IJNTTED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Office of Chemical Safety and 

Pollution Prevention 

PC Code: 044309 

Date: December 2nd, 20 10 

DP Barcodes: 378994,377955 

b&ct r f OAJ : +sj+q2, 46 15 74 

SUBJECT: Revised Assessment for Clothianidin Registration of Prosper T400 Seed 

Treatment on Mustard Seed (Oilseed and Condiment) and PonchoNotivo Seed 

Treatment on Cotton. / -: 

FROM: Joseph Decant, Ecologist 

Pchael Banett, Chemist 

Environmental Risk Branch V 

Environmental Fate and Effects Division (7507P) 

THROUGH: Mah T. Shamim, Branch Chief 

Environmental Risk Branch V .-CC---CC-C-- 

Environmental Fate and Effects Division 

TO: Kable Davis, Risk Manager Reviewer 

Venus Eagle, Risk Manager 

Insecticide-Rodenticide Branch 

Registration Division (7505P) 

This revised memo summarizes the Environmental Fate and Effects Division's (EFED) attached 

revised screening-level Environmental Fhsk Assessment for clothianidin. This revised memo 

and risk assessment provide more information related to the reclassification of a bee field study 

(46907801146907802) and how it impacts the conclusions of the assessment. 

The registrant, Bayer Cropscience, is submitting a request for registration of clothianidin to be 

used as a seed treatment on cotton and mustard (oilseed and condiment). The major risk 

concerns 'are with aquatic free-swimming and benthic invertebrates, terrestrial invertebrates, 

birds, and mammals. 

The proposed use on cotton poses an acute and chronic risk to freshwater and estuarinelmarine 

free-swimming invertebrates, but the risk in some cases depends on the incorporation method 

and the region of the U.S. where the crops are grown. The proposed use on mustard only shows 

a risk concern on a chronic basis to estuarinelmarine free-swimming invertebrates with a low 

TEXT SEARCHABLE DOCUMENT - 2010
efficiency incorporation method. The proposed uses result in acute risk to freshwater and 

estuarinelmarine benthic invertebrates, but incorporation and region have minimal impact on the 

risk conclusions. Chronic risk was only present for estuarinelmarine benthic invertebrates but 

was independent of incorporation efficiency and region. 

Clothianidin's major risk concern is to nontarget insects (that is, honey bees). Clothianidin is a 

neonicotinoid insecticide that is both persistent and systemic. Acute toxicity studies to honey 

bees show that clothianidin is highly toxic on both a contact and an oral basis. Although EFED 

does not conduct RQ based risk assessments on non-target insects, information from standard 

tests and field studies, as well as incident reports involving other neonicotinoids insecticides 

(e.g., imidacloprid) suggest the potential for long term toxic risk to honey bees and other 

beneficial insects. An incident in Germany already illustrated the toxicity of clothianidin to 

honeybees when allowed to drift off-site from treated seed during planting. 

A previous field study (MRID 46907801146907802) investigated the effects of clothianidin on 

whole hive parameters and was classified as acceptable. However, after another review of this 

field study in light of additional information, deficiencies were identified that render the study 

supplemental. 

In this field study, control and treated plots were each 1 hectare in size and paired, so that 4 sites 

were established with a control plot paired with a treated plot. These plots were separated by a 

minimum of 250 m. The study author states, "Of 23 back-up control nectar samples, 2 (field 

ElC, July 7; field W3C, July 7) had detectable clothianidin residues, at a maximum of 0.922 

ppb, suggesting that workers in control colonies may have foraged on clothianidin-treated 

canola. This may have occurred because the separation between some pairs of control and 

treated fields was insufficient or because the forage in some control fields was of lower 

quality. .." The inverse may also have occurred. That is, bees placed on treated fields likely 

foraged on the control fields, which would have reduced the level of exposure to clothianidin 

residues due to a lack of separation between sites. Bees have been shown to forage up to 6 km 

(Visscher and Seeley, 1982) or even twice that in some instances when no competing forage is 

present (Ratnieks, 2000). The distance of 250 m is inadequate for this separation. The 

inadequacy is evident given contamination in some of the nectar samples taken from control 

hives. 

Furthermore, the study authors state that, "Approximately 5 g of pollen was analyzed under a 

light microscope, which confirmed that bees foraged on canola, while the remainder.. .". This 

type of identification simply identifies that canola was present in the pollen samples, but does not 

quantify the proportion of canola pollen present in the sample. 'This type of pollen evaluation 

does not characterize the foraging of the bees. The bees in the treated fields could have foraged 

disproportionately on other uncontaminated sources relative to bees in the control fields. 

Furthermore, the study authors simply state that to their knowledge, no other forage was present 

with a radius of 1 km from the edge of the fields. However, given the ability of bees to forage 

long distances, this lack of data leaves uncertainty in the exposure and suggests that this study 

did not provide the worst case exposure scenario necessary for use in characterizing risk. 
An addendum (MRID 46907802) was submitted later that presented the results of the 

overwintering part of the study, which revealed that the majority of the hives, including those 

exposed to clothianidin during the previous season, survived the overwintering period. 

However, the cross-contamination in the control hives prevents a comparison between the 

control hives and the treated hives as they relate to whole hive parameters in this addendum. 

Therefore, this study can only be used to provide a qualitative description of hive survival 

following the exposure to clothianidin at the levels that were described in the study. 

It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the 

effects of clothianidin on bees through contaminated pollen and nectar. Exposure through 

contaminated pollen and nectar and potential toxic effects therefore remain an uncertainty for 

pollinators. 

EFED expects adverse effects to bees if clothianidin is allowed to drift from seed planting 

equipment. Because of this and the uncertainty surrounding the exposure and potential toxicity 

through contaminated pollen and nectar, EFED is recommending bee precautionary labeling. 

The proposed application rates and uses also pose an acute and chronic risk to small birds and 

mammals when clothianidin treated seeds are applied with low efficiency or no incorporation 

methods. 

Clothianidin does not appear to present risk to terrestrial plants (there were no significant effects 

in the studies submitted). In addition, it does not appear to present risk to aquatic vascular or 

nonvascular plants. 

Both high and low efficiency incorporation resulted in acute risk to freshwater invertebrates in 

North Carolina and Mississippi cotton, whereas cotton in California and mustard in North 

Dakota did not result in an exceedence of the LOC. These results suggest that certain regions of 

the country are more vulnerable to run-off and exposure of the proposed application rates of 

clothianidin, and therefore to the potential for the toxic effects of clothianidin to freshwater 

invertebrates. The acute lethal toxicity to benthic invertebrates also suggests this conclusion. 

These organisms are an integral part of the freshwater trophic system and serve as both 

decomposers/predators that are important for nutrient cycling and a food source for larger 

predators (e.g., fish). The ecological integrity in these vulnerable areas in the U.S. could 

therefore be impacted by the use on cotton at the proposed application rate. A reduction in the 

cotton application rate together with maximum incorporation of the seeds into the ground could 

therefore limit the exposure of clothianidin to aquatic invertebrates through run-off. 

Specific label language that clearly states a method of incorporation and incorporation depth 

would make a significant impact on other risk conclusions of the proposed new uses. Risk to 

estuarinelmarine invertebrates on an acute basis could be effectively mitigated by this label 

language, as shown by the lack of LOC exceedences in the high efficiency incorporation 

scenario (section 5.1.1). In addition, label language that would specify more efficient 
incorporation methods, such as T-banded incorporation with a specified depth, would eliminate 

all risk to birds and mammals by burying the seeds into the ground and thereby limiting any 

foraging on these seeds. 

Outstanding Data Requirements 

Environmental Fate: 

162-4 Aerobic Aquatic metabolism Study. Based on the additional information submitted by the 

registrant, EFED agreed to change the previously-reviewed aerobic aquatic metabolism study 

(MRID 45422324) from "unacceptable" to "supplemental". However, the aerobic aquatic 

metabolism data requirements are still not fulfilled? the registrant must submit a new aerobic 

aquatic metabolism study. Reasons are presented below: 

1. The potential for clothianidin to move from the treated area to the nearby surface water body 

has been increased significantly since 2003 because the registrant has recently added new uses 

on the labels. According to the review completed on 212012003 (Title - "EFED Risk 

Assessment for the Seed Treatment of Clothianidin 600E'S on Corn and Canola", the Agency 

required the registrant to conduct a new aerobic aquatic metabolism study (162-4). This risk 

assessment was based on the maximum application rate for the seed treatment at 0.1 Ib ai/A. 

However, according to the new uses reviewed by EFED (Turfgrass, Tobacco, Apples, Pears, and 

Ornamentals), this chemical can be directly applied to the soil surface/foliage at much higher 

application rate (0.4 lbs ai1A). As a result, the potential for clothianidin to move from the treated 

area to the nearby surface water body under the new uses is much greater than the use as a seed 

treatment. Therefore, there is a need for a better understanding of the fate of clothionidin in the 

aerobic aquatic environment. 

2. The fate of the thiazolyl ring was not monitored in the previously-reviewed aerobic aquatic 

metabolism study (MRID 45422324) because the test substance was labeled on the nitroimino 

side chain. Therefore, the fate of the thiazolyl ring remains unknown. The fate guidelines 

recommend to use the ring-labeled test substance. 

3. A well-designed new aerobic aquatic metabolism study is deemed critical for EPA to fully 

assess the risk of clothionidin in the aquatic environment. 

166-1 Small-Scale Prospective Groundwater Monitoring. Study. Due to direct soil and foliar 

applications of clothianidin and concerns about the chemical leaching into ground water (see 

below), the Agency will request the registrant to submit a small-scale prospective groundwater 

monitoring study. 

Source: EPA review "EFED Risk Assessment for the Seed Treatment of Clothianidin 

600FS on Corn and Canola" dated February 20, 2003 (page 3): 

"Clothianidin has the properties of a chemical which could lead to widespread groundwater contamination, but no ground-water monitoring studies have been conducted to 

date. Should the registrant request field uses involving direct application of clothianidin 
to the land surface, Prospective Ground-Water Monitoring Studies may be needed to 

evaluate fully the potential impact of such uses." Due to the extreme mobility and 

persistence of clothianidin in the environment, a small-scale prospective groundwater 

monitoring study will provide additional fate information on the better understanding of 

this chemical in the environment and improve the certainty of the risk assessment. 

Seed Leaching Study: EFED believes that a seed leaching study would greatly increase 

certainty regarding a more realistic estimate of the amount of available clothianidin residues on 

the seed surface. This in turn would allow a refinement of exposure estimates and environmental 

concentration values (EECs). A study has been submitted to the Agency and is currently under 

review (NIRID 47483002). 

Ecological Effects: 

The database available for clothianidin to support the assessment was largely complete. The 

following ecological studies for clothianidin are still outstanding and need to be submitted. 

Honey Bee Toxicity of Residues on Foliage (850.3030): This study is required for chemicals 

that have outdoor terrestrial uses in which honeybees will be exposed and exhibit an LD50 < 

11 pg a.i./bee. The study that was submitted to satisfy this guideline is supplemental but does not 

satisfy the guideline requirement. This study is not required for this assessment due to the lack 

of exposure to residues on foliage from the seed treatments. This study is placed in reserve 

pending future new uses. 

Field Test for Pollinators (850.3040): The possibility of toxic exposure to nontarget pollinators 

through the translocation of clothianidin residues that result from seed treatments has prompted 

EFED to require field testing (850.3040) that can evaluate the possible chronic exposure to 

honey bee larvae and queen. In order to fully evaluate the possibility of this toxic effect, a field 

study should be conducted and the protocol submitted for review by the Agency prior to 

initiation. Another study had been submitted to satisfy this guideline requirement. While it had 

originally been classified as acceptable, after recent reevaluation it is classified as supplemental, 

and a field study is still being needed for a more refined risk assessment. 

Algal Toxicity (850.5400): Data on four species of non-vascular plants is required. A study on 

only one species has been submitted to date on Selenastrum capricornutum. 

EFED Label Recommendations 

Label Recommendations 

Manufacturing Use Product 

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or 

other waters unless in accordance with the requirements of a National Pollutant Discharge 

Elimination System (NPDES) permit and the permitting authority has been notified in writing 
prior to discharge. Do not discharge effluent containing this product to sewer systems without 

previously notifying the local sewage treatment plant authority. For guidance contact your State 

Water Board or Regional Office of the EPA. 

End Use Products 

This product is toxic to aquatic invertebrates. Do not apply directly to water or to areas where 

surface water is present or to intertidal areas below the mean high-water mark. Do not 

contaminate water when cleaning equipment or disposing of equipment washwaters. Do not 

apply where runoff is likely to occur. Runoff from treated areas may be hazardous to aquatic 

organisms in neighboring areas. Apply this product only as specified on the label. 

This chemical has properties and characteristics associated with chemicals detected in ground 

water. The use of this chemical in areas where soils are permeable, particularly where the water 

table is shallow, may result in ground water contamination. 

This compound is toxic to birds and mammals. Treated clothianidin seeds exposed on soil 

surface may be hazardous to birds and mammals. Cover or collect clothianidin seeds spilled 

during loading. 

This compound is toxic to honey bees. The persistence of residues and potential residual toxicity 

of Clothianidin in nectar and pollen suggests the possibility of chronic toxic risk to honey bee 

larvae and the eventual instability of the hive. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Environmental Fate and Ecological Risk Assessmei~tfor .the Registration of 

CLOTHIANIDIN for Use as a Seed Treatment on 

Mustard Seed (Oilseed and Condiment) and Cotton 

ate: 12/02/10 

oseph Decant, Ecologist 

ichael Barrett, Chemist United States Environmental Protection Agenc 

Office of Pesticide Progra 

Environmental Fate and Effects Div 

Environmental Risk Bran ah T. Shamim, Chief 1200 Pennsylvania Ave., 

Mail Code 7507 
Table of Contents 

1 a Executive Summary ............................................................................................................... 10 

1.1 Potential Risk to Non-Target Organisms ........................................................................ 10 

1.2 Exposure Characterization .............................................................................................. 11 

1.3 Effects Characterization .................................................................................................. 12 

1.4 Data Gaps and Uncertainties ........................................................................................... 13 

2 Problem Formulation ............................................................................................................. 16 

2.1 Nature of Regulatory Action ........................................................................................... 16 ... 2.2 Stressor Source and Distribution ..................................................................................... 16 

2.2.1 Nature of the Chemical Stressor .............................................................................. 16 

2.2.2 Overview of Clothianidin Usage ............................................................................ 17 

2.3 Receptors ......................................................................................................................... 20 

2.3.1 Aquatic and Terrestrial Receptors and Effects ........................................................ 20 

2.3.2 Ecosystems Potentially at Risk ................................................................................ 21 

2.4 Assessment Endpoints ..................................................................................................... 21 

2.5 Conceptual Model ........................................................................................................... 21 

2.5.1 Risk Hypothesis ....................................................................................................... 22 

2.5.2 Conceptual Diagram ................................................................................................ 23 

2.6 Analysis Plan ................................................................................................................... 24 

2.6.1 Methods of Conducting Ecological Risk Assessment and Identification of Data 

Gaps ................................................................................................................................ -24 

2.6.2 Outstanding Data Requirements ............................................................................. -28 

2.6.3 Measures of Effect and Exposure ............................................................................ 30 

3 Exposure Assessment ............................................................................................................ 31 

3.1 Aquatic Exposure Estimates ........................................................................................... 33 

3.2 Terrestrial Exposure Estimates ....................................................................................... 39 

4 Ecological Effects Assessment .............................................................................................. 40 

4.1 Aquatic Effects Summary ............................................................................................... 40 

4.1.1 Freshwater and Marine Fish ........................................................................................ 40 

4.1.2 Freshwater and Marine Invertebrates .......................................................................... 40 

4.1.3 Aquatic Plants .............................................................................................................. 43 

4 .. 2 Terrestrial Effects Summary ........................................................................................... 43 

4.2.1 Toxicity Effects on Terrestrial animals ................................................................... 43 

4.2.2 Toxicity Effects on Invertebrates ............................................................................. 43 

4.2.3 Toxicity Effects on Terrestrial Plants ...................................................................... 44 

4.3 Incident Database Review ............................................................................................... 44 . . 5 Risk Characterization ............................................................................................................. 45 

5.1 Risk Estimation ............................................................................................................... 45 

5.1.1 Aquatic Risk Quotients ............................................................................................ 46 

5.1.2 Terrestrial Risk Quotients ........................................................................................ 49 

5.2 Risk Description .............................................................................................................. 49 

5.2.1 Risk to Aquatic Organisms ...................................................................................... 50 

5.2.2 Risk to Terrestrial Organisms .................................................................................. 51 

5.2.3 RiskRefinement ...................................................................................................... 54 
5.3 Uncertainties ................................................................................................................... 55 

5.3.1 Exposure and Effects Assessment ........................................................................... 55 

6 Bibliography .......................................................................................................................... 55 

List of Tables 

Table 1 . Summary of physicochemical properties of clothianidin ............................................... 16 

Table 2 . Use information for the proposed use of clothianidin on seeds as an insecticide ........... 18 

Table 3 . Test species evaluated for assessing potential ecological effects of clothianidin .......... 20 

Table 4 . Environmental fate data requirements for clothianidin .................................................. 24 

Table 5 . Ecological effects data requirements for clothianidin ................................................... 26 

Table 6 . Measures of effect and exposure for clothianidin .......................................................... 30 

Table 7 . Input parameters for PRZMIEXAMS for the calculation of aquatic and benthic EECs of 

clothianidin ................................................................................................................................... -34 

Table 8 . Estimated Environmental Concentrations for Clothianidin in Surface Water ................ 37 

Table 9 . Estimated Environmental Concentrations for Clothianidin in Benthic (soil-pore) Water . ...................................................................................................................................................... -37 

Table 10 . Estimated bound sediment concentrations for clothianidin .......................................... 38 

Table 11 . Top soil / sediment organic carbon fraction by PRZMEXAMS scenario ................... 38 

Table 12 . Bound Sediment Concentrations for Clothianidin normalized to Organic Carbon 

content ............................................................................................................................................ 38 

Table 13 . Summary of aquatic risk quotients for fish and aquatic invertebrates based on surface 

water EECs .................................................................................................................................... 46 

Table 14 . Summary of aquatic acute risk quotients for benthic aquatic invertebrates based on 

pore water EECs ............................................................................................................................ 47 

Table 15 . Summary of aquatic acute risk quotients for benthic aquatic invertebrates based on 

sediment bound (organic carbon normalized) EECs ..................................................................... 47 

Table 16 . Summary of aquatic chronic risk quotients for benthic aquatic invertebrates based on 

sediment bound (organic carbon normalized) EECs ..................................................................... 48 

Table 17 . Summary of Terrestrial Acute and Chronic Risk Quotients .......................................... 49 

List of Figures 

Figure 1 . Conceptual diagram depicting potential risks to terrestrial and aquatic animals from 

the use of clothianidin as a seed-treatment insecticide .................................................................. 23 

List of Appendices 

Appendix A . REX Methodology to Calculated Nagy Doses (EECs) and Risk Quotients for Birds 

and Mammals ................................................................................................................................. 57 

Appendix B . Summary of Ecotoxicity Data ................................................................................. 58 

Appendix C . The Risk Quotient Method and Levels of Concern .................................................. 72 

Appendix D: Equilibrium Partitioning and Concentration in the Sediment .................................. 73 

Appendix E: Aquatic Exposure Model Input and Output ............................................................. 75 
1. Executive Summary 

The Environmental Fate and Effects Division (EFED) has completed its ecological risk 

assessment in support of the proposed new uses of PONCHONOTiVO on cotton seed and 

Prosper T400 Insecticide and Fungicide Treatment on Mustard seed (oilseed and condiment) 

(Clothianidin as the active ingredient). The major risk concerns are with aquatic free-swimming 

and benthic invertebrates, terrestrial invertebrates, birds, and mammals. 

1 .I Potential Risk to Non-Target Organisms 

The proposed use on cotton poses an acute and chronic risk to freshwater and estuarinelmarine 

free-swimming invertebrates, but the risk in some cases depends on the incorporation method 

and the region of the U.S. where the crops are grown. The proposed use on mustard only shows 

a risk concern on a chronic basis to estuarinelmarine free-swimming invertebrates with a low 

efficiency incorporation method. While EFED does not currently have an established method of 

assessing risk to benthic freshwater and estuarinelmarine invertebrates, there is the potential for 

risk when the EECs are compared with the toxicity endpoints for these taxa related to the 

proposed use on cotton. However, the potential risk only extends to threatened and endangered 

freshwater species for the mustard use. 

Clothianidin's major risk concern is to nontarget insects (that is, honey bees). Clothianidin is a 

neonicotinoid insecticide that is both persistent and systemic. Acute toxicity studies to honey 

bees show that clothianidin is highly toxic on both a contact and an oral basis. Although EFED 

does not conduct RQ based risk assessments on non-target insects, information from standard 

tests and field studies, as well as incident reports involving other neonicotinoids insecticides 

(e.g., imidacloprid) suggest the potential for long term toxic risk to honey bees and other 

beneficial insects. An incident in Germany already illustrated the toxicity of clothianidin to 

honeybees when allowed to drift off-site from treated seed during planting. 

A previous field study (MRID 46907801146907802) investigated the effects of clothianidin on 

whole hive parameters and was classified as acceptable. However, after another review of this 

field study in light of additional information, deficiencies were identified that render the study 

supplemental. It does not satisfy the guideline 850.3040, and another field study is needed to 

evaluate the effects of clothianidin on bees through contaminated pollen and nectar. Exposure 

through contaminated pollen and nectar and potential toxic effects therefore remain an 

uncertainty for pollinators. 

EFED expects adverse effects to bees if clothianidin is allowed to drift from seed planting 

equipment. Because of this and the uncertainty surrounding the exposure and potential toxicity 

through contaminated pollen and nectar, EFED is recommending bee precautionary labeling. 

The proposed application rates and uses also pose an acute and chronic risk to small birds and 

mammals when clothianidin treated seeds are applied with low efficiency or no incorporation 

methods. 

10 
Clothianidin does not appear to present risk to terrestrial plants (there were no significant effects 

in the studies submitted). In addition, it does not appear to present risk to aquatic vascular or 

nonvascular plants. 

Both high and low efficiency incorporation resulted in acute risk to freshwater invertebrates in 

North Carolina and Mississippi cotton, whereas cotton in California and mustard in North 

Dakota, regardless of incorporation method, did not result in an exceedence of the LOC. These 

results suggest that certain regions of the country are more vulnerable to run-off and exposure 

from the proposed application rates of clothianidin, and therefore to the potential for the toxic 

effects of clothianidin to freshwater invertebrates. These organisms are an integral part of the 

freshwater trophic system and serve as both decomposers/predators that are important for 

nutrient cycling and a food source for larger predators, such as fish. The ecological integrity in 

these vulnerable areas in the U.S. could therefore be impacted by the use on cotton at the 

proposed application rate. A reduction in the application rate together with maximum 

incorporation of the seeds into the ground could therefore limit the exposure of clothianidin to 

aquatic invertebrates through run-off. 

Specific label language that clearly states a method of incorporation would make a significant 

impact on other risk conclusions of the proposed new uses. Acute risk to free-swimming 

estuarinelmarine invertebrates on an acute basis could be effectively mitigated by this label 

language, as shown by the lack of LOC exceedences in the high efficiency incorporation 

scenario (section 5.1.1). In addition, label language that would specify certain high efficiency 

incorporation methods, such as T-banded incorporation, would eliminate all risk to birds and 

mammals by burying the seeds into the ground and thereby limiting any foraging on these seeds. 

1.2 Exposure Characterization 

Clothianidin appears to be a persistent compound under most field conditions. Based on analysis 

of the laboratory studies alone, the major route of dissipation for clothianidin would appear to be 

photolysis if exposure to sunlight occurs (e.g., the measured aqueous photolysis half-life was <1 

day and aerobic half-lives were 148 to 1155 days). Although photolysis appears to be much more 

rapid than other avenues of degradationldissipation of clothianidin in the laboratory studies, the 

very slow rate of dissipation that was observed in field studies suggests that photolysis probably 

is not significant under most actual-use conditions. Photolysis may be quite important in surface 

waters if residues have reached clear bodies of water and are in solution rather than bound to 

sediment. Clothianidin is stable to hydrolysis at environmental pHs and temperatures. 

Degradation is also relatively rapid under anaerobic aquatic conditions (overall half-life of 27 

days); however, metabolic degradation occurs very slowly in aerobic soil. Clothianidin is mobile 

to highly mobile in the laboratory [soil organic carbon partition coefficients (Koc) values were 

84 to 129 for all test soils except for a sandy loam soil which had a Koc value of 3451, although 

only a modest amount of leaching was observed in the submitted field studies. Previous studies 

have confirmed that compounds with a similar combination of mobility and persistence 

characteristics have a potential to leach to ground water at some use sites. Volatilization is not 

expected to be a significant dissipation process. 
1.3 Effects Characterization 

The acute studies that were submitted that tested the parent compound showed that clothianidin 

is practically non-toxic to freshwater fish (LC5o >105.8 -1 17 pprn). Studies on degradates 

(TMG, MNG, and TZNG) indicated a similar practically non-toxic profile (LC50 >I05 pprn). A 

chronic early life stage study conducted on the fathead minnow showed that exposure of 20 ppm 

has the potential to affect length and dry weight of freshwater fish. The data submitted for 

estuarinelmarine fish on an acute basis showed that the LC50 = 93.6 ppm; therefore, clothianidin 

is categorized as slightly toxic. No study has been submitted on the chronic effects to 

estuarinelmarine fish. 

Available data that was submitted that tested the parent compound showed that clothianidin is 

practically non-toxic to Daphnia magna with an acute 48-hour EC50 value of >I19 ppm, but that 

it is very highly toxic to Chironomus riparius with an acute 48-hour ECso value of 0.022 ppm. 

Additional data (48-hour EC50) on degradates (TZNG, MNG, and TMG) indicated a practically 

non-toxic to slightly toxic profile (ECSo = 64.0 to >115.2 ppm). The data showed that 

clothianidin significantly reduced survival of mysid shrimp at 0.051 ppm, categorizing the 

compound as very highly toxic. Clothianidin was categorized as practically non-toxic to Eastern 

oyster because adverse effects did not occur for this species up to concentrations of 129.1 ppm. 

Regarding chronic toxicity to invertebrates, clothianidin has the potential for chronic toxicity to 

daphnids and possibly other freshwater invertebrates. Exposure to 0.12 pprn can result in 

reproductive effects, including the reduced number of juveniles produced per adult. The data 

submitted also indicate that clothianidin reduced the number of young per reproductive day at 

9.7 ppb. 

Two studies were submitted that assessed toxicity to sediment dwelling freshwater and 

estuarine/marine invertebrates. One study (MRID 46826902) assessed the toxicity to the midge 

(Chironomus riparius) during a 10-Day sediment exposure. This study revealed an LCso of 11 

ppb and a NOAEC of 1.1 ppb based on pore water concentrations. The other study (MRID 

47199401) evaluated a 10-day whole sediment toxicity test with Leptocheirus plumulosus using 

spiked sediment This study revealed an LCso of 20.4 ppb and a NOAEC of 11.6 ppb based on 

pore water concentrations. Therefore, clothianidin is very highly toxic to sediment dwelling 

aquatic invertebrates. 

Studies submitted for two of the five recommended species showed that exposure to clothianidin 

at levels greater than or equal to 3.5 ppm reduced biomass of aquatic non-vascular plants and 

increased the incidence of necrotic fronds in aquatic vascular plants. Studies on degradates 

(TMG, MNG and TZNG) showed reductions in green algal cell density when exposed to levels 

> 1.46 pprn 

An extensive assessment of the potential exposure and risk to avian guideline species exposed to 

clothianidin by oral intubation or in the diet concluded that clothianidin was moderately toxic to 

bobwhite quail on an acute basis (LD50> 200 mgkg) and non-toxic to the mallard duck and 

bobwhite quail on a sub-acute basis (5 day LC50 >5040 pprn and 5230 pprn), respectively. The 

submitted chronic toxicity data show that exposure of 525 pprn of clothianidin in the diet 

12 
adversely affected eggshell thickness (MRID 45422421). 

Likewise, an assessment of potential exposure and risk to small mammals exposed to 

clothianidin by the oral route suggests that clothianidin is moderately toxic to small mammals on 

an acute oral basis (mouse LD50 = 389 to 465 mgkglday). Reproduction studies in rats indicate 

that concentrations of 500 ppm clothianidin resulted in increased stillbirths and delayed sexual 

maturation in males. Developmental studies in rabbits indicate that concentrations of 75 

mgkglday resulted in premature deliveries, decreased gravid uterine weights, and increased litter 

incidence of missing lung lobeslfetus. 

Currently, EFED does not assess risk to nontarget insects or terrestrial invertebrates using the 

risk quotient method. However, it appears that clothianidin exposure to honeybees has the 

potential for high toxicity on both an acute contact and oral basis. Acute toxicity studies to 

honey bees show that clothianidin has the potential to be highly toxic on both a contact and an 

oral basis (contact LD50 = 0.044 y g/bee; oral LD50 = 0.0037 pglbee), while its degradates (e.g.,, 

TMG, MNG, TZMU, and TZNG) are moderately to practically non-toxic on an oral basis (LD50 

= 3.9 - >I53 pghee). One honey bee field study (MRID 45422435) showed that mortality, 

pollen foraging activity, and honey yield were negatively affected by residues of clothianidin; 

however, residues were not quantified in this study. Another honey bee field study (MRID 

45422440) showed that pollen treated with clothianidin at a measured concentration level up to 

19.7 pg a.i./kg produced no significant adverse effects to mortality, foraging activity (including 

pollen and honey collection), comb production, honey storage behavior, population growth 

(including egg, larvae, pupae, and adult growth stages), and behavioral anomalies. However, 

only one replicate hive per treatment level was tested, therefore, statistical analysis of the data 

could not be performed. 

