### UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY WASHINGTON, D.C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

PC Code: 128968 DP Barcode: 336179 

### MEMORANDUM DATE: October 24,2007


### SUBJECT: EFED Risk Assessment for the Proposed New Uses ofFluroxypyr on Pome Fruit, Proso Millet, and Pearl Millet. 

### FROM: JonathanAngier, Ph.D., Environmental Scientist Fred Jenkins, MS, Biologist Environmental Risk Branch I1 Environmental Fate and Effects Division (7507C) 

### THRU: Dana Spatz, Acting Chief, Environmental Risk Branch I1 Environmental Fate and Effects Division (7507C) 

### TO: Shaja Brothers Registration Division (7505P)
This memorandum pertains to proposed new uses for fluroxypyr on pome fiuit and millet. The results and conclusionspresented here were obtained using the best available data; however, the accuracy ofthis memo may be limited by uncertainties and data gaps. If additional information is acquired in the future that might affect the results presented in this assessment, this knowledge will be considered and incorporated in future assessments (if appropriate).

### Data gaps that have been identified, and that could ultimately affect 

### the outcome of fluroxypyr assessments,include: Rate of formation of fluroxypyracid from fluroxypyr-MHE, and relative quantitiesproduced under different conditions. Potential impact ofboth flwoxypyr-MHE and fluroxypyr (acid) co-existing within the same environment, as the MHE form degrades to the acid form. Lack of acceptable seedlingemergence and vegetativevigor study testing fluroxypyr acid.

### ECOLOGICAL RISK ASSESSMENT FOR THE Registration of New Uses for Fluroxypyr USEPA PC Code: 128959 Proposed New Uses:

### pome hit,proso millet, and pearl millet
End Use Product: STARANE@

Environment Risk Branch 

### I1 Team: 

### JonathanAngier, Ph.D., Environmental Scientist Fred Jenkins, MS, Biologist Environmental Fate and Effects Division (7507C)

Branch ChiefApproval: 

### Dana Spatz, Acting Chief EnvironmentalRisk 

### Branch I1 

### Environmental Fate and Effects Division (7507C)

### Table of 

### Contents



### ........................................................................................................ I

### . EXECUTIVE SUMMARY 6 I1


### . PROBLEM FORMULATION 

### ................................................................................................ 10 A


### . Stressor Source and Distribution 

### ................................................................................ 10 1


### . Source and Intensity

### ......................................................................................... 10 2


### . Physical/Chemical Fate and Transport Properties 

### ........................................... 11 3


### . Mode ofAction 

### ................................................................................................ 12 4


### . Overview of PesticideUsage 

### ........................................................................... 12 B

### . Receptors 

### ..................................................................................................................... 12 1


### .Aquatic Effects 

### .................................................................................................. 13 2


### . Terrestrial Effects 

### ............................................................................................. 14 3


### . Ecosystems at Risk

### ........................................................................................... 15 C


### . Assessment Endpoints

### ................................................................................................. 15 

### D


### . Conceptual Model 

### ....................................................................................................... 17



### ................................... 1


### . Rational for Risk Hypothesis Selected for Assessment 17 2


### .Risk Hypothesis

### ................................................................................................. 19 3


### . Diagram 

### ............................................................................................................ 20 E

### . Analysis Plan 

### ............................................................................................................... 22



### ..................................... . 1 Preliminary Identification of Data Gaps and Methods 22



### ....................... 

## . 2 Measures to Evaluate Risk Hypothesis and Conceptual Model 24



## . .......................................................................... a Measures of Exposure 24



## . ............................................................................... b Measures of Effect 26 I11


### . ANALYSIS 

### ................................. 

### ....................................................................................... 28 A


### . Exposure Characterization 

### ..........................................................................................28 1


### . Environmental Fate and Transport

### ................................................................... 28 a

### . Degradation and Metabolism 

### ...........................................................28 b


### . Transport and Mobility 

### ........................................................................ 28 c

## . Field Studies 

### ........................................................................................ 28 d


### . Bioaccumulation

### ................................................................................29 2


### . Measures of Aquatic Exposure 

### ........................................................................ 29 a

### . Aquatic Exposure Modeling

### ................................................................. 29 b


### . Water Monitoring Data 

### ......................................................................30 3


### . Measures ofTerrestrial Exposure 

### .................................................................... 30 a

### . Dietary Residues

## ................................................................................... 30 

### b

## . Exposure Modeling for Non-Target Plants 

### .......................................... 31 c

## . SprayDrift Analysis 

### ............................................................................. 31 C


### . Ecological Effects Characterization 

## ............................................................................ 32 1

### . Aquatic Effects Characterization 

### .....................................................................32



### .................................................................................... . a Aquatic Animals 33 (1) Acute Effects 

### ........................................................................... 33 (2) Chronic Effects


### ........................................................................ 35

### ...................................................................... (3) Sublethal Effects 35 (4) Field Studies 

## ...................................................................... 35 b

## . Aquatic Plants 

### ..................................................................................... 35



### ................................................................. 2

## . TerrestrialEffects Characterization 35 a

### . Terrestrial Animals 

### ............................................................................... 35 (1) Acute Effects 

### ...........................................................................37



### ........................................................................ (2) Chronic Effects 37



### ................................................................ (3) Sublethal Effects 3 8 (4) Field Studies 

### ............................................................................ 38



### .................................................................................. . b Terrestrial Plants 38 IV


### . RISK CHARACTERIZATION 

### ............................................................................................. 39 A


### . Risk Estimation

. 

### 'Integration of Exposure and Effects Data 

### ...................................... 39 1


### . Non-target Animals and Plants 

### ........................................................................ 39 B

### .Risk Description 

### ........................................................................................................... 44



### .............................................................................. 1

## .Risks to Aquatic Organisms 44 a

## . Animals

### ................................................................................................. 44 b

## . Plants 

### .................................................................................................... 45



## ......................................................................... 2

## . Risks to Terrestrial Organisms 45



### ................................................................................................. . a Animals 45 b


### . Plants 

### .................................................................................................... 46



### ............................. C


### . FederallyThreatened and Endangered (Listed) Species Concerns 46 a

### . Action Area 

### .....................................................................................................46



### ............................................................ . b Taxonomic Groups Potentiallyat Risk 47



### .............................................................. (1) Discussion ofRisk Quotients 47 c

### . Indirect Effects Analysis 

### .................................................................................. 49



## ................................................................................................. d


### . Critical Habitat 50



### .................................................................................... 

## . e Co-occurrenceAnalysis 51 V


### . REFERENCES

### ........................................................................................................................ 53 IV


### . APPENDICES 

### ....................................................................................................................... 54

### I. EXECUTIVE SUMMARY A. 

### Nature of Chemical Stressor STARANEB (Fluroxypyr-MHE) is a herbicideintended primarily forpostemergent selective control ofbroadleafweeds. It is currentlyregistered for use on wheat, barley, oats, corn, sorghum, fallow cropland, non-cropland (i.e., rangeland), and others. This Ecological Risk Assessment regards the proposed new uses on pome hitand millet. Fluroxypyr-MHE is formulated as an emulsifiable concentrate that is mixed with water and applied as ground or aerial spray. It may be applied as broadcast or banded, or even as spot treatmentby hand application. STARANE' can be used for pre-plant or post-emergent broadleafweed suppression. The proposed new uses for Fluroxypyr-MHE are: Pome Fruit, Group 11; Millet; Proso Millet; and Pearl Millet. Theproposed new use label for Pome Fruit includes potentially higher maximum rates for this use (specifically,application rates for "Weeds Suppressed") than for most already approved uses. Theproposed new use label states: "Do not apply more than 2 213 pints per acre (0.5 lb ailacre) per year." This assessmentreflects a high-exposure scenarioby assumingthe maximum application amount of 0.5 lb ailA is used per year. 

### B. Potential Risks to Non-target, non-listed Organisms Based on EFED's evaluation of fluroxypyr-MHE,which is the parent compound that degradesto the herbicidally active fluroxypyr acid, risk above the Agency level of concern for listed and nonlisted terrestrial dicot plant species may result from the proposed new uses. Based on limited supplemental terrestrial plant toxicity data, fluroxypyr, the degradate of fluroxypyr-MHE, may pose a greater risk to nontarget terrestrial plants than fluroxypyr-MHE. EFED does not expect fluroxypyr-MHE to pose a significant risk to birds, mammals, fish, aquatic invertebrates, or aquaticnon-vascular plants. C. Conclusions

## - Exposure Characterization Fluroxypyr MHE is expected to degradeto its herbicidal active ingredient, fluroxypyr acid following application. Degradation to active ingredient fluroxypyris expected to occur primarily over the course of days or weeks, dependingon conditions. Therefore, EFED's assessment expects terrestrial organismsto potentially be exposed to both fluroxypyr MHE and fluroxypyr (acid). However, EFED expects aquatic organisms to be predominately exposed to fluroxypyr because of its rapid formation, under aerobic aqueous conditions (tla 

### = 5 days), from its parent compound fluroxypyrMHE. In addition, unlike in the terrestrial environment (where potential exposure exists immediately following application), most ofthe aquatic exposure should occur when the chemical is transported into water bodies following a rain event (with conversionErom MHE to acid form occurringin the interim). Nevertheless, some MHE may be conveyed directly to the water body as spray drift 

### (andlor ifrunoff occurs soon after application). Consequently, while EFED's aquatic assessment would presumably focus primarily on assessing the risk of fluroxypyr exposureto aquatic organisms, some exposure to fluroxypyrMHE is also possible

### and cannot be discounted. 

### In the terrestrial environment fluroxypyr MHE is also expected to degrade to fluroxypyr,but typicallynot as rapidly as in the aquatic environment. Thus EFED anticipates that terrestrial organisms may be readily exposed to both fluroxypyr MHE and fluroxypyr. Accordingly, this assessment evaluated the risk posed to terrestrial species exposed to either fluroxypyrMHE or fluroxypyr. 

### D. Conclusions

## - Effects Characterization Table 

### 1,below, provides a characterization ofhow toxic fluroxypyrMHE and fluroxypyr is to aquatic organisms. These toxicity data are the most sensitive toxicity endpoints available for aquatic organisms. These toxicity data will be used to assess the risk of fluroxypyr and fluroxypyrMHE to aquatic organisms. Table 1. Aquatic organism toxicity characterizations for fluroxypyrMHE and its Herbicidal Degradate



### As demonstratedin Table 

### 1, above, fluroxypyr is slightly to practically nontoxic to aquatic organisms, Fluroxypyr MHE toxicity studies were only able to classify aquatic organism toxicity for marine estuarine invertebrates which was shown to be very highly toxic to these organism. No chronic toxicity data are available for aquatic organisms for either fluroxypyror fluroxypyrMHE. (See Appendix A for further details on all aquatic toxicity studies) Fluroxypyr Taxonomic Group
Freshwater Fish Freshwater Fish EstuarineMarine Fish EstuarinehiarineFish Freshwater Invertebrates Freshwater Invertebrates Marine Estuarine Invertebrates Marine EstuarineInvertebrates Aquatic nonvascular plants Aquatic nonvascular plants Aquatic vascular plants Aquatic vascular plants



### Below, Table 2 

### presents the characterizations ofhow toxic fluroxypy 

### MHE and fluroxypyr are to terrestrial organisms. These data are the most sensitive fluroxypyrMHE and fluroxypyr toxicity endpoints available for terrestrial organisms. These toxicity values will be used to assess the risk Chemical Fluroxypyr FluroxypyMHE Fluroxypyr FluroxypyrMHE Fluoxypyr FluroxypyrMHE Fluroxypyr FluroxypyrMHE Fluroxypyr

Note 1: This item is not applicable (NA) because the Agency does not assign acute toxicity characterizationsto aquaticplant toxicity endpoints. Note 2: This item is not applicable (NA) because there are no guideline aquatic plant chronic toxicity studies. FluroxypyrMHE Fluroxypyr FluroxypyrMHE Principal Acute Toxicity Endpoint

LCSo = 14.3 ppm ai LC50 = 13.2ppm ai No Data Available >0.087 ppm ai ECSo > 100ppm ai ECS0 >0.109ppm ai
5 1ppm ai 0.068 ppm ai ECso> 100ppm ai 0.29 ppm ai No Data Available >2.3 ppm ai Acute Toxicity Categories Slightlytoxic Slightly toxic NA Not determined Practically nontoxic Not determined Slightly toxic Very highly toxic NA 

## '
NA
------------ NA Principal Chronic Toxicity Endpoint No Data Available No Data Available No Data Available No Data Available No Data Available No Data Available
No Data Available No Data Available NA NA NA NA

### of fluroxypyr

### MHE and fluroxypyr to terrestrial animals.
Table 2. Terrestrialorganisms Taxonomic Group
Birds

Birds

Mammals Mammals Terrestrial Plants toxicity Chemical Fluroxypyr MHE

Fluroxyp yr

Fluroxypyr MHE Fluroxypyr Fluroxypyr MHE

Fluroxypyr characterizations of flurorypyr Principal Acute Toxicity Endpoint Acute dietaryLC50

> 5620 mg ailkg Acute oral toxicity data not available Acute dietaryLC50

> 5620 mg ailkg Acute oral LDso >

2000 mg dkg LD50 79 1 mg dkg No Data Available Seedling Emergence dicotNOAEC = 0.031 lbs. ailacre Monocot EC25 = 0.075 lbs. ailacre Seedling Emergence monocotNOAEC = 0.124 lbs. dacre EC25>0.25 Ibs. ailacre Vegetative vigor dicot NOAEC =0.001 lbs. dacre ECZ5 =0.004 lbs. ailacre Vegetative vigor monocotNOAEC = 0.062 lbs. ailacre. EC25 =0.124 lbs. ailacre Seedling emergence dicot NOEAC =not determined ECZ5 = 0.025 lb ai/A MIIE and fluroxypyr Acute Toxicity Categories Practically nontoxic

Practically nontoxic
Practically nontoxic ----------- NA'

NA' Principal Chronic Toxicity Endpoint LOAEC = 500 PPm ai NOAEC = 250 ppm ai No Data Available

NOAEC = 1000 ppm ai No Data Available NA~

NA~plant toxicity endpoints. Note 2: This item is not applicable (NA) because there no guideline terrestrial plant chronic toxicity studies. 

### As demonstrated in Table 2 above, fluroxypyrMHE and fluroxypyr are slightlyto practically nontoxic to birds, and mammals. The available avian chronic toxicity study demonstrated that fluroxypyrMHE caused egg yolk peritonitis in hens at a NOEAC of 250 ppm. The mammalian chronic toxicity studies demonstrated that the most sensitivechronic toxic endpoint was a parental NOAEL of 1000ppm for increased kidney weight with corresponding gross and microscopic findings including papillary atrophy, edema, necrosis, hyperplasia of the pelvic epithelium, degenerationhegenerationof the tubular epithelium,tubulo-interstitial nephritis, and dilatation of the tubules (See Appendix A for further details on all terrestrial organism toxicity studies). E. Uncertainties and Data Gaps 

### Fate Uncertaintiesand Data Gaps Once fluroxypyr MHE is applied to the environment, it is expected to degrade to its herbicidal active ingredient, fluroxypyr acid (often referred to simply as fluroxypyr). The fate of fluroxypyr-MHE in the environment is complicated by uncertainty in the formation rate and distribution of the initial degradate fluroxypyr acid (activeingredient in STARANE' fluroxypyrMHE) following spray application. Fluroxypyr-MHE application rates are established based upon acid equivalents (ae) pursuant to fluroxypyr acid as the active ingredient (ai). However, the solubility of fluroxypyr-MHE is much lower (-0.9 mg/L) than fluroxypyr acid (-8,000 mg/L); accordingto mixing/applicationinstructions,the tank must be agitated before and during applicationsto allow undissolved material to remain in suspension. In 

### neutral or low pH aqueous conditions, fluroxypyr-MHE is sufficiently stable such that spray distributed on a target zone will initially contain mostly the fluroxypyr-MHEform. Under field conditionsit is likely that most of the MHE will convert to the active ingredient (fluroxypyr acid) in the course of several days or weeks. 

### In the EFED models, it is assumed that the initial spray contains all the active ingredient, and that degradationrates for total toxic residues (fluroxypyr MHE and fluroxypyr acid) commence immediately after spraying. There may be initial on-siteexposureto

### the MHE form after spraying, with degradation occurring first from the MHE to acid form, then to other (less-toxic) forms. Actual exposure could then potentially be longer than assessed. Conversely, this effect may also attenuate the impact ofthe active ingredient, as it will be introduced onto the site more gradually (according to degradation rates). In high-pH conditions, though, degradation ofboth MHE and acid forms are expected to occur more rapidly. For the purpose of EFED assessments, the most conservative fate and effects input parameters areused where available; in 

### this instance, it is most conservative to use the values for total toxic residues for exposure. Ecological Effects Uncertaintiesand Data Gaps 

### Currently, there is a registrant submitted supplemental fluroxypyr seedling emergence study and a registrant submitted supplemental fluroxypyr vegetative vigor study. Both studies are deemed supplemental because of significant deviations from the study guidelines. Neither of these studies produced valid NOAEC values to calculate the risk of fluroxypyr to endangered terrestrial plant species. However, the EC25 results of these studies indicate that fluroxypyris substantially more toxic to plants than its parent compound fluroxypyr MHE. Despite the available supplemental fluroxypy terrestrialplant toxicity data, EFED would need guideline terrestrial plant toxicity data on fluroxypyr

### in order to more definitively access the risk of fluroxypyto terrestrial plants, especially endangeredplants.
11. PROBLEM FORMULATION A. Stressor Source and Distribution 

### 1 Source and Intensity 

### FluroxypyrMHE (active ingredient: fluroxypyr; trade name: StaraneB) is an auxin-type herbicide used for control of broadleaf weeds in a variety of crop and non-crop settings. Figure 1 

### (below) shows the chemical structureof fluroxypyr (ai); 

### Figure 2 shows the chemical structure of parent fluroxypyr-MHE. Fluroxypyr-MHEis formulated to be mixed with water and applied as spray. It may be applied as aerial spray, 'broadcast' or 'banded' ground-level spray, or as spot treatmentby hand spray.
Figure 

### 1. Fluroxypyr Chemical Structure

### Figure 

### 2. Fluroxypyr 

### MHE Chemical Structure

2. 

### Physical/ChemicalFate and Transport Properties Common Name: ChemicalName: PC Code: MolecularFormula: MolecularWeight: Density: Melting Point: Boiling Point: Vapor Pressure: Water Solubility:

Chemical Name: Molecular Formula: Molecular Weight: Density: Melting Point: Boiling Point: Vapor Pressure: Water Solubility: staranem Fluroxypyr methylheptyl ester 128968 CI~H~ICL~FN~O~ 367 dm01 1.g/mL 56-57°C 155-181°C 9.42" 1 

## o-~ mmHg 0.9 mg/L
Fluroxypyr (acid) C7H5Cl2FN2O3 255 dm01 1.3 g/mL 232-233°C N/A 1.07* mmHg 7950 mg/L
3. 

### Mode ofAction Fluroxypyris a broadleafweed herbicidein the Pyridinoxy acid chemical family. The active ingredient fluroxypyris applied as fluroxypyr-MHE, which is rapidly converted to fluroxypyr acid following plant uptake. Fluroxypyr actsby inducing leaf curling and other responses typical of auxin-type herbicides.

### 4. Overview of Pesticide Usage 

### Fluroxypyr-MHE is currentlyregistered for many uses, including: small grains, sweet corn, field corn, fallow cropland, and on-farm non-cropland. B. Receptors 

### Receptors are non-target organisms which potentially couldbe exposed to a chemical stressor such as fluroxypyrMHE andlor its primary degradate fluroxypyr. In 

### the initial stages of a risk assessment both aquatic and terrestrial species are considered. Direct acute and chronic exposures are considered initially. Aquatic animals of potential concern include freshwater fish and invertebrates, estuarine and marine fish and invertebrates, and amphibians. Terrestrial animals ofpotential concern include birds, mammals, and beneficial insects. 

### In determining which receptors should be evaluated in a risk assessment, registrant-submitted toxicity studies are considered. The measures of effects for Level 1 

### screening assessments are generallybased on registrant-submitted toxicity studies performed on a limited number of organisms representingbroad taxonomic groups (e.g., birds, mammals, fish, 

### invertebrates, plants). The taxonomic groups and test species typically evaluated for ecological effectsin screeninglevel risk assessments are shown in Table 3. 

### Within each ofthese broad taxonomic groups, the most sensitive acute andlor chronic endpoint is selected from the available test data and is used in the risk assessment.

### 1. Aquatic 

### Effects Table 3. Taxonomic Groups and Test Species Evaluated for Ecological Effects in Screening-level Risk Assessments.



