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

OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION



### MEMORANDUM

DATE: February 26, 2014

SUBJECT: Risk assessment for proposed new use of spirotetramat on lawns and turf in a formulated product (12ESP703 SC Insecticide) with imidacloprid

FROM: (PC 392201; DP Barcodes 0413577)**~**



### Joseph DeCant, Ecologist

# <**~ ~0i**  Jose Melendez, Chemist 

# F**~** 

# ·

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

THROUGH: Mah T. Shamim, Ph.D, Branch Chief
Environmental Risk Branch 5
Environmental Fate and Effects Division (7507P)

TO: Rita Kumar, Risk Manager Reviewer
John Hebert, Risk Manager #07
Insecticide and Rodenticide Branch Registration Division (7505P)

The Environmental Fate and Effects Division (EFED) has completed its review of an application

for a proposed new use of spirotetramat for lawns and turf. The proposed new use is a formulation with imidacloprid, named 12ESP703 SC Insecticide, and is intended primarily for

the control of Southern chinch bugs. Imidacloprid is already registered for use on residential and

commercial lawns and turf grass, including sod farms (e.g., Merit 2F Insecticide; Reg. No. 432- 1312). This package also requests the registration of alternate brand names for this formulation including Merit Complete, Merit Plus, Merit 360, Merit Revolution, Merit CIC, and Merit Total

Care.

The maximum seasonal apphcation rate of spirotetramat for the proposed use is 0.2 lb a.i./A,
which is less than the maximum labeled uses that have been previously assessed for banana and plantain (D398764; December 13, 2012). This assessment therefore relies on the previous GJ,ssessment, and 

### Table 1 provides a summary of the risks that EFED anticipates from the use of

this product to lawns and turf. 

### Table 2 presents an overview of the proposed use pattern. The

terrestrial models used in the previous risk assessment by EFED relied primarily on the

maximum single application rate, which is lower for the proposed use on turf (i.e., 0.2 lb a.i./ A

Page 11

### Page | 2 for tur f compared to 0.25 lb a.i./A for banana/plantain) . Therefore, the terrestrial risk conclusions in the previous assessment for spirotetr amat to banana and plantain apply to the currently proposed use with one difference

. In the previous asse ssment, the ap plication rate of 0.25 lb a.i./A for banana and plantain resulted in a borderline exceeded of the chronic mammalian LOC. The currently proposed use of 0.2 lb a.i./A decreases the residues to the point of eliminating the chronic LOC exceedance for mammals for spirotetramat alone

.

In addition, Tables 3 and 4 also confirm that the aquatic EECs of the proposed use on turf do not exceed the EECs from the previous assessment for the use s on banana and pomegranate

. Input parameters for the aquatic modeling are provided in Appendices A

- 1 and A

- 2. Given that the EECs from the previous assessment did not exceed levels of concern for aquatic organisms, the proposed use on turf and lawns also will not exceed levels of concern for aquatic organisms. Following Tables 3 and 4 , this memo presents additional characterization of the risk associated with the use of this formulated product.

Table 1 . Summary of e nvironmental risk conclusions for various taxa exposed to

s pi rot etramat a lone and the formulated product for the p r oposed u se on turf and l awns

.

Assessment Endpoint Identified Concerns with Spirotetramat
Alone Identified Concerns with the Formulation

Acute and Chronic Risk to
Freshwater and Estuarine/marine
Fish None None

Acute and Chronic Risk to
Freshwater and Estuarine/Marine
Invertebrates None Acute and Chronic risk to freshwater and
estuarine/marine invertebrates

Aquatic Benthic Invertebrates None Acute and Chronic risk to freshwater and
estuarine/marine invertebrates

Aquatic Non

- Vascular and
Vascular Plants None None

Acute and Chronic Risk to Birds Chronic risk to birds Acute and Chronic risk to birds (see risk description for more information regarding the uncertainty in this conclusion)

Acute and Chronic Risks to
Mammals None Chronic risk to mammals

Risks to Upland and Wetland
Plants None 

### None

Risk to Pollinating Bees Risk to pollinating bees Risk to pollinating bees



## Use Summary for New Use of Spirotetramat on Turf

Use Characterization

Table 2 is a summary of the new turf use pattern for spirotetramat in the proposed label for the new product 12ESP703 SC Insecticide (suspension concentrate) , which contains 8.6%

### Page | 3 spirotetramat and 21.4% imidacloprid

. The proposed new use pattern is outdoor resi dential, for

use on turf grass

, including residential home lawns, business and office complexes, shopping complexes, multi

- family residential complexes, golf courses, airports, cemeteries, parks, playgrounds, athletic fields, and sod farms

. Pests targeted for control are soil or surface inhabiting turf grass pests, such as chinch bugs. Table 2 is based on the proposed label and a summary provided by the registrant.