Subchronic invertebrate toxicity studies showed that clothianidin adversely affected earthworm 

mortality and body weight (LC50 = 15.5 ppm) and its degradates reduced body weight (LC50 = 

982.6 ppm). There were no apparent effects of clothianidin on earthworm reproduction or 

population dynamics. 

For terrestrial plants, the studies that were submitted tested formulated products of clothianidin 

(49.3% TI-435 50% WDG). The results of these studies showed that exposure elicited no effect 

(that is, 2 25%) on non-target terrestrial plants. 

1.4 Data Gaps and Uncertainties 

Outstanding Data Requirements 

Environmental Fate: 

162-4 Aerobic Aquatic metabolism Studv. Based on the additional information submitted by the 

registrant, EFED agreed to change the previously-reviewed aerobic aquatic metabolism study 

(MRID 45422324) from "unacceptable" to "supplemental". However, the aerobic aquatic 

metabolism data requirements are still not fulfilled, the registrant must submit a new aerobic 

aquatic metabolism study. Reasons are presented below: 

13 
1. The potential for clothianidin to move from the treated area to the nearby surface water body 

has been increased significantly since 2003 because the registrant has recently added new uses 

on the labels. According to the review completed on 212012003 (Title - "EFED Risk 

Assessment for the Seed Treatment of Clothianidin 600FS on Corn and Canola", the Agency 

required the registrant to conduct a new aerobic aquatic metabolism study (162-4). This risk 

assessment was based on the maximum application rate for the seed treatment at 0.1 lb ai/A. 

However, according to the new uses reviewed by EFED (Turfgrass, Tobacco, Apples, Pears, 

and Ornamentals), this chemical can be directly applied to the soil surfacelfoliage at much 

higher application rate (0.4 Ibs aiIA). As a result, the potential for clothianidin to move from the 

treated area to the nearby surface water body under the new uses is much greater than the use as 

a seed treatment. Therefore, there is a need for a better understanding of the fate of clothionidin 

in the aerobic aquatic environment. 

2. The fate of the thiazolyl ring was not monitored in the previously-reviewed aerobic aquatic 

metabolism study (MRID 45422324) because the test substance was labeled on the nitroimino 

side chain. Therefore, the fate of the thiazolyl ring remains unknown. The fate guidelines 

recommend to use the ring-labeled test substance. 

3. A well-designed new aerobic aquatic metabolism study is deemed critical for EPA to fully 

assess the risk of clothionidin in the aquatic environment. 

166-1 Small-Scale Prospective Groundwater Monitoring Study. Due to direct soil and foliar 

applications of clothianidin and concerns about the chemical leaching into ground water (see 

below), the Agency will request the registrant to submit a small-scale prospective groundwater 

monitoring study. 

Source: EPA review "EFED Risk Assessment for the Seed Treatment of Clothianidin 

600FS on Corn and Canola" dated February 20,2003 (page 3): 

"Clothianidin has the properties of a chemical which could lead to widespread groundwater contamination, but no ground-water monitoring studies have been conducted to 

date. Should the registrant request field uses involving direct application of clothianidin 

to the land surface, Prospective Ground-Water Monitoring Studies may be needed to 

evaluate fully the potential impact of such uses." Due to the extreme mobility and 

persistence of clothianidin in the environment, a small-scale prospective groundwater 

monitoring study will provide additional fate information on the better understanding of 

this chemical in the environment and improve the certainty of the risk assessment. 

Seed Leaching Study: EFED believes that a seed leaching study would greatly increase 

certainty regarding a more realistic estimate of the amount of available clothianidin residues on 

the seed surface. This in turn would allow a refinement of exposure estimates and environmental 

concentration values (EECs). A study has been submitted to the Agency and is currently under 

review (MRID 47483002). 
Ecological Effects: 

The database available for clothianidin to support the assessment was largely complete. The 

following ecological studies for clothianidin are still outstanding and need to be submitted. 

Honey Bee Toxicity of Residues on Foliage (850.3030): This study is required for chemicals 

that have outdoor terrestrial uses in which honeybees will be exposed and exhibit an LD50 < 

1 lpg a.i./bee. The study that was submitted to satisfy this guideline is supplemental but does not 

satisfy the guideline requirement. This study is not required for this assessment due to the lack 

of exposure to residues on foliage from the seed treatments. This study is placed in reserve 

pending future new uses. 

Field Test for Pollinators (850.3040): The possibility of toxic exposure to nontarget pollinators 

through the translocation of clothianidin residues that result from seed treatments has prompted 

EFED to require field testing (850.3040) that can evaluate the possible chronic exposure to 

honey bee larvae and queen. In order to fully evaluate the possibility of this toxic effect, a field 

study should be conducted and the protocol submitted for review by the Agency prior to 

initiation. Another study had been submitted to satisfy this guideline requirement. While it had 

originally been classified as acceptable, after recent reevaluation it is classified as supplemental, 

and a field study is still being needed for a more refined risk assessment. 

Algal Toxicity (850.5400): Data on four species of non-vascular plants is required. A study on 

only one species has been submitted to date on Selenastrum capricornutum. 

Uncertainties 

The uncertainties associated with clothianidin exposure in the environment are mainly focused in 

these areas: 

Accumulation of clothianidin in soils after repeated uses and the potential for 

transport/migration to surface water bodies and potential risk to sensitive aquatic 

invertebrates (e.g., sediment-dwelling benthic organisms) 

Label language that specifies the method of incorporation 

Potential toxic risk to pollinators (e.g. honeybees) as the result of accumulation from seed 

treatments andfor foliar spray on plants/blooms from repeated uses in cotton and mustard 

Repeated or continuous exposure to soil invertebrates and small mammals to clothianidin 

accumulated in soils after repeated uses. 

Data Gaps: The data gaps that were outlined in Section 2.6.1 were either required or 

conditionally required for clothianidin and still have to be submitted. Acceptable data 

from these studies will aid in reducing some of the uncertainty associated with this 

assessment. 

For terrestrial screening risk assessments, a generic bird or mammal is assumed to occupy either 

the treated field or adjacent areas receiving pesticide at a rate commensurate with the treatment 

rate on the field. The actual habitat requirements of any particular terrestrial species are not 

considered, and it is assumed that species exclusively and permanently occupy the treated area 
being modeled. This assumption leads to a maximum level of exposure in the risk assessment. 

In the absence of specific data, EFED assumes the most conservative scenario. Screening-level 

risk assessments for spray applications of pesticides usually consider dietary exposure alone. 

2 Problem Formulation 

The purpose of this problem formulation is to provide the foundation for the environmental fate 

and ecological effects risk assessment being conducted for the seed treatment insecticides with 

clothianidin. Additionally, this problem formulation is intended to identify data gaps, 

uncertainties, and potential assumptions to address those uncertainties relative to characterizing 

the risk associated with the registered uses of clothianidin, which is a neonicotinoid with current 

uses as a seed treatment application. 

2.1 Nature of Regulatory Action 

Under the authority of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), Bayer 

Cropsciences is seeking registration for the new uses of Clothianidin as a seed-treatment 

insecticide in cotton and mustard (oilseed and condiment). 

2.2 Stressor Source and Distribution 

2.2.1 Nature of the Chemical Stressor 

A summary of selected physical and chemical parameters for clothianidin is presented in Table 

1. 

Table 1. Summary of physicochemical properties of clothianidin. 

Physical-Chemical and Other Properties - - - - 

CAS Name 

IUPAC Name 

[C(E)]-N-[(2-chloro-5-thiazolyl)methyl]-N'-methyl-N '-nitruguanidine 

(E)- 1-(2-Chloro- 1,3-thiazol-5-ylmethyI)-3-methyl-2-nitroguanidine 

I 

I PesticideType 1 Insecticide I 

CAS No 

Empirical Formula 

Molecular Weight 

Common Name 

I Chemical Family I Neonicotinoid 1 

2 10880-92-5 (previously 2055 10-53-8) 

C6H8CIN502S 

249.7 

Clothianidin 
Although nicotine has been used as a pesticide for over 200 years, it degraded too rapidly in the 

environment and lacked the selectivity to be very useful in large scale agricultural situations. 

However, in order to address this problem, the neonicotinoids (chloronicotinyl insecticides) were 

developed as a substitute of nicotine, targeting the same receptor site (AChR) and activating 

post-synaptic acetylcholine receptors but not inhibiting AChE. Clothianidin, like other 

neonicotinoids, is an agonist of acetylcholine, the neurotransmitter that stimulates the nAChR. In 

insects, neonicotinoids cause symptoms similar to that of nicotine. The symptoms appear rapidly 

as increased restlessness followed by violent convulsions and death. The advantage of 

clothianidin and othcr neonicotinoids over nicotine is that they are less likely to break down in 

the environment. 

Physical-Chemical and 

Color/Form 

Odor 

Melting Point 

Flash Point 

Relative Density 

Water Solubility 

Solubility in other 

solvents 

Vapor Pressure 

Henry's Law Constant 

Kow 

2.2.2 Overview of Clothianidin Usage 

This assessment is intended to address the proposed new uses of clothianidin as a seed treatment 

for cotton and mustard (oilseed and condiment). The crop, target pests, and relevant application 

information are summarized in Table 2. 

Other Properties 

Clear and colorless/solid, powder 

odorless 

176.8"C 

NI A 

1.6 1 glml (at 20°C), 1.59 dcm3 

0.327gL (at 20°C) 

heptane <O.U0104 g/L (at 25°C) 

xylene 0.0128 

dichloromethane 1.32 

methanol 6.26 

octanol0.938 

acetone 15.2 

ethyl acetate 2.03 

3.8 x10-" Pa (at 20°C) 

2.9 x 10.'' Pa x m3Imol 

1.12 (at pH 7) 
Table 2. Use information for the proposed use of clothianidin on seeds as an insecticide. 

Uses being evaluated for D377955 and D378994 are in bolded dark blue text. 

Summary of Directions for Use of Clothianidin Seed Treatments, 

I I I I I 

Root Vegetables (Group 1) 

Use Directions and Limitations 

lb ai/A 

- - 

Bulb Vegetables (Group 3) 

Applic. Timing, Type, 

and Equip. 

Seed treatment using 

commercial seed 

treatment equipment 

only 

I I I 

Leafy Green Vegetables (Subgroup 4A) 

Form. 

[EPA Reg. No.] 

Application Rates ' 

Radish: 0.45 

Carrot: 0.1 18 

56.25% WP 

[264-XXX] 

Seed treatment using 

commercial seed 

treatment equipment 

only 

Bramica Leafy Vegetables (Group 5) 

g ail1000 seeds 

Bulb onion: 0.1 8 

Green onion: 

0.106 

Leek: 0.20 

56.25% WP 

[264-XXX] 

Seed treatment using 

commercial seed 

treatment equipment 

only 

oz ail 1000 

seeds 

Radish: 

0.0 1575 

Carrot: 

0.0042 

56.25% WP 

[264-XXX] 

Do not use treated 

seed for food, feed 

or oil processing. 

Seed treatment using 

commercial seed 

treatment equipment 

only 

Bulb onion: 

0.006 

Green onion: 

0.0037 

Leek: 0.007 1 

Head Lettuce: 

0.798 

Leaf Lettuce: 0.64 

Spinach: 0.16 

Radish: 0.50- 

0.67 

Carrot: 0.10- 

0.25 

Head 

Lettuce: 

0.70-2.25 

Leaf Lettuce: 

0.68-2.26 

Spinach: 

0.09-0.2 1 

Head Lettuce: 

0.028 

Leaf Lettuce: 

0.0225 

Spinach: 

0.0055 

56.25% WP 

[264-XXX] 

Fruiting Vegetables (Group 8 j 

Do not use treated 

seed for food, feed 

or oil processing. 

Bulb onion: 

0'06-0' l9 

Green onion: 

0'23-0'42 Leek: 0.30- 

0,35 

Do not use treated 

seed for food, feed 

or oil processing. 

Do not use treated 

seed for food, feed 

or oil processing, 

Cabbage: 1.193 

Broccoli: 1.193 

Mustard Greens: 

0.0995 

Seed treatment using 

commercial seed 

treatment equipment 

on1 y 

Tomato: 0.099 

Pepper: 0.495 

56.25% WP 

[264-XXX] 

Cabbage: 

0.04 16 

Broccoli: 

0.0416 

Mustard 

Greens: 

~ 

0.0035 

Cabbage: 

0.06-0.44 

Broccoli: 

0.39-0.42 

Mustard 

Greens: 0.03- 

0.16 

Tomato: 

0.0035 

Pepper: 

0.0174 

Tomato: 

0'02-0.06 

Pepper: 

0.04-0.2 1 

Cereal Grains, except rice (Group 15) 

Squash: 

0.034 

Melon: 0.034 

Cucumber: 

0.034 

Squash: 0.04 

Melon: 0.02- 

0.1 1 

Cucumber: 

0.04-0.16 

Seed treatment using 

commercial seed 

treatment equipment 

only 

Do not use treated 

seed for food, feed 

or oil procesaing. 

Do not use treated 

seed for food, feed 

or oil processing. 

56'25% WP 

[264-XXX1 

Squash: 0.995 

Melon: 0.995 

Cucumber: 995 
Sununary of Dictions for Use of Clothianidin Seed Treatments. 

Applic. Timing, Type, 

and Equip. 

Seed treatment using 

commercial seed 

treatment equipment 

only 

Form. 

[EPA Reg. No.] 

56.25% WP 

[264-XXX] 

Wheat, Barley and Triticale 

Application Rates ' 

Seed treatment using 

on farm or commercial 

seed treatment 

equipment. 

g ail1000 seeds 

70gail100kg 

seed 

Use Directions and Limitations ' 

7.5 g ail100 kg 

seed 

0.128 IbJgal HC 

[264-XXX] 

ozail1000 

seeds 

1.1250~ 

ail100 1bs 

seed 

,bailA2 

Corn: 0.007- 

0.01 1 

Sorghum: 

0.001 -0.007 

Millet: 

0'01 Barley: 1-0'025 

0.035-0.067 

Oats: 0.034- 

0.090 

Wheat: 

0.02 1-0.105 

Potato 

Do not use treated 

seed for food, feed 

or oil processing. 

0.12 oz 

ail100 1b seed 

Seed treatment using 

commercial seed 

treatment equipment 

on1 y 

Barley: 

0.004-0.007 

Wheat: 

0.002-0.01 1 

56.25% WP 

[264-XXX] 

Do not use treated 

seed for food, feed 

or oil processing. 

Forage may be 

grazed or 

harvested 3 1 days 

after seeding. 

Cotton 

12.5 g ail100 kg 

seed pieces 

Seed Treatment 

AE 1283742 

imidacloprid / 

clothianidn mix 

0.20 oz 

ailloo Ib seed 

pieces 

AE 1283742 

Poncho 600 

COTTON - NEW USE RATE - DP Barcode #378994 

potato: 

0.163-0.325 

0.15 lbJ100 Ibs 

seed 

Do not use treated 

seed for food, feed 

or oil processing. 

0.02 

Seed Treatment 3.53 a.looO 

seeds 

40.3% VOTiVO 

(unique 

formulation) 

MUSTARD SEED - NEW USE RATE - DP Barcode #378994 

Oso7' Oz 

aY1000 seeds 

Seed Treatment 

Up to 0.063 

21.75% 

Prosper T400 

0.215 fl 0~1100 

Ibs seed or 0.004 

Ib ail 100 Ibs 

seed 

Up to 0.028 
2.3 Receptors 

2.3.1 Aquatic and Terrestrial Receptors and Effects 

The receptor is a biological entity that is exposed to the stressor (US Environmental Protection 

Agency, 1998). As described in the risk assessment Overview Document (US EPA, 2004), this 

risk assessment uses a surrogate species approach in its evaluation of clothianidin. Toxicological 

data generated from surrogate test species, which are intended to be representative of broad 

taxonomic groups, are used to extrapolate the potential effects on a variety of species (receptors) 

included under these taxonomic groupings. For example, the mallard duck and bobwhite quail 

are the preferred species in avian toxicity tests (acute and chronic) to represent toxicity for the 

entire class of bird species. 

Acute and chronic toxicity data from studies submitted by the registrant along with the available 

open literature are used to evaluate potential direct effects of pesticides to aquatic and terrestrial 

receptors. These data include toxicity studies on the technical grade active ingredient (TGAI). 

The open literature are indentified through EPA's ECOTOX database 

(http://cfpub.epa.~ov/ecotox/), which employs a literature search engine for locating chemical 

toxicity data for aquatic and terrestrial floral and fauna. The evaluation of both sources of data 

provides insight into the direct and indirect effects of pesticides on biotic communities from the 

loss of species that are sensitive to the clothianidin, and changes in structural and functional 

characteristics of the affected communities. A search of the ECOTOX database did not yield any 

relevant studies additional to those submitted by the registrant that would support this action. 

Table 3 provides examples of taxonomic groups and the surrogate species tested to help 

understand potential ecological effects of clothianidin on these non-target taxonomic groups. 

Table 3. Test species evaluated for assessing potential ecological effects of clothianidin. 

Taxonomic Group ExIL~~~(s) of Smgste 

species Amte ToxWy Ckss~tion 

Mallard duck (Anus 

~irds' platyrlzynchos) Practically non-toxic on a dietary basis to 

Bobwhite quail (Colinus moderately toxic on a dose basis 

virginianus) 

Mammals Rat (Rattu~ norvegicus) Moderately toxic 

Bluegill sunfish (Lepomis 

Freshwater ~ish~ muc~rochirus) Practically non-toxic Rainbow trout (Oncorhynclzus 

mykiss) 

Freshwater Invertebrate Midge (Cllironomus riparius) Very highly toxic 

Freshwater Benthic Midge (Chironornus riparius) Very highly toxic Invertebrate 

Estuarinelmarine fish Sheepshead minnow Slightly toxic (Cyprinodon variegates) 

Estuarinelmarine Mysid shrimp (Mysidopsis 

bahia) Very highly toxic invertebrates 

Estuarine Marine Benthic Leptnclzeirus plum~losus Very highly toxic Invertebrate 
Taxo11.0& Group Example(s) of Sumgate 

Species Aaate Toxicity t3am-tion 

Eastern oyster (Crassotrea Estuarinelmarine mollusks Practically non-toxic virg inica) 

Terrestrial invertebrates Honey bees (Apis mellifera) Highly toxic 

'~irds represent surrogates for terrestrial-phase amphibians and reptiles 2 Freshwater fish serve as surrogates for aquatic-phase amphibians 

2.3.2 Ecosystems Potentially at Risk 

The ecosystems at risk from a stressor are often exclusive in scope, and as a result it may not be 

possible to identify specific ecosystems at the baseline level. However, in general terms, 

terrestrial ecosystems potentially at risk could include the treated field and areas immediately 

adjacent to the treated field that may receive drift or runoff. Areas adjacent to the treated field 

could include other cultivated fields, fencerows, hedgerows, meadows, fallow fields or 

grasslands, woodlands, riparian habitats, and other uncultivated areas. 

Aquatic ecosystems potentially at risk from a stressor include water bodies adjacent to, or down 

stream from the treated field and might include impounded bodies such as ponds, lakes, and 

reservoirs, or flowing waterways such as streams or rivers. For uses in coastal areas, aquatic 

habitat also includes marine ecosystems, including estuaries. 

For clothianidin, the terrestrial ecosystem primarily at risk is the rhizosphere zone in which 

treated seeds are planted on the crop field, through contaminated nectar and/or pollen, or due to 

the seed left (accidental spillage or otherwise) on the soil surface at the time of planting. Seedbound clothianidin may pose risk to aquatic ecosystems through leaching, runoff, or erosion 

from the crop field. It is noted that for soil incorporated chemicals, or seed treatments, drift is 

usually a minor component. 

2.4 Assessment Endpoints 

Assessment endpoints represent the actual environmental value that is to be protected, defined by 

an ecological entity (species, community, or other entity) and its attribute or characteristics (US 

Environmental Protection Agency 1998 and 2005). For clothianidin, the ecological entities 

include the following: birds, mammals, terrestrial plants, insects, freshwater fish and 

invertebrates, estuarinelmarine fish and invertebrates, aquatic plants, and algae. The assessment 

endpoints for each of these entities include survival, growth, and/or reproduction. This 

assessment will use the most sensitive toxicity measures of effect from surrogate test species to 

estimate treatment-related direct effects on acute mortality and chronic reproductive, growth, and 

survival assessment endpoints. 

2.5 Conceptual Model 

For a pesticide to pose an ecological risk, it must reach ecological receptors in biologically 

significant concentrations. An exposure pathway is the means by which a pesticide moves in the 

environment from a source to an ecological receptor. For an ecological pathway to be complete, 

it must have a source, a release mechanism, an environmental .transport medium, a point of 

exposure for ecological receptors, and a feasible route of exposure. 

2 1 
A conceptual model is intended to provide a written description and visual representation of the 

predicted relationships between the stressor, potential routes of exposure, and the predicted 

effects for the assessment endpoint. A conceptual model consists of two major components: the 

risk hypothesis and the conceptual diagram (US Environmental Protection Agency 1998 and 

2005). 

2.5.1 Risk Hypothesis 

Risk hypotheses are specific assumptions about potential adverse effects and may be based on 

theory and logic, empirical data, and mathematical models. For this assessment, the risk is 

stressor initiated where the stressor is the release of clothianidin into the environment. Relative 

to the proposed use of clothianidin, EFED initially had concerns for risk to aquatic organisms 

due to high persistence and potential mobility of clothianidin to surface waters. In the case of 

this assessment, EFED relied on the clothianidin toxicity studies which considers standard single 

chemical toxicity testing (acute and chronic endpoints) submitted by the registrant and reviewed 

by the Agency. EFED used this information for selection of the most sensitive species tested in 

order to generate RQ values. Effects data are included under the section "Characterization of 

Ecological Effects," and represent registrant submitted data. The effects database is mostly 

complete for freshwater and estuarinelmarine aquatic organisms and thus is suitable for a 

screening level risk assessment. The major endpoints related to aquatic environments at issue 

are: 

(a). Direct effects to aquatic invertebrates in the water column via acute toxicity. 

(b). Direct effects to benthic aquatic organisms dwelling in the sediment andlor pore 

water via acute and/or chronic toxicity. 

In addition to the concern for aquatic ecosystems, EFED is also concerned with potential impacts 

to terrestrial species and functiollal groups, including pollinators; nectar and fruit eating birds, 

mammals, and insects; and soil-inhabiting invertebrates and mammals (i.e. earthworms, 

burrowing mammals). Available effects data are included under the section "Characterization of 

Ecological Effects," and represent registrant submitted data. Although EFED does not conduct 

RQ based risk assessments on beneficial insects, there is potential for direct toxic effects to 

honey bees as suggested by the toxicity data. The terrestrial effects database for these species and 

functional groups is incomplete and thus recommendations are made for additional studies or 

assessments to fill data gaps needed for a suitable screening level risk assessment. The major 

endpoints related to terrestrial environments at issue are: 

(a). Direct effects to mammals, birds, insects, and soil invertebrates via acute toxicity. 

(b). Direct effects on reproduction to birds (eggshell thinning), mammals (endocrine 

disruption), and insects via chronic toxicity. 

(d). Direct effects to foraging activity of pollinators 

Therefore, the following risk hypothesis is presumed for this screening-level assessment: 
The proposed new use of clothianidin on cotton and mustard (oilseed and condiment) will 

likely involve situations where terrestrial animals and aquatic plants and animals will be 

exposed to the chemical and or its transformation products. Based on information on 

environmental fate, mode of action, direct toxicity, and potential indirect eflects, EFED 

assumes that clothianidin may have the potential to cause reduced survival, growth, and 

reproduction to terrestrial and aquatic animals and aquatic plants as a result of the 

proposed uses of the pesticide. However, due to the low toxicity of clothianidin to 

terrestrial plants and the limited exposure from the seed treatment, clothianidin is not 

likely to reduce the survival, growth, and reproduction of terrestrial plants based on the 

proposed uses. 

2.5.2 Conceptual Diagram 

The potential exposure pathways and effects of clothianidin on terrestrial and aquatic 

environments are depicted in Figure 1. Solid arrows represent the most likely routes of exposure 

and effects for clothianidin. 

Stressor Seed Treated with Clothianidin and Planted in Soil or Left on Soil Surface 

........................................ 

f Leaching Source/ Runoff and Erosion t (Infiltration/ i Transport f Percolation) I 

Pathway 

........... .......... Source/ 

Exposure (foliage, fruit, / 

Media insects)/Soil Soil FoliagalSoil ............................ 

Exposure GilY Integument Method Root Uptake Uptake ................................ 

Terrestrial Animals Tzmcsuial Aquatic lnvertcbrates 

(Birds, Mammals, Upland Plants Aquatic Vertebrates Receptors Reptiles, Terrestrial- Aquatic Plants 

phase Amphibians, Bees) 

I , r-k 

Individual Aauatic 

Direct Indi~idual Terrestrial Individual Terrestrial Verrehrares and Aauatic Plant 

Effects: Animals Plants Invertebrates Population 

Rerluced Sumii,al Seedling Emergence Reduced Sunival Reduced NonReduced Growth Vegetative Vigor Reduced Growth Growth Rates 

Endangered 

Species Reduced Reproduction Reduced Reproduction 

and Bionlass 

Indirect 

Effects 

Figure 1. Conceptual diagram depicting potential risks to terrestrial and aquatic animals 

from the use of clothianidin as a seed-treatment insecticide. Italicized groups of taxa are 

identified as the taxa of concern based on toxicity and results from previous assessments. 

Food Web 

Dynamics 

Perturbed Forage or 

Prey Availability 

Habitat Alteration: impacts on nesting 

ability, ability to scck cover, etc. 
2.6 Analysis Plan 

2.6.1 Methods of Conducting Ecological Risk Assessment and 

Identification of Data Gaps 

This document characterizes the environmental fate and effects of clothianidin to assess whether 

the proposed label new use of the compound results in risk to non-target organisms at levels 

above the Agency's LOCs. The primary method used to assess risk in this screening-level 

assessment is the risk quotient (RQ). The RQ is the result of comparing measures of exposure to 

measures of effect. A comnlonly used measure of exposure is the estimated exposure 

concentration (EEC) and commonly used measures of effect include toxicity values such as LDSo 

or NOAEC. The resulting RQ is then compared to a specified level of concern (LOC), which 

represents a point of departure for concern, 1.e. if the RQ exceeds the LOC, then risks are 

triggered. Although not necessarily a true estimate of risk since there is no estimated probability 

of effect, in general, the higher the RQ, the more certain the potential risks. 

Table 4 summarizes the environmental fate data requirements for clothianidin according to 40 

CFR Part 158 Subpart N. Studies that have been received or not yet received will be noted as 

such in the table. 

Table 4. Environmental fate data requirements for clothianidin. 

Table of Environmental Fate Data Requirements 

Guide- Study 

line # Data Requirement MRID # Classification Is more data needed? 

161-1 Hydrolysis 

161-2 Photodegradation in 

Water 

161-3 Photodegradation on 

Soil 

161-4 Photodegradation in 

Air 

162- 1 Aerobic Soil 

Metabolism 

162-2 Anaerobic Soil 

Metabolism 

Core 

Core 

Supplemental 

Core 

Supplemental 

Core 

Core 

Waived 

Core 

Core 

Supplemental 

Supplemental 
Table of Environmental Fate Data Requirements 

Guide- Study 

line # Data Requirement MRID # Classification Is more data needed? 

162-3 Anaerobic Aquatic 45422330 Core no 

Metabolism 

162-4 Aerobic Aquatic 46826903 Core no 

Metabolism 45422324 Supplemental 

45422329 Supplemental 

163- 1 Leaching- 454223 1 1 Core 

Adsorption/Desorpti 454223 12 Ancillary 

on 454223 13 Supplemental 

454223 14 Supplemental 

454223 15 Supplemental 

454223 16 Supplemental 

163-2 Laboratory Volatility NIA N/A 

163-3 Field Volatility N/A N/ A 

164- 1 Terrestrial Field 45490703 Core 

Dissipation 45490704 Core 

45490705 Core 

4542233 1 Supplemental 

45422332 Core 

45422333 Core 

45422334 Core 

45422335 Core 

45422336 Core 

45422508 Supplemental 

45422604 Ancillary 

454226 12 Ancillary 

164-2 Aquatic Field N/A N/ A Reserved 

Dissipation 

165-4 Accumulation in NIA N/A Waived 

Fish 

165-5 Accumulation- NIA NIA Reserved 

aquatic non-target 

166- 1 Ground Water- small N/ A N/ A Yes 

prospective 

201-1 Droplet Size 45490701 Supplemental Reserved 

Spectrum (upgradable) 

Waived 

Waived 

no 
Table of Environmental Fate Data Requirements 

Guide- Study 

line # Data Requirement MRID # Classification Is more data needed? 

