### 2 and water dispersible granule formulations for use as foliar spra y (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 ri sk assessment provides EFED’s assessment of the environmental fate, terrestr ial and aquatic exposure, and ecological risks associated with the proposed uses of benzovindifl upyr including blueberries, canola, cereal crops (oats, wheat, rye, and barley), corn, cotton, cu curbits, tomatoes, grapes, legumes, peanuts, pome fruit, soybeans, potatoes, turf grass, and nur sery crops. When estimates of benzovindiflupyr exposure considering all proposed uses in terrestr ial and aquatic environments are compared to the available ecotoxicity data, the resulting ri sk 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 inverteb rates, and estuarine/ma rine invertebrates was
identified. Acute risk but not chronic risk was identified for fr eshwater and estuarine/marine sediment dwelling invertebrates despite benzovindiflupyr’s persis tence 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 re solve some acute risks to both fish and
invertebrates. Risks above the level of concer n were not identified fo r aquatic plants (both vascular and non-vascular).

For terrestrial organisms, acute dose-based risk to bi rds 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 th e passerine acute dietary study. This may result
in decreased fitness th rough other impacts during sensitive times like during migratory or nesting seasons. There was also LOC exceedences for pi scivorous birds (e.g., sandpipers and rails consuming fish contaminated with benzovindifl upyr residues) suggest ing 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 identi fied for dietary-based exposure in mammals or acute risk from the consumption of fish cont aminated 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 prelimin ary exposure modeling and RQ analysis suggests that risk to adult bees via the cont act 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 wa sp) have endpoints that are in the range of application rates from the proposed uses of benz ovindiflupyr. There are no t 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 rest ricting benzovindifluypyr applications when plants are in bloom in the vicinit y. Therefore, risks to terrestrial invertebrates is presumed in the

### 3 absence of data and given benzonvindiflupyr’s po tential 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 ri sk identified to terrestrial plants.

Review of labels indicate that environmental h azard statements, while not pre-empting identified risks, sufficiently address the vulnerable diss ipation pathways of benzovindiflupyr to nearby terrestrial and aquatic habitats vi a runoff of contaminated erodible soil particles. However, there is uncertainty regarding seasonal maximum applica tion rates specified on the label. This risk
assessment evaluated one treatmen t/retreatment cycle of benzovi ndiflupyr 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: C 18 

# H 15 

# Cl 2 

# F 2 

# N 3 

# O
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 Ex posure Pathways ................................... 6

1.3 Summary of Effects an d Risk Conc lusions ....................................................................................... ..... 7
2. PROBLEM FORM ULATION ........................................................................................................... ................... 8

2.1 Use Character izatio n .......................................................................................................... .................... 8

2.2 Environmental Fate and Tran sport Character ization ........................................................................... 1 0

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

2.3.1 Aquatic Ef fects ............................................................................................................... ..................... 18

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

2.4 Conceptual Model and Risk Hypo thesis .......................................................................................... .... 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 Es timation ........................................................................................................... ................. 42

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

3.1.2 Terrestrial Exposu re Estimation ............................................................................................... ........... 47

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

3.2.1 Non-target Aquatic An imals and Plants ......................................................................................... ...... 53

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

3.3 Risk Desc ription .............................................................................................................. .................... 70

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

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

3.4 Review of Incident Data and En vironmental Monito ring 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 amid e fungicide chemical benzovindiflupyr (aka solatenol or SYN545192). This ri sk assessment utilizes the best available scientific information and proposed labels to evaluate the environmenta l fate and transport, and effects on non-target organisms. The proposed end use products are em ulsifiable concentrate and water dispersible granule formulations for use as foliar spray (gro und, 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 maximu m seasonal application rates up to 0.272 lbs. a.i./A specified. The specification of yearly applicat ions would provide further clarity related to seasonal application rates that a re currently specified on the proposed labels. The proposed uses of benzovindiflupyr include bl ueberries, canola, cer eal 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 tran sported from treated fields to off-site terrestrial habitats, wa ter bodies, and aquatic habitats via spray drift given its proposed spray applications; further, erosion of benzovi ndiflupyr-ladened soil particles embedded within runoff during rain events after application ma y occur. Benzovindifl upyr residues had foliar dissipation half-lives ranging between 0.6 – 20 days from turf, barley, peanut, and soybean crops
in residues measured in field diss ipation studies (MRID Nos. 48604997, 48604998, 48604502, 48604580, and 48604581). However, laboratory studies suggest that benzovindiflupyr is highly persistent in both terrestrial a nd aquatic environments. Therefor e, 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 a quatic habitats. Benzovindifl upyr’s high persistence was consistently observed in aerobic soil metabolis m and anaerobic soil metabolism studies with half-lives which ranged from 635 days – 1,788 days in seven soils 1 

### . Benzovindiflupyr’s high soil-water partition coefficient (K oc 

### ) 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 resi dues bound to eroded soil particle s. Once reaching water bodies, benzovindiflupyr’s high persistenc e also was observed in aquatic environments, as it was not observed to degrade at 50°C over a 30 day pe riod in the hydrolysis study (MRID No. 48604506) and its slow biodegradation which occurred wi th 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 applicati on. While persistent, a large portion of benzovindiflupyr residues present in the water co lumn 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 appl ication (MRID Nos. 48604509 and 48604510). Additional mesocosm studies with benzovindiflupyr in wate r-sediment systems were conduc ted 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 degrada tion and dissipation of benzovindifl upyr 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 terres trial and aquatic environments are compared to the available ecotoxicity data, the results of the screening-leve l assessment indicate a potential for risk above the level of concern to both aquatic and terres trial 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 propo sed uses of benzovindiflupyr specified by crop.

Risk concerns exist for acute a nd chronic exposures to fish and aquatic invertebrates. The chemical is highly toxic, persistent and RQs fo r many uses exceed LOCs. Risk is identified for acute exposures to birds and mammals and chroni c exposures to mammals. There is considerable uncertainty associated with risk conclusions asso ciated with birds becaus e of the regurgitation based endpoint used to derive acu te RQs. Although available information suggest low risk to bees, data gaps associated with critical life st ages (i.e., larvae) and chro nic 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 effect s to terrestrial and aquatic plants.

Risks in aquatic ecosystems are predominantly driv en by runoff as opposed to spray drift as risk conclusions largely do not change when rem oving the contribution of spray drift. The implementation of a spray drift buffer of 30 f eet 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 endpoi nts including acute freshwater fish, acute freshwater estuarine invertebrates, chronic fres hwater 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 benzovindiflu pyr 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 vari ous 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 expos ure, and ecological risk s associated with the proposed uses of benzovindiflupyr including blueberries, canola, cer eal crops (oats, wheat, rye, and barley), corn, cotton, cucurbits, tomatoes, gr apes, legumes, peanuts, pome fruit, soybeans, potatoes, turf grass, and nursery crops.

Benzovindiflupyr belongs to the py razole-carboxamides classes of fungicides and is effective against a broad range of fungal di seases. Other pyrazole fungicide s currently registered in the United States include, fluxapyroxad, penflufen, pe nthiopyrad, furamepyr, bi xafen, and sedaxane. Benzovindiflupyr is intended to prev ent 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 cycle 2 

### . This process is a vital energy production step that takes place in the mitochond ria of eukaryotic cells.

The active ingredient benzovindiflupyr is a (50:50) racemic mixture. The proposed benzovindiflupyr products consist of either emulsifi able concentrate or water dispersible granule
formulations. Emulsifiable concentrate formula tions 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 disper sible granule formulations compose of the multiple active ingredients benzovindiflupyr (1 5% a.i.) and axosystrobin (30% a.i.).

2.1 Use Characterization

Benzovindiflupyr is proposed to be used in c onventional ground, aerial, and chemigation spray foliar type of applications on blueberries, canola, cereal crops (oats, whea t, rye, and barley), corn, cotton, cucurbits, tomatoes, grapes, legumes , nursery plants, peanuts, pome fruit, soybeans, potatoes, and turf grass. Furthermore, bande d 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 seasona l application rates rather than

2 Citation: Fungicide Resistance Action Committee Classifica tion 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 la bels 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 ingredie nt 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 ye arly 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 C 18 H 15 Cl 2 F 2 N 3 O 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·m 3 /mol EpiSuite

HENRYWIN v. 3.20

Water Solubility

(pH 7, 20°C) 0.98 mg/L MRID 48604402

Octanol – water partition
coefficient (log K O W ) 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) t 1/2 = Stable (pH 4 at 50°C)

t 1/2 = Stable (pH 5 at 50°C)

t 1/2 = Stable (pH 7 at 50°C)

t 1/2 = 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: t 1/2 = 1,788 days (SFO)
France SiC: t 1/2 = 1,628 days (SFO)
Switzerland L: t 1/2 = 661 days (SFO)
California SaL: t 1/2 = 1,177 days (SFO)
North Dakota SaCL: t 1/2 = 1,172 days (SFO)

Switzerland L: t 1/2 = 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: t 1/2 = 616 - 742 days (n =2, SFO)
UK lake silt loam sediment: t 1/2 = 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: t 1/2 = 767- 934 days (n=2, SFO)
UK lake silt loam sediment t 1/2 = 882 days (DFOP) &

t 1/2 = 620 days (SFO) 48604509

&

48604510 Supplemental

 Study durations
insufficient to
determine full
formation and decline cycle for degradates

Mobility,

unaged leaching, adsorption/ desorption (K
oc )

(835.1220) UK SaCL: K
oc = 4,414 mL/g; K d = 123.6 mL/g; OC =

2.8%
Fr SiC: K
oc = 5,033 mL/g; K d = 45.3 mL/g; OC = 0.9%
Switzerland L: K
oc = 3,900 mL/g; K d = 78 mL/g; OC =

2.0%
California SaL K
oc = 5,214 mL/g; K d = 36.5 mL/g ; OC =

0.7 %
North Dakota SaL: K
oc =3,828 mL/g; K d = 95.7 mL/g ; OC
= 2.5 % 48604505 Acceptable

Terrestrial
Field Dissipation

(Soil Column)

(835.6100) Nebraska, USA Loam/Silty Loam: t 1/2 = 1,080 days (DFOP) 6 Illinois, USA Clay Loam Soil: t 1/2 = 2,725 days (SFO) 6 Georgia, USA Sandy Loam Soil: t 1/2 = 8,190 days (IORE)

