## Data Evaluation Report onthe Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial VascularPlants: SeedlingEmergence
PMRA Submission Number N/A
Data Requirement: EPA MRID Number 47748202
PMRA Data Code: EPA DP Barcode: None given OECD Data Point: EPA Guideline: OPPTS 850.4225 (l23-la)

Test material: Common name: Chemical name: Tribenuron methyl 50SG (AI: Tribenuron methyl) Purity: 52.3% (w/w) Tribenuron methyl IUPAC: methyl 2-[4-methoxy-6-methyl-1 ,3,5-triazin-2-yl(methy1)carbamoylsulfamoyl]benzoate CAS name: methyl 2-[[[[(4-methoxy-6-methyl-1 ,3,5-triazin-2- yl)methylamino]carbonyl]amino]sulfonyl]benzoate CAS No.: 101200-48-0 (a.i.) Synonyms: DPX-L5300, DPX-L5300-255 water soluble granular formulation, DPX-L5300-255, Tribenuron methyl 50SG

Primary Reviewer: Moncie Wright StaffScientist, Cambridge Environmental, Inc. Secondary Reviewer: Teri S. Myers Senior Scientist, Cambridge Environmental, Inc. Primary Reviewer: ChristinaWendel USEPA/OCSPP/OPP/ERBIIIBiologist Secondary Reviewer(s): Kristina Garber USEPA/OCSPP/OPP/ERBII/Biologist Reference/Submission No.: {. } 

### Signature: 

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Date: 07/27/09 

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Company Code Active Code Use Site Category: EPA PC Code 

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## } { } { } 128887 [For PMRA] [For PMRA] [ForPMRA]

Date Evaluation Completed: 05-04-2011

CITATION: Porch, 

### l.R. and 

### K.H. Martin. 2009. Tribenuron Methyl (DPX-L5300) 50SG: A Greenhouse Study to Investigate the Effects on Seedling Emergence and Growth ofTwo Sensitive Terrestrial Plants Following Soil Exposure. Unpublished study performed by Wildlife International, Ltd., Easton, Maryland. Laboratory Study Number: 112-623. Study sponsored by E.I. du Pont de Nemours and Company, Wilmington, Delaware. DuPont Study Number: DuPont-25762. Study completed April 8, 2009.

Page 1 of 14 

# /.11••1111 2086540

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl50SG (AI: Tribenuron methyl) to Terrestrial VascularPlants: Seedling Emergence PMRA Submission Number N/A 

### EXECUTIVE SUMMARY: EPA MRID Number 47748202

The effect ofTribenuron methyl50SG (formulation containing the active ingredient Tribenuron methyl) on the seedling emergence ofmono cot (onion, 