Table 2. Summary of Directions for the Proposed Turf Use of Spirotetramat, based on the proposed label for 12ESP703 SC Insecticide (EPA Reg. No. 72155

- xxxx)
Product’s Name 12ESP703 SC Insecticide Active Ingredients Spirotetramat 8.6% and Imidacloprid 21.4%; the product contains 0.8 lb spirotetramat and 2.0 lb imidacloprid per gallon

Use Site Turf G rasses ( turf grass

, including residential home lawns, business and office complexes, shopping complexes, multi

family residential complexes, golf courses, airports, cemeteries, parks, playgrounds, athletic fields, and sod farms) Type of Applica tion Identified by Equipment/Label Restriction Spray equipment Apply 12ESP703 SC Insecticide in sufficient wa t er to provide adequate distribution in the treated area

. The use of accurately calibrated equipment normally used for the application of turf gra ss insecticides is required

. Use equipmen t that will produce a unif orm, coarse droplet spray , using a low

- pressure setting to eliminate off target drift.
Check cal ibration periodically to ensure that equ i pment is working properly. Description of Application Method Type Spray

Formulation Description Suspension concentrate liquid Application Rate 12.8

- 32 fl oz product/A or 0.3 to 0.72 fl oz (8.8 to 21.1 mL) per 1000 sq ft; this application rate is equivalent to 0.08

– 0.2 lb a.i. spirotetramat/ A/ application: this application rate range is recommended for all pests, except for mole crickets, for
which the recommended rate is 0.2 lb spirotetramat/A

. Maximum Single Application
Rate 32 fl oz product/A or 0.72 fl oz (21.1 mL)/1000 sq ft; this applica tion rate is equivalent to 0.2 lb a.i. spirotetramat/A/ application
Maximum Number Applications / Season Not specified

Maximum Number Apps
/Year Two (2)

Maximum Number Apps
/ Year at Maximum Single
Rate One (1)

Maximum Application Rate
/ Year (lb a.i./A) 0.2 lb a.i. of spirotetramat and 0.5 lb a.i. of imidacloprid

### Page | 4 Table 2. Summary of Directions for the Proposed Turf Use of Spirotetramat, based on the proposed label for 12ESP703 SC Insecticide (EPA Reg. No. 72155

- xxxx)
Minimum Retreatment
Interval Not specified

Application Method Timing Spray before egg hatch. For mole cricket, can also apply when adult or large nymphs are present and actively tunneling, in combination with a remedial insecticide Registration Numbers 264

- 1049 (Technical); 72155

- xxxx (End

- use)
Use Directions and
Limitations 72155

- xxxx Repeat as needed, up to two times per year, not to exceed max application rate per year.
Pests Controlled Numerous species of insect species are listed in the label, including billibugs, annual bluegrass weevil, grubs, listed surface pests and below ground pests, and pyrethroid resistant chinch bugs.
Environmental Hazard
Statements - This product is highly tox ic to aquatic invertebrates. Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment
washwaters.

- This product is highly toxic t o bees exposed to direct treatment or to residues on crops or weeds in bloom. Do not apply this product or allow it to drift to crops or weeds in bloom if bees are visiting the treatment area.

- This chemical demonstrates the properties and characteristics associated with chemicals detected in groundwater. This chemical may leach into groundwater if used in areas where soils are permeable, particularly where the water table is
shallow.
Restrictions NOTE: For optimum control, if rainfall does not occur wit hin 24 hours after application, irrigate to move the active ingredient through the thatch.

- Do not apply through any irrigation system.

- Do not mow turf or lawn area until after sufficient irrigation or rainfall has occurred so that uniformity of applicati on will
not be affected.

- Do not graze treated areas or use clippings from treated areas for feed or forage.

- Do not allow runoff or puddling of irrigation water following application.

- Do not apply 12ESP703 SC Insecticide to areas that are water logged or saturated, it will not allow penetration into the root zone of the plant.