6 California, USA Loamy Sand Soil: t 1/2 = 240 days (DFOP) Manitoba, Canada Loam Soil: t 1/2 = 196,000 days (IORE) 6 Georgia, USA Loamy Sand Soil: t 1/2 = 582 days (DFOP) 6 New York, USA Loamy Sand Soil: t 1/2 =1,610 days (IORE) 6 48604496

48604497

48604498

48604499

48604502

48604511

48604581 Acceptable

Acceptable Acceptable

Acceptable Supplemental 4,5

Acceptable Supplemntal 4

### 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:

t 1/2 = 4 – 10.5 days (IORE, n = 3 applications)

Georgia whole peanut plant:

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

Manitoba barley crop:

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

California turf grass clippings

t 1/2 = 0.6 – 6.8 days (IORE, n = 4 applications,)

New York grass clippings

t 1/2 = 11.7 days (SFO, n = 1 application) 48604497

48604498

48604502

48604580

48604581 Acceptable

Acceptable

Supplemental

Acceptable

Supplemental 4,5

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 t 1/2 = 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/m 3

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 Ra te Equation, DFOP = Double First Order in Parallel

3 Soil textural classifications:

### 15 Sa: Sand, SaCL: Sandy Clay Loam, SaL: Sandy Lo am, 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 ma y be transported to surface water via erosion of benzovindiflupyr-ladened soil particles concurrent with rain events after application. Benzovindiflupyr residues ar e expected to be readily washed off from crops as suggested from foliar dissipation half-lives rangi ng 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 e nvironment, and therefore the longevity for it to be available for runoff will be high after its a pplication. The total soil half-life in four field dissipation studies were all greater than 2,000 days 3 

### . The total soil half-life in four other study plots were still highly persistent but to a le sser degree, ranging from between 240 – 1,080 days 4



### . The persistence of benzovindiflupyr in the fiel d verified well from laboratory aerobic soil
metabolism and anaerobic soil metabolism half-l ives which ranged from 635 days – 1,788 days
in seven soils 5



### .

Benzovindiflupyr possesses soil-w ater partition coefficient (K oc 

### ) 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 K oc 

### and low solubility values suggest that runoff of benzovindiflupyr residues bound to eroded soil part icles is expected to most impact surface water bodies. Benzovindiflupyr’s low solubility a nd mobility indicate that it may leach in small quantities. Benzovindiflupyr is no t expected to escape from dry or moist soil surfaces or water bodies to the atmosphere via volatilizati on 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

∙ m 3 

### /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 da y 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 sedi ment from the water column overtime from the four aquatic water-sediment systems examined in aerobic and anaerobic aquatic studies. Between 74 pe rcent – 85 percent of applied be nzovindiflupyr was observed to sorb to sediment for a period of up to 100 da ys after the application (MRID Nos. 48604509 and 48604510). It should be noted that quasi-suboxic conditions may ha ve 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 mesoco sym type of studies were conducted for benzovindiflupyr in aquatic environments to further investigate th e biodegradation of benzovindiflupyr in the total water-sediment sy stem. 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 exposur e 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 uncertainti es related to the mesocosm studies.

### 17 Figure 1. Residues of benzovindiflupyr in wa ter and sediment compartments within the aerobic and anaerobic aquatic laboratory studies (MRID Nos. 48604509 and 48604510).

 Transformation Products of Be nzovindiflupyr in Soil and Water

Given benzovindiflupyr’s persiste nt 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 percen t of applied and pyrazole amine formed up to 24.5 percent of applied 15 days after applicati on. However, although these metabolites form in water in the presence of light, th is transformation pathway is not e xpected 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 a nd 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 K ow 

### value of 4.30 suggests that resi dues 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 whol e fish suggests there is moderately high bioaccumulation potenti al 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 th e depuration rate is first-order is unknown because only one test con centration 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 flow ing water bodies by its rapid depuration rate.
No metabolites of benzovindi flupyr were known to exist in fish from the BCF study, although this is uncertain since a large portion of the ma terial 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 ar e termed the “toxicity reference values” which are used for this quantitative risk assessment. Aquatic toxicity studies were also submitted with various degradation products of pa rent benzovindiflupyr th at were detected in small quantities in the environmen tal fate studies. Since benzovi ndiflupyr is the main stressor of
concern in this risk assessment and because transf ormation products are not as toxic as the parent chemical (see Section 2.4 below), toxicological endpoints fro m the studies on the degradation products are not used in the risk assessmen t. 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) LC 50

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 

### Acceptable (7.6-10.8;

N/A)

Carp Cyprinus carpio 96-hr,
flowthrough TGAI (98.3%) 3.5 Mortality
and
Sublethal

effects Very highly
toxic

48604562 

### Acceptable (2.6 - 4.9;

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) EC 50

Endpoints
Affected Toxicity
Classificatio

n MRID 

### Acceptability (μg a.i/L)

(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) EC 50

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 

### Acceptability LOAEC MRID

(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) EC 50

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



### Acceptability (μg a.i/L) MRID

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) EC 50

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 )

* EC 05 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 give n taxa to be used in quantitative risk assessment.



###  Freshwater Fish

Acute toxicity studies with technical-grade benz ovindiflupyr were availabl e 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 LC 50 

### was 4.7 μg a.i/L classifying benzovindiflupyr as ve ry highly toxic. Sublethal effe cts 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 observe d with complete loss of equilibrium, fish on the bottom of the test vessel, and dark in colorati on. 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 LC 50 

### 9.1 μg a.i/L classifying benzovindiflupyr as very highly toxic. Sublethal effects included partial loss of equilibriu m 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-m easured concentrations were <LOQ (<0.022, negative and solvent controls), 0.61, 1.1, 2.3, 5.4, a nd 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 LC 50 

### 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 gr oup, 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 LC 50 

### 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 th e rainbow trout. In one study conducted with 98% purity of degrada tion 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 e ffects included fish lying on si de 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 observe d mainly on the bottom of the test vessel.
The 96 hour LC 50 

### 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 concentrat ion was 88.1 mg/L under static conditions. The
96-h LC 50 

### was >88.1 mg/L and there were not any mo rtalities or sublet hal effects observed during the 96 hour test. This st udy was classified as acceptable and suggests that M700F001 is slightly to practically no n-toxic to rainbow trout.

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

### 23 conducted with TGAI benzovindiflupyr (98.3% pu rity), 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 μ g a.i/L (mean measured) treatment concentration. The total length and dry weight were significantly reduced at ≥ the 1.8 μ g a.i/L (mean measured) treatment concentration. The 32-day NOAEC and LOAEC base d on mean measured concentrations were
0.95 and 1.8 μ g a.i/L, respectively for mean dry weight and mean length.

. 

### This study was classified as acceptable and for risk assessment pur poses, 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 T GAI benzovindiflupyr (98.3%) on freshwater
invertebrates was available for Daphnia magna (MRID 4864522). The mean-measured concentrations were <0.74 μg/L (<LOQ; ne gative and solvent cont rols), 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 EC 50 

### values was and 85 μg a.i/L indicating that benzovindiflupyr is very highly toxic to freshwater invertebrate s. This study is classified as acceptable and 85 μg a.i/L will be used for es timating acute risk quotients for freshwater
invertebrates.

There were two additional acute freshwater in vertebrate toxicity studies submitted with degradation products of benz ovindiflupyr, both conducted with Daphnia magna . One study was conducted with the degradation product of bot h benzovindiflupyr and fluxapyroxad (another pyrazole fungicide as indicated in Section 2). The degradate M 700F001 had a purity 99.2% (MRID 47923732). The mean-measured concentra tions 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 EC 50 

### was >98.2 mg a.i/L suggesting that this degradate is practically non-toxic to freshwater invertebra tes. 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 EC 50 

### values was 5.2 mg a.i/L sugges ting that this metabolite is moderately toxic to freshwater invertebrates. This study was classi fied as acceptable.

A freshwater invertebrate ( Daphnia magna ) lifecycle test with be nzovindiflupyr 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 contro l were observed for parental survival at 95 μ g a.i/L (mean measured, the highest treatment concentr ation tested and where there was complete mortality), and dry weight at 0.88 μ g a.i/L (mean measured, the lowest treatment concentration); the number of live offspring was unaffected by treatment up to 15 μ g a.i/L and no offspring were produced at 34 μ g a.i/L. There were no effects on parent al length up to the 34 μg a.i/L (mean measured) treatment concentra tion, although data from the 95μg a.i/L treatment concentration were excluded due to complete mortality in th at treatment concentra tion. There was also a significant increase in the average time to first brood at the 15 μ g a.i/L level relative to the negative control (Day 9). The NOAEC and LOAEC 5.6 μ g/L and 15 μ g a.i/L based on an increase in time to first brood as compared to th e negative control. This study was classified as acceptable due to the non-definiti ve endpoint and the NOAEC of 5.6 μ g/L will be used for estimating chronic risk quotient s 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 va lues. At 96 hours, mortality was 71, 100, and 100% in the 32, 70, and 150 μg a.i/L (mean measured) tr eatment 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. Subl ethal effects included lethargi c fish and complete loss of equilibrium in the 70 μg a.i/L group at 24 hours. The 96 hour LC 50 

### , based on mean-measured concentrations, were 28 μg a.i/L suggesting th at 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 determin ed 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 ava ilable 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 contro l was 2.8 and 3.2 mm, respectively. Mean shell growth in the 22, 35, 67, 140 and 240 μ g 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 μ g a.i./L treatment levels was 5, 9, 19, 50 and 68%, respectively. Based on mean measured concentrations, the 96-hour EC 50 

### was 160 μ g 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, a nd solvent control, 7.4, 17, 48, 120, 250 μ g a.i./L. Following 24 hours of exposure, 100% mortality was obs erved among mysids exposed to the 250 μ g/L (mean measured) treatment level, the highest treatment level tested. At test te rmination (96 hours), 10, 35 and 100% mortality was observed in mysids exposed to the 17, 48 and 120 μ g a.i/L (mean measured) treatment levels, respectively, the th ree highest treatment levels tested. Several surviving mysids exposed to the 48 μ g a.i/L treatment level were obser ved 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 μ g a.i/L) or the dilution water control. Ba sed on mean measured concentrations, the
96-hour LC 50 

### was estimated to be 47 μ g a.i/L indicating that that be nzovindiflupyr is very highly toxic to saltwater mysids. This study was classified as acceptabl e 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 μ g 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) comp ared to the controls at 15 a nd 31 μg ai/L. The NOAEC and LOAEC values for reproduction were 7.4 and 15 μ g ai/L, respectively, based upon meanmeasured concentrations. This endpoint will be used to assess chronic risk to estuarine/marine
invertebrates. The NOAEC and LO AEC for F0 female dry weight, F0 male dry weight, F0 male length, F0 survival post-pairing, were 15 and 31 μ g ai/L respectively. This study was classified as acceptable.

