2 

and water dispersible granule formulations for use as foliar spray (ground, aerial, and 

chemigation) or soil applications (in-furrow and banded) to various agricultural crops with 

maximum single application rates ranging from 0.046 to 0.089 lb a.i./A and maximum seasonal 

application rates up to 0.272 lbs. a.i./A specified. This risk assessment provides EFED’s 

assessment of the environmental fate, terrestrial and aquatic exposure, and ecological risks 

associated with the proposed uses of benzovindiflupyr including blueberries, canola, cereal crops 

(oats, wheat, rye, and barley), corn, cotton, cucurbits, tomatoes, grapes, legumes, peanuts, pome 

fruit, soybeans, potatoes, turf grass, and nursery crops. When estimates of benzovindiflupyr 

exposure considering all proposed uses in terrestrial and aquatic environments are compared to 

the available ecotoxicity data, the resulting risk quotients (RQs) for this screening-level 

assessment indicate a potential for risk to most, but not all aquatic and terrestrial taxa. 

For aquatic organisms, acute and chronic risk above established levels of concern to freshwater 

fish, estuarine/marine fish, freshwater invertebrates, and estuarine/marine invertebrates was 

identified. Acute risk but not chronic risk was identified for freshwater and estuarine/marine 

sediment dwelling invertebrates despite benzovindiflupyr’s persistence in the environment and 

its high propensity to bind to sediment. Some chronic risks to aquatic invertebrates may be 

resolved with establishing 30-ft. spray buffers. In addition, the restriction of applications 

occurring every few years may potentially resolve some acute risks to both fish and 

invertebrates. Risks above the level of concern were not identified for aquatic plants (both 

vascular and non-vascular). 

For terrestrial organisms, acute dose-based risk to birds was identified in all size classes of birds. 

Avian chronic RQs do not exceed the LOC in any scenario so direct chronic risk is presumed to 

be low though food avoidance demonstrated in the passerine acute dietary study. This may result 

in decreased fitness through other impacts during sensitive times like during migratory or nesting 

seasons. There was also LOC exceedences for piscivorous birds (e.g., sandpipers and rails 

consuming fish contaminated with benzovindiflupyr residues) suggesting risk through this 

pathway. There was also both acute and chronic dose-based risk identified in all size classes of 

mammals. There was not any chronic risk identified for dietary-based exposure in mammals or 

acute risk from the consumption of fish contaminated with benzovindiflupyr residues. 

Data gaps for this chemical include acute and chronic toxicity studies submitted for larval bees 

and chronic feeding studies for adult bees, and additional data on passerine species. 

The available data (acute oral and contact toxicity studies for adult bees) suggest that 

benzovindiflupyr is practically non-toxic to bees and preliminary exposure modeling and RQ 

analysis suggests that risk to adult bees via the contact and oral exposure pathways is below the 

level of concern. Studies to other beneficial insects used in the PMRA assessment suggest 

however that other insects (e.g. the parasitic wasp) have endpoints that are in the range of 

application rates from the proposed uses of benzovindiflupyr. There are not any acute or chronic 

toxicity studies submitted for larval bees or chronic feeding studies for adult bees. Furthermore, 

there is no language on the proposed labels restricting benzovindifluypyr applications when 

plants are in bloom in the vicinity. Therefore, risks to terrestrial invertebrates is presumed in the 
3 

absence of data and given benzonvindiflupyr’s potential bioavailability to beneficial insects 

which may be attracted to treated plants. EFED recommends the submittal of the additional 

honey bee toxicity data discussed above. This will allow EFED to reconsider the presumption 

of risk to bees. There was not any risk identified to terrestrial plants. 

Review of labels indicate that environmental hazard statements, while not pre-empting identified 

risks, sufficiently address the vulnerable dissipation pathways of benzovindiflupyr to nearby 

terrestrial and aquatic habitats via runoff of contaminated erodible soil particles. However, there 

is uncertainty regarding seasonal maximum application rates specified on the label. This risk 

assessment evaluated one treatment/retreatment cycle of benzovindiflupyr occurring per year. 

While this is likely the intended use pattern as suggested by resistance management strategies 

that are recommended on labels, specification of the seasonal maximum application rates as 

yearly maximum application rates would eliminate the possibility of multiple 

treatment/retreatment cycles per year to occur. 
4 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION

Environmental Fate and Ecological Risk Assessment 

for Benzovindiflupyr New Chemical Registration for 

Proposed Uses on blueberries, canola, cereal crops 

(oats, wheat, rye, and barley), corn, cotton, cucurbits, 

tomatoes, grapes, legumes, peanuts, pome fruit, 

soybeans, potatoes, turf grass, and nursery crops. 

Chemical Formula: C18H15Cl2F2N3O 

PC Code: 122305

CAS Number: 1072957-71-1

Prepared by: 

Gabe Rothman, Environmental Scientist 

Geoffrey Sinclair, Ph.D., Biologist 

Reviewed by: 

José L. Meléndez, Chemist 

Justin Housenger, Biologist 

Mah Shamim, Ph.D., Branch Chief, ERB5 

United States Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch V

1200 Pennsylvania Ave.

Mail Code 7507P

Washington, D.C. 20460
5 

Contents	

1. EXECUTIVE SUMMARY ................................................................................................................................... 6

1.1 Purpose of Assessment .......................................................................................................................... 6

1.2 Summary of Relevant Environmental Fate, Transport, and Exposure Pathways ................................... 6

1.3 Summary of Effects and Risk Conclusions ............................................................................................ 7

2. PROBLEM FORMULATION .............................................................................................................................. 8

2.1 Use Characterization .............................................................................................................................. 8

2.2 Environmental Fate and Transport Characterization ........................................................................... 10

2.3 Ecological Toxicity Characterization .................................................................................................. 18

2.3.1 Aquatic Effects .................................................................................................................................... 18

2.3.2 Terrestrial Effects ................................................................................................................................ 27

2.4 Conceptual Model and Risk Hypothesis .............................................................................................. 38

2.5 Analysis Plan ....................................................................................................................................... 39

2.5.1 Measures of Exposure .......................................................................................................................... 40

2.5.2 Measures of Effects ............................................................................................................................. 40

3. RISK ANALYSIS AND CHARACTERIZATION ............................................................................................. 42

3.1 Exposure Estimation ............................................................................................................................ 42

3.1.1 Aquatic Exposure Estimation .............................................................................................................. 42

3.1.2 Terrestrial Exposure Estimation .......................................................................................................... 47

3.2 Risk Estimation – Integration of Exposure and Effects Data ............................................................... 53

3.2.1 Non-target Aquatic Animals and Plants ............................................................................................... 53

3.2.2 Non-target Terrestrial Animals and Plants ........................................................................................... 61

3.3 Risk Description .................................................................................................................................. 70

3.3.1 Aquatic Organisms .............................................................................................................................. 70

3.3.2 Terrestrial Organisms .......................................................................................................................... 71

3.4 Review of Incident Data and Environmental Monitoring Data ........................................................... 73

4. ENDOCRINE DISRUPTOR SCREENING PROGRAM ................................................................................... 74

5. LISTED SPECIES ............................................................................................................................................... 75

6. UNCERTAINTIES, LIMITATIONS, AND IDENTIFICATION OF DATA GAPS .......................................... 77

7. CONCLUSIONS ................................................................................................................................................. 83

8. REFERENCES .................................................................................................................................................... 87
6 

1. EXECUTIVE SUMMARY 

1.1 Purpose of Assessment 

This screening-level risk assessment examines the potential ecological risks associated with 

proposed uses of the new pyrazole and amide fungicide chemical benzovindiflupyr (aka 

solatenol or SYN545192). This risk assessment utilizes the best available scientific information 

and proposed labels to evaluate the environmental fate and transport, and effects on non-target 

organisms. The proposed end use products are emulsifiable concentrate and water dispersible 

granule formulations for use as foliar spray (ground, aerial, and chemigation) or soil applications 

(in-furrow and banded) to various agricultural crops with maximum single application rates 

ranging from 0.046 to 0.089 lb a.i./A and maximum seasonal application rates up to 0.272 lbs. 

a.i./A specified. The specification of yearly applications would provide further clarity 

related to seasonal application rates that are currently specified on the proposed labels. 

The proposed uses of benzovindiflupyr include blueberries, canola, cereal crops (oats, wheat, 

rye, and barley), corn, cotton, cucurbits, tomatoes, grapes, legumes, peanuts, pome fruit, 

soybeans, potatoes, turf grass, and nursery crops. 

1.2 Summary of Relevant Environmental Fate, Transport, and Exposure Pathways 

When benzovindiflupyr is applied to crops and soil, it may be transported from treated fields to 

off-site terrestrial habitats, water bodies, and aquatic habitats via spray drift given its proposed 

spray applications; further, erosion of benzovindiflupyr-ladened soil particles embedded within 

runoff during rain events after application may occur. Benzovindiflupyr residues had foliar 

dissipation half-lives ranging between 0.6 – 20 days from turf, barley, peanut, and soybean crops 

in residues measured in field dissipation studies (MRID Nos. 48604997, 48604998, 48604502, 

48604580, and 48604581). However, laboratory studies suggest that benzovindiflupyr is highly 

persistent in both terrestrial and aquatic environments. Therefore, the longevity for it to be 

available for runoff will be high after its application with high residence times expected in 

impacted water bodies and aquatic habitats. Benzovindiflupyr’s high persistence was 

consistently observed in aerobic soil metabolism and anaerobic soil metabolism studies with 

half-lives which ranged from 635 days – 1,788 days in seven soils1. Benzovindiflupyr’s high 

soil-water partition coefficient (Koc) values ranging between 3,829 – 5,221 mL/g (MRID No. 

48604505) indicate that benzovindiflupyr would enter surface water bodies and aquatic habitats 

under a sorbed state with residues bound to eroded soil particles. Once reaching water bodies, 

benzovindiflupyr’s high persistence also was observed in aquatic environments, as it was not 

observed to degrade at 50°C over a 30 day period in the hydrolysis study (MRID No. 48604506) 

and its slow biodegradation which occurred with half-lives ranging between 427 – 934 days 

(MRID Nos. 48604509 and 48604510) under aerobic and anaerobic aquatic conditions. In both 

 

1

 Aerobic soils evaluated include Switzerland Loam Soil (MRID No. 48604492), United Kingdom Sandy Clay 

Loam Soil (MRID No. 48604493), France Silty Clay Soil (MRID No. 48604493), Switzerland Loam Soil (MRID 

No. 48604493), California Sandy Loam Soil (MRID No. 48604493), and North Dakota Sandy Clay Loam Soil 

(MRID No. 48604493). Anaerobic soils evaluated include United Kingdom Sandy Clay Loam Soil (MRID No. 

48604494). 
7 

aerobic and anaerobic conditions, >83 percent of benzovindiflupyr was still observed in aquatic 

environments 100 days after the application. While persistent, a large portion of 

benzovindiflupyr residues present in the water column was observed to sorb to sediment, 

amounting to between 74 percent and 85 percent of the applied amount, for a period of up to 100 

days after the application (MRID Nos. 48604509 and 48604510). Additional mesocosm studies 

with benzovindiflupyr in water-sediment systems were conducted to further investigate 

biodegradation of benzovindiflupyr mediated by the presence of algae and macrophytes in the 

environment (MRID Nos. 48604509, 48604510, and 48604578 ). However, there were 

substantial uncertainties related to incomplete accounting of the material balance over the study 

durations and mode of degradation and dissipation of benzovindiflupyr in water and sediment. 

Please refer to Section 6 for a comprehensive discussion on the nature of the uncertainties. 

1.3 Summary of Effects and Risk Conclusions 

As transformation products remained minimal in soil and water, the stressor of concern to 

aquatic and terrestrial organisms resulting from benzovindiflupyr application are due to the 

parent compound alone (see Section 2.4, Appendix F for environmental fate information, and 

Appendix G for ecological toxicity information on the degradates). When estimates of 

benzovindiflupyr exposure in terrestrial and aquatic environments are compared to the available 

ecotoxicity data, the results of the screening-level assessment indicate a potential for risk above 

the level of concern to both aquatic and terrestrial taxa broadly for all proposed uses of 

benzovindiflupyr. Please refer to Table 26 and Table 27 in the Conclusions Section of this 

document (Section 5) which present the risks of concerns found for all aquatic and terrestrial 

organisms, respectively, resulting from the proposed uses of benzovindiflupyr specified by crop. 

Risk concerns exist for acute and chronic exposures to fish and aquatic invertebrates. The 

chemical is highly toxic, persistent and RQs for many uses exceed LOCs. Risk is identified for 

acute exposures to birds and mammals and chronic exposures to mammals. There is considerable 

uncertainty associated with risk conclusions associated with birds because of the regurgitation 

based endpoint used to derive acute RQs. Although available information suggest low risk to 

bees, data gaps associated with critical life stages (i.e., larvae) and chronic exposures to adults 

prevent concluding that risk is low. Therefore, the potential bioavailability of 

benzovindiflupyr to beneficial insects which may be attracted to treated plants serves as 

rationale for additional data requests for terrestrial invertebrates (see Section 4). Available 

information indicate low concern for effects to terrestrial and aquatic plants. 

Risks in aquatic ecosystems are predominantly driven by runoff as opposed to spray drift as risk 

conclusions largely do not change when removing the contribution of spray drift. The 

implementation of a spray drift buffer of 30 feet from a neighboring water body can reduce the 

overall chronic risk for only estuarine/marine fish and invertebrates (water column). However, 

the 30 foot spray drift buffer still would not mitigate risks completely for all proposed 

benzovindiflupyr uses to other aquatic endpoints including acute freshwater fish, acute 

freshwater estuarine invertebrates, chronic freshwater fish, or benthic pore water invertebrates 

(both freshwater and estuarine-marine) endpoints. While spray drift buffers would only resolve 
8 

some chronic risks of concern, restrictions on the use of benzovindiflupyr to only every few 

years potentially can resolve acute risks of concern for aquatic organisms. 

2. PROBLEM FORMULATION 

The proposed end use products for benzovindiflupyr are emulsifiable concentrate and water 

dispersible granule formulations for use as foliar spray (ground, aerial, and chemigation) or soil 

applications (in-furrow and banded) to various agricultural crops with maximum single 

application rates ranging from 0.046 to 0.089 lb a.i./A and maximum seasonal application rates 

up to 0.272 lbs. a.i./A specified. This risk assessment provides EFED’s assessment of the 

environmental fate, terrestrial and aquatic exposure, and ecological risks associated with the 

proposed uses of benzovindiflupyr including blueberries, canola, cereal crops (oats, wheat, rye, 

and barley), corn, cotton, cucurbits, tomatoes, grapes, legumes, peanuts, pome fruit, soybeans, 

potatoes, turf grass, and nursery crops. 

Benzovindiflupyr belongs to the pyrazole-carboxamides classes of fungicides and is effective 

against a broad range of fungal diseases. Other pyrazole fungicides currently registered in the 

United States include, fluxapyroxad, penflufen, penthiopyrad, furamepyr, bixafen, and sedaxane. 

Benzovindiflupyr is intended to prevent or treat a wide variety of fungal diseases. The proposed 

mode of action identifies benzovindiflupyr as an inhibitor of the succinate dehydrogenase 

generation mechanism of the citric acid cycle2

. This process is a vital energy production step 

that takes place in the mitochondria of eukaryotic cells. 

The active ingredient benzovindiflupyr is a (50:50) racemic mixture. The proposed 

benzovindiflupyr products consist of either emulsifiable concentrate or water dispersible granule 

formulations. Emulsifiable concentrate formulations compose of benzovindiflupyr as the single 

active ingredient (10.27% a.i.) or compose of the following co-formulants: 7.5%:11.25% 

benzovindiflupyr:difenoconazole, 2.24%:11.25% benzovindiflupyr:difenoconazole, and 7.24%: 

12.07% benzovindiflupyr:propiconazole. Water dispersible granule formulations compose of the 

multiple active ingredients benzovindiflupyr (15% a.i.) and axosystrobin (30% a.i.). 

2.1 Use Characterization 

Benzovindiflupyr is proposed to be used in conventional ground, aerial, and chemigation spray 

foliar type of applications on blueberries, canola, cereal crops (oats, wheat, rye, and barley), 

corn, cotton, cucurbits, tomatoes, grapes, legumes, nursery plants, peanuts, pome fruit, soybeans, 

potatoes, and turf grass. Furthermore, banded or in-furrow pre-plant soil applications are 

proposed for peanuts and potatoes. Proposed single maximum application rates of 

benzovindiflupyr range between 0.046 – 0.089 lbs. a.i./A with the equivalent one to four 

retreatment intervals at a minimum of seven days between applications specified on the proposed 

product labels. It should be noted that this is derived from seasonal application rates rather than 

 

2 Citation: Fungicide Resistance Action Committee Classification on Mode of Action 2011. Accessible on-line: 

http://www.frac.info/frac/publication/anhang/FRAC%20MoA%20Poster%202011_final_HR.pdf

Accessed September 2014. 
9 

yearly application rates. The specification of seasonal application rates introduces uncertainty as 

more than one treatment and re-treatment cycles may occur over multiple seasons. With this 

uncertainty noted, this assessment evaluates one benzovindiflupyr treatment and re-treatment 

cycle occurring per year. This is likely the intended use pattern as suggested by resistance 

management strategies that are recommended on labels The critical use information relevant for 

outdoor uses of benzovindiflupyr is shown in Table 1. 

Table 1. Summary of proposed use information for benzovindiflupyr emulsifiable 

concentrate and water dispersible granules. 

CROP USE 

MAX. 

SINGLE 

APP. 

RATE 

(lbs. 

a.i./A)1

MAX. NUMBER OF 

APPS. and MIN. 

RETREATMENT 

INTERVAL

SEASONAL 

APP. RATE 

(lbs. a.i./A)3

APPLICATION 

METHOD 2

Corn 

0.068 4 apps., 7 days apart 0.272 Foliar Spray 

(C, G, A) 

Cucurbits 

Tomatoes and Fruiting 

Vegetables 

Grapes 

Tubers (Potatoes) 0.068 4 apps., 7 days apart 0.272 

Foliar Spray 

(C, G, A) 

Soil Banded or 

In-Furrow 

Application 

(Pre-plant) 

Peanuts 0.089 3 apps., 14 days 

apart 0.267 

Foliar Spray 

(C, G, A) 

Soil Banded or 

In-Furrow 

Application 

(Pre-plant) 

Nursery Plants, Tomato 

Transplant, Fruit 

Transplant, Cucurbit 

Transplant 

0.088 3 apps., 7 days apart 0.264 Foliar Spray 

(G Only) 

Turf Grass 0.088 3 apps., 14 days 

apart 0.264 Foliar Spray 

(G Only) 

Cotton 0.068 3 apps., 7 days apart 0.204 Foliar Spray 

(C, G, A) 
10 

Table 1. Summary of proposed use information for benzovindiflupyr emulsifiable 

concentrate and water dispersible granules. 

CROP USE 

MAX. 

SINGLE 

APP. 

RATE 

(lbs. 

a.i./A)1

MAX. NUMBER OF 

APPS. and MIN. 

RETREATMENT 

INTERVAL

SEASONAL 

APP. RATE 

(lbs. a.i./A)3

APPLICATION 

METHOD 2

Blueberries 0.068 2 apps., 10 days 

apart 0.136 

Foliar Spray 

(C, G, A) 

Soybeans 

0.068 2 apps., 7 days apart 0.136 Foliar Spray 

(C, G, A) Legumes 

Cereal (Oats, Barley, and 

Wheat) 0.068 2 apps., 14 days apart 0.136 Foliar Spray 

(C, G, A) 

Canola 0.068 1 app. 0.068 Foliar Spray 

(C, G, A) 

Pome fruit 0.046 4 apps., 7 days apart 0.184 Foliar Spray 

(C, G, A) 1. Maximum application rate based on product active ingredient density and maximum application rates (specified in 

fl oz./A) on product labels. 

2 Foliar spray method identifiers: G = Ground spray; A = Aerial Spray; C = Chemigation 3 Seasonal application rate assumed to be equivalent to a yearly application rate. Further label clarification needed 

for all crops.

2.2 Environmental Fate and Transport Characterization 

Physical and chemical properties of benzovindiflupyr are shown in Table 2 below. 

Environmental fate and transport properties of benzovindiflupyr based upon registrant submitted 

studies or other references are shown in Table 3 below.
11 

Table 2. Physical and chemical properties of benzovindiflupyr.

Property Value and units MRID or Source 

Structure MRID 48604402 

Chemical 

Formula C18H15Cl2F2N3O MRID 48604402 

Molecular 

Weight 398.2 g/mol MRID 48604402 

Vapor Pressure 

(25°C) 2.40 x 10-11 torr MRID 48604402 

Henry’s Law 

Constant 9.75 x 10-9 atm·m3

/mol EpiSuite 

HENRYWIN v. 3.20 

Water Solubility 

(pH 7, 20°C) 0.98 mg/L 

MRID 48604402 

Octanol – water 

partition 

coefficient 

(log KOW)

4.30 MRID 48604505 

Table 3. Summary of benzovindiflupyr environmental fate properties.

Study/ 

OCSPP 

Guideline 

No. 

Value and unit MRID # 

or 

Citation 

Study Classification, 

Comment 

Abiotic 

Hydrolysis 

(835.2120) 

t1/2 = Stable (pH 4 at 50°C) 

t1/2 = Stable (pH 5 at 50°C) 

t1/2 = Stable (pH 7 at 50°C) 

t1/2 = Stable (pH 9 at 25°C) 

48604506 Acceptable 

Aqueous 

Photolysis 

(835.2240) 

t 1⁄2 = 11.2 days (natural water, SFO) 

t 1⁄2 = 88.4 days (pH 7 buffer solution, SFO) 48604507 

Supplemental 

 Environmentally 

relevant half-life, 

corrected for dark 

control 

 Determination of 

natural equivalent 

photoperiod in the 

study not consistent 

with current OECD 

or OCSPP guidance. 
12 

Table 3. Summary of benzovindiflupyr environmental fate properties.

Study/ 

OCSPP 

Guideline 

No. 

Value and unit MRID # 

or 

Citation 

Study Classification, 

Comment 

Soil 

Photolysis 

(835.2410) 

Switzerland Loam (Moist): t 1⁄2 = 236 days (SFO) 

Switzerland Loam (Dry): t 1⁄2 = 492 days (SFO) 

48604495 

Supplemental 

 Environmentally 

relevant half-life, 

corrected for dark 

control 

 Determination of 

natural equivalent 

photoperiod in the 

study not 

consistent with 

current OECD or 

OCSPP guidance. 

Degradation 

in air 

(835.2370) 

Reaction with Hydroxyl Radicals 

t 1⁄2 = 0.237 days 

EpiSuite 

AopWin 

v. 1.92 

NA 

Aerobic Soil 

Metabolism 

(835.4100) 

UK SaCL: t1/2 = 1,788 days (SFO) 

France SiC: t1/2 = 1,628 days (SFO) 

Switzerland L: t1/2 = 661 days (SFO) 

California SaL: t1/2 = 1,177 days (SFO) 

North Dakota SaCL: t1/2 = 1,172 days (SFO) 

Switzerland L: t1/2 = 635 days (SFO) 

48604493 

48604492 

Acceptable

 Foreign soils were 

found to be 

representative of 

domestic soils based 

on soil taxonomy 

Supplemental

 Foreign soil 

representative of a 

few localized 

domestic soils based 

on soil taxonomy 

Anaerobic 

Soil 

Metabolism 

(835.4200) 

UK SaCL: t 1⁄2 = 1,339 days (SFO) 48604494 

Acceptable

Foreign soils were 

found to be 

representative of 

domestic soils based 

on soil taxonomy 
13 

Table 3. Summary of benzovindiflupyr environmental fate properties.

Study/ 

OCSPP 

Guideline 

No. 

Value and unit MRID # 

or 

Citation 

Study Classification, 

Comment 

Aerobic 

Aquatic 

Metabolism 

(835.4300) 

Swiss lake sand sediment: t1/2 = 616 - 742 days (n =2, SFO) 

UK lake silt loam sediment: t1/2 = 427 - 502 days (n = 2, 

SFO) 

48604509 

& 

48604510 

Supplemental 

 Study durations 

insufficient to 

determine full 

formation and 

decline cycle for 

degradates 

 Fringe anaerobic 

conditions (low 

dissolved oxygen 

levels, pe +pH <12) 

present throughout 

studies 

Anaerobic 

Aquatic 

Metabolism 

(835.4400) 

Swiss lake sand sediment: t1/2 = 767- 934 days (n=2, SFO) 

UK lake silt loam sediment t1/2 = 882 days (DFOP) & 

t1/2 = 620 days (SFO) 

48604509 

& 

48604510 

Supplemental 

 Study durations 

insufficient to 

determine full 

formation and 

decline cycle for 

degradates 

Mobility, 

unaged 

leaching, 

adsorption/ 

desorption 

(Koc) 

(835.1220) 

UK SaCL: Koc = 4,414 mL/g; Kd = 123.6 mL/g; OC = 

2.8% 

Fr SiC: Koc = 5,033 mL/g; Kd = 45.3 mL/g; OC = 0.9% 

Switzerland L: Koc = 3,900 mL/g; Kd = 78 mL/g; OC = 

2.0% 

California SaL Koc = 5,214 mL/g; Kd = 36.5 mL/g ; OC = 

0.7 % 

North Dakota SaL: Koc =3,828 mL/g; Kd = 95.7 mL/g ; OC 

= 2.5 % 

48604505 Acceptable

Terrestrial 

Field 

Dissipation 

(Soil 

Column) 

(835.6100) 

Nebraska, USA Loam/Silty Loam: t1/2 = 1,080 days 

(DFOP)6

Illinois, USA Clay Loam Soil: t1/2 = 2,725 days (SFO)6

Georgia, USA Sandy Loam Soil: t1/2 = 8,190 days (IORE) 6

California, USA Loamy Sand Soil: t1/2 = 240 days (DFOP)

Manitoba, Canada Loam Soil: t1/2 = 196,000 days 

 (IORE) 6

Georgia, USA Loamy Sand Soil: t1/2 = 582 days (DFOP) 6

New York, USA Loamy Sand Soil: t1/2 =1,610 days 

(IORE) 6

48604496 

48604497 

48604498 

48604499 

48604502 

48604511 

48604581 

Acceptable 

Acceptable 

Acceptable

Acceptable 

Supplemental4,5

Acceptable 

Supplemntal4
14 

Table 3. Summary of benzovindiflupyr environmental fate properties.

Study/ 

OCSPP 

Guideline 

No. 

Value and unit MRID # 

or 

Citation 

Study Classification, 

Comment 

Terrestrial 

Field 

Dissipation 

(Foliar 

Dissipation) 

(835.6100) 

Illinois soybean leaf disks: 

t1/2 = 4 – 10.5 days (IORE, n = 3 applications) 

Georgia whole peanut plant: 

t1/2 = 6.92 days (IORE, n = 1 application) 

Manitoba barley crop: 

t1/2 = 19.3 days (SFO, n = 1 application,) 

California turf grass clippings 

t1/2 = 0.6 – 6.8 days (IORE, n = 4 applications,) 

New York grass clippings 

t1/2 = 11.7 days (SFO, n = 1 application) 

48604497 

48604498 

48604502 

48604580 

48604581 

Acceptable 

Acceptable 

Supplemental 

Acceptable 

Supplemental4,5

Fish 

Bioconcen 

-tration 

Factor 

(BCF) 

(850.1730) 

Bluegill Sunfish 

Steady State BCF = 116 L/kg (Edible Tissues) 

Steady State BCF = 695 L/kg (Non-Edible Tissues) 

Steady State BCF = 405 L/kg (Whole Fish) 

Time to Steady State = 10 days 

Depuration t1/2 = 0.54 days, 96.9 percent total residues in 

whole fish were removed after 7 days of depuration. 

48604521 

Supplemental 

 A large portion of 

radioactivity was 

not identified

 Only one test 

concentration was 

examined

ECM/ILV 

(850.6100) 

Water 

LOQ = 0.05 g/m3

Soil 

LOQ = 0.001 mg/kg 

48604414 

48604415 

48604412,

48604413, 

48604457 

Acceptable 

 No ILV submitted

 Mean Recoveries 

less than 90 percent 

but greater than 

80.6 percent in all 

cases

Supplemental 

 Method evaluation 

conducted on 

different soils than 

evaluated in 

laboratory studies

 Mean Recoveries 

less than 90 percent 

but greater than 84 

percent in all cases 1 NA means not applicable. 

2 Half life degradation kinetics scheme determinations: 

SFO = Single First Order, IORE = Indeterminate Order Rate Equation, DFOP = Double First Order in Parallel 3 Soil textural classifications: 
15 

 Sa: Sand, SaCL: Sandy Clay Loam, SaL: Sandy Loam, LSa: Loamy Sand, SiC: Silty Clay, SiL: Silt 

 Loam, L: Loam, CL: Clay Loam 

4

 No discernible degradation of benzovindiflupyr was observed throughout the study duration. 

5 Only two applications were completed in the study amounting to a total load of 0.244 lbs.a.i./A less than the total 

maximum seasonal load of 0.272 lbs a.i./A. 

6

 Very slight to no discernible dissipation observed in the soil plots. 

 Fate and Transport Characteristics of Benzovindiflupyr in Soil and Water

Benzovindiflupyr when applied to crops and soil may be transported to surface water via erosion 

of benzovindiflupyr-ladened soil particles concurrent with rain events after application. 

Benzovindiflupyr residues are expected to be readily washed off from crops as suggested from 

foliar dissipation half-lives ranging between 0.6 – 20 days from turf, barley, peanut, and soybean 

crops (MRID Nos. 48604997, 48604998, 48604502, 48604580, and 48604581). 

Benzovindiflupyr is very persistent in the terrestrial environment, and therefore the longevity for 

it to be available for runoff will be high after its application. The total soil half-life in four field 

dissipation studies were all greater than 2,000 days3

. The total soil half-life in four other study 

plots were still highly persistent but to a lesser degree, ranging from between 240 – 1,080 days4. 

The persistence of benzovindiflupyr in the field verified well from laboratory aerobic soil 

metabolism and anaerobic soil metabolism half-lives which ranged from 635 days – 1,788 days 

in seven soils5. 

Benzovindiflupyr possesses soil-water partition coefficient (Koc) values ranging between 3,829 – 

5,221 mL/g (slightly mobile – immobile, MRID No. 48604505), and a water solubility of 0.98 

ppm (MRID No. 48604402). These high Koc and low solubility values suggest that runoff of 

benzovindiflupyr residues bound to eroded soil particles is expected to most impact surface 

water bodies. Benzovindiflupyr’s low solubility and mobility indicate that it may leach in small 

quantities. Benzovindiflupyr is not expected to escape from dry or moist soil surfaces or water 

bodies to the atmosphere via volatilization given its low vapor pressure of 2.4 x 10-11 torr (at 

20°C) and low Henry’s Law Constant of 9.75 x 10-9 atm∙m3/mol (at 25°C) (MRID No. 

48604402). 

Once reaching water bodies, benzovindiflupyr is very persistent in aquatic environments as well. 

Benzovindiflupyr was not observed to degrade at 50°C over a 30 day period in the hydrolysis 

study (MRID No. 48604506). In both aerobic and anaerobic conditions, >83 percent of 

benzovindiflupyr was still observed 100 days after the application, and half-lives ranged between 

3

 Study plots include Illinois Sandy Clay Loam Soil (MRID No. 48604497), Georgia Sandy Loam Soil (MRID No. 

48604998), Manitoba (Canada) Loam Bare Plot (MRID No. 48604502), and Manitoba (Canada) Cropped Plot 

(MRID No. 48604502). 

4

 Study plots include California Loamy Sand Soil (MRID No. 48604499), Nebraska Silty Loam Soil (MRID No. 

48604496), Georgia Loamy Sand Soil (MRID No. 48604511), and New York Loamy Sand (MRID No. 48604581). 

5

 Aerobic soils evaluated include Switzerland Loam Soil (MRID No. 48604492), United Kingdom Sandy Clay 

Loam Soil (MRID No. 48604493), France Silty Clay Soil (MRID No. 48604493), Switzerland Loam Soil (MRID 

No. 48604493), California Sandy Loam Soil (MRID No. 48604493), and North Dakota Sandy Clay Loam Soil 

(MRID No. 48604493). Anaerobic soils evaluated include United Kingdom Sandy Clay Loam Soil (MRID No. 

