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OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

December 4, 2014

PC Code: 035101

MEMORANDUM DP Barcode: 411597

SUBJECT: Preliminary Ecological Risk Assessment for the Registration Review of 

Daminozide

FROM: Christine Hartless, Ph.D., Wildlife Biologist

James Lin, Ph.D., Environmental Engineer

ERB2/EFED (7507P)

THROUGH: Greg Orrick, Environmental Scientist

Christina Wendel, Biologist

Jean Holmes, DVM, MPH, Risk Assessment Process Leader

Brian Anderson, MEM, Branch Chief

ERB2/EFED (7507P)

TO: Meg Hathaway, Chemical Review Manager

Kevin Costello, Branch Chief

RMIB2/PRD (7508P)

This memorandum transmits the preliminary ecological risk assessment for the registration 

review of the plant growth regulator daminozide. Based on currently registered uses and labeled 

rates, this preliminary assessment identifies potential risks to non-target organisms. This 

assessment is focused on species that are not federally listed as threatened or endangered 

(referred to as “listed”); however, some general discussion of taxa of listed species for which “no 

effect” determinations are expected is included in this assessment. For taxa where there may be 

risk, specific determinations for listed species are considered uncertain and are not discussed at 

this time and will be considered later in the registration review process. 

Risks due to use of daminozide using current labels were considered low for non-listed species

of fish, aquatic-phase amphibians (that do not have terrestrial-phases), aquatic invertebrates, 

aquatic plants, terrestrial invertebrates, monocots (in terrestrial and wetland habitats), and dicots 

(in terrestrial and wetland habitats). Risk due to use of daminozide at currently labeled rates 

cannot be precluded for listed and non-listed non-target birds, reptiles, terrestrial-phase 

amphibians and mammals. “No effect” (NE) determinations were made for listed species of fish, 

aquatic-phase amphibians (that do not have terrestrial-phases), aquatic invertebrates, aquatic 

plants, terrestrial invertebrates, monocots (in terrestrial and wetland habitats), and dicots (in 

terrestrial and wetland habitats) that do not rely upon birds, terrestrial-phase amphibians, reptiles, 

and/or mammals (for food or shelter).
Page 2 of 37

Preliminary Ecological Risk Assessment for the Registration Review 

of Daminozide

CAS Number 1596-84-5

USEPA PC CODE 035101

Prepared by:

Christine Hartless, Ph.D., Wildlife Biologist

James Lin, Ph.D., Environmental Engineer

Reviewed by:

Greg Orrick, Environmental Scientist

Christina Wendel, Biologist

Jean Holmes, DVM, MPH, Risk Assessment Process Leader

Approved by:

Brian Anderson, MEM, Branch Chief, Environmental Risk Branch II

Environmental Fate and Effects Division

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460

December 2, 2014
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Table of Contents

1 Executive Summary............................................................................................................ 4

2 Problem Formulation .......................................................................................................... 5

2.1 Target Pests and Mode of Action............................................................................ 6

2.2 Use Characterization............................................................................................... 6

2.3 Estimated Use in the United States......................................................................... 9

3 Exposure Analysis ............................................................................................................ 10

3.1 Environmental Fate Summary .............................................................................. 10

3.2 Residues of Concern ............................................................................................. 11

3.3 Aquatic Exposure.................................................................................................. 11

3.4 Terrestrial Exposure.............................................................................................. 14

4 Effects Analysis................................................................................................................ 16

4.1 Toxicity of Daminozide ........................................................................................ 16

4.2 Endocrine Disruptor Screening Program.............................................................. 19

5 Risk Characterization........................................................................................................ 19

5.1 Aquatic Organisms................................................................................................ 20

5.2 Terrestrial Organisms............................................................................................ 21

5.3 Listed Species ....................................................................................................... 24

5.4 Risk Conclusions .................................................................................................. 25

6 References......................................................................................................................... 26

Appendix A. Summary of All Ecotoxicity Data........................................................................... 27

Appendix B. MRID Bibliography for Environmental Fate and Toxicity Studies....................... 30
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1 Executive Summary

The purpose of this assessment is to evaluate the potential risks to non-target organisms from 

registered uses of daminozide ((N-dimethylamino)succinamic acid). This assessment is focused 

on non-listed species and does not consider risks to individual federally listed endangered and 

threatened (listed) species. This assessment is focused on species that are not federally listed as 

threatened or endangered (referred to as “listed”); however, some general discussion of taxa of 

listed species for which “no effect” determinations are expected is included in this assessment. 

For taxa where there may be risk, specific determinations for listed species are considered 

uncertain and are not discussed in this document. Risks to listed species will be considered later 

in the registration review process.

Daminozide is a plant growth regulator used to control the development of commercial 

container-grown plants both in greenhouses and outdoors by changing their growth habit; usually 

by making the plant smaller in height and thicker (more densely packed). It is applied as a 

foliage spray on ornamentals and is systemically distributed throughout the plant; there are no 

currently registered food uses. The maximum single application rate is one gallon of 0.75% 

daminozide solution for 200 sq feet of plants. This is equivalent to 13.63 lbs a.i./acre for the 

treated area (e.g., nursery beds of containerized plants). Multiple applications are allowed for 

many uses; however, an annual maximum total rate is not provided on the label. 

Daminozide is nonvolatile and is not expected to bioaccumulate in fish. Daminozide does not 

undergo hydrolysis. Aqueous photolysis of daminozide showed a half-life of 162 days. The 

compound does not persist in aerobic soil with a half-life of 9 hours. It is moderately mobile in 

soil (KOC range of 204-349 L/kgOC). The compound may move to surface water bodies via spray 

drift and runoff of dissolved or sorbed residues. In the aerobic soil metabolism study, the major 

degradate was CO2 and the minor degradate was formaldehyde.

Daminozide is practically non-toxic to birds and mammals on an acute exposure basis. In a 

reproduction study with bobwhite quail (Colinus virginianus), there was a reduction in the 

percent of surviving 14-day chicks relative to number hatching at 890 mg ai/kg-diet, resulting in 

a no observed adverse effect concentration (NOAEC) of 365 mg a.i./kg-diet. Available toxicity 

data for mammals did not identify any reproductive or offspring effects at doses up to 500 mg 

a.i./kg-bw/day. Daminozide is practically non-toxic to honey bees (Apis mellifera) on an acute 

exposure basis. Available data for terrestrial plants indicate that dicotyledonous (dicots) species

are more sensitive than monocotyledonous (monocots) species. No effects to monocots were 

indicated at rates up to 11.5 lbs a.i./acre. The most sensitive dicot was soybean exposed to 

daminozide during the vegetative vigor study. The most sensitive parameter was plant height, 

with an IC25 of 7.71 lbs a.i./acre, a NOAEC < 0.709 lb a.i./acre, and an IC05 of 0.39 lb a.i./acre. 

For aquatic animals, daminozide is practically non-toxic to fish and slightly toxic to invertebrates

on an acute exposure basis. No reproduction data are available for fish or invertebrates. The only

aquatic plant species tested (Pseudokirchneriella subcapitata) had a NOAEC of 99.8 mg a.i./L.

No ecological incidents were reported for daminozide. 

Based on the estimated exposure concentrations (EECs) and the toxicity of the parent compound, 

currently labeled rates of daminozide pose a potential risk to non-target terrestrial animals, 
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including birds, reptiles, terrestrial-phase amphibians and mammals. The risk conclusions for 

non-listed species are summarized as follows:

 Indoor Uses

o For all non-target plant and animal species, direct adverse effects are not 

expected for indoor uses (i.e., enclosed greenhouse) of daminozide.

 Outdoor Uses

o Mammals: Acute effects are not expected. Reproductive effects cannot be 

precluded as predicted exposure levels are higher than laboratory-tested levels. 

o Birds (surrogates for terrestrial-phase amphibians and reptiles): Outdoor uses of 

daminozide may pose a potential acute and chronic risk to birds feeding on or 

adjacent to treated plants. Although daminozide is classified as practically nontoxic on an acute basis, application rates on labels are higher than exposure levels 

evaluated in the avian toxicity tests; therefore, acute risk potential cannot be 

precluded. Chronic LOCs were exceeded for maximum label rates of daminozide.

o Aquatic animals and plants and terrestrial invertebrates and plants (fish are 

surrogates for aquatic-phase amphibians): Direct adverse effects are not 

expected.

 EPA has not completed effects determinations for most listed species associated with the 

outdoor registered uses of daminozide. Effect determinations for listed species of birds, 

terrestrial-phase amphibians, reptiles, and mammals as well as other listed species that 

rely upon birds, terrestrial-phase amphibians, reptiles, and/or mammals for food or shelter

are incomplete.

 Based on lack of LOC exceedances from exposure to daminozide assuming currently 

registered use patterns, a No Effect (NE) determination can be made for listed species of 

fish, aquatic-phase amphibians (that do not have terrestrial-phases), aquatic invertebrates, 

aquatic plants, terrestrial invertebrates, monocots (in terrestrial and wetland habitats), and 

dicots (in terrestrial and wetland habitats) that do not rely upon birds, terrestrial-phase 

amphibians, reptiles, and/or mammals for food or shelter.

2 Problem Formulation

The problem formulation section of this preliminary ecological risk assessment is based on the 

preliminary problem formulation (PF) for the registration review of daminozide (DP 358996; 

April 23, 2009). Modifications have been made to accommodate newly available data and 

methods currently approved for use in ecological risk assessments. The purpose of this 

assessment is to evaluate the potential risks to non-target organisms from the registered uses of 

daminozide. This assessment is focused on species that are not federally listed as threatened or 

endangered; however, some general discussion of taxa for which “no effect” determinations are 

expected is included in this assessment. For taxa where there may be risk for listed species, 

specific determinations are considered uncertain at this time.

The ecosystems that are potentially at greatest risk are those in close proximity to daminozide 

use sites. These include commercial or research greenhouses, shadehouses, and nurseries and the 

surrounding areas that may receive daminozide via spray drift and/or runoff. Organisms of 

concern include birds, mammals, reptiles, fish, and terrestrial and aquatic invertebrates, plants, 
Page 6 of 37

and amphibians. 

2.1 Target Pests and Mode of Action

Daminozide is a plant growth regulator used to control the development of container-grown 

plants by changing their growth habit; resulting in a plant appearance that is shorter in height 

with more densely packed stems and leaves. Daminozide has been demonstrated to be systemic, 

moving throughout the plant and any fruits present (Brewerton et al. 1972; Kvien et al. 1989).

Generally, plant growth retardants are synthetic compounds, which are used to reduce the shoot 

length of plants in a desired way without changing developmental patterns or being phytotoxic. 

