2

Problem Formulation for the Environmental Fate, 

Ecological Risk, Endangered Species, and Drinking 

Water Exposure Assessments in Support of the 

Registration Review of Acibenzolar-S-methyl

CAS: 135158-54-2

PC Code: 061402

Environmental Fate and Effects Division

Prepared by:

Michael Lowit, Ph.D., Ecologist

Steve Wente, Ph.D., Biologist

U.S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch I

1200 Pennsylvania Ave., NW

Mail Code 7507P

Washington, DC 20460

Reviewed by:

Faruque Kahn, Ph.D., Senior Fate Scientist

Robin Sternberg, Ph.D., Wildlife Biologist

N

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Table of Contents

1. Purpose........................................................................................................................................ 4

2. Problem Formulation .................................................................................................................. 4

2.1. Nature of Regulatory Action................................................................................................ 4

2.2. Previous Assessments.......................................................................................................... 4

2.2.1. Ecological Risk Assessments........................................................................................ 4

2.2.2. Drinking Water Exposure Assessments........................................................................ 4

3. Stressor Source and Distribution ................................................................................................ 5

3.1. Mechanism of Action.......................................................................................................... 5

3.2. Overview of Pesticide Use and Usage ................................................................................ 5

3.3. Physical, Chemical, and Environmental Fate Properties of Acibenzolar-S-methyl and Its 

Degradates................................................................................................................................... 7

3.4. Clean Water Act.................................................................................................................. 9

4. Receptors.................................................................................................................................... 9

4.1. Effects to Aquatic Organisms........................................................................................... 10

4.2. Effects to Terrestrial Organisms....................................................................................... 13

4.3. Incident Databases Review............................................................................................... 15

5. Exposure Pathways of Concern ............................................................................................... 16

6. Analysis Plan ........................................................................................................................... 16

6.1. Stressors of Concern .......................................................................................................... 17

6.2. Measures of Exposure........................................................................................................ 17

6.3. Measures of Effect ............................................................................................................. 18

6.4. Integration of Exposure and Effects .................................................................................. 18

6.5. Endangered Species Assessments...................................................................................... 18

6.6. Endocrine Disruptor Screening.......................................................................................... 19

6.7. Drinking Water Assessment .............................................................................................. 19

6.8. Preliminary Identification of Data Gaps............................................................................ 19

6.8.1. Environmental Fate Data ............................................................................................ 19

6.8.2. Ecological Effects Data............................................................................................... 21

7. References................................................................................................................................ 24

APPENDIX A. Submitted Environmental Fate and Effects Studies........................................... 25

APPENDIX B. SIP v.1.0 Inputs and Outputs.............................................................................. 29

APPENDIX C. STIR v.1.0 Inputs and Outputs........................................................................... 30

APPENDIX D. Chemical Names, Structures, and Maximum Reported Degradate Production in 

Environmental Fate Studies.......................................................................................................... 31
4

1. Purpose

The purpose of this problem formulation is to provide an understanding of what is known about 

the environmental fate, ecological effects, and currently registered uses of acibenzolar-S-methyl

(also known as acibenzolar and CGA-245704). This document provides a plan for analyzing 

data relevant to acibenzolar-S-methyl and for conducting environmental fate, ecological risk, 

endangered species, and drinking water exposure assessments for its registered uses. 

Additionally, this problem formulation identifies data gaps, uncertainties, and potential 

assumptions used to address those uncertainties relative to characterizing the potential ecological 

risk associated with the registered uses of acibenzolar-S-methyl.

2. Problem Formulation

2.1. Nature of Regulatory Action

As part of the implementation of the new Registration Review program1 pursuant to Section 3(g) 

of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Agency is beginning its 

evaluation of acibenzolar-S-methyl to determine whether it continues to meet the FIFRA 

standard for registration. This problem formulation in support of the registration review of 

acibenzolar-S-methyl will be posted in the initial docket which will be open to the public phase 

of the review process.

2.2. Previous Assessments

2.2.1. Ecological Risk Assessments

Acibenzolar-S-methyl was first registered in the US in 2000 as a fungicide for use on a 

variety of food crops. Previous Section 3 assessments for acibenzolar-S-methyl concluded 

no risk concern to any taxonomic groups (DP258689, DP317996, DP351609, DP371759, and 

DP386929)2 except chronic risk to mammals from sunflower seed use (DP398630).

2.2.2. Drinking Water Exposure Assessments

The most recent drinking water assessment (DWA) in support of human health risk assessment 

was conducted to support the registration of acibenzolar-S-methyl for use on the low growing 

berry subgroup 13-07G (DP 386365). The maximum drinking water exposure estimates are for 

use on cucurbits: (1) acibenzolar-S-methyl concentrations are 0.72 μg/L (1-in-10-year peak), 

0.16 μg/L (1-in-10-year annual mean), and 0.11 μg/L (30-year mean) for surface water and 1.25 

x 10-5 μg/L for ground water and (2) CGA-210007 concentrations are 20.02 μg/L (1-in-10-year 

peak), 19.11 μg/L (1-in-10-year annual mean), and 16.64 μg/L (30-year mean) for surface water 

and 8.12 x 10-2 μg/L for ground water.

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

2 DP258689 (3/00; leafy vegetable, cole crop, tomato, tobacco), DP317996 (7/06; cole crop, tomato, fruiting 

vegetable, lettuce, spinach, tobacco), DP351609 (2/09; cucurbit, dry onion bulb), DP371759 (8/10; turf, cotton 

seed), and DP386929 (5/11; low growing berry subgroup 13-07G)
5

3. Stressor Source and Distribution

3.1. Mechanism of Action

Acibenzolar is a fungicide in the benzothiadiazole class that works systemically by increasing 

enzymes in the plant, which then can degrade fungal and bacterial cell walls. The physiological 

process induced by acibenzolar-S-methyl treatment is achieved by the triggering of systemic 

activated resistance (SAR) within plants. This natural resistance can be induced biologically 

whenever a plant is attacked by low levels of pathogen inoculum.

3.2. Overview of Pesticide Use and Usage

Acibenzolar-S-methyl uses and application rates are based on the most recent label data report 

(Label Use Information System report; LUIS, 7/11/2013) provided by the Biological and 

Economic Analysis Division (BEAD). Maximum application rates, minimum application 

intervals, and application methods are indicated in Table 1. The registration review risk 

assessment will be based on current label information at the time of assessment as provided by 

BEAD.

To reduce uncertainty in the risk assessment, EFED is requesting that the registrant provide 

additional label information where necessary on the minimum application interval

(commercial/industrial lawns and ornamental lawns/turf). Additionally, EFED requests 

clarification on the maximum number of applications for transplant production uses.

EFED does not anticipate that using seasonal rates (as stated on current labels) instead of an 

annual maximum application rate would substantially affect the acibenzolar-S-methyl risk 

assessment because both acibenzolar-S-methyl and CGA-210007 (major degradate of concern) 

have short degradation half-lives (aerobic soil metabolism t1/2 of 0.22 days for acibenzolar-Smethyl and 16.5 days for CGA-210007) relative to the duration of a crop season (i.e., there will be 

little build up of acibenzolar-S-methyl or CGA-210007 across seasons). However, in the absence 

of labeled annual maximum application rates (or maximum number of crop seasons/year), EFED 

will assume multiple crop seasons for applicable crops and make conservative assumptions about 

the number of seasons based on best available information.

Acibenzolar-S-methyl was primarily used on spinach crops in terms amount of product applied 

(1000 lb ai) and percent crop treated (35% on average) from 2004-2011 according to the 

Screening Level Usage Analysis provided by BEAD (12/6/2012). Acibenzolar-S-methyl was 

applied ≤ 5% (on average) to all other crops.
6

Table 1. Maximum Rates for Registered Uses of Acibenzolar-S-methyl

Use Method of 

Application

Maximum

Single

Application 

Rate (lb ai/A)

Maximum 

Number of 

Applications 

(Assumed)

Minimum 

Application 

Interval 

(Days)

Seasonal

Maximum

Application Rate

(lb ai/A)

Cole Crops 

Aerial

Ground

Chemigation1

0.0313 4 7 0.125

Commercial/

Industrial

Lawns

Ground 0.0234

NS

(2)

NS 0.053

Cotton Seed Treatment 1.98 x 10-10

lb/seed NS NS 0.0002

Cucurbit 

Vegetables

Band Treatment

Aerial

Ground

Chemigation –

(drip irrigation)

0.0625

NS

(4)

7 0.25

Fruiting 

Vegetables

Band Treatment

Aerial

Ground

Chemigation1

0.0234 8 7 0.1875

Golf Course 

Turf Ground 0.0234

NS

(6)

14 0.1487

Lettuce

Band Treatment

Aerial

Ground

Chemigation1

0.0313 4 7 0.125

Onion

Band Treatment

Aerial

Ground

Chemigation1

0.0313

NS

(4)

7 0.125

Ornamental 

Lawns and 

Turf

Ground 0.0234

NS

(2)

NS 0.053

Ornamental 

Sod Farm 

(Turf)

Ground 0.0234

NS

(1)

NS 0.026
7

Use Method of 

Application

Maximum

Single

Application 

Rate (lb ai/A)

Maximum 

Number of 

Applications 

(Assumed)

Minimum 

Application 

Interval 

(Days)

Seasonal

Maximum

Application Rate

(lb ai/A)

Pepper 

(including 

chili type)

Band Treatment

Aerial

Ground

Chemigation1

 

0.0234 8 7 0.1875

Soil/media 

Treatment (drip 

feed at seeding –

transplant 

production)

1.1 x 10-7 lb/cell

NS

(1)

NS NS

Small Fruits

Band Treatment

Aerial

Ground

0.0234

NS

(8)

7 0.1875

Spinach

Band Treatment

Aerial

Ground

Chemigation1

0.0234 3 7 0.0703

Sunflower Seed Treatment 6.0 x 10-8 lb/seed NS NS 0.005

Tobacco

Aerial

Ground

Directed Spray

0.0156 3 10 0.0469

Foliar Treatment 

(pre-transplant) 6.3 x 10-7 lb/plant

NS

(1)

NS NS

Tomato

Band Treatment

Aerial

Ground

Chemigation1

0.0234 8 7 0.1875

Soil/media 

Treatment (drip 

feed at seeding –

transplant 

production)

1.1 x 10-7 lb/cell

NS

(1)

NS NS

NS – not stated on the label 1 Drip irrigation and overhead sprinkler irrigation.