 Benthic (Sediment Dwelling) Invertebrates

The effect of benzovindiflupyr on freshwater benthic invertebrate s 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-measur ed 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 a ffected included percent emerged and number eggs per emerged female. There were reductions in emergence fr om control of 19.4% and 17.7% in the 12 and 48 mg a.i/kg sediment level. Statistical analys is determined significant effects in emergence (p<0.05) at the three highest treatment concentr ations (12, 24, and 48 mg a.i/kg sediment). A 42% reduction from control in number of eggs pe r emerged female at the 6.7 mg a.i/kg sediment
was not identified as si gnificant (p>0.05. However, the st udy reviewer determined that a 42% reduction from control for this endpoint is bi ologically meaningful and therefore the NOAEC and LOAEC for number of eggs per emerged fema le 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 sedi ment. 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 th at were observed in any of the treatment levels. Survival was 88 and 80 percent for the negative and solvent cont rols, 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 a nd 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 ba sed 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 (M RID 48604526) for the pare nt 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%) cult ures were exposed to mean measured concentrations of <0.0020 (<LOQ, negative and solvent contro ls), 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 EC 50 

### 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 lim it test with mean measured concentrations of
420 and 890 μ g a.i/L. The EC 50 

### and NOAEC were >890 μ g a.i/L and 420 μ g 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 μ g a.i./L. The EC 50 

### 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 c ontrol), 0.21, 0.41, 0.90, 1.9, 4.0, and 6.4 mg a.i./L
under static conditions. The highest concentration represente d the limit of water solubility. After 96 hours, the most sensitive NOAEC and EC 50 

### 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 trea ted algal culture as compared to the negative control ranged from -4.4 to 26.7%. Th is study was classified as acceptable.

### 27 2.3.2 Terrestrial Effects

All toxicity reference values used to asse ss the potential acute and chronic risks of benzovindiflupyr exposure to birds, mammals, and invertebrates were obtained from acceptable or supplemental studies usi ng 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 LD 50 : 1373 (1047-1978; NA) mg/kg bw Mortality, bodyweight, and sublethal effects Slightly toxic
Acceptable ( Colinus virginianus ) 48604512

TGAI (98.3%) Bobwhite quail

14 d LD 50: >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 LD 50 = 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 LD 50: < 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 LC 50 : >
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
LC 50 : >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 LD 50 = 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 LD 50 : > 100 ug ai/bee (95% CI N/A)  Practically nontoxic Acceptable

(Acute contact toxicity) 48604527

TGAI
98.3% Honeybee Apis mellifera

48 h LD 50 : > 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 LC 50 : 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 LR 50 = 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 LR 50 : 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 (Worddoc) and PMRA2255551 (PDF) Supplemental

Bolded values refer to the most sensitive endpoint for a give n 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 qua il, mallard duck).

The first acute study with bobwhite quail (exposed birds via oral ga vage to concentrations of 0 (vehicle control) 292, 486, 810, 1350, and 2250 mg a i/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 e ffects were observed at all treatme nt 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-exc itability, lower limb rigidity, sporadic movement about cage, sporadic head movement, and depression. Treatment-related
effects were observed for overall body weight gain and feed cons umption. The 14-day acute oral

LD 50 

### for northern bobwhites exposed to SYN 545192 (Benzovindiflupyr) was 1373 mg a.i./kgbw. This would classify Benzovindiflupyr as s lightly toxic to the northern bobwhite quail on an acute oral basis. This study was classified as acceptable.

The second acute study with bobwhite quail expose d birds via oral gavage to a four stage sequential testing design with concen trations in stage 1 of 0 (vehic le 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 stag es. Body weight reducti ons 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 observe d for Days 0 to 14. The 14-day acute oral LD 50 

### for Northern bobwhites exposed to SYN545192 (B enzovindiflupyr) 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 us ing a two stage test via oral gavage. Regurgitation was observed at all treatmen t levels in Stages 1 an d 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 expose d once to the test materi al at concentrations of 0 (vehicle control), 10, 32, 100, and 320 mg ai/kg-bw. Ten (5/s ex/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 th e 0 (vehicle control 1), 0 (vehicle control 2), 10, 32, 259, and 432 mg ai/kg-bw groups, respec tively. 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 fo r acute oral toxicity study a passerine species due to the high degree of regur gitation throughout the study. The observation of regurgitation at all but the lowest treatment levels precluded the ability to derive a meaningful LD 50 

### from this study that could be used in risk assessment as it is unclear what dose the bi rds actually received.

### 32 EFED guidance 6 

### indicates to use the highest value be low which regurgitation did occur as the acute endpoint for this study. Based on this the LD 50 

### 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 su bmitted 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 LC 50 

### could not be determined due to ≥ 70% mortality at all treatment levels and survival data possibly being conf ounded by food avoidance and resulting starvation. This study could not be used to derive an endpoint but indicates that sola tenol is toxic to the
zebra finch in the doses th at were administered.

There were two subacute studies submitted fo r the northern bobwhite quail (MRID 48604515) and mallard duck (MRID 48604514), both categori zing benzovindiflupyr pr actically non-toxic
on a sub-acute basis. In the northern bobwh ite 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 gr oup, the highest concentration tested. The LC 50 

### 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. Slig ht lethargy was reported on days 4 and 5 but all birds appeared normal on days 6- 8. The 8-day acute dietary LC 50 

### based on mean-measured concentrations was >6390 mg ai/kg-diet. This study was classified as acceptable. For risk assessment purposes, a subacute dietary LC 50 

### of > 6390 ppm in the diet) will be used qualitatively to evaluate poten tial 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 be nzovindiflupyr to avian species. In the mallard duck study (MRID 48604516) 22 week old birds were exposed to meanmeasured concentrations were <25 (<LOQ, c ontrol), 59.4, 202, and 598 mg ai/kg diet. Based upon treatment-related effects on adult fema le body weights and offspring body weights (hatchling weight and 14-d surv ivor 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 regard ing adult survival, clinical signs of toxicity, food consumption, or gross pathol ogical findings. Data for ma le body weight gain were very

6 Citation: 

### ( http://www.epa.gov/pesticides/s cience/efed/policy_guidance/team _authors/terrestrial_biology_t ech_team/rr_regurg_acute_passerine.pdf )

### 33 highly variable (%CV over 300 for treatment concen trations) 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 concentr ations, respectively. There was a decreasing dose-dependent trend for female body weight ga in. 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 reproduc tion were evident at the 59.4 mg ai/kg diet treatment level. At the 598 mg ai/kg diet level, the reviewer’s an alysis detected a signif icant reduction in egg production (p=0.022), relative to the control. A dditionally, there were dose-dependent treatment reductions upon offspring body we ights at the 202 and 598 mg ai/kg diet levels, with statistically-significant differen ces 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), bi rds 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 embr yos 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 trea tment-related effects on adult survival, clinical signs of t oxicity, food consumption, adult b ody weight, or gross pathological findings. While statistically significant (p<0.05 ) effects on male body weight gain were attributed to high variation in th e data and not related to treatment as a stimulatory effect on body weight gain was observed in females. Base d 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 conduc ted with formulated benzovindiflupyr (10.2% w/w or 99.6g/L) in an up-down study using tr eatment concentrations of 17.5, 55, 175 mg/kg using young adult rats (MRID 48604427). Benzovindiflupyr caused mo rtalities 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), pilo erection (3/3), dyspnoea (3/3), decreased respiratory rate (1/3), clonic convulsion (1/3), decreased body temperatur e (3/3) and mortality (3 /3) at a dose level of 175 mg/kg bw and decreased activity (4/4), dyspn oea (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 LD 50 

### 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 th ree 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 LD 50 

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

LD 50 

### was >100 μg a.i/bee for th e contact test, and the LD 50 

### based on actual intake was >109  g ai/bee for the oral test. As a result, Benzovindiflupyr is categori zed as practically non-toxic to honey bees on an acute contact basis. Th is study was classified as acceptable.

 Other Non-target Terrestrial Organisms

An acute toxicity study was submitted that expo sed TGAI benzovindiflupyr to the earthworm ( Eisenia fetida , PMRA 2255438). Earthworms were expos ed to nominal concentrations of 62.5, 125, 250, 500 and 1000 mg a.i./kg soil dry weight in ad dition to negative control. No mortality (0 %) occurred in the contro l 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 LC 50 

### for mortality was 406.4 mg/kg with 95% confid ence 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 cont rol group during the test. At a concentration of 1000 mg a.i./kg soil d.w., the worm body was deform ed 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 EC 50 

### value
for biomass decrease could not be calculate d. The extent of the biomass decrease was significantly different than the co ntrol 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 re viewer to be 250 mg a.i.//kg soil d.w. This study was scientifically sound but was not desi gned to fulfill any cu rrent 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 SYN 545192 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 definitiv e 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, resp ectively. The 416 and 833 mL/ha treatment rates differed significantly from th e control (Fisher’s Exact Test, α = 0.05). The LR 50 

### value calculated by the PMRA reviewer was 578 mL product/ha with 95% confidence limits of 507 and 667 mL product/ha. The LR 50 

### value was used in the Canadi an assessment. The NOER for mortality was 208.3 mL/ha. This study was acc eptable and satisfies Canadian guideline requirements for a laboratory st udy with the parasitic wasp ( Aphidius rhopalosiphi ). For EFED risk description this study was scient ifically 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 SYN 545192 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 mortal ity 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 contro l, the no-observed-effe cts rate (NOER) for mortality was determined to be 833. 33 mL A17056F/ha. Therefore the ER 50 

### 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 equi valent 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 determin ed to be 3333 mL/ha (the highest
concentration evaluated for re production, and the second highest concentration in the overall dose-response test). Canada determined that th is study was acceptable and satisfied the Canadian guideline requirements for a laborato ry study with the predatory mite ( Typhlodromus pyri ). For EFED risk description this study was scient ifically 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 benzovindiflupy r EC (100) [referred to in the study report by its product code: A15457H]. This end-use produc t has a guarantee of 100 g/L SYN545192 (benzovindiflupyr – BZV). Treatments and contro ls were applied to pots of seedling barley ( Hordeum vulgare ) with a lab track sprayer that was us ed to deliver spray at a volume rate equivalent to 400 L/ha. Once the barley plants we re dry, they were enclos ed 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 mortal ities were 0, 16.7, 20, 50 a nd 80, respectively. The 1500, 3000 and 6000 mL/ha treatment rates differed si gnificantly from the control (Fisher’s Exact Test, α = 0.05). Therefore the NOER for mortality was 750 mL/ha. The LR 50 

### was calculated by the reviewer to be 2650 mL pr oduct/ha with confidence li mits 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, respec tively. This represents a -11 .4 (negative value indicating an increase), 12.9 and 35.3% change relative to the controls. The reprodu ctive 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 possibl e to calculate an ER 50 

### value for reproduction. Canada considered this study acc eptable and it satisfied Canadian guideline requirements for a laboratory st udy 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 ther efore classified as supplemental.