202- 1 Drift Field N/ A Reserved 

Evaluation 

Table 5 summarizes the data requirements for clothianidin according to 40 CFR Part 158 

Subpart G. Studies that have been received or not yet received will be noted as such in the table. 

Table 5. Ecological effects data requirements for clothianidin. 

Table of Jkological Toxicity Data Requirements 

Guideline 

# Data Requirement MRID # Classification Is more data needed? 

850.2100 Avian acute oral LDso 

(mallard duck) 

Cjapanese quail) 

850.2200 Avian subacute dietary LC5" 

(bobwhite quai)l 

(mallard duck) 

850.2300 Avian reproduction 

(bobwhite quail) 

(mallard duck) 

850.1075 Freshwater fish acute LCSoa 

(rainbow trout) 

TGAI 

DEG 

DEG 

DEG 

Core 

Supplemental 

Core 

Core 

Core 

Supplemental 

Supplemental 

Supplemental 

Supplemental 

Supplemental 

(bluegill sunfish) 45422407 Core 

TGAI 

850.1010 Freshwater invertebrate acute 

ECso (daphnia) 

TGAI 45422338 Core 

DEG 4542240 1 Core 

DEG 45422340 Core 

DEG 45422339 Supplemental 

(chironomid) 

TGAI 45422414 Supplemental No 
Table of Ecological Toxicity Data Requirements 

Guideline 

# Data Requirement MRID # Classification Is more data needed? 

I 850.1075 Estuarinelmarine fish acute 

LCso (sheepshead minnow) 4542241 1 Supplemental 

850.1025 Estuarinelmarine invertebrate 

850.1035 acute EC50 

850.1045 (eastern oyster) 45422404 Core 

850.1055 (mysid) 45422403 Core 

850.1075 

850.1400 Freshwater fish early life stage 

(fathead minnow) 454224 13 Supplemental 

850.1300 Freshwater invertebrate life 

cycle (daphnia) 454224 12 

Supplemental 

850.1350 Estuarinelmarine life cycle 

(mysid) 45422405 Core 

850.1735 Acute Freshwater Invertebrate 

Sediment Toxicity 

TGAI 468269-02 Supplemental 

850.1740 Acute EstuarinefMarine 

Invertebrate Sediment Toxicity 

TGAI 47 1994-01 Supplemental 

850.1950 Aquatic Field Study NA NA 

870.. 1 100 Acute mammalian oral 1,D~o 

(rat> 45422621 Core 

(mouse) 45422622 Core 

870.4100 Mammalian Chronic 

(rat) 454227 14- 16 Core 

(rat) 45422825 -26 Core 

(rabbit) 454227 12- 13 Core 

850.4 100 Seedling Emergence - Tier I 45422501 Core 1 850.4150 Vegetative Vigor - Tier I 45422502 Core 

850.5400 Aquatic plant algae 

TGAI 45422504 Core 

DEG 45422505 Core 

DEG 45422506 Core 

DEG 45422507 Core 

850.4400 Aquatic plant acute ECS0 45422503 Core No 

27 
Table of'Ecologica1 Toxicity Data Requirements 

Guideline 

# Data Requirement MRID # Classification Is more data needed? 

850.3020 Acute honey bee contact LD50 45422426 Core No 

Non- Acute honey bee oral LD50 

guideline TGAI 45422426 Supplemental 

DEG 45422427 Supplemental 

DEG 45422428 Supplemental 

DEG 45422429 Supplemental 

DEG 45422430 Supplemental 

850.3030 Honey Bee Residue on Foliage 45490702 Supplemental 

$50.3040 Honey Bee Field Testing for 4542243 1 Supplemental 

Pollinators 45422432 Supplemental 

45422433 Supplemental 

45422435 Supplemental 

45422436 Supplemental 

45422437 Supplemental 

45422440 Supplemental 

46907801/46 

907802 Yes 

850.6200 Earthworm Subchronic 

TGAI 454225 1 1 Core 

DEG 454225 12 Core No 

DEG 454225 13 Core 

Non- Earthworm Chronic 

guideline 45422525 Supplemental No 

45422526 Supplemental 

'EFED needs 3 more Tler 1 or Tler I1 Core clothianidin stud~es for the nonvascular surrogate species, rnanne dlatom (Skeletonerna costaturn), 

blue-green algae (Anabaena flos-aquae), and a freshwater dlatorn 

No 

Yes 

2.6.2 Outstanding Data Requirements 

Environmental Fate: 

162-4 Aerobic Aquatic metabolism Study. Based on the additional information submitted by the 

registrant, EFED agreed to change the previously-reviewed aerobic aquatic metabolism study 

(MRID 45422324) from "unacceptable" to "supplemental". However, the aerobic aquatic 

metabolism data requirements are still not fulfilled, the registrant must submit a new aerobic 

aquatic metabolism study. Reasons are presented below: 

1. The potential for clothianidin to move from the treated area to the nearby surface water body 

has been increased significantly since 2003 because the registrant has recently added new uses 

on the labels. According to the review completed on 212012003 (Title - "EFED Risk 

2 8 
Assessment for the Seed Treatment of Clothianidin 600FS on Corn and Canola", the Agency 

required the registrant to conduct a new aerobic aquatic metabolism study (162-4). This risk 

assessment was based on the maximum application rate for the seed treatment at 0.1 lb ai/A. 

However, according to the new uses reviewed by EFED (Turfgrass, Tobacco, Apples, Pears, and 

Ornamentals), this chemical can be directly applied to the soil surfacelfoliage at much higher 

application rate (0.4 lbs ailA). As a result, the potential for clothianidin to move from the treated 

area to the nearby surface water body under the new uses is much greater than the use as a seed 

treatment. Therefore, there is a need for a better understanding of the fate of clothionidin in the 

aerobic aquatic environment. 

2. The fate of the thiazolyl ring was not monitored in the previously-reviewed aerobic aquatic 

metabolism study (MRID 45422324) because the test substance was labeled on the nitroimino 

side chain. Therefore, the fate of the thiazolyl ring remains unknown. The fate guidelines 

recommend to use the ring-labeled test substance. 

3. A well-designed new aerobic aquatic metabolism study is deemed critical for EPA to fully 

assess the risk of clothionidin in the aquatic environment. 

166-1 Small-Scale Prospective Groundwater Monitoring, Study. Due to direct soil and foliar 

applications of clothianidin and concerns about the chemical leaching into ground water (see 

below), the Agency will request the registrant to submit a small-scale prospective groundwater 

monitoring study. 

Source: EPA review "EFED Risk Assessment for the Seed Treatment of Clothianidin 

600FS on Corn and Canola" dated February 20,2003 (page 3): 

"Clothianidin has the propcrties of a chemical which could lead to widespread groundwater contamination, but no ground-water monitoring studies have been conducted to 

date. Should the registrant request field uses involving direct application of clothianidin 

to the land surface, Prospective Ground-Water Monitoring Studies may be needed to 

evaluate fully the potential impact of such uses." Due to the extreme mobility and 

persistence of clothianidin in the environment, a small-scale prospective groundwater 

monitoring study will provide additional fate information on the better understanding of 

this chemical in the environment and improve the certainty of the risk assessment. 

Seed Leaching Study: EFED believes that a seed leaching study would greatly increase 

certainty regarding a more realistic estimate of the amount of available clothianidin residues on 

the seed surface. This in turn would allow a refinement of exposure estimates and environmental 

concentration values (EECs). A study has been submitted and is currently under review (MRID 

47483002). 

Ecological Effects: 

The database available for clothianidin to support the assessment was largely complete. The 

following ecological studies for clothianidin are still outstanding and need to be submitted. 
Honey Bee Toxicity of Residues on Foliage (850.3030): This study is required for chemicals 

that have outdoor terrestrial uses in which honeybees will be exposed and exhibit an LD50 < 

11pg a.i./bee. The study that was submitted to satisfy this guideline is supplemental but does not 

satisfy the guideline requirement. This study is not required for this assessment due to the lack 

of exposure to residues on foliage from the seed treatments. This study is placed in reserve 

pending future new uses. 

Field Test for Pollinators (850.3040): The possibility of toxic exposure to non-target 

pollinators through the translocation of clothianidin residues that result from seed treatments has 

prompted EFED to require field testing (850.3040) that can evaluate the possible chronic 

exposure to honey bee larvae and queen. In order to fully evaluate the possibility of this toxic 

effect, a field study should be conducted and the protocol submitted for review by the Agency 

prior to initiation. Another study had been submitted to satisfy this guideline requirement. 

While it had originally been classified as acceptable, after recent reevaluation it is classified as 

supplemental, and a field study is still being needed for a more refined risk assessment. 

Algal Toxicity (850.5400): Data on four species of non-vascular plants is required. A study on 

only one species has been submitted to date on Pseudokirchneriella subcapitata, formerly known 

as Selenastrum capricornutum. 

2.6.3 Measures of Effect and Exposure 

Table 6 lists the measures of environmental exposure and ecological effects used to assess the 

potential risks of clothianidin to non-target organisms in this assessment based on the concerns in 

the problem formulation. The methods used to assess the risk are consistent with those outlined 

in the document "Overview of the Ecological Risk Assessment Process in the Office of Pesticide 

Programs." (2004) 

Table 6. Measures of effect and exposure for clothianidin. 

Assessment Endgoint S~teS~ladM~ 

&-weal PW Mwwof Expowve 

- Mallard duck acute oral LD,, 

Survival - Bobwhite quail and mallard 

~irds~ duck subacute dietary LC50 

Reproduction Mallard duck and bobwhite quail Maximum residues on seed and 

and growth chronic reproduction NOAEL soil 

Survival Laboratory rat acute oral LDSo 

Mammals Reproduction Laboratory rat chronic 

and growth reproduction NOAEL 

Survival I Freshwater Water flea acute LCjo Peak EEC~ 

Invertebrates Reproduction Water flea NOAEC and LOAEC 

and growth 2 1 -day average EEC~ 

I Estuarinelmarine Survival Sheepshead minnow acute LC50 Peak EEC~ 

3 0 
Assessment Endpoint SwTogtlteSwWMof Ecokogical Effect' Measures of Exposure 

fish Reproduction 

and growth No study submitted 60-day average EEC~ 

Survival Estuarinelmarine Mysid shrimp acute LCSo Peak EEC~ 

invertebrates Reproduction 

and growth No study submitted 2 1 -day average EEC~ 

'1f species listed in this table represent most commonly encountered species from registrant-submitted studies, 

I risk assessment guidance indicates most sensitive tested within taxonomic group are to be used for baseline risk 1 I assessments I I 2~irds represent surrogates for terrestrial phase amphibians and reptiles I 

j~reshwater fish may be surrogates for amphibians (aquatic phase) 

'one in 10-year frequency 

3 Exposure Assessment 

Summary 

Clothianidin appears to be a persistent compound under most field conditions. Based on analysis 

of the laboratory studies alone, the major route of dissipation for clothianidin would appear to be 

photolysis if exposure to sunlight occurs (e.g., the measured aqueous photolysis half-life was <1 

day and aerobic half-lives were 148 to 1155 days). Although photolysis appears to be much more 

rapid than other avenues of degradatioddissipation of clothianidin in the laboratory studies, the 

very slow rate of dissipation that was observed in field studies suggests that photolysis probably 

is not significant under most actual-use conditions. Photolysis may be quite important in surface 

waters if residues have reached clear bodies of water and are in solution rather than bound to 

sediment. Clothianidin is stable to hydrolysis at environmental pHs and temperatures. 

Degradation is also relatively rapid under anaerobic aquatic conditions (overall half-life of 27 

days); however, metabolic degradation occurs very slowly in aerobic soil. Clothianidin is mobile 

to highly mobile in the laboratory [soil organic carbon partition coefficients (Koc) values were 

84 to 129 for all test soils except for a sandy loam soil which had a Koc value of 3451, although 

only a modest amount of leaching was observed in the submitted field studies. Previous studies 

have confirmed that compounds with a similar combination of mobility and persistence 

characteristics have a potential to leach to ground water at some use sites. Volatilization is not 

expected to be a significant dissipation process. 

Degradation and Metabolism 

Metabolism in aerobic soil occurred very slowly. At 20°C, clothianidin degraded in two soils 

with a first-order half-life of 148 and 239 days (Hofchen and Laacher soil series), in seven soils 

ranging in texture from sand to silt loam with half-lives of 495 to 1,155 days (BBA 2.2, Quincy, 

Sparta, Crosby, Susan, Elder, and Howe soil series), and in a tenth soil with a half-life that was 

nominally calculated to be 6,931 days (Fugay soil series). Degradation was too little in the 

Fugay soil study to accurately calculate the degradation rate over the 1-year study period (r2 = 

0.05). A total system half-life of 187 days was estimated from a 120-day aerobic aquatic 

metabolism study (MRID 46826903). 
Under anaerobic aquatic conditions, metabolic degradation occurred relatively quickly (half-life 

of 14 days in water; 37 days in sediment; 27 days overall). Clothianidin was <I% of the applied 

in the water at and after 120 days and was <2.0% in the silt loam sediment at and after 183 days. 

No major degradates were isolated; clothianidin was converted primarily to soil-bound residues. 

Clothianidin photodegraded with half-lives of <1 day in sterile buffer solution in the laboratory 

and in natural water outdoors, and approximately 34 days in soil in the laboratory. The range of 

values (1 to 34 days) given for surface water-source drinking water represents uncertainty with 

regard to the importance of photodegradation in the long-term fate of clothianidin in natural 

waters. In the laboratory, clothianidin photodegraded in sterile aqueous pH 7 buffer solutions 

with a half-life of 6.2-6.8 hours, based on a 12-hour light.42-hour dark cycle. Major degradates 

were N-(2-clorothiazol-5-ylmethy1)-N'-methylurea (TMZU), methylurea (MU), methylguanidine 

(MG), 4-hydroxy-2-methylamino-2-imidazolin-5-0 (HMIO), 7-methylamino-4H-imidazo[5,1- 

bl[l,2,5]thiadiazin-4-one (MIT), formamide (FA), and C02. Outdoors, clothianidin degraded in 

nonsterile river water with a half-life of 25.1 to 27.7 hours under a cycle of approximately 9 

hours sunlight115 hours darkness. Major transformation products were MG, HMIO, MU, Urea, 

TMG, 3-methylamino- 1 H-imidazo [1,5-c]imidazole (MAI), 2-chlorothiazol-5-ylmethanol 

(CTCA), and C02. There was no degradation in the control samples held in the dark, which is 

consistent with clothianidin's observed stability to hydrolysis. 

On moist soil, clothianidin photodegraded with a half-life of 8.2 days based on continuous 

irradiation (estimated to be equivalent to 34.2 solar summer days in Phoenix, AZ); degradation 

was not significant in the dark. At study termination (equivalent to 71 days solar summer days in 

Phoenix, AZ), 22.3% of the clothianidin remained undegraded. No degradates accumulated to 

significant levels during the study. 

Soil sorption and mobility 

In laboratory batch equilibrium studies, clothianidin had medium mobility in a US sandy loam 

soil and high mobility in US loamy sand and clay loam and German sand and sandy loam soils. 

In batch equilibrium studies using the same soils and similar conditions, MNG was very highly 

mobile, TZMU was highly to very highly mobile, TZNG was moderately mobile, and TMG was 

immobile or had low mobility. The mobility of clothianidin appeared to decrease as the length 

of time clothianidin was in contact with the soil increased; the longer clothianidin was aged in 

treated soil, the less likely it was to desorb from that soil. 

Field dissipution 

Clothianidin is expected to dissipate very slowly under terrestrial field conditions, based on the 

results of five bare ground field experiments conducted in the US and Canada. Half-lives of 

clothianidin, based on residues in the 0-15 cm soil depth, were 277 days (Wisconsin sand soil, 

incorporated), 315 days (Ohio silt loam soil, not incorporated), 365 days (Ontario silt loam soil, 

incorporated), and 1,386 days (North Dakota clay loam soil, not incorporated), and could not be 

determined at a fifth site due to limited dissipation during the 25-month study (Saskatchewan 

silty clay loam soil, incorporated). Incorporation did not appear to be a significant factor in 

determining the rate of dissipation. Clothianidin was generally not detected below the 45 cm soil 
depth except at one site, where it moved into the 45-60 cm depth. No degradates were detected 

at >lo% of the applied, and degradates were generally only detected in the 0-15 cm soil layer. 

However, in many cases most of the parent remained untransformed at the close of the study; 

further accumulation of degradates could have occurred. Degradates that were increasing in 

concentration or at least continuing to persist towards the close of one or more field dissipation 

studies were: MNG (MRID 45422336) TZNG (MRID 45422335, 45422333), and TZMU 

(MRID 45422335). 

Two studies were conducted to investigate leaching of clothianidin under ficld conditions 

(MRIDS 45422331 and 45422508). These studies were conducted in the Federal Republic of 

Germany and were apparently designed to fulfill certain European regulatory requirements. In 

these monolith lysimeter studies, 42 to 59% of the applied remained in the soil approximately 3 

to 4 years following the first of two applications, and residues were primarily undegraded 

clothianidin. The loss of radioactivity was attributed by the authors to mineralization of 

clothianidin, since 51% of the total residues were detected in the leachate. Clothianidin was not 

detected in the leachate. There was also a significant amount of TZNG and/ or MNG that 

remained in monolith lysimeters at the close of multi-year studies. In one study (MRID 

45422331), analysis of the soil in the lysirneter three years after the original application of 

clothianidin revealed TZNG was present as about 5% of the applied clothianidin. When the soil 

was analyzed more than 4 years after application in another lysimeter study (MRID 45422508) 

about 3% of the applied was present as MNG and 2% was present as TZNG. The substantial 

amount of clothianidin parent remaining in the soil profile at the close of these studies indicates 

that further leaching of clothianidin may occur in following years if sufficient precipitation 

occurs. 

3.1 Aquatic Exposure Estimates 

The aquatic exposure estimates presented in this assessment were based on the use of models as 

limited surface and ground water monitoring data are available for clothianidinl. To simulate the 

most conservative surface watcr exposure for the ecological risk assessment, the Tier I1 

PRZMEXAMS model was used. 

PRZM-EXAMS Model Inputs and Scenarios for Clothianidin 

The Pesticide Root Zone Model, (PRZM, Carsel et al., 1997) and the Exposure Analysis 

Modeling System (EXAMS, Bums, 1997) were used in tandem to generate aquatic estimated 

environmental concentrations (EECs). PRZM (3.12 beta dated May 24, 2001) simulates fate and 

transport on the agricultural field whereas EXAMS (2.98.04, dated July 18, 2002) simulates the 

fate and resulting daily concentrations in the water body. Simulations are carried out with thc 

I The primary but indirect exception to this are two Small-Scale Prospective Ground-Water Monitoring Studies for 

the related pesticide Thiamethoxam (thiamethoxam degrades readily to clothianidin). 

MRID 473797-0 1 A Small-Scale Prospective Groundwater Monitoring Study for Thiamethoxam Insecticide 

(platinumm) in Macon County, Georgia. Report dated 1/16/2008. 

MRID 474882.01. A Small-Scale Prospective Groundwater Monitoring Study for Platinum" 2SC (Thiamethoxam, 

CGA-293343) in St. Joseph County, Michigan. Report dated 6/6/2008. 
linkage program shell, EXPRESS (1.03.02, dated July 20, 2007). Simulations are run for 

multiple (usually 30) years, and the EECs represent peak values that are expected once every ten 

years based on the thirty years of daily values generated during the simulation. Additional 

information on these models can be found at: 

http://www.epa.gov/op~efed1/models/water/index.htm 

and at: 

http://www.epa. ~ov/ceampubl/swater/index.html 

The aquatic exposure is estimated for the maximum application pattern to a 10-ha field bordering 

a 1-ha pond, 2-m deep (20,000 m3) with no outlet. Exposure estimates generated using this 

standard pond are intended to represent a wide variety of vulnerable water bodies that occur at 

the top of watersheds including prairie pot holes, playa lakes, wetlands, vernal pools, man-made 

and natural ponds, and intermittent and first-order streams. As a group, there are factors that 

make these water bodies more or less vulnerable than the standard surrogate pond. Static water 

bodies that have larger ratios of pesticide-treated drainage area to water body volume would be 

expected to have higher peak EECs than the standard pond. These water bodies will be either 

smaller in size or have large drainage areas. Smaller water bodies have limited storage capacity 

and thus may overflow and carry pesticide in the discharge, whereas the standard pond has no 

discharge. As watershed size increases beyond 10-ha, it becomes increasingly unlikely that the 

entire watershed is planted with a non-major single crop that is all treated simultaneously with 

the pesticide. For major crops like cereal grains, however, this may not be the case. Headwater 

streams can also have peak concentrations higher than the standard pond, but they likely persist 

for only short periods of time and are then carried and dissipated downstream. 

OPP standard PRZM crop scenarios, which consist of location-specific soils, weather, and 

cropping practices, were used in the simulations to represent proposed labeled uses of 

Clothianidin. These scenarios were developed to represent high-end exposure sites in terms of 

vulnerability to runoff and erosion and subsequent off-site transport of pesticide. Model input 

parameters representing the proposed mustard and cotton seed treatment uses are provided in 

Table 7 (further details on model input and output are provided in the Appendix). 

for this type of use. 

Mustard seed treatment is an 

entirely new use. 

Table 7. Input parameters for PRZMIEXAMS for the calculation of aquatic and benthic 

EECs of clothianidin. 

Parameter (units) 

Output File Name 

Chemical Name 

Crop Names 

VaIue(s) 

CLOTHI ANIDIN 

Clothianidin 

Mustard seed treatment 

Cotton seed treatment 

Sources 

--- 

Label 

Label 

Comments 

..- 

Cotton seed treatment is higher 

rale than previously registered 
Parameter (units) 

Application Rate 

Day of Application (mm-dd) 

Number of Applications Allowed at 

the Maximum Application Rate 

Minimum Interval between 

Applications (days) 

CAM (Chemical application 

method) 

IPSCND (Flag indicating the 

Value(s) 

lb a.i Ja 

Mustard (ND Canola 

scenario) = 0.028 Ib ai1A 

Cotton (NC, MS, & CA 

scenarios) = 0.0633 Ib 

ai/A 

CA Cotton = 04-24 

MS Cotton = 04-24 

NC Cotton = 05-25 

ND Canola = 05-09 

1 

N/A 

5 or 8 

disposition of pesticide remaining 

Sources 

Proposed Labels 

Label 

Label 

Label 

--- 

DEPI = Incorporation Depth (cm) 

Koc 

Aerobic Soil Metabolism (days) 

Method of Application 

- ~ufffer Zone (fF) 

Application Efficiency (fraction) 

Spray Drift (fraction) 

Comments 

Regionally specific typical 

planting dates. 

CAM 8 represents efficient 

uniform planting at the 

nominal depth. CAM 5 allows 

for some of the seed to be 

distributed above the target 

planting depth. 

Applies only if CAM = 2 or 3 

Cotton = 1.27 cm 

Mustard = 1.27 cm 

160 

745 

Broadcast 

NIA 

1 

0 

Label 

MRID 454223 

MRIDs 45422325 

and45422326 

Label 

Label 

--- 

--- 

Typical minimum 

recommended planting depth 

The average Koc value (of 129, 

345, 123, 84 and 1 19), as per 

EFED guidance (1). The K, 

value represents better the 

mobility of clothianidin 

(relative standard deviation is 

smaller). 

Represents the 9oth percentile 

of the upper confidence bound 

on the mcan of 9 half-life 

values. tli2= 148, 239, 578, 

1155,533,533,693,990, and 

495 days. Mean = 596 days, 

Std. dev. 321 days, tW,"., = 

1.397 for n=9. The Fugay soil 

was excluded because too little 

degradation occurred to 

accurately calculate a half-life. 

Proposed label 

Proposed label 

For seed treatment. the 

application efficiency is 

assumed to be 100%. 

For seed treatment, the spray 

drift value is assumed to be 

0%. 
Aquatic EEC values derived from PRZMIEXAMS for each of the modeled crop scenarios are 

summarized in Table 8 and the benthic (soil pore-water) concentrations are provided in Table 9. 

Both high- and low-efficiency seedings were simulated: in the high efficiency simulation all of 

the seed is assumed to have been planted at the target depth (1.27 cm for both uses) whereas in 

the low efficiency application seed density is highest at 1.27 cm but a lesser concentration of 

seed is assumed to settle in the soil at a lesser depth.? Acute aquatic exposure was estimated to be 

up to 3.0 ug/L for the cotton seed use and 0.49 ug/L for the mustard seed use. The acute 

Refer to the PRZM user manual (http.//www.epa.gov/athens/uubl icationslreportslSuarez600R05 1 I I PRZM3.udf ) 

for further details. 

3 6 

Comments 

10X the actual solubility as per 

EFED guidance ( I ). Highest 

available value. 

3x single measured value 

Determined by multiplying the 

available half-life (27 days) by 

3 to account for the uncertainty 

associated with using a single 

value. 

EFED guidance (I). 

Longest half-life of 34 days 

used instead of aqueous 

photolysis half-life because of 

demonstrated persistence in 

water and on soil surface 

exposed to sunlight. Lower 

value of - I day from natural 

water photolysis study was not 

used in the modeling for this 

assessment. 

.-- 

At 20°C 

At 20°C (Not used for model 

input) 

Default for pond scenario, as 

opposed to index reservoir. 

--- 

EFED guidance (I) 

EFED guidance (I) 

EFED guidance (1) 

EFED guidance (1) 

PRZMIEXAMS (version 2.1 .) dated 

10122109, available at http://www.epa.gov/oppefedIImodelslwaterlinputgarameter~guidance.htm 

2. Sources for seeding rates and dates of application: 

Label directions andOPP internal compilations. 

3. European Commission Health & Consumer Protection Directorate document, Clothianidin SANCOl10533/05, Jan 2005 

Sources 

(3) 

MRID 46826903 

MRID 45422330 

MRID 454223 17 

MRID 45422323 

(soil); 

454223 18, 

45222320, 

45422322. 

45422319, 45422321 

(water) 

MRlD 454223 17 

(3) 

Calculated 

.-- 

--- 

--- 

-.- 

--- 

--- 

--- 

parameters for 

I Parameter (units) 

Solubility in Water (ppm) 

Aerobic Aquatic Metabolism (days) 

Anaerobic Aquatic Metabolism 

(days) 

Hydrolysis at pH 7 half-life (days) 

Aqueous Photolysis (days) 

Molecular Weight (glmole) 

Vapor Pressure (torr or mrnHg) 

Henry's Law Constant 

(~tm-m3/mol) 

Environment 

I Field Size 

Runoff 

FEXTRC, Foliar extraction 

PLDKRT, Decay rate on foliage 

PLVKRT, Volatilization rate from 

foliage 

UPTKF, Uptake factor 

1. All values were selected according 

Value(s) 

3270 mgL 

562 

8 1 

Stable 

34 

249.7 

3,8x lo.] I Pa = 2,9x 10-~3 

mmHg 

2.9e-16 Atm-m3lmole 

pond298.e~~ 

EPA Pond 

None 

0.5 

0 

0 

0 

to the EFED guidance on input 
concentration in the pore water was estimated to be up to 1.90 ug/L for the cotton seed use and 

0.33 ugL for the mustard seed use. Chronic exposure estimates were only marginally lower in 

both surface water and benthic pore water (consistent with the high environmental persistence of 

clothianidin observed in laboratory and field studies). 

Table 8. Estimated Environmental Concentrations for Clothianidin in Surface Water. 

1 Seed Treatment (high incorp. efficiency) 1 

- - 

Scenarios 

CA Cotton I 0.14 1 0.14 

Peak 

0.14 I I I 

MS Cotton 

NC Cotton 

ND Canola 

21-day Average 

(mustard seed) 

Seed Treatment (low incorp. eff~ciency) 

60-day Average 

1.47 

1.57 

0.26 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

(mustard seed) 

Table 9. Estimated Environmental Concentrations for Clothianidin in Benthic (soil-pore) Water. 

- - 

Seed Treatment (high incorp. efficiency) 

1.42 

1.53 

0.25 

0.3 1 

2.80 

3 .OO 

0.49 

Scenarios 

I I I 

1.36 

1.48 

0.24 

Peak 21-day Average 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

(mustard seed) 

MS Cotton I I 

(mustard seed) 

0.3 1 

2.74 

2.91 

0.48 

60-day Average 

0.1 1 

0.81 

1 .OO 

0.17 

0.1 1 

0.81 

1 .OO 

0.17 

We also estimated exposure to organisms ingesting residues from sediment. Peak exposures for 

0.30 

2.62 

2.82 

0.46 

0.1 1 

0.80 

1 .OO 

0.17 

Seed Treatment (low incorp. efficiency) 

NC Cotton I .US 

ND Canola 

1.58 1.56 

0.33 0.33 

CA Cotton 

1.58 

1.90 

0.33 

0.22 0.22 

1.89 

0.21 
both application efficiency level assumptions ranged from 0.74 to 12.83 ug / g of sediment 

(again, chronic exposure levels were not significantly lower) - see Table 10. Sediment residues 

normalized for organic carbon content ranged from 0.5 to 8.35 ug 1 g of sediment (peak or 

chronic exposure) - see Table 1 1. 

1 I I 

Seed Treatment: Pond Sediment Bound 1/10 year EECs (low incorp. efficiency) 

Table 10. Estimated bound sediment concentrations for clothianidin. 

