- -

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

OFFICE OF

CHEMICAL SAFETY AND

POLLUTION PREVENTION

PC Code: 084301

DP Barcode: 399720

May 15,2012

MEMORANDUM

SUBJECT:

TO:

FROM:

THRU:

The Environmental Fate and Effects Division Response to Comments Posted to

the Registration Review Docket for Benfluralin; Docket ID EPA-HQ-OPP-2011-

0931.

Garland Waleko

Chemical Review Manager

Pesticide Re-evaluation Division (7507P)

FrankT.Farruggia,Ph.D.,BiOlOgi~ it,tL S?S-/ib/ZJames Hetrick, Ph.D., Senior Scie~~ u·~,;{ J-;jJ //2-

Environmental Risk Branch 3 / t

Environmental Fate and Effects Division (7507P)

Dana Spatz, Branch Chie~....... .... ~/l y I~t "-

Environmental Risk Bran~~~ Environmental Fate and Effects Division (7507P)

This document contains the Environmental Fate and Effects Division's (EFED's) response to

comments on the Benfluralin Problem Formulation (Docket ID EPA-HQ-OPP-2011-0931).

COMMENT SOURCE: PCRM

PCRM COMMENT: It appears some passerine data may be available to fulfill the Avian Acute

Oral Toxicity requirement in the document titled Pesticide Acute Toxicity Reference Valuesfor

Birds published in Reviews ofEnvironmental Contamination and Toxicology. However, ifthis is

not sufficient we recommend that OECD Test Guideline 223, Avian Acute Oral Toxicity Test, be

used as the protocol instead ofEPA Guideline 850.2100 in the interest ofreducing the numbers

ofanimals used by up to 61%ii. We also refer the registrant to the "Guidance for Classifying

Studies Conducted Using the OECD Test Guideline 223 (FG223) (Acute Avian Oral Sequential

Dose Study)" available on the Agency's website.
2

EFED RESPONSE: EFED will consider the available toxicity data for benfluralin and 

passerines. The Terrestrial Biology Technical Team (TBTT) in the Environmental Fate and 

Effects Division (EFED) has completed its evaluation of the Organization for Economic Co -

operation and Development (OECD) Acute Avian Oral Sequential Dose Study Guideline 

(TG223). Based on their analyses, the TBTT determined that TG223 performed generally as 

well as 850.2100 regarding information on the LD50 value, slope, and observation of sublethal 

effects (with some caveats). It was determined that a study conducted using TG223 may be 

classified as ‘acceptable’ (i.e., adequate for use in risk assessment and fulfills a data requirement 

for avian acute oral toxicity data) if it is scientifically valid, is conducted using the ‘LD50 – slope 

test’ or ‘limit dose test’ guidelines (the ‘LD50 – only test’ is not adequate for fulfilling data 

requirements), and it meets certain criteria, for example:

• The study is conducted using bobwhite quail [other test species may be acceptable if they 

have low background mortality (≤1%) in the laboratory and do not regurgitate during the 

study]. 

• The chemical being tested does not cause delayed effects. 

• For a ‘limit dose test’, it is conducted at 2,000 mg a.i./kg-bw or the environmentally 

relevant concentration (whichever is greater). 

• The study meets the same validity requirements as 850.2100 (e.g., a study should be 

invalidated if >10% of the controls die). 

• Control birds are not added during the course of the study. 

Studies that deviate from the above criteria may be classified as ‘acceptable’ or ‘supplemental’ if 

they are considered adequate for use in risk assessment or ‘invalid’ if they are not scientifically 

sound; however, consultation with the TBTT will need to confirm the classification for any 

TG223 study that deviates from the above criteria. 
3

COMMENT SOURCE: DOW AGROSCIENCES' RESPONSE TO US EPA'S 

BENFLURALIN REGISTRATION REVIEW DOCKET (EPA-HQ-OPP2011-0931) 

DAS COMMENT(1): The Agency states on page 7 of 103: 

"Benfluralin is applied as band treatment, broadcast, golf course treatment... soil incorporated 

treatment, and spray with ground or sprinkler irrigation systems. " 

Benfluralin products are not applied by ground or sprinkler irrigation systems. The only 

benfuralin product intended for application mixed with water is Balan DF. This product 

label includes the specific prohibition: "Do not apply BALAN DF through any type of 

irrigation system." All other bent1uralin containing products are solid, granule products and 

cannot be mixed in water for application. 

