### ii The Environmental Fate and Effects Division (E FED) and Antimicrobials Division (AD) have completed the preliminary problem formulation (a ttached) for the environmental fate, ecological risk, endangered species, and drinking water expo sure assessments to be conducted as part of the Registration Review of the organochlorine f ungicide, mildewcide, algicide, and acaricide,

chlorothalonil. This document is intended to provide an overv iew of what is currently known regarding the environmental fate and ecological effects associated with registered uses of chlorothalonil and its degradation products, and outlines uncertainties regarding attributes of the parent compound and its transfor mation products. It describes th e preliminary ecological risk hypothesis and the processes that will be used during the completion of drinking water and ecological risk assessments in support of Regi stration Review. Within OPP, the EFED is responsible for assessing the conventional agri cultural food and non-agricu ltural turf uses of

chlorothalonil and the AD is re sponsible for assessing the wood and material preservative and

material additive uses of chlorothalonil.

This problem formulation outlines the plan to be ut ilized in the risk assessm ent of chlorothalonil. The risk assessment will consider not only parent chlorothalonil, but also the major degradate of toxicological concern, SDS-3701 (other degradates may be considered if additional information indicates they are of toxico logical concern), and manufact uring by-products of concern, including hexachlorobenzene (HCB) and congene rs (structurally rela ted chemicals) of polyhalogenated dibenzo-p-dioxin s/dibenzofurans (dioxins/fur ans). This document also

recommends studies that should be included in a data call-in (DCI) to address uncertainties surrounding the environmental fate and potential eco logical effects of chlo rothalonil. In addition to the DCI recommendations, EPA is requesting additional information from the chlorothalonil registrants to establish the levels of the known chlorothalonil impurities [ i.e ., hexachlorobenzene (HCB) and dioxin/furans] in currently registered products. Additional details are provided in the problem formulation.

### 1 REGISTRATION REVIEW

Preliminary Problem Formulation for the Envi ronmental Fate, Ecological Risk, Endangered Species and Drinking Water Assessments for:

Chlorothalonil 2,4,5,6-Tetrachloroisop hthalonitrile

Prepared by: Amy Blankinship, Chemist Rochelle Bohaty, PhD, Chemist Tanja Crk, MA, Biologist Melissa Panger, PhD, Senior Scientist



### Reviewed by: Rosanna Louie-Juzwiak, Risk Assessment

Process Leader Dana Spatz, Branch Chief

U. S. Environmental Protection Agency Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch 3 1200 Pennsylvania Ave., NW

Mail Code 7507P Washington, DC 20460 Srinivas Gowda, Microbiologist William Erickson, PhD, Biologist Najm Shamim, PhD, Chemist

Nader Elkassabany, PhD, Branch Chief

U.S. Environmental Protection Agency Office of Pesticide Programs

Antimicrobials Division Risk Assessment and Science Support Branch 1200 Pennsylvania Ave., NW

Mail Code 7510P Washington, DC 20460



### March 22, 2012 Cl

Cl Cl Cl N

N

### 2 TABLE OF CONTENTS

I. Purpose .............................................................................................................. 3

II. Problem Formulation ....................................................................................... 3

A. Nature of Regulatory Action ........................................................................................... 3

B. Previous Assessments ..................................................................................................... 4

C. Stressor Source and Distribution .................................................................................... 6

D. Environmental Fate and Transport ............................................................................... 30

E. Ecological Effects ......................................................................................................... 51

F. Analysis Plan ................................................................................................................ 78

G. Preliminary Identification of Data Gaps ....................................................................... 87

H. Effects ....................................................................................................................... .... 91

I. Other Information Needs .............................................................................................. 96

APPENDIX A. References ...................................................................................... 98 Appendix B: Submitted Environmental Fate an d Ecological Studies for the Registration

of Chlorothalonil ..................................................................................................... 100

APPENDIX C: Environmental Fate Studies Kinetic Analyses .......................... 124

APPENDIX D: DCI Justification Tables .............................................................. 133 APPENDIX E: SIP Input and Output .................................................................. 144 Appendix F: Stir Input and Output ...................................................................... 146

### 3 I. PURPOSE

The purpose of this problem formulation is to pr ovide the status of the environmental fate and ecological effects of chlorothalonil based on curr ently registered uses. This document provides a plan for analyzing data relevant to chloro thalonil and for conducting environmental fate, ecological risk, endangered species and drinking water exposure assessments for its registered uses. Additionally, this problem formulation is intended to identify data gaps, uncertainties and potential assumptions used to address those uncertainties relative to characterizing the environmental fate and ecological risk associated with the registered uses of chlorothalonil.

II. PROBLEM FORMULATION

A. N ATURE OF 

### R EGULATORY 

### A CTION



### Under the Federal Insecticide, F ungicide, and Rodenticide Act (FIF RA), all pesticid es distributed

or sold in the United States generally must be registered by the Environmental Protection Agency (EPA, or ‘the Agency’). In determini ng whether a pesticide can be registered in the United States, EPA evaluates its safety to non-target species based on a wide range of

environmental and health effects studies. In 1996, FIFRA was amended by the Food Quality Protection Act (FQPA), and the Agency was mandated to implement a new program for the periodic review of pesticides, i.e. , registration review. 1 

### The Registration Review program is intended to ensure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse

effects to human health and the environment. Ch anges in science, public policy and pesticide use practices will occur over time. Through the new Registration Review program, the Agency periodically reevaluates pesticides to make sure that as change occurs, products in the marketplace can be used safely.

As part of the implementation of the Registratio n Review program pursuant to Section 3(g) of FIFRA, the Agency is beginning its evaluation of chlorothalonil to determine whether it

continues to meet the FIFRA standard for re gistration. This problem formulation for the environmental fate, ecological ri sk, endangered species and drinki ng water assessment chapter in support of the registration review will be poste d in the initial docket which will open the public phase of the review process. This problem formulation considers all current and active registrations for chlorothalonil.

Problem formulations provide a strategic framew ork for the risk assessment. By identifying the important components of the proble m, it focuses the assessment on the most relevant life history stages, habitat components, chemical properties, exposure routes and endpoints. The structure of this risk assessment is based on guidance containe d in U.S. EPA’s Guidance for Ecological Risk Assessment (U.S. EPA 1998a), the Services’ Endangered Species Consultation Handbook (U.S. FWS/NMFS 1998) and is consistent with proced ures and methodology outlined in the Overview Document (U.S. EPA, 2004) and reviewed by th e U.S. Fish and Wildlife Service and National Marine Fisheries Service (U.S. FWS/NMFS 2004).

1 (http://www.epa.gov/oppsrrd1/registration_review/)

### 4 B. P REVIOUS 

### A SSESSMENTS



### Ecological Risk Assessments

Chlorothalonil has a long regulat ory history, and a number of ecol ogical risk assessments have been completed. Risk to non-target organism s was evaluated for conventional uses of chlorothalonil as part of the Re-registrati on Eligibility Decision (RED) in April 1999. A quantitative ecological risk assessment was not pe rformed for antimicrobial chlorothalonil uses at the time of the RED because the Agency did no t anticipate any exposure of concern to fish, wildlife, and/or endangered species based on the registered use patterns; furthermore, discharge to the environment complied with all Federal disp osal laws and NPDES. For registration review, the Agency anticipates the need to conduct a co mprehensive ecological risk assessment for both

conventional and antimicrobial uses of chlorothalonil.

For conventional pesticide uses in the 1999 RE D document, exceedances of the Agency’s presumptive level of concern (LOC) values in cluded exceedances for birds, mammals, fish, aquatic invertebrates and aquatic plants. According to the RED, as part of the outlined ecological risk mitigation measures for conventional uses, th e chlorothalonil registrants agreed to revise their product labels to include maximum individual applica tion rates, minimum application intervals, and maximum seasonal application rate s. Additionally, the registrants agreed to include a requirement for untreated buffers between treated agricultural fields and marine/estuarine water bodies (150 ft for aeria l and air-blast applica tions and 25 ft for ground applications).

As part of a recent “me-too” registrati on for turf and ornamentals (DP328075, 220223, 301503, 301500; June 2006), new data were submitted that indi cated greater toxicity of chlorothalonil to birds and daphnids than the data used in the 199 9 RED. Additionally, ecological risk assessments for IR-4 uses on multiple crops ( e.g ., fruiting vegetables, cucurbit vegetables, okra, persimmon, horseradish, rhubarb, ginseng, yams , lupine, lentils, brassica head and stem vegetables) have been conducted since the 1999 RED. The potential risks identified from the new uses were similar to those previously reported in the RED.

In October 2007, the Agency completed an assessment of the potential direct and indirect effects

of conventional uses of chloro thalonil to the California red-le gged frog (CRLF) and potential modification to designated critical habitat from uses of chlorothalonil. Based on the information available at that time the Agency made a May Affect and Likely to Adversely Affect determination for the CRLF from the use of chlorothalonil. Additionally, the Agency determined that there is the potential for modification of CRL F designated critical habitat from the use of

chlorothalonil.

According to the 1999 RED document for chloro thalonil, the 1984 Regist ration Standard for chlorothalonil required that levels of hexach lorobenzene (HCB), an impurity in technical chlorothalonil, be at or below 0.05%. Certificatio n of HCB levels was required in the RED. Additionally, there was a 1987 Data Call-In (DCI) to identify and indicate the amount of other known impurities in tech nical chlorothalonil ( i.e ., dioxins and dibenzof urans) via revised Confidential Statements of Formula (CSFs). At the time of the RED, these data were still outstanding. These impurities have not been c onsidered in past ecological risk assessments;

### 5 however, they will be considered in the ecological risk assessment conducted for chlorothalonil as part of the Registration Review process.

After reviewing the previous risk assessments, modifications to the risk analyses are expected during the Registration Review Pro cess. These changes are expected to be due, in part, to an evolution of Agency policy, exposure model devel opment, and additional data requirements. For example, the environmental fate and ecological t oxicity data were reeval uated as part of the problem formulation phase of the Registrati on Review process and changes in guideline standards and policies or in some cases the st udy reevaluation and inte rpretation of the study

resulted in the selecti on of different endpoints.

Drinking Water Exposure Assessments

Several drinking water assessments (DWAs) have b een completed for chlorothalonil. As part of the 1999 RED, a drinking water exposure assess ment was completed for conventional uses. A DWA exposure assessment was not performed specifi cally for antimicrobial chlorothalonil uses at the time of the RED because the Agency did not anticipate any exposure of concern based on the registered antimicrobial use patterns and that discharges to the environment complied with all Federal disposal laws and NPDES.

The 1999 RED drinking water exposure assessment performed included a review of groundwater and surface water monitoring data and was base d on these data. Model simulations were not performed or used for the drinking water exposure assessment. 2 

### The Agency used groundwater monitoring data [a 16 μg/L combined concentr ation of four environmental transformation products: 3-carbamoyl-2,4,5-trichlorobenzoi c acid (SDS-46851), 3-cyano-6-hydroxy-2,4,5- trichlorobenzamide (SDS-47525) , 4-hydroxy-2,5,6-trichloro-1,3-dicyanobenzene (SDS-3701), and 3-cyano-2,4,5,6-tertachlorobenzamide (SDS- 19221)] from New York to represent the potential exposure to chloroth alonil and other potentially to xic transformation products.

Since the RED, several drinking water assessmen ts have been completed for chlorothalonil. These assessments have utilized Tier I groundw ater and Tier II surface water modeling for estimating exposure to chlorothalonil and its tr ansformation product of toxicological concern, SDS-3701. Monitoring data have also been consider ed in these assessments; however, these data have not been recommended for use in the Human Health Assessment. The monitoring data was not recommended for use because: 1) the mon itoring data do not sp ecifically target chlorothalonil; 2) the number of samples taken at an individual site during a one year period is limited; 3) the reported data are several years old and may not accurately reflect current use patterns; and 4) available mon itoring data do not include degr adates, and, therefore, do not capture the potential exposure risk to total t oxic chlorothalonil residue s. In support of the 2010 IR-4 registration of chloroth alonil (Bravo Weather Stick®, 54 %) new uses on bulb vegetables, bushberries and low growing berries , a DWA was completed (DP 370488). 3 

### This recent

2 Frankenberry, M. Craqven, H. Clem, A. Wolf, J. Ne lson, H. EFED RED Science Chapter for Chlorothalonil, October 20, 1997 DP Codes 224421, 226857, 229496, 229499, 237908, 237908

3 R. Bohaty, Drinking Water Assessment for the IR-4 Registration of Chlorothalonil (Bravo Weather Stick ® , 54%) and the Degradation Product, 4-Hydroxy-2,5,6-trichloro-1,3-dicyanobenzene (SDS-3701) for the New Uses On: Bulb Vegetables, Bushberries, and Low Growing Berries (PC Code: 081901; DP Barcode: 370488)

### 6 assessment determined that chlorothalonil uses on horseradish, which was previously determined (DP 346321) 4 

### to result in the most conservative estimated drinking water concentrations (EDWCs) of all chlorothalonil uses, was still th e use that resulted in the most conservative EDWC (1 in 10 year peak concentration of 316 μg /L based on Tier II surface water modeling) of all currently registered uses of chlorothalonil. Past DWAs completed fo r chlorothalonil uses on turf also yielded very high EDWCs; however, turf application rates have been reduced in recent years reducing the corresponding EDWCs.

C. S TRESSOR 

### S OURCE AND 

### D ISTRIBUTION



### Chlorothalonil (2,4,5,6-tetrachlo roisophthalonitr ile; CAS 1897-45-6) is a broad spectrum, nonsystemic pesticide. Chlorothalonil is mainly used as a fungicide to control fungal foliar diseases of vegetable, field, and ornamental crops; however, chlorothalonil is also registered for use as an industrial and consumer wood pres ervative, a fungicida l/mildewcidal/algicidal paint, stain, and coating film preservative, and a material preser vative paper and paperboa rd (non-food contact)

and for the “in-service” life of caulks and s ealants, adhesives, grouts and joint compounds, wallboard, stucco. The chemical struct ure of chlorothalonil is provided in Figure 1

. Table 1 includes chemical identification and physical chemical properties of chlorothalonil.

Figure 1. Chemical Structure of Chlorothalonil

Table 1. Chemical Identification Information for Chlorothalonil

Parameter Value Source/Classification (Comments)

Chemical Name 2,4,5,6-tetrachlor oisophthalonitrile ChemDraw Ultra

Chemical Abstracts Service

(CAS) Registry Number 1897-45-6 CAS Registry

Molecular Formula C 8 Cl 4 N 2 ChemDraw Ultra USEPA Pesticide Code (PC #) 081901 Not applicable Smiles Notation C1(=C(C(=C(C(=C1Cl)C#N)Cl)Cl)Cl)C#N Pubchem Molecular Mass 265.9 g/mol ChemDraw Ultra

Melting point 250-251°C MRID 42354608, Acc. No.

143749

Boiling point 350°C (760 mmHg) MRID Nos. 42354608, Acc.

No. 143749

Density Specific Gravity 1.8 g cm − 3 , solid 1.8 at 25 deg C/4 deg C Relative density (water = 1): 1.8 MRID 40047601

Dissociation Constant in Not applicable Chlorothalonil is a neutral

4 L. Shanaman, Drinking Water Assessment for the IR-4 Registration of Chlorothalonil (Bravo Weather Stick ®

, 54%) and the Degradation Product, 4-Hydroxy-2,5,6-trichloro-1,3-dicyanobenzene (SDS-3701) for the New Uses on: Fruiting Vegetables, Cucurbit Vegetables, Okra, Persi mmon, Horseradish, Rhubarb, Ginseng, Yam, Lupine, Lentils and Brassica Head and Stem Vegetables (PC Code: 081901; DP Barcode: 346321). Cl

Cl Cl Cl N

N

### 7 Water molecule that does not dissociate to ionic species in aqueous solution.

MRID 42354608, Acc. No.

143749

Vapor Pressure 5.72 x 10 -7 torr (25 °C)

2.65 x 10 -6 torr (35 °C)

2.65 x 10 -5 torr (45 °C) Acc. No. 259753 scientifically valid

Water Solubility 0.8-0.96 mg/L 1999 RED Henry’s Law Constant 2.6 x 10 -7 atm - m 3 /mol 1999 RED Log K

ow 3.8 (Kow = 6277) 1999 RED



### The manufacturing processes for chlorothalonil ar e known to result in im purities including: hexachlorobenzene (HCB), polychlorinated dioxins (D), and dibenzofurans (F), as well as other possible organochlorine contaminants. These ch emicals have been found in technical grade chlorothalonil, as well as formulated chlorothal onil products; however, th e levels are low (39 ng DF/g a.i.). 5 

### Formulation documentation confirms low le vels of HCB in currently registered chlorothalonil products; however, there is no informati on provided on the other types of

contaminants mentioned above.

Several environmental transformation products of chlorothalonil are known including the major transformation products: SDS-3701, SDS-46851, 3- cyano-2,4,5-trichlorobenzamide (SDS47523), 2-amido-3,5,6-trichloro-4- cyanobenzenesulfonic acid (R417888), sodium 2,4-bis-amido3,5,6-trichlorobenzenesulfonate (R471811), 4-amindo-2,5-dichloro-6-cyanobenzene-1,3- disulphonic acid (R419492), 5-cy ano-4,6,7-trichloro-2H-1,2-benzis othiazol-3-one (SDS-67042), 2,5,6-trichloro-1,3-dicyanobenzene-4-sulphonate , trichloro-1,3-dicyanobenzene and 2,5,6- trichloro-4-(glutathio-S-yl)isophthalonitrile (SDS-66382). There are also numerous minor transformation products. Additional discussion of the formation of chlorothalonil transformation products in the environment is provided in the En vironmental Fate and Tran sport section of this

document.

The only transformation product previously cons idered of toxicological concern is SDS-3701.

This metabolite is also known to form under various laboratory test conditions , as well as in the

environment. The chemical struct ure of SDS-3701 is provided in Figure 2 . Given that there are uncertainties in the fate profile for chloroth alonil regarding the poten tial for degradates/ transformation products, if additional information becomes available, the evaluation of chlorothalonil and any transformation products deem ed to be of toxicological concern will be evaluated during the risk assessment phase of the Registratio n Review process by incorporating the total toxic residue appro ach when deriving aquatic a nd terrestrial environmental

concentrations. See Table 2 for the fate properties of SDS-3701.

5 Holt. E.; Weber, R.; St evenson, G.; Gaur, C. Environ. Sci. Technol. 2010, 44 , 5409-5415. Cl

OH Cl Cl N

N

### 8 Figure 2. Chemical Structure of SDS-3701, 4-hydroxy-2,5,6-trichloro-1,3-dicyanobenzene

Table 2. Chemical Identification Inform ation for SDS-3701, 4-hydroxy-2,5,6-trichloro-1,3- dicyanobenzene

Parameter Value Source/Classification (Comments)
Chemical Name 4-hydroxy-2,5,6-trichloro-1,3-dicyanobenzene ChemDraw Ultra

Chemical Abstracts Service (CAS) Registry Number 28343-61-5 CAS Registry

Molecular Formula C 8 Cl 3 N 2 OH ChemDraw Ultra USEPA Pesticide Code Not applicable -- Smiles Notation C1(=C(C(=C(C(=C1Cl)C#N)O[H])Cl)Cl)C#N Pubchem Molecular Mass 247.5 g/mol ChemDraw Ultra

Vapor Pressure (25 °C) 6.1 x 10 -7 mm Hg Modified Grain Method EPI Suite (v4.00)

Water Solubility 88 mg/L (fragment estimate) v1.01 EPI Suite (v4.00)

Henry’s Law Constant 2.2 x 10 -11 atm/m 3 /mol (bond method)

2.8 x 10 -11 atm/m 3 /mol (group method) EPI Suite (v4.00)

Log K

ow 3.1 WSKOW v1.41 EPI Suite (v4.00)



### EPA does not routinely include in its risk assessments an evaluati on of active ingredient mixtures - either mixtures of multiple ac tive ingredients in product formulations or an applicator tank mix. In the case of the product formulations of active ingredients (a.i.) (that is, a registered product containing more than one active ingredient), each active ingredient is su bject to an individual risk assessment for regulatory decision-making rega rding the active ingredie nt on a particular use

site. If effects data are ava ilable for a formulated product co ntaining more than one active ingredient, and demonstrate potentially enhan ced toxicity to a non-ta rget organism from exposure to the multiple a.i.’s, these data may be used qualitatively or quantitatively in accordance with the Agency’s Overview Docume nt and the Services’ Evaluation Memorandum (U.S., EPA 2004; USFWS/NMFS 2004, respectively) for risk assessment purposes.

There are 34 registered end-use products that contain multiple active ingredients, including chlorothalonil (see Table 3 ). Acute oral mammalian LD 50 

### data for multiple active ingredient end-use products which can be e xpressed as chlorothalonil relative to the single active ingredient are available for several of the multi-active ingredient formulations. These data, along with other data available on chlorothalonil mixtures, will be considered in the risk assessment conducted for the chlorothalonil regi stration review.

### 9 Table 3. Conventional and Antimicrobial Ch lorothalonil Formulated Products that Contain More than One Active Ingredient

Product EPA Registration

Number % Active Ingredient (PC Code)

RIDOMIL GOLD BRAVO 100-800 72% Chlorothalonil (081901) 4.5% Metalaxyl-M (113502)

QUADRIS OPTI 100-1171 46% Chlorothalonil (081901) 4.6% Azoxystrobin (128810)

TILT BRAVO SE 100-1192 38.5% Chlorothalonil (081901) 2.9% Propiconazole (122101)

RIDOMIL GOLD BRAVO SC 100-1221 33.1% Chlorothalonil (81901) 3.3% Metalaxyl-M (113502)

INSTRATA 100-1231 1.2% Fludioxonil (071503) 29.9% Chlorothalonil (081901) 4.7% Propiconazole (122101)

REVUS OPTI 100-1279 3.3% Mandipropamide Technical 0(36602) 33.3% Chlorothalonil (081901)

RENOWN FUNGICIDE 100-1315 45% Chlorothalonil (081901) 3% Azoxystrobin (128810)

CONCERT II (FUNGICIDE) 100-1347 38.5% Chlorothalonil (081901) 2.9% Propiconazole (122101)

DACONIL ACTION 100-1364 0.1% 1,2,3-Benzothiadiazole-7-carbothioic acid, S-methyl ester (06140 2)

53.9% Chlorothalonil (081901)

NUFARM TM + CTN SPC 66.6

WDG FUNGICIDE 228-638 50% Chlorothalonil (081901) 16.7% Thiophanate-methyl (102001)

TM + CTN E-PRO 90 WDG

FUNGICIDE 228-639 72% Chlorothalonil (081901) 18% Thiophanate-methyl (102001)

RESERVE FUNGICIDE 432-1486 40% Chlorothalonil (081901) 5% Triticonazole (125620)

CUPRINOL STAIN AND

WOOD PRESERVATIVE 577-544 0.7% Chlorothalonil (081901) 0.3% Bis(tributyltin) oxide (083001)

SPECTRO 90 WDG 1001-72 72% Chlorothalonil (081901) 18% Thiophanate-methyl (102001)

NEXGEN 1022-583 14.7% Methylene bis(th iocyanate) (068102) 14.5% Chlorothalonil (081901)

DENSIL CA 1258-1270 47% Chlorothalonil (081901)

6% N-Cyclopropyl-N'-(1,1-dimethylethyl)-6- (methylthio)-1,3,5-triaz ine-2,4-diamine (128996)

FUNGITROL 2010 1529-47 20.1% Chlorothalonil (081901) 10.1% 3-Iodo-2-propynyl butylcarbamate (107801)

FUNGITROL 2002 1529-48 48% Chlorothalonil (081901)

5.9% N-Cyclopropyl-N'-(1,1-dimethylethyl)-6- (methylthio)-1,3,5-triaz ine-2,4-diamine (128996)

HELENA BRAVO S 5905-472 27.3% Sulfur (077501) 19.2% Chlorothalonil (081901)

THE ANDERSONS 3-WAY

SNOW MOLD FUNGICIDE 9198-227 7.5% Benzene, pentachloronitro- (056502) 3.9% Chlorothalonil (081901) 0.6% Propiconazole (122101) TERRANIL S 9779-337 27.3% Sulfur (077501)

### 10 Product EPA Registration

Number % Active Ingredient (PC Code)

19.2% Chlorothalonil (081901)

CONSYST WDG 48234-7 50% Chlorothalonil (081901) 16.7% Thiophanate-methyl (102001)

FLOURONIL FUNGICIDE 55146-81 72% Chlorothalonil (081901) 4.4% Metalaxyl-M (113502)

ANTIBLU MC-30 62190-30 14.7% Methylene bis(thiocyanate) (068102) 15.5% Chlorothalonil (081901)

DISARM C FUNGICIDE 66330-379 2.4% Fluoxastrobin (028869) 38.4% Chlorothalonil (081901)

ACTICIDE PM 67071-2 19% Diuron (035505) 14.7% Chlorothalonil (081901)

ACTICIDE PM FLOWABLE 67071-15 19% Diuron (035505) 14.7% Chlorothalonil (081901)

ACTICIDE SR-1216/6 67071-17 19% Diuron (035505) 8.8% Chlorothalonil (081901) 6% Octhilinone (099901)

THOR GMBH ACTICIDE PAX 67071-39 19% Diuron (035505) 11.8% Chlorothalonil (081901) 6% Octhilinone (099901)

MONCUT CL FLOWABLE 71711-2 38.6% Chlorothalonil (081901) 10.3% Flutolanil (128975)

NAI-301 4 SE FUNGICIDE 71711-24 21.7% Chlorothalonil (081901) 1.8% Propiconazole (122101) 17.2% Flutolanil (128975)

INTACE FUNGICIDE B-6773 74075-1 28.3% Chlorothalonil (081901) 12.1% p-Tolyl diiodomethyl sulfone (101002)

PEREGRINE 81943-7 50% Chlorothalonil (081901) 16.7% Thiophanate-methyl (102001)

TEE-1 UP WDG FUNGICIDE 83070-2 50% Chlorothalonil (081901) 16.7% Thiophanate-methyl (102001)



### Pesticidal Mechanism of Action

Chlorothalonil acts on mold, mildew, stain, and ro t-causing fungi, staining and disfiguring algae, bacteria and microbes. Chlorothalonil targets multiple sites of the fungal pathogen upon contact (FRAC, 2011) affecting various enzymes and other metabolic pr ocesses in fungi; however, the

exact mechanism of action is unknown. Chlorothaloni l is believed to combin e with glutathione in fungal cells tying up available glut athione. It inhibits spore germ ination, and is toxic to fungal cell membranes. Unlike many other fungicides, ch lorothalonil resistance ha s not been reported. The mode of action for algae and bacteria is unknown.

Overview of Pesticide Use and Usage

Conventional use registrations of chlorothalonil consist of use on a variety of terrestrial food and feed crops, terrestrial non-food crops, and gr eenhouse food/non-food crops. Antimicrobial use registrations of chlorothalonil permit its use as an industrial and consum er wood preservative, a materials preservative, and as a fungicide/mildewcide/a lgaecide paint, stain, and coating film preservative. Chlorothalonil is formulated in so lid form as dust, water dispersible granules,

### 11 pellets, tablets, and as a wettable powder. In liquid form, chlorothalonil is available as an emulsifiable, flowable, and soluble concentr ate as well as a ready-to-use solution.

For conventional uses chlorothaloni l is used as a preventative trea tment and it is applied either by aerial or ground equipment, and can be used in tank mixes. A summary of the conventional pesticide agricultural and non-agri cultural uses of chlorothalon il is provided in the sections below based on information from the Biologi cal and Economic Analysis Division (BEAD). 6


### Total chlorothalonil use is estimated to be approximately 13.5 million pounds per year.

For antimicrobial uses, chlorothalonil is also used as a preventative treatment. It can be applied

to wood either at the industrial scale by dipping, sprayi ng or pressure treatment and for consumer products (paints, stains and co atings) by hand spray or brush. Ch lorothalonil is also mixed or blended into materials ( e.g ., paints, stains, stucco, adhesives, caulk) using a variety of methods depending upon the material. For the most pa rt these are blended at the industrial or manufacturing scale, the exception is post-ma nufacturing paint additive products. There are wood preservative stains and coatings for use by professionals or the public which can be handspray, brush or pad applied. Similarly there are exte rior and interior film preservatives (paints, stains and coatings) which can be applied to a variety of surface material s including wood, metal, masonry, and concrete by professi onals or the public by hand-spr ay, brush or pad. A summary of

the antimicrobial uses is available in the Summary of Registered Antimicrobial Uses of Chlorothalonil in Support of the Re gistration Review Summary Document available in the

docket.

Agricultural Uses

Chlorothalonil is labeled for use on hundreds of te rrestrial food crops incl uding: almond, apricot, asparagus, banana, bean (dry), bean (snap, succulent ), broccoli, Brussels sprouts, cabbage, carrot, cauliflower, celery, cherry (sweet and tart), co coa bean, coffee bean, corn (sweet), cucumber, ginseng, horseradish, lentils, l upine, mango, melon, mushroom, nect arine, okra, papaya, parsnip (root), passion fruit, pea (edi ble-podded), peach, peanut, persimm on, pistachio, plum (fresh and prune), pumpkin, rhubarb, soybean, squash (summe r and winter), tomato and yam, and bulb vegetables.

Based on private market pesticide usage data from 1998-2010, the annual to tal agricultural usage averaged approximately nine million pounds for eight million treated acres. For these same years, the largest markets in te rms of total pounds active ingredie nt applied are peanuts (37%), potatoes (26%) and tomatoes (8%). The crops with the most total area treated (total land) are peanuts (42%), potatoes (31%) and tomatoes (6 %). The maximum percent cropped area treated for chlorothalonil is for peanuts (80%), celery (70 %), tomatoes (70 %) and watermelons (65%). 7



### The agricultural use of chlorothalonil in the lower 48 states is shown in Figure 3 . The map was prepared by BEAD based on private market survey s (proprietary source) of pesticide use in

6 Yourman, L.; Alsadek, J.; Ranville, M.; BEAD Chemical Profile for Registration Review: Chlorothalonil (089101) Oct. 25, 2011

7 USDA-NASS 2001-2008; private pesticide market research 2001-2008; and California Department of Pesticide Regulation 2000-2009.

### 12 agriculture for 2006-2010 at the Crop Reporting District (CRD) level. 8 

### CRDs are boundaries created by USDA NASS which ar e aggregates of counties. 9 

### The map reveals intensive agricultural use in Michigan, Maine, Long Island (New York) and the Southeast (Florida, Georgia and Mississippi). The states with the mo st agricultural usage were on average Georgia (25%), Florida (13%), California (9%), Michigan (8%) and Alabama (7%). The survey data are limited to the states that represent the top 80-90 % of acreage for the individual crops; therefore, use may be occurring in regions outside the scope of th e survey. Pesticide usage is displayed as average pounds (for the years 2006-2010) per 1,000 acres of farmland in a CRD to normalize for

the variation in farmland between CRDs. Farmland acreage was obtained from USDA. 10 

### The map is an illustration of a snapshot in time of chlorothalonil use for agricultural purposes and

does not include non- agricultural uses.

Figure 3. Agricultural Use Pattern Summary for Chlorothalonil

Conventional Non-Agricultural Uses

Non-agricultural use sites include golf courses, lawn s around commercial and industrial buildings, and other turfgrass such as professional and collegiate at hletic fields. Chlorothalonil is also registered for home garden use on fruit a nd vegetables. Of these us es, chlorothalonil use is highest on golf courses, at approximately three million pounds per year. A large amount of chlorothalonil is also used by consumers ( i.e. , residential use). On average consumers use

8 Kaul, M. Chlorothalonil Usage Map by Crop Repo rting District, October 26, 2011 (via email)

9 USDA, 2006-2010. NASS Crop Reporting Districts. Online: http://www.ers.usda.gov/briefing/arms/res ourceregions/resourc eregions.htm#nass.

10 USDA, 2007. Census of Agriculture. Online: http ://www.agcensus.usda.gov/Publications/2007/index.asp.

### 13 approximately one million pounds of chlorothalonil per year. Usage data for 2002, 2004 and 2006 suggest the use of chlorothal onil is increasing on institu tional turf while nursery and greenhouse use is going down. In total, the average yearly non-agricultural use of chlorothalonil is approximately 4.5 million pounds per year. This statistic also includes turf farms which for analysis purposes were consider ed non-agricultural use.

Antimicrobial Non-Agricultural Uses

Chlorothalonil is used as a material preser vative for wood products used in making wood composites. It is mixed into wood stains, pain ts, and coatings; exterior aqueous- and solventbased paints, stains, and coatings as film preservatives and mixed into aqueous-based adhesives, stucco, grouts and joint compounds, aqueous-bas ed caulks and sealants as an antimildew/ antimold surface protectant. It is also used as an industrial wood preservativ e both as an additive to dip, spray, and pressure treatment solutions and independently as a sa pstain preventative in freshly sawn lumber and timber as well as mold control on previously pressure treated wood products. The pressure treatment use of chlorothal onil is carried along with previously registered chromate copper arsenate (CCA) mixture solutio n. Industrial scale wood pr eservative is applied by dipping, spraying or pressure treatment. Treat ed wood types includes timber, utility poles, crossarms, crossties, posts, pi lings, construction timbers, lumb er and wood products such as particle board, fencing, decking, building siding, and shingles. Chlorothalonil is also mixed or blended into a variety of materials ( e.g ., paints, stains, stucco, adhesi ves, caulk) using a variety of methods depending upon the material. For the most part these are blended at the industrial or manufacturing scale, the exception is post-ma nufacturing paint additive products. There are wood preservative stains and coatings for use by professionals or the public which can be hand spray, brush or pad applied. Similarly there are exte rior and interior film preservatives (paints, stains and coatings) which can be applied to a variety of surface material s including wood, metal, masonry, and concrete by professi onals or the public by hand spra y, brush or pad. The pressure

treatment use of chlorothalonil is carried along with previously registered chromate copper arsenate (CCA) mixture solution.

Label Application Rates and Intervals

Chlorothalonil labels may be categorized into two types: labels for manufacturing uses (including technical grade chloro thalonil and its formulated products) and end-use products. While technical products are not used directly in the environment, they are used to make formulated products. A complete list of all cu rrent conventional chloro thalonil uses and how EFED currently understands them, including the un certainties for which reasonable conservative assumptions will be made in the absence of additional label information, are listed in Table 4

. Table 5 summarizes the antimicrobial registrations of chlorothalonil as currently understood by

AD.

For some uses, there are different label restrict ions for agricultural and non-agricultural use labels for the same crop; these differences are also highlighted in Table 4 as appropriate. The

