OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C., 20460

Chemical: Fosamine Ammonium

PC Code: 106701

DP Barcode: 415252 Date: September 3, 2015

MEMORANDUM

SUBJECT: Registration Review Ecological Risk Assessment for Fosamine Ammonium (PC Code 106701; DP Barcode 415252)

TO: James Parker, Chemical Review Manager Neil Anderson, Chief Risk Management and Implementation Branch 6 Pesticide Reevaluation Division (7508P)

THROUGH: Dana Spatz, Chief

Environmental Risk Branch 3

Environmental Fate and Ef fects Division (7507P)

FROM: Frank T. Farruggia, Ph.D., Biologist Rosanna Louie-Juzwiak, RAPL

Environmental Risk Branch 3

Environmental Fate an d Effects Division (7507P)

EXECUTIVE SUMMARY

The Environmental Fate and Effects Division (EFED) ha s completed the ecological risk assessment as part of the Registration Review of the herbicide fo samine ammonium (PC Code 106701). Fosamine

ammonium is a non-selective herbicide used to co ntrol undesirable brush/herbaceous plant species used for brush control of nonagricultural rights-of-wa y (e.g., highways, railroads , and utilities), industrial sites, and fencerows. In 1995 the Agency conducted a risk assessment on the potential exposure and risk to the environment from registered uses of fosamine ammonium as part of the Reregistration Eligibility Decision (USEPA 1994). This assessment relies upon earlier assessments that found fosamine ammonium does not result in risk concerns to birds, mammals, invertebrates, fish, aquatic invertebrates or aquatic plant species as risk quotients (RQs) did not exceed the Agency's levels of concern (LOCs).

The following assessment focuses on the potential ri sks to terrestrial and semi-aquatic plants from current fosamine ammonium uses. The registrant has submitted plant toxicity data on the technical grade fosamine ammonium (MRID 42647601). Toxicity data on fosamine ammonium end-use product formulations are not available, and thus it is uncertain whether or not the formulations are more or less toxic than technical grade active ingredient. Several plant toxicity studies available in the open literature

### 2 evaluated the efficacy of products containing fosamine ammonium on target plants and trees at registered application rates. These studies do not re adily allow for estimating a corresponding NOEL or LOEL from these studies to compare against available registrant-submitted plant toxicity studies; however, there were no tested species that reported effects ( e.g. , reduction in height or growth) at an exposure rate lower than what is captured in the submitted plant studies. In addition, fosamine ammonium products are intended to control unwanted brush; although no toxicity data using woody species of plants have been submitted, some woody species are expected to be affected.

Based on the available toxicity data, risks to terrestrial plants are expected. These risks include potential risk to agricultural crops such as corn and soybeans, and to native non-target vegetation. Based on exposures and distance from the edge of the field, the estimated risks extend to 290 ft and beyond 1000 feet for sensitive monocot and dicot species respectively via spray drift, when applied by air. Coarser droplet spectra reduce the distances. For monocots such as corn, the most sensitive monocot tested, there are LOC exceedances out to 115 feet, and for dicots such as soybean, risk extends to 318 feet. Ground spray with coarser droplet sizes reduces the pr edicted drift distance greatly for monocots (from 154 to 36 ft) but the LOC continues to be exceeded for dicots to greater than 1000 feet for the most sensitive tested species, and at least 194 feet for the least sensitive dicot.

Summary of Prior Risk Conclusions

For birds, small mammals, terrestrial invertebrates, aquatic plants, and aquatic animals, the estimated acute risk quotients (RQs) did not exceed the Agency's levels of concern (LOCs). Acute risk to terrestrial plants could not be assessed at the time because da ta were still outstanding for corn, sugarbeet, pea, and cucumber. Available fate and toxicity data are summarized in Appendix B.

