Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

1 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION **UNITED ST AT**  **ES ENVIRONMENT AL**  **PROTECTION A GENCY** 

WA SHINGTON D.C., 20460

**MEMORANDUM DATE:**  **0 8/2**  **4 /2011**  **SUBJECT:** Non - target Organism and Endangered Species Screening Risk Assessment

for the Meth yl Anthranilate (Benzoic Acid, 2 - Amino , Methyl Ester) Registration Review Preliminary Work Plan **Chemical Class:** Biochemical **PC Code:** 128725 **CAS Number:** 134 - 20 - 3 **Tolerance Exe mptions:**  40 CFR 180. **FROM:** Russell S. Jones, Ph.D., Senior Biologist

Biochemical Pesticides B ranch Biopes ticides & Pollution Prevention Division **TO:** Chris Pfeifer, Regulatory Action Leader

Biochemical Pesticides Branch Biopes ticides & Pollution Prevention Division **EXECUTIVE SUMMARY** The bird repellent , Methyl Anthranilat e, in a naturally occurring flavoring substance in grapes. The repellent action arises from the stimulation of the trigemimal nerve in the head of a bird resulting in a pain response (Kirifides et. al., 2004). Based on the available data and information, the Agency does not foresee the need for new data or for new risk assessments for this active ingredient. Non - target organism h azard and exposure information as well as Agency risk assessments on Methyl Anthranilate were evaluated against current safet y standards establ ished by the Agency ’s scientific policies and regulations and it was determined that there is no need to conduct additional risk assessments. The active ingredient is a naturall y occurring substance , has a non - toxic mode of action, and is of low toxicity . There is reasonable certaint y of no harm to non - target organisms when Meth yl Anthranilate is applied in accordance with EPA - approved productMethyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

2 labeling. A screening level assessment was conducted to evaluate th e existing non - target organism data base. T oxic endpoints have not been identified for non - target mammals and non - target birds on an acute and dietary

basis in laboratory

testing (respective non - definitive endpoints of >5000 mg/kg and >500 mg/kg/day) . The active ingredient is moderately toxic to slightly

toxic to freshwater fish on a acute basis (9.12 ppm to 42.56 ppm), and practicall y non - toxic on a dietary basis (>1000 mg/kg in diet) in laboratory testing. It is slightl y toxic to aquatic invertebrates (17.0 to 29.1 ppm). Toxic endpoints have n ot been established for non - target insects (honey

bees). Non - target terrestrial plants can tolerate >40,000 ppm of Methyl Anthranilate before exhibiting an y observable foliar desiccation or necrosis (MRID 42740204). Based on the highest respective applic ation rates for terrestrial and aquatic use sites, calculated Risk Quotients (RQs) are all < 0.05 for all taxa. Based on the fact that Methyl Anthranilate is relatively no n - toxic to non - target organisms and on its use pattern and use instructions, EPA h as determined that Meth yl Anthranilate will have **"No Effect"** on any currentl y listed threatened or endangered species or an y designated critical habitat. **1. Description of the Active Ingredient**  **Common Name:** Methyl Anthranilate **Chemical Name:** Ben zoic Acid, 2 - Amino, Methyl Ester **Synonyms:** Anthranilic Acid, meth yl ester

Methyl - 2 - amonobenzoate Methyl o - aminobenzoate o - Carbomethox yaniline Neroli Oil Nevoli Oil **CAS Number:** 134 - 20 - 3 **Empirical Formula:** C 8 H 9 NO 2

**Figure 1. Structure of Methyl Anthranilate** Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

3 Methyl Anthranilate is a repellent used to repel pest birds from food use and non - food use sites. The active ingredient is employ ed in pesticide products used on landfills, tailing ponds, co mmercial/industrial water impoundments, temporary pools, decorative fountains, non - fish bearing waters , electrical substations, farmsteads, agricultural sites, structures, buildings, airports & other open areas; ornamental trees & shrubs; turf; lakes, pond s, harbors, boat docks, aquatic production sites (non - fish bearing waters such as hatcheries and culture ponds), pome fruits, stone fruits, cereal grains, blueberries, sunflowers, table grapes, and turf. Methyl Anthranilate was classified as a Biochemical Pesticide Active Ingredient by the OPP Biotechnology

