2

better able to characterize potential risks by elim inating uncertainties for both non-listed and listed species that cannot be accounted for using a lternate methods or weight of evidence.

Data from the following studies are considered to h ave high potential to add value to the ecological risk assessment for captan:

Environmental fate studies:

Guideline 835.4100 – Aerobic Soil Metabolism: Two aerobic soil metabolism studies are acceptable for risk assessment. Additional data ar e required under 40 CFR Part 158 for terrestrial outdoor uses. OCSPP guidance recommend s that these tests be performed with four soils. Because OCSPP uses an upper 90 th percentile estimate of soil metabolism half-lives based on available study data for modeling purposes, any additional data can reduce uncertainty related to the exposure assessment as well as the half-life value used in modeling. Additional data are considered to have a high potential to add value to the ecological risk and drinking water

assessments.

Guideline 835.4200 – Anaerobic Soil Metabolism: Two anaerobic soil metabolism studies are acceptable for risk assessment. Additional data ar e required under 40 CFR Part 158 for terrestrial outdoor uses. OCSPP guidance recommend s that these tests be performed with four soils. Because OCSPP uses an upper 90 th percentile estimate of soil metabolism half-lives based on available study data for modeling purposes, any additional data can reduce uncertainty related to the exposure assessment as well as the half-life value used in modeling. In the absence of anaerobic aquatic metabolism data, additional data are considered to have a high potential to add value to the ecological risk and drinking water ass essments.

Guideline 835.4400 – Anaerobic Aquatic Metabolism: Data are required under 40 CFR Part 158. OCSPP guidance recommends that these tests be performed with two sediments. Additional data are considered to have a high poten tial to add value to the ecological risk and drinking water assessments.

Ecological effects studies:

Guideline 850.2100 – Avian Acute Oral Toxicity Test , upland game or waterfowl species: The avian endpoints for acute oral toxicity are non -definitive ( i.e. , LD 50 > highest dose tested). The highest concentrations tested, 2150 and 2000 mg /kg-bw for bobwhite quail and mallard duck, respectively (MRIDs 00151236 and 00160000), a re less than the highest avian EECs calculated in the most recent assessments ( i.e ., 4968 mg/kg-bw in the 2007 CRLF litigation assessment; 6107 mg/kg-bw in the 2012 Section 24(c) SLN assessment, DP 400401), and sublethal effects including weight loss, ataxia, an d tremors were noted in the studies. Based on guidance for using non-definitive endpoints 1 , requesting additional data is recommended and considered to have a high potential to add value to the Registration Review ecological risk

assessment.

1 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_non_definitive_endpoints.htm3

Guideline 850.2100 – Avian Acute Oral Toxicity Test , passerine species: Acute oral toxicity data for a passerine species are required under the new 40 CFR Part 158. No studies have been submitted for this data requirement. Given the con cerns identified for existing toxicity data for upland game and waterfowl species and the need to b e protective of passerine species, fulfilling this data requirement has a high potential to add v alue to the Registration Review ecological risk

assessment.

Guideline 850.2200 – Avian Dietary Toxicity Test, u pland game: The avian endpoints for sub-acute dietary toxicity are non-definitive ( i.e. , LC 50 > highest concentration tested). The highest concentration tested, 4680 mg/kg-diet (if c orrected for % a.i.) for both bobwhite quail and mallard duck (MRIDs 43869802 and 43869803) is g reater than the highest avian EEC of 4362 mg/kg-diet calculated in the 2007 California R ed-legged Frog (CRLF) litigation assessment, but less than the highest avian EEC of 5112 mg/kg-diet calculated in the 2012 Section 24(c) SLN assessment (DP 400401). Furtherm ore, there was 30% (3 out of 10) mortality in the 5200 mg/kg-diet treatment group in the bobwh ite quail study, and frank sublethal effects including reduced body weight gain were noted at ≥ 2600 mg/kg-diet for both species. Based on guidance for using non-definitive endpoints 2 , requesting additional data is recommended and considered to have a high potential to add value to the Registration Review ecological risk

assessment.

Guideline 850.4100 – Seedling Emergence and Seedlin g Growth & Guideline 850.4150 – Vegetative Vigor: Data for terrestrial plant species are required un der 40 CFR Part 158. Open literature studies indicate that applications of ca ptan as low as 2.5 lb a.i./A could affect dicots (2007 CRLF litigation assessment; DP 400401). In a ddition, incidents associated with the use of captan and involving plants have been reported (see Section 5.3 ). Therefore, effects to terrestrial plants from use of captan cannot be discounted, and data from terrestrial plant studies are considered to have a high potential to add value to the Registration Review ecological risk

assessment.

Guideline 850.4500 – Algal Toxicity, freshwater dia tom: Data for aquatic non-vascular plant species including a freshwater diatom are required under 40 CFR Part 158. No data has been submitted for this data requirement. Results of aq uatic non-vascular plant toxicity studies with folpet, a phthalimide fungicide that is a structura l analogue of captan, show a freshwater diatom to be the most sensitive species tested. Therefore , freshwater diatoms are likely to be the most sensitive aquatic non-vascular plant species for ca ptan. The freshwater diatom endpoints for folpet (EC 50 /NOEC = 50/30 μg a.i./L) are close to the highest p eak EEC of 21.6 μg/L calculated in the 2007 CRLF litigation assessment and less tha n the highest peak EEC of 91.3 calculated for the 2012 Section 24(c) SLN assessment (DP 400401). Data for a freshwater diatom exposed to captan could impact risk conclusions and are consid ered to have a high potential to add value to the Registration Review ecological risk assessment.

2 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_non_definitive_endpoints.htm4

Non-Guideline Studies – Adult and Larval Honey Bee Acute Oral Toxicity Tests: A honey bee incident involving brood losses and the use of captan has been reported. In addition, the “White Paper in Support of the Proposed Risk Assess ment Process for Bees” as submitted to the FIFRA Scientific Advisory Panel 3 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. Adult honey bee acute contact toxicit y data are available for captan. However, adult and larval honey bee acute oral toxicity data are n ot. Therefore, data from the following nonguideline honey bee toxicity studies are recommende d for request and considered to have a high potential to add value to the Registration Review e cological risk assessment:

• (adult) honey bee acute oral toxicity test and

• larval honey bee acute oral toxicity test.

3 http://www.regulations.gov/#!documentDetail;D=EPA-H Q-OPP-2012-0543-0004

## REGISTRATION REVIEW

PROBLEM FORMULATION

US EPA PC CODE

Prepared by: Robin Sternberg, Ph.D., Wildlife Biologist Faruque Khan, Ph.D., Senior Fate Scientist
Environmental Risk Branch 1

Reviewed by: Anita Ullagaddi, M.S., Biologist Stephen P. Wente, Ph.D., Biologist
Environmental Risk Branch 1
Environmental Fate and Effects Division

5



## REGISTRATION REVIEW

PROBLEM FORMULATION

Captan

CAS Number 133-06-2

US EPA PC CODE 081301

Robin Sternberg, Ph.D., Wildlife Biologist Faruque Khan, Ph.D., Senior Fate Scientist

Environmental Fate and Effects Division U. S. Environmental Protection Agency Office of Pesticide Programs
Environmental Fat e and Effects Division

Environmental Risk Branch I 1200 Pennsylvania Ave., NW

Washington, DC 20460 S. Environmental Protection Agency Office of Pesticide Programs
e and Effects Division
Environmental Risk Branch I 1200 Pennsylvania Ave., NW

Mail Code 7507P Washington, DC 204606 

### Contents

1 Introduction ......................................

................................................... .................................... 7

2 Previous Assessments ..............................

................................................... ............................ 7

3 Overview of Captan Use ............................

................................................... .......................... 9

4 Environmental Fate Summary ........................

................................................... ................... 13

5 Ecological Effects Summary.........................

................................................... ..................... 16

5.1 Parent: Captan ....................................

................................................... ......................... 16

5.1.1 Changes to Toxicity Endpoints and Study Classificat ions ..................................... 20

5.2 Captan Degradates..................................

................................................... ..................... 21

5.3 Review of Incident Databases ......................

................................................... ............... 22

6 Risk Hypothesis ...................................

................................................... .............................. 24

7 Exposure Pathways of Concern ......................

................................................... ................... 24

8 Analysis Plan .....................................

................................................... ................................ 24

8.1 Stressors of Concern...............................

................................................... ..................... 25

8.2 Measures of Exposure ..............................

................................................... ................... 25

8.3 Measures of Effect ................................

................................................... ...................... 25

8.4 Integration of Exposure and Effects ...............

................................................... ............. 26

8.5 Drinking Water Assessment .........................

................................................... ............... 26

8.6 Endangered Species Assessments ....................

................................................... ........... 26

8.7 Endocrine Disruptor Screening Program .............

................................................... ....... 27

9 Data Gaps .........................................

................................................... .................................. 27

9.1 Environmental Fate Data ...........................

................................................... .................. 28

9.1.1 Environmental Fate Data for Degradate, THPI ....... ............................................... 30

9.2 Ecological Effects Data ...........................

................................................... .................... 30

10 References ........................................

................................................... .................................. 36

11 Bibliography of Cited MRIDs .......................

................................................... .................... 37

Appendix A: Chemical Structures of Captan and Its D egradates ......................................... ........ 42

Appendix B: SIP (v 1.0) Inputs and Results ........

................................................... ...................... 43

Appendix C: STIR (v 1.0) Inputs and Results .......

................................................... .................... 457



### 1 Introduction

The purpose of this problem formulation is to provi de an understanding of the environmental fate and ecological effects of the registered uses of captan in support of Registration Review. Captan is a non-systemic, broad-spectrum fungicide that inhibits normal cell division of microorganisms and fungi. Captan is registered for agricultural use on orchard and vine yard crops, beets, corn, cotton, cucurbits, forage grass es, ginseng, grain crops, legumes, melons, peanuts, potatoes, rapeseed, soybeans, strawberries , and vegetables. In addition, captan is registered for non-agricultural use on turf, grasse s grown for seed, and ornamental woody shrubs, vines, trees, and herbaceous plants.



### 2 Previous Assessments

Captan was first registered as a pesticide under th e Federal Insecticide, Fungicide and Rodenticide Act in 1951 to control fungal diseases of fruit crops. Prior to 1980, there were many use patterns registered and tolerances established for this broad-spectrum fungicide.

The captan Reregistration Eligibility Decision (RED ) document was completed in September
1999 4 . The RED ecological risk assessment (DP 207651+) identified risk to:

• birds from chronic exposure 5 ;

• mammals from chronic exposure;

• listed and non-listed freshwater fish from acute ex posure; and

• listed freshwater invertebrates from acute exposure

.

The Agency assessment determined that the data were sufficient to support reregistration of products containing captan, except for those with u ses on turf and aerially-applied wettable powder formulations. Products applied to turf at s od farms or golf courses were eligible for reregistration; uses at all other turf sites were v oluntarily cancelled. Wettable powder formulations that are applied aerially were eligibl e for reregistration, provided either: 1) the products are packaged in water soluble packaging; o r 2) the application rates are reduced to a level that is no higher than 1.2 lb a.i./A.

An amendment to the RED was issued on November 1, 2 004 4 . The amendment included the following ecological risk mitigations:

• The dichondra, ornamental grass, golf course turf, and turf sod farm use rates have been reduced from a single application rate of 43 lb a.i ./A to 4.3 lb a.i./A. Two applications per year are allowed for a seasonal maximum application rate of 8.6 lb a.i./A.

• Spray drift language has been modified to include a n additional requirement for a maximum nozzle height of 4 feet above the crop cano py with ground boom application.

4 http://www.epa.gov/oppsrrd1/reregistration/captan/

5 The potential for chronic risk to avian species is uncertain because test animals were not dosed at le vels sufficient to cause an effect. However, multiple applications of captan at the minimum application interval woul d potentially result in maximum residues greater than the NOEL of 1000 mg/kg-diet for most avian food items.8

• Application restrictions for products used on turf have been expanded to specify a prohibition on applications to turf in residential sites, apartment buildings, daycare centers, playgrounds, sports fields, or other resid ential areas.

An endangered species assessment for listed Pacific Anadromous salmon and steelhead was
conducted in 2003 6 . This regional assessment concluded that use of c aptan in the Pacific Northwest may have the following effects on salmoni d evolutionarily significant units (ESUs):

• may affect the Upper Columbia ESU of chinook salmon and the Snake River ESU of sockeye salmon;

• may affect, but not likely to adversely affect, the Snake River fall-run, Upper Willamette, Lower Columbia, and Puget sound ESUs of chinook sal mon and the Snake River Basin, Upper Columbia River, Middle Columbia River, Upper Willamette River, South-Central California Coast, and Southern California Coast ESU s of steelhead; and

• no effect on California Coastal, Central Valley spr ing-run, and Sacramento River winter run ESUs of chinook salmon, the ESUs of coho and ch um salmon considered, the Ozette Lake ESU of sockeye salmon, and the Lower Columbia River, Norther California, Central California Coast, and Central Valley, Calif ornia ESUs of steelhead.

In 2006, an ecological risk assessment was conducte d in response to the IR-4 petition for use of captan on ginseng (DP 318448+). The assessment was for a maximum single application rate of 2.0 lb a.i./A applied up to 8 times with a minimum application interval of 7 days. The assessment concluded that there is potential for ri sk to mammals from chronic exposure and freshwater fish from acute exposure due to the use of captan on ginseng.

