### 1 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

Date : September 8 , 2015 PC Code: 071003 MEMORANDUM DP Barcode: D 427108

SUBJECT: Registration Review: Draft Problem Formulation for Environmental Fate, Ecological Risk, Endangered Species, and Human Health Drinking Water Exposure Assessments for Rotenone

TO: Kelly Ballard , Chemical Review Manager Tom Moriarty, Team Leader Neil Anderson, Branch Chief Risk Management and Implementation Branch I Pesticide Re

- Evaluation Division (7508P)

FROM: Thomas Steeger, Ph.D., Senior Science Advisor Cheryl Sutton, Ph.D., Environmental Scientist Environmental Risk Branch IV Environmental Fate and Effects Division (7507P)

REVIEWED BY: Catherine Aubee

, Senior Scientist James Carleton, Ph.D., Senior Fate Scientist Katrina White, Ph.D., Risk Assessment Process Leader Environmental Risk Branch IV Environmental Fate and Effects Division (7507P)

THROUGH: Jean Holmes, D.V.M., M.P.H., Branch Chief Environmental Risk Branch IV Environmental Fate and Effects Division (7507P)



### 1. Executive S ummary

The Environm ental Fate and Effects Division (EFED) has completed the preliminary problem formulation for the ecological risk, environmental fate, endangered species, and drinking water assessments to be conducted as part of the Registration R eview of the pisci cide rotenone ( PC Code 07100 3

. ; C AS No: 83

- 79

- 4 ). The problem formulation describes the methods to be used during the completion of drinking water exposure and ecological risk assessments in support of R egist ration

### 2 R eview and provides an overview of the environmental fate, ecological effects, and potential risks associated with the use of rotenone . It describes uncertainties which may be encountered in the risk assessment and identifies additional studies and other i nformation that would be beneficial to its conduct.



### 2. Introduction

Rotenone is an isoflavone pesticide used to kill fish ( i.e. , as a piscicide) in fisheries management. Although it was historically also used on cranberries; as an insecticide to control aphids, thrips, suckers, moths, and beetles in organic fruit and vegetable crops ; as an insecticide/acaricide to control fire ants, for lice/tick control on pets ; and for warble fly control on livestock, these uses have all be en voluntarily cancelled by the technical registrants 1



### . Rotenone is a R estricted U se piscicide derived from the roots of tropical plants in the pea and bean family ( Leguminosae ) including jewel vine ( Derris spp.) and lacepod ( Lonchocarpus spp.) found in A ustralia, Oceania, southern As ia, and South America 2



### . The restricted use classification is based on the acute inhalation, acute oral and aquatic toxicity of the compound (USEPA 2007 3 

### ). The mechanism of action has been well documented and it is understood that rotenone uncouples oxidative phosphorylation by blocking electron transport at complex I within the mitochondria.

Rotenone is labeled for direct applications to mountain streams, lakes, ponds and fishery management operations

. Rotenone has been used to restore Federally

- listed threatened/endangered (listed) fish to their native habitats by eliminating competing fish

.

EFED examined the most recent environmental fate and ecological risk assessment

, 4 

### written in support of the March 2007 Re

- registration Eligibility Decision (RED) of rotenone

, 5 

### in association with updated toxicity, exposure, and usage information to determine if additional data are needed to support the R egistration R eview of rotenone . In addition, EFED considered the latest Agency science policies and risk assessment methodologies. Since the RED, th ere has been an assessment to determine the risks from rotenone use to the federally threatened California red

- legged frog ( Rana aurora draytonii ) as well as a FIFRA Sectio n 18 emergency exemption petition 6 

### submitted for the use of an unregistered formulation of rotenone as a piscicide

.

1 Cancellation orders for amendments to terminate uses: rotenone. http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPP

2005

- 0494

- 0065

2 Finlayson, B. J., R. A. Schnick., R. L. Cailteux., L. DeMong., W. D. Horton , W. McClay , C. W. Thompson, and G. J. Tichacek.. 2000. Rotenone Use in Fisheries Management: Administrative and Technical Guidelines Manual. American Fisheries Society, Bethesda, Maryland.

3 USEPA. 2007. Reregistration Eligibility Decision for Rotenone. Office of Ch emical Safety and Pollution Prevention formerly the Office of Prevention, Pesticides and Toxic Substances (7509P). EPA 738

- R

- 005. March 2007. Available on line at: http://www .epa.gov/oppsrrd1/reregistration/REDs/rotenone_red.pdf

4 USEPA. 2006. Environmental Fate and Ecological Risk Assessment Chapter (DP barcode D307382) n Support of Phase IV of the Reregistration Eligibility Decision on Rotenone (PC Code 071003) . Availab le on line at: http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPP

- 2005

- 0494

- 0031

5 Ibid USEPA. 2007.

6 USEPA. 2014. Review of Presidio Trust Section 18 Emergency Exe mption Request for Use of CFT Le gumine 3.3% (Rotenone) to Eradicate Invasive Fish in Mountain Lake, San Francisco, California (PC Code 071003; DP Barcode D421307). Dated July 15, 201 3.

### 3 3. Use Characterization

Rotenone has been used by fishery managers since the 1950s in the U.S. to kill fish in coves, shorelines, rivers and streams, and some estuarine habi tats 7 

### . Rotenone is typically applied to a surface water body as a piscicide in conjunction with a fisheries management or research program. Applicators must consult their local state Fish and Game Agency before applying ro tenone products 8 

### . In addition, the following use restrictions are typically recommended, although not required, when rotenone is applied to surface waters: (1) fish killed by using rotenone may not be consumed by people ; (2) water treated with rotenone ma y not be used to irrigate crops; and (3)
rotenone

- treated water may not be released within one

- half mile upstream of a drinking water supply intake or irrigation water intakes. Drinking water restrictions do not apply to municipalities that have an altern ative potable raw water source that may be used until rotenone has dissipated from the treated water supply 10



### .

Based on information from chemical profile on rotenone developed by the Biological and Economic Analysis Division (BEAD), r otenone is formulated as a dust, liquid, emulsifiable concentrate, and wettable powder (USEPA, 2015) . Dust formulations must be mixed as a slurry to be applied to water surface by dragging equipment to release product behind a boat below the water surface. Applications can be made with aircraft, backpack sprayer, drip can, or handheld or hand

directed nozzle to the water surface.

In lotic environments such as streams and rivers, rotenone is applied through drip stations or sprayers where the moving water carries the rotenone d ownstream. In lentic environments such as lakes, reservoirs and ponds, rotenone is typically pumped through a hose into the propeller wash of an outboard motor in order to distribute the chemical uniformly through the water column.

Rotenone has been used extensively as a piscicide throughout the United States. By the mid

- 1980s, its greatest use was in the management of warm water fisheries in the Southeast and cool water fisheries of the Midwest and Mountain states (MRID 4558010

- 73). According to a survey conducted by the American Fisheries Society, during the period of 1988 to 2002 rotenone was used for fisheries management in 38 states and five Canadian provinces ; e leven states and one Canadian province accounted for 89% of rotenone applications to surface waters in North America 9



### . Approximately 97% of rotenone applications during this period were made to standing waters (ponds and lakes). Reported uses were grouped into the following five categories, reflecting different fisheries management obje ctives: (1) obtain a sample of representative fish species and sizes to characterize fish populations ( i.e ., sampling; 34%); (2) manipulate fish populations to maintain desirable fish species for sport fisheries ( e.g ., reducing the density of planktivorous fish) (27%); (3) treat rearing ponds (17%); (4) remove exotic species (10%); and (5) restore threatened and endangered species (7%). Formulated products used in lentic environm en ts w ere roughly equally split between rotenone powder (53%) and liquid (47%) 10



### .

Similar to other piscicides, rotenone is a restricted use product (RUP) and the chemical has relatively detailed standard operating procedures (SOPs)

, developed by the American Fisheries

7 B ettoli, P. W. and M. J. Maceina. 1996. Sampling with toxicants. Pages 303

- 333 in B.R. Murphy and D.W. Willis (editors), Fisheries Techniques, American Fisheries Society, Bethesda, MD.

8 U.S. EPA. 1988. Rotenone EPA Pesticide Fact Sheet 10/88. Fact Sheet Number 198. Available on

- line at http://pmep.cce.cornell.edu/profiles/insect

- mite/propetamphos

- zetacyperm/rotenone/insect

- prof

- roten one.html

9 McClay W. 2005. Rotenone use in North America (1988

- 2002). Fisheries. 30(4): 29

- 31.

10 Ibid McClay 2005.

### 4 Society

, and associated with its use to renovate /restore fish populations 11 

### . Since the SOPs are linked to ( i.e., specified on) the federal label, they are considered part of the label and must be followed by the end user. The current SOP (USDOI 2010) states that, “ The flow of a stream or outflow of a treated l ake beyond the treatment area now requires chemical deactiv a tion with potassium permanganate unless it is demonstrated to be unnecessary

. ” An example of a situation in which deactivation would not be conducted is when it is deemed unfeasible, such as when the stream flow goes into a canyon (or other physical limitation) or “ if there is no discharge from the Treatment Area or the discharge goes dry in a distance shorter than 2 miles or 2 hours travel

- time (maximum distance/time between drip stations recommended on label) from the lowest drip station .” For the first scenario, “ the Certified Applicator through bioassay or analytical testing assures that the discharge is no longer toxic at 30 minutes travel time downstream of where the stream emerges at an accessible location and deactivation could be accomplished .” Examples of the latter scenario include ponds or lakes with no discharge or a stream that goes dry within two miles of the treatment area. An additional scenario in which deactivation is not required is when dilution of untreated waters renders “ undetectable concentrations ” ( i.e ., <2 ppb) in discharge
waters. Regardless of whether the compound is deactivated, bioassays are typically conducted and cages containing sent i nel species (typically the target fish species) are placed downstream of treated waters to ensure that the chemical does not substantially move outside of the targeted treatment

area.