48604494). 
16 

427 – 934 days (MRID Nos. 48604509 and 48604510). While persistent, a large portion of 

benzovindiflupyr residues present in the water column sorb to sediment. Figure 1 shows the 

buildup and equilibration of the benzovindiflupyr material in sediment from the water column 

overtime from the four aquatic water-sediment systems examined in aerobic and anaerobic 

aquatic studies. Between 74 percent – 85 percent of applied benzovindiflupyr was observed to 

sorb to sediment for a period of up to 100 days after the application (MRID Nos. 48604509 and 

48604510). It should be noted that quasi-suboxic conditions may have existed in the aerobic 

aquatic metabolism study given low redox potentials which existed from this study. Please see 

Section 4 for further discussion. 

It should be noted that additional mesocosym type of studies were conducted for 

benzovindiflupyr in aquatic environments to further investigate the biodegradation of 

benzovindiflupyr in the total water-sediment system. These studies modified the guideline 

aerobic aquatic metabolism guidelines study design to incorporate the impact of algae and 

macrophytes separately (MRID Nos. 48604509 and 48604510) and collective impacts 

incorporating both algae and macrophtyes (MRID No. 48604578). Each of these studies were 

also conducted under conditions with a light-dark cycle using an artificial light source. There 

were substantial uncertainties in each of these mesocosm studies related to incomplete material 

balances throughout the total aquatic-sediment system over the study durations. Consequently, 

the determination of the pathway of degradation in the water column and sediment or dissipation 

to sediment of the material is also uncertain. Given these uncertainties, the aquatic exposure 

assessment and the calculated estimated exposure concentrations (EECs) relied on the more 

definitive results provided in the guideline aerobic aquatic metabolism studies without algae and 

macrophytes conducted under darkness (MRID Nos. 48604509 and 48604510), and are 

reflective of environments free of these organisms. It should be noted that the diurnal lightdarkness cycles were incorporated into the aquatic exposure analysis and EECs using the 

existing aqueous photolysis study (MRID No. 48604507). Please refer to Section 6 for a more 

comprehensive discussion on the uncertainties related to the mesocosm studies. 
17 

Figure 1. Residues of benzovindiflupyr in water and sediment compartments within the 

aerobic and anaerobic aquatic laboratory studies (MRID Nos. 48604509 and 48604510). 

 Transformation Products of Benzovindiflupyr in Soil and Water 

Given benzovindiflupyr’s persistent properties, small levels of degradates (<< 10 percent of 

applied) were found in most laboratory studies. The only exception is the aquatic photolysis 

study where pyrazole acid formed up to 38.6 percent of applied and pyrazole amine formed up to 

24.5 percent of applied 15 days after application. However, although these metabolites form in 

water in the presence of light, this transformation pathway is not expected to be prevalent in the 

environment given the low occurrence of light penetration in some water bodies nearby 

agricultural fields as well as adjacent streams and reservoirs given the turbid properties of these 

water bodies. The formation of benzovindiflupyr’s metabolites in soil and water in various 

environmental fate transformation pathways is shown in Table F-1 in Appendix F. 

 Bioconcentration of Benzovindiflupyr and Degradate Residues in Fish 

Benzovindiflupyr’s log Kow value of 4.30 suggests that residues reaching water bodies may 

partition to fatty tissue in fish. Steady-state BCF values in freshwater fish (bluegill sunfish) 

between 116 and 695 L/kg from edible tissues, non-edible tissues, and whole fish suggests there 

is moderately high bioaccumulation potential of benzovindiflupyr residues (MRID No. 

48604521). However, the depuration rate of residues is rapid with a half-life of 0.54 days with 
18 

96.9 percent of total residues removed by 7 days of depuration. Whether the depuration rate is 

first-order is unknown because only one test concentration was examined. Given the information 

on the depuration of total residues within the bluegill sunfish, it appears that accumulation of 

benzovindiflupyr residues will be minimized in flowing water bodies by its rapid depuration rate. 

No metabolites of benzovindiflupyr were known to exist in fish from the BCF study, although 

this is uncertain since a large portion of the material detected was not identified throughout the 

study. Please refer to Section 4 for further discussion. 

2.3 Ecological Toxicity Characterization 

2.3.1 Aquatic Effects 

The acute and chronic toxicity values associated with freshwater and estuarine/marine species 

exposure to benzovindiflupyr are summarized in Table 4. Toxicity endpoints shown in bold 

represent the most sensitive endpoints within a taxonomic grouping (e.g., freshwater fish, 

freshwater invertebrates, aquatic plants, etc.). These endpoints are termed the “toxicity reference 

values” which are used for this quantitative risk assessment. Aquatic toxicity studies were also 

submitted with various degradation products of parent benzovindiflupyr that were detected in 

small quantities in the environmental fate studies. Since benzovindiflupyr is the main stressor of 

concern in this risk assessment and because transformation products are not as toxic as the parent 

chemical (see Section 2.4 below), toxicological endpoints from the studies on the degradation 

products are not used in the risk assessment. However, they are summarized in Table G-1 of

Appendix G. 

Table 4. Toxicity Reference Values For Aquatic Organisms Exposed to Benzovindiflupyr.

Acute Freshwater Fish

Species Study 

Type 

Test 

Substance 

(Purity) 

LC50

Endpoints 

Affected 

Toxicity 

Classificatio

n MRID 

Acceptability (μg a.i/L)

(95% CL; 

slope) 

Fathead minnow 

Pimephales promelas

96-hr, 

flowthrough 

TGAI 

(98.3%) 

4.7 Mortality 

and 

Sublethal 

effects 

Very highly 

toxic 

48604519 

Acceptable (3.6-6.2; 

N/A) 

Rainbow trout 

Onchorhynchus 

mykiss

96-hr, 

flowthrough 

TGAI 

(98.3%) 

9.1 Mortality 

and 

Sublethal 

effects 

Very highly 

toxic 

48604518 (7.6-10.8; Acceptable

N/A) 

Carp 

Cyprinus carpio

96-hr, 

flowthrough 

TGAI 

(98.3%) 

3.5 Mortality 

and 

Sublethal 

effects 

Very highly 

toxic 

48604562 

(2.6 - 4.9; Acceptable

N/A) 
19 

Chronic Freshwater Fish

Species Study 

Type 

Test 

Substance 

(Purity) 

NOAEC; 

Endpoints 

Affected 

  

Acceptability LOAEC MRID 

(μg a.i/L)   

Fathead minnow 

Pimephales promelas

32-d 

Early 

Life 

Stage 

98.30% 0.95 ; 1.8 Growth 48604520 Acceptable

Acute Freshwater Invertebrates

Species Study 

Type 

Test 

Substance 

(Purity) 

EC50

Endpoints 

Affected 

Toxicity 

Classificatio

n MRID 

(μg a.i/L) Acceptability

(95% CL; 

slope) 

Water flea 

Daphnia magna 

48-hr, 

static 

TGAI 

98.3%) 

85 

Immobility 

 Very Highly 

toxic 

48604522 

Acceptable (71-103) 

Chronic Freshwater Invertebrates

Species Study 

Type 

Test 

Substance 

(Purity) 

NOAEC; 

LOAEC Endpoints 

Affected MRID Acceptability

(μg a.i/L) 

Water flea 

Daphnia magna

21-day 

Life 

Cycle 

TGAI 

(98.3%) 5.6 ; 15 Time to first brood 48604523 Acceptable

Acute Saltwater Fish

Species Study 

Type 

Test 

Substance 

(Purity) 

EC50

Endpoints 

Affected 

Toxicity 

Classificatio

n MRID 

Acceptability (μg a.i/L) 

(95% CL; 

slope) 

Sheepshead minnow 

Cyprinodon 

variegatus

96-hour, 

flowthrough 

TGAI 

98.3%) 

Mortality 

and 

sublethal 

effects 

Very highly 

toxic 

48604534 

Acceptable

28 

(22-36; 

NA) 
20 

Chronic Saltwater Fish

Species Study 

Type 

Test 

Substance 

(Purity) 

NOAEC; 

Endpoints 

Affected 

  

LOAEC MRID Acceptability

(μg a.i/L)   

Sheepshead minnow 

Cyprinodon 

variegatus

32-d 

Early 

Life 

Stage 

TGAI 

98.3%) 5.66; 10.77 

Determined 

through 

acute to 

Chronic 

ratio 

Not 

Applicable Not Applicable 

       

Acute Saltwater Invertebrates

Species 

Study 

Type 

Test 

Substance 

(Purity) 

EC50

Endpoints 

Affected Toxicity 

Classificatio

n MRID 

Acceptability (μg a.i/L) 

(95% CL; 

slope) 

Eastern oyster 96-hour, 

flowthrough 

TGAI 

(97%) 

160 

Shell 

Deposition 

Highly toxic 

48604537 Acceptable

Crassostrea virginica (135-192; 

NA) 

Saltwater mysid 96-hour, 

flowthrough 

TGAI 

(99%) 

47 

Mortality 

Very highly 

toxic 

48604535 

Acceptable

Americamysis bahia (36-61; 

NA) 

Chronic Saltwater Invertebrates

Species 

Study 

Type 

Test 

Substance 

(Purity) 

NOAEC; 

LOAEC 

Endpoints 

Affected Endpoints 

(μg a.i/L) MRID Acceptability

Saltwater mysid 28-d Life 

Cycle 

TGAI 

(97%) 7.4 ; 15 Reproduction Reproduction 

48604536 Acceptable

Americamysis bahia 

Freshwater Chronic Sediment Invertebrate Toxicity Tests

Species Study 

Type 

Test 

Substance 

(Purity) 

Sediment 

NOAEC / 

LOAEC 

(mg a.i/kg 

sediment) 

Pore water 

NOAEC 

(mg a.i/L) 

MRID Acceptability

Freshwater midge 

56-day, 

whole 

sediment 

TGAI (97 

%) 

2.8 ; 6.7 0.069 ; 0.22 

48604525 Acceptable

Chironomus tentans Percent 

emerged 

Percent 

emerged 
21 

Estuarine/Marine Chronic Sediment Invertebrate Toxicity Tests

Species Study 

Type 

Test 

Substance 

(Purity) 

Sediment 

NOAEC / 

LOAEC 

(mg a.i/kg 

sediment) 

Pore water 

NOAEC 

(mg a.i/L) 

MRID Acceptability

Estuarine amphipod 

28-day, 

whole 

sediment 

TGAI (97 

%) 

4.1 ; 8.7 0.098 ; 0.12 

48604583 

Acceptable

Leptocheirus 

plumulosus Survival Survival 

Aquatic Plant Toxicity Tests

Species Study 

Type 

Test 

Substance 

(Purity) 

EC50

Endpoints 

Affected MRID Acceptability

(ug a.i./L) 

(95% CL)

and 

NOAEC

(ug a.i./L)

Marine diatom 

96-hr, 

static 

TGAI 

(97%) 

240 (185-

309) 

NOAEC = 

50 

Cell density 48604550 Acceptable (Skeletonema

costatum)

Freshwater green 

algae 

96-hr, 

static 

TGAI 

(98.3%) 

> 890 ; 

N/A; 

NOAEC= 

420 

Cell yield 48604524 Acceptable (Pseudokirchneriell

a subcapitata )

Duckweed 7-day 

static 

renewal 

TGAI 

(97%) 

> 880 ; 

N/A; 

NOAEC = 

430 

Growth

rate   48604526 Acceptable (Lemna gibba) 

* EC05 used for estimation of risk to endangered aquatic plant in the event the NOAEC is non-definitive. 

Bolded values refer to the most sensitive endpoint for a given taxa to be used in quantitative risk assessment. 

 Freshwater Fish 

Acute toxicity studies with technical-grade benzovindiflupyr were available for three species of 

freshwater fish: fathead minnow (Pimephales promelas), rainbow trout (Oncorhynchus mykiss)

and carp (Cyprinus carpio) All studies were conducted on TGAI with 98.3% purity. In the 

fathead minnow study (MRID 48604519) the mean-measured concentrations were <LOQ 

(<0.019, negative and solvent controls), 0.54, 1.1, 2.2, 4.4, and 9.4 μg a.i/L. At 96 hours, 

mortality was 43 and 100% in the 4.4 and 9.4 μg/L (mean measured) treatment groups, 
22 

respectively, the two highest treatment concentrations tested. The LC50 was 4.7 μg a.i/L 

classifying benzovindiflupyr as very highly toxic. Sublethal effects included fish being observed 

on the bottom of the test vessel and complete loss of equilibrium in the 4.4 μg a.i/L group at 96 

hours. In the 9.4 μg a.i/L group, fish were observed with complete loss of equilibrium, fish on 

the bottom of the test vessel, and dark in coloration. This study was classified as acceptable. 

In the rainbow trout study (MRID 48604518) the mean-measured concentrations were <LOQ 

(<0.061, negative and solvent controls), 1.5, 2.3, 4.7, 9.8, and 18 μg a.i/L. At 96 hours, mortality 

was 57 and 100% in the 9.8 and 18 μg a.i/L (mean measured) treatment groups, respectively, the 

two highest treatment concentrations tested. The LC50 9.1 μg a.i/L classifying benzovindiflupyr 

as very highly toxic. Sublethal effects included partial loss of equilibrium and dark in coloration 

in the 4.7 μg a.i/L group at 72 and 96 hours. In the 9.8 μg a.i/L group, fish were observed with 

complete loss of equilibrium, fish on the bottom of the test vessel, and dark in coloration. This 

study was classified as acceptable.

In the carp study (MRID 48604562), the mean-measured concentrations were <LOQ (<0.022, 

negative and solvent controls), 0.61, 1.1, 2.3, 5.4, and 10 μg a.i/L. At 96 hours, mortality was 

14, 100, and 100% in the negative control, 5.4, and 10 μg a.i/L groups, respectively. The LC50

was 3.5 μg a.i/L classifying benzovindiflupyr as very highly toxic. Sublethal effects included 

loss of equilibrium, dark in coloration, lethargic, and fish on the bottom of the test vessel in the 

5.4 μg a.i/L group throughout the test. In the 10 μg a.i/L group, fish were observed with 

complete loss of equilibrium and on the bottom of the test vessel. This study was classified as 

acceptable. 

Based on the available data, TGAI benzovindiflupyr is classified as very highly toxic to fish and 

the carp LC50 of 3.5 μg a.i/L will be used for estimating risk to this taxa. 

There were two additional acute freshwater fish toxicity studies submitted with degradation 

products of benzovindiflupyr. Both studies were conducted with the rainbow trout. In one study 

conducted with 98% purity of degradation product SYN546039 (MRID 48604545), the meanmeasured concentrations were <LOQ (<0.0544, negative control), 0.19, 0.41, 0.87, 1.9, 3.9, and 

7.2 mg a.i/L. At 96 hours, mortality was 14, 100 and 100% in the 1.9, 3.9, and 7.2 mg a.i/L 

groups, respectively. Sublethal effects included fish lying on side or back on bottom, strong 

ventilation, and tumbling during swimming in the 3.9 mg a.i/L group at 4 and 24 hours. In the 

1.9 mg a.i/L group, one fish at 48 hours was observed mainly on the bottom of the test vessel. 

The 96 hour LC50 based on mean-measured concentrations was 2.5 mg a.i/L. This study was 

classified as acceptable and suggests this metabolite is moderately toxic to rainbow trout. In the 

other study conducted with 99.2% purity of degradation product M700F001 (MRID 47923726), 

the limit test used a mean-measured concentration was 88.1 mg/L under static conditions. The 

96-h LC50 was >88.1 mg/L and there were not any mortalities or sublethal effects observed 

during the 96 hour test. This study was classified as acceptable and suggests that M700F001 is 

slightly to practically non-toxic to rainbow trout.

In a chronic early life stage test with a freshwater fish (fathead minnow, MRID 48604520) 
23 

conducted with TGAI benzovindiflupyr (98.3% purity), fertilized eggs/embryos (120/level, 6 

hours old) of fathead minnows were exposed to mean measured concentrations of ≤0.021 μg/L 

(negative and solvent controls), 0.29, 0.49, 0.95, 1.8, and 3.6 μg a.i/L. There were no treatmentrelated effects for pre-hatch survival and times to hatch. Larval survival at 28 days post-hatch 

was significantly reduced at the 3.6 μg a.i/L (mean measured) treatment concentration. The total 

length and dry weight were significantly reduced at ≥ the 1.8 μg a.i/L (mean measured) treatment 

concentration. The 32-day NOAEC and LOAEC based on mean measured concentrations were 

0.95 and 1.8 μg a.i/L, respectively for mean dry weight and mean length. . This study was 

classified as acceptable and for risk assessment purposes, a chronic toxicity of 0.95 μg a.i/L will 

be used for estimating chronic risk quotients for freshwater fish.

 Freshwater Invertebrates 

An acute toxicity study conducted with TGAI benzovindiflupyr (98.3%) on freshwater 

invertebrates was available for Daphnia magna (MRID 4864522). The mean-measured 

concentrations were <0.74 μg/L (<LOQ; negative and solvent controls), 8.5, 21, 56, 130, and 

330 μg a.i/L. Immobilization was 0% in the controls and ≤56 μg/L treatment groups, 100% in 

the 130 μg a.i/L and 330 μg a.i/L treatment groups. All surviving daphnids were lethargic in the 

56 μg a.i/L treatment group at 48 hours. The 48-hr EC50 values was and 85 μg a.i/L indicating 

that benzovindiflupyr is very highly toxic to freshwater invertebrates. This study is classified as 

acceptable and 85 μg a.i/L will be used for estimating acute risk quotients for freshwater 

invertebrates. 

There were two additional acute freshwater invertebrate toxicity studies submitted with 

degradation products of benzovindiflupyr, both conducted with Daphnia magna. One study was 

conducted with the degradation product of both benzovindiflupyr and fluxapyroxad (another 

pyrazole fungicide as indicated in Section 2). The degradate M700F001 had a purity 99.2% 

(MRID 47923732). The mean-measured concentrations were <LOQ (<0.05, negative control), 

9.37, 17.4, 38.9, 54.6, and 98.2 mg a.i/L. No treatment-related mortality or immobility was 

observed in the control and all treatment groups. The 48-hr EC50 was >98.2 mg a.i/L suggesting 

that this degradate is practically non-toxic to freshwater invertebrates. This study was classified 

as acceptable. The other study was conducted with the degradate SYN546039 that had a purity 

of 98% (MRID 48604546). The mean-measured concentrations were <LOQ (<0.0544, negative 

control), 0.40, 0.87, 1.9, 3.9, and 8.1 mg a.i/L. Immobilization was 0% in the controls and ≤1.9 

mg/L treatment groups, 10% in the 3.9 mg a.i/L treatment group, and 100% in the 8.1 mg a.i/L 

treatment group. Daphnids were observed with reduced swimming activity in the 3.9 and 8.1 mg 

a.i/L treatment groups. The 48-hr EC50 values was 5.2 mg a.i/L suggesting that this metabolite is 

moderately toxic to freshwater invertebrates. This study was classified as acceptable. 

A freshwater invertebrate (Daphnia magna) lifecycle test with benzovindiflupyr TGAI (98.3%) 

was submitted and found to be supplemental / reliable with restrictions (MRID 48604523). The 

21-day chronic toxicity was studied under static renewal conditions. Daphnids (<24 hours old; 

20 per level) were exposed to benzovindiflupyr at mean measured concentrations were ≤0.059 

μg a.i/L (≤LOQ; negative and solvent controls), 0.88, 2.7, 5.6, 15, 34, and 95 μg/L. Treatment-
24 

related reductions from the negative control were observed for parental survival at 95 μg a.i/L 

(mean measured, the highest treatment concentration tested and where there was complete 

mortality), and dry weight at 0.88 μg a.i/L (mean measured, the lowest treatment concentration); 

the number of live offspring was unaffected by treatment up to 15 μg a.i/L and no offspring were 

produced at 34 μg a.i/L. There were no effects on parental length up to the 34 μg a.i/L (mean 

measured) treatment concentration, although data from the 95μg a.i/L treatment concentration 

were excluded due to complete mortality in that treatment concentration. There was also a 

significant increase in the average time to first brood at the 15 μg a.i/L level relative to the 

negative control (Day 9). The NOAEC and LOAEC 5.6 μg/L and 15 μg a.i/L based on an 

increase in time to first brood as compared to the negative control. This study was classified as 

acceptable due to the non-definitive endpoint and the NOAEC of 5.6 μg/L will be used for 

estimating chronic risk quotients for freshwater invertebrates.

 Estuarine/Marine Fish 

One acute toxicity study was submitted conducted with TGAI benzovindiflupyr (98.3% purity) 

to the sheepshead minnow, Cyprinodon variegates (MRID 48604534). The mean-measured 

concentrations were <LOQ (<0.3, negative and solvent controls), 8.7, 16, 32, 70, and 150 μg 

a.i/L and ranged from 64-75% of nominal values. At 96 hours, mortality was 71, 100, and 100% 

in the 32, 70, and 150 μg a.i/L (mean measured) treatment groups, respectively, the three highest 

treatment concentrations tested. In the 32 μg a.i/L group, sublethal effects were observed 

throughout the test and included lethargic fish, complete loss of equilibrium, and fish on the 

bottom of the test vessel. Sublethal effects included lethargic fish and complete loss of 

equilibrium in the 70 μg a.i/L group at 24 hours. The 96 hour LC50, based on mean-measured 

concentrations, were 28 μg a.i/L suggesting that benzovindiflupyr is very highly toxic to 

estuarine/marine fish. This study was classified as acceptable and this endpoint will be used with 

assessing acute risk to estuarine/marine fish. 

There was not an estuarine/marine chronic fish early life stage test conducted with 

benzovindiflupyr. The NOAEC and LOAEC determined through examining the acute to chronic 

ratios of the fathead minnow were 5.66 μg a.i/L and 10.77 μg a.i/L respectively. 

 Estuarine/Marine Invertebrates 

Acceptable acute toxicity studies were available for two species of estuarine/marine 

invertebrates: the eastern oyster (Crassotrea virginica; MRID 48604537, and the mysid shrimp 

(Americamysis bahia; MRID 48604535). The oyster study examined reduction in shell 

deposition under flow- through conditions with TGAI of 97% purity. At test termination, mean 

shell growth in the control and solvent control was 2.8 and 3.2 mm, respectively. Mean shell 

growth in the 22, 35, 67, 140 and 240 μg a.i./L treatment levels was 2.8, 2.7, 2.4, 1.5 and 0.9 

mm, respectively. The percent reduction of shell growth at the 22, 35, 67, 140 and 240 μg a.i./L 

treatment levels was 5, 9, 19, 50 and 68%, respectively. Based on mean measured 

concentrations, the 96-hour EC50 was 160 μg a.i./L, indicating that benzovindiflupyr was highly 

toxic to the eastern oyster. 
25 

The mysid shrimp test was conducted with TGAI of 99% purity with mean measured treatment 

concentrations of control, and solvent control, 7.4, 17, 48, 120, 250 μg a.i./L. Following 24 

hours of exposure, 100% mortality was observed among mysids exposed to the 250 μg/L (mean 

measured) treatment level, the highest treatment level tested. At test termination (96 hours), 10, 

35 and 100% mortality was observed in mysids exposed to the 17, 48 and 120 μg a.i/L (mean 

measured) treatment levels, respectively, the three highest treatment levels tested. Several 

surviving mysids exposed to the 48 μg a.i/L treatment level were observed to be lethargic at test 

termination. Mortality of 5% was observed in mysids exposed to the solvent control. No 

mortality or adverse effects were observed for mysids exposed to the remaining treatment level 

tested (7.4 μg a.i/L) or the dilution water control. Based on mean measured concentrations, the 

96-hour LC50 was estimated to be 47 μg a.i/L indicating that that benzovindiflupyr is very highly 

toxic to saltwater mysids. This study was classified as acceptable and this endpoint will be used 

to assess the acute risk to estuarine/marine invertebrates. 

An estuarine/marine invertebrate (Americamysis bahia) lifecycle test with benzovindiflupyr 

TGAI (97 %) (MRID 48604536) exposed mysids to mean-measured concentrations were <0.24 

(<LOQ, control), 1.9, 3.5, 7.4, 15, and 31 μg ai/L throughout their life cycle. The number of 

offspring per female averaged 25.5 for the control group, and 20.7, 20.0, 21.6, 17.0, and 0.7 for 

the mean-measured 1.9, 3.5, 7.4, 15, and 31 μg ai/L levels, respectively. This endpoint was 

significantly reduced (p<0.05) compared to the controls at 15 and 31 μg ai/L. The NOAEC and 

LOAEC values for reproduction were 7.4 and 15 μg ai/L, respectively, based upon meanmeasured concentrations. This endpoint will be used to assess chronic risk to estuarine/marine 

invertebrates. The NOAEC and LOAEC for F0 female dry weight, F0 male dry weight, F0 male 

length, F0 survival post-pairing, were 15 and 31 μg ai/L respectively. This study was classified 

as acceptable.

 Benthic (Sediment Dwelling) Invertebrates 

The effect of benzovindiflupyr on freshwater benthic invertebrates is available from one study 

utilizing a 56 day exposure via spiked sediment to the midge Chironomous tentans (MRID 

48604525). Midges were exposed to mean-measured sediment concentrations were <0.28 

(<LOQ, controls), 2.8, 6.7, 12, 24, and 48 mg ai/kg and mean-measured pore-water 

concentrations were <LOQ (controls), 0.069, 0.22, 0.28, 0.67, and 1.15 mg a.i/L. The most 

sensitive endpoints that were affected included percent emerged and number eggs per emerged 

female. There were reductions in emergence from control of 19.4% and 17.7% in the 12 and 48 

mg a.i/kg sediment level. Statistical analysis determined significant effects in emergence 

(p<0.05) at the three highest treatment concentrations (12, 24, and 48 mg a.i/kg sediment). A 

42% reduction from control in number of eggs per emerged female at the 6.7 mg a.i/kg sediment 

was not identified as significant (p>0.05. However, the study reviewer determined that a 42% 

reduction from control for this endpoint is biologically meaningful and therefore the NOAEC 

and LOAEC for number of eggs per emerged female were determined to be 2.8 and 6.7 mg a.i/kg 

sediment, respectively and 0.069 and 0.22 mg a.i./L porewater respectively. 
26 

One 28-day sediment toxicity test on an estuarine/marine amphipod Leptocheirus plumulosus is 

available (MRID 48604583). Amphipods were exposed to 0 (negative and solvent control), 2.1, 

4.1 8.7, 17, 37 and 68 mg a.i. /kg dry weight sediment. Concentrations of Benzovindiflupyr 

remained mainly with the sediment throughout the duration of the test. The porewater 

concentrations were 0.020, 0.046, 0.11, 0.22, 0.42 and 0.76 mg a.i./L. There were not any 

sublethal or behavioral effects that were observed in any of the treatment levels. Survival was 88 

and 80 percent for the negative and solvent controls, respectively and 83%, 88%, 56%, for 2.1, 

4.1 and 8.7 treatment levels respectively. There was 100% mortality in the three highest test 

concentrations. The NOAEC and LOAEC were determined to be 4.1 and 8.7 mg a.i. / kg 

sediment and 0.098 and 0.12 mg a.i./L porewater based on effects to survival. This study was 

classified as acceptable. 

 Vascular and Non-vascular Aquatic Plants 

Two non-vascular aquatic plant studies (algae) (MRIDs 48604550,48604524) were submitted 

along with one vascular aquatic plant study (MRID 48604526) for the parent benzovindiflupyr. 

One algal study was submitted for the metabolite SYN46039 (MRID 48604547). 

In an acceptable study with the marine diatom Skeletonema costatum (MRID 48604550), TGAI 

benzovindiflupyr (purity 97%) cultures were exposed to mean measured concentrations of 

<0.0020 (<LOQ, negative and solvent controls), 0.047, 0.10, 0.20, 0.40, and 0.72 mg/L mg a.i/L 

to cultures. After 96 hours, the NOAEC and EC50 values based on yield were 0.05 and 0.24 mg 

a.i./L, respectively. No abnormalities were noted. Percent growth inhibition based on cell 

density in the treated algal culture as compared to the negative control ranged from 14 to 89%. 

This study was classified as acceptable. In an acceptable study with the freshwater green alga, 

Pseudokirchneriella subcapitata (MRID 48604524), TGAI benzovindiflupyr (purity 98.3%), 

cultures were exposed to a two concentration limit test with mean measured concentrations of 

420 and 890 μg a.i/L. The EC50 and NOAEC were >890 μg a.i/L and 420 μg a.i/L respectively. 

This study was classified as acceptable.

In the aquatic vascular plant toxicity study, Lemna gibba (duckweed) was exposed to mean 

measured treatment concentrations of 58, 110, 230, 430 and 880 μg a.i./L. The EC50 and 

NOAEC after the seven day exposure was >880 and 430 ug a.i./L respectively for biomass yield 

and growth rate based on biomass. This study was classified as acceptable. 

In another study (MRID 48604547) conducted with Pseudokirchneriella subcapitata, the 

benzovindiflupyr degradate (SYN46039, 98% purity) was exposed to cultures at mean measured 

concentrations of <0.0544 (<LOQ, negative control), 0.21, 0.41, 0.90, 1.9, 4.0, and 6.4 mg a.i./L 

under static conditions. The highest concentration represented the limit of water solubility. 

After 96 hours, the most sensitive NOAEC and EC50 values were 0.41 and 15.8 mg a.i./L, 

respectively, based on area under the curve (AUC). No abnormalities were noted. Percent 

growth inhibition based on cell density in the treated algal culture as compared to the negative 

control ranged from -4.4 to 26.7%. This study was classified as acceptable. 
27 

2.3.2 Terrestrial Effects 

All toxicity reference values used to assess the potential acute and chronic risks of 

benzovindiflupyr exposure to birds, mammals, and invertebrates were obtained from acceptable 

or supplemental studies using benzovindiflupyr TGAI (Table 5). 

Table 5. Toxicity Reference Values For Terrestrial Organisms Exposed To Benzovindiflupyr. 

Exposure 

Scenario % A.I. Species Dur. 

Toxicity 

Reference 

Value 

(std dev; 

slope) 

Endpoints 

Affected 

MRID; 

Classification Acceptability 

Birds 

Acute 

TGAI 

(97%) 

Bobwhite quail 

14 d 

 LD50 : 1373 

(1047-1978; 

NA) mg/kg bw 

Mortality, body 

weight, and sublethal effects 

Slightly toxic 

Acceptable (Colinus 

virginianus) 48604512 

TGAI 

(98.3%) 

Bobwhite quail 

14 d 

LD50: 

>1014(N/A; 

N/A) mg/kg 

bw 

NA 

Slightly toxic 

Acceptable 

(Colinus 

virginianus) 48604598 

TGAI 

(97%) 

Zebra Finch 

(Taeniopygia 

guttata

14 d 

14-d LD50 = 10 

(N/A; N/A) 

mg/kg bw 

Regurgitation 

equates to 

mortality in the 

absence of better 

data 

Highly toxic 

Supplemental 

48604513 

Acute 

Dietary 

TGAI 

(97%) 

Zebra Finch 

(Taeniopygia 

guttata

5 d 

LD50: < 562 

(N/A; N/A) 

mg/kg bw 

≥70% mortality at 

all treatment 

levels 

49383802 Supplemental 

SubAcute 

Dietary 

TGAI 

(97%) 

Bobwhite Quail 

Colinus 

virginianus

8 d 

8-d LC50 : > 

6390 mg a.i/kg 

diet (N/A; 

N/A) 

Mortality, body 

weight, and food 

consumption 

Practically 

nontoxic Acceptable 

48604515 

TGAI 

(97%) 

Mallard duck 8 d 

LC50: >6390 mg 

a.i/kg diet (95% 

CI not available) 

Mortality, body 

weight, and food 

consumption 

Practically 

nontoxic 

Acceptable (Anas 

platyrhynchos) 48604514 

Chronic 

Reproduc

-tion 

TGAI 

(97%) 

Mallard Duck 

Anas 

platyrhynchos

20 

week

s 

NOAEC=59.4 

mg a.i/kg diet 

hatchling weight, 

14-day survival 

weight, mean 

food 

48604516 Acceptable LOAEC=202 

mg a.i/kg diet 
28 

Table 5. Toxicity Reference Values For Terrestrial Organisms Exposed To Benzovindiflupyr. 