In the risk assessment conducted in support of the reregistration evaluation, the estimated environmental concentrations estimated for aquatic exposure were modeled using GENEEC, predicting a maximum concentration of 8.8 ppm resulting from runoff , based on the 24 lb a.i./A application rate. All acute RQs were below the LOC ( i.e. , <0.05). Chronic data for aquatic animals were unavailable; however, based on the short half-life of fosamine ammonium in the aerobic soil metabolism study ( i.e. , <4 days), the fish early life stage and aquatic invertebrate lif e cycle studies were not required. Given the limited ( i.e. , single application) frequency of exposure and the observed low acute toxicity to aquatic organisms, chronic risks to aquatic organism s were expected to be low.

Chronic exposure RQs for small mammals did not exceed Agency LOCs. Chronic data were unavailable for fish and aquatic invertebrates. The only level of concern exceeded (RQ = 23) was from a mallard reproduction study; however, there is some uncertainly associated with the experimental results (D214645). EPA suggested modifying the label to account for the potential adverse effects on avian reproduction including threatened and endangered species exposed to fosamine ammonium. This change is no longer an issue since EPA later (1997; per memo D231023) accepted a mallard reproduction study (MRID 44143501) showing the registered uses of fosamine ammonium do not result in RQs that exceed the Agency's LOCs.

Use of fosamine ammonium may, however, directly impact terrestrial and semi-aquatic plants, and, through loss of food source, indirectly impact animals depending on terrestrial plants for food or

habitat.

### 3 Chemical Properties and Fate Overview:

Although fosamine ammonium is highly soluble in water and mobile in various soils, fosamine ammonium degrades rapidly in the environment via microbial-mediated degradation in soil, which are supported by available terrestrial field data. Based on its physical and chemical properties alone, fosamine ammonium has low potential to volatilize from soils (vapor pressure) or from water (Henry’s Law Constant). It is also unlikely to bioacc umulate in fish given the low value of the Log n -octanol/water partition coefficient. Fosamine ammonium is stable to hydrolysis and photolysis (MRIDs 40133701, 40133702, and 40133703), and no degradation wa s observed under anaerobic conditions (MRIDs 42060602 and 42680701). No aerobic aquatic metabolism data have been submitted to the EPA. Major degradates (>10% of the applied) of fosamine ammonium are carbamolyphosphonic acid (CPA) and carboxylphosphonic acid (ING-3003), and carbon dioxide (MRIDs 42020206 and 42724301). There are

limited environmental fate data available for CPA a nd ING-3003; however, based on the ecological data, these compounds are of low toxicological concern.

Exposure Estimation

Current fosamine ammonium product labels ( Table 1 ) were used to derive EECs relevant to terrestrial and wetland plants using the TerrPlant and AgDrift models. Detailed information about the TerrPlant

model can be found at http://www.epa.gov/oppefed1/models/terrestrial/ and at http://www.epa.gov/oppefed1/models/water/index.htm#agdrift . The AgDRIFT spray drift model (v2.01; May 2001;) was used to assess exposures of organisms to fosamine ammonium deposited on terrestrial or aquatic habitats by spray drift alone.

Table 1. Maximum Fosamine Ammonium Use Rate

Group name Uses represented Max. Rate per App. (lb a.i./A) Maximum Annual Rate (lb a.i./A) 1 Application

Method 2

Terrestrial Non-Food Crop Agricultural andnonagricultural right-ofway/fencerows/ hedgerows

Agricultural uncultivated

areas

Airports/landing fields

Industrial areas (outdoor)

Nonagricultural uncultivated areas/soils

Sewage disposal areas 24 12 (aerial) 24 (ground) Aerial and ground

Forestry Pine (forest/shelterbelt) 6 12 Aerial and ground

1 Application methods reported for any labeled application rates (maximum rate per application and/or seasonal maximum dose/year) for that crop/use. The term ground includes any of the ground methods previously defined

### 4 as ground. In some cases when both aerial and ground application methods are reported for a crop/use, both methods may not be used at the maximum reported application rates (single application and/or seasonal application).