I --- ng/g (ppb) --- i 

21-day Average 60-day Average Scenarios 

(mustard seed) 

Seed Treatment: Pond Sediment Bound 1/10 year EECs (high incorp. efficiency) 

Peak 

1.45 

10.57 

NC Cotton 

ND Canola 

--- ng/g (ppb) --- I 

1.46 

10.66 

CA Cotton 

MS Cotton 

1.47 

10.69 

12.83 

2.25 

Table 11. Ton soil / sediment organic carbon fraction bv PRZMIEXAMS scenario. 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

(mustard seed) 

12.80 

2.25 

12.73 

2.24 

0.74 

5.48 

6.77 

1.18 

I Y 4 

-- - - -- - - 

Table 12. Bound Sediment Concentrations for Clothianidin normalized to Organic Carbon 

Scenarios 

0.74 

5.47 

6.77 

1.18 

0.0029 

0.01 28 

0.0232 

0.0236 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

Pond sediment Organic carbon fraction assumed to be equal to the fraction uf organic carbon in horizon 1 for the 

associated PRZM scenario. 

3 8 

0.74 

5.43 

6.75 

1.17 

Seed Treatment: Pond Sediment Organic Carbon Levels, Cotton and Canola scenario$ 

Organic Carbon (Percent) 

0.29% 

1.28% 

2.32% 

2.36% 

content. 

Organic Carbon 

(Fraction) 

Scenarios Peak 21-day Average 60-day Average 

Seed Treatment: Pond Sediment Bound 1/10 year EECs (low incorp. efficiency) 

--- nglg (ppb) --- 

CA Cotton 507 503 5 00 
3.2 Terrestrial Exposure Estimates 

Consumption of clothianidin-treated seed is the most likely exposure route for terrestrial animals. 

The Terrestrial Exposure Model (Version 1.4.1), was used to estimate the dietary exposure to 

terrestrial birds and mammals. Because of the differences in foliar application and seed 

treatment uses of pesticides, the seed treatment worksheet of TREX was used as a "stand-alone" 

tool for estimating the avian and mammalian exposure concentrations for various crops. 

MS Cotton 

NC Cotton 

ND Canola 

(mustard seed) 

The seed treatment worksheet of TREX assesses dietary exposure in two different ways. The 

first approach estimates the dietary dose assuming that an organism has been eating only treated 

seed. Using this assumption, the seed treatment worksheet calculates the food consumed by 

birds and mammals using Nagy's allometric food consumption equations. Food consumption is 

calculated for the smallest avian (20-gram weight) and mammalian (15-gram weight) species 

(Appendix A). Using a scaling factor approach, which adjusts food intake and toxicity values to 

account for the differences in the size of the animal assessed compared with the size of the 

animal used in the toxicity tests, daily doses or Nagy doses are calculated. Avian and 

mammalian Nagy doses for clothianidin were calculated using the equation - (daily food intake 

glday * 0.001 kg/g * maximum seed application rate mglkg-seed) 1 body weight of animal (kg). 

The second method calculates the available concentration of pesticide on the basis of pesticide 

applied per square foot. Maximum clothianidin application for each crop is converted to mg 

a.i./sq ft in order to derive an estimate of the pesticide exposure per square foot. 

835 

553 

95 

Typical input values (for foliar treatments) for TREX include application rate, time interval 

between two applications, total number of applications and foliar half-life periods. All seeding 

rate information was obtained from U.S. EPA, 2004b. Since clothianidin is a seed-treatment 

insecticide, terrestrial EECs were derived using 1 application for the maximum proposed use 

rates for each crop-The TREX model assumes a default density of 8.33 lblgal. This density 

was therefore used in the TREX model. Also, as clothianidin is a seed-treatment, foliar half-life 

periods are irrelevant for this analysis. 

Seed Treatment: Pond Sediment Bound 1/10 year EECs (high incorp. efficiency) 

--- nglg (ppb) --- 

833 

552 

95 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

(mustard seed) 

826 

549 

95 

255 

428 

292 

50 

255 

427 

292 

50 

255 

424 

29 1 

50 
4 Ecological Effects Assessment 

The short-term and long-term exposure effects of clothianidin on aquatic and terrestrial 

organisms were characterized based on the studies submitted by the registrant only as the 

ECOTOX database review did not reveal any open literature studies for clothianidin that were 

relevant. Toxicity studies available for this risk-assessment and the measurement endpoints 

selected for each taxonomic group are included in Appendix B of this document. 

4.1 Aquatic Effects Summary 

4.1.1 Freshwater and Marine Fish 

Two freshwater fish toxicity studies using the TGAI are required to establish the acute toxicity of 

clothianidin to fish. The preferred test species are rainbow trout (a coldwater fish) and bluegill 

sunfish (a warmwater fish). The acute studies that were submitted that tested the parent 

compound showed that clothianidin is practically non-toxic to freshwater fish (LC5o >105.8 -1 17 

pprn). Studies on degradates (TMG, MNG, and TZNG) indicated a similar practically non-toxic 

profile (LC5() >lo5 pprn). EFED will use the worst case value (LC50 >105.8 ppm) for 

evaluating acute toxic exposure to freshwater fish. 

A freshwater fish early life-stage test using the TGAI is required for clothianidin because the 

end-use product may be transported to water from the intended use site, and the following 

conditions are met: (1) clothianidin is intended for use such that its presence in water is likely to 

be continuous or recurrent regardless of toxicity; (2) studies on aquatic invertebrates showed 

reproductive effects (daphnid 21-day LOAEC = 0.12 ppm) and (3) clothianidin is persistent in 

water (e.g., half-life of 744 days aerobic soil metabolism). 

A chronic early life stage study conducted on the fathead minnow showed that exposure of 20 

pprn has the potential to affect length and dry weight of freshwater fish. The NOAEC of 9.7 

pprn will be used for risk assessment purposes. 

The preferred test species is sheepshead minnow. The data submitted showed that the LC5, = 

93.6 ppm; therefore, clothianidin is categorized as slightly toxic to estuarinelmarine fish on an 

acute basis. 

4.1.2 Freshwater and Marine Invertebrates 

A freshwater aquatic invertebrate toxicity test using the TGAI is required to establish the toxicity 

of clothianidin to aquatic invertebrates. The preferred test species is Daphnia magna. The data 

that was submitted that tested the parent compound showed that clothianidin is practically nontoxic to Daphnia magna with an acute 48-hour ECso value of >I19 ppm, but that it is very highly 

toxic to Chironomus riparius with an acute 48-hour EC50 value of 0.022 ppm. EFED will use the 

worst case value (ECSo= 0.022 ppm) for evaluating acute toxic exposure to freshwater 
invertebrates. Additional data (48-hour EC50) on degradates (TZNG, MNG, and TMG) indicated 

a practically non-toxic to slightly toxic profile (EC50 = 64.0 to >115.2 pprn). 

Acute toxicity testing with estuarinelmarine invertebrates using the TGAI is required for 

clothianidin because the end-use product is expected to reach this environment due to its 

potential use on crops with significant acreage in coastal counties. The preferred test species are 

mysid shrimp and eastern oyster. The data showed that clothianidin significantly reduced 

survival of mysid shrimp at 0.051 ppm, categorizing the compound as very highly toxic. 

Clothianidin was categorized as practically non-toxic to Eastern oyster because adverse effects 

did not occur for this species up to concentrations of 129.1 ppm. EFED will use the worst case 

value, LCso = 0.05 1 ppm, for evaluating acute toxic exposure to estuarinelmarine invertebrates. 

A freshwater aquatic invertebrate life-cycle test using the TGAI is required for clothianidin 

because the end-use product may be transported to water from the intended use site, and the 

following conditions are met: (1) the presence of clothianidin in water is llkely to be continuous 

or recurrent and (2) aquatic acute LCso or ECso values are less than 1 pprn (i.e., 0.022 ppm), and 

(3) physicochemical properties indicate that clothianidin is persistent in the aquatic environment 

(e.g., half-life of 744 days aerobic soil metabolism). 

The preferred test is a 21-day life cycle on Daphnia magna. The data that were submitted show 

that clothianidin has the potential for chronic toxicity to daphnids and possibly other freshwater 

invertebrates. Exposure to 0.12 ppm can result in reproductive effects, including the reduced 

number of juveniles produced per adult. The NOAEC of 0.042 pprn will be used in assessing 

risk. 

An estuarinelmarine invertebrate life-cycle toxicity test using the TGAI is required for 

clothianidin because the end-use product is expected to transport to an estuarinelmarine 

environment from the intended use site, and the following conditions are met: (1) the pesticide is 

intended for use such that its presence in water is likely to be continuous or recurrent regardless 

of toxicity, (2) an aquatic acute LCs0 or EC5() is less than 1 pprn (e.g., mysid LCso = 0.051 pprn), 

and (3) studies of other organisms indicate that the reproductive physiology of fish andlor 

invertebrates may be affected, physicochemical properties indicate cumulative effects, or the 

pesticide is persistent in water (e.g., half-life of 744 days aerobic soil metabolism). 

The preferred test species is mysid shrimp. The data submitted indicate that clothianidin reduced 

the number of young per reproductive day at 9.7 ppb. The NOAEC of 5.1 ppb will be used in 

assessing risk. 

Two studies were submitted that assessed toxicity to sediment dwelling freshwater and 

estuarinelmarine invertebrates. One study (MRID 46826902) assessed the toxicity to the midge 

(Chironomus riparius) during a 10-Day sediment exposure. This study revealed an LCs0 of 11 

ppb and a NOAEC of 1.1 ppb based on pore water concentrations. It also showed an LCso based 

on mean-measured sediment concentrations (OC normalized) of 12.91 mg/kg TOC and a 

NOAEC of 1.65 mg ailkg TOC. The other study (MRID 47199401) evaluated a 10-day whole 
sediment toxicity test with Leptocheirus plumulosus using spiked sediment. This study revealed 

an LCso of 20.4 ppb and a NOAEC of 11.6 ppb based on pore water concentrations. It also 

revealed an LC5() of 315 yg ailkg TOC and a NOAEC of 204 yg ailkg TOC based on meanmeasured sediment concentrations (OC normalized). Therefore, clothianidin is very highly toxic 

to sediment dwelling aquatic invertebrates. 

Calculations for sediment exposure to benthic organisms followed the equilibrium partitioning 

model as noted in Appendix D and applied in a previous risk assessment for cypermethrin 

(DP289427). The pore water based endpoints were measured in the studies, however the 

sediment based endpoints (OC normalized) are a function of the whole sediment LC50 divided 

by the proportion of organic carbon in the sediment. PRZM-EXMS provides both pore water 

and sediment concentrations (which were also adjusted based on the sediment concentration 

divided by the proportion of organic carbon in the sediment), so these values provided a direct 

comparison to the endpoints derived from the studies noted above. 

Chronic toxicity studies in benthic organisms were not submitted. To assess chronic risk to 

benthic organisms, chronic toxicity values were derived for both sediment and pore water. 

The chronic NOAEC estimated for benthic organisms in terms of yg a.i.kg sediment is 

based on the acute-to-chronic ratio method, determined by the following mathematical 

relationships : 

Freshwater invertebrate LCs0 (22 pg a.i./L) 1 Freshwater invertebrate NOAEC (42 yg 

a.i./L) = Benthic LCSo in sediment 12.91 mg a.i./kg sediment (OC normalized) / X 

(estimated benthic NOAEC value in sediment), where X = 24,600 pg a.i./kg TOC. 

Estuarinelmarine invertebrate LC50 (5 1 pg a.i./L) 1 Estuarinelrnarine invertebrate 

NOAEC (5.1 pg a.i./L) = Estuarinelmarine Benthic LC5() in sediment 315pg a.i./kg 

sediment(oc normalized) 1 X (estimated benthic NOAEC value in sediment-oc 

normalized), where X = 3 1.5 y g a.i./kg TOC. 

The chronic NOAEC estimated for benthic organisms in units of yg a.i.kg pore water is 

based on the acute-to-chronic ratio method, determined by the following mathematical 

relationships: 

Freshwater invertebrate LCso (22 yg a.i./L) 1 Freshwater invertebrate NOAEC (42 yg 

a.i./L) = Benthic LCso in pore water (1 1 yg a.i./L) / X (estimated benthic NOAEC 

value in pore water ), where X = 21 pg a.i./L pore water. 

Estuarinelrnarine invertebrate LCSo (5 1 pg a.i./L) / Estuarinelrnarine invertebrate 

NOAEC (5.1 pg a.i./L) = Benthic LC5() in pore water (20.4 pg a.i./L) 1 X (estimated 

benthic NOAEC value in pore water ), where X = 2.4 yg a.i./L pore water. 
No chronic toxicity tests on clothianidin formulations or clothianidin degradates in 

freshwater or estuarinelmarine benthic organisms were submitted. 

4.1.3 Aquatic Plants 

Several aquatic plant toxicity studies using the TGAI are required to establish the toxicity of 

clothianidin to non-target aquatic plants. The recommendation is for testing on five species: 

freshwater green alga (Selenastrum capricornutum), duckweed (Lemna gibba), marine diatom 

(Skeletonema costatum), blue-green algae (Anabaena flos-aquae), and a freshwater diatom. 

Studies submitted for two of the five recommended species showed that exposure to clothianidin 

at levels greater than or equal to 3.5 pprn reduced biomass of aquatic non-vascular plants and 

increased the incidence of necrotic fronds in aquatic vascular plants. Studies on degradates 

(TMG, MNG and TZNG) showed reductions in green algal cell density when exposed to levels 

>1.46 ppm. The ECso of 64 pprn will be used for evaluating acute toxic exposure to non-target 

aquatic plants. EFED needs 3 more Core clothianidin studies for the nonvascular surrogate 

species, marine diatom (Skeletonema costatum), blue-green algae (Anahaena Jlosaquae), and a 

freshwater diatom. 

4.2 Terrestrial Effects Summary 

4.2.1 Toxicity Effects on Terrestrial animals 

An extensive assessment of the potential exposure and risk to avian guideline species exposed to 

clothianidin by oral intubation or in the diet concluded that clothianidin was moderately toxic to 

bobwhite quail on an acute basis (LD50> 200 mglkg) and non-toxic to the mallard duck and 

bobwhite quail on a sub-acute basis (5 day LC50 >5040 pprn and 5230 pprn), respectively. The 

submitted chronic toxicity data show that exposure of 525 pprn of clothianidin in the diet 

adversely affected eggshell thickness (MRID 45422421). 

Likewise, an assessment of potential exposure and risk to small mammals exposed to 

clothianidin by the oral route suggests that clothianidin is moderately toxic to small mammals on 

an acute oral basis (mouse LD50 = 389 to 465 mglkglday). Reproduction studies in rats indicate 

that concentrations of 500 pprn clothianidin resulted in increased stillbirths and delayed sexual 

maturation in males. Developmental studies in rabbits indicate that concentrations of 75 

mg/kg/day resulted in premature deliveries, decreased gravid uterine weights, and increased litter 

incidence of missing lung lobeslfetus. 

4.2.2 Toxicity Effects on Invertebrates 

Currently, EFED does not assess risk to nontarget insects or terrestrial invertebrates using the 

risk quotient method. However, it appears that clothianidin exposure to honeybees has the 

potential for high toxicity on both an acute contact and oral basis. Acute toxicity studies to 

honey bees show that clothianidin has the potential to be highly toxic on both a contact and an 
oral basis (contact LD50 = 0.044 yghee; oral LD50 = 0.0037 pghee), while its degradates (e.g.,, 

TMG, MNG, TZMU, and TZNG) are moderately to practically non-toxic on an oral basis (LD50 

= 3.9 - >I53 ygtbee). One honey bee field study (MRID # 45422435) showed that mortality, 

pollen foraging activity, and honey yield were negatively affected by residues of clothianidin; 

however, residues were not quantified in this study. Another honey bee field study (MRID 

45422440) showed that pollen treated with clothianidin at a measured concentration level up to 

19.7 yg a.i./kg produced no significant adverse effects to mortality, foraging activity (including 

pollen and honey collection), comb production, honey storage behavior, population growth 

(including egg, larvae, pupae, and adult growth stages), and behavioral anomalies. However, 

only one replicate hive per treatment level was tested, therefore, statistical analysis of the data 

could not be performed. 

Subchronic invertebrate toxicity studies showed that clothianidin adversely affected earthworm 

mortality and body weight (LC50 = 15.5 ppm) and its degradates reduced body weight (LC50 = 

982.6 ppm). There were no apparent effects of clothianidin on earthworm reproduction or 

population dynamics. 

4.2.3 Toxicity Effects on Terrestrial Plants 

Terrestrial Tier I1 studies are required for all low dose pesticides (those with the maximum use 

rate of 0.5 Ibs a.i./A or less) and for any pesticide showing a negative response equal to or 

greater than 25% in Tier I studies. Two Tier I terrestrial plant toxicity studies were conducted to 

establish the toxicity of clothianidin to non-target terrestrial plants. The recommendations for 

seedling emergence and vegetative vigor studies are for testing of (1) six species of at least four 

dicotyledonous families, one species of which is soybean (Glycine max) and the second of which 

is a root crop, and (2) four species of at least two monocotyledonous families, one of which is 

corn (Zea mays). The studies that were submitted tested formulated products of clothianidin 

(49.3% TI-435 50% WDG). The results of these studies showed that exposure elicited no effect 

(that is, 2 25%) on non-target terrestrial plants, so Tier 11 tests were not necessary. 

4.3 Incident Database Review 

One incident was report in the EIIS, which was related to toxic effects to terrestrial invertebrates. 

The incident (1019743-001) involved hundreds of thousands of honeybees and was listed as 

highly probable, indicating that exposure to clothianidin was the llkely cause of death. 

According to a press release by a German government agency (BVL) and various news reports, 

beekeepers in Baden-Wurttemberg region of Germany had reported that two-thirds of their bees 

died in May 2008 following the application of a pesticide called clothianidin. Tests on dead bees 

showed that almost all of those examined had a build-up of clothianidin. The chemical, 

produced by Bayer Cropscience, is sold in Europe under the trade name Poncho. The seeds 

were treated in advance of being planted or were sprayed while in the field. The company said an 

application error by the seed company, which failed to use the glue like substance ("stickers") 

that sticks the pesticide to the seed, led to the chemical being dispersed into the air. Clothianidin 

is a systemic chemical that works its way through a plant and attacks the nervous system of any 
insect it comes into contact with and it is highly toxic to honeybees. The German Office for 

Consumer Protection and Food Safety has ordered the immediate suspension of the approval for 

eight seed treatment products including clothianidin as well as the related neonicotinoid 

ingredients imidacloprid and thiamethoxam, and the carbamate methiocarb. Germany 

temporarily pulled the registration for these seed treatments because of these incidents and the 

result of their studies. Investigations of bee kills determined that use of a particular type of 

pneumatic drilling equipment with treated seeds was causing a high exposure to bees. It appears 

that poorly applied corn seed treatments, together with physical abrasion of the treated seed by 

the pneumatic planters, led to dust clouds of pesticides being formed. These dust clouds drifted 

onto neighboring crops where bees were foraging. 

5 Risk Characterization 

Risk characterization is the integration of exposure and effects to determine the ecological risk 

from the use of such stressors as clothianidin. The risk characterization provides estimations and 

descriptions of the risk; articulates risk assessment assumptions, limitations, and uncertainties; 

synthesizes an overall conclusion; and provides the risk managers with information to make 

regulatory decisions. 

5.1 Risk Estimation 

The risk quotient (RQ) method was used to provide a metric for potential adverse ecological 

risks from the proposed uses of clothianidin. The risk quotient, a comparison of exposure 

estimates and toxicity endpoints, is estimated by dividing exposure concentrations by acute or 

chronic toxicity values (Appendix C). The resulting unitless RQs are compared to the Agency's 

levels of concern (LOC) to determine the need for regulatory action. 

These LOCs are criteria used by OPP to indicate potential risk to non-target organisms and the 

need to consider regulatory action. The criteria indicate that a pesticide used as directed has the 

potential to cause adverse effects on non-target organisms. LOCs currently address the 

following risk presumption categories: (1) acute - potential for acute risk is high, regulatory 

action may be warranted in addition to restricted use classification (2) acute restricted use - 

potential for acute risk is high, but this may be mitigated through restricted use classification (3) 

acute endangered species - the potential for acute risk to endangered species is high, regulatory 

action may be warranted, and (4) chronic risk - the potential for chronic risk high, regulatory 

action may be warranted. Currently, EFED does not perform assessment for chronic risk to 

plants, acute or chronic risks to non-target insects or chronic risks from granularhait 

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) LCso (fish 

and birds), (2) LDso (birds and mammals), (3) ECso (aquatic plants and aquatic invertebrates, and 

(4) EC15 (terrestrial plants). An example of a toxicity test effect level derived from the results of 

a long-term laboratory study that assesses chronic effects is (1) NOAEC (birds, fish, and aquatic 

invertebrates). Risk presumptions, along with corresponding RQs and LOCs are tabulated in 
Appendix B. 

5.1 .I Aquatic Risk Quotients 

The proposed seed treatments did not appear to pose an acute or chronic risk to either freshwater 

or saltwaterlestuarine fish (Table 10). However, chronic risk to saltwaterlestuarine fish could 

not be evaluated due to a lack of data on these taxa. h two of the scenarios, Mississippi and 

North Carolina cotton, the new uses pose acute risk to threatened and endangered freshwater 

invertebrates for both low efficiency and high efficiency incorporation applications. Only the 

low efficiency incorporation scenario with Mississippi and North Carolina cotton pose acute risk 

to threatened and endangered estuarinelmarine invertebrates. Regarding chronic risk to aquatic 

invertebrates, only two scenarios showed risk in the high efficiency incorporation scenarios: the 

Mississippi and North Carolina cotton scenarios with risk to estuarinelmarine invertebrates. 

However, with low efficiency incorporation there was risk in all scenarios to estuarinelmarine 

invertebrates and risk to freshwater invertebrates in the North Carolina and Mississippi cotton 

scenarios. 

Table 13. Summary of aquatic risk quotients for fish and aquatic invertebrates based on 

surface water EECs. LOC exceedances are in bold. 
Risk to sediment dwelling freshwater and estuarinelmarine invertebrates was assessed using the 

methods established for cypermethrin (DP289427) and described in section 4.1.2. Acute risk is a 

function of the peak pore water and organic carbon normalized sediment concentrations from 

PRZM-EXMS and the corresponding LCso identified in the studies. Chronic risk is a function of 

the average 21 day OC normalized sediment bound concentration and the corresponding 

estimated chronic LCso values also described in section 4.1.2. 

ND Canola 

(mustard) 

The proposed uses result in acute risk to aquatic benthic invertebrates through exposure to both 

pore water and sediment bound OC normalized concentrations of clothianidin for cotton and 

mustard (Tables 11 and 12). Risk was present for both low efficiency and high efficiency 

application scenarios. However, chronic risk was only found for estuarinelmarine invertebrates 

I~cute RQs are based on the peak EEC 

'chronic RQs are based on the 21-day average EEC for invertebrates and the 60-day average EEC for fish 

3~~'s exceed the threatened and endangered aquatic invertebrate LOC of 0.05 

N/A 

exposed to sediment bound residues, but risk was present for all application scenarios (Table 

13). 

4.74E-05 0.09413 

Table 14. Summary of aquatic acute risk quotients for benthic aquatic invertebrates based 

0.01 14 

Table 15. Summary of aquatic acute risk quotients for benthic aquatic invertebrates based 

on sediment bound (organic carbon normalized) EECs. Potential LOC exceedances are in 

bold. 

0.03 0.3' 0.0 162 0.0284 

Crop I Benthic Aquatic Invertebrate Risk ~uotients' 

High Efficiency 1 Acute RQs for I Sublethal RQs for ( Acute RQs for I Sublethal RQs for 

Low Efficiency 

Incorporation 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

(mustard) 

 cute RQs are based on the peak pore-water EEC and the LCs0. Sublethal RQs are based on the peak pore-water 

EEC for invertebrates and the NOAEC. 

'RQS exceed the threatened and endangered aquatic invertebrate LOC of 0.05 

'RQS exceed the acute risk LOC of 0.5 and the endangered species LOC of 0.05 

Acute RQs for 

Freshwater 

Invertebrates 

0.0222 

0.197~ 

0.225' 

0.0374 

Sublethal RQs for 

Freshwater 

Invertebrates 

0.222~ 

1.97~ 

2.253 

0.374' 

Acute RQs for 

EstuarineJMarine 

Invertebrates 

0.01 19 

0.106' 

0.121' 

0.0201 

Sublethal RQs for 

EstuarineIMarine 

Invertebrates 

0.0210 

0.187~ 

0.214' 

0.0354 
Table 16. Summary of aquatic chronic risk quotients for benthic aquatic invertebrates 

based on sediment bound (organic carbon normalized) EECs. Potential LOC exceedances 

Incorporation 

CA Cotton 

MS Cotton 

NC Cotton 

(mustard) 

Low Efficiency 

Incorporation 

CA Cotton 

MS Cotton 

NC Cotton 

ND Canola 

(mustard) 

are in bold. 

Estuarinemarine 

Invertebrates 

0.810~ 

1.36~ 

0.926~ 

Estuarine/Marine 

Invertebrates 

1.25~ 

2.10~ 

1.43~ 

Freshwater 

Invertebrates 

0.0 198 

0.0332 

0.0226 

 c cute RQs are based on the peak OC normalized sediment bound EEC and the OC normalized LC50. Sublethal 

RQs are based on the peak OC normalized sediment bound EEC for invertebrates and the OC normalized NOAEC. 

2~~s exceed the threatened and endangered aquatic invertebrate LOC of 0.05 

3~~s exceed the acute risk LOC of 0.5 and the endangered species LOC of 0.05 

0.00387 

Acute RQs for 

Freshwater 

Invertebrates 

0.0393 

0.0647' 

0.0428 

0.00738 

1 ND Canola I 1 1 I I 

Freshwater 

Invertebrates 

0.155~ 

0.259' 

0.177' 

MS Cotton 

0.0303 

Sublethal RQs for 

Freshwater 

Invertebrates 

0.307' 

0.506~ 

0.335' 

0.0578' 

0.0386 1 0.0 174 

(mustard) - 

Low Efficiency 

Incorporation 

CA Cotton 

1 ND Canola I I I I 1 

0.159' 

Acute RQs for 

EstuarinelMarine 

Invertebrates 

l.613 

2.65j 

1.75~ 

0.303' 

- - 

MS Cotton 

0.245' 

Sublethal RQs for 

EstuarineIMarine 

Invertebrates 

2.483 

4.09~ 

2.713 

0.467' 

0.337 

NC Cotton 

0.00809 

Freshwater 

Invertebrates - 

Pore Water 

0.0 105 

chronic ECS0 

'ROS exceed the chronic LOC of I 

13.6~ 

0.0476 0.01 19 

0.0752 

(mustard) 

Risk to vascular and non-vascular plants was negligible. Using data on Lemna gibba and the 

most sensitive algal species, Selenastrum capricornutum, RQ's ranged from 0.00205 for listed 

non-vascular plants and 5.08E-05 for listed vascular plants in the most conservative scenario for 

low efficiency incorporation applications. Neither of these values, which represents the 

maximum RQ's that can be expected, exceeds the endangered aquatic plant LOC of 1. 

0.00203 

Freshwater 

Invertebrates - 

Sediment Bound 

0.0205 

NC Cotton 

0.4 17 

0.0338 

'RQS are based on the 2 1 day pore-water and OC normalized sediment bound residue EEC and the estimated 

0.0157 

9.26' 

0.0708 

Estuarinemarine 

Invertebrates - Pore 

Water 

0.0917 

0.0900 

1.59' 

EstuarineIMarine 

Invertebrates - 

Sediment Bound 

16.0' 

0.658 

0.00387 

- 

26.4' 

0.0224 

0.137 

0.787 

3.03' 

17.5' 
5.1.2 Terrestrial Risk Quotients 

Table 14 summarizes the acute and chronic avian and mammalian RQs. Two scenarios were 

modeled for birds and mammals. The first scenario is based on the lack of a specific method of 

incorporation in the label language. In this scenario, 100% availability of the treated seed was 

assumed based on a broadcast application without incorporation or minimal incorporation. In 

this scenario, maximum avian acute RQ's ranged from 2.67 to 3.06 for cotton and mustard, 

respectively, and chronic RQ's ranged from 17.07 to 19.51. These RQ's result in risk to listed 

on non-listed birds. Maximum mammalian acute RQ's ranged from 1.64 to 1.87 for cotton and 

mustard, respectively, and chronic RQ's ranged from 23.33 to 26.67. These RQ's also result in 

risk to listed and non-listed mammals. However, under the second scenario in which an 

incorporation method is specified (i.e. T-Banded - covered with specified amount of soil, Infurrow, drill, or shanked-in) the resulting RQ's showed a maximum value of 0.03 for acute risk 

and 0.27 for chronic risk, neither of which result in risk to listed or non-listed birds or mammals. 

Currently, EFED does not assess risk to non-target insects. Results of acceptable studies are 

used for recommending appropriate label precautions. Available registrant submitted studies for 

the honey bee indicated that clothianidin is highly toxic to bees. While bees will generally not be 

exposed to clothianidin residues through direct contact due to the seed treatment, exposure to 

contaminated pollen and nectar could not be evaluated. Therefore, EFED cannot pedict risk in 

any capacity towards insects. 

Table 17. Summary of Terrestrial Acute and Chronic Risk Quotients. Values in bold 

represent an exceedence of the respective LOC. 