In a 14-day acute toxicity study, the predatory mite ( Typhlodromus pyri ) was exposed to benzovindiflupyr in the formulated product SYN 545192 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 faci ng 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 comp arison with the control, the no-observed-effects rate (NOER) for mortality was determined to be 3000 mL A17056F/ha. A reliable ER 50 

### for mortality could not be calculated due to lack of effects greater th an 15%. Thus, the LR 50 

### 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% (nega tive value denoting an increase relative to controls), 11.5, 6.8,
28.1 and 12.9% relative to the controls. When co mpared 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 re quirement and is therefore classified as supplemental.

### 37  Terrestrial Plants

Toxicity reference values for terrestrial pl ants exposed to benzovindiflupyr is shown in Table 6

.

Table 6. Toxicity Reference Values for T errestrial Plants Exposed to Benzovindiflupyr.

Crop Species Common name EC 25 (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 (formu lated 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 expo sed 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 equi valent to 100 g/Ha). There was however uncertainty in this endpoint. Six of the 10 speci es (onion, ryegrass, sugarbeet, cabbage, lettuce, and tomato) had treatment levels that were sta tistically 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 th e responses were not treatment re lated. The lack of trends in any of the data sets and the NOAEC at the highe st tested concentration make any of the EC 25 

### values determined uncertain. The EC 25 

### 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 cl assified 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) a nd 0.090 lb ai/A. In the vegetative vigor test, survival, plant dry weight, and pl ant height were not affected by the test material. The most sensitive monocot and dicot species could not be de termined due to a lack of toxicity in this study. The overall NOAEC value was 0.090 lb ai/A (equivalent to 101 g a i/ha). Chlorosis, necrosis, wilt, and insect damage were observed in the cabbage controls; however, the treated plants were unaffected. There was complete mort ality in a single treated lettuce plant; however, no other plants were affected. L eaf curl and necrosis were observ ed in the treated radish plants, but the effects were very slight a nd not attributable to the test ma terial. 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, fres hwater 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 magnit ude for non-vascular aquatic plants than the degradates (see Appendix G for the endpoint values of the ec ological toxicological studies for the degradates). Therefore, this risk assessmen t will only evaluate adverse impacts from parent benovindiflupyr considering the limited forma tion of transformation products and its high relative toxicity compar ed to the degradates.

The identification of relevant environmental expo sure pathways to benzovindiflupyr applications for this risk assessment evaluating impact to non-target organisms are discussed below:

 Dietary Exposure : Direct dietary exposure to non-targ et terrestrial organisms (birds and mammals) is possible due to the direct depos ition of benzovindiflupyr sprays on to crop foliage, enabling the bioavailability of benz ovindiflupyr. Furthermor e, 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 e xposed. Bioaccumulation of benzovindiflupyr residues is possible in fish given benzovindiflupyr’s Log K ow 

### 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 benzovindi flupyr 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 a nother relevant pathway associated with benzovindiflupyr applications. Freshwater and estuarine mari ne fish and invertebrates as well as aquatic plants in th e water column may be imp acted. In addition, benthic organisms residing in the bottoms of water bodies may also be impacted given the

### 39 benzovindiflupyr’s tendency to bind to sedi ment 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 vege tation. Furthermore, off-site deposition of benzovindiflupyr due to spray drift may also adversely impact non-target terrestrial pl ants. 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 pl ants to confirm this.

 Terrestrial invertebrates: Dietary and contact exposure to terrestrial invertebrates are possible pathways with benzovindiflupyr applications. Cr ops treated with benzovindiflupyr may potentially attract terrestrial invertebrates (e.g., be neficial insects) resulting in dietary and contact exposure.

Drinking water and inhalation exposure to te rrestrial 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 (STI R version 1.0; 11/23/2010), respectively. SIP is available publically at: http ://www.epa.gov/oppefed1/models/terre strial/sip/sip_user_guide.html. STIR may be accessed on-line at: http://www.epa.gov/oppefed1/models/terre strial/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 lik elihood 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 reproduc tion 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 LD 50 

### or NOAEC. The RQ is calculate d as a ratio of the estimated environmental concentration (EEC) to an effect level ( e.g. , LC 50 

### , LD 50 

### or NOAEC) using the

### 40 effect level as a denominator. The resulting RQ is then compared to a sp ecified level of concern (LOC), which represents a point of departure fo r 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 no t necessarily a true estimate of risk since there is no estimated probability of effect. Risk pr esumptions, 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 adequ acy of the submitted data is evaluated relative to Agency guidelines. For benzovindiflupyr, th e available environmental fate da ta ecological effects data is determined to be sufficient in evaluating the ecol ogical risk to terrestria l 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 terrestr ial environments, all exposure modeling and resulting risk conclusion s will be based on maximum application rates
and methods cited in Table 1 and will be estimated for each us e of benzovindiflupyr. Measures of exposure are based on aquatic and terrestria l models that predict estimated environmental concentrations (EEC) of benzovindiflupyr. A quatic exposure in surface waters, benthic pore water, and sediment for proposed benzovindiflupyr applications are estim ated using The Surface
Water Concentration Calculat or 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 th e 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/t errestrial/trex/t_rex_user_guide.htm . The model used
to derive EECs relevant to terrestrial and wetla nd plants is TerrPlant accessible publically at: http://www.epa.gov/oppefed1/models/terrestri al/terrplant/terrplan t_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 environmen tal fate data and ecolo gical 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/wat er/input_parameter_guidance.htm).

Since benzovindiflupyr is a new active ingredient, there are no environmental monitoring data available. Therefore, exposur e 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 sp ecies. 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 te sts. The focus on these effects for quantitative

### 41 risk assessment is due to their clear relations hip to higher-order ecolo gical systems such as populations, communities, and ecosystems. Alt hough monitoring data may also be used to provide supporting lines of evid ence for the risk characteri zation, monitoring data is not available for this new chemical. Commonly used laboratory-derived toxi city values include estimates of acute mortality (such as LD 50 

### , LC 50 

### , or EC 50 

### ) 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 considere d, (such as changes in biochemical, cellular, organ-level responses) but are typically used qu alitatively to characteri ze risks since, in many cases, the relationship between these effects an d higher-order processes is prone to more uncertainty. The latter can reflect changes s een in mortality, reproduc tion, or growth. In general, for a given assessment endpoint, the lowe st relevant measure of effect is used in calculating the risk quotient.

### 42 

## 3. RISK ANALYSIS AND CHARACTERIZATION

Risk characterization is the inte gration of exposure and effects ch aracterization to determine the ecological risk from the use of benzovindiflupyr and the likelihood of ef fects on aquatic life, wildlife, and plants based on varying pesticide-us e scenarios. The risk characterization provides estimation and a description of the exposure a nd resulting risk; articul ates risk assessment assumptions, limitations, and uncertainties; synthesi zes 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 para meters for the SWCC a quatic exposure modeling used to estimate upper-bound EECs due to be nzovindiflupyr applications are shown in Table 7 (chemical specific input parameters) and Table 8 (crop use specific i nput parameters). Broadcast aerial applications ar e only evaluated in this screeni ng 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 applic ations and localized banded and in-furrow soil applications. Only gr ound spray applications are evaluated for turf and nursery since aerial applica tions are not proposed on the pr oduct labels. EECs are calculated considering scenarios possessi ng the most vulnerable enviro nmental conditions for all benzovindiflupyr proposed uses nationwide. The EECs of benzovindiflupyr in the surface water column, benthic pore water, and sediment ar e 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 parame ter 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 (K
oc ) (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 (t 1/2 ) Stable MRID 48604506

Aerobic soil metabolism (t 1/2 ) and Reference Temperature 1,460 days @ 20°C MRID 48604492 & 48604493

EFED Input Parameter Guidance Upper 90 TH percentile confidence interval (n = 5 soils) 1

Aerobic aquatic metabolism (t 1/2 ) and 2,920 days @ 20°C MRID 48604509 & 48604510

### 43 Table 7. SWCC chemical property input parame ter 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 (t 1/2 ) and Reference Temperature 907 days @ 20°C MRID 48604494

EFED Input Parameter Guidance Upper 90 th percentile confidence interval (n = 4 soil-water sediment systems) 1

.

Aqueous Photolysis (t 1/2 ) and Reference
latitude 88.4 days @ 45°N MRID 48604507