EFED RESPONSE (1): EFED defers questions about use or usage to the Biological and 

Economic Analysis Division. 

DAS COMMENT(2): The Agency states on page 7 of 103: 

"All uses allow for ground and aerial applications.... " 

Benfluralin products are not applied by aerial application. The only benf1uralin product 

intended for application mixed with water is Balan OF. This product label includes the 

specific statement: "Spray Drift: Apply with nozzle height no more than 2 feet above the 

ground. Use hooded sprayer to direct spray toward the soil when wind speed is 10 mph or 

more at the application site. Use standard nozzles and apply as a medium or coarser spray 

(according to ASAE standard 572)." This statement precludes aerial application. All other 

benfluralin containing products are solid, granule products with a low concentration of 

benfluralin. These products are not conducive to aerial application nor are they applied in that 

manner. 

EFED RESPONSE (2): EFED defers questions about use or usage to the Biological and 

Economic Analysis Division. 

DAS COMMENT(3): The Agency states on pp. 8, 44, 51, 64, and 65 of 103: 

Table 3.1 summarizes the benfluralin uses considered in Registration Review. Specifically, the 

site characterization entries include: Christmas tree plantations, turf; and non-agricultural rights 

of way/ industrial. 

DAS disagrees with the Maximum Annual Rate or the Maximum Single Rate identified for 

Christmas Tree Plantations and Non Agricultural Rights of Way/Industrial site 

characterization in this table. In the Benfluralin RED, EPA requires that all product labels be 

amended to be eligible for re-registration. (U.S. EPA 2004) A maximum of 2 pounds active 

ingredient per acre per application, maximum of 2 applications per year, and a maximum of 4 

pounds active ingredient per acre per year were required for Christmas Tree Plantations and 

Non-Agricultural Rights of Way/Industrial sites. Additionally, Ornamental Sod Farm (Turf) was 

not a specific use pattern that was supported through the re-registration process. DAS requests 
4

that this table be amended to reflect the 2004 Benfluralin RED. 

EFED RESPONSE (3): EFED defers questions about use or usage to the Biological and 

Economic Analysis Division. 

DAS COMMENT(4): The Agency further states: Appendix A is related to Table 3.1 and 

describes formulations and uses for benfluralin. Specifically, the site description entries include: 

Christmas tree plantations, industrial/ construction areas (outdoor), non-agricultural rights of 

way/fencerows/ hedgerows, etc., and ornamental sodfarm (turf). (pp.44, 51, 64-65)

DAS agrees with the Agency summary in Appendix A and notes the following exceptions: 

Site Description: Christmas Tree Plantations - The Oryzalin 2G product entry describes a 4lb 

a.i./A maximum application rate. However, the Benfluralin RED required that the use rate on 

this site be reduced to 2 lbs a.i./A. DAS recommends for the Agency to work with this registrant 

to update this use pattern. Furthermore, DAS recommends that this 41b/A use rate not be 

included in any risk assessment. Site Desciption: Industrial Construction Areas (Outdoor) - The 

Oryzalin 2G product entry describes a 6 lb a.i./A maximum application rate. However, the 

Benfluralin RED required that the use rate on this site be reduced to 2 lbs a.i./A (U.S. EPA 

2004). DAS recommends for the Agency to work with this registrant to update this use pattern. 

Furthermore, DAS recommends that this 6 1b a.i./A use rate not be included in any risk 

assessment. Site Description: Non-Agricultural Rights-of-Way/ Fencerows/ Hedgerows, etc.- 

The Oryzalin 2G product entry describes a 6 lb a.i./A maximum application rate. 