A litigation assessment for the federally-threatene d California Red-legged Frog (CRLF; Rana aurora draytonii ) was conducted in 2007 7 . Overall, a likely to adversely affect (LAA) determination was concluded for the aquatic-phase C RLF, based on direct acute effects and indirect effects related to fish and frogs as food items to adult frogs. For the terrestrial-phase CRLF, an LAA determination was concluded based on d irect effects and indirect effects related to a reduction in mammals and frogs as food items. Given these direct and indirect effects to the CRLF, the assessment concluded that modification of critical habitat is also expected for both aquatic and terrestrial primary constituent element s (PCEs) of the CRLF.

Most recently, a 2012 ecological risk assessment ev aluated a Section 24(c) Special Local Need (SLN) for the use of captan on strawberries in Flor ida to control botrytis and leaf spot (DP 400401). The assessment was for a maximum applicat ion rate of 72 lb a.i./A/year, corresponding to 3 crop cycles. The assessed label specified a maximum single application rate of 3 lb a.i./A, a maximum seasonal rate per berry c rop cycle of 24 lb a.i./A ( i.e. , 8 individual applications at 3 lb a.i./A), and an application in terval of 7 to 14 days. The assessment concluded that there is potential for risk to fres hwater fish from acute exposure; birds and mammals from acute and chronic exposure; and terres trial plants due to the proposed use of
captan.

6 http://epa.gov/espp/litstatus/effects/#captan

7 http://epa.gov/espp/litstatus/effects/redleg-frog/i ndex.html#captan9

A drinking water assessment was performed as a part of EFED's RED Chapter for captan (DP 207651+).



### 3 Overview of Captan Use

Registered uses of captan are provided in Table 3-1

. Captan is formulated as dust, flowable concentrate, liquid, water dispersible granule (dry flowable), and wettable powder and can be applied by aerial equipment or ground equipment. Me thods of application include: band treatment, broadcast, dip treatment, foliar treatment, spray (including high volume), soak, soil treatment (including drench), soil in-furrow treatm ent, wash, and seed treatment. Application information for each use is provided in Table 3-2 . It should be noted that some labels do not specify one or more of the following parameters: ma ximum number of applications per crop cycle or year; maximum application rate per crop cy cle or year; and/or minimum application interval. The registrant(s) should provide this in formation to reduce the use of conservative assumptions.

Table 3-1. Registered Uses of Captan
Spray-Based Application Methods a , Food Use Almond Apple Apricot Blackberry Blueberry Caneberries Cheery Dewberry Ginseng (medicinal) Grapes Nectarine Peach Plum Prune Raspberry (black, red) Strawberry Seed Treatment, Non-Food Use Alfalfa Barley Beans, dried-type Bean, succulent (s nap) Beets (unspecified) Broccoli Brussels sprouts Cabba ge Canola/rape Cauliflower Chard, Swiss Clover Corn, field Corn, sweet Cotton (unspecified) Cowpea /blackeyed pea Cucumber Flax Grasses grown for seed kale Lespedeza Melons, cantaloupe Melons, musk Melons, w ater Mustard Oats Onion Peanuts (unspecified) Peas, dried-type Peas, succulent Peas (unspecified) Pepper Potato, white/Irish Pumpkin Radish Rye Sorghum (unspecified) Soybeans (unspecified) Spinac h Squash (all or unspecified) Sugar beet Sunflower Tomato Trefoil Turnip (greens) Turnip (root) Wheat Spray-Based Application Methods a , Non-Food Use Ginseng (medicinal) Golf course turf Ornamental and /or shade

trees Ornamental herbaceous plants
Ornamental lawns and turf Ornamental sod farm (turf) Ornamental woody shrubs
and vines Rose

a for each use, may include one or more of the follo wing methods of application: band treatment, broadc ast, dip treatment, foliar treatment, spray (including high volume), soak, soil treatment (including drench), s oil in-furrow

treatment, wash

Table 3-2. Application Information for Registered Uses of Captan

Use a.i. Max. Single App. Rate Max. No. of

App. per Crop Cycle Max. App.

Rate per Crop Cycle (lb a.i./A) Max. No.

of App. per Year Min.

App.
Interval (Days)

Strawberry 3.3 lb/A NS 26.4 NS 7

0.0001 lb/linear ft 4 NS NS 710

Use a.i. Max. Single App. Rate Max. No. of

App. per Crop Cycle Max. App.

Rate per Crop Cycle (lb a.i./A) Max. No.

of App. per Year Min.

App.
Interval (Days) Ginseng (medicinal) 2.0 lb/A 8 16.0 NS 7 Orchard Crops
Almond 4.9 lb/A NS 22.0 NS NS a

Apple 4.4 lb/A NS 35.2 NS 5 0.009 lb/gal NS NS 2 7 0.013 lb/gal NS 32.5 or NS NS NS 0.014 lb/gal NS 35.2 NS NS Apricot 2.7 lb/A NS 13.7 NS NS b

Cherry 2.2/3.2 lb/A NS 15.4/13.8 NS 3 0.009 lb/gal NS NS 4 7 0.013 lb/gal NS 14.2 or NS NS NS 0.014 lb/gal NS 15.4 NS NS

Nectarine 4.4 lb/A NS 26.4 NS 3

Peach 4.4 lb/A NS 35.2 NS 3 0.009 lb/gal NS NS 3 11

0.02 lb/A NS 32.6 NS NS Pear 0.014 lb/gal NS NS NS NS
Plum/Prune 3.3 lb/A NS 29.7 NS 7 Vineyard Crops Blackberry 2.2 lb/A NS 11.0 NS 10 Blueberry 2.7 lb/A NS 38.5 NS 7

Caneberries 2.0 lb/A NS 10 NS 10 Dewberry 2.2 lb/A NS 11.0 NS 10 Grapes 2.2 lb/A NS 13.2 NS 10 Raspberry (black, red) 2-2.2 lb/A NS 10-11.0 NS 7 o r 10

Turf
Golf course turf 4.4 lb/A NS 8.8 NS 7

Ornamental lawns and turf 47.8 lb/A NS NS NS 7

6.5-6.6 lb/A NS 8.6 or NS NS NS Ornamental sod farm (turf) 4.3-4.4 lb/A NS 8.5-8.8 or NS NS 7 or NS

Ornamentals

Ornamental and/or shade

trees 6.5 lb/A NS NS NS NS 0.0054 lb/gal NS NS 4 7

Ornamental herbaceous plants 184.3-184.7 lb/A 2 or NS 8.6 NS 7

44.2 lb/A NS NS NS 7 0.0054 lb/gal NS NS 6 7 0.0825 lb/gal NS NS NS NS Ornamental woody shrubs
and vines 6.6 lb/A NS NS NS NS 0.021 lb/gal NS NS NS 7 or NS

Rose 0.0054 lb/gal NS NS 6 7 0.012 lb/gal NS NS NS 7

Seed Treatments

Alfalfa 0.2545 lb/lb seed NS NS NS NS Barley 0.0954 lb/lb seed NS NS NS NS Beans, dried type 0.0938 lb/lb seed NS NS NS NS Beans, succulent (snap) 0.0938 lb/lb seed NS NS NS NS Beets (unspecified) 0.3817 lb/lb seed NS NS NS NS

Broccoli 0.07 lb/lb seed NS NS NS NS Brussels sprouts 0.07 lb/lb seed NS NS NS NS Cabbage 0.07 lb/lb seed NS NS NS NS11

Use a.i. Max. Single App. Rate Max. No. of

App. per Crop Cycle Max. App.

Rate per Crop Cycle (lb a.i./A) Max. No.

of App. per Year Min.

App.
Interval (Days) Canola/rape 0.0625 lb/lb seed NS NS NS NS

Cauliflower 0.07 lb/lb seed NS NS NS NS Chard, Swiss 0.3817 lb/lb seed NS NS NS NS

Clover 0.2545 lb/lb seed NS NS NS NS

Collards 0.0283 lb/lb seed NS NS NS NS Corn, field 0.0743 lb/lb seed NS NS NS NS Corn, sweet 0.1272 lb/lb seed NS NS NS NS Cotton (unspecified) 0.2227 lb/lb seed NS NS NS NS Cowpea/blackeyed pea 0.0938 lb/lb seed NS NS NS NS

Cucumber 0.1018 lb/lb seed NS NS NS NS

Flax 0.1272 lb/lb seed NS NS NS NS Grasses grown for seed 0.2608 lb/lb seed NS NS NS N S

Kale 0.0283 lb/lb seed NS NS NS NS

Lentils 0.0788 lb/lb seed NS NS NS NS Lespedeza 0.2545 lb/lb seed NS NS NS NS Melons - cantaloupe 0.1018 lb/lb seed NS NS NS NS

Melons - musk 0.0636 lb/lb seed NS NS NS NS

Melons - water 0.0636 lb/lb seed NS NS NS NS

Mustard 0.0625 lb/lb seed NS NS NS NS

Oats 0.1272 lb/lb seed NS NS NS NS

Onion 0.8143 lb/lb seed NS NS NS NS Peanuts (unspecified) 0.1909 lb/lb seed NS NS NS NS Peas (unspecified) 0.0827 lb/lb seed NS NS NS NS Peas, dried-type 0.0611 lb/lb seed NS NS NS NS Peas, succulent 0.0611 lb/lb seed NS NS NS NS Pepper 0.0945 lb/lb seed NS NS NS NS Potato, white/Irish 0.0733 lb/lb seed NS NS NS NS Pumpkin 0.0636 lb/lb seed NS NS NS NS

Radish 0.07 lb/lb seed NS NS NS NS Rye 0.0954 lb/lb seed NS NS NS NS Sorghum (unspecified) 0.1909 lb/lb seed NS NS NS NS

Soybeans (unspecified) 1.2 lb/lb seed NS NS NS NS

0.0246 lb/cu ft NS NS NS NS Spinach 0.2099 lb/lb seed NS NS NS NS Squash (all or unspecified) 0.0636 lb/lb seed NS NS NS NS Sugar beet 0.3817 lb/lb seed NS NS NS NS

Sunflower 0.1272 lb/lb seed NS NS NS NS

Tomato 0.0528 lb/lb seed NS NS NS NS

Trefoil 0.2545 lb/lb seed NS NS NS NS Turnip (greens) 0.0625 lb/lb seed NS NS NS NS Turnip (root) 0.0954 lb/lb seed NS NS NS NS

Wheat 0.1251 lb/lb seed NS NS NS NS App. = application; Min. = minimum; Max. = maximum; NS = not specified

a A 7-day application interval was assumed in the 700 7 CRLF litigation assessment.

b A 5-day application interval was assumed in the 20 07 CRLF litigation assessment.12

The results of a Screening Level Usage Analysis (SL UA) for captan 8 as performed by the Biological Economic Analysis Division (BEAD) of OPP are listed in Table 3

- 3 . This analysis provides estimated agricultural uses of captan ( i.e., turf uses are not included) in terms of total pounds of active ingredient. SLUA data sources inc lude:

• USDA-NASS (United States Department of Agriculture' s National Agricultural Statistics Service)

• Private Pesticide Market Research

• California DPR (Department of Pesticide Regulation) The top 5 agricultural uses of captan from 2003 to 2010 in terms of pounds of a.i. applied are apples, strawberries, peaches, almonds, and blueber ries.

Table 3-3. Screening Level Estimates of Agricultur al Uses of Captan Sorted Alphabetically ( Reporting Timeframe: 2003-2010)

Crop Average Annual
Lbs. A.I. Annual Percent Crop Treated

Average Maximum 1 Almonds 200,000 5 10 2 Apples 1,400,000 40 45 3 Apricots 10,000 30 60 4 Beans, Green 1,000 <1 <2.5 5 Blueberries 100,000 50 60 6 Caneberries 40,000 45 70 7 Cantaloupes <500 <1 <2.5 8 Cherries 60,000 15 25 9 Cucumbers 2,000 <1 <2.5 10 Grapes 40,000 <2.5 <2.5 11 Nectarines* 3,000 N/C N/C

12 Onions <500 <2.5 <2.5 13 Peaches 300,000 25 40

14 Peanuts Peanuts (seed treatment) 20,000 5,000 <1

5 <2.5
5

15 Pears 1,000 <1 <2.5 16 Peppers 3,000 <1 <2.5 17 Plums/Prunes 90,000 25 40 18 Pumpkins 2,000 <1 <2.5 19 Soybeans (seed treatment) 1,000 <1 <2.5 20 Squash <500 <1 <2.5 21 Strawberries 400,000 75 90 22 Tomatoes 3,000 <1 <2.5

23 Watermelons <500 <1 <2.5 24 Wheat (seed treatment) 3,000 <1 <2.5 N/C= not calculated since only pounds a.i. availabl e All numbers rounded. <500 Less than 500 pounds of a.i. <2.5 Less than 2.5% of crop treated <1 Less than 1% crop treated * Based on CA DPR data only (80% or more of U.S. ac res grown are in California)

8 Date: June 12, 201213



### 4 Environmental Fate Summary

Selected physical, chemical, and environmental fate properties of captan are listed in Table 4-1

. Captan has a low solubility (3.3 mg/L at 25°C) in w ater. The vapor pressure (<9.75 × 10 -6 mm Hg) and Henry's Law Constant (4.6 x 10 -9 atm-m3/mol) indicate that captan is a low-volatile
chemical. Over a 9-day period, approximately 0.003% of ring-l abeled captan volatilized from a
sand soil treated at a rate of 1 lb a.i./A in a laboratory v olatility study. Laboratory studies also suggest that c aptan has a relatively short degradation half-life (t 1/2 <1 to 15days) in soil and aquatic environments. Abiotic hydrolysis and aerob ic metabolism appear to be the major routes of captan dissipation in the environment. In both soil and water, the sulfur-nitrogen bond cleaves, thus separating the trichloromethylthio (T CMT) and tetrahydrophthalamide (THPI) moieties of the molecule. The TCMT moiety degrades by aerobic soil metabolism to form CO 2 , thiophosgene, and inorganic sulfur and chlorine. Di ssipation of thiophosgene is expected to be controlled by volatilization (est. vapor pressure=2 9.7 mm Hg and estimated Henry’s Law
Constant of 0.00586 atm•M -3 mole -1 ). It should be noted that thiophosgene was not de tected as a volatile component in any of the submitted laborato ry studies for captan. In aerobic aquatic metabolism study, the maximum reported THPI concent ration (81.2% of applied) detected at day 0 and tetrahydrophthalimic acid (THPAm) (27.0% of a pplied) and tetrahydrophthalic acid (THPAL) (10.8% of applied) reached their maximum at day 14. THPI and THPAm were also major degradates identified in aerobic soil metabol ism study. Captan photodegradation on soil also occurs, but is secondary to hydrolysis and aer obic soil metabolism.

