# SUJATHA

SANKULA Digitally signed by SUJATHA SANKULA

DN: c=US, o=U.S. Government,

ou=USEPA, ou=Staff, cn=SUJATHA

SANKULA, dnQualifier=0000034075

Date: 2016.01.28 18:14:16 -05'00'

# 2 toxic to aquatic invertebra tes than the parent compound. EFED modeling (DP 329613+) predicts

that flubendiamide and its des-iodo degradate will accumulate in aquatic systems eventually

exceeding Agency levels of concern (LOCs).

The purpose of this analysis is to: 1) briefly su mmarize the previous risk assessments and more

recent risk analyses performed for flubendiamide; 2) evaluate recent data submissions from the

registrant; 3) assess ecological risk for a propos ed tree nut use amendment the registrant has

proposed to retain as the sole use on future flube ndiamide labels; and 4) determine if any of the

recent submissions and/or analyses have change d the Agency’s understanding of the risks posed

by current and proposed uses of flubendiamide.

2. Description of Past Ri sk Assessment Conclusions

Flubendiamide has been subject to three ecologic al risk assessments prior to this document:

• June 23, 2008: DP Barcodes: 329594, 329613, 329606, and 329599

• May 17, 2010: DP Barcodes: 368029, 368036, 368040, and 368055

• December 16, 2010: DP Barcodes: 376460, 376101, and 376102

The June 23, 2008 risk assessme nt addressed registration pr oposals for two flubendiamide

formulations. Flubendiamide formulation 480 SC was proposed for corn, cotton, tobacco, grapes,

pome fruit, stone fruit, and tree nut crops. A se cond formulation, 24 WG, was proposed for use

on cucurbit vegetables, fruiting vegetables, leafy ve getables, and brassica (cole) leafy vegetables.

The maximum application rate wa s 0.156 lbs a.i./A for pome fruit. Evaluation of the physical

and chemical properties indicat ed that flubendiamide is stab le to hydrolysis, aerobic and

anaerobic soil metabolism, and aer obic aquatic metabolism. Phot olysis and anaerobic aquatic

metabolism were reported to be the main routes of degradation for flubendiamide.

Flubendiamide degrades to NNI-0001-des-iodo (h ereafter referred to as des-iodo) under

anaerobic aquatic conditions (t 1⁄2 

# = 364 days) and direct aqueous photolysis (t 1⁄2 

# = 11.6 days), but

rather slowly by soil photolysis (t 1⁄2 

# = 70.5 days). Flubendiamide and des-iodo were reported to

have the potential for groundwater contamination in vulnerable soils with low organic carbon

content, after very heavy rainfall, and/or in the presence of shallow groundwater. The risk

assessment noted that flubendiamide and the des-iodo degradate overall stability/persistence

profiles were suggestive of accumulation in soils, water column, and sediments with each

successive application. Analysis of available ecological effects data resulted in the conclusion

that both flubendiamide and the des-iodo degrad ate were of toxicological concern. The risk

assessment concluded that there are risk concerns for to benthic invertebrates 2 

# exposed to

flubendiamide and its des-iodo degradate. Furthermor e, the risk assessment concluded that the

formulated products 480 SC and 24 WG were also of concern for acute and chronic risks to

freshwater invertebrates from direct introducti on to surface waters by spray drift deposition.

The May 17, 2010 risk assessment addressed a dditional registration proposals for 480 SC

formulation use on Christmas trees and legume vegetables including soybeans, and the 24 WG

formulation for rotational plant-b ack interval use for legume vegetables. The conclusions of the

2 

# Some species of aquatic invertebrates inhabit the overlying water (water above the sediment in a water body),

while others inhabit the benthic zone (in or on the sediment in a water body). Because exposure and effects

endpoints can vary between overlying and benthic (or pore) water, it is sometimes necessary to specify overlying or

benthic if referring to only one portion of the water body or one of these groups of aquatic invertebrates.

# 3 risk assessment were not markedly different from the 2008 risk assessment’s characterization of

the environmental fate, stressors of concern, nor the risk conclusions: 1) concern for long-term

accumulation of the parent flubendiamide and the des-iodo degradate; 2) both flubendiamide and

the des-iodo degradate as stressors of concern; an d 3) risk concerns for benthic invertebrates

from both flubendiamide and the des-iodo degradate to freshwater invertebrates. However, the

risk assessment also addressed the potential for distance buffers between application sites and

surface waters as a risk mitigation option. The risk assessment concluded that buffers, from a

spray drift perspective, would have little impact on the risks of concern.

The December 16, 2010 risk assessment addre ssed proposed new uses of flubendiamide on

alfalfa, globe artichoke, low growing berries (e xcept cranberry), peanut, pistachio, small fruit

vine climbing (except fuzzy kiwifruit), sorghum, sugarcane, sunflower, safflower, turnip greens

and a proposed increased applicat ion rate on brassica leafy vegetables. The proposed new uses

and increased rate pertained to the formula tions SYNAPSETM WG (39%), a water dispersible

granule formulation, and BELTTM SC (24% ai ), a suspension concentrate formulation.

Flubendiamide was proposed for ground application, aerial application (rest ricted for pistachio,

and small fruit vine climbing group) , and chemigation. Again as in the previous risk assessments,

flubendiamide and the des-iodo degradate were identified as the stressors of concern.

Environmental fate and transpor t data indicated that flubendiamid e is stable to hydrolysis,

aerobic and anaerobic soil metabolism, and aerobic aquatic metabo lism. Photolysis and

anaerobic aquatic metabolism appeared to be the main routes of degradation for flubendiamide.

Flubendiamide was expected to be slightly to hardly mobile in the environment. Des-iodo was

concluded to be persistent (stable in an aerobic soil environment), and expe cted to be moderately

mobile. As in the other risk a ssessments, concern was indicated for chronic risk to freshwater

invertebrates from exposures in the water colu mn and pore water from the total residues of

flubendiamide and des-iodo. The December 16, 2010 ri sk assessment mentions that a field study

on the efficacy of vegetative filter strips to reduce pesticide loading to surface waters was under

review at the time of writing. However, the results of that study were not incorporated into the

risk assessment.

3. Time-limited/Conditional Registration Requirements

Sections 3 through 6 describe a series of less form al risk assessments that were undertaken by the

Agency in response to data submissions, alte rnative modeling submitted by Bayer CropScience,

proposed label revisions, and Agency/OPP Risk Manager requests. The results of these

individual analyses are described and integrated into an overall risk a ssessment in Section 7.

Issues surrounding the use of vegetative filter strips

After the initial (June 23, 2008) risk assessment, th e registrant argued th at the 15-ft. vegetative

filter strip (VFS) included on all flubendiamide labels would largely prevent transfer of

flubendiamide from the field of application to downslope waterbodies, thereby limiting the

accumulation of flubendiamide and des-iodo in these waterbodies and preventing exceedances of

Agency LOCs. According to this argument, the Agency’s modeling over-estimated exposure and

therefore risk, because it could not account for the mitigation provided by the VFS.

The Environmental Fate and Effects Division (EFED) counter-argued that VFSs can be

beneficial for pesticides that would degrade in the VFSs, but flubendiamide would not be

expected to degrade in the VFSs due to its persistent nature. Ther efore, EFED believed

# 4 flubendiamide movement would only be “temporarily delayed” by the VFS ( i.e. , flubendiamide

washed into the VFS by a runoff event would lik ely be transported to a downstream waterbody

by a subsequent runoff event).