### Page | 5 Table 3 . Upper bound peak exposure to invertebrates, 

### fish , and aquatic plants from the previous assessment and the new proposed use on turf
and lawn

. Crop Scenario/App. R ate (lb a.i./A) /No. Apps/Int. Between Apps. EEC/ppb
FL citrus* / 0.25 / 5 / 14 1.46
FL citrus TTR + NERs * / 0.25 / 5 / 14 19.6
FL turf / 0.2 / 1 / NA 0.397
FL turf TTRs + NERs / 0.2 / 1 / NA 1.99
*Surrogate scenario for bananas and plantains from the previous assessment (D398764)

.



### Table 4 . Upper bound chronic exposure for aquatic invertebrates and fish from the previous assessment and the new proposed use on turf and lawn

. a
Crop Scenario/App. R ate (lb a.i./A) /No. Apps/Int. Between Apps. Chronic 21d / ppb Chronic 60d / ppb

FL citrus* / 0.25 / 5 / 14 0.0622 0.0462
FL citrus TTR* / 0.25 / 5 / 14 18.7 17.5
FL turf / 0.2 / 1 / NA 0.0349 0.0122
FL turf TTRs + NERs / 0.2 / 1 / NA 1.94 1.88
*Surrogate scenario for bananas and plantains from the previous assessment (D398764)

.

a Chronic 21 day and 60 day average exposure concentrations are shown. The 21 day average relates to aquatic invertebrates whe reas the 60 day exposure concentrations relate to fish.



## Additional Risk Description **and Uncertainties**

Based on spirotetramat alone, the risk picture is relatively narrow in terms of the concerns. As evident from the information presented above, spirotetramat alone does not present a risk to most

taxa based on the proposed application rate. In fact, only chronic risk concerns to birds and risk concerns for pollinating bees remain for spirotetramat alone. The risk concerns for birds are
based on an endpoint from a supplemental study with the Mallard du ck from which a definitive NOAEC could not be derived. Therefore, there is uncertainty in the chronic risk for birds as the toxicity endpoint may be lower than the endpoint used in this analysis. A study (MRID 48958801) has been submitted by the registran t and is currently in review after which EFED may be able to arrive at a definitive NOAEC depending on the acceptability of the study.

The risk to pollinating bees , related to spirotetramat alone, is based on a number of non

- GLP tunnel studies that were submitted as part of the New Chemical assessment (see D345278, Appendix C). The previous assessment on banana and plantain (D398765) presents information on these studies and other higher tier stud ies for spirotetramat. In summary, the use rate for the proposed use on turf and lawns is high enough that, given the body of literature for spirotetramat, there is the potential for immediate adverse impact to brood production in honey bee colonies.
Con sidering that the honey bee is a surrogate for other pollinating bees, both bumble bee and solitary bee species would also be impacted by the proposed use rate of spirotetramat.

The proposed use of the formulated product with both spirotetramat and imid acloprid present a risk picture based on both products. The EECs for terrestrial and aquatic species for imidacloprid alone, based on the worst

- case scenario of a single application at 0.5lb a.i./A, would

### Page | 6 be similar to the relatively recent imidacloprid a ssessment on caneberries and artichokes (D334030+, May 1 2007). The risk conclusions for this use, with the single maximum application rate of 0.5lb a.i./A, were as follows:

• Acute and chronic risk to both estuarine and freshwater invertebrates, both free

swimming and benthic

• Chronic risk to birds

• Acute risk to mammals

• Potential for risk to pollinating bees

There is some uncertainty to consider rel ated to the conclusions for avian species from the previous risk assessment for imidacloprid . First, only ch ronic risk was highlighted as a concern , but this situation is a result of the acute toxicity value used for birds. The assessment used the
LC 50 

### of 1536 ppm, which is based on the dietary study with Bobwhite quail. The acute oral dose
based LD 50 

### with the sparrow is a much more conservative endpoint that would have resulted in exceedances of acute toxicity LOC’s. However, as highlighted in the previous assessment, imidacloprid appears to have repellent properties that limit the consumption of food items

c ontaminated with imidacloprid. Consequently, the acute risk concerns would be abated by the food avoidance behavior of birds when food items are contaminated with imidacloprid and alternative sources are available. Similarly, the chronic risk concerns ra ised by both imidacloprid and spirotetramat would likely be minimized due to food avoidance from the presence of imidacloprid to the formulation when alternative food sources are available. It is important to note that this conclusion rests on the assumpt ion that alternative food sources are
available for birds otherwise adverse effects due to reduced food consumption are possible.