THPI is degraded (t 1/2 = 5.8 to 20 days) by aerobic soil metabolism to a series of ring-containing products (including THPAm) and ultimately CO 2 (MRID 438689-02). Evidence indicates that THPI is more persistent (t 1/2 of 5.8 to 20 days) than parent compound which may b e present in soil for several weeks following captan application (Table 4.2). An additional cyano-acid major metabolite, cis-6-cyano-3-cyclohexenecarboxylic aci d (THCY) of captan was also identified in anaerobic soil metabolism and soil photolysis studi es. A maximum 20% of applied was detected in anaerobic soil metabolism study. THCY is unlike ly to be present in soil in significant
amounts under aerobic soil condition. Two minor de gradates were also detected in laboratory studies. These degradates are tetrahydrophthalamide epoxide (THPI-Epoxide) and 5 ,6 dihydroxyhexaryohophthalamide (Diol). Various degradate structures of captan can be found in Appendix A

.

Since captan is unstable due to rapid hydrolysis, b atch equilibrium adsorption/desorption is not a reliable method to determine adsorption/desorption coefficient of captan. Soil K d values were estimated using soil thin layer chromatography (TLC ) method. Soil K
oc of 103 to 575 ml/g indicate that captan is generally expected to be mo bile to moderate mobile in soil according to FAO pesticide mobility classification (FAO 2000). Koc values of 33 to 600 have also been reported in the open literature 9 for captan. In terrestrial field studies, however , captan was shown to be relatively immobile to slightly mobile at 6 d ifferent field sites. Soil Adsorption coefficient (Koc) values for THPI ranged from 8.3 to 13 L/kg in six soils (MRID 438689-11) and is expected to be mobile with surface water runoff or leaching into the soil ( Table 4-2 ).

9 http://toxnet.nlm.nih.gov/cgi-bin/sis/search/f?./te mp/~ixIqg7:1Table 4- 1. Selected Physical and Chemical Properties of C aptan

Parameter
Chemical Structure

Chemical Name Chemical Name (CAS)

Chemical Name (IUPAC)

Smiles notation

CAS Number

PC Code

Molecular Formula Molecular Weight Physical State

Color

Odor Density Vapor pressure

Water Solubility (pH 7, 25 o C)

Henry’s law constant

Octanol/Water Partition Coefficient (logK

ow ) Laboratory Volatility Hydrolysis pH 5

pH 7 pH 9 Photodegradation in water (pH 5)
Photodegradation in soil

Aerobic soil metabolism half-life

14 1. Selected Physical and Chemical Properties of C aptan

Value and Unit Sources

MRID 481125 02

Captan MRID 481125 02 3a,4,7,7a-tetrahydro-2-[(trichloro methyl)thio]-1H-isoindole-1,3(2H)-
dione MRID 481125 02

N -(trichloromethylthio)cyclohex-4- ene-1,2-dicarboximide MRID 481125 02

O=C(N(SC(Cl)(Cl)Cl)C(=O)C1CC=C C2)C12 EPISUITE 4.1

133-06-2 MRID 481125 02

081301 MRID 481125 02

C 9 H 8 CI 3 NO 2 S MRID 481125 02 300.57 gram/mol MRID 481125 02 Amorphous powder MRID 481125 04 White to beige MRID 481125 04

Odorless MRID 481125 04 1.62g/cm 3 @ 22°C MRID 481125 04

<1.3 mPa at 25°C
<9.75x 10 6 mm Hg at 25°C Pesticide Manual, 15
cited in MRID 3.3 mg/L at 25°C Pesticide Manual, 15
cited in MRID 481125

4.6 E-09 atm.M 3 Mol - 1 EPISUITE 4.1

2.8 Pesticide Manual, 15
cited in MRID 481125 0.003% Volatilized over 9 day period MRID 40231001

0.8 days 0.20 days 0.006 days MRIDs 41176301
00096974

Stable MRID 40208102
15 days Degradates THPI (21.3%) THCY (9.4%) MRIDs 40 658009

1.1 days a <1.0 days

Major Degradates THPI (66.0%) THPAm (16.5%)

Minor Degradates ( ≤ 3.2)

THPAI MRID s 00070414 02

02

02

02

02

02

02

02

04

04

04

04 Pesticide Manual, 15 th ed, p-155

48112504 Pesticide Manual, 15 th ed, p-155
MRID 481125 04

Pesticide Manual, 15 th ed, p-155
MRID 481125 04

MRID 40231001

41176301 , 40208101,

40208102

658009 , 40658010

s 00070414 and 4065800715

Parameter Value and Unit Sources

Diol THPI-Epoxide

Anaerobic soil metabolism half-life <1.0 days
Metabolites b
THPI ( ≈ 46%) THPAm ( ≈ 35%) THPAI ( ≈ 22%) THCY ( ≈ 20%) MRIDs 00098881, 40658008

Aerobic aquatic metabolism half-life <1.0 days Degradates THPI (81.2%) THPAm (27%) THPAL (10.8%) THPI Epoxide (9.4%) MRIDs 00096974, 40114502,
43868905

Soil Kd (K

oc ) Mackburg Silt clay loam- 4 (164) ml/g Crowley clay loam – 3 (185) ml/g Stockton Adobe clay 8 (585) ml/g Oakley sandy loam 7 (549) ml/g Nicollet clay loam 4 (103) ml/g MRIDs 00096972, 4065801

Terrestrial Field Dissipation (t 1⁄2 ) Study Sites Florida 3 days California 24 days Florida 3 days California 6 days New York 14 days Texas 4 days MRIDs 40823901, 40893601, 40893602, 40893603, 40932201,
40932202

Bioconcentration (BCFs) 102X for edible
126X non-edible
113X whole fish MRIDs 40756601, 40756602

a = No reported half-life. Estimated based on first-o rder degradation equation using 99% applied captan degraded in 7 day

b = Visual estimates. Degradates estimate were prese nted in a graphic form in the Data Evaluation Repor t.

Table 4-2. Environmental Fate Properties for the De gradate, THPI

Parameters Values and Unit Sources
Chemical Structure EPISUIE 4.1

Chemical Name 1,2,3,6-Tetrahydrophthalimide MRID 43868902

Soil Partition Coefficient K d (K

oc ) Gayton loamy sand - 0.16 (9.1) ml/g East Anglia sandy loam – 0.16 (8.6) Kenny Hill sandy loam 0.23 (7.6) ml/g Lily field sand 0.04 (8.3) ml/g Nebo silty clay loam 0.19 (13) ml/g Salmonds Bridge sandy loam 0.13 (8.4) ml/g MRID 438689-11

Molecular Weight 151.6 EPISUITE 4.1 Solubility (25° C) 42778 mg/L EPISUITE 4.1

Aerobic soil Metabolism t 1/2 5.8 - 20.0 days MRID 43868902 Aerobic Aquatic Metabolism Half-Life 21 days MRID 0 009888116

Captan has a low potential for bioaccumulation in f ish due to rapid hydrolysis in aquatic environments and low log K
ow (2.79) ( Table 4-1 ). Captan residues had fish bioconcentration factors (BCF) of 102X, 126X, and 113X for edible, n on-edible, and whole fish tissue, respectively. After a 14-day depuration period, ca ptan residues in edible tissue, non-edible tissue, and whole fish declined by 94%, 96%, and 95 %, respectively.

In terrestrial field dissipation study, parent capt an degraded with half-lives of 3 to 24 days and was relatively immobile to slightly mobile at six s ites. The maximum depth at which captan was detected was 6-12 inches. The degradate THPI was d etected at all sites and declined to less than detectable (0.01 ppm) levels between 14 and 184 day s after the final captan treatment. THPI was not detected below 12 inches of soil profiles.



### 5 Ecological Effects Summary

5.1 Parent: Captan

Studies characterizing the toxicity of captan are s ummarized in Table 5-1 . No studies have been submitted since the 2007 CRLF litigation assessment

.

Captan is practically non-toxic to birds on an acut e oral and sub-acute dietary basis; practically
non-toxic to terrestrial invertebrates on an acute contact basis; and moderately toxic to very highly toxic to fish and aquatic invertebrates on a n acute basis.

Data are not available for the following:

• acute toxicity to a passerine species;

• acute oral toxicity to adult honey bees ( Apis mellifera );

• acute oral toxicity to larval honey bees ( Apis mellifera );

• toxicity to terrestrial plants (seedling emergence and vegetative vigor);

• chronic toxicity to an estuarine/marine fish;

• chronic toxicity to estuarine/marine invertebrate;

• toxicity to a freshwater diatom (aquatic non-vascul ar plant); and

• a definitive NOEC for the cyanobacterium Anabaena flos-aquae

.

It should be noted that the avian endpoints for acu te oral and sub-acute dietary toxicity are nondefinitive ( i.e. , LD 50 or LC 50 > highest dose or concentration tested). For avia n acute oral toxicity, the highest concentrations tested, 2150 a nd 2000 mg/kg-bw for bobwhite quail and mallard duck, respectively (MRIDs 00151236 and 0016 0000), are less than the highest avian EECs calculated in the most recent assessments ( i.e ., 4968 mg/kg-bw in the 2007 CRLF litigation assessment; 6107 mg/kg-bw in the 2012 Se ction 24(c) SLN assessment, DP 400401), and sublethal effects including weight loss, ataxia , and tremors were noted in the studies.

For avian sub-acute dietary toxicity, the highest c oncentration tested, 4680 mg/kg-diet (if corrected for % a.i.) for both bobwhite quail and m allard duck (MRIDs 43869802 and 43869803), is greater than the highest avian EEC of 4362 mg/kg-diet calculated in the 200717

CRLF litigation assessment, but less than the highe st avian EEC of 5112 mg/kg-diet calculated in the 2012 Section 24(c) SLN assessment (DP 400401 ). Furthermore, there was 30% (3 out of 10) mortality in the 5200 mg/kg-diet treatment grou p in the bobwhite quail study, and reduced body weight gain was noted at ≥ 2600 mg/kg-diet for both species.

Table 5-1. Summary of the Endpoints from Toxicity Studies with Captan
Study Type
TGAI/TEP (% a.i.) Species Toxicity Endpoints, Effects, and Acute Toxicity Classification (If Applicable) Source & Study
Classification

Acute oral (NS) Bobwhite quail

(Colinus virginianus) 14-day LD 50 > 2150 mg/kg-bw (nom)

(no mortality; sublethal effects: reduced body weight gain/weight loss at 2150 mg/kg-bw) Practically non-toxic MRID 00151236 Acceptable

Acute oral limit

test TGAI (91) Mallard duck

(Anas platyrhynchos) 14-day LD 50 > 2000 mg/kg-bw (nom)

(no mortality; sublethal effects: ataxia, tremors with remission taking up to 1 week) Practically non-toxic MRID 00160000 Supplemental (due to sample size of n = 3) Acute oral Passerine species No data

Sub-acute dietary TGAI (95) Bobwhite quail

(Colinus virginianus) 8-day LC 50 > 2400 mg/kg-diet (nom)

(no mortality; sublethal effects: not documented) No more than slightly toxic MRID 00022923 Supplemental (due to sample size of n = 8 per
treatment level and
lack of
documentation of sublethal effects)

Sub-acute dietary TGAI (95) Mallard duck

(Anas platyrhynchos) 8-day LC 50 > 5000 mg/kg-diet (nom)

(no mortality; sublethal effects: not documented) Practically non-toxic MRID 00022923 Supplemental (due to only 3
treatment levels being tested and
lack of
documentation of sublethal effects)

Sub-acute dietary TGAI (90) Bobwhite quail

(Colinus virginianus) 8-day LC 50 > 5200 mg/kg-diet a (nom)

8-day NOEC = 1300 mg/kg-diet a (nom) (mortality: 3.3% [1 out of 30] in the control group ; 30% [3 out of 10] at 5200 mg/kg-diet sublethal
effects: NOEC based on reduced food consumption and body weight gain at ≥ 2600 mg/kg-diet) Practically non-toxic MRID 43869802 Acceptable

Sub-acute dietary TGAI (90) Mallard duck

(Anas platyrhynchos) 8-day LC 50 > 5200 mg/kg-diet a (nom)

8-day NOEC = 1300 mg/kg-diet a (nom) (mortality: 3.3% [1 out of 30] in the control group ; none in the treatment groups;
sublethal effects: NOEC based on reduced food consumption and body weight gain at ≥ 2600 mg/kg-diet) Practically non-toxic MRID 43869803 Acceptable18

Study Type
TGAI/TEP (% a.i.) Species Toxicity Endpoints, Effects, and Acute Toxicity Classification (If Applicable) Source & Study
Classification

