NH N+

NH2

-

O

O

Level I Screening Ecological Risk Assessment

for the Reregistration of Dodine

Dodine (dodecylguanidine monoacetate)

CAS No. 2439-10-3

Prepared by:

Christopher J. Salice, Biologist

Marietta Echeverria, Environmental Scientist

U. S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch IV

1200 Pennsylvania Ave., NW

Mail Code 7507C

Washington, DC 20460

Reviewed by:

Elizabeth Behl, Branch Chief

Ed Fite, Senior Biologist

Kevin Costello, RAPL
Page 2 of 219

1 EXECUTIVE SUMMARY

1.1 Nature of Chemical Stressor

Dodine (n-dodecylguanidine monoacetate; CAS 2439-10-3) is a fungicide of the guanidine group of

chemicals. Dodine is classified as a general toxophore with several sites of action; it has been shown to

disrupt the cytoplasmic membrane of some plant pathogens. Dodine is registered for control of a range of

pathogenic fungi that affect a number of agricultural and some ornamental crops. Current formulations

for dodine include liquid flowable concentrate and wettable powder. Based on current label information,

dodine is applied via ground spray, airblast or aerial application to apples, cherries, peaches, pears,

pecans, strawberries, and black walnut; crab apple and ornamental shade trees (SLN OR). There are no

expected major environmental degradates (other than CO2) of dodine. 

This assessment utilizes environmental fate and toxicity data for both dodine and DGH (dodecylguanidine

hydrochloride) because these compounds behave the same under environmental conditions. Dodine and

DGH are water soluble salts of a strong base, dodecylguanidine, and are expected to dissociate to the

same degree under any normal environmental conditions. As strong bases, these compounds will be

completely dissociated in aqueous solutions at normal environmental pHs. At the low concentrations

present in the environment, and in the presence of moisture, both compounds would be present as the

dodecylguanidinium ion and either the acetate or chloride ion. DGH is an antimicrobial pesticide that is

used as a sanitizer, bacteriostat, microbiocide, microbistat, fungicide, algicide, and molluscicide. 

Currently, a quantitative evaluation of the likelihood of the ecological exposures resulting from the

industrial uses of DGH overlapping spatially and temporally with the exposures resulting from the

agricultural uses of dodine is not possible. Therefore, the ecological risks are not aggregated in this

assessment.

1.2 Potential Risks to Non-target Organisms

This is a national screening-level ecological risk assessment for all labeled uses of dodine. The aquatic

assessment involved Tier II modeling (PRZM/EXAMS) for scenarios representing all proposed dodine

uses. Monitoring data were not considered because national-scale monitoring studies were not identified. 

Tables 1.1 and 1.2 summarize the major conclusions and uncertainties of this assessment for aquatic and

terrestrial receptors, respectively. The results of this screening-level risk assessment suggest the potential

for direct adverse acute effects to non-target aquatic freshwater invertebrates, non-vascular aquatic plants,

saltwater invertebrates and mollusc based on modeled national aerial application rates (7.8 to 13.0 lb

ai/A/yr) of dodine except strawberries and in some cases pears, and walnuts. The results also suggest the

potential for direct adverse acute effects to non-target terrestrial birds and mammals and chronic effects to

birds and mammals, based on modeled aerial application rates of dodine (2.0 to 13.0 lb ai/A/yr). 

Simulations indicate that to reduce risk below the chronic risk levels of concern for birds and mammals,

the application rate for a single application would have to be 0.825 lbs a.i./A and 0.29 lbs a.i./A for birds

and mammals, respectively. Also, based on modeled aerial applications to apples (Pennsylvania; 11.7 lbs.

a.i./A/yr) there is the potential for direct adverse acute effects to endangered and/or threatened (listed)

freshwater fish and chronic effects on freshwater invertebrates. Functionally, the estimated risks may

translate to reduced survival and reproduction of impacted species with subsequent effects at higher levels

of biological organization. Dodine is not likely to pose an acute risk to saltwater/estuarine fish nor is it

likely to pose a chronic risk to freshwater fish. There were no identified incidents or field studies to

either support or refute the estimated risks. 
Page 3 of 219

Chronic endpoints for saltwater fish and invertebrates could not be determined because no data were

available and the possibility of risk from chronic exposure to these receptors can not be precluded. The

low estimated acute risk to saltwater fish may indicate low risk to this receptor resulting from chronic

exposure as well. However, the high sensitivity of freshwater invertebrates and estimated risks to

saltwater invertebrates and molluscs indicate that conclusive determinations of chronic risk to saltwater

invertebrates cannot be made without more data.

 

Complete evaluation of the risk to aquatic plants could not be conducted since
Page 4 of 219

Table 1.1. Summary of Environmental Risk Conclusions for Aquatic Organisms and Plants

Risk Category Use: Application Rate a Summarized Risk Characterization and Important Unc

Acute Risk toFreshwater Fish

 Apples: 11.7 lbs ai/A/yr aerial* The acute RQ, based on aerial application to apples (in Pen

endangered species LOC. Exposure concentrations based at other sites did not result in exceedances. The Pennsylvacharacterized by relatively high average annual erosion, wexceedance for this use despite not having the highest appl

Chronic Risk toFreshwater Fish

None The available data suggest that dodine is not likely to pose 

freshwater fish based on modeled chronic exposure estima

Acute Risk toFreshwaterInvertebrates

Apples: 11.7 lbs ai/A/yr aerial***Cherries: 7.8 lbs ai/A/yr aerial***Peaches: 13.0 lbs ai/A/yr aerial***Pears: 11.7 lbs ai/A/yr aerial**Pecans: 13.0 lbs ai/A/yr aerial***Walnuts: 13.0 lbs ai/A/yr aerial**

The acute RQs, based on aerial applications of all national strawberries, exceed endangered species, acute restricted u

Chronic Risk toFreshwaterInvertebrates

Apples: 11.7 lbs ai /A/yr aerial The chronic RQ, based on aerial application to apples (in P

the LOC. Exposure concentrations based on application to not result in exceedances. The Pennsylvania apple scenarirelatively high average annual erosion, which results in the despite not having the highest application rate of all uses.

Acute Risk toEstuarine/Marine Fish

None The available data suggest that dodine is not likely to pose 

estuarine/marine fish based on modeled exposure estimate

Chronic Risk toEstuarine/Marine Fish

Unknown Chronic endpoints for esturaine/marine fish can not be der

data was not available. Risk to esturaine/marine fish from dodine can not be precluded. This is a source of uncertain

Acute Risk toEstuarine/MarineInvertebrates

Apples: 11.7 lbs ai/A/yr aerial**Cherries: 7.8 lbs ai/A/yr aerial**Peaches: 13.0 lbs ai/A/yr aerial*Pecans: 13.0 lbs ai/A/yr aerial**

The acute RQs, based on aerial applications of all national strawberries, and walnuts exceed acute restricted use and/o
Table 1.1. Summary of Environmental Risk Conclusions for Aquatic Organisms and Plants

Risk Category Use: Application Rate a Summarized Risk Characterization and Important Unc

Page 5 of 219

Chronic Risk toEstuarine/MarineInvertebrates

Unknown Chronic endpoints for estuarine/marine invertebrates can n

toxicity data are not available. Risk to estuarine/marine inexposure of dodine can not be precluded. This is a source assessment. 

Acute Risk toEstuarine/MarineMollusc

Apples: 11.7 lbs ai/A/yr aerial**Cherries: 7.8 lbs ai/A/yr aerial**Peaches: 13.0 lbs ai/A/yr aerial**Pecans: 13.0 lbs ai/A/yr aerial**Walnuts: 13.0 lbs ai/A/yr aerial*

The acute RQs, based on aerial applications of all national strawberries, exceed acute restricted use and/or listed spec

Risk to AquaticVascular Plants

Unknown There are no available aquatic vascular plant toxicity data; 

and source of uncertainty in this assessment. Risk to aquanot be precluded. 

Risk to Aquatic Nonvascular Plants Apples: 11.7 lbs ai/A/yr aerial*** Cherries: 7.8 lbs ai/A/yr aerial*** 

Peaches: 13.0 lbs ai/A/yr aerial*** Pears: 11.7 lbs ai/A/yr aerial*** Pecans: 13.0 lbs ai/A/yr aerial*** Walnuts: 13.0 lbs ai/A/yr aerial***

The acute RQs, based on aerial applications for all nationastrawberries, exceed LOCs.

a Aerial applications assume 5% spray drift.

* Exceeds acute listed species LOC for aquatics.** Exceeds acute listed species and acute restricted use LOC for aquatics.*** Exceeds acute listed species, acute restricted use and acute LOC for aquatics. 
Page 6 of 219

Table 1.2. Summary of Environmental Risk Conclusions for Terrestrial Organisms and Plants

Risk Category Use: Application Rate Summarized Risk Characterization and Important UncAcute Risk to Birds Apples: 11.7 lbs ai/A/yr aerial***

Cherries: 7.8 lbs ai/A/yr aerial***Crab apples (OR): 2.04 lbs ai/A/yr aerial***Ornamentals (OR): 5.1 lbs ai/A/yr aerial***Peaches: 13.0 lbs ai/A/yr aerial*** Pears: 11.7 lbs ai/A/yr aerial*** Pecans: 13.0 lbs ai/A/yr aerial*** Strawberries: 6.5 lbs ai/A/yr aerial***Walnuts: 13.0 lbs ai/A/yr aerial***

Acute, acute restricted use and/or listed species LOCs are consume short grass, tall grass, broadleaf plants, and small uses based on both dietary-based and dose-based toxicity eare exceeded even when non-conservative predicted mean concentrations) are used to assess risk. Sublethal effects nstudies include depression, reduced reaction to stimuli, wincoordination.

Chronic Risk to Birds Apples: 11.7 lbs ai/A/yr aerial

Cherries: 7.8 lbs ai/A/yr aerial Crab apples (OR): 2.04 lbs ai/A/yr aerialOrnamentals (OR): 5.1 lbs ai/A/yr aerialPeaches: 13.0 lbs ai/A/yr aerial Pears: 11.7 lbs ai/A/yr aerial Pecans: 13.0 lbs ai/A/yr aerial Strawberries: 6.5 lbs ai/A/yr aerialWalnuts: 13.0 lbs ai/A/yr aerial

The chronic LOC is exceeded for all dodine uses, based on specifically, reduction in number of eggs laid, eggs set, viaweek embryos, hatchlings, 14-day old chick survivors and 

Acute Risk toMammals

Apples: 11.7 lbs ai/A/yr aerial***Cherries: 7.8 lbs ai/A/yr aerial ***Crab apples (OR): 2.04 lbs ai/A/yr aerial*Ornamentals (OR): 5.1 lbs ai/A/yr aerial**Peaches: 13.0 lbs ai/A/yr aerial*** Pears: 11.7 lbs ai/A/yr aerial*** Pecans: 13.0 lbs ai/A/yr aerial*** Strawberries: 6.5 lbs ai/A/yr aerial**Walnuts: 13.0 lbs ai/A/yr aerial***

Acute, acute restricted use and/or listed species LOCs are that consume short grass, tall grass, broadleaf plants, and sweight classes for all dodine uses based on dose-based femendpoint. Acute LOCs are exceeded even when non-conse

residue values (exposure concentrations) are used to assess 
Table 1.2. Summary of Environmental Risk Conclusions for Terrestrial Organisms and Plants

Risk Category Use: Application Rate Summarized Risk Characterization and Important Unc

Page 7 of 219

Chronic Risk toMammals

Apples: 11.7 lbs ai/A/yr aerialCherries: 7.8 lbs ai/A/yr aerial Crab apples (OR): 2.04 lbs ai/A/yr aerialOrnamentals (OR): 5.1 lbs ai/A/yr aerialPeaches: 13.0 lbs ai/A/yr aerial Pears: 11.7 lbs ai/A/yr aerial Pecans: 13.0 lbs ai/A/yr aerial Strawberries: 6.5 lbs ai/A/yr aerialWalnuts: 13.0 lbs ai/A/yr aerial

Based on both dietary-based and dose-based toxicity endpoexceeded for all use rates, for wild mammals that consume broadleaf plants, and small insects, and in some cases fruitinsects. Risk estimates are based on deleterious effects of dgain.

Terrestrial Plants Assumed for all uses of Dodine A Tier I plant study shows a potential for dodine uses to ad

plants. Without a Tier II study, risk to listed terrestrial pla

of Tier II data is a major data gap and a source of uncertain

Non-target Insects None Based on acute contact toxicity studies on honeybees, dodi

practically non-toxic to these receptors.

* Exceeds acute listed species LOC for terrestrial animals.** Exceeds acute listed species and acute restricted use LOC for terrestrial animals.*** Exceeds acute listed species, acute restricted use and acute LOC for terrestrial animals. 
Page 8 of 219

PRZM/EXAMS modeling suggests that even though erosion was the dominant route of off-site transport

of dodine, spray drift alone as a route of exposure to freshwater invertebrates may be of concern.

Refined spray drift exposure estimates (AgDRIFT) were used to determine spray drift buffers for possibly

mitigating risk to listed freshwater invertebrates in aquatic ecosystems that are within close proximity to

agricultural fields that may be treated with liquid spray applications of dodine. Required buffer distances,

based on maximum aerial application rates and screening-level defaults, are expected to exceed the 1,000

foot limit of AgDRIFT. Modeled buffer requirements for listed freshwater invertebrates, based on

maximum aerial application rates and a 10-foot release height in wind speeds < 10 mph, are expected to

range from approximately >1,000 to 880 ft. for ASEA fine and ASEA medium droplet sizes, respectively. 

For orchard airblast applications for the lowest and highest national application rates, Tier I AgDRIFT

modeling suggests that buffer distances of 154 and 76 ft., respectively, would be sufficient to reduce

exposure concentrations below the LOC for listed freshwater invertebrates.

Based on acute risk to freshwater fish and both freshwater and saltwater invertebrates, indirect effects to

Federally endangered and threatened (listed) species (i.e., fish, mammals, birds, reptiles, amphibians) that

eat freshwater fish and freshwater or saltwater invertebrates may occur. The potential for adverse effects

to those listed obligate and general species that rely on aquatic plants for food and/or habitat and shelter

also exists.

1.3 Conclusions - Exposure Characterization

Dodine applied to an agricultural field is likely to be immobile in soils and is generally not expected to

persist longer than a few weeks. Based on a low estimated vapor pressure, volatilization is an unlikely

route of dissipation from the field. 

Because of dodine’s high partitioning coefficient and relative rapid degradation in aerobic soils, the

potential to reach aquatic ecosystems dissolved in runoff or leachate is limited. Dodine may, however,

be transported off-site to aquatic ecosystems adsorbed to eroded sediment or via spray drift during aerial,

airblast or ground spray applications. In aquatic environments, dodine is resistant to hydrolysis and

photolysis. In aerobic aquatic environments, dodine is likely to be moderately persistent to persistent. In

anaerobic aquatic environments, dodine is likely to be very persistent. Major environmental degradates

(excluding CO2) are not expected. 

For aquatic organisms, exposures to dodine are based on dodine dissolved in a water body. The routes of

dodine exposure are the integument and respiratory surfaces such as gills in fish and cutaneous absorption

as in some invertebrates and amphibians. Aquatic and terrestrial plants would be exposed to dodine

dissolved in water as well. Estimated surface water exposure concentrations were derived from Tier II

modeling with PRZM/EXAMS for all national uses of dodine. For birds and mammals, only the dietary

route of exposure is considered. Estimates of residues on food items such as grasses, broadleaf plants and

insects were obtained from the empirically determined Kenaga nomogram which relates pesticide

application rate to residues on food items. Estimates of daily food ingestion rates are used in combination

with the food item residue levels to determine daily exposure levels. 

1.4 Conclusions - Effects Characterization
Page 9 of 219

Dodine is practically non-toxic to honeybees, mammals, and estuarine/marine fish and slightly toxic to

birds on an acute exposure basis. Dodine is highly toxic to aquatic non-vascular plants, freshwater

invertebrates, estuarine/marine invertebrates and molluscs on an acute exposure basis. 

Dodine is slightly toxic to birds, mammals and freshwater invertebrates based on chronic exposures. In

birds, chronic effects on mallard ducks include reduced numbers of eggs laid, eggs set, viable embryos,

viable 3-week embryos, hatchlings, 14-day-old survivors and reduced adult food consumption, hatchling

body weight and adult female body weight. For mammals, chronic effects were limited to reductions in

body weight and body weight gain in rats. The results from the rat study were supported by a chronic

study on dogs which also showed reductions in body weight in some exposed individuals. 

1.5 Uncertainties and Data Gaps

The major data gap is the lack of aquatic plant and terrestrial plant toxicity studies. For dodine, the only

registrant-submitted aquatic plant study was on green alga (Selenastrum capricornutum). Results from

this study indicate that dodine is green algae. However, there are insufficient data to generate a

suitable understanding of the toxicity of dodine to aquatic 

There was also no submitted fish bioconcentration (BCF) study. This is a data gap and a source of

uncertainty in this assessment. However, the Hazardous Substances Data Bank (HSDB, 2005) reports an

estimated BCF for dodine of 16 suggesting that the potential for bioaccumulation in aquatic organisms is

low.
Page 10 of 219

TABLE OF CONTENTS

1 EXECUTIVE SUMMARY ..................................................... 2

1.1 Nature of Chemical Stressor .............................................. 2

1.2 Potential Risks to Non-target Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1.3 Conclusions - Exposure Characterization .................................... 8

1.4 Conclusions - Effects Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1.5 Uncertainties and Data Gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2 PROBLEM FORMULATION ................................................. 13

2.1 Stressor Source and Distribution .......................................... 13

2.1.1 Source and Intensity ....................................... 13

2.1.2 Physical/Chemical/Fate and Transport Properties ................ 14

2.1.3 Pesticide Type, Class and Mode of Action ..................... 14

2.1.4 Overview of Pesticide Usage ................................ 14

2.2 Receptors ............................................................ 15

2.2.1 Ecological Effects ........................................ 15

2.2.2 Ecosystems at Risk ....................................... 16

2.3 Assessment Endpoints .................................................. 16

2.4 Conceptual Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2.4.1 Risk Hypotheses ......................................... 17

2.4.2 Conceptual Model Diagram ................................. 17

2.5 Analysis Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.5.1 Preliminary Identification of Data Gaps and Methods ............ 20

2.5.2 Measures to Evaluate Risk Hypotheses and Conceptual Model ..... 23

2.5.2.1 Measures of Exposure ........................ 23

2.5.2.2 Measures of Effect ........................... 23

3 ANALYSIS ................................................................ 26

3.1 Use Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

3.2 Exposure Characterization ............................................... 28

3.2.1 Environmental Fate and Transport Characterization .............. 28

3.2.2 Measures of Aquatic Exposure .............................. 31

3.2.2.1 Aquatic Exposure Modeling .................... 31

3.2.2.2 Aquatic Exposure Monitoring and Field Data ..... 40

3.2.3 Measures of Terrestrial Exposure ............................ 40

3.2.3.1 Terrestrial Exposure Modeling ................. 41

3.2.3.2 Residue Studies ............................. 44

3.3 Ecological Effects Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

3.3.1 Aquatic Effects Characterization ...................... 45

3.3.1.1 Aquatic Animals ............................. 45

3.3.1.2 Terrestrial Animals .......................... 48

4 RISK CHARACTERIZATION ................................................ 51

4.1 Risk Estimation - Integration of Exposure and Effects Data ..................... 52

4.1.1 Non-target Aquatic Animals and Plants ........................ 53

4.1.1.1 Freshwater Fish and Invertebrates .............. 54

4.1.1.2 Estuarine/Marine Fish and Invertebrates ......... 54
Page 11 of 219

4.1.1.3 Aquatic Plants ............................. 55

4.1.2 Non-target Terrestrial Animals .............................. 56

4.1.2.1 Birds ...................................... 56

4.1.2.2 Mammals .................................. 60

4.1.2.3 Plants ..................................... 65

4.1.3 RQs Based on Mean Kenaga Residues ........................ 65

4.2 Risk Description ....................................................... 72

4.2.1 Risks to Aquatic Organisms ................................. 73

4.2.1.1 Freshwater Fish ............................. 74

4.2.1.2 Freshwater Invertebrates ...................... 74

4.2.1.3 Saltwater Fish .............................. 76

4.2.1.4 Saltwater Invertebrates ....................... 76

4.2.1.5 Aquatic Plants .............................. 77

4.2.2 Risks to Terrestrial Organisms ............................... 77

4.2.2.1 Birds ...................................... 77

4.2.2.2 Mammals .................................. 79

4.2.2.3 Plants ..................................... 80

4.2.3 Non-Target Insects ........................................ 80

4.2.4 Review of Incidents Data ................................... 80

4.2.5 Federally Threatened and Endangered (Listed) Species of Concerns . 80

4.2.5.1 Action Area ................................ 82

4.2.5.2 Taxonomic Groups Potentially at Risk ........... 82

4.3 Description of Assumptions, Limitations, Uncertainties, Strengths and Data Gaps

.................................................................... 95

4.3.1 Assumptions and Limitations Related to Exposure for all Taxa ..... 95

4.3.2 Assumptions and Limitations Related to Exposure for Aquatic Species

....................................................... 95

4.3.3 Assumptions and Limitations Related to Exposure for Terrestrial Species96

4.3.3.1 Location of wildlife species .................... 96

4.3.3.2 Routes of exposure ........................... 97

4.3.3.3 Incidental Pesticide Releases Associated with Use . . 98

4.3.3.4 Residue Levels Selection ...................... 98

4.3.3.5 Dietary Intake - The Differences Between Laboratory

and Field Conditions ......................... 99

4.3.4 Assumptions and Limitations Related to Effects Assessment ....... 99

4.3.4.1 Age class and sensitivity of effects thresholds ...... 99

4.3.4.2 Lack of Effects Data for Amphibians and Reptiles . 100

4.3.4.3 Use of the Most Sensitive Species Tested ......... 100

4.3.4.4 Data Gaps ................................ 100

4.3.5 Assumptions Associated with the Acute LOCs ................. 101

LITERATURE CITED ............................................................ 102

APPENDIX A. Maximum Use Rates Based on Current Labels Compiled by BEAD ......... 104

APPENDIX B. Environmental Fate Data ............................................. 109
Page 12 of 219

APPENDIX C. Aquatic Exposure Modeling Assessment - PRZM/EXAMS Outputs ......... 115

APPENDIX D. Ecological Effects Characterization for Dodine and DGH .................. 144

APPENDIX E. ECOTOX References not Used in Dodine Risk Assessment ................. 159

APPENDIX F. Spray Drift Assessment: AgDRIFT Modeling Approach and Results ......... 161

APPENDIX G. Listed Species by State ............................................... 164

APPENDIX H. Guideline Sequence Bibliography for Dodine ............................ 217
Page 13 of 219

2 PROBLEM FORMULATION

Problem formulation is used to establish the direction and scope of an ecological risk assessment. 

According to the Guidelines for Ecological Risk Assessment (USEPA, 1998), problem formulation

consists of defining the problem and purpose for the assessment, and developing a plan for analyzing and

characterizing risk. The critical components of the problem formulation are selection of the assessment

endpoints, formulation of risk hypotheses and the conceptual model, and development of an analysis plan. 

The analysis plan and supporting rationale are aimed at determining whether the proposed uses of dodine

on registered crops could result in exposures that cause unreasonable adverse effects (risk) to non-target

organisms including those federally listed as threatened or endangered (hereafter referred to as “listed”). 

This assessment was developed as part of the supporting information to determine the eligibility of dodine

for re-registration. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) requires that

registered pesticide uses do not pose unreasonable adverse effects to the environment, and the

Endangered Species Act requires that regulatory actions are not likely to adversely affect Federally listed

species or their habitats.

2.1 Stressor Source and Distribution

2.1.1 Source and Intensity

The source of the stressor considered in this ecological risk assessment is formulated dodine applied for

agricultural and some non-agricultural uses. In addition, the dissociation product of dodine,

dodecylguanidinium cation, is also derived from the antimicrobial active ingredient, dodecylguanidine

hydrochloride (DGH). Therefore, this assessment utilizes environmental fate and toxicity data for both

dodine and DGH since these compounds behave the same under environmental conditions (i.e., in water

and moist soil). DGH is an antimicrobial pesticide that is used as a sanitizer, bacteriostat, microbiocide,

microbiostat, fungicide, algicide, and molluscicide. Both dodine and DGH are water soluble salts of a

strong base, dodecylguanidine, that are expected to dissociate to the same degree under any normal

environmental conditions. As strong bases, these compounds will be completely dissociated in aqueous

solutions at normal environmental pHs. At the low concentrations present in the environment, and in the

presence of moisture, both compounds would be present as the dodecylguanidinium ion and either the

acetate or chloride ion.

DGH uses include: industrial once-through cooling water systems, auxiliary water and waste water

systems, enhanced oil recovery systems, recirculating cooling water systems, oil field water systems, oil

recovery drilling fluids, pulp and papermill systems, process waters and non-potable water treatment,

preservation of pulp and papermill chemicals, adhesives, and coatings, sewage disposal lagoons,

disposable diapers, food packaging, non-paper related aqueous systems, liquid concentrates, and air

washers. Given the similarities between DGH and dodine, there is the potential for exposure to aquatic

organisms to dodecylguanidinium based on both agricultural uses of dodine and industrial uses of DGH. 

However, current uses of DGH preclude a robust quantitative assessment of the likelihood of ecological

exposure resulting from uses of DGH overlapping both spatially and temporally with the potential

exposures resulting for the agricultural uses of dodine. Therefore, the ecological risks are not aggregated

in this assessment.

Dodine is applied via ground spray, airblast or aerial application to apples, cherries, peaches, pears,

pecans, strawberries and walnuts. Terrestrial exposure is based on direct spray application on food items

including short grass, seeds, and broadleaf plants and insects resulting from applications of dodine at the
Page 14 of 219

maximum label rates. Exposure to aquatic organisms is the result of runoff and spray drift from labeled

applications and is functionally the amount of compound in the water that would directly contact

organisms. The magnitude of exposure estimates are largely dependent on the biology of the receptor

(e.g., food consumption rate), the use patterns and environmental fate and transport, which are further

explored later in this document. 

2.1.2 Physical/Chemical/Fate and Transport Properties

 There are no

anticipated major environmental degradates of dodine.

2.1.3 Pesticide Type, Class and Mode of Action

Dodine is a fungicide of the guanidine group of chemicals and is considered a general toxophore with

several sites of action that may differ among members of the guanidine group. Primarily, dodine’s mode

of action is through disruptions of cell membranes. Dodine has been shown to cause extensive damage to

the cytoplasmic membrane of the common plant pathogen, Pseudomonas syringae, as evidenced by cell

death and leakage of K+, UV-absorbing materials, and ribose-containing molecules (Cabral, 1991). It is

registered for control of a range of pathogenic fungi that affect a number of agricultural and some

ornamental crops. Current formulations for dodine include liquid flowable concentrate and wettable

powder. Based on current label information, dodine is registered for use on apples, cherries, peaches,

pears, pecans, strawberries, and black walnut; crab apple and ornamental shade trees (SLN OR). 

2.1.4 Overview of Pesticide Usage

Dodine is used as a pre- or post-infection fungicide that is formulated as a liquid flowable concentrate 

and wettable powder. Dodine has been used to control fungal diseases on apples, cherries, peaches, pears,

pecans, strawberries and walnuts. Dodine may be applied to a number of stages of crop growth including

delayed dormant, dormant, foliar, pre-bloom, early bloom, bloom, petal fall, postharvest, and popcorn (a

developmental stage just before petals begin to open in peaches only). Mostly, dodine is applied by

ground using an air blast sprayer and is applied in a dilute or concentrate form. 

The National Center for Food and Agricultural Policy (NCFAP) reported a total use of 264,664 lbs. of

dodine in 1992. In 1997, the NCFAP reported a decrease from the 1992 total use to about 151,538 lbs. 

In both years, dodine was used most on apples followed by pears in 1992 and pecans in 1997. While

these data provide some insight into the historic use of dodine, fungicide use changes with the varying

resistance of fungi; predicting total use prospectively is difficult since it may be based on the

susceptibility of a particular fungus to a specific fungicide.
Page 15 of 219

2.2 Receptors

2.2.1 Ecological Effects

Table 2.1 provides taxonomic groups and test species used to indicate the potential for ecological effects

in this screening-level risk assessment. Within each of these very broad taxonomic groups, an acute

and/or chronic endpoint is selected from the available test data (see Section 2.3). A complete discussion

of all toxicity data available for this risk assessment and the resulting measurement endpoints selected for

each taxonomic group are included in Appendix D.

Table 2.1 Taxonomic Groups and Most Sensitive Test Species Evaluated for 

Ecological Effects of Dodine.

Taxonomic group Example(s) of representative species Endpoint Used

Birdsa Mallard duck (Anas platyrhynchos)

Bobwhite quail (Colinus virginianus)

Chronic, NOAEC

Acute, LD50/LC50

Mammals Laboratory rat (Rattus norvegicus) Acute LD50 and Chronic

NOAEL/NOAEC

Terrestrial insects Honeybees (Apis mellifera) Acute Oral LD50

Freshwater fishb Rainbow trout (Oncorhynchus mykiss)

Fathead minnow (Pimephales

promelas)

Acute LC50

Chronic NOAEC

Freshwater invertebrates Water flea (Daphnia magna)

Midge (Chironomus riparius)

Acute LC50 and Chronic

NOAEC

Chronic NOAEC

(Benthic)

Estuarine/marine fish Sheepshead minnow (Cyprinodon

variegatus)

Acute LC50

Estuarine/marine invertebrates Mysid shrimp (Mysidopsis bahia) 

Eastern oyster (Crassostrea virginica)

Acute LC50

Acute EC50

Terrestrial plantsc Monocots – corn (Zea mays)

Dicots – soybean (Glycine max)

Acute (Tier I, no EC50

estimated)

Aquatic plants and algae Green algae (Selenastrum

capricornutum)

Acute EC50

a

Birds are used as surrogates for terrestrial phase amphibians and reptiles (US EPA, 2004). b

Freshwater fish are used as surrogates for aquatic phase amphibians (US EPA, 2004). c

Four species of two families of monocots, of which one is corn; six species of at least four dicot families, of which one is

soybeans.
Page 16 of 219

2.2.2 Ecosystems at Risk

An ecosystem can be defined as a functional unit consisting of all the living organisms (plants, animals,

and microbes) in a given area, and all the non-living physical and chemical factors of their environment,

linked together through nutrient cycling and energy flow. An ecosystem can be of any size- a log, pond,

field, forest, or the earth's biosphere- but it always functions as a whole unit. Ecosystems are commonly

described according to the major type of vegetation, for example, forest ecosystem, old-growth

ecosystem, or range ecosystem. The ecosystems that could be potentially at risk due to agricultural use of

dodine include terrestrial and aquatic (lakes, ponds, streams) habitats in proximity to dodine use areas. 

Moreover, these habitats may be at risk from drift and/or runoff of dodine from use areas. The

estuarine/marine ecosystems are likely at less risk since they are typically further from agricultural areas

and are characterized by large volumes of water. However, in some areas where agriculture dominates

the landscape, risks to estuarine/marine ecosystems cannot be excluded. 

To address specific ecosystems at risk in this screening-level assessment is beyond the scope of this

effort. Generally, concerns of risk to ecosystems are addressed in the identification of assessment

endpoints, which reflect ecological entities and their associated attributes. Functionally, this assessment

specifically addresses risks at the individual level. However, given that the toxicity endpoints used in the

assessment relate directly to higher-levels of biological organization, any risks identified are considered

to provide insight into potential risks to ecosystems and ecosystem function. 

2.3 Assessment Endpoints

Assessment endpoints are defined as “explicit expressions of the actual environmental value that is to be

protected.” Operationally, the environmental value is represented by an ecological entity and associated

attributes or characteristics. The assessment endpoints for this ecological risk assessment are survival,

growth, and reproduction of terrestrial and aquatic animals and plants. Specifically, this assessment

addresses birds, mammals, reptiles, amphibians, terrestrial and aquatic invertebrates, terrestrial and

aquatic plants, and fish. These endpoints, in turn, are meant to reflect population sustainability and

community diversity within ecosystems. These are standard assessment endpoints that are considered for

the majority of pesticides with agricultural uses.

Measures of effect and measures of exposure are explicit toxicity and exposure measurements or

estimates that are used to identify risks. Measures of effect are used to relate pesticide exposure to

potential effects on the assessment endpoints, which are not explicitly evaluated in the assessment. 

Measures of exposure are typically values derived from chemical use information and standard fate,

transport and exposure models. The toxicity and exposure values are used to generate a risk quotient,

which is considered a screening-level estimate of risk, only. Additional refinements may be triggered if

the screen identifies potentially unacceptable levels of risk. Refinements may include the selection of

assessment endpoints more directly relevant to populations or communities, spatially-explicit

identification of risks, and the use of probabilistic methods for risk estimation. 

Assessing risks to reptiles and amphibians represents unique challenges. Currently, data on direct toxicity

to reptiles and amphibians are not required as part of the standard dataset submitted to the Agency for

pesticide registration or re-registration and these data are only occasionally available from the literature. 
Page 17 of 219

For ecological risk assessments in the Office of Pesticide Programs (OPP), if risks to birds are below the

level of concern, then risks to reptiles are also assumed to be low. For amphibians freshwater fish are

considered a suitable surrogate for the aquatic life-stage and birds a suitable surrogate for the terrestrial

life-stage.

2.4 Conceptual Model

2.4.1 Risk Hypotheses

The Office of Pesticide Programs uses a screening risk hypothesis for its initial risk assessments.

The risk hypothesis is that the use of dodine in accordance with the label results in adverse effects on

survival and/or fecundity to non-target terrestrial and/or aquatic animals; and that the use of dodine

according to the label results in adverse effects on survival, reproduction and/or growth to aquatic, semiaquatic and terrestrial plants. 

2.4.2 Conceptual Model Diagram

The conceptual model used to depict the potential ecological risk associated with dodine is fairly generic

and assumes that as a fungicide, dodine can affect terrestrial and aquatic organisms if environmental

concentrations are sufficiently elevated as a result of proposed label uses. A diagram of the conceptual

model is presented in Figure 2.1. All of the use scenarios for dodine involve foliar application of the

pesticide. Although not evident from the diagram, dodine degradation prior to runoff is explicitly

considered. Runoff includes transport of dodine in a dissolved state as well as dodine adsorbed to eroded

sediment. 

As there may be multiple applications of the pesticide to foliage in many of the labeled use patterns,

degradation on the foliage between applications is considered in the terrestrial assessments. The

dissipation rate from foliage used in the terrestrial assessments was 35 days, which is the default value. It

represents an upper bound on expected foliar dissipation rates across all pesticides, based on data in

Willis and McDowell (1987). For aquatic assessments the microbial degradation on foliage was assumed

stable, but wash-off of the foliage was considered using the default wash-off coefficient assumption of 0.5

cm-1. Spray drift was directly considered in the aquatic assessments as a route of loading to the pond,

with higher levels of spray drift for aerial applications vs. ground spray applications.

For terrestrial assessments, spray drift was not directly considered. However, since the evaluation of risk

was done for on-field foliage, non-target foliage receiving spray drift should have reduced pesticide

loading and the assessment based on the on-field residues would be protective of both. A variety of food

types (i.e., short grass, long grass, broadleaf plants etc.) were assessed regardless of the type represented

by the target crop, as a variety of food types will exist on and off the treated field.
Page 18 of 219

For aquatic assessments, once dodine reaches a water body, the pesticide is partitioned between the water

column, suspended sediment, and bed sediment based on its physical/chemical properties. Degradation

by photolysis, abiotic hydrolysis, and microbial metabolism is taken into account. The route of exposure

is uptake of dodine dissolved in the water column through the gills and integument.

 No studies on

the bioaccumulation of dodine in fish were available for review. However, the Hazardous Substances

Data Bank (HSDB, 2005) lists an estimated BCF for dodine of 16 suggesting that the potential for

bioaccumulation in aquatic organisms is low.

For birds and mammals, only the dietary route of exposure is considered. While there is a potential for

dermal and inhalation exposure from the foliar use, the data needed to assess these routes are not available

for dodine. Furthermore, these routes are not usually assessed at the screening level. Although the

inhalation route of exposure was also not assessed, dodine has a low vapor pressure, suggesting that

inhalation is not likely to be significant relative to other routes of exposure. 
Page 19 of 219

Stressor

Dodine applied as a ground/aerial spray (aerial or ground)

Source/

Transport

Pathways

Direct

Deposition

Runoff/

Erosion

Leaching

(Infiltration/

Percolation

Source/

Exposure

Media

Terrestrial Food 

Items (foliage, fruit, 

insects, seeds)

Upland

Foliage/Soil

Riparian/

Wetland 

Foliage/Soil

Receiving 

Water Body/ 

Sediment

Groundwater

Exposure

Route Ingestion Direct contact/

Root Uptake

Direct contact/

Root Uptake

Gill/

Integument 

Uptake

Receptors

Attribute

Changes

Terrestrial Vertebrates

Birds, Mammals,

Reptiles, Terrestrial 

Phase Amphibians

Terrestrial

Upland

Plants

Individual Animals

Reduced survival

Reduced growth

Reduced

reproduction

Aquatic 

Invertebrates

Aquatic 

Vertebrates

Wetland/ 

Riparian

Plants

Individual Plants

Seedling emergence

Vegetative vigor

Individual 

vertebrates and 

invertebrates

Reduced

survival

Reduced

growth

Reduced

reproduction

Plant 

population

Reduced

population

growth

Aquatic 

Plants

Uptake/ 

Adsorption

Spray

Drift

Stressor

Dodine applied as a ground/aerial spray (aerial or ground)

Source/

Transport

Pathways

Direct

Deposition

Runoff/

Erosion

Leaching

(Infiltration/

Percolation

Source/

Exposure

Media

Terrestrial Food 

Items (foliage, fruit, 

insects, seeds)

Upland

Foliage/Soil

Riparian/

Wetland 

Foliage/Soil

Receiving 

Water Body/ 

Sediment

Groundwater

Exposure

Route Ingestion Direct contact/

Root Uptake

Direct contact/

Root Uptake

Gill/

Integument 

Uptake

Receptors

Attribute

Changes

Terrestrial Vertebrates

Birds, Mammals,

Reptiles, Terrestrial 

Phase Amphibians

Terrestrial

Upland

Plants

Individual Animals

Reduced survival

Reduced growth

Reduced

reproduction

Aquatic 

Invertebrates

Aquatic 

Vertebrates

Wetland/ 

Riparian

Plants

Individual Plants

Seedling emergence

Vegetative vigor

Individual 

vertebrates and 

invertebrates

Reduced

survival

Reduced

growth

Reduced

reproduction

Plant 

population

Reduced

population

growth

Aquatic 

Plants

Uptake/ 

Adsorption

Spray

Drift

Figure 2.1 Conceptual model of the fate/transport and effects dodine in the environment. 
Page 20 of 219

2.5 Analysis Plan

2.5.1 Preliminary Identification of Data Gaps and Methods

The primary method used to assess risk in this screening-level assessment is the risk quotient (RQ) and

follows closely methods outlined in the EPA Overview Document (US EPA, 2004). 

. The resulting RQ is then compared to a specified level of concern

(LOC), which represents a point of departure for concern; if the RQ exceeds the LOC, then risks are

triggered.

Levels of concern are the policy tool for interpreting risks from direct pesticide effects and have a

magnitude, duration, frequency, and spatial extent. The magnitude is set by the risk presumption for each

endpoint (described below). The frequency of potential risk is once every ten years for aquatic endpoints

and one in every ten foliage samples for terrestrial risk. The spatial extent is defined by the use area, and

the areas downstream and areas potentially affected by spray drift. 

To evaluate the potential risk to non-target organisms from the use of dodine, risk quotients (RQ) are

calculated from the ratio of estimated environmental concentrations (EECs) to toxicity values. Risk

quotients are then compared to the LOCs to indicate potential risk to non-target organisms and the

consequent need to consider regulatory action. Risk presumptions, along with the corresponding RQs,

equations, and LOCs are summarized in Tables 2.2-2.5. The exposure estimates in this screening

assessment are derived using maximum label rates and minimum application intervals for each use. 
Page 21 of 219

Table 2.2 Risk presumptions for terrestrial animals (birds and wild mammals).

Risk Presumption RQ LOC

Acute EEC1

/LC50 or LD50/ft2 or

LD50/day3

0.5

Acute Restricted Use EEC/LC50 or LD50/ft2

 or

LD50/day (or LD50 < 50

mg/kg)

0.2

Acute Endangered Species EEC/LC50 or LD50/ft2

 or

LD50/day 

0.1

Chronic Risk EEC/NOEC 1

1

 abbreviation for Estimated Environmental Concentration (ppm) on avian/mammalian food items 

2

 mg/ft2 3 mg of toxicant consumed/day

 LD50 * wt. of bird LD50 * wt. of bird 

Table 2.3 Risk presumptions for aquatic animals. 

Risk Presumption RQ LOC

Acute EEC1

/LC50 or EC50 0.5

Acute Restricted Use EEC/LC50 or EC50 0.1

Acute Endangered Species EEC/LC50 or EC50 0.05

Chronic Risk EEC/NOEC 1

1

EEC = (ppm or ppb) in water

Table 2.4 Risk presumptions for terrestrial and semi-aquatic plants. 

Risk Presumption RQ LOC

Acute Risk EEC1

/EC25 1

Acute Endangered Species EEC/EC05 or NOEC 1 1

 EEC = lbs ai/A 
Page 22 of 219

Table 2.5 Risk presumptions for aquatic plants. 

Risk Presumption RQ LOC

Acute High Risk EEC1

/EC50 1

Acute Endangered Species EEC/EC05 or NOEC/EC05 or

NOEC

1

1

 EEC = (ppb/ppm) in water 

Generation of robust RQs is dependent on the quality of data from both fate and toxicological studies. 

These studies should be conducted following Agency guidelines and are subjected to extensive review to

ensure data quality. 

Estimates of exposure are generated using maximum label rates and minimum intervals between

applications. Toxicity values used in the risk quotient calculations are based on the most sensitive species

tested for a given exposure duration and taxonomic group.

Although the lowest toxicity value from available studies is used for RQ calculations, typically, only data

from a few species are available. For example, the Agency usually receives avian toxicity studies for

bobwhite quail and mallard ducks. Of the 650 avian species in the United States, bobwhite quail or

mallard ducks may not be the most sensitive. These species, in fact, were chosen primarily because they

are easy to maintain and rear in the laboratory and they have some value as game species. The same

argument holds for all toxicity estimates; in all likelihood the representative species are not the most

sensitive. Similarly, for reptiles and amphibian, typically no toxicity data is available at all. In

accordance with the EPA guidance (US EPA, 2004) birds are used as surrogates for terrestrial amphibians

and reptiles and fish are used as surrogates for aquatic amphibians. This is thought to result in

conservative estimates of risk for herpetofauna; however, due to the lack of available data, it is difficult to

determine whether this is the case or not. 

Exposure estimates are generated from chemical fate studies and label information, particularly maximum

application rates and minimum application intervals. Although exposure estimates using maximum label

rates and minimum interval times generate maximum EECs, they represent requested use rates. Actual

use rates may vary over the labeled range, particularly for certain uses.

Exposure estimates for terrestrial species are generated assuming these species feed exclusively on the

treated field soon after application of the pesticide. Moreover, the assumption is that these organisms will

consume at a particular daily ingestion rate while on the treated field. Although some individuals at

particular times may feed exclusively on a treated field, the actual frequency and duration of this type of

behavior is a source of uncertainty. While the current approach may overestimate exposure for some

individuals, it does capture the potential exposures that may occur. 

The major data gap regarding dodine toxicity is the lack of aquatic plant toxicity studies and registrant

submitted terrestrial plant studies. Agency guidelines indicate that for outdoor pesticide uses, plant

toxicity studies are required on a number of species including Selenastum capricornutum (green alga),

Lemna gibba (duckweed), Skeletonema costatum (marine diatom), and Anabaena flos-asquae (blue-green

alga). For dodine, the only registrant-submitted aquatic plant study was on green alga (Selenastrum

capricornutum). Results from this study indicate that dodine is highly to green alga; however, there

are insufficient data to generate a suitable understanding of the toxicity of dodine to aquatic plants. 
Page 23 of 219

Moreover, there are no registrant submitted Tier II data for the effects of dodine on terrestrial plants. Tier

I terrestrial plant studies indicate some effects of dodine at the highest registered application rate. 

Without Tier II data, however, it is impossible to conduct a thorough assessment of risks to terrestrial

plants from the use of dodine. This is particularly important in assessing risks to Federally listed species

given the multitude of listed plant species and the dependence of many animal species on a wide variety

of plant species.. The lack of toxicity data on aquatic and terrestrial plants represents a serious data gap in

the toxicity profile of dodine. 

Another important data gap is the lack of chronic toxicity studies on estuarine/marine fish and

invertebrates. Acute studies on representative species from these taxa indicate low toxicity of dodine,

which might suggest that chronic toxicity is low as well. Alternatively, freshwater invertebrates, in

particular, are extremely sensitive to dodine under chronic exposure conditions. In the absence of chronic

toxicity data on estuarine/marine fish and invertebrates, estimates of risk are highly uncertain. 

2.5.2 Measures to Evaluate Risk Hypotheses and Conceptual Model

Measures of exposure and measures of effect are used to evaluate the risk hypotheses and are listed in

Tables 2.6 and 2.7 for a specific assessment endpoint. The RQ is obtained by dividing the measures of

exposure for a particular assessment endpoint by the measures of effect for that endpoint.

2.5.2.1 Measures of Exposure

Measures of exposure are estimates of exposure for a receptor determined by modeling and/or monitoring

data. Measures of exposure for dodine in this assessment are obtained from modeling efforts only, since

national-scale monitoring data were not identified. Exposure models used for this assessment include the

suite of standard exposure models commonly used in pesticide risk assessments (EPA, 2004). Generally,

aquatic exposure estimates are generated from EFED models and incorporate maximum proposed use

rates and empirically-derived fate properties. Further details of the exposure models can be found in

Section 3.2 and on the web http://www.epa.gov/oppefed1/models/water/index.htm.

Measures of exposure for terrestrial mammals, birds, reptiles and amphibians similarly incorporate

maximum proposed use rates but rely less on fate properties. Instead, terrestrial exposure estimates are

derived directly from empirically determined observations of pesticide residues on various terrestrial food

items. The Kenaga nomogram, as modified by Fletcher et al., 

is used to relate pesticide application rates to residues on terrestrial food items. For numerous

applications for a given use, the exposure model incorporates a first-order decay rate dependent on the

soil half life of the chemical. The default foliar dissipation half-life of 35 days was used in this

assessment. Review of the bibliography on dodine indicated that several studies may provide data for use

in estimating a foliar dissipation half-life. The default foliar dissipation half-life was used since the uses

of dodine involve multiple applications and some simulations indicated that changes in the foliar

dissipation half-life did not have a significant effect on exposure estimates. The current terrestrial

exposure model used by EFED is TREX v.1.1. 

2.5.2.2 Measures of Effect

Measures of effect are based on deleterious changes in a receptor as a result of chemical exposure. 

Functionally, measures of effect typically used in risk assessments include changes in survival,

reproduction, or growth as determined from standard laboratory toxicity tests. The focus on these effects

for quantitative risk assessment is due to their clear relationship to higher-order ecological systems such
Page 24 of 219

as populations, communities, and ecosystems. Although effects other than survival, reproduction, and

growth may be considered, rarely are they used quantitatively to estimate risks since, in many cases, the

relationship between other effects and higher-order processes is tenuous at best. Commonly used

laboratory-derived toxicity values include estimates of acute mortality (e.g., LD50, LC50) and estimates of

effects due to longer term, chronic exposures (e.g., NOAEC, NOAEL). In general, for a given assessment

endpoint the lowest relevant measure of effect is used is calculating the RQ. More details concerning

measures of effect used in this assessment can be found in Section 3.3. 

Table 2.6 Terrestrial assessment endpoints.