3.3. Physical, Chemical, and Environmental Fate Properties of Acibenzolar-Smethyl and Its Degradates 

Registrant-submitted studies (Table 2) indicate that acibenzolar-S-methyl neither readily moves 

to surface water nor leaches to ground water due to its poor water solubility (7.7mg/L) and short 

degradation half-life in aerobic soil (t1/2 = 0.22 days), aerobic aquatic metabolism (t1/2 = 0.63 
8

days), and aqueous photolysis (t1/2 = 0.025 days) studies. Acibenzolar is unlikely to volatilize 

given its Henry’s law constant of 1.26 × 10-7 atm m3 mole-1 and vapor pressure of 3.5 × 10-6 mm 

Hg @ 25 ̊C. A bioaccumulation study of bluegill sunfish (Lepomis macrochirus) under flowthrough test conditions indicated mean bioconcentration factors (BCFs) of 48 in fillet, 199 in 

viscera, and 118 in whole fish samples.

The primary pathway of acibenzolar-S-methyl degradation in aerobic soil involves cleavage of 

the thioester to form a carboxylic acid derivative, 1,2,3-benzothiadiazole-7-carboxylic acid 

(CGA-210007). In non-sterile aerobic soil, CGA-210007 reached 62.5% of the applied 

acibenzolar-S-methyl in 6 hrs and peaked on day 3 at 99%. For sterile soil, CGA-210007 

reached 35.3% in 6 hrs and a maximum of 60.2% by day 7. In the aqueous photolysis study, 

acibenzolar-S-methyl rapidly degraded into several unknown compounds (at 25 ̊C in sterile 

aqueous sodium acetate buffer solution (pH 5)). The pseudo first order half-life was 0.025 days. 

After 30 days, the major degradates of aqueous photolysis were CO2 (33.4% formation), A8 

(25%), and A9 (19%). In the dark environment, CGA-210007 accumulated at a rate inversely 

proportional to the decline of acibenzolar-S-methyl, reaching 8.4% (maximum) of the applied 

acibenzolar-S-methyl in 30 days. Compared to acibenzolar-S-methyl, CGA-210007 is a 

relatively stable compound with a longer residue half-life in aerobic soil (t1/2 = 16.5 days) and 

higher water solubility (225 mg/L); thus, it is more readily available for lateral and vertical 

downward movement to surface and groundwater. Consequently, CGA-210007 exhibits greater 

exposure potential following application. Studies submitted by the registrant are listed in 

Appendix A. Appendix D provides the structures of acibenzolar-S-methyl and its degradates as 

well as the maximum reported degradate production in the submitted environmental fate studies.

Table 2. Environmental Fate and Transport Properties of Acibenzolar-S-methyl and 

CGA-210007 (Major Degradation Product)

Parameter Value Reference

Acibenzolar-S-methyl

Chemical Name 1,2,3 benzothiadiazole-7-carbothioic acid, Smethyl ester MRID 47833601

Molecular Formula C8H6N2OS2 MRID 47833601

Molecular Weight 210.3 g/mol MRID 47833601

SMILES Code c1ccc2N=NSc2c1C(=O)SC EPI Suite (v 3.20)

Melting Point 132.9oC MRID 45434102_CA

Vapor pressure (25°C) 3.5 × 10-6 mm Hg @ 25oC MRID 47833602

Henry’s Law Constant 1.26 × 10-7 atm m3 mole-1 Calculated

Solubility (pH 6, 20oC) 7.7 mg/L MRID 47833602

Hydrolysis (t1/2)

pH 5, 1,387 days

pH 7, 161.7 days

pH 9, 0.81 days

MRID 44014252

Aqueous Photolysis (t1/2) 0.025 days at pH 7 MRID 44537034

Soil Photolysis (t1/2) 1.0 days MRID 44537035

Aerobic Soil Metabolism (t1/2) 0.22 days MRID 44014253

MRID 44537036

Aerobic Aquatic Metabolism (t1/2) 0.63 days MRID 44537038

Anaerobic Soil Metabolism (t1/2) N/A No data

Anaerobic Aquatic Metabolism (t1/2) 3.98 days MRID 44537037

Koc (median) 1893 ml/g MRID 44537041
9

Parameter Value Reference

CGA-210007 (Major degradate)

Chemical Name 1,2,3-benzothiadiazole-7-carboxylic acid MRID 44537042

Molecular formula C7H4N2O2S1 EPI Suite (v 3.20)

Molecular weight 180.2 g/mol EPI Suite (v 3.20)

SMILES Code n1nc2cccc(C(=O)O)c2s1 EPI Suite (v 3.20)

Vapor pressure (20/25°C) 2.73 × 10-7 torr EPI Suite (v 3.20)

Henry’s Law Constant 3.42 × 10-11 atm m3 mole-1 EPI Suite (v 3.20)

Solubility (20oC) 225 mg/L MRID 44537042

Koc 138 ml/g (mean) MRID 44537042

Hydrolysis Assumed stable MRID 44014252

Aqueous Photolysis (t1/2) Assumed stable No data

Aerobic Aquatic Metabolism (t1/2) 746 days MRID 44537038

Aerobic Soil Metabolism (t1/2) 16.5 days MRID 44014253

Anaerobic Aquatic Metabolism (t1/2) Assumed stable No data

N/A = not available

3.4. Clean Water Act

Acibenzolar-S-methyl is not identified as a cause of impairment for any water bodies listed as 

impaired under section 303(d) of the Clean Water Act3

. In addition, no Total Maximum Daily 

Loads (TMDL) have been developed4. The Impaired Waters and Total Maximum Daily Loads 

website can be consulted for more information5

. The Agency invites submission of water quality 

data for acibenzolar-S-methyl. To the extent possible, data should conform to the quality 

standards in the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and 

Other Water Quality Data in OPP’s Registration Review Risk Assessment and Management 

Process6

, in order to ensure they can be used quantitatively or qualitatively in pesticide risk 

assessments.

4. Receptors

Consistent with the process described in the Overview Document (USEPA, 2004), the risk 

assessment for acibenzolar-S-methyl relies on a surrogate species approach. Toxicological data 

generated from surrogate test species, which are intended to be representative of broad 

taxonomic groups, are used to extrapolate the potential effects on a variety of species (receptors) 

included under these taxonomic groupings.

Acute and chronic toxicity data from studies submitted by pesticide registrants along with the 

available open literature will be used to evaluate the potential direct and indirect effects of 

acibenzolar-S-methyl to aquatic and terrestrial receptors. This includes toxicity on the technical 

grade active ingredient, degradates, and when available, formulated products (e.g., “Six-Pack” 

studies). Open literature studies will be identified through EPA’s ECOTOXicology (ECOTOX) 

database7

, which employs a literature search engine for locating chemical toxicity data.

 3 http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=885

4

http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id=885&p_pollutant_

group_name=PESTICIDES

5 http://www.epa.gov/owow/tmdl/ 6 http://www.epa.gov/oppfead1/cb/ppdc/2006/november06/session1-sop.pdf 7 http://cfpub.epa.gov/ecotox/
10

A summary of data representing non-target organisms exposed to acibenzolar-S-methyl in 

aquatic and terrestrial habitats is provided in Sections 4.1 and 4.2. Four additional studies (one 

850.2100 and three 850.5400) were recently received and are in review (see section 6.82). A 

summary of ecological incidents associated with acibenzolar-S-methyl is provided in Section 

4.3. Studies submitted by the registrant are listed in Appendix A. The ECOTOX database will 

be searched when the risk assessment for acibenzolar-S-methyl is prepared. At that time, EFED 

will review the endpoints from open literature studies that are more sensitive than those from 

available guideline studies.

4.1. Effects to Aquatic Organisms

Table 3. Summary of Toxicity of Acibenzolar-S-methyl (TGAI) to Aquatic Organisms

Species Exposure 

Scenario

% 

AI

Toxicity MRID Study 

Classification/

Acute Toxicity 

Category

Rainbow trout 

(Oncorhynchus 

mykiss)

96-hr, flowthrough98 LC50 = 0.88 (0.68-0.95) 

mg ai/L1

NOAEC = 0.43 mg ai/L

LOAEC = 0.68 mg ai/L 

based on lethargy, erratic 

swimming, and 

surfacing. Discoloration 

and lying on the bottom 

were observed at the 

highest test 

concentration.

44537013 Acceptable/

Highly toxic

Early-life 

stage, flowthrough

98 NOAEC = 0.026 mg ai/L

LOAEC = 0.054 mg ai/L 

based on reduced growth 

(wet and dry weight).

44537019 Acceptable/

Not applicable

Bluegill sunfish 

(Lepomis 

macrochirus)

96-hr, flowthrough98 LC50 = 1.6 (1.4-1.9) mg 

ai/L1

NOAEC = 0.90 mg ai/L

LOAEC = 1.3 mg ai/L 

based on mortality, 

lethargy, and surfacing. 

Discoloration, erratic 

swimming, and lying on 

the bottom were 

observed at the highest 

test concentration.

44537011 Acceptable/

Moderately toxic
11

Species Exposure 

Scenario

% 

AI

Toxicity MRID Study 

Classification/

Acute Toxicity 

Category

Water flea 

(Daphnia 

magna)

48-hr, flowthrough98 EC50 = 2.9 (2.5-3.5) mg 

ai/L1

NOAEC = 0.82 mg ai/L

LOAEC = 1.4 mg ai/L 

based on mortality and 

lethargy.2

44537014 Acceptable/

Moderately toxic

Life-cycle, 

flow-through

98 NOAEC = 0.048 mg ai/L

LOAEC = 0.087 mg ai/L 

based on reduced length 

and dry weight.

44537020 Acceptable/

Not applicable

Sheepshead 

minnow 

(Cyprinodon 

variegates)

96-hr, flowthrough98 LC50 = 1.67 (1.1-2.1) mg 

ai/L1

NOAEC = 1.1 mg ai/L

LOAEC = 2.1 mg ai/L 

based on mortality, 

lethargy, surfacing, and 

lying on the bottom.