11 Finlayson, B. J., R. A. Schnick., D. Skaar, J. Anderson, L. Demong, D. Duffield, W. Horton, and J. Steinkjer

. Planning and Standard Operat ing Procedures for the Use of Rotenone in Fish Management. Rotenone SOP Manual. Amer ican Fisheries Society Fish Management Chemicals Subcommittee. American Fisheries Society, Bethes da, Maryland. Available on line at: http://www.fisheriessociety.org/rotenone/rot.pdf

### 5 4. Conclusions from Previous Risk Assessments

The ecological risk assessmen t written in support of the RED document for rotenone was issued in September 2006 12 

### . Based on the previous analysis of the environmental fate, ecotoxicity, an d registered uses of rotenone

, exposure to the compound result ing from the maximum treatment concentration is expected to kill fish , aquatic

- phase amphibians, and aquatic invertebrates in the immediate treatment area. However, in lotic environments the compound is typically deactivated with a strong oxidizing agent ( e.g. , potassium permanganate; KMnO 4 

### ) to ensure that it does not move outside of the intended treatment area. Based on the most sensitive species and at the maximum treatment concentration, risk quotient (RQ) values exceed acute risk levels of concern (LOCs) by several orders of magnitude

.

While the conclusions presented below represent the most recent assessments, there have been changes made in the SOP that will affect the new assessment s . The major changes are :

• Maximum Rotenone Treatment Levels

— The maximum treatment level in standing waters

was reduced from 250 to 200 ppb rotenone (a.i.), and the maximum treatment level in flowing water was increased to 200 ppb rotenone (a.i.). For all applications, the selected treatment rate is based on response of target fish (or surrogate species) in a bioass ay with site water (or in similar water) within the maximum level on the label (SOP 5).

• Chemical Deactivation of Treated Flowing Water

— The flow of a stream or outflow of a treated lake beyond the treatment area now requires chemical deactiv a tion with pota ssium permanganate unless it is demonstrated to be unnecessary (SOP 7). The deactivation zone and other areas affected by the treatment are included in the definition of a project area (SOP 6).

**a. Ecological**  **Risk Assessment**

The major environmental fate and e cological risk conclusions presented in ecological risk
assessment s 13 

### in support of the RED (when the maximum treatment concentration was 250 μg/L

, rather than the current 200 μg/L ) were as follows:

T he use of rotenone as a piscicide is intended to kill target species. The chemical’s use at a treatment site is intended to kill fish and at maximum application rates (250 μg/L), exceeds the acute risk level of concern by factors of 206X and 108X for freshwater fish and invertebrates, respectively. Maximum treatment concentrations exceed the upper 95 th 

### percentile of 96

- hr median lethal concentrations for freshwater fish species sensitivity distribution . The extent of acute mortality that will be inflicted on aquatic animals within a treatment area is uncert ain; however, acute effects are expected. At the maximum application rate in cold water, the chronic risk level of concern is exceeded for freshwater fish and invertebrates by factors of 175X and 153X, respectively. To the extent that lower application r ates are used and that less sensitive species are present than those used to evaluate risk in this assessment, acute mortality among non

- target aquatic animals may be substantially lower.

Benthic macroinvertebrate monitoring data indicate that repeated yearly rotenone treatments conducted in mountain streams in California did not substantially reduce aquatic invertebrate abundance and that aquatic communities tended to return to pretreatmen t conditions one to two

12 Ibid USEPA 2006.

13 Ibid USEPA 2006.

### 6 years after treatment; whether these aquatic communities achieved species diversity similar to pretreatment conditions is uncertain. The likelihood of chronic exposure following the treatment of streams is considered low since rote none is typically applied only once per year and the chemical is continually diluted via displacement by inflowing water and , and by abiotic degradation ; however, is lentic systems where rotenone is not intentionally deactivated and where only a portion of the water body has been treated, there is potential for chronic exposure . The extent to which rotenone’s use as a piscicide will affect aquatic animals outside of the treatment area depends on the extent to which the chemical moves beyond the treatment a rea. Although not required by the label, relatively rigorous application and monitoring efforts may be conducted by resource managers using this compound and standard operating procedures typically recommend that rotenone be deactivated with potassium per manganate when there is a likelihood that the piscicide will move outside of the treatment area ( e.g ., see SOP 7 on Determining Need and Methods for Chemically Induced Deactivation 14 

### ) . Additionally, rotenone is a restricted use pesticide when used to kill fish. These procedures and practices would reduce the risk of non

- target aquatic animal mortality by limiting the movement of rotenone outside of treatment areas to the extent possible. The use of potassium permanganate to deactivate rotenone can result in acute toxicity as well for aquatic organisms which are in close proximity to the deactivation station. A more detailed analysis of the risk associated with potassium permanganate alone is contained in the 2006 risk assessment 15 

### and the reader is referred to that assessment.

Since rotenone is applied directly to water, the risk of terrestrial animal acute mortality is considered low since there are not likely to be any rotenone residues on terrestrial animal forage items. Altho ugh no specific application protocol is required, in cases where application protocols require that dead and/or dying fish be collected and buried, there is reduced opportunity for either birds or mammals to consume fish that may contain rotenone residues. However, even if birds or mammals were to consume fish killed by rotenone, there would be insufficient quantities of rotenone in the carcasses to represent a risk of acute mortality in terrestrial animals. Since fish are either collected or shortly sink to the bottom of treated water and rapidly decompose, the likelihood of chronic exposure through the diet of terrestrial animals is also considered to be low.

In addition, effects on threatened and endangered species may be an important consideration fo r site

- specific applications that are co

- located with critical habitat. Rotenone is an important chemical used in recovery efforts for endangered salmonid s pecies by eliminating competing species. Monitoring may be conducted by resource managers prior to and after the use of rotenone as a piscicide. It is not considered likely that these resource managers would disregard the presence of an endangered/threatened species in a projected treatment area.

Previously, a cute and chronic risk to estuarine/mari ne fish and invertebrates could not be determined because toxicity data were not available, and the possibility of risk from acute or chronic exposure to th ese receptors could not be precluded . However, the RED 16 

### stipulated that rotenone labels had to be up dated to prohibit use in estuarine/marine environments. Also, an evaluation of risk to aquatic plants could not be conducted since there were no pertinent toxicity data and the possibility of risk from exposure in treated waters could not be precluded.

14 American Fisheries Society. 2010. Determining Need and Methods for Chemically Induced Deactivation SOP 7 In Finlayson et al

. Planning and Standard Operating Procedures for the Use of Rotenone in Fish Management

. Rotenone SOP Manual . American Fisheries Society Fish Management Chemicals Subcommittee. http://www.afsbooks.org/55061P 15 Ibid USEPA 2006.

16 Ibid USEPA. 2007

### 7 **b. Dr**  **inking Water Exposure Assessments**

EFED conducted a drinking water assessment of rotenone 17 

### in 2005 as part of the RED process. The most conservative acute concentration s w ere considered as the maximum treatment concentration s , at the time of the assessment, of 25 0 μg/L and 50 μg/L for lakes and rivers, respectively . Chronic exposure values were not estimated for the piscicidal uses given that the compound was intentionally deactivated in some environments . However, based on the previous ly registered agricultural uses, which have subsequently been cancelled, the peak, annual mean and overall mean drinking water exposure concentrations were 1.83 and 0.0049 and 0.0028 μg/L

, respectively 18



### .

**c. Clean Water Act Programs** 

Rotenone is not identified a s a cause of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act. No Total Maximum Daily Load s (TMDL s ) or water quality criteria have been developed for rotenone

. 19



### 5. Environmental Fate and Transport

Rotenone or (6R , 6aS, 12aS)

- 1,2,6,6a,12,12a

- hexahydro

- 2

- isopropenyl

- 8,9

- dimethoxychromenyl[3,4

- bfuro[2,3

- h]chromen

- 6

- one, is a biochemical related to and derived from isoflavonoid compounds by plants. Rotenone has three chiral centers, and only one of the eight possib le stereoisomers is actually produced by plants. As with other stereoisomers, the environmental fate and biological effects can be influenced by the relative positions of atoms around chiral centers.

The physical and chemical properties that determine th e fate and transport of rotenone are detailed in Table 1 . The environmental fate data set for rotenone is incomplete, as the majority of studies submitted previously do not meet the current standards for environmental fate guideline data requirements (OCSPP Series 835)

. Based on available data, r otenone has a relatively low potential
to bioconcentrat e in aquatic organisms (BCF <30). Based on its estimated low vapor pressure and estimated low Henry’s Law constant

, rotenone is not expected to volatili ze

. When applied to water, rotenone is expected to hydrolyze, but data are required to accurately determine the rates at which this will occur at various environmental pH levels

, and to characterize the transformation products. Based on information available in the literature, aqueous photolysis may also occur, but acceptable guideline data have not been submitted to address this degradation
route

. The extent of degradation t hrough biotic mechanisms is unknown since no accepta ble metabolism data a re available to assess this potential route of degradation. Rotenone is expected to partition somewhat to the sediment phase of an aquatic environment, although the extent to which that will occur is unclear, as the submitted adsorpti on/desorption data do no t meet guideline requirements.

Although a n acceptable guideline aquatic field dissipation study has not been submitted, supplemental information is available through submitted studies on the aquatic dissipation of

17 USEPA. 2005. Drinking Water Exposure Assessment for Rotenone. DP Barcode D320702. Dated September 15, 2005. Available on line at: http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPP

- 2005

- 0494

- 0009

18 Ibid USEPA. 2005.

19 USEPA. 2015. Watershed Assessment, Tracking and Environmental Result s. Specific State Causes of Impairment that Make Up the National Pesticides Cause of Impairment Group. http://iaspub.epa.gov/tmdl_waters10/attains _nation_cy.cause_detail_303d?p_cause_group_id=885 \

### 8 rotenone (at 250 ppb) in two experimental ponds in Wisconsin that were maintained at two different temperatures (5 o 

### C and 23

– 27 o 

### C). Rotenone dissipated from the water column with half

- lives of 23 hrs in the cold water pond and 10.6 hours in the warm

- water pond ( Acc. # 0 0157851/T RID 4701520

- 10). Rotenone degraded from the entire system (water + sediment) with half

- lives of approximately 20 days in the cold

- water pond and 1.5 days in the warm

- water pond. Only the parent was assessed in this study. As would be expected, all the resident fish in the ponds died shortly after the initial application. After 7 days in the cold

- water pond and 1 day in the warm

- water pond, fat

- head minnows ( Pimephales promelas ) were placed in the pond in cages until 9 of 10 survived for 24 hours. T his occurred after 4 days in the warm pond and 30 days in the cold

- water pond. Notably, the pH near 8.5 in both ponds would have been expected to result in fairly rapid hydrolysis of rotenone based on available information

. While this occurred in the warm

- water pond, it did not in the cold water pond , suggesting that rotenone degradation may slow substantially in cool er environments.