Chronic TGAI (NS) Bobwhite quail

(Colinus virginianus) 8-week LC 50 > 4640 mg/kg-diet

8-week NOEC = 2150 mg/kg-diet (no mortality; sublethal effects: NOEC based on reduced weigth gain and food consumption at 4650 gm/kg-diet) MRID 000104686 Supplemental (due to deviations from guideline; range-finding study) Reproduction (chronic) (NS) Bobwhite quail

(Colinus virginianus) NOEC = 1000 mg/kg-diet (nom)

(no effects) MRID 00098295 Acceptable

Reproduction (chronic) (NS) Mallard duck

(Anas platyrhynchos) NOEC = 1000 mg/kg-diet (nom)

(no effects) MRID 00098296 Acceptable

Acute contact TEP: Captan 50WP (48.9) Blue orchard bee

(Osmia ligaria) 72-hr LD 50 (95% C.I.) = 270 (151-2842) μg a.i./bee

Practically non-toxic E087252 d
Quantitative

Acute oral TEP: Captan 50WP (48.9) Blue orchard bee

(Osmia ligaria) 72-hr LC 50 (95% C.I.) = 46 (33-77) μg a.i./bee

Practically non-toxic

Acute contact
limit TGAI (NS) Honey bee

( Apis mellifera ) 48-hr LD 50 > 215 μg/bee

Practically non-toxic MRID 00080871 Acceptable

Terrestrial plant seedling

emergence No data

Terrestrial plant vegetative vigor No data

Acute TGAI (90) Freshwater fish b

,

most sensitive:

Brown trout (Salmo trutta) 96-hr LC 50 (95% C.I.) = 26.2 (21.8-31.3) μg/L

(nom) Very Highly Toxic MRID 40098001 Supplemental (due to only 1 replicate per

treatment concentration)

Acute TGAI (90) Bluegill sunfish

( Lepomis
macrochirus ) 96-hr LC 50 (95% C.I.) = 310 (280-340) μg/L a

(nom) Highly toxic MRID 00162740 Acceptable

Chronic TGAI (88.4) Fathead minnow

( Pimephales promelas) NOEC = 16.5 μg a.i./L (mm)

LOEC = 39.5 μg a.i./L (mm) (based on reductions in parental and F 1 survival and growth) E000945 d
(MRID 00057846) Qualitative

Acute TGAI (99.8) Sheepshead minnow

(Cyprinodon variegatus) 96-hr LC 50 (95% C.I.) = 1926 (1816-2046) μg

a.i./L (im) Probit slope (95% C.I.) = 8.4 (6.8-10.0) 96-hr NOEC = 1000 μg a.i./L (im) NOEC based on 35% (7 out of 20) mortality at 1700 μg a.i./L Moderately toxic MRID 44806504 Acceptable

Acute TGAI (90) Water flea

(Daphnia magna) 48-hr EC 50 (95% C.I.) = 8400 (7060-9960) μg

a.i./L a (nom) Moderately Toxic MRID 00162739 Acceptable19

Study Type
TGAI/TEP (% a.i.) Species Toxicity Endpoints, Effects, and Acute Toxicity Classification (If Applicable) Source & Study
Classification

Acute TGAI (NS) Water flea

(Daphnia magna) 48-hr EC 50 > 7100 μg a.i./L (m)

No more than moderately toxic MRID 00070751 Supplemental (due to solubility issues & guideline deviations)

Acute TGAI (93.5) Water flea

(Daphnia magna) 48-hr EC 50 and NOEC: Could not be determined

due to unknown exposure concentrations 13.3% (4 out of 30) immobility at 1930 μg a.i./L (im) 23.3% (7 out of 30) immobility at 3250 μg a.i./L (im) MRID 43869807 Supplemental (due to uncertainty
associated with
measured
concentrations
which were below
the limit of
detection at test termination) Life cycle (chronic) TGAI (90) Water flea

(Daphnia magna) 21-day NOEC = 560 μg/L (nom)

21-day LOEC = 1000 μg/L (nom) (based on reductions in length and number of young) MRID 44148801 Supplemental (due to lack of
measured
concentrations
because of instability of test material in water; only the stock
concentration was measured)

Acute TGAI (91.3) Eastern oyster

( Crassostrea virginica ) 96-hr EC 50 (95% C.I.) = 3.3 (2.2-4.9) μg a.i./L

(mm) Probit slope = 9.12 96-hr NOEC = 1.1 μg a.i./L (mm) Very highly toxic MRID 46061701 Acceptable

Acute TGAI (99.8) Mysid shrimp

(Mysidopsis bahia) 96-hr LC 50 (95% C.I.) = 8435 (7160-1012) μg

a.i./L (im) Probit slope (95% C.I.) = 7.6 (3.8-11.3) 96-hr NOEC = 2800 μg a.i./L (im) NOEC based on 5% (1 out of 20) mortality at 5.1 mg a.i./L Moderately toxic MRID 44806505 Acceptable

Aquatic vascular plant TGAI (99.8) Duckweed

(Lemna gibba) 7 day EC 50 > 12700 μg a.i./L (im)

7-day NOEC = 443 μg a.i./L (im) (based on frond numbers) MRID 44806503 Acceptable

Aquatic nonvascular plant TGAI (92.7) Green alga

(Scenedesmus subspicatus) 96-hr EC 50 = 320 μg/L (nom)

NOEC: Could not be determined (based on cell density) MRID 00137688 Supplemental (due to lack of a
NOEC and data
for individual replicates)Aquatic nonvascular plant
Tier II TGAI (90) Green alga

( Selenastrum capricornutum ) 96-hr EC 50 (95% C.I.) = 1970 (1800-2160) μg

a.i./L (im) 96-hr NOEC = 200 μg a.i./L (im) (based on cell density) MRID 43869809 Acceptable20

Study Type
TGAI/TEP (% a.i.) Species Toxicity Endpoints, Effects, and Acute Toxicity Classification (If Applicable) Source & Study
Classification

Aquatic nonvascular plant Freshwater diatom No data

Aquatic nonvascular plant Tier II (99.8) Cyanobacterium

(Anabaena flosaqua ) 96-hr EC 50 (95% C.I.) = 994 (814-1120) μg a.i./L

(im)
96-hr EC 05 (95% C.I.) = 148 (NA-296) μg a.i./L (im) 96-hr NOEC < 234 μg a.i./L (im) (based on cell density) MRID 44806501 Acceptable

Aquatic nonvascular plant Tier II (99.8) Marine diatom

( Skeletonema

costatum ) 96-hr EC 50 (95% C.I.) = 169 (149-191) μg a.i./L

(im) 96-hr NOEC = 32.3 μg a.i./L (im) (based on cell density) MRID 44806502 Acceptable

Aquatic nonvascular plant Tier II (99.8) Marine algae c

,

most sensitive:
Skeletonema

costatum 48-hr EC 50 = 160 μg/L (nom) MRID 40228401 Supplemental (due to 48-hr exposure period) NA = not applicable; NS = not specified; C.I. = con fidence interval; nom = nominal concentration; im = initialmeasured concentration; mm = mean-measured concentr ation

a Not corrected for % a.i.

b Other species tested include: Channel catfish ( Ictalurus punctatus ); Chinook salmon ( Oncorhynchus tshawytscha ); Coho salmon ( Oncorhynchus kisutch ); Cutthroat trout ( Salmo clarki ); Fathead minnow ( Pimephales promelas) ; Lake trout ( Salvelinus fontinalis ); Rainbow trout ( Salmo gairdneri ); Yellow perch ( Perca flavescens ); Bluegill sunfish ( Lepomis macrochirus )

c Other species tested include: Isochrysis galbana

, Pavlova lutheri

, Pavlova gyrans , and Dunaliella tertiolecta

d identified via a query of the ECOTOXicology 10 database which is maintained by the U.S. EPA Offic e of Research and Development (ORD)

5.1.1 Changes to Toxicity Endpoints and Study Classificat ions

Raw data for several of the aquatic plant studies ( MRIDs 44806501, 44806502, 44806503) were re-analyzed because previous statistical comparison s were made using the solvent control instead of the negative control.

• Re-analysis of raw data for a study with Anabaena flos-aquae (MRID 44806501) yielded
a new EC 50 (994 μg a.i./L), confirmed the lack of a NOEC (< 2 34 μg a.i./L), and generated an EC 05 (148 μg a.i./L) in lieu of a NOEC; the study remai ned classified as Acceptable.

• Re-analysis of raw data for a study with Skeletonema costatum (MRID 44806502) yielded new endpoints (EC 50 = 169 μg a.i./L; NOEC = 32.3 μg a.i./L); the study remained classified as Acceptable.

• Re-analysis of the raw data for a study with Lemna gibba (MRID 44806503) yielded the same endpoints as previously determined; the study remained classified as Acceptable.

A NOEC could not be determined for a study with gre en alga Scenedesmus subspicatus (MRID 000137688) because data for treatment replicates wa s not provided. Therefore, the study classification was downgraded to Supplemental (from Acceptable).

10 http://cfpub.epa.gov/ecotox/21

The raw data for a study with green alga Selenastrum capricornutum (MRID 43869809) was reanalyzed because the previous EC 50 was determined using probit analysis rather than n on-linear Bruce and Versteeg analysis. This re-analysis yiel ded a new EC 50 endpoint (1970 μg a.i./L); the study remained classified as Acceptable.

In previous ecological risk assessments ( e.g. , 2004 RED; DP 318448+; 2007 CRLF litigation assessment; DP 400401), ECOTOX 11 open literature study E000945 (MRID 00057846) was referenced for characterizing the toxicity of capta n to freshwater fish from chronic exposure. A formal review of this study conducted in accordance with current guidelines for evaluating ecological toxicity data in the open literature 12 resulted in a study classification of qualitative for use in the Registration Review ecological risk asse ssment due to significant uncertainty associated with exposure concentrations which varie d greatly over the study.

5.2 Captan Degradates

Four major degradates of captan have been identifie d based on environmental fate studies: THPI, THPAm, THPAI and THCY. Studies characterizing the toxicity of THPI and THPAm to aquatic organisms are summarized in Table 5-2 . No toxicity data are available for degradates T HPAI and THCY. THPI and THPAm are several orders of mag nitude less toxic than parent captan to aquatic organisms. As a result, TPHI and THPAm wil l not be considered stressors of concern in the Registration Review ecological risk assessment. Since THPAI and THCY are major metabolites under anaerobic conditions, substantial amounts of these degradates are unlikely to
form in the aerobic environment due to terrestrial uses of captan. There are no aquatic uses of captan. Therefore, THPAI and THCY will not be consi dered stressors of concern in the Registration Review ecological risk assessment

The classification for the study with THPI and rain bow trout (MRID 43869806) was downgraded to Supplemental (from Acceptable) due a guideline deviation, i.e. , only 10 fish, rather than 30, were exposed at the limit concentra tion.

Table 5-2. Summary of the Endpoints from Toxicity Studies with Captan Degradates
THPI and THPAm
Study Type
TGAI/TEP (% a.i.) Species Toxicity Value, Effects, and Acute Toxicity Classification (If Applicable) Source and Status

THPI
Acute limit test (96) Rainbow trout

( Oncorhynchus mykiss ) 96-hr LC 50 > 120 mg a.i./L (mm)

96-hr NOEC = 120 mg a.i./L (mm) (no effects) Practically non-toxic MRID 43869806 Supplemental (due to only 10 fish not 30 being exposed at limit concentration)

THPAm
Acute limit test (95) Rainbow trout

( Oncorhynchus mykiss ) 96-hr LC 50 > 126 mg a.i./L (mm)

96-hr NOEC = 126 mg a.i./L (mm) (no effects) Practically non-toxic MRID 44738801 Supplemental (due to only 10 fish not 30 being exposed at limit concentration)

11 identified via a query of the ECOTOXicology 11 database ( http://cfpub.epa.gov/ecotox/ ) which is maintained by the U.S. EPA Office of Research and Development (OR D)

12 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_evaluation_open_literature.htm22

Study Type
TGAI/TEP (% a.i.) Species Toxicity Value, Effects, and Acute Toxicity Classification (If Applicable) Source and Status

THPI
Acute limit test (96) Water flea

( Daphnia magna ) 48-hr EC 50 > 113 mg a.i./L (mm)

48-hr NOEC = 113 mg a.i./L (mm) (no effects) Practically non-toxic MRID 43869808 Acceptable

THPIAquatic nonvascular plant Tier II (96) Green alga

( Selenastrum capricornutum ) 72-hr EC 50 > 181 mg a.i./L (mm)

72-hr NOEC = 181 mg a.i./L (mm) (no effects) MRID 43869810 Supplemental (due to test being terminated early when algal growth was still in the middle of the exponential phase of the growth curves)

mm = mean-measured concentration

5.3 Review of Incident Databases

Reviews on January 11, 2013 of the Ecological Incid ent Information System (EIIS, version 2.1.1), which is maintained by the Agency’s Office of Pesticide Programs, and the Avian Monitoring Information System (AIMS), which is main tained by the American Bird Conservatory, indicate a total of five reported eco logical incidents (in EIIS) associated with the use of captan. This total for captan excludes inci dents classified as ‘unlikely’ or ‘unrelated’ and only includes incidents with the certainty categori es of ‘possible’, ‘probable’, and ‘highly probable’ for EIIS.

