Page 2 of 12 Introduction

This is the Environmental Protection Agency’s (EPA or the Agency) Final Work Plan (FWP) for the registration review of prodiamine. The FWP includes the expected registration review timeline. The FWP also addresses public comments received concerning the Preliminary Work Plan (PWP) in the Summary Document , which was posted in the prod iamine registration review docket (EPA-HQ-OPP-2010-0920), and any other co mments concerning the initial docket postings. The Summary Document provided information on what EP A knows about the pesticide and what additional risk analyses and data or information the Agency believes are needed to make a registration review decision.

The Agency is implementing the registration re view program and will review each registered pesticide every 15 years to determine whether it continues to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) standard for registration. Changes in science, public policy, and pesticide use practices occur over time. The registra tion review program is intended to make sure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the stat utory standard. The public phase of registration review begins when the initial docket is opened for each case. Information on this program is provided at: http://www.epa.gov/oppsrr d1/registration_review/

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Prodiamine is a dinitroaniline herbicide first registered in 1992 for selective, pre-emergent control of many grasses and broadl eaf weeds. Prodiamine is registered for use in non-crop areas such as rights-of-way, conifer and hardwood seedling nurseries, esta blished perennial and wildflower plantings, established turf sites, residential and institutional lawns, commercial sod farms, golf courses, railways, and landscape or namentals. There are two Special Local Needs (SLN) registrations in Californi a and Arizona for use on irrigati on drainage ditches, spreading grounds, channels, canals, and levees in wastew ater treatment facilities. There are over 150 prodiamine products currently registered.

Updates since Preliminary Work Plan was Issued

The Agency indicated in the prodiamine PW P and problem formulation documents that photolysis studies for prodiamine in water (GLN 835.2240) and soil (GLN 835.2410) were anticipated as being required in support of registration revi ew. However, the prodiamine technical registrant has recently submitted studies that fulfill these data gaps. Consequently, photolysis studies for prodiamine in water and soil will no longer be re quired in registration review. In addition, due to a ch ange in policy, the Agency is no longer requiring a UV/Visible Light Absorption study for prodiamine (GLN 830.7050) . These changes are reflected in this Final Work Plan.

The Agency indicated in the prodiamine PWP and Problem Formulation that several acute toxicity studies on aquatic organisms would be required on the prodiamine degradate of concern, prodiamine benzimidazole. Six of these st udies will no longer be required (GDLN 850.1075 Acute Freshwater Fish Toxicity Test, GDLN 850.1075 Acute Saltwater Fi sh Toxicity Test Study, GDLN 850.1400 Freshwater Fish Ea rly Life Stage Study, GDLN 850.1400Page 3 of 12 Estuarine/Marine Fish Early Life Stage Study, GDLN 850.1010 Acute Toxicity Freshwater Invertebrates, and GDLN 850.1025/850.1035/850.1055 Ac ute Toxicity Estuarine/Marine Invertebrates). The Agency has come to th e conclusion that acut e studies on prodiamine benzimidazole in aquatic organisms would not be of high value, because there is a low aquatic acute toxicity concern for pa rent prodiamine and low exposure potential for the degradate prodiamine benzimidazole relati ve to parent prodiamine.

Instead of requiring acute aquatic toxicity stud ies on prodiamine benzimidazole, the Agency will require longer-term aquatic t oxicity studies on prodiamine benzimidazole, specificallyGDLN 850.1500 Freshwater Fish Life Cycle Study and a non-guideline Chronic Fr eshwater Sediment Study: Chronic Invertebrates Fr eshwater and Marine (using Hyaella azteca, Chironomus dilutus/C. tetans, and Leptocheirus plumulosus ) using the degradate prodiamine benzimidazole.

For further details regarding ch anges to the data requirements refer to the (Registration Review – Addendum to the Preliminary Problem Formula tion for the Ecological Risk Assessment of Prodiamine Clarifying Data Needs for the Major Degradate, Prodiamine Benzimidazole) , dated June XX, 2011, which can be located in the pr odiamine registration review docket (EPA-HQOPP-2010-0920) at: www.regulations.gov

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Comments Received on Preliminary Work Plan

On December 22, 2010 EPA opened a 60-day public comment period for the registration review of prodiamine. The comment period ended on February 22, 2011. During the public comment period the Agency received one comment on th e prodiamine PWP, from registrant Syngenta Crop Protection Inc. (Syngenta). The comment r eceived did not change the risk assessment and data needs or the timeline deta iled in the prodiamine PWP. The majority of Syngenta’s comments pertained to the prodiamine PWP and Problem Formulation. Although the comments did not change the risk assessment, the data re quirements, as indicated in this FWP, have changed since the issuance of the PWP and Problem Formulation documents due to the submission of additional data. Through the PWP, EPA solicited comments on three specific topics: environmental justice, water body impairment, and trade irritants. No comments or information were received during the comment period concerning these topics. Consequently, this document makes final the work plan for th e prodiamine registration review process.