However, the Benfluralin RED required that the use rate on these sites be reduced to 2 lbs 

a.i./A (U.S. EPA 2004). DAS recommends for the Agency to work with this registrant to update 

this use pattern. Furthermore, DAS recommends that this 6 1b a.i./A use rate not be included in 

any risk assessment. Site Desciption: Ornamental Sod Farm (Turf) Sod was not a specific use 

pattern that was supported through the re-registration process which culminated in the issuance 

of the Benfluralin RED (U.S. EPA 2004). However, three end use products continue to include 

this sod use pattern: Fertilizer with Starteem ® #1 (EPA Reg. No. 52287-10), Fertilizer with 

Starteem ® #2 (EPA Reg. No. 52287-11), and Fertilizer with Starteem ® #3 (EPA Reg. No. 

52287-12). DAS recommends for the Agency to work with this registrant to update this use 

pattern. DAS further recommends that this use pattern should not be included in any risk 

assessment. 

EFED COMMENT(4): EFED defers questions about use or usage to the Biological and 

Economic Analysis Division. 

DAS COMMENT(5): DAS: GLN 850.1010 - Acute Toxicity Freshwater Invertebrates Study 

To address this guideline requirement, DAS submitted the study by Hertl et al.(2003) on 

February 12, 2007. According to our records, the EPA evaluation is still pending. 

EFED RESPONSE(5): This study by Hertl et al. (2003; MRID 47055203) was 

determined to be invalid because the measurements of the dissolved chemical were not 

provided, and the exposure of the organism to the test chemical could not be determined. 

This study (GLN 850.1010) is still needed. 
5

DAS COMMENT(6): DAS: GLN 850.1025 - Oyster Acute Toxicity Test (Shell Disposition) 

For the oyster acute toxicity test, DAS disagrees with its inclusion in the data gap summary. 

Although the study by Hicks (2007) has been previously classified as "supplemental" primarily 

on the grounds that a specific endpoint has not been identified, DAS believes that this study is of 

the highest scientific standard and that a repeat study is unlikely to provide the Agency with any 

useful additional information. Due to the limited solubility of benfluralin in seawater, 50 ug/L 

was the highest exposure level achievable under flow-through conditions. Measured exposure 

levels, although lower than target due to adsorption losses, remained essentially constant during 

the study. All samples were centrifuged prior to analysis and therefore 50 μg/L reflects the 

maximum functional solubility of benfluralin in seawater. No statistically significant adverse 

effects on shell growth occurred at this level. In view of this finding, DAS would propose that a 

repeat study is considered unnecessary since it would likely only re-confirm that a specific 

endpoint for inhibition of shell growth is not achievable for benfluralin. Additionally, DAS 

recommends for the assessment as a data gap for the oyster acute toxicity test (shell disposition) 

to be reconsidered. 

EFED RESPONSE(6): This study (MRID 47269801) is scientifically sound but does not 

satisfy the guideline requirement for an acute estuarine mollusk toxicity study because a 

definitive endpoint (the IC50) could not be calculated from the study. Deviations from 

study guidelines contributed to the lack of sufficient data to assess risk to these organisms: 

1. A definitive endpoint (the IC50) could not be calculated from the study. 

2. The acclimation period (2 days) was much shorter than the OCSPP 

recommendations of 12-15 days. The oysters were acclimated to the test 

temperature at least 2 days before use. 

3. The TOC of the dilution water was not reported. 

4. The study author reported that each treatment tank received ca. 10 mL of a 

diluted marine microalgal concentrate shellfish diet with each diluter cycle, 

and that additional marine microalgal concentrate was added manually (5 mL 

was added 2-3 times each day during exposure); OCSPP guidelines suggest 

that cultured algae be added to the dilution water sparingly, and as necessary 

to support life and growth without affecting the test results. 

EFED believes that a well designed flow-through study would reduce the fluctuations of 

dissolved benfluralin to be within the OCSPP guidelines. This study (GLN 850.1025) is 

still needed. 

