OFFICE OF 

CHEMICAL SAFETY AND 

POLLUTION PREVENTION

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

PC Code: 125620

DP Barcode: 425625

Date: September 17, 2015

MEMORANDUM 

SUBJECT: Problem Formulation for the Ecological Risk and Drinking Water 

Exposure Assessments to be Conducted in Support of the Registration 

Review for Triticonazole; DP Barcode D425625. 

FROM: Nicholas Mastrota, Ph.D., Wildlife Biologist 

Melanie Biscoe, M.E.M, Physical Scientist 

Environmental Risk Branch 3 

Environmental Fate and Effects Division (7507P) 

REVIEWED Rosanna Louie-Juzwiak, Risk Assessment Process Leader 

BY:

James Hetrick, Ph.D., Senior Advisor 

Environmental Risk Branch 3 

Environmental Fate and Effects Division (7507P) 

THROUGH: Dana Spatz, Branch Chief 

Environmental Risk Branch 3 

Environmental Fate and Effects Division (7507P) 

TO: Kelly Sherman, Branch Chief 

Miguel Zavala, Chemical Review Manager 

Risk Management and Implementation Branch 3 

Pesticide Re-Evaluation Division (7508P) 

1. Executive summary

The Environmental Fate and Effects Division (EFED) has completed the problem formulation 

for the ecological risk and drinking water assessments to be conducted as part of the registration 

review of the fungicide triticonazole (PC code 125620). The problem formulation describes the 

methods planned to be used during the completion of drinking water and ecological risk 

assessments in support of registration review, and provides an overview of the environmental 

fate, ecological effects, and potential risks associated with the use of triticonazole. Uncertainties 

unique to the risk assessment of triticonazole are also discussed. 

JAMES 

HETRICK

Digitally signed by JAMES 

HETRICK 

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

ou=USEPA, ou=Staff, cn=JAMES 

HETRICK, 

dnQualifier=0000005599 

Date: 2015.09.17 11:29:21 

-04'00'

1
2

The following fate data are recommended to support the fate dataset for triticonazole:

• Guideline 850.6100, Analytical Method in Water: the Environmental Chemistry Method 

(ECM) and Independent Laboratory Validation (ILV) studies for triticonazole and its 

transformation products

• Guideline 850.6100, Analytical Method in Soil: the ILV study for triticonazole and its 

transformation products

The following new ecological effects studies are recommended for reducing uncertainty in the 

ecological risk assessment for triticonazole:

• Guideline 850.2300, Avian Reproduction Test with the northern bobwhite (TGAI)

• Guideline 850.1035, Mysid Acute Toxicity Test (TGAI)

• A honey bee acute oral study with adult bees (OECD 213) (TGAI)

• A honey bee acute oral toxicity study with bee larvae (OECD 237) (TGAI)

• A honey bee chronic oral toxicity study with adult bees (TGAI)

• A honey bee chronic oral toxicity study with bee larvae (TGAI)

In addition, the following higher-tier honey bee studies may be required, depending on the 

results that are obtained in the tier I studies:

• Residues in Pollen and Nectar/Field Residue Analysis (non-guideline study, tier II) (TEP)

• Semi-field testing (tunnel or colony feeding study, Tier II) (TEP)

• Field testing for pollinators (OCSPP guideline 850.3040, tier III) (TEP).

Introduction

EFED evaluated the most recent ecological risk assessments for triticonazole in association with 

the current toxicity, exposure, and usage information to determine if sufficient data are available 

and if further updates are needed to support registration review. Recent risk assessments include 

a 2013 ecological risk assessment for the use of triticonazole on the expansion of ornamental 

plant uses (D402686) and a 2013 drinking water assessment updating drinking water exposure 

estimates for turf and evaluating the ornamental plant use expansion (D402685). In addition, 

EFED considered the latest Agency science policies and risk assessment methodologies. 

Mechanism of Action

Triticonazole is in the triazole family of fungicides, and product labels claim it is systemic. Like 

other triazole fungicides, triticonazole acts by inhibiting the biosynthesis of sterols. Its mode of 

action places it in the class called sterol biosynthesis inhibitors (BSIs) and the subclass called de-
3

methylation inhibitors (DMIs) (FRAC, 2013). The target of triazole fungicides is a specific 

enzyme of sterol biosynthesis, C14 demethylase. Inhibition of this enzyme inhibits sterol 

production, which interferes with the development of cell membranes and cell walls, thereby 

resulting in abnormal fungal growth and eventual death (Mueller, 2006).

2. Use Characterization

Triticonazole is a broad-spectrum fungicide used to control and suppress certain fungal diseases. 

It is registered for use in seed treatments for barley, corn, oats, rye, sorghum, triticale, and wheat. 

Application rates for seed treatments are given in terms of weight of triticonazole applied to 

weight of seed. Application rates range from 0.01 to 0.05 pound active ingredient (a.i.) per 100 

pound of seed. Maximum application rates in terms of pounds a.i. per acre treated are not 

specified on bags of seed treated with triticonazole. As a result, EFED has estimated per-acre 

maximum application rates by multiplying the pounds a.i.-per-seed rates by maximum expected 

seed planting rates (seeds per acre) provided by the Biological and Economic Analysis Division, 

as shown in Table 1. 

Table 1. Application Information for Seed Treatment Uses of Triticonazole.

Seed Type

Maximum 

Application Rate

(lb a.i./100 lb seed)

Estimated Maximum 

Seeding Rate

(lb seed/Acre)1

Estimated Max 

Application Rate

(lb a.i./A)

Barley 0.01 138.3 0.0138

Corn (sweet, field, and pop) 0.05 33.2 0.0166

Oat 0.01 90 0.0090

Rye 0.01 90 0.0090

Sorghum 0.02 9.1 0.0018

Triticale 0.01 109 0.0156

Wheat 0.01 156 0.0156 1 Maximum seeding rates were obtained from the Biological and Economic Analysis Division Memo entitled Acres 

Planted per Day and Seeding Rates of Crops Grown in the United States, signed March 2011. 

Triticonazole is also registered for use as a broadcast or spray application to ornamentals, 

residential lawns, commercial and industrial lawns, golf course turf, ornamental lawns and turf, 

ornamental sod farms, recreation area lawns, Christmas tree plantations, conifer plantations and 

nurseries, forest trees, nursery stock, ornamental and shade trees, ornamental herbaceous plants, 

ornamental woody shrubs and vines, and roses. For non-seed treatment uses, application 

equipment include tank-type sprayers, hose-end sprayers, aircraft, ground equipment, spreaders, 

and pressurized can. There is one granular product containing triticonazole that is registered for 

use on turf and sod farms (EPA Reg. No. 7969-304). There is one pressurized liquid product 

registered for fog treatment of ornamental plants in greenhouses (EPA Reg. No. 499-555). The 

chemical profile produced by BEAD, located in the docket, lists the use patterns of maximum 

exposures for the current uses Triticonazole. EFED will use application scenarios that result in 

maximum exposure scenarios for a given use for the risk assessment. Any absence of 

information on the labels that specifies the maximum single application rate, the application 

interval, the annual maximum rate allowed (lbs a.i./year), or application method may result in 

conservative assumptions.
4

3. Conclusions from Previous Risk Assessments

a. Ecological Risk Assessments

Previous ecological risk assessments have used a Total Toxic Residue (TTR) approach to assess 

potential ecological risk from use of triticonazole because triticonazole transforms to the Z 

isomer or degrades to hydroxylated compounds that are structurally similar to the parent in the 

environment. Previous assessments have characterized the environmental fate of triticonazole

and its residues as highly persistent and moderately mobile in soil, with its leaching potential 

verified in terrestrial field dissipation studies and groundwater detection in the USDA Pesticide 

Data Program. Triticonazole has been found to have a low potential to bioaccumulate based on

bioconcentration factors of 14x (edible tissue), 157x (inedible tissue), 94x (whole fish) in 

juvenile bluegill sunfish (Lepomis macrochirus) with a > 98% depuration in 3 days.

Previously completed ecological risk assessments for triticonazole are summarized in Table 2. 

Risk assessments for current triticonazole uses predict that chronic exposure may cause adverse 

effects to fish, aquatic invertebrates, and terrestrial vertebrates (birds, mammals, reptiles, and 

terrestrial phase of amphibians). Some assessments also predict risk to terrestrial plants and to 

nonvascular aquatic plants. Ecological risk assessment for seed treatment uses of triticonazole 

have identified chronic risk to some taxa. An assessment for use of triticonazole as a fog 

treatment inside greenhouses concluded negligible risk to non-target organisms due to the 

minimal exposure to organisms outside of the greenhouse.

Table 2. Summary of Conclusions of Previous Risk Assessments Conducted by EFED on Triticonazole. 

Use Reference Max. Application Rate

Taxa for which risk was 

identified at the Agency’s 

concern levels

Previously Assessed Uses

Seed treatment use on wheat 

and barley 

D260430, 

D260433,

D260435,

D262200,

D275686,

D275785,

D275908

(2002)

0.0049-0.0069 lb a.i./A No significant risk to non-target 

organisms

Turf 0.58 lb a.i./A

3.48 lb a.i./A annually

Acute risk to freshwater fish, 

saltwater invertebrates, plankton, 

and some listed species of birds 

and mammals. Chronic risk to 

freshwater and saltwater fish

(using ACR for other conazoles), 

freshwater and saltwater 

invertebrates, birds, reptiles, and 

terrestrial-phase amphibians. Risk 

to some aquatic and terrestrial 

plants.

Turf D313848, 

D314324

(2006)

1.15 lb a.i./A

3.45 lb a.i./A annually

Chronic risk to freshwater fish, 

freshwater invertebrates, saltwater 

invertebrates, birds, reptiles, and 

terrestrial-phase amphibians. Risk 

to terrestrial dicot plants.

Seed treatment use on cereal 

grains (barley, corn, oats, rye, 

sorghum, triticale, and wheat)

D358616

(2009)

0.013-0.076 lb a.i./A Chronic risk to freshwater fish, 

freshwater invertebrates, and 

seed-eating birds. Risk to listed 
5

Use Reference Max. Application Rate

Taxa for which risk was 

identified at the Agency’s 

concern levels

Previously Assessed Uses

(0.02-0.05 lb a.i./cwt seed

and seeding rate of 150 lb 

seed/A)

species of plants (wetland dicots 

only).

Ornamental plants and turf 

(granular application)

D372455 and 

D376793

(2010)

0.56 lb a.i./A

2.8 lb a.i./A annually

Possible acute risk to listed birds 

(i.e., non-definitive endpoints 

failed to preclude risk to listed 

species). Chronic risk to 

freshwater fish, freshwater 

invertebrates, saltwater 

invertebrates, mammals, birds, 

reptiles, and terrestrial-phase 

amphibians. Risk to terrestrial 

plants, and aquatic nonvascular 

plants (listed only)

Turf (granular application) D429730

(2011)

0.56 lb a.i./A

2.81 lb a.i./A annually

Chronic risk to freshwater fish, 

freshwater invertebrates, saltwater 

invertebrates, mammals, birds, 

reptiles, and amphibians. Risk 

terrestrial plants, and aquatic 

nonvascular plants (listed only)

Ornamental plants in indoor 

greenhouses

D391500

(2011)

2 cans per 3,000 ft2 No risk to nontarget organisms.

Turf, ornamental plants, 

nursery trees, Christmas trees

D402686 

(2013)

Turf:

1.15 lb a.i./A

3.45 lb a.i./A annually

Ornamentals:

0.475 lb a.i./A

2.85 lb a.i./A annually

Chronic risk to freshwater fish and 

saltwater invertebrates. Chronic 

risk to terrestrial animals. Acute 

risk to birds. Risk to terrestrial 

plants.

ACR = acute-to-chronic ratio

The major ecological risk and exposure conclusions from previous assessments are summarized 

in Table 3.

Table 3. Major Risk and Exposure Conclusions from Previous Triticonazole Assessments

Birds Mammals Terr.

Plants

Terr.

Inverts Fish BCF Aquatic Inverts

Aquatic 

Plants

Groundwater 

Contamination Persistence Degradates of Concern

√ √ √ √ -- √ √ √ √ √

b. Drinking Water Exposure Assessments

A drinking water exposure assessment for turf and ornamental uses was conducted for 

triticonazole in 2013 (D402685). Surface water exposure estimates of triticonazole from turf, the 

use that produces maximum drinking water exposures, were 157 μg/L (1-in-10-year peak), 116

μg/L (1-in-10-year annual mean), and 81 μg/L (30-year mean). Using the PRZM-GW model, 
6

groundwater exposure estimates from the turf use for the 30-year simulation were 10 μg/L 

(peak), and 2 μg/L (post-breakthrough average). For each PRZM-GW scenario, the daily 

concentration values calculated for the 30-year simulation indicated that higher ground water 

concentrations may be expected to occur over a time period greater than 30 years, assuming that 

the maximum annual application is applied every year. Consequently, concentrations were 

calculated for a 100-year simulation with resulting estimates of 520 μg/L (peak) and 166 μg/L 

(post-breakthrough average) for the turf use.

c. Clean Water Act Programs

Triticonazole is not identified as a cause of impairment for any water bodies listed as impaired 

under section 303(d) of the Clean Water Act1

. In addition, no Total Maximum Daily Loads 

(TMDL) have been developed for triticonazole2. More information on impaired water bodies and 

TMDLs can be found at the Agency’s website3. The Agency invites submission of water quality 

data for this pesticide. To the extent possible, data should conform to the quality standards in 

Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and 

Other Water Quality Data in OPP’s Registration Review Risk Assessment and Management 

Process4 in order to ensure they can be used quantitatively or qualitatively in pesticide risk 

assessments. Aquatic benchmarks5 have not been established for triticonazole. Any data 

submitted or otherwise located as part of the registration review process may be used to update 

aquatic life benchmarks, if applicable.

4. Environmental Fate and Transport

Structures, chemical names, and other identifiers of triticonazole, its stereoisomer and its 

transformation products are given in Appendix A.

Laboratory fate studies and field dissipation studies indicate that triticonazole is moderately

mobile in the environment (FAO 2000). Triticonazole’s Freundlich soil-water partition 

coefficients range from 4.1 to 14.4 and its organic carbon-normalized Freundlich coefficients 

range from 344 to 812. In a lysimeter study focused on fate and transport of triticonazole applied 

as a seed treatment, dissipation of triticonazole into the surrounding soil and leaching to below

the 35 cm soil depth was observed with no clear pattern of degradation over an 18-month period 

(MRIDs 44802132, 44904514). Triticonazole is not expected to volatilize under field conditions.

