use Product (TEP) 1 Proposed Uses Name % Fluxapyroxad % Pyraclostrobin

Sercadis  SC (BAS 700 04 F) 27.0 NA Citrus; grass forage, fodder, and hay; grass for seed; n on

- grass animal feed, including alfalfa and
clover

Imbrex  6.0 NA Citrus; grass forage, fodder, and hay; grass for seed; n on

- grass animal feed, including alfalfa and
clover

Priaxor  SC (BAS 703 02 F) 14.4 27.1 Citrus; grass for seed; alfalfa

The reported percentages of active ingredient in TEP are for ecotoxicity test material and may differ slightly from registere d
labels.



### Estimated Environmental Concentrations (EECs)

Estimated environmental concentrations (EECs) are calculated for non

- target organisms in aquatic and
terrestrial habitats. The SWCC (surface water concentration calculator) modeling scenarios used to generate EECs in surface water are shown in Table 4

. Of these, only the results from the scenario generating the highest EE Cs are shown in subsequent tables. For estimated exposures to sediment

dwelling invertebrates, the FLcitrus scenario was run, as this scenario generated the highest peak ( i.e

., daily) surface water EECs in the SWCC runs. This estimate was converted to un its of μg/kg dry sediment by using the pore water/water column concentrations, the sediment organic carbon partition coefficient ( K oc 

### = 931 L/kg
oc 

### )

, and an assumption of equilibrium partitioning (US EPA, 2008) . For terrestrial exposure modeling, EECs are calculated using T

- REX (v. 1.5.2) and TerrPlant with the application rates in Table 2
and a default foliar dissipation half

- life of 35 days (T

- REX only)

.

Table 4 . Application scenarios and start dates for SWC C modeling.
Use(s) SWCC Scenario Application dates 1 Application Rates ( lbs a.i./A)

Citrus CACitrus

FLCitrus 0, 10, 20, 30 0. 12 2 x 4

Grass for
seed CATurfRLF
FLturfSTD
PATurfSTD 0, 14, 28 0.089 x 3

Grass forage, fodder, and hay, n on

grass animal feed CAalfalfaOP
ILalfalfaNMC
MNalfalfaOP
NCalfalfaOP
PAalfalfaOP
TXalfalfaOP 0, 14, 28 0.089 x 3

1. Dates are relative to emergence date.

### 6 The highest s urface water EECs from combined loading of runoff and spray drift to a water body are shown

in Table 5 . Peak EECs for acute exposure from spray drift only , which are used to assess aquatic exposure to formulated fluxapyroxad, are shown in Table 6

.

The 1

- in

- 10 year peak and 21

- day benthic pore water concentrations for use on citrus were each 26.9 μg/L, which yiel ded a n estimated sorbed concentration of 1, 012 μg/kg dry sediment. The use s on grass for seed and grass for forage are expected to result in lower benthic pore water and sediment EECs than
the use on citrus

.

Table 5 . Surface water EECs of fluxapyroxad fr om runoff plus spray drift (SWCC).

Use(s) Scenario Application
Method Application Rate (lbs a.i./A), Number of apps, RTI EECs (μg/L)

Peak 21 day 60 day

Citrus FLcitrus Aerial 0.122 x 4, 1 0 days 29.5 28.9 28.3

FLcitrus Ground 25.4 24.9 24.4

Grass for seed CATurfRLF Aerial 0. 0 8 9 x 3, 14 days 12.5 12.3 12.1

CATurfRLF Ground 7.68 7.58 7.50

Grass forage, fodder, and hay, n on

- grass animal feed ILalfalfaNMC Aerial

0. 0 8 9 x 3, 14 days 22.0 21.6 21.2

TXalfalfaOP Ground 17.9 17.4 17.0

RTI

– retreatment interval

.

Table 6

. Surface water EECs from spray drift only (SWCC) based on the proposed maximum number of fluxapyroxad applications in one year of use

.

Use(s) Scenario Application Method EECs (μg/L)

Peak

Citrus FLcitrus Aerial 2.66

FLcitrus Ground 1.32

Grass for seed CATurfRLF Aerial 1.49

CATurfRLF Ground 0.74

Grass forage, fodder, and hay ; n on

- grass animal feed ILalfalfaNMC Aerial 1.48

TXalfalfaOP Ground 0.73



### Table 7 shows EECs for terrestrial vertebrates exposed to fluxapyroxad residues in the diet. The highest EECs are for small vertebrates that primarily consume items like short grass ( EECs up to 1 02 mg/kg bw
and 56.7 mg/kg bw for small birds exposed following use on citrus and on grass and non

- grass f eed

, respectively ). For honey bees potentially exposed to fluxapyroxad through contact and through the diet,
Table 8 provides exposure estimates using equations documented in the bee risk assessment guidance (US Environmental Pr otection Agency (EPA), 2014)

. Table 9 shows EECs for terrestrial plants exposed to runoff and spray drift of fluxapyroxad adjacent to the treated field

.