Assessment Endpoint Measures of Effect

(Toxicity Endpoints)

Measures of Exposure

(Exposure Endpoints)

Avian Survival acute avian oral LD50, dietary

LC50 for most sensitive bird

tested, adjusted for size for 20-g

bird

maximum concentration on food

items (foliar) or dose on planted

seeds consumed by 20 g bird

Avian Reproduction and/or

Survival

NOAEC/LOAEC from avian

chronic study for most sensitive

bird tested

maximum residue on food items

(foliar) or planted seeds

Mammalian Survival acute oral LD50, dietary LC50 for

most sensitive mammal tested

maximum concentration on food

items (foliar) or dose on planted

seeds

Mammalian Reproduction

and/or Survival 

NOAEC/LOAEC from chronic

mammalian study for most

sensitive mammal tested

maximum concentration on food

items

Non-target Beneficial Insect

Survival

Honey-bee acute contact LD50 maximum application rate

Terrestrial Plants Survival and

Growth

Tier I, Tier II plant toxicity

data; EC25

estimates of runoff and spray

drift to non-target areas
Page 25 of 219

Table 2.7 Aquatic assessment endpoints

Assessment Endpoint Measures of Effect

(Toxicity Endpoints)

Measures of Exposure

(Exposure Endpoints)

Freshwater Fish Survival 96-hr LC50 for most sensitive

species tested

1-in-10 year peak concentration

Freshwater Fish Reproduction

an/or Survival

Fish Early Life Stage

NOAEC/LOAEC for Growth

1-in-10 year 60-day average

concentration 

Freshwater Invertebrate

Survival

48-hr EC50 based on mortality

(immobility) for most sensitive

species tested

1-in-10 year peak concentration

Freshwater Invertebrate

Reproduction and/or Survival

Invertebrate Life Cycle NOAEC

for growth or reproductive

effect

1-in-10 year 21-day average

concentration

Marine/Estuarine Fish Survival 96-hr LC50 for most sensitive

species tested

1-in-10 year peak concentration

Marine/Estuarine Fish

Reproduction and/or Survival

Estuarine/Marine Fish NOAEC

for growth

1-in-10 year 60-day average

concentration

Marine/Estuarine Invertebrate

Survival

48-hr EC50 based on mortality

(immobility) for most sensitive

species tested

1-in-10 year peak concentration

Marine/Estuarine Invertebrate

Reproduction and/or Survival

Estuarine/Marine Invertebrate

NOAEC for reproduction for

most sensitive species

1-in-10 year 21-day average

concentration

Aquatic Vascular and Nonvascular Plant Survival and

Growth

Tier I, Tier II plant toxicity

estimates; EC25

1-in-10 year peak concentration

2.5.2.3 Measures of Ecosystem and Receptor Characteristics

The changes in ecosystems and free-ranging receptors in response to proposed uses of dodine are not

explicitly quantified in this assessment. It would be nearly impossible to address the myriad of uses,

ecosystems and receptors that may interact as a result of dodine use. Instead, the measures of exposure

and measures of effect are used to generate estimates of risk that can be applied to a wide variety of

receptor/ecosystem combinations that are represented by the specified assessment endpoints. 

The assessment endpoints specified in Tables 2.6 and 2.7 can be summarized as survival, growth, and

reproduction of terrestrial and aquatic receptors to include birds, mammals, reptiles, amphibian, fish,

terrestrial and aquatic invertebrates and terrestrial and aquatic plants. The response of these receptors to

dodine exposure is represented by a small number of toxicity studies on representative or surrogate
Page 26 of 219

species. Hence, there is considerable uncertainty regarding the response of a free-ranging receptor since

data for all species potentially exposed are not available. The lowest available measure of effect for a

given assessment endpoint is used to calculate RQs to accommodate for some of this inherent uncertainty. 

However, the extent to which this is sufficient is unknown. 

3 ANALYSIS

3.1 Use Characterization

Dodine is used as a pre- or post-infection fungicide that is formulated as a flowable liquid concentrate and

wettable powder. Dodine is used to control fungal diseases on apples, cherries, peaches, pears, pecans,

strawberries and walnuts. It is also used to control fungal diseases on ornamentals in Oregon (SLN 24c). 

Dodine may be applied to a number of stages of crop growth including delayed dormant, dormant, foliar,

pre-bloom, early bloom, bloom, petal fall, postharvest, and popcorn (a development stage just before

petals open in peaches only). Mostly, dodine is applied by ground using an air blast sprayer and is

applied in a dilute or concentrate form. Application by aircraft is also permitted. 

Based on current labels and on information provided by the registrant (Dodine and DGH Use Closure

Memo, dated 2/2/05), the maximum single application rates among all uses ranges from 0.34 to 2.6 lbs.

a.i./A and maximum annual application rates range from 2.04 to 13.0 lbs. a.i./A/yr (Table 3.4). Complete

maximum use rates and management practices by crop based on current labels are presented in Table A1

(in Appendix A), compiled by BEAD, for all labels accepted as of 05/03/04. 

Based on information compiled by the National Center for Food and Agricultural Policy (NCFAP) and

reported from the U.S. Geological Survey as part of the National Pesticide Synthesis Project (NPSP,

http://ca.water.usgs.gov/pnsp/), among agricultural crops, dodine is most frequently used on apples, pears,

cherries and pecans. In the benchmark year 1997 (based on crop acreage in 1997 and pesticide use

patterns for the years 1995–1998), the estimated annual agricultural use for these four crops, respectively,

was 45,538 lbs., 41,910 lbs., 29,971 lbs. and 27,233 lbs., accounting for almost all of the agricultural use

of dodine. Approximately 31% and 28% of the estimated national agricultural use of dodine in

benchmark year 1997 was on apples and pears, respectively. Cherries and pecans accounted for 20% and

19%, respectively, and all other crops on which dodine was used each accounted for less than 1.7% of

the national use.

Based on a screening level usage analysis (SLUA; dated 3/31/05) of pesticide usage data for the years

1998–2003, compiled by BEAD, 10,000 - 30,000 lbs. of dodine was applied annually to each pears,

pecans, apples and cherries (Table 3.1). The National Center for Food and Agricultural Policy (NCFAP)

reported a total use of 264,664 lbs. dodine in 1992. In 1997, the NCFAP reported a decrease from the

1992 total use to about 151,538 lbs. 
Page 27 of 219

Table 3.1 Screening-level estimates of agricultural uses of dodine for 1998-2003 (BEAD)

Crop Pounds a.i.

Pecans 30,000

Pears 30,000

Apples 20,000

Cherries 10,000

Peaches 3,000

Strawberries <500

Figure 3.1 shows estimated annual agricultural use of dodine for 1997 (NCFAP/NPSP). Dodine has been

used historically in the Pacific Northwest on apples and pears. Apple use also includes the south east

(North Carolina), the mid-Atlantic (Pennsylvania), north central (Michigan and Ohio) and the north east

(New York and Vermont). Dodine use on cherries is primarily in Michigan with approximately 30,000

lbs. applied in 1997 (NCFAP). In the south east, dodine has been primarily used on pecans (Georgia and

Texas).
Page 28 of 219

Figure 3.1 1997 Estimated annual agricultural use of dodine (NCFAP/NPSP).

 

3.2 Exposure Characterization

3.2.1 Environmental Fate and Transport Characterization

This environmental fate and transport characterization addresses dodine (dodecylguanidine acetate) and

DGH (dodecylguanidine hydrochloride) as a combined data set because these compounds behave the

same under environmental conditions (i.e., in water and moist soil). Both compounds are water soluble

salts of a strong base (dodecylguanidine, CAS No. 112-65-2) that should dissociate to the same degree

under any normal environmental conditions. DGH is miscible in water (MRID 409408-01), whereas the

water solubility of dodine is 630 mg/L (product chemistry data). As strong bases, these compounds will
Page 29 of 219

be completely dissociated in aqueous solutions at normal environmental pHs. At the low concentrations

present in the environment, and in the presence of moisture, both compounds would be present as the

dodecylguanidinium ion and either the acetate or chloride ion. More complete information on the

submitted environmental fate guideline studies can be located in Appendix B. 

Dodine is likely to be immobile in soils, based on Kads values for DGH (Kads = 2202 - 18,019 L/kg, MRID

42148901) and is generally not expected to persist in aerobic soils (half-lives 17.5 - 22.3 d, MRID

43945201). Because of dodine’s high partitioning coefficient, the potential to reach aquatic ecosystems

dissolved in runoff or leachate is limited. Based on a low estimated vapor pressure of 1.5 x 10-7 torr for

dodine (EPI Suite), volatilization is an unlikely route of dissipation. Dodine may, however, be

transported off-site to aquatic ecosystems adsorbed to eroded sediment or via spray drift during aerial,

airblast or ground spray applications. Once in aquatic environments, dodine is resistant to hydrolysis

based on data for DGH (half-lives 576-1198 d, MRID 42242601) and photolysis (half-lives 641-770 d,

MRIDs 42419001, 46438203). In aerobic aquatic environments, dodine is likely to be moderately

persistent to persistent (half-lives 38.9, 59.8, 227 d, MRIDs 46438202, 42327401, 42414601). In

anaerobic aquatic environments, dodine is likely to be very persistent based on data for DGH (half-life

2,492 d, MRIDs 42763100, 42763002). The general fate and physical-chemical property source data

used for dodine aquatic exposure modeling are presented in Table 3.2. 

There were two aerobic aquatic metabolism studies reviewed for this assessment, which showed varying

degrees of degradation with total system half-lives ranging from 38.9-59.8 d in the dodine study (MRID

46438202) and a half-life of 227 d reported in the DGH study (MRIDs 42327401, 42414601). In the

DGH study, less than 10% of the parent was degraded throughout the 30 day study. In the dodine study

at 84 days post-treatment, 14CO2 totaled 72-89% of the applied radioactivity, suggesting significant

degradation. Both studies were scientifically valid and can be used to meet the requirements for an

aerobic aquatic metabolism study. Possible reasons for the observed variability in these two studies could

include varying redox conditions and/or varying microbial activity between the two studies. In the dodine

study in both systems, redox potentials were measured at ca. +80 to ca. +180 mV and ca. -300 to ca. -100

mV for the water layers and sediments, respectively. Redox potentials were not reported in the DGH

study. Microbial activity was not measured in either study, but microbial biomass determined by total

plate count analysis was reported at 1.5 x 105

 and 5.8 x 107 CFU/g at day 0 and day 30, respectively, in

the DGH study. The differing conditions between the two studies that resulted in the varying degrees of

degradation may also occur in the natural environment, therefore, both studies were considered in this

assessment. 

In the field, dodine was almost exclusively confined to the 0-6 inch depth of bareground plots (MRID

44985701). This lack of leaching in the field is supported by a soil adsorption study in the laboratory in

which DGH was immobile in soil (sand, sandy loam, clay loam, and silt loam), regardless of organic

matter content (Kads values of 2,202 to 18,019). With adsorption occurring in the upper layer of soil and

rapid degradation to aerobic soil metabolism, it is unlikely that toxicologically-important concentrations

of dodine will leach to ground water. 

There was no submitted fish bioconcentration (BCF) study. This is a data gap and a source of uncertainty

in this assessment. However, the Hazardous Substances Data Bank (HSDB, 2005) reports an estimated

BCF for dodine of 16 suggesting that the potential for bioaccumulation in aquatic organisms is low.
Page 30 of 219

Major degradates (excluding CO2) were not identified in the available studies. Dodine degradation is

most likely the result of beta-oxidation, whereby two carbons at a time are cleaved from the alkyl chain. 

The ultimate metabolite is CO2. Recovery of 14CO2 from dodine radiolabeled at the guanidine moiety was

approximately 90% in the aerobic soil metabolism study in the laboratory. 

Table 3.2 General fate and physical-chemical property source data used for dodine aquatic exposure modeling.

PARAMETER VALUE SOURCE

Chemical Name Dodine

(dodecylguanidine

acetate)

DGH

(dodecylguanidine

HCl)

–

Molecular Weight 287.44 263.85 –

Water Solubility (25 o

C) 630 mg/L no data product chemistry data

Vapor Pressure (25 o

C) 1.5 x 10-7 torr no data EPI Suite

Hydrolysis Half-life (25 o

C)

pH 5 

pH 7 

pH 9

no data

576 d

914 d

 1198 d

(< 10% in 30 days)

 MRID 42242601

Aqueous Photolysis Half-life 641 d

(<10% in 30 days)

770 d

(<10% in 30 days)

MRID 46438203 (dodine)

MRID 42419001 (DGH)

Soil Photolysis Half-life 239 d no data MRID 46438204

Aerobic Soil Metabolism Half-life 17.5 d (sandy loam),

 22.3 d (sandy loam)

no data MRID 43945201

Anaerobic Soil Metabolism Half-life no data no data –

Aerobic Aquatic Metabolism Halflife38.9 d (loamy sand/sand),

 59.8 d (silt loam)

227 d (sandy loam) 

(<10% in 30 days)

MRID 46438202 (dodine)

MRIDs 42327401, 42414601

(DGH)

Anaerobic Aquatic Metabolism Halflifeno data 2492 d

(~10% in 12 months)

MRIDs 42763100, 42763002 

Soil Partition Coefficient (Kads, L/kg) no data 2202, 6440, 15228,

18019

MRID 42148901
Page 31 of 219

3.2.2 Measures of Aquatic Exposure

The assessment involved Tier II modeling (PRZM/EXAMS) for selected scenarios representing all

proposed dodine uses. Monitoring data were not considered because national-scale monitoring studies

were not identified. For Tier II, two models are used in tandem. The Pesticide Root Zone Model,

(PRZM, Carsel et al., 1997) simulates fate and transport on the agricultural field. The version of PRZM

used was PRZM 3.12 beta dated May 24, 2001. The water body is simulated with Exposure Analysis

Modeling System (EXAMS), version 2.98, dated July 18, 2002 (Burns, 1997). Simulations are run for

multiple (usually 30) years and the reported EECs represent the values that are expected once every ten

years based on the thirty years of daily values generated during the simulation.

For aquatic endpoints, the exposure is estimated for the maximum application pattern to a 10-ha field

bordering a 1-ha pond, 2-m deep (20,000 m3

) with no outlet. Exposure estimates generated using the

standard pond are intended to represent a wide variety of vulnerable water bodies that occur at the top of

watersheds including prairie pot holes, playa lakes, wetlands, vernal pools, man-made and natural ponds,

and intermittent and first-order streams. As a group, there are factors that make these water bodies more

or less vulnerable than the standard surrogate pond. Static water bodies that have larger ratios of drainage

area to water body volume would be expected to have higher peak EECs than the standard pond. These

water bodies will be either smaller in size or have large drainage areas. Smaller water bodies tend to have

limited additional storage capacity and thus tend to overflow and carry pesticide in the discharge whereas

the standard pond has no discharge. As watershed size increases beyond 10-ha, it becomes increasingly

unlikely that the entire watershed is planted with a non-major single crop, which is all treated with the

pesticide. Headwater streams can also have peak concentrations higher than the standard pond, but they

tend to persist for only short periods of time and are then carried downstream.

OPP standard PRZM crop or orchard scenarios, which consist of soils, weather and cropping practices

that are location-specific, are used in the simulations to represent labeled uses of dodine. These scenarios

are developed to represent high-end exposure sites in terms of vulnerability to runoff and erosion and

subsequent off-site transport of pesticide. 

 

3.2.2.1 Aquatic Exposure Modeling

Tier II Estimated Environmental Concentrations (EECs) were estimated using EFED’s aquatic models

PRZM and EXAMS (described in previous section). PRZM is used to simulate pesticide transport as a

result of runoff, erosion and spray drift from a 10-ha agricultural field and EXAMS considers

environmental fate and transport of pesticides in surface water and predicts EECs in a standard pond

(10,000-m2

 pond, 2-m deep), with the assumption that the small field is cropped at 100%. Simulations are

carried out with the linkage program shell, PE4V01.pl (dated 8/13/2003), which incorporates the standard

crop and orchard scenarios developed by EFED. Additional information on these models can be found at:

http://www.epa.gov/oppefed1/models/water/index.htm.

All dodine uses were considered in this assessment (apples, cherries, peaches, pears, pecans, strawberries,

and walnuts; crab apples and ornamentals (SLN OR)). Various scenarios, where available, were

simulated for specific crops to account for different geographical locations and agricultural practices (e.g.,

apples). A summary of the crop scenarios used to estimate dodine concentrations in the aquatic systems
Page 32 of 219

for ecological risk assessment is listed in Table , along with some characterization of why the scenario

was chosen. The maximum application rate was chosen for each crop or group of crops. 

A map showing the county-level dodine usage from the NCFAP (1992) and the locations of the EFED

aquatic scenarios is also included in this assessment (Figure The 1992 NCFAP data were used to

show the overlay with the PRZM scenarios because the spatial data were available in-house while the

1997 data were not at the time that this assessment was written. While these data provide some insight

into the historic use of dodine, dodine use is likely to change with varying resistance of fungi. This point

is illustrated by comparing the 1992 (Figure 3.2) and 1997 (Figure 3.1) NCFAP usage data for dodine. In

1992, there was no reported use of dodine in the state of Texas, whereas in 1997 some counties in Texas

were amongst the highest use areas. Similarly, there are several states for which dodine use was reported

in 1992 but not in 1997 (e.g., FL, AL, MS, CA etc.). Whether these discrepancies reflect changes in

actual dodine use patterns or are an artifact of the sampling/reporting, can not be determined without

more information. This screening-level assessment, however, is designed to be protective at a national

scale of all potential use sites. A map of the potential county-level use sites (i.e., total acreage of crops

with dodine labeled uses) is shown in Figure 4.1 (AgCensus, 2002). 

For this assessment, the apple use was modeled with scenarios in the Willamette Valley of Oregon, south

eastern Pennsylvania, and in western North Carolina; all of these areas are high historic dodine use areas. 

Cherries were modeled in northern Michigan which is a high cherry-producing area as well as a high

dodine use area. The peaches and pecans uses were represented by scenarios in central and southern

Georgia, respectively. The pear and walnut uses were represented by scenarios in the central valley of

California. Although the central valley of California does not appear to be high in historic dodine use, it

is an area of potential use. Additionally, since the pear use pattern is similar to that of apples and the

walnut use pattern is similar to that of pecans, the apple scenarios and the GA pecan scenario can be

viewed as surrogates for the pear and walnut uses as well. The strawberry use was represented by a

scenario in central west Florida, the only currently available EFED strawberry scenario. 

Table 3.3 Summary of crop scenarios used in estimating EECs 

Dodine Uses

(EPA Reg. #)

Crop Scenario MLRA/ Met

Station

Scenario Characterization 

Apple (55260-5);

Crab Apples and

Ornamentals

(OR040025)

OR apple: Marion County,

Cornelius silt loam

MLRA A2; 

W24229

Selected based on geographical location,

agricultural practices, and use patterns. 

Only OR apple was used to represent OR

PA apple SLN for crab apples and ornamentals : Lancaster County,

Elioak silt loam

MLRA 148; 

W14737

NC apple: Henderson County,

Hayesville loam

 MLRA 130; 

W03812

Cherries 

55260-6

MI cherries: Leelanau County,

Kewaunee Silt Loam

MLRA96;

W14850

Selected based on agricultural practices and

label information

Peaches

55260-5

GA peaches: Peach County,

Greenville fine sandy loam

MLRA 133;

W93805

Selected based on agricultural practices and

label information
Table 3.3 Summary of crop scenarios used in estimating EECs 

Dodine Uses

(EPA Reg. #)

Crop Scenario MLRA/ Met

Station

Scenario Characterization 

Page 33 of 219

Pears 

55260-5

CA fruit: Central Valley,

Exeter fine sandy loam

MLRA 17; 

W93193

CA fruit scenario represents all non-citrus

fruit grown in Central Valley CA. Selected

based on label information

Pecans

55260-5

GA pecan: Mitchell and Dougherty

Counties, Greenville Fine Sandy

Loam

MLRA 133A;

W93805 

Selected based on agricultural practices and

label information

Strawberries

55260-5

FL strawberry: Hillsborough

County, Myakka sand

MLRA U-154;

W12842

Selected based on agricultural practices and

label information

Walnuts

55260-5

CA almond: San Joaquin County, 

Manteca fine sandy loam

MLRA-17;

W23232 

CA almond scenario represents almond or

walnut production. Selected based on label

information
Page 34 of 219

Figure 3.2 1992 NCFAP county-level dodine usage (lbs./mi2) relative to PRZM scenarios used in

estimating exposure concentrations.

PRZM/EXAMS modeling of dodine was done for the nine scenarios identified in Table 3.3 using the

current maximum label rate, maximum number of applications per year and the minimum application

interval of all the dodine uses represented by each scenario. The maximum number of applications per

year and the minimum application interval were derived from the Dodine and DGH Use Closure Memo

(dated 2/2/05), since these parameters are currently not specified on product labels. This assessment is

contingent on these application restrictions being incorporated on product labels. Where applicable,

modeling input parameters were selected according to current guidance (Guidance for Selecting Input

Parameters in Modeling the Environmental Fate and Transport of Pesticides Version II, EFED, February

28, 2002). Application-specific and chemical-specific input parameters for PRZM/EXAMS modeling are

listed in Table 3.4 and Table 3.5, respectively. All scenarios were simulated with aerial or ground spray

applications (PRZM chemical application method, CAM = 2), and corresponding application efficiency

and drift fractions equal to 0.95 and 0.05 respectively for air spray or 0.99 and 0.01 for ground spray. 

The condition for disposition of the pesticide remaining on foliage after harvest (PRZM variable

IPSCND) was set to 1 (pesticide remaining on foliage is converted to surface application) for all uses

consistent with deciduous orchards and strawberry cropping practices. Application dates were chosen

based on the label information of the crop-stage to which dodine is applied, as well as on reported

planting dates found in the documentation section of each crop scenario.
Page 35 of 219

A soil partitioning coefficient (Kads) for DGH of 10427 L/kg, the mean of four soils, was used. The 90% 

upper confidence bound on the mean was used for the aerobic soil and aerobic aquatic metabolism halflives (27.3 and 333 days, respectively). Since there was only one study for the anaerobic aquatic

metabolism on DGH, three times the half-life was used to account for variability in the environment

(7476 days). The maximum aqueous photolysis half-life, 770 days for DGH, was used and a hydrolysis

half-life of 914 days also for DGH was used since the ecological water body is a constant pH 7. 
Page 36 of 219

Table 3.4 PRZM/EXAMS application-specific input parameters.

Dodine Use(s)(EPA Reg. #)

PRZMscenarios

Maximumsingle app. rate(lbs a.i./A)

No. of app. per year/interval (d)1

 App. method drift/ app.efficiency

Application timing2 

Apples (55260-5);Crab apples andornamentals(OR040025)

NC appleOR applePA apple

1.95 6/5 aerial spray

0.05/ 0.95

Pre-bloom (scab) 

Cherries(55260-6)

MI cherries 1.3 6/7 aerial spray

0.05/ 0.95

Petal fall (leaf spot) 

Peaches(55260-5)

GA peaches 2.6 5/7 aerial spray

0.05/ 0.95

Shuck-split (bacterialspot)

Pears (55260-5)

CA fruit 1.95 6/5 aerial spray

0.05/ 0.95

Pre-bloom (scab) 

Pecans(55260-5)

GA pecans 2.6 5/10 aerial spray

0.05/ 0.95

First leaves (scab) 

Strawberries(55260-5)

FL strawberries 1.3 5/7 ground spray

0.01/ 0.99

New growth (leafscorch) 

Walnuts(55260-5)

CA almond(walnuts)

2.6 5/10 aerial spray

0.05/ 0.95

First leaves (leafblight)

1 Maximum number of applications per year and application intervals are currently not specified on product labels. The number of applications and i

and DGH Use Closure Memo (dated 2/2/05).2 Application timing information from product labels.
Page 37 of 219

Table 3.5 PRZM/EXAMS chemical-specific inputs for all scenarios

Parameter Value Source Comment

Soil Partition Coefficient (Kd L/kg) 10427 MRID 42148901 average of four values

(2202, 6440, 15228,

18019)

Aerobic Soil Metabolism Half-life

(days)

27.3 MRID 434945201 90% upper confidence

bound on the mean of

two half-life values (17.5,

22.3)

Molecular Weight (g/mol) 287.4

Vapor Pressure (torr) 1.5 x 10-7 EPI Suite

Henry’s Law Constant (atm-m3

-

mol)

9 x 10-11 calculated

Solubility in Water at 25o

C (ppm) 6300 10x the water solubility 

Aerobic Aquatic Metabolism Halflife (days)333 MRIDs 46438202,

42327401, 42414601

90% upper confidence

bound on the mean of

three half-life values

(38.9, 59.8, 227)

Anaerobic Aquatic Metabolism

Half-life (days)

7476 MRIDs 42763100,

42763002

3x the anaerobic aquatic

metabolism half-life

(2492)

Hydrolysis Half-life @ pH 7 (days) 914 MRID 42242601 pond scenario pH 7

Aquatic Photolysis Half-life (days) 770 MRID 42419001 maximum value reported

Foliar Extraction 0.5 default

Foliar Decay Rate 0 default stable with respect to

foliar degradation

Simulated EECs for all scenarios are presented in Table 3.6. Copies of the input and output files are in

Appendix C. Acute EECs range from 0.80 - 43 μg/L, 21-day chronic EECs range from 0.28 - 8.7 μg/L 

and 60-day average EECs range from 0.26 - 7.8 μg/L.
Page 38 of 219

Table 3.6 Estimated aquatic exposure concentrations calculated with PRZM/EXAMS.

Dodine uses

(EPA Reg. #)

Scenario Yearly Max.

App. Rate 

(lbs. a.i./A)

1-in-10

Year

Acute 

(μg/L)

1-in-10 Year

21-day

Chronic

(μg/L)

1-in-10 Year

60-day

Chronic

(μg/L)

Apples (55260-5); 

Crab apple,

Ornamentals 

(OR040025)

NC apple 11.7 7.5 3.1 2.8

OR apple 11.7 6.4 2.7 2.4

PA apple 11.7 43 8.7 7.8

Cherries (55260-6) MI cherries 7.8 24 4.5 4.0

Peaches (55260-5) GA peaches 13.0 16 3.2 2.9

Pears (55260-5) CA fruit1 11.7 6.0 2.4 2.1

Pecans (55260-5) GA pecans 13.0 19 4.8 4.6

Strawberries

(55260-5)

FL

strawberry

6.5 0.80 0.28 0.26

Walnuts (55260-5) CA almond1

(walnut)

13.0 7.8 2.6 2.4

1 Scenario simulated without irrigation because of a known error in irrigation algorithms in PRZM 3.12 beta

The highest acute EECs predicted are for the PA apple scenario followed by the MI cherries scenario with

EECs of 43 and 24 μg/L, respectively. Even though the highest annual application rates were for GA

peaches, GA pecans and CA almond at 13.0 lbs a.i./A, these did not produce the highest EECs. The

average runoff and erosion and the loading of dodine in runoff, erosion and spray drift predicted by

PRZM for each scenario are shown in Table 3.7. The sum of the sediment loss, runoff and pesticide

loading associated with these two compartments over the entire simulation was divided by the number of

years in the simulation to obtain average yearly fluxes. For spray drift, the exact yearly loading was

calculated from the application rate, number of applications and the inputted fraction of drift (0.05 and

0.01 for aerial and ground spray, respectively). In all simulations, erosion was the dominant route of

dodine loading to the pond relative to runoff, accounting for as much as 99.9% of the average yearly

loading to the pond for PA apple and MI cherries. Both of these scenarios resulted in the highest EECs

and are characterized by the highest average yearly erosion fluxes, 56 and 27 ton ha-1 yr-1. Spray drift was

the dominant route of dodine loading to the pond in one case accounting for 74.7% of the average yearly

loading for CA fruit, a scenario characterized by both low runoff and low erosion. Even though spray

drift was only the dominant route of off-site transport for this one scenario and the resulting EECs are

among the lowest, there is a possibility that the exposure due to spray drift alone could result in

exceedances of aquatic levels of concern. This possibility is further explored in section 4.2.1 in the Risk

Description.
Page 39 of 219

Table 3.7. Relative contribution of erosion, runoff and spray drift to PRZM-simulated loading to pond

Average

Erosion

Average

Runoff

Average Dodine Loading to Pond

Erosion Runoff Drift

Scenario ton ha-1 yr-1 m3

 ha-1 yr-1 kg a.i. ha-1 yr-1

(% of total)

NC apple 3.1 1589 279

(99.3)

1.2

(0.4)

0.66

(0.2)

OR apple 0.92 756 23

(96.6)

0.13

(0.6)

0.66

(2.8)

PA apple 56 1152 1750

(99.9)

1.0

(0.1)

0.66

(0.0)

MI cherries 27 568 778

(99.9)

0.39

(0.1)

0.44

(0.1)

GA peaches 2.6 677 219

(99.4)

0.69

(0.3)

0.73

(0.3)

CA fruit1 0.002 123 0.18

(20.5)

0.04

(4.8)

0.66

(74.7)

GA pecans 11 3363 837

(99.5)

3.1

(0.4)

0.73

(0.1)

FL strawberry 0.58 5527 14

(87.6)

1.9

(11.9)

0.07

(0.5)

CA almond1

(walnut)

0.07 359 8.2

(89.4)

0.24

(2.6)

0.73

(7.9)

1 Scenario simulated without irrigation because of a known error in irrigation algorithms in PRZM 3.12 beta

The ecological pond modeled with EXAMS is a static water body of fixed volume with no outlet. Since

dodine was assumed relatively persistent in aquatic environments with inputted aquatic dissipation halflives ranging from 333 to 7476 d (see Table 3.5) and since the ecological pond has not outlet, there was

an accumulation of dodine in the pond throughout the 30 year simulations. This was the case for all

modeled scenarios and was verified by graphing daily concentrations over time (data not shown). 

Exposure endpoints, in this assessment, are based on yearly peak concentrations. For scenarios where

spray drift was a main route of off-site transport, predicted yearly peak concentrations increased over time

with the simulation (e.g., CA fruit; see Appendix C). This is because spray drift is assumed constant for

every application throughout the simulation (i.e., 1 and 5% for ground and aerial applications,

respectively) and the yearly loading is, therefore, constant throughout the simulation. In these cases, a 1-

in-10 year EEC does not reflect varying meteorological conditions that are expected once every 10 years,

since the yearly peaks are not independent but are actually correlated to the previous year’s peak

concentration. For scenarios where erosion was the main route of off-site transport, predicted yearly peak
Page 40 of 219

concentrations are more variable and do not increase over time throughout the simulation (e.g., PA apple;

see Appendix C). This is because erosion loadings are variable rather than constant throughout the

simulation and the loading events are dependent on meteorological conditions relative to applications. 

There is a known error in the irrigation algorithms in PRZM 3.12 beta and, therefore, scenarios that are

historically simulated with irrigation were simulated in a no-irrigation mode in this assessment. There is

also a known compatibility error in the formatting of PRZM Record 9c (soil loss cover management

factors -USLEC) in EFED standard scenarios with PRZM 3.12 beta. Record 9 in the EFED scenarios is

formatted according to a calendar-year starting on January 1st and PRZM 3.12 beta expects the format to

be according to a crop-year starting with emergence of the crop. This discrepancy may be important for

compounds like dodine, for which erosion is a dominant route of off-site transport. 

There is an interim version of PRZM, PRZM 9 dated 11/10/04, that has corrected irrigation routines and

also corrects the formatting inconsistency in the Record 9. This version was used to characterize the

effect of the known errors described above. Using PRZM 9 to simulate irrigation for CA fruit and CA

almond resulted in EECs that are not significantly different than those estimated in the no-irrigation

mode; in fact, the EECs were the same to two significant figures for both CA fruit and CA almond. Using

PRZM 9 to correct the formatting inconsistency with Record 9c for the PA apple scenarios resulted in

EECs that are slightly higher than those estimated with PRZM 3.12 beta. The acute, 21-day chronic and

60-day chronic EECs for PA apple simulated with PRZM 9 were 45, 9.1 and 8.2 ppb, respectively. These

EECs are less than 5% higher than those predicted with PRZM 3.12 beta, which is well within the

uncertainty of the model (Table 3.6).

3.2.2.2 Aquatic Exposure Monitoring and Field Data

No identifiable national scale monitoring studies for dodine were available for the assessment.

3.2.3 Measures of Terrestrial Exposure

The measures of exposure for terrestrial receptors in Agency ecological risk assessments can be obtained

from monitoring data, field studies, GIS analysis, and exposure modeling. Exposure modeling was used

to generate measures of exposure for terrestrial organisms that may come in contact with areas where

dodine may be used. GIS analyses of crops for which dodine can be used were done to provide a

perspective on the national use of dodine. In some refinements, GIS analyses can be used to evaluate the

likelihood of species specific exposure but these analyses were not conducted in this assessment. Other

data sources including monitoring efforts and field studies were not used to estimate dodine exposures

because this information was not readily available. 

This assessment focuses on the dietary route of exposure for terrestrial birds, mammals, and invertebrates

as a result of spray applications of dodine. Even though other routes of exposure, primarily dermal,

inhalation, and incidental soil ingestion, may contribute to overall exposure for a given receptor,

frequently there is insufficient information available to generate reasonable estimates of these exposure

routes. Moreover, studies on the dermal or inhalation toxicity of a chemical may not exist, further

inhibiting accurate estimates of risk as a function of these exposure routes. However, when pesticides are

applied as a granular formulation, the exposure estimate is assumed to account for all methods of
Page 41 of 219

exposure. For dodine, there are no proposed uses for granular formulations; models were used to estimate

dietary exposures resulting from spray applications only. 

 

Exposure of free-ranging receptors is a function of the timing and extent of pesticide application with

respect to the location and behavior of identified receptors. EFED’s terrestrial exposure model generates

exposure estimates assuming that the receptor is present on the use site at the time that pesticide levels are

their highest. The maximum pesticide residue concentration on food items is calculated from both initial

applications and any additional applications taking into account pesticide degradation between

applications. Although this is a conservative approach, it is not outside the realm of possibility,

particularly when evaluating acute risks. Longer term exposure estimates used in generating chronic risk

estimates also assume that a receptor is present when pesticide residue levels are highest, and furthermore

assume the receptor uses the site to forage on a repeated basis although the exact frequency and duration

of foraging events on the use site is not specified. 

The duration of the exposure for estimates of acute risks is a single day and occurs when pesticide

residues on food items are highest. The acute exposure level is the quantity of residues consumed in a

single day associated with food requirements for that day.

The current approach to screening-level terrestrial exposure estimation does not directly relate the timing

of exposure to critical or sensitive population, community, or ecosystem processes. Given that for

dodine, application timing and location are crop dependent, it is difficult to address the temporal and

spatial co-occurrence of dodine use and sensitive ecological processes. However, it is worth noting that

pesticides are frequently used from spring through fall, which are times of active migrating, feeding, and

reproduction for many wildlife species. The increased energy demands associated with these activities

(as opposed to hibernation, for example) can increase the potential for exposure to pesticide contaminated

food items since agricultural areas can represent a concentrated source of relatively easily obtained, highenergy food items. In this assessment, the spatial extent of exposure for terrestrial animal species is

limited to the use area only. The majority of applied dodine will likely be limited to the use area although

some spray drift is possible, particularly for air blast applications. 

3.2.3.1 Terrestrial Exposure Modeling

3.2.3.1.1 Birds and Mammals

Estimated exposure concentrations for terrestrial receptors were determined using the standard screeninglevel exposure model, TREX (v.1.1) . Maximum exposure levels were calculated for

spray applications of dodine using maximum proposed application rates, maximum number of
Page 42 of 219

applications, and minimum application intervals for all proposed uses (Table 3.8). These exposure

estimates are based on a database of pesticide residues on wildlife food sources associated with a

specified application rate. Essentially, for a single application, there is a linear relationship between the

amount of pesticide applied and the amount of pesticide residue present on a given food item. These

relationships for the various food items are determined from the Kenaga nomogram as modified by

Fletcher (Hoerger and Kenaga, 1972; Fletcher et al., 1994). TREX (v.1.1) is a simulation model that, in

addition to incorporating the nomogram relationship, also includes pesticide degradation in the estimation

of EECs. 

TREX calculates pesticide residues on each type of food item on a daily interval for one year. A first

order decay function is used to calculate the residue concentration at each day based on the concentrations

present from both the initial and additional applications. The first-order rate equation is:

Ct = Cie-kt

Where Ct is concentration at time t (days; t= 0 initially), Ci is initial concentration after application, k is

the foliar dissipation half-life, and t is time in days. The initial concentration, Ci

, is determined by

multiplying the application rate by a constant specific to a food item. For 1.0 lb a.i. of pesticide per acre

the upper-bound, food item concentration (ppm) is: 240 for short grass, 110 for tall grass, 135 for

broadleaf plants and small insects, and 15 for fruits, pods, and large insects. In many cases, an

empirically determined foliar dissipation half-life value is not available, in which case the default value of

35 days is used (Willis and McDowell, 1987). The food item concentration on any given day is the sum

of all concentrations up to that day taking into account the first-order degradation. The initial application

is on day 0 (t = 0) and runs for 365 days. Over the 365 day run, the highest residue concentration is used

in calculations of the RQ. 

Importantly, TREX considers exposure only in the area where dodine is applied. The underlying

assumption is that most, if not all, of the applied pesticide will settle in the use area. However, depending

on weather conditions and type of application, spray drift of pesticides may occur, increasing the

likelihood of wildlife exposure outside the use area. Since dodine is applied via spray methods, spray

drift in some cases is likely. Particularly for air blast applications, spray drift could be significant. 

Table 3.8 Estimates of foliar residues of dodine for proposed uses

Crop

Application Rate lbs.

a.i./A

(# apps / interval, days) Food Items

Maximum EEC

(mg/kg)1

Apples, Pears

1.95

(6 / 5)

Short grass 2224

Tall grass 1019

Broadleaf plants/small insects 1251
Table 3.8 Estimates of foliar residues of dodine for proposed uses

Crop

Application Rate lbs.

a.i./A

(# apps / interval, days) Food Items

Maximum EEC

(mg/kg)1

Page 43 of 219

Fruits, pods, seeds, and large insects 139

Cherries

1.3

(6 / 7)

Short grass 1361

Tall grass 624

Broadleaf plants/small insects 766

Fruits, pods, seeds, and large insects 85

Crab Apples (OR

only)

0.34

(6 / 5)

Short grass 388

Tall grass 178

Broadleaf plants/small insects 218

Fruits, pods, seeds, and large insects 24

Ornamental Shade

Trees (OR only)

0.85

(6 / 10)

Short grass 789

Tall grass 362

Broadleaf plants/small insects 444

Fruits, pods, seeds, and large insects 49

Peaches

2.6

(5 / 7)

Short grass 2410

Tall grass 1105

Broadleaf plants/small insects 1356

Fruits, pods, seeds, and large insects 151

Pecans, Walnuts

2.6

(5/ 10)

Short grass 2183

Tall grass 1000

Broadleaf plants/small insects 1228

Fruits, pods, seeds, and large insects 136

Strawberries

1.3

(5 / 7)

Short grass 1205

Tall grass 552

Broadleaf plants/small insects 678

Fruits, pods, seeds, and large insects 75

1

Predicted maximum residues for specified application rates are based on Hoerger and Kenaga (1972) as modified by Fletcher et al. (1994).
Page 44 of 219

3.2.3.1.2 Terrestrial Plants

Dodine exposure to terrestrial plants was estimated using OPP’s Terr Plant(v 1.0) model. The model

produces EECs for plants residing near a use area that may be exposed to pesticides via runoff and/or

spray drift. The EECs apply to plants that inhabit both dry and semi-aquatic (wetland) habitats. The

EECs are generated from one application at the maximum rate for a particular use and compound-specific

solubility information. The EECs for terrestrial plants for a single application of dodine at the maximum

label rate for different crops are presented in Table 3.9.

Table 3.9. EECs for Terrestrial Plants Near Dodine Use Areas

Application Rate, lbs a.i./A

(crop)

EECs (lbs. a.i./A)

Total Loading to Adjacent

Areas (sheet runoff + drift)

Total Loading to SemiAquatic Areas (channelized

runoff + drift)

Drift EEC

2.6

(peaches, pecans, walnuts)

0.208 0.910 0.130

1.95

(apples, pears)

0.156 0.683 0.096

1.3

(cherries, strawberries)

0.104 0.096 0.065

3.2.3.2 Residue Studies

Environmental residue studies can also provide useful information regarding the potential exposure of

terrestrial wildlife receptors. These data can be used to corroborate modeling results or to provide

additional insights into chemical fate with respect to exposure. For dodine, no studies are available; all

estimates of exposure are based on modeling efforts. 

3.3 Ecological Effects Characterization

The ecological effects characterization for dodine is based primarily on registrant-submitted toxicity

studies. Toxicity data from both dodine and DGH were considered for aquatic species only since these

compounds behave similarly in water; both dissociate to form the dodecylguanidinium ion. Importantly,

the DGH studies incorporated the use of formulated product for exposures. Review of the formulated

product ingredients indicate that the active ingredient, dodecylguanidine hydrochloride is the only

ingredient expected to result in toxic effects. A summary of acute and chronic toxicity data for dodine

and DGH used to calculate RQs is provided here and in Tables 3.10, 3.11 and 3.12. Additional

summaries of laboratory toxicity data can be found in Appendix D. All registrant-submitted studies

provided useful information for this assessment.

Dodine is practically non-toxic to honeybees, birds, and mammals on an acute exposure basis. However,

dodine is moderately to very highly toxic to aquatic non-vascular plants, freshwater aquatic invertebrates,
Page 45 of 219

freshwater fish, estuarine/marine invertebrates, molluscs, and estuarine/marine fish on an acute exposure

basis. Also, dodine is somewhat toxic to birds, mammals and freshwater aquatic invertebrates under

longer-term, chronic exposures. Importantly, results from dodine toxicity tests do not likely capture

dodine toxicity to all species of birds, mammals, or aquatic organisms. Typically, only a few surrogate

species are used to represent all freshwater fish, birds, mammals, invertebrates, and plants. For reptiles

and amphibians there are no currently required toxicity tests; birds and fish are used as surrogates for

these taxa. The representation of numerous species by a few commonly used laboratory species is a

source of uncertainty. 

In addition to the data submitted in support of registration and the information compiled through the

Agency pesticide review process, the ECOTOX (ECOTOXicity) database was used to identify additional

toxicity data from the open literature. The ECOTOX database is a user-friendly, publicly-available,

quality-assured, comprehensive tool for locating toxicity data from the open literature and is maintained

by EPA Mid-Atlantic Ecology Division. More information on ECOTOX can be found at:

http://www.epa.gov/ecotox. Research papers are thoroughly screened using standard procedures before

being accepted into ECOTOX thereby ensuring consistent, high quality information. For dodine, no

studies were identified in ECOTOX that were suitable for use in this assessment (Appendix E).

3.3.1 Aquatic Effects Characterization

3.3.1.1 Aquatic Animals

3.3.1.1.1 Freshwater Fish

Acute toxicity studies using both bluegill sunfish (Lepomis macrochirus) and rainbow trout

(Oncorhynchus mykiss) indicated that dodine is to freshwater fish on an acute exposure basis. 

Of the two species, the rainbow trout is slightly more sensitive with an LC50 of 570 ppb (430-750 ppb)

compared to the blue gill sunfish Both studies were classified as

ACCEPTABLE (formerly CORE) despite the fact that no controls were reported; it was stated in the

report that the study was conducted generally in accordance with the EPA Fish-Pesticide Acute Toxicity

Test guidelines and also in accordance with the Fish Bioassay Procedure in the 1970 edition of the

Standard Methods (APHA) except as noted in the report. The report did not mention exclusion of

controls indicating that controls were included in the study. No other freshwater fish acute toxicity

studies for dodine are available for review.

A freshwater fish early life-stage chronic toxicity test on fathead minnows (Pimephales promelas) was

used to evaluate the chronic toxicity of dodine. Results from the study indicated a No Observed Adverse

Effect Level (NOAEL) of 99 ppb and an associated Lowest Observed Adverse Effect Level (LOAEL) of

200 ppb. The basis of these effect levels was an observed decrease in both larval weight and larval length

of dodine-exposed fish (Sousa, 1995). No other early life-stage toxicity studies or full life-cycle toxicity

studies for freshwater fish were available for review. 
Page 46 of 219

3.3.1.1.2 Freshwater Invertebrates

Three freshwater invertebrate acute toxicity studies indicated that dodine is very highly toxic to

waterfleas (Daphnia magna). The lowest estimated 48 hour-EC50 was 17.8 ppb (14.8-22.3 ppb) and was

based on immobilization of waterfleas. This study is classified as ACCEPTABLE.

An aquatic invertebrate life cycle test was conducted to evaluate the chronic toxicity of dodine to the

freshwater aquatic invertebrate, Daphnia magna. There were significant effects of dodine on survival of

first-generation daphnids, number of young produced, dry weight of first-generation daphnids, and length

of first-generation daphnids. The most sensitive endpoint was the number of young produced with a

NOAEC of 7.3 ppb and a LOAEC of 13 ppb. 

3.3.1.1.3 Estuarine/Marine Fish

Results from a DGH study on sheepshead minnows, Cyprinodon variegatus, were used in this risk

assessment since the LC50 for the DGH study was lower than that of a comparable study on dodine (See

Appendix D). Sheepshead minnows were exposed to DGH under flow-through conditions for 96 hours to

generate an estimate of the acute toxicity to an estuarine/marine fish. The LC50 was 1782 ppb. The LC50

classifies dodine as moderately toxic to estuarine/ marine fish. The study was conducted in a

scientifically sound manner and meets the requirements for an estuarine/marine fish acute flow-through

toxicity study. 

No tests of the chronic toxicity of dodine to estuarine/marine fish were available for this assessment. 

3.3.1.1.4 Estuarine/Marine Invertebrates

The acute toxicity value for estuarine/marine invertebrates used in this assessment is based on a DGH

study. Although a study on estuarine/marine invertebrates was available for dodine, the dodine study

indicated a lack of toxicity to mysid shrimp, Americamysis bahia, (LC50 = 2335 ppb) whereas the DGH

toxicity study showed that DGH was highly toxic to mysid shrimp on an acute exposure basis. For the

study with DGH, the 96-hour LC50 was 59.4 ppb a.i. and the NOAEC was < 46.2 ppb a.i. and the LOAEC

was 46.2 ppb a.i. (lowest concentration tested). Similar to the results from the study on mysid shrimp, a

96-hour shell deposition study on eastern oysters (Crassostrea virginica) indicated that DGH was highly

toxic to this mollusc species. There were significant, concentration-dependent effects of dodine on shell

deposition. However, a NOAEC could not be determined since oysters at the lowest test concentration

showed significantly reduced shell deposition. The 96-hour EC50 was 69.3 ppb (95% C.I. = 52.8 and 99

ppb) with a corresponding LOAEC of 9.9 ppb. The study was considered scientifically sound and meets

the guideline requirements for a 96-hour flow-through mollusc shell deposition acute toxicity test. 

The large difference in mysid shrimp LC50s for DGH and dodine is somewhat surprising. Review of the

DGH formulation ingredients used in the mysid study indicated that toxicity was likely the result of

exposure to the active ingredient only. The next most abundant chemical in the formulation (17.5% by

weight) has an estimated LC50 in brown shrimp of 1150 ppm suggesting that it is not a likely contributor

to the lower LC50 associated with DGH. Further, review of both the dodine and DGH studies did not
Page 47 of 219

reveal any obvious explanation for the difference in acute toxicity. Indeed, DGH and dodine are expected

to behave similarly in aquatic environments. If this were true, results from toxicity tests on aquatic

species would likely show similar results with one chemical more or less sensitive than the other in

random fashion. Examination of the data, however, indicate that for saltwater species, DGH appears to be

more toxic. Further analysis or research may be required to characterize the relative toxicity of DGH and

dodine to aquatic species. Again, for purposes of this assessment, it is assumed that DGH and dodine

behave similarly in aquatic environments and therefore, the lowest toxicity value is used in calculating

RQs. Discussion of both the DGH and the dodine studies is found in Appendix D. 

There were no chronic estuarine/marine invertebrate toxicity data available for this assessment.