Cell elongation is reduced, and the rate of cell division is lowered. In their effect on the 

morphological structure of plants, growth retardants such as daminozide are antagonistic to 

gibberellins (GAs) and auxins, the plant hormones that are primarily responsible for shoot 

elongation. Specifically, daminozide is a member of the acylcyclohexanedione class of growth 

retardants, which particularly block 3ß-hydroxylation, thereby inhibiting the formation of highly 

active GAs from inactive precursors (Rademacher, 2000).

2.2 Use Characterization

2.2.1 Registered Uses

Historically, daminozide was used on a wide range of crops. Currently, there are no registered 

food uses for daminozide and it is only registered for use on ornamentals grown in commercial 

or research greenhouses, shadehouses, and nurseries. 

At the present time, there are two technical registrations (EPA Reg. No. 400-17 and 62097-16), 

one manufacturing registration (EPA Reg. No. 400-79) and three end-use product (EUP) 

registrations (EPA Reg. No. 400-110, 400-478, and 62097-17) for daminozide. These 

registrations are maintained by two different registrants. Table 2.1 summarizes the formulated 

products currently registered for daminozide as well as uses and application rates and methods. 

The label recommended application volume is 1 gallon of spray solution to cover 200 square feet 

of area, providing foliage coverage just to the point of runoff. The maximum label application 

rate is 7500 ppm (0.75% solution) on foliage plants, which is equivalent to 33.4 grams per gallon

and 13.6 lbs a.i./acre. The application rate expressed as lbs a.i./acre was derived as follows:

85% a.i. x 33.4g/gal x gal/200 ft2 x 43560 ft2/acre x lb/453.59g = 

13.632 lbs a.i./acre

Depending on the targeted plant species, the labeled solution concentration rates range from 

1000 ppm to 7500 ppm, resulting in a range of equivalent application rates of 1.8 to 13.6 lbs 

a.i./acre of treated plants. These application rates are reflective of daminozide applied only to the 

treated plants and does not include roads and non-production areas in the nursery.

One of the end-use products (Dazide® 85 WSG, EPA Reg. No. 62097-17) is labeled for use only

in enclosed areas (e.g., greenhouses). The Dazide ® 85 WSG label includes directions for a foliar 
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spray on ornamentals and for a pre-plant dip for cuttings. Given this restriction of use only in an 

enclosed greenhouse, environmental exposures from this EUP to non-target organisms are 

unlikely to occur through drift, runoff, or direct contact with treated plants. 

Two other end-use products (B-Nine® SP and B-Nine® WSG, EPA Reg. Nos. 400-110 and 400-

478) are labeled for use in enclosed areas (e.g., greenhouses) as well as for use in shadehouses, 

nurseries, and other production areas. Both of these labels state that use in production areas not 

under cover is restricted to containerized ornamentals. Ecological risk concerns discussed in this 

assessment will be with regard to the uses and labels for outdoor applications including, but not 

limited to, uncovered production areas, unenclosed nurseries, and shadehouses (B-Nine® SP and 

B-Nine® WSG, EPA Reg. Nos. 400-110 and 400-478). 

Table 2.1 Daminozide Labels and Labeled Uses. 

Reg. No.,

Product 

Name,

% AI

Use

Maximum 

single 

application 

rate *

Multiple application label 

language

Application 

method Restrictions

400-110,

B-Nine®-

SP, 85%

Azaleas (florist)

Bedding/flowering 

plants

Bedding plant plugs

Chrysanthemums

Foliage plants

Gardenias

Hydrangeas

Poinsettias

13.6 lbs 

a.i./acre

Label states that two 

applications at 1⁄2 to 2⁄3 the 

maximum single label rate may 

give better control than a single 

application at the maximum 

rate. Minimum time between 

applications is not specified on 

label. 

Depending on use, multiple 

application instructions are 

provided. Examples of 

language are provided in 

Footnote #1.

Ground

Spray

(foliar)

Arizona – use 

on bed-grown 

or 

containerized 

ornamentals 

not permitted 

on pervious 

flooring

400-478,

B-Nine®

WSG, 

85%

Azaleas (florist)

Bedding/flowering 

plants

Bedding plant plugs

Chrysanthemums

Foliage plants

Gardenias

Hydrangeas

Poinsettias

13.6 lbs 

a.i./acre

Label states that two 

applications at 1⁄2 to 2⁄3 the 

maximum single label rate may 

give better control than a single 

application at the maximum 

rate. Minimum time between 

applications is not specified on 

label. 

Depending on use, multiple 

application instructions are 

provided. Examples of 

language are provided in 

Footnote #1.

Ground

Spray

(foliar)

Arizona – use 

on bed-grown 

or 

containerized 

ornamentals 

not permitted 

on pervious 

flooring
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Table 2.1 Daminozide Labels and Labeled Uses. 

Reg. No.,

Product 

Name,

% AI

Use

Maximum 

single 

application 

rate *

Multiple application label 

language

Application 

method Restrictions

62097-17,

Dazide® 85 

WSG,

85%

Bedding/flowering 

plants

Bedding plant plugs

Chrysanthemums

Foliage plants

Gardenias

Hydrangeas

Poinsettias

13.6 lbs 

a.i./acre

Label states that two 

applications at 1⁄2 to 2⁄3 rate 

within 48 hours may be more 

efficacious than a single 

application of the total 

application rate.

Depending on use, multiple 

application instructions are 

provided. Examples of 

language are provided in 

Footnote #2.

Ground

Spray

(foliar)

1) Spray must 

be performed 

in enclosed 

area (e.g., 

greenhouse). 

2) Arizona –

use on bedgrown or 

containerized 

ornamentals 

not permitted 

on pervious 

flooring

*The maximum single application rate for daminozide is 13.6 lbs a.i./acre on the treated (target) plants. Label 

alternatively recommends applying daminozide at 2⁄3 the maximum rate (9.1 lbs a.i./acre) twice over a 48 hr 

interval. 

Footnote #1: 

- An additional application may be made two weeks later, if necessary.

- Repeat applications can be made at 1 to 2 week intervals or as needed.

- Additional applications, if required, may be made at 2 week intervals, stopping one week prior to disbudding.

- Two or more applications may be necessary if new growth begins to stretch or for enhanced coloration.

- Repeat applications may be necessary for optimum plant size.

Footnote #2:

- Repeat applications may be made as new growth continues to elongate.

- Repeat applications at 1-2 week intervals may be made as required, but the most vigorous seedlings will require 

the most regular applications.

- Repeat applications may be required if new growth begins.

- Repeat applications can be made as needed.

2.2.2 Uncertainties Surrounding Label Language

The information provided on the Section 3 labels is used to parameterize the fate and transport 

models that estimate exposure concentrations of daminozide in terrestrial and aquatic habitats. 

Relevant parameters include: maximum single application rates, numbers of applications per 

year, intervals between applications and application methods. In many cases, these parameter 

values can be obtained directly from the label; however, when the labels are not clear about these 

parameters, assumptions are made, unless there is evidence to the contrary. This section 

discusses cases where daminozide labels are unclear and explains the conservative assumptions 

that are made in this assessment to compensate for the lack of clearly defined parameters 

relevant to application of daminozide. 

Maximum single application rate information is clearly labeled; however, the maximum annual
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application rate of daminozide on a given plant is not clearly stated on the labels. For example, 

for B-Nine® SP use on foliage plants such as ficus, an initial application of 2500 to 7500 ppm 

solution is permitted, and follow-up applications are permitted if new growth “begins to stretch.” 

The label does not specify the minimum interval between applications, the maximum number of 

applications on a given plant, or the maximum annual application rate.

Ornamental plants will only stay in nurseries until they are ready to be shipped to wholesalers,

retailers, or consumers, thus plants will be constantly moving in and out of a given facility. The 

current daminozide labels do not specify the maximum number of applications in a calendar year 

within a nursery. This maximum environmental exposure to daminozide is a function of the 

application rate, the number of times a given plant is treated while in the nursery, and the number 

of plants that are rotated into the same space in the nursery over the course of a year. Obtaining 

this information would minimize the uncertainty in exposure frequency and duration. 

2.3 Estimated Use in the United States

In 2011, daminozide usage in horticultural nurseries across the United States was reported to be 

13,000 lbs active ingredient (EPA Proprietary Data 2012). Additional usage data available for 

portions of the US are outlined below. 

National Agricultural Statistics Service (NASS) conducts periodic summaries of pesticide usage 

in commercial nurseries and floriculture operations. The six states involved in this survey 

program are California, Florida, Michigan, Oregon, Pennsylvania, and Texas. In 2006, a total of 

16,300 lbs of daminozide were reported used in the surveyed commercial nurseries floriculture 

operations; the average and 90th percentile application rate for a single application was reported 

as 3.4 and 7.7 lbs a.i./acre, respectively. In 2009, a total of 10,600 lbs of daminozide were 

reported used in the surveyed commercial nurseries floriculture operations; the average and 90th

percentile application rate for a single application was reported as 1.5 and 4.2 lbs a.i./acre, 

respectively (database query at: http://quickstats.nass.usda.gov/) (USDA 2007; USDA 2009).

California’s Department of Pesticide Regulation provides detailed pesticide usage for each 

registered chemical. Annual reported use of daminozide ranged between a low of 6,570 pounds

and a high of 9,635 pounds of active ingredient between 2004 and 2012

(http://www.cdpr.ca.gov/docs/pur/pur12rep/tables/table5.pdf); however, no temporal trends in 

total poundage used were identified. 

Daminozide can be used in an enclosed area where environmental exposure is unlikely and in 

non-enclosed areas where environmental exposure may occur. California’s Pesticide Information 

Portal (CALPIP) provides usage data classified as either indoor or outdoor applications. In 2011, 

California indoor use (e.g., greenhouse) accounted for 5117 lbs a.i. and outdoor use (e.g., nonenclosed nursery space) accounted for 3285 lbs a.i., and in 2012, California indoor use accounted 

for 4536 lbs a.i. and outdoor use accounted for 3459 lbs a.i. (database query at:

http://calpip.cdpr.ca.gov/year.cfm). These data confirm that daminozide is applied in both the 

indoor and outdoor settings. 
Page 10 of 37

3 Exposure Analysis

3.1 Environmental Fate Summary

Daminozide is readily soluble in water and is not expected to volatilize from water or soil. It is 

moderately mobile in soil (KOC range of 204-349 L/kg OC) and can move to surface water 

through runoff and spray drift and may leach to groundwater depending on soil conditions. 

Daminozide does not undergo hydrolysis, and aqueous photolysis of daminozide showed a halflife of 162 days. The compound is susceptible to biotic metabolism with an aerobic soil 

metabolism half-life of 9 hours. Due to daminozide’s unique and limited use on containerized 

ornamentals, both terrestrial and aquatic field dissipation study requirements are waived.

Daminozide has an octanol-water partition coefficient (KOW) of 0.0309 (log Kow = -1.51), and 

for this reason, the fish bioaccumulation study was not required. Table 3.1 summarizes the 

submitted chemical and environmental fate data for daminozide.