### 7 Table 7 . Terrestrial EECs as food residues for animals exposed to fluxapyroxad as a result of the proposed foliar uses (T

- REX)

.

Food Type Dietary

- based (mg/kg diet) (mammals and birds) Dose

- based (mg/kg bw) (birds) Dose

- based (mg/kg bw) (ma mmals)

All Size Classes Small (20 g) Medium (100 g) Large (1000 g) Small (15 g) Medium (35 g) Large (1000 g)

Citrus ; 0. 122 lbs a.i./A; 4 applications; 1 0

- day interval Short grass 89.2 102 57.9 25.9 85.0 58.8 13.6 Tall grass 40.9 46.5 26.5 11.9 39.0 26.9 6.24 Broadleaf plants/small insects 50.2 57.1 32.6 14.6 47.8 33.1 7.66 Fruits/pods/seeds 5.57 6.35 3.62 1.62 5.31 3.67 0.85 Arthropods 34.9 37.8 22.7 10.2 33.3 23.0 5.34 Seeds (granivore) N/A 1.41 0.80 0.36 1.18 0.82 0.19
Grass for seed ; g rass forage, fodder, and hay ; non

- grass animal feed ; 0. 089 lbs a.i./A; 3 applications ; 14

- day interval Short grass 49.8 56.7 32.4 14.5 47.5 32.8 7.61 Tall grass 22.8 26.0 14.8 6.64 21.8 15.1 3.49 Broadleaf plants/small insects 28.0 31.9 18.2 8.15 26.7 18.5 4.28 Fruits/pods 3.11 3.55 2.02 0.91 2.97 2.05 0.48 Arthropods 19.5 22.2 12.7 5.67 18.6 12.9 2.98 Seeds (granivore) N/A 0.79 0.45 0.20 0.66 0.46 0.11

N/A Not applicable.

### 8 Table 8 . Contact and dietary exposure estimates for honey bees exposed to fluxapyroxad based on proposed new

uses.

Use Measurement Endpoint Exposure

Route Equation EEC

Citrus Individual Survival (adults) Contact AR English *(2.7 μ g a.i./bee) 0.329 Individual Survival (adults) Diet AR English *(110 μ g a.i /g)*(0.292 g/day) 3.92

Brood size and success Diet AR English *(110 μ g a.i /g)*(0.124 g/day) 1.66 Grass for seed; g rass forage, fodder, and hay; non

- grass animal
feed Individual Survival (adults) Contact AR English *(2.7 μ g a.i./bee) 0.240

Individual Survival (adults) Diet AR English *(110 μ g a.i /g)*(0.292 g/day) 2.86

Brood size and success Diet AR English *(110 μ g a.i /g)*(0.124 g/day) 1.21

AR English = application rate in lbs a.i./A (citrus: 0.122 lbs a.i./A , grass and non

- grass animal feed: 0.089 lbs a.i./A)

Table 9 . EECs for non

- target terrestrial and semi

- aquatic plants based on proposed uses of fluxapyroxad (TerrPlant). App.

- Application. Max.

- Maximum. N/A

- Not applicable.

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

Dry Area Semi

Aquatic

Area Spray Drift Only

Citrus 0.122 Aerial 0.007 0.018 0.006

Ground 0.002 0.013 0.001

Grass for seed; g rass forage, fodder, and hay;

non

- grass animal feed 0.089 Aerial 0.005 0.013 0.004

Ground 0.002 0.010 0.001



### Risk Estimation : RQ Values

E stimates of risk are calculated as risk quotients (RQs) based on the ratio of EECs to point estimates of toxicity, generally derived from laboratory studies. The RQ values are then compared to an established
LOC to evaluate risk to listed or non

- listed species. In some cases ( i.e ., chronic risk) the LOC is the same
for both listed and non

- listed species. Risk quotients generally are not calculated in the absence of a definitive toxicity endpoint. For fluxapyroxad, risk quo tients are calculated in this assessment for acute and chronic risk to fish and invertebrates, risk to aquatic plants, subacute (dietary) risk to birds, chronic risk to mammals, and risk to listed terrestrial plants. Other lines of evidence are integrated in the subsequent discussion of these risks and of other risks for which RQ values could not be calculated.