Table 3.10. Summary of Acute and Chronic Aquatic Toxicity Data for Dodine and DGH

Species

Acute Toxicity Chronic Toxicity

96-hr LC50

(μg a.i./L)

48-hr EC50

(μg a.i./L)

Acute Toxicity

(MRID)

NOAEC / LOAEC

(μg a.i./L)

Affected Endpoints

(MRID)

Rainbow trout

Oncorhynchus mykiss

(TGAI)

570 –(a) Highly toxic

(Acc.# 132149) -- --

Fathead Minnow

Pimephales promelas

(TGAI)

-- -- -- 99/ 200

Larval length and

weight

(438765-02)

Water flea

Daphnia magna

(TGAI)

-- 17.8 Very highly toxic

(423396-01)

7.3/13

Number young

produced

(438765-01)

Sheepshead minnow

Cyprinodon variegatus

1782(b) -- Moderately toxic

(434855-06) -- --

Eastern oyster

Crassostrea virginica

69.3(b) -- Highly toxic

(434855-08) -- --

Mysid shrimp

Americamysis bahia

59.4(b) -- Highly toxic

(434855-07) -- --

(a)Indicates toxicity value not available

(b)Based on a DGH study

3.3.1.1.5 Aquatic Plants

Aquatic plant toxicity testing indicated that the nonvascular plant, Selenastrum capricornutum (green

algae), is particularly sensitive to dodine at the concentrations tested. The estimated 120-hour EC50 was

0.95 and based on cell density effects. The corresponding 120-hour NOAEC for this effect was

0.082 ppb. Based on these results, dodine is classified as very highly toxic to green algae. A complete

evaluation of the toxicity of a compound to aquatic plants requires at least one study on aquatic vascular

plants. This study was not available for dodine. 
Page 48 of 219

Table 3.11 Summary of Aquatic Plant Toxicity Data for Dodine.

Species/ static or

static renewal % ai

NOAEC/ 

EC50 (μg a.i./L)

(measured)

MRID No.

Green algae

Selenastrum capricornutum (120-hour)/ Static 94.1 Technical /0.95 426951-01

3.3.1.2 Terrestrial Animals

3.3.1.2.1 Birds

Two studies on the acute toxicity of dodine to birds were available for review. The studies indicated that

dodine is practically non-toxic to mallard ducks, Anas platyrhynchos, and slightly toxic to bobwhite quail,

Colinus virginianus, on an acute exposure basis (See Appendix D). Since bobwhite quail showed more

sensitivity to dodine, results from that study were used for this assessment. The bobwhite quail LD50 was

690 mg a.i./kg body weight. In addition to mortality, observed sublethal effects included ruffled feathers

and depression. Subacute dietary exposures of the same species indicated that dodine was practically

non-toxic to both species with LC50s of 8413 ppm and >10000 ppm for bobwhite quail and mallard ducks,

respectively. In the subacute bobwhite quail study, other toxic signs included depression, reduced

reaction to external stimuli, wing droop, and coordination loss. No mortality was seen in the acute dietary

study on mallard ducks. 

Three avian toxicity tests were conducted to evaluate the reproductive toxicity of dodine. Only one was

considered useful for quantitative estimates of avian risks; the other two suffered from design errors

and/or control mortalities (see Appendix D). In the one study classified as ACCEPTABLE, twenty-fourweek old mallard ducks, Anas platyrhynchos, were exposed to dodine in feed at several concentrations. 

There were significant effects of dodine on the number of eggs laid, eggs set, viable embryos, viable 3-

week embryos, hatchlings, 14-day old survivors, adult food consumption, hatchling body weights, and

adult female body weights at diet concentrations > 600 ppm (mg a.i./kg feed). The NOAEC for these

effects was 200 ppm. In a similar study conducted on bobwhite quail (Colinus virginianus), no toxic

effects were observed at any exposure level including the highest exposure level (300 ppm) which was

the reason for the classification of SUPPLEMENTAL. These data indicate that use of the mallard duck

data likely represents the lowest available toxicity estimate. However, it is important to acknowledge that

NOAECs generated from these studies are dependent on chosen exposure levels and estimates of true

NOAECs are difficult to obtain. 

3.3.1.2.2 Mammals

Wild mammal testing is required on a case-by-case basis only, and is dependent on the results of lower

tier laboratory mammalian studies, intended use patterns, and pertinent environmental fate characteristics. 

In most cases, rat or mouse toxicity values obtained from the Agency’s Health Effects Division (HED)

are used as surrogates for wild mammal toxicity testing.
Page 49 of 219

The acute toxicity of dodine was evaluated using the common laboratory rat. The acute toxicity of dodine

differed between male and female rats with females showing greater sensitivity. The LD50s were 1056

and 1698 mg/kg for females and males, respectively, with a combined LD50 of 1379 mg/kg. For this

assessment, the lower female-specific value of 1056 mg/kg was used. 

As with the acute mammalian toxicity data, chronic toxicity data are obtained from the Agency’s HED

and are considered representative of wild mammals. These studies provide adequate toxicity data on the

potential effects of chronic dodine exposure in mammals. Chronic studies in both dogs and rats show that

the endpoint most sensitive to dodine exposure seems to be reduced body weight/growth in adults and/or

offspring. In rats (Rattus norvegicus), the NOAEL was 30.28 mg/kg/day for decreased male pup body

weight, which corresponds to a dietary level of 400 ppm (mg a.i./kg feed). In dogs (Canis familiaris), the

NOAEL was 2.0 mg/kg/day based on decreased food consumption and decreased weight gain in female

dogs that received dodine via capsule. For this assessment, the rat toxicity data were used since these

studies are more commonly encountered and also, the results from the dog study were based on a small

number of experimental animals indicating a less robust experimental design. Growth or body size as a

measure of effect for mammals is used because growth rate or body size can be important for survival and

reproduction of wild mammals. Frequently, a larger size is associated with increased chances of survival

or competitive advantage and growth rate directly influences maturation rate, a strong contributor to

population growth rate in many populations.

3.3.1.2.3 Terrestrial Invertebrates

Acute toxicity of dodine to terrestrial invertebrates was assessed in studies where honey bees (Apis

mellifera) were exposed to dodine via both contact and oral routes. The contact LD50 was more than 200

:g per bee, the highest dose tested. This characterizes dodine as practically non-toxic to honey bees via

contact exposure. In the oral toxicity test, suspensions of dodine in 50% sucrose water were prepared

such that four test concentrations were administered to test bees. Similar to the contact toxicity study,

dodine did not cause significant mortality at the concentrations tested. The resulting LD50 was > 200 :g

per bee. Both the oral and contact studies were conducted in a scientifically sound manner and are

classified as ACCEPTABLE. 
Page 50 of 219

Table 3.12 Summary of Acute and Chronic Toxicity Data for Terrestrial Organisms Exposed to

Dodine.

Species

Acute Toxicity Chronic Toxicity

LD50

(mg/kg)

Acute Oral

Toxicity

(MRID)

8-day LC50

(mg/kg diet)

Subacute Dietary

Toxicity

(MRID)

NOAEC/LOAEC

(mg/kg diet)

(MRID)

Affected

Endpoints

Northern bobwhite quail

Colinus virginianus

690

Slightly toxic

(Acc.#

130888)

8413

Practically nontoxic

(Acc.# 226855)

<75/75

(458197-24)

growth (14-

day survivor

weight);

reproduction

(eggs cracked)

Mallard duck

Anas platyrhynchos

2214

Practically

non-toxic

(Acc.#

131455)

>10000

Practically nontoxic

(Acc.# 226855)

200/600

(432746-02)

multiple

reproductive

Dog

Canis familiaris -- -- -- --

2.0/10.0

Mg/kg/d

(442461-01)

body weight

Laboratory rat

Rattus norvegicus

1056

Practically

non-toxic

(449224-01)

-- -- 30.28 /60.5

(442460-01)

decreased pup

body weights 

Honey bee

Apis meliferus

>200

(μg/bee

contact)

Practically

non-toxic

(4013155-05)

-- -- -- --

(a)Toxicity data unavailable

3.3.1.2.4 Terrestrial Plants

Tier I plant studies were submitted in support of the re-registration of dodine (Table 3.13). Tier I studies

are aimed at quickly evaluating the phytotoxicity of a compound at the maximum single application rate,

which for dodine is 2.6 lbs a.i./A. Tier II plant studies are triggered when effects from the Tier I studies

exceed 25% of control. For dodine, cabbage showed a 25% reduction in plant dry weight compared to

controls. This was the only effect greater than or equal to 25% although several effects were > 20%. No

Tier II plant studies were submitted for review, precluding the calculation of RQs. In cases where no Tier

II plant studies are available for review and at least one plant species shows effects > 25% for Tier I

studies, risks are assumed for terrestrial plants. 
Page 51 of 219

Table 3.13 Tier I Results for the Effects of Dodine on Terrestrial Plants

Crop Study Species % Reduction Compared to Controls

Seedling Emergence Plant Height Plant Dry Weight

Seedling Emergence (MRID# 426951-02)

Monocots Corn 0 1 10

Oats 0 9 0

Onion 15 0 11

Ryegrass 0 5 0

Dicots Radish 0 1 9

Soybean 0 7 11

Lettuce 2.5 17 14

Tomato 6 0 0

Cucumber 0 2 14

Cabbage 3 22 25

Vegetative Vigor (MRID# 426951-03)

Monocots Corn –(a) 0 0

Oats -- 2 0

Onion -- 5 20

Ryegrass -- 0 8

Dicots Radish -- 5 0

Soybean -- 0 3

Lettuce -- 14 0

Tomato -- 1 0

Cucumber -- 4 15

Cabbage -- 12 21

(a)This endpoint not measured

4 RISK CHARACTERIZATION

Risk characterization is the integration of exposure and effects characterization to determine the

ecological risk from the use of dodine and the likelihood of effects on aquatic life, wildlife, and plants

based on varying pesticide-use scenarios. The risk characterization provides an estimation and a
Page 52 of 219

description of the risk; articulates risk assessment assumptions, limitations, and uncertainties; synthesizes

an overall conclusion; and provides the risk managers with information to support regulatory decision

making.

4.1 Risk Estimation - Integration of Exposure and Effects Data

Results of the exposure and toxicity effects data are used to evaluate the likelihood of adverse ecological

effects on non-target species. For the assessment of dodine risks, the risk quotient (RQ) method is used to

compare exposure and toxicity values. Estimated environmental concentrations (EECs) are divided by

acute and chronic toxicity values. The resulting RQs are compared to the Agency’s levels of concern

(LOCs). These LOCs are the Agency’s interpretive policy and are used to analyze potential risk to nontarget organisms and the need to consider regulatory action. These criteria are used to indicate when a

pesticide’s use as directed on the label has the potential to cause adverse effects on non-target organisms. 

A summary of toxicity values used to calculate Rqs is provided in Table 4.1; a more detailed discussion

of dodine toxicity can be found in section 3.3 and Appendix D. 

Table 4.1 Summary of Toxicity Data for Most Sensitive Test Species Used to Calculate Risk

Quotients to Evaluate Ecological Risks of Dodine Use.

Taxonomic

Group

Most Sensitive Species Exposure Category Toxicity Value

Birdsa Bobwhite quail (Colinus

virginianus)

Mallard duck (Anas

platyrhynchos)

Acute (LD50/LC50)

Chronic (NOAEC)

690 mg/kg LD50

8413 mg/kg-feed LC50

200 ppm (feed)

Mammals Laboratory rat (Rattus

norvegicus)

Acute LD50 and

Chronic

NOAEL/NOAEC

1056 mg/kg LD50

30.28 mg/kg (chronic)

400 ppm (chronic diet)

Terrestrial

insects

Honeybees (Apis

mellifera)

Acute Oral LD50 > 200 :g a.i./bee

Freshwater fishb Rainbow trout

(Oncorhynchus mykiss)

Fathead minnow

(Pimephales promelas)

Acute LC50

Chronic NOAEC

570 ppb

99 ppb

Freshwater

invertebrates

Water flea (Daphnia

magna)

Midge (Chironomus

riparius)

Acute LC50 and

 Chronic NOAEC

Chronic NOAEC

(Benthic)

17.8 ppb

7.3 ppb

380 ppb (pore-water)
Table 4.1 Summary of Toxicity Data for Most Sensitive Test Species Used to Calculate Risk

Quotients to Evaluate Ecological Risks of Dodine Use.

Taxonomic

Group

Most Sensitive Species Exposure Category Toxicity Value

Page 53 of 219

Estuarine/marine

fish

Sheepshead minnow

(Cyprinodon variegatus)

Acute LC50 1782 ppb

Estuarine/marine

invertebrates

Mysid shrimp

(Mysidopsis bahia) 

Eastern oyster

(Crassostrea virginica)

Acute LC50

Acute EC50

59.4 ppb

69.3 ppb

Terrestrial plantsc Monocots – corn (Zea

mays)

Dicots – soybean

(Glycine max)

Acute (Tier I, no EC50

estimated)

No EC50 estimate due to lack

of Tier II data - risks

asssumed.

Aquatic plants

and algae

Green algae (Selenastrum

capricornutum)

Acute EC50 0.95 ppb

0.082 ppb (NOAEC)

a

Birds are used as surrogates for terrestrial phase amphibians and reptiles (US EPA, 2004).

b

Freshwater fish are used as surrogates for aquatic phase amphibians (US EPA, 2004).

c

Four species of two families of monocots, of which one is corn; six species of at least four dicot families, of which one is

soybeans.

4.1.1 Non-target Aquatic Animals and Plants

Surface water concentrations resulting from dodine application to agricultural and non-agricultural crops

were predicted with the Tier II models PRZM-EXAMS. Nine scenarios that consisted of aerial or ground

spray applications of dodine, including apples (in North Carolina, Oregon and Pennsylvania), crab apples

(in Oregon), ornamentals (in Oregon), cherries (in Michigan), peaches (in Georgia), pears (in California),

pecans (in Georgia), strawberries (in Florida) and walnuts (in California) were modeled. The crab apple

and ornamental use patterns were modeled with the OR apple scenario as a surrogate. The California fruit

scenario is intended to be representative of pears. The California almond scenario is representative of the

walnut use pattern. 

To determine if spray drift is a major factor in estimating EECs, average yearly loadings of dodine in

runoff, eroded sediment and spray drift were compared. Results, as indicated in Table 3.7, show that

dodine adsorbed to eroded sediment was the dominant route of loading to the pond relative to runoff for

all scenarios. Drift was only the dominant route of off-site transport for one scenario (CA pears) and the

resulting EECs were some of the lowest. 

One-in-10 year peak EECs were compared to acute toxicity endpoints to derive acute RQs and 1-in-10

year 21-day average EECs were compared to chronic toxicity endpoints to derive chronic RQs. Acute

and chronic RQs for freshwater and saltwater organisms are summarized in Table 4.2 and Table 4.3.
Page 54 of 219

Chronic RQ values could not be derived for estuarine/marine fish and invertebrates due to a lack of

toxicity data for these taxa. 

For aquatic non-vascular plants, 1-in-10 year peak EECs were compared to acute EC50 values to derive

acute non-listed species RQs.

 RQs for aquatic

non-vascular plants are summarized in Table 4.2.

4.1.1.1 Freshwater Fish and Invertebrates

Table 4.2 lists the RQs for freshwater fish, aquatic-phase amphibians, and aquatic invertebrates

potentially exposed to dodine. For freshwater fish and aquatic-phase amphibians, the acute RQ value of

0.08 based on aerial application of dodine to Pennsylvania apples (11.7 lb ai/A/yr) exceeds the listed

species acute risk LOC. The acute RQ values associated with all other modeled scenarios are less than

the listed species LOC. For freshwater fish and aquatic-phase amphibians, the chronic RQ values

associated with all modeled scenarios are less than the chronic risk LOC (RQ < 1). 

For freshwater invertebrates, acute RQs for all modeled scenarios, except Florida strawberry, exceed the

acute restricted use and listed species LOCs (RQs = 0.34 - 2.4). In addition, for the current application

rates modeled, the acute risk LOC is exceeded for freshwater invertebrates for aerial applications to

Pennsylvania apples (11.7 lb ai/A/yr; RQ = 2.4), Michigan cherries (7.8 lb ai/A/yr; RQ = 1.4), Georgia

pecans (13.0 lbs. a.i./A/yr; RQ = 1.1), and Georgia peaches (13.0 lbs. a.i./A/yr; RQ = 0.9). For freshwater

invertebrates, the chronic RQ value based on aerial application of dodine to Pennsylvania apples (11.7 lb

ai/A/yr) exceeds the chronic LOC (RQ = 1.2).

In addition to toxicity studies on freshwater fish and invertebrates, a non-guideline 28-day toxicity study

on sediment-water-dwelling larvae of Chironomus riparius was available for review (MRID#464382-01). 

This study showed that there were no significant effects of dodine at any of the concentrations tested. 

The highest pore-water concentration tested was 380 ppb. The 1-in-10 year, 21-day chronic estimated

pore-water concentration from PRZM/EXAMS was 7.3 ppb for the Pennsylvania apples scenario. The

RQ based on these values is 0.02, which does not exceed any LOC. This analysis indicates that risk to

benthic invertebrates is expected to be low. 

4.1.1.2 Estuarine/Marine Fish and Invertebrates

Table 4.3 lists the RQs for estuarine/marine fish and invertebrates potentially exposed to dodine. Acute

RQ values calculated for estuarine/marine fish for all modeled scenarios are less than the listed species

acute risk LOCs (RQs < 0.05). were

exceeded for for all modeled scenarios except Florida strawberry (RQs =

0.10 - 0.72). The acute risk LOC of 0.5 for non-listed invertebrate species was exceeded for Pennsylvania

apples (RQ = 0.72) For molluscs, acute RQs for all modeled scenarios, except Florida strawberry and

California pear exceeded acute restricted use and listed species acute risk LOCs (RQs = 0.11 - 0.62). 

Additionally, the RQ for the Pennsyvannia apple scenario exceeds the acute LOC of 0.5 for molluscs. 

The RQ for the California pear scenario exceeds the listed species acute risk LOC (RQ = 0.09) for
Page 55 of 219

molluscs.

4.1.1.3 Aquatic Plants

Table 4.2 lists the RQs for aquatic, non-vascular plants potentially exposed to dodine. For non-listed

non-vascular plants, acute RQs for all modeled scenarios, except Florida strawberry, exceed the acute risk

LOC (RQs = 6.3 - 45). 
Page 56 of 219

Table 4.2 Risk Quotients for Freshwater Fish, Aquatic Amphibians, Aquatic Invertebrates and

 Non-vascular Plants Exposed to Dodine

Use Application

Rate lbs. a.i./A

(# app/ interval,

days)

EECs

(ppb)

Fish and

Amphibian RQs 

LC50 = 570 ppb

NOAEC = 99 ppb

Invertebrate RQs

EC50 = 17.8 ppb

NOAEC = 7.3 ppb

Non-vascular Plant

RQs

EC50 = 0.95 ppb

NOAEC = 0.082 ppb

Acute 21-day 60-day acute chronic acute chronic acute(1) acute(2)

Apples (PA) 1.95

(6/5)

43 8.7 7.8 0.08* 0.08 2.42*** 1.19 45.26 524

Cherries

(MI)

1.3

(6/7)

24 4.5 4.0 0.04 0.04 1.35*** 0.62 25.26 293

Peaches

(GA)

2.6

(5/7)

16 3.2 2.9 0.03 0.0 0.90*** 0.44 16.84 195

Pears

(CA)

1.95

(6/5)

6.0 2.4 2.1 0.01 0.02 0.34** 0.32 6.31 73

Pecans

(GA)

2.6

(5/10)

19 4.8 4.6 0.03 1.07*** 0.66 20.00 232

Strawberries

(FL)

1.3

(5/7)

0.80 0.28 0.26 0.00 0.04 0.04 0.84 10

Walnuts

(CA)

2.6

(5/10)

7.8 2.6 2.4 0.01 0.44** 0.36 8.21 95

* exceeds LOC for acute risk to listed fish or invertebrate species (RQ $ 0.05)

** exceeds LOCs for acute risk to listed fish or invertebrate species and restricted use (RQ $ 0.1)

*** exceeds LOCs for acute risk, acute risk to listed fish or invertebrate species, and restricted use (RQ $ 0.5)

(1)bolded numbers exceed LOC for acute risk to aquatic plant species (RQ > 1.0, calculated as EC50/acute EEC)

(2)bolded numbers exceed LOC for acute risk to endangered aquatic plant species (RQ > 1.0, calculated as NOAEC/acute EEC)
Page 57 of 219

Table 4.3 Risk Quotients for Saltwater Fish and Invertebrates Exposed to Dodine

Use Application Rate

lbs. a.i./A

(# app/ interval,

days)

EECs

(ppb)

Fish RQs

LD50 = 1782 ppb 

Invertebrate RQs

EC50 = 59.4 ppb

Mollusc RQs

EC50 = 69.3

ppb

Acute 21-day 60-day acute chronic acute chronic acute

Apples

(PA)

1.95

(6/5)

43 8.7 7.8 0.02 NA 0.72*** NA 0.62***

Cherries (MI) 1.3

(6/7)

24 4.5 4.0 0.01 NA 0.40** NA 0.34**

Peaches

(GA)

2.6

(5/7)

16 3.2 2.9 0.01 NA 0.27** NA 0.23**

Pears

(CA)

1.95

(6/5)

6.0 2.4 2.1 0.00 NA 0.10** NA 0.09*

Pecans

(GA)

2.6

(5/10)

19 4.8 4.6 0.01 0.32** 0.27**

Strawberries

(FL)

1.3

(5/7)

0.80 0.28 0.26 0.00 0.00 0.00

Walnuts

(CA)

2.6

(5/10)

7.8 2.6 2.4 0.00 0.13* 0.11**

* exceeds LOC for acute risk to listed species (RQ $ 0.05)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.1)

*** exceeds LOCs for acute risk, acute risk to listed species, and restricted use (RQ $ 0.5)

4.1.2 Non-target Terrestrial Animals

The EEC values for terrestrial exposure for spray applications of dodine were derived from the Kenaga

nomograph, as modified by Fletcher et al. (1994), based on a large set of actual field residue data. EECs

were calculated for all labeled uses (apple, cherries, crab apples, ornamentals, peaches, pears, pecans,

strawberries and walnuts) with application rates ranging from 0.34 to 2.6 lb ai/A. Risk quotients are

based on the most sensitive studies that yielded the lowest toxicity values. For this assessment, the lowest

LC50 and NOAEC values were used for birds and the lowest LD50 and NOAEL were used for mammals

(based on lab rat studies). 

Acute and chronic RQs for birds are presented in Tables 4.4 and 4.5, respectively; acute and chronic RQs

for mammals are summarized in Tables 4.6 and 4.7, respectively.

4.1.2.1 Birds

Table 4.4 summarizes the avian dose-based acute RQs for foliar uses of dodine. Acute, acute restricted

use and/or listed species acute risk LOCs are exceeded for birds that consume short grass, tall grass,

broadleaf plants, and small insects across most weight classes for all modeled scenarios and application
Page 58 of 219

rates, with acute RQs ranging from 0.06 to 5.6. In addition, acute RQ values also exceed acute restricted

use and/or listed species acute risk LOCs for birds that consume fruits, pods, seeds, and large insects at

application rates for all modeled scenarios, except crab apples, at the smallest weight class, and in some

cases at the medium weight class (RQs that represent exceedances = 0.12 - 0.35).

Table 4.5 summarizes the avian dietary-based acute and chronic RQs for foliar uses of dodine. Acute,

acute restricted use and/or listed species LOCs are exceeded for birds that consume short grass, tall grass

(in most cases), broadleaf plants, and small insects based on the dietary-based toxicity endpoint for all

modeled scenarios and application rates, with acute RQs that represent exceedances ranging from 0.10 to

1.1. Importantly, the dietary-based acute RQs are provided for comparison purposes and are not the

primary contributor to conclusions of avian risk since there is less uncertainty with dose-based estimates. 

The avian chronic risk LOCs are exceeded for birds that consume short grass, tall grass (in most cases),

broadleaf plants, and small insects for all modeled scenarios and application rates, with chronic RQs that

represent exceedances ranging from 1.09 to 12. 

Table 4.4 Avian dose-based acute RQ values for proposed uses of dodine based on a bobwhite

quail LD50 = 690 mg/kg-bw and upper-bound Kenaga residues. 

Use Application Rate

lbs. a.i./A

(# app / interval,

days)

Body

Weight, g

Avian Acute Risk Quotients (based on upper-bound Kenaga residues) 

Short Grass Tall Grass Broadleaf

Plants/Small Insects

Fruits/Pods/Seeds

Large Insects

Apples 1.95

(6 / 5)

20 5.19*** 2.38*** 2.92*** 0.32**

100 2.32*** 1.07*** 1.31*** 0.15*

1000 0.73*** 0.34** 0.41** 0.05

Cherries 1.3

(6 / 7)

20 3.18*** 1.46*** 1.79*** 0.20**

100 1.42*** 0.65*** 0.80*** 0.09

1000 0.45** 0.21** 0.25** 0.03

Crab apples

(OR)

0.34

(6 / 7)

20 0.90*** 0.41** 0.51*** 0.06

100 0.41** 0.19* 0.23** 0.03

1000 0.13* 0.06 0.07 0.01

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

20 1.84*** 0.84*** 1.04*** 0.12*

100 0.83*** 0.38** 0.46** 0.05

1000 0.26** 0.12* 0.15* 0.02

Peaches 2.6

(5 / 7)

20 5.62*** 2.58*** 3.16*** 0.35**

100 2.52*** 1.15*** 1.42*** 0.16*

1000 0.80*** 0.36** 0.45** 0.05

Pears 1.95

(6 / 7)

20 5.19*** 2.38*** 2.92*** 0.32**

100 2.32*** 1.07*** 1.31*** 0.15*

1000 0.73*** 0.34** 0.41** 0.05
Table 4.4 Avian dose-based acute RQ values for proposed uses of dodine based on a bobwhite

quail LD50 = 690 mg/kg-bw and upper-bound Kenaga residues. 

Use Application Rate

lbs. a.i./A

(# app / interval,

days)

Body

Weight, g

Avian Acute Risk Quotients (based on upper-bound Kenaga residues) 

Short Grass Tall Grass Broadleaf

Plants/Small Insects

Fruits/Pods/Seeds

Large Insects

Page 59 of 219

Pecans 2.6

(5 / 10)

20 5.09*** 2.33*** 2.87*** 0.32**

100 2.28*** 1.05*** 1.28*** 0.14*

1000 0.72*** 0.33** 0.41** 0.05

Strawberries 1.3

(5 / 7)

20 2.81*** 1.29*** 1.58*** 0.18*

100 1.26*** 0.58*** 0.71*** 0.08

1000 0.40** 0.18* 0.22** 0.02

Walnuts 2.6

(5 / 10)

20 5.09*** 2.33*** 2.87*** 0.32**

100 2.28*** 1.05*** 1.28*** 0.14*

1000 0.72*** 0.33** 0.41** 0.05

* exceeds LOC for acute risk to listed species (RQ $ 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)

*** exceeds LOCs for acute risk, acute risk to listed species, and restricted use (RQ $ 0.5)

Table 4.5 Avian dietary-based acute and chronic RQ values for proposed uses of dodine based

on upper-bound Kenaga residues.

Use/App.

Method

Application

Rate lbs. ai/A

(# app /

interval, days)

Food Items

Upper

Bound

EEC

(mg/kg)a

Acute

Dietary

RQ

(EEC/

LC50)

b

Chronic

RQ

(EEC/

NOAEC)

Apples 1.95

(6 / 5)

Short grass 2224 0.26** 11.12

Tall grass 1019 0.12* 5.10

Broadleaf plants/small insects 1251 0.15* 6.25

Fruits, pods, seeds, and large

insects 139 0.02 0.69

Cherries 1.3

(6 / 7)

Short grass 1361 0.16* 6.81

Tall grass 624 0.07* 3.12

Broadleaf plants/small insects 766 0.09 3.83

Fruits, pods, seeds, and large

insects 85 0.01 0.43
Table 4.5 Avian dietary-based acute and chronic RQ values for proposed uses of dodine based

on upper-bound Kenaga residues.

Use/App.

Method

Application

Rate lbs. ai/A

(# app /

interval, days)

Food Items

Upper

Bound

EEC

(mg/kg)a

Acute

Dietary

RQ

(EEC/

LC50)

b

Chronic

RQ

(EEC/

NOAEC)

Page 60 of 219

Crab Apples

(OR)

0.34

(6 / 5)

Short grass 388 0.05* 1.94

Tall grass 178 0.02 0.89

Broadleaf plants/small insects 218 0.03 1.09

Fruits, pods, seeds, and large

insects 24 0.00 0.12

Peaches 2.6

(5 / 7)

Short grass 2410 0.29* 12.05

Tall grass 1105 0.13* 5.52

Broadleaf plants/small insects 1356 0.16* 6.78

Fruits, pods, seeds, and large

insects 151 0.02 0.75

Pears 1.95

(6 / 5)

Short grass 2224 0.26** 11.12

Tall grass 1019 0.12** 5.10

Broadleaf plants/small insects 1251 0.15* 6.25

Fruits, pods, seeds, and large

insects 139 0.02 0.69

Pecans 2.6

(5 / 10)

Short grass 2183 0.26** 10.91

Tall grass 1000 0.12* 5.00

Broadleaf plants/small insects 1228 0.15* 6.14

Fruits, pods, seeds, and large

insects 136 0.02 0.68

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

Short grass 789 0.09 3.95

Tall grass 362 0.04 1.81

Broadleaf plants/small insects 444 0.05* 2.22

Fruits, pods, seeds, and large

insects 49 0.01 0.25
Table 4.5 Avian dietary-based acute and chronic RQ values for proposed uses of dodine based

on upper-bound Kenaga residues.

Use/App.

Method

Application

Rate lbs. ai/A

(# app /

interval, days)

Food Items

Upper

Bound

EEC

(mg/kg)a

Acute

Dietary

RQ

(EEC/

LC50)

b

Chronic

RQ

(EEC/

NOAEC)

Page 61 of 219

Strawberries 1.3

(5 / 7)

Short grass 1205 0.14* 6.03

Tall grass 552 0.07* 2.76

Broadleaf plants/small insects 678 0.08* 3.39

Fruits, pods, seeds, and large

insects 75 0.01 0.38

Walnuts 2.6

(5 / 10)

Short grass 2183 0.26** 10.91

Tall grass 1000 0.12* 5.00

Broadleaf plants/small insects 1228 0.15* 6.14

Fruits, pods, seeds, and large

insects 136 0.02 0.68

(a)Based on bobwhite quail LC50 = 8413 ppm

(b)Based on mallard duck NOAEC = 200 mg/kg feed

* exceeds LOC for acute risk to listed species (RQ $ 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)

*** exceeds LOCs for acute risk to birds, acute risk to listed species, and restricted use (RQ $ 0.5)

4.1.2.2 Mammals

Table 4.6 summarizes the mammalian dose-based acute RQs for foliar uses of dodine. Acute, acute

restricted use and/or listed species acute risk LOCs are exceeded for mammals that consume short grass,

tall grass, broadleaf plants, and small insects across all weight classes for all modeled scenarios and

application rates, except crab apples and ornamentals, with acute RQs that represent LOC exceedances

ranging from 0.10 to 0.99. 

Table 4.7 summarizes the mammalian dose-based chronic RQs for foliar uses of dodine. The chronic

LOC is exceeded for mammals that consume short grass, tall grass, and broadleaf plants and small insects

across all weight classes for all modeled scenarios and application rates, with chronic RQs that represent

exceedances ranging from 1.0 to 34. For mammals that consume fruits, pods, and/or large insects, RQs

exceeded the chronic LOCs for all national uses with the exception of 1000 kg mammals in most cases. 

For seed eating mammals, no RQs exceeded the chronic LOC for any use. 

Table 4.8 summarizes the mammalian dietary-based chronic RQs for foliar uses of dodine. The chronic

LOC is exceeded for mammals that consume short grass, tall grass, broadleaf plants, and small insects for

all modeled scenarios and application rates, except crab apples and ornamentals, with chronic RQs that

represent exceedances ranging from 1.1 to 6.0. 
Page 62 of 219

Table 4.6 Mammalian dose-based acute RQ values for proposed uses of dodine based on a rat

LD50 = 1056 mg/kg-bw and upper-bound Kenaga values. 

Use Application

Rate lbs. a.i./A

(# app /

interval, days)

Body

Weight, g

Mammalian Acute Risk Quotients (upper-bound Kenaga residues)

Short

Grass Tall Grass

Broadleaf

Plants/Small

Insects

Fruits/pods/

large insects

Seeds

Apples 1.95

(6 / 5)

15 0.91*** 0.42** 0.51*** 0.06 0.0

35 0.78*** 0.36** 0.44** 0.05 0.01

1000 0.41** 0.19* 0.23** 0.03 0.01

Cherries 1.3

(6 / 7)

15 0.56*** 0.26** 0.31** 0.03 0.01

35 0.48** 0.22** 0.27** 0.03 0.01

1000 0.25** 0.12* 0.14* 0.02 0.00

Crab apples

(OR)

0.34

(6 / 5)

15 0.16* 0.07 0.09 0.01 0.00

35 0.14* 0.06 0.08 0.01 0.00

1000 0.07 0.03 0.04 0.00 0.00

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

15 0.32** 0.15* 0.18* 0.02 0.00

35 0.28** 0.13* 0.16* 0.02 0.00

1000 0.15* 0.07 0.08 0.01 0.00

Peaches 2.6

(5 / 7)

15 0.99*** 0.45** 0.55*** 0.06 0.01

35 0.85*** 0.39** 0.48** 0.05 0.01

1000 0.45** 0.20** 0.25** 0.03 0.01

Pears 1.95

(6 / 5)

15 0.91*** 0.42** 0.51*** 0.06 0.01

35 0.78*** 0.36** 0.44** 0.05 0.01

1000 0.41** 0.19* 0.23** 0.03 0.01

Pecans 2.6

(5 / 10)

15 0.89*** 0.41** 0.50*** 0.06 0.01

35 0.77*** 0.35** 0.43** 0.05 0.01

1000 0.40** 0.18* 0.23** 0.03 0.01

Strawberries 1.3

(5 / 7)

15 0.49** 0.23** 0.28** 0.03 0.01

35 0.42** 0.19* 0.24** 0.03 0.01

1000 0.22** 0.10* 0.13* 0.01 0.00

Walnuts 2.6

(5 / 10)

15 0.89*** 0.41** 0.50*** 0.06 0.01

35 0.77*** 0.35** 0.43** 0.05 0.01

1000 0.40** 0.18* 0.23** 0.03 0.01

* exceeds LOC for acute risk to listed species (RQ $ 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)
Page 63 of 219

*** exceeds LOCs for acute risk to mammals, acute risk to listed mammals, and restricted use (RQ $ 0.5)

Table 4.7 Mammalian dose-based chronic RQ values for proposed uses of dodine based on a rat

reproductive NOAEL of 30.28 mg/kg-bw/day and upper-bound Kenaga residues. 

Use Application

Rate lbs. a.i./A

(# app /

interval, days)

Body

Weight, g

Mammalian Chronic Risk Quotients (upper-bound Kenaga values)

Short

Grass Tall Grass

Broadleaf

Plants/Small

Insects

Fruits/pods/

large insects

Seeds

Apples 1.95

(6 / 5)

15 31.74* 14.55* 17.86* 1.98* 0.44

35 27.26* 12.49* 15.33* 1.70* 0.39

1000 14.32* 6.56* 8.06* 0.90 0.18

Cherries 1.3

(6 / 7)

15 19.43* 8.91* 10.93* 1.21* 0.27

35 16.68* 7.65* 9.38* 1.04* 0.24

1000 8.77* 4.02* 4.93* 0.55 0.11

Crab apples

(OR)

0.34

(6 / 5)

15 5.53* 2.54* 3.11* 0.35 0.08

35 4.75* 2.18* 2.67* 0.30 0.07

1000 2.50* 1.14* 1.40* 0.16 0.03

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

15 11.27* 5.16* 6.34* 0.70 0.16

35 9.68* 4.43* 5.44* 0.60 0.14

1000 5.08* 2.33* 2.86* 0.32 0.06

Peaches 2.6

(5 / 7)

15 34.41* 15.77* 19.35* 2.15* 0.48

35 29.54* 13.54* 16.62* 1.85* 0.42

1000 15.52* 7.11* 8.73* 0.97 0.19

Pears 1.95

(6 / 5)

15 31.74* 14.55* 17.86* 1.98* 0.44

35 27.26* 12.49* 15.33* 1.70* 0.39

1000 14.32* 6.56* 8.06* 0.90 0.18

Pecans 2.6

(5 / 10)

15 31.16* 14.28* 17.53* 1.95* 0.43

35 26.76* 12.26* 15.05* 1.67* 0.38

1000 14.06* 6.44* 7.91* 0.88 0.18

Strawberries 1.3

(5 / 7)

15 17.20* 7.88* 9.68* 1.08* 0.24

35 14.77* 6.77* 8.31* 0.92 0.21

1000 7.76* 3.56* 4.37* 0.49 0.10

Walnuts 2.6

(5 / 10)

15 31.16* 14.28* 17.53* 1.95* 0.43

35 26.76* 12.26* 15.05* 1.67* 0.38

1000 14.06* 6.44* 7.91* 0.88 0.18

*exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.
Page 64 of 219

Table 4.8 Mammalian dietary-based chronic RQ values for proposed uses of dodine based on a

rat reproductive NOAEC of 400 mg/kg feed and upper-bound Kenaga residues. 

Use Application Rate

lbs. ai/A

(# app / interval,

days)

Food Items

Upper

Bound

EEC

(mg/kg)a

Chronic RQ

(EEC/

NOAEC)

Apples 1.95

(6 / 5)

Short grass 2224 5.56*

Tall grass 1019 2.55*

Broadleaf plants/small insects 1251 3.13*

Fruits, pods, seeds, and large insects 139 0.35

Cherries 1.3

(6 / 7)

Short grass 1361 3.40*

Tall grass 624 1.56*

Broadleaf plants/small insects 766 1.92*

Fruits, pods, seeds, and large insects 85 0.21

Crab Apples

(OR)

0.34

(6 / 5)

Short grass 388 0.97

Tall grass 178 0.45

Broadleaf plants/small insects 218 0.55

Fruits, pods, seeds, and large insects 24 0.06

Ornamental

Shade Trees (OR)

0.85

(6 / 10)

Short grass 789 1.97*

Tall grass 362 0.91

Broadleaf plants/small insects 444 1.11*

Fruits, pods, seeds, and large insects 49 0.12

Peaches 2.6

(5 / 7)

Short grass 2410 6.03*

Tall grass 1105 2.76*

Broadleaf plants/small insects 1356 3.39*

Fruits, pods, seeds, and large insects 151 0.38

Pears 1.95

(6 / 5)

Short grass 2224 5.56*

Tall grass 1019 2.55*

Broadleaf plants/small insects 1251 3.13*

Fruits, pods, seeds, and large insects 139 0.35
Table 4.8 Mammalian dietary-based chronic RQ values for proposed uses of dodine based on a

rat reproductive NOAEC of 400 mg/kg feed and upper-bound Kenaga residues. 

Use Application Rate

lbs. ai/A

(# app / interval,

days)

Food Items

Upper

Bound

EEC

(mg/kg)a

Chronic RQ

(EEC/

NOAEC)

Page 65 of 219

Pecans 2.6

(5 / 10)

Short grass 2183 5.46*

Tall grass 1000 2.50*

Broadleaf plants/small insects 1228 3.07*

Fruits, pods, seeds, and large insects 136 0.34

Strawberries 1.3

(5 / 7)

Short grass 1205 3.01*

Tall grass 552 1.38*

Broadleaf plants/small insects 678 1.70*

Fruits, pods, seeds, and large insects 75 0.19

Walnuts 2.6

(5 / 10)

Short grass 2183 5.46*

Tall grass 1000 2.50*

Broadleaf plants/small insects 1228 3.07*

Fruits, pods, seeds, and large insects 136 0.34

*exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.

4.1.2.3 Plants

Risk quotients for terrestrial plants could not be calculated because Tier II toxicity studies were not

submitted for review and therefore toxicity values used to calculate RQs were not available. Tier I plant

studies indicated some deleterious effects of dodine on some species of plants. In the absence of suitable

Tier II toxicity data and when Tier II effects > 25% are evident, risks to terrestrial plants are assumed.

4.1.3 RQs Based on Mean Kenaga Residues

Tables 4.9 - 4.13 summarize acute and chronic avian and mammalian RQs using mean Kenaga residue

values. These RQs do not form the basis of risk conclusion for birds and mammals but are provided for

comparison purposes. Using the mean Kenaga residue values for calculating RQs would not protect birds

and mammals that consume food items that have residues on the higher end of the residue distribution. 

An analysis of the residue distribution for the different food items using input values from Fletcher et al.

(1994) and assuming a log-normal distribution of residues on food items was conducted. The analysis

shows that the mean Kenaga values range from about the 62-87 percentile indicating that up to 38% of

the higher-end food item residue estimates are not captured by using the mean Kenaga values. 

Importantly, if the actual distribution differed from log-normal, these estimates could change
Page 66 of 219

substantially. The implications and utility of these values is described further in the Risk Description

section. 

Table 4.9 Acute dose-based RQ values for small (20-g), intermediate (100-g) and large (1,000-g)

birds exposed to dodine based on a bobwhite quail LD50 = 690 mg/kg-bw and mean Kenaga

residues. 

Use Application Rate

lbs. a.i./A

(# app / interval,

days)

Body

Weight, g

Avian Acute Risk Quotients (mean Kenaga residues)

Short Grass Tall Grass Broadleaf

Plants/Small Insects

Fruits/pods/

large insects

Apples 1.95

(6 / 5)

20 1.84*** 0.78*** 0.97*** 0.15*

100 0.82*** 0.35** 0.44** 0.07

1000 0.26** 0.11* 0.14* 0.02

Cherries 1.3

(6 / 7)

20 1.13*** 0.48** 0.60*** 0.09

100 0.50*** 0.21** 0.27** 0.04

1000 0.16* 0.07 0.08 0.01

Crab apples

(OR)

0.34

(6 / 7)

20 0.32** 0.14* 0.17* 0.03

100 0.14* 0.06 0.08 0.01

1000 0.05 0.02 0.02 0.00

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

20 0.65*** 0.28** 0.35** 0.05

100 0.29** 0.12* 0.15* 0.02

1000 0.09 0.04 0.05 0.01

Peaches 2.6

(5 / 7)

20 1.99*** 0.84*** 1.05*** 0.16*

100 0.89*** 0.38** 0.47** 0.07

1000 0.28** 0.12* 0.15* 0.02

Pears 1.95

(6 / 5)

20 1.84*** 0.78*** 0.97*** 0.15*

100 0.82*** 0.35** 0.44** 0.07

1000 0.26** 0.11* 0.14* 0.02

Pecans /

Walnuts

2.6

(5 / 10)

20 1.80*** 0.76*** 0.96*** 0.15*

100 0.81*** 0.34** 0.43** 0.07

1000 0.26** 0.11* 0.14* 0.02

Strawberries 1.3

(5 / 7)

20 1.00*** 0.42** 0.53** 0.08

100 0.45** 0.19* 0.24** 0.04

1000 0.14* 0.06 0.07 0.01

* exceeds LOC for acute risk to listed species (RQ $ 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)

*** exceeds LOCs for acute risk to birds, acute risk to listed birds, and restricted use (RQ $ 0.5)
Page 67 of 219

Table 4.10 Acute and chronic dietary-based RQ values for birds exposed to dodine based on

mean Kenaga residues.

Use Application

Rate lbs. ai/A

(# app /

interval, days)

Food Items

Mean

EEC

(mg/kg)a

Acute

Dietary

RQ

(EEC/

LC50)

b

Chronic

RQ

(EEC/

NOAEC)

Apples 1.95

(6 / 5)

Short grass 788 0.09 3.94

Tall grass 334 0.04 1.67

Broadleaf plants/small insects 417 0.05 2.08

Fruits, pods, seeds, and large

insects 65 0.01 0.32

Cherries 1.3

(6 / 7)

Short grass 482 0.06 2.41

Tall grass 204 0.02 1.02

Broadleaf plants/small insects 255 0.11* 1.28

Fruits, pods, seeds, and large

insects 40 0.01 0.20

Crab Apples

(OR)

0.34

(6 / 5)

Short grass 137 0.02 0.69

Tall grass 58 0.01 0.29

Broadleaf plants/small insects 73 0.01 0.36

Fruits, pods, seeds, and large

insects 11 0.001 0.06

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

Short grass 280 0.03 1.40

Tall grass 118 0.01 0.59

Broadleaf plants/small insects 148 0.02 0.74

Fruits, pods, seeds, and large

insects 23 0.003 0.12

Peaches 2.6

(5 / 7)

Short grass 854 0.10* 4.27

Tall grass 362 0.04 1.81

Broadleaf plants/small insects 452 0.05 2.26

Fruits, pods, seeds, and large

insects 70 0.01 0.35
Table 4.10 Acute and chronic dietary-based RQ values for birds exposed to dodine based on

mean Kenaga residues.

Use Application

Rate lbs. ai/A

(# app /

interval, days)

Food Items

Mean

EEC

(mg/kg)a

Acute

Dietary

RQ

(EEC/

LC50)

b

Chronic

RQ

(EEC/

NOAEC)

Page 68 of 219

Pears 1.95

(6 / 5)

Short grass 788 0.09 3.94

Tall grass 334 0.04 1.67

Broadleaf plants/small insects 417 0.05 2.08

Fruits, pods, seeds, and large

insects 65 0.01 0.32

Pecans/

Walnuts

2.6

(5 / 10)

Short grass 773 0.09 3.87

Tall grass 327 0.04 1.64

Broadleaf plants/small insects 409 0.05 2.05

Fruits, pods, seeds, and large

insects 64 0.01 0.32

Strawberries 1.3

(5 / 7)

Short grass 280 0.03 2.13

Tall grass 118 0.01 0.90

Broadleaf plants/small insects 148 0.02 1.13

Fruits, pods, seeds, and large

insects 23 0.003 0.18

(a)Based on bobwhite quail LC50 = 8413 ppm

(b)Based on mallard duck NOAEL = 200 mg/kg feed

* exceeds LOC for acute risk to listed species (RQ $ 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)

*** exceeds LOCs for acute risk to birds, acute risk to listed species, and restricted use (RQ $ 0.5)
Page 69 of 219

Table 4.11 Mammalian acute dose-based RQ values for proposed uses of dodine based on a rat

LD50 = 1056 mg/kg-bw and mean Kenaga residues. 

Use Application

Rate lbs. a.i./A

(# app /

interval, days)

Body

Weight, g

Mammalian Acute Risk Quotients (based in mean Kenaga residues)

Short

Grass Tall Grass

Broadleaf

Plants/Small

Insects

Fruits/pods/

large insects

Seeds

Apples 1.95

(6 / 5)

15 0.32** 0.14* 0.17* 0.03 0.01

35 0.28** 0.12* 0.15* 0.02 0.01

1000 0.15* 0.06 0.08 0.01 0.00

Cherries 1.3

(6 / 7)

15 0.20** 0.08 0.10* 0.02 0.00

35 0.17* 0.07 0.09 0.01 0.00

1000 0.09 0.04 0.05 0.01 0.00

Crab apples

(OR)

0.34

(6 / 5)

15 0.06 0.02 0.03 0.00 0.00

35 0.05 0.02 0.03 0.00 0.00

1000 0.03 0.01 0.01 0.00 0.00

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

15 0.11* 0.05 0.06 0.01 0.00

35 0.10* 0.04 0.05 0.01 0.00

1000 0.05 0.02 0.03 0.00 0.00

Peaches 2.6

(5 / 7)

15 0.35** 0.15* 0.18* 0.03 0.01

35 0.30** 0.13* 0.16* 0.02 0.01

1000 0.16* 0.07 0.08 0.01 0.00

Pears 1.95

(6 / 5)

15 0.32** 0.14* 0.17* 0.03 0.01

35 0.28** 0.12* 0.15* 0.02 0.01

1000 0.15* 0.06 0.08 0.01 0.00

Pecans/ 

Walnuts

2.6

(5 / 10)

15 0.32** 0.13* 0.17* 0.03 0.01

35 0.27** 0.12* 0.14* 0.02 0.01

1000 0.14* 0.06 0.08 0.01 0.00

Strawberries 1.3

(5 / 7)

15 0.17* 0.07 0.09 0.01 0.00

35 0.15* 0.06 0.08 0.01 0.00

1000 0.08 0.03 0.04 0.01 0.00

* exceeds LOC for acute risk to listed species (RQ $ 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)

*** exceeds LOCs for acute risk to mammals, acute risk to listed mammals, and restricted use (RQ $ 0.5)
Page 70 of 219

Table 4.12 Mammalian dose-based chronic RQ values for proposed uses of dodine based on a

rat reproductive NOAEL of 30.28 mg/kg-bw/day and mean Kenaga values. 