### Allium cepa) and dicot (sugarbeet, 

### Beta vulgaris) crops was studied at nominal application rates of0 (negative and surfactant controls), 0.137, 0.273, 0.547, 1.09,2.19, 4.38, 8.75, and 17.5 g a.i./ha, which were equivalentto 0 (negative and surfactant control), 0.000122, 0.000242, 0.000486, 0.000968,0.00194,0.00389,0.00777, and 0.01551bs a.i.lA.
The growth medium used in the seedling emergence test was a natural soil classified as a sandy loam with an organic carbon content of0.8% and a pH of6.1. On Day 21 the surviving plants per pot were recorded and cut at soil level for measuring the height and dry weight. Sugarbeet survival on day 21 was 92% and 86% in the negative and surfactant controls, respectively. There was no inhibition in survival for sugarbeet. Percent emergence was 75% and 65% on day 7, and was 78% and 65% on day 21 in the negative and surfactant controls, respectively. Inhibition for sugarbeet emergence was at a maximum of 17% on day 7, and 10% on day 21 in the 0.00777lbs ai/A treatment group, respectively. Inhibitions in sugarbeet plant height ranged from 0% to 18% in the treatment groups, and was 2% in the surfactant control. Inhibitions in sugarbeet dry weightranged from -17% to 33% in the treatment groups, and was -17% (positive growth) in the surfactant control. Sugarbeet exhibited signs oftoxicity such as chlorosis, mortality, stem curl and necrosis. Although toxicity was variable and scattered, there is concern aboutthe impact ofthe surfactant control on the results seen. Onion survival on day 21 was 97% and 100% in the negative and surfactant controls, respectively. There was no inhibition in survival for onion. Percent emergence was 30 and 8% on day 7, and 78% and 63% on day 21 in the negative and surfactant controls, respectively. Inhibition for onion emergence was at a maximum of42 % in the 0.0004861bs ai/A treatment group on day 7, and 19% in the 0.000242 lbs ai/A treatment group on day 21. Inhibitions in onion plantheight ranged from -1% to 20%, in the treatment groups, and was 30% in the surfactant control. Inhibitions in onion dry weightranged from 0% to 36% in the treatment groups, and was 36% in the surfactant control. Onion exhibited signs oftoxicity such as mortality, stem curl and necrosis. Although toxicity was variable, there is concern aboutthe impact ofthe surfactant control on the effects seen, as there was a 36% inhibition on onion dry weight, and a 30% inhibition on onion height.
There was no indication ofa dose-response relationship for any endpoint ofany species tested. However, this lack ofdose-response may be related to the affect ofthe surfactant on the species tested. There is a large variability within this data, and as a result a definitive response curve could not be conceived from the available data. The high variability precluded the ability ofthe t-test to detect a significant difference, and the possibility that the surfactant may have impacted onion and sugarbeet yield responses cannot be ruled out. This possible surfactant effect makes it difficult to conclude that there is no chemical effect. This uncertainty in the data, especially in regards to the surfactant control effect, is too great to discount, and therefore the study is not reliable or usable in risk assessment. This study is classified as invalid, and does not satisfy guideline requirement for a Tier IIterrestrial plant seedling emergence toxicity study. The high variability precluded the ability ofthe t-test to detect a significant difference, and the possibility that the surfactant may have impacted onion and sugarbeetyield responses cannot be ruled out. In addition the study author's failed to test up to the highest single application rate and failed to capture an 

## Ee2s. It is the combination ofhigh variability within the data set, the inhibition effects observed in the surfactant control as compared to the negative control, and the failure to test up to the highest single application rate registered for the chemical that result in this study being classified as unacceptable for use in risk assessment. Therefore, a new study is required.

Page 2 of 14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methylSOSG (AI: Tribenuron methyl) to Terrestrial VascularPlants: Seedling Emergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 Maximum Labeled Rate: The maximum single application rate ofthis chemical is 0.03 ]25 Ibs a.i./A, which is greater than the maximum application rate that was used in this study. I. 

### MATERIALS AND METHODS GUIDELINE FOLLOWED: This study was conducted following guidelines outlined in the U.S. Environmental Protection Agency Series 850 Ecological Effects Test Guidelines (Draft), OPPTS 850.4100 and 850.4225 (Tiers I and II), U.S. EPA Pesticide Assessment, Subdivision J, Hazard Evaluation: Nontarget Plants, Series 122-1 and ]23-1, and OECD Guideline 208, Seedling Emergence and Seedling Growth Test. Deviations from OPPTS 850.4225 were noted:
• The physicochemical properties of the test material were not reported. • The study author's failed to test up to the highest single application rate that is registered to the chemical (0.0313 Ibs ailA), and failed to capture an EC2s. 

### These deviations do impact the acceptability ofthe study. COMPLIANCE:

A. MATERIALS: 1. 

### Test Material
Description: Lot No./Batch No. : Purity: Stability of compound under test conditions:

Storage conditions of test chemicals: Signed and dated No Data Confidentiality, GLP and Quality Assurance statements were provided. This study was conducted in compliance with the Good Laboratory Practice Standards as published by the U.S. EPA, FIFRA (40 CFR, Part 160; ]989), which are consistent with the OECD Principles of GLP (ENV/MC/CHEM(98)]

### 7; 1998) and Japan MAFF (I 

### 1 NohSan, Notification No. 6283; 1999) with the following exception: Periodic soil and water screening analyses were not performed according to GLP standards. These tests were performed using standard EPA procedures and a certified laboratory.