### Aquatic effects are determined through assessment of potential impacts of exposure to aquatic organisms. Once fluroxypyrMHE is applied to the environment, it is expected to degradeto its herbicidal active ingredient, fluroxypyr. The degradation is expected to be very rapid once fluroxypyrMHE comes in contact with water. Thus, aquatic organisms may be exposed to both fluroxypyrMHE and fluroxypy. However, EFED expects aquatic organismsto be predominately exposed to fluroxypyr because of its rapid formation from itsparent compound (fluroxypyrMHE), and because Starme@is not intended to be applied directlyto water. Nevertheless, EFED's aquatic assessment focuses on assessing the risk of exposureto aquatic organisms from fluroxypyr total toxicresidues (MHE and acid forms)


### . Fish, aquatic-phase amphibians, aquatic invertebrates (epi-benthic, benthic, sediment dwelling), and aquatic plants may all be potential receptors for environmental exposure to fluroxypyrresidues. Taxonomic group Birds 

### "
Mammals Freshwater fish
Freshwater invertebrates Estuarine and marine fish Estuarine and marine invertebrates
Terrestrialplants Aquatic plants and algae



### The followingis a list of registrant submittedtoxicity data that is utilized to evaluate the impact of fluroxypyr on aquatic organisms. Example(s) of representative species mallard duck (Anasplaytrhynchos) bobwhite quail (Colinus virginianus) laboratory rat (Rattus nowegicus) bluegill sunfish (Lepomismacrochirus) rainbow trout (Oncorhynchusmykiss) water flea (Daphnia magna) sheepshead minnow (Cyprinodon variegatus) eastern Oyster (Crassostrea virginica) mysid Shrimp (Americamysisbahia) monocots -corn (Zea mays) dicots - soybean (Glycinema) duckweed (Lemna gibba) green algae (Selenastrumcapricornutum) "Birds represent surrogates for amphibians (terrestrial phase) and reptiles.

Freshwater fish may be surrogates for amphibians (aquatic phase). Four species of two families of monocots, of which one is corn; six species of at least four dicot families,of which one is soybeans.

### Available Aquatic Organism Acute ToxicityData Five fluroxypyrMHE freshwater fish acute-toxicityLCs0studies testing inland silverside,bluegill sunfish, rainbow trout, and golden orfe Three fluroxypyr

### freshwater fish acute toxicity LCs0studies testing rainbow trout, bluegill sunfish, and golden orfe. Two fluroxypyr MHE .freshwaterinvertebrate acute toxicity LCs0studies testing waterflea Two fluroxypyr freshwater invertebrate ECsostudies testing water flea. Two fluroxypyr marinelestuarine fish acute toxicity LCs0studies testing Atlantic silverside, and sheepshead minnow. Four fluroxypyr MHE marinelestuarine invertebrateECS0 studies testing eastern oyster, grass shrimp, and pink shrimp. Two fluroxypyr marinelestuarine invertebrate ECsostudies testing eastern oyster and grass shrimp. These studies are summarized in detail in Appendix A,
2. Terrestrial Effects 

### Terrestrial effects are evaluated through assessment of the potential impact of exposure on representative terrestrial organisms. In the terrestrial environment fluroxypyr MHE is expected to degradeto fluroxypyr (acid). Terrestrialorganisms will be exposed to both fluroxypyr MHE and fluroxypyr soon after application. Moreover, fluroxypyrMHE degradation to fluroxypyrin the terrestrial environment may not occur as rapidly as in the aquatic environment. Thus EFED anticipates that terrestrial animals may be readily exposedto both fluroxypyrMHE and fluroxypyr. Consequently, this assessment evaluated the risk posed to terrestrial animals exposed to either fluroxypyr MHE or fluroxypyr. Reptiles, birds, mammals, invertebrates, such as honeybees and earthworms, and non-target plants are potential terrestrial receptors of concern for environmentalexposure to fluroxypyr MHE and fluroxypyr. A summary ofthe registrantsubmitted laboratory studies on the toxicity of fluroxypyr and fluroxypyr MHE to terrestrial organisms are available below. Available Terrestrial Organism Acute ToxicityData Two fluroxypyr acute oral LD50 studies testing mallard duck, and bobwhite quail Two fluroxypyr acute dietary LC50 studies testingbobwhite quail and mallard duckThree fluroxypyrMHE acute dietary LC50 studies testing mallard duck and bobwhite quail Two fluroxypyrMHE avianreproduction studies for bobwhite quail, and mallard duck One fluroxypyr acute oral toxicity study for rat One fluroxypyr reproductive toxicity test for rat One fluroxypyr vegetativevigor toxicity study and one seedling emergence toxicity study. One fluroxypyrMHE vegetative vigor toxicity study and one seedling emergencetoxicity study. These studies are summarized in detail in Appendix A.
3. Ecosystems at Risk The ecosystems at risk are typicallynational in scope. Consequently,it may not be possible to identify specific ecosystems at the screening level. However, in general terms, ecosystems potentially at risk could be identified as those ecosystems in close proximity to siteswhere fluroxypyr MHE is used. These ecosystems could include: Freshwater habitats, such as streams, rivers, or lakes Estuaries Forests Grasslands Wetlands Ecosystems potentially at risk are expressed in terms ofthe selected assessment endpoints. The typical assessment endpoints for screening-levelpesticide ecological risks are discussed in Section 1I.C (Assessment Endpoints).
C. Assessment Endpoints An assessment endpointrepresents an actual environmental value that is to be protected (ecological entity) as well as its attributes or characteristics. Examples of specific endpoints include individual bird survival, diversity of a fish community, and sustainabilityof a bird population. Each assessment endpoint needs one or more "measures of effect", which are changes in the attributes of an assessment endpoint itself in response to exposureto a pesticide. Measures of effect are discussed in more detail in Section II.E.2.b.The selection ofthe assessment endpoints is based on valued entities (i.e., ecological receptors), the ecosystems potentially at risk, the migration pathways of pesticides, and the routes by which ecological receptors are exposed to pesticides. Clearly defined assessment endpoints are important because they provide direction and boundaries in the risk assessment for addressing risk management issues of concern. The typical assessment measures of effect for screening-levelpesticide ecological risk assessments are reduced survival, impaired reproduction and impaired growth for both aquatic and terrestrial animal species. For terrestrialplants including those in semi-aquaticareas, the screening assessment endpoint is the perpetuation of populations ofnon-target species (based on data from studies using crops and non-crop plant species). Existing testing requirements for terrestrial plants and semi-aquaticplants have the capacity to evaluate emergence of seedlings
, and vegetative vigor. Although it is recognized that the measures of effect of seedling emergence and vegetative vigor may not address all terrestrial and semi-aquaticplant life cycle components, it is assumed that impacts at emergence and in active growth have the potential to impact individual competitive ability and reproductive success. The assessment endpoint for aquatic plants and algae is the maintenance and growth of standing crop or biomass. Measurementsof effects for this assessment endpoint focus on algal and vascularplant (i.e., duckweed) growth rates and biomass measurements. In order to protect threatened and endangered species, all assessment endpoints are measured at the individual level. Although all endpoints are measured at only the individual level, they provide insight into risks at higher levels of biological organization (e.g. populations and communities).For example, pesticide effects on individual survivorshiphave important implications for both population rates of increase and habitat carrying capacity. The ecological relevance of selecting the above-mentioned assessment measures of effect is as follows: 1) complete exposure pathways exist for these receptors; 

### 2) the receptors may be potentially sensitiveto pesticides in affected media and in residues on plants, seeds, and insects; and 3) the receptors could potentially inhabit areas where pesticides are applied, or areas where runoff and/or spray drift may impact the sites because suitablehabitat is available. This ecological risk assessment considers maximum application rates of fluroxypyr MHE to fields that have vulnerable soils, maximum number of applications (as well as single applications), and minimum intervals for uses on representative crops to estimate exposure concentrations. 

### In addition,this assessmentis not intended to represent a site- or time-specific analysis. Instead, this assessment is intended to represent high-end exposures at a national level. Likewise, the most sensitive toxicitymeasures of effect areused from surrogate test speciesto estimate treatment-relateddirect effects on survival, reproduction, and growth. Toxicity tests are intended to determine effects of fluroxypyr-MHE and its primary degradate, fluroxypyr, exposure on birds, mammals, fish, terrestrial and aquatic invertebrates, and plants. These tests include short-term acute, subacute, and reproductive studies and are typically arranged in a hierarchical or tiered systemthat progresses from basic laboratory tests to applied field studies. The toxicity studies are used: 1)to evaluate the potential of fluroxypyr MHE and fluroxypyrto cause adverse effects, 2) to determine whether further testing is required, and 3) to determine the

### need for precautionary label statements to minimize the potential adverse effects to non-target animals and plants (CFR 40 

## 5 158.202,2002). A 

### summary ofthe assessment endpoints and measurements of effects selected to characterize potential ecological risks associated with exposure to fluroxypyr 

### MHE is provided in Table 4. 1 

# I Table 4. Summary of Assessment and Measurement Endpoints for FluroxypyrMHE and its primary

degradate,Fluroxypyr (TGAI). 

# I I Assessment Endpoint 

# I Measurement Endpoint 

# I

2. Abundance (i.e., survival) of individuals and 

# I 2 Rat developmental toxicity chronicNOAEL and populations of mammals. LOAEL 

# I 1. Abundance (i.e., survival) of individuals and populations ofbirds. la. Bobwhite quail acute oral LD5O. lb. Bobwhite quail and mallard duck subacute dietary LC50.

3. Survival and reproduction of individuals and communities of freshwater fish and invertebrates.



### D. Conceptual Model 3a. Rainbow trout and bluegill sunfish acute LC50. 3b. Water flea acute LCs0. 

# I

4. Survival of terrestrial plants

5. Survival and reproduction of aquatic plants

A 

### conceptualmodel (CM) consists of a written descriptiodriskhypothesis and visual representation of the predicted relationships between a stressor,the potential routes of exposure, and the attribute changes of concern for the assessment endpoint. Visual representationsof the risk hypothesis assessed in this screening level risk assessment are provided for fluroxypyrMHE applied as a ground or aerial sprayin Figure 3. 5a. Seedling emergenceEC25 and NOAEC in Cocklebur. 5b. Vegetative vigor EC25and NOAEC in Cocklebur. 6a. Duckweed ECS0 and NOAEC. 6b. Green algae, bluegreen algae, freshwater diatom, and marine diatom EC50and NOAEC.

1. 

### Rational for Risk Hypothesis Selected for Assessment LD50=Lethal dose to 50% of the test population. NOAEC =No-observed-adverse-effect level. LOAEC = Lowest-observed-adverse-effect level. (EC50) =Lethal (effective) concentration to 50% of the test population. LC25(EC25)=Lethal (effective) concentration to 25% of the test population.

A 

### risk hypothesis is a statement of the predicted relationship between a chemical stressor (such as fluroxypyrMHE and its' herbicidal active degradate, fluroxypyr) and the environment into which it is released. Within the context of this assessment,the risk hypothesis takes into account elements necessary for pathways of exposure to be completed, and makes assumptions andpredictions about whether completed exposure pathways could result in adverse effects upon receptors of ecological interest. An exposure pathway is the means by which a chemical of interest, such as fluroxypyr MHE, and its' herbicidal active degradate, fluroxypyr moves in the environment from a sourceto an ecologicalreceptor. For an ecological exposure pathway to be complete, there must be a source, a release mechanism, an environmental transport medium, a point of exposure for an ecological receptor (this is a location), and a feasible route of exposure for the receptor (for example, oral, dermal or inhalation) at the exposurepoint. a) Terrestrial Ecosvstems Once fluroxypyrMHE is applied to the target plant it is hydrolyzed to the parent acid, fluroxypyr which is the herbicidal active form, and translocated rapidly to other parts of the plants. Fluroxypyr acts by inducing characteristicauxin-type responses, e.g. leaf curling. As such, potentially completepathways of fluroxypyr MHE and its degradate, fluroxypyr, exposureto nontarget organisms could include: exposure ofterrestrial plants through foliar contact and root uptake; exposure of terrestrial wildlife (birds, mammals, invertebrates) through oral and dermal contact with fluroxypyr MHE and its herbicidal degradate, fluroxypyr, applied to plants and soil; through inhalation and dermal contact with spray drift; and through oral and dermal contact with fluroxypyr in water. In regards to the terrestrial environment, the highest fluroxypyrMHE and fluroxypyr residue levels are expected to be located in the soil and on foliage, seeds, insects, and soil invertebrates on treated fields immediately following applications. While spray drift fi-omground and aerial sprays may result in transport and deposition of fluroxypyr MHE onto off-target field surface soil, foliage, seeds, insects or soil invertebrates, the highest concentration for these media are still expected to be those on the treated field. Risk hypotheses evaluatingrisk of fluroxypyrMHE and fluroxypyr via exposure of the dietary route was developed for screening in this risk assessment. These risk hypotheses include impacts fi-omdietary exposureto fluroxypyr MHE and fluroxypyr by secondary and tertiary consumers, both vertebrates and invertebrates,representing common ecological functional feeding groups (i.e.herbivores, insectivores).Herbivores, as used here, include animals that feed on foliage (stems and leaves), seeds, and/or hits;the term granivore is sometimesused to identify animals that feed primarily on seeds. Omnivores are also potentially exposedbut are not specifically included in the receptor list for a screening level risk assessmentbecause exposure concentrations and risk levels will fall between the exclusive feeding groups. Because toxicity data for reptiles and terrestrial phase amphibians are rarely available, risk hypotheses addressing dietary exposure for birds were used as representative as risk to reptiles and terrestrial phase amphibians (USEPA 2004). While the selected risk hypotheses only address terrestrial wildlife exposure via dietaryexposure 

### fi-om residues on foliage and insects, information or data that areavailable to indicate that other routes of exposure may be potentially significant contributorsto wildlife risk and would affect the outcome of risk conclusions are considered in the risk characterization. b) Aquatic Ecosvstems Potentialpathways of exposure in these ecosystems are: exposure of aquatic plants via direct contact; exposure of aquatic animals via dermal contact and uptake through gills, and other water filtration devices and uptake through integument. exposure of soil dwellers, epi-benthic, and somebenthic organisms via sediments.


### 2. Risk Hypothesis Terrestrial Ecosystems terrestrial herbivore and insectivore vertebrates (birds, mammals, reptiles, terrestrial phase amphibians) are subject to reduced number and reproduction when exposed to fluroxypyrMHE and fluroxypyr residues on seeds, insects, foliage due to direct deposition or spray drift from labeled use ofthe pesticide. upland plants (non-wetlandlriparian) are subjectto reduced number and vegetative vigor in areas adjacent to treated field when exposedto fluroxypyrMHE and fluroxypyr residues in soil from spray drift alone or in concert with surface water run-off from labeled use of the pesticide. upland plants adjacent to treated field are subject to reduced vegetative vigor when exposed to fluroxypyr MHE and fluroxypyr residues on foliage due to spray drift from labeled use ofpesticide. ripariadwetland plants adjacent to treated field are subject to reduced numbers when exposed to fluroxypyr MHE and fluroxypyr residues in soil from spray 

### drift alone or in concert with surfacewater run-offfrom labeled use of the pesticide. ripariadwetland plants adjacent to treated field are subjectto reduced numbers when exposedto fluroxypyr MHE and fluroxypyr residues on foliage due to spray drift from labeled use ofpesticide. 

### Aquatic Ecosystems aquatic invertebrates and fish in surface water adjacent to treated fields are subjectto mortality and reduced reproduction when exposed to fluroxypyrresidue in water due to spray drift alone or in concert with run-off from labeled use of the pesticide; exchange of water and sedimentsbetween wetland areas and associated water bodies may also be a factor.

### aquatic plants in surfacewater adjacent to treated field are subjectto reduced growth and reduced biomass when exposed to fluroxypyrresidue 

### in water due to spray drift alone or in concert with run-offfiom labeled use of the pesticide. The data available for assessing the potential impairment of survival, reproduction, and growth associated with the potentially complete pathways of exposure were presented in the previous section (Section 3C) 

### and summarizedin Table 4. 

### Based on the above considerations, this screening-level assessment presumes the following risk hypothesis: FluroxypyrMHE 

### applicationto agricultural fieldsmay result in the exposure of nearby non-target plants and animals, in both terrestrial and aquatic ecosystems. Such exposures have the potential to cause acute or chronic effects to terrestrial or aquatic animals, and to impair growth and survival of terrestrial and aquatic plants.
3. Diagram Figure 3 

### is a visual depiction ofthe conceptual model preliminarily used to assess the potential ecological impacts of fluroxypyr MHE 

### and fluroxypyr on non-target species and the environment. Dashed lines indicateroutes that are either unknown or highly unlikely given what is understood about this chemical.

# + + Direct Contact Difict Contact1 GilllIntegumentU take And I gestion 

### P Root ptake 

# Y 

# P

Figure 3. 

### Conceptual Model for Fluroxypyr MHE New Uses.

### E. Analysis Plan This assessmentfocuses on adverse acute and chronic reproductive effects to terrestrial and aquatic wildlife associated with the proposed new uses for fluroxypyr MHE. This analysis plan identifies the approach, methods, specificmodels, information, and data that will be used to estimate and evaluate risks from proposed labeled uses of fluroxypyr MHE based on the conceptualmodel and risk hypotheses. 1. Preliminary Identification of Data Gaps and Methods a) Data Gaps and Uncertainties There is uncertainty regardingthe rate at which fluroxypyr (ai) is converted from fluroxypyrMHE (appliedproduct), or even if this has any practical implications for the risk assessment. Under field conditions it is likelythat most ofthe MHE will convert to the active ingredient (fluroxypyr acid) in the course of several days or weeks. Both terrestrial and aquatic exposuremodels assume exposure to both fluroxypyr and fluroxypyr-MHE,. Although there are differencesin physical/chemical characteristics that may presumably influence mobility and fate of these 2 forms, for the purpose of aquatic modeling there was no significant distinctionbetween model results using the input parameters (where different) for the MHE vs. the acid form; therefore, a combined residues approach was used. Chronic aquatic toxicological studies are lacking. However, because of the relatively rapid degradation of fluroxypyr in aquatic environments (5-14 days), long-term exposureto fluroxypyrin surface water is considered unlikely; thus, these studies may not be necessary. This is further supported by the lack of detection of fluroxypyr in (foreign) targeted water monitoring studies. Low acute toxicity and lack of chronic risk concerns (based on the available terrestrial animal studies) also indicatethat chronic aquaticrisk shouldbe very low. There are currentlyno availableregistrant-supplied chronic avian toxicological studies for fluroxypyr. However, the Agencybelieves this risk is likely low, based upon absence of chronic avian risk from fluroxypyr-MHE and lack of chronicrisk to mammals from fluroxypyr. Thus, avian chronic toxicological studies for fluroxypyrmay not be necessary.
b) Risk Characterization Method (Risk quotients and levels of concern) Risk characterization integrates exposure and measure of effects data to evaluate the likelihood of adverse effects. For a screening level risk analysis, the Agency accomplishes this integration using a risk index approach,the risk quotient method. Risk quotients (RQs) are calculatedby dividing estimates of exposure (EEC) by acute and chronic measures of effect. RQ = EXPOSURE / MEASURE OF EFFECT 22RQs are then comparedto levels of concern (LOCs) to indicatethe potential risk to nontarget, listed (endangered or threatened), and non-listed organisms. The LOCs are presumptive risk values; a RQ that exceeds the LOC has a presumed risk to non-target organisms. LOCs currently address the following categories ofpresumed risk: $ acute 

### - potential for acuterisk is high and regulatory actionbeyond restricted use classificationmay be warranted 

### - $ acute restricted 

### - the potential for acute risk is high, but may be mitigated through restricted use classification $ acute listed species 

### - threatened and endangered species may be adversely affected $ chronic risk 

### - the potential for chronic risk is high and regulatory action may be warranted. The measures of effect used in the acute and chronic risk quotients are derived fiom required laboratory toxicity studies identifiedin section 

### II.B.3. Table 

### 5 lists the LOC value by taxonomic group associated with a given risk presumption and the specific associated RQ calculation. Each of the taxonomic groups corresponds to the risk hypotheses identified for this assessment in section 1I.D. Table 5. Risk presumption

### LOC values and associated formulas for RQ calculations Risk Presumption RQ LOC Birds and Wild Mammals Acute ~isk' Acute Restricteduse1 Acute Listed species1 Chronic ~isk' EEC~ (ppm) 1LCSO (ppm) or EEC (mglkg-bwld)I LDSO (mglkg-bwld) EEC (ppm) I LCs0(ppm) or EEC (mg/kg-bwld) 1LDSO (mglkg-bwld) EEC (ppm) 1LCS0 (ppm) or EEC (mg/kg-bwld)I LD50 (mglkg-bwld) EEC (ppm) 1NOAEC (ppm) or EEC (mglkg-bwld)I NOAEL (mglkgbwld) 0.5 0.2 0.1 1.O Aquatic Animals Acute Risk Acute RestrictedUse Acute Listed Species Chronic Risk EEC (PP~) (LC50 (ppm) or EC~o bpm)) EEC (PP~) (LCso (ppm) or ECso (PP~)) EEC bpm) LC50 (PP~) or ECso EEC (ppm) 1NOAEC (ppm) 0.5 0.1 0.05