Use Application

Rate lbs. a.i./A

(# app /

interval, days)

Body

Weight, g

Mammalian Chronic Risk Quotients (based on mean Kenega residues)

Short

Grass Tall Grass

Broadleaf

Plants/Small

Insects

Fruits/pods/

large insects

Seeds

Apples 1.95

(6 / 5)

15 11.24* 4.76* 5.95* 0.93 0.20

35 9.65* 4.09* 5.11* 0.79 0.18

1000 5.07* 2.15* 2.69* 0.42 0.08

Cherries 1.3

(6 / 7)

15 6.88* 2.91* 3.64* 0.57 0.13

35 5.91* 2.50* 3.13* 0.49 0.11

1000 3.10* 1.31* 1.64* 0.26 0.05

Crab apples

(OR)

0.34

(6 / 5)

15 1.96* 0.83 1.04* 0.16 0.04

35 1.68* 0.71 0.89* 0.14 0.03

1000 0.88 0.37 0.47 0.07 0.01

Ornamental

Shade Trees

(OR)

0.85

(6 / 10)

15 3.99* 1.69* 2.11* 0.33 0.07

35 3.43* 1.45* 1.81* 0.28 0.06

1000 1.80* 0.76 0.95 0.15 0.03

Peaches 2.6

(5 / 7)

15 12.19* 5.16* 6.45* 1.00* 0.22

35 10.46* 4.43* 5.54* 0.86 0.20

1000 5.50* 2.33* 2.91* 0.45 0.09

Pears 1.95

(6 / 5)

15 11.24* 4.76* 5.95* 0.93 0.20

35 9.65* 4.09* 5.11* 0.79 0.18

1000 5.07* 2.15* 2.69* 0.42 0.08

Pecans/

Walnuts

2.6

(5 / 10)

15 11.04* 4.67* 5.84* 0.91 0.20

35 9.48* 4.01* 5.02* 0.78 0.18

1000 4.98* 2.11* 2.64* 0.41 0.08

Strawberries 1.3

(5 / 7)

15 6.09* 2.58* 3.23* 0.50 0.11

35 5.23* 2.22* 2.77* 0.43 0.10

1000 2.75* 1.16* 1.46* 0.23 0.05

*exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.
Page 71 of 219

Table 4.13 Mammalian dietary-based chronic RQ values for proposed uses of dodine based on a

rat reproductive NOAEC of 400 mg/kg feed and mean Kenaga residues.

Use Application Rate

lbs. ai/A

(# app / interval,

days)

Food Items

Mean

EEC

(mg/kg)a

Chronic RQ

(EEC/

NOAEC)

Apples 1.95

(6 / 5)

Short grass 788 1.97*

Tall grass 334 0.84

Broadleaf plants/small insects 417 1.04*

Fruits, pods, seeds, and large insects 65 0.16

Cherries 1.3

(6 / 7)

Short grass 482 1.21*

Tall grass 204 0.51

Broadleaf plants/small insects 255 0.64

Fruits, pods, seeds, and large insects 40 0.10

Crab Apples

(OR)

0.34

(6 / 5)

Short grass 137 0.34

Tall grass 58 0.15

Broadleaf plants/small insects 73 0.18

Fruits, pods, seeds, and large insects 11 0.03

Ornamental

Shade Trees (OR)

0.85

(6 / 10)

Short grass 280 0.70

Tall grass 118 0.30

Broadleaf plants/small insects 148 0.37

Fruits, pods, seeds, and large insects 23 0.06

Peaches 2.6

(5 / 7)

Short grass 854 2.14*

Tall grass 362 0.91

Broadleaf plants/small insects 452 1.13*

Fruits, pods, seeds, and large insects 70 0.18

Pears 1.95

(6 / 5)

Short grass 788 1.97*

Tall grass 334 0.84

Broadleaf plants/small insects 417 1.04*

Fruits, pods, seeds, and large insects 65 0.16
Table 4.13 Mammalian dietary-based chronic RQ values for proposed uses of dodine based on a

rat reproductive NOAEC of 400 mg/kg feed and mean Kenaga residues.

Use Application Rate

lbs. ai/A

(# app / interval,

days)

Food Items

Mean

EEC

(mg/kg)a

Chronic RQ

(EEC/

NOAEC)

Page 72 of 219

Pecans 2.6

(5 / 10)

Short grass 773 1.93*

Tall grass 327 0.82

Broadleaf plants/small insects 409 1.02*

Fruits, pods, seeds, and large insects 64 0.16

Strawberries 1.3

(5 / 7)

Short grass 427 1.07*

Tall grass 181 0.45

Broadleaf plants/small insects 226 0.56

Fruits, pods, seeds, and large insects 35 0.09

Walnuts 2.6

(5 / 10)

Short grass 773 1.93*

Tall grass 327 0.82

Broadleaf plants/small insects 409 1.02*

Fruits, pods, seeds, and large insects 64 0.16

*exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.

4.2 Risk Description

The available data on the fate and effects of dodine were sufficient to address the risk hypothesis for

most, but not all taxa. The results of this screening-level risk assessment indicate acceptance of the risk

hypothesis and that there is po tential for direct adverse acute effects to non-target aquatic freshwater

invertebrates, non-vascular aquatic plants, saltwater invertebrates and molluscs, birds, mammals and

chronic effects to birds and mammals, based on modeled aerial application rates of dodine of 2.0 to 13.0

lb ai/A/yr. These yearly application rates represent most of the proposed uses of dodine applied at the

maximum label rate. In addition, based on modeled aerial applications to apples (Pennsylvania; 11.7 lbs.

a.i./A/yr) there is the potential for direct adverse acute effects on Federally listed freshwater fish and

chronic effects on freshwater invertebrates. Dodine is not likely to pose an acute risk to

saltwater/estuarine fish nor is it likely to pose a chronic risk to freshwater 
Page 73 of 219

A description of the potential direct effects associated with exposure to dodine is provided for each of the

taxonomic groups below. Table 4.14 provides a summary of the direct effects for Federally listed species

of concern, including the range of RQ values and the acute dose-response slopes used in evaluating the

probability of individual effects.

Table 4.14. Summary of Direct Effects for Federally Listed Species

Listed Species

Taxonomic Group of

Concern

Direct Effects Slopea RQ Range

Freshwater fish Acute: mortality <LOC - 0.08

Freshwater invertebrates Acute: mortality/immobilization

Chronic: growth/reproduction

<LOC - 2.42

<LOC - 1.19

Saltwater mollusc Acute: shell deposition < LOC - 0.62

Aquatic Plants:

 Vascular 

 Non-vascular

no data

Acute: reduced cell density

NA no data

<LOC - 45

Birds Acute: mortality/sublethal

Chronic: reproduction

<LOC - 5.62

<LOC - 12

Mammals Acute: mortality

Chronic: 

<LOC - 0.99

<LOC - 286

therefore a default slope value and 95%

confidence intervals were used (Urban and Cook, 1986).

4.2.1 Risks to Aquatic Organisms

The risk assessment for aquatic species is based on data from both dodine and DGH since both

compounds are expected to behave similarly in aquatic environments; both will dissociate to the

dodecylguanidinium ion and their respective cation, acetate or chloride. Furthermore, review of DGH

product formulations indicate that formulation components other than the active ingredient

(Dodecylquanidine hydrochloride) are unlikely to cause significant toxic effects. Given the similarities

between DGH and dodine, there is the potential for exposure to aquatic organisms to dodecylguanidine

based on uses of DGH; however, current uses of DGH preclude a robust quantitative assessment of the

likelihood of exposure. This assessment is based entirely on uses of dodine.
Page 74 of 219

4.2.1.1 Freshwater Fish

Risk quotients indicate that there is a potential for direct effects to freshwater fish. The only LOC

exceedance was for the 11.7 lb ai/A/yr aerial application to apples, as simulated using the Pennsylvania

apple scenario in PRZM/EXAMS (RQ = 0.08). For this scenario, the acute EEC was 43ppb and the

NOAEC for fish mortality based on the rainbow trout study was 320 ppb. The same dodine use, when

modeled using the North Carolina and Oregon apple scenarios, results in risk quotients below the LOC. 

Predicted risks in Pennsylvania are likely the result of higher erosion and subsequent off-site transport of

dodine adsorbed to eroded sediment into water bodies adjacent to treated fields. As discussed in section

3.2.2.1, the highest annual use rates, simulated for peaches, pecans and walnuts (13.0 lbs. a.i./A/yr), did

not produce EECs that resulted in LOC exceedances. The Pennsylvania apple scenario is characterized

by an average annual sediment loss of 56 ton ha-1 yr-1 compared to 2.6, 11 and 0.07 ton ha-1 yr-1 for

Georgia peaches, Georgia pecans and California walnut, respectively (Table 3.7). It is possible that

dodine use at higher rates (peaches, pecans, walnuts; 13.0 lbs. a.i./A/yr) could result in higher EECs than

seen in this aquatic modeling assessment if the site is as vulnerable to soil loss as the Pennsylvania

scenario. Based on the screening-level RQs, chronic risks associated with freshwater fish exposure to

dodine are not likely.

The freshwater fish toxicity data indicate that dodine is very highly toxic to rainbow trout, however,

extrapolation to other freshwater fish is highly uncertain. In all likelihood, more sensitive species are

likely to exist. In cases, where dodine levels in water approach those where risks were identified, other

fish species may also be at risk.

4.2.1.2 Freshwater Invertebrates

As detailed in section 4.1.1.1, acute restricted use and listed species LOCs for freshwater invertebrates are

exceeded for all modeled uses, except strawberries in Florida. In addition, for the current application

rates modeled, acute LOCs are exceeded for freshwater invertebrates for aerial applications to

Pennsylvania apples (11.7 lb ai/A/yr), Michigan cherries (7.8 lb ai/A)/yr, Georgia pecans (13.0 lbs.

a.i./A/yr), and Georgia peaches (13.0 lbs. a.i./A/yr). For freshwater invertebrates, the chronic LOC is

exceeded based on aerial application of dodine to Pennsylvania apples (11.7 lb ai/A/yr) only. Analysis

based on one study of benthic invertebrates indicated that for benthic invertebrate species, the chronic risk

LOC was not exceeded and risks are expected to be low.

The strawberry use modeled in Florida did not result in exceedances because it is the use with the lowest

application rate (6.5 lbs ai/A/yr) and it is only applied by ground spray which generally results in less

spray drift than aerial applications. However, it important to note that much strawberry production uses

full-bed plastic mulch (USDA Crop Profiles:

http://www.ipmcenters.org/cropprofiles/docs/FLstrawberries.html), which could result in increased runoff

and off-site transport of pesticide. Currently, OPP does not have a standard approach for quantifying

increased runoff and pesticide loading resulting from applications to plastic mulch. For dodine, however,

erosion and/or spray drift are the likely dominant routes of off-site transport.

 

PRZM/EXAMS simulations indicate that the greatest contribution to predicted dodine exposure in water
Page 75 of 219

is erosion, particularly for the Pennsylvania apple and Michigan cherries scenarios. In one case, pears in

California, spray drift was the dominant route of off-site transport of dodine. The California fruit

scenario, used to represent pears, is characterized by both low annual average runoff and erosion (Table

3.7). The modeling assessment suggests that dodine exposure is highly dependant not only on the

application rate, but also on the vulnerability of the site to sediment loss. For example, the Pennsylvania

apples (11.7 lb ai/A/yr) and Michigan cherries (7.8 lb ai/A/yr) scenarios had higher acute EECs than the

Georgia peaches, Georgia pecans and California walnut, all of which had the highest annual application

rates (13 lb ai/A/yr).

Even though spray drift was the only dominant route of off-site transport for one scenario, there is a

possibility that spray drift alone could result in acute exposures that exceed LOCs for freshwater

invertebrates. Aquatic acute EECs would have to be as low as 8.9, 1.8 or 0.89 ppb to reach RQ values for

freshwater invertebrates that are less than acute, acute restricted use or listed species LOCs. Simulated

acute EECs under drift-only conditions (i.e., application efficiency set to 0 and drift set to 0.05 in PRZM)

for peaches, the highest maximum application rate (2.6 lbs ai/A/app; 5 applications; 7 day interval), and

cherries, the lowest maximum national application rate for which aerial applications are allowed (1.3 lbs

ai/A/app; 6 applications; 7 day interval) are 7.6 and 4.2 ppb, respectively, suggesting that spray drift alone

as a route of exposure to freshwater invertebrates may be of concern.

Given that RQ values, based on spray drift only at application rates of 1.3 to 2.6 lb ai/A, are in excess of

LOCs for freshwater invertebrates, the AgDRIFT model (Version 2.01) was used to refine the spray drift

exposure estimate (Teske et al., 2001). Downwind spray drift buffers were developed for possible use in

mitigating risk for listed freshwater invertebrates in aquatic ecosystems that are within close proximity to

agricultural fields that may be treated with liquid spray applications of dodine. The approach and results

of the AgDRIFT modeling including downwind distance are presented in Appendix F. The results of the

AgDRIFT modeling show that required buffer distances, based on aerial applications at 2.6 lb ai/A and

assuming screening-level defaults for droplet size (ASEA fine), wind speed (15 mph) and release height

(15 ft.), are expected to exceed the 1,000 foot limit of AgDRIFT. Modeled buffer requirements for listed

invertebrates, based on aerial application of dodine (2.6 lb ai/A) at a 10 foot release height in wind speeds

< 10 mph, are expected to range from approximately > 1,000 to 880 ft., for ASEA fine and ASEA

medium droplet sizes, respectively. For orchard airblast applications at 2.6 and 1.3 lbs. ai/A, Tier I

AgDRIFT modeling suggests buffer distances of 154 and 76 ft., respectively, would be sufficient to

reduce exposure concentrations below the LOC for listed 
Page 76 of 219

4.2.1.3 Saltwater Fish

Acute risk to estuarine/marine fish is unlikely, based on the results of the screening assessment.

4.2.1.4 Saltwater Invertebrates

 The acute risks to

saltwater invertebrates suggest the potential for chronic risks as well. Also, given the sensitivity of

freshwater invertebrates to dodine, studies on the chronic toxicity of dodine to estuarine/marine

invertebrates are warranted. Invertebrates are vitally important components of estuarine and marine

environments providing food for a wide variety of species, including listed species. In addition to a

potential reduction in biomass, mortality of invertebrates could lead to a shift in the invertebrate

community structure towards less sensitive species, which may or may not result in a change in

ecosystem function (see Relyea, 2005).

For molluscs, acute restricted use and listed species LOCs are exceeded for all modeled scenarios (7.8-

13.0 lbs ai/A/yr) except strawberries (6.5 lbs ai/A/yr). Molluscs are important components of many nearshore saltwater ecosystems. Molluscs serve as prey to a number of aquatic and terrestrial species, can be

a commercial commodity, and help clean water through filtration. The effects of dodine on molluscs are

not all together unexpected as a structurally similar chemical, DGH, is used in control of some molluscan

species. Dodine, however, is not used as a molluscicide.

The toxicity data on estuarine/marine invertebrates (including molluscs) was based on data from studies

using DGH. As previously explained (sec 3.3), the active ingredient for both DGH and dodine is

expected to be the dodecylguanidinium ion, and therefore to have similar toxicities. Importantly, a drift

assessment is not required for formulations of DGH since the uses of this chemical are non-agricultural 

and therefore, drift is not possible. 
Page 77 of 219

4.2.1.5 Aquatic Plants

Based on predicted EECs for the modeled dodine use patterns and available toxicity data, LOCs are

exceeded for non-listed and listed non-vascular aquatic plants. Since there are no available toxicity data

for aquatic vascular plants, the risk due to dodine use is unknown.

Specifically, LOCs for listed and non-listed non-vascular plants are exceeded for all modeled uses (7.8 -

13.0 lbs. ai/A/yr) except strawberries in Florida (6.5 lbs ai/A/yr). As mentioned previously, the

strawberry scenario does not account for increased runoff due to applications to plastic mulch, which

could result in an underestimation of exposure for this scenario. Aquatic acute EECs would have to be as

low as 0.05 ppb to be sufficient to achieve RQ values for non-vascular aquatic plants that are less than the

LOCs. Given the high toxicity of dodine to non-vascular aquatic plants and the lack of sufficient

information on the toxicity of dodine to aquatic vascular plants, for the sake of this discussion both nonvascular and vascular aquatic plants are considered together as “aquatic plants”. Aquatic plants are key

components to all aquatic ecosystems and provide a multitude of ecological functions. They provide food

and shelter for a wide variety of aquatic animal species and help maintain water quality through

temperature modulation, filtration, and oxygen supply. Any effects on aquatic plants as a result of dodine

use would be expected to result in significant ecosystem-level effects. Most notably, there would likely

be a near instant decrease in water quality associated with plant decay and depletion of oxygen. In turn,

sedimentation would likely increase due to decay and a loss in filtering capacity. The depletion of

oxygen and increased siltation could result in widespread fish and invertebrate mortality. The cascade of

effects due to effects on aquatic plants would pose a risk to any aquatic listed species near the use area as

well as terrestrial species that rely on aquatic organisms as food items such as piscivorous birds,

mammals, or reptiles (see Relyea, 2005 for an example of pesticide-induced effects on aquatic

communities). 

4.2.2 Risks to Terrestrial Organisms

4.2.2.1 Birds

Using both dose-based (LD50 = 690mg/kg-bw for bobwhite quail) and dietary-based (LC50 = 8413 mg/kgdiet for bobwhite quail) toxicity values, acute, acute restricted use and/or listed species LOCs are

exceeded for birds that consume short grass, tall grass, broadleaf plants, and small insects for all modeled

scenarios and application rates (2.04 - 13.0 lbs ai/A/yr). Based on the dose-based endpoint, acute

restricted use and/or listed species LOCs are also exceeded for birds that consume fruits, pods, seeds, and

large insects at application rates for all modeled scenarios, except crab apples (2.04 lbs ai/A/yr), at the

smallest weight class, and in some cases at the medium weight class. 

Risk quotients calculated using the dose-based toxicity values are generally higher than RQs calculated

using the dietary-based toxicity values.
Page 78 of 219

To bound the estimates of risk to birds resulting from acute exposure to dodine, RQs using mean Kenaga

residue values in addition to upper-bound values were calculated (Tables 4.9 and 4.10). Even using the

less conservative mean residue values, which do not include up to 38% of the higher-end residue

estimates, LOCs are exceeded for birds, based on the dose-based, with dose-based RQs ranging from

<LOC to 2.0. Using the data summarized in Fletcher et al. (1994) for input values, log-normal

distributions were generated that describe residue levels on the various food items, assuming a log-normal

distribution. In this case, the mean Kenaga residue estimates typically fell within the 62-87 percentile,

indicating that about 38-13% of the higher-end residue estimates were not captured in estimating

exposure. In contrast, for the upper-end Kenaga residue estimates, about 3-13% of the upper-end residue

estimates were not captured. This highlights the fact that the upper-end Kenaga values are not a

maximum exposure level. In addition to mortality, sublethal effects to birds resulting from acute

exposure to dodine in the field could include depression, reduced reaction to external stimuli, wing droop

and loss of coordination.

Chronic risks to birds were evaluated using a mallard duck NOAEL value of 200 mg/kg-feed, based on

reproductive effects including reduction in the number of eggs laid, eggs set, viable embryos, viable 3-

week embryos, hatchlings, 14-day old chick survivors and hatchling weight. Based on the mallard duck

NOAEL of 200 mg/kg-feed, chronic LOCs are exceeded for birds that consume short grass, tall grass,

broadleaf plants, and small insects for all modeled scenarios and application rates (2.04 - 13.0 lbs

ai/A/yr). Even assuming non-conservative mean Kenaga residue values resulting from maximum

application rates of dodine, risk from chronic exposure is likely with RQs ranging from <LOC - 4.3

(Table 4.10).

The estimates for chronic risks to birds were based on the NOAEL of 200 mg/kg-feed from a study on

mallard ducks. A similar study using bobwhite quail showed that there were no effects associated with

dodine exposure, even at the highest concentration of 300 mg/kg-feed. These data suggest that under

chronic exposure conditions, mallard ducks are more sensitive than bobwhite quail, which contrasts with

the acute toxicity data in which bobwhite quail were shown to be more sensitive. Chronic toxicity

endpoints are largely a function of the exposure levels chosen for the experiment and, for dodine, the true

NOAEL may lie between 200 and 600 ppm (the lowest LOAEL). Simulations using different

hypothetical NOAELs indicate that the NOAEL would have to exceed 550 ppm for the chronic risk to
Page 79 of 219

birds to change significantly. Above 550 ppm, RQs for birds that consume tall grass would fall below the

LOC, however, birds that consume short grass, broadleaf plants, and large insects would still be at risk. 

Although it is possible that the true NOAEL is 550 ppm, it is unlikely to be so close to the LOAEL of 600

ppm. This analysis indicates that the overall risk to birds associated with chronic dodine exposure is

adequately captured by results from submitted toxicity studies. 

4.2.2.2 Mammals

Acute risks to wild mammals were evaluated using a common laboratory rat female-specific LD50 value

of 1056 mg/kg. Acute, acute restricted use and/or listed species LOCs are exceeded for mammals that

consume short grass, tall grass, broadleaf plants, and small insects across most weight classes for all

modeled scenarios and application rates (2.04 - 13.0 lbs ai/A/yr). Even using the non-conservative mean

residue values (Table 4.11), LOCs are exceeded for mammals, based the dose-based female-specific

endpoints, with RQs ranging from <LOC to 0.35.

 
Page 80 of 219

4.2.2.3 Plants

, risks to terrestrial plants are assumed. Listed plant species are assumed to be at risk or

direct effects from some uses of dodine, particularly at higher use rates. Tier II plant studies are needed

to conduct a robust assessment of risks to terrestrial plants. As a rough RQ estimate, it is assumed that the

approximate EC25 for dodine is 2.6 lbs. a.i./A based on a Tier I plant study. Comparing to the highest

EEC generated from Terr Plant (v 1.0) of 0.910, the estimated RQ is 0.35. The LOC for non-listed plants

is 1 suggesting that non-listed plants may not be at risk. Risk quotients for listed plant species are

calculated using the EC05, which is unavailable for dodine. Overall, the available data indicate that risks

to non-listed plant species may not be expected while the potential for risks to listed plant species remains

unknown. Tier II plant studies are required to fully characterize risks to terrestrial plant species

associated with uses of dodine.

Studies available in the open literature and obtained from a search of the ECOTOX database provide

further insight into the effects of dodine on plants. Wood et al. (1985) showed that photosynthesis was

reduced by 20% in foliage sprayed with dodine. Moreover, treated foliage did not recover for 13-17 days

after spraying. In contrast, dodine sprayed on apple trees caused no significant effects on photosynthesis

(Sharma et al., 1977). While not exhaustive, the available data on the effects of dodine on terrestrial

plants suggests that studies are needed to more fully characterize dodine phytotoxicity. 

4.2.3 Non-Target Insects

EFED currently does not estimate risk quotients for terrestrial non-target insects. However, an

appropriate label statement is required to protect foraging honeybees when the LD50 is < 11 μg/bee. 

Based on the acute contact toxicity study to honeybees, the LD50 for dodine is >200 μg/bee. This

classifies dodine as practically non-toxic to honeybees.

4.2.4 Review of Incidents Data

No incidents of wildlife or aquatic species poisonings associated with uses of dodine were found in the

Ecological Incident Information System (EIIS) database.

Section 7 of the Endangered Species Act, 16 U.S.C. Section 1536(a)(2), requires all federal agencies to

consult with the National Marine Fisheries Service (NMFS) for marine and anadromous listed species, or

the United States Fish and Wildlife Services (FWS) for listed wildlife and freshwater organisms, if they

are proposing an "action" that may affect listed species or their designated habitat. Each federal agency is

required under the Act to insure that any action they authorize, fund, or carry out is not likely to

jeopardize the continued existence of a listed species or result in the destruction or adverse modification

of designated critical habitat. To jeopardize the continued existence of a listed species means "to engage
Page 81 of 219

in an action that reasonably would be expected, directly or indirectly, to reduce appreciably the likelihood

of both the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or

distribution of the species." 50 C.F.R. § 402.02.

To facilitate compliance with the requirements of the Endangered Species Act subsection (a)(2) the

Environmental Protection Agency, Office of Pesticide Programs has established procedures to evaluate

whether a proposed registration action may directly or indirectly reduce appreciably the likelihood of both

the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or

distribution of any listed species (U.S. EPA 2004). After the Agency’s screening level risk assessment is

conducted, if any of the Agency’s listed species LOCs are exceeded for either direct or indirect effects, an

analysis is any listed or species may co-occur in the area of the

proposed pesticide use or areas downstream or downwind that could be contaminated from drift or

runoff/erosion. If determined that listed or candidate species may be present in the proposed action areas,

further biological assessment is undertaken. The extent to which listed species may be at risk then

determines the need for the development of a more comprehensive consultation package as required by

the Endangered Species Act.

The federal action addressed herein is the proposed re-registration of pesticide products that contain the

Growing areas for these crops encompasses most of the United States (Figure 4.1).
Page 82 of 219

Figure 4.1. Total acreage of crops with dodine labeled uses (apples, cherries (sweet and tart), peaches,

pears, pecans, strawberries, walnuts) according to AgCensus 2002 (http://www.nass.usda.gov/census/). 

4.2.5.1 Action Area

For listed species assessment purposes, the action area is considered to be the area affected directly or

indirectly by dodine use and not merely the immediate area where dodine is applied. At the initial

screening-level, the risk assessment considers broadly described taxonomic groups and so conservatively

assumes that listed species within those broad groups are co-located with the pesticide treatment area. 

This means that terrestrial plants and wildlife are assumed to be located on or adjacent to the treated site

and aquatic organisms are assumed to be located in a surface water body adjacent to the treated site. The

assessment also assumes that the listed species are located within an assumed area which has the

relatively highest potential exposure to the pesticide, and that exposures are likely to decrease with

distance from the treatment area. Section 1.0 of this risk assessment presents the pesticide use sites that

are used to establish initial co-location of species with treatment areas. 
Page 83 of 219

4.2.5.2 Taxonomic Groups Potentially at Risk

If the assumptions associated with the screening-level action area result in RQs that are below the listed

species LOCs, a "no effect" determination conclusion is made with respect to listed species in that taxa,

and no further refinement of the action area is necessary. Furthermore, RQs below the listed species

LOCs for a given taxonomic group indicate no concern for indirect effects on listed species that depend

upon the taxonomic group for which the RQ was calculated. However, in situations where the screening

assumptions lead to RQs in excess of the listed species LOCs for a given taxonomic group, a potential for

a "may affect" conclusion exists and may be associated with direct effects on listed species belonging to

that taxonomic group or may extend to indirect effects upon listed species that depend upon that

taxonomic group as a resource. In such cases, additional information on the biology of listed species, the

locations of these species, and the locations of use sites are considered to determine the extent to which

screening assumptions regarding an action area apply to a particular listed organism. These subsequent

refinement steps will consider how this information would impact the action area for a particular listed

organism and potentially include areas of exposure that are downwind and downstream of the pesticide

use site.

Assessment endpoints, exposure pathways, and the conceptual model addressing proposed dodine reregistration uses, and the associated exposure and effects analyses conducted for the dodine screeninglevel risk assessment are in The assessment endpoints used in the screening-level risk

assessment include those defined operationally as reduced survival and reproductive impairment for both

aquatic and terrestrial animal species and survival, reproduction, and growth of aquatic and terrestrial

plant species from both direct acute and direct chronic exposures. These assessment endpoints address

the standard set forth in the Endangered Species Act requiring federal agencies to ensure that any action

they authorize does not reduce appreciably the likelihood of both the survival and recovery of a listed

species in the wild by reducing the reproduction, numbers, or distribution of the species. Risk estimates,

RQs, integrating exposure and effects are calculated for broad based taxa groups for the screening-level

risk assessment are presented in 

Both acute endangered species and chronic risk LOCs are considered in the screening-level risk

assessment to identify direct and indirect effects to taxa of listed species. This section identifies direct

effect concerns, by taxa, triggered by exceeding endangered LOCs in the screening level risk assessment

with an evaluation of the potential probability of individual effects for exposures that may occur at the

established endangered species LOC. Data on exposure and effects collected under field conditions are

evaluated to make determinations on the predictive utility of the direct effect screening assessment

findings to listed species. Additionally, the results of a screen for indirect effects to listed species, using

direct effect acute and chronic LOCs for each taxonomic group, is presented and evaluated.

4.2.5.2.1 Listed Species Risk Quotients

Freshwater Fish and Amphibians

Listed species acute risk LOCs for direct effects on freshwater fish and amphibians were exceeded (RQ >

0.05) for dodine when used at the maximum label rate for apples. There were no other exceedances. No

chronic risk LOCs (RQ > 1.0) were exceeded for freshwater fish.
Page 84 of 219

Freshwater Invertebrates

Listed species acute risk LOCs (RQ > 0.05) for direct effects on freshwater invertebrates were exceeded

(RQ > 0.05) for all uses of dodine at the maximum label rates except strawberries. RQs ranged from 0.34

for pears to 2.42 for apples. The listed species chronic risk LOC (RQ > 1.0) was exceeded for freshwater

invertebrates associated only with the use of dodine on apples at the maximum application rate.

Estuarine/Marine Fish

The listed species acute risk LOCs for estuarine/marine fish were not exceeded for any labeled uses of

dodine when applied at the maximum label rates. 

Estuarine/Marine Invertebrates

The listed species acute risk LOCs were exceeded for non-molluscan, estuarine/marine invertebrates for

all uses of dodine except strawberries. Similarly for molluscs, the listed species acute risk LOCs were

exceeded (RQ > 0.05) for uses of dodine on all labeled crops at the maximum labeled rate except for

strawberries. No chronic toxicity data were available to use in calculating listed species chronic risk

estimates for any estuarine/marine invertebrates. 

Aquatic Plants

The listed species acute risk LOCs were exceeded for non-vascular aquatic plants for all uses of dodine

(RQ > 1.0, calculated as NOAEC/EEC). 

Birds

Listed species acute risk LOCs (RQ > 0.1) for direct effects of dodine to birds were exceeded for all uses

of dodine for at least one body size/food item combination. Some RQs did not exceed the listed species

acute risk LOCs for larger birds and for birds that consume fruits, pods, seeds, and/or large insects. 

Similarly, listed species chronic risk LOCs (RQ > 1.0) were exceeded for all uses of dodine for at least

one combination of body size and food item type. Here too, RQs were lower for birds that consume

fruits, pods, seeds, and/or large insects. These results also apply to reptiles and amphibians since avian

species are used as surrogates for these taxonomic groups. 

Mammals

Listed species acute risk LOCs (RQ > 0.1) for direct effects of dodine on mammals were exceeded for all

uses of dodine for at least one combination of body size and food item. However, there were no

exceedances of the acute risk LOC for mammals that eat fruits, pods, large insects, or seeds. Also, for

uses of dodine on crab apples and cherries (OR only), there were less exceedances for some food types

and larger mammals compared to other uses. Listed species chronic risk LOCs (RQ > 1.0) were exceeded

for all uses of dodine for mammals that consume short grass, tall grass, broadleaf plants, and small
Page 85 of 219

insects. For mammals that consume fruits, pods, and/or large insects, chronic risk LOCs were exceeded

for smaller body size mammals for all national uses of dodine. Risk quotients for seed-eating mammals

did not exceed the LOC for any dodine use. 

4.2.5.2.2 Probit Dose-Response Analysis 

Aquatic Listed Species Probability of Effects on Individuals

The probability of individual effects at the acute endangered species LOC (RQ = 0.05 which is equivalent

to 1/20 of the LC50 or EC50) for each major listed species taxonomic group and the probability of

individual effects at estimated acute RQs above the endangered species acute risk LOC is provided in

Table 4.13. In addition, extrapolation of low probability events such as those occurring at the LOC, are

associated with a high degree of uncertainty. To address this uncertainty, analyses of individual effects

are also conducted at the upper and lower 95% confidence interval of the probit slope for each taxa. The

probit slopes used in this analysis were obtained from dose-response relationships used in calculating

RQs. 

For freshwater fish, the probit dose-response slope was 8.16 (95% C.I. 4.88-11.45) based on the rainbow

trout acute toxicity test. Should exposure to listed freshwater fish occur at the acute listed species LOC,

the probability of one individual being affected is 1 in 1.0E+16. At the lower and upper 95% confidence

limits, the probabilities are 1.0 in 9.19E+09 and 1.0 in 1.0E+16, respectively. Analyses of the probability

of individual effects occurring at exposures that occur at the EECs for these organisms indicate that for

fish, the probability of individual effects is the same as at the LOC, 1 in 1.0E+16; a very low probability

event. 

The probability of individual effects to listed freshwater invertebrates should exposure occur at the LOC

is 1.0 in 4.88E+11. The probit dose-response slope used for freshwater invertebrates was 5.33 (95% C.I.-

1.18 -11.84) based on a 48-h acute study on waterfleas. At the lower and upper 95% confidence limits

the probability of individual effects is 1.0 in 1.07E+00 and 1.0 in 1.00E+16, respectively. For freshwater

invertebrates that might be exposed to levels of dodine corresponding to the crop-specific EECs, the

probability of individual effects ranges from 1 in 160 for pears to 1 in 1.02 for apples. The probability of

individual effects to molluscs was not calculated since the estimated EC50 is based on effects of growth, a

continuous endpoint.

For estuarine/marine non-molluscan invertebrates, the probability of individual effects is 1.0 in 1.02E+07. 

The analysis of the probability of effects to individual listed estuarine/marine invertebrates was based on

a probit dose-response slope of 4.2. The lower and upper 95% confidence limits were -0.24 and 8.31,

respectively which correspond to probabilities of individual effects of 1 in 2.56 and 1 in 1.00E+16. For

exposures that occur at EECs for which LOCs were exceeded, the probabilities of individual effects

ranged from 1.0 in 152 for apples to 1.0 in 1.59E+04 for pecans. 
Page 86 of 219

Table 4.13 Probability of Direct Individual Effects to Aquatic Organisms

Associated with Maximum Use Rates of Dodine

Crop Site Application Rate

lbs a.i./A

Freshwater Saltwater

Fish and Amphibian Invertebrate Invertebrate

(# applications/

interval, days)

Probit Slope

 = 8.16(a)

Probit Slope

 = 5.33(b)

Probit Slope

= 4.0(c)

LOC Federally Listed

(0.05)

1 in 1.0E+16 1 in 4.88E+11 1 in 1.02E+07

Apples

(PA)

Maximum: 1.95 lb

ai/acre (6/5)

RQ = 0.08

1 in 1.0E+16

RQ = 2.42

1 in 1.02

Cherries

(MI)

Maximum: 1.3 lb

ai/acre (6/7)

–(f) RQ = 1.35

1 in 1.32

Peaches

(GA)

Maximum: 2.6 lb

ai/acre (5/7)

-- RQ = 0.90

1 in 2.48

Pears

(CA)

Maximum: 1.95 lb

ai/acre (6/7)

-- RQ = 0.34

1 in 160

Pecans

(GA)

Maximum: 2.6 lb

ai/acre (5/10)

-- RQ = 1.07

1 in 1.78

Strawberries

(FL)

Maximum: 1.3 lb

ai/acre (5/7)

-- --

Walnuts

(CA)

Maximum: 2.6 lb

ai/acre (5/10)

-- RQ = 0.44 

1 in 34.9

Probit slope based on acute toxicity data for freshwater fish (rainbow trout).

(b) Probit slope based on acute toxicity data for freshwater invertebrate (waterflea)

(e)Probit slope based on DGH acute toxicity data for mysid shrimp

(F) -- = endangered species acute LOC is not exceeded and the probability of an individual effect is less than the value listed for the endangered

species LOC. 

Terrestrial Listed Species Probability of Effects on Individuals

The probability of individual effects at the acute endangered species LOC (1/10 of the LD50) and the

probability of individual effects at calculated acute RQs for the highest registered use rate (2.6 lb ai/A) of

dodine for birds, reptiles, terrestrial amphibians, and mammals is provided in Table 4.14. For birds,

reptiles and amphibians, the probability of one individual being affected if exposed at the acute listed

species LOC is one in 7050. This estimate is based on a probit dose-response slop of 3.63 (95% C.I.

1.13-6.12) obtained from an acute dose-based toxicity study on bobwhite quail. At the lower and upper

95% confidence limits the probability of individual effects is 1.0 in 7.74 and 1.0 in 2.13E+09,

respectively. For birds exposed to dodine as a result of the highest registered use, the probability of

individual effects ranges from 1.0 in 8.6E+05 to 1.0 in 1.00. 

The probability of effects on individual mammals was based on the default probit dose-response slope of
Page 87 of 219

4.5 since raw data were not available at the time of this assessment. The lower and upper confidence

limits are assumed to be 2 and 9, respectively. The probability of individual effects is 1.0 in 2.94E+05. 

At the lower and upper confidence limits, the probability of individual effects is 1.0 in 44 and 1.0 in

1.0E+16, respectively. For mammals exposed to dodine at the highest application rate, the probability of

individual effects ranges from 1.0 in 1.0E+16 to 1.0 in 2.03. 

Table 4.14 Probability of Acute Mortality of an Individual, by Taxa Group and Body Weight,

Exposed at the Endangered Species LOC(1) and at the Highest Registered Use Rate (2.6 lbs a.i./A )

for Dodine

Taxa Body Wt

(g)

Dietary

Food Source

LOC(1) Exposure 2.6 lbs a.i./A Application

5 apps./ 7 day interval

Probability(2) of

effect at LOC

 (1 in ___)

EEC(3)

(ppm)

RQ(4) Probability(2) of

Effect at RQ

(1 in ___ )

Birds 20 seeds 7050 151 0.35 20.4

100 seeds 7050 151 0.16 518

1000 seeds 7050 151 0.05 8.58E+05

20 insects 705 0 1356 3.16 1.04

100 insects 705 0 1356 1.42 1.41

1000 insects 7050 1356 0.45 9.61

20 short grasses 7050 2410 5.62 1.00

100 short grasses 705 0 2410 2.52 1.08

1000 short grasses 7050 2410 0.80 2.76

Mammals 15 seeds 2.94E+05 151 0.01 1.00E+16

35 seeds 2.94E+05 151 0.01 1.00E+16

1000 seeds 2.94E+05 151 0.01 1.00E+16

15 insects 2.94E+05 1356 0.55 8.24

35 insects 2.94E+05 1356 0.48 13.2

1000 insects 2.94E+05 1356 0.25 297

15 short

grasses

2.94E+05 2410 0.99 2.03

35 short grasses 2.94E+05 2410 0.85 2.66

1000 short grasses 2.94E+05 2410 0.45 16.9

Reptiles, and

Terrestrial

Amphibians

20 insects 2.94E+05 1356 3.16 1.04

100 insects 2.94E+05 1356 1.42 1.41

1000 insects 2.94E+05 1356 0.45 9.61

20 short grasses 2.94E+05 2410 5.62 1.00

100 short grasses 2.94E+05 2410 2.52 1.08
Table 4.14 Probability of Acute Mortality of an Individual, by Taxa Group and Body Weight,

Exposed at the Endangered Species LOC(1) and at the Highest Registered Use Rate (2.6 lbs a.i./A )

for Dodine

Taxa Body Wt

(g)

Dietary

Food Source

LOC(1) Exposure 2.6 lbs a.i./A Application

5 apps./ 7 day interval

Probability(2) of

effect at LOC

 (1 in ___)

EEC(3)

(ppm)

RQ(4) Probability(2) of

Effect at RQ

(1 in ___ )

Page 88 of 219

 1000 short grasses 2.94E+05 2410 0.80 2.76

At the estimated exposure levels for the highest registered use rate for dodine (5 applications at 7 day

intervals of 2.6 lbs. a.i./A) the probability of an individual being affected is greater than the acute

endangered species LOC for most taxonomic groups feeding on most dietary items (Table 4.14,

Probability of Effect at RQ). The exceptions are large (1 kg) seed-eating birds and all seed-eating

mammals (Table 4.14). For other dietary categories and taxa, the highest probability of an individual

being affected is found in small birds and small reptiles/amphibians that consume insects or short grasses;

these are near a 1 in 1 chance of effects. Generally, for all the taxa, the chance of effects is highest for

smaller body-sized organisms and for those that consume short grass or insects. Note that the upper limit

for the probability of effects is 1 in 1; which is equivalent to 100%.

Similar results as described in the preceding paragraph would be observed for other specified use rates for

dodine since there are similar use rates for a number of labeled crops. The exceptions are cherries,

strawberries and crab apples and shade trees in Oregon. These uses would result in lower probabilities of

individual effects, however, it should be noted that, with the exception of cherries, these are relatively

minor uses of dodine.

Since available data indicates that dodine is practically non-toxic to terrestrial invertebrates, the

probability of individual effects at the listed species LOC was not calculated. There is no evidence

available that suggests risk to terrestrial invertebrates associated with uses of dodine. However, it is

possible that some insects are more sensitive to dodine than honeybees. 

A thorough assessment of risks to terrestrial plants was not possible given the lack of Tier II plant toxicity

data. However, Tier I studies indicated that for some plants, effects > 25% may be expected for the

highest rates of dodine use. In cases where Tier II data is not available and Tier I studies indicate an

effect, risks to terrestrial plants are assumed. A robust assessment of risks to terrestrial plants requires

Tier II plant toxicity testing.

Uncertainties and Assumptions of the Probit Dose-Response Analysis
Page 89 of 219

Estimates of the probability of affecting individual organisms is based on extrapolation of very low

probability events and is associated with considerable uncertainty in the resulting estimates. To provide a

sense of possible probability values, the analysis was also conducted using the lower and upper 95%

confidence limits of the probit dose-response slope. For mammals, the default slope of 4.5 was used since

data were unavailable to generate a specific estimate of the probit dose-response slope. The lack of an

experimentally determined estimate increases the uncertainty. To explore possible bounds to such

estimates, upper and lower values (9 and 2) were used to calculate upper and lower estimates of the

effects probability associated with the listed species LOC. In addition to noting the relatively large

uncertainty bounds around the probabilities, care should be employed in interpreting these probabilities

beyond their intended purpose as an indication of a margin of safety, or lack there of, for the endangered

species risk estimates based on the quotient model.

4.2.5.2.3 Terrestrial and Aquatic Field Data

The screening assessment indicates that dodine use may potentially affect a variety of terrestrial and

aquatic receptors including birds, mammals, herpetofauna, aquatic invertebrates, molluscs, freshwater

fish, and aquatic plants. There are no field data or incident reports indicating poisoning of species from

these taxa associated with dodine use. However, a lack of documented incidents is not evidence that

poisonings have not or will not occur. Typically, field incident data is infrequent and can be ad-hoc. 

Moreover, many receptors may move from the site of poisoning precluding discovery, and given the

status of these populations, the probability of detecting an effect to an individual is extremely low. 
Page 90 of 219

4.2.5.2.4 Indirect Effects

Pesticides have the potential to cause indirect effects to endangered or threatened species by, for example,

perturbing forage or prey availability, altering the extent of nesting habitat, etc. The potential for indirect

effects is determined by comparing RQs to the listed species LOCs. If the RQ exceeds the listed species

LOC then there is the potential for indirect effects to listed species dependent on those taxa for which the

RQ exceeded the listed species LOC. 

For aquatic species potentially exposed to dodine, RQs exceeded the listed species acute risk LOCs to

varying degrees for freshwater fish, freshwater invertebrates, estuarine/marine invertebrates, saltwater

molluscs, and aquatic non-vascular plants. Aquatic non-vascular plants had the highest RQs and for all

uses of dodine, the probability of individual effects was 1 in 1

molluscs and freshwater fish showed lower probabilities of individual effects associated

with uses of dodine. 

Given the sensitivities of the aquatic taxa to dodine, indirect effects to listed species would be expected

most for species dependent on freshwater non-vascular (and perhaps vascular) plants and freshwater

invertebrates based on the results of the above analysis. Given that both aquatic plants and invertebrates

are important components of any aquatic ecosystem, indirect effects on a number of aquatic (and

terrestrial) listed species is possible. The most obvious indirect effects would likely relate directly to

reductions in food availability or habitat alterations associated with reduced aquatic plant and invertebrate

biomass. Other, less obvious, indirect effects might include disruptions of listed species life cycles if

certain life-cycle components are dependent on particular plant or invertebrate species. 

Although the analysis suggests that indirect effects to listed species associated with dodine use would be

dominated by effects on aquatic plants and invertebrates, there are some risks for fish, saltwater nonmolluscan invertebrates, and molluscs that may result in indirect effects as well. Representative species

from these taxa were less sensitive to dodine compared to aquatic plants and invertebrates; probability of

effects for these taxa ranged from 1 in 216 (saltwater invertebrates; apples) to more than 1 in a million. 

Nevertheless, the possibility of indirect effects to listed species dependent on saltwater invertebrates or

molluscs cannot be excluded. Importantly, with these taxa, the likelihood of indirect effects is increased

with higher use rates. 

For terrestrial species, the screening-level analysis indicated that, for most uses, dodine may cause

deleterious effects in exposed bird and mammal populations (i.e., acute and chronic LOCs are exceeded

for birds and mammals) (Section 4.1). This suggests potential concern for indirect effects on listed

organisms dependant upon vertebrate species (birds, mammals, reptiles and amphibians) as prey items. A

potential drop in vertebrate biomass associated with dodine use may reduce a significant portion of the

prey base. While it is likely that fields can be repopulated by immigrants and living breeders after the use

of pesticides, if the prey base is removed at a critical life-cycle juncture, over a large area or of if it is

removed for a long enough duration, some species may have difficulty meeting energy needs. Also, some

species may be particularly sensitive during reproductive or developmental periods. A starting point for

evaluating the potential risk of such a scenario would be to first identify listed species likely to occur in

dodine use areas, compare life histories of listed species in known dodine use areas and determine if use

is likely to overlap with a sensitive life-cycle component. 
Page 91 of 219

Based on the calculated probabilities ( Tables 4.13-4.14-2.3.5), it appears likely that some taxa for most

uses (birds, mammals, reptiles, terrestrial phase amphibians) will be affected by dodine. Therefore,

further analyses of indirect effects are warranted for the listed species that are dependent or partially

dependent on any of these taxonomic groups.

Because of the likelihood of direct impacts to birds and mammals under certain uses of dodine, there is

also a potential for indirect effects to some listed plant species through effects on pollinators. For

example, if avian pollinators are negatively impacted by dodine, use during the reproductive period of a

particular plant could reduce successful pollination. This particular indirect effect is dependent both on

pollinator species affected and on the timing and manner of dodine use. A preliminary analysis could

include first, identifying plants that could be at risk based on location and timing of pollination. Second,

identifying potential pollinators and whether they would be affected by the intended use of dodine as not

all uses may cause risk to all pollinators.

The information presented on indirect effects serves as a guide to establish the need for and extent of

additional analyses that may be performed using Services-provided “species profiles” as well as

evaluations of the geographical and temporal nature of the exposure to ascertain if a “not likely to

adversely affect” determination can be made. The degree to which additional analyses are performed is

commensurate with the predicted probability of adverse effects from the comparison of the dose-response

information with the EECs. The greater the probability that exposures will produce effects on a taxa, the

greater the concern for potential indirect effects for listed species dependant upon that taxa, and therefore,

the more intensive the analysis on the potential listed species of concern, their locations relative to the use

site, and information regarding the use scenario (e.g., timing, frequency, and geographical extent of

pesticide application).