Amle h-Brtsed RQs I Chronic RQS~ 

Mammalian RQs 

23.33 

5.2 Risk Description 

cotton5 

Mustard4 

oilseed) 

Mustard5 

(condiment, 

oilseed) 

The results of this baseline risk assessment show that the proposed new uses may pose acute risk 

to both freshwater and saltwater invertebrates. The results also indicate that the proposed uses 

for clothianidin may pose risk to both non-listed and listed mammalian and avian taxa, 

0.03 

oi cute RQs for birds and mammals are determined by dividing the estimated dietary intakes (mglkg-bwlday) by a 

body weight adjusted avian LD50 of 1333 mgkg-bw for mallard duck and a body weight adjusted mammalian LDjo 

of 5000 mg/kg-bw for the rat. 

 cute RQs were based on pesticide applied per square foot (mg a.i./ft*/L~~~*bw) 

'chronic RQs were based on clothianidin seed application rate (mg a.i./kg seed) divided by a dietary-based NOAEC 

(550 mglkg-diet for the mallard duck and a 200 mag-diet for the rat). 4 RQ's based on broadcast application ~ith 100% availability of application rate on seeds. 

'RQ's based on specified incorporation method and 1 % availability of application rate on seeds. 

0.03 

(condiment, 3.06 

0.00 

0.00 

0.04 

0.02 

0.02 

1.87 

0.00 

0.00 

0.04 

0.17 

0.02 

0.23 

19.51 

0.27 

26.67 
depending on the presence or absence of protective label language. Therefore, the hypothesis is 

supported that clothianidin has the potential to compromise survival and cause sub-lethal effects 

in non-target species. Risk to non-target beneficial insects cannot be assessed, but will be 

qualitatively discussed in the following sections. 

5.2.1 Risk to Aquatic Organisms 

The available data on clothianidin show that the compound is relatively persistent to very 

persistent under most circumstances. Clothianidin is stable to hydrolysis at all pH's at 

environmental temperatures, moderately to highly stable under aerobic soil metabolism 

conditions (half-lives range from 148-6,900 days), and shows moderate stability under anaerobic 

aquatic metabolism (half-life of 27 days for the overall system). Laboratory data suggests that 

photolysis appears to play a role in the dissipation of the chemical (half-life of 14.4 hours in 

sterile water, 25.4 hours in natural water, and 34 days on soil). Clothianidin has medium to very 

high mobility in soils. The fact that the KOC's of four of the five soils were of similar order of 

magnitude (range 84-129) indicates that there may be a correlation of the mobility with the 

organic carbon content of the soil. Certain degradates appeared to accumulate in some soils 

under some conditions [e.g., TZNG MNG, NTG, (aerobic) and TMG (anaerobic)]; over the very 

long term significant contamination of soil and water with these products might occur. The 

terrestrial field dissipation studies confirm the findings in the laboratory studies. Clothianidin 

was found to be persistent in the field (half-lives of 277 days, 1,400 days, and too high to 

calculate). Based on the overall picture that the laboratory and field studies provided, EFED 

concluded that there is a very high likelihood that clothianidin would persist and accumulate 

from year to year after repeated uses. 

The potential impact to water quality from the use of clothianidin appears to be most likely due 

to the parent compound. The laboratory studies indicate that clothianidin is initially labile and 

then relatively persistent under most environmental conditions. This makes the chemical 

available for lengthy periods of time for runoff and exposure to aquatic environments. The 

impact of clothianidin to aquatic environments will also be affected by its mobility. The 

available studies indicated that clothianidin is persistent and mobile, stable to hydrolysis and has 

potential to leach to ground water and be transported via runoff to surface water, and will 

accumulate and persist in soils. 

Non-target aquatic organisms (freshwater and estuarinelmarine fish and invertebrates) can be 

exposed to clothianidin from the proposed uses mainly by runoff into surface water. EFED's 

risk assessment suggests that toxic risk to freshwater and estuarinelmarine fish appears low. 

Acute, restricted use, and endangered species acute and chronic levels of concern for freshwater 

and estuarinelrnarine fish were not exceeded for the application rates and uses evaluated. 

Chronic risk to estuarinelrnarine fish could not be evaluated in this assessment due to the lack of 

data on this taxa. Given the low level of chronic toxicity of freshwater fish as well as the low 

acute toxicity of estuarinelmarine fish, as well as the resulting very low RQ values to these taxa, 

it appears unlikely that the proposed uses of clothianidin would pose a chronic risk to estuarine 

and marine fish. 

The proposed uses for mustard did not result in acute or chronic risk to either freshwater or 
estuarine/marine free-swimming invertebrates, except in the low efficiency incorporation where 

chronic risk was found for estuarine/marine invertebrates. However, the proposed cotton use in 

two of the scenarios, North Carolina and Mississippi, posed acute risk to freshwater invertebrates 

in both the low efficiency and high efficiency incorporation methods. Only the low efficiency 

incorporation method posed acute risk in the same scenarios to estuarine and marine 

invertebrates, suggesting that the method of incorporation is important in determining risk to 

these taxa. Chronic risk to free-swimming estuarinelmarine invertebrates was present in all of 

the cotton scenarios with low incorporation efficiency, but only in North Carolina and 

Mississippi with high incorporation efficiency. High incorporation efficiency eliminated chronic 

risk to freshwater free-swimming invertebrates. 

The clothianidin toxicity threshold is low for freshwater benthic invertebrates on an acute basis, 

so their vulnerability represents acute potential risk from accumulations of clothiandin in 

sediments. A comparison of peak EECs, both pore water and sediment bound residues, with the 

LCs0 (mortality) and the NOAEC (sublethal) reveals that the proposed uses have the possibility 

of acute toxic risk to non-endangered and endangered freshwater and estuarinelmarine benthic 

invertebrates, via runoff especially if repeated uses occur (Table 12). The acute risk, based on 

both lethal and sublethal effects, to estuarine/marine benthic invertebrates was independent of 

the region and the incorporation efficiency when exposure occurs via sediment bound 

concentrations. Chronic risk to this taxa also shows a similar result. This conclusion suggests 

that the application rates would need to be amended or other mitigation options that would 

reduce run-off are required to refine the risk any further. 

5.2.2 Risk to Terrestrial Organisms 

EFED's risk characterization of terrestrial animals focused on the potential for acute and chronic 

toxic risk from exposure to residual clothianidin after application. Based on proposed 

application rates and uses, acute risks is possible to terrestrial small birds and mammals. Results 

from exposure modeling of representative species indicates that acute (small birds and mammals) 

and chronic (birds and mammals) RQs exceed LOCs. 

The exceedences and thus the risk are only present when no label language specifies the 

incorporation method. Given no incorporation or only minimal incorporation, the proposed uses 

for mustard and cotton pose an acute and chronic risk to birds and mammals. Incorporation of 

the treated seeds into the soil by certain methods as modeled in TREX eliminated all of the risk 

to both birds and mammals in the risk picture. According to current modeling approaches in 

EFED using TREX, the modeling assumptions for the various incorporation methods are as 

follows in terms of percent a.i. still available on the seeds that could be forage: 

T-Banded - covered with specified amount of soil: 1 % 

In-furrow, drill, or shanked-in: 1% 

Side-dress, banded, mix, or lightly incorporate with soil: 15% 

Broadcast, mix, or lightly incorporated: 15% 

Side-dress, banded, unincorporated: 100% 

Broadcast, aerial broadcast, unincorporated: 100% 
These modeling assumptions illustrate the typical types of seed incorporation that can best 

mitigate any risk to birds and mammals. 

Another source of potential concern is the uncertainty surrounding clothianidin's possible role as 

an endocrine disrupter as noted from mammalian developmental and reproductive effects. This 

issue is compounded by the fact that clothianidin is an analog of nicotine and that studies in the 

published literature suggest that nicotine, when administered, causes developmental toxicity, 

including functional deficits, in animals and/or humans that are exposed in utero. Mammalian 

data shows that exposure to clothianidin can result in developmental effects (rabbit) that include 

premature deliveries, decreased gravid uterine weights, and increase incidence of missing lung 

lobe in fetus. The mammalian data also suggests that chronic toxicity in mammals can be 

manifested as systemic effects that can include decreased body weight gains and delayed sexual 

maturation (males only); decreased absolute thymus weight in F1 pups (both sexes), and 

increased stillbirths (Fl and F2 litters). Reproductive effects were also noted for adult rats that 

included decreased sperm motility and increased number of sperm with detached heads. 

Although these effects did not reduce rat fecundity, they do raise an uncertainty as to possible 

reproductive effects to other species that may have a more limited (less frequent) reproductive 

capability. 

Accumulation of clothianidin in soils as the result of multiple applications and repeated or 

continuous exposure may adversely affect soil invertebrates. Subchronic invertebrate toxicity 

studies showed that clothianidin adversely affected earthworm mortality and body weight (LC5o 

= 15.5 ppm) and its degradates reduced body weight (LC5o = 982.6 ppm). Additional testing 

(chronic study) or modeling may be needed to determine if soil invertebrates are at risk from 

repeated uses of clothianidin. 

Although EFED does not do a risk assessment on non target insects, information from standard 

tests and field studies, as well as incident reports involving other neonicotinoid insecticides (e.g., 

imidacloprid) also suggest the potential for long term toxic risk to honey bees and other 

beneficial insects. Other neonicotinoid compounds like imidacloprid (e.g., sunflower seed 

treatment) have resulted in incidents to honey bees. The National Union of French Beekeepers 

had concerns regarding imidacolprid (GAUCHO) seed treatment to sunflowers after beekeepers 

noted that honey bees were showing modifications of behavior that were reflected in foraging 

and orientation that eventually resulted in a drastic change in hive conditions and bee survival. 

Further research by the Le Centre Technique Interprofessional des Oleagineux (CETIOM) 

confirmed imidacloprid toxic residue levels in the sunflower nectar. This action has prompted 

France to ban the use of imidacloprid for sunflower seed treatment. Since clothianidin has a 

similar toxicity profile as imidacloprid and is a member of the same family of compounds, there 

is uncertainty regarding the toxic risk to honey bee development and foraging behavior, as well 

as the welfare of the queen from long term exposure to clothianidin residues that can be stored in 

the hive in honey andlor pollen. 

A previous field study (MRID 46907801146907802) investigated the effects of clothianidin used 

as a seed treatment on whole hive parameters and was classified as acceptable. However, after 
another review of this field study in light of additional information, deficiencies were identified 

that render the study supplemental. 

In this field study, control and treated plots were each 1 hectare in size and paired, so that 4 sites 

were established with a control plot paired with a treated plot. These plots were separated by a 

minimum of 250 m. The study author states, "Of 23 back-up control nectar samples, 2 (field 

EIC, July 7; field W3C, July 7) had detectable clothianidin residues, at a maximum of 0.922 

ppb, suggesting that workers in control colonies may have foraged on clothianidin-treated 

canola. This may have occurred because the separation between some pairs of control and 

treated fields was insufficient or because the forage in some control fields was of lower 

quality.. ." The inverse may also have occurred. That is, bees placed on treated fields likely 

foraged on the control fields, which would have reduced the level of exposure to clothianidin 

residues due to a lack of separation between sites. Bees have been shown to forage up to 6 km 

(Visscher and Seeley, 1982) or even twice that in some instances when no competing forage is 

present (Ratnieks, 2000). The distance of 250 m is inadequate for this separation. The 

inadequacy is evident given contamination in some of the nectar samples taken from control 

hives. 

Furthermore, the study authors state that, "Approximately 5 g of pollen was analyzed under a 

light microscope, which confirmed that bees foraged on canola, while the remainder.. .". This 

type of identification simply identifies that canola was present in the pollen samples, but does not 

quantify the proportion of canola pollen present in the sample. This type of pollen evaluation 

does not characterize the foraging of the bees. The bees in the treated fields could have foraged 

disproportionately on other uncontaminated sources relative to bees in the control fields. 

Furthermore, the study authors simply state that to their knowledge, no other forage was present 

with a radius of 1 km from the edge of the fields. However, given the ability of bees to forage 

long distances, this lack of data leaves uncertainty in the exposure and suggests that this study 

did not provide the worst case exposure scenario necessary for use in characterizing risk. 

An addendum (MRID 46907802) was submitted later that presented the results of the 

overwintering part of the study, which revealed that the majority of the hives, including those 

exposed to clothianidin during the previous season, survived the overwintering period. 

However, the cross-contamination in the control hives prevents a comparison between the 

control hives and the treated hives as they relate to whole hive parameters in this addendum. 

Therefore, this study can only be used to provide a qualitative description of hive survival 

following the exposure to clothianidin at the levels that were described in the study. 

It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the 

effects of clothianidin on bees through contaminated pollen and nectar. Exposure through 

contaminated pollen and nectar and potential toxic effects therefore remain an uncertainty for 

pollinators. Further studies are needed to determine the toxicity to honeybees from seed 

treatment applications. 

Bayer has submitted an interim report (MRID 477987-01) on a study they are conducting in 

Austria. According to the report, the objective of the study was to investigate the frequency at 

which maize seedlings exude guttation fluid and to assess the relevance of guttation fluid to 
honeybees. Although not specifically mentioned in the text of the report, the study material 

appears to be clothianidin (based on one of the report figures). Over the two study areas, 

roughly 83% of the maize seedlings exuded guttation liquid. According to the report 16% of the 

assessment days at which guttation fluid was observed, honeybees were present when no 

alternative water supply was available; however, when alternative water was available, the 

honeybee visitation rate was 4%. Clothianidin residue levels in bees were greater than the level 

of quantification up to 14 days after seedling emergence; in bees without alternative water 

supply, honeybee mortality appeared to be correlated with clothianidin residues; however, the 

number of bees for which this relationship existed is uncertain. The study authors state that 

despite an increased bee mortality in some hives for 1 - 3 days during the survey, the overall 

development of the hives was not adversely affected by guttation fluid even under realistic, worst 

case exposure conditions. 

This is an interim report and it does not contain sufficient detail or raw data with which to 

understand the study. The methods section does not describe the placement of colonies with and 

without water, nor is it possible to determine what bees were actually foraging on during the 

study period. It appears from the study that at least some of the bees did take advantage of the 

guttation liquid and that they were exposed to clothianidin. In some cases, bees exhibited 

behavioral effects and increased incidence of mortality that appeared to be associated with 

elevated clothianidin residues. 

Clothianidin is a neonicotinoid insecticide that is relatively persistent in the environment; the 

compound is intended to be systemic in plants and the extent to which residues may be present in 

various plant tissues from seed treatments is uncertain. Clothianidin is highly toxic to bees on 

both an acute contact and oral exposure basis. A concern from the current seed treatment uses 

may be to beneficial insects (pollinators) that forage on crops grown from treated seed where 

exposure may occur through ingestion of residues in pollen and nectar as well as through 

guttation water produced by developing seedlings. Seed treatments are normally considered a 

lower exposure element to bees due to possible full ground incorporation of the seeds as well as 

a low drift component of the application to adjacent areas where bees may forage. However, 

recent incidents in Europe resulting from seed treatments where appropriate stickers were not 

utilized, indicate that dust-off drift can also have a significant impact on pollinators foraging in 

the vicinity of recently seeded fields under some environmental conditions. As such, there is 

uncertainty regarding the extent to which seed treatments may represent a route of exposure due 

to the compound's systemic and persistent nature. 

5.2.3 Risk Refinement 

Both high and low efficiency incorporation resulted in acute risk to freshwater invertebrates in 

North Carolina and Mississippi cotton, whereas cotton in California and mustard in North 

Dakota did not result in an exceedence of the LOC. These results suggests that certain regions of 

the country are more vulnerable to run-off and exposure of the proposed application rates of 

clothianidin, and therefore to the potential for the toxic effects of clothianidin to freshwater 

invertebrates. The acute lethal toxicity to benthic invertebrates also suggests this conclusion. 
These organisms are an integral part of the freshwater trophic system and serve as both 

decomposerslpredators that are important for nutrient cycling and a food source for larger 

predators (e.g., fish). The ecological integrity in these vulnerable areas in the U.S. could 

therefore be impacted by the use on cotton at the proposed application rate. A reduction in the 

cotton application rate together with maximum incorporation of the seeds into the ground could 

therefore limit the exposure of clothianidin to aquatic invertebrates through run-off. 

Specific label language that clearly states a method of incorporation and incorporation depth 

would make a significant impact on other risk conclusions of the proposed new uses. Risk to 

estuarinelmarine invertebrates on an acute basis could be effectively mitigated by this label 

language, as shown by the lack of LOC exceedences in the high efficiency incorporation 

scenario (section 5.1.1). In addition, label language that would specify more efficient 

incorporation methods, such as T-banded incorporation with a specified depth, would eliminate 

all risk to birds and mammals by burying the seeds into the ground and thereby limiting any 

foraging on these seeds. 

5.3 Uncertainties 

5.3.1 Exposure and Effects Assessment 

Accumulation of clothianidin in soils after repeated uses and the potential for 

transportlmigration to surface water bodies and potential risk to sensitive aquatic 

invertebrates (e.g., sediment-dwelling benthic organisms) 

Potential toxic risk to pollinators (e.g. honeybees) as the result of accumulation from seed 

treatments and/or foliar spray on plants/blooms from repeated uses in cotton and mustard 

Repeated or continuous exposure to soil invertebrates and small mammals to clothianidin 

accumulated in soils after repeated uses. 

Data Gaps: The data gaps that were outlined in Section 2.6.1 were either required or 

conditionally required for clothianidin and still have to be submitted. Acceptable data 

from these studies will aid in reducing some of the uncertainty associated with this 

assessment. 

6 Bibliography 

Nagy, K. A. 1987. Field metabolic rate and food requirement scaling in mammals and birds. 

Ecological Monographs. 57: 1 1 1- 128. 

U.S. Environmental Protection Agency. 1998. Guidelines for Ecological Risk Assessment. Risk 

Assessment Forum, Office of Research and Development, Washington, D.C. EPAl6301R951002F. April 1998. 

U.S. Environmental Protection Agency. 2004a. Overview of the Ecological Risk Assessment 
Process in the Office of Pesticide Programs, U.S. Environmental Protection Agency. 

Endangered and Threatened Species Effects Determinations. Office of Prevention, 

Pesticides and Toxic Substances, Office of Pesticide Programs, Washington, D.C. 

January 23,2004. 

U.S. Environmental Protection Agency. 2004b. Science Advisory Council for Exposure 

Standard Operating Procedure (SOP) #15: Amount of Seed Treated or Planted Per Day. 

U.S. Environmental Protection Agency. 2005. Generic Format and Guidance for the Level I 

Screening Ecological Risk Assessments Conducted in the Environmental Fate and Effects 

Division. Office of Pesticide Programs, Washington, D.C. January 24, 2005. 

U.S. Environmental Protection Agency. 2004. Overview of the Ecological Risk Assessment 

Process in the Office of Pesticide Programs. http:Nwww.epa.govloppfeadl/ 

endanger/consultationlecorisk-overview .pdf 
Appendix A. REX Methodology to Calculated Nagy Doses (EECs) 

and Risk Quotients for Birds and Mammals 

The seed treatment worksheet of TREX calculates the avian and mammalian doses or exposure concentrations using 

two approaches: Nagy doses (mg a.i./kg-bw day-') and pesticide available on unit soil surface area (mg a.i. ft2). 

Nagy doses are used in the calculation of both acute and chronic RQs for birds and mammals. Only acute RQs are 

calculated using the pesticide available on unit soil area. 

Nagy doses for seed treatment applications are calculated using the scaling factor approach for a 20-gram bird and 

15-gram mammal. The scaling factor approach adjusts the food intake and toxicity values to account for the 

differences in the size of the animal assessed compared with the size of the animal used in the toxicity tests. The 

Agency calculates the avian and mammalian Nagy doses using the equation below: 

Avian and Mammalian Nagy Doses (mg a.i./kg-bw) = (daily food intake glday "0.00 1 kglg * maximum seed 

application (mg/kg-seed) / (body weight of animal (kg) 

In the second approach, the amount of pesticide available on unit soil surface area is calculated by converting the 

maximum application rate from Ib acre-' to rng a.i.lft2. The equation used for this calculation is presented below: 

Available a.i.(rng a.i.lft2) = (Maximum application rate (IbsIAcre) * lo6 mgkg) l(43,560 square feetlacre * 2.2 

IbJkg) 

Calculation of Risk Quotients (RQs) for Seed Treatment Applications 

Acute risk quotients are calculated using the adjusted LD50 value for the smallest weight class of animal (20g for 

birds and 15g for mammals). Acute RQs are calculated using the two methods: 

Method 1 or EEC/LDSo method 

Acute RQ = mg a.i./kg-' day-'/adjusted LDSo 

Method 2 or EEC/LDso ft" method 

Acute RQ = mg/kg-' a.i. ft2 / (adjusted LDso * body weight (kg) 

Chronic RQs, which are not adjusted to different weight classes of birds or mammals, are calculated using the 

following equation: 
Appendix B. Summary of Ecotoxicity Data 

Toxicity to Terrestrial Animals 

Birds, Acute and Subacute 

An oral toxicity study using the technical grade of the active ingredient (TGAI) is required to establish the acute 

toxicity of clothianidin to birds. The preferred guideline test species is either mallard duck (a waterfowl) or 

bobwhite quail (an upland gamebird). The data that were submitted show that the 14-day oral LD50 is >2.000 mgkg 

for bobwhite quail. The NOAEL is 500 mgkg with observed effects including reduced mean body weights, 

mortality and clinical effects (subdued birds) in the 1,000 and 2,000 mgkg test groups. A study conducted on a 

non-guideline species, Japanese quail, showed that the 14-day oral LD50 is 423 mglkg. The NOAEL is 12.5 mdkg 

bw based on clinical signs of toxicity (lethargy and ruffled appearanced) at the 25 mg/kg treatment level. Based on 

these results, clothianidin is categorized as ranging from practically non-toxic to moderately toxic to avian species 

on an acute oral basis; the guideline (7 1 - 1 ) is fultilled (MRID $4542241 7). 

Avian Acute Oral Toxicity I 

species % ai LDSO Toxicity MRlD No. Study 

(Wm2) Category Author, Year Classification 

Northern bobwhite quail 96.0 >2,000 Practically non- 454224 17 Core 

(Colinus virginianus) toxic Johnson, 1998 

Japanese Quail 97.6 423 Moderately toxic 4542241 8 Supplemental 

(Coturnix coturnix Gallagher et 

japonica) al., 2000 

Two dietary studies using the TGAI are required to establish the subacute toxicity of clothianidin to birds. The 

preferred test species are mallard duck and bobwhite quail. The data that were submitted show that the 8-day acute 

dietary LC50 is >5,000 ppm; therefore, clothianidin is categorized as practically non-toxic to avian species on a 

subacute dietary basis. The 8-day NOAEC's for each species based on sublethal effects (reduced body weight gain) 

were 309 ppm for the quail and 646 ppm for the mallard. The guideline (71-2) is fulfilled (MRID $45422419; 

MRID #45422420). 

Avian Subacute Dietary Studies 

I 1 

Species % ai 5-Day LC50 Toxicity MRlD No. Study 

(PP~)' Category Author, Year Classification 

Northern 96 

bobwhite quail 

(Colinus 

virginianus) 

>5,230 Practically non- 454224 19 Core 

toxic Johnson. 1998 

Mallard duck 96 >5,040 Practically non- 45422420 Core 

(Anas toxic Johnson, 1998 

platyrhynchos) 

Birds, Chronic 

Avian reproduction studies using the TGAI are required for clothianidin because birds may be subject to repeated or 

continuous exposure to the pesticide, especially preceding or during the breeding season. The preferred test species 

are mallard duck and bobwhite quail. The submitted data show that clothianidin exposure of 525 ppm adversely 
affected eggshell thickness for bobwhite quail, but did not result in chronic effects during reproduction for mallard 

duck; the guideline (7 1-4) is fulfilled (MRID #4542242 1 ; MRID #45422422). 

Avian Reproduction 

I I I 

Species 

Northern bobwhite 

quail 

(Colinus virginianus) 

% ai 

Mallard duck 

(Anas platyrhynchos) 

Eggshell 

thickness 

LOAEC 

End~oints 

NOAECnOAEC 

(PP~) 

97.6 45422421 

Gallagher et al., 

2000 

MRID. No. 

Author. Year 

2051525 

97.6 5251>525 No effect on ( 45422422 

Study 

Classification 

reproduction 

Core 

Gallagher et 

al.., 2000 

Supplemental 

Mammals, Acute and Chronic 

Wild mammal testing is required on a case-by-case basis, depending on the results of lower tier laboratory 

mammalian studies, intended use pattern and pertinent environmental fate characteristics. In most cases, rat or 

mouse toxicity values obtained from the Agency's Health Effects Division (HED) substitute for wild mammal 

testing. These toxicity values are reported below. 

Mammalian Acute and Chronic Toxicity 

Species % Toxicity 

ai. 

Rat 

(Rattus 

norvegicus) 

Test 

Type 

Mouse 

(Mus 

musculus) 

I NOAEL (M) = 3 1.2 mg/kg/day 

(500 ppm0)5 

96 

Rat 

(Rattus 

norvegicus) 

LOAEL (M)= 163.4 mgkglday 

(2500 vurnl5 

96 

Acute 

96 

LDso =5,000 mglkglday 

Acute 

Rabbit 

(Sy lvilagus 

SP.) 

Affected 

Endpoints 

Mortality 

LDSo = 389-465 mglkglday 

2-Generation 

Reproduction 

MRID No. 

Author, 

Year 

45422621 

Gardner, 1997 

Mortality 

NOAEL (MIF) = 9.811 1.5 

mg/kg/day (1 501500 pprn)' 

LOAEL (M/F) = 3 1.2136.8 

mglkglday (5001500 ppm)5 

'~ecreased body weight gains and delayed sexual maturation (males only); dec 

F1 pups (both sexes), and increased stillbirths (F1 and F2 litters). 2 Decreased sperm mobility and increased number of sperm with detatched heac 

3~remature deliveries, decreased gravid uterine weights, and increased litter in( 

96 ~evelo~ment~ 454227 12 and / -13, 

1998 

.eased absolute thymus weight in 

45422622 

Gardner, 1997 

Offsprinf 

systemic 

s (FI and F2 litters). 

idence of missing lobe of the lung 

45227 14- 16 

and 

45422825-26, 

2000and2001 

Developmental NOAEL/LOAEL = 25/75 

mgkglda~ 

(82512,475 ppm)4 
The results indicate that clothianidin is categorized as practically non-toxic to small mammals on an acute oral basis 

(LDSo = 389->5,000 mg/kg/day). 

In the 2-generation rat reproduction study, offspring systemic toxicity was detected for males and females at 500 

ppm and reproductive toxicity was detected in males at 2500 ppm. The NOAEL for offspring systemic toxicity was 

150 and 500 pprn for males and females, respectively, and the NOAEL for reproduction was 500 ppm. In the rabbit 

developmental study, toxicity was observed at 75 mg/kg/day: the NOAEL was 25 mg/kg/day. 

Insects, Acute Contact and Oral 

A honey bee acute contact study using the TGAI is required for clothianidin because its foliar application treatment 

use will result in honey bee exposure. The acute contact LD50, using the honey bee. Apis mellifera, is an acute 

contact, single-dose laboratory study designed to estimate the quantity of toxicant required to cause 50% mortality in 

a test population of bees. The acute contact LD50 for clothianidin is 0.0439 yg a.i./bee and it is, therefore, classified 

as highly toxic to bees on a contact exposure basis < 2 ~(g a.i./bee, based on toxicity categories in Atkins 

(1 98 I)]. The guideline (14 1-1) is fulfilled (MRID No. 45422426). 

per fetus. 4 pprn conversion based on: 

1 mg/kg/day = 20 pprn in adult rats, I0 pprn in younger rats, 7 pprn in mice and 33 pprn in rabbits. (Nelson, 1975) 5 

pprn value determined from study. 

Toxicity Affected 

Endpoints 

Five acute oral toxicity studies are available for clothianidin and its metabolites: however, they are categorized as 

supplemental because the submission of honey bee acute oral toxicity studies is not a guideline requirement. The 

Office of Pesticide Programs (OPP) does not have a categorization scheme for acute oral toxicity to honey bees. 

However, based on the ICBB (1985) acute oral toxicity categorization scheme, clothianidin would be considered 

highly toxic to the honey bee by the oral route. With the exception of TZNG, the clothianidin metabolites TMG. 

MNG, and TZMU would be virtually non-toxic to honey bees. TZNG would be moderately toxic. 

MRID No. 

Author, 

Year 

Test 

Type 

Species % 

a.i. 

( Honey bee Acute Contact Toxicity - Clothianidin I 

Nontarget Insect Acute Contact and Oral Toxicity 

SpecieslStudy 

Duration 

Honey bee 

(Apis mellifera) 

48 hour 

LD50 

% ai (~g ailbee) 

highly toxic 

Honey bee Acute Oral Toxicity - Clothianidin 

96 

Honey bee 

(Apis mellifera) 

48 hour 

I Honey bee Acute Oral Toxicity - Clothianidin Metabolite - MNG I 

Toxicity 

Category 

0.0439 45422426 

Weyman, 1998 

Honey bee Acute Oral Toxicity - Clothianidin Metabolite -TMG 

Core 

96 

Honey bee 

(Apis mellifera) 

48 hour 

MRID No. 