44537016 Acceptable/

Moderately toxic

Eastern oyster 

(Crassostrea 

virginica)

96-hr, flowthrough98 EC50 = 0.59 (0.47-0.75) 

mg ai/L1

NOAEC = 0.19 mg ai/L

LOAEC = 0.34 mg ai/L 

based on reduced shell 

growth.

44537017 Acceptable/

Highly toxic

Saltwater mysid 

(Americamysis 

bahia)

96-hr, flowthrough98 LC50 = 0.88 (0.74-1.04) 

mg ai/L1

NOAEC = 0.37 mg ai/L

LOAEC = 0.61 mg ai/L 

based on mortality and 

erratic swimming. 

Lethargy was observed 

at higher test 

concentrations.

44537018 Acceptable/

Highly toxic

Green algae

(Selenastrum 

capricornutum)

96-hr, initial 

measured 

concentration

98 EC50 = 3.3 (2.9-3.9) mg 

ai/L1

NOAEC = 1.3 mg ai/L

LOAEC = 2.6 mg ai/L 

based on reduced cell 

density.

44537030 Acceptable/

Not applicable

1 Range is 95% confidence interval

2 Some Daphnids were observed floating throughout the test in all test concentrations and the solvent 

control.
12

Table 4. Summary of Toxicity of CGA-210007 to Aquatic Organisms

Species Exposure 

Scenario

% 

AI

Toxicity MRID Classification/

Category

Rainbow trout 

(Oncorhynchus 

mykiss)

96-hr, static 97 LC50 > 92 mg total ai/L2

NOAEC ≥ 92 mg total 

ai/L

No mortality or sublethal effects observed.

44537012 Supplemental/

Not applicable

Water flea 

(Daphnia 

magna)

48-hr, static 97 EC50 = 59.9 (44.9-91) 

mg ai/L1

NOAEC = 10.3 mg ai/L

LOAEC = 18.6 mg ai/L 

based on mortality.

No sub-lethal effects 

observed.

44537015 Supplemental/

Slightly toxic

Green algae

(Selenastrum 

capricornutum)

72-hr, mean 

measured 

concentration

97 EC50 = 80.1 (55.7-97.5) 

mg ai/L1

NOAEC = 57.7 mg ai/L

LOAEC = 97.5 mg ai/L 

based on reduced cell 

density.

44537031 Supplemental/

Not applicable

1 Range is 95% confidence interval

2 Previous risk assessments reported in error that the toxicity was > 100 mg ai/L. Toxicity is reported as 

“total ai” because precipitate was observed in the test chamber throughout the test and samples were not 

filtered or centrifuged prior to analysis.

Toxicity of CGA-210007 to rainbow trout may be underestimated because precipitate was 

observed in the test chamber and samples were not filtered or centrifuged prior to analysis. 

Centrifugation or filtration is required to determine the amount of CGA-210007 that was freely 

dissolved and bioavailable. However, the available study provides enough evidence to 

reasonably conclude that CGA-210007 is likely less toxic than acibenzolar-S-methyl to rainbow 

trout. The LC50 from the CGA-210007 study is at least two orders of magnitude higher (i.e., less 

toxic) than the acute LC50s from the available acibenzolar-S-methyl fish studies; this means that 

CGA-210007 is less toxic than acibenzolar-S-methyl as long as > 1% of the CGA-210007 was in 

solution (i.e., dissolved). This is reasonable given that the test concentration was well below the 

reported solubility limit of CGA-210007 (225 mg/L at 20°C). Repeat testing is unlikely to 

demonstrate that CGA-210007 is more toxic than acibenzolar-S-methyl.

Available data for the major degradation product, CGA-210007, shows that it is less toxic than 

acibenzolar-S-methyl for certain taxonomic groups. Given the limited toxicity data on CGA210007, Ecological Structure Activity Relationship (ECOSAR) methods were used to predict the 

aquatic toxicity of CGA-210007 based on structural similarity to chemicals for which aquatic 

toxicity data are known. ECOSAR predictive software is available publically though the Epi 
13

SuiteTM program8

. Confidence in the ECOSAR estimates was low because they were more than 

an order of magnitude greater, that is, less toxic, than experimentally derived toxicity values. 

However, relative comparison of ECOSAR estimates of acibenzolar and CGA-210007 suggests 

that CGA-210007 is not more toxic than acibenzolar-S-methyl to fish and invertebrates on an 

acute or chronic basis.

4.2. Effects to Terrestrial Organisms

Table 5. Summary of Toxicity of Acibenzolar-S-methyl (TGAI) to Terrestrial Organisms

Species Exposure 

Scenario

% AI Toxicity MRID Study Classification/

Acute Toxicity 

Category

Bobwhite quail 

(Colinus

virginianus)

Single oral 

dose, birds 

observed for 

14 days

97.9 LD50 > 2000

mg/kg-bw

No effects observed

44537005 Acceptable/

Practically non-toxic

8 days 

(5 days 

treatment and 

3 days 

observation)

97.9 LC50 > 5000

mg/kg-diet

No effects observed

44537006 Acceptable/

Practically non-toxic

22 weeks 97.9 NOAEC = 600 mg/kgdiet

LOAEC = 1000 

mg/kg-diet based on 

reduced 14-day-old 

survivor weights and 

reduced percentage of 

14-day-old hatchling 

survivors.

44537009 Acceptable/

Not applicable

Mallard duck 

(Anas 

platyrhynchos)

Single oral 

dose, birds 

observed for 

14 days

97.9 LD50 > 2000

mg/kg-bw

No effects observed

44537004 Acceptable/

Practically non-toxic

8 days 

(5 days 

treatment and 

3 days 

observation)

97.9 LC50 > 5000

mg/kg-diet

NOAEC = 2450 

mg/kg-diet 

LOAEC = 5000 

mg/kg-diet based on 

reduced body weight 

gain

44537008 Acceptable/

Practically non-toxic

23 weeks 97.9 NOAEC ≥1000 

mg/kg-diet

LOAEC = No effects 

observed.

44537010 Acceptable/

Not applicable

 8 http://www.epa.gov/oppt/exposure/pubs/episuite.htm
14

Species Exposure 

Scenario

% AI Toxicity MRID Study Classification/

Acute Toxicity 

Category

Laboratory Rat Single oral 

dose, rats 

observed for 

14 days

98 LD50 > 5000

mg/kg-bw

44014214 Acceptable/

Practically non-toxic

2-generation 

reproduction 

study

97.9 NOAEC = 200 mg/kgdiet

LOAEC = 2000 

mg/kg-diet based on 

parental toxicity 

(increased weights and 

hemosiderosis of the 

spleen) and 

developmental toxicity 

(reduced pup body 

weight gains and lower 

pup body weights 

during lactation).

44014241 Acceptable/

Not applicable

Honey bee 

(Apis mellifera)

48 hours, 

contact and 

oral

97.9 Contact LD50 > 100 

μg/bee

Oral LD50 > 100 

μg/bee

44537033 Acceptable (contact 

test), Supplemental 

(oral test)/

Practically non-toxic
15

Table 6. Summary of Toxicity of Acibenzolar-S-methyl (Formulations) to Terrestrial 

Organisms

Species Exposure 

Scenario

% AI Toxicity MRID Classification/

Category

Terrestrial 

Plants

Tier 1, 

seedling 

emergence, 

0.094 lb ai/A 

of CGA245704 50 

WG

51.2 Monocots

EC25 > 0.094 lb ai/A 

NOAEC < 0.094 lb 

ai/A for wheat based 

on dry weight 

inhibition

Dicots

EC25 > 0.094 lb ai/A 

NOAEC < 0.094 lb 

ai/A for tomato based 

on shoot height 

inhibition

44537028 Supplemental/

Not applicable

Tier 1, 

vegetative 

vigor, 0.094 

lb ai/A of 

CGA-245704 

50 WG

51.2 Monocots

EC25 > 0.094 lb ai/A 

NOAEC = 0.094 lb 

ai/A 

Dicots

EC25 > 0.094 lb ai/A 

NOAEC = 0.094 lb 

ai/A 

44537029 Acceptable/

Not applicable

4.3. Incident Databases Review

Reviews were conducted of the Ecological Incident Information System (EIIS, version 2.1.1)9, 

the Agency’s Aggregated Incidents Reports database, and the Avian Incident Monitoring System 

(AIMS)10 on August 2, 2013. Incidents involving acibenzolar-S-methyl were reported in the 

EIIS database only. Syngenta submitted four incident reports on head lettuce damaged 

throughout California due to direct application of acibenzolar-S-methyl (Table 7). The legality 

of use for these incidents is “registered use”. The certainty index for these incidents is possible.

The total number of actual incidents associated with the use of acibenzolar-S-methyl may be 

higher than what is reported to the Agency. Incidents may go unreported since effects may not 

be immediately apparent or readily attributed to the use of a chemical. As such, the absence of 

incident reports cannot be construed as the absence of incidents.

 9 http://www.epa.gov/espp/consultation/ecorisk-overview.pdf 10 http://www.abcbirds.org/abcprograms/policy/toxins/aims/aims/index.cfm
16

Table 7. Acibenzolar-S-methyl Incident Data from the EIIS Database

Incident 

ID Date Legality Certainty

State

(City)

Generic

Species and

(Total 

Magnitude) Comments

I014597

-006 3/23/2003

Registered 

use Possible

CA

(Monterey)

Lettuce, head

(77 acres)

Blockade (Actigard 

50WG) caused chlorosis 

(yellowing).

I014597

-007 3/27/2003

Registered 

use Possible

CA

(Monterey)

Lettuce, head

(77 acres)

Blockade (Actigard 

50WG) caused 

discoloration/bleaching.

I014597

-008 6/9/2003

Registered 

use Possible

CA

(Santa 

Cruz)

Lettuce, head

(108 acres)

Blockade (Actigard 

50WG) caused chlorosis 

(yellowing).

5. Exposure Pathways of Concern

The use patterns and environmental fate properties of acibenzolar-S-methyl indicate that 

exposure to non-target aquatic and terrestrial organisms may occur from direct spray and offsite 

movement via spray drift and runoff.