final risk assessment will be based on the labe led uses (maximum single and yearly application rates and minimum retreatment intervals) at the time the assessment is conducted and are considered part of the federal action reflecting the current labe led uses of chlorothalonil.14Table 4. Chlorothalonil Conventional Pesticide Use Label Summary*Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)CommentsALMOND:air/groundHull split, petal fall, popcorn to fullbloom, postharvest, bud break,foliar3.0 18.8 NS [61] NS [32]- If 6 applications at 3.0lb a.i./acre were made, anadditional application of 0.8 lb a.i./acre could bemade in that year to reach the 18.8 lb a.i./acreannual maximum application rate.- Geographic disallowable: CA- 150 day(s) preharvest interval.- 42 day(s) preharvest interval.APRICOT:air/groundHull split, petal fall, popcorn to fullbloom, postharvest, bud break,foliar, delayed dormant, dormant,established plantings, late fall, pinkthrough petal fall, popcornNS [3.14] NS [15.5] NS [51] NS [10]- The application information is from 50534-201- For ECHO® RTU (EPA Reg. No. 60063-30) thelabel does not specify a single max or annual maxapplication rate for the following use sites: Peach,nectarine, apricot, cherry, plum, and prune. Theapplication rate for these uses is provided as follows- “Apply full coverage spray to the point of runoffto thoroughly cover tree canopy includingundersides of leaves.”- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.ASPARAGUS:air/GroundEarly bloom, post-final harvest,postharvest3.0 9.0 NS [31] 14- Buffer zone restriction.- Geographic disallowable: AZ, CA- 120 day(s) preharvest interval.- 190 day(s) preharvest intervalBANANA:air/ground (not specified); foliar2.7 30.0 NS [111] 10-If 11applications at 2.7 lb a.i./acre were made, anadditional application of 0.3 lb a.i./acre could bemade in that year to reach the 30.0 lb a.i./acreannual maximum application rate.- Geographic allowable: PR- Max application rate is provided for each cropcycle (not per year)BEANS, DRIED-TYPE:1.5 6.0 NS [41] 7 - Buffer zone restriction.15Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/ chemigation /groundEarly bloom through foliar, Earlybloom, Foliar- Geographic disallowable: CA- 14 day(s) preharvest interval.- 42 day(s) preharvest interval.BEANS, SUCCULENT (SNAP):air/groundEarly bloom through foliar2.3 9.0 NS [41] 7-If 4 applications at 2.3 lb a.i./acre were made, itwould result in 0.2 lb a.i./acre over the 9.0 lba.i./acre annual maximum application rate.- Buffer zone restriction.- 2.5 lb/a (residential) 60063-16- 7 day(s) preharvest interval.BEANS:air/ground (not specified)Early bloom, when needed0.2034 0.2034 NS [11] 7- Max application rate is provided per ‘season’ notper year.- 7 day(s) preharvest interval.BULB VEGETABLES:air/chemigation/groundFoliar1.2 5.0 NS [41] 7-If 4 applications at 1.2 lb a.i./acre were made, anadditional application of 0.2 lb a.i./acre could bemade in that year to reachthe 5.0 lb a.i./acre annualmaximum application rate.BLUEBERRY:air/groundAt bud break, Delayed dormant,Post-final harvest, Postharvest3.0 9.0 NS [31] 10- Buffer zone restriction.- Geographic allowable: FL, GA, MS- Geographic disallowable: AZ, CA- 42 day(s) preharvest interval.BRASSICA (HEAD ANDSTEM):air/chemigation/groundFoliar, Postemergence,Posttransplant, Transplant, Whenneeded1.58.8NS [61]7- Labels differ on the maximum single andmaximum annual application rate allowed;therefore, rates associated with the maximum singleand maximum annual application rate are provided.- If 6 applications at 1.5 lb a.i./acre were made, itwould result in 0.2 lb a.i./acre over the 8.8 lba.i./acre annual maximum application rate.1.1 10.5 NS [91]BROCCOLI, CHINESE:air/chemigation/groundFoliar, Postemergence, Transplant1.5 12.0 NS [81] 7- Buffer zone restriction.- 7 day(s) preharvest interval.BROCCOLI:1.5 12.0 NS [81] 7 - 7 day(s) preharvest interval.16Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundFoliar, Postemergence,Posttransplant, Transplant, WhenneededBRUSSELS SPROUTS:air/chemigation/groundFoliar, Postemergence,Posttransplant, Sprout, Transplant,When needed1.5 12.0 NS [81] 7- Buffer zone restriction.- Geographic allowable: CA (Foliar andPostemergence)- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.CABBAGE, CHINESE:air/chemigation/groundFoliar, Postemergence,Posttransplant, Transplant, WhenneededFoliar1.5 12.0 NS [81] 7- Buffer zone restriction.- 7 day(s) preharvest interval.CABBAGE:air/chemigation/groundFoliar, Postemergence,Posttransplant, Transplant, Whenneeded1.5 12 NS [81] 7- Buffer zone restriction.- 7 day(s) preharvest interval.CARROT (INCLUDINGTOPS):air/chemigation/groundFoliar, When needed1.5 15 NS [101] 7- Geographic disallowable: CA- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.CAULIFLOWER:air/chemigation/groundFoliar, Postemergence,Posttransplant, Transplant, Whenneeded1.5 12 NS [81] 7- Buffer zone restriction.- 7 day(s) preharvest interval.CELERY:2.3 18.0 NS [81] 3 - If 8 applications at2.3 lb a.i./acre were made, it17Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundAt planting, Foliar, Postemergence,Posttransplant, Seed bed,Transplantwould result in 0.4 lb a.i./acre over the 18.0 lba.i./acre annual maximum application rate.- Buffer zone restriction.- 7 day(s) preharvest interval.CHERRY:air/groundBloom, Delayed dormant,Dormant, Established plantings,Foliar, Pink through petal fall,Popcorn to full bloom, Popcorn,PostharvestNS [4.2] NS [15.5] NS [31] 7- Not all of the labels for this use specify a maxsingle or max annual application rate. For example,the label for ECHO® RTU (EPA Reg. No. 60063-30) does not specify a single max or annual maxapplication rate for the following use sites: Peach,nectarine, apricot, cherry, plum, and prune. Theapplication rate for these uses is provided as follows- “Apply full coverage spray to the point of runoffto thoroughly cover tree canopy includingundersides of leaves.”- If 3 applications at 4.2lb a.i./acre were made, anadditional application of 2.9 lb a.i./acre could bemade in that year to reach the 15.5 lb a.i./acreannual maximum application rate.- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.CHRISTMAS TREEPLANTATIONS:air/groundNurserystock, Before budbreak,After bud break,4.216.5NS [41]NS [32]- If 3 applications at 4.5lb a.i./acre were made, anadditional application of 3.0 lb a.i./acre could bemade in that year to reach the 16.5 lb a.i./acreannual maximum application rate.4.5 NS [31]COLE CROPS:air/chemigation/groundFoliar1.0 12.0 NS [121] 17- No commentCOMMERCIAL/INDUSTRIAL11 26.0 NS [21] NS [32] - If 2 applications at 11lb a.i./acre were made, an18Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)CommentsLAWNS:chemigation/groundfoliar, late fall, fall, at seeding, latewinteradditional application of 4.0 lb a.i./acre could bemade in that year to reach the 26 lb a.i./acre annualmaximum application rate.CONIFERS(PLANTATIONS/NURSERIES):air/chemigation/groundNurserystock, Before budbreak,After bud break, Spring, Seed bed4.5 16.5 NS [31] NS [32]- If 3 applications at 4.5lb a.i./acre were made, anadditional application of 3.0 lb a.i./acre could bemade in that year to reach the 16.5 lb a.i./acreannual maximum application rate.CORN (UNSPECIFIED):air/groundFoliar, Seed crop1.5 9 NS [61] 7- Application information is from 50534-188- Buffer zone restriction.- 14 day(s) preharvest interval.CORN, SWEET:air/groundFoliar, Seed crop, When needed1.5 9.0 NS [61]74 (for as neededlow rate)- Buffer zone restriction.- 14 day(s) preharvest interval.- 7 day(s) preharvest interval.CRANBERRY:air/chemigation/groundEarly bloom through foliar, Earlybloom, Foliar, Prebloom5.3 15.1NS [31]10- If 3 applications at 5.3 lb a.i./acre were made, itwould result in 0.8 lb a.i./acre over the 15.1 lba.i./acre annual maximum application rate.- Buffer zone restriction.- Geographic disallowable: AZ, CA- 50 day(s) preharvest interval.CUCUMBER:air/chemigation/groundAt vine formation, Foliar, Whenneeded6.3 (vineformation)15.8NS [21]7- If 2 applications at 6.3lb a.i./acre were made, anadditional application of 3.2 lb a.i./acre could bemade in that year to reach the 15.8 lb a.i./acreannual maximum application rate.- If 7 applications at 2.3 lb a.i./acre were made, itwould result in 0.3 lb a.i./acre over the 15.8 lba.i./acre annual maximum application rate.- Buffer zone restriction.- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.2.3 (foliar)NS [71]CUCURBIT VEGETABLES:2.3 15.8 NS [71] 5 -If 7 applications at 2.3 lb a.i./acre were made, it19Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundFoliarwould result in 0.3 lb a.i./acre over the 15.8 lba.i./acre annual maximum application rate.FILBERT (HAZELNUT):air/groundAt bud break, Delayed dormant,Foliar, Popcorn3.6 9 NS [21] 14- If 2 applications at 3.6lb a.i./acre were made, anadditional application of 1.8 lb a.i./acre could bemade in that year to reachthe 9.0 lb a.i./acre annualmaximum application rate.- Buffer zone restriction.- Geographic allowable: OR- 120 day(s) preharvest interval.FOREST TREES(SOFTWOODS, CONIFERS):Nurserystock, Before budbreak,After bud break, Spring, Seed bed4.5 16.5 NS [41] NS [32]- Not all of the labels for this use specify aminimum application interval.- If 4 applications at 4.5 lb a.i./acre were made, itwould result in 1.5 lb a.i./acre over the 16.5 lba.i./acre annual maximum application rate.FRUITING VEGETABLES:air/chemigation/groundFoliar2.3 18.0 NS [81] 7- If 3 applications at 2.3 lb a.i./acre were made, itwould result in 0.4 lb a.i./acre over the 18.0 lba.i./acre annual maximum application rate.GARBANZOS (INCLUDINGCHICK PEAS):air/ chemigation /groundFoliar1.5 6.0 NS [41] 7- WA020022 does not limit the maximum yearlyapplication rate or the number of applications.GARBANZOS (INCLUDINGCHICK PEAS):air/chemigation/groundFoliar1.5 6.0 NS [41] 7- Do not make more than 5 applications per cropcycle.- Geographic allowable: ND, OR, WA- 14 day(s) preharvest interval.GARLIC :2.3 15.1 NS [61] 7 - If 6 applications at 2.3 lb a.i./acre were made, an20Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundFoliar, Seed crop, When neededadditional application of 1.3 lb a.i./acre could bemade in that year to reach the 15.1 lb a.i./acreannual maximum application rate.- Buffer zone restriction.- Foliar and Seed Crop: Grown for seed only.- Grown for seed only.- 7 day(s) preharvest interval.GINSENG (MEDICINAL):air/chemigation/groundFoliarNS [1.5] NS [21] NS [141] 7- Not all of the labels for this use specify a maxsingle or max annual application rate.GOLF COURSE:6.2525NS [41]7- No commentGRASSFORAGE/FODDER/HAY:air/groundFoliar, Seed crop1.6 4.5 NS [31] 14-If 3 applications at 1.6 lb a.i./acre were made, itwould result in 0.3 lb a.i./acre over the 4.5 lba.i./acre annual maximum application rate.- Buffer zone restriction.- 14 day(s) preharvest interval.GRASSES GROWN FOR SEED:air/chemigation/groundInternode elongation1.5 4.5 NS [31] 14- 14 day(s) preharvest interval.HORSERADISH:air/chemigation/groundFoliar2.2 18.0 NS [81] 7-If 8 applications at 2.2 lb a.i./acre were made, anadditional application of 0.4 lb a.i./acre could bemade in that year to reach the 18.0 lb a.i./acreannual maximum application rate.LEEK:air/chemigation/groundFoliar, When needed2.3 6.8 NS [31] 7- Buffer zone restriction.- Do not make more than 3 applications per cropcycle.- 14 day(s) preharvest interval.- 7 day(s) preharvest interval.LENTILS:1.1 6.0 NS [51] 7 - If 5 applications at 1.1 lb a.i./acre were made, an21Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundFoliaradditional application of 0.5 lb a.i./acre could bemade in that year to reachthe 6.0 lb a.i./acre annualmaximum application rate.LUPINE, GRAIN:air/chemigation/groundFoliar1.1 6.0 NS [51] 7- If 5 applications at 1.1lb a.i./acre were made, anadditional application of 0.5 lb a.i./acre could bemade in that year to reachthe 6.0 lb a.i./acre annualmaximum application rate.MANGO:air/groundAt bud break, Early bloom throughfoliar, Early bloom, Popcorn2.6 24 NS [91] 7- If 9 applications at 2.6lb a.i./acre were made, anadditional application of 0.6 lb a.i./acre could bemade in that year to reach the 24.0 lb a.i./acreannual maximum application rate.- 21 day(s) preharvest interval.MELONS:air/chemigation/groundAt vine formation, Foliar6.3 (vineformation)15.8NS [21]7- If 2 applications at 6.3lb a.i./acre were made, anadditional application of 3.2 lb a.i./acre could bemade in that year to reach the 15.8 lb a.i./acreannual maximum application rate.- If 7 applications at 2.3 lb a.i./acre were made, itwould result in 0.3 lb a.i./acre over the 15.8 lba.i./acre annual maximum application rate.- Buffer zone restriction.- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.2.3 (foliar) NS [71]MINT/PEPPERMINT/SPEARMINT:air/chemigation/groundFoliar1.1 3.0 NS [31] 7- If 3 applications at 1.1 lb a.i./acre were made, itwould result in 0.3 lb a.i./acre over the 3.0 lba.i./acre annual maximum application rate.- Buffer zone restriction.- Geographic allowable: IN, MI, ND, OR, WI- 80 day(s) preharvest interval.MINT:1.1 3.0 NS [31] 7 - If 3 applications at1.1 lb a.i./acre were made, it22Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/groundFoliarwould result in 0.3 lb a.i./acre over the 3.0 lba.i./acre annual maximum application rate.- Buffer zone restriction.- Geographic allowable: IN, MI, WI- 80 day(s) preharvest interval.MUSHROOMS:chemigation/groundAfter spawning, Plant bed 11.5 NS [23] 2 NS [32]- The maximum number of applications and themax annual application rate are based on cropcycles not per year.- 5 day(s) preharvest interval.NECTARINE:air/groundBefore bud break, Bloom, Delayeddormant, Dormant, Establishedplantings, Foliar, Late fall, Petalfall through foliar, Petal fall, Pinkthrough petal fall, Popcorn to fullbloom, Popcorn, Postharvest 3.1 15.5 NS [51] 10- For ECHO® RTU (EPA Reg. No. 60063-30) thelabel does not specify a single max or annual maxapplication rate for the following use sites: Peach,nectarine, apricot, cherry, plum, and prune. Theapplication rate for these uses is provided as follows- “Apply full coverage spray to the point of runoffto thoroughly cover tree canopy includingundersides of leaves.”- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.- Preharvest interval not located on the label.ONION:air/chemigation/groundFoliar, In storage, Seed crop, Whenneeded2.2 15 NS [71] 7- If 7 applications at 2.2 lb a.i./acre were made, itwould result in 0.4 lb a.i./acre over the 15.0 lba.i./acre annual maximum application rate.- Buffer zone restriction.- 7 day(s) preharvest interval.6.8 (seed) 6.83NS [33] Not applicable3ONIONS (GREEN):2.3 6.8 3 7 - Buffer zone restriction.23Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundfoliar, When needed- Do not make more than 3 applications per cropcycle.- 14 day(s) preharvest interval.- 7 day(s) preharvest interval.ORNAMENTALS (LAWNS,TURF, SOD FARMS) :air/chemigation/ground13.0(chemigationand ground)27.0NS [21]NS [32]- If 2 applications at 13.0lb a.i./acre were made, anadditional application of 1.0 lb a.i./acre could bemade to reach the 27.0 lb a.i./acre annual maximumapplication rate.- If 2 applications at 11.4lb a.i./acre were made, anadditional application of 4.2 lb a.i./acre could bemade to reach the 27.0 lb a.i./acre annual maximumapplication rate.11.4 NS [21]ORNAMENTALS (PLANTSAND TREES):air/chemigation/groundNS [1.5] NS [36.36] NS [241] NS [7]- The application information is from 228-639; notall of the labels for this use specify a max single orannual application rateor provide a minimumapplication interval.- If 24 applications at 1.5 lb a.i./acre were made, anadditional application of 0.36 lb a.i./acre could bemade in that year to reach the 36.36 lb a.i./acreannual maximum application rate.OtherPAPAYA:groundFoliar3.0 6.8 3 14- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.- 14 day(s) preharvest interval.PARSNIP:air/chemigation/groundFoliar1.6 6.0 4 7- Buffer zone restriction.- Geographic disallowable: AZ, CA- 10 day(s) preharvest interval.PASSION FRUIT2.2 7.6 NS [31] 14 - If 3 applications at2.2 lb a.i./acre were made, an24Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Comments(GRANADILLA):groundBloom through foliar, Bloom,Foliar,additional application of 1.0 lb a.i./acre could bemade in that year to reachthe 7.6 lb a.i./acre annualmaximum application rate.- Buffer zone restriction.- Geographic allowable: HI- 7 day(s) preharvest interval.PEACH:air/groundBefore bud break, Bloom,Dormant, Established plantings,Foliar, Late fall, Delayed dormant, Petal fall through foliar, Petal fall,Pink through petal fall, Popcorn tofull bloom, Popcorn, Postharvest3.1 15.5 NS [51] 10- For ECHO® RTU (EPA Reg. No. 60063-30) thelabel does not specify a single max or annual maxapplication rate for the following use sites: Peach,nectarine, apricot, cherry, plum, and prune. Theapplication rate for these uses is provided as follows- “Apply full coverage spray to the point of runoffto thoroughly cover tree canopy includingundersides of leaves.”- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.PEANUTS (UNSPECIFIED):air/chemigation/groundFoliar, Postplant,1.29.0NS [71] 10- If 7 applications at 1.2lb a.i./acre were made, anadditional application of 0.6 lb a.i./acre could bemade in that year to reachthe 9.0 lb a.i./acre annualmaximum application rate.- Buffer zone restriction.- Do not apply through any type of irrigationsystem.- Do not make more than 4 applications per cropcycle.- 14 day(s) preharvest interval.- Postplant: 120 months rotational/plant back croprestriction.0.75(postplant)4 (postplant) 14 (postplant)PISTACHIO:air/groundBloom4.5 22.5 NS [51] 28- 14 day(s) preharvest interval.- 42 day(s) preharvest interval.PLANTAIN:2.7 30.0 NS [111] 10 -If 11applications at 2.7 lb a.i./acre were made, an25Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/groundFoliaradditional application of 0.3 lb a.i./acre could bemade in that year to reach the 30.0 lb a.i./acreannual maximum application rate.- Geographic allowable: PR- Max application rate is provided for each cropcycle (not per year)PLUM:air/groundBloom, Delayed dormant,Dormant, Established Plantings,Foliar, Pink through petal fall,Popcorn to full bloom, Popcorn3.1315.53NS [51] 10- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.POTATO, WHITE/IRISH:air/chemigation/groundAt vine formation, Foliar, Whenneeded1.4NS [4.2 (exceptin FL); 5.6 (inFL)]NS [3 (exceptin FL); 4 (inFL)]5- The max annual application rate and max numberof applications is not provided on all of the labelsfor this use.- The max annual application rate is from 55146-81.- Buffer zone restriction.- Geographic allowable: MI, MN, ND, NE, WI- 5 day(s) preharvest interval.- 7 day(s) preharvest interval.PRUNE:air/groundBloom, Delayed dormant,Dormant, Established Plantings,Foliar, Pink through petal fall,Popcorn to full bloom, Popcorn3.1 15.5 NS [51] 10- For ECHO® RTU (EPA Reg. No. 60063-30) thelabel does not specify a single max or annual maxapplication rate for the following use sites: Peach,nectarine, apricot, cherry, plum, and prune. Theapplication rate for these uses is provided as follows- “Apply full coverage spray to the point of runoffto thoroughly cover tree canopy includingundersides of leaves.”- Buffer zone restriction.- Geographic disallowable: AZ, CA- 00 day(s) preharvest interval.PUMPKIN:1.36 15.75 NS [111] 10 - If 11 applications at1.36 lb a.i./acre were made,26Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundFoliar, When neededan additional application of 0.79 lb a.i./acre couldbe made in that year toreach the 15.75 lb a.i./acreannual maximum application rate.- Buffer zone restriction.- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.ROSE:groundFoliar1.1 NS [27] NS [27] 7- The application information is from 829-287; notall of the labels for this use specify a max annualapplication rate or max number of applicationsallowed/year.SHALLOT:air/chemigation/groundFoliar, When needed2.2 6.7 NS [31] 7- Do not make more than 3 applications per cropcycle.- 14 day(s) preharvest interval.- 7 day(s) preharvest interval.SOYBEANS (UNSPECIFIED):air/chemigation/groundAt emergence through seedlingstage, At emergence, Bloomthrough foliar, Early bloomthrough foliar, Foliar,Postemergence1.9 4.5 NS [21] NS [14]- If 2 applications at 1.9lb a.i./acre were made, anadditional application of 0.7 lb a.i./acre could bemade in that year to reachthe 4.5 lb a.i./acre annualmaximum application rate.- The application interval is not specified on all ofthe labels for this use.- Buffer zone restriction.- Geographic disallowable: AZ, CA- 42 day(s) preharvest interval.SQUASH (ALL ORUNSPECIFIED):air/chemigation/groundFoliar, When needed1.36 15.75 NS [111] 10- If 11 applications at 1.36 lb a.i./acre were made,an additional application of 0.79 lb a.i./acre couldbe made in that year toreach the 15.75 lb a.i./acreannual maximum application rate.- Buffer zone restriction.- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.STONE FRUITS:NS [4.2] NS [15.5] NS [31] 7 - Not all of the labels for this use specify a max27Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)CommentsnsAt bud break, Hull split, Pinkthrough petal fall, Popcornsingle or max annual application rate.- If 3 applications at 4.2lb a.i./acre were made, anadditional application of 2.9 lb a.i./acre could bemade in that year to reach the 15.5 lb a.i./acreannual maximum application rate.- Buffer zone restriction.- 00 day(s) preharvest interval.STRAWBERRY:air/chemigation/groundNonbearing nursery stock, Preplant1.1 15 NS [141] NS [10]- Geographic allowable: CA- Nonbearing Nursery Stock- Tank dip (no retreatmentinterval is specified onCA960027)- If 14 applications at 1.1 lb a.i./acre were made, itwould result in 0.4 lb a.i./acre over the 15.0 lba.i./acre annual maximum application rate.SUGAR BEET:air/chemigation/groundOctober1.3NS [36.4 – seecomments]NS [28 – seecomments]NS [32]- Geographic allowable: OROR990039- The max annual application rate, max number ofapplications allowed per year, and the minimumapplication interval are not provided on the label forthis use; therefore, the max number of applicationsthat can be modeled (for aquatic modeling) isassumed.TOMATO:air/chemigation/groundFoliar, Fruiting, When needed2.3 15.1 NS [61] 7- If 6 applications at 2.3lb a.i./acre were made, anadditional application of 1.3 lb a.i./acre could bemade in that year to reach the 15.1 lb a.i./acreannual maximum application rate.- Buffer zone restriction.- Geographic disallowable: AZ, CA- 0 day(s) preharvest interval.- 7 day(s) preharvest interval.YAM:0.9 11.2 NS [121] 10 - If 12 applications at 0.9 lb a.i./acre were made, an28Use:MethodTiming(For Any Registration Number)LIMITATIONSMaximumSingleApplicationRate (lba.i./acre)MaximumYearlyApplicationRate (lba.i./acre)MaximumNumber ofApplicationsPer YearMinimumRetreatmentInterval (days)Commentsair/chemigation/groundFoliaradditional application of 0.4 lb a.i./acre could bemade in that year to reach the 11.2 lb a.i./acreannual maximum application rate.* Table reflects current labels as of December 23, 2011.The bracketed information represents the assumptions that will be made for risk assessment purposes in the absence of additional label information.NS = ‘not specified’ on at least one of the labels for that use site.1.The maximum number of applications/year was calculated by dividing the maximum annual application rate by the single maximum application rateallowed on the label. If the single max application cannot be evenly divided into the max application rate, it is indicated this in the ‘Comment’ column.This implies that the use may not be modeled by simply multiplying the number of applications by the maximum single applicationrate.2.A 3-day reapplication interval is assumed based on the shortest retreatment interval allowed on any label for any chlorothalonil use (i.e., celery).3.Since this is a seed treatment use only one application is assumed per season; however, since onions specifically green onionscan be planted up to threetimes per year in some locations the number of applications per year is assumed to be three.11This assumes that the label that specifies “onion” does notalso include onion (green onion) limitations.11Kaul, M. Maximum Number of Crop Cycles Per Year in California for Methomyl Use Sites. Date February 28, 2001.29Table 5. Chlorothalonil Antimicrobial Pesticide Use Label SummaryUse1Method ofApplicationApplication RateMaximum Concentration ofa.i. in Treated MaterialCommentsIndustrial wood preservative (timber,lumber, utility poles, crossarms,crossties) and sapstainDip tank, brush,spray2,486 to 23,797 ppm a.i.Retention rate in lbs a.i./ft3is notprovidedPressure treatmentAt retention level of 0.3 to 0.8a.i lbs ft30.8 lbs a.i. per ft3of woodMaterial preservative—woodcompositesVarious methods areused to mix1.25-12.5 lbs a.i./ft312.5 lbs a.i./ft3Industrial preparation of over-thecounter wood preservative paints,stains, and coatings (siding, fences,decks, planking, shingles, shakes,wood furniture)Various industrialmethods are used tomix and blend13,950 ppmTreated material can besprayed, pad, or brush appliedto exterior and interior woodsurfacesIndustrial preparation of over-thecounter antifungal/antimold paints,stains, and coating for use on metal,masonary,etc. (Film preservative)Various industrialmethods are used tomix and blend13,950 ppm exterior9,799 ppm interiorTreated material can besprayed, pad, or brush appliedto exterior and interior hardsurfaces (e.g., concrete,metal)Material preservative—stuccoVarious industrialmethods are used tomix and blendNo application rate to exteriorsurfaces providedMaterial preservative—aqueousbased adhesives, caulks & sealantsVarious industrialmethods are used tomix and blendNo application rate to exteriorsurfaces provided11,750 ppmNo restriction as to indoor oroutdoor useMaterial preservative—Paper/paperboard (non-food contact)Various industrialmethods are used tomix and blendNo application rate provided 1,415 ppmlbs a.i./ft3: pounds of active ingredient per cubic footppm: parts per million or milligram per kilogram (mg/kg)

### 30 D. E NVIRONMENTAL 

### F ATE AND 

### T RANSPORT



### Chlorothalonil Fate Properties

Environmental fate properties of chlorothalonil are summarized in Table 6 . The fate dataset has major deficiencies. No fate studies are classi fied as acceptable with the exception of two BCF studies. Based on supplemental information, chlo rothalonil was shown to undergo a number of different chemical reactions including de-chl orination, hydroxylation and sulfonation in the

environment to form a number of different transformation products. All the transformation products reported retain the phenyl ring with the exception of carbon dioxide (CO 2 

### ). Maximum concentration of each transformation product formed is provided in Table 7 . In summary, laboratory studies indicate chlorothalonil will tr ansform primarily through aqueous photolysis in clear, shallow water. Chloroth alonil is also susceptible to microbial-mediated transformation,

with transformation rates often de parting from first-order kinetics. Degradation rates have been shown to be dependent on the application rate with higher chlorothal onil application rates resulting in slower degradation rates and vice versa. Data also suggest that chlorothalonil is rapidly transformed in water/sediment syst ems under both aerobic and anaerobic conditions. Field dissipation studies show that chlorothalonil dissipates ( e.g. , transformation or relocation)

with half-lives less than 100 days; however, in a few field di ssipation studies chlorothalonil was observed in soil samples taken after one year. Ba tch equilibrium data suggest chlorothalonil is slightly to hardly mobile in soil systems. A su mmary of submitted environmental fate studies is provided in APPENDIX A . A detailed discussion of each of the relevant environmental fate studies is provided in the subsections below.

Table 6. Environmental Fate Pa rameters of Chlorothalonil

Parameter Value Source Classification; Comments

Abiotic Transformation Mechanisms

Hydrolysis Half-life No substantial degradation (pH 5 and 7) MRID 00040539 Supplemental

Some aspects of the study are invalid ( i.e., pH 9). Transformation of chlorothalonil was observed at pH 9; however, a mass balance was not provided and degradation products were only analyzed in one sample (day 89).

Additional data are needed to assess the

transformation of chlorothalonil under basic conditions (pH >9).

Soil Photolysis Half-life No substantial degradation MRID 00087349 Supplemental

No substantial degradation MRID 00040543 Supplemental Aqueous Photolysis

half-life 10.3 hours pH 7, 30 °North MRID 45710223 Supplemental 3

Biotic Transformation Mechanisms 1

Aerobic Soil

Metabolism Half-life 58 days (SFO)/ 127 days (DFOP) STERILE CONTROL: 105 days (SFO) 39 mg/kg (~78 lb/a 2 ); Illinois silty clay loam (pH 5.1 1.3% OC) MRID 00087351

MRID 00040547

Supplemental

### 31 Parameter Value Source Classification; Comments 15 days (SFO)/ 23 days (IORE) STERILE CONTROL: 32 days (SFO) 39 mg/kg (~78 lb/a 2 ); Iowa loam (pH 7.0 4.2% OC) These two MRIDs are the same study.

A substantial amount of chlorothalonil

transformation is observed in the sterile controls; and a material balance could not

be determined because unextracted residues were not measured directly. 14 days (SFO)/ 23 days (IORE) STERILE CONTROL: 33 days (IORE) 39 mg/kg (78 lb/a 2 ); Texas sandy loam (pH 8.0 0.9% OC) 10 days (SFO)/ 16 days (IORE) STERILE CONTROL: 33 days (SFO) 3.9 mg/kg (8 lb/a 2 ); Ohio sandy loam (pH 6.0 1.9% OC) 5.4 days (SFO)/ 18 days (IORE) 1 mg/kg, 1.7 lb/a 2 ; Ohio loamy sand (pH 5.1, 1.5% OC, 2.6 %OM, 7.1, 7.0 CEC) MRID 43879601 Supplemental 21.3 days (SFO)/ 34.8 days (IORE) 10 mg/kg (20 lb/a 2 ); Ohio loamy sand (pH 5.1, 1.5% OC, 2.6 %OM, 7.1, 7.0 CEC)

0.5 days (SFO)/0.3 days (IORE) 0.1 mg/kg (0.2 lb/a 2 ); 18 acres (not reported) MRID 47207702 Supplemental No data are provided for day 0 (assumed to be 100%), for this reason, chlorothalonil concentration at day 0 was assumed to be 100% of the applied radioactivity; soil characterization was not provided; duplicate samples were not analyzed; and no soil controls were provided. 3 days (SFO)/ 18 days (IORE) 1 mg/kg (2 lb/a 2 ); 18 acres (not reported) 10 days (SFO) 10 mg/kg (20 lb/a 2 ); 18 acres (not reported)

18 days (SFO)/ 243 days (IORE) 25 mg/kg (50 lb/a 2 ); 18 acres (not reported)

1 day (SFO)/ 1.5 days (IORE) 1.5 kg/ha; 1.3 lb/a; 18 acres (pH 5.4, 4.5% OC, 4.5 %OM, 16.2 CEC) MRID 47207703 Supplemental

Application rates are not reflective of

current maximum label rates and

transformation of chlorothalonil has been shown to be concentration dependent. 0.3 days (SFO)/ 0.5 days (IORE) 1.5 kg/ha; 1.3 lb/a; Chamberlain’s Farm (pH 6.8, 3.2% OC, 3.2% OM, 8.0 CEC)

1.3 days (SFO)/ 1.7 days (IORE) 1.5 kg/ha; 1.3 lb/a; ERTC (pH 5.0, 1.3% OC, 1.3% OM, 4.4 CEC) 2.4 days (SFO)/ 4.1 days (IORE) 1.5 kg/ha; 1.3 lb/a; Munster (pH 4.8, 2.5% OC, 2.5% OM, 5.5 CEC)

Anaerobic Soil

Metabolism Half-life no data available

Aerobic Aquatic

Metabolism Half-life 3.4 days (SFO)/ 8.5 days (IORE) Bury Pond [pH 5.2 (water) 8.0 (sediment), 1% OC, 16 CEC)], The concentrations varied substantially throughout the study. MRID 45908001 Supplemental

The stability of the parent and its transformation products during storage prior to analysis were not addressed; volatile transformation products were

detected at ≥ 10% AR but not identified; and there is also a large amount of

unidentified HPLC residues. 0.1 day (SFO)/1.1days (IORE) Houghton Meadow [pH 6.73 (water) 7.3 (sediment), 5.8% OC, 51.4 CEC)]

### 32 Parameter Value Source Classification; Comments 0.06 days (SFO)/ 0.1 days (IORE) 0.6 mg/L; Ohio and DI water (pH 6.8) MRID 42226101 Supplemental

Studies were not conducted with natural

water. 0.3 days (SFO)/ 1.9 days (DFOP) 0.6 mg/L; Virginia with artificial sea water (pH 9.3) 2.6 days (SFO) 2
Emperor Lake (pH 7.4) MRID 47207701 Supplemental

Establishment of chlorothalonil transformation profile could not be determined; analytical methods were not suitable for isolating individual compounds; and not all major transformation products were identified. 0.8 days (SFO) 2
Bury Pond (pH 7.9)

Anaerobic Aquatic

Metabolism Half-life 10.6 days (SFO) Tennessee silt loam (pH 6.0-7.2, 8.4-10.4 CEC) MRID 00147975 Supplemental

No data are provided for day 0 (assumed to be 100%), for this reason, chlorothalonil concentration at day 0 was assumed to be 100% of the applied radioactivity; for one test system the study was terminated before the pattern of dissipation of some of the major transformation products was established;

distilled water was used instead of natural

water and soil rather than sediment was used in this study; and although the test system was kept on nitrogen (30 days prior to study initiation) redox potentials and oxygen concentrations were not provided during the experiment so it cannot be determined that the test systems

was anaerobic. 9.7 days (SFO)/ 21.5 days (IORE) Ohio sandy loam (pH 5.7-6.0, 112.0-12.6 CEC)

Mobility Range of Freundlich soil-water partition coefficients (K F ); exponent (1/n) values;

andorganic carbonnormalized coefficients (K FOC ) 12, 14, 19, 56, 131, and 500 L/kg-soil; 0.66, 0.66, 0.72, 0.91, 1.1, and 1.2; and 1121, 2039, 2958, 5085, 6605, and 11935 mL/g OC MRID 00029406 Supplemental

The temperature and the light conditions used in the definitive study were not reported; a desorption phase was not conducted; and material balance was not

determined.

### 33 Parameter Value Source Classification; Comments
Field Dissipation

Terrestrial Field Dissipation Half-life 58, 56, 74, and 81 days * 00071625 Supplemental

*Sampling intervals were inadequate to

define the half-life under field conditions. A storage stability study was not conducted. The pattern of formation and decline of the transformation products

could not be determined. And the sampling depth was not sufficient to define leaching.

33, 46, 50, 58, and 74 days* MRIDs 00071627, 00087369, 00087332,

and 00087301 Supplemental

*Sampling intervals were inadequate to

define the half-life under field conditions Analytical methods were inadequate in identifying transformation products of

chlorothalonil.

Bioaccumulation

Fish BCF edible, non-edible, and

whole fish tissues 256, 5812 and 3077 at initial water exposure level of 0.1 μg/L

chlorothalonil MRID 45710224 Acceptable

Chlorothalonil concentration in water during the exposure ranged from 39-97%. No data was provided on the depuration rates in this study. 306, 5694 and 3041 at initial water exposure level 0.5 μg/L

chlorothalonil

Oyster BCF whole oyster 2660 (total residue primarily of transformation products) MRID 43070601 Acceptable

1. Representative half-life values were calculated using the draft NAFTA degradation kinetics document: Guidance for Evaluating and Calculating Degradation Kinetics in Environmental Media (draft document June 29, 2011); Single First Order (SFO), Nth-Order Rate Model or Indeterminate Order Rate Equation Model (IORE), and Double First-Order in Parallel (DFOP)

2. SFO kinetic analysis was the only method employed.

3. Aquatic photolysis study was reclassified to supplemental as all major transformation products were not adequately identified. Additional data are needed to identify all major transformation products or other residues of potential toxicological concern. Applied Radioactivity (AR)

BCF: bioconcentration factor Cation Exchange Capacity (CEC)

DI: deionized water

lb/a 2 : pound per square acre mg/kg: milligrams per kilogram mL/g OC : milliliters per gram of organic carbon Organic Carbon (OC) OM: organic matter pH: One divided by the log of the hydrogen ion concentration34Table 7. Maximum Observed Concentrations of Chlorothalonil Transformation Products in Environmental Fate LaboratoryStudiesCode Name/SynonymChemical NameSmiles CodeChemical StructureStudy Type/CorrespondingOCSPP GuidelineMRID(classification)Maximum % AR(interval)1Major (>10%) Transformation ProductsSDS-3701DCA-3701DS-3701R182281CNIL/024-hydroxy-2,5,6-trichloro-1,3-dicyanobenzeneC1(=C(C(=C(C(=C1Cl)C#N)O[H])Cl)Cl)C#NAquatic Photolysis835.224045121803Supplemental24.9 (9 hrs)Aerobic SoilMetabolism835.41000004054700087351Supplemental34.1 (60 days; loamsoil)Aerobic AquaticMetabolism835.430045908001Supplemental16.2 (59 days)Hydroxy-chloro-1,3-dicyanobenzene (unspecifiednumber of attached atoms (1-3)NNOHxClxAquatic Photolysis835.224045121803Supplemental214.1(9 hrs)SDS-47523R611966CNIL/053-cyano-2,4,5-trichlorobenzamideC1(=C(C(=CC(=C1Cl)C(=O)N([H])[H])Cl)Cl)C#NCONH2NClClClAerobic SoilMetabolism835.410043879601Supplemental310.39 (91 days)SDS-46851 3-carbamoyl-2,4,5-Aerobic Soil 43879601 18.94 (181 days)ClOHClClNN35Code Name/SynonymChemical NameSmiles CodeChemical StructureStudy Type/CorrespondingOCSPP GuidelineMRID(classification)Maximum % AR(interval)1R611965CNIL/04trichlorobenzoic acidC1(=CC(=C(C(=C1Cl)C(=O)N([H])[H])Cl)Cl)C(=O)O[H]COOHCONH2ClClClMetabolism835.4100Supplemental3R417888CNIL/102-amido-3,5,6-trichloro-4-cyanobenzenesulfonic acidC1(=C(C(=C(C(=C1Cl)C(=O)N([H])[H])[S](=O)(=O)O[H])Cl)Cl)C#NCONH2NClClClSO3HAerobic SoilMetabolism835.410047207703Supplemental14.1 (7 days)R471811CNIL/13Sodium 2,4-bis-amido-3,5,6-trichlorobenzenesulfonateC1(=C(C(=C(C(=C1Cl)C(=O)N([H])[H])[S](=O)(=O)[O-])Cl)C(N([H])[H])=O)C#N.[Na+]CONH2NClClH2NOCSO3NaAerobic SoilMetabolism835.410047207702Supplemental11.9 (125 days)R419492CNIL/124-amindo-2,5-dichloro-6-cyanobenzene-1,3-disulphonicacidNClClHO3SSO3HCONH2Aerobic SoilMetabolism835.410047207703Supplemental12.4 (120 days)36Code Name/SynonymChemical NameSmiles CodeChemical StructureStudy Type/CorrespondingOCSPP GuidelineMRID(classification)Maximum % AR(interval)1SDS-67042R6138415-cyano-4,6,7-trichloro-2H-1,2-benzisothiazol-3-one4,6,7-trichloro-5-cyano-2Hbenzisothiazol-3-oneC1(=C(C(=C2C(=C1Cl)C(NS2)=O)Cl)Cl)C#NNClClClSNHOAerobic AquaticMetabolism835.430042226101Supplemental31.91(1 day)2,5,6-trichloro-1,3-dicyanobenzene-4-sulphonateNClClClSO3HNAerobic SoilMetabolism835.410045908001Supplemental10.4 (0.25 days)Trichloro-1,3-dicyanobenzeneNNCl3Aquatic Photolysis835.224045121803Supplemental26.9 (12 hrs)Aerobic AquaticMetabolism835.430045908001Supplemental28.3 (0.25 days)37Code Name/SynonymChemical NameSmiles CodeChemical StructureStudy Type/CorrespondingOCSPP GuidelineMRID(classification)Maximum % AR(interval)1SDS-663822,5,6-trichloro-4-(glutathion-S-yl)isophthalonitrileNClClClSNHNHNOOOHOHOH2NOAerobic AquaticMetabolism835.430042226101Supplemental7.89 (16 days)Carbon Dioxide CO2Aerobic SoilMetabolism835.410047207703Supplemental23.8 (120 days)Minor (<10%) Transformation ProductsSDS-133532,5,6-trichloro-4-(thio)isophthalonitrileNClClClSHNAerobic AquaticMetabolism835.430042226101Supplemental8.55 (0.25 days)38Code Name/SynonymChemical NameSmiles CodeChemical StructureStudy Type/CorrespondingOCSPP GuidelineMRID(classification)Maximum % AR(interval)1SDS-66432NClClSSNHNNHOOOOHOHH2NONHNHOOOHOHONH2O2,5-dichloro-4,6-di-(glutathion-S-yl)isophthalonitrileAerobic AquaticMetabolism835.430042226101Supplemental9.62 (16 days)DS-19221SDS-19221R613636CNIL/033-Cyano-2,4,5,6-tertachlorobenzamideCONH2NClClClClAerobic SoilMetabolism835.41000004054700087351Supplemental7.3 (30 days)SDS-47524R611967CNIL/063-cyano-2,5,6-trichlorobenzamideCONH2NClClClAerobic SoilMetabolism835.410043879601Supplemental38.41 (14 days)39Code Name/SynonymChemical NameSmiles CodeChemical StructureStudy Type/CorrespondingOCSPP GuidelineMRID(classification)Maximum % AR(interval)1SDS-47525R611968CNIL/073-cyano6-hydroxy-2,4,5-trichlorobenzamideCONH2NClClClOHAerobic SoilMetabolism835.410047207702Supplemental6.5 (2 days)R418503CNIL/112,5 Dichloro-4,6-dicyanobenzene-1,3-disulfonicacidNClClH3OSSO3HNAerobic SoilMetabolism835.41004720772Supplemental0.9 (125 days)R419492CNIL/124-carbamoyl-2,5-dichloro-6-cyano-benzene-1,3-disulfonicacidCONH2NClClH3OSSO3HAerobic SoilMetabolism835.41004720772Supplemental3.2 (125 days)1.Bold font indicates maximum concentration was observed at studytermination; therefore, the formation and decline of the transformation productwas not established in the experiment.2.Aquatic photolysis study was reclassified tosupplemental as all major transformationproducts were not adequately identified.Additional data areneeded to identify all major transformation products or other residues of toxicological concern.3.This aerobic soil metabolism study was reclassified to supplemental as all major transformation products were not adequately identified. Additionaldata are needed to identify all major transformation products or other residues of toxicological concern.Applied Radioactivity (AR)

### 40 Abiotic Degradation

Hydrolysis

One submitted study explored the hydrolysis of chlorothalonil at pH 5, 7 and 9 [MRID 00040539 (1976)]. The study was originally cl assified as acceptable; howeve r, after recent review this study has been reclassified to supplemental. Th e portion of the study that was conducted at pH 9 does not meet guideline standards because a ma terial balance and ch aracterization of the transformation products were not provided. The data suggest that chlo rothalonil may hydrolyze (DT 50 

### = 51 days) under basic conditions (pH >7), but that chloroth alonil is not susceptible to hydrolysis at pHs 5 and 7. Additional data are ne eded on chlorothalonil hydrolysis at pH 9 and until such data is received hydrolysis is considered a data gap.

Aquatic Photolysis

Five aquatic photolysis studies were submitted for chlorothalonil; however, two of these studies [MRIDs 40183418 (1987) and 00087281 (1972)] were d eemed unacceptable. These studies were classified unacceptable, because the intensity an d spectral distribution of the artificial light source to natural sunlight was not provided, and identification of the transformation products was not provided. Another study [MRID 41030001 (1989)] is not actua lly an aquatic photolysis study. The submitted material provided supplemental information on concerns raised by EPA in the review of the unacceptable study, MR ID 40183418, including characterization of the artificial light source and samp le frequency. The submittal of this information does not support upgrading the classification of MRID 40183418. A previously cl assified supplemental study [MRID 00040540 (1976)] was reevalua ted and reclassified as unacceptable because the study report did not adequately compare the intensity a nd spectral distribution of the artificial light source to natural sunlight, or, identify tran sformation products. Based on laboratory data generated using an artificia l light source, a more recen t study [MRID 45710223 (1996)] showed

that chlorothalonil did transform under aqueous photolysis with an environmental predicted photo-transformation half-life of 10.3 hours (DT 50 

### = 10.5 hours artificial light; MRID 45710223) at 30 °N latitude. This study was originally clas sified as acceptable; however, after a recent review this study was reclassified as supplemen tal. This study was reclassified because three major transformation products [47% of the applie d radioactivity (AR)] were not identified—this is a data gap. Additional data are needed to id entify these major transf ormation products or any other potentially toxic transformation products obs erved in the study. If ad ditional data are not provided, the unknown residues will be assumed to be of equal toxici ty to chlorothalonil or SDS3701, whichever is more conservative, for risk assessment purposes.

Soil Photolysis

Eight soil photolysis studies have been submitted for chlorothalonil. Three of these studies were

deemed suitable for use in risk assessment and were classified supplemental [MRIDs 00087349 (1975), 00040543 (1976) and 00156470 (1985)] while th e others have been classified as unacceptable (see APPENDIX A ) for a number of reasons incl uding: the studies were not conducted on soil or the intensity and spectral distribution of the ar tificial light source to natural sunlight was not provided. Despite the guideline deviations in the supplemental studies, it was

### 41 determined that little would be gained from re peating these studies as no substantial degradation of chlorothalonil was observed in these studies; th erefore, chlorothalonil is considered stable to soil photolysis.

Biotic Degradation

Aerobic Soil Metabolism

Six aerobic soil metabolism studies have been submitted for chlorothalonil. Two of the six studies [MRIDs 00087285 (1970) and 00114035 (1970)] we re determined to be unacceptable

because the studies were conducted with bacterial cultures (inoculat ed with soil perfusions) and

not soil. These studies were not reevaluated as part of this pr oblem formulation. The remaining studies have been classified as supplement al, and are discussed individually, below.

One of the aerobic soil metabolism studies appears to have been submitted twice and as a result was given two different MRID number s (MRIDs 00087351/00040547(1976)). For this study, two different application rates were used - 8 and 78 lb a.i./a. The highest a pplication rate is much higher (6 times) than the current applicati on rate (13 lb a.i./a) permitted on registered conventional pesticide chlorothal onil use labels. Chlorothalonil tr ansformation half-lives ranged from 10 to 58 days using non-linear single fi rst order (SFO) kinetic model; however,

chlorothalonil does not follow SFO degradation kinetics. Upon a dditional kinetic analysis using

Nth-Order Rate Model or Indeterminate Order Rate Equation Model (IORE), and Double FirstOrder in Parallel (DFOP) models, 12 

### representative half-life va lues for chlorothalonil were determined to range from 16-127 days. Chloroth alonil concentrations de crease at the beginning of the study; however, after approximately 20-40 days chlorothalonil concentrations become steady at approximately 40-50% of the AR in one soil and 10-20% of the AR in the other three soils tested. In general, the transformation of chlorothalonil depends on th e application rate as the highest application ra te resulted in the longest half-lif e while the lowest application rate

resulted in the shortest half-life. A substa ntial amount of chloroth alonil transformation was observed in the sterile control (hal f-life values ranged from 33-105 da ys). It is unclear if this transformation is representative of another dissipati on pathway or if the soils were not sterile. In

three of the four sterile contro l experiments, chlorothalonil tran sformation can be described using

SFO. Chlorothalonil transformation in the fourth control experiment is best described using IORE. Two transformation products were id entified in this study, SDS-3701 (34.1% AR) and DS-19221 (7.3% AR). Although these transforma tion products were identified, a material

balance could not be determined because unext racted residues were not measured and it is unclear if all major, or potent ially toxic, transformation products were identified. Up to 27% of the applied radioactivity was found in the aqueous extracts. This material was not characterized.

In another aerobic soil metabolism study, chlorothalonil was also inve stigated at application rates of approximately 2 and 20 lb a.i./a [MRID 43879601 (1995)]. The corresponding half-lives were 6 and 21 days using a non-linear SFO kinetic mode l, respectively. Nevert heless, chlorothalonil

transformation was shown not to follow SFO ki netics. Upon additional kinetic analysis, the representative half-life values for chlorothaloni l were determined to be 18 and 35 days using

12 Guidance for Evaluating and Calculating Degradation Kinetics in Environmental Media (draft document June 29, 2011).

### 42 IORE, respectively. These results also suggest th at chlorothalonil transformation depends on the application rate. Neither of the tw o application rates used in this study are representative of the current maximum single rate (13 lb a.i./a). Tr ansformation products identified in this study include SDS-3701 (14% AR), SDS-19221 ( 6.35% AR), SDS-47523 (10% AR), SDS-47524 (13.77 % AR), SDS-47525 (4.73% AR), and SDS-46851 (19% AR). One major transformation product (representing up to 12% AR) was not identified in this study.

The aerobic soil metabolism of chlorothalonil was al so investigated over a range of application rates [approximately 0.2-50 lb a.i./a; MRID 47207702 (2000)]. This study also showed that the

transformation rate of chloro thalonil depends on the soil a pplication rate. Estimated chlorothalonil half-lives ranged from less than a day to 18 days using SFO kinetics. The

transformation of chlorothalonil is best described using IORE for th ree of the test concentrations

and SFO for one of the test concentrations. The representative half-life values ranged from less than one day for the lowest applic ation rate (0.2 lb a.i. /a) to 243 days for th e highest application rate (50 lb a.i./a). This study also shows that any chlorothalonil presen t after approx imately 20- 40 days is no longer metabolized. The range of application rates tested in this study spans the current maximum application rate; however, th e current maximum application rate was not

tested. No data on transformation of chlorothal onil were provided until day two; therefore, the half-life values above were derived assuming a 100% of the applied radi oactivity was present on day one. This introduces uncertainty in the re presentation of the calcu lated half-life values, especially for the lowest application rate tested as the estimated half-life value was less than two days. This uncertainty limits the usefulness of the data for risk assessment purposes. This study

also did not include soil char acterization, duplicate samples, or sterile controls, further complicating the interpretation of the study. Transformation pr oducts identified in this study include SDS-3701, R417888, R471811, SDS-19221, SDS-47523, SDS-47524, SDS-47525, R419492, SDS-46851 and CO 2



### .

The last aerobic soil metabolism study submitted fo r chlorothalonil indicates half-life values ranged from 1 to 2.5 days using (SFO); however , SFO does not best desc ribe the data [MRID 47207703 (2001)]. In all four soils the transforma tion of chlorothalonil is best described by IORE with representative half-l ife values ranging from less than one day to up to four days.

These results are for chlorothalon il applications around 1 lb a.i./a, and are consistent with other

studies conducted with a similar application rate. This study was originally classified as an acceptable study; however, this study has been recl assified to supplemental as the results may not represent the half-life value of the current maximum single chlorothalonil application rate (13 lb a.i./a) or a large number of other curr ent maximum single chlorothalonil application rates (see Table 4 ). For chlorothalonil the application rate ha s been shown in other studies to influence

the rate of transformation. These reported half-life values should not be used to represent the current chlorothalonil use pattern. Transforma tion products identified in this study include R182281, R417888, R419492, SDS-19221, SDS-46851, SDS-47523, R471811 and CO 2



### .

Taken together, these aerobic soil metabolism studies demonstrate th at chlorothalonil can undergo a number of different chemical reactions in the soil to form a number of transformation products. All the transformation pr oducts reported retain the phenyl ring with the exception of

CO 2 

### . Maximum observed concentrations of each of these transformation products reported in the submitted aerobic soil metabolism studies are highlighted in Table 7 . The transformation rate of

### 43 chlorothalonil was also shown to be heavily influenced by the application rate. Higher application rates result in longer half-life values while lower app lication rates resu lt in shorter half-life values (MRIDs 43879601, 47207702, 00087351 and 00040547). This is likely the result of a decrease in viability of the soil microbes after exposure to chlorothalonil. This is supported by a decrease in observed microbial activity at study termination as compared to study initiation (MRID 47207703). All aerobic soil metabolism kinetic analyses are provided in APPENDIX B

. In general, this suite of studi es indicate that chlorothalonil degrades over the first 20 days; however, if any chlorothal onil remains after 20-40 days it is not likely to be metabolized or it is metabolized very slowly. This was generally obs erved for all application rates. Representative half-life values for chlorothalonil compared to a pplication rates used in the submitted studies that span the current single maximum a pplication rates ar e provided in Table 8 . Based on the data presented in this table, the half-life value for the currently approved maximum application rate is likely between 18-35 days; however, additional data are needed to confirm this assumption.