2 Aerial refers to helicopter application only.

Terrestrial Plant Toxicity Data and Related Uncertainty in the Assessment of Risk to Terrestrial Plants

Terrestrial Plant Toxicity Exposure and Risk Assessment

For this risk assessment, terrestrial plant toxicity data for seedling emergence (850.4100) and vegetative vigor (850.4150) stages of plant development were re-evaluated (MRID 42647601). In the original Agency review, the results for corn, sugarbeet, pea an d cucumber were considered invalid for use due to the study authors’ use of chemicals for sterilization of the soils. Two of the chemicals used in the study, captan and thiram, have since been permitted for use to sterilize soils in the conduct of terrestrial plant studies; therefore the terrestrial plant effects data considered in this assessment now includes the results from corn and pea. Sugarbeet and cucumber seed were also treated with other unapproved compounds ( e.g. , Lindane), so they were not reconsidered in this assessment.

Based on the available seedling emergence and vegetative vigor toxicity data (MRID 42647601), it appears that the vegetative vigor plant growth stage is most sensitive to fosamine ammonium (technical) ( Table 2 and 3 ). At the seedling emergence stage, shoot height was impacted for several species, with onion and oilseed rape being the most sensitive taxa for monocots and dicots respectively (Table 2).

Table 2. Terrestrial Plants Toxicity: Seedling Emergence for Fosamine Ammonium Technical (lb a.i./A) a

Species Endpoint NOEC IC 05 IC 25

Monocots Onion Shoot Height 3.0 0.86 3.55 Corn Shoot Height 24 NC >24 Wheat Shoot Height 24 NC >24

Dicots Sorghum Shoot Height 3.0 3.18 11.6 Soybean Shoot Height 6.0 2.61 8.86 Pea Shoot Height 24 9.86 23.0 Tomato Shoot Height 12 5.71 >24 Oilseed Rape Shoot Height 1.5 0.61 2.29

a NC- not calculable; value either could not be comp uted or was not a realistic value. In cases where

less than 25% effects were ob served the corresponding IC 25 value is represented as ‘greater than’ the highest concentration tested.

Bolded values identify most sensitive taxon within monocots and dicots. Italicized values identify where the IC 05 will be used in lieu of the NOEC

Data are from MRID 42647601.

At the vegetative vigor stage, the most sensit ive species of monocots was corn with an IC 25 of 0.383 lb a.i./A, and the most sensitive dicot was soybean with an IC25 of 0.0994 lbs a.i./A. EPA relied upon the

### 5 IC 05 for both of these species in the RQ calculations. For corn the NOAEC was statistically determined to be 0.375 lb a.i./A.

Table 3. Terrestrial Plants Toxicity: Vegetative Vigor for Fosamine Ammonium Technical (lb a.i./A) a

Species Endpoint NOEC IC 05 IC 25

Monocots Onion Shoot Height 3.0 0.64 6.58 Corn Total Weight 0.375 0.105 0.383 Wheat Total Weight 1.5 0.699 1.865

Dicots Sorghum Total Weight 0.750 0.73 1.63 Soybean Total Weight <0.0938 0.0126 0.0994 Pea Total Weight 1.5 NC >1.5 Tomato Total Weight 1.5 0.830 2.125 Oilseed Rape Total Weight 1.5 0.54 1.174

a NC- not calculable; value either could not be comp uted or was not a realistic value. In cases where

less than 25% effects were ob served the corresponding IC 25 value is represented as ‘greater than’ the highest concentration tested.

Bolded values identify most sensitive taxon within monocots and dicots. Italicized values identify where the IC 05 will be used in lieu of the NOAEC

Data are from MRID 42647601.

Table 4. Estimated Risk Quotients for Plants and Endangered Terrestrial Plants for Ground and Aerial Application of Fosamine Ammonium

Organism Ground Spray (24 lb a.i./A) Aerial Spray (12 lb a.i./A) Adjacent uplands Adjacent

wetlands Drift Only Adjacent uplands Adjacent

wetlands Drift Only

Monocots 0.4 3.4 0.6 0.3 1.9 1.6

Listed

Monocots 0.5 4.1 0.6 0.4 2.2 5.7

Dicots 0.6 5.3 2.4 0.5 2.9 6.0

Listed Dicots 1.0 8.2 19.0 0.8 4.4 47.6

Bold values denote an exceedance of the LOC (=1.0) Results presented are based on the maximum single application rate and the endpoints for the most sensitive taxa presented in Tables 2 & 3.