Work Group August 24, 1992 (EPA, 1992 ). **2. Registered End**  **- Use Products and Maximum Use Rates**  There are 7 currently

registered End - Use Products (EPs) containing Methyl Anthranilate as the ir active i ngredient (see Appendix Table 1 ). **3 .**  **Ecological Hazards** Adequate non - target toxicology data/information are available to support registration of Methyl Anthranilate . All non - target organism toxicology data requirements for Meth yl Anthranilate have b een satisfied. No additional data are required. There are no concerns for an y non - target organisms when Methyl Anthranilate is applied in accordance with EPA - appr oved label use directions. T oxic endpoints have not been identified for non - target mammal s and non - target birds on an acute and dietary basis in laboratory

testing . The active ingredient is moderately toxic to slightly

toxic to freshwater fish on a acute basis , and practicall y non - toxic on a dietary basis in laboratory

testing . It is slightl y toxic to aquatic invertebrates. Toxic endpoints have not been established for non target insects (honey

bees). Non - target terrestrial plants can tolerate >40,000 ppm of Methyl Anthranilate before exhibiting an y observable foliar desiccation or necrosis ( MRID 42740204 ). A review of the ECOTOX database did not reveal any additional non - target toxicity data or endpoints that w ere lower than those previousl y evaluated b y the Agency . **4. Environmental Fate and Ground Water Data**  The need for environm ental fate and groundwater data was not triggered because results of the acute toxicity

assessment did not trigger any additional Tier I studies. Some data, however, are available from studies submitted in support of a Tolerance Exemption and from externa l technical sources . Residues of Methyl Anthranilate (MA) applied to food crops are expected to dissipate to background levels before they are distributed for consumption.Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

4 Methyl anthranilate is extremely volatile (vapor pressure of 2.7 x 10 - 2 mm Hg at 25 o C) and will rapidly

dissipate into the surrounding atmosphere from foliar surfaces to which it has been applied , and is expected to have an atmospheric half - life of 11 hours (HSDB, 2004). Based on its vapor pressure and low water solubility, MA is al so expected to volatilize rapidly from water surfaces (HSDB, 2004) in a s little as 16 day s. D ata obtained from the technical literature suggest a range of degradation rates depending upon environmental conditions. Aronov and Clark (1996) report that MA is not subject to hydrol ys is under laboratory conditions between pH 5 to pH 9 in aqueous phosphate buffers, but is susceptible to degradation by UV light (up to 42% after 27 day s of illuminance at 1.25 mW cm - 2 , equivalent to natural sunlight at noon at 40 o north latitude). Microbial activity was observed to be a significant degradation pathway with 22% loss after nine day s and 100% loss after 20 day s at optimal conditions of light and temperature ( a 12:12 hr light:dark cycle and 23 o C). Laboratory

studies (Askham, 1992) with MA on glass slides demonstrated that MA was extremel y photolabile with 50% loss after two day s of exposure to full sunlight and was undetectable after four day s exposure. Avery et. al. (1995) reported residues on rice as 11.7 ppm imme diately following an application of ReJex - ItAG - 36 (14.5% a.i.) at 6.2 lb a.i./A, which rapidl y declined over the next 14 day s with a half