4.2.5.2.5 Critical Habitat for Listed Species

In the evaluation of pesticide effects on designated critical habitat, consideration is given to the physical

and biological features (constituent elements) of a critical habitat identified by the U.S Fish and Wildlife

and National Marine Fisheries Services as essential to the conservation of a listed species and which may

require special management considerations or protection. The evaluation of impacts for a screening-level

pesticide risk assessment focuses on the biological features that are constituent elements and is

accomplished using the screening-level taxonomic analysis (risk quotients, RQs) and listed species levels

of concern (LOCs) that are used to evaluate direct and indirect effects to listed organisms.

The screening-level risk assessment has identified potential concerns for indirect effects on listed species

for those organisms dependant 

 light of the potential for indirect effects, the next step for EPA and the

Service(s) is to identify which listed species and critical habitat are potentially implicated. Analytically,

the identification of such species and critical habitat can occur in either of two ways. First, the agencies

could determine whether the action area overlaps critical habitat or the occupied range of any listed

species. If so, EPA would examine whether the pesticide's potential impacts on non-endangered species

would affect the listed species indirectly or directly affect a constituent element of the critical habitat. 

Alternatively, the agencies could determine which listed species depend on biological resources, or have

constituent elements that fall into the taxa that may be directly or indirectly impacted by the pesticide. 

Then EPA would determine whether use of the pesticide overlaps the critical habitat or the occupied
Page 92 of 219

range of those listed species.

This screening-level risk assessment for critical habitat provides a listing of potential biological features

that, if they are constituent elements of one or more critical habitats, would be of potential concern. 

These correspond to the taxa identified above as being of potential concern for indirect effects and

include the following

This list should serve as an initial step in problem formulation for further assessment of

critical habitat impacts outlined above, should additional work be necessary.

4.2.5.2.6 Listed Species Occurrence Associated with Dodine Uses

A preliminary analysis of the co-occurrence of listed species and proposed re-registration of dodine uses

was conducted using EFED’s LOCATES database. The objective was to provide insight into the

potential for exposure of listed species and to identify those areas, crop uses, and listed species that

warrant further attention. A tabulation of the number of unique listed species that occur in the vicinity of

dodine use, by crop and by state is provided in

By this tabulation there are a total of potentially 796 listed species in counties where dodine can be used. 

Listed plant species account for almost half of this total followed by fish, clams, and birds and the other

taxa. Although a lack of Tier II plant studies precludes a thorough assessment of the risks to terrestrial

plants, at the very least, indirect effects on listed plant species are possible via direct effects on avian

pollinators. Listed fish species are the second most numerous. The screening-level analysis indicated

that the acute risk LOCs for freshwater fish were only exceeded for uses of dodine on apples. Most listed

fish species (94%), however, are associated with or are in the vicinity of apple orchards. Currently, none

of the listed taxa in Tables 4.15 and 4.16 can be discounted since for many, direct effects are expected

and, in addition, indirect effects may be important for some species in all taxa given the risks of dodine to

aquatic plants and invertebrates.

In terms of states in which dodine might be used, a total of 46 states have listed species and crops for

which dodine may be used. California has the highest number (271) of listed species that may co-occur

with dodine use areas. Alabama is the second highest with 87 total species followed by Florida with 79,

Tennessee with 70 and Texas with 65. 

No estimate of the overlap of dodine use with special local needs for Oregon was conducted since those

particular crops (crab apples, ornamental shade trees) were not listed in the LOCATES database.

In general, for all labeled uses of dodine there is at least one, and usually more, listed species that may

potentially occur in or near a use area. Appendix G lists the occurrence in each state of counties that have

a listed species of a specified taxa and the total list of endangered species that may co-occur with labeled

uses of dodine and a comprehensive list of species in counties where dodine may be used. This

preliminary analysis indicates that there is a potential for dodine use to overlap with listed species and

that a more refined assessment is warranted. The more refined assessment should involve clear

delineation of the action area associated with uses of dodine and best available information on the

temporal and spatial co-location of listed species with respect to the action area. This analysis has not
Page 93 of 219

been conducted for this assessment.

Table 4.15 Tabulation by Taxonomic Group and Crop of Listed Species that Occur in

Proposed Re-registration Dodine Use Areas.

Crop

Taxonomic Group

BirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants

Total

Apples 33 48 23 17 103 19 9 38 25 68 335 718

Cherries, sweet 19 26 7 3 26 7 0 15 4 3 139 249

Cherries, tart 17 14 5 3 22 3 0 9 3 3 64 143

Peaches 35 49 26 16 82 16 11 36 20 68 318 677

Pears 31 44 22 15 70 11 11 33 12 41 276 566

Pecans 31 35 20 15 65 11 10 18 15 48 179 447

Strawberries 28 36 18 9 45 14 0 28 5 40 240 463

Walnuts 14 26 8 6 20 8 0 19 1 0 165 267

Total Unique Species 38 55 28 18 109 19 11 41 26 70 381 796

Total States 46 44 18 11 39 11 3 23 11 27 46

Table 4.16 Tabulation by State and Taxonomic Group of Listed Species that Occur in

Proposed Re-registration Dodine Use Areas.

State

Taxonomic Group

BirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants

Total

Alabama 4 4 5 3 14 1 10 29 17 87

Arizona 8 8 2 2 15 1 13 49

Arkansas 3 3 3 2 1 1 6 4 23

California 15 21 8 6 23 8 20 1 169 271

Colorado 2 2 5 6 15

Connecticut 3 2 1 1 1 2 10

Delaware 22 1 2 7
Table 4.16 Tabulation by State and Taxonomic Group of Listed Species that Occur in

Proposed Re-registration Dodine Use Areas.

State

Taxonomic Group

BirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants

Total

Page 94 of 219

Florida 9 8 10 1 4 1 1 7 38 79

Georgia 4 2 2 1 7 1 15 15 47

Idaho 1 3 5 4 3 16

Illinois 3 2 1 1 2 1 1 6 17

Indiana 1 2 1 1 9 14

Iowa 1 1 1 2 5 10

Kansas 4 2 4 1 2 13

Kentucky 3 2 3 1 17 5 31

Louisiana 4 2 2 2 2 1 13

Maine 3 2 2 3 10

Maryland 1 3 2 2 1 6 15

Massachusetts 3 2 1 1 3 3 13

Michigan 2 2 1 3 2 6 16

Minnesota 21 14 8

Mississippi 6 1 5 1 3 3 2 21

Missouri 2 2 6 1 4 7 22

Montana 12 2 2 7

Nebraska 3 14

Nevada 1 1 8 1 7 18

New Hampshire 11 1 12 6

New Jersey 3 2 1 5 11

New Mexico 5 5 1 1 11 1 2 12 38

New York 3 2 1 1 1 6 14

North Carolina 6 5 1 3 1 4 25 45 

Ohio 1 1 1 1 1 5 4 14

Oklahoma 7 3 4 1 2 2 19

Oregon 5 1 18 2 1 10 37

Pennsylvania 22 22 8

Rhode Island 12 1 1 2 7
Table 4.16 Tabulation by State and Taxonomic Group of Listed Species that Occur in

Proposed Re-registration Dodine Use Areas.

State

Taxonomic Group

BirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants

Total

Page 95 of 219

South Carolina 4 3 2 2 1 1 18 31

South Dakota 3 1 15

Tennessee 3 4 14 1 1 3 26 18 70

Texas 11 3 3 4 6 1 10 8 19 65

Utah 2 2 1 8 17 30

Vermont 11 12 5

Virginia 1 5 1 1 4 1 12 11 36

Washington 4 4 15 6 29

West Virginia 12 114 9

Wisconsin 11 2 1 5

Total Unique

Species

38 55 28 18 109 19 11 41 26 70 381 796

4.3 Description of Assumptions, Limitations, Uncertainties, Strengths and Data Gaps

4.3.1 Assumptions and Limitations Related to Exposure for all Taxa

This screening-level risk assessment relies on proposed labeled statements of the maximum rate of dodine

application, the maximum number of applications, and the shortest interval between applications. The

frequency at which actual uses approach these maxima is dependant on agricultural conditions (presence

of fungi) and market forces.

4.3.2 Assumptions and Limitations Related to Exposure for Aquatic Species

Although there are uncertainties associated with using the standard PRZM/EXAMS runoff scenario (10

ha field draining into 20,000 m3

 pond with no outlet) for an aquatic exposure assessment, it is designed to

represent pesticide exposure from an agricultural watershed impacting a vulnerable aquatic environment. 

Extrapolating the risk conclusions from this standard pond scenario may either underestimate or

overestimate the potential risks.
Page 96 of 219

Major uncertainties associated with the standard runoff scenario include the physical construct of the

watershed and representation of vulnerable aquatic environments for different geographic regions. The

physicochemical properties (pH, redox conditions, etc.) of the standard farm pond are based on a Georgia

farm pond. These properties are likely to be regionally specific because of local hydrogeological

conditions. Any alteration in water quality parameters may impact the environmental behavior of a

pesticide. The farm pond represents a well mixed, static water body. Because the farm pond is a static

water body (no flow through), it does not account for pesticide removal through flow through or water

releases. The lack of flow through the farm pond provides an environmental condition for accumulation

of persistent pesticides. The assumption of uniform mixing does not account for stratification due to

thermoclines (e.g., seasonal stratification in deep water bodies). Additionally, the dimensions of the

standard runoff scenario assumes a watershed area to water body volume ratio of 10 ha: 20,000m3

. This

ratio is recommended to maintain a sustainable constructed pond in the Southeastern United States. The

use of higher watershed area to water body volume ratios (as recommended for sustainable ponds in drier

regions of the United States) may lead to higher pesticide concentrations when compared to the standard

watershed area to water body volume ratio.

The standard runoff scenario assumes uniform soils and agronomic management practices across the

standard 10 hectare field. Soils can vary substantially across even small areas; this variation is not

reflected in the model simulations. Additionally, the impact of unique soil characteristics and soil

management practices (e.g., tile drainage) are not considered in the standard runoff scenario. The

assumption of uniform site and management conditions is not expected to represent some site-specific

conditions. Extrapolating the risk conclusions from the standard pond scenario to other aquatic habitats

(e.g., marshes, streams, creeks, and shallow rivers, intermittent aquatic areas) may either underestimate or

overestimate the potential risks in those habitats.

4.3.3 Assumptions and Limitations Related to Exposure for Terrestrial Species

4.3.3.1 Location of wildlife species

For screening terrestrial risk assessments for listed species, a generic bird or mammal is assumed to

occupy either the treated field or adjacent areas receiving pesticide at a rate similar to the treatment rate

on the field. This assumption leads to an overestimation of exposure to species that do not occupy the

treated field. For screening risk assessment purposes, the actual habitat requirements of any particular

terrestrial species are not considered, and it assumed that species occupy, exclusively and permanently,

the treated area being modeled. This assumption leads to an overestimate of exposure in the risk

estimates fo a proportion of individuals of the exposed population. Although this estimate represents

higher levels of exposure, it is within the range of possibility as some species may occupy habitats near

the use site and use the use site to forage. Gorging can be a common opportunistic behavior in some

animals whereby food items are consumed in excess of the daily requirement due to availability. This

example is more likely to support an acute exposure scenario. Chronic exposure is more difficult to

ascertain since it occurs over a longer duration providing more opportunity for animals to move and seek

forage elsewhere. Nonetheless, many animals do forage over a range that would be included in

agricultural fields; all prey items for these species may come from agricultural use areas.

4.3.3.2 Routes of exposure
Page 97 of 219

Screening-level risk assessments for spray applications of pesticides consider dietary exposure alone. 

Other routes of exposure, not considered in this assessment, are discussed below:

4.3.3.2.1 Incidental soil ingestion exposure

This risk assessment does not consider incidental soil ingestion. Available data suggests that up to 15%

of the diet can consist of incidentally ingested soil depending on the species and feeding 

A simple first approximation of soil concentration of pesticide from spray application

shows the effect of not considering incidental soil ingestion:

 For example a

20 g birds consumes approximately 22.8 g food daily. The amount of dodine ingested from short grass is

approximately 50 mg (22.8 g food consumed x 2224 ppm in food). The amount of dodine ingested as a

result of incidental soil ingestion is approximately 0.1 mg (0.15 x 22.8 x 29 ppm), which represents about

0.2% of the total exposure due to eating dodine-contaminated food-items. 

4.3.3.2.2 Inhalation exposure

The screening risk assessment does not consider inhalation exposure. Such exposure may occur through

three potential sources: (1) spray material in droplet form at the time of application (2) vapor phase

pesticide volatilizing from treated surfaces, and (3) airborne particulate (soil, vegetative material, and

pesticide dusts).

Available data suggest that inhalation exposure at the time of application is not an appreciable route of

exposure for birds. According to research on mallards and bobwhite quail, respirable particle size in birds

(particles reaching the lung) is limited to a maximum diameter of 2 to 5 microns . The spray

droplet spectra covering the majority of pesticide application situations (AgDrift model scenarios for

very-fine to coarse droplet applications) suggests that less than 1% of the applied material is within the

respirable particle size. However, the particles still may be ingested, and the model does not address this.

Theoretically, inhalation of pesticide active ingredient in the vapor phase may be another source of

exposure for some pesticides under some exposure situations. Considering dodine’s low vapor pressure,

it is unlikely that dodine will exist in the gaseous phase at any considerable amount to cause any adverse

effects via inhalation.
Page 98 of 219

The impact from exposure to dusts contaminated with the pesticide cannot be assessed generically as

partitioning issues related to application site soils and chemical properties render the exposure potential

from this route highly situation specific.

4.3.3.2.3 Dermal exposure

The screening assessment does not consider dermal exposure, except as it is indirectly included in

calculations of RQs based on lethal doses per unit of pesticide treated area. Dermal exposure may occur

through three potential sources: (1) direct application of spray to terrestrial wildlife in the treated area or

within the drift footprint, (2) incidental contact with contaminated vegetation, or (3) contact with

contaminated water or soil.

The available measured data related to wildlife dermal contact with pesticides are extremely limited. The

Agency is actively pursuing modeling techniques to account for dermal exposure via direct application of

spray and by incidental contact with vegetation.

4.3.3.3 Incidental Pesticide Releases Associated with Use

This risk assessment is based on the assumption that the entire treatment area is subject to dodine

application at the rates specified on the label. In reality, there is the potential for uneven application of

dodine through such plausible incidents as changes in calibration of application equipment, spillage, and

localized releases at specific areas of the treated field that are associated with specifics of the type of

application equipment used (e.g., increased application at turnabouts when using older ground application

equipment).

4.3.3.4 Residue Levels Selection

As discussed earlier in the exposure section of this document, the Agency relies on the work of Kenaga

and Fletcher et al. (1994) for setting the assumed pesticide residues in wildlife dietary items. The Agency

believes that these residue assumptions reflect a realistic upper-bound residue estimate, although the

degree to which this assumption reflects a specific percentile estimate is difficult to quantify. It is

important to note that the field measurement efforts used to develop the Fletcher estimates of exposure

involve highly varied sampling techniques. It is entirely possible that much of these data reflect residues

averaged over entire above ground plants in the case of grass and forage sampling. Depending upon a

specific wildlife species’ foraging habits, whole aboveground plant samples may either underestimate or

overestimate actual exposure.

4.3.3.5 Dietary Intake - The Differences Between Laboratory and Field Conditions

The acute and chronic characterization of risk rely on comparisons of wildlife dietary residues with LC50

or NOAEC values expressed in concentrations of pesticides in laboratory feed. These comparisons

assume that ingestion of food items in the field occurs at rates similar to those in the laboratory. 

Although the screening assessment process adjusts dry-weight estimates of food intake to reflect the
Page 99 of 219

increased mass in fresh-weight wildlife food intake estimates, it does not allow for gross energy and

assimilative efficiency differences between wildlife food items and laboratory feed.

On gross energy content alone, direct comparison of a laboratory dietary concentration- based effects

threshold to a fresh-weight pesticide residue estimate would result in an underestimation of field exposure

by food consumption by a factor of 1.25 - 2.5 for most food items. Only for seeds would the direct

comparison of dietary threshold to residue estimate lead to an overestimate of exposure.

Differences in assimilative efficiency between laboratory and wild diets suggest that current screening

assessment methods do not account for a potentially important aspect of food requirements. Depending

upon species and dietary matrix, bird assimilation of wild diet energy ranges from 23 - 80%, and mammal

assimilation of diet ranges from 41 - 85% ( ). If it is assumed that laboratory chow is

formulated to maximize assimilative efficiency (e.g., a value of 85%), a potential for underestimation of

exposure may exist by assuming that consumption of food in the wild is comparable with consumption

during laboratory testing. In the screening process, exposure may be underestimated because metabolic

rates are not related to food consumption.

Finally, the screening procedure does not account for situations where the feeding rate may be above or

below requirements to meet free living metabolic requirements. Gorging behavior is a possibility under

some specific wildlife scenarios (e.g., bird migration) where the food intake rate may be greatly

 has suggested that an upper-bound limit to this behavior might be the typical

intake rate multiplied by a factor of 5.

In contrast, there is the potential for avoidance, operationally defined as animals responding to the

presence of noxious chemicals in their food by reducing consumption of treated dietary elements. This

response is seen in nature where herbivores avoid plant secondary compounds. However, reduced food

intake, particularly over an extended period, could result in reduced survival or reproductive output.
Page 100 of 219

4.3.4 Assumptions and Limitations Related to Effects Assessment

4.3.4.1 Age class and sensitivity of effects thresholds

4.3.4.3 Use of the Most Sensitive Species Tested

Although the screening risk assessment relies on a selected toxicity endpoint from the most sensitive

species tested, it does not necessarily mean that the selected toxicity endpoints reflect sensitivity of the

most sensitive species existing in a given environment. The relative position of the most sensitive species

tested in the distribution of all possible species is a function of the overall variability among species to a

particular chemical. The relationship between the sensitivity of the most tested species versus wild

species (including listed species) is unknown and a source of significant uncertainty. The use of

laboratory species has historically been driven by availability and ease of maintenance. A widespread

comparison of species is lacking, however, even variation within a species can be quite high. For

example, in this assessment, acute studies on waterfleas yielded three different values. Granted these

were within an order of magnitude but examples exist where differences have been more extreme. 
Page 101 of 219

4.3.4.4 Data Gaps

The major data gap is the lack of aquatic vascular plant toxicity studies and registrant submitted Tier II

terrestrial plant studies. For dodine, the only registrant-submitted aquatic plant study was on green algae

(Selenastrum capricornutum). Results from this study indicate that dodine is highly to green alga

(Selenastrum capricornutum), however, there is insufficient data to generate a suitable understanding of

the toxicity of dodine to aquatic plants. 

argue for a robust

understanding of the chronic toxicity of dodine to estuarine/marine invertebrates. To generate robust

estimates of risk for estuarine/marine fish and invertebrates, chronic toxicity studies on representative

species from these taxa are required.

4.3.5 Assumptions Associated with the Acute LOCs
Page 102 of 219

LITERATURE CITED

Burns, Lawrence, 2004. Exposure Analysis Modeling System (EXAMS): User Manual and System

Documentation. Ecosystem Research Division, National Exposure Research Laboratory. U. S.

Environmental Protection Agency, Athens, GA.

Cabral, J.P.S. 1991. Damage to the Cytoplasmic Membrane and Cell Death Caused by Dodine

(Dodecylganidine Monoacetate) in Pseudomonas syringae ATCC 12271. Antimicrobial Agents

and Chemotherapy 35(2):341-344.

Carsel, R. F., J. C. Imhoff, P. R. Humel, J. M. Cheplick, and A. S. Donigian, Jr. 1997. PRZM-3, A Model

for Predicting Pesticide and Nitrogen Fate in the Crop Root and Unsaturated Zones: User’s

Manual for Release 3.0. National Exposure Research Laboratory, Office of Research and

Development, U. S. Environmental Protection Agency, Athens, GA.

Dodine. Hazardous Substances Data Bank. 2005. http://toxnet.nlm.nih.gov. 

Environmental Fate and Effects Division. 2002. Guidance for Selecting Input Parameters in Modeling the

Environmental Fate and Transport of Pesticides, Version II. U. S. Environmental Protection

Agency. Washington, D.C. 

http://www.epa.gov/oppefed1/models/water/input_guidance2_28_02.htm

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA

food-chain (Kenaga) nomogram, and instrument for estimating pesticide residues on plants.

Environmental Toxicology and Chemistry 13 (9):1383-1391.

Gianessi, L.P. and M.B. Marcelli. 2000. Pesticide Use in U.S. Crop Production: 1997 National Summary

Report. National Center for Food and Agricultural Policy, Washington D.C.

http://www.ncfap.org/database/default.htm 

Hoerger, F., and E.E. Kenaga. 1972. Pesticide residues on plants: Correlation of representative data as a

basis for estimation of their magnitude in the environment. In F. Coulston and F. Korte, eds.,

Environmental Quality and Safety: Chemistry, Toxicology, and Technology, Georg Thieme Publ,

Stuttgart, West Germany, pp. 9-28.

Kirkwood, J.H. 1983. A limit to metabolizable energy intake in mammals and birds. Comp. Biochem.

Physiol. 75A:1-3.

OPP EFED. 1999. Downwind Deposition Tolerance Bounds for Orchards. Scientific Advisory Panel

background document. http://www.epa.gov/scipoly/sap/1999/july/airblast.pdf.

Relyea, R.A. 2005. Impacts of Insecticides and Herbicides on the Biodiversity and Productivity of

Aquatic Communities. Ecological Applications 15(2): 618-627.
Page 103 of 219

Sharma, D.P., D.C. Ferree, and F.O. Harman. 1977. Multiple Applications of Dicofol and Dodine Sprays

on Net Photosynthesis of Apple Leaves. Hortscience 12(2): 154-155.

Teske, M., S.L. Bird, D.M. Esterly, S.L. Ray, and S.G. Perry. 2001. A User’s Guide for AgDRIFT 2.01:

A Tiered Approach for the Assessment of Spray Drift of Pesticides. Spray Drift Task Force. 

Macon, MO.

Thelin, G.P and L.P Gianessi. 2000. Method for Estimating Pesticide Use for County Areas of the

Conterminous United States. U.S. GEOLOGICAL SURVEY. Open-File Report 00-250.

Sacramento, CA. http://ca.water.usgs.gov/pnsp/pesticide_use_maps_1997/ 

U.S. EPA. 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide

Programs. Office of Prevention, Pesticides and Toxic Substances. Office of Pesticides Programs. 

Washington, DC. January 23, 2004.

U.S. EPA. 1998. Guidelines for Ecological Risk Assessment. Risk Assessment Forum, Washington, DC.

EPA 630/R-95/002F April 1998.

U.S. EPA. 1993. Wildlife Exposure Factors Handbook. EPA/600/R-13/187a, Office of Research and

Dvelopment, Washington, D.C. 

U.S. EPA. 1990. Laboratory Test Methods of Exposure to Microbial Pest Control Agents by the

Respiratory Route to Nontarget Avian Species. Environmental Research Laboratory, Corvalis,

OR. EPA/600/3-90/070.

Willis, G.H., and L.L. McDowell. 1987. Pesticide Persistence on Foliage in Reviews of Environmental

Contamination and Toxicology. 100:23-73.

Wood, B.W. and J.A. Payne. 1985. Inhibition of Photosynthesis in Pecan Leaves by Fungicides. Plant

Disease 69: 997-998.
Page 104 of 219

APPENDIX A - Maximum Use Rates Based on Current Labels Compiled by BEAD
Table 1. Maximum Dodine use rates and management practices by crop based on current labels. 

(Generalized Screening Level Portrayal Of Current Label Uses)

Current As Of - 05/03/2004

Page 105 of 219

Use Site Max. Rate

per App

 Max. Rate

 Unit/Area

*UG 

Form Max.#

Apps

cc & yr 

Max. App

Rate/

cc & yr 

 Min. App

 Interval

 (days) 

 Application Equipment

 //Type

(Reg # Code)

NON-FOOD/NON-FEED USES

cherry .3400~ lb A FlC 1/1 yr NS 7 Aircraft/ Sprayer 

//Low volume spray 

(concentrate)/ Spray (a)

 .3400~ lb A FlC NS NS 7 Aircraft/ Sprayer 

//Low volume spray 

(concentrate)/ Spray (b)

crabapple .3400~ lb A FlC NS NS 5 Aircraft/ Sprayer 

//Low volume spray 

(concentrate)/ Spray (a)

ornamental and/or shade trees .8500~ lb A FlC NS NS 10 Aircraft/ Sprayer 

//Low volume spray 

(concentrate)/ Spray (a)

FOOD/FEED USES

apple 1.95 lb A WP NS NS 5

AN

NS 

Aircraft/ High volume ground 

sprayer/ Low volume ground 

sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

cherry 1.275 lb A FlC 1/1 yr NS 7 High volume ground sprayer/ 

Low volume ground sprayer/ 

Sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

 1.6 lb A D NS NS 7 Aircraft/ Ground 

//Dust (b)

peach 1.275 lb A FlC 1/1 yr NS NS High volume ground sprayer/ 

Low volume ground sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

 2.6 lb A WP NS NS 7

NS 

High volume ground sprayer/ 

Low volume ground sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (b)

pear 1.95 lb A WP 6/cc NS 5 Aircraft/ High volume ground 

sprayer/ Low volume ground 

sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

 1.95 lb A WP NS NS 5 Aircraft/ High volume ground 
Table 1. Maximum Dodine use rates and management practices by crop based on current labels. 

(Generalized Screening Level Portrayal Of Current Label Uses)

Current As Of - 05/03/2004

Use Site Max. Rate

per App

 Max. Rate

 Unit/Area

*UG 

Form Max.#

Apps

cc & yr 

Max. App

Rate/

cc & yr 

 Min. App

 Interval

 (days) 

 Application Equipment

 //Type

(Reg # Code)

Page 106 of 219

sprayer/ Low volume ground 

sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (b)

pecan 2.6 lb A WP NS NS 10

AN 

Aircraft/ High volume ground 

sprayer/ Low volume ground 

sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

strawberry 1.3 lb A WP NS NS 7 High volume ground sprayer 

//High volume spray (dilute) (a)

use 03009 2.6 lb A WP NS NS 10 High volume ground sprayer/ 

Low volume ground sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

walnut (english/black) 2.6 lb A WP NS NS 10 High volume ground sprayer/ 

Low volume ground sprayer 

//High volume spray (dilute)/

Low volume spray 

(concentrate) (a)

Use Site/Registration Number(s) for Maximum Dosages with Reg # Codes

NON-FOOD/NON-FEED USES

cherry OR04002500(a,b)

crabapple OR04002500(a)

ornamental and/or shade trees OR04002500(a)

FOOD/FEED USES

apple 241-51(a), 55260-5(a)

cherry 34704-153(b), 55260-6(a)

peach 241-51(b), 55260-5(b), 55260-6(a)

pear 241-51(b), 55260-5(a)

pecan 241-51(a), 55260-5(a)

strawberry 241-51(a), 55260-5(a)
Table 1. Maximum Dodine use rates and management practices by crop based on current labels. 

(Generalized Screening Level Portrayal Of Current Label Uses)

Current As Of - 05/03/2004

Page 107 of 219

use 03009 241-51(a)

walnut (english/black) 55260-5(a)
Page 108 of 219

LEGEND

HEADER ABBREVIATIONS

Use Site : The use site refers to the entity (crop, building, surface or article) where a 

 pesticide is applied and/or which is being protected. 

Max.Rate per App : Maximum dose for a single application to a single site. System calculated. 

Max.Rate Unit/Area : Units and Area associated with the maximum dose. 

*UG : Use Group codes. 

Form : The physical form of the end use product found in the container. 

Max. # Apps cc & yr : The maximum number of applications. 

Max. App Rate/cc & yr : The maximum amount of pesticide product that can be applied to a site in one 

 growing season (/cc) or during the span of one year (/yr). 

Min. App Interval (days): The minimum retreatment interval between applications in days (aggregated). 

Application Equipment : The equipment used to apply pesticide (aggregated). 

Application Type : The type of pesticide application (aggregated). 

Current as of - : The label data for the listed products in this report is current as of this date. 

ABBREVIATIONS

AN - As Needed. 

NA - Not Applicable. 

NS - Not Specified (on label). 

(L) - The dosage information provided is from the label in terms of product (e.g., ounces, gallons, or 

 pounds of the product) because there was insufficient information (e.g., missing density, area, or 

 active ingredient percentages) to provide converted dosage information. 

~ - The tilde indicates a dosage that includes information from a SLN label. 

APPLICATION RATE

cwt :Hundred Weight. 

nnE-xx :nn times (10 power -xx), for instance, "1.234E-4" is equivalent to ".0001234". 

-- :No description available in LUIS unit conversion vocabulary. 

FORMULATION CODES

D : Dust 

FlC : Flowable Concentrate 

WP : Wettable Powder 
Page 109 of 219

APPENDIX B. ENVIRONMENTAL FATE DATA

Abiotic Degradation

Hydrolysis

Dodecylguanidine HCl is stable to hydrolysis at environmentally relevant pHs and temperatures. In a

hydrolysis study conducted for 30 days in darkness at 25°C, dodecylguanidine HCl (14C-radio-labeled in

the guanidine moiety) at a concentration of 10 μg/mL did not hydrolyze in sterile pH 5, 7 and 9 aqueous

buffer solutions (MRID 42242601). Although material balances were occasionally variable,

dodecylguanidine HCl was the only compound detected following HPLC separation with UV detection.

The half-lives reported in the study (576 days @ pH 5, 914 days @ pH 7, and 1198 days @ pH 9) are of

questionable value, as they were extrapolated beyond the scope of the data (i.e., far beyond the 30-day

study). The submitted study was classified as acceptable and provides adequate data for the risk

assessment. 

Aqueous Photolysis

Dodecylguanidine HCl did not photograde in water under favorable light conditions. 14C-Radiolabeled

dodecylguanidine HCl at 12 μg/mL did not appreciably photodegrade in sterile pH 5 aqueous buffered

solution maintained at 25°C and irradiated continuously with a xenon arc lamp for 30 days (MRID

42419001). At 30 days posttreatment, 14C-dodecylguanidine comprised $95.9% of the organosoluble

residues; no other 14C-compounds were detected. The half-life calculated by the authors of the study (770

days vs 1004 days for the dark control) is of questionable value, as it was extrapolated beyond the scope

of the data. The study was classified as acceptable and provides useful data for the risk assessment. 

Dodine is stable to photolysis under environmental light conditions. 14C-Radiolabeled dodine decreased

from 91.0% of the applied at day 0 to 82.1% at 30 days in sterile pH 7 aqueous buffered solution

maintained at 25°C and irradiated continuously with a xenon arc lamp for 30 days (MRID 46438203). 

One transformation product was identified as guanidine (Rt 2.1-2.7 minutes) and was a maximum 14.7%

and 7.3% of the applied in the irradiated solutions and in the dark controls, respectively . The

environmental half-life calculated by the reviewer of the study (641 days) is of questionable value, as it

was extrapolated beyond the scope of the data. The study was classified as acceptable and provides

useful data for the risk assessment. 

Soil Photolysis

Dodine is stable to photolysis under environmental light conditions. 14C-Radiolabeled dodine decreased

from 89.4% of the applied at day 0 to 71.4% at 30 days in a sandy loam soil [pH 6.2, organic matter

0.44%] from California maintained at 25 ± 3°C and irradiated on a twelve hour light/dark cycle using a

UV-filtered xenon lamp (MRID 46438204). No major transformation products were identified. The

environmental half-life calculated by the reviewer of the study (239 days) is of questionable value, as it

was extrapolated beyond the scope of the data. The study was classified as acceptable and provides

useful data for the risk assessment. 
Page 110 of 219

Metabolism

Aerobic Soil Metabolism

Dodine is metabolized in soil under aerobic conditions (MRID 43945201). Dodine, radiolabeled on the

guanidine carbon (14C-guanidine), was added to flasks containing a high organic sandy loam soil (pH 5.3,

organic carbon 2.2%) from the UK and a low organic sandy loam soil (pH 5.9, organic carbon 0.6%)

from Mississippi at approximately the a nominal rate of 2.5 mg a.i./kg. Volatiles and carbon dioxide were

collected in ethylene glycol and potassium hydroxide, respectively, over a period of 100 days. The soils

were extracted at intervals, and the extracts were analyzed. Recoveries of applied radioactivity were

generally 90-110%. The major metabolite trapped in potassium hydroxide was carbon dioxide, 91-92%

of the applied dose. The percent of material in the soil extract fell with time from 90% on day 0 to 3% at

day 100. The half lives in the US and UK soils were 22.3 (r2

 = 0.76) and 17.5 (r2 = 0.91) days,

respectively, calculated by log-linear regression. Degradates were not identified. The study was

classified as acceptable and provides useful data for the risk assessment. 

Anaerobic Soil Metabolism

No studies were conducted on anaerobic soil metabolism.

Aerobic Aquatic Metabolism

Dodecylguanidine HCl is metabolized slowly in flooded soil under aerobic conditions. [14C]-

dodecylguanidine HCl (radiolabeled in the guanidine moiety), at 12 ppm, degraded by 9.6% in aerobic

sandy loam soil that was incubated in the dark at 25±1°C for 30 days (MRID 42327401). At 30 days,

extractable 14C-labeled soil residues were 87.3% of the applied, and dodecylguanidine HCl averaged

98.5% of the extractable residues. Unextracted soil 14C residues were 5.3% of the applied, with 93.9, 4.8,

and 1.4% in the humin, humic acid, and fulvic acid fractions, respectively. 14C residue in the floodwater

was 0.75%. A 14C compound present in the floodwater at 0.01 ppm could not be identified. Floodwater 14CO2 averaged 2.3%. Based on the results of the study, microbially mediated metabolism of

dodecylguanidine HCl in flooded aerobic soil is expected to proceed slowly in the environment. The

half-life reported in the study (227 days) is of questionable value, as it was extrapolated beyond the scope

of the data (i.e., beyond the 30-day study). This study was classified as acceptable and provides adequate

data for the risk assessment.

Dodine is metabolized in flooded soil under aerobic conditions. [14C]-dodecylguanidinium acetate

(radiolabeled in the guanidine moiety) was studied in lake water-silt loam sediment and pond waterloamy sand/sand sediment systems from The Netherlands for 84 days under aerobic conditions in

darkness at 20 ± 2°C (MRID 46438202). The sediment extraction method consisted of organic solvents

(methanol/dichloromethane/ n-hexane) and resulted in a substantial proportion of nonextractable residues. 

 Since dodine is a salt of a strong base, an acid/base extraction method (e.g., KOH in methanol/HCl in

methanol), as used in the aerobic soil metabolism study (MRID 4394520) and the aerobic aquatic

metabolism study for dodecylguanidine HCl (MRIDs 42327401, 42414601), would have been the

preferred extraction method. Therefore, sediment and total system half-lives were calculated assuming

the nonextractables were non-degraded parent dodine. 
Page 111 of 219

In a lake water-silt loam sediment systems, [14C]dodine in the total system declined from 92.81% of the

applied radioactivity at time 0 to 60.34% at 0.2 days (5 hours) to 21.76% at 1 day to 15.20% at 2 days to

5.03% at 5 days and was 0.32-1.75% at 9-84 days posttreatment (final sampling interval). In the water

layers, [14C]dodine declined from 92.81% at time 0 to 55.70% at 0.2 days (5 hours) to 16.63% at 1 day to

9.98% at 2 days to 1.36% at 5 days and was not reported at 9-84 days. In the sediments, [14C]dodine was

measured at 3.67-5.22% at 0.2-5 days and was 0.32-1.75% at 9-84 days. In the water layer, the

transformation product M2 averaged a maximum of 10.08% of the applied radioactivity at 2 days

posttreatment (last sampling interval analyzed), and M1 (tentatively identified as urea) and M3 were

2.91% and 3.72% at 1 day, respectively. No transformation products were isolated from the sediment. 

Extractable [14C]residues were 3.7-7.2% of the applied at 0.2-9 days and declined to 0.8% at 84 days. 

Nonextractable [14C]residues were a maximum of 57.7% of the applied at 1 day, declined to 21.7-23.0%

at 20-48 days, and were 33.4% at 84 days. Assuming the nonextractable residues are parent dodine,

results in a total system half-life of 59.8 days.

In the pond water-loamy sand/sand sediment systems, [14C]dodine in the total system declined from

96.73% of the applied radioactivity at time 0 to 57.44% at 0.2 days (5 hours) to 26.44% at 2 days to

5.17% at 5 days and was 0.43-1.17% at 20-84 days posttreatment (final sampling interval). In the water

layers, [14C]dodine declined from 96.73% at time 0 to 29.93% at 0.2 days (5 hours) to 10.59% at 1 day to

5.16% at 2 days to 0.46% at 5 days and was not reported at 9-84 days. In the sediments, [14C]dodine

declined from 21.28-27.51% at 0.2-2 days to 3.37-4.71% at 5-8 days and was 0.43-1.17% at 20-84 days. 

In the water layer, the transformation product M2 averaged a maximum of 13.95% of the applied

radioactivity at 2 days posttreatment (last sampling interval analyzed), and M1 (tentatively identified as

urea) and M3 were 4.63% and 4.50% at 0.2 days, respectively. No transformation products were isolated

from the sediment. Extractable [14C]residues were 33.6% at 0.2 days posttreatment, declined to 8.2% at 5

days, and were 0.8% at 84 days. Nonextractable [14C]residues were a maximum of 34.6% at 1 day

posttreatment, declined to 9.4% at 20 days, and were 13.8% at 84 days. Assuming the nonextractable

residues are parent dodine, results in a total system half-life of 38.9 days. This study was classified as

supplemental, but it’s scientifically valid and meets the requirements for an aerobic aquatic metabolism

study.

Anaerobic Aquatic Metabolism

Dodecylguanidine HCl is degraded very slowly in flooded soil under anaerobic conditions. The

biodegradation of 14C-dodecylguanidine HCl (radio-labeled in the guanidine moiety) was studied in sandy

loam soil under anaerobic (nitrogen atmosphere) conditions in the dark at approximately 25°C for up to

12 months (MRID 42763001). Analyses for the parent compound were performed immediately posttreatment, at 1, 3, 7, and 14 days, and at 1, 2, 3, 4, 6, 9, and 12 months post-treatment. In the soil

substrate [14C]dodecylguanidine HCl comprised 86.5-95.6% of the applied immediately post-treatment,

ranged from 88.27 to 97.08% of the applied between 1 day and 9 months post-treatment (except for 79.8-

80.9% at 1 month) with no discernable pattern of decline, and comprised 77.8-82.8% at 12 months. 

Greater than 89% of the applied radioactivity was associated with the soil at all sampling intervals, and

[

14C]dodecylguanidine HCl comprised >95.6% of the radioactivity in the soil extracts at all sampling

intervals. Other 14C residues totaled 1.4-10.5% of the applied radioactivity through 30 days posttreatment (maximum at 0 days) and 0.6-1.5% at two through 12 months. Floodwater was not analyzed for

degradates prior to 3 months. At 3 through 12 months, 14C-dodecylguanidine HCl in floodwater was

#0.75% of that applied. At 12 months, 14CO2 was 0.69% of that applied.
Page 112 of 219

A nonvolatile degradate, n-dodecylamino hydroxymethanamine was isolated from both the soil extracts

and floodwater. This degradate accounted for 1.9-3.9% of the applied compound at 12 months posttreatment (degradates were not characterized at earlier time points). Another nonvolatile degradate was

present at approximately 1.2% in the soil at 12 months. This latter degradate was not identified.

Unextracted soil 14C residues in the 12-month sample were differentiated into humin, humic acid, and

fulvic acid fractions. The three respective fractions accounted for 8.7 (1.00 μg/g), 0.9 (0.10 μg/g), and

0.3% (0.04 μg/g) of the applied radioactivity.

Based on the results of this study, microbially mediated metabolism of dodecylguanidine HCl in

anaerobic aqueous conditions is expected to proceed very slowly in the environment. The half-life

reported in the study (2492 days) is of questionable value, as it was extrapolated beyond the time frame of

the 12-month study. In addition, 14C-residues in the floodwater were not accounted for. However, the

study is scientifically sound and provides useful data for the risk assessment. The study fails to meet

Subdivision N guidelines because radioactivity in the floodwater (approximately 7.1% of the applied

dose) was not characterized through 2 months posttreatment and one degradate was not identified.

Mobility and Persistence

Adsorption/Desorption

Based on soil adsorption coefficient (Kd) values determined using Freundlich adsorption isotherms with

batch equilibrium study data, dodecylguanidine HCl was determined to be immobile in soil, regardless of

soil organic matter content. No data were available for degradates. A single batch equilibrium study was

submitted for dodecylguanidine HCl (MRID 42148901); no data were submitted for dodine.

The soils were characterized as sand, sandy loam, clay loam, and silt loam. Organic carbon content and

pH were not stated. The soils and adsorption/desorption study results are presented in Table B1. The

adsorption and desorption of guanidine 14C-labeled- dodecylguanidine HCl was studied in four soils

treated at concentrations of 0.67, 0.365, 0.557, or 0.770 μg/mL and maintained in the dark at 25°C for 72

hours. The soil:solution suspensions (0.01 N calcium chloride) were equilibrated on a mechanical shaker

during the incubation. After the equilibration period, Freundlich Kads values were 6440 for the sand, 2202

for the sandy loam, 18,019 for the clay loam, and 15,228 for the silt loam soils; n values were 0.45, 0.51,

1.01, and 0.83, respectively. Desorption (Kdes) values were 294 for the sand, 3095 for the sandy loam,

2028 for the clay loam, and 760 for the silt loam soils. Koc values ranged from 5.51 x 105

 to 1.29 x 107 for

adsorption, and from 3.62 x 104

 to 7.74 x 105 for desorption. However, adsorption did not appear to be

correlated with organic matter content or clay. Material balances for the soil suspensions following

desorption ranged from 89.81 to 116.15% of the applied radioactivity. This study was classified as

acceptable and provides data on the mobility of unaged dodecylguanidine HCl. Data on aged

dodecylguanidine HCl and dodine were not submitted.
Page 113 of 219

Table B1. Freundlich adsorption and desorption constants for dodecylguanidine HCl in four

soils1

Soil type

(texture, OC %,

pH)

Adsorption Desorption

K (mL/g) n r2 K (mL/g) 1/n r2

sand (0.05%,

7.6)

6440 0.45 0.8770 294 2.22 0.9651

sandy loam (0.40

%, 6.5)

2202 0.51 0.9735 3095 1.96 0.9983

clay loam

(0.65%, , 6.4)

18019 1.01 0.9955 2028 0.99 0.8164

silt loam (2.1%,

7.4)

15228 0.83 0.9962 760 1.2 0.9845

Laboratory Volatility

No laboratory studies were conducted on volatility.

Field Volatility

Field studies of the volatility of dodine or dodecylguanidine HCl were not conducted. Based on the low

vapor pressure of both chemicals (1.5 x 10-7 mm Hg for dodine), volatilization is not expected to occur in

the field. 

Terrestrial Field Dissipation

Based on the results of a single terrestrial field dissipation study, dodine is expected to be non-persistent

in the field. The terrestrial field dissipation of dodine was studied in bareground plots (orchard use

pattern) at four U.S. sites. Dissipation was not fully considered in the study as degradates of dodine were

not analyzed (however, prior aerobic degradation studies had failed to show the presence of significant

amounts of metabolites). There was some variation in dissipation among and within sites and

rainfall/evaporation data were not always representative of normal site conditions, but, taken as a whole,

the study was scientifically valid. The parent compound did not leach through soil. 

The soil types were sand (Washington), loam (New Jersey), sand (Georgia), and loamy sand (California). 

Dodine was broadcast applied six times as a spray, at 7-day intervals, at a nominal rate of 1.95 lb a.i./acre

(total application 11.7 lb a.i./acre) (MRID 44985701). Following the sixth application, dodine dissipated

from the respective sites with observed first half-lives of <0.25 months, <0.25 months, between 0.25 and

0.5 months, and between 0.5 and 1 month (respective calculated first half-lives were 0.39 months, 0.28

months, 0.26 months, and 0.40 months. Dissipation was biphasic in all four plots, with an initial rapid

phase occurring during the first month post-treatment. 
Page 114 of 219

At all four sites, dodine was present primarily in the 0- to 6-inch depth. Dodine was not detected below 6

inches with the following exceptions: (1) 6- to 12-inch depth once at the New Jersey site and once at the

California site (each time, 1 of 4 replicates) and (2) 18-24-inch depth once at the Georgia site (1 of 4

replicates); all concentrations outside the 0- to 6-inch depth were #0.034 ppm. 

Table B2. Terrestrial field dissipation studies results (dodine).

MRID Soil Texture

(pH, organic

matter

content)

Target

Applic.

Rate

(lb

ai/A)

Site Plot Type Dissipation

Half-life (or

DT50) in

Soil 

(days)

Parent

Maximum

Leaching

Depth 

Major Degradates

& Maximum

Leaching Depth

Application

Type/

Formulation

44985701 sand (6.7;

1.2%)

11.71 WA bareground t1/2 = 12 0-6"2 Not applicable3 broadcast as a

spray

“ loam (6.0;

2.3%)

11.7 NJ bareground t1/2 = 8.4 0-6" Not applicable broadcast as a

spray

“ sand (7.1-7.4;

1.0-1.5%)

11.7 GA bareground t1/2 = 7.8 0-6" Not applicable broadcast as a

spray

“ loamy sand

(7.1; 0.5%)

11.7 CA bareground t1/2 = 12 0-6"4 Not applicable broadcast as a

spray

1

Six applications of 1.95 lb a.i./A with 7-day intervals.

2

Although dodine was found at one or more lower depths at a single sampling interval, the detections were low (<0.034 ppm) and quantifiable

concentrations were found in only 1 of 4 replicates.

3

Degradates were not identified.