One of the reported captan incidents involved aquat ic organisms and was a result of accidental misuse of the pesticide. Specifically, according t o the "Summary of Reported DDT, Endrin, and Methyl Parathion Episodes Involving Fish from 1967 to February, 1975", there was a large fish kill in the state of New York on May 24, 1972 (Inci dent B000-245-01). A spray rig being filled with thiodan and captan overflowed into a stream, r esulting in the death of 10,000 fish. The certainty index for this incident is ‘highly probab le’ because although no analytical data were included in the report, it is certain that spillage of captan concentrate into a stream would be
lethal to fish.

Two of the reported captan incidents involved terre strial organisms; the legality of the use for
both incidents is undetermined. In the first incid ent, an extension apiculturist from UC Davis wrote in a short paper titled "Honey Bees and Fungi cides" that California beekeepers documented a possible connection between brood prob lems of honey bees and crop diseasepreventing fungicides in 1967 (Incident I0020302-00 1). The beekeepers noticed substantial brood losses following application of captan in som e almond orchards in northern California. Similar reports in 1971 led to an investigation of dying larvae, pupae and emerging bees. This investigation found that many emerging adults were light in color and often had deformed wings and that up to 50% of the brood could be negatively affected by captan used at field doses. The certainty index for this incident is ‘probable.’

In the second terrestrial incident, an estimated 30 to 35 snow geese were found dead or dying in a field on the eastern shore of Virginia in Accomac k County on January 30, 1985. Necropsy of two of the birds showed aquatic vegetation in the d igestive tract, but there were no gross lesions or evidence of infectious diseases. Empty bags of Vitavax flowable fungicide were found in the23

nearby field. The certainty index for this inciden t is ‘probable’ because in the absence of analyses of tissue residues, it can only be surmise d that the birds died from ingestion of captan that once filled the bags found nearby.

Two of the reported captan incidents involved plant s; both were the result of accidental misuse of the pesticide. In the first incident, Gustafson LLC reported that a formulator erroneously added the antimicrobial tebuconazole to a 790 gallo n lot of the fungicide Rival (pentachloronitrobenzene [PCNB], thiabendazol, capt an) to create a formulation of an unregistered end-use product for soybean seed treat ment. About 403 gallons of this lot was sold to and used by 10 commercial seed treating companie s for soybeans. The material was used in IL, IN, OH, MI and LA. Gustafson was notified on M ay 21, 2004 of stunted soybean growth from treated seeds and instructed growers, via the associated seed treating companies, to destroy their crops (Incident I015152-001). The certainty index for this incident is ‘possible’ for all four listed pesticides. Whether or not an individual pe sticide or some combination of the pesticides caused the stunted growth could not be determined.

In the second plant incident, Zeneca reported a com plaint from a grower in North East, PA, that Abound (AI: azoxystrobin) had damaged his apples. In his deposition, the grower admitted to spraying grapes with parathion, captan, and Stop-It (a calcium supplement) prior to spraying the apples and may not have completely washed out the t ank before adding Abound. The worst damage occurred with the first tank full of pestici de suggesting that the pesticides used on the grapes were responsible for the damage. However, A bound is not registered for use on apples,
and the current label for Abound states: “Abound is extremely phytotoxic to certain apple
varieties. AVOID SPRAY DRIFT. Extreme care must be used to prevent injury to apple trees (and apple fruit). DO NOT spray Abound where spray drift may reach apple trees.” This label language suggests that Abound was responsible for t he damage. The certainty index for this incident is ‘possible’ for all of the involved pest icides. Whether or not an individual pesticide or some combination of the pesticides caused the damag e could not be determined.

In addition to the incidents recorded in EIIS and A IMS, additional incidents are reported to the Agency in aggregated form. Pesticide registrants r eport certain types of incidents to the Agency as aggregate counts of incidents occurring per prod uct per quarter. Ecological incidents reported in aggregate reports include those categorized as ‘ minor fish and wildlife’ (W-B), ‘minor plant’ (P-B), and ‘other non-target’ (ONT) incidents. ‘Ot her non-target’ incidents include reports of
adverse effects to insects and other terrestrial in vertebrates. For captan, registrants have reported no minor fish and wildlife incidents, 38 minor plan t incidents, and no other non-target incidents as of January 11, 2013. All of the minor incidents are associated with Ortho Home Orchard Spray (Reg No. 239-568).

The total number of actual incidents associated wit h the use of captan may be higher than what is reported to the Agency. Incidents may go unreporte d since effects may not be immediately apparent and/or readily attributed to the use of a chemical.24



### 6 Risk Hypothesis

The Registration Review ecological risk assessment will test the following risk hypothesis:

Based on the application methods, the assumed fate and transport, and the assumed sensitivity of non-target aquatic and terrestrial s pecies, captan has the potential to reduce survival, growth, and/or reproduction of non-target terrestrial and aquatic organisms. These non-target organisms include Federally-listed threa tened and endangered species as well as non-listed species.



### 7 Exposure Pathways of Concern

For terrestrial vertebrates, the major route of exp osure to captan is considered to be via dietary ingestion of food items such as seeds, plants, and/ or animals that have captan residues as a result of direct application, spray drift, and runoff. Exposure to captan through the consumption of drinking water alone is not considered a potential concern for birds and mammals based on the results of EFED’s Screening Imbibition Program (SIP v. 1.0) indicates ( Appendix B ). Exposure to terrestrial vertebrates through inhalation is co nsidered not likely significant given captan’s low vapor pressure and the results of EFED’s Screening Tool for Inhalation Risk (STIR v. 1.0) ( Appendix C ).

For terrestrial invertebrates, the major routes of exposure to captan are considered to be direct contact as a result of direct application and spray drift and dietary ingestion of plants, animals, and/or soil that have captan residues as a result o f direct application, spray drift, and runoff.

For aquatic animal species, the major route of expo sure to captan is considered to be uptake via the respiratory surface (gills) or the integument f rom surface water/sediment that has captan residues as a result of spray drift, runoff, and le aching to groundwater from soil.

For terrestrial (upland and semi-aquatic) non-targe t plants, the major routes of exposure to captan
are considered to be direct contact as a result of direct application and spray drift and root uptake via soil contaminated via spray drift and runoff.

For aquatic plants, the major routes of exposure to captan are considered to be uptake from surface water/sediment containing captan residues a s a result of spray drift, runoff, and leaching to groundwater from soil.



### 8 Analysis Plan

To address the risk hypothesis, the potential for a dverse effects on the environment will be estimated. Usage, environmental fate, and ecologic al effects of captan will be characterized and integrated to assess the risks. As outlined in the Overview Document (USEPA, 2004), the likelihood of effects to individual organisms from particular uses of a chemical is estimated25

using the probit dose-response slope and either the level of concern (LOC) or the actual calculated risk quotient value.

This analysis plan will be revisited and may be rev ised depending upon a full review of the data available in the open literature and the informatio n submitted by the public in response to the opening of the Registration Review docket.

8.1 Stressors of Concern

Toxicity data indicates that degradates TPHI and TP HAm are much less toxic to aquatic organisms than parent captan. Furthermore, environ mental fate data indicates that substantial amounts of degradates THPAI and THCY are unlikely t o form in environments where captan is used, i.e. , terrestrial aerobic environments. Therefore, onl y parent captan will be considered a stressor of concern in the Registration Review ecol ogical risk assessment.

8.2 Measures of Exposure

To estimate risks to aquatic and terrestrial organi sms from exposure to captan, all exposure modeling and resulting risk conclusions will be mad e based on maximum application rates, application methods, and any mitigation measures sp ecifically indicated on the label. Models that will be used to predict estimated environmenta l concentrations (EECs) of captan are discussed on OPP’s model website 13 . These models include: PRZM (P esticide R oot Z one M odel) and EXAMS (EX posure A nalysis M odeling S ystem), PRZM-groundwater (PRZM-GW), T-REX, and TerrPlant.

8.3 Measures of Effect

Ecological effects data are used as measures of dir ect and indirect effects to non-target organisms. Data are obtained from registrant-submi tted studies or from literature studies identified via a query of the ECOTOXicology databas e 14 which is maintained by the U.S. EPA Office of Research and Development (ORD). Informat ion on the potential effects of captan to non-target organisms is also collected from reviews of incidents associated with the use of captan (see Section 5.3 ).

Where available, sub-lethal effects observed in bot h registrant-submitted and open literature studies will be evaluated qualitatively. Such effe cts may include behavioral changes ( e.g. , lethargy and changes in coloration). Quantitative assessments of risks, though, are limited to those endpoints that can be directly linked to the Agency’s assessment endpoints of impaired survival, growth, and reproduction.

The assessment of risk for direct effects to non-ta rget organisms makes the assumption that toxicity of captan to birds is similar to terrestri al-phase amphibians and reptiles. The same assumption is made for fish and aquatic-phase amphi bians.

13 http://www.epa.gov/pesticides/science/models_db.htm

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

8.4 Integration of Exposure and Effects

Risk characterization is the integration of exposur e and ecological effect characterizations to determine the potential ecological risk from the us e of captan and the likelihood of direct and indirect effects to non-target organisms in aquatic and terrestrial habitats. The exposure and effects data are integrated to evaluate potential a dverse ecological effects on non-target species. For the captan ecological risk assessment, the risk quotient (RQ) method will be used to compare estimated exposure and measured toxicity values. A cute and chronic EECs will be divided by acute and chronic toxicity values. The resulting R Qs will then be compared to the Agency’s Levels of Concern (LOC) (USEPA, 2004). These crite ria are used to indicate when captan’s use, as directed on the labels, has the potential to cau se adverse direct or indirect effects to non-target organisms. In addition, incident data from EIIS, a ggregate incident reports, and AIMS will be considered as part of the risk characterization.

8.5 Drinking Water Assessment

A new drinking water assessment may be conducted if warranted to support future human health dietary risk assessments of captan and will conside r all currently registered uses. The new drinking water assessment will incorporate model es timates as well as available monitoring data of captan and any transformation products of toxico logical concern in surface water and groundwater that might be identified by the Health Effects Division (HED). The potential toxicity of captan and its transformation product T HPI will be considered in the drinking water assessment conducted during the Registration Review process. Any additional determination of the residues of concern in the drinking water asses sment will be made through consultation with HED and through any proceedings of the ROCKS (Resid ues of Concern Knowledge Subcommittee).

8.6 Endangered Species Assessments

Consistent with the Agency’s responsibility under t he Endangered Species Act (ESA), the Agency will evaluate risks to Federally-listed thre atened and/or endangered (listed) species from registered uses of captan. 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/NMFS, 1998).

The assessment of effects associated with the regis tration of captan is based on an action area.
The action area is considered to be the area direct ly or indirectly affected by the federal action, as indicated by the exceedance of Agency Levels of Con cern (LOCs) used to evaluate direct or indirect effects. The Agency’s approach to definin g the action area under the provisions of the Overview Document (USEPA, 2004) considers the resul ts of the risk assessment process to
establish boundaries for that action area with the understanding that exposures below the Agency’s defined LOCs constitute a no-effect thresh old. For the purposes of this assessment, attention will be focused on the footprint of the a ction ( i.e ., the area where captan application occurs), plus all areas where offsite transport ( i.e ., spray drift, runoff, etc .) may result in potential exposure that exceeds the Agency’s LOCs. Specific measures of ecological effect that define the action area for listed species include any direct a nd indirect effects and/or potential modification of its critical habitat, including reduction in sur vival, growth, and reproduction as well as the full27

suite of sub-lethal effects available in the effect s literature. Therefore, the action area extends t o a point where environmental exposures are below any measured lethal or sub-lethal effect threshold for any biological entity at the whole or ganism, organ, tissue, and cellular level of organization. In situations where it is not possib le to determine the threshold for an observed effect, the action area will be assumed to encompas s the entire United States.

8.7 Endocrine Disruptor Screening Program

As required by FIFRA and FFDCA, EPA reviews numerou s studies to assess potential adverse outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and chronic toxicity, including assessments of carcinog enicity, neurotoxicity, developmental, reproductive, and general or systemic toxicity. The se studies include endpoints which may be susceptible to endocrine influence, including effec ts 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 a nd reproductive effects in different taxonomic groups. As part of the most recent regis tration decision, 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 sec tion 408(p), captan is subject to the endocrine screening part of the Endocrine Disruptor Screening Program (EDSP).

EPA has developed the EDSP to determine whether cer tain 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 oth er such endocrine effects as the Administrator may designate.” The EDSP employs a two-tiered appr oach 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, a ndrogen, or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screenin g and are found to have the potential to interact with E, A, or T hormonal systems will proc eed to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests a re necessary based on the available data. Tier 2 testing is designed to identify any adverse endocri ne-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 ord ers/data call-ins for the first group of 67 chemicals, which contains 58 pesticide active ingre dients and 9 inert ingredients. Captan is among the group of 58 pesticide active ingredients on the initial list to be screened under the EDSP. For additional information on the EDSP progr am, visit http://www.epa.gov/endo/

.



### 9 Data Gaps

The following two sections identify environmental f ate and effects data that are needed to complete an environmental fate and ecological risk assessment in support of the Registration Review of the registered uses of captan.28

Submission of data to eliminate data gaps would red uce uncertainties in the ecological risk assessment. Data gaps have been assigned either a low or high potential to add value to the Registration Review ecological risk assessment. Wh ile still considered data gaps according to 40 CFR Part 158, data from low potential studies are u nlikely to change risk conclusions, and alternate methods and weight of evidence can be use d in the absence of data. In contrast, data from high potential studies are likely to impact ri sk conclusions and allow the Agency to be better able to characterize potential risks by elim inating uncertainties for both non-listed and listed species that cannot be accounted for using a lternate methods or weight of evidence.