Tribenuron methyl (DPX-L5300) 50SG (formulation containing Tribenuron methyl) Not reported MAY07EL003 52.3% (w/w)
Analytical recoveries of the primary stock solution following solution preparation were 97% ofnominal test concentrations. (DEeD 

### recommends chemicalstability in water andlight)

Not reported

Page 3 of 14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial VascularPlants: SeedlingEmergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 nuron methyl). Table 2. Physical/chemical properties ofTribenuron methyl 50SG (AI: Tribe

Parameter Values Comments Water solubility at 20EC Not Reported Vapor pressure Not Reported UV absorption Not Reported pKa Not Reported Kow Not Reported
2. Test organism: Monocotyledonous species: Onion (Allium cepa, Family Liliaceae; WI-30t); EPA recommendsfour monocots in two families, including corn. Dicotyledonous species: Sugarbeet (Beta vulgaris, Family Chenopodiaceae; none given); EPA recommends six dicots in fourfamilies, includingsoybean and a root crop.
DECD recommends a minimum of three species selectedfor testing, at least onefrom each of thefollowing categories: Category 1: ryegrass, rice, oat, wheat, and sorghum; Category 2: mustard, rape, radish. turnip, and Chinese cabbage; Category 3: vetch. mung bean. red clover, fenugreek, lettuce, and cress. 

### Seed source: Onion obtainedfrom Wannamaker Seeds, St. Matthews, SC (lot no. WS06-02); and sugarbeet obtained from Betaseed, Inc., Shakopee, MN (lot no. 7073). Prior seed treatment/sterilization: None reported Historical % 

### germination ofseed: Onion, >85%; and sugarbeet, 90% Seed storage, if any: Not reported.

B. STUDY DESIGN: 1. Experimental Conditions a. Limit test: N/A- test was conducted under Tier II conditions. b. Range-finding study: No range-finding data were provided. c. Definitive Study

Page 4 of 14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: Seedling Emergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 Table 3: 

### Experimental Parameters - Seedling 

### Emergence. Parameters Seedling Emergence Details Remarks 

### Criteria Duration ofthe test

Number of seeds/plants/species/ replicate

Number ofreplicates Control: Adjuvant control: Treated:

Test concentrations Nominal (reported):

Nominal (reviewerconverted):

Method and interval of analytical verification
LOQ: LOD: Adjuvant (type, percentage, ifused) 21 Days

10 seeds per replicate pot



### 4 4 

### 4/level



# o(negative and surfactant controls), 0.137,0.273,0.547, 1.09,2.19,4.38,8.75, and 17.5 g ai/ha 

# o(negative and surfactant control), 0.000122, 0.000242, 0.000486, 0.000968,0.00194,0.00389, 0.00777, and 0.0155 lbs ai/A Samples from the primary stock solution were analyzed after solution preparation using HPLC with UV (254 nm) detection. Not reported Set at the lowest analytical standard analyzed Tween 80 non-ionic surfactant, 0.25% (v/v) Page 5 of 14 Recommendedtest duration is 14-21 days. DECD recommends that the test be terminatedno sooner than 14 days after 50percent of the control seedlings have emerged

Ten seeds per replicate shouldbe used. DECD recommends a minimum offive seedsplanted in each replicate within 24 hours of incorporation of

the test substance. All seeds of each species for each testshouldbe of the same size class. The seed shouldnot be imbibed.

Four replicates per dose shouldbe used. DECD recommends a minimum offourreplicates pertreatment

Five test concentrations shouldbe used with a dose range of 2X or3X progression DECD recommends three concentrations. preferablywith application rates equivalent to 0.0 (control), 1.0. 10.0 and 100 mg substance per kg of oven-driedsoil.