 

Bioaccumulation

Bioaccumulation in Fish

Bioaccumulation studies were not conducted.
Page 115 of 219

APPENDIX C. Aquatic Exposure Modeling Assessment - PRZM/EXAMS Outputs

NC Apple Aerial Application

stored as NCapple.out

Chemical: dodine

PRZM environment: NCappleC.txt modified Satday, 12 October 2002 at 18:09:36

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w03812.dvf modified Wedday, 3 July 2002 at 10:05:50

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1965 4.876 0.7837 0.6146 0.3134 0.2542 0.1276

1966 4.364 0.7525 0.6874 0.4268 0.3813 0.255

1967 4.495 0.8832 0.8183 0.5423 0.5005 0.3838

1968 4.674 1.014 0.9502 0.669 0.6112 0.4943

1969 4.731 1.119 1.058 0.7886 0.721 0.602

1970 4.838 1.252 1.171 0.8835 0.816 0.6939

1971 4.92 1.309 1.244 0.9663 0.902 0.785

1972 5.486 1.492 1.339 1.106 1.036 0.9146

1973 7.035 1.893 1.522 1.302 1.266 1.106

1974 7.394 2.126 1.761 1.465 1.389 1.246

1975 5.477 1.903 1.815 1.535 1.499 1.362

1976 5.606 2.273 1.98 1.665 1.645 1.504

1977 9.113 2.581 2.183 1.843 1.766 1.623

1978 6.18 2.243 2.179 1.903 1.836 1.705

1979 6.303 2.452 2.314 2.018 1.946 1.803

1980 6.919 2.529 2.414 2.132 2.07 1.917

1981 6.943 2.607 2.482 2.19 2.16 2.02

1982 6.239 2.627 2.563 2.284 2.221 2.099

1983 6.377 2.932 2.701 2.393 2.324 2.182

1984 6.991 2.872 2.781 2.507 2.436 2.289

1985 6.506 2.903 2.834 2.55 2.482 2.355

1986 6.561 2.95 2.886 2.604 2.538 2.41

1987 7.585 3.161 2.943 2.665 2.631 2.499

1988 6.714 3.161 3.041 2.763 2.694 2.561

1989 6.809 3.185 3.096 2.853 2.787 2.658
Page 116 of 219

1990 6.884 3.39 3.23 2.954 2.884 2.746

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.037037037037037 9.113 3.39 3.23 2.954 2.884 2.746

0.0740740740740741 7.585 3.185 3.096 2.853 2.787 2.658

0.111111111111111 7.394 3.161 3.041 2.763 2.694 2.561

0.148148148148148 7.035 3.161 2.943 2.665 2.631 2.499

0.185185185185185 6.991 2.95 2.886 2.604 2.538 2.41

0.222222222222222 6.943 2.932 2.834 2.55 2.482 2.355

0.259259259259259 6.919 2.903 2.781 2.507 2.436 2.289

0.296296296296296 6.884 2.872 2.701 2.393 2.324 2.182

0.333333333333333 6.809 2.627 2.563 2.284 2.221 2.099

0.37037037037037 6.714 2.607 2.482 2.19 2.16 2.02

0.407407407407407 6.561 2.581 2.414 2.132 2.07 1.917

0.444444444444444 6.506 2.529 2.314 2.018 1.946 1.803

0.481481481481481 6.377 2.452 2.183 1.903 1.836 1.705

0.518518518518518 6.303 2.273 2.179 1.843 1.766 1.623

0.555555555555556 6.239 2.243 1.98 1.665 1.645 1.504

0.592592592592593 6.18 2.126 1.815 1.535 1.499 1.362

0.62962962962963 5.606 1.903 1.761 1.465 1.389 1.246

0.666666666666667 5.486 1.893 1.522 1.302 1.266 1.106

0.703703703703704 5.477 1.492 1.339 1.106 1.036 0.9146

0.740740740740741 4.92 1.309 1.244 0.9663 0.902 0.785

0.777777777777778 4.876 1.252 1.171 0.8835 0.816 0.6939

0.814814814814815 4.838 1.119 1.058 0.7886 0.721 0.602

0.851851851851852 4.731 1.014 0.9502 0.669 0.6112 0.4943

0.888888888888889 4.674 0.8832 0.8183 0.5423 0.5005 0.3838

0.925925925925926 4.495 0.7837 0.6874 0.4268 0.3813 0.255

0.962962962962963 4.364 0.7525 0.6146 0.3134 0.2542 0.1276

0.1 7.4513 3.1682 3.0575 2.79 2.7219 2.5901

Average of yearly averages: 1.55158461538462

Inputs generated by pe4.pl - 8-August-2003
Page 117 of 219

Data used for this run:

Output File: NCapple

Metfile: w03812.dvf

PRZM scenario: NCappleC.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 2.19 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 15-3 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 5 days Set to 0 or delete line for single app.

Interval 2 interval 5 days Set to 0 or delete line for single app.

Interval 3 interval 5 days Set to 0 or delete line for single app.

Interval 4 interval 5 days Set to 0 or delete line for single app.

Interval 5 interval 5 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond
Page 118 of 219

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

=====================================================================

OR Apple Aerial Application

stored as ORapple.out

Chemical: dodine

PRZM environment: ORappleC.txt modified Satday, 12 October 2002 at 18:16:34

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w24229.dvf modified Wedday, 3 July 2002 at 10:06:10

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 4.264 0.7772 0.6019 0.3069 0.2384 0.1099

1962 4.348 0.813 0.6717 0.3985 0.3313 0.2058

1963 4.443 0.8316 0.7674 0.4948 0.4274 0.301

1964 4.537 0.9255 0.8605 0.5799 0.5136 0.39

1965 4.63 1.094 0.9691 0.678 0.61 0.4823

1966 4.715 1.104 1.039 0.7584 0.692 0.568

1967 4.8 1.188 1.123 0.8427 0.7762 0.6515

1968 4.882 1.27 1.205 0.9267 0.862 0.7364

1969 4.968 1.356 1.292 1.011 0.9441 0.8194

1970 5.049 1.437 1.373 1.092 1.025 0.8994

1971 5.134 1.588 1.48 1.184 1.115 0.9844

1972 5.212 1.601 1.536 1.255 1.188 1.062

1973 5.287 1.676 1.611 1.33 1.263 1.137

1974 5.363 1.751 1.686 1.405 1.338 1.212

1975 5.436 1.824 1.76 1.479 1.412 1.285

1976 5.509 1.897 1.833 1.552 1.485 1.358

1977 5.58 1.969 1.904 1.623 1.556 1.43

1978 5.653 2.041 1.976 1.698 1.631 1.502

1979 5.723 2.112 2.048 1.77 1.702 1.573

1980 5.792 2.181 2.117 1.835 1.768 1.641

1981 5.859 2.248 2.183 1.902 1.835 1.707

1982 6.003 2.329 2.263 1.974 1.906 1.776

1983 5.993 2.381 2.317 2.035 1.967 1.84

1984 6.062 2.496 2.406 2.112 2.042 1.909

1985 6.125 2.513 2.449 2.168 2.105 1.975
Page 119 of 219

1986 6.19 2.578 2.514 2.232 2.165 2.036

1987 6.249 2.637 2.573 2.291 2.224 2.094

1988 8.659 3.005 2.695 2.383 2.31 2.168

1989 6.387 2.788 2.71 2.428 2.36 2.229

1990 6.44 2.841 2.765 2.484 2.416 2.285

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 8.659 3.005 2.765 2.484 2.416 2.285

0.0645161290322581 6.44 2.841 2.71 2.428 2.36 2.229

0.0967741935483871 6.387 2.788 2.695 2.383 2.31 2.168

0.129032258064516 6.249 2.637 2.573 2.291 2.224 2.094

0.161290322580645 6.19 2.578 2.514 2.232 2.165 2.036

0.193548387096774 6.125 2.513 2.449 2.168 2.105 1.975

0.225806451612903 6.062 2.496 2.406 2.112 2.042 1.909

0.258064516129032 6.003 2.381 2.317 2.035 1.967 1.84

0.290322580645161 5.993 2.329 2.263 1.974 1.906 1.776

0.32258064516129 5.859 2.248 2.183 1.902 1.835 1.707

0.354838709677419 5.792 2.181 2.117 1.835 1.768 1.641

0.387096774193548 5.723 2.112 2.048 1.77 1.702 1.573

0.419354838709677 5.653 2.041 1.976 1.698 1.631 1.502

0.451612903225806 5.58 1.969 1.904 1.623 1.556 1.43

0.483870967741936 5.509 1.897 1.833 1.552 1.485 1.358

0.516129032258065 5.436 1.824 1.76 1.479 1.412 1.285

0.548387096774194 5.363 1.751 1.686 1.405 1.338 1.212

0.580645161290323 5.287 1.676 1.611 1.33 1.263 1.137

0.612903225806452 5.212 1.601 1.536 1.255 1.188 1.062

0.645161290322581 5.134 1.588 1.48 1.184 1.115 0.9844

0.67741935483871 5.049 1.437 1.373 1.092 1.025 0.8994

0.709677419354839 4.968 1.356 1.292 1.011 0.9441 0.8194

0.741935483870968 4.882 1.27 1.205 0.9267 0.862 0.7364

0.774193548387097 4.8 1.188 1.123 0.8427 0.7762 0.6515

0.806451612903226 4.715 1.104 1.039 0.7584 0.692 0.568

0.838709677419355 4.63 1.094 0.9691 0.678 0.61 0.4823

0.870967741935484 4.537 0.9255 0.8605 0.5799 0.5136 0.39

0.903225806451613 4.443 0.8316 0.7674 0.4948 0.4274 0.301
Page 120 of 219

0.935483870967742 4.348 0.813 0.6717 0.3985 0.3313 0.2058

0.967741935483871 4.264 0.7772 0.6019 0.3069 0.2384 0.1099

0.1 6.3732 2.7729 2.6828 2.3738 2.3014 2.1606

Average of yearly averages: 1.27890333333333

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: ORapple

Metfile: w24229.dvf

PRZM scenario: ORappleC.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 2.19 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 5 days Set to 0 or delete line for single app.

Interval 2 interval 5 days Set to 0 or delete line for single app.

Interval 3 interval 5 days Set to 0 or delete line for single app.

Interval 4 interval 5 days Set to 0 or delete line for single app.
Page 121 of 219

Interval 5 interval 5 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

========================================================================

PA Apple Aerial Application

stored as PAapple.out

Chemical: dodine

PRZM environment: PAappleC.txt modified Satday, 12 October 2002 at 18:24:46

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w14737.dvf modified Wedday, 3 July 2002 at 10:06:12

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 15.65 2.229 0.7058 0.4014 0.3465 0.191

1962 27.79 4.097 1.21 0.8065 0.726 0.5003

1963 4.805 1.193 1.129 0.8477 0.7907 0.6834

1964 8.642 1.883 1.32 1.101 1.035 0.8591

1965 5.117 1.506 1.441 1.166 1.1 0.9866

1966 5.31 1.626 1.565 1.283 1.216 1.107

1967 30.18 5.276 2.372 1.926 1.808 1.483

1968 24.08 9.08 3.393 2.517 2.358 1.96

1969 8.696 4.011 2.681 2.405 2.365 2.212

1970 9.91 3.368 2.827 2.538 2.516 2.378

1971 16.82 4.967 3.353 2.953 2.861 2.64

1972 43.19 8.322 4.268 3.66 3.503 3.094

1973 35.15 7.63 4.384 3.938 3.822 3.501

1974 23.64 6.881 4.663 4.175 4.061 3.817

1975 23.48 6.636 4.672 4.391 4.338 4.092

1976 12.02 5.304 4.676 4.409 4.337 4.229

1977 16.31 5.935 4.773 4.614 4.556 4.376
Page 122 of 219

1978 25.89 8.123 5.585 5.017 4.917 4.65

1979 41.27 10.54 6.225 5.474 5.357 5.011

1980 9.289 5.992 5.671 5.363 5.283 5.118

1981 24.72 8.296 6.38 5.801 5.664 5.34

1982 48.67 11.46 7.377 6.402 6.236 5.778

1983 18.76 7.671 6.396 6.248 6.167 5.977

1984 33.22 9.965 7.743 6.997 6.833 6.374

1985 14.9 9.169 7.46 7.034 6.937 6.656

1986 21.98 9.295 7.507 7.107 7.011 6.814

1987 17.6 8.309 7.333 7.141 7.105 6.94

1988 42.39 14.75 8.857 7.895 7.749 7.315

1989 24.01 10.58 9.066 8.366 8.187 7.731

1990 42.88 12.68 9.317 8.557 8.446 8.076

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 48.67 14.75 9.317 8.557 8.446 8.076

0.0645161290322581 43.19 12.68 9.066 8.366 8.187 7.731

0.0967741935483871 42.88 11.46 8.857 7.895 7.749 7.315

0.129032258064516 42.39 10.58 7.743 7.141 7.105 6.94

0.161290322580645 41.27 10.54 7.507 7.107 7.011 6.814

0.193548387096774 35.15 9.965 7.46 7.034 6.937 6.656

0.225806451612903 33.22 9.295 7.377 6.997 6.833 6.374

0.258064516129032 30.18 9.169 7.333 6.402 6.236 5.977

0.290322580645161 27.79 9.08 6.396 6.248 6.167 5.778

0.32258064516129 25.89 8.322 6.38 5.801 5.664 5.34

0.354838709677419 24.72 8.309 6.225 5.474 5.357 5.118

0.387096774193548 24.08 8.296 5.671 5.363 5.283 5.011

0.419354838709677 24.01 8.123 5.585 5.017 4.917 4.65

0.451612903225806 23.64 7.671 4.773 4.614 4.556 4.376

0.483870967741936 23.48 7.63 4.676 4.409 4.338 4.229

0.516129032258065 21.98 6.881 4.672 4.391 4.337 4.092

0.548387096774194 18.76 6.636 4.663 4.175 4.061 3.817

0.580645161290323 17.6 5.992 4.384 3.938 3.822 3.501

0.612903225806452 16.82 5.935 4.268 3.66 3.503 3.094

0.645161290322581 16.31 5.304 3.393 2.953 2.861 2.64
Page 123 of 219

0.67741935483871 15.65 5.276 3.353 2.538 2.516 2.378

0.709677419354839 14.9 4.967 2.827 2.517 2.365 2.212

0.741935483870968 12.02 4.097 2.681 2.405 2.358 1.96

0.774193548387097 9.91 4.011 2.372 1.926 1.808 1.483

0.806451612903226 9.289 3.368 1.565 1.283 1.216 1.107

0.838709677419355 8.696 2.229 1.441 1.166 1.1 0.9866

0.870967741935484 8.642 1.883 1.32 1.101 1.035 0.8591

0.903225806451613 5.31 1.626 1.21 0.8477 0.7907 0.6834

0.935483870967742 5.117 1.506 1.129 0.8065 0.726 0.5003

0.967741935483871 4.805 1.193 0.7058 0.4014 0.3465 0.191

0.1 42.831 11.372 8.7456 7.8196 7.6846 7.2775

Average of yearly averages: 3.99631333333333

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAapple

Metfile: w14737.dvf

PRZM scenario: PAappleC.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm
Page 124 of 219

Application Rate: TAPP 2.19 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 25-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 5 days Set to 0 or delete line for single app.

Interval 2 interval 5 days Set to 0 or delete line for single app.

Interval 3 interval 5 days Set to 0 or delete line for single app.

Interval 4 interval 5 days Set to 0 or delete line for single app.

Interval 5 interval 5 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

================================================================================

MI Cherries Aerial Application

stored as MIcherries.out

Chemical: dodine

PRZM environment: MICherriesC.txt modified Satday, 27 March 2004 at 15:39:38

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w14850.dvf modified Wedday, 3 July 2002 at 10:05:40

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 2.987 0.6592 0.2596 0.1892 0.1684 0.09118

1962 15.61 2.921 0.8968 0.5319 0.4669 0.2887

1963 8.713 1.471 0.7364 0.607 0.5491 0.424

1964 11.01 1.932 0.8256 0.6925 0.6598 0.5412

1965 3.396 0.9881 0.8227 0.7672 0.7228 0.6469

1966 5.063 1.313 0.9162 0.8463 0.8329 0.748

1967 3.61 1.477 1.123 1.003 0.9551 0.8497

1968 4.676 1.438 1.145 1.08 1.051 0.9432

1969 24.85 4.685 2.267 1.665 1.548 1.232
Page 125 of 219

1970 4.134 1.817 1.566 1.505 1.46 1.386

1971 5.429 2.005 1.649 1.579 1.552 1.475

1972 12.25 3.472 2.045 1.803 1.764 1.626

1973 5.392 2.327 1.919 1.895 1.847 1.74

1974 16.92 4.38 2.496 2.178 2.101 1.91

1975 7.874 2.801 2.257 2.142 2.099 2.03

1976 4.923 2.478 2.3 2.227 2.186 2.105

1977 4.979 2.816 2.416 2.307 2.264 2.179

1978 5.675 3.008 2.536 2.445 2.394 2.283

1979 8.397 3.209 2.691 2.544 2.52 2.401

1980 10.09 3.513 2.87 2.683 2.628 2.504

1981 22.45 5.604 3.295 2.94 2.874 2.679

1982 17.83 4.907 3.256 2.999 2.96 2.829

1983 10.37 3.957 3.188 3.124 3.108 2.976

1984 6.736 3.56 3.322 3.208 3.161 3.072

1985 19.28 5.329 3.628 3.398 3.345 3.2

1986 29.75 6.978 4.6 3.957 3.834 3.51

1987 11.69 4.788 3.995 3.862 3.837 3.703

1988 6.537 4.129 3.965 3.896 3.867 3.772

1989 23.93 6.939 4.997 4.377 4.263 3.979

1990 20.21 6.874 4.932 4.49 4.416 4.2

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 29.75 6.978 4.997 4.49 4.416 4.2

0.0645161290322581 24.85 6.939 4.932 4.377 4.263 3.979

0.0967741935483871 23.93 6.874 4.6 3.957 3.867 3.772

0.129032258064516 22.45 5.604 3.995 3.896 3.837 3.703

0.161290322580645 20.21 5.329 3.965 3.862 3.834 3.51

0.193548387096774 19.28 4.907 3.628 3.398 3.345 3.2

0.225806451612903 17.83 4.788 3.322 3.208 3.161 3.072

0.258064516129032 16.92 4.685 3.295 3.124 3.108 2.976

0.290322580645161 15.61 4.38 3.256 2.999 2.96 2.829

0.32258064516129 12.25 4.129 3.188 2.94 2.874 2.679

0.354838709677419 11.69 3.957 2.87 2.683 2.628 2.504

0.387096774193548 11.01 3.56 2.691 2.544 2.52 2.401
Page 126 of 219

0.419354838709677 10.37 3.513 2.536 2.445 2.394 2.283

0.451612903225806 10.09 3.472 2.496 2.307 2.264 2.179

0.483870967741936 8.713 3.209 2.416 2.227 2.186 2.105

0.516129032258065 8.397 3.008 2.3 2.178 2.101 2.03

0.548387096774194 7.874 2.921 2.267 2.142 2.099 1.91

0.580645161290323 6.736 2.816 2.257 1.895 1.847 1.74

0.612903225806452 6.537 2.801 2.045 1.803 1.764 1.626

0.645161290322581 5.675 2.478 1.919 1.665 1.552 1.475

0.67741935483871 5.429 2.327 1.649 1.579 1.548 1.386

0.709677419354839 5.392 2.005 1.566 1.505 1.46 1.232

0.741935483870968 5.063 1.932 1.145 1.08 1.051 0.9432

0.774193548387097 4.979 1.817 1.123 1.003 0.9551 0.8497

0.806451612903226 4.923 1.477 0.9162 0.8463 0.8329 0.748

0.838709677419355 4.676 1.471 0.8968 0.7672 0.7228 0.6469

0.870967741935484 4.134 1.438 0.8256 0.6925 0.6598 0.5412

0.903225806451613 3.61 1.313 0.8227 0.607 0.5491 0.424

0.935483870967742 3.396 0.9881 0.7364 0.5319 0.4669 0.2887

0.967741935483871 2.987 0.6592 0.2596 0.1892 0.1684 0.09118

0.1 23.782 6.747 4.5395 3.9509 3.864 3.7651

Average of yearly averages: 2.04412933333333

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: MIcherries

Metfile: w14850.dvf

PRZM scenario: MICherriesC.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L
Page 127 of 219

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 1.46 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 10-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 7 days Set to 0 or delete line for single app.

Interval 2 interval 7 days Set to 0 or delete line for single app.

Interval 3 interval 7 days Set to 0 or delete line for single app.

Interval 4 interval 7 days Set to 0 or delete line for single app.

Interval 5 interval 7 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

================================================================================

GA Peaches

stored as GApeaches.out

Chemical: dodine

PRZM environment: GAPeachesC.txt modified Satday, 12 October 2002 at 17:59:56

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w03813.dvf modified Wedday, 3 July 2002 at 10:04:32

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 5.624 0.825 0.495 0.3392 0.2652 0.115
Page 128 of 219

1962 5.74 1.295 0.6817 0.4687 0.3916 0.2357

1963 5.886 1.186 0.7553 0.5655 0.4944 0.3457

1964 5.977 1.315 0.8529 0.6874 0.6143 0.4583

1965 19.36 3.249 1.205 0.9777 0.9013 0.6738

1966 6.333 1.559 1.218 1.042 0.9658 0.8156

1967 6.427 1.628 1.33 1.138 1.065 0.9145

1968 9.633 2.118 1.507 1.269 1.187 1.021

1969 6.628 1.829 1.5 1.325 1.251 1.108

1970 6.711 1.912 1.583 1.406 1.336 1.191

1971 8.459 2.188 1.719 1.522 1.449 1.288

1972 6.889 2.09 1.761 1.595 1.52 1.37

1973 14.46 3.196 2.043 1.757 1.67 1.488

1974 7.101 2.486 2.008 1.806 1.729 1.58

1975 7.177 2.378 2.05 1.901 1.824 1.667

1976 9.692 3.37 2.365 2.062 1.97 1.78

1977 7.377 2.578 2.249 2.072 1.998 1.851

1978 7.435 2.636 2.307 2.13 2.058 1.91

1979 7.494 2.695 2.366 2.191 2.116 1.969

1980 7.552 2.753 2.424 2.247 2.176 2.027

1981 22.26 4.853 2.891 2.535 2.433 2.195

1982 7.808 3.009 2.681 2.503 2.429 2.281

1983 8.416 3.167 2.763 2.633 2.547 2.367

1984 16.35 5.062 3.209 2.825 2.731 2.515

1985 8.113 3.313 2.985 2.807 2.741 2.59

1986 8.16 3.36 3.032 2.854 2.777 2.638

1987 8.212 3.413 3.084 2.917 2.84 2.687

1988 8.256 3.457 3.128 2.95 2.877 2.73

1989 8.303 3.504 3.175 3.002 2.925 2.773

1990 8.339 3.54 3.211 3.034 2.957 2.809

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 22.26 5.062 3.211 3.034 2.957 2.809

0.0645161290322581 19.36 4.853 3.209 3.002 2.925 2.773

0.0967741935483871 16.35 3.54 3.175 2.95 2.877 2.73

0.129032258064516 14.46 3.504 3.128 2.917 2.84 2.687
Page 129 of 219

0.161290322580645 9.692 3.457 3.084 2.854 2.777 2.638

0.193548387096774 9.633 3.413 3.032 2.825 2.741 2.59

0.225806451612903 8.459 3.37 2.985 2.807 2.731 2.515

0.258064516129032 8.416 3.36 2.891 2.633 2.547 2.367

0.290322580645161 8.339 3.313 2.763 2.535 2.433 2.281

0.32258064516129 8.303 3.249 2.681 2.503 2.429 2.195

0.354838709677419 8.256 3.196 2.424 2.247 2.176 2.027

0.387096774193548 8.212 3.167 2.366 2.191 2.116 1.969

0.419354838709677 8.16 3.009 2.365 2.13 2.058 1.91

0.451612903225806 8.113 2.753 2.307 2.072 1.998 1.851

0.483870967741936 7.808 2.695 2.249 2.062 1.97 1.78

0.516129032258065 7.552 2.636 2.05 1.901 1.824 1.667

0.548387096774194 7.494 2.578 2.043 1.806 1.729 1.58

0.580645161290323 7.435 2.486 2.008 1.757 1.67 1.488

0.612903225806452 7.377 2.378 1.761 1.595 1.52 1.37

0.645161290322581 7.177 2.188 1.719 1.522 1.449 1.288

0.67741935483871 7.101 2.118 1.583 1.406 1.336 1.191

0.709677419354839 6.889 2.09 1.507 1.325 1.251 1.108

0.741935483870968 6.711 1.912 1.5 1.269 1.187 1.021

0.774193548387097 6.628 1.829 1.33 1.138 1.065 0.9145

0.806451612903226 6.427 1.628 1.218 1.042 0.9658 0.8156

0.838709677419355 6.333 1.559 1.205 0.9777 0.9013 0.6738

0.870967741935484 5.977 1.315 0.8529 0.6874 0.6143 0.4583

0.903225806451613 5.886 1.295 0.7553 0.5655 0.4944 0.3457

0.935483870967742 5.74 1.186 0.6817 0.4687 0.3916 0.2357

0.967741935483871 5.624 0.825 0.495 0.3392 0.2652 0.115

0.1 16.161 3.5364 3.1703 2.9467 2.8733 2.7257

Average of yearly averages: 1.64645333333333

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: GApeaches

Metfile: w03813.dvf

PRZM scenario: GAPeachesC.txt
Page 130 of 219

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 2.91 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 7 days Set to 0 or delete line for single app.

Interval 2 interval 7 days Set to 0 or delete line for single app.

Interval 3 interval 7 days Set to 0 or delete line for single app.

Interval 4 interval 7 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

================================================================================

CA Fruit Aerial Application

stored as CAfruit0.out

Chemical: dodine
Page 131 of 219

PRZM environment: CAfruit0C.txt modified Thuday, 17 June 2004 at 10:14:02

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w93193.dvf modified Wedday, 3 July 2002 at 10:04:24

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 4.248 0.6364 0.5713 0.2909 0.2248 0.1073

1962 4.338 0.727 0.662 0.3815 0.3153 0.1972

1963 4.427 0.8155 0.7506 0.47 0.4037 0.2852

1964 4.514 0.9022 0.8373 0.5566 0.4903 0.3708

1965 4.598 0.9866 0.9218 0.6411 0.5746 0.455

1966 4.681 1.069 1.005 0.7236 0.657 0.5366

1967 4.761 1.149 1.085 0.8041 0.7374 0.6162

1968 4.839 1.227 1.162 0.8814 0.8147 0.693

1969 4.915 1.306 1.239 0.9583 0.8915 0.7696

1970 4.99 1.379 1.314 1.033 0.9662 0.8435

1971 5.063 1.451 1.387 1.106 1.039 0.916

1972 5.134 1.523 1.458 1.177 1.11 0.9862

1973 5.204 1.592 1.528 1.246 1.179 1.055

1974 5.271 1.659 1.595 1.314 1.246 1.122

1975 5.336 1.725 1.66 1.379 1.312 1.188

1976 5.403 1.791 1.727 1.445 1.378 1.253

1977 5.467 1.856 1.791 1.51 1.443 1.316

1978 5.526 1.916 1.85 1.569 1.502 1.375

1979 5.585 1.973 1.909 1.627 1.56 1.432

1980 5.64 2.028 1.964 1.683 1.615 1.488

1981 5.696 2.084 2.02 1.738 1.671 1.542

1982 5.748 2.137 2.073 1.791 1.723 1.596

1983 5.803 2.192 2.128 1.846 1.778 1.65

1984 5.854 2.242 2.178 1.896 1.828 1.698

1985 5.9 2.289 2.225 1.943 1.875 1.745

1986 5.946 2.335 2.271 1.989 1.921 1.791

1987 5.992 2.38 2.317 2.034 1.966 1.836

1988 6.038 2.427 2.363 2.081 2.013 1.882

1989 6.083 2.471 2.407 2.125 2.057 1.927

1990 6.127 2.516 2.452 2.17 2.102 1.971
Page 132 of 219

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 6.127 2.516 2.452 2.17 2.102 1.971

0.0645161290322581 6.083 2.471 2.407 2.125 2.057 1.927

0.0967741935483871 6.038 2.427 2.363 2.081 2.013 1.882

0.129032258064516 5.992 2.38 2.317 2.034 1.966 1.836

0.161290322580645 5.946 2.335 2.271 1.989 1.921 1.791

0.193548387096774 5.9 2.289 2.225 1.943 1.875 1.745

0.225806451612903 5.854 2.242 2.178 1.896 1.828 1.698

0.258064516129032 5.803 2.192 2.128 1.846 1.778 1.65

0.290322580645161 5.748 2.137 2.073 1.791 1.723 1.596

0.32258064516129 5.696 2.084 2.02 1.738 1.671 1.542

0.354838709677419 5.64 2.028 1.964 1.683 1.615 1.488

0.387096774193548 5.585 1.973 1.909 1.627 1.56 1.432

0.419354838709677 5.526 1.916 1.85 1.569 1.502 1.375

0.451612903225806 5.467 1.856 1.791 1.51 1.443 1.316

0.483870967741936 5.403 1.791 1.727 1.445 1.378 1.253

0.516129032258065 5.336 1.725 1.66 1.379 1.312 1.188

0.548387096774194 5.271 1.659 1.595 1.314 1.246 1.122

0.580645161290323 5.204 1.592 1.528 1.246 1.179 1.055

0.612903225806452 5.134 1.523 1.458 1.177 1.11 0.9862

0.645161290322581 5.063 1.451 1.387 1.106 1.039 0.916

0.67741935483871 4.99 1.379 1.314 1.033 0.9662 0.8435

0.709677419354839 4.915 1.306 1.239 0.9583 0.8915 0.7696

0.741935483870968 4.839 1.227 1.162 0.8814 0.8147 0.693

0.774193548387097 4.761 1.149 1.085 0.8041 0.7374 0.6162

0.806451612903226 4.681 1.069 1.005 0.7236 0.657 0.5366

0.838709677419355 4.598 0.9866 0.9218 0.6411 0.5746 0.455

0.870967741935484 4.514 0.9022 0.8373 0.5566 0.4903 0.3708

0.903225806451613 4.427 0.8155 0.7506 0.47 0.4037 0.2852

0.935483870967742 4.338 0.727 0.662 0.3815 0.3153 0.1972

0.967741935483871 4.248 0.6364 0.5713 0.2909 0.2248 0.1073

0.1 6.0334 2.4223 2.3584 2.0763 2.0083 1.8774

Average of yearly averages: 1.15478666666667
Page 133 of 219

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: CAfruit0

Metfile: w93193.dvf

PRZM scenario: CAfruit0C.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 2.19 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 10-3 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 5 days Set to 0 or delete line for single app.

Interval 2 interval 5 days Set to 0 or delete line for single app.

Interval 3 interval 5 days Set to 0 or delete line for single app.

Interval 4 interval 5 days Set to 0 or delete line for single app.

Interval 5 interval 5 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT
Page 134 of 219

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

=====================================================================

GA Pecans Aerial Application

stored as GApecan.out

Chemical: dodine

PRZM environment: GAPecansC.txt modified Tueday, 22 April 2003 at 08:57:20

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w93805.dvf modified Wedday, 3 July 2002 at 10:04:32

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 5.624 0.8286 0.4858 0.3106 0.2463 0.1236

1962 5.751 0.9522 0.6104 0.4487 0.3896 0.2581

1963 5.895 1.233 0.7844 0.6357 0.5729 0.4281

1964 8.18 1.797 1.049 0.8917 0.8844 0.6897

1965 15.58 2.947 1.563 1.269 1.217 0.9977

1966 20.05 3.784 1.841 1.62 1.532 1.304

1967 8.231 2.813 1.982 1.712 1.652 1.486

1968 7.123 2.35 1.959 1.793 1.722 1.586

1969 7.192 2.405 2.052 1.896 1.857 1.724

1970 9.398 2.892 2.201 2.058 2.033 1.889

1971 7.508 2.709 2.382 2.198 2.154 2.027

1972 17.27 4.263 2.782 2.6 2.507 2.266

1973 15.69 4.933 3.111 2.847 2.748 2.511

1974 9.037 3.741 3.256 2.95 2.858 2.679

1975 9.327 4.046 3.302 3.105 3.032 2.855

1976 12.82 5.17 3.652 3.347 3.275 3.056

1977 8.654 3.854 3.515 3.39 3.311 3.163

1978 8.797 3.98 3.596 3.446 3.404 3.25

1979 18.71 6.233 4.243 3.773 3.709 3.464

1980 9.088 4.762 4.029 3.793 3.723 3.581

1981 9.147 4.347 4.011 3.837 3.773 3.625

1982 20.26 5.926 4.201 3.99 3.935 3.747

1983 9.359 5.096 4.311 4.124 4.05 3.859
Page 135 of 219

1984 10.32 5.015 4.345 4.15 4.089 3.923

1985 14.46 5.456 4.332 4.234 4.193 4.017

1986 13.01 5.278 4.445 4.318 4.289 4.127

1987 13.4 6.205 4.839 4.609 4.531 4.303

1988 9.885 5.086 4.748 4.583 4.505 4.354

1989 12.43 5.694 4.867 4.757 4.707 4.484

1990 10.06 5.36 4.934 4.758 4.71 4.546

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 20.26 6.233 4.934 4.758 4.71 4.546

0.0645161290322581 20.05 6.205 4.867 4.757 4.707 4.484

0.0967741935483871 18.71 5.926 4.839 4.609 4.531 4.354

0.129032258064516 17.27 5.694 4.748 4.583 4.505 4.303

0.161290322580645 15.69 5.456 4.445 4.318 4.289 4.127

0.193548387096774 15.58 5.36 4.345 4.234 4.193 4.017

0.225806451612903 14.46 5.278 4.332 4.15 4.089 3.923

0.258064516129032 13.4 5.17 4.311 4.124 4.05 3.859

0.290322580645161 13.01 5.096 4.243 3.99 3.935 3.747

0.32258064516129 12.82 5.086 4.201 3.837 3.773 3.625

0.354838709677419 12.43 5.015 4.029 3.793 3.723 3.581

0.387096774193548 10.32 4.933 4.011 3.773 3.709 3.464

0.419354838709677 10.06 4.762 3.652 3.446 3.404 3.25

0.451612903225806 9.885 4.347 3.596 3.39 3.311 3.163

0.483870967741936 9.398 4.263 3.515 3.347 3.275 3.056

0.516129032258065 9.359 4.046 3.302 3.105 3.032 2.855

0.548387096774194 9.327 3.98 3.256 2.95 2.858 2.679

0.580645161290323 9.147 3.854 3.111 2.847 2.748 2.511

0.612903225806452 9.088 3.784 2.782 2.6 2.507 2.266

0.645161290322581 9.037 3.741 2.382 2.198 2.154 2.027

0.67741935483871 8.797 2.947 2.201 2.058 2.033 1.889

0.709677419354839 8.654 2.892 2.052 1.896 1.857 1.724

0.741935483870968 8.231 2.813 1.982 1.793 1.722 1.586

0.774193548387097 8.18 2.709 1.959 1.712 1.652 1.486

0.806451612903226 7.508 2.405 1.841 1.62 1.532 1.304

0.838709677419355 7.192 2.35 1.563 1.269 1.217 0.9977
Page 136 of 219

0.870967741935484 7.123 1.797 1.049 0.8917 0.8844 0.6897

0.903225806451613 5.895 1.233 0.7844 0.6357 0.5729 0.4281

0.935483870967742 5.751 0.9522 0.6104 0.4487 0.3896 0.2581

0.967741935483871 5.624 0.8286 0.4858 0.3106 0.2463 0.1236

0.1 18.566 5.9028 4.8299 4.6064 4.5284 4.3489

Average of yearly averages: 2.67744

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: GApecan

Metfile: w93805.dvf

PRZM scenario: GAPecansC.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 2.91 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 15-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.
Page 137 of 219

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

=====================================================================

FL Strawberry Aerial Application

stored as FLstraw.out

Chemical: dodine

PRZM environment: FLstrawberryC.txt modified Friday, 4 July 2003 at 21:12:58

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w12842.dvf modified Wedday, 3 July 2002 at 10:04:28

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 0.5646 0.08305 0.04993 0.03324 0.02587 0.01396

1962 0.5783 0.09477 0.06196 0.04532 0.03777 0.0256

1963 0.5897 0.1151 0.07808 0.05838 0.05045 0.03758

1964 0.5993 0.1216 0.08609 0.06892 0.06125 0.04983

1965 0.6213 0.1337 0.09797 0.07975 0.07227 0.06025

1966 0.6216 0.1414 0.1084 0.08994 0.08258 0.07036

1967 0.6314 0.1498 0.1171 0.0997 0.09217 0.07979

1968 0.6405 0.159 0.1259 0.1086 0.1012 0.08895

1969 0.7254 0.1747 0.1372 0.1208 0.1128 0.1002

1970 0.6606 0.1791 0.1476 0.1306 0.1228 0.1096

1971 0.6808 0.1889 0.1551 0.1381 0.1308 0.1184

1972 0.687 0.1988 0.1653 0.1472 0.1396 0.1266

1973 0.6863 0.2047 0.1718 0.156 0.1484 0.1349

1974 0.6943 0.2127 0.1797 0.1628 0.1552 0.1424

1975 0.7068 0.2202 0.1872 0.1698 0.1623 0.1493

1976 0.7085 0.2269 0.1941 0.1766 0.1692 0.1568
Page 138 of 219

1977 0.7163 0.2348 0.202 0.1844 0.1768 0.1632

1978 0.7282 0.2521 0.2114 0.1921 0.1842 0.1703

1979 0.7443 0.2633 0.2204 0.1997 0.1923 0.181

1980 0.7658 0.2622 0.2262 0.2088 0.2017 0.188

1981 0.8852 0.2786 0.2343 0.2165 0.2086 0.1947

1982 0.7531 0.2727 0.2406 0.2219 0.2143 0.2012

1983 0.7601 0.2786 0.2488 0.2313 0.2235 0.2093

1984 0.7958 0.2879 0.2545 0.2365 0.2288 0.2147

1985 0.7726 0.2911 0.258 0.2412 0.2335 0.2196

1986 0.7814 0.2957 0.2626 0.2472 0.2394 0.225

1987 0.8019 0.3034 0.2722 0.2555 0.2473 0.2324

1988 0.7914 0.3083 0.2768 0.2587 0.251 0.2369

1989 0.804 0.3146 0.2801 0.2625 0.2549 0.2407

1990 0.7985 0.3224 0.2857 0.2675 0.2596 0.2447

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 0.8852 0.3224 0.2857 0.2675 0.2596 0.2447

0.0645161290322581 0.804 0.3146 0.2801 0.2625 0.2549 0.2407

0.0967741935483871 0.8019 0.3083 0.2768 0.2587 0.251 0.2369

0.129032258064516 0.7985 0.3034 0.2722 0.2555 0.2473 0.2324

0.161290322580645 0.7958 0.2957 0.2626 0.2472 0.2394 0.225

0.193548387096774 0.7914 0.2911 0.258 0.2412 0.2335 0.2196

0.225806451612903 0.7814 0.2879 0.2545 0.2365 0.2288 0.2147

0.258064516129032 0.7726 0.2786 0.2488 0.2313 0.2235 0.2093

0.290322580645161 0.7658 0.2786 0.2406 0.2219 0.2143 0.2012

0.32258064516129 0.7601 0.2727 0.2343 0.2165 0.2086 0.1947

0.354838709677419 0.7531 0.2633 0.2262 0.2088 0.2017 0.188

0.387096774193548 0.7443 0.2622 0.2204 0.1997 0.1923 0.181

0.419354838709677 0.7282 0.2521 0.2114 0.1921 0.1842 0.1703

0.451612903225806 0.7254 0.2348 0.202 0.1844 0.1768 0.1632

0.483870967741936 0.7163 0.2269 0.1941 0.1766 0.1692 0.1568

0.516129032258065 0.7085 0.2202 0.1872 0.1698 0.1623 0.1493

0.548387096774194 0.7068 0.2127 0.1797 0.1628 0.1552 0.1424

0.580645161290323 0.6943 0.2047 0.1718 0.156 0.1484 0.1349

0.612903225806452 0.687 0.1988 0.1653 0.1472 0.1396 0.1266
Page 139 of 219

0.645161290322581 0.6863 0.1889 0.1551 0.1381 0.1308 0.1184

0.67741935483871 0.6808 0.1791 0.1476 0.1306 0.1228 0.1096

0.709677419354839 0.6606 0.1747 0.1372 0.1208 0.1128 0.1002

0.741935483870968 0.6405 0.159 0.1259 0.1086 0.1012 0.08895

0.774193548387097 0.6314 0.1498 0.1171 0.0997 0.09217 0.07979

0.806451612903226 0.6216 0.1414 0.1084 0.08994 0.08258 0.07036

0.838709677419355 0.6213 0.1337 0.09797 0.07975 0.07227 0.06025

0.870967741935484 0.5993 0.1216 0.08609 0.06892 0.06125 0.04983

0.903225806451613 0.5897 0.1151 0.07808 0.05838 0.05045 0.03758

0.935483870967742 0.5783 0.09477 0.06196 0.04532 0.03777 0.0256

0.967741935483871 0.5646 0.08305 0.04993 0.03324 0.02587 0.01396

0.1 0.80156 0.30781 0.27634 0.25838 0.25063 0.23645

Average of yearly averages: 0.146207333333333

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLstraw

Metfile: w12842.dvf

PRZM scenario: FLstrawberryC.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual
Page 140 of 219

Incorporation Depth: DEPI cm

Application Rate: TAPP 1.46 kg/ha

Application Efficiency: APPEFF .99 fraction

Spray Drift DRFT .01 fraction of application rate applied to pond

Application Date Date 1-2 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 7 days Set to 0 or delete line for single app.

Interval 2 interval 7 days Set to 0 or delete line for single app.

Interval 3 interval 7 days Set to 0 or delete line for single app.

Interval 4 interval 7 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

=====================================================================

CA Almond/Walnut Aerial Application

stored as CAalmond0.out

Chemical: dodine

PRZM environment: CAalmond0C.txt modified Thuday, 17 June 2004 at 10:13:20

EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30

Metfile: w23232.dvf modified Wedday, 3 July 2002 at 10:04:22

Water segment concentrations (ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly

1961 5.624 0.8252 0.4832 0.3096 0.2406 0.1196

1962 5.725 0.9262 0.5842 0.4105 0.3415 0.2234

1963 5.834 1.036 0.7003 0.5235 0.4536 0.3298

1964 5.932 1.133 0.7914 0.6177 0.5485 0.4255

1965 6.027 1.228 0.8867 0.7126 0.6433 0.5201

1966 6.12 1.321 0.9791 0.8053 0.7359 0.6121

1967 6.211 1.413 1.072 0.8978 0.8283 0.7032

1968 6.299 1.501 1.159 0.9855 0.916 0.7907

1969 6.387 1.588 1.249 1.074 1.004 0.8781
Page 141 of 219

1970 6.472 1.673 1.331 1.158 1.088 0.9622

1971 6.556 1.757 1.415 1.242 1.172 1.046

1972 6.637 1.838 1.497 1.323 1.254 1.126

1973 6.717 1.919 1.577 1.404 1.334 1.206

1974 6.795 1.996 1.655 1.481 1.411 1.284

1975 6.948 2.075 1.736 1.561 1.491 1.361

1976 6.977 2.152 1.807 1.633 1.563 1.433

1977 7.019 2.22 1.879 1.705 1.635 1.506

1978 7.091 2.293 1.951 1.778 1.708 1.578

1979 7.163 2.364 2.023 1.849 1.779 1.648

1980 7.231 2.432 2.091 1.917 1.847 1.717

1981 7.301 2.502 2.161 1.987 1.917 1.786

1982 7.968 2.633 2.254 2.066 1.994 1.86

1983 7.443 2.644 2.303 2.133 2.062 1.929

1984 7.505 2.707 2.366 2.192 2.121 1.988

1985 7.565 2.766 2.425 2.251 2.181 2.048

1986 7.625 2.826 2.485 2.311 2.241 2.108

1987 7.685 2.886 2.545 2.372 2.301 2.167

1988 7.74 2.941 2.601 2.428 2.357 2.222

1989 7.795 2.997 2.657 2.483 2.412 2.278

1990 7.851 3.052 2.712 2.538 2.468 2.333

Sorted results

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly

0.032258064516129 7.968 3.052 2.712 2.538 2.468 2.333

0.0645161290322581 7.851 2.997 2.657 2.483 2.412 2.278

0.0967741935483871 7.795 2.941 2.601 2.428 2.357 2.222

0.129032258064516 7.74 2.886 2.545 2.372 2.301 2.167

0.161290322580645 7.685 2.826 2.485 2.311 2.241 2.108

0.193548387096774 7.625 2.766 2.425 2.251 2.181 2.048

0.225806451612903 7.565 2.707 2.366 2.192 2.121 1.988

0.258064516129032 7.505 2.644 2.303 2.133 2.062 1.929

0.290322580645161 7.443 2.633 2.254 2.066 1.994 1.86

0.32258064516129 7.301 2.502 2.161 1.987 1.917 1.786

0.354838709677419 7.231 2.432 2.091 1.917 1.847 1.717

0.387096774193548 7.163 2.364 2.023 1.849 1.779 1.648
Page 142 of 219

0.419354838709677 7.091 2.293 1.951 1.778 1.708 1.578

0.451612903225806 7.019 2.22 1.879 1.705 1.635 1.506

0.483870967741936 6.977 2.152 1.807 1.633 1.563 1.433

0.516129032258065 6.948 2.075 1.736 1.561 1.491 1.361

0.548387096774194 6.795 1.996 1.655 1.481 1.411 1.284

0.580645161290323 6.717 1.919 1.577 1.404 1.334 1.206

0.612903225806452 6.637 1.838 1.497 1.323 1.254 1.126

0.645161290322581 6.556 1.757 1.415 1.242 1.172 1.046

0.67741935483871 6.472 1.673 1.331 1.158 1.088 0.9622

0.709677419354839 6.387 1.588 1.249 1.074 1.004 0.8781

0.741935483870968 6.299 1.501 1.159 0.9855 0.916 0.7907

0.774193548387097 6.211 1.413 1.072 0.8978 0.8283 0.7032

0.806451612903226 6.12 1.321 0.9791 0.8053 0.7359 0.6121

0.838709677419355 6.027 1.228 0.8867 0.7126 0.6433 0.5201

0.870967741935484 5.932 1.133 0.7914 0.6177 0.5485 0.4255

0.903225806451613 5.834 1.036 0.7003 0.5235 0.4536 0.3298

0.935483870967742 5.725 0.9262 0.5842 0.4105 0.3415 0.2234

0.967741935483871 5.624 0.8252 0.4832 0.3096 0.2406 0.1196

0.1 7.7895 2.9355 2.5954 2.4224 2.3514 2.2165

Average of yearly averages: 1.33962333333333

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: CAalmond0

Metfile: w23232.dvf

PRZM scenario: CAalmond0C.txt

EXAMS environment file: pond298.exv

Chemical Name: dodine

Description Variable Name Value Units Comments

Molecular weight mwt 287.4 g/mol

Henry's Law Const. henry 9e-11 atm-m^3/mol

Vapor Pressure vapr 1.5e-7 torr

Solubility sol 6300 mg/L

Kd Kd 10427 mg/L
Page 143 of 219

Koc Koc mg/L

Photolysis half-life kdp 770 days Half-life

Aerobic Aquatic Metabolism kbacw 333 days Halfife

Anaerobic Aquatic Metabolism kbacs 7476 days Halfife

Aerobic Soil Metabolism asm 27.3 days Halfife

Hydrolysis: pH 7 914 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 2.91 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-3 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

=====================================================================
Page 144 of 219

APPENDIX D: Ecological Effects Characterization for Dodine and DGH

Aquatic Organism Effects Characterization

Toxicity values used in assessing risks of dodine to aquatic organisms included data from both

dodine and DGH studies. In water, these two compounds are expected to form the dodecylguanadinium

ion and their respective salts. From a toxicological perspective, it is likely that toxicity in aquatic media

for both parent compounds will reflect effects of the dodecylguanidinium ion. 

Acute Toxicity to Freshwater Invertebrates

Acute toxicity of dodine to daphnids (Daphnia magna) was determined under flow through

conditions (MRID#423396-01). Two groups of ten daphnids each (20 per treatment total) were exposed

to a negative control, solvent control and mean-measured concentrations of 36.5, 19.6, 9.1, 5.4, and 5.3

μg a.i./l. There were no control mortalities or immobilizations observed, however, 100, 55 and 1% of the

daphnids in the 36.5, 19.6 and 5.4 μg a.i./l treatments were immobilized (Table D.1.). The 48-hour EC50

was 17.8 μg a.i./l (95% C.I. = 14.8-22.3) calculated using the moving average method, which classifies

dodine as VERY HIGHLY TOXIC to daphnids on an acute exposure basis. The NOAEC was 5.3 :g

a.i./l. The study was classified as acceptable. Importantly, for this study, the mean-measured

concentrations were QC-adjusted; the mean percent quality control recovery was 73.4%. The solvent

control received 0.075 ml methanol/l. 

In another study on the acute toxicity of dodine to freshwater invertebrates, 20 daphnids per

treatment were exposed to mean-measured concentrations of 12, 19, 29, 46, and 87 μg a.i./l along with

appropriate controls (MRID#426535-01). There were no mortalities/immobilizations in the control

groups but 100, 75, and 5% mortality/immobilization in the 87, 46, and 29 μg a.i./l treatments,

respectively. The EC50 was 40 μg a.i./l (95% C.I. = 36-45) calculated using the probit method (slope =

11.6 (95% C.I. = 6.2-17.0). The study was classified as acceptable and the results indicated that dodine

could be classified as VERY HIGHLY TOXIC to daphnids on an acute exposure basis. In this study,

daphnids were exposed to radiolabeled dodine, which facilitated measurement in solution. The

formulation (solvent) control received 0.0023 ml methanol/l. 

