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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

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# J-;j J //2-

Environmental Risk Branch 3 / t
Environmental Fate and Effects Division (7507P)

Dana Spatz, Branch

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### 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 Values for

Birds published in Reviews of Environmental Contamination and Toxicology. However, 

### if this is

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

used as the protocol instead of EPA Guideline 850.2100 in the interest of reducing the numbers of animals 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 to xicity data for benfluralin and passerines. The Terrestrial Bi ology Technical Team (TBTT) in the Environmental Fate and Effects Division (EFED) has completed its eval uation of the Organization for Economic Co - operation and Development (OECD) Acute Av ian Oral Sequential Dose Study Guideline (TG223). Based on their analyses, the TBTT de termined that TG223 performed generally as well as 850.2100 regarding information on the LD 50 value, slope, and observation of sublethal effects (with some caveats). It was determ ined that a study conduc ted 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 ‘LD 50 – slope test’ or ‘limit dose test’ guidelines (the ‘LD 50 – only test’ is not adequate for fulfilling data requirements), and it meets certain criteria, for example:

• The study is conducted using bobwhite quail [oth er 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 doe s 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 va lidity requirements as 850.2100 ( e.g ., a study should be

invalidated if >10% of the controls die).

• Control birds are not added dur ing the course of the study.

Studies that deviate from the above criteria may be classified as ‘acceptabl e’ or ‘supplemental’ if they are considered adequate for us e 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 fr om the above criteria.3 COMMENT SOURCE: DOW AGROSCIENC ES' RESPONSE TO US EPA'S

BENFLURALIN REGISTRATION RE VIEW DOCKET (EPA-HQ-OPP2011-0931)

DAS COMMENT(1): The Agency states on page 7 of 103: "Benfluralin is applied as band treatment, broad cast, golf course treatm ent... 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: "D o not apply BALAN DF through any type of irrigation system." All other bent1uralin co ntaining products are so lid, 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 appl ied 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 no zzles and apply as a medium or coarser spray (according to ASAE standard 572)." This statem ent precludes aerial application. All other benfluralin containing products are solid, granu le products with a low concentration of benfluralin. These products are no t 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 en tries 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 Agricult ural Rights of Way/ Industrial site characterization in this table. In the Benflu ralin RED, EPA requires that all product labels be amended to be eligible fo r re-registration. (U.S. EPA 2004) A maximum of 2 pounds active ingredient per acre per applic ation, maximum of 2 applications per year, and a maximum of 4 pounds active ingredient per acre per year we re required for Christ mas Tree Plantations and Non-Agricultural Rights of Wa y/Industrial sites. Additionally , Ornamental Sod Farm (Turf) was not a specific use pattern that was supported th rough the re-registration process. DAS requests4 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: Appe ndix A is related to Table 3.1 and describes formulations and uses for benfluralin. Specifically, the site description entries include: Christmas tree plantations, indus trial/ construction ar eas (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 recomme nds for the Agency to work with this registrant to update this use pattern. Furthermore, DAS r ecommends that this 41b/A use rate not be included in any risk assessment. Site Descipti on: 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-Agricultur al Rights-of-Way/ Fencer ows/ 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 Agen cy 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-registra tion 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 Ferti lizer 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 us e 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 s ubmitted the study by Hertl et al.(2003) on February 12, 2007. According to our record s, 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 measur ements 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 Toxi city Test (Shell Disposition) For the oyster acute toxicity test, DAS disagr ees with its inclusion in the data gap summary. Although the study by Hicks (2007) has been previ ously classified as "supplemental" primarily on the grounds that a specific endpoint has not been identified, DAS believes th at this study is of the highest scientific standard and that a repeat study is unlikely to prov ide the Agency with any useful additional information. Due to the limited solubility of benflura lin in seawater, 50 ug/L was the highest exposure level achievable unde r flow-through conditions. Measured exposure levels, although lower than target due to adsorption losses, remain ed 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 statisti cally 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 oy ster acute toxicity te st (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 IC 50 ) could not be calculated from the study. Deviations from study guidelines contributed to the lack of suffici ent data to assess risk to these organisms:

1. A definitive endpoint (the IC 50 ) could not be calculated from the study.

2. The acclimation period (2 days) wa s 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 tr eatment 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 di lution water sparingly, and as necessary to support life and growth without affecting the test results.

EFED believes that a well designed flow-thr ough study would reduce th e 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 Toxi city Test (Bluegill, Rainbow Trout) DAS agrees to provide th is study for benfluralin with the bluegill sunfish, Lepomis macrochirus, to upgrade the registration pa ckage and address these guidelines. DAS looks forward to discussion of the timeline for the c onduct and submission of th is study. To address the guideline requirement for the rainbow trout, DA S submitted the study by Hertl et al. (2003) on February 12, 2007. According to our record s, 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 wa s determined to be invalid6 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 Invertebr ate Life Cycle (Freshwater) DAS agrees to provide this study for benfluralin to upgrade the registration package and address these guidelines. DAS looks forward to discussi on of the timeline for the conduct and submission of this study.