Exposure 

Scenario % A.I. Species Dur. 

Toxicity 

Reference 

Value 

(std dev; 

slope) 

Endpoints 

Affected 

MRID; 

Classification Acceptability 

consumption, 

female weight 

gain 

TGAI 

(97%) 

Bobwhite Quail 

Colinus 

virginianus

20 

week

s 

NOAEC= 610 

mg a.i/kg diet 

 48604517 Acceptable LOAEC= >610 

mg a.i/kg diet 

Mammals 

Acute 

 Rat 

14 d 

LD50 = 66.3 mg 

ai/kg bw 

(females) 

   

Acceptable TGAI 

97% 

(Rattus 

norvegicus) Mortality 

48604427 

 

     

Chronic 

TGAI 

97% 

Rat 

2 

gen 

NOAEL = 8.2 

mg/kg/day 

(females) Decreased body 

weight/weight gain 

and decreased food 

consumption in 

parental males 

Acceptable (Rattus 

norvegicus) 

LOAEL = 19.4 

mg/kg/day 48604449 

       

Nontarget Insects - Bees 

Acute 

TGAI 

98.3% 

Honeybee Apis 

mellifera 48 h 

LD50: > 100 ug 

ai/bee (95% CI 

N/A) 



Practically nontoxic 

Acceptable 

(Acute contact 

toxicity) 48604527 

TGAI 

98.3% 

Honeybee 

Apis mellifera

48 h 

LD50: > 109 ug 

ai/bee (95% CI 

N/A) 

 Practically nontoxic 48604527 Acceptable 

(Oral toxicity 

study) 
29 

Table 5. Toxicity Reference Values For Terrestrial Organisms Exposed To Benzovindiflupyr. 

Exposure 

Scenario % A.I. Species Dur. 

Toxicity 

Reference 

Value 

(std dev; 

slope) 

Endpoints 

Affected 

MRID; 

Classification Acceptability 

Other Non-target Terrestrial Organisms 

Acute TGAI 

94.7% 

Earthworm 

(Eisenia fetida) 14 d 

LC50: 463 mg 

a.i/kg dw soil 

 Mortality was 

significantly higher 

in two highest 

concentrations

PMRA 

2255438,2255478 

Supplemental NOAEC (body 

weight): 125 mg 

a.i/kg soil 

 Body weight was 

significantly 

reduced (p<0.05) at 

the three highest 

concentrations

Supplemental 

NOAEC 

(mortality): 250 

mg a.i/kg soil 

 

Acute 

SYN545

192 EC 

(synony

m: 

A17056F

) 

Guarante

e: 150 

g/L 

benzovin

diflupyr 

Parasitic Wasp 

Aphidus 

rhopalosiphi

13 d 

 2-d LR50 = 

578 mL 

product/ha 

(86.7 g a.i./ha) 

(95% CL 507 

– 667 mL 

product/ha)2-d 

NOER 

[mortality] = 

208.3 mL 

product/ha 

(31.25 g 

a.i./ha) 11-d 

NOER 

[reproduction]: 

416.5 mL 

product/ha 

(62.5 g a.i./ha) 

Effects on nontarget terrestrial 

arthropods on 

artificial substrate 

IIA 8.8.1.1/01 

PMRA-2307584 

(Word doc) and 

PMRA-2255447 

(PDF) 

Supplemental 

Acute 

SYN545

192 EC 

(synony

m: 

A17056F

) 

Guarante

e: 150 

g/L 

Predatory mite 

Typhlodromus pyri 14 d 

7-d LR50: > 

833.33 mL 

product/ha ( > 

125 g a.i./ha) 

7-d NOER 

[mortality]: 

833.33 mL 

product/ha 

Effects on nontarget terrestrial 

arthropods on 

artificial substrate 

IIA 8.8.1.2/01 

PMRA-2307583 

(Word doc) and 

PMRA-2255451 

(PDF) 

Supplemental 
30 

Table 5. Toxicity Reference Values For Terrestrial Organisms Exposed To Benzovindiflupyr. 

Exposure 

Scenario % A.I. Species Dur. 

Toxicity 

Reference 

Value 

(std dev; 

slope) 

Endpoints 

Affected 

MRID; 

Classification Acceptability 

benzovin

diflupyr 

(125 g 

a.i./ha)14-d 

NOER 

[reproduction]: 

3333 mL 

product/ha 

(500 g a.i./ha) 

Acute 

Benzovi

ndiflupyr 

EC 

(synony

m: 

A15457F

H) 

Guarante

e: 100 

g/L 

SYN545

192 

Parasitic Wasp 

Aphidus 

rhopalosiphi 

13 d 

2-d LR50: 2650 

mL product/ha 

(C.L. 2102 – 

3482 mL 

product/ha)[26

5 (C.L. 210 – 

348) g 

a.i./ha]2-d 

NOER 

[mortality]:750 

mL product/ha 

(75 g 

a.i./ha)11-d 

NOER 

[reproduction]:

1500 mL 

product/ha 

(150 g a.i./ha) 

Effects on nontarget terrestrial 

arthropods in 

extended 

laboratory tests 

IIA 8.8.2.1/01 

PMRA-2307606 

(Word doc) and 

PMRA-2255555 

(PDF) 

 

 

Supplemental 

Acute 

Benzovi

ndiflupyr 

EC 

(synony

m: 

A15457F

H) 

Guarante

e: 100 

g/L 

SYN545

192 

Predatory mite 

Typhlodromus pyri 14 d 

7-d LR50: > 

6000 mL 

product/ha ( > 

600 g a.i./ha) – 

highest test 

conc. 7-d 

NOER 

[mortality]:300

0 mL 

product/ha 

(300 g 

a.i./ha)14-d 

NOER 

[reproduction]: 

6000 mL 

product/ha 

(600 g a.i./ha) 

Effects on nontarget terrestrial 

arthropods in 

extended 

laboratory tests 

IIA 

8.8.2.2/01PMRA

-2307607 (Word 

doc) and PMRA2255551 (PDF) 

Supplemental 

Bolded values refer to the most sensitive endpoint for a given taxa to be used in quantitative risk assessment. 

*Regurgitation guidance (referenced in the effects section) states that the endpoint is the highest 
31 

 Birds (Acute and Sub-Acute Toxicity) 

Three acute oral studies are available of three avian species (northern bobwhite quail, mallard 

duck, zebra finch) and two subacute dietary toxicity studies are available for two avian species 

(northern bobwhite quail, mallard duck). 

The first acute study with bobwhite quail (exposed birds via oral gavage to concentrations of 0 

(vehicle control) 292, 486, 810, 1350, and 2250 mg ai/kg-bw. On Day 14, there was 0, 0, 10, 0, 

60, and 80% mortality in the 0 (vehicle control) 292, 486, 810, 1350, and 2250 mg ai/kg-bw 

groups, respectively. Sub-lethal effects were observed at all treatment levels and included one or 

more of the following characteristics: ruffled appearance, lethargy, loss of coordination, lower 

limb weakness, prostrate posture, loss of righting reflex, hyper-excitability, lower limb rigidity, 

sporadic movement about cage, sporadic head movement, and depression. Treatment-related 

effects were observed for overall body weight gain and feed consumption. The 14-day acute oral 

LD50 for northern bobwhites exposed to SYN545192 (Benzovindiflupyr) was 1373 mg a.i./kgbw. This would classify Benzovindiflupyr as slightly toxic to the northern bobwhite quail on an 

acute oral basis. This study was classified as acceptable. 

The second acute study with bobwhite quail exposed birds via oral gavage to a four stage 

sequential testing design with concentrations in stage 1 of 0 (vehicle control) or 2000 mg /kg-bw; 

stage 2 at concentrations of 392, 497, 630, 800, 1014, 1286, 1632, 2070, 2625, and 3330 mg/kgbw; Stage 3 at concentrations of 889, 1129, 1433, 1819, and 2309 mg/kg-bw; stage 4 at 

concentrations of 1025, 1301, 1652, 2097, and 2662 mg/kg-bw. Sub-lethal effects were 

observed at all treatment levels during all stages. Body weight reductions were reported for 28 

of 29 surviving birds from Days 0 to 3, and a majority of birds continued to lose weight from 

Days 3 to 7, and overall weight loss was observed for Days 0 to 14. The 14-day acute oral LD50

for Northern bobwhites exposed to SYN545192 (Benzovindiflupyr) was estimated as >1014 mg 

a.i./kg-bw. This study was classified as acceptable. 

The third study with zebra finch exposed birds to benzovindiflupyr using a two stage test via oral 

gavage. Regurgitation was observed at all treatment levels in Stages 1 and 2. During stage 1, ten 

(5/sex/group) birds were exposed once to the test material at concentrations of 0 (vehicle 

control), 259, and 432 mg ai/kg-bw. Two males dosed at 259 mg ai/kg-bw and three males 

dosed at 432 mg ai/kg-bw were observed for 14 days post-dosing (mortality only). During stage 

2, up to 18 (9 male and 9 female) birds were exposed once to the test material at concentrations 

of 0 (vehicle control), 10, 32, 100, and 320 mg ai/kg-bw. Ten (5/sex/group) birds that did not 

regurgitate in the 10 and 32 mg ai/kg-bw doses were observed for 14 days post-dosing. On Day 

14, there was 0, 0, 0, 0, 50, and 33.3% mortality in the 0 (vehicle control 1), 0 (vehicle control 

2), 10, 32, 259, and 432 mg ai/kg-bw groups, respectively. No treatment-related effects were 

observed for body weight or feed consumption. This study is classified as supplemental, as it 

does not fully satisfy the guideline requirement for acute oral toxicity study a passerine species 

due to the high degree of regurgitation throughout the study. The observation of regurgitation at 

all but the lowest treatment levels precluded the ability to derive a meaningful LD50 from this 

study that could be used in risk assessment as it is unclear what dose the birds actually received. 
32 

EFED guidance6

 indicates to use the highest value below which regurgitation did occur as the 

acute endpoint for this study. Based on this the LD50 is 10 mg/kg bw and categorizes 

benzovindiflupyr as highly to very highly toxic to the zebra finch. 

An additional acute dietary toxicity test was submitted for zebra finch to try to better understand 

the toxic effects of solatenol on passerine species (MRID 49383802). This study exposed birds 

to nominal doses of 0 (negative control), 562, 1000, 1780, 3160, and 5620 mg ai/kg bw of diet in 

a 5 day test. A reliable LC50 could not be determined due to ≥70% mortality at all treatment 

levels and survival data possibly being confounded by food avoidance and resulting starvation. 

This study could not be used to derive an endpoint but indicates that solatenol is toxic to the 

zebra finch in the doses that were administered. 

There were two subacute studies submitted for the northern bobwhite quail (MRID 48604515) 

and mallard duck (MRID 48604514), both categorizing benzovindiflupyr practically non-toxic 

on a sub-acute basis. In the northern bobwhite quail study, birds were exposed to meanmeasured concentrations were <50 (<LOQ, control), 588, 959, 1780, 3130, and 6390 mg ai/kgdiet, respectively. Mortality was limited to one bird in the control group and one bird in the 6390 

mg ai/kg-diet (mean measured) treatment group, the highest concentration tested. The LC50

based on mean-measured concentrations was >6390 mg ai/kg-diet. This study was classified as 

acceptable. In the mallard duck study, birds were exposed to mean-measured concentrations of 

<50 (<LOQ, control), 588, 959, 1780, 3130, and 6390 mg ai/kg-diet. There was not any 

treatment-related mortality during the study. Slight lethargy was reported on days 4 and 5 but all 

birds appeared normal on days 6-8. The 8-day acute dietary LC50 based on mean-measured 

concentrations was >6390 mg ai/kg-diet. This study was classified as acceptable. For risk 

assessment purposes, a subacute dietary LC50 of > 6390 ppm in the diet) will be used 

qualitatively to evaluate potential acute effects to birds (i.e., a lower bound of 6390 ppm will be 

assumed as a screen for acute effects). 

 Birds (Chronic Toxicity) 

Two studies were submitted that examined the chronic toxicity of benzovindiflupyr to avian 

species. In the mallard duck study (MRID 48604516) 22 week old birds were exposed to meanmeasured concentrations were <25 (<LOQ, control), 59.4, 202, and 598 mg ai/kg diet. Based 

upon treatment-related effects on adult female body weights and offspring body weights 

(hatchling weight and 14-d survivor weight) at the 202 and 598 mg ai/kg diet levels, the overall 

NOAEC and LOAEC were 59.4 and 202 mg ai/kg bw, respectively. There were no treatmentrelated effects noted for any treatment level regarding adult survival, clinical signs of toxicity, 

food consumption, or gross pathological findings. Data for male body weight gain were very 

 

6

 Citation: 

(http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/terrestrial_biology_t

ech_team/rr_regurg_acute_passerine.pdf)
33 

highly variable (%CV over 300 for treatment concentrations) and so while no significant effects 

were observed (p<0.05), percent reductions from control were 34.5, 12.6, and 136.8% for the 

59.4, 202, and 598 mg a.i/kg/diet treatment concentrations, respectively. There was a decreasing 

dose-dependent trend for female body weight gain. The body weight gain of females was 

significantly reduced from control (p<0.05) at the 202 and 598 mg ai/kg-diet levels. No 

treatment-related effects on reproduction were evident at the 59.4 mg ai/kg diet treatment level. 

At the 598 mg ai/kg diet level, the reviewer’s analysis detected a significant reduction in egg 

production (p=0.022), relative to the control. Additionally, there were dose-dependent treatment 

reductions upon offspring body weights at the 202 and 598 mg ai/kg diet levels, with 

statistically-significant differences indicated for both hatchlings and 14-day old chicks (p<0.05; 

William’s test). This study was classified as acceptable. 

In the bobwhite quail study (MRID 48604517), birds were exposed to mean-measured 

concentrations of <25 (<LOQ, control), 60.0, 200, and 610 mg ai/kg diet, There was a slight, but 

significant dose-dependent reduction in the ratio of live 3-week embryos to viable embryos at the 

200 and 610 mg ai/kg treatment levels (p<0.005; Jonckheere-Terpstra). However, the reduction 

in this reproductive endpoint did not exceed 1% of control and there were no other reproductive 

treatment-related effects noted in the study. There were no treatment-related effects on adult 

survival, clinical signs of toxicity, food consumption, adult body weight, or gross pathological 

findings. While statistically significant (p<0.05) effects on male body weight gain were 

attributed to high variation in the data and not related to treatment as a stimulatory effect on body 

weight gain was observed in females. Based on these findings, the NOAEC and LOAEC were 

determined to be 610 and >610 mg ai/kg diet, respectively. This study was classified as 

acceptable. 

 Mammals (acute toxicity) 

The acute oral toxicity for mammals, as conducted with formulated benzovindiflupyr (10.2% 

w/w or 99.6g/L) in an up-down study using treatment concentrations of 17.5, 55, 175 mg/kg 

using young adult rats (MRID 48604427). Benzovindiflupyr caused mortalities at 175 mg/kg bw 

(3/3) and at 55 mg/kg bw (1/4). Clinical signs included decreased activity (3/3), prone position 

(3/3), incoordination (3/3), piloerection (3/3), dyspnoea (3/3), decreased respiratory rate (1/3), 

clonic convulsion (1/3), decreased body temperature (3/3) and mortality (3/3) at a dose level of 

175 mg/kg bw and decreased activity (4/4), dyspnoea (4/4), incoordination (4/4), hunched back 

(1/4), mortality (1/4) at 55 mg/kg. There were no adverse signs observed in the animal dosed at 

17.5 mg/kg bw. The reviewer calculated LD50 was 66.3 mg/kg will be used for estimating acute 

RQs in mammals. This study was classified as acceptable. 

 Mammals (chronic toxicity) 

 

There was an acceptable chronic two-generation reproduction study conducted with the Norway 

rat submitted in support of benzovindiflupyr using dietary levels of 0, 25, 100, 250, 600 ppm 

(MRID 48604449). Food consumption in both the P and F1 generation were statistically lower 

in the highest two dietary levels but unaffected in the lower three concentrations. Body weights 
34 

in both the generations demonstrated the same trends as food consumption. Hepatocellular 

glycogen deposits were decreased in females at 100 and 250 ppm. The NOAEC calculated by 

ToxSAC for this study is 8.2 mg/kg/day for females, since the lowest LOAEL was 19.4 

mg/kg/day in the matching females (which were consistently the most sensitive gender). The 

NOAEC of 8.2 mg/kg/day will be used for estimating the acute RQs in mammals. 

 Non-target Beneficial Insects 

One study examined acute oral and contact exposure of bees (Apis mellifera) to benzovindiflupyr 

(98.3% a.i) for 48 hours (MRID 48604527). The bees were exposed to nominal limit dose of 

100 μg a.i/bee, as well as negative and solvent controls. By 48 hours in the contact and oral 

tests, no mortality occurred in the controls or treatment group. No LD50 values could be 

determined since cumulative mortality was <50% during both the contact and oral tests. The 

LD50 was >100 μg a.i/bee for the contact test, and the LD50 based on actual intake was >109 g 

ai/bee for the oral test. As a result, Benzovindiflupyr is categorized as practically non-toxic to 

honey bees on an acute contact basis. This study was classified as acceptable. 

 Other Non-target Terrestrial Organisms 

An acute toxicity study was submitted that exposed TGAI benzovindiflupyr to the earthworm 

(Eisenia fetida, PMRA 2255438). Earthworms were exposed to nominal concentrations of 62.5, 

125, 250, 500 and 1000 mg a.i./kg soil dry weight in addition to negative control. No mortality 

(0 %) occurred in the control group. The mortalities were 0, 2.5, 12.5, 70 and 95% in the 62.5, 

125, 250, 500 and 1000 mg/kg treatments. The increase in mortality was significantly different 

than the control group in the two highest test substance concentrations: 500 and 1000 mg/kg. 

Thus, the NOEC for mortality was 250 mg/kg. The reviewer-calculated 14-day LC50 for 

mortality was 406.4 mg/kg with 95% confidence limits of 352.4 – 469.5 mg/kg. No abnormal 

behavior or toxic symptoms of the worms were observed at test concentrations up to and 

including 500 mg a.i./kg soil d.w. or in the control group during the test. At a concentration of 

1000 mg a.i./kg soil d.w., the worm body was deformed with one or more constrictions visible. 

Thus the NOEC for sub-lethal signs of toxicity was visually determined to be 500 mg/kg. In the 

control group, the mean biomass changed by -5.7% (negative value denoting an overall 

decrease). The biomass changes in the 62.5, 125, 250, 500 and 1000 mg/kg treatments were - 

5.1, - 6.4, - 11.6, -15.9, and - 27.3%. Due to the lack of effects at the 50% level, an EC50 value 

for biomass decrease could not be calculated. The extent of the biomass decrease was 

significantly different than the control group in the three highest test substance concentrations: 

250, 500 and 1000 mg/kg (Williams Multiple Sequential t-test Procedure, α = 0.05). Thus, the 

NOEC for biomass decrease was determined by the reviewer to be 250 mg a.i.//kg soil d.w. This 

study was scientifically sound but was not designed to fulfill any current OCSPP guideline 

requirement and is therefore classified as supplemental. 

In a 13-day acute toxicity study, the parasitic wasp (Aphidius rhopalosiphi) was exposed to 

benzovindiflupyr in the formulated product SYN545192 EC (150) [referred to in the study report 

by its product code: A17056F]. This end-use product has a guarantee of 150 g/L SYN545192 

(benzovindiflupyr – BZV). At 48 h in the definitive test, the mortality in the control treatment 
35 

was 0.0%, whereas mortalities of 0, 0, 2.5, 17.5 and 77.5 were observed in the 52.1, 104.1, 

208.3, 416.5, and 833 mL/ha treatment rates, respectively. The 416 and 833 mL/ha treatment 

rates differed significantly from the control (Fisher’s Exact Test, α = 0.05). The LR50 value 

calculated by the PMRA reviewer was 578 mL product/ha with 95% confidence limits of 507 

and 667 mL product/ha. The LR50 value was used in the Canadian assessment. The NOER for 

mortality was 208.3 mL/ha. This study was acceptable and satisfies Canadian guideline 

requirements for a laboratory study with the parasitic wasp (Aphidius rhopalosiphi). 

For EFED risk description this study was scientifically sound but was not designed to fulfill any 

current OCSPP guideline requirement and is therefore classified as supplemental. 

In a 14-day acute toxicity study, the predatory mite (Typhlodromus pyri) was exposed to 

benzovindiflupyr in the formulated product SYN545192 EC (150) [referred to in the study report 

by its product code: A17056F]. This end-use product has a guarantee of 150 g/L SYN545192 

(benzovindiflupyr – BZV). The corrected mortality was observed to be 16, 14, 27, 41 and 92% in 

the 420, 833.33, 1667, 3333, and 6667 mL/ha (63, 125, 250, 500 and 1000 g a.i./ha) treatments. 

Based on statistical comparison with the control, the no-observed-effects rate (NOER) for 

mortality was determined to be 833.33 mL A17056F/ha. Therefore the ER50 for mortality was 

empirically determined to be > 833.33 mL A17056F/ha. The reductions in fecundity in the 420, 

833.33, 1667 and 3333 mL/ha treatments were equivalent to 25.5, 37.6, 30.7 and 17.7% relative 

to the control. When compared statistically, no test-item treatment differed significantly from the 

control (ANOVA, α = 0.05) and the NOER was determined to be 3333 mL/ha (the highest 

concentration evaluated for reproduction, and the second highest concentration in the overall 

dose-response test). Canada determined that this study was acceptable and satisfied the Canadian 

guideline requirements for a laboratory study with the predatory mite (Typhlodromus pyri). 

For EFED risk description this study was scientifically sound but was not designed to fulfill any 

current OCSPP guideline requirement and is therefore classified as supplemental. 

In a 13-day acute toxicity study, the parasitic wasp (Aphidius rhopalosiphi) was exposed to the 

formulated product benzovindiflupyr EC (100) [referred to in the study report by its product 

code: A15457H]. This end-use product has a guarantee of 100 g/L SYN545192 

(benzovindiflupyr – BZV). Treatments and controls were applied to pots of seedling barley 

(Hordeum vulgare) with a lab track sprayer that was used to deliver spray at a volume rate 

equivalent to 400 L/ha. Once the barley plants were dry, they were enclosed within cylindrical, 

ventilated collars. In addition to mortality and reproduction, the apparent repellence of the 

product was examined by observing settling behavior of the wasps. At 48 h in the definitive test, 

the mortality in the control treatment was 0.0%, whereas in the 375, 750, 1500, 3000 and 6000 

mL/ha treatment rates, the observed mortalities were 0, 16.7, 20, 50 and 80, respectively. The 

1500, 3000 and 6000 mL/ha treatment rates differed significantly from the control (Fisher’s 

Exact Test, α = 0.05). Therefore the NOER for mortality was 750 mL/ha. The LR50 was 

calculated by the reviewer to be 2650 mL product/ha with confidence limits of 2102 – 3482 mL 

product/ha. The mean reproductive output was 41.7 mummies produced per surviving female in 

the controls, compared with values of 46.5, 36.3 and 27 in the 750, 1500 and 3000 mL 

product/ha treatment rates, respectively. This represents a -11.4 (negative value indicating an 

increase), 12.9 and 35.3% change relative to the controls. The reproductive performance of 
36 

surviving wasps was significantly affected 3000 mL product/ha treatment rate (i.e. 35.3% 

reduction). Therefore, the NOER for reproduction was 1500 mL product/ha. Due to the nature of 

the response data (lack of effects beyond 35%), it was not possible to calculate an ER50 value for 

reproduction. Canada considered this study acceptable and it satisfied Canadian guideline 

requirements for a laboratory study with the parasitic wasp (Aphidius rhopalosiphi). For EFED 

risk description this study was scientifically sound but was not designed to fulfill any current 

OCSPP guideline requirement and is therefore classified as supplemental. 

In a 14-day acute toxicity study, the predatory mite (Typhlodromus pyri) was exposed to 

benzovindiflupyr in the formulated product SYN545192 EC (100) [referred to in the study report 

by its product code: A15457H]. This end-use product has a guarantee of 100 g/L SYN545192 

(benzovindiflupyr – BZV). Treatments and controls were applied to leaf discs taken from French 

bean plants (Phaseolus vulgaris L.) using a lab track sprayer to deliver spray at a volume rate 

equivalent to 200 L/ha. After the leaf discs had dried, they were placed into test chambers with 

their treated surface facing upwards. Mite mortality was 0% in the control and was observed to 

be 0, 7, 0, 2, 2 and 15% in the 375, 750, 1500, 3000 and 6000 mL/ha (37.5, 75, 150, 300 and 600 

g a.i./ha) treatments. Based on statistical comparison with the control, the no-observed-effects 

rate (NOER) for mortality was determined to be 3000 mL A17056F/ha. A reliable ER50 for 

mortality could not be calculated due to lack of effects greater than 15%. Thus, the LR50 for 

mortality was empirically determined to be > 6000 mL A17056F/ha. The reductions in fecundity 

in the 375, 750, 1500, 3000 and 6000 mL/ha (37.5, 75, 150, 300 and 600 g a.i./ha) treatments 

were equivalent to -10.4% (negative value denoting an increase relative to controls), 11.5, 6.8, 

28.1 and 12.9% relative to the controls. When compared statistically, no test-item treatment 

differed significantly from the control (ANOVA, α = 0.05) and the NOER was determined to be 

6000 mL/ha (the highest test concentration). Canada considered this study acceptable and it 

satisfied Canadian guideline requirements for a laboratory study with the predatory mite 

(Typhlodromus pyri). For EFED risk description this study was scientifically sound but was not 

designed to fulfill any current OCSPP guideline requirement and is therefore classified as 

supplemental. 

 
37 

 Terrestrial Plants 

Toxicity reference values for terrestrial plants exposed to benzovindiflupyr is shown in Table 6. 

Table 6. Toxicity Reference Values for Terrestrial Plants Exposed to Benzovindiflupyr.

Crop Species Common name EC25 

(lbs a.i./A) 

NOAEL 

(lbs a.i./A) 

MRID 

Acceptability 

Seedling Emergence (formulated benzovindiflupyr) 

Monocots 

Corn >0.089 0.089 

48604538 

Supplemental 

Wheat >0.089 0.089 

Onion >0.089 0.089 

Ryegrass >0.089 0.089

Dicots 

Cabbage >0.089 0.089 

Lettuce >0.089 0.089 

Sugar beet >0.089 0.089 

Tomato >0.089 0.089 

Radish >0.089 0.089 

Soybean >0.089 0.089 

Vegetative Vigor (formulated benzovindiflupyr) 

Monocots 

Corn NC 0.09 

48604599 

Acceptable 

Wheat NC 0.09 

Onion NC 0.09 

Ryegrass NC 0.09 

Dicots 

Cabbage NC 0.09 

Lettuce NC 0.09 

Sugarbeet NC 0.09 

Tomato NC 0.09 

Radish NC 0.09 

Soybean NC 0.09 

NC: Not calculated 

A seedling emergence and vegetative vigor study (Table 6) were submitted with TEP 

benzovindiflupyr (purity is 148 g/L; 14.6% a.i) (MRIDs 48604538 and 48604599, respectively). 

In the seedling emergence study, seeds were exposed to mean measured concentrations ranging 

from 0.0011 to 0.089 lb a.i./A depending on the species for 21 days. The NOAEC for monocots 

and dicots was 0.089 lbs a.i/A (which is equivalent to 100 g/Ha). There was however 

uncertainty in this endpoint. Six of the 10 species (onion, ryegrass, sugarbeet, cabbage, lettuce, 

and tomato) had treatment levels that were statistically different from controls, and NOAECs 

derived from these species ranged from 0.003 to 0.029 lbs a.i./A. But in each case there was 

very poor statistical power and the responses were not treatment related. The lack of trends in 

any of the data sets and the NOAEC at the highest tested concentration make any of the EC25

values determined uncertain. The EC25 is therefore set at greater than the highest concentration 

tested which is 0.089 lbs a.i/A. As a result, this study partially fulfils the guideline requirement 

for a Tier II Seedling Emergence study and is classified as supplemental but indicates that 

solatenol is not likely to have adverse impacts on plants. 
38 

The effect of benzovindiflupyr on the vegetative vigor of monocots and dicots was studied at 

measured concentrations of <LOQ (control) and 0.090 lb ai/A. In the vegetative vigor test, 

survival, plant dry weight, and plant height were not affected by the test material. The most 

sensitive monocot and dicot species could not be determined due to a lack of toxicity in this 

study. The overall NOAEC value was 0.090 lb ai/A (equivalent to 101 g ai/ha). Chlorosis, 

necrosis, wilt, and insect damage were observed in the cabbage controls; however, the treated 

plants were unaffected. There was complete mortality in a single treated lettuce plant; however, 

no other plants were affected. Leaf curl and necrosis were observed in the treated radish plants, 

but the effects were very slight and not attributable to the test material. In conclusion, there were 

no compound-related phytotoxic effects. 

2.4 Conceptual Model and Risk Hypothesis 

Benzovindiflupyr is considered to be the primary stressor in this risk assessment. Given 

benzovindiflupyr’s persistent properties, small levels of degradates are expected under 

environmentally relevant conditions as demonstrated with environmental fate and terrestrial field 

dissipation studies (see Appendix F). Furthermore, measured comprehensive toxicity data on 

two of these degradates for freshwater fish, freshwater invertebrates, and aquatic plants indicate 

that parent benzovindiflupyr is between 3 and 4 orders of magnitude more toxic for freshwater 

fish and invertebrates and one order of magnitude for non-vascular aquatic plants than the 

degradates (see Appendix G for the endpoint values of the ecological toxicological studies for 

the degradates). Therefore, this risk assessment will only evaluate adverse impacts from parent 

benovindiflupyr considering the limited formation of transformation products and its high 

relative toxicity compared to the degradates.

The identification of relevant environmental exposure pathways to benzovindiflupyr applications 

for this risk assessment evaluating impact to non-target organisms are discussed below: 

 Dietary Exposure: Direct dietary exposure to non-target terrestrial organisms (birds and 

mammals) is possible due to the direct deposition of benzovindiflupyr sprays on to crop 

foliage, enabling the bioavailability of benzovindiflupyr. Furthermore, indirect dietary 

exposure may result from the impact of benzovindiflupyr’s resulting aquatic exposure 

(discussed further below) with fish. Piscivorous birds and mammals feeding on 

contaminated fish may potentially be exposed. Bioaccumulation of benzovindiflupyr 

residues is possible in fish given benzovindiflupyr’s Log Kow value of 4.30 and steady-state 

BCF values in fish of up to 405 L/Kg (MRID No. 48604521). 

 Aquatic Exposure: The overall persistence of benzovindiflupyr in the environment and its 

potential to be transported to water bodies and aquatic habitat mainly in a sorbed state to 

erodible soil particles embedded within runoff or its deposition into water bodies via spray 

drift indicates that aquatic exposure is another relevant pathway associated with 

benzovindiflupyr applications. Freshwater and estuarine marine fish and invertebrates as 

well as aquatic plants in the water column may be impacted. In addition, benthic 

organisms residing in the bottoms of water bodies may also be impacted given the 
39 

benzovindiflupyr’s tendency to bind to sediment to a large extent as shown in Figure 1. 

 Terrestrial plants: Terrestrial plants may be impacted from benzovindiflupyr applications 

given the potential for residues to runoff off-site from treated fields to adjacent lands 

covered with non-targeted vegetation. Furthermore, off-site deposition of benzovindiflupyr 

due to spray drift may also adversely impact non-target terrestrial plants. However, the 

NOAEC for terrestrial plants are equivalent to the highest application rate (see Table 6). 

Therefore, adverse impacts are not expected. Nonetheless, the risk analysis will be 

conducted for terrestrial plants to confirm this.

 Terrestrial invertebrates: Dietary and contact exposure to terrestrial invertebrates are 

possible pathways with benzovindiflupyr applications. Crops treated with 

benzovindiflupyr may potentially attract terrestrial invertebrates (e.g., beneficial insects) 

resulting in dietary and contact exposure.