However, neither the registrant nor EFED had data to support either side’s argument. This

uncertainty is reflected in the preliminary acceptance letter dated 7/31/2008 (a document

notifying the registrant of the conditions of registration) which required the following:

1. Small-Scale Run-off/Vegetative Filter Strip Study – a run-off study to determine the

magnitude of the parent, flubendiamide, retained in filter strips of various widths; and

2. Farm Pond Monitoring Program – if risk asse ssment, based on the results from the smallscale run-off/vegetative filter strip study and additional available data indicates that there

are still risk concerns, monitoring of selected receiving waters will be required within

watersheds where flubendiamide will be used.

Flubendiamide was granted a time- limited/conditional registr ation while the registrant generated

the data necessary to address the uncertainties identified at the time of registration.

A major modeling error was identified in a curs ory review (DP 382010) of the small-scale runoff/vegetative filter strip study (M RIDs 48175602, 48175604, and 48175606) submitted by the

registrant in response to the first condition of re gistration. The Agency requested that the study

be corrected and resubmitted to the Agency, but the study was never re-submitted. Therefore, the

second requirement, the ‘farm pond’ m onitoring program, was triggered.

Requirements for Environmental Monitoring

The registrant submitted a monitoring protocol for flubendiamide and its metabolite, des-iodo

flubendiamide, in sediment and surface water (MRID 48010201). EFED recommended (DP

375361) three modifications of the proposed study. First, the submitted protocol should include

water bodies that will likely represent worst case scenarios in terms of flubendiamide

accumulation in sediment ( e.g. , ponds for which the entire upstream drainage area is treated with

flubendiamide). Second, the time period monitored should be extended to allow accurate

accumulation rates in sediment for flubendiamide and its des-iodo degradat e to be determined.

Third, the registrant needs to make available sufficient quantities of the technical grade active

ingredient and des-iodo degradate for analytical st andards, so that the U.S. Geological Survey

(USGS) can include these chemicals in their pesticide surveys.

After site selection studies in Georgia (MRID 48644901) and North Carolina (MRID 48535201),

the registrant and EFED agreed to monitoring a total of three ponds (two adjacent ponds in

Georgia (DP 398132) and one pond in North Caro lina (DP 394006)). Both sites were selected

from regions of the United States with hi gh initial (2009) flube ndiamide sales data.

In addition to the registrant’s monitoring effo rt, the USGS was able to add flubendiamide and

des-iodo to their pesticide monitoring pr ograms from 2012 onward (water sampling only, no

sediment monitoring).

Registrant-suggested Modeling Efforts

The registrant asked the Agency to consider modeling pond overflow in MRID 49532601. The

registrant documented overflow events at the ponds monitored in the farm pond study (MRIDs

49415303, 49415302, and 49415301), but did not measure ove rflow volumes or concentrations

# 5 in overflow for any of the ponds. In response to the registrant’s request, the Agency modeled

several scenarios (Appendix 1) using the “var ying volume and flowthrough” option in the

Surface Water Concentration Calculator (S WCC version 1.106; PRZM version 5.0; VVWM

version 1.0).

Modeling overflow dramatically decreases the pond estimated environmental concentrations

(EECs) in the Eastern/Southeastern United States scenarios modeled relative to the EECs based

on standard EFED modeling (which uses the “c onstant volume, no flowthrough” option). This

change in EECs is due to greater precipitation in the Eastern/Southeaste rn United States, which

keeps the pond near full capacity and causes overflow with most runoff events ( i.e. , little change

in EECs due to changing pond volume, but does in clude a significant pesticide mass loss through

overflow). However, EECs are higher in the We stern United States using the “varying volume

and flowthrough” option relative to standard EFED modeling that does not account for overflow.

In the Western United States, the farm pond is of ten below full capacity and refills rather than

overflows with most runoff events ( i.e. , concentration increases as pond volume diminishes,

while pesticide mass loss through overflow is rare).

Additionally, it is important to note that any fl ubendiamide or des-iodo “l ost” with overflow is

expected to accumulate in a different aquatic environment ( e.g. , lakes, reservoirs, and/or

estuaries) further downstream due to the persistence of these chemicals. Therefore, modeling

overflow doesn’t diminish the overall environmental consequences of flubendiamide

applications in the Eastern/Southeastern United St ates and results in higher EECs in the Western

United States (DP 426940).

Responses to Registrant Email Inquiries

The registrant asked the Agency to consider several topics through emails submitted 6/22/2015

and 6/30/2015. The 6/22/2015 email concerned USGS stream monitoring data, the proximity of

farm ponds to crop areas with flubendiamide use, and aquatic photolysis as an explanation for

the 66-day mesocosm study half-life. A re sponse provided on 7/8/2015 (DP 427901) concluded

that “the information contained in this submissi on would not change the conclusions of previous

EFED responses subsequent to the pond studies or previous EFED risk assessments”.

The 6/30/2015 email contained an attachment entitled “White Pa per: Flubendiamide Benefits,

Aquatic Risk Assessment Summa ry and Proposed Path Forwar d” (no MRID number) with

comments on several topics: 1) pond monitoring da ta; 2) USGS stream monitoring; 3) the low

extent of des-iodo formation in aerobic and se mi-aerobic environments ; 4) limited numbers of

ponds adjacent to high use areas; 5) lower toxicity compared to main comp etitor products; 6) fate

of flubendiamide and des-iodo in streams under re al world conditions; 7) interpretation of 3.5-

year monitoring data – farm pond accumulation; and 8) a proposed path forward. The Agency

responded (DP 427973) to the 2 nd 

# email on 7/15/2015 with the same response as for the first

email because the information provided did not change the conclusions of previous EFED

responses subsequent to the pond studies or previous EFED risk assessments.

Responses to Registrant Requests to Review Flubendiamide Analyses Prepared for Agency

Managers

In the fall of 2015, a series of presentations were made to the Office of Pesticide Programs (OPP)

Risk Managers regarding flubendiamide ( 10/28/2015 – 12/3/2015). As part of these

presentations, two series of analyses were produced at the request of the Risk Managers from the

# 6 Registration Division of OPP. Because the registrant asked to see these analyses, two memos

were subsequently produced to provide a written context to analyses so that the registrant could

better interpret these analyses. The first memo (DP 430747) compared four regulatory scenarios

for multiple crops based on the standard EFED aquatic modeling procedures. The crops selected

were those with the largest number of acres treated according to proprietary pesticide usage data

available to the Agency. The regulatory scen arios assumed maximum use rates from 2009 (the

year after flubendiamide was registered) to 2015 a nd then changed according to the regulatory

scenario modeled, which included ‘no change from current label’, ‘change to one ground

application forever’, ‘change to one ground app lication, then cancel in 2018’, and ‘cancel uses

after the 2015 application’. This analysis showed th at all four of the regulatory scenarios exceed

Agency LOCs for all of the simulated crops be cause too much flubendiam ide had already been

applied to these simulated fields through 2015 based on the maximum application rates on

current labels. Any additional a pplications beyond 2015 simply cau ses further deterioration of

the aquatic envir onment modeled ( i.e. , des-iodo would continue to accumulate adversely

affecting greater proportions of aquatic invertebrates with similar sensitivities to the organisms

from which the endpoints were derived as well as adversely affecting greater numbers of less

sensitive aquatic invertebrate species as those species’ tolerances are exceeded).