Aquatic Organisms

The proposed use on citrus results in RQ values that exceed the LOC for acute risk to listed species of
freshwater fish and for chronic risk to listed and non

- listed species of freshwater fish ( Table 10 ). These risk estimates are used as surrogates for risk to amphibians in aquatic habitat. Other RQ values for aquatic animals exposed to fluxapyroxad a.i. in the water column and in sediment are below LOCs.

### 9 Estuarine/marine and sediment t oxicity values for fish and invertebrates are provided for reference in
footnotes 2

, 3

, 4

, 5



### .

Table 10 . Acute and chronic RQ values for freshwater fish and invertebrates exposed to fluxapyroxad in surface

water (runoff and spray drift combined , based on toxicity data for TGAI )

.

Use App Rate lbs a.i./A

(#app) App
Method RQ Values

Freshwater Fish

LC 50 =290 μ g/L

NOAEC (from ACR) = 22 μ g/L Freshwater Invertebrate

EC 50 =5

, 100 μ g/L

NOAEC=460 μ g/L

Acute Chronic Acute Chronic

Citrus 0.122 (4) Aerial 

### 0.10 1. 3 0.0 1 0 .06

Ground 

### 0.09 1.1 0.0 1 0 .05

Grass for seed 0.089 (3) Aerial 

### 0.04 0.55 < 0.0 1 0 .03

Ground 

### 0.0 3 0.34 < 0.0 1 0.02
Grass forage, fodder, and hay; non

- grass animal feed 0.089 (3) Aerial 

### 0.0 8 0.96 < 0.0 1 0.0 5

Ground 

### 0.06 0.77 < 0.0 1 0.0 4

Bold values are RQs that exceed the Agency’s acute risk LOC (RQ> 0.05) for listed species or the chronic risk LOC (1) for listed/ non

- listed species.



### Freshwater fish are up to 64 times more sensitive to fluxapyroxad co

- formulated with pyraclostrobin (LC 50 

### =4.5 μ g/L ) 

### than to fluxapyroxad TGAI (LC 50 

### =290 μ g/L ) 

### . Freshwater invertebrates are up to 614 times

more sensitive to fluxapyroxad co

- formulated with pyraclostrobin (EC 50 

### =8.3 μ g/L ) 

### than to the fluxapyroxad

TGAI (EC 50 

### =5,100 μ g/L 

### ) . As a result, all proposed uses of the Priaxor  

### formulation present acute risk
concerns for listed species of aquatic animals ( Table 1 1 and Table 12 )

. Aerial application to citrus presents
RQs that exceed the acute risk l evel of concern for non

- listed species of fish and aquatic

- phase amphibians

. RQ values are not calculated for e stuarine/marine organisms exposed to fluxapyroxad end

use products because formulated product toxicity data for these organisms were not submitted. Nonetheless, based on the relative increase in sensitivity of freshwater organisms to formulations of
fluxa pyroxad that include pyraclostrobin, acute risk to estuarine/marine fish and invertebrates from spray drift exposure of these products is presumed likely to exceed the listed species LOC

. Although exposure to the fluxapyroxad a.i. through spray drift and runoff (combined) presents risks of concern for the use on citrus, exposure to single a.i. formulations through spray drift (alone) does not present acute risks of
concern for fish

, or aquatic invertebrates. Spray drift

- only EECs represent a single year of applications, as the toxicity of the fo rmulated product is dependent on the relative contributions of the product’s constituents, which are not expected to be in the same proportions beyond a year.

Table 1 1 . Acute RQ values for freshwater fish exposed to fluxapyroxad end

- use product s in surface water as a result of spray drift only, for multiple applications in a single year

.