Foliar Extraction 0.5 Default assumption for foliar applications

1 The upper 90 th percentile half life calculated as follows: t 1/2 input = ݐ ଵ/ଶ ത ത ത ത ത + (t 90, n-1 x σ )

n 1/2

where ݐ ଵ/ଶ ത ത ത ത ത

is the mean of the set of half lives from each study, t 90, n-1 is the one-sided t value for the 90 th percentile
level, σ is the standard deviation of the set of half lives dete rmined from each study, and n is the sample size of the set of half lives determined from each study.44Table 8. SWCC crop scenario and application methods input parameter valuesfor benzovindiflupyr aquatic exposureestimation.Crop UseSWCC Application Method and Crop Scenario Input ParametersRepresentativeVulnerable SWCCScenario andWeather Station1ApplicationRate(kg a.i./ha)2Number ofApplicationsandRetreatmentInterval2FirstApplicationDate3ApplicationMethods4ApplicationEfficiency5Spray DriftFraction6Corn MS Corn03940.dvf(Jackson, MS)0.0764 apps.,7 days apartApr. 10Foliar -Aerial0.950.125Cucurbits FL Cucumbers12844.dvf(West Palm Beach, FL)Oct. 25Tomatoes and Fruiting Vegetables FL Tomato12844.dvf(West Palm Beach, FL)May 1Grapes NY Grape14860.dvf(Erie, PA)Sept. 15Tubers (Potatoes) ME Potato14607.dvf(Caribou, ME)Aug. 15Peanuts NC Peanuts13722.dvf(Raleigh, NC)0.13 apps.,14 days apartAug. 1Nursery Plants, Tomato Transplant,Fruit Transplant, CucurbitTransplantNJ Nursery93730.dvf(Atlantic City, NJ)3 apps.,7 days apartAug. 5Foliar -Ground0.990.062Turf Grass FL Turf12834.dvf(Daytona Beach, FL)3 apps.,14 days apartOct. 5CottonMS Cotton03940.dvf(Jackson, MS)0.0763 apps.,7 days apartMay 15Foliar –Aerial0.950.12545Table 8. SWCC crop scenario and application methods input parameter valuesfor benzovindiflupyr aquatic exposureestimation.Crop UseSWCC Application Method and Crop Scenario Input ParametersRepresentativeVulnerable SWCCScenario andWeather Station1ApplicationRate(kg a.i./ha)2Number ofApplicationsandRetreatmentInterval2FirstApplicationDate3ApplicationMethods4ApplicationEfficiency5Spray DriftFraction6Blueberries NY Grape14860.dvf(Erie, PA)0.0762 apps.,10 days apartSept. 15Foliar –Aerial0.950.125Soybeans & Legumes MS Soybean03940.dvf(Jackson, MS)0.0762 apps.,7 days apartMay 15Cereal (Oats, Barley, and Wheat) ND Wheat14914.dvf(Fargo, ND)0.0762 apps.,14 days apartJun. 20Canola ND Canola24013.dvf(Minot, ND)0.076 1 app.Aug. 15Pome fruit CA Fruit93193.dvf(Fresno, CA)0.0524 apps.,7 days apartFeb. 101Selected crop scenarios possessing most vulnerable environmental conditions for all benzovindiflupyr uses. Refer toTable 1for information onmaximum application rates specified on the label for proposed uses which was partially considered to select crop scenarios.2Maximum single application rate specified on product labels (Table 1).3Selected based on maximum rainfall climatological date at meteorological station aftercrop emergence date specified in PRZM crop scenario based onexpected pest pressure.4The most conservative application method evaluated based on crop uses specified on product labels.5EFED input parameter guidance for aerial and ground applications.6Spray drift fraction for aerial and ground applications from Table 2 of EPA, 2013, “Guidance on Modeling Offsite Deposition ofPesticides via SprayDrift”.

### 46 Table 9. SWCC estimated upper bound concentrations in the surface water column, pore water, and sediment (ppb) fo r 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) fo r 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 be nzovindiflupyr exposures in terres trial 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 an imals assumed to be in the target area or in an area exposed to spray drift are derived from using the T-RE X model (Version 1.5, released 03/2012). This model incorporates the Kenaga nom ogram, 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 90 th 

### percentile confidence bound of foliar dissipation half-life values from actual field measurements. The Fletcher et al. (1994) modifications to the Kenaga nomograph are ba sed 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 di ssipation) half-life of 10.9 days was derived 90 th 

### percentile value from the foliar dissipation half-l ives of submitted studies and was used to estimate EECs in lieu of the T-REX default half-life of 35 days 7



### . 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 concentra tions (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 quotie nts described in the risk char acterization section. The T-REX sample input file is provided in Appendix B.

Table 10. Terrestrial food item residue es timates 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 UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeeds

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 m g/kg-bw).

15 gram "Small" Mammal 35 gram "Medium" Mammal 1000 gram "Large" Mammal

Crop UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeeds

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 UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropods

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 UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropods

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 we tland plants is TerrPlant (version 1.2.2, released 12/2006). EECs for terrestrial plants inhabiting dry and wetland areas ar e derived using this model which utilizes the solubility of pesticid e in runoff and in spray drift. Additionally,
TerrPlant derived EECs factor in application rate and mi nimum 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 (K OW 

### based Aquatic BioAccumulation M odel) version 1.0 was used to evaluate the potential exposure and risk of direct effects to birds and mammals via bioaccumulation and biomagnification in aquati c 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 bi oaccumulation model based on P CBs and some pesticides ( e.g ., lindane, DDT) in freshwater aquatic ecosystem s (Arnot and Gobas, 2004). KABAM relies on a chemical's octanol-water partition coefficient (K OW 

### ) to estimate uptake and elimination constants through respiration and diet of organisms in diffe rent trophic levels. Pest icide tissue residues are
calculated for different levels of an aquatic food web. The m odel then uses pesticide tissue concentrations in aquatic animal s to estimate dose- and dietary- based exposures and associated risks to mammals and birds (surrogate for amphibi ans and reptiles) consuming aquatic organisms. Seven different trophic levels in cluding phytoplankton, zooplankton, be nthic invertebra tes, filter feeders, small-sized (juvenile) forage fish, medium -sized forage fish, and larger piscivorous fish, are used to represent an aquatic food web. In put 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 K OW 4.3 MRID 48604402

K OC 4,478 L/kg OC 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 resi dues 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 Benzovi ndiflupyr in Aquatic Organi sm 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 Benzovi ndiflupyr in Aquatic Organi sm 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 th e assessment of benzovindiflupyr risks, the risk quotient method is used to comp are 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 ar e then compared to the Agency’s levels of concern. These LOCs, summarized in Appendix A , are the Agency’s inte rpretive 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 direct ed 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 a nd 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 ve ry highly toxic to a ll 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 freshwat er 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 us e. 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 endpoi nt 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 fr eshwater fish from a broad range of uses.

Benzovindiflupyr was also classified as very highly toxic to estu arine/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 acut e 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 w ith 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 toxi city study for estuarine/marine fish, the ACR be calculated using the most sensitive species from th e parallel studies (in th is case the freshwater acute and chronic fish studies) and using the sa me species. Since there was not any chronic studies conducted with carp, the fathead minnow was selected sin ce 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 unbounde d estimate of toxicity has uncer tainties 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/ma rine 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 LC 50 = 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 th e freshwater chronic RQs by 33 percent. Acute Estuarine/Marine Fish: Sheepshead Minnow EC 50 = 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 freshwat er invertebrates (EC 50 

### = 85 ug a.i./L; MRID 48604522) and estuar ine/marine invertebrates (EC 50 

### = 47 ug a.i./L; MRID 48604535). Acute RQs for freshwater invertebrate s ranged from less than 0.01 to 0.1 with eight out of fourteen proposed uses (corn, cucurbit s, 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 (L OC = 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 de monstrated 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 on e proposed use (potatoes) exceeding the chronic LOC. From this data, there is risk concern from chronic e xposure 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/ma rine 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/ma rine 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 av erage) 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 LC 50 = 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 EC 50 = 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 en dpoints are provided below to supplement risk estimation to water column organisms. The evalua tion of toxic risk to th e 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 chr onic risk and one for acute risk. Approach 1 (chronic risk with sediment exposure): 21-day EC s 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 m odel-generated (SWCC) and compared to the toxicity value as report ed for pore water (NOAEC) in the sedi ment 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 (Sedimen t NOAEC 4.1 mg a.i./kg; MRID 48604583). The RQs were derived from the 21-day se diment 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 compar ing peak porewater concentrations with the acute toxicity endpoints of bot h freshwater and estuarine/ma rine 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 RQ s for estuarine/marine
invertebrates exceeded the acute lis ted species LOC in nine of the fourteen proposed uses. The only uses that exceeded the restricted use LOC we re corn, grapes, and tubers. The RQs indicate
that there is acute risk concern for both freshw ater 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

0.06 0.04 

### 0.25 0.17 0.05 0.08 (FL Cucumber, 0.068 lbs. a.i./A, 4 apps. 7 days apart)
Grapes

0.08 0.05 

### 0.34 0.24 0.06 0.11 (NY Grape, 0.068 lbs. a.i./A, 4 apps. 7 days apart)
Nursery Crops

0.04 0.03 

### 0.18 0.12 0.03 0.06 (NJ Nursery , 0.088 lbs. a.i./A, 3 apps. 7 days apart)

Peanuts

0.05 0.04 

### 0.22 0.15 0.04 0.07 (NC Peanuts, , 0.089 lbs. 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

0.01 0.01 

### 0.05 0.03 0.01 0.02 (FL Turf, 0.088 lbs. a.i./A, 3 apps. 14 days apart)

Cotton

0.06 0.06 

### 0.25 0.17 0.05 0.08 (MS Cotton, 0.068 lbs. a.i./A, 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

0.03 0.03 

### 0.15 0.10 0.03 0.05 (ND Wheat, 0.068 lbs. a.i./A, 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 aver age) SWCC pore water and sediment EECs for each crop use utilized in RQs.

2 Most sensitive endpoints for benzovindiflupyr utilized in RQs:
Chronic Freshwater Invert ebrates (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 Invert ebrates (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 (EC 50 

### >880, NOAEC = 430 ug a.i./L; MRID 48604526) and non-vascular (algae) plants (EC 50 

### = 240 ug a.i./L, NOAEC = 50 ug a.i./L utilizing the EECs presented in Table 9 . The EC 50 

### 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 list ed LOC of 1.0 in any scenario for either nonvascular plants or vascular plants. RQs for nonvascular plants ra nged from <0.01 to 0.04 for non-listed species and from 0.02 to 0.17 for listed species. RQs for vasc ular 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 ingesti on of six different food items exposed to benzovindiflupyr. Table 19 below summarizes the acute dose-b ased RQs to birds for proposed uses of benzovindiflupyr. The acute endangered sp ecies 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 LO C (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 si zed birds, there were not any exceedances when eating seeds. For large sized birds feeding on s hort grass, tall grass, a nd 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 eati ng fruits/pods, arthropods, or seeds ( Table 19 ). LOC exceedances in every size cl ass of bird for both listed (L OC = 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 fo r 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 LargeShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeeds

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;; No n-listed animals acute LOC = 0.5

### 63 Table 20. Chronic dietary-ba sed RQs for birds due to exposure to proposed uses of benzovindiflupyr.

Crop UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropods

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 inge stion 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 pl ants 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 ta ll grass and broadleaf pl ants. For large sized mammals, only three of the ten use groups exc eeded 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 th e 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 on e 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 LargeShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeeds

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 mammal s due to exposed to proposed uses of benzovindiflupyr.

Small Medium Large

Crop UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeedsShort GrassTall GrassBroadleaf PlantsFruits/podsArthropodsSeeds

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 RQ s for mammals due to exposed to proposed uses of benzovindiflupyr.