Screening Imbibition Program

The Screening Imbibition Program (SIP v.1.0)

11 was used to calculate an upper bound estimate 

of bird and mammal exposure to acibenzolar-S-methyl in drinking water. Drinking water 

exposure alone was determined not to be a potential acute or chronic concern for birds or 

mammals. Screening of CGA-210007 risk will be performed if toxicity data become available. 

Appendix B provides model results.

Screening Tool for Inhalation Risk 

The Screening Tool for Inhalation Risk (STIR v.1.0)

10 was used to provide an upper bound 

estimate of exposure of birds and mammals to pesticides through inhalation of spray drift or 

vapor. The screening suggests that acibenzolar-S-methyl exposure is not likely significant 

enough for an inhalation risk concern. Appendix C provides model results.

6. Analysis Plan

In order to address the risk hypothesis, the potential for adverse effects on the environment is 

estimated. The use, environmental fate, and ecological effects of acibenzolar-S-methyl will be 

characterized and integrated to assess risk. This will be accomplished using a risk quotient (RQ; 

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 or magnitude of an adverse 

effect. However, as outlined in the Overview Document (USEPA, 2004), the likelihood of 

effects to individual organisms from particular uses of acibenzolar-S-methyl will be estimated 

 11 http://www.epa.gov/oppefed1/models/terrestrial
17

using the probit dose-response slope and either the level of concern or actual calculated risk 

quotient value.

This analysis plan will be revisited and may be revised depending upon a full review of the data 

available in the open literature and the information submitted by the public in response to the 

opening of the Registration Review docket.

6.1. Stressors of Concern

Ecological Risk Assessment

Acibenzolar-S-methyl and CGA-210007 will be considered the stressors of concern in the 

ecological risk assessment. CGA-210007 is a concern given the rapid degradation of 

acibenzolar-S-methyl (e.g., t1/2 = 0.025 days in the available aqueous photolysis study), the 

substantial formation of CGA-210007 (e.g., formation up to 99% in the available aerobic soil 

metabolism study), and lack of a complete toxicity dataset. Risk from acibenzolar-S-methyl and 

CGA-21007 will be assessed separately when toxicity data is available for both compounds. For 

assessment endpoints without CGA-210007 toxicity data, CGA-210007 toxicity will be assumed 

equal to that of acibenzolar-S-methyl (given that available information does not indicate greater 

toxicity of CGA-210007) and a total toxic residue (TTR) modeling approach will be used to 

calculate EECs based on acibenzolar-S-methyl plus CGA-210007 residues.

CGA-210007 toxicity to birds and mammals12 is unknown and will be assumed equal to that of 

acibenzolar-S-methyl in the absence of data. However, there is no basis at this time for 

characterizing a level of confidence in the assumption that CGA-210007 is not more toxic than 

acibenzolar-S-methyl to birds and mammals.

Drinking Water Assessment

Acibenzolar-S-methyl and CGA-210007 will be considered the stressors of concern in the 

drinking water assessment consistent with past DWAs and the conclusions of the Metabolism 

Assessment Review Committee (MARC) decision memo (11/29/99).

6.2. Measures of Exposure

Acibenzolar-S-methyl and CGA-210007 concentrations in aquatic and terrestrial environments 

will be modeled using the maximum labeled application rates, the maximum number of 

applications, the minimum application intervals, and application methods that have the greatest 

potential for off-site transport.

 12 A rat acute oral LD50 > 2000 mg/kg is reported in the IUPAC footprint database 

(http://sitem.herts.ac.uk/aeru/iupac/688.htm). This data has not been reviewed by the Agency and the toxicity 

endpoint is presented at face value. This data does not support or reject the assumption that CGA-210007 is not 

more toxic than acibenzolar-S-methyl.
18

Aquatic Exposure 

Tier II models PRZM (Pesticide Root Zone Model, v3.12.3; June, 2006) and EXAMS (EXposure 

Analysis Modeling System, version 2.98.04.06, April 2005) in the PE5 shell13 will be used to 

model estimated environmental concentrations (EECs) of acibenzolar-S-methyl and CGA210007 in surface waters.

Terrestrial Exposure

There is potential for exposure to non-target organisms through consumption of contaminated 

food items (e.g., treated insects or vegetation), direct application, runoff, or spray drift.

T-REX (v 1.5)14 will be used to estimate avian and mammal exposure to acibenzolar-S-methyl

and CGA-210007. For input into T-REX, the default foliar dissipation half-life of 35 days will 

be used in the absence of acceptable foliar dissipation rate data.

TerrPlant (v 1.2.2)13 will be used to calculate EECs for characterizing exposure to terrestrial and 

semi-aquatic plants.

6.3. Measures of Effect

Toxicity effects data will be used as measures of direct and indirect effects to biological 

receptors (USEPA, 2004). As discussed previously, data will be obtained from registrantsubmitted studies and from literature studies identified in ECOTOX.

Quantitative assessment of risks will be based on study endpoints that can be directly linked to 

the Agency’s assessment endpoints of impaired survival, growth, and reproduction. Sub-lethal 

effects (e.g., lethargy and changes in coloration) will be evaluated qualitatively. Available 

incident data will be used to further characterize risk.

6.4. Integration of Exposure and Effects

The exposure and effects data will be integrated in order to evaluate potential adverse ecological 

effects on non-target species. The risk quotient method will be used to compare exposure and 

measured toxicity values. EECs will be divided by acute and chronic toxicity values. The 

resulting RQs will be compared to the Agency’s Levels of Concern (LOC) (USEPA, 2004). 

6.5. Endangered Species Assessments

Consistent with the Agency’s responsibility under the Endangered Species Act (ESA), the 

Agency will evaluate risks to Federally-listed threatened and endangered (listed) species from 

registered uses of acibenzolar-S-methyl. This assessment will be conducted in accordance with 

the Overview Document (USEPA, 2004), provisions of the ESA, and the Services’ Endangered 

Species Consultation Handbook (USFWS and NMFS, 1998).

 13 http://www.epa.gov/oppefed1/models/water 14 http://www.epa.gov/oppefed1/models/terrestrial
19

6.6. Endocrine Disruptor Screening

As required by Federal Food, Drug and Cosmetic Act (FFDCA) section 408(p), acibenzolar-Smethyl is subject to the endocrine screening part of the Endocrine Disruptor Screening Program 

(EDSP)15. Acibenzolar-S-methyl is not in the first or second group of pesticide active 

ingredients to be screened under the EDSP. 

6.7. Drinking Water Assessment

A DWA will be conducted for acibenzolar-S-methyl, if requested by the Health Effects Division 

(HED). Concentrations of the residue in surface waters will be estimated using the Tier II 

PRZM/EXAMS model and in ground water by the Tier I SCI-GROW model and Tier II PRZMGW model16.

6.8. Preliminary Identification of Data Gaps

Available studies submitted to fulfill environmental fate and ecological effects guideline 

requirements, as well as outstanding data gaps for acibenzolar-S-methyl are defined in Sections 

6.8.1 and 6.8.2, respectively. Studies are identified that offer data for each guideline 

requirement, as well as study classifications and whether or not further data are needed in order 

to support the risk assessment.

6.8.1. Environmental Fate Data

Environmental fate data gaps for acibenzolar-S-methyl and CGA-210007 are indicated in the 

table below (Table 8). 

EFED recommends requesting the following studies:

• Environmental chemistry method (acibenzolar-S-methyl and CGA-210007 in water)

• Independent laboratory method (acibenzolar-S-methyl and CGA-210007 in water)

Fulfilling the environmental chemistry methods (ECM) and independent laboratory validation 

(ILV) studies for water sampling is important for monitoring and enforcement purposes.

Anaerobic Soil Metabolism

The anaerobic soil metabolism study remains a data gap, but not one that EFED recommends 

being fulfilled at this time. The anaerobic soil metabolism study would not likely provide 

information that would greatly change the Agency’s understanding of the environmental risks of 

acibenzolar-S-methyl because sufficient information on the anaerobic metabolism of 

acibenzolar-S-methyl can be obtained from the anaerobic aquatic metabolism study.

 15 http://www.epa.gov/endo/ 16 http://www.epa.gov/oppefed1/models/water
20

Table 8. Environmental Fate Data and Data Gaps for Acibenzolar-S-methyl and CGA210007

Guideline Description MRID Classification Data 

Gap? Comments

835.2120 Hydrolysis 44014252 Acceptable No

1 Not recommended at 

this time (see text 

above).

2 To be determined. 

Study was recently 

received and is in 

review.

835.2240 Photodegradation in 

Water 44537034 Acceptable No

835.2410 Soil Photolysis 44537035 Supplemental No

835.2370 Photodegradation in Air Not Required No

835.4100 Aerobic Soil Metabolism 44014253

44537036 Supplemental No

835.4200 Anaerobic Soil 

Metabolism - - Yes1

835.4300 Aerobic Aquatic 

Metabolism 44537037 Acceptable No

835.4400 Anaerobic Aquatic 

Metabolism 44537038 Supplemental No

835.1230

835.1240

Leaching

Adsorption/Desorption:

Acibenzolar

44014254

44537040

44537041

Supplemental

Acceptable

Acceptable

No

CGA-210007 44537042 Acceptable No

835.1410 Laboratory Volatility Not Required No

835.8100 Field Volatility Not Required No

835.6100 Terrestrial Field 

Dissipation

44537046

44537047 Acceptable No

850.6100

Acibenzolar –

soil

ECM

ILV

44537044

44537045 Acceptable No

CGA-210007 –

soil

ECM

ILV

44537048

44537043 In Review Yes2

Acibenzolar –

water

ECM

ILV - - Yes

CGA-210007 –

water

ECM

ILV - - Yes

850.1730 Accumulation in Fish 44537049 Acceptable No
21

6.8.2. Ecological Effects Data

Data gaps for acibenzolar-S-methyl remain (Tables 9, 10, and 11). After review, some studies 

have been reclassified and no longer meet a given data requirement.

EFED recommends requesting the following studies to refine the risk assessment: 

• Terrestrial plant toxicity (TEP; Tier II seedling emergence; wheat and tomato) 

• Aquatic vascular plant toxicity (acibenzolar-S-methyl; TGAI) 

• Avian reproduction (CGA-210007; bobwhite quail)

• Larval honeybee acute oral toxicity (acibenzolar-S-methyl; TGAI)

CGA-210007

EFED does not recommend requesting additional aquatic toxicity data for CGA-210007 at this 

time given that available data indicate that it is not more toxic than acibenzolar-S-methyl. 