1.0 Terrestrial and PlantsInhabiting Semi-Aquatic Areas Acute Risk Acute Listed Use EEC (lbs ai/A) 1EC2, (lbs ai/A) EEC (lbs ai/A) 1(ECoS or NOAEC (lbs ai/A)) 1 .O 1 .ORisk Presumption 

# I RQ 

# I LOC 

### I Auuatic Plants 

## 1

.-

### - , dietary level from the laboratory study is adjusted for the body weight ofrepresentative exposedmammals or birds or compare normalized dose values in terms of milligram of ai per kilogrambody weight per day (mglkgbwid). 2 EEC = estimate environmental concentration Acute Risk Acute Listed Species



### Screening level models used for derivingEECs to address each ofthe risk hypothesesby the appropriateRQ method and LOC comparison, as defined above, are described in the section below in the fate and exposure analysis plan. The fate and exposure analysis plan also identifies the type of data required to support model inputs and provides the strategy for identifying and using other sources of exposure information to characterize exposure and model results. The analysis plan section on effects describes the selection process for the measure of effect value to be used in RQ 

### calculations in a screening level risk assessment.
2. Measures to Evaluate Risk Hypotheses and Conceptual Model 

# 'For mammals and birds, one can either calculate based on concentration of the ai in the diet (ppm) where the EEC (PP~) 1ECso bpm) EEC (ppm) / (ECo5 or NOAEC (ppm))



### a) Measures of Exposure 1 .O 1 .O



### Methodsused to determine exposure concentrations of a pesticide are dependent on its environmentalfate and physicochemical properties, the application method, and the presence ofreliable monitoring data that are considered representative of the proposed use sites. Initial factors considered for the exposure assessment are provided in Table 6 

### below. Table 6. Factors that may affect the exposure of fluroxypyr

Consideration 

### Monitoring data

Degradation Fluroxypyr Specific data 

### No targeted data from U.S. Targeted monitoring from other countries revealed no detections Fairly rapid degradation, especially in aquatic and high-pH environments. Conclusion 

### Insufficient data available to use in risk assessment. Lack of detects in foreign studies indicate probable low aquatic risk. Little likelihood for longterm high-exposure conditions. Greatest exposure risk following application and 

### decreasing rapidly thereafter.Exposure in TerrestrialSystems Sorptionto soil Bioconcentration Factor (BCF) Applicationmethod

For birds and mammals, the screening assessment of the terrestrial dietary exposureroute for uptake ofpesticide active ingredient assumes that organisms are exposed to a single pesticide residue level for both acute and chronic exposure estimates. EECs in wildlife food items focus on quantifying possible dietary ingestion of residues on vegetative matter and insects on the treated field as the highest residue level that will occur from fluroxypyr MHE use per the label. EFED uses differentEECs for a variety of food substrates. Those food substrates are: short grass, tall grass, broadleaf plantslsmal1insects, and hits/pods/seeds/large insects. The EECs are based on a nomogram that relates food item residues to pesticide application rate (Hoerger and Kenaga (1972) as modified by Fletcher et al. (1 994)). The maximum Kenaga value represents residue levelspresent immediately following chemical application (day zero). The mean Kenaga value represents mean residue levels present (consideringday 0 and day 100 residue levels). The first tier nomogram uses the maximum predicted residues immediately following application. The residue concentrations are converted to a daily oral dosebased on fractions ofbody weight consumed daily as estimated from mammalian allometric relationships in EPA's Wildlife Exposure Factors Handbook (1996). The EECs for birds are adjustedbased on food in-take and body weight differences, so that they are comparable for a given weight class of animal. 

### In all screening-level assessments, the organisms are assumed to consume 100% oftheir diet as one food type. EFED also used the T-REX model to estimate (1) EECs for different food items for birds and mammals and (2) doseldiet based risk to birds as well as dosebased risk to mammals. These input parameters may be seen in Appendix 

### B. EFED used the TERRPLANT model to estimate (1) EECs from a single application only and (2) risk from runoffto monocot and dicot terrestrial plants in areas adjacent to the treated field (sheet runoff), wetland areas (channelizedrunoff),and from spray drift. Input parameters and assumptions from the model are included in Appendix 

### B.. Mobile, accordingto Koc value(s) (FA0 classification) < 100 (fish = 26) Spray (aerial and ground).

Exposure in Aquatic Systems Rapid degradation limits real mobility. Low bioaccumulation potential. Possibility for off-site contamination resulting from spray drift.

At the screeningrisk assessment level for aquatic organisms, such as plants, fish, aquaticphase amphibians, and invertebrates,computer simulationmodels are used to estimate acute (annual instantaneouspeak) and chronic (21 and 60 day weighted average annual peaks for 25

### aquatic invertebrates and fish, respectively) residue levels ofthe dissolved pesticide active ingredientin surfacewater and sediment pore water and in bulk sediment fi-omrunoff and spray drift. These models calculate EECs in surfacewater and sediment using environmental fate data for fluroxypyr. Monitoring data, if available, may also be used to determineEECs or to support the model's exposure estimates. PRZM-EXAMS, as documented at 

### www.epa.govloppefedl/modelslwater/index.htm, is the model used to simulate the fate and transport of fluroxypyr MHE fiom a treated field to and into a receiving water body adjacent to the treated field. Cropping patterns, soil properties, and weather input data for the simulation modelinghave been standardized for a number of crops, referred to as crop scenarios,to provide high-end estimates of runoff and soil erosion representative of the primary growing area for a given crop. The quality control checked crop scenarios and associated meteorological files available for use in a risk analysis are also found at the same web address under the "PRZM crop scenario metadata" (download

### WPD file 1468KB). b) Measures ofEffects Each assessment endpoint requires one or more measures of ecological effect, which are defined as changes in the attributesof an assessment endpoint itself or changes in a surrogate entity or attributein responseto pesticide exposure (Table 

### 4). Ecological measurement endpoints for the screeninglevel risk assessment are based on a suiteofregistrant-submitted toxicity studiesperformed on a limited number of organisms in the followingbroad groupings : 

### Birds (typical test species aremallard duck and bobwhite quail) which are also used as surrogate taxa for terrestrial-phaseamphibians and reptiles. Mammals (typical test species arethe laboratory rat or mouse) Freshwater fish (typical test species are the bluegill sunfish and rainbow trout) which are also used as a surrogatefor aquatic-phase amphibians Freshwater invertebrates (typical test species is the water flea 

## - Daphnia magna) Estuarinelrnarine fish (typicaltest species is the sheepshead minnow or Atlantic silverside) Estuarinelmarineinvertebrates (typical test species are the Eastern oyster and mysid shrimp) Beneficial insects (typicaltest species is the domestic honey bee) Terrestrial plants (typical test species are corn, onion, ryegrass, wheat, buckwheat, cucumber, soybean, sunflower, tomato, and turnip) Algae and aquaticplants (typical test species areAnabaenaJlos-aquae, Selenastrum capricornutum, Scenedesmus subspicatus, Chlorella vulgaris for algae; Skeletonema costatum and Navicula seminulum for diatoms; and Lemna gibba for vascular plants)

### The acute contact LD50value is used 

### as a measure of effect for beneficial insects. The typical test speciesused as a surrogatefor all beneficial insects is the domestic honey bee. The screening assessment endpoint for plants in terrestrial and semi-aquatic environmentsis the perpetuation ofpopulations ofnon-target species (both crop and non-crop species). Measures of effect include the concentration of the pesticide formulation that would cause a 25 

### percent reduction in seedling emergence (EC25) and the concentration ofthe pesticide that would cause a 25 

### percent inhibition (EC25)

### in vegetative vigor. Although it is recognized that the seedling emergence and vegetative vigor endpointsmay not address all plant life cycle components, it is assumed that impacts at emergence and during active growth may impact individual competitive ability and reproductive success. Algae and aquaticplant measures of effect are the growth and biomass 5-day (7-day for duckweed)EC50. Because the proposed labeled use is not for direct application to aquatic systems, the measures of effect desired for algae and aquatic plants are for the technical grade active ingredient form of fluroxypyr. Measures of effect data submitted by the registrant are identified in Section I1 

### B and will be reviewed for use in RQ calculations. Measures of effect for which data are not available, are discussed as data gaps. The abilityto evaluate risk is identified inboth the Toxicity Assessment Section and the Risk Characterization Section. For this screening assessment, the most sensitive measure of effect for each surrogatetaxa group (i.e., 

### freshwater fish and invertebrates, estuarine/marinefish and invertebrates, aquatic plants, terrestrial plants, birds, and mammals) will be used in RQ oalculations. The same measures of effect used for non-listed species are used for listed species= taxonomic groups except the measures of effect for terrestrial plants, algae, and aquatic plants. For terrestrial plants, the measure of effect desired is the ECo5 or NOAEC for vegetative vigor and the ECo5 or NOAEC for seedlingemergence. The ECo5 for growth or biomass is used for algae and aquaticplants.111. ANALYSIS A. Exposure Characterization 1. EnvironmentalFate and Transport
a. Degradation and Metabolism 

### Degradation of fluroxypyr-MHE and fluroxypyrin environmental fate laboratory studies occurs throughbase-catalyzed hydrolysis and microbial-mediated metabolism under aerobic conditions. In sterilizedbuffered water, fluroxypyr-MHE hydrolyzed to the fluroxypyr with half-lives of 3 and 454 days at pH 9 and 7, respectively. Hydrolysis of fluroxypyr-MHE was not observedin the acidic test system at pH 5. No hydrolysis of Fluroxypyr was observed at pH 5,7, or 9. 

### In the aerobic soil metabolism study, both fluroxypyr-MHE and fluroxypyr transformrapidly. Microbial degradation of fluroxypyr-MHE appears to follow a biphasic degradation pattern with an initial first-order half-life of 1to 3 weeks in four soils. Degradation of fluroxypyr-MHE yields fluroxypyr (theherbicidal agent), 4-amino-3,5- dichloro-6-fluoro-pyridin-2-01 (pyridinol metabolite), 

### 4-amino-3,5-dichloro-6-fluoro-2- methoxypyridine (methoxypyridine metabolite) and C02. Fluroxypyrthen degraded with calculated half-lives of 12,23, 12, and 7 days. The rate ofmetabolism decreased significantly after 2 months. Fluroxypyr-MHE and fluroxypyr degrade rapidly in the aerobic aquatic environment (tin 

### -14 days). The major degradate 3-chloropyridinol, was present in the water phase at maximum of 18% of the applied radioactivity at 

### 4 months posttreatment. The major degradate dichloropyridinol,was present in the water phase at maximum of 44% of the applied radioactivity at 4 weeks posttreatment. These degradates are significantly less toxic than either fluroxypyror fluroxypyr-MHE, and are not included as part of 'total toxicresidues' in this assessment. Fluroxypyr-MHE and fluroxypyr degrade rapidly in the anaerobic aquatic environment (tIl2 -8 days). Major degradates were 3-chloropyridinol and dichloropyridinol. Fluroxypyr-MHE and fluroxypyr do not degrade by photolysis in aqueous environmentsor in soil. b. Transport and Mobility 

### Volatility is not a significant route of dissipation. Fluroxypyr is considered to be mobile based on Freundlich

### Lds values ranging from 0.1 1 

## - 1.9 mllg in four test soils (silt loam, sandy loam, loam, and silty clay textures). Major degradate (fluroxypyr) is not expected to bioaccumulate sinceit will be in an ionic form in water.
c. Field Studies 

### Field dissipation studies conducted in Oklahoma (MRID 45204201), North Carolina (MRID 44896702) and Missouri (MRID 45204202) indicate a field dissipation half-life of 5-8 days. The primary dissipation route appearedto be transformation. 28

### d. Bioaccumulation According to the Staranem Material Safety Data Sheet (Dow AgroSciences), bioconcentration potential is low (BCF < 

### 100); a BCF of 26 

### is cited for fish.
2. 

### Measures of Aquatic Exposure
a. Aquatic Exposure Modeling The PRZM-EXAMS model was used to estimate the surface water concentrations for fluroxypyr from the proposed new uses. Input values for this model are listed in Table 

### 7. Values for the fluroxypyr acid form were used for molecular weight, vapor pressure, solubility, and hydrolysis, as this is the active ingredient degradation product for which these uses are intended. All fateltransport parameters in Table 7 

### are for total toxic residues (MHE and acid forms). Regardless, modeling acid-only versus MHE-only forms yielded insignificant differencesin predicted Environmental Exposure Concentrations (EECs) for EFED baseline-assessmentmodels. 

### 'TX Sorghum' was used as a surrogate scenario for milletbecause sorghum is very similarto millet in terms of crop type and production methods, and is grown predominantly in the southern plains region of the U.S. (Texas being one ofthe major producers ofmillet). Below (Table 8) 

### are the model results for predicted surfacewater concentrations (using the PRZMEXAMS model).



## I I pH 7 = Stable 

## I MRID 40244539 

## I

Table 7. 

### Fluroxypyr Input Parameters for PRZM-EXAMS Model PARAMETER: ' Molecular Weight Henry's Law Constant Vapor Pressure Solubility Hydrolysis Half-life Aqueous PhotolysisHalf-life Water Half-life (aerobic) Benthic Half-life (anaerobic) Soil Half-life (aerobic) 

### KC Application Rate: Sorghum ApplicationMethod: Sorghum Number of Applications/ Intervals: Sorghum Application Rate: Pome Fruit VALUE: 255 glmol NIA 9.4*10-~ mm Hg 7950 mg/L pH 5 = Stable SOURCE: OPPIPesticideFact Sheetl1998 STARANEBMaterial Safety Data Sheet STARANEBMaterial Safety Data Sheet pH 9 = Stable Stable 42 days 24 days 14 days

68 0.125 lb aUA Aerial Spray 2 per year 1 14 days 0.5 lb aUA MRID 44080342 MRID 44080345 - 3X single value of 14 days MRID 44080344 - 3X single value of 8 days MRID 42 137317 -median value for 4 soil types MRID 42 137319 - average of 4 values &om4 different soils Label Label Label Label

### The estimated peak, 4-day, 21-day, 60-day, and 90-day concentrations of fluroxypyrin surface water predicted by PRZM-EXAMS arepresented in Table 8, 

### below. Detailed PRZM-EXAMSmodel output files arepresented in Appendix E Application Method: Pome Fruit Number of Applications 1Intervals: Pome Fruit



### Table 8. 

### Tier 2 

### (PRZM-EXAMS) Estimated Environmental Concentrations (EEC) of Ground Spray

1per year



### b. Water MonitoringData Label Label



### Fluroxypyr in 

### Standard Farm Pond from Use on Pome Fruit and Millet.



### There is insufficienttargeted monitoring data for fluroxypyr in the U.S. to allow for evaluation ofpotential exposure in 

### aquatic environments. However, there havebeen targeted studies in other countries. A targeted monitoring study conducted in Australia (Waugh and Padovan, 2004) did not detect any fluroxypyr residues in sediments, ground water, or surface waters, even though fluroxypyr was one ofthe most heavily applied chemicals ofthe 33 

### measured (most of the other chemicals had some detections). Similarly, a Norwegian. study (Haarstad and Ludvigsen, 2007) did not detect fluroxypyrin any ground water samples obtained during the 9 years of monitoring; fkequent detections 

### of other chemicals also applied to nearby fields frequently yielded positive results, indicating that some compounds (other than fluroxypyr)were indeed entering ground water. Nevertheless, consideringthe lack ofrobust monitoring for fluroxypyr in the U.S. the Agency has instead used model results to make fate and effects determinations. CROP: Pome fruit Millet

3. 

### Measures of Terrestrial Exposure
a. Dietary Residues Peak (ug/L) 9.18 7.64



### The predicted maximum residues of fluroxypyr MHE that may be expected to occur on selected avian food items immediately following application arepresented in Table 9. 

### Maximum EECs were calculatedbased onmaximum label use rate for proposed new uses. 96 hr (ug/L) 7.34 5.85 21 Day (ug/L) 3.45 2.84 60 Day (ug/L) 1.36 1.11 90 Day (ug.'L) 0.92 0.74 Yearly 0.23 0.18

### b. Exposure Modeling for Non-Target Plants Table 9. Estimated environmentalconcentrations of fluroxypyr

### MHE on avian and mammalian food items.



### Terrestrial and semi-aquaticplant exposure characterization employs runoff and spray drift scenarios contained in OPP's Terrplant model. The TerrPlant model is described in fbrther detail in Appendix 

### B. Exposure calculations are based on a pesticide's water solubility and the amount ofpesticidepresent on the surface soil within the first inch of depth. For dry areas, the loading ofpesticide active ingredient from runoffto an adjacent non-target area is assumed to occur from one acre of treatment to one acre of non-target area; for semi-aquatic (wetland) areas, runoff is considered to occur from a larger source area with active ingredient loading originating from 10 acres oftreated area to a single acre of non-target wetland. Default spray drift assumptions are 1% for ground applications and 

### 5% for aerial, airblast, forced air, and chernigation applications. Terrestrial plant EECs for non-granular formulations are summarized in Table 10. 

### EECs for granular formulations are not presented because the label does not specify granular formulations for fluroxypyr MHE. It should be noted that Terrplant modeling was conducted for 1 application ofthe maximum single application rate for each crop. Crop

Pome millet

c. Spray Drift Analysis APPLICATIONS: Rate (Ibs./acre)/ Number / Interval 0.51110 0.12512114

Table 10. EECs for FluroxypyrMHE application at maximum use rate for uses on pome fruit and millet. Units in Ibs ailacre.



### AgDrift version 2.01 was used to estimate the exposure of downwind terrestrial and aquatic plants to fluroxypyr MHE from 

### the proposed new uses. AgDrift is a computer model developedby the SprayDrift 

### Task Force to evaluate off-site deposition ofpesticides applied by aerial, ground, and orchard blast sprayingtechniques, and for estimation ofbuffer zones Description Runoff to dry areas Runoff to semi-aquatic areas Spray drift Total for dry areas Total for semi-aquatic areas Estimated Environmental Concentration(EEC) (ppm) Short grass
120 120

Pome fruit EEC Millet EEC 0.005 0.00125 0.05 0.0125 0.005 0.00125 0.01 0.0025 0.055 0.01375 

# I Tall grass 5 5 24.17 Broadleafplantslsmall insects 67.50 29.66 Fruits/pods/ large insects 7.5 3.30needed to protect sensitive aquatic and terrestrial speciesfrom undesired exposures. For this assessment,AgDrift may be used to calculate the distance downwind of a treated field that would be needed to reduce exposure to below a no-observed-effect-level for terrestrial and aquatic plants. C. Ecological Effects Characterization In screening-levelecological risk assessments, the effects characterization section describes the types of effects on aquatic and terrestrial organisms, which result fi-ompesticide exposure. This characterization is based on registrant-submitted studies that describe information regarding acute and chronic effects toxicity for various aquatic and terrestrial animals and plants. Appendix C summarizesthe results ofthe registrant-submitted toxicity studies on fluroxypyr used to characterize effects for this risk assessment. The toxicity testing reported in this section is not an exhaustive survey of all species ofbirds, mammals, or aquatic organisms. Only a few surrogate species for both freshwater fish and birds are used to represent all freshwater fish (2000+) and bird (680+) species in the United States. For mammals, acute studies are usually limited to the Norway Rat or the House Mouse. Testing for reptiles and amphibians are not required. The risk assessment assumes that conclusions drawn from avian toxicity studies are applicable to reptiles. Similarly, conclusions drawn from studies conducted with fish are assumed applicableto amphibians. In general, categoriesof acute toxicityranging from "practically nontoxic" to "very highly toxic" have been established for aquatic organisms (based on 

### LCs0 values), terrestrial mammals (based on 

### LDS0 values), avian species (based on 

### LCs0values), and non-target insects (based on 

### LDSo values for honey bees) (U.S. EPA 2001). These categories are presented in Appendix 

### D.


### 1. Aquatic Effects Characterization Themost sensitive acute toxicity values associated with exposure of freshwater species to fluroxypyMHE and fluroxypyr are summarizedin Table 11. A more detailed summary of the aquatic toxicity data availableto characterize risks associated with fluroxypyr MHE and fluroxypyr exposureis given in Appendix A. RQ calculations for aquatic organismswill be done based the most sensitive fluroxypyrMHE and fluroxypyrtoxicity endpoints among fish, aquatic invertebrate, and aquaticplants. For example the freshwater fish acute RQ will be done based on the fluroxpyr MHE fish 

### LCs0of 13.2ppm ai because it is more sensitive than the most sensitive fluroxypyr freshwater fish acute toxicity 

### LCso (Table 12).

### The registrant has submitted toxicity studies for aquaticplants, fish and aquatic invertebrates for fluroxypyr

### MHE and fluroxypyr. The following is a brief discussion of the studies submitted. A 

### more detailed summary of the aquatic toxicity data availableto characterize risks associated with fluroxypyr

### MHE and fluroxypyr exposure is given in Appendix A. Table 11. Aquatic organism toxicity characterizations for fIuroxypyrMHE and its Herbicidal Degradate

a. Aquatic Animals Fluroxypyr Taxonomic Group
Freshwater Fish Freshwater Fish EstuarineMarine Fish EstuarineMarine Fish Freshwater Invertebrates Freshwater Invertebrates Marine EstuarineInvertebrates Marine Estuarine Invertebrates Aquatic nonvascular plants Aquatic nonvascular plants Aquatic vascular plants Aquatic vascularplants Note 1:This item is not