An overview of the comments and the Agency’s response is presented in the “Summary of Comments and Agency Responses” section of this document.

Risk Assessment and Data Needs

In support of this registration review the Agen cy will conduct a comprehensive ecological risk assessment including an endangered species ri sk assessment; as well as dietary (food and drinking water), occupational (han dler and post-application), and residential (handler and postapplication) exposure and risk assessments for prodiamine. Pr ior to conducting these risk assessments, the Agency requires additional data.Page 4 of 12 Ecological Risk:

• The Agency has not conducted an ecological risk assessment for prodiamine. An Environmental Fate review and EPA Fact Sh eet were completed for prodiamine in 1991.

• The Agency has not conducted a risk asse ssment that supports a complete endangered species determination for prodiamine. Th e ecological risk assessment planned during registration review will allow the Agency to determine whether prodiamine’s use has “no effect” or “may affect” federally listed threat ened or endangered sp ecies (listed species) or their designated critical ha bitats. When an assessment c oncludes that a pesticide’s use “may affect” a listed species or its designate d critical habitat, the Agency will consult with the U.S. Fish and Wildlife Service (F WS) and/or National Marine Fisheries Service (NMFS) (the Services), as appropriate.

• On January 19, 2011, the Center for Biologi cal Diversity and the Pesticide Action Network North America filed a lawsuit in th e United States District Court for the Northern District of California, against th e Environmental Protection Agency (EPA) for allegedly failing to undergo consultation with the United States Fish and Wildlife Service and the National Marine Fisheries Service re garding the effects of over 350 pesticides, including prodiamine, on over 200 endangere d and threatened species throughout the United States (Center for Biological Dive rsity, et al. v. EPA, et al., No. C 11-00293 (N.D.Cal.).

• The Agency will require the following data in order to conduct a complete ecological risk assessment, including an endangered speci es assessment, for all prodiamine uses:

Environmental fate data gaps Parent Prodiamine

• GDLN 835.4300 – Aerobic aquatic metabolism

• GDLN 835.4400 – Anaerobic aquatic metabolism

• GDLN 835.6100 (footnote 7) – Terrestr ial field dissipation – soil

• GDLN 835.6200 – Aquatic field dissipation

Degradate – Prodiamine Benzimidazole

• GDLN 835.2240 – Photodegradation in water

• GDLN 835.1230 – Adsorption/desorp tion (batch equilibrium)

Ecological toxicity data gaps Parent Prodiamine

• GDLN 850.1300 – Aquatic Inverteb rate Life Cycle Toxicity (Freshwater), TGAI

• GDLN 850.1350 – Aquatic Inverteb rate Life Cycle Toxicity (estuarine/marine), TGAI

• GDLN 850.1500 – Freshwater Fish Full Life Cycle Study, TGAI

• GDLN 850.1500 – Estuarine/Marine Fi sh Life Cycle Study, TGAI

• GDLN 850.2100 – Acute Avian Oral Toxicity Te st using a passerine species, TGAIPage 5 of 12 • GDLN 850.4400 – Aquatic Vascular Plant Tier II study using Lemna spp ., TGAI

• GDLN: 850.5400 – Aquatic Plant Tier II Algal toxicity study, TGAI

• No Guideline Number Available, Study Title: Whole Sediment: Chronic Invertebrates Freshwater and Marine (using Hyaella azteca, Chironomus dilutus/C. tetans, and Leptocheirus plumulosus ) using TGAI (Special Study)

Degradate – Prodiamine Benzimidazole

• GDLN 850.1300 – Aquatic Invertebrate Li fe Cycle Toxicity (Freshwater)

• GDLN 850.1350 – Aquatic Inverteb rate Life Cycle Toxic ity (Esturarine/Marine)

• GDLN 850.4400 (122-2) – Aqua tic Vascular Plant Tier II study using Lemna spp

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• GDLN 850.5400 (122-2) – Aquatic Plant Tier II Algal toxicity study