EFED RESPONSE(8): E PA 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 co nducted as a 21-day flowthrough study on the fathead minnow, Pimephales prom elas, and was conducted according to US and OECD guidelines for a Fish Short-term Re production 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 fr om 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 result ing from exposure to a substan ce 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 di sagrees with its incl usion 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 Ag ency 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 th e Hudson (2010; MRID 48204501)

rebuttal to the classifi cation 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 b ecause the control mortality was 12.5% during the study, while no more than 10% is acceptabl e in controls. The high mortalities and type of mortalities indicate hi gh levels of stress on the test organisms making the results difficult to interpret. Thus, there still re mains uncertainty with regard to avian reproductive effects.7 DAS COMMENT(12): DAS: GLN 850.4100 - Seedling Emergen ce 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 st udy 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 assess ment prior to the issuance of a DCI.

DAS COMMENT(13): DAS: GLN 850.4200 - Vegetative Vigor Te rrestrial 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 re quirement. According to our reco rds, 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 assess ment 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 Skel etonema (2007b) have been previously classified as "supplemental" on the grounds that"...measured c oncentrations were below LOQ for all times and treatment groups thus it is not possible to obtain suitable endpoi nts from the study." (EPAHQ-OPP-2011-0931-0003) In fact, th e 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 gr owth studies, by necessity, must be conducted under conditions of high light inte nsity, this is an unavoidable feat ure of the study and should not be taken to invalidate the results. All samples were centrifuged prior to analysis and therefore represent true bioavailable con centrations of benf1uralin in the exposure media. DAS believes that these studies are of the hi ghest scientific standard and would propose that a repeat study is considered unnecessary. Additionally, DAS recomme nds for the assessment as a data gap for the aquatic plant growth Tier II study with non-va scular aquatic plants to be reconsidered. Furthermore, an equivalent study on Anahaena fl os-aquae, conducted by He rtl 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) nom inal concentrations were 0 (negative and solven t 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 th e 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 concentratio ns were 0 (negative and solvent controls), 0.00166, 0.00416, 0.0104, 0.0260 and 0.0650 mg a.i./L under static condit ions; 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 meas urements of concentrations at the 24, 48, 72 and 96 hr times below the LOQ. Ther efore, 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 unsou nd and was classified as Invalid.

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

solutions were not measured for the disso lved 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 ascompared 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 Nontarge t Plant Phytotoxicity Policy Issu es”, 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 variab ility in the growth rates ac ross the test c oncentrations 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 chemi cal, 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 chemi cal could not be assessed.

These studies (GLN 850.5400) are still need ed. 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 poten tial risks to aquatic plan ts is essential for sound environmental management. The data will also be used in determining whether a “may affect” to Federally-listed threatened a nd endangered species is likely under the Endangered Species Act

.

DAS COMMENT(15): DAS: 40 CFR Part 1 58 (USEPA, 2007a) - Whol e Sediment chronic Invertebrates, Freshwater and Marine - In res ponse to this data requirement, DAS will be submitting the following study: Memmert, U. E ffects of Benfluralin Technical on the Development of Sediment-Dwelling Larvae of Ch ironomus riparius in a Water-Sediment System. Study ID: 842140, 2003.

EFED RESPONSE (15): EPA looks forward to the re ceipt 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 benflu ralin effects on aqua tic 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 sc heme. 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 fo rmulation types. Runoff Input - There are major uses of benf1uralin either by soil incorporati on 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 th e Conceptual Model, runo ff 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 rout e of exposure within the Conceptual Model. Atmospheric Transport Input. - Although dissipa tion 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 ther efore significant amounts of benfluralin are not expected to be present in air. Therefore at mospheric 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, th ere is one currently registered benfluralin product that can be applied as a liquid ( i.e., Balan DF); therefore, spray drift is a poten tial 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 exposur es occurring due to th e chemical properties and use pattern. Although some pathways may lead to higher exposur es than others, all pathways in the conceptual model are stil l 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-evaluat ion Division (PRD) request submission of a passerine study protocol for review by the Agency prior to initia tion of this study."

DAS Comment:DAS agrees to provide this study pr otocol 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 subm ission of this protocol.

EFED RESPONSE(17): EPA looks forward to the rece ipt of this study protocol.10 DAS COMMENT (18) : “ Parameter: Aerobic Aquatic Metabolism Half-life (20 o C) The value entry indicates that no data is available. However, an aquatic degradation study is available (Knoch and Heim, 2002). This study wa s 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 DT 50 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 r apidly volatilized or diss ipated to the sediment layer with an overall DT 50 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 docum ent Benfluralin Summary Document that this data requirement is “Non-Guideline.” In res ponse 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 re ad as Benfluralin Concentrations in NAWQA Ground Water Monitoring.

EFED RESPONSE (20): EPA will correct the table headin g 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 Benf luralin Technical to Daphnia

magna in a 48-Hour Immobilization Test.

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

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

MRID 47055203. Hertl et al. 2003. Toxicity of Benflu ralin 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): (E PA 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, Pesticid es, and Toxic Substan ces, Washington, D.C. EPA 738-R-04-012. July 2004, pp. 74-75.