- life of 7 day s (interpolated by reviewer based on study

author data). The application rate used in this study is equ ivalent to the maximum approved label application rate for food crops (see Appendix Table 1). Based on data from empirical studies, MA residues will be low immediately following application and will rapidly dissipate in terrestrial environments under th e combined influences of UV light and microbial degradation (Aronov & Clark, 1996; Askham, 1992) . Low solubility

in water coupled with rapid volatilization and microbial degradation will result in minimal residues in aquatic habitats . **5. Ecological Exposure and Risk Characterization**  Methyl Anthranilate is a naturally - occurring substance in plants such as corn, sunflowers, grapes (33 ppm) and cherries (35 ppm) , as well as cocoa and black tea (EPA, 1994). H oney made from citrus floral sources has be en reported to contain from 3.60 to 5.04 mg/kg of MA (Ferreres et. a., 1994 ; White & Bry ant, 1996, unpublished study). It is extremel y volatile and degrades rapidl y into non - toxic components such as anthranilic acid. Numerous studies are available evalu ating residues on crops and aquatic environments following application of Methyl Anthranilate at maximum label use rates for the respective use sites . Terrestrial Residues : Data from magnitude of the residue studies on apples, corn (sweet), and sunflow er, submitted in support of an Experimental Use Permit in 2000 (66550 - EUP 001 ; EPA, 2000 ) confirm the rapid dissipation of MA. Residues on whole apples treated with a single foliar application of MA at 2.29 lbs a.i./A declined from 1.79 ppm at 1 - hour posttreatment to <0.055 ppm (non - detectable) b y 14 day s posttreatment (MRID 45065105). Residues on sweet corn treated with a single foliar application of MA at 0.573 lbs a.i./A wereMethyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

5 1.65 ppm at 1 - hour posttreatment. Following a second treatment after a five - day application interval, residues were 0.374 ppm 10 - day s after the second application (MRID 45065103). Residues on sunflowers treated with a single foliar application of MA at 0.573 lbs a.i./A were 0.011 ppm at 1 - hour posttreatment. Following a second treatment after a five - day application interval, residues were 0.233 ppm 10 - day s after the second application (MRID 45065104). Avery et. al. (1995) reported residues on rice as 11.7 ppm immediately following an application of ReJex - ItAG - 36 (14.5% a.i.) at 6.2 lb a.i./A, which rapidl y declined over the next 14 day s with a half

- life of 7 day s (interpolated by reviewer based on study

author data). The application rate used in this study is equivalent to the maximum approved label application rate for food crops (see Appendix Table 1). The residue value reported by Avery et. al. (1995) was used to calculate Risk Quotients (RQs) for mammals and birds following terrestrial applications of meth yl Anthranilate at the maximum label used rate. Aquatic Residu es : Magnitude of the residue studies have been conducted for both direct application and fogging applications of Methyl Anthranilate products to aquatic sites. In a catfish toxicity

study (Dorr et. al. 1998), a 40% liquid MA end - use product (ReJex - iT A G 40; EPA Reg. No. 58035 - 7; not currentl y registered) was applied directly to the surface of an aquaculture pond at an exaggerated rate of 80 lb a.i./A water surface (10X the maximum label rate for currentl y registered products ). T he maximum concentration of MA was 4.44 ppm at a depth of 24 inches following seven applications over a two week period. If mathematicall y adjusted to a 1X rate, the calculated residues are estimated to be approximately **0.444 ppm** . A magnitude of the residue study (MRIDs 45210 201, 45210202, & 45229701) was conducted to determine the maximum amount of MA residues that would occur in a pond following fogging applications using two different ty pes of foggers (thermal and ultra low volume) and a product that is no longer registered for use (ReJex - iT TP - 40; EPA Reg. No. 58035 - 7; 40% a.i.) . The samples were not replicated which precluded statistical anal ys is and an ass essment of sample variability , and there were five anomalousl y high MA residue measurements (5.97 ppm to 60.47 ppm) that were well outside the range of the majority of samples (total = 26), which were in the range of <0.016 ppm to 1.6 ppm. In addition, the unusually high values were well outside the values reported b y Dorr et. al. (1998), following direct spray

applicat ion to pond. Therefore, these data are considered unreliable for purposes of non - target organism risk assessment. It was observed, however, that MA content of water samples generally

decreased with distance from the foggers . Fog application rates are an order of magnitude below that of direct spray applications (0.21 lb a.i/A vs. 8.0 lb a.i./A) . T he Tier I Rice Model equation (EPA, 2007 ) was used t o estimate environmental concentrations in water following a fog application at maximum label use rates ( 0.21 lbs a.i./A or 0.24 kg a.i./ HA) and assuming a K oc of 250 for MA (HSDB, 2004):Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

