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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

,. fi "5 WASHINGTON, D.C. 20460 

DP Barcode: D267178 

PC Code: 101601 

MEMORANDUM 

Subject: Cyhexatin: Review of environmental fate and ecological effects data 

submitted in support of registration on hops. 

From: Dana S. Spatz, Risk Assessment Proces 

I Thomas Steeger, Ph.D., Fishery Biologis 

Environmental Risk Branch IV 

Environmental Fate and Effects Division 

Through: Mah Shamim, Ph.D., Chief 

Environmental Risk Branch IV 

Environmental Fate and Effects ~ivision 

To: Akiva Abramovitch, PM Team Reviewer 

Tina Levine, Chief 

Insecticide/Rodenticide Branch 

Registration Division 

EFED has completed an initial screen of Elf Atochem's 3/27/2000 cyhexatin 

submission (MRID #s:45074701, 451 26301, and 451 10301 ) to determine if it 

adequately addressed any of the outstanding environmental fate or ecological effects 

data gaps. Unfortunately, we have concluded that the data package does not provide 

the missing information needed to complete a risk assessment. 

ECOLOGICAL EFFECTS 

The report provides an overview of the ecotoxicology database for the organotin 

compound, and an assessment of the potential risks to nontarget organisms from 

cyhexatin use on hops. The report however does not address any of the outstanding 

data requirements, i.e., acute and chronic aquatic toxicity studies using technical grade 

Text Searchable File
active ingredient, identified earlier by EFED. While the report cites acute and chronic 

aquatic toxicity data, it fails to note that EFED classified many of the studies as invalid. 

Additionally, the data cited in the report may significantly underestimate toxicity since 

many of the studies are based on nominal rather than mean measured concentrations. 

The following data requirements remain unfulfilled: 

72-4(a) 

72-4(a) 

72-4(b) 

72-1 

72-1 (a) 

72-1 (c) 

72-3(a) 

72-3(~) 

Freshwater fish early life-stage (technical grade active ingredient [TGAI]) 

Estuarinelmarine fish early life-stage (TGAI) 

Freshwater invertebrate life cycle (TGAI) 

Freshwater invertebrate acute toxicity with Daphnia magna (TGAI) 

Freshwater fish (warm water) acute toxicity with bluegill sunfish (TGAI) 

Freshwater fish (cold water) acute toxicity with rainbow trout (TGAI) 

Estuarinelmarine acute toxicity with sheepshead minnow (TGAI) 

Estuarinelmarine invertebrate with mysid shrimp (TGAI) 

ENVIRONMENTAL FATE 

Elf Atochem submitted a four volume, I1 96 page compilation of mostly irrelevant 

information hoping to fulfill the environmental fate data gaps. Some of the impertinent 

information included in the data package was, 1) previously submitted studies, several 

of which were already determined to be invalid, 2) the entire TPTH RED, 3) literature 

information on Tributyltin, and 4) data sheets in German. Several European studies on 

Azocyclotin, which hydrolyzes to cyhexatin, were included, however these studies 

provided no information addressing the remaining data requirements. Specifically, the 

photodegradation in water (161 -2), photodegradation on soil (1 61 -3), batch equilibrium 

(1 63-I), accumulation in fish (1 65-4), and field dissipation (1 64-1) data requirements 

remain unfulfilled. 
CASE: 060207 

SUBMISSION: S581867 

DATA PACKAGE RECORD 

BEAN SHEET 

DATE: 07/05/00 

Page 1 of 1 

CASE TYPE: REGISTRATION ACTION: 010 NEW CHEMICAL SCREENING 

RANKING : 0 POINTS () 

CHEMICALS: 101601 Cyhexatin (ANSI) 96.0000% 

ID#: 004581-GIE TECHNICAL CYHEXATIN 

COMPANY: 004581 ELF ATOCHEM NORTH AMERICA INC 

PRODUCT MANAGER: 04 TINA LEVINE 703-308-7055 ROOM: CM2 219 

PM TEAM REVIEWER: AKIVA ABRAMOVITCH 703-308-8328 ROOM: CM2 207 

RECEIVED DATE: 06/01/00 DUE OUT DATE: 07/31/00 

* * * DATA PACKAGE INFORMATION * * * 

DP BARCODE: 267178 EXPEDITE: Y DATE SENT: 07/05/00 DATE RET.: / / 

CHEMICAL : 101601 Cyhexatin (ANSI) 

DP TYPE: 001 

CSF: N LABEL: N 

ASSIGNED TO DATE OUT ADMIN DUE DATE: 09/03/00 

DIV : EFED 7 / /f /60 NEGOT DATE: / / 

BRAN: ERB4 7 / c(/6~ PROJDATE: / / 

SECT: 10 /rr /m 

REVR : 

CONTR : / / 

* * * DATA REVIEW INSTRUCTIONS * * * 

review/screen MRID 45074701, 45126301 and 45110301 (already 

screened), any changes to data gaps? list data gaps 

* * * DATA PACKAGE EVALUATION * * * 

No evaluation is written for this data package 

* * * ADDITIONAL DATA PACKAGES FOR THIS SUBMISSION * * * 

DP BC BRANCH/SECTION DATE OUT DUE BACK INS CSF LABEL