9.1 Environmental Fate Data

Table 9-1 provides environmental fate studies by MRID that of fer data for each guideline requirement as well as study classifications and wh ether or not further data are needed to support the Registration Review ecological risk assessment ( i.e. , whether there is a data gap). The fate database for captan is adequate for exposure assess ment. Additional data as noted in Table 9-1 will reduce uncertainty related to the exposure ass essment.

Table 9-1. Registrant-Submitted Fate Data for Capt an and Remaining Data Gaps

Guideline Description MRID/
Source Classification Data Gap?

835.2120
161-1 Hydrolysis 41176301
40208101
00096974 Acceptable No

835.2240
161-2 Photodegradation in water 40208102 Acceptable No

835.2410
161-3 Photodegradation in soil 40658009 Acceptable No

835.4100
162-1 Aerobic

soil metabolism 00070414
40658007 Acceptable Yes. Partially fulfilled
Two aerobic soil metabolism studies are acceptable for risk assessment. Additional data are required under 40
CFR Part 158 for terrestrial outdoor uses. OCSPP guidance recommends that these tests be performed with
four soils. Because OCSPP uses an upper 90 th percentile estimate of soil
metabolism half-lives based on available study data for modeling purposes, any additional data can reduce uncertainty related to the exposure assessment as well as the half-life value used in modeling.
Additional data are considered to
have a high potential to add value to the ecological risk and drinking water

assessments.29

Guideline Description MRID/
Source Classification Data Gap?

835.4200
162-2 Anaerobic

soil metabolism 00098881
40658008 Supplemental Yes. Partially fulfilled
Two anaerobic soil metabolism studies are acceptable for risk
assessment. Additional data are required under 40 CFR Part 158 for
terrestrial outdoor uses. OCSPP guidance recommends that these tests be performed with four soils. Because OCSPP uses an upper 90 th percentile estimate of soil metabolism half-lives based on available study data for modeling purposes, any additional data can reduce uncertainty related to the exposure assessment as
well as the half-life value used in modeling Additional data are
considered to have a high potential to add value to the ecological risk and drinking water assessments.

835.4300
162-4 Aerobic aquatic

metabolism 00096974
40114502
43868905 Acceptable No

835.4400
162-3 Anaerobic aquatic

metabolism No data --- Yes. Data are required under 40 CFR Part 158. OCSPP guidance
recommends that these tests be performed with two sediments. In absence of anaerobic aquatic metabolism data, anaerobic soil
metabolism data will be used in exposure modeling purposes.
Additional data are considered to
have a high potential to add value to the ecological risk and drinking water

assessments.

835.1230
835.1240
163-1 Leaching-adsorption/

desorption 00096972
40658001 Acceptable No

835.6100
164-1 Terrestrial

field dissipation 40823901
40893601
40893602
40893603
40932201
40932202 Supplemental No

850.6100 Analytical method - Soil 40823901 Acceptab le No30

Guideline Description MRID/
Source Classification Data Gap?

850.6100

Analytical method - Water No data --- Yes. Environmental chemistry method (ECM) and independent laboratory validation method (ILV) for water are required to support monitoring for captan residues and to
evaluate submitted environmental fate and ecological effects data.

850.1730
165-4 Accumulation in fish 40756601
40756602 Acceptable No

9.1.1 Environmental Fate Data for Degradate, THPI

There are limited registrant-submitted environmenta l fate data available for THPI ( Table 4-2 ). Several key environmental fate data ( i.e. , hydrolysis [OCSPP 835-2120], aquatic photolysis [OCSPP 835-2240], and anaerobic aquatic metabolism [OCSPP 835-4400]) are not available for the aquatic exposure assessment. The registrant an d/or public are welcome to submit additional information that would provide THPI's environmental fate properties. In the absence of these data, conservative assumptions will be made about t he fate properties for THPI, including the use of predictive models to generate appropriate data. The Agency would be interested in any public perspective regarding the availability of environme ntal fate data.

9.2 Ecological Effects Data

Table 9-2 provides ecological effects studies by MRID that of fer data for each guideline requirement as well as study classifications and wh ether or not further data are needed to support the Registration Review ecological risk assessment ( i.e. , whether there is a data gap).

Table 9-2. Ecological Effects Data for Captan and Remaining Data Gaps

Guideline Description MRID/
Source Classification Data Gap?

850.1010 Acute toxicity

freshwater
invertebrates 00070751

00162739
43869807 Supplemental

Acceptable Supplemental No

850.1025
850.1055 Acute toxicity

estuarine/marine
mollusk 46061701 Acceptable No

850.1035
850.1045 Acute toxicity

estuarine/marine
invertebrate 44806505 Acceptable No

850.1075 Acute toxicity

freshwater fish (cold water species) 40098001 Supplemental Yes. Acceptable acute toxicity data are not available for a cold water species. However, data from repeating this study are considered
to have a low potential to add value to the ecological risk assessment.31

Guideline Description MRID/
Source Classification Data Gap?

Acute toxicity
freshwater fish (warm water species) 00162740

40098001 Acceptable

Supplemental No

Acute toxicity
estuarine/marine fish 44806504 Acceptable No

850.1300 Aquatic invertebrate

life cycle (freshwater) 44148801 Supplemental Yes. Acceptable chronic toxicity data are not available for a freshwater aquatic invertebrate. However, data from repeating this study are considered to have a low potential to add value to the ecological risk

assessment.

850.1350 Aquatic invertebrate

life cycle (saltwater) No data -- Yes. Aquatic invertebrate life cycle toxicity
data for an estuarine/marine invertebrate are required under 40 CFR Part 158 if the product is expected to enter the environment in significant concentrations because of its expected use or mobility patterns. However, data for this guideline requirement are
considered to have a low potential to add value to the ecological risk assessment.

850.1400 Fish early life stage

(freshwater) 00057846

(E000945 a ) Qualitative Yes. Acceptable early life stage toxicity data
are not available for a freshwater fish. However, data from repeating this study are
considered to have a low potential to add value to the ecological risk assessment.

Fish early life-stage (saltwater) No data -- Yes. Early-life stage toxicity data for an estuarine/marine fish are required under 40 CFR Part 158 if the product is expected to enter the environment in significant concentrations because of its expected use or mobility patterns. However, data for this guideline requirement are considered to have

a low potential to add value to the ecological
risk assessment.

850.2100 Avian oral toxicity

(upland game or waterfowl species) 00151236

00160000 Acceptable

Supplemental No. However, based on guidance for using

non-definitive endpoints 15 , requesting additional toxicity data is recommended (see discussion below) and considered to have a high potential to add value to the ecological
risk assessment.

Avian oral toxicity (passerine species) No data -- Yes. Avian acute oral toxicity data for a passerine species are required under the new 40 CFR Part 158. Data for this guideline requirement are considered to have a high potential to add value to the ecological risk

assessment.

15 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_non_definitive_endpoints.htm32

Guideline Description MRID/
Source Classification Data Gap?

850.2200 Avian dietary toxicity

(upland game species) 00022923

43869802 Supplemental

Acceptable No. However, based on guidance for using

non-definitive endpoints 9 , requesting additional toxicity data is recommended (see discussion below) and considered to have a high potential to add value to the ecological
risk assessment. Avian dietary toxicity (waterfowl species) 00022923

43869803 Supplemental

Acceptable

850.2300 Avian reproduction

(upland game species) 00098295 Acceptable No

Avian reproduction (waterfowl species) 00098296 Acceptable No

850.3020 Honeybee acute

contact toxicity E087252 a

00080871 Quantitative

Acceptable No. However, based on a documented honey

bee incident involving the use of captan and the “White Paper in Support of the Proposed
Risk Assessment Process for Bees” as submitted to the FIFRA Scientific Advisory Panel, data from the following non-guideline honey bee toxicity studies are recommended for request and considered to have a high potential to add value to the ecological risk

assessment:

• (adult) honey bee acute oral toxicity
test and

• larval honey bee acute oral toxicity

test.

850.4100 Seedling emergence

(terrestrial plants) No data -- Yes. Data for terrestrial plant species are required under 40 CFR Part 158. Data for this guideline requirement are considered to
have a high potential to add value to the ecological risk assessment. 850.4150 Vegetative vigor

(terrestrial plants) No data --

850.4400 Aquatic plant growth

(aquatic vascular plant toxicity) 44806503 Acceptable No

850.4500 Aquatic plant growth

(aquatic non-vascular plant: algal toxicity) Green alga:

00137688
43869809 Supplemental

Acceptable No

Freshwater
diatom:
No data -- Yes. Data for aquatic non-vascular plant species including a freshwater diatom are required under 40 CFR Part 158. Data for this guideline requirement are considered to
have a high potential to add value to the ecological risk assessment.

Marine
diatom:
40228401
44806502 Supplemental

Acceptable No

850.4550 Aquatic plant growth

(aquatic non-vascular plant: cyanobacteria toxicity) 44806501 Acceptable No33

FW = freshwater; SW = saltwater

a identified via a query of the ECOTOXicology 16 database which is maintained by the U.S. EPA Offic e of Research and Development (ORD)

Data from the following studies are considered to h ave high potential to add value to the ecological risk assessment for captan:

Guideline 850.2100 – Avian Acute Oral Toxicity Test , upland game: The avian endpoints for acute oral toxicity are non-definitive ( i.e. , LD 50 > highest dose tested). The highest concentrations tested, 2150 and 2000 mg/kg-bw for b obwhite quail and mallard duck, respectively (MRIDs 00151236 and 00160000), are les s than the highest avian EECs calculated in the most recent assessments ( i.e ., 4968 mg/kg-bw in the 2007 CRLF litigation assess ment; 6107 mg/kg-bw in the 2012 Section 24(c) SLN assessm ent, DP 400401), and sublethal effects including weight loss, ataxia, and tremors were not ed in the studies. Based on guidance for using non-definitive endpoints 17 , requesting additional data is recommended and con sidered to have a high potential to add value to the Registrat ion Review ecological risk assessment.

Guideline 850.2100 – Avian Acute Oral Toxicity Test , passerine species: Acute oral toxicity data for a passerine species are required under the new 40 CFR Part 158. No studies have been submitted for this data requirement. Given the con cerns identified for existing toxicity data for upland game and waterfowl species and the need to b e protective of passerine species, fulfilling this data requirement has a high potential to add v alue to the Registration Review ecological risk assessment. In the absence of these data, passerin e toxicity data for surrogate pesticides – starting with data for surrogate chemicals ( e.g. , folpet) and proceeding to data for less related chemicals – may be used to characterize the toxicit y of captan to passerine species.

Guideline 850.2200 – Avian Dietary Toxicity Test, u pland game and waterfowl species: The avian endpoints for sub-acute dietary toxicity are non-definitive ( i.e. , LC 50 > highest concentration tested). The highest concentration t ested, 4680 mg/kg-diet (if corrected for % a.i.) for both bobwhite quail and mallard duck (MRIDs 438 69802 and 43869803) is greater than the highest avian EEC of 4362 mg/kg-diet calculated in the 2007 CRLF litigation assessment, but less than the highest avian EEC of 5112 mg/kg-diet calculated in the 2012 Section 24(c) SLN assessment (DP 400401). Furthermore, there was 30% (3 out of 10) mortality in the 5200 mg/kg-diet treatment group in the bobwhite quail st udy, and frank sublethal effects including reduced body weight gain were noted at ≥ 2600 mg/kg-diet for both species. Based on guidan ce for using non-definitive endpoints 18 , requesting additional data is recommended and con sidered to have a high potential to add value to the Regist ration Review ecological risk assessment.

Guideline 850.4100 – Seedling Emergence and Seedlin g Growth & Guideline 850.4150 – Vegetative Vigor: Data for terrestrial plant species are required un der 40 CFR Part 158. Open

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

17 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_non_definitive_endpoints.htm

18 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_non_definitive_endpoints.htm34

literature studies indicate that applications of ca ptan as low as 2.5 lb a.i./A could affect dicots (2007 CRLF litigation assessment; DP 400401). In a ddition, incidents associated with the use of captan and involving plants have been reported (see Section 5.3 ). Therefore, effects to terrestrial plants from use of captan cannot be discounted, and data from terrestrial plant studies are considered to have a high potential to add value to the Registration Review ecological risk assessment. In the absence of these data, terrestr ial plant toxicity data for surrogate pesticides – starting with data for surrogate chemicals ( e.g. , folpet) and proceeding to data for less related chemicals – may be used to characterize the toxicit y of captan to terrestrial plants.

Guideline 850.4500 – Algal Toxicity, freshwater dia tom: Data for aquatic non-vascular plant species including a freshwater diatom are required under 40 CFR Part 158. No data has been submitted for this data requirement. Results of aq uatic non-vascular plant toxicity studies with folpet, a phthalimide fungicide that is a structura l analogue of captan, show a freshwater diatom to be the most sensitive species tested. For folpe t, a comparison of EC 50 ’s for the tested species yields the following order of sensitivities (most t o least sensitive): freshwater diatom (EC 50 /NOEC = 50/30 μg a.i./L; MRID 45784605) > marine di atom (EC 50 /NOEC = 220/41 μg a.i./L; MRID 45784607) > cyanobacterium (EC 50 /NOEC = 1100/350 μg a.i./L; MRID 45784606) > green alga (EC 50 /NOEC = 1800/480 μg a.i./L; MRID 45784604). This o rder of sensitivities for folpet matches that for captan wi th respect to available data: marine diatom (EC 50 /NOEC = 169/32.3 μg a.i./L; MRID 44806502) > cyanob acterium (EC 50 /NOEC = 995/<234 μg a.i./L; MRID 44806501) > green alga (EC 50 /NOEC = 1972/200 μg a.i./L; MRID 43869809). Therefore, freshwater diatoms are likel y to be the most sensitive aquatic nonvascular plant species for captan. The freshwater diatom endpoints for folpet are (EC 50 /NOEC = 50/30 μg a.i./L) are close to the highest peak EEC of 21.6 μg/L calculated in the 2007 CRLF litigation assessment and less than the highest pea k EEC of 91.3 calculated for the 2012 Section 24(c) SLN assessment (DP 400401). Data for a fresh water diatom exposed to captan could impact risk conclusions and are considered to have a high potential to add value to the Registration Review ecological risk assessment. In the absence of these data, data for a freshwater diatom exposed to folpet may be used to characterize toxicity of captan to freshwater
diatoms.