Table 3.1. Chemical Properties and Environmental Fate Parameters of Daminozide.

Parameter Value Source

Selected Physical/Chemical Parameters

Molecular mass (molecular formula) 160.17 g/mol (C6H12N2O3) (Calculated)

Vapor pressure 1.10 x 10-8torr (20 °C) MRID 49385202

Aqueous solubility (20C) 18,000 mg/L MRID 48395201

Henry’s Law Constant (20°C, pH 7) 1.32 x10-14 atm-m3/mol calculated

Log octanol-to-water partition coefficient

(log KOW) (20°C)

-1.51 (Kow 0.0309) http://www.rsc.org/

pdf/general/16dami

no.pdf

Dissociation constant (pKa) pK1 4.19 (amine), pK2 5.59 (carboxylic acid 

group)

1993 RED

Persistence

Hydrolysis half-life (50oC) No substantial degradation

(pH 5, 7, and 9)

MRID 47188101

Aqueous photolysis half-life (25oC) t1⁄2 = 162 days MRID 47188110

Aerobic soil metabolism half-life (20oC) t1⁄2 = 9.5 hours (0.3958 days) MRID 46164615

Aerobic aquatic metabolism half-life Study is waived Not applicable

Anaerobic aquatic metabolism half-life Study is waived Not applicable

Mobility

Freundlich soil-water partition coefficients 

(Kd); Freundlich organic carbon-normalized 

partition coefficients (KOC)

Kd = 1.26, 5.93, 1.43, and 3.29 (L/kg);

KOC = 315, 349, 204 and 299 (L/kgoc)

MRID 46164616

Fish Bioconcentration

Fish bioconcentration factors (steady-state) Study waived due to low log KOW (-1.51) Not applicable
Page 11 of 37

3.1.1 Transport and Mobility

Daminozide is not expected to significantly volatilize from soil or water bodies based on its 

water solubility (18,000 mg/L), vapor pressure (1.1 x 10-8torr), and Henry’s Law Constant (1.32

x 10-14 atm-m3/mol). According to the FAO mobility classification, daminozide is “moderately 

mobile” in soil with a mean organic carbon adsorption coefficent (Koc) of 292 L/kgoc (range 

from 204 to 349). 

Daminozide may be sorbed to residues in or dissolved in runoff feeding surface water bodies. 

The compound may also reach surface water bodies via spray drift.

3.1.2 Degradation

Daminozide does not undergo hydrolysis in water bodies over the range of pH 5 to 9. It 

degraded in an aqueous photolysis study with the dark-control-adjusted half-life of 162 days, 

indicating that this is not a significant environmental fate pathway. Daminozide biodegraded 

rapidly in soil with a half-life of 9.5 hours (0.3958 days). Aquatic biodegradation studies were 

waived.

3.1.3 Field Studies

Terrestrial field dissipation studies are required for terrestrial outdoor uses. Since the use of 

daminozide on ornamentals in containers is likely to result in minimal offsite transport, EPA

granted a waiver for the field studies.

3.1.4 Environmental Degradates

Based on the aerobic soil metabolism data, sixty-two percent of daminozide mineralized to CO2

within 72 hours of application. The other identified degradate was formaldehyde, and it was 

present at a maximum of four percent of the applied daminozide. 

3.2 Residues of Concern

Daminozide is considered to be the only residue of concern for this risk assessment. 

3.3 Aquatic Exposure

Exposure in surface water from the proposed daminozide uses due to runoff, erosion, and spray 

drift was assessed with the Surface Water Concentration Calculator 1(SWCC ver 1.106). The 

model input parameters, based on the general chemical and environmental fate data for 

daminozide alone and the model input parameter guidance (USEPA 2009), are listed in Table 

3.2. 

 

1 Donald Brady. 2014/04/10. Implementation of the Surface Water Concentration Calculator for use in the 

Environmental Fate and Effects Division (EFED) 
Page 12 of 37

Table 3.2. SWCC Chemical Input Parameters for Daminozide.

Input Parameter Value Comment Source (MRID)

Molecular Mass (g/mol) 160.17 Product chemistry data (Calculated)

Vapor pressure (torr) 1.10 x 10-8 Product chemistry data 48395202

Solubility in Water (mg/L) 18,000 Represents the value at 20 oC 48395201

Organic Carbon Partition Coefficient (KOC) 

(L/kgOC)

292 Represents the mean KOC of four

values (204, 299, 315, and 349)

46164616

Aerobic Soil Metabolism Half-life (days) 1.19 3 times a single half-life value to 

account for uncertainty associated 

with using one value

46164615

Aerobic Aquatic Metabolism Half-life 

(days)

2.37 2 times the aerobic soil input value Modeling Input 

Guidance (2009)

Anaerobic Aquatic Metabolism Half-life 

(days)

0 Assumed stable Modeling Input 

Guidance (2009)

Hydrolysis Half-life (days) (50oC) 0 Represents stability to hydrolysis 47188101

Aqueous Photolysis Half-life (days) (25oC) 162 Dark-control-adjusted half-life 47188110

The Dazide® 85 WSG label specifies that spray applications must only be performed in enclosed 

areas, such as greenhouses, where spray drift outside the treated area cannot occur. However, 

the B-Nine® SP and B-Nine® WSG labels do not have enclosed area requirements.

The maximum application rate is 1 gallon of spray solution containing 0.75% daminozide to 

cover 200 square feet of area. This will provide foliage coverage just to the point of runoff. As 

shown in Section 2.2.1, this is equivalent to a maximum single application rate on treated plants 

of 13.63 lbs a.i./acre. Considering the container nursery layout, the typical production areas are

designed to allow for the orderly, efficient movement of plants into and out of the areas by

workers and to allow easy access for the care of these plants. Yeager and Ingram (2010) 

describe the layout of typical production areas for non-greenhouse nurseries. These areas have

plant beds that are 8 feet wide separated by 2-foot-wide walkways for placement of tightlyspaced containerized plants. Equipment access is provided by a narrow road (10 to 20 feet

wide) every 100 feet between the plant beds and by a 30-foot-wide perimeter road. This

layout results in the production area with approximately 50% of the area consisting of plant

beds, with the remaining area in service roads and access paths. For the operation as a whole,

this estimate does not account for propagation areas, media preparation and storage areas,

service areas (equipment storage and repair facilities, chemical storage areas, offices),

employee facilities, and shipping areas. Itshould be noted that these typical dimensions are

often modified based on local conditions.

Assuming the production area is 50% for the plant beds, the maximum application rate used for 

estimation of off-site spray drift and runoff should be adjusted accordingly:

Max rate per application per acre: 13.63 lbs a.i./acre x 50% = 6.82 lbs a.i./acre

The labels also state that “two applications at 1⁄2 to 2⁄3 the label rates may give better control 

than a single application of the total recommended rate;” therefore, an application rate of 9.09

lbs a.i./acre before adjusting for plant bed spacing and an application rate of 4.54 lbs a.i./acre 

after adjusting for plant bed spacing will be used for two applications spaced 48 hours apart. 
Page 13 of 37

Consequently, two application scenarios are modeled for estimating aquatic concentrations of 

daminozide: (1) a single application rate of 6.82 lbs a.i./acre, and (2) two application rates of 

4.54 lbs a.i./acre within 48 hours. 

There are six nursery modeling scenarios available in SWCC database: California, Florida, 

Michigan, New Jersey, Oregon, and Tennessee. To determine the potential high exposure 

situations, the function of “Application Window Batch Analysis” within SWCC was set from 

March 1 to May 31. The first modeling run used March 1 as the first application date and then 

move on to March 2 as the first application date for the second modeling run. The batch analysis 

stops at May 31 as the first application date. The model input parameters to simulate daminozide 

application and crop management practices are provided in Table 3.3. 

Table 3.3. SWCC Scenario and Input Parameters Describing the Maximum 

Proposed Daminozide Use Patterns (outdoor applications only).

Modeling Scenario App. Rate (lbs 

a.i./A)+

App. per 

Year

Depth, 

cm

CAM 

Input

IPSCND 

Input

Application 

Efficiency/ 

Spray Drift

CA Nursery (1 app.) 6.82 1 0 2 1 0.99/0.062

CA Nursery (2 app.) 4.54 2 * 0 2 1 0.99/0.062

FL Nursery (1 app.) 6.82 1 0 2 1 0.99/0.062

FL Nursery (2 app.) 4.54 2 * 0 2 1 0.99/0.062

MI Nursery (1 app.) 6.82 1 0 2 1 0.99/0.062

MI Nursery (2 app.) 4.54 2 * 0 2 1 0.99/0.062

NJ Nursery (1 app.) 6.82 1 0 2 1 0.99/0.062

NJ Nursery (2 app.) 4.54 2 * 0 2 1 0.99/0.062

OR Nursery (1 app.) 6.82 1 0 2 1 0.99/0.062

OR Nursery (2 app.) 4.54 2 * 0 2 1 0.99/0.062

TN Nursery (1 app.) 6.82 1 0 2 1 0.99/0.062

TN Nursery (2 app.) 4.54 2 * 0 2 1 0.99/0.062

+ The application rate used for calculation of drift and runoff reflects a 50% adjustment for non-treated 

areas within the nursery operation. 

* A 2-d interval was modeled between multiple applications.

The SWCC generated highest 1-in-10 year aquatic Estimated Environmental Concentrations

(EECs) for the period from March to May are presented in Table 3.4. The highest values are 

bolded and they are based on Florida and New Jersey nursery scenarios. For the aquatic 

exposure assessment, the concentration values of 123 μg/L, 39.7 μg/L, and 17.3 μg/L, should be 

used for peak, 21-day average, and 60-day average, respectively.
Page 14 of 37

Table 3.4. 1-in-10-year Aquatic EECs of Daminozide (outdoor applications only)

Modeling Scenario Peak (μg/L) 21-day Average (μg/L) 60-day Average (μg/L)

CA Nursery (1 app.) 42.2 9.02 3.24

CA Nursery (2 app.) 39 10.2 4.1

FL Nursery (1 app.) 123 14.7 5.19

FL Nursery (2 app.) 119 17.3 6.1

MI Nursery (1 app.) 35.2 16.7 7.88

MI Nursery (2 app.) 42.8 23.1 11

NJ Nursery (1 app.) 109 33.8 13.3

NJ Nursery (2 app.) 116 39.7 17.3

OR Nursery (1 app.) 27.5 10.1 3.92

OR Nursery (2 app.) 33.4 13.6 5.26

TN Nursery (1 app.) 80 28.5 10.7

TN Nursery (2 app.) 104 35.9 13.1

3.4 Terrestrial Exposure

3.4.1 Direct Deposition onto Food Items for Terrestrial Animals (located on 

treated field)

To estimate exposure concentrations, the ecological risk assessment considers application at the 

maximum rate to fields that have vulnerable soils. This assessment will focus on daminozide 

only. For this assessment, the Terrestrial Residue Exposure (T-REX) model (version 1.5.2) is 

used to assess risks to terrestrial vertebrates (i.e., mammals, birds, terrestrial-phase amphibians 

and reptiles) consuming food directly from the treated field. 