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial VascularPlants: Seedling Emergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 Parameters Seedling Emergence Details Remarks**--------------------------------~-----------------** 

### Criteria Test container (pot)

-------------------------------------------------- 

### SizeNolume 16 em diameter; 12 em depth Non-porous containers shouldbe used. 

### Material: Plastic (glass/polystyrene) OECD recommends that non-porousplastic or glazedpot be used. 

### Growth facility Greenhouse Method/depth ofseeding A template was used to prepare 10 holes ofsimilar size and depth in the soil surface, and then the seeds were placed in each hole and closed by depressing the soil surface. Sugarbeet and onion were planted at 

### ca. 6 mm depth. Test material application Sprayer was calibratedto apply approx. 400L Application time including Test material was applied to the water/ha at approx. 2.8 bar (40 psi) the plant growth stage soil surface on Day O. Number ofapplication Single application Application interval N/A Method ofapplication Automated laboratory track sprayer equipped with a Teejet 8002E spray nozzle. Details ofsoil used Organic matter content: 1.3% Geographic location Sandy loam (non-sterile, natural pH (CaCIz): 5.8 topsoil) obtained from Chris Lee Bulk density: 1.32 g/cm" and Son, Inc., Easton, MD; Potassium: 58 ppm geographic location not reported Magnesium: 85 ppm Depth ofsoil collection Not reported Calcium: 744 ppm Soil texture Sandy loam Sodium: 17 ppm % sand 57% -------------------------------------------------- 

### % silt 27% Soil mixes containingsandy loam. loam, or clay 

### % clay 16% loam soil with no greater than 2% organic matter are preferable. Glass beads, rock wool, and 100% 

### pH: 6.1 (water) acid washedsandare not preferred. 

### % organic carbon 0.8% CEC 7.4 meq/lOO g OECD prefers the soil to be sieved (0.5 em) to 

### Moisture at 1/3 atm (%) 14.4% remove coarse fragments. Carbon content should not exceed 1.5% (3% organic matter). Fineparticles (under 20um) makeup shouldbe between 10 and 20%. The recommendedpHis between 5.0 and 7.5. 

### Page 6 of14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: Seedling Emergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 Parameters Seedling Emergence Details Remarks

-------------------------------------------------- 

### Criteria Details ofnutrient medium, N/A; a nutrient medium was not if used used Watering regime and Water characterization: schedules pH: 8.1 Water source/type: Domestic well water Dissolved oxygen: 8.1 ppm Volume applied: Not reported Conductivity: 371 umhos/cm Interval ofapplication: Every 2 to 5 days Temperature: 18.2°C Method ofapplication: All pots were top-watered after Alkalinity: 182 mg/L as CaC03 

### application to ensure movement of Hardness: 140 mg/L as CaC03 

### the test material into the soil. -------------------------------------------------- 

### Thereafter, seedlings were sub- EPAprefers that bottom watering be utilized for seedling emergence studies so that the chemical is 

### irrigated. not leachedout of the soil during the test. 

### Any pest control None reported method/fertilization, if used Test conditions Greenhouse Temperature: 18.9-34.0°C Photoperiod: 16L:80 -------------------------------------------------- EPAprefers that the cold vs warm lovingplants be 

### Light intensity and quality: Moles PAR: 8.3-19.0 tested in two separate groups to optimizeplant 

### Natural daylight supplementedby growth. 

### artificial lighting (high pressure sodium lamps) DEeDprefers that the temperature. humidity and light conditions be suitablefor maintaining normal 

### Relative humidity: 23.3-93.0% growth of each species for the test period. 

### Reference chemical (ifused) N/A A reference chemical was not used. Name: Concentrations: Otherparameters, if any None

Page 7 of 14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial VascularPlants: Seedling Emergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 2. Observations: 

### S 

## au E t f 

### P a 

### e : 

### serva IOn arame 

### ers - ee 109 

### mergence. Parameters Seedling Emergence Details Remarks Parameters measured (e.g., number -Emergence ofgerminated seeds, emerged -Survival seedlings, plantheight, dry weight -Height or other endpoints) -Dry Weight -Phytotoxicity Measurementtechnique for each Emergence, survival, and parameter phytotoxicity were determined by visual assessment. Height determination methods were not reported. Dry weight was determined by drying the plant material in an oven at 80°C for at least 48 hours, cooling to room temperature, and weighing. Observation intervals Emergence, survival, and phytotoxicity were assessed on Days 7, 14 and 21. Dry weight and height were assessed at study termination. Other observations, if any None reported Were raw data included? Yes Phytotoxicity rating system, ifused 