An earlier study on the acute toxicity of dodine to freshwater invertebrates reported a higher EC50

compared to the previous two studies (Acc.#226855). Twenty daphnids each were exposed to control

conditions and 32, 56, 100, 180, and 320 ppb cytox 2160 (95% a.i. dodine). There was 100% mortality in

the two highest treatments and 5% mortality in the lowest treatment. These results precluded use of the

moving average or probit methods to calculate and EC50. The binomial analysis provided an estimate of

the EC50 of 134 (95% C.I. = 100-180). 

An study on the acute effects of DGH to Daphnia magna was also considered for this assessment

(MRID#407568-05). At the time of this assessment, however, information regarding the details of the

study was not available, only the toxicity values. Results from this study indicate that toxicity from DGH

exposure falls within the range of toxicity values for dodine. The LC50 was 29 :g a.i./l (95% C.I. = 25-

33), which is slightly higher than the lowest reported value of 17.8 :g a.i./l used for estimating risks.
Page 145 of 219

Table D.1. Acute Toxicity Values for Freshwater Invertebrates Exposed to Dodine and DGH

Study Type Species Endpoint EC50/LC50

:g a.i./l

Tox Category MRID# Study

Invert.

Acute flow through

(72-2a)

Daphnia magna Immobilization 17.8 (14.8-22.3) Very highly toxic 423396-01

(Putt, 1992)

A

Invert.

Acute flow through

(72-2a)

Daphnia magna Immobilization 40.2 (36.0-45.0) Very highly toxic 426535-01

(Putt, 1992)

A

Invert.

Acute flow through

(72-2a)

Daphnia magna Immobilization 134.6 (100-180)

probit and moving

avg. can’t be used:

re-did w/binomial

Very highly toxic Acc.#

226855

(Bauer, 1976)

A

DGH Studies

Invert.

Acute static on

formulated product

(33% a.i.)

(72-2b)

Daphnia magna Immobilization 88 (77 - 100) μg

product/L [29 (25 -

33) μg a.i./L]

MISSING DER

Very highly toxic 407568-05 A

Chronic Toxicity to Freshwater Invertebrates

 An aquatic invertebrate life cycle test was conducted to evaluate the chronic toxicity of dodine to

the freshwater aquatic invertebrate, Daphnia magna (MRID#438765-01). Daphnids were exposed to

negative and solvent control conditions and mean-measured concentrations of 4.4, 7.3, 13, 25, and 52 μg

a.i. dodine/l. There were significant effects of dodine on survival of first generation daphnids, number of

young produced, dry weight of first generation daphnids, and length of fist generation daphnids. The

most sensitive endpoint was the number of young produced with a NOEC of 7.3 μg a.i./l and a LOEC of

13 μg a.i./l (Table D.2.). The registrant reported results were lower than those reported here, however,

the registrant reported results could not be repeated. The study was conducted in a scientifically sound

manner and was classified as ACCEPTABLE (formerly CORE) meeting requirements for guideline study

72-4b. 

Table D.2. Chronic Toxicity Values for Freshwater Invertebrates Exposed to Dodine

Study Type Species Endpoint NOEC

:g a.i./l

LOEC MRID# Study
Page 146 of 219

Invert.

Life Cycle 

(72-4b)

Daphnia magna Reproduction 7.3 13 438765-01

(Putt, 1995)

A

Acute Toxicity to Freshwater Fish

Two studies were conducted to evaluate the acute toxicity of dodine to freshwater fish. The

methods for the two studies appear similar and were in accordance with 1970 Standard Methods (APHA). 

In one study, a warm water species ,bluegill sunfish (Lepomis macrochirus), were exposed to 0.75, 1.0,

2.1, 3.2, and 4.2 mg dodine/l; although no controls were reported, initial reviewers concluded that since

the study followed guideline, controls must have been included. In another study on the cold water

species, rainbow trout (Oncorhynchus mykiss), fish were exposed to 0.32, 0.75, 1.2, 1.6, and 2.1 mg

dodine/l. Similar to the bluegill study, no controls were reported yet it was assumed that controls had

been included in the design since the original report stated that methods were generally in accordance

with EPA guidelines and also in accordance with the Fish Bioassay Procedure in the 1970 edition of the

Standard Methods (APHA). Statistical determination of the LC50 was based on linear regression using

logs and probits. The 96-h LC50 for bluegill and rainbow trout were 0.86 and 0.57 mg dodine/l,

respectively (Table D.3.). The NOAECs for bluegill and rainbow trout were 0.75 mg a.i./l and 0.32 mg

a.i./l, respectively. These studies were classified as CORE (ACCEPTABLE) despite the fact that data on

control fish was not included in the original report. Both estimates of the freshwater fish LC50 fall within

the HIGHLY TOXIC categorization.

A study on the acute toxicity of DGH to rainbow trout was also available for this assessment. 

Detailed information on this study was not available. Toxicity values, however, were available and

indicate that for the conditions specific to the DGH test, toxicity to rainbow trout was similar to that of

bluegill for dodine with an LC50 of 0.890 mg a.i./l.

Table D.3. Acute Toxicity Values for Freshwater Fish Exposed to Dodine and DGH

Study Type Species Endpoint EC50/LC50

:g a.i./l

Tox Category MRID#

or Acc. #

Study

Freshwater fish

Acute toxicity

Lepomis

macrochirus

Mortality 860 (810-910) Highly toxic 132149

(Sleight,

1971)

A

Freshwater fish

Acute toxicity

Oncorhynchus

mykiss

formerly (Salmo

gairdneri)

Mortality 570 (430-750) Highly toxic 132149

(Sleight,

1971)

A

DGH
Page 147 of 219

Freshwater fish

Acute toxicity

33% a.i.

formulation

Rainbow trout

(Oncorhynchus

mykiss,

formerly Salmo

gairdneri)

Mortality

MISSING DER

890 (790 - 1000)

Highly toxic (a.i.)

434855-05 A

Chronic Toxicity to Freshwater Fish

A fish early life stage toxicity test was conducted to evaluate the toxicity of dodine to early life

stage fathead minnows, Pimephales promales (MRID#438765-02) . Embryos less than 24 hours old were

exposed to negative and solvent control conditions and mean-measured dodine concentrations of 26, 55,

99, 200, and 400 :g a.i./l. Results indicated that the most sensitive endpoints were larval length and

weight with a NOAEC of 99 :g a.i./l and a LOAEC of 200 :g a.i./l. Also, there was a significant

treatment-related effect on larval survival at 400 :g a.i./l. The study was conducted in a scientifically

sound manor with no major deviations. The study satisfied the guideline requirements for a freshwater

fish early life stage test (72-4a) and was classified as ACCEPTABLE (formerly CORE). 

Table D.4. Chronic Toxicity Values for Freshwater Fish Exposed to Dodine

Study Type Species Endpoint NOEC

:g a.i./l

LOEC

:g a.i./l

MRID# Study

Freshwater fish

early life stage

(72-4a)

Pimephales

promales

Larval length

and weight

99 200 438765-02

(Sousa, 1995)

A

Acute Toxicity to Estuarine/Marine Invertebrates

Juvenile mysid shrimp, Americamysis bahia (formerly Mysidopsis bahia), were exposed to

dodine for 96 hours under flow-through conditions (MRID# 426535-04). Mean measured test

concentrations of active ingredient were 310, 540, 980, 1700, and 3000 :g a.i./l (ppb) plus a negative

control and a formulation blank control. Some mortality occurred in all groups except the 540 ppb and

the controls. The LC50 was 2335 ppb and was calculated using the moving average method; the probit

method did not yield usable results (Table D.5). The NOAEC was 540 ppb. The study meets the

guideline requirements for an acute toxicity study on an estuarine/marine invertebrate (72-3) and was

classified as ACCEPTABLE.
Page 148 of 219

A study on mysid shrimp, Americamysis bahia, was also conducted using DGH. Mysids < 24

hours old were exposed to DGH under flow-through conditions for 96 hours at mean measured product

concentrations of <0.03 (control), 140, 200, 450, 530, and 840 ppb formulated product, which correspond

to 46, 66, 149, 176, and 279 ppb a.i. Mortality occurred in all groups with one in the control and two in

the 46 ppb mean-measured concentration. The estimated LC50 for the active ingredient was 59.4 ppb

(95% C.I. = 46 - 148 ppb) and a NOAEC < 46 ppb. The study meets the guideline requirements for an

acute toxicity study on an estuarine/marine invertebrate (72-3) and was classified as ACCEPTABLE. 

This study also represents the lowest available invertebrate toxicity value and is used in the estimation of

risks associated with dodine use. 

The LC50 from the DGH study on mysid shrimp, 59.4 ppb, is markedly lower than the LC50 from

the dodine study on mysid shrimp, which was 2335 ppb. Review of the DGH formulation used in the

mysid study indicated that there were no formulation ingredients, other than the active ingredient, that

could likely contribute to the lower LC50 seen in this test. For example, one component that contributed

17.5% by weight to the formulation has an LC50 for brown shrimp on the order of 1150 ppm. Review of

both the dodine and DGH studies do not suggest any obvious reason for the disparity in the results of

these tests. In general, it seems that the differences between DGH and dodine toxicity are more

pronounced in saltwater tests. Although DGH and dodine are expected to behave similarly in aquatic

environments, it is possible that in the presence of saltwater, the chemicals actually behave differently. 

More research may be needed to further understand the toxicity of DGH and dodine to estuarine and

marine organisms. 

A 96-hour shell deposition study was conducted to evaluate the acute toxicity of dodine to eastern

oysters (Crassostrea virginica) under flow-through conditions. Forty oysters were placed in each of the

treatments which included a dilution water control a formulation blank control and mean measured dodine

concentrations of 110, 130, 260, 370, and 670 :g a.i./L. There were significant, concentration-dependent

effects of dodine on shell deposition. However, a NOAEC could not be determined since oysters in the

lowest test concentration showed significantly less shell deposition compared to controls. The 96-hour

EC50 was 167 :g a.i./L (95% C.I. = 144 and 189 :g a.i./L) and was calculated using the probit method. 

Despite the fact that control oysters did not obtain 2 mm of shell deposition, the study is considered

scientifically sounds and meets the guideline requirements for a 96-hour flow-through mollusc shell

deposition acute toxicity test. The study is classified as ACCEPTABLE. 

A 96-hour shell deposition study was also conducted to evaluate the acute toxicity of DGH to

eastern oysters. Oysters were exposed, under flow-through conditions, to formulated product

concentrations of < 0.015 (control), 0.03, 0.08, 0.12, 0.22, and 0.36 ppm. Oysters exposed to DGH

showed significantly less shell deposition compared to controls. A NOAEC could not be determined

since oysters at the lowest exposure level showed less shell deposition compared to controls. The

estimated LC50 for the formulated product was 210 ppb (95% C.I. 160 - 300 ppb) This corresponds to an

estimated LC50 for the active ingredient of 69.3 ppb ppb (95% C.I. = 52.8 - 99 ppb). The study was

scientifically sound and classified as ACCEPTABLE. The LC50 represents the lowest toxicity value for

molluscs and was used in the assessment for estimating risks associated with uses of dodine.

Another study was conducted to evaluate the toxicity of DGH to saltwater invertebrates. At the

time of this assessment, however, details regarding the study were not available for review. Blue crabs,

Callinectes sapidus, were exposed to DGH under acute conditions. The resulting LC50 for active
Page 149 of 219

ingredient was 446 ppm (95% C.I. = 395 - 503 ppm). This classifies DGH as practically non-toxic to

blue crabs. The study was classified as SUPPLEMENTAL, likely due to the fact that blue crabs are nonguideline species.

Table D.5. Acute Toxicity Values for Estuarine/Marine Invertebrates Exposed to Dodine

Study Type Species Endpoint EC50/LC50

:g a.i./l

Tox Category MRID# Study

Estuarine shrimp

Acute flow through

(72-3)

Americamysis

bahia (formerly

Mysidopsis

bahia

Mortality 2335 (1831-3166) Practically nontoxic426535-04

(Bettencourt1992)

A

Mollusc 96-hour,

flow-through shell

deposition study

(72-3)

Crassostrea

virginica

Shell

deposition

167 (144-189) Highly toxic 426535-03

(Dionne, 1992)

A

 DGH

Marine/Estuarine

shrimp

Acute flow through

(72-3) (33% a.i.

formulation)

Americamysis

bahia (formerly

Mysidopsis

bahia

Mortality 59.4 (46.2 - 148.5)

NOEC < 46.2 

based on mortality

in lowest

treatment group

Very highly toxic 434855-07 (Jones

and Davis, 1994)

A

Marine/estuarine

mollusk, Acute

flow-through shell

deposition test (72-

3) (33.2% a.i.

formulation)

Eastern oyster

(Crassostrea

virginica)

Shell

deposition

69.3 (52.8 - 99) 

:g a.i./L]

NOEC < 9.9 

based on an 18%

decrease in shell

deposition at

lowest level tested

Very highly toxic 434855-08

(Youngerman and

Davis, 1994)

A

Marine/Estuarine

invertebrate Acute

(72-3) (40.6% a.i.

formulation)

Blue crab

(Callinectes

sapidus)

Mortality (446 (395 - 503)

mg a.i./L)

MISSING DER

Practically nontoxic40940802 S

Acute Toxicity to Estuarine/Marine Fish

Sheepshead minnow, Cyprinodon variegatus, were exposed to dodine under flow-through

conditions for 96 hours. Treatments included a control and mean-measured dodine concentrations of

0.98, 1.5, 2.5, 4.1, and 8.3 mg a.i./L. Effects included loss of equilibrium, erratic swimming behavior,

lethargy, and mortality. Mortality only occurred in the highest test concentration and was 100% by the

end of the study. Lethargy was observed in one individual in the 0.98 mg a.i./L treatment. Other sub-
Page 150 of 219

lethal effects were limited to organisms in the 2.5, 4.1, and 8.3 mg a.i./L treatments with relatively more

severe effects (in terms of number of organisms) associated with higher concentrations of dodine. The

LC50 is 5.8 mg a.i./L and was estimated using the binomial test since only the highest concentration tested

caused mortality (Table X6). The study was conducted in a scientifically sound manner and meets the

requirements for an estuarine/marine fish acute flow-through toxicity study. The study is classified as

ACCEPTABLE.

In a similar study on DGH, sheepshead minnows were exposed to <30 (control), 990, 1560, 2570,

4310, and 8220 ppb mean-measured concentrations for formulated product. The LC50 for active

ingredient was calculated to be 1782 ppb (95% C.I. = 1419 - 2706) with a NOAEC of 858 ppb. The

study was scientifically sound and classified as ACCEPTABLE.

Table D.6. Acute Toxicity Values for Estuarine/Marine Fish Exposed to Dodine

Study Type Species Endpoint EC50/LC50

:g a.i./l

Tox Category MRID# Study

Estuarine/marine

fish

Acute flow through

(72-3)

Cyprinodon

variegatus

Mortality 5833(4100-8300) Moderately toxic 426535-02

(Bettencourt1

993)

A

DGH

Estuarine/marine

fish

Acute flow through

test (72-3) (33.2%

a.i. formulation)

Sheepshead

minnow,

Cyprinodon

variegatus

Mortality 1782 (1419 - 2706) 

NOEC 858 

Moderately toxic 43485506

(Youngerman

and Davis,

1994)

A

Terrestrial Organism Effects Characterization

Acute Toxicity to Terrestrial Invertebrates

Acute toxicity of dodine to terrestrial invertebrates was assessed by exposing honey bees, Apis

millifera, to dodine via both contact and oral exposures. In the contact test, microliter of acetone solution

which contained the test compound was applied to the ventral thorax of test bees. After exposure, bees

were returned to their cages and observed for 24 hours. There were 40 bees in each group, which

included controls and 10, 50, 100, and 200 :g per bee treatments. The contact LD50 was more than 200

:g per bee, the highest dose tested. This characterizes dodine as practically non-toxic to honey bees via

contact exposure. The study was scientifically sound and classified as ACCEPTABLE.
Page 151 of 219

As part of the effort to evaluate the acute toxicity of dodine to honey bees, five suspensions of

dodine in 50% sucrose water were prepared such that they contained 10, 50, 100, and 200 :g dodine/bee

(if bee consumed 0.01 ml of test solution). Similar to the contact toxicity study, dodine did not cause

significant mortality at the doses tested. The resulting LD50 was > 200 :g per bee. The study was

conducted in a scientifically sound manner and is classified as ACCEPTABLE. 

Another acute contact toxicity study was conducted on honey bees, Apis mellifera, where bees

were exposed to only one concentration, 12.09 :g a.i. per bee. Mortality at this dose was 2.45%. 

Although there was not enough data to generate an estimate of the LD50, the study authors and EFED

reviewers concluded that dodine was relatively non-toxic to honey bees. 

Table D.7. Acute Toxicity Values for Honey Bees Exposed to Dodine

Study Type Species Endpoint LD50

:g a.i./bee

Tox Category MRID# Study

Honey Bee

acute contact

Apis mellifera Mortality > 200 Practically nontoxic4013155-05

(Van Beek,

1984)

A

Honey Bee

acute oral

Apis mellifera Mortality > 200 Practically nontoxic4013155-05

(Van Beek,

1984)

A

Honey Bee

acute contact

Apis Mellifera Mortality 2.45% at 12.09

:g/bee

Relatively nontoxic(Greywood

and

Macdonald,

1975)

A

Acute and Sub-acute Toxicity to Birds

The acute toxicity of dodine to birds was evaluated using both bobwhite quail and mallard ducks. 

Bobwhite quail, Colinus virginianus, were given single oral doses by intubation of dodine at levels of

180, 320, 560, 1000, 1800, and 3200 ppm (mg/kg body weight). Controls were also included in the

study. The estimated LC50 is 690 mg/kg (95% C.I. = 511-932 mg/kg). Other signs of toxicity included

depression and ruffled feathers. Generally, the study followed available guidelines for an acute oral avian

toxicity study with several minor deviations. The age of birds was not specified beyond “young adults”,

10 birds used at controls and high dose while 20 were used at other doses, and housing conditions were

incompletely reported. The study is considered scientifically sounds and is classified as ACCEPTABLE.

In a similar study, mallard ducks, Anas platyrhynchos, were orally exposed to dodine via

intubation. The study consisted of controls and dodine doses of 560, 1000, 1800, 3200, 5600, and 10,000
Page 152 of 219

mg/kg body weight. The estimated LD50 is 2240 mg/kg (95% C.I. = 1659-3024 mg/kg). Other signs of

toxicity included prostration, depression, and huddling. Food consumption was at first reduced but was

no significantly different from controls at 21 days. The study followed guidelines for an avian acute oral

toxicity study and is classified as ACCEPTABLE. 

Bobwhite quail (Colinus virginianus) were also used in a study to evaluate the sub-acute dietary

toxicity of dodine to a representative bird species. Bobwhite quail were provided with feed that had 0

(control), 464, 1000, 2150, 4640, and 10,000 ppm dodine. The calculated LC50 is 8413 ppm (95% C.I. =

5115-13,838 ppm). There was no mortality at the three lowest levels and 60% mortality at the highest

exposure level. Other toxic signs included depression, reduced reaction to external stimuli, wing droop,

and coordination loss. The study followed the guidelines for an acute dietary avian toxicity study and is

classified as ACCEPTABLE.

In a similar study, the dietary toxicity of dodine was also evaluated using mallard ducks (Anas

platyrhynchos). The levels of dodine in feed provided to mallards was 0 (control), 464, 1000, 2150,

4640, and 10,000 ppm dodine. There was no mortality in this study so the LC50 was greater than 10,000

mg/kg. The study followed the guidelines for an acute dietary avian toxicity study and is classified as

ACCEPTABLE. 

Table D.8. Acute and Sub-acute Toxicity Values for Birds Exposed to Dodine

Study Type Species Endpoint LD50/LC50

mg/kg or ppm

Tox Category MRID# Study

Avian acute oral Colinus

virginianus

Mortality 690 (511-932) Slightly toxic Acc.# 130888

(Howard &

Johnston

1971)

A

Avian acute oral Anas

platyrhynchos

Mortality 2240 (1659-3024) Practically nontoxicAcc.# 131455

(Carter, 1971)

A

Avian acute dietary Colinus

virginianus

Mortality 8413 (5115-13838) Practically nontoxicAcc.# 226855

(Fink 1976)

A

Avian acute dietary Anas

platyrhynchos

Mortality >10000 Practically nontoxicAcc.# 226855

(Fink, 1976)

A

Chronic Toxicity to Birds

Several studies were conducted to evaluate the chronic and reproductive toxicity of dodine to
Page 153 of 219

avian species. In one study, 20-week old bobwhite quail (Colinus virginianus) were exposed to dodine

mixed in commercial feed at concentrations of 0 (control), 200, 600, and 1000 ppm a.i. (mg dodine/kg

feed) (Pedersen, 1994; MRID# 432746-01). There were statistically significant effects of dodine on the

number of day-14 survivors, female body weights, and day-14 brood weights. However, the study was

considered INVALID since there was widespread mortality in controls and in animals prior to the start of

the study. In fact, the study authors attributed most of the observed effects to be non-related to treatments

and result of using non-suitable birds. Pre-test mortality was 8% and control mortality during the test was

16%. 

An apparent follow-up study on bobwhite quail was conducted in a scientifically sound manner

but did not satisfy guideline requirements (Pedersen, 1999; MRID# 449857-05) . In this study, 21-week

old bobwhite quail were exposed to dodine in feed at concentrations of 0 (control), 75, 150, and 300 ppm

a.i. (mg dodine/kg feed). There were no significant treatment-related effects and it was not stated whether

the highest test concentration was at or above the maximum field residue level. The study is classified as

supplemental but does not provide enough information to be used quantitatively in estimating risk to

avian species.

 An avian reproduction test was also conducted using mallard ducks, Anas platyrhynchos. 

Twenty-four-week old mallard ducks were exposed to dodine in feed at concentrations of 0 (control), 200,

600, and 1000 ppm a.i. (mg dodine/kg feed). There were significant effects of dodine on the number of

eggs laid, eggs set, viable embryos, vile 3-week embryos, hatchlings, 14-day old survivors, adult food

consumption, hatchling body weights, and adult female body weights at diet concentrations > 600 ppm

a.i. The NOAEC for these effects is 200 ppm a.i. The study was conducted in a scientifically sound

manner, meets the requirements for an avian reproduction test and is classified as ACCEPTABLE. 

Table D.9. Reproductive Toxicity Values for Birds Exposed to Dodine 

Study Type Species Endpoint NOAEL

ppm (mg/kg

feed)

MRID# Study

Avian reproduction

test

Colinus

virginianus

Various None determined 432746-01

(Pedersen 1994)

I

Avian reproduction

test

Anas

platyrhynchos

Various 200 432746-02

(Pedersen 1994)

A

Avian reproduction

test

Colinus

virginianus

Mortality > 300 449857-05

(Pedersen 1999)

S

Acute Toxicity to Mammals
Page 154 of 219

Acute toxicity data for mammals used in this assessment was obtained from the EPA Health

Effects Division (HED) (Table D.10). The acute oral LD50 for rats was 1056 mg/kg body weight for

females (MRID#44922401). Male rats appear less sensitive to dodine with an estimated LD50 of 1698

mg/kg body weight. For purposes of this assessment, the value for females was used.

Table D.10. Acute Oral Toxicity of Dodine to Mammals

Study Type Species Endpoint LD50

mg/kg body

weight

Tox Category

(HED

designation)

MRID#

Acute oral rat

870.1100

Ratus

norvegicus

Mortality 1056 females

1698 males

III 449224-01

Chronic Toxicity to Mammals

Chronic toxicity data for mammals was obtained through HED. In one study, rats were exposed

to dodine in feed at concentrations of 0 (control), 200, 400, and 800 ppm (MRID#442460-01). Exposures

were continuous over the course of two generations. Concentrations of dodine in feed were measured as

were food consumption rates. Significant effects on body weight were seen at the dodine exposure level

of 400 ppm, however, effects at this level were not considered biologically significant (< 10% difference

compared to controls). Hence, the LOAEL was considered to be the 800 ppm treatment level, where

differences in body weight exceeded 10% compared to controls. The NOAEL was 400 ppm which

corresponds to a calculated dose (based on body weight and feed consumption) of 30.28 mg/kg-d. 

Decreased pup body weight likely relates directly to survival and or timing of reproduction in wildlife

population, hence, this endpoint was considered ecologically significant. There were no other observed

effects of dodine on rat reproduction or fertility.

Another chronic study was conducted on beagle dogs. The HED summary states: 

“In a chronic toxicity study (MRID 44246101), Dodine (98.6% a.i., Batch No. 1174) was administered to

4 beagle dogs/sex/group in a gelatin capsule at doses of 0, 2, 10, and 20 mg/kg/day. The capsules were

administered orally once a day, 7 days/week, for at least 52 weeks. No statistically significant differences

were observed for group mean values in absolute body weights, overall weight changes, food

consumption, or food efficiency between the treated and control groups of either sex. However, one middose female, one high-dose female, and one high-dose male dog exhibited marked weight losses due to

reduced food consumption during the first few weeks of the study. Therefore, the LOAEL for female

beagle dogs is 10 mg/kg/day based on body weight loss by individual animals and the NOAEL for female

beagle dogs is 2 mg/kg/day. The LOAEL for male beagle dogs is 20 mg/kg/day based on body weight

loss by an individual animal and the NOAEL for male beagle dogs is 10 mg/kg/day.”

The results from this study were not used in this risk assessment since there were no statistically

significant results and the study lacked sufficient n to support use of these endpoints in the assessment. 
Page 155 of 219

Furthermore, data on rats is preferred to that of dogs due to the wider acceptability and availability of rat

data and that the body size of rats is more likely to reflect that of most mammals in the wild that may be

exposed to dodine. The study does, however, corroborate effects seen in the rat study; decreased body

weight in dodine exposed mammals.

Table D.11. Chronic Toxicity Values for Mammals Exposed to Dodine

Study Type Species Endpoint NOAEL

(mg/kg bw)

MRID#

870.3800

Reproduction and

fertility effects (rat)

Ratus

norvegicus

Primarily based on

decreased pup body

weights

30.28 442460-01

870.4100b

Chronic toxicity

(dog)

Canus

domesticus

2 mg/kg-d females

10 mg/kg-d males

442461-01
Page 156 of 219

REFERENCES

Acc. 130888. Howard, D.J. and C.D. Johnston. 1971. CYTOX 2160 - Safety Evaluation by Single Oral

Administration to Bobwhite Quail. Unpublished Study Conducted by Woodard Research Corporation for

American Cyanamid Co. 

Acc. 131455. Johnston, C.D. 1971. CYTOX 2160 - Safety Evaluation by Single Oral Administration to

Mallard Ducks. Unpublished Study Conducted by Woodard Research Corporation for American

Cyanamid Co.

Acc.132149. Sleight, Bevier Hasbrouck. 1971. The Acute Toxicity of CYTOX 2160 (ST 45093) to

Bluegill (Lepomis macrochirus) and Rainbow Trout (Onchirynchus mykiss formerly Salmo gairdneri). 

Unpublished Study Conducted by Bionomics, Inc. for American Cyanamid Co.

Acc. 226855. Fink, R. 1976. Eight-Day Dietary LC50 - Bobwhite quail - CYTOX 2160. Unpublished

Study Conducted by Wildlife International for Union Carbide Corp. Submitted by American Cyanamid

Company.

Acc. 226855. Fink, R. 1976. Eight-Day Dietary LC50 - Mallard Duck - CYTOX 2160. Unpublished

Study Conducted by Wildlife International for Union Carbide Corp. Submitted by American Cyanamid

Company.

Acc. 226855. Bauer, E.P. 1976. Acute Toxicity of CYTOX 2160 to the Water Flea, Daphnia magna

Straus. Unpublished Study Conducted by Aquatic Environmental Services, Union Carbide Corp. for

American Cyanamid Company. 

Acc. 403155-05. Van Beek, L. 1984. Acute Dermal Toxicity and Oral Toxicity Studies with Dodine in

Honey Bees. Unpublished Study Conducted by the Netherlands Organization for Applied Scientific

Research for Drexel Chemical Co.

MRID 423396-01. Putt, A.E. 1992. (Dodine Technical) - Acute Toxicity to Daphnids (Daphnia magna)

Under Flow-Through Conditions. for RhonePoulenc Ag Company.

MRID 426535-01. Putt, A.E. 1992. Dodine 65W - Acute Toxicity to Daphnids (Daphnia magna) Under

Flow-Through Conditions. for Rhone-Poulenc

Ag Company. 

MRID 426535-02. Bettencourt, M.J. 1993. Dodine 65W - Acute Toxicity to Sheepshead Minnow

(Cyprinodon variegatus) Under Flow-Through Conditions. Unpublished Study Conducted by Springborn

Laboratories, Inc. for Rhone-Poulenc Ag Company.

MRID 426535-03. Dionne, E. 1992. Dodine 65W - Acute Toxicity to Eastern Oyster (Crassostrea
Page 157 of 219

virginica) Under Flow-Through Conditions. Unpublished Study Conducted by Springborn Laboratories

for Rhone Poulenc Ag Company. 

MRID 426535-04. Bettencourt, M.J. 1992. Dodine 65W - Acute Toxicity to Mysid Shrimp (Mysidopsis

bahia) Under Flow-Through Conditions. Unpublished Study Conducted by Springborn Laboratories, Inc.

for Rhone-Poulenc Ag Company.

MRID 426951-02. Maggi, V.L. 1993. Tier I: Determination of the Phytotoxic Effects of Dodine

Fungicide on Seedling Emergence of Nontarget Plants. Unpublished Study Conducted by California

Agricultural Research, Inc. for Rhone-Poulenc Ag Company.

MRID 426951-03. Maggi, V.L. 1993. Tier I: Determination of the Phytotoxic Effects of Dodine

Fungicide on Vegetative Vigor of Nontarget Plants. Unpublished Study Conducted by California

Agricultural Research, Inc. for Rhone-Poulenc Ag Company.

MRID 432746-01. Pederson, C.A. 1994. Dodecylguanidine Acetate (Dodine) Technical Grade:

Toxicity and Reproduction Study in Bobwhite Quail. Unpublished Study Conducted by Bio-life

Associates, Ltd. for Rhone-Poulenc Ag Company.

MRID 432746-02. Pederson, C.A. 1994. Dodecylguanidine Acetate (Dodine) Technical Grade:

Toxicity and Reproduction Study in Mallard Ducks. Unpublished Study Conducted by Bio-life

Associates, Ltd. for Rhone-Poulenc Ag Company.

MRID 438765-01. Putt, A.E. 1995. Dodine Technical - The Chronic Toxicity to Daphnia magna Under

Flow-Through Conditions. Unpublished Study Conducted by Springborn Laboratories, Inc. for RhonePoulenc Ag Company.

MRID 438765-02. Sousa, J.V. 1995. Dodine Technical: The Toxicity to Fathead Minnow (Pimephales

promelas) During an Early Life-Stage Exposure. Unpublished Study Conducted by Springborn

Laboratories, Inc. for Rhone-Poulenc Ag Company. 

MRID 449857-05. Pederson, C.A. 1999. Avian Reproductive Toxicity Study with Dodecylguanidine

Acetate (Dodine) Technical in Bobwhite Quail. Unpublished Study Conducted by Bio-life Associates,

Ltd. for Rhone-Poulenc Ag Company.

MRID 464382-01. Desmares-Koopmans, M.J.E. 2002. Sediment-Water Chironomid Toxicity Test

Using Water Spiked with Dodine Technical. Unpublished Study Conducted by Notox for ChimacAgriphar S.A.

MRID 44246001. 1996. Mammalian reproduction and fertility effects (rat).
Page 158 of 219

MRID 44246101. 1996. Mammalian chronic oral toxicity (dog).

Atkins, E.L., E.A. Greywood, and R.L. Macdonald. 1975. Toxicity of Pesticides and Other Agricultural

Chemicals to Honey Bees. Laboratory Studies. University of California, Division of Agricultural

Sciences. Leaflet 2287, 38pp. 

DGH Studies

MRID 434855-07. Jones, F., and J. W. Davis. 1994. CT-334-87 - Dodecylguanidine Hydrochloride

(DGH): Acute Toxicity to the Mysid, Mysidopsis bahia, Under Continuous Flow-through Conditions. 

Unpublished Study. Conducted by Toxikon Environmental Sciences for Cytec Industries.

MRID 434855-08. Youngerman, D., and J.W. Davis. 1994. CT-334-87 - Dodecylguanidine

Hydrochloride (DGH): Acute Effect on New Shell Growth of the Eastern Oyster, Crassostrea virginica.

Unpublished Study. Conducted by Toxikon Environmental Sciences for Cytec Industries.

MRID 434855-06. Youngerman, D., and J.W. Davis. 1994. CT-334-87 - Dodecylguanidine

Hydrochloride (DGH): Acute Toxicity to the Sheepshead Minnow, Cyrpinodon variegatus, Under

Continuous Flow-through Conditions. Unpublished Study Conducted by Toxikon Environmental

Sciences for Cytec Industries.

MRID 434855-10. Helsten, B.R., and A. M. Solatycki. 1994. 8-Day Acute Dietay LC50 Study with CT334-87 (DGH) in Mallard Ducklings. Unpublished Study. Conducted by Bio-Life Associates, Ltd., for

Cytec Industries.

Other DGH Studies (no DERs)

MRID 40940802.

MRID 43485505.

MRID 40756805.

MRID 41316904

MRID 41316905

MRID 41063003

MRID 40940803
Page 159 of 219

APPENDIX E. ECOTOX References not Used in Dodine Risk Assessment

REFERENCE: Frear, D.E.H., and J.E. Boyd. 1967. Use of Daphnia magna for the Microbioassay of

Pesticides. I. Development of Standardized Techniques for Rearing Daphnia and Preparation of

Dosage-M. J. Econ. Entomol. 60(5):1228-1236

JUSTIFICATION: Methods

REFERENCE: Grutzmacher, A.D., O. Zimmermann, A. Yousef, and S.A. Hassan. 2004. The SideEffects of Pesticides Used in Integrated Production of Peaches in Brazil on the Egg Parasitoid

Trichogramma cacoeciae Marchal (Hym., Trichogrammatidae). J. Appl. Entomol. 128(6):377-

383.

JUSTIFICATION: Terrestrial invertebrate; dermal exposure

REFERENCE: Koller, W. and W.F. Wilcox. 2000. Interactive Effects of Dodine and the DMI Fungicide

Fenarimol in the Control of Apple Scab. Plant. Dis. 84:144-156.

JUSTIFICATION: Mixture

REFERENCE: Maheshwari, S.K., S.K. Gandhi, and P.C. Gupta. 1996. Effects of Fungicides on Yield

and Incidence of Purple Blotch in Onion. Tests Agrochem. Cultiv. 17:12-13.

JUSTIFICATION: Field efficacy study 

REFERENCE: Masood, K.J., M.F. Rahman, J. Narsaiah, and M. Mustafa. 1991. Hematological and

Biochemical Alterations in Rats Subjected to Dermal Application of Dodine. Indian J. Comp.

Anim. Physiol. 9(1):27-31.

JUSTIFICATION: Dermal study

REFERENCE: Mayer, F.L.J., and M.R. Ellersieck. 1986. Manual of Acute Toxicity: Interpretation and

Data Base for 410 Chemicals and 66 Species of Freshwater Animals. Resour. Publ. No. 160,

U.S. Dep. Interior, Fish Wildl. Serv., Washington, D.C.: 505pp. (USGS Data File)

JUSTIFICATION: Summary/review

REFERENCE: Mitjans, M., and M.P. Vinardell. 1998. Effects of Dodine (n-Dodecylguanidine Acetate)

Subchronic Treatment on Intestinal Morphology and Brush Border Enzymatic Activity in Rats. 

Pestic. Biochem. Physiol. 62(2)96-101. 

JUSTIFICATION: Endpoint not used to assess risks.

REFERENCE: Mitjans, M., and M.P. Vinardell. 1999. Hematological and Biochemical Parameters in

the Rat Following Subchronic Oral Administration of Dodine (n-Dodecylguanidine Acetate). 

Pestic. Biochem. Physiol. 65(3):151-159.

JUSTIFICATION: No effects
Page 160 of 219

REFERENCE: Reilly, C.C., and B.W. Wood. 1996. No Adverse Effect of Early Season Fungicide and

Zinc Sprays on Leaf Area, Fruit Set, and Nut Quality of Pecan. Hortscience 31(5):808-810.

JUSTIFICATION: Mixed trials - dodine combined with other chemicals.
Page 161 of 219

APPENDIX F. Spray Drift Assessment: AgDRIFT Modeling Approach and Results

The AgDRIFT model (Version 2.01) was used to refine the spray drift exposure estimate for aquatic

invertebrates. Downwind spray drift buffers were developed for possible use in mitigating risks to

endangered freshwater invertebrates in aquatic ecosystems that are within close proximity to agricultural

fields that may be treated with liquid spray applications of dodine. The model was used to estimate spray

buffer distances for aerial and orchard airblast application to reach the EEC in the ecological water body

for which the endangered species LOC for invertebrates would not be exceeded (0.89 ppb). 

A summary of the results of the AgDRIFT modeling for aerial and orchard airblast applications of dodine

is presented in Table F-1. Spray drift buffers or distances required to reduce spray drift such that

endangered species LOCs for invertebrates are not exceeded are estimated for aerial and orchard airblast

applications of dodine at the highest and lowest maximum national use rates. The range of dissipation

distances is dependant on a number of input variables including droplet size, release height, canopy

characteristics etc., which are discussed in further detail for aerial and orchard airblast applications below. 

Drift dissipation distances for endangered species, based on aerial applications, are expected to exceed the

1,000 foot limit of the AgDRIFT Tier II aerial model based on conservative defaults (i.e., fine spray, 15

foot release height and 15 mph wind speed). Modeled dissipation distances for endangered invertebrates,

based on aerial application of dodine at 1.3 and 2.6 lbs ai/A assuming a 10 foot release in wind speeds of

10 mph and a medium droplet size, are expected to range from approximately 643 to 880 feet. Tier I

modeled dissipation distances for endangered invertebrates , based on orchard airblast application of

dodine at 1.3 and 2.6 lbs ai/A, are expected to range from approximately 76 to 154 feet. Label language

that requires spray drift mitigation measures (i.e., lower release heights, wind speed restrictions, and

specification of spray droplet sizes) is recommended.

Table F-1. Summary of AgDRIFT Modeling Results for Endangered Invertebrates

Crop/

Application

rate

Tier II Aerial Model Inputs Buffer Distance

for Aerial

Application a (ft)

Buffer Distance

for Orchard

Airblast

Application b (ft) ASEA 572

Droplet

Size

Release

Height (ft)

Wind

Speed

(mph)

Pecans, peaches,

walnuts

 2.6 lbs ai/A

Fine 15 15 > 1,000 154

10 10 > 1,000

Medium 15 15 > 1,000

10 10 880

Cherries

1.3 lbs ai/A

Fine 15 15 > 1,000 76

10 10 > 1,000

Medium 15 15 > 1,000
Page 162 of 219

10 10 643

a Tier II aerial model

b Tier I orchard airblast model with a correction factor of three to account for variability in field trial data used in model 

Orchard Airblast Application

The most important factors affecting spray drift from orchard airblast applications are canopy

characteristics such as canopy height, density, and spacing. Tall, very dense, or sparse orchards tend to

result in higher off-target drift. Other factors that also affect drift are wind speed and application

parameters such as the amount of spray being directed above tree height, spraying in spaces between

trees, and turning off outwardly pointed nozzles at ends of rows and outside rows. Airblast sprays tend to

be relatively fine. Very fine sprays, such as those produced with mist blower equipment may result in

higher downwind deposition at greater distances than predicted based on airblast sprayer data. Shrouded

sprayers, wraparound sprayers, or tower sprayers which direct spray horizontally or downward tend to

minimize spray drift relative to radial airblast sprayers which can direct a significant portion of spray

upwards. 

The orchard airblast model of AgDRIFT is empirically based on field data. Presently, the orchard

airblast portion of AgDRIFT is the least conservative because the data do not capture relatively high drift

conditions and instead reflect typical to low drift application conditions for many orchards. The airblast

data is consistent with applications in relatively low wind speeds (<10 mph), shutting off outward pointed

nozzles when turning corners, wind direction perpendicular to orchard rows, minimizing spray above tree

tops, and incomplete analytical recoveries. 

Although the product labels for dodine contain the statement, “Do not apply when weather conditions

favor drift from treated areas”, they do not specify canopy characteristics, wind speeds, or specific drift

reduction measures for airblast applications. Therefore, for this screening-level assessment in order to

account for field trial variability, the orchard deposition results were multiplied by a correction factor. 

Based on the variability in field trial data, a three-fold correction factor was used to estimate a 95th

percentile deposition for orchards in general (OPP EFED, 1999). Specifically, for determining the buffer

sizes for orchard airblast applications with dodine, the toxicological endpoint for endangered freshwater

invertebrates, 0.89 ppb, was divided by 3(0.297 ppb) and was used as the initial average concentration in

the EPA-defined pond. 

Tier I modeled buffer distances for endangered invertebrates , based on orchard airblast application of

dodine at 1.3 and 2.6 lbs ai/A, are expected to range from approximately 76 to 154 feet (Table F1).

Aerial Application

The most important factors affecting drift from aerial applications are spray droplet size, release height,

and wind speed. The aerial part of the AgDRIFT model predicts mean dissipation distances based on the

inputs provided. When wind speed and/or release height is lower than the modeled values, the spray drift

levels would expected to be lower. Conversely, in instances where applications may be made in higher
Page 163 of 219

wind speeds or at a higher release height, these inputs may not be adequately conservative and higher tier

modeling may be necessary.

Although the product labels for dodine contain the statement, “Do not apply when weather conditions

favor drift from treated areas”, they do not specify release heights, wind speeds, or spray droplet sizes for

aerial applications. Although the label does not specify a droplet size for aerial application of dodine,

fixed winged applications (applications made by airplanes) are limited in the coarsest droplet size that can

be sprayed. Typical fixed wing aerial application speeds exceed 120 mph. At these speeds, coarse

droplets shatter and produce medium or finer sprays. Therefore, it is generally inappropriate to model

coarse sprays for fixed wing applications without some restriction on flight speed. 

For aerial applications, the model contains three tiers of increasing complexity. 

Tier I Aerial Modeling

The AgDRIFT Tier I model for aerial application limits the input parameters to droplet size only. The

output of the Tier I AgDRIFT model provides distances required to dissipate spray drift to the endangered

species invertebrate toxicological endpoint (0.89 ppb) . Based on a fine to medium default spray,

dissipation distances from the edge of the field that are protective of both endangered invertebrates were

>1,000 ft and 824 ft for 2.6 and 1.3 lbs ai/A, respectively. 

Tier II Aerial Modeling

Tier II aerial spray drift estimates were also derived for dodine because this level of modeling allows for

greater control over input and output options. With the exception of droplet size, wind speed, and release

height, AgDRIFT default parameters were used for all other variables in the Tier II model. Tier II

modeling was done for a combination of input parameters: application rate (2.6 and 1.3 lbs ai/A), wind

speed (15 and 10 mph), release height (15 and 10 ft), and droplet size (fine and medium). The results

suggest that for all combinations, except for the least conservative scenario (medium spray with a 10 ft

release height and 10 mph winds), the required no-spray zone would exceed the 1,000 ft limit in the Tier

II model. The modeled no-spray buffers, assuming a 10 foot release in wind speeds of 10 mph and a

medium droplet size, were 643 to 880 ft for 1.3 and 2.6 lbs ai/A, respectively (Table F1).
Page 164 of 219

APPENDIX G. Listed Species by State 

Species Details by State for Preliminary Assessment

Cherries, sweet (188), Cherries, tart (198), Peaches (142), Pears (144), 

Pecans (145), Strawberries (180), Walnuts, English (62)

Minimum of 100 Acres.