In addition, the concerns with pollinating bees are addressed to some extent by the proposed label, but concerns remain. The proposed label contains in the environmental hazards section the statement, “ This product is highly toxic to bees exposed to direct treatment or to residues on crops or weeds in bloom. Do not apply this product or allow it to drift to crops or weeds in
b loom if bees are visiting the treatment area”. Imidacloprid is highly toxic to adult bees based on acute contact and oral exposure. Unlike imidacloprid, spirotetramat does not appear to adversely impact adult bees at realistic concentration s, but rather it impacts brood survival. So the label statement above primarily protects adult foraging bees, including honey bees as well as bumblebees and solitary bees, from direct contact exposure to imidacloprid. The remaining issue is that both spirotetramat and imidacloprid are systemic insecticides that can translocate into pollen and nectar to be collected by bees

.

These systemic residues in pollen and nectar present a concern not addressed by the bee hazard labeling. While applications are restricted durin g bloom when bees are visiting the application area, the systemic nature of both chemicals implies that applications made before bloom can also be expressed in pollen and nectar when bee attractive weeds ( e.g. , clover or dandelion) on the application site begin to bloom. Furthermore, imidacloprid is stable to degradation and may

carry

- over in the soil until the next season when translocation may also occur into pollen and

nectar. In this case, foragers would collect contaminated food sources and return th ese to the hive or nest. Consequently, because the formulation contains both imidacloprid and spirotetramat, the hive or nest would be exposed to a chemical that can affect foraging and

### Page | 7 behavior at sublethal levels (imidacloprid) as well as a chemical tha t is toxic to brood development (spirotetramat). The two chemicals together represent a potent combination if exposure to pollinating bees occurs. Due to a lack of empirical residue data on the proposed formulated product, t here is uncertainty as to the residue levels that can be expected from the maximum application rate of t he proposed formulated product. Nonetheless, given the maximum application rate of the two active ingredients, the impacts to brood from spirotetramat in tunnel studies at lower app lication rates than the currently proposed rate , the combined activity on both adult and brood due to the presence of both imidacloprid and spirotetramat, the proposed formulated product has a high potential for substantial impacts to honey bee and
bumble bee colony health, as well as native bee and beneficial arthropod diversity and
abundance

, based on toxicity and the proposed application rates

.

Risk to bees is not solely based on toxicity, however. Exposure is an integral component to the risk picture, and consideration of the use pattern is essential. Turf and lawns are not high acreage pollinator attractive crops, nor do they represent highly concentrated sources of pollen and nectar as the presence of weeds are often intentionally minimized. So in many cases, the lack of flowering weeds in turf and lawns will limit exposure to bees, though ground nesting bees would be an exception as these bees may build ground nests on the site of application

. However, w hen the density of flowering weeds increases the risk to pollinating bees will
increase despite the proposed protective label language . EFED does not have a means of assessing the abundance of flowering weeds in areas of turf and lawn or the spatial extent of this
risk.

In summary, the major tax a of concern from the proposed use of the formulated product are terrestrial arthropods and pollinating bees, aquatic invertebrates, chronic risk to mammals, and
acute and chronic risk to birds. The food avoidance behavior exhibited by birds to imidaclopr id contaminated food items suggests that the risk to birds may be attenuated by the presence of imidacloprid when alternative sources of food are available

. Similarly, the fact that turf and
lawns are not high acreage pollinator attractive crops, nor do t hey represent highly concentrated sources of pollen and nectar as the presence of weeds are often intentionally minimized, also suggests that exposure to pollinating bees may be attenuated by the use pattern itself

. Unlike pollinating bees, however, the u se pattern would not attenuate exposure to beneficial arthropods

, including natural predators of the pest species, on the site of application

.