# o= no effect; 10

### = effects at the threshold ofvisual detection; 100 

### = complete mortality or defoliation Percent visual response is presented in the statistical output and report tables as 0% 

### =plant death and 100% 

### =no visual response. 

### T bl 4 Ob

Page 8 of 14

## Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: Seedling Emergence PMRA Submission Number N/A


### II. RESULTS and DISCUSSION: A. INHIBITORY EFFECTS: 1. Seedling Emergence: EPA MRID Number 47748202

Sugarbeet survival was 92% and 86% in the negative and surfactant controls, respectively. There was no inhibition in survival for sugarbeet. Emergence was 78% and 65% in the negative and surfactant controls, respectively. Inhibition for sugarbeet emergence was at a maximum of 10% in the 0.00777 Ibs ai/A treatment group. Inhibitions in sugarbeet plant height were relatively low, ranging from 0% to 18%. Inhibitions in sugarbeet dry 

### weight were moderate, ranging from -17% to 33%. Sugarbeet exhibited signs oftoxicity such as chlorosis, mortality, stem, curl and necrosis. Although toxicity was variable and scattered, there is concern about the impact ofthe surfactant control on the results seen. Onion survival was 97% and 100% in the negative and surfactant controls, respectively. There was no inhibition in survival for onion. Emergence was 78% and 63% in the negative and surfactant controls, respectively. Inhibition for onion emergence was at a maximum of19% in the 0.000242 Ibs ai/A treatment group. Inhibitions in onion plant height were relatively low, ranging from -1% to 20%. Inhibitions in onion dry weight were moderate, ranging from 0% to 36%. Onion exhibited signs oftoxicity such as mortality, stem, curl and necrosis. Although toxicity was variable and scattered, there is concern about the impact ofthe surfactant control on the results seen. The most sensitive monocot and dicot species were determined during Tier I testing, and this study was conducted in order to determine toxicity values for onion and sugarbeet. All sugarbeet endpoints had reportedNOAEC, EC25, 

### and EC50 

### values of17.5, >17.5, and> 17.5 g ai/ha, respectively, which were equivalentto 0.0155, >0.0155, and >0.0155 Ibs

### ail A, respectively. All onion endpoints had reported NOAEC, ECz5, 

### and EC50 

### values of17.5, >17.5, and>17.5 g ai/ha, respectively, which were equivalentto 0.0155, >0.0155, and >0.0155 Ibs ai/A, respectively.



### B. REPORTED STATISTICS: Mean dry weight, shoot height, emergence, and survival ofthe controls and treatment groups were compared. The NOAEC was determined using a Jonckheere-Terpstratrend test (a=0.05). The ECx values and their 95% confidence limits were determined by non-linear regression analysis ofthe biological response versus the nominal application rate using SAS Version 8. The study authors analysis detected significant differences (p<0.05) between biomass means for the negative and surfactant control groups, but did not detect differences between the treatment groups and the negative, surfactant, or pooled controls. The study authors reported that because no other endpoint showed differences between the control groups, control responses were pooled for comparison to treatment. C. 

### VERIFICATION OF STATISTICAL RESULTS BY THE REVIEWER: Statistical Method(s): Any species exhibiting an inhibition of::>:5% relative to the negative control based on % Page 9 of14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: SeedlingEmergence PMRA Submission Number N/A 