• GDLN 850.1500 – Freshwater Fish Life Cycle Study

• No Guideline Number Available, Study Title: Whole Sediment: Chronic Invertebrates Freshwater and Marine (using Hyaella azteca, Chironomus dilutus/C. tetans, and Leptocheirus plumulosus ) using prodiamine benzimidazole (Special Study)

Studies on Typical End-use Product

• GDLN 850.1010 – Acute Toxicity Freshwat er Invertebrates (Daphnia), TEP

• GDLN 850.1025/850.1055 – Estuarine Invertebra te Acute Toxicity (Mysid and Eastern Oyster are the preferred species), TEP

For a detailed discussion of the ecological risk assessment and data needs refer to the Registration Review – Preliminary Problem Form ulation for the Ecological Risk Assessment of Prodiamine, dated November 16, 2010, the EFED Response to Public Comments on Registration Review Preliminary Pr oblem Formulation for Prodiamine , dated May 5, 2011, and the (Registration Review – Addendum to the Preliminary Problem Formulation for the Ecological Risk Assessment of Prodiamine Clarifying Data Needs for the Major Degradate, Prodiamine Benzimidazole) , dated June XX, 2011 ) . These documents can be located in the prodiamine registration review docket (EPA-HQ-OPP-2010-0920) at: www.regulations.gov

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Human Health Risk:

• An analysis of toxicity studies and an assessment of occupational and residential exposure were conducted for prodiamine in December 1991 in support of the registration of prodiamine.

• The toxicity data base for prodiamine is substantially complete. However, data evaluation records (DERs) for the available toxi city studies need to be re-evaluated and updated based on current policies and pro cedures. In addition, a comprehensive evaluation of the available toxicity data is needed for the purpose of selecting points of departure (PODs) based on current endpoint sele ction criteria for a ll potential routes of exposure for registered uses of prodiamine.

• There were no food uses of prodiamine in 1992 when prodiamine was first registered. Therefore a dietary assessment was not requ ired. However, Special Local Need (SLN) registrations issued in 2005 and 2008 provide for use of prodiamine on irrigation ditches,Page 6 of 12 and the interpretation of the label is that the SLN labels constitute a food use. EPA anticipates requiring data to establish tole rances and will complete a dietary exposure

assessment.

• A quantitative drinking water assessment has not been conducted for prodiamine but will be conducted during Registration Review.

• A residential exposure assessment was c onducted for prodiamine in December 1991. Agency policies, standard operating proce dures, and exposure assessment methodologies have changed since the resi dential exposure assessment was conducted in 1991. In addition, a number of registrations for use of prodiamine on turf have been approved in recent years. A quantitative assessment of re sidential exposure and risk is anticipated.

• An aggregate risk assessment has not been conducted for prodiamine. An aggregate assessment may be required during registration review depending on the results of EPA’s reevaluation of dietar y, drinking water, and/or residential exposures.

• An occupational assessment was comple ted for prodiamine in December 1991. An updated occupational risk assessment ma y be conducted for prodiamine during registration review due to ch anges in exposure protocols a nd updated points of departure (PODs) identified as part of an upda ted hazard identification assessment.

• Prodiamine’s major degradate as identified in fate studies is prodiamine benzimidazole. Prodiamine benzimidazole was observed in rat metabolism studies. Since the results of the rat metabolism studies reflect the toxicity of both the parent and degradate, additional data are not anticipated to be required on prodiamine benzimidazole for mammalian toxicity.

• The database is complete with the exception of the following studies, which the Agency anticipates requiring in order to conduc t a complete human health assessment:

o 870.3250 - Subchronic inhalation study

o 870.7800 - Immunotoxicity (rats)

• The Agency interprets the language on the SL N labels for ditchbank uses as constituting a food use for those registrations. The Agency anticipates the need to require data to establish tolerances for this use, and anticipates requiring the following studies:

o 860.1300 - Nature of the Residue--Plants, Livestock

o 860.1380 - Storage Stability Data

o 860.1400 - Water, Fish, Irrigated Crops

o 860.1480 - Meat/Milk/Poultry/Eggs

o 860.1500 - Crop Field Trials

o 860.1520 - Processed Food/Feed (August 1996)

o 860.1850 - Confined Accumulation in Rotational Crops

o 860.1900 - Field Accumulation in Rotational CropsPage 7 of 12 • Please refer to Prodiamine: Human Health Risk Scoping Document in Support of Registration Review, dated November 10, 2010, located in the prodiamine docket, for a detailed discussion of the anticipated human health risk assessment needs.