Table 8. Representative Aerobic Soil Metaboli sm Half-life Values for Chlorothalonil in Relationship to Experimental Application Rates and Current Maximum Single Application

Rate Application Rate (lb a.i./a) Representative Half-life (days) Source Comments

1 2

MRID 47207703

IORE best fit kinetic

model 1 1

1 2

1 4

2 18 MRID 43879601

2 18* MRID 47207702

8 16 MRIDs

00087351/00040547

20 35 MRID 43879601

20 10* MRID 47207702 SFO best fit kinetic

model

50 243* MRID 47207702 IORE best fit kinetic

model

*The half-life value is estimated as data we re not provided until two days after treatment. Zigzag line represents current ma ximum single application rate.



### Anaerobic Soil Metabolism

No anaerobic soil metabolism data has been submitted. This is considered a data gap. In absence of this data the anaerobic aqua tic metabolism rate may be used as a surrogate. A supplemental anaerobic aquatic metabolism (MRID 00147975) study has been submitted (see discussion below).

Aerobic Aquatic Metabolism

Three different aerobic aquatic metabolism studies have been submitted for chlorothalonil. All of these studies have been classified as supplementa l. All three studies indi cate that chlorothalonil transformation is rapid (<1 day). Ne vertheless, all of thes e studies have deficiencies that limit the use of the data for risk assessment purposes. One common deficiency is th at none of the studies

### 44 identified all the major transformation pr oducts. One of the studies [MRID 45908001 (1996)] report fluctuating chlorothalonil concentrati ons (going up and down) and thus corresponding half-life values should not be used quantitatively in a risk assessment. In another study (MRID 42226101(1991)], artificial sources of water were used and the resulting half -life values may not accurately represent those found in natural wa ter bodies. Additional data are needed on the

transformation rate of chlorothalonil in aerobic aquatic systems, as well as full characterization of all major transformation products or transf ormation products of toxicological concern. Until

such information is received aerobic aquatic metabolism is considered a data gap.

Anaerobic Aquatic Metabolism

One supplemental anaerobic aquatic meta bolism study [MRID 00147975 (1985)] has been submitted. These data suggest that chlorothal onil can transform under anaerobic conditions; however, after reevaluation of the study several deficiencies have been noted that limit the use of these data for risk assessment purposes. Redox potentials and oxygen con centrations were not provided during the experiment; therefore, it cannot be confirmed that the system was anaerobic. Since the test system was purged with nitrogen for 30 days prior to study initiation it is assumed that the study was conducted under anaerobic conditi ons; however, additional data are needed to confirm this assumption. In addition, no data are provided for day 0. For this reason,

chlorothalonil concentration at day 0 was assumed to be 100% of the applied radioactivity. The study was also terminated before the pattern of formation and decline could be established for the transformation products in one of the test syst ems. The test systems used in this experiment

are soil and distilled water. Cu rrent guidelines indicate that anaerobic aquatic metabolism studies should be conducted with sediment (not soil) alo ng with natural water (not distilled water). For all the reasons mentioned above, the anaerobic aquatic metabolism study is considered a data gap

without additional information.

Adsorption/Desorption-Batch Equilibrium

One supplemental adsorption study [MRID 00029406 (1980)] indicates that chlorothalonil is slightly to hardly mobile in soils (K F 

### range from 12 to 500 L/kg-soil while K

oc 

### values range from 1121 to 11935 mL/g OC 

### ). The leaching potential of chloroth alonil through soil is correlated with the organic carbon fraction of the soil. The Fr eundlich exponent (1/n) ranges from 0.7 to 1.2, suggesting that adsorption is non-linear. This study did not investig ate the desorption of chlorothalonil from soil, and this is considered a data gap.

Terrestrial Field Dissipation

Two supplemental terrestrial field dissipa tion studies [MRIDs 00071625 (1981) and MRIDs 00071627, 00087332, 00087369, 00087301 (1980, 1967 and 1965)] are available for chlorothalonil. In both of these studies, sampling did not begin until at least one month after chlorothalonil applications. This limits the ability to estimate a representative half-life value for chlorothalonil, as well as for any chlorothalonil transformation products. In addition, both of

these studies also have additional deficiencies as listed in Table 6 , including limited

characterization of environmental transformation products. The estimated half-life values suggest that substantial amounts of applied chlorothaloni l could be available fo r runoff or soil-sorbed

### 45 erosion transport for several weeks to months pos t-application (estimated half-life values ranged from 33 to 81 days). Terrestrial field dissipation is considered a data gap for chlorothalonil.

Fish Bioaccumulation

A fish bioconcentration [MRID 45710224 (1997)] study showed that chlorothalonil is absorbed by fish; however, it depurates when exposure c eases (approximately 31-35% decrease after one day). For the two different concentrations test ed (0.1 μg/L and 0.5 μg/L) the bioconcentration factor (BCF) were determined to range from 256-306, 5694-5812 and 3041-3077 for the edible, non-edible, and whole fish tissues , respectively. Three transformati on products were identified to form—triglutathione and diglut athione conjugates and SDS-3701. Several other transformation products were observed. These transformation products did not make up more than 10% AR combined. Up to 28 % of the AR was identified as polar components and not characterized while up to 15% of the radioactivity was not extracted.

An oyster bioconcentration (MRID 43070601) study s howed that chlorothal onil is adsorbed by oysters. A total residue BCF (primary transf ormation products) was determined to be 2600 suggesting there is some potenti al for bioaccumulation of chlo rothalonil transformation products.

Dissipation

Spray Drift

Based on conventional use patterns there is the potential for ch lorothalonil to drift following application. Spray drift results in deposition to adjacent areas including terrestrial habitats and aquatic environments that serve as habitat or source water for drinking water. In general, deposition of drifting or volatilized pesticides is expected to be gr eatest closest to the site of application.

As result of the 1999 RED, all agricultural labels were updated to include a buffer zone between agricultural fields (including sod farms, farms, forests, nurseries and greenhouses) and marine/estuarine water bodies. The required buffer is 150 feet for aerial and air-blast applications and 25 feet for ground applications.

### 46 Overspray-Antimicrobial Coating Applications

Application of exterior paints , stains, and coatings using ai r or airless spray equipment 13 

### has the potential, due to overspray, to result in deposi tion to adjacent areas. This is considered a negligible exposure pathway of antimicrobials fo r nontarget organisms due to a combination of factors. With delivery rates of paint on the order of 0.24 gallons per minute (gpm) to greater than 1 gpm (0.91 to >3.8 liters per minute) for airless sprayers 14 

### , median droplet size is expected

to be in the hundreds to thousands of micron size range which is mu ch larger than particle sizes that are more prone to drift (< 150 microns). Additionally, the high percent solids content in paints, stains and coatings (20- 70% solids for exterior coatings 15 

### ) is expected to drastically reduce the distance overspray would travel from th e point of application as compared to spray drift from agricultural spray applic ations. While such conditions ar e expected, to the best of the Agency’s knowledge there is no quantitative info rmation available on the distance paints, stains, and coatings drift from various spray equipment applications. In OECD Emission Scenario Document Number 22 for Coatings 15 

### the estimate of drift is 1 to 10% based on a review of general and agricultural spray drift information in support of Emission Scenario Document for Biocides used as Masonry Preservatives ,16 

### At the highest chlorothal onil active ingred ient content in paint (0.12 lbs per gallon), if 10% drifted over a perimeter of 25 ft the loading rate is <1 lb

a.i./acre. Another factor considered is that the frequency of overspray occurring at any given location will be extremely limited as the life expectancy of paint on exterior home building wood, aluminum, or brick components is 7 to 10 years 17,18 

### . Smaller structural elements such as decks which have been treated with clear, pr eservative coatings may require more frequent treatment (life expectancy 1 to 2 years) but due to the small size of thes e structure, the Agency expects that environmental loading will be negligib le despite the more frequent applications.

Volatilization

Based on laboratory data, the vapor pressure (5.7 x 10 -7 

### torr) and Henry’s Law Constant (2.6 x

10 -7 

### atm - m3/mole) values for chlorothalonil indicate some degree of volatility from both soil and water (semi-volatile). However, volatilizat ion would not be expected to be a major dissipation route. Nonetheless, a number of studies have docume nted atmospheric transport and redeposition of various pesticides , including chlorothalonil, from the Central Valley to the Sierra

Nevada Mountains. 19,20,21 

### This is likely the result of prev ailing winds blowing across the Central

13 0-1 bar or 0-14.5 pounds per square inch of pressure

14 http://www.portlandcompressor. com/airless/tip-sizing.aspx

15 Emission Scenario Documents on Coatings Industry (Paints, Laquers, Varnishes). OECD Series on Emission Scenario Documents Number 22. ENV/JM/MONO(2009)24. http://www.oecd.org/offici aldocuments/displaydocumentpdf/?cote =env/jm/mono(2009)24&doclanguage=en

16 Migne, V. 2002. Supplement to the methodology for risk evaluation of biocides. Emission scenario document for biocides used as masonry preservatives (product type 10). Institut National De L’Environnement Industriel Et Des Risques (INERIS). CA-Jun03-Doc.8.2-PT10.

17 http://www.fpl.fs.fed.us/doc umnts/finlines/knaeb95b.pdf

18 Appendix C –Life Expectancy of Housing Components. National Association of Home Buliders Economics Department. http://www.metrohome. us/information_kit_files/life.pdf

19 Fellers, G.M, L.L. McConnell, D. Pratt, S. Datta. 2004. Pesticides in Mountain Yellow-Legged Frogs (Rana Mucosa) from the Sierra Nevada Mountains of California, USA. Environ. Tox. Chem. 23 (9):2170-2177.

20 Sparling, D.W., Fellers, G.M., McConnell, L.L., 2001. Pest icides and amphibian population declines in California

USA. Environ. Tox. Chem. 20: 1591-1595.

### 47 Valley eastward to the Sierra Nevada Mountains transporting airborne pollutants such as

chlorothalonil into the Sierra Ne vada ecosystems. In addition, lo cal ambient air monitoring data

from a site in North Dakota and three sites in Calif ornia, to list a few, indicate that chlorothalonil was present in the air at application sites and at locations up to a mile away from the application

sites. 22 

### Data from the state of Montana show detecti ons of chlorothalonil in precipitation. This indicates that chlorothalonil volatility or particle phase transport plays a role in the dissipation of chlorothalonil and that it is possible for chloroth alonil exposure to occur adjacent to application sites, as well as areas distant from ap plication sites (long range transport).

The magnitude of transport via secondary drif t depends on the amount of chlorothalonil that

becomes mobilized into air and its eventual re moval through wet and dr y deposition of gases, and particles and photochemical reactions in th e atmosphere. Currently, the Agency does not

have data on direct and indirect chlo rothalonil phototransformation (OCSPP 835.2370). Therefore, physicochemical properti es of chlorothalonil that describe its potential to enter the air from water or soil ( e.g. , Henry’s Law constant and vapor pre ssure), pesticide use data, modeled estimated concentrations in water and air, and ava ilable air monitoring data will be considered in evaluating the potential for atmospheric transpor t of chlorothalonil. In order to reasonably

estimate concentrations of chloro thalonil in air, additional information is needed, including flux data, for chlorothalonil from a fi eld volatility study (OCSPP 835.8100).

Volatilization from freshly applied wood preserva tive or exterior paints , stains, and coatings, stucco, grout, adhesives, sealants or volatilization from these materials after they have cured or dried is not expected to be a major or significant dissipation r oute or exposure pathway for nontarget organisms. Unlike agri cultural uses, applica tion of these products by homeowners or professionals is limited in both time and spatial extent. For example, homes made out of cedar or other wood types, depending on the harshness of the climates, are repainted every three to seven years, while newer siding materi als require paint every 10 to 15 years. 23 

### Spray applications are limited in spatial extent to areas smaller than a single house ( e.g ., furniture, concrete driveway or sidewalk), up to the size of a house or building structure. At such a

localized scale and limited time scale for vulnera bility to rapid volat ilization, and expected relatively instant dilution and turbulence in air, exposure of nontarget organisms would be negligible for these uses.

Runoff

Fate data indicate that chloro thalonil can dissipate in the environment after application via dissolved phase and sorption to eroded sediment. To gain a bette r idea of the potential exposure to chlorothalonil as a result of these dissipation pathways, PRZM (Pesticide Root Zone Model) will be used to simulate pesticide transport as a result of runoff and erosion from an agricultural field. In addition to model estimates, mon itoring data will also be evaluated.

21 LeNoir, J.S., L.L. McConnell, G.M. Fellers, T.M. Cahill, J.N. Seiber. 19 99. Summertime Transport of Currentuse pesticides from California’s Central Valley to the Sierra Nevada Mountain Range, USA. Environmental Toxicology & Chemistry 18(12): 2715-2722.

22 JOURNAL OF PESTICIDE REFORM/ WINTER 1997 • VOL.17, NO. http://64.233.161.104/s earch?q=cache:0yXOLRyW_IUJ:www.pesticide.or g/chlorothalonil.pdf+ chlorothalonil+moni toring&hl=en&gl=us&ct=clnk&cd=5

23 http://www.ehow.com/way_5231946_should-paint-house_.html

### 48 Monitoring data can elucidate what is happeni ng under current use practices and under typical conditions. Although monitoring data can provide a direct estimate of the concentration of a pesticide in water, it does not always provide a reliable estim ate of peak exposures because sampling may not occur where the highest pestic ide concentrations are found and/or sampling may not occur when the pesticide concentrations are the highest. In addi tion, monitoring is often conducted for purposes other than characterizing e xposure from a particular pesticide. A useful interpretation of monitoring va lues requires in-depth assess ment of the data. A thorough examination of available monitoring data will be conducted as part of the registration review exposure assessment. A brief summary of what is currently known about available monitoring data is provided below by media. The NAWQA (USGS National Water Quality Asse ssment Data Warehouse) is a national-scale assessment program that contains monitoring da ta for pesticides in streams. The NAWQA monitoring program was not design ed to specifically target ch lorothalonil use; however, the

database includes data for chlorothal onil (NAWQA parameter codes 49306 and 70314). NAWQA reports chlorothalonil detections in su rface water. These data will be evaluated and specific attention will be paid to the sample timing and frequency of sampling.

California Department of Pesticide Regulation (CalDPR) also has data on detections of chlorothalonil in surface water samples.

The Agency invites submission of water quality data for chlorothalonil. To the extent possible, data should conform to the quality standards in Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water B ody and Other Water Quality Data in OPP’s Registration Review Risk Assessment and Management Process (see: http://www.epa.gov/oppfead1/cb/p pdc/2006/november06/session1-sop.pdf ), in order to ensure they can be used quantitatively or qual itatively in pesticide risk assessments.

Soil Leaching

NAWQA reports detections of chlorothalon il transformation products in groundwater. In addition, groundwater monitoring data fr om Suffolk County, New York (MRID 44006001, 1996) confirmed that chlorothalonil metabolites were present in ground water. These data will be evaluated and specific attention will be paid to the sample timing and frequency of sampling.

Several interim reports [MRIDs 43959401 (1996), 43959402 (1996), and 44254801 (1997)] submitted to the Agency by the registrant fo r a small-scale prospective groundwater study suggest that chlorothal onil and some of its environmental transformation products can leach to groundwater. The final report for this study has not been submitted to the Agency. To date the interim reports have not been fully reviewed. Th e Agency will consider all available data during the risk assessment phase of registration review.

### 49 Treated Wood Leaching

No leaching studies of chlorothalonil and its major transformation products are available for

treated wood. These data are needed to conduc t the ecological assessment for wood preservative

uses.”

Clean Water Act

Organochlorine pesticides are identified as a cau se of impairment for two water bodies listed as impaired under section 303(d) of the Clean Wate r Act as of the water body report completed in

2010. 24 

### It is unclear if chlorothalonil is one of th e organochlorine pesticides contributing to the water body impairment. The two water bodies are Ni agara River, upper, main stem and Niagara River, lower, main stem. A Total Maximum Daily Loads (TMDL) 25 

### has not been developed for chlorothalonil or organoc hlorine pesticides.

SDS-3701

As mentioned above, chlorothalonil is likely to transform to form SDS-3701 under various

environmental conditions. SDS-3701 is much mo re soluble (115.7 mg/L at 25 °C; EPI Web 4.0 WSKOW v. 1.41) than chlorothalonil. Laborat ory studies suggest that SDS-3701 may also transform through microbial-mediate d processes, and is more mob ile than chloro thalonil (see Tables 6, 7, and 9 ). A summary of the environmental fate properties of SDS-3701 is provided in

Table 9 . A detailed discussion of each of the releva nt environmental fate studies is provided in

the subsections below.

Table 9. Environmental Fate Parameters of SDS-3701

Parameter Value Source Classification; Comments

Abiotic Transformation Mechanisms Hydrolysis Half-life No data Soil Photolysis Half-life No data

Biotic Transformation Mechanisms

Aqueous Photolysis

half-life No data Concentrations of SDS-3701 can be added to chlorothalonil in a total toxic residue approach to account for this uncertainty. 1

Aerobic Soil

Metabolism Half-life No data Concentrations of SDS-3701 can be added to chlorothalonil in a total toxic residue approach to account for this uncertainty.

Anaerobic Soil

Metabolism Half-life No data Concentrations of SDS-3701 can be added to chlorothalonil in a total toxic residue approach to account for this uncertainty.

Aerobic Aquatic

Metabolism Half-life No data Concentrations of SDS-3701 can be added to chlorothalonil in a total toxic residue approach to account for this uncertainty.

Anaerobic Aquatic

Metabolism Half-life No data Concentrations of SDS-3701 can be added to chlorothalonil in a total toxic residue approach to account for this uncertainty.

24 http://iaspub.epa.gov/tmdl_waters10/attains_nation.cause_detail_303d?p_cause_group_id=885&p_cycle=2010

25 http://www.epa.gov/owow/tmdl/

### 50 Parameter Value Source Classification; Comments
Mobility Range of Freundlich soil-water partition coefficients (K F ); exponent (1/n) value;

andorganic carbonnormalized coefficients (K FOC ) 5, 9, and 11 L/kg-soil 0.96, 0.87, and 0.91; and 718, 351 and 559 mL/g OC MRID 46786901 Supplemental

Field Dissipation

Terrestrial field dissipation half-life No data Concentrations of SDS-3701 can be added to chlorothalonil in a total toxic residue approach to account for this uncertainty.

1 This approach can only be used for SDS-3071 as it is identified in the chlorothalonil studies. 

### EPA does not currently anticipate requiring any environmental fate-r elated data for any of the

other chlorothalonil environmen tal transformation products or manufacturing byproducts like

HCB and dioxin/furans. In the absence of these data, if degradates of similar toxicity to

chlorothalonil are identified as re sidues of toxicological concern a total toxic residue method will be employed to derive estimated environmental concentrations.

Environmental Transport Assessment for Conventional Pesticide Use

Possible routes of transport of pesticides, and pesticide tr ansformation products including

chlorothalonil and its environmental transformation products, are illustrated in Figure 4 . In addition to fate data, monitoring data suggest that chlorothalonil can dissip ate in the environment after application via dissolved pha se (dissolved in water); eroded sediment, spray drift, and volatilization are probable e nvironmental transport mechan isms for chlorothalonil. Chlorothalonil applications can lead to surface wate r contamination as a result of spray drift as well as through runoff and sediment erosion. Aer obic soil metabolism data indicated that once

chlorothalonil reaches the soil it can be transf ormed to SDS-3701 (a transformation product of toxicological concern) as well as several other transformation products (discussed further in the environmental fate section of this document). The soil/water partitioning of chlorothalonil indicates that chlorothalonil runoff is generally by dissolution in runoff water rather than soil erosion ( i.e. , chlorothalonil is not expected to readily sorb to soil and sediment). Chlorothalonil may also leach through the soil. SDS-3701 may also reach surface water though runoff and

sediment erosion. SDS-3701 as well as other chlorothalonil soil transformation products has been shown to leach to groundwater. Once in su rface water, chlorothalonil is expected to transform rapidly via aqueous photol ysis as well as metabolism.

### 51 Figure 4. Potential Routes of Pestic ide Dissipation in the Environment

Environmental Transport Assessment fo r Antimicrobial Pesticide Uses

For chlorothalonil applied to wood ( e.g. , lumber, timber) at the indus trial scale by dip (bulk and non-bulk vats), pad, spray, or pressure treatm ent, there is potential for emissions of chlorothalonil and its major tran sformation products to waste wa ter treatment plants (WWTPs) with subsequent discharge to surface water, and to soil and surface water from leaching of treated wood during storage and in-servi ce use of the wood (OECD, 2000) (see Figure 7 ). Manufacturing of paints, stains, a nd coatings with film preserva tives added can also result in discharge of chlorothalonil to WWTPs. For chlo rothalonil spray, pad, or brush applied as a wood preservative or as an antimildew/antimold surf ace protectant, leaching from exterior surfaces of treated items ( e.g , fencing, shakes, decking, treated concrete, stucco, etc .) to soil with subsequent

run-off to surface water and/or l eaching from soil to groundwater has the potential to occur.

Aerobic soil metabolism data indicated that once chlorothalonil reaches the soil it can be transformed to SDS-3701 (a residue of potential t oxicological concern) as well as several other transformation products (discussed further in the environmental fate section of this document). The soil/water partitioning of chlorothalonil indi cates that chlorothaloni l runoff is generally by

dissolution in runoff water rather than soil er osion. Chlorothalonil may also leach through the soil. SDS-3701 may also reach surface water though runoff and sediment erosion. SDS-3701 as well as other chlorothalonil soil transformation products has been shown to leach to groundwater. Once in surface water, chlorothalonil is expected to transform rapidly via aqueous photolysis as well as aqueous metabolism.

E. E COLOGICAL 

### E FFECTS



### The Agency evaluates the potential for adverse e ffects as a result of chlorothalonil usage. As described in the Agency’s Overview Docu ment (U.S. USEPA, 2004), the most sensitive endpoint for each taxon is evaluated. Assessment endpoints include direct toxic effects on the survival, reproduction, and growth of terrestrial and aquatic life, as well as indirect effects, such as reduction in prey base and/or modification of habitat. The ev aluated taxa include freshwater and estuarine/marine fish, freshw ater and estuarine/marine invert ebrates, aquatic plants, birds, mammals, terrestrial invertebrates, and terrestrial plants. The environmental fate and toxicity of

### 52 chlorothalonil have been discu ssed in depth in the 1997 Science Chapter for the Reregistration Eligibility Decision document published in 1999, a nd readdressed in previous risk assessments (D301163, D301165, 2004 and D371947, 2009). A brief summary of toxicity data is provided in

Tables 10 through 12 . Toxicity endpoints are based on da ta generated from guideline studies submitted by the registrant, and from open literature studies that meet the criteria for inclusion into the ECOTOX database maintained by the Of fice of Research and De velopment (U.S. EPA, 2004). 26



### Acute (short-term) and chronic (long-term) toxi city information is characterized based on registrant-submitted studies and a comprehensive review of the open literature on chlorothalonil. Other sources of information, including use of the acute probit dose response relationship to establish the probability of an individual effect and reviews of ecological incident reports, are

conducted to further refine the characterization of potential ecol ogical effects associated with exposure to chlorothalonil. A summary of the ava ilable ecotoxicity information and the incident information for chlorothalonil are provided below.

The available data for chlorothalonil ( Tables 10 and 11) indicate that the technical grade active ingredient (TGAI) is:

• Very highly toxic to freshwater and saltwater organisms (96-h LC 50 

### = 18 μg a.i./L, rainbow trout; 48-h EC 50 

### = 54 μg a.i./L, freshwater crustacean);

• Practically nontoxic to small mammals on an acute oral basis, based on rat data (LD 50 

### >10,000 mg/kg-bw;

• Practically nontoxic to birds on an acute oral basis (LD 50 

### >4,640 mg/kg-bw for mallard ducks and >2,000 mg/kg-bw for Japanese qua il) and a sub-acute dietary basis (LD 50 

### ≥ 21,500 mg a.i./kg-diet for mallard and >10,000 mg a.i./kg-diet for bobwhite quail);

• Practically nontoxic to honey bees (LD 50 

### > 181 μg/bee);

Also:

• The EC 50 

### for non-vascular aquatic plants (freshwa ter diatoms) is 12 μg a.i./L, and the

EC 50 

### for aquatic vascular plants ( duckweed) is 640 μg a.i./L;

• The EC 25 

### for inhibition of growth in terrestria l plants is approximately 16 lb a.i./A.

For birds, no mortality occurred in studies that tested up to 4640 mg/kg-bw in an acute oral gavage study and at dietary concentrations up to 21,500 mg a.i./kg-diet in subacute studies. However, there was reduced body weight gain at va rious concentrations inseveral of the acute and sub-acute studies ( e.g., MRIDs 00068753, 00030388, 00039146). For mammals, no mortality occurred up to 10,000 mg/kg- bw, the highest dose tested, but clinical signs of toxicity ( e.g ., decreased activity, diarrhea, tremors, and decr eased reflexes and muscle tone) were present (MRID 00094941).

Chronic toxicity studies established the followi ng no-observable adverse effect concentration (NOAEC) values: birds 153 mg a.i./kg-diet, bobwhite quail; small mammals 1,200 mg a.i./kg-

26 http://cfpub.epa.gov/ecotox/

### 53 diet, rat; freshwater fi sh 1.3 μg a.i./L, fathead minnow; fres hwater invertebrates 0.6 μg a.i./L, daphnia; and estuarine inverteb rates <0.65 μg a.i./L, mysid.

Tables 10 and 11 summarize the most sensitive ecological toxicity endpoints for parent chlorothalonil based on currently available data. A brief summary of submitted data considered relevant to this ecological risk assessment is presented below. Additional data have also been submitted by the registrant regarding toxicity of a multi-a.i. formulation (chlorothalonil and penthiopyrad) to a variety of non- target terrestrial invertebrates. These will be reviewed and evaluated to determine potential use in the ecological risk assessment.

Table 10. Aquatic Toxicity Profile for Chlorothalonil

Taxon Exposure

Duration Most Sensitive Species Tested Toxicity Value Acute Toxicity Category Classification Source

Freshwater Fish Acute Rainbow trout Onchorynchis mykiss 96-hr LC 50 = 18 μg a.i./L Very Highly

toxic Acceptable MRID

45710219

Chronic Fathead minnow Pimephales promelas NOAEC = 1.3 μg ai/L N/A Supplemental 1 MRID

00030391

Freshwater

Invertebrates Acute Water Flea Daphnia

magna 48-hr EC 50 = 54 μg a.i./L Very highly

toxic Acceptable MRID

45710221

Chronic Water Flea Daphnia magna 21-day

NOAEC = 0.6 μg ai/L N/A Supplemental 2 MRID

45710222

Saltwater Fish Acute No acceptable study available 3

Chronic No data available

Saltwater

Invertebrates Acute Eastern oyster

Crassostrea

virginica 96- hr

EC 50 = 3.6 μ g a.i./L (shell deposition) Very highly

toxic Acceptable MRID

00138143

Chronic No acceptable study available 4

Non-vascular plant -- Diatom

Navicula pelliculosa 5-d EC 50 = 12 μg a.i./L

NOAEC = 3.9 μg a.i./L (based on area under curve) N/A Acceptable MRID

44908105

Vascular plant -- Duckweed Lemna gibba 7-d EC 50 = 640 μg ai/L

NOAEC = 290 μg ai/L (based on dry wt) N/A Acceptable MRID

44908102

### 54 Taxon Exposure

Duration Most Sensitive Species Tested Toxicity Value Acute Toxicity Category Classification Source

1 This endpoint is appropriate for quantitative use; classifi ed Supplemental due to replicate size and solvent control mortality.

2 Classification based on instability of the test substance as measured concentrations were below detection for several concentrations at the end of a renewal period. The endpoint values for this study are derived on the basis of biological significance and not statistical significance. Given that the study was conducted as a static renewal with

non-detection levels accounted for in the concentration es timates by using a value of zero for the non-detects [i.e. the compound was unstable be tween media renewal intervals but the shape of the decline curve for the chemical is unknown].

3 A study with sheepshead minnow was available (MRID 00127863); however, given the uncertainties in the exposure concentrations (nominal concentrations in a static system), the endpoint value is for qualitative use only and a new study is requested.

4 A mysid life-cycle study (MRID 42433807) was available and originally the st udy was classified as unacceptable. Prior to Registration Review, the study was reclassified to acceptable, but as part of a re-evaluation during Registration Review, it has been down graded to unacceptable once again.



### Table 11. Terrestrial Toxicity Pr ofile for Chlorothalonil

Taxon Exposure

Duration Most Sensitive Species Tested Toxicity Value Acute Toxicity Category Classification Source

Mammals Acute Oral Rat

Rattus norvegicus LD 50 = >10,000 mg/kg-bw Practically

non-toxic Acceptable MRID

00094941

Chronic Repro Rat R. norvegicus
2-Generation

repro NOAEL = 1,200 mg a.i./kg-diet (92.5 mg a.i/kg-bw) LOAEL = 3,000 mg a.i./kg-diet N/A Acceptable MRID

45710209

Birds Acute Oral Passerine species No Data -- -- --

Mallard Duck

Anas platyrhynchos LD 50 >4640 mg/kg –

bw Practically

non-toxic Acceptable MRID

00068753

Subacute

dietary Mallard Duck A. platyrhynchos LC 50 >21,500 mg a.i./kg-diet Practically

non-toxic Acceptable MRID

00039146 Bobwhite quail

Colinus virginianus LC 50 >10,000 mg a.i./kg-diet Practically

non-toxic Acceptable MRID

00030388

Chronic Repro Bobwhite quail C. virginianus NOAEC = 153 mg a.i./kg-diet LOAEC = 624 mg a.i./kg-diet N/A Acceptable MRID

45710218

Terrestrial

Invertebrates Acute Honey Bee Apis mellifera LD 50 >181 μg a.i./bee Practically

non-toxic Acceptable MRID

00077759

Terrestrial

Plants Seed germination/seedling

emergence-- Tier 1 10 species EC 25 = >16 lb a.i./A

NOAEL < 16 lb a.i./acre (for onion) N/A Acceptable MRID

42433808

Vegetative vigor--Tier 1 10 species EC 25 = >16 lb a.i./A

NOAEL < 16 lb

a.i./acre (for cucumber) N/A Acceptable MRID

42433809

### 55 The major degradate of chlorothal onil previously identified as oftoxicological concern is SDS3701. The toxicity data for this chemical, summarized in Table 12 , are available for freshwater fish/invertebrates, aquatic pl ants, mammals, and birds.

For the major degradate SDS-3701 acute to xicity data indicate that it is:

• Moderately toxic to very hi ghly toxic (more toxic than parent) to small mammals (oral

LD 50 

### = 242 mg/kg-bw, rat acute; 6 mg/kg-bw, rat chronic);

• Slightly toxic to moderately toxic (m ore toxic than parent) to birds (LD 50 

### = 158 mg/kgbw, mallard duck acute oral toxicity; 1746 ppm, bobwhite quail sub-acute dietary toxicity);

• Slightly toxic to moderately toxic (less toxi c than parent) to aquatic organisms (96-hr

LC 50 

### = 9.2 ppm, bluegill sunfish; 48-h EC 50 

### = 26 mg/L, daphnia); and

• Less toxic than parent to algae (EC 50 

### = 33.7 mg/L).

Table 12. Aquatic and Terrestrial Toxicity Profile for SDS-3701

Taxon Exposure

Duration Most Sensitive Species Tested Toxicity Value Acute Toxicity Category Source

Freshwater

Fish Acute Bluegill sunfish Lepomis macrochirus 96 h LC 50 = 9,200 μ g/L

SDS-3701 Moderately

toxic Ernst et al., 1993 1

Freshwater

Invertebrates Acute Water Flea Daphnia magna 48 h EC 50 = 26,000 μ g/L

SDS-3701 Slightly toxic Killeen et al., 1977 2
(MRID 00030394)

Vascular

Plant -- Duckweed Lemna gibba No data available

Non-vascular plant -- Green Alga

Selenastrum capricornutum EC 50 = 33,700 μ g/L SDS3701 NA Ernst et al 1993

Mammals Acute Oral Rat Rattus norvegicus LD 50 = 242 mg/kg-bw

SDS-3701 Moderately

toxic MRID 00001098

Chronic Repro Rat R. norvegicus

1-Generation repro

3-Generation repro NOAEL = 6 mg/kg-bw (120 mg a.i./kg-diet)

SDS-3701 No LOAEL

NOAEL = 6.25 mg/kg-bw (125 mg a.i./kg-diet )

SDS-3701 No LOAEL NA MRID 00127845

MRID 00127844

Birds Acute Oral Mallard Duck Anas platyrhynchos LD 50 = 158 mg/kg–bw

SDS-3701 Moderately

toxic MRID 00030395

Subacute dietary Mallard Duck A. platyrhynchos LC 50 = 2000 mg a.i./kgdiet SDS-3701 Slightly toxic MRID 00115108

Bobwhite quail Colinus virginianus LC 50 = 1746 mg a.i./kgdiet SDS-3701 Slightly toxic MRID 00115109

Chronic Repro Mallard Duck A. platyrhynchos NOAEC = 50 mg a.i./kgdiet

SDS-3701 LOAEC = 100 mg/kg N/A MRID 40729402

### 56 Taxon Exposure

Duration Most Sensitive Species Tested Toxicity Value Acute Toxicity Category Source

SDS-3701

Bobwhite quail C. virginianus NOAEC = 100 mg a.i./kgdiet SDS-3701LOAEC = 250 mg a.i./kgdiet SDS-3701 N/A MRID 40729404

Terrestrial

Invertebrates Acute Honey Bee Apis mellifera No Data for SDS-3701

-- --

Terrestrial plants N/A N/A No Data for SDS-3701

-- --

1 Due to reporting deficiencies in the available document, these values should only be used qualitatively.



### Effects to Aquatic Organisms

Freshwater Invertebrates - Acute Exposure Studies

Chlorothalonil (TGAI, Parent)
An open literature study (Davies et al ., 1994) reported 96-hour LC 50 

### values for two invertebrate species that were more sensitive to chlorothalonil than daphnids (48-h EC 50 

### of 54 μg a.i./L). 96-

hour LC 50 

### values for the giant freshwater crayfish ( Astacopsis gouldi ) and the freshwater atyid shrimp ( Paratya australiensis ) were 12 μg a.i./L and 16 μg a.i. /L, respectively. Details of the study were not reported in the article such as poten tial prior pesticide exposu re of the wild caught

P. australiensis , the five test concentration levels, and control survival performance. Finally, the invertebrates in the study were fed crumbled commercial salmon food which may be an adequate substrate for chlorothalonil to bind (log K

ow 

### 3.8); therefore, the bioa vailability of the test compound is an uncertainty.

The technical grade study on the wate r flea (MRID 45710221) indicated a 48-hour EC 50 

### of 54 μg a.i./L based on immobility of the test organisms. Cumulative immobility was 0% in the negative and solvent control groups , and 0, 0, 5, 5, 40, 100, 95, 100, and 100% in the mean-measured concentration 5.1, 9.3, 16.9, 31.6, 51.5, 95.2, 169.5, 286.7, and 491.6 μg a.i./L test groups. Given the uncertainty in the open literature study (Davies et al. 1994) endpoints, this latter study would provide the next most sensitive and valid endpoint for use in risk estimation. In all cases, the technical grade active ingredient of chlorothalonil is considered very highly toxic to freshwater

invertebrates.

OCSPP guideline spiked-sediment toxi city tests for freshwater and estuarine/marine sedimentdwelling organisms to address exposure from bot h water and sediment are not available. A 28- day whole sediment spiked-water study, which followed OECD 219 guidance, with Chironomus riparius is available but has not been forma lly reviewed (MRID 45425801). In this study, chlorothalonil was applied at test initiation to the overlying water; the OECD guideline is reflective of a single spray drif t or run-off event exposure scen ario. According to the study author, residues of chlorothalonil were found in pore water and sediment [concentrations not reported] from the highest test concentrati on (0.5 mg/L) at 24 hour a nd 7 days and in the sediment at 28 days. Also, at this high test concentration, 0. 5 mg/L, there was 0% emergence after 28 days with the next lower concentration results comparable to the control. The study

### 57 provides evidence that chlorothalonil is toxic to sediment-dwelling organisms in a watersediment test system. Chronic sediment toxicity testing of midges shoul d include an evaluation of reproduction, as well as survival, emer gence, and growth. The OECD 219, OCSPP 850.1735 and OCSPP 850.1740 do not evaluate reproduction and ar e considered short-term or sub-chronic

tests.

Based on the guidance outlined in 40 CFR Part 158 for sediment organism testing, chlorothalonil meets the requirements for sediment testing: K

ow 

### ≥ 3; K d 

### ≥ 50 and K

oc 

### ≥ 1000. An evaluation of the persistence of chlorothalonil in soil indicates representative half-lives range from 1 day to 243 days (aerobic soil metabolism) and that the tran sformation rate is app lication rate dependent. Based on the data presented in Table 8 , the half-life value for th e currently approved maximum chlorothalonil application rate is likely between 18-35 days; however, additional data are being requested to confirm this assumption. Aerobic aquatic representative half-life values are generally less than 10 days base d on total system (water and sedi ment). For the aerobic aquatic studies, chlorothalonil is added to the water co lumn, and as chlorothal onil may enter aquatic systems via runoff through sorbtion to soil partic les, there is uncertain ty in the rate of chlorothalonil dissipation in the water-sediment system. Chlorothalonil is expected to reach aquatic environments from spray drift, as we ll as leaching and runoff, and based on its use patterns, it has the potential to reach both freshwater and estuar ine/marine environments. As the fate studies suggest that chlo rothalonil may dissipate in the aquatic environment under aerobic conditions, it is requested that the 10-day whole sediment toxicity studies be conducted following OPPTS 850.1735 and 850.1740 guidelines. It is also requested that studies be conducted on freshwater organisms, Chironomus tentans and Hyallela azteca, as well as the recommended estuarine/marine organism, Leptocheirus plumulosus . However, since chlorothalonil may be persistent in terrestrial environments, based on the aerobic soil metabolism data, and is expected to enter aquatic envir onments through runoff, this runoff may provide a more chronic or pulsed exposure to sediment organi sms. Therefore, it is recommended that after the 10-day studies along with the requested enviro nmental fate data are submitted and reviewed,

if there is evidence that chroni c toxicity testing is warranted (based on observed toxicity and persistence in the 10-day studies and modeled chronic EECs), then chronic testing will likely be requested. Chronic testing woul d evaluate reproduction as we ll as survival and growth; additionally emergence for midge species.

End-Use Product (TEP, Formulation)

The conventional end-use product, Bravo 720 (54% a.i.), was tested on the water flea at the following mean-measured test concentrati on levels: 50, 91, 160, 260, and 420 μg form/L (equivalent to 27, 49, 86, 140, and 227 μg a.i./L ). This study (MRID 42433806) indicated an

EC 50 

### of 97 μg a.i./L based on immobility (equivalent to mortality) of the test organisms, whereby the mean cumulative immobility at 48-hours wa s 0% in the negative control group, and 0, 0, 30, 95, and 100% in the respective tested concentrations . As in the case of the technical grade active ingredient, the end-use product is also consider ed to be very highly toxic to freshwater

invertebrates.

SDS-3701 (Degradate)

### 58 The chlorothalonil degradate, SDS-3701, appears to be considerably less toxic than parent

chlorothalonil as either technical grade or end-use product to freshwater invertebrates. The 48-

hour LC 50 

### in the water flea was 26,000 μg a.i./L (M RID 00030394) based on mortality of the test organisms, whereby average percentage morta lity was 0, 7, 27, 87, 80, and 100% in the nominal
test concentrations 10,000, 15,000, 22,000, 32,000, 46,000, 68,000, and 100,000 μ g a.i./L. An acetone solvent was used; the negative and solvent controls had 0% mortality at 48-hours. As

these values are based on nomi nal concentrations, and the degr adation of SDS-3701 in water is not known, there is uncertainty in what the actual exposur e concentrations were.

Freshwater Invertebrates - Chronic Exposure Studies

Chlorothalonil (TGAI, Parent)

A chronic study using the parent chlorothalonil as the test substance yielded an overall 21-day survival-based NOAEC of 0.6 μg a.i./L (MRID 45710222) with the water flea. The LOAEC in this study was 1.8 μg a.i./L, which was based on in creased mortality. After 21 days of exposure, cumulative adult mortality/immobility was 7% for both control groups (acetone and negative), and 5, 25, 40, 55, and 60% in the mean-measured concentrations <0.0001 (<limit of detection, solvent control), 0.60, 1.8, 5.8, 19, and 75 μg a.i. /L, respectively. Ther e was a significant inhibitory effect on reproduction (number of live young/adult) at the 75 μg a.i./L test level. The total number of live young produced per adult was ≥ 40 for the control through 19 μg a.i./L test groups, and was 31 for the 75 μg a.i./L group. No dead young were observed during the study in any test group, and the number of unhatched eggs per adult wa s <1 for all control and test groups. Terminal growth measurements were not performed.

However, chlorothalonil was unsta ble under the static renewal conditions employed in this test, declining to less than the level of detection to 62% of nominal concentra tions in expired test

media. Because chlorothalonil concentrations declin ed to less than the le vel of detection at the lower concentrations, there is c onsiderable uncertainty in the chlorothalonil levels associated with toxic effects in this study. Thus, the study was classified supplemental. Furthermore, the most sensitive endpoint, survival, for this study was derived on the basis of biological significance and not statistical si gnificance. The study was conducte d as a static renewal with

non-detection levels accounted for in the concentration estimates and represented as a value of zero ( i.e., the compound was unstable between media renewal intervals but the decline of

chlorothalonil in the water column could not be determined as concentrations were only measured at the beginning and end of a renewal period).

As there is uncertainty in the mean measured test concentrations, gi ven that chlorothalonil dissipated during the renewal periods, there is uncertainty if the NOAEC value accurately reflects the actual exposure concentrations. However, it is determined that the observed mortality effect is treatment related and the reported NOAE C value will be used in the risk estimation calculation. However, a second chronic Daphnia study with a higher reported NOAEC will be

used to characterize risk to fres hwater aquatic invertebrates. Th e second chronic study utilized a flow-through test design and pare nt chlorothalonil as the test substance; the water flea study

### 59 yielded a 21-day NOAEC of 39.5 μg a.i./L (MRID 00115107) based on both survival and cumulative number of offspring produced per female.

Estuarine/Marine Invertebrates - Acute Exposure Studies

Chlorothalonil (TGAI, Parent)

Significant reductions in she ll deposition were observed in the eastern oyster study (MRID 00138143) for the six measured concentrations tested (ranging 0.6 – 30.8 μ g a.i./L), yielding a

96-hr EC 50 

### of 3.6 μ g/L (95% CI of 2.9 – 4.3 μ g a.i./L). Chlorothalonil is considered very highly

toxic to estuarine-marine mollusks.

On the basis of mortality in the 96-hour study (MRID 00127864) conducted on the pink shrimp ( Penaeous duorarum ), the 96-hr LC 50 

### was 165 μ g/L. Chlorothalonil is considered highly toxic to estuarine-marine shrimp.

As described above, spiked-sediment data for estuarine/marine sediment organisms are not available but are requested.

End-Use Product (TEP, Formulation)

The single study on a conventional pesticide fo rmulated product (B ravo; 75% a.i.) and dungeness crab larvae ( Cancer magister ) was an open literature study (MRID 00127865), which was deemed supplemental as it provided some useful information; however, due to missing information on dose concentrations and possible c ontrol contamination, the study is reclassified to unacceptable and will not be used further in the risk assessment.

Estuarine/Marine Invertebrates - Chronic Exposure Studies

Chlorothalonil (TGAI, Parent)

A mysid shrimp ( Americamysis bahia formerly called Mysidopsis bahia ) chronic toxicity test (MRID 42433807) that may be reporte d in previous risk assessm ents was re-evaluated for registration review. A recalcu lation (Dunnett’s test) of the e ndpoints for this study using the current methodology of using the negative contro l yielded a significant difference at every

concentration level and a non-definitive NOAEC of <0.65 μ g a.i./L. On this basis and additional issues with the study, this study has been re-c lassified to unacceptable and a new study is requested at this time.