However, for endpoints without CGA-210007 toxicity data, a total toxic residue (TTR) approach 

will be used and CGA-210007 toxicity will be assumed equal to that of acibenzolar-S-methyl.

Past risk assessments have not identified a risk concern for birds based on the assumption that 

CGA-210007 and acibenzolar-S-methyl are similar in toxicity. Chronic exposure is more likely 

from CGA-210007 given that fate data suggests quick degradation of acibenzolar-S-methyl by 

several pathways. Therefore, there is some uncertainty in the risk conclusions given that there 

would be a risk concern if the degradate is slightly more toxic than acibenzolar-S-methyl. For 

instance, recent risk assessments stated that there would be a chronic risk concern if CGA210007 is about 2-15X more toxic than acibenzolar-S-methyl which caused effects to birds in 

one of the available reproduction studies. On the other hand, chemical structures suggest that 

CGA-210007 is more likely than acibenzolar-S-methyl to be excreted in urine. Given the 

uncertainty, EFED recommends requesting one study on chronic toxicity of CGA-210007 to 

birds. CGA-210007 data from one study would reduce uncertainty described above and would 

be used to confirm the assumption that CGA-210007 is not more toxic than acibenzolar-Smethyl. If CGA-210007 is more toxic than acibenzolar-S-methyl, then additional testing may be 

recommended. A study with bobwhite quail is recommended instead of mallard duck primarily 

because it was the species showing greater sensitivity in the available chronic studies with 

acibenzolar-S-methyl. In this case, an acute dose or dietary study with CGA-210007 cannot be 

used to address the uncertainty; it cannot be used to extrapolate to the available chronic data 

because the available acute studies with acibenzolar-S-methyl showed no mortality which is the 

basis for comparison. In the absence of data, CGA-210007 toxicity will be assumed equal to that 

of acibenzolar-S-methyl and uncertainty in the risk conclusions will be characterized in terms of 

how much more toxic CGA-210007 would need to be compared to acibenzolar-S-methyl to 

trigger a risk concern.

Whole Sediment Acute Toxicity (Freshwater and Marine Invertebrates) 

Acute whole sediment studies are a data gap for acibenzolar-S-methyl; however, EFED does not 

recommended requesting data at this time. To have a risk concern, acibenzolar-S-methyl would 

need to be at least three orders of magnitude more toxic to benthic invertebrates than to water 
22

column invertebrates17. There was not an acute risk concern for aquatic invertebrates in previous 

risk assessments; a conclusion that is unlikely to change with submission of additional data. 

There is not a data gap for CGA-210007 because it is more mobile than acibenzolar-S-methyl 

and is less likely to accumulate in sediments. Nonetheless, it is worth noting that CGA-210007 

would need to be at least two orders of magnitude more toxic to benthic invertebrates (compared 

to water column invertebrates) for there to be a risk concern

17. Studies could be recommended in 

the future if exposure levels increase (e.g., higher labeled rates) or other information suggests 

that there may be concern for benthic invertebrates.

Table 9. Ecological Effects Data (TGAI) for Aquatic Organisms Exposed to Acibenzolar-Smethyl and Data Gaps

Guideline Description MRID Classification Data 

Gap? Comments

850.1075

Acute freshwater fish 

toxicity

(cold water species)

44537013 Acceptable No

1

Toxicity may be estimated using 

an acute-to-chronic ratio using 

available daphnid and mysid data. 

2

Toxicity may be estimated using 

an acute-to-chronic ratio using 

available rainbow trout and 

sheepshead minnow data. 

3 Studies are not recommended at 

this time as additional data are 

unlikely to change risk

conclusions (see text above).

4 To be determined. Study was 

recently received and is in review.

5 Solvent effects were observed 

and the NOAEC is non-definitive. 

In the absence of data, toxicity 

from analogous chemicals may be 

considered; however, no analogs 

have been identified at this time. 

Risk to vascular aquatic plants 

will be assumed in the absence of 

data.

Acute freshwater fish 

toxicity

(warm water species)

44537011 Acceptable No

Acute estuarine/

marine fish toxicity 44537016 Acceptable No

850.1010

Acute toxicity to 

freshwater 

invertebrates

44537014 Acceptable No

850.1025

Acute estuarine/

marine mollusk 

toxicity

44537017 Acceptable No

850.1035

Acute estuarine/

marine invertebrate 

toxicity

44537018 Acceptable No

850.1300 Freshwater 

invertebrate life cycle 44537020 Acceptable No

850.1350 Saltwater invertebrate 

life cycle - - Yes1

850.1400

Freshwater fish early 

life stage 44537019 Acceptable No

Saltwater fish early life 

stage - - Yes2

850.1735

Whole sediment acute 

toxicity, freshwater 

invertebrates

- - Yes3

 17 Based on preliminary benthic pore water EECs from aerial use on cucurbits (the Section 3 use with the highest 

reported EECs in past risk assessments). Acibenzolar-S-methyl peak EEC = 0.008 μg/L. CGA-210007 peak EEC = 

5.25 μg/L.
23

Guideline Description MRID Classification Data 

Gap? Comments

850.1740

Whole sediment acute 

toxicity, marine 

invertebrates

- - Yes3

850.5400A

Aquatic plant growth

(freshwater green 

alga)

44537030 Acceptable No

Aquatic plant growth 

(freshwater diatom) 49111303 - Yes4

Aquatic plant growth 

(saltwater diatom) 49111302 - Yes4

Aquatic plant growth 

(Cyanobacteria) 49111304 - Yes4

850.4400 Aquatic plant growth 

(vascular plants) 44537032 Invalid Yes5

AAs of July 2012 the new guideline numbers are 850.4500 (Algal toxicity) and 850.4550 (Cyanobacteria toxicity)

Table 10. Ecological Effects Data (TGAI) for Terrestrial Animals Exposed to AcibenzolarS-methyl and Data Gaps

Guideline Description MRID Classification Data 

Gap?

Comments

850.2100

Avian acute oral 

toxicity

(upland game or 

waterfowl species)

44537004

44537005

Acceptable

Acceptable No

1 To be determined. Study was 

recently received and is in review.

2 Data requirement fulfilled for 

acibenzolar-S-methyl. Data gap 

for CGA-210007 (see text above)

3 The “White Paper in Support of 

the Proposed Risk Assessment 

Process for Bees”A as submitted to 

the FIFRA Scientific Advisory 

Panel proposes a screening-level 

risk assessment process that 

includes acute contact and oral 

toxicity tests with adult bees and 

an acute oral toxicity test with 

larval bees. Therefore, EFED 

recommends requesting a larval 

honey bee acute oral toxicity test.

The study protocol should be 

submitted to the Agency for 

review prior to the initiation of the 

study.

Avian acute oral 

toxicity (passerine 

species)

49111301 In Review Yes1

850.2200

Avian dietary toxicity 

(upland game species) 44537006 Acceptable No

Avian dietary toxicity 

(waterfowl species) 44537008 Acceptable No

850.2300

Avian reproduction 

(upland game species) 44537009 Acceptable No2

Avian reproduction 

(waterfowl species) 44537010 Acceptable No

850.3020

Honeybee acute 

contact and oral 

toxicity

44537033

Acceptable 

(oral study is 

Supplemental)

No

NonguidelineLarval honeybee acute 

oral toxicity - - Yes3

A www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2012-0543-0004
24

Table 11. Ecological Effects Data (TEP) for Plants Exposed to Acibenzolar-S-methyl and 

Data Gaps

Guideline Description MRID Classification Data 

Gap? Comments

850.4100

or

850.4225A

Terrestrial plant 

toxicity (Tier I or Tier 

II seedling emergence)

44537028 Supplemental Yes1

1 Tier II testing is triggered for 

wheat and tomato based on 

statistically significant effects 

observed in the Tier I test. EFED 

prefers that Tier II testing be 

conducted with the same 

formulation used in the Tier I test. 

In the absence of data, toxicity 

from analogous chemicals may be 

considered; however, no analogs 

have been identified at this time. 

Risk to plants will be assumed in 

the absence of data.

850.4150

or

850.4250B

Terrestrial plant 

toxicity (Tier I or Tier 

II vegetative vigor)

44537029 Acceptable No

A As of July 2012 the Final Guideline 850.4100 contains both Tier I and Tier II test guidance. B As of July 2012 the Final Guideline 850.4150 contains both Tier I and Tier II test guidance.

7. References

USEPA. 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide 

Programs. U.S. Environmental Protection Agency, Office of Prevention, Pesticides and 

Toxic Substances, Office of Pesticide Programs, Washington DC. January 23, 2004.

USFWS and NMFS. 1998. Endangered Species Consultation Handbook: Procedures for 

Conducting Consultation and Conference Activities Under Section 7 of the Endangered 

Species Act. Final Draft. March 1998. 
25

APPENDIX A. Submitted Environmental Fate and Effects Studies

Environmental Fate Studies

MRID Citation

44014252 Adam, D. (1994) Hydrolysis of CGA-245704 Under Laboratory Conditions: Lab Project Number: 

17/93: 93DA01: PR 17/93. Unpublished study prepared by Ciba-Geigy Ltd. 82 p. 

44014253 Adam, D. (1994) Degradation of CGA-245704 in Soil Under Aerobic, Aerobic/Anaerobic, and 

Sterile/Aerobic Conditions at 20 (degrees) C: Lab Project Number: PR 48/94: 93DA02. 

Unpublished study prepared by Ciba-Geigy Ltd. 72 p. 

44014254 Keller, A. (1995) Adsorption/Desorption of CGA-245704 in Various Soil Types: Lab Project 

Number: 94AK04. Unpublished study prepared by Ciba-Geigy Ltd. 80 p. 

44537034 Spare, W. (1998) Aqueous Photolysis of (carbon-14)-CGA-245704: Lab Project Number: 12228: 

112-96. Unpublished study prepared by Agrisearch Inc. 729 p. 

44537035 Spare, W. (1997) Photodegradation of (Phenyl-U-(carbon-14))CGA-245704 on Soil Under 

Artificial Sunlight: Lab Project Number: 12229: 111-96. Unpublished study prepared by 

Agrisearch Inc. 555 p. 