Data No Longer Needed:

• The PWP for prodiamine noted that the Agency anticipated requiring GDLN 830.7050 - UV/Visible Light Absorption for prodiamine. Du e to a change in policy, the Agency will no longer require this study for the re gistration review of prodiamine.

• The PWP for prodiamine noted that the Agency anticipated requiring GDLN 835.2240 Photolysis in Water and GDLN 835.2410 Photol ysis in Soil for prodiamine. The registrant has submitted studies that fulfill the data gaps for these studies. Consequently, these studies are no longer required for the registration review of prodiamine.

• The PWP for prodiamine noted that the Agency anticipated requiring GDLN 850.1075 Acute Freshwater Fish Toxicity Test, GDLN 850.1075 Acute Saltwater Fish Toxicity Test Study, GDLN 850.1400 Fres hwater Fish Early Li fe Stage Study, GDLN 850.1400 Estuarine/Marine Fish Early Life Stage Study, GDLN 850.1010 Acute Toxicity Freshwater Invertebrates, a nd GDLN 850.1025/850.1035/850.1055 Acute Toxicity Estuarine/Marine Invertebrates on the de gradate prodiamine benzimidazole. These studies will no longer be required for prodiamin e benzimidazole. There is a low toxicity concern for parent prodiamine and low exposur e potential for the degradate prodiamine benzimidazole relative to parent prodiamine, thus the Agency has come to the conclusion that acute studies on prodiamine benzimidazo le in aquatic organisms would not be of high value.

New Data Needs:

• Longer-term toxicity studies wi ll be required on the degradat e prodiamine benzimidazole. The Agency will require GDLN 850.1500 Freshwat er Fish Life Cycle Study. A life cycle study is considered more useful than the earl y life stage study due to the bioaccumulation potential of prodiamine benzimidazole.

• The Agency will require a non-guideline Chro nic Freshwater Sedi ment Study: Chronic Invertebrates Freshwat er and Marine (using Hyaella azteca, Chironomus dilutus/C.
tetans, and Leptocheirus plumulosus ) using the degradate prodiamine benzimidazole. Prodiamine benzimidazole is likely to partiti on to soil and sediment and may enter the water via soil erosion. Parent prodiamin e has high chronic toxicity and prodiamine benzimidazole has a higher tendency to bind to soil relative to the parent, so these data will be required for risk assessment.

Timeline

EPA has created the following estimated timeline for the completion of the prodiamine registration review.Page 8 of 12 Registration Review for Prodiamine – Projected Registration Review Timeline
Activities Estimated Date Opening the Docket Open Docket and Public Comment Period 2010 – December Close Public Comment 2011 – February Case Development Final Work Plan 2011 – June Issue DCI 2012 – Jan. – March Data Submission 2014 – Jan. – March Open Public Comment Period for Draft Risk Assessments 2015 – July – Sept. Close Public Comment Period 2015 – Oct. – Dec. Registration Review Decision Open Public Comment Period for Proposed Registration Review Decision 2016 – Jan. – March

Close Public Comment Period 2016 – April – June Registration Review Decision and Begin Post-Decision Follow-up 2016 Total (years) 6

Summary of Comments Receive d During Docket Opening

The prodiamine registration review docket was open for a 60-day public comment period which began on December 22, 2010 and ended on February 22, 2011. During that time one prodiamine registrant, Syngenta Syngenta, submitted comments. The comments submitted by Syngenta focused on the anticipated environmental fate and ecological toxico logy data requirements discussed in the prodiamine PWP and Problem Formulation documents. Specifically, the registrant submitted proposed corrections to endpoints, molecular weights, and technical terms; offered suggestions for the use of certain studi es; and commented on the requirements for studies on the prodiamine degradate, prodiamine benzimidazole.

For a detailed description of the comments received and the Agency’s response to these comments refer to the EFED Response to Public Comments on Registration Review Preliminary Problem Formulation for Prodiamine (D386126) , dated May 5, 2011, and the (Registration Review – Addendum to the Preliminary Problem Formulation for the Ecol ogical Risk Assessment of Prodiamine Clarifying Data Needs for th e Major Degradate, Prodi amine Benzimidazole)

, dated June XX, 2011 ) . These documents can be located in the prodiamine registration review docket (EPA-HQ-OPP-2010-0920) at: www.regulations.gov

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EPA’s response to some of the comments submitted by Syngenta have been updated since EFED’s response to comments document was made available. These updates are listed below.