Triticonazole is persistent in aerobic soil and water; aerobic soil metabolism half-lives range 

from 81 to 715 days in warm temperatures (20-25°C), and the aerobic aquatic metabolism halflife is 210 days (25°C). It is also resistant to degradation in soil as a result of photolysis (half-life 

of 92 days). Triticonazole is stable to microbial degradation under anaerobic conditions. 

 1 http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=885

2 http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id=885&p_pollutant_group_name=PESTICIDES 3 http://www.epa.gov/owow/tmdl/ 4 http://www.epa.gov/oppsrrd1/registration_review/water_quality_sop.htm

5 http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm
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Photolysis in water results in transformation to the Z isomer via E-Z isomerization. Results from

terrestrial field dissipation studies and a lysimeter study suggest that triticonazole residues may

accumulate from year to year. Environmental fate data for triticonazole are summarized in Table 

4.

Bioconcentration of triticonazole was studied in juvenile bluegill sunfish (Lepomis macrochirus, 

MRID 44922311). Maximum bioconcentration factors were 14x for the muscle (edible) tissue, 

157x for the visceral (nonedible) tissue, and 94x for the whole fish. These results indicate that 

triticonazole does not bioconcentrate to a significant extent.

Triticonazole may be transformed in the environment via 1) E-Z isomerization, 2) hydroxylation, 

or 3) stepwise mineralization and potential formation of 1,2,4-triazole. With the exception of 

1,2,4-triazole and 1,2,4-triazole acetic acid, triticonazole’s transformation products observed in 

the laboratory and field studies are structurally similar to the parent and are expected to have 

similar physical, chemical and toxicological properties. Based on their structural similarity and 

observations in field and laboratory studies, these transformation products are expected to be 

moderately mobile and are not expected to undergo significant degradation in the environment.

Table 4. Chemical Properties and Environmental Fate Parameters of Triticonazole.

Parameter Value Description Source

Selected Physical/Chemical Parameters

Molecular mass (molecular 

formula)

317.82 g/mol (C7H3Cl2N) -- (Calculated)

Vapor pressure (50°C) 7.5 x 10-9 torr MRID 44802008

Aqueous solubility (20°C) 9.9 mg/L MRID 44802006

Henry’s Law Constant (20°C) 3.2 x 10-10 atm-m3/mol (Calculated with 

vapor pressure at 50 

°C assumed to be the 

same at 20°C)

Log octanol-to-water partition 

coefficient

(log KOW)

3.29 MRID 44802002

Persistence

Hydrolysis half-life (25°C) Stable at pH 5, 7, 9 MRID 44922305

Aqueous photolysis isomerization 

rate (25°C, 30°N, 22°C 40°N for 

the respective MRIDs)

7.5 hours to 48 days Isomeric conversion 

mechanism.

MRID 44922306, 

47296302

Soil photolysis half-life (20°C, 

50°N)

92.4 days MRID 44802123
8

Parameter Value Description Source

Aerobic soil metabolism half-life 

[dissipation half-life A] (22°C;

25°C; 10 and 22°C; and 10 and 

25°C for the respective MRIDs)

Sandy loam: 301 days at 

22°C (linear/natural log)

Clay loam: 141 days at 22°C

(linear/natural log)

Speyer 2.2 artificial loamy 

sand: 257 days at 22°C

(nonlinear/normal)

Sharkey clay soil: 715 days 

at 25°C (linear/natural log)

Loamy sand: 344 days at 

22°C (linear/natural log)

Loamy sand: 691 days at 

10°C (linear/natural log)

Sandy loam: 359 days at 

10°C (linear/natural log)

Clay loam: 224 days at 10°C

(linear/natural log)

Speyer 2.2 loamy sand: 

stable at 10°C (1,800 days; 

DFOP)1

Sandy loam: 187 days at 

25°C (nonlinear/normal)

Sandy loam: 693 days at 

10°C (linear/natural log)

CA sand: 307 days at 20°C

(linear, calculated by study 

author)

NJ loam: 81 days at 20°C

(linear, calculated by study 

author)

WI sand: 120 days at 20°C

(linear, calculated by study 

author)

MRIDs 44802124 in 

conjunction with

45749206;

44802126;

44802125; 

45749205; 

(49017701)

Anaerobic soil metabolism half-life 

(25°C) Stable MRID 44922308

Aerobic aquatic metabolism halflife [dissipation half-life A] (25°C) 210 days MRID 47296301

Anaerobic aquatic metabolism halflife (20°C) Stable MRID 44922309
9

Parameter Value Description Source

Mobility

Freundlich soil-water partition 

coefficients (KF); organic carbonnormalized Freundlich coefficients 

(KFOC)

4.1-14.4 L/kg;

344 – 812 L/kgOC

MRID 44802129

Field Dissipation

Terrestrial field dissipation halflife; leaching depth

Pre-plant wheat application 

169 d 

(0-0.15 m depth; WA 

Timmerman sandy loam); 

leached to 0.15 m depth

MRIDs 44802132, 

44904514

California

Bareground 925 d 

(0-15m depth; sandy loam)

leached to 0.60- 0.75 m 

depth

Turf grass 61 d

North Carolina

Bareground 116 d 

(0-15m depth; Norfolk 

sandy loam) leached to 0.75-

0.90 m depth

Turf grass 64 

Washington

Bareground 160 d 

(0-15m depth; WA Quincy 

loamy fine sand) leached to 

0.75-0.90 m depth

Turf grass 140 d 

MRIDs 44802133, 

44904513, 

44922310

Fish Bioconcentration

Fish bioconcentration factors 

(steady-state); depuration rate

14x (edible), 157x 

(inedible), 94x (whole); >

98% depuration in 3 days

Low bioconcentration 

potential

MRID 44922311

Parentheses around the MRID number indicate study is currently in review.

1 Calculated according to EFED’s 2012 Standard Operating Procedure for Using the NAFTA Guidance to Calculate 

Representative Half-life Values and Characterizing Pesticide Degradation.

a. Transformation Products

In the environment, triticonazole transforms to a cis-isomer (i.e., Z-isomer), several hydroxylated 

compounds (RPA 406341, RPA 406780, RPA 407922 and RPA 404766, RPA 404886, RPA 

405826, Reg. No. 5059144, Reg. No. 5079285), 1,2,4-triazole, and 1,2,4-triazole acetic acid.

Table 5 summarizes the prevalence of each triticonazole transformation product in the 

environmental fate studies.
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With the exception of 1,2,4-triazole, and 1,2,4-triazole acetic acid, the toxicological and 

environmental fate properties of the degradates observed in environmental fate laboratory and 

field studies have not been measured. Triticonazole’s Z isomer and hydroxylated degradates, due 

to their structural similarity to the parent, are assumed to be equivalent to triticonazole in 

persistence, mobility, and toxicity for the purposes of risk assessment. 

Triticonazole’s Z isomer (RPA 406203) and four transformation products, (RPA 406341, RPA 

406780, RPA 407922 and RPA 404766) were detected at >10% applied radioactivity in 

submitted environmental fate studies. In addition, six minor transformation products (Reg. No.

5059144, Reg. No. 5079285, RPA 404886, RPA 405826, 1,2,4-triazole, and 1,2,4-triaozle acetic 

acid) were also detected in the studies (<10%). The Z isomer is formed primarily by photolysis, 

forming up to 45% of applied radioactivity in irradiated water and 11% of radioactivity in 

irradiated soil. 

In the field dissipation studies, the Z isomer was formed upwards of 46% applied radioactivity

and was detected at the 15-30 cm soil depth. Major degradates RPA 406341, RPA 406780, RPA 

407922, and RPA 404766 are primarily formed via microbially-mediated hydroxylation of the 

parent in aerobic soil. Maximum RPA 406341 formation ranged from 9-17% in the aerobic soil 

metabolism studies, and the compound consistently began degrading by the end of the studies.

RPA 406341 was also detected at the 45-60 cm sample depth. 

Similarly, maximum RPA 406780 formation in aerobic soil ranged from 7-14% with slight 

declines by the end of the studies. The other two major hydroxylated degradation products, RPA 

407922 and RPA 404766, were formed at maxima of 2-15% and 4-10%, respectively, and 

degradation was rarely observed at study termination. Minor degradates Reg. No. 5059144, Reg. 

No. 5079285 are enantiomers of each other and were individually detected at 8% and 9% in one 

aerobic soil metabolism study, respectively, declining slightly by study termination. Minor 

transformation product RPA 404886 was observed at 4% or less in the aerobic soil metabolism 

studies and typically began declining by the end of the studies. RPA 405826 was only observed 

at <1% applied radioactivity in the anaerobic soil metabolism study.

Over the past decade, there has been concern over the potential for the conazole fungicides to 

degrade in the environment to triazole or triazole conjugates. The degree of formation of 1,2,4-

triazole and triazole metabolites in plants, animals, and the environment is highly dependent on 

the properties of the various parent conazole fungicides (2/28/2006; DP 320682). 1,2,4-triazole 

and 1,2,4-triazole acetic acid were detected at < 5% in an aerobic soil metabolism study 

conducted in 2012. No free or conjugated triazoles of concern were measured in studies 

previously submitted. Although these earlier studies were not specifically designed to quantify 

the triazoles, a follow-up study (MRID 45749201) analyzed samples from one of the earlier 

aerobic soil metabolism study (MRID 44802125) and determined that 1,2,4-triazole was not 

formed as a result of aerobic soil metabolism in that study. 

FAO. 2000. Appendix 2. Parameters of pesticides that influence processes in the soil. In FAO 

Information Division Editorial Group (Ed.), Pesticide Disposal Series 8. Assessing Soil 

Contamination. A Reference Manual. Rome: Food & Agriculture Organization of the United 

Nations (FAO).
11

FRAC, 2013. Fungicide Resistance Action Committee. http://www.frac.info/

Mueller, D. 2006. Fungicide: Triazoles. Iowa State University, University Extension Service. 

IC-496(13). May 30, 2006. http://www.ipm.iastate.edu/ipm/icm/2006/5-30/fungicides.html

US EPA. EFED Risk Assessment for the Proposed New Use of Triticonazole on Ornamental 

plants (Reg. No. 7969-257). July 25, 2013. EFED Memorandum for DP 402686.

US EPA. Triticonazole: Tier I and II Drinking Water Exposure Assessment for Existing Turf 

Uses and the Proposed Expansion of Ornamental Use on the Trinity® Fungicide Label (Reg. No. 

7969-257). April 3, 2013. EFED Memorandum for DP 402685.
12

Appendix presents the structures of triticonazole transformation products and summarizes the 

maximum amounts of formed in the environmental fate studies. Based on repeated long-term 

detections in both the field dissipation study and the aerobic soil metabolism study, the 

hydroxylated products appear to be persistent and mobile. 

In the fish bioconcentration study, RPA 404886 and RPA 405826 comprised < 7% of total 

radiolabeled residues while their glucuronide conjugates (I and II) comprised 20-43% of total 

radiolabeled residues. Another metabolite, RPA 406972, was also present at 9-21% of total 

radiolabeled residues. Other residues were also present at levels below 4%.

Table 5. Triticonazole Transformation Products Identified in Environmental Fate Studies.

Degradates Hydrolysis Photolysis 

(water)

Photolysis 

(soil)

Aerobic 

Soil

Anaerobic 

Soil

Terrestrial 

Field

RPA 406203 

(Z isomer) -- Xa Xa X -- X

RPA 406341 -- -- X Xa X X

RPA 406780 -- -- -- Xa -- --

RPA 407922 -- -- -- Xa -- --

RPA 404886 -- -- -- X -- --

RPA 404766 -- -- X Xa X --

RPA 405826 -- -- -- X --

Reg. No. 5059144 -- -- -- X -- --

Reg. No. 5079285 -- -- -- X -- --

1,2,4-triazole -- -- -- X -- --

1,2,4-triazole 

acetic acid -- -- -- X -- --

a - major degradates (>10%)

5. Receptors

a. Toxicity Overview

Triticonazole showed no acute toxicity to birds, mammals, or bees when tested at the limit doses, 

classifying the pesticide as practically nontoxic to these taxa. However, some subacute toxicity 

was observed in chronic tests. Triticonazole is classified as moderately toxic to aquatic 

invertebrates and as no more than moderately toxic fish. Triticonazole is toxic to some plants at 

tested exposure levels. Dicotyledonous plants are more sensitive to triticonazole than 

monocotyledonous plants. Diatoms appear to be the most sensitive aquatic plants. Additional 

details on toxicity testing of aquatic and terrestrial organisms are provided below.

b. Effects to Aquatic Organisms

Table 6 summarizes the toxicity endpoints of sensitive species that will be used to assess the risk 

of triticonazole to aquatic organisms. Based on the available data, triticonazole is classified as no 

more than moderately toxic to freshwater and saltwater fish (based on non-definitive endpoints), 
13

and moderately toxic to freshwater and saltwater invertebrates on an acute basis. Complete 

chronic toxicity data are available with both freshwater and saltwater species of fish and 

invertebrates. The fathead minnow is the most sensitive fish species, with growth effects 

observed in an early life-stage study at concentrations as low as 51 μg a.i./L, and a NOAEC 

established at 21 μg a.i./L. A full life-cycle study with this species found slightly higher toxicity 

endpoints. The saltwater mysid was the most sensitive aquatic invertebrate species, with toxic 

effects observed at concentrations as low as 41 μg a.i./L, and a NOAEC established at 25 μg 

a.i./L.

An aquatic plant and algal toxicity testing found that various taxa vary greatly in their sensitivity 

to triticonazole, with IC50 values ranging from 0.35 mg a.i./L to >2.5 mg a.i./L. The most 

sensitive test species is the marine diatom (IC50 0.35 mg a.i./L, NOAEC 0.033 mg a.i./L). 

Freshwater diatoms are also sensitive to triticonazole (IC50 0.79 mg a.i./L, NOAEC 0.17 mg 

a.i./L, MRID 44802117). Duckweed was not highly sensitive, but it should be recognize 

duckweed is a monocotyledonous plant, and monocotyledonous plants have been shown to be 

less sensitive to triticonazole than dicotyledonous plants. Therefore, triticonazole may be more 

toxic to dicotyledonous aquatic plants.

1,2,4-Triazole and its conjugates that are degradation products of triticonazole have been found 

to be less toxic to aquatic organisms than the parent compound (toxicity data are presented in 

Appendix C) and are expected to form in the environment in only small amounts. Therefore, 

these degradation products are not expected to contribute significantly to the total toxicity of 

triticonazole to aquatic organisms.