44537036 Adam, D. (1994) Degradation of CGA-245704 in Soil Under Aerobic, Aerobic/Anaerobic and 

Sterile/Aerobic Conditions at 20(degree centigrade): Amendments to Final Report (MRID 

#44014253): Lab Project Number: 93DA02: 568-93: PR-48/94. Unpublished study prepared by 

Novartis Crop Protection AG. 6 p. 

44537037 Schwartz, B. (1998) Anaerobic Aquatic Metabolism of (U-Phenyl-(carbon-14)CGA-245704: Lab 

Project Number: ABR-97122: 219-96. Unpublished study prepared by Novartis Crop Protection, 

Inc. 243 p. 

44537038 Adam, D. (1995) Degradation and Metabolism of (carbon-14)-CGA-245704 in Aerobic Aquatic 

Systems: Lab Project Number: 94DA01: 487-94. Unpublished study prepared by Novartis Crop 

Protection AG. 82 p. 

44537039 Erhardt-Zabik, S.; Wolt, J. (1996) Design and interpretation of herbicide anaerobic aquatic 

metabolism studies: CGA-245704. Weed Technology 10:191-201. 

44537040 Spare, W. (1997) Laboratory Column Leaching Characteristics of Aged (Phenyl-U-(carbon14)CGA-245704 in Six Soil Types: Lab Project Number: 12239: 45-97. Unpublished study 

prepared by Agrisearch, Inc. 468 p.

44537041 Spare, W. (1997) Adsorption/Desorption of (carbon-14)-CGA-245704 by the Batch Equilibrium 

Method on Representative Agricultural Soils: Lab Project Number: 12226: 107-96. Unpublished 

study prepared by Agrisearch, Inc. 364 p. 

44537042 Spare, W. (1996) Adsorption/Desorption of (carbon-14)-CGA-210007 by the Batch Equilibrium 

Method on Representative Agricultural Soils: Lab Project Number: 12227: 108-96. Unpublished 

study prepared by Agrisearch, Inc. 359 p. 
26

44537044 Formica, G. (1993) Determination of Residues of Parent Compound by High Performance Liquid 

Chromatography (HPLC): CGA-245704: Lab Project Number: 218-98: REM 172.04. Unpublished 

study prepared by Novartis Crop Protection AG. 18 p. 

44537046 Jacobson, B.; Balu, K.; Manuli, P. (1998) Terrestrial Field Dissipation of CGA-245704-50WG with 

Tomatoes and Bare Soil in California: Lab Project Number: 121-96: 242.18: 01-9604. Unpublished 

study prepared by Waterborne Environmental, Inc. Minnesota Valley Testing Laboratory, Inc. 386 

p. 

44537047 Jacobson, B.; Balu, K.; Manuli, P. (1998) Terrestrial Field Dissipation of CGA-245704-50WG on 

Bare Soil in North Carolina: Lab Project Number: 303-97: 242. 33: 01-9706. Unpublished study 

prepared by Waterborne Environmental, Inc. and Minnesota Valley Testing Laboratory, Inc. 301 p. 

44537048 Formica, G. (1995) Determination of the Metabolite CGA 210007 by High Performance Liquid 

Chromatography (HPLC): Lab Project Number: REM 172.08: 219-98. Unpublished study prepared 

by Novartis Crop Protection AG. 20 p. 

44537049 Clark, A. (1998) Uptake, Depuration, and Bioconcentration of (carbon-14)-CGA-245704 in 

Bluegill Sunfish (Lepomis macrochirus) Under Flow-Through Test Conditions: Lab Project 

Number: ABR-97035: 277-96: 43459. Unpublished study prepared by Novartis Crop Protection, 

Inc. 199 p. 

44537063 Hayworth, C. (1998) (Carbon 14)-CGA-245704: Uptake and Distribution of Residues in Field 

Grown Confined Rotational Crops: Lab Project Number: ABR-98002: 248-96: 436001. 

Unpublished study prepared by Novartis Crop Protection, Inc. 150 p. {OPPTS 860.1850}

Effects Studies

MRID Citation

44014207 Johnson, A. (1993) CGA 245704: Acute Oral Toxicity (LD50) to the Mallard Duck: Lab Project 

Number: CBG 625/931492: 573-93. Unpublished study prepared by Huntingdon Research Centre 

Ltd. 41 p.

44014208 Johnson, A. (1993) CGA 245704: Acute Oral Toxicity (LD50) to the Bobwhite Quail: Lab Project 

Number: CBG 624/931489: 572-93. Unpublished study prepared by Huntingdon Research Centre 

Ltd. 42 p.

44014209 Johnson, A. (1993) CGA 245704: Subacute Dietary Toxicity (LC50) to the Bobwhite Quail: Lab 

Project Number: CBG 622/931451: 570-93. Unpublished study prepared by Huntingdon Research 

Centre Ltd. 39 p.

44014210 Johnson, A. (1993) CGA 245704: Subacute Dietary Toxicity (LC50) to the Mallard Duck: Lab 

Project Number: CBG 623/931450: 571-93. Unpublished study prepared by Huntingdon Research 

Centre Ltd. 39 p.

44014211 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Flow-Through Acute Toxicity Test with 

the Bluegill (Lepomis macrochirus): (Final Report): Lab Project Number: 108A-176: 148-96. 

Unpublished study prepared by Wildlife International Ltd. 46 p.

44014212 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Flow-Through Acute Toxicity Test with 

the Rainbow Trout (Oncorhynchus mykiss): (Final Report): Lab Project Number: 108A-177: 147-

96. Unpublished study prepared by Wildlife International Ltd. 46 p.
27

44014213 Roberts, C.; Swigert, J. (1996) CGA-245704: A 48-Hour Flow-Through Acute Toxicity Test with 

the Cladoceran (Daphnia magna): (Final Report): Lab Project Number: 108A-175: 149-96. 

Unpublished study prepared by Wildlife International Ltd. 46 p. 

44014251 Petto, R. (1994) Laboratory Testing for the Toxicity of CGA 245704 to Honey Bees, Apis 

mellifera L: Lab Project Number: 417003: 574-93. Unpublished study prepared by RCC 

Umweltchemie GmbH & Co. 23 p. 

44537004 Johnson, A. (1993) CGA-245704: Acute Oral Toxicity (LD50) to the Mallard Duck: Lab Project 

Number: CBG 625/931492: 573-93: CBG 625. Unpublished study prepared by Huntingdon 

Research Centre Ltd. 43 p. 

44537005 Johnson, A. (1993) Acute Oral Toxicity (LD50) to the Bobwhite Quail with CGA-245704: Lab 

Project Number: CBG 624/931489: 572-93. Unpublished study prepared by Huntingdon Research 

Centre Ltd. 42 p.

44537006 Johnson, A. (1993) Subacute Dietary Toxicity (LC50) to the Bobwhite Quail with CGA-245704: 

Lab Project Number: CBG 622/931451: 570-93. Unpublished study prepared by Huntingdon 

Research Centre Ltd. 39 p. 

44537008 Johnson, A. (1993) Subacute Dietary Toxicity (LC50) to the Mallard Duck with CGA-245704: 

Lab Project Number: CBG 623/931450: 571-93. Unpublished study prepared by Huntingdon 

Research Centre Ltd. 39 p.

44537009 Redgrave, V. (1995) Bobwhite Quail Dietary Reproduction and Tolerance Studies with CGA245704: Lab Project Number: CBG 621/942676: 595-93. Unpublished study prepared by 

Huntingdon Research Centre Ltd. 268 p.

44537010 Redgrave, V. (1995) Mallard Duck Dietary Reproduction and Tolerance Studies with CGA245704: Lab Project Number: CBG 620/942943: 596-93. Unpublished study prepared by 

Huntingdon Research Centre Ltd. 205 p.

44537011 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Flow-Through Acute Toxicity Test with 

the Bluegill (Lepomis macrochirus): Lab Project Number: 108A-176: 148-96. Unpublished study 

prepared by Wildlife International Ltd. 46 p.

44537012 Rufli, H. (1995) Acute Toxicity Test of CGA-210007 Technical (Metabolite of CGA-245704) to 

Rainbow Trout (Oncorhynchus mykiss) in the Static System: Lab Project Number: 943649: 789-

95. Unpublished study prepared by Ciba-Geigy Ltd. 28 p.

44537013 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Flow-Through Acute Toxicity Test with 

the Rainbow Trout (Oncorhynchus mykiss): Lab Project Number: 108A-177: 147-96. 

Unpublished study prepared by Wildlife International Ltd. 46 p.

44537014 Roberts, C.; Swigert, J. (1996) CGA-245704: A 48-Hour Flow-Through Acute Toxicity Test with 

the Cladoceran (Daphnia magna): Lab Project Number: 108A-175: 149-96. Unpublished study 

prepared by Wildlife International Ltd. 46 p.

44537015 Grade, R. (1994) Report on the Acute Toxicity Test of CGA-210007 Technical (Metabolite of 

CGA-245704) on Daphnia (Daphnia magna Straus 1820): Lab Project Number: 943555: 511-94. 

Unpublished study prepared by Ciba-Geigy Ltd. 27 p.
28

44537016 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Flow-Through Acute Toxicity Test with 

the Sheepshead Minnow (Cyprinodon variegatus): Lab Project Number: 108A-178: 152-96. 

Unpublished study prepared by Wildlife International Ltd. 47 p. 

44537017 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Shell Deposition Test with the Eastern 

Oyster (Crassostrea virginica): Lab Project Number: 108A-180: 151-96. Unpublished study 

prepared by Wildlife International Ltd. 47 p. 

44537018 Roberts, C.; Swigert, J. (1996) CGA-245704: A 96-Hour Flow-Through Acute Toxicity Test with 

the Saltwater Mysid (Mysidopsis bahia): Lab Project Number: 108A-179: 150-96. Unpublished 

study prepared by Wildlife International Ltd. 46 p. 

44537019 Graves, W.; Mank, M.; Swigert, J. (1997) CGA-245704: An Early Life-Stage Toxicity Test with 

the Rainbow Trout (Oncorhynchus mykiss): Lab Project Number: 108A-186: 154-96. 