The second memo (DP 430972) provided additional ch aracterization of ecological risk through

consideration of a subset of crops proposed as posing limited ecological risk to aquatic

invertebrates. The crop scenarios were sel ected based on the 13 crops (or crop groups; i.e.

, alfalfa, brassica leafy vegetables, cotton (AZ and CA only), cucurbit vegetables, fruiting

vegetables, grape, leafy vegetables, legume ve getables, pome fruit, stone fruit, strawberry,

tobacco, and tree nuts) that the registrant propos ed to retain on flubendiamide labels (email from

Charlotte Sanson of Bayer CropScience to Susa n Lewis of USEPA on 12/15/15). The application

rates, number of applications per year and a nnual maximum application rates were based on an

email from Nancy Delaney of Bayer CropScien ce to Deborah McCall of USEPA on 8/12/15.

Only two application scenarios (high and low expos ure) were investigated for this second memo.

This analysis assumed no prior use of fl ubendiamide and modeled different numbers of

applications per year from the maximum allowed on the label down to one at the maximum

single application rate.

Additional analysis of all these crops was perfor med prior to a meeting with the registrant and

provided to the registrant at that meeting on 1/ 6/2016. This analysis used the same methods as

described in the second me mo and is attached to this memo as Appendix 3. These results confirm

the range of results in the second memo (DP 430972) and provides add itional results for the

entire set of uses described by the BCS emails.

4. Discussion of Fate and Effects Data Submitted after the Last Risk Assessment

Several fate and effects studies have been submitted since the last comprehensive risk

assessment conducted in 2010.

Toxicological Data

Subsequent to the risk assessments in 2010 additi onal sediment effects data were made available

to the Agency. In addition, over the course of several months OPP Risk Managers requested

additional perspective on the suite of effects observed in available sediment effects data at doses

beyond the no adverse effect concentra tion (NOAEC) for the available data.

# 7 Submissions of Sediment Toxicity Data After 2010

The registrant submitted a des-iodo degradate prolonged sediment toxicity test with Chironomus

riparius using spiked sediment (MRID 48175605). The Agency completed a data evaluation

record (DER) for this study in July of 2011. The study was classified supplemental and returned

a NOAEC at the highest dose tested: time weighted average (TWA) of 52.6 μ g of total

recoverable residue (TRR)/kg-dw sediment; TWA 7.18 μ g TRR/L overlying water; TWA 19.5

μ g TRR/L pore water.

In January of 2016 the registrant submitted a fl ubendiamide prolonged sedi ment toxicity test

with C. riparius using spiked sediment (MRID 49661801). The Agency has conducted an

evaluation of the study (DP 431040) and concludes that the study is scientifically sound and

suitable for use quantitatively in risk assessment. Consistent with other studies with this species

and sediment, emergence of the organisms pr oved to be the most sensitive endpoint. The

Agency’s Data Evaluation Record concludes that the NOAEC is TWA 12.3 μ g/L in overlying

water and TWA 4.32 μ g/L in pore water. The LOAEC is TWA 23.7 μ g/L in overlying water and

TWA 8.09 μ g/L in pore water.

Confirmation of Existing Studies

In 2015, while the evaluation of all lines of evidence was underway with respect to the efficacy

of vegetative filter strips, mode l assumptions and surface water monitoring, the Risk Managers

from the Registration Division of OPP requested that exposure modelling results be compared to

the full suite of effects endpoints from the two sp iked water prolonged sediment toxicity tests

with C. riparius (MRIDs 46817022 (flubendiamide) and 46817023 (des-iodo degradate)).

EFED issued a memorandum (DP 430746) that summa rized the approach for evaluation of the

two studies and the findings of that effort. The resulting endpoints, expressed as TWA, follow in

Tables 1 and 2.

Table 1. Flubendiamide Effects Endpoints (mg/L) from MRID 46817022

Concentration Based on Nominal

Treatment Concentration Based on Time

Weighted Average (TWA) Effect Observation

Overlying Water

0.04 0.015504356* NOEC Percent emergence

0.08 0.029875** LOEC 22% inhibition

0.16 0.062017426* 100% inhibition

Pore Water

0.04 0.001513025* NOEC Percent emergence

0.08 0.0025** LOEC 22% inhibition

0.16 0.006052101* 100% inhibition



# * based on nominal treatment a nd average ratio of nominal:TWA

** based on measured TWA

# 8 Table 2. Des-iodo Effects Endpoints (mg/L) from MRID 46817023

Concentration Based on Nominal

Treatment Concentration Based on Time

Weighted Average (TWA) Effect Observation

Overlying Water

0.004 0.00189775* NOEC Percent emergence

0.008 0.004135578** LOEC 17% inhibition

0.016 0.008271157** 33% inhibition

0.032 0.015995* 80% inhibition

Pore Water

0.004 0.00027825* NOEC Percent emergence

0.008 0.000737285** LOEC 17% inhibition

0.016 0.00147457** 33% inhibition

0.032 0.00391375* 80% inhibition



# * based on nominal treatment a nd average ratio of nominal:TWA

** based on measured TWA

A comparison of the past risk assessment use of the flubendiamide endpoints from MRID

46817022 is presented below (Table 3), and shows th at TWA concentrations were not reported

in previous risk assessments for the NOAEC in ov erlying and pore waters and that previous risk

assessments reported the LOAEC as a sing le post application measured dose of 69 μ g/L in

overlying water and 3 μ g/l in pore water.

Table 3. Current Flubendiamide Endpoints from the Spiked Water 28-day Chironomus riparius (MRID

46817022) Compared with Previous Assessments ( μ g/L)

Risk Assessment Overlying Water Con centrations Based

on Time Weighted Average Pore Water Concentrations Based on

Time Weighted Average

NOAEC LOAEC NOAEC LOAEC

June 2008 Not Calculated 69 (single measured

value) Not Calculated 3 (single measured

value)

May 2010 Not Calculated 69 (single measured

value) Not Calculated 3 (single measured

value)

December 2010 Not Calculated 69 (single measured

value) Not Calculated 3 (single measured

value)

Current 15 29.8 1.5 2.5



# A comparison of the past risk assessment use of the des-iodo degradate endpoints from MRID

46817023 is presented below in Table 4, and shows th at TWA concentrations are the same as

previous risk assessments for the NOAEC in overl ying and pore waters and that previous risk

assessments did not report a TWA for the LOAEC.

Table 4. Current Des-iodo Endpoints from the Spiked Water 28-day Chironomus riparius (MRID 46817023)

Des-iodo Compared with Previous Assessments ( μ g/L)

Risk Assessment Overlying Time Weighted Average Pore Time Weighted Average

NOAEC LOAEC NOAEC LOAEC

June 2008 1.9 Not Calculated 0.28 Not Calculated

May 2010 1.9 Not Calculated 0.28 Not Calculated

December 2010 1.9 Not Calculated 0.28 Not Calculated

Current 1.90 4.14 0.28 7.4

# 9 Final Suite of Available Effects Endpoints

The following is the final suite of flubendiamide and des-iodo endpoints for C. riparius in spiked

water and spiked sediment test s. Flubendiamide’s mode of ac tion is purported to be taxaspecific, principally targeting the lepidopteran ryanodine receptor. The extent to which the

receptor affinity for the compound and its degradat e changes across invertebrate taxa is not well

understood for all aquatic invertebra tes and so there remains uncertainty as to the representation

of any given species to all species within a taxonomic group. However, effects endpoints based

on the test organism C. riparius (not a lepidopteran) remain th e most sensitive available and,

consistent with EPA policy, are th e basis for the risk assessment.