### EPA MRID Number 47748202 emergence, % survival, dry weight or height was statistically analyzed. The toxicity values were visually determined when inhibitions did not exceed 5% for a given endpoint. All analyses were conductedusing the negative control only. The negative and surfactant controls were compared using a t-test in Toxstat or in Excel. Following the t-test, the reviewer tested each data set for normality using the Chi-square and Shapiro-Wilks tests and for homogeneity ofvariance using the Hartley and Bartlett's tests. If the data met these assumptions of ANOYA, the NOAEC value was determined using the parametric Dunnett's test (ofBonferonni's test for unequal replicates) and Williams' test. If the data did not meet these assumptions, the NOAEC value was determined using the non-parametric Kruskal- Wallis test. In all cases, the reviewer also compared the doseresponse pattern (as determined by the % inhibitions) to the output ofthe statistical tests to determine if biological significance existed in the absence ofstatistical significance. These analyses were conducted using Toxstat statistical software. The reviewer then attempted to determine the ECx values, 95% confidence intervals and slopes using the probit analysis viaNuthatch statistical software. All analyses were conductedusing the nominal application rates ofthe active ingredient. D. STUDY DEFICIENCIES: A t-test conducted on onion dry weight data detected a significant reduction (36%, p<0.05) in the surfactant control group, relative to the negative control group. Further, while the t-test conducted for onion height did not detect a significant difference between the negative and surfactant controls, there was a 30% inhibition in the surfactant control as compared to the negative control. High variability precludedthe ability ofthe t-test to detect a significant difference, but the possibility that the surfactant may have impacted onion yield responses cannot be ruled out. For sugarbeet dry 

### weight, although not a significant difference, there was a -17% inhibition (positive growth) in the surfactant control as compared to the negative control. High variability precludedthe ability ofthe t-test to detect a significant difference, but the possibilitythat the surfactant may have impacted the surgarbeet yield cannot be ruled out. Control group differences were not detected for the other endpoints. In addition to the surfactant effect that was observed, the study author's failed to test up to the highest single application rate that is registered to the chemical (0.0313 Ibs ailA), and failed to capture an EC25.



### E. REVIEWER'S COMMENTS: The reviewer could not definitively calculate ECx values for either onion or sugarbeet endpoints. The maximum single application rate that isregistered for this chemical is 0.0313 Ibs ai/A, which is greater than the highest concentration that was tested (0.0155 Iba ai/A). It 

### was determined that there was a potential interaction ofthe surfactant control on both species, in addition to the large variability ofthe data, that confoundedthe results. The combination ofthese two factors precluded the ability to detect a significant difference even if one was present. The data available within this study cannot be used, and a new study is required. The in-life phase ofthe test with onion, ryegrass, wheat, corn, and carrot was conducted from January 20 to February 10,2009. The in-life phase ofthe test with sugarbeet, cabbage, soybean, lettuce, and tomato was conducted from January 22 to February 12,2009. F. CONCLUSIONS: This study is classified as invalid, and does not satisfy guideline requirement for a Tier II terrestrial plant seedling emergence toxicity study. High variability precluded the ability ofthe t-test to detect a significant difference, and the possibility that the surfactant may have impacted onion and sugarbeet yield responses cannot be ruled out. It 

### is the combination ofhigh variability within the data set, the inhibition effects observed in the surfactant control as comparedto the negative control, and the failure to test up to the highest single application rate registered for the chemical that result in this study being classified as unacceptable for use in risk assessment. Page 10of14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: SeedlingEmergence PMRA Submission Number 

### N/A III. REFERENCES: EPA MRID Number 47748202



### U.S. Environmental Protection Agency, Series 850- Ecological Effects Test Guidelines (draft), OPPTS Number 850.4100: Terrestrial Plant Toxicity, Tier I (Seedling Emergence). 1996. U.S. Environmental Protection Agency, Series 850- Ecological Effects Test Guidelines (draft), OPPTS Number 850.4225: Terrestrial Plant Toxicity, Tier II (Seedling Emergence). 1996. Bruce, Robert D. and Donald J. Versteeg. 1992. A Statistical Procedure for Modeling Continuous Toxicity Data. Environmental Toxicology andChemistry. 11: 1485-1494. U.S. Environmental Protection Agency, "Pesticide Assessment Guidelines, Subdivision J, Hazard Evaluation: Nontarget Plants, Series 122-1 and 123-1", 22 October 1982. OECD, OECD Guideline for the Testing ofChemicals, Guideline 208, Terrestrial Plant Test: Seedling Emergence and Seedling Growth Test. July 2006. Frans, R.E. and Talbert, R.E., Design ofField Experiments and the Measurement and Analysis ofPlant Responses. Pages 15-23 in B. Truelove, ed. Research Methods in Weed Science. Southern Weed Science Society, Auburn University, Alabama, 1977. SAS Institute, Inc. 1999. SAS/STAT