Freshwater Fish - Acute Exposure Studies

Chlorothalonil (TGAI, Parent)

There are several acute freshwater fish toxi city studies available. The reported 96-h LC 50 

### values for freshwater fish range from 10.5 to 120 μg a.i./L. For the study with the most sensitive 96-h

LC 50 

### value of 10.5 μg a.i./L using rainbow trout, a co-stressor of reduced oxygen ( ca . 50% of

### 60 saturation) was used in the study (Ecotox 87454 ;7055); therefore, this study was deemed not appropriate for use in the risk estimation (risk qu otient) evaluation. Howeve r, it will be used during the risk description/char acterization of chlorothalonil for freshwater fish. The second most sensitive study, which also us ed rainbow trout, reported a 96-h LC 50 

### value of 18 μg a.i./L and this value will be used to calculate the risk quotient (MRID 45710219). In this study, swimming and/or hanging at the surface, lethargy , loss of equilibrium, and/or moribundity were observed in surviving fish from the ≥ 17.7 μg a.i./L groups; effects were first observed within 6 hours of exposure and continued through 96 hours in groups with surviving fish. The observed NOEC (for mortality and sub-leth al effects) was 8.5 μg a.i./L.

A 96-hour fathead minnow (4-8 day old larvae) LC 50 

### value was also conducted in the fathead minnow chronic life-cycle study (discussed below) and was reported to be 23 μg/L by the study authors. This value was calculated using mean measured concentrations during a 35 day testing period in which the first sample was collected on Day 6. The 96-h LC 50 

### value was recalculated (using Toxanal) using the reported 35 day mean measured concentrations for a 96-hour value of 16 μg/L. As there is uncertainty in the LC 50 

### value due to the uncertain ty in the actual exposure concentrations during the 96 hour period, the reported 96 hour valu e for the rainbow trout above will be used as the acute endpoint for the assessm ent (18 μg a.i./L) which is very close to the

calculated fathead minnow value.

End-Use Product (TEP, Formulation)

Laboratory acute toxicity studies with freshwater fish for conventional pestic ide chlorothalonil

formulations are available. The formulations tested include: Bravo W- 75 (75% a.i.) and Bravo 720 (54% a.i.). MRIDs 00087304, 00087303, and 00087258 (Bravo W-75 (75% a.i.) were considered in the 1999 RED; however , as part of the registration review process they were reevaluated. These studies were cond ucted as static test systems, did not report if a dilution water control group was used, and the results were base d on nominal concentrations, and as such these studies are now classified as unacceptable. For MRIDs 43302101 and 42433804, the test system was flow-through and the results were based on mean measured concentrations. The LC 50 

### values range from 49 to 61 μg/L (26 – 33 μg a.i./L) and are presented in Table 13

.

In the paper by Ernst, 1991 (MRID 44286001), for th e formulation, Bravo 500 (40% a.i.), the 96

hour LC 50 

### for the three-spine stickleback was <73 μg a.i/L (183 μg/L formulation; measured concentration); mortality on indivi dual test concentrations was not available. For rainbow trout,

the 96 hour LC 50 

### was 69 μg a.i./L (173 μg/L formulation; nominal) using Bravo 500, and this value was not statistically different (p<0.05) from th at of the technical (76 μg a.i./L, nominal).

### 61 Table 13. Acute Toxicity for Freshwater Fi sh for Chlorothalonil Conventional Use

Formulations

Test Species % a.i. (Formulation) LC 50 μg/L

Formulation Citation (MRID #) Toxicity Category 1

Rainbow trout 54 (Bravo 720) 61 (33.2 μg a.i./L) 43302101 very highly

toxic

Bluegill 54 (Bravo 720) 49 (26.3 μg a.i./L) 42433804 very highly

toxic

Rainbow trout 40 (Bravo 500) 173 (69 μg a.i./L Ernst et al.,

1991 (44286001) highly toxic

Three-spined

stickleback 40 (Bravo 500) <183 (< 73 μg a.i./L) Ernst et al.,

1991 (44286001) highly toxic

1 based on formulated product



### Additional data have also been submitted by the registrant regarding toxicity of a multi-a.i. formulation (chlorothalonil and pe nthiopyrad) to a variety of non-targ et terrestrial invertebrates. These will be reviewed and evaluated to determine potential use in the ecological risk

assessment.

SDS-3701 Degradate

SDS-3701 acute toxicity tests with bluegill sunfish are available. For both MRID 00029415 and 00030393, the 96-h LC 50 

### values of 45,000 and 15,000 μg/L, re spectively, are uncertain as dissolved oxygen was not measured in all treatments, some of which had significant mortality; where dissolved oxygen was measured it was less th an 60% of saturation during some period of testing. Therefore, the potentia l co-stressor of low oxygen may have been present during both of these studies which may have influenced the toxicity and rend ers the reported LC 50 

### values unreliable. Although the co-stre ssor of low dissolved oxygen ma kes it difficult to interpret whether the observed mortality was attributed to chlorothalonil or to the low dissolved oxygen, it appears that SDS-3701 is less toxi c than parent chloro thalonil to freshwater fish. For MRID 00030393, at a nominal concentration of 6,000 μg/L where the dissolved oxygen was 8% of saturation at 96 hours, there was no observed mortality with the bl uegill. Another study conducted with bluegill reported a 96 hour LC 50 

### of 9,200 μg a.i./L (E rnst, 1993); however, control performance and a summary of mortality in the treatment groups as well as measured concentrations were not reported and as such th is study will be used qualitatively. However,

additional studies with SDS-3701 ar e not requested at this time.

Freshwater Fish - Chronic Exposure Studies

Chlorothalonil (TGAI, Parent)

A chronic toxicity test for chlorothalonil w ith fathead minnow was available (MRID 00030391). The study authors reported NOAEC was 3.0 μg/L base d on significantly reduced number of eggs per spawn and hatchability of F1 eggs at 6.5 μg/L. The study authors performed statistics on number of eggs/spawn; however, a decrease in the total number of spawns and eggs was observed in the 3.0 μg/L compared to the control. The number of eggs per female in the negative

### 62 control was 494 whereas it was 103 in the 3.0 μg/L group; however, because there is inherent variability in egg production and the use of only two replicates, this decrease (79% difference) was not significant. However, the decrease is thought to be biologically significant and treatment-related and therefore, the NOAEC is 1.4 μg/L where the number of eggs per female was 459. The report did not indicate if the test solutions were adjust ed for purity (96%), therefore, the 1.4 μg/L value was adjusted for purity and the NOAEC to be used in the risk assessment is 1.3 μg a.i./L. During this study, all of the fish in the solv ent control replicate A died between day 16 and 33 due to microbial bu ildup which could not be controlled. Fish from solvent control B were placed in replicate A and these fish were carried out through the remainder of the study; in addition, the hatchi ng success for solvent control replicate A was significantly less than the negative control due to several ea rly egg spawns that did not hatch. Given this mortality and the use of two replicates that diminished the ability to detect significant differences, this study is re-class ified as Supplemental but a new study is not requested at this

time.

Chronic toxicity tests with the de gradate SDS-3701 were not available.

Estuarine/Marine Fish Acute and Chronic Exposure Studies

Chlorothalonil (TGAI, Parent)

For estuarine/marine fish, a sheepshead mi nnow study was available with a reported LC 50 

### of 33 μg/L (MRID 00127863). This study was conducted us ing 3-7 day old larvae. Sublethal effects were not reported but there was no mortality re ported at 30 μg/L. The study was conducted using ‘whole material’ and the purity of th e material was not reported. The LC 50 

### was recalculated using the current EFED model (Toxana l, June 12, 2009). This study was conducted using a static system without measuring the test concentrations and as such there is uncertainty in the actual exposure chlorothalonil concentrations. This uncer tainty is significant given that for several other studies conducted with chlorothalonil, ma intaining nominal concen trations was difficult even under flow-through conditions (MRI D 45710219; 00030391). This study has been reclassified as Supplemental and for qualitat ive use only. As such a new acute study with sheepshead minnow in which the test con centrations are monitored is requested.

A chronic toxicity test for an estuarine/marine fi sh species is not availa ble and as a result this study is considered to be a data gap. Based on the chlorothalonil convent ional agricultural use map in Figure 3 , chlorothalonil may potentially be pres ent in estuarine/marine environments, especially in the Southeast. As there is uncertainty in the acute LC 50 

### value for sheepshead minnow, and there are problems with calculating a fish acute-to-chronic ratio to extrapolate a chronic value for the sheepshead minnow—in the absence of data chronic risk to

estuarine/marine fish will be assumed. The onl y fish species with both an acute and chronic value was the fathead minnow, but given the expo sure uncertainties in the both the fathead

minnow acute LC 50 

### value and NOEC from the chronic st udy, using an ACR derived from these

values is not reliable.

### 63 Aquatic-phase Amphibians

In the paper by McMahon et al., 2011 toxicity of chlorothalon il to amphibians was evaluated. This study evaluated mortality in three different sp ecies of frogs. This paper will be considered for potential use in the risk assessment.

Aquatic Plants

Chlorothalonil (TGAI, Parent)

A chlorothalonil toxicity test wi th the aquatic vascular plant, Lemna gibba , is available and the 7-day EC 50 

### value is 640 μg a.i./L, based on dr y weight (MRID 44908102). The NOAEC is 290 μg a.i./L. The original review compared the chlorothalonil treatment groups to the pooled controls; therefore, dry weight endpoint was re-analyzed using the current methodology of using the negative control. In add ition, the study authors reported to xic symptoms as discolored leaves, reduced root growth, and small frond size in concentrations of 71 μg/L and higher from Day 2 onward. By the end of the experiment, similar symptoms were observed at the two lowest concentrations, 17 and 35 μg/L.

Several non-vascular toxicity tests using chloroth alonil are available. Th e most sensitive 5-day

EC 50 

### endpoint values for the freshwater ( Navicula pelliculosa ) and marine diatom ( Skeletonema

costatum ) were similar with values of 12 a nd 14 μg a.i./L, respectively (MRID 44908105; 44908103). A green algae, Selenastrum capricornutum, 5-day EC 50 

### value was 190 μg a.i./L (MRID 42432801). In the original review of thes e studies, the treatment groups were compared to a pooled control or solvent control and only the endpoint of cell density was analyzed. Therefore, cell density was re-analyzed using a comparison to the negative control and the additional endpoints of area under the curve, growth rate, and yield were an alyzed. Prior to this problem formulation, the study with Anabaena flos-aqua was deemed unacceptable due to higher than recommended starting cell density which may have had an impact on the study. Upon further review, growth in this study was deemed acceptable and therefore this study is upgraded to Acceptable (MRID 44908104). As stated above, the cell density was re-analyzed as well as the additional endpoints. An additional green alg ae study was available in the open literature and the reported EC 50 

### value was 6.8 μg a.i./L (Mezcua et al., 2002; Ecotox 80359). This study utilized the Algaltoxkit which is reported to be a miniaturized assay that uses ‘algal beads’, which can be stored for long periods of time, as th e initial source of the alga l cells. The assay is performed in disposable spectopho tometric cells of 10 cm path length, which are used as test vessels and analytical containers . This assay is reported to basically adhere to the ISO 8692

norm and the OECD 201 Test Guideline 27 

### . Since this study design seems to deviate substantially from the OPPTS 850.5400 guideline, this study, while reporting the most sensitive algal endpoint these results will only be used qualitatively.

SDS-3701 (Degradate)

27 http://www.microlan.nl/uploads/file s/qaqc/intercalibration_exercise_onthe_algal_toxicity_toxkits.pdf?phpMy Admin=90a1592554ecf76ebe7 c76e2d531280f (accesse d December 13, 2011).

### 64 A green algae ( Selenastrum capricornutum ) study with SDS-3701 was av ailable with a reported

EC 50 

### value of 33,700 μg a.i./L (Ernst et al., 1993). Details on the methodology were not provided in the report as well as a summary of the cell counts ther efore this study will be used qualitatively. However, additional da ta is not requested at this time.

Conventional Use Pesticide Field Studies

In the paper by Ernst, 1991 (MRID 44286001), sprayi ng of ponds at 875 g a.i. /ha (0.78 lb a.i./A) resulted in mortality of caged water boatmen ( Sigara alternate ) and threespine stickleback ( Gasterosteus aculeatus ) which could be related to chloroth alonil exposure. However, caddisfly larvae ( Limnephilus spp.), freshwater clams ( Psidium spp.), water beetles ( Haliplus spp.), scud ( Gramarus spp.) and midge larvae (Chironomidae) did not suffer substantial chlorothalonilinduced mortality. Changes in endemic benthic invertebrate abundance after sprays were not

remarkable or related to treatment. Faunal impacts on the pond were generally of smaller magnitude than were predicted by bioassay resu lts. Factors such as dilution, adsorption to suspended particles and microbial degradation are thought to have at tenuated the initial pond concentrations of chlorothalonil, thereby reducing the toxicity.

A field study was conducted in which Bravo 500 wa s applied 3 times to soybeans adjacent to an experimental and control pond (MRIDs 00071552, 00127862) and was preliminarily reviewed for Registration Review. However, after trea tment, maximum residues were 0.6 ppb and 1.1 ppb in the experimental and control pond water, resp ectively. The highest resi dues found in sediment were 51 ppb and 31 ppb in the experimental pond and control pond, respectively. As

chlorothalonil was detected in the control pond, this study is deemed invalid.

An additional mesocosm study, Ashwell, 2002 (MRID 46047304) is available and will be

reviewed.

Effects to Terrestrial Organisms

Birds

Chlorothalonil (TGAI, Parent)

One avian acute oral toxicity study is availa ble for chlorothalonil e xposure to Mallard duck ( Anas platyrhynchos ) (MRID 00068753). There were no mort alities observed during the study

and the LD 50 

### value was determined to be greater than 4,640 mg/kg-bw (t he highest concentration tested). Chlorothalonil is, therefor e, classified as practically non- toxic to birds on an acute oral basis. The LOAEC in this study was determined to be 2,150 mg a.i./kg-bw based on reduced body weight.

Avian subacute dietary toxicity studies have been submitted for Northern bobwhite quail ( Colinus virginianus ) (MRID 00030388) and mallard duc k (MRID 00039146). There were no mortalities at any exposure level for either the bobwhite quail or the mallard duck, and therefore

the LC 50 

### values are greater than 10,000 mg a.i./kg-di et and greater than 21,500 mg a.i./kg-diet, respectively. Chlorothalonil is, therefore, classified as prac tically non-toxic to birds on a subacute dietary basis. In the bobwhite quail st udy, there was a slight reduction in body weight

### 65 at the highest concentration te sted (10,000 mg a.i./kg- diet) and in the ma llard study there was reduced weight gain starting at the 4,600 mg a.i./kg-diet concentration.

The most sensitive avian reproduction toxicity study submitted for chlorothalonil was conducted using bobwhite quail (MRID 45710218). The results of this study were not included in the chlorothalonil RED, because it was not submitted to the Agency until after the RED was completed (however, it has been used in subs equent risk assessments). A NOAEC of 153 mg a.i./kg-diet and a LOAEC of 624 mg a.i./kg-diet were found, based on a reduced number of 14- day old survivors per hen (and th e related endpoint of reduced nu mber of eggs laid per hen). Although the endpoints were not st atistically significantly diffe rent than the controls, the

differences were considered bi ologically significant (there was an 18% reduction in the number of 14-day old survivors/hen and a 34% reduction in the number of eggs laid/hen at the 624 mg a.i./mg-diet concentration when co mpared to the controls).

SDS-3701 (Degradate)

SDS-3701 has been shown to be considerably more toxic than chlorothaloni l to birds on an acute

basis. The most sensitive LD 50 

### and LC 50 

### of 158 mg/kg-bw (mallard duck) and 1746 mg a.i./kgdiet (northern bobwhite quail), respectively, will be used to calculate RQs for the degradate (MRIDs 00030395 and 00115109, respectively). Availa ble avian reproduction studies using

SDS-3701 indicates that SDS-3701 is more toxic to bird reproduction than parent chlorothalonil. In mallard ducks and bobwhite quail, the NOAECs for SDS-3701 are 200- and 1.5-fold lower, respectively, than NOAECs for chlorothalonil. The NOAEC for mallard ducks and SDS-3701 is 50 mg a.i./kg-diet (the LOAEC is 100 mg a.i./kg-diet based on re duced egg-shell thickness; there were also the following effects noted at 250 mg a.i./kg-diet – reduced adult body weight, food consumption, number of eggs laid, hatchabili ty, and hatchling survival) (MRID 40729402). The NOAEC for bobwhite quails and SDS-3701 is 100 mg a.i./kg-diet (the LOAEC is 250 mg a.i./kg-diet based on reduced number of eggs laid and hatchling survival) (MRID 40729404).

Mammals

Chlorothalonil (TGAI, Parent)

Chlorothalonil is practically non-toxic to mammals [rat ( Rattus norvegicus) ] on an acute oral basis (LD 50 

### >10,000 mg/kg-bw, MRID 00094940). Reprodu ctive impairment was not observed in two 2-generation reproduction to xicity studies with rats ( R. norvegicus ) (MRIDs 41706201, 45710209) at the highest chlorothalonil levels test ed (3000 mg a.i./kg-diet, approximately 230 to 250 mg/kg-bw). The most sensitive NOAEL = 1,200 mg a.i./kg-diet (LOAEL = 3,000 mg a.i./kg-diet, based on decreased body weight ga in in parents and offs pring) (MRID 45710209).

SDS-3701 (Degradate)

The degradate, SDS-3701, is more toxi c than chlorothalonil with an LD 50 

### of 242 mg/kg-bw, which classifies SDS-3701 as moderately t oxic to mammals (rat) (MRID 0001098). SDS-3701 was studied in a 1-generation and a 3-generation rat reproducti on toxicity studies (MRIDs 00127844 and 00127845, respectively). No reproductive impairment occurred in these studies up to the maximum dose tested of approximately 6 mg/kg-bw (120 – 125 mg a.i./kg-diet).

### 66 Terrestrial Invertebrates

A honey bee acute contact study (formulation wa s not identified) resulted in honey bee

LD 50 

### >181 μ g a.i./bee (MRID 00077759). There was no men tion of mortality or sublethal effects in the study. Chlorothalonil is, therefore, classifi ed as practically non-tox ic to bees. Additional data have also been submitted by the registrant regarding toxicity of a multi-a.i. formulation (chlorothalonil and penthiopyrad) to a variety of non-target terrestri al invertebrates. These will

be reviewed and evaluated to de termine potential use in the ec ological risk assessment.

Terrestrial Plants

Tier I seedling emergence and vegetative vigor st udies are available for chlorothalonil using 16 lb a.i./acre test concentrations (MRI Ds 42433808 and 42433809). These studies were not conducted with a typical end-use product (TEP), but were instead conducted using chlorothalonil mixed with a solvent (100% acetone ). In previous risk assessmen ts it was concluded that Tier II testing was not necessary because the highest regi stered application rate for chlorothalonil was

22.7 lb a.i./acre and th ere were no effects ≥ 25% at the 16 lbs a.i./acr e concentration. It was reported that the most sensitive species in the seedling emergence study (onions) showed an 11% reduction in wet weight and the most sensitiv e species in the vegeta tive vigor study (soybean) showed a 9% reduction in fresh weight. However, upon a re-evaluation of these studies as part of the Registration Review proce ss it was determined that these results were based on the pooled (solvent and negative) controls instead of the more appropriate negative control. When the results are compared to the negative (and not the pooled) control, onion shows an inhibition in growth of 26% in the seedling emergence study and cucumber shows a 26% inhibition in growth in the vegetative vigor study at the 16 lbs a.i./acre concentration.

Contaminant toxicity (dioxins and HCB)

Another possible source of toxicity from the use of chlorothalonil products is the presence of the known impurities that result from the manufacturing process. Hexachlorobenzene (HCB), dioxin/furan congeners and other possible organochlorine contaminants have been found in the chlorothalonil products. The term “dioxins” is used to repres ent polychlorinated dibenzo-pdioxins (PCDDs) and polychlorinated dibenzofur ans (PCDFs). There are 210 different congeners of dioxins (75 PCDDs and 135 PCDFs); however, only 17 congeners are considered to be of toxicological concern (listed in Table 14 ). For these 17 congeners, evidence is sufficient to conclude that a common mechanism of action, in volving binding of the ch emicals to the aryl hydrocarbon receptor (AHR) as the initial ste p, underlies 2,3,7,8-TCDD-like toxicity elicited by these PCDDs, PCDFs, and Polychlorinated biph enyls (PCBs) (Van den Berg et al., 1998, 2006; Hahn, 2002).

Table 14. Dioxin Congeners of Toxicological Concern; Toxicity equivalency factors for mammals, birds and fish a ssociated with each isomer are from U.S. EPA 2008b

Congener* Mammal TEF Bird TEF Fish TEF

2378-TCDF 0.1 1 0.05

### 67 Congener* Mammal TEF Bird TEF Fish TEF

12378-PeCDF 0.03 0.1 0.05

23478-PeCDF 0.3 1 0.5

123478-HxCDF 0.1 0.1 0.1

123678-HxCDF 0.1 0.1 0.1

234678-HxCDF 0.1 0.1 0.1

123789-HxCDF 0.1 0.1 0.1
1234678-HpCDF 0.01 0.01 0.01
1234789-HpCDF 0.01 0.01 0.01

OCDF 0.0003 0.0001 <0.0001

2378-TCDD 1 1 1

12378-PeCDD 1 1 1

123478-HxCDD 0.1 0.05 0.5

123678-HxCDD 0.1 0.01 0.01

123789-HxCDD 0.1 0.1 0.01
1234678-HpCDD 0.01 <0.001 0.001

OCDD 0.0003 0.001 <0.001 *Abbreviations are as follows: TCDD = tetrachlorodibenzodioxin; PeCDD = pentachlorodibenzodioxin; HxCDD = hexachlorodibenzodioxin; HpCDD = Heptachlorodibenzodioxin; OCDD = Octachlorodibenzodioxin; TCDF = Tetrachlorodibenzofuran; PeCDF = Pentachlorodibenzofuran; HxCDF = Hexachlorodibenzofuran; HpCDF = Heptachlorodibenzofuran; OCDF = octachlorodibenzofuran



### Research has been conducted to characterize th e toxicities of PCDDs and PCDFs especially relative to each other, since these compounds are often pres ent together in the environment. Demonstrated toxic effects of 2,3,7,8-TCDD and other similar-acting PCDD, PCDF and PCB congeners in fish, birds, a nd mammals include adverse eff ects on reproduction, development, and endocrine functions; wasting syndrome; i mmunotoxicity; and mortality in both laboratory and field settings (U.S. EPA 2008b). The EP A (U.S. EPA 2008b) and the World Health Organization (Van Den Berg et al. 1998 and 2006) have established toxicity equivalency factors (TEFs) for dioxins as they relate to mammals, to birds and to fish ( Table 14 ). In the TEF approach, the toxicities of i ndividual congeners are related to 2,3,7,8-TCDD, which is the most toxic congener of dioxins to animals (U.S. EPA 2008b; Table 14 ). For each PCDD and PCDF, the concentration (or mass) of the chemical is multiplied by its TEF. The sum of the product for each PCDD and PCDF represents the toxicity eq uivalent (TEQ) concentration relative to 2,3,7,8- TCDD (Equation 1; U.S. EPA 2008b).

Equation 1

. 

# ∑

=

n n n 

### TEF ion Concentrat TEQ *



### Dioxins, and HCB are both listed under the St ockholm Convention as Persistent Organic Pollutants (POPs). These chemicals are persiste nt, bioaccumulative and subject to long range transport. In general, chronic toxicity endpoints for mammals and birds exposed to pesticides are expressed in terms of mg pestic ide/kg-bw. The toxicity of 2,3,7,8-TCDD is expressed in units of ng/kg-bw, which indicates that this chemical is or ders of magnitude more toxic than pesticides which are typically assessed by OPP. To characteri ze the risk associated with HCB, the toxicity of HCB will be summarized from the scientific literature. The Agency for Toxic Substances and Disease Registry (ATSDR), associated with the Center for Disease Control (CDC),

### 68 Toxicological Profile for HCB (ATSDR, 2002) will be used as one source of information in the

characterization of th e toxicity of HCB.

When using the TEQ approach, the exposure concen tration of each dioxin congener is adjusted

relative to the toxic ity of 2,3,7,8-TCDD.

In 1993, EPA developed a report (interim) on the available data and methods for assessing ecological risks associated w ith 2,3,7,8-TCDD (USEPA 1993). Th is section summarizes the ecological effects data that are described in that report. Because of the low solubility and high Koc and Kow values of dioxins, a method for char acterizing toxicity base d on the concentration of dioxin in the organism (tissu e-based residues), rather than freely dissolve d concentrations in the water is used. Therefore, this section will report toxicity data in terms of organism

concentrations.

Currently, the toxicity and risk associated with the presence of the contaminant HCB has not been fully characterized. However, information fr om available scientific literature, including the Toxicological Profile for HCB (ATSDR, 2002) will be used to characte rize the toxicity and estimate the risk associated with the presence of HCB as a contaminant of chlorothalonil.

Fish

Toxicity data are available for several species of freshwater and saltwater fish exposed to 2,3,7,8-TCDD. A review of the data indicates that the most sensitive life stage is fish fry. According to the 1993 EPA report, “[T]here is no de finitive evidence of adve rse effects in any of the fish species tested if accumulation in e ggs is less than 34 pg TCDD/g [ng TCDD/kg], the highest no observed effect level for trout fry. This likely corresponds to an accumulation in parent fish, with lipid content similar to the eggs, of less than 50 pg TCDD/g.” Based on this information, the NOAEC for effects of 2,3,7,8-TC DD on fish fry is 34 ng/kg, which corresponds to an accumulation in parent fish (who transfer dioxins to eggs) of <50 ng/kg. Effects to fish fry survival are expected when concentrations of 2,3,7,8-TCDD in eggs are 50-500 ng/kg, which corresponds to concentrati ons of 75-705 ng/kg in parent fish. Mo rtality in adult fish is expected with body concentrations of 2,3,7,8-TCDD are 1000-15000 ng/kg (USEPA 1993).

Aquatic Invertebrates

Data are available from toxicity studies wh ere a species of freshwater invertebrates, i.e ., the

cladoceran Daphnia magna , and a snail ( Physa sp. ) were exposed to 2,3,7,8-TCDD. After 33-d exposures, no adverse effects were observed in either species. Con centrations of 2,3,7,8-TCDD in the cladoceran and snail were 1,570,000 and 502,000 ng/kg, respectively (Inensee and Jones 1975; Inensee 1978). These concen trations are based on measur ed levels of 2,3,7,8-TCDD in

tissues.

Aquatic Plants

Data are available from toxicity studies wher e non-vascular, i.e., al gae (Oedogonium cardiacum) and vascular, i.e., duckweed (Lemna minor), aquatic plants were exposed to 2,3,7,8-TCDD. After 33-d exposures, no toxic effects were obser ved in either species. Concentrations of 2,3,7,8-

### 69 TCDD in duckweed and algae were 3 0,700 and 2,295,000 ng/kg, respec tively, without any apparent adverse effects on the aquatic plants (Inensee and Jones 1975; Inensee 1978). These

concentrations are based on measured le vels of 2,3,7,8-TCDD in aquatic plants.

Birds

In 2003, EPA finalized a document summarizing avai lable laboratory and fi eld studies involving reproductive toxicity in birds that are exposed to dioxins. A review of avai lable studies indicates that exposures of birds to dioxins lead to mo rtality, deformity and inhibited development in offspring (USEPA 2003b).

In the Great Lakes Water Quality Initiative Cr iteria for the Protection of Wildlife for 2,3,7,8- TCDD, USEPA Office of Water (USE PA OW) also identified severa l studies reporting toxicity data involving chronic exposures of birds to 2,3,7,8-TCDD. From these studies, OW selected a reproduction study with the ring-necked pheasant ( Phasianus colchicus ) exposed to 2,3,7,8- TCDD (Nosek et al. 1992a, 1992b, 1993) to derive the avia n wildlife value used for the 2,3,7,8- TCDD criteria. In this study, female birds we re dosed intraperitonieally with 2,3,7,8-TCDD for 10 weeks at 1.4, 14 and 140 ng/kg-day. As the birds were injected with the chemical which does not represent a relevant route of exposure, this study is not appr opriate for use in an EFED and

AD risk assessment.

Mammals

Chronic toxicity endpoints for mammals expos ed to 2,3,7,8-TCDD have been identified by the USEPA OW for the Great Lakes Water Quality Initiative Criteria for the Protection of Wildlife (USEPA 1995). USEPA OW defined a no observe d adverse effect level (NOAEL) of 1 ng/kgbw/day (i.e., 0.001 μg/kg-bw/day or 1x10 -6 

### mg/kg-bw/day) for reproductive effects to mammals exposed to 2,3,7,8-TCDD in food. This NOAEL was based on reduced fertility in first (f1) and second generation (f2) rats at the lowest obs erved adverse effect le vel (LOAEL) of 10 ng/kgbw/day (Murray et al. 1979). Ecological Incidents

Reviews of the Ecological Incident Informati on System (EIIS, version 2.1) and the Avian Incident Monitoring System (AIMS) 28 

### were conducted on Nov. 28, 2011. There are 33 chlorothalonil incidents reported in the EIIS (see Table 15 ). The reported incidents occurred between 1976 and 2003. In one of the incidents, chlorothalonil was unlik ely the cause of the

incident. Six of the incidents involved misuses or spills. In the remaining 26 incidents, the legality of use was either a registered use (5) or undetermined (21) and the certainty index was possible (24) or highly probabl e (2). Of these 26 incidents, 7 involved aquatic animals, 4 involved terrestrial animals, a nd 15 involved plant damage. Ther e were no additional incidents

identified in the AIMS database for chlorothalonil.

In the risk assessment, the incidents will be fu rther evaluated to determine if the reported incidents represent current patt erns of use for chlorothaloni l. Examples of additional

28 http://www.abcbirds.org/abcprograms/ policy/pesticides/aims/aims/index.cfm

### 70 considerations are mitigation ( e.g ., reduced application rates), product cancellations, and changes in use patterns that have occurred sin ce the date of the reported incident(s).

In addition to the incidents r ecorded in EIIS and AIMS, addi tional pesticide incidents are reported to the Agency in aggregated incident repor ts. Ecological incident s reported in aggregate reports include those categorized as ‘minor fish and wildlife’ (W-B), ‘min or plant’ (P-B), and ‘other non-target’ (ONT) incidents. ‘Other non-target’ incidents include reports of adverse

effects to insects and other te rrestrial invertebrates. As of Nov. 28, 2011, there have been 409 aggregate incidents reported to the Agency from 1995 to 2011 (404 involving plants and 5 involving animals). These incidents will be assume d to be the result of registered uses unless

additional information on the a ggregate incidents is provide d for the risk assessment.

Table 15. Summary of Incidents Reported in EIIS

Type Incident ID Year Legality Certainty AQUATIC B000637-001 1976 Undetermined Highly Probable AQUATIC I000636-014 1984 Undetermined Possible AQUATIC B0000-500-15 1989 Registered use Possible

TERRESTRIAL I000103-008 1990 Undetermined Unlikely

PLANTS I003377-013 1993 Misuse (accidental) Highly Probable AQUATIC I002200-001 1994 Registered use Possible AQUATIC I003596-001 1994 Undetermined Possible

PLANTS I014406-002 1996 Misuse Possible AQUATIC I012265-006 1996 Undetermined Possible AQUATIC I007372-007 1997 Misuse (accidental) Probable PLANTS I014597-011 1998 Registered use Possible

PLANTS I007340-625 1998 Undetermined Possible

PLANTS I007340-629 1998 Undetermined Possible

PLANTS I007340-631 1998 Undetermined Possible

PLANTS I007340-628 1998 Undetermined Possible

PLANTS I007340-630 1998 Undetermined Possible

PLANTS I007340-632 1998 Undetermined Possible PLANTS I014597-010 1998 Registered use Possible

PLANTS I007340-638 1998 Undetermined Possible

PLANTS I007340-686 1998 Undetermined Possible

PLANTS I007340-693 1998 Misuse (intentional) Possible

PLANTS I007340-712 1998 Undetermined Possible TERRESTRIAL I013884-010 1998 Undetermined Highly Probable

TERRESTRIAL I014341-034 1999 Undetermined Possible

TERRESTRIAL I014341-033 1999 Undetermined Possible

TERRESTRIAL I013587-012 1999 Undetermined Possible

PLANTS I009262-115 1999 Undetermined Possible AQUATIC I017028-001 2000 Undetermined Possible

PLANTS I011838-111 2001 Undetermined Possible

PLANTS I011942-002 2001 Undetermined Possible PLANTS I013550-002 2001 Registered use Possible TERRESTRIAL/AQUATIC I011988-008 2001 Misuse (accidental) Possible AQUATIC I014538-013 2003 Spill Possible

The shaded incidents will not be consid ered in the risk assessment because they involve misuses or incidents unlikely caused by chlorothalonil.



### Characteristics of Ecosystems Potentially at Risk

### 71 The ecosystems potentially at risk are often extensive in scope; therefore, it may not be possible to identify specific ecosystems during the deve lopment of a nation-wide ecological risk assessment. However, in general terms, te rrestrial ecosystems potentially at risk from conventional pesticide uses coul d include the treated field and immediately adjacent areas that may receive drift or runoff. Areas adjacent to th e treated field could include cultivated fields, fencerows and hedgerows, meadows, fallow fields or grasslands, woodlands , riparian habitats,

and other uncultivated areas.

Aquatic ecosystems potentially at risk from conve ntional uses include water bodies adjacent to, or downstream from, the treated site and might include impounded bodies such as ponds, lakes and reservoirs, or flowing waterways such as stre ams or rivers including all adjacent off-channel habitats that are permanently or intermittently co nnected to flowing waters. For uses in coastal areas, aquatic habitat also incl udes marine ecosystems, includi ng estuaries, embayments, and

near shore environments.

Aquatic ecosystems potentially at risk from indus trial pressure treated wood use and industrial discharge from film preservati ve manufacturing include those water bodies to which a WWTP directly discharges effluent or downstream of the effluent discha rge and could include impounded bodies such as lakes and reservoirs or flowing waterways such as streams and rivers or if the WWTP discharges to the ocean or an estuary, ecosystems affected may include marine coastal ecosystems, bays and estuaries. Simila rly, aquatic ecosystems pot entially at risk from wood preservative uses include water bodies adjacen t to or nearby the application or use site. Such water bodies might include impounded waters such as ponds, lakes and reservoirs, or flowing waterways such as streams or rivers in cluding all adjacent off-channel habitats that are permanently or intermittently connected to flowing waters. For uses in coastal areas, aquatic habitat also includes marine ecosystems, incl uding estuaries, embayments, and near shore

environments.

Assessment Endpoints

Assessment endpoints are defined as “explicit expressions of the actual envir onmental value that is to be protected.” Defining an assessment e ndpoint involves two steps: 1) identifying the

valued attributes of th e environment that are considered to be at risk; and 2) operationally defining the assessment endpoint in terms of an ecological entity ( i.e ., a community of fish and aquatic invertebrates) and its attributes ( i.e ., survival and reproduction). Therefore, selection of the assessment endpoints is ba sed on valued entities ( i.e ., ecological receptors), the ecosystems potentially at risk, the migration pathways of pesticides, and the routes by which ecological receptors are exposed to pesticide-related c ontamination. The selection of clearly defined assessment endpoints is important because they provide direction and bou ndaries in the risk assessment for addressing risk management issu es of concern. Changes to assessment endpoints are typically estimated from the available toxici ty studies, which are used as the measures of effects to characterize potential ec ological risks associated with e xposure to a pesticide, such as chlorothalonil. For a summary of the aquatic and terrestrial toxicological endpoints for

chlorothalonil see Tables 10 and 11 in the Ecological Effect s section, respectively.

### 72 Conceptual Model

The conceptual model is a graphic representation of the structure of the risk assessment. It specifies the chlorothalonil release mechanisms, biological receptor types, and effects endpoints of potential concern. The con ceptual models for aquatic a nd terrestrial ex posures from conventional use pesticides Figures 5 and 6 , respectively. Dashed lin es denote exposure routes

not assessed due to the like lihood of low potential exposure.

Chlorothalonil, when used as a material pr eservative surface protecta nt in joint and dry compound for use on wallboard, in accordance with current labels, is not expected to result in exposure of non-target organisms. This use is ex pected to result in no transport of chlorothalonil or its major degradates to outdoor environments eith er at the industrial faci lities where it is added to the joint or dry compound or during its stor age and in-service use. Wallboard is used primarily to form the interior of houses or commercial buildings ( e.g ., drywall, particle board, plasterboard, gypsum board). No effect to non-target organisms in cluding Federally-listed threatened and endangered species (listed) as well as non-listed species is expected because exposure is not expected.

Potential emission sources of wood pr eservative treatment facilities are described in detail in the OECD (2000) Emission Scenario Document (ESD ) for Wood Preservatives Part 1. Of these potential sources, the major emission sources iden tified as likely and complete, given the fate and transport properties of chlorothalonil was co llection of wastes from various process points with subsequent discharge to on-site or off-site waste water treatment plants (WWTPs), leaching Figure 7 along with the receptors of concern and the potential attribute changes in the receptors due to exposure to chlorothal onil and its major transformati on product (SDS-3701). Emissions to air during the application process is likely but low as the vapor pressure of chlorothalonil is considered negligible (~ 10 -7 

### mm Hg) while volat ilization from treated wood would be even

lower as more chlorothalonil will absorb into the interior of the wood structure and less would

be at the surface. Bioaccumulation or food chai n transfer is considered a potential exposure pathway contributing to risk to aquatic and terre strial biota that ingest aquatic biota because

chlorothalonil has a fish BCFs greater than 3000 for whole fish (greater than 5500 for ‘nonedible’ portion [while this porti on is usually not eaten by humans, it includes soft internal body organs such as the liver, guts, etc . and skin that would be ingested by wildlife]) (MRID 45710224) and the BCF for total chlorothalonil residues is 2660 in mollusk (MRID 43070601).

Chlorothalonil, added to exterior wood preservati ve paints, stains, and coatings, when used in accordance with current labels, is expected to result in exposur e of non-target organisms as chlorothalonil and its major tran sformation products in these cons umer products can leach from exterior treated surfaces ( e.g ., wood, concrete, brick) to soil, and treated surfaces can result in transport to surface water, and can leach from contaminated so il to groundwater. Potential sources and transport mechanisms are depicted in Figure 8 along with the receptors of concern and the potential attribute changes in the recepto rs due to exposure to chlorothalonil and its major transformation products of toxic concer n. Exposure of nontarget organisms from overspray drift is considered a negligible e xposure pathway as discu ssed previously in the

environmental fate assessment section. Emission s to air during the applic ation process is likely low as the vapor pressure of chloroth alonil is considered negligible (~ 10 -7 

### mm Hg) while

### 73 volatilization from treated wood and other surfaces would be even lower as more chlorothalonil

will be absorbed into the structure and less woul d be at the surface. Bioaccumulation or food chain transfer in the aquatic environment is c onsidered a potential expos ure pathway contributing to risk to aquatic and terrestrial biota that ingest aquatic biota.

Figure 5. Conceptual Model for Conventional Pesticide Use Effects on Aquatic Systems Stressor

Source

Receptors

Attribute Change DCPA applied to use site and associated degradate and impurities

Spray drift

Fish/aquaticphase amphibians

**Piscivorous

mammals and

birds

Individual organisms

Reduced survival Reduced growth Reduced reproduction Food chain Reduction in algae Reduction in prey

Modification of

PCEs related to prey

availability Habitat integrity Reduction in primary productivity

Reduced cover Community change

Modification of PCEs related to

habitat Surface water/

Sediment Runoff

Aquatic Animals

Invertebrates

Vertebrates 

### Exposure

Media

Uptake/gills or integument

Ingestion Ingestion Long range atmospheric

transport

Wet/dry deposition Soil Groundwater

Uptake/gills or integument

Aquatic Plants

Non-vascular

Vascular Uptake/cell, roots, leaves Riparian plant

terrestrial

exposure pathways Chlorothalonil applied to use site and associated degradate and impurities

### 74 Figure 6. Conceptual Model for Conventional Pesticide Use Effects on Terrestrial Systems Stresso r

Source

Receptors

Attribute Change Chlorothalonil applied to use site and associated degradate and impurities

Direct application Spray drift

Birds/terrestrial phase amphibians/ reptiles/mammals

Terrestrial

insects

Individual organisms

Reduced survival Reduced growth Reduced reproduction Food chain Reduction in prey

Modification o f

PCEs related to prey availability Habitat integrity Reduction in primary productivit y Reduced cove r Community change

Modification o f PCEs related to

habitat Terrestrial/riparian plants grasses/forbs,

fruit, seeds (trees, shrubs) Runof f

Mammals/

birds Exposure

Media Soil

Ingestion/

inhalation Ingestion/

inhalation

Ingestion/

inhalation Ingestion Dermal uptake/Ingestion/

inhalation Long range atmospheric

transport

Root uptake
Wet/dry deposition

Terrestrial phase amphibians - Ingestion/

inhalation

### 75 Figure 7. Conceptual Model of the Transp ort, Exposure and Effects to Aquatic and Terrestrial Organisms from I ndustrial Treated Wood Product Uses of Chlorothalonil

Stressor

Source

Receptors

and Exposure

Routes

Attribute Change(s) Dip, Pad or Pressure

Treated Wood Process

Facility Drain

Individual organisms

Reduced survival Reduced growth Reduced reproduction Food chain Reduction in aquatic plants Reduction in prey
Modification of PCEs related to prey availability Habitat integrity Reduction in primary productivity

Reduced cover Community change

Modification of PCEs related to

habitat Surface Water

Aquatic Animals

Invertebrates

Vertebrates 

### Exposure

Media

Ingestion Ingestion Uptake across gills or integument and/or sediment ingestion

Aquatic Plants

Non-vascular

Vascular Uptake or sorption by cells, roots, leaves,

Piscivorous*

Invertebrates

Vertebrates Phytoplanktivore

/ Herbivore

Invertebrates

Vertebrates

*As used here this term refers to animals (terrestrial or aquatic) that eat not just fish but any aquatic animal ( e.g .,amphibians, mollusks, crustaceans,, etc.) Ingestion STP/WWTP

Key Most likely exposure pathway contributing to risk

Low likelihood of contributing to risk Post-Treated Wood Product Storage

Leaching and Run-off In-Use Service of Wood

Treated Wood Products

Leaching and Run-off

Sediment

### 76 Figure 8. Conceptual Model of the Transport, Exposure and Effects to (A) Aquatic and (B) Terrestrial Organisms from Us e of Chlorothalonil in Consumer Products used Outdoors

Stressor

Source

Receptors

and Exposure

Routes

Attribute Change(s) Exterior application to wood and wood products or use of antimildew/antimold products on exterior surfaces (e.g., paints and coatings for concrete, etc.)

Leaching/Run-off

Individual organisms

Reduced survival Reduced growth Reduced reproduction Food chain Reduction in algae Reduction in prey
Modification of PCEs related to prey availability Habitat integrity Reduction in primary productivity

Reduced cover Community change

Modification of PCEs related to

habitat Surface water/

Sediment Overspray

Aquatic Animals

Invertebrates

Vertebrates 

### Exposure

Media

Ingestion Ingestion Long range atmospheric

transport

Wet/dry deposition

Uptake across gills or integument and/or sediment ingestion

Aquatic Plants

Non-vascular

Vascular Uptake or sorption by cell, roots, or leaves, Riparian plant

terrestrial

exposure pathways see

Figure 8(B)

Piscivorous*

Invertebrates

Vertebrates Phytoplanktivore/

Herbivore

Invertebrates

Vertebrates

*As used here this term refers to animals (terrestrial or aquatic) that eat not just fish but any aquatic animal ( e.g .,amphibians, mollusks, crustaceans,, etc.) Ingestion Key Most likely

exposure pathway contributing to risk

Low likelihood of contributing to risk 

### (A)

Stressor

Source/ Exposure

Media

Receptors

and Exposure

Routes

Attribute Change(s) Exterior application to wood and wood products or use of antimildew/antimold products on exterior surfaces (e.g., paints and coatings for concrete, etc.)