Unpublished study prepared by Wildlife International Ltd. 83 p. 

44537020 Graves, W.; Mank, M.; Swigert, J. (1996) CGA-245704: A Flow-Through Life-Cycle Toxicity 

Test with the Cladoceran (Daphnia magna): Lab Project Number: 108A-187: 153-96. Unpublished 

study prepared by Wildlife International Ltd. 64 p.

44537028 Porch, J.; Krueger, H. (1998) CGA-245704 50 WG: A Tier I Toxicity Test to Determine the 

Effects of the Test Substance on Seedling Emergence of Ten Species of Plants: Lab Project 

Number: 108-388: 757-97.

44537029 Krueger, H.; Porch, J.; Springer, T. (1997) CGA-245704 50 WG: A Toxicity Test to Determine 

the Effects of the Test Substance on Vegetative Vigor of Ten Species of Plants: Lab Project 

Number: 108-389: 308-97. Unpublished study prepared by Wildlife International, Ltd. 132 p. 

{OPPTS 850.4150}

44537030 Hughes, J.; Alexander, M.; Conder, L. (1997) Effect of CGA-245704 on the Growth and 

Reproduction of Selenastrum capricornutum: Lab Project Number: 21-01-1: 367-96. Unpublished 

study prepared by Carolina Ecotox, Inc. 73 p. 

44537031 Grade, R. (1995) Report on the Growth Inhibition Test of CGA-210007 Technical (Metabolite of 

CGA-245704) to Green Algae (Selenastrum capricornutum): Lab Project Number: 943650: 790-

95. Unpublished study prepared by Ciba-Geigy Ltd. 27 p. 

44537032 Hughes, J.; Alexander, M.; Conder, L. (1997) Effect of CGA-245704 on the Growth and 

Reproduction of Lemna gibba: Lab Project Number: 21-01-2: 368-96. Unpublished study prepared 

by Carolina Ecotox, Inc. 93 p. 

44537033 Petto, R. (1994) Laboratory Testing for Toxicity (Acute Contact and Oral LD50) of CGA-245704 

to Honey Bees, Apis mellifera L: Lab Project Number: 417003: 574-93. Unpublished study 

prepared by RCC Umweltchemie GMBH & Co. 23 p.
29

APPENDIX B. SIP v.1.0 Inputs and Outputs

Table 1. Inputs

Parameter Value

Chemical name Acibenzolar

Solubility (in water at 25oC; mg/L) 7.7

Mammalian LD50 (mg/kg-bw) 5000

Mammalian test species laboratory rat

Body weight (g) of "other" mammalian 

species

Mammalian NOAEL (mg/kg-bw) 10

Mammalian test species laboratory rat

Body weight (g) of "other" mammalian 

species

Avian LD50 (mg/kg-bw) 2000

Avian test species northern bobwhite quail

Body weight (g) of "other" avian species

Mineau scaling factor 1.15

Mallard NOAEC (mg/kg-diet) 1000

Bobwhite quail NOAEC (mg/kg-diet) 600

NOAEC (mg/kg-diet) for other bird species 0

Body weight (g) of other avian species 0

NOAEC (mg/kg-diet) for 2nd other bird 

species 0

Body weight (g) of 2nd other avian species 0

Table 2. Mammalian Results

Parameter Acute Chronic

Upper bound exposure (mg/kg-bw) 1.3244 1.3244

Adjusted toxicity value (mg/kg-bw) 3845.8028 7.6916

Ratio of exposure to toxicity 0.0003 0.1722

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) 6.2370 6.2370

Adjusted toxicity value (mg/kg-bw) 1440.8590 49.6126

Ratio of exposure to acute toxicity 0.0043 0.1257

Conclusion*

Drinking water exposure 

alone is NOT a potential 

concern for birds

Drinking water exposure 

alone is NOT a potential 

concern for birds

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. 

Therefore, when aggregated with other routes (i.e., diet, inhalation, dermal), pesticide exposure through 

drinking water may contribute to a total exposure that has potential for effects to non-target animals.
30

APPENDIX C. STIR v.1.0 Inputs and Outputs

Input

Application and Chemical Information

Enter Chemical Name Acibenzolar

Enter Chemical Use Outdoor

Is the Application a Spray? (enter y or n) y

If Spray What Type (enter ground or air) air

Enter Chemical Molecular Weight (g/mole) 210.3

Enter Chemical Vapor Pressure (mmHg) 3.50E-06

Enter Application Rate (lb a.i./acre) 0.0625

Toxicity Properties

Bird

Enter Lowest Bird Oral LD50 (mg/kg bw) 2000

Enter Mineau Scaling Factor 1.15

Enter Tested Bird Weight (kg) 0.178

Mammal

Enter Lowest Rat Oral LD50 (mg/kg bw) 5000

Enter Lowest Rat Inhalation LC50 (mg/L) 5.02

Duration of Rat Inhalation Study (hrs) 4

Enter Rat Weight (kg) 0.35

Output

Results Avian (0.020 kg )

Maximum Vapor Concentration in Air at Saturation (mg/m3) 3.96E-02

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 4.98E-03

Adjusted Inhalation LD50

1.12E+0

1

Ratio of Vapor Dose to Adjusted Inhalation LD50 4.45E-04

Exposure not Likely 

Significant

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 6.00E-03

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD50 5.36E-04

Exposure not Likely 

Significant

Results Mammalian (0.015 kg )

Maximum Vapor Concentration in Air at Saturation (mg/m3) 3.96E-02

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 6.26E-03

Adjusted Inhalation LD50

2.99E+0

2

Ratio of Vapor Dose to Adjusted Inhalation LD50 2.09E-05

Exposure not Likely 

Significant

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 7.55E-03

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD50 2.53E-05

Exposure not Likely 

Significant
31

APPENDIX D. Chemical Names, Structures, and Maximum Reported 

Degradate Production in Environmental Fate Studies

Table D-1. Chemical Names and Structures of Acibenzolar and its Degradates

Chemical Name Structure

Acibenzolar (CGA-245704)

IUPAC name: S-methyl 

benzo[1,2,3]thiadiazole-7-carbothioate

CAS name: S-methyl 1,2,3-

benzothiadiazole-7-carbothioate

CGA-176315

IUPAC Name: Benzo[1,2,3Jthiadiazole-7-

carboxylic acid, methyl ester

CGA-210007

CAS name: benzo[1,2,3]thiadiazole-7-

carboxylic acid

CGA-206485

IUPAC name: Benzo[1,2,3]thiadiazole

CGA-307970

CAS name: Thianthrene

N

N

S

S

CH3

O

N

N

S

O

CH3

O

N

N

S

O OH

N

N

S

S

S
32

Chemical Name Structure

CGA-323060

CGA-324041

CGA-337304

IUPAC Name: 1,1-Dioxo-3-oxy-1H-1λ 6-

benzo[1,2,3]thiadiazole-7-carboxylic acid

CGA-379019

A5

N

N

S

O OH

OH

N

N

S

O OH

HO

N

N

S

O OH

O

O

O

S

O OH

O

O

O

S

O

O

O

C C

O

SO2NH2
33

Chemical Name Structure

A7

A8

A14 (Dimer)

Table D-2. Maximum Reported Amounts of Acibenzolar Degradation Products.

Degradate Maximum % of Applied (ppm in Field Studies) Study Type MRID

CGA-176315 Laboratory studies

Irradiated non-sterile @ 25 ̊C 8.2% (15 d)

Control non-sterile @ 25 ̊C 4.9% (0.25 d)

Irradiated sterile @ 25 ̊C 7.3% (15 d)

Control sterile @ 25 ̊C 3.9% (14 d)

Soil Photolysis 44537035

Water Fraction @ 25 ̊C 2.3% (7 d)

Sediment Fraction @ 25 ̊C 2% (7 d)

Total System @ 25 ̊C 2.49% (7 d)

Anaerobic Aquatic 

Metabolism 44537037

MS Loam aged 2.3 h @ 25 ̊C 3.1% (treated layer)

GA sandy loam aged 53.5 h @ 25 ̊C 0.8% (treated layer)

NC sandy clay loam aged 1 h @ 25 ̊C 0.2% (treated layer)

Switzerland loam aged 2.7 min. @ 25 ̊C 0% (N.A.)

MD loamy sand aged 2.2 h @ 25 ̊C 1.1% (treated layer)

CA sandy loam aged 19.5 h @ 25 ̊C 0.6% (treated layer)

Aged Soil Column 

Leaching 44537040

<DL (uptake day 28 fillet from 16ppb treatment)

<DL (uptake day 28 viscera from 16ppb treatment)

0.02ppm (uptake day 28 fillet from 156ppb treatment)

0.03ppm (uptake day 28 viscera from 156ppb treatment)

Bioaccumulation in 

Fish 44537049

CGA-210007 Laboratory studies

pH 1.17 @ 24 ̊C 44.84% (23 d)

pH 1.17 @ 50 ̊C 58.01% (23 d)

pH 1.33 @ 70 ̊C 96.27% (30 d)

pH 5.12 @ 24 ̊C 4.52% (30 d)

pH 5.23 @ 50 ̊C 42.92% (30 d)

Abiotic Hydrolysis 44014252

OH

O

C C S

O

O

NH2

C C C S

O

O

NH2

O

O

C

SO2NH2

C

HO2C

H

N

N

S

S

O

N

N

S

S

O
34

Degradate Maximum % of Applied (ppm in Field Studies) Study Type MRID

pH 5.39 @ 70 ̊C 108.32% (28 d)

pH 7.17 @ 24 ̊C 35.38% (30 d)

pH 7.30 @ 50 ̊C 93.97% (30 d)

pH 7.30 @ 70 ̊C 78.32% (0.31 d)

pH 9.15 @ 24.2 ̊C 41.27% (0.26 d)

pH 9.02 @ 50 ̊C 87.68% (0.087 d)

pH 9.16 @ 70 ̊C 104.2% (0.031 d)

pH 13 @ 24 ̊C 101.61% (0.01 d)

Irradiated pH 5 @ 25 ̊C 0.9% (3 d)

Control pH 5 @ 25 ̊C 8.4% (30 d) Aqueous Photolysis 44537034

Irradiated non-sterile @ 25 ̊C 65.4% (5 d)