The distance from the application site where risk to terrestrial plant taxa are no longer of a concern following fosamine ammonium application is greater th an 290 feet for all terrestrial plants when applied by air (Table 6). Coarser droplet spectra reduce the distances; however, for monocots such as corn, the most sensitive monocot tested, risk extends to 115 feet from the field’s edge, and for dicots such as soybean, risk extends to 318 feet. Listed species of dicots are at risk beyond 1000 feet (AgDrift maximum estimated distance = 995 ft) for all aerial and ground application scenarios. Applying by ground spray with coarser droplet sizes reduces the predicted drift distance greatly for monocots (from

### 6 154 to 36 ft) but dicots continue to have RQs above the LOC at 194 ft and greater than 1000 for listed species for fine to medium/coarse droplets.

Table 5. Estimated distance (feet) from the edge of the spray area to the most sensitive monocot or dicot species in the vegetative vigor stage of growth (AgDrift Tier-I) 1

.

Additional Terrestrial Plant Risk Characterization

Open literature toxicity data for ‘target’ terrestrial plant species, which include efficacy studies, are not currently considered in deriving the most sensitive endpoint for terrestrial plants. Efficacy studies do not typically provide endpoint values that are useful for risk assessment ( e.g. , NOAEC, EC 50 , etc.), but rather are intended to identify a dose th at maximizes a particular effect ( e.g. , EC 100 ). However, there are several studies conducted on the efficacy of fosamine ammonium on various tree species at labeled rates, which are qualitatively considered here to inform on the potential for effects on underrepresented species ( e.g. , woody species) in the absence of registrant-submitted plant toxicity data using woody species. A study (Geyer, 1994) conducted in the context of typical rights-of-way vegetation management ( e.g. , including mechanical cutting of br ush or trees along with herbicides) using a typical end-use product that contained fosamine ammonium (combined with a water softener and surfactant) demonstrated a reduction in height as well as percent resprouting when compared to the cut-only control stand. Treated species included American plum, black cherry, black locust, black walnut, boxelder, cottonwood, dogwood, elm, green ash, hackberry, mulberry, redbud, and red and white oak trees. While the magnitude of effects on woody species treated using products containing fosamine ammonium without prior cutting, sensitive woody species may be affected if exposed.

Incidents

As of September 2, 2015, the Ecological Incident Information System (EIIS, version 2.1), which is maintained by the Agency’s Office of Pesticide Programs, returned one terrestrial plant incident in Arkansas attributed to fosamine ammonium use with “possible” certainty, reporting damage to nearby crops (cantaloupe, tomato, and watermelon) from exposure to drift ( Table 6 ). Organism Ground Spray (24 lbs a.i./A) 2 Aerial Spray (12 lbs a.i./A)

Very-Fine

To Fine Fine to Medium/Coars

e Fine to

Medium Medium to

Coarse Coarse to Very Coarse

Monocots 154 36 289 164 115

Listed

Monocots 157 36 295 167 115

Dicots 482 194 >995 522 318

Listed Dicots >995 >995 >995 >995 >995

1 results presented are based on the maximum single application rate and the endpoints for the most sensitive taxa presented in Tables 2 & 3.

2 ground application assumes a high -boom spray application method

### 7 Table 6. Ecological Incidents Associated with Fosamine Ammonium

Incident

Number Taxa

Involved Magnitude Year Location Use Legality of

Use Certainty Category Residues Other

Chemicals

Involved

I015280-

001 Terrestrial

Plant ~ 5 acres 2004 AR Rights of

way Registered

Use Possible None reported None reported

No ecological incidents were reported in the IDS Aggregate Incident Reports’ database maintained by

EPA.

Clean Water Act

Fosamine ammonium is not identified as a cause of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_na tion_cy.cause_detail_303d?p_cause_group_id=885

. In addition, no Total Maximum Daily Loads (TMDL) have been developed for fosamine ammonium, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attains_nati on.tmdl_pollutant_detail?p_pollutant_group_id=885 &p_pollutant_group_name=PESTICIDES. More informat ion on impaired water bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/.