Over Spray

Terrestrial insects

Individual organisms

Reduced survival (emergence*) Reduced growth Reduced reproduction** Food chain Reduction in plant biomass Reduction in prey
Modification of PCEs related to prey availability Habitat integrity Reduction in primary productivity

Reduced cover Community change
Modification of PCEs

related to habitat Terrestrial plants Grasses/forbs, fruit, seeds, trees, shrubs Leaching

Terrestrial Animals Birds (Reptiles, Amphibians)

Mammals Soil

Ingestion Ingestion Dermal uptake/ Ingestion Long range atmospheric transport

Root uptake Wet/dry deposition

Dermal contact Contact/Uptake leaves, stems

Beneficial

Insects

Reduced

survival

*Refers to seedling emergence **Vegetative vigor and seedling emergence endpoints are assumed to be as sensitive or more sensitive than reproduction endpoint and plant reproduction s not explicitely evaluated. (B)

Key Most likely

exposure pathway contributing to risk

Low likelihood of contributing to risk

### 77 Risk Hypothesis A risk hypothesis describes the predicted re lationship among the stre ssor, exposure, and assessment endpoint response along with the rationale for their selection. For chlorothalonil, the following ecological risk hypothesi s is being employed for this national-level ecological risk

assessment:

Conventional Pesticide Uses: Chlorothalonil, when used in accordance with current labels, can result in off-site movement of the compound via runoff, le aching to groundwater, spray drift and atmospheric transport leading to exposur e of non-target plants and animals. Direct applications to and atmospheric depos ition to foliar surfaces may serve as a major source of chlorothalonil expos ure to wildlife. Exposure in these environmental compartments will result in adverse effects upon the survival, growth, and reproduction of non-target te rrestrial and aquatic organisms. These non-target organisms include federally-lis ted threatened and endangered species.

Industrial Wood Preservative Uses: Chlorothalonil, when used as an industri al wood preservative, in accordance with current labels, can result in transport of it and its major transformation products via down-the-drain disposal from a wood preserva tive facility to surface water. Leaching and run-off to soil and surface water may occu r during storage and/or in-service use of treated wood. Exposure in these environmenta l compartments has the potential to reduce survival, growth, and/or reproduction in non- target aquatic organisms, terrestrial nontarget plants, and non-target terrestrial organisms that ingest aquatic animals and plants

— when used in accordance with the curre nt labels. These non-target organisms include Federally-listed threatened and endange red species (listed) as well as non-listed species.

Consumer Product Wood Preservative, and Exterior Building/Construction Material Preservative/Surface Protectant Uses: Chlorothalonil, when used as a consumer product wood preservative or as a surface protectant, in accordance with curr ent labels, can result in transport of it and its major transformation products off the in-service use site from leaching and run-off to soil and surface wate r. Exposure in these environmental compartments has the potential to re duce survival, growth, and/or reproduction in non-target aquatic organisms, terrestrial non-target organisms

— when used in

accordance with the current labels. These non-target organisms include Federally-listed threatened and endangered sp ecies (listed) as well as non-listed species.

Joint and Dry Compound for Use on Wallboard: Chlorothalonil, when used as a materi al preservative in joint and dry compound for use on wallboard, in accordance with current labels, will not result in exposure of non-target organisms. Th is use has no exposure and therefore no effect to non-target or ganisms including Federa lly-listed threatened and endangered species (listed) as well as non-listed species.

### 78 F. A NALYSIS 

### P LAN



### In order to address the risk hypot hesis, the potential for adverse effects on the environment is estimated. The use, environmental fate, and ecologi cal effects of chloroth alonil are characterized and integrated to assess the risks. This is a ccomplished using a risk quo tient (ratio of exposure

concentration to effects concentr ation) approach. Although risk is often defined as the likelihood and magnitude of adverse ecological effects, the risk quotient-based approach does not provide a quantitative estimate of likelihood and/or magnitude of an adverse effect. However, as outlined in the Overview Document (USEPA 2004), the likelihood of effects to individual organisms from particular uses of chlorothalonil is estimat ed using the probit dose-response slope and either the level of concern (discussed below) or actual calculated risk quotient value. For down-thedrain risk estimates, an approach that estimates the number of days a concentration-of-concern (COC) is exceeded, also referred to as a probabi listic dilution model (PDM) approach may be used to assess risk to aquatic organisms.

This analysis plan will be revisited and may be revise d depending upon the information submitted by the public in response to the openi ng of the Registration Review docket for

chlorothalonil.

Measures of Exposure

Aquatic Exposure

Drinking Water

Conventional Pesticide Uses

A drinking water assessment will be conducted to support future human health dietary risk assessments of chlorothalonil. The drinking water assessment will incorporate model estimates of chlorothalonil and any transformation products of toxicological concern in surface water and groundwater. The potential toxicity of chlorothalon il transformation products will be considered in the drinking water assessment conducted during the Registration Review process. The final

determination of the residues of concern will be made through consultation with the Health Effects Division (HED) and through any proceed ings of the ROCKS (Residues of Concern Knowledge Subcommittee). The drinking water assessment will include the modeling results discussed in the Drinking Water Exposure Asse ssment section above and will also include a summary of available surface water and groundwater monitoring data.

The potential toxicity of chlorothalonil transf ormation products in addition to SDS-3701 will be considered in the drinking water assessment c onducted during the Registra tion Review process. If degradates of similar toxici ty to chlorothalonil are identified as residues of toxicological concern a total toxic residue method will be empl oyed to derive EDWCs. To account for total toxic residues, each relevant environmental fa te study (hydrolysis, aqueous photolysis, aerobic soil metabolism, etc.) will be used to calculate th e amount of total toxic re sidues present in each study at each sampling interval. If a transforma tion product was not iden tified in one of the

studies it will be assumed to be a toxic resi due. The total concentra tions at each sampling

interval will be used to recalcu late the rate constant and th e corresponding half-life value for

### 79 each study. These data will then be used to calculate modeling i nput parameters according to the current (the time when the assessment is comple ted) input parameter guidance. When there are

no data available for the identified or unidentif ied transformation products, input values will be assumed to be equivalent to the parent value. If data are available for bo th chlorothalonil and the transformation products of toxicological concer n and the data cannot be combined, the most conservative plausible values will be used. This will be based on the assessor’s best judgment. Rationales for choosing each input parameter wi ll be discussed in the assessment. If a transformation product is identified that has a different mode of toxi city or is substantially more toxic than the parent it will be modeled separately if data are available.

The current models available for conducting drin king water assessment for surface water include PRZM (Pesticide Root Zone Model, vers ion 3.12.3, June 2006) and EXAMS (EXposure Analysis Modeling System, version 2.98.04.06, Apr il 2005) models. PRZM will be used to simulate pesticide transport as a result of r unoff and erosion from an agricultural field while

EXAMS will be used to estimate environmental fa te and transport of pe sticides in the index reservoir. Measures of exposure will be based maximum single and year labeled application rates, minimum retreatment intervals, and cons ervative methods of application. The location of the field is specific to the crop being simulate d using site-specific information on the soils, weather, cropping, and management factors asso ciated with the scenario. The crop/location scenario is intended to represent a high-end e xposure site on which the crop is normally grown. Based on historical rainfall patte rns, the receiving water body receives multiple runoff events during the years simulated. Weather and agricultural practices are simulated for 30 years so that the 10-year exceedances probability at the site can be estimated. The simulation is generated using 30 years of meteorological data, enco mpassing the years from 1961 to 1990. Several

standard PRZM scenarios are available which will be used to represent eac h chlorothalonil use. If multiple scenarios exist for the same crop the most conservative scenario will be used. If a PRZM scenario does not exist for a specific chlo rothalonil use and surrogate scenario will be used. Generally, the 1-in-10 year peak is used for estimating acute exposures, 1-in-10-year annual average is used for assessing chronic expo sure, and a 1-in-10 year average is used for cancer exposure; however, a distri bution of daily concentrations or some other averaging period not listed above could be used dependi ng on the exposure duration of concern.

Currently, groundwater modeling is completed using SCI-GROW (S creening C oncentration i n Gro undw ater, version 2.3, August 8, 2003); however, PRZM-groundwater [(GW); November 2, 2011 Prerelease version] is also available to refine groundwater expos ure estimates. SCI-GROW is an empirical model based on a linear be st fit through 13 single -application groundwater

studies. PRZM-GW can be used to simulate vert ical pesticide transpor t through the soil profile into an aquifer following application to an ag ricultural field. The PRZM scenarios used in groundwater simulations are repres entative of vulnerable sites— shallow unconfined aquifers under an agricultural field with leaching prone soil—and output values represent pesticide concentrations that may be observed in drinki ng water resulting from the use of groundwater vulnerable to pesticide contamination as source wa ter. The results are expected to represent the upper bound values on the concentrat ions of toxic residues that mi ght be found in drinking water supplied by groundwater.

### 80 The drinking water assessment will also include available surface and ground water monitoring data with consideration of change s in use patterns that may have occurred. States are encouraged to submit monitoring data for review.

Antimicrobial Pesticide Uses

A drinking water assessment will be conducted to support human health dietary risk assessments of chlorothalonil. The drinking water assessment will incorporate model estimates of chlorothalonil in surface water from the industrial wood preservative use.

The General Population and Ecological Exposure from Industrial Releases module of E-FAST2 (version 2, August 31, 2009) and the Industrial Re leases module will be used to develop screening estimates of total t oxic residues of chlorothalonil co ncentrations in drinking water

sources that are derived from st reams and rivers that receive wastewater discharges from a facility engaged in industrial us es of wood preservatives. In the absence of appropriate data on the percent removal of chloroth alonil and its major toxic transf ormation products during drinking water treatment the Agency will assume there is no removal.

Spray Drift

AgDrift will be used to assess the potential spray drift of chloro thalonil to adjacent terrestrial habitats or aquatic environments that serve as habitat and source water for drinking water. These data will be compared to the Levels of Concer n (LOCs) for humans and non-target organisms. In addition to the use of spray drift models, as part of the registration review assessment, available monitoring data from the open literature and any submitted data will be evaluated to assess the potential impacts of spray drif t on human health and non-target organisms. Other methods of atmospheric transport are possible other than sp ray drift including volatil ization or particulate phase transport.

Volatilization

While the Agency does not yet have a method fo r quantitatively assessing long range transport, PERFUM can be used to look at vapor phase concentrations of chlo rothalonil adjacent to application sites. If a long ra nge transport model is available at the time the assessment is completed, long range transport of chloro thalonil will be quan titatively assessed.

Ecological Exposure for Conve ntional Use Pesticides

Estimated environmental concentrations of ch lorothalonil and other residues of potential toxicological concern in surface water will al so be calculated using PRZM-EXAMs; however, the standard scenarios used for ecological pest icide assessments assume application to a 10- hectare agricultural field that drains into an ad jacent 1-hectare water body that is 2 meters deep (20,000 m 3 

### volume) with no outlet. PRZM/EXAMS is used to estimate screening-level exposure of aquatic organisms to chlorothalonil. The meas ure of exposure for aquati c species is the 1-in10 year return peak or rolling mean concentratio n. The 1-in-10 year peak is used for estimating acute exposures of direct effects to aquatic organisms. The 1-in-10-year 60-day mean is used for

### 81 assessing chronic exposure to fish and aquatic-ph ase amphibians. The 1-in-10-year 21-day mean is used for assessing chronic exposure to aquatic i nvertebrates. As stated in the drinking water portion above, the potential toxi city of chlorothalonil transfor mation products in addition to SDS-3701 will be considered as part of the risk assessment process. If degradates of similar toxicity to chlorothalonil are identified as residu es of toxicological conc ern a total toxic residue method will be employed to derive estimated environmental concentrations (EECs).

Exposure estimates for terrestrial an imals assumed to be in the target area or in an area exposed to spray drift are derived using the T-REX model (version 1.4.1, 10/09/2008). This model incorporates the Kenega nomogr aph, as modified by Fletcher et al. (1994), which is based on a large set of field residue data . The upper limit values from the nomograph represent the upper

bound of residue values from actual field meas urements (Hoerger and Kenega 1972). The

Fletcher et al. (1994) modifications to the Kenega nomograph are based on measured field residues from 249 published research papers, incl uding information on 118 species of plants, 121 pesticides, and 17 chemical classes.

Terrestrial exposure to the degr adate SDS-3701, which is more toxic to birds and mammals than the parent, will be estimated using TREX. The a pplication rate input valu e will be the maximum registered application rate times the maximum percent that the degradate was formed in the fate studies ( i.e., 34.1%, aerobic soil metabolism studies, MRIDs 00040547 and 00087351). The potential toxicity of chloro thalonil transformation products in addition to SDS-3701 will be considered as part of the risk assessment proc ess. If degradates of similar toxicity to

chlorothalonil are identified as residues of toxico logical concern for terres trial organisms then it is assumed that these degradates would be acco unted for when the EECs are derived by using the default 35-day foliar half-life in T-REX ( i.e ., this is similar to the TTR approach described above for the aquatic assessment).

EECs for terrestrial plants inha biting dry and wetland areas are derived using TerrPlant (version 1.2.2, 12/26/2006). This model uses estimates of pe sticides in runoff and in spray drift to calculate EECs. EECs are based upon solubilit y, application rate and minimum incorporation depth.

In general, deposition of drifting or volatilized pe sticides is expected to be greatest close to the site of application. The AgDRIFT spray dr ift model (v2.01; May 2001) is used to assess exposures of organisms to chlorothalonil depos ited on terrestrial habi tats by spray drift.

Aquatic exposure to the impurities, HCB and dioxins, will be characterized. PRZM/EXAMS will be used to estimate screening-level expos ure of aquatic organisms to these compounds. Terrestrial exposure to HCB and 2,3,7,8-tetrachlorodebenzo- p -dioxin (TCDD) will be estimated using TREX, and KABAM, as bioaccumulation is a major transport pathway for these chemicals. The application rate input value wi ll be either the maximum allowed amount of the impurity in the final formulation or an upper es timate of the amount in the final formulation, respectively.

The S creening I mbibition P rogram (SIP v.1.0, Released June 15, 2010) was used to calculate an upper bound estimate of exposure to wildlife via drinking water us ing chlorothalonil’s aquatic

### 82 solubility limit (0.8 mg/L), the most sensitive acu te and chronic avian toxi city endpoints (mallard

duck with LD 50 

### >4,640 mg/kg-bw and bobwhite quail NOAEC = 153 mg a.i./kg-diet, respectively), and the most sensitive acute a nd chronic mammalian toxicity endpoints (rat LD 50 

### >10,000 mg/kg-bw, and NOAEL = 92.5 mg a.i./kg-bw , respectively). Drinking water exposure alone was determined not to be a potential pathwa y of concern for parent chlorothalonil for avian or mammalian species on an acute basis or chroni c basis. For a sample of the output generated by SIP v.1.0, please see APPENDIX D . Detailed information about the SIP v.1.0, as well as the tool, can be found on the EPA’s website at http://www.epa.gov/pesticides/science/models_pg.htm#terrestrial

SIP was also used to calculate an upper bound estimate of exposure to wildlife via drinking water using the estimated aquatic solubility limit for the degradate SDS-3701 (115.7 mg/L), the most

sensitive acute and chronic avian toxi city endpoints (ma llard duck with LD 50 

### = 158 mg/kg-bw and NOAEC = 50 mg a.i./kg-diet, respectively), and the most sensitive acute and chronic mammalian toxicity endpoints (rat LD 50 

### = 242 mg/kg-bw, and NOAEL = 6 mg a.i./kg-bw, respectively). Drinking water exposure alone was determined to be a potential pathway of concern for avian and mammalian species on an acute basis and chronic basis. This pathway for the degradate will be explored fu rther with the development of SIP v.2.0 in the Ecological Risk Assessment for chlorothalonil. Again, for a samp le of the output generated by SIP v.1.0, please

see APPENDIX D

.

The S creening T ool for I nhalation R isk (STIR v.1.0, November 19, 2010) was used to calculate an upper bound estimate of exposure using ch lorothalonil’s vapor pressure (5.7 x 10 -7 

### torr) and molecular weight (265.91 amu) for vapor phase exposure as well as the maximum application rate (13 lb a.i./acre) and method of application for spray drift. STIR incorporates results from several toxicity studies including acute oral and inhalation rat t oxicity endpoints obtained from the “six-pack” of core studies, which are a series of six guideline studies th at are submitted to the Registration Division of the Office of Pesticide Programs for technical and formulated products of a pesticide [rat acute oral LD 50 

### >10,000 mg a.i./kg-bw and acute inhalation LC 50 

### = 0.012 mg/L (MRID 43678403), respectively] as well as the most sensitive acute oral avian toxicity endpoint (enter avian species with LD 50 

### > 4,640 mg a.i./kg-bw). Based on the results of the STIR model, inhalation exposure alone was determin ed to be a potential pathway of concern for avian and mammalian species on an acute basis.

The inhalation pathway via spray drift of the pestic ide is of potential significance. This pathway will be explored further by requesting additional toxicity or exposure da ta (non-guideline acute avian inhalation toxicity) that may reduce uncertainty and the incorporation of this data into the

inhalation risk assessment for birds and mammals . Potential risks from inhalation of the chlorothalonil degradate SDS-3701 will be consider ed in the assessment, but EFED does not recommend requesting an avian inhalation study for SDS-3701 at this time. For a sample of the output generated by STIR v.1.0, please see APPENDIX E . Detailed information about the STIR

v.1.0 tool can be found on the EPA’s website at: http://www.epa.gov/pesticides/science/models_pg.htm#terrestrial

.

### 83 Ecological Exposure for Antim icrobial Use Pesticides

The tool used to predict aquatic estimated envi ronmental concentrations (EECs) and the number of days a COC is exceeded for down-the-drain emissions is the Exposure and Fate Assessment Screening Tool (E-FAST2) (version 2, August 31, 2009). For the wood preservative treatment process emission scenario, the General Populat ion and Ecological Exposure from Industrial Releases module, hereinafter referred to as th e Industrial Releases module, will be used to develop screening estimates of chlorothalonil and its major transformation toxic residues in surface waters as a result of facility drain releases to WWTPs 29 

### . Inputs in addition to the physical-chemical properties of chlorothalonil and its toxic transformation products include information regarding: the percent removal during wastewater treat ment; production or use volume for the industrial wood pres ervative use (to help determin e the number of facilities); and treatment wood preservative facility information, such as number of days of release per year. For the physical-chemical properties th e Agency anticipates using the available environmental fate information from guideline studies for chloro thalonil and its major degradates which are

summarized in Tables 7 through 9 . An Activated Sludge Respira tion Inhibition Test (ASRI) and one of four biodegradation test s (Ready Biodegradation; Porous Pot; Simulation Test to Assess the Biodegradability of Chemicals Discharged in Wastewater Trea tment, Test for Biodegradation in Activated Sludge; or Simulation Test – Ae robic Sewage Treatment: A. Activated Sludge Units) are required to analyze th e potential impact of the chemi cal on the microorganisms in the biological treatment processes of a WWTP, and to determine its fate and residue levels in surface water receiving effluent discharge. The Ready Biodegradability Test is not an option if the median effect concentration (EC 50 

### ) from the ASRI test is less than or equal to 20 milligrams per liter (mg/L); in that case, one of the th ree simulation tests must be performed.

Default values for volume of wood treated pe r day from the emission scenario for wood preservatives document (OECD, 2002), the water sol ubility of chlorothalonil, and label use rate will be used to estimate releases to a facility drain in units of kilograms per day (kg/site/day).

Facility information needed to estimate aquatic exposures fr om emissions to WWTP from the industrial wood preservative pr ocess include the following:

• The number of facilities that treat (dip , spray, or pressure) wood products with chlorothalonil; and

• How many of these facilities have on-site and/or off-site wastewater treatment.

In the absence of information on the number of facilities that treat wood products with chlorothalonil and how many of these facilities have on-site and/or off-site wastewater treatment, the Agency will assume that all wood treatment f acilities in the United States have the potential

to use chlorothalonil.

In the absence of appropriate test data on biodegradation duri ng wastewater treatment, the Agency will assume that there is no removal of chlorothalonil and its ma jor toxic transformation products during wastewater treatment.

29 http://www.epa.gov/opptintr/exposure/pubs/screen.htm

### 84 The tool used to predict aquatic EECs for leaching and runoff from treated materials ( e.g ., fence, deck, siding, shakes, foundations, etc.) and from c ontaminated soil at wood preservative facilities is expected to be PRZM/EXAMS. A pervious soil, impervious surface, and a combination of pervious and impervious surfaces (residential scenar io) is expected to be used to bound risks. For the physical-chemical properties the Agency anticipates using the available environmental fate information from guideline studies for ch lorothalonil and its majo r degradates which are

summarized in Tables 7 through Table 9 . Emission rate of chloro thalonil and its major toxic transformation products and impuriti es of concern is needed for treated materials as input to determine loading.

Measures of Toxicity

Ecological effect data are used as measures of di rect and indirect effect s to biological receptors. Data were obtained from registrant-submitted studies. Also, prior to completion of the risk assessment, literature studies identified by ECOTOX will also be incorporated as appropriate. The ECOTOXicology database (ECOTOX) will be s earched in order to provide more ecological effects data to bridge existing data gaps. EC OTOX is a source for locating single chemical toxicity data and potential chemical mixture toxicity data for aqua tic life, terrestrial plants, and

wildlife. ECOTOX was created and is mainta ined by the USEPA, Office of Research and Development, and the National Health and Envi ronmental Effects Research Laboratory's MidContinent Ecology Division (USEPA 2007 d ).

Where available, sublethal effects observed in both registrant-submitted and open literature studies will be evaluated qualitatively. Such effects have included behavioral changes [ e.g. , lethargy, changes in coloration and effects to olfaction (relating to the sense of smell) in fish]. Quantitative assessments of risks, though, are lim ited to those endpoints that can be directly linked to the Agency’s assessment endpoints of impaired survival, growth and reproduction.

The assessment of risk for direct effects to non-target organisms makes the assumption that toxicity of chlorothalonil to birds is similar to terrestrial-phase amphi bians and reptiles. The same assumption is made for fish and aquatic-phas e amphibians in the absence of data. If data becomes available for these taxa, then it will be evaluated for use in the risk assessment.

The acute measures of effect used for animals in this screening-level assessment are the LD 50 

### , LC 50 

### and EC 50 

### . LD stands for "Lethal Dose", and LD 50 

### is the amount of a material, given all at once, that is estimated to cause the death of 50% of the test orga nisms. LC stands for “Lethal

Concentration” and LC 50 

### is the concentration of a chemical that is estimated to kill 50% of the test organisms. EC stands for “Effective Concentration” and the EC 50 

### is the concentration of a chemical that is estimated to produce a specific e ffect in 50% of the test organisms. Endpoints for chronic measures of exposure for listed and non-listed animals are the NOAEL/NOAEC and

NOEC. NOAEL stands for “No Observed-Adverse-E ffect-Level” and refers to the highest tested dose of a substance that has been reported to have no harmful (adverse) effects on test organisms. The NOAEC ( i.e. , “No-Observed-Adverse-Effect-Concen tration”) is the highest test

concentration at which none of the observed effects were statistically different from the control.

The NOEC is the No-Observed-Effects-Con centration. For non- listed plants, the EC 25 

### for

### 85 terrestrial plants and EC 50 

### for aquatic plants is used; for li sted plants, either the NOAEC or EC 05 

### is used.

Measures of Risk

Previously completed screening level risk asse ssments and exceedances of Agency levels of

concern indicate a need to further examine and refi ne risk to aquatic and terrestrial animal and aquatic plant species. Analysis of potential indirect effects on listed species (both aquatic and terrestrial) is also required. This analysis pl an will be revisited and may be revised depending upon the data available in the open literature and the information submitted by the public in response to the opening of the Registration Review docket.

Integration of Exposure and Effects

Risk characterization is the integration of e xposure and ecological effe cts characterization to determine the potential ecological risk from th e use of chlorothalonil on use sites listed in Table

4 for conventional uses and for the regi stered antimicrobial used listed in Table 5 , and the

likelihood of direct and indirect e ffects to non-target organisms in a quatic and terrestrial habitats. The exposure and toxicity effects data are integrated in order to evaluate the risks of adverse ecological effects on non-target species For the assessment of chlorothalonil risks for

conventional uses and for antimicrobial uses—ex cept for the down-the-drain analysis, the risk quotient (RQ) method is used to compare exposur e and measured toxicity values. EECs are divided by acute and chronic toxicity values. The resulting RQ values are then compared to the Agency’s LOC values (USEPA 2004). These crite ria are used to indicate when chlorothalonil’s uses, as directed on the label, have the potential to cause adverse di rect or indirect effects to nontarget organisms. In addition, incident data from EIIS, aggregate inci dent reports, and AIMS will be considered as part of the risk charac terization. As noted previously, where data are lacking on the toxicity of chloroth alonil, risk will be presumed.

For down-the-drain risk estimates for antimicrobial uses, exposure and toxicity information is integrated using an approach that estimates the number of days a COC is exceeded, also referred to as a probabilistic dilution model (PDM) a pproach. COC values will be derived for chlorothalonil by multiplying the Agency’s presumptive level of concern (LOC) values, which are unitless, by the most sensit ive endpoint for the relevant receptor group. This allows expression of the LOC values in terms of concen tration. Calculations used for determining COC values are listed in for aquatic animals and plants (see Table 16 ).

Table 16. Aquatic Animal and Plant LOC Values and Comparable COC Values

LOC COC calculations
Aquatic Animals

Acute risk 0.5 (LC 50 

### or EC 50 

### ) × LOC Acute listed species 0.05 (LC 50 

### or EC 50 

### ) × LOC

Chronic risk 1 NOAEC × LOC Aquatic Plants Listed species 1 IC 50 

### × LOC Non-listed species 1 NOAEC a 

### × LOC

a An IC 05 may be used as a surrogate when a NOAEC cannot be determined.

### 86 For a screening level estimate, results are base d on a high-end scenario which represents the averaged probability of exceedance of 10 percent of wastewater treatmen t plants (WWTPs) that have the highest probability of exceedance of the COC following treatment based on the

distribution of the ratio of str eam flows to wastewater treatment plant flows for the category of Standard Industrial Classification (SIC) code th at most closely represents wood preservative treatment facilities These results are expressed as the number of days per year of exceedance of

the concentrations of concern determined for key categories of aquatic organisms, including freshwater fish, freshwater invertebrates, and aquatic plants. EECs based on the 10 th 

### percentile WWTP 1Q10 30 

### and 7Q10 31 

### are also provided. After the Agen cy’s down-the-drain assessment is performed, if any of the Agency’s acute CO Cs for the high-end exposure scenario has a probability of being exceeded > 4 days/year, or a chronic COC has a probability of being

exceeded > 20 days/year, a potential for adverse effects is presumed.

Endangered Species Assessments

Consistent with the Agency’s responsibility under the Endangered Species Act (ESA), the Agency will evaluate risks to Federally-listed th reatened and/or endangere d (listed) species from registered uses of chlorothalonil. This asse ssment will be conducted in accordance with the Overview Document (USEPA, 2004), provi sions of the ESA, and the Services’ Endangered Species Consultation Handbook (USFWS/NMFS, 1998).

The action area is used to identify all listed (t hreatened and endangered) species and designated

critical habitat that could be affected by the Federal action. The Federal action is the authorization or registration of pesticide use or uses as descri bed on the label(s) of pesticide products containing a particular active ingredient. The action area is defined by the Endangered Species Act as, “all areas to be affected directly or indirec tly by the Federal action and not merely the immediate area involved in the action” (50 CFR §402.2). Based on an analysis of the Federal action, the action area is defined by the actual and pote ntial use of th e pesticide.

When conducting the ecological risk assessment for chlorothalonil under Registration Review, the action area will encompass the entire United St ates and its territories. The purpose of defining the action area as the entire United States and its territories is to ensure that the initial area of consideration encompasses all areas where chlorothalonil may be used now and in the future, including the potential for off-site tran sport via spray drift and downstream dilution. Additionally, the concept of a na tionwide action area takes into account the potential for direct and indirect effects and any poten tial modification to critical ha bitat based on ecological effect measures associated with reduction in survival, growth, and reproduction, as well as the full suite

of sublethal effects available in the effects literatu re. It is important to note that the nationwide action area does not imply that dire ct and/or indirect e ffects and critical ha bitat modification are expected to or are likely to occur over the full ex tent of the action area, but rather to identify all listed species and critical habita t that may potentially be affected by the action. The Agency will

30 Hydrologically-based design flow term describing the lowest one-day average flow that occurs (on average) once
every ten years.

31 Hydrologically-based design flow term describing the lowest consecutive seven-day average flow that occurs (on average) once every ten years.

### 87 use more rigorous analysis including consideratio n of available land cover data, toxicity data, and exposure information to determine areas wh ere individual listed species and designated critical habitat may be affected or modified via endpoints associated with reduced survival, growth, or reproduction.

Endocrine Disruptor Screening Program

As required under FFDCA section 408(p), EP A has developed the Endocrine Disruptor Screening Program (EDSP) to determine whether certain substances (inc luding pesticide active and other ingredients) may have an effect in humans or wildlife si milar to an effect produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator may designate.” The EDSP employs a two-tiered ap proach to making the statutorily required

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a chemical substance to interact with the estroge n, androgen, and or thyroid (E, A, or T) hormonal systems. Chemicals that go th rough Tier 1 screening and are found to have the potential to interact with E, A, or T hormonal systems will proceed to the next stag e of the EDSP where EPA will determine which, if any, of th e Tier 2 tests are necessary base d on the available data. Tier 2 testing is designed to identify a ny adverse endocrine related eff ects caused by the substance, and establish a dose-response relationship between the dose and the E, A, or T effect.

Between October 2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 chemicals, which contains 58 pesticid e active ingredients and 9 inert ingredients.

This list of chemicals was selected based on th e potential for human exposure through pathways such as food and water, residen tial activity, and certain post-applic ation agricultural scenarios.

This list should not be construed as a lis t of known or likely e ndocrine disruptors.

Chlorothalonil was among the group of 58 pesticid e active ingredients th at received EDSP test orders. For information on the status of the orders issued under the EDSP for each chemical, please visit our website at http://www.epa .gov/endo/ and click on the "Status of EDSP Orders/DCIs" in the Highlights Box. Additiona l information on the EDSP, including the policies and procedures, the list of 67 chemicals, the test guidelines and the Tier 1 screening battery, can

also be found at this website.

G. P RELIMINARY 

### I DENTIFICATION OF 

### D ATA 

### G APS



### Environmental Fate

Several environmental fate studies have been submitted to support the registration of chlorothalonil; however, many of these studies were classified as supplemental or unacceptable. For many of the studies, the id entification of chlo rothalonil transformation products was not provided. The status of environmental fate studies for chlorothalonil is presented in Table 17

.

### 88 Table 17. Environmental Fate Data Requirement Table for Chlorothalonil

Guideline Description MRID Classification Data Gap? Comments

835.1110 Activated Sludge Sorption Isotherm, TGAI No data

─ Yes To determine extent of partitioning of chlorothalonil and its major toxic transformation products to biosolids for the antimicrobial down-the-drain analysis

835.2120 Hydrolysis 00040539 Supplemental Yes No data have been provided on the

transformation of chlorothalonil under basic conditions. Data on the dissipation of chlorothalonil at pH >7 ( e.g. , pH 9) is

needed.

835.2410 Soil Photolysis 00087349 Supplemental No Despite the guideline deviations in these studies, little would be gained from repeating them—chlorothalonil is

considered stable 00040543 Supplemental No

835.2370 Air Photolysis No data available Yes No data has been provided on the photolysis for chlorothalonil in air.

835.2240 Aqueous Photolysis 45710223 Supplemental Yes MRID 45710223 was originally classified as acceptable; however, after a recent review this study was reclassified as supplemental because three major transformation products (up to 47% AR)

were not identified. Additional data are needed to identify these major transformation products and any other potentially toxic transformation products observed in this study. If this information cannot be provided, a new study is required. If additional data are not provided, these unidentified residues

would be assumed to be as toxic as chlorothalonil or SDS-3701 as part of a total toxic residue approach.

835.3110

or Ready Biodegradability,

TGAI or No data

─ Yes The results of the ASRI effects test (GLN 850.6800 or OECD 209), determine which of these biodegradation tests are required. If the ASRI test EC 50 is < 20 mg/L, then choose either: (i) the Biodegradation in Activated Sludge (835.3280), or (ii) the Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units (835.3240), or (iii) the Porous Pot Test (835.3220). If the ASRI 835.3220

or Porous Pot Study,

TGAI or

835.3240

or Simulation Test – Aerobic Sewage

Treatment: A Activated Sludge Units, TGAI or

### 89 Guideline Description MRID Classification Data Gap? Comments

835.3280 Simulation Tests

to Assess the Primary and

Ultimate Biodegradability

of Chemicals Discharged to Wastewater, also

referred to as the Biodegradation in Activated Sludge

Test TGAI test EC 50 is > 20 mg/L, then the applicant must choose either: (i) Ready Biodegradability (835.3110), or (ii) a) Biodegradation in Activated Sludge (835.3280), or b) the Simulation Test – Aerobic Sewage Treatment: A. Activated Sludge Units (835.3240), or c) the Porous Pot Test (835.3220). If the Ready Biodegradability study is conducted and the antimicrobial passes, then no further testing is required. If, however, the antimicrobial fails the Ready Biodegradability Study, then the (i) Biodegradation in Activated Sludge, or (ii) Simulation Test – Aerobic Sewage

Treatment: A. Activat ed Sludge Units or (iii) the Porous Pot Study is required. In the absence of this data, no biodegradation of the test compound during wastewater treatment would be assumed. Required for the antimicrobial down-the-drain analysis.

835.4100 Aerobic Soil

Metabolism 00087351

00040547 Supplemental

Yes Each of the submitted studies has

deficiencies that limit the use of the data (see Table 5 ). In addition, chlorothalonil

transformation in soil has been shown to be concentration dependent and none of

the submitted studies have been

conducted at the maximum use rates foragricultural or conventional nonagriculture uses. A new study that explores current maximum single application rates is required so that an appropriately representative half-life

value can be calculated. Antimicrobial uses, will have much lower loading rates than the agricultural uses and conventional non-ag uses, and therefore this is not identified as a data gap for

antimicrobial uses. 43879601 Supplemental

47207702 Supplemental

47207703 Supplemental

835.4200 Anaerobic Soil

Metabolism No data available Yes No data have been submitted to fulfill this data requirement; however, an anaerobic aquatic metabolism study is being requested in lieu of the anaerobic soil metabolism study.

835.4300 Aerobic Aquatic

Metabolism 45908001 Supplemental Yes None of the studies identified all the major transformation products and it is 42226101 Supplemental

### 90 Guideline Description MRID Classification Data Gap? Comments

47207701 Supplemental unclear if the degradation rates can be accurately calculated based on the submitted data. For these reasons,

additional data are needed on the

transformation rate of chlorothalonil in aerobic aquatic systems as well as full characterization of all major transformation products or transformation products of toxicological concern.

835.4400 Anaerobic Aquatic

Metabolism 00147975 Supplemental Yes Redox potentials and oxygen concentrations during the experiment were not provided; therefore, it cannot be confirmed that the system was anaerobic.

N o data are provided for day 0. The study was also terminated before the pattern of

formation and decline could be

established for the transformation products in one of the test systems. The test systems did not use an appropriate

sediment/water matrix. A new anaerobic aquatic study is required.

835.1230

835.1240 Adsorption/ Desorption

Batch Equilibrium 00029406 Supplemental Yes Information is needed on the desorption

of chlorothalonil as well as the temperature and the light conditions used in this experiment, if this cannot be provided a new study is required.

835.6100 Terrestrial Field Dissipation 00071627, 00087369, 00087332, 00087301 Supplemental

Yes There were several deficiencies in the submitted studies including: no storage stability data, inadequate sampling intervals, limited sampling depths.

Additional information is needed to confirm the chlorothalonil dissipation conceptual model proposed based on the laboratory data. In addition, environmental chemistry methods for

water and soil should be submitted for chlorothalonil. This study is not required

to conduct the risk assessment for

antimicrobial uses. 00071625 Supplemental

835.8100 Field Volatility No data available Yes No data has been provided on the field volatility of chlorothalonil.

835.6200 Aquatic Field Dissipation 127861 Acceptable No

850.1730 Fish

Bioconcentration 45710224 Acceptable No

850.1710 Oyster Bioconcentration, 43070601 Acceptable No

### 91 Guideline Description MRID Classification Data Gap? Comments

Special Study Wood Leaching Study, TEP No data

─ Yes To determine leach ra te of chlorothalonil and its major toxic transformation

p roducts, and impurities of concern out of preserved wood for use in modeling loading to soil from rain washoff of antimicrobial applied wood preservatives.

The leach rate from other material preservative uses ( e.g ., stucco, paint, coating, and caulk) is desired but in the absence of leaching data, the wood leaching results will be assumed to apply. A protocol should be submitted for Agency review prior to conducting the study.



### Data deficiencies:

Data deficiencies and data ga ps described in this assessmen t were identified in previous assessments (see 1999 RED, 2007 CRLF Assessment, and D371947) and are summarized below.

Data on the amount of SDS-3701 e xpected after chloro thalonil application to only peanut hay, turf, and grass grown for seed are available and do not provide a dependable basis for estimating the amount of SDS-3701 that may form on avian and mammalian food items ( i.e ., tall and short grass). Also, most of the availa ble residue studies were designedto measure the amount of SDS3701 that is taken up by crops a nd how much accumulates in vegetable items associated with human consumption such as beans and fruits, rath er than pesticide concen trations on animal food

items. The amount of SDS-3701 available for terrest rial animal consumption is an uncertainty.

Additionally, EFED recommends that the Agency work with the chlorothalonil registrants to

establish the levels of the known chlorothalonil impurities ( i.e ., HCB and dioxin/furans) in currently registered products. EFED does not anticipate requir ing any environmental effectsrelated data for HCB and dioxin/furans.

H. E FFECTS



### Data gaps:

Although many submissions have been made to pr ovide data on the effect s of chlorothalonil on aquatic and terrestrial organisms, data gaps still exist to support both conventional and antimicrobial uses. Data gaps include the followi ng: avian acute oral toxi city (passerine), avian acute inhalation, terrestrial plan t, acute and chronic estuarine- marine fish, chronic estuarinemarine invertebrate, freshwater and estuarine/ marine sediment toxicity, and activated sludge respiration inhibition. These data gaps are discussed below in Tables 18

, 19 , and 20

.

### 92 Table 18. Summary of Ecological Effects Da ta for Terrestrial Animals Exposed to Chlorothalonil and Identified Data Gaps.

Guideline Description MRID Classification Data
Gap? 

### * Comments

850.2100 Avian acute oral toxicity 00068753 Acceptable Yes 1
(C) 1 Avian acute oral toxicity

data are not available for passerines, which are required under the 40 CFR Part 158. Therefore,

this is identified as a data

gap.

2 An evaluation of

inhalation as a route of exposure using the Screening Tool for Inhalation Risk (STIR, v. 1.0) model suggests that inhalation exposure is a pathway of concern for

avian wildlife due to vapor-phase pesticide 850.2200 Avian dietary toxicity 00030388 Acceptable No 00039146 Acceptable Special study Avian acute

inhalation No data

available Not applicable Yes 2
(C) 850.2300 Avian reproduction 45710218 Accep table No

850.3020 Honeybee acute contact toxicity 00077759 Acceptable No



### * C = data gap for conventional uses

Table19. Summary of Ecological Effects Data for Aquatic Animals Exposed to Chlorothalonil and Identified Data Gaps

Guideline Description MRID Classification Data
Gap? 

### * Comments

850.1075 Freshwater fish – Acute toxicity 45710219 Acceptable No 1 Study re-classified due to variability in reproduction stemming

from number of replicates and issues

with solvent control survival. However, a new study is not requested at this time.

2 Classification based on instability of test

material in test

solutions however a new study is not requested at this time.

3 Conducted as static test 850.1500 Freshwater fish – Life-cycle toxicity 00030391 Supplemental 1 No

850.1010 Freshwater

invertebrates – Acute toxicity 45710221 (TGAI) Acceptable No

850.1300 Freshwater

invertebrate – life cycle test 45710222 (TGAI) Supplemental 2 No

850.1075 Saltwater fish – Acute toxicity 00127863 Supplemental 3 Yes (C,A)

### 93 Guideline Description MRID Classification Data
Gap? 

### * Comments

850.1025 (shell dep) Saltwater

invertebrates – Acute toxicity 00138143 (TGAI; presumably
parent compound) Acceptable No and did not measure test concentrations, study not for quantitative use

4 The submission of study is needed.

5 Study yielded nondefinitive endpoint. 850.1400 Saltwater fish – early life stage test No data No data 4 Yes (C,A)

850.1350 Saltwater

invertebrates – life cycle test 42433807 (TGAI) Unacceptable 5 Yes (C,A)

850.1735 Freshwater

invertebrate – Acute

whole sediment No Data No data 4 Yes (C,A)

850.1740 Estuarine/marine

invertebrate – Acute

whole sediment No Data No data 4 Yes (C,A)



### * C, A = data gap for both conve ntional and antimicrobial uses

Table 20. Summary of Ecological Effects Data for Plants Exposed to Chlorothalonil and Identified Data Gaps

Guideline Description MRID Classification Data
Gap? 

### * Comments

850.4100 Terrestrial Plant toxicity: seedling

emergence

(Tier 1) 42433808 Acceptable Yes (C) The study was not conducted with a typical end-use product (TEP) – it was conducted using TGAI and a solvent (acetone). At 16 lbs a.i./acre (1.2 times the highest currently registered single application rate) there was a 26% inhibition in plant growth for onion when compared to the negative

control.

850.4150 Terrestrial Plant toxicity: vegetative vigor (Tier 1) 42433809 Acceptable Yes (C) The study was not conducted with a typical end-use product (TEP) – it was conducted using TGAI and a solvent (acetone). At 16 lb a.i./acre (1.2 times the highest currently registered single application rate) there was a 26% inhibition in plant growth for cucumber when compared to the negative control.

850.5400 Aquatic Plant Growth: algae

(Tier 1 & 2) 44908105 Acceptable

No -- 44908103 Acceptable

42432801 Acceptable

### 94 Guideline Description MRID Classification Data
Gap? 

### * Comments

44908104 Acceptable

850.4400 Aquatic Plant

Growth: vascular plants (Tier 1 & 2) 44908102 Acceptable No --

850.6800

or OECD

209 Activated Sludge Respiration

Inhibition No data

─ Yes (A) --



### * C = data gap for conventional uses A = data gap for antimicrobial uses C,A = data gap for both conve ntional and antimicrobial uses

Avian Acute Oral Toxicity

Acceptable acute avian oral toxicity data we re submitted for exposures of mallard duck to chlorothalonil; however, data are not available for passerines, which are required under the 40 CFR Part 158 (Oct. 26, 2007) data requirement s for conventional pesticides (72 FR 60934;

USEPA 2007 d ). The Part 158 data requirements specify that acute avian oral toxicity data be submitted for either a mallard duck or bobwhite qu ail and a passerine spec ies. Therefore, an avian oral toxicity test (OCSPP Guideline 850.2100) is needed for pa sserine birds, as specified in 40 CFR Part 158 (Oct. 26, 2007).

Although, there were no mortalitie s observed during the acute or al study available for mallard

ducks and the LD 50 

### value was determined to be greater than 4,640 mg/ kg-bw (the highest concentration tested), the LOAEC in this study wa s determined to be 2,150 mg a.i./kg-bw based on reduced body weight. Weight loss was also not ed in the available av ian sub-acute dietary studies, indicating potentia l toxicity of chlorothal onil to birds. Therefore, this indicates that chlorothalonil may be toxic to birds.

EFED recommends that the Pesticide Re-evalu ation Division (PRD) request submission of a passerine study protocol for review by the Agency pr ior to initiation of this study. If oral acute toxicity data are not submitted for passerines, EFED will assume acute risk for passerine species.

### 95 Avian Acute Inhalation Toxicity

Acceptable acute avian toxicity data were submitted for oral exposures of mallard duck ( Anas platyrhynchos ) to chlorothalonil; however, data are not available for inhalation toxicity. Acute toxicity data using rats indicat e that mammals are much more se nsitive to chlorothalonil when exposed via the inhalation route compared to th e oral route. Furthermore, an evaluation of inhalation as a route of exposur e using the Screening Tool for Inhalation Risk (STIR, v. 1.0) model suggests that inhalation exposure is a path way of concern for avia n wildlife due to vaporphase pesticide. Therefore, EFED recommends re questing an acute avian i nhalation toxicity test using the most sensitive avian species as shown by avian acute oral studies. The study being requested will aid in evaluating this pathway of concern for avian taxa. An avian inhalation study protocol must be submitted for review and appr oval by the Agency prior to initiation of this study.