Table 6. Summary of the Most Sensitive Endpoints from Aquatic Toxicity Studies for Triticonazole.

Taxonomic 

Group

Study 

Type Surrogate Species

Toxicity Value

(all units in terms of 

active ingredient)

Acute Toxicity 

Classification

Source (Study 

Classification)

Freshwater fish1

Acute

Rainbow Trout

(Oncorhynchus 

mykiss)

LC50 > 2.3 mg/L

No more than 

moderately 

toxic

44802020

(Supplemental2)

Chronic 

(Early 

life-stage)

Fathead Minnow

(Pimephales promelas)

NOAEC: 21 μg/L

LOAEC: 51 μg /L

Endpoint: Reduced 

weight

-- 44802027

(Acceptable)

Chronic 

(Life 

cycle)

Fathead Minnow

NOAEC: 47.3 μg/L3

LOAEC: 93.7 μg /L

Endpoints: Reduced 

length and weight, 

curvature of the spine

-- 48819801

(Acceptable)

Freshwater 

invertebrates

Acute Water Flea 

(Daphnia magna) EC50 = 7.6 mg/L Moderately 

toxic

44802021

(Supplemental2)

Chronic Water Flea 

NOAEC: 0.11 mg/L

LOAEC: 0.21 mg/L

Endpoint: Reduced 

number of young per 

female

-- 48842801

(Acceptable)
14

Taxonomic 

Group

Study 

Type Surrogate Species

Toxicity Value

(all units in terms of 

active ingredient)

Acute Toxicity 

Classification

Source (Study 

Classification)

Estuarine/marine 

fish

Acute

Sheepshead Minnow 

(Cyprinodon 

variegatus)

LC50 > 5.7 mg/L

No more than 

moderately 

toxic

44802023

(Supplemental4)

Chronic Sheepshead Minnow

NOAEC: 0.122 mg/L

LOAEC: >0.122 mg/L

(No adverse effects 

observed)

-- 46876702

(Acceptable)

Estuarine/marine 

invertebrates

Acute

Mysid

(Americamysis bahia) EC50 = 1.6 mg/L Moderately 

toxic

44922304

(Supplemental2,5

)

Eastern Oyster

(Crassostrea 

virginica)

EC50 = 8.8 mg/L Moderately 

toxic

44802024

(Supplemental2)

Chronic Mysid

NOAEC = 25 μg a.i./L

LOAEC = 41 μg a.i./L

Endpoint: Reduced 

number of young per 

female

-- 46876703

(Acceptable)

Aquatic plants 

and algae

Vascular Duckweed 

(Lemna gibba)

NOAEC: 0.33 mg/L

IC50 = 1.4 mg/L -- 44802119(Acceptable)

Nonvascular

Marine diatom

(Skeletonema 

costatum)

NOAEC: 0.033 mg/L

IC50 = 0.35 mg/L -- 44802121

(Acceptable)

1 Freshwater fish may be surrogates for aquatic-phase amphibians. 2 Because the test was conducted at close to the solubility limit and because water samples were not filtered before analysis, the 

measured concentration at the highest test level may represent the total concentration, including undissolved test material, rather 

than the soluble fraction. This may have caused the toxicity of dissolved triticonazole to be slightly underestimated. 3 This acceptable study revised the life-cycle toxicity endpoints from a previously submitted supplemental study (MRID 

47622101). The previous NOAEC that was used in earlier assessment was 12 μg a.i./L. 4 The study was classified as “Supplemental” because of uncertainty of the NOAEC determination; however, the conclusion 

concerning the LC50 was considered valid and acceptable. 5 The study data did not fit a clear dose-response relationship with higher mortality observed in lower exposure levels than in

some higher exposure levels.

c. Effects to Terrestrial Organisms

Error! Reference source not found. summarizes the toxicity endpoints of sensitive species that 

will be used to assess the risk of triticonazole to terrestrial organisms. Triticonazole has very low 

acute toxicity to terrestrial animals. On an acute toxicity basis, triticonazole is classified as 

practically nontoxic to birds, mammals, and bees. The only sublethal effects observed in the 

acute studies were in acute studies with laboratory rats, in which a transient decrease in activity 

and ataxia were observed. The rat behavior returned to normal within two days. Triticonazole is 

more toxic to birds on a chronic basis. The northern bobwhite was found to be more sensitive 

than the mallard, with adverse reproductive effects observed at dietary concentrations as low as 

172 mg a.i./kg-diet. Since adverse effects were observed at all test concentrations, the NOAEC 

was undetermined. Less chronic toxicity was observed in mammals, with parental and 

reproductive effects observed in the rat at a dietary concentration of 5000 mg a.i./kg-diet 

(NOAEC 750 mg a.i./kg-diet). 
15

Triticonazole is toxic to some terrestrial plants. Effects on seedling emergence occurred at 

considerably lower rates than effects on the growth (vegetative vigor) of emerged plants. The 

most sensitive terrestrial plant species was lettuce, for which the IC50 and NOAEC for seedling 

emergence effects were 0.015 and 0.0040 lb a.i./A, respectively.

1,2,4-Triazole, a degradation products of triticonazole, has been found to be somewhat more

toxic to terrestrial animals than the parent compound. The acute oral LD50 for the rat is 1375 

mg/kg for 1,2,4-triazole (MRID 45284008), whereas it is >2000 mg a.i./kg for triticonazole

(MRID 44802028). The acute oral LD50 for the bobwhite quail is 770 mg/kg for 1,2,4-triazole 

(MRID 49380701), whereas it is >1910 mg a.i./kg for triticonazole (MRID 44922301).On a 

chronic basis, a 1,2,4-triazole concentration of 250 mg/kg-diet caused reduced body weight, 

decreased body weight gain, and reduced brain and spleen weights in rats (MRID 46467304), 

whereas a triticonazole concentration of 750 mg a.i./kg-diet did not cause any observable effects 

(MRID 44933604). However, acute toxicity data for fish and aquatic invertebrates show 1,2,4-

triazole has little toxic to aquatic organisms. Therefore, the ecological risk assessment for 

triticonazole will include a separate analysis to determine if formation of 1,2,4-triazole as a result 

of triticonazole use poses a risk to terrestrial animals. Avian and mammalian toxicity endpoints 

for 1,2,4-triazole that are to be used in the risk assessment are presented in Table 7. The complete 

set of ecotoxicity data on 1,2,4-triazole and its conjugates are provided in Appendix C.

Table 7. Summary of the Most Sensitive Endpoints from Terrestrial Toxicity Studies for Triticonazole and 

1,2,4-Triazole.

Taxonomic 

Group

Study 

Type Surrogate Species

Toxicity Value

(all units in terms of 

active ingredient)

Acute Toxicity 

Classification

Source (Study 

Classification)

Triticonazole

Birds1

Acute

Northern Bobwhite

(Colinus virginianus)

and 

Mallard (Anas 

platyrhynchos)

LD50 > 1910 mg/kg-bw Practically 

nontoxic2

44922301

& 44922302

(Acceptable)

Sub-acute 

dietary

Northern Bobwhite 

and Mallard

LC50 > 5000 mg/kg-diet

(No signs of toxicity)

Practically 

nontoxic

44922303

& 44802016

(Acceptable)

Chronic Bobwhite quail

NOAEC: < 172 mg/kg 

diet

LOAEC: 172 mg/kg diet

Endpoints: Reduced egg 

hatchability, reduced 

hatchling survival, and 

reduced hatchling weight

-- 47296304

(Supplemental3)

Mammals

Acute Oral Laboratory rat 

(Rattus norvegicus)

LD50 > 2000 mg/kg-bw

(Decreased motor activity 

and ataxia observed on 

Day 1)

Practically 

nontoxic

44802028

(Acceptable)

Acute 

Inhalation Laboratory rat 

LC50 > 2.63 mg/L

(Decreased activity 

observed on Day 1 and 2)

Toxicity 

Category IV

44802028

(Acceptable)
16

Taxonomic 

Group

Study 

Type Surrogate Species

Toxicity Value

(all units in terms of 

active ingredient)

Acute Toxicity 

Classification

Source (Study 

Classification)

Chronic

Laboratory rat 

(two-generation 

reproductive study)

NOAEL: 750 mg/kg diet

LOAEL: 5000 mg/kg diet

Endpoints: Reproductive 

and parental effects

-- 44933604

(Acceptable)

Insects Acute 

contact

Honey bee 

(Apis mellifera L.) LD50 > 24 μg/bee Practically nontoxic

44802122

(Acceptable)

Terrestrial 

plants

Seedling 

Emergence

Monocot – ryegrass

(Lolium sp.)

IC25 > 4.2 lb/A

NOAEL = 1.3 lb/A

Endpoint: Shoot length

-- 44802116

(Acceptable)

Dicot – lettuce

(Lactuca sativa)

IC25 = 0.015 lb/A

NOAEL = 0.0040 lb/A

Endpoint: shoot length

-- 44802116

(Acceptable)

Vegetative 

Vigor

Monocot – various 

species

IC25 > 4.2 lb/A

NOAEL = 4.2 lb/A

Endpoint: None

-- 44802116

(Acceptable)

Dicot – turnip

(Brassica rappa)

IC25 = 1.3 lb/A

NOAEL = 1.0 lb/A

Endpoint: Dry weight

-- 44802116

(Acceptable)

1,2,4-Triazole

Birds

Acute Northern Bobwhite LD50 = 770 mg/kg-bw No more than 

slightly toxic

49380701

(Acceptable)

Chronic (no data) -- --

Mammals

Acute Laboratory rat LD50 = 1375 mg/kg-bw Slightly toxic 45284008

Chronic Laboratory rat NOAEC < 250 mg/kg-diet

LOAEL = 250 mg/kg-diet -- 46467304(Acceptable)

1 Birds represent surrogates for terrestrial-phase amphibians and reptiles. 2 As no mortality and no signs of toxicity were observed at a dose of 1900 mg a.i./kg-bw, the LD50 is very likely greater than 

2000 mg-ai/kg-bw, the criteria for “practically nontoxic” classification. 3 This study was classified as Supplemental because it failed to determine the NOAEC.

d. Ecological Incidents

A preliminary review of the Ecological Incident Information System (EIIS, version 2.1) in April 

2015 did not identify any ecological incident of adverse field effects to nontarget plants or 

animals attributed to use of triticonazole. Also, review of the Avian Monitoring Information 

System (AIMS), which is maintained by the American Bird Conservancy, did not identify any 

ecological incident associated with the use of triticonazole. 
17

In addition to the incidents recorded in EIIS and AIMS, the Agency maintains a database which 

stores counts of minor incidents that pesticide registrants record in quarterly aggregated incident 

reports. Ecological incidents recorded in these aggregated reports include those categorized as 

‘minor fish and wildlife’ (W-B), ‘minor plant’ (P-B), and ‘other non-target’ (ONT) incidents. 

‘Other non-target’ incidents include reports of adverse effects to insects and other terrestrial 

invertebrates. A review of this database in April 2015 found two incidents that were associated 

with triticonazole and another pesticide ingredient. One minor plant damage incident was 

reported in an aggregated report in 2012 for the product Bug B Gon Insect & Disease Control 

(EPA Reg. No. 8033-108-239, Incident I024402-247). That product contains the neonicotinoid

insecticide acetamiprid as well as triticonazole. A second minor wildlife incident was reported in 

an aggregated report in 2014 for the product “Pillar G” (EPA Reg. No. 7969-304, Incident 

I026079-020). That product contains the insecticide pyraclostrobin as well as triticonazole.

Because these pesticide products contained more than one active ingredient, it is uncertain which 

ingredient caused the observed adverse effects. It is plausible that the minor plant damage 

incident may have been caused by triticonazole. It is unlikely, however, that the minor wildlife 

incident was caused by triticonazole because this ingredient has very low acute toxicity to 

wildlife.

6. Exposure Pathways of Concern

Based on the use pattern and environmental fate characteristics of this pesticide, the following 

exposure pathways are expected to be most relevant for determining exposure and potential risk 

of triticonazole to non-target organisms:

• Direct spray

• Consumption of contaminated water and food items

• Consumption of treated seeds (seed treatment uses only)

• Spray drift (except for seed treatments and granular products)

• Runoff

• Leaching to groundwater

Drinking water and inhalation exposure pathways were screened using the SIP (Screening 

Imbibition Program) and STIR (Screening Tool for Inhalation Risk) screening models to 

determine if they are potential pathways of concern or support requesting data. The results 

indicated that both exposure pathways are of low concern for triticonazole, and additional data 

specific to these exposure pathways are not needed. Sample outputs from these models are 

provided in Appendix D. SIP and STIR are described in detail at: 

http://www.epa.gov/oppefed1/models/terrestrial/index.htm.

7. Analysis Plan

a. Stressors of Concern
18

i. Ecological Risk

The stressors of ecological concern for terrestrial and aquatic organisms fall into three distinct 

groups. The first group includes triticonazole, its cis-isomer and its hydroxylated degradates. 

These compounds are assumed to be equally toxic due to structural similarity, an assumption 

that is supported by ECOSAR results where the majority of toxicity endpoints for triticonazole, 

its cis-isomer, and its hydroxylated degradates fall within an order of magnitude of each other. 

Based on the likelihood of exposure, this is the group for which the bulk of the risk assessment 

will be focused. 

The second group includes 1,2,4-triazole, and the third group 1,2,4-triazole acetic acid. 1,2,4-

triazole and 1,2,4-triazole acetic acid were identified as minor degradates in one aerobic soil 

metabolism study, and each compound has different ecological endpoints as illustrated in 

Appendix C.

1,2,4-triazole is less toxic than triticonazole in all taxa in the aquatic toxicity tests conducted for 

1,2,4-triazole, including freshwater fish (acute and chronic), freshwater invertebrates (acute), and 

aquatic nonvascular plants. With regard to terrestrial organisms, 1,2,4-triazole is more toxic than 

triticonazole to birds on an acute basis and more toxic to mammals on an acute and chronic basis. 

1,2,4-triazole chronic toxicity data have not been submitted for birds. Data submitted for soil 

arthropods are not appropriate for comparing the relative toxicities of 1,2,4-triazole and 

triticonazole for honey bees and other pollinators. No terrestrial plant data have been submitted 

for 1,2,4-triazole. 

1,2,4-triazole acetic acid is less toxic than triticonazole for all taxa of aquatic and terrestrial 

animals tested, including freshwater fish (acute), freshwater invertebrates (acute), and mammals 

(acute and chronic). Data are unavailable chronic toxicity of 1,2,4-triazole to aquatic animals and 

toxicity of 1,2,4-triazole to aquatic plants. Data are also unavailable for acute and chronic 

toxicity of 1,2,4-triazole to birds.