DAS COMMENT(7): DAS: GLN 850.1075 - Fish Acute Toxicity Test (Bluegill, Rainbow 

Trout) DAS agrees to provide this study for benfluralin with the bluegill sunfish, Lepomis 

macrochirus, to upgrade the registration package and address these guidelines. DAS looks 

forward to discussion of the timeline for the conduct and submission of this study. To address the 

guideline requirement for the rainbow trout, DAS submitted the study by Hertl et al. (2003) on 

February 12, 2007. According to our records, the EPA evaluation is still pending. 

EFED RESPONSE(7): EPA looks forward to the receipt of the bluegill study. 

Regarding, Hertl et al. (2003; MRID 47055202), this study was determined to be invalid 
6

because the measurements of the dissolved chemical were not provided, and the exposure 

of the organism to the test chemical could not be determined. 

DAS COMMENT(8): DAS: GLN 850.1300 - Aquatic Invertebrate Life Cycle (Freshwater) 

DAS agrees to provide this study for benfluralin to upgrade the registration package and address 

these guidelines. DAS looks forward to discussion of the timeline for the conduct and submission 

of this study. 

EFED RESPONSE(8): EPA looks forward to the receipt of this study. 

DAS COMMENT(9): DAS: GLN 850.1500 - Fish Life Cycle 

DAS submitted the study by Marino et al. 2011 on 10/28/2011 to add to the understanding of the 

chronic effects of benfluralin TGAI on fish. The study was conducted as a 21-day flowthrough 

study on the fathead minnow, Pimephales promelas, and was conducted according to US and 

OECD guidelines for a Fish Short-term Reproduction Assay (OPPTS 890.1350; OECD 2009). 

According to our records, the EPA evaluation is still pending. Although not a full life-cycle 

study, its findings taken together with data from the "core" Early Life Stage study by Cocke 

(1990) are considered sufficient to provide realistic and meaningful data for the evaluation of 

the chronic effects on fish resulting from exposure to a substance of low persistence in the 

aquatic environment. 

EFED RESPONSE(9): EFED will consider this request and provide feedback prior to 

the issuance of a DCI.

DAS COMMENT(10): DAS: GLN 850.2100 - Avian Acute Oral Toxicity Test (Passerine 

Species) DAS agrees to provide this study for benfluralin to upgrade the registration package 

and address these guidelines. DAS looks forward to discussion of the timeline for the conduct 

and submission of these studies. 

EFED RESPONSE(10): EPA looks forward to the receipt of this study. 

DAS COMMENT(11): DAS: GLN 850.2300 - Avian Reproduction Test (Bobwhite Quail) For 

the avian reproduction test, DAS disagrees with its inclusion in the data gap summary. A study 

by Frey et al. (2008) was submitted on February 11, 2008 to the Agency to satisfy this data 

requirement. A subsequent rebuttal to the Agency decision regarding that study by Hudson 

(2010) was submitted to the EPA on August 24, 2010. According to our records, the EPA 

evaluation is still pending. 

EFED RESPONSE(11): EFED has reviewed the Hudson (2010; MRID 48204501) 

rebuttal to the classification of Frey et al. (2008). The study, Frey et al. Benfluralin: A 

Reproduction Study with the Northern Bobwhite - Final Report (MRID 47346601) was 

determined to be scientifically unsound because the control mortality was 12.5% during 

the study, while no more than 10% is acceptable in controls. The high mortalities and 

type of mortalities indicate high levels of stress on the test organisms making the results 

difficult to interpret. Thus, there still remains uncertainty with regard to avian 

reproductive effects. 
7

DAS COMMENT(12): DAS: GLN 850.4100 - Seedling Emergence Terrestrial Plant Toxicity 

Test, Tier II. For the seedling emergence terrestrial plant toxicity test tier II, DAS disagrees with 

its inclusion in the data gap summary. A study by Rockliff was submitted on November 21, 2011 

to the Agency to satisfy this data requirement. According to our records, the EPA evaluation is 

still pending. 

EFED RESPONSE(12): EPA will review this submitted study and consider it for 

adequacy of its use in the risk assessment prior to the issuance of a DCI. 