Drinking water and inhalation exposure to terrestrial animals are not expected to be of 

concern as verified by results of the Screening Imbibition Program (SIP version 1.0, 6/15/2010) 

and the Screening Tool for Inhalation Risk (STIR version 1.0; 11/23/2010), respectively. SIP is 

available publically at: http://www.epa.gov/oppefed1/models/terrestrial/sip/sip_user_guide.html. 

STIR may be accessed on-line at: 

http://www.epa.gov/oppefed1/models/terrestrial/stir/stir_user_guide.html. 

Risk hypotheses are specific assumptions about potential adverse effects (i.e., changes in 

assessment endpoints) and may be based on theory and logic, empirical data, mathematical 

models, or probability models (EPA 1998). For benzovindiflupyr, the following ecological risk 

hypothesis is being employed for this risk assessment:

Given the proposed ground and aerial foliar spray uses of benzovindiflupyr and its 

environmental fate properties, there is a likelihood of exposure to non-target terrestrial 

and aquatic organisms. 

When used in accordance with the label, benzovindiflupyr results in potential adverse 

effects upon the survival, growth, and reproduction of non-target terrestrial and aquatic 

organisms. 

2.5 Analysis Plan 

The primary method used to assess risk in this screening-level assessment is the risk quotient 

(RQ) and follows the methods outlined in the EPA Overview Document (EPA, 2004). The RQ 

is the primary risk value for the screening-level assessment and is the result of comparing 

measures of exposure to measures of effect. A commonly used measure of exposure is the 

estimated exposure concentration (EEC) and commonly used measures of effect include toxicity 

values such as the LD50 or NOAEC. The RQ is calculated as a ratio of the estimated 

environmental concentration (EEC) to an effect level (e.g., LC50, LD50 or NOAEC) using the 
40 

effect level as a denominator. The resulting RQ is then compared to a specified level of concern 

(LOC), which represents a point of departure for concern. For example, if the RQ exceeds the 

LOC, then there is the potential for risk. In general, the higher the RQ, the more certain the 

potential risks. However, the risk quotients are not necessarily a true estimate of risk since there 

is no estimated probability of effect. Risk presumptions, along with the corresponding RQs and 

LOCs, are summarized in Appendix A. 

Generation of robust risk quotients is dependent on the quality of data from both fate and 

toxicological studies. The adequacy of the submitted data is evaluated relative to Agency 

guidelines. For benzovindiflupyr, the available environmental fate data ecological effects data is 

determined to be sufficient in evaluating the ecological risk to terrestrial and aquatic organisms 

as a result of the proposed uses. 

2.5.1 Measures of Exposure 

To estimate risks of benzovindiflupyr exposures in aquatic and terrestrial environments, all 

exposure modeling and resulting risk conclusions will be based on maximum application rates 

and methods cited in Table 1 and will be estimated for each use of benzovindiflupyr. Measures 

of exposure are based on aquatic and terrestrial models that predict estimated environmental 

concentrations (EEC) of benzovindiflupyr. Aquatic exposure in surface waters, benthic pore 

water, and sediment for proposed benzovindiflupyr applications are estimated using The Surface 

Water Concentration Calculator interface (SWCC version 1.106, dated June 6, 2014). The 

SWCC is available on-line at: http://www.epa.gov/oppefed1/models/water/#swcc. The standard 

farm pond scenario will be used to estimate the aquatic EECs. The model used to predict 

terrestrial EECs on food items is the Terrestrial Residue Exposure (T-REX) publically available 

at: http://www.epa.gov/oppefed1/models/terrestrial/trex/t_rex_user_guide.htm. The model used 

to derive EECs relevant to terrestrial and wetland plants is TerrPlant accessible publically at: 

http://www.epa.gov/oppefed1/models/terrestrial/terrplant/terrplant_user_guide.html. The model 

used to derived EECs relevant to drift is AgDrift (version 2.1.1). These models are 

parameterized using relevant reviewed environmental fate data and ecological toxicity studies 

from registrant submissions and the literature; model input values will be consistent with the 

most recent version of the input parameter guidance (citation: 

http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm). 

Since benzovindiflupyr is a new active ingredient, there are no environmental monitoring data 

available. Therefore, exposure will only be quantified using EECs calculated from the models 

described above. 

2.5.2 Measures of Effects 

Measures of ecological effects are obtained from a suite of registrant-submitted guideline studies 

conducted with a limited number of surrogate species. Measures of effect are based on 

deleterious changes in an organism as a result of chemical exposure. Functionally, measures of 

effect typically used in risk assessments include changes in survival, reproduction, or growth as 

determined from standard laboratory toxicity tests. The focus on these effects for quantitative 
41 

risk assessment is due to their clear relationship to higher-order ecological systems such as 

populations, communities, and ecosystems. Although monitoring data may also be used to 

provide supporting lines of evidence for the risk characterization, monitoring data is not 

available for this new chemical. Commonly used laboratory-derived toxicity values include 

estimates of acute mortality (such as LD50, LC50, or EC50) and estimates of effects due to longer 

term, chronic exposures (such as the NOAEC or NOAEL). In addition, effects other than 

survival, reproduction, and growth may be considered, (such as changes in biochemical, cellular, 

organ-level responses) but are typically used qualitatively to characterize risks since, in many 

cases, the relationship between these effects and higher-order processes is prone to more 

uncertainty. The latter can reflect changes seen in mortality, reproduction, or growth. In 

general, for a given assessment endpoint, the lowest relevant measure of effect is used in 

calculating the risk quotient. 
42 

3. RISK ANALYSIS AND CHARACTERIZATION 

Risk characterization is the integration of exposure and effects characterization to determine the 

ecological risk from the use of benzovindiflupyr and the likelihood of effects on aquatic life, 

wildlife, and plants based on varying pesticide-use scenarios. The risk characterization provides 

estimation and a description of the exposure and resulting risk; articulates risk assessment 

assumptions, limitations, and uncertainties; synthesizes an overall conclusion; and provides the 

risk managers with information to make regulatory decisions. 

3.1 Exposure Estimation 

3.1.1 Aquatic Exposure Estimation 

The fate parameters and use-specific input parameters for the SWCC aquatic exposure modeling 

used to estimate upper-bound EECs due to benzovindiflupyr applications are shown in Table 7 

(chemical specific input parameters) and Table 8 (crop use specific input parameters). 

Broadcast aerial applications are only evaluated in this screening level risk assessment for all 

uses except turf and nursery plants since this is considered to be the application method resulting 

in the most conservative exposure scenario as compared to ground applications and localized 

banded and in-furrow soil applications. Only ground spray applications are evaluated for turf 

and nursery since aerial applications are not proposed on the product labels. EECs are calculated 

considering scenarios possessing the most vulnerable environmental conditions for all 

benzovindiflupyr proposed uses nationwide. The EECs of benzovindiflupyr in the surface water 

column, benthic pore water, and sediment are shown for aerial and ground applications in Table 

9. A sample SWCC output file is provided in Appendix E. 

Table 7. SWCC chemical property input parameter values for benzovindiflupyr aquatic exposure 

estimation. 

SWCC Input Parameter Input Value and Unit Source 

Physical Chemical Properties 

Molecular Weight (g/mol) 398.2 MRID 48604402 

Vapor Pressure (torr) 2.40 x 10-11 MRID 48604402 

Solubility in Water (mg/L) 0.98 MRID 48604402 

Soil-Water Partition Coefficient (Koc) 

(mL/g) 

4,478 MRID 48604505 

EFED Input Parameter Guidance 

Mean value from batch equilibrium 

studies ( n = 5 soils) 

Environmental Fate Properties

Hydrolysis at pH7 (t1/2) Stable MRID 48604506 

Aerobic soil metabolism (t1/2) and Reference 

Temperature 

1,460 days @ 20°C MRID 48604492 & 48604493 

EFED Input Parameter Guidance 

Upper 90TH percentile confidence 

interval (n = 5 soils)1

 

Aerobic aquatic metabolism (t1/2) and 2,920 days @ 20°C MRID 48604509 & 48604510 
43 

Table 7. SWCC chemical property input parameter values for benzovindiflupyr aquatic exposure 

estimation. 

SWCC Input Parameter Input Value and Unit Source 

Reference Temperature 

EFED Input Parameter Guidance 

Supplemental aerobic aquatic 

metabolism study available. 

Conservative default of 2 x aerobic 

soil metabolism half-life used (2 x 

1,460 days). 

Anaerobic aquatic metabolism (t1/2) and 

Reference Temperature 

907 days @ 20°C MRID 48604494 

EFED Input Parameter Guidance 

Upper 90th percentile confidence 

interval (n = 4 soil-water sediment 

systems)1. 

Aqueous Photolysis (t1/2) and Reference 

latitude 

88.4 days @ 45°N MRID 48604507 

Foliar Extraction 0.5 Default assumption for foliar 

applications 1

 The upper 90th percentile half life calculated as follows: t1/2 input = ݐଵ/ଶ തതതതത + (t90, n-1 x σ) 

 n1/2 

where ݐଵ/ଶ തതതതത is the mean of the set of half lives from each study, t90, n-1 is the one-sided t value for the 90th percentile 

level, σ is the standard deviation of the set of half lives determined from each study, and n is the sample size of the 

set of half lives determined from each study. 
44 

Table 8. SWCC crop scenario and application methods input parameter values for benzovindiflupyr aquestimation.

Crop Use

SWCC Application Method and Crop Scenario Input Parameters 

Representative 

Vulnerable SWCC 

Scenario and 

Weather Station1

Application 

Rate 

(kg a.i./ha)2

Number of 

Applications 

and 

Retreatment 

Interval2

First 

Application 

Date3

Application 

Methods4

Ap

Ef

Corn MS Corn 

03940.dvf (Jackson, MS) 

0.076 4 apps., 7 days apart 

Apr. 10 

Foliar - 

Aerial 

Cucurbits FL Cucumbers 

12844.dvf (West Palm Beach, FL) 

Oct. 25 

Tomatoes and Fruiting Vegetables FL Tomato 

12844.dvf (West Palm Beach, FL) May 1 

Grapes NY Grape 

14860.dvf (Erie, PA) Sept. 15 

Tubers (Potatoes) ME Potato 

14607.dvf (Caribou, ME) Aug. 15 

Peanuts NC Peanuts 

13722.dvf (Raleigh, NC) 

0.1 

3 apps., 14 days apart Aug. 1 

Nursery Plants, Tomato Transplant, Fruit Transplant, Cucurbit Transplant 

NJ Nursery 93730.dvf (Atlantic City, NJ) 

3 apps., 7 days apart Aug. 5 

Foliar - 

Ground 

Turf Grass FL Turf 12834.dvf 

(Daytona Beach, FL) 

3 apps., 14 days apart 

Oct. 5 

Cotton MS Cotton 

03940.dvf (Jackson, MS) 

0.076 3 apps., 7 days apart May 15 Foliar – Aerial 
45 

Table 8. SWCC crop scenario and application methods input parameter values for benzovindiflupyr aquestimation.

Crop Use

SWCC Application Method and Crop Scenario Input Parameters 

Representative 

Vulnerable SWCC 

Scenario and 

Weather Station1

Application 

Rate 

(kg a.i./ha)2

Number of 

Applications 

and 

Retreatment 

Interval2

First 

Application 

Date3

Application 

Methods4

Ap

Ef

Blueberries NY Grape 

14860.dvf (Erie, PA) 

0.076 2 apps., 10 days apart Sept. 15 

Foliar – 

Aerial 

Soybeans & Legumes MS Soybean 

03940.dvf (Jackson, MS) 

0.076 2 apps., 7 days apart May 15 

Cereal (Oats, Barley, and Wheat) ND Wheat 

14914.dvf (Fargo, ND) 

0.076 2 apps., 14 days apart Jun. 20 

Canola ND Canola 

24013.dvf (Minot, ND) 

0.076 1 app. Aug. 15 

Pome fruit CA Fruit 

93193.dvf (Fresno, CA) 

0.052 4 apps., 7 days apart Feb. 10 

1 Selected crop scenarios possessing most vulnerable environmental conditions for all benzovindiflupyr uses. Refer to Table 1 fo

maximum application rates specified on the label for proposed uses which was partially considered to select crop scenarios. 

2 Maximum single application rate specified on product labels (Table 1). 

3 Selected based on maximum rainfall climatological date at meteorological station after crop emergence date specified in PRZM 

expected pest pressure. 

4 The most conservative application method evaluated based on crop uses specified on product labels. 5 EFED input parameter guidance for aerial and ground applications. 6 Spray drift fraction for aerial and ground applications from Table 2 of EPA, 2013, “Guidance on Modeling Offsite Deposition of 

Drift”. 
46 

Table 9. SWCC estimated upper bound concentrations in the surface water 

column, pore water, and sediment (ppb) for aerial application of benzovindiflupyr 

at the highest application rate for proposed crop uses. 

Crop Use 

(SWCC Scenario, App. 

Rate, Number of Apps., 

App. Interval) 

 

Pore Water EECs 

(μg/L) 

Sediment EECs 

(μg/Kg dry wt.) 

Surface Water Column EECs 

(μg/L) 

Peak 21-day 60-day Peak 21-day Peak 21-day 

Corn 

(MS Corn, 

0.068 lbs. a.i./A, 4 apps. 

7 days apart) 

8.13 7.11 6.76 6.42 6.41 1,149 1,147 

Cucurbits 

(FL Cucumber, 0.068 

lbs. a.i./A, 4 apps. 7 days 

apart) 

5.66 4.49 4.24 3.88 3.88 695 695 

Grapes 

(NY Grape, 0.068 lbs. 

a.i./A, 4 apps. 7 days 

apart) 

6.85 5.94 5.61 5.38 5.38 963 963 

Nursery Crops 

(NJ Nursery , 0.088 lbs. 

a.i./A, 3 apps. 7 days 

apart) 

3.83 3.24 3.01 2.85 2.85 510 510 

Peanuts 

(NC Peanuts, , 0.089 lbs. 

a.i./A, 3 apps. 7 days 

apart) 

4.52 3.93 3.69 3.43 3.43 614 614 

Tubers (Potatoes) 

(ME Potatoes, 0.068 lbs. 

a.i./A, 4 apps. 7 days 

apart) 

8.71 8.17 7.91 7.77 7.77 1,391 1,391 

Tomatoes and Fruiting 

Vegetables 

(FL Tomatoes, 0.068 lbs. 

a.i./A, 4 apps. 7 days 

apart) 

5.62 4.52 4.15 3.78 3.77 677 675 

Turf Grass 

(FL Turf, 0.088 lbs. 

a.i./A, 3 apps. 14 days 

apart) 

1.09 0.881 0.842 0.730 0.729 131 130 

Cotton 

(MS Cotton, 0.068 lbs. 

a.i./A, 3 apps. 7 days 

apart) 

5.30 4.55 4.28 3.98 3.97 712 711 

Blueberries 

(NY Grape, 0.068 lbs. 

a.i./A, 2 apps. 10 days 

apart) 3.40 3.06 2.93 2.82 2.82 505 505 
47 

Table 9. SWCC estimated upper bound concentrations in the surface water 

column, pore water, and sediment (ppb) for aerial application of benzovindiflupyr 

at the highest application rate for proposed crop uses. 

Crop Use 

(SWCC Scenario, App. 

Rate, Number of Apps., 

App. Interval) 

 

Pore Water EECs 

(μg/L) 

Sediment EECs 

(μg/Kg dry wt.) 

Surface Water Column EECs 

(μg/L) 

Peak 21-day 60-day Peak 21-day Peak 21-day 

Soybeans and Legumes 

(MS Soybeans, 0.068 

lbs. a.i./A, 2 apps. 7 days 

apart) 

2.84 2.46 2.23 2.05 2.05 367 367 

Cereal Crops 

(ND Wheat, 0.068 lbs. 

a.i./A, 2 apps. 14 days 

apart) 

2.86 2.53 2.42 2.28 2.27 408 406 

Canola 

(ND Canola, 0.068 lbs. 

a.i./A, 1 app.) 

1.36 1.12 1.00 0.928 0.928 166 166 

Pome fruit 

(CA Fruit, 0.046 lbs. 

a.i./A, 4 apps. 7 days 

apart) 

1.42 1.19 1.04 0.910 0.909 163 163 

*Bold text indicate maximum values. 

EECs are not one-in-ten year return frequency values due to accumulation in the pond. 

3.1.2 Terrestrial Exposure Estimation

In order to estimate risks of benzovindiflupyr exposures in terrestrial environments, all exposure 

modeling and resulting risk conclusions will be based on maximum application rates for a given 

use. Measures of exposure are based on aquatic and terrestrial models that predict estimated 

environmental concentrations (EECs) of benzovindiflupyr. 

 Wildlife Dietary Exposure Estimation

Exposure estimates for terrestrial animals assumed to be in the target area or in an area exposed 

to spray drift are derived from using the T-REX model (Version 1.5, released 03/2012). This 

model incorporates the Kenaga nomogram, as modified by Fletcher et al. (1994), which is based 

on a large set of actual field residue data. The upper limit values from the nomograph (Hoerger 

and Kenaga, 1972) was developed using the upper 90th percentile confidence bound of foliar 

dissipation half-life values from actual field measurements. The Fletcher et al. (1994) 

modifications to the Kenaga nomograph are based on field measured field residues from 249 

published papers, including information on 118 species of plants, 121 pesticides, and 17 

chemical classes. The environmental (foliar dissipation) half-life of 10.9 days was derived 90th

percentile value from the foliar dissipation half-lives of submitted studies and was used to 

estimate EECs in lieu of the T-REX default half-life of 35 days7

. Table 10 and Table 11 show 

 

7

 Please refer to data presented for terrestrial field dissipation studies in Table 3 (MRID Nos. 48604498, 48604502, 

48604580, 48604581). 
48 

the estimated environmental dose-based concentrations (EECs) for the three weight classes of 

birds and mammals, respectively. Table 12 shows the estimated dietary-based concentrations 

(EECs) for both birds and mammals. These EECs were combined with the most sensitive 

endpoints to generate risk quotients described in the risk characterization section. The T-REX 

sample input file is provided in Appendix B.

Table 10. Terrestrial food item residue estimates for birds with proposed crop uses of benzovindiflupyr (environmental 

dose mg/kg-bw). 

 20 g "Small" Bird 100 gram "Medium" Bird 1000 gram "Large" Bird 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Corn, cucurbits, 

fruit and tomatos, 

grapes, tubers 

43.0 19.7 24.2 2.7 16.8 0.6 24.5 11.2 13.8 1.5 9.6 0.3 11.0 5.0 6.2 0.7 4.3 0.2 

Peanuts 38.4 17.6 21.6 2.4 15.0 0.5 21.9 10.0 12.3 1.4 8.6 0.3 9.8 4.5 5.5 0.6 3.8 0.1 

Nursery Plants, 

Tomato Transplant, 

Fruit Transplant, 

Curcubit Transplant 

49.3 22.6 27.8 3.1 19.3 0.7 28.1 12.9 15.8 1.8 11.0 0.4 12.6 5.8 7.1 0.8 4.9 0.2 

Turf grasses 38.0 17.4 21.4 2.4 14.9 0.5 21.7 9.9 12.2 1.4 8.5 0.3 9.7 4.4 5.5 0.6 3.8 0.1 

Cotton 38.1 17.5 21.4 2.4 14.9 0.5 21.7 10.0 12.2 1.4 8.5 0.3 9.7 4.5 5.5 0.6 3.8 0.1 

Blueberries 28.4 13.0 16.0 1.8 11.1 0.4 16.2 7.4 9.1 1.0 6.3 0.2 7.3 3.3 4.1 0.5 2.8 0.1 

Soybeans, Legumes 30.5 14.0 17.2 1.9 11.9 0.4 17.4 8.0 9.8 1.1 6.8 0.2 7.8 3.6 4.4 0.5 3.0 0.1 

Cereal (Oats, 

Barley, and Wheat) 26.2 12.0 14.7 1.6 10.3 0.4 15.0 6.9 8.4 0.9 5.9 0.2 6.7 3.1 3.8 0.4 2.6 0.1 

Canola 18.6 8.5 10.5 1.2 7.3 0.3 10.6 4.9 6.0 0.7 4.2 0.1 4.7 2.2 2.7 0.3 1.9 0.1 

Pome fruit 29.1 13.3 16.4 1.8 11.4 0.4 16.6 7.6 9.3 1.0 6.5 0.2 7.4 3.4 4.2 0.5 2.9 0.1 

 
49 

Table 11. Terrestrial food item residue estimates for mammals with proposed crop uses of benzovindiflupyr (environmental dose mg/kg-bw). 

 

15 gram "Small" Mammal 35 gram "Medium" Mammal 1000 gram "Large" Mammal 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Corn, cucurbits, fruit and 

tomatos, grapes, tubers 36.0 16.5 20.3 2.3 14.1 0.5 24.9 11.4 14.0 1.6 9.7 0.3 5.8 2.6 3.2 0.4 2.3 0.1 

Peanuts 32.2 14.7 18.1 2.0 12.6 0.4 22.2 10.2 12.5 1.4 8.7 0.3 5.2 2.4 2.9 0.3 2.0 0.1 

Nursery Plants, Tomato 

Transplant, Fruit Transplant, 

Curcubit Transplant 

41.3 18.9 23.2 2.6 16.2 0.6 28.5 13.1 16.1 1.8 11.2 0.4 6.6 3.0 3.7 0.4 2.6 0.1 

Turf grasses 31.8 14.6 17.9 2.0 12.5 0.4 22.0 10.1 12.4 1.4 8.6 0.3 5.1 2.3 2.9 0.3 2.0 0.1 

Cotton 31.9 14.6 18.0 2.0 12.5 0.4 22.1 10.1 12.4 1.4 8.6 0.3 5.1 2.3 2.9 0.3 2.0 0.1 

Blueberries 23.8 10.9 13.4 1.5 9.3 0.3 16.4 7.5 9.3 1.0 6.4 0.2 3.8 1.7 2.1 0.2 1.5 0.1 

Soybeans, Legumes 25.5 11.7 14.4 1.6 10.0 0.4 17.6 8.1 9.9 1.1 6.9 0.2 4.1 1.9 2.3 0.3 1.6 0.1 

Cereal (Oats, Barley, and 

Wheat) 21.9 10.1 12.3 1.4 8.6 0.3 15.2 7.0 8.5 0.9 5.9 0.2 3.5 1.6 2.0 0.2 1.4 0.0 

Canola 15.6 7.1 8.8 1.0 6.1 0.2 10.8 4.9 6.0 0.7 4.2 0.1 2.5 1.1 1.4 0.2 1.0 0.0 

Pome fruit 24.4 11.2 13.7 1.5 9.5 0.3 16.8 7.7 9.5 1.1 6.6 0.2 3.9 1.8 2.2 0.2 1.5 0.1 

Table 12. Terrestrial food item residue estimates for birds and mammals 

with proposed crop uses of benzovindiflupyr (dietary concentration ppm). 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Corn, cucurbits, fruit and tomatos, grapes, tubers 37.8 17.3 21.2 2.4 14.8

Peanuts 33.7 15.5 19.0 2.1 13.2

Nursery Plants, Tomato Transplant, Fruit Transplant, 

Curcubit Transplant 43.3 19.9 24.4 2.7 17.0

Turf grasses 33.4 15.3 18.8 2.1 13.1

Cotton 33.5 15.3 18.8 2.1 13.1

Blueberries 25.0 11.4 14.0 1.6 9.8
50 

Table 12. Terrestrial food item residue estimates for birds and mammals 

with proposed crop uses of benzovindiflupyr (dietary concentration ppm). 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Soybeans, Legumes 26.8 12.3 15.1 1.7 10.5

Cereal (Oats, Barley, and Wheat) 23.0 10.6 12.9 1.4 9.0

Canola 16.3 7.5 9.2 1.0 6.4 

Pome fruit 25.6 11.7 14.4 1.6 10.0

 Terrestrial Plant Exposure Estimation

The model used to predict terrestrial and wetland plants is TerrPlant (version 1.2.2, released 

12/2006). EECs for terrestrial plants inhabiting dry and wetland areas are derived using this 

model which utilizes the solubility of pesticide in runoff and in spray drift. Additionally, 

TerrPlant derived EECs factor in application rate and minimum incorporation depth. Table 13

summarizes the EECs resulting from the proposed uses of benzovindiflupyr. The sample 

TerrPlant model output file is presented in Appendix D.

Table 13. TerrPlant derived EECs for dry and semi-aquatic areas resulting from 

proposed benzovindiflupyr crop uses.

Crop Uses Description of Area EEC 

(lbs a.i/A) 

Pome fruit 

Runoff to Dry areas 0.00046 

Runoff to semiaquatic areas 0.0046 

Spray drift 0.00046 

Total for dry areas 0.00092 

Total for semiaquatic areas 0.00506 

Corn 

Cucurbits 

Tomatoes and Fruiting Vegetables 

Grapes 

Tubers (Potatoes) 

Cotton 

Blueberries 

Soybeans and Legumes 

Cereal Crops (Oats, Barley, and Wheat) 

Canola 

Runoff to Dry areas 0.00068 

Runoff to semiaquatic areas 0.0068 

Spray drift 0.00068 

Total for dry areas 0.00136 

Total for semiaquatic areas 0.00748 
51 

Table 13. TerrPlant derived EECs for dry and semi-aquatic areas resulting from 

proposed benzovindiflupyr crop uses.

Crop Uses Description of Area EEC 

(lbs a.i/A) 

Peanuts 

Nursery Plants 

Tomato Transplant, Fruit Transplant, and Cucurbit Transplant 

Turf Grass 

Runoff to Dry areas 0.00089 

Runoff to semiaquatic areas 0.0089 

Spray drift 0.00089 

Total for dry areas 0.00178 

Total for semiaquatic areas 0.00979 

 Terrestrial Organism Exposure to Residues in Aquatic Food Items 

The KABAM model (KOW based Aquatic BioAccumulation Model) version 1.0 was used to 

evaluate the potential exposure and risk of direct effects to birds and mammals via 

bioaccumulation and biomagnification in aquatic food webs. KABAM is used to estimate 

potential bioaccumulation of hydrophobic organic pesticides in freshwater aquatic ecosystems and 

risks to mammals and birds consuming aquatic organisms which have bioaccumulated these 

pesticides. The bioaccumulation portion of KABAM is based upon work by Arnot and Gobas 

(2004) who parameterized a bioaccumulation model based on PCBs and some pesticides (e.g., 

lindane, DDT) in freshwater aquatic ecosystems (Arnot and Gobas, 2004). KABAM relies on a 

chemical's octanol-water partition coefficient (KOW) to estimate uptake and elimination constants 

through respiration and diet of organisms in different trophic levels. Pesticide tissue residues are 

calculated for different levels of an aquatic food web. The model then uses pesticide tissue 

concentrations in aquatic animals to estimate dose- and dietary-based exposures and associated 

risks to mammals and birds (surrogate for amphibians and reptiles) consuming aquatic organisms. 

Seven different trophic levels including phytoplankton, zooplankton, benthic invertebrates, filter 

feeders, small-sized (juvenile) forage fish, medium-sized forage fish, and larger piscivorous fish, 

are used to represent an aquatic food web. Input parameters from the modeled scenarios are 

presented in Table 14. Example output from the bioaccumulation model is provided in Appendix 

C. 

 
52 

Table 14. Benzovindiflupyr input parameter values for 

KABAM. 

Parameter Input Value Source 

Pesticide Name Benzovindiflupyr 

Log KOW 4.3 MRID 48604402 

KOC 4,478 L/kgOC MRIDs 48604505 

Use patterns 

Acute 

Concentration in 

sediment pore 

water (ppb) 

Acute 

Concentration in 

water column 

(ppb) 

Corn 6.41 7.11 

Cucuribits 3.88 4.49 

Grapes 5.38 5.94 

Nursery Crops 2.85 3.24 

Peanuts 3.43 3.93 

Tubers 7.77 8.17 

Tomatos 3.78 4.52 

Cotton 3.97 4.55 

Blueberries 3.98 3.06 

Soybeans and legumes 2.05 2.46 

Cereal Crops 2.27 2.53 

Canola 0.928 1.12 

Pome fruits 0.909 1.19 

Turf grass 0.729 0.881 

Based on KABAM results, estimated concentrations of benzovindiflupyr residues in the tissue of 

organisms in the different trophic levels following application on the proposed uses of 

benzovindiflupyr range from 817 to 9,055 μg/kg (Table 15). 

Table 15. Predicted Acute Concentrations of Benzovindiflupyr in Aquatic Organism Tissues at Different 

Trophic Levels (g/kg). 

Crop Uses Phytoplankton Zooplankton Benthic 

Invertebrates 

Filter 

Feeders 

Small 

Fish 

Medium 

Fish 

Large 

Fish 

Corn 6603 4884 5348 3517 7079 7347 7877

Cucuribits 4170 3085 3371 2217 4462 4631 4973

Grapes 5517 4081 4469 2939 5915 6139 6581

Nursery Crops 3650 2700 2952 1941 3907 4055 4353

Peanuts 4170 3085 3429 2255 4535 4709 4986 
53 

Table 15. Predicted Acute Concentrations of Benzovindiflupyr in Aquatic Organism Tissues at Different 

Trophic Levels (g/kg). 

Crop Uses Phytoplankton Zooplankton Benthic 

Invertebrates 

Filter 

Feeders 

Small 

Fish 

Medium 

Fish 

Large 

Fish 

Tubers 7588 5613 6161 4052 8154 8463 9055 

Tomatos 4198 3105 3388 2228 4485 4655 5005

Cotton 5517 4081 4469 2939 5915 6139 6581 

Blueberries 2842 2102 2304 1515 3050 3165 3391 

Soybeans and 

legumes 2842 2102 2304 1515 3050 3165 3391 

Cereal Crops 2350 1738 1903 1251 2518 2614 2803 

Canola 1040 769 839 552 1111 1153 1240 

Pome fruits 1105 818 889 585 1177 1221 1317 

Turf grass 817 605 660 434 873 906 974 

3.2 Risk Estimation – Integration of Exposure and Effects Data 

 

Risks of adverse effects on non-target species are assessed using RQs based on exposure and 

toxicity data for mortality, growth and reproduction. For the assessment of benzovindiflupyr 

risks, the risk quotient method is used to compare exposure and measured toxicity values (refer 

to Appendix A). Estimated environmental concentrations are divided by the most sensitive 

acute and chronic toxicity values. The RQs are then compared to the Agency’s levels of 

concern. These LOCs, summarized in Appendix A, are the Agency’s interpretive policy and are 

used to analyze potential risk to non-target organisms and the need to consider regulatory action. 

These criteria are used to indicate when a pesticide’s use as directed on the label has the potential 

to cause adverse effects on non-target organisms. 

3.2.1 Non-target Aquatic Animals and Plants 

To assess risk of benzovindiflupyr to non-target aquatic animals and plants, surface water, pore 

water and sediment EECs for benzovindiflupyr were obtained from the SWCC based on its 

proposed uses (Table 9). EECs were compared to the most sensitive toxicological endpoints for 

aquatic organisms as shown in Table 4. 

 Fish (Acute and Chronic) 

Maximum acute and chronic RQs for freshwater and estuarine/marine fish are determined from 

the peak and 60-d average EECs, respectively (Table 9) and the most sensitive toxicity reference 

values (Table 4). Table 16 summarizes the acute and chronic RQs for freshwater and 

estuarine/marine fish in the water column. 
54 

Benzovindiflupyr was classified as very highly toxic to all three species of freshwater fish tested 

on an acute basis. The most acutely sensitive species, Cyprinus carpio, had an LC50 of 3.5 ug 

a.i. /L (MRID 48604562). The acute RQs for freshwater fish derived from this endpoint and the 

peak EECs presented in Table 16, ranged from 0.3 for turf to 2.4 for potatoes. RQs exceeded the 

LOC for acute listed (LOC = 0.05) for every use. The RQ exceeded the acute LOC for nonlisted 

species (LOC = 0.5) in eleven out of the fourteen proposed uses, with the canola, pome fruit, and 

turf uses below the acute level of concern for non-listed species. This suggests that there is acute 

risk concern for freshwater fish over a broad range of uses. The chronic NOAEC for freshwater 

fish was calculated through the ACR with the fathead minnow data was 0.73 ug a.i./L. This 

value increased the calculated RQs 33 percent over the endpoint from fathead minnow (0.95 ug 

a.i./L). Utilizing the 60 day EECs presented in Table 9, chronic RQs for freshwater fish ranged 

from 1.2 to 9.3 (Table 16). RQs exceeded the chronic LOC (1.0) in all the proposed uses 

indicating there is chronic risk concern to freshwater fish from a broad range of uses. 