### Page | 8 Table A

- 1. Input Parameters for PRZM/ EXAMS for the Estimation of the EECs of Spirotetramat


### Parameter (units) Value(s) Sources Comments/ Other

Output File Name SPIROTET

--- --- Chemical Name Spirotetramat Label Proposed labels Crop Names FL turf Label Represents golf courses and various other
turf uses. Application Rate Crop/ lb a.i./A/ kg a.i./ha

FL turf/ 0.2/ 0.2241 Label Proposed labels

Day of Application (day

- month)/

pre

- harvest interval FL turf 01

- 04 Label Proposed labels

Maximum Number of Applications Allowed at the Maximum Application Rate FL turf 1 Label Proposed labels

Minimum Interval between Applications (days) FL turf N/A Label Proposed labels

CAM (Chemical application method) 2 Label 2, linear foliar based on crop canopy

IPSCND ( Flag indicating the disposition of pesticide remaining on foliage after harvest) 1 Input Parameter
Guid ance 1, pesticide remaining on foliage is converted to surface application to the top soil layer DEPI = Incorporation Depth (cm) 0.0 Label Proposed labels

K

d (m L/g) 4.39 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour The average K d value, as per current EFED guidance on input parameters for PRZM/
EXAMS. The K d value represents better the mobility of spirotetramat (relative standard deviation is smaller). Aerobic Soil Metabolism (days) 0.298 OECD Monograph
Annex B. Spirotetramat. B. 8 Fate
and Behaviour Represents the 90 th percentile of the upper
confidence bound on the mean of four half

life values ( FL sandy loam; t 1/2 = 0.30 days, sandy loam; t 1/2 = 0.24 days, silty loam; t 1/2 = 0.26 days, silt; t 1/2 = 0.09 days) (DFOP best
fit kine tics). Method of Application Ground Label Proposed labels Buffer Zone (ft.) N/A Label Proposed labels Application Efficiency (fraction) 0.99 for ground application

--- EFED guidance Spray Drift (fraction) 0.01 for ground application

--- EFED guidance Solubility in Water (ppm) 33.5 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour EFED guidance

Aerobic Aquatic Metabolism (days) 0.2676 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour Represents the 90 th percentile of the upper
confidence bound on the mean of two half

life values at 20 0 C (loam sediment; t 1/2 =1.06 days, loamy sand sediment; t 1/2 =1.05 days) (SFO kinetics). Adjusted values at 25 0 C: 0.265 days and 0.2625 days, mean 0.26375, std. dev. 0.00178 days, t 90,n

- 1 = 3.078. Anaerobic Aquatic Metabolism (days) 2.1 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour Determined by multiplying the available
half

- life (2.8 days) by 3 to account for the uncertainty associated with using a single value (SFO kinetics). Since the value was
obtained at 20 0 C, it was adjusted to 25 0 C (0.70 days x 3 = 2.1 days). Hydrolysis at pH 7 half

- life (days) 13.1 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour EFED guidance (SFO kinetics).

Aqueous Photolysis @ pH 7 (days ) 14.4 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour t 1/2 = 14.4 Phoenix, AZ days, maximum
dark

- controlled available value (SFO kinetics).

Molecular Weight (g/mole) 373.45 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour ---

Vapor Pressure (torr or mmHg) 4.2x10

- 11 OECD Monograph

---

### Page | 9 Table A

- 1. Input Parameters for PRZM/ EXAMS for the Estimation of the EECs of Spirotetramat


### Parameter (units) Value(s) Sources Comments/ Other

Annex B. Spirotetramat. B.8 Fate
and Behaviour Henry’s Law Constant (Atm

- m 3 /mol) 6.90x10

- 13 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour ---

Environment pond298.exv

--- Default for pond scenario, as opposed to
index reservoir. Field Size EPA Pond

--- Runoff none

--- --- FEXTRC, Foliar extraction 0.5

--- EFED guidance PLDKRT, Decay rate on foliage 0

--- EFED guidance PLVKRT, Volatilization rate from foliage 0

--- EFED guidance

UPTKF, Uptake factor 0

--- EFED guidance

Write Benthic Pore Water
Concentrations? Yes

--- For information only

Table A

- 2. Input Parameters for PRZM/EXAMS for the Estimation of the EECs of Spirotetramat + Degradates (Total Residues: Spirotetramat + Spirotetramat

- enol + Spirotetramat

- ketohydroxy + Non

Extracted Residues) for a Representative Crop With the Highest EECs: FL citrus (bananas and plantains) Parameter (units) Value(s) Sources Comments
Output File Name SPIROTET

--- --- Chemical Name Spirotetramat Label Proposed labels Crop Names FL turf Label Represents golf courses and various other
turf uses. Application Rate Crop/ lb a.i./A/ kg a.i./ha
FL turf/ 0.2/ 0.2241 Label Proposed labels