Table 5. Current Flubendiamide and Des-iodo Endpoints for Chironomus riparius in Spiked Water and

Spiked Sediment Tests

Overlying Water TWA ( μ g/L) Pore Water TWA ( μ g/L) Endpoint Label

Flubendiamide – Spiked Water 28-Day (MRID 46817022)

15.5 1.51 NOAEC Percent emergence

29.9 2.50 LOAEC 22% inhibition

62.0 6.05 100% inhibition

Flubendiamide – Spiked Sediment (MRID 49661801) (in review)

12.3 4.32 NOAEC Percent emergence

23.7 8.09 LOAEC Percent emergence

Des-iodo – Spiked Water 28-Day (MRID 46817023)

1.90 0.278 NOAEC Percent emergence

4.14 0.737 LOAEC 17% inhibition

8.27 1.47 33% inhibition

16.0 3.91 80% inhibition

Des-iodo – Spiked Sediment (MRID 48175605)

7.18 19.5 NOAEC (Highest dose tested)

>7.18 >19.5 LOEC



# Registrant Endpoint Selection

In December 2014 the registrant submitted a document containing their perspective on

flubendiamide and des-iodo degradate sedime nt toxicity endpoints (MRID 49415302). The

following is a summary of the registrant’s endpoint selection:

x Flubendiamide Sediment Toxicity Study, Spiked Water (MRID 46817022) – results

based on nominal initial overlying water

o EC 50 

# 59 μ g a.i./L

o EC 15 

# 45 μ g a.i./L

o NOAEC 40 μ g a.i./L

x Flubendiamide Sediment Toxicity St udy, Spiked Sediment (MRID 49661801)

o NOAEC ȝJNJVHGLPHQW (dry weight)

o NOAEC 2.56 ȝJDL/SRUHZDWHU

x Des-iodo Degradate Sediment Toxicity Study, Spiked Water (MRID 46817023) – results

based on nominal initial overlying water

o EC 50 

# ȝJ/

o EC 15 

# ȝJ/

o NOA (&ȝJ/

# 10 x Des-Iodo Degradate Sediment Toxicity Study, Spiked Sediment (MRID 48178605)

o NOA (&ȝJNJVHGLPHQWGU\ZHLJKW

o NOAEC peak p RUHZDWHUȝJGHV -iodo/L

o NOA (&PHDQPHDVXUHSRUHZDWHUȝJGHV -iodo/L

x Flubendiamide Daphnia magna Reproduction Study, Spiked Water (MRID 46816944)

o 12$(&ȝJ/

Fate Data

The flubendiamide fate data interpretation has not changed since the 2008 and 2010 risk

assessment. Additional laboratory fate data was requested and submitted for des-iodo after the

time-limited/conditional regist ration. All of this de s-iodo data indicated that des-iodo does not

degrade in the environment with the exception of the recently (1/5/2016) submitted des-iodo

aquatic photolysis stud y, described below.

Des-iodo Aquatic Photolysis Study

The registrant submitted a 10-day, aqueous photolysis study (MRID 49661701) that estimates a

79-day half-life for des-iodo when expressed as an environmentally relevant half-life for June in

Phoenix, AZ. At the end of the 10-day study, 77% of the des-iodo remained as untransformed

des-iodo. The other 23% had transf ormed into 14 degradates and CO 2 

# . Because so many

degradates together make up so little mass, no degradate exceeded 6% and only two degradates

could be identified. None of the degradates have toxicity data, so none can be ruled out as toxic

degradates of concern other than CO 2 

# . Potentially, these degradates may be: more toxic than desiodo; as toxic as des-iodo; or less toxic than de s-iodo. Assuming that all of the degradates other

than CO 2 

# are as toxic as des-iodo would produce a half-life for the entire mass of toxic

metabolites (total toxic residue half-life) exceeding 1000 years. Therefore the 79-day aquatic

photolysis half-life for des-iodo estimated in MRID 49661701 should be considered an

optimistic estimate. Other caveats in using this half-life are discussed in Section 5.

5. Modeling Based on Tree Nut Use in California

The Agency received a new proposed label for flubendiamide on 1/8/2016 that limits use to tree

nuts in California only and further limits application rates for tree nut uses below that on the

current label. Up to three applications can be made to tree nuts, therefore modeling was

conducted for one to three applica tions per year. Modeling this proposed use in this memo allows

the Agency to perform an assessment of not only the reduced application rates, but also

incorporate the 79-day aqueous photolysis half-life for des-iodo into this assessment (previous

analyses had not used this half-life estimate since it was only submitted to the Agency on

1/5/2016).

Risk, based on the time-weighted average concentration endpoints (DP 430746) and on the

registrant-suggested endpoints, is displayed over time in the graphs of Figure 1 of Appendix 3. It

should be noted that EFED does not believe that the registrant-submitted toxicity endpoints are

appropriate because they appear to be based on the nominal con centrations to which the test

organisms were intended to be exposed rather than the measured, time-varying concentrations to

which the organisms were actually exposed.

Flubendiamide airblast applications to tree nuts were modeled usin g the California almond

scenario based on an application rate of 0.125 lbs a i/A with a 7-day application interval and up to

# 11 three applications per year. The scenario modele d assumes that flubendiamide has not previously

been used in the fields to which it is to be applied and includes a 30-ft spray drift buffer zone

around aquatic areas based on the new proposed la bel (previous modeling had only included a

15-ft spray drift buffer zone which was correct ba sed on the spray drift language of the previous

labels).

Because flubendiamide and its des-iodo degradate are expected to persist and accumulate in the

environment, the ecological risk posed by these chemicals in aquatic environments is expected to

increase over time. Therefore, the number of applications per year EECs are compared in a set of

graphs for each number of applications per year simulation depicting how ecological exposure

changes over time for flubendiamide in pore water, des-iodo in overlying water, and des-iodo in

pore water (flubendiamide in overlying water didn’ t exceed Agency LOCs and therefore, is not

presented).

Predicted changes in aquatic exposure over time are displayed in Figure 1 of Appendix 3 3 

# . To

provide an estimate of the ecological effects to be anticipated at different risk quotient levels, the

no observed adverse effect concentration (NOAEC) and any additional tr eatment levels that

showed a significant effect above the NOAEC (MRIDs 46817022, 46817023, 46816944 and

49661801) were included in the graphs of Figure 1 of Appendix 3. Analyzed endpoints include

both the Agency endpoints based on time-weighte d averages (Table 5 and DP 430746) and the

registrant-suggested endpoints (MRID 49415302) that are not supported by the Agency guidance

(DP 430746). Appendix 4 reports the input parameters used in this analysis. Results are

discussed in Section 7.