Author, Year 

Honey bee 

Study 

Classification 

0.0037 

96 

not applicable 

2152 

99.2 >I53 not applicable 

45422426 

Weyman, 1998 

not applicable 

Supplemental 

45422428 

45422427 

Wilkins, 2000 

Supplemental 

Supplemental 
Insects, Mortality, Reproduction, and Feeding Capacity 

Two studies were submitted to show acute effects of corn (MRID 45422520) and summer rape (MRID 45422521) 

seeds treated with TI 435 FS600 (formulated product) on carabid beetles (Poecilus cupreus) under extended 

laboratory test conditions. The goal of these studies was to evaluate whether or not exposing carabid beetles to 

clothianidin treated corn or rape seeds increased mortality or decreased feeding rate compared to the controls. 

About one third of the adult carabid beetles exposed to the treated corn seeds at a seed treatment rate of 0.45 Ib ai/A 

showed abnormalities (undescribed signs of intoxication). Rape seed treated with clothianidin at an application rate 

of 0.095 Ib ai/A caused behavioral impacts (intoxication) to 63 % of adult carabid beetles in the treatment group. 

The feeding rate of beetles in the treatment group was significantly reduced. There was also a significant difference 

in mortality (13.3 %) of the treatment group compared to the control. These studies were scientifically sound and 

classified as Supplemental. 

Three studies (MRTD Nos. 45422524,45422522, & 45422523) were submitted to show effects of clothianidin on the 

life cycle of rove beetles (Aleochara bilineata) under extended laboratory conditions. The first study (MRTD No. 

45422524) was designed to evaluate the effects clothianidin would have on the beneficial ground beetles exposed to 

the pesticide in treated soil. Study endpoints were adult mortality and reproduction (total number of progeny 

produced). In this study, there were no significant differences observed between the control and clothianidin 

treatment groups for adult mortality. Reproductive performance (as indicated by decreased number of progeny) was 

affected in the two highest clothianidin treatment groups (200 and 250 pg a.i./kg soil). The goal of final two (2) 

rove beetle studies was to evaluate whether or not exposure of rove beetles to corn seeds (MRID No. 45422522) 

treated at a rate of 0.55 Ib ai/A and to rape seeds (MRID No. 45422523) treated at a rate of 0.095 lb ai/A (10 g 

a.i./kg TI 435 FS 600) would result in significantly increased mortality of parent beetles and whether or not the 

offspring production rate would be adversely affected. The beetles exposed to the treated corn seed experienced a 

significant increase in mortality (55%) but no significant reproductive difference when compared to the controls. 

The reproductive performance of the rove beetles was determined by counting the number of rove beetles which 

emerged from the host pupae between days 39 and 77 after treatment. Rove beetles exposed to the treated rape seed 

experienced an increase in mortality and a reduced parasitization capacity. The number of offspring that emerged 

(reproductive performance) in the rape seed treated test groups was not significantly lower than the control group. 

These studies were scientifically sound and classified as Supplemental. 

SpecieslStudy 

Duration 

(Apis mellifera) 

48 hour 

Insects, Residual Contact 

A honey bee toxicity of residues on foliage study is required on an end-use product for any pesticide intended for 

outdoor application when the proposed use pattern indicates that honey bees may be exposed to the pesticide and 

when the formulation contains one or more active ingredients having an acute contact honey bee LD50 which falls in 

the moderately toxic or highly toxic range. The purpose of this guideline study is to develop data on the residual 

toxicity to honey bees. Bee mortality determinations are made from bees exposed to treated foliage harvested at 

various time periods after treatment. Clothianidin, as indicated in the acute toxicity test (MIUD 45422426), is 

highly toxic to honey bees on a contact basis. Pesticides toxic to honey bees require bee precautionary labeling on 

Toxicity 

%ai Category 

Honey bee Acute Oral Toxicity - Clothianidin Metabolite - TZMU 

MRID No. 

Author, Year 

Wilkins, 2000 

LD50 

(pg ~ihe) 

Study 

Classification 

Honey bee 

(Apis mellifera) 

48 hour 

98.8 not applicable Supplemental 

Honey bee Acute Oral Toxicity - Clothianidin Metabolite - TZNC 

>I13 45422429 

Wilkins, 2000 

Honey bee 

(Apis tnellifera) 

48 hour 

98.6 3.95 not applicable 45422430 

Wilkins, 2000 

Supplemental 
all end-use formulations and registrants are required to submit data in accordance with Guideline 141-2 - Honey Bee 

Toxicity of Residues on Foliage. A scientifically-sound study was performed. 

Alfalfa foliage was sprayed with Clothianidin. as V-10066, at application rates of 30, 60, and YO g a.i.1acre. Honey 

bees, three replicateslrate, were exposed in the lab to the weathered foliage at varying times until the mortality of 

bees exposed to residues was lower than 25%. Sublethal observations were also made. The RT,, for V-10066 at 30, 

60, and 90 g a.i./acre were 11 1.68, 179.5 1, and 512.39 hours, respectively. EFED expects clothianidin's residue on 

treated foliage to remain toxic to bees for days after clothianidin is applied. Results indicate that clothianidin, a5 V10066, should not be applied to blooming pollen-shedding or nectar-producing parts of plants. 

Non-target Insects - Toxicity of Residues on Foliage I I 

MRID No. 

Honey Bee 30 11 1.68 45490702 Supplemental 

(Apis mellifera) (0.07 lb ai/A) (4.7 days) Mayer. 2000 

Honey Bee 60 179.51 45490702 Supplemental 

(Apis mellifera) (0.13 Ib ai/A) (7.5 days) Mayer, 2000 

Honey Bee 90 512.39 45490702 Supplemental 

(Apis mellifera) 0.21 (Ib ai/A) (2 1.3 days) Mayer, 2000 

' RTZ5 is the residual time required to reduce the activity of the test material and bring bee mortality down to 25% in cage test exposures to 

field-weathered spray deposits (Mayer and Johansen, 1990). The time period determined by this toxicity value is considered to be time that the 

test material is expected to remain toxic to bees in the field from the residual exposure of the test material on vegetation at an expressed rate of 

application (Ib ai/A). 

Insects, Field Testing for Pollinators 

Six honey bee field studies were undertaken in various locations (Sweden, United Kingdom, France, Canada, United 

States, and Germany) to determine the residue levels of clothianidin in various parts of summer rape plants grown 

from seeds treated at various application rates (8.62 Ib ai/1000 Ib seed or 0.038 Ib ai/acre; 10.4 Ib ai/1000 Ib seed or 

0.046 Ib ai/acre; 6 Ib ai/1000 Ib seed or 0.04 Ib ailacre; and 1 Ib ail100 Ib seed or 0.025 Ib ai/acre). Residue levels in 

the honey bees that foraged on the plants grown from the treated seeds were also determined. These studies were 

considered scientifically sound; however, they do not fulfill the requirements for a pollinator field test (OPPs 

Guideline 141-5) because the protocol was not approved by EPA. They are classified as Supplemental. An 

approved protocol would have required that the studies be conducted in the United States, longer duration of honey 

bee activity observations. and the use of replications in the treatments and controls for statistical analyses. Field 

exposure to the test substance and the bee observation period were too brief (< 30 daysj lo fully evaluate the impact 

the exposure levels of clothianidin would have had on the bee colonies tested. The complete life cycle for an 

individual worker bee during the time period tested would be approximately 63 days. 

These field studies evaluated the effects to small honey bee colonies hived on clothianidin rape seed treated and 

untreated (control) plots. Colonies were placed, on the treated and untreated plots during the rape bloom stage 

approximately two months after the rape crops were planted. Bees were monitored for short periods of time to 

determine if they were being adversely affected by the clothianidin exposure as a result of the systemic activity 

demonstrated by clothianidin. Residues of clothianidin in the nectar from rape flowers ranged from I .O to 7.2 pg 

ai/kg. Nectar sampled from beehives ranged from 0.9 to 3.7pg adkg and nectar sampled from forage bees honey 

stomachs contained 8.6 pg ai/kg clothianidin. Residues of clothianidin were also found in forage bees (1.4 pg 

ai/kg), rape flowers (3.3 - 4.1 pg ailkg). pollen taken from foraging bees (1.7 - 2.5 yg ai/kg), and pollen from 

beehives (1.6 - 3.0 pg ailkg). These residues were a result of the clothianidin seed treatments performed 

approximately 60 days prior to sampling the commodities. Two (2) studies (MFUD 45422436 & 45422437) also 

tested for the clothianidin metabolites, TZMU and TZNG, but residues of these metabolites were not found in the 

nectar and pollen samples analyzed. With the exception of one study (MRID 45422435): none of the studies 

reported mortality or adverse effects to the foraging activity of the bees. However, the residue levels in the nectar 

taken from the bees, 8.6 pg ailkg, exceeds the honey bee acute oral LDSo of 3.7pg ai/kg (MRID 45422426). One 

honey bee field study (MRID # 45422435) showed that mortality, pollen foraging activity, and honey yield were 
negatively affected by residues of clothianidin; however, residues were not quantified in this study. 

Non-target Insect Reld Studies 

MRID# Study Study 

Classification Location & 

Plant Date 

of Treated 

Seed 

Chemical Sample Commodity 

Application Date(s) Sampled 

Rate 

Clothianidin 

Residues Found 

(Pg 

4542243 1 Supplemental BorlundaSkelinge, 

Sweden 

Clothianidin lSt week of forage bees 

July '98 

8.6 g a.i./kg seed 

or 1" week of nectar in bces 

8.62 Ib ail1000 Ib July '98 

seed 

or 7/3/98 nectar from 

0.038 Ib ailacre and rape flowers 

7/2/98 

1.4 

8.6 

1.2 and 

1" week of rape flowers 

July '98 

45422432 Supplemental Elm Farm., 

United 

Kingdom 

Clothianidin 6122-6124198 rape flowers 3.3 

10.4 Ib ai/1000 Ib none detected 

seed 

or 

0.046 Ib ailacre 

6122-6124198 forage bees 

45422433 Supplemental Conches in 

Northern 

France 

Clothianidin 6115-6/18/98 pollen taken 

from forage 

10.4 Ib ail1000 Ib bees 

seed 

or 

0.046 Ih ailacre 

45422435 Supplemental Ontario, 

Canada 

Clothianidin 6126-7/20/00 pollen from 

bee hives 

3.0 

(6 1 days after 

6 Ib ai/1,000 Ib application) 

seed 

or 

0.04 Ib ai /A 

1.6 

(68 days after 

application) 

nectar from 

bee hives 

3.7 

(6 1 days after 

application) 

0.9 * 

(68 days after 

application) 

Minnesota, 

US 

51 16/00 

6128-7/28/00 pollen from 

bee hives 

2.3 

(50 days after 

application) 

2.8 

(57 days after 

application) 
Non-target Insect Field Studies 

MRID# Study Study Chemical 

ClassBcation Location & Application 

Plant Date Rate 

of Treated 

Seed 

45422436 Supplemental Monheim. Clothianidin 

Germany 

1056 g a.i.1100 

5/2/00 kg seed 

or 

I Ib ail100 Ib 

seed 

or 

0.025 Ib ai/A 

45422437 Supplemental Burscheid. Clothianidin 

Germany 

1056 g a.i.llOO 

4/28/00 kg seed 

or 

1 Ib ail100 Ib 

seed 

or 

0.025 lb ai/A 

Sample Commodity Clothianidin 

Dates) Sampled Residues Found 

(ag ailkg) 

nectar from 1.1 

bee hives (50 days after 

application) 

1.0 

(57 days after 

application 

7/6/00 nectar from 2.8 

and rape flowers and 

7/7/00 3.0 

6130100 nectar from 5.4 

and rape flowers and 

7/6/00 I .0 

combs pollen from 1.9 to 2.5 

sampled combslforage 

71 12/00; bees 

forage bees 

sampled on 

712 and 

71 18/00 

1 * <Level of Quantitication (LOQ) =10 pgkg and Level of Detection (LOD) = 0.3 pgkp I 

A seventh honey bee field study (MRID No. 45422440), reviewed under guideline 141-5, evaluated the effects of 

clothianidin treated pollen on the development of small honey bee colonies and on the behavior and mortality of 

honey bees. Three treatment levels and two controls were tested. One small beehive (about 500 bees) per treatment 

and control was tented on oat plots in cages and fed treated maize pollen. Pollen treated with clothianidin at a 

measured concentration level up to 19.7 pg ailkg produced no significant adverse effects to the parameters 

measured in this study based upon the visual inspection of the data. The parameters measured included mortality, 

foraging activity (including honey and pollen collection). comb production, honey storage behavior, population 

growth (including egg, larvae, pupae, and adult growth stages) and behavioral anomalies. Since there was only one 

replicate hive per treatment level, a statistical analysis could not be made of the data provided. MIUD No. 

45422440 was determined to be scientifically sound and classified as Supplemental. 

An eight honey bee field study (MRID 46907801/46907802) evaluated the long-term effects of clothianidin treated 

canola seed on whole hive parameters. This study was classified as scientifically sound and satisfied the guideline 

requirements for a field toxicity test with honeybees (OPP Gdln. No. 141-5; OPPTS 850.3040). Overall. there was 

no difference between colonies from clothianidin-treated and control fields. Although sporadic treatment or site 

differences were found on various dates, essentially no differences in worker or drone mortality, worker longevity, 

or brood development occurred during the study. Colonies in treated fields had similar weight gains and honey 
yields as those in control fields. Qualitative assessments, made the following spring by experienced bee researchers, 

confirmed that colonies from clothianidin-treated fields were as strong and healthy as those from control fields. It 

was concluded that honey bees that forage on clothianidin seed-treated canola will be exposed to clothianidin 

residues in pollen, nectar, and honey; however. exposure concentrations are below those required to elicit acute and 

sublethal effects. This study has recently been re-reviewed and found to contain deficiencies that limit its ability to 

determine the effects of clothianidin treated seed on honeybees. It is classified Supplemental due to cross 

contamination of the control hives that foraged in treated fields. 

Spider, Mortality and Feeding Capacity 

Two extended laboratory studies (MRID Nos. 45422518 & 454225 19) evaluated the effects of clothianidin treated 

seed on the wolf spider, Pardosa spp. (Araneae, Lycosidae). The goal of these studies was to evaluate whether or 

not exposing wolf spiders to treated corn and rape seeds increased mortality or decreased feeding rate compared to 

the controls. The seed treatment rate for the corn seeds was 48.8 g a.i./Unit (1 Unit = 50,000 seed) with 2 corn seeds 

per 1 170 cm2 test box equivalent to 0.15 Ib ai/A. The seed treatment rate for the rape seeds was 10 g a.i./kg TI 435 

FS 600 with 4 rape seeds per 178 cm2 test box equivalent to 0.06 lb ai/A. The studies' results indicated that the wolf 

spider mortality and feeding capacity in the clothianidin treatments were not significantly different from the 

controls. These studies were scientifically sound and classified as Supplemental. 

Earthworm, Acute and Chronic 

Five acutelchronic earthworm studies were reviewed for clothianidin and its metabolite/transformation products. 

These studies were conducted in compliance with the Organization for Economic Cooperation and Development 

(OECD) guidelines for testing of chemicals and were reviewed, by EFED, under EPA Ecological Effects Test 

Guidelines (U.S. EPA Ecological Effects Test Guidelines, April, 1996). EFED does not have a toxicity 

categorization for earthworms. The clothianidin earthworm LCSo (conc. in soil) was determined to be 15.5 mglkg 

(MRID No. 45422511) with the metabolite, MNG, and transformation product, TZNG, being less toxic to 

earthworms than the parent compound. EPA does not presently require reproductive or population toxicity testing 

with earthworms for pesticide registration; however, two studies indicate that clothianidin exhibits no apparent 

effect to earthworm reproduction at application rates equal to or greater than 0.054 Ib ai/A (MRID 45422525) or 

opulation densityhiomass at application rates equal to or greater than 0.08 Ib ai/A (MRID 45422526). I Earthworm Acute and Chronic Toxicity 

LC501 NOAEC/ 

EC50 LOAEC MRID# Study 

Endpoints Authornear Classification 

% (mgflrg in dry (m%kg in dry 

Spedes/Study ai sdl or Ib soil or Ib &A) 

Duration ai/A) 

Eisenia foetida 96 15.5 mgkg < 10.0 mglkg mortality 454225 1 1 Acceptable 

(nominal) (nominal) Weyman. 1998 

14 days 

Eisenia fetida 48 >0.054Ib 2 0.054 Ib ai/A1 no significant 45422525 Supplemental 

 ail^' (nominal) treatment- Meisner, 2000 

56 days (nominal) related effects 

on mortality, 

body weight, 

or # offspring1 

surviving adult 

Lumbricus 47.8 > 0.08 Ib ai/A2 2 0.08 Ib ai/~' no significant 45422526 Supplemental 

terrestris, (measured) (measured) treatment- Heimbach, 2000 

L.rubellus, related effect 

L. castaneus, on number and 

hiomass of 

Apporrectodea earthworms 

caliginosa, 
Earthworm Acute and Chronic Toxicity 

LC501 NOAEU 

ECSO LOAEC MRID# Study 

Endpoints Aut hor~Year Cldcation 

% (rng/kg in dry (mg/kg in dry 

SpeciedStudy ai soil or Ib soil or Ib ailA) 

Duration aVA) 

Allolohophora 

chlorotica 

1 year 

Clothianidin Metabolite - MNG 

Eisenia fetida 99.2 > 1,000 320 mglkg reduction in 454225 12 Acceptable 

mgkg (nominal) hody weights Noack, 2000 

14 days (nominal) 

Clothianidin Transformation Product - TZNG 

Eisenia fetida 99 982 mgkg 125 mgkg mortality 454225 13 Acceptable 

(nominal) (nominal) Noack, 2000 

14 days 63 mgkg reduction in 

(nominal) body weight 

' Equivalent to >500,000 clothianidin dressed corn seedsha 

'Equivalent to > 91.4 g a.i./ha 

Toxicity to Aquatic Organisms 

Freshwater Fish, Acute 

Two freshwater fish toxicity studies using the TGAI are required to establish the acute toxicity of clothianidin to 

fish. The preferred test species are rainbow trout (a coldwater fish) and bluegill sunfish (a warmwater fish). The 

acute studies that were submitted that tested the parent compound showed that clothianidin is practically non-toxic 

to freshwater fish (LCSo >105.8 -1 17 ppm). Studies on degradates (TMG, MNG, and TZNG) indicated a similar 

practically non-toxic profile (LCs0 >lo5 ppm). EFED will use the worst case value (LC5,) >105.8 ppm) for 

evaluating acute toxic exposure to freshwater Ash. The guideline (72-1) is fulfilled (MRID 45422407; MRID 

45422406). 

Freshwater Fish Acute Toxicity 

Species % ai %-hour Toxicity MRID No. Study 

LC50 (PP~) Category AuthorNear Classification 

(nominal) 

Bluegill sunfish 97.6 >I 17 Practically non- 45422407 Core 

(Lepomis macrochirus) toxic Palmer et al . 2000 

Rainbow trout 96 >105.8 Practically non- 45422406 Supplemental 

(Oncorhynchus mykiss) toxic Wilhelmy et al., 

1998 

Rainbow trout 95.1 >I 10 Practically non- 35422408 Supplemental 

(Oncorhynchus mykiss) TMG toxic Dorgerloh, 2000 

Rainbow trout 99.0 >I05 Practically non- 45422409 Supplemental 
Freshwater Fish Acute Toxicity 

Species % ai %-hour Toxicity MRID No. Study 

LC50 (ppm) Category Aut hor/Year Classiffcation 

(nominal) 

(Oncorhynchus mykiss) MNG toxic Dorgerloh, 2000 

Rainbow trout 99.0 >I16 Practically non- 454224 10 Supplemental 

(Oncorhynchus mykiss) TZNG toxic Dorgerloh, 2000 

Freshwater Fish, Chronic 

A freshwater fish early life-stage test using the TGAI is required for clothianidin because the end-use product may 

be transported to water from the intended use site, and the following conditions are met: (I) clothianidin is intended 

for use such that its presence in water is likely to be continuous or recurrent regardless of toxicity; (2) studies on 

aquatic invertebrates showed reproductive effects (daphnid 21-day LOAEC = 0.12 ppm) and (3) clothianidin is 

persistent in water (e.g., half-life of 744 days aerobic soil metabolism). 

A chronic early life stage study conducted on the fathead minnow showed that exposure of 20 ppm has the potential 

to affect length and dry weight of freshwater fish. The NOAEC of 9.7 ppm will be used for risk assessment 

purposes. The guideline (72-4) is satisfied (MRID #45422413). 

Freshwater Fish Early Life-Stage Toxicity Under Flow-Through Conditions 

Species % ai NOAEULOAEC Endpoints MRID No. Study 

(PP~) Affected Authornear Classification 

Fathead Minnow 97.6 9.7/20 Length and dry 454224 13 Supplemental 

(Pimephales promelas) weight Drottar et al., 2000 

Freshwater Invertebrate Acute Toxicity for Clothianidin 

Species %ai 48-hour ECSn Toxicity MRID No. Study 

(PP~) CatetZOrY AuthorIYear Classification 

Waterflea 99 

(Daphnia 

magna) 

>I19 Practically non- 45422338 Core 

toxic Palmer. 2000 

Midge 97.6 0.022* Very highly toxic 45422414 Supplemental 

(Chironomus Mattock, 2001 

riparius) 

Waterflea 99.0 TZNG 64 Slightly toxic 45422401 Core 

(Daphnia Hendel, 2000 

magna) 

Waterflea 99.0 MNG > 100.8 Practically non- 45422340 Core 

(Daphnia toxic Hendel, 2000 

magna) 

Waterflea 95.1 TMG >115.2 Practical1 y non- 45422339 Supplemental 

(Daphnia toxic Hendel, 2000 

magna) 

Midge LC5o = I 1 ppb (Chironomus Very highly >99 NOAEC 1. lppb toxic 468269-02 Supplemental 

riparius) Putt, A.E. 2006 
* The ECso value for exposure to Clothianidin TI-435 was the most sensitive; ECSo values for TZMU, MU, and TZNG were 

>I02 ppm, $33.6 ppm, and 0.386 ppm, respectively. 

Freshwater Invertebrates, Acute 

A freshwater aquatic invertebrate toxicity test using the TGAI is required to establish the toxicity of clothianidin to 

aquatic invertebrates. The preferred test species is Daphnia magna. The data that was submitted that tested the 

parent compound showed that clothianidin is practically non-toxic to Daphnia magna with an acute 48-hour ECS0 

value of >I 19 ppm, but that it is very highly toxic to Chironomus riparius with an acute 48-hour ECSo value of 0.022 

ppm. EFED will use the worst case value (ECSo= 0.022 ppm) for evaluating acute toxic exposure to freshwater 

invertebrates. Additional data (48-hour ECSo) on degradates (TZNG, MNG, and TMG) indicated a practically nontoxic to slightly toxic profile (ECso = 64.0 to >I 15.2 pprn). Another study (MRID 46826902) assessed the toxicity 

to the midge (Chironomus riparius) during a 10-Day sediment exposure. This study revealed an LCs0 of 1 I ppb and 

a NOAEC of 1.1 ppb based on pore water concentrations. The guideline requirements (72-2) for acute invertebrate 

toxicity are fulfilled (MRID 45422338; MIUD 45422414). 

Freshwater Invertebrate, Chronic 

A freshwater aquatic invertebrate life-cycle test using the TGAI is required for clothianidin because the end-use 

product may be transported to water from the intended use site, and the following conditions are met: (1) the 

presence of clothianidin in water is likely to be continuous or recurrent and (2) aquatic acute LCso or ECsO values are 

less than 1 pprn (i.e., 0.022 ppm), and (3) physicochemical properties indicate that clothianidin is persistent in the 

aquatic environment (e.g., half-life of 744 days aerobic soil metabolism). 

The preferred test is a 21-day life cycle on Daphnia magna. The data that were submitted show that clothianidin has 

the potential for chronic toxicity to daphnids and possibly other freshwater invertebrates. Exposure to 0.12 pprn can 

result in reproductive effects, including the reduced number of juveniles produced per adult. The NOAEC of 0.042 

pprn will be used in assessing risk. The guideline (72-4) is fulfilled (MIUD 454224 12). 

Freshwater Aquatic Invertebrate Chronic Toxicity 

sped& kai 21-day MATC' Endpoints MRID No. Study 

Static Renewal NOAEXXOAEC (PPm) Affected Authornear Classification 

(PP~) 

Waterflea 96 0.032/0.12 ND Reproduction 454224 12 Supplemental 

(Daphnia Noack et al., 

magna) Static 1998 

Renewal 

Freshwater Field Studies 

No data submitted. 

Estuarine and Marine Fish, Acute 

The preferred test species is sheepshead minnow. The data submitted showed that the LCs0 = 93.6 ppm; therefore, 

clothianidin is categorized as slightly toxic to estuarinelmarine fish on an acute basis. The guideline (72-3) is 

fulfilled (MRID 4542241 1). 

Estuarine/Marine Fish Acute Toxicity 

96-hour Toxicity MRID No. Study 

Species/Static % ai LC50 (PP~) Category Authornear Classification 

(nominal) 

Sheepshead minnow 97.6 >93.6 Slightly toxic 4542241 1 Supplemental 
EstuarinelMarine Fish Acute Toxicity 

%-hour Toxicity MRID No. Study 

Spedeslstatic % ai LC50 (PP~) Category AuthorrYear Classification 

(nominal) 

(Cyprinodon variegatus) Scheerbaum, 

1999 

Estuarine and Marine Fish, Chronic 

No data submitted. 

Estuarine and Marine Invertebrates, Acute 

Acute toxicity testing with estuarinelrnarine invertebrates using the TGAI is required for clothianidin because the 

end-use product is expected to reach this environment due to its potential use on crops with significant acreage in 

coastal counties. The preferred test species are mysid shrimp and eastern oyster. The data showed that clothianidin 

significantly reduced survival of mysid shrimp at 0.051 ppm, categorizing the compound as very highly toxic. 

Clothianidin was categorized as practically non-toxic to Eastern oyster because adverse effects did not occur for this 

species up to concentrations of 129.1 ppm. EFED will use the worst case value, LC50 = 0.05 1 ppm, for evaluating 

acute toxic exposure to estuarinelmarine invertebrates. A 10-day whole sediment toxicity test with Leptocheirus 

plurnulosus using spiked sediment was submitted to the Agency. This study is classified as supplemental, and 

shows that clothianidin is very highly toxic to benthic estuarinelmarine invertebrates with an LC50 of 20.4 pg/L 

and a NOAEC of 1 1.6 pg/L based on pore water concentrations. The data requirements (72-3b) are fulfilled (MRID 

45422404; MRID 45422403). 

EstuarineMarine Invertebrate Acute Toxicity 

Species/Static or % ai. %-hour Toxicity Category MRID No. Study 

Flow-through LC9 (PP~) Author/Year ClassiP~cation 

Eastern oyster 97.6 ECx,> I 29.1 Practically non- 45422404 Core 

(Crassostrea virginica) toxic Scheerbaum, 1999 

Mysid 97.6 LCSo=0.05 1 Very highly toxic 45422403 Core 

(Americarnysis bahia) Drottar et a]., 2000 

LC50 = 20.4 

Leptocheirus plurnulosus 99.4 ppb Very highly toxic 47 1994-0 1 Supplemental 

NOAEC = Thomas et al., 2007 

11.6 ppb 

Estuarine and Marine Invertebrate, Chronic 

An estuarinelrnarine invertebrate life-cycle toxicity test using the TGAI is required for clothianidin because the enduse product is expected to transport to an estuarinelrnarine environment from the intended use site, and the following 

conditions are met: (I) the pesticide is intended for use such that its presence in water is likely to be continuous or 

recurrent regardless of toxicity, (2) an aquatic acute LCSo or ECso is less than 1 ppm (e.g., mysid LC50 = 0.05 1 ppm), 

and (3) studies of other organisms indicate that the reproductive physiology of fish and/or invertebrates may be 

affected, physicochemical properties indicate cumulative effects, or the pesticide is persistent in water (e.g., half-life 

of 744 days aerobic soil metabolism). 

The preferred test species is mysid shrimp. The data submitted indicate that clothianidin reduced the number of 

young per reproductive day at 9.7 ppb. The NOAEC of 5.1 ppb will be used in assessing risk. The guidelines (72-4c) 

have been fulfilled (MRID 45422405). 

EstuarinelMarine Invertebrate Lie-Cycle Toxicity 

spedes % ai 39-day Endpoints MRID No. Study 
Estuarine/Marine Invertebrate Lifecycle Toxicity 

NOAECnOAEC Affected Authornear Classification 

(PP~) 

Mysid 97.6 5.119.7 Reproduction 45422405 Core 

(Mysidopis bahia) Drottar et al.. 2000 

Estuarine and Marine Field Studies 

No data submitted. 