6

C w = m ai/(0.00105 + (0.00013 * Kd )) Where: C w = water concentration [ μg/L ]

m ai ' = mass applied per unit area [kg/ha] Kd = water - sediment partitioning coefficient [ L/k g] (and Kd = 0.01Koc ) Koc = organic carbon partitioning coefficient [L/kg] Then: Cw = 0.24/( 0.00105 + ( 0.00013 * 2.5)) = **0. 175**  **ppm** This value is less that the calculated EEC of 0.44 4 ppm (estimated using data from Dorr et. al., 199 8). The conservative **EEC of 0.444 ppm** will be used to evaluate risk to non - target aquatic organisms when Methyl Anthranilate is applied at the maximum label use rates . **6. Threatened and Endangered Species Assessment** A qualitative risk assessment c an be conducte d with acute and dietary mammal and avian toxicity data ; aquatic organism L C 50 and EC 50 data; and terrestrial plant and insect (honey bee) data from obtained from guideline studies, non - guideline studies, and the open technical literature (Appendix Table 2), in conjunction with the label use information for Meth yl Anthranilate f

ro m the product labels (Appendix Table 1) . Although none of the labels specified an y limitation on the number of applications , there is sufficient information to cond uct a qualitative endangered species risk assessment due to the minimal toxicity of Methyl Anthranilate to non - target species and its rapid biodegradation in the environment. Toxic endpoints were not found for mammals, birds, and terrestrial insects in laboratory testing (Appendix Table 2). Field testing on cherries, blueberries, grapes, and sweet corn demonstrated that >40000 ppm of methyl anthranilate was required to induce slight necrosis and desiccation of foliage (MRID 42740204). The product is c onsidered slightly toxic for five of six fish species tested (LD 50 range: 16.23 to 42.56 ppm) and moderately toxic (LD 50 = 9.12 ppm) to one fish species (Appendix Table 2). Mammals : Mammalian (rat) acute oral toxicity is >5000 mg/kg (Toxicity Catego ry IV ; Appendix Tabl e 2 ). The subchronic (90 - day) dietary No Observable Effects L evel (NOEL) was > 500 ppm (Appendix Table 2) . The non - definitive endpoints are respectivel y approximately

430X and 43X greater than the observed maximum environmental concentrations of 11.7 ppm for MA residues (Avery et. al., 1995) on terrestrial foliage. Based on the data and the Guidance for Using Non -Definitive Endpoints in Evaluating Risks to Listed and Non - listed Animal Species (EPA, 2010), there are no concerns for non - target mammals. Birds : Avian acute oral toxicity >2250 mg/kg (Practic all y Non - toxic; Appendix Table 2 ). avian d ietary

toxicity was >5620 ppm (Practicall y Non - toxic ; Appendix Table 2 ). The non definitive endpoints are respectivel y approximately 192X and 4 80 X greater than the observed maximum environmental concentrations of 11.7 ppm for MA residues (Avery et.Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

7 al., 1995) on terrestrial foliage. Based on the data and the Guidance for Using Non Definitive Endpoints in Evaluating Risks to Listed and Non - li sted Animal Species (EPA, 2010), there are no concerns for non - target birds. Fish : Freshwater fish 96 - hr LC 50 s ranged from 9.12 ppm to 42.56 ppm across five fish species, which are categorized as moderatel y toxic to slightly toxic (Appendix Table 2 ). Using the most conservative endpoint for fish in laboratory testing ( Bluegill sunfish; 9.12 ppm) and the measured calculated maximum E EC of MA in water (0.44 ppm) , the Risk Quotient ( RQ ) was calculated as:

RQ = 0. 44 ppm = 0.019

9.12 ppm Th e RQ is well below any Level of Concern ( LOC ) for non - target fish, including threatened and endangered species. Aquatic Invertebrates : Aquatic Invertebrate EC 50 s for daphnids ranged from 17.0 to 29.1 ppm which is categorized as moderatel y to slightly toxic (Appendix Table 2 ). Using the most conservative endpoint for aquatic invertebrates ( 17.0 ppm) in laboratory testing and the maximum estimated environmental concentration ( EEC ) of MA in water following a direct spray application to water ( 0.44 ppm), the RQ was calculated as: RQ = 0.44 ppm = 0.0 48

17.0 ppm The RQ is below an y LOC for non - target aquatic invertebrates , including threatened and endangered species. Plants : Methyl anthranilate is a naturally - occurring substance foun d in many plant species such as corn, sunflowers, grapes (33 ppm) and cherries (35 ppm ) . It is extremely volatile and degrades rapidl y into non - toxic components such as anthranilic acid. MA has no known toxic effects when applied exogenousl y to plants at the proposed rates of application. Reports of leaf desiccation in some studies were later attributed to the presence of certain surfactants in the end - use products and were not caused b y MA (Askham, 1992; MRID 42740204). In a field study using leaves o f blueberries, cherries, and grapes, it was demonstrated that n on - target terrestrial plants can tolerate >40,000 ppm of Methyl Anthranilate before exhibiting an y observable , but minor foliar desiccation or necrosis (MRID 42740204 ). Minor foliar desiccatio n or necrosis was observed at 80000 ppm , but no plant mortality

was reported (Askham, 1992; MRID 42740204). . Using the most conservative non - definitive endpoint for plants (40000 ppm) and the maximum observable residues on plants following a foliar sp ray application at the maximum label use rate (11.7 ppm; Avery et. al., 1995) , the RQ was calculated as:Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

8

RQ = 11.7 ppm = 0.002

40000 ppm The RQ is w ell below any L OC for non - target plants, including threatened and endangered species. Insects : N on - target insect contact toxicity L D 50 for insects (honey

bee) was > 25 ug/bee (see Appendix Table 2 ), which is categorized as practically non - toxic. No toxic effects were observed at the highest rate used in laboratory testing. Meth yl anthranilate is a naturall y occurring substance found in many plant species such as corn, sunflowers, grapes (33 ppm) and cherries (35 ppm) to which pollinators and other insects are exposed on a regular basis (EPA, 1994) . Endogneous levels of MA reported for grapes and cherries are higher than residues measured on foliage (11.7 ppm) following a single application of MA at maximum label use rates (Avery

et. al., 1995). Honey

made from citrus floral sources has been reported to contain from 3.60 to 5.04 mg/kg of MA (Ferreres et. a., 1994; White & Bry ant, 1996, unpublished study) indicating regualr dietary and contact exposure to naturally - occurring MA by pollinators . Based on these data, the Agency has no concerns to non - target insects. CONCLUSIONS: There are no concerns for an y non - target organism when Methyl Anthranilate is applied in accordance with EPA - approved product labeling. Based on the fact that Methyl Anthranilate has minimal toxicity to non - target organisms and on its use pattern and use instructions, EPA has determined that Meth yl Anthranilate will have "No Effect" on an y currentl y listed threatened or endangered species or an y designated critical habitat. REFERENCES Aronov, E. V. and L. Clark. 1996. Degradation studies of the non - leth al bird repellent, methyl anthranilate. Pesticide Science 47: 355 - 362. Askham, L . R. and J. K. Fellman. 1989. Use of DMA to reduce robin depredation on cherries. Proceedings of the Great Plains Wildlands Damage Control Workshop 9: 116 - 119. Askham , L . R. 1992. Efficacy of methyl anthranilate as a bird repellent on cherries, blueberries and grapes. Proceedings of the Fifteenth Vertebrate Pest Conference . J. E. Borrecco & R. E. Marsh, Eds. Published at University of California, Davis. 1992, pp. 137 - 141. Avery , M. L. 1989. Experimental evaluation of partial repellent treatment for reducing bird damage to crops. Journal of Applied Ecology 26: 433 - 439.Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