Because the toxicological endpoints indicate that birds and mammals are more sensitive to 1,2,4-

triazole than to triticonazole, the triticonazole risk assessment will also assess risk of 1,2,4-

triazole to birds and mammals as a result of triticonazole use. Since 1,2,4-triazole is more toxic 

to terrestrial animals than 1,2,4-triazole acetic acid, and the exposure potential from both 

compounds is comparable, risk estimates for 1,2,4-triazole are expected to be protective of 

potential risk from 1,2,4-triazole acetic acid as well. Considering the limited extent to which 

triticonazole degrades to 1,2,4-triazole and 1,2,4-triazole acetic acid in soil and the low toxicity 

of both compounds to aquatic taxa, 1,2,4-triazole and 1,2,4-triazole acetic acid will not be 

considered a stressor of concern for the purposes of risk assessment. 

ii. Drinking Water 

The drinking water assessments conducted to support future human health risk assessments of 

triticonazole will incorporate model estimates of triticonazole residues of concern, which are the 

parent compound, its cis-isomer, and its hydroxylated degradates in surface and ground waters

(MARC Memo D274564 and D274567). Triticonazole may also be considered in an updated
19

aggregate drinking water assessment for triazole-derivative fungicides. The triticonazole residues 

of concern may be reevaluated if additional environmental fate and toxicity data for triticonazole

and its transformation products were submitted. 

b. Measures of Exposure 

EFED will use models to evaluate potential exposures to aquatic and terrestrial organisms as 

described at http://www.epa.gov/pesticides/science/models_db.htm. 

Exposure to terrestrial animals is estimated using the Terrestrial Residue Exposure (T-REX) 

model. Exposure to terrestrial plants is estimated using the TerrPlant model. For terrestrial 

plants, exposure is based on the calculated maximum application rate with assumed exposure 

from runoff, but not spray drift. These models are described at 

http://www.epa.gov/pesticides/science/models_db.htm. 

For terrestrial animals exposed to treated seed, the maximum application rate will be used to 

estimate the LD50-per-square-foot risk index. In addition, risk quotients will be calculated based 

on dietary exposure for animals that feed directly on treated seeds. This exposure is calculated by 

multiplying the amount of a.i. expected to be on a treated seed by the number of seeds an animal 

would need to consume in one day to meet its daily average food intake. Finally, risk is further 

characterized by calculating the number of treated seeds animals need to consume to reach a 

dose equal to the acute LD50 and chronic NOAEL. 

Monitoring Data

EPA is aware of monitoring conducted by federal (e.g., USGS NAWQA) and states (e.g., CDPR 

monitoring database) agencies. Available monitoring data will be evaluated and considered in an 

assessment conducted for Registration Review.

c. Measures of Effect 

Toxicity data presented in Section 3 of this problem formulation will be used to calculate risk 

quotients. Any additional information submitted by the registrant or found in the open literature 

prior to conduct of the risk assessment will also be considered. The open literature studies are 

identified using EPA’s ECOTOXicology database (ECOTOX) (USEPA, 2007), which employs a 

literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, and 

wildlife. The evaluation of both sources of data can also provide insight into the direct and 

indirect effects of pesticides on biotic communities from loss of species that are sensitive to the 

chemicals and from changes in structure and functional characteristics of the affected 

communities.

d. Estimation of Risk
20

The exposure and toxicity data are integrated in order to evaluate the potential risks of adverse 

ecological effects on non-target species. The risk quotient (RQ) method is used to compare 

exposure and toxicity values. EECs are divided by acute and chronic toxicity values. The 

resulting RQs are then compared to the Agency’s levels of concern (LOCs). Risk presumptions, 

along with the corresponding RQs and LOCs for terrestrial animals are summarized in Table 8. 

Table 8. Risk Presumptions and Levels of Concern

Risk Presumption RQ LOC

Birds1

Acute Risk EEC/LC50 or LD50/sqft or LD50/day 0.5

Acute Restricted Use EEC/LC50 or LD50/sqft or LD50/day 0.2

Acute Endangered Species EEC/LC50 or LD50/sqft or LD50/day 0.1

Chronic Risk EEC/NOEC 1

Mammals1

Acute Risk EEC/LC50 or LD50/sqft or LD50/day 0.5

Acute Restricted Use EEC/LC50 or LD50/sqft or LD50/day 0.2

Acute Endangered Species EEC/LC50 or LD50/sqft or LD50/day 0.1

Chronic Risk EEC/NOEC 1

1

 LD50/sqft = (mg/sq ft) / (LD50 * wt. of animal) 

 LD50/day = (mg of toxicant consumed/day) / (LD50 * wt. of animal)

e. Endangered Species Assessments

Consistent with EPA’s responsibility under the Endangered Species Act (ESA), the Agency will 

evaluate risks to federally listed threatened and endangered (listed) species from registered uses 

of pesticides in accordance with the Joint Interim Approaches developed to implement the 

recommendations of the April 2013 National Academy of Sciences (NAS) report, Assessing 

Risks to Endangered and Threatened Species from Pesticides. The NAS report outlines 

recommendations on specific scientific and technical issues related to the development of 

pesticide risk assessments that EPA and the Services must conduct in connection with their 

obligations under the ESA and FIFRA. EPA will address concerns specific to triticonazole in 

connection with the development of its final registration review decision for triticonazole. 

In November 2013, EPA, the U.S. Fish and Wildlife Service, National Marine Fisheries (the 

Services), and USDA released a white paper containing a summary of their joint Interim 

Approaches for assessing risks to listed species from pesticides. These Interim Approaches were 

developed jointly by the agencies in response to the NAS recommendations, and reflect a 

common approach to risk assessment shared by the agencies as a way of addressing scientific 

differences between the EPA and the Services. Details of the joint Interim Approaches are 

contained in the November 1, 2013 white paper, Interim Approaches for National-Level 

Pesticide Endangered Species Act Assessments Based on the Recommendations of the National 

Academy of Sciences April 2013 Report.
21

Given that the agencies are continuing to develop and work toward implementation of the 

Interim Approaches to assess the potential risks of pesticides to listed species and their 

designated critical habitat, this ecological problem formulation supporting the Preliminary Work 

Plan for triticonazole does not describe the specific ESA analysis, including effects 

determinations for specific listed species or designated critical habitat, to be conducted during 

registration review. While the agencies continue to develop a common method for ESA analysis, 

the planned risk assessment for the registration review of triticonazole will describe the level of 

ESA analysis completed for this particular registration review case. This assessment will allow 

EPA to focus its future evaluations on the types of species where the potential for effects exists, 

once the scientific methods being developed by the agencies have been fully vetted. Once the 

agencies have fully developed and implemented the scientific methods necessary to complete 

risk assessments for listed species and their designated critical habitats, these methods will be 

applied to subsequent analyses of triticonazole as part of completing this registration review.

f. Endocrine Disruptor Screening Program

Triticonazole was not included in the first group of 67 chemicals issued an order to conduct Tier 

1 EDSP testing. For additional information the EDSP program, visit http://www.epa.gov/endo/. 

8. Preliminary Identification of Data Gaps

a. Environmental Fate

Table 9 identifies triticonazole environmental fate studies by MRID that offer data for each

guideline requirement, as well as study classifications. Environmental fate data for 

transformation products have not been submitted. Due to the structural similarity of triticonazole 

transformation products to the parent, additional fate data for the degradates are not expected to 

substantially refine risk assessment estimates or change risk assessment conclusions. With the 

exception of the following studies, no further fate data are needed in order to support risk 

assessment:

• Guideline 850.6100, Analytical Method in Water: the Environmental Chemistry Method 

(ECM) and Independent Laboratory Validation (ILV) studies for triticonazole and its 

transformation products

• Guideline 850.6100, Analytical Method in Soil: the ILV study for triticonazole and its 

transformation products

Table 9. Submitted Environmental Fate Data for Triticonazole

OCSPP 

Guideline Data Requirement Submitted Studies (MRID)

Study 

Classifications

Are data needed to conduct risk 

assessment?

835.2120 Hydrolysis 44922305 Acceptable No

835.2240 Aqueous photolysis 44922306 Supplemental No 47296302 Acceptable

835.2410 Soil photolysis 44802123 Acceptable No
22

OCSPP 

Guideline Data Requirement Submitted Studies (MRID)

Study 

Classifications

Are data needed to conduct risk 

assessment?

835.4100 Aerobic soil 

metabolism

44802124 and 

45749206 Acceptable

No

44802126 Supplemental

44802125 Acceptable

45749204 Supplemental

45749205 Acceptable

49017701 In Review

835.4200 Anaerobic soil 

metabolism 44922308 Supplemental No

835.4300 Aerobic aquatic 

metabolism 47296301 Acceptable No

835.4400 Anaerobic aquatic 

metabolism 44922309 Acceptable No

835.1230

835.1240

Adsorption/ desorption 

and leaching 44802129 Acceptable No

835.1410 Volatility – laboratory n/a n/a No

835.6100 Terrestrial field 

dissipation

44802132 Acceptable

No

44904514 Acceptable

44802133, 44904513, 

44922310 in 

conjunction with 

aerobic soil 

metabolism studies

Acceptable

835.6200 Aquatic field 

dissipation n/a n/a

No Analytical method in 

water n/a n/a

850.6100 Analytical method in 

soil and turf 44802130-ECM Soil 

and Turf

44802131-Turf ILV

Acceptable

Yes

Independent laboratory validation

(ILV) study for soil are needed for 

triticonazole and its transformation 

products

Analytical method in 

water

none none

Yes

Environmental chemistry method 

(ECM) and independent laboratory 

validation (ILV) studies are needed

for triticonazole and its 

transformation products

165-4 

(850.1730)

Fish bioconcentration 44922311 Acceptable No

n/a = not applicable

b. Ecological Effects

Table 10 and Table 11 identify ecological effects studies by MRID that offer data for each guideline 

requirement, as well as study classifications and whether further data are needed in order to 
23

support risk assessment. The ecological toxicity data for triticonazole are complete with the 

exception of an avian reproduction study, an acute mysid study, and tier-1 honey bee studies. 

A new avian reproduction study is needed with the northern bobwhite because neither of the two 

studies that were submitted with this species are adequate for risk assessment. Both the first 

bobwhite reproduction study submitted (MRID 44802017) and the repeated study which was 

later submitted (MRID 47296304), were classified as Supplemental because significant adverse 

effects were observed at all test concentrations in both studies. Therefore, neither of these studies

determine the NOAEC for the bobwhite. An acceptable avian reproduction study is available 

with the mallard, but results indicate that the mallard is less sensitive than is the bobwhite. 

Therefore, chronic risk quotients for birds based on the most sensitive species cannot be 

calculated without a new bobwhite study to provide a definitive NOAEC.

Additional acute toxicity data with the mysid, a saltwater crustacean, would reduce uncertainty 

in risk assessment for aquatic invertebrates that stem from uncertainty with the supplemental 

acute mysid study (MRID 448020-23). Based on the supplemental data, is the mysid is the most 

sensitive aquatic test animal tested and therefore results for this test species will drive the risk 

conclusions for aquatic invertebrates. Based on the data for the mysid, a previous assessment for 

use of granular triticonazole on turf (D429730) determined an acute RQ for saltwater crustaceans 

of 0.03. While this RQ was below the LOC for listed species (0.05), there is a small margin of 

safety between the RQ and the LOC. An increase in the mysid LC50 value of 67% or more would 

result in an RQ that exceeds the listed species LOC. Because the data from the mysid acute study 

showed an extreme lack of a dose response, it is plausible that the LC50 could change by greater 

this amount, which could change the conclusion for listed species.

Several of the other aquatic toxicity studies with triticonazole also are classified as supplemental 

due to the possibility of undissolved test material in the exposure chambers, and the lack of 

centrifuging or filtration of the water samples prior to measurement of the concentrations. This 

could have caused the test concentrations to be somewhat overestimated, and the toxicity 

endpoint to be somewhat underestimated. However, supplemental information provided by the 

registrant provided evidence that undissolved material was not likely present in quantities 

sufficient to significantly alter the toxicity endpoint estimations (see Memorandum D314207). 

Furthermore, for aquatic test animals other than mysid, the margin of safety between the RQ and 

the LOC is large enough that a small change in the toxicity endpoint would not likely change the 

conclusion of low risk for listed as well as unlisted species. Therefore, additional data are needed 

only for the mysid to complete the ecological risk assessment for triticonazole. A new acute 

toxicity study with the mysid is needed because it is the most sensitive aquatic species, and the 

uncertainty in this endpoint would create uncertainty in the aquatic risk conclusions.

The registrant submitted an acute toxicity study that measured toxicity of a RPA 406203, the cisisomer (Z-isomer) of the parent molecule, to the waterflea (MRID 44802022). This study is 

classified as supplemental because the concentration of solvent in the control was less than in the 

highest test concentration, undissolved particles were observed in the two highest test 

concentrations, and the protocol did not indicate that water samples were centrifuged or filtered 

to remove undissolved particles prior to analyses. Nevertheless, this study supports the 

assumption that the toxicity of triticonazole and its cis-isomer are approximately equivalent, and 
24

support the consideration of triticonazole parent, its cis-isomer, and its structurally similar 

degradation products when assessing exposure and risk to non-target organisms, as supported by 

ECOSAR results. Additional data on the toxicity of degradation products of triticonazole are not

needed for risk assessment. 

The Agency has recently issued interim guidance for assessing the potential risks of pesticides to 

bees and the data needed to support such assessments (USEPA et al., 2014). The guidance 

document indicates that if exposure of bees to a pesticide is expected, a Tier I risk assessment is 

conducted. Currently the only honey bee data available is the acute contact toxicity study

(Guideline 850.3020). Additional tier-1 honey bee studies which are needed are the acute oral 

toxicity test with adult bees (OECD Guideline 213), the acute larval toxicity test, and the chronic 

larval toxicity test. Depending on the results of these studies, additional higher-tiered honey bee 

testing may be needed.