Non-Guideline Studies – Adult and Larval Honey Bee Acute Oral Toxicity Tests: A honey bee incident involving brood losses and the use of captan has been reported. In addition, the “White Paper in Support of the Proposed Risk Assess ment Process for Bees” as submitted to the FIFRA Scientific Advisory Panel 19 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. Adult honey bee acute contact toxicit y data are available for captan. However, adult and larval honey bee acute oral toxicity data are n ot. Therefore, data from the following nonguideline honey bee toxicity studies are recommende d for request and considered to have a high potential to add value to the Registration Review e cological risk assessment:

• (adult) honey bee acute oral toxicity test and

• larval honey bee acute oral toxicity test.

Data from the following studies are considered to h ave low potential to add value to the ecological risk assessment for captan:

19 http://www.regulations.gov/#!documentDetail;D=EPA-H Q-OPP-2012-0543-000435

Guideline 850.1075 – Fish Acute Toxicity Test, cold water species: Acceptable acute toxicity data is not available for a cold water species. A study with brown trout ( Salmo trutta ) is classified as Supplemental due to a guideline devia tion, i.e. , there was only one replicate per treatment concentration (MRID 40098001). Repeating this study has a low potential to add value to the Registration Review ecological risk as sessment. In the absence of these data, the existing endpoint for brown trout may be used to ch aracterize the toxicity of captan to freshwater fish from acute exposure.

Guideline 850.1300 – Daphnid Chronic Toxicity Test: Acceptable chronic toxicity data is not available for a freshwater aquatic invertebrate. A study with Daphnia magna is classified as Supplemental due to the lack of measured concentrat ions; only the stock concentration was measured (MRID 44148801). Repeating this study has a low potential to add value to the Registration Review ecological risk assessment. In the absence of these data, the existing endpoint for Daphnia may be used to characterize the toxicity of captan to freshwater aquatic invertebrates from acute exposure.

Guideline 850.1350 – Mysid Chronic Toxicity Test: Aquatic invertebrate life cycle toxicity data for an estuarine/marine invertebrate are requi red under 40 CFR Part 158 if the product is expected to enter the environment in significant co ncentrations because of its expected use or mobility patterns. No studies have been submitted for this data requirement. Given that there is
no evidence to indicate that estuarine/marine anima ls are substantially more sensitive to captan than freshwater animals, fulfilling this data requi rement has a low potential to add value to the Registration Review ecological risk assessment. In the absence of these data, toxicity to estuarine/marine invertebrates from chronic exposur e to captan may be characterized by applying an acute to chronic ratio (ACR) generated from toxicity data for Daphnia to the acute toxicity endpoint for mysid shrimp.

Guideline 850.1400 – Fish Early Life Stage Toxicity Test, freshwater: Acceptable early life stage toxicity data are not available for a freshwa ter fish. In previous ecological risk assessments ( e.g. , 2004 RED; DP 318448+; 2007 CRLF litigation assess ment; DP 400401), ECOTOX open literature study E000945 (MRID 00057846) was refere nced for characterizing the toxicity of captan to freshwater fish from chronic exposure. A formal review of this study conducted in accordance with current guidelines for evaluating e cological toxicity data in the open literature 20
resulted in a study classification of qualitative f or use in the Registration Review ecological risk assessment due to significant uncertainty associate d with exposure concentrations which varied greatly over the study. Since repeating this study is likely to yield the same uncertainty with respect to exposure concentrations, fulfilling this data requirement has a low potential to add value to the Registration Review ecological risk as sessment.

An acceptable early life stage toxicity test with f olpet, a phthalimide fungicide that is a structural analogue of captan, yielded a NOEC and LOEC of 8.8 μg a.i./L and 17.7 μg a.i./L, respectively, based on reductions in growth of fathead minnow (MR ID 43786301). So in the absence of these

20 http://www.epa.gov/pesticides/science/efed/policy_g uidance/team_authors/endangered_species_reregistrat ion_work group/esa_evaluation_open_literature.htm36

data, toxicity to freshwater fish from chronic expo sure to captan may be characterized by applying an acute to chronic ratio (ACR) generated from toxicity data for freshwater fish exposed to folpet to the most sensitive acute toxic ity endpoint for freshwater fish exposed to
captan.

Guideline 850.1400 – Fish Early Life Stage Toxicity Test, estuarine/marine: Early life stage toxicity data for an estuarine/marine fish are requ ired under 40 CFR Part 158 if the product is expected to enter the environment in significant co ncentrations because of its expected use or mobility patterns. No studies have been submitted for this data requirement. Given that there is
no evidence to indicate that estuarine/marine anima ls are substantially more sensitive to captan than freshwater animals, fulfilling this data requi rement has a low potential to add value to the Registration Review ecological risk assessment. In the absence of these data, toxicity to estuarine/marine fish from chronic exposure to capt an may be characterized using toxicity data
for freshwater fish.



### 10 References

DP 207651, 222887. EFED's Reregistration Eligibili ty Decision Chapter for Captan (Chemical #081301, DP Barcodes D207651, D222887) including Da ta Evaluation report. U.S. Environmental Protection Agency, Office of Preventi on, Pesticides and Toxic Substances, Office of Pesticide Programs, Washington D.C. July 10, 1997.

DP 318448, 318449, 318450, 318451, and 318452. IR- 4-Local Registration for Captan Use on Ginseng (PC Code 081301; CAS Number 133-06-2). Mar ch 2, 2006.

DP 400401. Ecological Risk Assessment in Response to the Section 24(c) Special Local Need for the Use of Captan on Strawberries in Florida. May 16, 2012.

E000945 (MRID 00057846). Hermanutz, R.O., Mueller, L.H., Kemper, K.D. 1973. Effects Captan toxicity to fathead minnows ( Pimephales promelas ), bluegills ( Lepomis
macrochirus ), and brook trout ( Salvelinus fontinalis ). J. Fish. Res. Board. Can. 30: 1811-
1817.

E087252. Ladurner, E., Bosch, J., Kemp, W. P., and Maini, S. 2005. Assessing delayed and acute toxicity of five formulated fungicides to Osmia lignaria Say and Apis mellifera

. Apidologie 36: 449-460.

Food and Agricultural Organization of the United Na tions (FAO). 2000. FAO Pesticide Disposal Series 8. Assessing soil contamination: A Reference Manual. Appendix 2. FAO
Information Division: Rome. http://www.fao.org/docrep/003/X2570E/X2570E00.HTM

USEPA. 2004. Overview of the Ecological Risk Asse ssment Process in the Office of Pesticide Programs. U.S. Environmental Protection Agency, Of fice of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, Was hington D.C. January 23, 2004.37

U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS). 1998. Endangered Species Consultation Handbook: Procedur es for Conducting Consultation and Conference Activities Under Section 7 of the Endang ered Species Act. Final Draft. March
1998.



### 11 Bibliography of Cited MRIDs

Environmental Fate Studies

48112502 Byrd, C. (2010) Captan Technical- Product Identity and Composition, Description

of Beginning Materials, Manufacturing Process, and Discussion of Formation of Impurities. Unpublished study prepared by RedEagle International, LLC. 63 p.

48112504 Sun, G. (2010) Captan Technical Grade Acti ve Ingredient Physical and Chemical

Characteristics: Final Report. Project Number: 01/1 5419/01/002, GLP/SP/082. Unpublished study prepared by Southwest Research In stitute. 25 p.

00070414 Pack, D.E. (1974) The soil metabolism of c arnoyl-14-c-captan. File No 773.2.

Unpublished study prepared by Chevron Chemical Co. 49 p.

00096972 Pack, D.E. (1977) Soil Mobility of Captan, Folpet and Captafol As Determined by

Soil Thin-layer Chromatography: File No. 722.0. (Un published study received May 30, 1978 under 239-2211; sub- mitted by Chevron Chemical Co., Richmond, Calif.; CDL:234046-N)

00096974 Wolfe, N.L.; Zepp, R.G.; Doster, J.C.; et al. (1976) Captan hydrolysis. Journal of

Agricultural and Food Chemistry 24(5):1041- 1045. ( Also~In~unpublished submission received May 30, 1978 under 239-2211; su bmitted by Chevron Chemical Co., Richmond, Calif.; CDL:234046-R)

00098881 Pack, D.E. (1979) The Anaerobic Soil Metab olism of Carbonyl-^14IC|captan:

File No. 721.14. (Unpublished study received Aug 27 , 1979 under 239-2457; submitted by Chevron Chemical Co., Richmond, Calif. ; CDL:240891-B)

40208101 Pack, D. (1987) [Trichloromethyl-[Carbon-1 4]] Captan Hydrolysis Products:

Laboratory Project ID: MEF-0002, 8702383. Unpublish ed study prepared by Chevron Chemical Co. 28 p

40231001 Pack, D. (1987) Captan Volatility from Soi l--Laboratory Study: Laboratory

Project ID: MEF-0027; 8704537. Unpublished study pr epared by Chevron Chemical Co. 13 p.

40208102 Pack, D. (1986) Photolysis of Captan in St erile Aqueous Solution: Laboratory

Project ID: MEF-0001. Unpublished study prepared by Chevron Chemical Co. 13

p.38

40658007 Pack, D.; Verrips, I. (1988) Aerobic Soil Metabolism of Trichloro-methyl-Carbon

14||Captan: Laboratory Project ID: MEF-0060/ 880988 7. Unpublished study prepared by Chevron Chemical Co. 49 p.

40658008 Pack, D.; Verrips, I. (1988) Anaerobic Soi l Metabolism of Tri- chloromethylCarbon 14||Captan: Laboratory Project ID: MEF- 0061 /8809887. Unpublished study prepared by Chevron Chemical Co. 39 p.

40658009 Ruzo, L. (1988) Soil Surface Photolysis of Carbon 14-Trichloro- methyl| Captan in Natural Sunlight: Laboratory Project ID: 231. Un published study prepared by Pharmacology and Toxicology Re- search Laboratory. 117 p.

40658010 Ruzo, L. (1988) Soil Surface Photolysis of Carbon 14| Captan in Natural Sunlight: Laboratory Project ID: 232. Unpublished study prepa red by Pharmacology and Toxicology Research Laboratory. 109 p.

40658011 Pack, D. (1987) Estimation of Soil Adsorpt ion Coefficient of Captan from TLC

Data: Laboratory Project ID: MEF-0073/8726836. Unpu blished study prepared by Chevron Chemical Co. 39 p.

40756601 Surprenant, D. (1988) Bioconcentration and Elimination of Carbon 14|-residues

by Bluegill ( Lepomis macrochirus ) exposed to Cyclohexane Carbon 14|-Captan: T-13068: Final Report: SLS Report #87-11-2558: Stud y #723.0387.6109.140/240. Unpublished study prepared by Springborn Life Sciences, Inc. 67 p.

40756602 Surprenant, D. (1988) Bioconcentration and Elimination of Carbon 14|-residues

by Bluegill (Lepomis macrochirus) exposed to Trichl oromethyl Carbon 14|- Captan: T-13069: Final Report: SLS Report #87-12-25 74: Study #723.0387.6108.140/240. Unpublished study prepared by Springborn Life Sciences, Inc. 70 p.

40823901 Jones, P. (1988) Captan 50-WP Field Dissip ation Study on California

Strawberries: Project ID PAL-EF-87-17F. Unpublished study prepared by Morse Laboratories, Inc. in association with Pan-Agricult ural Laboratories, Inc. 199 p.

40893601 Jones, P. (1988) Captan 50-WP Field Dissip ation Study on Oregon Grapes:

Project ID: PAL-EF-87-17D. Unpublished study prepar ed by Morse Laboratories, Inc. 216 p.

40893602 Jones, P. (1988) Captan 50-WP Field Dissip ation Study on Florida Tomatoes:

Project ID: PAL-EF-87-17C. Unpublished study prepar ed by Morse Laboratories, Inc. 184 p39

40893603 Jones, P. (1988) Captan 50-WP Field Dissip ation Study on California Tomatoes:

Project ID: PAL-EF-87-17E. Unpublished study prepar ed by Morse Laboratories, Inc. 170 p.

40932201 Jones, P. (1988) Captan 50-WP Field Dissip ation Study on New York Apples:

Proj. I.D. PAL-EF-87-17A. Unpublished study prepare d by Morse Laboratories, Inc. 209 p

40932202 Jones, P. (1988) Captan 50-WP Field Dissip ation Study on Texas Cantaloupes:

Proj. I.D. PAL-EF-87-17B. Unpublished study pre- pa red by Morse Laboratories, Inc. 185 p.

41176301 Lee, K. (1989) Trichloromethyl-carbon 14| Captan--Hydrolysis at 25(degree)C:

Project ID: Report No. WRC 89-44; Study No. ENV-011 . Unpublished study prepared by ICI Americas Inc. 37 p.

43868905 Travis, J.S. and N.D. Simmons (1993). Capt an: Degradation in sediment-water

systems under laboratory conditions. Laboratory Pro ject ID 92JH101. Unpublished study prepared by ICI Agrochemicals, Je alott's Hill Research Station. 53p. Not listed in fate bibliography.

