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 prodiamine registration review 

docket (EPA-HQ-OPP-2010-0920), and any other comments concerning the initial docket 

postings. The Summary Document provided information on what EPA 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 review 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 registration 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 statutory 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/oppsrrd1/registration_review/. 

Prodiamine is a dinitroaniline herbicide first registered in 1992 for selective, pre-emergent 

control of many grasses and broadleaf weeds. Prodiamine is registered for use in non-crop areas 

such as rights-of-way, conifer and hardwood seedling nurseries, established perennial and 

wildflower plantings, established turf sites, residential and institutional lawns, commercial sod 

farms, golf courses, railways, and landscape ornamentals. There are two Special Local Needs 

(SLN) registrations in California and Arizona for use on irrigation drainage ditches, spreading 

grounds, channels, canals, and levees in wastewater treatment facilities. There are over 150 

prodiamine products currently registered. 

 

Updates since Preliminary Work Plan was Issued

The Agency indicated in the prodiamine PWP 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 review. 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 required in registration 

review. In addition, due to a change 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 studies will no longer be required (GDLN 850.1075 

Acute Freshwater Fish Toxicity Test, GDLN 850.1075 Acute Saltwater Fish Toxicity Test 

Study, GDLN 850.1400 Freshwater Fish Early Life Stage Study, GDLN 850.1400 
Page 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 Acute Toxicity Estuarine/Marine 

Invertebrates). The Agency has come to the conclusion that acute studies on prodiamine 

benzimidazole in aquatic organisms would not be of high value, because there is a low aquatic 

acute toxicity concern for parent prodiamine and low exposure potential for the degradate 

prodiamine benzimidazole relative to parent prodiamine. 

Instead of requiring acute aquatic toxicity studies on prodiamine benzimidazole, the Agency will 

require longer-term aquatic toxicity studies on prodiamine benzimidazole, specificallyGDLN 

850.1500 Freshwater Fish Life Cycle Study and a non-guideline Chronic Freshwater Sediment 

Study: Chronic Invertebrates Freshwater and Marine (using Hyaella azteca, Chironomus 

dilutus/C. tetans, and Leptocheirus plumulosus) using the degradate prodiamine benzimidazole. 

For further details regarding changes to the data requirements refer to 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, which can be located in the prodiamine registration review docket (EPA-HQOPP-2010-0920) at: www.regulations.gov.

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 the prodiamine PWP, from registrant Syngenta 

Crop Protection Inc. (Syngenta). The comment received did not change the risk assessment and 

data needs or the timeline detailed 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 requirements, 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 the 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 Agency will conduct a comprehensive ecological risk 

assessment including an endangered species risk assessment; as well as dietary (food and 

drinking water), occupational (handler and post-application), and residential (handler and postapplication) exposure and risk assessments for prodiamine. Prior 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 Sheet were completed for prodiamine in 1991. 

• The Agency has not conducted a risk assessment that supports a complete endangered 

species determination for prodiamine. The 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 threatened or endangered species (listed species) 

or their designated critical habitats. When an assessment concludes that a pesticide’s use 

“may affect” a listed species or its designated critical habitat, the Agency will consult 

with the U.S. Fish and Wildlife Service (FWS) and/or National Marine Fisheries Service 

(NMFS) (the Services), as appropriate. 

• On January 19, 2011, the Center for Biological Diversity and the Pesticide Action 

Network North America filed a lawsuit in the United States District Court for the 

Northern District of California, against the Environmental Protection Agency (EPA) for 

allegedly failing to undergo consultation with the United States Fish and Wildlife Service 

and the National Marine Fisheries Service regarding the effects of over 350 pesticides, 

including prodiamine, on over 200 endangered and threatened species throughout the 

United States (Center for Biological Diversity, 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 species 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) – Terrestrial field dissipation – soil 

• GDLN 835.6200 – Aquatic field dissipation 

Degradate – Prodiamine Benzimidazole 

• GDLN 835.2240 – Photodegradation in water 

• GDLN 835.1230 – Adsorption/desorption (batch equilibrium) 

 Ecological toxicity data gaps

 Parent Prodiamine 

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

• GDLN 850.1350 – Aquatic Invertebrate Life Cycle Toxicity (estuarine/marine), 

TGAI 

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

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

• GDLN 850.2100 – Acute Avian Oral Toxicity Test using a passerine species, TGAI 
Page 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 Life Cycle Toxicity (Freshwater) 

• GDLN 850.1350 – Aquatic Invertebrate Life Cycle Toxicity (Esturarine/Marine) 

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

• 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 Freshwater Invertebrates (Daphnia), TEP 

• GDLN 850.1025/850.1055 – Estuarine Invertebrate 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 Formulation for the Ecological Risk Assessment 

of Prodiamine, dated November 16, 2010, the EFED Response to Public Comments on 

Registration Review Preliminary Problem 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. 