In summary, the studies needed in order to conduct the ecological risk assessment for 

triticonazole include the following:

• Guideline 850.2300, Avian Reproduction Test with the northern bobwhite (TGAI)

• Guideline 850.1035, Mysid Acute Toxicity Test (TGA)

• A honey bee acute oral study with adult bees (OECD 213) (TGAI)

• A honey bee acute oral toxicity study with bee larvae (OECD 237) (TGAI)

• A honey bee chronic oral toxicity study with adult bees (TGAI)

• A honey bee chronic oral toxicity study with bee larvae (TGAI)

In addition, the following higher-tier honey bee studies may be required, depending on the 

results that are obtained in the tier studies:

• Residues in Pollen and Nectar/Field Residue Analysis (non-guideline study, tier II) (TEP)

• Semi-field testing (tunnel or colony feeding study, Tier II) (TEP)

• Field testing for pollinators (OCSPP guideline 850.3040, tier III) (TEP)
25

Table 10. Submitted Aquatic Ecological Effects Data for Triticonazole

OCSPP

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Test Species Study 

Classifications

Are data 

needed to 

conduct risk 

assessment?

Justification and 

Comments

850.1010 Freshwater 

invertebrate 

acute toxicity

44802021 Water flea Supplemental No Despite uncertainties in the 

data related to possible 

undissolved test material 

(see text), the study is 

adequate to show that 

triticonazole lacks acute 

toxicity at environmentally 

relevant concentrations.

850.1035

850.1045

Saltwater 

crustacean

acute toxicity 

44922304 Mysid Supplemental Yes A new acute mysid study 

would reduce uncertainty in 

the aquatic risk assessment. 

Deficiencies make the 

results of the current study 

uncertain, and because the 

mysid was the most 

sensitive aquatic species 

tested, it makes the RQ for 

saltwater invertebrates 

uncertain. Water samples of 

test concentrations were not 

centrifuged prior to 

analysis, and therefore may 

not accurately reflect 

dissolved concentration. 

Also the mortality results 

showed a poor doseresponse, making the EC50

calculations uncertain.

Based on previous 

assessment, it appears 

possible that refinement of 

the mysid toxicity could 

potentially result in a 

change in the risk 

conclusions for listed 

species (i.e., the RQ could 

exceed 0.05).

850.1025

850.1055

Saltwater 

bivalve

acute toxicity

44802024 Eastern 

oyster

Supplemental No Despite uncertainties in the 

data related to possible 

undissolved test material 

(see text), the study is 

adequate to show that 

triticonazole lacks acute 

toxicity at environmentally 

relevant concentrations.

850.1075 Freshwater fish 

acute toxicity 

44802019 Bluegill 

sunfish

Supplemental No
26

OCSPP

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Test Species Study 

Classifications

Are data 

needed to 

conduct risk 

assessment?

Justification and 

Comments

44802020 Rainbow 

trout

Supplemental Despite uncertainties in the 

data related to possible 

undissolved test material 

(see text), the study is 

adequate to show that 

triticonazole lacks acute 

toxicity at environmentally 

relevant concentrations.

850.1075 Saltwater fish 

acute toxicity 

44802023 Sheepshead 

minnow

Supplemental No The study was classified as 

“Supplemental” because of 

uncertainty of the NOAEC 

determination. However, since 

the conclusion concerning the 

LC50 was considered valid, the 

data are adequate for risk 

assessment.

850.1300 Freshwater 

invertebrate 

life cycle 

44842801 Water flea Acceptable No --

46876701 Water flea Supplemental

44802025 Water flea Invalid

850.1350 Saltwater 

invertebrates 

life cycle 

46876703 Mysid Acceptable No

850.1400 Freshwater fish 

early-life stage

44802027 Fathead 

minnow

Acceptable No --

44802026 Fathead 

minnow

Supplemental

850.1400 Saltwater fish 

early-life stage

46876702 Sheepshead 

minnow

Acceptable No --

850.1500 Fish life cycle 48819801 Fathead 

minnow

Acceptable No --

47622101 Fathead 

minnow

Supplemental

850.4400 Aquatic plant 

Toxicity Test 

using Lemna 

spp.

44802119 Duckweed Acceptable No --

850.4500 Algal toxicity 44802118 Green algae Acceptable No --

44802117 Freshwater 

diatom

Acceptable

44802121 Marine 

diatom

Acceptable No --

850.4550 Cyanobacteria 44802120 Blue-green 

algae

Acceptable No --
27

Because of testing was conducted near the solubility limit and because analytical samples were not centrifuged or filtered prior to 

analysis, this study may have slightly underestimated toxicity. However, the study is expected to be adequate to demonstrate lack 

of toxicity at environmentally relevant concentrations.

Table 11. Submitted Terrestrial Ecological Effects Data for Triticonazole

OCSPP 

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Test 

Species

Study 

Classifications

Are data 

needed for 

risk 

assessment?

Current Additional

Data Need

850.2100 Avian oral 

toxicity

44922301 Bobwhite Acceptable No Although no acute 

toxicity data are 

available for passerine 

birds, the acute oral and 

subacute dietary data 

available for birds are 

adequate to show that 

triticonazole has general 

low acute toxicity to 

birds, and would pose 

low risk to all types of 

birds.

44922302 Mallard Acceptable

(none) Passerine --

850.2200 Avian dietary 

toxicity 

44922303 Bobwhite Acceptable No --

44802016 Mallard Acceptable

850.2300 Avian 

reproduction

47296304 Bobwhite Supplemental Yes

44802017 Bobwhite Supplemental

44802018 Mallard Acceptable

NonguidelineAvian inhalation -- -- (N/A) No Because of the lack of 

acute toxicity to birds, 

an avian acute 

inhalation study is not 

requested.

850.3020 Honey bee acute 

contact toxicity

44802122 Honey 

bee

Acceptable No --

NonguidelineHoney bee larvae 

acute oral 

toxicity

Yes Because triticonazole is 

used on flowering 

ornamental plants, and 

because use on forestry 

trees and turf would 

likely result in 

inadvertent exposure to 

flowering plants, these 

tier-1 toxicity tests are 

required to ensure 

protection of insect 

pollinators.

NonguidelineHoney bee adult 

acute oral 

toxicity

Yes

NonguidelineHoney bee 

chronic larvae 

toxicity

Yes

NonguidelineHoney bee 

chronic adult 

toxicity

Yes

850.3030 Honey bee 

residue on foliage

(N/A) No Because of the low 

acute contact toxicity to 

the adult bee, this study 

is not required.
28

OCSPP 

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Test 

Species

Study 

Classifications

Are data 

needed for 

risk 

assessment?

Current Additional

Data Need

NonguidelineSemi-field testing 

for pollinators 

(tunnel or colony 

feeding studies)

-- -- (N/A) Yes Currently registered 

triticonazole uses are 

expected to result in 

exposure to insect 

pollinators. The need 

for this study is 

contingent on the 

results of earlier tier 

studies.

NonguidelineResidues in 

Pollen and 

Nectar/Field 

Residue Analysis

-- -- (N/A) Yes

850.3040 Field testing for 

pollinators

-- -- (N/A) Yes

850.4100 Seedling 

Emergence and 

Seedling Growth

44802116 10 species Acceptable No --

850.4150 Vegetative Vigor 44802116 10 species Acceptable No --

References

FAO. 2000. Appendix 2. Parameters of pesticides that influence processes in the soil. In FAO 

Information Division Editorial Group (Ed.), Pesticide Disposal Series 8. Assessing Soil 

Contamination. A Reference Manual. Rome: Food & Agriculture Organization of the United 

Nations (FAO).

FRAC, 2013. Fungicide Resistance Action Committee. http://www.frac.info/

Mueller, D. 2006. Fungicide: Triazoles. Iowa State University, University Extension Service. 

IC-496(13). May 30, 2006. http://www.ipm.iastate.edu/ipm/icm/2006/5-30/fungicides.html

US EPA. EFED Risk Assessment for the Proposed New Use of Triticonazole on Ornamental 

plants (Reg. No. 7969-257). July 25, 2013. EFED Memorandum for DP 402686.

US EPA. Triticonazole: Tier I and II Drinking Water Exposure Assessment for Existing Turf 

Uses and the Proposed Expansion of Ornamental Use on the Trinity® Fungicide Label (Reg. No. 

7969-257). April 3, 2013. EFED Memorandum for DP 402685.
29

Appendix A

Triticonazole and its Transformation Products

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

PARENT

Triticonazole

(E isomer; 

RPA-400727)

(1RS)-(E)-5-[(4-chlorophenyl)methylene]-2,2-

dimethyl-1-(1H,1,2,4-triazol-1-ylmethyl)-

cyclopentan-1-ol

CAS No.: 131983-72-7

Formula: C17H20ClN3O

MW: 317.813 g/mol

Smiles:

CC1(C)CC\C(=C/C2=CC=C(Cl)C=C2)C1(O)C

N1C=NC=N1

TRANSFORMATION PRODUCTS
30

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

RPA 406203 

(Z isomer)

(Z)-2-(4-chlorobenzylidene)-5,5-dimethyl-l-

(l,2,4-triazol1--ylmethy1)-cyclopentan- l-ol

Aq 

photolysis

44922306 45% (6 d)A 45% (6 d) A

47296302

40% (2 d)A

triazole ring

41% (1d)A

phenyl ring

26% (17 d)A

triazole ring

28% (17 d) A

phenyl ring

Soil 

photolysis 44802123 11% (30 d) 11% (30 d)

Aerobic soil 44802126 2% (129 d) ND (365 d)

Aerobic soil 45749205

< 4.1% (NS) at 

25°C

< 4.4% (NS) at 

10°C

NS
31

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Terr. Field 

Diss.

44802133, 

44904513, 

44922310

California

bareground: 

3% (14 d)

fallow soil:

3% (0.5 mo)

turf soil:

21% (0 d)

North Carolina

bareground: 

9% (30 d)

fallow soil:

7% (1 mo)

turf soil:

46% (1 mo)

Washington

bareground: 

6% (7 d)

fallow soil:

5% (0.25 mo)

turf soil:

3% (0 d)

California

bareground:

1% (18 mo)

fallow soil:

2% (4 mo)

turf soil:

ND (4 mo)

North 

Carolina

bareground:

ND (18 mo)

fallow soil:

3% (4 mo)

turf soil:

7% (4 mo)

Washington

bareground:

ND (18 mo)

fallow soil:

2% (4 mo)

turf soil:

ND (4 mo)

RPA 406341

(major)

(E)-(lR*,3R *)-2-(4-chlorobenzylidene)-5,5-

dimethyl-1-((lH)-1,2,4-triazol-1-ylmethyl)-

cyclopentan-1,3-diol 

Soil 

photolysis 44802123 4% (30 d) 4% (30 d)

Aerobic soil

44802124 

and 

45749206

Clay loam: 

10% (112 d)

Sandy loam: 

11% (56 d)

Speyer 2.2 

artificial loamy 

sand: 15% (357 

d)

Clay loam: 

8% (363 d)

Sandy loam: 

6% (363 d)

Speyer 2.2 

artificial 

loamy sand:

15% (357 d)

Aerobic soil 44802126 12% (240 d) 11% (365 d)
32

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Aerobic soil 44802125

Loamy sand: 

15% (56 d) at 

22°C

Loamy sand: 

9% (363 d) at 

10°C

Sandy loam: 

11% (306 d) at 

10°C

Clay loam: 

16% (308 d) at 

10°C

Speyer 2.2 

artificial loamy 

sand: 10% (140 

d) at 10°C

Loamy sand: 

7% (363 d) at 

22°C

Loamy sand: 

9% (363 d) at 

10°C

Sandy loam: 

10% (363 d) 

at 10°C

Clay loam: 

13% (363 d) 

at 10°C

Speyer 2.2 

artificial 

loamy sand: 

9% (363 d) at 

10°C

Aerobic soil 45749205

Sandy loam: 

17% (189 d) at 

25°C

Sandy loam: 

15% (365 d) at 

10°C

Sandy loam: 

15% (365 d) 

at 25°C

Sandy loam: 

15% (365 d) 

at 10°C

Anaerobic 

soil 44922308 2% (100 d) 2% (100 d)
33

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Terr. Field 

Diss.

44802133, 

44904513, 

44922310

California

bareground: 

2% (296 d)

fallow soil:

1% (1 mo)

turf soil:

17% (2 mo)

North Carolina

bareground: 

5% (182 d)

fallow soil:

4% (4 mo)

turf soil:

58% (1 mo)

Washington

bareground: 

4% (14 d)

fallow soil:

3% (0.5 mo)

turf soil:

13% (0 d)

California

bareground:

2% (18 mo)

fallow soil:

1% (4 mo)

turf soil:

12% (4 mo)

North 

Carolina

bareground:

2% (18 mo)

fallow soil: 

4% (4 mo)

turf soil:

43% (4 mo)

Washington

bareground:

ND (18 mo)

fallow soil:

2% (4 mo)

turf soil:

10% (4 mo)

RPA 406780 

(major)

(E)-5-(4-chlorobenzylidene)-2,2-dimethyl-1-

((1H)-1,2,4-triazol-1-ylmethyl)cyclopentan-1,3-

diol

Aerobic soil

44802124 

and 

45749206

Clay loam: 

8% (28 d)

Sandy loam: 

8% (168 d)

Speyer 2.2 

artificial loamy 

sand:

10% (84 d)

Clay loam: 

3% (363 d)

Sandy loam: 

7% (363 d)

Speyer 2.2 

artificial 

loamy sand:

9% (357 d)
34

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Aerobic soil 44802125

Loamy sand: 

8% (28 d) at 

22°C

Loamy sand: 

8% (56 d) at 

10°C

Sandy loam: 

7% (245 d) at 

10°C

Clay loam: 

14% (28 d) at 

10°C

Speyer 2.2 

artificial loamy 

sand: 

9% (245 d) at 

10°C

Loamy sand: 

3% (363 d) at 

22°C

Loamy sand: 

6% (363 d) at 

10°C

Sandy loam: 

7% (363 d) at 

10°C

Clay loam: 

8% (363 d) at 

10°C

Speyer 2.2 

artificial 

loamy sand: 

8% (363 d) at 

10°C

RPA 407922 

(major)

(E)-(lRS)-5-(4-chloro-3-hydroxybenzylidene)-

2,2-dimethyl-1-((lH)-1,2,4-triazoll-ylmethyljcyclopentan-l-ol

Aerobic soil

44802124 

and 

45749206

Clay loam: 

15% (266 d)

Sandy loam: 

6% (363 d)

Speyer 2.2 

artificial loamy 

sand:

2% (357 d)

Clay loam: 

12% (363 d)

Sandy loam: 

6% (363 d)

Speyer 2.2 

artificial 

loamy sand:

2% (357 d)

RPA 404766 

(major)

[(Z)-2-(4-chlorobenzy1idene)-5,5-dimethy- 1 -

(1,2,4-triazol- 1 -ylmethyl)-1,3 -cyclopentandiol Soil 

photolysis 44802123 4% (30 d) 4% (30 d)
35

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Aerobic soil 44802126 10% (365 d) 10% (365 d)

Aerobic soil 45749205

Sandy loam: 

9% (100 d) at 

25°C

Sandy loam: 

6% (365 d) at 

10°C

Sandy loam: 

4% (365 d) at 

25°C

Sandy loam: 

6% (365 d) at 

10°C

Anaerobic 

soil 44922308 2% (29 d) 2% (100 d)

Reg. No. 