Alabama (49 species)

Group Critical Habitat

AMPHIANTHUS, LITTLE Plant No

BAT, GRAY Mammal No

BAT, INDIANA Mammal Yes

CAMPELOMA, SLENDER Snail No

CLUBSHELL, OVATE Clam No

CLUBSHELL, SOUTHERN Clam No

DARTER, BOULDER Fish No

DARTER, SLACKWATER Fish Yes

EAGLE, BALD Bird No

ELIMIA, LACY Snail No

FERN, AMERICAN HART'S-TONGUE Plant No

HARPERELLA Plant No

HEELSPLITTER, INFLATED Clam No

KIDNEYSHELL, TRIANGULAR Clam No

MOCCASINSHELL, COOSA Clam No

MOUSE, ALABAMA BEACH Mammal Yes

MOUSE, PERDIDO KEY BEACH Mammal Yes

PEARLYMUSSEL, CUMBERLAND MONKEYFACE Clam No

PEARLYMUSSEL, ORANGE-FOOTED Clam No

PEARLYMUSSEL, PINK MUCKET Clam No

PIGTOE, HEAVY (=JUDGE TAIT'S MUSSEL) Clam No
Page 165 of 219

PIGTOE, ROUGH Clam No

PITCHER-PLANT, ALABAMA CANEBRAKE Plant No

PLOVER, PIPING Bird Yes

POCKETBOOK, FINE-LINED Clam No

POCKETBOOK, SHINY-RAYED Clam No

Thursday, April 21, 2005 Page 1 of 27
Page 166 of 219

POTATO-BEAN, PRICE'S Plant No

PRAIRIE-CLOVER, LEAFY Plant No

QUILLWORT, LOUISIANA Plant No

RIVERSNAIL, ANTHONY'S Snail No

ROCKSNAIL, PAINTED Snail No

ROCKSNAIL, PLICATE Snail No

SALAMANDER, FLATWOODS Amphibian No

SALAMANDER, RED HILLS Amphibian No

SHINER, CAHABA Fish No

SNAIL, ARMORED Snail No

SNAIL, TULOTOMA Snail No

SNAKE, EASTERN INDIGO Reptile No

STORK, WOOD Bird No

STURGEON, ALABAMA Fish No

STURGEON, GULF Fish Yes

SUNFLOWER, EGGERT'S Plant No

TORTOISE, GOPHER Reptile No

TREEFROG, PINE BARRENS Amphibian No

TRILLIUM, RELICT Plant No

TURTLE, ALABAMA RED-BELLIED Reptile No

TURTLE, FLATTENED MUSK Reptile No

TURTLE, LOGGERHEAD SEA Reptile No

WOODPECKER, RED-COCKADED Bird No

Arizona (33 species)

Group Critical Habitat

AGAVE, ARIZONA Plant No

BAT, LESSER (=SANBORN'S) LONG-NOSED Mammal No

CACTUS, ARIZONA HEDGEHOG Plant No
Page 167 of 219

CACTUS, COCHISE PINCUSHION Plant No

CACTUS, NICHOL'S TURK'S HEAD Plant No

CATFISH, YAQUI Fish Yes

Chub, Gila Fish No

Thursday, April 21, 2005 Page 2 of 27
Page 168 of 219

CHUB, YAQUI Fish Yes

CLIFFROSE, ARIZONA Plant No

DOCK, CHIRICAHUA Plant No

EAGLE, BALD Bird No

FALCON, NORTHERN APLOMADO Bird No

FLYCATCHER, SOUTHWESTERN WILLOW Bird Yes

FROG, CHIRICAHUA LEOPARD Amphibian No

JAGUAR Mammal No

Jaguarundi, Sinaloan Mammal No

LADIES'-TRESSES, CANELO HILLS Plant No

MINNOW, LOACH Fish Yes

OCELOT Mammal No

OWL, MEXICAN SPOTTED Bird Yes

PLOVER, MOUNTAIN Bird No

PRONGHORN, SONORAN Mammal No

PUPFISH, DESERT Fish Yes

PYGMY-OWL, CACTUS FERRUGINOUS Bird Yes

RAIL, YUMA CLAPPER Bird No

RATTLESNAKE, NEW MEXICAN RIDGE-NOSED Reptile Yes

SALAMANDER, SONORA TIGER Amphibian No

SHINER, BEAUTIFUL Fish Yes

SPIKEDACE Fish Yes

SUCKER, RAZORBACK Fish Yes

TOPMINNOW, GILA (YAQUI) Fish No

UMBEL, HUACHUCA WATER Plant Yes

WOLF, GRAY Mammal Yes

Arkansas (10 species)

Group Critical Habitat
Page 169 of 219

BAT, GRAY Mammal No

DARTER, LEOPARD Fish Yes

EAGLE, BALD Bird No

MUSSEL, SCALESHELL Clam No

Thursday, April 21, 2005 Page 3 of 27
Page 170 of 219

PEARLYMUSSEL, PINK MUCKET Clam No

POCKETBOOK, FAT Clam No

ROCK-POCKETBOOK, OUACHITA (=WHEELER'S PM) Clam No

STURGEON, PALLID Fish No

TERN, INTERIOR (POPULATION) LEAST Bird No

WOODPECKER, RED-COCKADED Bird No

California (233 species)

Group Critical Habitat

ADOBE SUNBURST, SAN JOAQUIN Plant No

ALLOCARYA, CALISTOGA Plant No

ALOPECURUS, SONOMA Plant No

AMBROSIA, SAN DIEGO Plant No

Amole, Camatta Canyon Plant Yes

AMOLE, PURPLE Plant Yes

ASTER, DEL MAR SAND Plant No

BACCHARIS, ENCINITAS Plant No

BARBERRY, ISLAND Plant No

BARBERRY, NEVIN'S Plant No

BEDSTRAW, EL DORADO Plant No

BEDSTRAW, ISLAND Plant No

BEETLE, DELTA GREEN GROUND Insect Yes

BEETLE, MOUNT HERMON JUNE Insect No

BEETLE, OHLONE TIGER Insect No

BEETLE, VALLEY ELDERBERRY LONGHORN Insect Yes

BIRD'S-BEAK, PALMATE-BRACTED Plant No

BIRD'S-BEAK, PENNELL'S Plant No

BIRD'S-BEAK, SALT MARSH Plant No

BIRD'S-BEAK, SOFT Plant No
Page 171 of 219

BLUEGRASS, NAPA Plant No

BLUEGRASS, SAN BERNARDINO Plant No

BRODIAEA, THREAD-LEAVED Plant No

BROOM, SAN CLEMENTE ISLAND Plant No

Thursday, April 21, 2005 Page 4 of 27
Page 172 of 219

BUCKWHEAT, IONE (IRISH HILL) Plant No

BUSH-MALLOW, SAN CLEMENTE ISLAND Plant No

BUSHMALLOW, SANTA CRUZ ISLAND Plant No

BUTTERFLY, BAY CHECKERSPOT Insect Yes

BUTTERFLY, BEHREN'S SILVERSPOT Insect No

BUTTERFLY, CALLIPPE SILVERSPOT Insect No

BUTTERFLY, EL SEGUNDO BLUE Insect No

BUTTERFLY, LANGE'S METALMARK Insect No

BUTTERFLY, LOTIS BLUE Insect No

BUTTERFLY, MYRTLE'S SILVERSPOT Insect No

BUTTERFLY, PALOS VERDES BLUE Insect Yes

BUTTERFLY, SMITH'S BLUE Insect No

BUTTERWEED, LAYNE'S Plant No

BUTTON-CELERY, SAN DIEGO Plant No

CACTUS, BAKERSFIELD Plant No

CEANOTHUS, COYOTE Plant No

CEANOTHUS, PINE HILL Plant No

CHECKER-MALLOW, KECK'S Plant Yes

CHECKER-MALLOW, KENWOOD MARSH Plant No

CHUB, MOHAVE TUI Fish No

CLARKIA, PISMO Plant No

CLARKIA, PRESIDIO Plant No

CLARKIA, SPRINGVILLE Plant No

CLARKIA, VINE HILL Plant No

CLOVER, MONTEREY Plant No

CLOVER, SHOWY INDIAN Plant No

CONDOR, CALIFORNIA Bird Yes

COYOTE-THISTLE, LOCH LOMOND Plant No
Page 173 of 219

CRAYFISH, SHASTA Crustacean No

CROWN-BEARD, BIG-LEAVED Plant No

CYPRESS, GOWEN Plant No

CYPRESS, SANTA CRUZ Plant No

Thursday, April 21, 2005 Page 5 of 27
Page 174 of 219

DUDLEYA, CONEJO Plant No

DUDLEYA, MARCESCENT Plant No

DUDLEYA, SANTA CLARA VALLEY Plant No

DUDLEYA, SANTA CRUZ ISLAND Plant No

DUDLEYA, SANTA MONICA MOUNTAINS Plant No

DUDLEYA, VERITY'S Plant No

EAGLE, BALD Bird No

EVENING-PRIMROSE, ANTIOCH DUNES Plant Yes

EVENING-PRIMROSE, SAN BENITO Plant No

FIDDLENECK, LARGE-FLOWERED Plant Yes

FLANNELBUSH, MEXICAN Plant No

FLANNELBUSH, PINE HILL Plant No

FLY, DELHI SANDS FLOWER-LOVING Insect No

FLYCATCHER, SOUTHWESTERN WILLOW Bird Yes

FOX, SAN JOAQUIN KIT Mammal No

FOX, SAN MIGUEL ISLAND Mammal No

FOX, SANTA CATALINA ISLAND Mammal No

FOX, SANTA CRUZ ISLAND Mammal No

FOX, SANTA ROSA ISLAND Mammal No

FRINGEPOD, SANTA CRUZ ISLAND Plant No

FROG, CALIFORNIA RED-LEGGED Amphibian No

FROG, MOUNTAIN YELLOW-LEGGED Amphibian No

GILIA, HOFFMANN'S SLENDER-FLOWERED Plant No

GILIA, MONTEREY Plant No

GNATCATCHER, COASTAL CALIFORNIA Bird Yes

GOBY, TIDEWATER Fish Yes

GOLDEN SUNBURST, HARTWEG'S Plant No

GOLDFIELDS, BURKE'S Plant No
Page 175 of 219

GOLDFIELDS, CONTRA COSTA Plant Yes

GRASS, CALIFORNIA ORCUTT Plant No

GRASS, COLUSA Plant Yes

GRASS, HAIRY ORCUTT Plant Yes

Thursday, April 21, 2005 Page 6 of 27
Page 176 of 219

GRASS, SACRAMENTO ORCUTT Plant Yes

GRASS, SAN JOAQUIN VALLEY ORCUTT Plant Yes

GRASS, SLENDER ORCUTT Plant Yes

GRASS, SOLANO Plant Yes

GRASSHOPPER, ZAYANTE BAND-WINGED Insect Yes

JEWELFLOWER, CALIFORNIA Plant No

KANGAROO RAT, FRESNO Mammal Yes

KANGAROO RAT, GIANT Mammal No

KANGAROO RAT, MORRO BAY Mammal Yes

KANGAROO RAT, STEPHENS' Mammal No

KANGAROO RAT, TIPTON Mammal No

LARKSPUR, SAN CLEMENTE ISLAND Plant No

LARKSPUR, YELLOW Plant Yes

LAYIA, BEACH Plant No

LILY, PITKIN MARSH Plant No

LIVEFOREVER, LAGUNA BEACH Plant No

LIVEFOREVER, SANTA BARBARA ISLAND Plant No

LIZARD, BLUNT-NOSED LEOPARD Reptile No

LIZARD, ISLAND NIGHT Reptile No

LUPINE, CLOVER Plant No

LUPINE, NIPOMO MESA Plant No

MALACOTHRIX, ISLAND Plant No

MALACOTHRIX, SANTA CRUZ ISLAND Plant No

MALLOW, KERN Plant No

MANZANITA, DEL MAR Plant No

MANZANITA, IONE Plant No

MANZANITA, MORRO Plant No

MANZANITA, PALLID Plant No
Page 177 of 219

MANZANITA, SANTA ROSA ISLAND Plant No

MEADOWFOAM, BUTTE COUNTY Plant Yes

MEADOWFOAM, SEBASTOPOL Plant No

MILK-VETCH, BRAUNTON'S Plant No

Thursday, April 21, 2005 Page 7 of 27
Page 178 of 219

MILK-VETCH, CLARA HUNT'S Plant No

MILK-VETCH, COASTAL DUNES Plant No

MILK-VETCH, VENTURA MARSH Plant Yes

MINT, OTAY MESA Plant No

MINT, SAN DIEGO MESA Plant No

MONARDELLA, WILLOWY Plant No

MORNING-GLORY, STEBBINS Plant No

MOTH, KERN PRIMROSE SPHINX Insect No

MOUNTAIN BEAVER, POINT ARENA Mammal No

MOUNTAINBALM, INDIAN KNOB Plant No

MOUNTAIN-MAHOGANY, CATALINA ISLAND Plant No

MOUSE, PACIFIC POCKET Mammal No

MOUSE, SALT MARSH HARVEST Mammal No

MURRELET, MARBLED Bird Yes

NAVARRETIA, FEW-FLOWERED Plant No

NAVARRETIA, MANY-FLOWERED Plant No

NAVARRETIA, SPREADING Plant No

OTTER, SOUTHERN SEA Mammal No

OWL, NORTHERN SPOTTED Bird Yes

OWL'S-CLOVER, FLESHY Plant Yes

PAINTBRUSH, SAN CLEMENTE ISLAND INDIAN Plant No

PAINTBRUSH, SOFT-LEAVED Plant No

PAINTBRUSH, TIBURON Plant No

PELICAN, BROWN Bird No

PENTACHAETA, LYON'S Plant No

PENTACHAETA, WHITE-RAYED Plant No

PHACELIA, ISLAND Plant No

PIPERIA, YADON'S Plant No
Page 179 of 219

PLOVER, MOUNTAIN Bird No

PLOVER, WESTERN SNOWY Bird No

POLYGONUM, SCOTT'S VALLEY Plant Yes

POTENTILLA, HICKMAN'S Plant No

Thursday, April 21, 2005 Page 8 of 27
Page 180 of 219

PUPFISH, DESERT Fish Yes

PUSSYPAWS, MARIPOSA Plant No

RABBIT, RIPARIAN BRUSH Mammal No

RAIL, CALIFORNIA CLAPPER Bird No

RAIL, LIGHT-FOOTED CLAPPER Bird No

ROCK-CRESS, HOFFMANN'S Plant No

ROCK-CRESS, MCDONALD'S Plant No

ROCK-CRESS, SANTA CRUZ ISLAND Plant No

RUSH-ROSE, ISLAND Plant No

SALAMANDER, CALIFORNIA TIGER Amphibian No

SALAMANDER, SANTA CRUZ LONG-TOED Amphibian No

SALMON, CHINOOK (CALIFORNIA COASTAL ESU) Fish Yes

SALMON, CHINOOK (CENTRAL VALLEY SPRING RUN) Fish Yes

SALMON, CHINOOK (SACRAMENTO RIVER WINTER RUN) Fish No

SALMON, COHO (CENTRAL CALIFORNIA COAST POP) Fish No

SALMON, COHO (SOUTHERN OR/NORTHERN CA COAST) Fish No

SANDWORT, MARSH Plant No

SEA-BLITE, CALIFORNIA Plant No

SEAL, GUADALUPE FUR Mammal No

SEDGE, WHITE Plant No

SHEEP, PENINSULAR BIGHORN Mammal Yes

SHREW, BUENA VISTA Mammal No

SHRIKE, SAN CLEMENTE LOGGERHEAD Bird No

SHRIMP, CALIFORNIA FRESHWATER Crustacean No

SHRIMP, CONSERVANCY FAIRY Crustacean Yes

SHRIMP, LONGHORN FAIRY Crustacean Yes

SHRIMP, RIVERSIDE FAIRY Crustacean No

SHRIMP, SAN DIEGO FAIRY Crustacean Yes
Page 181 of 219

SHRIMP, VERNAL POOL FAIRY Crustacean Yes

SHRIMP, VERNAL POOL TADPOLE Crustacean Yes

SKIPPER, LAGUNA MOUNTAIN Insect No

SMELT, DELTA Fish No

Thursday, April 21, 2005 Page 9 of 27
Page 182 of 219

SNAIL, MORRO SHOULDERBAND Snail Yes

SNAKE, GIANT GARTER Reptile No

SNAKE, SAN FRANCISCO GARTER Reptile No

SPARROW, SAN CLEMENTE SAGE Bird No

SPINEFLOWER, BEN LOMOND Plant No

SPINEFLOWER, HOWELL'S Plant No

SPINEFLOWER, MONTEREY Plant Yes

SPINEFLOWER, ORCUTT'S Plant No

SPINEFLOWER, ROBUST Plant Yes

SPINEFLOWER, SCOTTS VALLEY Plant Yes

SPINEFLOWER, SLENDER-HORNED Plant No

SPINEFLOWER, SONOMA Plant No

SPURGE, HOOVER'S Plant Yes

STEELHEAD, CALIFORNIA CENTRAL VALLEY POP Fish Yes

STEELHEAD, CENTRAL CALIFORNIA POPULATION Fish Yes

STEELHEAD, NORTHERN CALIFORNIA POPULATION Fish No

STEELHEAD, SOUTH-CENTRAL CALIFORNIA POP Fish Yes

STEELHEAD, SOUTHERN CALIFORNIA POPULATION Fish Yes

STICKLEBACK, UNARMORED THREESPINE Fish Yes

STICKYSEED, BAKER'S Plant No

STONECROP, LAKE COUNTY Plant No

SUCKER, SANTA ANA Fish Yes

TARPLANT, GAVIOTA Plant Yes

TARPLANT, OTAY Plant Yes

TARPLANT, SANTA CRUZ Plant Yes

TERN, CALIFORNIA LEAST Bird No

THISTLE, CHORRO CREEK BOG Plant No

THISTLE, FOUNTAIN Plant No
Page 183 of 219

THISTLE, LA GRACIOSA Plant Yes

THISTLE, SUISUN Plant No

THORNMINT, SAN DIEGO Plant No

TOAD, ARROYO SOUTHWESTERN Amphibian Yes

Thursday, April 21, 2005 Page 10 of 27
Page 184 of 219

TORTOISE, DESERT Reptile No

TROUT, LAHONTAN CUTTHROAT Fish No

TROUT, LITTLE KERN GOLDEN Fish Yes

TROUT, PAIUTE CUTTHROAT Fish No

TUCTORIA, GREEN'S Plant Yes

TURTLE, OLIVE (PACIFIC) RIDLEY SEA Reptile No

VIREO, LEAST BELL'S Bird Yes

WALLFLOWER, BEN LOMOND Plant No

WALLFLOWER, CONTRA COSTA Plant Yes

WALLFLOWER, MENZIE'S Plant No

WATERCRESS, GAMBEL'S Plant No

WHIPSNAKE (=striped racer), ALAMEDA Reptile Yes

WOODLAND-STAR, SAN CLEMENTE ISLAND Plant No

WOODRAT, RIPARIAN Mammal No

WOOLLY-STAR, SANTA ANA RIVER Plant No

WOOLLY-THREADS, SAN JOAQUIN Plant No

YERBA SANTA, LOMPOC Plant Yes

Colorado (8 species)

Group Critical Habitat

CACTUS, UINTA BASIN HOOKLESS Plant No

CHUB, BONYTAIL Fish Yes

CHUB, HUMPBACK Fish Yes

EAGLE, BALD Bird No

FERRET, BLACK-FOOTED Mammal No

SQUAWFISH, COLORADO Fish Yes

SUCKER, RAZORBACK Fish Yes

WILD-BUCKWHEAT, CLAY-LOVING Plant Yes

Connecticut (4 species)
Page 185 of 219

Group Critical Habitat

EAGLE, BALD Bird No

MUSSEL, DWARF WEDGE Clam No

STURGEON, SHORTNOSE Fish No

Thursday, April 21, 2005 Page 11 of 27
Page 186 of 219

WHALE, NORTHERN RIGHT Mammal Yes

Delaware (5 species)

Group Critical Habitat

EAGLE, BALD Bird No

PINK, SWAMP Plant No

PLOVER, PIPING Bird Yes

SQUIRREL, DELMARVA PENINSULA FOX Mammal No

WHALE, NORTHERN RIGHT Mammal Yes

Florida (61 species)

Group Critical Habitat

ASTER, FLORIDA GOLDEN Plant No

BANKCLIMBER, PURPLE Clam No

BAT, GRAY Mammal No

BAT, INDIANA Mammal Yes

BEARGRASS, BRITTON'S Plant No

BLAZING STAR, SCRUB Plant No

BONAMIA, FLORIDA Plant No

BUCKWHEAT, SCRUB Plant No

CAMPION, FRINGED Plant No

CARACARA, AUDUBON'S CRESTED Bird No

CHAFFSEED, AMERICAN Plant No

CLADONIA, FLORIDA PERFORATE Plant No

DARTER, OKALOOSA Fish No

EAGLE, BALD Bird No

FRINGE TREE, PYGMY Plant No

GOOSEBERRY, MICCOSUKEE (FLORIDA) Plant No

HAREBELLS, AVON PARK Plant No

HYPERICUM, HIGHLANDS SCRUB Plant No
Page 187 of 219

JAY, FLORIDA SCRUB Bird No

KITE, EVERGLADE SNAIL Bird Yes

LUPINE, SCRUB Plant No

MANATEE, WEST INDIAN (FLORIDA) Mammal Yes

Thursday, April 21, 2005 Page 12 of 27
Page 188 of 219

MEADOWRUE, COOLEY'S Plant No

MINT, LONGSPURRED Plant No

MOCCASINSHELL, GULF Clam No

MOCCASINSHELL, OCHLOCKONEE Clam No

MOUSE, CHOCTAWHATCHEE BEACH Mammal Yes

MOUSE, PERDIDO KEY BEACH Mammal Yes

MUSTARD, CARTER'S Plant No

PIGTOE, OVAL Clam No

PINKROOT, GENTIAN Plant No

PLOVER, PIPING Bird Yes

PLUM, SCRUB Plant No

POCKETBOOK, SHINY-RAYED Clam No

POLYGALA, LEWTON'S Plant No

RHODODENDRON, CHAPMAN Plant No

ROSEMARY, SHORT-LEAVED Plant No

SALAMANDER, FLATWOODS Amphibian No

SANDLACE Plant No

SAWFISH, SMALLTOOTH Fish No

SHRIMP, SQUIRREL CHIMNEY CAVE Crustacean No

SKINK, BLUE-TAILED MOLE Reptile No

SKINK, SAND Reptile No

SLABSHELL, CHIPOLA Clam No

SNAKE, EASTERN INDIGO Reptile No

SPARROW, FLORIDA GRASSHOPPER Bird No

STORK, WOOD Bird No

STURGEON, GULF Fish Yes

STURGEON, SHORTNOSE Fish No

THREERIDGE, FAT Clam No
Page 189 of 219

TORREYA, FLORIDA Plant No

TURTLE, GREEN SEA Reptile Yes

TURTLE, LEATHERBACK SEA Reptile Yes

TURTLE, LOGGERHEAD SEA Reptile No

Thursday, April 21, 2005 Page 13 of 27
Page 190 of 219

WAREA, WIDE-LEAF Plant No

WHALE, NORTHERN RIGHT Mammal Yes

WHITLOW-WORT, PAPERY Plant No

WINGS, PIGEON Plant No

WIREWEED Plant No

WOODPECKER, RED-COCKADED Bird No

ZIZIPHUS, FLORIDA Plant No

Georgia (26 species)

Group Critical Habitat

AMPHIANTHUS, LITTLE Plant No

BANKCLIMBER, PURPLE Clam No

BAT, INDIANA Mammal Yes

BEETLE, AMERICAN BURYING Insect No

CAMPION, FRINGED Plant No

DROPWORT, CANBY'S Plant No

EAGLE, BALD Bird No

MOCCASINSHELL, GULF Clam No

PIGTOE, OVAL Clam No

PITCHER-PLANT, GREEN Plant No

PLOVER, PIPING Bird Yes

POCKETBOOK, SHINY-RAYED Clam No

PONDBERRY Plant No

QUILLWORT, BLACK-SPORED Plant No

QUILLWORT, MAT-FORMING Plant No

RATTLEWEED, HAIRY Plant No

SALAMANDER, FLATWOODS Amphibian No

SNAKE, EASTERN INDIGO Reptile No

STORK, WOOD Bird No
Page 191 of 219

STURGEON, GULF Fish Yes

STURGEON, SHORTNOSE Fish No

THREERIDGE, FAT Clam No

TORREYA, FLORIDA Plant No

Thursday, April 21, 2005 Page 14 of 27
Page 192 of 219

TRILLIUM, RELICT Plant No

TURTLE, LOGGERHEAD SEA Reptile No

WOODPECKER, RED-COCKADED Bird No

Idaho (3 species)

Group Critical Habitat

EAGLE, BALD Bird No

PEPPERGRASS, SLICK SPOT Plant No

TROUT, BULL Fish No

Illinois (7 species)

Group Critical Habitat

AMPHIPOD, ILLINOIS CAVE Crustacean No

ASTER, DECURRENT FALSE Plant No

BAT, INDIANA Mammal Yes

EAGLE, BALD Bird No

POTATO-BEAN, PRICE'S Plant No

STURGEON, PALLID Fish No

TERN, INTERIOR (POPULATION) LEAST Bird No

Kansas (8 species)

Group Critical Habitat

BAT, GRAY Mammal No

CRANE, WHOOPING Bird Yes

EAGLE, BALD Bird No

MADTOM, NEOSHO Fish No

MILKWEED, MEAD'S Plant No

PLOVER, PIPING Bird Yes

SHINER, ARKANSAS RIVER Fish Yes

TERN, INTERIOR (POPULATION) LEAST Bird No

Kentucky (4 species)
Page 193 of 219

Group Critical Habitat

BAT, INDIANA Mammal Yes

EAGLE, BALD Bird No

STURGEON, PALLID Fish No

Thursday, April 21, 2005 Page 15 of 27
Page 194 of 219

TERN, INTERIOR (POPULATION) LEAST Bird No

Louisiana (10 species)

Group Critical Habitat

BEAR, LOUISIANA BLACK Mammal Yes

EAGLE, BALD Bird No

HEELSPLITTER, INFLATED Clam No

PEARLSHELL, LOUISIANA Clam No

QUILLWORT, LOUISIANA Plant No

STURGEON, GULF Fish Yes

STURGEON, PALLID Fish No

TORTOISE, GOPHER Reptile No

TURTLE, RINGED SAWBACK Reptile No

WOODPECKER, RED-COCKADED Bird No

Maine (1 species)

Group Critical Habitat

WHALE, NORTHERN RIGHT Mammal Yes

Maryland (11 species)

Group Critical Habitat

BAT, INDIANA Mammal Yes

BEETLE, PURITAN TIGER Insect No

BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No

DARTER, MARYLAND Fish Yes

EAGLE, BALD Bird No

HARPERELLA Plant No

PINK, SWAMP Plant No

SQUIRREL, DELMARVA PENINSULA FOX Mammal No

STURGEON, SHORTNOSE Fish No

TURTLE, BOG (NORTHERN POPULATION) Reptile No
Page 195 of 219

WHALE, NORTHERN RIGHT Mammal Yes

Massachusetts (3 species)

Group Critical Habitat

EAGLE, BALD Bird No

Thursday, April 21, 2005 Page 16 of 27
Page 196 of 219

POGONIA, SMALL WHORLED Plant No

WHALE, NORTHERN RIGHT Mammal Yes

Michigan (9 species)

Group Critical Habitat

BUTTERFLY, KARNER BLUE Insect No

BUTTERFLY, MITCHELL'S SATYR Insect No

EAGLE, BALD Bird No

GOLDENROD, HOUGHTON'S Plant No

IRIS, DWARF LAKE Plant No

MONKEY-FLOWER, MICHIGAN Plant No

PLOVER, PIPING Bird Yes

POGONIA, SMALL WHORLED Plant No

THISTLE, PITCHER'S Plant No

Mississippi (20 species)

Group Critical Habitat

BEAR, LOUISIANA BLACK Mammal Yes

COMBSHELL, SOUTHERN (=PENITENT MUSSEL) Clam No

CRANE, MISSISSIPPI SANDHILL Bird Yes

DARTER, BAYOU Fish No

EAGLE, BALD Bird No

FROG, DUSKY GOPHER (MISSISSIPPI DPS) Amphibian No

PELICAN, BROWN Bird No

PIGTOE, HEAVY (=JUDGE TAIT'S MUSSEL) Clam No

PLOVER, PIPING Bird Yes

PONDBERRY Plant No

POTATO-BEAN, PRICE'S Plant No

SNAKE, EASTERN INDIGO Reptile No

STURGEON, GULF Fish Yes
Page 197 of 219

STURGEON, PALLID Fish No

TERN, INTERIOR (POPULATION) LEAST Bird No

TORTOISE, GOPHER Reptile No

TURTLE, LOGGERHEAD SEA Reptile No

Thursday, April 21, 2005 Page 17 of 27
Page 198 of 219

TURTLE, RINGED SAWBACK Reptile No

TURTLE, YELLOW-BLOTCHED MAP Reptile No

WOODPECKER, RED-COCKADED Bird No

Missouri (11 species)

Group Critical Habitat

BAT, GRAY Mammal No

BAT, INDIANA Mammal Yes

BEETLE, AMERICAN BURYING Insect No

CLOVER, RUNNING BUFFALO Plant No

DARTER, NIANGUA Fish Yes

EAGLE, BALD Bird No

GEOCARPON MINIMUM Plant No

MILKWEED, MEAD'S Plant No

MUSSEL, SCALESHELL Clam No

PEARLYMUSSEL, PINK MUCKET Clam No

STURGEON, PALLID Fish No

Montana (6 species)

Group Critical Habitat

BEAR, GRIZZLY Mammal No

CATCHFLY, SPALDING'S Plant No

EAGLE, BALD Bird No

HOWELLIA, WATER Plant No

TROUT, BULL Fish No

WOLF, GRAY Mammal Yes

New Jersey (10 species)

Group Critical Habitat

BAT, INDIANA Mammal Yes

BEAKED-RUSH, KNIESKERN'S Plant No
Page 199 of 219

CHAFFSEED, AMERICAN Plant No

EAGLE, BALD Bird No

JOINT-VETCH, SENSITIVE Plant No

PINK, SWAMP Plant No

Thursday, April 21, 2005 Page 18 of 27
Page 200 of 219

PLOVER, PIPING Bird Yes

STURGEON, SHORTNOSE Fish No

TURTLE, BOG (NORTHERN POPULATION) Reptile No

WHALE, NORTHERN RIGHT Mammal Yes

New Mexico (24 species)

Group Critical Habitat

Amphipod, Noel's Crustacean No

CACTUS, KUENZLER HEDGEHOG Plant No

CACTUS, LEE PINCUSHION Plant No

CACTUS, SNEED PINCUSHION Plant No

EAGLE, BALD Bird No

FALCON, NORTHERN APLOMADO Bird No

FERRET, BLACK-FOOTED Mammal No

FROG, CHIRICAHUA LEOPARD Amphibian No

GAMBUSIA, PECOS Fish No

OWL, MEXICAN SPOTTED Bird Yes

PENNYROYAL, TODSEN'S Plant Yes

PLOVER, MOUNTAIN Bird No

POPPY, SACRAMENTO PRICKLY Plant No

SHINER, BEAUTIFUL Fish Yes

SHINER, PECOS BLUNTNOSE Fish Yes

Snail, Koster's Tryonia Snail No

Snail, Pecos Assiminea Snail No

Springsnail, Roswell Snail No

SUNFLOWER, PECOS Plant No

TERN, INTERIOR (POPULATION) LEAST Bird No

THISTLE, SACRAMENTO MOUNTAINS Plant No

TROUT, GILA Fish No
Page 201 of 219

WILD-BUCKWHEAT, GYPSUM Plant Yes

WOLF, GRAY Mammal Yes

New York (12 species)

Group Critical Habitat

Thursday, April 21, 2005 Page 19 of 27
Page 202 of 219

AMARANTH, SEABEACH Plant No

BAT, INDIANA Mammal Yes

EAGLE, BALD Bird No

FERN, AMERICAN HART'S-TONGUE Plant No

GERARDIA, SANDPLAIN Plant No

MONKSHOOD, NORTHERN WILD Plant No

PLOVER, PIPING Bird Yes

POGONIA, SMALL WHORLED Plant No

STURGEON, SHORTNOSE Fish No

TERN, ROSEATE Bird No

TURTLE, BOG (NORTHERN POPULATION) Reptile No

WHALE, NORTHERN RIGHT Mammal Yes

North Carolina (7 species)

Group Critical Habitat

CAHOW Bird No

EAGLE, BALD Bird No

LOOSESTRIFE, ROUGH-LEAVED Plant No

PONDBERRY Plant No

SILVERSIDE, WACCAMAW Fish Yes

WHALE, NORTHERN RIGHT Mammal Yes

WOODPECKER, RED-COCKADED Bird No

Ohio (3 species)

Group Critical Habitat

BAT, INDIANA Mammal Yes

EAGLE, BALD Bird No

ORCHID, EASTERN PRAIRIE FRINGED Plant No

Oklahoma (18 species)

Group Critical Habitat
Page 203 of 219

BAT, GRAY Mammal No

BAT, INDIANA Mammal Yes

BAT, OZARK BIG-EARED Mammal No

BEETLE, AMERICAN BURYING Insect No

Thursday, April 21, 2005 Page 20 of 27
Page 204 of 219

CAVEFISH, OZARK Fish No

CRANE, WHOOPING Bird Yes

CURLEW, ESKIMO Bird No

DARTER, LEOPARD Fish Yes

EAGLE, BALD Bird No

MADTOM, NEOSHO Fish No

MUSSEL, SCALESHELL Clam No

ORCHID, EASTERN PRAIRIE FRINGED Plant No

ORCHID, WESTERN PRAIRIE FRINGED Plant No

PLOVER, PIPING Bird Yes

SHINER, ARKANSAS RIVER Fish Yes

TERN, INTERIOR (POPULATION) LEAST Bird No

VIREO, BLACK-CAPPED Bird No

WOODPECKER, RED-COCKADED Bird No

Oregon (33 species)

Group Critical Habitat

BUTTERFLY, FENDER'S BLUE Insect No

BUTTERFLY, OREGON SILVERSPOT Insect Yes

CHECKER-MALLOW, NELSON'S Plant No

CHUB, OREGON Fish No

DAISY, WILLAMETTE Plant No

DEER, COLUMBIAN WHITE-TAILED Mammal No

EAGLE, BALD Bird No

FRITILLARY, GENTNER'S Plant No

LOMATIUM, BRADSHAW'S Plant No

LOMATIUM, COOK'S Plant No

LUPINE, KINCAID'S Plant No

MEADOWFOAM, LARGE-FLOWERED WOOLY Plant No
Page 205 of 219

MURRELET, MARBLED Bird Yes

OWL, NORTHERN SPOTTED Bird Yes

PELICAN, BROWN Bird No

PLOVER, WESTERN SNOWY Bird No

Thursday, April 21, 2005 Page 21 of 27
Page 206 of 219

POPCORNFLOWER, ROUGH Plant No

SALMON, CHINOOK (LOWER COLUMBIA RIVER) Fish Yes

SALMON, CHINOOK (SNAKE RIVER FALL RUN) Fish No

SALMON, CHINOOK (SNAKE RIVER SPRING/SUMMER) Fish Yes

SALMON, CHINOOK (UPPER COLUMBIA RIVER SPRING) Fish Yes

SALMON, CHINOOK (UPPER WILLAMETTE RIVER) Fish Yes

SALMON, CHUM (COLUMBIA RIVER POPULATION) Fish Yes

SALMON, COHO (OREGON COAST POPULATION) Fish Yes

SALMON, COHO (SOUTHERN OR/NORTHERN CA COAST) Fish No

SALMON, SOCKEYE (SNAKE RIVER POPULATION) Fish No

SHRIMP, VERNAL POOL FAIRY Crustacean Yes

STEELHEAD, LOWER COLUMBIA RIVER POPULATION Fish Yes

STEELHEAD, MIDDLE COLUMBIA RIVER POPULATION Fish Yes

STEELHEAD, SNAKE RIVER BASIN POPULATION Fish Yes

STEELHEAD, UPPER COLUMBIA RIVER POPULATION Fish Yes

STEELHEAD, UPPER WILLAMETTE RIVER POPULATION Fish Yes

TROUT, BULL Fish No

Pennsylvania (7 species)

Group Critical Habitat

BAT, INDIANA Mammal Yes

BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No

CLUBSHELL Clam No

EAGLE, BALD Bird No

PLOVER, PIPING Bird Yes

RIFFLESHELL, NORTHERN Clam No

TURTLE, BOG (NORTHERN POPULATION) Reptile No

South Carolina (26 species)

Group Critical Habitat
Page 207 of 219

AMARANTH, SEABEACH Plant No

AMPHIANTHUS, LITTLE Plant No

ARROWHEAD, BUNCHED Plant No

CHAFFSEED, AMERICAN Plant No

Thursday, April 21, 2005 Page 22 of 27
Page 208 of 219

CONEFLOWER, SMOOTH Plant No

DROPWORT, CANBY'S Plant No

EAGLE, BALD Bird No

HARPERELLA Plant No

HEARTLEAF, DWARF-FLOWERED Plant No

HEELSPLITTER, CAROLINA Clam Yes

IRISETTE, WHITE Plant No

LOOSESTRIFE, ROUGH-LEAVED Plant No

MANATEE, WEST INDIAN (FLORIDA) Mammal Yes

PINK, SWAMP Plant No

PITCHER-PLANT, MOUNTAIN SWEET Plant No

PLOVER, PIPING Bird Yes

PONDBERRY Plant No

STORK, WOOD Bird No

STURGEON, SHORTNOSE Fish No

SUNFLOWER, SCHWEINITZ'S Plant No

TREEFROG, PINE BARRENS Amphibian No

TRILLIUM, RELICT Plant No

TURTLE, LOGGERHEAD SEA Reptile No

WHALE, NORTHERN RIGHT Mammal Yes

WOLF, RED Mammal No

WOODPECKER, RED-COCKADED Bird No

Tennessee (4 species)

Group Critical Habitat

BAT, INDIANA Mammal Yes

EAGLE, BALD Bird No

STURGEON, PALLID Fish No

TERN, INTERIOR (POPULATION) LEAST Bird No
Page 209 of 219

Texas (59 species)

Group Critical Habitat

AMPHIPOD, PECK'S CAVE Crustacean No

BEAR, LOUISIANA BLACK Mammal Yes

Thursday, April 21, 2005 Page 23 of 27
Page 210 of 219

BEETLE, COFFIN CAVE MOLD Insect No

BEETLE, COMAL SPRINGS DRYOPID Insect No

BEETLE, COMAL SPRINGS RIFFLE Insect No

BEETLE, HELOTES MOLD Insect Yes

BEETLE, KRETSCHMARR CAVE MOLD Insect No

BEETLE, TOOTH CAVE GROUND Insect No

CACTUS, BLACK LACE Plant No

CACTUS, SNEED PINCUSHION Plant No

CACTUS, TOBUSCH FISHHOOK Plant No

CICURINA VENII (NCN) Arachnid Yes

CRANE, WHOOPING Bird Yes

CURLEW, ESKIMO Bird No

DARTER, FOUNTAIN Fish Yes

DAWN-FLOWER, TEXAS PRAIRIE (=TEXAS BITTERWEED Plant No

DOGWEED, ASHY Plant No

EAGLE, BALD Bird No

FALCON, NORTHERN APLOMADO Bird No

GAMBUSIA, CLEAR CREEK Fish No

GAMBUSIA, PECOS Fish No

GAMBUSIA, SAN MARCOS Fish Yes

HARVESTMAN, BEE CREEK CAVE Arachnid No

HARVESTMAN, BONE CAVE Arachnid No

HARVESTMAN, ROBBER BARON CAVE Arachnid Yes

LADIES'-TRESSES, NAVASOTA Plant No

MINNOW, DEVILS RIVER Fish No

OCELOT Mammal No

PELICAN, BROWN Bird No

PHLOX, TEXAS TRAILING Plant No
Page 211 of 219

PLOVER, MOUNTAIN Bird No

PLOVER, PIPING Bird Yes

POPPY-MALLOW, TEXAS Plant No

PRAIRIE-CHICKEN, ATTWATER'S GREATER Bird No

Thursday, April 21, 2005 Page 24 of 27
Page 212 of 219

PSEUDOSCORPION, TOOTH CAVE Arachnid No

PUPFISH, LEON SPRINGS Fish Yes

RHADINE EXILIS (NCN) Insect Yes

RHADINE INFERNALIS (NCN) Insect Yes

SALAMANDER, BARTON SPRINGS Amphibian No

SALAMANDER, SAN MARCOS Amphibian Yes

SALAMANDER, TEXAS BLIND Amphibian No

SAND-VERBENA, LARGE-FRUITED Plant No

Snail, Pecos Assiminea Snail No

SNAKE, CONCHO WATER Reptile Yes

SNOWBELLS, TEXAS Plant No

SPIDER, GOVERNMENT CANYON CAVE Arachnid Yes

SPIDER, MADLA'S CAVE Arachnid Yes

SPIDER, ROBBER BARON CAVE Arachnid Yes

SPIDER, TOOTH CAVE Arachnid No

SPIDER, VESPER CAVE Arachnid Yes

SUNFLOWER, PECOS Plant No

TERN, INTERIOR (POPULATION) LEAST Bird No

TOAD, HOUSTON Amphibian Yes

TURTLE, KEMP'S (ATLANTIC) RIDLEY SEA Reptile No

TURTLE, LOGGERHEAD SEA Reptile No

VIREO, BLACK-CAPPED Bird No

WARBLER (WOOD), GOLDEN-CHEEKED Bird No

WILD-RICE, TEXAS Plant Yes

WOODPECKER, RED-COCKADED Bird No

Utah (15 species)

Group Critical Habitat

BEAR-POPPY, DWARF Plant No
Page 213 of 219

CACTUS, SILER PINCUSHION Plant No

CHUB, VIRGIN RIVER Fish Yes

EAGLE, BALD Bird No

LADIES'-TRESSES, UTE Plant No

Thursday, April 21, 2005 Page 25 of 27
Page 214 of 219

MILK-VETCH, DESERET Plant No

MILK-VETCH, HOLMGREN Plant No

MILK-VETCH, SHIVWITS Plant No

OWL, MEXICAN SPOTTED Bird Yes

PHACELIA, CLAY Plant No

PRAIRIE DOG, UTAH Mammal No

SUCKER, JUNE Fish Yes

TORTOISE, DESERT Reptile No

TROUT, LAHONTAN CUTTHROAT Fish No

WOUNDFIN Fish Yes

Virginia (9 species)

Group Critical Habitat

BAT, VIRGINIA BIG-EARED Mammal Yes

BITTERCRESS, SMALL-ANTHERED Plant No

BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No

ISOPOD, MADISON CAVE Crustacean No

LOGPERCH, ROANOKE Fish No

SNEEZEWEED, VIRGINIA Plant No

SPINYMUSSEL, JAMES RIVER Clam No

SPIRAEA, VIRGINIA Plant No

WHALE, NORTHERN RIGHT Mammal Yes

Washington (23 species)

Group Critical Habitat

BEAR, GRIZZLY Mammal No

CHECKER-MALLOW, WENATCHEE MOUNTAINS Plant Yes

DEER, COLUMBIAN WHITE-TAILED Mammal No

EAGLE, BALD Bird No

HOWELLIA, WATER Plant No
Page 215 of 219

MURRELET, MARBLED Bird Yes

OWL, NORTHERN SPOTTED Bird Yes

RABBIT, PYGMY Mammal No

SALMON, CHINOOK (LOWER COLUMBIA RIVER) Fish Yes

Thursday, April 21, 2005 Page 26 of 27
Page 216 of 219

SALMON, CHINOOK (PUGET SOUND) Fish Yes

SALMON, CHINOOK (SNAKE RIVER FALL RUN) Fish No

SALMON, CHINOOK (SNAKE RIVER SPRING/SUMMER) Fish Yes

SALMON, CHINOOK (UPPER COLUMBIA RIVER SPRING) Fish Yes

SALMON, CHUM (COLUMBIA RIVER POPULATION) Fish Yes

SALMON, SOCKEYE (SNAKE RIVER POPULATION) Fish No

STEELHEAD, LOWER COLUMBIA RIVER POPULATION Fish Yes

STEELHEAD, MIDDLE COLUMBIA RIVER POPULATION Fish Yes

STEELHEAD, SNAKE RIVER BASIN POPULATION Fish Yes

STEELHEAD, UPPER COLUMBIA RIVER POPULATION Fish Yes

STEELHEAD, UPPER WILLAMETTE RIVER POPULATION Fish Yes

STICKSEED, SHOWY Plant No

TROUT, BULL Fish No

WOLF, GRAY Mammal Yes

West virginia (4 species)

Group Critical Habitat

BAT, INDIANA Mammal Yes

BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No

EAGLE, BALD Bird No

HARPERELLA Plant No

Wisconsin (4 species)

Group Critical Habitat

DRAGONFLY, HINES EMERALD Insect No

EAGLE, BALD Bird No

IRIS, DWARF LAKE Plant No

THISTLE, PITCHER'S Plant No
Page 217 of 219

Appendix H. Guideline Sequence Bibliography for Dodine

161-1 Hydrolysis

MRID Citation Reference

00101402 Clarke, G.; Norris, M.; Bruesch, J.; et al. (1977) Report on Hydrolysis of Cytox 2160 Biocide.

(Unpublished study received Nov 2, 1977 under 1730-43; submitted by American Cyanamid Co.,

Consumer Products Research Div., Wayne, NJ; CDL:232157-A)

00134831 Betz Entec, Inc. (1973) ?Study--Chemical: Betz Entec 348|. (Unpub- lished study received Jun

27, 1978 under 345-719; submitted by L and K Laboratories, Brooklyn, NY; CDL:234355-A)

00144366 Rozzi, T. (1984) Letter sent to E. Jones dated Nov 16, 1984: Hy- drolysis of dodecylguanidine

hydrochloride. Prepared by Calgon Corp. 14 p.

42242601 Daly, D., K. Kabler, and K. Williamson. 1991. Hydrolysis of dodecylguanidine HCl as a

function of pH at 25 C. ABC Final Report No. 38680. Unpublished study prepared by Analytical

Bio-Chemistry Laboratories, Inc., Columbia, MO, for Calgon Corporation, Pittsburgh, PA, and submitted

by American Cyanamid Company, Wayne, NJ.

161-2 Photodegradation-aqueous

MRID Citation Reference

42419001 Daly, D., and K. Kabler. 1991. Determination of the photolysis rate of 14C-dodecylguanidine

hydrochloride in pH 5 buffered solution at 25 C. Final Report No. 38681. Unpublished study performed

by Analytical Bio-Chemistry Laboratories, Inc., Columbia, MO, and submitted by Calgon Corporation,

Pittsburgh, PA.

46438203 Slangen, D.J. and B. van Noorloos. 2004. Photodegradation of dodine in water including

amendment (attachment 1). Unpublished study prepared by Notox BV, Hertogenbosch, The Netherlands;

sponsored by Chimac-Agriphar S.A., Ougree, Belgium; and submitted by Ceres International LLC, West

Chester, PA. Study Report No. 327061. Experimental start date October 31, 2001, and termination date

March 3, 2004 (p. 4). Final report issued May 7, 2004.

161-3 Photodegradation-soil

MRID Citation Reference

43506401 Jendrzejczak, N.; Maestracci, M. (1994) Dodine--UV-Visible Characteristics: Lab Project

Numbers: 94-140: R&D/CRLD/AN/9416845: A521. Unpublished study prepared by Rhone-Poulenc

Secteur Agro. 19 p.

46438204 Mislankar, S.G. 2001. Photodegradation of dodine in soil. Unpublished study performed by

Aventis CropScience, Raleigh, NC; sponsored by Chimac-Agriphar S.A., Ougree, Belgium; and
Page 218 of 219

submitted by Ceres International LLC, West Chester, PA. Study Report No. 2000X18609. Experimental

start date October 3, 2000, and experimental end date November 10, 2000 (Table IX, p. 39). Final report

issued June 14, 2001.

162-1 Aerobic soil metabolism

MRID Citation Reference

00058169 Goldberg, M.C.; Wershaw, R.L. (1969) Biodegradation of Dodecyl- guanidine acetate

(Dodine). Geological Survey Research 1969. By ? N.P. (pp. D235-D239,~In~U.S. Geol. Survey Prof.

paper 650-D, published study; CDL:232344-D)

43945201 Cooper, J.; Jones, M.; Lowden, P. (1996) (Carbon 14)-Dodine: Aerobic Soil Metabolism in

Two Soils at 25 (degrees) C: Lab Project Number: P 94/162: 201088: 95/18. Unpublished study prepared

by Rhone-Poulenc Agriculture Ltd. 156 p.

162-3 Anaerobic aquatic metabolism

MRID Citation Reference

00058169 Goldberg, M.C.; Wershaw, R.L. (1969) Biodegradation of Dodecyl- guanidine acetate

(Dodine). Geological Survey Research 1969. By ? N.P. (pp. D235-D239,~In~U.S. Geol. Survey Prof.

paper 650-D, published study; CDL:232344-D)

42763001 Cady, C. 1993a. Anaerobic aquatic metabolism of Metasol DGH. Final Report No. 38684. 

Unpublished study performed by Analytical Biochemistry Laboratories, Inc., Columbia, MO, for Calgon

Corporation, Pittsburgh, PA; and submitted by American Cyanamid Company, Wayne, NJ.

162-4 Aerobic aquatic metabolism

MRID Citation Reference

42327401 Cady, C., and W. Cranor. 1992a. Aerobic aquatic metabolism of Metasol DGH. Final Report

No. 38682. Unpublished study performed by Analytical Bio-Chemistry Laboratories, Inc., Columbia,

MO, and submitted by Calgon Corporation, Pittsburgh, PA.

46438202 Slangen, D.J., and B. van Noorloos. 2004. The fate of dodine in two water/sediment systems. 

Unpublished study performed by Notox BV, Hertogenbosch, The Netherlands; sponsored by

Chimac-Agriphar S.A., Ougree, Belgium; and submitted by Ceres International LLC, West Chester, PA. 

Study Report No.: 344677. Study initiation January 21, 2002 and completion May 17, 2004; experiment

initiation and completion dates were not reported (p. 4). Final report issued June 11, 2004.

163-1 Leach/adsorption/desorption
Page 219 of 219

MRID Citation Reference

5001190 Helling, C.S.; Dennison, D.G.; Kaufman, D.D. (1974) Fungicide movement in soils.

Phytopathology 64(8):1091-1100.

42148901 Williams, M., and S. Hargadine. 1991. Soil/sediment adsorption-desorption of DGH. ABC

Final Report No. 38683. Unpublished study performed by Analytical Bio-Chemistry Laboratories, Inc.,

Columbia, MO, for Calgon Corporation, Pittsburgh, PA, and submitted by American Cyanamid

Company, Wayne, NJ.

164-1 Terrestrial field dissipation

MRID Citation Reference

00094615 Larsen, D.J. (1979) Spinach Foliar Fungicide Study. Includes method dated Apr 17, 1978.

(Unpublished study, including letter dated Sep 25, 1979 from R.W. Vetro to C.F. Niven, Jr., received Feb

9, 1982 under 4E1474; submitted by Interregional Research Project No. 4, New Brunswick, N.J.;

CDL:070669-H)

00101375 Larsen, D. (1979) Spinach Foliar Fungicide Study. (Unpublished study received Oct 29, 1979

under 4E1474; submitted by Inter- regional Research Project No. 4, New Brunswick, NJ; CDL: 099066-

A)

44985701 Norris, F. (1999) Terrestrial Soil Dissipation After Application of SYLLIT Brand 65W Fruit

Fungicide to Bare Ground Plots Simulating an Orchard or Grove: Lab Project Number: 45751:

96X10342: 10342-02. Unpublished study prepared by Qualls Agricultural, Labs. and Excel Research

Services, Inc. 1408 p.

44985702 Yang, J. (1998) Dodine: Validation of Method of Analysis for Dodine in Soil Using GC-MSD:

Lab Project Number: EC-97-384: 45316. Unpublished study prepared by Rhone-Poulenc Ag Co. 138 p.

{OPPTS 860.1340}