Much of the concentration data related to the application of rotenone to California’s Lake Davis to control northern pike ( Esox lucius ) was collected in 1997 (California Department of Fish and Game, 1999). Lake Davis , which is in the Plumas National Forest, has a surface area of 4030 acres and a normal capacity of 84,370 acre

- feet. The dataset can be used to estimate the dissipation rate of rotenone from Lake Davis after the initial application, which was made on October 17, 1997 ( rather late in the season for rotenone application ) when the water was fairly cold (9 o 

### C). Measurements

wer e made at nine sites on each of six time periods extending out to 25 d post

- application. The mean concentration of rotenone in the lake on the day of application was 45 μg∙L

- 1



### . A control sample taken prior to application showed that no rotenone or rotenol one was present. Rotenone dissipated from the reservoir with a half

- life of 10.3 d (USEPA

, 20 08) . A pproximately 55% of the rotenone formed rotenolone. Rotenolone dissipated with a half

- life of 5.5 d. Some portion of the dissipation of both rotenone and ro tenolone would have been due to discharge from the lake; the volume of discharge was not reported.



### Table 1. Chemical Properties and Environmental Fate Parameters of Rotenone.

Chemical/Fate Parameter Value Description/Comments Source (MRID)

Selected Physical/Chemical Parameters

Chemical name (6R, 6aS, 12aS)

- 1,2,6,6a,12,12a

- hexahydro

- 2

- isopropenyl

- 8,9

- dimethoxychromenyl[3,4

- bfuro[2,3

- h]chromen

- 6

- one  ̄  ̄

Rotenone CAS Number 83

- 79

- 4  ̄  ̄
SMILES Notation COc5cc4OCC3Oc2c1CC(Oc1c cc2C(=O)C3c4cc5OC)C(C)=C  ̄  ̄

Molecular formula C 23 H 22 O 6  ̄  ̄

Molecular mass 394.4 g mol

- 1

 ̄ Tomlin, 1994 20

Vapor pressure ( 25 ° C ) 6.9 x 10

- 10 Torr Not likely to volatilize. EPISuiteTM v4.11

Water solubility ( 2 0 ° C ) 0.2 mg/L  ̄ Augustijn

- Beckers, 1994 21

20 Tomlin, C. 1994. Pesticide Manual 10 th edition. British Crop Protection Council. The Royal Society of Chemistry, Cambridge U.K.

21 Augustijn

- Beckers P, A. G. H ornsby , and R. D Wauchope . 1994. The SCS/ARC /CES pesticide properties database for environmental decision

- making. Additional compounds. Rev. Environ. Contam. Toxicol. 137:1

- 82.

### 9 Chemical/Fate Parameter Value Description/Comments Source (MRID)

Octanol

- water partition coefficient ( Log K OW ) 4.10  ̄ Hansch et al ., 1995 22

Henry’s Law Constant (25°C) 1.1x10

- 13 atm

- m 3 mol

- 1 Not likely to volatilize from moist soil or water. EPISuiteTM v4.11

Persistence
Hydrolysis half

- life (days; 25 ° C ) No data.  ̄  ̄

Aqueous photolysis half

- life (25 ° C) No data.  ̄  ̄

Soil photolysis half

- life (25 ° C) No data. Not required for aquatic

use. ˗

Aerobic soil metabolism half

- life (25°C) No data.  ̄  ̄

Anaerobic soil metabolism half

- life (25°C) No data. Not required for aquatic

use. ˗

Aerobic aquatic metabolism half

- life ( 25°C ) No data.  ̄  ̄

Anaerobic Aquatic half

- life ( 25°C ) No data.  ̄  ̄

Mobility

S oil

- water partition

coefficients (K d ); No data.  ̄  ̄

Or ganic carbon

- normalized

soil partition coefficients (K FOC ) No data.  ̄  ̄

Field Dissipation

Aquatic field dissipation half

- life 1.5 days (5 °C ) 20 days (23

- 27 °C )

10.3 days (parent) 5.5 days (rotenolone)  ̄ Acc. # 00157851 (TRID 470152

- 010)

MRID 42217701

Fish Bioconcentration

Fish bioconcentration factors (steady

- state) 10.8 X (viscera) 27.9 X (head) 27.6 X (carcass)  ̄ USEPA 2008
(Acc.#’s 146183, 143252)

22 Hansch, C., A. Leo, and D. Hoekmann. 1995. Exploring QSAR. Hydrophobic, Electronic, and Steric Constants. ACS Prof Ref Bo ok. Heller SR, consult. ed., Washington, DC: Amer Chem Soc.Hazardous Substances Data Bank (HSDB). 2004. Available through TOXNET, NLM. http://toxnet.nlm.nih.gov/.

### 10 **a. Transformation Products**  The major degradate of rotenone , previously identified in submitted studies, is 6 αß, 12 αß

rotenolone

, which is structurally similar to the parent compound. Identification of additional degradates may occur once acceptable environmental fate data are submitted.



### 6. Receptors

The most sensitive aquatic and terrestrial toxicity data for rotenone are summarized in Table s 2 and 3 , respectively . Within each of these very broad taxonomic groups, an acute and/or chronic endpoint is select ed from the available test data and is used as a denominator in ratios comparing point estimates of exposure to point estimates of effect

.



### Table 1 . Rotenone toxicity values (μg a.i./L) for aquatic organisms.

Species Toxicity
Value (μg a.i./L) Effects Endpoint Exposure Duration Toxicity Classification Reference (classification)

Acute toxicity

Freshwater Fish Rainbow Trout ( Oncorhynchus mykiss ) LC 50 = 1.94
98% a.i. Survival 96

- hour Very highly toxic MRID 439751

- 02 23 (Acceptable)

Freshwater Invertebrates Daphnid

( Daphnia magna ) EC 50 = 3.7
96.5% a.i. Survival 48

- hour Very highly toxic MRID 400633

- 03 24 (Supplemental)

Estuarine/Marine Fish No data

Estuarine/Marine

Invertebrates No data

Aquatic Plants No data
Chronic Toxicity

Freshwater Fish Rainbow Trout ( Oncorhynchus mykiss ) NOAEC = 1.01
96.5% a.i. Growth 32

- day NR MRID 400633

- 02 25 (Supplemental)

Freshwater Invertebrates Daphnid

( Daphnia magna ) NOAEC = 1.25
96.5% a.i. Reproduction 21

- day NR MRID 400633

- 03 26 (Supplemental)

23 Sousa, J. 1996. Crystalline Rotenone

-- Acute Toxicity to Rainbow Trout ( Oncorhynchus mykiss ) Under Flow

- Through Conditions: Lab Project Number: 10824.0625.6119.108: 95

- 10

- 6154: 051995/FIFRA/108. Unpublished study prepared by Springborn Laboratories, Inc. 70 p. MRID 439751

- 01.

24 Rach, J., T. Bills, an d L. Marking. 1986. Rotenone

-- Acute LC 50 Freshwater Invertebrate

-- Daphnia: TOX 83

- 626/01A. Unpublished study prepared by U.S. Fish and Wildlife Service. 26 p. MRID 400633

- 03.

25 Bills, T., J. Rach, and L. Marking. 1986. Rotenone

-- Fish Early Life Stage

-- Rain bow Trout: Laboratory Project ID; TOX 83

- 626.01B. Unpublished study prepared by U.S. Fish and Wildlife Service. 15 p. MRID 400633

- 02.

26 Rach, J. J., T. D. Bills, and L. L. Marking

. 1986. Rotenone

– aquatic invertebrate life cycle

— Daphnia. U.S. Fish and Wil dlife Service,

### 11 Species Toxicity
Value (μg a.i./L) Effects Endpoint Exposure Duration Toxicity Classification Reference (classification)

Estuarine/Marine Fish No data

Estuarine/Marine

Invertebrates No data

NR = not relevant; EFED has not established toxicity classifications for chronic endpoints.



### Table 2 . Rotenone toxicity values for terrestrial organisms.

Species % a.i. Toxicity Value Toxicity Category Reference Study Classification

Mammalian Acute Oral Toxicity

Rat ( Rattus norvegicus ) 99.2% LD 50 : 102 mg a.i./kg (Males) 39.5 mg a.i./kg (Females) Highly toxic Acc. 00145496 27 Acceptable

Mammalian Chronic Toxicity

Rat ( Rattus norvegicus )

Two

- generation reproductive study 97.9% NOAEL = 7.5 mg/kg (0.5 and 0.6 mg/kg/day for males and females, respectively)

based on decreased body weight and body

weight gain NA Acc. 00141408 28 Acceptable

Avian Acute Oral Studies

Mallard duck ( Anas platyrhynchos ) 32.4 % LD 50 = 2200 mg/kg bw Practically nontoxic Acc. 143250 29 Supplemental

Ring

- necked pheasant ( Phasianus colchicus ) 32.4 LD 50 = 1680 mg/kg bw Slightly toxic MRID 143250 30 Supplemental

Avian Subacute Dietary Studies

National Fisheries Research Center, LaCrosse, Wisconsin

27 Eiseman, J. and A. Thakur. 1984. General Metabolism Study for Safety Evaluation of Rotenone using Rats. Project No. 419

- 137. Unpublished Study Prepared by Hazleton Laboratories, America, Inc. 311 p. Accession number: 000145496.

28 Kehoe, D, K. MacKenzie. 1983. Reproduction Study for Safety Evaluation of Rotenone Using Rats. Final Report. Study No 81077. Unpublished study prepared by Hazleton Raltech, Inc. 732p. Accession number: 000141408.

29 Tucker, R. 1968. Rotenone: [Acute Oral Toxicity to Mallard Ducks and Ring

- necked Pheasants]. Unpublished study prepared by U.S. Fish and Wildlife Service, Denver Wildlife Research Center. 8 p. Accession number: 000143250.