Use App Rate lbs a.i./A

(#app) App Method Spray Drift RQ Values

Fish

Sercadis 

LC 50 = 660 μ g/L Fish

Imbrex 

LC 50 = 470 μ g/L Fish

Priaxor 

LC 50 = 4.5 μ g/L

2 Sheepshead minnow ( Cyprinodon variegatus ): LC 50 =1,300 μ g/L ; estimated NOAEC=100 μ g/L (from fathead minnow, Pimephales promelas , ACR=0.077)

3 Eastern oyster ( Crassotrea virginica ) IC 50 =960 μ g/L

4 Freshwater amphipod ( Hyalella azteca ): 10

- d NOAEC=67,000 μ g /kg dry sediment

5 Estuarine/marine amphipod ( Leptocheirus plumulosus ): 10

- d NOAEC=27,000 μ g /kg dry sediment

### 10 Acute Acute Acute

Citrus 0.122 (4) Aerial <0.01 <0.01 

### 0.59

Ground <0.01 <0.01 

### 0.29

Grass for seed 0.089 (3) Aerial <0.01 <0.01 

### 0.33

Ground <0.01 <0.01 

### 0.16
Grass forage, fodder, and hay; non

- grass animal feed 0.089 (3) Aerial <0.01 <0.01 

### 0.33

Ground <0.01 <0.01 

### 0.16

Bold values are RQs that exceed the Agency’s acute risk LOC (0.05) for listed aquatic species

. Shaded
values also exceed the acute risk LOC (0.5) for nonlisted species.

Table 1 2 . Acute RQ values for freshwater invertebrates exposed to fluxapyroxad end

- use products in surface

water as a result of spray drift only, for multiple applications in a single year

.

Use App Rate lbs a.i./A

(#app) App
Method Spray Drift RQ Values

Invertebrates

Sercadis 

LC 50 = 28,000 μ g/L Invertebrates

Imbrex 

LC 50 = 680 μ g/L Invertebrates

Priaxor 

LC 50 =8.3 μ g/L

Acute Acute Acute

Citrus 0.122 (4) Aerial <0.01 <0.01 

### 0.32

Ground <0.01 <0.01 

### 0.16

Grass for seed 0.089 (3) Aerial <0.01 <0.01 

### 0.18

Ground <0.01 <0.01 

### 0.09
Grass forage, fodder, and hay; non

- grass animal feed 0.089 (3) Aerial <0.01 <0.01 

### 0.18

Ground <0.01 <0.01 

### 0.09

Bold values are RQs that exceed the Agency’s acute risk LOC (0.05) for listed aquatic species

. Shaded
values also exceed the acute risk LOC (0.5) for nonlisted species.



### All RQ values calculated for aquatic plants are below LOCs for listed and non

- listed species. Toxicity values are presented in footnotes for reference 6

, 7

, 8

. 

### Risk estimates are not calculated for formulated product

e xposure in 

### aquatic vascular plants because formulated product toxicity data are not available for this taxonomic group

.

Terrestrial organisms

In this assessment, RQ values are calculated for subacute, dietary

- based risk to birds (not shown)

, for chronic risk to mammals ( Table 1 3 ) , and for acute risks to honey bees ( Table 1 4 ) . RQ values are not calculated for acute, dose

- based risk to birds, chronic risk to birds, or acute risk to mammals because the toxicity endpoints needed for these calculations are non

- definitive. Specifically, the LD 50 

### values for birds and mammals were greater than the highest dose tested in each study; whereas, the NOAEC value for chronic toxicity to birds was estimated to be less than the lowest treatment level tested in the avian reproduction study with bobwhite quail ( Colinus virginianus )

.

For the foliar uses of fluxapyroxad on citrus and on grass and non

- grass animal feed , the subacute dietary

based RQ values for birds are below the Agency’s LOCs for acute risk to listed (RQ≥0.1) and non

- listed (RQ≥0.5) specie s. Dose

- adjusted RQ values 9 

### exceed the level of concern for chronic risk to mammals

6 Aquatic vascular plants exposed to fluxapyroxad TGAI: EC 50 = 2,400 μg a.i./L

, NOAEC= 440 μg a.i./L

7 Aquatic nonvascular plants exposed to fluxapyroxad TGAI: EC 50 = 370 μg a.i./L

, NOAEC= 150 μg a.i./L

8 Aquatic nonvascul ar plants exposed to Priaxor  : EC 50 =120 μg a.i./L

, NOAEC=14 μg a.i./L

9 Two

- generation reproduction in rat ( Rattus norvegicus ): NOAEC=112 mg ai/kg diet, NOAEL=10 mg ai/kg bw/day

### 11 (RQ > 1) that consume certain types of dietary items within a fluxapyroxad treatment area, particularly short grass and broadleaf plants ( Table 1 3 )

. For the use on citrus, calculated residues on tall grass and arthropods within the treatment area also exceed the chronic risk LOC for wild mammals.