Aquatic Plants 

Several aquatic plant toxicity studies using the TGAI are required to establish the toxicity of clothianidin to nontarget aquatic plants. The recommendation is for testing on five species: freshwater green alga (Selenastrum 

capricornutum), duckweed (Lemna gibba), marine diatom (Skeletonema costatum), blue-green algae (Anabaena 

flos-aquae), and a freshwater diatom. Studies submitted for two of the five recommended species showed that 

exposure to clothianidin at levels greater than or equal to 3.5 ppm reduced biomass of aquatic non-vascular plants 

and increased the incidence of necrotic fronds in aquatic vascular plants. Studies on degradates (TMG, MNG and 

TZNG) showed reductions in green algal cell density when exposed to levels >I .46 ppm. The ECSo of 64 ppm will 

be used for evaluating acute toxic exposure to non-target aquatic plants. The guideline requirements (1 22-2 and 

123-2) are fulfilled (MRID 45422503; MRID 45422504) for two of the five required species. EFED needs 3 more 

Core clothianidin studies for the nonvascular surrogate species, marine diatom (Skeletonema costatum), blue-green 

algae (Anabaenujlosaquae), and a freshwater diatom. 

Non-target Aquatic Plant Toxicity 

I 1 

Species 

[Study Type1 

Green Algae 6413.5 

(Selenastrum 

capricornutum) 

Duckweed 

(Lernna gibba) 

[Tier 21 

Green Algae 95.1 

(Selenastrum TMG 

capricomutum) 

[Tier 21 

% ai. 

97.6 

EC-AEC 

(PP~) 

Endpoints MRID No. 

Author, Year 

Green Algae 

(Selenastrum 

capricornutum) 

[Tier 11 

Biomass 45422504 

Sutherland et al., 

2000 

Necrotic fronds 

99.0 

MNG 

Cell density 45422505 

Dorgerloh. 2000 

45422503 

Palmer el al., 2000 

>100.6/100.6 

Study 

Classification 

None 

Core 

45422506 

Dorgerloh. 2000 

Core 

Core 

Core 

Core 

Terrestrial Plants 

Terrestrial Tier I1 studies are required for all low dose pesticides (those with the maximum use rate of 0.5 Ibs a.i./A 

or less) and for any pesticide showing a negative response equal to or greater than 25% in Tier I studies. Two Tier I 

terrestrial plant toxicity studies were conducted to establish the toxicity of clothianidin to non-target terrestrial 

plants. The recommendations for seedling emergence and vegetative vigor studies are for testing of (1) six species 

Green Algae 

(Selenastmm 

capricomutum) 

[Tier 11 

Cell density 45422507 

Dorgerloh, 2000 

99.0 

TZNG 

>103/<103 
of at least four dicotyledonous families, one species of which is soybean (Glycine max) and the second of which is a 

root crop, and (2) four species of at least two monocotyledonous families, one of which is corn (Zea mays). The 

studies that were submitted tested formulated products of clothianidin (49.3% TI-435 50% WDG). The results of 

these studies showed that exposure elicited no effect (that is, 2 25%) on non-target terrestrial plants, so Tier I1 tests 

were not necessary. The guidelines (122- la and 122-1 b) are fulfilled (MRID 45422501 ; MRID 45422502). 

Non-target Terrestrial Plant Toxicity 

I 

- - - 

m: Soybean (Glycine max), 

Pinto bean (Phaseolus vulgaris), 

Radish (Raphanus sativus), 

Cabbage (Brassica oleracea), 

Lettuce (Lactuca sativa), Tomato 

(Lycopersicon esculentum) 

49.3 

TI-435 50% 

WDG 

Monocots: Corn (Zea mays). 

Wheat (Triticum aesti\ium). 

Ryegrass (Lolium perenne), 

Onion (Allium cepa) 

[Tier I Seedling Emergence] 

Dicots: Soybean (Glycine max), 

Pinto bean (Phaseolus vulgaris), 

Radish (Raphanus sativus), 

Cabbage (Brassica oleracea), 

Lettuce (Lactuca sativa), Tomato 

(Lycopersicon esculentum) 

Monocots: Corn (Zea mays), 

Wheat (Triticum aestivum). 

Ryegrass (Lolium perenne), 

Onion (Allium cepa) 

Application 

Rate 

(ib &A) 

0.2 

Endpoints MIUD No. 

APfected Author, Year 

- - 

45422501 

effect on 2000 

seedling 

emergence 

45422502 

sic / Brignolzt al., 

reduction in 

I Study 

I Classification 

Core 

Core 
Appendix C. The Risk Quotient Method and Levels of Concern 

The Risk Quotient Method is the means by which the Environmental Fate and Effects Division (EFED) 

integrates the results of exposure and ecotoxicity data. In this method, both acute and chronic risk 

quotients (RQs) are calculated by dividing exposure estimates by the most sensitive ecotoxicity values or 

toxicity endpoints derived from the studies. Calculated RQs are then compared to OPP's levels of concern 

(LOCs). The LOCs are the criteria used by OPP to indicate potential risk to non-target organisms and the 

need to consider regulatory action. EFED has defined LOCs for acute risk, potential restricted use, and for 

endangered species. Risk presumptions, along with the corresponding RQs and LOCs are summarized in 

the table below. 

Birds 

Acute Risk EEC/LCTO or LD5dsqft or LDSrjday 0.5 

Acute Restricted Use EEC/LC50 or LD5dsqft or LDTdday (or LDTo < 50 0.2 

mg/kg) 

Acute Endangered Species EEC/I,CSo or LDSo/sqft or LD5dday 0.1 

Chronic Risk EEC/NOAEC 1 

Mammals 

Acute Risk EEC/LCSo or LD,dsqft or LD5rjday 0.5 

Acute Restricted Use EEC/LC50 or LD50/sqft or LDSdday (or LDso < 50 0.2 

mg/kg) 

Acute Endangered Species EEC/LCSo or LDSdsqft or LD5u/day 0.1 

Chronic Risk EEC/NOAEC I 

Aquatic Animals 

Acute Risk EEC/LCSo or ECso 0.5 

Acute Restricted Use EEC/LCSo or ECSO 0.1 

Acute Endangered Species EEC/LCSO or ECS~ 0.05 

Chronic Risk EEC/NOAEC 1 

Terrestrial and Semi-Aquatic Plants 

Acute Risk EEC/EC25 1 

Acute Endangered Species EEC/EC05 or NOAEC I 

Aquatic Plants 

0 

Acute Risk EEC/ECSO 

1 
Appendix D: Equilibrium Partitioning and Concentration in the 

Sediment 

In general, pyrethroid insecticides are lipophilic compounds that can adsorb readily to 

particulate and sediment, thus possibly limiting its exposure to aquatic life in the water 

column but increasing toxic exposure in the benthos. Sediment can act as a reservoir for 

lipophilic persistent compounds. The sediment and particulate likely adsorb a high 

percentage of pyrethrin, as indicated by its high KO,. Therefore, coupled with cypermethrin's 

expected persistence in anaerobic environments, sediment bound cypermethrin could present 

a toxicity risk for benthic aquatic life and aquatic ecosystems in general. Exposure to this 

sediment can result in a direct impact to aquatic life through respiration, ingestion, dermal 

contact, as well as indirect impact through alterations of the food chain. Pesticide compounds 

that bind readily to particulate and organic carbon in the water column can eventually settle 

onto the benthos. This increase in particulatebound pesticides can result in an accumulation 

of compounds in or on the sediment that may have the potential for toxic impact to benthic 

and epibenthic aquatic organisms (e-g., early life stage of many invertebrates and fish, as 

well as crabs and shrimp). However, evaluating the risk to aquatic life fiom this exposure 

becomes problematic given the lack of adequate sediment toxicity and exposure data. 

Therefore, in order to assess this potential for pesticide risk to aquatic benthic systems, 

EFED has adopted the method used by the USEPA Office of Water (OW) that relies on 

equilibrium partitioning (EqP) of chemicals. Th EqP theory is based on the hydrophobicity 

and concentrations of the chemical normalized to organic carbon (OC) in sediment (De Toro 

et al., 1991) and holds that a nonionic chemical in sediment partitions between sediment 

organic carbon, interstitial (pore) water and benthic organisms. At equilibrium, if the 

concentration in any phase is known, then the concentration in the other phases can be 

predicted. A key component to this theory is the chemicals organic carbon coefficient (Koc), 

which is constant for every chemical and represents the ratio of the chemical concentration in 

water to the concentration in organic carbon. The document, " Technical Basis for the 

Derivation of Equilibrium Partitioning Sediment Guidelines (ESG) for the Protection of 

Benthic Organisms: Nonionic Organics" (USEPA, 2000a), demonstrates that biological 

responses of benthic organisms to nonionic organic chemicals in sediments are different 

when the sediment concentrations are expressed on a dry weight basis, but similar when 

expressed on a ug chemicallg organic carbon basis (uglg,,). Similar responses were also 

observed across sediments when interstitial water concentrations were used to normalize 

biological availability. The Technical Basis Document further demonstrates that if the toxic 

effect concentration in water is known (e.g., LC,,), the effect concentration in sediment on a 

uglg,, basis can be predicted by multiplying the effect concentration in water by the chemical 

Koc. 

(LC50 ug/L x Koc Llkgoc x 1 kgoc/1000goc = LC50 pg/goc) 

Since EFED uses a deterministic method for its screening level risk assessment, the 

calculation of risk quotient values (RQ) is important for assessing possible risk. The RQ 
values are calculated by taking the ratio of the estimated exposure concentrations (EEC) to 

the toxicity effect value (e.g., LC,,, NOAEC). The EEC values are model generated (e.g., 

PRZW EXAMS) and reflect peer evaluated and approved scenarios for assessing pesticide 

exposure to an aquatic environment. However, the PRZNII EXAMS output produces water 

column EEC values, as well as sediment and porewater EEC values. Therefore, in order to 

assess possible toxic pesticide exposure to aquatic organisms from sediments, EFED uses the 

PRZMI EXAMS model, which incorporates the principles of the equilibrium partitioning 

theory, in order to generate EECs from sediment and pore water. By relying on sediment 

andlor porewater output values, EFED uses two methods to calculate RQ values for 

sediments by using porewater exposure values and bulk sediment values. 

Risk calculations that rely on pore water concentrations can be calculated by dividing the 

PRZMI EXAMS output value for pore water by the dissolved concentrations in the water 

column that cause toxicity in bioassays (e.g., LC50). EEC pore water ug/L 1 LC50 ugL 

If sediment effects data are available (LC50 uglkg,), RQs can be produced by using the 

PRZMI EXAMS sediment output value for sediment. 

EEC sediment uglugoc 1 LC50 ugkgoc 

The following three principle observations underlie the equilibrium partitioning (EqP) 

approach: 

The concentrations of nonionic organic chemicals in sediments (expressed on an 

organic carbon basis) and in interstitial waters correlate with observed biological 

effects on sediment-dwelling organisms across a range of sediments. 

Partitioning models can relate sediment concentrations for nonionic organic 

chemicals on an organic carbon basis to freely-dissolved concentrations in interstitial 

water. 

The distribution of sensitivities of benthic organisms is similar to that of water 

column species. 
Appendix E: Aquatic Exposure Model Input and Output 

MASTER INPUT COMPILATION (Project File) for EXPRESS PRZM-EXAMS Modeling 

Interface 

(includes scenarios for several other crops that were run at the same time). CAM = 5 for cotton 

and mustard seed treatment simulations. 

Master Project File Created: 2010-10-07 at 10:56:07 

Express v. 1.03.02 (2007-07-20) 

Parent Compound: Clothianidin 

Scenario Group File: 1 1STDEFED.GRP 

Scenario Type: 3 

PRZM Crop Selector: 

00000000000000000000000000000000000000010000110000 

PRZM Crop Selector: 

00000001000110000110000001110010010100001000011000 

PRZM Crop Selector: 

00000001010100000000000000000100000000000000000000 

PRZM Crop Selector: 

00100010111000001000000000000000000000000000000000 

Chemical Input Data Controls: 1 1 0 1 0 

Express Operational Mode: OPP 

Chemical Name(s) : Clothianidin I 

Molecular Weight: 249.7 

Plant Uptake Factor: 0.000 

Partition Coefficient Method: 1 

Partition Coefficient Value: 160.0 160.0 

Vapor Pressure: 0.2900E-12 

Solubility : 3270. 

Soil Degradation Half-Life: 745.0 

% Degradate formed: 0.000 0.000 

Foliar Half-Life: 0.000 

Foliar Washoff Coefficient: 0.5000 

Air Diffusion Coefficient: 4300. 

Enthalpy of Vaporization: 20.00 

Application DataSets Number: 27 

Application Parameters: 1 2 1 2 1 0 0 

Days Relative/Absolute 0 

Month 0 

CAM 1 

Depi (cm) : 4.000 

Rate : 0.2000 

Drift Farm Pond % : 1.000 

Drift Index Reservoir % : 6.400 

Efficiency % : 99.00 

Application Parameters: 1 4 1 2 1 0 0 

Days Relative/Absolute 0 

Month 0 

CAM 5 

Depi (cm) : 1.270 

Rate : 0.2800E-01 

Drift Farm Pond % : 0.000 
Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir 8 : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond B : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 
Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

~epi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 
Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir 8 : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency 8 : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond 8 : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 
Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Product chem./hydr. status: 
Aerobic Dissipation (days) : 

Q10 Base Temperature : 

Q10 Lirnnetic 

Anaerobic Dissipation(days) : 

Q10 Base temperature: 

Q10 Benthic 

Photolysis Half-Life (days) : 

Number of Hydrolysis Obs.: 

Hydrolysis Temperatures: 

Hydrolysis C1: 0.000E+00 0.( 

pH Hydrol. C1: 5.00 

Melting Point: 

MASTER INPUT COMPILATION (Project File) for EXPRESS PRZM-EXAMS Modeling 

Interface (includes scenarios for several other crops that were run at the same time). CAM = 8 

for cotton and mustard seed treatment simulations. 

Master Project File Created: 2010-10-07 at 12:27:57 

Express v. 1.03.02 (2007-07-20) 

Parent Compound: Clothianidin 

Scenario Group File: 1 1STDEFED.GRP 

Scenario Type: 3 

PRZM Crop Selector: 

00000000000000000000000000000000000000010000110000 

PRZM Crop Selector: 

00000001000110000110000001110010010100001000011000 

PRZM Crop Selector: 

00000001010100000000000000000100000000000000000000 

PRZM Crop Selector: 

OOlOOOlOlllOOoOOlOOOOOOOOOOOOOOOOOOOOOOOoooooooooo 

Chemical Input Data Controls: 1 1 0 1 0 

Express Operational Mode: OPP 

Chemical Name(s) : Clothianidin I 

Molecular Weight: 249.7 

Plant Uptake Factor: 0.000 

Partition Coefficient Method: 1 1 

Partition Coefficient Value: 160.0 160.0 

Vapor Pressure: 0.2900E-12 

Solubility : 3270. 

Soil Degradation Half-Life: 745.0 

8 Degradate formed: 0.000 0.000 0.000 

Foliar ~alf-Life: 0.000 

Foliar Washoff Coefficient: 0.5000 

Air Diffusion Coefficient: 4300. 

Enthalpy of Vaporization: 20.00 

Application DataSets Number: 27 

Application Parameters: 1 2 1 2 1 0 0 87.00 0 

Days Relative/Absolute 0 

Month 0 

CAM 1 

Depi (cm) : 4.000 

Rate : 0.2000 

Drift Farm Pond % : 1.000 

Drift Index Reservoir 8 : 6.400 

Efficiency 8 : 99.00 
Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 
CAM 

Depi (crn) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond 8 : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond 8 : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir 8 : 

Efficiency 8 : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir 8 : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 
Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 
Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond 8 : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

~epi (cm) 

Rate 

Drift Farm Pond 8 : 

Drift Index Reservoir % : 

Efficiency 8 : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 

CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir % : 

Efficiency % : 

Application Parameters: 

Days Relative/Absolute 

Month 
CAM 

Depi (cm) 

Rate 

Drift Farm Pond % : 

Drift Index Reservoir 8 : 

Efficiency % : 

Product chem./hydr. status: 

Aerobic Dissipation (days) : 

Q10 Base Temperature : 

Q10 Limnetic 

Anaerobic Dissipation(days) : 

Q10 Base temperature: 

Q10 Benthic 

Photolysis Half-Life (days) : 

Number of Hydrolysis Obs.: 

Hydrolysis Temperatures: 

Hydrolysis C1: 0.000E+00 0. 

pH Hydrol. C1: 5.00 

Melting Point: 

Sample PRZM Input Files 

MISSISSIPPI COTTON SCENARIO, CAM 5 

FILE NAME = MS 1Ctt-P.INP 

*** Record 1: (A78), TITLE - label for simulation title 

Express v. 1.03.02 (2007-07-20) 

**"S Cotton; 8/13/2001 Title of input file Existing *** 

*** Record 2: (A78), HTITLE - Hydrology Information Title 

"Yazoo County; MLRA 134; Metfile: W03940.dvf (old: Met13 

*** 

*** Record 3: (2F8.0,18,F8.0,218,514) PFAC,SFAC,IPEIND,ANETD,INICRP,ISCOND 

***PFAC SFAC IPEIND ANETD INICRP ISCOND (WDM data sets not used) 

7.50E-013.60E-01 02.50E+01 1 1 

* * * 

*** Record 6: (18) ERFLAG: Flag to calculate erosion 

4 

* * * 

*** Record 7: (4F8.0,8X,I8,2F8.0) USLEK,USLELS,USLEP,AFIELD,IREG,SLP,HL 

***USLEKUSLELS USLEP AFIELD IREG SLP HL 

4.90E-011.34E+005.00E-011.00E+Ol 3 6.00 356.80 

*** 

*** Record 8: (18) NDC - Number of different crops simulated; FLITNUM 

10 

* * * 

*** Record 9 for Crop 1: (18,3F8.0,18,3(1X,I3),2F8.0) 

ICNCN,CINTCP,AMXDR,COVMAX,ICNAH,(3)CN,WFMAX,HTMAX 

***ICNCNCINTCP AMXDR COVMAX ICNAH CN1 CN2 CN3WFMAX HTMAX 

12.00E-016.50E+011.0OE+02 3 89 86 870.00E+001.22E+02 

* * * 

*** Record 9A (218): CROPN0,NUSLEC - Crop, Number of USLE C (cover management) factors 

1 2 6 

*** Record 9B: (16!12,12,1X) GDUSLEC,GMUSLEC for each USLEC 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 
0105 1605 0106 1606 0107 1607 0108 1608 0109 1609 2209 0110 1610 0111 1611 0112 

*** Record 9C: (16(F4.0,1X)) - USLEC (USLE Cover management factors) 

.718 .699 .620 .496 .354 .303 .305 .289 .343 .359 .359 .223 .327 .376 .425 .465 

*** Record 9D: (16(F4.0,1X)) - MNGN - Manning's N for each USLEC 

.014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .OX4 .014 .014 

*** Record 9E: (16(14,1X)) - CN(I1) for each USLEC 

86 86 86 86 86 86 86 86 86 86 86 89 89 89 89 89 

*** 

*** Continuation of Records 9B,9C,9D,9E for USLEC 17-26 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

1612 0101 1601 0102 1602 0103 1603 0104 1604 2504 

.494 .500 .517 .532 .549 .567 .591 .617 .667 .705 

.014 .014 .014 .014 .014 .014 .014 .014 ,014 .014 

89 89 89 89 89 89 89 89 89 89 

* * * 

*** Record 10: (18) NCPDS - number of cropping periods 

3 0 

* * * 

*** Record(s) 11: (2X,312,2X,312,3X,312,18) - dates of crop EMergence, MAturation, and 

HArves t 

*** EMD,EMM,IYREM,MAD,MAM,IYRMAT,HAD,HAM,IYRHAR,INCROP 

***EMerge MAture HArvest 

***DMMYY DDMMYY DDMMYY Crop NO. 

010561 070961 220961 1 

010562 070962 220962 1 

010563 070963 220963 1 

010564 070964 220964 1 

010565 070965 220965 1 

010566 070966 220966 1 

010567 070967 220967 1 

010568 070968 220968 1 

010569 070969 220969 1 

010570 070970 220970 1 

010571 070971 220971 1 

010572 070972 220972 1 

010573 070973 220973 1 

010574 070974 220974 1 

010575 070975 220975 1 

010576 070976 220976 1 

010577 070977 220977 1 

010578 070978 220978 1 

010579 070979 220979 1 

010580 070980 220980 1 

010581 070981 220981 1 

010582 070982 220982 1 

010583 070983 220983 1 

010584 070984 220984 1 

010585 070985 220985 1 

010586 070986 220986 1 

010587 070987 220987 1 

010588 070988 220988 1 

010589 070989 220989 1 

010590 070990 220990 1 

*** 

*** Record 12: (A78) PTITLE - Label for pesticide 

Chemical Input Data: 

* * * 

*** Record 13: (418) NAPS,NCHEM,FRMFLG,DK2FLG 

*** NAPS NCHEM FRMFLG DK2FLG 

3 0 1 0 0 * * * 

*** Record 15: (3A20) Name(s) of pesticides for output titles 

Clothianidin 
* * * 

*** Record(s) 16: (2X,312,13,3(12,F5.0,F6.O,F5.O,F5.0)) - application data 

*** including the application date (APD,APM,IAPYR), WINDAY, and 

(1) (CAM,DEPI,TAPP,APPEFF,DRFT) 

***DMMYYWinCmDepi Tapp Eff Drft CmDepi Tapp Eff Drft CmDepi Tapp Eff Drft 

240461 0 5 1.270.07091.000.0000 

240462 0 5 1.270.07091.000.0000 

240463 0 5 1.270.07091.000.0000 

240464 0 5 1.270.07091.000.0000 

240465 0 5 1.270.07091.000.0000 

240466 0 5 1.270.07091.000.0000 

240467 0 5 1.270.07091.000.0000 

240468 0 5 1.270.07091.000.0000 

240469 0 5 1.270.07091.000.0000 

240470 0 5 1.270.07091.000.0000 

240471 0 5 1.270.07091.000.0000 

240472 0 5 1.270.07091.000.0000 

240473 0 5 1.270.07091.000.0000 

240474 0 5 1.270.07091.000.0000 

240475 0 5 1.270.07091.000.0000 

240476 0 5 1.270.07091.000.0000 

240477 0 5 1.270.07091.000.0000 

240478 0 5 1.270.07091.000.0000 

240479 0 5 1.270.07091.000.0000 

240480 0 5 1.270.07091.000.0000 

240481 0 5 1.270.07091.000.0000 

240482 0 5 1.270.07091.000.0000 

240483 0 5 1.270.07091.000.0000 

240484 0 5 1.270.07091.000.0000 

240485 0 5 1.270.07091.000.0000 

240486 0 5 1.270.07091.000.0000 

240487 0 5 1.270.07091.000.0000 

240488 0 5 1.270.07091.000.0000 

240489 0 5 1.270.07091.000.0000 

240490 0 5 1.270.07091.000.0000 

* * * 

*** Record 17: (includes data for each chemical) (F8.0,3(18,F8.0)) FILTRA, 

(1) (IPSCND,UPTKF) 

***FILT IPSCNDl UPTKFl IPSCND2 UPTKF2 IPSCND3 UPTKF3 

0.00E+00 10.00E+00 

* * * 

*** Record 19: (A78) STITLE - label for soil properties 

Loring Silt Loam; HYDG: C Brief description of soil pr * * * 

*** Record 20: (F8.0,8X8914) 

CORED,BDFLAG,THFLAG,KDFLAG,HSWZT,MOC,IRFLAG,ITFLAG,IDFLAG,BIOFLG 

***CORED (cm) BD TH KD HS MOC IR IT ID BIO 

1.55E+02 000000000 

*** 

*** Record 26: (9F8.0) (l)DAIR, (l)HENRYK, (1)ENPY 

4.30E+031.19E-152.OOE+01 

* * * 

*** Record 33: (18) NHORIZ (total number of soil horizons) 

6 

* * * 

*** Record 34 for Horizon 1: (I8,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

11.30E+011.40E+003.85E-010.00E+OOO.OOE+O00.00E+00 

* * * 

*** Record 36 for Horizon 1: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 1: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

1.00E-013.85E-011.51E-011.28E+002.05E+00 

87 
* * * 

*** Record 34 for Horizon 2: (I8,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

22.30E+011.40E+003.7OE-010.00E+OOO.OOE+O00.00E+00 

*** 

*** Record 36 for Horizon 2: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 2: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

1.00E+003.70E-011.46E-014.90E-017.84E-01 

*** 

*** Record 34 for Horizon 3: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

33.30E+011.40E+003.7OE-010.00E+OOO.OOE+O00.00E+00 

* * * 

*** Record 36 for Horizon 3: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 3: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

3.00E+003.70E-011.46E-011.60E-012.56E-01 

* * * 

*** Record 34 for Horizon 4: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

43.00E+011.45E+003.4OE-010.00E+OOO.OOE+O00.00E+00 

* * * 

*** Record 36 for Horizon 4: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 4: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

5.00E+003.4OE-O11.25E-011.20E-011.92E-O1 

* * * 

*** Record 34 for Horizon 5: (I8,8F8.0) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

52.30E+011.49E+003.35E-010.00E+OOO.OOE+O00.00E+00 

* * * 

*** Record 36 for Horizon 5: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 5: (8X.7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

1.00E+003.35E-O11.37E-017.00E-O21.12E-O1 

*** 

*** Record 34 for Horizon 6: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD,(I)DISP,ADL 

63.30E+011.51E+003.43E-010.00E+OOO.OOE+000.00E+00 

*** 

*** Record 36 for Horizon 6: (8X, 9F8.0) (l)DWRATE, (l)DSRATE, (1)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 6: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

3.00E+003.43E-011.47E-016.00E-029.60E-02 

* * * 

*** Record 40: (218) ILP; CFLAG (blank if ILP=O) 

0 

*** 

*** Record 42: (3 (4X,A4,4X,A4, I8), 14) 

ITEMl,STEP1,LFREQl,ITEM2,STEP2,LFREQ2,ITEM3,STEP3,LFREQ3,E~FLG 

WATR YEAR 10 PEST YEAR 10 CONC YEAR 

* * * 

*** Record 43: (18) EXMENV 

9 9 

*** 

*** Record 44 for Chemical 1: EXMCHM,CAS Number,NPROC,RFORM,YIELD 

1 CASSNO: 999 1 10.00E+00 

* * * 

*** Record 45: NPLOTS (number of time series variables,STEP4 

0 YEAR 

* * * 

*** Records 46: Plotting variables 
NORTH CAROLINA COTTON SCENARIO, CAM 5 

FILE NAME = NC 1Ctt-P.INP 

*** Record 1: (A78), TITLE - label for simulation title 

Express v. 1.03.02 (2007-07-20) 

*** NCcottonTitle of input file Develope *** 

*** Record 2: (A78), HTITLE - Hydrology Information Title 

"MLRA 133A; Metfile: W13722.dvf (old: Metl33A.met)," Sh 

* * * 

*** Record 3: (2F8.0,18,F8.0,218,514) PFAC,SFAC,IPEIND,ANETD,INICRP,ISCOND 

***PFAC SFAC IPEIND ANETD INICRP ISCOND (WDM data sets not used) 

7.50E-013.60E-01 01.75E+01 1 1 

*** 

*** Record 6: (18) ERFLAG: Flag to calculate erosion 

4 

*** Record 7: (4F8.0,8X,I8,2F8.0) USLEK,USLELS,USLEP,AFIELD,IREG,SLP,HL 

***USLEKUSLELS USLEP AFIELD IREG SLP HL 

3.40E-011.34E+001.00E+001.00E+01 3 6.00 356.80 

* * * 

*** Record 8: (18) NDC - Number of different crops simulated; FLITNUM 

10 

* * * 

*** Record 9 for Crop 1: (18,3F8.0,18,3(1X,I3),2F8.0) 

ICNCN, CINTCP , AMXDR, COW, ICNAH, ( 3 ) CN, WFMAX, HTMAX 

***ICNCNCINTCP AMXDR COVMAX ICNAH CN1 CN2 CN3WFMAX HTMAX 

12.00E-016.50E+011.0OE+02 3 92 89 900.00E+001.22E+02 

* * * 

*** Record 9A (218): CROPN0,NUSLEC - Crop, Number of USLE C (cover management) factors 

1 2 5 

*** Record 9B: (16(12,12,1X) GDUSLEC,GMUSLEC for each USLEC 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

0106 1606 0107 1607 0108 1608 0109 1609 0110 1610 0111 1611 0112 1612 0101 1601 

*** Record 9C: (16(F4.0,1X)) - USLEC (USLE Cover management factors) 

.640 .511 .364 .311 .314 .299 .359 .376 .228 .326 .362 .396 .427 .460 .474 .504 

*** Record 9D: (16(F4.0,1X)) - MNGN - Manning's N for each USLEC 

.014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 

*** Record 9E: (16(14,1X)) - CN(I1) for each USLEC 

89 89 89 89 89 89 89 89 89 89 92 92 92 92 92 92 

* * * 

*** Continuation of Records 9B,9C,9D,9E for USLEC 17-25 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

0102 1602 0103 1603 0104 1604 2504 0105 1605 

.532 .557 .584 .615 .645 .707 .741 .748 .720 

.014 .014 .014 .014 .014 .014 .014 .014 .014 

92 92 92 92 92 92 92 92 92 

* * * 

*** Record 10: (18) NCPDS - number of cropping periods 

3 0 

*** 

*** Record(s) 11: (2X, 312,2X, 312,3X, 312,18) - dates of crop EMergence, MAturation, and 

HArves t 

*** EMD,EMM,IYREM,MAD,MAM,IYRMAT,HAD,HAM,IYRHAR,INCROP 

***EMerge MAture HArvest 

***DMMYY DDMMYY DDMMYY Crop No. 

010661 010861 011161 1 

010662 010862 011162 1 

010663 010863 011163 1 

010664 010864 011164 1 
010665 010865 011165 

010666 010866 011166 

010667 010867 011167 

010668 010868 011168 

010669 010869 011169 

010670 010870 011170 

010671 010871 011171 

010672 010872 011172 

010673 010873 011173 

010674 010874 011174 

010675 010875 011175 

010676 010876 011176 

010677 010877 011177 

010678 010878 011178 

010679 010879 011179 

010680 010880 011180 

010681 010881 011181 

010682 010882 011182 

010683 010883 011183 

010684 010884 011184 

010685 010885 011185 

010686 010886 011186 

010687 010887 011187 

010688 010888 011188 

010689 010889 011189 

010690 010890 011190 

* * * 

*** Record 12 : (A78) PTITLE 

Chemical Input Data: 