Endangered Species

Consistent with EPA’s responsibility under the Enda ngered Species Act (ESA), the Agency will evaluate risks to federally listed threatened and endangered (lis ted) species from registered uses of pesticides in accordance with the Joint Interim Approaches developed to implement the recommendations of the April 2013 National Academy of Sciences (NAS) report, Assessing Risks to Endangered and Threatened Species from Pesticides . The NAS report outlines recommendations on specific scientific and technical issues related to the development of pesticide risk assessments that EPA and the Services must conduct in connection with their obligati ons under the ESA and FIFRA. EPA will address concerns specific to fosamine ammonium in connection with the developm ent of its final registration review decision for

fosamine ammonium

.

In November 2013, EPA, the U.S. Fish and Wildlife Serv ice, National Marine Fisheries (the Services), and

USDA released a white paper containing a summary of their joint In terim Approaches for assessing risks to listed species from pesticides. These Interim Approaches were developed jointly by the agencies in response to the NAS recommendation s, and reflect a common approach to risk assessment shared by the agencies as a way of addressing scientific differences between the EPA and the Services. Details of the joint Interim Approaches are contained in the November 1, 2013 white paper

, Interim Approaches for National-Level Pesticide Endangered Species Act Assessments Based on the Recommendations of the National Academy of Sciences April 2013 Report.

Given that the agencies are continuing to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticid es to listed species and their designated critical habitat, this ecological problem formulation supporting the Preliminary Work Plan for fosamine ammonium does not describe the specific ESA analys is, including effects determinations for specific

### 8 listed species or designated critical habitat, to be conducted during registration review. While the agencies continue to develop a common method for ESA analysis, the planned risk assessment for the registration review of fosamine ammonium will desc ribe the level of ESA analysis completed for this particular registration review case. This assessment will allow EPA to focus its future evaluations on the types of species where the potential for effects exists, once the scientific methods being developed by the agencies have been fully vetted. Once the agencies have fully developed and implemented the scientific methods necessary to complete risk assessme nts for listed species and their designated critical habitats, these methods will be applied to subsequent analyses of fosamine ammonium as part of completing this registration review.

Endocrine Disruption Screening Program

Fosamine ammonium was not included in the first group of 67 chemicals issued an order to conduct Tier 1 EDSP testing. For additional information on the EDSP, visit http://www.epa.gov/endo/

.

References

U.S. EPA, 1994. Fosamine Ammonium RED . Environmental Fate and Effects Division.

Geyer, W.A., et al. Woody Vegetation Control on Utility Rights-of-Way in Eastern Kansas: I. Management Techniques. Journal of Arboriculture 20(5): 282-286. September 1994. ECOTOX Ref. 116047.

Marrs R.H. Studies on the conservation of lowland Calluna heaths. I. Control of birch and bracken and its effect on heath vegetation. Journal of Applied Ecology, 24, 163-175. 1987. ECOTOX Ref.

### 9 APPENDIX A: TerrPlant v. 1.2.2 Green values signify user inputs (Tables 1, 2 and 4). Input and output guidance is in popups indicated by red arrows.

Table 1. Chemical Identity.

Parameter User Inputs

Chemical Name Fosamine Ammonium

PC code 106701

Use Airports Application Method Ground Spray

Application Form Liquid Solubility in Water (ppm) 1790000

Table 2. Input parameters used to derive EECs.

Input Parameter Symbol Value (user inputs) Units

Application Rate A 24 lbs a.i./A

Incorporation I 1 none Runoff Fraction R 0.05 none

Drift Fraction D 0.01 none

Table 3. EECs for Fosamine Ammonium. Units in lbs a.i./A.