The T-REX model is used to generate upper-bound concentrations of daminozide on food items 

(i.e., grass, broadleaf plants, seeds and arthropods) located on the treated field. The relevant 

single maximum application rate for estimate of daminozide spray residues on plant materials or 

insects on or near the treated plants is 13.63 lbs a.i./acre. The adjustment for untreated pathways 

in the nursery is not made when considering exposure to terrestrial wildlife on or adjacent to the 

treated plants. The resulting concentrations on the treated plants from a single maximum label 

rate application and two closely spaced applications (48-hr interval) at 2⁄3 the maximum single 

rate are provided in Tables 3.5 and 3.6 for birds (surrogate for terrestrial-phase amphibians and 

reptiles) and mammals, respectively. These values are used to represent dietary-based exposures 

and were converted to dose-based exposures using food ingestion rates for mammals and birds.

Daminozide is systemic in plants and magnitude of residue data suitable for calculating a foliar 

dissipation half-life are not available; therefore, for multiple applications of daminozide, the 

default foliar dissipation half-life of 35 days will be used for terrestrial assessments.
Page 15 of 37

Table 3.5 On-Field Upper-bound Kenaga Nomogram EECs for Dietary- and Dose-based 

Exposures of Birds (surrogate for terrestrial-phase amphibians and reptiles) to 

Daminozide (outdoor uses only)

Application Rate 

(Interval days) Dietary Category

Avian Dosed-based EECs

(mg/kg-bwt)

Avian Dietarybased EECs

(mg/kg-diet) 20 g 100 g 1000 g

13.63 lb a.i./acre

(single application at the 

maximum rate)

Short Grass 3742 2134 955 3286

Tall Grass 1715 978 438 1506

Broadleaf plants 2105 1200 537 1848

Fruits/pods 234 133 60 205

Arthropods 1466 836 374 1287

Seeds 52 30 13 205

9.09 lb a.i./acre

(two applications at 2⁄3 

the maximum rate 48 

hours apart)

Short Grass 4873 2779 1244 4278

Tall Grass 2233 1274 570 1961

Broadleaf plants 2741 1563 700 2407

Fruits/pods 305 174 78 267

Arthropods 1909 1088 487 1676

Seeds 68 39 17 267

Table 3.6 On-Field Upper-bound Kenaga Nomogram EECs for Dietary- and Dose-based 

Exposures of Mammals to Daminozide (outdoor uses only)

Application Rate 

(Interval days) Dietary Category

Mammalian Dosed-based EECs

(mg/kg-bwt)

Mammalian

Dietary-based 

EECs

(mg/kg-diet) 15 g 35 g 1000 g

13.63 lb a.i./acre

(single application at the 

maximum rate)

Short Grass 3133 2165 502 3286

Tall Grass 1436 992 230 1506

Broadleaf plants 1762 1218 282 1848

Fruits/pods 196 135 31 205

Arthropods 1227 848 197 1287

Seeds 44 30 7.0 205

9.09 lb a.i./acre

(two applications at 2⁄3 the 

maximum rate 48 hours apart)

Short Grass 4079 2819 654 4278

Tall Grass 1870 1292 300 1961

Broadleaf plants 2295 1586 368 2407

Fruits/pods 255 176 41 267

Arthropods 1598 1104 256 1676

Seeds 57 39 9.1 267
Page 16 of 37

3.4.2 Drift and runoff to non-target terrestrial plants.

The spray drift and runoff exposure concentrations as calculated by TerrPlant 1.2.2 are provided 

in Table 3.7. These figures represent point estimates of off-field exposure based on the 

maximum single application rate of 6.82 lbs ai/acre. The application rate of 6.82 lbs a.i./acre 

accounts for targeted application on nursery plants and not on pathways in the nursery (see 

Section 3.3).

Table 3.7 EECs for daminozide exposure to off-field non-target plants (outdoor uses only)

Exposure Description Equation# EEC (lbs a.i./acre)

Runoff to dry areas (A/I)*R 0.34

Runoff to semi-aquatic areas (A/I)*R*10 3.41

Spray drift A*D 0.068

Total for dry areas ((A/I)*R)+(A*D) 0.408

Total for semi-aquatic areas ((A/I)*R*10)+(A*D) 3.476

# A= application rate (=6.82 lbs ai/acre)

I = incorporation depth (=1 inch, default)

R = runoff fraction (=0.05, for solubility >100mg/L)

D = drift fraction (=0.01, for ground spray)

4 Effects Analysis

This section summarizes the available toxicity data for daminozide. Additional details on the 

daminozide ecotoxicity studies are provided in Appendix A. The endpoints used for deriving

risk quotient (RQ) values are provided in Tables 4.1 and 4.2. Toxicity data were obtained from 

registrant-submitted studies and the scientific literature. A search of the publically available 

ecotoxicity data cataloged in EPAs ECOTOX database (http://cfpub.epa.gov/ecotox/) did not 

identify any studies with endpoints more sensitive than those submitted to the Agency within the 

categories of mortality, growth, and reproduction for animals and plants. 

In addition, the Ecological Incident Information System (EIIS), the Avian Incident Monitoring 

System (AIMS) and aggregate incident databases were searched for incident reports on April 30, 

2014. No ecological incidents were reported in any of the evaluated databases. 

4.1 Toxicity of Daminozide

For aquatic animals, daminozide is classified as practically non-toxic to fish and slightly toxic to 

invertebrates on an acute exposure basis (Table 4.1). No reproduction data are available for fish 

or invertebrates. The only aquatic plant species tested, a green algae, had a NOAEC of 99.8 mg 

a.i./L.

Daminozide is practically non-toxic to birds and mammals on an acute exposure basis (Table 
Page 17 of 37

4.2). In a reproduction study with bobwhite quail, there was a 5% reduction in the percent of 

surviving 14-day chicks relative to number hatching at 890 mg a.i./kg-diet, resulting in a no 

observed adverse effect concentration (NOAEC) of 365 mg a.i./kg-diet. Available toxicity data 

for mammals did not identify any reproductive or offspring effects at doses up to 500 mg a.i./kgbw/day (Daminozide (Alar). Draft Risk Assessment to Support Registration Review; 

DPbarcode: D411596).

Daminozide is practically non-toxic to adult honey bees on an acute exposure basis; data are not 

available to assess the toxicity to adult bees through ingestion of residues in pollen/nectar nor are 

data available on the toxicity of the compound to larval bees.

Available data for terrestrial plants indicate that dicotyledonous (dicots) species are more 

sensitive than monocotyledonous (monocots) species. No effects to monocots were indicated at 

rates up to 11.5 lbs a.i./acre. The most sensitive dicot exposed to daminozide during the 

vegetative vigor study was soybean. Twenty-five percent plant height reductions (IC25) were 

predicted at 7.71 lbs a.i./acre and significant reductions (p<0.05) were detected at all test 

concentrations (NOAEC < 0.709 lb a.i./acre). A 5% reduction in plant height (IC05) was 

predicted at 0.39 lb a.i./acre. 

Table 4.1. Measurement Endpoints for Aquatic Organisms Exposed to Daminozide

Assessment Endpoint Species Toxicity Value * Reference and 

Study 

Classification

Comments

Freshwater fish** Rainbow trout

Salmo gairdneri

96-hr LC50 = 149.3 

mg a.i./L 

MRID 00097046

Acceptable

PF identified a different 

study; MRID 00097046

was subsequently 

identified as having a 

lower LC50. Fish were 

lethargic and swam 

erratically at test 

concentration of 180 mg 

a.i./L

Freshwater invertebrates Waterflea

Daphnia magna

48-hr EC50 > 100

mg a.i./L

MRID 47188103

Acceptable

PF identified a different 

study; MRID 47188103

was recently submitted to 

the Agency. No mortality 

or sub-lethal effects were 

reported.

Estuarine/marine fish 

and invertebrates No data No data No data

Vascular aquatic plant No data No data No data

Non-vascular aquatic 

plant

Green alga 

Pseudokirchneriella 

subcapitata

72-hr IC50 >99.8 

mg a.i./L

NOAEC = 99.8 mg 

a.i./L

MRID 47188106 

Supplemental

No growth reductions or 

phytotoxic effects

observed

*For animals, LC/EC50 values are used to evaluate acute exposures and NOAEC values are used for chronic 

exposures. Only acute data are available for this aquatic toxicity assessment.

** Freshwater fish represent surrogates for aquatic-phase amphibians.
Page 18 of 37

TABLE 4.2. Measurement Endpoints for Terrestrial Organisms Exposed to Daminozide

Taxonomic 

group

Study type and 

Species

Toxicity Value* Reference and 

Study 

Classification

Comments

Birds**

Acute Oral –

Mallard duck (Anas 

platyrhynchos)

LD50 > 4640 mg 

a.i./kg-bw

MRID 00009703

Supplemental

No mortality

Sub-acute Dietary –

Bobwhite quail 

(Colinus 

virginianus)

LC50 > 10,000 mg 

a.i./kg-diet

MRID 2030700 

Acceptable

No mortality

Avian Reproduction 

- Bobwhite quail

NOAEC = 365 mg 

ai/kg-diet

MRID 48791803

Acceptable

Most sensitive endpoint: 

percent of surviving 14-

day chicks relative to 

number hatching reduced 

at 890 mg a.i./kg-diet

Terrestrial 

mammals

Acute Oral –

Laboratory Rat

LD50 >5000 mg 

a.i./kg-bw

MRID 46164609 

Acceptable

No mortality.

2-generation –

Laboratory Rat 

Reproductive:

NOAEL ≥ mg

a.i./kg-bw/day 

MRID 40233901 No reproductive or 

offspring effects observed. 

(DPbarcode: D411596)

Terrestrial 

insects

Acute Contact –

Honey bee 

(Apis mellifera)

LD50 > 205 μg ai/bee MRID 00018842

Acceptable

PF identified a different 

toxicity value; the correct 

value from the study is 

reported here. 

Terrestrial 

plants 

Seedling emergence 

- Monocot

IC25>11.5 lb a.i./acre

NOAEC =11.5 lb 

a.i./acre

MRID 48791804

Acceptable

No effects on survival or 

growth for monocot 

(onion, Allium cepa; 

ryegrass, Lolium perenne; 

wheat, Triticum aestivum; 

and corn, Zea mays) and 

dicot (sugarbeet, Beta 

vulgaris; oilseed rape, 

Brassica napus; cabbage, 

Brassica oleracea; 

soybean, Glycine max; 

lettuce, Lactuca sativa; 

and tomato, Lycopersicon 

esculentum)

Seedling emergence 

- Dicot

IC25>11.3 lb a.i./acre

NOAEC =11.3 lb 

a.i./acre

Vegetative vigor -

Monocot

IC25>11.5 lb a.i./acre

NOAEC =11.5 lb 

a.i./acre

MRID 48791805

Acceptable

No effects on survival or 

growth for onion, 

ryegrass, wheat, and corn.