30 Ibid Tucker 1968.

### 12 Species % a.i. Toxicity Value Toxicity Category Reference Study Classification

Mallard duck (Anas platyrhynchos ) 34.5 5

- day LC 50 : 2600 mg/kg diet Slightly toxic Acc. No. 248788 31 Supplemental

Ring

- necked pheasant ( Phasianus colchicus ) 34.5 5

- day LC 50 : 1608 mg/kg diet Slightly toxic Acc. No. 248788 32 Supplemental

Japanese quail ( Coturnix japonica ) 34.5 5

- day LC 50 : 1882 mg/kg diet Slightly toxic Acc. No. 248788 33 Supplemental

Honey bee Acute Contact Toxicity
Honey bee ( Apis mellifera ) > 95 LD 50 : > 60 μg a.i./bee Practically

non

- toxic Acc. No. 05001991 34 Acceptable

Honey bee ( Apis mellifera )/
48 hour Technical 2.4 μg a.i./bee elicited 12%

mortality Moderately toxic Acc. No. 00036935 35 Supplemental



### a. **Ecological Incidents**

The Ecological Incident Information System (EIIS) is an internal OPP database that houses ecological incidents that have been reported to the Agency. When available, EIIS includes date and location of an incident, type and magnitude of effects observed in various species, use(s) of pesticides known or suspected of cont ributing to the incident, and results of any chemical residue analysis or other analyses conducted during incident investigation. EIIS incidents are categorized according to the relative certainty that the incident resulted from pesticide exposure. A sea rch of the EIIS for ecological incidents run on February 19 , 2015

, identified six incident reports which were reported over the period from 1977 to 1999. Three of the incidents were classified as having occurred as a result of misuse of the compound while for the remaining three the legality of use was undetermined. All but one of the reported incidents involved the loss of fish; however, one incident reported the loss of swans and geese. Since the incident occurred several days after the rotenone was ap plied, the report indicated that it was “unlikely” that the loss was associated with the rotenone application. I ncidents may have occurred due to rotenone exposures but may not have been reported due to various factors, such as a lack of reporting, or a lack of o bservation of effects. Therefore, t he lack of incident reports does not necessarily indicate the absence of incidents ; however, the restricted use status of the compound coupled with its detailed SOPs may limit the extent of unintended exposure

.

31 Hill, E. F., R. G. Heath, J. W. Spann and J. D. Williams. 1975. Lethal dietary toxicities of environmental pollutants to bi rds. U. S. Fish and Wildlife Service, Special Scientific Report Wildlife No. 191. Washington, D. C. Accession n umber: 000248788.

32 Ibid Hill et al . 1975. 33 Ibid Hill et al . 1975.

34 Stevenson, J. H. 1978. The Acute Toxicity of Unformulated Pesticides to Worker Honey Bees ( Apis mellifera L.). Plant Pathology 27(1): 38

- 40. Accession number: 005001991.

35 Atkins, E. L., E. A. Greywood and R. L. Macdonald. 1975. Toxicity of Pesticides and Other Agricultural Chemicals to Honey

Bees: Laboratory Studies. University of California, Department of Entomology, U.C. Cooperative Extension (Leaflet 2287) 38p. Accession nu mber: 00036935.

### 13 No plant or wildlife incidents have been reported through OPP’s aggregate incident report database and no avian incidents have been captured in the Avian Incident Monitoring System (AIMS; American Bird Conservancy 2013 ) 36 

### as of February 10, 2015

. The AIMS database contains publicly available reports on pesticide

- related avian incidents through 2005.



### 7. Exposure Pathways of Concern

For a pesticide to pose an ecological risk, it must reach ecological receptors in biologically significant concentrations. An exposure pathway is the means by which a pesticide moves in the environment from a source to an ecological receptor. For an ecological pathway to be comple te, it must include a source, a release mechanism, an environmental transport medium, a point of exposure for ecological receptors, and a feasible route of exposure.

When used as a piscicide, rotenone is applied directly into

, or on to the surface of

, a re ceiving water body , which may be a stream, pond, or lake/reservoir. Once in the water column, non

- target aquatic organis ms may be exposed to rotenone via three main exposure pathways and two minor pathways.

1. Rotenone will initially be distributed in the water column of the receiving water, and organisms in the water column (aquatic invertebrates, fish, amphibians and plants) may be directly exposed through contact. Organisms can take up soluble rotenone through the g ills or integument. This is expected to be the ir main route of exposure to rotenone. If sufficient concentrations exist, then individual toxic effects in aquatic invertebrates, fish, aquatic

phase amphibians and/or plants can result. This may result in reductions in populations of species within these taxa.

2. Rotenone released into water will likely sorb to sediment and suspended solids. Receptors such as aquatic invertebrates, fish, and aquatic

- phase amphibians may be exposed to sorbed
rotenone through incidental ingestion of or contact with sediment and/or suspended solids. This can result in changes in population s ize from reduced survival, growth and reproduction.

3. Rotenone may sorb to plant surfaces. Ingestion of plant m aterials with sorbed rotenone can result in a similar exposure pathway as described for sediment and suspended solids. Nonvascular or vascular plants may also be exposed to rotenone through direct contact or root uptake. This could result in changes in plant populations due to direc t toxicity. However, since no plant toxicity data are availab le for rotenone , potential risks to aquatic plants cannot be evaluated.

4. Rotenone residues may accumulate in target and non

- target organisms, although this is not considered likely given the l ow estimated bioconcentration factor. Other organisms that live in or around the treatment ar ea may be exposed to rotenone by consuming treated organisms.

5. Direct exposure of terrestrial animals/plants to rotenone is not likely since the chemical is only applied to water bodies. Indirect exposure to both mammals and birds is possible through the consumption of dead and dying fish and larger invertebrates an d through

36 Available at: http://www.abcbirds.org/abcprograms/policy/toxins/aims/aims/index.cfm

### 14 ingestion of rotenone

- treated water or through ingestion of plants or aquatic animals in
t reated areas

. Given that aerial application are permitted on some labels, spray drift may also serve as a potential route of exposure.

Environmental fate data suggest (but have not clearl y demonstrated) that rotenone has low potential
to volatilize ; thus

, the likelihood of inhalation exposure is considered low

. The compound is applied directly to water ; therefore, the opportunity for inhalation exposure in birds is considered low.

Potential exposure through ingestion of rotenone

- treated water was evaluated using the Screening Imbibition Program (SIP; version 1.0). The model is intended to provide an upper bound of exposure to birds and mammals to pesticides through drinking water alone. Results from the Excel ®



### - based tool are provided in Appendix C and indicate that drinking water exposure alone is not a potential concern for acute risk to birds or mammals . The available data also indicate that exposure through drinking water is not a potential concern for chronic risk to mammals; however, since n o chronic toxicity data are available for birds, there are insufficient data to preclude chronic risk.



### 8. Analysis Plan

In order to address the risk hypothesis, the potential for adverse effects on the environment is estimated. The use s , environmental fate, and ecological effects of rotenone are characterized and integrated to assess the risks. This is acco mplished using a risk quotient ( i.e
., ratio of exposure concentration to effects concentration) 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.

This analysis plan may be revised depending upon the info rmation submitted by the public in response to the opening of the Registration Review docket for rotenone

.

**a. Stressors of Concern** 

i. Ecological Risk Assessment

The stressors of concern are as follows:

• Terrestrial and Aquatic Environment s : rotenone (parent on ly ) at this time. However, submission of new data which identifies and quantifies environmental degradates may lead to determination of additional compounds which will be included as stressors of concern in the ecological exposure estimates. These data wi ll be considered along with the requirement for deactivation of the parent compound in flowing waters or standing waters that have a means of discharge.

ii. Drinking Water

A new drinking water assessment ( DWA ) will be conducted for the Registration Review of
rotenone to incorporate the changes to the maximum treatment concentrations as stated in the new SOPs (USDOI 2010) . EFED conducted a drinking water assessment for rotenone in 2005 in which the most conserv ative acute concentration was considered the maximum treatment concentration

### 15 of 250 μg/L and 50 μg/L for lakes and rivers, respectively. These values, which are target treatment concentration s and not results from modeling, would decrease as the treatment concentrations for rotenone have changed. The current maximum treatment concentration for all bodies of water (flowing and standing) is 2 0 0 μg/L

. Chronic exposure values were not estimated in the 2005 DWA for the piscicidal uses (the only remaining uses currently on the label) given that the compound was intentionally deactivated in some environments

. Additionally, the compound is expected to degrade via abiotic processes. Because the new SOP requires deactivation, chronic exposure values will not be de termined in the new DWA

.
**b. Measures of Exposure** 

Th e registered use of rotenone as a piscicide require s the direct application of the compound to water to maintain specific water concentrations for defined durations. Therefore, aquatic exposure number s are specific to meet the management objective of the treatment. As such, exposure modeling per se is not needed for rotenone as actual treatment levels will be used for aquatic estimated environmental concentrations (EEC)

.

i. Available Monitoring Data

The Agency is not aware of surface water or groundwater monitoring conducted by federal or state agencies ; monitoring within the treatment area is typically conducted via bioassay, i.e ., cage d live fish . However, if monitoring data of rotenone become availabl e, they will be considered in the
assessment.

**c. Measures of Effect** 

Toxicity data presented in Section 3 of this problem formulation will be used to calculate risk quotients. Any additional information submitted by the registrant or found in the open lite rature meeting the standards established by the Agency prior to conduct of the risk assessment will also be considered. The open literature studies are identified using EPA’s ECOTOXicology database ( ECOTOX) 37 

### , which employs a literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, and wildlife. The evaluation of both sources of data can also provide insight into direct and indirect effects of pesticides on biotic communitie s from loss of species that are sensitive to the chemicals and from changes in structure and functional characteristics of the affected communities.



### 9. Endangered Species Assessments

Consistent with the Agency’s responsibility under the Endangered Species Act (ESA), the Agency will evaluate risks to listed species from registered uses of pesticides in R egistration R eview . The process for evaluating potential risks to listed species is further described at http://www.epa.gov/oppfead1/endanger/litstatus/riskasses.htm

.

37 http://cfpub.epa.go v/ecotox/

### 16 10. Endocrine Disruptor Screening Program (EDSP)

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

.