Benzovindiflupyr was also classified as very highly toxic to estuarine/marine fish on an acute 

basis (LC50 = 28 ug a.i./L, MRID 48604534). The acute RQs derived from this endpoint and the 

peak EECs presented in Table 9 ranged from less than 0.01 for turf to 0.3 for potatoes. RQs in 

thirteen of the fourteen proposed uses exceeded the LOCs for acute listed species, with the turf 

use below the acute LOC, indicating a risk concern for listed species over a broad range of uses. 

No proposed use exceeded the acute LOC for non-listed species. The NOAEC for estuarine / 

marine fish (sheepshead minnow) was calculated with the acute to chronic ratio from the acute 

and chronic toxicity endpoints from the freshwater fathead minnow. The NOAEC for 

sheepshead minnow was calculated to be 5.66 ug a.i./L. EFED recommends that when there is a 

data gap such as there was for the chronic toxicity study for estuarine/marine fish, the ACR be 

calculated using the most sensitive species from the parallel studies (in this case the freshwater 

acute and chronic fish studies) and using the same species. Since there was not any chronic 

studies conducted with carp, the fathead minnow was selected since the toxicity endpoints were 

within 2 ug ai /L and an acceptable chronic study was submitted for fathead minnow. The 

calculation of ACR provides an unbounded estimate of toxicity has uncertainties inherent with it. 

The RQs derived with this value and the 60 day EECs presented in Table 9 ranged from 0.5 and 

1.4. The chronic LOC of 1.0 was exceeded for only three proposed uses including potatoes, 

corn, and grapes (Table 16). 

 
55 

Table 16. RQs for freshwater and estuarine/marine fish for the proposed uses of 

benzovindiflupyr.1,2

Freshwater Fish Estuarine / Marine Fish 

Crop Use 

(SWCC Scenario, App. Rate, Number of 

Apps., App. Interval)

Acute RQ Chronic RQ Acute RQ Chronic RQ 

Corn 

(MS Corn, 

0.068 lbs. a.i./A, 4 apps. 7 days apart)        

2.3 9.3 0.29 1.2 

Cucurbits 

(FL Cucumber, 0.068 lbs. a.i./A, 4 apps. 

7 days apart) 

1.6 5.8 0.20 0.7 

Grapes 

(NY Grape, 0.068 lbs. a.i./A, 4 apps. 7 

days apart) 

1.9 7.7 0.24 1.0 

Nursery Crops 

(NJ Nursery , 0.088 lbs. a.i./A, 3 apps. 7 

days apart) 

1.3 4.1 0.16 0.7 

Peanuts 

(NC Peanuts, , 0.089 lbs. a.i./A, 3 apps. 7 

days apart) 

1.3 5.1 0.16 0.6 

Tubers (Potatoes) 

(ME Potatoes, 0.068 lbs. a.i./A, 4 apps. 7 

days apart) 

2.4 10.8 0.30 1.4 

Tomatoes and Fruiting Vegetables 

(FL Tomatoes, 0.068 lbs. a.i./A, 4 apps. 7 

days apart) 

1.6 5.6 0.20 0.7 

Turf Grass 

(FL Turf, 0.088 lbs. a.i./A, 3 apps. 14 

days apart) 

0.30 1.2 <0.01 0.1 

Cotton 

(MS Cotton, 0.068 lbs. a.i./A, 3 apps. 7 

days apart) 

1.47 5.9 0.19 0.8 

Blueberries 

(NY Grape, 0.068 lbs. a.i./A, 2 apps. 10 

days apart) 

0.94 4.01 0.12 0.5 

Soybeans and Legumes 

(MS Soybeans, 0.068 lbs. a.i./A, 2 apps. 7 

days apart) 

 

0.79 3.1 0.10 0.4 

Cereal Crops 

(ND Wheat, 0.068 lbs. a.i./A, 2 apps. 14 

days apart) 

0.79 3.3 0.10 0.4 

Canola 

(ND Canola, 0.068 lbs. a.i./A, 1 app.) 0.38 1.4 0.05 0.2 

Pome fruit 

(CA Fruit, 0.046 lbs. a.i./A, 4 apps. 7 

days apart) 

0.39 1.4 0.05 0.2 

*Acute Listed Species LOC = 0.05; Non-listed species LOC 0.5; Chronic LOC = 1.0. 

**Bolded values indicate LOC exceedence. 

1 Please refer to Table 9 for the acute (peak) and chronic (60-day average) SWCC water column EECs for 
56 

each crop use utilized in RQs. 

2 Most sensitive endpoints for benzovindiflupyr utilized in RQs: 

 Acute Freshwater Fish: Carp LC50 = 3.6 g a.i./L (MRID No. 48604562) 

 Chronic Freshwater Fish: Carp ACR NOAEC = 0.73 g a.i./L based on Fathead minnow data. 

Utilizing the Carp ACR rather than the fathead minnow chronic data of 0.95 g a.i./L (MRID No. 

48604520) increased the freshwater chronic RQs by 33 percent. 

 Acute Estuarine/Marine Fish: Sheepshead Minnow EC50 = 28 g a.i./L (MRID No. 48604534) 

 Chronic Estuarine/Marine Fish: Sheepshead Minnow NOAEC = 5.66 g a.i./L (Acute to Chronic 

 Ratio using values from Fathead minnow)

 

 Aquatic Invertebrates - Water Column (Acute and Chronic) 

Benzovindiflupyr was classified as very highly toxic to both freshwater invertebrates (EC50 = 85 

ug a.i./L; MRID 48604522) and estuarine/marine invertebrates (EC50 = 47 ug a.i./L; MRID 

48604535). Acute RQs for freshwater invertebrates ranged from less than 0.01 to 0.1 with eight 

out of fourteen proposed uses (corn, cucurbits, grapes, nursery crops, peanuts, potatoes, 

tomatoes, and cotton) exceeding the LOC for acute listed species (LOC = 0.05), and no proposed 

uses exceeding for acute non-listed species (LOC = 0.5). Acute RQs for estuarine/marine 

invertebrates ranged from 0.02 to 0.18 with all but three proposed uses (turf, canola, and pome 

fruit) exceeding the LOC for acute listed species and no exceedances for non-listed species. 

Both freshwater and estuarine invertebrates demonstrated sensitivity to benzovindiflupyr on a 

chronic basis with NOAECs of 5.6 ug a.i./L (MRID 48604523) and 7.4 ug a.i./L (MRID 

48604536), respectively. Using the NOAEC of 5.6 ug a.i/L, the chronic RQs for freshwater 

invertebrates are predicted to range from at least 0.2 to 1.5 (Table 17). Three proposed uses for 

freshwater invertebrates exceeded the chronic LOCs. The chronic RQs for estuarine/marine 

invertebrates ranged from 0.1 to 1.1 with only one proposed use (potatoes) exceeding the chronic 

LOC. From this data, there is risk concern from chronic exposure for both freshwater and 

estuarine/marine invertebrates but the risk is less prevalent than those observed for fish. 

Table 17. RQs for freshwater and estuarine/marine aquatic invertebrates in the water 

column for the proposed uses of benzovindiflupyr.1,2

Freshwater Invertebrates Estuarine / Marine Invertebrates 

Crop Use 

(SWCC Scenario, App. Rate, 

Number of Apps., App. Interval)

Acute RQ Chronic RQ Acute RQ Chronic RQ 

Corn 

(MS Corn, 

0.068 lbs. a.i./A, 4 apps. 7 days 

apart)         

0.10 1.3 0.17 0.9 

Cucurbits 

(FL Cucumber, 0.068 lbs. a.i./A, 4 

apps. 7 days apart) 

0.07 0.8 0.12 0.6 

Grapes 

(NY Grape, 0.068 lbs. a.i./A, 4 

apps. 7 days apart) 

 

0.08 1.1 0.15 0.8 
57 

Table 17. RQs for freshwater and estuarine/marine aquatic invertebrates in the water 

column for the proposed uses of benzovindiflupyr.1,2

Freshwater Invertebrates Estuarine / Marine Invertebrates 

Crop Use 

(SWCC Scenario, App. Rate, 

Number of Apps., App. Interval)

Acute RQ Chronic RQ Acute RQ Chronic RQ 

Nursery Crops 

(NJ Nursery , 0.088 lbs. a.i./A, 3 

apps. 7 days apart) 

0.05 0.6 0.10 0.5 

Peanuts 

(NC Peanuts, , 0.089 lbs. a.i./A, 3 

apps. 7 days apart) 

0.05 0.7 0.09 0.5 

Tubers (Potatoes) 

(ME Potatoes, 0.068 lbs. a.i./A, 4 

apps. 7 days apart) 

0.10 1.5 0.18 1.1 

Tomatoes and Fruiting 

Vegetables 

(FL Tomatoes, 0.068 lbs. a.i./A, 4 

apps. 7 days apart) 

0.06 0.8 0.12 0.6 

Turf Grass 

(FL Turf, 0.088 lbs. a.i./A, 3 apps. 

14 days apart) 

<0.01 0.2 0.02 0.1 

Cotton 

(MS Cotton, 0.068 lbs. a.i./A, 3 

apps. 7 days apart) 

0.06 0.8 0.11 0.6 

Blueberries 

(NY Grape, 0.068 lbs. a.i./A, 2 

apps. 10 days apart) 

0.04 0.5 0.07 0.4 

Soybeans and Legumes 

(MS Soybeans, 0.068 lbs. a.i./A, 2 

apps. 7 days apart) 

0.03 0.4 0.06 0.3 

Cereal Crops 

(ND Wheat, 0.068 lbs. a.i./A, 2 

apps. 14 days apart) 

0.03 0.5 0.06 0.3 

Canola 

(ND Canola, 0.068 lbs. a.i./A, 1 

app.) 

 

0.02 0.2 0.03 0.1 

Pome fruit 

(CA Fruit, 0.046 lbs. a.i./A, 4 apps. 

7 days apart) 

0.02 0.2 0.03 0.1 

*Acute Listed Species LOC = 0.05; Non-listed species LOC 0.5; Chronic LOC = 1.0. 

**Bolded values indicate LOC exceedence. 1

Please refer to Table 9 for the acute (peak) and chronic (60-day average) SWCC water column EECs for each crop 

use utilized in RQs. 2

Most sensitive endpoints for benzovindiflupyr utilized in RQs: 
58 

 Acute Freshwater Invertebrates: Water Flea LC50 = 85 g a.i./L (MRID No. 48604522) 

 Chronic Freshwater Fish: Water Flea NOAEC 5.6 g a.i./L (MRID No. 48604523) 

 Acute Estuarine/Marine Fish: Eastern Oyster EC50 = 47 g a.i./L (MRID No. 48604535) 

 Chronic Estuarine/Marine Fish: Saltwater Mysid NOAEC = 7.4 g a.i./L (MRID No. 48604536) 

 Benthic Invertebrates (Acute and Chronic) 

Comparisons of EECs and sediment toxicity endpoints are provided below to supplement risk 

estimation to water column organisms. The evaluation of toxic risk to the benthic organisms was 

approached by assuming equilibrium partitioning benzovindiflupyr between the sediment and the 

pore water (the water found between particulates in the sediment). Risk to benthic organisms 

was assessed using three approaches, two for chronic risk and one for acute risk. Approach 1 

(chronic risk with sediment exposure): 21-day ECs for sediment were model-generated (SWCC) 

and compared to the toxicity value as reported for sediment exposure (NOAEC) in the sediment 

toxicity tests (normalized to organic carbon). Approach 2 (chronic risk from porewater 

exposure): 21-day EECs for pore water were model-generated (SWCC) and compared to the 

toxicity value as reported for pore water (NOAEC) in the sediment toxicity tests. Approach 2 

(acute risk from porewater exposure): Peak EECs for pore water were model-generated (SWCC) 

and compared to the acute toxicity value as reported water column invertebrates. 

There was one 56-day chronic sediment toxicity test for freshwater invertebrates (Sediment 

NOAEC = 2.8 mg a.i./kg; MRID 48604525) and one 28-day chronic sediment toxicity test for 

estuarine/marine invertebrates (Sediment NOAEC 4.1 mg a.i./kg; MRID 48604583). The RQs 

were derived from the 21-day sediment EECs and porewater EECs (Table 9) and the respective 

sediment and pore water endpoints in Table 4). The RQs derived from both pore water and 

sediment values did not exceed the chronic LOC of 1.0 for any of the proposed uses (Table 18). 

There were however LOC exceedances when comparing peak porewater concentrations with the 

acute toxicity endpoints of both freshwater and estuarine/marine invertebrates indicating 

potential risk. The acute RQs of freshwater sediment invertebrates exceeded the acute listed 

species LOC in five of the fourteen proposed uses while the acute RQs for estuarine/marine 

invertebrates exceeded the acute listed species LOC in nine of the fourteen proposed uses. The 

only uses that exceeded the restricted use LOC were corn, grapes, and tubers. The RQs indicate 

that there is acute risk concern for both freshwater and estuarine/marine benthic invertebrates 

from a broad range of uses but no chronic risk exceeding levels of concern in both freshwater 

and estuarine marine environments. 

 
59 

Table 18. Chronic RQs for benthic invertebrates for the proposed uses of 

benzovindiflupyr.1,2

Crop Use

Chronic Pore Water Chronic Sediment Acute Porewater 

Freshwater Estuarine/ 

Marine Freshwater Estuarine/ Marine Freshwater Estuarine/ Marine (SWCC Scenario, App. Rate, 

Number of Apps., App. 

Interval) 

Corn 

0.09 0.07 0.41 0.28 0.08 0.14 (MS Corn, 

0.068 lbs. a.i./A, 4 apps. 7 

days apart)        

Cucurbits 

(FL Cucumber, 0.068 lbs. 0.06 0.04 0.25 0.17 0.05 0.08

a.i./A, 4 apps. 7 days apart) 

Grapes 

(NY Grape, 0.068 lbs. a.i./A, 4 0.08 0.05 0.34 0.24 0.06 0.11

apps. 7 days apart) 

Nursery Crops 

(NJ Nursery , 0.088 lbs. a.i./A, 0.04 0.03 0.18 0.12 0.03 0.06

3 apps. 7 days apart) 

Peanuts 

(NC Peanuts, , 0.089 lbs. 0.05 0.04 0.22 0.15 0.04 0.07

a.i./A, 3 apps. 7 days apart) 

Tubers (Potatoes) 

0.11 0.08 0.50 0.34 0.09 0.17

(ME Potatoes, 0.068 lbs. 

a.i./A, 4 apps. 7 days apart) 

Tomatoes and Fruiting 

Vegetables 0.05 0.04 0.24 0.17 0.04 0.08

(FL Tomatoes, 0.068 lbs. 

a.i./A, 4 apps. 7 days apart) 

Turf Grass 

(FL Turf, 0.088 lbs. a.i./A, 3 0.01 0.01 0.05 0.03 0.01 0.02

apps. 14 days apart) 

Cotton 

(MS Cotton, 0.068 lbs. a.i./A, 0.06 0.06 0.25 0.17 0.05 0.08

3 apps. 7 days apart) 

Blueberries 

0.04 0.04 0.18 0.12 0.03 0.06

(NY Grape, 0.068 lbs. a.i./A, 2 

apps. 10 days apart) 

 
60 

Table 18. Chronic RQs for benthic invertebrates for the proposed uses of 

benzovindiflupyr.1,2

Crop Use

Chronic Pore Water Chronic Sediment Acute Porewater 

Freshwater Estuarine/ 

Marine Freshwater Estuarine/ Marine Freshwater Estuarine/ Marine (SWCC Scenario, App. Rate, 

Number of Apps., App. 

Interval) 

Soybeans and Legumes 

0.03 0.03 0.13 0.09 0.02 0.04

(MS Soybeans, 0.068 lbs. 

a.i./A, 2 apps. 7 days apart) 

Cereal Crops 

(ND Wheat, 0.068 lbs. a.i./A, 0.03 0.03 0.15 0.10 0.03 0.05

2 apps. 14 days apart) 

Canola 

(ND Canola, 0.068 lbs. a.i./A, 

1 app.)

0.01 0.01 0.06 0.04 0.01 0.02

Pome fruit

(CA Fruit, 0.046 lbs. a.i./A, 4 

apps. 7 days apart) 

0.01 0.01 <0.01 <0.01 0.01 0.02

Chronic LOC = 1.0; Acute risk listed species = 0.05;Acute non-listed species LOC = 0.5. 

Bolded values indicate LOC exceedence

**Bolded values indicate LOC exceedence. 1

Please refer to Table 9 for acute (peak) and chronic (21-day average) SWCC pore water and sediment EECs for 

each crop use utilized in RQs. 2

Most sensitive endpoints for benzovindiflupyr utilized in RQs: 

Chronic Freshwater Invertebrates (Pore Water): 

 Freshwater Midge NOAEC = 69 g a.i./L (MRID No. 48604525) 

Chronic Estuarine/Marine Invertebrates (Pore Water): 

 Estuarine Amphipod NOAEC = 98 g a.i./L (MRID No. 48604583) 

Chronic Freshwater Invertebrates (Sediment): 

 Freshwater Midge NOAEC = 2.8 mg/kg dry wt. (MRID No. 48604525) 

Chronic Estuarine/Marine Invertebrates (Sediment): 

 Freshwater Midge NOAEC = 4.1 mg/kg dry wt. (MRID No. 48604583) 

 Aquatic Plants 

RQs were estimated for non-listed and listed vascular (EC50 >880, NOAEC = 430 ug a.i./L; MRID 

48604526) and non-vascular (algae) plants (EC50 = 240 ug a.i./L, NOAEC = 50 ug a.i./L utilizing 

the EECs presented in Table 9. The EC50 values were used to determine the RQs for non-listed 

species while the NOAECs were used to determine the RQs for listed species. There were no RQs 

that exceeded the non-listed and listed LOC of 1.0 in any scenario for either nonvascular plants or 

vascular plants. RQs for nonvascular plants ranged from <0.01 to 0.04 for non-listed species and 

from 0.02 to 0.17 for listed species. RQs for vascular plants ranged from <0.01 to 0.02 for listed 

species and from less than 0.01 to 0.01 for non-listed species. Based on these RQs, there is risk 

below the level of concern determined for vascular and non-vascular aquatic plants for all proposed 

benzovindiflupyr uses. 
61 

3.2.2 Non-target Terrestrial Animals and Plants 

 Acute and Chronic Risk to Birds 

T-REX provides acute dose based RQs for three size classes of birds as well as acute and chronic 

dietary based RQs resulting from ingestion of six different food items exposed to 

benzovindiflupyr. Table 19 below summarizes the acute dose-based RQs to birds for proposed 

uses of benzovindiflupyr. The acute endangered species LOC (0.1) was exceeded for small birds 

eating short grass, tall grass, broadleaf plants, fruits/pods and arthropods for all proposed uses. 

The acute endangered species LOC (0.1) was also exceeded in one of the 10 use groups when 

eating seeds. The acute endangered species LOC (0.1) was exceeded for medium birds eating 

short grass, tall grass, broadleaf plants for all proposed uses as well as when eating arthropods 

for all uses except turf grass. For medium sized birds, there were not any exceedances when 

eating seeds. For large sized birds feeding on short grass, tall grass, and broadleaf plants, the 

RQs exceeded the acute listed species LOC for all uses (Table 19). There were not any listed or 

non-listed LOC exceedances for large birds eating fruits/pods, arthropods, or seeds (Table 19). 

LOC exceedances in every size class of bird for both listed (LOC = 0.1) and non-listed (LOC0.5) species suggest that there is acute concern for birds from a broad range of uses and 

application rates. 

Table 20 presents the chronic dietary based RQs for birds resulting from ingestion of five 

different food items exposed to benzovindiflupyr. The acute dietary based RQs were all less 

than or equal to 0.01 and are not presented here as they were not higher than any LOCs. The 

chronic dietary based RQs also did not exceed the chronic LOC of 1.0 and ranged from 0.28 o 

0.73 for short grass to 0.02 to 0.06 for fruits/pods.

 
62 

Table 19. Acute dose-based RQs for birds due to exposure to proposed uses of benzovindiflupyr. 

 

Crop Use 

Small Medium Large 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Corn, 

cucurbits, 

fruit and 

tomatos, 

grapes, 

tubers 

4.0 1.8 2.3 0.3 1.6 0.1 1.8 0.8 1.0 0.1 0.7 <0.1 0.6 0.3 0.3 <0.1 <0.1 <0.1 

Peanuts 3.6 1.7 2.0 0.2 1.4 0.1 1.6 0.7 0.9 0.1 0.6 <0.1 0.5 0.2 0.3 <0.1 <0.1 <0.1 

Ornamenta

ls (Nursery 

Plants, 

Tomato 

Transplant, 

Fruit 

Transplant, 

Curcubit 

Transplant) 

4.6 2.1 2.6 0.3 1.8 0.1 2.1 0.9 1.2 0.1 0.8 <0.1 0.7 0.3 0.4 <0.1 <0.1 <0.1 

Turf 

grasses 

3.6 1.6 2.0 0.2 1.4 1.6 0.7 0.9 0.1 0.6 0.0

2 <0.1 0.5 0.2 0.3 <0.1 <0.1 <0.1 

Cotton 3.6 1.6 2.0 0.2 1.4 0.1 1.6 0.7 0.9 0.1 0.6

3 <0.1 0.5 0.2 0.3 <0.1 <0.1 <0.1 

Blueberries 2.7 1.2 1.5 0.2 1.0 <0.1 1.2 0.5 0.7 0.1 0.4

7 <0.1 0.4 0.2 0.2 <0.1 <0.1 <0.1 

Soybeans, 

Legumes 2.9 1.3 1.6 0.2 1.1 <0.1 1.3 0.6 0.7 0.1 0.5

0 <0.1 0.4 0.2 0.2 <0.1 <0.1 <0.1 

Cereal 

(Oats, 

Barley, and 

Wheat) 

2.5 1.1 1.4 0.2 1.0 <0.1 1.1 0.5 0.6 0.1 0.4

3 <0.1 0.3 0.2 0.2 <0.1 <0.1 <0.1 

Canola 1.7 0.8 1.0 0.1 0.7 <0.1 0.8 0.4 0.4 0.1 0.3

1 <0.1 0.2 0.1 0.1 <0.1 <0.1 <0.1 

Pome fruit 2.7 1.3 1.5 0.2 1.1 <0.1 1.2 0.6 0.7 0.1 0.4

8 <0.1 0.4 0.2 0.2 <0.1 <0.1 <0.1 

Acute listed species LOC = 0.1;; Non-listed animals acute LOC = 0.5 
63 

Table 20. Chronic dietary-based RQs for birds due to 

exposure to proposed uses of benzovindiflupyr. 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Corn, cucurbits, fruit and 

tomatos, grapes, tubers 0.64 0.29 0.36 0.04 0.25

Peanuts 0.57 0.26 0.32 0.04 0.22

Nursery Plants, Tomato 

Transplant, Fruit Transplant, 

Curcubit Transplant 

0.73 0.33 0.41 0.05 0.29

Turf grasses 0.56 0.26 0.32 0.04 0.22

Cotton 0.56 0.26 0.32 0.04 0.22

Blueberries 0.42 0.19 0.24 0.03 0.16

Soybeans, Legumes 0.45 0.21 0.25 0.03 0.18

Cereal (Oats, Barley, and 

Wheat) 0.39 0.18 0.22 0.02 0.15

Canola 0.27 0.13 0.15 0.02 0.11

Pome fruit 0.43 0.20 0.24 0.03 0.17

Chronic LOC = 1.0 

 
64 

 Acute and Chronic Risk to Mammals 

T-REX provides acute and chronic dose- based RQs for three size classes of mammals as well as 

chronic dietary based RQs resulting from ingestion of six different food items exposed to 

benzovindiflupyr. Table 21 below summarizes the acute dose-based RQs to mammals for all 

proposed use of benzovindiflupyr. For small mammals the acute listed species LOC was 

exceeded for all ten use groups eating short grass, and for two, five, and one of the use groups 

eating tall grass, broadleaf plants and arthropods respectively (Table 21). For medium sized 

animals, the acute listed species LOC was exceeded for nine of the ten use groups for short grass 

and for one and four of the use groups for both tall grass and broadleaf plants. For large sized 

mammals, only three of the ten use groups exceeded the acute listed species LOC when eating 

shortg rass. Overall acute RQs ranged from 0.01 to 0.28 and no dietary item from any use group 

exceeded the LOCs for non-listed species. 

Table 22 summarizes the chronic dose-based RQs to mammals for all proposed uses. Chronic 

RQs ranged from 0.01 to 2.29. For small mammals the chronic LOC of 1.0 was exceeded in nine 

of ten use groups from consumption of short grass while the chronic LOC was exceeded from 

consuming tall grass and broadleaf plants in one and two of the use groups respectively. For 

medium sized mammals, the chronic LOC was exceeded in nine of ten use groups when 

consuming short grass and two of ten use groups when consuming broadleaf plants. There were 

only two LOC exceedances for large sized mammals consuming short grass (Table 22). 

The dietary based RQs did not exceed the chronic LOC of 1.0 for any dietary item in any of the 

ten proposed use groups for benzovindiflupyr (Table 23). RQs ranged 0.01 when consuming 

fruits/pods to 0.26 when consuming short grass. Based on this there is predicted to be low 

chronic risk from dietary items in Table 23. 
65 

Table 21. Acute dose based RQs for mammals for benzovindiflupyr uses. 

 

 Crop Use 

Small Medium Large 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Corn, 

cucurbits, 

fruit and 

tomatoes, 

grapes, 

tubers 

0.25 0.11 0.14 0.02 0.10 <0.1 0.21 0.10 0.12 0.01 0.08 <0.1 0.11 0.05 0.06 0.01 0.04 <0.1 

Peanuts 0.22 0.10 0.12 0.01 0.09 <0.1 0.19 0.09 0.11 0.01 0.07 <0.1 0.10 0.05 0.06 0.01 0.04 <0.1 

Nursery 

Plants, 

Tomato 

Transplant, 

Fruit 

Transplant, 

Curcubit 

Transplant 

0.28 0.13 0.16 0.02 0.11 <0.1 0.24 0.11 0.14 0.02 0.09 <0.1 0.13 0.06 0.07 0.01 0.05 <0.1 

Turf grasses 0.22 0.10 0.12 0.01 0.09 <0.1 0.19 0.09 0.10 0.01 0.07 <0.1 0.10 0.05 0.06 0.01 0.04 <0.1 

Cotton 0.22 0.10 0.12 0.01 0.09 <0.1 0.19 0.09 0.11 0.01 0.07 <0.1 0.13 0.06 0.07 0.01 0.05 <0.1 

Blueberries 0.16 0.07 0.09 0.01 0.06 <0.1 0.14 0.06 0.08 0.01 0.05 <0.1 0.10 0.05 0.06 0.01 0.04 <0.1 

Soybeans, 

Legumes 0.18 0.08 0.10 0.01 0.07 <0.1 0.15 0.07 0.08 0.01 0.06 <0.1 0.08 0.04 0.05 0.01 0.03 <0.1 

Cereal 

(Oats, 

Barley, and 

Wheat) 

0.15 0.07 0.08 0.01 0.06 <0.1 0.13 0.06 0.07 0.01 0.05 <0.1 0.07 0.03 0.04 <0.1 0.03 <0.1 

Canola 0.11 0.05 0.06 0.01 0.04 <0.1 0.09 0.04 0.05 0.01 0.04 <0.1 0.05 0.02 0.03 <0.1 0.02 <0.1 

Pome fruit 0.17 0.08 0.09 0.01 0.07 <0.1 0.14 0.07 0.08 0.01 0.06 <0.1 0.08 0.04 0.04 <0.1 0.03 <0.1 

Acute listed species LOC = 0.1;; Non-listed animals acute LOC = 0.5 

 
66 

Table 22. Chronic dose based RQs for mammals due to exposed to proposed uses of 

benzovindiflupyr. 

 Small Medium Large 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Seeds 

Corn, 

cucurbits, 

fruit and 

tomatos, 

grapes, 

tubers 

2.0 0.9 1.1 0.1 0.8 <0.1 1.7 0.8 1.0 0.1 0.7 <0.1 0.9 0.4 0.5 0.1 0.4 <0.1 

Peanuts 1.8 0.8 1.0 0.1 0.7 <0.1 1.5 0.7 0.9 0.1 0.6 <0.1 0.8 0.4 0.5 0.1 0.3 <0.1 

Ornamental

s (Nursery 

Plants, 

Tomato 

Transplant, 

Fruit 

Transplant, 

Curcubit 

Transplant) 

2.3 1.1 1.3 0.1 0.9 <0.1 2.0 0.9 1.1 0.1 0.8 <0.1 1.1 0.5 0.6 0.1 0.4 <0.1 

Turf grasses 1.8 0.8 1.0 0.1 0.7 <0.1 1.5 0.7 0.9 0.1 0.6 <0.1 0.8 0.4 0.5 0.1 0.3 <0.1 

Cotton 1.8 0.8 1.0 0.1 0.7 <0.1 1.9 0.9 1.1 0.1 0.8 <0.1 1.0 0.5 0.6 0.1 0.4 <0.1 

Blueberries 1.3 0.6 0.7 0.1 0.5 <0.1 1.1 0.5 0.6 0.1 0.4 <0.1 0.6 0.3 0.3 <0.1 0.2 <0.1 

Soybeans, 

Legumes 1.4 0.7 0.8 0.1 0.6 <0.1 1.2 0.6 0.7 0.1 0.5 <0.1 0.7 0.3 0.4 <0.1 0.3 <0.1 

Cereal 

(Oats, 

Barley, and 

Wheat) 

1.2 0.6 0.7 0.1 0.5 <0.1 1.0 0.5 0.6 0.1 0.4 <0.1 0.6 0.3 0.3 <0.1 0.2 <0.1 

Canola 0.9 0.4 0.5 0.1 0.3 <0.1 0.7 0.3 0.4 0.1 0.3 <0.1 0.4 0.2 0.2 <0.1 0.2 <0.1 

Pome 1.4 0.6 0.8 0.1 0.5 <0.1 1.2 0.5 0.7 0.1 0.5 <0.1 0.6 0.3 0.4 <0.1 0.2 <0.1 

Chronic LOC = 1.0 
67 

Table 23. Chronic dietary based RQs for mammals due to exposed 

to proposed uses of benzovindiflupyr. 

Crop Use 

Short Grass 

Tall Grass 

Broadleaf Plants 

Fruits/pods 

Arthropods 

Corn, cucurbits, fruit and tomatos, grapes, 

tubers 0.23 0.11 0.13 0.01 0.09 

Peanuts 0.21 0.09 0.12 0.01 0.08 

Ornamentals (Nursery Plants, Tomato 

Transplant, Fruit Transplant, Curcubit 

Transplant) 

0.26 0.12 0.15 0.02 0.10 

Turf grasses 0.20 0.09 0.11 0.01 0.08 

Cotton 0.20 0.09 0.11 0.01 0.08 

Blueberries 0.15 0.07 0.09 0.01 0.06 

Soybeans, Legumes 0.16 0.07 0.09 0.01 0.06 

Cereal (Oats, Barley, and Wheat) 0.14 0.06 0.08 0.01 0.05 

Canola 0.10 0.05 0.06 0.01 0.04 

Pome fruit 0.16 0.07 0.09 0.01 0.06 

Chronic LOC = 1.0 

 
68 

 Terrestrial Invertebrates and Beneficial Insects 

Benzovindiflupyr is classified as practically non-toxic to honeybee (acute contact LD50 >100 ug 

a.i/bee; MRID 48604527) and was shown to be non-toxic at a dose of 109 μg a.i/bee in an acute 

oral exposure study (MRID 48604527). RQs were determined utilizing the equations in the 

Guidance for Assessing Pesticide Risks to Bees (US EPA, 2014). For risk through acute contact 

on individual survival the exposure was estimated by multiplying the maximum application rate 

by 2.7 μg a.i./bee and then comparing it to the acute contact LD50. Oral exposure was determined 

by multiplying the maximum application rate by 110 μg a.i./g multiplied by 0.292 g/day (page 

17 of guidance). The RQs for acute contact and oral exposures were <0.01 and 0.03 respectively 

and were below the LOC of 0.4 for bees. Therefore, while the potential exists via exposure 

pathways such as foliar sprays, the low application rates and lack of toxicity suggest that there is 

low risk concern to bees. One important caveat to this is that, as part of the aforementioned 

guidance document, the Agency now requires studies on acute oral toxicity to larval honey bees, 

chronic oral toxicity to adult honey bees, and chronic oral toxicity larval honey bees in addition 

to the acute contact toxicity to adult honey bees and acute oral toxicity to adult honey bees. 