43869811 Rowe, D.; Lane, M. (1993) Captan: Adsorpti on and Desorption Properties of Soil

Metabolites THPI and THPAM: Lab Project Number: RJ1 448B: 92JH086. Unpublished study prepared by ICI Agrochemicals, Je alott's Hill Research Station. 100 p.

Ecological Effects Studies

00022923 Hill, E.F., R.G. Heath, J.W. Spann, et al. (1975) Lethal Dietary Toxicities of

Environmental Pollutants to Birds: Special Scientif ic Report – Wildlife No. 191. (U.S. Dept. of the Interior, Fish and Wildlife Serv ice, Patuxent Wildlife Research Center; Unpublished Report.)

00070751 Boudreau, P.; Forbis, A.D.; Cranor, W.; et al. (1980) Static Acute Toxicity of

Captan Technical (SX-1086) to Daphnia magna : ABC Report # 26633. (Unpublished study received Jan 12, 1981 under 239- 1246; prepared by Analytical Bio Chemistry Laboratories, Inc., submit ted by Chevron Chemical Co., Richmond, Calif.; CDL: 244428-A)

00080871 Atkins, E.L., E.A. Greywood, R.L. Macdonal d (1972) Effect of Pesticides on

Apiculture: Project No. 1499. 1972 Annual Report. ( Unpublished Study Received Jan. 24, 1974 under 4F1459; Prepared by Univ. of Ca lifornia – Riverdale, Dept. of Entomology, Div. of Economic Entomology, Submitted by Nor-Am Agricultural Products, Inc., Naperville, Ill.; CDL: 093885-A)

00098295 Chevron Chemical Company (1980) One Genera tion Reproduction Studies with

Captan (SX-1086)|. (Compilation; unpublished study received Apr 5, 1982 under40 239-1246; CDL:247147-C)

00098296 Chevron Chemical Company (1980) Captan (SX -1086)/One Generation

Reproduction Studies, Including Diet Analyses|. Inc ludes method dated Jun 15, 1979. (Compilation; unpublished study received Apr 5, 1982 under 239-1246; CDL:247147-D)

00137688 Dickhaus, S.; Heisler, E. (1983) Algal Gro wth Inhibition Test with Captan:

E.H./P. 1-8-150-83. (Unpublished study received Feb 22, 1984 under 11678-1; prepared by Pharmatox Forschung und Beratung GmbH, W. Ger., submitted by Makhteshim Beer Sheva Chemical Works Ltd., New York , NY; CDL:252586-A)

00151236 Beavers, J. (1978) Acute Oral LD50 - Bobwh ite Quail: Orthocide Technical: Final

Report: Project No. 162-102. Unpublished study prep ared by Wildlife International, Inc. 15 p.

00160000 Hudson, R.H., R.K. Tucker, M.A. Haegele (1 984) Handbook of Toxicity of

Pesticides to Wildlife. USDI. Pb. 153, Washington, DC.

00162739 Palmateer, S. (1979) Biological Report of Analysis: [Toxicity Test of Captan on

Daphnia magna ]. Unpublished study prepared by U.S. Environmental Protection Agency, Terrestrial & Aquatic Biology Laboratory. 1 p. with technical

00162740 Palmateer, S. (1979) Biological Report of Analysis: [Toxicity Test of Captan on

Bluegills]. Unpublished study prepared by U.S. Envi ronmental Protection Agency, Terrestrial & Aquatic Biology Laboratory. 1 p.

40098001 Mayer, F.; Ellersieck, M. (1986) Manual of Acute Toxicity: Interpretation and Data Base for 410 Chemicals and 66 Species of Fresh water Animals. US Fish & Wildlife Service, Resource Publication 160. 579 p.

40228401 Mayer, F.L. 1986. USEPA Gulfbreeze Labo ratory Test Results

With 5 species of Marine algae

43869802 Hakin, B.; Johnson, A.; Anderson, A.; et a l. (1990) Captan: Dietary Toxicity

(LC50) Study with the Bobwhite Quail: Lab Project N umber: ISN 230/901123: ISN/230. Unpublished study prepared by Huntingdon R esearch Centre Ltd. 28 p.

43869803 Hakin, B.; Johnson, A.; Anderson, A.; et a l. (1990) Captan: Dietary Toxicity

(LC50) Study to the Mallard Duck: Lab Project Numbe r: ISN 229/901208: ISN/229. Unpublished study prepared by Huntingdon R esearch Centre Ltd. 28 p.

43869806 Kent, S.; Sankey, S.; Caunter, J.; et al. (1994) THPI: Acute Toxicity to Rainbow

Trout ( Oncorhynchus mykiss ): Lab Project Number: BL5237/B: AA0427/B. Unpublished study prepared by Zeneca Ltd., Brixham Environmental Lab. 19 p.

43869807 Rapley, J.; Hamer, M. (1993) Captan: Acute Toxicity of the Technical Material to

First Instar Daphnia magna : Lab Project Number: 91JH187: RJ1116B. Unpublished study prepared by ICI Agrochemicals, Je alott’s Hill Research Station. 16 p.

43869808 Kent, S.; Sankey, S.; Banner, A.; et al. ( 1994) THPI: Acute Toxicity to Daphnia41 magna : Lab Project Number: BL5239/B: AA0427/D. Unpublish ed study prepared by Zeneca Ltd., Brixham Environmental Lab. 18 p.

43869809 Smyth, D.; Sankey, S.; Tapp, J.; et al. (1990) Capt an: Toxicity to the Green Alga

Selenastrum capricornutum : Lab Project Number: BL3954/B: T505/C: FT78/90. Unpublished study prepared by Imperial Chemical Ind ustries PLC. 22 p.

43869810 Kent, S.; Sankey, S.; Morgan, D.; et al. ( 1994) THPI: Toxicity to the Green Alga

Selenastrum capricornutum : Lab Project Number: BL5238/B: AA0427/C. Unpublished study prepared by Zeneca Ltd., Brixham Environmental Lab. 22 p.

44148801 Stewart, K.; Tapp, J.; Sankey, S. et al. ( 1991) Captan: Chronic Toxicity to

Daphnia magna : (Final Report): Lab Project Number: T505/F: FT11/ 91: BL4102/B. Unpublished study prepared by Imperial Ch emical Industries PLC. 26

p.

44738801 Kelso, H.; Kent, S.; Morris, D. et al. (19 95) THP Am: Acute Toxicity to Rainbow

Trout ( Oncorhynchus mykiss ): Lab Project Number: AB0085/C: BL5445/B. Unpublished study prepared by Zeneca Limited. 19 p.

44806501 Drottar, K.; Krueger, H. (1999) Captan: A 96-Hour Toxicity Test with the

Freshwater Alga (

Anabaena flos-aquae ): Final Report: Lab Project Number: 493A-101A. Unpublished study prepared by Wildlife I nternational Ltd. 45 p. {OPPTS 850.5400}

44806502 Drottar, K.; Krueger, H. (1999) Captan: A 96-Hour Toxicity Test with the Marine

Diatom ( Skeletonema costatum ): Final Report: Lab Project Number: 493A-102. Unpublished study prepared by Wildlife Internationa l Ltd. 45 p. {OPPTS 850.5400}

44806503 Drottar, K.; Krueger, H. (1999) Captan: A 7-Day Toxicity Test with Duckweed

( Lemna gibba G3): Final Report: Lab Project Number: 493A-103. U npublished study prepared by Wildlife International Ltd. 44 p. {OPPTS 850.4400}

44806504 Drottar, K.; Krueger, H. (1999) Captan: A 96-Hour Static Acute Toxicity Test

with the Sheepshead Minnow ( Cyprinodon variegatus ): Final Report: Lab Project Number: 493A-104. Unpublished study prepared by Wil dlife International Ltd. 39 p. {OPPTS 850.1075}

44806505 Drottar, K.; Krueger, H. (1999) Captan: A 96-Hour Static Acute Toxicity Test

with the Saltwater Mysid ( Mysidopsis bahia ): Final Report: Lab Project Number: 493A-105. Unpublished study prepared by Wildlife In ternational Ltd. 39 p. {OPPTS 850.1035}

46061701 Boeri, R.; Wyskiel, D.; Ward, T. (2003) Ca ptan Technical: Oyster Shell

Deposition Test. Project Number: 2428/MA. Unpublish ed study prepared by T.R. Wilbury Laboratories, Inc. 35 p.

### Appendix A: Chemical Structures of Captan and

Table C- 1. Chemical Names and Structures of

Chemical Name

Captan 3a,4,7,7a-tetrahydro-2-[(trichloro methyl)thio]-1H-isoindole-1,3(2H)-
dione

THPI Tetrahydrophthalamide

THPAm Tetrahydrophthalimic acid

THCY Cis-6-cyano-3- cyclohexenecarboxylic
acid

THAPI (THAPL) Tetrahydrophthalic acid

THPA-Epoxide Tetrahydrophthalamide epoxide

5,6 dihydroxyhexaryohophthalamide (Diol)

42



### Chemical Structures of Captan and Its Degradates

1. Chemical Names and Structures of Diflubenzuron and its Degradates

Structure

cyclohexenecarboxylic

Structure not found and its Degradates43



### Appendix B: SIP (v 1.0) Inputs and Results

The purpose of this model is to provide an upper bo und estimate of exposure of birds and mammals to pesticides through drinking water alone. This model is intended for use in problem formulation to determine whether or not drinking water exposure al one is a potential pathway of concern. This does no t aggregate drinking water exposure with other exposu re routes (i.e., diet, inhalation, dermal).

Assumptions:

SIP employs the following conservative assumptions to derive upper bound exposure estimates:

1) The chemical concentration in drinking water is at the solubility limit in water (at 25 o C). 2) The assessed animals obtain 100% of their daily water needs through drinking water. 3) The daily water need is equivalent to the daily water flux rate as calculated by Nagy and Peterson (1988). 4) The body weight of the assessed bird is equivale nt to the smallest generic bird modeled in T-REX (i .e., 20 g). This assumption results in the highest ratio of exposure to toxicity for the 3 assessed avian b ody weights of T-REX (i.e., 20, 100, 1000 g).
5) The body weight of the assessed mammal is equiva lent to the largest generic mammal modeled in TREX (i.e., 1000 g). This results in the highest rat io of exposure to toxicity for the 3 assessed mamma lian body weights of T-REX (i.e., 15, 35, 1000 g).

Table 1. Inputs

Parameter Value

Chemical name captan Solubility (in water at 25 o C; mg/L) 3.3

Mammalian LD 50 (mg/kg-bw) 5000 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg-bw) 250 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg-bw) 1255 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) 1000 NOAEC (mg/kg-diet) for other bird species Body weight (g) of other avian species NOAEC (mg/kg-diet) for 2nd other bird species Body weight (g) of 2nd other avian species44

Table 2. Mammalian Results

Parameter Acute Chronic Upper bound exposure (mg/kg-bw) 0.5676 0.5676 Adjusted toxicity value (mg/kg-bw) 3845.8028 192.2901 Ratio of exposure to toxicity 0.0001 0.0030

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) 2.6730 2.6730 Adjusted toxicity value (mg/kg-bw) 904.1390 49.6126 Ratio of exposure to acute toxicity 0.0030 0.0539

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 ro utes ( i.e ., diet, inhalation, dermal), pesticide exposure through drinking water may contr ibute to a total exposure that has potential for effects to non-target animals.45



### Appendix C: STIR (v 1.0) Inputs and Results



## Welcome to the EFED Screening Tool for Inhalation Risk

This tool is designed to provide the risk assessor with a rapid method for determining the potential significance of the inhalation exposu re route to birds and mammals in a
risk assessment.



## Input

Application and Chemical Information

Enter Chemical Name captan
Enter Chemical Use 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) 300.57 Enter Chemical Vapor Pressure (mmHg) 8.00E-08 Enter Application Rate (lb a.i./acre)

Toxicity Properties

Bird

Enter Lowest Bird Oral LD 50 (mg/kg bw) 1255 Enter Mineau Scaling Factor 1.15 Enter Tested Bird Weight (kg) 0.178

Mammal

Enter Lowest Rat Oral LD 50 (mg/kg bw) 5000

Enter Lowest Rat Inhalation LC 50 (mg/L) 0.72 Duration of Rat Inhalation Study (hrs) 4 Enter Rat Weight (kg) 0.35



## Output

Results Avian (0.020 kg ) Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 1.29E-03 Maximum 1-hour Vapor Inhalation Dose (mg/kg) 1.63E-04

Adjusted Inhalation LD 50 1.01E+00

Ratio of Vapor Dose to Adjusted Inhalation LD 50 1.61E-04 Exposure not Likely Significant Maximum Post-treatment Spray Inhalation Dose (mg/kg) 0.00E+00 Ratio of Droplet Inhalation Dose to Adjusted
Inhalation LD 50 0.00E+00 Exposure not Likely Significant

Results Mammalian (0.015 kg )

Maximum Vapor Concentration in Air at Saturation 1.29E-0346

(mg/m 3 )
Maximum 1-hour Vapor Inhalation Dose (mg/kg) 2.04E-04

Adjusted Inhalation LD 50 4.29E+01

Ratio of Vapor Dose to Adjusted Inhalation LD 50 4.77E-06 Exposure not Likely Significant Maximum Post-treatment Spray Inhalation Dose (mg/kg) 0.00E+00 Ratio of Droplet Inhalation Dose to Adjusted
Inhalation LD 50 0.00E+00 Exposure not Likely Significant