Day of Application (day

- month)/

pre

- harvest interval
FL turf 01

- 04 PHI (days) : FL citrus 1 Estimated from metadata file & labels. Crop emergence/ maturity/ harvest day

- mo : FL citrus 01

- 01/ 02

- 01/ 31

- 12

Maximum Number of Applications Allowed at the Maximum Application Rate FL turf 1 Label Proposed labels

Minimum Interval between Applications (days) FL turf N/A Label Proposed labels

CAM (Chemical application method) 2 Label 2, linear foliar based on crop canopy

IPSCND ( Flag indicating the disposition of pesticide remaining

on foliage after harvest) 1 Input Parameter
Guidance 1, pesticide remaining on foliage is converted to surface application to the top soil layer DEPI = Incorporation Depth (cm) 0.0 Label Proposed labels

K

OC (m L/g OC ) 65.32 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour The average K OC value, as per EFED guidance on input parameters for
PRZM/EXAMS. The K OC value represents better the mobility of spirotetramat

ketohydroxy, the terminal degradate and the most stable (relative standard d eviation is smaller). Aerobic Soil Metabolism (days) Total Residues 222.3 days OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour Represents the 90 th percentile of the upper
confidence bound on the mean of four half

life values for the total residues of the enol and the ketohydroxy (all possible significant figures used, use of log

- linear parameters) ( t 1/2 = 203.82 days, t 1/2 = 169.02 days, t 1/2 = 161. 16 days, t 1/2 = 203.82 days; mean = 184.455 days; std. dev. 22.58984 days). Method of Application Ground Label Proposed labels Buffer Zone (ft.) N/A Label Proposed labels Application Efficiency (fraction) 0.99 ground application

--- EFED guidance Spray Drift (fraction) 0.01 for ground application

--- EFED guidance

### Page | 10 Table A

- 2. Input Parameters for PRZM/EXAMS for the Estimation of the EECs of Spirotetramat + Degradates (Total Residues: Spirotetramat + Spirotetramat

- enol + Spirotetramat

- ketohydroxy + Non

Extracted Residues) for a Representative Crop With the Highest EECs: FL citrus (bananas and plantains) Parameter (units) Value(s) Sources Comments
Solubility in Water (ppm) 228 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour EFED guidance

Aerobic Aquatic Metabolism (days) Total Residues 140.9 days OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour For the parent + enol + ketohydroxy, represents the 90 th percentile of the upper
confidence bound on the mean of four half

life values 385.00 ; 693.00, 141.43, 256.67 days at 20 0 C, which are adjusted to 25 0 C: 96.25, 17 3.25, 35.36, and 64.17 days; std. dev = 59.447 days, mean = 92.26 days ( used of log

- linear parameters). Anaerobic Aquatic Metabolism (days) OVERALL

– Stable OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour The enol is stable and there are no adequate data on the ketohydroxy; the most conservative scenario is presumed.

Hydrolysis at pH 7 half

- life (days) OVERALL

– Stable OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour The enol is stable and there are no adequate
data on the ketoh ydroxy; the most conservative scenario is presumed.

Aqueous Photolysis @ pH 7 (days) OVERALL

– Stable OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour The enol and the ketohydroxy are not photodegradates; therefore, in the absence of data, th e most conservative scenario is presumed. Molecular Weight (g/mole) 373.45 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour Assumed to be the one for the parent.

Vapor Pressure (torr or mmHg) 4.2x10

- 11 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour Assumed to be the same than for the parent,
due to similar structures.

Henry’s Law Constant (Atm

- m 3 /mol) 6.90x10

- 13 OECD Monograph
Annex B. Spirotetramat. B.8 Fate
and Behaviour Assumed to be the same than for the parent,
due to sim ilar structures.

Environment pond298.exv

--- Default for the standard pond scenario, as opposed to index reservoir. Field Size EPA Pond

--- Runoff none

--- --- FEXTRC, Foliar extraction 0.5

--- EFED guidance PLDKRT, Decay rate on foliage 0

--- EFED guidance PLVKRT, Volatilization rate from foliage 0

--- EFED guidance

UPTKF, Uptake factor 0

--- EFED guidance

Write Benthic Pore Water
Concentrations? Yes

--- For information only