### User's Guide, Version 8. SAS Institute, Inc., Cary, NC.

Page 11 of 14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: Seedling Emergence PMRA Submission Number N/A EPA MRID Number 47748202 APPENDIX I. 

### OUTPUT OF REVIEWER'S STATISTICAL VERIFICATION: Table 1 as lbs a.i./A as lbs a.i./A Onion Weight Mean SO %Inhibition Sugarbeet Weight Mean SO %Inhibition Neg control 0.011 0.002309 N/A Neg control 0.046 0.029 N/A Surfactant control 0.007 0.0015 36 Surfactant control 0.054 0.021 -17 0.000122 0.007 0.001291 36 0.000122 0.036 0.008 22 0.000242 0.009 0.003202 18 0.000242 0.04 0.014 13 0.000486 0.008 0.000816 27 0.000486 0.054 0.03 -17 0.000968 0.01 0.000816 9 0.000968 0.042 0.014 9 0.00194 0.01 0.00263 9 0.00194 0.037 0.015 20 0.00389 0.01 0.001915 9 0.00389 0.031 0.005 33 0.00777 0.011 0.002217 0 0.00777 0.044 0.006 4 0.0155 0.008 0.0015 27 0.0155 0.047 0.03 -2

as lbs a.i./A as lbs a.i./A Onion Height Mean SO %Inhibition Sugarbeet Height Mean SO %Inhibition Neg control 9.0 1.576 N/A Neg control 8.1 1.972 N/A Surfactant control6.3 1.879 30 Surfactant control 7.9 0.974 2 0.000122 7.7 0.419 14 0.000122 7.1 0.686 13 0.000242 7.2 1.234 20 0.000242 7.3 0.850 10 0.000486 7.6 0.877 16 0.000486 8.1 1.132 0 0.000968 8.7 0.574 3 0.000968 7.5 0.206 8 0.00194 8.9 0.594 1 0.00194 6.7 0.500 18 0.00389 7.8 0.532 13 0.00389 6.8 0.507 16 0.00777 9.1 1.159 -1 0.00777 7.4 0.789 9 0.0155 8.6 1.252 4 0.0155 7.8 1.907 4 ( -) : indicates positive growth Tribenuron methyl & onion 21-day % emergence; lbs ai/A File: 84020e Transform: NO TRANSFORMATION
t-test of Surfactant and Blank Controls Ho:GRP1 MEAN = GRP2 MEAN GRP1 (SURFACTANT CRTL) MEAN GRP2 (BLANK CRTL) MEAN DIFFERENCE IN MEANS 77.5000 CALCULATED t VALUE 62.5000 DEGREES OF FREEDOM = 15.0000 6 1.6859

TABLE t VALUE (0.05 (2), 6) 2.447 TABLE t VALUE (0.01 (2), 6) = 3.707 NO significant difference at alpha=0.05 NO significant difference at alpha=O.Ol Tribenuron methyl & sugarbeet 21-day % emergence lIb/A) File: 8402se Transform: NO TRANSFORM
t-test of Surfactant and Blank Controls Ho:GRP1 MEAN = GRP2 MEAN GRP1 (SURFACTANT CRTL) MEAN GRP2 (BLANK CRTL) MEAN DIFFERENCE IN MEANS 77.5000 CALCULATED t VALUE 65.0000 DEGREES OF FREEDOM = 12.5000 6 0.8885

TABLE t VALUE (0.05 (2), 6) 2.447 TABLE t VALUE (0.01 (2), 6) = 3.707 NO significant difference at alpha=0.05 NO significant difference at alpha=O.Ol Page 12 of 14