(1) Acute Effects Freshwater Fish aquatic plant toxicity endpoints. Note 2: This item is not applicable (NA) because there are no guideline aquatic plant chronic toxicity studies. Chemical Fluroxypyr FluroxypyMHE Fluroxypyr FluroxypyrMHE Fluroxypyr FluroxypyrMHE Fluroxypyr FluroxypyrMHE Fluroxypyr FluroxypyrMHE Fluroxypyr FluroxypyrMHE applicable (NA) because

Acute Toxicity 

### The registrant submitted 3 

### acceptable freshwater fish acute toxicity tests for fluroxypyr including a rainbow trout study, a bluegill sunfish study, and a golden orfe study. The LCsa Principal Acute Toxicity Endpoint LC50 = 14.3 ppm ai

= 13.2ppm ai No Data Available
> 0.087ppm ai EC50 > 100ppm ai EC50 > 0.109 pprn ai 51 ppm ai 0.068ppmai EC50 > 100ppm ai
0.29 ppm ai No Data Available >2.3 ppm ai the Agency does not Acute Toxicity Categories Slightlytoxic Slightly toxic NA Not determined Practically nontoxic Not determined Slightlytoxic Veryhighly toxic NA 

## '

NA 

## '

------------ NA 

## ' assign acute toxicity Principal Chronic Toxicity Endpoint No Data Available No Data Available No Data Available No Data Available No Data Available No Data Available No Data Available No Data Available NA
NA NA NA characterizationsto

### toxicities for these studiesranged from 14.3pprn ai - > 

### 100pprn ai. Thus, fluroxypyr is slightly to practically nontoxic to freshwater fish. The LC50 of 13.2 pprn ai (table 12)will be used to calculate the acute risk quotients for freshwater fish because it is the most sensitive toxicity freshwater fish acute toxicity endpoint among the available data for fluroxypyr MHE and fluroxypyr. Theregistrant submitted 2 freshwater fish acute toxicity tests for fluroxypyrMHE including an inland silverside and bluegill sunfish. The LCs0toxicities for these studies were 40 pprn and > 

### 0.63 pprn respectively. Fluroxypyr 

### MHE is slightlytoxic to freshwater fish. Freshwater Invertebrates Acute toxicity 

### The registrant submitted two acceptable freshwater invertebrate studies evaluating the acute toxicity of fluroxypyr on Daphnia magna 

### and two acceptable freshwater invertebrates studies testing the acute toxicity of fluroxypyrMHE. The ECsO toxicity values were greater than the highest values tested (up to 

### > 100pprn ai) for all the studies. Based on the results of these studies fluroxypyris practically nontoxicto freshwater invertebrates. RQs will not be calculated for freshwater invertebrates because the available toxicity studies demonstrated that fluroxypyr and fluroxypyr MHE ispractically nontoxicto freshwaterinvertebrates. MarineJEstuarineFish Acute Toxicity 

### The registrant submitted two marinelestuarine fish toxicity studies testingthe acute toxicity of fluroxypyrMHE on Atlantic silversideand sheepsheadminnow. The study testing Atlantic silverside was deemed supplemental. The study testing sheepshead minnow was deemed acceptable. The LC50 toxicity values ofthese studies were not determined because the LCsowas higher than the hghest concentrations tested which were 0.188 pprn ai and 0.087 pprn ai. respectively. Marine Estuarine Invertebrates Acute toxicity 

### The registrant submitted two acceptable marinelestuarine invertebrate studies testing fluroxypyr acute toxicity on the eastern oyster and grass shrimp. The ECS0 toxicity values for these studiesranged from 5 

### 1pprn ai 

### - > 

### 120pprn ai. These results demonstrate that fluroxypyris slightlyto practicallynontoxic to marinelestuarine invertebrates. The registrant has also submitted four marinelestuarine studies testing fluroxypyr 

### MHE acute toxicity on the eastern oyster, grass shrimp, and pink shrimp. Two ofthe studieswere deemed supplemental (one testing eastern oyster and the other testingpink shrimp) and the two other studies (one testing eastern oyster and the other testing grass shrimp) was deemed acceptable. The supplemental study testing eastern oyster MRID 440803 10was the only studythat 34

### produced an ECSo value. This value was 

### 0.068ppm ai The results ofthis study deemed fluroxypyrMHE as very highly toxic to marinelestuarine invertebrates. RQs for marine estuarine invertebrateswill be calculatedusing the fluroxypyrMHE most sensitive marine estuarine invertebrate acute toxicity value of 

### 0.068ppm a.i (2) Chronic toxicity 

### No chronic toxicity tests on aquaticorganisms have been submittedby the registrant. (3) Sublethal Effects 

### None ofthe available data report any sublethal toxic effects on aquatic organisms. (4) Field Studies 

### No field studies with aquatic animals are available. b. Aquatic Plants 

### The registrant submitted several acceptable aquatic plant toxicity studies for fluroxypyrMHE and many of it degradates includingfluroxypyr, fluroxypyrMHE, 4-amino-3-5,5-dichloro6-fluoro-2-pyridinol,

### 4-arnino-3,5-dichloro-6-fluoro-2-methoxypyridine. Appendix A provides further details of all the aquatic plant toxicity studies submitted. 2. Terrestrial Effects Characterization 

### The most sensitive acute and chronic toxicity values associated with exposureofterrestrial species to fluroxypyrMHE and fluroxypyr are summarizedin Table 12. 

### A more detailed summary ofthe terrestrial toxicity data availableto characterize risks associated with fluroxypyrMHE and fluroxypyr is given in Appendix A.

Table 12. Fluroxypyr MHE and Fluroxypyr Most Sensitive Toxicity Values for TerrestrialOrganisms. Reference (Classification) Exposure Scenario Exposure Duration Species
Mammals Most Sensitive Toxicity Value

MRID 44080329
MRD44080321 Acute(Dosebased) Chronic

(Dosebased) Oral Dose
2 generation Rat

R~~ LDro790 rng ailkg (Fluronypyr MHE)
NOAEC = 10000ppm ai (FluroxypyrMHE)a. Terrestrial Animals Birds

The 

### EPA examines two endpoints, the LD50and LC50, when assessing the acute risk to birds and mammals, and generally uses the endpoint that is most sensitive or which represents the scenario best. The LD50may give a better indication of inherent toxicity than the LCsoin cases where 

### a pesticide is not too palatable, and animals simply avoid eating the resource. The LDsomay also be more representativeof animals that gorge when feeding. LDso >2000 mg ailkg (Fluroxypyr)

LCSo> 5620 ppm ai(F1uroxypyrand FluroxypyrMHE) LOAEC = 500 ppm ai NOAEC =250 ppm a1 (FluroxypyrMHE) Single oral dose

days

N,A Acute(Dosebased)

Acute(Dietarybased) Chronic(Dietarybased) MRID 40244514 and MRID 402445 15

MRTDs 42137302 and

42137301

MRID 42137304 Northern bobwhite quail and Mallard

Duck Mallard

Duck
Mallard

Duck
Plant ToxicityMRID 44080335 sing1e application single application Cucumber

Onion Tier I1 seedling emergenc

Plant Toxicity NOAEC = 0.03 1 Ibs. ailacre EC25 = 0.075 lbs. aiiacre (FluroxypyrMHE)

NOAEC = 0.124 lbs. adacre EC25 = > 0.25 Ibs. ailacre (FluroxypyrMHE) Dicot Monocot

MRID 44080335 single application single application tomato

and sunflower

Onion Vegetative Vigor

Non-target BeneficialInsects NOAEC = 0.001 Ibs. ailacre EC25 = 0.004 lbs. ailacre NOAEC = 0.062 lbs. aiiacre. EC25 = 0.124 lbs. ailacre (FluroxypyrMHE) Dicot Monocot

MRID 42137314 >25 uglbee ai (FluroxYPyr) 96 hrs Acute Contact Toxicity Honey bee @pis mellifera)The registrant submitted studies testing fluroxypyr MHE and fluroxypyr on birds, bees, and mammals. 

### 1) Acute Effects Birds The registrant submitted studies submittedtwo avian acute oral toxicity studies testing fluroxypyr on mallard duck and bobwhite quail. One ofthe studies was deemed acceptable, and the other study was deemed supplemental. Both studiesresulted in LDs0values greater than 2000 mglkg. Thus,based on the results of this study fluroxypyr MHE and fluroxypyr are practically nontoxic to birds on an acute oral dosebasis. The registrant also submitted two acceptable avian dietary acute dietary studies testing fluroxypyr on bobwhite quail and one acceptable avian acute dietary study testing fluroxypyr MHE on mallard duck. All these studies demonstrated that fluroxypyr and fluroxypyrMHE were practically nontoxic to birds (LC50 

### > 5000 pprn ai). 

### Mammals There is one registrant submitted acute oral MRID studyin rats for fluroxypyr MHE (MRID 44080321). A LDsoof 3 160mgkg (practically nontoxicto mammals) was obtained in the study.


### 2) Chronic Effects Birds There are two acceptable registrant submitted guideline avian reproductive toxicity studies testing Fluroxypyr MHE on northern bobwhite quail and mallard duck The NOEAC for the studies were 5620 pprn ai and 250 pprn ai respectively. There were no endpoints significantly affected in the northern bobwhite quail study at the highest concentrations tested and the endpoints affected in the mallard duck included egg yolk peritonitis in hens at a NOEAL of 250 ppm. 

### Mammals The registrant submitted one reproductive toxicity study 0x1 rats. The study results yielded 

### a parental toxicityNOAEL of 1000ppm, a reproductive NOEAL of 7500 ppm, and a pup
. survival and weight gain NOEAL of 10,000pprn (MRID 44080321). 373) Sublethal Effects None of the terrestrial animal acute toxicity studies report any significant sublethal effects.
4) Field Studies No field studies were submitted to the Agency. 

### b. Terrestrial Plants Terrestrial Tier I1 seedling emergence and vegetative vigor studies are required for all low dose herbicides (those with the maximum use rate

# <0.5 lbs ai /A) and any pesticide showing a negative response equal to or greater than 25% in Tier I tests. The available terrestrial plant toxicity data include acceptableregistrant submitted tier I1 vegetative vigor and tier I1 seedling emergence studies forboth the formulated product of fluroxypyrMHE and fluroxypyr. Results of the acceptable Tier I1 seedling emergencetoxicity study on fluroxypyr MHE demonstratedthat the most sensitivetested species was cucumber. The EC25and the NOEC for cucumber are 0.075 and 0.03 1lb ai/A. The results of this study also demonstratedthat fluroxypyrMHE is generally not toxic to monocots at 0.25 lb ai/A. The results of the acceptable tier I1 vegetative vigor toxicity testing on a formulated product of fluroxypyrMHE showed the most sensitive species was cotton. Based on the most sensitiveparameter, phytotoxic symptoms, 25% inhibitionwas predicted to occur at a dose of 0.0012 lb ai/A. The no observed effect level (NOEL) for cotton was 0.0010 lb ai/A. The tier I1 seedling emergence study testing fluroxypyr (which was deemed as supplemental) showed that the most sensitive ofthe six species tested is cotton, which has an EC25of 0.025 lb ai/A. This is approximately 5 times lower than the cotton EC25 for fluroxypyr MHE. The tier I1 vegetative vigor study testing fluroxypy (which was deemed as supplemental) suggested that fluroxypyr acid is more toxic to vegetative vigor than fluroxypyr MHE. The most sensitive of the six species in the fluroxypyr acid study is soybean which produced 

### an EC25of 0.00067 lb ai/A. This is approximately 12times lower than the soybeanEC25 for fluroxypyrMHE.

### IV. RISK CHARACTERIZATION Risk characterizationis the integration of exposure and effects characterizationto determine the ecological risk from the use of fluroxypyr MHE and the likelihood of effects on aquatic life, wildlife, and plants based on varying pesticide-use scenarios. The risk characterization provides estimations and descriptions of the risk; articulates risk assessment assumptions, limitations, and uncertainties; synthesizes an overall conclusion; and provides the risk managers with informationto make regulatory decisions.


### A. Risk Estimation

## - Integration of Exposure and Effects Data Results of the exposure and toxicity effects data are used to evaluate the likelihood of adverse ecological effects on non-target species. For the screening risk assessment of fluroxypyrMHE and fluroxypyr, the RQ method as described in Section 1I.Eis used to compare exposure and measured effects data. The RQs are compared to the Agency=s LOCs. These LOCs are listed in Section 1I.E and are the Agency=sinterpretive policy to analyze potential risk to non-target organisms and assess the need to consider regulatory action. These criteria are used to indicatewhen a pesticide=s directed label use has the potential to cause adverse effects on non-target organisms.
1. 

### Non-target Animals
Peak EECs were comparedto acute measures of effect for fluroxypyrto derive acute RQs for fish, and invertebrates.,Peak me& 2 

### 1 -day and 60-day EECs could not be used to calculate chronic RQs for invertebrates and fish, respectively, because no chronic toxicity data was submittedby the registrant or available in the open literature. Results of the RQ calculations demonstrate the level of concern is only exceeded for acute risk to marinelestuarine invertebrates (Table 13). 

### Table 13. Acute and chronic RQs for non-listed fish and aquatic invertebrates using the PRZM-EXAMS EECs

Use site Taxa

Freshwater fish Acute EEC @pm)

0.009 Chronic 21 day160 day EEC @pm)A

0.00341 0.0014 Acute TOX. @pmai)

13.2 Chronic Tox. @pmai)

No data available RQa @EC/Tox.) Acute @OC exceedances are in bold)

0.0006 Chronic @OC exceedan ces are in

bold) NAfishrespectively. The LOC for acute risk is not exceeded. The acute risk quotient value could not be calculatedfor freshwater invertebrates because the EC50value for freshwater invertebrates > 100ppm a.i which was the highest concentration. This study demonstratedthat fluroxypyr is practically nontoxic to freshwater invertebrates. Thus, EFED does not expect fluroxypyrto pose a significantrisk to freshwater invertebrates that will exceed the Agency LOC.

The LOC for acute risk to estuarine marine invertebratesis exceeded. Use site

Pome

~ill~t

A The 2 1

b. 

### Aquatic Plants Aquatic plant RQ's are calculated by 

### dividing the peak EEC 

### values for the proposed uses by 

### the acute EC5() and NOAEC toxicity endpoints for risk to nonendangered and endangered vascular plants, and non-vascular plant to calculate acute RQs to non-listed aquaticplant species The Table 14

### below lists the results of the RQ calculations. Based on these calculations the level of concern is not exceeded for risks to aquaticnonvascular or vascular plants. Taxa

Freshwater invertebrate Estuarine fish
Estuarine invertebrate Freshwater fish Freshwater invertebrate Estuarine fish Estuarine invertebrate day EEC and the Acute EEC @pm)

0.009 0.009

0.009 0.008
0.008 0.008 0.008 60 day EEC Chronic 21 day160 day EEC @pm)A

0.00341 0.0014 0.00341 0.0014 0.00341 0.0014 0.00281 0.00074 0.00281 0.00074 0.00281 0.00074 0.00281 0.00074 values are Acute Tox. @pmai)

> 100
No endpoint available 0.068 13.2

> 100
No data available 51 used to calculate Chronic Tox. (ppm ai)

No data available No data available
No data available No data available No data available No data available No data available chronicrisk RQa Acute &OC exceedances are in bold)

NoLOC Exdeedance NA

0.13

0.006 NoLOC Exdeedance NA 0.00016 quotients for (EECITox.) Chronic

(LOC exceedan ces are in

bold) NA NA

NA NA
NA NA NA invertebrates andA risk quotient value could not be calcuiated for aquatic vascular plant risk because the aquatic vascular plant ECsO value was greater than the highest concentration tested which was 2.3 ppm. An aquatic vascular plant ECS0 value > 2.3 ppm ai is far below the Agency LOC based on an acute EEC of 0.009 ppm. 

### Table 14. Acute RQs for non-listed aquatic plants

c. TerrestrialAnimals Use site

Pome

Millet

A Below the



### Birds 

# - The T-REX model (version 1.2.3)is used to estimate risk to birds in fields treated with fluroxypyrMHE. The TREX model predicts peak EECs and uses these values in combination with the most sensitive acute and chronic toxicity values availableto calculate risk quotients. Because fluroxypry MHE and fluroxypyr were practically nontoxic to birds on an acute dietaryand acute oral basis (Appendix A), and there were no mortalities in any of the fluroxypyMHE or fluroxypy avian acute toxicity studies, EFED does not expect fluroxypyrto pose a significant risk to birds. Especially, since the estimated exposure values (Table 8) 

### are several magnitudes lower than the concentrations which demonstrated that fluroxypyrMHE and fluroxypyr 

### arepractically nontoxicto birds. Thus, based on this conclusion ofno acute risk to birds, EFED did not calculate any acute risk quotients for birds (Table 15). The table below demonstrates the results ofthe chronic RO 

### calculations for birds. Taxa

Aquatic nonvascular plants Aquatic vascular plants Aquatic nonvascular plants Aquatic vascular plants level of concern Acute EEC @pm)
0.009

0.009
0.008

0.008 for risk to Aquatic plant EC50 (PP~ ail 0.29

> 2.3
0.29

> 2.3 aquatic plants Aquatic plant @pmail 0.18

1.2
0.18

1.2 RQ*(EEC/T~&) Non -listed aquatieplant RQ 0.03

Below LOC
0.02

Below LOC Listed aquatic plant RQ
0.05 A
0.0075 A
0.04 A

0.0067

### Table 15. Chronic RQs calculations for birds (Upper Bound Kenaga) Use site Food habits chronic


# I I tall grass 

## 1 0.22 short grass 0.48 A

I fruitslpods/lginsects 0.03 MILLET 

# I I broadleaf plantslsm insects 

## 1 0.27

short grass tall grass



### Mammals 0.21 A 0.10 broadleaf plants/sm insects ~ts/pods/lg insects



### The T-REX model (version 1.2.3) was used to estimate risk to mammals in fields treated with fluroxypyr MHE. 

### Peak EECs were compared to the acute and chronic toxicity endpoints for the rat to calculate acute and chronic RQs to non-listed mammalian species. The respective LDsoand chronic endpoint values are 125mag (females) and 25 mag (mortality). Results are listed in Table 16. 

### Based on the RQ calculations, there are no exceedances for the Agency LOC for mammals. 0.12 0.01 Note A The LOC of 1isnot exceeded for chronic risk to birds



### Table 16. Acute and chronic RQs for non-listedmammals (Upper Bound Kenaga) Use site

POME FRUIT Food habits

0.05 A

0.02 short grass
tall grass Chronic dietary based RQs dose-based RQs

0.01

< 0.01 0.05

0.01 15g

< 0.01

< 0.01 acute 0.02

0.01 < 0.01

<0.01 chronic 35g

< 0.01

< 0.01 acute lOOOg chronic acute Chronic0.2 for acute restricteduse, 0.1 for acute endangered species. Note B: The chronic RQ is below the Agency LOC of 1for chronic risk to mammals. Note ': The RQ value is below the Agency LOC for risk to mammals and is below the range of values that can be displayedby TREX. 

### d. Non-target Upland and Wetland/Riparian Plants Peak EECs were calculated using TerrPlant (version 1 .O) 

### and compared to the lowest EC25 (Most Sensitive ToxicityValues, Table 12)to calculate RQs for non-listed terrestrial plant species. Fluroxypyr MHE RQ results are listed in Table 17 

### and 18. Based on the RQ calculations for the fluroxypyr MHE uses on apple and millet, the LOC is only exceeded for risks to dicot species. Risk quotients for FluroxypyrMHE degradates, fluroxypyrcould not be calculatedbecause, the endpoint values produced in this studywere deemed as inappropriate for use in a risk assessment because of several study deficiencies.Dicot listed 0.44 1.25 *If RQ > 1 .O, the LOC is exceeded, resulting in potential for risk to that plant group.


### B. Risk Description 

## - Interpretation ofDirect Effects 

### Summaryofmaior conclusions for non-listed species
a. Risk to AquaticAnimals and Plants Acute 

### Risk Based on the RQ calculations the only exceedances of the LOC are for acute risk to marine estuarine invertebrates. This LOC exceedance is only applicable to non Federally listed marinelestuarineinvertebrates since there are no listed marinelestuarine invertebrates. Because the acute RQs for other aquatic animals' freshwater fish and aquatic invertebrate are several orders of magnitude below the Agency LOC and because fluroxypyr MHE and fluroxypyris only slightlyto practically nontoxic to fish and aquatic invertebrate,

### EFED does not expect fluroxypyr to pose a 

### significant acute risk to fish andlor aquatic invertebrate. The RQ calculations for fluroxypyr and fluroxypyr MHE risk to aquatic plants also demonstrateRQ values several orders of magnitudes below the LOC for risk to aquatic plants. Thus, fluroxypyr is not expectedto pose a significant risk to aquatic plants.