Control non-sterile @ 25 ̊C 107% (14 d)

Irradiated sterile @ 25 ̊C 25.7% (15 d)

Control sterile @ 25 ̊C 52.1% (30 d)

Soil Photolysis 44537035

MS Loam @ 25 ̊C 85.5% (3 d)

GA sandy loam @ 25 ̊C 58.4% (8 d)

NC sandy clay loam @ 25 ̊C 92.7% (1 d)

Switzerland loam @ 25 ̊C 91.1% (1 d)

MD loamy sand @ 25 ̊C 89.1% (1 d)

CA sandy loam @ 25 ̊C 71.5% (3 d)

Aerobic Soil 

Metabolism 44537040

Aerobic non-sterile @ 20 ̊C 82.57% (1 d)

Anaerobic non-sterile @ 20 ̊C Little change

Aerobic sterile @ 20 ̊C 8.74% (90 d)

Aerobic/anaerobic 

Soil Metabolism 44014253

Water Fraction @ 25 ̊C 70.87% (272 d)

Sediment Fraction @ 25 ̊C 23.88% (14 d)

Total System @ 25 ̊C 92.65% (360 d)

Anaerobic Aquatic

Metabolism 44537037

River Water @ 20 ̊C 75.1% (3 d)

River Sediment @ 20 ̊C 35.26% (59 d)

River Total System @ 20 ̊C 95.74% (7 d)

Pond Water @ 20 ̊C 68.53% (3 d)

Pond Sediment @ 20 ̊C 38.18% (59 d)

Pond Total System @ 20 ̊C 93.39% (7 d)

Aerobic Aquatic 

Metabolism 44537038

MS Loam aged 2.3 h @ 25 ̊C 26.8% (leachate)

GA sandy loam aged 53.5 h @ 25 ̊C 16.8% (treated layer)

NC sandy clay loam aged 1 h @ 25 ̊C 77.4% (leachate)

Switzerland loam aged 2.7 min. @ 25 ̊C 82.6% (leachate)

MD loamy sand aged 2.2 h @ 25 ̊C 47.7% (leachate)

CA sandy loam aged 19.5 h @ 25 ̊C 19.1% (treated layer)

Aged Soil Column 

Leaching 44537040

0.04ppm (uptake day 28 fillet from 16ppb treatment)

0.31ppm (uptake day 28 viscera from 16ppb treatment)

0.61ppm (uptake day 28 fillet from 156ppb treatment)

3.25ppm (uptake day 28 viscera from 156ppb treatment)

Bioaccumulation in 

Fish 44537049

Terrestrial field dissipation studies

Bare ground sandy clay loam soil – 0.099ppm (5 d after last 

treatment)

Tomato in sandy clay loam soil – 0.081ppm (5 d after last 

treatment)

Terrestrial field 

dissipation 44537046

Bare ground sandy loam soil – 0.042ppm (6 h after last 

treatment)

Terrestrial field 

dissipation 44537047

CGA-206485 Laboratory studies
35

Degradate Maximum % of Applied (ppm in Field Studies) Study Type MRID

Irradiated non-sterile @ 25 ̊C Not detected

Control non-sterile @ 25 ̊C Not detected

Irradiated sterile @ 25 ̊C 1.8% (7 d)

Control sterile @ 25 ̊C 1.5% (30 d)

Soil Photolysis 44537035

CGA-307970 Laboratory studies

Irradiated pH 5 @ 25 ̊C 0.9% (3 d)

Control pH 5 @ 25 ̊C 1.2% (30 d) Aqueous Photolysis 44537034

Irradiated non-sterile @ 25 ̊C 3.6% (3.5 d)

Control non-sterile @ 25 ̊C 0.8% (0.25 d)

Irradiated sterile @ 25 ̊C 4.5% (0.5 d)

Control sterile @ 25 ̊C Not detected

Soil Photolysis 44537035

CA sandy loam @ 25 ̊C 0.6% (0 d – impurity) Aerobic Soil 

Metabolism 44537040

MS Loam aged 2.3 h @ 25 ̊C 0.6% (treated layer)

GA sandy loam aged 53.5 h @ 25 ̊C 0.5% (treated layer)

NC sandy clay loam aged 1 h @ 25 ̊C 0.2% (treated layer)

Switzerland loam aged 2.7 min. @ 25 ̊C 0.2% (treated layer)

MD loamy sand aged 2.2 h @ 25 ̊C 0.3% (treated layer)

CA sandy loam aged 19.5 h @ 25 ̊C 0.4% (treated layer)

Aged Soil Column 

Leaching 44537040

CGA323060/324041

Laboratory studies

Irradiated non-sterile @ 25 ̊C 0.9% (10 d)

Control non-sterile @ 25 ̊C Not detected

Irradiated sterile @ 25 ̊C 1.7% (7 d)

Control sterile @ 25 ̊C Not detected

Soil Photolysis 44537035

CGA-323060 

Alone

Laboratory studies

Water Fraction @ 25 ̊C Not detected

Sediment Fraction @ 25 ̊C 0.34% (360 d)

Total System @ 25 ̊C 0.34% (360 d)

Anaerobic Aquatic 

Metabolism 44537037

CGA-324041 

Alone

Laboratory studies

Water Fraction @ 25 ̊C Not detected

Sediment Fraction @ 25 ̊C 0.24% (62 d)

Total System @ 25 ̊C 0.24% (62 d)

Anaerobic Aquatic 

Metabolism 44537037

CGA-337304 Laboratory studies

Irradiated pH 5 @ 25 ̊C 1.0% (3 d)

Control pH 5 @ 25 ̊C 1.1% (10 d) Aqueous Photolysis 44537034

CGA-379019 Laboratory studies

Water Fraction @ 25 ̊C 1.35 % (360 d)

Sediment Fraction @ 25 ̊C 0.6% (187 d)

Total System @ 25 ̊C 1.56% (130 d)

Anaerobic Aquatic 

Metabolism 44537037

A5 Laboratory studies

Irradiated pH 5 @ 25 ̊C 6.6% (0.083 d)

Control pH 5 @ 25 ̊C Not detected Aqueous Photolysis 44537034

A7 Laboratory studies

Irradiated pH 5 @ 25 ̊C 38.5% (0.17 d)

Control pH 5 @ 25 ̊C Not detected Aqueous Photolysis 44537034

A8 Laboratory studies

Irradiated pH 5 @ 25 ̊C 42.2% (0.5 d)

Control pH 5 @ 25 ̊C Not detected Aqueous Photolysis 44537034

A14 Laboratory studies
36

Degradate Maximum % of Applied (ppm in Field Studies) Study Type MRID

Irradiated pH 5 @ 25 ̊C 9.3% (0.041 d)

Control pH 5 @ 25 ̊C Not detected Aqueous Photolysis 44537034

Nonextractable 

Residues

Laboratory studies

Irradiated non-sterile @ 25 ̊C 11.9% (7 d)

Control non-sterile @ 25 ̊C 4.5% (0.25 d)

Irradiated sterile @ 25 ̊C 9.9% (0.25 d)

Control sterile @ 25 ̊C 3.3% (0.25 d)

Soil Photolysis 44537035

Aerobic non-sterile @ 20 ̊C 59.75% (90 d)

Anaerobic non-sterile @ 20 ̊C Little change

Aerobic sterile @ 20 ̊C 7.92% (90 d)

Aerobic/anaerobic 

Soil Metabolism 44014253

Total System @ 25 ̊C 11.81% (130 d) Anaerobic Aquatic 

Metabolism 44537037

River System @ 20 ̊C 26.39% (363 d)

Pond System @ 20 ̊C 36.19% (350 d)

Aerobic Aquatic 

Metabolism 44537038

MS Loam @ 25 ̊C 10.5% (1 d)

GA sandy loam @ 25 ̊C 6.8% (8 d)

NC sandy clay loam @ 25 ̊C 8.9% (3 d)

Switzerland loam @ 25 ̊C 11.6% (3 d)

MD loamy sand @ 25 ̊C 6.1% (6 h)

CA sandy loam @ 25 ̊C 6.3% (3 d)

Aerobic Soil 

Metabolism 44537040

MS Loam aged 2.3 h @ 25 ̊C 3.3% (treated layer)

GA sandy loam aged 53.5 h @ 25 ̊C 6.7% (treated layer)

NC sandy clay loam aged 1 h @ 25 ̊C 4.3% (treated layer)

Switzerland loam aged 2.7 min. @ 25 ̊C 3.7% (treated layer)

MD loamy sand aged 2.2 h @ 25 ̊C 1.9% (treated layer)

CA sandy loam aged 19.5 h @ 25 ̊C 8.1% (treated layer)

Aged Soil Column 

Leaching 44537040

Carbon 

Dioxide

Laboratory studies

Irradiated pH 5 @ 25 ̊C 34.2% (15 d)

Control pH 5 @ 25 ̊C Analysis not performed Aqueous Photolysis 44537034

Irradiated non-sterile @ 25 ̊C 3.1% (10 d)

Control non-sterile @ 25 ̊C 3.2% (20 d)

Irradiated sterile @ 25 ̊C Not detected

Control sterile @ 25 ̊C Not detected

Soil Photolysis 44537035

Aerobic non-sterile @ 20 ̊C 39.37% (360 d)

Anaerobic non-sterile @ 20 ̊C Little change

Aerobic sterile @ 20 ̊C 3.95% (28 d)

Aerobic/anaerobic 

Soil Metabolism 44014253

Total System @ 25 ̊C 1.36% (130 d) Anaerobic Aquatic 

Metabolism 44537037

River System @ 20 ̊C 9.5% (363 d)

Pond System @ 20 ̊C 9.6% (350 d)

Aerobic Aquatic 

Metabolism 44537038

MS Loam @ 25 ̊C 1.0% (3 d)

GA sandy loam @ 25 ̊C 1.2% (8 d)

NC sandy clay loam @ 25 ̊C 1.0% (3 d)

Switzerland loam @ 25 ̊C 1.7% (3 d)

MD loamy sand @ 25 ̊C 1.5% (3 d)

CA sandy loam @ 25 ̊C 1.0% (3 d)

Aerobic Soil 

Metabolism 44537040

min. = minutes; d = days; h = hours.