DAS COMMENT(13): DAS: GLN 850.4200 - Vegetative Vigor Terrestrial Plant Toxicity Test, 

Tier II.For the vegetative vigor terrestrial plant toxicity test tier II, DAS disagrees with its 

inclusion in the data gap summary. A study by Rockliff was submitted on November 21, 2011 to 

the Agency to satisfy this data requirement. According to our records, the EPA evaluation is still 

pending. 

EFED RESPONSE(13): EPA will review this submitted study and consider it for 

adequacy of its use in the risk assessment prior to the issuance of a DCI. 

DAS COMMENT(14): DAS: GLN 850.5400 - Aquatic Plant Growth Tier II Study (NonVascular Aquatic Plants). For the aquatic plant growth Tier II study with non-vascular aquatic 

plants, DAS disagrees with its inclusion in the data gap summary. The studies by Hancock et al. 

on Navicula (2007a) and Skeletonema (2007b) have been previously classified as 

"supplemental" on the grounds that"...measured concentrations were below LOQ for all times 

and treatment groups thus it is not possible to obtain suitable endpoints from the study." 

(EPAHQ-OPP-2011-0931-0003) In fact, the measured concentrations for all treatment groups in 

both studies were above the LOQ and close to nominal on study initiation. Measured levels only 

fell below LOQ on study termination, as would be expected for a substance such as benfluralin 

that is rapidly degraded in light. Since algal growth studies, by necessity, must be conducted 

under conditions of high light intensity, this is an unavoidable feature of the study and should not 

be taken to invalidate the results. All samples were centrifuged prior to analysis and therefore 

represent true bioavailable concentrations of benf1uralin in the exposure media. DAS believes 

that these studies are of the highest scientific standard and would propose that a repeat study is 

considered unnecessary. Additionally, DAS recommends for the assessment as a data gap for the 

aquatic plant growth Tier II study with non-vascular aquatic plants to be reconsidered. 

Furthermore, an equivalent study on Anahaena flos-aquae, conducted by Hertl et al. [28] was 

submitted to EPA on February 12,2007. According to our records, the EPA evaluation is still 

pending. 

EFED RESPONSE(14): In Hancock et al (2007a) nominal concentrations were 0 

(negative and solvent controls), 0.00406, 0.00813, 0.0163, 0.0325 and 0.0650 mg ai/L 

under static conditions; initial measured concentrations were <0.000390 (<LOQ; 

controls), 0.00381, 0.00763, 0.0145, 0.0305 and 0.0622 mg a.i./L. The authors report 

measurements of concentrations at the 24, 48, 72 and 96 hr times below the LOQ. 

Therefore, there was <24-hr exposure to benfluralin technical in this study. 
8

In Hancock et al. (2007b) nominal concentrations were 0 (negative and solvent controls), 

0.00166, 0.00416, 0.0104, 0.0260 and 0.0650 mg a.i./L under static conditions; initial 

measured concentrations were <0.000159 (<LOQ; controls), 0.00168, 0.00448, 0.0107, 

0.0250 and 0.0550 mg ai/L. The authors report measurements of concentrations at the 24, 

48, 72 and 96 hr times below the LOQ. Therefore, there was <24-hr exposure to 

benfluralin technical in this study. 

The study Hertl et al. Toxicity of Benfluralin Technical to Anabaena flos-aquae in an 

Algal Growth Inhibition Test. Study ill: 13064210, 2003 (MRID 47055203) was 

determined to be scientifically unsound and was classified as Invalid. 

• The solubility of the test compound in water is 0.065 mg/L, Concentrations of the test 

solutions were not measured for the dissolved concentration so actual exposure of 

Anabaena to the dissolved test material is unknown. 

• The percent growth inhibition, based on cell density, in the treated algal culture as 

compared to the control ranged from -7.9% to 12.2%; however, no clear dosedependent response was observed. 

• This study was only conducted for 72 hours, instead of the recommended 96-120 

hours for an algal study. According to a US EPA memo (October 21, 1994) entitled, 

“Closure on Nontarget Plant Phytotoxicity Policy Issues”, three-day OECD studies 

will be accepted for review as Tier I screening studies only. 