### ChronicRisk EFED could not assess the chronic risk to freshwater and estuarinelmarinefish and invertebrates at this time due to lack of registrant submitted and open literature studies. Aquatic plant risk Based on the RQ calculationsfor fluroxypyrthere are no LOC exceedances for aquatic plants and algae. Thus, EFED does not expect fluroxypyrMHE or fluroxypyr to pose significant risk to aquatic plants or algae. The registrant submitted toxicity data for aquatic plant and algae on the degradates, 

### 4-Amino-3,5-dichloro-6-fluoro-2-pyridinol and 4-Amino-3,5- dichloro-6-fluoro-2-methoxypyridine. 

### Risk quotients are not calculated for these degradates because of the lack environmental fate data on the degradates. However, EFED does not expect these degradatesto pose a significant risk to aquaticplants or algae because the toxicity data demonstratedthat aquatic plants and algae were less sensitiveto these than to fluroxypyr,which itself does not exceed the Agency level of concern for risk.
b. Risk to Terrestrial Animals In the terrestrial environment fluroxypyrMHE is also expected to degradeto fluroxypyr. However, fluroxypyrMHE degradation to fluroxypyrin a terrestrial environment may not occur as rapidly as in aquatic environments, and potential exposure exists immediately upon application (unlike the aquatic environment, where exposure is unlikely prior to a runoffinducing rain event).. Thus terrestrial animals are expected to be readily exposed to fluroxypyrMHE and fluroxypyr. Consequently,this risk assessment characterizes the risk of fluroxypyrMHE and fluroxypyrto terrestrial animals exposed to these chemicals. AvianAcute Risk Although avian acute risk quotientswere not calculated, EFED does not expect fluroxypyror fluroxypyrMHE to pose a significant acute risk to birds because the avian acute toxicity test demonstratedthat both fluroxypyr MHE and fluroxypyr were practically nontoxic to birds on an acute oral and acute dietary basis at concentrations that were several orders ofmagnitude higher than the estimated concentrations expected in a terrestrial environment. Avian ChronicRisk EFED does not expect fluroxypyr MHE to pose any significantrisk to avian species because the RQ values were well below the LOC for chronicrisk to birds. Currently, EFED is unable to determine the chronicrisk of fluroxypyr to birds because no fluroxypyr avian chronic toxicity data are available. However, Agency believes this risk to probably be low, based upon absence of chronic avian risk fiom fluroxypyr-MHE and lack of chronic risk to mammals from fluroxypyr. Thus, avian chronic toxicological studies for fluroxypyr may not be necessary. 45Mammalian Acute Risk Currentlythe Agency has mammalian acute and chronic toxicity data for fluroxypyr only and not fluroxypyrMHE. Based on the fluroxypyrmammalian risk quotient calculations, fluroxypyris not expected to pose significant acute or chronic risk to mammals especially since the RQ values are well below any LOC for risk to mammals. c. Risk to Plants Based on the terrestrialplant RQs, spray drift from flwoxypyr MHE applicationto pome fruit poses a risk above the LOC for listed and nonlisted dicot plant species. The RQs also specifically demonstrate that spray drift from fluroxypyrMHE use on millet poses a risk above the LOC for listed dicot species only. Additionally, based on supplemental data, fluroxypyris more toxic to emerging seedlings than fluroxypyrMHE. The most sensitive of the six species tested is cotton, which has an EC25 of 0.025 lb ai/A. This is approximately5 times lower than the cotton ECz5 of 0.125 lbs. ai/A for fluroxypyr MHE (Appendix 

### B). However, the endpoint values produced in this study were deemed as inappropriatefor calculating risk quotientsbecause of several study deficiencies. Thus, EFED assumes fluroxypyrmay pose a greater risk to terrestrial nontarget plants. However, EFED needs adequate terrestrial plant toxicity data testing fluroxypyrin order to more effectively determine the risk of fluroxypyr to terrestrial plants. C. Federally Threatened and Endangered (Listed) Species Concerns a. Action Area For listed species assessment purposes, the action area is considered to be the area affected directly or indirectlyby the Federal action and not merely the immediate area involved in the action. At the initial screening-level, the risk assessment considersbroadly described taxonomic groups and so conservatively assumes that listed species within those broad groups are collocated with the pesticide treatment area. This means that terrestrial plants and wildlife are assumed to be located on or adjacent to the treated site and aquatic organisms are assumed to be located in a surfacewater body adjacent to the treated site. The assessment also assumes that the listed species are located within an assumed area, which has the relatively highest potential exposure to the p.esticide,and that exposures are likely to decrease with distance from the treatment area. The Use Characterization ofthis risk assessment presents the pesticide use sites that are used to establish initial collocation of species with treatment areas. If the assumptions associated with the screening-level action area result in RQs that are below the listed species LOCs, a "no effect" determination conclusion is made with respect to listed species in that taxa, and no further refinement of the action area is necessary. Furthermore, RQs below the listed species LOCs for a given taxonomic group indicate no concern for indirect effectsupon listed species that depend upon the taxonomic group 46

### covered by the RQ as a resource. However, in situationswhere the screening assumptions lead to RQs in excess ofthe listed speciesLOCs for a given taxonomic group, a potential for a "may affect" conclusion exists and may be associated with direct effects on listed species belonging to that taxonomic group or may extend to indirect effects upon listed species that depend upon that taxonomic group as a resource. In 

### such cases, additional information on the biology of listed species, the locations ofthese species, and the locations ofuse sites could be considered to determine the extent to which screeningassumptions regarding an action area apply to a particular listed organism. These subsequent refinement steps could considerhow this informationwould impact the action area for a particular listed organism and may potentially include areas of exposure that are downwind and downstream ofthe pesticide use site. b. Taxonomic Groups potentially at Risk 

### The Level I 

### screening assessment process for listed species uses the generic taxonomic group-based process to make inferences on direct effect concerns for listed species. The first iteration ofreporting the results ofthe Level I 

### screening is a listing ofpesticide use sites and taxonomic groups for which RQ calculations reveal values that meet or exceedthe listed species LOCs. In the majority of cases, the screening-level risk assessment process reports RQ calculations for the following broad taxonomic groupings: Birds (also used as surrogate for terrestrial-phaseamphibians and reptiles) Mammals Freshwater fish (also used as a surrogatefor aquaticphase amphibians) Freshwaterinvertebrates Estuarine and marine fish Estuarine and marine invertebrates Terrestrial invertebrates Terrestrial plants Aquatic plants (1) Discussion of Risk Quotients Risk Quotients Based on Maximum Application Rate Scenarios 

### As mentioned above, there are fluroxypyr

### MHE LOC exceedances for dicot terrestrial plants. These exceedances range from 1.75to 2.55. (2) Probit Dose-Response Relationship 

### A. Probit Slope Response Relationship on the Listed Species Levels of Concern 

### The Agency uses the probit doseresponse relationship as a tool for providing additional information on the listed animal species acute levels of concern (LOC). The acute listed

### species LOCs of 0.1 and 0.05 are used for terrestrial and aquatic animals, respectively. As part of the risk characterization,an interpretation of acute LOCs for listed species is discussed. This interpretationispresented interms of the chance of an individual event (i.e., mortality or immobilization) should exposure at the estimated environmental concentration actually occur for a species with sensitivityto fluroxypyr with the acute toxicity endpoint selected for RQ 

### calculation.To accomplishthis interpretation, the Agency uses the slope of the dose response relationship availablefrom the toxicity studyused to establish the acute toxicitymeasurement endpointsfor each taxonomic group. The individual effects probability associated with the LOCs is based on the mean estimate ofthe slope and an assumptionof a probit doseresponse relationship. In 

### addition to a single effects probability estimatebased on the mean, upper and lower estimates ofthe effects probabilityare also provided to account for variance in the slope. Theupper and lower bounds ofthe effects probability arebased on available information on the 95% confidence interval of the slope. A 

### statement regarding the confidencein the applicabilityofthe assumed probit dose response relationship for predicting individual event probabilitiesis also included. Studies with good probit fit characteristics (i.e., statistically appropriate for the data set) are associated with a high degree of confidence. Conversely, a low degree of confidence is associated with data fiom studies that do not statistically support aprobit dose response relationship.In 

### addition, confidencein the data set may be reduced by high variance in the slope (i.e., large 95% confidence intervals), despite good probit fit characteristics. Individual effect probabilities are calculated based on an Excel spreadsheet tool IECV1.l (Individual Effect ChanceModel Version 1.1) developedby EFED ofthe U.S. 

### EPA, OPP, Environmental Fate and Effects Division (June 22,2004). Themodel allows for such calculationsby entering the mean slope estimate (and the 95% confidence bounds ofthat estimate) as the slopeparameter for the spreadsheet. In 

### addition, the LOC (0.1 for terrestrial animals and 0.05 for aquatic animals) is entered as the desired threshold.The followingis the summary of screening assessment of listed terrestrial and aquatic species Levels of Concern using probit slope relationship. Table 19 

### Probit Slope and 

### Effects Probabilities Listed Sp. Acute Tox. End Point LD50/EC50/Lc50 Probit x2value Mean Slope Slope Confid. Interval Effect probabilityp MallardDuck No Mortalities

NA NA NA NA Rat 3160

NA 4.5* NA 3.4E-06 Daphnia No mortalities

NA NA NA NA Bluegill 14.3

NA 4.5" NA 2.39E-09Based on the above table, the results of probit slope analysis show that chance of individual effectis minimal.The effect probability p(Z) ranges is 3.40E-06 for rat and 2.40E-09 for bluegill. Since a slope value is unavailable, a default value of 4.5 has been assigned in the case ofrat, and bluegill. Furthermore, if they sharethe same slope and LOC values (0.1 or 0.05), they will have the same effect probability and hence the chance of individual effect. (Z) (Confidence Interval) Chance of Individual effect (11~)

1. Terrestrial Listed Species (Mallard duck and rat) There were no mortalities in the avian toxicity studies. Therefore 

### a probit analysis was not performed for birds. Calculations for rat yielded an effectprobability (z value) of 3.40E-06 and individual mortality probability of 1in 2.94E+05. 

### * default slopevalue (4.5) had to be used due to lack of information NA

2. Aquatic Listed Species (daphnia and rainbow trout) There were no mortalities in the aquatic invertebrate toxicity studies. Therefore a probit analysis was not performed for aquaticinvertebrates. Calculations for rat yielded an effect probability (z value) of 2.39E-09 and individual mortality probability of 1in 4.18E+08. 2.94+05

(3) Indirect Effects Analysis The Agency acknowledges that pesticides have the potential to exert indirect effects upon the listed organismsby, for example, perturbing forage or prey availability, alteringthe extent of nesting habitat, creating gaps in the food chain, etc. NA



### In conducting a screen for indirect effects, direct effect LOCs for each taxonomic group are used to make inferences concerning the potential for indirect effectsupon listed species that rely upon non-listed organismsin these taxonomic groups as resources critical to their life cycle. 4.18E+08

Screening-levelacute RQsfor terrestrialplants and marine estuarine invertebrates are above the LOCs. The Agency considers this to be indicative of a potential for adverse effects to those listed specieswithin the action area that rely either on a specificplant species (plant species obligate) or multipleplant species (plant dependent) for some important aspect of 49their life cycle. The Agency may determine if listed organisms, for which plants were a critical component oftheir resourceneeds, are within the action area. This will be accomplishedthrough a comparison of Service-provided species profiles and listed species location data. Ifno listed organisms that are either plant species obligates or plant dependent reside within the action area, a no effect determination on listed species will be made. If plant species obligate or dependent organisms reside within the pesticide use area, the Agency will consider temporal and geographical nature of exposure, and the scope of the effects data, to determineif anypotential effects can be determined to not likely adversely affect a plant species obligate or dependent listed organism. EFED concludesthat due to terrestrial plant and marine estuarine invertebrateLOC exceedances (usingmaximum application rates), there may be a concern for indirect effects to the following groups of organisms in the area for the fluroxypyr 

### MHE regulatory action: Freshwater fish Freshwater amphibians Freshwater invertebrates Terrestrial invertebrates Terrestrial plants and plants in semi-aquaticareas Birds Mammals Reptiles For listed species that may potentiallybe affected directly and/or indirectlyby the Federal action, seeAppendix C (Locates runs). 

### (4) CriticalHabitat In the evaluation ofpesticide effects on designated critical habitat, considerationis given to the physical and biological features (constituent elements) of a critical habitat identifiedby the U.S Fish and Wildlife and National Marine Fisheries Services as essential to the conservationof a listed species and which may require special management considerationsor protection. The evaluation of impacts for a screening level pesticide risk assessment focuses on the biological features that are constituent elements and is accomplished using the screening-level taxonomic analysis (risk quotients, RQs) and listed specieslevels of concern (LOCs) that are used to evaluate direct and indirect effects to listed organisms. The screening-level risk assessment has identified potential concerns for indirect effects on listed species for those organisms dependant upon terrestrial plants and marine estuarine invertebrates. 

### Inlight of the potential for indirect effects, the next step for EPA and the Service(s)is to identify which listed species and critical habitat are potentially implicated. Analytically,the identificationof such species and critical habitat can occur in either oftwo ways. First, the agencies could determine whether the action area overlaps critical habitat orthe occupied range of any listed species. If so, EPA would examine whether the pesticide's potential impacts on non-listed species would affect the listed species indirectly or directly affect a constituent element of the critical habitat. Alternatively, the agencies could determine which listed species depend on biological resources or have constituent elementsthat fall into the taxa that may be directly or indirectlyimpacted by the pesticide. Then EPA would determine whether use of the pesticide overlaps the critical habitat or the occupied range of those listed species. At present, the information reviewedby EPA does not permit use of either analytical approach to make a definitive identificationof species that are potentially impacted indirectly or critical habitats that is potentially impacted directlyby the use ofthe pesticide. EPA and the Service(s) are working together to conduct the necessary analysis. This screening-level risk assessment for criticalhabitat provides a listing ofpotential biological features that, if they are constituent elements of one or more critical habitats, would be ofpotential concern. These correspondto the taxa identified above as being of potential concern for indirect effects and include the following: fish and aquatic invertebrates, amphibians, birds, mammals, and reptiles. This list should serve as an initial step in problem formulationfor further assessment of critical habitat impacts outlined above, should additionalwork be necessary.

c. Co-occurrence Analysis The goal of the analysis for co-location is to determine whether sites ofpesticide use are geographically associated with known locations of listed species. At the screening level, this analysis is accomplished using the LOCATES database. The database uses location information for listed species at the county level and compares it to agriculturalcensus data for crop production at the same county level of resolution. The product is a listing of federally listed speciesthat are located within counties ktiown to produce the crop upon which the pesticide will be used. Because the Level I screening assessment considers both direct and indirect effects across generic taxonomic groupings, it is not possible to exclude any taxonomic group from a LOCATES database run for a screening risk assessment. Given the extent of fluroxypyr usage across the U.S. and\theexpected large number of listed species that are likely,tooccur in counties where this pesticide is used, a list of endangeredlthreatened species and crop acreage at the county level for the taxonomic groups and crops of concern is not included in this phase of the risk assessment process. Appendix C provides a list of endangeredlthreatened species at the state level for the taxonomic groups of concern. EFED assumes that listed species may be at risk for the states where pome fruit and millet use occurs according to LOCATES, but where fluroxypyr usage is not reported necessarilyby BEAD Usage Report. The registrant must provide information on the proximity of Federallylisted freshwater invertebrates, terrestrial and aquatic plants, birds, mammals, amphibians, crustaceans, reptiles, arachnids, insects, snails, and clams to the fluroxypyr use sites. This requirement may be satisfied in one ofthree ways: 1)having membershipin the FIFRA Endangered Species Task Force (Pesticide Registration [PR] Notice 2000-2); 2) citing FIFRA Endangered Species Task Force data; or 3) independently 51producing these data, provided the information is of sufficient quality to meet 

### FIFRA requirements. The informationwill be used by the OPP Endangered Species Protection Program to develop recommendations to avoid adverse effectsto listed species.

### V. 

### REFERENCES EPA's Wildlife Exposure Factors Handbook (1996) Haarstad, 

### K. and G.H. Ludvigsen (2007) Ten Years of Pesticide MonitoringinNorwegiam Ground Water. Ground Water Monitoring & 

### Remediation 27 (3), 

### 75-89. Hoerger and Kenaga (1972) as modified by Fletcher et al. (1994) Waugh, P.S. and A.V. Padovan (2004) Review of Pesticide Monitoring, Use and Risk to Water Resources in the Darwin Region. Report No. 02/2004D,Natural Resource Management Division Conservation and Natural Resources Group.Appendix A a. Toxicity to Terrestrial Animals 

### I. Birds, Acute and Subacute 

### An acute oral toxicity studyusingthe technical grade of the active ingredient (TGAI) is required to establish the toxicity to birds. The preferred test species is either mallard duck (a waterfowl) or bobwhite quail (an upland gamebird). The registrant submitted acute oral avian toxicity tests on fluroxypyr acid and fluroxypyr MHE. The tests indicated that fluroxypyr acid and fluroxypyr MHE arepractically nontoxic to avian species on an 

### acute oral basis. Results and further details ofthese tests are tabulatedbelow.

Avian Acute OralToxicity MRIDNo. Study Species Chemical LD50 (mglkg Toxicity Category Authorh'ear Classification1 ail Mallard duck Fluroxypyr acid >2000 Practically nontoxic 40244514 Supplemental Bobwhite quail Fluroxypyr acid >2000 Practically nontoxic 402445 15 Acceptable Mallard duck Fluroxypyr MHE >2000 Practically nontoxic 402445 16 Acceptable Bobwhite quail Fluroxypyr MHE > 5000 Practically nontoxic 4024451 7 Acceptable Bobwhite quail Fluroxypyr MHE >2000 Practically nontoxic 40244546 Acceptable ~cceptabli (study satisfiesguideline). 

### Two subacute dietary studies using the TGAI are required to establish the toxicity of the TGAI to birds. The preferred test species aremallard duck and bobwhite quail. The registrant submitted subacute dietary tests on the parent compound, fluroxypyrMHE, and the fluroxypyr acid. Fluroxypyr MHE and fluroxypyr acid is practically nontoxic to avian species on an acute dietary basis. Results ofthese tests and further details are tabulated below.

Avian Subacute Dietary Toxicity 5-Day LC50 MRID No. Species Chemical (PP~ ai) Toxicity Catego~y AuthorNear Study Classification1 Bobwhite quail Fluroxypyr acid > 5000 Practically nontoxic 40244547 Acceptable Mallard duck Fluroxypyr > 5620 Practically nontoxic 42137302 Acceptable acid Mallard duck FluroxypyrMHE > 5620 Practically nontoxic 42137301 Acceptable Acceptable (study satisfiesguideline). Supplemental (study is scientifically sound, but does not satisfyguideline.ii. Birds, Chronic 

### The registrant has submitted a bird reproductive toxicity studies testing the fluroxypyr 

### MHE on bobwhite quail, and mallard. Details ofthe studies are tabulated below.

Avian ChronicToxicity Study NOEC LQEC Endpoints affected MRID No. Species Chemical Study Classification' % ai Toxic Toxic Endpoint Endpoint (PP~ ai) (ppmai) 42137303 Northern Bobwhite Fluroxypyr 5620 > 1000 None Acceptable MHE 42137304 Mallard Duck Fluroxypyr 250 500 Egg yolk Acceptable MHE peritonitis in hens
iii. Mammals, Acute and Chronic 

### Wild mammal testing is required on a case-by-case basis, depending on the results of lower tier laboratory mammalian studies, intended use pattern and pertinent environmental fate characteristics. In most cases, rat or mouse toxicity values obtained from the Agency's Health Effects Division (HED) substitute for wild mammal testing. These toxicity values arereported below.

Table 8. Chronic Species Laboratory rat (Rattus norvegicus) NOEL/LOEL O?P~ ail 1000 ppm

750 ppm 10,000 ppm MRU) No.
44080321 Mammalian Toxicity Test Type 2-generation l-eproduction

Acute Oral Toxicity for fluroxypyr for Fluroxypyr Endpoint
Parental toxicity ((increased kidney weight with correspondinggross and microscopic findings including papillary atrophy, edema, necrosis, hypqlasia ofthepelvic epithelium, degenem!ion/regenemtion ofthe tubularepithelium,tubulo-intersftial nephritis, and dilatation ofthe tubules)) Reproduction Pup sunrivaland weight gain

LD50 a.i
790 mdkg ai Species Laboratory rat (Rattus norvegicus) MRID
44080329 Test Type Acute oral % ai
25.6% Endpoint Mortality

### The results indicate that fluroxypry

### MHE is practically nontoxicto smallmammals on an acute oral basis.
iv. Insects 

### A honey bee acute contact study using the TGAI 

### is required because the proposed uses may result in honeybee exposure. Results ofthis test are tabulated below.

Nontarget Insect Acute Contact Toxicity LD50 MRID No. Study Species Chemical (ug ai.ibee) Toxicity Categoly Classification Honey Bee Fluroxypry > 25 Relatively non-toxic 42137314 Acceptable acid Honey Bee 40244527 Fluroxypry Could not be NA determined MHE Supplemental



### The results as demonstrated above indicatethat fluroxypyr acid is relatively non-toxic to bees on an acute contact basis.
b. 