6. Confirmation of Risk from Lowest Exposure Scenario

The Risk Managers from the Registration Divisi on of OPP requested that exposure modeling be

conducted with the lowest possible exposure scenar io in conjunction with the half-life from the

recently submitted des-iodo photolysis study (M RID 49661701; discussed in Section 4). In the

document that evaluated ecological risk for 13 c rops proposed as posing limited ecological risk

to aquatic invertebrates (DP 430972) there was at least one crop use with more limited exposure

than the tree nut use from the latest propos ed label (Section 5). However, DP 430972 was

prepared before the des-iodo photolysis study was submitted to the Agency. Including the

photolysis half-life with the lowest exposur e scenario from DP 430972 (ground application to

cucurbit vegetables) would produce a lower ex posure than had been modeled. Therefore to

ensure that the Agency considered the lowest exposure (the scenario most favorable to the

registrant and least likely to exceed Agency LOCs), the lowest exposure scenario from DP

430972 was modeled with the des-iodo photolysis ha lf-life using the modeling assumptions from

the tree nut use in Section 5 (a 30-ft spray dr ift buffer and applied ass uming that flubendiamide

had not been previously applied to the modeled f ield under the higher application rates of the

current labels). The same assessment methods de scribed for assessment of tree nuts (Section 5)

were used also used in this analysis. Gra phical results are provided in Appendix 3 Figure 2.

Discussion of results occurs in Section 7.

3 

# Note that these graphs are presented in concentration units ( μ g/L) rather than risk units as in previous analyses (DP

430747 and 430972) and Appendix 2.

# 12 7. Integration of New Informat ion into the Risk Assessment

Results from the Farm Pond Monitoring Study (DP 412791+)

At the end of three years of monitoring, the registrant submitted the farm pond monitoring

reports (MRIDs 49415303, 49415302, and 49415301). EF ED identified several issues

(variability in crops grown, variability in the date of application(s), variability in the application

rates, magnitude of the study application rates compared to the maximum annual label

application rates, installation of grass waterways in the GA ponds’ watershed, dilution of pore

water and sediment samp les with underlying uncontaminated material) with this monitoring data

(DP 412791+). Despite these issues, EFED believe d the monitoring data showed clear evidence

that both flubendiamide and des-iodo accumulated in the ponds monitored 4 

# . The accumulation

measured in the first three years of the pond data least impacted by the identified issues largely

matched the initial 3 years of concentration predictions of EFED’s aquatic exposure modeling.

Because EFED’s modeling does not account for the effect of VFSs, but still largely matched the

monitoring data, EFED believes the effect of VFSs is not large enough to mitigate the ecological

risks posed by flubendiamide applications. EFE D concluded the origin al and subsequent

ecological risk assessments performed by the Agency (DP 329594+, 368029+, and 376460+)

adequately reflect the risks posed by flubendia mide applications and rejects the registrant’s

argument that the label-required 15-ft VFSs would prevent accumulation from exceeding

Agency LOCs (DP 412791+).

Analysis of Results from Four Regulat ory Scenarios for Multiple Crops (DP 430747)

When considering the time-weighted average endpoi nts (upper set of graphs on each page in

Appendix 1 Figure 1), all four of the regulatory scenarios exceed Agency LOCs for all of the

simulated crops. Consistently, the greatest exceed ances occur for des-iodo in pore water. Note

that many of these scenarios achieve exposure le vels that resulted in 80% emergence inhibition

in the des-iodo chronic laboratory toxicity study (MRID 46817023). (80% emergence inhibition

indicates that 80% of the test organisms were unable to emer ge as the adult, reproductive lifestage from the sediment where the juveniles reside, while only 20% were able to emerge and

potentially complete their life-cycle.) Such adverse impacts would directly impact aquatic

invertebrates in ponds, lakes, rese rvoirs, estuaries, areas of sediment accumulation in flowing

waterbodies and any non-flowing waterbodies wh ere des-iodo would accumulate downstream of

lands where flubendiamide is used as well as resu lt in indirect impacts to fish and wildlife for

which aquatic invertebrates serve as the basis for their food chain.

Flubendiamide and its des-iodo degradate pose a ri sk long after a regulatory action may take

place ( i.e. , there is a time-lag between mitigation and the maximum risk). For example, under the

“cancel now” regulatory scenario (light blue dots in Figure 1), flubendiamide applications to the

watershed above the modeled pond stop after 2015. However, risk from des-iodo in pore water

does not level-off (stop increasing) for more than a decade after. This time-lag is due to the time

required to transport the flubendiamide from the field to the pond and for flubendiamide in the

pond to convert into des-iodo.

4 

# The fitted trends increase with time (accumulate) in all of the 18 time-series data sets collected from these ponds [3

ponds × 3 media (water column, sediments, and pore water) × 2 chemicals = 18 time series data sets]. Fitting these

trends as exponential trends ( i.e. , fitting a linear trend to the natural log of the concentration observations) indicated

that 13 of these 18 trends were statistically significant at the p = 0.05 level of confidence. Continued monitoring

after the three year study period ended produced statistically significant trends in all 18 time series.

# 13 As a final note concerning the graphs base d on time-weighted average endpoints, exceedances

tend to occur quite early in the temporal tre nds. For example, all of the des-iodo pore water

graphs based on the time-weighted average endpo ints exceed Agency LOCs within 2 years.

Considering that flubendiamide applications c ould have started in 2009 for these crops, these

projected exceedances could have occurred as early as five years ago.

Even if risk were judged by the less sensitive endpoints suggested by the registrant (lower set of

graphs on each page in Appendix 1 Figure 1), a ll but two of the regulatory scenarios exceed

Agency LOCs. These two regulatory scenarios ar e the “Change to one ground application then

cancel after 2018” and “Cancel now” scenarios for the leafy vegetables (based on the CA lettuce

scenario, with ground applications initially in the first time period).

Analysis Results from High and Low Exposure Analysis for 13 Crop Uses (DP 430972)

Based on the two crops modeled to capture the ra nge of flubendiamide risk from the registrantproposed crops to be retained, both the high and low exposure/risk crop scenarios exceed

Agency LOCs (based on the time-weighted averag e endpoints). There is risk for all of the

numbers of applications modeled for both high and low scenarios even though the scenarios

assumed that flubendiamide was applied to fields to which flubendiamide had never before been

applied. The low exposure scenario exceeds Agency LOCs in: three years at six, five, or four

applications per year; four years at three applica tions per year; six years at two applications per

year; and nine years with only one application per year. The high exposure scenario applying two

applications per year (the most allowed by the registrant proposal) exceeds Agency LOCs in two

years, while the first exceedance occurs in three years with only one application per year.

Based on the TWA endpoints, all of the crop scenarios exceed exposure levels that resulted in

80% emergence inhibition in the des-iodo ch ronic laboratory toxicity study (MRID 46817023)

within the 30 years simulated except: ground a pplication to cucurbit vegetables at two

applications per year (would exceed 80% em ergence inhibition after 30 years) and one

application per year (exceeds 33% emergence inhib ition); airblast application to grapes at one

application per year (would exceed 80% emerge nce inhibition after 30 years); and airblast

application to stone fruit at one application per year (would ex ceed 80% emergence inhibition

after 30 years). Again such adverse impacts would directly impact aquatic invertebrates in ponds,

lakes, reservoirs, estuaries, ar eas of sediment accumulation in flowing waterbodies and any nonflowing waterbodies where des-iodo woul d accumulate downstream of lands where

flubendiamide is used as well as indirectly impact fish and wildlife for which aquatic

invertebrates serve as the basis for their food chain.

Although the Agency does not agree with the us e of the nominal-based endpoints that were

suggested by the registrant, with respect to th e registrant-suggested e ndpoints, the low exposure

scenario exceeds Agency LOCs in 11 years at six applications per year, 13 years at five

applications per year, 16 years at four applicati ons per year, and 21 years at three applications

per year. The low exposure scenario based on eith er one or two applica tions per year does not

exceed LOCs within the 30 years simulated ba sed on the registrant-suggested endpoints.