Description Equation EEC

Runoff to dry areas (A/I)*R 1.2 Runoff to semi-aquatic areas (A/I)*R*10 12 Spray drift A*D 0.24 Total for dry areas ((A/I)*R)+(A*D) 1.44 Total for semi-aquatic areas ((A/I)*R*10)+(A*D) 12.24

Table 4. Plant survival and growth data used for RQ derivation. Units are in lbs a.i./A. All values are user inputs

Seedling Emergence Vegetative Vigor Plant type EC25 NOAEC EC25 NOAEC

Monocot 3.55 3 0.383 0.375

Dicot 2.29 1.5 0.0994 0.0126

Table 5. RQ values for plants in dry and semi-aquatic areas exposed to Fosamine Ammonium through runoff and/or spray drift.*

Plant Type Listed Status Dry Semi-Aquatic Spray Drift

Monocot non-listed 0.4 3.4 0.6

Monocot listed 0.5 4.1 0.6

Dicot non-listed 0.6 5.3 2.4

Dicot listed 1.0 8.2 19.0
*If RQ > 1.0, the LOC is exceeded, resulting in potential for risk to that plant group.APPENDIX B. SUMMARY OF AVAILABLE FATE AND TOXICITY DATA FOR FOSAMINE AMMONIUMTable 1. Physical and Chemical Properties of Fosamine AmmoniumCommon name Fosamine AmmoniumChemical name ammonium ethyl carbamoylphosphonatePesticide type herbicideChemical class organophosphonateCAS number 25954-13-6Empirical formula C3H11O4N2PMolecular mass (g/mol) 170.11Vapor pressure4 x 10-6mm Hg (25° C)5.3 x 10-3Pa (25° C)Henry’s Law Constant 5.04 x 10-7PA m3/mol (calculated)Solubility in water1,795,000 mg L-1(20°C)1,790,000 mg L-1(25° C)1Kow0.0012 (0.00104-0.00139)Melting Point173-175qC (tech.)1http://www.invasive.org/gist/products/handbook/13.Fosamine.pdfTable 2. Environmental Fate Data for Fosamine AmmoniumStudy/CurrentGuidelinesValueMajor Degradates1/CommentsMRIDClassificationHydrolysis835.21200, Stable None 40133701 AcceptablePhotodegradationin Water835.22400, Stable None 40133702 AcceptablePhotodegradationon Soil835.24100, Stable None 40133703 Acceptable11LaboratoryVolatility835.1410<0.00631ʅŐͬĐŵ2/hourфϮϮʅŐͬŵ3Fosamine ammonium (2% AR in soil)CPA (max 89% AR in soil)IN-G3003 (max 15% in soil)42492201 AcceptableAerobic SoilMetabolism835.4100t1/2= 0.5 to 12 daysCPA (max 94% AR immediatelyposttreatment)t1/2= 144 daysIN-G3003 (max 26% AR at 1 monthposttreatment)t1/2= 34 daysTotal residue t1/2= 204 days; observedDT50= 220CO2(max at 33% at study termination)42060601141554AcceptableAnaerobicAquaticMetabolism835.4400t1/2= 2 daysCPA (max 59% AR at 14 daysposttreatment)t1/2= 12 daysING-3003 (max 43% AR at 9 monthsposttreatment)CO2(max at 7.6% at 12 months--studytermination)420606024268070142724301AcceptableStudy/CurrentGuidelinesValueMRIDClassificationAdsorption/Desorption(Batchequilibrium)835.1230Soil Kd(mL/g) Koc(mL/g)KF(ad)(ʅg1-1/n(cm3)1/ng-1)1/nKFoc(ʅg1-1/n(cm)1/ng-1)424924014013370442492301AcceptableNew Jerseysandy loam> 1 8.087 0.066 0.8603 ---Woodstownsandy loam0.14 13.249 0.14 0.98 13.249Cecil sandyloam0.11 5.302 0.11 ~1 5.302Flanagan siltloam0.11 2.645 0.11 ~1 2.64512Study/CurrentGuidelinesValueMajor Degradates1/CommentsMRIDClassificationTerrestrial FieldDissipation835.61001 d Lexington, TN1 d Newark, DE5 d Fayetteville, NCFosamine ammonium found predominantly inthe 0 to 15 cm soil samples.CPA (max at 26.7% at six weeks, DE silt loam;max at 40% at six weeks, IL