### 11. Preliminary Identification of Data Gaps

**a. Environmental Fate** 

Table 4 identif ies environmental fate studies that were submitted for each guideline requirement, as well as current study classifications and whether or not further data are needed in order to support risk assessment. Environmental fate data that were previously submitted were reviewed using current standards. This r eview resulted in several studies being classified as “not acceptable” due to various deficiencies in the experimental method and/or the analytical method, as well as additional deficiencies related to OCSPP Series 835 guideline study requirement s.

In t he 1983 hydrolysis study

, transformation products were inadequately characterized. Unidentified residues in the organic and aqueous extracts were present at up to 48% and 16% of the applied, respectively. Unidentified residues at TLC plate origins were pre sent at up to 12% of the applied. Material balances were incomplete , with losses of 26

- 48% of the applied across all three pH levels studied . Additionally, the concentration of the co

- solvent was not reported and it was not confirmed that the test vessels were sterilized

.

The 1982 aqueous photolysis study was not conducted at the environmental pH level at which hydrolysis was expected to be slowest ( i.e ., pH 5), but was studied at pH 7.6. The compound was

s tudied at an initial concentration of 1 ppm, although the aqueous solubility is reported to be 0.2 ppm at 20 C. Up to 60% of the applied was not characterized ( i.e ., isolated and identified) and degradates were not definitively identified. Additionally, the artificial light source used in the study was not fully described.

The 1986 adsorption/desorption batch equilibrium study was not conducted using 0.01 N CaCl 2 

### solution, but was done with other salts which could alter the adsorption of the pesti cide on the sediments studied. Freundlich adsorption coefficients were not calculated. Instead, adsorption was determined in five sediments each reportedly studied at fo ur different pH levels

.

A 1 984 aerobic aquatic metabolism study (Acc#141274) is not valid, as material balances were variable; recoveries ranged from 73.2 to 173.1% of the applied in the nonsterile system and from 120.4 to 188.3% of the applied in the sterile system. Additionally, not all major degradates were identified

, and un extracted residu es were high, at up to 86% of the applied in some samples, suggesting that the single extraction solution (acetone:water, 3:1 v:v) used to extract the sediment samples was not sufficient. Similar deficiencies were found in the other 1984 aerobic and anaer obic aquatic metabolism stud ies (Acc# 253754).

### 17 Table 4 . Submitted Environmental Fate Data for Rotenone

.

OCSPP Guideline Data Requirement Submitted Studies (Accession #

or MRID) Study Classification Are data needed to conduct risk assessment? Justification and Assumptions EPA will

Make in Absence of Data

835.2120 Hydrolysis 141409 Not Acceptable Yes In the absence of data, rotenone will be assumed to be stable.

835.2370 Aqueous Photolysis 254730
141410 Not Acceptable Yes In the absence of data,
rotenone will be assumed to be stable.

835.2410 Soil Photolysis No data. Not required for aquatic use.  ̄ No

 ̄

835.4100 Aerobic Soil Metabolism No data.

 ̄ No In the absence of data, rotenone will be assumed to be stable.

835.4200 Anaerobic Soil Metabolism No data. Not required for aquatic use.  ̄ No  ̄

835.4300 Aerobic Aquatic Metabolism 141274
253454 Not Acceptable Yes In the absence of data,
roten one will be assumed to be stable

.

835.4400 Anaerobic Aquatic Metabolism 141273 (253754) Not Acceptable Yes In the absence of data,
rotenon e will be assumed to be stable

.

835.1230 Adsorption/ Desorption ( batch equilibrium ) 00 157850 Not Acceptable Yes  ̄

835.6100 Aquatic Field Dissipation Acc. # 00157851

(TRID 470152

- 010)

MRID 42217701 Supplemental No  ̄

850.1730 Bio accumulation in Fish Acc. #146183
Acc. #143252 Supplemental No  ̄



### b. **Ecological Effects**

### 18 Table 5 identifies ecological effects studies with rotenone , by MRID (or Accession number), for each guideline requirement, as well as study classifications and whether or not additional data are needed in order to support risk assessment. Rationale for any additional data requested is presented below the tables. No data are available for the chronic effects of rotenone on birds; g iven that the compound is appli ed aerially and that there may be circumstances where the compound is not deactivated in lentic environments , the likelihood of chronic exp osure to birds is uncertain; therefore, avian reproduction data are recommended . Data are also not available for ter restrial plants; however, given that rotenone is a flavonoid derived from plants and given that the compound is no longer applied to terrestrial environments, the likelihood of adverse effects on terrestrial plants from the use of rotenone as a piscicide i s considered low.

No data are available for estuarine/marine organism; howe ver, the compound is prohibited from

use in estuarine/marine environment . The SOP also stipulates that when applied to freshwater environments processes ( e.g ., deactivation) should be in place to ensure that the compound does not move outside of the targeted treatment area; , therefore, the likelihood of exposure is considered low. While toxicity data are available for freshwater fish and invertebrates for both the technical
g rade active ingredient and multiple formulations (USEPA 2007), no data are available for the most recent formulation of rotenone ( i.e

. , CFT Legumine TM 

### 3.3%) which was developed to address uncertainties regarding the solvents ( e.g ., toluene) associated with older formulations. Therefore, EFED recommends acute toxicity data for the formulated product using rainbow trout ( O. mykiss ) (OSCPP Guideline 850.1075) and using the waterflea ( D. magna ) (OCSPP 850.1010). Since no data are available on the extent to whi ch rotenone may partition to benthic sediments and given the estimated octanol

- water partition coefficient (K ow 

### ≈4.10) and the potentially high organic carbon partition coefficient (K oc 

### ), EFED recommends the 10

- day sediment toxicity test with both the midge ( Chironomus riparius ) and the amphipod ( Hyalella azteca ) (OCSPP Guideline 850.1735). Pending the outcome of the 10

- day sediment toxicity test, a whole

- sediment chronic toxicity test with a freshwater benthic invertebrate may be recommended as well; there fore, the whole sediment chronic toxicity test should be held in reserve.

Although rotenone is not applied to estuarine/marine environments, EFED is recommending acute toxicity data on molluscs (OCSPP Guideline 850.1025); however, rather than using the E astern oyster ( Crassostrea virginica ), the registrant should consider substituting a freshwater mussel ( e.g ., Corbicula spp.).

In 2014, EPA in collaboration with Health Canada’s Pest Management Regulatory Agency and the California Department of Pesticide Regulation is sued a harmonized guidance document on assessing the risk of pesticides to bees (USEPA 2014 38 

### ). I n the guidance

, multiple laboratory

- based acute and chronic toxicity tests with individual honey bee adults and larvae were identified in addition to semi

- and full

- field tests with honey bee colonies to inform the risk assessment process

. The tie red data requirements for honey bees identified in Table 5 reflect the full suite of studies identified in the guidance. Whether such tests are required th ough depends on the likelihood that bees will be exposed. Since rotenone is added directly to water, the likelihood of the material being applied to plants w h ere bees may be foraging is considered low; therefore, these studies are not being required at th is time.

38 USEPA 2014. Guidance for Assessing Pesticide Risks to Bees. Office of Pesticide Programs, USEPA; Health Canada Pest Management Regulatory Agency, Ottawa, ON, Canada; California Department of Pesticide Regulation, Sacramento, CA. http://www2.epa.gov/sites/production/files/2014

- 06/documents/pollinator_risk_assessment_guidance_06_19_14.pdf

### 19 Table 5 . Submitted Ecolog ical Effects Data for Rotenone.

Guideline Description

— Test Substance MRID or Acc. No. Study Classification Are data Needed for Risk Assessment? Comments (Justification and Assumptions EPA will Make in Absence of Data) Avian and Mammalian Testing

71

- 1 (850.2100) Avian acute oral toxicity, waterfowl Mallard duck ( Anas platyrhynchos )

T EP Acc. No. 143250 Supplemental No Guideline specifies that acute oral toxicity test should be conducted using TGAI; however, given that the compound is applied directly to water and the likelihood of exposure is considered low; the currently

available data on TEP are sufficient. 71

- 1 (850.2100) Avian acute oral toxicity, upland game bird species Ring

- necked

pheasant ( Phasianus colchicus ) TEP Acc. No. 143250 Supplemental No

850.2100 Avian acute oral toxicity, passerine species

TEP No data No Based on available data, rotenone is slightly toxic to practically

non

- toxic to birds on both an acute oral and subacute dietary

exposure basis. Compound

applied directly to water; therefore, the likelihood of exposure to passerine species considered low. Additional testing of birds is not needed.

850.2200 Avian dietary toxicity, waterfowl specie s
M allard duck (Anas platyrhynchos

T EP Acc. No. 248788 (Hill et al.

, 1975) Supplemental No

Guideline specifies that acute oral toxicity test should be conducted using TGAI; however, given that the compound is applied directly to water and the likelihood of exposure is considered low; the curre ntly

available data on TEP are sufficient. Avian dietary toxicity, upland
game Japanese quail ( Coturnix japonica ) bird Ring

- necked

pheasant ( Phasianus colchicus ) T EP Acc. No. 248788 (Hill et al.

, 1975) Supplemental No

### 20 Guideline Description

— Test Substance MRID or Acc. No. Study Classification Are data Needed for Risk Assessment? Comments (Justification and Assumptions EPA will Make in Absence of Data)

Avian die tary toxicity, upland game bird T EP Acc. No. 248788 (Hill et al.

, 1975) Supplemental No

71

- 4 (850.2300) Avian reproduction, waterfowl species

— TGAI No data Yes Based on available data, rotenone is slightly toxic to practically

non

- toxic to birds on both an acute oral and subacute dietary

exposure basis. Rotenone is added directly to water and may be deactivated; however, spray drift may be associated with the

aer ial application. L ikelihood of chronic exposure is uncertain. In the absence of data, chronic risk to birds will be presumed.

71

- 4 (850.2300) Avian reproduction, upland game bird

species

— TGAI No data Yes Based on available data, rotenone is slightly toxic to practically

non

- toxic to birds on both an acute oral and subacute dietary

exposure basis. Rotenone is added di rectly to water and may be deactivated; however, spray drift maybe associated with the aeri al application. L ikelihood of chronic exposure is uncertain. In the absence of data, chronic risk to birds will be presumed.

850.2400 Wild mammal toxicity

— TGAI No data No Chronic toxicity data are already available and are considered sufficient for risk assessment.