Vegetative vigor -

Dicot (most 

sensitive- soybean)

IC25= 7.71 lb a.i./acre

NOAEC <0.709 lb 

a.i./acre (lowest 

concentration)

IC05 = 0.39 lb 

a.i./acre

For dicots, soybean height 

most sensitive parameter. 

Significant reductions at 

all test concentrations. 

*For birds and mammals, LC50 and LD50 values are used to evaluate acute exposures and NOAEC and NOAEL 

values are used for reproduction studies. For terrestrial plants, IC25 values are used to evaluate non-listed species, 

and NOAEC values are used to evaluate listed species. 

** Birds are considered surrogates for terrestrial-phase amphibians and reptiles. 
Page 19 of 37

4.2 Endocrine Disruptor Screening Program

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse 

outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and 

chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, 

reproductive, and general or systemic toxicity. These studies include endpoints which may be 

susceptible to endocrine influence, including effects on endocrine target organ histopathology, 

organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, 

and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and 

chronic studies that assess growth, developmental and reproductive effects in different 

taxonomic groups. As part of the Preliminary Problem Formulation for Registration Review (DP 

Barcode 342370), EPA reviewed these data and selected the most sensitive endpoints for 

relevant risk assessment scenarios from the existing hazard database. However, as required by 

FFDCA section 408(p), daminozide is subject to the endocrine screening part of the Endocrine 

Disruptor Screening Program (EDSP). 

EPA has developed the EDSP to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator 

may designate.” The EDSP employs a two-tiered approach to making the statutorily required 

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a 

chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal 

systems. Chemicals that go through Tier 1 screening and are found to have the potential to 

interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA 

will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 

testing is designed to identify any adverse endocrine-related effects caused by the substance, and 

establish a dose-response relationship between the dose and the E, A, or T effect. 

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between 

October 2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 

chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. A second list 

of chemicals identified for EDSP screening was published on June 14, 2013

(http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0477-0074) and 

includes some pesticides scheduled for registration review and chemicals found in water. Neither 

of these lists should be construed as a list of known or likely endocrine disruptors. 

Daminozide is not on the first or the second list of chemicals identified for EDSP screening.

Further information on the status of the EDSP, the policies and procedures, the lists of chemicals, 

future lists, the test guidelines and the Tier 1 screening battery is available at 

http://www.epa.gov/endo/.

5 Risk Characterization

For this preliminary assessment of daminozide, the deterministic RQ method was used to provide 

a metric of potential risks. The RQ is a comparison of exposure estimates to toxicity endpoints

(i.e., RQ = EEC/toxicity endpoint). The resulting RQs are compared to the Agency’s risk levels 
Page 20 of 37

of concern (LOC), which are the Agency’s interpretive policy such that when acute or chronic 

risk LOCs are exceeded, the need for regulatory action may be considered. The LOCs are used 

to indicate when the use of a pesticide, as directed on the label, has the potential to cause adverse 

effects to non-target organisms. For acute and chronic risks to animals, the LOCs are 0.5 and 1.0, 

respectively, and for plants, the LOC is 1.0. For each taxon, RQs are generated and risks are 

discussed. This discussion includes consideration of additional data and lines of evidence such as 

environmental monitoring and ecological incident data

5.1 Aquatic Organisms

For fish, an RQ was generated using the most conservative EEC derived from SWCC (i.e., FL 

nursery with one application per year had peak EEC =123 μg a.i./L) and the most conservative 

acute endpoint for fish (Table 5.1). For outdoor uses of daminozide, the acute RQ for fish does 

not exceed the LOC for non-listed species (i.e., 0.5) or the LOC for listed species (i.e., 0.05). 

Since the endpoints from the invertebrate and aquatic plant studies were non-definitive (EC50 > 

101000 μg a.i./L and IC50 >98000 μg a.i./L), respectively), RQs were not calculated. Acute risks 

to invertebrates and non-vascular plants are presumed low as the EEC was approximately 1000 

times less than the highest test concentrations. 

Table 5.1. Daminozide RQs for acute exposures to aquatic organisms (outdoor uses only)

Taxa EEC (μg a.i./L) Endpoint (μg a.i./L) RQ

Fish

123*

149300 <0.001

Aquatic 

invertebrates >101000 **

Aquatic 

non-vascular plants >98000 ***

*Highest modeled aquatic concentration of daminozide (FL nursery with one application per year at a rate of 6.82 

lbs a.i./acre, accounting for non-treated walkways in the nursery)

** An RQ was not calculated; however, the highest EEC is approximately 1000 times less than the highest test 

concentration in the acute daphnid study.

*** An RQ was not calculated; however, the highest EEC is approximately 1000 times less than the highest test 

concentration in the green algae study.
Page 21 of 37

Although an RQ was not calculated for determining chronic risk to fish (due to a lack of toxicity 

data), effects to growth and reproduction are not expected because the chronic toxicity of 

daminozide would have to be at least 8600 times greater than the acute toxicity (LC50 = 149300

μg a.i./L) in order to equal or exceed the chronic LOC of 1.02. Similarly for aquatic 

invertebrates, effects to growth and reproduction are not expected as the chronic toxicity would 

have to be at least 2500 times greater than the highest tested acute concentration in daphnids 

(100,000 μg a.i./L with no lethal or sublethal effects observed) in order to equal or exceed the 

chronic LOC of 1.03. It is unlikely that daminozide would be orders of magnitude more toxic to 

fish or aquatic invertebrates on a chronic exposure basis than on an acute exposure basis because 

this pattern has not been observed in other taxa (i.e., birds and mammals). In addition, observed 

acute-to-chronic ratios (ACR) of 8600 and 2500 are unlikely given that median and 90th

percentile aquatic ACRs calculated from the available toxicity data in the EFED toxicity 

database were 8.3 and 79.5, respectively (Raimondo et al. 2007). Therefore, the likelihood that 

runoff and drift from use of daminozide will result effects on survival, growth, and reproduction

of non-listed aquatic organisms via long-term exposure is considered low.

Although only one aquatic plant species (Pseudokirchneriella subcapitata) was tested, the 

highest test concentration can be used to characterize low thresholds of effect as no effects were 

observed at any test concentration. The NOAEC for non-vascular aquatic plants is 98 mg a.i./L. 

The high-end estimate of exposure, i.e., 123 μg a.i./L, is 800 times lower than the NOAEC for 

non-vascular aquatic plants. This indicates, with some uncertainty since only one non-vascular 

plant species was tested, that adverse effects to other species of non-vascular aquatic plants are

unlikely. In addition, given the large differential between the NOAEC for non-vascular plants 

and the EEC, it is reasonable to presume that effects to vascular aquatic plants are also unlikely.

5.2 Terrestrial Organisms

5.2.1. Birds, Amphibians and Reptiles

As birds are considered surrogates for terrestrial-phase amphibians and reptiles, conclusions 

related to risks to birds also applied to risks to terrestrial-phase amphibians and reptiles.

Although daminozide is classified as practically non-toxic to birds on an acute oral exposure 

basis (LD50 >4640 mg a.i./kg-bw with no mortalities) and sub-acute dietary basis (LC50 > 10,000 

mg a.i./kg-diet with no mortalities), and the reproductive endpoint (NOAEC = 365 mg a.i./kgdiet, based on ratio of number of 14-day-old chicks to hatched chicks) suggests low toxicity, risk 

cannot be precluded due to potential high exposures from high application rates.

Since definitive toxicity endpoints were not determined in the acute and sub-acute studies for 

birds and no mortality was observed in these studies, RQs were not calculated. The highest 

 

2 Using a 60-day aquatic EEC of 17.3 μg a.i/L, a fish chronic NOAEC of 17.3 μg a.i/L or less would be necessary to 

exceed the chronic LOC (1.0). The resulting Acute-to-Chronic Ratio (ACR) would be calculated as 149300/17.3 = 

8630. Therefore, the chronic NOAEC would need to be at least 8600 times lower that the LC50 for the chronic LOC 

to be exceeded.

3 Using a 21-day aquatic EEC of 39.7 μg a.i/L, an aquatic invertebrate chronic NOAEC of 39.7 μg a.i/L or less 

would be necessary to exceed the chronic LOC (1.0). The resulting ACR would be calculated as 101000/39.7 = 

2540. Therefore, the chronic NOAEC would need to be at least 2500 times lower that the highest test concentration 

in the acute test for the chronic LOC to be exceeded.
Page 22 of 37

concentration tested for the acute oral study (4640 mg a.i./kg-bw) is less than the 

environmentally relevant exposure concentration (the highest ratio of exposure to toxicity is 

1.55, for small birds consuming short grass). The highest concentration tested for the sub-acute 

dietary study (10,000 mg a.i./kg-diet) is greater than the environmentally relevant exposure 

concentration (the highest ratio of exposure to toxicity is 0.33 for birds consuming short grass).

Table 5.2 presents chronic RQs based on dietary exposures. Exposure estimates represent single 

application of daminozide at the maximum labeled use rate and two applications 48 hours apart

at 2⁄3 the maximum labeled rate (Table 3.5). Exposure estimates and RQs were calculated using 

T-REX 1.5.2. As indicated in these tables, daminozide application at the maximum labeled rates 

results in chronic LOC exceedances for consumers of short grass, tall grass, broadleaf plants, and 

arthropods feeding at the treated sites.

Table 5.2 Upper-bound Kenaga Nomogram RQs for Chronic Dietary- Exposures of Birds 

to Daminozide (outdoor uses only) 

Application Rate 

(Interval days) Dietary Category

Avian Chronic Dietary based RQs

(mg/kg-diet) *

13.63 lb a.i./acre

(single application at 

the maximum rate)

Short Grass 9.00

Tall Grass 4.13

Broadleaf plants 5.06

Fruits/pods/seeds 0.56

Arthropods 3.53

9.09 lb a.i./acre

(two applications at 2⁄3 

the maximum rate 48 

hours apart)

Short Grass 11.72

Tall Grass 5.37

Broadleaf plants 6.59

Fruits/pods/seeds 0.73

Arthropods 4.59

* Bolded RQs indicate an exceedance of the Chronic LOC (>1.0).

There is uncertainty in the risks to birds for several reasons:

 There was no mortality in the acute oral or dietary bird studies, but the highest evaluated 

exposures were less than the maximum predicted environmental exposures; therefore, 

risks cannot be precluded.

 None of the target plant species listed on the labels are grasses; however, drift of 

daminozide to adjacent ornamental grasses or grassy weeds may occur. Exposure to short 

and tall grasses cannot be precluded. 