These additional studies would reduce uncertainty about benzovindiflupyr’s effect on other life 

stages of the honey bee. 

 Terrestrial Plants 

Utilizing the data that was submitted, there was not any risk identified to terrestrial plants from 

any application of benzovindiflupyr. Seedling emergence and vegetative vigor studies are 

available for benzovindiflupyr but there remains uncertainty with several species that were tested 

in the seedling emergence study (see the ecological effects section for discussion of these 

species. The estimates of exposure generated by TerrPlant and described in Section 3.1.2 were 

compared to estimates of toxicity to estimate RQ for listed and non-listed plants in dry and semi 

aquatic areas and from spray drift. At the highest application rate modeled (0.089 lb a.i/A) there 

were not any exceedences of the LOC of 1.0 with RQs ranging from <0.1 in dry areas to 0.11 in 

semi-aquatic areas. However, there are uncertainties related to these risk conclusions related to 

the seedling emergence of plants and vegetative vigor. These uncertainties are discussed and 

characterized in Sections 3.3 and 4. 

.

 Risks Resulting from Bioaccumulation in the Food Web 

KABAM was used to calculate risk quotients from a bioaccumulation pathway for aquatic food 

items that may be consumed by birds and mammals (Table 24). There were not any mammalian 

wildlife species modeled that exceeded either the acute or chronic LOCs when consuming fish 

contaminated by benzovindiflupyr and are not presented here. The RQs modeled for avian 

wildlife species only exceeded the LOC for acute dose based exposure. The acute dietary based 

exposure and chronic based exposure (both dose based and dietary based) did not exceed any 

LOCs and are not presented. The acute dose based RQs exceeded the acute listed species LOC 
69 

in 11 of 14 scenarios modeled for sandpipers and in 8 of 14 scenarios modeled for rails. The 

acute dose-based based RQs for sandpipers ranged from 0.13 (cereal crops) to 0.42 (tubers) and 

from 0.16 (cotton) to 0.23 (tubers) for rails (Table 24). There were not any LOC exceedances 

for chronic exposure of avian species consuming fish contaminated with benzovindiflupyr. 

Likewise risk to avian species on a chronic basis also appears to be low as evidenced by no LOC 

exceedances in any scenario. On an acute dose basis, there does appear to be risk to federally 

listed birds consuming fish contaminated with benzovindiflupyr as seen in listed LOC 

exceedances for two species of birds and in 11 of the 14 proposed uses of benzovindiflupyr. 

However, if this model uses the LD50 for bobwhite quail (1373 mg/kg-bw), there would not be 

any LOC exceedances for either sandpipers or rails. Furthermore, given the uncertainty with the 

passerine study and the regurgitation driving the endpoint, there is uncertainty in the risk 

conclusions using the passerine endpoint. 

Table 24. Calculation of RQ values for birds consuming fish contaminated by 

benzovindiflupyr. 

Crop Use

Dose Based Acute Avian RQs

sandpipers cranes rails herons small 

osprey 

white 

pelican 

Corn 0.37 0.02 0.20 0.03 0.05 0.02 

Cucuribits 0.23 0.01 0.12 0.02 0.03 0.01 

Grapes 0.31 0.02 0.16 0.03 0.04 0.02 

Nursery 

Crops 

0.20 0.01 0.11 0.02 0.03 0.01 

Peanuts 0.23 0.01 0.13 0.02 0.03 0.01 

Tubers 0.42 0.02 0.23 0.04 0.06 0.03 

Tomatos 0.23 0.01 0.13 0.02 0.03 0.01 

Cotton 0.31 0.02 0.16 0.03 0.04 0.02 

Blueberries 0.16 0.01 0.09 0.01 0.02 0.01 

Soybeans and 

legumes 

0.16 0.01 0.09 0.01 0.02 0.01 

Cereal Crops 0.13 0.01 0.07 0.01 0.02 0.01 

Canola 0.06 <0.01 0.03 0.00 0.01 <0.01 

Pome fruits 0.06 <0.01 0.03 0.01 0.01 <0.01 

Turf grass 0.05 <0.01 0.02 <0.01 0.01 <0.01 

*Acute listed species LOC = 0.1;; Non-listed animals acute LOC = 0.5 

Chronic LOC = 1.0 

**Bolded Red Values Indicate LOC exceedence 

 
70 

3.3 Risk Description 

3.3.1 Aquatic Organisms 

The proposed benzovindiflupyr applications are predicted to adversely impact both freshwater 

and estuarine/marine fish on both an acute and a chronic basis. The proposed applications also 

adversely impact both freshwater and estuarine/marine water column invertebrates on an acute 

and chronic basis. Sediment invertebrates are expected to have low exposures to 

benzovindiflupyr with RQs being less than the LOC for fish and invertebrates in the water 

column since the relevant endpoints for benthic invertebrates are less sensitive effects. Table 26

in Section 5 below lists the expected adverse impacts by aquatic organism for each proposed use. 

Exceedances of LOCs appear to be driven by benzovindiflupyr’s high toxicity and high 

persistence despite its low application rate. In addition, aquatic exposure for the 

benzovindiflupyr proposed uses appear to be driven by runoff. Therefore, the ability to mitigate 

risk to water column organisms by eliminating spray drift is minimal. Modeling with the SWCC 

shows that RQs would decrease by ca. 30% (range 29 -33%) by eliminating spray drift to water 

bodies but would not change the risk conclusions, particularly for acute exposure for freshwater 

fish, chronic freshwater fish, and chronic exposure to water column freshwater invertebrates. 

The implementation of spray drift buffers can only mitigate risk for all benzovindiflupyr uses 

related to chronic impacts estuarine/marine fish and estuarine/marine invertebrates (water 

column) including proposed uses on potato, corn, and grapes with these taxa. For example, the 

chronic estuarine/marine fish RQ from the highest exposure scenario (ME potatoes) decreases 

from 1.4 to slightly below the LOC threshold without drift. The Tier 1 AgDrift model (version 

2.1.1) indicates that a 30 ft spray drift buffer would effectively mitigate risk with all 

benzovindiflupyr proposed uses for chronic estuarine/marine invertebrates (water column) and 

chronic estuarine/marine fish. However, it is still important to note that spray drift buffers would 

not resolve the risks anticipated to adverse impacts expected for acute freshwater fish, acute 

freshwater estuarine invertebrates, chronic freshwater fish for all of the proposed 

benzovindiflupyr uses collectively. 

Given benzovindiflupyr’s persistence in aquatic environments, residue build up in the water 

column and sediment is possible and can result in higher aquatic EECs than depicted in this 

assessment given the finite timeframe (30 years) simulated to calculate EECs with the SWCC. 

However, the proposed seasonal treatment schedules of benzovindiplupyr, its slow degradation 

observed in aquatic environments in the aquatic metabolism studies, and its tendency to 

equilibrate relatively rapidly in sediment and the water column (see Figure 1) all indicate that 

steady state concentrations of benzovindiflupyr would be expected to be reached within a 30-

year window of time. This is evident from time series produced by the SWCC for all of the 

aquatic scenarios modeled (sample from the ME Potatoes scenario shown in Figure 2). Annual 

average SWCC estimated concentration in the water column and benthic pore water indicate that 

steady state is reached with ca. 20 years of steady labeled application of benzovindiflupyr. Since 
71 

steady state concentrations are reached within the simulation time in this evaluation, 

uncertainties in EECs due to continual buildup of residues over time are expected to be minimal. 

Figure 2. Time series of SWCC annual average concentrations predicted in the water 

column (blue squares) and benthic pore water (yellow dots). Sample results from SWCC 

Maine potato application scenario. 

Regardless of benovindiflupyr’s high persistence, restrictions on the use of benzovindiflupyr to 

only every few years potentially can resolve acute risks of concern for aquatic organisms. While 

long-term concentrations, as shown in Figure 2 would not change chronic exposure risks of 

concern, short-term pulses entering waterways associated with benzovindiflupyr applications can 

be reduced with sparser applications of benzovindiflupyr applications every few years. 

3.3.2 Terrestrial Organisms 

For dietary exposure, there are risks of concern for both birds and mammals related to acute 

dose-based impacts for all of the proposed uses of benzovindiflupyr. The direct deposition of 

benzovindiflupyr residues on treated crops are expected to result in toxicologically adverse 

impacts considering the maximum single application rates, number of applications, and 

application intervals for the proposed uses of benzovindiflupyr as shown in Table 1. It should 

be noted that risk of concern are likely driven from a conservative endpoint from the passerine 

oral toxicity study (MRID No. 48604513) due to the frequency of regurgitation at all but the 

lowest treatment group precluded the determination at a definitive endpoint. The conservative 

endpoint was estimated according to EFED guidance (EPA 2012; also online at 

http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/terrestrial_biology_te

ch_team/rr_regurg_acute_passerine.pdf ) on the basis of the highest dose concentration below 

which regurgitation occurred. Given the conservative nature of this endpoint, the risk 

conclusions utilizing this endpoint would likely be protective. If the endpoint for bobwhite quail 

is used (LD50 = 1373 mg/kg-bw), there would not be any acute risk identified for birds for any 
72 

use of solatenol. Additional studies submitted for passerine birds may enable for the 

determination of an oral LD50 that would likely yield a less conservative depiction of the actual 

lethal dose. The dietary study that was received indicated that benzovindiflupyr was toxic with 

70 percent mortality occurring at the lowest dose tested and precluded determination of an 

appropriate endpoint. For chronic impacts to birds, there are no impacts expected for any of the 

proposed uses of benzovindiflupyr based on dietary-based RQs. 

Dietary-based RQs do not exceed any of the LOCs for mammals as well. In general, chronic 

exposure is anticipated to be minimized by the small total loadings of benzovindiflupyr (up to 

0.272 lbs. a.i./A) considering all proposed uses. Furthermore, chronic exposures to 

benzovindiflupyr crop residues on turf grass, barley, peanuts, and soybeans are not expected to 

be prevalent given foliar dissipation half-lives between 0.6 – 19.3 days have been determined 

from the field dissipation plant residue module (MRID Nos. 48604497, 48604498, 48604502, 

48604502, 58604580, and 48604581, refer to Table 3). The foliar dissipation half-lives from 

these submitted studies were used the in exposure modeling the risk quotient calculations. While 

chronic dietary-based exposures are not expected to mammals, chronic dosed-based exposures 

may occur. The dosed-based exposure can more capture the longer-term exposure via 

benzovindiflupyr residues for mammals which feed more consistently within treated fields 

leading to repeat exposure. However, in cases where mammals are more transient in their 

dietary habits with feedings which may occur off the treated field, the dietary-based RQs may be 

a more relevant depiction of risk. In any case, the chronic dose-based risk of concern to 

mammals is not discountable given the on-field non-transient exposure scenario for mammalian 

habitats described above. 

There is risk concern related to the indirect dietary exposure pathway of piscivorous birds 

consuming fish containing benzovindiflupyr residue and related impacts resulting from the food 

web at lesser trophic levels, as indicated by KABAM modeling and LOC exceedances for two 

species of birds modeled for 11 of the 14 proposed uses of benzovindiflupyr. While 

benzovindiflupyr’s bioavailability within fish tissues is limited from a combination of low 

application rates and moderately high depuration rates, the predicted toxicity to birds, 

particularly from the passerine oral toxicity study with a likely highly conservative endpoint 

given the regurgitation limitations with the study, make this route of exposure an area of 

concern. As noted for the results of the TREX generated RQs, the RQs decrease significantly (to 

below the agencies LOCs) if the LD50 used was from the bobwhite quail study (LD50 =1373 

(quail) vs LD50 = 10 (passerine species). Benzovindiflupyr’s expected accumulation as 

suggested by its log Kow = 4.3, BCF values appear to be moderated by benzovindiflupyr’s overall 

rapid depuration with total residue half-lives of < 1 day measured in the bluegill sunfish BCF 

study (MRID No. 4864521, refer to Table 3). The demonstrated bioconcentration potential 

found in benzovindiflupyr BCF study is similar to those used in KABAM modeling with the 

BCF values generated by KABAM being 2.4 times greater than those measured in the BCF study 

(MRID 48604521) suggesting that the model estimates represent a reasonable assessment of risk 

from consumption of fish from contaminated water bodies. Evaluating the reduction of the 

accumulation of benzovindiflupyr on fish tissues due to metabolism were not found to impact the 

overall risk conclusions. 
73 

Risks to terrestrial invertebrates (beneficial insects) are not expected via the contact or oral route 

on an acute basis. This is primarily due to that exposure to benzovindiflupyr residues which are 

directly deposited on to treated crop foliage from spray applications are not expected to be in 

high enough quantities to exceed the level of concern based on EEC calculations from the 

existing honeybee contact toxicity study (acute contact LD50 >100 ug a.i/bee; MRID 48604527), 

and acute oral toxicity study (non-toxic finding at a dose of 109 μg a.i/bee, MRID 48604527). 

However, there is uncertainty for terrestrial invertebrates. The LR50 for the parasistic wasp is 

equivalent to 0.077 lbs a.i. per acre. The application rates for benzovindiflupyr range from 0.68 

to 0.088 lbs a.i. per acre suggesting that benzovindiflupyr may adversely impact terrestrial 

invertebrates. Additionally, there is uncertainty related to adverse impacts to larval honey bees 

via the oral exposure route (acute and chronic) as well as chronic adverse impacts to adult honey 

bees via the oral route as no studies have been submitted. There is no language on the proposed 

labels restricting benzovindifluypyr applications when plants are in bloom in the vicinity. 

Furthermore, chronic adverse impacts to bees and terrestrial invertebrates are possible especially 

considering the risks of concern identified with aquatic invertebrates. Therefore, at this time, 

EPA presumes risk to terrestrial invertebrates and will re-visit this risk finding upon submission 

of the acute and chronic larval oral toxicity studies and chronic adult bee contact toxicity study. 

Based on vegetative vigor and seedling emergence toxicity studies submitted for 

benzovindiflupyr and Terrplant EECs, there are not any LOC exceedances from proposed 

applications. The NOAEC for the seedling emergence study (MRID 48604538) was 0.089 

lbs./A for monocots and dicots. The NOAEC for the vegetative vigor study (MRID 48604599) 

was 0.09 lbs a.i./A for all monocots and dicots tested. The EC25 values are used to calculate the 

RQs for non-listed species suggesting that there is uncertainty with these RQs due to nondefinitive EC25 values. The RQs ranged from <0.1 for monocots to 0.11 for listed dicots in semiaquatic areas. While there is uncertainty in risk due to non-definitive endpoints, the results 

suggest there is low risk to plants. 

Please refer to Table 27 in Section 5 below which breaks down the expected adverse impacts by 

terrestrial organism for each proposed use.

3.4 Review of Incident Data and Environmental Monitoring Data 

As benzovindiflupyr has not been previously approved for use in the United States, there are no 

incident reports or environmental monitoring data for this chemical. 
74 

4. ENDOCRINE DISRUPTOR SCREENING PROGRAM 

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse 

outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and 

chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, 

reproductive, and general or systemic toxicity. These studies include endpoints which may be 

susceptible to endocrine influence, including effects on endocrine target organ histopathology, 

organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, 

and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and 

chronic studies that assess growth, developmental and reproductive effects in different 

taxonomic groups. As required by FFDCA section 408(p), benzovindifluypyr is subject to the 

endocrine screening part of the Endocrine Disruptor Screening Program (EDSP). 

EPA has developed the EDSP to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator 

may designate.” The EDSP employs a two-tiered approach to making the statutorily required 

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a 

chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal 

systems. Chemicals that go through Tier 1 screening and are found to have the potential to 

interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA 

will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 

testing is designed to identify any adverse endocrine-related effects caused by the substance, and 

establish a dose-response relationship between the dose and the E, A, or T effect. 

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between 

October 2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 

chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. A second list 

of chemicals identified for EDSP screening was published on June 14, 20138

 and includes some 

pesticides scheduled for registration review and chemicals found in water. Neither of these lists 

should be construed as a list of known or likely endocrine disruptors. 

Benzovindifluypyr is not on the first or second list. The second list represents the next set of 

chemicals for which EPA intends to issue test orders/data call-ins in the near future. For further 

information on the status of the EDSP, the policies and procedures, the lists of chemicals, future 

lists, the test guidelines and the Tier 1 screening battery, please visit our website.9

 

 

8

 See http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0477-0074 for the final second list of 

chemicals. 9

 http://www.epa.gov/endo/ 
75 

5. LISTED SPECIES 

In November 2013, the EPA, along with the U.S. Fish & Wildlife Service (USFWS), the 

National Marine Fisheries Service (NMFS) (collectively, the Services), and the U.S. Department 

of Agriculture (USDA) released a summary of their joint Interim Approaches for assessing risks 

to listed species from pesticides. The Interim Approaches were developed jointly by the 

agencies in response to the National Academy of Sciences’ (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. 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 

Endangered Species Act (ESA) and FIFRA. 

The joint Interim Approaches were released prior to a stakeholder workshop held on November 

15, 2013. In addition, the EPA presented the joint Interim Approaches at the December 2013 

Pesticide Program Dialogue Committee (PPDC) and State-FIFRA Issues Research and 

Evaluation Group (SFIREG) meetings, and held a stakeholder workshop in April 2014, allowing 

additional opportunities for stakeholders to comment on the Interim Approaches. As part of a 

phased, iterative process for developing the Interim Approaches, the agencies will also consider 

public comments on the Interim Approaches in connection with the development of upcoming 

Registration Review decisions. The details of the joint Interim Approaches are contained in the 

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,” dated November 1, 2013. 

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 preliminary risk assessment for benozvindiflupyr does not contain 

a complete ESA analysis that includes effects determinations for specific listed species or 

designated critical habitat. Although EPA has not yet completed effects determinations for 

specific species or habitats, for this preliminary assessment, EPA conducted a screening-level 

assessment for all taxa of non-target wildlife and plants that assumes for the sake of the 

assessment that listed species and designated critical habitats may be present in the vicinity of 

the application of benzovindiflupyr. This screening level 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. This screening-level risk 

assessment for benzovindiflupyr indicates potential risks of direct effects to listed mammals, 

birds, terrestrial invertebrates, fish, and aquatic invertebrates on all of its registered use sites. 

Listed species of aquatic and terrestrial plants may also be affected through indirect effects 

because of the potential for direct effects on listed and non-listed species upon which such 

species may rely. Potential direct effects on listed mammals, birds, terrestrial invertebrates, fish, 

and aquatic invertebrates from the use of benzovindiflupyr may be associated with modification 

of Primary Constituent Elements (PCEs) of designated critical habitats, where such designations 

have been made. Once the agencies have fully developed and implemented the scientific 
76 

methods necessary to complete risk assessments for endangered and threatened (listed) species 

and their designated critical habitats, these methods will be applied to subsequent analyses for 

benzovindiflupyr as part of completing this registration review. 
77 

6. UNCERTAINTIES, LIMITATIONS, AND IDENTIFICATION OF

DATA GAPS 

 Labels and Proposed Uses 

There is uncertainty regarding seasonal maximum application rates specified on the label. This 

risk assessment evaluated one treatment and retreatment cycle of benzovindiflupyr occurring per 

year. While this is likely the intended use pattern, specification of seasonal maximum 

application rates potentially enables multiple series of benzovindiflupyr treatment and 

retreatment cycles throughout the year. Therefore, specifying seasonal maximum application 

rates as yearly maximum application rates would address this uncertainty, which exists for all 

proposed crop uses. 

The Executive Summary (Section 1.1) re-iterates the need for providing this clarification 

on labels to address this uncertainty related to treatment and re-treatment application 

cycles of benzovindiflupyr which may occur throughout the course of the year. 

 Aquatic Exposure Assessment 

The main uncertainty in the aquatic exposure assessment for benzovindiflupyr concerns a major 

deficiency in the aerobic aquatic studies (MRID Nos. 48604509 and 48604510). The aerobic 

aquatic metabolism half-life is one critical parameter impacting acute and chronic aquatic EECs. 

Conditions in these studies were fringe anaerobic (suboxic) as the criteria for aerobic conditions 

taking into account redox potential and pH was not satisfied10. However, benzovindiflupyr is 

very persistent in all environmental media with half-lives in the range of 620 – 1,788 days in soil 

and water. So, it is unlikely that benzovindiflupyr would degrade exceptionally faster in water 

under aerobic conditions. In lieu of the aerobic aquatic studies available, this uncertainty is 

addressed in this risk assessment by utilizing the conservative default of doubling the soil 

metabolism half-life to represent the aquatic environmental biodegradation in the modeling. 

However, given that benzovindiflupyr is persistent as it is, aquatic EECs would not be impacted 

unless aerobic aquatic metabolism half-lives much lower in magnitude than other degradation 

pathways, which is not likely given the appearance of the persistent moiety of benzovindiflupyr 

in the environment. 

In addition related to aerobic degradation of benozvindiflupyr in water-sediment environments, 

photosynthetically active organisms may provide an additional mode of degradation for 

benzovindiflupyr. To investigate this, additional mesocosym type of studies were conducted by 

th for benzovindiflupyr in aquatic environments. These mesocosm studies modified the 

guideline aerobic aquatic metabolism guidelines study design to incorporate the impact of algae 

and macrophytes separately (MRID Nos. 48604509 and 48604510) and collective impacts 

incorporating both algae and macrophtyes (MRID No. 48604578). Each of these studies were 

also conducted under conditions with a light-dark cycle using an artificial light source. The 

 

10 The criteria for aerobic conditions is pe + pH >12 where pe = redox potential/59.2 (Sposito, 1989). 
78 

registrant calculated half-lives for benzovindiflupyr in the range between 52 – 85 days with algae 

cultures, 19 – 39 days with macrophyte cultures, and 15 – 56 days with combined algae and 

macrophyte cultures. However, there were substantial uncertainties in each of these mesocosm 

studies related to incomplete material balances throughout the total aquatic-sediment system over 

the study durations. In summary, there were instances where at least 30 percent of the overall 

material balance was not known, and in some cases such was the case well in exceedance of this 

amount in the total water-sediment system. Furthermore, in most cases, the degradates detected 

in the mesocosm studies were less than 10 percent total of the material balance. Therefore,, there 

are a lot of uncertainities with the environmental context of the registrant calculated half-lives in 

the mesocosm studies, and the pathway of degradation in the water column and sediment or 

dissipation to sediment of the material is also uncertain. Given these uncertainties, the aquatic 

exposure assessment and the calculated estimated exposure concentrations (EECs) relied on the 

more definitive results provided in the guideline aerobic aquatic metabolism studies without 

algae and macrophytes conducted under darkness (MRID Nos. 48604509 and 48604510), and 

are reflective of environments free of these organisms. It should be noted that the diurnal lightdarkness cycles were incorporated into the aquatic exposure analysis and EECs using the 

existing aqueous photolysis study (MRID No. 48604507). 

One other limitation related to aquatic exposure in this screening risk assessment is that surface 

water aquatic exposure EECs presented for the proposed nationwide uses of benzovindiflupyr are 

based on a finite collection of application scenarios associated with the SWCC model. While 

finite, the application scenarios for crops were selected based on the combination of the highest 

application rates proposed for crops, application methods, and environmental conditions across 

the country which would result in upper-bound exposure out of all of the proposed uses for 

benzovindiflupyr consistent with the screening approach to this risk assessment. For instance, 

first, only aerial applications are evaluated for surface water for all application scenarios except 

where only ground spray applications are proposed for turf and ornamental uses. Aerial 

applications result in upper-bound EDWCs since the spray drift contribution with these 

applications most impact water bodies. Furthermore, broadcast aerial applications would result 

in higher EECs than banded and in-furrow soil applications also proposed for potatoes and 

peanuts since these soil applications would be a more localized application rather than a 

broadcast application. Secondly, while all proposed uses were evaluated in this risk assessment, 

only one crop scenario per use site is presented in the surface water exposure assessment. These 

presented crop scenarios were selected based on the SWCC scenario which produces the highest 

runoff and resulting exposure out of all regional crop scenarios developed across the country. 

With this stated, the maximum EECs identified in Table 9 is considered the upper-bound EECs 

for the entire collection of proposed crops for benzovindiflupyr, considering all of the decision 

points related to application rates, application methods, and environmental regional variations 

discussed above. 

Despite the uncertainties described above, the dataset of environmental fate studies and 

ecological toxicity studies for the aquatic exposure assessment is complete for 

benzovindiflupyr. The submission of additional studies to address the various deficiencies 

noted above would not change the risk conclusions presented in Section 3.2 and Section 5
79 

below. Therefore, no data to support future aquatic exposure assessments for benzovindiflupyr 

are requested at this time. 

 Terrestrial Exposure Assessment

The exposure assessment for terrestrial organisms in this risk assessment relies on the best 

available estimates of environmental fate and physicochemical properties, maximum application 

rate of benzovindiflupyr, maximum number of applications, and the shortest interval between 

applications. However, several uncertainties and model limitations are noted and should be 

considered in interpreting the results of this terrestrial risk assessment. 

When effects data are available, dose-based and dietary-based acute RQs should be provided to 

risk managers. The dose-based approach assumes that the uptake and absorption kinetics of a 

gavage toxicity study approximate the absorption associated with uptake from a dietary matrix. 

Toxic response is a function of duration and intensity of exposure. Absorption kinetics across the 

gut and enzymatic activation/deactivation of a toxicant may be important and are likely variable 

across chemicals and species. For many compounds, a gavage dose represents a very short-term, 

high intensity exposure, whereas dietary exposure may involve a more prolonged exposure period. 

The dietary-based approach assumes that animals in the field are consuming food at a rate similar 

to that of confined laboratory animals. Energy content in food items differs between the field and 

the laboratory as do the energy requirements of wild and captive animals. The Wildlife Exposure 

Factors Handbook can provide insights into energy requirements of animals in the wild as well as 

energy content of their diets (USEPA, 1993). 

The typical 21-week avian reproduction study does not define the true exposure duration needed 

to elicit the observed responses. The study protocol was designed to establish a steady-state tissue 

concentration for bioaccumulative compounds. For other pesticides, it is entirely possible that 

steady-state tissue concentrations are achieved earlier than the 21-week exposure period. 

Moreover, pesticides may exert effects at critical periods of the reproduction cycle; therefore, longterm exposure may not be necessary to elicit the effect observed in the 21-week protocol. The 

EFED screening-level risk assessment uses the single-day maximum estimated EEC as a 

conservative approach. The degree to which this exposure is conservative cannot be determined 

by the existing reproduction study. 

In the risk assessment, RQs were only calculated for the most sensitive dietary class relevant to 

the organisms assessed. For most organisms, not enough data is available to conclude that birds 

or mammals may not exclusively feed on a dietary class for at least some time period. However, 

most birds and mammals consume a variety of dietary items and thus the RQ will overestimate 

risk to those organisms. Additionally, some organisms will not feed on all of the dietary classes. 

For example, many amphibians would only consume insects and not any plant material. 

In addition, there are a couple of uncertainties to note related to the potential bioaccumulation of 

benzovindiflupyr residues in the tissues of fish which may be bioavailable to piscivorous birds. 

The uncertainties are all related to the existing BCF study on the bluegill sunfish (MRID No. 

48604521). First, only one test concentration of benzovindiflupyr was evaluated in the study. 
80 

The test concentration of 0.26 g a.i./L in the study was on the lower bound of the range of 

aquatic EECs for benzovindiflupyr. Despite this uncertainty, BCFs calculated in KABAM, 

which served as the basis of exposure dose concentrations for piscivorous birds and based on 

upper-bound aquatic EECs, were similar in magnitude to BCFs determined in the study, with a 

magnitude departure of less than 2.4 in all cases. Secondly, only a small amount of 

benzovindiflupyr was detected throughout the study. However, it was found that depuration of 

total residues was rapid, with a depuration half-life of 0.54 days and that the vast majority of 

total residues were removed from whole fish after 7 days of depuration. This suggests that the 

residence time of any toxic residue, including benzovindiflupyr, in fish tissues is similarly short 

in a flowing water body, but not in a static pond. 

Considering the discussion above, the ecological toxicity database is largely complete. 

However, the following are a list of exceptional data gaps applicable to the terrestrial 

assessment: 1.) Honeybee toxicity studies: The available data (acute oral and contact toxicity 

studies for adult bees) suggest that benzovindiflupyr is practically non-toxic to bees and 

preliminary exposure modeling and RQ analysis suggests that risk to adult bees via the contact 

and oral exposure pathways is low. However, there are no acute or chronic toxicity studies 

submitted for larval bees or chronic feeding studies for adult bees. There is no language on the 

proposed labels restricting benzovindifluypyr applications when plants are in bloom in the 

vicinity. Therefore, risks to terrestrial invertebrates is presumed in the absence of data and given 

benzonvindiflupyr’s potential bioavailability to beneficial insects which may be attracted to 

treated plants. This presumption of risk finding for terrestrial invertebrates will be re-considered 

contingent upon the submission of these honeybee toxicity studies. The Executive Summary 

(Section 1.3) re-iterates the need for the additional bee toxicity data at this time including 

acute and chronic larval-stage bee toxicity studies and chronic feeding toxicity studies for 

adult bees to address the potential risks to different life stages of terrestrial invertebrates 

not assessed with the currently available data. 2.) Passerine study: As of the time of this 

assessment, the existing passerine study (MRID 48604513) was considered supplemental. In the 

currently available passerine study, the frequency of regurgitation at all but the lowest treatment 

group precluded the determination at a definitive endpoint. EFED guidance (EPA 2012; also 

online at 

http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/terrestrial_biology_te

ch_team/rr_regurg_acute_passerine.pdf) indicates to “use the highest value below which 

regurgitation did occur as the acute endpoint for that study”. Therefore, the risk conclusions 

utilizing this endpoint would likely be protective considering the uncertainty that regurgitation 

introduces. An additional passerine study that has been requested to address this uncertainty has 

not been submitted as of the time of this assessment.

 Other General Uncertainties for Screening Risk Assessments

Routes of Exposure 

The screening assessment does not consider benzovindiflupyr dermal exposure to terrestrial 

organisms. The Agency is actively pursuing modeling techniques to account for dermal exposure 
81 

via direct application of spray and by incidental contact with contaminated vegetation, soil and 

water. 

Age Class and Sensitivity of Effects Thresholds 

It is generally recognized that test organism age may have a significant impact on the observed 

sensitivity to a toxicant. The screening risk assessment acute toxicity data for fish are collected 

on juvenile fish and aquatic invertebrate acute testing is performed on recommended immature 

age classes. Similarly, acute dietary testing with birds is also performed on juveniles, with 

mallard being 5-10 days old and quail at 10-14 days of age. 

Testing of juveniles may overestimate the toxicity of direct acting pesticides in adults. As 

juvenile organisms do not have fully developed metabolic systems, they may not possess the 

ability to transform and detoxify xenobiotics equivalent to the older/adult organism. The 

screening risk assessment has no current provisions for a generally applied method that accounts 

for this uncertainty. In so far as the available toxicity data may provide ranges of sensitivity 

information with respect to age class, the risk assessment uses the most sensitive life-stage 

information as the conservative screening endpoint. 

Lack of Effects Data for Amphibians and Reptiles 

Currently, toxicity studies on amphibians and reptiles are not required for pesticide registration. 

Since these data are lacking, the Agency uses fish as surrogates for aquatic phase amphibians and 

birds as surrogates for terrestrial phase amphibians and reptiles. If other species are more or less 

sensitive to benzovindiflupyr than the surrogates, risks may be under- or overestimated, 

respectively. The Agency is not limited to a base set of surrogate toxicity information in 

establishing risk assessment conclusions. The Agency also considers toxicity data on nonstandard test species when available. Further research is needed to determine whether, in 

general, reptiles and terrestrial-phase amphibians are suitably represented by bird species in 

assessing risks for benzovindiflupyr and fish are an appropriate surrogate for aquatic-phase 

amphibians. 