Crop UseShort GrassTall GrassBroadleaf PlantsFruits/podsArthropods

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 LD 50 

### >100 ug a.i/bee; MRID 48604527) and was shown to be non-toxi c at a dose of 109 μg a.i/bee in an acute oral exposure study (MRID 48604527). RQs were de termined 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 estimat ed by multiplying the maximum application rate by 2.7 μg a.i./bee and then compar ing it to the acute contact LD 50 

### . 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. Therefor e, while the potential exists via exposure pathways such as foliar sprays, th e 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 hone y 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 benzovi ndiflupyr’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 benzovindifl upyr. Seedling emergence and vegetative vigor studies are available for benzovindiflupyr but th ere remains uncertainty with seve ral species that were tested in the seedling emergence study (see the ecologi cal effects section for discussion of these species. The estimates of exposure gene rated 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 highe st application rate mode led (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 un certainties 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 fr om 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 th e acute or chronic LOCs when consuming fish contaminated by benzovindiflupyr and are not pr esented 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 ba sed 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 basi s, there does appear to be risk to federally listed birds consuming fish contaminated w ith 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 bobw hite 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 regurgita tion 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;; N on-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 pr edicted to adversely im pact both freshwater
and estuarine/marine fish on both an acute and a chronic basis. The proposed applications also adversely impact both freshwater and estuarine/ma rine water column invertebrates on an acute
and chronic basis. S ediment invertebrates are expect ed to have low exposures to benzovindiflupyr with RQs being less than the LOC for fish and invert ebrates 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 it s low application rate. In ad dition, 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 sp ray 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 ri sk conclusions, partic ularly for acute exposure for freshwater fish, chronic freshwater fish, a nd chronic exposure to water column freshwater invertebrates. The implementation of spray drift buffers can onl y mitigate risk for all benzovindiflupyr uses related to chronic impacts estuarine/marine fi sh 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 hi ghest exposure scenario (ME potatoes) decreases from 1.4 to slightly below the LOC threshold wit hout drift. The Tier 1 AgDrift model (version 2.1.1) indicates that a 30 ft spray drift buffe r would effectively m itigate risk with all benzovindiflupyr proposed uses for chronic estuar ine/marine invertebrate s (water column) and
chronic estuarine/marine fish. Ho wever, it is still important to note that spray drift buffers would not resolve the risks anticipated to adverse imp acts expected for acute freshwater fish, acute freshwater estuarine invertebrates, chroni c freshwater fish for all of the proposed benzovindiflupyr uses collectively.

Given benzovindiflupyr’s persiste nce 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 a quatic 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 ti me 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 wate r column and benthic por e water indicate that steady state is reached with ca. 20 years of steady labeled appli cation of benzovindiflupyr. Since

### 71 steady state concentrations are reached with in the simulation time in this evaluation, uncertainties in EECs due to continual buildup of re sidues 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 ri sks of concern for aqua tic organisms. While long-term concentrations, as shown in Figure 2 would not change chronic exposure risks of concern, short-term pulses enteri ng waterways associated with be nzovindiflupyr applications can be reduced with sparser applications of be nzovindiflupyr applicati ons 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 treate d crops are expected to resu lt in toxicologically adverse impacts considering the maximum single applic ation 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 conser vative 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/pol icy_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 conser vative 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 LD 50 

### that would likely yield a less cons ervative depiction of the actual lethal dose. The dietary study th at was received indicated that benzovindiflupyr was toxic with 70 percent mortality occurring at the lowest dose tested and pr ecluded 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 sm all total loadings of benzovindiflupyr (up to 0.272 lbs. a.i./A) considering a ll proposed uses. Furthermore, chronic exposures to benzovindiflupyr crop residues on turf grass, barle y, peanuts, and soybeans are not expected to be prevalent given foliar dissipa tion 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 exposur e modeling the risk quotien t 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 mamma ls which feed more consistently within treated fields leading to repeat exposure. However, in cas es where mammals are mo re transient in their dietary habits with feedings which may occur o ff the treated field, the dietary-based RQs may be a more relevant depiction of risk. In any cas e, 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 exposur e pathway of piscivorous birds consuming fish containing benzovindiflupyr residue and related impacts re sulting from the food web at lesser trophic levels, as indicate d 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 ti ssues is limited from a combination of low application rates and moderately high depuratio n rates, the predicted toxicity to birds, particularly from the passerine oral toxicity study with a likely highl y 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 K ow 

### = 4.3, BCF values appear to be m oderated 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 meas ured 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 insect s) are not expected via the contact or oral route on an acute basis. This is primarily due to th at exposure to benzovindifl upyr residues which are directly deposited on to treated crop foliage from spray applicati ons 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 LD 50 

### >100 ug a.i/bee; MRID 48604527), and acute oral toxicity study (non-toxic findi ng 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 app lication rates for benzovindiflupyr range from 0.68 to 0.088 lbs a.i. per acre suggesting that benzov indiflupyr 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 chroni c 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 ar e in bloom in the vicinity. Furthermore, chronic adverse impacts to bees and terrestrial invertebrates are possible especially considering the risks of concern id entified with aquatic invertebrates. Therefore, at this time, EPA presumes risk to terrestria l invertebrates and will re-visit this risk finding upon submission
of the acute and chronic larval or al 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 EC 25 

### values are used to calculate the RQs for non-listed species sugge sting that there is uncertain ty with these RQs due to nondefinitive EC 25 

### values. The RQs ranged from <0.1 for m onocots to 0.11 for listed dicots in semiaquatic areas. While there is unc ertainty in risk due to non-de finitive 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 appr oved 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 num erous studies to asse ss potential adverse outcomes from exposure to chemicals. Collectiv ely, these studies includ e acute, subchronic and chronic toxicity, including asse ssments of carcinogenicity, ne urotoxicity, developmental, reproductive, and general or systemic toxicity. These studies include e ndpoints which may be susceptible to endocrine influe nce, including effects on endocri ne target organ histopathology, organ weights, estrus cyclicity, sexual maturatio n, fertility, pregnancy rates, reproductive loss, and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and chronic studies that assess gr owth, developmental and reprod uctive effects in different taxonomic groups. As required by FFDCA section 408(p), benzovindifluypyr is subject to the endocrine screening part of the Endocrine Disruptor Screenin g Program (EDSP).

EPA has developed the EDSP to determine whet her 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 ot her such endocrine effect s as the Administrator may designate.” The EDSP employs a two-tiered approach to making th e 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 estrog en, androgen, or thyroid (E, A, or T) hormonal systems. Chemicals that go th rough Tier 1 screening and are found to have the potential to interact with E, A, or T hormonal systems will proceed to the next stag e of the EDSP where EPA will determine which, if any, of th e Tier 2 tests are necessary base d on the available data. Tier 2 testing is designed to identify a ny adverse endocrine-related eff ects 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 pest icide active ingredient s and 9 inert ingredients. A second list
of chemicals identified for EDSP sc reening was published on June 14, 2013 8 

### and includes some pesticides scheduled for registration review and chemicals found in water

. Neither of these lists
should be construed as a list of know n or likely endocri ne disruptors.

Benzovindifluypyr is not on the firs t or second list. The second lis t 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, pleas e 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 Servi ces), and the U.S. Department of Agriculture (USDA) released a summary of th eir joint Interim Approaches for assessing risks to listed species from pesticides. The Inte rim 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 prio r to a stakeholder workshop held on November 15, 2013. In addition, the EPA presented the join t 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 stake holders to comment on the Interim Approaches. As part of a phased, iterative process for developing the Inter im Approaches, the agencies will also consider public comments on the Interim Approaches in connection with the development of upcoming Registration Review decisions. Th e details of the joint Interim A pproaches are contained in the white paper “Interim Approaches for Nati onal-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 de velop and work toward implementation of the Interim Approaches to assess the potential risk s of pesticides to listed species and their designated critical habitat, this preliminary ri sk assessment for benozvindiflupyr does not contain a complete ESA analysis that includes effect s determinations for specific listed species or designated critical habitat. Although EPA has not yet complete d effects determinations for specific species or habitats, for this prelimin ary assessment, EPA conducted a screening-level
assessment for all taxa of non-ta rget wildlife and plants that assumes for the sake of the assessment that listed species and designated criti cal habitats may be present in the vicinity of the application of benzovindiflupyr. This screen ing level assessment will allow EPA to focus its future evaluations on the types of species where th e potential for effects exists once the scientific methods being developed by the agencies have b een fully vetted. This screening-level risk assessment for benzovindiflupyr indicates potentia l risks of direct effects to listed mammals, birds, terrestrial invertebrates, fish, and aquatic invertebrates on a ll of its registered use sites. Listed species of aquatic and te rrestrial plants may also be a ffected through indirect effects because of the potential for direct effect s 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 benz ovindiflupyr may be associated with modification of Primary Constituent Elements (PCEs) of designa ted critical habitats, where such designations have been made. Once the agencies have fu lly developed and implemented the scientific

### 76 methods necessary to complete risk assessments for endangered and threatened (listed) species and their designated critical habitats, these met hods will be applied to subsequent analyses for benzovindiflupyr as part of comple ting this registration review.

### 77 

## 6. UNCERTAINTIES, LIMITATIONS, AND IDENTIFICATION OF

DATA GAPS

 Labels and Proposed Uses

There is uncertainty regarding se asonal maximum application rates specified on the label. This
risk assessment evaluated one treatment and re treatment 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. Ther efore, 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 as sessment for benzovindiflupyr concerns a major deficiency in the aerobic aquatic stud ies (MRID Nos. 48604509 and 48604510). The aerobic aquatic metabolism half-life is one critical parame ter impacting acute and chronic aquatic EECs. Conditions in these studies were fringe anaerob ic (suboxic) as the crite ria for aerobic conditions taking into account redox potenti al and pH was not satisfied 10 

### . However, benzovindiflupyr is very persistent in all environmental media with ha lf-lives in the range of 620 – 1,788 days in soil and water. So, it is unlikely that benzovindiflup yr 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 utilizi ng the conservative defa ult of doubling the soil metabolism half-life to represen t the aquatic environmental bi odegradation in the modeling. However, given that benzovindiflupy r is persistent as it is, aq uatic 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 appearan ce 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 a quatic environments. These mesocosm studies modified the guideline aerobic aquatic metabolism guidelines st udy 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 rang e 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 substan tial uncertainties in each of these mesocosm studies related to incomplete material balances throughout the total aqua tic-sediment system over the study durations. In summary, there were inst ances 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. Furthe rmore, in most cases, the degradates detected in the mesocosm studies were less than 10 percent to tal of the material balance. Therefore,, there
are a lot of uncertainities with the environmental c ontext of the registrant calculated half-lives in the mesocosm studies, and the pathway of degrad ation in the water colu mn and sediment or dissipation to sediment of the material is also uncertain. Given these un certainties, the aquatic exposure assessment and the calculated estimate d exposure concentrations (EECs) relied on the more definitive results provide d in the guideline aerobic aqua tic metabolism studies without algae and macrophytes conducted under darkness (MRID Nos. 48604509 and 48604510), and are reflective of environments free of these organi sms. 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 asse ssment is that surface water aquatic exposure EECs presented for the pr oposed nationwide uses of benzovindiflupyr are
based on a finite collection of a pplication 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 cr ops, application methods, and e nvironmental conditions across the country which would result in upper-bound e xposure out of all of the proposed uses for benzovindiflupyr consistent with th e screening approach to this ri sk assessment. For instance, first, only aerial applications are evaluated for surface water for all application scenarios except where only ground spray applicatio ns are proposed for turf and ornamental uses. Aerial applications result in upper-bound EDWCs sinc e the spray drift contribution with these applications most impact water bodies. Furthe rmore, broadcast aerial applications would result in higher EECs than banded and in-furrow soil applications also pr oposed for potatoes and peanuts since these soil applica tions 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 presente d in the surface water expos ure assessment. These presented crop scenarios were selected based on the SWCC scenario which produces the highest runoff and resulting exposure out of all regiona l crop scenarios develope d 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, consider ing all of the decision points related to application ra tes, application methods, and e nvironmental regional variations
discussed above.