9 Avery , M. L., D. G. Decker, J. S. Humphrey , S. Aronov, S. D. L indscombe, and M. O. Way . 1995. Methyl anthranilate as a rice seed treatment to deter birds. Journal of Wildlife management 59(1): 50 - 56. Dorr, B., L. Clark, J. E. Glahn, I. Mezine. 1998. Evaluation of a methyl anthranilate - based bird repellent. Toxicity

to channel catfish Ictalurus punctatus and ef fect on Great Blue Heron Ardea h erodias feeding behavior. Journal of the World Aquaculture Society 29(4): 451 - 462. EPA. 1992 . Classification of Methyl Anthranilate (Chem. No. 128725 ) as a Conventional Chemical or as a Bioche mical Pesticide . Memorandum from J. T. McClintock to D. B. Peacock. EPA. 1994. SAB review of the product chemistry, toxicology , summary information, and toxicology

and residue chemistry

waivers submitted for the registration of technical methyl anthr anilate and an end - use product, “Bird Shield Repellent.” Product chemistry (Case# 008125; Chemical # 128725; Submission # S455617; DP barcode D197915). Memorandum from S. K. Reilly

to R. Forrest, dated 11/17/1994. EPA. 2000. Experimental use permit for Bird Shield Repellent (EPA Reg. No. 6550 - EUP 001) containing 26.4% methyl anthranilate as its active ingredient in or on corn sunflowers, and apples (chemical no. 128725): Evaluation of residue chemistry and analy

tical method. MRIDs 450651 - 01, - 02, - 03, - 04, and - 05; Case no. 066100; Submission no. S580610; DP barcode D266613. Memorandum from F. Toghrol to J. Downing, dated 08/16/2000. EPA. 2007. Guidance for Tier I Estimation of Aqueous Pesticide Concentrations in Rice Paddies. Memorandum fr om S. Bradbury to EFED/OPP, dated 05/08/2007. EPA. 2010. Guidance for Using Non - Definitive Endpoints in Evaluating Risks to L isted and Non - listed Animal Species. Memorandum from D. J. Brady (Director, Environmental Fate and Effects Division) to Envir onmental Fate and Effects Division Scientists, dated 08/03/2010. Ferreres, F., J. M. Giner, and F. A. Tomas - Barberan. 1994. A comparative study of hesperetin and methyl anthranilate as markers of floral origin of citrus honey . Journal of the Science of Food and Agricultural Science 65(3): 371 - 372. Harpaz, S. and L. Clark. 2006. Effects of addition of a bird repellent to fish diets on their growth and bioaccumulation. Aquaculture Research 37: 132 - 138. Hazardous Substances Data Base (HSDB). 2 004. National L ibrary of Medicine/TOXNET (05/25/2004 update). http://toxnet.nlm.nih.gov/cgi - bin/sis/search/a?dbs+hsdb:@term+@DOCNO+1008Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

10 Kirifides, M. L., M. P. Kur nellas, L. Clark, and B. P. Bryant. Calcium responses of chicken trigeminal nerve ganglion neurons to methyl anthranilate and capsaicin. Journal of Experimental Biology

207: 715 - 722. White, J. W. and V. M. Bry ant 1996. Assessing citrus honey quality: Pollen and methyl anthranilate content. (Unpublished study). http://www.honey .com/white/pdf/white199 - assessing - citrus - honey - quality .pdf

cc: C. Pfeifer , R.S. Jones, BPPD Subject File/IHAD R. S. Jones, Ph.D., Sr. Scientist, FT, OPY: 0 8 /24 /2011Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