### Toxicity to Freshwater Aquatic Animals I. Freshwater Fish, Acute 

### Two freshwater fish toxicity studiesusing the TGAI arerequired to establish the toxicity to fish. The preferred test species arerainbow trout (a coldwaterfish) andbluegill sunfish (a warm water fish). The registrant submitted studies on the fluroxypyr

### MHE and fluroxypryacid. Results of these tests are tabulatedbelow.Freshwater Fish Acute Toxicity 96-hour Species (all oftesting LC50 (ppm ai) MRIDNo. Study Below are Static) Chemical Toxicity Category Classification Golden Orfe 40244519 Fluroxypyr > 100 acid Bluegill sunfish Fluroxypyr 14.3 acid Rainbow trout Fluroxypyr > 100 acid Inland silverside Fluroxypyr 40 MHE Bluegill sunfish Fluroxypyr r 0.63 Practically Acceptable nontoxic 42137306 Slightly Toxic Acceptable 40244518 Practically Acceptable nontoxic Slightly toxic 44080309 Acceptable

Not determined 44080307 Acceptable MHE Rainbow trout Fluroxypyr >0.7 Not determined 402445-22 Acceptable
Golden Orfe MHE Fluroxypyr > 0.7 MHE Rainbow trout Fluroxypyr 13.42 402445-23 Not determined Supplemental
402445-25 Slightly Supplemental MHE Bluegill sunfish Fluroxypyr NA NA 421373-05 Invalid MHE Since the LC50 falls in the range of 14.3- > 100ppm ai, fluroxypyrMHE and fluroxypyr acid is ranges from slightlyto practically non-toxicto freshwater fish on an acutebasis. 

### ii. Freshwater Fish, Chronic Currently, no fish chronic toxicity studies have been submitted to the Agency. 

### iii. Freshwater Invertebrates, Acute A fieshwater aquatic invertebrate toxicity test using the TGAI is required to establishthe toxicity to aquatic invertebrates. Thepreferred test speciesisDaphnia magna. Results ofthis test are tabulatedbelow.Freshwater InvertebrateAcute Toxicity 48-hour EC50 Species (PP~ ai) MRIDNo. StudyClassification %ai Toxicity Category AuthorNear Water flea Water flea
Water flea Fluroxypyr > 100 Practically 40244524 Acceptable acid nontoxic Fluroxypyr > 100 Practically 4024452 1 Acceptable acid nontoxic Fluroxypyr > 0.6 Not determined 40244520 Acceptable MHE Water flea Fluroxypyr >0.109 ppm Not determined 421373-08 Acceptable MHE 

### Since the 

### ECS0 falls in the range of >I00 ppm, fluroxypyr acid is practically nontoxic to practically nontoxic to aquaticinvertebrates on an acute basis. The guideline (72-2) is fulfilled (MRIDs 40244524, and MRID 40244521). iv. Freshwater Invertebrate, Chronic 

### The registrant has submitted one freshwater chronic toxicity study testing fluroxypyr MHE. The results of the study are tabulatedbelow.
LOEAUNOEAL MRID No. ppm ai Authoriyear Species Study Classification % ai Water flea Fluroxypyr MHE 0.1091 0.06 44080314 Supplanental

c. Toxicity to Estuarine and Marine Animals 

### I. Estuarine and Marine Fish, Acute 

### Acute toxicity testing with estuarine and marine fish using the TGAI is required because the enduse product is intended for application sites near coastal counties. The registrant submitted to the Agency one estuarine and marine fish acute toxicity test using the longnose killifish. Based on the results of this study, fluroxypyrMHE is practically nontoxic to estuarine and marine fish. The results of this study are illustrated in the table below.Estuarine and Marine Fish Acute Toxicity Species (all oftesting MRID No. Study Below are Static) - %ai (ail Toxicity Category AuthorNear Classification Atlantic Silverside Fluroxypyr > 0.188 Not determined 42137309 Supplemental MHE Sheepsheadminnow Fluroxypyr 44080308 >0.087 (> 100 Not determined Acceptable MHE nominal)



### ii. Estuarine and Marine Fish, Chronic 

### The registrant did not submit any chronic toxicity data testing marine estuarine organisms. iii. Estuarine and Marine Invertebrates, Acute 

### Acute toxicity testing with estuarine and marine invertebrates using the TGAI 

### is required because the end-useproduct is intended for application sitesnear coastal counties. The followingtable demonstrates the toxicity of fluroxypyr acid and fluroxypyr MHE. Oysters appear to be more sensitivethan shrimp and fish to fluroxypyr acid and fluroxypyr MHE. Since the LC50 for the eastern oyster fall in the range of 10 to 100ppm, Fluroxypyr acid is considered slightly toxic to estuarine and marine invertebrates on an acute basis. Fluroxypyr MHE had an 

### LC50 of 0.0068 ppm for eastern oyster, categorizingit as very highly toxic to estuarine and marine invertebrateson an acute basis. Fluroxypyr MHE is not toxic to marine and estuarine shrimp at its solubility limit.Table 11. Acute Toxicityto EstuarineiMarine Invertebrates SpeciesITestType

Easternoyster (Crassostrea virginica), Flow-through shell deposition 

### I I I I 440803 11 Boeri, Kowalski, and Ward, 1994 96-hour LC50 or EC50 (mg aUL)

51 (measured) Acceptable

Flmoxypyr MHE I I I I Slightly toxic Grass shrimp (Palaemonetespugio), Flow-through Toxicity Category

Eastern oyster (Crassostrea virginica), Flow-through shell >I20 (measured)
Eastern oyster (Crussostrea virginica), Flow-through shell MRlDNo. AuthoriYear

Acceptable Study Classification

Practically nontoxic

0.068 (measured)
Not determined' 45725801 Springborn Laboratories

-. duorarum), Flow-through 

## I >0.13 (measured) 

### I Not determined3 

### I Manning 1988 

### I Supplemental 

## I 1 ECS0was higherthan thehighest concentration tested. 44080312 Boeri, Kowalski, and Ward, 1994

Very highly toxic

Grass shrimp (Palaemonetes pugio), Flow-through

2.A test concentrations at the solubility limit caused no mortality 3 Five percent mortality occurred at the solubility limit. Acceptable

iv. Estuarine and Marine Invertebrate, Chronic 44080310 Boeri, Kowalski, and Ward, 1995

>0.135 (measured)

The registrant did not submit any chronic toxicity data testing estuarine 

### and marine invertebrate. Supplemental

Not detamined2 44080313 Boeri, Kowalski, and Ward, 1995 Acceptable

### d. Toxicityto Plants I. Terrestrial 

### Terrestrial plant testing (seedlingemergence and vegetative vigor) is required because fluroxypyr has terrestrial non-residential outdoor use patterns and it may move off the application site through spray drift or runoff. For seedlingemergence and vegetative vigor testing the followingplant species and groups shouldbe tested: (1) six species of at least four dicotyledonous families, one species of which is soybean (Glycine max), and the second ofwhich is a root crop, and (2) 

### four species of at least two monocotyledonous families, one of which is corn (Zea mays). Terrestrial Tier 11 studies are required for all low doseherbicides (those with the maximum use rate of 0.5 

### lbs ai/A or less) and any pesticide showing a negative response equal to or greater than 25% 

### in Tier 

### I tests. Tier I1 tests measure the response ofplants, relative to a control, and five or more test concentrations. Results of Tier I1 toxicity testing on the technicaVTEP material for the most sensitive species are as follows. Toxicity to Plants i. 

### Terrestrial 

### Results of Tier I1 seedling emergencetoxicitytesting with a formulated product of fluroxypyrMHE are given in Table J. 

### The most sensitivetest species for seedling emergence effects was cucumber. The EC25 and the NOEC 

### for cucumber are 0.075 

### and 0.03 1 

### lb ai/A. FluroxypyrMHE is generallynot toxic to monocots at 0.25 

### lb ai/A.Table J. Phytotoxicityof Fluroxypyr MHE-Tier I1 Seedling Emergence Tests Most Sensitive Eczs NOEC Study Classification Species Parameter (lb ai/A) (lb ai/A) MRID No. AuthorNear Corn (monocot) All similar >0.25 0.25 44080335 Acceptable Schwab, 1996 Onion (monocot) All similar >0.25 0.25 Acceptable Ryegrass (monocot) Phytotoxic >0.25 0.124 Acceptable SymPtOn= Wheat (monocot) All similar >0.25 0.25 Acceptable Cotton (dicot) Phytotoxic 0.125 0.062 symptoms Cucumber (dicot) Phytotoxic 0.075 0.03 1 symptoms Acceptable Acceptable
Radish (dicot) All similar >0.25 0.25 Acceptable Soybean (dicot) Phytotoxic 0.24 0.062 symptoms Sunflower (dicot) Phytotoxic 0.109 0.062 symptoms Tomato (dicot) Shoot fresh 0.142 0.124 weight Acceptable Acceptable Acceptable
1 ThisNOEL is based on 17% mortality ofplants occurring at the next higher test level, 0.01 1lb ai/A. 2 Seedlingemergence data for lyegiass is upgraded from supplemental to acceptable. Results of Tier I1 seedling vegetative vigor toxicity testing on a formulated product of fluroxypyr

### MHE are given in Table 

### K. The most sensitive species was cotton. Based on the most sensitiveparameter, phytotoxic symptoms, 25% idubition was predicted to occur at a dose 

### of 0.0012 lb ai/A. The no observed effect level 

### (NOEL) was 0.0010 lb ai/A.Table K Phytotoxicityof Fluroxypyr MHE-Tier II VegetativeVigor Tests Most Sensitive EC25 NOEC Study Species Parameter (lb aVA) (lb aVA) MRID No.; AuthorNear Classification Corn (monocot) Phytotoxic 0.176 0.03 1 44080335; Schwab, 1996 Acceptable symptoms Onion (inonocot) Phytotoxic 0.124 0.062 symptom Acceptable Ryegrass (monocot) All similar >0.25 0.25 Acceptable Wheat (monocot) Phytotoxic >0.25 0.062 symptom Cotton (dicot) Phytotoxic 0.0012 0.0010 symptoms Acceptable Acceptable Cucumber (dicot) Phytotoxic 0.010 symptoms 0.004 Acceptable Radish (dicot) All similar 0.056 0.03 1 Acceptable Soybean (dicot) Phytotoxic 0.008 0.004 symptoms Sunflower (dicot) Phytotoxic 0.004 0.001 symptoms Tomato (dicot) Shoot fresh 0.004 0.001 weieht Acceptable Acceptable Acceptable

Since fluroxypyr

### MHE might degrade to fluroxypyr acid before reaching nontarget plants, data on the phytotoxicity of fluroxypyr acid to emerging seedlings is given in Table 

### L.

Table L. Phytotoxicityof Fluroxypyr Acid-Tier I1 Seedling Emergence Tests Most Sensitive ECz5 MRID No.; Study Species Parameter (lb aUA) Authornear Classification Corn (monocot) Fresh weight 0.178 44094902; Wright and Supplemental Rowland, 1996 Wheat (monocot) Fresh weight 0.079 Supplemental Cotton (dicot) Fresh weight 0.025 Supplemental Radish (dicot) Fresh weight 0.295 Supplemental Soybean (dicot) Fresh weight 0.072 Supplemental Sunflower (dicot) Plant height 0.036 Supplemental
Based on supplementaldata, fluroxypyr acid is more toxic to emerging seedlings than fluroxypyr

### MHE. The most sensitive of the six species tested is cotton, which has an ECZ5 of 0.025 lb ai/A. This is approximately 5 times lower than the cotton EC25 for fluroxypyrMHE.Table M. Phytotoxicity of Fluroxypyr Acid-Tier I1Vegetative Vigor Tests Most Sensitive ECzs MRDNo.; Study Classification Species Parameter (Ib aiJA) AuthorJYear Corn (monocot) Fresh weight >0.5 44094902; Wright and Supplemental Rowland, 1996 Wheat (inonocot) Fresh weight >0.5 Supplemental Cotton (dicot) Fresh weight ND Supplemental Radish (dicot) Fresh weight > 0.5 Supplemental Soybean (dicot) Fresh weight 0.00067 Supplemental Sunflower (dicot) Plantheight ND Supplemental


### The fluroxypyr acid data cannotbe used to calculaterisk quotient calculation because of several deviations in the study. However, the study is deemed supplemental. This supplemental data suggest that fluroxypyr acid is more toxic to vegetative vigor than fluroxypyrMHE. The most sensitiveof the six species in the fluroxypyr acid study is soybeanwhich produced an EC2~ of 0.00067 lb 

### ai/A. This is approximately 12

### times lower than the soybeanEC25 

### for fluroxypyr MHE.ii. Aquatic Plants 

### The results of the Aquaticplant toxicity tests are given in Table 

### M.TableN. Nontarget Aquatic Plant Toxicity (Tier 2) EGO NOEC MRIDN~. study Classification Species (ppm ai) (ppm ai) AuthorNear FluroxypyrAcid Green algae Kirchnena subcapitata Green algae chlorella vulgaris -- -- 42164501 Invalid Cowgill, Milazzo, and Murphy, 1988 >lo0 100 40244526 Jones, 1984 Duckweed 7.7 ND 44094902 Invalid Lemna gibba

Duckweed Lemna zibba >3.2 3.2 4501 16-02 Acceptable Ward, Mazazu. and Boeri Fresh water Green Alga >3.4 3.4 4501 16-03 Acceptable Selenastrum capricomutum Ward, Mazazu, and Boeri FreshwaterDiatom Navicula uelliculosa 1.1 0.19 450116-01 Acceptable Ward. Mazazu. and Boeri

- Blue-green Algae >2.9 0.36 450116-04 Acceptable Anabaena flos-aquae Ward, Mazazu, and Boeri Marine diatom > 3.0 3.0 450116-05 Acceptable Skeletonema costaturn Ward, Mazazu, and Boeri
FluroxypyrMHE Green algae Kirchneria subcapitata
Fresh water GreenAlga Selenastrum capricomutum Fresh water GreenAlga Selenastrum capricomutum Green algae Kivchnena subcapitata
Duckweed Lemna gibba
Duckweed Lemna gibba Bluegreen Algae Anabaenaflos-aquae >1.6 0.12 42137312 Supplementali2 Hughes and Alexander, 1991 >1.410 199 440803:40 Acceptable

> 3.4 3.4 4501 16-03 Acceptable Ward, Magazu, and Boeri, 2000 >1.4 0.20 44080340 Acceptable Milazzo, Hugo, and Martin, 1996 23.2 3.2 4501 16-02 Acceptable Ward, Magazu, and Boeri, 2000 >2.3 1.2 44080338 Acceptable Milazzo, Hugo, and Martin, 1996 0.40 0.030 44080336 Acceptable Milazzo, Hugo, and Martin, 1996Table N. NontargetAquatic PlantToxicity (Tier 2) EGO NOEC MRIDNo. Study Classification Species (ppin ai) (ppm ai) AuthorNear Marine diatom Skeletonema costaturn 0.29 0.18 44080337 Acceptable Milazzo, Hugo, and Martin, 1996 Freshwater Diatom 0.056 <0.015 44080339 Invalid Naviculapelliculosa Milazzo, Hugo, and Martin, 1996 1 The test species is not an acceptable in US guidelines, and cell counts were not determined. 2 Becauseof lack of solubility, the concentration of test material in solutionduring the test was uncertain. 3. This study did not comply with GLP standards
. 

### No acceptable aquaticplant toxicity data are available for fluroxypyr acid. Supplemental data, however, indicate that it has low toxicityto green algae. Additional data are not required on the fluroxypyr acid for registration of products containing fluroxypyr MHE. Data on the toxicity of fluroxypyr MHE to aquatic plants are complete with the exception of data for a fi-eshwaterdiatom, such asNaviculapelliculosa. A new study with a fi-eshwater diatom is required. The test guideline for tier I1 aquaticplant testing (123-2) is not fulfilled. The studies with 

### 4-amino-3,5-dichloro-6-fluro-2-methoxypyridine a degradateproduct (MRID 44080341) is not a GLP study, but it provides usable information on the toxicity of this degradationproduct of fluroxypyr MHE.

### Appendix 

### B Terrestrial Exposure Modeling


### TREX MODEL T-IM( Version 1.t 1 December7,m 

# 1

Thisspreadsheetwas developed bytheTerrestrial Biologyand ExposueTechnicalTeams. For infwmationor quesb'ons ccncemingthisspreackheet, pleasecontacttheTerrMral -we TechnicalTeam &Chairs.
New version Nates 711- v. 1.22 Mneauscalingfactwsfor birdsMUSTbe manually entered inthe lrputs~lrkket. While the EFEDdefaultvalue is 1.15 it MUSTalso be enteredif thatdefault isdesired. If novalue isprovideQ the mcdelwill embitwarningsWements in all outpLts. Iftheuserdesrestohem,~q~,O~beenteredintheIrpns~. Body\ht?igMsfor Mallardduckand BdmhitequailuereWusk-3(Dulning, 1984). Usercan optfor tesi spedesfor ac& andchmic

### mi otherthan malbrdand txhhite (testanimal boqrwei@t datamust be provided) Usercan optfor altem bach/weiihtsfrmdefaultsforewints esWishedvith ithte and mallard lhsWR-2 data inputWon inthe Inputswrksheetwas reqanbd to be more user-Wmdty. U)50fi-2can nowbe isculated for a liqd brdastapplication. AIl referencesare available inthe seedtreaimentworlcsheet. iWsereferencesare also hyperlinked. Wmumseeding rate infmtionisnm in blueandcan be adjusted bythe user. S'lEW5 v. 1.23. Acanmentsheet has beenx&d so that EEOws canprod? fe&ackor poseqMm to theTmrialBiologymi &mure Tebn'lcal Teams This Mue isavailableto EFED usersonly.
1~~ v. 1.3.1. Anew sheet 'Print Resllts'was acfdto fadlitate cuningand p&ng intoMS Word documents. Fwlrampamq, the mlts summarytables includetoxicity and eqx6uevalues Use of FDA's assumption thata lab raf mmes 5% of itsdiet cbilywasmadeaonalfor mammalianchrmicsWes If asWyreports botha NOAEC inppmand a NOAnin n The %a.i. cell wasformatted to percent. The ddationsofapplication rate (lbsailhe)inthe lpper boa Kenapandthe mean Kenagasheets m, longer referema Hddeno the applicatian ratein ternof %a.i., but is isdatedinthe "apflicationrate" cell. PWitionalcalarhtionsmreincluzkd to allowfaadditionaldlaracterization of the LD50-W. Anewsheet "C3anular ChamderiaiknCalcs"&estimates the nmber of granules re& ck6ethat mki biggera level ofconcern. The assodated minimtmforagng areawith sufficientnumher of granulest0achieveadosethat exwdsthe w l/lM theWL assumpbansof feedng effidency(10°/4 50°/+ or 1Whofgranules in an areaare mnslrmed).
7/7R007 v. 1.3.1. Fordarifiii,percenta.i. vvds rnadea user input inthe GranularOnm%rWikm Calcssheet insteadof importing the valuefrom the lrputssheet. No othwd-tangeswe rnade SupportingLbcummWon Forfurther mdsl informationconsldtthe 'Usec's Guide' doamentcontainingT-RMoperating instluctiansand badcgroundinfcmation. UWs Qide TRMvl.3.1, Dmber 2006, USEPAOfficeof PesticideRograms, Washington OC

hning,J.B. 1984. Bodywhtsof686 spedesof NmthAmerican birds Western Bird bding Assoc. MonosraphNo.1. Fletcher,J.S, J.E Neil-andT. G Pfleegx. 1994. Literature reviewand evaluationof the EPAfoodchain (Kemga)nwnogrsun, an .nstnunentforestimatingpestid6 residueson plants Envim.ToxAnd Chem. 13(9):1383139l Hoerpr, F. and E.E Kerraga. 1972. Pestidde residussmplants:correlation of representative data as a basisfor estimationoftheir mgitudeinthe environment IN: F. Coulstonand F. Corte, eds., EnvimmentalChalitywl %Safety: Chemistry, Toxicdogyand Technology. MI 1. GewgTheime Publishers,Shrttgart, @many. pp. 428 Mneau, P., BT. CdIirs,A MI. 1996. 01 the use ofscalingfactMs to improve interspeciesextrapoldmto acutetoxic4tyinbinls. Reg. Toxicd. Fbmnxd. 2424-29 UM,D. J. 2MX). Guidancefor Wing Saeening LevelAvim Riskkssmmtsfor SpayApplications of Wades OPPIEFED,USEPA USEPA 1993. Wldife ExposureFadmHandxokVdm I of II. EPN€xX@53/187a. Gffice of Research and Development,WsWgtm, D. C. 20460. USEPA 1995.&at LakesWater Wi Technical S&pM Documentfor WildlifeCfiteria Office ofWater, Washington D.C. Doament Ntmber EPA8208095-009 Wiliiand MzIImell. 1987. Pesticide persistenceon fdii.him.Ccntam.Toximl. 10032373