 It is expected that commercial nurseries and floriculture operations would work to 

minimize the occurrence of birds and other taxa within the growing areas in order to 

minimize any damage by birds and other animals that may occur. However, the presence 

of birds, including beneficial pollinators, feeding or moving through the treated plants 

cannot be precluded.

 There is uncertainty associated with the magnitude of exposure resulting from 

applications to ornamentals as labels do not define the maximum number of applications 

per year. EFED assessed risk assuming that only one or two applications would be used 

in a given location in the ornamental plant nursery. However, the labels state that repeat 

applications on the same plants may be necessary. Therefore, exposures to birds may be 
Page 23 of 37

higher than presented. 

 Individual ornamental and floriculture specimens are likely to move through the nursery 

to wholesalers and retailers at rates faster than one cycle per year. Even if individual 

plants are only treated one time while in the nursery, daminozide exposure to birds may 

be relatively continuous throughout the year as the mature plant stocks move out of the 

nursery and new plants stocks move in and are treated. Under this scenario, daminozide 

exposure could be continuous for birds who visit the nursery grounds throughout the year 

and risks to those birds may be higher than the risks to birds only exposed to one or two 

applications annually.

5.2.2 Mammals

Although daminozide is classified as practically non-toxic to mammals on an acute oral exposure 

basis (LD50 >5000 mg a.i./kg-bw with no mortalities) and no reproductive or offspring effects 

were observed in the 2-gen reproduction study (NOAEC = 500 mg a.i./kg-bw/day), risk cannot 

be precluded due to potential high exposures from high application rates.

Since definitive toxicity endpoints were not determined in the acute toxicity study for rats and no 

mortality was observed in these studies, RQs were not calculated. The highest concentration 

tested for the acute oral study (5000 mg a.i./kg-bw) is greater than the highest exposure 

concentration from Table 3.6 (i.e., the highest ratio of exposure to toxicity is 0.37 for small 

mammals consuming short grass). Since estimated exposure is less than the highest tested acute 

toxicity level and no effects were observed in the toxicity study, acute risk to mammals from 

currently labeled use rates of daminozide is low. 

As with the acute oral exposure, RQs were not calculated for evaluation of chronic risks as a 

definitive NOAEC was not determined in the reproduction study. Based on dietary intake 

estimates, the highest ratio of exposure to high test concentration was 0.43 (consumption of short 

grass). Using dose-based intake estimates, the highest ratio of exposure to high test concentration 

was 3.71 (small mammals consuming short grass). Since potential exposure is higher than the 

highest tested dose, chronic risk to mammals eating on treated sites cannot be precluded. 

There is uncertainty in the risks to mammals for several reasons:

 None of the target plant species listed on the labels are grasses; however, drift of 

daminozide to adjacent ornamental grasses or grassy weeds may occur. Exposure to short 

and tall grasses cannot be precluded. 

 It is expected that commercial nurseries and floriculture operations would work to 

minimize the occurrence of mammals and other taxa within the growing areas in order to 

minimize any damage that may occur. However, the presence of mammals feeding or 

moving through the treated plants cannot be precluded.

 There is uncertainty associated with the magnitude of exposure resulting from 

applications to ornamentals as labels do not define the maximum number of applications 

per year. EFED assessed risk assuming that only one or two applications would be used 

in a given location in the ornamental plant nursery. However, the labels state that repeat 

applications on the same plants may be necessary. Therefore, exposures to mammals may 

be higher than presented. 
Page 24 of 37

 Individual ornamental and floriculture specimens are likely to move through the nursery 

to wholesalers and retailers at rates faster than one cycle per year. Even if individual 

plants are only treated one time while in the nursery, daminozide exposure to mammals

may be relatively continuous throughout the year as the mature plant stocks move out of 

the nursery and new plants stocks move in and are treated. Under this scenario, 

daminozide exposure could be continuous for mammals who visit the nursery grounds 

throughout the year and risks to those mammals may be higher than the risks to mammals

only exposed to one or two applications annually.

5.2.3. Terrestrial Invertebrates

Daminozide is classified as practically non-toxic to adult honeybees on an acute contact 

exposure basis, and with LD50 > 205 μg ai/bee. RQ values were not calculated because no 

definitive toxicity endpoints were available for honeybees; however, due to low toxicity the 

potential for adverse effects form contact exposure to daminozide residues on plants is expected 

to be low. Studies reported in EPAs ECOTOX database did not identify any terrestrial 

invertebrate species with a greater sensitivity to daminozide.

5.2.4. Plants

The measurement endpoint (IC25) for non-listed dicot plants is 7.71 lb a.i./A, based on effects to 

vegetative vigor (reduction in soybean plant height). For listed dicot plants, the measurement 

endpoint (IC05) is 0.35 lbs a.i./acre as the NOAEC was not defined (less than the lowest test 

concentration). No effects to monocots were indicated at rates up to 11.5 lbs a.i./acre. Using 

TerrPlant 1.2.2 (Table 5.2), all calculated RQs were less than the LOC (1.0); therefore, off-field 

drift risks to non-target plants is presumed to be low. 

Table 5.2 RQ values for plants in dry and semi-aquatic areas exposed to daminozide 

through runoff and/or spray drift* (outdoor uses only)

Plant Type Listed Status Dry Semi-Aquatic Spray Drift

Monocot non-listed <0.1 0.30 <0.1

Monocot listed <0.1 0.30 <0.1

Dicot non-listed <0.1 0.31 <0.1

Dicot listed <0.1 0.31 0.17

*If RQ > 1.0, the LOC is exceeded, resulting in potential for risk to that plant group.

5.3 Listed Species

Although EPA has not completed effects determinations for most listed species associated with 

the registered uses of daminozide, this analysis indicates that direct effects to fish, aquatic 

invertebrates, aquatic plants, terrestrial invertebrates, monocot plants (in terrestrial and wetland 

habitats), and dicot plants (in terrestrial and wetland habitats) are unlikely. Risk cannot be 

precluded for birds, terrestrial-phase amphibians, reptiles, and mammals. Indirect effects may 

occur to listed animals and plants that rely upon birds, terrestrial-phase amphibians, reptiles, 

and/or mammals for food or shelter. 
Page 25 of 37

“No Effect (NE)” determinations can be made for listed species of fish, aquatic-phase 

amphibians (that do not have terrestrial-phases), aquatic invertebrates, aquatic plants, terrestrial 

insects, monocot plants (in terrestrial and wetland habitats), and dicot plants (in terrestrial and 

wetland habitats) that do not rely upon birds, terrestrial-phase amphibians, reptiles, and/or 

mammals for food and shelter. For all other species, the effect determinations are uncertain.

5.4 Risk Conclusions

Based on the estimated environmental exposure levels coupled with acute and reproductive

toxicity estimates, currently labeled rates of daminozide pose a potential risk to non-target 

terrestrial animals, including birds, reptiles, terrestrial-phase amphibians and mammals. The risk

conclusions are summarized as follows:

 Direct adverse effects are not expected for aquatic animals, aquatic plants, and terrestrial 

plants exposed to daminozide following spray drift and runoff. 

 Direct adverse effects are not expected for terrestrial invertebrates exposed to daminozide 

on the treated plants or off-site drift.

 For birds (and terrestrial-phase amphibians and reptiles, for which birds are considered 

surrogates), risk due to outdoor uses of daminozide cannot be precluded. 

 For mammals, chronic risk due to outdoor daminozide exposures cannot be precluded. 

Acute risk to mammals is low.

 “No Effect (NE)” determinations can be made for listed species of fish, aquatic-phase 

amphibians (that do not have terrestrial-phases), aquatic invertebrates, aquatic plants, 

terrestrial invertebrates, monocots (in terrestrial and wetland habitats), and dicots (in 

terrestrial and wetland habitats) that do not rely upon birds, terrestrial-phase amphibians, 

reptiles, and/or mammals (for food or shelter).

 Effect determinations for listed species of birds, terrestrial-phase amphibians, reptiles, 

and mammals are uncertain. Effects determinations for any listed species that relies on 

birds, terrestrial-phase amphibians, reptiles, and/or mammals (for food or shelter) are 

uncertain.
Page 26 of 37

6 References

Brewerton, H.V., M.M. Gibbs and R.M. Davison. 1972. Dimas (‘alar’) residues in apples and 

Chinese gooseberries (Actinidia chinensis Planch), New Zealand Journal of Agricultural 

Research, 15:2, 388-394.

Kvien, C.S., R.A. DePalma, A.R. Raczynski, and L.M. Hellmann. 1989. Effect of Soil and Foliar 

Daminozide Applications on Residue Levels in Peanut. Journal of Agricultural and Food 

Chemistry 37: 200-203.

Rademacher W. 2000. Growth retardants: effects on gibberellin biosynthesis and other metabolic 

pathways. Annual Review of Plant Physiology and Plant Molecular Biology 51:501-531.

Raimondo, S., B.J. Montague and M.G. Barron. 2007. Determinants of variability in acute to 

chronic ratios for aquatic invertebrates and fish. Environ. Toxicol. Chem. 26:2019-2023.

USDA. 2007. Agricultural Chemical Usage 2006 Nursery and Floriculture Summary. December 

2007. U.S. Department of Agriculture, National Agricultural Statistics Service. Ag Ch 1 (07).

USDA. 2009. Statistical Methodology: Nursery and Floriculture Chemical Use Survey 

(NFCUS), 2009. Online at: 

http://www.nass.usda.gov/Surveys/Guide_to_NASS_Surveys/Chemical_Use/ChemUseNurseryF

loricultureStatisticalMethodology.pdf

USEPA. 2009. Guidance for Selecting Input Parameters in Modeling the Environmental Fate 

and Transport of Pesticides. Version 2.1. U.S. Environmental Protection Agency, Office of 

Pesticide Programs, Environmental Fate and Effects Division, Oct. 22, 2009. Online at: 

http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm

Yeager, T.H. and D. L. Ingram. 2010. Layout and Design Considerations for a Wholesale

Container Nursery. CIR558, Environmental Horticulture Department, Florida

Cooperative Extension Service, Institute of Food and Agricultural Sciences, University of 

Florida.
Page 27 of 37

Appendix A. Summary of All Ecotoxicity Data

Table A1. Daminozide Toxicity Data for Freshwater Fish 

Species Toxicity Value Reference and 

Study Classification

Comments

Rainbow trout

Salmo gairdneri 96-hr LC50 = 149.3 mg a.i./L 

MRID 00009706

MRID 00096322

Acceptable

Fish were lethargic and 

swam erratically at test 

concentration of 180 mg 

a.i./L

Rainbow trout 96-hr LC50 > 100 μg a.i./L

MRID 00009732

MRID 00140204

Supplemental

One mortality at 17.8 μg 

a.i./L and 31.6 8 μg a.i./L. 