11 **APPENDIX Appendix**  **Table 1.**  **Currently registered**  **products and**  **maximum label**  **use rates**  **for each product label. Highest use rates are boldfaced.**  **Product EPA**  **Reg. N**  **o. Methyl**  **Anthranilate Percentage**  **Maximum Use Rate per Acre** 

**per Application Application**  **Intervals** Avian Control TM 33162 - 1 20 .00 % **Ground: 8 lb a.i**  **. /A surface water**  **1** 1 - 4 days Fog: 0.21 lbs a.i. /A 2 1 - 4 days ReJex - It Fog Force TM 58037 - 7 40 .00 % **Ground: 8 lb a.i .**  **/A surface water 1**  1 - 4 days Outdoor Fog: 0.21 lbs a.i. /A 2 , 3 1 - 4 days ReJex - It AG - 36 TM 58035 - 9 14.50% **Ground: 6.**  **18 lb a.i**  **. /A**  **4** Not specified **Aerial: 6.**  **18 lb a.i**  **. /A**  **5** Not specified **Aerial: 6.**  **18 lb a.i**  **. /** **A 6**  22 days Ground: 0.07 lb a.i./A 7 4 days ReJex - It Fog Force AR - 20 TM 58035 - 15 20.00% Outdoor Fog: 0.21 lb a.i. /A 2, 7 1 - 4 days Bird Shield Repellent 66550 - 1 20.00% **Ground/aerial: 0.28 –**  **5.73 lb a.i./A 8**  Not specified Aerial: 0.28 lb a.i./A 9 Not specified Ground: 2.29 lb a.i./A 10 Not specified **Ground: 4.58 lb a.i./A**  **7** 7

– 14 days Ground: 0.07 lb a.i./gal Spot spray Ground : 0.12 lbs a.i./gal 1 Added to pool Liquid Fence Goose Repellent 72041 - 2 20.7 2% Ground: 0.5 gal/40K sq ft 7 Not specified Avex 83359 - 4 26.40% Ground/aerial: 5.73 lb a.i./A 8 Not specified Aerial: 0.28 lb a.i./A 9 Not specified Ground: 2.29 lb a.i./A 10 Not specified Ground: 2.29

– 4.58 lb a.i./A 7 7

– 14 day s Ground: 0.07 lb a.i. /gal Spot spray Ground: 0.12 lbs a.i. / gal 1 Added to pool 1 Ground application to landfills, tailing ponds, commercial/industrial water impoundments, tem porary pools, decorative fountains, non - fish bearing waters. 2 Electr ical substations, farmsteads, agricultural sites, structures, buildings, airports & other open areas; ornamental trees & shrubs; turf; lakes, ponds, harbors, boat docks, aquatic production sites (non - fish bearing waters such a s hatcheries and culture ponds ) 3 Tree fruits & cereal grains 4 Apples, stonefruits, blueberries, & grapes 5 Cereal Grains 6 Sunflow ers 7 Turf 8 Pom e fruit, stone fruit 9 Sunflow er, blueberries 10 Table grapesMethyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

12 **Appendix Table 2. Summary of Non**  **- Target Organism Data**  **Study Type /OCSPP G**  **uideline LD**  **50 /LC**  **50 /** **EC 50**  **Results Toxicity** 

**Category MRID**  Ac ute Oral Toxicity / OCSPP 870.1100 >5000 mg/kg (rat) Tox Category IV 42608702 90 - day Feeding (rat) / OCSPP 870. >500 mg/kg/day No effects on growth or survival 42151904 Avian Acute Oral T oxicity / OCSPP 850.2100 >2036 ppm (Bobwhite quail) Practically non - toxic 42966902 >2250 ppm (Bobwhite quail) Practically non - toxic 43610701 Avian Dietary Toxicity / OCSPP 850. >5620 ppm (Mallard duck) Practically non - toxic 42608808 >2200 (White crow