Table 1 3 . Chronic dietary and dose

- based RQ values for mammals exposed to fluxapyroxad as a result of the proposed foliar uses.

Food Type Dietary

- based (mg/kg diet)

Rat NOAEC = 112

mg ai/kg diet Dose

- based (mg/kg bw) Rat NOAEL = 10 mg ai/kg bw/day

All Size Classes Small (15 g) Medium (35 g) Large (1000 g)

Citrus ; 0. 122 lbs a.i./A; 4 applications; 1 0

- day interval Short grass 0.80 3.87 3.30 1.77 Tall grass 0.36 1.77 1.51 0.81 Broadleaf plants 0.45 2.18 1.86 1.00 Fruits/pods 0.05 0.24 0.21 0.11 Arthropods 0.31 1.52 1.29 0.69
Seeds N/A 0.05 0.05 0.02
Grass for seed ; g rass forage, fodder, and hay ; nongrass animal feed ; 0. 089 lbs a.i./A; 3 applications ; 14

- day interval Short grass 0.44 2.16 1.85 0.99 Tall grass 0.20 0.99 0.85 0.45 Broadleaf plants 0.25 1.22 1.04 0.56 Fruits/pods/seeds 0.03 0.14 0.12 0.06 Arthropods 0.17 0.85 0.72 0.39
Seeds N/A 0.03 0.03 0.01

N/A Not applicable. Bolded values in shaded cells exceed the Agency’s Level of Concern (LOC) for chronic risk to listed and nonlisted wild mammals (RQ > 1).



### Fluxapyroxad is practically non

- toxic to young adult honey bees on an acute oral and an acute contact exposure basis 10

, 11



### . The LD 50 

### values for the Priaxor  

### product are greater than the highest dose tested 12



### . Using the acute contact and oral LD 50 

### values for Imbrex ® as a conservative screen for the toxicity of fluxapyroxad, the acute RQ values for the proposed new uses are below acute risk LOCs (0.4) for both contact and dietary exposure of adult bees ( Table 1 4 ) . No Tier 1 chronic toxicity data with the honey bee are available; therefore, chronic RQ values for fluxapyroxad risk to honey bees are not calculated. A semi

field study (bee brood tunnel test) conducted with another dual a.i. product, Merivon  

### (BAS 703 01 F), indicated no significant effects on bee brood development or viability at the single treatment rate of 0.14 lbs fluxapyroxad a.i./A (MRID 48812702, 2015) . Although a slight and transient treatment

- related e ffect on foraging of adult bees was noted, it was not identified as statistically significant and recovery occurred within the course of the study with no apparent adverse effect on the bee colonies

.

10 TGAI : acute contact and oral LD 50 >100 μg a.i./bee

11 Imbrex ® end

- use product (BAS 700 01 F, 6% a.i.): contact LD 50 = 15.7 μg a.i./bee; oral LD 50 = 62.8 μ g a.i./bee

12 Priaxor  : contact LD 50 > 33.3 μg fluxapyroxad a.i./bee , oral LD 50 > 32.4 μg fluxapyroxad a.i./bee

### 12 Table 1 4 . Contact and dietary exposure RQ values for honey bees exposed to fluxapyroxad based on proposed

new uses.

Use Measurement Endpoint Exposure Route EEC Acute Chronic

Citrus Individual Survival (adults) Contact 0.329 0.02 Not
calculated Individual Survival (adults) Diet 3.92 0.06

Brood size and success Diet 1.66 Not calculated
Grass for seed; grass forage, fodder, and hay;

non

- grass animal feed Individual Survival (adults) Contact 0.240 0.02 Individual Survival (adults) Diet 2.86 0.05

Brood size and success Diet 1.21 Not calculated

AR English = application rate in lbs a.i./A
Based on Imbrex ® EP: contact LD 50 = 15.7 ug a.i./bee; oral LD 50 = 62.8 ug a.i./bee.



### For terrestrial plants, RQ values for the foliar uses in this assessment ( Table 1 5 ) are calculated based on the most sensitive toxicity endpoints from the submitted seedling emergence and vegetative vigor tests with Sercadis® 13 

### and Priaxor ® 14 

### . When comparing EECs to the toxicity data for Sercadis®, risk to terrestrial plants from exposure to solo formulations of fluxapyroxad ( Sercadis® and Imbrex® ) is below the LOC

. However, t he proposed use s of Priaxor ® result in RQ values for dicot yledonou s (dicot) plants which exceed the Agency’s LOC for risk to listed plants in semi

- aquatic areas . The aerial (including airblast) use of

Priaxor ® on citrus yields RQ values that also exceed the LOC for listed dicot plants in dry areas and for listed dicot plants exposed through spray drift only. No RQ values are calculated for non

- listed plant

spec ies exposed to fluxapyroxad because all differences from control plants are less than 25% at the highest application rates tested

.