 

Use of the Most Sensitive Species Tested 

Although the screening risk assessment relies on a selected toxicity endpoint from the most 

sensitive species tested, it does not necessarily mean that the selected toxicity endpoints reflect 

sensitivity of the most sensitive species existing in a given environment. The relative position of 

the most sensitive species tested in the distribution of all possible species is a function of the 

overall variability among species to a particular chemical. The relationship between the 

sensitivity of the most sensitive tested species versus wild species (including listed species) is 

unknown and a source of significant uncertainty. In addition, in the case of listed species, there is 

uncertainty regarding the relationship of the listed species' sensitivity and the most sensitive 

species tested. 
82 

Sublethal Effects

When assessing acute risk, the screening risk assessment relies on the acute mortality endpoint as 

well as a suite of sublethal responses to the pesticide, as determined by the testing of species 

response to chronic exposure conditions and subsequent chronic risk assessment. Consideration 

of additional sublethal data in the effects determination is exercised on a case-by-case basis and 

only after careful consideration of the nature of the sublethal effect measured and the extent and 

quality of available data to support establishing a plausible relationship between the measure of 

effect (sublethal endpoint) and the assessment endpoints. However, the full suite of sublethal 

effects from valid open literature studies is considered for the characterization purposes. 

To the extent to which sublethal effects are not considered in this assessment, the potential direct 

and indirect effects of benzovindiflupyr on listed species may be underestimated. 
83 

7. CONCLUSIONS 

The risk hypothesis identified in the problem formulation (Section 2.4) stated, 

“Based on the application methods, mode of action, fate and transport, and the sensitivity of 

non-target aquatic and terrestrial species, benzovindiflupyr has the potential to reduce survival, 

reproduction, and/or growth in non-target terrestrial and aquatic organisms when used in 

accordance with the current label. 

After reviewing the most recent environmental fate and effects data for benzovindiflupyr, the 

screening-level assessment concludes that registered uses of the fungicide may result in risk to 

both listed and non-listed species of aquatic and terrestrial animals and wildlife. 

When estimates of benzovindiflupyr exposure in terrestrial and aquatic environments are 

compared to the available ecotoxicity data, the results of the screening-level assessment indicate 

a potential for risk to both aquatic and terrestrial taxa. Environmental fate modeling and risk 

quotient determination indicate potential adverse effects on aquatic animal taxa. Acute and 

chronic risk to freshwater fish, estuarine/marine fish, freshwater invertebrates, and 

estuarine/marine invertebrates was identified. Chronic RQs for sediment dwelling invertebrates 

did not exceed LOCs and did not identify any chronic risk to sediment dwelling invertebrates. 

Acute RQs derived from comparing peak porewater concentrations to acute water column 

toxicity endpoints did however predict acute risk concerns to sediment dwelling invertebrates. 

Risk above the level of concern was not identified for aquatic plants (both vascular and nonvascular). Acute dose based risk to birds was identified in all size classes of birds. There was 

also LOC exceedences for sandpipers and rails consuming fish contaminated with 

benzovindiflupyr suggesting risk through this pathway. Avian chronic RQs did not exceed the 

LOC in any scenario so chronic risk is presumed to be low. There was also acute and chronic 

dose-based risk identified in all size classes of mammals. There was not any chronic risk 

identified for dietary based exposure in mammals or acute risk from the consumption of fish 

contaminated with benzovindiflupyr. The available data suggest that benzovindiflupyr is 

practically non-toxic to bees and preliminary modeling and RQ analysis suggests that acute risk 

to bees via the contact exposure route is low. However, chronic risk and acute dietary risk to 

terrestrial invertebrates remain an uncertainty due to lack of toxicity data. There was not any 

risk identified to terrestrial plants. 

The overall risk conclusions for aquatic and terrestrial taxa broken down by each proposed use of 

benzovindiflupyr are presented below in Table 26 and Table 27, respectively. Collectively for 

all proposed uses of benzovindiflupyr, no risks to listed terrestrial plant species are anticipated. 

Risks for direct and indirect effects to all terrestrial and aquatic listed species are expected. The 

exceptions are chronic impacts to listed benthic estuarine/marine and freshwater invertebrates. 
84 

Table 26. Summary of adverse impacts for aquatic organisms expected from the proposed uses benzovindiflupyr. Proposed Use 

Adverse Impacts Expected for Aquatic Organisms? (No/Yes: A = Acute, C=Chronic) 

Freshwater 

Fish 

Estuarine/Marine 

Fish 

Freshwater 

Invertebrates 

(Water 

Column) 

Estuarine/ 

Marine 

Invertebrates 

(Water 

Column) 

Freshwater 

and 

Saltwater 

Benthic 

Invertebrates 

(Sediment) 

Freshwater 

Benthic 

Invertebrates 

(Pore water) 

 Saltwate

Benthic 

Invertebra

(Pore wat

Corn YesA,C YesA,C YesA,C YesA No YesA YesA Cucurbits YesA,C YesA YesA YesA No No YesA Tomatoes and Fruiting Vegetables 

YesA,C YesA YesA,C Yes No No YesA 

Grapes YesA,C YesA,C YesA YesA No YesA YesA Tubers (Potatoes) YesA,C YesA,C YesA YesA,C No YesA YesA Peanuts YesA,C YesA YesA,C YesA No No YesA Nursery Plants, Tomato Transplant, Fruit Transplant, Cucurbit Transplant 

YesA,C YesA YesA YesA No No YesA 

Turf Grass YesA,C No No No No No No Cotton YesA,C YesA YesA YesA No No YesA 
85 

Table 26. Summary of adverse impacts for aquatic organisms expected from the proposed uses benzovindiflupyr. Proposed Use 

Adverse Impacts Expected for Aquatic Organisms? (No/Yes: A = Acute, C=Chronic) 

Freshwater 

Fish 

Estuarine/Marine 

Fish 

Freshwater 

Invertebrates 

(Water 

Column) 

Estuarine/ 

Marine 

Invertebrates 

(Water 

Column) 

Freshwater 

and 

Saltwater 

Benthic 

Invertebrates 

(Sediment) 

Freshwater 

Benthic 

Invertebrates 

(Pore water) 

 Saltwate

Benthic 

Invertebra

(Pore wat

Blueberries YesA,C YesA No YesA No No YesA Soybeans & Legumes YesA,C YesA No YesA No No No Cereal (Oats, Barley, and Wheat) 

YesA,C YesA No YesA No No No 

Canola YesA,C YesA No No No No No Pome fruit YesA,C YesA No No No No No 

Risk duration identifiers: A = Acute C = Chronic 
86 

Table 27. Summary of adverse impacts for terrestrial organisms expected from the proposed uses of ben

Proposed Use

Adverse Impacts Expected for Terrestrial Organisms? (No/Yes: A = Acute, C=C

Birds Mammals Piscivorous Birds 

Piscivorous 

Mammals Terrestrial Plants 

Corn YesA YesA,C YesA No No Cucurbits YesA YesA,C YesA No No Tomatoes and Fruiting Vegetables YesA YesA,C YesA No No Grapes YesA YesA,C YesA No No Tubers (Potatoes) YesA YesA,C YesA, No No Peanuts YesA YesA,C YesA No No Nursery Plants, Tomato Transplant, Fruit Transplant, Cucurbit Transplant 

YesA YesA,C YesA No No 

Turf Grass YesA YesA,C No No No Cotton YesA YesA,C YesA No No Blueberries YesA YesA,C YesA No No Soybeans & Legumes YesA YesA,C YesA No No Cereal (Oats, Barley, and Wheat) YesA YesA,C No No No Canola YesA YesA YesA No No Pome fruit YesA YesA,C No No No 

Risk duration identifiers: A = Acute C = Chronic 1 Risk presumed in the absence of acute and chronic oral laraval-stage bee toxicity studies and chronic contact adult bee toxicity study. 
87 

8. REFERENCES 

Sposito, G. 1989. The Chemistry of Soils. Oxford Univ. Press, New York. 

U.S. Environmental Protection Agency 2012. Guidance for Use When Regurgitation is 

Observed in Avian Acute Toxicity Studies with Passerine Species, Office of Prevention, 

Pesticides and Toxic Substances, Office of Pesticide Programs, Environmental Fate and Effects 

Division. April 9, 2012. 

U.S. Environmental Protection Agency 2012. NAFTA Guidance for Evaluating and Calculating 

Degradation Kinetics in Aquatic Media, Office of Prevention, Pesticides and Toxic Substances, 

Office of Pesticide Programs, Environmental Fate and Effects Division. December 17, 2012. 

U.S. Environmental Protection Agency 2014. Surface Water Concentration Calculator User 

Manual, Office of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, 

Environmental Fate and Effects Division. July 1, 2014. 

U.S. Environmental Protection Agency. 2014. Guidance for Assessing Pesticide Risks to Bees. 

Office of Pesticide Programs, Health Canada Pest Management Regulatory Agency, California 

Department of Pesticide Regulation. 

 
88 

Environmental Fate Studies 

P C Code 122305 Benzovindiflupyr Fate Bibliography 

Hydrolysis 

MRID Citation Reference 

48604551 Simmonds, R. (2011) SYN545192 - Aqueous Hydrolysis at 90, 100 and 

120 (Degrees Celsius): Final Report. Project Number: TK0002633/OCR, 

NC/09/021. Unpublished study prepared by Battelle Agrifood, Ltd. 61p. 

162-1 Aerobic soil metabolism 

MRID Citation Reference 

48604492 Lowrie, C.; Phillips, M. (2011) SYN545192 - Rate and Route of 

Degradation of [Carbon 14]-Phenyl Labelled SYN545192 Under Aerobic 

Conditions in One Soil at 20 (Degrees Celsius): Final Report 

Amendment 1. Project Number: T001815/08/OCR, 31530, 214771. 

Unpublished study prepared by Charles River Laboratories. 91p. 

163-1 Leach/adsorption/desorption 

MRID Citation Reference 

49120606 Simmonds, M.; Burgess, M. (2009) SYN524464 - Adsorption Desorption 

of Metabolite [Carbon 14]-CSCC210616: Final Report. Project Number: 

T012282/05/OCR, NC/08/026. Unpublished study prepared by Battelle 

UK Ltd. 95p. 

835.1230 Sediment and soil absorption/desorption for parent and 

degradates 

MRID Citation Reference 

48604505 Wardrope, L. (2010) SYN545192 - Adsorption/Desorption Properties in 

Five Soils: Final Report. Project Number: T001808/08/OCR, 30469, 

808863. Unpublished study prepared by Charles River Laboratories. 

85p. 

835.2110 Hydrolysis as a function of pH 

MRID Citation Reference 
89 

48604402 Stulz, J. (2012) Benzovindiflupyr: Summary Report: Physico-Chemical 

Studies of Pure and Technical Substance (Section 1) for NAFTA 

Submission. Project Number: SYN545192/10198/OCR. Unpublished 

study prepared by Syngenta Crop Protection, AG. 509p. 

835.2120 Hydrolysis of parent and degradates as a function of pH at 25 C 

MRID Citation Reference 

48604402 Stulz, J. (2012) Benzovindiflupyr: Summary Report: Physico-Chemical 

Studies of Pure and Technical Substance (Section 1) for NAFTA 

Submission. Project Number: SYN545192/10198/OCR. Unpublished 

study prepared by Syngenta Crop Protection, AG. 509p. 

48604506 Lowrie, C. (2009) SYN545192 - Hydrolysis in Sterile Buffer at pH 4, 5, 7 

and 9: Final Report. Project Number: T001809/08/OCR, 30389, 214939. 

Unpublished study prepared by Charles River Laboratories. 52p. 

48604539 Stulz, J. (2012) Solatenol (SYN545192): Document M-II, Section 1: 

Identity, Physical and Chemical Properties, Further Information and 

Proposed Classification. Unpublished study prepared by Syngenta Crop 

Protection, LLC. 29p. 

835.2210 Direct photolysis rate in water by sunlight 

MRID Citation Reference 

48604539 Stulz, J. (2012) Solatenol (SYN545192): Document M-II, Section 1: 

Identity, Physical and Chemical Properties, Further Information and 

Proposed Classification. Unpublished study prepared by Syngenta 

Crop Protection, LLC. 29p. 

835.2240 Direct photolysis rate of parent and degradates in water 

MRID Citation Reference 

48604402 Stulz, J. (2012) Benzovindiflupyr: Summary Report: Physico-Chemical 

Studies of Pure and Technical Substance (Section 1) for NAFTA 

Submission. Project Number: SYN545192/10198/OCR. Unpublished 

study prepared by Syngenta Crop Protection, AG. 509p. 

48604507 Wardrope, L. (2011) SYN545192 - Photodegradation in Sterile 

Aqueous Solution: Final Report. Project Number: TK0002647/OCR, 

32108, 808989. Unpublished study prepared by Charles River 

Laboratories. 196p. 

48604539 Stulz, J. (2012) Solatenol (SYN545192): Document M-II, Section 1: 

Identity, Physical and Chemical Properties, Further Information and 

Proposed Classification. Unpublished study prepared by Syngenta 

Crop Protection, LLC. 29p. 

835.2370 Photodegradation of parent and degradates in air 
90 

MRID Citation Reference 

48604402 Stulz, J. (2012) Benzovindiflupyr: Summary Report: Physico-Chemical 

Studies of Pure and Technical Substance (Section 1) for NAFTA 

Submission. Project Number: SYN545192/10198/OCR. Unpublished 

study prepared by Syngenta Crop Protection, AG. 509p. 

48604539 Stulz, J. (2012) Solatenol (SYN545192): Document M-II, Section 1: 

Identity, Physical and Chemical Properties, Further Information and 

Proposed Classification. Unpublished study prepared by Syngenta 

Crop Protection, LLC. 29p. 

835.2410 Photodegradation of parent and degradates in soil 

MRID Citation Reference 

48604495 McCorquodale, G.; White, D. (2012) SYN545192 - Soil Surface 

Photolysis of [Carbon 14]-Phenyl and [Carbon 14]-Pyrazole Labelled 

SYN545192: Final Report. Project Number: TK0002646/OCR, 32453, 

809207. Unpublished study prepared by Charles River Laboratories. 

174p. 

835.4100 Aerobic soil metabolism 

MRID Citation Reference 

48604493 Lowrie, C.; Phillips, M. (2011) SYN545192 - Rate and Route of 

Degradation of (Carbon 14)-Pyrazole Labelled SYN545192 Under 

Aerobic Conditions in Five Soils at 20 (Degrees Celsius): Final 

Report. Project Number: T001814/08/OCR, 31529, 214682. 

Unpublished study prepared by Charles River Laboratories. 156p. 

48604602 Marshall, S.; Nichols, C.; Hand, L. (2012) SYN545192 - Route and 

Rate of Degradation of [Carbon 14]-Pyrazole Labelled SYN545192 in 

Intact Soil Cores: Final Report. Project Number: TK0002662/OCR, 

PM/11/115. Unpublished study prepared by Syngenta Jealotts Hill 

International Research Centre. 74p. 

835.4200 Anaerobic soil metabolism 

MRID Citation Reference 

48604494 McCorquodale, G.; Bell, S. (2011) SYN545192 - Rate and Route of 

Degradation of [Carbon 14]-Phenyl and [Carbon 14]-Pyrazole 

Labelled SYN545192 Under Anaerobic Laboratory Conditions in One 

Soil at 20 (Degrees Celsius): Final Report. Project Number: 

T001816/08/OCR, 30877, 808973. Unpublished study prepared by 

Charles River Laboratories. 108p. 

835.4300 Aerobic aquatic metabolism 
91 

MRID Citation Reference 

48604509 Ferguson, H.; Lowrie, C. (2012) Rate and Route of Degradation of 

[Phenyl-(Carbon 14)]-SYN545192 in Two Sediments at 20 (Degrees 

Celsius): Final Report Amendment 1. Project Number: 

TK0002641/OCR, 32794, 218027. Unpublished study prepared by 

Charles River Laboratories. 310p. 

48604510 Lowrie, C.; Ferguson, H. (2012) SYN545192 - Rate and Route of 

Degradation of [Pyrazole-5-(Carbon 14)]-SYN545192 in Two 

Sediments at 20 (Degrees Celsius): Final Report. Project Number: 

TK0002642/OCR, 32793, 217175. Unpublished study prepared by 

Charles River Laboratories. 320p. 

48604578 Oddy, A.; Simmonds, R. (2012) SYN545192 - Degradation in Aquatic 

Microcosms: Final Report. Project Number: TK0012432/OCR, 

NC/10/047. Unpublished study prepared by Battelle Agrifood, Ltd. 

236p. 

835.4400 Anaerobic aquatic metabolism 

MRI

D Citation Reference 

 

48604509 Ferguson, H.; Lowrie, C. (2012) Rate and Route of Degradation of 

[Phenyl-(Carbon 14)]-SYN545192 in Two Sediments at 20 (Degrees 

Celsius): Final Report Amendment 1. Project Number: 

TK0002641/OCR, 32794, 218027. Unpublished study prepared by 

Charles River Laboratories. 310p. 

48604510 Lowrie, C.; Ferguson, H. (2012) SYN545192 - Rate and Route of 

Degradation of [Pyrazole-5-(Carbon 14)]-SYN545192 in Two 

Sediments at 20 (Degrees Celsius): Final Report. Project Number: 

TK0002642/OCR, 32793, 217175. Unpublished study prepared by 

Charles River Laboratories. 320p. 

835.6100 Terrestrial field dissipation 

MRID Citation Reference 

48604496 Wiepke, T.; Jacobson, B.; Hagan, M. (2012) SYN545192 - 

Dissipation of SYN545192 EC(150) in Soil Applied at Typical 

Fungicide Application Timing in Corn in the Midwestern United 

States: Final Report. Project Number: TK0002575/OCR, T002296/09, 

242/122. Unpublished study prepared by Syngenta Crop Protection. 

318p. 

48604497 Wiepke, T.; Jacobson, B.; Hagan, M.; et al. (2012) SYN545192: 

Dissipation of SYN545192 EC(150) in Soil Under Soybean 
92 

Production Conditions and in a Bare Soil Plot in the Midwestern 

United States: Final Report. Project Number: TK0002574/OCR, 

T002297/09, 242/123. Unpublished study prepared by Syngenta 

Crop Protection, Waterborne Environmental, Inc. and ALS 

Environmental. 526p. 

48604498 Wiepke, T.; Jacobson, B.; Hagan, M. (2012) SYN545192 - 

Dissipation of SYN545192 EC (150) in Soil Under Peanut Production 

Conditions and in a Bare Soil Plot in the Southeastern United States: 

Final Report. Project Number: TK0002573/OCR, T002298/09, 

242/124. Unpublished study prepared by Syngenta Crop Protection, 

Waterborne Environmental, Inc. (WEI) and ALS Environmental. 446p.

48604499 Wiepke, T.; Jacobson, B.; Hagan, M. (2012) SYN545192 - 

Dissipation of SYN545192 EC (150) in Soil Applied at a Typical 

Fungicide Application Timing for Fresh Market Tomatoes in the 

Central Valley of California: Final Report. Project Number: 

TK0002572/OCR, T002299/09, 242/125. Unpublished study 

prepared by Syngenta Crop Protection, Waterborne Environmental, 

Inc. and ALS Environmental. 331p. 

48604502 Harrington, C. (2012) SYN545192 EC (A15457B) - Dissipation Trial 

to Determine Persistence and Leaching Movement of SYN545192 

and its Significant Soil Degradation Products after Application of 

SYN545192 100EC Fungicide: Final Report. Project Number: 

TK0174173/OCR, CER/05908/11, 12SYN3092/REP. Unpublished 

study prepared by Syngenta Canada, Inc., and ALS Environmental. 

401p. 

48604504 Wiepke, T.; Hagan, M.; Bertrand, N. (2012) Stability of SYN545192 in 

Soil Under Freezer Storage Conditions: Final Report Amendment 1. 

Project Number: TK0002513/OCR, 11SYN291/REP. Unpublished 

study prepared by ALS Environmental and Syngenta Crop 

Protection, LLC. 142p. 

48604511 Simmons, D.; Jacobson, B.; Herczog, K. et al. (2012) SYN545192 - 

Dissipation of (Carbon 14)-SYN545192 EC Formulation in a Bare 

Soil Plot Under Field Conditions: Final Report. Project Number: 

TK0002514/OCR, 796/21, 026407. Unpublished study prepared by 

Waterborne Environmental, Inc. (WEI), Ricerca Biosciences, LLC 

and Syngenta Crop Protection LLC. 305p. 

48604580 Wiepke, T.; Jacobson, B.; Neely, M. (2012) SYN545192 - Dissipation 

of SYN545192 EC (150) in a Warm-Season Turf in the Central Valley 

of California: Final Report. Project Number: TK0019552/OCR, 

796/20, 1390/011. Unpublished study prepared by MPI Research 

State College, Waterborne Environmental, Inc. (WEI) and Syngenta 

Crop Protection, LLC. 416p. 

48604581 Wiepke, T.; Jacobson, B.; Hagan, M.; et al. (2012) SYN545192 - 

Dissipation of SYN545192 EC (150) in a Cool-Season Turf and in 

Bare Soil in the Finger Lakes Region of New York: Final Report. 

Project Number: TK0019550/OCR, 796/19, 11SYN280/REP. 

Unpublished study prepared by Waterborne Environmental, Inc. 

(WEI), ALS Environmental and Syngenta Crop Protection, LLC. 
93 

791p. 

48604582 Dharmasri, C.; Hagan, M.; Bertrand, N. (2012) SYN545192 - Stability 

of SYN545192 in Turf Grass Clippings, Thatch-Sod and Soil Under 

Freezer Storage Conditions: Final Report. Project Number: 

TK0019549/OCR, 11SYN292/REP. Unpublished study prepared by 

Syngenta Crop Protection, LLC and ALS Environmental. 215p. 

Ecological Effects Studies

122305 Benzovindiflupyr (Solatenol) Eco Effects Bibliography 

Compiled 1 May 2014 

850.1010 Aquatic invertebrate acute toxicity, test, freshwater daphnids 

MRID Citation Reference 

48604522 Fournier, A. (2012) SYN545192 - Acute Toxicity to Water Fleas (Daphnia 

magna) Under Static Conditions: Final Report Amendment 1. Project Number: 

T000872/08/OCR, 1781/6723. Unpublished study prepared by Smithers 

Viscient Laboratories. 43p. 

48604546 Liedtke, A. (2012) SYN546039 - Acute Toxicity to Daphnia magna in a 48-Hour 

Immobilization Test: Final Report. Project Number: TK0054003/OCR, D46513. 

Unpublished study prepared by Harlan Laboratories Ltd. 44p. 

850.1025 Oyster acute toxicity test (shell deposition) 

MRID Citation Reference 

48604537 York, D. (2010) SYN545192 - Toxicity to Eastern Oyster (Crassostrea virginica) 

Under Flow-Through Conditions: Final Report. Project Number: 

TK0002601/OCR, 1781/6750. Unpublished study prepared by Smithers 

Viscient Laboratories. 52p. 

850.1035 Mysid acute toxicity test 

MRID Citation Reference 

48604535 Fournier, A. (2010) SYN545192 - Acute Toxicity to Mysid (Americamysis 

bahia), Under Static Conditions: Final Report. Project Number: 

T000874/08/OCR, 1781/6726. Unpublished study prepared by Springborn 

Smithers Laboratories. 41p. 

850.1075 Fish acute toxicity test, freshwater and marine 
94 

MRID Citation Reference 

48604518 Fournier, A. (2010) SYN545192 - Acute Toxicity to Rainbow Trout 

(Oncorhynchus mykiss) Under Flow-Through Conditions: Final Report. Project 

Number: T000867/08/OCR, 1781/6719. Unpublished study prepared by 

Springborn Smithers Laboratories. 40p. 

48604519 Fournier, A. (2010) SYN545192 - Acute Toxicity to Fathead Minnow 

(Pimephales promelas) Under Flow-Through Conditions: Final Report. Project 

Number: T000869/08/OCR, 1781/6722. Unpublished study prepared by 

Springborn Smithers Laboratories. 41p. 

48604534 Fournier, A. (2010) SYN545192 - Acute Toxicity to Sheepshead Minnow 

(Cyprinodon variegates) Under Flow-Through Conditions: Final Report. Project 

Number: T000870/08/OCR, 1781/6720. Unpublished study prepared by 

Springborn Smithers Laboratories. 40p. 

48604545 Liedtke, A. (2012) SYN546039: Acute Toxicity to Rainbow Trout 

(Oncorhynchus mykiss) in a 96-Hour Test: Final Report. Project Number: 

TK0054004/OCR, D46502. Unpublished study prepared by Harlan Laboratories 

Ltd. 47p. 

48604562 Fournier, A. (2010) SYN545192 - Acute Toxicity to Carp (Cyprinus carpio) 

Under Flow-Through Conditions: Final Report. Project Number: 

T000868/08/OCR, 1781/6721. Unpublished study prepared by Springborn 

Smithers Laboratories. 41p. 

850.1300 Daphnid chronic toxicity test 

MRID Citation Reference 

48604523 Fournier, A. (2010) SYN545192 - Full Life-Cycle Toxicity Test with Water Fleas, 

Daphnia magna, Under Static-Renewal Conditions: Final Report. Project 

Number: T000873/08/OCR, 1781/6724. Unpublished study prepared by 

Springborn Smithers Laboratories. 56p. 

850.1350 Mysid chronic toxicity test 

MRID Citation Reference 

 

48604536 Lee, M. (2011) SYN545192 - Life-Cycle Toxicity Test with Mysids 

(Americamysis bahia): Final Report. Project Number: TK0002657/OCR, 

1781/6760. Unpublished study prepared by Smithers Viscient Laboratories. 

99p. 

850.1400 Fish early-life stage toxicity test 
95 

MRID Citation Reference 

48604520 York, D. (2010) SYN545192 - Early Life-Stage Toxicity Test with Fathead 

Minnow (Pimephales promelas): Final Report. Project Number: 

T000871/08/OCR, 1781/6718. Unpublished study prepared by Springborn 

Smithers Laboratories. 53p. 

850.1730 Fish BCF 

MRID Citation Reference 

48604521 York, D.; Lentz, N. (2012) SYN545192 - Fish Bioconcentration Test with 

Bluegill Sunfish (Lepomis macrochirus): Final Report Amendment 1. Project 

Number: T001888/08/OCR, 1781/6714. Unpublished study prepared by 

Smithers Viscient Laboratories. 78p. 

850.2100 Avian acute oral toxicity test 

MRID Citation Reference 

48604512 Hubbard, P.; Beavers, J. (2011) SYN545192 - An Acute Oral Toxicity Study 

with the Northern Bobwhite: Final Report. Project Number: TK0013012/OCR, 

528/363. Unpublished study prepared by Wildlife International, Ltd. 59p. 

48604513 Hubbard, P.; Beavers, J. (2011) SYN545192 - An Acute Oral Toxicity Study 

with the Zebra Finch (Taeniopygia guttata): Final Report. Project Number: 

TK0002594/OCR, 528/365. Unpublished study prepared by Wildlife 

International, Ltd. 58p. 

48604598 Hubbard, P.; Beavers, J. (2009) SYN545192 - An Acute Oral Toxicity Study 

with the Northern Bobwhite Using a Sequential Testing Procedure: Final 

Report. Project Number: T000876/08/OCR, 528/286. Unpublished study 

prepared by Wildlife International Ltd. 59p. 

49251501 Wildlife International Evans Analytical Group (2013) SYN545192 - AN LC Study 

Using Dietary Exposure with the Zebra Finch. Project Number: 528/XXX, 

TK0153778. Unpublished study. 15p. 

850.2200 Avian dietary toxicity test 

MRID Citation Reference 

48604514 Hubbard, P.; Martin, K.; Beavers, J. (2010) SYN545192 - A Dietary LC(50) 

Study with the Mallard: Final Report. Project Number: TK0002597/OCR, 

528/321. Unpublished study prepared by Wildlife International, Ltd. 67p. 

48604515 Hubbard, P.; Martin, K.; Beavers, J. (2010) SYN545192 - A Dietary LC(50) 

Study with the Northern Bobwhite: Final Report. Project Number: 
96 

TK0002598/OCR, 528/320. Unpublished study prepared by Wildlife 

International, Ltd. 67p. 

49251501 Wildlife International Evans Analytical Group (2013) SYN545192 - AN LC Study 

Using Dietary Exposure with the Zebra Finch. Project Number: 528/XXX, 

TK0153778. Unpublished study. 15p. 

850.2300 Avian reproduction test 

MRID Citation Reference 

48604516 Frey, L.; Martin, K.; Beavers, J. et al. (2011) SYN545192 - A Reproduction 

Study with the Mallard: Final Report Amendment 1. Project Number: 

TK0002595/OCR, 528/324. Unpublished study prepared by Wildlife 

International, Ltd. 201p. 

48604517 Frey, L.; Martin, K.; Beavers, J. et al. (2011) SYN545192 - A Reproduction 

Study with the Northern Bobwhite: Final Report Amendment 1. Project Number: 

TK0002596/OCR, 528/323. Unpublished study prepared by Wildlife 

International, Ltd. 205p. 

850.3020 Honey bee acute contact toxicity 

MRID Citation Reference 

48604527 Kling, A. (2008) SYN545192 - Acute Oral and Contact Toxicity to the Honeybee 

Apis mellifera L. in the Laboratory: Final Report. Project Number: 

T000875/08/OCR, S08/02807, S08/02807/L1/BLEU. Unpublished study 

prepared by Eurofins - GAB GmbH. 32p. 

141-2 Honey bee residue on foliage 

MRID Citation Reference 

48604528 Stevens, J. (2011) SYN545192 EC (A17056F) - A Rate-Response Laboratory 

Bioassay of the Effects of Fresh Residues on the Parasitic Wasp Aphidius 

rhopalosiphi (Hymenoptera, Braconidae): Final Report. Project Number: 

TK0013031/OCR, SYN/11/8. Unpublished study prepared by Mambo-Tox Ltd. 

30p. 

850.4150 Terrestrial plant toxicity, Tier 1 (vegetative vigor) 

MRID Citation Reference 

 

48604599 Porch, J.; Martin, K.; Krueger, H. (2011) SYN545192 EC (A17056F) - 

Toxicity Effects on the Vegetative Vigor of Ten Species of Plants: Final 

Report. Project Number: TK0013028/OCR, 528/359. Unpublished study 
97 

prepared by Wildlife International Ltd. 81p. 

850.4225 Seedling emergence, Tier II 

MRID Citation Reference 

 

48604538 Porch, J.; Martin, K.; Krueger, H.; et al. (2011) SYN545192 EC (A17056F) - 

Toxicity Effects on the Seedling Emergence of Ten Species of Plants: Final 

Report. Project Number: TK0058662/OCR, 528/358. Unpublished study 

prepared by Wildlife International Ltd. 127p. 

850.4400 Aquatic plant toxicity test using Lemna spp. Tiers I and II 

MRID Citation Reference 

48604526 Softcheck, K. (2011) SYN545192 - 7-Day Toxicity Test with Duckweed (Lemna 

gibba): Final Report. Project Number: TK0002658/OCR, 1781/6749. 

Unpublished study prepared by Smithers Viscient Laboratories. 70p. 

850.5400 Algal toxicity, Tiers 1 and II 

MRID Citation Reference 

48604524 Softcheck, K. (2010) SYN545192 - 96-Hour Toxicity Test with the Freshwater 

Green Alga, Pseudokirchneriella subcapitata: Final Report. Project Number: 

T001181/08/OCR, 1781/6725. Unpublished study prepared by Springborn 

Smithers Laboratories. 61p. 

48604547 Liedtke, A. (2012) SYN546039 - Toxicity to Pseudokirchneriella subcapitata in a 

96-Hour Algal Growth Inhibition Test: Final Report. Project Number: 

TK0054002/OCR, D46480. Unpublished study prepared by Harlan Laboratories 

Ltd. 56p. 

48604550 Softcheck, K. (2011) SYN545192 - 96-Hour Toxicity Test with the Marine 

Diatom, Skeletonema costatum: Final Report. Project Number: 

TK0058664/OCR, 1781/6805. Unpublished study prepared by Smithers 

Viscient Laboratories. 66p. 