5059144

(minor)

Aerobic soil (49017701)

CA Sand: 

8% (3664 d)

NJ Loam 

(triazole): 

6% (120 d)

NJ Loam 

(phenyl): 

6% (63 d)

WI Sand:

6% (274 d)

CA Sand: 

8% (366 d)

NJ Loam 

(triazole): 

4% (366 d)

NJ Loam 

(phenyl): 

4% (366 d)

WI Sand:

5% (366 d)
36

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Reg. No. 

5079285

(minor)

Aerobic soil (49017701)

CA Sand: 

9% (274 d)

NJ Loam 

(triazole): 

7% (63,91 d)

NJ Loam 

(phenyl): 

8% (63 d)

WI Sand:

8% (120 d)

CA Sand: 

8% (366 d)

NJ Loam 

(triazole): 

4% (366 d)

NJ Loam 

(phenyl): 

5% (366 d)

WI Sand:

6% (366 d)

RPA 404886 

(minor)

(E)-(lS*,2R*)-5-(4-chlorobenzylidene)-2-

hydroxymethyl-2-methyl-1-((1H)-1,2,4-triazol1-ylmethyl)-cyclopentan-1-01

Aerobic soil

44802124 

and 

45749206

Clay loam: 2% 

(224 d)

Sandy loam: 

4% (168 d)

Speyer 2.2 

artificial loamy 

sand: 2% (140 

d)

Clay loam: < 

1% (363 d)

Sandy loam: 

ND (363 d)

Speyer 2.2 

artificial 

loamy sand: < 

1.2% (357 d)
37

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

Aerobic soil 44802125

Loamy sand: 

2% (112 d) at 

22°C

Loamy sand: 

1% (112 d) at 

10°C

Sandy loam: 

2% (168 d) at 

10°C

Clay loam: 2% 

(112 d) at 10°C

Speyer 2.2 

artificial loamy 

sand: 1% (84 

d) at 10°C

Loamy sand: 

1% (363 d) at 

22°C

Loamy sand: 

1% (363 d) at 

10°C

Sandy loam: 

ND (363 d) at 

10°C

Clay loam: 

ND (363 d) at 

10°C

Speyer 2.2 

artificial 

loamy sand: 

ND (363 d) at 

10°C

RPA 405826 

(minor)

(E)-2-(4-chlorobenzylidene)-5-hydroxymethyl5-methyl-l-(1H-1,2,4-triazol-l-ylmethyl)-

cyclopentan-1-01

Anaerobic 

soil 44922308 < 1% (8 d) ND (100 d)
38

Code Name/ 

Synonym Chemical Name Chemical Structure Study Type Ref.

(MRID)D

Maximum 

%AR (day)

Final %AR 

(study 

length)

1,2,4-Triazole

(minor)

1,2,4-triazole

Aerobic soil (49017701)

CA Sand: 

3% (366 d)

NJ Loam: 

3% (274 d)

WI Sand:

2% (366 d)

CA Sand: 

3% (366 d)

NJ Loam: 

4% (366 d)

WI Sand:

2% (366 d)

1,2,4-Triazole 

Acetic Acid

(minor)

2-(1H-1,2,4-triazol-1-yl)acetic acid

Aerobic soil (49017701)

CA Sand: 

5% (274 d)

NJ Loam: 

4% (184 d)

WI Sand:

1% (91 d)

CA Sand: 

3% (366 d)

NJ Loam: 

4% (184 d)

WI Sand:

1% (366 d)

NS= Not Specified

A Illumination occurred for the entire duration of days reported in the table. B ND means “not detected”.

C Terrestrial field study percentages represent the ratio of degradate concentration to the maximum parent concentration, both in the top layer of soil. D Studies with MRIDs in parentheses are in review. Their data are provisional pending the review.
39

Appendix B

Chemical Properties and Environmental Fate Parameters of 1,2,4-Triazole and Conjugates

Parameter Value* Description Source (MRID) Study Status

1,2,4-Triazole

Persistence

Hydrolysis half-life 303 days

(DFOP) pH 5 acetate buffer at 25°C

00133373 Supplemental 421 days

(DFOP) pH 7 phosphate buffer at 25°C

98.7 days

(SFO) pH 9 borate buffer at 25°C

Aqueous photolysis 

half-life Stable pH 7 distilled water temperature not reported 45284026 Supplemental

Aerobic soil 

metabolism half-life 378 days 

(DFOP)

Les Barges (Swiss) silty loam

1 ppm applied

pH 7.6 at 25°C

45284027 Supplemental

70.1 days

(IORE)

Laacher Hof AXXa (German) sandy loam

~0.06 ppm applied

pH 6.9 (H2O) at 20±2°C

45284032 Supplemental 319 days

(DFOP)

BBA 2.2 (German) loamy sand

~0.06 ppm applied

pH 6.19 (H2O) at 20±2°C

20.3 

(IORE)

Laacher Hof A III (German) silt loam

~0.06 ppm applied

pH 7.88 (H2O) at 20±2°C

Stable

(DFOP half-life 

1,530 days)

Standard Soil 2.2

50 ppm applied

pH 6.0 at 22±2°C

45297203 Supplemental Stable

(DFOP half-life 

1,550 days)

Standard Soil 2.3

50 ppm applied

pH 5.5 at 22±2°C

Anaerobic soil 

metabolism half-life

81.2 days

(SFO)

Les Barges (Swiss) silt loam 

pH 7.31 at 20±2°C 45930701 Acceptable

Mobility

Adsorption – Kf 0.84 1

/n = 0.90

Alpaugh Silty Clay: 0.65% OC, soil pH 8.8, 

CEC 30.5 meq/100g

40891501 Acceptable 0.27 1

/n = 0.63

Hollister Clay Loam: 1.74% OC, soil pH 6.9, 

CEC 16.9 meq/100g

0.23 1

/n = 0.89

Lakeland Sand: 0.12% OC, soil pH 4.8, 

CEC 1.2 meq/100g
40

Parameter Value* Description Source (MRID) Study Status

1,2,4-Triazole

0.73 1

/n = 0.92

Lawrenceville Silty Clay Loam: 0.70% OC, 

soil pH 7, 

CEC 6.6 meq/100g

0.72 1

/n = 1.02

Pachappa Sandy Loam: 0.81% OC, soil pH 

6.9, 

CEC 11.1 meq/100g

0.56 MEAN

Study conducted at 25±1°C

Adsorption – Kfoc 129 Alpaugh Silty Clay: 0.65% OC, soil pH 8.8, 

CEC 30.5 meq/100g

48 Hollister Clay Loam: 1.74% OC, soil pH 6.9, 

CEC 16.9 meq/100g

202 Lakeland Sand: 0.12% OC, soil pH 4.8, 

CEC 1.2 meq/100g

104

Lawrenceville Silty Clay Loam: 0.70% OC, 

soil pH 7, 

CEC 6.6 meq/100g

89

Pachappa Sandy Loam: 0.81% OC, soil pH 

6.9, 

CEC 11.1 meq/100g

114 MEAN

Study conducted at 25±1°C

Field Dissipation

Terrestrial Field 

Dissipation Half-Life 445 days

(IORE)

Newtown, Pennsylvania Silty Loam, 0-3” 

depth 

(leached to 6-12” segment; study sampled 

to 36” depth)

45284025 Supplemental

391 days 

(SFO)

Newtown, Pennsylvania Silty Loam, 0-3” 

depth 

(leached to deepest sampling depth of 6-

12”) 00164564 Supplemental

525 days

(SFO)

Cleveland, Mississippi Loam, 0-3” depth 

(leached to deepest sampling depth of 6-

12”)

1,2,4-Triazole Acetic Acid

Persistence

Aerobic soil 

metabolism half-life

5.01 days**

(IORE)

SP-2.1 (German) sand

pH 5.2 at 20°C

46017601 Pending Review 6.27 days**

(IORE)

SP-2.2 (German) loamy sand

pH 5.6 at 20°C

7.04 days**

(DFOP)

SP-2.3 (German) sandy loam

pH 6.3 at 20°C
41

*All values have been re-estimated by the authors of this document. Representative half-lives are estimated SFO 

half-lives (for EFED modeling inputs) from a degradation curve that does not necessarily follow the SFO equation. 

Representative half-life values were calculated using nonlinear regression and SFO, DFOP, or IORE equations. The 

equations can be found in the document, Standard Operating Procedure for Using the NAFTA Guidance to 

Calculate Representative Half-life Values and Characterizing Pesticide Degradation (US EPA 2012). Representative 

half-life values calculated in this table do not include unextracted residues. 

**This aerobic soil metabolism study did not identify any conjugates or degradates of 1,2,4-Triazole Acetic Acid, 

even though transformation products formed to upwards of 75% applied radioactivity. It is possible that 1,2,4-

Triazole Acetic Acid in combination with its conjugates of concern are persistent in aerobic soil, even though, based 

on the data in this study, 1,2,4-Triazole Acetic Acid is not persistent in aerobic soil.
42

Appendix C

Summary of the Most Sensitive Endpoint Data for 1,2,4-Triazole and Conjugates1

Taxonomic 

Group Study type Surrogate Species Toxicity MRID (classification) Comments

1,2,4-triazole (aquatic toxicity)

Freshwater 

fish

Acute 

Rainbow Trout 

(Oncorhynchus 

mykiss)

96 hr-LC50 = 498 mg ai/L

NOAEC = 378 mg ai/L

(mortality)

48474301

(Acceptable) None

Chronic (28 day 

growth toxicity 

test)

Rainbow trout

(Oncorhynchus 

mykiss)

LC50: > 100 mg/L

NOAEC (growth) ≥ 100 

mg/L

NOAEC (sublethal effects) 

= 3.2 mg/L

LOAEC (sublethal effects) 

= 10.0 mg/L

Observed sublethal 

effects included multiple 

fish being inactive or 

displaying abnormally low 

activity, labored 

respiration, and lying 

inactive on the bottom of 

the aquarium in the three 

highest concentrations 

tested between days 23 

and

28.

45880405 

(Supplemental)

Supplemental 

due to nonguideline 

study

Freshwater 

Invertebrates

Acute Water flea 

(Daphnia magna)

LC50 = 900 (730 to 2200, 

95% C.I.) mg/L. 00133381 Under Review

Acute Water flea 

(Daphnia magna)

48-hr EC50 > 98.1 mg ai/L

NOAEC = 98.1 mg ai/L 

(based on mobility, 

highest concentration 

tested)

48453206

(Acceptable) None

Aquatic 

Plants -

Non vascular Acute 

Freshwater Algae 

(Pseudokirchneriell

a subcapitata, 

formerly 

Selenastrum 

capricornutum)

96-hr endpoints:

Biomass (most sensitive):

EC50 = 14 mg ai/L 

NOAEC = 3.1 mg ai/L

Cell Density: 

EC50 = 18 mg ai/L

NOAEC = 6.8 mg ai/L

Growth Rate:

45880401

(Acceptable) None
43

Taxonomic 

Group Study type Surrogate Species Toxicity MRID (classification) Comments

EC50 > 31 mg ai/L

NOAEC = 6.8 mg ai/L 

Acute

Green algae 

(Scenedesmus 

subspicatus)

EC50 = 6.3 (5.5 to 7.1, 95% 

C.I.) mg/L 00133382 Under Review

1,2,4-triazole (terrestrial toxicity)

Birds 

Acute Coturnix quail

(Coturnix japonica) LD50 >316 mg/kg bw 45284015 Under Review

Acute 

Bobwhite quail 

(Colinus 

virginianus)

LD50 = 770 mg/kg bw

NOAEL = 245 mg/kg bw

LOAEL = 392 based on 

reduced body weight and 

food consumption; other 

observed effects included 

mortality and clinical 

signs of toxicity

49380701

(Acceptable) None

Mammals

Acute Laboratory mouse 

(Mus musculus) LD50 = 3650 mg/kg 45284001 Review not 

available2

Acute Laboratory Rat (M)

(Rattus norvegicus)

LD50 = 1375 mg/kg

LD50 = 1648-3080 mg/kg

45284008

45284004, 

45284001

Reviews not 

available2

Reproduction 

and fertility 

effects

0, 250, 500, 

3000 ppm

M: 15, 31, 189 

mkd

F: 18, 36, 218 

mkd

Laboratory rat 

(Rattus norvegicus)

Parental:

NOAEC/NOAEL <250 

ppm/15 mg/kg/day

LOAEC/LOAEL= 250 

ppm/15 mg/kg/day based 

on decrease in 

bodyweight, bodyweight 

gain and spleen weight.