However, both application patterns of one or two applications pe r year would be expected to

eventually exceed if applications continued l ong enough. The high exposure scenario based on

two applications per year exceeds LOCs based on the registrant-suggested endpoints in eight

years, while the first exceedance occurs in 11 years with only one application per year.

# 14 Therefore, when considering the registrant’s less conservative proposed endpoints, use of

flubendiamide still results in risk concerns for aquatic invertebrates.

Tree Nut Assessment Results

Based on the time-weighted average endpoints, th e currently proposed flubendiamide tree nut

use results in risk that exceeds Agency LOCs for all numbers of applications modeled. The tree

nut scenario exceeds Agency LOCs in two years at three applications per year and three years at

two or one application(s) per year. All of the num bers of applications per year modeled exceed

exposure levels that resulted in 80% emergen ce inhibition in the des-iodo chronic laboratory

toxicity study (MRID 46817023) within the 30 years simulated even though these scenarios also

assumed that flubendiamide was applied to fields to which flubendiamide had never before been

applied.

Although the Agency does not agree with the us e of the nominal-based endpoints that were

suggested by the registrant, the proposed tree nut scenario exceeds Agency LOCs using these

endpoints in 10 years at three applications per ye ar, 11 years at two applications per year, and 21

years at one application per year. Therefore, when considering the registrant’s less conservative

proposed endpoints, use of flubendi amide still results in risk con cerns for aquatic invertebrates.

Recall that the tree nut use is based on the newly proposed label that includes an expanded spray

drift buffer and uses the maximum photolysis estimate ( i.e. , most degradation due to photolysis

and therefore, most favorable to the registrant’s position). Comparing the results of this analysis

for tree nuts to a model run assuming no photolysis (but, retains the 30-ft spray drift buffer)

decreases the 21-day average des-iodo overlying water EEC at year 30 by 24.1% (17.0 μ g/L vs

. 12.9 μ g/L). The reason for the 24% decrease in exposure is that des-iodo has a low K OC 

# and

therefore, tends to spend more time in the wa ter column where photolysis could occur than

chemicals with higher K OC 

# s.

However, there are several reasons to suspect that such a large photolysis effect would not occur

in the environment. First, the SWCC does not account for the change of light intensity as the sun

changes position throughout the year. In pure wa ter (no interference due to suspended sediment,

algae, etc .), the light intensity is greatest when the sun is directly overhead (typically near the

summer solstice in the United States) and least during the winter solstice, when the sun's daily

maximum elevation in the sky is at its lowest. The 79-day aquatic photolysis half-life estimate is

for June in Phoenix, AZ and likely represents an over-estimate for the rest of the year in Phoenix.

For parts of the United States further north, this half-life is likely an over-estimate throughout the

year.

Second, waters draining, or downstream of, agricultu ral land tend to have hi gh concentrations of

dissolved or suspended sediment and nutrients compared to the pure water in which aquatic

photolysis is measured. These impurities can bloc k light penetration. Ther efore after individual

storm events and/or throughout the rainy s eason, aquatic photolysis is likely greatly overestimated. Nutrients promote the growth of aquatic plants and algae which can block or limit

light penetration for much of the time of the year when sunlight is most intense in the Northern

United States or the entire year in the Southern United States (Note that in Figure 1 of DP

412791+, the Georgia ponds are a deep shade of green in images taken from September of 2010

and 2013.)

# 15 Thirdly, there is a mass transfer issue of des-i odo from the benthic sediment (where the des-iodo

would form and the majority of it would remain ) to the water column (where aqueous photolysis

could occur). In the SWCC, equilibrium is re-established between the benthic and overlying

water on a daily basis. Therefore any des-iodo degraded in the upper portion of the water column

where photolysis is greatest is replaced with des- iodo from the bottom sediment within 1 day. In

the actual environment, this transfer would likely be much slower as the des-iodo has to desorb

from the sediment and is impeded by thermal stra tification in waterbodies throughout much of

the year, especially during the summer when aqueous photolysis would potentially be at its

maximum.

Additionally as discussed previously, the degr adates produced through aqueous photolysis may

more be more or less toxic than des-iodo. Most of these degradates are unidentified and none

have toxicity data. Therefore, toxicity may not diminish as des-iodo de grades through aqueous

photolysis.

Note that EFED believes the SWCC performs qui te well under more typical situations where

pesticides degrade in shorter amounts of time ( e.g. , wintertime photolysis is not an issue if most

of the chemical has degraded within 60 days of a spring/summer application). It is specifically

due to the persistence of flube ndiamide and des-iodo that the a ssumptions of the SWCC have to

be examined in such great detail. Further note th at the farm pond monitoring results agreed quite

well with modelling predictions (Figure 6 in DP 412791+) using modeling parameters that did

not include the photolysis half-life. This provide s further support that the 79-day half-life overestimates the actual aqueous photolysis rate under environmental conditions.

Comparing the results of this analysis for tree nuts to a model run assuming no photolysis with a

30-ft spray drift buffer to a model run assuming no photolysis with a 15-ft spray drift buffer

decreases the 21-day average des-iodo overl ying water EEC at year 30 by 3.5% (17.6 μ g/L vs

. 17.0 μ g/L). Therefore the combined effect of includ ing the new des-iodo photolysis half-life and

extended spray drift buffer decreases the 21-day average des-iodo overlying water EEC at year

30 by 26.7% (17.6 μ g/L vs . 12.9 μ g/L).

Cucurbit Vegetable Assessment Results (Lowest Ex posure Scenario Combined with the Recent

Des-iodo Photolysis Half-life Estimate)

Based on the time-weighted average endpoints, th e optimistic des-iodo aque ous photolysis halflife, and a proposed 30-ft spray drift buffer, the cucurbit vegetable use (which results in the

lowest exposure) results in risk that exceeds Agency LOCs for all numbers of applications per

year modeled. The cucurbit vegetable scenario excee ds Agency LOCs in three years at six, five,

and four applications per year, four years at three applications per year, six years at two

applications per year, and nine ye ars at one application per year. N umber of applications per year

scenarios exceed exposure levels that resulte d in 80% emergence inhibition in the des-iodo

chronic laboratory toxicity study (MRID 46817023) within the 30 years simulated for six, five,

four, or three applications per year. Two a pplications per year exceeds the 33% emergence

inhibition within the 30 years simulated, while one application per year would exceed the 33%

emergence inhibition sometime after the 30 years simulated. Again such adverse impacts would

directly impact aquatic invertebra tes in ponds, lakes, reservoirs, estuaries, areas of sediment

accumulation in flowing waterbodies and any non-flowing waterbodies where des-iodo would

# 16 accumulate downstream of lands where flubendiamide is used as well as indirectly impact fish

and wildlife for which aquatic invertebrates serve as the basis for their food chain.