• There were no compound-related phytotoxic effects observed, however, with a test 

lasting 96-120 hours, the variability in the growth rates across the test concentrations 

may reveal reduced growth rates across the test samples. 

• Furthermore, the inclusion of the emulsifier Methyl-Cellulose, likely interferes with 

the chemical properties of the test chemical, potentially reducing the actual exposure 

of the alga to the test chemical. 

• Measurements of the dissolved test chemical were not provided, and thus Anabaena

exposure to the test chemical could not be assessed. 

These studies (GLN 850.5400) are still needed. The data will reduce uncertainties 

associated with the current risk assessment for plants and will improve our understanding 

of the potential effects of benfluralin use on aquatic plants. Because aquatic plants form 

the basis of many habitats and significantly contribute to overall environmental quality, a 

solid understanding of the potential risks to aquatic plants is essential for sound 

environmental management. The data will also be used in determining whether a “may 

affect” to Federally-listed threatened and endangered species is likely under the 

Endangered Species Act. 

DAS COMMENT(15): DAS: 40 CFR Part 158 (USEPA, 2007a) - Whole Sediment chronic 

Invertebrates, Freshwater and Marine - In response to this data requirement, DAS will be 

submitting the following study: Memmert, U. Effects of Benfluralin Technical on the 

Development of Sediment-Dwelling Larvae of Chironomus riparius in a Water-Sediment System. 

Study ID: 842140, 2003. 

EFED RESPONSE (15): EPA looks forward to the receipt of this study and will 

consider it for adequacy of its use in the risk assessment. 
9

DAS COMMENT(16): DAS: The Agency states on page 27 of 103: 

The conceptual model for benfluralin effects on aquatic organisms is described in Figure 6.1. 

: 

In the Conceptual Model which depicts multiple source inputs to the exposure media, several 

key factors need to be considered in this scheme. Spray Drift Input For significant uses - 

benfluralin is formulated as a granule. Within the Conceptual Model, spray drift could be 

considered a minor route of exposure for these formulation types. Runoff Input - There are major 

uses of benf1uralin either by soil incorporation or application to turf. Runoff is significantly 

reduced by soil incorporation since the compound is no longer on the soil surface and thereby 

unavailable for runoff. Furthermore, turf uses would mitigate runoff since the turf thatch 

structure significantly reduces runoff. Within the Conceptual Model, runoff could be considered 

a minor route of exposure for these two uses. Leaching to Groundwater Input - As the sorption 

Koc value is so high, mobility in soil is considered a low risk for benf1uralin. Therefore leaching 

to groundwater could be considered a minor route of exposure within the Conceptual Model. 

Atmospheric Transport Input. - Although dissipation to air is seen for benfluralin, the 

photodegradation half-life is very short. In air, benf1uralin has a calculated photochemical 

oxidative degradation half-life of 5.8 hours and therefore significant amounts of benfluralin are 

not expected to be present in air. Therefore atmospheric transport could be considered a minor 

route of exposure within the Conceptual Model. 

EFED RESPONSE (16): Because EPA is required to assess all current uses, EFED 

considers all possible pathways leading to exposure, including minor pathways. As 

stated in the DAS comments, there is one currently registered benfluralin product that can 

be applied as a liquid (i.e., Balan DF); therefore, spray drift is a potential route of 

exposure for this product. However, as an example, if runoff is expected to be low and 

RQs based on runoff exposure are exceeding the LOC then the chemical review team will 

further consider the probability of the exposures occurring due to the chemical properties 

and use pattern. Although some pathways may lead to higher exposures than others, all 

pathways in the conceptual model are still relevant potential exposures and will be 

considered in the risk assessment. 

DAS COMMENT(17): The Agency States on Page 37 of 103: 

"EFED recommends that the Pesticide Re-evaluation Division (PRD) request submission of a 

passerine study protocol for review by the Agency prior to initiation of this study." 