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: Seedling Emergence
PMRA Submission Number N/A 

### Onion Survival Mean Variance Observations Hypothesized Mean Difference 

### df t Stat P(T<=t)one-tail t Critical one-tail P(T<=t)two-tail t Critical two-tail 

### SugarbeetSurvival Mean Variance Observations Hypothesized Mean Difference 

### df t Stat P(T<=t)one-tail t Critical one-tail P(T<=t)two-tail t Critical two-tail 

### Negcontrol 97 36



### 4 

# o 3 

### -1 0.195501109 2.353363435 0.391002218 3.182446305



### Negcontrol 92.25 93.58333333 

### 4 

# o 6 0.878953192 0.206619244 1.943180274 0.413238488 2.446911846 

### Solvcontrol 100 

# o 4



### Solvcontrol 86 108.6666667 

### 4 EPA MRID Number 47748202

Tribenuron methyl & onion dry weight per plant (g) ;lb/A File: 84020w Transform: NO TRANSFORM
t-test of Surfactant and Blank Controls Ho:GRP1 MEAN = GRP2 MEAN GRP1 (SURFACTANT CRTL) MEAN GRP2 (BLANK CRTL) MEAN DIFFERENCE IN MEANS 11.0000 CALCULATED t VALUE 6.7500 DEGREES OF FREEDOM = 4.2500 6 3.0867

TABLE t VALUE (0.05 (2), 6) = 2.447** SIGNIFICANT DIFFERENCE at alpha=0.05 TABLE t VALUE (0.01 (2), 6) = 3.707 NO significant difference at alpha=O.Ol Tribenuron methyl & sugarbeet weight per plant (g) ;lb/A File: 8402sw Transform: NO TRANSFORM
t-test of Surfactant and Blank Controls Ho:GRP1 MEAN = GRP2 MEAN GRP1 (SURFACTANT CRTL) MEAN GRP2 (BLANK CRTL) MEAN DIFFERENCE IN MEANS 46.2500 CALCULATED t VALUE 53.5000 DEGREES OF FREEDOM = -7.2500 6 -0.4045

TABLE t VALUE (0.05 (2), 6) = 2.447 TABLE t VALUE (0.01 (2), 6) = 3.707 NO significant difference at alpha=0.05 NO significant difference at alpha=O.Ol Tribenuron methyl & onion height (em); lbs ai/A File: 84020h Transform: NO TRANSFORM
t-test of Surfactant and Blank Controls Ho:GRP1 MEAN = GRP2 MEAN GRP1 (SURFACTANT CRTL) MEAN GRP2 (BLANK CRTL) MEAN DIFFERENCE IN MEANS 8.9750 CALCULATED t VALUE 6.2500 DEGREES OF FREEDOM = 2.7250Page 13 of14 6 2.2226

### Data Evaluation Report on the Acute Toxicity ofTribenuron methyl 50SG (AI: Tribenuron methyl) to Terrestrial Vascular Plants: Seedling Emergence
PMRA Submission Number N/A TABLE t VALUE (0.05 (2), 6) 2.447 TABLE t VALUE (0.01 (2), 6) = 3.707 EPA MRID Number 47748202 NO significant difference at alpha=0.05 NO significant difference at alpha=O.Ol Title: Tribenuron methyl & sugarbeet height (em); lbs ai/A File: 8402sh Transform: NO TRANSFORM
t-test of Surfactant and Blank Controls Ho:GRP1 MEAN = GRP2 MEAN GRP1 (SURFACTANT CRTL) MEAN GRP2 (BLANK CRTL) MEAN DIFFERENCE IN MEANS 8.1250 CALCULATED t VALUE 7.9250 DEGREES OF FREEDOM = 0.2000 6 0.1818

2-sided t VALUE (0.05, 6) = 2.4469 2-sided t VALUE (0.01, 6) = 3.7074 NO significant difference at alpha=0.05 NO significant difference at alpha=O.Ol WARNING: This procedure assumes normality and equal variances!

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