Syngenta Comment: Proposed data gap: 835.2240, Photodegradation in Water (Parent Prodiamine): Syngenta has recently submitted a study entitled Photolysis of 14C-Labelled Prodiamine in Sterile Natura l Water and Sterile pH 7 Buffe r under Laboratory Conditions

, by A. D. Hurt, G. Mason and K. Anderson, 15 September 2005 (MRID 48308301). ThisPage 9 of 12 study was conducted to comply with Japanese and OECD guidelines and should also address EPA questions regarding the photodegradation of parent and prodiamine benzimidazole (SYN-530120). The study demonstrated that prodia mine rapidly degrades photolytically with half-lives of less than 8 hours in both sterile natural water and pH 7 buffer.

EPA Response: EPA has determined that this study fulfills the datagap for photolysis in water of parent prodiamine (Guideline 835.2240). Consequently, this study will no longer be required for registration review.

Syngenta Comment: Proposed data gap: 835.2410, Photodegradation in Soil (Parent Prodiamine): Syngenta has recently submitted a study entitled Artificial Sunlight Photodegradation of 14C-Prodiamine on a Representative Agricultural Soil by R. N. Fathulla, 17 January 1996 (MRID 48308302). Prodi amine photodegraded rapidly in treated soil (half-life of ~5 days). Prodiamine benz imidazole was only a minor photodegradate (peak at 1.9% applied radioactivity) and underwent further photodegradation.

EPA Response: EPA has determined that this study fulfills the datagap for photolysis in soil of parent prodiamine (Guideline 835.2410). Consequently, this study will no longer be required for registration review.

Syngenta Comment: Proposed data gap: 835.2240, Photodegradation in Water (prodiamine benzimidazole, SYN530120): As indicated above, Syngenta has recently submitted photolysis studies which should addr ess questions regarding the behavior of prodiamine benzimidazole unde r photolytic conditions:

From these two photolysis studies, prodiam ine benzimidazole was found as only a minor or transitory photodegradate wh ich rapidly underwent further de gradation to one or more photodegradates.

Syngenta contends that the e-fates of bot h prodiamine and prodiamine benzimidazole (SYN530120) are well underst ood and supported by existing studies. Available e-fate data clearly indicate SYN530120 is not of c oncern environmentally since it is degraded rapidly under photolytic, aquatic/sediment ( aerobic and anaerobic) and anaerobic soil conditions. The photolysis and mobility studi es clearly indicate that under field conditions SYN530120 photodegrades rapidly and is likely only a minor metabolite with low leaching potential.

EPA Response: EPA has determined that the studies submitted fulfill the datagaps for photolysis in water and soil of parent prodiamine (Guidelines 835.2240 and 835.2410). It has been determined that some of the da ta requirements for prodiamine benzimidazole listed in the Preliminary Work Plan will no l onger be required. In their place two other studies will be required on the degradate, GDLN 850.1500 Freshwater fish life-cycle, and a non-guideline study, Chronic freshwat er sediment study using prodiaminePage 10 of 12 benzimidazole. For more information, please see the (Registration Review – Addendum to the Preliminary Problem Formulation for the Ecological Risk Assessment of Prodiamine Clarifying Data Needs fo r the Major Degradate, Prodiamine Benzimidazole) , dated June XX, 2011. )

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Data Requirements Table The Agency will issue a DCI for th e studies listed in Table 1 below. The required data identified in this FWP has changed from those the Agency anticipated as being needed in the prodiamine PWP. For a detailed descripti on of these changes please see the Registration Review – Addendum to the Preliminary Problem Formula tion for the Ecological Risk Assessment of Prodiamine Clarifying Data Needs for the Major Degradate, Prodiamine Benzimidazole) , dated June XX, 2011,, which can be located in the pr odiamine registration review docket (EPA-HQOPP-2010-0920) at: www.regulations.gov

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Table 1. Prodiamine Registrati on Review Data Requirements Data Requirement Guideline Number Listed In PWP Listed In FWP

Aerobic Aquatic Metabolism – parent prodiamine 835.4300

These studies are listed in both the PWP and FWP. The Agency will issue a DCI for these studies. Anaerobic Aquatic Metabolism – parent prodiamine 835.4400 Terrestrial Field Dissipation – Soil (footnote 7) – parent prodiamine 835.6100

Aquatic Field Dissipation – parent prodiamine 835.6200 Photodegradation in Water – prodiamine benzimidazole 835.2240