850.2500 Simulated or actual field testing

— TEP No Terrestrial uses eliminated.

Aquatic Animal Testing

72

- 2 (850.1010) Freshwater invertebrate, acute toxicity Waterflea ( Daphnia magna ) TGAI 400633

- 03 Supplemental No

### 21 Guideline Description

— Test Substance MRID or Acc. No. Study Classification Are data Needed for Risk Assessment? Comments (Justification and Assumptions EPA will Make in Absence of Data)

72

- 2 (850.1010) Freshwater invertebrate, acute toxicity Waterflea ( Daphnia magna ) T EP See
comment box to right Yes Although multiple test are available on formulated products, rotenone has recently been reformulated to reduce the reliance on organic solvents. Data are needed to evaluate the

relative toxicity of the new formulation to freshwater invertebrates.

72

- 3 (850.1025) Estuarine/Marine Mollusc acute toxicity

— TGAI No data Yes Compound cannot be applied in estuarine/marine environments ; however, freshwater mussels may be exposed to rotenone

. Con sider

testing Corbicula sp

. in lieu of Eastern oyster.

72

- 3 (850.1035) Estuarine/Marine
crustacean acute toxicity

TGAI No data No Compound cannot be applied in estuarine/marine environments.

850.1075 Freshwater fish, acute toxicity, warm water species Bluegill sunfish ( Lepomis macrochirus ) TGAI 439751

- 01 443829

- 02 Acceptable No

850.1075 Freshwater fish, acute toxicity, cold water species Rainbow trout ( Oncorhynchus mykiss ) TGAI 439751

- 02 443829

- 01 400633

- 01 Acceptable No

850.1075 Freshwater fish, acute toxicity, cold
water species Rainbow trout ( Oncorhynchus mykiss )

TEP See comment box to right. Yes Although multiple test are available on formulated products, rotenone has recently been reformulated to reduce the reliance on organic solvents. Data are needed to evaluate the

relative toxicity of the new formulation to freshwater fish.

850.1075 Estuarine/Marine fish acute toxicity

— TGAI No data No Compound cannot be applied in estuarine/marine environments.

### 22 Guideline Description

— Test Substance MRID or Acc. No. Study Classification Are data Needed for Risk Assessment? Comments (Justification and Assumptions EPA will Make in Absence of Data)

72

- 4 (850.1300) Freshwater invertebrate, reproduction test Waterflea ( Daphnia magna ) TGAI 400633

- 03 Supplemental No

850.1350 Estuarine/marine invertebrate, reproduction test

— TGAI No data No Compound cannot be applied in estuarine/marine environments.

850.1400 Freshwater fish, early life stage test

Rainbow trout ( Oncorhynchus mykiss ) TGAI 400633

- 02 Supplemental No

850.1400 Saltwater fish, early life stage test

— TGAI No data No Compound cannot be applied in estuarine/marine environments.

850.1500 Freshwater fish life cycle test No data No

Estuarine/marine fish life cycle test No data No Compound cannot be applied in estuarine/marine environments.

850.1950 Simulated or actual field testing for aquatic organisms Open literature Supplemental No Lentsch et al . 2001 39 describes actual application of rotenone; Finlayson et al. 2001 40 Sediment Testing

850.1735 Whole sediment 10

- d freshwater invertebrate

— TGAI Midge ( Chironomus riparius ) and amphipod ( Hyalella

a zteca ) No data Yes Given the high K ow (estimated 4.10) and uncertainty regarding the extent to which it partitions to

sediment ( i.e ., unknown K d and K oc )

850.1740 Whole sediment 10

- d estuarine/marine invertebrate

— TGAI No data No Compound cannot be applied in estuarine/marine environments.

39 Lentsch, L. D., C. W. Thompso n, and R. L. Spateholts. 2001. Overview of Large

- scale Chemical Treatment Success Story: Strawberry Valley, Utah. Pates 63

- to in R. L. Cailteux, L. DeMong, B. J. Finlayson, W. Horton, W. McClay, R. A. Schnick, and C. Thompson, editors. Rotenone in fis heries: are the rewards worth the risks? American Fisheries Society, Trends in Fisheries Science and Management 1, Bethesda, Maryland.

40 Finalyson, B. J., S. Siepmann, and J. Trumbo. 2001. Chemical Residues in Surface and Ground Waters Following Rotenone Application to California Lakes and Streams. Pages 37 to 53 in: R. L. Cailteux, L. DeMong, B. J. Finlayson, W. Horton, W. Mc Clay, R. A . Schnick, and C. Thompson (editors), Rotenone in Fisheries: Are the Rewards Worth the Risks? American Fisheries Society, Trends in Fisheries Science and Management 1, Bethesda, MD.

### 23 Guideline Description

— Test Substance MRID or Acc. No. Study Classification Are data Needed for Risk Assessment? Comments (Justification and Assumptions EPA will Make in Absence of Data)

Non

guideline Whole sediment chronic freshwater

and/or marine invertebrate

— TGAI No data Yes Whole sediment chronic study with freshwater invertebrates held in reserve pending outcome of 10

- day sediment toxicity test (850.1735) Insect Pollinator Testing

850.3020 Honey bee acute contact toxicity ( Apis mellifera ) TGAI Acc. No.
05001991 (Stevenson JH, 1978)
Acc. No. 00036935 (Atkins EL et al. , 1975) Acceptable No

Non

guideline (OECD 213) Honeybee acute oral toxicity study

— TGAI No data No Rotenone is added directly to water; likelihood of exposure is considered low.

Non

guideline (OECD 237) Honeybee Larval Acute Toxicity

Test

— TGAI No data No Rotenone is added directly to water; likelihood of exposure is considered low.

Non

guideline Honeybee 10

- day adult chronic toxicity No data No Rotenone is added directly to
water ; likelihood of chronic exposure is considered low. Non

- guideline Honeybee 21

- day larval chronic toxicity No data No

850.3030 Honeybee toxicity of residues on foliage

— TEP No data No Based on acute contact toxicity data, study is not triggered.

850.3040 Field testing for pollinators No data No Based on acute toxicity data and the absence of adverse effect data, study not required at this time.

T errestrial Plant Testing

850.4100 Seedling emergence (10 species)

— TEP No data No Compound is applied directly to water and is a natural constituent of plants. 850.4150 Vegetative vigor (10 species)

— TEP No

Aquatic Plant Testing

850.4400 Aquatic plant growth, vascular plant

— TGAI No data No Compound is a natural constituent of plants.

### 24 Guideline Description

— Test Substance MRID or Acc. No. Study Classification Are data Needed for Risk Assessment? Comments (Justification and Assumptions EPA will Make in Absence of Data)

850.4500* Aquatic Plant, freshwater green alga species

— TGAI No data No

Compound is a natural constituent of plants. Aquatic Plant, freshwater diatom

— TGAI No data No

Aquatic Plant, marine diatom

— TGAI No data No

850.4550 † Aquatic Plant, cyanobacterium

— TGAI No data No

TGAI = Technical Grade Active Ingredient TEP = technical end product * Algal toxicity tests are now under guideline OCSPP 850.4500 (formerly 850.5400)
† Cyanobacterium tests are now under guideline 850.4550 (formerly 850.5400)

### 25 APPENDIX A. Submitted Guideline Studies

Environmental Fate

161

- 1 Hydrolysis

MRID Citation Reference

45950 Derse, P.H.; Strong, F.M. (1963) Toxicity of Antimycin to fish. Nature 200(4906): 600

- 601. (Also~In~unpublished submission received Jun 30, 1965 under 8991

- 5; submitted by Ayerst Laboratories, Div. of American Home Products Corp., New York, N.Y.; CDL:10052 8

- D)

141409 2038363 Thomas, R. (1983) Hydrolysis of [6

- [Carbon 14]]

- Rotenone: Final Report: Borriston Project No. 0301A. Unpublished study prepared by Borriston Laboratories, Inc. 11 p.

141731 2022496 Spare, W. (1984) Final Report: Hydrolysis of [Radio labeled] Rotenone: Project No. 82

- E

- 076

- AM. Unpublished study prepared by Biospherics, Inc. 19 p

46688301 Alva, S. (2005) Giochem Cube Powder: Product Identity, Composition and Analysis. Unpublished study prepared by Universidad Nacional Agraria La Molina. 33 p

161

- 2 Photodegradation

- water

MRID Citation Reference

141410 2022497 2038364 Spare, W. (1982) Aqueous Photodegradation of [Carbon 14]

- Rotenone: Final Report: Project No. 82

- E

- 076

- P. Unpublished study prepared by Biospherics Incorporated. 18 p.

162

- 1 Aerobic soil metabolism

MRID Citation Reference

141411 Felkner, I. (1983) Effects of Microbes on Rotenone: Final Report: Borriston Project No. 0301B. Unpublished study prepared by Bor

- riston Laboratories, Inc. 22 p.

46688301 Alva, S. (2005) Giochem Cube Powder: Product Identity, Composition and Analysis. Un published study prepared by Universidad Nacional Agraria La Molina. 33 p.

162

- 2 Anaerobic soil metabolism

### 26 MRID Citation Reference

141411 Felkner, I. (1983) Effects of Microbes on Rotenone: Final Report: Borriston Project No. 0301B. Unpublished study prepared by Borriston Laboratories, Inc. 22 p.

162

- 3 Anaerobic aquatic metabolism

MRID Citation Reference

254731 2022602 Felkner, I. (1983) Effects of Microbes on Rotenone: Final Report: Borriston Project No. 0301B. Unpublished study prepared by Borriston Laboratories, Inc. 22
p.

141273 2022496 2038365 Spare, W. (1984) Final Report: Anaerobic Aquatic Metabolism of [Radiolab eled] Rotenone: Project No. 82

- E

- 076

- AM. Unpublished study prepared by Biospherics, Inc. 19 p.

162

- 4 Aerobic aquatic metabolism

MRID Citation Reference

254731 2022602 Felkner, I. (1983) Effects of Microbes on Rotenone: Final Report: Borriston Project No. 0301B. Unpublished study prepared by Borriston Laboratories, Inc. 22
p.

141273 2022496 Spare, W. (1984) Final Report: Aerobic Aquatic Metabolism of [Radiolabeled] Rotenone: Project No. 82

- E

- 076

- AM. Unpublished study prepared by Biospherics, Inc. 19 p.