850.6200 Earthworm subchronic toxicity test 

MRID Citation Reference 

48604532 Friedrich, S. (2011) SYN545192 - Sublethal Toxicity to the Earthworm Eisenia 

fetida in Artificial Soil with 5% Peat: Final Report. Project Number: 

TK0058663/OCR, 11/10/48/069/S. Unpublished study prepared by Biochem 

Agrar, Labor fuer Biologische und Chemische. 36p. 
98 

48604533 Friedrich, S. (2008) CSCD465008 - Sublethal Toxicity to the Earthworm Eisenia 

fetida: Final Report. Project Number: T000614/08/OCR, 08/10/48/025/S. 

Unpublished study prepared by Biochem Agrar, Labor fuer Biologische und 

Chemische. 25p. 

850.7100 Data reporting for environmental chemistry methods 

MRID Citation Reference 

48604557 Amic, S. (2012) SYN545192 - Independent Laboratory Validation of Residue 

Method GRM042.02A for the Determination of SYN545192 in Soil: Method 

Validation. Project Number: TK0002570/OCR, S11/03840, GRM042/02A. 

Unpublished study prepared by ADME Bioanalyses. 46p. 

48604560 Braid, S.; Wiesner, F.; Breyer, N. (2012) SYN545192 - Analytical Method 

GRM042.05A for the Determination of SYN545192 and its Metabolite 

SYN546206 in Soil. Project Number: T001407/08/OCR, GRM042/05A. 

Unpublished study prepared by Jealott''s Hill Res. Station. 80p. 

850.1735 Whole sediment: acute freshwater invertebrates 

MRID Citation Reference 

48604583 Picard, C. (2012) SYN545192 - 28-Day Toxicity Test Exposing Estuarine 

Amphipods (Leptocheirus plumulosus) to Spiked Sediment: Final Report. 

Project Number: TK0053449/OCR, 1781/6806. Unpublished study prepared by 

Smithers Viscient Laboratories. 92p. 

48286201 Benyon, K. (2010) SYN545192: Toxicity Test with Sediment-Dwelling Midges 

(Chironomus riparius) Under Static Conditions, Using Spiked Sediment. Project 

Number: TK0013014, 1781/6759, 090110/OECD/MIDGE/SPIKED/SEDIMENT. 

Unpublished study prepared by Springborn Smithers Laboratories. 12 p. 

Non-Guideline 

 

48286301 Benyon, K. (2010) Syn545192 - 28-Day Toxicity Test Exposing Estuarine 

Amphipods (Leptocheirus plumulosus) to a Test Substance Applied to 

Sediment Following EPA Test Methods. Project Number: 

101008/EPA/28/D/LEPTOCHEIRUS. Unpublished study prepared by 

Springborn Smithers Laboratories. 12 p. 

48415801 Hubbard, P. (2011) SYN545192- An Acute Oral Toxicity Study with the Canary 

using a Sequential Testing Procedure: Protocol. Project Number: Syngenta 

Study Number, 582/021811/CLD/Seq/SUB528. Unpublished study prepared by 

Wildlife International, Ltd. 23 

48604529 Fallowfield, L. (2011) SYN545192 EC (A17056F) - A Rate-Response 

Laboratory Bioassay of the Effects of Fresh Residues on the Predatory Mite, 

Typhlodromus pyri (Acari - Phytoseiidae): Final Report. Project Number: 
99 

TK0013029/OCR, SYN/11/7. Unpublished study prepared by Mambo-Tox Ltd. 

30p. 

48604541 Peffer, R.; Hofstra, A.; Parsons, P. (2012) Solatenol (SYN545192): Document 

M-II, Section 3: Toxicological Studies. Unpublished study prepared by 

Syngenta Crop Protection, LLC. 508p. 

48604569 Stevens, J. (2012) Benzovindiflupyr EC (A15457H) A Rate-Response Extended 

Laboratory Bioassay of the Effects of Fresh Residues on the Parasitic Wasp 

Aphidius rhopalosiphi (Hymenoptera, Braconidae): Final Report. Project 

Number: TK0013057/OCR, SYN/12/14. Unpublished study prepared by 

Mambo-Tox Ltd. 38p. 

48640917 Ueckermann, A. (2012) A15457B: Details of SYN545192 Solo Formulations 

Used in Regulatory Studies Submitted in NAFTA Joint Review Benzovindiflupyr 

Dossier (November 2012). Project Number: A15457B/50090/OCR. 

Unpublished study prepared by Syngenta Crop Protection, LLC. 5p. 

49070301 Ueckermann, A.; Rezaaiyan, R.; Sanchez, U. (2013) Syngenta Response to 

COFEPRIS, EPA and PMRA Deficiencies Noted During Completeness Check 

for NAFTA Joint Review of Benzovindiflupyr Technical and Seven Associated 

End-Use Products - A15457TO Fungicide, A15457 Fungicide, Mural Fungicide, 

A18126 Fungicide, A18993 Fungicide, A19334 Fungicide and Ascenity 

Fungicide. Project Number: TK0180690. Unpublished study prepared by 

Syngenta Crop Protection, LLC. 56p. 

49070501 Lorez, C. (2013) Solatenol (SYN545192) - Toxicological and Metabolism 

Studies and Their Use in Determination of the ADI. Project Number: 

TK0180689/OCR. Unpublished study prepared by Syngenta Crop Protection, 

AG. 11p. 

MRID Citation Reference 

D417315 Stevens, J. (2011) SYN545192 EC (A17056F) - A Rate-Response Laboratory 

Bioassay of the Effects of Fresh Residues on the Parasitic Wasp Aphidius 

rhopalosiphi (Hymenoptera, Braconidae): Final Report. Project Number: 

TK0013031/OCR, SYN/11/8. Unpublished study prepared by Mambo-Tox Ltd. 

30p. 
100 

Appendix A. The Risk Quotient Method and Levels of Concern 

The Risk Quotient Method is the means by which the Environmental Fate and Effects Division (EFED) integrates 

the results of exposure and ecotoxicity data. In this method, both acute and chronic risk quotients (RQs) are 

calculated by dividing exposure estimates by the most sensitive ecotoxicity values or toxicity endpoints derived 

from the studies. Calculated RQs are then compared to OPP's levels of concern (LOCs). The LOCs are the criteria 

used by OPP to indicate potential risk to non-target organisms and the need to consider regulatory action. EFED has 

defined LOCs for acute risk, potential restricted use, and for endangered species. Risk presumptions, along with the 

corresponding RQs and LOCs are summarized in the table below. 

These LOCs are criteria used by EFED to indicate potential risk to non-target organisms and the need to consider 

regulatory action. The criteria indicate that a pesticide used as directed has the potential to cause adverse effects on 

non-target organisms. LOCs currently address the following risk presumption categories: (1) acute – potential for 

acute risk is high, regulatory action may be warranted in addition to restricted use classification (2) acute restricted 

use - potential for acute risk is high, but this may be mitigated through restricted use classification (3) acute 

endangered species – the potential for acute risk to endangered species is high, regulatory action may be warranted, 

and (4) chronic risk - the potential for chronic risk high, regulatory action may be warranted. Currently, EFED 

does not perform assessment for chronic risk to plants, acute or chronic risks to non-target insects or chronic risks 

from granular/bait formulations to mammalian or avian species. 

The ecotoxicity test values (i.e., measurement endpoints) used in the acute and chronic risk quotients are derived 

from the results of required studies. Examples of ecotoxicity values derived from results of short-term laboratory 

studies that assess acute effects are (1) LC50 (fish and birds), (2) LD50 (birds and mammals), (3) EC50 (aquatic plants 

and aquatic invertebrates, and (4) EC25 (terrestrial plants). An example of a toxicity test effect level derived from 

the results of a long-term laboratory study that assesses chronic effects is (1) NOAEC (birds, fish, and aquatic 

invertebrates). 

Risk Presumption RQ LOC 

Birds 

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

 Acute Restricted Use EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50 

mg/kg) 

0.2 

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

 Chronic Risk EEC/NOAEC 1 

Mammals 

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

 Acute Restricted Use EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50 

mg/kg) 

0.2 

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

 Chronic Risk EEC/NOAEC 1 

Aquatic Animals 

 Acute Risk EEC/LC50 or EC50 0.5 

 Acute Restricted Use EEC/LC50 or EC50 0.1 

 Acute Endangered Species EEC/LC50 or EC50 0.05 

 Chronic Risk EEC/NOAEC 1 

Terrestrial and Semi-Aquatic Plants 

 Acute Risk EEC/EC25 1 

 Acute Endangered Species EEC/EC05 or NOAEC 1 

Aquatic Plants 

 Acute Risk EEC/EC50 1 

 Acute Endangered Species EEC/EC05 or NOAEC 1 
101 

Appendix B. Output of T-REX 

Example from Corn 

Chemical Name: Solatenol 

 Use 1 

 Formulation 0 

Application Rate 0.068 

lbs 

a.i./acre

Half-life 10.9 days 

Application Interval 7 days 

Maximum # Apps./Year 4 

Length of Simulation 1 year 

Variable application rates? no 

Endpoints 

Avian 

zebra finch LD50 (mg/kg-bw) 10.00 

Bobwhite quail LC50 (mg/kg-diet) 6390.00 

Bobwhite quail NOAEL(mg/kg-bw) 0.00 

Mallard duck NOAEC (mg/kg-diet) 59.40 

 

Mammals 

LD50 (mg/kg-bw) 66.30 

LC50 (mg/kg-diet) 0.00 

NOAEL (mg/kg-bw) 8.20 

NOAEC (mg/kg-diet) 164.00 
102 

Dietary-based EECs 

(ppm)

Kenaga 

Values 

Short Grass 37.77 

Tall Grass 17.31 

Broadleaf plants 21.25 

Fruits/pods/seeds 2.36 

Arthropods 14.79 

Avian Body 

Ingestion 

(Fdry) 

Ingestion 

(Fwet) % body wgt FI 

Class Weight (g) (g bw/day) (g/day) consumed (kg-diet/day) 

Small 20 5 23 114 2.28E-02 

Mid 100 13 65 65 6.49E-02 

Large 1000 58 291 29 2.91E-01 

 20 5 5 25 5.06E-03 

Granivores 100 13 14 14 1.44E-02 

 1000 58 65 6 6.46E-02 

Avian Body Adjusted LD50 

Weight (g) (mg/kg-bw) 

20 10.67 

100 13.58 

1000 19.18 

Dose-based EECs (mg/kg-bw)

Avian Classes and Body Weights (grams) 

small mid large 

20 100 1000 

Short Grass 43.02 24.53 10.98 

Tall Grass 19.72 11.24 5.03 

Broadleaf plants 24.20 13.80 6.18 

Fruits/pods 2.69 1.53 0.69 

Arthropods 16.85 9.61 4.30 

Seeds 0.60 0.34 0.15 
103 

Dose-based RQs 

(Dose-based EEC/adjusted LD50)

Avian Acute RQs 

Size Class (grams) 

20 100 1000 

Short Grass 4.03 1.81 0.57 

Tall Grass 1.85 0.83 0.26 

Broadleaf plants 2.27 1.02 0.32 

Fruits/pods 0.25 0.11 0.04 

Arthropods 1.58 0.71 0.22 

Seeds 0.06 0.03 0.01 

Dietary-based RQs 

(Dietary-based EEC/LC50 or 

NOAEC)

RQs 

 

 Acute Chronic 

Short Grass 0.01 0.64 

Tall Grass 0.00 0.29 

Broadleaf plants 0.00 0.36 

Fruits/pods/seeds 0.00 0.04 

Arthropods 0.00 0.25 

Mammalian Body 

Ingestion 

(Fdry) 

Ingestion 

(Fwet) % body wgt FI 

Class Weight (g bwt/day) (g/day) consumed (kg-diet/day) 

 15 3 14 95 1.43E-02 

Herbivores/ 35 5 23 66 2.31E-02 

insectivores 1000 31 153 15 1.53E-01 

 15 3 3 21 3.18E-03 

Grainvores 35 5 5 15 5.13E-03 

 1000 31 34 3 3.40E-02 

Mammalian Body Adjusted Adjusted 

Class Weight LD50 NOAEL 

 15 145.72 18.02 

Herbivores/ 35 117.90 14.58 

insectivores 1000 51.00 6.31 

 15 145.72 18.02 

Granivores 35 117.90 14.58 

 1000 51.00 6.31 
104 

Dose-Based EECs 

(mg/kg-bw)

Mammalian Classes and Body weight 

(grams) 

15 35 1000 

Short Grass 36.01 24.89 5.77 

Tall Grass 16.50 11.41 2.64 

Broadleaf plants 20.26 14.00 3.25 

Fruits/pods 2.25 1.56 0.36 

Arthropods 14.10 9.75 2.26 

Seeds 0.50 0.35 0.08 

Dose‐based

RQs        

(Dose‐based

EEC/LD50 or

NOAEL) Small mammal Medium mammal Large mammal

15 grams 35 grams 1000 grams

Acute Chronic Acute     Chronic Acute     Chronic

Short Grass   0.247128 1.998121 0.211095 1.706782 0.113155 0.914902

Tall Grass 0.113267 0.915805 0.096752 0.782275 0.051863 0.41933

Broadleaf

plants 0.13901 1.123943 0.118741 0.960065 0.06365 0.514633

Fruits/pods 0.015446 0.124883 0.013193 0.106674 0.007072 0.057181

Arthropods 0.096792 0.782597 0.082679 0.66849 0.044319 0.358337

Seeds 0.003432 0.027752 0.002932 0.023705 0.001572 0.012707

Dietary-based RQs 

(Dietary-based EEC/LC50 or 

NOAEC)

Mammal RQs 

 

Acute Chronic 

Short Grass #DIV/0! 0.23 

Tall Grass #DIV/0! 0.11 

Broadleaf plants #DIV/0! 0.13 

Fruits/pods/seeds #DIV/0! 0.01 

Arthropods #DIV/0! 0.09 
105 

Appendix C. Kow (based) Aquatic Bioaccumulation Model Output using 

Corn scenario 

Table C-1. Estimated concentrations of Solatenol in ecosystem components. 

Ecosystem Component 

Total 

concentration 

(μg/kg-ww) 

Lipid 

normalized 

concentration 

(μg/kg-lipid) 

Contribution 

due to diet 

(μg/kg-ww) 

Contribution 

due to 

respiration 

(μg/kg-ww) 

Water (total)* 7 N/A N/A N/A

Water (freely dissolved)* 7 N/A N/A N/A

Sediment (pore water)* 6 N/A N/A N/A

Sediment (in solid)** 1,148 N/A N/A N/A

Phytoplankton 6,603 330168 N/A 6,603.36

Zooplankton 4,884 162816 32.11 4,852.36

Benthic Invertebrates 5,348 178278 88.18 5,260.16

Filter Feeders 3,517 175856 56.82 3,460.30

Small Fish 7,079 176973 346.88 6,732.03

Medium Fish 7,347 183675 662.91 6,684.10

Large Fish 7,877 196923 1,229.40 6,647.50

* Units: μg/L; **Units: μg/kg-dw 

Table C-2. Total BCFand BAF values of Solatenol in 

aquatic trophic levels. 

Trophic Level 

Total BCF 

(μg/kgww)/(μg/L) 

Total BAF 

(μg/kgww)/(μg/L) 

Phytoplankton 959 929 

Zooplankton 683 687 

Benthic Invertebrates 742 752 

Filter Feeders 488 495 

Small Fish 955 996 

Medium Fish 955 1033 

Large Fish 959 1108 
106 

Table C-3. Lipid-normalized BCF, BAF, BMF and BSAF values of Solatenol in aquatic 

trophic levels. 

Trophic Level 

BCF 

(μg/kglipid)/(μg/L) 

BAF 

(μg/kglipid)/(μg/L) 

BMF 

(μg/kglipid)/(μg/kglipid) 

BSAF 

(μg/kglipid)/(μg/kgOC) 

Phytoplankton 47931 46437 N/A 12 

Zooplankton 22774 22900 0.49 6 

Benthic Invertebrates 24744 25074 1.10 6 

Filter Feeders 24414 24734 1.08 6 

Small Fish 23868 24891 1.04 6 

Medium Fish 23868 25833 1.03 6 

Large Fish 23986 27697 1.07 7 

Table C-4. Calculation of EECs for mammals and birds consuming fish contaminated by 

Solatenol. 

Wildlife Species 

Biological Parameters 

EECs (pesticide 

intake) 

Body 

Weight 

(kg) 

Dry Food 

Ingestion 

Rate (kgdry food/kgbw/day) 

Wet Food 

Ingestion 

Rate (kgwet 

food/kgbw/day) 

Drinking 

Water 

Intake 

(L/d) 

Dose 

Based 

(mg/kgbw/d) 

Dietary 

Based 

(ppm) 

Mammalian 

fog/water shrew 0.02 0.140 0.585 0.003 3.131 5.35 

rice rat/starnosed mole 0.1 0.107 0.484 0.011 2.573 5.32 

small mink 0.5 0.079 0.293 0.048 2.156 7.35 

large mink 1.8 0.062 0.229 0.168 1.684 7.35 

small river otter 5.0 0.052 0.191 0.421 1.404 7.35 

large river otter 15.0 0.042 0.157 1.133 1.238 7.88 

Avian 

sandpipers 0.0 0.228 1.034 0.004 5.5144 5.33 

cranes 6.7 0.030 0.136 0.211 0.7373 5.42 

rails 0.1 0.147 0.577 0.010 3.5885 6.21 

herons 2.9 0.040 0.157 0.120 0.9994 6.35 
107 

Table C-4. Calculation of EECs for mammals and birds consuming fish contaminated by 

Solatenol. 

Wildlife Species 

Biological Parameters 

EECs (pesticide 

intake) 

Body 

Weight 

(kg) 

Dry Food 

Ingestion 

Rate (kgdry food/kgbw/day) 

Wet Food 

Ingestion 

Rate (kgwet 

food/kgbw/day) 

Drinking 

Water 

Intake 

(L/d) 

Dose 

Based 

(mg/kgbw/d) 

Dietary 

Based 

(ppm) 

small osprey 1.3 0.054 0.199 0.069 1.4654 7.35 

white pelican 7.5 0.029 0.107 0.228 0.8407 7.88 

Table C-5. Calculation of toxicity values for mammals and birds 

consuming fish contaminated by Solatenol. 

Wildlife Species 

Toxicity Values 

Acute Chronic 

Dose 

Based 

(mg/kgbw) 

Dietary 

Based 

(mg/kg-diet) 

Dose Based 

(mg/kg-bw) 

Dietary 

Based 

(mg/kgdiet) 

Mammalian 

fog/water shrew 115.49 N/A 16.38 156 

rice rat/starnosed mole 78.35 N/A 11.11 156 

small mink 51.65 N/A 7.33 156 

large mink 36.52 N/A 5.18 156 

small river otter 28.29 N/A 4.01 156 

large river otter 21.50 N/A 3.05 156 

Avian 

sandpipers 15.07 6390.00 N/A 59.4 

cranes 36.04 6390.00 N/A 59.4 

rails 18.18 6390.00 N/A 59.4 

herons 31.79 6390.00 N/A 59.4 
108 

Table C-5. Calculation of toxicity values for mammals and birds 

consuming fish contaminated by Solatenol. 

Wildlife Species 

Toxicity Values 

Acute Chronic 

Dose 

Based 

(mg/kgbw) 

Dietary 

Based 

(mg/kg-diet) 

Dose Based 

(mg/kg-bw) 

Dietary 

Based 

(mg/kgdiet) 

small osprey 28.02 6390.00 N/A 59.4 

white pelican 36.66 6390.00 N/A 59.4 

Table C-6. Calculation of RQ values for mammals and birds consuming 

fish contaminated by Solatenol. 

Wildlife Species 

Acute Chronic 

Dose 

Based 

Dietary 

Based 

Dose Based Dietary 

Based 

Mammalian 

fog/water shrew 0.027 N/A 0.191 0.034 

rice rat/starnosed mole 0.033 N/A 0.232 0.034 

small mink 0.042 N/A 0.294 0.047 

large mink 0.046 N/A 0.325 0.047 

small river otter 0.050 N/A 0.350 0.047 

large river otter 0.058 N/A 0.406 0.050 

Avian 

sandpipers 0.366 0.001 N/A 0.090 

cranes 0.020 0.001 N/A 0.091 

rails 0.197 0.001 N/A 0.105 

herons 0.031 0.001 N/A 0.107 

small osprey 0.052 0.001 N/A 0.124 

white pelican 0.023 0.001 N/A 0.133 
109 

Appendix D. Terrplant. 

Table 1. Chemical Identity. 

Chemical Name 

PC code 122305 

Use Cucurbits 

Application Method 

Application Form 

Solubility in Water (ppm) 2.1 

 

Table 2. Input parameters used to derive EECs. 

Input Parameter Symbol Value Units 

Application Rate A 0.068 y 

Incorporation I 1 none 

Runoff Fraction R 0.01 none 

Drift Fraction D 0.01 none 

 

Table 3. EECs for . Units in y. 

Description Equation EEC 

Runoff to dry areas (A/I)*R 0.00068 

Runoff to semi-aquatic areas (A/I)*R*10 0.0068 

Spray drift A*D 0.00068 

Total for dry areas ((A/I)*R)+(A*D) 0.00136 

Total for semi-aquatic areas ((A/I)*R*10)+(A*D) 0.00748 

 

Table 4. Plant survival and growth data used for RQ derivation. Units are in y. 

 Seedling Emergence Vegetative Vigor 

Plant type EC25 NOAEC EC25 NOAEC 

Monocot 0.089 0.089 x 0.09 

Dicot 0.089 0.089 x 0.09 

 

Table 5. RQ values for plants in dry and semi-aquatic areas exposed to through runoff and/or spray drift.* 

Plant Type Listed Status Dry Semi-Aquatic Spray Drift 

Monocot non-listed <0.1 <0.1 <0.1 

Monocot listed <0.1 <0.1 <0.1 

Dicot non-listed <0.1 <0.1 <0.1 

Dicot listed <0.1 <0.1 <0.1 

*If RQ > 1.0, the LOC is exceeded, resulting in potential for risk to that plant group. 
110 

Appendix E. Sample SWCC Output File 

Summary of Water Modeling of Solatenol and the USEPA Standard 

Pond 

Estimated Environmental Concentrations for Solatenol are presented in Table 1 for the USEPA standard pond with 

the MEpotatoSTD field scenario. A graphical presentation of the year-to-year peaks is presented in Figure 1. These 

values were generated with the Surface Water Concentration Calculator (SWCC Version 1.106). Critical input 

values for the model are summarized in Tables 2 and 3. 

This model estimates that about 4.1% of Solatenol applied to the field eventually reaches the water body. The main 

mechanism of transport from the field to the water body is by erosion (43.4% of the total transport), followed by 

spray drift (30.4%) and runoff (26.2%). 

In the water body, pesticide dissipates with an effective water column half-life of 4638.4 days. (This value does not 

include dissipation by transport to the benthic region; it includes only processes that result in removal of pesticide 

from the complete system.) The main source of dissipation in the water column is metabolism (effective average 

half-life = 6781.9 days) followed by photolysis (14682.8 days) and volatilization (2.905305E+07 days). 

In the benthic region, pesticide dissipation is negligible (2106.6 days). The main source of dissipation in the benthic 

region is metabolism (effective average half-life = 2106.6 days). The vast majority of the pesticide in the benthic 

region (99.79%) is sorbed to sediment rather than in the pore water. 

Table 1. Estimated Environmental Concentrations (ppb) for Solatenol. 

Peak (1-in-10 yr) 8.71 

4-day Avg (1-in-10 yr) 8.46 

21-day Avg (1-in-10 yr) 8.17 

60-day Avg (1-in-10 yr) 7.91 

365-day Avg (1-in-10 yr) 7.71 

Entire Simulation Mean 5.71 

Table 2. Summary of Model Inputs for Solatenol. 

Scenario MEpotatoSTD 

Cropped Area Fraction 1 

Koc (ml/g) 4478 

Water Half-Life (days) @ 20 °C 2920 

Benthic Half-Life (days) @ 20 °C 907 

Photolysis Half-Life (days) @ 45 °Lat 88.4 

Hydrolysis Half-Life (days) 0 

Soil Half-Life (days) @ 20 °C 1460 

Foliar Half-Life (days) 0 

Molecular Wt 398.2 

Vapor Pressure (torr) 2.4e-11 
111 

Solubility (mg/l) 0.98 

Table 3. Application Schedule for Solatenol. 

Date (Mon/Day) Type Amount (kg/ha) Eff. Drift 

8/15 Foliar 0.076 0.95 0.125 

8/22 Foliar 0.076 0.95 0.125 

8/29 Foliar 0.076 0.95 0.125 

9/5 Foliar 0.076 0.95 0.125 

Figure 1. Yearly Peak Concentrations 
112 

Appendix F. Formation of Benzovindiflupyr Transformation Products in 

Environmental Fate Studies

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

Hydrolysis (MRID No. 48604506) 

None – Stable at pH 4, 5, 7, and 9 

Aquatic Photolysis (MRID No. 48604507) 

Pyrazole Acid 

(NOA449410, CSAA798670; 

CA4312) 

8.9% at 15 

days (pH7 

solution) 

38.6% at 15 

days (natural 

water) 

Study terminated 

at 15 days. 

Pyrazole Amine 

(SYN508272, CSCC210616) 

2.6% at 15 

days (pH7 

solution) 

24.5% at 15 

days (natural 

water) Study terminated 

at 15 days. 

Carbon Dioxide 

6.9% at 15 

days (natural 

water) 

25.7% at 15 

days (natural 

water) 

Study terminated 

at 15 days. 

Soil Photolysis (MRID No. 48604495) 

Pyrazole Acid 

(NOA449410, CSAA798670; 

CA4312) 

2.9% at 30 

days 

Study terminated 

at 30 days. 
113 

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

Pyrazole Amine 

(SYN508272, CSCC210616) 

6.5% at 30 

days 

Study terminated 

at 30 days. 

SYN546039 

(CSCD695908) 

7.0% at 30 

days 

Study terminated 

at 30 days. 

SYN545720 

(CSCD465008) 

0.7% at 30 

days 

Study terminated 

at 30 days. 

Carbon Dioxide 

2.2% at 30 

days 

Study terminated 

at 30 days. 
114 

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

Aerobic Soil Metabolism (MRID Nos. 48604492 and 48604493) 

SYN546206 (CSCD711742) 

5.6% at 365 

days 

Study terminated 

at 365 days. 

Carbon Dioxide 6.0% at 365 

days. 

Study terminated 

at 365 days. 

Anaerobic Soil Metabolism (MRID Nos. 48604494) 

Pyrazole Acid 

(NOA449410, CSAA798670; 

CA4312) 

2.4% at 120 

days. 

Study terminated 

at 120 days. 

Carbon Dioxide 0.4% at 120 

days. 

Study terminated 

at 120 days. 

Aerobic Aquatic Metabolism (MRID Nos. 48604509 and 48604510) 

Pyrazole Acid 

(NOA449410, CSAA798670; 

CA4312) 

3.1% at 102 

days 

Study terminated 

at 102 days. 
115 

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

SYN546039 

(CSCD695908) 

0.4% at 29 

days 

Study terminated 

at 102 days. 

SYN546206 

(CSCD711742) 

1.4% at 60 

days 

Study terminated 

at 102 days. 

SYN546040 

(CSCD696468) 

0.1% at 61 

days 

Study terminated 

at 100 days. 

Carbon Dioxide 

0.3% at 100 

days 

Study terminated 

at 100 days. 
116 

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

Anaerobic Aquatic Metabolism (MRID Nos. 48604509 and 48604510) 

Pyrazole Acid 

(NOA449410, CSAA798670; 

CA4312) 

3.0% at 102 

days 

Study terminated 

at 100 days. 

SYN546039 

(CSCD695908) 

0.2% at 59 

days

Study terminated 

at 100 days. 

SYN546206 

(CSCD711742) 

1.7% at 30 

days 

Study terminated 

at 100 days. 
117 

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

SYN546040 (CSCD696468) 

0.6% at 61 

days 

Study terminated 

at 100 days. 

Carbon Dioxide 0.3% at 100 

days

Study terminated 

at 100 days. 

Terrestrial Field Dissipation (MRID Nos. 48604498, 48604502, and 48604511) 

Pyrazole Acid 

(NOA449410, CSAA798670; 

CA4312) 

0.77% at 29 

days after 2nd

application 

0.5% at 7 

days after 1st 

application 

Manitoba Loam 

Soil, Bare Plot 

(MRID No. 

48604502) 

Georgia Loamy 

Sand (MRID No. 

48604511) 

Pyrazole Amine 

(SYN508272, CSCC210616) 

2.0% at 7 

days after 1st 

application 

Georgia Loamy 

Sand (MRID No. 

48604511) 
118 

Table F-1. Benzovindiflupyr degradation products identified in environmental fate studies.

Degradate 

Identity Structure

Max% of 

Applied 

and Days 

Post 

Application

Comments

SYN546039 

(CSCD695908) 

1.2% at 34 

days after 3rd

application 

1.5% at 63 

days after 1st 

application 

Georgia Peanut 

Plants (MRID No. 

48604498) 

Georgia Loamy 

Sand Soil (MRID 

No. 48604511) 

SYN546206 

(CSCD711742) 

1.8% at 148 

days after 1st

application 

Georgia Loamy 

Sand Soil (MRID 

No. 48604511) 

SYN546040 (CSCD696468) 

0.6% at 91 

days after 1st

application 

Georgia Loamy 

Sand Soil (MRID 

No. 48604511) 

 
119 

Appendix G. Ecological Toxicity Data for Transformation Products for 

Benzovindiflupyr Transformation Products

Table G-1. Toxicity Reference Values For Aquatic Organisms Exposed to Degradation 

Products of Benzovindiflupyr. 

Species Study 

Type 

Test 

Substance 

(Purity) 

LC50

Endpoints 

Affected 

Toxicity 

Classification 

(MRID) 

(μg 

a.i/L)1,2,3

(95% 

CL; 

slope) 

Acute Freshwater Fish Test with Benzovindiflupyr Metabolite M700F001

Rainbow trout 

(Oncorhynchus 

mykiss)

96-

hour, 

flowthrough

TGAI 

(99.2 %) 

>88100 

None 

slightly to 

practically nontoxic 

(47923926) 

Acute Freshwater Fish with Benzovindiflupyr MetaboliteSYN46039

Rainbow trout 

(Oncorhynchus 

mykiss)

96-

hour, 

flowthrough

TGAI (98 

%) 

2500 

(2000-

3000; 

NA) 

Mortality 

and 

Sublethal 

effects 

Moderately 

toxic 

(48604545) 

Acute Freshwater Invertebrate Test with Benzovindiflupyr Metabolite M700F001

Species Study 

Type 

Test 

Substance 

(Purity) 

LC50

Endpoints 

Affected 

Toxicity 

Classification 

(MRID) 

(μg 

a.i/L)1,2,3

(95% 

CL; 

slope) 

Water flea 

(Daphnia magna) 

48-hr, 

static 

TGAI 

(99.2%) >98200 None 

practically nontoxic 

(47923732) 

Acute Freshwater Invertebrate test with Benzovindiflupyr MetaboliteSYN46039

Species Study 

Type 

Test 

Substance 

(Purity) 

LC50

Endpoints 

Affected 

Toxicity 

Classification 

(MRID) 

(μg 

a.i/L)1,2,3

(95% 

CL; 

slope) 

Water flea 

(Daphnia magna) 

48-hr, 

static 

TGAI 

(98%) 

5450 

(4790 - 

6190; 

NA) 

immobility

Moderately 

toxic 

(48604546) 

Aquatic Plant Test with Benzovindiflupyr Metabolite SYN46039
120 

Species Study 

Type 

Test 

Substance 

(Purity) 

LC50

Endpoints 

Affected 

Toxicity 

Classification 

(MRID) 

(μg 

a.i/L)1,2,3

(95% 

CL; 

slope) 

Species Study 

Type 

Test 

Substance 

(Purity) 

EC50

Endpoints 

Affected (MRID) 

(ug 

a.i./L) 

(95% 

CL)1,2

Freshwater green 

algae 96-hr, 

static 

TGAI 

(98%) 

> 6400 ; 

N/A 

Growth 

Rate (48604547)

(Pseudokirchneriella

subcapitata )