Adsorption/Desorption (Batch Equilibrium) – prodiamine benzimidazole 835.1230

Aquatic Invertebrate Life Cycle Toxicity (Freshwater), TGAI – parent prodiamine 850.1300

Aquatic Invertebrate Life Cycle Toxicity (Estuarine/Marine), TGAI – parent prodiamine 850.1350

Freshwater Fish Full Life Cycle Study, TGAI – parent prodiamine 850.1500

Estuarine/Marine Fish Life Cycle Study, TGAI – parent prodiamine 850.1500

Acute Avian Oral Toxicity Test with Passerine Species, TGAI – parent prodiamine 850.2100

Aquatic Vascular Plant Tier II study using Lemna spp.

, TGAI – parent prodiamine 850.4400

Aquatic Plant Tier II Algal Toxicity Study, TGAI – parent prodiamine 850.5400

Whole Sediment: Chronic Invertebrates Freshwater and Marine (using Hyaella azteca, Chironomus dilutus/C.

tetans , and Leptocheirus plumulosus ), TGAI – parent prodiamine Nonguideline

Aquatic Invertebrate Life Cycle Toxicity (Estuarine/Marine Invertebrates) - prodiamine 850.1300Page 11 of 12 benzimidazole

These studies are listed in both the PWP and FWP. The Agency will issue a DCI for these studies. Aquatic Invertebrate Life Cycle Toxicity (Estuarine/Marine) - prodiamine benzimidazole 850.1350

Aquatic Vascular Plant Tier II study using Lemna spp. - prodiamine benzimidazole 850.4400

Aquatic Plant Tier II Algal Toxicity Study - prodiamine benzimidazole 850.5400

Acute Toxicity Freshwater Invertebrates (Daphnia), TEP 850.1010

Estuarine Invertebrate Acute Toxicity (Mysid and Easter Oyster are the preferred species), TEP 850.1025 850.1055 Subchronic Inhalation Toxicity 870.3250

Immunotoxicity (Rats) 870.7800

Nature of the Residue – Plants, Livestock 860.1300

Storage Stability Data 860.1380

Water, Fish, Irrigated Crops 860.1400

Meat/Milk/Poultry/Eggs 860.1480

Crop Field Trials 860.1500

Processed Food/Feed (August 1996) 860.1520

Confined Accumulation in Rotational Crops 860.1850

Field Accumulation in Rotational Crops 860.1900

Photodegradation in Water – parent prodiamine 835.2240 Yes No The registrant has submitted studies that satisfy the datagaps for these requirements. Photodegradation in Soil – parent prodiamine 835.2410

UV/Visible Light Absorption 830.7050 Yes No Due to a change in policy EPA is no longer requiring this study for the registration review of prodiamine. Acute Toxicity Freshwater Invertebrates (Daphnia) – prodiamine benzimidazole 850.1010 Yes No These studies will no longer be required. Because there is a low toxicity concern for parent prodiamine and low exposure potential for the degradate prodiamine benzimidazole relative to parent prodiamine, the Agency has come to the conclusion that acute studies in aquatic organisms would not be of high value. Acute Freshwater Fish Toxi city Test (Rainbow trout) – prodiamine benzimidazole 850.1075

Acute Saltwater Fish Toxicity Test (Sheepshead minnow) - prodiamine benzimidazole 850.1075

Acute Toxicity Estuarine/Marine Invertebrates - prodiamine benzimidazole 850.1025 850.1035 850.1055 Freshwater Fish Early Life Stage Study (using a species for which acute data is available) - prodiamine benzimidazole 850.1400

Estuarine/Marine Fish Early Life Stage Study (using a species for which acute data is available) - prodiamine benzimidazole 850.1400Page 12 of 12 Freshwater Fish Life Cycle – prodiamine benzimidazole 850.1500 No Yes A life cycle study will be required instead of the early life stage study due to the bioaccumulation potential of prodiamine benzimidazole. Whole Sediment: Chronic Invertebrates Freshwater and Marine (using Hyaella azteca, Chironomus dilutus/C.

tetans , and Leptocheirus plumulosus ), prodiamine benzimidazole Nonguideline No Yes Prodiamine benzimidazole is likely to partition to soil and sediment and may enter the water via soil erosion. Parent prodiamine has high chronic toxicity and prodiamine benzimidazole has a higher tendency to bind to soil relative to the parent, so these data will be required for risk assessment.