ned sparrow) Practically non - toxic 42966903 >5259 ppm (Mallard duck) Practically non - toxic 44741501 Freshwater Fish Acute Toxicity, 96 hr / OCSPP 850.1075 9.12 ppm 1, 2 (Bluegill sunfish) Moderately toxic 42718202 42.56 ppm NOEC = 33.6 ppm (b luegill) Slightly toxic 43610702 22.91 ppm 1 (Rainbow trout) Slightly toxic 42966901 25.40 ppm 2 (Rainbow trout) Slightly toxic 43610703 16.23 ppm 1 (Channel catfish) Slightly toxic 42699803 32.25 ppm 1 (Atlantic salmon) Slightly toxic 42995101 F reshwater Fish Dietary Toxicity, 12 - hr /Non - Guideline > 1000 mg/kg (striped bass & African cichlid) No effects on growth or survival Harpaz &

Clark, 2006 Aquatic Freshwater Invertebrate Toxicity, 48 - hr / OCSPP 850.1010 17.0 mg/L Slightly toxic 418952 07 29.1 mg/L Slightly toxic 42718203 Non - target Plants >40000 ppm on blueberries, cherries, grapes, and raspberries 3 Practically non - toxic 42740204 Non - target Insects (Honey Bee Contact Toxicity, >25 ng/bee Practically non - toxic 41623704Methyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

13 **Study Type /OCSPP G**  **uideline LD**  **50 /LC**  **50 /** **EC 50**  **Results Toxicity** 

**Category MRID**  48 - hr)/ OCSPP 850.3020 1 Static conditions 2 Flow - through conditions 3 Based on visual observations of foliar necrosis/ desiccationMethyl Anthranilate

PC Code: 128725 Non - Target Organism Hazard Assessment and Endangered Species Screening Risk Assessment for Registratio n Revie w Preliminary Work Plan

14 **Appendix Table 3. Maximum N**  **- 6**  **- BA residues following a single application, or two**  **consecutive applications at the maximum label use rates.**  **1 Environmental Matrix**  **Residues (ppm** **) following single**  **application at 0.039lb**  **a.i./A 2**  **Residues (ppm** **)**

**following two applications at 0.041 lb**  **a.i./A with a 3 -**  **day interval**  **3 Residues**  **(ppm )** 

**following two applications at 0.165**  **lb a.i./A with a 7**  **- day**  **interval 3**  **Short Grass Tall Grass**  **Broadleaf Plants/Small Insects Fruits/Pods/Seedlings/Large**  **insects** 1 Dietary - based Estimated Environmental Concentration (EEC) calculated using T - REX model (EPA, 2005). 2 Prom alin Plant Growth Reg ulator (EPA Reg. No. 73049 - 1) 3 Riteway (EPA Reg. No. 71368 - 60) **Appendix Table 4. Maximum N**  **- 6**  **- BA residues in aquatic environments following a**  **single application, or two consecutive airblast**  **applications at the maximum label use rates (airblast/orchard a**  **pplication method). 1**  **Environmental Matrix Residues**  **(pp b**  **) following single**  **application at 0.039lb**  **a.i./A 2**  **Residues (pp**  **b )** 

**following two applications at 0.041 lb**  **a.i./A with a 3 -**  **day interval**  **3 Residues**  **(pp b**  **)**

**following two applications at 0.165**  **lb a.i./ A with a 7**  **- day**  **interval 3**  **Peak GEEC Maximum 4**  **- Day Avg. GEEC**  **Maximum 21 -**  **Day Avg. GEEC Maximum 60**  **- Day Avg. GEEC**  **Maximum 90 -**  **Day Avg. GEEC** 1 Estimated Environmental Concentration (EEC) calculated using GENEEC2 model (EPA, 2001). 2 Prom al in Plant Growth Regulator (EPA Reg. No. 73049 - 1) 3 Riteway (EPA Reg. No. 71368 - 60)