*** 

- Label for pesticide 

*** Record 13: (418) NAPS,NCHEM,FRMFLG,DK2FLG 

*** NAPS NCHEM FRMFLG DK2FLG 

3 0 1 0 0 

* * * 

*** Record 15: (3A20) Name(s) of pesticides for output titles 

Clothianidin 

* * * 

*** Record(s) 16: (2X,312,13,3(12,F5.0,F6.O,F5.O,F5.0)) - application data 

*** including the application date (APD,APM,IAPYR), WINDAY, and 

( 1 ) (CAM, DEPI , TAPP , APPEFF , DRFT ) 

***DMMYYWinCmDepi Tapp Eff Drft CmDepi Tapp Eff Drft CmDepi Tapp Eff Drft 

250561 0 5 1.270.07091.000.0000 

250562 0 5 1.270.07091.000.0000 

250563 0 5 1.270.07091.000.0000 

250564 0 5 1.270.07091.000.0000 

250565 0 5 1.270.07091.000.0000 

250566 0 5 1.270.07091.000.0000 

250567 0 5 1.270.07091.000.0000 

250568 0 5 1.270.07091.000.0000 

250569 0 5 1.270.07091.000.0000 

250570 0 5 1.270.07091.000.0000 

250571 0 5 1.270.07091.000.0000 

250572 0 5 1.270.07091.000.0000 

250573 0 5 1.270.07091.000.0000 

250574 0 5 1.270.07091.000.0000 

250575 0 5 1.270.07091.000.0000 

250576 0 5 1.270.07091.000.0000 

250577 0 5 1.270.07091.000.0000 

250578 0 5 1.270.07091.000.0000 

250579 0 5 1.270.07091.000.0000 

250580 0 5 1.270.07091.000.0000 

250581 0 5 1.270.07091.000.0000 

250582 0 5 1.270.07091.000.0000 
250583 0 5 1.270.07091.000.0000 

250584 0 5 1.270.07091.000.0000 

250585 0 5 1.270.07091.000.0000 

250586 0 5 1.270.07091.000.0000 

250587 0 5 1.270.07091.000.0000 

250588 0 5 1.270.07091.000.0000 

250589 0 5 1.270.07091.000.0000 

250590 0 5 1.270.07091.000.0000 

* * * 

*** Record 17: (includes data for each chemical) (F8.0,3(18,F8.0)) FILTRA, 

( 1 ) ( IPSCND , UPTKF ) 

***FILT IPSCNDl UPTKFl IPSCND2 UPTKF2 IPSCND3 UPTKF3 

0.00E+00 10.00E+00 

*** 

*** Record 19: (A78) STITLE - label for soil properties 

"Boswell, sandy loam, HYDG: D" Brief description of s * * * 

*** Record 20: (F8.0,8X,914) 

CORED,BDFLAG,THFLAG,KDFLAG,HSWZT,MOC,IRFLAG,ITFLAG,IDFLAG,BIOFLG 

***CORED (cm) BD TH KD HS MOC IR IT ID BIO 

1.00E+02 000000000 

*** 

*** Record 26: (9F8.0) (l)DAIR, (l)HENRYK, (1)ENPY 

4.30E+031.19E-152.00E+01 

C C I 

*** Record 33: (18) NHORIZ (total number of soil horizons) 

3 

* * * 

*** Record 34 for Horizon 1: (I8,BFg.O) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

11.00E+011.80E+002.13E-010.00E+OOO.OOE+OOO.OOE+OO 

*** 

*** Record 36 for Horizon 1: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 1: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

1.00E-012.13E-016.30E-O22.32E+OO3.71E+OO 

* * * 

*** Record 34 for ~orizon 2: (18,gFg.O) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

22.00E+001.80E+002.13E-01O.OOE+OOO.OOE+OOO.OOE+OO 

* * * 

*** Record 36 for Horizon 2: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

*** 

*** Record 37 for Horizon 2: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

2.OOE+002.13E-016.30E-O22.32E+OO3.71E+OO 

* * * 

*** Record 34 for Horizon 3: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

38.80E+011.70E+003.54E-010.00E+OOO.OOE+OOO.OOE+OO 

* * * 

*** Record 36 for Horizon 3: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

*** 

*** Record 37 for Horizon 3: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

4.00E+003.54E-012.13E-012.90E-014.64E-01 

*** 

*** Record 40: (218) ILP; CFLAG (blank if ILP=O) 

0 

* * * 

*** Record 42: (3 (4X,A4,4X,A4,18], 14) 

ITEMl,STEPl,LFREQl,ITEM2,STEP2,LFREQ2,ITEM3,STEP3,LFREQ3,EXMFLG 

WATR YEAR 10 PEST YEAR 10 CONC YEAR 10 1 

*** 

*** Record 43: (18) EXMENV 

9 1 
*** Record 44 for Chemical 1: EXMCHM,CAS Number,NPROC,RFORM,YIELD 

1 CASSNO: -999 1 10.00E+00 

*** 

*** Record 45: NPLOTS (number of time series variables,STEP4 

0 YEAR 

*** 

*** Records 46: Plotting variables 

NORTH DAKOTA CANOLA SCENARIO, CAM 5 

FILE NAME = ND 1 Cno-P. INP 

*** Record 1: (A78), TITLE - label for simulation title 

Express v. 1.03.02 (2007-07-20) 

*** NDCanolaTitle of input file "Existin 

* * * 

*** Record 2: (A78), HTITLE - Hydrology Information Title 

"Cavalier County, ND MLRA 55a; Metfile: W24013.dvf (Old * * * 

*** Record 3: (2F8.0,18,F8.0,218,514) PFAC,SFAC,IPEIND,ANETD,INICRP,ISCOND 

***PFAC SFAC IPEIND ANETD INICRP ISCOND (WDM data sets not used) 

7.60E-013.60E-01 01.25E+01 1 1 

* * * 

*** Record 6: (18) ERFLAG: Flag to calculate erosion 

4 

* * * 

*** Record 7: (4F8.0,8X,I8,2F8.0) USLEK,USLELS,USLEP,AFIELD,IREG,SLP,HL 

***USLEKUSLELS USLEP AFIELD IREG SLP HL 

2.80E-012.5OE-O11.00E+001.OOE+O1 3 1.50 356.80 

* * * 

*** Record 8: (18) NDC - Number of different crops simulated; FLITNUM 

10 

* * * 

*** Record 9 for Crop 1: (18,3F8.0,18,3(lX,I3),2F8.0) 

ICNCN,CINTCP,AMXDR,COVMAX,ICNAH, (3)CN,WFMAX,HTMAX 

***ICNCNCINTCP AMXDR COVMAX ICNAH CN1 CN2 CN3WFMAX HTMAX 

11.OOE-O11.2OE+O21.OOE+02 3 87 82 830.00E+001.25E+02 

* * * 

*** Record 9A (218): CROPN0,NUSLEC - Crop, Number of USLE C (cover management) factors 

1 2 9 

*** Record 9B: (16(12,12,1X) GDUSLEC,GMUSLEC for each USLEC 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

1605 0106 1606 0107 1607 0108 0508 1008 1608 2508 0109 1609 0110 1610 0111 1611 

*** Record 9C: (16(F4.0,1X)) - USLEC (USLE Cover management factors) 

.562 .468 .268 .092 .064 .065 .036 .098 .I10 .I10 .I26 .I39 .I52 .I62 .I68 .I70 

*** Record 9D: (16(F4.0,1X)) - MNGN - Manning's N for each USLEC 

.014 .014 .014 ,014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 

*** Record 9E: (16 (I4,lX) ) - CN(I1) for each USLEC 

82 82 82 82 82 82 82 82 82 82 87 87 87 87 87 87 

* * * 

*** Continuation of Records 9B,9C,9D,9E for USLEC 17-29 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

0112 1612 0101 1601 0102 1602 0103 1603 0104 1604 2004 0105 0505 

.I71 .I71 .583 .581 .579 .577 .574 .574 .575 .575 .611 .617 .610 

-014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 .014 

87 87 87 87 87 87 87 87 87 87 87 87 87 

* * * 

*** Record 10: (18) NCPDS - number of cropping periods 

2 8 

* * * 
*** Recordls) 11: (2X,312,2X,312,3X,312,18) - dates of crop EMergence, MAturation, and 

HArvest 

*** EMD,EMM,IYREM,MAD,MAM,IYRMAT,HAD,HAM,IYRHAR,INCROP 

***EMerge MAture HArvest 

***DMMYY DDMMYY DDMMYY Crop NO. 

160561 150861 250861 1 

160562 150862 250862 1 

160563 150863 250863 1 

160564 150864 250864 1 

160565 150865 250865 1 

160566 150866 250866 1 

160567 150867 250867 1 

160568 150868 250868 1 

160569 150869 250869 1 

160570 150870 250870 1 

160571 150871 250871 1 

160572 150872 250872 1 

160573 150873 250873 1 

160574 150874 250874 1 

160575 150875 250875 1 

160576 150876 250876 1 

160577 150877 250877 1 

160578 150878 250878 1 

160579 150879 250879 1 

160580 150880 250880 1 

160581 150881 250881 1 

160582 150882 250882 1 

160583 150883 250883 1 

160584 150884 250884 1 

160585 150885 250885 1 

160586 150886 250886 1 

160587 150887 250887 1 

160588 150888 250888 1 

* * * 

*** Record 12: (A78) PTITLE - Label for pesticide 

Chemical Input Data: 

* * * 

*** Record 13: (418) NAPS,NCHEM,FRMFLG,DK2FLG 

*** NAPS NCHEM FRMFLG DK2FLG 

2 8 1 0 0 

* * * 

*** Record 15: (3A20) Name(s) of pesticides for output titles 

Clothianidin 

* * * 

*** Record(s) 16: (2X,312,13,3(12,F5.0,F'6.0,F5.O,F5.0)) - application data 

*** including the application date (APD,APM,IAPYR), WINDAY, and 

(1) (CAM, DEPI, TAPP, APPEFF, DRFT) 

***DMMYYWinCmDepi Tapp Eff Drft CrnDepi Tapp Eff Drft CrnDepi Tapp Eff Drft 

090561 0 5 1.270.03141.000.0000 

090562 0 5 1.270.03141.000.0000 

090563 0 5 1.270.03141.000.0000 

090564 0 5 1.270.03141.000.0000 

090565 0 5 1.270.03141.000.0000 

090566 0 5 1.270.03141.000.0000 

090567 0 5 1.270.03141.000.0000 

090568 0 5 1.270.03141.000.0000 

090569 0 5 1.270.03141.000.0000 

090570 0 5 1.270.03141.000.0000 

090571 0 5 1.270.03141.000.0000 

090572 0 5 1.270.03141.000.0000 

090573 0 5 1.270.03141.000.0000 

090574 0 5 1.270.03141.000.0000 

090575 0 5 1.270.03141.000.0000 
*** Record 17: (includes data for each chemical) (F8.0,3(18,F8.0)) FILTRA, 

(1) (IPSCND, UPTKF) 

***FILT IPSCNDl UPTKFl IPSCND2 UPTKF2 IPSCND3 UPTKF3 

0.00E+00 10.00E+00 

* * * 

*** Record 19: (A78) STITLE - label for soil properties 

Hamerly loam; HYDG: C Brief description of soil proper *** 

*** Record 20: (F8.0,8X,914) 

CORED,BDFLAG,THFLAG,KDFLAG,HSWZT,MOC,IRFLAG,ITFLAG,IDFLAG,BIOFLG 

***CORED (cm) BD TH KD HS MOC IR IT ID BIO 

1.50E+02 000000000 

* * * 

*** Record 26: (9F8.0) (l)DAIR, (l)HENRYK, (1)ENPY 

4.30E+031.19E-152.00E+01 

*** 

*** Record 33: (18) NHORIZ (total number of soil horizons) 

4 

*** 

*** Record 34 for Horizon 1: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

11.00E+011.48E+002.24E-010.00E+OOO.OOE+OOO.OOE+OO 

*** 

*** Record 36 for Horizon 1: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 1: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

1.00E-012.24E-011.08E-012.36E+003.78E+00 

* * * 

*** Record 34 for Horizon 2: (I8,8F8.0) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

21.50E+011.48E+002.24E-010.00E+OOO.OOE+O00.00E+00 

* * * 

*** Record 36 for Horizon 2: (8X,9F8.0) (l)DWRATE, (l)DSRATE, (1)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 2: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

5.00E+002.24E-011.08E-012.36E+003.78E+00 

* * * 

*** Record 34 for Horizon 3: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

32.50E+011.48E+O02.24E-010.00E+OOO.OOE+O00.00E+00 

* * * 

*** Record 36 for Horizon 3: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 3: (8X.7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

5.00E+002.24E-011.08E-018.20E-011.31E+00 

* * * 

*** Record 34 for Horizon 4: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

41.00E+021.48E+002.28E-010.00E+OOO.OOE+O00.00E+00 

* * 
*** Record 36 for Horizon 4: (8X, 9F8.0) (1) DWRATE, (1) DSRATE, (1) DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 4: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

5.00E+O02.28E-011.10E-012.50E-014.00E-01 

*** 

*** Record 40: (218) ILP; CFLAG (blank if ILP=O) 

0 

*** 

*** Record 42: (3 (4X,A4,4X,A4,18), 14) 

ITEM~,STEP~,LFREQ~,ITEM~,STEP~,LFREQ~,ITEM~,STEP~,LFREQ~,E~FLG 

WATR YEAR 10 PEST YEAR 10 CONC YEAR 10 3 

*** 

*** Record 43: (18) EXMENV 

9 9 

*** 

*** Record 44 for Chemical 1: EXMCHM,CAS Number,NPROC,RFORM,YIELD 

1 CASSNO: -999 1 10.00E+00 

*** 

*** Record 45: NPLOTS (number of time series variables,STEP4 

0 YEAR k * * 

*** Records 46: Plotting variables 

CALIFORNIA COTTON SCENARIO, CAM 5 

FILE NAME = CAI Ctt-P.INP 

*** Record 1: (A78), TITLE - label for simulation title 

Express v. 1.03.02 (2007-07-20) 

*** "CaCotton.xls - Created August 6, 2001" Title of i 

* * * 

*** Record 2: (A78), HTITLE - Hydrology Information Title 

"Fresno County, CA - MLRA 17, Metfile: W93193.dvf (old: * * * 

*** Record 3: (2F8.0,18,F8.0,218,514) PFAC,SFAC,IPEIND,ANETD,INICRP,ISCOND 

***PFAC SFAC IPEIND ANETD INICRP ISCOND (WDM data sets not used) 

7.30E-010.00E+OO 01.75E+01 1 1 

* * * 

*** Record 6: (18) ERFLAG: Flag to calculate erosion 

4 

*** 

*** Record 7: (4F8.0,8X,I8,2F8.0) USLEK,USLELS,USLEP,AFIELD,IREG,SLP,HL 

***USLEKUSLELS USLEP AFIELD IREG SLP HL 

2.1OE-O13.7OE-O11.OOE+OO1.OOE+O1 1 2.50 356.80 

* * * 

*** Record 8: (18) NDC - Number of different crops simulated; FLITNUM 

LO 

* * * 

*** Record 9 for Crop 1: (18,3F8.0,18,3(lX,I3),2F8.0) 

ICNCN,CINTCP,AMXDR,COVMAX,ICNAH, (3)CN,WFMAX,HTMAX 

***ICNCNCINTCP AMXDR COVMAX ICNAH CN1 CN2 CN3WFMAX HTMAX 

12.00E-016.50E+011.0OE+02 3 89 86 870.00E+001.22E+02 

*** 

*** Record 9A (218): CROPN0,NUSLEC - Crop, Number of USLE C (cover management) factors 

1 2 6 

*** Record 9B: (16(12,12,1X) GDUSLEC,GMUSLEC for each USLEC 

***M DDIYIM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

0105 1605 0106 1606 0107 1607 0108 1608 0109 1609 0110 1610 0111 1111 1611 0112 

*** Record 9C: (16(F4.0,1X)) - USLEC (USLE Cover management factors) , 
.I61 .085 -062 .062 .062 .054 .054 .054 .054 .054 .055 .091 .098 .098 .lo8 .I23 

*** Record 9D: (16(F4.0,1X)) - MNGN - Manning's N for each USLEC 

.023 .023 .023 .023 .023 .023 .023 .023 .023 .023 .023 .023 .023 .023 .023 .023 

*** Record 9E: (16(14,1X)) - CN(I1) for each USLEC 

86 86 86 86 86 86 86 86 86 86 86 86 86 86 89 89 

* * * 

*** Continuation of Records 9B,9C,9D,9E for USLEC 17-26 

***M DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM DDMM 

1612 0101 1601 0102 1602 2502 0103 1603 0104 1604 

.I37 .I57 .I75 .I96 .351 -395 .412 .392 .337 .259 

.023 .023 .023 .023 .023 .023 .023 .023 .023 ,023 

89 89 89 89 89 89 89 89 89 89 

*** 

*** Record 10: (18) NCPDS - number of cropping periods 

3 0 

*** 

*** Record(s) 11: (2X,312,2X,312,3X,312,18) - dates of crop EMergence, MAturation, and 

HArves t 

*** EMD,EMM,IYREM,MAD,MAM,IYRMAT,HAD,HAM,IYRHAR,INCROP 

***EMerge MAture HArvest 

***DMMYY DDMMYY DDMMYY Crop No. 

010561 200961 111161 1 

010562 200962 111162 1 

010563 200963 111163 1 

010564 200964 111164 1 

010565 200965 111165 1 

010566 200966 111166 1 

010567 200967 111167 1 

010568 200968 111168 1 

010569 200969 111169 1 

010570 200970 111170 1 

010571 200971 111171 1 

010572 200972 111172 1 

010573 200973 111173 1 

010574 200974 111174 1 

010575 200975 111175 1 

010576 200976 111176 1 

010577 200977 111177 1 

010578 200978 111178 1 

010579 200979 111179 1 

010580 200980 111180 1 

010581 200981 111181 1 

010582 200982 111182 1 

010583 200983 111183 1 

010584 200984 111184 1 

010585 200985 111185 1 

010586 200986 111186 1 

010587 200987 111187 1 

010588 200988 111188 1 

010589 200989 111189 1 

010590 200990 111190 1 

* * * 

*** Record 12: (A78) PTITLE - Label for pesticide 

Chemical Input Data: 

*** 

*** Record 13: (418) NAPS,NCHEM,FRMFLG,DK2FLG 

*** NAPS NCHEM FRMFLG DK2FLG 

3 0 1 0 0 

*** 

*** Record 15: (3A20) Name(s) of pesticides for output titles 

Clothianidin 

*** 

*** Record(s) 16: (2X,312,13,3(12,F5.O,F6.O,F5.O,F5.0)) - application data 

96 
*** including the application date (APD,APM,IAPYR), WINDAY, and 

( 1) (CAM, DEPI , TAPP, APPEFF, DRFT) 

***DMMYYWinCmDepi Tapp Eff Drft CmDepi Tapp Eff Drft CmDepi Tapp Eff Drft 

240461 0 5 1.270.07091.000.0000 

240462 0 5 1.270.07091.000.0000 

240463 0 5 1.270.07091.000.0000 

240464 0 5 1.270.07091.000.0000 

240465 0 5 1.270.07091.000.0000 

240466 0 5 1.270.07091.000.0000 

240467 0 5 1.270.07091.000.0000 

240468 0 5 1.270.07091.000.0000 

240469 0 5 1.270.07091.000.0D00 

240470 0 5 1.270.07091.000.0000 

240471 0 5 1.270.07091.000.0000 

240472 0 5 1.270.07091.000.0000 

240473 C 5 1.270.07091.000.0000 

240474 0 5 1.270.07091.000.0000 

240475 0 5 1.270.07091.000.0000 

240476 0 5 1.270.07091.000.0000 

240477 0 5 1.270.07091.000.0000 

240478 0 5 1.270.07091.000.0000 

240479 0 5 1.270.07091.000.0000 

240480 0 5 1.270.07091.000.0000 

240481 0 5 1.270.07091.000.0000 

240482 0 5 1.270.07091.000.0000 

240483 0 5 1.270.07091 .OOO.OOOO 

240484 0 5 1.270.07091.000.0000 

240485 0 5 1.270.07091.000.0000 

240486 0 5 1.270.07091.000.0000 

240487 0 5 1.270.07091.000.0000 

240488 0 5 1.270.07091.000.0000 

240489 0 5 1.270.07091.000.0000 

240490 0 5 1.270.07091.000.0000 

*** 

*** Record 17: (includes data for each chemical) (F8.0,3(18,F8.0)) FILTRA, 

(1) (IPSCND,UPTKF) 

***FILT IPSCNDl UPTKFl IPSCND2 UPTKF2 IPSCND3 UPTKF3 

0.00E+00 10.00E+00 

* * * 

*** Record 19: (A78) STITLE - label for soil properties 

Twisselman Clay - Hydg: C Brief description of soil pr * * * 

*** Record 20: (F8.0,8X,914) 

CORED,BDFLAG,THFLAG,KDFLAG,HSWZT,MOC,IRFLAG,ITFLAG,IDFLAG,BIOFLG 

***CORED (cm) BD TH KD HS MOC IR IT ID BIO 

1.00E+02 000002000 

*** 

*** Record 26: (9F8.0) (l)DAIR, (l)HENRYK, (1)ENPY 

4.30E+031.19E-152.00E+01 

*** 

*** Record 27 (18,3F8.0) IRTYP,FLEACH,PCDEPL,RATEAP - irrigation specifications 

***IRTYPFLEACH PCDEPL RATEAP 

41.00E-015.50E-017.4OE-02 

*** 

*** Record 33: (18) NHORIZ (total number of soilhorizons) 

3 

* * * 

*** Record 34 for Horizon 1: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD,(l)DISP,ADL 

11.00E+011.45E+003.6OE-O1O.OOE+OOO.OOE+OOO.OOE+OO 

* * * 

*** Record 36 for Horizon 1: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO 

*** 
*** Record 37 for Horizon -1: (8X,7F8.0) DPN,THEFC,THEWP,OC, (1)KDs 

1.00E-013.60E-012.20E-012.90E-014.64E-01 

*** 

*** Record 34 for Horizon 2: (I8,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

22.60E+011.50E+003.6OE-010.00E+OOO.OOE+OOO.OOE+OO 

*** 

*** Record 36 for Horizon 2: (8X, 9F8.0) (l)DWRATE, (l)DSRATE, (1)DGRATE 

9.30E-049.30E-040.00E+OO 

* * * 

*** Record 37 for Horizon 2: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

2.00E+003.60E-012.20E-012.90E-014.64E-01 

*** 

*** Record 34 for Horizon 3: (18,8F8.0) HORIZN,THKNS,BD,THETO,AD, (l)DISP,ADL 

36.40E+011.60E+003.17E-010.00E+OOO.OOE+OOO.OOE+OO 

*** 

*** Record 36 for Horizon 3: (8X,9F8.0) (l)DWRATE,(l)DSRATE,(l)DGRATE 

9.30E-049.30E-040.00E+OO * * * 

*** Record 37 for Horizon 3: (8X,7F8.0) DPN,THEFC,THEWP,OC,(l)KDs 

4.00E+003.17E-011.97E-011.74E-012.78E-01 

* * * 

*** Record 40: (218) ILP; CFLAG (blank if ILP=O) 

0 

* * * 

*** Record 42: (3 (4X,A4,4X,A4,18), 14) 

ITEMl,STEPl,LFREQl,ITEM2,STEP2,LFREQ2,ITEM3,STEP3,LFREQ3,EmFLG 

WATR YEAR 10 PEST YEAR 10 CONC YEAR 10 1 

*** 

*** Record 43: (I81 EXMENV 

9 9 

* * * 

*** Record 44 for Chemical 1: EXMCHM,CAS Number,NPROC,RFORM,YIELD 

1 CASSNO: -999 1 10.00E+00 

* * * 

*** Record 45: NPLOTS (number of time series variables,STEP4 

0 YEAR 

* * * 

*** Records 46: Plotting variables 

................................................................... 
Table of Estimated Environmental Concentrations from PRZM-EXAMS 

CAM = 5 for Seed Treatments, CAM = 1 or 2 for surface applications (pond water EECs): 

Upper 10th Percentile Limnetic EECs in Farm Pond 

Chemical - Clothianidin 

Scenarios I lmtantaneous / 96-Hour I 2l-Day I GO-Day I 90-Day I Annual I 

RUN ID: GAlOni-P 31 .4 31.2 30.6 29.3 27 .9 18.6 

RUN ID: FLlCar-P 17.4 17.2 16.8 15.9 14.4 9.1 5 

 RUN ID: FLICuc-P 1 10.8 ( 10.8 ( 10.6 1 10.2 1 8.85 1 6.13 1 

 RUN ID: FLlPep-P 1 10.6 1 10.8 1 10.4 1 9.85 1 9.44 1 8.06 ( 

IRUN ID: NCICtt-P ( 3.00 1 2.98 1 2.91 1 2.82 1 2.78 ( 2.18 1 

RUN ID: FLICbb-P 

RUN ID: PAITur-P 

RUN 10: FLITur-P 

5.58 

4.47 

3.05 

RUN ID: NY2Gra-P 

RUN ID: FLlTrna-P 

RUN ID: CAlGra-P 

RUN ID: MSISyb-P 

RUN ID: CAlOni-P 

(RUN ID: MEIPm-P 1 0.265 1 0.265 1 0.264 1 0.260 1 0.258 1 0.214 1 

RUN 10: P A1 Trna-P 

RUN ID: NCITba-P 

RUN ID: NDIWhe-P 

RUN ID: NDICno-P 

RUN ID: CAlCtt-P 

 RUN ID: MSICor-P ( 0.152 ( 0.151 1 0.148 1 0.141 1 0.137 ( 0.106 1 

5.54 

4.46 

3.04 

2.26 

1.15 

1 .I1 

1.07 

1.07 

(RUN ID: IL1 Cor-P I O.672E-01 I 0.668E-01 I O.663E-01 I 0.641E-01 1 0.623E-01 1 0.508E-01 1 

0.998 

0.983 

0.798 

0.491 

0.31 0 

5.43 

4.39 

2.97 

2.25 

1 .I4 

I .I0 

1 .07 

I .06 

1 RUN ID: NC1 Cor-P ( 0.305E-01 I O.304E -01 I 0.302E-01 ( 0.296E -01 I 0.292E -01 1 0.224E -01 I 

0 .Q9# 

0.977 

0.793 

0.488 

0.309 

RUN ID: OH1 Car-P 

5.22 

4.28 

2.85 

2.23 

1 .I1 

1.08 

1.05 

1 .04 

0.978 

0.955 

0.782 

0.480 

0.308 

RUN ID: P A1 Cor-P I 0.369E-01 1 0.367E -01 1 0.362E-01 1 0.351E -01 1 0.344E -01 1 0.302E-01 1 

0.556E-01 

4.82 

4.1 4 

2.76 

2.16 

1 .07 

I .02 

1 .Ol 

0.997 

3.42 

3.41 

2.17 

0 943 

0.935 

0.770 

0.462 

0.300 

0.553E -01 

2.1 3 

1.08 

0.993 

0.976 

0.987 

1.65 

0.829 

0 701 

0.708 

0.729 

0.016 

0.91 6 

0.757 

0.450 

0.296 

0.53QE -01 

0.759 

0.893 

0.829 

0.367 1 

0.224 

O.524E -01 0.51 OE -01 O.438E -01 
CAM = 8 for Seed Treatments, CAM = 1 or 2 for surface applications (pond water EECs): 

Upper 10th Percentile Limnetic EECs in Farm Pond 

Chemical - Clothianidin 

RUN ID: OHICor-P 

RUN ID: PAlCor-P 

RUN ID: IDlPa-P 

RUN ID: MElPat-P 

RUN ID: MSISyb-P 

RUN 10: NDlWhe-P 

Eqea u. 103m @@?07.@- bans29BD+D8uih PRZU 3.122[q 

0.00 

0.00 

0.00 

0.00 

0 .OO 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0 .00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0 .OO 

0 .OO 

0.00 

0.00 

0.00 

0 .OO 

0 .00 

0 .OO 

0 .00 

0 .OO 

0 .00 

0.00 

0 .OO 

0 .OO 

0 .00 

0.00 

0.00 
CAM = 8 for Seed Treatments, CAM = 1 or 2 for surface applications (benthic pore water 

EECs) : 

Upper 10th Percentile Benthic EECs in Farm Pond 

Chemical - Clothianidin 

bpree u. lmD.2 @O?U-~QJ- hs2~1I+D6uih P~3.122[(8]