Although the Agency does not agree with the use of the nominal-based endpoints that were

suggested by the registrant, the cucurbit vegeta ble scenario using the optimistic des-iodo aqueous

photolysis half-life and proposed 30-ft spray drif t buffer, exceeds Agency LOCs in 12 years at

six applications per year, 14 years at five applicat ions per year, 18 years at four applications per

year, and 25 years at three applications per year . The lowest exposure scenario based on either

one or two applications per year does not exceed LOCs within the 30 years simulated based on

the registrant-suggested endpoints. However, the two applications per year scenario would be

expected to eventually exceed if applications continued long enough, while the one application

per year scenario probably would not. Additionallynote that all the caveats concerning the desiodo photolysis half-life discussed for tree nut s apply equally well to the cucurbit vegetable

assessment. Therefore, when considering the re gistrant’s less conservative proposed endpoints,

use of flubendiamide still results in risk concerns for aquatic invertebrates for all numbers of

applications per year except a single applica tion per year, and only under the most optimistic of

assumptions.

8. Results from USGS Monitoring

USGS data (2012 – early 2014) s howed detection of flubendiamid e and/or des-iodo in filtered

samples at 26 sites in 14 states (river and stream sites only, no ponds). California, Georgia, North

Carolina, Mississippi, and Louisiana had multiple sites with frequent detections (Figure 1). The

USGS monitoring effort complimented the targeted monitoring of the registrant by providing a

nationwide (though non-targeted) scale in which to interpret the registrant’s monitoring results.

These widespread, non-targeted, filtered USGS detections are comparable to concentrations

collected downstream from the monitored ponds, wh ich indicates that there may be depositional

zones similar to the monitored ponds upgradient from the widespread detections that have

concentrations similar to those in the mon itored ponds (which are well estimated by EPA

modeling that assumes the des-iodo degrad ate is stable to aqueous photolysis).

Figure 1. Flubendiamide detections in surface water samples collected by the USGS and registrant.

# 17 9. Conclusions

After review of the all of th e data submissions and previ ous risk assessments, EFED’s

conclusions on the environmental risks posed by flubendiamide at the time of writing are

consistent with those identified in 2008. EFED or iginally concluded that “Flubendiamide and its

degradate’s overall stability/persistence suggests that they will accumulate in soils, water

column, and sediments with each successive appl ication” (DP 329613+). EFED’s analysis of the

registrant’s field monitoring (farm pond) study co ncludes that there is 1) accumulation of both

flubendiamide and des-iodo in the water colu mn, sediment, and pore water for all ponds

monitored; and 2) definitive evidence that VFSs do not sufficiently control off-site transport of

these chemicals to downstream waterbodies. In addition, stream and river monitoring conducted

by the registrant and the U.S. Geological Survey over much of the United States indicates: 1) the

failure of VFSs to contain these chemicals is a widespread occurrence; and 2) the potential for

water quality impacts is also widespread. Based on the California almond scenario presented

above as well as the other recent mode ling (DP 430747, 430972, and Appendix 2), significant

effects to aquatic organisms due to the use of flubendiamide could potentially occur in as little as

2 years. While the registrant has raised many i ssues as discussed in detail above and in the

referenced documents, none have been persua sive that the original and subsequent risk

assessment conclusions were inaccurate nor have they diminished confidence in those

conclusions. Considering all the evol ving lines of evidence, there is increased confidence in the

conclusions contained in EFED’s past risk assessments for flubendiamide.18Appendix 1. Comparison of Four Regulatory Scenarios for Multiple Crops based on the Registrant-suggested Aquatic Modeling Procedures Including Pond OverflowFlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterSoybeans based on MS Soybean Scenario(Initially as Aerial Application; Applied Every Other Year)Time-weighted Average Endpoints0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.111010010002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.0010.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Comparison of Four Regulatory Scenarios for Nine Crops Using both Time-weighted and Registrant-suggested Endpoints19FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterTree Nuts based on CA Almond Scenario(Air Blast Application)Time-weighted Average Endpoints0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition11010010002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued20FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterTobacco based on NC Tobacco Scenario(Initially as an Aerial Application)Time-weighted Average Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued21FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterPeanuts based on NC PeanutsScenario (Initially as an Aerial Application)Time-weighted Average Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.0010.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued22FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterCucurbits based on FL Cucumber Scenario(Initially as an Aerial Application)Time-weighted Average Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.0010.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued23FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterCotton based on MS Cotton Scenaio(Initially as an Air Application)Time-weighted Average Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.0010.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued24FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterFruiting based on CA Tomato Scenaio(Initially as a Ground Application)Time-weighted Average Endpoints0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.111010010002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued25FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterLeafy Vegetables based on CA Lettuce Scenario(Initially as a Ground Application)Time-weighted Average Endpoints0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition11010010002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued26FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterAlfalfa based on PA Alfalfa Scenario(Initially as a Aerial Application)Time-weighted Average Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years100%NOAEC Present Studies Back22% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibitionRegistrant-suggested Endpoints0.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

Registered0.010.11101002000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)Years80%33%NOAEC Present Studies Back17% RegisteredInhibition0.0010.010.11102000 2005 2010 2015 2020 2025 2030 2035 2040