silt loam; and 83%at two weeks, FL sandy loam)40955701 AcceptableFish BCF850.1730No accumulation observed therefore no BCFcould be calculated. A 9% observed mortality.42587601 Acceptable1Major degradates are defined as those that >10% of the applied.13Table 3. Aquatic Toxicity Profile for Fosamine AmmoniumStudy/CurrentGuidelinesTaxonExposureDurationMost SensitiveSpecies TestedToxicity Valuemg a.i./LAcuteToxicityCategory1MRIDClassification/CommentsFish Acute,Freshwater and Marine850.1075Freshwater Fish AcuteRainbow trout,Oncorhynchus mykissLC50= 377Practicallynontoxic41607103 AcceptableFish Acute,Freshwater and Marine850.1075Estuarine/Marine FishAcuteSheepshead minnow,Cyprinodon variegatusLC50= >128Practicallynontoxic42715101 SupplementalAquatic InvertebrateAcute,Freshwater Daphnids850.1010FreshwaterInvertebratesAcuteWater Flea,Daphnia magnaLC50= 1524Practicallynontoxic00143492and92086005SupplementalMysid Chronic850.1350Estuarine/MarineInvertebratesAcute Eastern oysterLC50= >122Practicallynontoxic42715102 SupplementalAlgal Toxicity,Tiers I and II850.5400Non-vascularplantTier IAlga,SkeletonemacostatumEC25= >15NOAEC = 15Slightly toxictopracticallynontoxic42902904 AcceptableAquatic Plant ToxicityTest Using Lemna spp.,Tiers I and II850.4400Vascular plant Tier IDuckweed,Lemna gibbaEC50= >21(EC40= 21)NOAEC = <21Slightly toxictopracticallynontoxic42587602 Supplemental1Categories of acute toxicity for aquatic organisms(U.S. EPA, 2004) based on LC50(mg/L): < 0.1 very highly toxic; 0.1-1 highly toxic; >1-10moderately toxic; >10-100 slightly toxic; >100 practically nontoxic. Toxicity categories for aquatic plants have not been defined.14Table 4. Terrestrial Toxicity Profile for Fosamine AmmoniumGuidelineTaxonExposureDurationMost SensitiveSpecies TestedToxicity ValueAcuteToxicityCategoryClassificationMRIDMammalAcute850.2400MammalsAcuteRatRattus norvegicusWaived; LD50>1954 mga.i./Kg bw (adjusted for97.7% purity) from acuteneurotoxicity study with nodeaths up to HDT1(2000 mgtech/kg bw)PracticallynontoxicAcceptable 42946501ChronicRatR. norvegicusNOAEC = 200 mg/Kg/dLOAEC = 1000 mg/Kg/dN/ASupplemental00075736Avian AcuteOral850.2100BirdsAcute OralNorthernbobwhite quail(Colinusvirginianus)Mallard(Anasplatyrhynchos)PasserineLD50= >5000 mg/Kg bwLD50= >5000 mg/Kg bwnonePracticallynontoxicPracticallynontoxicSupplementalSupplemental0013022500093715Avian Dietary850.2200Sub-acuteDietaryQuail and mallard(C. virginianusandA. platyrhynchos)>5620 ppm dietPracticallynontoxicSupplemental4189160241891603AvianReproduction850.2300ChronicReproductionMallardA. platyrhynchosNOAEC = 11,600 ppmLOAEC = >11,600 ppm(mg/Kg/d)PracticallynontoxicSupplemental 44143501Honey BeeAcute ContactToxicity850.3020TerrestrialInvertebratesAcuteHoney BeeApis melliferaLD50 = >200 ug a.i./beePracticallynontoxicSupplemental 41215802TerrestrialPlant Toxicity,Tier IITier II –SeedlingEmergenceRape, shootlength inhibitionEC25= 2.3EC50= 5.8NOAEL = 1.5 lb a.i./acreN/AAll exceptsugarbeetacceptable4264760115850.4100850.4150VegetativeVigorSoybean, totalweight inhibitionEC25= 0.099EC50= 0.42NOAEL = <0.094 lb a.i./acre436511011HDT = highest dose tested.