Terrestrial Plant Studies

Terrestrial plant toxicity studies using TEP(s) and associated risk analysis of plants are required for registration of conventional pesticides with outdoor uses (CFR Part 158). For terrestrial plants, Tier II studies are required when potential concerns are triggered ( i.e ., when there is some indication that there may be signifi cant toxicity to plants). These indicators may be an herbicidal mode of action, statements on the labe l indicating toxicity to plants, or ≥ 25% effect levels in the

Tier I studies.

Tier I seedling emergence and vegetative vigor st udies are available for chlorothalonil using 16 lb a.i./acre test concentrations (MRI Ds 42433808 and 42433809). These studies were not conducted with a typical end-use product (TEP), but were instead conducted using chlorothalonil mixed with a solvent (100% acetone). When th e results are compared to the negative (and not the pooled) control, onion shows an inhibition in growth of 26% in the seedling emergence study and cucumber shows a 26% inhibition in growth in the vegetative vigor study at the 16 lbs

a.i./acre concentration.

Because these studies were conducted using TGAI mixed with acetone (instead of a TEP) and there were effects greater than 25% noted in the studies for some species, EFED recommends that these data be requested for the chlorothalonil risk assessment. If additional toxicity data for terrestrial plants are not submitted for chloroth alonil, EFED will assume risk for terrestrial plants.

Acute and Chronic Estuarine-marine Fish Studies

The available acute sheepshead study was conducted as a static study and th e test concentrations

were not measured. Given the difficulties in ma intaining test concentrations observed in other aquatic fish toxicity studies, th ere is substantial uncertainty in the actual exposure concentrations in the acute sheepshead study. As chlorothalonil is very highly toxic to fish, the use of nominal test concentrations is probably underes timating risk to estuarine-marine fish.

### 96 A chronic toxicity test with chlorothalonil for estuarine-marine fish is not available. As chlorothalonil is toxic to fish, this study is needed to evaluate risk to estuarine-marine fish. If data are not provided, EFED will assume risk to estuarine-marine fish.

Chronic Estuarine-marine Invertebrate Study

The available chronic mysid shrimp toxicity stud y is classified as unacceptable based on several factors: 1) test concentrati ons of several replicates were variable and did not meet ASTM requirements; 2) average solvent control surv ival was only 62%; and, 3) the NOAEC and MATC could not be determined. A recalculation (Dunnett’s test) of the endpoints for this study using the current methodology of using the negative contro l yielded a significant difference at every

concentration level and a non-definitive NOAEC of <0.65 μ g a.i./L. On this basis and additional issues with the study, this study has been re-c lassified as unacceptable and a new study is requested at this time.

Freshwater and Estuarine-ma rine Sediment Studies

Based on it use pattern and fate properties, chlo rothalonil has the potential to reach freshwater and estuarine-marine aquatic e nvironments and bind to sediment . In addition, a 28-day study, in which chlorothalonil was applied to water, provided evidence that chlorothalonil is toxic to sediment-dwelling organisms in a water-sediment system. Therefore, 10-day toxicity test following OPPTS 850.1735 and 850.1740 guidelines are requested for both freshwater organisms, Chironomus tentans and Hyallela azteca as well as the recommended estuarine/marine organism, Leptocheirus plumulosus . However, since chlorothalonil may be persistent in terrestrial envir onments, based on the aerobic soil metabolism, and is expected to enter aquatic environments through runoff, this runoff may provide a more chronic or pulsed exposure to sediment organisms. Therefore, it is recommended that afte r the 10-day studies are submitted and reviewed, if there is evidence that chronic toxicity testing may be warranted (based on observed toxicity and persistence in the 10-day studies and modeled EECs), then chronic testing, which would eval uate reproduction as well as su rvival and growth, should also be requested.

I. O THER 

### I NFORMATION 

### N EEDS



### There is specific information that will assist the Agency in refining the environmental fate, ecological risk, endangered species, and dri nking water exposure asse ssments, including any species-specific effects determinations. The Agency is very much interested in obtaining the following information:

1. confirmation on the following label information

a. frequency of application, applicati on intervals, and maximum number of applications per season

b. geographic limitations on use

2. use or potential use distributi on (e.g., acreage and geographica l distribution of relevant crops)

3. use history

### 97 4. median and 90 th 

### percentile reported use rates (lbs. a. i./acre) from usage data – national, state, and county

5. application timing (date of first application and application interval s) by crop – national, state, and county

6. sub-county crop location data

7. usage/use information for non-agricultural uses (e.g., forestry, reside ntial, rights-of-way)

8. directly acquired county-level usage da ta (not derived from state level data)

a. maximum reported use rate (lbs. a.i. /acre) from usage data – county

b. percent crop treated – county

c. median and 90 th 

### percentile number of applications – county

d. total pounds per year – county

e. the year the pesticide was last us ed in the county/sub-county area

f. the years in which the pesticide was applied in the county/sub-county area

9. typical interval (days)

10. state or local use restrictions

11. ecological incidents (non-target plant damage and avian, fish, reptilian, amphibian and mammalian mortalities) not alr eady reported to the Agency

12. monitoring data

13. the amount of dioxins/furans, and HCB present in technical chlorothalonil.

The analysis plan will be revi sited and may be revised dependi ng upon the data available in the open literature and the information submitted by the public in response to the opening of the Registration review docket.

### 98 APPENDIX A. REFERENCES

Agency for Toxic Substances and Disease Registry (ATSDR). 2002. Toxicological Profile for Hexachlorobenzene. U.S. Department of Health and Human Services. Public Health

Service.

Ernst, W.R; J.D.A. Vaughn; A.L. Huybers; K. G. Doe; P.A. Hennigar PA. 1993. The toxicity of chlorothalonil and its 4-hydr oxy metabolite to selected a quatic species. Environment Canada, Environmental Protection, Conser vation and Protection, Dartmouth, Nova Scotia. Unpublished manuscript

Hahn, ME. 2002. Aryl hydrocarbon recepto rs: diversity and evolution. Chem Biol Interact

141:131-160.

Isensee, A.R. and G.E. Jones. 1975. Distribu tion of 2,3,7,8-tetrachlorodi benzo-p-dioxin (TCDD) in aquatic model ecosystem. Environ. Sci. Technol. 9:668-672.

Isensee, A.R. 1978. Bioaccumulation of 2,3,7,8-te trachlorodibenzo-para-dioxin. Ecol. Bull. (Stockholm) 27:255-262.

Killeen JC Jr.; G.A. Leblanc; G.A. Cary. 1977. Acute Toxicity of DS-3701 to the water flea (Daphnia magna). EG & G Bionomics repor t to Diamond and Shamrock Corporation Report No. 1000-5TX-77-0071-001.

McMahon, T.; N. Halstead; S. Johnson; T. Raff el, J. M. Romansic; P. W. Crumrine; R.K. Boughton; L. B. Martin; J. R. Rohr. 2011. Th e Fungicide Chlorothalonil is Nonlinearly Associated with Corticosterone Levels, Immunity, and Mortality in Amphibians. Environ. Health Perspect. 119:1098-1103. http://dx.doi.org/10.1289/ehp.1002956

Mezcua, M.; M.D. Hernando; L. Piedra; A. Aguera; A.R. Fernandez-Alba. 2002. Chromatogrophy-Mass Spectrometry and Toxicity Evaluation of Selected Contaminants

in Seawater. Chromatographia 56(3/4):199-205

Murray, F.J., Smith, F.A., Nitschke, K.D., Hunist on, C.G, Kociba, R.J, and B.A. Schwetz. 1979. Three-generation reproduction study of rats given 2,3,7,8-tetrachlorodobenzo- p - diozin (TCDD) in the diet. Toxicol. Appl. Pharmacol. 50:241-252.

Nosek, J.A., Sullivan, J.R., Hurley, S.S., Ols on, J.R., Craven, S.R. and R.E. Peterson. 1992a. Metabolism and disposition of 2,3,7,8-tetr achlorodibenzo-p-dioxin in ring-necked pheasant hens, chicks, and eggs.. J. Toxicol. Environ. Health, 35:153-164.

Nosek, J.A., Sullivan, J.R., Hurley, S.S., Crav en, S.R. and R.E. Peterson. 1992b. Toxicity and reproductive effects of 2,3,7,8-tetrachlorodibe nzo-p-dioxin toxicity in ring-necked pheasant hens. J. Toxicol. Environ. Health, 35: 187-198.

### 99 Nosek, J.A., Sullivan, Amundson, T.E., Craven, S. R., Miller, L.M., Fitzpatrick, A.G., Cook, M.E. and R.E. Peterson. 1993. Embryotoxicity of 2,3,7,8-tetrachlorodibenzo-p-dioxin in the ring-necked pheasants. E nviron. Toxicol. Chem. 12:1215-1222.

U.S. EPA. 1995. Great Lakes Wate r Quality Initiative cr iteria Documents for the Protection of Wildlife – DDT, Mercury, 2,3,7,8-TCDD, PCBs . U.S. Environmental Protection Agency, Office of Water. March 1995. EPA/820/B/95/008.

U.S. EPA. 2003a. Exposure and Human Hea lth Reassessment of 2,3,7,8- Tetrachlorodibenzo-pdioxin (TCDD) and Related Compounds. Part 1. Estimating Exposure to Dioxin-Like Compounds. Volume 2. Properties, Envir onmental Levels, and Background Exposures.

NAS Review Draft. December 2003. EP A/600/P-00/001Cb. National Center for

Environmental Assessment. Office of Res earch and Development. Washington, D.C.

Available at: http://www.epa.gov/ncea/pdfs/dioxin/nas-review/ (accessed 02/04/2009)

U.S. EPA. 2003b. analysis of laboratory and fiel d studies of reproductive toxicity in birds exposed to dioxin-like compounds for use in ecological risk assessm ent. United States Environmental Protection Agency. Office of Research and Development. National Center

for Environmental Assessment. Cinci nnati, OH. EPA/600/R-03/114F. April, 2003.

U.S. EPA. 2004. Overview of the Ecological Risk Assessmen t Process in the Office of Pesticide Programs. January 23, 2004. Office of Pesticid e Programs. Office of Prevention, Pesticides, and Toxic Substances. Washington, D.C. Available at: http://www.epa.gov/espp/consultation/ecorisk -overview.pdf (accesse d January 26, 2009)

U.S. EPA, 2006b. Technical Factsheet on: Dioxin (2,3,7,8-TCDD). National Primary Drinking Water Regulations. Office of Water. Washington, D.C. Available at: http://www.epa.gov/OGWDW/dwh/t-soc/dioxin.html (accessed February 4, 2009)

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Assessment Forum. EPA 100/R-08/004. June 2008.

Van den Berg, M., L. Birnbaum, A.T. Bosveld et al. 1998. Toxic equivalenc y factors (TEFs) for PCBs, PCDDs, PCDFs for humans and wild life. Environ. Health Perspect. 106(12):775-

792.

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re-evaluation of human and mammalian toxic equivalency fact ors for dioxins and dioxin- like compounds. Toxicol. Sci. 93(2):223-241.

### 100 APPENDIX B: SUBMITTED ENVIRO NMENTAL FATE AND ECOLOGICAL

STUDIES FOR THE REGISTRATI ON OF CHLOROTHALONIL

161-1 Hydrolysis

MRID Citation Reference

0040539

161-2 Photodegradation-water

MRID Citation Reference

40183418 Nelsen, T. (1987) An Aqueous Photolysis Study with [Carbon 14]- 2,4,5,6- Tetrachloroisophthalonitrile (Chlorothalonil), SDS- 2787: Ricerca Study No. 85-0075. Unpublished study prepared by Ricerca, Inc. 59 p.

41030001 Doran, T. (1989) An Aqueous Photolysis Study with ^Carbon 14|-2,4, 5,6- Tetrachloroisothalonitrile (Chlorothalonil), SDS-2787: Document No. 1185-85-0075-EF-001. Unpublished study prepared by Ricerca, Inc. 35 p.

45710223 Kirkpatrick, D. (1996) Chlorothalonil Phot odegradation in Water: Lab Project Number: VCM 42/951419: VCM/42. Unpublished study prepared by Huntingdon Research Centre Ltd. 78 p.

40540 Szalkowski, M.B. (1976) Photodegradation of Daconil in Aqueous Systems. (Unpublished study received Feb 25, 1976 under 6F1749; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:096466-C)

87281 Wolfe, A.L. (1972) The Effect of Ultraviolet Radiation on 4- Hydroxy-2,5,6- trichloroisophthalonitrile in Aqueous Solutions. (Unpublishe d study received Aug 11, 1970 under 1F1024; submitted by Diamond Shamrock Ch emical Co., Clevelan d, Ohio; CDL:093333- A)

161-3 Photodegradation-soil

MRID Citation Reference

40541 Szalkowski, M.B. (1976) Photodegradation of Daconil and Its Metab- olite, 4-Hydroxy-2,5,6- trichloroisophthalonitrile, on Inert Surfaces. (Unpublished study received Feb 25, 1976 under 6F1749; submitted by Diamond Shamrock Ag ricultural Chemicals, Cleveland, Ohio; CDL:096466-D)

40542 Szalkowski, M.B. (1975) Photodegradation of Daconil and 4-Hydroxy- 2,5,6- trichloroisophthalonitrile on Silica Gel Plates. (Unpub- lished study received Feb 25, 1976 under 6F1749; submitted by Diamond Shamrock Agri cultural Chemicals, Cleveland, Ohio; CDL: 096466-E)

40543 Szalkowski, M.B. (19??) Photodegradation and Mobility of Daconil and Its Major Metabolite on Soil Thin Films. (Unpublished study receive d Feb 25, 1976 under 6F1749; submitted by Diamond Sham- rock Agricultural Chemicals, Cleveland, Ohio; CDL:096466-F)

87348 Szalkowski, M.B. (1975) Photodegradation of Daconil and 4-Hydroxy- 2,5,6- trichloroisophthalonitrile on Silica Gel Plates. (Unpub- lished study received Feb 25, 1976 under 6F1749; submitted by Diamond Shamrock Agri cultural Chemicals, Cleveland, Ohio; CDL: 097394-D)

### 101 87349 Szalkowski, M.B. (1975) Photodegradation an d Mobility of Daconil and Its Major Metabolite on Soil Thin Films. (Unpublished study receive d Feb 25, 1976 under 6F1749; submitted by Diamond Sham- rock Agricultural Chemicals, Cleveland, Ohio; CDL:097394-E)

143751 Szalkowski, M. (19??) Photodegradation and Mobility of Daconil and Its Major Metabolite on Soil Thin Films. Unpublished study prepared by Diamond Shamrock Corp. 35 p.

UNACCEPTABLE:

156470 Nelson, T. (1985) Scientific Validity of th e [Carbon-14] Chlorothalonil Soil Photolysis Study. Unpublished study prepared by SDS Biotech Corp. 27 p.

41030002 Nelsen, T. (1989) Photodegradation and Mobility of Daconil and Its Major Metabolite on Soil Thin Films. Unpublished study prepared by Fermenta Plant Protection Co. 22 p.

162-1 Aerobic soil metabolism

MRID Citation Reference

40547 Szalkowski, M.B. (1976) Effect of Microorganisms upon the Soil Metabolism of Daconil and 4- Hydroxy-2,5,6,tric hloroisophthalo- nitrile. (Unpublishe d study received Feb 25, 1976 under 6F1749; prepared in cooperation with Ohio State Univ., Soil Testing Laboratory, submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:096466-J)

87285 Duane, W.C. (1970) Biodegradation of Daconil 2787. (Unpublishe d study received Aug 11, 1970 under 1F1024; submitted by Diamond Shamrock Chemical Co., Cleveland, Ohio; CDL:093333-E).

87351 Szalkowski, M.B. (1976) Effect of Microorganisms upon the Soil Metabolism of Daconil and 4- Hydroxy-2,5,6-tric hloroisophthalo- nitrile . (Unpublished study received Feb 25, 1976 under 6F1749; submitted by Diamond Shamrock Ag ricultural Chemicals, Cleveland, Ohio; CDL:097394-I)

114035 Diamond Shamrock Chemical Co. (1970) The Results of Tests on the Amount of Residue Remaining, Including a Description of the Analytical Method Used: ?Daconil 2787|. (Compilation; unpub- lished study received Sep 1, 1971 under 1F1024; CDL:091899-B)

43879601 Duane, W. (1995) Aerobic Metabolism of (carbon 14)-Chlorothalonil in Soil: Lab Project Number: 93-0295: SDS-2787: 5905-93-0295-EF-002. Unpublished study prepared by Ricerca, Inc. 105 p.

47207702 Gibbings, E.; Bramley, Y. (2000) Chloroth alonil: Aerobic Soil Degradation at Four Treatment Rates: Final Report. Project Number: TMJ4487B, T003973/07. Unpublished study prepared by Syngenta Jealotts Hill International. 37 p.

47207703 Bramley, Y.; Gibbings, E. (2001) Chloro thalonil: Degradation in Aerobic Soil: Final Report. Project Number: RJ3099B, T003974/07. Unpublishe d study prepared by Syngenta Jealotts Hill International. 68 p.

162-2 Anaerobic soil metabolism

MRID Citation Reference

162-3 Anaerobic aquatic metab.

MRID Citation Reference

45330901 Gentle, W. (1999) Chlorothalonil: Dissipatio n in a 30cm Deep Indoor Aquatic Microcosm: Lab Project Number: TMJ4216B. Unpublished study prepared by Zeneca Agro chemicals. 15 p.

### 102 147975 Nelsen, T. (1985) An Anaerobic Aquatic Soil Metabolism Study with [Radiolabeled Carbon]- chlorothalonil: Document No. 680-3EF-84- 0026-001. Unpublished study prepared by SDS Biotech Corp. 68 p.

162-4 Aerobic aquatic metab.

MRID Citation Reference

42226101 Hatzenbeler, C. (1991) An Aerobic Aquatic Soil Metabolism Study with ?carbon 14|- Chlorothalonil: Lab Project Number: 90-0240; 3163-90-0240-EF-001. Unpublished study prepared by Ricerca, Inc. 137 p.

43890604 Frazier, H. (1995) Chlorothalonil--A Summary of Aerobic Aquatic Degradation Data (Half-Life Values) in Natural Water: Lab Project Number: 5980-95-0263-EF-001: 95-0263: J9203008. Unpublished study prepared by Ricerca, Inc. and Toxikon Environmental Sciences. 65 p.

47207701 Hurt, A.; Oliver, S. (200 2) Chlorothalonil: Degradation of (Carbon 14)-Labelled Compound in Natural Water Sediment Systems Under Laboratory Conditions: Final Report. Project Number: RJ3227B, T003976/07. Unpublished study prepared by Syngenta Jealotts Hill International. 86

p.
163-1 Leach/adsorp/desorption

MRID Citation Reference

29406 Szalkowski, M.B.; Stallard, D.E. (198 0) Adsorption of Chloro- thalonil (2,4,5,6- Tetrachloroisophthalonitrile) DS -2787. (Un- published study r eceived Feb 19, 1 980 under 677- 313; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099248- D)

29407 Szalkowski, M.B.; Mannion, J.J.; Stallard, D.E.; et al. (1979) Quantitation and Characterizationof the Biotransformation Pro- ducts of 2,4,5,6-Tetrachloroisophthalonitrile (Chlorothalonil, DS2787) in Soil. (U npublished study received Feb 19, 1980 un- der 677-313; submitted by Diamond Shamrock Agricultural Chemi- cals, Cleveland, Ohio; CDL:099248-E)

40546 Szalkowski, M.B. (1976) Leaching of Degr adation Products. (Unpub- lished study received on unknown date under 6F1749; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:096466-I)

71058 Johnston, E.F. (1981) Soil Disappearance Studi es with Benlate^(R)I Fu ngicide and Bravo^(R)I 500 F Fungicide, Alone and in Combina- tion: Document No. AMR-06-81. (Unpublished study received Feb 27, 1981 under 352-354; submitte d by E.I. du Pont de Nemours & Co., Wilmington, Del.; CDL:244633-B)

87286 Wolfe, A.L.; Stallard, D.E. (1968) The Fate of DAC-3701 (4-Hydroxy- 2,5,6- trichloroisophthalonitrile) in Soil. (Unpublished study receive d Aug 11, 1970 under 1F1024; submitted by Diamond Sham- rock Chemical Co., Cleveland, Oh io; CDL:093333-F)

87332 Stallard, D.E.; Wolfe, A.L. (1967) The Fate of 2,4,5,6-Tetra- chloro isophthalonitrile (Daconil 2787) in Soil. (U npublished study received May 17, 1967 under 7F0599; submitted by Diamond Alkali Co., Cleveland, Ohio; CDL:090770-J)

87349 Szalkowski, M.B. (1975) Photodegradation an d Mobility of Daconil and Its Major Metabolite on Soil Thin Films. (Unpublished study receive d Feb 25, 1976 under 6F1749; submitted by Diamond Sham- rock Agricultural Chemicals, Cleveland, Ohio; CDL:097394-E)

87350 Szalkowski, M.B. (1976) Leaching of Degradation Products: ?Daco- nil|. (Unpublished study received Feb 25, 1976 under 6F1749; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:097394-H)

### 103 87369 Skinner, W.A.; Wolfe, A.L.; Stallard, D.E. (1965) Determinations of the Fate of 2,4,5,6- Tetrachloroisophthalonitrile (D aconil 2787) in Soil. (Unpublished stud y received Sep 30, 1965 under 677- 229; submitted by Diamond Shamrock Agricultural Ch emicals, Cleveland, Ohio; CDL:120430-A)

115105 Capps, T.; Marciniszyn, J.; Marks, A.; et al . (1982) Adsorption and Desorption of Chlorothalonil

to Soils: Document No. 555- 4EF-81- 0216-0 01. (Unpublished study received Sep 21, 1982 under 0F2405; submitted by Diamond Shamrock Corp., Cleveland, OH; CDL: 071096-B)

137232 Nelsen, T.; Marks, A.; Ignatoski, J. (1983) Mobility of Chlorothal- onil and Metabolites in Soil:

Document No. 000-3EF-83-01 12-002; Report/DS- 2787. (Unpublished st udy received Dec 20, 1983 under 50534-8; submitted by SDS Biotech Corp., Painesville, OH; CDL: 252253-A)

138144 Vonk, J.; Van Den Hoven, A.; De Jong, P.; et al. (1983) Mobility of Chlorothalonil and Metabolites in Soil: Report No. 83/0684a/ 4205-61044/ HV/IH. (Unpublished study received Jan 10, 1984 under 50534-8; prepared by Institute of Applied Chemistry TNO, Neth., submitted by SDS Biotech Corp., Painesv ille, OH; CDL: 072267-A)

143752 Nelson, T. (1 985) An Aged Soil Leaching Study with [Carbon-14]- Ch lorothalonil (2, 4, 5, 6- Tetrachloroisophthalonitrile). Un- published study prepared by SDS Biotech Corporation. 13 p.

153730 Nelson, T. (1 985) An Aged Soil Leaching Study with [Carbon-14]- Ch lorothalonil (2, 4, 5, 6- Tetrachloroisophthalonitrile): Report No. SD S-2787. Unpublished study prepared by SDS Biotech Corp. 71 p.

153731 Capps, T. (1982) Adsorption and Desorption of Chlorothalonil to Soils: Report No. DS-2787. Unpublished study prepared by Dia- mond Shamrock Corp. 57 p.

44483404 Waller, R. (1992) Adsorption and Desorption of SDS-46851 to Soils: Lab Project Number: 90- 0374: 3605-90-0374-EF-001: REPORT/SDS-46851. Unpublished study prepared by Ricerca, Inc. 102 p.

44483405 Archer, G. (1991) Adsorption and Desorption of SDS-3701 to Soils: Lab Project Number: 90-

0375: 3606-90-0375-EF-001: REPORT/SDS-3701. U npublished study prepared by Ricerca, Inc. 120 p.

163-2 Volatility - lab

MRID Citation Reference

143751 Szalkowski, M. (19??) Photodegradation and Mobility of Daconil and Its Major Metabolite on Soil Thin Films. Unpublished study prepared by Diamond Shamrock Corp. 35 p.

164-1 Terrestrial field dissipation

MRID Citation Reference

71625 Nixon, W.B. (1981) Tank Mix Soil Dissipation Studies: Ridomil^(R)I/ Bravo^(R)I; Ridomil^(R)I/Difolatan^(R)I; Ridomil^(R)I/Dithane M- 45^(R)I: Report No. EIR-81003. (Unpublished study received Apr 15, 1981 under 100-607; subm itted by Ciba-Geigy Corp., Greens- boro, N.C.; CDL:070010-A)

71627 Ciba-Geigy Corporation (1980) ?Tank Mix Soil Dissipation Studies with Various Chemicals|: AG-A 4801 I, II A. (Compilation; unpublished study, including AG-A 4801 I, II, III, 2nd Report A, 4802 I, II, III, 48 02 I, II, III, Second Report B..., received Apr 15, 1981 under 100-607; CDL:070010-E)

87296 Stallard, D.E.; Wolfe, A.L.; Duane, W.C. (197 2) Evaluation of the Leaching of Chlorothalonil

under Field Conditions and Its Poten- tial To Contaminate Underground Water Supplies. (Unpublished study received Feb 25, 1976 u nder 6F1749; submitted by Diamond Shamrock

### 104 Chemical Co., Cleveland, Ohio; CDL:098072-R)

87300 Wolfe, A.L.; Stallard, D.E. (1965) Residue of Tetrachloroisoph- thal onitrile (Forturf) in Soil Resulting from Foliar Application to Establis hed Turf. (Unpublished study received Dec 21, 1965 under unknown admin. no.; submitted by Diamond Shamrock Chemical Co., Cleveland, Ohio; CDL:110552-A)

87332 Stallard, D.E.; Wolfe, A.L. (1967) The Fate of 2,4,5,6-Tetra- chloro isophthalonitrile (Daconil 2787) in Soil. (U npublished study received May 17, 1967 under 7F0599; submitted by Diamond Alkali Co., Cleveland, Ohio; CDL:090770-J)

87369 Skinner, W.A.; Wolfe, A.L.; Stallard, D.E. (1965) Determinations of the Fate of 2,4,5,6- Tetrachloroisophthalonitrile (D aconil 2787) in Soil. (Unpublished stud y received Sep 30, 1965 under 677- 229; submitted by Diamond Shamrock Agricultural Ch emicals, Cleveland, Ohio; CDL:120430-A)

41564828 Rose, C.; Ballee, D. (1988) Determin ation of Residues (Field-Soil Dissipation) of Tetrachloroisophthalonitrile (Chlorothalonil, SDS-2787), Its Soil Metabolites and Manufacturing Impurities in Soil from Bravo Tr eated Areas-Donalsonville, GA-1986-1988: Lab Project Number: 1401-86-0084-CR-002: 1401-86-0084. Unpublished study prepared by Ricerca, Inc. 413 p.

41564829 Formanik, J. (1989) Field-Soil Dissipation of Residues of Tetra- chloroisophthalonitrile (Chlorothalonil, SDS-2787), Its Soil Metabolites and Manufacturing Impurities in Soil from Bravo Treated Areas-Fresno, CA-1986-1988: Lab Project Number: 1401-86- 0084-cr-003: 1401-86-0084. Unpublished study prepared by Ri- cerca, Inc. 550 p.

41564830 King, C. (1989) Field-Soil Dissioation of Residues of Tetrachloro- isophthalonitrile (Chlorothalonil, SDS-2787), Its Degradatio n Products and Manufacturing Impurities in Soil from Bravo Treated Areas-Greenfirld, CA.-1986-1988: Lab Project Number: 1401-86- 0084- CR-004. Unpublished study prepared by Ricerca, Inc. 361 p.

42433813 Kenyon, R.; Ballee, D. (1991) Field Soil Dissipation of Residues of Tetrachloroisophthalonitrile (Chlorothalonil, SDS-2787), It's Soil Metabo lites and Manufacturing Impurities in Soil from Bravo Treated Areas--Phelps, NY: 1986-1988: Lab Project Number: 86-0084: 1401-86-0084- CR-018. Unpublished study prepared by ISK Biotech Corp. 340 p.

42433814 Kenyon, R. (1991) Residues of Tetrachloroisophthalonitrile (Chlorothalonil, SDS-2787), It's Degradation Products and Manufacturing Impur ities in Soil from a Stability Study--One Year Interim Report: Lab Project Number: 3436-89-0375: 3436-89-0375-CR-001. Unpublished study prepared by Ricerca, Inc. 137 p.

42875907 Jacobson, B.; Schollenberger, J. (1992) Dissipation of 4-Hydroxy-2,4,5- Trichloroisophthalonitrile (SDS-3701) in Soil: A Re-analysis of Chlorothalonil Soil Dissipation Data: Lab Project Number: 1874-T. Unpublished study prepared by Ricerca, Inc. 23 p.

44006001 Ricerca, Inc. (1996) Environmental Fate of Chlorothalonil and Metabolites in Soil, Plants,

Surface Water and Ground Water--Additional New Informati on: Lab Project Number: EF-96- HF-020-001-001: WR 1201T: 762-3AS-86-0010-000. Unpublished study. 206 p.

164-2 Aquatic field dissipation

MRID Citation Reference

127861 Diamond Shamrock Agricultural Chemicals (1982) ?Bravo: Residues in Rice and Other Subjects|. (Compilation; unpublished study re- ceived Apr 21, 1983 under 677-313; CDL:071553-B)

45908001 Kirkpatrick, D. (1996) Chlorothalonil Degrad ability and Fate in Water/ Sediment Systems: Lab Project Number: VCM 45: VCM 45/962245. Unpublished study prepared by Technology

### 105 Sciences Group Inc. 126 p.

165-0 Accumulation Studies -- General

MRID Citation Reference

115104 Marciniszyn, J.; Marks, A.; Ignatoski, J. (1982) Characterizati on and Quantitation of 14Cresidues in Water, Soil and Fish Exposed to 14C-2,4,5,6-tetrachloroisophthalonitrile (Chlorothalonil, DS-2787) in a Static Aquatic System: Document No. 078-3EI-79- 0030-002. (Unpublished study received Sep 21, 1982 u nder 0F2405; submitted by Diamond Shamrock Corp., Cleveland, OH; CDL: 071096-A)

127860 Stallard, D.; Marks, A.; Ignatoski, J.; et al. (1982) Evaluation of the Residues of ... Chlorothalonil, DS-2787 and ... DS-3701 on Ri ce Straw, Rice Grain and the Impact of Rice Paddy Ecology: Document No . 069-3CR-82-013 6-001. (Unpublished study received Apr 21, 1983 under 677-313; submitted by Diamond Shamrock Ag- ricultural Chemicals, Cleveland, OH; CDL:071553-A)

127862 Hutchinson, C.; Shults, S.; Killeen, J.; et al. (1982) Aquatic Field Study with Bravo 500:

Document No. 518-5TX-81-01 71-003. (Unpublished study recei ved Apr 21, 1983 under 677- 313; sub- mitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH; CDL:071552- A)

137146 Shults, S.; Killeen, J.; Ignatoski, J. (1982) Aquatic Field Study with Bravo 500: Document No.

518-5TX-81-0171- 003. (Unpublished study received Jan 18, 1984 under 50534-8; prepared by Diamond Shamrock Corp., submitted by SDS Biot ech Corp., Painesville , OH; CDL:072280-A)

### 106 71-1 Avian Single Dose Oral Toxicity

MRID Citation Reference

30395 Beavers, J.B.; Fink, R.; Brown, R. (1978) Final Report: Acute Oral LD50--Mallard Duck: Project No. 111-110. (Unpublished study includi ng submitter summary, received Feb 19, 1980 under 677- 313; prepared by Wildlife International, Ltd. in cooperation with Washington College, submitted by Diamond Shamrock Agricul- tural Chemicals, Cleveland, Ohio; CDL:099247-N)

68753 Fink, R.; Beavers, J.B.; Brown, R. (1977) Final Report: Acute Oral LD50--Mallard Duck: Project No. 111-109. (Unpublished study, including submitter summary, received Jan 19, 1978 under 677- 229; prepared by Wildlife International Ltd. and Washington College, submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:232729-A)

40964105 Shults, S.; Wilson, N.; Killeen, J. (1987) Acute Oral Toxicity (LD50) Study in Japanese Quail with Technical Chlorothalonil: Ricerca--Document No. 1582-87-0041-TX-002. Unpublished study prepared by Wildlife International Ltd. 54 p.

71-2 Avian Dietary Toxicity

MRID Citation Reference

30388 Shults, S.K.; Killeen, J.C., Jr.; Heilman, R. D. (1979) Chlorothalo- nil (Technical) Eight-Day Dietary (LCI50^) Study in Bobw hite Quail. (Unpublished study received Feb 19, 1980 under 677- 313; prepared in cooperation with Wild life International, Ltd., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland Ohio; CDL:099247-A)

30389 Shults, S.K.; Killeen, J.C., Jr.; Heilman, R.D. (1979) Chlorothalon il (Technical) Eight-Day Dietary (LC50) Study in Mallard Ducks. (Unpub lished study received Feb 19, 1980 under 677- 313; prepared in cooperation w ith Wildlife International, Ltd., submitted by Diamond Shamrock Agricultural Chemicals, Clev eland, Ohio; CDL:099247-B)

39146 Dieterich, W.H. (1965) Acute Dietary Administration--Wildfowl: Project No. 200-163. (Unpublished study received Feb 25, 1976 under 6F1749; prepared by Hazleton Laboratories, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:096459- B)

115108 Shults, S.; Killeen, J.; Ignatoski, J. (1981) Dietary Study (LC50) in Mallard Ducks with DS3701 (4-Hydroxy-2,5,6-trichloroiso- phthalonitrile): Document No. 449-5TX-81-0008-002. (Unpublished study received Sep 21, 1982 u nder 0F2405; submitted by Diamond Shamrock Corp., Cleveland, OH; CDL:071097-B)

115109 Shults, S.; Killeen, J.; Ignato ski, J. (1981) Dietary Study (LC50) in Bobwhite Quail with DS3701 (4-Hydroxy-2,5,6-trichloroiso- phthalonitrile): Document No. 448-5TX-81-0007-002. (Unpublished study received Sep 21, 1982 u nder 0F2405; submitted by Diamond Shamrock Corp., Cleveland, OH; CDL:071097-C)

71-4 Avian Reproduction

MRID Citation Reference

41440 Fink, R. (1976) Final Report: One-Generation Reproduction Study-- Bobwhite Quail: Project No. 111-107. (Unpublished study in- cluding su bmitter summary, received Feb 19, 1980 under 677-313; prepared by W ildlife International, Ltd., submitte d by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099247-F)

41441 Fink, R. (1976) Final Report: One-Generation Reproduction Study-- Mallard Duck: Project No. 111-108. (Unpublished st udy including submitter summary, received Feb 19, 1980 under 677-

### 107 313; pre- pared by Wildlife International, Ltd., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099247-G)

40729401 Shults, S.; Wilson, N.; Killeen, J. (1988) Pilot Reproduction Study in Mallard Ducks with 4- Hydroxy-2,5,6-trichloroisophthalonitrile Project ID. 230-102. Unpublished study prepared by

Wildlife International Ltd. and Ricerca, Inc. 134 p.

40729402 Shults, S.; Wilson, N.; Killeen, J. (1988) Reproduction Study in Mallard Ducks with 4-Hudroxy2,5,6-trichloroisophthalonitrile: Project ID. 230-106. Unpublished study prepared by Wildlife International Ltd. and Ricerca, Inc. 193.

40729403 Shults, S.; Wilson, N.; Killeen, J. (1988) Pilot Reproduction Study in Bobwhite Quail with 4- Hydroxy-2,5,6-trichloroisophthalonitrile: Project ID. 230-101. Unpublished study prepared by

Wildlife International Ltd. and Ricerca, Inc. 131 p.

40729404 Shults, S.; Wilson, N.; Killeen, J. (1988) Reproduction Study in Bobwhite Quail with 4- Hydroxy-2,5,6-trichloroisophthalonitrile: Project Id. 230-105. Unpublished study prepared by

Wildlife International Ltd. and Ricerca, Inc. 195 p.

40964101 Shults, S.; Wilson, N.; Killeen, J. (1988) Pilot Reproduction Study in Mallard Ducks with Technical Chlorothalonil: Document No. 1469-87-0003-TX-002. Unpublished study prepared by Wildlife In- ternational Ltd. in co operation with Ricerca, Inc. 138 p.

40964102 Shults, S.; Wilson, N.; Killeen, J. (1988) Reproduction Study in Mallard Ducks with Technical Chlorothalonil: Ricerca--Document No. 1469-87-0004-TX-002. Unpublished study prepared by Wild- life International Ltd. in cooperation with Ricerca, Inc. 196 p.

40964103 Shults, S.; Wilson, N.; Killeen, J. (1988) Pilot Reproduction Study in Bobwhite Quail with Technical Chlorothalonil: Ricerca--Docu- ment No. 1469-87-0005-TX-002. Unpublished study prepared by Wildlife International Ltd. in cooperation with Ricerca, Inc. 136 p.

40964104 Shults, S.; Wilson, N.; Killeen, J. (1988) Re production Study in Bobwhite Quail with Technical Chlorothalonil: Ricerca--Document No. 1469-87/-0006-TX-002. Unpublished study prepared by Wild- life International Ltd. in cooperation with Ricerca, Inc. 185 p.

45710218 Redgrave, V. (1993) Chlorothalonil: Bobwhite Quail Dietary Reproduction and Tolerance Studies: Lab Project Number: VCM 11/930496. Unpublished study prepared by Huntingdon Research Centre Ltd. 314 p. {OPPTS 850.2300}

BEES:

MRID: 77759

Citation

Reference: Atkins, E.L., Jr.; Anderson, L.D. (1969) Effect of Pesticides on Apiculture: Project No. 1499; Research Report CF-4863. Annual rept., Oct 1968. (Unpublished study received Mar 16, 1970 under 0F0961; prepared by Univ. of California--River side, Dept. of Entomology, submitted by Nor-Am Agricultural Products, Inc., Na perville, Ill.; CDL:093272-B)

72-1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

87258 McCann, J.A.; Pitcher, F. (1973) ?Bravo TM W-75: Bluegill (?~Lepomis macrochirus?~)|: Test No. 548. (U.S. Environmental Protection Agen cy, Pesticide Regulation Div., Agricultural Research Center, Animal Biology Laboratory and Fish Toxicity Laboratory; unpublished study; CDL:128550-A)

87303 Pitcher, F. (1972) ?Tetrachloroisophthalonitrile: Rainbow Trout (?~Salmo gairdneri~?)|: Test No. 503. (U.S. Agricultural Re- search Service, Pesticides Regulation Div., Animal Biology Lab- oratory; unpublished study; CDL:130256-A)

### 108 87304 Pitcher, F. (1972) ?Tetrachloroisophthalonitrile: Rainbow Trout (?~Salmo gairdneri~?)|: Test No. 504. (U.S.Agricultural Re- search Service, Pesticides Regulation Div., Animal Biology Labo- ratory; unpublished study; CDL:130254-A)

42433804 Gelin, M.; Laveglia, J. (1992) Bravo 720--Acute Toxicity to Bluegill Sunfish (Lepomis macrochirus) under Flow-Through Conditions : Lab Project Number: 5088-91-0428-TX-002: 12073. 1091.6110.105: 91-0428. Unpublished study prepared by Ricerca, Inc. and Springborn Labs, Inc. 69 p.

42433805 Wuthrich, V. (1990) Daconil 2787 Extra: 96-Hour Acute Toxicity Study (LC50) in the Rainbow Trout: Lab Project Number: 25 8052. Unpublished study prepared by RCC UmweltChemie Ag. 44 p.

43302101 Shults, S.; Brock, A.; Laveglia, J. (1994) Acute Toxicity to Rainbow Trout (Oncorhynchus mykiss) under Flow-through Conditions with BRAVO 720: Final Report: Lab Project Number: 5727/93/0120/TX/002: 93/0120: 94/1/5129. Unpublished study prepared by Ricerca, Inc. and Springborn Laboratories, Inc. 93 p.

45425803 Forster, A. (1998) Chlorothalonil: Assessm ent of Acute Toxicity to Rainbow Trout in the Presence of Sediment: Lab Project Number: RIA 002/983531. Unpublished study prepared by Huntingdon Life Sciences Ltd. 151 p.

45710219 Douglas, M. (1992) Chlorothalonil: The Acut e Toxicity to Rainbow Trout: Lab Project Number: VCM 8(B)/920232. Unpublished study prepared by Huntingdon Research Centre Ltd. 25 p. {OPPTS 850.1075}

45710220 Douglas, M. (1992) The Acute Toxicity of Chlorothalonil to Common Carp: Lab Project Number: VCM 8(C)/920233. Unpublished study prepared by Huntingdon Research Centre Ltd. 24 p. {OPPTS 850.1075}

72-2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

68754 LeBlanc, G.A. (1977) Acute Toxicity of DTX-77-0072 to the Water Flea (~Daphnia magna~). (Unpublished study, including submit- ter su mmary, received Jan 19, 1978 under 677-229; prepared by EG & G, Bionomics, submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:232729-B)

42433806 Gelin, M.; Laveglia, J. (1992) Bravo 720--Acute Toxicity to Daphnids (Daphnia magna) under Flow-through Conditions: Lab Project Number: 5087-91-0427-TX-002: 12073.1091.6108.115: 91-0427. Unpublished study prepared by Springborn Labs, Inc. and Ricerca, Inc. 135 p.

45425801 Forster, A. (1998) Toxicity of Chloroth alonil to the Sediment Dwelling Phase of the Midge Chironomus Riparius: Lab Project Number: RIA 1/974025. Unpublished study prepared by Huntingdon Life Sciences Ltd. 54 p.

45425802 Forster, A. (1998) Chlorothalonil: Assessm ent of Acute Toxicity to Daphnia Magna in the Presence of Sediment: Lab Project Number: RIA 003/982279. Unpublished study prepared by Huntingdon Life Sciences Ltd. 150 p.