Rainbow trout 96-hr LC50 > 5 mg a.i./L MRID 00024631

Supplemental

End-use product (B-Nine) 

with 5% daminozide was 

used. No mortalities were 

recorded.

Rainbow trout NA MRID 00009730

Invalid

Polyethylene liners used in 

all test vessels.

Bluegill sunfish 

Lepomis macrochirus 96-hr LC50 = 448 mg a.i./L

MRID 00009704

MRID 00143056

Acceptable

Moribund fish became dark 

and lethargic, then lost 

equilibrium and died.

Bluegill sunfish 96-hr LC50 > 562 μg a.i./L MRID 00009733

Supplemental No mortalities.

Bluegill sunfish 96-hr LC50 > 5 mg a.i./L MRID 00024630

Supplemental

End-use product (B-Nine) 

with 5% daminozide was 

used. No mortalities were 

recorded.

Bluegill sunfish NA MRID 00009730

Invalid

Polyethylene liners used in 

all test vessels.

Common carp 

Cyprinus carpio LC50 >100 mg a.i./L MRID 47188104Acceptable

No mortality or sublethal 

effects at any test 

concentration.

Table A2. Daminozide Toxicity Data for Freshwater Invertebrates

Species Toxicity Value Reference and Study 

Classification

Comments

Waterflea

Daphnia magna 48-hr EC50 > 100 mg a.i./L MRID 47188103Acceptable

No mortality or sub-lethal 

effects were reported.

Waterflea 48-hr EC50 > 100 mg a.i./L

96-hr EC50 = 71 mg a.i./L

MRID 42429002

Supplemental

Due to length of test, 

daphnids were fed 

Selenastrum capricornutum.

Waterflea NA MRID 00009576

Invalid

Precipitate observed at all 

test levels.
Page 28 of 37

Table A3. Daminozide Toxicity Data for Non-vascular Aquatic Plants

Species Toxicity Value Reference and 

Study Classification

Comments

Green alga 

Pseudokirchneriella subcapitata 72-hr EC50 >99.8 mg a.i./L MRID 47188106 

Supplemental

No growth reductions or 

phytotoxic effects

observed

TABLE A4. Daminozide Toxicity Data for Acute Oral Exposure to Birds

Species Toxicity Value Reference and 

Study 

Classification

Comments

Mallard duck 

Anas platyrhynchos

LD50 > 2250 mg a.i./kg-bw MRID 42429001

Acceptable

No mortality

Mallard duck

LD50 > 4640 mg a.i./kg-bw MRID 00009703

Supplemental

No mortality, 14-day old 

birds were used.

Japanese quail 

Coturnix coturnix japonica

LD50: >2250 mg a.i./kg-bw MRID 47188105

Acceptable

No mortality or sublethal 

effects

TABLE A5. Daminozide Toxicity Data for Dietary Exposure to Birds

Species Toxicity Value Reference and 

Study 

Classification

Comments

Bobwhite quail 

Colinus virginianus

LD50 > 4640 mg a.i./kg-diet MRID 00009416

Supplemental

No mortality, 

Bobwhite quail 

LC50 > 10,000 mg a.i./kg-diet MRID 00009705

Acceptable

No mortality, reduced 

weight gain at 10,000 mg 

a.i./kg-diet

Mallard duck LC50 > 10,000 mg a.i./kg-diet MRID 00009575

Acceptable

No mortality or sublethal 

effects.

TABLE A6. Daminozide Chronic Toxicity Data for Exposure to Birds (Reproduction)

Species Toxicity Value Reference and 

Study 

Classification

Comments

Bobwhite quail

NOAEC = 365 mg ai/kg-diet MRID 48791803

Acceptable

Most sensitive endpoint: 

percent of surviving 14-

day chicks relative to 

number hatching reduced 

at 890 mg a.i./kg-diet

Mallard duck NOAEC = 890 mg ai/kg-diet MRID 48791802

Acceptable

No growth or reproductive 

effects.
Page 29 of 37

TABLE A7. Daminozide Toxicity Data for Contact Exposure to Honey Bees

Species Toxicity Value Reference and Study 

Classification Comments

Honey bee 

Apis mellifera

LD50 > 205 μg ai/bee MRID 00018842

Acceptable

Mortalities not reported.

TABLE A8. Daminozide Toxicity Data for Terrestrial Plants

Study type and Plant 

classification

Toxicity Value Reference and 

Study 

Classification

Comments

Seedling emergence -

Monocot

IC25>11.5 lb a.i./acre

NOAEC =11.5 lb a.i./acre

MRID 48791804

Acceptable

No effects on survival or growth for 

monocot (onion, Allium cepa; 

ryegrass, Lolium perenne; wheat, 

Triticum aestivum; and corn, Zea 

mays) and dicot (sugarbeet, Beta 

vulgaris; oilseed rape, Brassica 

napus; cabbage, Brassica oleracea; 

soybean, Glycine max; lettuce, 

Lactuca sativa; and tomato, 

Lycopersicon esculentum)

Seedling emergence -

Dicot

IC25>11.3 lb a.i./acre

NOAEC =11.3 lb a.i./acre

Vegetative vigor -

Monocot

IC25>11.5 lb a.i./acre

NOAEC =11.5 lb a.i./acre

MRID 48791805

Acceptable

No effects on survival or growth for 

onion, ryegrass, wheat, and corn.

Vegetative vigor - Dicot 

(most sensitivesoybean)

IC25= 7.71 lb a.i./acre

NOAEC <0.709 lb 

a.i./acre (lowest 

concentration)

IC05 = 0.39 lb a.i./acre

For dicots, soybean height most 

sensitive parameter. Significant 

reductions at all test concentrations. 
Page 30 of 37

Appendix B. MRID Bibliography for Environmental Fate and Toxicity Studies

850.1010 Aquatic invertebrate acute toxicity, test, freshwater daphnids

MRID Citation Reference

47188103 Manson, P.; Scholey, A. (2005) Daminozide Technical: Acute Toxicity to 

Daphnia magna: Final Report. Project Number: 2242/039, 2242/039/D2149. 

Unpublished study prepared by Covance Laboratories, Ltd. 33 p.

42429002 Lintott, D. (1992) Alar Technical: Acute Toxicity to the Water Flea, Daphnia 

magna, under Flow-through Test Conditions: Lab Project Number: 

J9202003B. Unpublished study prepared by Toxikon Environmental Sciences. 

24 p. 

850.1075 Fish acute toxicity test, freshwater and marine

MRID Citation Reference

3059 Weir, R.J. (1966) Final Report: Acute Toxicity in Aqueous Exposure to 

Bluegill Sunfish: Project No. 798-100. (Unpublished study received Dec 14, 

1966 under 400-EX-27; prepared by Hazleton Lab- oratories, Inc., submitted 

by Uniroyal Chemical, Bethany, Conn.; CDL:123429-B) 

76405 Weir, R.J.; Rathbun, F. (1966) Final Report: Acute Toxicity in Aqueous 

Exposure to Bluegill Sunfish: Project No. 798-100. (Unpublished study 

received Apr 10, 1967 under 400-82; prepared by Hazleton Laboratories, Inc., 

submitted by Uniroyal Chemical, Bethany, Conn.; CDL:090718-G) 

112368 Weir, R.; Rathbun, F. (1966) Acute Toxicity in Aqueous Exposure to Bluegill 

Sunfish: ?Alar 85 and Other Compounds|: Project No. 798-100. Final rept. 

(Unpublished study received May 29, 1967 under 7F0614; prepared by 

Hazleton Laboratories, Inc., submitted by Uniroyal Chemical, Bethany, CT; 

CDL:092906-C) 

140204 Weir, R.; Hopkins, M. (1966) Acute Aqueous Exposure: Rainbow Trout: Alar85 and F461-75W: Project No. 798-100. Final rept. (Unpublished study 

received Dec 3, 1969 under 400-90; prepared by Hazleton Laboratories, Inc., 

submitted by Uniroyal Chemical, Bethany, CT; CDL:003277-E) 

143056 Sleight, B. (1972) Acute Toxicity of Alar to Bluegill (Lepomis ma- crochirus). 

Unpublished Bioassay study prepared by Bionomics, Inc. 7 p. 
Page 31 of 37

47188104 Manson, P.; Scholey, A. (2005) Daminozide Technical: Acute Toxicity to 

Cyprinus carpio: Final Report. Project Number: 2242/038, 2242/038/D2149. 

Unpublished study prepared by Covance Laboratories, Ltd. 34 p.

9704 Sleight, B.H., III (1972) Bioassay Report Submitted to Uniroyal Chemical, 

Naugatuck, Connecticut: Acute Toxicity of Alar(R) to Bluegill (Lepomis 

macrochirus). (Unpublished study received Aug 25, 1977 under 400-79; 

prepared by Bionomics, Inc., submitted by Uniroyal Chemical, Bethany, 

Conn.; CDL:096322-B) 

9706 Kuc, W.J. (1977) Acute Toxicity of Alar Technical, Lot BL 8190 to the 

Rainbow Trout,~?Salmo gairdneri~Richardson: UCES Project No. 11506-29-

04. (Unpublished study received Aug 25, 1977 under 400-79; prepared by 

Union Carbide Corp., submitted by Uniroyal Chemical, Bethany, Conn.; 

CDL:096322-D) 

9730 Mastri, C. (1970) Report to Uniroyal Chemical, Division of Uniroyal, Inc.: 

Four-Day Fish Toxicity Study on Alar-85: IBT No. A8585. (Unpublished 

study received Sep 15, 1970 under unknown admin. no.; prepared by Industrial 

Bio-Test Laboratories, Inc., submitted by Uniroyal Chemical, Bethany, Conn.; 

CDL: 132143-A) 

9732 Weir, R.J. (1966) Final Report: Acute Aqueous Exposure--Rainbow Trout: 

Project No. 798-100. (Unpublished study received Nov 30, 1966 under 

unknown admin. no.; prepared by Hazleton Labora- tories, Inc. for United 

States Rubber Co., submitted by Uniroyal Chemical, Bethany, Conn.; 

CDL:104900-A) 

9733 Weir, R.J. (1966) Final Report: Acute Toxicity in Aqueous Exposure to 

Bluegill Sunfish: Project No. 798-100. (Unpublished study received Nov. 16, 

1966 under unknown admin. no.; prepared by Hazleton Laboratories, Inc. for 

United States Rubber Co., sub- mitted by Uniroyal Chemical, Bethany, Conn.; 

CDL:104902-A) 

24630 McCann, J.A. (1971) ?B-Nine: Toxicity to Bluegill|: Test No. 320. (U.S. 

Agricultural Research Service, Pesticides Regulation Div., Animal Biology 

Laboratory, unpublished report.) 

24631 McCann, J.A. (1971) ?B-Nine: Toxicity to Rainbow Trout|: Test No. 332. 

(U.S. Agricultural Research Service, Pesticides Regu- lation Div., Animal 

Biology Laboratory, unpublished report.) 