Risk Quotient (Unitless)YearsNOAEC Present Studies Back

RegisteredCancel Now (7 years aerial@ 4 apps/year, then Cancel)Change to 1 App. and Cancel (7 years ground or aerial @ 4apps/year, then 3 years ground @ 1 app/year, then cancel)Change to 1 App. Forever (7 years aerial @ 4apps/year, then 23 years ground @ 1 app/year)Current Label (30 years aerial @ 4 apps/year)Appendix 1 Figure 1. Continued27Appendix 2. Regulatory Scenario Comparisons Using Time-weighted Average Concentration Endpoints and Registrant-suggestedEndpointsAppendix 2 Table 1. Comparison of Time to Exceed Agency Levels of Concern in Years using boththe Time-weighted Average Endpoints and the Registrant-suggestedEndpoints for the Crops Retainedin Bayer CropScience's Proposal.BELT Label UsesApplicationType:A = AerialAB = AirblastG = GroundTime to Exceed Agency Levels of Concern (Years) based on the Number ofApplications (App.)1Application CharacteristicsMaximumSingleApplicationRate (lbs ai/A)Maximum # ofApplications(MinimumReapplicationInterval)MaximumAnnualApplicationRate (lbs ai/A)Time-weighted Average EndpointsRegistrant-suggested Endpoints1App.2App.3App.4App.5App.6App.1App.2App.3App.4App.5App.6App.AlfalfaA 3 3 NA 12 11 NA0.125 2 (21) 0.141G 4 4 NA 21 19 NABrassica LeafyVegetablesA 3 2 2 2 NA 10 7 6 5 NA0.075 4 (5) 0.282G 3 3 2 2 NA 12 8 7 6 NACotton (AZ and CAonly)A 3 3 NA 15 11 NA0.094 2 (5) 0.141G 5 4 NA 26 18 NACucurbit VegetablesA 5 3 3 2 2 2 28 16 12 10 8 70.047 6 (7) 0.282G 9 5 4 3 3 3 >30 >30 21 16 13 11Fruiting VegetablesA 4 3 3 2 2 2 21 13 10 8 7 70.047 6 (3) 0.282G 5 4 3 3 3 3 29 18 13 11 9 8GrapesG 7 5 4 NA >30 22 20 NA 0.125 3 (5) 0.282Leafy VegetablesA 3 2 2 2 2 2 14 9 7 6 6 50.047 6 (3) 0.282G 4 3 2 2 2 2 15 10 8 7 6 6Legume VegetablesA 3 2 2 NA 13 8 5 NA0.094 3 (5) 0.282G 4 3 2 NA 18 11 6 NAPome FruitAB 5 4 NA 27 17 NA 0.156 2 (7) 0.282Stone FruitAB 6 4 4 NA >30 19 18 NA 0.125 3 (7) 0.282StrawberryA 3 2 2 2 NA 10 7 5 5 NA0.075 4 (3) 0.282G 3 2 2 2 NA 11 7 6 5 NATobaccoA 3 2 NA 13 11 NA0.094 2 (5) 0.141G 4 3 NA 19 15 NATree NutsAB 3 3 2 NA 18 10 9 NA 0.125 4 (7) 0.2821It may seem that stopping flubendiamide applications just before the Agency Levels of Concern (LOCs) are exceeded based on theinformation provided in Appendix 2 Table 1might be a reasonable mitigation option. For example based on the time-weighted average endpoints, applying one application peryear by ground application methods to cucurbitvegetables first exceeds Agency LOCs in year nine; therefore limiting similar flubendiamide applications to eight years might seem to prevent Agency LOC exceedances.However, there is a multi-year time-lag between application and attaining the maximum risk level from prior applications. Underthe aforementioned cucurbit application scenario:stopping applications after year eight or seven still results in an exceedance later in year 9; stopping after year six only delays LOC exceedance to year 10; stopping after year fivedelays LOC exceedance to year 13; stopping after year four delays LOC exceedance to year 24; stopping after year three or lessdelays LOC exceedance beyond the 30 yearssimulated.28FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterAlfalfa based on CAalfalfa_WirrigOP Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L11010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Comparison of Potential Regulatory Scenarios Using Time-weighted Average Concentration Endpoints and Registrant-suggested Endpoints.29FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterAlfalfa based on CAalfalfa_WirrigOP Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L11010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Continued.30FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterBrassica Leafy Vegetables based CAColeCropRLF_V2 Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.31FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterBrassica Leafy Vegetables based CAColeCropRLF_V2 Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.32FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterCotton (AZ and CA only) based CAcotton_WirrigSTD Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L11010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Continued.33FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterCotton (AZ and CA only) based CAcotton_WirrigSTD Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Continued.34FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterAerial Low Exposure Scenario: Cucurbit Vegetable based on CAMelonsRLF_V2 Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.35FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterGround Low Exposure Scenario: Cucurbit Vegetable based on CAMelonsRLF_V2 Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.36FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterFruiting Vegetables based on CARowCropRLF_V2 Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.37FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterFruiting Vegetables based on CARowCropRLF_V2 Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.38FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterGrapes based on CAgrapes_WirrigSTD Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.39FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterLeafy Vegetables based on CAlettuceSTD Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.40FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterLeafy Vegetables based on CAlettuceSTD Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.41FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterLegume Vegetables based on CARowCropRLF_V2 Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.42FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterLegume Vegetables based on CARowCropRLF_V2 Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.43FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterHigh Exposure Scenario: Pome Fruit (Single Application Rate = 0.156 lb ai/A) based on CAfruit_WirrigSTD Scenaio (Air Blast Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Continued.44FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterStone Fruit based on CAfruit_WirrigSTD Scenario (Airblast Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.45FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterStrawberry based on CAStrawberry-noplasticRLF_V2 Scenario (Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.46FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterStrawberry based on CAStrawberry-noplasticRLF_V2 Scenario (Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.111010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.47FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterTobacco based on NCtobaccoSTD Scenario using a TN Weather File (W13882.dvf; Aerial Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L11010010000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Continued.48FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterTobacco based on NCtobaccoSTD Scenario using a TN Weather File (W13882.dvf; Ground Application)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LOne application per year for 30 yearsTwo applications per year for 30 yearsAppendix 2 Figure 1. Continued.49FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterTree Nuts based on CAalmond_WirrigSTD Scenario (Airblast Application)Agency Endpoints based on Time-weighted Average Concentrations0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)Years100%NOAEC*22%Inhibition*Based on a NOAEC of 1.51μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 1.89μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 0.28μg/LRegistrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Risk Quotient (Unitless)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11100 5 10 15 20 25 30

Risk Quotient (Unitless)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsOne application per year for 30 yearsAppendix 2 Figure 1. Continued.50Appendix 3. Results of the Tree Nut and Cucurbit vegetable Use Assessments with the Des-iodo Aqueous Photolysis Half-life Included.FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterTree Nut Assessment based on CA Almond Scenario (Airblast Application with Maximum Photolysis Rate and 30-ft Spray Drift Buffer)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years100%NOAEC*22%InhibitionNOAEC*LOAEC*Based on NOAECs of 1.51μg/L (reddashed lines andlabels; MRID 46817022 – spiked water) or 4.32μg/L(bluedashed lines; MRID 49661801 – spiked sediment).0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years80%33%NOAEC*17%InhibitionNOAEC**Based on a NOAEC of 1.89μg/L (reddashed lines andlabels; MRID 46817023 – spiked water) or 7.18μg/L(bluedashed line; MRID 48175605 – spiked sediment).0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years80%33%NOAEC*17%InhibitionNOAEC**Based on a NOAEC of 0.28μg/L (reddashed lines andlabels; MRID 46817023 – spiked water) or 19.5μg/L(bluedashed line; MRID 48175605 – spiked sediment).Registrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Concentration ( μ g/L)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.010.11101000 5 10 15 20 25 30

Concentration ( μ g/L)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsOne application per year for 30 yearsAppendix 3 Figure 1. Comparison of Time-weighted Average Concentration Endpoints and Registrant-suggested Endpoints for the Tree Nut Scenario51FlubendiamideDes-iodoBenthic Pore WaterOverlying WaterBenthic Pore WaterCucurbit Vegetable based on CAMelonsRLF_V2 Scenario (Ground Application with Maximum Photolysis Rate and 30-ft Spray Drift Buffer)Agency Endpoints based on Time-weighted Average Concentrations0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years100%NOAEC*22%InhibitionLOAECNOAEC**Based on NOAECs of 1.51μg/L (reddashed lines andlabels; MRID 46817022 – spiked water) or 4.32μg/L(bluedashed lines; MRID 49661801 – spiked sediment).0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years80%33%NOAEC*17%InhibitionNOAEC**Based on a NOAEC of 1.89μg/L (reddashed lines andlabels; MRID 46817023 – spiked water) or 7.18μg/L(bluedashed line; MRID 48175605 – spiked sediment).0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years80%33%NOAEC*17%InhibitionNOAEC**Based on a NOAEC of 0.28μg/L (reddashed lines andlabels; MRID 46817023 – spiked water) or 19.5μg/L(bluedashed line; MRID 48175605 – spiked sediment).Registrant-suggested Endpoints0.010.11100 5 10 15 20 25 30

Concentration ( μ g/L)YearsNOAEC**Based on a NOAEC of 2.56μg/L0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)Years80%33%NOAEC*17%Inhibition*Based on a NOAEC of 4.0μg/L0.11101000 5 10 15 20 25 30

Concentration ( μ g/L)YearsNOAEC**Based on a NOAEC of 19.5μg/LTwo applications per year for 30 yearsThree applications per year for 30 yearsFour applications per year for 30 yearsFive applications per year for 30 yearsSix applications per year for 30 yearsOne application per year for 30 yearsAppendix 3 Figure 2. Comparison of Time-weighted Average Concentration Endpoints and Registrant-suggested Endpoints for the Cucurbit Vegetable Scenario.

# 52 Appendix 4. Flubendiamide Chemical Parameter Inputs to the Surface Water

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