DAS Comment:DAS agrees to provide this study protocol for benfluralin in an effort to upgrade 

the registration package and address these guidelines. DAS looks forward to discussion of the 

timeline for the conduct and submission of this protocol. 

EFED RESPONSE(17): EPA looks forward to the receipt of this study protocol. 
10

DAS COMMENT (18):“ Parameter: Aerobic Aquatic Metabolism Half-life (20o

C)

The value entry indicates that no data is available. However, an aquatic degradation study is 

available (Knoch and Heim, 2002). This study was conducted to meet EU German requirements 

(BBA Guideline Part IV, Section 5-1). The study shows that Benfluralin dissipates from the 

water sediment systems with a DT50 value between 1.1 and 1.3 days (mean 1.2 days). So when 

applied directly to the water layer of the water/sediment system to mimic entry into aquatic 

systems via spray drift, benfluralin was either rapidly volatilized or dissipated to the sediment 

layer with an overall DT50 value of ca 1.2 days.” 

EFED RESPONSE(18): EPA is willing to evaluate any data to address this uncertainty, 

and would appreciate the submission of this study for consideration in the risk 

assessment. 

DAS COMMENT (19): “GLN 835.1410-Laboratory Volatility.

The Agency states on pages 5 of 19 in the document Benfluralin Summary Document that this 

data requirement is “Non-Guideline.” In response to this data requirement, DAS will be 

submitting a recent study by Knoch and Heim [15].” 

EFED RESPONSE(19): EPA looks forward to the receipt of this study and will consider 

it for use in the risk assessment. 

DAS COMMENT (20): Table 3.7 is mislabeled. It should read as Benfluralin Concentrations 

in NAWQA Ground Water Monitoring. 

EFED RESPONSE (20): EPA will correct the table heading if it is used in the risk 

assessment conducted for benfluralin.. 

 
11

Literature Cited: 

MRID 41613805. Cocke, P., et al. 1990. The Toxicity of Benefin to Rainbow Trout (Salmo 

gairdneri) in a 49-Day Early Life-Stage Study. 

MRID 47346601. Frey, L.T., et al.2008. Benfluralin: A Reproduction Study with the NOlthern 

Bobwhite - Final Report. 

MRID 47247301. Hancock, G.A., et al. 2007a. Bentluralin TGAI: Growth Inhibition Test with 

the Freshwater Diatom, Navicula pelliculosa.

MRID 47247302. Hancock, G.A., et al. 2007b. Benfluralin TGAI: Growth Inhibition Test with 

the Saltwater Diatom, Skeletonema costatum.

MRID 47055201. Hertl, J., et al. 2003. Acute Toxicity of Benfluralin Technical to Daphnia 

magna in a 48-Hour Immobilization Test.

MRID 47055202. Hertl, J. et al. 2003. Acute Toxicity of Benfluralin Technical to Rainbow 

Trout (Oncorhynchus mykiss) in a 96-Hour Static Test. 

MRID 47055203. Hertl et al. 2003. Toxicity of Benfluralin Technical to Anabaenaflos-aquae in 

an Algal Growth Inhibition Test. 

MRID 47269801. Hicks, S.L. 2007. Benfluralin: Effect on New Shell Growth of the Eastern 

Oyster (Crassostrea virginica).

MRID 48204501. Hudson, A. 2010. Response to Wagman and Bailey DER of December 

28,2009 (DP Barcode: 352.183); Benfluralin: A Reproduction Study with the Northern 

Bobwhite. (2010): (EPA MRill: 47346601). 

Knoch, E., and Heim, L.G. 2002. Aerobic Aquatic Degradation of Benfluralin According to 

BBA Guideline Part IV, Section 5-1. 

MRID 48614906. Marino, T. et al. 2011. Benefin: A Fish Short-Term Reproduction Assay 

Using the Fathead Minnow, Pimephales promelas.

U.S. Environmental Protection Agency. 2004. Reregistration Eligibility Decision (RED) 

for Benfluralin, Office of Prevention, Pesticides, and Toxic Substances, Washington, D.C. 

EPA 738-R-04-012. July 2004, pp. 74-75.