Offspring:

NOAEC/NOAEL= <250 

ppm/19 mg/kg/day

LOAEC/LOAEL= 250 

ppm/19 mg/kg/day based 

on decrease in 

bodyweight, bodyweight 

gain, brain and spleen 

weights 

Reproduction:

NOAEC/NOAEL= 250 

ppm/15 mg/kg/day

Repro LOAEC/LOAEL= 500 

ppm/31 mg/kg/day based 

46467304

(Acceptable) None
44

Taxonomic 

Group Study type Surrogate Species Toxicity MRID (classification) Comments

on abnormal sperm and 

↓# of corpus luteum (CL) 

in F1 females

At 3000 ppm/218 

mg/kg/day, reproductive 

failure (no viable 

offspring), ↑CL in F0

parental females

Developmental 

Toxicity in 

Rabbits

0,5,15,30,45 

mg/kg/day

New Zealand white 

rabbit

Parental/

Developmental: 

NOAEL= 30 mg/kg/day

LOAEL= 45 mg/kg/day 

based on mortality and 

clinical signs (decreased 

motor activity, head tilt, 

lacrimation, drooping 

eyelids, diarrhea and 

salivation) for parental 

effects and decreased 

fetal weight and urinary 

tract malformations for 

developmental effects

Mortality (6/25 rabbits) in 

45 mg/kg/day group 

46492903

(Acceptable) None

Terrestrial 

Invertebrates

Acute and 

reproductive 

(28 days)

Collembolan 

(springtails) 

Species (Folsomia 

candida) soil 

arthropods

LC50>10 mg/kg

NOAEC (mortality) ≥ 

10mg/kg

NOAEC (reproduction) = 

1.8 mg/kg

45880404

(Supplemental)

Non-guideline 

study

Growth and 

reproductive (8 

weeks, adult 28 

day exposure, 

additional 4 

week offspring 

exposure)

Earthworms 

(Eisenia fetida)

LC50> 70.81 ug/kg

NOAEC ≥ 70.81 ug/kg 

(highest concentration 

tested)

No significant treatment 

effects for mortality, 

behavior, body weights, 

reproduction or food 

consumption

45880402

(Supplemental)

Non-guideline 

study

Triazole alanine (aquatic toxicity)

No submitted data identified

Triazole alanine (terrestrial toxicity)

Mammals

90-day oral 

toxicity in 

rodents – rat

Laboratory rat

(Rattus norvegicus)

NOAEL = 90/160 

mg/kg/day (M/F)

LOAEL = 370/400 

mg/kg/day (M/F) based 

00164107

(Acceptable) None
45

Taxonomic 

Group Study type Surrogate Species Toxicity MRID (classification) Comments

0, 1250, 5000, 

20000 ppm

M: 0, 90, 370, 

1510 

mg/kg/day

F: 0,160, 400, 

1680 

mg/kg/day

on decreased leukocyte 

counts and decreased 

triglycerides in females

At 1510/1680 mg/kg/day 

(M/F) decreased body 

weight (M), body weight 

gain (M), leukocytes 

(M/F) and triglycerides 

(M/F)

Reproduction 

and fertility 

effects

0, 200, 2000, 

10000 ppm

M: (F0/F1) 0, 

50/47, 213/192, 

1098/929 

mg/kg/day

F: 0, 51/49, 

223/199, 

1109/988 

mg/kg/day

Laboratory rat

(Rattus norvegicus)

Parental: NOAEC/NOAEL=

10000 ppm/929 

mg/kg/day

LOAEC/LOAEL: >10000 

ppm/929mg/kg/day

Offspring: NOAEC/NOAEL

<250 ppm/19 mg/kg/day

LOAEC/LOAEL=2000ppm/

192 mg/kg/day based on 

reduced mean litter 

weights in both 

generations

Reproduction:

LOAEC/LOAEL>10000 

ppm/929mg/kg/day

00164112

(Acceptable) None

Triazole acetic acid (aquatic toxicity)

Freshwater 

Fish Acute

Rainbow trout

(Oncorhynchus 

mykiss)

96 hr-LC50 >101 mg ai/L

NOAEC = 101 mg ai/L

(mortality/sub-lethal 

effects)

48453209

(Acceptable) None

Freshwater

Invertebrates Acute Water flea 

(Daphnia magna)

48-hr EC50 > 108 mg ai/L

NOAEC = 108 mg ai/L

(based on mobility, 

highest concentration 

tested)

48453208

(Acceptable) None

Triazole acetic acid (terrestrial toxicity)

Mammals

Acute Laboratory rat

(Rattus norvegicus)

LD50 > 5000 mg/kg 45596802 Review not 

available2

14 day oral 

toxicity in 

rodents

0, 100, 1000, 

8000 ppm

Laboratory rat

(Rattus norvegicus)

NOAEL = 788.3/703.5 

mg/kg/day

(M/F)

LOAEL >788.3/>703.5 

mg/kg/day (M/F)

45596801 None
46

Taxonomic 

Group Study type Surrogate Species Toxicity MRID (classification) Comments

M: 0, 10.6, 

102.8, 788.3 

mg/kg/day

F: 0, 10.1, 97.2, 

703.5 

mg/kg/day

1 Many endpoints derived from summary document USEPA 2006 b. 1,2,4-Triazole, Triazole 

Alanine, Triazole Acetic Acid: Human Health Aggregate Risk Assessment in Support of 

Reregistration and Registration Actions for Triazole-derivative Fungicide Compounds. 2 Values taken from triazole aggregate study referenced above, where it was noted that some 

values were from submitted summary data and full study reports were not available. 
47

Appendix D

SIP Model Output

Table 1. Inputs

Parameter Value

Chemical name Triticonazole

Solubility (in water at 25oC; mg/L) 9.9

Mammalian LD50 (mg/kg-bw) 2000

Mammalian test species laboratory rat

Body weight (g) of "other" mammalian 

species

Mammalian NOAEL (mg/kg-bw) 750

Mammalian test species laboratory rat

Body weight (g) of "other" mammalian 

species

Avian LD50 (mg/kg-bw) 1910

Avian test species northern bobwhite quail

Body weight (g) of "other" avian species

Mineau scaling factor 1.15

Mallard NOAEC (mg/kg-diet) 236

Bobwhite quail NOAEC (mg/kg-diet) 172

NOAEC (mg/kg-diet) for other bird species

Body weight (g) of other avian species

NOAEC (mg/kg-diet) for 2nd other bird 

species

Body weight (g) of 2nd other avian species

Table 2. Mammalian Results

Parameter Acute Chronic

Upper bound exposure (mg/kg-bw) 1.7028 1.7028

Adjusted toxicity value (mg/kg-bw) 1538.3211 576.8704

Ratio of exposure to toxicity 0.0011 0.0030

Conclusion*

Drinking water exposure 

alone is NOT a potential 

concern for mammals

Drinking water exposure 

alone is NOT a potential 

concern for mammals

Table 3. Avian Results

Parameter Acute Chronic

Upper bound exposure (mg/kg-bw) 8.0190 8.0190

Adjusted toxicity value (mg/kg-bw) 1376.0204 11.7086

Ratio of exposure to acute toxicity 0.0058 0.6849
48

Conclusion*

Drinking water exposure 

alone is NOT a potential 

concern for birds

Drinking water exposure 

alone is NOT a potential 

concern for birds

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. 

Therefore, when aggregated with other routes (i.e., diet, inhalation, dermal), pesticide exposure 

through drinking water may contribute to a total exposure that has potential for effects to non-target 

animals.

STIR Model Output

Input

Application and Chemical Information

Enter Chemical Name Triticonazole

Enter Chemical Use Turf

Is the Application a Spray? (enter y or n) y

If Spray What Type (enter ground or air) air

Enter Chemical Molecular Weight (g/mole) 317.82

Enter Chemical Vapor Pressure (mmHg) 0.00000001

Enter Application Rate (lb a.i./acre) 1.1

Toxicity Properties

Bird

Enter Lowest Bird Oral LD50 (mg/kg bw) 1910

Enter Mineau Scaling Factor 1.15

Enter Tested Bird Weight (kg) 0.178

Mammal

Enter Lowest Rat Oral LD50 (mg/kg bw) 2000

Enter Lowest Rat Inhalation LC50 (mg/L) 2.63

Duration of Rat Inhalation Study (hrs) 4

Enter Rat Weight (kg) 0.35

Output

Results Avian (0.020 kg )

Maximum Vapor Concentration in Air at Saturation (mg/m3) 0.000171036

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 2.15002E-05

Adjusted Inhalation LD50 14.0042303

Ratio of Vapor Dose to Adjusted Inhalation LD50 1.53527E-06

Exposure not 

Likely Significant

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 0.105672785

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD50 0.007545776

Exposure not 

Likely Significant
49

Results Mammalian (0.015 kg )

Maximum Vapor Concentration in Air at Saturation (mg/m3) 0.000171036

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 2.7026E-05

Adjusted Inhalation LD50 156.576512

Ratio of Vapor Dose to Adjusted Inhalation LD50 1.72606E-07

Exposure not 

Likely Significant

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 0.132831988

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD50 0.000848352

Exposure not 

Likely Significant
50

Appendix E

Bibliography of Submitted Studies

Ecotoxicity

125620 Triticonazole Eco Effects Bibliography 

71-1 Avian Single Dose Oral Toxicity

MRID Citation Reference

44922301 Hakin, B.; Rodgers, M. (1991) RPA 400727: Acute Oral Toxicity (LD50) to Bobwhite 

Quail: Lab Project Number: RNP 379/911024. Unpublished study prepared by 

Huntingdon Research Centre Ltd. 40 p. 

44922302 Hakin, B.; Rodgers, M. (1991) RPA 400727: Acute Oral Toxicity (LD50) To Mallard Duck: 

Lab Project Number: RNP 378/911023. Unpublished study prepared by Huntingdon 

Research Centre Ltd. 41 p. 

71-2 Avian Dietary Toxicity

MRID Citation Reference

44802016 Hakin, B.; Rodgers, M.; Anderson, A. et al. (1992) RPA 400727: Subacute Dietary 

Toxicity (LC50) to Mallard Duck: Lab Project Number: RNP 384/91681. Unpublished 

study prepared by Huntingdon Research Centre Ltd. 60 p. 

44922303 Hakin, B.; Rodgers, M.; Anderson, A. et al. (1992) RPA 400727: Subacute Dietary 

Toxicity (LC50) to Bobwhite Quail: Lab Project Number: RNP 387/91682. Unpublished 

study prepared by Huntingdon Research Centre Ltd. 61 p. 

850.2300 71-4 Avian Reproduction

MRID Citation Reference

44802017 Taliaferro, L.; Brewer, L. (1995) The Reproductive Toxicity Test of RPA 400727 in 

Northern Bobwhite (Colinus virginianus): Lab Project Number: 029406: 727-TP-95-5500. 

Unpublished study prepared by Ecotoxicology and Biosystems Associates, Inc. 247 p. 

44802018 Taliaferro, L.; Miller, V. (1998) The Reproductive Toxicity Test of RPA 400727 with the 

Mallard Duck (Anas platyrhynchos): Final Report: Lab Project Number: 029718: EBA029718. Unpublished study prepared by EBA, Inc. 325 p. 

47296304 Zok, S. (2007) BAS 595 F -1-Generation Reproduction Study on the Bobwhite Quail 

(Colinus virginianus) by Administration in the Diet. Project Number: 2006/1026908, 
51

71W0622/055033, 01Y0622/058037. Unpublished study prepared by BASF 

Aktiengesellschaft. 319 p.

72-1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

44802019 Machado, M. (1998) RPA 400727--Acute Toxicity to Bluegill Sunfish (Lepomis 

macrochirus) Under Flow-Through Conditions: Lab Project Number: 92-8-4392: 

10566.0492.6239.105. Unpublished study prepared by Springborn Laboratories, Inc. 

62 p. 

44802020 Odin-Feurtet, M. (1998) Triticonazole Acute Toxicity (96 Hours) to Rainbow Trout 

(Oncorhyncus mykiss) Under Flow-Through Conditions: Lab Project Number: SA 

97447: RANDD/CRSA/ANL/97-046. Unpublished study prepared by Rhone-Poulenc 

Agro. 68 p. 

46021001 Chalmers, A. (2003) RPA-400727 - Acute Toxicity to Bluegill Sunfish (Lepomis 

macrochirus) Under Flow through Conditions. Project Number: B004375. Unpublished 

study prepared by Springborn Laboratories Inc. 9 p.

72-2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

44802021 Douglas, M.; Halls, R.; Macdonald, I. (1990) The Acute Toxicity of RPA 400727 to 

Daphnia magna: Lab Project Number: RNP 371/901398. Unpublished study prepared by 

Huntingdon Research Centre Ltd. 24 p. 

44802022 Putt, A. (1998) RPA 406203--Acute Toxicity to Daphnids (Daphnia magna) Under FlowThrough Conditions: Final Report: Lab Project Number: 98-6-7359: 10566.0498.6493.115: 

15530. Unpublished study prepared by Springborn Laboratories, Inc. 71 p. 

46021002 Chalmers, A. (2003) The Acute Toxicity of RPA 400727 to Daphnia magna. Project 

Number: B004377. Unpublished study prepared by Huntingdon Life Sciences, Ltd. 5 p.

72-3 Acute Toxicity to Estuarine/Marine Organisms

MRID Citation Reference

44802023 Sousa, J. (1998) Triticonazole Technical--Acute Toxicity to Sheepshead Minnow 

(Cyprinodon variegatus) Under Flow-Through Conditions: Final Report: Lab Project 

Number: 98-4-7298: 10566.1197.6457.505. Unpublished study prepared by Springborn 

Laboratories, Inc. 70 p. 

44802024 Dione, E. (1998) Triticonazole Technical--Acute Toxicity to Eastern Oyster (Crassostrea 

virginica) Under Flow-Through Conditions: Final Report: Lab Project Number: 98-5-7331: 

10566.1197.6466.504. Unpublished study prepared by Springborn Laboratories, Inc. 70 

p. 
52

44922304 Souza, J. (1998) Triticonazole Technical--Acute Toxicity to Mysids (Mysidopsis bahia) 

Under Flow-Through Conditions: Final Report: Lab Project Number: 98-2-7257: 

10566.1197.6455.515. Unpublished study prepared by Springborn Laboratories, Inc. 85 

p. 

46021003 Chalmers, A. (2003) Triticonazole Technical - Acute Toxicity to Mysids (Mysidopsis 

bahia) Under Flow-Through Conditions. Project Number: B004373. Unpublished study 

prepared by Springborn Laboratories Inc. 8 p.

46021004 Chalmers, A. (2003) Triticonazole Technical - Acute Toxicity to Sheepshead Minnow 

(Cyprinodon variegatus) Under Flow Through Conditions. Project Number: B004372. 

Unpublished study prepared by Springborn Laboratories Inc. 8 p.

46021005 Chalmers, A. (2003) Triticonazole Technical - Acute Toxicity to Eastern Oysters 

(Crassostrea virginica) Under Flow Through Conditions. Project Number: B004371. 

Unpublished study prepared by Springborn Laboratories Inc. 9 p.

850.1400 72-4 Fish early-life stage toxicity - Marine and Fresh

44802026 Sousa, J. (1998) Triticonazole Technical--Early Life-Stage Toxicity Test with Fathead 

Minnow (Pimephales promelas): Final Report: Lab Project Number: 98-5-7338: 

10566.0298.6478.120. Unpublished study prepared by Springborn Laboratories, Inc. 86 

p. 

44802027 Sousa, J. (1998) Triticonazole Technical--Early Life-Stage Toxicity Test with Fathead 

Minnow (Pimephales promelas): Final Report: Lab Project Number: 98-6-7366: 

10566.0598.6500.120. Unpublished study prepared by Springborn Laboratories, Inc. 83 

p. {OPPTS 850.1400} 

46021006 Chalmers, A. (2003) Triticonazole Technical - Early Life Stage Study with Fathead 

Minnow (Pimephales promelas). Project Number: B004374. Unpublished study 

prepared by Springborn Laboratories Inc. 24 p.