Despite the uncertainties described above, the dataset of environmental fate studies and ecological toxicity studies for the aquati c 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 organism s 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 th e 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 an d dietary-based acute RQ s should be provided to risk managers. The dose-based approach assume s that the uptake and absorption kinetics of a gavage toxicity study approximate the absorption a ssociated 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 t oxicant may be important and are likely variable across chemicals and species. Fo r many compounds, a gavage dose re presents a very short-term, high intensity exposure, whereas dietary exposure may involve a mo re 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 w ild and captive animals. The Wildlife Exposure Factors Handbook can provide insights into energy re quirements of animals in the wild as well as energy content of thei r diets (USEPA, 1993).

The typical 21-week avian reproduc tion study does not define the true exposure duration needed to elicit the observed responses. The study protocol was designed to establish a st eady-state tissue
concentration for bioaccumulativ e compounds. For other pesticides, it is entirely possible that steady-state tissue concentratio ns are achieved earlier than the 21-week exposure period. Moreover, pesticides may exert eff ects at critical periods of the reproduction cycl e; 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 fo r 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 fe ed on a dietary class for at least some time period. However, most birds and mammals consume a variety of di etary items and thus the RQ will overestimate risk to those organisms. Additionally, some organi sms will not feed on all of the dietary classes. For example, many amphibians would only c onsume 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 tissu es of fish which may be bioavailable to piscivorous birds.
The uncertainties are all rela ted to the existing BCF st udy 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 th e lower bound of the range of aquatic EECs for benzovindiflupyr . Despite this uncertaint y, BCFs calculated in KABAM, which served as the basis of exposure dose conc entrations for piscivor ous birds and based on upper-bound aquatic EECs, were similar in magnit ude to BCFs determined in the study, with a magnitude departure of less than 2.4 in al l cases. Secondly, only a small amount of benzovindiflupyr was detected thr oughout the study. However, it was found that depuration of total residues was rapid, with a de puration half-life of 0.54 days and that the vast majority of
total residues were removed from whole fish afte r 7 days of depuration. This suggests that the residence time of any toxic residue , including benzovindiflupyr, in fi sh 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 exception al 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 benzovindifl upyr is practically non -toxic to bees and preliminary exposure modeling and RQ analysis sugge sts that risk to adul t bees via the contact and oral exposure pathways is low. However, there are no acute or ch ronic toxicity studies submitted for larval bees or chronic feeding studi es for adult bees. There is no language on the proposed labels restricting benz ovindifluypyr applications when plants are in bloom in the vicinity. Therefore, risks to terre strial invertebrates is presumed in the absence of data and given benzonvindiflupyr’s potential bioavailability to be neficial 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 addition al bee toxicity data at this time including acute and chronic larval-stage bee toxicity st udies and chronic feeding toxicity studies for adult bees to address the potential risks to di fferent life stages of te rrestrial 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 determinati on at a definitive endpoint. EFED guidance (EPA 2012; also
online at http://www.epa.gov/pesticides/science/efed/pol icy_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 ac ute endpoint for that study”. Th erefore, the risk conclusions utilizing this endpoint would likel y 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 be nzovindiflupyr dermal e xposure to terrestrial organisms. The Agency is actively pursuing mode ling 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 sc reening risk assessment acute toxic ity data for fish are collected on juvenile fish and aquatic invertebrate acute testing is performed on recommended immature age classes. Similarly, acute diet ary testing with birds is also performed on juveniles, with mallard being 5-10 days old and qua il at 10-14 days of age.

Testing of juveniles may overestimate the toxicity of direct acting pest icides in adults. As juvenile organisms do not have fully develope d metabolic systems, they may not possess the ability to transform and detoxify xenobiotics equivalent to the olde r/adult organism. The screening risk assessment has no current provisions for a generally applie d 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 fo r Amphibians and Reptiles

Currently, toxicity stud ies on amphibians and reptiles are not required for pesticide registration. Since these data are lacking, the Agency uses fi sh 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 surroga tes, risks may be under- or overestimated, respectively. The Agency is not limited to a ba se set of surrogate toxicity information in establishing risk assessment c onclusions. The Agency also co nsiders toxicity data on nonstandard test species when available. Further research is needed to determine whether, in general, reptiles and terrestria l-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 asse ssment relies on a sele cted toxicity endpoint from the most sensitive species tested, it does not necessarily mean that the sele cted 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 distribu tion of all possible species is a function of the overall variability among species to a partic ular 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 a ddition, 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 a ssessment relies on the acute mortality endpoint as
well as a suite of sublethal res ponses to the pesticide, as dete rmined by the testing of species response to chronic exposure c onditions and subsequent chronic risk assessment. Consideration
of additional sublethal data in the effects determination is exer cised on a case-by-case basis and only after careful consideration of the nature of the sublethal eff ect 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. Howeve r, 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 c onsidered in this assessme nt, the potential direct
and indirect effects of be nzovindiflupyr on listed speci es 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 acti on, fate and transport, and the sensitivity of non-target aquatic and terrestrial species, benzovindiflupyr has th e potential to reduce survival, reproduction, and/or growth in non-target terr estrial 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 assessm ent 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 terrestr ial 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 chroni c risk to sediment dwelling invertebrates. Acute RQs derived from comparing peak porewat er concentrations to acute water column toxicity endpoints did however pr edict acute risk concerns to se diment dwelling invertebrates.
Risk above the level of concern was not identif ied 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 ra ils consuming fish contaminated with benzovindiflupyr suggesting risk through this pa thway. 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 al l size classes of mammals. Th ere was not any chronic risk identified for dietary based exposure in mammals or acute risk from the consumption of fish contaminated with benzovindiflupyr. The avai lable 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 du e to lack of toxicity data. There was not any risk identified to terrestrial plants.

The overall risk conclusions for aquatic and terr estrial 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 benzovindiflupy r, no risks to listed terrestrial plant speci es are anticipated.
Risks for direct and indirect eff ects to all terrestrial and aquatic listed species are expected. The exceptions are chronic impacts to listed benthic es tuarine/marine and freshwater invertebrates.84Table 26. Summary of adverse impacts for aquaticorganisms expected from the proposed uses ofbenzovindiflupyr.Proposed UseAdverse Impacts Expected for Aquatic Organisms? (No/Yes: A = Acute, C=Chronic)FreshwaterFishEstuarine/MarineFishFreshwaterInvertebrates(WaterColumn)Estuarine/MarineInvertebrates(WaterColumn)FreshwaterandSaltwaterBenthicInvertebrates(Sediment)FreshwaterBenthicInvertebrates(Pore water)SaltwaterBenthicInvertebrates(Pore water)AquaticPlantsCornYesA,CYesA,CYesA,CYesANoYesAYesANoCucurbitsYesA,CYesAYesAYesANo NoYesANoTomatoesand FruitingVegetablesYesA,CYesAYesA,CYesNo NoYesANoGrapesYesA,CYesA,CYesAYesANoYesAYesANoTubers(Potatoes)YesA,CYesA,CYesAYesA,CNoYesAYesANoPeanutsYesA,CYesAYesA,CYesANo NoYesANoNurseryPlants,TomatoTransplant,FruitTransplant,CucurbitTransplantYesA,CYesAYesAYesANo NoYesANoTurf GrassYesA,CNo NoNo No No No NoCottonYesA,CYesAYesAYesANo NoYesANo85Table 26. Summary of adverse impacts for aquaticorganisms expected from the proposed uses ofbenzovindiflupyr.Proposed UseAdverse Impacts Expected for Aquatic Organisms? (No/Yes: A = Acute, C=Chronic)FreshwaterFishEstuarine/MarineFishFreshwaterInvertebrates(WaterColumn)Estuarine/MarineInvertebrates(WaterColumn)FreshwaterandSaltwaterBenthicInvertebrates(Sediment)FreshwaterBenthicInvertebrates(Pore water)SaltwaterBenthicInvertebrates(Pore water)AquaticPlantsBlueberriesYesA,CYesANoYesANo NoYesANoSoybeans &LegumesYesA,CYesANoYesANo No No NoCereal(Oats,Barley, andWheat)YesA,CYesANoYesANo No No NoCanolaYesA,CYesANoNo No No No NoPome fruitYesA,CYesANoNo No No No NoRisk duration identifiers:A = AcuteC = Chronic86Table 27. Summary of adverse impacts for terrestrial organisms expected from the proposed uses of benzovindiflupyr.Proposed UseAdverse Impacts Expectedfor Terrestrial Organisms?(No/Yes: A = Acute, C=Chronic)BirdsMammalsPiscivorous BirdsPiscivorousMammalsTerrestrial PlantsTerretrialInvertebrates1CornYesAYesA,CYesANo NoYesA,CCucurbitsYesAYesA,CYesANo NoYesA,CTomatoes and FruitingVegetablesYesAYesA,CYesANoNoYesA,CGrapesYesAYesA,CYesANo NoYesA,CTubers (Potatoes)YesAYesA,CYesA,No NoYesA,CPeanutsYesAYesA,CYesANo NoYesA,CNursery Plants, TomatoTransplant, Fruit Transplant,Cucurbit TransplantYesAYesA,CYesANo NoYesA,CTurf GrassYesAYesA,CNo No NoYesA,CCottonYesAYesA,CYesANo NoYesA,CBlueberriesYesAYesA,CYesANo NoYesA,CSoybeans & LegumesYesAYesA,CYesANo NoYesA,CCereal (Oats, Barley, andWheat)YesAYesA,CNo NoNoYesA,CCanolaYesAYesAYesANo NoYesA,CPome fruitYesAYesA,CNo No NoYesA,CRisk duration identifiers:A = AcuteC = Chronic1Risk presumed in the absence of acuteand 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 w ith Passerine Species, Office of Prevention, Pesticides and Toxic Substances, Office of Pest icide 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 Fa te and Effects Division. December 17, 2012.