141274 2038366 Spare, W. (1984) Final Report: Aerobic Aquatic Metabolism of [Radiolabeled] Rotenone: Project No. 82

- E

- 076

- M. Unpublished study prepared by Biospherics, Inc. 21 p.

163

- 1 Leach/adsorption/desorption

MRID Cita tion Reference

113292 2022598 Ref International Minerals & Chemical Corp. (1950) ?Dilan: Residues in Soil, Apples and Other Crops|. (Compilation; unpublished study received on unknown date under unknown admin. no.; CDL:120375

- A)

157850 2038366 2038368 Dawson, V. (1986) Adsorption

- desorption of [6a

- [Carbon

- 14]]

- Rotenone by Bottom Sediments: Final Report: ROT

- 84

- 988.02. Unpublished study prepared by National Fishery Research Laboratory, U.S. Fish and Wildlife Service. 144 p.

46688301 Alva, S. ( 2005) Giochem Cube Powder: Product Identity, Composition and Analysis. Unpublished study prepared by Universidad Nacional Agraria La Molina. 33 p.

### 27 163

- 2 Volatility

- lab

MRID Citation Reference

46688301 Alva, S. (2005) Giochem Cube Powder: Product Identity, Composition and Analysis. Unpublished study prepared by Universidad Nacional Agraria La Molina. 33 p.

163

- 3 Volatility

- field

MRID Citation Reference

46688301 Alva, S. (2005) Giochem Cube Powder: Product Identity, Composition and Analysis. Unpublished study prepared by Universidad Nacional Agraria La Molina. 33 p.

164

- 2 Aquatic field dissipation

MRID Citation Reference

157850 2038367 2038368 Dawson, V. (1986) Adsorption

- desorption of [6a

- [Carbon

- 14]]

- Roten

- one by Bottom Sediments: Final Report: ROT

- 84

- 988.02. Unpublished study prepared by National Fishery Research Laboratory, U.S. Fish and Wildlife Service. 144 p.

157851 2038367 Gilderhus, P.; Dawson, V.; Allen, J. (1986) Persistence of Rotenone in Aquatic Environments at Different Temperatures: Final Report: Report No. ROT

- 83

- 988.02. Unpublished study prepared by National by National Fishery Research Laboratory, U.S. Fish and Wild

- life Ser vice. 99 p.

40307401 Fugami, J.; Yamamoto, I.; Casida, J. (1966) Metabolism of rotenone in vitro by tissue homogenates from mammals and insects. Scien

- ce 155:713

- 716.

40307402 Fugami, J.; Shishido, T.; Fukunaga, K.; et al. (1969) Oxidative metabolis m of rotenone in mammals, fish, and insects and its relation to selective toxicity. Journal of Agricultural and Food Chemistry 17:1217

- 1226.

40307406 2022596 2022602 2033061 Ref Dawson, V. (1986) Analyses of Pretreatment Samples: Addendum to Study, Persi stence of Rotenone in Aquatic Environments at Different Temperatures: Project/Study No. ROT 83

- 988.02. Unpublished study prepared by U.S. Fish and Wildlife Service. 20 p.

40307407 2022578 Dawson, V.; Allen, J. (1987) Liquid Chromatographic Determination of Rotenone in Fish, Crayfish, Clams, and Sediments: Laboratory Project ID: Project/Study No. ROT 83

- 988.02. Unpublished study prepared by U.S. Fish and Wildlife Service. 16 p.

42217701 2 050430 Finlayson, B.; Harrington, J. (1991) Chemical Residues in Surface and Ground Waters Following Rotenone Application to California Lakes and Streams. Unpublished study prepared by California Dept. of Fish and Game. 39 p.

### 28 165

- 4 Bioaccumulation in fish

MRID Citation Reference

143252 2038367 Gingerich, W. (1984) Bioaccumulation Potential of Rotenone in Fish. Unpublished study prepared by US Fish and Wildlife Service. 5 p.

146183 2038367 2038370 Gingerich, W.; Rach, J. (1985) Accumulation and Elimination of [6A

- Carbon

14]

- Rotenone by Bluegills: Final Report. Unpublished study prepared by U.S. Fish and Wildlife Service. 115 p.

40307401 Fugami, J.; Yamamoto, I.; Casida, J. (1966) Metabolism of rotenone in vitro by tissue homogenates from mammals and insects. Science 155:713

- 716.

40307402 2022498 2022602 Fugami, J.; Shishido, T.; Fukunaga, K.; et al. (1969) Oxidative metabolism of rotenone in mammals, fish, and insects and its relation to selective toxicity. Journal of Agricultural and Fo od Chemistry 17:1217

- 1226.

40307403 Gingerich, W. (1987) Isolation, Purification, and Characterization of a Major Polar [Carbon 14]

- Rotenoid Residue from Rainbow Trout Bile: Addendum: Project/Study No: ROT 82

- 977.03. Unpublished study prepared by U.S. F ish and Wildlife Service. 46 p.

43494302 Gingrich, W. (1986) Distribution and accumulation of rotenone in tissues of warmwater fish. Transactions of the American Fisheries Society 115(1986):214

- 219.

43796401 Gilderhus, P.; Dawson, B.; Allen, J. (1984) Deposition and Persistence of Rotenone in Shallow Ponds During Cold and Warm Seasons: Supplement: (Raw Data): Lab Project Number: ROT

- 83

- 988.02. Unpublished study prepared by U.S. Fish and Wildlife Service. 1076 p.

165

- 5 Bioaccum

- aquatic non

- target

MRID Citation Reference

146183 2038370 Gingerich, W.; Rach, J. (1985) Accumulation and Elimination of [6A

- Carbon

14]

- Rotenone by Bluegills: Final Report. Unpublished study prepared by U.S. Fish and Wildlife Service. 115 p.

157851 2038367 Gilderhus, P.; Dawson, V.; Allen, J. (1986) Persistence of Rotenone in Aquatic Environments at Different Temperatures: Final Report: Report No. ROT

- 83

- 988.02. Unpublished study prepared by Nation

- al by National Fishery Research Laboratory, U.S. Fish and W ild

- life Service. 99 p.

40307401 Fugami, J.; Yamamoto, I.; Casida, J. (1966) Metabolism of rotenone in vitro by tissue homogenates from mammals and insects. Science 155:713

- 716.

40307402 2022498 Fugami, J.; Shishido, T.; Fukunaga, K.; et al. (1969) Oxidative metabolism of rotenone in mammals, fish, and insects and its relation to selective toxicity. Journal of Agricultural and Food Chemistry 17:1217

- 1226.

### 29 40307404 Yamamoto, I.; Unai, T.; Ohkawa, H.; et al. (1970) Stereochemical considerations in th e formation and biological activity of the rotenone metabolites. Pesticides Biochemistry and Physiology 1:143

- 150.

40307405 Gingerich, W.; Rach, J. (1984) Uptake, biotransformation, and elimination of rotenone by bluegills (lepomis macrochirus). Aquatic Toxicology 6:179

- 196.

40307406 2022596 Dawson, V. (1986) Analyses of Pretreatment Samples: Addendum to Study, Persistence of Rotenone in Aquatic Environments at Different Temperatures: Project/Study No. ROT 83

- 988.02. Unpublished study prepared by U.S. Fish and Wildlife Service. 20 p.

40307407 2022578 Ref Dawson, V.; Allen, J. (1987) Liquid Chromatographic Determination of Ro tenone in Fish, Crayfish, Clams, and Sediments: Laboratory Project ID: Project/Study No. ROT 83

- 988.02. Unpublished study prepared by U.S. Fish and Wildlife Service. 16 p.

40348709 2202602 Fugami, J.; Shishido, T.; Fukunaga, K.; et al. (1969) Oxidative m etabolism of rotenone in mammals, fish, and insects and its relation to selective toxicity. Journal of Agricultural and Food Chemistry 17:1217

- 1226.

43494301 Gilderhus, P.; Dawson, B.; Allen, J. (1984) Deposition and persistence of rotenone in shallow po nds during cold and warm seasons. Journal of Investigations in Fish Control 95:1

- 7.

43796401 Gilderhus, P.; Dawson, B.; Allen, J. (1984) Deposition and Persistence of Rotenone in Shallow Ponds During Cold and Warm Seasons: Supplement: (Raw Data): Lab Project Number: ROT

- 83

- 988.02. Unpublished study prepared by U.S Fish and Wildlife Service. 1076 p

Non

- guideline

MRID Citation Reference

46688301 Alva, S. (2005) Giochem Cube Powder: Product Identity, Composition and Analysis. Unpublished study prepared by Universidad Nacional Agraria La Molina. 33 p.



### Ecological Effects

36935 Atkins, E. L., E. A. Greywood and R. L. Macdonald. 1975. Toxicity of Pesticides and Other Agricultural Chemicals to Honey Bees: Laboratory Studies. University

o f California, Department of Entomology, U.C. Cooperative Extension (Leaflet 2287) 38p.

71003 Hudson, R. H., r. K. Tucker and M. A. Haegele. 1984. Handbook of Toxicity of Pesticides to Wildlife. USDI, Resource Publication 153. Washington DC, 90 p

141408 Kehoe, D, K. MacKenzie. 1983. Reproduction Study for Safety Evaluation of Rotenone Using Rats. Final Report. Study No 81077. Unpublished study prepared by Hazleton Raltech, Inc. 732p.

### 30 143250 Tucker, R. 1968. Rotenone: [Acute Oral Toxicity t o Mallard Ducks and Ring

necked Pheasants]. Unpublished study prepared by U.S. Fish and Wildlife Service, Denver Wildlife Research Center. 8 p.

145496 Eiseman, J. and A. Thakur. 1984. General Metabolism Study for Safety Evaluation of Rotenone using Rat s. Project No. 419

- 137. Unpublished Study Prepared by Hazleton Laboratories, America, Inc. 311 p.

248788 Hill, E. F., R. G. Heath, J. W. Spann and J. D. Williams. 1975. Lethal dietary toxicities of environmental pollutants to birds. U. S. Fish and Wildlife Service, Special Scientific Report Wildlife No. 191. Washington, D. C.