Table 1 5 . RQ values for listed species of non

- target terrestrial and semi

- aquatic plants based on proposed uses of fluxapy roxad (TerrPlant).

Use(s) Formulation App
Method Dry Area RQs Semi

- Aquatic Area RQs Spray Drift Only
RQs

Monocot Dicot Monocot Dicot Monocot Dicot

Citrus 

### Sercadis® 13 Aerial <0.10 <0.10 <0.10 <0.10 <0.10 <0.10

Ground <0.10 <0.10 <0.10 <0.10 < 0.10 <0.10



### Priaxor ® 14 Aerial 0.16 1.33 0.41 3.33 0.14 1.11

Ground <0.10 0.44 0.30 2.44 <0.10 0.22

Grass for seed; grass forage, fodder, and hay; non

- grass animal feed 

### Sercadis® 13 Aerial <0.10 <0.10 <0.10 <0.10 <0.10 <0.10

Ground <0.10 <0.10 <0.10 <0.10 <0.10 <0.10



### Priaxor ® 14 Aerial 0.12 0.97 0.30 2.43 <0.10 0.81

Ground <0.10 0.32 0.22 1.78 <0.10 0.16

13 Based on seedling emergence and vegetative vigor (monocot and dicot NOAEL=0.226 lbs a.i./A) data for

Sercadis 

. 14 Based on seedling emergence (monocot NOAEL=0.0446 lbs a.i./A, dicot NOAEL = 0.0055 lbs a.i./A) and vegetative vigor (monocot NOAEL=0.0681 lbs a.i./A, dicot NOAEL=0.0167 lbs a.i./A) data for Priaxor 

.

### 13 Risk Description and Conclusions

The best available data for fluxapyroxad support the risk hypotheses that the proposed new uses on citrus and on grass and non

- grass animal feed may result in exposure and adverse effects to certain terrestrial plants and to animals in terrestrial and aqua tic habitats. Specifically, the Agency’s LOCs are exceeded for

• Acute risk s to non

- listed species of fish and aquatic

- phase amphibians from spray drift of Priaxor® ( citrus

– aerial)

• Acute risk s to listed species of freshwater fish and aquatic

- phase amphibians from runoff and spray drift

, combined ( citrus

– ground and aerial)

• Acute risk s to listed species of fish, aquatic

- phase amphibians, and invertebrates from spray drift of Priaxor® (all proposed uses)

• C hronic risks to freshwater fish and aquatic

- phase amphibians (citrus

– ground and aerial )

• Chronic risks to mammals and to birds, reptiles, and terrestrial

- phase amphibians exposed through the diet (all proposed uses)

• Risks to listed species of d icot plants (all proposed uses of Priaxor ® )

Acute risk to aquatic animals from exposure to fluxapyroxad co

- formulated with pyraclostrobin (Priaxor®) may be reduced below LOCs by implementing spray drift buffers of a specified distance in combination with a specified droplet size distribution ( e.g ., medium

- to

- coarse).

There is uncertainty regarding the potential for chronic risk to birds (and other non

- mammalian vertebrates exposed through the diet) . Bobwhite quail exposed to fluxapyroxad in the laboratory diet grew less than untreated birds. The difference was slight (<10%) but statistically significant at treatment levels as low as 100 mg/kg diet. The highest dietary EECs for the proposed uses ( citrus : 89.2 mg/kg diet, grass and non

- gr ass animal feed : 49.8 mg/kg diet) are below this value , but a lower bound (NOAEC) for
the effect has not been established . Therefore, the potential for adverse effects (impaired growth) in birds following chronic exposure is uncertain

. However, given tha t similar effects were not reported in mallard ducks, t he magnitude of potential effects is likely to vary according to species

.

Overall, the risks identified for the proposed new uses of fluxapyroxad on citrus and on grass and non

grass animal fe ed are similar to those associated with previously assessed uses.

### 14 References Reilly, T., Smalling, K., Orlando, J., & Kuivila, K. (2012). Occurrence of boscalid and other selected fungicides in surface water and groundwater in three targeted use areas in the United States.
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