29174 Weir, R.J.; Rathbun, F.; Hopkins, M. (1967) ?Acute Toxicity in Aqueous 

Exposure to Bluegill Sunfish and Rainbow Trout|: Project No. 798-100. Final 

rept. (Unpublished study received Dec 12, 1967 under 400-49; prepared by 

Hazleton Laboratories, Inc., sub- mitted by Uniroyal Chemical, Bethany, 

Conn.; CDL:009021-G) 
Page 32 of 37

850.2100 Avian acute oral toxicity test

MRID Citation Reference

9416 Weir, R.J. (1966) Final Report: Acute Dietary Toxicity--Bobwhite Quail: 

Project No. 798-100. (Unpublished study received Dec 15, 1966 under 

7F0552; prepared by Hazleton Laboratories, Inc., sub- mitted by United States 

Rubber Co., Naugatuck, Conn.; CDL: 090684-J) 

9703 Beavers, J.B. (1977) Final Report: Acute Oral LD50--Mallard Duck: Project 

No. 117-121. (Unpublished study received Aug 25, 1977 under 400-79; 

prepared by Wildlife International, Ltd., submit- ted by Uniroyal Chemical, 

Bethany, Conn.; CDL:096322-A) 

42429001 Campbell, S.; Lynn, S. (1992) Alar Technical: An Acute Oral Toxicity Study 

with the Mallard: Lab Project Number: 117-165. Unpublished study prepared 

by Wildlife International, Ltd. 18 p. 

47188105 Gallagher, S.; Beavers, J. (2006) Daminozide Technical: An Acute Oral 

Toxicity Study with the Japanese Quail. Project Number: 429/104. 

Unpublished study prepared by Wildlife International, Ltd. 31 p.

48791801 Hubbard, P.; Beavers, J. (2011) Daminozide: An Acute Oral Toxicity Study 

with the Zebra Finch (Taeniopygia guttata). Project Number: 616/106. 

Unpublished study prepared by Wildlife International, Ltd. 70p.

850.2200 Avian Dietary Toxicity

MRID Citation Reference

9575 Fink, R. (1974) Final Report: Eight-Day Dietary LCI50^--Mallard Ducks: 

Project No. 117-104. (Unpublished study received Oct 13, 1976 under 6F1752; 

prepared by Truslow Farms, Inc., submitted by Uniroyal Chemical, Bethany, 

Conn.; CDL:095567-A) 

9705 Beavers, J.B. (1977) Final Report: Eight-Day Dietary LC50--Bobwhite Quail: 

Project No. 117-126. (Unpublished study received Aug 25, 1977 under 400-79; 

prepared by Wildlife International, Ltd., submitted by Uniroyal Chemical, 

Bethany, Conn.; CDL:096322-C) 
Page 33 of 37

850.2300 Avian reproduction test

MRID Citation Reference

48791802 Frey, L.; Martin, K.; Beavers, J. et al. (2012) Daminozide: A Reproduction 

Study with the Mallard: Final Report. Project Number: 616/105. Unpublished 

study prepared by Wildlife International, Ltd. 197p.

48791803 Frey, L.; Martin, K.; Beavers, J. et al. (2012) Daminozide: A Reproduction 

Study with the Northern Bobwhite: Final Report. Project Number: 616/104. 

Unpublished study prepared by Wildlife International, Ltd. 203p.

850.3020 Honey bee acute contact

MRID Citation Reference

00018842 Atkins, E.L., Jr. J Anderson, L.D.J Greywood, E.A. {1969) Effect of 

Pesticides on Apiculture: Project No. 14991 Research Report CF-7501. 

{Unpublished study received May 8, 1971 under 1F1174; prepared by Univ. of 

California--Riverside, Dept. of Entomology, submitted by Ciba Agrochemical 

co., Summit, N.J., CDL:090973-B) 

850.4225 Seedling emergence, Tier II

MRID Citation Reference

48791804 Sindermann, A.; Porch, J.; Krueger, H. et al. (2012) Daminozide Formulation: 

A Toxicity Test to Determine the Effects (Tier II) on Seedling Emergence of 

Ten Species of Plants: Final Report. Project Number: 616/107. Unpublished 

study prepared by Wildlife International, Ltd. 122p.

850.4250 Vegetative vigor, Tier II

MRID Citation Reference

48791805 Sindermann, A.; Porch, J.; Krueger, H. et al. (2012) Daminozide Formulation: 

A Toxicity Test to Determine the Effects (Tier II) on Vegetative Vigor of Ten 

Species of Plants: Final Report. Project Number: 616/108. Unpublished study 

prepared by Wildlife International, Ltd. 157p.

850.5400 Algal toxicity, Tiers 1 and II

MRID Citation Reference
Page 34 of 37

47188106 Manson, P.; Scholey, A. (2006) Daminozide Technical: Inhibition of Growth 

to the Alga Pseudokirchneriella subcapitata: Final Report. Project Number: 

2242/049, 2242/049/D2149. Unpublished study prepared by Covance 

Laboratories, Ltd. 42 p.

161-1 Hydrolysis

MRID Citation Reference

9707 Kucharczyk, N.; Smith, A.; Stone, G. (1971) Environmental Fate Studies on 

Alar^(R)I: Status Report on PR 70-15: Work on Suc- cinic acid, 2,2-

Dimethylhydrazide (Alar-85, Kylar-85, Kylar). (Unpublished study received 

Sep 27, 1971 under 400-79; submitted by Uniroyal Chemical, Bethany, Conn.; 

CDL:120366-A) 

126786 Stone, G. (1983) Daminozide Status Report: Draft. (Unpublished study 

received Apr 14, 1983 under 400-79; submitted by Uniroyal Chemical, 

Bethany, CT; CDL:249926-A) 

128352 Uniroyal Chemical (1983) Daminozide Residue and Hydrolysis Studies: 

?Apples and Other Crops|. (Compilation; unpublished study re- ceived May 3, 

1983 under 400-79; CDL:250161-A) 

138265 Uniroyal Chemical (1983) Summary Report: ?UDMH|. (Compilation; 

unpublished study received Apr 17, 1984 under 400-117; CDL: 253012-A) 

147749 Lengen, M. (1985) Addendum to: Hydroysis of Daminozide... and Daminozide 

Photolysis in Water and on Soil--Interim Report: Pro- ject No. 84244/84246. 

Unpublished study prepared by Uniroyal Chemical. 59 p. 

154942 Lengen, M.; Abdel-Kader, H.; Peterson, G. (1984) Hydrolysis of Daminozide: 

Project No. 84244. Unpublished study prepared by Uniroyal Chemical. 21 p. 

47188101 Knowles, R. (2005) Determination of Hydrolysis as a Function of pH for 

Daminozide: Final Report. Project Number: J15268, FOR/04/055. 

Unpublished study prepared by GC Laboratories, Ltd. 14 p.

161-2 Photodegradation-water

MRID Citation Reference

147749 Lengen, M. (1985) Addendum to: Hydroysis of Daminozide... and Daminozide 

Photolysis in Water and on Soil--Interim Report: Pro- ject No. 84244/84246. 

Unpublished study prepared by Uniroyal Chemical. 59 p. 

154943 Lengen, M.; Dzialo, D. (1984) Daminozide Photolysis in Water and on Soil: 

Project No. 84246. Unpublished study prepared by Uniroyal Chemical. 21 p. 
Page 35 of 37

47188110 Brice, A.; Scholey, A. (2006) Carbon 14 Daminozide: Photodegradation in 

Sterile, Aqueous Solution: Final Report. Project Number: 2242/044/D2149, 

2242/044. Unpublished study prepared by Covance Laboratories, Ltd. 54 p.

161-3 Photodegradation-soil

MRID Citation Reference

147749 Lengen, M. (1985) Addendum to: Hydroysis of Daminozide... and Daminozide 

Photolysis in Water and on Soil--Interim Report: Pro- ject No. 84244/84246. 

Unpublished study prepared by Uniroyal Chemical. 59 p. 

42457301 Batorewicz, W. (1992) UV-Visible Spectra of Daminozide, N-Dimethylamino 

Succinimide and 1,1 Dimethylhydrazine: Lab Project Number: 92160. 

Unpublished study prepared by Uniroyal Chemical Co., Inc. 20 p. 

162-1 Aerobic soil metabolism

MRID Citation Reference

9707 Kucharczyk, N.; Smith, A.; Stone, G. (1971) Environmental Fate Studies on 

Alar^(R)I: Status Report on PR 70-15: Work on Suc- cinic acid, 2,2-

Dimethylhydrazide (Alar-85, Kylar-85, Kylar). (Unpublished study received 

Sep 27, 1971 under 400-79; submitted by Uniroyal Chemical, Bethany, Conn.; 

CDL:120366-A) 

9708 Dannals, L.E.; Puhl, R.J.; Kucharczyk, N. (1972) Environmental Fate Studies 

on Alar^(R)I: Second Status Report on PR 70-15: Work on Succinic acid, 2,2-

dimethylhydrazide (Alar-85, Kylar-85, Kylar). (Unpublished study received 

Apr 20, 1972 under 400-79; submitted by Uniroyal Chemical, Bethany, Conn.; 

CDL:120367-A) 

160675 Dzialo, D.; Harned, W. (1986) Daminozide Aerobic and Anaerobic Soil 

Metabolism Studies: Project No. 8501-2, 8561. Unpublished study prepared by 

Uniroyal Chemical. 35 p. 

42687201 Yu, W.; Kobryn, K. (1993) Daminozide Aerobic Soil Metabolism: Lab Project 

Number: 92123. Unpublished study prepared by Uniroyal. 53 p. 

43005601 Yu, W. (1993) Characterization of Volatiles from Daminozide Aerobic Soil 

Metabolism: Lab Project Number: 9398. Unpublished study prepared by 

Uniroyal Chemical Co., Inc. 47 p. 

46164615 Goodyear, A. (1995) (Carbon 14)-Daminozide Soil Metabolism and 

Degradation: Final Report. Project Number: 1137/2/1015, 1137/2, 5239/24. 

Unpublished study prepared by Corning Hazleton (Europe), A & L Great 

Lakes Laboratories, and Eurolabs Ltd. 94 p.
Page 36 of 37

162-2 Anaerobic soil metabolism

MRID Citation Reference

160675 Dzialo, D.; Harned, W. (1986) Daminozide Aerobic and Anaerobic Soil 

Metabolism Studies: Project No. 8501-2, 8561. Unpublished study prepared by 

Uniroyal Chemical. 35 p. 

163-1 Leach/adsorp/desorption

MRID Citation Reference

9707 Kucharczyk, N.; Smith, A.; Stone, G. (1971) Environmental Fate Studies on 

Alar^(R)I: Status Report on PR 70-15: Work on Suc- cinic acid, 2,2-

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164-5 Long term soil dissipation

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