U.S. Environmental Protection Agency 2014. Su rface Water Concentration Calculator User Manual, Office of Prevention, Pesticides and To xic Substances, Office of Pesticide Programs,
Environmental Fate and Effect s Division. July 1, 2014.

U.S. Environmental Protection Agency. 2014. Guid ance 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 Repo rt. 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 (D egrees 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]-CSCC21061 6: Final Report. Project Number: T012282/05/OCR, NC/08/026. Unpublis hed study prepared by Battelle UK Ltd. 95p. 

## 835.1230 Sediment and soil absorpt ion/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) Benzovindifl upyr: 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 pare nt and degradates as a f unction of pH at 25 C

MRID Citation Reference

48604402 Stulz, J. (2012) Benzovindifl upyr: 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 - Hydrolys is 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 Pr operties, Further Information and Proposed Classification. Unpublis hed 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) Benzovindifl upyr: 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 Pr operties, Further Information and Proposed Classification. Unpublis hed study prepared by Syngenta Crop Protection, LLC. 29p.



## 835.2370 Photodegradation of pa rent and degradates in air

### 90 MRID Citation Reference

48604402 Stulz, J. (2012) Benzovindifl upyr: 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 Pr operties, Further Information and Proposed Classification. Unpublis hed study prepared by Syngenta Crop Protection, LLC. 29p. 

## 835.2410 Photodegradation of pa rent 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 prep ared 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 L aboratory 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 Tw o 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 prepar ed 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 Tw o 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 prepar ed 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. Pr oject Number: TK0002574/OCR, T002297/09, 242/123. Unpublis hed 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 prepar ed 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. Un published study prepared by Syngenta Crop Protection, LLC and ALS Environmental. 215p.



## Ecological Effects Studies



# 122305 Benzovindiflupyr (Solat enol) Eco Effects Bibliography Compiled 1 May 2014

850.1010 Aquatic invertebrate acute to xicity, test, freshwater daphnids

MRID Citation Reference

48604522 Fournier, A. (2012) SYN545192 - Ac ute 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 To xicity 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 - Ac ute 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 st udy 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.; Beaver s, 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.; Beaver s, J. (2011) SYN545192 - An Acute Oral Toxicity Study with the Zebra Finch (Taeniopygia guttata): Final Report. Project Number: TK0002594/OCR, 528/365. Unpublishe d study prepared by Wildlife International, Ltd. 58p.

48604598 Hubbard, P.; Beaver s, 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 Anal ytical Group (2013) SYN545192 - AN LC Study Using Dietary Expos ure 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. Unpublishe d study prepared by Wildlife International, Ltd. 67p.

49251501 Wildlife International Evans Anal ytical Group (2013) SYN545192 - AN LC Study Using Dietary Expos ure with the Zebra Finch. Project Number: 528/XXX, TK0153778. Unpublished study. 15p.



## 850.2300 Avian re production 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. Unpublishe d 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. Unpublishe d study prepared by Wildlife International, Ltd. 205p.



## 850.3020 Honey bee acut e 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 Resi dues on the Parasitic Wasp Aphidius rhopalosiphi (Hymenoptera, Braconidae ): Final Report. Project Number: TK0013031/OCR, SYN/11/8. Unpublished st udy prepared by Mambo-Tox Ltd. 30p.



## 850.4150 Terrestrial plant toxici ty, Tier 1 (vegetative vigor)

MRID Citation Reference

48604599 Porch, J.; Martin, K.; Krueger, H. (2011) SYN545192 EC (A17056F) - Toxicity Effects on the Vegetative Vi gor 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 Emerge nce 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-H our 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 Te st: Final Report. Project Number: TK0054002/OCR, D46480. Unpublished st udy 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 subc hronic 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. Unpub lished study prepared by Biochem Agrar, Labor fuer Biologische und Chemische. 36p.

### 98 48604533 Friedrich, S. (2008) CSCD465008 - Subl ethal 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 env ironmental 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: TK000257 0/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: ac ute 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: Toxici ty Test with Sediment-Dwelling Midges (Chironomus riparius) Under Static Cond itions, Using Spiked Sediment. Project Number: TK0013014, 1781/6759, 09011 0/OECD/MIDGE/SPIKED/SEDIMENT. Unpublished study prepared by Springborn Smithers Laboratories. 12 p.



# Non-Guideline

48286301 Benyon, K. (2010) Syn545192 - 28-D ay Toxicity Test Exposing Estuarine Amphipods (Leptocheirus plumulosus) to a Test Substance Applied to Sediment Following EPA Test Methods. Project Number:
101008/EPA/28/D/LEPTOCHE IRUS. Unpublished st udy prepared by Springborn Smithers Lab oratories. 12 p.

48415801 Hubbard, P. (2011) SYN545192- An Acut e Oral Toxicity Study with the Canary using a Sequential Testing Procedure: Protocol. Project Number: Syngenta Study Number, 582/021811/CLD/Seq/SUB 528. 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 st udy prepared by Mambo-Tox Ltd. 30p.

48604541 Peffer, R.; Hofstra, A.; Parsons, P. (2012) Solatenol (SYN545192): Document M-II, Section 3: Toxicological Studi es. Unpublished study prepared by Syngenta Crop Protection, LLC. 508p.

48604569 Stevens, J. (2012) Benzovindifl upyr 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 Sy ngenta Crop Protection, LLC. 5p.

49070301 Ueckermann, A.; Rezaaiyan, R.; S anchez, U. (2013) Syngenta Response to COFEPRIS, EPA and PMRA Deficiencies Noted During Completeness Check
for NAFTA Joint Review of Benzovindi flupyr Technical and Seven Associated End-Use Products - A15457TO Fungici de, A15457 Fungicide, Mural Fungicide, A18126 Fungicide, A18993 Fungici de, 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 prepa red 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 Resi dues on the Parasitic Wasp Aphidius rhopalosiphi (Hymenoptera, Braconidae ): Final Report. Project Number: TK0013031/OCR, SYN/11/8. Unpublished st udy 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 Envi ronmental Fate and Effects Di vision (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 O PP'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 su mmarized 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 potentia l to cause adverse effects on non-target organisms. LOCs currently address the followi ng risk presumption categories: (1) acute – potential for acute risk is high, regulatory action may be warranted in a ddition to restricted use classi fication (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 enda ngered 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) LC 50 (fish and birds), (2) LD 50 (birds and mammals), (3) EC 50 (aquatic plants and aquatic invertebrates, and (4) EC 25 (terrestrial plants). An example of a toxicity test effect level derived from the results of a long-term laboratory study that assesse s chronic effects is (1) NOAEC (birds, fish, and aquatic invertebrates).

Risk Presumption RQ LOC

Birds
Acute Risk EEC/LC 50 or LD 50 /sqft or LD 50 /day 0.5
Acute Restricted Use EEC/LC 50 or LD 50 /sqft or LD 50 /day (or LD 50 < 50 mg/kg) 0.2

Acute Endangered Species EEC/LC 50 or LD 50 /sqft or LD 50 /day 0.1
Chronic Risk EEC/NOAEC 1

Mammals
Acute Risk EEC/LC 50 or LD 50 /sqft or LD 50 /day 0.5
Acute Restricted Use EEC/LC 50 or LD 50 /sqft or LD 50 /day (or LD 50 < 50 mg/kg) 0.2

Acute Endangered Species EEC/LC 50 or LD 50 /sqft or LD 50 /day 0.1
Chronic Risk EEC/NOAEC 1 Aquatic Animals
Acute Risk EEC/LC 50 or EC 50 0.5
Acute Restricted Use EEC/LC 50 or EC 50 0.1 Acute Endangered Species EEC/LC 50 or EC 50 0.05
Chronic Risk EEC/NOAEC 1 Terrestrial and Semi-Aquatic Plants
Acute Risk EEC/EC 25 1 Acute Endangered Species EEC/EC 05 or NOAEC 1 Aquatic Plants
Acute Risk EEC/EC 50 1 Acute Endangered Species EEC/EC 05 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 IngestionRate (kgdry food/kgbw/day) Wet Food IngestionRate (kgwetfood/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 IngestionRate (kgdry food/kgbw/day) Wet Food IngestionRate (kgwetfood/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 EC 25 NOAEC EC 25 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, resulti ng in potential for risk to that plant group.

### 110 

## Appendix E. Sample SWCC Output File



# Summary of Water Modeling of So latenol 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 Surf ace Water Concentration Calculator (SWCC Version 1.106). Critical input
values for the model are summ arized 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 wa ter 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 dissipa tion in the water column is metabolism (effective average half-life = 6781.9 days) followed by photolysis (1 4682.8 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 Benzovindi flupyr Transformation Products in
Environmental Fate Studies

Table F-1. Benzovindiflupyr degradation produc ts 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 produc ts 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 produc ts 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 produc ts 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 produc ts 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 produc ts 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, 486045 02, and 48604511)

Pyrazole Acid (NOA449410, CSAA798670; CA4312) 0.77% at 29 days after 2 nd 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 produc ts identified in environmental fate studies.



### Degradate Identity Structure Max% of Applied and Days

Post Application Comments

SYN546039 (CSCD695908) 1.2% at 34 days after 3 rd 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 1 st application Georgia Loamy Sand Soil (MRID No. 48604511)

SYN546040 (CSCD696468) 0.6% at 91 days after 1 st application Georgia Loamy Sand Soil (MRID No. 48604511)

### 119 

## Appendix G. Ecological Toxicity Da ta for Transformat ion 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) LC 50

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 topractically 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) LC 50

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) LC 50

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) LC 50

Endpoints
Affected Toxicity
Classification (MRID) (μg a.i/L) 1,2,3

(95% CL; slope)

Species Study Type Test
Substance

(Purity) EC 50

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 )