### TREX Millet Output Results for Avian RQs Avian Results 

# -

how TOpmvnJe nsk management w th the maxtmum posslole ,nformat on ~tIS rewmmended that both the oose-based and wncenlrahowbased ROSbe calculated when data are available

### TREX Millet Output 

### for Mammalian RQs Mammalian Results

Note: To provide risk management with the maximum possible information, it is recommendedthat both the dose-based and concentration-based RQs be calculated when data are available

### TREX Pome 

### Fruit Output 

### for Avian RQs Avian ResultsMammalian Results

Note: To provide risk management withthe maximum possible information, it is recommendedthat both the dose-based and concentration-based RQs be calculated when data are available

### Appendix 

### C LOCATES Output for Summary of Federally Listed Species Species Countsby Statefor Indicated Crops

No species were excluded. Minimum of 1 Acre. All Medium Types Reported apples, pears, all AL, 

### AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, 

### IA, KS, KY, LA, ME, MD, MA, MI, MN, 

### MS, MO, MT, NE, NV, NH, NJ, 

### NM, NY, 

### NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, 

### TX, UT, VT, VA, WA, WV, WI, WY



### Alabama

The taxa Amphibian has 2 

### species co-occurring with indicated crops. The taxa Bird has 3 species co-occurring with indicated crops. The taxa Bivalve has 30 species co-occurring with indicated crops.
The taxa Crustacean has 

### 1 species co-occurring with indicated crops. The taxa Dicot has 10 species co-occurring with indicated crops. The taxa Fish has 15 species co-occurring with indicated crops.
The taxa Gastropod has 10 species co-occurring with indicated crops. The taxa Mammal has 

### 4 species co-occurring with indicated crops. The taxa Monocot has 3 species co-occurringwith indicated crops.

### The taxa Reptile has 5 species co-occurring with indicated crops. Arizona

The taxa Amphibian has 2 species co-occurring with indicated crops. The taxa Bird has 7 species co-occurring with indicated crops. The taxa Dicot has 16 species co-occurring with indicated crops.
The taxa Fish has 18 

### species co-occurring with indicated crops. The taxa Gastropod has 

### 1 species co-occurring with indicated crops. The taxa Mammal has 9 

### species co-occurring with indicated crops.
The taxa Monocothas 

### 2 species co-occurringwith indicated crops. The taxa Reptile has 2 

### species co-occurring with indicated crops.
Arkansas

The taxa Bird has 2 

### species co-occurring with indicated crops. The taxa Bivalve has 6 species co-occurring with indicated crops.
The taxa Crustacean has 2 

### species co-occurring with indicated crops. 11/8/20075:35:04 PM Ver. 2.10.3 Page 1 of 14



### AL, AK, 

### AZ, AR, 

### CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, 

### IA, KS, 

### KY, LA, ME, MD, MA, MI, MN, 

### MS, MO, MT, NE, NV, NH, NJ, NM, NY, 

### NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, 

### TX, UT, VT, VA, WA, WV, 

### WI, WY



### The taxa Dicot has 4 species co-occurring with indicated crops. The taxa Fish has 3 

### species co-occurring with indicated crops. 75

### The taxa Gastropod has 1

### species co-occurring with indicated crops.
The taxa Insect has 

### 1 species co-occurring with indicated crops. The taxa Mammal has 3 

### species co-occurring with indicated crops.
California

The taxa Amphibian has 6 

### species co-occurring with indicated crops. The taxa Bird has 15 species co-occurring with indicated crops.
The taxa Crustacean has 9 

### species co-occurring with indicated crops. The taxa Dicot has 158 

### species co-occurringwith indicated crops. The taxa Fish has 3 

### 1 species co-occurring with indicated crops.
The taxa Gastropod has 

### 1 species co-occurring with indicated crops. The taxa Insect has 

### 22 species co-occurringwith indicated crops. The taxa Mammal has 20 

### species co-occurring with indicated crops.
The taxa Monocot has 17 

### species co-occurring with indicated crops. The taxa Reptile has 8 

### species co-occurring with indicated crops.
Colorado

The taxa Bird has 2 

### species co-occurring with indicated crops. The taxa Dicot has 8 

### species co-occurring with indicated crops.
The taxa Fish has 6 

### species co-occurring with indicated crops. The taxa Insect has 2 

### species co-occurring with indicated crops. 76

### The taxa Mammal has 2 species co-occurring with indicated crops.
The taxa Monocot has 1 species co-occurringwith indicated crops. Connecticut

The taxa Bird has 2 species co-occurring with indicated crops. The taxa Bivalve has 1 species co-occurring with indicated crops. The taxa Dicot has 1 species co-occurring with indicated crops.
The taxa Fish has 1 species co-occurring with indicated crops. The taxa Insect has 1 species co-occurring with indicated crops.

11/8/20075:35:04 PM Ver. 2.10.3 Page 2 of 14

AL, AK,AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, KS, 

### KY, LA, ME, MD, MA, MI, MN, 

### MS, MO, MT, NE, NV, NH, NJ, NM, 

### NY,NC, ND, 

### OH, OK, 

### OR, PA, PR, RI, SC, SD, TN, 

### TX, UT, VT, VA, WA, WV, 

### WI, WY



### The taxa Mammal has 1 

### species co-occurring with indicated crops. 77The taxa Monocot has 1 species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
Delaware

The taxa Bird has 1 species co-occurring with indicated crops.
The taxa Fish has 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurringwith indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops. The taxa Reptile has 

### 1 species co-occurring with indicated crops. Florida

The taxa Amphibian has 

### 1 species co-occurring with indicated crops. The taxa Bird has 8 species co-occurring with indicated crops. The taxa Bivalve has 7 species co-occurring with indicated crops.
The taxa Crustacean has 1 species co-occurring with indicated crops. The taxa Dicot has 23 species co-occurring with indicated crops. The taxa Fish has 4 species co-occurring with indicated crops.
The taxa Insect has 1 species co-occurring with indicated crops. The taxa Mammal has 5 species co-occurring with indicated crops. The taxa Monocot has 1 species co-occurring with indicated crops.
The taxa Reptile has 9 species co-occurring with indicated crops. 78Georgia
The taxa Amphibian has 1 species co-occurring with indicated crops. The taxa Bird has 4 species co-occurring with indicated crops. The taxa Bivalve has 15 species co-occurringwith indicated crops.
The taxa Dicot has 8 species co-occurring with indicated crops. The taxa Fish has 8 species co-occurring with indicated crops. The taxa Insect has 1 species co-occurring with indicated crops.
The taxa Mammal has 2 species co-occurring with indicated crops. The taxa Monocot has 6 species co-occurring with indicated crops.
11/8/20075:35:04 PM Ver. 2.10.3 Page 3 of 14

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, KS, KY, LA, ME, MD, 

### MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR,RI, SC, SD,TN,TX,UT,VT,VA, WA, 

### WV, WI, WY

The taxa Reptile has 2 species co-occurring with indicated crops. Hawaii

The taxa Bird has 21 species co-occurring with indicated crops. The taxa Dicot has 113 species co-occurring with indicated crops. The taxa Insect has 1 species co-occurring with indicated crops.
The taxa Mammal has 1 species co-occurring with indicated crops. 79The taxa Monocot has 11 species co-occurring with indicated crops. The taxa Reptile has 

### 2 species co-occurring with indicated crops.
Idaho

The taxa Bird has 1 species co-occurringwith indicated crops.
The taxa Dicot has 3 species co-occurring with indicated crops. The taxa Fish has 8 species co-occurring with indicated crops. The taxa Gastropod has 

### 5 species co-occurring with indicated crops.
The taxa Mammal has 4 species co-occurring with indicated crops. Illinois

The taxa Bird has 2 species co-occurring with indicated crops. The taxa Bivalve has 

### 7 species co-occurring with indicated crops. The taxa Crustacean has 1 species co-occurring with indicated crops.
The taxa Dicot has 7 species co-occurring with indicated crops. The taxa Fish has 1species co-occurringwith indicated crops. The taxa Gastropod has 

### 1 species co-occurring with indicated crops.
The taxa Insect has 2 species co-occurring with indicated crops. The taxa Mammal has 

### 2 species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops.
Indiana

### The taxa Bird has 2 species co-occurringwith indicated crops.
The taxa Bivalve has 11 species co-occurringwith indicated crops. The taxa Dicot has 4 species co-occurring with indicated crops. The taxa Insect has 2 species co-occurring with indicated crops.
11/8/20075:35:04PM Ver. 2.10.3 Page4 of 14



### AL, AK, AZ, 

### AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, 

### KS, KY, 

### LA, ME, MD, MA, 

### MI, MN, 

### MS, MO, MT, NE, NV, NH, 

### NJ, NM, NY, 

### NC, 

### ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, 

### TX, UT, VT, VA, WA, WV, 

### WI, WY



### The taxa Mammal has 2 species co-occurring with indicated crops. The taxa Monocot has 1 

### species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
Iowa

The taxa Bird has 2 species co-occurring with indicated crops.
The taxa Bivalve has 2 species co-occurring with indicated crops. The taxa Dicot has 3 

### species co-occurring with indicated crops. The taxa Fish has 2 species co-occurring with indicated crops.
The taxa Gastropod has 

### 1 species co-occurring with indicated crops. The taxa Mammal 

### has 1 

### species co-occurring with indicated crops. The taxa Monocothas 2 species co-occurring with indicated crops.Kansas The taxa Bird has 3 species co-occurring with indicated crops.

The taxa Bivalve has 3 species co-occurring with indicated crops.
11/8/20075:35:04 PM Ver. 2.10.3 Page 5 of 14

The taxa Dicot has 

### 1 species co-occurring with indicated crops. The taxa Fish has 4 species co-occurring with indicated crops. The taxa Insect has 1 species co-occurring with indicated crops.
The taxa Mammal has 2 species co-occurring with indicated crops. The taxa Monocot has 

### 1 species co-occurring with indicated crops. Kentucky

The taxa Bird has 6 species co-occurring with indicated crops. The taxa Bivalvehas 22 species co-occurring with indicated crops.
The taxa Crustaceanhas 1 species co-occurring with indicated crops. The taxa Dicot has 10 species co-occurring with indicated crops. The taxa Fish has 4 species co-occurring with indicated crops.
The taxa Insect has 1 species co-occurringwith indicated crops. The taxa Mammal has 3 species co-occurring with indicated crops.
Louisiana

The taxa Bird has 4 species co-occurring with indicated crops.

### AL, AK, AZ, 

### AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, 

### MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, 

### PR, RI, SC, SD, 

### TN, TX, UT, VT, VA, WA, WV, 

### WI, 

### WY

The taxa Dicot has 2 

### species co-occurring with indicated crops. The taxa Fish has 2 

### species co-occurring with indicated crops. The taxa Mammal has 1 

### species co-occurring with indicated crops.
The taxa Reptile has 7 

### species co-occurring with indicated crops. Maine

The taxa Bird has 2 

### species co-occurring with indicated crops. The taxa Dicot has 1 

### species co-occurring with indicated crops. The taxa Fish has 2 

### species co-occurring with indicated crops.
The taxa Mammal has 1

### species co-occurringwith indicated crops. The taxa Monocot has 

### 2 species co-occurringwith indicated crops. Maryland

The taxa Bird has 1 

### species co-occurring with indicated crops. The taxa Bivalve has 1 

### species co-occurring with indicated crops.
The taxa Dicot has 4 

### species co-occurring with indicated crops.

. The 

### taxa Fish has 2 

### species co-occurring with indicated crops. The taxa Insect has 2 

### species co-occurring with indicated crops. 83The taxa Mammal has 2 species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
Massachusetts

The taxa Bird has 3 species co-occurring with indicated crops.
The taxa Dicot has 1 species co-occurring with indicated crops. The taxa Fish has 

### 1 species co-occurring with indicated crops. The taxa Insect has 3 species co-occurring with indicated crops.
The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops. The taxa Reptile has 2 species co-occurringwith indicated crops. Michigan

The taxa Bird has 2 species co-occurring with indicated crops.
11/8/20075:35:04 PM Ver. 2.10.3 Page 6 of 14

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, WY

The taxa Bivalve has 2 species co-occurring with indicated crops. The taxa Dicot has 4 species co-occurring with indicated crops. 84

### The taxa Insect has 

### 4 species co-occurring with indicated crops.
The taxa Mammal has 3 

### species co-occurring with indicated crops. The taxa Monocot has 3 

### species co-occurringwith indicated crops. The taxa Reptile has 

### 1 species co-occurring with indicated crops.
Minnesota

The taxa Bird has 

### 1 species co-occurring with indicated crops.
The taxa Bivalve has 2 

### species co-occurring with indicated crops. The taxa Dicot has 2 

### speciesco-occurring with indicated crops. The taxa Fish has 

### 1 species co-occurringwith indicated crops.
The taxa Insect has 

### 1 species co-occurring with indicated crops. The taxa Mammal has 

### 2 species co-occurring with indicated crops. The taxa Monocot has 2 

### speciesco-occurring with indicated crops. Mississippi

The taxa Amphibian has 

### 1 species co-occurring with indicated crops.
The taxa Bird has 

### 5 species co-occurring with indicated crops. The taxa Bivalve has 8 

### species co-occurring with indicated crops. The taxa Dicot has 2 

### species co-occurringwith indicated crops.
The taxa Fish has 3 

### species co-occurring with indicated crops. The taxa Mammal has 3 

### species co-occurring with indicated crops. 85

### The taxa Reptile has 

### 7 species co-occurring with indicated crops.
Missouri

The taxa Bird has 

### 2 species co-occurring with indicated crops.
The taxa Bivalve has 6 

### species co-occurring with indicated crops. The taxa Dicot has 7 

### species co-occurring with indicated crops. The taxa Fish has 

### 6 species co-occurring with indicated crops.
The taxa Insect has 2 species co-occurring with indicated crops. The taxa Mammal has 

### 2 species co-occurring with indicated crops.
11/8/20075:35:04 PM Ver. 2.10.3 Page 

### 7 of 14

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, IA, 

### KS, 

### KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, 

### NY,NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, 

### WI, 

### WY

The taxa Monocot has 1 species co-occurring with indicated crops. Montana

The taxa Bird has 3 

### species co-occurring with indicated crops. The taxa Dicot has 2 species co-occurring with indicated crops. The taxa Fish has 5 species co-occurring with indicated crops.
The taxa Mammal has 3 species co-occurring with indicated crops. NebraskaThe taxa Bird has 3 species co-occurringwith indicated crops. The taxa Dicot has 

### 1 species co-occurring with indicated crops. The taxa Fish has 2 species co-occurring with indicated crops.
The taxa Insecthas 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Monocot has 

### 1 species co-occurring with indicated crops.
Nevada

The taxa Bird has 2 species co-occurring 

### with indicated crops.
The taxa Dicot has 8 species co-occurring with indicated crops. The taxa Fish has 23 species co-occurring with indicated crops. The taxa Insect has 2 species co-occurring with indicated crops.
The taxa Monocot has 1 species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
New Hampshire

The taxa Bivalve has 1 species co-occurring with indicated crops. The taxa Dicot has 1 species co-occurring with indicated crops.
The taxa Insect has 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Monocot has 1 species co-occurring with indicated crops. 87

### New Jersey The taxa Bird has 2 species co-occurring with indicated crops.
The taxa Dicot has 2 species co-occurring with indicated crops. 11/8/20075:35:05 PM Ver. 2.10.3 Page 8 of 14



### AL, AK, 

### AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### lN, IA, KS, KY, LA, ME, MD, MA, MI, MN, 

### MS, MO, MT, NE, 

### NV, NH, 

### NJ, NM, NY, 

### NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, 

### TX, UT, VT, VA, WA, WV, WI, WY



### The taxa Fish has 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Monocot has 3 species co-occurring with indicated crops.
The taxa Reptile has 1 species co-occurring with indicated crops. New Mexico

The taxa Amphibian has 1 species co-occurring with indicated crops. The taxa Bird has 

### 6 species co-occurring with indicated crops. The taxa Crustacean has 2 species co-occurring with indicated crops.
Thetaxa Dicot has 11 species co-occurring with indicated crops. The taxa Fish has 13 species co-occurring with indicated crops. The taxa Gastropod has 5 species co-occurring with indicated crops.
The taxa Mammal has 2 species co-occurring with indicated crops. 88New York
The taxa Bird has 2 species co-occurring with indicated crops. The taxa Bivalve has 

### 1 species co-occurring with indicated crops. The taxa Dicot has 4 species co-occurring with indicated crops.
The taxa Fish has 1 species co-occurringwith indicated crops. The taxa Gastropod has 

### 1 species co-occurring with indicated crops. The taxa Insect has 

### 1 species co-occurring with indicated crops.
The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Monocot has 1 species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
North Carolina

The taxa Arachnid has 1 species co-occurring with indicated crops.
The taxa Bird has 

### 4 species co-occurring with indicated crops. The taxa Bivalve has 8 species co-occurring with indicated crops. The taxa Dicot has 21 species co-occurring with indicated crops.
The taxa Fish has 4 species co-occurring with indicated crops. The taxa Gastropod has 1 species co-occurring with indicated crops.
11/8/20075:35:05 PM Ver. 2.10.3 Page 9 of 14

### AL, AK, 

### AZ, AR, CA, CO, CT, DE, DC, FL, GA, 

### HI, ID, IL, IN, IA, KS, KY, LA, ME, MD, MA, 

### MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VT, VA, WA, 

### WV, WI, WY



### The taxa Insect has 1 

### species co-occurring with indicated crops. The taxa Mammal has 4 

### species co-occurring with indicated crops. The taxa Monocot has 5 

### species co-occurring with indicated crops.
The taxa Reptile has 5 

### species co-occurring with indicated crops. North Dakota

The taxa Bird has 1 

### species co-occurring with indicated crops. The taxa Monocot has 1 

### species co-occurring with indicated crops.
Ohio

The taxa Bird has 

### 1 species co-occurring with indicated crops. The taxa Bivalve has 6 

### species co-occurring with indicated crops.
Thetaxa Dicot has 4 

### species co-occurring with indicated crops. The taxa Fish has 

### 1 species co-occurring with indicated crops. The taxa Insect has 

### 4 species co-occurring with indicated crops.
The taxa Mammal has 2 

### species co-occurringwith indicated crops. The taxa Monocot has 2 

### species co-occurring with indicated crops. The taxa Reptile has 2 

### species co-occurring with indicated crops.
OklahomaThe taxa Bird has 6 species co-occurring with indicated crops.
The taxa Bivalve has 2 species co-occurring with indicated crops. The taxa Fish has 4 species co-occurring with indicated crops. The taxa Insect has 1 species co-occurring with indicated crops.
The taxa Mammal has 3 species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurringwith indicated crops. Oregon

The taxa Bird has 4 species co-occurring with indicated crops. The taxa Crustacean has 1 species co-occurring with indicated crops.
The taxa Dicot has 11 species co-occurring with indicated crops. The taxa Fish has 19 species co-occurringwith indicated crops. The taxa Insect has 2 species co-occurringwith indicated crops.
11/8/20075:35:05 PM Ver. 2.10.3 Page 10 of 14

AL, AK, 

### AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, 

### LA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, 

### NM, NY, NC, ND, OH, OK, OR, PA, 

### PR, RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, 

### WY

The taxa Mammal has 1 species co-occurring. with indicated crops. The taxa Monocot has 2 species co-occurringwith indicated crops. Pennsylvania 9 1The taxa Bird has 1 species co-occurring with indicated crops. The taxa Bivalvehas 

### 2 species co-occurring with indicated crops.
The taxa Mammal has 2 species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops. The taxa Reptile has 

### 1 species co-occurring with indicated crops.
Rhode Island

The taxa Bird has 1 species co-occurring with indicated crops.
The taxa Dicot has 1 species co-occurring with indicated crops. The taxa Fish has 

### 1 species co-occurringwith indicated crops. The taxa Insect has 1 species co-occurring with indicated crops.
The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Monocot has 1 species co-occurring with indicated crops.
South Carolina

The taxa Amphibian has 1 species co-occurring with indicated crops. The taxa Bird has 4 species co-occurring with indicated crops.
The taxa Bivalvehas 1 species co-occurring with indicated crops. The taxa Dicot has 

### 12 species co-occurring with indicated crops. The taxa Fish has 1 species co-occurring with indicated crops.
The taxa Mammal has 1 species co-occurring with indicated crops. 92The taxa Monocot has 6 species co-occurring with indicated crops. The taxa Reptile has 5 species co-occurring with indicated crops.
South Dakota

The taxa Bird has 3 species co-occurring with indicated crops.
The taxa Fish has 2 species co-occurring with indicated crops. The taxa Insect has 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurring with indicated crops.
11/8/2007 5:35:05 PM Ver. 2.10.3 Page 11 of 