400633

- 01 USFWS., 1986. Rotenone Freshwater Fish LC 50 

### Rainbow Trout and Bluegill Sunfish. Lab ID Number 83

- 626.01B.

400633

- 02 Bills, T., J. Rach, and L. Marking. 1986. Rotenone

-- Fish Early Life Stage

-- Rainbow Trout: Laboratory Project ID; TOX 83

- 626.01B. Unpublished study prepared by U.S. Fish and Wildlife Service. 15 p.

400633

- 03 Rach, J., T. Bills, and L. Marking. 1986. Rotenone

-- Acute LC 50 

### Freshwater Invertebrate

-- Da phnia: Rotenone Aquatic Invertebrate Life Cycle

- Daphnia: Laboratory Project ID; TOX 83

- 626/01A. Unpublished study prepared by U.S. Fish and Wildlife Service. 26 p.

439751

- 01 Sousa, J. 1996. Crystalline Rotenone

-- Acute Toxicity to Bluegill Sunfish ( Lepomis macrochirus ) Under Flow

- Through Conditions: Lab Project Number: 10824.0695.6118.105: 95

- 10

- 6148: 051995/FIFRA/105. Unpublished study prepared by Springborn Laboratories, Inc. 70 p.

439751

- 02 Sousa, J. 1996. Crystalline Rotenone

-- Acute Toxicity to Rainbow Trout ( Oncorhynchus mykiss ) Under Flow

- Through Conditions: Lab Project Number: 10824.0625.6119.108: 95

- 10

- 6154: 051995/FIFRA/108. Unpublished study prepared by Springborn Laboratories, Inc. 70 p.

443829

- 01 Sousa, J. V., 1997. Rotenone Acute Toxicity to Rainbow Trout (Oncorhynchus mykiss) under Flow

- through Conditions. Lab Report No. 97

- 9

- 7064. Unpublished study prepared by Springborn Laboratories, Wareham, MA.

443829

- 02 Sousa, J. V., 1997. Rotenone Acute Toxicity to Bluegill Sunfish ( Lepomis macrochi rus ) under Flow

- through Conditions. Lab Report No. 97

- 8

- 7063. Unpublished study prepared by Springborn Laboratories, Wareham, MA.

### 31 5001991 Stevenson, J. H. 1978. The Acute Toxicity of Unformulated Pesticides to Worker Honey Bees ( Apis mellifera L.). Pl ant Pathology 27(1): 38

- 40.

### 32 APPENDIX B

. EPI Suite Output File for Rotenone

SMILES : COc5cc4OCC3Oc2c1CC(Oc1ccc2C(=O)C3c4cc5OC)C(C)=C
CHEM : rotenone MOL FOR: C23 H22 O6 MOL WT : 394.43

------------------------------ EPI SUMMARY (v4.11)

--------------------

------ Physical Property Inputs: Log Kow (octanol

- water):

------ Boiling Point (deg C) :

------ Melting Point (deg C) :

------ Vapor Pressure (mm Hg) :

------ Water Solubility (mg/L):

------ Henry LC (atm

- m3/mole) :

------

Log Octanol

- Water Partition Coef (SRC): Log Kow (KOWWIN v1.68 estimate) = 4.31 Log Kow (Exper. database match) = 4.10 Exper. Ref: HANSCH,C ET AL. (1995)

Boiling Pt, Melting Pt, Vapor Pressure Estimations (MPBPVP v1.43): Boiling Pt (deg C): 501.20 ( Adapted Stein & Brown method) Melting Pt (deg C): 213.16 (Mean or Weighted MP) VP(mm Hg,25 deg C): 6.94E

- 010 (Modified Grain method) VP (Pa, 25 deg C) : 9.25E

- 008 (Modified Grain method) MP (exp database): 176 deg C BP (exp database): 210

- 220 @ 0.5 mm Hg deg C Subcooled liquid VP: 2.56E

- 008 mm Hg (25 deg C, Mod

- Grain method) : 3.41E

- 006 Pa (25 deg C, Mod

- Grain method)

Water Solubility Estimate from Log Kow (WSKOW v1.42): Water Solubility at 25 deg C (mg/L): 1.045 log Kow used: 4.10 (expkow data base)

no

- melting pt equation used Water Sol (Exper. database match) = 0.2 mg/L (20 deg C) Exper. Ref: AUGUSTIJN

- BECKERS,PWM ET AL. (1994)

Water Sol Estimate from Fragments: C H 3
O

O O O O O C H

3

H

3 C H

2 C

### 33 Wat Sol (v1.01 est) = 0.013116 mg/L

ECOSAR Class Program (ECOSAR v1.11): Class (es) found: Vinyl/Allyl Ethers

Henrys Law Constant (25 deg C) [HENRYWIN v3.20]: Bond Method : 1.12E

- 013 atm

- m3/mole (1.13E

- 008 Pa

- m3/mole) Group Method: Incomplete For Henry LC Comparison Purposes:
User

- Entered Henry LC: not entered Henrys LC [via VP/WSol estimate using User

- Entered or Estimated values]: HLC: 3.447E

- 010 atm

- m3/mole (3.492E

- 005 Pa

- m3/mole) VP: 6.94E

- 010 mm Hg (source: MPBPVP) WS: 1.04 mg/L (source: WSKOWWIN)

Log Octanol

- Air Partition Coefficient (25 deg C) [KOAWIN v1.10]: Log Kow used: 4.10 (exp database) Log Kaw used:

- 11.339 (HenryWin est) Log Koa (KOAWIN v1.10 estimate): 15.439 Log Koa (experimental database): None

Probability of Rapid Biodegradation (BIOWIN v4.10): Biowin1 (Linear Model) : 1.3355 Biowin2 (N on

- Linear Model) : 0.9999 Expert Survey Biodegradation Results: Biowin3 (Ultimate Survey Model): 1.8648 (months ) Biowin4 (Primary Survey Model) : 3.5050 (days

- weeks ) MITI Biodegradation Probability: Biowin5 (MITI Linear Model) : 0. 6583 Biowin6 (MITI Non

- Linear Model): 0.3312 Anaerobic Biodegradation Probability: Biowin7 (Anaerobic Linear Model): 0.3225 Ready Biodegradability Prediction: NO

Hydrocarbon Biodegradation (BioHCwin v1.01): Structure incompatible with current estimat ion method!

Sorption to aerosols (25 Dec C)[AEROWIN v1.00]: Vapor pressure (liquid/subcooled): 3.41E

- 006 Pa (2.56E

- 008 mm Hg) Log Koa (Koawin est ): 15.439 Kp (particle/gas partition coef. (m3/ug)): Mackay model : 0.879 Octanol/air (Koa) mode l: 675 Fraction sorbed to airborne particulates (phi): Junge

- Pankow model : 0.969 Mackay model : 0.986 Octanol/air (Koa) model: 1

Atmospheric Oxidation (25 deg C) [AopWin v1.92]: Hydroxyl Radicals Reaction:
OVERALL OH Rate Constant = 328.8113 E

- 12 cm3/molecule

- sec Half

- Life = 0.033 Days (12

- hr day; 1.5E6 OH/cm3) Half

- Life = 23.421 Min Ozone Reaction: OVERALL Ozone Rate Constant = 1.200000 E

- 17 cm3/molecule

- sec

### 34 Half

- Life = 0.955 Days (at 7E11 mol/cm3) Half

- Life = 22.9 20 Hrs Fraction sorbed to airborne particulates (phi): 0.978 (Junge

- Pankow, Mackay avg) 1 (Koa method) Note: the sorbed fraction may be resistant to atmospheric oxidation

Soil Adsorption Coefficient (KOCWIN v2.00): Koc : 2.611E+005 L/kg (MCI method) Log Koc: 5.417 (MCI method) Koc : 3165 L/kg (Kow method) Log Koc: 3.500 (Kow method)

Aqueous Base/Acid

- Catalyzed Hydrolysis (25 deg C) [HYDROWIN v2.00]: Rate constants can NOT be estimated for this structure!

Bioaccumulation Estimates (BCFBAF v3.01): Log BCF from regression

- based method = 1.787 (BCF = 61.25 L/kg wet

- wt) Log Biotransformation Half

- life (HL) =

- 1.0793 days (HL = 0.0833 days) Log BCF Arnot

- Gobas method (upper trophic) = 2.006 (BCF = 101.5) Log BAF Arnot

- Gobas method (upper trophic) = 2.006 (BAF = 101.5) log Kow used: 4.10 (expkow database)

Volatilization from Water: Henry LC: 1.12E

- 013 atm

- m3/mole (estimated by Bond SAR Method) Half

- Life from Model River: 1.038E+010 hours (4.326E+008 days) Half

- Life from Model Lake : 1.133E+011 hours (4.719E+009 days)

Removal In Wastewater Treatment: Total removal: 34.83 percent Total biodegradation: 0.36 percent Total sludge adsorption: 34.47 percent Total to Air: 0.00 percent (using 10000 hr Bio P,A,S)

Level III Fugacity Model: Mass Amount Half

- Life Emissions (percent) (hr) (kg/hr) Air 5.87e

- 006 0.755 1000 Water 2.89 1.44e+003 1000 Soil 53.6 2.88e+003 1000 Sediment 43.5 1.3e+004 0 Persistence Time: 4.9e+003 hr

### 35 Appendix C. Screening Imbibition Program Output.

Table 1. Inputs Parameter Value Chemical name Rotenone Solubility (in water at 25 o C; mg/L) 0.2

Mammalian LD 50 (mg/kg-bw) 286 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species Mammalian NOAEL (mg/kg-bw) 0.5 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg-bw) 2200 Avian test species mallard duck Body weight (g) of "other" avian species Mineau scaling factor 1.15 Mallard NOAEC (mg/kg-diet) 0 Bobwhite quail NOAEC (mg/kg-diet) 0 NOAEC (mg/kg-diet) for other bird species 0 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) 0.0344 0.0344 Adjusted toxicity value (mg/kg-bw) 219.9799 0.3846 Ratio of exposure to toxicity 0.0002 0.0894

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) 0.1620 0.1620 Adjusted toxicity value (mg/kg-bw) 1142.2959 0.0000 Ratio of exposure to acute toxicity 0.0001 0.0000

Conclusion* Drinking water exposure alone is NOT a potential concern for birds Due to insufficient data, risk cannot be precluded

*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.