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 toxicity studies need to be re-evaluated and 

updated based on current policies and procedures. 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 selection criteria for all 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 required. 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 tolerances 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 conducted for prodiamine in December 1991. 

Agency policies, standard operating procedures, and exposure assessment methodologies 

have changed since the residential 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 residential 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 dietary, drinking water, and/or residential exposures.

• An occupational assessment was completed for prodiamine in December 1991. An 

updated occupational risk assessment may be conducted for prodiamine during 

registration review due to changes in exposure protocols and updated points of departure 

(PODs) identified as part of an updated 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 conduct a complete human health assessment: 

o 870.3250 - Subchronic inhalation study

o 870.7800 - Immunotoxicity (rats)

• The Agency interprets the language on the SLN 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 Crops 

 
Page 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. Due to a change in policy, the Agency will 

no longer require this study for the registration review of prodiamine. 

• The PWP for prodiamine noted that the Agency anticipated requiring GDLN 835.2240 

Photolysis in Water and GDLN 835.2410 Photolysis 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 Freshwater Fish Early Life Stage Study, GDLN 850.1400 

Estuarine/Marine Fish Early Life Stage Study, GDLN 850.1010 Acute Toxicity 

Freshwater Invertebrates, and GDLN 850.1025/850.1035/850.1055 Acute Toxicity 

Estuarine/Marine Invertebrates on the degradate prodiamine benzimidazole. These 

studies will no longer be required for prodiamine benzimidazole. There is a low toxicity 

concern for parent prodiamine and low exposure potential for the degradate prodiamine 

benzimidazole relative to parent prodiamine, thus the Agency has come to the conclusion 

that acute studies on prodiamine benzimidazole in aquatic organisms would not be of 

high value. 

New Data Needs: 

• Longer-term toxicity studies will be required on the degradate prodiamine benzimidazole. 

The Agency will require GDLN 850.1500 Freshwater Fish Life Cycle Study. A life cycle 

study is considered more useful than the early life stage study due to the bioaccumulation 

potential of prodiamine benzimidazole. 

• The Agency will require a non-guideline Chronic Freshwater Sediment Study: Chronic 

Invertebrates Freshwater and Marine (using Hyaella azteca, Chironomus dilutus/C. 

tetans, and Leptocheirus plumulosus) using the degradate prodiamine benzimidazole. 

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. 

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 Received 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 toxicology 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 studies; 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 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. 

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 Natural Water and Sterile pH 7 Buffer under Laboratory Conditions, 

by A. D. Hurt, G. Mason and K. Anderson, 15 September 2005 (MRID 48308301). This 
Page 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 prodiamine 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). Prodiamine photodegraded rapidly in treated 

soil (half-life of ~5 days). Prodiamine benzimidazole 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 address questions regarding the behavior of 

prodiamine benzimidazole under photolytic conditions: 

From these two photolysis studies, prodiamine benzimidazole was found as only a minor 

or transitory photodegradate which rapidly underwent further degradation to one or more 

photodegradates. 

Syngenta contends that the e-fates of both prodiamine and prodiamine benzimidazole 

(SYN530120) are well understood and supported by existing studies. Available e-fate 

data clearly indicate SYN530120 is not of concern environmentally since it is degraded 

rapidly under photolytic, aquatic/sediment (aerobic and anaerobic) and anaerobic soil 

conditions. The photolysis and mobility studies 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 data requirements for prodiamine benzimidazole 

listed in the Preliminary Work Plan will no longer 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 freshwater sediment study using prodiamine 
Page 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 for the Major Degradate, Prodiamine 

Benzimidazole), dated June XX, 2011.). 

Data Requirements Table

The Agency will issue a DCI for the 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 description of these changes please see 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,, which can be located in the prodiamine registration review docket (EPA-HQOPP-2010-0920) at: www.regulations.gov. 

Table 1. Prodiamine Registration 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 

850.1300 
Page 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 Toxicity 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 

850.1400 
Page 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.