45710221 Douglas, M. (1992) The Acute Toxicity of Chlorothalonil to Daphnia magna: Lab Project Number: VCM 8(A)/920231. Unpublished study prepared by Huntingdon Research Centre Ltd. 24 p. {OPPTS 850.1010}

72-3 Acute Toxicity to Estuarine/Marine Organisms

MRID Citation Reference

127863 Ward, S.; Shults, S.; Killeen, J.; et al. (19 82) Static Acute Toxicity Study in Sheepshead

### 109 Minnows with Technical Chlorothalonil: Document No. 537-5TX-82-0053-002. (Unpublished study received Apr 21, 1983 under 677-313; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH; CDL:071552-B)

127864 Ward, S.; Shults, S.; Killeen, J.; et al. (1982) Static Acute Toxicity Study in Penaeid (Pink) Shrimp with Technical Chloro- thalonil: Document No. 537-5TX-82-0054-002. (Unpublished study received Apr 21, 1983 under 677-313; submitted by Diamond Sham- rock Agricultural Chemicals, Cleveland, OH; CDL:071552-C)

127865 Armstrong, D.; Buchanan, D.; Caldwell, R. (1976) A mycosis caused by lagenidium sp. in laboratory-reared larvae of the dungeness cr ab, cancer magister, and possible chemical treatments. Jour- nal of Invertebrate Pathology 28:329-336. (Also In unpublished submission received Apr 21, 1983 under 677-313; subm itted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH; CDL: 071552-D)

138143 Ward, G.; Shuba, P. (1983) Acute Toxicity of T-117-11 to Eastern Oysters (Crassostrea virginica): Report No. BP-83-2-25. (Un- published study received Jan 10, 1984 under 50534-8; prepared by EG & G Bionomics, submitted by SDS Biotech Corp., Painesville, OH; CDL:072266-A)

72-4 Fish Early Life Stage/ Aquatic Invertebrate Life Cycle Study

MRID Citation Reference

29410 Szalkowski, M.B.; Stallard, D.E.; Bachand, R.T., Jr. (1979) Acute Toxicity of 2,4,5,6- Tetrachloroisophthalonitrile (Chlorothalo- nil) to Bluegill Sunfish (?~Lepomis macrochirus~?): Research Re- port R-79-0003. (Unpublished study received Feb 19, 1980 under 677-313; submitted by Diamond Shamrock Agricultural Chem icals, Cleveland, Oh io; CDL:099248-H)

29415 Szalkowski, M.B.; Stallard, D.E.; Bachand, R.T., Jr. (1979) Acute Toxicity of 4-Hydroxy-2,5,6- trichloroisophthalonitrile (DS-370 1) to Bluegill Sunfish (?~Lepomis macrochirus~?): Research Report R-79-0004. (Unpublished study received Feb 19, 1980 under 677 - 313; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099248-M)

30390 Shults, S.K.; Killeen, J.C., Jr.; Heilman, R. D.; et al. (1980) Chloro thalonil (Technical) Acute Toxicity (LCI50^) Study in Channel Catfish. (Unpublished study including report # BW-79-6- 460, received Feb 19, 1980 unde r 677-313; prepared in coopera - tion with EG&G, Bionomics, submitted by Diamond Shamrock Agri- cultural Ch emicals, Cleveland, Ohio; CDL:099247-E)

30393 Buccafusco, R.J. (1977) Acute Toxicity of DTX-77-0070 to Bluegill (?~Lepomis macrochirus~?). (Unpublished study including s ub- mitter summary, received Feb 19, 1980 under 677-313; prepared by EG&G, Bionomics, submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099247-L)

39145 Dieterich, W.H. (1965) Acute Aqueous Exposure--Fish: Project No. 200-164. (Unpublished study received Feb 25, 1976 under 6F1749; prep ared by Hazleton Labora tories, Inc., submitted by Diamond Shamrock Agricultural Chemical s, Cleveland, Ohio; CDL: 096459-A)

41439 Shults, S.K.; Killeen, J.C., Jr.; Heilman, R. D.; et al. (1980) Chloro thalonil (Technical) Acute Toxicity (LCI50^) Study in Bluegill. (Unpublished study including report # BW-79-6-446, received Feb 19, 1980 under 677-313; prepared in coopera tion with EG&G, Bionomics, submitted by Diamond Shamrock Agricul- tural Chemicals, Cleveland, Ohio; CDL:099247-D)

56486 Shults, S.K.; Killeen, J.C., Jr.; Heilman, R.D. (1980) Chlorothalo- nil (Technical) Acute Toxicity (LCI50^) Study in Rainbow Trout. (Unpublished study including report # BW-79-6- 461, re- ceived Feb 19, 1980 under 677-313; prepared in cooperation with EG&G, Bionomics, submitted by Diamond Shamrock Agricultural Chem icals, Cleveland, Oh io; CDL:099247-C)

115107 Shults, S.; Killeen, J.; Ignatoski, J. (1982) Chronic Toxicity Study in Daphnia magna with

### 110 Technical Chlorothalonil: Document No. 447-5TX-81-0006-002. (Unpublished study received Sep 21, 1982 under 0F2405; submitted by Diamond Shamrock Corp., Cleve- land, OH; CDL:071097-A)

42433807 Shults, S.; Brock, A.; Laveglia, J. (1991) Flow-through Life-Cycle Toxicity Test in Mysid Shrimp with Technical Chlorothalonil: La b Project Number: 322 8-89-0043-TX-002: 12073. 0289. 6100. 530: 90-05-3330. Unpublished study prepared by Springborn Labs, Inc. and Ricerca, Inc. 103 p.

42924901 Surprenant, D. (1993) Individual Growth Data for First Generation Male and Female Shrimp for the Study, "Flow-through Life-cycle Toxic ity Test in Mysid Shrimp with Technical Chlorothalonil," (MRID #42433807; Doc. No. (3228-89-0043-TX-002): Lab Project Number: FW-93-RPB-004-001. Unpublished study prepared by Springborn Labs., Inc. 6 p.

45710222 Douglas, M. (1992) An Assessment of the Effects of Chlorothalonil on the Reproduction of Daphnia magna: Lab Project Number: VCM 8(E)/920814. Unpublished study prepared by Huntingdon Research Centre Ltd. 65 p. {OPPTS 850.1500}

72-6 Aquatic org. accumulation

MRID Citation Reference

43070601 Kabler, K.; Quinn, B. (1993) Chlorothalon il: Bioconcentration Test with the Eastern Oyster, Crassostrea virginica, Under Flow-Through Conditions: Lab Project Number: J9205003. Unpublished study prepared by Toxikon Environmental Sciences. 68 p.

72-7 Simulated or Actual Field Testing

MRID Citation Reference

44286001 Ernst, W.; Doe, K.; Jonah, P. et al. (1991) Th e toxicity of chlorothalonil to aquatic fauna and the impact of its operational use on a pond ecosystem. Archives of Environmental Contamination and Toxicology 21:1-9.

44453501 Ernst, W.; Doe, K.; Jonah, P. et al. (1991) Th e toxicity of chlorothalonil to aquatic fauna and the impact of its operational use on a pond ecosystem. Archives of Environmental Contamination and Toxicology 21:1-9.

81-1 Acute oral toxicity in rats

MRID Citation Reference

11514 Perkins, C.T. (1975) Acute Oral Toxicity of DTX-75-0018 in Male and Female Albino Rats: Project Number: 27-216. (Unpublished study received Jan 27, 1976 under 677-EX-13; prepared by Bio/Tox Re- search Laboratories, Inc., submitted by Diamond Shamrock Agri- cultural Chemicals, Cleveland, Ohio; CDL:227752-D)

11515 Perkins, C.T. (1975) Acute Oral Toxicity of DTX-75-0019 in Male and Female Albino Rats: Project Number: 27-219. (Unpublished study received Jan 27, 1976 under 677-EX-13; prepared by Bio/Tox Labo- ratories, Inc., submitted by Diamond Shamrock Agricultural Chem- icals, Cleveland, Ohio; CDL:227752-H)

14430 Perkins, C.T. (1975) Acute Dermal Toxicity of DTX-75-0018 in Albino Rabbits: Project Number: 27-214. (Unpublished study received Ja n 27, 1976 under 677- EX-13; prepared by Bio/Tox Research Laboratories, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:227752-E)

14431 Perkins, C.T. (1975) Acute Eye Irritation of DTX-75-0018 in Albino Rabbits with and without Washing: Project Number: 27-215. (Un- publis hed study received Jan 27, 1976 under 677-EX-

### 111 13; prepared by Bio/Tox Research Laborator ies, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Clev eland, Ohio; CDL:227752-F)

14432 Perkins, C.T. (1975) Acute Dermal Toxicity of DTX-75-0019 in Albino Rabbits: Project Number: 27-217. (Unpublished study received Ja n 27, 1976 under 677- EX-13; prepared by Bio/Tox Research Labo- ratories, Inc., submi tted by Diamond Shamrock Agricultural Chemicals, Cleveland, Oh io; CDL:227752-I)

14433 Perkins, C.T. (1975) Acute Eye Irritation of DTX-75-0019 in Albino Rabbits with and without Washing: Project Number: 27-218. (Un- publis hed study received Jan 27, 1976 under 677-EX13; prepared by Bio/Tox Research Laborator ies, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Clev eland, Ohio; CDL:227752-J)

30353 Braun, W.G.; Rinehart, W.E. (1979) Acute Oral Toxicity Study in Rats: Project No. 5121-78. (Unpublished study including submit- ter su mmary, received Feb 19, 1980 under 677-313; prepared by Bio/dynamics, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099244-D)

30357 Braun, W.G.; Rinehart, W.E. (1978) Acute Oral Toxicity Study in Rats: Compound: T-118-1: Project No. 5124-78. (Unpublishe d study including submitter su mmary, received Feb 19, 1980 under 677-313; prepared by Bio/dynamics, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:099244-H)

38909 Doyle, R.L.; Elsea, J.R. (1963) Acute Oral, Dermal, and Eye Toxici- ty and Irritation Studies on DAC-2787: N-107. (Unpublished study received Fe b 25, 1976 under 6F1749; prepared by Hill Top Research Institute, Inc., submitted by Diamond Shamrock Agricul- tural Chemicals, Cleveland, Ohio; CDL:096457-A)

38910 Powers, M.B. (1965) Acute Oral Administration--Rats: Project No. 200-167. (Unpublished study received Feb 25, 1976 under 6F1749; prep ared by Hazleton Labora tories, Inc., submitted by Diamond Shamrock Agricultural Chemical s, Cleveland, Ohio; CDL: 096457-B)

38911 Paynter, O.E. (1965) Final Report: Oral Dose Range--Dogs: Project No. 200-168. (Unpublished study received Feb 25, 1976 under 6F1749; prep ared by Hazleton Labora tories, Inc., submitted by Diamond Shamrock Agricultural Chemical s, Cleveland, Ohio; CDL: 096457-C)

42447 Piccirillo, V.J.; Leatherwood, L.; Shopp, G. (1 979) Acute Oral Toxicity (LDI50^) Study in Rats with T-126-1: Proj ect No. 209-C. Final rept. (Unpublishe d study received Sep 2, 1980 under 2204- 17, prepared by Borriston Research Laboratories, Inc., submitted by Diamond Shamrock Corp., Morristown, N.J.; CDL:243157-C)

47937 Wazeter, F.X.; Golden thal, E.I.; Dean, W.P. (1971) Acute Or al LDI50^ in Male Albino Rats: IRDC No. 293-004. (Unpublished study received Dec 8, 1976 under 677-313; prepared by Interna- tional Research and Development Corp., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:095783-B)

47938 Hastings, T.F. (1973) AOLDI50^ in S-D Rats Using DAC-3701. (Unpub- lished study received Dec 8, 1976 under 677-313; prepared by Bio/ Tox Research Laboratories, Inc., submitted by Diamond Sham- rock Agricultural Chemicals, Cleveland, Ohio; CDL:095783-C)

47939 Wazeter, F.X.; Golden thal, E.I.; Dean, W.P. (1972) Acute Or al Tox- icity (LDI50^) in Beagle Dogs: IRDC No. 239-021. (Unpublished study including letter dated Oct 13, 1972 from E.I. Goldenthal to Milton Eisler, received Dec 8, 19 76 under 677-313; prepared by International Research and Development Corp., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL: 095783-D)

55020 Dean, W.P. (1976) Acute Oral Toxicity (LDI50^) Study in Male and Female Albino Rats: IRDC No. 293-050. (Unpublished study re- ceived Sep 23, 1976 under 6G1871; prepared by International Re- search and Development Corp., submitted by Diamond Shamrock Ag-

### 112 ricultural Chemicals, Clevel and, Ohio; CDL:095293-G)

61443 WARF Institute, Incorporated (1975) Re port: WARF No. 5010231. Summary of studies 228211-C through 22821 1-F. (Unpublished study receive d Jun 17, 1975 under 538-139; submitted by O.M. Scott & Sons Co., Marysville, Ohio; CDL:228211-B)

61444 WARF Institute, Incorporated (1975) Acute Oral Toxicity: WARF No. 5010231. (Unpublished study received Jun 17, 1975 unde r 538-139; submitted by O.M. Sc ott & Sons Co., Marysville, Ohio; CDL:228211-C)

70357 Chevron Chemical Company (1974) Summary: Toxicology for Ortho Liq- uid Lawn Disease Control (Chlorothalonil 2.88 Flowable). Sum- mary of studies 232607-B through 232607-L. (Unpublished study received Nov 23, 19 76 under 239-2432 ; CDL:232607-A)

70358 Rittenhouse, J.R.; Narcisse, J.K. (1974) The Acute Oral Toxicity of Daconil 2.88F to Adult

Male and Female Rats: SOCAL 571/XVIII:75 (S-669). (Unpublished study received Nov 23, 1976 under 239- 2432; submitted by Chevron Chemical Co., Richmond, Calif.; CDL:232607-B)

87306 Heenehan, P.R.; Braun, W.G.; Rinehart, W.E. (1977) Acute Oral Tox- icity Study: Project No. 4501-77. (Unpublished study, in cluding submitter summary, r eceived Oct 24, 1978 under 677- 315; prepared by Bio/dynamics, Inc., submitted by Diamond Shamrock Agricul- tural Chemicals, Cleveland, Ohio; CDL:235370-A)

87322 WARF Institute, Incorporated (1973) Report: WARF No. 3091600. (Un- published study received Feb 6, 1974 under 538-1 14; submitted by O.M. Scott & Sons Co., Marysville, Ohio; CDL:023130-D)

91284 Paynter, O.E. (1965) Final Report: Oral Dose Range--Dogs: Project No. 200-168. (Unpublished study received May 17, 1967 unde r 7F0599; prepared by Hazleton Laboratories, Inc., submitted by Diamond Alkali Co., Cleveland, Ohio; CDL:090769-B)

92411 Goldenthal, E.I.; Wazeter, F. X.; Dean, W.P. (1972) Acute Oral Toxicity (LDI50^) in Beagle Dogs: 293-021. (Unpublished study, including letter dated Oct 13, 1972 from E.I. Goldenthal to Milton Eisler, received on unknow n date under 2F1230; prepared by International Research and Development Corp., submitted by Diamond Shamrock Chemical Co ., Cleveland, Ohio; CDL:091081-B)

94728 Moreno, M.T.; Lundberg, D.; Killeen, J.C., Jr.; et al. (1980) Acute Oral (LD\50^) Toxicity Study in Rats with Nopcocide N-96: Docu- ment No. 103-5TX-79-0057-002; prepared in cooperation with MB Research Laboratories, Inc. Unpublished study; 13 p.

94941 Shults, S.K.; Killeen, J.C., Jr.; Ignatoski, J.A. (1981) Acute Oral Toxicity (LDI50^) Study in Rats with Technical Chlorothalonil: Document No. 296-5TX-80-0092-002. (Unpublished study received Feb 22, 1982 under 677-283; subm itted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:246843-C)

105964 Bottoms, J. (1981) Oral Toxicity--EPA 40 CFR 163.81-1 Proposed: ?Germain's Lawn and Garden Fungicide|: Laboratory No. 17480. (U npublished study received May 12, 1982 under 6993-61; pre- pared by Applied Biological Sciences Laboratory, submitted by Germain's, Inc., Los Angeles, CA; CDL:247763-A)

120333 Cannelongo, B.; Sabol, E.; Sabol, R. (1982) Rat Acute Oral Toxici- ty: Bravo 500/Sulphur 6 50:50 072382-A: Project No. 2 781-82. (Unpublished study r eceived Dec 9, 1982 under 5905- 472; pre- pared by Stillmeadow, Inc., submit ted by Helena Chemical Co., Memphis, TN; CDL:249039-A)

126494 Perkins, C.; Dickson, M. (1975) Acute Oral Toxicity of DTX-75-0018 in Male and Female Albino Rats: Project No. 27-216. (Unpub- lishe d study received Jan 27, 1976 under unknown admin. no.; prepared by Bio/Tox Research Laboratories, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Clevel and, OH; CDL: 249762-A)

### 113 126497 Perkins, C.; Dickson, M. (1975) Acute Oral Toxicity of DTX-75-0019 in Male and Female Albino Rats: Project No. 27-219. (Unpub- lishe d study received Jan 27, 1976 under unknown admin. no.; prepared by Bio/Tox Research Laboratories, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Clevel and, OH; CDL: 249762-D)

136963 Mastri, C. (1971) Report to ...: Acute Toxicity Studies with Dac- onil-Dexon 40-32, Seed

Protectant--7385-21: IBT No. A9 419. (Un- published study r eceived Feb 19, 1971 under 677- 311; prepared by Industrial Bio-Test Laboratories, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Clev eland, OH; CDL:004258-C)

137703 Dunn, G.; Guidi, L. (1981) Acute Oral Range Finding Determination Performed on 9660-1: Bioassay Systems Corp. Project No. 10656. (U npublished study received Feb 14, 1984 under 518-71; prepared by Bioassay Systems Corp ., submitted by Darworth, Inc., Avon, CT; CDL:252618-A)

137949 Penick Corp. (19??) Acute LD50 Values Were Determined for 3 Pesti- cides and the Synergist Sulfoxide. (Unpublished stu dy received Jan 15, 1973 unde r 432-502; CDL:003351-N)

141697 Major, D. (1983) Acute Oral Toxicity LD50 Study in Rats with Chlo- rothalonil 90 DG: Document No: 620-5TX-83-0019-002. Unpublished study prepared by Diamond Shamrock Corporation and Toxicol/Sisa, Inc. 49 p.

145529 Sabol, E. (1982) Rat Acute Oral Toxicity: Bravo 500/Sulphur 6 50:50 072382-A: Project No. 2781-82. Unpublished report prepared by Stillmeadow, Inc. 10 p.

147071 James, C. (1985) Acute Oral Toxicity (LD50) Study in Rats with Chlorothalonil + Copper + Maneb (WDG) Formulation: Report No: TEK/0018/P1105/0. Unpublished study prepared by Sisa Toxicolo- gical Laboratories, Inc. 83 p.

147868 Schiavo, D.; Breckenridge, C.; Grewen, J. (1985) Acute Oral Toxici- ty Study in Male & Female Rats [Ridomil/Bravo]: Report No. 295/84. Unpublished study prepared by Ciba-Geigy Corp. 28

p.

152530 Davis, T. (1985) Acute Oral Toxicity Screen [Olympic Semi-Transpa- rent Weather Screen]: Lab No. 59425. Unpublished study prepared by Mideco, Inc. 45 p.

154287 Shults, S. (1985) Acute Oral Toxicity (LD50) Study in Rats with Chlorothalonil + Oxadixyl (WDG) Formulation: Report Document No.: 738-5TX-85-0016-002. Unpublished study prepared by SDS Biotech Corp. and SISA Toxicological Laboratories, Inc. 49 p.

160358 Levitz, E. (1985) Acute Oral Toxicity Study in Rats: Test Mate- rial: Chlorothalonil 90DF: Project No. 5969-85. Unpublished study prepared by Bio/dynamics Inc. 9 p.

162383 Savides, M. (1986) Identification of Metabolites in Urine and Blood following Oral Administration of [Carbon 14]-Chlorothanolin ([Carbon 14]-SDS-2787) Male Rats: II. Effects of Multiple Dose Administration on the Excretion of Thiol Metabolites in Urine Excretion of Thiol Metabolites in Urine: Report/SDS-2 787: Docu- ment No. 621-4AM-83-0061-002. Unpublished study prepared by SDS Biotech Corp. 72 p.

40243702 Ford, W.; Killeen, J. (1987) A 90-day Feeding Study in Rats with Chlorothalonil: Supplemental Data: Document No.: 1115-85-0079- TX-006; Project ID: 293-144. Unpublished study prepared by Ricerca, Inc. in cooperation with International Research and Development Corp.; Experimental Pathology Laboratories, Inc.; and Laboratoire d'histopathologie, C.E.R.T.I. 464 p.

40405102 Gabriel, D. (1987) Consyst Turf Fungicide - Acute Oral Toxicity, Single Level - Rats: Proj. No. 87-5495A. Unpublished study pre- pared by Biosearch Inc. 8 p.

40459605 Reagan, E. (1987) Acute Oral Toxicity Study of Flexgard III in Sp- rague Dawley Rats: Lab. Proj. ID 9537-A. Unpublished study pre- pared by Food & Drug Research Laboratories, Inc. 35

p.

### 114 40461002 Siglin, J. (1987) Acute Oral Toxicity Study of Ole' K in Rats: Lim- it Test (EPA): SLS Study No. 3159.10. Unpublished study pre- pared by Springborn Life Sciences, Inc. 25 p.

40461003 Siglin, J. (1987) Acute Oral Toxicity Study of Ole' K in Rats: LD50 Test (EPA): SLS Study No. 3159.23. Unpublished study prepared by Springborn Life Sciences, Inc. 85 p.

40509901 Siglin, J. (1987) Acute Oral Toxicity Study of Flowable Chloro- thalonil in Rats (EPA): Study No. 3159.5.1. Unpublished study prepared by Spring born Institute for Bior esearch, Inc. 25 p.

40703904 Kuhn, J. (1988) Acute Oral Toxicity Study in Rats: Lesco Two-Some Flowable Fungicide: Proj. No. 5339-88. Unpublished study pre- pared by Stillmeadow, Inc. 19 p.

40956504 Myers, R.; Christopher, S. (1988) Woolsey Lumaguard Anti-fouling Finish 680 Blue: Acute Toxicity and Primary Irritation Studies: Laboratory Project ID: 51-594. Unpublished compilation prepared by Union Carbide, Bushy Run Research Center. 25 p.

41206011 Shults, S.; Wilson, N.; Killeen, J. (1989) Acute Oral Toxicity (LD50) Study in Rats with Tuffcide 500: Project ID: 88-0051; Document No. 3034-88-0051-TX-001. Unpublished study prepared by Ricerca, Inc. 37 p.

41564801 Shults, S.; Long, M.; Wilson, N. (1985) Ac ute Oral Toxicity Screen- ing in Rats with SDS46851: Lab Project Number: 684-5TX-84-0033- 001. Unpublished study prepared by SDS Biotech Corp. 31 p.

41756602 Kuhn, J. (1990) Acute Oral Toxicity Study in Rats: Chlorothalonil 6L: Lab Project Number: 7098-90. Unpublished study prepared by Stillmeadow, Inc. 11 p.

41822103 Shults, S.; Brock, A.; Kileen, J. (1990) Ac ute Oral Toxicity (LD50) Study in Rats with ASC66779-0101-0701: Lab Project Number: 2051 -89-0376-TX-001: 89-0376. Unpublished study prepared by Ricerca , Inc. 37 p.

41978401 Robbins, G. (1991) Acute Oral Toxicity in Rats: Funginil Lawn and Garden Fungicide: Lab Project Number: A3159. Unpublished study prep ared by Cosmopolitan Safety Evaluation, Inc. 19 p.

42148514 Shults, S.; Brock, A.; Killeen, J. (1991) Acute Oral Toxicity Study in Rats with ASC-66518- 0101-1203: Lab Project Number: 3780-91-0030-TX-001: 91-0030. Unpublished study prepared by Ricerca, Inc. 21 p.

42325604 Shults, S.; Brock, A.; Killeen, J. (1990) Ac ute Oral Toxicity (LD50) Study in Rats with ASC66792-X-0104: Lab Project Number: 90-0170. Unpublished study prepared by Ricerca, Inc. 47

p.

42493401 Cerven, D. (1991) Single Dose Oral Toxicity in Rats/LD 50 in Rats: Compound SO-1 Chlorothalonil 75 W D G Lab Project Number: MB 91-778 A. Unpublished study prepared by MB Research Laboratories Inc. 29 p.

42552504 Cerven, D. (1992) Single Dose Oral Toxicity in Rats/LD50 in Rats: SO-2, Chlorothalonil Flowable 40.8%: Lab Project Number: MB 91-924 A. Unpublished study prepared by MB Research Labs, Inc. 24 p.

42670002 Gabriel, D. (1992) Acute Oral Toxicity, Two Levels--Rats: ConSyst (chlorothalonil and thiophanate methyl): Lab Project Number: 92-7558A. Unpublished study prepared by Biosearch Inc. 15 p.

42683101 Kuhn, J. (1992) Acute Oral Toxicity Study in Rats: Chlorothalonil 4L, Flowable Agricultural Fungicide: Lab Project Number: 9401-92. Unpublishe d study prepared by Stillmeadow, Inc. 20

p.

42789404 Shults, S.; Brock, A.; Killeen, J. (1991) Ac ute Oral Toxicity (LD50) Study in Rats with ASC64216-0101-0301: Lab Project Number: 91-0025: 3779-91-0025-TX-001. Unpublished study

### 115 prepared by Ricerca, Inc. 37 p.

42864801 Kukulinski, M. (1993) Acute Oral Toxicity Study: Yard Guard: Final Report: Lab Project Number: 93-98-1. Unpublished study prepared by Tox Monitor Labs, Inc. 9 p.

42871701 Kuhn, J. (1993) Acute Oral Toxicity Study in Rats: Chlorothalonil Flowable 720: Lab Project Number: 9895-93. Unpublished study prep ared by Stillmeadow, Inc. 18 p.

42976104 Kuhn, J. (1993) Acute Oral toxicity Study in Rats: Export (ASC-67097): Lab Project Number: 9055-92. Unpublished study prepared by Stillmeadow, Inc. 24 p.

42979104 Parcell, B.; McRae, L. (1993) Acute Oral Toxicity to the Rat of SR2040 (Proposed ACTICIDE PM) (Diuron, Chlorothalonil): Lab Project Number: THR 24/930085/AC. Unpublished study prepared by Huntingdon Research Centre Ltd. 19 p.

43041202 Kuhn, J. (1993) Acute Oral Toxicity Study in Rats: Dragon Rose and Flower Dust: Lab Project Number: 0394-93. Unpublished study prepared by STILLMEADOW, Inc. 21 p.

43142005 Gabriel, D. (1992) Acute Oral Toxicity, LD-Rats: ConSyst 4FL: Lab Project Number: 92/7571A. Unpublished study prepared by Biosearch Inc. 23 p.

43520202 Wnorowski, G. (1994) Acute Oral Toxicity Limit Test (in Rats): Chlorothalonil 90D: Lab Project Number: 3135: P320. Unpublished study prepared by Product Safety Labs. 16 p.

43594004 Shults, S.; Brock, A.; Laveglia, J. (1994) ASC 66783: Acute Oral Toxicity (LD50) Study in Rats With Chlorothalonil Plus Flutolanil (ASC 66783-0201-0202): Lab Project Number: 5933-93- 0350-TX-001. Unpublished study prepared by Ricerca, Inc. 42 p.

43622601 Wnorowski, G. (1995) Acute Oral Toxicity Defined LD50 (in Rats): Chlorothalonil & Sulphur Fungicide: Lab Project Number: 3453: P320. Unpublished study prepared by Product Safety Labs. 26 p.

43646603 Shults, S.; Brock, A.; Laveglia, J. (1992) Acute Oral Toxicity (LD50) Study in Rats with ASC 67114-0101-0101: Lab Project Number: ASC-67114-0101-0101: 1081-92-0237-AS-001: 5323- 92-0201-TX-001. Unpublished study prepared by Ricerca, Inc. 56 p.

43678401 Kuhn, J. (1992) Acute Oral Toxicity Study in Rats: Chlorothalonil Technical: Lab Project Number: 9374-92. Unpublished study prep ared by Stillmeadow, Inc. 12 p.

43793301 McRae, L. (1995) SR 2040 (Acticide PM): Acute Oral Toxicity to the Rat: Lab Project Number: THR/33: THR/33/951611/AC. Unpublished study prepared by Huntingdon Research Centre Ltd. 16 p.

43800324 Kuhn, J. (1995) Acute Oral Toxicity Study in Rats: CGA-32951/CT 76.5 WP: Final Report: Lab Project Number: 2014-95. Unpublished study prepared by Stillmeadow, Inc. 39 p.

43809202 Wnorowski, G. (1995) Acute Oral Toxicity Defined LD50 (in Rats): Terranil & Copper: Lab Project Number: 3815: P320. Unpublished study prepared by Product Safety Labs. 27 p.

44044204 Shults, S.; Brock, A.; Laveglia, J. (1995) Acute Oral Toxicity (LD50) Study in Rats with Dacobre (ASC-67213-0101-0101): Lab Project Number: 6275-94-0208-TX-002: 94-0208: 6275-94-0208-TX-001. Unpublished study prepared by Ricerca, Inc. 88 p.

44064601 Denton, S. (1992) T81 Propamocarb-HCL: Rat Acute Oral Toxicity Study: Lab Project Number: 920530D/SMS 411/AC: TOX/92/186-19: TOX 92156. Unpublished study prepared by Huntingdon Research Centre Ltd. 23 p.

44071104 Wnorowski, G. (1995) Acute Oral Toxicity Defined LD50 (in Rats): BP-1007: Lab Project Number: 3421: P320. Unpublished study prepared by Product Safety Labs. 28 p.

44079802 Glaza, S. (1996) Acute Oral Toxicity Study of EXP- 10673A in Rats: Final Report: Lab Project

### 116 Number: CHW 50302780: TP3013R: 50302780. Unpublished study prepared by Corning Hazleton Inc. 40 p.

44412201 Bomann, W. (1993) Study on the Acute Oral Toxicity in Rats: Tebuconazole and Chlorothalonile: Lab Project Number: 22696: T 5044160. Unpublished study prepared by Bayer Ag. 40 p.

44420401 Kuhn, J. (1997) Acute Oral Toxicity in Rats: NeXgen: Lab Project Number: 3580-97: S9-FF81- 1. Unpublished study prepared by Stillmeadow, Inc. 21 p.

44993203 Wnorowski, G. (1999) Acute Oral Toxicity Study in Rats--Limit Test: GX-611001E: Lab Project Number: 7703: P320. Unpublished study prepared by Product Safety Labs. 17 p. {OPPTS 870.1100}

45038501 Moore, G. (1999) Acute Oral Toxicity Study in Rats: Spectro 90 WDG: Lab Project Number: 8116: P320. Unpublished study prepared by Product Safety Labs. 20 p. {OPPTS 870.1100}

45049103 Moore, G. (2000) Acute Oral Toxicity Study in Rats--Limit Test: GX-612/Equus DF: Lab Project Number: 8136: P320. Unpublished study prepared by Product Safety Labs. 15 p. {OPPTS 870.1100}

45077801 Kuhn, J. (1998) Acute Oral Toxicity Study in Rats: IBC 4A: Final Report: Lab Project Number: 3852-97. Unpublished study prepared by Stillmeadow, Inc. 20 p.

45077802 Kuhn, J. (1997) Acute Oral Toxicity Study in Rats: IBC 4B: Final Report: Lab Project Number: 3853-97. Unpublished study prepared by Stillmeadow, Inc. 22 p.

45077803 Kuhn, J. (1998) Acute Oral Toxicity Study in Rats: IBC 4C: Final Report: Lab Project Number: 3854-97. Unpublished study prepared by Stillmeadow, Inc. 18 p.

45077804 Kuhn, J. (1998) Acute Oral Toxicity Study in Rats: IBC 4D: Final Report: Lab Project Number: 3855-97. Unpublished study prepared by Stillmeadow, Inc. 18 p.

45082801 Auletta, C. (1985) Acute Oral Toxicity: Terranil 90DF (in Rats): Lab Project Number: 5971-85. Unpublished study prepared by Bio/dynamics, Inc. 11 p. {OPPTS 870.1100}

45105603 Merkel, D. (2000) Acute Oral Toxicity in Rats--Limit Test of Cuprinol Siding & Stain Preservative: Lab Project Number: 8749: P320. Unpublished study prepared by Product Safety Labs., Inc. 14 p. {OPPTS 870.1100}

45105604 Merkel, D. (2000) Acute Oral Toxicity in Rats--Limit Test of Cuprinol Siding & Stain Preservative: Lab Project Number: 8755: P320. Unpublished study prepared by Product Safety Labs., Inc. 14 p. {OPPTS 870.1100}

45134401 Moore, G. (2000) Acute Oral Toxicity Stu dy in Rats--Limit Test: Allpro Exotherm Termil: Lab Project Number: 8915. Unpublished study prepared by Product Safety Labs. 15 p. {OPPTS 870.1100}

45162202 Kuhn, J. (2000) Acute Oral Toxicity Study in Rats: Chlorothalonil 51% Flowable: Final Report: Lab Project Number: 5836-00. Unpublished study prepared by Stillmeadow, Inc. 11 p. {OPPTS 870.1100}

45163901 Moore, G. (2000) Acute Oral Toxicity Study in Rats: (Chlorothalonil): Lab Project Number: PSL-8730: P320.ZEN.CHLORO. Unpublished study prepared by Product Safety Labs. 21 p. {OPPTS 870.1100}

45339801 Merkel, D. (2001) Acute Oral Toxicity Stu dy in Rats-Limit Test: Bio-Flex: Lab Project Number: 10003: P320. Unpublished study prepared by Product Safety Labs. 14 p. {OPPTS 870.1100}

45464702 Merkel, D. (2001) Acute Oral Toxicity Study in Rats-- Limit Test: Intace B- 6773: Lab Project Number: 10552. Unpublished study prepared by Product Safety Labs. 16 p. {OPPTS 870.1100}

### 117 45507302 Freemantle, M. (2001) BP 1040: Acute Oral To xicity Study in the Rat: Final Report: Lab Project Number: 1803/16-D6144. Unpublished study prepared by Covance Laboratories Ltd. 31 p. {OPPTS 870.1100}

45559703 Moore, G. (2001) Acute Oral Toxicity Study in Rats--Limit Test: Taratek 5F: Lab Project Number: 10601: P320. Unpublished study prepared by Product Safety Labs. 15 p. {OPPTS 870.1100}

45606004 Kuhn, J. (2001) Acute Oral Toxicity Study in Rats: Echo Home Garden Fungicide & Insecticide: Final Report: Lab Project Number: 6401-01. Unpu blished study prepared by Stillmeadow, Inc. 14 p. {OPPTS 870.1100}

45710203 Cummins, H. (1988) Chlorothalonil Technical: Acute Oral Toxicity Study in the Rat: Lab Project Number: 88/CFA002/276. Unpublished study prepared by Life Science Research. 19 p. {OPPTS 870.1100}

83-4 2-generation repro.-rat

MRID Citation Reference

38912 Paynter, O.E. (1966) Reproduction--Rabbits: DAC 2787: Project No. 200-176. (Unpublished study received Feb 25, 1976 under 6F1749; prep ared by Hazleton Labora tories, Inc., submitted by Diamond Shamrock Agricultural Chemic als, Cleveland, Oh io; CDL:096457-D)

38913 Paynter, O.E.; Kundzin, M.; Crews, L.M. (1 967) Final Report: Three- Generation Reproduction Study--Rats: Project No. 200-150. (Un- published study received Feb 25, 1976 under 6F1749; prepared by Hazleton Laboratories, Inc., submitted by Diamond Shamrock Agri- cultural Chemicals, Cleveland, Ohio; CDL:096457-E)

38914 Paynter, O.E.; Kundzin, M. (1967) Final Report: Three-Generation Reproduction Study--Rats: Project No. 200-155. (Unpublished study received Feb 25, 1976 under 6F1749; prepared by Hazleton Laboratories, Inc. , submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:096457-F)

42095 Budny, J.A. (1976) Letter sent to E.M. Wilson dated Dec 2, 1976 ?Points of clarification on Bravo 6F in response to phone con- versations 11/23/76 and 11/24/76 between Dr. Coberly (EPA) and Dr. Budny (Diamond Shamrock)|. (U npublished study receive d Dec 8, 1976 under 677-313; submitted by Diamond Shamrock Agri- cultural Chemicals, Cleveland, Ohio; CDL:095783-E)

47946 Hastings, T.F.; Ferrell, J.F. (1975) 3-Genera tion Reproduction Study in Albino Rats: Dac-3701: Study No. 24-051A. Final rept . (Unpublished study including submitter summary, received Dec 8, 1976 under 677-313; prepared by Bio/Tox Research Laboratories, Inc. and Experimental Pathology Laboratories, Inc., submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL: 095783-M)

87283 Diamond Shamrock Chemical Company (19??) Litter Observations in 3-generation Rat Reproduction Study--Daco nil. (Unpublished study receive d Aug 11, 1970 under 1F1024; CDL:093333-C)

91288 Paynter, O.E.; Kundzin, M. (1967) Final Report: Three-generation Reproduction Study--Rats: Project No. 200-150. (Unpublished study received May 17, 1967 under 7F0599; prepared by Hazleton Laboratories, Inc., submitted by Diamond Alkali Co., Cleveland, Ohio; CDL:090769- K)

91289 Paynter, O.E.; Kundzin, M. (1967) Final Report: Three-generation Reproduction Study--Rats: Project No. 200-155. (Unpublished study received May 17, 1967 under 7F0599; prepared by Hazleton Laboratories, Inc., submitted by Diamond Alkali Co., Cleveland, Ohio; CDL:090769-

### 118 L)

112736 Paynter, O. (1965) Progress Report: Three-generation Reproduction Study--Rats: ?Dac-2787|: Project No. 200-150. (Unpublished study received Oct 20, 1965 under 7G0516; prepared by Hazleton Laboratories, Inc., submitted by Diamond Alkali Co., Cleveland, OH; CDL:090609-H)

127844 Ford, W.; Killeen, J.; Ignatoski, J.; et al. (1981) A Three Gen- eration Reproduction Study in Rats with DS-3701. (Unpub- lished study received Apr 21, 1983 under 677-313; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH; CDL: 071524-E)

127845 Ford, W.; Bush, M.; Killeen, J.; et al. (1982) A One-generation Reproduction Study in Rats with DS-3701: Document No. 529-5TX- 81-0193-002. (Unpublished study received Apr 21, 1983 under 677-313; submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH; CDL:071525-E)

131200 Killeen, J.; Ford, W.; Ignatoski, J.; et al. (1981) A Three Genera- tion Reproduction Study in

Rats with DS-3701: Document No. 107- 5TX-78-0023- 002. (Unpublished study received Oct 3, 1983 under 3F2875; prepared by Diamond Shamrock Agricultural Chemicals, submitted by SDS Biotech Corp., Painesville, OH; CDL:071976-A)

140849 Hastings, T.; Stemmer, K.; Fe rrell, J. (1974) 3-Generation Repro- duction Study in Albino Rats Using DAC-3701 in the Diet: Pr oject No. 24-051. Final rept. (Unpublished study received Jul 31, 1974 under 2F1230; prepared by Bio/T ox Research Laboratories, Inc., submitted by Diamond Shamrock Chemical Co., Cleveland, OH; CDL:097942-A)

146938 Ford, W.; Killeen, J.; Ignato ski, J. (1985) Histopathology Evalua- tion--A Three Generation Reproduction Study in Rats with SDS- 3701: Report No. 107-5TX-78-0023-102. Unpublished study pre- pared by SDS Biotech Corp. 257 p.

41706201 Lucas, F.; Benz, G. (1990) A Two Generation Reproduction Study in Rats with Technical Chlorothalonil: Lab Project Number: 87-0121: 1722-87-0121-TX-003. Unpublished study prepared by Ricerca, Inc., and Experimental Pathology Labs, Inc. 1673 p.

45710209 Myers, D. (1995) Chlorothalonil: A Study of the Effect on Reproductive Function of Two Generations in the Rat: Lab Project Number: VCM 21/942505. Unpublished study prepared by Huntingdon Research Centre Ltd. 402 p. {OPPTS 870.3800}

121-1 Phytotoxicity

MRID Citation Reference

8144 Bear, W.H. (1973) La nnate L--Celery. (Unpub lished study received Mar 5, 1974 under 352-342; prepared in cooperation with A. Duda & Sons, submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.; CDL:023293-G)

9563 Kantzes, J.G.; Weaver, L.O. (1964) Results of Tomato Fungicide Tests--1964. (Unpublished study received May 29, 1970 unde r 0F0923; prepared by Univ. of Maryland, Dept. of Botany, submit- ted by Uniroyal Chemical, Bethany, Conn.; CDL:091577-Q)

9943 Smith, D.H.; Crosby, F.D. (1968) Peanuts: Leafspot:~Cercospora~ ?~arachidicola?~. (Unpublished study received Feb 26, 1969 un- de r 3238-42; prepared by Univ. of Georgia, Georgia Station in cooperation with ESSA-W eather Bureau, Georgia Station, submitted by Agrico Chemical Co., Tuls a, Okla.; CDL:220181-A)

13021 Nor-Am Agricultural Products, Incorporated (1963) Nematocides-- Fungicide Trials. (Unpublished study receive d on unknown date under 2139-76; CDL: 025254-H)

22056 Smith, D.H. (1969) 1969 Peanut Leafspot Fungicide Test--Plains, Georgia. (Unpublished study including letter dated Oct 24, 1969 from D.H. Sm ith to Sidney Fox, received Dec 9, 1969 under 400- EX-37; prepared by Univ. of Georgia, De pt. of Plant Pathology, Georgia Station, submitted

### 119 by Uniroyal Chemical, Bethany, Conn.; CDL:123444-H)

30230 R.T. Vanderbilt Company, Incorporated (1970) Leaf Spot Test 1--1970 (Miscellaneous Chemicals Test). (Unpublished study received May 6, 1971 under 1 965-66; CDL:025216-A)

30715 Simone, ?; Jackson, ?; Couch, ?; et al. (1978) Results from Tersan 1991 & Daconil Alone & in Combination on Turfgrass. (Unpub - lished study received Feb 29, 1980 under 352-3 57; prepared in cooperation with Univ. of Illinois and others, submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.; CDL:241974-A)

38737 Green Light Company (1959) A Test of Bore r Killer Phytotoxicity to Young Cottonwood Trees: Test No. 3. (Unpublished study in clud- ing test no. 2, received Jul 29, 1968 under 869-40; CDL: 236701-A)

87373 Alvarez, A. (1975) Letter sent to John Hylin dated Oct 17, 1975: Bravo 6F, efficacy and phytotoxicity data. (Unpublished study received Mar 15, 1976 under 6E1761; prepared by Univ. of Hawaii, Dept. of Plant Pathology, submitted by Interregional Research Project No. 4, New Brunswick, NJ; CDL:097359-B)

97624 Diamond Shamrock Agricultural Chemicals (1976) Results of 1976 Bravo 6F Experimental Use Permit on Citrus. (Compilation; un- published st udy received Sep 14, 1977 under 677-EX-9; CDL: 233159-A)

136952 Diamond Shamrock Agricultural Chemical s (1966) ?Efficacy: DAC2787 and Others|. (Compilation; unpublished study received Apr 25, 1967 under 677 -282; CDL: 004248-A)

136972 Diamond Shamrock Agricultural Chemicals (1 971) ?Efficacy of Bravo 6F|. (Compilation; unpublished study received Nov 16, 1971 under 677-313 ; CDL:004260-B)

147022 SDS Biotech Corp. (1984) [Bravo 500: Control of Anthracnose on To- matoes]. Unpublished compilation. 68 p.

122-1 Seed Germination/S eedline Emergence and Vegetable Vigor

MRID Citation Reference

159006 Kahlon, P.; Banerjee, M. (1979) Evaluation of bravo, phosdrin and telvar as possible environmental mutagens. Bull. Environm. Contam. Toxicol. 22:365-370.

42433808 Backus, P. (1992) Effect of Chlorothalonil on Seed Germination/Seedling Emergence (Tier I): Lab Project Number: 92-0119: 5234-92-0119-BE-001. Unpublished study prepared by Ricerca, Inc. 63 p.

42433809 Backus, P. (1992) Effect of Chlorothalonil on Vegetative Vigor of Plants (TIer I): Lab Project Number: 92-0120: 5234-92-0120-BE-001. Unpublished study prepared by Ricerca, Inc. 50 p.

123-2 Aquatic plant growth

MRID Citation Reference

42432801 Hughes, J.; Williams, T. (1992) The Toxicity of Technical Chlorothalonil Fungicide to Selenaestrum capricornutum: Lab Project Number: B038-001-1. Unpublished study prepared by Malcolm Pirnie, Inc. 37 p.

44908102 Smyth, D.; Magor, S.; Shillabeer, N. (1998) Chlorothalonil: Toxicity to Duckweed: Lab Project Number: BL6473/B: AF0336/A: WINO 41417. Unpublished study prepared by Brixham Environmental Laboratory, Zeneca Limited. 24 p.

44908103 Smyth, D.; Magor, S.; Shillabeer, N. (1 998) Chlorothalonil: Toxicity to Marine Alga: Skeletonema costatum: Lab Project Number: BL6422/B: AF0302/C: WINO 41416. Unpublished

### 120 study prepared by Brixham Environmenta l Laboratory, Zeneca Limited. 25 p.

44908104 Smyth, D.; Magor, S.; Shillabeer, N. (1998) Chlorothalonil: Toxicity to Marine Alga: Anabaena flos-aquae: Lab Project Number: BL6413/B: AF0302/A: WINO 41414. Unpublished study prepared by Brixham Environmental Laboratory, Zeneca Limited. 26 p.

44908105 Smyth, D.; Magor, S.; Shillabeer, N. (1998) Chlorothalonil: Toxicity to Freshwater Diatom: Navicula pelliculosa: Lab Project Number: BL 6423/B: AF0302/B: WINO 41415. Unpublished study prepared by Brixham Environmenta l Laboratory, Zeneca Limited. 24 p.

165-4 Bioaccumulation in fish

MRID Citation Reference

45710224 McEwen, A. (1997) Chlorothalonil Bioaccumulation in Rainbow Trout: Lab Project Number: VCM 67/963833: VCM/67. Unpublished study prepared by Huntingdon Life Sciences Ltd. 86 p.