### 14

AL, AK, AZ, 

### AR, CA, CO, CT, DE, DC, 

### FL, GA, HI, ID, IL, 

### IN, IA, KS, KY, LA, 

### ME, MD, MA, MI, 

### MN, MS, MO, MT, NE, 

### NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR, 

### Rl,SC, SD, TN, 

### TX, UT, 

### VT, VA, WA, WV, WI, 

### WY

The taxa Monocot has 1 species co-occurring with indicated crops. Tennessee

The taxa Arachnid has 

### 1 species co-occurringwith indicated crops. The taxa Bird has 3 species co-occurring with indicated crops. The taxa Bivalve has 37 species co-occurring with indicated crops.
The taxa Crustacean has 1 species co-occurringwith indicated crops. The taxa Dicot has 16 species co-occurring with indicated crops. The taxa Fish has 16 species co-occurring with indicated crops. 93

### The taxa Gastropod has 2 species co-occurring with indicated crops. The taxa Mammal has 3 

### species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops.
Texas

The taxa Amphibian has 4 

### species co-occurring with indicated crops.
The taxa Arachnid has 10 species co-occurring with indicated crops. The taxa Bird has 12 species co-occurringwith indicated crops. The taxa Crustaceanhas 1

### speciesco-occurring with indicated crops.
The taxa Dicot has 20 species co-occurring with indicated crops. The taxa Fish has 7 

### species co-occurring with indicated crops. The taxa Insecthas 9 

### species co-occurring with indicated crops.
The taxa Mammal has 5 

### species co-occurring with indicated crops. The taxa Monocot has 

### 3 species co-occurring with indicated crops. The taxa Reptile has 6 

### species co-occurring with indicated crops.
Utah

The taxa Bird has 2 

### species co-occurring with indicated crops.
The taxa Dicot has 22 species co-occurring with indicated crops. The taxa Fish has 8 

### species co-occurring with indicated crops. The taxa Mammal has 2 species co-occurring with indicated crops. 94

### The taxa Monocot has 2 species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
11/8/20075:35:05 PM Ver. 2.10.3 Page 12 of 14

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, 

### IA, KS, KY, LA, ME, MD, MA, MI, 

### MN, MS, MO, MT, 

### NE, NV, NH, NJ, NM, NY, 

### NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, 

### TX, UT, VT, VA, WA, WV, 

### WI, WY



### Vermont

The taxa Bivalve has 1 species co-occurring with indicated crops.
The taxa Dicot has 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurringwith indicated crops. The taxa Monocot has 1 species co-occurring with indicated crops. Virginia

The taxa Amphibian has 1 species co-occurring with indicated crops.
The taxa Bird has 2 

### species co-occurring with indicated crops. The taxa Bivalve has 21 species co-occurring with indicated crops. The taxa Crustacean has 2 species co-occurring with indicated crops.
The taxa Dicot has 13 species co-occurring with indicated crops. The taxa Fish has 7 species co-occurring with indicated crops. The taxa Gastropod has 1 species co-occurring with indicated crops. 95The taxa Insect has 3 species co-occurring with indicated crops. The taxa Mammal has 5 species co-occurring with indicated crops. The taxa Monocothas 4 species co-occurringwith indicated crops.
The taxa Reptile has 1 species co-occurringwith indicated crops. Washington

The taxa Bird has 4 species co-occurring with indicated crops. The taxa Dicot has 7 species co-occurring with indicated crops. The taxa Fish has 19 species co-occurring with indicated crops.
The taxa Mammal has 5 species co-occurring with indicated crops. West Virginia

The taxa Amphibian has 1 species co-occurring with indicated crops. The taxa Bivalve has 5 species co-occurring with indicated crops. The taxa Dicot has 4 species co-occurring with indicated crops.
The taxa Gastropod has 1 species co-occurring with indicated crops. The taxa Mammal has 5 species co-occurring with indicated crops. The taxa Monocot has 1 species co-occurringwith indicated crops.
11/8/20075:35:05 PM Ver. 2.10.3 Page 

### 13 of 14

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR,RI, SC, SD,TN,TX,UT,VT,VA, WA, WV, WI, WY 96Wisconsin The taxa Bird has 3 species co-occurring with indicated crops.
The taxa Bivalve has 2 species co-occurring with indicated crops. The taxa Dicot has 4 species co-occurring with indicated crops. The taxa Insecthas 2 species co-occurring with indicated crops.
The taxa Mammal has 2 species co-occurring with indicated crops. The taxa Monocot has 2 species co-occurring with indicated crops. Wyoming

The taxa Dicot has 1 species co-occurring with indicated crops. The taxa Mammal has 3 species co-occurring with indicated crops.
No species were excluded. Dispersed species included in report.
11/8/20075:35:05 PM Ver. 2.10.3 Page 14of 14

### Species Counts by 

### State for Indicated Crops

No species were excluded. Minimum of 1

### Acre. All Medium Types Reported proso millet AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, 

### IN, IA, KS, KY, LA, ME, MD, MA, 

### MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, 

### TN, TX, UT, VT, VA, WA, WV, 

### WI, WY

California

The taxa Bird has 

### 1 species co-occurring with indicated crops. The taxa Dicot has 1 

### species co-occurring with indicated crops. The taxa Fish has 

### 2 species co-occurring with indicated crops.
The taxa Insect has 

### 1 species co-occurring with indicated crops. Colorado

The taxa Bird has 1 

### species co-occurring with indicated crops. The taxa Dicot has 3 

### species co-occurring with indicated crops. The taxa Fish has 3 

### species co-occurring with indicated crops.
The taxa Mammal has 2 

### species co-occurringwith indicated crops. 98

### The taxa Monocot has 1 species co-occurringwith indicated crops.
Florida

The taxa Bird has 4 species co-occurring with indicated crops. The taxa Bivalve has 1 species co-occurring with indicated crops.
The taxa Crustacean has 

### 1 species co-occurring with indicated crops. The taxa Dicot has 4 species co-occurring with indicated crops. The taxa Fish has 1 species co-occurring with indicated crops.
The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Reptile has 

### 5 species co-occurring with indicated crops. Georgia

The taxa Bird has 2 species co-occurring with indicated crops. The taxa Bivalve has 

### 5 species co-occurring with indicated crops.
The taxa Dicot has 4 species co-occurring with indicated crops. The taxa Fish has 

### 1 species co-occurring with indicated crops. 11/9/20079:04:04 AM Ver. 2.10.3 Page 1 of 4

AL, AK, 

### AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, 

### IA, KS, KY, LA, ME, MD, MA, MI, MN, 

### MS, MO, MT, NE, NV, 

### NH, NJ, NM, NY, NC, ND, OH, OK, 

### OR, PA, PR, RI, SC, SD, 

### TN, TX, UT, VT, VA, WA, WV, 

### WI, WY



### The taxa Insect has 1 species co-occurring with indicated crops.

### The taxa Mammal has 

### 1 species co-occurring with indicated crops. The taxa Monocot has 1 

### species co-occurring with indicated crops.
The taxa Reptile has 1 

### species co-occurring with indicated crops. Illinois

The taxa Dicot has 

### 1 species co-occurring with indicated crops. The taxa Mammal has 1 

### species co-occurring with indicated crops.
Iowa

The taxa Dicot has 1 

### species co-occurringwith indicated crops. The taxa Mammal has 1 

### species co-occurring with indicated crops.
The taxa Monocot has 2 

### species co-occurring with indicated crops. Kansas

The taxa Bird has 1 

### species co-occurring with indicated crops. The taxa Dicot has 1 

### species co-occurring with indicated crops. The taxa Fish has 1 

### species co-occurring with indicated crops.
The taxa Mammal has 2 

### species co-occurring with indicated crops. The taxa Monocot has 

### 1 species co-occurring with indicated crops. Michigan

The taxa Insect has 1 

### species co-occurring with indicated crops.
Minnesota

### The taxa Bird has 1 species co-occurring with indicated crops. The taxa Mammal has 2 species co-occurring with indicated crops.
The taxa Monocot has 1 species co-occurringwith indicated crops. Mississippi

The taxa Mammal has 1 species co-occurring with indicated crops. The taxa Reptile has 1 species co-occurring with indicated crops.
Montana

The taxa Bird has 3 

### species co-occurring with indicated crops.

11/9/20079:04:04 AM 

### Ver. 2.10.3 Page 2 

### of 

### 4

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, IA, 

### KS, 

### KY, LA, 

### ME, MD, MA, MI, 

### MN, MS, MO, MT, NE, 

### NV, NH, NJ, 

### NM, NY, NC, 

### ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, 

### WI, WY

The taxa Dicot has 2 species co-occurring with indicated crops. The taxa Fish has 4 species co-occurring with indicated crops. The taxa Mammal has 3 

### species co-occurring with indicated crops.
Nebraska

The taxa Bird has 3 

### species co-occurring with indicated crops.
The taxa Dicot has 2 species co-occurring with indicated crops.

### The taxa Mammal has 1 

### species co-occurring with indicated crops.
North Carolina

The taxa Bird has 1 

### species co-occurring with indicated crops. The taxa Bivalvehas 4 

### species co-occurring with indicated crops.
The taxa Dicot has 

### 1 speciesco-occurring with indicatedcrops. The taxa Fish has 

### 1 species co-occurring with indicated crops. The taxa Monocot has 4 

### species co-occurring with indicated crops.
North Dakota

The taxa Bird has 3 

### species co-occurring with indicated crops.
The taxa Fish has 

### 1 species co-occurring with indicated crops. The taxa Monocot has 1 

### species co-occurring with indicated crops.
Ohio

The taxa Dicot has 

### 1 species co-occurring with indicated crops. The taxa Insect has 1 

### species co-occurring with indicated crops.
The taxa Mammal has 1 

### species co-occurring with indicated crops. Oklahoma

The taxa Bird has 

### 4 species co-occurring with indicated crops. The taxa Fish has 1 

### species co-occurring with indicated crops.
South DakotaThe taxa Bird has 3 species co-occurring with indicated crops. The taxa Fish has 2 species co-occurring with indicated crops.
The taxa Insect has 1 species co-occurring with indicated crops. The taxa Mammal has 1 species co-occurringwith indicated crops. 11/9/20079:04:04 AM Ver. 2.10.3 Page 3 of 

### 4

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, WY

The taxa Monocot has 1 species co-occurringwith indicated crops. Texas

The taxa Bird has 1 species co-occurring with indicated crops. Wisconsin

The taxa Bird has 1 species co-occurring with indicated crops. The taxa Dicot has 1 species co-occurring with indicated crops. The taxa Insect has 2 species co-occurring with indicated crops.
The taxa Monocot has 1 species co-occurring with indicated crops. Wyoming

The taxa Dicot has 1 species co-occurring with indicated crops. The taxa Mammal has 2 species co-occurringwith indicated crops. 103No specieswere excluded. Dispersed species included in report.

11/9/2007 9:04:04 AM Ver. 2.10.3 Page 4 of 4

### Appendix 

### D Ecotoxicity Categories for Terrestrial and Aquatic Organisms Avian Acute Oral Dietary Concentration (mg/kg) Toxicity Category Concentration @pm) Toxicity Category <lo very highly toxic <50 very highly toxic 10-50 highly toxic 50-500 highly toxic 5 1-500 moderately toxic 501-1000 moderatelytoxic 501-2000 slightly toxic 1001-5000 slightlytoxic >2000 practically nontoxic 25000 practically nontoxic Aquatic Organisms: Acute Concentration (ppm) Toxicity Category <O. 1 very highly toxic 0.1 

### - 1 highly toxic >1- 10 moderately toxic >10 

### - 100 slightly toxic >lo0 practicallynontoxic 

# -- Wild Mammals: Acute Oral Concentration (mg/kg) Toxicity Category <lo very highly toxic 10

### - 50 highly toxic 51 

### - 500 moderately toxic 501 

### - 2000 slightly toxic >2000 practically nontoxic Non-Target Insects: Acute Toxicity Concentration (@bee) Toxicity Category <2 highly toxic 2- 11 moderately toxic >11 practicallynontoxic

### Appendix 

### E 

### PRZM-EXAMS Output 

### Files
Pome Fruit : stored as STAR-NC.out Chemical: fluroxypyr PRZM environment: NCappleC.txt modified Satday, 12 October 2002 at 16:09:36 EXAMS environment: pond298.e~~ modified Thuday, 29 August 2002 at 16:33:30 Metfile: w03812.dvf modified Wedday, 3 July 2002 at 09:05:50 Water segment concentrations (ppb) Year 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 19 82 1983 1984 1985 1986 1987 1988 1989 1990 Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.5647 0.4521 0.236 0.1297 0.08803 0.02176 14.12 11.12 5.299 2.065 1.381 0.3411 3.796 3.35 1.74 0.7453 0.5072 0.1256 5.959 4.761 2.251 0.9022 0.6055 0.1492 0.5653 0.461 0.2629 0.1284 0.0862 0.02134 1.012 0.8171 0.3949 0.1785 0.1208 0.03028 0.6613 0.5321 0.2683 0.1072 0.07235 0.01788 1.687 1.353 0.6366 0.2899 0.2146 0.05309 8.098 6.42 2.931 1.173 0.7861 0.1941 7.47 6.073 2.965 1.167 0.7803 0.1926 0.6038 0.4885 0.2524 0.142 0.0957 0.0237 1.337 1.08 0.7338 0.3498 0.2352 0.05793 2.162 1.738 0.8226 0.3736 0.2517 0.0622 3.578 2.883 1.44 0.5802 0.3885 0.09595 0.5807 0.4711 0.2253 0.1256 0.08545 0.02114 0.5078 0.4157 0.2079 0.1232 0.08874 0.02197 0.28 0.2282 0.1121 0.04486 0.03432 0.0105 0.28 0.2248 0.1267 0.05545 0.0432 0.01124 1.182 0.9672 0.5066 0.2256 0.1601 0.03972 1.404 1.136 0.7825 0.3649 0.2449 0.06037 6.613 5.341 2.567 1.04 0.7023 0.1735 1.031 0.834 0.4046 0.2057 0.1383 0.03423 0.868 0.7055 0.3469 0.164 0.1167 0.02897 0.2943 0.2399 0.1253 0.08529 0.06247 0.01553 4.356 3.481 1.649 0.7225 0.4869 0.1204 11.7 9.503 4.585 1.812 1.227 0.3033 Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.037037037037037 14.12 11.12 5.299 2.065 1.381 0.3411 0.0740740740740741 11.7 9.503 4.585 1.812 1.227 0.3033 0.111111111111111 8.098 6.42 2.965 1.173 0.7861 0.1941 0.148148148148148 7.47 6.073 2.931 1.167 0.7803 0.1926 0.185185185185185 6.613 5.341 2.567 1.04 0.7023 0.1735 0.222222222222222 5.959 4.761 2.251 0.9022 0.6055 0.1492 0.259259259259259 4.356 3.481 1.74 0.7453 0.5072 0.1256 0.296296296296296 3.796 3.35 1.649 0.7225 0.4869 0.1204 0.333333333333333 3.578 2.883 1.44 0.5802 0.3885 0.09595 0.37037037037037 2.162 1.738 0.8226 0.3736 0.2517 0.0622 0.407407407407407 1.687 1.353 0.7825 0.3649 0.2449 0.06037 0.444444444444444 1.404 1.136 0.7338 0.3498 0.2352 0.057930.1 9.1786 7.3449 3.451 1.3647 0.91837 0.22686 Average of yearly averages: 0.0856769230769231 Inputs generated by pe4.pl - 8-August-2003 Data used for this run: 

# I Output File: STAR-NC Metf ile: w03812.dvf PRZM scenario: NCappleC.txt EXAMS environment file: pond298.exv Chemical Name: fluroxypyr Description Variable Name Value Units Comments Molecular weight mwt 255.03 g/mol Henry's Law Const. henry 0.0005 atm-mA3/mol Vapor Pressure vapr 9.43-7 torr Solubility sol 79500 mg/L Kd Kd mg/L Koc Koc 68 mg/L ~hotolysis half -1ife kdp 0 days Half-life Aerobic Aquatic Metabolism kbacw 42 days Halfife Anaerobic Aquatic Metabolism kbacs 24 days Halfife Aerobic Soil Metabolism asm 14 days Halfife Hydrolysis: pH 5 0 days Half-life Hydrolysis: pH 7 0 days Half-life Hydrolysis: pH 9 0 days Half-life Method : CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 0.56 kg/haApplication Efficiency: APPEFF 0.99 fraction Spray Drift DRFT 0.01 fraction of application rate applied to pond Application Date Date 1-8 dd/mm or dd/mmm or dd-mm or dd-m Record 17: FILTRA IPSCND 1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

### Millet: stored as STAR-TXs.out Chemical: fluroxypyr PRZM environment: TXsorghumOP.txt modified Satday, 12 October 2002 at 17:29:44 EXAMS environment: pond298.e~~ modified Thuday, 29 August 2002 at 16:33:30 Metfile: w13958.dvf modified Wedday, 3 July 2002 at 09:06:24 Water segment concentrations (ppb) Year 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.4645 0.3376 0.2326 0.1039 0.06955 0.01715 0.3817 0.2975 0.1925 0.125 0.08378 0.02066 0.3879 0.2878 0.1777 0.08125 0.05425 0.01338 0.6191 0.4632 0.25-6 0.1107 0.07402 0.0182 5.283 4.087 1.869 0.7435 0.4963 0.1224 1.366 1.083 0.5661 0.2211 0.1475 0.03642 1.073 0.7974 0.3695 0.1795 0.1199 0.02957 2.021 1.505 0.9975 0.4399 0.2936 0.07221 0.745 0.6125 0.4104 0.1819 0.1214 0.02996 9.79 7.413 3.038 1.145 0.7645 0.1885 0.3855 0.2835 0.1685 0.08227 0.05552 0.01372 8.623 6.668 2.947 1.117 0.7458 0.1834 0.411 0.3067 0.2061 0.09342 0 -0626 0.01544 2.378 1.765 0.8868 0.3386 0.2259 0.05582 1.141 0.8859 0.4477 0.2369 0.1583 0.03904 1.537 1.181 0.6751 0.2956 0.1974 0.04854 0.3957 0.3006 0.1907 0.1002 0.06686 0.01652 3.929 2.932 1.263 0.5169 0.3449 0.08504 5.353 4.06 1.709 1.034 0.6906 0.1703 0.6646 0.5279 0.4062 0.1696 0.1131 0.02785 1.259 0.9459 0.596 0.2768 0.1848 0.04557 0.9949 0.7457 0.5013 0.2212 0.1477 0.03641 1.94 1.488 0.8109 0.337 0.225 0.05548 0.3895 0.291 0.1836 0.0843 0.05626 0.01384 0.3999 0.3045 0.1849 0.08823 0.05907 0.01457 7.899 6.042 3.196 1.283 0.8563 0.2112 0.6804 0.5774 0.3621 0.1728 0.1154 0.02847 0.869 0.6685 0.3491 0.1754 0.1172 0.02883 2.106 1.782 1.187 0.4868 0.3248 0.0801 3.851 2.855 1.208 0.4615 0.308 0.07595 Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 9.79 7.413 3.196 1.283 0.8563 0.2112 0.0645161290322581 8.623 6.668 3.038 1.145 0.7645 0.1885 0.0967741935483871 7.899 6.042 2.947 1.117 0.7458 0.1834 0.129032258064516 5.353 4.087 1.869 1.034 0.6906 0.1703 0.161290322580645 5.283 4.06 1.709 0.7435 0.4963 0.1224 0.193548387096774 3.929 2.932 1.263 0.5169 0.3449 0.08504 0.225806451612903 3.851 2.855 1.208 0.4868 0.3248 0.0801 0.258064516129032 2.378 1.782 1.187 0.4615 0.308 0.07595 0.290322580645161 2.106 1.765 0.9975 0.4399 0.2936 0.07221 0.32258064516129 2.021 1.505 0.8868 0.3386 0.2259 0.055820.1 7.6444 5.8465 2.8392 1.1087 0.74028 0.18209 Average of yearly averages: 0.059818 Inputs generated by pe4.pl 

### - 8-August-2003 Data used for this run: Output File: STAR-TXs Metfile: w13958.dvf PRZM scenario: TXsorghumOP.txt EXAMS environment file: pond298.e~~ Chemical Name : fluroxypyr Description Variable Name Value Units Cononents Molecular weight mwt 255.03 g/mol Henry's Law Const. henry 0.0005 atm-mA3/mol Vapor Pressure vapr 9.43-7 torr Solubility sol 7950 mg/L Kd Kd mg/LKoc Koc 68 mg/L Photolysis half-life kdp 0 days Half-life Aerobic Acpatic Metabolism kbacw 42 days Halfife Anaerobic Aquatic Metabolism kbacs 24 days Halfife Aerobic Soil Metabolism asm 14 days Halfife Hydrolysis: pH 5 0 days Half-life Hydrolysis: pH 7 0 days Half-life Hydrolysis: pH 9 0 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 0.14 kg/ha Application Efficiency: APPEFF 0.95 fraction Spray Drift DRFT 0.05 fraction of application rate applied to pond Application Date Date 1-5 dd/rnm or dd/mor dd-m or dd-mm Interval 1 interval 14 days Set to 0 or delete line for single aPP

## - Record 17: FILTRA IPSCND 1 UPTKF Record 18 : PLVKRT I PLDKRT I FEXTRC 0.5 Flag for Index Res. Run IR Pond I Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)