46876702 Cafarella, M. (2006) BAS 595 F (triticonazole) - Early Life-Stage Toxicity Test with 

Sheepshead Minnow (Cyprinodon variegatus). Project Number: 986/6168, 138650, 

2006/7007245. Unpublished study prepared by Springborn Smithers Laboratories. 55 p.

850.1300 72-4 Aquatic Invertebrate Life Cycle Study

MRID Citation Reference

46876701 Putt, Arthur E. 2006. BAS 595 F (Triticonazo1e)- Full Life-Cycle Toxicity Test with 

Water Fleas, Daphnia magna, Under Static-Renewal Conditions. Unpublished study 

performed by Springborn Smithers Laboratories, Wareham, MA. Laboratory report 

number 986.6170. Study sponsored by BASF Corporation, Research Triangle Park,

North Carolina. Study completed on June 26, 2006.

46021007 Chalmers, A. (2003) Triticonazole - Daphnia magna Life Cycle (21-Day Static 

Renewal) Chronic Toxicity Test. Project Number: B004376. Unpublished study 

prepared by Rhone-Poulenc - Secteur Agro. 7 p.

850.1350 Mysid chronic toxicity test
53

46876703 Putt, A. (2006) BAS 595 F (Triticonazole) - Life-Cycle Toxicity Test with Mysids 

(Americamysis bahia). Project Number: 986/6167, 138656, 2006/7007246. 

Unpublished study prepared by Springborn Smithers Laboratories. 68 p. Relates to 

L0001064. 

850.1500 72-5 Life cycle fish

MRID Citation Reference

47622101 Zok, S. (2008) BAS 595F (Triticonazol) - Life Cycle Test on the Fathead Minnow 

(Pimephales promelas) in a Flow Through System. Project Number: 

81F0622/055075, 2008/1028361. Unpublished study prepared by BASF SE. 269 p.

122-1 Seed Germination/Seedling Emergence and Vegetative Vigor

MRID Citation Reference

44802116 Teixeira, D. (1998) Triticonazole--Determination of Effects on Seedling Emergence 

and Vegetative Vigor of Ten Plant Species: Final Report: Lab Project Number: 98-4-

7310: 10566.1197. 6464.610. Unpublished study prepared by Springborn 

Laboratories, Inc. 249 p. 

122-2 Aquatic plant growth

MRID Citation Reference

44802117 Hoberg, J. (1998) Triticonazole--Toxicity to the Freshwater Diatom, Navicula 

pelliculosa: Amended Final Report: Lab Project Number: 98-47302: 

10566.1197.6461.440. Unpublished study prepared by Springborn Laboratories, Inc. 

70 p. 

44802118 Hoberg, J. (1998) Triticonazole--Toxicity to the Freshwater Green Alga, Selenastrum 

capricornutum: Final Report: Lab Project Number: 98-3-7273: 10566.1197.6459.430. 

Unpublished study prepared by Springborn Laboratories, Inc. 66 p. 

44802119 Hoberg, J. (1998) Triticonazole--Toxicity to the Duckweed, Lemna gibba: Final 

Report: Lab Project Number: 98-4-7317: 10566.1197.6462.410. Unpublished study 

prepared by Springborn Laboratories, Inc. 76 p. 

44802120 Hoberg, J. (1998) Triticonazole--Toxicity to the Freshwater Blue-Green Alga, 

Anabaena flos-aquae: Final Report: Lab Project Number: 98-3-7286: 

10566.1197.6460.420. Unpublished study prepared by Springborn Laboratories, Inc. 

65 p. 

44802121 Hoberg, J. (1998) Triticonazole--Toxicity to the Marine Diatom, Skeletonema 

costatum: Final Report: Lab Project Number: 98-3-7278: 10566.1197.6458.450. 

Unpublished study prepared by Springborn Laboratories, Inc. 68 p. 
54

141-1 Honey bee acute contact

MRID Citation Reference

44802122 Collins, M. (1998) Triticonazole Technical--Acute Contact Toxicity Test with Honey 

Bees (Apis mellifera): Final Report: Lab Project Number: 97-11-7149: 13634: 

10566.0997.6452.266. Unpublished study prepared by Springborn Laboratories, Inc. 

63 p. 

Non-Guideline Study

MRID Citation Reference

44802134

Pugsley, R.; Theissen, R. (1999) Probablistic Modeling of Triticonazole Exposure to 

Aquatic Nontarget Organisms and Assessment of Potential Exposure in Drinking 

Water Associated with Chipco Triton Use on Turf: Lab Project Number: WEI 746. 10. 

Unpublished study prepared by Waterborne Environmental, Inc. 95 p. 
55

Environmental Fate

125620 Triticonazole Fate Chemistry Bibliography 

161-1 Hydrolysis

MRID Citation Reference

44922305 Corgier, M.; Robin, J. (1991) (Carbon-14)-RPA 400727: Hydrolysis at 25(degrees) 

C: Lab Project Number: 91-20: AG/CRLD/AN/9116312: RND/CRLD/AN/981612. 

Unpublished study prepared by Rhone-Poulenc Secteur Agro. 59 p. 

161-2 Photodegradation-water

MRID Citation Reference

44922306 Corgier, M.; Robin, J. (1992) (Carbon-14)-RPA 400727: Aqueous Photolysis: Lab 

Project Number: 91-50: AG/CRLD/AN/9216236: 429307. Unpublished study 

prepared by Rhone-Poulenc Secteur Agro. 89 p. 

47296302 Singh, M. (2007) Aqueous Photolysis of [Carbon 14]-BAS 595 F (Triticonazole): 

Final Report. Project Number: 2007/7001058, 138659, AR07/046. Unpublished 

study prepared by BASF Corporation. 181 p.

161-3 Photodegradation-soil

MRID Citation Reference

44802123 Jones, M.; Ayliffe, J. (1998) Fungicides: Triticonazole: Soil Photolysis: Lab Project 

Number: P95/065: 201021. Unpublished study prepared by Rhone Poulenc. 117 p. 

162-1 Aerobic soil metabolism

MRID Citation Reference

44802124 Austin, D.; Ayliffe, J. (1998) Fungicides: RPA400727-(carbon-14): Aerobic Soil 

Metabolism in Three Soils: Lab Project Number: P91/326: 200159. Unpublished 

study prepared by Rhone Poulenc. 172 p. Related to L0000817. 

44802125 Godward, P.; Ayliffe, J. (1993) Fungicides: RPA 400727-(carbon-14): Rate of 

Degradation in Four Soils: Lab Project Number: P91/411. Unpublished study 

prepared by Rhone Poulenc. 76 p. 

44802126 Doble, M.; Ferreira, E.; Hardy, I. (1996) (Carbon-14)--Triazole Labelled 

Triticonazole: Rate of Degradation in Clay Soil under Aerobic Conditions: Lab 
56

Project Number: P94/158: 201171. Unpublished study prepared by Rhone-Poulenc. 

88 p. 

44922307 Doble, M.; Parsons, R. (1994) Fungicides: Triticonazole ((carbon-14) Phenyl): Soil 

Persistence Study Using Lysimeter Tubes: Lab Project Number: P91/393: 200248. 

Unpublished study prepared by Rhone-Poulenc Agriculture Limited. 123 p. 

45749201 Huang, M. (2002) 1,2,4-Triazole Analysis in Triticonazole Plant and Soil Studies: Lab 

Project Number: B003968. Unpublished study prepared by Aventis Crop Science 

USA. 25 p. 

45749203 Lowden, P. (2002) (Carbon 14)-Triticonazole: Characterisation/Identification of 

Triticonazole Residues in Extracts of Soil Samples and Soil Samples Treated with 

(Carbon 14)-Triticonazole, from Studies CX/01/010 and CX/01/011: Lab Project 

Number: CX/01/010: CX/01/011: C024884. Unpublished study prepared by Battelle 

AgriFood, Ltd. 90 p. 

45749204

Lowden, P.; Simmonds, M. (2002) (Carbon 14)-Triticonazole: Generation and 

Identification of Soil Metabolites: Lab Project Number: CX/01/011: CX021044: 

28047. Unpublished study prepared by Battelle AgriFood, Ltd. 80 p. 

45749205 Simmonds, M.; Hardy, I.; Ferreira, E. (1996) Triticonazole: Rate of Degradation in 

One Soil Type under Aerobic Conditions with Regard to Varying Temperature, Soil 

Moisture, Treatment Rate and Soil Viability: Lab Project Number: P 94/141: 201173: 

R012995. Unpublished study prepared by Rhone-Poulenc Agriculture Limited. 149 

p. 

45749206 Ayliffe, J.; McMillan-Staff, S. (1994) Aerobic Soil Metabolism in Three Soils: RPA 

400727-(Carbon 14): Addendum Report: Lab Project Number: P91/326: 200471: 

R012981. Unpublished study prepared by Rhone-Poulenc Agriculture Limited. 48 p. 

47296303 Afzal, J. (2007) Aerobic Soil Metabolism of BAS 595 F: Final Report. Project 

Number: 2007/7007035, 138662. Unpublished study prepared by BASF Corporation. 

81 p.

162-2 Anaerobic soil metabolism

MRID Citation Reference

44922308 Goodyear, A. (1994) (Carbon-14)-RPA 400727: Anaerobic Soil Metabolism: Final 

Report: Lab Project Number: 68/136: 68/136-1015: P7662D. Unpublished study 

prepared by Hazleton Europe. 80 p. 

162-3 Anaerobic aquatic metab.

MRID Citation Reference

44922309 McGhee, I.; Mac Connachie, J. (1999) (Carbon-14)-Triticonazole: Anaerobic Aquatic 

Study: Lab Project Number: 12965: 201936. Unpublished study prepared by RhonePoulenc Agriculture Limited. 99 p. 
57

835.4300 or 162-4 Aerobic aquatic metab.

MRID Citation Reference

44802127 Wyss-Benz, M. (1995) (Carbon-14)-RPA 400727: Degradation and Metabolism in 

Aerobic Aquatic System: Lab Project Number: 374850. Unpublished study prepared 

by RCC Umweltchemie AG. 144 p. 

47296301 Malinsky, D. (2007) Aerobic Aquatic Metabolism of [Carbon 14] BAS 595 F: 

Amended Final Report. Project Number: 138665, 2007/7013575, 2007/7009864. 

Unpublished study prepared by BASF Corporation and Agvise, Inc. 78 p.

163-1 Leach/adsorp/desorption

MRID Citation Reference

44802128 John, A.; Lowden, P.; Austin, D. (1998) (Carbon-14)-Triticonazole Fungicides: RPA 

400727-(carbon 14) (Phenyl Label): Fresh and Aged Leaching Study with Five Soils

(Final Report): Lab Project Number: P91/357: 200173. Unpublished study prepared 

by Rhone-Poulenc. 160 p. 

44802129 Burr, C. (1998) (Carbon-14)-Triticonazole Adsorption/Desorption to and from Four 

Soils and a Sediment: Lab Project Number: 12966: 201670. Unpublished study 

prepared by Rhone-Poulenc. 117 p. 

164-1 Terrestrial field dissipation

MRID Citation Reference

44802130 Burns, G.; Gottschalk, R.; Tauber, R. (1998) Validation of the Method of Analysis for 

Triticonazole (RPA 400727) and its Metabolites in Soil and Turf: Lab Project 

Number: EC-97-410: 98RP26.REP. Unpublished study prepared by Rhone-Poulenc. 

262 p. 

44802132

See 

MRID# 

45064401

Norris, F. (1998) Triticonazole: Terrestrial Soil Dissipation After Preplant Application 

or Seed Treatment on Wheat: Lab Project Number: 45608: 97Z13032B. 

Unpublished study prepared by Enviro-Test Laboratories and Agvise, Inc. 775 p. 

44802133 Norris, F.; Burns, G. (1999) Storage Stability Study of Triticonazole and its 

Metabolites in Soil and Turf: Lab Project Number: ETL97RP03.PRO: EC-97-412: 

99RP42.REP. Unpublished study prepared by Enviro-Test Laboratories. 152 p. 

{OPPTS 840.1100} 

44904512 Norris, F. (1999) Triticonazole: Terrestrial Soil Dissipation After Application to a 

North Carolina Turfed Soil: Lab Project Number: 98Z15601A: 45865: 99RP48.REP. 

Unpublished study prepared by Rhone-Poulenc Ag Company, and American 

Agricultural Company. 601 p. 
58

44904513 Norris, F. (1999) Triticonazole: Continuation, After Four Months Post Application, of 

a Terrestrial Soil Dissipation Study Under Agricultural Field Conditions: Lab Project 

Number: 45863: 97Z13033A: 97Z13032A. Unpublished study prepared by RhonePoulenc Ag Company, and American Agricultural Company. 1160 p. 

44904514 Kretschmar, J. (1999) Triticonazole: Continuation, After Four Months 

Postapplication, of a Terrestrial Soil Dissipation Study Following Preplant Application 

or Seed Treatment on Wheat: Lab Project Number: 45864: 97Z13033B: 

99RP45.REP. Unpublished study prepared by Rhone-Poulenc Ag Company, and 

Qualls Agricultural Laboratories. 900 p. 

44922310 Norris, F. (1998) Triticonazole: Terrestrial Soil Dissipation Study After Application to 

Turf and Bare Soil: Lab Project Number: 45596: 97Z13032A: 13032-01. Unpublished 

study prepared by Rhone-Poulenc Ag Company. 1347 p. 

45064401

See 

MRID # 

45064401

Norris, F. (1998) Triticonazole: Terrestrial Soil Dissipation After Preplant Application 

or Seed Treatment on Wheat: Lab Project Number: 45608: 97Z13032B. 

Unpublished study prepared by Aventis Cropscience. 293 p. 

44904511 Wicks, R. (1996) Triticonazole: Terrestrial Field Soil Dissipation Study in Europe 

(Final Report): Lab Project Number: P 92/029: 201284. Unpublished study prepared 

by Rhone-Poulenc Agrochemie ADME Bioanalysis. 455 p. 

165-1 Confined rotational crop

MRID Citation Reference

44995701 Lowden, P.; Maycey, P. (1996) (Carbon-14)-Triticonazole: A Confined Rotational 

Crop Study Using Radish, Lettuce and Wheat: Lab Project Number: P 93/192. 

Unpublished study prepared by Rhone-Poulenc Ag Ltd. 401 p. 

165-4 Bioaccumulation in fish

MRID Citation Reference

44922311 Chapleo, S.; Keirs, D.; Briggs, C. (1996) (Carbon-14)-Triticonazole: Bioaccumulation 

Test in Bluegill Sunfish: Lab Project Number: 386722: 13148. Unpublished study 

prepared by Inveresk Research. 124 p. {OPPTS 850.1730}