165-5 Bioaccu m-aquatic non-target

MRID Citation Reference

44286001 Ernst, W.; Doe, K.; Jonah, P. et al. (1991) Th e toxicity of chlorothalonil to aquatic fauna and the impact of its operational use on a pond ecosystem. Archives of Environmental Contamination and Toxicology 21:1-9.

850.1010 Aquatic invertebrate acute toxicity, test, freshwater daphnids

MRID Citation Reference

47737324 Gallagher, S.; Kendall, T.; Krueger, H. (2009) Chlorothalonil/Penthiopyrad (DPX-QFA61) SC (250 g/L:100 g/L): A 48-Hour Static Acute Toxicity Test with the Cladoceran (Daphnia magna). Project Number: DUPONT/25538, DUPONT/25538/OCR, 112A/252. Unpublished study prepared by Wildlife International, Ltd. 52 p.

850.1075 Fish acute toxicity test, freshwater and marine

MRID Citation Reference

47737323 Gallagher, S.; Kendall, T.; Krueger, H. (2009) Chlorothalonil/Penthiopyrad (DPX-QFA61) SC (250 g/L:100 g/L): A 96-Hour Static Acute Toxicity Test with the Rainbow Trout (Oncorhynchus mykiss). Project Number: DUPONT/25536, DUPONT/25536/OCR, 112A/253. Unpublished study prepared by Wild life International, Ltd. 51 p.

48513701 Brain, R.; Perkins, D.; Bang, J.; et al. (2011) Chlorothalonil Preliminary Response to the National Marine Fisheries Service Revised Draft Biological Opinion Concerning Chlorothalonil of May 13, 2011: Final Report. Project Number: TK0061921. Unpublished study prepared by Syngenta Crop Protection. 25 p.

850.1950 Field testing for aquatic organisms

MRID Citation Reference

46047304 Ashwell, J.; Grant, R.; Dark, R.; et. al. (2002 ) Outdoor Microcosm Study to Assess the Effect of Chlorothalonil on Aquatic Oranisms: Final Report. Project Number: RJ3261B, 00JH010. Unpublished study prepared by Syngenta Jealotts Hill International. 923 p.

850.2100 Avian acute oral toxicity test

MRID Citation Reference

### 121 46998703 Roy, B. (2006) Acute Oral Toxicity Study of Banko 720 SC in Rats. Project Number: 5138. Unpublished study prepared by Jai Research Foundation. 37 p.

850.3020 Honey bee acute contact toxicity

MRID Citation Reference

47737326 Jeyalakshmi, T. (2009) Chlorothalonil/P enthiopyrad (DPX-QFA61) SC (250 g/L:100 g/L): Acute Oral and Contact Toxicity to the Ho ney Bee, Apis mellifer a L.. Project Number: DUPONT/24930, DUPONT/24930/OCR, 08279. Unpublished study prepared by International Institute of Biotechnology and Toxicology . 37 p.

850.5400 Algal toxicity, Tiers 1 and II

MRID Citation Reference

47737325 Porch, J.; Kendall, T.; Krueger, H. (2009 ) Chlorothalonil/Penthiopyrad (DPX-QFA61) SC (250 g/L:100 g/L): A 72-Hour Toxicity Test with the Freshwater Alga (Pseudokirchneriella subcapitata). Project Number: DUPONT/25534, DUPONT/25534/OCR, 112A/249. Unpublished study prepared by Wildlife International, Ltd. 62 p.

870.1000 Acute toxicity testing--background

MRID Citation Reference

46230803 Longobardi, C. (2001) Acute Oral Toxicity Study in the Rat: Nuocide 2002. Project Number: 8045/005, 8045/005/T/340/2001. Unpublished study prepared by Research Toxicology Centre, S.p.A. 67 p.

46230804 Longobardi, C. (2001) Acute Dermal Toxicity Study in the Rat: Nuocide 2002. Project Number: 8046/005, 8046/005/T/323/2000. Unpublished study prepared by Research Toxicology Centre, S.p.A. 24 p.

46230806 Longobardi, C. (2001) Acute Eye Irritation in the Rabbit: Nuocide 2002. Project Number: 8049/005, 8049/005/T/379/2000. Unpublished study prepared by Research Toxicology Centre, S.p.A. 24 p.

46230807 Longobardi, C. (2001) Acute Dermal Irritation Study in the Rabbit: Nuocide 2002. Project Number: 8048/005, 8048/005/T/332/2000. Unpublished study prepared by Research Toxicology Centre, S.p.A. 23 p.

46230808 Longobardi, C. (2001) Delayed Dermal Sensitisation Study in the Guinea Pig (Buehler Method): Nuocide 2002. Project Number: 8050/005, 8050/005/T/159/2001. Unpublished study prepared by Research Toxicology Centre, S.p.A. 26 p.

47365002 Orr, G. (2008) Bridging Statement Concerning Applicability of Existing of Acute Toxicity Studies to Pegasus DFX. Project Number: PEC/007/T. Unpublished study prepared by Rivendell Consulting USA, LLC. 6 p.

870.1100 Acute oral toxicity

MRID Citation Reference

45843603 Merkel, D. (2002) Acute Oral Toxicity Study in Rats: Azoxystrobin/Chlorothalonil 660 SC-A: Final Report: Lab Project Number: 12496: 1829-02: P320 UDP. Unpublished study prepared by Product Safety Labs. 18 p.

46079703 Merkel, D. (2003) Acute Oral Toxicity Up and Down Procedure in Rats: Propiconazole(CGA64250)/Chlorothalonil SE: Final Report. Project Number: 12966, 1836/02, P320/UDP.

### 122 Unpublished study prepared by Product Safety Labs, Food Products Laboratory and Silliker Laboratories of New Jersey, Inc. 16 p.

46230803 Longobardi, C. (2001) Acute Oral Toxicity Study in the Rat: Nuocide 2002. Project Number: 8045/005, 8045/005/T/340/2001. Unpublished study prepared by Research Toxicology Centre, S.p.A. 67 p.

46231303 Longobardi, C. (2001) Nuocide 2010: Acute Oral Toxicity Study in the Rat. Project Number: 8045/006, 8045/006/T/350/2001. Unpublished study prepared by Research Toxicology Centre, S.p.A. and Creanova Inc. 65 p.

46328501 Moore, G. (2004) Acute Oral Toxicity Up And Down Procedure in Rats: NAI-301 4SE. Project Number: 15144, P320/UDP. Unpublished study prepared by Product Safety Labs. 15 p.

46387403 Kuhn, J. (2004) Metalaxyl-M (Mefenoxam)/Chlorothalonil SC (040/400) (A13842C): Acute Oral Toxicity Study in Rats: Final Report. Project Number: 8188/04, T006822/04. Unpublished study prepared by Stillmeadow, Inc. 13 p.

46440703 Moore, G. (2004) AND4251: Acute Oral Toxicity Up and Down Procedure in Rats. Project Number: 15720, P320/UDP. Unpublished study prepared by Product Safety Labs. 14 p.

46502803 Merkel, D. (2005) Acute Oral Toxicity Up and Down Procedure in Rats with Propiconazole/Fludioxonil/Chlorothalonil SE: Final Report. Project Number: 16351, T001009/04, P320/UDP. Unpublished study prepared by Product Safety Laboratories. 17 p.

46946304 Durando, J. (2006) Acute Oral Toxicity Up and Down Procedure in Rats: CTN G-Pro 720. Project Number: 19410, P320/UDP. Unpublished study prepared by Product Safety Laboratories. 17 p.

47061003 Merkel, D. (2004) NOA 446510/Chlorothalonil SC (040/400) (A-13985A): Acute Oral Toxicity Up and Down Procedure in Rats: Final Report. Project Number: 14728, T003560/03, P320. Unpublished study prepared by Product Safety Laboratories. 17 p.

47294603 Durando, J. (2007) Disarm C Fungicide: Acute Oral Toxicity Up and Down Procedure in Rats. Project Number: 23060, P320/UDP. Unpublished study prepared by Product Safety Laboratories. 17 p.

47333105 Merkel, D. (2004) Acute Oral Toxicity Up and Down Procedure in Rats: LBG-G31FCL. Project Number: 14968, P320/UDP. Unpublished study prepared by Product Safety Laboratories. 15 p.

47405203 Durando, J. (2007) Azoxystrobin/Chlorothalonil SC (038.7/580) (A15935A) - Acute Oral Toxicity Up-and-Down Procedure in Rats: Final Report. Project Number: 22325, T008672/06. Unpublished study prepared by Product Safety Laboratories. 17 p.

47409003 Durando, J. (2008) Acute Oral Toxicity Up and Down Procedure in Rats: Chlorothalonil 82.5 WDG. Project Number: P320/UDP, 24306, 080212/4H. Unpublished study prepared by Product Safety Laboratories. 15 p.

47457903 Moore, G. (2008) Acute Oral Toxicity Up and Down Procedure in Rats: 39.95% Chlorthalonil + 4.99% Triticonazole SC. Project Number: P320/UDP, 24844, 080411/8D. Unpublished study prepared by Eurofins Product Safety Laboratories. 14 p.

47734803 Kuhn, J. (2009) Antiblu MC-30: Acute Oral Toxicity (UDP) in Rats: Final Report. Project Number: 12301/08. Unpublished study prepared by Stillmeadow, Inc. 15 p.

47737316 Carpenter, C. (2008) Chlorothalonil/Penthi opyrad (DPX-QFA61) SC (250 g/L:100 g/L): Acute Oral Toxicity Study in Rats - Up-and-Down Procedure. Project Number: DUPONT/24839, DUPONT/24839/OCR, 17747. Unpublished study prepared by E.I. du Pont de Nemours and Company. 39 p.

47900003 Durando, J. (2008) Chlorothalonil/Acibenz olar SC (A16422A)-Acute Oral Toxicity Up-and-

### 123 Down Procedure in Rats: Final Report. Project Number: 24535, T008659/06. Unpublished study prepared by Eurofins/Product Safety Laboratories. 17 p.

48326606 Kuhn, J. (2010) Chlorothalonil TC: Acute Or al Toxiciity Study (UDP) in Rats: Final Report. Project Number: 14089/10. Unpublished study prepared by Stillmeadow, Inc. 11 p.

48515005 Clouzeau, J. (1994) Acute Oral Toxicity in Rats: Echo 375/Cymoxanil 50. Project Number: 11854/TAR. Unpublished study prepared by Centre International de Toxicologie. 29 p.

### 124 APPENDIX C: Environmental Fate Studies Kinetic Analyses

Aerobic Soil Metabolism Kinetic Analysis

MRID 0040547

### 125

### 126

### 127

### 128 MRID 47207702

### 129

### 130 MRID 43879601

### 131 MRID 47207703

### 132

### 133 APPENDIX D: DCI Justification Tables

Environmental Fate

Guideline Numb er: 835.2120 Study Title: Hydrolysis 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are requ ired for all terrestrial use patterns.

One study has been submitted that explored the hydrolys is of chlorothalonil at pH 5, 7 and 9 (MRID 0040539). The study was originally classified as acceptable; however, after recent revi ew this study has been reclassified to supplemental because the portion of the study that was conducted at pH 9 does not meet guideline criteria

because a material balance and characterization of the transformation products were not provided. The data suggest that chlorothal onil may hydrolyze (DT 50 = 51 days) under basic conditions (pH >7). Additional data are needed on chlorothalonil hydrolysis at pH 9. 

### Practical Utility of the Data

How will the data be used? Chlorothalonil is toxic to humans and to other non-target organism. Knowledge of the persistence chlorothalonil in aquatic environments as well as the identification of transformation products will help the Agency determine and estimate exposure of chlorothalonil and other residues of potential toxicological concern to non-target organisms. The results of this study will be used in the environmental fate assessment, and later on, in the ecological risk characterization.

For modeling generally the half-life value used in modeling is for pH 7; however, it is likely that the drinking water assessment as well as the aquatic exposure assessment will need to be highly refined. Without hydrolysis data at pH 9 the effects different aquatic environment (pH >7) may have on chlorothalonil cannot be assessed. In addition, drinking water treatment process such as water softening cannot be taken into account.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , assume chlorothalonil is stable to hydrolysis at all pH ranges and/or if it transfor ms it transforms to a residu e of toxicological concern). This conservative assumption could lead to higher predicted concentrations (EECs or EDWCs), according to the models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Numb er: 835.2370 Study Title: Air Photolysis 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are requ ired for all terrestrial use patterns.

Based on laboratory data, the vapor pressure (5.7 x 10 -7 torr) and Henry’s Law Constant (2.6 x 10 -7 atm -

m 3 /mole) values for chlorothalonil indicate some degree of volatility from both soil and water (semi-volatile). However, volatilization would not be expected to be a major dissipation route. Nonetheless, a number of studies have documented atmospheric transport and redeposition of various pesticides, including chlorothalonil. In addition, local ambient air monitoring data from sites near application, as well as locations up to a mile away from the application sites. Data from the state of Mont ana show detections of chlorothalonil in precipitation. This indicates that chlorothalonil volatility or particle phase transport plays a role in the dissipation of chlorothalonil and that it is possible for chlorothalonil exposure to occur adjacent to application sites, as well as

### 134 areas distant from application s ites (long range transport). 

### Practical Utility of the Data

How will the data be used? Chlorothalonil is toxic to humans and to other non-target organism via the inhalation route. Knowledge of the persistence chlorothalonil in air as well as the identif ication of transformation products will help the Agencydetermine and estimate exposure of chlorothalonil and other residues of potential toxicological concern to nontarget organisms in air. This data will be compared to inhalation toxicity data for non-target organism.

Specifically, the data will be used to help refine spray drift and volatility estimates of chlorothalonil and its transformation of toxicological concern.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , that chlorothalonil does not degrade in the air). This conservative assumption could lead to higher predicted concentrations (EECs or EDWCs), according to the models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Numb er: 835.2240 Study Title: Aquatic Photolysis 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are requ ired for all terrestrial use patterns.

Five aquatic photolysis studies have been submitted fo r chlorothalonil; however, two of these studies (MRIDs 40183418 and 0087281) were deemed unacceptable. Another study (MRID 41030001) is not actually an aquatic photolysis study. The submitted material provides supplemental information on concerns raised by EPA in the review of the unacceptable study, MRID 40183418 including char acterization of the artificial light source and sample frequency. The submittal of this information does not support changing the classification of MRID 40183418. A previously classified acceptable study (MRID 0040540) was reevaluated and reclassified as supplemental because the study report did not adequately compare the intens ity and spectral distribution of the artificial light source to natural sunli ght or identify transformation products. Based on laboratory data generated using an artificial light source, a more recent study (M RID 45710223) showed that chlorothalonil did transform under aqueous photolysis with an environmental predicted photo-transformation half-life of 10.3 hours (DT 50 = 10.5 hours; MRID 45710223) at 30 °N latitude. This study was origina lly classified as a cceptable; however, after a recent review this study was al so reclassified as supple mental. This study was re classified because three major transformation products [47% of the applied radio activity (AR)] were not identified. Additional data is needed to identify these major transformation products or any other potentially toxic transformation products observed in the study. 

### Practical Utility of the Data

How will the data be used? Chlorothalonil is toxic to humans and to other non-target organism. Knowledge of the persistence chlorothalonil in aquatic environments as well as the identification of transformation products will help the Agency determine and estimate exposure of chlorothalonil and other residues of potential toxicological concern to non-target organisms. The results of this study will be used in the environmental fate assessment, and later on, in the ecological risk characterization.

Specifically, the data will be used to derive the aquatic photolysis half-life value used as an input parameter for aquatic models—PRZM-EXAMS permitting the Agency estimate exposure of chlorothalonil and its transformation products of toxicological concern to non-target organisms.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , the unidentified residues

### 135 are as toxic as chlorothalonil or its most toxic transf ormation product whichever is greatest). This conservative assumption could lead to higher predicted concentrations (EECs or EDWCs), according to the models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Numb er: 835.4100 Study Title: Aerobic Soil Metabolism 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are conditional required for all terrestrial use patterns.

Six aerobic soil metabolism studies have been submitted for chlorothalonil. Two of the six studies (MRIDs 87285 and 114035) were de termined to be unacceptabl e because the studies were conducted with bacterial cultures (inoculated with soil perfusions) and not soil. The remaining studies have been classified supplemental. Taken together these aerobic soil metabolism studies demonstrate that chlorothalonil can undergo a number of

different chemical reactions in the soil to form a number of different transformation products. All the transformation products reported retain th e phenyl ring with the exception of CO 2 . The transformation rate or chlorothalonil was also shown to be heavily influenced by the application rate. Higher application rates results in long half-life values while lower application rate s result in shorter half-life values (MRIDs 43879601, 47207702, 00087351and 00040547). This is likely the resu lt of a decrease in viability of the soil microbes after exposure to chlorothalonil. This is supported by a decr ease in observed microbial activity at study termination as compared to study initial (MRID 47207703). None of the st udies have been conducted at application rates that represent the maximum single application rates currently pe rmitted on the label. In general, this suite of studies indicate that chlorothalonil degrades over the first 20 days; however, if any chlorothalonil remains after 20-40 days it is not likely to be metabolized or it is metabolized very slowly. Based on the data presented in this table, the half-life value for the currently approved maximum application rate is likely between 18-35 days; however, additional data are needed to confirm this assumption. It was also noted that in several of the submitted studies that not all of the transformation pr oducts were identified. This limits th e Agency’s ability to identify residues of toxicological concern. 

### Practical Utility of the Data

How will the data be used? Chlorothalonil is toxic to humans and to other non-target organism. Knowledge of the persistence chlorothalonil based on the current use pattern will help the Agency determine and estimate exposure of chlorothalonil and other residues of potential toxicological concern to non-target organisms.

Specifically, the data will be used to derive the aerobic soil metabolism half-life value used as an input parameter for aquatic models—PRZM-EXAMS and SCI- GROW/PRZM_GW permitting the Agency estimate exposure of chlorothalonil and its transformation products of toxicological concern to non-target organisms.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , that chlorothalonil degrades at rates representative of higher applications ra tes). This conservative assumption could lead to higher predicted concentrations (EECs or EDWCs), according to th e models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate

assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Numb er: 835.4300 Study Title: Aerobic Aquatic Metabolism

### 136 Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are requ ired for all terrestrial use patterns.

Three different aerobic aquatic metabolism studies have been submitted for chlorothalonil. All of these studies have been classified as supplemental. All three studie s indicate that chlorothalonil transformation is rapid >1 day. Nevertheless, all of these studies have deficiencies that limit the use of the data for risk assessment purposes. One common deficiency is th at none of the studies identified all the major transformation products. One of the studies (MRID 45908001) report fluctuating chlorothalonil concentration (going up and down) and thus corresponding half-life values should not be use quantitatively in risk assessment. In another study (MRID 42226101), artificial so urces of water were used and the resulting ha lf-life values may not accurately represent

those for natural water. Additional data is needed on th e transformation rate of chlorothalonil in aerobic aquatic systems, as well as full characterization of all major transformation products or transformation products of toxicological concern. 

### Practical Utility of the Data

How will the data be used? Chlorothalonil is toxic to humans and to other non-target organism. Knowledge of the persistence chlorothalonil based on the current use pattern will help the Agency determine and estimate exposure of chlorothalonil and other residues of potential toxicological concern to non-target organisms.

Specifically, the data will be used to derive the aerobic aquatic metabolism half-life value used as an input parameter for aquatic models—PRZM-EXAMS permitting the Agency estimate exposure of chlorothalonil and its transformation products of toxicological concern to non-target organisms.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , the unidentified residues

are as toxic as chlorothalonil or its most toxic transf ormation product whichever is greatest). This conservative assumption could lead to higher predicted concentrations (EECs or EDWCs), according to the models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Number: 835.1230/835.1240 Study Title: Adsorption/ De sorption Batch Equilibrium 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are requ ired for all terrestrial use patterns.

An adsorption study has been submitted for chlorothalonil; however, it was cl assified as supplemental because the temperature and light conditions used in the experiment were not reported. No data has been submitted on the desorption of chlorothalonil from soil. 

### Practical Utility of the Data

How will the data be used? Chlorothalonil is toxic to humans and to other non-target organism. Knowledge of the mobility chlorothalonil based on the current use pattern will help the Agency determine and estimate exposure of chlorothalonil.

Specifically, the data will be used to determine the fate of chlorothalonil in soil and system systems to better characterize the exposure of non-ta rget organisms to chlorothalonil.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , assume highest possible concentrations in both water and soil or sediment depending on the exposure scenario evaluated) for risk

### 137 assessment purposes. This conservative assumption could lead to higher predicted concentrations (EECs or EDWCs), according to the models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Numb er: 835.4200 Study Title: Anaerobic Aquatic Metabolism 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are conditional required for all terrestrial use patterns.

One supplemental anaerobic aquatic metabolism study (MRID 00147975) has been submitted. These data suggest that chlorothalonil can transform under anaero bic conditions; however, after reevaluation of the study several deficiencies have been noted that limit the use of this data for risk assessment purposes. Redox potentials and oxygen concentrations were not provided during the experiment; therefore, it cannot be confirmed that the system was anaerobi c. Since the test system was purged with nitrogen for 30 days prior to study initiation it is assumed that study was conducted under anaerobic conditions; however, additional data are needed to confirm this assumption. In addition, no data are provided for day 0. For this reason, chlorothalonil concentration at day 0 was assumed to be 100% of the applied radioactivity. The study was also terminated before the pattern of formation and decline could be established for the transformation products in one of the test systems. The test systems used in this experiment are soil and distilled water. Current guidelines indicate that anaerobic aquatic metabolism studies are conducted with sediment (not soil) along with natural water (not distilled water). For all the reasons mentioned above, th e anaerobic aquatic metabolism study is considered a data gap without additional information. 

### Practical Utility of the Data

How will the data be used? Specifically, the data will be used to derive the anaerobic aquatic metabolism half-life value used as an input parameter for aquatic models—PRZM-EXAMS permitting the Agency estimate exposure of chlorothalonil and its transformation products of toxicological concern to non-target organisms.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency would have to make a conservative assumption ( e.g. , chlorothalonil is stable to anaerobic aquatic metabolism). This conservative assump tion could lead to higher predicted concentrations (EECs or EDWCs), according to the models, and consequently, higher risk quotients or drinking water exposures. Also, there would be a higher degree of uncertainty in the environmental fate assessment.

The lack of this data limits the flexibility the Agency and registrants have to come into compliance with the Endangered Species Act. This could result in use rest rictions for chlorothalonil that may be unnecessary.

Guideline Numb er: 835.8100 Study Title: Field Volatility 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are conditional required for all terrestrial use patterns.

Based on laboratory data, the vapor pressure (5.7 x 10 -7 torr) and Henry’s Law Constant (2.6 x 10 -7 atm -

m 3 /mole) values for chlorothalonil indicate some degree of volatility from both soil and water (semi-volatile). However, volatilization would not be expected to be a major dissipation route. Nonetheless, a number of studies have documented atmospheric transport and redeposition of various pesticides, including chlorothalonil. In addition, local ambient air monitoring data from sites near application, as well as locations up to a mile away from the application sites. Data from the state of Mont ana show detections of chlorothalonil in precipitation. This indicates that chlorothalonil volatility or particle phase transport plays a role in the dissipation of

### 138 chlorothalonil and that it is possible for chlorothalonil exposure to occur adjacent to application sites, as well as areas distant from application sites (long range transport). 

### Practical Utility of the Data

How will the data be used? While the Agency does not have a method for assessing lo ng range transport at this time, PERFUM can be used to look at vapor phase concentrations of chlorothalonil ad jacent to application sites. If a long range transports model is available at the time the assessment is completed long range transport of chlorothalonil will be

assessed.

How could the data impact the Ag ency’s future decision-making? Without this data the Agency would have to assume exposure to chlorothalonil through volatility. Quantitative assessment would be limited; therefore, the risk would be assumed.

If future endangered species risk assessments are perf ormed without these data, the Agency would have to presume risk to non-target organism from use of chlorothalonil in the air. Therefore, use of chlorothalonil and its formulated products may need to be restricted in areas where listed sp ecies could be exposed. The lack of these data will limit the flexibility the Agency and re gistrants have in coming into compliance with the Endangered Species Act and could result in use restric tions for chlorothalonil that are unnecessarily severe.

Guideline Numb er: 835.4300 Study Title: Terrestrial Field Dissipation 

### Rationale for Requiring the Data
According to 40 CFR Part 158, Subpart N (Environmental Fate) §158.1300 (Environmental fate data requirements table), these data are conditional required for all terrestrial use patterns.

Two supplemental terrestrial field dissipation studies are available for chlorothalonil. In both of these studies, sampling did not begin until at least one month after chlorothalonil applications. This limits the ability to estimate a represent half-life value for chlorothalonil, as well as for any chlorothalonil transformation products. The estimate half-life values suggest that substantial amounts of applied chlorothalonil could be available for runoff or soil- sorbed erosion transp ort for several weeks to months post-a pplication (estimated half-life values ranged from 33 to 81 days).

There is also no environmental chemistry method for chlorothalonil in water. 

### Practical Utility of the Data

How will the data be used? Terrestrial field dissipation data is used to confirm the conceptual environmental fate model derived from laboratory studies to insure that all appropriate dissipa tion pathways are identified and that all environmentally relevant transformation products are identified.

How could the data impact the Ag ency’s future decision-making? Without these data, the Agency is unable to confirm th e conceptual model for the dissipation of chlorothalonil and its transformation products in the environment. This le ad could lead to a higher degree of uncertainty in the

environmental fate assessment.



### Environmental Effects

Guideline Number: 850.2100 Study Title: Avian Acute Oral Toxicity Test

Rationale for Requiring the Data Acceptable acute avian oral toxicity data were submitted for exposures of mallard ducks ( Anas platythynchos ) to chlorothalonil; however, data are not available for a passerine species, which is required under the 40 CFR Part 158 (Oct. 26, 2007) data requirements for conventional pesticides. The new Part 158 data requirements specify that acute avian oral toxicity data be submitted for either mallard duck or bobwhite quail and a passerine species. Although, there were no mortalities observed during the acute oral study available for mallard ducks and the LD 50 value was determined to be greater than 4,640 mg/kg-bw (the highest concentration tested), the LOAEC in this

### 139 study was determined to be 2,150 mg a.i./kg-bw based on reduced body weight. Weight loss was also noted in the available avian sub-acute dietary studies, indicating potential toxicity of chlo rothalonil to birds. Therefore, an avian oral toxicity test is required for passerine birds, as specified in 40 CFR Part 158. A passerine study protocol must be submitted for review by the Agency prior to initiation of this study. Practical Utility of the Data

How will the data be used? Acute avian oral toxicity data for passerine species w ill be used to refine the screening-level assessment by determining whether there are differences in avian speci es sensitivity to chlorothalonil between passerines and upland game and waterfowl species. If oral acute toxicity data are not submitted for passerines, risk will be assumed for all passerine species.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are performe d without these data, the Agency would have to assume that chlorothalonil “may affect” listed passerine birds dire ctly (and listed species from other taxa indirectly), and use of chlorothalonil and its formulated products may need to be restricted in areas where listed species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use rest rictions for chlorothalonil use that are unnecessarily severe.

Guideline Numbers: 850.4100 and 850.4150 Study Title: Terrestrial Plan t Toxicity Tests (Tier II)

Rationale for Requiring the Data Terrestrial plant toxicity studies using TEP(s) and associated risk analysis of plants are required for registration of pesticides with outdoor uses (CFR Part 158). For terrest rial plants, Tier II studies are required when potential concerns are triggered ( i.e ., when there is some indication that there ma y be significant toxicity to plants). These indicators may be an herbicidal mode of action, statements on the label indicating toxicity to plants, or ≥ 25%

effect levels in the Tier I studies.

Tier I seedling emergence and vegetative vigor studies are available for chlorothalonil using 16 lb a.i./acre test concentrations (MRIDs 42433808 and 42433809). These studies were not conducted with a typical end-use product (TEP), but were instead condu cted using chlorothalonil mixed with a solvent (100% acetone). When the results are compared to the negative (and not the pooled) control, onion shows an inhibition in growth of 26% in the seedling emergence study and cucumber shows a 26% inhibition in growth in the vegetative vigor study at the

16 lb a.i./acre concentration. Becau se these studies were conducted using TGAI mixed with acetone (instead of a TEP) and there were effects greater than 25% noted in th e studies for some species, EF ED recommends that these data be requested for the chlorothalonil risk assessment. If additional toxicity data for terrestrial plants are not submitted for chlorothalonil, EFED will assume risk for terrestrial plants. Practical Utility of the Data

How will the data be used? Tier II vegetative vigor and seedling emergence data for terrestrial plants will be us ed to determine the potential for chlorothalonil to affect non-target pl ant species in the terrestrial environm ent. In the absence of data specific for these plants, risk to terrestrial plants will be assumed.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are perf ormed without these data, the Agency would have to presume risk to non-target terrestrial plants from use of chlorothalonil. Therefore, use of chlorothalonil and its formulated products may need to be restricted in areas where listed species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictions for chlorothalonil that are unnecessarily severe.

Guideline Number: Non-guideline Study Title: Avian Inhalation Toxicity

Rationale for Requiring the Data Acceptable acute avian toxicity data were s ubmitted for oral exposures of mallard duck ( Anas platythynchos )

### 140 to chlorothalonil; however, data are not available for inhalation toxicity. Acute toxicity data using rats indicate that mammals are much more sensitive to chlorothalonil when exposed via the inhalation route compared to the oral route. Furthermore, an eval uation of inhalation as a route of exposure using the Screening Tool for Inhalation Risk (STIR, v. 1.0) model suggests that inhalation exposure is a pathway of concern for avian wildlife due to spray drift. Therefor e, an acute avian inhalation toxicity test is being requested using the most sensitive avian species as s hown by avian acute oral studies. The study being requested will aid in evaluating this pathway of concern for avian taxa. An avian inhalation study protocol must be submitted for review and approval by the Agency prior to initiation of this study. Practical Utility of the Data

How will the data be used? Acute avian inhalation toxicity data will be used to identify potential risks to birds from acute exposure to

chlorothalonil. The data will reduce uncertainties associ ated with the current risk assessment for birds and will improve the Agency’s understanding of the potential effects of chlorothalonil on terrestrial species. If inhalation acute toxicity data are not submitted for birds, then risk to birds from acute inhalation exposure to chlorothalonil will be presumed.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are performed without these data, the Agency would have to assume that chlorothalonil “may a ffect” listed bird species directly (and listed species from other taxa indirectly), and use of chlorothalonil and its formulated products may need to be restricted in areas where listed species could be exposed. The lack of these data will limit the flexibility of the Agency and the registrants for compliance with the Endangered Species Act and could result in use restrictions for

chlorothalonil use that are unnecessarily severe.

Guideline Number: 850.1075 Study Title: Fish Acute Toxicity Test , Estuarine-marine, Chlorothalonil TGAI

Rationale for Requiring the Data An acceptable estuarine-marine fish st udy for chlorothalon il is not currently available to assess the risk of

chlorothalonil to estuarine/marine fish on an acute exposure basis. Chlorothalonil is applied in many different

scenarios where drift or runoff is expected to enter aquatic ecosystems.

The requested data would allow EPA to refine its acute ri sk estimates for estuarine/ma rine fish, and allow it to define an action area for endangered sp ecies. Risk mitigation strategies ( e.g. , determining maximum chlorothalonil application rate that results in an RQ below the LOC) cannot be evaluated without this data.

Practical Utility of the Data

How will the data be used? The data will be used to estimate potential risks to estuarine/marine fish, including the likelihood of potential risks to endangered species, either by direct effects or by indirect effects, and to reduce uncertainties as sociated with the current ecological risk assessment. By refining the assessment , the Agency will be able to determine whether current labeling is appropriate and whether further mitigation is necessary.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are performe d without these data, the Agency would have to assume that chlorothalonil "may affect" endangered fish directly (and endangered species from other taxa indirectly), and use of chlorothalonil products might need to be restricted in areas where endangered species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictio ns for chlorothalonil produc ts which are unnecessarily

severe.

### 141 Guideline Numb er: 850.1400 Study Title: Fish Early-Life Stage Toxicity (Saltwater), ( Cyprinodon variegates ) is the preferred species Test Substance: Chlorothalonil (TGAI) Rationale for Requiring the Data The requested data would allow EPA to refine its chronic risk (growth and reproduction) estimates for estuarine/marine fish, and allow it to define an action area for endangered species. Risk mitigation strategies ( e.g. , determining maximum chlorothalonil application rate that results in an RQ below the LOC) cannot be evaluated

without this data.

Since the registration of chlorothalonil, the Agency has worked to finalize its update to the data requirements in 40 CFR Part 158. These updated data requirements were promulgated in October 2007. Now one estuarine/marine fish early life stage study is required to support all terres trial, aquatic, forestry, and residential turf use patterns when those uses can lead to exposure in estuarine and/or marine habitats. 40 CFR Part 158 was revised to list the fish early-life stage and aquatic inverteb rate life-cycle studies as separate requirements in the data table; then identify each test organism as a freshwater or saltwater sp ecies. For the saltwater fish early-life stage and saltwater invertebrate life-cycle data requireme nts, the Agency requires testing of one fish species and one aquatic invertebrate species, respectively, fo r the terrestrial, aquatic, forestry, and residential turf use patterns when estuarine or marine habitats may be exposed to the chemic al. Previously, the saltwater invertebrate life cycle and saltwater fish early life stage tests were combined under one data requirement with te sting required of only the more sensitive species in acute studies. However, when a pesticide enters the aquatic environment, both groups of organisms are exposed. Moreover, acu te sensitivity is not necessarily a re liable indicator of chronic sensitivity when looking across different groups of organisms. Therefore, chronic data are needed regardless of the results of acute testing.

This change was warranted because the relative sensitivity of fish and invertebrates can vary widely across chemicals. Previously, only the more sensitive of the two organisms, either fish or aquatic invertebrates, as determined by Tier I acute studies, was tested. However, since both organisms are exposed when a pesticide enters an aquatic environment and the acute sensitivity of an invertebrate may not accurately predict the chronic sensitivity in fish and vice versa, both species must now be tested for chronic effects.

Chlorothalonil is toxic to both freshwater and estuarine-marine fish on an acute basis and is toxic to freshwater fish on a chronic basis. Therefore, chloro thalonil has the potential to be toxic to estuarine-marine fish on a chronic basis as well. Chlorothalonil is applied in many different scenarios where drift or r unoff is expected to enter estuarine and marine ecosystems. Practical Utility of the Data

How will the data be used? These data are needed for a registration review decision and for an endangered species assessment, which will be conducted as part of that decision. The effects data woul d be used to determine the likelihood that the chronic risks can potentially impact aquatic communities, by direct effects on fish and their reproduction. In the absence of data, the Agency will use available toxicity data to determine an acute-to-chronic ratio (ACR) using conservative assumptions to be more protective, especially of endangere d species. In addition, other sources of data from other chemicals in similar chemical class or mode of action group may be used to derive ACR using most conservative assumptions. By refining the assessment, the Agency would be able to determine the appropriate mitigation for

chlorothalonil.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are performe d without these data, the Agency would have to assume that chlorothalonil “may affect” endang ered fish directly (and endangered species from other taxa indirectly). Thus, use of chlorothalonil might need to be restricted in areas where endangered species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restric tions for chlorothalonil which are unnecessarily severe.

Guideline Numb er: 850.1350 Study Title: Mysid Chronic Toxicity Test Substance: Chlorothalonil (TGAI)

### 142 Rationale for Requiring the Data The submitted study (MRID 42433807) indicat es that chlorothalonil is toxic to estuarine-marine invertebrates on a chronic basis; however, the study resulted in a non-definitive NOAEC value (significant effects at all concentrations tested). Therefore, a definitive NOAEC va lue is not available and use of the non-definitive value may underestimate risk to estuarine-marine invertebrates.

The requested data would allow EPA to refine its chronic risk (growth and reproduction) estimates for estuarine/marine invertebrates, and allow it to define an action area for endangered species. Risk mitigation strategies ( e.g. , determining maximum chlorothalonil application rate that results in an RQ below the LOC) cannot

be evaluated without this data.

Practical Utility of the Data

How will the data be used? These data are needed for a registration review decision and for an endangered species assessment, which will be conducted as part of that decision. The effects data woul d be used to determine the likelihood that the chronic risks can potentially impact aquatic communities, by direct effects on aquatic invertebrates and their reproduction. In the absence of data, the Agency may use available freshwater invertebrate toxicity data to determine an acute-tochronic ratio (ACR) using conservative assumptions to be more protective, especially of endangered species. In addition, other sources of data from other chemicals in similar chemical class or mode of action group may be used to derive ACR using most conservative assumptions. By refining the assessment, the Agency would be able to determine the appropriate mitigation for chlorothalonil.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are performe d without these data, the Agency would have to assume that chlorothalonil “may affect” enda ngered estuarine-marine aquatic invertebrates directly (and endangered species from other taxa indirectly). Thus, use of chlorothalonil might need to be restricted in areas where endangered species could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictions for chlorothalonil which are unnecessarily severe.

Guideline Number: 850.1735 and 850.1740 Study Title: 10-day Whole Sediment Toxicity Test, Chlorothalonil TGAI: 850.1735 with Chironomus tentans

and Hyalella azteca ; 850.1740 with Leptocheirus plumulosus Rationale for Requiring the Data

Data for freshwater and estuarine-mari ne sediment-dwelling invertebrates in a water-sediment test system are not currently available to assess the risk of chlorothalonil to freshwater and estuarine/marine sediment-dwelling organisms on a short-term exposure basis. Chlorothalonil is applied in many different scenarios where drift or runoff is expected to enter aquatic ecosystems. Therefore, 10 -day toxicity test following OPPTS 850.1735 and 850.1740 guidelines are requested for both freshwater organisms, Chironomus tentans and Hyallela azteca as well as the recommended estuarine/marine organism, Leptocheirus plumulosus . However, since chlorothalonil may be persistent in terrestrial environments, based on the ae robic soil metabolism, and is expected to enter aquatic environments through runoff, this runoff may provide a more chronic exposure to sediment organisms. Therefore, it is recommended that after the 10-day studies are submitted and reviewed, if there is evidence that chronic toxicity testing may be warranted (based on observed toxicity and persistence in the 10-day stud ies), then chronic testing, which would evaluate reproduction as well as survival and growth, should also be requested.

The requested data would allow EPA to refine its risk estimates for freshwater and estuarine/marine sedimentdwelling invertebrates, and allow it to define an action area for endangered species. Risk mitigation strategies ( e.g. , determining maximum chlorothalonil application rate that results in an RQ below the LOC) cannot be evaluated

without this data.

Practical Utility of the Data

How will the data be used? The data will be used to estimate potential risks to freshw ater and estuarine/marine sediment-dwelling invertebrates,

### 143 including the likelihood of potential risks to endangered species, either by direct effects or by indirect effects, and to

reduce uncertainties associated with the current ecological ri sk assessment. By refining the assessment, the Agency will be able to determine whether current labeling is ap propriate and whether further mitigation is necessary.

How could the data impact the Ag ency’s future decision-making? If future endangered species risk assessments are performe d without these data, the Agency would have to assume that chlorothalonil "may affect" endang ered sediment-dwelling invertebrates directly (and endangered species from other taxa indirectly), and use of chlorothalonil products might need to be restricted in areas where endangered species could be exposed. The lack of these data will lim it the flexibility the Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictions for chlorothalonil products which are unnecessarily severe.

### 144 APPENDIX E: SIP Input and Output

Parent Chlorothalonil:

Degradate SDS-3701:

Table 1. Inputs Table 1. Inputs

Parameter Value

Chemical name Chlorothalonil
Solubility (in water at 25 o C; mg/L) 0.8

Mammalian LD 50 (mg/kg-bw) 10000

Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg-bw) 92.5 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg-bw) 4640

Avian test species mallard duck Body weight (g) of "other" avian species Mineau scaling factor 1.15

Mallard NOAEC (mg/kg-diet) Bobwhite quail NOAEC (mg/kg-diet) 153 NOAEC (mg/kg-diet) for other bird species Body weight (g) of other avian species NOAEC (mg/kg-diet) for 2nd other bird species Body weight (g) of 2nd other avian species

Table 2. Mammalian Results

Parameter Acute Chronic Upper bound exposure (mg/kg-bw) 0.1376 0.1376 Adjusted toxicity value (mg/kg-bw) 7691.6057 71.1474 Ratio of exposure to toxicity 0.0000 0.0019

Conclusion* Drinking water exposure alone is NOT a potential

concern for mammals Drinking water exposure alone is NOT a potential

concern for mammals

Table 3. Avian Results

Parameter Acute Chronic Upper bound exposure (mg/kg-bw) 0.6480 0.6480 Adjusted toxicity value (mg/kg-bw) 2409.2059 16.2636 Ratio of exposure to acute toxicity 0.0003 0.0398

Conclusion* Drinking water exposure alone is NOT a potential

concern for birds Drinking water exposure alone is NOT a potential

concern for birds

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. Therefore, when aggregated with other routes ( i.e ., diet, inhalation, dermal), pesticide exposure through drinking water may contribute to a total exposure that has potential for effects to non-target animals.

### 145 Parameter Value

Chemical name SDS-3701

Solubility (in water at 25 o C; mg/L) 115.7

Mammalian LD 50 (mg/kg-bw) 242
Mammalian test species laboratory rat Mammalian NOAEL (mg/kg-bw) 6
Mammalian test species laboratory rat

Avian LD 50 (mg/kg-bw) 158
Avian test species mallard duck
Mineau scaling factor 1.15 Mallard NOAEC (mg/kg-diet) 50

Table 2. Mammalian Results

Parameter Acute Chronic
Upper bound exposure (mg/kg-bw) 19.9004 19.9004 Adjusted toxicity value (mg/kg-bw) 186.1369 4.6150
Ratio of exposure to toxicity 0.1069 4.3121

Conclusion* Exposure through drinking water alone is a

potential concern for

mammals Exposure through drinking water alone is a

potential concern for

mammals

Table 3. Avian Results

Parameter Acute Chronic
Upper bound exposure (mg/kg-bw) 93.7170 93.7170 Adjusted toxicity value (mg/kg-bw) 82.0376 2.4806
Ratio of exposure to acute toxicity 1.1424 37.7795

Conclusion* Exposure through drinking water alone is a

potential concern for
birds Exposure through drinking water alone is a

potential concern for
birds

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. Therefore, when aggregated with other routes ( i.e ., diet, inhalation, dermal), pesticide exposure through drinking water may contribute to a total exposure that has potential for effects to non-target animals.

### 146 APPENDIX F: STIR Input and Output



## Input

Application and Chemical Information

Enter Chemical Name Chlorothalonil Enter Chemical Use Turf (golfcourse) Is the Application a Spray? (enter y or n) y If Spray What Type (enter ground or air) ground Enter Chemical Molecular Weight (g/mole) 265.91 Enter Chemical Vapor Pressure (mmHg) 5.72E-07 Enter Application Rate (lb a.i./acre) 13

Toxicity Properties

Bird

Enter Lowest Bird Oral LD 50 (mg/kg bw) 4640
Enter Mineau Scaling Factor 1.15 Enter Tested Bird Weight (kg) 1.6

Mammal

Enter Lowest Rat Oral LD 50 (mg/kg bw) 10000

Enter Lowest Rat Inhalation LC 50 (mg/L) 0.012
Duration of Rat Inhalation Study (hrs) 4 Enter Rat Weight (kg) 0.35



## Output

Results Avian (0.020 kg )

Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 8.19E-03 Maximum 1-hour Vapor Inhalation Dose (mg/kg) 1.03E-03

Adjusted Inhalation LD 50 2.23E-02

Ratio of Vapor Dose to Adjusted Inhalation LD 50 4.61E-02 Exposure not Likely Significant
Maximum Post-treatment Spray Inhalation Dose (mg/kg) 1.37E+00

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD 50 6.15E+01 Proceed to Refinements



### Results Mammalian (0.015 kg )

Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 8.19E-03 Maximum 1-hour Vapor Inhalation Dose (mg/kg) 1.29E-03

Adjusted Inhalation LD 50 7.14E-01

Ratio of Vapor Dose to Adjusted Inhalation LD 50 1.81E-03 Exposure not Likely Significant
Maximum Post-treatment Spray Inhalation Dose (mg/kg) 1.73E+00

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD 50 2.42E+00 Proceed to Refinements **NOTE**: When entering values, pre s in order to update linked cells.